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HomeMy WebLinkAbout09-0503COMPLAINT FOR DIVORCE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA In re: the Marriage of Keith B. Helfrick Plaintiff and Carol Ann Helfrick Defendant oq- 503 l:.iv;tTeri, Docket No. The Plaintiff, Keith B. Helfrick, respectfully declares the following: 1. Plaintiffs Residence: Plaintiff resides at 1717 Fisher Road, Mechanicsburg, Cumberland County, Pennsylvania and has been a resident of the Commonwealth of Pennsylvania for 40 years. 2. Defendant's Residence: Defendant resides at 11 Bradford Court, Mechanicsburg, Cumberland County, Pennsylvania and has been a resident of the Commonwealth of Pennsylvania for 40 years. 3. Marriage: On December ,8, 1995 in Mechanicsburg, Cumberland County, Pennsylvania, the Plaintiff and Defendant married. An official copy of the marriage license is attached to this COMPLAINT FOR DIVORCE. 4. Children: Plaintiff and Defendant have the following children born or adopted into their marriage: Name: Clay Joseph Helfrick Name: Victoria Lauren Helfrick Date of Birth: June 6, 1996 Date of Birth: November 6,1998 5. Jurisdiction: This Court is that of proper jurisdiction to hear this cause. The Defendant has agreed to file an Affidavit of Consent in this cause. Neither the Plaintiff or Defendant has been involved in any litigation or other proceeding involving the other party in this or any other jurisdiction with respect to their marriage or any other domestic matter. 6. Grounds for No-Fault: Plaintiff wishes a dissolution of marriage with Defendant based on the grounds the marriage is irretrievably broken and efforts at reconciliation have failed. Address, Line 1 Address, Line 2 COMMONWEALTH OF PENNSYLVANIA COUNTY OF and sworn to before me on this J day of Q(Dr , 20 O$? POP Or F?3wJ,tA4:?a y ?K;<? ?t3MMki?MA ? .d ?i;2iMN??0 cu V r l r+1 6_. AFFIDAVIT OF CONSENT COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA In re: the Marriage of Keith B. Helfrick Plaintiff and Carol Ann Helfrick Defendant OQ- 503 Civil Docket No. 1. A COMPLAINT FOR DIVORCE was filed between Plaintiff and Defendant on the ;7,-7- day of &T6 64 , 2008. 2. The marriage between Plaintiff and Defendant is irretrievably broken and efforts at reconciliation have failed. 3. I, tCet,, have received a copy of the COMPLAINT FOR DIVORCE, and I have read it thoroughly and understand it. I do not wish to contest this proceeding. I do not object to the declarations made in the COMPLAINT FOR DIVORCE. I do hereby consent to the relief requested in therein and to the entry of a DECREE OF DIVORCE dissolving and forever terminating the marriage between Plaintiff and Defendant. I consent that the court may hear this cause on any day convenient to the court without further notice to me. I further consent that the court may enter any order granting any and all the relief sought in the COMPLAINT FOR DIVORCE. 4. I waive any and all rights I may have to a motion for a new trial, a record testimony, findings of fact and conclusions of law, notice of trial, a notice of entry of a DECREE OF DIVORCE and my right to appeal. I do not waive any future rights I may have to the modification of any judgment or decree in relation to this cause. 5. I affirm under penalty of perjury that all statements in this Affidavit of Consent are accurate to the best of my knowledge. I have filed this Affidavit of Consent in good faith and have not colluded with anyone in relation to it, nor have I been subject to any force or duress in signing it. Date s V ,... J} ,.3... - _. `- IT3 C=l "? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Keith B. Helfrick : Case No. 2009-00503 Plaintiff VS. : Civil Action - Law Carol Ann Helfrick : Divorce Defendant Acceptance of Service Defendant in the above titled action hereby consents to and acknowledges service of the complaint in Divorce filed on February 2, 2009. The date of service by hand delivery was February 3, 2009. Defendant NoWWSW MdM Gm tay.NdmyPd* HWWMTwp., CW batiattdC=1W MyCommission ft1$Z= Member. Pennalvania A On Of NOla?les 2909 AIN 15 M 8: ? 