HomeMy WebLinkAbout99-05285
Ix:
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF PENNA.
SHERI D. COOVER,
99-5285 CIVIL TEfJ
Plaintiff No. - ...................... .................
... ........
Versus
JEFFREY D. COOVEIZ
Defendant
DECREE IN
••,, DI VORCE
AND NOW, ......../"#1CvVJA1 a0???tlis o dered and
..................
SHERI D. COOVER
decreed that .................................................• plaintiff,
JEFFREY D. COOVER
and .........................................................• defendant,
are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have
been raised of record in this action for which a final order has not yet
been entered; Hone.
.. ...1T.. IS.. FVATXgR..OnER]RD.. And. .ARORE&D.. ghat.. the ..terms ..a1}d
conditions of the Marital Settlement Agreement attached hereto,
At'e' 'ibCbi'lftfth'ted' h'eYAia 'byr' refer .. ... ' ........................
By h ur
Attest: --?,
Prothonotary
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MARITAL SETTLEMENT
BY AND BETWEEN
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SHERI D. COOVER
AND
JEFFREY D. COOVER
Jordan D. Cunningham, Enquire
Cunningham & Chernicoff, P.C.
2320 North Second Street
P. O. Box 60457
Harrisburg, PA 17106-0457
(Attorney for Sheri D. Coover)
MARITAL 3STTLSMSNT AGRRSMRNT
THIS AGREEMENT is made by and between SHERI D. COOVER,
of Carlisle, Cumberland County, Pennsylvania (hereinafter
referred to as "WIFE"), and JEFFREY D. COOVER, of
Shippensburg, Cumberland County, Pennsylvania (hereinafter
referred to as "HUSBAND"),
WITNESSETH:
WHEREAS, WIFE was born on April 2S, 1969, and
currently resides at 1133 Pheasant Drive, North, Carlisle,
Pennsylvania;
WHEREAS, HUSBAND was born on June 22, 1971 and
currently resides at 12 Wyrick Avenue, Shippensburg,
Pennsylvania;
WHEREAS, the parties hereto are husband and wife,
having been married on July 28, 1990, in Shippensburg,
Pennsylvania;
:ny
WHEREAS, the parties are the parents of the following
minor children:
Name
Tyler Matthew Coover
I'
Andrew Jeffrey Coover
Patrick Samuel Coover
Date of Birth
M 1/17/91
M 12/14/92
M 12/27/94
WHEREAS, the parties hereto are desirous of settling
fully and finally their respective financial and property
rights and obligations as between each other, including,
without limitation, the settling of all matters between
them relating to the ownership of real and personal
property, the support and maintenance of one another, and
in general, the settling of any and all claims and possible
claims by one against the other or against their respective
estates.
NOW, THEREFORE, in consideration of these premises,
and of the mutual promises, covenants, and undertakings
hereinafter set forth, and for other good and valuable
consideration, receipt and sufficiency of which is hereby
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j acknowledged by each of the parties hereto, HUSBAND and
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WIFE, each intending to be legally bound hereby, covenant
and agree as follows:
1. ADVICE OF COUNSEL: The provisions of this
Agreement and their legal effect have been fully explained
to WIFE by her counsel, Jordan D. Cunningham, Esquire.
