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HomeMy WebLinkAbout01-2080 FX APR 1 0 2001 ELISA S. COHEN, Plaintiff V. SCOTT A. COHEN, Defendant AND NOW, this day of : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 0 1 o2??'O IN DIVORCE ORDER OF COURT 200, upon consideration of the attached Complaint, it is hereby directed that the parties and their respective counsel appear before the conciliator, at on the _ day of 2001, at _.m., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT, By:, Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans With Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. 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, PA 17013 (717) 249-3166 fy, e- ELISA S. COHEN, V. Plaintiff SCOTT A. COHEN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW :NO. Q`'O7D 0 IN DIVORCE ORDER OF COURT AND NOW, this day of , 2001, upon consideration of the Plaintiffs Petition For Special Relief, filed herein, A RULE IS HEREBY ISSUED upon Defendant, SCOTT A. COHEN, to show cause, if any he has, why the relief requested therein should not be granted. RULE RETURNABLE days after service by mail. IT IS FURTHER ORDERED AND DECREED that a preliminary injunction is issued, directing Defendant, SCOTT A. COHEN, pending hearing, to designate and maintain Plaintiff as the sole primary survivor beneficiary of any life insurance on his life and of his military retirement benefits and to cooperate as required to provide medical services and other military benefits for Plaintiff and the minor children of the parties. BY THE COURT: J. ELISA S. COHEN, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. o/-,VP6 SCOTT A. COHEN, Defendant 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 the 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, 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, PA 17013 (717) 249-3166 ELISA S. COHEN, Plaintiff V. SCOTT A. COHEN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. o /- ..ZbPO etcu j /_z/_ IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes the above-named Plaintiff, ELISA S. COHEN, by and through her attorney, CONSTANCE P. BRUNT, ESQUIRE, and seeks to obtain a Decree in Divorce fromthe above-named Defendant, SCOTTA. COHEN, upon the grounds hereinafter set forth. COUNTI DIVORCE 1. Plaintiff is ELISA S. COHEN, an adult individual, who currently resides at 3415 Hawthorne Drive, Camp Hill, Pennsylvania 17011. 2. Defendant is SCOTT A. COHEN, an adult individual, who currently resides at USS Enterprise, Norfolk Naval Base, Norfolk, Virginia. 3. Plaintiff has been a bona fide resident of 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 December 19, 1987, in Frankfort, Kentucky. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff and Defendant are both citizens of the United States of America. 7. The Defendant is a member of the United States Navy, currently a member of the crew of the USS Enterprise, stationed at Norfolk Naval Base, Norfolk, Virginia. 8. The Plaintiffhas been advised of the availability of marriage counseling and understands that she may request that the Court require the parties to participate in counseling. 9. The Plaintiff avers that the grounds on which the action is based are that the Defendant has offered such indignities to the person of the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. 10. Plaintiff requests the Court to enter a Decree in Divorce. 2 COUNT II REQUEST FOR EOUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502(a) OF THE DIVORCE CODE 11. Paragraphs 1 through 7 inclusive of Count I are specifically incorporated by reference as though fully set forth hereinafter. 12. Plaintiff and Defendant have individually or jointly acquired real and personal property during the marriage, in which they individually or jointly have a legal or equitable interest, which marital property is subject to equitable distribution. 13. Plaintiff requests the Court to determine and equitably distribute, divide or assign said marital property, pursuant to Section 3502 of the Divorce Code. COUNT III REQUEST FOR ALIMONY PENDENTE LITE, COUNSEL FEES COSTS AND EXPENSES UNDER SECTION 3702 OF THE DIVORCE CODE 14. Paragraphs 1 through 7 inclusive of Count I are specifically incorporated by reference as though fully set forth hereinafter. 15. Plaintiff is without sufficient assets and income to support herself and pay her attorney's fees and the costs and expenses of this action. 16. Defendant has sufficient earning capacity to support the Plaintiff and to pay the Plaintiffs attorney's fees and the costs and expenses of this action. 17. Plaintiff requests the Court to order the Defendant to support the Plaintiff during the pendency of this action and to pay Plaintiffs counsel fees, expenses and the costs of this action, pursuant to Section 3702 of the Divorce Code. COUNT IV REQUEST FOR ALIMONY UNDER SECTION 3701 OF THE DIVORCE CODE 18. Paragraphs 1 through 7 inclusive of Count I are specifically incorporated by reference as though fully set forth hereinafter. 19. Plaintiff lacks sufficient property to provide for her reasonable needs. 20. Plaintiff is unable to sufficiently support herself through appropriate employment. 21. Defendant has sufficient property, assets, and income to provide continuing support for the Plaintiff. 22. Plaintiff requests the Court to order the Defendant to pay alimony to Plaintiff pursuant to Section 3701 of the Divorce Code. 4 r COUNT V REQUEST FOR CUSTODY UNDER SECTION 3323(,b OF THE DIVORCE CODE 23. Paragraphs 1 through 7 inclusive of Count I are specifically incorporated by reference as though fully set forth hereinafter. 