HomeMy WebLinkAbout05-0217
Thomas Cromer Heatwole, IN THE COURT OF COMMON PLEAS
PLAINTIFF , )
)
) CUMBERLAND COUNTY,
PENNSYLVANIA
)
v. ) CML DMSION
)
) NO. oS' - ;(J 7 Ct'uLL ~92..W\
Patricia Ann Heatwole, )
DEFENDANT )
NOTICE TO DEFEND AND CLAIM RIGHTS
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 DNORCE OR ANNULMENT MAYBE ENTERED
AGAINST YOU BY THE COURT. A WDGMENT 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 CHILD(REN).
WHEN THE GROUND FOR THE DNORCE ARE INDIGNITIES OR
IRRETRIEVABLE BREAKDOWN OF THE MARIAGE, YOU MAY REQUEST MARRIAGE
COUNSELING. A LIST OF MARRIAGE COUNSELORS IS AVAILABLE IN THE OFFICE
OF THE PROTHONOTARY IN PENNSYLVANIA.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY; DNISION OF PROPERTY,
LA WYERS FEES, OR EXPENSES BEFORE A DNORCE 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.
LAWYERS REFERRAL SERVICE
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Telephone: (717)2JJU fUT ~ S l3e.Jft,~ '5't
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Petitioner Signature
112 Victoria Drive
Mechanicsburg, Pennsylvania 17055
717-766-9450
Thomas Cromer Heatwole, IN THE COURT OF COMMON PLEAS
PLAINTIFF, )
) CUMBERLAND COUNTY,
PENNSYLVANIA
v.
)
) CML DMSION
~ NO. {)S" - ;2../7 (J 'u ~ L ~ 82-Yvl
DEFENDANT ) l
)
)
Patricia Ann Heatwole,
COMPLAINT IN DIVORCE
COMES, the Plaintiff, Thomas Cromer Heatwole, by FILING PRO SE, who files
this Complaint in Divorce a statement of which is as follow:
1.
1.
The Plaintiff is Thomas Cromer Heatwole, an adult individual
currently residing at 112 Victoria Drive Mechanicsburg, Pennsylvania 17055.
2.
2.
The Defendant is Patricia Ann Heatwole, an adult individual
currently residing at 112 Victoria Drive Mechanicsburg, Pennsylvania 17055.
3.
3.
The Plaintiff has been a bona fide resident of the Commonwealth
of Pennsylvania for at least six (6) months previous to the filing of this Complaint.
4.
4.
The Plaintiff and Respondent were married on July 29,1990, in
the State of Pennsylvania.
5.
5.
There are no children born or adopted of this marriage, and none
is expected.
6.
6.
There have been no prior actions of divorce or for annulment
between the parties.
7.
7.
Neither party is a member of any branch of military.
8.
8.
The marriage is irretrievably broken.
9.
9.
Plaintiff has been advise that counseling is available and that
Plaintiff may have the right to request that the Court require the parties to participate in
counseling.
10.
10.
The Plaintiff, Thomas Cromer Heatwole, respectfully requests that
this Court grant this Divorce pursuant to Section 3301 (c), or in the alternative, Section
3301 (d) of the Divorce Code and that a Decree of Divorce be entered.
I verify that the statements made in the Complaint are true and correct. I
understand that false statements made herein are subject to penalties of 18 Pa. C.S.A
Section 4904, relating to unsworn falsification to authorities.
Respectfully submitted,
~~~
Signature of Plaintiff
Thomas Cromer Heatwole
Dated: 1-7- 05
AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA )
)ss.
County of CUMBERLAND )
Before me, the subscriber; a Notary Public in and for said Commonwealth and
Cumberland County, personally appeared Thomas Cromer Heatwole, who, being duly
sworn according to law, deposes and says that the facts contained within the foregoing
Complaint in Divorce are true and correct to the best of his/her knowledge, information,
and belief, and that he/she is authorized to make this Affidavit.
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Si;~ture ---! ~ I
Name: ShdlcV I\I\U WlUf ~a-.
