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Home My WebLink About00-03663 -,'; "--'-, "" " - ~,.- ,---" oj--_-, '", ,'_ ~,. '-..,' ~~.XX*1f.:~::;~<&:::Xff:'~X.X::.;3I>XX.~:X.XJ;~C"J;~<&:)3&::XC;:::)3&:i~.X::;~;:X.X:::;~.X)~C'n;~c;:::::;~C;:)}lXC:_.Ji1S,>>~n;~C'l\li::C<1T:<.X;;~:.;:;3&"1I~''ill:;1 y ~.,.~. N. t.;r< ~ V t:t ~ ~ ~"~ i IN THE COURT OF COMMON PLEAS ~ ~.~ OF CUMBERLAND COUNTY ~ ;:t ~ ~.~ e h ~ e ~-', >-~' ~ ~ li'.~ i ~ --- " ~ ~ y I ~ J...::. _. *::. .>>::. ">>> _. *::. .:c. .:c. <<t:::-.:c. .:+::. .:€. .:+> .:+~+::. .:+:::. ~. .::+::. :;':.::';:::::':.::.;;:::~:.::.',::::.:::.:::.'::::;.::.::',:::;.:.::~:.::;.:.::...:::.::..::~,::::,.:.;..,:>:+::' ',<,,' ~ li'.~ ~~~ ~ v ~ ~ ~.~ ~ ~'s , ~ ~ ~.~ ~\ ,"'. ~.~ * ',,' ;..s ~ ~":~ ~ M ~ ~.~ ~ ~ t~ ~ I "",, .".* ~ "'." ~ '"'' ~ ~ li'.~ ~ ~ i ~.~ ~.~ ~ ~.; ~ ~.~ ~ :,',; ~ li'.~ STATE OF PENNA. DIJ~()~u L: u 1i:E1-JSI:~' N O. .........u...O.O'~.3663...~~.'?:.1., Itym Plaintiff Versus R.IlJfJ\RDu R, JIE}jSEL , lli fell<l1m t DECREE IN DIVORCE AND NOW, ..J.~r! y~ 1-.. ..I.~.. .. .. " ~ .ZQQl., it is ordered and decreed that.. . . . .. ..1?~9~.r,.: ):ll?~1?r,.. . , , .. , . . .. .. .. .. .. .. ", plaintiff, and. .. . . .. . . .. . . .. . , . RI.QIARD. R.. RE.N.Sl3.L , . , .. .. , . .. , . .. .. .. ", defendant, are divorced from the bonds of matrimony. The attached Sep::ration . Agreenent is incorporated, but not merged, and made a part of thlS llicree m Divorce-I:. ' , . d' t' f h f II ' I' h' h h IlIe court retains IUrlS IC Ion 0 t e 0 OWing calms W IC ave been raised of record in this action for which a final order has not yet been entered; . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , .................,.... ,.................................. Prothonotary ~.~ ~ ~ a ~.; ~":~ ~ ~ 'd a li'.~ ~'S ~ I ~ i ~.~ ~.~ ~ ~ ....,. ~ ~.~ ~ . ~:~ e ::"~ ~ ~~ ~.~ ~ ~.~ ~ ~', i ~.~ ~.'~ ~ ~~~ ~ ::;,; ~ t';, Q ~.~ ~.~ ~ ',"; i y "S ~ ~ y f.~ ~ ~ ~.~ J. ~ 'l $ ~ ~.~ 1 I I , I I: ~" '0.,." ." , '.' .....I!I\!!.. ~-, / 2(}., -0/ / o'~d -0/ ,", ,. . .~ . I: -t", t \. . tal t't?1/ IU:J1; ~ 4 ~ 11~ ~ Z tiff- , ". , '~I'1I!'~ J!JWf!!iIm~,_" "" .rw---1!lHili'l ,~ ,? '. ",., " "'" ~ - "'- ," .' . , .. SEPARATION AGREEMENT THIS AGREEMENT, made this if'b~ day of rtVL~. 2000, by and between DEBORAH L. HENSEL, (hereinafter called "Wife"), and RICHARD R. HENSEL, (hereinafter called "Husband"); WITNESSETH: WHEREAS, the parties hereto are Husband and Wife; and WHEREAS, the parties have come to an agreement between themselves regarding their respective financial and property rights and obligations and wish to have said agreement set forth in a'written document which could become effective immediately but which would become incorporated in a Decree in Divorce if such Decree is entered in the future; and WHEREAS, the parties have jointly retained Richard S. Friedman, Esquire as attorney for the purpose of drafting a written agreement setting forth all of the terms and conditions of an oral agreement heretofore reached by the parties; and WHEREAS, each party further acknowledges that he or she has the right to be represented by independent counsel of his or her choice to advise him or her as to his or her rights and all matters between the parties hereto relating to ownership of property and settlement of other financial matters between the parties, but neither chooses to avail himself or herself of said representation; and 1 , ~-l.. ".' . . .. ," , , .' ., ',' WHEREAS, both parties further declare that they are executing this Agreement freely and voluntarily, and that said Agreement is fair and equitable and sets forth their wishes. regarding the settling of the matters contained herein, is not the result of fraud, coercion, duress or undue influence, and that neither party wishes to retain independent counsel to advise him or her, although he or she has the absolute right to do so; and WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the present intention of Wife and Husband to live separate and apart, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other including, without limitation by specification: the settling of all matters between them relating to the ownership of real and personal propertYi the settling of all matters between them relating to the past, present and future support and/or maintenance (alimony) of Wife by Husband or of Husband bywifei the equitable division of marital property; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. 