24. The Plaintiff is seeking primary legal and physical custody of the following children: Name Residence Age Aaron M. Cohen 3415 Hawthorne Drive 9 Camp Hill, PA 17011 David M. Cohen 3415 Hawthorne Drive 6 Camp Hill, PA 17011 The children were born of the marriage between Plaintiff and Defendant. The children are presently in the custody of Plaintiff, ELISA S. COHEN, who currently resides at 3415 Hawthorne Drive, Camp Hill, Cumberland County, Pennsylvania, 17011. For the past five (5) years, the children have resided with the following persons and at the following addresses: 5 (a) From 11/99 through present 3415 Hawthorne Drive Camp Hill, PA 17011 With Plaintiff, ELISA S. COHEN (b) From 12/98 through 10/99 Qtrs. P-4 Antrim Drive Mechanicsburg, PA 17055 With Plaintiff and Defendant (c) From 8/97 through 11/98 4768 Famdon Court Fairfax, VA 22032 With Plaintiff and Defendant (d) From 12/95 through 7/97 1298 Spruance Road Monterey, CA 93940 With Plaintiff and Defendant The mother of the children is Plaintiff, ELISA S. COHEN, residing at 3415 Hawthorne Drive, Camp Hill, Cumberland County, Pennsylvania, 17011. The father of the children is Defendant, SCOTT A. COHEN, residing on the USS Enterprise, stationed at Norfolk Naval Base, Norfolk, Virginia. 6 25. The relationship of Plaintiff, ELISA S. COHEN, to the child is that of natural mother. 26. The relationship of Defendant, SCOTT A. COHEN, to the child is that of natural father. 27. The Plaintiff has not participated as a party or witness, or in any other capacity, in other litigation concerning the custody of the children in this or any other court. Plaintiff has no information of a custody proceeding concerning the custody of the said children pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 28. The relief requested by Plaintiff is in the best interests of the children because the Plaintiff has served as the primary caregiver for the children since birth and is best suited to provide them with a stable and wholesome home environment. 29. Each parent whose parental rights of the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, Plaintiff prays that your Honorable Court enter a Decree in Divorce as follows: (a.) dissolving the marriage between the parties; (b.) equitably distributing, dividing or assigning the marital property of the parties; (c.) ordering Defendant to pay alimony nendente lite, counsel fees, expenses and costs of this action to Plaintiff; (d) ordering Defendant to pay alimony to Plaintiff; (e.) granting Plaintiff primary legal and physical custody of the minor children of the parties, subject to Defendant's rights of partial physical custody; and (f.) granting such other further relief as the Court deems appropriate. Respectfully submitted, ZCONSTANCE P. BRUNT, ESQUIRE Supreme Court ID# 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 Attorney for Plaintiff 8 VERIFICATION I verify that the statements made in the foregoing Complaint In Divorce 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. DATED: z ELISA S. COHEN ELISA S. COHEN, Plaintiff V. SCOTT A. COHEN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 61-,9096) : IN DIVORCE PLAINTIFF'S PETITION FOR SPECIAL RELIEF IN THE FORM OF AN INJUNCTION PURSUANT TO 23 Pa. C.S. §§3323(f). 3502(d). AND 3702 AND Pa. R.C.P.1920.43(a) AND NOW, comes the Plaintiff, ELISA S. COHEN, by and through her attorney, CONSTANCE P. BRUNT, ESQUIRE, and petitions this Honorable Court as follows: The above-captioned action in divorce was instituted by Plaintiff, ELISA S. COHEN, on April 9, 2001, by the filing of a Complaint In Divorce, which included, inter alia, claims for equitable distribution of marital property, alimony, alimony pendente lite, counsel fees, costs and expenses, and custody of the minor children of the parties. 2. The parties are the parents of two minor children, aged 9 and 6, who reside with Plaintiff. Defendant is an active duty member of the United States Navy and is frequently required to engage in long cruises at sea. 4. Plaintiff and minor children of the parties are dependent upon Defendant for their support. 5. As a member of the United States Navy, Defendant is insured by certain life insurance policies and has entitlement to retirement benefits which would be distributed in the event of Defendant's death according to beneficiary designations and not as part of his probate estate. Defendant is scheduled to leave the country on April 25, 2001 for a six- month cruise, where he will be exposed to substantial physical danger. 7. In the event that the Defendant would die prior to the final resolution of the economic claims in this matter, the divorce action would abate, and Plaintiff would be limited to her claims in intestacy or her right to elect to take against the Defendant's Will with respect to Defendant's probate estate only. Other than Defendant's military retirement benefits and possible life insurance proceeds, there are no significant assets which would be part of Defendant's probate estate. 9. Because the assets held in Defendant's name are in forms which would not be part of a probate estate, their disposition would be controlled by beneficiary designation, and Plaintiff would be left without sufficient income or assets under her control to meet her reasonable needs and the reasonable needs of the minor children of the parties if they were distributed to some third party. 2 10. The Defendant has always been the primary wage earner of the parties, and Plaintiff's career development has been affected by her role as the primary caretaker for the children and by the numerous moves the parties have been required to make because of Defendant's military career. 11. Pursuant to 23 Pa. C.S. §3502(d), Plaintiff requests that the Court enter an Order directing Defendant to maintain all insurance policies on his life now existing, paying all necessary premiums thereon as due and designating Plaintiff as the sole primary beneficiary of said policies, pending final resolution of the economic claims of the parties. 12. Plaintiff also requests that the Court enter an Order directing Defendant to designate and maintain Plaintiff as the primary survivor beneficiary on any retirement accounts of any nature, including specifically his retirement benefits through the United States Navy, pending final resolution of the economic claims of the parties. 13. Throughout the marriage of the parties, the Plaintiff and the minor children have had the benefit of medical services and other military benefits as Defendant's dependents. 