Loading...
HomeMy WebLinkAbout05-0714John W. Purcell, Jr. I.D. 29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell@pkh.com JOHN R. KELLER, Plaintiff vs. TINA M. KELLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OS'- Y14/ C/ vL* L7£-e-k7lq CIVIL ACTION-LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Room 101, Dauphin County Courthouse, Front and Market Streets, Harrisburg, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 North Front Street Harrisburg, PA 17101 (717) 232-7536 John W. Purcell, Jr. I.D. 29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell@pkh.com JOHN R. KELLER, vs. TINA M. KELLER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff NO. OS- to'c CIVIL ACTION-LAW IN DIVORCE Defendant COMPLAINT IN DIVORCE AND NOW COMES Plaintiff, John R. Keller, by his attorneys, Purcell, Krug & Haller, and avers as follows: DIVORCE PURSUANT TO SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is John R. Keller, an adult individual whose current address is 35 Lake Meade Drive, East Berlin, Adams County, Pennsylvania 17316-9234. 2. Defendant is Tina M. Keller, an adult individual whose current address is 509 West Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania 17055-3765. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on December 18, 1993, in New Cumberland, Pennsylvania. 5. There have been no prior actions in divorce or annulment between the parties. 6. The Plaintiff avers that there are three children of the parties under the age of 18: Karissa Caye Keller, born October 2, 1990, Sarah Ann Keller, born November 16, 1996 and Rachael Marie Keller, born June 10, 1999. 7. Neither of the parties in this action is presently a member of the Armed Forces. 8. The Plaintiff and Defendant are both citizens of the United States. 9. The Social Security Number of the Plaintiff is 183-66-3214 and the Social Security Number of the Defendant is 184-48-3058. 2 10. The marriage is irretrievably broken. 11. Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree in Divorce. PURCELL, KRUG & HALLER By. ohn .Purcell, Jr., Esquire ID ## 955 9 North Front Street Harrisburg, PA 17102 Dated:.` -O - ?S (717) 234-4178 3 VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Dated: February 7, 2005 y ^ ^ j L John R. Keller ? T ) c? v ? CO ` CA { r S c-? r. i U John W. Purcell, Jr. I.D. 29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 ipurcell(a)pkh.com JOHN R. KELLER, Plaintiff VS. TINA M. KELLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05- CIVIL TERM -ql CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) ss: COUNTY OF DAUPHIN I, Carol Masich, secretary to John W. Purcell, Jr., Attorney for the Plaintiff in the above action, hereby swear and affirm that on the 10' day of February, 2005 I sent, by certified mail, return receipt requested, deliver to addressee only, a certified copy of the Complaint in Divorce, containing Notice to Defend and Claim Rights to Tina J. Keller, the Defendant in the above action. The return receipt, duly signed by the Defendant is attached hereto and made a part hereof as Exhibit " A". .- ti?t;? v Carol Masich Secretary to John w. Purcell, Jr. Sworn and subsc, to befor e t s S-V Of 2005. Notary Public Notarial Seal Bonita E. Prussack, Notary Pubfio City of Harrisburg, DaaPhin County My commission Expires Sept. 26, 2005 Member, Pe,insylvania Association of Notaries ¦ Complete Items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: S??WeS??ivn?ohS? (11-ec?d,v?? cs\ov?K??? \(\oss -J)bs A. B. Received by (Printed Name) C. Date of Delivery /to D. Is delivery ad ress d' 17 d Yes If YES, enter deli3 vr.;\ ? No ??,', FEB 2 4 2005 4 3. Service Type Certified Mall ail Certified ? Return Receipt for Merchandise ? Insured Mail Q C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number rr?-? t\Q- r-? (Transfer from service label) ?(? GQ vC9(7a- - \ .r- PS Form 3811, August 2001 Domestic Return Receipt 102595-02-M-1590 U.S. Postal Service e CE (Domestic MaRTIFIED MAIL RECEIPT il Only; No insurance CoveragProvided) M 0' Postage $ O Certilled Fee Return Receipt Fee Postmark rut C3 (Endorsement Requiredl ____ __ _ Here 0 Restricted Delivery Fee p (Endorsement Required) 4_-_ r3 Total Postage & Fees .p -_ - _ .-D S gent To -- ----- ---- --- ---- fll Street, Apt. No., .... .....; .................... .......... C3 or PO Box No. 1 ::3 _W ?_lti. ?_Yx•x M1 Clty, State !Pr 4 :rt lr Exhibit "A" a -- \? .? ?