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Home My WebLink About04-1708JAMIE HEMMING, Plaintiff KENNETH HEMMING, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : : CIVIL ACTION - LAW IN : DIVORCE :NO.O~-/7o[ CIVIL TERM 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 right 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 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 S. Bedford St. Carlisle, PA 17013 (717) - 249-3166 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. JAMIE HEMMING, Plaintiff KENNETH HEMMING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. Og-tTO7 CIVIL TERM COMPLAINT The Plaintiff, Jamie Hemming, by her attorneys, the Family Law Clinic, sets forth the following cause of action: DIVORCE UNDER SECTIONS 3301(c) & (d) OF THE DIVORCE CODE 1. Plaintiff is Jamie Hemming, who currently resides at 252 McCalister Church Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Kenneth Hemming, whose current residence is 25 Pfautz Avenue, Litiz, Lancaster County, Pennsylvania 17543. 3. Plaintiff has been a bona fide resident of the Commonwealth and Cumberland County for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on November 17, 2000 in Elizabethtown, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since July 14, 2001. 6. There have been no prior actions of divorce or for aamulment 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 Cottrt require the parties to participate in counseling. WHEREFORE, Plaintiff requests that the court enter a decree of divorce dissolving the marriage. Date: Respectfully submitted, Certified Legal Intern Thomas M. Place Lucy Johnston-Walsh SUPERVISING ATTORNEY FAMILY LAW CL1NIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 VERIFICATION I verify that the statements made in this Divorce Complaint are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. t~i~nie Hemming JAM1E HEMMiNG, Plaintiff KENNETH HEMMiNG, Defendant : iN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA : : CIVIL ACTION - LAW iN DIVORCE : NO. 0 St-/70YC1VIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Jamie Hemming, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date Erin Chafin Certified Legal Intern LUCY JOHNSTON-WALSH Supervising Attorneys THE FAMILY LAW CLiNIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 JAMIE HEMMING, Plaintiff KENNETH HEMMING, Defendant : 1N THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : : CIVIL ACTION - LAW IN : DIVORCE : :NO. O~/-/?oyCIVIL TERM NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF TIlE DIVORCE CODE 1. The parties to this action separated July 14, 2001, and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date mming JAMIE HEMMING, Plaintiff KENNETH HEMMING, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION - LAW IN DIVORCE :NO. 04-1708 CIVIL TERM VERIFICATION OF SERVICE Understanding that the making of any false statement would subject The Family Law Clinic to the penalties of 18 Pa. C.S. § 4904 (relating to unsworn falsification to authorities), the undersigned verifies that Erin Chafin mailed a true copy of the Divorce Complaint, Plaintiff's Affidavit, and Pmecipe to Proceed In Forma Pauperis on the Defendant by placing the same in the U.S. Mail, certified no. 7002 0860 0001 5847 8721, restricted delivery, return receipt requested, postage prepaid, on the 20th of April, 2004 addressed as follows: Kenneth Hemming 25 Pfautz Avenue Litiz, PA 17543 Sender's receipt no. 7002 0860 0001 5847 8721 is attached hereto and incorporated by reference. Green return receipt no. 7002 0860 0001 5847 8721 was delivered to The Family Law Clinic, bearing the signature of Kenneth Hemming and showing a date of service of April 21, 2004. The return receipt is attached hereto and incorporated by reference. Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243 -2968 · AJ!nbul ue 6ujqeuJ uoq~A 1[ lUeSoJd pue TdpaoJ s!qi 8AeS :1NVli~OdWl :soplAOJd I!elAJ pa!l!pa:) · ite~. -.*-r name and address on the reverse so that · Attach ~3 No [~ Express Mai[ Certified Mail -~ Return Receipt for MerchandiSe 7002 0860 00£11 5847 6721 ~uguSt 2001 JAMIE HEMMING, Plaintiff KENNETH HEMMING, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW : Divorce : NO. 04-1708 CIVIL TERM CERTIFICATE OF SERVICE I, Jason C. Evans, hereby certify that I am a competent adult and that I served a true and correct copy of the Notice of Intent to file a Praecipe to Transmit Record, to Kenneth Hemming, 25 Pfautz Avenue Litiz, PA 17543. I verify that the statements made in this certificate are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to nnsworn falsification to authorities. Date Jason ~5. Evans Certi~ed Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243 -2968 CiE~.~c~ C~ 0 JAMIE HEMMING, Plaintiff KENNETH HEMMING, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA : : CIVIL ACTION - LAW : IN DIVORCE : : : NO. 0 it. / 70," CIVIL TERM pRAECIPE TO PROCEEB IN FORM.4, PAUPERI£ To the Prothonotary: Kindly allow Jamie Hemming, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date Erin Chafin Certified Legal Intern ANNE ~?fi2DONALD-FOX-/ THOMAS M. PLACE LUCY JOHNSTON-WALSH Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243 -2968 JAMIE HEMMING, Plaintiff KENNETH HEMMING, Defendant : IN THE COURT OF COMMON PLEAS OF i CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW : DIVORCE : :NO. 04-1708 CIVILTERM _PRAECIPE TO TRANSMIT RECORB To the Prothonotary: Please transmit the record, together with the following information, to the court for entry ora divorce decree: Ground for divorce: irretrievable breakdown under Section 3301(d)(1) of the Divorce Code. Date and manner of service of the complaint: Served on Defendant by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Defendant on April 21, 2004. Date of execution of the Plaintiff's Affidavit required by Section 3301 (d) of the Divorce Code: April 20, 2004. Date of filing of the Affidavit: April 20, 2004. Date of service of the Plaintiffs Affidavit upon the Defendant: April 21, 2004. Related claims pending: None. Date and manner of service of the Notice of Intention to Request Entry of Divorce Decree, a copy of which is attached:: United States mail, first class, postage prepaid on May 27, 2004. Date Respectfully Submitted, so?j:, l~:vans Certified Legal Intern r (tCpON^LD-FOX LUCY JOftNSTON-WALSH ROBERT E. RAINS THOMAS M. PLACE Supervising Attorneys The Family Law Clinic 45 North Pitt Street Carlisle, P^ 17013 (717)243 -2968 Fax (717)243-3639 JAMIE HEMMING, Plaintiff KENNETH HEMMING, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION-LAW : Divorce : : NO. 04-1708 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE TO: DEFENDANT, Kenneth Hemming You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the § 3301(d) affidavit. Therefore, on or after June 16, 2004 the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothontary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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 32 South Bedford Street. Carlisle, PA 17013 (717) - 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court 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 hefore 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. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of PENNA. Jam~e Hemming Plaintiff VERSUS Kenneth Hemminq Defendant NO. 04-1708 DECREE IN DIVORCE AND NOW,_ DECREED THAT AND July '~ Jami~ Hemming Kenneth Hemminq ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,2004 , IT IS ORDERED AND ,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 BEEN ENTERED;