WIFE and HUSBAND declare that each has had a full and fair
opportunity to obtain independent legal advice of counsel
of her and his selection; that WIFE has been independently
represented by counsel and that HUSBAND, cognizant of his
right to legal representation, declares that it is his
express, voluntary and knowing intention not to avail
himself of his right to counsel and chooses instead to
represent himself with respect to the preparation and
execution of this Agreement. Each party acknowledges that
he or she has had the opportunity to receive independent
legal counsel of his or her selection, and that each fully
understands the facts and his or her legal rights and
obligations, and each party acknowledges and accepts that
this Agreement is, in the circumstances, fair and
equitable, and that it is being entered into freely and
voluntarily, and that execution of this Agreement is not
the result of any duress or undue influence, and that it is
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not the result of any improper or illegal agreement or
agreements. In addition, each party hereby acknowledges
that he or she is aware of the impact of the Pennsylvania
Divorce Code, 23 Pa. C.S.A. 53101, vt a=., whereby the
Court has the right and duty to determine all martial f
rights of the parties including divorce, alimony, alimony
pendente lite, equitable distribution of all marital
property or property owned or possessed individually by the
other, counsel fees and costs of litigation and, fully
knowing the same, and being fully advised of his or her
rights thereunder, each party hereto still desires to
execute this Agreement, acknowledging that the terms and
conditions set forth herein are fair, just and equitable to
each of the parties, and waives his and her respective
right to have the Court of Common Pleas of Cumberland
County, or any other court of competent jurisdiction, make
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any determination or order affecting the respective
parties, rights to alimony, alimony pendente lite,
equitable distribution of all marital property, counsel
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fees and costs of litigation, or any other right arising
from the parties' marriage.
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2. PERSONAL PROPERTY: HUSBAND warrants and
represents to WIFE, and WIFE warrants and represents to
HUSBAND, that they have effected a fair and equitable
division of all marital property of the parties, and that
any and all marital property, except as expressly provided
herein, presently in possession or under the control of
WIFE shall be the property solely of WIFE, and that any and
all marital property, except as expressly provided herein,
presently in possession or under the control of HUSBAND
shall be the property solely of HUSBAND.
WIFE shall have sole rights of possession, title
and ownership to the personal property presently in her
possession, and HUSBAND does hereby waive and relinquish
any and all right he has or may have to claim any interest
or share in said personal property.
HUSBAND shall have sole rights of possession,
title and ownership to the personal property presently in
his possession, and WIFE does hereby waive and relinquish
any and all right she has or may have to claim any interest
or share in said personal property.
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Neither party shall make any claim to any items
of marital property, or of the separate
personal property
of either party, which are awarded to the other pursuant to
the provisions of this Agreement or which are now in the
possession and/or under the control of the other. Should
it become necessary, the parties each agree to sign, upon
request, any titles or documents necessary to give effect
to this paragraph. Property shall be deemed to be in the
possession or under the control of either party if, in the
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case of tangible personal property, the item is physically
in the possession or control of the party at the time of
the signing of this Agreement, and in the case of
intangible personal property, if any physical or written
evidence of ownership, such as passbook, checkbook, policy
or certificate of insurance or other similar writing is in
the possession or control of the party.
HUSBAND and WIFE do hereby waive and forever
release any interest or right either may have to make any
claim against or to assert any interest or right to or in
any retirement plan, pension plan, profit sharing plan, or
other employee benefits of any nature or type earned or
provided to the other.
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3. REAL PROPERTY: For and in consideration of the
sum of Twenty Three Thousand and 00/100 Dollars
($23,000.00) representing WIFE'S marital property interest
in the former marital residence to be paid at execution of
'i this Agreement, WIFE shall make, execute and deliver to
HUSBAND a special warranty deed conveying, transferring and
granting to HUSBAND all of her right, title and interest in
and to the real property of the parties situated at and
known as 12 Wyrick Avenue, Shippensburg, Cumberland County,
Pennsylvania. The aforesaid sum shall be paid to WIFE upon
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execution and delivery of this Agreement and the warranty j
deed. This is not a conveyance or sale.
4. DEBTS AND INDEMNIFICATION: HUSBAND and WIFE
represent and warrant to each other that except as provided
herein, neither one has contracted, since separation or
will in the future contract, any debts, charges or
liabilities whatsoever for which the other party or their
property or their estates shall or may be or become liable
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or responsible, and they covenant that they will at all
times keep each other free, harmless and indemnified
against and from any and all debts and liabilities
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heretofore or hereafter contracted or incurred by the
other, except as expressly provided in this Agreement.
S. WAIVER OF RIGHTS AND MUTUAL RELEASE: The parties
hereto have been informed of their rights by their
respective counsel under and pursuant to the Divorce Code,
Act of April 2, 1980, Number 1980-26, particularly the
provisions for alimony, alimony pendente lite, equitable
distribution of marital property, counsel fees or expenses.
