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Home My WebLink About01-3452 MICI-IEI.I.EY. ttENDRICKS, :IN THE COURT OF COMMON PLR~R, Plaintiff : CUMBERIAND COUNTY, PENNSYLVANIA JACK L. I-IENDHICKS, : CIVIL ACTION - DIVORCE Defendant : NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BERN SUEn 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 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, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALrMONY, DMSION OF PROPERTY, LAWYER~ FE. ES OR EXPENSES BEFORE A DIVORCE OR ANNUI.~ IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF YOU SHOULr~ 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 WFIERE YOU CAN GET T.~.A.,.T, I-Pa.T .p. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 1'/013 (717) 249-3166 MICHP. f.f.P.Y. HENDRICKS, :IN THE COURT OF COMMON PLEAS, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. :NO. : JACK L. HI!~I-DI~CKS, : ~IVIL AC'rION - DIVORCe. Defendant : COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Michelle Y. Hendricks, who resides at 503 Thomas Road, Camp Hill, Pennsylvania. 2. Defendant is Jack L. Hendricks, who resides at 54 Greenmont Drive, Enola, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of this Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 6, 1988, in Snyder County, Pennsylvania 5. The parties have been living separate and apart since on or about February, 2001, a date prior to the filing of this Complaint. 6. There have been no prior actions of divorce or for annulment between the parties. ?. Neither of the parties in this action is presently a member of the Armed Forces on active duty. 8. Plaintiff and Defendant are beth citizens of the United States. 9. Plaintiff b~-~ been advised of the availability of marriage counseling and of the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff waives the right to request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued by the Court. 10. Plaintiff avers that this ground on which the action is based is that the marriage is irretrievably broken. WHER~..I~ORE, Plaintiff respectfully requests that Your Honorable Court enter a Decree of Divorce. COUNT I EQUITABI,P, DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 11. The prior paragraphs of this pleading are incorporated herein by reference thereto. 12. The parties have accumulated various items of property both real and personal during the marriage. 13. Upon information and belief Defendant bn-~ various items of premarital property that have increased in value during the marriage. 14. The parties have been unable to agree upon an appropriate distribution of the marital assets. 15. Plaintiff desires that the Court equitably divide, distribute or assign the marital property between the parties in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff respectflflly requests that Your Honorable Court enter an Order equitably distributing the marital property purs-~nt to Section 3502 of the Divorce Code. No~a,F. Blair SupYeme Court ID 45513 5440 Jonestown Road Post Office B~x 6216 Harrisburg, PA 17112-0216 (717) 541-1428 VERIFICATION I verify that the statement made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that the statements therein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. v. : NO. 01q~2 Civil Term : JACK