Sworn to and subsPfiPed before me this
3- day of .J a."-UlWv\ ,20 oG
Notllrial Seal 1
NOT ARY ptJ.!ftf'ilfJurr~y Moore. Notary Public
- Ciijof HarrIsburg. Dauphin County
My Commission Expires June 20. 2005
Member, Pennsylvania Association of Notanes
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PROPERTY SETTLEMENT AGREEMENT
This Property Settlement Agreement, which will be referred to as the "Agreement," is
made by Patricia Ann Heatwole and Thomas Cromer Heatwole, residents of the State of
Pennsylvania, who will be referred to as Patricia and Thomas, or as the "parties" or
"parents" in this Agreement.
INTRODUCTION: THE BASES FOR THIS AGREEMENT
The parties have decided and agree that they can no longer live together because of
irreconcilable differences; there is no reasonable likelihood that their marriage can be
preserved, and therefore, the marriage is irretrievably broken. The parties have no minor
children.
A petition for divorce has been filed in the court with family/divorce jurisdiction in
Cumberland County in the state of Pennsylvania, in the country of United States.
Both parties wish to reach a settlement concerning the issues presented by their
dissolution. This agreement sets out the process they have used to arrive at settlement
and the decisions they have reached together. Those agreements and decisions are
organized as follows:
INTRODUCTION: The Bases for This Agreement.
PETS.
DEFERRED COMPENSATION PLANS: Annuities, Pension, Retirement, Individual
Retirement Accounts (IRA's), and Profit Sharing Plans.
PERSONAL PROPERTY AND MARITAL DEBTS: Motor Vehicles, Household
Furnishings, Bank Accounts, Certificates of Deposit, Securities, Miscellaneous Financial
Assets, Pending Litigation and Tax Liabilities.
REAL PROPERTY: Family Residence and Other Real Property.
BUSINESS INTERESTS.
SPOUSAL MAINTENANCE.
ADMINISTRATIVE PROVISIONS, PROFESSIONAL FEES AND COSTS. TAX
STATUS. AND OTHER RESPONSIBILITIES UNDER THIS AGREEMENT.
The parties have reached this Agreement with the consultation of their attorneys
in order to obtain a settlement they consider fair and reasonable for themselves.
The parties stipulate and promise that they have fully disclosed to each other all
marital and non-marital property held by each of them and all other matters relevant to
their respective financial conditions. They have disclosed to and received from each
other no less than the following information or documents: their respective financial
disclosure statements, income and expenses statements. If either desired or requested
appraisals as to the value of any real property or any other asset, those documents were
provided. Both parties have had the opportunity to seek professional consultation and
advice with accountants, attorneys, or other experts deemed appropriate to make
informed decisions. Each party expressly represents to the other that they have relied
upon the full and complete disclosure of the other person in entering into this Agreement.
The parties believe this Agreement is fair and equitable, and agree to submit it to
the Court and request that the Court accepts this Agreement. They understand that the
Agreement is subject to the final approval of the Court as required by law and contingent
upon the Court entering a final Decree of Dissolution of their marriage.
Patricia and Thomas agree that the following provisions, terms, and conditions shall
be applicable and binding upon both of them in the complete settlement of the
dissolution of their marriage:
Pets
The parties have the following animals as marital property at the time of the
divorce: Rainbow Dog
The parties agree that they will split the following pet-related expenses equally.
Therefore, it has been determined that Thomas will pay 50% of the animal's expenses
listed below and Patricia will pay 50% ofthe animal's expenses listed below.
1) veterinarian expenses
2) mutually agreed upon grooming expenses
DEFERRED COMPENSATION PLANS: Annuities, Pension, Retirement, Individual
Retirement Accounts (IRA's), and Profit Sharing Plans.
The parties possess various retirement accounts, the division of which is specified below.
