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HomeMy WebLinkAbout01-0515 FX " . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , .-J ~ ~ ~ ~~~ ~~ ~ ;f. if. :ti'" if. :Ii "';F. '" ;F. iF.:tifli:ti . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ALBERT L. HECKMAN, JR., Plaintiff No. 01-515 CIVIL TERM VERSUS PA~RTrTA A HRrKMAN Defendant DECREE IN DIVORCE AND NOW,~\>.>1- .g '''?-UD " IT IS ORDERED AND DECREED THAT ALBERT L, HECKMAN. JR. , PLAINTIFF, AND PATRICIA A. HECKMAN , DEFENDANT, 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; NO issues are outstanding. All issues have been resolved and settled by the parties' Marriage Settlement Agreement dated June 26, 2001, inr.()rpOY8ten but not merged. into this Decree. . . . :+: if.;f. :ti, '" "';I; ~ "'-", . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ""'"'""'"" ,0'," ',f 9''lf'~( ~?ClI . ~,.~~ ,~ ) ,j" , , . , . ~_ "~c. e_~"__. ___ . . ".) It.. ~~~" ~.~: 'J' - Jt., c') -.-.'...., ~\p or . " , . '. " " ( ., .. UUl~~~~'~c~'""",). ,V,~l_, _~"~"A~~ _,__,_", "'- J, ---~- -< .'. , _.'- ~ d "'''<1'''''., SOCIAL SECURITY INFORMATION SHEET PURSUANT TO 23 Pa.C.S,A, SECTION 4304,1() (3) ALL DIVORCES MUST INCLUDE THE PARTIES SOCIAL SECURITY NUMBERS. PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE. DATE 08/01/01 DOCKET NUMBER 01-515 PLAINTIFF'S NAME Albert L. Heckman, Jr. PLAINTIFF'S SS # 195-38-8014 DEFENDANT'S NAME Patricia A. Heckman DEFENDANT'S SS# 204-36-6880 DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (117) 737-0100 '" '--'--,.' _.--",~~~,-( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALBERT L. HECKMAN, JR., Plaintiff v, NO. 6/- s:/.s- I e-o"(Y~ PATRICIA A. HECKMAN, Defendant CIVIL ACTION - LAW DIVORCE NOTICE 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 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 Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 - -,~-'~-- .-1.. ..~"" '-'l_.' ~~--: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALBERT L. HECKMAN, JR., Plaintiff v. NO.tJ/.5'6~ T~ CIVIL ACTION - LAW DIVORCE PATRICIA A. HECKMAN, Defendant COMPLAINT AND NOW, this _ day o~V\()(ll~.At, 2001, comes the Plaintiff, ALBERT L. HECKMAN, JR., by his attorney, DIANE G. RADCLIFF, ESQUIRE, and files this Complaint in Divorce of which the following is a statement: COUNT I: DIVORCE 1. The plaintiff is ALBERT L. HECKMAN, JR., an adult individual residing at 4025 Valley Road, Enola, PA 17025, 2. The Defendant is PATRICIA A. HECKMAN, an adult individual residing at 833 Mandy Lane, Camp Hill, PA 17011. 3. Plaintiff and/or Defendant have been bona fide residents of the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 7, 1984 at Hershey, Dauphin County, Pennsylvania. 5, There have been no prior actions of divorce or annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 731.0100 -2- ""' '~~'t', 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff avers that the grounds on which the action is based are: a. That the marriage is irretrievably broken; Or in the alternative, b. That the parties are now living separate and apart, and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. COUNT II: EOUITABLE DISTRIBUTION 9. Paragraphs 1 through 8 are incorporated by reference hereto as fully as though the same were set forth at length. 10. Plaintiff and Defendant have acquired property and debts, both real and personal, during their marriage from July 7, 1984 until December 18, 2000, the date of separation, all of which are "marital property" or "marital debts". 11. Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, "non-marital property" which has increased in value since the date of marriage and/or subsequent to its acquisition during the marriage, which increase in value is "marital property", plaintiff and Defendant have been unable to agree as to an 12. DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL. PA 17011 (711) 737-0100 - 3 - I ~ . " 0...>..,' '~" equitable division of said property and debts as of the date of the filing of this Complaint. WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property and debts of the parties. COUNT III: ALIMONY PENDENTE LITE. ALIMONY 13. Paragraphs 1 through 12 are incorporated by reference hereto as fully as though the same were set forth at length. 