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Home My WebLink About00-02458 , , , . . . . . . --', -,',"-' .. . . .. . . . . . .. . .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ANGELA M. HESS, Plaintiff NO. Civil Term 00-2458 VERSUS VICTOR E. HESS, . Def.I'H'ldant , . . DECREE IN DIVORCE . . . AND NOW, ~("" I- DECREED THAT ANGELA M. HESS , PLAINTIFF, .2g' ?001 ,IT IS ORDERED AND . . VICTOR E. HESS , DEFENDANT, AND . . . . 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 . PROTHONOTARY . U~A4 . J. . . . . . . . . . .. '" '" '" Of. '" . . . ~< " . ''Ii , . . . , . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . ---j~ ,- ,< --',>",,-- .:.;" "~.; " - ',' - ANGELA M. HESS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-2458 CIVIL TERM VICTOR E. HESS, Defendant : CIVIL ACTION - DNORCE AND CUSTODY PRAECIPE TO TRANSMIT RECORD TO THE PROTIIONOTARY: 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 330l(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified mail on Victor Hess, Defendant, by certified mail on April 28, 2000. 3. Date of execution of the Affidavit of Consent required by Section 330l(c) of the Divorce Code: By Plaintiff: August 16, 2001; By Defendant: August 14, 2001. 4. Related claims pending: None. 5. lndicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 330l(d) of the Divorce Code: Waiver of notice executed by Plaintiff on August 16, 2001 and by Defendant on August 14, 2001. Respectfully submitted, J10 Auf19LZoc1( Date C_~~Q Robert P. Kline, Esquire KLINE LAW OFFICE 714 Bridge Street Post Office Box 461 New Cumberland, PA 17070-0461 (717) 770-2540 Attorney for Plaintiff .1::: ..'.'.'hi"., , ,.o,.----:-~"~ .'"""~ " ,~'V ",,,,. ,."w'~Yi ,'f,,';\ .,',. ,e.,. " ,,'...; <2 0 0 -- -(\ '" ~ ~I~-n -ocJ'; ',? ~q', G> '~;\\5 ';2:\:;,. -r-..) ~<. r...:> ':.:}() r:;G' -_.:. ~'. , ~. ~i~\ ~- -.' ~C) -' ;r.:..Q - YC ,:.; .". z.. ,-'" ~ :2 (1) , - ~- - "", ,'-",~ d,.-"__~c~,~,.,,,j':"'~'.-"< ';<",. 'J"~',,,,,,', , "- --;- ""-"'~' ,-",~,,,,,, -"", ""-..>I:. , "' , '" C.' _ ~', 0 ANGELA M. HESS, Plaintiff v. ; IN TIIE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00- .2 'f S- JY CIVIL TERM VICTOR E. HESS, Defendant : CIVIL ACTION - DNORCE AND CUSTODY ORDER OF COURT AND NOW, this :;24'/1- day of ftfA ,-I , 2000, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before "j)Ii.WN ). s:'~i [>'1 ' the conciliator, at 31 JJ fl{q:... <=it f11Lc la-u'cs/vr; on the 'G-ln day of ~ ' 2000, at ~M, for a Pre-Hearing Custody Conference. At such Conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to enter into a temporary order. All children age five or older may also be present at the Conference. Failure to appear at the Conference may provide grounds for entry of a temporary or permanent order. FOR TIIE COURT, r 11 I: V Ii ~: , l; By: Custody Conciliator v < ( ~~'1 . I Lf,iJ 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. 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 . ,,-, , If- d.s" t:/j ~-dS "t9tJ ~OJS" 01 . , ""-, "'^',"" U;": ' (",-) '--,'J ., :,)7it--7Y 'J. <::J P,',' '" J: ,;:;'5 eflt,,:, --j7s;i~r~,L./\,",,::,) if i I) :....I\];\,,(:\}/I} t '--'~;l"i'I-I-\,J" ~,J . ,/ '1 ,\,. " ""'i-I--'\,I/\ I td_~~-0 4~ ~~~~" ~ ~ ~ ~~~ ., ,-..,~ "..