2 ~"'$:~J' ., , -"~ " '","'" ," " " " NOW, THEREFORE, in consideration of the mutual promises, covenants and undertakings herein contained, the parties hereto, each intending to be legally bound, agree as follows: 1. Wife and Husband both acknowledge that the within agreement was prepared by Richard s. Friedman, Esquire and the firm of Friedman & King, P.C. (hereinafter interchangeably referred to as "Friedman"). Friedman has represented both Husband and Wife in various matters in the past and moreover, is personal friends with both Husband and Wife. Both parties acknowledge that Friedman advised them that he did not wish to provide any services relative to the within agreement or any pending divorce action, but, out of respect for the wishes of both parties, Friedman ,has agreed to act only as a scrivener to create the within agreement, which embodies the terms which Husband and Wife have previously fully agreed to between themselves and which Husband and Wife have related to Friedman. The parties acknowledge that Friedman did not in any way participate in negotiatiorisbetween Husband and Wife, nor did Friedman giveanyaclvice,t()'~usband or wife as to his or her rights or responsibilities. Both parties acknowledge that Friedman advised them tos~~k separate arid independent counsel. By executing the within agreement, both Husband and Wife acknowledge that they have sought the advice of said independent counselor choose not to do so, and by signing the within 3 ,. ,~ '0' -. .", ~,~ ~!<R':" . ,', . , ',' '" agreement, both Husband and Wife waive any conflict of interest which they could otherwise assert against Friedman. 2. Wife and Husband may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully.asifthey were unmarried. They may reside at such place or places as they may select. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to him or her may seem advisable. Wife and Husband shall not molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to comp~l the other to cohabit or dwell by any means in any manner whatsoever with him or her. 3. During the said separation, the parties shall have the right to live as though they were unmarried and their conduct during the separation shall not give rise to additional grounds for divorce which do not presently exist. 4. This agreement shall survive any action for divorce and decree of divorce and shall forever be bindin~ and conclusive on the parties, and independent lega"1 action may be brought .to enforce the terms of this agreement by either Husband or Wife until it shall have been fully satisfied and performed, The consideration for this contract and agreement is the mutual benefits to be obtained by both of the parties to the .other. "The 4 'd ~' -j . f ,,' ',' adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the parties, and the parties intend to be legally bound hereby. 5. Husband and Wife each do hereby mutually and severally remise, release, quitclaim and forever discharge the other and the estate of such other of and from any and all rights, title and interest, or claims in or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way or dower or curtesy, or claims in the nature or dower or curtesy or widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate or any rights which either party may have or any time hereafterhave'for pa~t, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result' of the marital relation or otherwise; except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for any breach of any provision hereof. It is the intention of Husband and Wife to give to. each other by the execution of .' 5 , ~j this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision hereof. 