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HomeMy WebLinkAbout02-1898HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF TONI S. KECK, Plaintiff Vw LARRY G. KECK, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 02 - /~ CIVIL TERM : 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 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 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, Carlisle, Pennsylvania 17013. 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 TONI S. KECK, Plaintiff LARRY G. KECK, JR, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : CIVIL ACTION - LAW :NO. 02- /9~ CIVIL TERM : IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c) OF THE DIVORCE CODE NOW, comes the plaintiff, by her attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Toni S. Keck, an adult individual residing at 120 East Louther Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Larry G. Keck, Jr., an adult individual residing at 23 Swartz Road, Newburg, Cumberland County, Pennsylvania 17240. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were marded on December 23, 1990, in Carlisle, Cumberland County, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as your Honorable Court may deem equitable and just. 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. Section 4904, relating to unsworn falsification to authorities. April 18, 2002 TON~ S. KECK, 4~laintiff ~ 35 East High Street Carlisle, Pennsylvania 17013 (717) 243-6090 TONI S. KECK, Plaintiff LARRY G. KECK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02 - /~ CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of mardage 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 mardage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not .request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. April 18, 2002 /~~ ~~/ TONI S. KECK, ~ I~aintiff 4 TONI S. KECK, Plaintiff LARRY G. KECK, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02 - /?~ CIVIL TERM : IN DIVORCE COMPLAINT FOR CUSTODY NOW comes the plaintiff, by her attorney, Harold S. Irwin, III Esquire, and files this complaint and agreement for custody, representing as follows: 1. The plaintiff, Toni S. Keck, is an adult individual residing at 120 East Louther Street, Apartment D, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant, Larry G. Keck, Jr., is an adult individual residing at 23 Swartz Road, Newburg, Cumberland County, Pennsylvania 17040. 3. The parties are the natural parents of a minor child, namely Stormilee Keck (born October 18, 1997, age 4 years). 4. The child resided with both of the parties from the birth of the child until the parties' separation on February 9, 2002. The child has resided with each party at their respective residences on a mutually agreeable joint custody basis since the parties' separation. 5. The plaintiff has not participated as a party, witness or in any other capacity in other litigation concerning the custody of the child in this or another court. 6. The plaintiff has no information regarding any other custody proceeding concerning the child pending in a court of this Commonwealth. 7. The plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 8. The plaintiff believes and therefore avers that the best interests and permanent welfare of the child require that the parties have joint legal and physical custody of the child0 in accordance with their mutual agreement. 9. Both parties, as evidenced by their joint execution of this complaint, have mutually agreed upon an amicable arrangement for the legal, physical and temporary custody of the child and request that the Court enter an order as provided below without the necessity of a hearing: A. The parties shall have joint legal custody of the child. B. The parties shall have joint physical custody of the child, with the understanding that they shall share time with the child as they shall mutually agree on as equal a basis as reasonably possible. C. The Father shall always have the child on Father's Day and the Mother shall always have the child on Mother's Day. D. The parties shall have reasonable telephone contact with the child while the child is in the other's custody. E. Any modificatioh or waiver of any of the provisions of this agreement shall be effective only if made in writing and only if executed with the same formality of this agreement. F. The parties shall keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to insure that the health, welfare and well being of the child is protected. G. The parties shall do nothing that may estrange the child from the other party or hinder the natural development of the child's love or affection for the other party. H. In the event of the breach of this agreement by any party, the nonbreaching party shall have the right to file a petition for contempt of court and to seek specific performance of the terms of this agreement. All costs, expenses and reasonable attorney fees incurred by the successful party in any litigation to obtain an order of contempt or specific performance of this agreement shall be recoverable as part of the judgment entered by the court I. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. J. The parties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County without the necessity for a hearing or other proceeding thereon, and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over these issues and shall retain such jurisdiction should circumstances change and any party desire further or require further modification of said Order. WHEREFORE, the plaintiff respectfully requests that the court enter an order providing for the legal and physical custody of the child as aforesaid. Attomey for Plaintiff VERIFICATION AND CONFIRMATION OF AGREEMENT We do hereby verify that the acts set forth in this complaint are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904, relating to unsworn falsification to authorities. Furthermore, by the execution of this Confirmation, we do each unequivocally express our mutual and voluntary agreement to the amicable custody arrangement provided above and request that the terms thereof be entered as an Order of Court without the necessity of a custody conciliation, hearing or other proceeding. ~4RR~//G. KECK // SEAL) HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE I~A 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF TONI S. KECK, Plaintiff Vm LARRY G. KECK, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02 - /?