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Home My WebLink About95-02560 ~ ~ 'I ! II I I' I ,I , i . I . ~ 1 , I I J I I J b , I 1 , , I, I ~ 3 'I, " . 1 , I , ' ,'!I IN TH~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLV AN tI\ (f) /,,',j /I ... ',I; rll'95 I ,;:1),. 'Ii'; DIVORCE COMPLAINT , \1':' I, Iii' II 1'1, , , I 1 , I I , Ii. , I , , I, 'I '. I, ,I I' I f;'i'l.! KENNETH E. WEAVER, plaintiff v. 11>'0 r' .f.&. 5.tJ{J /' ~ /.s:- (JIJ ~,c.:7'f I r:'tM.J ~ORENE L. WEAVER, Det'en<lant I, CIVI~ ACTION - LAW c;I..,; ~.)~(/ ,erIf- ,.) !/ J V3 , , Ii, I' 'j , '1', " , I I I, , , , , , I " 'i" I I '^\lI'1fIKl.I O'BRIEN. BARIC. SCIIERER ,~~ lOOn' I/^NOI1J\ mn r CAI\lI5IJ., ,{NNIYLVANIA 11013 ,;1 I" '1'1 I, I >/1 :, '11 I,; " I 'I ,I I;' KENNETH E. WEAVER, I IN THE COURT OF COMMON PLEAB OF plaintitt I CUMBERLAND COUNTY, PENNSYLVANIA I VB. t CIVIL ACTION - r,^w I NO. 96- CIVIL TERM LORENE L. WEAVER, I Defendant I IN DIVORCE COMPLAIN'l' UNDER SEC'I'IONS 33011CI liliD. 3301(0) OF 'l'HE DIVORCE CODE 1. Plaintiff is Kenneth E. Weaver, an adult individual who currently resides at R.D.H2, Box 40A, Loysville, Pennsylvania, 17047. 2. Defendant is Lorene L. Weaver, an adult individual who currently resides at 3703 Enola Road, Newville, cumberland county, Pennsylvania, 17241. 3. plaintiff and Defendant have baen bona fide residents in the Commonwealth of pennsylvania for at least six months immediately previous to the filing of this Complaint. 4, The Plaintiff and Defendant were married on in Cumberland county, Pennsylvania. ~ DIVORCE Plaintiff hereby incorporates by reference avermentB 1 through 4 as if each averment were set forth fully hereunder. 6. There have been no prior actions of divorce or for annulment between the parties as to theJ.r current marriage. 6. Neither Plaintiff nor Defendant is in the Armed Forces of the United states. 7. Plaintiff avers that the marriage between the parties is irretrievably broken. Q. The Vlnintiff hRa beon advised of the availability of coun.elinq nnd thnt ho mny have the right to request that the oourt require tho pRrtlQa to participato in counBeling. ~. Vlalntlff avors in the alternative that Defendant/ in violation or her marriago VOWB and of the Laws of the commonwoalth of I~nnsvlvonla, has offered Buch indignitieo to the parson or the V1Rlntlff, her injured and innocent spouse, as to render the condition of the l'laintlff intolerable and life burdenaome. 10. ThlB action ia not collusive. ~QVli~-Il - DIVISION OF PllOPEB~ l'lalntlff hereby incorporates by reference all of the averment. contained in Count 1 of thia complaint. 11. The partieB have acquired home furniBhings, motor vehicle., bank accounts, and miscellaneous items of perBonal property. 12. The Oefendant Wife haB title to real eotate which haa appreciatd in value due to the efforts of the Plaintiff and whioh ghould be distributed ~quitablY, 13. The aforeBaid items are marital property and the Plaintiff requests that they be equitably divided. WHEREFORE, Plaintiff prays that a decree be entered in favor of the Plaintiff and against the Defendant as follows: a) That a decree in divorce be enteredl b) That the herein described marital property owned by the Plaintiff and Defendant be distributed according to lawl v. IN 'l'HE COUll'r 01;' eOMMON Pl,EM OF CUMB6RLAND COtJN'l'Y, I?BNNSVl,vANIA 95-2560 CIVIL TERM KENNE'rH E. Wli:lWER, Plaintiff LORENE L. WEAVER, Pefendant I IN PIVOReE P~f/J:'V r.r.FFJ .,1'''''Mft'lt' ArrIDAVIT 0' CONSIDI'T, ACCIPTANCI 0' SlaVICI AND WAlvaR 0' NOTICI 0' INTINTION TO alQUlST .-TRY 0' DIVOaCI DICal1 UNOI. SICTION 3301(C) 0' TUB DIVOaCI COOl 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on May 11, 1995, 2. Defendant Ackn.:>wledges receipt and accepts Bervice of the eomplaint on 3. The marriage of. the Plaintiff and Defendant is irretrievably brol<en and ninety days have elapsed from the date of the filing of the Complaint, 4. 1 consent to the entry of a final decree in divorce without notice, 5. 1 understand that 1 may lose rights concerning alimony, division of p~operty, lawyers fees or expenses if I do not claim them before a divorce is granted, 6, I understand that I will not be divorced l;ntH 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, 7. 1 have been advised of the avaHab,i.J.ity of marriage counseling and understand that I may r~quest that the court require counseling. 1 do not request that the court require counseling, 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, Section 4904 relating to unsworn falsification to authorities. Date; '1--/ '5"-1? ___2.____..._._______. . /' ,...I: I(l~ ~tj[ t:(/~ _....l<'~~...,,-._""""--,,-..---,-.-,-- KENNETH E, WEAVER I " ".1 i" '. 'I'! I " , , , ',i1 I, .. I I I ".. , .1 " ~ENNETH E. WEAVER, PlIl inti ft v. IN 'l'IIE COURT OF' COMMON PLEAB OF CUMBERI,AND COUN'l'V, PENNSYLVANIA 96-2560 CIVIL TERM LORENE L. WEAVER, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF OONSENT, AOOEPTANOB 0' SIRVICI AND "AlVER or NOTIOE or INTIlNTION TO REQUBST INTRY 0' DIVOROI DIORII UNDBR SECTION 3301(0) or THe DIVORCI COOl 1. A oomplaint in divorce under Section 3301 (C) of the Divorce Code waa filed on May 11, 1995. 2. Defendant acknowledges receipt and accepts service of the complaint on 3. The marriage of the Plaintiff and Pefendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree tn divorce without notice. 6. 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. 6. I understand that I will not be divorced until a Divorce Pecree is entered by the eourt and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseLing. I do not request that the court t'equire counBeling. 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 IB Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Dilts I J I:n)rn I I (I ~LL ,( (j)~1.IJ<A LORENE L. WEAVER " I' " " ]'1 " ( 'I Ir,l ".) L ...., '" '-'Il" ~'r. I liP , 11 ,,,I " ~ ,I ,I ., "l " ,..,'.' .,1 1/) I:' I 'j " " ! i') , 1 III " .. 'I} ,- (" , " ~ ", " KENNETH E, WEAVER, Plalnllff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION, LAW NO, 95,2560 CIVIL TERM VIS, LORENE L WEAVER, Defendlill1t I CERTIEJ.QATE Of SERVICj; ,. Robert L. O'Brien, Esquire, allorney for Ihe Plalnllff In the above,oaptloned divorce BCtlon, do hereby cerllfy that I served a cerllfled copy of Ihe Complaint In Divorce to the Defendant on May 16, 1995, as per Iho allached U,S. Postal Service Certified Mall, return rocelpt card, O'BRIEN, BARIC & SCHERER BY r ~~ , Robert L, O'Brien, Esquire DATE: I , , I