14. The Plaintiff does not have access to any other equivalent medical insurance coverage for herself and the minor children. 15. Pursuant to 23 Pa. C.S. §3502(d), Plaintiff requests that the Court enter an Order directing Defendant to cooperate as required to provide continuing medical services and other military benefits for the Plaintiff and the minor children of the parties, pending final resolution of the economic claims of the parties. 16. Because Defendant will be leaving the country immediately to embark on an extended sea cruise during which he will be exposed to considerable danger and because the Plaintiff and the minor children are dependent upon him, Plaintiff believes and therefore avers that it is imperative that this Honorable Court enter an immediate Temporary Order directing Defendant to designate and maintain Plaintiff as the sole primary survivor beneficiary of any life insurance on his life and of his military retirement benefits and to cooperate as required to provide continuing medical services and other military benefits for Plaintiff and the minor children of the parties to avoid permanent and irreparable prejudice to them. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an Order issuing a rule upon Defendant, SCOTT A. COHEN, to show cause, if any he has, why the relief requested herein should not be granted. Further, Plaintiff requests the immediate entry of an Order temporarily directing Defendant, pending hearing, to designate and maintain Plaintiff as the sole primary survivor beneficiary of any life insurance on his life and of his military retirement benefits and to cooperate as required to provide continuing medical services and other military benefits for Plaintiff and the minor children of the parties. Plaintiff also seeks the entry of an Order Of Court following hearing providing as follows: A. Directing Defendant to maintain all insurance policies on his life which were in existence at the date of the filing of Plaintiff's Complaint In Divorce, paying all necessary premiums thereon as due, and prohibiting and enjoining Defendant from taking any loans from said policies or in any way encumbering the proceeds of said policies, pending further Order Of Court; B. Directing Defendant to designate and maintain Plaintiff as the primary beneficiary of any life insurance policies insuring his life, including all policies provided through his service with the United States Navy; C. Directing Defendant to designate and maintain Plaintiff as the sole primary survivor beneficiary of all retirement accounts or benefits of any nature as he may have, including specifically his military retirement benefits through the United States Navy, pending final resolution of the economic claims of the parties; and D. Directing Defendant to cooperate as required to provide and maintain continuing medical services and other military benefits for the benefit of the Plaintiff and the minor children of the parties, pending final resolution of the economic claims of the parties. Respectfully submitted, ZtA CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Plaintiff's Petition For Special Relief In The Form Of An Injunction Pursuant To 23 Pa. C.S. §§3323(f), 3502(d) And 3702 And Pa, R.C.P. 1920.43(a) are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. DATED: ? p 0/ L;' ? ISA S. C HEN, Plaintiff 6 ELISA S. COHEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA BY THE COURT, V. CIVIL ACTION - LAW SCOTT A. COHEN, Defendant NO. 01-2080 CIVIL TERM ORDER OF COURT AND NOW, this 12'' day of April, 2001, upon consideration of Plaintiff's Petition for Special Relief in the Form of an Injunction Pursuant To 23 Pa. C.S. §3323(f), 3502(d), and 3702 and Pa. R.C.P. 1920.43(a), a hearing is scheduled for Monday, April 23, 2001, at 11:30 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. Constance P. Brunt, Esq. Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 Attorney for Plaintiff Scott A. Cohen USS Enterprise Norfolk Navel Base Norfolk, VA :rc ?,D D Wesley Oler J ., J. CAa'?s 1\ AINmn :? ELISA S. COHEN, Plaintiff V. SCOTT A. COHEN, Defendant I : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 01-2080 IN DIVORCE AFFIDAVIT OF SERVICE I, Shari R. Gorman, paralegal for Constance P. Brunt, Esquire, do hereby certify that on April 10, 2001, I did serve on Defendant, SCOTT A. COHEN, true and correct copies of the Complaint In Divorce and of the Plaintiff's Petition For Special Relief filed on April 9, 2001, in the above-captioned matter, by personally delivering them to him at 3:35 p.m. at Plaintiff's residence at 3415 Hawthorne Drive, Camp Hill, PA 17011. shy /? 2eiir J> 4 / SHARI R. GORMAN ELISA S. COHEN, Plaintiff V. SCOTT A. COHEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW NO. 01-2080 : IN DIVORCE PLAINTIFF'S PETITION FOR ALIMONY PENDENTE LITE AND NOW, comes the Petitioner, ELISA S. COHEN, by and through her attorney, CONSTANCE P. BRUNT, ESQUIRE, and files the following Petition For Alimony Pendente Lite: 1. Plaintiff/Petitioner, ELISA S. COHEN, is an adult individual currently residing at 3415 Hawthorne Drive, Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant/Respondent, SCOTT A. COHEN, is an adult individual residing at USS Enterprise, Norfolk Naval Base, Norfolk, Virginia. 3. On April 9, 2001, the Plaintiff/Petitioner filed a Complaint In Divorce in the above matter, in which she raised a claim for alimony nendente lite in Count III. 4. The Plaintiff/Petitioner is employed at Harrisburg Area Community College from which she earns approximately $25,000 per year, an amount which is insufficient to properly provide for herself and the minor children of the parties. 5. Defendant/Respondent is employed by the United States Navy, from which he earns approximately $49,000 per year, plus various benefits and allotments. 