HomeMy WebLinkAbout95-06949
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF '* PENNA,
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lh'intiff:
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1"Il'W,\ i , ]l;1:1']1,":Y
Dc f(mclun t
DeCREE IN
DIVORCE
AND NOW".. ..l~)...~..... 19~~.,
it is ordered and
d d h "'n' I :... I'{ I . tiff
ecree t at ..,. "VI', . \ , ,,'. . ,. I ,. " ."....,.......,....,..,.., pam ,
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an .... ~'l.,J..J. ,I... ',:" J .. L . , ,. . , . . , . ", , . . . . ... , .
. . , . . . . . , . '. defendant,
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which hOVEl
been raised of record in this action for which 0 final order has not yet
be nt r d.llon", '1'1\(' 11'Oi:(,)'Ly :..;t,t)"I'f!nt !/'t""',c,nt, (>X(~"\lt"cl
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tnto tht: IJivorc,'-; i)(;Ct.'(:P,
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PROPIlRTY 8ETTLI!IIBNT AGRBIDIBII'l'
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I.
THIS AGREEMENT made and entered into this r:
day of
.Plt~""fil2
, 1995, by and between FREDA M. KEPPLEY of the County
of Cumberland, Commonwealth of Pennsylvania (hereinafter referred
to as "Wite"),
a
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EDWIN L. I<EPPLEY, ot the County of Cumberland, and Commonwealth of
Pennsylvania (hereinafter referred to as "Husband").
IfiTNESSBTH :
WHEREAS, the parties were marr...ed on October 17, 1987, in
York County, Pennsylvania; and
WHEREAS, the Husband and wife are owners in fee simple of
certain real estate, situated in the Township of Middlesex, County
'of Cumberland, Commonwealth of pennsylvania, known and identified
as 366 South Middlesex Road, Carlisle PA 17013; and
WHEREAS, certain differences have arisen between the parties
and as a consequence thereof, they have chosen to live separate and
apart I and
WHEREAS, the Husband and Wife desire to settle and determine
matters of support, property settlement, and related items, and
also other matters that are more fully set forth in the within
Agreemen t.
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NOW THEREFORE, in consideration of the promises, mutual
covenants, and agreements hereinafter set forth, the parties hereto
covenant, promise and agree with one another as follows:
1. Husband t'elinquishes his inchoate intefitate rights in and
to the estate of the Wife ~nd the wife on her part relinquishes her
inchoate intestate rights in and to the estate of her Husband, and
each of the parties hereto by these presents, for himself and
herself, his or her heirs, executors, administrators or assigns,
does remise, release, quitclaim and forever discharge the other
party hereto, his or her heirs, executors, administrators or
assigns, of any and all claims or demands, damages, actions, be
they civil or criminal, causes of action, or suits at law or in
equity, of whatever kind of nature for or because of any matter or
thing done, committed or suffered to be done by said other party
prior to and including the date thereof, except that this release
shall in no way affect any cause of action in absolute divorce
which the Wife or Husband may contemplate against each other, nor
'shall this complete and final release in any way mitigate against
either of the parties hereto filing suit against the other in
equity or at law enforce any right or covenant incorporated in this
Agreement. Each of the parties further renounces and relinquishes
any and all claims and rights that he or she may have or hereafter
acquire to act as executor or administrator of the other party's
estate, unless such party shall specifically d~~lgnate otherwise,
2. It shall be lawful for the Husband and the wife at all
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times hereafter li.va separate and apart from each other and to
reside from time to time at such place or places as they deem tit,
tree trom all restraint or interference, either direct or indirect,
by each other. Neit.her party shall molest the other or compel the
other to cohabit, dwell with, or support the other party by any
legal proceeding.
3. Both parties waive and relinquish any claim for, or right
to, or interest in any Order of alimony, alimony pendente lite,
spousal support, or the like, from the othllr party. This
provision, for the full and complete waiver of alimony or similar
payment, is not modifiable by any Court, even if there should be a
change in circumstances for the parties.
