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Home My WebLink About08-1059r ADAM J. HEIKEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008- ) 6 S? CA;, CIVIL ACTION - LAW KIM M. HEIKEL, : Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Adam J. Heikel who currently resides at 34 Cardinal Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Kim M. Heikel who currently resides at 34 Cardinal Drive, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on the 24"' day of October, 2002. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Service Member's Civil Relief Act. 6. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 7. 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. COUNTI REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 330WQ OR (D) OF THE DIVORCE CODE 8. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 9. The marriage of the parties is irretrievably broken. 10. When at the appropriate time, Plaintiffwill file an affidavit stating that two years have expired from the date of separation. :1E COP' FROM , Taft ff" I "= ,I a 4X i ` UKI IV my h& me. Pa. f WHEREFORE, Plaintiffrespectfully requests the Court to enter a decree of divorce pursuant to Section 3301 of the Divorce Code. MARTSON LAW Hubert X. Date: By hsquire 10 East High reet Carlisle, PA 7013 (717) 243-3341 Attorneys for Plaintiff a VERIFICATION The foregoing Divorce Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the Divorce Complaint and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Adam J. Heikel FAFILES\Firm\SRB\Heflcel Divorce Complaint \v C .Q `,' w p? t vU' vV A ;Z7 i7 f fl`f Vin? )rrj F:\FILES\C1ients\12938\He&m1 Divorce Complaint Created: 611/06 8:50AM Revised: 2/19108 10: 50AM Hubert X. Gilroy, Esquire I.D. 29943 MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ADAM J. HENKEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008- 10 5q CIVIL ACTION - LAW KIM M. HENKEL, Defendant 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. Upon your request, the Court may require you and your spouse to attend up to three sessions. A request for counseling must be made in writing and filed with the Prothonotary within twenty (20) days of receipt of this Notice. 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. 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 Telephone (717) 249-3166 ADAM J. HENKEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008- CIVIL ACTION - LAW KIM M. HENKEL, Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Adam J. Henkel who currently resides at 34 Cardinal Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Kim M. Henkel who currently resides at 217 Louis Lane, Enola, Cumberland County, Pennsylvania. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on the 24' day of October, 2002. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Service Member's Civil Relief Act. 6. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 7. 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. COUNTI REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(C) OR (D) OF THE DIVORCE CODE 8. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 9. The marriage of the parties is irretrievably broken. 10. When at the appropriate time, Plaintiffwill file an affidavit stating that two years have expired from the date of separation. F:\FILES\Clients\12938\12938.1.Afndav.ser divorcr.wpd Created: 9120/04 0:06PM Revised: 2119108 10:28 AM Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ADAM J. HENKEL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. KIM M. HENKEL, Defendant NO. 2006- I D51 CIVIL ACTION - LAW IN DIVORCE ACKNOWLEDGMENT OF SERVICE I, KIM M. HENKEL, Defendant in the above divorce action, hereby acknowledge receipt and service of the Complaint in Divorce filed in the above matter along with the Notice to Plead on February , 2008. 'mMD'y - D T &,.4 1?lk_ KIM M. HENKEL C? C 7 ? f Y"t F:\FILES\CGents\12938 Henkel\Heokel Coos AM Created: 9/20/04 0:06PM Revised: 5/14/08 11:15 AM Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ADAM J. HENKEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008-1059 CIVIL ACTION - LAW KIM M. HENKEL, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on February 19, 2008. 2. Defendant acknowledges receipt and accepts service of the Complaint with executed and filed Acknowledgment of Service on or about February 19, 2008. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. 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. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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: S - 1 0? A? e KIM M. HENKEL/Defendant try ? - ? G r-n F:\F1LES\C&ms\12938 Heokdffieokel Coos Aff Crested: 9/20/04 0:06PM Revised: 5/14/08 11:15AM Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ADAM J. HENKEL, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2008-1059 CIVIL ACTION - LAW KIM M. HENKEL, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on February 19, 2008. 2. Defendant acknowledges receipt and accepts service of the Complaint with executed and filed Acknowledgment of Service on or about February 19, 2008. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. 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. 6. 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. 7. 1 have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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: 5 -lf-0S eVo, n Z7, k---, ? ADAM J. HENKEL/Defendant r: ? ?t y w ctt 0 FARLESTNentA12938 HenkeMenkel Praedpe.div.wpd Created: 9/20/04 0:06PM RA*d: 5/14108 11:18AM Hubert X. Gilroy, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER MARTSON LAW OFFICES I.D. 29943 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff ADAM J. HENKEL, IN THE COURT OF COMMON PLEAS OF Plaintiff COUNTY, PENNSYLVANIA V. NO. 2008-1059 CIVIL ACTION - LAW KIM M. HENKEL, Defendant : 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. Ground for Divorce: Irretrievable breakdown under Section (X)3301(c) ()3301(d)(1) of the Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complaint: February 19, 2008 by executed and filed Acknowledgment of Service. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff. May 19, 2008; by Defendant: May 19, 2008. (b) (1) Date of execution of the Plaintiffs affidavit required by Section 3301() of the Divorce Code: 2) Date of service of the Plaintiffs affidavit upon the Defendant: _ 4. Related claims pending: None. 5. Complete either (a) (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: May 19, 2008. (b) Date Plaintiffs Waiver of Notice was filed with the Prothonotary: May 19, 2008. (b) Date Defendant's Waiver of Notice was filed with the Prothonotary: May 19, 2008. Hubert XFeardorff y, Esquire Attorney intiff Martson Willimas Otto Gilroy & Faller Carlisle, PA 17013 717-243-3341 C7 ? C3 w -ri t r.` °L7- C: rn 1? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ADAM J. HENKEL No. 2008-1059 Plaintiff VERSUS KIM M. HENKEL Defendant DECREE IN + DIVORCE + + AND NOW, 1009 IT IS ORDERED AND + DECREED THAT ADAM J. HENKEL PLAINTIFF, KIM M. HENKEL AND 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; * Al0litC BY THE COURT: ATTEST: J + PROTHONOTARY y. il 4-W-