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Home My WebLink About98-05307 ,,, "I' , " H " " I' " I." " Icl, " " " H " " H " Ii I " " .. , " " I ~ " .'.;i' I jl cj "j " I , ,j, , " " 1".1 , I" ","~ I'! I ~ " i " "1'0 " " " ~' t'; I' " Q IV " '1 "I' l,li " '1' , " \ " '111 " \ " , " , ;; , " \ , " " , " \ " '1' H " " ! 'I, " " ,," " I "j. !-''' , I I' I' I " If " " '1 "j' I " " I; " 1'1' " ! .,i , , , <I' ,. ,.. Ii " 'I; " H .." " " ,I " " " " " l'. " I! , " 1/; " I' ,i I". " ., d",; , " " " , " , " , " ( ... ~ " " " .....' . , .2 i dj \.'-, /;;II ~I ~I I l~1 ~! I ~I .... "i' Ii " fi ,. " " ,I' Ie " " I.' 'II " " " Ii ." " 11I('l'HY HIJI1,COY, Plnlnlllf \ Tlwn1\JIt'\'OF!'OMMPN P\MHIW \ CIIMIW.\~I.I\NI) C( l\ JNTY, I'1.lNNHYLYi\NIi\ ,. Viii , I : Nil, \l)llll.~;H1H'IYII.THI~M IWNNIf-i It COy, ,lit, , \l~liln\11I111 . , i l.'\YlI,I\CTION. M I,^W : PIY()IUT (..:!m:CUI'I( 'A,\,V IW Hl1UV\( !I': 1".101111\11\ I" CIIHIllpl1l1lllH, HH\\\llro, lwrob~ con11r 111111 Ihltllhl)' I Horvod II Ol1p~ Ill' tho , 1I11110ho\1 \hl0\ll\1Ul1ll1pllll I\W porHllll, 1111\11\\ tho I1HIIlIWI"ll1Illolllcll Iwlllll', wlllch Hol'vl~o HI\IIHlioH Iho l'oqllll'OIlWl1\H Ill' IIw PI\ HII,loH Ill' ch'lI P1'1l00\hll'o, h~ IlopoHlIll1U II Ollp~ Ill' Iho HII\110 wllh 1110 \1\\110\1 HIII\OH PI1H\ ot'l1oo III McchllllloHh\II'lI, POllllHylvlIl1ll1,lhnlllUh I1I'HI ~hIHH \111111, pr~plllil,nlld lllllh'OHHOd IIH 1'1l\lI1I1'H; 11I1rnl\Il'l, \1'11'111, \II, HHqlllro M HI1Il\h 1'111 Rll'cOI ' . C!II'\IHlo, 1'1\ I'/ol~ I' it ',' /..2/1 ?/~- )^TH: - - " BETSY SUE COY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION—LAW DENNIS R. COY, NO. 1998-5307 CIVIL TERM Defendant IN DIVORCE c PRAECIPE FOR ENTRY OF APPEARANCE -o Cr, To the Prothonotary: �= C'.) (-) Kindly enter my appearance on behalf of the Plaintiff, Betsy Sue Coy. Date: 2- Micl1aef A. Scherer, Esquire 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 I.D. 61974 CERTIFICATE OF SERVICE I hereby certify that on , 2013, I, Lori Duncan, of Baric Scherer, did serve a copy of the Praecipe for Entry of Appearance, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Harold S. Irwin, III, Esquire 64 South Pitt Street Carlisle, PA 17013 ri Duncan BETSY SUE COY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION—LAW DENNIS R. COY, NO. 1998-5307 CIVIL TERM Defendant IN DIVORCE PRAECIPE TO WITHDRAW CLAIM OF EQUITABLE DISTRIBUTION To the Prothonotary: Kindly withdraw the Plaintiff's claims for Equitable Distribution raised in her Petition dated December 12, 2005 and in her Counter-Affidavit dated December 12, 2005. Date: ich el A. Scherer, Esquire 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 I.D. 61974 c c— w a - , M C =r f - ,C__ ,,,:) 1 CERTIFICATE OF SERVICE I hereby certify that on to �� , 2013, I, Lori Duncan, of Baric Scherer, did serve a copy of the Praecipe to Withdraw Claim of Equitable Distribution, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Harold S. Irwin, III, Esquire 64 South Pitt Street Carlisle, PA 17013 Lori Duncan BETSY SUE COY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1998 - 5307 CIVIL TERM DENNIS R. COY, JR., IN DIVORCE Defendant NOTICE OF ELECTION TO RETAKE MAIDEN NAME Notice is hereby given that the Plaintiff in the above matter, hereby elects to retake and hereafter use her previous name of Betsy Sue Kiner. ✓ prior to the entry of a Final Decree In Divorce or after the entry of a Final Decree In Divorce dated and gives this written notice avowing her intention pursuant to the provisions of 54 P.S.A. 704. . -5-�-� f- '�-0 1-3 Dated. Betsy Sue Coy TO BE KNOWN AS M z. 1-7,1— pka Betsy Sue Kiner Me c COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On thec-,P- d-ay of 2013, before me, a notary public, personally appeared Betsy Sue Coy to be know s Betsy Sue Kiner, 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 official seal. 20 11MONWEALTil OF pENNSYLVANL4 NO Hai ai a or,No ruste ro, rn nd Public ODunty COMM on C- 4 -)Iva/ 4 "es Oct.2,2014 13-04 ozo BETSY SUE COY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION—LAW DENNIS R. COY, NO. 1998-5307 CIVIL TERM Defendant IN DIVORCE M -<> PROOF OF SERVICE c— To the Prothonotary: c._ ry: p T-,,) CD c~ CI , I William S. Daniels, Esquire attorney who filed the complaint in the above captioned divorce action, do hereby certify that I served a certified copy of the Complaint in Divorce to the Defendant, as per the attached U.S. Postal Service Certified Mail, return receipt card. Date: William S. Daniels, Esquire 1 West High Street Carlisle, Pennsylvania 17013 (717) 243-3831 Law Office of William S. Daniels Humer& Daniels M &T Bank Building One West High Street- Suite 205 Carlisle, Pennsylvania 17013 Office, 717. 243.3831 Fax: 717. 