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HomeMy WebLinkAbout03-2714 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDA C. COHEN, vs. CIVIL ACTION - LAW NO. 03 / ~ 7 JLf MICHAEL S. 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 foregoing 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 in divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 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 Telephone: (717) 249-3166 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDA C. COHEN, vs. CIVIL ACTION - LAW NO. MICHAEL S. COHEN, Defendant IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDA C. COHEN, vs. CIVIL ACTION - LAW NO. 0.3.- J.. 7 ,'-I MICHAEL S. COHEN, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, LINDA C. COHEN, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is LINDA C. COHEN, an adult individual who currently resides at 536 West Cumberland Street in Enola, Cumberland County, Pennsylvania. 2. The Defendant is MICHAEL S. COHEN, an adult individual who currently resides at 541 West Cumberland Street in Enola, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 13 October 1973 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I - IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. COUNT II - EQUITABLE DISTRIBUTION 9. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as martial property. COUNT III - ALIMONY 10. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 11. Plaintiff is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 12. The Defendant is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance of the Plaintiff and pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. COUNT IV - ALIMONY PENDENTE LITE 13. Plaintiff is without sufficient income to support and maintain herself during the pendency of this action. 14. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her reasonable alimony pendente lite during the pendency of this action. COUNT V - COUNSEL FEES AND EXPENSES 1 5. Plaintiff is without sufficient funds to retain counsel to represent her in this matter. 16. Without competent counsel, Plaintiff cannot adequately prosecute her claims against Defendant and cannot adequately litigate her rights in this matter. 1 7. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's attorney and the expense of this litigation. WHEREFORE. Plaintiff prays this Honorable Court to order Defendant to pay the legal fees and expenses incurred by Plaintiff in this litigation of this action. ~..._--~ ~.~ Sa L. Andes Attorney for Plaintiff Supreme Court 10 # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 VERI FICA nON I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 1 8 Pa. C.S. 4904 (unsworn falsification to authorities). Date: j\ ('^:...A \ .4 L ~ l">;) -'~ .~.o, 0. ~ LINDA-C. COHEN _~_'M___._'''..'. A\\ ....... '-l ~ "'\ ~ ~ (..., \ ~ V' ~ ~ '.. ~---" ';...~.) ',.n .< I"'; ~~ (,.. V' , ~ (-) ...~ 'i,:; SHERIFF'S RETURN - REGULAR CASE NO: 2003-02714 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND COHEN LINDA C VS COHEN MICHAEL S GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - DIVORCE was served upon COHEN MICHAEL S the DEFENDANT , at 2035:00 HOURS, on the 16th day of June , 2003 at 541 WEST CUMBERLAND STREET ENOLA, PA 17025 by handing to MICHAEL S COHEN a true and attested copy of COMPLAINT - DIVORCE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 10.35 .00 10.00 .00 38.35 r~~.c~ R. Thomas Kline 06/20/2003 SAMUEL ANDES Sworn and Subscribed to before By: ..r< J )~ .~..~ (/VI Deputy Sh 1ff .., me this 30 ~ day of ~ 7.(}f)3 A.D. n o.~^jp;(; '-l~honotary '.f J COMMONWEALTH OF PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY LINDA C. COHEN, No. 03 - 2714 Plaintiff v. CIVIL ACTION - LAW MICHAEL S. COHEN, Defendant IN DIVORCE DEFENDANT'S REQUEST FOR COUNSELING I, Michael S. Cohen, do hereby request marriage counseling by a marriage counselor mutually agreed upon by Plaintiff and me through our respective counsel. Date: 07-67- O"} ~~<~ - Michael S, ohen, Defendant - CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the foregoing Defendant's Request for Counseling on counsel for Plaintiff, by placing the same in the United States Mail at Harrisburg, Pennsylvania, first-class