3 C? Nay IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Keith B. Helfrick : Case No. 2009-00503 Plaintiff vs. : Civil Action - Law Carol Ann Helfrick : Divorce Defendant AFFADAVIT OF NON-MILITARY SERVICE Before me, notary public, personally appeared Keith B. Helfrick, Plaintiff in the above entitled case, who being duly sworn or affirmed according to law deposes and says, that the defendant or respondent above named is not in the military service of the United States of America, that he has s personal knowledge that the said defendant or respondent is now living at: and is employed at or by: Plaintiff further says that the obligation sought to be enforced in this suit is not an obligation against a surety, guarantor, endorser, or other person liable, primarily or secondarily for a party in the military service. 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.A. 4904 relating to unsw rn falsificatio to autho ' 'es. P amtiff ( ign here in nt of a notary public) Sworn and subscribed before me this ZZ day of (a 1C Q j ?_ , 2009. Mdft Hampde n T"36' CCW ?d 0W* mycamrrJWm8VWA&o 12,2000 M1tr, Ptnat*w t A"DCW* n of N00" OF THE 2 0 0 9 ,1 UN 15 ?ti4 8: 4 3 1'i 'rH1- 1-1-111 Dr fA VfAAiAfflAT ICI P AQ fAL' f-111%AU1PD1 AM" f-'fliTT?T`TV 21 i S SiL: L U V S\ 1 ill iV V1TS:T1111 Y 1 LiiJL7iT ili Z l: li111L111:C-il iiF L V Vii 1 S i Y N.!1! !4! Y III; Y q !N ! n Keith B. Helfrick : Case No. 2009-00503 N e,l.l,+;tt VS. : Civil Action - Law nroi vnn "Piiris i sivt?rs s Defendant _PA W%- _..---T------ T'__l__ 1719111 r_e YY AlY I.l i)l 1\Vlli.l. Vl K"aiLslll"" lV XLi%JsziLat lbllll • t1¦ A MY 11¦li• Vi,il i.a. it llLL4l JJIIaI%- Acceptance of Service 1 141111.111 111 ll Ll.i 4ll" V V L1 L1laLL 4V 11V 11 11L.1 L. t/Y VVl1JL.11W LV 411LL 4L.lil1V VW IL.LL?Ir) JVl V 1LaLi Vl Llll, rmmnlaint in Divorce tiled on !-'ehnsarv "l.- 'l.(}t?y_ 'ihe. bate of service. by hand deliverv YYUJI V"1 U41 ?' JI LVV/. 1. I consent to the entry of a final decree of divorce without notice. L. l LL11LL\.1 JLLL11LL Ulul 1 111UY 1- 11 11LJ LalJllVVllllll U11111V11Y. u1V lJ1Vl1 Vl -p-iY_ ILA-YVl J fees or expenses if I do not claim them before a divorce is granted. ^ T ., 3 ___._ _ ... .T .z a T --- T'. a. `_. z._-,-,:.. -.1 -.,:...') -. .1; ._.-" _1 -- - - - - 3 1 st. r• J. 1 Ul.1LLV1 JLt.Ll1L11.11Ut. 1 YY11111"L VV LA&Y VLIaVLL Lll ALlA" LilYVl VV LL?.Vl ?. \. 1J L.11 LLa1 t.LL VY LAIL. \l U1L and that a cony of the decree will he sent to me immediately after it is tiled with the copy . n-. _ .T_ _ .- -. _. _.. - A 1"ul"11"LUl y . I verify that the statements made in this affidavit are true and correct. I understand that f 4e ryia-YSt-I:t tier. i. Z?'jr1 r? eee AP ct:lz nrt to the r -ia tiae of ! K IT3.??.?'s. 'N ?9 :R`3?s21?` to 13aJL vilii' .11 11 a JiYL' L'V1 LV i.il V iVU Vi llntiwnrn I-aISi irarion in amnnnijes E )aTP.' F11 F[[ -&-FjI ;F OF THE C IY 2009 JUN 19 All 9-, 611 ?J1???:L??tiT rr PF,D N Y??j.?ti?,? ??, W; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Keith B. Helfrick : Case No. 2009-00503 Plaintiff vs. : Civil Action - Law Carol Ann Helfrick : Divorce Defendant Waiver of Notice of Intention to Request Entry of A Divorce Decree Under 3301 Acceptance of Service Defendant in the above titled action hereby consents to and acknowledges service of the complaint in Divorce filed on February 2, 2009. The date of service by hand delivery was February 3, 2009. 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: 4; ? ) 4 l Zodq v Defendant FILED- 0 vI: 1?c r'":,'un,ej?r"Y r THE 2009 JUN 19 AM 9: 0 l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Keith B. Helfrick : Case No. 2009-00503 Plaintiff VS. : Civil Action - Law Carol Ann Helfrick : Divorce Defendant TO the Prothonotary: Praecipe To Transmit the Record Transmit the record, together with the following information, to the court for the entry of a divorce decree: 1. Ground for Divorce: irretrievable breakdown under 3301© of the Divorce Code. 2. Date and Manner of service of the complaint: Hand delivery with signed acknowledgement. 3. Date of execution of the affadavit of consent required by 3301 (c) dated 4. No related claims pending. 5. Date and manner of service of the Notice of intention to fila preacipe a copy of which is attached . Date Plaintiff's waiver filed Date Defendant' waiver filed Plaintiff FILED-# H'I F OF "I'HP 1141,11 HONOTAPY 2009 JUI 19 Ali 9* 02 LA uiti Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Keith B. Helfrick V. Carol Ann Helfrick ' NO.2oo9-mm DIVORCE DECREE AND NOW, of , it is ordered and decreed that Keith B. Helfrick , plaintiff, and Carol Ann Helfrick , defendant, are divorced from the bonds of matrimony. 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 By Attest: J. Prothonotary ?9 Q9 Cut c'r _m 7& Rv