6. The parties are joint owners of a house situate 1912 Logan street, camp Hill, Pennsylvania, with a value which both estimate is between $120,000.00 and $135,000.00. Wife shall receive sole and exclusive possession of said premises. Concurrent with the execution of the within agreement, Husband agrees to execute a Deed transferring his interest in sUbject premises to Wife. 7. The parties acknowledge that the premises at 1912 Logan street, Camp Hill, Pennsylvania, is encumbered by a mortgage in the amount of $3,000.00. Husband shall be solely responsible for said mortgage and shall indemnify Wife and hold her harmless therefrom. Husband's payment of said mortgage shall not be treated as spousal support or alimony and therefore shall not be deductible to Husband nor includible by Wife for income tax purposes. 8. Husband is the owner or equitable owner of property situate 545 Brandt Avenue, New Cumberland, Pennsylvania, being a four unit apartment building purchased by Husband in July of 1999. The parties acknowledge that Husband's equity in said 6 '-- , property is approximately $10,000.00, being the down payment tendered by Husband. Husband shall receive sole legal and equitable title to subject premises. wife agrees to execute, now or in the future, any documents necessary to effectuate the intention of the within paragraph. Husband agrees that in five (5) years from the date of this Agreement, he will cause Wife's name to be removed from the mortgage and bond securing subject premises. If he is unable to do so, he will list the property for sale within thirty (30) days thereafter. In addition, in the event Husband is in default for a period of ninety (90) days under the terms and conditions of said mortgage, Husband agrees to immediately have Wife's name removed from the mortgage or list property for sale. 9. Husband is the owner or equitable owner of property situate 201 s. Market street, Mechanicsburg, Pennsylvania, being a four unit apartment building and a store purchased by Husband in December of 1998. The parties acknowledge that Husband's equity in said property is approximately $15,000.00, being the down payrnenttendered by Husband. Husband shall receive sole legal and equitable title to subject premises. Wife agrees to execute, now or in the future, any documents necessary to effectuate the intention of the within paragraph. 10. Wife shall retain as her sole and exclusive property an Individual Retirement Account in Wife's name, which the parties acknowledge has a value of approximately $4,000.00. 7 -;!sw:",J I I I 1 '[ :1 \1 I, I II II II 11 II II ij l 1.[ " I' II !'I II 11 11 ',I Ii I J I , , ~~ ""'-- , ~. < <" 11. Wife shall retain as her sole and exclusive property a savings account in Wife's name, which the parties acknowledge has a value of approximately $3,000.00. 12. The parties jointly own stocks which they estimate to have a value of approximately $10,000.00. Husband shall receive sole and exclusive ownership of said stocks. Wife shall now or hereafter execute any documentation required to effectuate the intention of the within paragraph. 13. The parties acknowledge that Husband earns $44,000.00 per year as the Manager of the Executive House, and Wife earns $22,000.00 per year as an employee of Stephenson's Flowers. 14. Husband shall pay all household bills for the property at 1912 Logan street, Camp Hill, Pennsylvania, including but not limited to taxesW!lw'~i ~ef.,insurance, maintenance, and shall $ 4tJ ,00 ~~o /Jsl"fI 0~7-06 pay Wife ~s.eo r w ek for groceries and household supplies through August 1, 2000. Said payments shall not be treated as spousal support or alimony and therefore shall not be deductible by Husband nor includible by Wife for income tax purposes. 15. The parties agree to jointly file a 1999 income tax return. Any taxes owed to local, state or federal government shall be payable by Husband. Any refund due to the parties from local, state or federal government shall be divided equally between the parties. 8 - ..'~ ~," " <~, ~= . , 16. Husband shall be solely responsible for all joint debt outstanding at the time of execution of the within agreement, and shall indemnify Wife and hold her harmless therefrom. 17. Each party shall retain the vehicle or vehicles currently titled in his or name. 18. The parties acknowledge that they have divided all of their personal property not set forth herein to their mutual satisfaction. 