/? ?f A JOHN R. KELLER, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, :PENNSYLVANIA V. NO. 05-714 CIVIL TERM TINA M. KELLER, Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of the Family Law Clinic on behalf of the Defendant, Tina M. Keller, in the above captioned matter. /9 2005 l Burgess C. Bradshaw Certified Legal Intern Robert E. Rains Thomas M. Place Lucy Johnston-Walsh Ann MacDonald-Fox Supervising Attorneys Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 fax: (717) 243-3639 _ r?? c-? r _1 _. S.. ? "?. i:__ t.w ". JOHN R. KELLER, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, :PENNSYLVANIA V. NO. 05-714 CIVIL TERM TINA M. KELLER, Defendant : CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Burgess Bradshaw, hereby certify that I am serving a true and correct copy of a praecipe to enter appearance on the following person, counsel for plaintiff, by depositing a copy of the same in the United States mail, postage prepaid, this 19a' day of April, 2005. John W. Purcell, Jr. Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 Burgess C. Bradshaw Certified Legal Intern THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 (1 r.? . ? -? t ^ t :; -. JOHN R. KELLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE TINA M. KELLER, Defendant : No. 05-714 CIVIL TERM PETITION FOR LEAVE TO WITHDRAW Petitioner, the Family Law Clinic, hereby petitions to withdraw from further representation of Tina M. Keller, pursuant to Rule 1.16(b) (1) and (5) of the Pennsylvania Rules of Professional Conduct and Pa.R.C.P. 1012, and in support therefore avers the following: 1. On April 19, 2005, the Family Law Clinic filed a Praecipe to Enter Appearance on behalf of Tina M. Keller. 2. Since January of 2006, the Family Law Clinic has continually made numerous unsuccessful efforts to contact Ms. Keller. Because The Clinic is unable to reach Ms. Keller, the Family Law Clinic is unable to represent her adequately. 3. The last known address for Tina M. Keller is 8 West Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 4. As there are currently no hearings pending in this matter, withdrawal can be accomplished without adverse effect on the interests of Ms. Keller. 5. Pursuant to C.C.R.P. 208.2(d), the concurrence of opposing counsel, John W. Purcell, Jr., Esq., has been sought. Opposing counsel does not concur. WHEREFORE, the Family Law Clinic requests permission to withdraw as counsel for Tina M. Keller in this matter. Respectfully submitted, G? / c Date Krista Ann Freego Certified Legal Intern --V44-,, UA, 4 - ?4 Thom lace Robert E. Rains Anne MacDonald-Fox Lucy Johnston-Walsh Megan Riesmeyer Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 JOHN R. KELLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE TINA M. KELLER, : Defendant : No. 05-714 CIVIL TERM CERTIFICATE OF SERVICE I, Krista Ann Freego, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy of a Petition for Leave to Withdraw on the following persons by first class United States mail, postage prepaid, the Jam day of ?ftwbxe( , 2006: Tina M. Keller, residing at 8 West Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania 17055, and John W. Purcell, Jr., Esq., at 1719 North Front Street, Harrisburg, Pennsylvania 17102. e?7 Krista Ann Freego Certified Legal Intern ANNE AUDONALD-FOX- LUCY JOHNSTON-WALSH MEGAN RIESMEYER THOMAS M. PLACE ROBERT E. RAINS Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, Pa 17013 717/243-2968 SEP 1 `, 2006 BY.- R. KELLER, JOHN Plaintiff V. TINA M. KELLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : No. 05-714 CIVIL TERM ORDER OF COURT-RULE TO SHOW CAUSE i AND NOW, this ?J day of _ 6, upon consideration of the foregoing petition, it is hereby ordered that (1) a rule is issued upon Tina M. Keller to show cause why the Family Law Clinic should not be granted leave to withdraw as counsel of record; (2) Tina M. Keller shall file an answer to the petition within twenty days of service upon her; (3) the petition shall be decided under Pa.R.C.P. No. 206.7; (4) notice of the entry of this order shall be provided to all parties by the Family Law Clinic. J. ? 1. 1 SI i) j r` , 1 T -,__.. _ :? -t JOHN R. KELLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE TINA M. KELLER, Defendant : No. 05-714 CIVIL TERM CERTIFICATE OF SERVICE I, Krista Ann Freego, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy of Order of Court- Rule to Show Cause on the following persons by first class United States mail, postage prepaid, the 6 day of October, 2006: Tina M. Keller, residing at 8 West Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania 17055, and John W. Purcell, Jr., Esq., at 1719 North Front Street, Harrisburg, Pennsylvania 17102. ------ N Kri,6ta Ann Freego Certified Legal Inter r? - ANNE LD-FOX LUCY JO NSTON-WALSH MEGAN RIESMEYER THOMAS M. PLACE ROBERT E. RAINS Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, Pa 17013 717/243-2968 hJ ?i ??