14. Plaintiff lacks sufficient property to provide for his reasonable means and is unable to support himself through appropriate employment. 15. Plaintiff requires reasonable support to adequately maintain himself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of alimony pendente lite until final hearing and hereafter enter an award of alimony permanently thereafter. COUNT IV: COUNSEL FEES 16. Paragraphs 1 through 15 are incorporated by reference hereto as fully as though the same were set forth at length. 17. plaintiff has employed Diane G. Radcliff, Esquire, as counsel but is unable to pay the necessary and reasonable attorney's fees for said counsel. 18. The Plaintiff is in need of hiring various experts to appraise the parties' marital assets and does not have the funds to pay DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP IDLL, PA 17011 (717) 737-0100 - 4- ~, - J. DIANE G. RADCLIFF 3448 TRlNDLE ROAD CAMP HILL, PA 11011 (717) 737-0100 -'" , , ~i~~ the necessary and reasonable fees. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of interim counsel fees, costs and expenses and to order such additional sums hereafter as may be deemed necessary and appropriate and at final hearing to further award such additional counsel fees, costs and expenses as are deemed necessary and appropriate. le Road Hill, PA 17011 rt ID # 32112 Phone: (717) 737-0100 Fax: (717) 975-0697 - 5 - DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP IDLL, PA 17011 (717) 737-0100 , ,_L ~ '~-;\' 1> VERIFICATION ALBERT L. HECKMAN, JR. verifies that the statements made in this Complaint are true and correct. ALBERT L. HECKMAN, JR, understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ~t{~f -6- I ~ ,- ._-"".. <CJ'. ,_'-' ,,-- i.'.../ .'.tT;C',i . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALBERT L. HECKMAN, JR., Plaintiff v. NO. 01-515 CIVIL TERM CIVIL ACTION - LAW DIVORCE PATRICIA A. HECKMAN, Defendant NOTICE 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 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 Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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, CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP IDLL, PA 17011 (717) 737-0100 '.'~ , J , I ,~. "'~'-~~'i,-, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALBERT L. HECKMAN, JR" Plaintiff v. NO. 01-515 CIVIL TERM PATRICIA A. HECKMAN, CIVIL ACTION - LAW Defendant DIVORCE AMENDED COMPLAINT AND NOW, this _ day of Plaintiff, ALBERT L. HECKMAN, JR., 2001, comes the by his attorney, DIANE G. RADCLIFF, ESQUIRE, and files this Complaint in Divorce of which the following is a statement: COUNT I: DIVORCE 1. The Plaintiff is ALBERT L. HECKMAN, JR., an adult individual residing at 4025 Valley Road, Enola, PA 17025. 2. The Defendant is PATRICIA A. HECKMAN, an adult individual residing at 833 Mandy Lane, Camp Hill, PA 17011. 3. Plaintiff and/or Defendant have been bona fide residents of the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 7, 1984 at Hershey, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA nOll (117) 737-0100 - 2- -" ,. .'"~t1: 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8, The Plaintiff avers that the grounds on which the action is based are: a. That the marriage is irretrievably broken; Or in the alternative, b, That the parties are now living separate and apart, and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. COUNT II: EOUITABLE DISTRIBUTION 9. Paragraphs 1 through 8 are incorporated by reference hereto as fully as though the same were set forth at length. 10. Plaintiff and Defendant have acquired property and debts, both real and personal, during their marriage from July 7, 1984 until November 18, 2000, the date of separation, all of which are "marital property" or "marital debts". 11. Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, "non-marital property" which has increased in value since the date of marriage and/or subsequent to its acquisition during the marriage, which increase in value is "marital property". 