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Home My WebLink About95-02713 i / ./ ./r ~ c .A j I :::r: 1\ l, 1 ;1 ~ I j :! ~ J i , rV"\! \ . I i - I f'\ <0, , I ~) , ,*,.*..*~:.~,~.,~~*:....:,~:~:~:~;~~:~.;~~~.~,.~..~.~,*-. 8 $ ., ~ It. ~. It. It. ~, ~ I!l; i.! 1'.1 ~i . , 81 :t: ~ It. It. ~ It. It. It. '" l!\ It. 8: ~ It. IJ. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY I:,\, t....oL.y STATE OF f)~1~\~! PENNA, .......;J.)r' , Sl'EFFANI A. IIlJEIINEH 1 1'1 uIIIL t ff \"( I . , I!ll 81 ~ ~l It.! ~I . . II 8 81 I!ll ..' " if ~ ... ~'..~,~"~_.*.~*..~,~;~.~~;:.:~:.::.:~:.:-~;~:~.~,~,~:.~:,.~~ Wi DEAN II. IIl/EIINEH I Ill~ f(,I1<1ulIl AND NOW, decrood that and Il(,nl1 II. IhlPhllo.. ;\.11,27]) 199J DECREE IN o I V 0 R C E 4' ~ ~ Z8 P)1 -. 19 'J/j it is ordored and It A. Iltwhlll'" , plaintiff, dofendant. are divorced from the bOllds of tnUlrlrnollY, Tho court retaills jurisdictioll of the following claims which have been raised of record in Ihls (Jcllon for which a lillal order has not yet be Oil entered; NOll!' {J..1 $ ., r,; $ ~ 8 $ $ 8 ~ ~ 8 $ 8 I, 18 r I~ I!l ;8 :$ i' '8 f 18 :1iC I: ;~ I. It. , . !1Ii 8 .~ ~ ~ ,~ ~ s ~ i! ~ ~' STEFFANI A. HUEBNER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 95-2713 CIVIL TERM DEAN H. HUEBNER, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORO To the Prothonotary: Tranamit 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) . 2. Date and manner of service of the complaint: May 19, 1995, by certified mail, restricted delivery. 3. (a) Date of execution of affidavit of consent required hy S3301(c) of the Divorce Code: by the plaintiff - March 19, 19981 by the defendant - July 13, 1998, 4. Related claims pending: None. 5. (b) Date plaintiff's Waiver of Notice in ~3301(c) was filed with the Prothonotary: -&,1, S' , lit1r Date defendant'a Waiver of Notice in ~3301(c) was filed with the Prothonotary: July 16. 1998, ADDAMS & RUNDLE By: ~u~JR~ Michael R. Rundle supreme Court I,D. No. 27768 28 South Pitt Street P.O, Box 208 Carlisle, PA 17013 (717) 249-8300 Attorneys for Plaintiff STEffAN I A. IIUEBNEH, plaintiff III TilE COUIlT OF COMMON PLEAS OF CUMIlEHL1\llD coUNTY, PENNSYLVANIA v. NO. 95- CIVIL TERM DE1\N II. IIUEBNEH, Defendant III DIVORCE COMPLAIllT III DIVOHCE 1. The plaintiff is steffani A. Huebner, an adult individual residing at 532 Salmon Hoad, Mechanicsburg, cumberland county, Pennsylvania. 2. The Defendant is Dean II. lIuebner, an adult individual residing at 532 Salmon Road, Mechanicsburg, cumberland county, Pennsylvania. 3. The plaintiff and Defendant have been bona fide residents of the commonwealth of Pennsylvania for at least six (6) months immediately preceeding the filing of this complaint. 4. The parties are husband and wife, having been lawfully married on July 7, 1978, in Hershey, Pennsylvania. 5. Neither plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Solider'B and sailor's civil Relief Act of the congress of 1940 and its amendments. 6. There have been no prior actions for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 19. The Plaintiff requires reasonable support to adequately maintain herself in accordance with the standards of living established juring the marriage. WIIEIlEfORE, the Plaintiff respectfully t"equests the Court to enter an award of a I i many pendente Ii te unti 1 fi na 1 hearing and thereupon to enter an order of alimony in her favor, pursuant to section 3701 and 3702 of the Divorce Code. COUlIT V REQUEST fOR COUlISEL fEES. COSTS AND EXPENSES UNDER SECTION 3104. SECTION 3323 AND SECTION 3702 Of TilE DIVORCE com:; 20. