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Home My WebLink About00-06974 ,( . . . , I: , , j; ,. ~ ~~~~ ~ ~~~~~ ~~~~ ~ :';"'''':f. :Ii Of.;t: , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , , , , , , , STATE OF , , , , , , , JENNIFER MCCOY, Plaintiff , VERSUS , , JONATHAN MCCOY, Defendant , , , , , PENNA. No. 2000-6974 DECREE IN DIVORCE , AND NOW, f.\U()uJ ry JENNIFER MCCOY , '2.00 \, IT IS ORDERED AND , DECREED THAT , PLAINTIFF, AND JONATHAN MCCOY , 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. , , , , , J. , , , , ""-'tJ , , , , , , . , . . . , , , . . , , , , , , . . . , , . . . . , , , , . . . . . . , , , , , , , , , , , . , , . . . , , , . . . . . . . . . . . . . , , , , ., II I ~I I: ~ I , 1 ,j I I I' ~ ~ ' , , :" ~, <~' < ,"- ".., ~ ~~,"'-:-'"'"' 'if '<t '01 fl"!)! ", ~ ~ ' " "'. '" 1 ~. r~'. ". . . , \"~'i ~:"r- . .. '.. ~\,- 1:' ',,~ , . (L-l~ ~ -d; 4U# ~~ J:4fi~ .,,"__ "',_ 1JT ,.~J,lllll~J.!I!Mr_~~~ =~,~", ,~~~ _~_".~,.,,,U"""!JJ~",~,, ,w,-'~:,,~ ~~"" j I ~"'......' '" . , JENNIFER MCCOY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00-6974 CIVIL TERM JONATHAN MCCOY, Defendant : CIVIL ACTION - LAW : IN DIVORCE 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 S 3301(c) 33€11(d) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint. Service was made on October 19, 2000 by certified, restricted mail signed for by the Defendant. 3. (Complete either paragraph (a), or (b).) (a) Date of execution of the Affidavit of Consent required by S 3301(c) of the Divorce Code: by the Plaintiff: July 5, 2001; by the Defendant: August 1, 2001. (b) (1) Date of execution ofthe Plaintiffs Affidavit required by S 3301(d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit upon the Defendant: 4. Related claims pending: None 5. (Complete either (a) or (b); (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, and a copy of which is attached: (b) Date of execution of the Waiver of Notice of Intention to File Divorce Decree as required by S 3301(c) of the Divorce Code: by the Plaintiff: July 5, 2001; by the Defendant: August 1, 2001. Date: August 6, 2001 omas S. Diehl, Esquire Attorney for Plaintiff 1iiliilB!1l_lIli~iWliHiliitttl])_-~:'< -.-~~tbW~~~'l$~'._'t "" ,~ ., . III 11' d"_"___ -,- . , - - ~--~,~ .. ~ c ~~- ;'.,'> '"II iI :1 ,. . C) 0 c: r'J "s: o.J ,,,. EPrq - ;?") ~-, ,-t-; :;Z:P' f "- Cr.l~' _,"I ;:$2~ 0-, -r:::'Cl ",0 v '=J(~ ~8 -. :~C::ri --".~ , ,- )>c:: s--? '""5-(") 6:11 $ en ~; P' :0 -< , , ~'I ' 1 , ",'i" ' JENNIFER MCCOY, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00- t.. q 7'{ CIVIL TERM JONATHAN MCCOY, Defendant : CIVIL ACTION - LAW : IN 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 Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 ,'_-'.'- ",,-,~ II -;l" JENNIFER MCCOY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00- (" '1 '1 'i CIVIL TERM JONATHAN MCCOY, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE The Plaintiff, Jennifer McCoy, through her attorney, Thomas S. Diehl, makes the following Complaint in Divorce, and, in support thereof, avers as follows: 1. The Plaintiff, Jennifer McCoy, is an adult individual who currently resides at 709 West Pine Street, Mount Holly Springs, Cumberland County, Pennsylvania 17065. 2. The Defendant, Jonathan McCoy, is an adult individual who currently resides at 1924B Austin Road, Ft. Bliss, Texas 79906. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on May 1, 1998 in Camp Hill, Cmnberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Defendant is a member of the Armed Forces of the United States of America, and is stationed at Ft. Bliss, Texas. Defendant is on full-time active duty status, and is not deployed outside of the continental United States at the time of the filing and service of this Complaint. .:"I,l. . ": 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. WHEREFORE, the Plaintiff, Jennifer McCoy, respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. 