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Home My WebLink About95-04383 ., i J f: ~ J ('f) 00 c<) =J- \ LO IT ,.'t . ':~. ,:.c. .;c. ... ....... ... ... ...' ... ....:11I> ... .;c. .:11I> .r.:. ':11I> '>>:0 .:.c. .:.c.')c.rc<:~:"':;':III>:,'.: ....':.;c.. oQID('oQID(~ 8 -- & lJ ~ ~ e 8 8 e 8 e s ~ ~ ~ e ~ e IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF '* PENNA. ,..., , ~..q~ JIl\/oIf.IAKER" ."... '..'.."....)" II Plaintiff .j !I N (), ......~,!;i,'::~,~,!!~.. ......,.......... 19 VCI'SUB II II ......'...........,.. 'I il PEREl<.V..lWWIKER, " Defendant " ~ e ,;, ~ DECREE IN DIVORCE AND NOW. .. .. . (#n.l., .. .. .. .. .. ... 19?~..... it is ordered and decreed that ..~, ~~.~..... , ..... ................. plaintiff. and. .. .. .. , , , ..Q~ .v.~ ,~. . ,. , , , . ,. .. .. , . . , .. , .... . . '. defendant. are divorced from the bonds of matrimony, ;. .' ~ 8 ~ ~ e s e 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; M ... ~ ~. 8 e ~ ~ ~ e ~ 8 ~ ? ~---_. ,..:- ~. .:.:. .:.:. .:.: . none ,... .... '0 .......... .... ....... ....... .... ...... .,0 ,'0 .... II .............0. ...... .... ,. .... " " I!... . .~.. _ r.o .' ...:- : - ~. .... Atte~I:~~ [' ~ ~..,.#~~ J: ~nt K ~. fl.J!-. . , , '7 ""7";jl'rolhonotnry '-- - .' : - ...- . ~.. '."",,- - h....... .I" '~ ;##., 0".,"" .;'..,--....-. .. . ....':,='.. ." --4 .... '" ~ $ . 8 . * . - ~ . ~ . ~ . . ~ ~ . . g . e " ~ . ~ $ ~ ... . ~ e ,;, ;:< .', ~ 8 ,', ~ ~ ':> v ',' .~ /,.' I, t~ l~ " ..~_,~...,__.,_..,_ _. "__'~_'..._' _.~.~._..~.,~.-_ ,. ':it ~~~~~~****~*~~~~*~~~**~. . 1?.e;~ &d~~;J/ ~~,.~ 1/.tf1(, 71flia ~~4 o~ . . '. l':o/m~I:lt1~~;!,:,~',,~),:~>,;,.,:;;,:;y '" '-'-,'. ,', I'<;":<""'''''''.'C40,,",..', r" '. I f~rf1i::~ts:t=.i.,,:/~4Si.:... "~i;",, W "::j",11 iz..li!'NntYourniino............... Iho _. .'....._... ';:-.....-10101I. '. , , ' . ~f.,.Fa.~. '''.~t;7~:. ~::r::::~:,::.~Iho. H '... I.~II' ir2S;'~"':~~..._lovf"iolho_................ :/,f,:.3~,~"'V'.Add...1ld10: . ~,Attlcle umber I';" J~ f" c. .,..c;;., · '. Z 321 761 663 I",c, DBi:'eJc. V H.snnaker 4b, S'rvlce TVPt I,' "1622 WainutBottan Road o Reg/llored Olnourtd 'I:'~ r :"Carlisle PA 17013 BXConlrlod 0 COD ,:,' "'" , 0 Ell",... Mill 0 Rllum R_PI for ': " 7. DOl. of 0.11..,." . .. i 1< 'i- ~.Sf'" r---!; .' i...' - 8. AcId,_'o Acid.... lOnIy If r"'lUOOledl" ',' tnd foe 10 plld' . . . '., , !, , J:e., S/gnalU,o tAD.ml . :' I ~I~:;,;.;; ... .-..... -.,.. -- -.me ~ ~ji "",...",',...! ,", " ., ..., "" SAIDIS, GUIDO, SHUFF & MASLAND 26 W, Hlah SIt<<. Cull.,.. PA Exhibit "A" lA $e ai "U~P:! UDt"J:e. ~ S 1:0'''';: u..~~..J r.> .... - I \....f vt - .:':JI'r" -J;Z ;';'1 Cl.I... .,. (.D :JtaJ~t.J 4.~;).:,,,, - ~l g ~l..I' ~ .... Q Z :s ::l rIJ lii~a 8 ~~~~~ ~ GlS~:I:ffi!: li: OliloD:c o a 'XIIlIll ~ ~~,.:!1l~ ..J ,,0'......l:I: ~ :!l ~ 0. rIJ U - a ~ , . . >.. \n -- 'j-,., C'.l 1... i iJ:J ,.,~ u-'~ ~ t ).. ."' O' .~ -,)::'l~ F' ..~..: ,..,*j '.- cr- , ,I..': - '., c._~! C' --.. ~:;!~. , "~ e): (.~ .:\tn ~ c.- . '. i ,.;..::';' ,- \.'