4. It is noted that the parties are the joint owners of
certaln real estate known and identif ied as 366 South Middlesex
Road, Middlesex township, carlisle, Pennsylvania. The Husband
shall deliver, unto the Wife, a Deed of General Warranty to the
extent that the Wife shall become the exclusive owner thereof. It
is specifically noted that the Wife shall become responsible for
any and all expenses related to the residence, including any and
all debts associated with same. This shall spedfically include
the mortgage ( owed to Farmers First Bank and/or its successors or
assigns), taxes, insurance, uti 1 ities, and any and all other
Charges associated with the ownership and/or maintenance of the
residence, past, present and tuturll.
'lhe tt.Isl:lani shall pay for any costs llSSOCiated with the
filing of said deed.
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The Wife shall indemnify the Husband and hold him
harmless from any and all claims that may arise in conjunction with
the mortgage, or any other debts associated with the residence,
Said indemnity shall include attorney's fees, costs and expenses.
60th parties shall promptly notify the other of any and all matters
that could effect such debts, including claims of lateness or lack
of payments, collection proceedings, and any and all other matters
relating to these debts.
Wife shall not only assume all responsibility tor
payment of all expens~s associated with the residence, but shall
also keep current with said obligations. If, as a result of Wife's
failure to keep current and/or perform any obligation prescribed by
the mortgage documents or any other debt, Husband incurs any
adverse credit rating, Wife shall notify any and all credit
reporting agencies or lending institutions prescribed by Husband
and so advise same the Wife as solely responsible for said
obligations and that Wife was solely at fault for breaking said
Obligations. Wife will make every effort to have removed any
'adverse rating, notation and/or other detriment from Husband's
credit rating.
Said debts are nondischargable under the Bankruptcy
Code.
5. The Ford Truck and Pontiac Fiero currently titled in the
Husband's name, shall remain as the sole and exclusive property of
the Husband. The Wite does waive and relinquish any and all claims
to or against said vehicles.
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6. 'lhe Buick Park Avenue currently ti tled in the Wife's name
shall remain the sole and exclusive property of Wife. Husband
waives and relinquishes any and all claims to or against said
vehicle.
7. Husband has an individual employee benefit (retirement)
plan through his employer, Ray Garver, Inc. Husband shall pay, to
Wife, one half (1/2) of the value of the plan accrued as of the
date of separation minus, any amount imposed as a penalty for early
withdrawal.
8. Each party does waive and relinquish any and all right
to, claim against, or interest in the bank accounts of the other.
Husband waives any interest in or right to any joint bank account
of the parties.
9. Husband doos waive and relinquish any and all right to,
claim against, or interest in and bonds that are marital property
or Wite's property.
10. Each party shall receive their own personal effects,
which ar.e and ~hall be considered to be the sole and exclusive
'property of such party. It is specifically noted that this
includes their Clothing, jewolry, and other purely personal
effects. It is specifically noted that the parties have previously
distributed such personal property. It is specifically noted that
Husband is to receive all of his tools, and that Wife waives any
and all interest in and to Husband's tools.
11. Each of the parties hereto covenants and agrees that they
have not or will not at any time in the future incur or contract
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any debt, charge or liability whatsoQver for which either of them,
their legal representatives, or their property or their estate may
become liable, other than those set forth in this Agreement; and
each of them further covenants et all times to keep the other free,
harmless and indemnified of and from all debts, charges and
liabilities hereafter contracted by them.
12. Wife agrees to assume, be exclusively responsible, and
hold Husband harmless for the payment in full of the following
debts:
, II/SA-: _
1. Mastercard # S'Z~, aile ISOI S'I~1# 4'2J() 4fC +17 710 :/'.tn. tt:.
2. Jeff Sanders - Electrician
Said debts are nondischargable under sections 523 (a) (5) and (a)
(15) of the Bankruptcy Code.