#1J_ , ANGELA M. HESS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00- ;;LLJ:f:f CIVIL TERM VICTOR E. HESS, Defendant : CIVIL ACTION - DNORCE AND CUSTODY 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 will proceed without you and a decree in divorce or annulment may 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 First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE TIllS 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 '- ~-- "', I;; 1'1 , ~ ~~i . f! ~ : n i,; ~ I ~] '. lj l- II [,: , I' lJ 11 ,. " ~~ "." '" :;; ANGELA M. HESS, Plaintiff v. : IN TIlE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-.;2 '16'7 CIVIL TERM : CIVIL ACTION - DIVORCE AND CUSTODY VICTOR E. HESS, Defendant COMPLAINT IN DIVORCE AND CUSTODY 1. Plaintiff is Angela M. Hess, an adult individual, currently residing at 1819 Anna Street, New Cumberland Borough, Cumberland County, Pennsylvania. 2. Defendant is Victor E. Hess, an adult individual, currently residing at 2400 Market Street, Apt. B-83, Harrisburg, Dauphin County, Pennsylvania. 3. Plaintiff and Defendant are bonafide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on December 28, 1991 in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Defendant is not now a member of the Armed Forces of the United States of America, or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties have lived separate and apart since February 25, 2000, and continue to live separate and apart as of the date of this Complaint. 10. The parties' marriage is irretrievably broken. I ~ , ~, .' 11. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. COUNT II CUSTODY 12. Paragraphs 1 through 11 are incorporated herein by reference as if set forth in their full text. 13. Plaintiff seeks custody of her children, Brittany Lynn Hess, born September 18, 1992, and Jayda Rose Hess, born September 1, 1998, currently residing at 1819 Anna Street, New Cumberland Borough, Cumberland County, Pennsylvania. 14. The children are presently in the custody of Plaintiff. 15. The children have resided with the following over the past five years: Name Address Date Plaintiff and maternal grandparents 1819 Anna Street 2/25/00 to present New Cumberland, PA 17070 Plaintiff, Defendant and maternal 1819 Anna Street 3113/99 through grandparents New Cumberland, P A 17070 2/25/00 Plaintiff and Defendant Fort Bragg, NC 7/98 to 3/99 Plaintiff and Defendant Fort Benning, GA 6/95 to 7/98 16. The natural mother of the children is Angela M. Hess, currently residing at the above-stated address. 17. The natural father of the children is Victor E. Hess, currently residing at the above-stated address. 18. The relationship of the Plaintiff to the children is that of natural mother. 19. The relationship of the Defendant to the children is that of natural father. - ", ',~ "" 20. The Plaintiff has not participated as a party or in any other capacity, in other I I ,:,j .' : ~ t:i I! 22. The best interests and permanent welfare of the children will be served by granting .' I'; I H ii Ii ii ,i " [,: I: ,i [-'l ;, ;,i litigation concerning the custody of the children in this or any other court. 21. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. the relief requested because the Plaintiff is the primary care giver with respect to the children. [:': 23. Each parent whose parental rights to the children have not been terminated and the f'i ii person who has physical custody of the children have been named as parties to this action. No ~! other persons are known to have or claim to have any right to custody or visitation of the children 1,: i', i,i Ii ;'i I d other than the parties to this action. WHEREFORE, Plaintiff requests your Honorable Court to grant to Plaintiff primary physical custody of her children, Brittany Lynn Hess and Jayda Rose Hess, subject to reasonable rights of partial custody and/or visitation for the Defendant. Respectfully Submitted, ~': n ::1 t<\.