postage prepaid, on the p- day of July, 2003, addressed as follows: Samuel L. Andes, Esquire 525 North 12th Street Lemoyne, Pennsylvania 17043 (Attorney for Plaintiff) Attorney for Defendant Michael S. Cohen o c ;;'". -orti "'''1''. Z:':LI ~';. r':lf""'; ;,r-'-- ~() >?::' z ...:.J -< o w ,- c: ,.. I -.I . , o ~Tl -v ..,., r:;;:: ....,(i'1 ',;r, <'I ~;C) ;\ :+i ":::.f5 ~', I" '~3 ~ -< r;:> ~ -""" COMMONWEALTH OF PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY LINDA C. COHEN, No. 03 - 2114 Plaintiff v. CIVIL ACTION - LAW MICHAEL S. COHEN, Defendant IN DIVORCE COUNTER-AFFIDAVIT OF MICHAEL S. COHEN UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1 . I oppose the entry of a divorce decree because: (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses, or other important rights. 3. I understand that in addition to making a claim for economic relief as stated above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the Divorce Decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claim. I verify that the statements made in this Counter-Affidavit 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. Date: 07-D 7- 03> -2- CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the foregoing Counter- affidavit of Michael S. Cohen under Section 3301 (d) of the Divorce Code on counsel for Plaintiff, by placing the same in the United States Mail at Harrisburg, Pennsylvania, first- class postage prepaid, on the fiT~day of July, 2003, addressed as follows: Samuel L. Andes, Esquire 525 North 12th Street Lemoyne, Pennsylvania 17043 (Attorney for Plaintiff) John vas ,/ ,- // Atttney for Defendant Michael S. Cohen 0 c:> 0 ~ W .n s:. <- -on' c ~D rn r""] ,- " Z i" I J"") Z l;:-J (/) :" -.l _? .: :,-:) r': ~" -;:J " 0<"""'. ~r"-" ::t.: in $~ ~ ~' ~) rn ~:::l -/' ::> 51 S! .l='" -<. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDA C. COHEN, Plaintiff CIVIL ACTION - LAW vs. NO. 2003-2714 MICHAEL S. COHEN, Defendant IN DIVORCE MOTION FOR HEARING ON APL REQUEST AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes,' and requests that the Domestic Relations Office schedule a conference and, if necessary, a hearing on her request for Alimony Pendente Lite, which was first raised in her Complaint in Divorce which was filed in June of 2003, a copy of which is attached. -3~~-J~~~ Sa I L. Andes Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDA C. COHEN, vs. CIVIL ACTION - LAW NO. O:J - .2 71cr MICHAEL S. COHEN, Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in I the foregoing pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree in divorce or annulment may be I entered against you by the court. A judgment may also be entered againtt' y05:;for'.~n'Y other claim or relief requested in these papers by the Plaintiff. You mav.:cj(fse m'Oneyiar, property or other rights important to you, including custody or visitation~t'youO:hildhrj!J. ;jl' 0 ' _/ - ,'~' When the ground for the divorce is indignities or irretrievable brea~pwn ~ the)~ marriage, you may request marriage counseling. A list of marriage COul$ti1.~rs \!bavalJ6~le L__ u -"I in the Office of the Prothonotary at: :e;; :..n ::5 --< (,W -< Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 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 I_EGAL HELP. II II II II Ii Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 Telephone: (717) 249-3166 Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDA C. COHEN, vs. CIVIL ACTION - LAW NO. MICHAEL S. COHEN, Defendant IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302 (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty days of the date on which you receive this notice. Failure to do so wi!1 constitute a waiver of your right to request counseling. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDA C. COHEN, vs. CIVIL ACTION - LAW NO. MICHAEL S. COHEN, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, LINDA C. COHEN, by her attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is LINDA C. COHEN, an adult individual who currently resides at 536 West Cumberland Street in Enola, Cumberland County, Pennsylvania. 