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Home My WebLink About08-6723 JENNIFER E. HECKENDORN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO.2008- u 793 CIVIL TERM KEVIN S. JONES, CIVIL ACTION -LAW 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 marriage, you must request marriage counseling. A list of marriage counselors is avail- able in the Office of the Prothonotary at 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 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 6k( y MAX J. SMITH ' ., Esquire JARAD W. HANDELMAN, Esquire Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 i w Max J. Smith, Jr., Esquire Attorney I.D. #32114 Jarad W. Handelman, Esquire Attorney I.D. #82629 James, Smith, Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 Telephone: 717-533-3280 Fax: 717-533-2795 e-mail: mjs@jsdc.com JENNIFER E. HECKENDORN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO.2008- (,7 d 3 CIVIL TERM KEVIN S. JONES, CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the Plaintiff, JENNIFER E. HECKENDORN, by her attorney, MAX J. SMITH, JR., Esquire, and seeks to obtain a Decree in Divorce upon the grounds hereinafter more fully set forth: 1. The Plaintiff, JENNIFER E. HECKENDORN, is an adult individual and citizen of the United States of America, whose address is 4 Bellaire Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, KEVIN S. JONES, is an adult individual and citizen of the United States of America, whose address is 18 Woodcrest Drive, Carlisle, Cumberland County, Pennsyl- vania 17013. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on or about September 18, 2007 in Carlisle, Pennsylvania. 5. Plaintiff avers that there is one (1) child of the parties under the age of 18, namely: JADYN A. JONES, born September 26, 2003. 6. Neither Plaintiff nor Defendant is a member of the United States Armed Services. 7. Plaintiff and Defendant have both been advised of the availability of marital counseling and that each may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff avers that there has been no prior action for divorce or annulment of the marriage filed by either party in this or any other jurisdiction. 9. Plaintiff avers that the marriage is irretrievably broken. WHEREFORE, Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. Respectfully submitted, Date: November 12, 2008 &?Nq MAX J. SMITH, , Esquire I.D. No. 32114 JARAD W. HANDELMAN, Esquire I.D. No. 82629 James, Smith, Dietterick & Connelly LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 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. Section 4904, relating to unsworn falsification to authorities. ZI A" ?' tcs t. JENNIFER E. HECKENDORN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2008-6723 CIVIL TERM KEVIN S. JONES, CIVIL ACTION -LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 13th day of November, 2008, I, MAX J. SMITH, JR., Esquire, Attorney for Plaintiff, hereby certify that I have this day sent a copy of Complaint in Divorce by depositing a certified copy of the same in the United States mail, postage prepaid, certified mail #7008 1300 0001 8217 1951 at Hummelstown, Pennsylvania, addressed to: Kevin S. Jones 18 Woodcrest Drive Carlisle, PA 17013 Mailing and return receipt cards attached hereto. MAX J. SMITH, JR. squire I.D. No. 32114 JARAD W. HANDE MAN, Esquire I.D. No. 82629 James, Smith, Dietterick & Connelly u.e P.O. Box 650 Hershey, PA 17033 (717) 533-3280 Ln IT, r44 FF .. II QE A ni No Postage $ A COMW Fee a D wirm* x ` Q O Retum Receipt Fee (Endoraernent Requlre? .'?.? !ere.. O Fee (Endotaertierd Required) y ?10 em-l Total Floatage d Fees I s q , -7 IV C3 aw TO ur PO S Ab ?? , or OX - J .. .?. W Q(d, Mw ....... .. ........??. g:-C------------------- i AA; 0 SWO" kwo 1, 2, end d& Also co?tMede IMM 4 If'Reebluts rf o.uwery Is dembft M ant y w name mW e 11 1 on the reverse a that we cm mtwn the cod t o.yom 11 Ifs h ibis dend to the tack d the mdpiece elr on the front ii: specs pem IW 1. Alice AddMand to: c? of 3 ... 