~, ~ Date ~~ ROBERT PElER KLINE, ESQUIRE 331 Bridge Street, Suite 350 Post Office Box 461 New Cumberland, PA 17070-0461 (717) 770-2540 Attorney for Plaintiff ., <I Ii 11 Ii I i1 , ~, ,~ "'I '. I" "I ~; i;' ,,', !r-i .]i I,' "i I' ,. 1'1 i' i 1') U ',:i Iii H i:~ :,I ii !:1 i,1 ,,) ":1 !i.l ]:1 'I 1:, II 1" 'II i;1 i'! ii f;'j ~' i , ]i,1 i::! H ~i "I , ,;1 :~ '1 ~-- :1 " 11 ! II II II ,I II II I I VERIFICATION I verifY that the statements made in the foregoing Divorce and Custody Complaint are true and correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. Section 4904 relating to unsworn falsification to authorities. tf I fI(,/oD Date ~i /Ii!.., A M. HESS gj~"~~~jrJW.l!~~'lJ~J '"Ili'''~!i<l~~->IIt\illl,~~~.<<I'~~ll ~ w,_ - ~ !Il' - ~~ lWr.~ 1""'............ ~~~ =" C) S; ~i~:i -;,/,,'..'.' 'D -';;': "- ::< '" - <-~ (...::~ """ ~':J :';J ~;, ,~ >.,J &- \ P n I t 'C \ I:) \.:> ( r en -rJ r--.,) .1--__ -':,. ~.-) (~5r(\ ~-;: "-., ,~~J -< .:J1 --.\ c_ ., _c' ~,,- ";-'-'---'.' ,,-;,', '~".,.- - - '_,-~---" ANGELA M. HESS, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff vs. NO. {}1J..2 'I s-f" CIVIL TERM VICTOR E. HESS, Defendant PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Respectfully submitted, I' II I' ~ ! I 1.1 tJ fl i d d Kindly allow Angela M. Hess, Plaintiff, to proceed in forma paulleris. I, Robert Peter Kline, Esquire, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to paythe costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs oflitigation is attached hereto. _\ '\. ~f \ 2cuD DATE ?~ ROBERT PETER KLINE, ESQUIRE 331 Bridge Street, Suite 350 Post Office Box 461 New CmnberIand, PA 17070-0461 (717) 770-2540 Attorney for Plaintiff ftUc.a.A 1\'1., OOS IN THE COURT OF COMMON PLEAS OF Plaintiff v. CUMBERLAND COUNTY, PENNSYLVANIA fT1). ,;}.'!{''? NO. ~ CIVIL TERM \llC.Tol1.. f, ~ Defendant AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am the plaintiff/defendant in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: A"'eJp/a I~p<;,,> Address: I gig Anna SJ.. Np"J C,M6.JQ/\,..{, !1 11070 Social Security Number: 7../')'1- L{1,-n7?3 (b) presently employed, state 170"'/; <;<;{")n 1.L+".1 C nmp '-I; II ey(h," (0.,...,,0 f./; If. P4 On II If you are Employer: Address: Salary or wages per month: Vn"'5 Type of work: TJy,,,,?/,~t S"",IPJ' If you are presently unemployed, Date of last employment: 4 z.t3!4 + bp5 n'''''~J' (0- ?o{.....,o (li, ,,>=1:. , state -.......,.,.-"-. :1 'I i I, ij II i' rj 'I I 'I " I,j 1j :i I I I I I' i-i ,I I' I ,-, '~ " "" "~- ~ ~,' ,- ,.," Salary or wages per month: Type of work: (c) other income within the past twelve months Business or profession: other self-employment: Interest: Dividends: Pension and annuities: social Security benefits: Support payments: :$ I ,{~ Lj Disability payments: Unemployment compensation and supplemental benefits: - r}"L-I supporl- , Workman's compensation: public Assistance: other: (d) Other contributions to household support (Wife) (Husband) Name: If your (husband) (wife) is employed, state Employer: Salary or wages per month: Type of work: contributions from children: (e) property owned Cash: Checking Account: jj I SD ....," ,1'- ,,- '"";J . , Savings Account: :IJ 4?D Certificates of Deposit: Year )9CJn Amount owed ?l Stocks; bonds: other: (f) Debts and obligations Monthly Expenses: $.3C>.(J}.y'J' ) ?J.1.l .,,,J,c}' IfZ<;-<ru.J;/-cnrrl (pari'pwd b.{ Px, sk,~(Js) , lIb. c(<'<Of}. ,^II.366. toc u;..) /A'I()-IO" lZiJ, n rt"lI;k,,, 11 roo ~ />/\ , ;j Z-.,,) - dodo,- h, / / (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: K"'d Iy" Name: . Ar,!-IaflY, ~~rfQ.. Age: 12, 71 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. 