Loading...
HomeMy WebLinkAbout07-5025 STACY B. WOLF, ESQUIRE ATTORNEY ID N0.88732 10 WEST HIGH STREET CARLISLE PA 170]3 (717) 241-4436 ATTORNEY FOR PLAINTIFF SUE A. HEFFLEFINGER, Plaintitl' v. BRADY O. HEFFLEFINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.07 - Sd ~S CIVIL TERM IN 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 in divorce or annulment maybe 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, Cumberland County Courthouse, Carlisle, Pennsylvania 17013. 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 170Li (717) 241{436 ATTORNEY FOR PLAINTIFF SUE A. HEFFLEFINGER, Plaintiff v. BRADY O. HEFFLEFINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.07 - ~ ~ ~ CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(C) OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Sue A. Hefflefinger, an aduk individual residing at 240 Richwine Road, Apt. 10, Shermansdale, Perry County, Pennsylvania 17090. 2. The defendant is Brady O. Hefflefinger, an adult individual residing at 52 Buttonwood Lane, Carlisle, Cumberland County, Pennsylvania 17015. 3. The plaintiff and defendant have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on April 1,1984, in Hagerstown, Maryland. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as this Honorable Court may deem equitable and just. I verifythat 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. Section 4904, relating to unsworn falsification to authorities. 2007 Sue A. Hefflefinger, Pla' tiff WOLF & WOLF 2007 BY: ~-- STACY B. OLF, ESQU Supreme Court ID #8873 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Attorney for Plaintiff Q ~~ Q [~ (vAVa\ ( nN 1 - -V V^\ V ~) C._ ~. ~' rJ C=? Lj:~ -.. dt `~~,J `~ ...+' ~,a ~.. ~_) 'T) .~ .,_1~ `1 t~~ .~ ..ti STACY B. WOLF, ESQUIRE ATTORNEY ID N0.88732 10 WEST HIGH STREET CARLISLE PA 170]3 (717) 241-4436 ATTORNEY FOR PLAINTIFF SUE A. HEFFLEFINGER, Plaintiff v. BRADY O. HEFFLEFINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.07 - ~~~ CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require. that my spouse and I participate in counseling. 2. I undelstand that the court maintains a list of marriage counselors in the Prothonotar~s Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verifythat the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. GS. Section 4904 relating to unsworn falsification to authorities. C ~_, 2007 Sue A. Heffiefinger, Pla' 'ff r.') r.~ `•-- ~~~ ~_;y t_~ _ ~ ~ ~T . _ ~7r _~ _ 9'x.3 `~ ~j ~"1 ~..) _-i L~ ~ STACY B. WOLF, ESQUIRE ATTORNEY II) N0.88732 10 WAST HIGH STREET' CARLISLE PA 17A13 (71~ 241.4[36 ATTORNEY FOR PlrIIIaTTgF SUE A. HEFFLEFINGER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND CO LINTY, PENNSYLVANIA n. CPVIL ACTION -LAW BRADY O. HEFFLEFINGER, Defendant ~ N0.07 - ~,~(~.~ CIVIL TERM IN DIVORCE I, Brady O. Iiefflefinger certify that I am 'the defendant in hereby certify that on d , 2007, I received a ~ro per. f~the~~~ I complaint filed in th;~ actio PY dlvonce 2007 ....,. ~ o tx_~ rr-; to ~ ~"-~ ^C _ .. ~ C3 ~-~ _~ cx1 -~ ~ ~ STACY B. WOLF, ESQUIRE ATTORNEY ID NO.56732 30 WEST HIGH STREET r~gir~RPA17013 f 717) 241-436 ATTORNEY POR PLAINTTFp SUE A. HEFFLEFINGER, Flaiatiff n. BRADY O..HEFFLEFINGER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.07 - ~,_ CIVIL TERM IN DIVORCE The defendarn, being dulysworn accoitiing to law, deposes and says: 1. I have been advised of the avai).Tbility of marriage. counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I undeiataud that the court maintains a list of marriage counselors in the Pmthonotary's Office, which list is aval7able to me upon request. 3. Being so advised, I do not request that the court re quire that my spouse and I participate in Counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are tnie and cornec~t. I understand that false statements herein made are subject to the penalties of 18 Pa. C,.S. Section 4904 relating to unsworn falsification to authorities. --~.-~_, zoo? cs -.~ ~ 4 "D . -t ~ ~-` ~ ~` © ~3 ~ ~ ~ ~• p Cj clt fp ..~ NwRO~a s. ~RMIIN, u~ wTTORNEY ~o No. 29020 64 SOUTH PITT STREET CARLISLE PA 1701 S (717) Z43-dOSO ATTORNEY FOR PWNTIFF SUE A. HEFFLEFIN6ER, Plalntl~f vs. BRADY O. HEFFLEFINGER, Deindant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2007 - ~ O 2~~]CIVIL TERM IN DIVORCE PRAECIPE FOR WITHDRAW AND ENTRY OF APPEARANCE OF COUNSEL OF RECORD TO THE PROTHONOTARY: Please withdraw the appearance of STACY B plaintiff in this matter. Marcho~, 2008 WOLF, ESQUIRE as attorney of record for the ........... ~, STACY B. W F WOLF & WOLF 10 West High Street Carlisle, PA 17013 (717) 241-4436 Please enter the appearance of HAROLD S. IRWIN, III, ESQ IRE as attorney of record for the plaintiff in this matter. h c`l, , 2008 HAROLD S. IRWIN, II IRWIN LAW OFFICE 64 South Pitt Street Carlisle, PA 17013 717-243-6090 Supreme Court ID No. 29920 ? r-~ ` .