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Home My WebLink About05-1616 JAMES F. HETRICK, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LA W 1, I {p 2005 - {P CIVIL TERM DAWN M. HETRICK, Defendant IN DIVORCE NOTICE 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 in 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 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 17013. 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 HA VE 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. JAMES F. HETRICK, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2005 - CIVIL TERM DAWN M. HETRICK, Defendant IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c) OF THE DIVORCE CODE NOW comes the Plaintiff, James F. Hetrick, Jr., by his attorney, Marcus A. McKnight, III, Esquire, and files this Complaint in Divorce against Defendant, Dawn M. Hetrick, representing as follows; 1. The Plaintiff is James F. Hetrick, Jr., an adult individual residing at 1874 George Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Dawn M. Hetrick, an adult individual residing at 2619 Valley Road, Marysville, Pennsylvania 17053. 3. The Plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The Plaintiff and the Defendant were married on September 26, 1996, in Hershey, Pennsylvania and separated on June 20, 2000. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff and Defendant have one child born to this marriage, namely Michaela M. Hetrick, born December 2, 1997. 7. Pursuant to the Divorce Code, Section 3301(c), the Plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 8. The Plaintiff avers that he has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the Plaintiff demands judgment dissolving the marriage between the two parties. Respectfully submitted, By: Marc s A. Me i , Esq. Attorney for Plat tiff 60 West Pomfret eet Carlisle, Pennsylvania 17013-3222 (717) 249-2353 Supreme Court LD. No. 25476 Date: March 25, 2005 JAMES F. HETRICK, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LA W 2005 - CIVIL TERM DAWN M. HETRICK, Defendant IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDA VIT The plaintiff, 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: March 25, 2005 VERIFICATION The foregoing document is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: March 25, 2005 1l~ ~~ ~,~ () ,\ ~ (j.., ~ ~ ~ ~" \... . ~ ~\~ l ......... ~. ~ \..J '-.J ~ I:J\;. \.j ~, )J ~ ~ , ~ ~i:i" ~ 3 ~ r11 p1 -Orn :~)'y C~) (.!-~ =:i~~~~l f'-' ,-::' en ::;~ W :0 (..J -<. JAMES F. HETRICK, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2005-1616 CIVIL TERM DAWNM. HETRICK, Defendant IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(I)(i) COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF CUMBERLAND NOW, Marcus A. McKnight, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the captioned action in divorce. 2. That a certified copy of the Complaint in Divorce was served upon the defendant, Dawn M. Hetrick, on April 4, 2005, by certified, restricted delivery mail, addressed to her at 2619 Valley Road, Marysville, Pennsylvania 17053, with Return Receipt Number 7003 3110 0004 5770 5568. 3. That the said receipt for certified mail is signed and attached hereto and made a part hereof. I verify that the statements made in this affidavit are false statements herein made are subject to the penalties 0 unsworn falsification to authorities. e and correct. I understand that P . S. ection 4904, relating to T, III, ESQUIRE Date: April 6, 2005 U.S. Postal Service, CERTIFIED MAIL, RECEIPT -(Domestic Mail Only; No Ins'lK.ance Coverage Provided) "" ..II U'l U'l CJ r- r- U'l MAHC) 5/6 Postage $ .:t" Certlfled Fee CJ o Return Reclept Fee o (Endorsement Required) o Restricted Dellv M (Endorsement R ..... m Total Postage & Fees $ :',:10 Postmark ",'" 1. 3!f: rn CJ "'PI~ DAWN H HETRICK i2 sii.6.'ijI:-Nf~I;E'l'---ROM>-m_n..m_..-_n.---___.n__._n___n__.___._- ~U.LE.._l'A.U053.___mn___nm.__...n_..m.nn_n_.__ City. State, ZIP+-4 PS Form 3800 June 2002 See Reverse lor lnslrllGllonS . cOmplete Items 1. 2, and 3. Also cornplele item 4 ff RestrIcI1!d Delivery Is desired. . Print your name and addnlS8 on the rwerse ...... we can return the cam to you. . -.n this cam to the beck of the mailplece, '" on tile front ff space permits. 1. AI1IdIl Addressed to: ~' . Daleol~ f"1 l.{_ 'f-ci\l Is doIIYery __ fIom It8m 11 C Yes........- ff YES, enter deIIv8Iy __ below: la-HO lIB 1WIJI H BETlUCK 2619 VALLEY BOAD JIAlrSVILLE PA 17053 3. _lypo II CettIlIsd Mall C Exproos Mall C Rog_ IlRe1um~""'_ [J _ .0.0. cted Delivery? (&tra Fee) II Yes 2. Artlcle Number (1lBns""""........... ~ PS Form 3811, Februsry 2004 7003 3110 0004 5770 5568 ~-FIoC:oIpt 102'96-Oa-M-164Q I (") c; 'c ,..., = <:,.