L. ~RICI4~S, : CIVIL ACTION - DIVORCE Defendsnt : NOTICE TO DEl .ND AND CLArM RIGHTS YOU HAVE RI~IN ~ 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 proc=d without you and a decree of divorce or annulment may be entered sgainst you by the Court. A judgment may also be entered against you for any other el.irn or relief or property or other fights 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, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FrL~ A CLAm FOR A?.r~[ONY, DIVISION OF PROPERTY, L~WY~R'S ~ OR EXPENSES BEFORE A DIVORCE OR ANNULM10~T IS GRANTk~I1, YOU MAY LOSE THE HIGHT TO CLAIM ANY OF YOU SHOUT.11 TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TIilT.I~.I~I-IONE TH~ OFFICE s~r FORTH RleTOW TO FIND OUT WHERE YOU CAN GET T,~.C_xAL l-II~ .P. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 v. : NO. 01-34~ CivilTerm : JACK L. 3n~IDRI~S, : CIVIL ACTION - DIVORCE De~eDdnr~t : ADDITIONAL COUNT TO DIVORCE COMPLAINT And now comes Michelle Y. Hendricks and by and through her attorney, Nora F. Blair, Esquire files this Additional Count to Divorce Complaint and in support thereof avers as follows: 1. A Complaint under Section 3301(c) or 3301(d) of the Divorce Code was filed in the above-captioned matter on June 5, 2001. 2. Said Divorce Complaint set forth a Complaint for Divorce under Section 3301(c) or 3301(d) of the Divorce Code and a claim for equitable distribution. 3. Plaintiff now desires to file an additional count to the Divorce Complaint. COUNT ALTMONY PENDI~.~I'E T.1TE UNDI~.R SECTION 3'/02 OF THE DIVORCE CODE 4. The prior paragraphs of this pleading and of the Complaint in Divorce are incorporated herein by reference thereto. 5. Plaintiff is unable to sustain herself during the course of litigation. 6. Plaintiff lacks sufficient property to provide for her reasonable needs and is unable sustain herself through appropriate employment. 7. Defendant has sufficient resources available to sustain himself, pay his counsel fees, costs and expenses and provide assistance to Plaintiff for her support. 8. Defendant is in a better position to provide for Plaintiff than Plaintiff can provide for herself. 9. Plaintiff desires that the Court enter an award of Alimony Pendente Lite after considering all relevant factors. WHE1~E'~O]~.~ Plaintiff respectfully requests that Your Honorable Court enter an award of Alimony Pendente Lite until final hearing. Respee~lly submitted, DA"~D: lc, - I0 .' ~, ~ ~ Supreme Court ID #45513 5440 Jonestown Road Post Office B~x 6216 Harrisburg, PA 17112-0216 (717) 541-1428 v. :NO. 01-0452 ~ ~ : JACKI~ I-mND~, : CIVIL ACTION - DIVORCE Defendant : CERTIFICATE OF SERVICE I hereby certify that I have this date served a copy of the Additional Count to Divorce Complaint on the person in the manner stated below which service satisfies the requirement of Pa.R.C.P. No. 440. SERVICE BY FIRST CLASS MAIL TO: Jack L. Hendricks 54 Greenmont Drive Enola, Pennsylvania 17025 Date: October 10, 2001 Respectfully submitted, MICI-m. TJ.~. y. J~NDRI~, : IN TIlE COURT OF COMMON pr ~ai~ : ~ ~, ~V~ : v. : NO. 01~ ~ ~ : ~ ~ ~~, : ~ A~ON- D~O~ WAIVER OF NOTICE OF INTE~ON TO REQUEST EN'rRY OF A DIVORCE DECREE UNDER SEC'rlON 3301(c) OF ~ 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 Decree of Divorce 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 unsworn falsification to authorities. MICI-I~.I.