13. Husband agrees to assume, be exclusively responsible, and
hold Wife harmless for payment in full of the following debt:
1. Mastercard # 5369933050150883
14. It is acknowledged that both parties have received
independent ,legal advice from their counsel. Harold S. Irwin, III,
Esquire represents the Wife and Gregory J. Katshir, Esquire
represents the Husband. Each party acknowledges that he or she
fully understands the facts and has been fully informed of his or
her legal rights and obligations and each party acknowledges and
accepts that this Agreement is, under the circumstances, fair and
equitable, and that it is being entered into freely and voluntarily
after having received such advice and that the execution 'of this
Agreement is not the result of any dlJress or undue influence and
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that it is not the result of any collusion or improper or illegal
agreement or agreements.
15. The parties agree that if he/she were to tile for
Bankruptcy under any section of the Bankruptcy code, he/she must
notify the opposing party of such.
16. The parties acknowledge that a Divorce Complaint will be
processed by the Husband. It is acknowledged that the Husband
shall file a Divorce complaint setting forth a count for a divorce
based upon irretrievable breakdown. No other counts shall be set
forth in this Divorce complaint. The wife, or counsel for Wife,
agrees to execute and file an appropriate Acceptance of Service.
No responsive pleading shall be required by the Wife. The parties
specifically acknowledge their understanding that pennsylvania law
speaks of a waiver of clailns foe alimony, counsel fees, equitable
distribution and other matters, in the event that snch a claim is
not made prior to the entry of the final divorce decree. The
Husband will not present any such claim in conjunction with his
Divorce complaint, and the Wife shall not file any form of
'responsive pleading making a demand for the same. However, thie
shall not act in any manner to serve as a waiver of such claims in
the event that the parties do not proceed under the terms and
conditions of this Agreement, and/or if further litigation is
necessary.
'1he parties shall ~'.JIlt'tly execute ard tile Affidavits
of consent, after the expiration of the ninety (90) day waiting
period required by Pennsylvania law. Gregory J, Katshir, Esquire
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shall provide the parties with these Affidavits of Consent, and
shall promptly file them so as to have a Divorce Decree issued.
'!he HUsband shall pay any court costs or f.ill~ tees
associated with the filing of the Divorce pleadings. Each party
shall be responsible for their own attorney's fees.
17. The parties shall file a joint tax return for 1995,
unless it shall be determined that it shall be beneficial for the
o:l.~ 111., 04, "'~'<7 7c':'
parties to file otherwise. Any tax refund, n~ '811 81111,a'llvR.
shall be shared equally by the parties, if the parties
retu"n. ~, - - JI - ; ..
tax oft r' -~ - .~- ,J&' ,.}",,/ '';7
file a jointJ.'Il\.{.
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18. The parties agree and acknowledge that they have reached
a' fair distribution of property. That each party has received
their share of any and all marital estate matters. The parties
again acknowledge that they will retain full ownership of any items
in their possession, and expressly waive and relinquish any claim
against any of the personalty, tangible assets, intangible assets,
or any other matter, of the other party.
19. The parties specifically acknowledge that the settlement
arranged herein is an equitable distribution of the property of
the parties, and each party waives distribution of marital property
by a Court.
20. The parties expressly waive and relinquish any right to
or claim for any entitlement provided by law and not expressly
provided for herein. It is acknowledged by the parties that the
receipt of those benefits and distributions set forth in this
Agreement are in full satisfaction of or any entltlement provlded
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for by law.
21. The parties acknowledge that they have made, to each
other, a full and complete disclosure of all matters related to the
assets and/or liabilities of the mar! tal estate, and that they
waive any specific listing or documentation thereof, for the
purpose. of this Agreement.
22. This Agreement constitutes the entire understanding of
the parties. There are no representations or warranties other than
those expressly herein set forth.