Both parties agree that this Agreement shall conclusively
provide for the distribution of property under the said law
and hereby waive, release and relinquish any further rights
they may respectively have against the other for alimony,
alimony pendente lite, equitable distribution of marital
k property, counsel fees or expenses. From the date hereof,
each party may acquire either personal or real property in
their own name. Any property so acquired shall be owned
solely by that party and shall not be subject to any claim
whatsoever by the other party.
Subject to the provisions of this Agreement, each
party has released, discharged and, by this Agreement, does
for himself or herself, and his or her heirs, legal
is
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representatives, executors, administrators and assigns,
release and discharge the other of and from all cause of
actions, claims, rights or demands whatsoever, in law or
equity, which either of the parties ever had, now have, or
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can have at any time against the other, specifically
including rights or claims to spouse support, alimony,
alimony pendente lite, counsel fees and expenses, and
equitable distribution of marital property, except for any
cause of action for divorce from the bonds of matrimony and
any cause of action for breach of any provisions of this
Agreement.
The parties hereto expressly relinquish and waive
any and all rights that they may have now or in the future
to claim and/or obtain spouse support, alimony pendente
lite, alimony, counsel fees and expenses or equitable
distribution of property.
This Agreement is not intended to be nor shall it
be construed or deemed to be a release or waiver of any
right WIFE or HUSBAND may have to claim, assert or obtain
social security benefits to which either may be entitled by
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virtue of the marriage relationship between HUSBAND and
WIFE.
6. ESTATE RELEASE: Except as herein otherwise
provided, each party may dispose of his or her property in
any way, and each party hereby waives and relinquishes any
and all rights he or she may now have or hereafter acquire,
under the present or future laws of any jurisdiction, to
share in the property or the estate of the other as a
result of the marital relationship, including without
limitation, dower, courtesy, statutory allowance, widow's
allowance, right to take property under equitable
distribution, right to take in intestacy, right to take
against the will of the other, and right to act as
administrator or executor of the others estate, and each
will, at the request of the other, execute, acknowledge,
and deliver any and all instruments which may be necessary
or advisable to carry into effect this mutual waiver and
relinquishment of all such interests, rights and claims.
7. AFTER ACQUIRED PERSONAL PROPERTY: Each of the
parties shall hereafter own and enjoy, independently of any
a
i? claims or right of the other, all items of real and
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personal property, tangible or intangible, hereafter
acquired by him or her, with full power in him or her to
dispose of the same as fully and effectively, in all
respects and for all purposes, as though he or she were
unmarried.
8. PRIOR INCOME TAX RETURNS: The parties have
heretofore filed joint federal and state income tax
returns. HUSBAND agrees that in the event any deficiency
in federal, state, or local income tax is proposed, or any
assessment of any such tax is made against WIFE by reason
of her having joined in the filing of said joint returns,
HUSBAND will indemnify and hold WIFE harmless from and
against any loss or liability for any such tax deficiency
or assessment and any interest and penalty incurred as a
result of HUSBANDS misrepresentation or failure to
disclose the nature and extent of HUSBAND'S separate
income, and WIFE hereby agrees that she will indemnify and
hold harmless HUSBAND from and against any loss or
liability for any tax deficiency or assessment and any
interest and penalty incurred as a result of WIFE'S
misrepresentation or failure to disclose the nature and
extent of WIFE'S separate income.
9. REPRESENTATIONS AND WARRANTIES: The parties
acknowledge that they have been advised by their respective
counsel of their right to require the filing of financial
disclosure statements by the other prior to the entering
into this Agreement, and being so advised the parties
acknowledge that they have waived their right to request
such financial disclosure. However, each of the parties
hereby warrant and represent to the other that at the time
of separation, they had no right, title and interest in any
real or personal property with a fair market value in
excess of Five Hundred and 00/100 Dollars ($500.00) except
for any asset or item of real or personal property
specifically described and awarded pursuant to Paragraphs
i and 2 of this Agreement.