19. Wife agrees, within ten (10) days of execution of the within agreement, to file a no-fault Complaint in Divorce under Section 3301(c) of the Pennsylvania Divorce Code. Husband shall be responsible for all costs of filing, serving and finalizing said divorce, including the attorney's fees of Friedman. Husband agrees to immediately accept service of said complaint by certified mail. Both parties agree upon expiration of the mandatory waiting period, that either will, within five (5) days of request by the other, execute an Affidavit of Consent and other necessary documents to enable said divorce decree to be finalized. 20. Each party waives any right to alimony, alimony pendente lite, spousal support, and further distribution of marital property other than that set forth herein. 21. Each party represents and warrants to the other that he or she will not incur any debt, obligation or other liability other than those already described in this Agreement, on which 9 - ~ !~;, ,. .' the other party is or may be liable. Each party covenants and agrees that if any claim, action or proceeding is hereafter initiated seeking to hold the other party liable for any other debt, obligation, liability, act or omission of such party, such party will, at his or her sole expense, defend the other against any claim or demand, whether or not well-founded, and that he or she will indemnify or hold harmless the other party in respect to all damages resulting therefrom. 22. The parties acknowledge their date of separation to be October 1, 1999. 23. This Agreement shall not be considered to affect or bar the right of Wife or Husband to a limited or absolute divorce on lawful grounds if such grounds now exist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed to be a condonation on the part of either party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which have occurred prior to or which may occur sUbsequent to the date hereof. 24. The parties agree to elect to have the provisions of section 1041 of the Internal Revenue COde apply to all qualifying transfers of property after December 31, 1983. The parties understand that Section 1041 applies to all property transferred between spouses or former spouses incident to divorce. . .The parties further understand tha.t the effects for federal.income 10 _ '" . __ ~ _;, " 0... - ~ - .0;.0",:, tax purposes of having Section 1041 apply are that (1) no gain or loss is recognized by the transferor spouse/former spouse as a result of this transfer and (2) the basis of the transferred property in the hands of the transferee spouse/former spouse is the adjusted basis of the property in the hands of the transferor spouse immediately before the transfer, whether or not the adjusted basis of the transferred property is less than, equal to, or greater than the fair market value of the property at the time of transfer. The parties understand that if the transferee spouse/former spouse disposes of the property in a transaction in which gain is recognized, the amount of gain that is taxable may be larger than it would have been if this election had not been made. 25. The parties consent to the provisions of this Agreement being incorporated, but not merged in the final Decree in Divorce obtained, in the action intended to be filed in the Court of Common Pleas of Cumberland County, Pennsylvania, as provided in Section 3105 of the Pennsylvania Divorce Code, and shall be enforceable by said Court. The parties further agree that pursuant to Pa. R.C.P. 1920.1 et seq., "The Divorce code", the terms, provisions and conditions 'of this Agreement shall be incorporated in the Decree in Divorce to be entered in the pending divorce action by reference as fully as though the same were set forth at length. This Agreement shall not merge with, but shall survive the Decree and any related Order. The parties 11 ~.- agree and intend that said incorporation is for the purpose of enforcement only, and shall not vest in the court issuing the Decree in Divorce any power to modify the terms of this Agreement. The parties further stipulate and agree that Section 31D5(c) of the 1980 Pennsylvania Divorce Code shall apply to the Court's enforcement powers, even if said Code is subsequently amended or repealed, and that there is no provision in this Agreement which grants the Court the power to modify this Agreement. 