2. The Defendant is MICHAEL S. COHEN, an adult individual who currently resides at 541 West Cumberland Street in Enola, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on 13 October 1973 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT I - IRRETRIEVABLE BREAKDOWN 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the Divorce Code of Pennsylvania. II II I COUNT II - EQUITABLE DISTRIBUTION 9. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joiint names and in the individual names of each of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Defendant, to equitably divide the property, both real and personal, owned by the parties hereto as martial property. COUNT III - ALIMONY 10. Plaintiff lacks sufficient property to provide for her reasonable needs in accordance with the standard of living of the parties established during the marriage. 11. Plaintiff is unable to support herself in accordance with the standard of living of the parties established during the marriage through appropriate employment. 12. The Defendant is employed and enjoys a substantial income from which he is able to contribute to the support and maintenance .of the Plaintiff and pay her alimony in accordance with the Divorce Code of Pennsylvania. WHEREFORE, Plaintiff prays this Honorable Court to enter an Order awarding Plaintiff from Defendant permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff in the station of life to which she has become accustomed during the marriage. COUNT IV - ALIMONY PENDENTE LITE 13. Plaintiff is without sufficient income to support and maintain herself during the pendency of this action. 14. Defendant enjoys a substantial income and is well able to contribute to the support and maintenance of Plaintiff during the course of this action. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay her reasonable alimony pendente lite during the pendency of this action. COUNT V - COUNSEL FEES AND EXPENSES 1 5. Plaintiff is without sufficient funds to retai n counsel to represent her in this matter. 16. Without competent counsel, Plaintiff cannot adequately prosecute her claims against Defendant and cannot adequately litigate her rights in this matter. II I 17. Defendant enjoys a substantial income and is well able to bear the expense of Plaintiff's attorney and the expense of this litigation. WHEREFORE, Plaintiff prays this Honorable Court to order Defendant to pay the legal fees and expenses incurred by Plaintiff in this litigation of this action. ~-~ ~D Sa L. Andes Attorney for Plaintiff Supreme Court 10 # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 I I VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that any false statements in this Complaint are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: .1'\ ~'1 ^:....~ -~ .~ c, Q. LINDA-C. COHEN Q~.,- ..-\.- .). ;'<>"j I p U -...t.. cf- cJ 1P D () C) c::-:) fi (~) --"1 c:> :.., '"t) 1";- ,~~ ,. nc , .-i " ~ , "- i" , , '>.1 (....'1 r" , (-.) r-:-: ;r,. ;:~ 1"1 ::.t >c;, .c.:,. ;"il '" :;, :i;; _. ,- ':'0 (1"\ -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDA C. COHEN, Plaintiff CIVIL ACTION - LAW VS. NO. 2003-2714 MICHAEL S. COHEN, Defendant IN DIVORCE DRS ATTACHMENT FOR APL PROCEEDINGS PETITIONER NAME LINDA C. COHEN ADDRESS 536 WEST CUMBERLAND STREET ENOLA, PA 17025 BIRTH DATE AUGUST 17, 1949 SOCIAL SECURITY NUMBER 182-40-7937 HOME PHONE 732-1639 WORK PHONE NONE EMPLOYER NAME NONE EMPLOYER ADDRESS N/A JOB TITLE/POSITION N/A DATE EMPLOYMENT COMMENCED N/A GROSS PAY N/A NET PAY SERS - $108.09 PER MONTH SOCIAL SECURITY - $104.Q1 PER MONTH OTHER INCOME NONE ATTORNEY'S NAME SAMUEL L. ANDES ATTORNEY'S ADDRESS 525 NORTH 12TH STREET LEMOYNE, PA 17043 ATTORNEY'S PHONE NUMBER (717) 761-5361 RESPONDENT NAME MICHAEL S. COHEN ADDRESS 541 WEST CUMBERLAND STREET ENOLA, PA 17025 BIRTH DATE MARCH 23, 1949 SOCIAL SECURITY NUMBER 197-40-5216 HOME PHONE WORK PHONE 608-9400 EMPLOYER NAME NESTRONIX, INC. EMPLOYER ADDRESS 1900 AM DRIVE QUAKERSTOWN, PA 18951 JOB TITLE/POSITION UNKNOWN DATE EMPLOYMENT COMMENCED UNKNOWN BUT MORE THAN A YEAR AGO GROSS PAY $3,323.08 1 BI WEEKLY NET PAY $2,659.481 BI WEEKLY OTHER INCOME UNKNOWN ATTORNEY'S NAME JOHN HAVAS, ESQUIRE ATTORNEY'S ADDRESS 6121 STEPHENS CROSSING MECHANICSBURG, PA 17050 ATTORNEY'S PHONE NUMBER 979-4840 MARRIAGE INFORMATION DATE OF MARRIAGE OCTOBER 13, 1973 PLACE OF MARRIAGE CARLISLE, PENNSYLVANIA DATE OF SEPARATION MAY 2003 ADDRESS OF LAST MARITAL HOME 541 WEST CUMBERLAND STREET ENOLA, PA 17025 DESCRIPTION OF DOCUMENT RAISING APL COMPLAINT FOR DIVORCE CLAIM DATE APL DOCUMENT FILED JUNE 10, 2003 LINDA C. COHEN, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA VS, CIVIL ACTION - DIVORCE MICHAEL S. COHEN, Defendant/Respondent NO. 2003-2714 CIVIL TERM IN DIVORCE Pacses# 797105882 ORDER OF COURT AND NOW, this 24th day of November, 2003, 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 Januarv 5. 