9 3301(c) or 3301(d) of the Divorce Code. ~f Date: L/ t~ II J-ODu J Resp~tt~~/ ~ ./f/ ( ) f' I ",' ill,~ \ //'-0' ~ '---TIromas S. Diehl Attorney for the Plaintiff One West High Street Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX LD. Number 78942 ",1"0 , ~ ki , ~~ VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904, relating to unsworn falsification to authorities. ,.",--- I' .1 , ,ir JENNIFER MCCOY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-6974 CIVIL TERM JONATHAN MCCOY, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 24th day of October 2000, comes Thomas S, Diehl, Esquire, Attorney for the Plaintiff, Jennifer McCoy, and states that he had cause to be mailed a certified copy of a Complaint in Divorce to the Defendant, Jonathan McCoy, at 1924B Austin Road, Ft. Bliss, Texas 79906 by restricted, certified, return-receipt requested. A copy of said receipt is attached hereto indicating service was made on October 19,2000. Respectfully s Hted, () I/' 4JJf! omas S. Diehl Attorney for the Plaintiff One West High Street, Suite 208 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX ,."--~ ,'~ I, II ~",""o ~ , ",. II'" ru U'J :r II'" ..D U'J .-'l Postage $ .55 1.. ,/0 Certlfied Fee ' tr Return ReceIpt Fee I:J (Endo_ Requkad) CJ Restricted DeI!YerY I:ee CJ (Endorsement Requll!ld) I:J -_&.... $ ru ru fTl Nam~PI~'"CIea~ff' 0 bB completsd h..-IIht_!!'./,.. ,,;j.......- -',. J - !', "'# ---,- , ' g: ~~ii"ffu~m'1fb~'-----------'---".'-"-----'--'---'''. ~ ~~iJ~~"Tit----'79'906"--""."---'_.'---'-'---'----'_.._'--- PS Form 3800, July 1999 See Reverse for Instructions . 'CompriU'fi~M'$r1'~i:"tb1a3/ iO~~:,",'~.,' ttem 4if Fleslrlctlid DeUv~ 1& (lesll'ed.' . Print your name and ~dres$ on ine reverse so that we can return the card to you. . Attach thi$ carel to thil back of the mallplece, ,", or on the front if space permits. 1. Article Addressed to: JONATHAN MCCOY 1924B AUSTIN ROAD FT. BLISS, TX 79906 ~f'" . Is delivery address d_ from item 17 If YES, enter delivery address below: [J Agent [J Add......' [J Yes [J No 3. Service Type XlCXCertifted M [J Registered o Insured Mail 4. Restricted DeUvery? (Extra Fee) [J Yes 2. Miele Number (Copy from service label) '7099 3220 0009 1569 4529 PS Form 3811, July 1999 .....- Domestic Return Receipt 102595-OQ-M-0952 .' 'lii~: "Il8l.iB_l:IJIfllil8m~~1'<i!\!;,1~"il~w.;["~,~Iit*,i1\J!~'. ~.' .... w,' ~, ~ o ,.._" ~ .~~'"-"'" '" ~,~ ,"~ O"A,,,_'"~ ,~,~, " ~", ,~. ~ ~~, . ~,~ ~_' d_,~ , .. ,0 ~,~~u m~""'''''''''''' ~ ~~-.~ . " ~, () ~~~~ :-::;' ',-" ~ 1'.] (:;;-", -',,) (...) I I '~ o o 'r ". ""'-'''''';-.l~ .... .." JENNIFER MCCOY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-6974 CIVIL TERM JONATHAN MCCOY, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. 11,2000. A complaint in divorce under 93301(c) of the Divorce Code was filed on October 2. The marriage of the Plaintiff and 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 after service of notice of intention to request entry of the Decree. 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. 94909 relating to unsworn falsification to authorities. Date: 1/ f 1m I , ~~uf. 7nc~ ' IF R. MCCOY, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a Final Decree in Divorce without notice. 2. I understand that I may lose rights 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 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. 9 4909 relating to unsworn falsification to authorities. Date: 7/ f/~J - ~ It- mc~ JE IFE . MCCOY, Plaintiff I'j"f.".liliiiir~I!iti" ^'~iUH8ii~ljhi;',;,. " 1 :,_itl!ll~~Jr,i\t""~,,,;,,-!s,~,~i-;:U!'k,,:'dti:;:rnll,[nAA!0\-~_ii..~-" ' #il8)~ ~;;, } "~~",,. ... .. ~--.'.-'--' .... .. .'~"""""-'...;.,IiIIiliiIiiM"~ o 1. .. ~~ (" , :-'~) :';J c:;.. .. , ,- .. ';... JENNIFER McCOY, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : oe 6991 CIVIL TERM : Q)-G, 97'/ : IN DIVORCE JONATHAN McCOY, Defendant DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. A Complaint III divorce under Section 3301(C) of the Divorce Code was filed on October 11, 2000 2. Defendant acknowledges receipt and accepts service of the Complaint on or about October 12, 2000 3. The marriage of the Plaintiff and Defendant 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 of divorce without notice. 5. 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 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. 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 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. S4904 relating to unsworn falsification to authorities. Date: I Av;~ 0 ( ----, Jl .-~ ""~ -"""~- r 1"< . ,-- " ,-, ~ ~,.,- rY-LlII,'~--- IIIfTlilti r - L_", ,_~ "0__""''__ ~","",,,"__,.,""', - ...~ - ",', , ,~~~ "'lUIII "~ "e'. ,-.> ,--~~" " "..' -, (") a \.-..1 c . ~"1 s:: J> .~ "'tltrJ ~ ;;g mEn 1;'5 ZJ_' I ~:38 z~ ~2.~- N '~-.) (.I.., kC) -u ~j'T. ---'~"-rl ~o :l: Q;~ ....:.-rl1 >8 r- 0 .. ~ ~ 0 0 -< .",