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HomeMy WebLinkAbout99-06430I V G ?? ?+ y f 5 S' Y p t xri i Y? ` ? tk !i t I 7 ?' z } . rN'.b? 3 z>? ? 'gf?.'Sik`? s ? 5 ?. ?f f'+ k ((m.. 7 iy t y x Y ? ? K 2? X r'?3 ? S } y psi •} Y 4 ? , ? CT Y X 3 ' 1r•• r. 3 ?id . t4 ? +n a + t t r ski ??*n*. x e ' r 1 t -, r5F4 3i a k ? yJ r W i o t 4 c S ? s ? z 4 Y t? l t i Mal t ? ?. s t NE ' 1 l } O " , `d'am k •k k pe'S Y ? I t WE z ^ ?¢- c? 't YX a. r y( kr Y r } r1 yl y?£j r ? }?N } { F kY rj 1 £ S 1? ? z And, h 4 xF +. >? } P §3 . f ?j 1x '?5 ? ,> 14 60, S Zoo i INA! •:ri •:r? •:s+ •:r• •:N :r• :ti •XP 00 -We -.V? '0 -'V- 00 -'*e ,W. 6r. -*0 -.4r. -We Y 1 IN THE COURT OF COMMON PLEAS i? OF CUMBERLAND COUNTY y STATE OF PENNA. r '®r JEFFREY•_S....KOOSER, N o...997643.0- CIVIL.... 19 t ... Plaintiff.. Va•eus s ERIN E. ROOSERr ._ __ .... ii Defendant y r, DECREE IN DIVORCE ; AND NOW, .... .. ?.S ... ".2ooq, it is ordered and G decreed that .. . . . . . . . JEFFREY. , S.• , ROO$ER, • Plaintiff, ?; ..... and . . . . . . . ..ERIN .E.. xoosm ............................. . defendant, i, are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have ti been raised of record in this action for which a final order has not yet R i been entered; is Nvpe ...................................... ?............. 3 i1 ................. C R By Thic Cc ur/ ? s Attest ? ?; 3? A ¦? r Prolhnnotnry Y r. u. rx: •i: •w: ar, ?w:• •x.• ev.:e:• •;.;• .:e: W. te: W. •x.• :e:.*W. <e:• •:e} •:r. •:e::.: ce:• •:.:• •:e:• •:r.• te> a:• tr. JEFFREY S. KOOSER, IN THE COURT OF COMMON PLEAS Plaintiff DAUPHIN COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ERIN E. KOOSER, NO. 99-6430 CIVIL Defendant IN DIVORCE PRAECIPE TO TRANSWr 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(c) of the Divorce Code. 2. Date and manner of service of the Complaint: certified mail. return recetot mquested. restricted delivery on October 27. 1999. 3. (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce Code: by Plaintiff 1/31/00 ; by Defendant 1/29/00. (b)(1) Date of execution of the Affidavit required by § 3301(d) of the Divorce Code: (2) Date of filing and service of Plaintiffs Affidavit upon the Defendant: 4. Related claims pending: nom 5. (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 Plaintiffs Waiver of Notice in § 3301(c) Divorce was fled with the prothonotary: 213/00. Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: 2/4/00. '.? 2 Attorney forlylair# ff ^ C) L y C: 1?t ? ley C.: it GOLDBERG, KAIZMAN & SHIPMAN, P.C. Paul J. Esposito - I.D. #25454 Attorneys for Plaintiff 320 Market Street, Strawberry Square Post Office Box 1268 Harrisburg, PA 17108.1268 (717) 234-4161 JEFFREY S. KOOSER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ERIN E. KOOSER, NO. 0*9 Defendant IN DIVORCE You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Goldberg, Kuunen & Shipnuo, P.C. Paul J. Esposito, Esquire - I.D. /15454 110 Market Street Post Me too: 1165 Harrisburg, PA 17105.1265 Attorneys for Plahaiff JEFFREY S. KOOSER, Plaintiff V. ERIN E. KOOSER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. t999 - 6 9036 e, Tu •-- CIVIL ACTION - LAW IN DIVORCE JEFFREY S. KOOSER, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require my spouse and I to 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 that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I verify that the statements made in this Waiver 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 unswom falsification to authorities. Date: /0 /i JEFFREY S. KOOSER GOLDMMG, KATZMAN & SHWAAN, P.C. Paul J. E*wito - I.D. /25454 Attorneys for Plaintiff 320 Market Street, Strawberry Square Post Office Box 1268 Harrisburg, PA 17108-1268 (7M 2344161 JEFFREY S. KOOSER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW ERIN E. KOOSER, NO. S 199 - t 14u ee '?a ru-- Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff, JEFFREY S. KOOSER, is an adult individual, who currently resides at 137 Red Tank Road, Boiling Springs, Cumberland County, Pennsylvania. 2. Defendant, ERIN E KOOSER, is an adult individual who currently resides at 1401 State Street, Chambersburg, Franklin County, Pennsylvania. 3. Plaintiff avers that he has been a bona fide resident in the Commonwealth of Pennsylvania for a period of at least six (6) months previous to the filing of this Complaint. 4. The parties were married on August 21, 1999, in Connellsville, Fayette County, Pennsylvania. 5. There have been no prior actions of divorce or annulment filed by either of the parties hereto. 6. Plaintiff has been advised of the availability of counseling and that Plaintiff has the right to request that the Court require the parties to participate in counseling. 7. The Defendant in this action is not presently a member of the United States Armed Forces or of any of its allies. 