The parties request that the Court enter a Qualified Domestic Relations Order to divide
the following retirement accounts according to the specified wishes of the parties
represented below:
Marital, Husband's Wife's Husband's Wife's
Valne Non- Non-
Company Type Value Date NM,or Marital Marital Marital Marital
Both Portion Portion Portion Portion
Charles IRA 180,000.0001/01/05 Both 25,000.00 25,000.00 130,000.00
Schwab
Marital
Charles IRA 42,000.00 0 I/O 1/05 Non- 42.000.00
Schwab Marital
Both parties agree to transfer all right, title, and interest he/she may have in the account
being relinquished to the other and the owner of the account will indemnify and hold the
other harmless from any liability, including attorney's fees.
PERSONAL PROPERTY AND MARITAL DEBTS: Motor Vehicles, Household
Furnishings, Bank Accounts, Certificates of Deposit, Securities, Miscellaneous Financial
Assets, Pending Litigation and Tax Liabilities.
Automobiles and Other Motor Vehicles
H b d' W'~' Husband'sWife's
Year, ValueDate of Loan Net Titled in Marital/Non-Mus .:~ s M' e.: INon- Non-
Make,ModelRetailValue BalanceValuebis/hers/botbMaritallBotbp a:~ a p a:~ a Marital Marital
or IOn or IOn Portion
Mercury 7200 0 I/O 1/05
Sable
1998 Subaru 7200 0 I/O 1105
Outback
7200 His
Non-Marital 0
o
o
o
7200 Her
Non-Marital 0
o
7200
7200
For each of the vehicles assigned to the parties above, the other agrees to transfer all
right, title, and interest that they may have to the party taking possession and the party
taking possession agrees to indemnifY and hold the relinquishing party harmless from any
liability, including collection costs and attorney's fees.
Household Furnishings and Furniture
A schedule of the personal property division is attached to this Agreement. Patricia has
taken marital personal property valued at $475 and non-marital personal property valued
at $1,050. Thomas has taken marital personal property valued at $3,725 and non-marital
personal property valued at $900.
Bank Accounts and Certificates of Deposit
The parties have various bank accounts that are listed below and assigned to the parties as
follows:
Marital, Husband's Wife's Husband's Wife's
Non- Non-
Company Type Balance Date NM,or Marital Marital Marital Marital
Both Portion Portion Portion Portion
PNC Sank Say 15000 01101105 Non- 15000
Marital
PNC Sank Say 7400 01101105 Non- 7400
Marital
PNC Sank Checking 400 0]/01105 Marital 400
PNC Sank Checking 400 0110]/05 Marital 400
For each of the bank accounts assigned to the parties above, the other agrees to transfer
all right, title, and interest they may have to the party taking possession and the party
taking possession agrees to indemnify and hold the relinquishing party harmless from any
liability, including collection costs and attorney's fees.
Cash On Hand
The parties agree that whatever cash the parties have on hand at the dissolution date is to
be considered non-marital property and is to remain with the respective party.
Securities
The parties have various securities that are listed below and assigned to the parties as
follows:
Marital1 Husband's Wife's Husband's Wife's
Company Type Balance Date NM,or Marital Marital Non- Non-
Marital Marital
Both Portion Portion Portion Portion
Charles Stocks 60000 01101/05 Both 22500 22500 15000
Schwab
For each of the securities assigned to the parties above, the other agrees to transfer all
right, title, and interest they may have to the party taking possession and the party taking
possession agrees to indemnify and hold the relinquishing party harmless from any
liability, including collection costs and attorney's fees.
Cash Value Life Insurance
The parties have no cash value life insurance.
Miscellaneous Financial Assets
The parties have no miscellaneous assets that have not been addressed in other sections.
Pending Litigation: Potential Recipients of Award
The parties have no pending litigation.
Debts and Credit Card Accounts
The parties agree that there is approximately $1,500.00 in marital debts. The itemization
of those debts, the amount of each and the party responsible for payment are as follows:
Marital, Husband's Wife's Husband's Wife's
Date of Non- Non-
Creditor Type Balance Balance NM,or Marital Marital Marital Marital
Both Portion Portion Portion Portion
PNC Bank Credit 300 01/01/05 Both 300
Card
PNC Bank Credit 1200 01/01/05 Both 600 600
Card
Husband is therefore agreeing to assume responsibility for $900.00 in marital debts and
Wife assumes an amount of debt totaling $600.00.