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: t:/JiL//OO , 1,.1 fl Ji'9 , 'JA~ilt!!lB~il~!..""b"!~~",~Ii\ilIlii~llliJl;!m.il-&'ii..,;:~(i<I'~~ ~" " < "," -~, llil-- .......~ ~,. " (') ~ ~[P ~'- 0)"0:-' f:: f~, ~~E~ )>c ~ -< l!!I&t1.iilUMM M' - ~, c;: C::.} ~ C') ''','' :"";-:J I) r-;-:: ,:~-j t..G ;"'j . ,-, ['...::: (~ iTI :.n :'-:':0 -<. 'D I'!> - - ~ - ,~;':- ' '--.'.--- c..;; ;__~ ' ",_'. ",' ,_' ".:&:.,;- '~-:i ANGELA M. HESS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-2458 CIVIL TERM VICTOR E. HESS, Defendant : CIVIL ACTION - DIVORCE AND CUSTODY AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a certified copy of the Divorce and Custody Complaint filed in the above captioned case upon Victor E. Hess, Defendant, by certified mail, retmn receipt requested on April 26, 2000, addressed to : Victor E. Hess 2400 Market Street, Apt. B-83 Harrisburg, P A 17103 and did thereafter receive same as evidenced by the attached Post Office receipt card dated April 28, 2000. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. I UNDERSTAND THAT FALSE STATEMENTS HERElN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. z.. '/t'\A-'-{ ? cY"'-" Date c-~~ ~ gO. RO ERT PETER KLINE, ESQUIRE 331 Bridge Street, Suite 350 Post Office Box 461 New CmnberIand, PA 17070-0461 (717) 770-2540 Attorney for Plaintiff 'Gi 96111DIi!R: " 'iij ~ ~ ~ .Il., '. .,1 + Z 284 664 151 Special Delivery Fee Restricted Delivery Fee '" '" '" I also wish to receive the' follow- ing services (for ah extra fee): [J Complete items 1 and/or 2 for additional selVi(:es, Complete lIems 3, 4a, and 4b. [J Print your name and address on the reverse of this form so that we can return this card to you. p Attach this form 10 the front of the mailpiece, or on the back if space does not permit. I IJ Write 'Retum Receipt Requested" on the mai!plece below the article number. [:J The Return Receipt will sr,ow to whom the article was delivered and the da1e I:Illlivered. 3. Article Addressed to: m .c ~ c o I 1. 0 Addressee's Address 2, yf Restricted Delivery t9i7 .d-f'.. 17 10.3 4a. Article Number C oZJ-1 t,t, '-/Is? 4b. Service Type Registered o Express Mail D Return Receipt for Merchandise /lle7o~ E. fJ aSS :z,'IotJ mHkli7 0:;: ~sl3urec. ;2A Ott;ertifled ; o Insured eJ 5 o >- .!!! PS Fonn 3il11 , December :994 102595-99-6-G223 ~ ai' .. ~ G), <P I: l III ~ : .E [~' -"" c' ; '", ,c" .... iji~'-~""" "~'iliUH", ,-~.. d~ilu-i "'~"",.-, " ~ ~. ;.~:-, ~.w,- " ,'-' .,. '.----1 (') 0 ~ C 0 -~ :I: .... S. -o-OJ .~ :,t;:!J rnrT\ -< ; \ '1_'_ ;~:';r.' I -)j{Ti t;S N :~O(""1 '")~, ~~.t, -'-j...:! ""'-....... --0 :;~ -T1 ?io ~ ~.:;;::(::s ~g ~ c5fTI ,_. ~ 0, -p; :;:, -< " " '=1ill ANGELA M. HESS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-2458 CIVIL lERM VICTOR E. HESS, Defendant : CIVIL ACTION - DIVORCE AND CUSTODY AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 19, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of the final Decree of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STAlEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA. C.S. SECTION 4904 RELATING TO UNSWORN F ALSIFICA TION TO AUTHORITIES. ~116/ClI Date 1i.1.. pi JL AN LA M. HESS SS : 209-46-0723 mllliliidll!f' ~,,~~, i ~,~~ ....1Il1ill!!i/Wli-' =,,' .l1 ~ "'-WliIIl~--~ nrr-f""'-.--"'- -, ,," "~ ~-' ~~- -" ., ~ "' 1~' 0 0 Cl C "\~[ :? "'" -Urn ,. n',[!:, in , '!'''- Z.-,_ ZC N ~?i:l:~ ~?: f'-' ._~-' .'-, ~C:J -0 . ~ ~~.~ >c} :-~ ~~~ ~i:) :PC ~ -j ,:,.) 