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Home My WebLink About94-03567 I'.' r~. IJ. , , " " '~ """".~'" I', . " " '( I, ," ...~ ~ " " ~ ~ ',I 1.,1 I' , -~~~~-,~~~*~-,~*,~-,~j-,~,,~~*,,~-~,~~--~-,. . "-"""""'''''''''''. ,,,,,-,,, """",,,,,..,.. .... '. . .."""""''''. . 8 \ 8 8 8 8 81 8 ~ $ 8 8 $ 8 ~ 8 8 .. ., Sl . i 8 (I 8 8 8 S IN THE COURT OF COMMON PLEAS 8 8 8 ~ 8 3 ~ ~ ~ ~ .:. ., 8 ~ ~ ~ t.. \~ \ ~., DEe R E E , N J: Ii ANDNOW~J~'VOR Ifl~ It l.o~:,~~~k1. ii NONE. w '" I~ )': {~ I~ ~v \~ )",- I~ i ~,' \~ , ::~ i: 1,~ ( . S 8 I~ 8 ,,',,',","',""""""""""'" (y : n .AfI(~' · ': ~ k.lfV1~(,t",'xJ[1/Je~t; ~~V7t~~' ~ . ~ ~~m~K~~ _ ?/ r7 >Orl I'rnthollnl""y -- - - - ., ""'- ,,,. , , . : .~~~-'._~~*,~.~.~.~,~*,~,~,.~,.~"~,~,*,~,,*,'~~.,~.,~"~..~, OF CUMBERLAND COUNTY 5:ATE OF '* PENNA. CAMILLE M. KELLER, i'\ () . 94-.35li,?" . ,,' II) Plaintiff, \'1'1'0'11_'; JOHN M. McNULTY, Defendant CAMILLE M. KELLER decreed that " and.." , , , ' " plaintiff. , , , , " defendant. JOHN M. McNULTY are divorced from the bonds of matrimony. The court retains lurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; w ... ~ ~ ,1'1 fY 41'/ t'?1 ~u~../i; ~ ~ ,,'lr.ft5' 71;1tu l#a&JI 72' r.:Y ~.ei , , , ' " . , ..J ... " .. v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE CAMILLE M. KELLER, Plaintiff, JOHN M. McNULTY, NO. 94-3567 CIVIL TERM Defendant. PRAZCIPB TO TRANSMIT RBCORD 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: July 5, 1994, by United States Certified Mail, Restricted Delivery, Return Receipt Requested, an affidavit regarding which was filed with this Court on July 8, 1994. 3. Date of execution of the plaintiff's affidavit required by Section 3301(c) of the Divorce Code: by the plaintiff, June 8, 1995, by defendant, June 8, 1995. 4. Related claims pending: All economic claims raised have been fully and finally resolved by a Marital Settlement Agreement entered into by and between the pa~~ on June 8G95' t.~ . R c a;d C. Seneca, Esquire Supreme Court ID #49807 Thomas, Thomas & Hafer P.O. Box 999 305 North Front Street Harrisburg, PA 17108 (717) 255-7629 Attorneys for Plaintiff Dated: June 8, 1995 . ~ ,- ." or . - ., " , , if: I " l~' .. --, I ''> t"i ~. ~ " ." ". " r\ .. "" " , ," ,/ , '" :.~ ':~ " , ".,.j eM " ,~ III " ~ ~ '. , ., -, ..l ~ C') E ~~~ i Q ~ ~ t i ... ~ ~ g Q ~ . .. ; . I, CD CD CD . o CD <) .. g i " .. ~ ~ ii ~ % ... '" CAMILLI M. KELLER, I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff , I I CIVIL ACTION - LAW v. I IN DIVORCE I NO. Ci/. (I { l}~ { 0 L.c~. JOHN M. McNULTY, J~ft. I Detendant. NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. It you wish to detend against the claims set forth in the tOllowing pages, you must take prompt action. You are warned that it you tail to do so, the case may proceed without you ahd 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 ot your children. When the ground tor the divorce irretrievable breakdown of the marriage, you counseling. A list of marriage counselors Office of the Prothonotary at the Cumberland 1 Courthouse Square, carliSle, Pennsylvania is indignities or may request marriage is available in the County Courthouse, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMEN'r 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. COURT ADMINISTRATOR 4TH FLOOR, CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 .. CAHILL! M. K!LLER, I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, I I CIVIL ACTION - LAW v. I IN DIVORCE I JOHN M. McNULTY, I NO. I Defendant. I COMPLAINT IN DIVORCE 1. Plaintiff is camille M. Keller, who currently reside. at 2112 D Market street, camp Hill, Cumberland County, Pennsylvania since January 15, 1987. 2. Defendant is John M. McNulty, who currently resides at Apart.ent 1202, 2116 Cedar Run, Camp Hill, Cumberland County, Pennsylvania since August 1, 1993. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on June 28, 1986, in Allegheny County, Pennsylvania. 5. Neither plaintiff or defendant is in the military or naval service of the United states or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no prior actions of divorce or for annul.ent between the parties. 