The parties acknowledge a disparity in the amount of debt assumed and will compensate
for the disparity in assumption of debt in the totality of this Agreement.
The parties will close all joint checking, savings accounts and credit card accounts, and
open individual accounts.
For each of the debts assigned to be paid by a party or credit card account to be held by a
party, that party agrees to indemnify and hold the other party harmless from any liability,
including attorney's fees and costs.
Tax Liabilities
The parties have no tax liabilities.
Pending Litigation: Potential Pavers of Award
The parties have no pending litigation.
REAL PROPERTY: Familv Residence and Other Real Property
Familv Residence
The parties presently hold as joint tenants the family residence located 112 Victoria
Drive, Mechanicsburg, P A, the legal description of which is set out in Exhibit II attached
to this Agreement. A mortgage on the home is held by PNC Bank with a balance of
approximately $13,600. The parties agree that the value of the home is $155,000.
The disposition of the family residence will be as follows:
Thomas will purchase Patricia's interest in the family residence by paying $66,850 at
closing. At that time, Patricia will sign a quitclaim deed relinquishing all interest in the
family residence. Thomas will indemnify and hold Patricia harmless from all liability,
including attorney fees, arising from the possession of this property. The division of the
value of the house shall be as follows.
Husband's marital portion: $66,850 Wife's marital portion: $66,850 Husband's Non-
marital portion: $10,650 Wife's non-marital portion: $10,650.
In addition to the $66,850 due to Patricia, Thomas will also pay Patricia $25,750 for her
other marital portion items in this agreement. Total due Patricia at settlement is $92,600.
BUSINESS INTERESTS
The parties have no business interests.
SPOUSAL MAINTENANCE
No maintenance will be paid to or by either party.
ADMINISTRATIVE PROVISIONS, PROFESSIONAL FEES AND COSTS, TAX
STATUS AND RESPONSIBILITIES UNDER THIS AGREEMENT, CHANGE OF
NAME
Change of Name. Wife shall retain the name of Patricia Ann Myers upon the
dissolution of the marriage.
Time. Where some act is required to be performed under the terms of this
Agreement and no time is specified for its performance, it shall be done as soon as
practical.
Release. The parties mutually release each other from any and all obligations, debts,
duties, and causes of action arising out of the marriage, and out of their joint ownership
of real or personal property, except those specifically set out in this Agreement.
Execution of Documents. The parties agree to sign and execute any and all
documents and instruments required ,if any, to effectuate any of the purposes of this
Agreement.
Beneficiaries. This Agreement is binding upon and shall inure to the benefit of
heirs, executors, administrators, and assigns of the parties.
Definition of TelIDS. Any term defined in any section of this Agreement is
applicable as defined in every other section of the Agreement.
The parties agree that failure of either party to insist upon strict performances of
one or more of the terms and provisions of this Agreement shall not be construed as a
waiver or relinquishment in the future of any term or provision which shall continue in
full force and effect.
Settlement of Disagreements: Mediation
A. Mediation. The parties agree that if any disagreement should arise concerning this
Agreement that cannot be settled directly between themselves by negotiation, they will
first attempt in good faith to mediate the dispute with the services of a professional
mediator of mutual choice.
B. This section shall not be construed to abridge or deny either party from any other
remedy available at law.
Review and Modification of This Agreement
No modification or waiver of any of the terms ofthis Agreement shall be valid
unless it is in writing and executed with the same formality as this Agreement and where
necessary, approved by a Court of competent jurisdiction as required by law.
Entire Agreement. Neither party has been induced to execute this Agreement by
reason of any representation or promise by or on behalf of the other party that is not
contained in this Agreement, and both have had the opportunity to consult with legal
counsel. Neither party shall assert or claim that this Agreement or any provision is
invalid by reason of any such representation or promise. The parties have incorporated in
this Agreement their entire understanding.
