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Home My WebLink About03-1933Shannon Gail Heinbaugh, Plaintiff Christopher Scott Heinbaugh, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA · NO. 03- /?~"~'-~ CIVIL TERM : CIVIL ACTION - LAW :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 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 THIS PAPER TO YOUR LAVVYER 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 Shannon Gail Heinbaugh, Plaintiff Christopher Scott Heinbaugh, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 03- j~ 3 ~ CIVIL TERM · CIVIL ACTION - LAW · IN DIVORCE COMPLAINT IN DIVORCI= 1. Plaintiff is Shannon Gail Heinbaugh, an adult individual, currently residing at 204 Farm Road, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is Christopher Scott Heinbaugh, an adult individual, currently residing at 1543 Newville Road, Cumberland County, Pennsylvania. ~ P~ 3. Plaintiff and Defendant are bonafide residents of the Common,yeS,Ih 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 October 20, 1998 in Cumberland County, Pennsylvania. parties. There have been no prior actions for divorce or annulment between the 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 May, 2001 and continue to live separate and apart as of the date of this Complaint. 10. The parties' marriage is irretrievably broken. 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. 6. The Defendant is not a member of the Armed Forces of the United States of America, or its Allies. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. Respectfully Submitted TURO LAW OFFICES Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Divorce Complaint are true and correct. I understand that false statements herein made are subject to the penalties of Pa.C.S. {}4904 relating to unsworn falsification to authorities. Date nnon G. HeTnb~i~h - / - Shannon Gail Heinbaugh, Plaintiff Christopher Scott Heinbaugh, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 03.-1933 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on April 25, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notic, of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAV 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. Dat~/ ~ ~'~annon Heinba~g~ - - | - Shannon Gail Heinbaugh, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-1933 CIVIL TERM Christopher Scott Heinbaugh, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on April 25, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in 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. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. ltlo% Dat~/ ~ ~'hannon Heinba~g~ Shannon Gail Heinbaugh, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-1933 CIVIL TERM Christopher Scott Heinbaugh, Defendant : CIVIL ACTION - LAW :IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301('c) OF THE DIVORCE CODF 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 THE FOREGOING 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. D~te / Shannon Heinb~gh - j' Shannon Gail Heinbaugh, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-1933 CIVIL TERM Christopher Scott Heinbaugh, Defendant : CIVIL ACTION - LAW :IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF Ar~IVORCE DECHEE UNIDEI~ .~ 3301(c) OF THE DIVORCE CODF 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 THE FOREGOING 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 AU7 iiORiTiE$. D~te ' ' C~ris~opl~er Scott Heinba[Jgh- Shannon Gall Heinbaugh, Plaintiff Christopher Scott Heinbaugh, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-1933 CIVIL TERM : : CIVIL ACTION - LAW .'IN DIVORCE ACCEPTANCE OFSERVICE I accept service of the Complaint in Divorce filed on the 25th day of April 2003, in the Court of Common Pleas of Cumberland County, Pennsylvania Date Shannon Gail Heinbaugh, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Christopher Scott Heinbaugh, Defendant v. : NO. 03-1933 CIVIL TERM : : CIVIL ACTION - LAW :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. Code. 2. 25, 2003. 3. Divorce Code. Ground for divorce: irretrievable breakdown under {}3301(c)of the Divorce Date and manner of service of the complaint: Acceptance of Service April Date of execution of the Affidavit of Consent required by {}3301(c) of the By Plaintiff: November 9, 2003 4. Related claims pending: None. Date the Waiver of Notice in {}3301(c) Prothonotary: By Plaintiff: November 13, 2003 By Defendant: November 7, 2003 divorce was filed with the By Defendant: November 13, 2003 Robert J. M¢/derig, Es~luir~ Attorney for'Plaintiff IN The COURT OF COMMON OF CUMBERLAND COUNTY STATE Of Shannon gail Heinbaugh Plaintiff VERSUS Christopher Scott Heinbaugh Defendant PENNA. N O. 03-1933 PLEAS DECREE IN DIVORCE ~/0.'~.~, AND Now, 9~ /~/ ,2003 ,,T,SORDeREDAND DECREED THAT Shannon Gail Heinbaugh , PLAiNTiff, AND Christopher Scott Heinbaugh , 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 WHCH a FINAL ORDER HAS NOT YET BEEN ENTERED; None ATTES~~ J. PROTHONOTARY Shannon Gail Heinbaugh, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 03-1933 CIVIL TERM Christopher Scott Heinbaugh, Defendant : CIVIL ACTION - LAW :IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divome Code was filed on April 25, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in 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. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Date