12. Plaintiff and Defendant have been unable to agree as to an DIANE G, RADCLIFF 3448 TRlNDLE ROAD CAMP IDLL. PA 17011 (117) 737-0100 - 3 - DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 ~~ -," , ",' ~ ~ "j~>j: equitable division of said property and debts as of the date of the filing of this Complaint. WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property and debts of the parties. COUNT III: ALIMONY PENDENTE LITE. ALIMONY 13. Paragraphs 1 through 12 are incorporated by reference hereto as fully as though the same were set forth at length. 14. Plaintiff lacks sufficient property to provide for his reasonable means and is unable to support himself through appropriate employment. 15. Plaintiff requires reasonable support to adequately maintain himself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of alimony pendente lite until final hearing and hereafter enter an award of alimony permanently thereafter. COUNT IV: COUNSEL FEES 16. Paragraphs 1 through 15 are incorporated by reference hereto as fully as though the same were set forth at length. 17, Plaintiff has employed Diane G. Radcliff, Esquire, as counsel but is unable to pay the necessary and reasonable attorney's fees for said counsel. 18. The plaintiff is in need of hiring various experts to appraise the parties' marital assets and does not have the funds to pay -4- c DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP IIILL, PA 17011 (717) 131-0100 Il'~~ """""'t~, the necessary and reasonable fees. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of interim counsel fees, costs and expenses and to order such additional sums hereafter as may be deemed necessary and appropriate and at final hearing to further award such additional counsel fees, costs and expenses as are deemed necessary and appropriate. C ESQUI E e Road amp 1 ,PA 17011 Supreme Court ID # 32112 Phone: (717) 737-0100 Fax: (717) 975-0697 - 5 - -.- ~ DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA l70H (717) 737-0100 - ~ ~"'~~'*"---"". , VERIFICATION ALBERT L. HECKMAN, JR, verifies that the statements made in this Complaint are true and correct. ALBERT L. HECKMAN, JR. understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, falsification to authorities. relating to unsworn - 6- DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 731-0100 -'-. 0__ -~, "",'c_ 'Mf_~.",",,_: '" '~. """" \lh g. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALBERT L. HECKMAN, JR., Plaintiff v. NO. 01-515 CIVIL ACTION - LAW DIVORCE PATRICIA A. HECKMAN, Defendant CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the Complaint in Divorce has been served upon the Defendant, patricia A. Heckman, by Certified Mail, Restricted Delivery on January 26, 2001. The return receipt is attached hereto as Exhibit "AN and made a part hereof. Respectfully submitted, lANE 344 C m , P Phone: (717) 737-0100 Fax: (717) 975-0695 Supreme Court ID # 32112 Attorney for Plaintiff . . " -'" -<,,"; ,- ,-,'->...,-" L-.~i,i _com'plele iiel1'ls 1, 2, and 3. Also compl~le;:- item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you. . Attach this card to the back of the mailpiece,. or on the front if space permits. 1. Article Addressed to: x D. Is delivery address different from item 1? If YES, enter delivery address below: o Agent o Addressee Dyes o No 'P~CIIl A. I-kcClt'^-fI<1'-J '633 v-fI.~'D'1 CDot2-T C~? fh t.l, ?f>r 11-c>lf 3. Service Type 1&Certified Mail 0 Express Mail ?B Registered ~etum Receipt for Merchandise o Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) ~es . 2. Article Number (Copy from service fabeQ 'PS Form 3811, July 1999 Domestic Return Receipt 102595-99-M-1789 + EXHIBIT "A" RETURN RECEIPT DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 11011 (717) 737-0100 -2- ,,~.....