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HomeMy WebLinkAbout10-3312LAURIE W. HELWIG, Plaintiff v. RODGER A HELWIG, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ~ N :CIVIL ACTION -LAW G • lb -- 33l0~ Ctv~ t l eCMI` `'~ ~ ~' i p ~;, ~-=' ~' ~:~ NOTICE TO DEFEND AND CLAIM RIGHTS 00 0 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse 4th Floor, One Courthouse Square Carlisle, PA 17013 (717) 240-6200 _~, ---~ -r r~~ ~ -~ ,-~. --~, ~, ~. ,_~ _ _.: c_ ~~.} '_ ._. T~; ~'~n. .~ ~''I'(o7.50 PQ l4Try e~," 5ot 8 2~ a~I a3~ ~~~ r LAURIE W. HELWIG, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v :CIVIL ACTION -LAW RODGER A HELWIG, NO. Defendant IN CUSTODY COMPLAINT UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is Laurie W. Helwig, an adult individual who resides at 602 Park Ridge Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Rodger A. Helwig, an adult individual who resides at 440 Waterleaf Court, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. The plaintiff and defendant were married on May 15, 1993, at Harrisburg, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and that plaintiff has the right to request that the court require that the parties participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce r Count II Custody 9. Paragraph 1 through 8 are incorporated herein by reference. 10. Plaintiff seeks custody of Andrew A. Helwig, born May 15, 1997, and Noah J. Helwig, born October 31, 2003. 11. The children were not born out of wedlock. The children are presently in the custody of Laurie W. Helwig, who has had custody of the children since September, 2007. 12. For the past five years, the children have resided with the following persons at the following addresses: Custodian Address Dates Laurie W. Helwig 602 Park Ridge Drive 4/07 to Mechanicsburg, PA present Laurie W. Helwig 602 Park Ridge Drive 1/07 to Rodger A. Helwig Mechanicsburg, PA 4/07 Laurie W. Helwig 3520 Rolo Court 7/97 to Rodger A. Helwig Mechanicsburg, PA 1 /07 13. The mother of the children is Laurie W. Helwig who currently resides at 602 Park Ridge Drive, Mechanicsburg, Pennsylvania. She is married to defendant. 14. The father of the children is Rodger A. Helwig, currently residing at 440 Waterleaf Court, Mechanicsburg, Pennsylvania. He is married to plaintiff. 15. The plaintiff currently resides with Craig Starner, Andrew A. Helwig and Noah J. Helwig. 16. The defendant currently resides with Dianne Gray and her three children. 17. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. 18. The plaintiff has no information of a custody proceeding concerning the children pending in a court in this Commonwealth or in any other court. 19. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 20. The best interest and permanent welfare of the children will be served by granting the relief requested. 21. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, plaintiff requests this Court to award her primary legal physical custody of Andrew A. Helwig and Noah J. Helwig. H. Rehkamp, Esquire ~ AND O'CONNELL ~ 1 North Front Street Harrisburg, PA 17110 (717) 232-4551 Attorney for plaintiff Verification I verify that the statements made in the foregoing Complaint are true and correct. I understand false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Clw~ ~ ' Y 7 O au e W. Helwig Date:.5 v~' LAURIE W. HELWIG, IN THE COURT OF COMMON PLEAS Plaintiff :POTTER COUNTY, PENNSYLVANIA v. NO. 2010- RODGER A. HELWIG, :CIVIL ACTION -LAW Defendant IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counteraffidavit within twenty days after this affidavit has been served on you or the statements will be admitted. Plaintiff s Affidavit Under Section 3301(d) of the Divorce Code The parties to this action have continued to live separate and apart for a period of at least two years, since September 15, 2007. 2. The marriage is irretrievably broken. 3. 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. 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. Section 4904 relating to unsworn falsification to authorities. Date 7 IN THE COURT OF COMMON PLEAS OF LAURIE W. HELWIG :CUMBERLAND COUNTY, PENNSYLVANIA V. RODGER A. HELWIG 10-3312 CIVIL TERM . ~NO. DIVORCE DECREE AND NOW, ~~_ a~, aal d , it is ordered and decreed that LAURIE W. HELWIG plaintiff, and RODGER A. HELWIG ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente life 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 the Court, A J. Prothonotary 7~~~ ~ ~ o Cc~1-- G ma.~ lQa -~o ~ ~~~