Loading...
HomeMy WebLinkAbout05-0892Michael S. Travis Attorney at Law ID No.77399 3904 Trindle Road Camp Hill, PA 17011 717-731-9502 In the Court of Common Pleas of Cumberland County, Pennsylvania RONALD A. KEISTER, ) Plaintiff, ) VS. ) No. 2005 - THERESA M. KEISTER, ) CIVIL TERM Defendant. ) 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 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 at: Office of the Prothonotary Cumberland County Courthouse Carlisle, Pennsylvania 17013 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 In the Court of Common Pleas of Cumberland County, Pennsylvania RONALD A. KEISTER, ) Plaintiff, ) VS. ) No. 2005 - THERESA M. KEISTER, ) CIVIL TERM Defendant. ) IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Michael S. Travis ID No. 77399 3904 Trindle Road Camp Hill, PA 17011 (717) 731-9509 In the Court of Common Pleas of Cumberland County, Pennsylvania RONALD A. KEISTER, ) Plaintiff, ) VS. ) No. 2005 - THERESA M. KEISTER, ) CIVIL TERM Defendant. ) IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE Plaintiff, by his attorney Michael S. Travis, respectfully represents: Plaintiff is Ronald A. Keister, who resides at P.O. Box 51, Summerdale, Cumberland County, Pennsylvania, 17093, since October 2002. 2. Defendant is Theresa M. Keister, who resides at RD1 Box 3588, Sugar Run Road, Millerstown, Perry County, Pennsylvania, 17062, since 1994. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. The Plaintiff and Defendant were married on July 23, 1994, in Perry County, Pennsylvania. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. The marriage is irretrievably broken. The parties have been living separate and apart. At a subsequent time, Plaintiff may submit an Affidavit that the parties have lived separate and apart for at least two (2) years. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. Neither party is in the Military Service in the United States. 10. Plaintiff requests the court to enter a decree of divorce. I verify that the statements made in this Complaint are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. Date: 2-G f Ronald A. Keister, Plamtif Michael S. Travis Attorney for Plaintiff I.D. # 77399 3904 Trindle Road Camp Hill, PA 17011 (717) 731-9502 Fax 731-9511 rk M? ? 1 V t ' l 1 Curtis R. Long Prothonotary (Office of the Protbonotarp Cumberranb Cauntp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor J?) 5 - S 4.,2 -CIVIL TERM o ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA RCP230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573