HomeMy WebLinkAbout02-0490DAVID C. HECK,
RENEE E. HECK,
· IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v. : NO. E~- a/c?f.~ CIVIL TERM
: IN DIVORCE
Defendant :
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 LEGAL HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LnlERTY AVENUE
CARIJ,ql,E, PENNSYLVANIA 17013
(717) 249-3166
DAVID C. HECK,
RENEE E. HECK,
Plaimiff
V.
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.Oa ~ ,t/~ CIVIL TERM
:
: IN DIVORCE
:
COMPLAINT
1. The Plaintiff is David C. Heck, who currently resides at 110 November Drive, Apt.
5, Camp Hill, Cumberland County, Pennsylvania.
2. The Defev~lant is Renee E. Heck, who currently resides at 1203 Kings Circle,
Mechanicsburg, Cumberland County, Pennsylvania.
3. Plaimiff 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 September 11, 1989 in Hawaii.
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(¢) and 3301(d), in that:
a)
b)
2001 and continue to do so.
The marriage is irretrievably broken.
Plaintiff and Defendant have lived separate and apart since Febnlary
8. The Haintiff has been advised that counseling is available and that Plaimiff may
have the right to request that the court require the parties to participate in counseling.
9. Defe,dant is not a member of the armed services.
WI-W, REFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce.
COUNT H - EQUITAB!.E DISTRmUT~ON
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 September 11, 1989 until Febr~,ary 2001, 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
ha.~ increased in value during the marriage, all of which property is 'marital property'.
13. Plaintiff and Defer~dant have agreed to a preliminary equitable division of said
property prior to the filing of this Complaint.
WIW, REFORE, Plaintiff requests this Honorable Court to equitably divide all marital
property.
Respectfully submitted,
~(ustin F. G~o~gan~uire
24 North 32nd ~re~, Camp Hill, PA 17011
(717) 737-1956~-~
Attorney for Plaintiff
I.D. ~9020
VERIFICATION
I, DAVID C. HECK, verify that the statements made in the foregoing Complaint are tree 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.
DAVID C. HECK
C
Ir.
0
0
DAVID C. HECK,
RENEE E. HECK,
Plaintiff
V.
Defendant
· IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 02-490 CIVIL TERM
:
: IN DIVORCE
,2002, by and
between DAVID C. HECK, hereinafter referred to as "Husband", and RENEE E. HECK,
hereinafter referred to as "Wife".
WITNESSETH:
WHEREAS, the parties hereto are Husband and Wife, having been married on
September 11, 1989; and
WHEREAS, differences have arisen between Husband and Wife, as a result of which it
is the desire of the parties after long and careful consideration, amicably to adjust, compromise
and settle all property rights and all rights in, to, or against each other's property or estate,
including property heretofore or subsequently acquired by either party, and to settle all
disputes existing between them, including any and all claims for maintenance, support,
alimony, equitable distribution, counsel fees, and costs; and
WHEREAS, it is the mutual desire of Husband and Wife to reduce their agreement to
writing; and
NOW, THEREFORE, in consideration of the mutual promises, covenants, and
agreements hereinafter contained, each of the parties hereto, intending to be legally bound
hereby promises, covenants, and agrees as follows:
1.
PARTIES TO LIVE SEPARATE AND APART
The parties mutually agree to live separate and apart. Neither party will molest the
other, or in any way harass or malign the other, nor in any way interfere with the peaceful
existence of the other.
2.
PERSONAL PROPERTY
Husband and Wife have exchanged a list of items that Husband will remove from the
parties home and a list of items that Husband will be permitted to store at the home to include
the lawn equipment. Furtheimore, the parties agree that should the Wife sell the house, move
out of thc house or if the children no longer reside with the Wife then the children's bedroom
furniture will go to the Husband. Otherwise, Husband and Wife have divided all personal
property, which would constitute marital property. Wife agrees that any property in the
possession and control of Husband shall be the sole and separate property of Husband.
Husband agrees that all property in the possession and control of Wife shall be the sole and
separate property of Wife. Each of the parties does hereby specifically waive, release,
renounce and forever abandon whatever claims, if any, he or she may have to the sole and
separate property of the other.