6. Plaintiff/Petitioner is unable to provide and maintain the standard of living to which she and the minor children were accustomed and is need of alimony nendente lite to support herself and the minor children of the parties and to adequately protect her rights and interests in the pending divorce action. 7. Defendant/Respondent has sufficient assets and income to provide continuing support to Plaintiff/Petitioner. WHEREFORE, Plaintiff/Petitioner prays this Honorable Court to enter an Order directing Defendant/Respondent to pay alimony nendente lite to Plaintiff/Petitioner in accordance with the guidelines set forth in the Rules of Civil Procedure. Respectfully submitted, AeIIA CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID# 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 Attorney for Plaintiff/Petitioner VERIFICATION I verify that the statements made in the foregoing Plaintiff s Petition For Alimony Pendente Lite 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. DATED: Y1l71Gl k? ELISA S. COHEN, Plaintiff/Petitioner k CERTIFICATE OF SERVICE I, C/O?NS?TANCE P. BRUNT, ESQUIRE, do hereby certify that on the /Pk- day of 2001,1 served a true and correct copy of the Plaintiff s Petition For Alimony Pendente Lite, by depositing same in the United States Mail, first class postage prepaid, in the Post Office at Harrisburg, Pennsylvania, addressed as follows: Scott A. Cohen USS Enterprise Norfolk Naval Base Norfolk, VA Defendant .. zag CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID# 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 Attorney for Defendant/Petitioner ELISA S. COHEN IN THE COURT OF COMMON PLEAS OF PLAI=F CUMBERLAND COUNTY, PENNSYLVANIA V. SCOTT A. COHEN 01-2080 CIVIL ACTION LAW DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Tuesday, April 17, 2001 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. the conciliator, at 214 Senate Avenue, Suite 105, Camp Hill, PA 17011 on Monday, May 07, 2001 at 11:00 a.m. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By. /s/ Melissa P Greevay, Este Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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 Telephone (717) 249-3166 ?? ? ? ?j e?bi? ?, ,?:,,, ?I_i I ELISA S. COHEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW SCOTT A. COHEN, Defendant No. 01-2080 CIVIL TERM ORDER OF COURT AND NOW, this 23rd day of April, 2001, upon consideration of Plaintiff's Petition for Special Relief in the Form of an Injunction Pursuant to 23 Pa. C.S. Section 3323(f), 3502(d), and 3702 and Pa. R.C.P. 1920.43(a), and following a hearing, the petition is denied. Constance P. Brunt, Esquire Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 For the Plaintiff Samuel L. Andes, Esquire 525 N. 12th Street Lemoyne, PA 17043 For the Defendant wcy a By the Court, HINVPIADNIN3d Alpqno - 0,\`,v, pevjno tie :6 gZ88V ED n ??G'i I!G 1120 Y ELISA S. COHEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW SCOTT A. COHEN, Defendant No. 01-2080 CIVIL TERM ORDER OF COURT AND NOW, this 23rd day of April, 2001, upon consideration of Plaintiff's Petition for Special Relief in the Form of an Injunction Pursuant to 23 Pa. C.S. Section 3323(f), 3502(d), and 3702 and Pa. R.C.P. 1920.43(a), and following a hearing at which Plaintiff was represented by Constance P. Brunt, Esquire, and Defendant appeared by telephone and represented himself, the record is declared closed, and the matter is taken under advisement. By the Court, Constance P. Brunt, Esquire Beaufort Professional center 1820 Linglestown Road, Harrisburg, PA 17110-3339 For the Plaintiff Samuel L. Andes, Esquire 525 N. 12th Street Lemoyne, PA 17043 For the Defendant wcy ?/ - PJ oy;2G- 6 / A ? ilno 1A1IL, 8 Af) Se =5 WV 10 ??IJ?iCrCl?lj? ELISA S. COHEN, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - DIVORCE NO. 01-2080 CIVIL TERM SCOTT A. COHEN, IN DIVORCE Defendant/Respondent DR# 30611 Pacses# 923103398 ORDER OF COURT AND NOW, this 25" day. of April, 200-1-,.upon.consideration.of.the-attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shaddav on. June 5.2001 at 9:OOA.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. NOTE: The support conference previously scheduled before Charles Carothers will now be heard before RJ. Shadday. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.110 (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Mail copies on Petitioner 4-25-01 to: < Respondent Constance Brunt, Esquire Date of Order: April 25, 2001 Conference YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 MNVAWiNN9d J, INriC}0 OrN i,':177FV O 4.a pit 0 8 2001 V) ELISA S. COHEN IN THE COURT OF COMMON PLEAS Plaintiff, OF CUMBERLAND COUNTY, PENNSYLVANIA V. No. 01-2080 Civil Action - Law SCOTT A. COHEN, In Custody Defendant. ORDER OF COURT AND NOW, this 4th day of May, 2001, the Conciliator, being advised by Plaintiff s counsel that the parties have reached an agreement, hereby relinquishes jurisdiction in this case. FOR THE COURT, Melissa eel Greevy, Esquire Custody Conciliator MN't';111,SN??d I-Nno F ELISA S. COHEN, Plaintiff V. SCOTT A. COHEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 01-2080 IN CUSTODY STIPULATION OF THE PARTIES AND NOW, come the above-captioned parties, by their respective counsel of record, and stipulate and agree as follows: 1. The above-captioned action was initiated by the filing on April 9, 2001, of a Complaint In Divorce, containing a claim in Count IV by Plaintiff, ELISA S. COHEN, for custody of the two minor children of the parties. 