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HomeMy WebLinkAbout07-7113Melissa Hetrick, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Brandon Hetrick, Defendant : NO. 07- -7113 CIVIL TERM 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 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, Cumberland County Courthouse, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 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. Melissa Hetrick, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Brandon Hetrick, Defendant : NO. 07- 7f ?3 CIVIL TERM DIVORCE COMPLAINT The plaintiff, Melissa Hetrick, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. 93301(,cc), 3301(4) AND 3301(a)(6) OF THE DIVORCE CODE 1. 2. 3. 4. 5. 6. 7. Plaintiff is Melissa Hetrick, who currently resides at Cumberland County Prison Carlisle, PA 17013, since August 14, 2007. Defendant is Mr. Brandon Hetrick, who currently resides at Cumberland County Prison Carlisle, PA 17013 , since August 14, 2007. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. Plaintiff and Defendant were married on April 2006 in Carlisle, Cumberland County, Pennsylvania. Plaintiff and Defendant have lived separate and apart since August 14, 2007. There have been no prior actions for divorce or for annulment between the parties. The marriage is irretrievably broken. 8. Plaintiff avers that Defendant has offered such indignities to Plaintiff, an injured and innocent spouse, as to render the condition of Plaintiff intolerable and life burdensome 9. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Y?1 Scott Weber Certified Legal Intern ROBE 4(T E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date -/O /')'a//q Plaintiff" Melissa Ha 0 rJ .. --_ ? y `LL's (C7 ` -33 33 Melissa Hetrick, Plaintiff V. Brandon Hetrick, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 07- 7113 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Melissa Hetrick, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date ?'1 a U Respectfully submitted, vt V if, Scott Weber Certified Legal Intern fi-pw &J, ROB T E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 717-243-3639 "< fTp i' . N . { CI P.,) -< MELISSA HETRICK, Plaintiff v BRANDON HETRICK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN DIVORCE No. 07-7113 CIVIL TERM To The Prothonotary: PRAECIPE TO REINSTATE COMPLAINT Please reinstate the Divorce Complaint at the above-captioned docket. 1 Michael Lightfoot Certified Legal Intern Ann ald-F Supervising Attorney Penn State Dickinson Family Law Clinic 45 North Pitt St Carlisle, PA 17013 Date: February 1, 2008 ? o 'Z3 C7 Melissa Hetrick, Plaintiff V. Brandon Hetrick, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 07-7113 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Melissa Hetrick, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date Res ectfully sub fitted, I ' IN Michael Lightfoot Certified Legal Intern ROBER THOMAS M. PLACE ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 717-243-3639 G ?; .,? Y?fc?:? ? ? ? ..G ? MELISSA HETRICK, Plaintiff V. BRANDON HETRICK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 07-7113 CIVIL TERM ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint on behalf of Brandon Hetrick and certify that I am authorized to do so. r Date a-'4-06 T' ell, Esq. Attorney for Brandon Hetrick, Defendant 4415 N. Front Street Harrisburg, PA 17110 (717) 232-4551 s.? l -0 Melissa Hetrick, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Brandon Hetrick, ; Defendant :NO. 07-7113 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on November 28, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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 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. §4904, relating to unsworn falsification to authorities. Date r-a ? ' v ,? - 4'.? .? 1 ? t .. - _. r 4f? ?? ?.., s ?y s??' ' ' 4L'' Melissa Hetrick, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Brandon Hetrick, Defendant :NO. 07-7113 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(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 statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date 02 0S1- C'x_ e-7 ?:?: c- ?? °?-? , `" ?t -? _ rZ f?7{?. r'. ? 4.' ?'_ -i .; j:.. ?°r ^^`° Melissa Hetrick, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Brandon Hetrick, Defendant :NO. 07-7113 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on November 28, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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 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. §4904, relating to unworn falsification to authorities. Date W 3/d ?s# t9q-62. -goys' Brandon Hetrick, Defendant ?,: ..C? t??. - c...; a ms`s r?? ' ?`,? . ? , ?. -_, t_t ? - ?. -- "? =; s r_ ' ? c.? C3 =_; . _ Melissa Hetrick, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Brandon Hetrick, Defendant :NO. 07-7113 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(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 statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn falsification to authorities. Date 6/31/05! O Brandon Hetrick, Defendant w.. "``' '°?-?f'- ?:..? c..., ? ;?. n?? - , -? ?.' -- ti;?ri Melissa Hetrick, Plaintiff V. Brandon Hetrick, Defendant PR To the Prothonota Transmit the recoi divorce decree: 1. Ground for div IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW IN DIVORCE : No. 07 - 7113 CIVIL TERM TO TRANSMIT RECORD together with the following information, to the court for entry of a irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and mann er of service of the complaint: Served on Timothy J. O'Connell, Attorney for Defendant, a ccompanied by Acceptance of Service. Service was complete upon receipt by Timothy J. O' Connell, Esquire on February 4, 2008. 3. Date of execut ion of the affidavit of consent required by §3301(c) of the Divorce Code: by Plaintiff- May 1, 2008; by Defendant- June 3, 2008 4. Related claims pending: none 5. Date Plaintiff Waiver of Notice was filed with the Prothonotary: May 23, 2008 Date Defend is Waiver of Notice was filed with the Prothonotary: June 26, 2008 a? 6% Date MICHAEL LIGHTFO Certified Legal Intern + .? G RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff " C > ? =n -_ c_... ?. -r, <? ? ?? ?? ?,a r . . ?:. ;? . -? . ?w ss =? ?...; IN THE COURT OF COMMON PLEAS Melissa Hetrick, Plaintiff VERSUS Brandon Hetrick, Defendant No. DECREE IN DIVORCE 2007 - 7113 -7-a , IT IS ORDERED AND AND NOW, Aj I DECREED THAT AND OF CUMBERLAND COUNTY STATE OF PENNA. Melissa Hetrick Brandon Hetrick ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, 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; ?!?(?, ?^ ? ? ??"? s :>; ?; .? ,• . ?• ? 'L' ?f , ?C ?,