0
MARITAL DEBTS
The parties acknowledge that they have a mortgage on the marital home located at 1203
Kings Circle, Mechanicsburg, Pennsylvania, with a payoff value of approximately
$199,000.00. Fur~ermor¢, thc parties acknowledge that the Wife will be responsible for
refinancing thc mortgage and assuming the primary mortgage to the marital home.
Husband and Wife each covenant, represent, and agree that each other will now and at
all times hereafter save harmless and keep the other indemnified from all debts, charges, and
liabilities incurred by the other prior to or after the effective date of this Agrcemem, except as
may be otherwise specifically provided for the by the terms of this Agreement.
4.
REAL PROPERTY
Husband and Wife agree that they are the fee simple owners of the marital residence
located at 1203 Kings Circle, Mechanicsburg, Pennsylvania, which real estate has a currem
value of $300,000.00, which constitutes marital property. The parties agree that said property
shall be the sole and separate property of Wife. The parties agree that husband shall waive all
his rights, title and interest in the home and shall sign a deed transferring said rights to Wife
simultaneously with the execution of this Marriage Settlemem Agreement. Said deed shall be
held in escrow by counsel for Husband and released to the settlement agent contemporaneously
with Wife's settlement for refinancing of the mortgage obligations as set forth in paragraph 3
of this Agreement.
Husband and Wife are also the fee simple owners of two timeshares. One timeshare is
designated as the Ridge Tahoe (hereinafter "the Ridge") and is available for one week in odd
years. The second timeshare is designated as the Tahoe Beach and Ski timeshare (hereinafter
"the Beach") and is available for one week in even years. The parties agree that they shall
continue to maintain joint ownership of both timeshares with rights of survivorship. The
parties agree that they will alternate their use in the timeshares, with Husband having the right
to use "the Beach" in year 2002 and "the Ridge" in year 2003. Wife shall have the right to
use "the Beach" in year 2004 and "the Ridge" in year 2005. The parties shall alternate the
actual right of use on successive two year periods. The parties each agree that they shall share
all costs and maintenance fees associated with both timeshares on an annual basis. All invoices
and billing information shall be mailed to Wife and Wife shall have the duty of keeping the
timeshare advised of her current address. Husband agrees to pay to Wife one-half (1/2) of all
sums billed within twenty (20) days of Wife's presentment of the invoice to Husband. Wife
shall then remit a single check to the respective timeshare to cover the obligations. In the
event that either party will not be using the timeshare in their designated year they will have
the discretion to allow a family member use of the property. This will not interrupt the
scheduled rotation except by mutual agreement of the parties in writing prior to the exchange.
Any compensation received from a third party will be the sole property of the party forfeiting
his or her scheduled week of use. Furthermore, the parties agree that without mutual consent
of both parties, neither party will sell the timeshares in the next five years. Thereafter, the
party desiring to sell their share agrees to give the other party a period of six months to
exercise the option to purchase.
5.
CHILD SUPPORT AND ALIMONY
Husband acknowledges that the Wife will be the custodial parent of the parties' minor
children and that the Husband will pay child support in the amount of $1,400.00 per month and
alimony of $1,000.00 per month. The parties agree that the Child support will be fixed for the
first thirty-six (36) months. Furthermore, the parties agree that the Child Support shall be
modifiable if the Husband becomes unemployed or his income decreases by at least 15%, the
Wife sells the house within the thirty-six (36) months, or the Wife remarries or cohabitates
with another individual in an intimate relationship. Following the fxrst thirty six (36) month
period of Child Support, the alimony payments will be calculated, as income for child support
purposes should either party petition the court for a review.
The parties agree that the Alimony will be fixed and is payable for Sixty (60) months
commencing the month following the divorce. Furthermore, the parties agree that the alimony
shall be modifiable if the Husband becomes unemployed or his income decreases by at least
15%. The alimony shall terminate upon the following conditions: death of the Wife, death of
the Husband, the Wife remarries or cohabitates with another individual in an intimate
relationship. The parties acknowledge that the alimony be paid to the Wife as taxable income
for the Wife and taxable income deduction for the Husband in the amount of $1,000.00 per
month for a period of sixty 60 months commencing the f~rst month following the divorce.
