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Home My WebLink About06-1975 Melissa Keeseman, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Heath Fittery, Defendant CIVIL ACTION - LAW No.O&' -/91$ CIVIL IN DIVORCE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. 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, High and Hanover Streets, Carlisle. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABLE TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. . Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. Melissa Keeseman, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VI. Heath Fittry, Defendant CIVIL ACTION - LAW No. 0(" - /9 'IS CIVIL IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE I. Plaintiff is Melissa Keeseman, an adult individual, who resides at 1815 F. Willow Road, Carlisle, Cumberland County, Pennsylvania 170 I 3. 2. Defendant is Heath Fittry, an adult individual, who resides at 2 East Main Street, P.O. Box 140, Plainfield, Pennsylvania 1708 I. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on July 2004 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 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 in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, ROMINGER, BAYLEY & WHARE Date: 4/~JoG. ! ! Leslie A. Tom 0, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 200198 Attorney for Plaintiff VERIFICATION 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. 94904, relating to unsworn falsification to authorities. Date: :JL/ /6) /00 . if /Ynol~ "1-<o@.~ / Melissa Keeseman, Plaintiff Melissa Keeseman. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Heath Fittry, Defendant CIVIL ACTION - LA W No. CIVIL IN DIVORCE CERTIFICATE OF SERVICE I, Leslie A. Tomeo, Esquire, attorney for Plaintiff do hereby certify that I this day mailed a copy of the within Motion upon the following by depositing same in the United States mail, postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Heath Fittry 2 East Main Street P.O. Box 140 Plainfield, Pa 17081 Dated: ~(, (O(P I .UJ. \.) ---.. 7'( 7' ....\J 1l \) ~ vt ~ C> -...1 ;U \'- tit r- ~ <:;; r- ~ ~ .~ c:- <' c:?, .--{ "1:'- .t;~ ~: ;/f) -- \ (.:-) "'-..3 (.) 0...... _J Melissa Keeseman, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. Heath Fittery, Defendant CIVIL ACTION - LA W No. 06-1975 CIVIL IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 6, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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: 07/10/0(0 , .- ~/TYloJ~ ~~ Melissa Keeseman/Plaintiff .~ ,i; _.! ~"..~~. \.~. ,./ Melissa Keeseman, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. Heath Fittery, Defendant CIVIL ACTION - LAW No. 06-1975 CIVIL 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! 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: () 7/' () / (; (p . ./(flD~ ~ Melissa Keeseman, Plaintiff c:' Melissa Keeseman, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. Heath Fittery, Defendant CIVIL ACTION - LAW No. 06-1975 CIVIL IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 6, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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: 7-10- t'/ro , 1lI~~~ Heath Fittery/Defendant c. .--i 0-;-1 c: Melissa Keeseman, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. Heath Fittery, Defendant CIVIL ACTION - LAW No. 06-1975 CIVIL 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: 7 -/0 -{;lG I/I~~ Heath Fittery, Defendant c__ ~-1 i' ;;.; -~,! C' Melissa Keeseman, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERL.\ND COUNTY, PENNSYL VANIA v. Heath Fittery, Defendant CIVIL ACTION - LAW No. 06-1975 CIVIL IN DIVORCE PROQF OF SERVICE 1. Allele ~ -' to: \\ectth nMY ~ 'taS-\ ~l~ ~Vli+ f.O.~ lL/D . ~\aLn~dd, f} 1708'1 ?If. h D.lodollvlry____1? Ov.o WYES, -dIIWy -- p-No 3._~ .. CortIIIod _ 0 e.pr..- C Ra.;I.l.lllM1 B:'RItum ReceIpt for Mb.ot_'" 01_ _ 0 C.O.D. 4. '1.. ....,...- .... Z....AIl!dON..- ~7. 350 0.003 ... ~ ~u. j PS Form 3811..F....., -- ~.._______.__.n_._ __~_..__ _ 7142 bb32 10296-02-M-154O (") s;; "'- "1:J tjJ mfr. Z'::' rr '~. \~ *r; :~~: =< ~~ i-l'1 CV-\ ", Melissa Keeseman, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. Heath Fittery, Defendant CIVIL ACTION - LAW No. 06-1975 CIVIL IN DIVORCE PRAECIPE TQ TMNSMIT RECOap TO THE PROTHONOTARY: Transmit the record, together with the following infonnation, to the Court for entry of a divorce decree: I. Grounds for divorce: irretrievable breakdown under ~ 330 I (c) of the Divorce Code. 2. Date and manner of service of the Complaint: April 6, 2006, was served on Defendant by Certified Mail and the green card was signed on April 8, 2006 (attached hereto as Proof of Service). 3. Date of execution of the Affidavit of Consent required by ~ 3301(c) or The Divorce Code: by the Plaintiff July 10, 2006; by the Defendant July 10, 2006. 4. Related claims pending: None; 5. (b) Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotuy:JulyI7,2006 Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotuy: July 17,2006 Date: :;/11-10" Leslie A. T eo, Esquire 155 South anover Street Carlisle, P A 17013 (717) 241-6070 Supreme Court ID No. 200198 (:') -n \ -- .- C\ f" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF Melissa Keeseman Plaintiff VERSUS Heath Fitterv n~'fenM7'nt . AND NOW, PENNA. . No. 2006 - 1975 DECREE IN DIVORCE -:r ~ ).~ ..;r 3:/)l)f'''' . Jofi. . IT IS ORDERED AND DECREED THAT Melissa K~esernan , PLAINTIFF, AND Heath Fittery . , 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. . J. PROTHONOTARY . h ~ 'W"'P7Y ~ ~,g p,.. ~ '~." ~ "/"9 . ~,' 1(- ,":.1/. .. ..~ " ~- ?tJ .ge - t.. ~(l. !>-C-L