~ CIVIL TERM IN DIVORCE ORDER OF COURT AND NOW, this /(--~' day of ~ ,2002 upon presentation and consideration of the within complaint and the stipulation and agreement incorporated therein, and upon agreement of the parties, it is hereby ordered and decreed as follows: A. The parties shall, have joint legal custody of the child. B. The parties shall have joint physical custody of the child, with the understanding that they shall share time with the child as they shall mutually agree on as equal a basis as reasonably possible. C. The Father shall always have the child on Father's Day and the Mother shall always have the child on Mother's Day. D. The parties shall have reasonable telephone contact with the child while the child is in the other's custody. E. Any modification or waiver of any of the provisions of the agreement of the parties shall be effective only if made in writing and only if executed with the same formality of the agreement of the parties. F. The parties shall keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to insure that the health, welfare and well being of the child is protected. G. The parties shall do nothing that may estrange the child from the other parties or hinder the natural development of the child's love or affection for the other parties. H. In the event of the breach of the agreement of the parties by any party, the nonbreaching party shall have the right to file a petition for contempt of court and to seek specific performance of the terms of the agreement of the parties. All costs, expenses and reasonable attorney fees incurred by the successful party in any litigation to obtain an order of contempt or specific performance of this agreement shall be recoverable as part of the judgment entered by the court. I. The Court of Common Pleas of Cumberland County has jurisdiction over these issues and shall retain such jurisdiction should circumstances change and any party desire further or require further modification of said Order. BY THE COURT, Jo TONI S. KECK, Plaintiff LARRY G. KECK, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 02 - /??~ CIVIL TERM : IN DIVORCE COMPLAINT FOR CUSTODY NOW comes the plaintiff, by her attorney, Harold S. Irwin, III Esquire, and files this complaint and agreement for custody, representing as follows: 1. The plaintiff, Toni S. Keck, is an adult individual residing at 120 East Louther Street, Apartment D, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant, Larry G. Keck, Jr., is an adult individual residing at 23 Swartz Road, Newburg, Cumberland County, Pennsylvania 17040. 3. The parties are the natural parents of a minor child, namely Stormilee Keck (born October 18, 1997, age 4 years). 4. The child resided with both of the parties from the birth of the child until the parties' separation on February 9, 2002. The child has resided with each party at their respective residences on a mutually agreeable joint custody basis since the parties' separation. 5. The plaintiff has not participated as a party, witness or in any other capacity in other litigation concerning the custody of the child in this or another court. 6. The plaintiff has no information regarding any other custody proceeding concerning the child pending in a court of this Commonwealth. 7. The plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 8. The plaintiff believes and therefore avers that the best interests and permanent welfare of the child require that the parties have joint legal and physical custody of the child0 in accordance with their mutual agreement. 9. Both parties, as evidenced by their joint execution of this complaint, have mutually agreed upon an amicable arrangement for the legal, physical and temporary custody of the child and request that the Court enter an order as provided below without the necessity of a hearing: A. The parties shall have joint legal custody of the child. B. The parties shall have joint physical custody of the child, with the understanding that they shall share time with the child as they shall mutually agree on as equal a basis as reasonably possible. C. The Father shall always have the child on Father's Day and the Mother shall always have the child on Mother's Day. D. The parties shall have reasonable telephone contact with the child while the child is in the other's custody. E. Any modificatioh or waiver of any of the provisions of this agreement shall be effective only if made in wdting and only if executed with the same formality of this agreement. F. The parties shall keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to insure that the health, welfare and well being of the child is protected. G. The parties shall do nothing that may estrange the child from the other party or hinder the natural development of the child's love or affection for the other party. H. In the event of the breach of this agreement by any party, the nonbreaching party shall have the right to file a petition for contempt of court and to seek specific performance of the terms of this agreement. All costs, expenses and reasonable attorney fees incurred by the successful party in any litigation to obtain an order of contempt or specific performance of this agreement shall be recoverable as part of the judgment entered by the court I. The parties agree that in making this agreement there has been no fraud, concealment, overreaching, coercion or other unfair dealing on the part of the other. J. The parties desire that this agreement be made an order of Court through the Court of Common Pleas of Cumberland County without the necessity for a hearing or other proceeding thereon, and further acknowledge that the Court of Common Pleas of Cumberland County has jurisdiction over these issues and shall retain such jurisdiction should circumstances change and any party desire further or require further modification of said Order. WHEREFORE, the plaintiff respectfully requests that the court enter an order providing for the legal and physical custody of the child as aforesaid. Attorney for Plaintiff VERIFICATION AND CONFIRMATION OF AGREEMENT We do hereby verify that the acts set forth in this complaint are true and correct. We understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. § 4904, relating to unsworn falsification to authorities. Furthermore, by the execution of this Confirmation, we do each unequivocally express our mutual and voluntary agreement to the amicable custody arrangement provided above and request that the terms thereof be entered as an Order of Court without the necessity of a custody conciliation, hearing or other proceeding. Date: /_.I~J~RR~//6. KECK Date: SEAL) ,q HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA t ?013 (717) 243-6090 ATTORNBY FOR PLAINTIFF TONI S. KECK, Plaintiff LARRY G. KECK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02 - 1898 CIVIL TBRM IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i) NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That the defendant accepted service of a certified copy of the complaint in divorce on or about Apdl 18, 2002, as shown by the attached Acceptance of Service, executed by the defendant on May 18, 2002. