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Home My WebLink About05-2208d E V'ILESVDATAFII,LIGwemlACwn:nN 137129_wm CaaLed. 920104 0.0611M R,,i,,d 3/31105 11.46AM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD, 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff BRIAN KEESEMAN IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05- 7 C'8 CIVIL ACTION - LAW TINA KEESEMAN, 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 Plainti ff. 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. Upon your request, the Court may require you and your spouse to attend up to three sessions. A request for counseling must be made in writing and filed with the Prothonotary within twenty (20) days of receipt of this Notice. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone:(717) 249-3166 BRIAN KEESEMAN IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. TINA KEESEMAN, Defendant NO. 05- 2,2 U (c i• l i?- CIVIL ACTION - LAW IN DIVORCE DIVORCE COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE Plaintiff is Brian Keeseman, who currently resides at 408 Nealy Road, Newville, Cumberland County, Pennsylvania. 2. Defendant is Tina Keeseman, who currently resides at 12 East Main Street, Plainfield, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiffand Defendant were married on April 13, 2002, in Cumberland County, Pennsylvania. 5. The parties were previously divorced on March 13, 1998, Docket No. 97-02575, in the Court of Common Pleas of Cumberland County. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, Plaintiff prays your Honorable Court to issue a Decree of Final Divorce pursuant to Section 3301 (c) of the Divorce Code. COUNTI CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 9. The allegations of Paragraphs 1 through 8 hereof are incorporated hereby referenced. 10. Plaintiff and Defendant are the joint owners as tenants by the entireties ofcertainreal estate which is subject to equitable distribution by this Court. 11. Plaintiff and Defendant aretheowners ofvarious items of personal property, furniture and household furnishings acquired during their marriage which are subject to equitable distribution by this Court. 12, Plaintiff and Defendant are the owners of various motor vehicles and bank accounts acquired during their marriage which are subject to equitable distribution by this Court. WHEREFORE, Plaintiff requests the Court to determine and equitable distribute, divide or assign said marital property pursuant to §3502 (a) of the Divorce Code. MARTSON DEARDORFF WILLIAMS & OTTO By _ Jennifer L. *rssquire 10 East High Street Carlisle, PA 17013 (717) 243-3341 Date: ??2? Attorneys for Plaintiff VERIFICATION The foregoing Divorce Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I maybe subject to criminal penalties. Brian Keeseman v L .y g C.l C .... ' „ rn- . r ta n co j? ii FAPILESVDATAFILCenerzACur [AI 13]1.29. ws Created 9/20!04 006PM Revised. 5/2/05 3:41PM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street (Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff KEESEMAN IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 05- 0Zo708 CIVIL ACTION - LAW A KEESEMAN, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF PENNSYLVANIA ) : SS. OF CUMBERLAND I hereby certify that a copy of the Complaint in Divorce was mailed to Defendant Tina eeseman at 12 East Main Street, Plainfi estricted delivery, return receipt requested. I eld, PA 17081 on April 29, 2005, by certified mail, Attached is the Post Office return receipt signed "Tina Keeseman" and dated April 30, 2005. i to and subscribed me this,5,,' day of 2005. CC.- COMMONWEALTH OF PENNSYLVANIA /AVW --- Jenn fer V. Spears, Esquire Notarial Seal Mary M. Price, Notary Public Carlisle Boro, Cumberland County My Commission Expires Aug. 18, 2007 AAemher pnnne/ ivarra AssxjjtR,n of Notaries i ?D O a / ra Postage $ rl M GedHled Fee R) Ree?Y1R ? Cl 1 Return Rempt Fee (Endorsement Required) M ReStrioted Pelve Fee i d) q C i J r9 C3 re u (Endorsement Re C r? $ 6 Fees B.15 J L ^ ? Total Postage ? I ^ m p p sent ro Mo.; Street, APt. -- -- • i Q n L /??A. A ¦ Complete items 1, 2, and 3. Also complete A. Signal to item 4 if Restricted Delivery is desired. X t(/J? ? Agent r ¦ Print your name and address on the reverse r B+Aaaressee so that we can return the card to you. ¦ Attach this card to the back of the mallplece, S. Received by PNnted Nerve) Kff S C. Date of Delivery or on the front if space permits. Q 1. Article Addressed to: D. is delivery address different from Item 19 ...????,,,///??`Y'''ee ( if YFS, enter delivery address below: No la ?ftz'?acc,??ut ,Oid, 9/? l Y0/4 17681 3. Service Type // -$CedffW Mail 0 Expreas Mail 0 Registered 0 Return Receipt for Merchandise 4.. Restricted Delivery? (Extra Fee) 'Wes 2. Article Number 7003 1010 0001 1188 7842 (Tianeler from aeMce ftW, PS Form 3811, August 2001 Domestic Retum Receipt IOMS-024A4540 • LISPS - Track & Confirm 0, MNITEMATES Page 1 of 1 ?:t? `€ w' ". ' i? i`"ti " :r" ? .r' i ?.,. >b r , ?sik`11t;mSi;,? "WINT s ` 102"M fI ' ? ` Track & Confirm Current Status You entered 7003 1010 0001 1188 7842 Your item was delivered at 11:48 am on April 30, 2005 in PLAINFIELD, PA 17081. i s8tpnuemi oeralis> } Notification Options / Track & Confirm by email what is this? .. Go> Track & Confirm Enter label number: Track & Confirm FAQs ' POSTAL INSPECTORS site map contact us government services Preserving the Trust Copyright O 1999-2002 LISPS. All Rights Reserved. Terms of Use Privacy Policy http://trkenfrml.smi.usps.com/netdata-cgi/db2www/cbd 243.d2w/output 5/2/2005 r'? ?-, "' o ?. _ ? ? -?, __ .? _r = ;', - ? i? vc_ ,, ,... L ._ , Curtis R. Long Prothonotary (OffltC of the Protbonotarp Cumberlanb CountP Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER NO RESPONSE?THEOABOVOEF INTENTION TO PROCEED AND RECEIVING CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R. C P 230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573