--~~~ '" ~~\: , , ALBERT L. HECKMAN, JR., Plaintit1i'Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE PATRICIA A. HECKMAN, Defendant/Respondent NO. 01-515 CIVIL TERM IN DIVORCE DR# 30513 Pacses# 923103154 ORDER OF COURT AND NOW, this 20'" day of March, 2001, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees. it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav onAori/ll. 2001 at 10:30 A.M. for a conference. at 13 N. Hanover St., Carlisle. PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (I) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order. completed as required by Rule 191O.11@ (4) verification of child care expenses (5) proof of medical coverage which you limy have. or lJ1ay (lave available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer. President Judge Maii:q"'1)ieson ','"w,"',"',r..",,', :3i"ZI.T"oi,io;'\ < Petitioner Respondent Diane Radcliff, Esquire Barbara Sump Ie-Sullivan, Esquire ;J R. Date of Order: March 20, 200 I YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY A VB. CARLISLE, PENNSYL VANIA 17013 (717) 249-3166 ^ ,",c .".. BiJ~' YOUR HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 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. BY OR FOR THE COURT: - 2 - ,< ~ L ,. " . ~ I. 1_ - ':'.- h ',., I~-'i .' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALBERT L. HECKMAN, JR., Plaintiff v, NO. 01-515 PATRICIA A. HECKMAN, Defendant CIVIL ACTION - LAW DIVORCE RE: MOTION FOR CONFERENCE ON CLAIMS FOR ALIMONY PENDENTE LITE AND INTERIM COUNSEL FEES AND COSTS TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, this J'l~ day of February, 2001, comes the Petitioner, ALBERT L. HECKMAN, JR., by his attorney, Diane G. Radcliff, Esquire, who moves this Honorable Court to schedule a conference on Plaintiff's claims for Alimony Pendent Lite and Interim Counsel Fees and Costs set forth in the Divorce Complaint and Amended Divorce Complaint filed in this action, true and correct copies of which are attached hereto, marked Exhibits "A" and "B" respectively and made a part hereof. A background information sheet pertaining to these claims has or will be filed with The Domestic Relations Office as required by Local Rules of Court. The amount asked by the Petitioner for Alimony Pendente Lite is the maximum amount provided for under the guidelines. The amount of Interim Counsel Fees and Costs requested by the petitioner is $2,000.00. - 3 - .A ., " i I' .L' " _",," k-,' -'-, WHEREFORE, Petitioner prays that the Court enter an Order scheduling a conference before the Cumberland County Domestic Relations office and at or after that conference entering an order: 1. Requiring the Respondent to pay the Petitioner Alimony Pendente Lite in the maximum amount provided for by law under the state support guidelines; 2. Requiring the Respondent to provide medical support for the Petitioner; 3. Requiring the Respondent to pay a reasonable amount towards the Petitioner's Interim Counsel Fees and Costs. Respectfully submitted, , ESQUIR e Road A 17011 rt ID # 32112 Phone: (717) 737-0100 Fax: (717) 975-0695 Attorney for Plaintiff - 4 - '." ><.'-'--,'-" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALBERT L. HECKMAN, JR., Plaintiff v. NO. 01- S'1.s- OOltTDu., CIVIL ACTION - LAW DIVORCE PATRICIA A. HECKMAN, Defendant NOTICE 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 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 Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. DIANE G. RADCLIFF 3448 TRlNDLE ROAD CAMP HILL, PA 17011 (717) 137-0100 CUMBERLAND COUNTY BAR ASSOqIATION 2 LIBERTY AVE~E: . CARLISLE, PA.17013 (717) 24,9-3166' TRlJ~}COPY FROM\~ In T~ 'fJIOO~,' 1.l'J~ ul1tO.1llf \wIG ~t,~ ,.-JtE,' C3, '_,~, ~, ~~~ ( s]jfJjj, J . '(' " " "JlrG onotarv 11/4/' '."" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALBERT L. HECKMAN, JR., Plaintiff v. NO. PATRICIA A. HECKMAN, Defendant CIVIL ACTION - LAW DIVORCE COMPLAINT AND NOW, this _ day o~l'\( )(Il)>.A t' 2001, comes the Plaintiff, ALBERT L. HECKMAN, JR., by his attorney, DIANE G. RADCLIFF, ESQUIRE, and files this Complaint in Divorce of which the following is a statement: COUNT I: DIVORCE 1. The Plaintiff is ALBERT L. HECKMAN, JR., an adult individual residing at 4025 Valley Road, Enola, PA 17025. 2. The Defendant is PATRICIA A. HECKMAN, an adult individual residing at 833 Mandy Lane, Camp Hill, PA 17011. 3. Plaintiff and/or Defendant have been bona fide residents of the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 7, 1984 at Hershey, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. DIANE G. RADCLIFF 3448 TRlNDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 -2- 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff avers that the grounds on which the action is based are: a. That the marriage is irretrievably broken; Or in the alternative, b. That the parties are now living separate and apart, and at -flie appropriaEe-Ume, PlalntiTf---w.rn- suomiT- an - --- Affidavit alleging that the parties have lived separate and. apart for at least two (2) years and that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. COUNT II: EQUITABLE DISTRIBUTION 9. Paragraphs 1 through 8 are incorporated by reference hereto as fully as though the same were set forth at length. 