. ,n .5 1..) "" (.) \ l .. JENNIFER C. HAMMAKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 95- ~3r'J CIVIL TERM DEREK V. HAMMAKER, Defendant IN DIVORCE NOTICE 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 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 at the Cumberland County Court House, High and Hanover Street, 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 Court Administrator One Courthouse Square Carlisle, PA 17013 (717) 240-6200 _7 ,-Dei, , EsquJ.re SA~ ' GUI~O, SHUFF & MASLAND 26' est Hign Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff " SAIDIS, GUIDO, SHUFF &. MASLAND 26 w, Hlab Slteet c.rJlal.. PA JENNIFER C. HAMMAKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 95- CIVIL TERM DEREK V. H~~KER, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301/cl OR 3301/dl OF THE DIVORCE CODE 1. Plaintiff is Jennifer C. Hammaker, who currently resides at 32 W. High Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Derek V. Hammaker, who currently resides at 1622 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania l70l3. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 29, 1990, Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling, Having been so advised Plaintiff does not desire the Court to order counseling, 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce, COUNT II 8. The allegations in paragraphs one through seven, inclusive, are made a part hereof and incorporated herein by reference. g. The Plaintiff alleges that in violation of the marriage vows, the Defendant has over a period, in Cumberland County, offered such indignities to the person of the Plaintiff as to render her condition intolerable and life burdensome. 10. This action in divorce is not collusive. 11. Neither party to this action is a member of the armed forces of the United States of America. WHEREFORE, Plaintiff prays Your Honorable Court to enter a ,decree of divorce in favor of the Plaintiff and against the Defendant on the basis of indignities. Respectfully submitted, SAIDIS, Jo Dated: <g<1J:'t5 Attorney for Plaintiff SAlOIS, GUIDO, SHUFF '" MASLAND 26 W, Hi,h Slm:1 Carlisi., PA JENNIFER C. IW+IAKER. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. CIVIL 1995 DEREK V. IW+IAKER'Defendant IN DIVORCE AFFIDAVIT I, Jennifer C. Hamnaker., being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counselling and understand that I may request that the court require that my spouse and I participate in counselling, (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 counselling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of l8 Pa, C.S. Section 4904 relating to unsworn falsification to authorities, ! SAIDIS, GUIDO i '" MASLANO i 26 W, Hilh Sir.,.. ! Carlhlc. PA Dated: 't-I-QS ~.~~~^~ ifer . , aintiff ~ JENNIFER C. HAMMAKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 95-4383 CIVIL TERM it- v. DEREK V. HAMMAKER, Defendant IN DIVORCE AFFIDAVIT OF CONSENT (1) A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on August l6, 1995, (2) The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint, (3) I consent to the entry of a final decree of divorce, (4) 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, 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. Dated:~5J /q9& \~..,~ L.~mrL~ ni r C, Ha ker, laintiff SAlDIS, GUIDO, SHUFF &. MASLAND 26 w, Hlah S"'l c...U.le. PA ii: 4' -- N f_ .' ',," ~8 Ci:J ~~J~ ,':)-'" Z': .)% C <f. ~ ..::: 2~ '- .::r (, ,'- I ,)... .-Il' 1'':: :HLiJ CI:< C'.. f.'. 0::: ~..:.:; .u... tl. U) 5 u en Q JENNIFER C. HAMMPJ<ER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW v. NO. 95-4383 CIVIL TERM CIVIL ACTION-IN DIVORCE DEREK V. HAMMAKER, Defendant AFFIDAVIT OF CONSENT 1. A complaint in Divorce under section 3301 (c) of the Divorce Code was filed on August 16, 1995. 2. The marriage of plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing 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. 4. 