26. Each of the parties hereto agrees to execute any and all documents, deeds, bills of sale or other writings necessary to carry out the intent of this agreement. In the event either party fails to execute said documents, deeds, bills of sale or other writings, upon proper request Husband appoints wife as his attorney-in-fact and Wife appoints Husband as her attorney-in-fact for the purpose of executing said documents, deeds, bills of sale or other writings which are necessary or deemed necessary to fulfill the obligation of either party under this Agreement. 27. The waiver of any term, condition, clause or provision of this Agreement shall, in no way, be deemed or considered a waiver of any other term, condition, clause or provision of this Agreement. 12 - - , - - ..- - , . 28. If any term, condition, clause or provision of this Agreement shall, by its reasonable interpretation, be intended to survive and extend beyond the termination of the marriage relationship presently existing between the parties hereto, said term or terms, condition or conditions, clause or clauses, or provision or provisions, shall be so construed, it being the express intention of both parties hereto to have this Agreement govern their relationship now and hereafter, irrespective of their marital status. 29. If any term, condition, clause or provision of this Agreement shall be deemed to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement as is held to be void or invalid by a Court of competent jurisdiction and in other respects this Agreement shall be valid and in full force and operation. 30. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania, and both parties consent and agree to the jurisdiction of the Court of Common Pleas of Cumberland County; Pennsylvania, on account of any suit or action brought with respect to this Agreement or any provisions or matters referred to in any provisions thereof. 31. This Agreement sets forth the entire understanding of the parties and shall not be amended, altered or otherwise modified except in writing executed by the parties hereto. 13 -- ~, .' < '. 32. This Agreement shall be binding in all its terms, conditions, clauses and provisions on the parties hereto and their respective heirs, administrators, executors and assigns. IN WITNESS WHEREOF, the parties hereto have hereunto set their hands and seals the day and year first above written intending thereby to be legally bound. WITNESS; -1~~ ~ . ~ 1JeJx:J)a~d [1{M Q (SEAL) Deboreh L~ ~R Heneel (SEAL) /\ .f -co TSo\H afp:agr\hensel.agr 14 . . ~ ~ . COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF DAUPHIN On this, the d-~ day of./f11a...v- , 2000, before me a Notary Public, the undersigned officer, personally appeared Deborah L. Hensel, 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. seal. IN WITNESS WHEREOF, I hereunto set my hand and official ~/J2xuA,-7? -f~,-- COMMONWEALTH OF PENNSYLVANIA . . tiOTARI~~~~~~;PUbIlC' . IIARBARA E. PAL ,*,10 county Harrisb~rg, 2:urres May 17.2001 . My COlllmlsSIOO .,.? . SS: COUNTY OF DAUPHIN On this, the J-'7>vd day of t11Ct-U- ,2000, before me a Notary Public, the undersigned offiEer, personally appeared Richard R. Hensel, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seaL ~ '--C--f~PI ,... tiEO~~~~~ita~ pull\iq. BAR~:t~b~Tg, ~!U~~O M~~ur~ 200~ My com111\SSIOO .,.? 15 . llillr"'"" -'1Jlj;'i\ll!!M.'~~il'~:" ~~JI""1~~"- "--l]rli!d''-;''llItll6iirll~ . ~~ ~w.... ~ , ,-, () c -D(J Sf ~~:} 6~ :-~,-~ ~?l_J ~~C) ~~ ~~~ ='1 -<; -~ ~' , C) o -q --1 i:;:~F-g -,-,iTl o . -~. I " ..'j() ,~ ~LJ :..::~('-) h~~ in ::"D -< ,- I CD -r:> r:-? :.-.:> <:) m ,-..,--'-'- ,-, . "'--. , "'0< ",";-.,: ,-,,,,,:_,__,._. v_" _,_,_'__",;_, "n,'__',-c' . . DEBORAH L. HENSEL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-3663 civil Term RICHARD R. HENSEL, Defendant COMPLAINT IN DIVORCE PRAECIPE TO TRANSMIT RECORD 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. (strike out inapplicable section.) 2. Date and manner of service of the complaint: certified Mail, Restricted Delivery, on June 20, 2000. 