2. A pre-hearing custody conference has been scheduled before MELISSA P. GREEVY, ESQUIRE, on Monday, May 7, 2001, at 11:00 a.m. The parties, by their counsel, agree that the Court shall enter the attached Order to temporarily resolve the claims raised in the custody action between them. CONSTANCE P. BRUNT, ESQUIRE Attorney for Plaintiff ..s)4_G_ of." EL L. AND, ESQUIRE Attorney for Defendant w ELISA S. COHEN, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. SCOTT A. COHEN, Defendant CIVIL ACTION - LAW NO. 01-2080 : IN CUSTODY TEMPORARY ORDER OF COURT AND NOW, this day of Me 12001, upon Stipulation Of The Parties filed herein, It is hereby ORDERED AND DECREED as follows: A. Plaintiff and Defendant shall enjoy shared legal custody of their minor children, AARON M. COHEN (DOB: 05/21/91) and DAVID M. COHEN (DOB: 12/16/94). In the event that the parent then having physical custody of the said children is unable to reach the other parent after reasonable efforts, that parent shall have the authority to make such major decisions as are appropriate for the health, education, safety, religious training, and general welfare of the children. B. Plaintiff, ELISA S. COHEN, shall have primary physical custody of the subject minor children, subject to such rights of partial physical custody by Defendant as the parties shall from time to time agree. A. '? tall.,\Idr?;. ? C. The pre-hearing custody conference scheduled for May 7, 2001, is hereby continued generally, subject to being rescheduled upon the Motion of either party. D. The Parties acknowledge that this Order is entered on a temporary basis because SCOTT A. COHEN is currently out of the country on active duty with the United States Navy and the parties agree that they shall renegotiate and revise their arrangements for custody of the children upon his return sometime in the fall of 2001. This Order is entered without prejudice to the rights of the parties, and any claims or defenses they may have, regarding their custody position at that time. BY THE COURT: k r?5 o 6 2 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION ELISA S. COHEN ) Docket Number 01-2080 CIVIL Plaintiff ) VS. ) PACSES Case Number 92310339B/D3%11 SCOTT A. COHEN ) Defendant ) Other State ID Number ORDER AND NOW, to wit on this 5TH DAY OF JUNE, 2001 IT IS IIEREBY ORDERED that the 0 Complaint for Support or Q Petition to Modify or ® Other ALIMONY PENDENTE LITE PETITION filed on APRIL 18, 2001 in the above captioned matter is dismissed without prejudice due to: AN ORDER OF SPOUSAL SUPPORT BEING ESTABLISHED UNDER DOCKET NO.297 S 2001 AND PACSES NO.972103351. Q The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. BY THE COURT: DRO: RJ ShaddaY VARn xc: plaintiff defenlant Constance Brunt, Esquire Service Type M Ee JUDGE Form OE-506 Worker ID 21005 C V,?rr: - 5?7? r? BURTON NEIL & ASSOCIATES, P.C. By: Burton Neil, Esquire Identification No. 11348 26 South Church Street West Chester, PA 19382 610-696-2120 Attorney for Plaintiff CITIBANK (SOUTH DAKOTA) N.A. Plaintiff VS. CALVIN S BARD JR Defendant and MEMBERS FIRST FEDERAL CREDIT UNION Garnishee IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-02081 CIVIL ACTION - LAW Praecipe to Dissolve Attachment To the Prothonotary: Dissolve the attachment against Members First Federal Credit Union, garnishee. BURTON NEIL & ASSOCIATES, P.C. BY: Burton Neil, Esquire Attorney for Plaintiff In making this communication, we advise that our firm is a debt collector. E?co C.? V E? CIO Cam' i ._% ^ s err, ' . AUG a o 2007al f ELISA S. COHEN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 01-2080 SCOTT A. COHEN, : CIVIL ACTION - LAW Defendant : IN DIVORCE ORDER APPOINTING MASTER AND NOW, 2007, , Esquire is appointed Master with respect to the following claims: Alimony, Alimony Pendente Lite, Distribution of Property, Counsel Fees and Costs and Expenses. By the Court: ..? G D' tribution: an M. Kadel, Esquire, P.O. Box 650, Hershey, PA 17033 ,j nstance P. Brunt, Esquire, 1820 Linglestown Rd., Harrisburg, PA 1711( a.. p r-- ?° _7D C) c v Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cabruntP-CPBruntLaw.com Attorney for Plaintiff ELISA S. COHEN, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : CIVIL ACTION -LAW V. SCOTT A. COHEN, : NO. 01-2080 Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, SUSAN M. KADEL, ESQUIRE, attorney for the Defendant, SCOTT A. COHEN, in the above-captioned divorce action, hereby accept service of the Amended Complaint in Divorce tiled on August 13, 2008, in the Court of Common Pleas of Cumberland County, Pennsylvania, and certify that I am authorized to do so. Date: 91/l.Z/o 7- / L S KADEL, ESQUIRE Supreme Court ID # 44837 .LAMES, SMITH, DURKIN & CONNELLY, LLP 134 Sipe Avenue Hershey, PA 17033 (717) 533-3280 FAX (717) 533-7771 smk(&-jsdleaal.com Attorney for Defendant CZI> n Q 'J Zr Co C ELISA S. COHEN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 01-2080 SCOTT A. COHEN, : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE TO THE PLAINTIFF If you wish to deny any of the statements set forth in this Affidavit, you must file a Counteraffidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. DEFENDANT'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE I . The parties to this action have been separated since November 1, 1999, and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. 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 unworn falsification to authorities. Date: Po8 Cry L' Sco A. Cohen, Defendant I . ELISA S. COHEN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 01-2080 CERTIFICATE OF SERVICE I, Susan M. Kadel, Esquire, of James, Smith, Dietterick & Connelly, LLP attorney for the SCOTT A. COHEN, : CIVIL ACTION - LAW Defendant : IN DIVORCE Defendant, Scott A. Cohen, hereby certify that I have served a copy of the foregoing Defendant's Affidavit under Section 3301(d) of the Divorce Code on the following on the date and in the manner indicated below: VIA U.S. MAIL. FIRST CLASS. PRE-PAID Constance P. Brunt, Esquire Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: ?S ) 7- By: Susan M. Kadel Attorney I.D. #44837 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Defendant r , ? ,. = i ? r.? r _? - i.,_ ^ C"4 ?? . ?.1? ..? ? i .. `,-r ? ..-... ?? • • ,i .?.? a .. Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cpbruntOCPBruntLaw.com Attorney for Plaintiff C7 C.: ^' c-3 r -T, ELISA S. COHEN, Plaintiff V. SCOTT A. COHEN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01-2080 IN DIVORCE MOTION FOR ENTRY OF STIPULATED DOMESTIC RELATIONS ORDER AND NOW comes the Plaintiff, ELISA S. COHEN, by and through her attorney, CONSTANCE P. BRUNT, ESQUIRE, and moves this Honorable Court as follows: 1. On August 29, 2008, the parties to the above-captioned action executed a Marital Settlement Agreement, pursuant to which they resolved all of their various economic claims against one another arising from their marriage, including, without limitation, equitable distribution of marital property. 