10. SEPARATION: It shall be lawful for each party at
all times hereafter to live separate and apart from the
other party at such place or places as he or she may from
time to time choose or determine fit.
11. NO INTERFERENCE: Each party shall be free from
interference, authority and control, direct and indirect,
by the other as fully as if he or she were single and
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unmarried. Neither shall molest the other, compel, or
endeavor to compel, the other to cohabit or dwell with him
or her, or to interfere with friendships, society or
acquaintances which either of the parties hereto may choose
or have from this day forward. Neither party shall do or
say anything to the children of the parties at any time
which might in any way influence the children adversely
against the other party.
12. DOCUMENTS: Each party shall, at the request of
the other, execute, acknowledge and deliver to the other
party any documents which may be reasonably necessary to
give full force and effect to this Agreement.
13. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS: This
Agreement shall not be considered to affect or bar the
right of WIFE or HUSBAND to a divorce on lawful grounds as
such grounds now exist or shall hereafter exist or to such
defense as may be available to either party. This
Agreement is not intended to condone and shall not be
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deemed to be a condonation on the part of either party
hereto of any act or acts on the part of the other party
which have occasioned the disputes or unhappy differences
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which have occurred prior to or which may occur subsequent
to the date hereof. The parties intend to secure a mutual
consent, no fault divorce pursuant to the terms of Section
3301(c) of the Divorce Code of 1980. The parties agree to
sign all necessary documents, including Affidavits of
Consent, to secure said no-fault divorce.
14. ABSOLUTE AND FINAL SETTLEMENT: The provisions of
this Agreement are intended to consider, determine, and
distribute all of the assets of the parties hereto as part
of the terms of this Postnuptial Agreement. This Agreement
is intended by the parties hereto to be a valid Postnuptial
Agreement, providing for the absolute and final settlement
of their respective property rights and all obligations of
spouse support. This Agreement is not intended to be a
mere Separation Agreement. This Agreement contains the
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entire understanding of the parties, and there are no
representations, warranties, covenants or promises other
than those expressly set forth in this Agreement.
15. VOLUNTARY EXECUTION AND FAIRNESS OF AGREEMENT:
Each party acknowledges that this Agreement has been
entered into of his or her own volition, (with full
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knowledge of the facts and full information as to the legal
rights, liabilities and the assets of the other), and that
each believes the Agreement to be reasonable under the
circumstances and not the result of any duress or undue
influence.
16. MODIFICATION AND WAIVER: Neither this Agreement
nor any provision thereof shall be amended or modified or
deemed amended or modified, except by an agreement in
writing duly subscribed and acknowledged with the same
formality as this Agreement. Any waiver by either party of
any provision of this Agreement, or any right or option
hereunder shall not be deemed a continuing waiver, and
shall not prevent or estop such party from thereafter
enforcing such provision, right or option, and the failure
of either party to insist in any one or more instances upon
the strict performance of any of the terms or provisions of
this Agreement by the other party shall not be construed as
a waiver or relinquishment for the future of any such term
or provision, but the same shall continue in full force and
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effect.
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17. SITUS: This Agreement shall be construed and
governed in accordance with the laws of the Commonwealth of
Pennsylvania.
18. INDEPENDENT SEPARATE COVENANTS: It is specifi-
cally understood and agreed by and between the parties
hereto that each paragraph hereof shall be deemed to be a
separate and independent covenant and agreement.
If any term, condition, clause or provision of
this Agreement shall be determined or declared to be void
or invalid in law or otherwise, then only that term,
condition, clause or provision shall be stricken from this
Agreement and in all other respects this Agreement shall be
valid and continue in full force, effect and operation.
19. DESCRIPTIVE HEADINGS: The descriptive headings
used herein are for convenience only. They shall have no
effect whatsoever in determining the rights or obligations
of the parties.
20. SURVIVAL OF THIS AGREEMENT: It is the intention
of the parties that this Agreement shall survive any action
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for divorce which may be instituted or prosecuted by either
party and no Order, judgment or decree of divorce
(temporary, interlocutory, final or permanent) shall affect
or modify the financial terms of this Agreement.