2004 at 9:00 A.M for a conference, at 13 N. Hanover SI., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. 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 1910.1l<<:l (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 11-24-03 to: Petitioner < Respondent Samuel Andes, Esquire John Havas, Esquire -/1 <L. pLUA.L4- l~ ~ (~r Date of Order: November 24. 2003 R. J. Shadday, Conference Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FINn OUT WHERE YOU MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIA nON 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cC361 CJ C >- l~.- Z -:J ;.~)~ '-.".~ '-)~ -::J --(I) .':z: ~-" ......." ,;jL'] :"-;JC.l.. ?5 (.) -::; .-'-- (',; ,~) ;-::.:) LINDA M. COHEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 03-2714 CIVIL TERM MICHAEL S. COHEN, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 10 June 2003 and was served upon the Defendant on or about 16 June 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. I consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counseling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 7?Ur:-.f?/J62 ~... MICHAEL S: COHtON DATE ,..., 0 = =, '" oS:' ::r. :;:l 7P' fn:D :;Q -of;; \ .'''6 ....') 6 ~-,; r::: c.,:i! - ..-,~ ( -' '~.' - 8t11 c: ~.-' ~ .'h "" :;J C.') ....-;:: " 1':1' LINDA M. COHEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 03-2714 CIVIL TERM MICHAEL S. COHEN, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 33011c) 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 I 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 that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand hat false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. -'_._~4i,.' .",~~ ",> , . 6;2 C .. R - - MICHAEL 5,. COHEN (') ~-; ~:\' ~ ~ J:' '% ~ I u:> '~~:.:~ r;:.'.:,.~- :~~.:i,~:': )?~ :3.. o --\1 -, ~1:. :rJ 11''''-: -d'Q t\b ~:;:\ Dr'" ?:: ft\ 9 ~; ~ 5:' - - - c.,;l !I LINDA M. COHEN, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, ) PENNSYLVANIA ) vs. ) CIVIL ACTION - LAW ) ) NO. 03-2714 CIVIL TERM MICHAEL S. COHEN, ) Defendant ) IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please withdraw the Defendant's Counter-Affidavit Under Section 3301 (d) of the Divorce Code and Defendant's request for counseling previously filed in this matter. C) ...., c = 0 = ;;?'~ or- .." :z ::;:! ;po ;;:0 nl:D r- I -om \.0 96 c ;;> :i!jj ru' 9(-) S~ (Sin :2 ::~ :-.0 (.:> -< In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION LINDA C. COHEN ) Docket Number 03-2714 CIVIL Plaintiff ) vs. ) PACSES Case Number 797105882 MICHAEL S. COHEN ) Defendant ) Other State ID Number ORDER AND NOW, to wit on this 1ST DAY OF JUNE. 2004 IT IS HEREBY ORDERED that the 0 Complaint for Support or 0 Petition to Modify or 0 Other filed on OCTOBER 17, 2003 in the above captioned ALIMONY PENDENTE LITE matter is dismissed without prejudice due to: THE PARTIES NOT PURSUING THE MATTER THROUGH THE DOlllESTIC RELATIONS SECTION. o . !he Complaint or Petition may be reinstated upon written application of the plaintiff petitIOner. DRO: RJ Shadday xc: plaintiff defendant Samuel Andes, Esquire John Havas. Esquire JUDGE Service Type M ~llt'i~D Form OE-S06 Worker ID 21005 0 ....., c:: = 0 = ?;: .r:- ., to-CO, <- :r..,., (= ( ..~,.... ~~ n'F I -om N B? -0 :r!u ..,. C) -:;,.. C):!J -",- ~._- (~. (^". ~nl ~- '-:? ;-::-= __._1 ,-I -< W ,,::.~ ._:0 -< ,: ".I " LINDA M. COHEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2003-2714 CIVIL TERM MICHAEL S. COHEN, Defendant 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. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c). 