23. The parties agree that all questions pertaining to the
effect and validity of this Agreement, and the administration of
its provisions, shall be governed by the laws of the Commonwealth
of Pennsylvania. The parties agree that any further action to be
brought for the enforcement of this Agreement shall be brought in
the Courts of Cumberland County, Pennsylvania.
24. If any term, condition, clause or provision of this
Agreement shall be determined to be void or invalid at law or for
any other rOlison, then only that term, condition, clause or
provision shall be stricken from this Agreement as is deemed to be
void or invalid at law, and in all other respects this Agreement
shall remain in full force and effect.
25. This Property Settlement Agreement shall be incorporated
into the Divorce Decree to be issued in this matter in the Court of
Common Pleas of Cumberland County, Pennsylvania.
26. This Agreement shall maintain its independent vitality,
and shall survive any incorporation, by reference or otherwise,
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GREGORY J. KATSHIR
Altorney at Law
900 Markel Slreet
Lemoyne, Pennsylvania 17043
(717) 763.8133. Fax (7"') 763.9425
J
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,
..
EDWIN L. KEPPLEY
plaintiff,
) IN THE COURT OF COMMON PLEAS OF
) CUMBERLAND COUNTY, PENNSYLVANIA
)
) 95-6949 CIVIL TERM
)
)
)
)
) CIVIL ACTION - LAW
) IN DIVORCE
VB.
FREDA M. KEPPLEY
Defendant.
PDRt!IPB 'l'O TRANSIIIT RECORD UMDBR SECTION 3301(0)
OF THE DIVORCE CODB
TO THE PROTHONOTARY:
Kindly transmit the record and the following information
for entry of a Divorce Decree.
1. Ground for divorce: Irretrievable breakdown under section
3301(0) of the Divorce Code.
2. Date and manner of service of Complaint: Complaint
acoepted by counsel for Defendant on December 18, 1995.
3. Date Affidavit of Consent under section 3301(0) of the
Divoroe Code signed:
By Plaintiff: March 19, 1996
By Defendant: April 5, 1996
4. Relatod claims pending: All matters have been resolved
by way of the property Settlement Agreement executed by the
parties.
Gregor~ J. Katshir, Esquire
Attorn y for Plaintiff
BDWIN L. REPPLEY ) IN THE COURT OF COMMON PLEAS
plaintiff ) CUMBERLAND COUNTY, PENNSYLVANIA
)
VS. \ CIVIL ACTION - LAW
)
FREDA N. ~EPPLEY ) NOI
Defendant )
) IN DIVORCE
NOTICE OF AVAILABILITY QLnCQY~ELING
TO THE WITHIN NAMED DEFENDANT:
You have been named as the Defendant in a complaint 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 being handed down by the
court. A list of professional marriage counselors is available
at the Domestic Relations Office, 13 North Hanover street,
Carlisle Pennsylvania. You are advised that this list is kept as
a convenience to you and you are not bound to choose from a
counselor from this list. All necessary arrangements and the
costs of counseling sessions are to be borne by you and your
spouse.
If you desire to pursue counseling, you must make your
request for counseling within twenty days of the date on which
you receive this notice. Failure to do so will constitute a
waiver if your right to request counseling.
.
BOllIN L. KEPPLEY
Plaintiff, ) IN THE COURT OF COMMON PLBAS
) CUMBERLAND COUNTY, PENNSYLVANIA
vs. )
)
) CIVIL ACTION - LAW
FREDA M. KEPPLEY )
Defendant. ) NO.
)
) IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes Plaintiff, Edwin L. Keppley, QY his attorney
Gregory J. Katshir, Esquire with the following Complaint and'prayer
for relief wherein it is set forth as follows:
CQUltT I - DIV~
1. Your Plaintiff is Edwin L. Keppley, an adult individual
residing at 520 Walnut Street, Apartment 4, Lemoyne, CUmQerland
County, pennsylvania.
2. The Defendant is Freda H. Keppley, an adult individual
residing at 366 South Middlesex Road, Carlisle, Cumberland County,
pennsyl vania.
