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Home My WebLink About09-0316A CHAD D. HEFLIN, Plaintiff V. KATHERINE R. HEFLIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 0 9- 3 A cxt 146rft CIVIL ACTION - LAW 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 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, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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 St. Carlisle, PA 17013 (717) 249-3166 OR (800) 990-9108 CHAD D. HEFLIN, Plaintiff V. KATHERINE R. HEFLIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 09 - 314 C; j ,'I tcr? CIVIL. ACTION - LAW IN DIVORCE COMPLAINT 1. Plaintiff is Chad D. Heflin, who currently resides at 2208 Ritner Highway, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Katherine R. Heflin, who currently resides at 2110 Douglas Drive, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 11, 1997. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Divorce is sought pursuant to the provisions of the Divorce Code, § 3301(c), and §3301(d) in that: The marriage is irretrievably broken. 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 such counseling. 8. Plaintiff does not request counseling, pursuant to §§3301(c) and 3301(d) of the Divorce Code. 9. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. Respectfully submitted, Date: `ate -V i Andrew H. Shaw, Esquire 200 S. Spring Garden Street Suite 11 Carlisle, PA 17013 (717) 243-7135 (717)243-7872 facsimile Attorney for Plaintiff VERIFICATION I, Chad D. Heflin, 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. Cons. Stat. § 4904 relating to unworn falsification to authorities. Date: Chad D. Heflin `Y ?- -- M _? rry yw t Or g- 9 CHAD D. HEFLIN, Plaintiff V. KATHERINE R. HEFLIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 09-316 CIVIL ACTION - LAW IN DIVORCE PROOF OF SERVICE I, Andrew H. Shaw, Counsel for the Plaintiff, Chad D. Heflin, hereby certify that a true and correct copy of the Divorce Complaint in the above captioned case was served upon Defendant via personal service on January 22, 2009. A copy of the Acceptance of Service is attached. Date: RM f Andrew H. haw, Esquire PA Sup. Ct. ID Num. 87371 200 S. Spring Garden St., Suite 11 Carlisle, PA 17013 717-243-7135 Counsel for Plaintiff CHAD D. HEFLIN, Plaintiff V. KATHERINE R. HEFLIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 09-316 CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Katherine R. Heflin, hereby accept service of the Divorce Complaint. Date: 0,2 -0q -0 9 Katherine R. Heflin, fe dant FILED-()r,1CE OF THE PROT ?? 10TAPY 2009 JUN -9 PH 2' 4 0 PIENINS''p'L" AN A CHAD D. HEFLIN, Plaintiff V. KATHERINE R. HEFLIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 0 T 3 l ?a CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301 (c) of the Divorce Code was filed on January 22, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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. Dated: CO q M ' Chad D. Heflin, Plainti ALED-4?: tir=iCE OF THE FY'J E H -,",4 FARY 2009 JUN - 9 Pty Z: 4 0 U4 16 -ti _,1,1?'"??Y Pff? S'Yi A-i' A CHAD D. HEFLIN, Plaintiff V. KATHERINE R. HEFLIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 09-316 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301 (c) of the Divorce Code was filed on January 22, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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. Dated: 1,09 r44 --( ''F lC;E 2009 JUN - 9 PH 2: 4 0 iPRI"4, -VAIN}A CHAD D. HEFLIN, Plaintiff V. KATHERINE R. HEFLIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 09-316 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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. Section 4904 relating to unsworn falsification to authorities. DATE: atherine R. Heflin, Def OF TH PROTH 'v IT Y 2009 JUN - 9 PM 2: 4 0 PENNSYLVANIA CHAD D. HEFLIN, Plaintiff V. KATHERINE R. HEFLIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: o9- 3 I tp CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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. Section 4904 relating to unsworn falsification to authorities. DATE: (Q Adg) , Chad D. Heflin, Plai tiff FILED--OliTii i OF THE PRA:? I"HNOTARY 2009 JUN -9 PM e= li 0 PEN ',SYLVAINIA 1110k . M CHAD D. HEFLIN, Plaintiff V. KATHERINE R. HEFLIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 09-316 IN DIVORCE CIVIL ACTION - LAW 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 §3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Personal service on January 22, 2009. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code: by Plaintiff on June 9, 2009; by Defendant on June 9, 2009; 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice was filed with the Prothonotary's Office: June 9, 2009, Date Defendant's Waiver of Notice was filed with the Prothonotary's Office: June 9, 2009. Date: By: Andrew H. eShaw, quire Attorney I.D. # 87371 200 Spring Garden Street, Ste. 11 Carlisle, PA 17013 Attorney for Plaintiff JJ!IU!eld Joj Iiauaoud (altuzcSMU) ZLBL-£bZ (LIL) (auogd) S £ i L-£bZ (LIL) £ I OL I V d `ais?i-MD pails uapnq OuudS 'S OOZ IL£L8 'ON 'Q'I 'ID 'dnS JuepuajaQ £ I OL I dd `alsiljl33 aniaQ se12noQ 0112 ui13aH •g ouiiaglex :snnolloj se passaippe `uowagj predoid 32ejsod `ssgo-isjid `lreux salelS pollun aql ui aums fuiould Xq `paureu molaq aql uo al-ep sup panns siam `p.zooag I!wsue i L oZ admaid `luawnoop Bumollo3 aqj jo Woo ioouoo put, anal e I-eqj K3ijzao Xgwaq op `aacnbsg `mugs .H ma.zpuV `I 3DIA'HgS 30 31VJIAIIH33 .. ,AWNWASM43c3w4 I I •Z ltd 5- Nnr 6oaz A8ViQN()rHiO6d :'Hl JO 38 'b" . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHAD D. HEFLIN V. KATHERINE R. HEFLIN NO. 09-316 DIVORCE DECREE AND NOW, r? ?- l!J vo it is ordered and decreed that CHAD D. HEFLIN plaintiff, and KATHERINE R. HEFLIN bonds of matrimony. 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 D By the Court, J. q 09