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Home My WebLink About07-2858f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RHEANNE HAMMOND, CIVIL ACTION - LAW Plaintiff V. NO. KENNETH RAY HAMMOND, JR., Defendant 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 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 grounds 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 at Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 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 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 Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 WEIGLE & ASSOCIATES. P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RHEANNE HAMMOND, CIVIL ACTION - LAW Plaintiff V. NO. KENNETH RAY HAMMOND, JR., . Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, comes the above named Plaintiff, Rheanne Hammond, by and through her attorneys, Weigle & Associates, P.C., and Jerry A. Weigle, Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff, Rheanne Hammond, is an adult individual presently residing at 1171 Three Square Hollow Road, Newburg, Cumberland County, Pennsylvania 17240, since 2006. 2. Defendant, Kenneth Ray Hammond, Jr., is an adult individual presently residing at 25 Covered Bridge Road, Newburg, Cumberland County, Pennsylvania 17240, with mailing address of P.O. Box 81 since January 2006. 3. The Plaintiff and Defendant are nationals and citizens of the United States of America, and both have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of the Complaint in Divorce. 4. The Plaintiff and Defendant were married on October 24, 1998, in Franklin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. 8. The parties have lived separate and apart since January 2006. 9. The Plaintiff requests the court to enter a decree of divorce. WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 COUNT II - EQUITABLE DISTRIBUTION 10. Paragraphs 1 through 9 of Plaintiff's Complaint are incorporated herein by reference as though set forth in full. 11. Plaintiff and Defendant have legally and beneficially acquired property, both real and personal, during their marriage from October 24, 1998, until January 4, 2006, date of separation, all of which property is "marital property". 12. Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, "non-marital property" which has increased in value since the date of the marriage and or subsequent to its acquisition during the marriage, which increase in value a marital property- 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property to the date of the filing of this Complaint and substantial portions of said property are in the exclusive control of Defendant. 14. Plaintiff requests the Court to equitably divide all marital property. WHEREFORE, Plaintiff requests the Court to equitably divide all marital property and to enjoin Plaintiff and Defendant from the removal, disposition, alienation, or encumbering of all real and personal property of the parties. WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony and for such other and further relief to which Plaintiff shall be entitled. WEIGLE & ASSOCIATES, P.C,, By. J Z' eeigle, Esquire Attorney for Plaintiff Attorney ID #01624 126 East King Street Shippensburg, PA 17257 Telephone 717-532-7388 WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. § 4904, relating to unworn falsification to authorities. Dated: WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 11 O R.? Qs W C? n? v v ?.v rv ca kJO 0 TI r.z1 a l? J C It IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RHEANNE HAMMOND, CIVIL ACTION - LAW Plaintiff V. NO. 07-2858 CIVIL KENNETH RAY HAMMOND, JR., Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS Brooke L. Naugle, being duly sworn according to law, deposes and says that on May 26, 2007, a true and attested copy of Complaint in Divorce with Notice to Defend and Claim Rights was served upon the Defendant, Kenneth Ray Hammond, Jr. Manner of service: by mailing the same postage paid, certified mail, addressee only, and return receipt requested, at Shippensburg, Pennsylvania, addressed as follows: Kenneth Ray Hammond, Jr. PO Box 81 Covered Bridge Road Newburg, PA 17240 The return receipt signed by the Defendant is evidence of delivery to him and is attached hereto as "Exhibit A." Bro e L. Naugle Sworn to and subscribed me this 31 st dav-of Mal WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 Notarial eal Rhonda R. Wolford, Notary Publiio Shippensburg Boro, cumberiand County My Commission Expires Jan. 20, 2009 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RHEANNE HAMMOND, CIVIL ACTION - LAW Plaintiff V. NO. 07-2858 CIVIL KENNETH RAY HAMMOND, JR., Defendant IN DIVORCE PROOF OF SERVICE ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we stum the card to you. ¦ Attach t the back of the mailpiece, or on permits. 1. Artlole to: Rennef'h Ray Hammond, Jr., PO Box 81 Covered Bridge Rd. Newburg, P® 17240 A. swohn 13 6. Received bf(Pdnfed Name) C. Date of Delivery D. Is delivery address d iferent from item 1? ? Yea If YES, enter delivery address below: ? No 3. Type Certified Mall 13 Mail ? R"Istered Retum Recelpt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Ex" Fee) 2. Article Number Mwafer from service &W P3 Form 3811, February 2004 Domestic Regan Reoso 1e25e5-02-r,1-1540 WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 a ? ft3 ':l7 C) lqo , A• RHEANNE HAMMOND, IN THE COURT OF COMMON Plaintiff PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO 01- ?,2BS8 at u KENNETH RAY HAMMOND, JR. Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under §3301(c) of the Divorce Code was filed on April 30, 2007. 2. The marriage of 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 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. § 4904 relating to unsworn falsification to authorities. Dated: KE ET Y FHA- ND, JR., Defendant WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 ?t rs`t ? ; ' .6 ? , ? c ? C?' .? ?, -' .-? ? d : RHEANNE HAMMOND, IN THE COURT OF COMMON Plaintiff PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW c? NO 07, .2858 KENNETH RAY HAMMOND, JR. Defendant IN'DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) AND § 3301(d) 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. § 4944 relating to unsworn falsification to authorities. Dated: NNETH RAY , JR., Defendant WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 ????, ? ? .?, ..? :?j ?=:??- -? ??? ? ?:?' ?: ? ?? ? V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RHEANNE HAMMOND, CIVIL ACTION - LAW Plaintiff V. NO. 07-2858 CIVI1; KENNETH RAY HAMMOND, JR., Defendant 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. Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: June 18, 2007, Acceptance of Service. - 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by Plaintiff, RHEANNE HAMMOND October 29, 2007; by Defendant, KENNETH RAY HAMMOND, JR., November 3, 2007. 4. Related claims pending: None 5. Date of filing of the Waiver of Notice required by § 3301(c) of the Divorce Code: Plaintiff's, October 29, 2007; Defendant's, November 13, 2007. WEIGLE & ASSOCIATES, P.C. - )IZ4 q t JgFry A. W igle, Esquire Attorney for Plaintiff Attorney ID # 01624 126 East King Street Shippensburg, PA 17257 Telephone (717)532-7388 r WEIGLE & ASSOCIATES, P.C. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 e,a a ? O -st - to r? ? a rarr; ? f: ?c.? ?:? r-n ? ?, -? ca ?, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. RHEANNE HAMMOND Plaintiff VERSUS KF-NNFTH RAY HAMMOND. JR. Defendant No. 07-2858 DECREE IN DIVORCE '#IJ 2,7 gyp? ?4 AND NOW, IT IS ORDERED AND D E C R E E D T H AT RHEANNE HAMMOND AND KENNETH RAY HAMMOND, JR. ARE DIVORCED FROM THE BONDS OF MATRIMONY. , 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 BE ENTERED; BY THE ATT ST: J. 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