~.Y.I~I~IDRICI~S, :IN TIIE COUt~ OF COMMON PLEAS, PlaintiR : CUMBERI.~ID COUNTY, PENNSYLVANIA : v. : NO. 01-11452 CILVIL TERM : JACK L. FIRNDRICKS, : CIVIL ACTION - DIVORCE Defendant : AFFIDAVIT OF SERVICE I, Nora F. Blair, Esquire, hereby certify that a true and correct copy of the Complaint in Divorce was served on the Defendant by certified mail, restricted delivery, return receipt requested, on June 9, 2001, addressed as follows: Jack L. Hendricks 54 Greenmont Drive Enola, Pennsylvania 17625 The return receipt card is attached hereto marked Exhibit 'A' and incorporated herein by reference. DATED:,/? t ! ~.~~"~-"'- Supreme Court ID 45513 5440 Jonestown Road Post Office Box 6216 Harrisburg, PA 17112-0216 (71'/) 541-1428 · '-----.m ue~my I~ ~lred. · Print Y°ur name and address on ihe reverae s° ~hat we can tatum the card to you. C. · AttL~n th/s card to the back of t/~ m~/ll~iece, ~. °r °n ~e f~'om if splice l~m~il~. to: :lfr~mt ~mm i~m ~? MICI-IP. LI.~".Y. I41O~DRICKS, :IN THE COURT OP COMMON PIJ~.~, Pl~iutiff : CUMBERLAND COUNTY, PENNSYLVANIA JACK L. I-I]~IDI~CKS, : CIVIL ACTION - DIVORCP. Defendant : PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter my appearance as attorney for the Plaintiff in the above- captioned case. Respecu~'~lly submitted, 5440 Jonestown Road P~t Office ~ 6216 Harrisburg, PA 17112-0216 (?17) 541-1428 v. : NO. 01-3452 CIVIL ~ : JACK L. 7-Tk~DRICKS, : CIVIL ACTION- DIVORCE Defend ~,fl/P, espondent : PETITION FOR APL CONFERENCE AND NOW comes Michelle Y. Hendr/cks, by and through her attorney, Nora F. Blair, Esquire, files this Petition for APL Conference and in support thereof avers as follows: 1. Petitioner is Michelle Y. Hendricks who resides at 503 Thomas Road, Camp Hi]I, Pennsylvania 17011. 2. Respondent is Jack L. Hendricks who resides at 54 Greenmont Drive, Enola, Pennsylvania 17025. 3. Petitioner and Respondent were married on May 6, 1999. 4. Petitioner and Respondent are the parents of two minor children: Kati Hendricks, December 24, 1991; and Derek Hendricks, September 17, 1996. 5. The parties separated on or about February, 2001. 6. A Comp],h~t Under Section 3301(c) or 3301 (d) of the Divorce Code was filed on June 5, 2001. ?. A claim for Alimony Pendente Lite (APL) was filed in the divorce action simultaneously with the filing of this Petition. 8. A DHS Attachment for APL Proceedings is being filed simultaneously with the filing of this Petition. w~:xs:~l~E, Petitioner respect~ requests that a conference be scheduled and held at the Domestic Relations Section to address Petitioner's claim for Alimony Pendente Lite. Respectfu.~ submitted, DATED: [ Sup~me Cou~ ~ 4551~ ~0 Jon~ ~d Post ~ ~ 6216 ~sburg, PA 17112-0216 (~1~) ~1-1428 v. : NO. 014~52 CIVILTEHM : JACKT, I4~gDI{ICKS, : CIVIL ACTION - DIVORCE Defendant : CERTIFICATE OF SERVICE I hereby certify that I have this date served a copy of the Petition for APL Conference on the person in the manner stated below which service satisfies the requirement of Pa.tLC.P. No. 440. SERVICE BY FIRST CLASS M~TT. TO: Jack L. Hendricks 54 Greenmont Drive Enola, Pennsylvania 17025 Date: October 10, 2001 Respectfully submitted, lq'o~t~ F. Blah' v. : NO. 01-34~2 CivilTerm : JACKI~ I~O/DRICKS, : CIVIL ACTION - DIVORCE