„) _ C?'? _ ? M.y --? ? tl ?r- j-; ??? l,! ;.:+ '`, r .' :. JOHN R. KELLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE TINA M. KELLER, Defendant : No. 05-714 CIVIL TERM PETITION TO MAKE RULE ABSOLUTE UNDER Pa.R.C.P. No. 206.7 Petitioner, the Family Law Clinic, petitions the Court as follows: 1. Petitioner, the Family Law Clinic, is counsel of record for the above named Defendant, Tina M. Keller. 2. Petitioner filed a Petition for Leave to Withdraw in this matter on September 12, 2006. On September 15, 2006, this Court issued an Order of Court - Rule to Show Cause. A copy of the Petition and Rule to Show Cause Order are attached hereto and incorporated herein by reference as Exhibit "A." 3. The September 15, 2006 Order of Court - Rule to Show Cause permitted Respondent, Tina M. Keller, to object to the Family Law Clinic's request to withdraw as her counsel by filing an answer to the Petition within twenty (20) days after service of the Order upon her. 4. A true and correct copy of the Petition for Leave to Withdraw was served upon Respondent, Tina M. Keller, by first class mail, postage prepaid, at her last known address on September 12, 2006. A true and correct copy of the Petition was served upon counsel for Plaintiff on the same date. 5. A true and correct copy of the Order of Court - Rule to Show Cause was served upon Respondent, Tina M. Keller, by first class mail, postage prepaid, at her last known address on October 6, 2006. A true and correct copy of the Order of Court - Rule to Show Cause was served upon counsel for Plaintiff on the same date. 6. More than twenty (20) days have passed since the Order of Court - Rule to Show Cause was served upon the Respondent and Plaintiff's counsel, and no response or objection has been filed. 7. Pursuant to C.C.R.P. 208.2(d), the concurrence of opposing counsel, John W. Purcell, Esq., has been sought. Opposing counsel does not concur. WHEREFORE, the Family Law Clinic requests this Court to enter an Order permitting the Family Law Clinic to withdraw as counsel for Tina M. Keller in this matter. Date: it is 106 Respectfully, Krista Ann Freego Certified Legal Intern THO LACE ROBERT t. RAINS LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. I //0 Da Kris#a Ann Freego Certified Legal Int JOHN R. HELLER, Plaintiff V. TINA M. KELLER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE : No. 05.714 CIVIL TERM PETITION FOR LEAVE TO WITHDRAW Petitioner, the Family Law Clinic, hereby petitions to withdraw from further representation of Tina M. Keller, pursuant to Rule 1.16(b) (1) and (5) of the Pennsylvania Rules of Professional Conduct and Pa.R.C.P. 1012, and in support therefore avers the following: 1. On April 19, 2005, the Family Law Clinic filed a Praecipe to Enter Appearance on behalf of Tina M. Keller. 2. Since January of 2006, the Family Law Clinic has continually made numerous unsuccessful efforts to contact Ms. Keller. Because The Clinic is unable to reach Ms. Keller, the Family Law Clinic is unable to represent her adequately. 3. The last known address for Tina M. Keller is 8 West Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 4. As there are currently no hearings pending in this matter, withdrawal can be accomplished without adverse effect on the interests of Ms. Keller. 5. Pursuant to C.C.R.P. 208.2(d), the concurrence of opposing counsel, John W. Purcell, Jr., Esq., has been sought. Opposing counsel does not concur. WHEREFORE, the Family Law Clinic requests permission to withdraw as counsel for Tina M. Keller in this matter. Date_ q11"? o(o Respectfully submitted, c Krista Ann Freego Certified Legal Intern Thom ace Robert E. Rains Anne MacDonald-Fox Lucy Johnston-Walsh Megan Riesmeyer Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 JOHN R. KELLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : IN DIVORCE TINA M. KELLER, . Defendant : No. 05-714 CIVIL TERM CERTIFICATE OF SERVICE I, Krista Ann Freego, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy of a Petition for Leave to Withdraw on the following persons by first class United States mail, postage prepaid, the Q4?k day of st -evA+ C, 2006: Tina M. Keller, residing at 8 West Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania 17055, and John W. Purcell, Jr., Esq., at 1719 North Front Street, Harrisburg, Pennsylvania 17102. 1 _..? Krista Ann Freego Certified Legal Intern ??-q 4ez? - A6 ANNE NALD-F LUCY JOHNSTON-WALSH MEGAN RIESMEYER THOMAS M. PLACE ROBERT E. RAINS Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, Pa 17013 717/243-2968 .?, L? -:? i:? t? ; -:-, ?