10. Plaintiff and Defendant have acquired property and debts, both real and. personal, during their marriage from July 7, 1984 until December 18, 2000, the date of separation, all of which are "marital property" or "marital debts". 11. Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, "non-marital property" which has increased in value since the date of marriage and/or subsequent to its acquisition during the marriage, which increase in value is "marital property". 12. Plaintiff and Defendant have been unable to agree as to an DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 11011 (717) 731-0100 - 3 - '.'~ ,. ,- ~ equitable division of said property and debts as of the date of the filing of this Complaint. WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property and debts of the parties. COUNT III: ALIMONY PENDENTE LITE. ALIMONY u~________ 13-:---Paragra:plis 1 -'Elirougli12 are incorporated by re!erence nereEo--- as fully as though the same were set forth at length. 14. Plaintiff lacks sufficient property to provide for his reasonable means and is unable to support himself through appropriate employment. 15. Plaintiff requires reasonable support to adequately maintain himself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of alimony pendente lite until final hearing and hereafter enter an award of alimony permanently thereafter. COUNT IV: COUNSEL FEES 16. Paragraphs 1 through 15 are incorporated by reference hereto as fully as though the same were set forth at length. 17. Plaintiff has employed Diane G. Radcliff, Esquire. as counsel but is unable to pay the necessary and reasonable attorney's fees for said counsel. 18. The Plaintiff is in need of hiring various experts to appraise the parties' marital assets and does not have the funds to pay DIANE G. RADCLIFF 3448 TRINDLE ROAD :AMP HILL, PA 17011 :717) 731-0100 -4- DIANE G. RADCLIFF 3448 TRlNDLE ROAD CAMP lllLL, PA 17011 (711) 737-0100 the necessary and reasonable fees. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of interim counsel fees, costs and expenses and to order such additional sums hereafter as may be deemed necessary and appropriate and at final hearing to further award such additional counsel fees, costs and expenses as are deemed necessary and appropria-te-. Respectfully Ie Road Hill, PA 17011 rt ID # 32112 Phone: (717) 737-0100 Fax: (717) 975-0697 - 5 - -1' DIANE G. RADCLIFF 3448 TRlNDLE ROAD CAMP HILL, PA 17011 (717) 737.Q!00 VERIFICATION ALBERT L. HECKMAN, JR. verifies that the statements made in this Complaint are true and correct. ALBERT L, HECKMAN, JR. understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ~fl~L;:- BERT L.'~' . -6- . ~.-_ ,_' -~__' 0 "'j: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PATRICIA A. HECKMAN, Defendant CIVIL ACTION DIVORCE (') ~ ;:R ~~~, :ZT,' ----;T,-. (n'~'~ NO. 01-515 CIVIL T~ ,c;C> LAW ""0 Pc ~ o (') ALBERT L. HECKMAN, JR" Plaintiff ,- "3 , , . ," --~ \ .-~ ___1_~ w r,_' ',JC,l '.-' -n '--,'2C~ i.~=)tn ~~ :::: v. -0 ::,.-;: :.n <p NOTICE 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 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 Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 DIANE G. RADCLIFF 3448 TRlNDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 , ~l '--'. k-"r' C'" ' " ~ -",,', ',__, _c ',., 'j",,,:' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ALBERT L. HECKMAN, JR., Plaintiff v. NO. 01-515 CIVIL TERM PATRICIA A. HECKMAN, CIVIL ACTION - LAW Defendant DIVORCE AMENDED COMPLAINT AND NOW, this _ day of Plaintiff, ALBERT L. HECKMAN, JR., 2001, comes the by his attorney, DIANE G. RADCLIFF, ESQUIRE, and files this Complaint in Divorce of which the following is a statement: COUNT I: DIVORCE 1. The Plaintiff is ALBERT L. HECKMAN, JR., an adult individual residing at 4025 Valley Road, Enola, PA 17025. 