3. Date of execution of the Affidavit of Consent required by section 3301(C) of the Divorce Code: by Plaintiff 1/2/01; by Defendant 1/2/01. 4. Related claims pending: There are no related claims pending. 5. (a) Date Plaintiff's Waiver of Notice was filed with the Prothonotary: 1/8/01. (b) Date Defendant's Waiver of Notice was filed with the Prothonotary: 1/8/01. Friedman, Esquire for Plaintiff Richard Attorn!liy i 'C' ~ " - "" '~.;,,"~ ^ . ~ ",C'''~'O ,~"~,.~ _"'~''''^~',. "o~-", ,'" - -~, .-.. J,,; ill' - '. '.,',",. ~q~r [1,'1. , 2:"':~" -:~~ ,-. (15). --< .,- [.:::C:' ~ l;:() L_,,_., s.:;C 2: -i -< ~:? ..' ".' .. " '.:J co :':: ;'0 ':0 C:) 1,' -- , -~ '-~-'.(.,' - '--"'-'"'. ~---"< _-,,,,"-,-_> - ,-.;. "'; ','.k:-""g;,j;:.."~,_~."t;;.' "-;'--':,'_-,"'" ." , ,-;,---'1 "T , . , .. . DEBORAH L. HENSEL, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00 - 2f..t..3 (I/Uil ~;L'I COMPLAINT IN DIVORCE RICHARD R. HENSEL, Defendant 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 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 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 Cumberland County Court House 1 Courthouse Square, 4th FIr. Carlisle, PA 17013-3387 (717) 240-6200 By: Rich rd S. Friedman, Esquire 600 . Second st., 5th FIr. P. O. Box 984 Harrisburg, PA 17108 (717) 236-8000 ~- -, . " , "-,.," -' , .- . . , DEBORAH L. HENSEL, plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. tJ(J- 3(,.(.3 ~ I~ : RICHARD R. HENSEL, Defendant COMPLAINT IN DIVORCE COMPLAINT UNDER SECTION 3301/0) OR SECTION 3301/d) OF THE DIVORCE CODE 1. Plaintiff is Deborah L. Hensel, who currently resides at 1912 Logan Street, Cumberland County, Pennsylvania 17011. 2. Defendant is Richard R. Hensel, who currently resides at 545 C Brandt Avenue, New Cumberland, Cumberland County, Pennsylvania 17070. 3. The parties have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 28, 1996, in Wormleysburg, Pennsylvania. 5. Plaintiff avers that there are no children of the parties under the age of eighteen (18). 6. There have been no prior actions of divorce or for annulment between the parties. 7. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. The marriage is irretrievably broken. ~.' --,,- '-'.-' ,,~" ,~.<"- ,..'" ". .'u,'~', - " ,~, - -.; {_~ , .~:: .- . . & 9. Neither Plaintiff nor Defendant is in the military service of the united states. 10. The parties separated on October 1, 1999. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, Date:~h\..L 1Jdtvt J Ric ard S. Friedman, Esquire 60 N. Second street Penthouse suite P. O. Box 984 Harrisburg, PA 17108 (717) 236-8000 RSF/bp:divorce\hensel.div ~" .- 'do. ',-~ ,~ ,,~, . ",-"_',,-_,,~,~., __, o"}, "I .- -, , . . VERIFICATION I, Deborah L. Hensel, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Complaint in Divorce; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. section 4904, relating to unsworn falsification to authorities. Dated: ~q(d6!J.), [)~h01tJt d. JJBVlSP~ Deborah L. Hensel , '-' .,". . ~ DEBORAH L. HENSEL, Plaintiff v. RICHARD R. HENSEL, Defendant < >_''; .''''';~''';:P,!1.f~';"''';' '. ~~., __~_" ,- '. ;" ',' ,_ ~'.-_~, ,'_ _~__"_"" ~ ' ., , IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-3663 civil Term COMPLAINT IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SS: Personally appeared before me, a Notary Public, in and for said Commonwealth and County, Richard S. Friedman, Esquire, Attorney for the Plaintiff, who, being duly sworn according to law, deposes and says that a certified copy of the Complaint in Divorce in the above-captioned matter was served upon Defendant, Richard R. Hensel, by certified Mail, Restricted Delive y, on June 20, 2000, as evidenced by the attached rtifi ail card. Sworn and subscribed to before ~iS ~ day of M_A', 2001. ~~~1aP~. .