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 21. The Plaintiff has employed Michael R. Rundle, Esquire, of the firm of fowler, Addams, Shughart & Rundle to represent her in this matrimonial cause. 22. The Plaintiff is unable to pay the necessary counsel fees, costs and expenses and the Defendant is more than able to pay them. 23. The Plaintiff is in need of hiring various experts to appraise the parties' marital assets and does not have the funds to pay the necessary and reasonable fees. WIIEREfORE, the PIa i nt if f respectfu Il y requests that pursuant to Section 3104, section 3323 and Section 3702 of the Divorce ~ '--- ~ ItJ ~ IJ X' ..... h ~ ~ ~ 1k t (J'\ f'\ "\ ~ . ' \:~ rX" () , '- . - \J \ \\ - IJ \ t..f.l ~ U. V\ Ii' \:S ~ . ~ ~\ ~~~ ~ VJ t ("\ '. I. '. ~ ~ ~ "---" .... r r }' L. '" , } 0, --.~ .. 'J 'lJ .:: STEfFAN I A. IIUEBNER, Plaintiff IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 9'i-2713 CIVIL TERM DEAN H. IIUEBNER, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 330I(c) of the Divorce Code was filed on May 19, 1995. 2, The matTiage of Plaintiff and Defendant is in'etrievably broken and ninety (90) days have elapsed from the filing 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, 4. I have been advised of the availability of marriage counsell ing and undet'stand that I may request that the court require that my spouse and 1 participate in counselling prior to a divorce decree being handed down by the court. 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. !l4904 relating to unsworn falsification to authodties. / ) 8tefi Datel < 8//111/ { i . , I99B v. IN THE COURT oF' COMMON PLEAS OF ('UMBERI1\NU COUNTY, PENNSYLVANIA NO. 95-271] CIVIL TERM STEFFAN I A. IIUEBNEIt, Plaintiff DEAN 11. IIUEBNER, Defendant I N III VOIleE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 13301(0) OF THE DIVORCE CODE 1. I consent to the ('nUy of a finill decree of divorce without not i ce. 2. I understand that I may lOBe tiSlhts concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted, l. 1 undel'stand that I wi 1 I not bll di VOL ced unll I a divorce decree is entered by the Court and that. a copy of the decl'ee will be Bent to me immediatel y after it i B fi 1 CHi wi th the ProthonotalY. I verify that the statementB made In this affidavit are true and con-eel. 1 undel'stand that false statements herein are made subject to the penalties of 18 Po. (,,8. 54904 relating to unsworn falsification to authorities. Date. 3/lf/fX f , / / I / , /1//. .'.'slelHlt6( . ) , I9!l1l ,II 'J .~ , , , I -,., .,\ -, t ~.' STEI'FANI A. IIUEBNEll, plainti I.f IN TIlE COURT OF COMMON PI,EAS OF CUMBERLAND COUNTY, I'ENNSYINANIA v. NO. 95-2713 CIVIL TERM DEAN II. IIUEBNER, Defendant IN lJIVOIlCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 13301(c) OF THE DIVORCE CODE I. I consent Lo Lhe enLry of a t inal decl-ee of divol-ce without not ice. 2. I understand that I may lOBe l-ights concerning alimony, division of property, lawyer's fees or expenses if 1 do not claim them before a divorce is granted. 3. 1 understand that I wi 1 I noL be divorced unt i 1 a di VOl'Ce decree is entered by the COUlt and that a copy of the decree will be sent to me immediately alter it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct, I understand that false stiltements her"ein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. __~.-.... :::I!' :r~ Oean II. lIuebner Date. Jul y 13 , 1990