21. BREACH: If either party breaches any provision
of this Agreement, (excluding however, provisions or terms
relating to child custody or child support) the other party
shall have the right, at his or her election, to sue for
damages for such breach, or seek such other legal or
equitable remedies or relief as may be available to him or
her; and the party breaching this contract hereby agrees to
be responsible for payment of all attorneys fees, legal
costs and expenses incurred by the other in enforcing their
rights under this Agreement.
22. BINDING EFFECT: Each of the parties hereto
intends to be legally bound hereby, and this Agreement
shall be binding upon their heirs, personal representatives
and assigns of the respective parties hereto.
IN WITNESS WHEREOF, the parties have hereunto set
their hands and seals the day and date first written, each
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adopting the seal following his or her signature as his or
her own.
•., TI. ne ,n
HUSBAND:
4FY COOVER
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1 4.
COMMONWEAL H OF PENNSYLVANIA
COUNTY OF L?
On this, the ? day of A, be,- 2001,
before me, a Notary Public, the undersigned officer,
personally appeared SHERI D. COOVER known to me (or
satisfactorily proven) to be the person whose name is
subscribed to the foregoing Postnuptial Agreement and
acknowledged that she executed the same for the purposes
therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and
official seal.
Blan"a A. 1h
H9RbC
Comm COMMONWEALTH OF PENNSYLVANIA : My Hart b UfQ,
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COUNTY OF member, ennsy var
On this, the --?k Q4 day of 200',
before me, a Notary Public, the U-n-dersigned officer,
personally appeared JEFFREY D. COOVER known to me (or
satisfactorily proven) to be the person whose name is
subscribed to the foregoing Postnuptial Agreement and
acknowledged that she executed the same for the purposes
therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and
official seal.
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SHERI D. COOVER,
Plaintiff
V.
JEFFREY D. COOVER,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5285
CIVIL ACTION - ACTION
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following
information, to the Court for entry of a Divorce Decree:
1. Ground for divorce: irretrievable breakdown under
3301-fe} or 3301(d)(1) of the Divorce Code. (Strike out
inapplicable section.)
2. Date and manner of service of the rmmnlainf•.
(a) Date of execution of the Affidavit of Consent
required by 53301(c) of the Divorce Code: by Plaintiff:
November 9. 2001: Defendant: November 2. 2001.
(b) (1) Date of execution of the Affidavit required by
53301(d) of the Divorce Code: N/A.
(2) Date of filing and service of the Plaintiff Is
Affidavit upon the respondent: N/A.
4; Related claims pending: All economic and
the parties.
3. (Complete either Paragraph (a) or (b)).
S. (Complete either Paragraph (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: N/A
(b) Date Plaintiffis Waiver of Notice in 53301(c)
Divorce was filed with the Prothonotary: November 14
2001.
Date Defendants Waiver of Notice in 53301(c)
Divorce was filed with the Prothonotary: November 14
2001.
Respectfully submitted,
, P. C.
11 . Date:November 14, 2001
,Jdrdan . Cunningham, Esquire
I.D. 3144
2320 North Second Street
P. O. Box 60457
Harrisburg, PA 17106-0457
(Attorneys for Plaintiff)
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CUNNINGHAM & CHERNICOFF, P.C.
-• .
SHERI D. COOVER,
Plaintiff
V.
JEFFREY D. COOVER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. J42 K5
CIVIL ACTION - LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend
against the claims set forth in the following pages, you must
take prompt action. You are warned that if you fail to do so,
the case may proceed without you and a Decree of Divorce or
annulment may be entered against you by the court. A judgment
may also be entered against you for any other claim or relief
requested in these papers by the Plaintiff. You may lose
money or property or other rights important to you, including
custody or visitation of your children.
When the ground for 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 Dauphin County
Courthouse, Harrisburg, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS ENTERED, 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 Court Administrator
Cumberland County Courthouse-4th Floor
1 Courthouse Square
Carlisle, PA 17013-3387
Telephone: (717) 240-6200
CUNNINGHAM & CHERNICOFF, P.C.
