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HomeMy WebLinkAbout01-5077 ROBERT L. KECK, JR., Plaintiff PATRICIA A. KECK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAN NO. 2001- '~i'~-7':]' CIVIL TERM CIVIL ACTION - LAW : : IN DIVORCE NOTICE~TO D_EFEN_D AND CLAIM RI------~.~HTS 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. Ajudgment may also be entered against you for any other claim or reliefreq 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 that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. 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 WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 SNELBAKER BRENNEMAN SPARE SNELBAKER, BRENNEMAN & SPARE, P.C. Attorneys for Plaintiff ROBERT L. KECK, JR., Plaintiff V. PATRICIA A. KECK, Defendant : 1N THE COURT OF COMMON PLEAS OF ! CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001- 50'77 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT COUNT I - DIVORC~ 1. Plaintiff ROBERT L. KECK, JR. is an adult individual residing at 128 E. Locust Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant PATRICIA A. KECK is an adult individual residing at 4600 Warrington Avenue, Apartment 2, Mechanicsburg, Cumberland County, Pennsylvania. 3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were latvfully joined in marriage on February 9, 2001 in Carlisle, Cumberland County, Pennsylvania. SPARE 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction since the date of the marriage averred in Paragraph 4, above. 6. Neither party is a member of the armed forces of the United States of America. 7. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. 8. The Plaintiffhas 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. The Plaintiffrequests this Court to enter a decree of divorce. WHEREFORE, ROBERT L. KECK, JR. requests this Court to enter a Decree of Divorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between the Plaintiff and Defendant. SNELBAKER, BRENNEMAN & SPARE, P.C. Date: August 27, 2001 Keith O. Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055-0318 (717) 697-8528 Attorneys for Plaintiff Robert L. Keck, Jr. BRENNEMAN SPARE -2- VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4909 relating to unsworn falsification to authorities. Date: Robert L. Keck, Jr. ROBERT L. KECK, JR., Plaintiff V. PATRICIA A. KECK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNS' NO. 2001- : CIVIL ACTION - LAW : : IN DIVORCE CIVIL TERM AF__._FIDAVI~T I, ROBERT L., KECK, JR., being duly sworn according to law, depose and say: 1. I have been advised °f the availability of marriage counseling and understand that i may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do _NOT_ request that the court require my spouse and I participate ~n counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. LAW Of F{CES SNELBAKER. BRENNEMAN & SPARE Robert L. Keck, Jr. (Plaintiff) LAW OFFICES SNELBAKER, BRENNEMAN & SPARE ROBERT L. KECK, JR., Plaintiff PATRICIA A. KECK, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-5077 CIVIL TERM : CIVIL ACTION - LAW : : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) Keith O. Brenneman, Esquire, being duly sworn according to law deposes and says: thai he is a principal in the law finn of Snelbaker, Brenneman & Spare, P. C., being the attorneys fm Robert L. Keck, Jr., Plaintiff in the above captioned action in divorce; that on August 31, 2001, he did send to Defendant Patricia A. Keck by certified mail, return receipt requested, restricted delivery, a duly certified copy of the Complaint in Divorce which was filed in the above captioned action as evidenced by the attached cover letter of the same date and Receipt for Certified Mail No. 7000 1670 0008 5047 3077; that both the Complaint and cover letter were duly received by Patricia A. Keck, the Defendant herein, as evidenced by the return receipt card for said certified mail dated September 1, 2001; that a copy of the aforementioned cover letter dated August 31, 2001 is attached hereto and incorporated by reference herein as "Exhibit A" and that the original Receipt for Certified Mail and the Domestic Return Receipt are attached hereto and incorporated by reference herein as "Exhibit B"; and that the foregoing facts are true LAW OFFICES SNELBAKER, BRENNEMAN & SPARE and correct to the best of his knowledge, information and belief. Keith O. Brenneman Sworn to and subscribed before me this 5th day of September, 2001. -2- LAW OFFICES SNELBAKER. BReNNEMAN & SPaRe (Endomement Required} I . 