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. the marriaqe of the partie. is irretrievably broken. WHEReFORE, plaintiff re.pectfully requests the Court to enter . decree of divorce pur.uant to 533011c) of the Divorce Code. THOMAS, THOMAS , HAFER c_ By: _~ /I n 'RiC~ {: ~ ~~quire Supreme Court 10 #49807 P.O. Box 999 305 North Front Street Harrisburq, PA 17108 (717) 255-7629 Attorneys for Plaintiff, Camille K. Keller -2- . , CAMILLE M. KELLER, I IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, I I CIVIL ACTION - LAW v. I IN DIVORCE I JOHN M. McNULTY, I NO. 94-3567 CIVIL TERM Defendant. AFFIDAVIT OF SERVICE I, Richard C. Seneca, Esquire being duly sworn according to law depose and say that I caused a copy of the Complaint in the above-captioned matter to be .erved upon the Defendant, John M. McNulty by united States certified Mail, Re.tricted Delivery on July 5, 1994, and that the attached Domestic Return Receipt is evidence of the service set forth herein. I. l...,_....__. I" " ,It 'I . _ I. .... .. . _. ' following ...... lftlr .. ,litre, , . .... vow..... ....... on the rtYtfII of ttW tonn M NI .. '11'I r..,: ' :-r.,:o="~~...".,,..... _., Of... ... _ 1'_. t. 0 AcIdI_', Add.... .. ...,.".... ,. . w....-.....~................-...-- 2.. Ilettrlclld DtllwrI :.l:...~IIo_"_"-"'_w._"""'- c' It ~, lor I Tt'nicte Add....." to: ' Article umbtr Mr. John M. McNulty ,Apart.ent, 1202 2116 Cedar Run cup Hlll, PA , , I """'---". OO_11IC RI'TUIIW ~ .C...fL. r ~ - .. - - Ri~hard C. Seneca, Esquire Supreme Court ID #49807 Sworn to and Subscribed before me this 7th day of July, 1994 ) // ,/L~iu.- W .dLk-,~ Notary Pub,)ic Nola,;ojStei Crdce M El&kIr, ~ PIJIIc Htn!stJurg llouphn Coonlv !.tt ea.vr....o;, bpm JlJnt ,~, , tI11 ~~ ~~~ ~jl J ' en en en ~ o III o ~ III o E f .; .. " III <II ii .. . % -:r- ~'.. '1\; ", ") ''l " , , , "~'") :r;-;;_ -:=======~-- -:.-::==-=-...:=..=:==- ..1::: '," " " '. '. CAMILLE M. KELLER, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 94-3567 CIVIL TERM v. JOHN M. McNULTY, Defendant. APPIDAVIT OP CONS.NT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on June 30, 1994. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that if a claim for alimony, alimony pendente lite, equitable distribution of marital property or counsel fees and expenses has not been filed with the Court before the entry of a Final Decree in Divorce, the right to claim any of them will be lost. 5. 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. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to be me upon request. 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 by the Court. I verify that the statements made in this affidavit are true .... . . w - and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 54904 relating to unsworn falsification to authorities. Datel ~~~KM.~ Plaintiff June 8, 1995 COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS. ON THIS, the 8th day of June, 1995, before me, a Notary Public, the undersigned officer, personally appeared CAMILLE M. KELLER known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ))U ('(/ J Jl( '- f- Notary x~ u<-- Public My Commission Expires: NoIarIaI s.I Mellnll R Love, NoIIIY PIdo Hlrrilbu,g, Dluphln COUnt\l ~ "mmlllion Expl'H Aug. 1Ir. 1_ ,." ',r'I",Jn&~,ofNotlr1el ~ -, ... . lA - ;~; t ,-_IT ,~, . t ".! '.;' :,; i ~... .'~ l ./., I.. I 'I" ,. :I: "!d . , 'J1.,.l'" 1_.1'..1 11.1 F , "'.\ " ~ .... ~ N en L ~ t; ~ b ... 8 '4 ~ 1: III .. ~ .. .. ~ 1; z .. ~ >< .; ~ .. 0 IX \;l al ~ ~ E z 0 al .. III IX .. ii .!l 0 ~ Z IX .. .. >< z ~ 0 ... \;l ~ .. . . ... \ , - CAMILLE M. KELLER, Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE v. JOHN M. McNULTY, t NO. 94-3567 CIVIL TERM Defendant. ArrIDAVIT OF CONSBNT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on June 30, 1994. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry cf a final decree of divorce. 4. I understand that if a claim for alimony, alimony pendente lite, equitable distribution of marital property or counsel fees and expenses has not been filed with the Court before the entry of a Pinal Decree in Divorce, the right to claim any of them will be lost. 5. 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. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to be me upon request. 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 by the Court. I verify that the statements made in this affidavit are true . ... ~ . IE en ;:I N CT'I i!i -, ~: ~: ;~' ;/' . \ 141.._ ) r)'..I"',' 11- \~ ~, . 1,..01 " ",1 ,I,": -II , , ' :," I", , '. 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