2. The Defendant is PATRICIA A. HECKMAN, an adult individual residing at 833 Mandy Lane, Camp Hill, PA 17011. 3. Plaintiff and/or Defendant have been bona fide residents of the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on July 7, 1984 at Hershey, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. DIANE G. RADCLIFF 1448 TRINDLE ROAD :AMP HILL. PA 170ll :717) 737-0100 -2- 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff avers that the grounds on which the action is based are: a. That the marriage is irretrievably broken; Or in the alternative, That the parties are now living separate and apart, and at the appropriate time, Plaintiff will submit an b. Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. COUNT II: EOUITABLE DISTRIBUTION 9. Paragraphs 1 through 8 are incorporated by reference hereto as fully as though the same were set forth at length. 10. Plaintiff and Defendant have acquired property and debts, both real and personal, during their marriage from July 7, 1984 until November 18, 2000, the date of separation, all of which are "marital property" or "marital debts". 11. Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, "non-marital property" which has increased in value since the date of marriage and/or subsequent to its acquisition during the marriage, which increase in value is "marital property". 12. Plaintiff and Defendant have been unable to agree as to an DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP fiLL, PA 11011 (117) 737-0100 -3- .n" " ,_, _, _ ,_;<'- "' _'r~:'i ,,__ '.'\'; equitable division of said property and debts as of the date of the filing of this Complaint. WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property and debts of the parties. COUNT III: ALIMONY PENDENTE LITE. ALIMONY 13. Paragraphs 1 through 12 are incorporated by reference hereto as fully as though the same were set forth at length. 14. Plaintiff lacks sufficient property to provide for his reasonable means and is unable to support himself through appropriate employment. 15. Plaintiff requires reasonable support to adequately maintain himself in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of alimony pendente lite until final hearing and hereafter enter an award of alimony permanently thereafter. COUNT IV: COUNSEL FEES 16. Paragraphs 1 through 15 are incorporated by reference hereto as fully as though the same were set forth at length. 17. plaintiff has employed Diane G. Radcliff, Esquire, as counsel but is unable to pay the necessary and reasonable attorney's fees for said counsel. 18. The Plaintiff is in need of hiring various experts to appraise the parties' marital assets and does not have the funds to pay DIANE G. RADCLIFF 3448 TRlNDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 - 4- ~~, DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (117) 737-0100 , n~' .....:;,"_"_ .' "- ~^,;c" _ ,"_' - . ~ '" ~ _ _,' ':c., the necessary and reasonable fees, WHEREFORE, plaintiff requests this Honorable Court to enter an award of interim counsel fees, costs and expenses and to order such additional sums hereafter as may be deemed necessary and appropriate and at final hearing to further award such additional counsel fees, costs and expenses as are deemed necessary and appropriate. - 5 - E DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA nOll (717) 737-0100 ",,;j VERIFICATION ALBERT L. HECKMAN, JR. verifies that the statements made in this Complaint are true and correct. ALBERT L. HECKMAN, JR. understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, falsification to authorities. relating to unsworn -6- i.