Defeod~t/Respondent : DRS A'I ACH1WENT FOR APL PROCEEDINGS AND NOW comes Michelle Y. Hendricks, by and through her attorney, Nora F. Blair, Esquire, files this DRS Attachment for APL Proceedings and presents the following: PETI'I ONER: NAME Michelle Y. ~endricks 'ADDRESS 503 Thomas Road Camp Hill, Pon--~,lwniR 17011 BIRTH DATE Nowmher 9, 1967 SOCIAL SECURri'¥ NUMBER 169-64-2936 HOME PHONE (717) 303-2064 WORK PHONE (717) 221-2948 EMPLOYER NAME WlTF, IllC. EMPLOYER ADDRESS 1982 Locust Lane l-l~wisbur~, PA 17109 JOB '£1T~,~POSITION Director of Steward.~hip Activities DATE EMPLOYMENT BEGAN 1999 GROSS PAY 100.00 N ~,'1' PAY ~ INCOME A'I~rORNEY'S NAME Nora F. A~ORNE~S ADDRESS 5440 Jonestown Road PO Box 6216 PA 1712-0216 NUM~R 541-1428 NAME Jack L. Hpnrl~icks ADDRESS 54 Greenmont Drive BIRTH DATE June 24, 1964 SOCIAL SECUlhT¥ NUMBER 161-52-3388 HOME PHONE (717) 732-686 WORK PHONE (717) 972-3450 EMPLOYER NAME Footlocker EMPLOYER ADDRESS , Road PA 17055 JOB 'l'rr J .?~POSITION DATE E1ViPLO~NT BEGAN GROSS PAY 000.00+ N~.'T PAY ?? O'rPl ~:1~ INCOME ATTORNEYS NAME ?? ATI~ORNE~S ADDRESS ? ? PHONE NUMBER .. MARRIAGE INFORMATION: DATE OF MARRIAGE May 6, 1988 PLACE OF MARRIAGE Sn},der Count~,, Penns~,lvania DATE OF ~:i'ARATION February,, 2001 ADDRESS OF LAST MARITAL 54 Greenmont Drive HOME E~nla. PA 17025 DESCRIPTION OF DOCUMENT Additional Count ot Divorce RAISING APL CLAIM Complaint DATE APL DOCUMENT FTT,I~.n October 10, 2001 Respee~ submit~:l, DATED: [ ~ ~ ! O- ~/ .F. Blair Supreme Court ID 45513 5440 Jonestown Road Post Office Box 6216 Harrisburg, PA 17112-0216 (717) 541-1428 Plaintiff : CUMBEP, J_,AND COUI~i~, PgNNSYLVANIA v. : NO. 01-3452 Civil Term JACK L. I-rENDRICKS, : CIVIL ACTION- DIVORCE CERTIFICATE OF SERVICE I hereby certil~ that I have this date served a copy of the DRS Attachment for/kilL Proceedings on the person in the manner stated below which service satisfies the requirement of Pa.R.C.P. No. 440. SERVICE BY FIRST CLASS MAIL TO: Jack L. Hendricks 54 Greenmont Drive Enola, Pennsylvania 17025 Date: October 10, 2001 Respectfully submitted, MIiH4w.T.~.Y.I-r~NDRICKS, :IN THE COURT OF COMMON I~.~AS, pl~iut~l~ : CUMB~ COUNTY, PENNSYLVANIA : v. : NO. 01-3452 Civil Term : JACKL. I-Ila:NDRICK~ : CIVIL ACTION - DIVORCE Defe~dn~t : PBAECIPE TO TRANSMIT RECORD UNDg:R § 3301(c) OF ~ DIVORCE CODE 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: (a) Date of service: June 9, 2001. CO) Manner of service: Certified Mail, Restricted Delivery, Return Receipt Requested 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: (a) By the Plaintiff: July 11, 2003 Co) By the Defendant: June 16, 2003 4. Date of execution of Waiver of Notice of Intention to File Praecipe to Transmit Record: (a) By the Plaintiff: July 11, 2003 Co) By the Defendant: June 16, 2003 5. Related claims pending: NONE · . ~..~.~. DA'I~D: July' ~4, 20011 ./..~_~~ ~ NOra F. Blair, E-qquire Attome7 for Plaintiff iN THE COURT Of COMMON PLEAS OFCUMBERLANDCOUNTY STATE Of . PENNA. :MIC~r-TI~.T ,T .'~. y. HF, NDRICKS N O. 01-3452 Civil Term Plaintiff VERSUS JACK L. HENDRICKS Defendant DECREE IN DIVORCE AND NOW, ~Z,. ,,~" (e" . ~oo~ , It IS ORDERED AND DECREED ThAt M~I~.T.T,]~. ~ ~Tl~.}~Tl~]:[T~.~.~ , PLAI NTI ff, JACK L. ]~ ~: ~DRICKS AND , 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; BY The COURT: PROTHONOTARY