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Home My WebLink About01-04550IN THE COURT OF COMMON PLE~+S ROBERT L. HEFFELFINGSR Plaintiff VERSUS PAMELA S. HEFFELFINGSR, Defendant N O. 2001-4550 CIVIL DECREE IN DIVORCE ~- ! o: ~oR.NI AND NOW, ~/ ( ~ 2001, IT IS ORDERED AND DECREED THAT ROBERT L. HEFFELFINGSR PLAINTIFF, AND PAMELA S. HEFFELFINGSR ,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; NONE By ATTEST: J. r PROTHONOTARY ROBERT L. HEFFELFINGER, PLAINTIFF v. PAMELA S. HEFFELFINGER, DEFENDANT IN THE COURT OF COMMON PLEAS . CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - 4550 CIVIL TERM 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. ~. Thomas D. Gould, Esquire Attorney For Plaintiff ROBERT L. 8E'FELFINGER, PLAINTIFF v. PAMELA S. HEFFELFINGER, IN THE COURT OF COMMON PLEAS C[7MBERLAND COUNTY, PENNSYLVAN NO. 2001 -<FS"6~ CIVIL TERM 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. HEFELFINGER, PLAINTIFF v. PAMELA S. HEFFELFINGER, IN THE COURT OF COMMON PLEAS CU~ERLAND COUNTY, PENNSYLVAN NO. 2001 - y J"S~ CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) 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. r y 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. " .~~!om2e ll. >C~~es~C~ Thomas D. Gould Attorney for Plaintiff I.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 : ~-~ I - UI ~~'~ a- ~a c^e Robert L. Heff finger ROBERT L. HEFFELFINGER, PLAINTIFF v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAN NO. 2001 - 4550 CIVIL TERM PAMELA S. HEFFELFINGER, IN DIVORCE DEFENDANT AFFIDAVIT OF SERVICE I, Thomas D. Gould, attorney fog 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 '' Pendant ter, August 3, 2001. Thomas D. Gould ID # 36508 Attorney At Law 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 ;- ROBERT L. HEFFELFINGER, PLAINTIFF v. PAMELA S. HEFFELFINGER, DEFENDANT .~- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 2001 - 4550 CIVIL TERM 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 o' the filing and service of the Cemplaint. 3. I consent to the entry of a cinal Cecree 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 __ ,_._- _ requiremecit that L receive notice of intention to request entry of the decree. `'T' 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: /~~~~''O! //r o~ ./ - . ROBERT L. E LFINGER '- ~~ ROBERT L. HEFFELFINGER, PLAINTIFF v. PAMELA S . HEFE'ELFINGER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - 4550 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. T consent to the entry of a final decree without notice. 2. I understand that I may lose rights concerning alimony, division oz property, lawyer's fees or expenses if I do not claim them befor> a divorce is granted. 3. Y 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 prothonctary. " I 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: ~i~'-J~~d~ 13~1~!L/J ~" /~~.f~.~C/~11T-~' ROBERT L. HEFFEL GE ROBERT L. HEFFELFINGER, PLAINTIFF v. PAMELA S. HEFFELFINGER, DEE'ENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001 - 4550 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1, A Complaint in Divorce under Section 3301(c) of the Divorca_ 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 1920.42 (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 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. 1 ~- lX--~' ~ G DATED: ~ PAMELA S. HEFFEL~ GE E ROBERT L. HEFFELFINGER, PLAINTIFF v. PAMELA 3. HEFFELFINGER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAN NO. 2001 - 4550 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree 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. t I verify that the statements made in this Affidavit are true any: 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: _ I ~- (~- O L PAMELA S. HEFFELFI