In addition, the Husband agrees to pay 75 % of the non-reimbursed medical expenses
after Wife has satisfied the initial $250.00 per child annual deductible. The parties agree that
daycare expenses shall be divided between the parties on the same percentage for the first 12
months. Following that 12 month period the non-reimbursed medical expenses and childcare
will be based on the earnings or earning capacity of the parties.
6.
CUSTODY
The parties acknowledge that they are the parents of two children, Andrew Heck and
Samuel Heck, and that the Wife will be the custodial parent of the children. The parties shall
enjoy shared legal custody of the children with Wife having primary custody. The Husband
shall have unlimited partial custody as the parties may agree. Further'more, the parties desire
that the children will attend the Cumberland Valley School District and the Wife shall consult
Husband or obtain the Court's permission to move the children out of the Cumberland Valley
School District.
Furthe~-~xlore, Husband will claim Samuel Heck as his dependent for IRS purposes
beginning in the year 2002. The Wife will claim Andrew Heck as her dependent for IRS
purposes. If either party determines that he or she does not need the tax write-off during a tax
year, the other party shall have the right to claim that child as a tax deduction. Said party shall
advise the other by April 1 of the following year as to whether or not he or she will be using
the child as a dependent for IRS purposes.
7.
LIFE INSURANCE
Husband and Wife agree to maintain a minimum of $250,000.00 of life insurance and
hereby elect the children as the beneficiaries of each of the life insurance policies until they are
21 years of age. Parties agree that they will, on an annual basis, exchange paid premiums to
show that the life insurance is in full force and effect.
8.
I~vrEP~Sr m RETIREMENT~ IRA AND 401(K)
Husband and Wife acknowledge they are owners of the following accounts, which
constitute marital property of IRA's and 401(k)'s:
1. David Heck's IRA, account number 9889172710, valued as of September 30, 2001
at $74,500.00;
2. Vanguard 401(k), account number 092497, valued as of September 30, 2001 at
$90,000.00;
3. Renee Heck's IRA, Scudder Investment, account number 7EE-326320, valued as of
October 26, 2001 at $70,800.00;
Each party acknowledges that they have a marital interest in the individual IRA's and
401(k)'s and hereby waives any interest and will execute any documents necessary to remove
their respective names as beneficiaries of the IRA and 401(k) accounts.
9.
MONEY MARKET SAVINGS ACCOUNT
Parties acknowledge they are the owners of a Vanguard Prime money market account,
account number 9930072659, with a current value of $58,000.00, which will be assigned to
the Wife.
10.
VEHICLES
The parties acknowledge that they are the owners of a 1994 Nissan Quest and a 1995
Toyota Corolla. The 1994 Nissan Quest is awarded to Wife and the 1995 Toyota Corolla is
awarded to Husband. Each party waives any interest in the other parties' vehicle.
11.
LEGAL REPRESENTATION
Husband and Wife declare that each has had a full and fair opportunity to obtain and
consult with legal counsel of his/her selection and that the parties, cognizant of their legal
rights, declare and express that:
A) Austin F. Grogan, Esquire, represents Husband, David C. Heck; and
B) Barbara Sumple Sullivan, Esquire, represents Wife, Renee Heck.
12.
MUTUAL DISCHARGE
Except as otherwise expressly provided by this Agreement:
A) Each party hereby absolutely and unconditionally releases and forever
discharges the other and the estate of the other for all purposes from any and all rights and
obligations, which either may have or at any time hereafter have for past, presem or future
support or maintenance, alimony pendente lite, alimony, equitable distribution, counsel fees,
costs, expenses and any other right or obligation, economic or otherwise, whether arising out
of the marital relationship or otherwise, including all rights and benefits under the
Pennsylvania Divorce Code of 1980, it supplements and amendmems, as well as under any
other law of any other jurisdiction, except and only except all rights, agreements and
obligations of whatsoever nature arising or which may arise under this Agreement or for the
breach of any provision thereof. Neither party shall have any obligation to the other not
expressly set forth herein.