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 prior to a divorce decree being handed down by the court. 6. I am not a member of the armed forces, nor in active military service, of the United states of America or the commonwealth of pennsylvania. 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 .utho"t'e~~ a~,,~ " __A__-L DEREK V. ER Date: .3/2J, (Cfb ,.:..,'.c;'~''''',.'':.>.'f.\.,,^ "",{:-,.;"""........'.i;f .~..... .... ~..",- lE..,. f::~:: UO:; --':-.1 '1" ;~jC, c%:, ")~...:j If'" -~j~~ .,;": :_-",_~;.o... r~ <,~." ...:" '.,'1 ?'<...,.. :l. ,...... o.c..;o;"':l,,~ <.';"..:t'_ +... I" r.' '_" L u ~J ..L ~~. ~St~u. ~. ~ f3 ~.. JENNIFER C. HAMMAKER, Plaintiff I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I 95-4383 CIVIL TERM v. DEREK V. HAMMAKER, Defendant IN DIVORCE AFFIDAVIT OF CONSEN'l' AND WAIVER OF NOTICE OF INTEN'l'ION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1, A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 16, 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint, 3, I consent to the entry of a final decree of divorce without notice, 4. 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, 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 SAID IS, GUIDO, SHUFF & MASLAND 26 W, "11h S...., Cadi. Ie. PA 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, Section 4904 relating to unsworn falsification to authorities. DATED: mQ/llVvl5 , IQ9l- ... ..::1' '- f:: (... N ,. ,~ i: 8 -i _ ~!: . ...... )~... .- -)::! c..;.i ".,\~ EEi .~ ~, -. '~fil " .';........... u:'-- I -':1''"'.'' -1j , r~ "l ltc' co. ....,w,.. ".. f-" -;., " .' v') '") C <.' [l DEREK V.HAMMAKER, Defendant NO. 95-4383 CIVIL ACTION-IN DIVORCE JENNIFER C. HAMMAKER Plaintiff . . . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW v. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER S3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the court before the entry of a final decree in divorce, the right to claim any of them will be lost. 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. Section 4904, relating to unsworn falsification to authorities. Date: ~~qlD J2-,~ t/ d~...,J,~ DEREK V. HAMMAKER >- ..:l' ;0- cr r- N :...:..; ~;;.; CO . 1_ ',:!~'l IF . . _.,J :.;~ :..:. ~. -,': o~. :;:: c," -, ';'1) =.j' I ]:;2: II: " n... l,b , ~,- '71~1.. I ....0. " '" ~:; (j c"\ !R ~ {Il e >. ':it: .-...~ "'\'lI ::a4f u,.~..;; l~l,,(,.t.i t~"':;I~'~ ~~:.I.;o'J &:"1/;':::;\ ~"f'i:~~ . .1#,1...... ~',:,:" ..; ~ 1:! ...~ &.. :", ....,(~ '-0 - g - Q Z :s .., ~ !ii~a ffl ::s~~<~ u ~""!i;z~ fE o~:cffi;:::, o lQoo.;: ~ ac:iX~~ :s 8p.;:i:!o ~e>::C rii <0. _ u Q - < tIJ J '. .. ". .' , " JENNIFER C. HAMMAKER, Plaintiff V. DEREK V. HAMMAKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 95- '13$3 CIVIL TERM . . : IN DIVORCE ATTORNEY'S AFFIDAVIT SUPPORTING PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS I, Johnna J. Deily, Esquire of Saidis, Guido, Shuff & Masland, attorney for the party petitioning to proceed in forma pauperis, certify that I believe petitioner is unable to pay the cost of instituting this action and that I am providing free legal service to petitioner. Plaintiff's Affidvait showing inability to pay the costs of litigation is attached hereto. Date R -9-cr;- SAlOIS, GUIDO, SHUFF & MASLAND 26 w, Hi&h S_I c.vlillc. PA , ., : JENNIFER C. HAMMAKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 95- CIVIL TERM : IN DIVORCE V. DEREK V. HAMMAKER, Defendant AFFIDAVIT SUPPORTING PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS TO THE HONORABLE JUDGES OF SAID COURT: The petitioner, Jennifer C. Hammaker, residing at 32 West High Street, Carlisle, Pennsylvania, Cumberland County. 