3. Defendant is a national of the United States of America.
4. Plaintiff and Defendant were 14arried on October 17, 1987,
in York County, Pennsylvania.
5. Both parties have been bona fide residents of the
Commonwealth of pennsylvania for at least six months prior to the
filing of this Complaint.
.
6. There have been no prior actions for divorce or annulment
between the parties.
7. . The Plaintiff avers that:
a) The Defendant has offered such indignities to the
pef.'Bon of the Plaintiff, the injured and innocent
spouse, as to render his condition intolerable and
his life burdensome; and
b) The marriage is irretrievably broken and is
irretrievably broken to the extent that the parties
are separated and will remain separated into the
future, for such a period as would extend beyond
that provided by law for the granting of a divorce
decree under the laws of our Commonwealth.
B. The Plaintiff acknowledges and avers that he has been
advised that marriage counseling is available to him, and to either
party, and haa further been advised of his right to request that
this Honorable Court require the parties to participate in
counseling.
WHEREFORE, Plaintiff respectfully requests that this Honorable
Court grant him a decree in divorce.
Respectfully submitted,
J. Katshir, Esq.
rney for plaintiff
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: I
EDWIN L. KEPPLEY
plaintiff
) IN THE COUR'!' OF COMMON PLEAS
) CUMBERLAND COUNTY, PENNSYLVANIA
)
)
) CIVIL ACTION - LAW
)
) NO.
vs.
FREDA M. KEPPLEY
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 judgmant 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.
is indignities or
may request marriage
is available in the
When the ground for the divorce
irretrievable breakdown of the marriage, you
counseling. A list of marriage counselors
Office of the Prothonotary at:
Offica of the Prothonotary
Cumberland County court House
carlisle, PaTsylvania 17103
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 HELP:
Court Administrator, Fourth Floor
cumberland County Court House
Carlisle, pennsylvania 11103
(111) 240-6200
BDWIN L. KEPPLEY
Plaintiff, ) IN THE COURT OF COMMON Pl.EAS
) CUMBERLAND COUNTY, PENNSYl.VANIA
vs. )
)
) CIVIl. ACTION - LAW
FREDA H. KEPPLEY )
Defendant. ) NO.
)
) IN DIVORCE
#.11.11080 COIIPLAIII'1' IN DIVORCE
AND NOW comes Plaintiff, Edwin L. Keppley, by his attorney
Gregory J. Katshir, Esquire with the following Amended Complaint
and prayer for relief wherein it is set forth as follows:
COUNT I - DIVORCE
1. ~our Plaintiff is Edwin L. Keppley, an adult individual
residing at 520 Walnut street, Apartment 4, Lemoyne, CUlllberland
County, Pennsylvania.
2. The Defendant is Freda M. Keppley, an adult individual
residing at 366 South Middlesex Road, Carlisle, Cumberland County,
penneyl vania.
3. Defendant is a national of the United states of America.
4. plaintiff and Defendant were married on October 17, 1987,
in York county, Pennsylvania.
5. Both parties have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months prior to the
filing of this Complaint.
"
6. There have been no prior actions for divorce or annulment
between the parties.
7. The Plaintiff avers that:
a) The marriage is irretrievably broken and is
irretrievably broken to the extent that the parties
are separated and will remain separated into the
future, for such a period as would extend beyond
that provided by law for the granting of a divorce
decree under the laws of our commonwealth.
8. The plaintiff acknowledges and avers that he has been
advised that marriage counseling is available to him, and to either
party, and has further been advised of his right to request that
this Honorable Court require the parties to participate in
counse ling.
WHEREFORE, plaintiff respectfully requests that this Honorable
Court grant him a decree in divorce.
Respectfully submitted,
Gregor . Ratshir, Esq.