Date: Cltt ?;.??\ 31;. q li By:?
Paige Macdonald-Matthes, Esquire
I.D. #66266
2320 North Second Street
P.O. Box 60457
Harrisburg, PA 17106-0457
(717) 238-6570
SHERI D. COOVER,
Plaintiff
V.
JEFFREY D. COOVER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. -2
CIVIL ACTION - LAW
IN DIVORCE
COMPLAINT UNDER SECTION 3301(c)
OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, Sheri D. Coover, by and
through her attorneys, Cunningham & Chernicoff, P.C., who
files this Complaint in Divorce, alleging the following:
1. Plaintiff is Sheri D. Coover, who currently resides
at 35 North 4th Street, Apartment 1, Newport, Perry County, PA
17074. The Plaintiff is a citizen of the United States of
America and has been issued social security number 172-58-
5805.
2. Defendant is Jeffrey D. Coover, who currently
resides at 12 Wyrick Avenue, Shippensburg, Cumberland County,
Pennsylvania, 17257. The Defendant is a citizen of the United
States of America and has been issued social security number
229-90-3249.
3. Plaintiff and Defendant have been bona fide
residents in 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 July 28,
1990 in Shippensburg, Pennsylvania.
5. The Plaintiff and Defendant separated on July 15,
1999.
6. The marriage is irretrievably broken.
7. The Plaintiff avers that she is the innocent and
injured spouse, and the Defendant has offered such indignities
to the Plaintiff so as to render her condition intolerable and
life burdensome.
8. There have been no prior actions for divorce or
annulment of marriage between the parties in this or any other
jurisdiction.
9. Plaintiff has been advised that counseling is
available and that Defendant may have the right to request
that the Court require the parties to participate in
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counseling.
10. Plaintiff avers that there are three (3) children of
this marriage under the age of eighteen (18) years of age,
Tyler Matthew Coover, DOB January 17, 1991; Andrew Jeffrey
Coover, DOB December 14, 1992; and Patrick Samuel Jordan
Coover, DOB December 27, 1994.
WHEREFORE, Plaintiff requests this Court to enter a
Decree of Divorce, and further award Plaintiff all such other
relief as is proper and just.
COUNT II- EQUITABLE DISTRIBUTION
11. The averments in Paragraphs 1 through 10, inclusive,
are incorporated herein by reference thereto.
12. During the course of the marriage, the parties
acquired marital property.
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WHEREFORE, the Plaintiff requests the Court to equitably
determine, divide, distribute and assign the marital property
of the parties pursuant to Section 3501 of the Divorce Code.
Respectfully submitted,
CUNNINGHAM & CHERNICOFF, P.C.
Date: C??t 3„ M 99 By: kL .n Iwo. c c1?. oS?a rh„9?c 4a c
Paige Macdonald-Matthes, Esquire
I.D. #66266
2320 North Second Street
P.O. Box 60457
Harrisburg, PA 17106-0457
(717) 238-6570
(Attorneys for Plaintiff)
4
VERIFICATION
I, Sheri D. Coover, verify that the statements made in
the foregoing Complaint in Divorce are true and correct to the
best of my knowledge, information and belief. I understand
that false statements herein are made subject to the penalties
of 18 Pa. C.S. §4904, relating to unsworn falsification to
authorities.
N?.u?. COocie?,
rS eri D. Coover
Date:_ U,)O" f l
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF Lure zLoioh ss;
The Plaintiff, being duly sworn according to law, deposes
and says that she is the Plaintiff in the above captioned
matter and that she personally knows that the Defendant is
over the age of eighteen (18) years.
The Plaintiff further avers that the Defendant is in the
National Guard out of Chambersburg, Franklin County,
Pennsylvania, however, he has not been deployed. Defendant is
not in the Military Service or in any branch of the Armed
Forces of the United States of America or its Allies or
otherwise within the provisions of the Soldiers, and Sailors,
Civil Relief Act of Congress of 1940 and its Amendments.