2. Date and manner of service of the Complaint: Acceptance of Service filed bv Plaintiff's counsel indicatina service on or about 16 June 2003. 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: By Plaintiff: 16 February 2005 By Defendant: .1Q Februarv 2005 (b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: 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, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Dated 16 February 2005 and filed contemporaneously herewith. Date Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: Dated 16 February 2005. and filed contemporaneous Iv herewith. Date: 16 February 2005 B,~Sh.~~ '- uel L. A s Attorney for Plaintiff " Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LINDA M. COHEN, vs. CIVIL ACTION - LAW NO. 03-2714 CIVIL TERM MICHAEL S. COHEN, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 lcl of the Divorce Code was filed on 10 June 2003 and served upon the Defendant on or about 16 June 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. I consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing of my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counselling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ~-/~-~S- Date ~;~, \(VI, ~, LINDA M. COHEN LINDA M. COHEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW 1\10.03-2714 CIVIL TERM MICHAEL S. COHEN, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 10 June 2003 and was served upon the Defendant on or about 16 June 2003. 2. The marriage of Plaintiff and Defendant is irrEltrievably broken and ninety (90) days have elapsed from the date of filing of the complaint and the date of service of the complaint on the Defendant. 3. I consent to the entry of a final decree in divorce either after service of a Notice of Intention to Request Entry of the Decree or upon filing (If my Waiver of the Notice of Intention to Request Entry of the Decree. 4. I have been advised of the availability of marrilage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and, being so advised, do not request that the Court require that my spouse and I participate in counSElling prior to the divorce becoming final. I verify that the statements made in this Affidavit are true and correct and I understand that false statements herein are made subje1ct to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATE as- ~~~~ MICHAEL S. C N " LINDA M. COHEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 03-2714 CIVIL TERM MICHAEL S. COHEN, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 IC) 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 I 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 that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Waiver are true and correct. I understand that false statements herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. ..2-/~-t7.7 Date ~=-.D, ~ C'~ LINDA M. COHEN LINDA M. COHEN, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND COUNTY, ) PENNSYL VANIA ) vs. ) CIVIL ACTION - LAW ) ) 1\10.03-2714 CIVIL TERM MICHAEL S. COHEN, ) Defendant ) 111I DIVORCE WAIVER OF NOTICE OF INTENTION 1'0 REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301lcl 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 concernin~1 alimony. division of property, lawyer's fees, or expenses if I do not claim them before, a divorce is granted. 3. I understand that I will not be divorced until B1 divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand hat false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. ~>>ft:~ MICHAEL S. COHEN .' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . "":'+"'''' :f ... :f.:f.:f.:f. :f.:f. :+::+' ... . , .. .. " Of. :t::+:+ . . ;+:+.;+: Of' ;+::f,+ . IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. LINDA M. COHEN, Plaintiff NO. VERSUS MICHAEL S. COHEN, Defendant DECREE IN DIVORCE AND NOW, ~, 2005 , IT IS ORDERED AND 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; DECREED THAT LINDA M. COHEN AND MICHAEL S. COHEN ARE DIVORCED FROM THE BONDS OF MATRIMONY. NONE 2003-2714 , PLAINTIFF, , DEFENDANT, 'l Am':a~4 ~- .. .. 'f. 'f. 'f ~ Of '+' Of '+ Of '+ '+ '+ Of '+' fI' '+'+ 't''+'+'f.'f ;"+';1;'+:10'+ PROTHONOTARY +1 Of'l' 'f 'f.:f. Of.;f. Of. Of:+. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . . ,,' ~~7 ~~SOIE "l"'I1 i-" .~ ~.MP .I"f} .so./ .