243.5916 Z 332 883 757 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Don t use for International Mail See reverse ' Sent t Street �? ' &Nu r (46e� Po ce,State,&ZIP Code 02 Postage OF rA= $ i Certified Fee r 3 Special Delivery Fee' Restricted D ery 'l U) co Retu Re g to Whom 8 I CL Retum R y Q Date,&Add ee ddress" 0 TOTAL Post e& r J Postmark of Date SENDER ; ax CL w.i to receive the: • Complete,items 1i and/gr2'for, adOftional services.,•_ • Complete items 1, and 0'415: �`� EY�.CeS 1foF an extra v H) • Print,your,name and address on,the,reverse.of thi fo � g 2, . :return this card to you Add see's Address m Attach this form to the front of the mailpiece,o� the back if s ace D does not permit. =5.• W.rite"R:eturn Receipt Requested gn;the mailpiece. low.t Rest LCted D$IlVery m +' • The,R'eturn Receipt wAfishgw'to,whgm the:article w .Aeli�acwd a?d4kwd8 {� S ter,for.fee:. - �, C delivered. I 3 Article Addressed to 4a Articie Number 4b: Service Type �L t° E Registered ❑ Insufed cm, 1 Certified' ❑'CQD ❑ Express Mail ❑ Return Receipt for I.W i Merchandise, 0 1 7. Dafe:of D'elive /' { >. :. Z "8 Addressee s Address:(Only,,it requested x j 5 Signature (Addressee) a_nd fee is p,..eid) _; j )" rK F—. I6 `Signature Agent 0. PS F'or'm 381`1,,December;1'.99r1 itU.S..GP0:1892-323 402 D-OMESTIC RETURN' RECEIPT' • `j . BETSY SUE COY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA C") t7D V. NO. 1998-5307 CIVIL TERM C'= Z ZZ DENNIS R. COY,JR., CIVIL ACTION-LAW Defendant IN DIVORCE co S r-x 5C= 'Wo 4 NOTICE 11 �; 4 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 THE DIVORCE CODE 1. The parties to this action filed for divorce in 1998 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 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.§4904 relating to unsworn falsification to authorities. Date: May 24 , 201 3 Betsy Sue Coy BETSY SUE COY, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1998-5307 CIVIL TERM-oz ,�� rn_W DENNIS R. COY, JR. , Defendant IN DIVORCE r-x 3 � 3 n -v tD .,, ZZ CD PLAINTIFF'S AFFIDAVIT OF CONSENT ' AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF 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 September 11, 1998. 2. Defendant filed a counter complaint form on November 28, 2005. 3. The marriage of Plaintiff and Defendant is irretrievably broken 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 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. 1 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. 7. 1 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 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.A. Section 4904 relating to unsworn falsification to authorities. Date: May 24 , 2013 " Betsy Sue Coy BETSY SUE COY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYWANIA Vs. CIVIL ACTION - LAW MM M .. DENNIS R. COY, JR. NO. 1998-5307 Defendant IN DIVORCE - , M...-.i 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. Ground for divorce: irretrievable breakdown under Section 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: Plaintiffs prior.counsel, William Daniels, Esquire, served the Defendant with the Divorce Complaint via certified mail on September 21, 1998. Proof of service has been filed of record in this matter. 3. (complete either paragraph (a) or (b).) A. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: B. (1) date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce Code: Plaintiff initially filed a 3301c divorce. Defendant filed a "counter- complaint" alleging grounds for divorce under section 3301 d. Plaintiff filed a counter-affidavit agreeing to the divorce both on December 12, 2008 and May 24, 2013. (2) date of service of the Plaintiffs Affidavit upon the Defendant: December 12, 2008 and May 24, 2013. 4. Related claims pending: None. Plaintiff withdrew her claim for equitable distribution. 5.. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301(d)(1)(i) of the Divorce Code: On June 10, 2013, undersigned counsel served Defendant with a Notice of Intention to Request Entry of a Divorce Decree at his residence via first class mail and provided a opcy of the Praecipe to Transmit Record. Defendant received the notice because undersigned counsel received a phone call from Defendant confirming such. Respectfully submitted, Micfia eI A. Scherer, Esquire V i BETSY SUE COY, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION—LAW DENNIS R. COY, JR., : NO. 1998-5307 CIVIL TERM Defendant IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE To Dennis R. Coy, Jr. C/O Lashelle's Island Apartments 1582 Holly Pike Carlisle, Pennsylvania 17015 Betsy Sue Coy, Plaintiff, intends to file with the Court the attached Praecipe to Transmit Record on or after June 13, 2013, requesting that a final Decree in Divorce be entered. Date: Mic ael . Scherer, Esquire 19 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 I.D. 61974 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Betsy Sue Kiner f/k/a Betsy Sue Coy V. Dennis R. Coy, Jr. NO, 1998-5307 DIVORCE DECREE AND NOW, dO13 , it is ordered and decreed that Betsy Sue Kiner f/k/a Betsy Sue Coy , plaintiff, and Dennis R. Coy, Jr. , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be'deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None By the Court, Attest: J. - o Amp LO� Prothonota yco 76 ��