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HomeMy WebLinkAbout05-4070 CHRISTIAN B. KELLER Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2005- )(070 cw.; DEBORAH E. B. KELLER, 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 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013, Phone: (717) 240-6195. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 CHRISTIAN B. KELLER Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2005 - 101<> ~..J~ DEBORAH E. B. KELLER, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(C) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Christian B. Keller, who currently resides at 1054 Rebecca Street, Carlisle (North Middleton Township), Cumberland County, Pennsylvania, since July 2003. 2. Defendant is Deborah E. B. Keller, who currently resides at 1054 Rebecca Street, Carlisle (North Middleton Township), Cumberland County, Pennsylvania, since July 2003. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 7, 2000 in Lexington, Virginia. 5. There have been no prior actions of divorce or for annulment between the parties. 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. I verify that the statements made in this Complaint 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. ~i~.~~ Christian B. Kel er Date: F /<J/t5S , f Dale Supreme 35 East High Street, Carlisle, PA 17013 (717) 241-4311 203 ~ ~ 0 ...., ~ ~ ~ c.: = ~ = :;::- "" ol\.. :n. <::::;; ~ ;:WD """ ~ ~ ZL: c: ~ ~ f _ . ..T:l <n ~~ - Z["- r;;-- w;;.~: I ~ ~C \D :0 -....J ~ 0 ~' "l~ \.,oJ , ~8 " 2j:H c::. ~ " :x: >c: "7(") - - N Om ~ ~ ~ .. '4 ~ VI -.< ~ vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2005- Lj-D7 D CHRISTIAN B. KELLER Plaintiff DEBORAH E. B. KELLER, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint. A true and correct copy thereof has been delivered to me by Dale F. Shughart, Jr., Esquire. Date: August 10, 2005 ~j~f:.I3.~f'~N Deborah E. B. Keller (') S -::: ~rf:; IT~r~' :.::: ..~' I:, ~ ....., <::> = c.n ;po c:: (n ~ !~ g~ -,-..,.., 00 Om ~ '-< (Jl '"'0 -''''' ~.. ~ o CHRISTIAN B. KELLER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 2005 - 4070 DEBORAH E. B. KELLER, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To 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 ~ (3301(c)) of the Divorce Code. 2. Date and manner of service of the complaint: Divorce Complaint was served by Acceptance of Service by the Defendant on August 10, 2005. 3. Date of execution of the affidavit of consent required by ~ 3301(c) of the Divorce Code: by plaintiff November 21, 2005; by defendant November 21, 2005. 4. Related claims pending: resolved. None. all claims have been 5. Date plaintiff's waiver of Notice in ~ 3301(c) Divorce was filed with the prothonotary: November 21, 2005. Date defendant's Waiver of Notice in was filed with the prothonotary: November 21 ~ Divorce r Dale F. Supreme 35 East High Carlisle, PA 17013 (717) 241-4311 Attorney for Plaintiff aj 203 9. 'l-.) ;~.? \.j:~' CHRISTIAN B. KELLER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. 2005 - 4070 CIVIL DEBORAH E. B. KELLER, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 330l(c) of the Divorce Code was filed on August 9, 2005 and served on August 10, 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 authorities. DATE: November , 2005 C)~~ 8.~~ Christian B. Keller ///z//o..r . Sworn to and subscribed before me /'jsT this day 0 NOTARIAL SEAL _NIE L COYLE, NOTARY PUBLIC BOIlO Of CARUSLE. CUMBERLAND CO. PA MY CONMJSSlON EXPIRES OCTOBER 17. 2006 <.' \..",) -1'1 :~ 2~, -I"' "':" r0 r.,.: ,.- , CHRISTIAN B. KELLER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 2005 - 4070 CIVIL DEBORAH E. B. KELLER, Defendant IN DIVORCE 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 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: (/ /2/ /4f I f C&::- N_ r~ Christian B. Keller ~.) c.:) <:,:.../1 c) ~-l\ ..... ~J~ ,,', j::::; -- ..~ ~ . '~) --:-, ('-' -.! CHRISTIAN B. KELLER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 2005 - 4070 CIVIL DEBORAH E. B. KELLER, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301 (c) of the Divorce Code was filed on August 9, 2005 and served on August 10, 2005. 2. The marriage of the 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 lB Pa. C.S. ~4904 relating to unsworn falsification to authorities. DATE: November , 2005 r.JdAp,nl!. g. A ';Iftltn,; Deborah E. B. Keller Sworn to and subscribed before me this .2/M: day of November, 2005. (j);f.uwvt-/J f f). ?(PV/'{)f!../ NOTARIAl SEAL BONNIE L. COYLE, NOTARY PUBLIC BORO Of CARUSLE. CUMBERLAND CO. PA 11:'/ cOloNlSSlON EXPIRES OCTOBER 17, 2006 ,) " :~ r ~:. r,) _..l.~ r'-' ,:.. _1 .v .,; CHRISTIAN B. KELLER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 2005 - 4070 CIVIL DEBORAH E. B. KELLER, Defendant IN DIVORCE 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 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: .t./ 1( t<nW11 /!w" MO.? o /1flJ\{) Ji, {f2, 'kJi flnv Deborah E. B. Keller C) n --; ~:.~ ,h I'.' n r:-? ~ _0 ._-~>-",~-,..- ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~+~~~+~~~~~~~ . ~,.,:+:~~+~++~~+~;f.~ ~~Oj;~~:f.~~:+:~~ ~~++++~'.f. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CHRISTIAN B. KELLER, PEN NA. STP fE OF PLAINTIFF No. 2005-4070 CIVIL VERSUS DEBORAH E. B. KELLER, DEFENDANT DECREE IN . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . DIVORCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . , . . . . . . . . . . , . . . . . . . . ~ 'I; ~ ~ ~ + + + ~ + ~ ~ +. ~ OJ; ~+ eA' J:oI I,M. ,J ~ J...:> 2005 , IT IS ORDERED AND AND NOW, CHRISTIAN B. KELLER , PLAINTIFF, DECREED THAT DF1\ORAl1 F 1\ KFT,] FR , DEFENDANT, AND 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 --.-----=~=-"''''". /'~- . . . . . . . . . . . . . . . . . . ATIE'j1 . .~ .. ~ PROTHONOTARY . . . +*++~+++ 'f+'f.+'f ... ~~+'f.+~+++~~Oj;++ ... +:+:~+ '+'~+~++~~+ .. +'I':t:~+~ . . . . . . . . . . . . . . . . . . . . . J. . h ~. ~~ ~~/L" 50 rE~.// .k"'7/~ p.:2 /~(fY'^r"~.J ';;Pp y;>, f(j/ .' .. .' ''''...,.'