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Home My WebLink About02-0223FRANCES MARIE HEIN, Plaintiff RONALD JAMES HEIN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : IN DIVORCE : NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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 judgement 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, 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 !,EGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 FRANCES MAIRE HEIN, Plaintiff RONALD JAMES HEIN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. IN DIVORCE COMPLAINT 1. The Plaintiff is Frances Marie Hein, who currently resides at 7 Locust Circle, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is Ronald James Hein, who currently resides at 517 Boston Court, Mechanicsburg, Cumberland County, Pennsylvania. 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 August 20, 1977 at Corpus Christi, Texas. COUNT I - DIVORCE 5. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Divorce is sought pursuant to the provisions of the Divorce Code, Sections 3301(c) and 3301(d), in that: a) The marriage is irretrievably broken. b) Plaintiff and Defendant have lived separate and apart since January 14, 2002 and continue to do so. 8. The 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. 9. Defendant is not a member of the armed services. WItEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce. COUNT H - EQUITABLE DISTRIBUTION 10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as though set forth in full. 11. Plaintiff and Defendant have acquired property, both real and personal, during their marriage from August 20, 1977 until January 14, 2002, the date of their separation, which property is "marital property". 12. Plaintiff and Defendant may have owned, prior to the marriage, property which has increased in value during the marriage and/or which has been exchanged for other property, which has increased in value during the marriage, all of which property is "marital property". 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property prior to the filing of this Complaint. WHE~FO~, Plaintiff requests this Honorable Court to equitably divide all marital property. COUNT HI - ALIMONY PENDENTE LITE AND ALIMONY 14. Paragraphs 1 through 13 of this Complaint are incorporated herein by reference as though set forth in full. 15. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 16. Plaintiff requires reasonable support to maintain herself adequately in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of alimony pendente lite until final hearing and thereafter to enter an award for alimony. COUNT IV - COUNSEL FEES AND COSTS 17. Paragraphs 1 through 16 of this Complaint are incorporated herein by reference as though set forth in full. 18. Plaintiff has retained the Law Offices of Austin F. Grogan but she is unable to pay the necessary and reasonable attorneys' fees for said counsel. 19. Plaintiff may need to hire experts to appraise the marital property but she lacks funds to pay the necessary and reasonable fees. WHEREFORE, Plaintiff requests this Honorable Court to enter an award of interim counsel fees, costs and expenses and to order such additional sums hereafter as may be deemed necessary and appropriate, and at final hearing to award such additional counsel fees, costs and expenses as are deemed necessary and appropriate. Date Respectfully su~Ttt~Lt~ Austin F. GrogS, Esg~re 24 North 32nd Street6/ Camp Hill, PA 17011 (717) 737-1956 Attorney for Plaintiff I.D. #59020 VERIFICATION I, FRANCES MARIE HEIN, verify that the statements made in the foregoing Complaint are tree and correct to the best of my knowledge, infmmation, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. Date I-I~'°Z ~~ fl/I, /~4~ FRANCES MARIE HEIN C FRANCES MARIE HEIN, Plaintiff RONALD JAMES HEIN, Defendant AND NOW, this : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-223 : ' IN DIVORCE : PRAECIPE TO DISCONTINUE /! Tff day of February 2002, the Plaintiff, Frances Hein, by and through her attorney, Austin F. Grogan, Esq., respectfully requests this Honorable Court to discontinue the Divorce action, docket number 02-223. Respectfully submitted, Austin F. E u re 24 North 32nd Stre~/ Camp Hill, PA 17011 (717) 737-1956 Attorney for Plaintiff ID #59020 PRAECIPE TO WITHDRAW APPEARANCE AND NOW, this //-F/~ day of February 2002, the undersigned attorney withdraws his appearance on behalf of the Plaintiff, Frances Marie Hein. Date Austin F. Grogan, Es~ire //] 24 North 32nd Street Camp Hill, PA 17011 "~ (717) 737-1956 Attorney for Plaintiff ID #59020 VERIFICATION I, FRANCES MARIE HEIN, verify that the statements made in the foregoing Praecipe to Discontinue are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. FRANCES MARIE HEIN O~ 0 E~ O~ 0 OZ