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Home My WebLink About98-03436 L. v ~' ~' ~. -. .a U v! ~, o'. ~~ :e:• <~:• te: t~:• t~:• <~:• :~> <~:• •;•> ;e• e e s e e: • ..~,, ~', ~. ,~ ... ~ •_: c~ + ~+'~. i o:;,;o:~;:'e:c•i9 ;i; ~ '; • o IN THE COURT OF COMMON hLEAS A OF CUMBERLAND COUNTY ° ;:; s t~^ ,• • ~ ;i; ~'" J ~~Os STATE OF sr'~t"A)~~F,~;,~ PENNA. ;i; _,.STEPHEN,.E,_ HUMMER _ _ _ L\' a ....3.9.3 6 .......... ......9.8...... I t) ', .: ..... Plaintiff __ • 1'ci,u ;i; ;i; i ~ ELIZABETH. J.. HUMMER _ ', ;i; •; _ _ Defendant - - %• ;i; ii o ®ECREE IIl1 DIVORCE ;: AND NOW, .....Noy.e'-'e ~ cT• • • ~•I• • • ... , 19 .R.~. , it is ordered and •. :, plaintiff, ••' decreed that .... STtrPH.~N. >r...HUMMER ........................ . s ;, ;: ;e; and ... EL.IZABE.TH. J....HUMMER ............................... . defendant, e 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 8 been entered; ;:•, a • • ;:•, ~ o P By The C~ t:~ !: (/(/// 0 is ~ ...r _.. 3 b e __ .... ~ - ;. Attegr. P~r~~/ ~ • e C.r'oL~frii .P~r ~nea`~ A d Prolhonotlry /...,.! %s:• >»:•, >;e • <o:• t~:• • e • co;• •s,• :ei •;~ • <~ • <s • <e: c~. s>~•a:•~ •c~:• te:• ~ce:• te• ~ s:• :ei •;e:• •;e:• te:• cei re:• ~;e:. <~: •a:' _._., ,„a ,._ .. -. _...., mom..-,~ ~~ ~ PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West Lowther Street Carlisle, PA 17013 (717) 249-2721 .STEPHEN E. HUMMER Plaintiff V. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW ELIZABETH J. HUMMER NO. 98-3436 CIVIL TERM Defendan4 IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: Complaint served on Elizabeth J. Hummer by Certified Mail, vrith return receipt signed on June 22, 1998. 3. Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: Plaintiff on September 24, 1998. Defendant on October 23, 1998. 4. Related claims pending: None Date: Tuesday November 3 1998 ~~ Peter J. Russ-~- ~^. : h r'l = G~ _ n _'.I •~J '~ _ 1~1~ ~ _ •~ f_~.~ ~.~ . .1 f jl! . . -~ _ . J _.~ . ']7 .J -~ STEPHEN E. HUMMER PlafntiN v. ELIZABETH J. HUMMER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION))- LAW NO. 98- 3 y3 ~P CIVIL TERM 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 mujst take prompt action. You are warned that if you fail to do so, the case 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 4o 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 Court House, 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 OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717j 249-3166 PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 STEPHEN E. HUMMER Plalntlff v. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW ELIZABETH J. HUMMER NO. 9& CIVIL TERM Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 33010 AND 3391 (D) OF THE DIVORCE CODE. AND NOW comes the above-named Plaintiff by and through his attorney Peter J. Russo, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff is an adult individual residing at 411 North Street, Apt. 3, Carlisle, Cumberland County, Pennsylvania and is a citizen of the United States. 2. Defendant is an adult individual residing at 661 Mud Level Road, Shlppinsburg, Cumberland County, Pennsylvania and is a citizen of the United States. 3, Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania and has resided continuously therein for at least six months prior to filing of this Complaint. 4. Defendant has been a resident of the Commonwealth of Pennsylvania and has resided continuously therein for at least six months prior to filing of this Complaint. 5. Plaintiff and Defendant were married on July 21, 1982 in Dillsburg, Pennsylvania. COUNT 1 -DIVORCE 6. Plaintiff hereby incorporates by reference averments 1 through 5 of this Complaint as if each averment were set forth fully hereunder. 