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Home My WebLink About01-0727IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PAMELA S. HEISHMAN, PLAINTIFF MARK E. HEISHMAN DEFENDANT No. -200I 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 the diw>rce 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 the Cumberland County Courthouse. 1 Courthouse Square, Carlisle, PA 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 Lawyer Referral Service 2 Liberty Ave. Carlisle, PA 17013 717-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PAMELA S. HEISHMAN, PLAINTIFF Vo MARK E. HEISHMAN DEFENDANT No. ~/- '7.~ 7 -2001 CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c} OF THE DIVORCE CODE 1. Plaintiff is Pamela Sue Heishman, who currently resides at 113 South Hanover St. Apartment 5, Carlisle, Cumberland County, Pennsylvania 17013, since October 16, 2000. 2. Defendant is Mark E. Heishman, who currently resides at 399 Pinedale Road, Carlisle, Cumberland County, Pennsylvania 17013, since 1958. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 17, 1985 at West Hill Church in Newville, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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 counseling. 8. Plaintiffrequests the court to enter a decree of divorce. Attorney for Plaintiff ID No. 52651 61 W. Louther St. Carlisle, PA 17013 717-249-1177 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 unswom falsification to authorities. DATE: Pamela S. Heishman, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PAMELA S. HEISHMAN, PLAINTIFF Vo MARK E. HEISHMAN, DEFENDANT NO. 727-2001 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301 (c) of the Divorce Code was filed on February 6, 2001. 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 ora 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: & -13-0q Pamela S. Heishman, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PAMELA S. HEISHMAN, PLAINTIFF MARK E. HEISHMAN, DEFENDANT NO. 727-2001 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT A complaint in divorce under § 3301(c) of the Divorce Code was filed on February 6, 2001. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 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: MARK E. HEISHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PAMELA S. HEISHMAN, PLAINTIFF Vo MARK E. HEISHMAN, DEFENDANT NO. 727-2001 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER § 3301 (c) AND (d) 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 ifI do not claim them before a divorce is granted. 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 unswom falsification to authorities. Dated: o~ -13 - aY Pamela S. Heishman, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PAMELA S. HEISHMAN, PLAINTIFF MARK E. HEISHMAN, DEFENDANT NO. 727-2001 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c} AND $ 3301(d} OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 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 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 prothono*,ary. I veri:~'y 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: MARK E. HEISHMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA PAMELA S. HEISHMAN, PLAINTIFF MARK E. HEISHMAN DEFENDANT No. 727-2001 CIVIL ACTION - LAW IN DIVORCE PROOF OF SERVICE BY MAIL PURSUANT TO PA. 1L C. P. 1930.4 I, Stephanie E. Chertok, swear that I mailed a copy of the Complaint in Divorce filed in this matter by certified U.S. mail, return receipt requested, to the Defendant at 399 Pinedale Road, Carlisle, Cumberland County, PA 17013, on February 8, 2001. The return receipt signed by the Defendant is evidence of delivery to him and is attached hereto. DATE: ID No. 52651 61 W. Louther St. Carlisle, PA 17013 717-249-I 177 Plaintiff Mark E. Welshman, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 727-2001 CIVIL TERM 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) 3301 (d)(1) ~f th~ Oi'v~ cc C'oJ~. (Strike out inapplicable sectio(3). 2. Date and manner of service of the complaint: February 8, 2001 by Certifiec] ~a~ Complete either paragraph (al or (b). (al Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: bypiaintiff February 13, 2004 ; by defendant January 20, 2004 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: None 5. Complete either (al or (b). (al Date and manner of serwce of copy of which is attached: the notice of intention to file praecipe to transmit record, a (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: ye~,r~ary 18. ?D0~, Date defendant's Waiver of Notice in {}3301 (c) Divorce was filed with the Prothonotary: February 18, 2(304 IN THE COURT Of COMMON OFCUMBERLAND COUNTY STATE OF ~~ PENNA. Pamela $. Heishman, Plaintiff NO. 727 VERSUS Mark E. Heishman, Defendant pLeas - 2001 Decree IN DIVORCE AND NOW, /"g~ ~' DECreed THAT Pamela $. ~eishman ~d~/ , IT IS ORDERED AND ,pIA] NTIFF, AND Mark E. ~eishman , 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; None. By The COUrt: / PROTHONOTARY