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HomeMy WebLinkAbout05-0979 Kenneth A. Wise, Esquire Attorney 1.0. No. 16142 126 Locust Street P. O. Box 11489 Harrisburg, PA 17108-1489 (717) 238-3838 Attorney for Plaintiff SUZANNE L YN HEBERLlG, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05' - q19 Cw'Ll~~ RAYMOND BERGERON, Defendant 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 of 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 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, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW, THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 or (800) 990-9108 Kenneth A. Wise, Esquire Attorney 1.0. No, 16142 126 Locust Street P. O. Box 11489 Harrisburg, PA 17108-1489 (717) 238-3838 Attorney for Plaintiff SUZANNE L YN HEBERLlG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. RAYMOND BERGERON, Defendant NO. DS' - 977 CIVIL ACTION - LAW IN DIVORCE c;u~ l Ly-82-~ COMPLAINT DIVORCE UNDER SECTION 3301 (C) OR 3301 (D) OF THE DIVORCE CODE AND NOW COMES Plaintiff, Suzanne Heberlig, by her attorney, Kenneth A. Wise, Esquire, and respectfully represents as follows: 1. Plaintiff is Suzanne Heberlig, an adult individual who resides at 53 W. Main Street, Apartment 2, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 2. Defendant is Raymond Bergeron, an adult individual who resides at 1101 N, Front Street, Apt. 2, Harrisburg, Dauphin County, Pennsylvania, 17102, 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. The Plaintiff and Defendant were married on September 28, 2002, in Clark County, Nevada. 5, There were no children born of the marriage. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling, 8. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 9. The causes of action and sections of the Divorce Code under which Plaintiff is proceeding are: Section 3301(c): The marriage of the parties is irretrievably broken. After ninety (90) days have elapsed from the date of filing this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant. Date: 71 Klo( Respectfully submitted, . . .;. ~. /11'." /it/II: . '/ 1/2;i// Kenneth NWise, Esquire Attorney I.D, No, 16142 126 Locust Street P. O. Box 11489 Harrisburg, PA 17108-1489 (717) 238-3838 Attorney for Plaintiff 2 Kenneth A. Wise, Esquire Attorney 1.0. No. 16142 126 Locust Street P. O. Box 11489 Harrisburg, PA 17108-1489 (717) 238-3838 Attorney for Plaintiff SUZANNE L YN HEBERLlG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v, NO. RAYMOND BERGERON, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT SUZANNE HEBERLlG, being duly sworn according to law, deposes and says: 1, I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3, Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S, Section 4904 relating to unsworn falsifica' n to authorities. ,,/ VERIFICATION Upon my personal knowledge or information and belief, I hereby verify that the facts averred in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief. I understand that false statements or averments therein made will subject me to the criminal penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: 1h~5 I , I verify that I have reviewed this form with my client and to the best of my knowledge the allegations herein are true and correct. / / ,? i . / / . ," ,...~/ ,', /1 .I' '.: .. I , /,." ..... ...' " '); / " . v'..,.. . I' ,.- .Iv! {/' <'-, /, /,y> 1 ./ . . r _ Kenneth A. Wise, Esquire Attorney I.D. No, 16142 126 Locust Street P, O. Box 11489 Harrisburg, PA 17108-1489 (717) 238-3838 Attorney for Plaintiff ~ -p (.) - \\- \ "9 lI{, ~ ~ ~ 0- --l 'i:L !:D \ . E .....L !J " ~ .~, .~. " .. '" D 2"l, ,'I (,1 ~.~ .. .' .