7. There has been no prior action for divorce by either party against the other. 8. Neither Plaintiff nor Defendant is in the Armed Forces of the United States or any of its allies. 9. Plaintiff avers that the marriage between the parties is irretrievably broken. 10. 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, but does not request the same. WHEREFORE, Plaintiff, Stephen E. Hummer, prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: A. That a decree in divorce be entered dissolving the marriage between the two parties. Res ecffully submitted, ~~.~ Peter J. Russo, Esquire Date: Friday, June 19. 1998 VERIFICATION I, Stephen E. Hummer, hereby state that the statements made in the foregoing are true and correct to the best of my knowledge, information and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: (9 '-' ~ ~^ / ~~ St hen E. Humm r ~I `; .~ I ~ _~ ~~ Q 1 V c'> _n --~ C: ='> i i r n r 1 !) - '~ -ii ( -- `~ `J ~i .j ,,~ ~~ -. tG -. ,~ PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West Lowther Street Carlisle, PA 17013 (717) 249-2721 STEPHEN E. HUMMER Plaintiff v. ELIZABETH J. HUMMER Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 98-3436 CIVIL TERM . IN DIVORCE PROOF OF SERVICE OF P INTIFF'S COMPLAINT UPON DEFENDANT AND NOW, COMES, Peter J. Russo, Attorney for Plaintiff, Stephen E. Hummer, and certifies that on June 20, 1998, he did serve the Defendant, Elizabeth J. Hummer, with a true and correct copy of the Divorce Complaint filed against her alleging the parties marriage was irretrievably broken under Section 3301 (d) and Section 3301 (c) of the Divorce Code. Said complaint was served upon the defendant by placing same in an envelope, return receipt requested and addressed to Elizabeth J. Hummer, 661 Mud Level Road, Shippensburg, Pennsylvania, 17251. Service of Plaintiffs Complaint on the defendant, Elizabeth J. Hummer, was effected on June 22, 1998. A true and correct copy of the U.S. Postal Service Return ' Receipt is attached hereto and the original is affixed to the reverse of this document as ' well as the Defendant's Acknowledgement of Service. Date: Thursday June 25 1998 Respectfully submitted, Peter J. Russo ..+ I o SENDER: I also wish to receive the Iv_ •ComDlate Hemet andlar 2lor additional 6arvicea. end 46 Ia 3 {OIIOWIng Services (for an l m I m , , •COmplele items a . antra tae): .prim your name and eddrem on the rovarao of Ihis loan so That we can return Ih 1 L ~ card to you. .Attach Nis loan to the Iron) of the mallplece, or on the hack it apace dose nol 1. ~ Addf0558B'S Address ~ m I ~ ~ °r permit. •Wdle'Refum Receipt Requested'on the mailpiece below the adide number. 2. 0 Restricted Da Vary nide was delivered and the data h N °' Ir~ . e s .The Relum Receipt vAll show to whom t Consult postmasterfor fee. ~ I c ~ ~ delivered. 3. Article Addressed lo: 4a. Article Number ~ ~ 13 a1 t u ci ~ - ~. ¢ , ~ I °-' E`tzatx.~h Humme.n 4b. Service Type d a ~ ~ ~ YY~ycA Lc~~ eQ ~ c1, ( ( ^ P,egistered ~ Certified d e I w o ~ S~1i `~,~{ ~ 1"~ ~ ~ ~ 5~ ~ ~ ~- ^ ExpressMail ^ Insure ~ Retum Receipt for Merchandise ^ COD ~ ~ . w ; ' 0 1 0 7. Date of Delivery ~,~ •~ C (/ ~• O a o T Q c // R. Addressee's Address (Only it requested m i 5. Received By: (Print Name) and /ee Is paid) s lu t „ i .. re: (Addressee ar U ' is I T ~/ A ~ Domestic Return Receipt I. PS nn 3811, December 1994 '' ~! I~i 'f ~' STEPHEN E. HUMMER Plalntlff v. ELIZABETH J. HUMMER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 98- CIVIL TERM IN DIVORCE ACKNOWLEDGEMENT OF SERVICE OF COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW, COMES, Defendant, Elizabeth J. Hummer, and does hereby acknowledge that on the date indicated below he did receive a verified copy of a Complaint in Divorce filed against him in the above captioned case. DATED: tv Elizab J. ummer ~~~~~' ~., . -~ ,, !