[ ., -<.' . ~ ~ ,., ..."'" - LINDA C. COHEN, Plaintiff ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW NO. 2003-2714 MICHAEL S. COHEN, Defendant IN DIVORCE MOTION TO CORRECT DIVORCE DECREE AND NOW comes the above-named Plaintiff, by her attorney, Samuel L. Andes, and i' I moves the court to modify and correct the final decree in divorce in this matter entered on 1 I March 2005 as follows: I I , ! I I I I I 1. The moving party herein is the Plaintiff, Linda C. Cohen. The responding party herein is the Defendant, Michael S. Cohen. 2. Plaintiff's name is Linda C. Cohen and that was correctly noted on the Complaint and in the original caption and other pleadings in the case. 3. When the final decree in divorce was prepared, because of a typographical error, Plaintiff's name was incorrectly listed as Linda M. Cohen. As a result, the final decree was entered in that name. 4. To correct the final decree in divorce, Plaintiff's name on the decree should be changed to "Linda C. Cohen", which is Plaintiff's actual and lawful name. WHEREFORE, Plaintiff moves this court to correct the final decree in divorce entered in this matter to reflect her correct name and to do so by entering the attached final decree. ,...~. t < ~~. fA Samuel L. An es Attorney for Plaintiff Supreme Court ID # 17225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 VERIFICATION I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date:__~//~ /rx;' ~ id ~_ Il~V SA EL L.~Ms , II . LINDA C. COHEN, Plaintiff vs. ) ) ) ) ) ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003-2714 If MICHAEL S. COHEN, Defendant IN DIVORCE JOINDER AND CONSENT I AND NOW comes the above-named Defendant, Michael S. Cohen, by his attorney John Havas, Esquire, and joins in the attached Motion to correct the Decree in Divorce and consents to the correction of the final Decree as requested in that Motion. 1 II D'te otJ- {" )0<0') I, I! II I I II I I " vs. ) IN THE COURT OF COMMON ) PLEAS OF CUMBERLAND ) COUNTY, PENNSYLVANIA ) ) CIVIL ACTION - LAW ) ) NO. 2003-2714 ) ) IN DIVORCE LINDA C. COHEN, Plaintiff i II MICHAEL S COHEN, I' Defendant il JOINDER AND CONSENT I AND NOW comes the above-named Defendant, Michael S. Cohen and joins in the I attached Motion to correct the Decree in Divorce and consents to the correction of the final Decree as requested in that Motion. Date: If/l7/oj ~<< Michael . Cohen I' Of'f:+:+' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ;t X~ . . . . . . . . . . . . . . . . , . . , . , . . . . . . , . , . . . . . , . . . . . , . . . . . . . . . '+':+:+;+. :+'+'+.:+'+':+'+:Of.'+''+'+':+.<t:'+::+ :++.,+,<t:+.+.+. :+:+.+.+. '+''+'+.+.+. +.+.+.'+'+.+.:++.+.'f:+:+:++''+'+'+'+' +.+.+.<t:'+':+;+.,+, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. LINDA C. COHEN. Plaintiff No. 03-2714 CIVIL TERM VERSUS MICHAEL S COHEN, Defendant DECREE IN DIVORCE JI,ND NOW, , IT IS ORDERED AND ZUUt> DECREED THAT . PLAI NTI FF, L1NUA C. GOHI:::N AND . DEFloNDANT, MICHAEL S. COHEN AflE 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 By THE COURT: ATTEST: . . . . . . . . . . . . . . Of'+'+''+'<t:+.+.+.+.+.,+,:+:+++.,+,+.+.~+.+.+.+.+.+.+.+.+.+.+.+.,+,+.+' PROTHONOTARY . . . +.+. +. + :-to: ~ +. :+' ~ '+: + +. +. + +. +. + :+. 'f + +. '+''1':+:+ +. '+' 'f +.:+ + +.+ '+'+ '+' +.:f '+' +. +:+:+ +:+ 'to '+' '+' , . . . . . . , . . . . , . , . . . , , . , . . . . . . . . . . . . . . . . . . . . , . . . . , . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. n c-' 0 , n , +n . .-1 -:-:c -n ril ,c::;, 1 C:) C) , c> ,. -, ~I.: " ! Ii ..J J) C) .< " LINDA C. COHEN, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. MICHAEL S. COHEN, DEFENDANT : 03-2714 CIVIL TERM AMENDED DECREE IN DIVORCE AND NOW, this -z.ts. ~ day of April, 2005, the motion of Linda C. Cohen to correct a name in the Divorce Decree entered on March 1, 2005, IS GRANTED. The name of plaintiff in that Decree, "Linda M. Cohen," is deleted and replaced with the name LINDA C. COHEN. By theC6urt, // :sal / C"P..~ J/:.v ~ /';}' '2'01 ';>!J-~'~)(., <jP"t77 ,F?l 217,r-" h7{19 ';:'>1.7 " . f" f~ ')~~.) -/~- n 5:;'/c'/7 /\1, ~, i: < i',... D I .... .,'-" 11 t _:, .t. ,.C. I') " ''I "''''7 (.I ('r;~' '::i0Ju N:i/1~j,~,: 3Hl =K) ':(;~: '!C)-G:f:d