5 0 (Endorsement Required) 3 * 2 0 Patricia A. Keck '~ State, ZIP+4 · Ce~plete Items 1, 2, and 3. Also complete I~m 4 tf Restricted Delivery is desired. · I~t your name and address on the reveres eo that we can return the card to you. · Altech-this card to the back of the mailpiece, o~on the front if space permits. 1. ~'tic~ Addressed to: Patricia A. Keck Apartment 2 4600 WarringtonAvfldue Mechanicsburg, PA 17055 A. Received by (P/ease Print C/ear/y) [] Age~ [] Ad~:; ~ D. Is detlve~y eddmss d~nt from item l ? [] Yes ~f YES, enter delivery address below: [] No 2. Article Number (Copy from service labe0 PS FOrm 38111 JuN' 1999 3. Service Type ]~ Certified Mall [] Registered r-i Insured Mail [] Express Mail [] Return R~ceipt for Merctt~t~e [] C.O.D. /uuu z6/O UOOo 504~ 3077 Domestic Return Receipt 102595-00-M.0952 EXHIBIT B SNELBAKER, BRENNEMAN & SPARE ROBERT L. KECK, JR., Plaintiff V. PATRICIA A. KECK, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-5077 CIVIL TERM : CIVIL ACTION - LAW : : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 30, 2001. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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. 4. 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 authorities. Robert L. Keck, Jr. (Plaintiff) LAW OFFICES SnEIBAKER. BRENNEMAN & SPARE ROBERT L. KECK, JR., Plaintiff V. PATRICIA A. KECK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-5077 CIVIL TERM : CIVIL ACTION - LAW : : IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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. 4. 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 unswom falsification to authorities. Date: '~Ro~, Jr. (Plaintiff) SNELBAKER. BRENNEMAN & SPARE ROBERT L. KECK, JR., Plaintiff Vo PATRICIA A. KECK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2001-5077 CIVIL TERM : CIVIL ACTION - LAW : : 1N DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 30, 2001. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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. 4. I verify that the statements made in this Affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to unswom falsification to authorities. Date: 12- -01 Patricia A. Keck (Defendant) LAW OFFICES SNELBAKER. BRENNEMAN & SPARE ROBERT L. KECK, JR., Plaintiff PATRICIA A. KECK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-5077 CIVIL TERM : CIVIL ACTION - LAW : : IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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. 4. 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 authorities. Date: Patricia A. Keck (Defendant) ROBERT L. KECK, JR., Plaintiff IN THE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY STATE OF PENNA. VERSUS PA~"R T~.T A A_ Defendant NO. 2001-5o77 CIVIL DECREE iN DIVORCE AND NOW,~~~~-~/~ /~_ , IT IS ORDERED AND DECreED That ROBERT L. KECK. JR. , PLaINtiff, AND PATRICIA A. KECK , 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; NONE. By T ATTEST: PROTHONOTARY LAW OFFICES SNEIBAKEr. BRENNEMAN & SPARe ROBERT L. KECK, JR., Plaintiff Vo PATRICIA A. KECK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2001-5077 CIVIL TERM : CIVIL ACTION - LAW : : 1N DIVORCE PRAECIPE TO TRANSMIT RECORD TO: Prothonotary of Cumberland County: Please 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 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: by certified mail, restricted delivery on Defendant on September 1,2001 (see Affidavit of Service filed September 6, 2001). 3. Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: by the Plaintiff.' December 10, 2001; by the Defendant: December 8, 2001. 4. Date of execution of Waiver of Notice in Section 3301(c) Divorce: by the Plaintiff: December 10, 2001; by the Defendant: December 8, 2001. 5. Related pending claims: None. Date: SNELBAKER, BRENNEMAN & SPARE, P. C. By: ~ Attorneys for Plaintiff