Loading...
HomeMy WebLinkAbout06-1877 MEGAN N. HEIKEL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO, 06 -/P"!7 CIVIL TERM JASON E. HEIKEL 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 or reliefrequested 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, 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, 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 MAYBE 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 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court ofComrnon 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. MEGAN N. HEIKEL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO. 06 -IP7J CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE JASON E. HEIKEL Defendant DIVORCE COMPLAINT UNDER 23 Pa.C.S. ~3301(c) AND 3301(d) OF THE DIVORCE CODE Plaintiff, Megan N, Heikel, sets forth the following cause of action in divorce: I. Plaintiff is Megan N, Heikel, who currently resides at 930 South Humer Street, Enola, Cumberland County, Pennsylvania 17025 since March 2005. 2. Defendant is Jason E, Heikel, who currently resides at 6789 Carlisle Pike Mechanicsburg, Cumberland County, Pennsylvania 17055 since August 2005. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing ofthis complaint. 4. Plaintiff and Defendant were married on November 20,2004 in Summerdale, Cumberland County, Pennsylvania, 5. Plaintiff and Defendant have lived separate and apart since March 2005. 6. There have been no prior actions for divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8, Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling, WHEREFORE, Plaintiff requests the court to enter a decree of divorce. ~~~ 930 South Humer Street Enola, P A 17025 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. Date -3 . I q ()(SJ Pl>in<iff ~~ 0c~ Ms, Me n N, Hel el ~ -.,) x;- ?--J ~ ~ ...() \) lrt C> ~ r- (iJ ('/\ (' (,--' (~\ '::~\< ...--'. 'it'. ,>) / ,? \ ,,) t',.! MEGAN N. HElKEL, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-1':;77 CIVIL TERM JASON E. HEIKEL, Defendant. : CIVIL ACTION - LAW : IN DIVORCE ACCEPTANCE OF SERVICE I, Jason E. Heikel, accept service of the Divorce Complaint, ') /,,', --"'/7/' I --/ Date I.....-? :> I ( t7 I 1 C I I u1e/l son E. Heikel, Defendant ,;~\L ',',.,,"', C'. MEGAN N. HEIKEL, Plaintiff : IN THE COURT OF COMMON PLEA.S OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-1877 CIVIL TERM JASON E. HEIKEL, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 93301 (c) of the Divorce Code was filed on ~arch 31, I 2006. i I I I 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninetyl (90) days I have elapsed from the date of filing and service of the Complaint. I I I I 3. I consent to the entry of a final decree of divorce after service of notice ot intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I unde stand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904, relati g to unsworn falsification to authorities. Date~ ,...." '. ,......, ,,~ '::.:::) c..:..,...... ...r';::: (J\ c:- MEGAN N. HEIKEL, Plaintiff v. JASON E. HEIKEL, Defendant : IN THE COURT OF COMMON PLE~S OF : CUMBERLAND COUNTY, PENNSY~ VANIA : NO. 06-1877 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~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 prope+y, lawyer's fees or expenses if I do not claim them before a divorce is granted. I I I 3. I understand that I will not be divorced until a divorce decree is entered b~ the Court and that a copy of the decree will be sent to me immediately after it is filed w*h the prothonotary. t I verify that the statements made in this affidavit are true and correct. I unde stand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relatin to unsworn falsification to authorities. I I I I I I I Date \\~ \u\AQ \\' CJ C "'-' c,::;:) 6~ 0'--' s-:? c., MEGAN N. HEIKEL, Plaintiff : IN THE COURT OF COMMON PLEJ1\S OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-1877 CIVIL TERM JASON E. HEIKEL, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 2006. 