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
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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
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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
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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
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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
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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
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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-
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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
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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
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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
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G RIESMEYER
Supervising Attorney
FAMILY LAW CLINIC
45 N. Pitt Street
Carlisle, PA 17013
717-243-2968
Fax: 717-243-3639
Attorneys for Plaintiff
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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;
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