Attorney for plaintiff
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VERIPICATION OF KNOWLEDGE. I~FORMATION AND BELIEF
I verify that the facts set forth in the foregoing
lIIIIended Complaint are true and correct to the best of my knowledge,
intormation and belief. I understand that false averments herein
are made subject to the penaltios of 18 Pa. C.S. section 4904,
relating to unsworn falsification to authoritieo.
DATE: JJ..,/II ) '1,1)
f I
fd~i ~
Edwin L. Keppley
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GREGORY J. KATSHIR
AlIorney at Law
900 Markel Street
Lemoyne, Pennsylvania 17043
(717) 763.6133. Fax (717) 763.9425
..... I. . ,
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. IPiCIN 1.. J<BPPLEY ) IN THE COURT OF COMMON PLEAS OF
) CUMBERLAND COUN'rY, PENNSYLVANIA
Plaintiff )
) CIVIL ACTION - LAW
VB. )
) NO: 95-6949 Civil Term
PRIDA M. J<EPPLEY )
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Detendant )
ACCEPTANCE OF ~ERV~
I, accept service of the Amended Complaint in Divorce on
behalf ot Defendant, Freda M. J<eppley, and certify that I am
authorized to do BO.
Date I
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36 South Pitt Street
Carlisle PA 17013
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GREGORY J, KATSHIR
Anorney et Law
900 Market Slreet
Lemoyne, Pennsylvania t 7043
(717) 763.8t33. Fax (117) 763.9425
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GREGORY J. KATSHIR
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(717) 763.6133' Fax (717) 763,9425
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GREGORY J. KATSHIR
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(717) 763.8133. Fax (717) 763.9425
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GREGORY J. KATSHIR
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900 Market Street
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EDWIN L. KEPPLEY,
PlalntllT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COIJNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: NO. 95 - 6949 CIVIL TERM
v.
FREDA M. KEPPLEY,
Defendant
: IN D1VOnCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this
malleI' on December 6, 1995 and served upon the delendant on December 18, 1995,
2. The marriage of plaintitl'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 veritY that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subje't to the penalties of 18 Pa. C. S. Section 4904 relating to
unsworn falsilication to authorities.
April -.:.r,,1996
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FREDA M. KEPPLEY ,f'1._ f.;
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GREGORY J. KATSHIR
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Alterney at Law
900 Market Street
Lemeyne, Pennsylvania 17043
(717) 763.6133. Fax (717) 763.9425
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BOWIN L. I(BPPLEY
plaintiff , ) IN THE COURT OF COMMON PLEAS
) CUMBERLAND COUNTY, PENNSYLVANIA
vs. )
~ CIVIL ACTION - LAW
PREDA M. KEPPLEY )
Defendant. ) NO. 95-6949 CIVIL TERM
)
) IN DIVORCE
PLAINTIFF'S ~IAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and
says:
1. I have been advised of the availability of marriage
counseling and understand that I may request 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 is available to me
upon request.
3. Being so advised, I do not require that my spouse and I
participate in counseling prior to a divorce decree being issued.
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.
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GREGORY J. KATSHIR
Marney at Law I
900 Market Slreet
Lemayn.. Pennsylvania 17043
(717) 763.8133. Fax (717) 763.9425
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EDWIN L. KEPPLEY,
PI.lnUIT
I IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION . LAW
: NO. 9S . 6949 CIVIL TERM
FREDA M. KEPPLEY,
DerendRllt
: IN DIVORCE
DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT
The plaintllT, being duly sworn according to law, deposes and says:
I. I have been advised of the availability of marriage counseling and understand that I
may request that the court rcquirc that my spouse and I participate in counseling.
2. I understand that the court maintains a list of marriage counselors in the
Prothonotary's Ollice, which list is available to me upon request.
3. Being so advised, I do not rcquest that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down.
I veritY that the statements madc in this allidavit are true and correct. I understand that
false statements herein made are subjcctto the penalties of 18 Pa. C.S. Section 4904, relating to
unsworn falsilication to authorities.
April S-, 1996
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