B) Each party hereby absolutely and unconditionally releases and forever
discharges the other and his or her heirs, executors, administrators, assigns, property and
estate from any and all rights, claims, demands or obligations arising our of or by virtue of the
marital relationship or the parties or otherwise, whether now existing or hereafter arising. The
above release shall be effective regardless of whether such claims arise out of any former or
future acts, contracts, engagements or liabilities or the other or by way of dower, curtesy,
widow's rights, family exemption or similar allowance, or under the intestate laws, or the right
to take against the spouse's will, or the right to treat a lifetime conveyance by the other as
testamentary or all other rights of a surviving spouse to participate in a deceased spouse's
estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory
or the United States, or any other country. It is expressly understood, however, that neither
the provisions of this release nor the subsequent entry of a divorce decree are intended to
defeat the right of either party to receive any insurance proceeds at the death of the other of
which she or he is the named beneficiary (whether the beneficiary designation was made prior
or subsequent to execution hereof), nor to defeat the right of either party to receive any legacy,
bequest or residuary portion of the other's estate under his or her will, or to act as personal
representative or executor if so names by the will of the other, whether such will was executed
prior or subsequent to this Agreement.
C) Except for any cause of action for divorce which either party may have or claim
to have, and except for the obligations of the parties contained in this Agreement and such
rights as are expressly reserved herein, each party gives to the other by the execution of this
Agreement an absolute and unconditional release and discharge from all causes of action,
claims, rights or demands whatsoever, in law or in equity, which either party ever had or now
has against the other.
3.0
13.
NO-FAULT DIVORCE
An action for Divorce has been instituted by the Husband in the Court of Common
Pleas of Cumberland County, Pennsylvania, docketed to No. 02-490 Civil Term, alleging that
the marriage is irretrievably broken and requesting a no-fault divorce under Section 3301(c) of
the Divorce Code.
It is hereby agreed that the marriage is irretrievably broken and that coincident to the
signing of this Agreement, both parties will execute affidavits of consent to the entry of a
Decree in Divorce under Section 3301(c) of the Divorce Code.
14.
EXECUTION AND DELIVERY OF DOCUMENTS
The parties hereto agree to execute and deliver all papers needed to effectuate the terms
and intentions of this Agreement.
15.
BREACHING PARTY Pars CosTs
If either party breaches any provisions of this Agreement, the other party shall have the
right, at his or her election, either to sue for specific perfmmance or for damages for such
breach, and the party breaching this Agreement shall be responsible for reasonable legal fees
and costs incurred by the other in enforcing his or her rights under this Agreement.
11
16.
~JENERAL PROVISIONS
This Agreement encompasses all agreements between the parties concerning the matters
set forth herein and may not be altered or omitted except in writing executed by the parties; the
waiver of any term, condition or provision of this Agreement shall in no way be deemed a
waiver of any other term, conditions or provisions of this Agreement.
If any term, condition or provision of this Agreement shall be determined to be void or
invalid in law or otherwise, then only that term, condition or provision shall be stricken from
this Agreement, and in all other respects, this Agreement shall be valid and continue in full
force.
It is agreed by and between the parties hereto that this Agreement shall survive and
shall not be merged into any decree, judgment, or order of divorce or separation. It is
specifically agreed, however, that a copy of this Agreement or the substance of the provisions
thereof, may be incorporated, by reference, into any divorce, judgment, or decree. This
incorporation, however, shall not be regarded as a merger, it being the specific intent of the
parties to permit this Agreement to survive any judgment and to be forever binding and
conclusive upon the parties.
This Agreement shall be construed under the laws of the Commonwealth of
Pennsylvania.
This Agreement is executed in triplicate, and Husband and Wife, as parties hereto,
12
acknowledge the receipt of a duly executed copy hereof.
IN WITNESS WHEREOF, the parties hereto have set their hands and seals the date
first above written.
WITNESS:
RENEE E. HECK, Defendant
13
COMMONWEALTH OF PENNSYLVANIA :
:
COUNTY OF CUMBERLAND :
SS
On this, the /~ ¢~/day of ~ ,2002, before
me,
the
undersigned
officer, personally appeared DAVID C. HECK, known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within Agreement, and acknowledged that he
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my hand and notaries seal.
~ Rhonda D. Rudy. Notary Public
· ?~p Ell! B?ro, Cumberland Co~Jnty
My t~omm~ss~on Expires Aug. 12, 2002
~:,,~h~,r Pennsy~vanh Associallonof Notaries
COMMONWEALTH OF PENNSYLVANIA :
: SS
COUNTY OF CUMBERLAND :
On this' the/~fr~day°f ~~~__ , 2002, before me, the undersigned
officer, personally appeared RENEE E. HECK, known to me (or satisfactorily proven) to be
the person whose name is subscribed to the within Agreement, and acknowledged that she
executed the same for the purposes therein contained.~
IN WITNESS WHEREOF, Ihave hereuntp~e~ ~y h~d not~ries seal.