< C;,-) Kenneth A. Wise, Esquire Attorney 1.0, No, 16142 126 Locust Street P, 0, Box 11489 Harrisburg, PA 17108-1489 (717) 238-3838 Attorney for Plaintiff SUZANNE L YN HEBERLlG, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v, RAYMOND BERGERON, Defendant NO. 05-979 CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO REINSTATE TO THE PROTHONOTARY: Please reinstate the Complaint in this action. Respectfully submitted, Date: J1/1/tJr , k///~ -1<enneth A. Wise, Esquire Attorney 1.0, No. 16142 126 Locust Street P, 0, Box 11489 Harrisburg, PA 17108-1489 (717) 238-3838 Attorney for Plaintiff - ~~~ sf, <;;~r-1 , N -,,-. - r-- o Kenneth A. Wise, Esquire Attorney 1.0. No. 16142 126 Locust Street P. O. Box 11489 Harrisburg, PA 17108-1489 (717) 238-3838 Attorney for Plaintiff SUZANNE L YN HEBERLlG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-979 Civil Term RAYMOND BERGERON, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 24" 2005. 2. The marriage between Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce after service of Notice of Intention to Request Entry of the Decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees and expenses if I do not claim them before a divorce is granted. 1 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. Section 4904, relating to unsworn falsification to authorities. Date II/j /()r:; I I C~I .--j I ...>~ Co_.: Kenneth A. Wise, Esquire Attorney I.D. No. 16142 126 Locust Street P. O. Box 11489 Harrisburg, PA 17108-1489 (717) 238-3838 Attorney for Plaintiff SUZANNE L YN HEBERLlG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-979 Civil Term RAYMOND BERGERON, Defendant CIVIL ACTION - LAW IN DIVORCE 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 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 understand that the statements made in this affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C. S. 94904 relating to unsworn falsification to authorities. Date: ( 11 ()1.,/ D"l 1 I I I" C') r,.) Kenneth A. Wise, Esquire Attorney I.D. No. 16142 126 Locust Street P. O. Box 11489 Harrisburg, PA 17108-1489 (717) 238-3838 Attorney for Plaintiff SUZANNE L YN HEBERLlG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-979 Civil Term RAYMOND BERGERON, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on February 24, 2005. 2. The marriage between Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce after service of Notice of Intention to Request Entry of the Decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees and expenses if I do not claim them before a divorce is granted. 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. Section 4904, relating to unsworn falsification to authorities. Date: / ; 5"/ (? .5 I ~~./~..4 .-1 - '47 /~//5~ I ,> --- Raymond Bergeron SSN: 032-54-6266 , f\LJ ",,- Kenneth A. Wise, Esquire Attorney I.D. No. 16142 126 Locust Street P. O. Box 11489 Harrisburg, PA 17108-1489 (717) 238-3838 Attorney for Plaintiff SUZANNE L YN HEBERLlG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-979 Civil Term RAYMOND BERGERON, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 Ie) 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 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 understand that the statements made in this affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C. S. 94904 relating to unsworn falsification to authorities. I ...,~ . f . ...-1 Date: /;';/z.> /) 5' ;:::~:/':J ~-.-....... , , Raymond Bergeron SSN: 032-54-6266 ,_..-, .1 .--\ \ r'-,~ I') ,\ J, !tj , Kenneth A. Wise, Esquire Attorney 1.0. No. 16142 126 Locust Street P. O. Box 11489 Harrisburg, PA 17108-1489 (717) 238-3838 Attorney for Plaintiff SUZANNE L YN HEBERLlG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-979 Civil Term RAYMOND BERGERON, Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Kenneth A. Wise, Esq., attorney for Plaintiff, certify that service of the Complaint has been effected on Defendant on the 8th day of June, 2005 in a manner authorized by Pa. R. C.P. 402(b), to wit, written acceptance of service. See Acceptance of Service and Statement of