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HomeMy WebLinkAbout01-0774KOREN HAIVflVIONS Plaintiff VS. SHAWN HAMMONS Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. 0]" 77q C"(,~{'I : 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 Plainti~ 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 Court House, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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. Pennsylvania Bar Association Lawyer Referral Service P.O. Box 186 Harrisburg, PA 17108 Telephone: 1-800-692-7375 (PA Only) or (717) 238-6715 KOREN HAMMONS Plaintiff VS. SHAWN HAMMONS Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA :NO. O/,?7q ~ 7~**~ : Divorce COMPLAINT DIVORCE UNDER SECTION 3301 (C) OR 3301 (D} OF THE DIVORCE CODE. I. Plaintiffis Koren Hammons, has no permanent residence, bm a mailing address of 22 Park Street, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. Plaintiff has resided in Cumberland County for at least the last year. 2. Defendant is Shawn Hammons, who currently resides at Molly Pitcher Hotel, 13 South Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013 since approximately November 2000. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 18, 2000 in Carlisle, Pennsytvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 8. The Defendant is not a member of the Armed Services of the United States or any of its Allies. are~ 9. The causes of action and sections of the Divorce Code under which Plaintiffis proceeding A. Section 3301(c): The marriage of the parties is irretrievably broken. After ninety (90) days have elapsed from the date of filing this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiffbelieves that Defendant may also file such an Affidavit. B. Section 3301(d): The marriage of the parties is irretrievably broken. The Plaintiff and Defendant separated on May 30, 2000. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant. Respectfully submitted, Date: Koren Hammons Pro Se 22 Park Street Mt. Holly Springs, PA 17065 (717) 486-7907 VERIFICATION Upon my personal knowledge or information and belief, I hereby verify that the facts averred in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements or averments therein made will subject me to the criminal penalties of 18 Pa. CS. Section 4904 relating to unswom falsification to authorities. Date: O/ /OQ /0/ Koren Hammons 3 KOREN HAIVIMONS Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. SHAWN HAMMONS Defendant : Divorce AFFIDAVIT KOREN ItAMMONS, being duly sworn according to law, deposes and says: 1. 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. 2. I understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Be'mg so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I understand that false statements here'm are made subject to the penalties of 18 Pa. C.S. Section 4909 relating to unsworn falsification to authorities. Koren Hammons 4 KOP~N HAMMONS, Plaintiff SHAWN HAMMONS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01-774 Civil Divorce Praeclpe to Reinstate Complaint TO PROTHONOTARY: Please re-instate the attached Complaint in Divorce. Respectfully submitted, REICHARD LAW OFFICES, LLC. Carrie M. Bowmaster, Esquire Attorney I.D. No. 70226 Reichard Law Offices, LLC. 70 West King Street Chambersburg, PA 17201 (717) 267-2288 Attorney for Plaintiff KOREN HAMMONS Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. SHAWN HAMMONS Defendant :NO'O/-77q : Divorce NOTICE TO DEFEND AND CLAIM RIGHTS YOU ItAVE 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 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, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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 TH/S PAPER TO YOUR LAWYER AT ONCE, IF YOUDO 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. Pennsylvania Bar Association Lawyer Referral Service P.O. Box 186 Harrisburg, PA 17108 Telephone: 1-800-692-7375 (PA Only) or (717) 238-6715 KOREN HAMMONS : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA rs, : NO. SHAWN HAMMONS Defendant : Divorce COMPLAINT DIVORCE UNDER SECTION 330I (C) OR 3301 (D) OF TIlE DIVORCE CODE. 1; Plalntiffis Koren Hammons, has no permanent residence, but a mailing address of 22Park Street, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. Plaintiff has resided in Cumberland County for at Feast the I~as~ year. Z Defendant is Shawn Hammons, who currently resides at Molly Pitcher Hotel, I[7 South Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013 since approximately November' 2000. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months mediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 18; 2001Yin CarlisIe, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiffhas been advised of the availability of counseling and the fight to request that the Court require the parties to participate in counseling. 8. The Defendant is not a member of the Armed Services of the United States or any of its Allies. are; 9. The causes of action and sections of the Divorce Code under which Plaintiffis proceeding A. Section 3301(c): The marriage of the parties is irretrievably broken. After ninety (90) days have elapsed from the date of filing this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiffbelieves that Defendant may also file such an Affidavit. B. Section 3301(d): The marriage of the parties is irretrievably broken. The Plaintiff and Defendant separated on May 30, 2000. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree in Divorce, divorcing Plaintiff and Defendant. Respectfully submitted, Date: Koren Hammons Pro Se 22 Park Street Mt. Holly Springs, PA 17065 (717) 486-7907 VEP. IFICATION Upon my personal knowledge or information and belief, I hereby verify that the facts averred in the foregoing Complaint are true and correct to the best of my knowledge, information and belief I understand that false statements or averments there'm made will subject me to the criminal penalties of 18 Pa.C.S. Section 4904 relafmg to unswom falsification to authorities. Date: O I /OC~ lO/ Koren Hammons 3 2025 E. Main Street Post Office Box 8 ~Vaynesboro, PA 17268 717-762-1131 717-267-3006 FAX 717-762.8800 REICHARD LAW O CES, LLC. The Fort Chambers Bldg. 70 W. ~ Street Suite B Chambenburg, PA 17201 717-267-2288 FAX 717-267-1151 KOREN HAMMONS Plaintiff VS. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. SHAWN HAMMONS Defendant · Divorce AFFIDAVIT KOREN HAMMONS, being duly sworn according to law, deposes and says: 1. 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. 2. I understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4909 relating to unswom falsification to authorities. Koren Hammons 4 TN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY~ PENNSYLVANTA KOREN HAMMONS, PLAI'NTTFF SHAWN HAMMONS, DEFENDANT CI'VZL ACTI'ON-LAW NO. 01-774 TN DZVORCE NOTTCE OF ELECTTON TO RETAKE MATDEN NAME Notice is hereby given that the Plaintiff in the above-captioned matter, having been granted a Final Decree in Divorce from the bonds of matrimony on 22nd day of October, 2001 by the Court of Common Pleas of Cumberland County, Pennsylvania, a copy of which is attached hereto, made part hereof, and marked Exhibit "A", hereby elects to retake and hereafter use her maiden name of Koren Sease. Koren Hammons, Petitioner To be known as: Koren Sease Commonwealth of P_ennsiylva. nia County of F-r~P~n personally appeared Koren Hammons, to be known as Koren Sease, known to me, or satisfactorily proven to be, the person whose name is subscribed to the within instrument and acknowledged that she executed the foregoing for the purpose herein contained. TN WTTNESS WHEREOF, ! have hereu~set my hand and o~ficia~ seal. NOTARIAL SEAL DAWN M. SHUGHART, Notary Public Carlisle, Cumberland County . ,,My ,Commission Expires Nov. 28, 2002 IN THE COURT OF COMMON KOREN HAMMONS OF CUMBERLAND COUNTY STATE OF PENNA. NO, 01-774 PLAINTIFF VERSUS SHAWN HAMMONS PLEAS DEFENDANT DECREE IN DIVORCE AND NOW, October 22, 2001 , IT IS ORDERED AND DECREED THAT KOREN HAMMONS , PLAINTIFF, AND SHAWN HAMMONS , DEFENDANT, 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 BY THE COURT: /s/ Edgar B. Bayley ATTEST: CERTIFIED COPY ISSUED OCTOBER PROTHONOTARY 2001 KOREN HAMMONS : 1N THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. :NO. o l- C, r, I SI-lAWN HAMMONS Defendant : Divorce AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Complaint was filed on February 1, 200.1 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry ora final decree in divorce a!~er service of Notice of Intention to Request Entry of the Decree. I verify that the statements made in this affidavit are true and correct to the best of my knowledge, information and beliet~ I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: Koren Hammons IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KOREN HAMMONS, PLAINTIFF -v$- SHAWN HAMMONS, DEFENDANT CIVIL ACTION NO. OZ-774 IN DIVORCE a v.m. AFFIDAVIT OF CONSENT Complaint in Divorce under Section 33o1(C) was filed on February 1, 2OOl. The marriage of the Plaintiffand 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 as I have waived notice of intention to request entry of a divorce decree under Section 33o1(C) of the Divorce Code. I verifythat the statements made in this Affidavit are true and correct. I understand that false statements made hereunder are subject to the penalties of ~8 Pa. C.S. f49o4 relating to unsworn falsification to authorities. Date: ~ -~ 'Ol ,2001 ~l.~~' Shawn Hammons, Defendant KOREN HAMMONS : 1N THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. :NO. SHAWN HAMMONS Defendant : Divorce WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 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 fights concerning alimony, division of property, lawyer's fees or expenses if! 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 document are true and correct to the best of my knowledge, information and belie£ I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Koren Hammons IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KOREN HAMMONS, PLAINTIFF SHAWN HAMMONS, DEFENDANT CIVIL ACTION NO. 01-774 CIVIL IN DIVORCE a v.m. _WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SEC. 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 ifI 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. Sec. 4904 relating to unswom falsification to authorities. Date:7"'a~, 9 -O/ 2001 .OaO~.