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IN THE COURT OF COMMON PLEAS :
OF CUMBERLAND COUNTY
STATE OF
PENNA.
.
ROBERT L. HEFFELFINGER,
Plaintiff
No. 2001-4550
CIVIL
VERSUS
PAMELA S. HEFFELFINGE~,
Defendant
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DECREE IN
DIVORCE
AND NOW,
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,. 2001 IT IS ORDERED AND
DECREED THAT ROBERT L. HEFFELFINGER
, PLAINTIFF,
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.
AND PAMELA S. HEFFELFINGER
, DEFENDANT,
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.
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
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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
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PROTHONOTARY
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ROBERT L. HEFFELFINGER,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2001 - 4550 CIVIL TERM
PAMELA S. HEFFELFINGER,
DEFENDANT
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information,
to the Court for the 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: On August 3,
2001 by U.S. Postal Service, Restricted delivery.
3. Date of execution of the affidavit of consent required by
Section 3301(c) of the Divorce Code:
By Plaintiff, December 11,
2001; By Defendant, December 6, 2001.
4.
Related claims pending:
None
5. Date Plaintiff's Waiver of Notice in ~ 3301(c) divorce
was filed with the Prothonotary on December 14, 2001.
Date Defendant's Waiver of Notice in ~ 3301(c) divorce
was filed with the Prothonotary on December 14, 2001.
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Thomas D. Gould, Esquire
Attorney For Plaintiff
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ROBERT L. Hmh:LFINGER,
PLAINTIFF
IN THE COURT OF COMNON PLEAS
CUMBl!:RLAND COUNTY, PENNSYLVANIA
v.
NO. 2001 - 'I~a> CIVIL TERM
PAMELA S. HEFFELFINGER,
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 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 is indignities or irretrievable breakdown
of the marriage, you may request marriage counseling. A list of
marriage counselors is available in the Court Administrator's
Office, Fourth floor, Cumberland County Courthouse, Hanover and
High Streets, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Lawyer Referral Service
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
1-800-990-9108
ROBERT L. .LFINGER,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUM8ERLAND COUNTY, PENNSYLVANIA
v.
NO. 2001 - 'i S-S1:> CIVIL TERM
PAMELA S. HEFFELFINGER,
DEFENDANT
IN DIVORCE
COMPLAINT UNDER SECTION 3301(0) OR
3301(d) OF THE DIVORCE CODE IN DIVORCE
1. The Plaintiff is Robert L. Heffelfinger who resides at 1-
B Umbroto Avenue, New Cumberland, Mechanicsburg, Cumberland County,
Pennsylvania 17070.
2. The Defendant is Pamela L. Heffelfinger who resides at
5156 Birch Avenue, Sarasota, FL 34233.
3. The Plaintiff has been a bonafide resident of the
Commonwealth of Pennsylvania for at least six months immediately
prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on May 26, 1998
in Richmond, Virginia.
5. There have been no prior actions of divorce or annulment
between the parties in this or any other juriSdiction.
6. The marriage is irretrievably broken.
7. The Defendant is not a member of the Armed Services of
the United States or any of its Allies.
8. The Plaintiff has been advised of the availability of
counseling and that Plaintiff may have the right to request that
the Court require the parties to participate in counseling.
9. Plaintiff requests the court to enter a decree of divorce.
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Thomas D. Gould
Attorney for Plaintiff
1. D. # 36508
2 East Main Street
Shiremanstown, PA 17011
(717) 731-1461
VERIFICATION
I verify that the statements made in this Complaint are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn
falsification to authorities.
Date: 7-~- 01
Z2.L/1 .;t- ~~ &
Robert L. Heff finger
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ROBERT L. HEFFELFINGER,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2001 - 4550 CIVIL TERM
PAMELA S. HEFFELFINGER,
DEFENDANT
IN DIVORCE
AFFIDAVIT OF SERVICE
I, Thomas D. Gould, attorney fOE Plaintiff, in the above
captioned action for divorce, hereby certify that a conformed and
certified copy of the Complaint in Divorce was served upon the
Defendant by depositing the same in the United States mail,
certified, restricted delivery, on July 30, 2001, pursuant to Rule
1920.4 of the Amendments to the Pennsylvania Rules of Civil
Procedure relating to the Divorce Code. As indicated by the postal
return receipt attached hereto, the Complaint was received by the
Defendant on August 3, 2001.
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Thomas D. Gould
ID # 36508
Attorney At Law
2 East Main Street
Shiremanstown, PA 17011
(717) 731-1461
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Item 4 If Restrlcted Delivery Is desired.
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ROBERT L. HEFFELFINGER,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2001 - 4550 CIVIL TERM
PAMELA S. HEFFELFINGER,
DEFENDANT
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the
Divorce Code was filed on July 30, 2001.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety (90) days have elapsed from the date of the
I
filing and service of 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
acknowledge that pursuant to Rule 1920.42 (e) I have waived the
requirement that Iteceive notice of intention to request 'entry of
the decree.
.-r~erify that the statements made in this Affidavit~~e true
and correct. I understand that false statements herein are subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED: j;;t - /1-0 I
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ROBERT L. LFINGER
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ROBERT L. HEFFELFINGER,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
,
v.
NO. 2001 - 4550 CIVIL TERM
PAMELA S. HEFFELFINGER,
DEFENDANT
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(0) OF THE DIVORCE CODE
1. I consent to the entry of a final decree 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.
'. '1 verify that the statements made in this Affidavit'-are true
and correct. I understand that false statements herein are subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED: J;}-j/-Ol
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ROBERT L. HEFFEL GE
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ROBERT L. HEFFELFINGER,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2001 - 4550 CIVIL TERM
PAMELA S. HEFFELFINGER,
DEFENDANT
IN qIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the
Divorce Code was filed on July 30, 2001.
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 a Final Decree of Divorce after
service of notice of intention to request entry of the decree. I
acknowledge that pursuant to Rule 192Q. 42 (e) I have waived the
requirement that I receive notice of intention to request entry of
the decree.
I verify that the statements made in this Affidavit are true
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an~ correct. I understand that false statements herein are subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED:
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ROBERT L. HEFFELFINGER,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2001 - 4550 CIVIL TERM
PAMELA S. HEFFELFINGER,
DEFENDANT
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(0) OF THE DIVORCE CODE
1. I consent to the entry of a final decree 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.
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I verify that the statements made in this Affidavit are true
anq cor~ect. I understand that false statements herein are subject
to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
falsification to authorities.
DATED: J~-~-Ol
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ROBERT L. HEFFELFINGER,
PLAINTIFF
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2001 - 4550 CIVIL TERM
PAMELA S. HEFFELFINGER,
DEFENDANT
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information,
to the Court for the 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: On August 3,
2001 by u.S. Postal Service, Restricted delivery.
3. Date of execution of the affidavit of consent required by
Section 3301(c) of the Divorce Code: By Plaintiff, December 11,
2001; By Defendant, December 6, 2001.
4.
Related claims pending:
None
5. Date Plaintiff's Waiver of Notice in ~ 3301(c) divorce
was filed with the Prothonotary on December 14, 2001.
Date Defendant's Waiver of Notice in ~ 3301(c) divorce
was filed with the Prothonotary on December 14, 2001.
~oo 'D. ~~
Thomas D. Gould, Esquire
Attorney For Plaintiff
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