_. ' ?',i L.: ti -' . _ c.. ?? REC'' F' • ? w' ?'_ ' . SEP 1 ' 1006 JOHN R. KELLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : IN DIVORCE TINA M. KELLER, Defendant : No. 05-714 CIVIL TERM ORDER OF COURT-RULE TO SHOW CAUSE i AND NOW, this O day of , upon consideration of the foregoing petition, it is hereby ordered that (1) a rule is issued upon Tina M. Keller to show cause why the Family Law Clinic should not be granted leave to withdraw as counsel of record; (2) Tina M. Keller shall file an answer to the petition within twenty days of service upon her; (3) the petition shall be decided under Pa.R.C.P. No. 206.7; (4) notice of the entry of this order shall be provided to all parties by the Family Law Clinic. J. 3 k°•?'+ ., , ..? ?... JOHN R. KELLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE TINA K. KELLER, Defendant No. 05-714 CIVIL TERM CERTIFICATE OF SERVICE I, Krista Ann Freego, Certified Legal Intern, the Family Law Clinic, hereby certify that I am serving a true and correct copy of Order of Court- Rule to Show Cause on the following persons by first class United States mail, postage prepaid, the 6 day of October, 2006: Tina M. Keller, residing at 8 West Simpson Street, Mechanicsburg, Cumberland County, Pennsylvania 17055, and John W. Purcell, Jr., Esq., at 1719 North Front Street, Harrisburg, Pennsylvania 17102. ?•---? ?? Kri to Ann Freego Certified Legal Inter ANNE LD-FOX ` LUCY JO NSTON-WALSH MEGAN RIESMEYER THOMAS M. PLACE ROBERT E. RAINS Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, Pa 17013 717/243-2968 C'? ? ? t r ??? .-a r i? ? ??; ?, C7 ? i ` ?. -14. "_ ? , t `? rte .? `...-i ? ?" - ..{ ?' r-? -= _.? ?? :?: ?_ _ ., ._ :?. __-- _,? Nov ao 20M af f JOHN R. KELLER, Plaintiff V. TINA M. KELLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE No. 05-714 CIVIL TERM ORDER OF COURT AND NOW, this ? day of A)PI14e , 2006, upon consideration of the attached Petition To Make Rule Absolute, leave is granted to the petitioner, the Family Law Clinic, to withdraw as counsel for Defendant Tina M. Keller. J. L? 17 "fix d iaf f / 11 r ';I try JOHN R. KELLER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. TINA M. KELLER, Defendant NO. 05-0714 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the divorce Code was filed on February 9, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final dec divorce after service of notice of intention to request entry of the dec ?Vvl Date: G Tina M. Keller 11 WAIVER OF NOTICE OF INTENTION TO REG ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit and Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsw a s n to authorities. Date: 7 "C?b?j ?f /cam, Tina M. Keller Gw?3 r CY ,y ?..' .7 in ?- JOHN R. YELLER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. TINA M. KELLER, Defendant NO. 05-0714 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the divorce Code was filed on February 9, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to aut Date: /)?/Ix A pyU7 PlIn R. Kell r WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are "made subject to penalties o P8 Pa. C.S. § 4904 relating to unsworn falsification tR? th3otie* ? Date: r? b m R. Keller ?_ ?y ??, _. C.",r??Jy t °" 't_. ?? fjx C?' ? G `?.??. JOHN R. KELLER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 05-0714 CIVIL TERM TINA M. KELLER, : CIVIL ACTION-LAW Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: Irretrievable breakdown under Section (x) 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: February 24, 2005 by Certified Mail 3. (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: by Defendant: May 16, 2007 April 23, 2007 (b) (1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiffs Affidavit upon the Defendant: 4. Related claims pending: No economic claims have been raised. 5. (a) Date and manner of service of the Notice of Intention to file Praecipe to transmit record, a copy of which is attached: (b) Date of Plaintiff's Waiver of Notice in 3301(c) Divorce was filed with Prothonotary: Filed contemporaneously herewith Date of Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: May 10, 2007 JOHO1 W. PVRCELL, JR. ESQ. co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ell STATE OF PENNA. JOHN R. KELLER N O. 05-0714 CIVIL VERSUS TINA M. KELLER Defendant DECREE IN DIVORCE AND NOW, 2007 , IT IS ORDERED AND DECREED THAT John R. Keller PLAINTIFF, AND Tina M. Keller ,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; A oaE TH ATT,QST: / A --? I J PRoFrHC/N/ITARY rr„n' r ca - Sf Lo - s- f