2. In the aforesaid Agreement, the parties agreed to the equitable distribution of Defendant's pension through the Military Retirement System, which resulted from his service with the United States Navy, and agreed to cooperate in the entry of a Domestic Relations Order directing the distribution of the retirement plan. 3. Attached hereto is a proposed Domestic Relations Order applicable to the Military Retirement System, which has been signed and consented to by Plaintiff, ELISA S. COHEN, and by Defendant, SCOTT A. COHEN, by his attorney-in-fact, Evelyn Apter. 4. Also attached is a copy of the Limited Power of Attorney signed by Defendant, SCOTT A. COHEN, authorizing Evelyn Apter to execute the said Domestic Relations Order on his behalf. Defendant is currently employed by NATO and is stationed in Baghdad, Iraq. WHEREFORE, Plaintiff respectfully moves this Honorable Court to enter an Order in the proposed form attached hereto making distribution of the Defendant's Military Retirement System pension as set forth therein. Respectfully submitted, j7L?54 CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID # 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 FAX (717) 232-0255 cpbrunt@CPBruntLaw.com Attorney for Plaintiff 2 CERTIFICATE OF SERVICE I, CONSTANCE P. BRUNT, ESQUIRE, do hereby certify that on the /(f day of oclz:?1,_ _ , 2008, 1 served a true and correct copy of the foregoing Motion For Entry Of Stipulated Domestic Relations Order, by depositing the same in the United States mail, first-class postage prepaid, at Harrisburg, Pennsylvania, addressed to the following: Susan M. Kadel, Esquire James, Smith, Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 Attorney for Defendant j7zl_?f CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID # 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 FAX (717) 232-0255 cpbruntO-CPBruntLaw.com Attorney for Plaintiff 3 LIMITED POWER of ATTORNEY I, Scott Allen Cohen, of 162-41 Powells Cove Boulevard, Beechhurst, New York 11357- 1449, do hereby appoint Evelyn Apter, of 162-41 Powells Cove Boulevard, Beechhurst, New York 11357-1449, my true and lawful attorney-in-fact, for me, and in my name, place and stead, and for my use and benefit to execute a Domestic Relations Order relating to my military retired pay under the Military Retirement System. I further give and grant unto my said attorney-in-fact full power and authority to do and perform every act necessary and proper to be done in the exercise of any of the foregoing powers as fully as I might or could do if personally present. I hereby ratify and confirm all that my attorney shall lawfully do or cause to be done by virtue hereof. Rs Aud Root c?• G Date Scott Allen Cohen Commonwealth of Pennsylvania . ss. County of Dauphin On this Jr day of August, 2008, before me, a Notary Public, the undersigned officer, personally appeared Scott Allen Cohen, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public My Commission Expires: COMMONWEALTH OF PENNSYLVANIA Notarial Seal Maria B. LaRue, Notary Public Derry Twp., Dauphin County My Commission Expires Nov. 8, 2009 Member, Pennsylvania Association of Notaries Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cPbruntDCPBruntLaw.com Attorney for Plaintiff ELISA S. COHEN, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : CIVIL ACTION -LAW V. SCOTT A. COHEN, : NO. 01-2080 Defendant : IN DIVORCE AMENDMENT TO MOTION FOR ENTRY OF STIPULATED DOMESTIC RELATIONS ORDER AND NOW comes the Plaintiff, ELISA S. COHEN, by and through her attorney, CONSTANCE P. BRUNT, ESQUIRE, and amends the Motion For Entry of Stipulated Domestic Relations Order as follows: 1. Pursuant to C.C.R.P. 208.3(a), Defendant's counsel has concurred in the Motion For Entry of Stipulated Domestic Relations Order. 2. By Order entered April 23, 2001, the Honorable J. Wesley Oler, Jr., J., has previously ruled upon the Plaintiffs Petition For Special Relief In The Form Of An Injunction in this matter. 3. By Order entered September 4, 2007, the Honorable Edgar B. Bayley, P.J., has previously ruled upon the Defendant's Motion For Appointment Of Master in this matter. Respectfully submitted, CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID # 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 FAX (717) 232-0255 cpbruntOCPBruntLaw com Attorney for Plaintiff 2 CERTIFICATE OF SERVICE I, CONSTANCE P. BRUNT, ESQUIRE, do hereby certify that on the V" day of QClw , 2008, 1 served a true and correct copy of the foregoing Amendment To Motion For Entry Of Stipulated Domestic Relations Order, by depositing the same in the United States mail, first-class postage prepaid, at Harrisburg, Pennsylvania, addressed to the following: Susan M. Kadel, Esquire James, Smith, Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 Attorney for Defendant 441P_ CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID # 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 FAX (717) 232-0255 cl2bruntOCPBruntLaw com Attorney for Plaintiff r a CO .z Co -"r ' e, Ot'? '' 100 Elisa S. Cohen Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW IN DIVORCE Scott A. Cohen Defendant NO. 01-2080 DOMESTIC RELATIONS ORDER 1. This Domestic Relations Order ("DRO") creates and recognizes the existence of the Alternate Payee's right to receive a portion of the benefits payable with respect to the Participant. 2. This DRO is entered pursuant to authority granted under the applicable domestic relations laws of the State of Pennsylvania. 3. This DRO relates to the provision of marital property rights to the Alternate Payee. 