NOTARY
DAVID C. HECK,
RENEE E. HECK,
Plaintiff
V.
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 02-490 CIVIL TERM
:
: IN DIVORCE
.
AFFIDAVIT OF ACCEPTANCE OF SERVICE
I, RENEE E. HECK, Defendant in the above-captioned action in Divorce, hereby
acknowledge that I have in fact received a copy of the Complaint for Divorce in this matter on
the /3"7~ay of February, 2002 at /O,'OD I~M.
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 umworn
falsification to authorities.
Date /o?dS/d)o~.
REN~EE E. HECK
DAVID C. HECK,
RENEE E. HECK,
Plaintiff
V.
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 02-490 CIVIL TERM
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Di¥orce Code was filed on
January 28, 2002.
2. The marriage of Plaintiff and Defendant is ~rretrlevably broken and ninety days
have elapsed from the date of filing and service of the Complaint.
3. 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.
Date
RENEE E. HECK
DAVID C. HECK,
RENEE E. HECK,
Plaintiff
V.
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 02-490 CIVIL TERM
:
: IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the D~orce Code was filed on
January 28, 2002.
2. The marriage of Plaintiff and Defendant is ~rretrlevablyI broken and ninety days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a f'mal 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 tree and c6rrect. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. § ~904 relating to unswom
falsification to authorities.
DAVID C. HECK
DAVID C. HECK,
RENEE E. HECK,
Plaintiff :
:
v. : NO. 02-490 CIVIL TERM
:
: IN DIVORCE
Defendant :
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(e) OF THE DIVORCE COD!
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
1. I consem to the entry of a fmal decree of divorce x fithout notice.
2. I understand that I may lose rights concemkg alimony, division of
property, lawyer's fees or expenses if I do not claim them before a divor~ :e is granted.
3. I understand that I will not be divorced until a div >rce decree is entered by
the Court and that a copy of the decree will be sent to me immediately after it is fried with the
Prothonotary.
I verify that the statements made in this affidavit ar~ 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. '
Date: ~ ~/a°'~2.- ~~.~/~~
DAVID C. HECK '~
DAVID C. HECK,
RENEE E. HECK,
Plaintiff :
:
v. : NO. 02-490
:
: IN DIVORCE
Defendant :
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL TERM
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) 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 if I do not claim them before a divorbe is granted.
3. I understand that I will not be divorced until a divbrce 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 a~e 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.
Date:
Rl~NEE E. HECK
DAVID C. HECK,
Plaintiff
VS
RENEE E. HECK,
Defendant
IN THE COURT OF COMMON PLEAS
YORK COUNTY, PENNSYLVANIA
NO. 02-490 CIVIL ACTION
CIVIL ACTION - LAW
DIVORCE
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. Grounds for divorce: irretrievable breakdown under § 3301(c) 330 Divorce Code.
Date and manner of service of the complaim:
By personal service February 15, 2002
3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce
Code: by Plaintiff June 18, 2002 by Defendant June 18, 2002
4. Related claims pending: All claims raised resolved in Marriage Settlement
Agreement dated 10 June 2002
5. Date Plaintiff's Waiver of Notice in § 3301(c) Divorce was filed with the
Prothonotary: June 21, 2002
Date Defendant's Waiver of Notice in § 3301(c) Divorce was fried with the
Prothonotary: June 21, 2002
Date: July 1, 2002 ~ ~
Austin F. Grogan, Es~u~/e
Attorney for Plaintiff ~'
24 North 32nd Street
Camp Hill, PA 17011
(717) 73%1956
Id # 59020
IN THE COURT OF COMMON PLEAS
Of CUMBERLAND COUNTY
STATE Of ..~. PENNA.
Plain~£ff
VERSUS
Defendant
RENEE E.
N o. ~9_~q~ ~TVTT. ~T!ON
Decree IN
DIVORCE
AND NOW,~
DECREED THAT DAV-TD C. HECK
,~~, IT IS ORDERED AND
, PLAINTIFF,
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;