-='" ~. ..,..... ,<- ,- "----" ~- ,,}'" ,.' ~ DR 30513 PACSES ill 923103154 ALBERT L. HECKMAN,]R. Plaintiff/Petitioner vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : DOMESTIC RELATIONS SECTION : CNIL ACTION - LAW PATRICIA A. HECKMAN, Defendant/Respondent : NO. 01-515 CIVIL TERM ORDER OF COURT AND NOW, this 12th day of April, 2001, based upon the Court's determination that Petitioner's monthly net income/earning capacity is $2,264.14 per month and Respondent's monthly net income/earning capacity is $3,749.94 per month, it is hereby Ordered that the Respondent pay to the Pennsylvania State Collection and Disbursement Unit, $408.00 per month payable bi-weekly as follows; $178.16 bi-weekly for alimony pendente lite and $10.15 bi-weekly on arrears, First payment due on next pay date @ $188.31 bi-weekly. Arrears set at $772.00 as of April II, 2001. The effective date of the order is February 27,2001. This Order gives consideration that Respondnet is responsible for the parties' mortgage, real estate taxes, and homeowner's insurance. Further consideration is given for Repsondent being responsible for the parties' hobbylbusiness losses and a time share condo payment that will be due in October, 2001. Failure to make each payment on time and in full will cause all arrears to become subject to immediate collection by all of the means as provided by 23 Pa,C.S,g 3703. Further, if the Court finds, after hearing, that the Respondent has willfully failed to comply with this Order, it may declare the Respondent in civil contempt of Court and its discretion make an appropriate Order, including, but not limited to, commitment of the Respondent to prison for a period not to exceed six months. Said money to be turned over by the P A SCDU to: Albert 1. Heckman, Ir.. Payments must be made by check or money order. All checks and money orders must be made payable to P A SCDU and mailed to: PASCDU P.O. Box 69110 Harrisburg, PA 17106-9110 Payments must include the defendant's P ACSES Member Number or Social Security Number in , order to be processed. Do not send cash by mail. " ,~"'~,~ , ~ I > __ _ .~ !lE.. This Order shall become final ten days after the mailing of the notice of the entry of the Order to the parties unless either party files a written demand with the Prothonotary for a hearing de novo before the Court. DRO: R. J. Sbadday Mailed copies on IcJV/r,trl to:'< e];j Petitioner Respondent Diane Radclifi; Esqnire Barbara Sumbple-Sullivan, Esquire Edgar B. Bayley 1. ~ ,,"- J:)~ Q {I "P~ ':..JU7.~~,t;,,'Y J ,,;,,'P I'" . l\ I "1.11 CUi'v~C,I~-:_i"[i "" ,I.:I 9: 13 PI 'I .,"",' :: '11\!S~+..(!,C()U\rl- --.,/.:.^-I" ,~ y "vi\ i I I I I j i J ~"'"'' ~, ~."- " _ , ~co.d If!.;~- ~--~;"'-" , No. 01- S-j:5 Cl";! ))g. 30S 13 ;v14Y 2 3 2[JJj CUMBERLAND COUNTY DOMESTIC RELATIONS Date of Application: 5/21/01 Requestfor Support Record Search Nmne: HAr.km~n Patricia A. (Last) (First) (MI) Address: 833 Mandv Lane, Camp Hill, PA 17011 Social Security Number: /.02-36-6880 D.O.B,: Domestic Relations Case Number if Known: Party Reqllesting Information: Corn"rRton" L~nn Transfer, Inc. (Print Name of Firm Name) , "' ,( 717;) , 730'-9664 (Telephone Number) (717) 73 0~9665 (Fax Number) 4705E. Tri~dle Road,Mechanicsburg; PA, 17050 (Address) ~ ';J-~ (Signature) A Twenty Dollar ($20.00) Fee is Due per Social Security Number Mal<e check or money order payable to: DRSILien Search i INITIAL REQUESlj 'A Has no Record in Domestic Relations as of: '" Support Arrears as of End of Month Prior to Date of Application: $ Monthly Total Support Obligation: $ 380.00!tn or1fh I ' The Amountshown above is reflected in the Domestic Relations Section Office of Cumberland County, Pennsylvania. Nl WI bJ1.(" ~ (n!o5'O( 007:<,-/ Domestic Relations Case Number: P () (:56 ,.:t:l=' q a 3/ 03 I 5 LJ $~;(3--01 (Date) qt.oq. la<1 Signed: @JJ f-,~ J'h. 6-'~k (Lien Search Coordinator) (Date) BRING-DOWN REQUEST Support ArrearS: $ As Of: (Date) Signed: (Lien Coordinator) (Date) , *** Lien Satisfisfaction Receipt Available Upon Request*** P/< (lse ~.k" (\ / /, ,y~i<? I I , ~;'i)Un'( Of "t~y 23 (_1)--; :3: S2 (" P, ."""1"', - ,-.. '(J-'( ...AJ!/i;:;L: "i'i.J."!VU \;()u \ { PENNSYL\I;\NI/\ . I ~ J j 1 , 11 ;~ .~ , i ~ , ~ 'i'.i ~ ~ ~ , I I a I I ~ $ " " "-~ .~-- -,'- ",,& ALBERT L. HECKMAN. JR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - DIVORCE PATRICIA A. HECKMAN. Defendant : NO. 01-515 AFFIDA VTT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 31, 2001. 2, The marriage of the Plaintiff and Defendant is irretrievably broken, Ninety days have elapsed since 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, 4, 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. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities, DATE: 6-~t:,-D I W&..\- L.~~~ ALBERT L. HECK , JR. - ~ O~ . ___e~_^ --~~"''^-, "~__ __-';C~".-.