-- l7 : ~\ "n ~-> ~~ _ ~ ~ tJ i i;: ,~~ STEPHEN E. HUMMER Plaintiff v. ELIZABETH J. HUMMER Defendant IN THE COURT OF COMMON PLEAS OF , CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.88-3436 CIVIL TERM . IN DIVORCE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 19, 1998. 2. The marriage is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce without further notice. 4. I understand that I may lose rights connsming alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. 5. 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's Office. 6. 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. I understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me on request. 7. Being so advised, I, Stephen E. Hummer, do nat request that the Court require my spouse and me to participate in counseling prior to a divorce decree being handed down by the Court. I verify 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.GS. § 4904 relating to unsworn falsification to Authorities. gla~ll~~ ~ ~ Date St en .Hummer ' Gi p ~ _ :n _ ('1 .' T [~: ~ ~ :: . ~r _~.. ~ J ...~ fl'1 il} ... ~ ' ~ -~ --- ~_ .. :J '1 ~b 1 STEPHEN E. HUMMER Plainttff v. ELI7JaBETH J. HUMMER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 98-3436 CIVIL TERM IN DNORCE DEFENDANTS AFFIDAVIT OF CONSENT AWD WAIVER OF NOTICE OF INTENTION TO ENTER DIVORCE DECREE UNDER SECTION 33o1(c) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on June 19, 1998. 2. The marriage is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. 1 consent to the entry of a Final Decree of Divorce without further notice. 4. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. 5. 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's Office. 6. 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. I understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me on request. 7. Being so advised, I, Elizabeth J. Hummer, do not request that the Court require my spouse and me to participate in counseling prior to a divorce decree being handed down by the Court. I verify that the statements made in this Affidavit era 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. ~ ~~ C ~ t ~,L, N~re1~ ~l~r~v~a~-~ Date Elizabeth Hummer C) .~ T C: _t ~ .~ r_i , _ .:jp i. i,> , i I'7 ..J •TJ •'n ' J ~, : ~:? =~ :..J J7 -` f ~~,. ~ . ... STEPHEN E. HUMMER Plaintiff v. ELI7~IBETH J. HUMMER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.98-3436 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Peter J. Russo, hereby certify that I am on this day serving a copy of the Defendant's Affidavit of Consent and Plaintiff s Affidavit of Consent. upon the person(s) and in the manner indicated below, service by First-Class Mail, Postage Prepaid, and Addressed as Follows: Elizabeth J. Hummer 661 Mud Level Road Shippensburg, PA 17257 ~~ Peter J. Russo 61 West Lowther Street Carlisle, PA 17013 (717) 249-2721 Date: Thursday October 1 1998 ~, r STEPHEN E HUNlP.~ER Plalrrtlif v. ELIZABETH J. HUMMER Defendant . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACT10N -LAW NO. 9&3436 CfV11 TERM IN DIVORCE PROOF OF SERVICE OF DEFENne~S e~nn~~~T UPON DEFENDANT AND NOW, COMES, Peter J. Russo, Attorney for Plaintiff, Stephen E. Hummer, and certifies that on Thursday, October 1, 1998, he did serve the Defendant, Elizabeth E. Hummer, with the Affidavit of Defendant Under Section 3301 (c) of the Divorce Code requesting her signature thereon by placing same in an envelope addressed to Elizabeth E. Hummer as set forth in the attached certificate of service. Peter J. Russo Date: Thursday. October 1 1998 COO p~ STEPHEN E HUA~tMER Plairtth{ la THE COURT OF COI11i1~ON PLEgS OF ~I~ERL,AidD COUNTY, PENNSYLVANW v. • cma-ACnoa - u-w J. HUIIitUER .. IN~DNORCE CNIL 7'ERY 1 • A Complaint in Divorce under Section 3301(c) of the Dlvorce Code was filed on June 19, 1998. 