5J ro -< 1 \.' . I I I ANGELA M. HESS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V ANlA v. : NO. 00-2458 CIVIL TERM VlCTORE. HESS, Defendant : CIVIL ACTION - DIVORCE AND CUSTODY WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. <g J Iv f oj Date ~J.?IL, AN A M. HESS ZD - '(I. - 07"8 o C :? -am rnrT1 ~~ ~~: r::::C! J>~ 2:'-': ~~ =<! - -^, N'^ ,. 'J I"~: :) " ! o o -T'l , --1""._._ ::-\1 ;.~ r-; >~ ',..1 ~.~j~: Om 5~ ::0 -< :"'" G"} N f'.) """'C.'! '"^' m . ~~ ~, ,,--~- , .-, ~"",,",'! , ANGELA M. HESS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-2458 CIVIL TERM VICTOR E. HESS, Defendant : CIVIL ACTION - DIVORCE AND CUSTODY AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 19, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of the final Decree of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. rS//cj /(7/ Date' ~d~ VICTOR E. HES SSN: 171-56-4252 - lijdd ~', -.;,L'~iM "--"""'~" ~ ,- ~ ~-~~ ^,""",,,",.~';'~ .~ ........ ,~ -~ """'" ^< ^,}"; , o ~ :::-= ""OeD mfT; Z:tJ ze:- UJ-d-;:' -<~- CC ~C) L.a )>c:: ~ ~. ~ "-; [, I, f I' i',.'.'...,! 'J , i< I 1 i , <=> ('} -n ~ G"J N '''' ::::1 'h~-: ---,!---r! _.0--:_,-', ---.1 ::.-=;~} ,.. " _-C" -1"1 (,?(-) Off: :9 :D -< .''0 3 '-..:> co "-~_. %- ANGELA M. HESS, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-2458 CIVIL TERM VICTOR E. HESS, Defendant : CIVIL ACTION - DIVORCE AND CUSTODY WAIVER OF NOTICE OF INTENTION TO REQlJEST ENTRY OF A DIVORCE DECREElTNDER SECTION 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. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. f5//tfOj Date ' ~ VICT R E. HESS .1I(;lfiN , , J......:liI........IUIlllll-m=' -*'jjlt1~ -~ L ~~.",,~,~~. = '--'';'~'''~\- ,]~ - "~ '~.-..;. . ~~.- ..;..... ~~~ _"-~""SI<ld!li"_ '--"~-'-;:::: til' ,.'," :i l~: ! ! ~i I' () 0 () I c: -n i :?" ",. ~ -0(.0 "..- -'-1 FTlfTi G") Z:::::J N ',,7'--n V5~j.: f"0 -'~-: 0' , , -<~.- "'l':d !<C " ~~fS PC) ;:}~ :;:';6 ;:::.,nl Pc: :=/ ~ '0, :...:J 5:J CD -< , ",,; ,,-.'" '. ,___ '-:,'.h' ") i I .' ANGELA M. HESS, : IN THE COURT OF COMMON PLEAS OF plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. : NO. 00-2458 CIVIL TERM : VICTOR E. HESS, . CIVIL ACTION - LAW . Defendant . CUSTODY . ORDER OF COORT AND Nail, this .!Z I" consideration of the attached and directed as follows: day of 1.""""- CUstody Conciliation , 2000, upon Report, it is ordered 1. The Mother, Angela M. Hess, and the Father, victor E. Hess, shall have shared legal custody of Brittany Lynn Hess, born September 18, 1992, and Jayda Rose Hess, born september 1, 1998. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education and religion. 2. The Mother shall have primary physical custody of the Children. 3. The Father shall have partial physical custody of the Children on alternating weekends from saturday at 9:00 a.m. through Sunday at 6:00 p.m., beginning Saturday, June 17, 2000. The Father shall have custody of the Children for up to 2 evenings per week for a 3 hour period at times to be arranged by agreement of the parties. The Father may also have custody of the Children at any additional times agreed upon by the parties. 4. The Father shall have custody of the Children every year on Father's day from 9:00 a.m. through 6:00 p.m. and the Mother shall have custody of the Children every year on Mother's Day from 9:00 a.m. through 6:00 p.m. The parties shall make arrangements for custody of the Children on all remaining holidays by agreement. 5. The parties shall equally share the responsibility for transportation of the Children for exchanges of custody. BY THE COURT, cc: Robert P. Kline, Esquire - Counsel victor E. Hess, Father /IlL J..~ C~ 1i~g: ~ <t-~ ) / ..... T' 'c"\-"I '"<.iT Any 00 .J!.?',] 2 2' 1" n I. S ! curv18;:H~./-I:\IJ CUUNTy' PENNSYLVANIA "'-.'-