~l,~ ~J/~~ Shawn Hammons, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA KOREN HAMMONS, PLAINTIFF CIVIL ACTION-LAW NO. 01-774 CIVIL SHAWN HAMMONS, DEFENDANT DIVORCE CERTIFICATE OF SERVICE I, Kathy A. Bamhart, for Carrie M. Bowmaster, Esquire, attorney for plaintiff do hereby aver that a true and attested copy of the Complaint in Divorce in the above-captioned matter was served on the defendant, by certified mail, return receipt requested, as evidenced below. Date: Septemberj~, 2001 Kath~ A.UBarnhart For: Carrie M. Bowmaster, Esquire Reichard Law Offices, LLC Attorney for Plaintiff · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Pdnt your name and address onthe reveme so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: 2. Article Nu B. Date of Delivery C. Si0p u ~.~ ~ I-1 Agent X [] Addressee D. Is delive~ address diffe*ent frern item l? []Yes If YES, enter delivery address below: [] No 3. Service Type ~ Certified Mail [] Express Mail [] Registered [] Return Receipt for Merchandise [] Insured Mail [] C.O.D. 4. Restricted Delivery? (Extra Fee) /~ Yes ps Form 3! 3-M-0952 KOREN HAMMONS Plaintiff VS. SHAWN HAMMONS Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Ol-77q cro;t : Divorce AND NOW, this O~ day of IN Forma Pauperis is granted. Order ,200I, the Plaintiff's Motion to Proceed By the court, ~ (,J. KOREN HAMMONS Plaintiff 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SHAWN HAMMONS Defendant : Di¥ore~ Petition to Proceed In Forma Pauperis I am the Plaintiffin the above matter and because of my financial condit~n an~lnab~ to pay the fees and costs of prosecuting or defending the action or proceeding. 2. I am unable to obtain funds from anyone, including my fanu~[y and associates, to pay the costs of litigation, I have not hired an attorney and am proeeedingpro se. represent that the information below relating to my ability to pay the fees and costs is tree and correct: (a) Name: Koren Hammons Mailing Address: 22 Park Street, Mt. HollY Springs, PA 17065 (b) Employment (I) If you are presently employecI, state Employer: N/A Address: Salary or wages per month: Type of work: (2) If you are presently unemployed, state: Date of last employment: October 2000 to December 2000 Salary or wages per month: $1,040.00 gross per month Type of work: Burger King (c) Other income within the past twelve months Business or profession: Other self-employment: Interest: Dividends: Pension and annuities: Social Security benefits: Support payments: Disability payments: Unemployment compensation and supplemental benefits: Worker's Compensation: Public Assistance: Other: (d) Other contributions to household support (Wife) (Husband) Name: None If your (wife) (husband) is employed, state Employer: Salary or wages per month: Type of work: Contributions from children: Contributions from parents: Other comributions: (e) Property owned Cash: $0.00 Checking account: $0.00 Savings account: Certificates of deposit: Real estate (including home); Motor vehicle: Make Cost Stocks or bonds: Other: (f) Debts and obligations Mortgage: Rent: Loans: Other: Fines - approx. $200 (g) Persons dependent upon you for support (Wife) (Husband) Name: No one Children, if any: None Other persons: None Year Amount owed __ 4. I understand that I have a continuing obligation to inform the court of improvement of my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in the affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. 2025 E. Main Street Post Office Box 8 Waynesboro, PA 17268 717~762-1131 717.267-3006 FAX 717.762-8800 REICHARD LAW OFFICES, LLC. The Fort Chambers Bldg. 70 W. King Street Suite B Chambetsbutg, PA 17201 717-267-2288 FAX 717.2674151 / KOREN HAMMONS, Plaintiff VS. : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 01-774 Civil SHAWN HAMMONS, Defendant TO THE PROTHONOTARY: : Divorce PRAECIPE Please enter the appearance of Carrie M. Bowmaster, Esquire of Reichard Law Offices, LLC., as counsel for Plaintiff in the above-captioned action. Respectfully submitted, REICHARD LAW OFFICES, LLC. Date: Carrie M. Bowmaster Attorney for Plaintiff Reichard Law Offices 70 West King Street Chambersburg, PA 17201 (717) 267-2288 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KOREN HAMMONS, PLAINTIFF SHAWN HAMMONS, DEFENDANT CIVIL ACTION-LAW NO. 01-774 CIVIL DIVORCE PRAECIPE TO TRANSMIT RECORD TO: 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 Section 3301(C) of the Divorce Code. 2) Date and manner of service of the Complaint: The Complaint was filed on February 1, 2001, and served on the Defendant on May 21, 2001, by certified mail, return receipt requested. 3) The date of execution of the affidavit of consent required by 3301(C) of the Divorce Code: By the Plaintiff on October 5, 2001. By the Defendant on September 29, 2001. The affidavits were filed simultaneous with this Praecipe. 4) The date of execution of the waiver required by 3301(C) of the Divorce Code: By the Plaintiff on October 5, 2001. By the Defendant on September 29, 2001. The waivers were flied simultaneous with this Praecipe. 5) Related claims pending: none. Carrie M. Bowrnaster, Esquire Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF KOREN HAMMONS PLAINTIFF PENNA. NO. 01-774 civil VERSUS SHAWN HAMMON$ DEFENDANT DECREE IN DIVORCE AND NOW, "~'~")'~;f iT IS ORDERED AND DECREED THAT KOREN HAMMONS AND SHAWN HAMMONS ,PLAINTIFF, ,DEFENDANT, 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;~OiI~; ATTEST: PROTHONOTARY