- -'~"'~ (__.".' '-__,"_,,,,,'~~",-.-\o'~~_'~~"____' -~ ,_ ",~"__"~<"^___,,,, '"",__" ALBERT 1. HECKMAN, JR.. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - DIVORCE PATRICIA A. HECKMAN, Defendant NO. 01-515 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301 Ie) 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, I verify that the statements made in this affidavit are true and correct. I understand that false statement herein are made subject to the penalties of 18 Pa.C,S, ~4904 relating to unsworn falsification to authorities. DATE: (P-21.rO \ GH~\-- L~H~" C ALBERT L. HECKMA JR. - --~ . "'-~ ,_r ~~ -.~'. .',,,, ALBERT L. HECKMAN. JR.. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - DIVORCE PATRICIA A. HECKMAN, Defendant NO. 01-515 AFFlDA VIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 31, 2001. 2. The marriage of the Plaintiff and Defendant is irretrievably broken. Ninety days have elapsed since 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. 4. 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. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. DATE:~ f~ Q_t~ PATRICIAA.HECKMAN ~ ~ ~ ,~~" .. ALBERT L. HECKMAN, JR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - DIVORCE PATRICIA A. HECKMAN, Defendant NO. 01-515 W A IVRR OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER !l3301 (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 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. I verify that the statements made in this affidavit are true and correct. I understand that false statement herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. DATE: t.R&>101 , I ~ (lt~ PATRICIAA.HECKMAN - ~~ - LIEN SATISFACTION Pacses# 923103154 No. 515 CV 01 DR# 30513 Name: Patricia Heckman Social Security Number: 202-36-6880 Judgment Lien Satisfied as of: 07/11/01 Amount Paid: $ Case Closed Signed: ~ /n. 6~ (Lien Coordinator) 7-/,) -01 (Date) , ,". ~;,j ~" -~ ~~ ,. .' " ~-." ". ~" " .'~i. In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION ALBERT L. HECKMAN JR ) Docket Number 01-515 CIVIL Plaintiff ) vs. ) PACSES Case Number 923103154 jD3Cl513 PATRICIA A. HECKMAN ) Defendant ) Otber State ill Number ORDER AND NOW, to wit, on this 11TH DAY OF JULY, 2001 IT IS HEREBY ORDERED that the support order in this case be 0 Vacated or OSuspended or <i> Terminated without prejudice or 0 Terminated and Vacated, effective JUNE 26, 2001 , due to: THE PARTIES' MARITAL SETTLEMENT AGREEMENT. PURSUANT TO THE SAM!! AGREEMENT, THERE IS NO BALANCE DUE THE PLAINTIFF. BYTIIEQ~'1~ Edgar B. Bayley JUDGE DRO: R.J Shadday xc: plaintiff deferrlant Diane RAdcliff, Esquire Barbara Sumple-Sulli van, Esquire Service Type M Form OE-504 Worker ill 21005 -"~~.. -,- .-...~" - ALBERT L. HECKMAN, JR., Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-515 PATRICIA A. HECKMAN, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE OF 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. 2. Date a. b. c. of filing and manner of service Date of filing of Complaint: Manner of service of Complaint: Date of Service of Complaint: of the complaint: January 24, 2001 Certified Mail/Restricted January 26, 2001 Delivery 3.. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: a. Plaintiff: June 26, 2001 b. Defendant: June 26, 2001 OR Date of execution of the Plaintiff's affidavit required by Section 330l(d) of the Divorce Code and date of service of the Plaintiff's 3301 (d) affidavit upon the Defendant: a. Date of execution: b. Date of filing: c. Date of service: 4. Related claims pending: No issues are pending. All issues have been resolved pursuant to the Marriage Settlement Agreement between the parties dated June 26, 2001, which Agreement is to be incorporated into but not merged with the Divorce Decree. 5. Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d) (1) (i) of the Divorce Code: a. Date of Service: N/A b. Manner of Service: N/A Date Waiver of Prothonotary: a. Plaintiff's b. Defendant's OR Notice in Section 330l(c) Divorce was filed with the Waiver: June 27, 2001 Waiver: July 3, 2001 ESQUIRE FiLED-OFFICE ~- T' ,"" -'~~'''' 1"1J10T~RY r 1.- ;l",j', U,_'( 'I'-! ;,' , I V, "-'.,' '>-J, _\._ .. I I o IIWG -6 PM 12: 24 CUMBERIJ'ND COUNTY PENNSYLVANIA 11 I Ji j 'i I I I i i :1 ~