1. A Complaint in Divorce under s3301(c) of the Divorce Code was filed onlMarch 31, I I I I I 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninet~ (90) days I I I I I I I 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. s4904, relating to unsworn falsification to authorities. Date~ O~ o ()JYN\ J as E. Heikel, Defendant o -n --- 0" dJ .' -- C/O, MEGAN N. HEIKEL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-1877 CIVIL TERM JASON E. HEIKEL, Defendant : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~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 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. \\ I \~ / 00 Date t--,) ('~-~ ~ -1, 0') C) c;-, MEGAN N. HEIKEL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-1877 CIVIL TERM JASON E. HEIKEL, 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: 1. Ground for divorce: irretrievable breakdown under 93301 (c) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant by hand delivery. Service was complete upon receipt by Jason E. Heikel on 03/31/06. Acceptance of Service filed with the court 04/12/06. 3. Date of execution of the affidavit of consent required by 93301 (c) of the Divorce Code: by plaintiff - 11/14/06; by defendant - 11/14/06. 4. Related claims pending: none 5. Date plaintiffs Waiver of Notice was filed with the Prothonotary: 11/16/06. Date defendant's Waiver of Notice was filed with the Prothonotary: 11/16/06. November 16,2006 ~~~ ~w.~ Meg N. Heikel ::~: C) ..::::::_J --on 0' G' C') cr. IN THE COURT OF COMMON PLEAS :li :li'" :f.:f."':fi"'''' :f.:f. :li :f.:f.:fi"''f. :li :fi :Ii f+J :fi :Ii l4i :fi'" '" Of. OFCUMBERLANDCOUNTY STATE OF PENNA. MRG~1\1 1\1 HRTKF.T No. 1877 2006 Pl;'Ii nt; ff VERSUS JASON E. BEIKEL, Defendant DECREE IN DIVORCE 01 ~: Sf AA · ~ . IT IS ORDERED AND AND NOW, ,J ~ do&-- MEGAN N. BEIKEL , PLAI NTI FF, DECREED THAT JASON E. BEIKEL , DEFEN DANT, AND 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; NONE J. ATTEST: ~~ ROTHONOTARY "''f.'" 'f.:f. '" '" :li 'f. :f.:f.'f.:li0fl'f.0fl :li:fi:f. 'f. '" 'f.Et' Of. 'f.'f.Ef :f.:f. Ef Ef :fiEf;!; Ef Of. _-& 1 ~ ~ 10- /r-e/ 1f1-~~-r; W.jr-e/ . . ."... . .. . .... . ...~ MEGAN N. HEIKEL, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 06-1877 CIVIL TERM JASON E. HEIKEL, Defendant : CIVIL ACTION - LAW : IN DIVORCE NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in divorce from the bonds of matrimony on the 28th day of November, 2006, hereby elects to retake and hereafter use her previous name of Megan N. Morris, and gives this written notice avowing her intention in accordance with the provisions of 54 Pa.C.S. S 704. ~(\\k ~~ w. W Megan . Heikel Wishes To Be Known As: '\I\~>\\ .~. ~l\j\''0':J Megan Morris COMMONWEAL TH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. On the 1 st day of December, 2006, before me, a Notary Public, personally appeared Megan N. Heikel, known to me as the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notanal seiaL r ~ ' ~~~J~C-/ 2t2fr Notarial Sell Laurie L Wolt Notary PubIJo Carlisle BolO, Cumberland County My Com1DissioD Expires Feb. 14,2010 ~;t;' ;- :.~>fi \~ . ".' .... r' :' .,' (") f"..:) ~ ~ c::;3 c:: c::;3 ?:' CT" ~ ......1 '"t) '-r- 0 ~ l:', \.,-~~ f"I1 )\1r,'. ('11~ ~ ~ ~ Z.:", ("'") ".."/~ ','- :g I ,-,.':",-. , -;;:-- C) ~r .+:'" 1":)rr' .~- >U ~ ""::> ,;:\-r.j ~:2 :t:::'> 5:r " ~ :z 20 \.0 Om .::::-t - ~ ~ '1> - ~ --....l \;D ;.<, ~ . ~ t .,1 .. f