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Home My WebLink About01-04614MICHAEL L. COYLE, Plaintiff v. AUDRA L. COYLE, Defendant 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 that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. 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 WHERE YOU CAN GET LEGAL HELP. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ~ I .- ~ 61 ~# CIVIL TERM CIVIL ACTION -LAW IN DIVORCE Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 LAW OFFICES SNELBAKER, BRENNEMAN R SPARE SNELBAKER, BRENNEMAN & SPARE, P.C. By: ~~ Attorneys for Plaintiff MICHAEL L. COYLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 0 I- 4 (, ~ Y CIVIL TERM CIVIL ACTION -LAW AUDRA L. COYLE, Defendant IN DIVORCE COMPLAINT COUNT I -DIVORCE 1. Plaintiff MICHAEL L. COYLE is an adult individual residing at 391 Crossroad School Road, Newville, Cumberland County, Pennsylvania. 2. Defendant AUDRA L. COYLE is an adult individual residing at 391 Crossroad School Road, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents 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 lawfully joined in marriage on May 4, 1996 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction since the date of the marriage averred in 4, above. LAW OFFICES SNELBAKER, BRENNEMAN & SPARE 6, Neither party is a member of the armed forces of the United States of America. 7. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. 8. The Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. The Plaintiff requests this Court to enter a decree of divorce. COUNT II - EQUITABLE DIVISION OF PROPERTY 10. The Plaintiff and Defendant have legally and beneficially acquired property and debt during their marriage from May 4, 1996. 11, The Plaintiff and Defendant have not agreed as to any equitable distribution of their property and debts. 12. The Plaintiff requests this Court to equitably divide all marital property and debts pursuant to Section 3502 of the Pennsylvania Divorce Code. WHEREFORE, the Plaintiff requests this Court to: (a) enter a decree of divorce, divorcing the Plaintiff from the bonds of matrimony; LAW OFFICES SNELBAKER, BRENNEMAN & SPARE (b) order equitable distribution of marital property; and -2- (c) order such other relief as this Court deems just and reasonable. SNELBAK~ER~, BRENNEMAN & SPARE, P.C. Keith O. Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055-0318 Telephone: 717-697-8528 Date: August 2, 2001 Attorneys for Plaintiff LAW OFFICES SNELBAKER. BRENNEMAN & SPARE -3- VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4909 relating to unsworn falsification to authorities. ~. ~,,/; ._ 7~P-D/ el L. Coyle Date: August 2, 2001 LAW OFFICES SNELBAKER. BRENNEMAN & SPARE MICHAEL L. COYLE, v. AUDRA L. COYLE, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA NO. -CIVIL TERM Defendant :CIVIL ACTION -LAW IlV DIVORCE AFFIDAVIT MICHAEL L. COYLE, being duly sworn according to law, deposes and says: I . 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. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do NOT request that the court require my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. 7~p/ ichael L. Coyle (Plaintiff) LAW OFFICES SNELBAKER, BRENNEMAN & SPARE Date: August 2, 2001 S ~ Cll U1 ~' O -P M c-~ ~ Ci {' Z .a. 7 L.. UJ ~' by -C r_ Gt'' "~ { ~• ~. ~ Cff .. t.3 -G ~ c/'` r~, _' T . ,'f: ;_} ='' C J -: ''i C;:' C"> C7 ~sl ~% 4. G MICHAEL L.COYLE, Plaintiff v. AUDRA L. COYLE, Defendant IN THE COURT OF COMMON PLEAS OF °CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4614 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND Keith O. Brenneman, Esquire, being duly sworn according to law deposes and says: that LAW OFFICES S NEl.9AKER, BRENNEMAN & SPARE he is a principal in the law firm of Snelbaker, Brenneman & Spare, P. C., being the attorneys for Michael L. Coyle, Plaintiff in the above captioned action in