(Jeri D. Coover
SWORN and Subscribed to
Before me this day
of 1999.
NOT/ Y PUBLIC
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AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA :
COUNTY OF BA4PH-IN
I, Sheri D. Coover, being duly sworn according to law,
depose and say:
(1) 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 Domestic
Relations Office, which list is available to me
upon request.
(3) Being so advised, I do not request that
the Court require that my spouse and I participate
in cn-seling prior to a Divorce Decree being
ha,,led 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 au /Aorities? ^.
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CS eri D. Coover
SWORN and Subscribed to
Before me this day
of _auqu6e 1999.
NOTARY PUBLIC
Mr=,,
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Coumy ;iq. 1990
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SHERI D. COOVER, :IN THE COURT OF COMMON PLEAS
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99-5285
JEFFREY D. COOVER, :CIVIL ACTION - LAW
Defendant :IN DIVORCE
PROOF OF SERVICE
I do hereby certify that a true and correct copy of the
Complaint in Divorce in the above captioned matter was served
on Defendant, Jeffrey D. Coover, by First Class, Certified
Mail, Restricted Delivery, postage prepaid, on September 2,
1999. The receipt card is attached hereto.
Respectfully submitted,
CUNNINGHAM & CHERNICOFF, P.C.
Date: September 7, 1999 By: CA .
Beth A. Theurer, Secretary to
Paige Macdonald -Mat thes, Esquire
I.D. #66266
2320 North Second Street
P.O. Box 60457
Harrisburg, PA 17106-0457
(717) 238-6570
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SHERI D. COOVER,
Plaintiff
V.
JEFFREY D. COOVER,
Defendant
IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5285
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under 53301(c) of the
Divorce Code was filed on August 30, 1999.
2. The marriage of Plaintiff and Defendant is
irretrievably broken and ninety (90) days have elapsed from
the date of filing and service of the Complaint.
3. 1 consent to the entry of a Final Decree of
Divorce after service of Notice of Intention to Request
Entry of the Decree.
I verify that the statements made in this Affidavit
are true and correct. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S.
94904 relating to unsworn falsification to authorities.
I I 1 C V i ?^ {. l.C
Date:
ERI D. COOVER
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SHERI D. COOVER,
Plaintiff
V.
JEFFREY D. COOVER,
Defendant
:IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5285
CIVIL ACTION - LAW
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER 93301(C) OF THE DIVORCE CODE
1. I consent to the entry of a Final Decree of 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. 1 understand that I will not be divorced until a
Divorce Decree is entered by the Court and that a copy of
the Decree will be sent to me immediately after it is filed
with the Prothonotary.
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.
54904, relating to unsworn falsification to authorities.
Date: ,'I 1 CI _r(?Cl?
HERI D. COOVER
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SHERI D. COOVER, : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. 99-5285
CIVIL ACTION - LAW
JEFFREY D. COOVER,
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under §3301(c) of the Divorce
Code was filed on August 30, 1999.
2. The marriage of Plaintiff and Defendant is
irretrievably broken and ninety (90) days have elapsed from
the date of filing and service of the complaint.
3. I consent to the entry of a Final Decree of Divorce
after service of Notice of Intention to Request Entry of the
Decree.
I verify that the statements made in this Affidavit are
true and correct. I understand that false statements herein
are made subject to the penalties of 18 Pa.C.S. 54904 relating
to unsworn falsification to authorities.
Date ?--1s
JEV?M-1) . COOVER
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SHERI D. COOVER,
Plaintiff
V.
JEFFREY D. COOVER,
Defendant
:IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5285
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER 53301(C) OF THE DIVORCE CODE
1. I consent to the entry of a Final Decree of Divorce
without notice.
2. I understand that I may lose rights concerning
alimony, division of property, lawyers 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 that false statements
herein are made subject to the penalties of 18 Pa. C.S.
§4904, relating to unsworn falsification to authorities.
Date:.xJ6) vO0/ '` _
JE y COOVBR
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