The URL can be used to link to this page

Home My WebLink About06-1143WILLIAM J. O'KEEFE, Plaintiff V. THERESA M. O'KEEFE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PEN/NA NO. L CIVIL ACTION - LAW IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in 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 at the Cumberland County Court House, One Courthouse Square, Carlisle, Pennsylvania. 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 Phone: (717) 249-3166 John J. Connelly, Jr., Esquire (?ttorn(y-for Plaintiff . J I,- WILLIAM J. O'KEEFE, Plaintiff V. THERESA M. O'KEEFE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO. nt CIVIL ACTION - LAW IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant in-a 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 decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, One Courthouse Square, 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 bome by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Prothonotary WILLIAM J. O'KEEFE, Plaintiff V. THERESA M. O'KEEFE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO. O(o CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE Plaintiff is William J. O'Keefe, social security no. 201-50-3086, who currently resides at 22 West Maplewood Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Theresa M. O'Keefe, social security no. 200-50-6390, who currently resides at 22 West Maplewood Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055. 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. Plaintiff and Defendant were married on August 7, 1981, in Mechanicsburg, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 8. The marriage is irretrievably broken. 9. The 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. 10. Plaintiff requests the Court to enter a Decree in Divorce. 11. This action is not collusive. COUNT II CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 13. Plaintiff and Defendant are the owners of various real and personal property, motor vehicles, bank accounts and insurance policies acquired during their marriage which are subject to equitable distribution by this Court. WHEREFORE, the Plaintiff requests the Court to enter a Decree: a. dissolving the marriage between the Plaintiff and Defendant; b. equitably distributing all property owned by the parties hereto; C. for such further relief as the Court may determine equitable and just. Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: Z 2' 0 By: - - Li Jo}},,,,,? J Co ell , Jr. Att - ey 5615 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Plaintiff William J. O'Keefe VERIFICATION I, William J. O'Keefe, verify that the statements made in the foregoing Divorce Complaint 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 unswom falsification to authorities. Date: G12- 7 (}a f ilham J. U efe C? ? -4f3 rv WILLIAM J. O'KEEFE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06-1143 THERESA M. O'KEEFE, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN ss. AND NOW, this 9ei day of March, 2006, personally appeared before me, a Notary Public in and for the State and County aforementioned, John J. Connelly, Jr., Esquire, who, being duly swom according to law, deposes and says that a copy of the Divorce Complaint was served on the Defendant, Theresa M. O'Keefe, on March 3, 2006, by certified mail number 7004 1160 0002 1103 6174, as evidenced by the return receipt card attached hereto and made a part hereof. Sworn to and subscribed before me this day of March, 2006. m? ;- Notary Public COMMONWEALTH OF PENNSYLVANIA Notarial Seal Maria B. LaRue, Notary Public Derry Twp., Dauphin County My Commission Expires Nov. 8, 2009 Member, Pennsylvania Association of Notaries 1 . ¦ Complete items 1, 2, and 3. Also complete Item 4 if Restricted Delivery is desired. 1 ¦ 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: T« s x'1'1. 0' K-?-L f e 2 wt4 MaPluk)OOA HARRISBURG PA 171 /srr A. Sign ? Addressee B. Received by (Printed Name) 47 C. Date of Delivery D. Is del" rem from item 17 0 Yes If Y ress below: 0 No 141;. 1 ?1 I I? lX LYE1?1? \ (S ?lr? 3. Se art d ail Cl Express Mall ? 0 Registered 0 Return Receipt for Merchandise 1 0 Insured Mail ? C.O.D. 4. Restricted Deliveryl (Extra Fee) es 2. ArticleNUmm (irmrsrer servke MbNJ 7004 1160 0002 1103 6174 PS Form 3811, February 2 _ t r r Curtis R. Long Prothonotary office of the Protbonotarp (Cuntbertanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor nL - ]1L/3 CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE 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