--~., ' f\lO'[p~RLIMA~~e:otary Public BARBARA E. " . c untY Harrl~b~rg. EDapU&~~n Ma~ 17, 2001 MY Commission x Richard S. Friedman, Esquire -, .v ~ SENDER: "'0 I'll Complete items 1 and/or 2 for addJtional services. Ow II'li Compfete Items 3, 4a, and 4b. Q) III Pnnt your name and address on the reverse af this form so that we can return this l'! card to you. g iii Atta.ch this form to the Iront of the mailpiece, or on the back if space does not e pelmit. Q) III Write "Return FleceiptRsquested" on the mailpiece below the article number :5 !Ill J~,fv~~~~n Receipt will show to whom the article was delIvered and the date 5 3. Article Addressed to: l-1~~~<~ r S-YS-G~< I~~~i f;4 I I also wJsh to receive the following_services (for an extra fee): 4b. Service Type o Registered i 0 Express Mail o Return Receipt ior Merchandise 7. Date of Delrery ~ . 1:)0: o-d 8. Addressee's Address (Only if requested and fee is paid) ~ " o ,.. !!2 Domestic Return Receipt .....-.... .. ress .:= 1:. 0>- <n '5.: -is " ..--.. ~ . E " -0. 0: '" " Ui ~ .e, " o ,.. '" " '" .<:: ... ~ , ,- ., -.. () '--' c ~ I : <"" -off n1fT: .2:...1. Zy V>_ l._~' 0<4 ~~ ~;~' r-,- ~- ""q Zc - , , 5>C T.-_ ~,....,. '-' Z { , ~ ::< "'- -:v , ,., " 1 ""..i , . DEBORAH L. HENSEL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-3663 civil Term RICHARD R. HENSEL, Defendant COMPLAINT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 16, 2000. 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. c. 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. S 4904 relating to unsworn falsification to authorities. DATED: ( ~ d- -0 ( /Jehopa J7 eX fJ~~ Deborah L. Hensel , ~ ,,,,"j~ mr '~~[Ifi!~JL , ~ C~ ~, j,~ " ..li>,~""'~""""'" ~. ~"' ~~ ,,-,'-- ,,;j .. > 0 c:o c..... c:: ~/ s:: "T} "t) J:L :t'"", .~ nllT 7,~2: ) ::..:~] Z-=C::. Z ,- , , ej) < G:l -. e) ....< .<-- r-. C:::C: ....J ::-=:" .- . , "f:c~ L.. ~ "-~ i-;:::; :sCI c: 1\...) :~ .. /.2: .J) ::r",; =2 C::i =D -< ..- - - ~ ~~ - _-'" , ~ r DEBORAH L. HENSEL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-3663 Civil Term RICHARD R. HENSEL, Defendant COMPLAINT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) AND 3301(D) 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. 4. 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. S 4904 relating to unsworn falsification to authorities. Date:~-d--61 OehowJ;cX Nmc~~ Deborah L. Hensel, Plaintiff r~'" l ~ ~ ;" ~~.'="" .- '~I~"''''''''~ "ilIIlllfi :il1id1','~~wl!,/.,.!Wi;~l<lliI;',l;hl!~~.J_ ;MI~ .< o"'.~, ~- '~-'J""", " ",. () C ::;:;:><< Uc~- nl}-2~ ~~~i -<'-;,., S( ~~:-' r:~- '::;:::'-- ;> z(; $)d ~ 2.:: :::! .' ....I.~ N :.,~) .CJ '~, .. c' C) "'71 i-~. ::;;" ;,;:: ,~ (X) ~Y':i '".~' '.,),J--.., -i::l~ ,:"'\--~ -'\"; () ~i" :.c -< -0 . "" .','h. . ",., "'"'.,', .","," ,'-'\5--, ;-~:,-;~<~\<,:>---~,=:~-,->.: ,;~;~::,.." ;~""",'.;,:,;;~;".~: -;:",_' <'<.-.: M,_ -",;;".'. '-,,_ ':~.:r;:.;': , i > , . " . DEBORAH L. HENSEL, Plaintiff IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-3663 Civil Term RICHARD R. HENSEL, Defendant COMPLAINT IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under section 3301(c) of the Divorce Code was filed on June 16, 2000. 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. S 4904 relating to unsworn falsification to authorities. DATED: (-- )-- --O( ~}fMd~~ chard R Hensel '.:I .t ". ., ~ W~. ~" ~,o_ y." '~'.'.;- . .",,' c.') r- :-?-" "1]f"; ~~. ~~. ~..... -~ ~~~ 2: =7 -,~ . ii' <j: I. Ii !! Ii !i :1 c:..' ~T, "'.oIl I t:::) =-~? I).' :...) c:: '-...) ?i; -< '0 ",,~.~t".' ~." ",' < .~~' - ~",-Qo" "'",,;,,,,~';;~;.,:- ",,_ , ',..&-,;O-C""",;i';"" :~~~::,J";:i:.',,~;;:~.~~-.:_~;~, ['iL~:: ,~"~. :.,,_:,. "-,~-;,,,;/,",'-~' J., . , '" - DEBORAH L. HENSEL, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-3663 Civil Term RICHARD R. HENSEL, Defendant : COMPLAINT IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) AND 3301(D) 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. Divorce Decree Decree will be Prothonotary. I understand that I will not be divorced until a is entered by the Court, and that a copy of the sent to me immediately after it is filed with the 4. 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. S 4904 relating to unsworn falsification to authorities. ~cAtUd~ . chard R. Hensel, Defendant !~J--01 Date: ., ~, --' ,.'-' '"'-'0.'",~, '-,' " ",..,<_'. ,,,~, " .- ..,"' >.~>.". '.. "'" C:~ :s-, ~fJ>' ----".~- ......_'. (j') -,--~~ --...--' .....- ~.-. :c... \~_ 2C: Zr-', ;P:,= ~~ -< " II ijji ,,; " .. :'1 ':i ,. , ~! 'II .' Ii !I jj , ] .1 ] '..- ~;;:;;.. -,- , c':> i>? ~B -< -:,.) C~)