2• The marriage is irretrievably broken and Winery days have elapsed from the date of the filing and service of the Complaint. 3• I consent to the entry of a Finn! Decree of Divorce without fwttter notice. 4• I understand that I may lose rights concerning alimanY~ division of property, lawyers fees ar expenses if I do net Gaim them before a divorce is 9r~tted the C 5. I understand that I will not be divorced until a divorce decree is entered b Dort and that a copy of the decree will be sent to me immediately after it is filed y with the Prothonotary~s OPlice. 6• I have been advised of the availability of marriage ~urtseling and understand that I maY request that the court require that my spous® and I counseling. 1 understand that the court maintains a list of mama ® P~cipate in Domestic Relations Office, which list is available to me on ® CO~lore in the request. 7• Being so advised,, 1, Stephen E Hummer, do not request that the Court require my spouse and~mrte to P~tiGpate in counseling prior to a divorce decree 6ein handed down b the C I verify that the statements made in thisAffidavit are true and correct. 1 understand that false stbtements herein are made § 4904 relating to unswom falsificaQion to Authorities~~ to the penalties of 18 PaC.S. 9~d4!'q$'7RIJE COPY FRCM RECOR Date m Testimony whereof, I hove unto set and the seal of said Court at Carlisle, Pa. en • Hummer rnis ,-- -u~ day 19~ s ~,~., ,-----_. .. Prothnnntarv r STEPHEN E HUMMER Plairittft v. ELIZABETH J. HUMMER ~4andettt IN THE COURT OF COMMON PLEAS OF CUMBERLANt7 COUNTY, PENNSYLVANIA CIVIL ACTION _ LAW NO. 98.3438 CML TEAM . IN DIVORCE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on Jtute 19, 1998. 2. The marriage is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Fnal Decree of Divorce without further notice. 4. I understand that f may lose rights connsming alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. 5. 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 Prathonotar~s Office. 6. 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 partiapate in counseling. I understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me on request. 7. Being so advised, I, Elizabeth J. Hummer, do not request that the Court require my spouse and me to participate in counseling prior to a divorce decree being handed dawn 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 Ps.C.S. §4904 relating to unswom falsification to Authorities. Date Elizabeth J. Hummer i i'' ~: ~; r~ ~.;~ ;, _ _;_ '; .-„ ~., j: { __- ~ %~j j ", . ..rn -'i: N =i { ~ a' .tl ._. ~ ~ ,1 ~,1 I STlPNlN !. HUMMlR, Plaintiff v. ELIZABlTH J. HUMMlR, Defendant IN TH! COURT OF COMMON PLlAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 1998 - 03436 CIVIL TERM IN DIVORC! NOTICE OF INTENTION TO RESUME PRIOR SURNAME Notice is hereby given that the PLAINTIFF in the above matter: prior to the entry of a Final Decree in Divorce, or x after the entry of a Final Decree in Divorce, dated November 11, 1998, hereby elects to resume the prior surname of ELIZABETH J. LEREW, and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. Section 704. Signa re - ELIZAB N J. fHUMMlR ~ (SEAL) Signa re of Nam Being Resumed ELI BlTN J. LlREw COMMONWEALTH OF PENNSYLVANIA :SS: COUNTY OF CUMBERLAND On the 9"' day of November, 2007, before me, a notary public, personally appeared the above affiant, known to me to be 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 me hand and officiaVseal. COMMONWEALTH OF PENNSYLVANIA `-~ y NOTARIAL SEAL Notary Public Harold S. [twin iii; Esq, Notary Public Carlisle, Gttmberland County My commission expires February 06, 2011 `'~'~+ c ~ ~~5 x V ~ ~F.~ W y~ ~~ ~ 7* -: Q W .,,~