1. I am the named Plaintiff in the above action and the Defendant is Derek V. Hammaker. 2. This affidavit is made to inform the Court as to my status of indigency and to induce the Court to grant me leave to proceed in this cause as an indigent. 3. In making this affidavit, I am aware that perjury is a felony and that the punishment is a fine of not more than $3,000.00 or imprisonment for not more than seven years or both. 4. I do not have any money on my person, at home, or elsewhere which could be used for the expenses of this proceeding. 5. I do not own real estate, personal property, or any other assets. I am not owed any amounts of money by any person. SAlOIS, GUIDO, SHUFF &: 6. My husband, Derek V. Hammaker, presently resides at 1622 MASLAND 26W,III&/lSu..1 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania Carli. I.. PA 17013. He is 23 years old. a) I last lived with my husband on June 1l, 1995 after which time I moved out. b) I do not have information or knowledge as to whether my husband is employed, has any money, owns an automobile, owns real estate, or has any other personal property or assets. c) I have not brought action for child support payments because at the present time there is a shared custody order, and neither party is paying support. 7. I have a shared custody arrangement for Cody, D.C.B. 12- 21-90 and Tyler D.C.B. 6-22-93. 8. I am presently unemployed because the care of my young children requires my presence at home. I have not worked since the children have been born. 9. My social security number is 199-60-6060. 10. I have the following monthly income of $0.00. 11. My monthly expenses are as follows: (shared with a roommate) groceries, and for the care of my children. 12. My husband and I have not maintained a checking account throughout our marriage. 13. I do not own an automobile. unsworn falsification to authorities. WHEREFORE, petitioner pray. that this Honorable Court give petitioner leave to proceed in fanna pauperis in the above titled action without fee or cost to the petitioner. Date 8-q - q5 ~..,~, \\n.'n~ IN THE COURT OF CO~l!"ON PLEAS OF CU:'lImIlLANIl COU~TY, PE~NSYLVANIA CIVIL ACTION - LAW JENNIFER C. HAMMAKER Plaint if f ~O, 95-4383CIVIL TERM VB. DEREK V. HAMMA~~indant ACTIO~ [~ DIVORCE NOTICE OF ELECTIOX TO RETA!:t: FO~IER :~AME Notice is hereby given that the Plaintiff in the above matter. having been granted a Final Decree in divorce from the bonds of matrimony on the 9th day of April , 19 9~ hereby elects to retake and hereafter use her previous name of JENNIFER C. CAREY To Be Known As: ~l"~~ l.~~~r~)\ ~N ER C. H MAKER ~""~\-" C e (Hu l ~ NN ER C. CAREY COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND , On the 15,th day of ADril , 19 96 , before me, a Notary Public. personally appeared Jenniter C. Hammaker * ,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 my hand and ~lotari3l Seal. c;/ttU~dmirL ~OTARY PU3LIC - NOTARIAL seAL JOAN e, SMITH, tlOTAIlI' Pue~~ ,,, l)ARUSLe IlOROUGH, CUM8ER~ _ 101'I' couu1ll5l0N EXPIRES IoIAAClt Do * TO BE KNOWN AS JENNIFER C. CAREY ......... , '. ~ , , ! --,- J ""'.'-... ~ ~ ~ \ L'- C') - .,. f"'< ~ U,C ~ 0: or...,:" fc.., ,...... 4.~ ~ ,-, 0' f.:'- ~',~ 1"- , , ~ :.:.."i Cj' r- 'Y) 1:.'. ~ ;':':; -. L:\ ~ c:.:. , ~. . '. ~ . - :lJ r~ ~ l' ~.- L' \-., ..j "U "- (---,