~ en ~ 7..:1 , -J ~ o -n 9-..,., f'11p "'0 fIJ, -q, ~~~? ~-: -1", --~. ~ '~; r:? U'I N "I JAMES F. HETRICK, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2005-1616 CIVIL TERM DAWN M. HETRICK, Defendant IN DIVORCE 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 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 verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~, 2005 ;' ~) 11]') 1211 'l/pt J,( k/ DAWN M. HETRICK Defendant ~.,,((~ =~ -< o (~ r-' ceo <:;:".::.l en ,-- c: c~- N C" i.; r;;"l ~ CP o -n -1 ::r:~ ~;1;~; i.--' ,~'" '::J';-r', 1,,';i7Q 'C:,i"-h ~:;.~~ :L}. JAMES F. HETRICK, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2005-1616 CIVIL TERM DAWN M. HETRICK, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 28, 2005. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date:~'2005 :]>,,, 'Y1 111. Jk-iNJ-; DAWN . ETRICK C) ~~.- i';" -.... -<: .......) C:J c.::.." en C r-~ N c.r'" () "Tl :~ f;l~ ;' Cl -I"; _ iT) ,', ,0 ~, ~-'l ,:,. /'-, ..r:- v::o ~-:..] .< JAMES F. HETRICK, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2005-1616 CIVIL TERM DAWN M. HETRICK, Defendant IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: I. 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: "J.\ 'JO ,2005 ,-\ v1J J v~L./~~ /) . '..{>, //\71 I i(" /12 (tee" f/) DAWN M. HETRICK ~) .--' c-...? 0 C.:l -n ~,""j l" CO, ~'. ~:J .-\ :r::-l' n.tc.~ :\\\~~), ), /;,;";1 ~ .V' ...0 ::~:': '~:l ..<:. JAMES F. HETRICK, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2005-1616 CIVIL TERM DAWN M. HETRICK, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 28, 2005. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3. I consent to the entry of a final decree in divorce. 4. 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: JULY 26 ,2005 J. JAMES F. HET JR. o (~. r-." (:;-:7' C:;;:~l ;.;..Sl (~ 'c..... l-" ".' 0' ...'" -' c) -"r1 .-' -r.:---r., \^nr~', -"~-1 ;""'. \~,~ '-) ;'::~,' '~~)',:\\ \ ~~ ..... r:? <.-'1 o JAMES F. HETRICK, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2005-1616 CIVIL TERM DAWN M. HETRICK, Defendant IN DIVORCE 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 in 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 herein made are subject to the penalties of 18 Pa. C.s. Section 4904 relating to unsworn falsification to authorities. Date: JULY 26 , 2005 a JAMES F. HET JR. Plaintiff r-> C,;':' c..? <.:..J'1 (_.. C~: r-.-~ \'0.) C;" r:.? o -n ::;l f~~i~\ . -J (\...) ,~:~ ~~,; t',:,.~r'n ....::, '):; ,;"1 .<, ,- ,J' o JAMES F. HETRICK, JR., Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW 2005-1616 CIVIL TERM DAWN M. HETRICK, Defendant IN DIVORCE To the Prothonotary: PRAECIPE TO TRANSMIT RECORD 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 3301(c) of the Divorce Code. 2. Date and manner of service of complaint: A certified copy of the Complaint in Divorce was served upon the defendant, Dawn M. Hetrick, on April 4, 2005, by certified, restricted delivery mail, addressed to her at 2619 Valley Road, Marysville, Pennsylvania, 17053, with Return Receipt Number 7003 3110 0004 5770 5568. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 330 I (c) of the Divorce Code: by plaintiff: July 26. 2005; by defendant: July 20, 2005. (b)(l) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: (b )(2) Date of filing and service of the plaintiffs affidavit upon the defendant: 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 plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: July 26, 2005. Date defendant's Waiver of Notice in Prothonotary: July 26, 2005. Date: July 26, 2005 ~ i:::~ oJ' (~ (--- I- e." cr. >"7 -- o ..." .-1 :T:-n \~~\!~ ~~:~ .,- ?~~; C) ---,.; IC? U1 o .~: ~:~i -\r'1 .~ ":..) :....t::. - . . . . . . . . . . . . '. .. .. :f.;f.:f.:f.:f.:f.:f.:f. . . ~ :f. ~:f.:f.:f. :f.:f.:f.:f.:f.~:f.:f.:f.~:f.~:f.:f.:f.:f.:f.:f.:f.:f.:f. +:f.:f.:f.+ . :f. + + "':l-;f "'Of . . . . . . . . . . . IN THE COURT OF COMMON PLEAS . . . . OF CUMBERLAND COUNTY STATE OF . . . . JAMES P. HETRICK, JR., . . . . PLAINTIFF . . VERSUS DAWN K. HETRICK, . . . . DEFENDANT . . . . . . . . . . . . . . . . . . . . . . . . . . . AND NOW, DECREED THAT AND PENNA. No. 2005-1616 CIVIL TERM DECREE IN DIVORCE ~')0"'><;'~ '-\ Z.OClS, IT IS ORDERED AND JAMES P. HETRICK, JR. , PLAINTIFF, DAWN K. HETRICK , DEFENDANT, NONE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :f.:f.:f.+:f.+:f.+++++++++++++++++++++++++? ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . . . . . . . . . . THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT . . . . . -i " v . . . . ",.. '" .9 ........"" . ",. . ......,.. ....... .,/ --!'........... ,. ... -......;,;.. ." '. \'-. ~ . "<'I" ...: . ~" ... ..."". """" ................ .-,"""",: V . . ._- "- ,/ ;......""...........;.\', ':i'" . Ij .~~...... - . . 'tj:f.:f.:+;+ +'I'O:f.+;!;'f! '+'+:+:'10""+ Of. ItJL:! v - )~~ ROTHONOTARY --- . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. rIP '1 ~ ~'" 50 5' f> ~,'" Y 1- ~ ""rf"l yJ1 J. ~ ' . ~ , .~ . ....' ~ . ..~ ,.3"" . .. ..1\. "". . -