Professional Fees and Costs
Court Costs. The party filing the petition shall bear the expense of any related Court
Costs.
Attornev's Fees.
Mediator's Fees.
Tax Status and Responsibilities
The parties will file jointly federal and state income tax returns for the 2004
calendar year.
The parties will equally share the mortgage interest tax deduction for the current tax
year.
Thomas will take the entire mortgage interest tax deduction each year after the
current tax year.
IN WITNESS WHEREOF, THESE PARTIES HAVE SIGNED THIS
AGREEMENT AS THEIR FREE ACT AND DEED ON THIS 12TH DAY OF
FEBRUARY, 2005.
~c.M~
, Petitioner
~"._- t;: ).1- /..7.. _, I,
, Respondent
By: Filing PRO SE
By: Filing PRO SE
Attorney for the Petitioner
Attorney for the Respondent
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Date
Date
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Schedule of Division of Household Personal Property
Value and Disposition
Item Marital/ Wife Wife Non-Husband Husband
# Items (By Room) Non-Marital iMarital Marital Marital Non-
Marital
1 Snow thrower/Lawn Mower Marital $ $125
2 Living Room - Sofa & two side chairs Marital 450
3 TV & VCR 50
4 Lamps (3) 50
5 Dining Room - Table & Two Chairs Non- 200
Marital
6 Hutch & Corner Cabinet Marital 350
7 Bedroom I Bed & Dresser & Chest 200 200
8 Bedroom 2 Bed & Dresser 100 100
9 Family Room - Sofa & Chair Non- 350
Marital
10 Entertainment Center TV Marital 1500
11 Desktop Computer & Printer Marital 1000
12 Oak Bookcases (2) Marital 150 150
13 Kneehole Desk & Chair Non- 400
Marital
14 Roll top Desk & Chair Non- 400
Marital
15 Bathroom Wicker Cabinets (2) Marital 100 100
16 Kitchen Table & Bench Marital 175
17
18
19
20
21
22
23
25
Subtotal $475
$1050
$3725
$900
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IN THE COURT OF COMMON PLEAS
Thomas Cromer Heatwole
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL DIVISION
Patricia Ann Heatwole
NO. 05 - 217
CIVIL TERM
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information to the court for entry of a divorce decree:
1. Ground for divorce:
Irretrievable breakdown under ~3301(c)
a381 (8)(1) ef II,,,, Di_vl"'" Code.
(Strike out inapplicable section).
2. Date and manner of service of the complaint: Certified Mail January 13, 2005
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by ~3301 (c) of the Divorce Code:
by plaintiff May 11, 2005 ; by defendant May 11, 2005
(b) (1) Date of execution of the affidavit required by ~3301 (d)
of the Divorce Code:
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
4.
Related claims pending:
None
5. Complete either (a) or (b).
(a) Date and manner of service of the notice of intention to file praecipe to transmit record, a
copy of which is attached:
(b) Date of plaintiff's Waiver of Notice in ~3301 (c) Divorce was filed with
the Prothonotary: M",'1 I~, ::1.01l$
Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with
the Prothonotary: M 0.." J:?" ~t'o~-
.
~ L)J~ Filing PRO SE
Attorney for Plaintiff / Defendant
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Thomas Cromer Heatwole,
PLAINTIFF,
IN THE COURT OF COMMON PLEAS
)
)
) CUMBERLAND COUNTY,
PENNSYLVANIA
)
v.
) CIVIL DIVISION
)
)
) NO. 05 - 217 Civil Term
)
Patricia Ann Heatwole,
DEFENDANT
ACCEPTANCE OF SERVICE AND ENTRY OF APPEARANCE
PLEASE take notice that I, Patricia Ann Heatwole, Defendant, was provided with
a Copy of the Notice to Defend and Claim Rights and Complaint for Divorce and do accept service of
same. I further enter my appearance in this action for all purposes.
ffi'l"'^~j Ct ) 4il"v-v4.<.....