4. This DRO applies to the Military Retirement System ("Plan") and any successor thereto. Scott A. Cohen ("Participant") is a Participant in the Plan. Elisa S. Cohen ("Alternate Payee"), the former spouse, is the Alternate Payee for the purpose of this DRO. 5. The Participant's name, mailing address, Social Security number and date of birth are: Scott A. Cohen c/o Evelyn Apter 162-41 Powells Cove Blvd. Beechhurst, NY 11357-1449 Social Security No.: 127-56-6943 Date of Birth: June 4, 1964 6. The Alternate Payee's name, mailing address, Social Security number and date of birth are: Elisa S. Cohen 3122 Yale Avenue Camp Hill, PA 17011 Social Security No.: 404-96-6166 Date of Birth: September 24, 1962 7. The Participant assigns to the Alternate Payee an interest in the Participant's disposable military retired pay. The Alternate Payee is entitled to a direct payment in the amount specified below and shall receive payments at the same time as the Participant. 8. The Participant's rights under the Servicemembers' Civil Relief Act were observed by the Court as evidenced by the Participant's presence at the proceedings. DRO Page 2 9. This Order assigns to Alternate Payee an amount equal to 35.46% of the Participant's disposable military retired pay under the Plan. In addition to the above, the Alternate Payee shall receive a pro rata share of any increases made to the Participant's benefits. The pro rata share shall be calculated in the same manner as the Alternate Payee's share of the Participant's retirement benefits is calculated pursuant to this Paragraph 9. 10. Payments to Alternate Payee shall commence as soon as administratively feasible following the date this Order is approved by the appropriate Military Pay Center. 11. Payments shall continue to Alternate Payee for the remainder of the Participant's lifetime, irrespective of the future marital status of either Alternate Payee or Participant. If the Alternate Payee dies before the Participant, the Alternate Payee's share of the Participant's disposable military retired pay shall revert to the Participant. 12. The Participant agrees to elect to make the Alternate Payee (and such Alternate Payee shall be deemed) the irrevocable beneficiary of the survivor's Survivor Benefit Plan ("SBP"). The Participant shall elect the former spouse and child (or children) option and shall select as the base amount the full amount of monthly retired pay. The Participant shall make the necessary election in a timely manner to effectuate the SBP coverage for the Alternate Payee and shall execute such paperwork as is required. The Participant shall do nothing to reduce or eliminate the survivor benefit to the Alternate Payee. 13. The jurisdictional requirements of 10 U.S.C. Section 1408 have been complied with, and this Order has not been amended, superseded, or set aside by any subsequent order. 14. The Participant and the Alternate Payee acknowledge that they have been married for a period of more than ten years during which time the Participant performed more than ten years of creditable military service. The parties were married on December 19, 1987, and separated on November 1, 1999. 15. The Alternate Payee agrees that any future overpayments to her are recoverable and subject to involuntary collection from her or her estate. 16. The Alternate Payee agrees to notify DFAS about any changes in the Domestic Relations Order or the order affecting these provisions of it, or in the eligibility of any recipient receiving benefits pursuant to it. 17. The Participant and the Alternate Payee intend that this Order qualify under the Uniformed Services Former Spouses' Protection Act, 10 U.S.C. Section 1408 and following. 18. The Participant agrees to cooperate with the Alternate Payee to prepare an application for direct payment to the Alternate Payee from the Participant's retired or retainer pay pursuant to 10 U.S.C. Section 1408. The Participant agrees to execute all documents that the United States Navy may require to certify that the disposable military retired pay can be provided to the Alternate Payee. DRO Page 3 19. The parties acknowledge that the following items must be sent by the Alternate Payee to DFAS-CL/GAG, Assistant General Counsel for Garnishment Operation, Defense Finance and Accounting Services Cleveland, P.O. Box 998002, Cleveland, Ohio 44199-8002 and to DFAS, U.S. Military Retired Pay, P.O. Box 7130, London, KY 40742-7130. The Participant agrees to provide any of this information to the Alternate Payee at the Alternate Payee's request and to make all necessary efforts to obtain any of this information that the Alternate Payee is unable to obtain. a. Deemed Election Letter b. A certified copy of the Divorce Decree. C. A certified copy of this Domestic Relations Order. d. A copy of the Marriage Certificate of Mr. and Mrs. Cohen. e. An executed copy of Form 2656-1 entitled "Survivor Benefit Plan (SBP) Election Statement for Former Spouse Coverage." f. An executed copy of Form 2293 entitled "Application for Former Spouse Payments From Retired Pay." 20. The Court shall retain jurisdiction to enter such further orders as are necessary to enforce the award to the Alternate Payee of the military retirement benefits awarded herein. 21. The Participant shall make direct payments to the Alternate Payee in such amounts as necessary to provide her with her intended portion of his retirement benefits until her direct payment commences by DFAS or in the event that her direct payments are reduced or terminated by DFAS for any reason. Accepted and Ordered this day of /--) ",C , 20 CONSENT TO ORDER: 8/-2gl0 Plaintiff/ ternate Payee Date Attorney for Plaintiff/ Date Alternate Payee Defend tlPartic' ant Date Atto ey for Defendant/ Date Participant Rv TT-TF !!nTTRT • Q ,?u.? s1 ac?o _ ?3v??,Io? rye`''.; c l: 134 Bo0 ?S1GI`is;, - l ELISA S. COHEN, Plaintiff V. SCOTT A. COHEN, Defendant To the Prothonotary: IN THE COURT OF CUMBERLAND CC No. 01-2080 CIVIL ACTION - LA IN DIVORCE TO MMON PLEAS TY, PENNSYLVANIA Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under Sect 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: April 10, 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent and required by Section 3301(c) of