Suzanne Heberlig identifying the signature of Defendant, attached hereto. Date: S- k, cr Respegtully submitted, MIIIJ/~t4t[ Kenneth A. Wise, Esquire Attorney 1.0. No. 16142 126 Locust Street P. O. Box 11489 Harrisburg, PA 17108-1489 (717) 238-3838 Attorney for Plaintiff Kenneth A. Wise, Esquire Attorney 1.0. No. 16142 126 Locust Street P. O. Box 11489 Harrisburg, PA 17108-1489 (717) 238-3838 Attorney for Plaintiff SUZANNE L YN HEBERLlG, Plaintiff v. RAYMOND BERGERON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-979 Civil Term : CIVIL ACTION - LAW : IN DIVORCE ACCEPTANCE OF SERVICE I, Raymond Bergeron, Defendant, accept service of the Complaint in this action. Date: 6/J/CJ5 ~#~ Raymond Bergeron . Kenneth A. Wise, Esquire Attorney 1.0. No. 16142 126 Locust Street P. O. Box 11489 Harrisburg, PA 17108-1489 (717) 238-3838 Attorney for Plaintiff SUZANNE L YN HEBERLlG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-979 Civil Term RAYMOND BERGERON, Defendant CIVIL ACTION - LAW IN DIVORCE STATEMENT OF SUZANNE L YN HEBERLlG AND NOW, comes Plaintiff, Suzanne Lyn Heberlig, and subject to the penalties provided by 18 Pa. C. S. 94904 (unsworn falsification to authorities) deposes and says as follows: 1. My name is Suzanne Lyn Heberlig and I am the Plaintiff in this action. 2. I have inspected the signature on the Acceptance of Service dated June 8, 2003. 3. I am familiar with the signature of my husband, Raymond Bergeron. 4. I recognize the signature on the Acceptance of Service as being that of my husband, Raymond Bergeron. Date: /JIO,J/{)r:) f I . CERTIFICATION OF SERVICE I hereby certify that I am this day serving a true and correct copy of the foregoing Certificate of Service on the following individual by First Class U,S. Mail addressed as follows: Raymond Bergeron Hess Gas Station State & Market Street Lemoyne, PA 17043 ;)ec .' Date: s.);jw ().>' r;J;11/ , :l./I//Jc:t; . //;~/d- Kenneth A. Wise, Esquire Id. No. 16142 126 Locust Street P.O. Box 11489 Harrisburg, PA 17108-1489 (717) 238-3838 Attorney for Plaintiff ;1 r'~ '; c '-, . , Kenneth A. Wise, Esquire Attorney !.D. No. 16142 126 Locust Street P. O. Box 11489 Harrisburg, PA 17108-1489 (717) 238-3838 Attorney for Plaintiff SUZANNE L YN HEBERLlG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO, 05-979 Civil Term RAYMOND BERGERON, Defendant CIVIL ACTION - LAW IN 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: I. Ground for divorce: irretrievable breakdown under Section (XX ) 3301(c) H 3361(d)(1) of the Divorce Code. (strike out inapplicable section), 2, Date and manner of service of the Complaint: Acceptance of Service.signed June 8, 2005, 3, Complete either paragraph (a) or (b), (a) Date of execution of the Affidavit of Consent reqwred by Section 201 (c) of the Divorce Code: by Plaintiff Novemher i, ?00'i ~f11...ci Of':~.f':mheT ." ?00'i); by Defendant Novemher ?'i, ?00'i (:filf':d Oe"emhp,r?, ?OO'i, (b) (1) Date of execution of the Plaintiffs Affidavit reqwred by Section 3301(d) of the Divorce Code: N/A ; (2) date of service of the Plaintiffs Affidavit upon the Defendant: . , 4. Related claims pending: Nane. 5, Date and manner of service of the notice of intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301 (d)(l)(i) of the Divorce Code, N/A Date: /S-:5e ~t J~ ft~ Kenneth A. Wise, Esqillre Attorney for Plaintiff , ~ ") ""-.C..~' ::;. .,., (_C'_ ~3 C:1 c.) - - " r..:- 0' \ 1 \ \ \ \ . . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF I?M'{J.."Y 2-<:1, 2006 , IT IS ORDERED AND J SUZANNE LYN HEBERLIG SUZANNE LYN HEBERLIG . VERSUS RAYM:tID BERGERCN . . . . AND NOW, DECREED THAT . No, DECREE IN DIVORCE . . AND RAYM:tID BERGJ:RCN ARE DIVORCED FROM THE BONDS OF MATRIMONY. PENNA, 05-979 CIVIL . . , 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; . . . J,/4IJ{ -/J . . J. . (Q~:(~Y~~~ .-.dJp ~ 'P'?,;,~ ~It, ?rJ. L -,$ ~-? ~'~ %-,ap ~.t.-~ ~