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn faisificatio~ authorities. May 21, 2002 HAROLD S. IRWIN, III, ESQUIRE A'I'I'ORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF TONI $. KECK, Plaintiff LARRY G. KECK, JR., Defendant : IN THE COURT OF COMMON PLEA8 OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02 - 1898 CIVIL TERM : IN DIVORCE ACCEPTANCE OF SERVICF I hereby certify that on April /<~ , 2002, I received a certified copy of the divorce complaint filed in this action. May /~7, 2002 LARRY C~. KE~K, JR. - JF Defendant TONI S. KECK, Plaintiff LARRY G. KECK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02 - 1898 CIVIL TERM : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about Apdl 18, 2002 and served upon defendant on April 18, 2002 (See Acceptance of Service executed by the defendant and filed on May 22, 2002.) 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. September 3, 2002 TONI~S. KECK TONI S. KECK, Plaintiff LARRY G. KECK, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02 - 1898 CIVIL TERM : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT 1. I have been advised of the availability of mardage 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 Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. 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. Section 4904 relating to unsworn falsification to authorities. September 3, 2002 TONIC. J(ECK ' ~ ' / TONI S. KECK, Plaintiff LARRY G. KECK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02 - 1898 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUESi ,_,ENTRY OF A DIVORCE DECRE.~ UNDER SECTION 3301(C) OF THE DIVORCE CODi 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 divomed 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. Section 4904 relating to unsworn falsification to authorities. September 3, 2002 T(:~N I ~S. KECK v .... TONI $. KECK, Plaintiff LARRY G. KECK, JR., Defendant : IN THE COURT OF COMMON PLEA8 OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION. LAW : : NO. 02 - 1898 CIVIL TERM : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about April 18, 2002 and served upon defendant on April 18, 2002 (See Acceptance of Service executed by the defendant and filed on May 22, 2002.) 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. August 29, 2001 LARRY (~ KECK, Ji~. / TONI S. KECK, Plaintiff LARRY G. KECK, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA _, : CIVIL ACTION. LAW : : NO. 02 - 1898 CIVIL TERM : IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly swom according to law, deposes and says: 1. I have been advised of 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 Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. August 29, 2002 I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. · ~ ,JR. 'J -- TONI 8. KECK, Plaintiff LARRY G. KECK, Defendant IN THB COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02 - 1898 CIVIL TERM IN DIVORCE :,WAIVER OF NOTICE OF INTENTION TO REClUE~, ENTRY OF A DIVORCE DECREr UNDER SECTION 3301 C) OF THE DIVORCE COD. 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, lawye¢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. Section 4904 relating to unsworn falsification to authorities. August 29, 2002 HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF TONI $. KECK, : IN THE COURT OF COMMON PLEA8 OF Plaintiff V, LARRY G. KECK, Defendant : CUMBERLAND COUNTY, PENNSYLVANIA _, : CIVIL ACTION - LAW : : NO. 02 - 1898 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECO__ To the Prothonotary: decree: Transmit the record, together with the following information, to the court for entry of a divorce 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. Date and manner of service of the complaint: On or about April 18, 2002, defendant was served with a copy of the divorce complaint. See Affidavit of Service filed on May 22, 2002. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: September 3, 2002. By the defendant: August 29, 2002. (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: N/A. Related claims pending: None Complete either (a) or (b): (a) (b) September4~'.'.2002 Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A Date plaintiffs Waiver of Notrice in Section 3301(c) divorce was filed with the Prothonotary: September~, 2002. Date defendant's Waiver of Notice in Section 3301© Divorce was filed with the Prothonotary: September~ 2002. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY TONI S. KECK Plaintiff STATE OF ~ PENNA. VERSUS Y.~IRRY G. KECK, JR, Defendant N O. DECREE iN DIVORCE AND NOW, DECREED THAT AND T~NT ~_ LARRy G. K~CK~ , 2~2__, IT IS ORDERED AND , PLAINTIFF, , 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 ~ROTHONOTARY NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 35 EAST HIGH STREET CARLISLE PA t70t3 (7t7) 243-6090 ATTORNEY FOR DEFENDANT TONI S. KECK, Plaintiff LARRY G. KECK, JR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION., LAW : : NO. 02 - t898 CIVIL TERM : IN DIVORCE NOTICE OF INTENTION TO RETAKE AND USE PRIOR NAME I, TONI S. KECK hereby give notice, avowing my intention to resume and hereafter use my prior surname, to wit: TONI S. FAILOR, in accordance with the provisions of the Act of December 16, 1982, P.L. 1309, No. 295, Section 704 (a) (54 Pa.C.S.A. Section 704 (a)). My divorce, docketed to the above term and number was granted on the 13TM day of September, 2002. I verify that the statements made in this document are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities, IN WITNESS WHEREOF, I have hereunto set my hand and seal this 234 day of November, 2002. Witness: TONI S. KECK TO BE KNOWN AS: TONI S. FAILOR