'..711) os .-
. . Patricia Ann Heatwole
112 Victoria Drive
Mechanicsburg, Pennsylvania 17055
717-766-9450
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. Complete items 1, 2, and 3. Also oomp/ele
~em 4 if Restricted Delivery Is desired.
. Print your name and address on the reverse
so that Wll.C8l1 return the card to you.
. Attach this card to the back of the mailplece,
or on the front ~ space pennlts.
1. Article Addressed to:
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PS Form 3811, February 2004
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B. Received by (Printed Name) C. Date of Delivery
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4. Restricted Delivery? (Extra Fee) Cl Yes
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Thomas Cromer Heatwole,
PLAINTIFF,
IN THE COURT OF COMMON PLEAS
)
)
) CUMBERLAND COUNTY,
PENNSYLVANIA
)
v.
) CIVIL DIVISION
)
)
) NO. 05 - 217 Civil Term
)
Patricia Ann Heatwole,
DEFENDANT
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
January 11,2005.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety
days have elapsed from the date of filing and 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.
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(c) OF THE DIVORCE CODE
I. 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! do not claim them before a Divorce is granted.
3 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 here-in are made subject to the penalties of 18 Pa C.S. Section 4904
relating to unsworn falsification to authorities.
Date:
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Thomas Cromer Heatwole
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Thomas Cromer Heatwole,
PLAINTIFF,
IN THE COURT OF COMMON PLEAS
)
)
) CUMBERLAND COUNTY,
PENNSYL VANIA
)
v.
) CIVIL DIVISION
)
)
) NO.05-217CivilTerm
)
Patricia Ann Heatwole,
DEFENDANT
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on
January 11. 2005.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety
days have elapsed from the date of filing and Complaint.
3 1 consent to the entry of a final decree of Divorce after service of notice of
intention to request entry of the decree.
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! do not claim them before a Divorce is granted.
3 I understand that I will not be divorced until a Divorce decree is entered by the
Court and that a copy ofthe 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 here-in are made subject to the penalties of 18 Pa C.S. Section 4904
relating to unsworn falsification to authorities.
Date:
'f!:/I!CS-
, "L:<_._ C:: -~ t.J_____i~
Patricia Ann Heatwole
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE OF
Thomas Cromer Heatwole
PENNA.
No. 05-217 Civil Term
VERSUS
Patricia Ann Heatwole
DECREE IN
DIVORCE
AND NOW,
~14
I
DECREED THAT
Thnm::l!::. r.TnmP-T 'Rp.at:wole
AND
Patricia Ann Heatwole
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
z.oos, IT IS ORDERED AND
, PLAINTIFF,
, DEFENDANT,
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;
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By THE COtz;L
ATTES :
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PROTHONOTARY
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.
Thomas Cromer Heatwole,
PLAINTIFF,
IN THE COURT OF COMMON PLEAS
)
)
) CUMBERLAND COUNTY,
PENNSYLVANIA
)
v.
) CIVIL DIVISION
)
)
) NO. 05-217 Civil Term
)
Patricia Ann Heatwole,
DEFENDANT
NOTICE OF INTENTION TO RETAIN LAST NAME
Plaintiff/Defendant in the above matter, was granted a Final Decree in Divorce,
on the 19 day of May, 2005. She hereby elects to retain the last name of Myers, and gives
this written notice avowing her intention in accordance with the provisions of 54 Pa. C.S.A.
S 704.
~~ ~ '>>1'tr~-)/~
Signature
New Name: Patricia Ann Myers
\.fJ~ ~~--)
On the /),7 day of
Notary Public, personally appeared Patrici
whose name is subscribed to the within do
foregoing for the purpose therein contained.
, 20 (}.s , before me, a
nn Heatwole, known to me to be the person
ent and acknowledged that she executed the
IN WITNESS WHEREOF I have hereunto set my hand and seal.
NOTARiAl SEAL
PROTHONOTARY, NOTARY PUBLIC
CAJUSlE CUMBERLAND COUNTY COURT HOUSE
MY COMMISSION EXPIRES JANUARY 2. 2000
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