the Divorce Code: (b) (1) Date of execution of the Defendant's Affidavit of the Divorce Code: August 25, 2008. (2) Date of service of the Defendant's Affidavit upon August 25, 2008. ( ) 3301(c) (X) 1; hand delivered. aiver of Counseling by Section 3301(d) the Plaintiff On or about 4. Related claims pending: None 5. Date and manner of service of Notice of Intention to file Transmit Record, a copy of which is attached, if the decree is to be E of the Divorce Code: On or about September 17, 2008. or, date of execution of Waiver of Notice of Intention to under Section 3301(c) of the Divorce Code: by Plaintiff: by JAMES, SMITH, Date: September 17, 2008 Susan adel, Esquire Attorney for Plaintiff Post Office Box 650 Hershey, PA 17033 (717) 533-3280 PA I.D. No. 44837 e to under Section 3301(d) Entry of a Divorce Decree & CONNELLY, LLP ELISA S. COHEN. Plaintiff V. SCOTT A. COHEN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND C UNTY. PENNSYLVANIA No. 01-2080 CIVIL ACTION - LAW IN DIVORCE NTENTION TO REQUEST ENTRY OF I)IVORCE DECREE TO: Elisa S. Cohen, Plaintiff c/o Constance P. Brunt, Esquire Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 Defendant, Scott A. Cohen, intends to file with the court th attached Praecipe to Transmit Record on or after October 7, 2008, requesting that a final, decree in divorce be entered. Respectfully Date: /7 Susanybl. Kadel, I Attorney for Defe Post Office Box 6 Hershey, PA 170 (717) 533-3280 PA I.D. No. 4483 Scott A. Cohen ELISA S. COHEN, Plaintiff V. SCOTT A. COHEN, Defendant To the Prothonotary: IN THE COURT Ot COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 01-2080 CIVIL ACTION - L?W IN DNORCE 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 ction ( ) 3301(c) ( X } 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: April 1 , 2001; hand delivered. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent and Waiver of Counseling required by Section 3301(c) of the Divorce Code: (b) (1) Date of execution of the Defendant's Affidav t required by Section 3301(d) of the Divorce Code: August 25, 2008. (2) Date of service of the Defendant's Affidavit up n the Plaintiff. On or about August 25, 2008. 4. Related claims pending: None 5. Date and manner of service of Notice of Intention to file Transmit Record, a copy of which is attached, if the decree is to be of the Divorce Code: On or about September 17, 2008. or, date of execution of Waiver of Notice of Intention to under Section 3301(c) of the Divorce Code: by Plaintiff: by Date: September 17, 2008 JAMES, SMITH, Susan . adel, Esqi Attorney for Plaintiff Post Office Box 650 Hershey, PA 17033 (717) 533-3280 PA I.D. No. 44837 ipe to j under Section 3301(d) Entry of a Divorce Decree & CONNELLY,LLP ELISA S. COHEN, Plaintiff V. SCOTT A. COHEN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND C LINTY, PENNSYLVANIA No. 01-2080 CIVIL ACTION - L W IN DIVORCE CERTIFICATE OF SERVICE I, Susan M. Kadel, Esquire, of James, Smith, Dietterick & C Defendant, Scott A. Cohen, hereby certify that I have served a cof Request Entry of Divorce Decree on the following on the date and in U.S. MAIL. FIRST CLASS, PRE-P Constance P. Brunt, Esquire Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 JAMES, SMITH, D Date: ?? a?`• y? By: / Susan M. Nadel, Esqui Attorney for Defendan- Post Office Box 650 Hershey, PA 17033 (717) 533-3280 PA I.D. No. 44837 , LLP, attorney for the of the Notice of Intention to manner indicated below: & CONNELLY ELISA S. COHEN, Plaintiff V. SCOTT A. COHEN, Defendant IN THE COURT OF 1 CUMBERLAND COI No. 01-2080 CIVIL ACTION - LA IN DIVORCE CERTIFICATE OF SERVICE I, Susan M. Kadel, Esquire, of James, Smith, Dietterick & Defendant, Scott A. Cohen, hereby certify that I have served a copy of Transmit Record on the following on the date and in the manner Constance P. Brunt, Esquire Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 Dated: October 9, 2008 By: JAMES, SMITH, DIE & CONNELLY, LLP Susan M. Kadel Attorney I.D. #44837 P.O. Box 650 Hershey, PA 17033-0650 (717) 533-3280 Attorneys for Defendant 4ON PLEAS PENNSYLVANIA y, LLP attorney for the foregoing Praecipe to below: CK ?- P,::7 -I'I ?> C ?3 i'ti"4 I V .?.? ? !_ 7 ?' i . ' ('1 .. ? f , ' ?a , '? Constance P. Brunt, Esquire Supreme Court ID #29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 FAX (717) 232-0255 cpbrun CPBruntLaw.com Attorney for Plaintiff ELISA S. COHEN, Plaintiff V. SCOTT A. COHEN, Defendant TO: Curtis Long, Prothonotary : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW : NO. 01-2080 : IN DIVORCE PRAECIPE Please mark as withdrawn and discontinued the Plaintiffs claims for equitable distribution, alimony and alimony pendente lite, counsel fees, costs and expenses, as set forth in Counts 11, III, and IV of Plaintiffs Complaint filed herein on August 13, 2008. DATE: /r 14KCZ 7/L;4 CONSTANCE P. BRUNT, ESQUIRE Supreme Court ID # 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110-3339 (717) 232-7200 FAX (717) 232-0255 cpbruntO-CPBruntLaw.com Attorney for Plaintiff V. CERTIFICATE OF SERVICE I, CONSTANCE P. BRUNT, ESQUIRE, do hereby certify that on the day of /Ya,2, 4 , 2008, 1 served a true and correct copy of the Inventory Of ELISA S. COHEN, by depositing the same in the United States mail, first-class postage prepaid, at Harrisburg, Pennsylvania, addressed to the following: Susan M. Kadel, Esquire James, Smith, Dietterick & Connelly, LLP 134 Sipe Avenue PO Box 650 Hershey, PA 17033 Attorney for Defendant CONSTANCE P. BRUNT, ESQUIRE Supreme Court I.D. No. 29933 Beaufort Professional Center 1820 Linglestown Road Harrisburg, PA 17110 (717) 232-7200 (FAX) (717) 232-0255 cgbruntO-CPBruntLaw.com Attorney for Plaintiff r) '", °-t c ,_.. -w ELISA S. COHEN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. SCOTT A. COHEN NO 01-2080 DIVORCE DECREE AND NOW, - COS , it is ordered and decreed that ELISA S. COHEN plaintiff, and SCOTT A. COHEN 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, f r ? V /, r.,? r - ? f j / ,?7..' i?'"' ??"? 'a'il, ?- I _. /,! / // y _,- t1 ? f Jt ?x ? ??` '?.