0 AGW X 4mlneJnIAA AMM. - VJA ?l ? c. r? ar orlMrwtr 0. is d.NwyelttiiNiee AMtswrsAom IMm 14 D'Nes s. M YES, erlser deetwery adkMew tlelow: D No PLc?ndsW Mdl 0 r. F Mw 0 R ols- 1 0 FMtixn wee>.Ipt for MMetrr 0 OWANd Mw p G.O.Q. 7006 1300 adOl 6-217 1451 + 3V 1 1411hriirrllIW 00*6malwafU r-al *rrt ,ter •;..? n? JENNIFER E. HECKENDORN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. NO. 08 - 6723 CIVIL TERM KEVIN S. JONES, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 2008. 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on November 12, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. 1 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: S, Kevin S. Jones, Defen nt WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 0301(c) AND §3301(d) OF THE DIVORCE CODE 1. 1 consent to entry of a final decree of divorce without notice. 2. 1 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: yZ ' . Kevin S. Jones, Defendant F(C1 try i?E JF ?N f'c^T{.,,_ne `TAR 2009 OCT 30 P 3: 34 N -. JENNIFER E. HECKENDORN, : IN THE COURT OF COMMON I tr4S +tr Plaintiff : CUMBERLAND COUNTY, PENfYLVAN 'A V. : NO. 08 -C-12NCIVIL.TERM KEVIN S. JONES, : IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on or about December 16, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. 1 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Date: p? )\', kJ-Y 0 4:4 nn r 4He dorn, Plaintiff WAIVER OF NOTICE I ENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(01 AND 43301(d) OF THE DIVORCE CODE 1. 1 consent to entry of a final decree of divorce without notice. 2. 1 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. 1 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 nswo ific2 to authorities. Date: 1 --- , E. Heckbnaorn, Plaintiff JENNIFER E. HECKENDORN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA C) N vs. NO. 08 - 6723 Civil Term KEVIN S. JONES, ACTION IN DIVORCE E - 1 T T Defendant rv PRAECIPE TO TRANSMIT RECORD , TO THE PROTHONOTARY: Please accept this request to transmit the "rec6td, " together with the following information to the Court for entry of a divorce Decree: 1. Grounds for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and Manner of the service of the Complaint: via first class mail, return receipt requested, service on November 15, 2008. 3. Date of execution of the Affidavit of Consent required by 3301(c) of the Divorce Code: By Plaintiff: January 22. 2010 By Defendant: January 26. 2010 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice under §3301(c) of the Divorce Code was filed with the Prothonotary: January 29. 2010 6. Date Plaintiffs Waiver of Notice under §3301(c) of the Divorce Code was filed with the Prothonotary: Contemporaneously with this Praecipe espectfully subm' ed, Date: tA ms, Esqui re 9465 uth St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF JENNIFER E. HECKENDORN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 08 - 6723 Civil Term KEVIN S. JONES, ACTION IN DIVORCE - _y Defendant C S AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on November 12, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. 1 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 also 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) Z U moo"`- 1?-- Kevin S. Jones, Def ndant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) AND 43301(d) OF THE DIVORCE CODE 1. 1 consent to entry of a final decree of divorce without notice. 2. 1 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. 1 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: t /,??ivP I l (: t two . Zi; Kevin S. Jones, Def ndant IN THE COURT OF COMMON PLEAS OF JENNIFER E. HECKENDORN CUMBERLAND COUNTY, PENNSYLVANIA V. KEVIN S. JONES NO. 08 - 6723 Civil Term DIVORCE DECREE AND NOW, _ FC63 0?`y 1? it is ordered and decreed that JENNIFER E. HECKENDORN KEVIN S. JONES bonds of matrimony. plaintiff, and defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None; the marriage settlement agreement, which was signed by the parties on May 27, 2009, shall be incorporated and not merged into this agreement. By the Court, r YV?? Attest: '4 ,?ua-ej a /i ?c X70 Al4