~ --~ ~y , ~ ~ -~. x.. -~- _~, ~ .,~~, -r `<<< ,: ~ -~:- _. ~'» ~r° `}~ ~ _,. ' ~ .._.,~ SUE A. NEFFLEFIN6ER, PlalntiM'f vs. BRADY O. HEFFLEFIN6ER, Dstsndant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.2007 - 502E CIVIL TERM IN DIVORCE AFFDAVIT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or about August 22, 2007. Service of the complaint was made upon defendant as indicated on defendant's acceptance of service filed on September 20, 2007. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. June ~, 2008 SUE A. HEFFLEFING R WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY of w Dn-ORCE DECREE UNDER SECTION 3S0'I (D~ OF THE DIVORCE CODE 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 statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. c June ~, 2008 VL SUE E. HEFFLE 1 G R SUE A. HEFFLEFINOER, : IN THE COURT OF COMMON PLEAS Plaintlfl` : OF CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION -LAW v. NO. 2007 - 5025 CIVIL TERM BRADY O. HEFFLEFINGER, Defendant : IN DIVORCE AFFDAVIT OF CONSENT A complaint in divorce under Section 3301(d) of the Divorce Code was filed in this matter on or about August 22, 2007. Service of the complaint was made upon defendant on or about August 24, 2007, as indicated on the Acceptance of Service filed herewith. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. May ~, 2009 UNDER SECTION 3301 (D) OF THE DIVORCE CODE 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 statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. May S 2009 ENTRY OF A DIVORCE DECREE F'1~~--t.~r=~~E 20~~ MAY -7 PN Z~ ~ ! FNI~^Yl.~'r~~~a#1 HAROLD S. 1 wIN~ 111, EsQU1RE ATTORNEY D NO. 29920 64 SOUTH P TT STREET CARLISLE P 1701 S (717) ATTORNEY OR PLAINTIFF SUE A. v. BRADY O. FFLEFINGER, : IN TH! COURT OF COMMON PLEAS PlalntMf : OF CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION - LArll NO. 2007 -5025 CIVIL TERM HEFFLEFIN6ER, : DNsndant : IN DIVORCE ACCEPTANCE OF SERVICE I, BRADY . HEFFLEFINGER, defendant in this matter, hereby certify that f accepted service of a copy of the complaint in this divorce on or about August 24, 2007. I verify that he statements made in this acceptance of service are true and correct. I understand hat false statements herein are made subject to the penalties of 18 Pa. C.S. Section 490 relating to unswom falsification to authorities. May ~, ~~ ~~~ ~~~ ~ ~ ~::~ ~~-3~r~,~1~ 2~~9~'i~~ ~'b F~~ ~~ '`. ~-~ ` ~ , ~ . HAROLD S. 1 wIN, 111, ESQUIRE ATTORNEY D N0.28920 64 SOUTH P TT STREET CARLISLE P 17013 (717) 243-6 ATTORNEY OR PLAINTIFF su! A. He v. BRADY O. To the Proth~ Tran decree: 1. 2. was served v 3. 4. 5. May ilR, : IN THE COURT OF COMMON PLlAS OF PlalntMf : CUMBlRLAND COUNTY, PlNN3YLVANIA :CIVIL ACTION -LAIN NO. 2007 -:1025 CIVIL TlRM HlFFLlFINGlR, Ds+fsndant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD the record, together with the following information, to the court for entry of a divorce Ground for divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. Date and manner of service of the complaint: On or about August 24, 2007, defendant a copy of the divorce complaint (See Acceptanc of Service filed simultaneously herewith.) Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: February 12, 2009 By the defendant: April 3, 2009 (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: N/A. Related claims pending: None Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A. (b) Date plaintiffs Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: May 26, 2009 Date defendants Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: May 26, 2009 HAROLD S. IRWIN,111 Attorney for Plaintiff ~ ~~;~.i ~-'. ~.. Z~~~ ~i,~al~ ~°J ~.; ,. la:. .: .. ., ...•~ R s 1 ~ ~ I 1: F~ t_ .) _ .. SUE~A. HEFFLEFINGER, Plainfiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. ~Y O. HEFFLEFINGER, Defendant NO 2007 - 5025 CIVIL TERM DIVORCE DECREE SUE AND NOW, ~ 2 ~ 'Z oog , it is ordered and decreed that A. HEFFLEFINGER, Plaintiff plaintiff, and )Y O. HEFFLEFINGER, Defendant ,defendant, are divorced from the of matrimony. Any existing spousal support order shall hereafter be deemed an order for y pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for wfhich a final order has not yet been entered. Those claims are as follows: (If no remain indicate "None.") NONE By the Court, ~ ~ s- ~q ~o~ w ,,