8. Plaintiff requests the court to enter a decree of divorce. 9. The averments of Paragraphs 1 through 8 herein are hereby incorporated by reference thereto. 10. The marriage is irretrievably broken. WHEREFORE, Plaintiff prays Your Honorable Court to: (a) Enter a Decree in Divorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between Plaintiff and Defendant; and (b) Order such other relief as the Court deems just and reasonable. Respectfully submitted, GOLDBERG, KATZMAN & SHIPMAN, P.C. B 4KWJZ2? PAUL J. P STTO, ESQUIRE Post Office Box 1268 Harrisburg, PA 17018-1268 Supreme Court ID #25454 Attorneys for Plaintiff I verify that the statements contained in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief. I understand that false statements contained herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Date: b /&&- /iYr?*i JEFFERY. KOOSER V P= r I L FL 6 c N D N c v'T :Z L` A r ? )- P <zt ? ? 00 p oolaerg. Katrmn A Shipman, P.C. Pwl J. FAi aito, Esquire - I.D. x25474 320 Muket Sint Pod onla Box 1268 Harrisburg. PA 17108.1268 Attwu r fm Plaints r JEFFREY S. KOOSER, Plaintiff V. ERIN E. KOOSER Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6430 CIVIL CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF DAUPHIN Personally appeared before me, a Notary Public, in and for said Commonwealth and County, PAUL J. ESPOSITO, ESQUIRE, who being duly sworn according to law deposes and says that on October 25, 1999, he sent a certified copy of a Complaint in Divorce by certified mail, return receipt requested, restricted delivery, to Erin E. Kooser, 1401 State Street, Chambersburg, PA 17201, and the return receipt card signed by Erin Kooser, and shown as being delivered October 27, 1999, is attached hereto and made a part hereof. 96?IA-Z'/ PAUL J. PO ITO, ESQUIRE Sworn to and subscribed before me this 20th My Commission E*pires: Notarial Seat Victoria Y. Chambers, Notary Public Harrisburg, Dauphln County My Commission Explros Apr. 7, 2003 • Complete items 1, 2, and 3. Also complete hem 4 If Restricted Delivery Is, desired. j Print your name and address on thf reverse that we can return the card to you. ' WiMach this card to the back of the mallpi or on the front It space permits. ' 1. Ankle Addressed tQ: i , 1 ? 140 strati I ? r-?41 Mich AW 07 cl 71 ' r n? ., Flu IW u+ CJ a GOLDBERG, KA4ZMAN & SWMAN, P.C. Paul J. Egmlto - I.D. #25454 Attorneys for Plaintiff 320E Market Street P.O. Box 1268 Harrisburg, PA 17108.1268 (717) 234.4161 JEFFREY S. KOOSER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-6430 CIVIL ERIN E. KOOSER, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on October 21, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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. Section 4904, relating to unswom falsification to authorities. Date: gyec , /• Ao '^ 4 &10?0 JEFFREY %. KOOSER ? G?; ' ? ?. ' ! 1r.! ?? C` ? t sti _J 1 ' C.,, , C ?L .., ? fr y . _ S? .} `S n ,? JEFFREY S. KOOSER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-6430 CIVIL ERIN E. KOOSER, : CIVIL ACTION -LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTEN'PION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(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. 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 unswom falsification to authorities. Date: .S 00 JEFFREY S. KOOSER m u? F' C%J - Cl JEFFREY S. KOOSER, Plaintiff V. ERIN E. KOOSER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 99-6430 CIVIL CIVIL ACTION -LAW IN DIVORCE 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on October 21, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have clapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling and I understand that I may request that the Court require that my spouse and I participate in counseling. I understand that the Court maintains a list of marriage counselors, which lisi is available to me upon request. Being so advised, I do not request that the Court require my spouse and I to participate in counseling prior to a divorce being handed down by the Court. 5. I acknowledge that I received a copy of the Complaint in Divorce on or about October 27, 1999. 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 unsworn falsification to authorities. Date: i 121 0") n ( Y`'' ERIN E. KOOSER i= - co Ot- .?Y t,• F.' C. -: (Ij V . ,.y. sfi If „t Ctiv v? I yr SSG+?y i r*; d) ? „may • Y. LL ? r'hl' 4' C! ? at1?R1}y}? JEFFREY S. KOOSER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 99-6430 CIVIL ERIN E. KOOSER, CIVIL ACTION -LAW Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(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. 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 unswom falsification to authorities. Date: t 1,7 0 ERIN E. KOOSER :• CO f= L. L L'