divorce; that on August 2, 2001, he did send to Defendant Audra L. Coyle by certified mail, return receipt requested, restricted delivery, a duly certified copy of the Complaint in Divorce which was filed in the above captioned action as evidenced by the attached cover letter of the same date and Receipt for Certified Mail No. 7000 1670 0008 5047 3145; that both the Complaint and cover letter were duly received by Audra L. Coyle, the Defendant herein, as evidenced by the return receipt card for said certified mail dated August 4, 2001; that a copy of the aforementioned cover letter dated August 2, 2001 is attached hereto and incorporated by reference herein as "Exhibit A" and that the original Receipt for Certified Mail and the Domestic Return Receipt are attached hereto and incorporated by reference herein as "Exhibit B' ;and that the foregoing facts are true and correct t to the best of his knowledge, information and belief. Keith O. Brenneman Sworn to and subscribed before me this 8"' day of August, 2001. ~~ i Notary Pub is Bwq Crta~iM~C~MV ~ n P~v.24, ~~ LAW OFFICES SNELBAKER. BRENNEMAN Hf SPARE _2_ ,. SNELBAKER, BRENNEMAN F3 SPARE A PROFESSIONAL CORPORATION ATTORNEYS AT LSW 44 WEST MABY STREET MECHANICSBURG, PENNSYLVANIA V055 RICHARD C SNELBAKEA KEITH O. BRENNEMAN PHILIP H. SPARE Audra L. Coyle 391 Crossroad School Road Newville, PA 17241 717-697-8528 August 2, 2001 Re: Coyle v. Coyle No. 2001-4614, Cumberland County Deaz Mrs. Coyle: ,, P. O. BOX 318 FACSIMILE (717) 697-7681 Enclosed please find a certified copy of a Divorce Complaint noting that a divorce action has been initiated on August 2, 2001. Yours truly, Keith O. Brenneman KOB/sz Enclosure CC: Michael Coyle (w/enclosure) Via certified mail, return receipt requested, restricted delivery, pazcel No. 7000 1670 0008 5047 3145 EXHIBIT A ~, m - ~~ i4' i i'~ H ~ Postage $ ~ ~'~'] O yT Certifietl Fee 2 . 1 Q tmark ~ ~ Return Raoeipt Fee (Entlorsament Required) 1.50 d ere 1 O Resttlctatl Delivery Fee (Entlarsement Requiretl) 3.20 ~ Totel Postage & Foes $ Z. .d A Sent To Audra L. Coyle O _ _ Street, Apt. No.; or PO Box No. ° 391 Crossroad School Road a r` __.. C,ty, Stele. P __________________________________ ..,....----------- 1~dPaville, PA 17241 ___ _...__ LAW OFFICES SNELBAKER. BRENNEMAN $r SPARE ~~dnplete items f, 2, and 3. Also complete item 4'If Restricted Delivery is desired. ^ ~IHflt your name and address on the reverse- &9jthat we can return the card to you. s ,4ktach this card to the back of the mailpiece, or on the front if space permits. A. (Received by (Plea/se~Print Clearly) 8. Date of DI~I /-/17d,JrG WCI~P O"~'0~ l~ C. Sig ! re T~_ X ^ AgeM ddes D. Is delivery address tlifferent fro item 77 - ~~r-rY'es If YES, enter delivery address below: ~do 1. Article Addressetl to: A~tdra' L. Coyle 391 Crossroad School Road ~ewville, PA 17241 i 3. Service Type %~I Cert~ed Mail ^ Express Mail ^ Registered ^ Return Receipt for Merchandise D Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Fee) vTBayas - 2. Article Number (Copy from service label) 7QQ0 167,0 0(iO8 5047 3145 PS Form $811, July 7999 Domestic Retum Receipt 7025g5~00-tit+0®52 EXIiIBIT B ~ c'a ?: `b l'7 Xiw " _, _ a n~iS, " C _ .r, J 'rr.-~ (%{- ~ __ _ = ~T `<'' C~i ~. r- \. - i ~ . ~~ -~ ~ ' - ~_ ' "~r~~l. ~ ~ C. Y`1 :~ rrl 4 ,) phi ~< ~Ti ~ . ~~ a__ .w. $3sx~ _ MICHAEL L. COYLE, PLAINTIFF vs. AUDRA L. COYLE, DEFENDANT : IN THE COURT OF COMMON PLEAS OF CUMBERLAIM COUNTY, :PENNSYLVANIA NO. 01-4614 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE P A_ PECI E FOR E1~1TRY OF APPEARANCE Please enter my appearance on behalf of the Defendant, Audra L. Coyle. Respectfully submitted, Dated: August ~, 2001 LAW FIRM OF SUSAN KAY Susan Kay Ca cell ~Esgi PA LD. # 64 8 5021 East Trin Ro Suite 100 Mechanicsburg FA 17050 (717)796-1930 P.C. ~ ~ -' ; c LL. ~ -~ ~ r.; ' m,-; ~ _ - _'' U ~ E -C. ~ , ~ F- C, -i -=. y' r- ~=- ~. -!: tLY