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HomeMy WebLinkAbout07-4589TRACY COFFEE, Plaintiff, vs. CYNTHIA COFFEE, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 07- H58~ ~ivt ( I ~f'INI CIVIL ACTION -LAW IN DIVORCE N O T I C E 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 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 Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 TRACY COFFEE, Plaintiff, vs. CYNTHIA COFFEE, Defendant. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. ©~'- f~ Pq CIVIL ACTION -LAW 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 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 17013. 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. KOPE ~ ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY l.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 (beam@kopelaw.com TRACY COFFEE, Plaintiff, vs. CYNTHIA COFFEE, Defendant. Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. o~- ys~9 C'c~-~ T.,~.r-., CIVIL ACTION -LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, TRACY COFFEE, by and through his attorney, LESLEY J. BEAM, ESQ., and makes the following Complaint in Divorce: 1. The Plaintiff is TRACY COFFEE, an adult individual who currently resides at 28 E. Willow Terrace, Mechanicsburg, Cumberland County, Pennsylvania 17050. All legal papers may be served on the Plaintiff through his counsel at 4660 Trindle Road, Suite 201, Camp Hill, Pennsylvania 17011. 2. The Defendant is CYNTHIA COFFEE, an adult individual who currently resides at 28 E. Willow Terrace, Mechanicsburg, Cumberland County, Pennsylvania 17050. 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 married on September 1, 1972, in Wamer Robins, Houston County, Georgia, 5. The Parties separated on July 17, 2007, when Defendant informed Plaintiff of his intention to proceed with a divorce, and the parties began living separate and apart within the marital residence. 6. Neither the Plaintiff nor Defendant is in the military service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 7. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling and the right to request that the Court require the parties to participate in counseling. 9. Plaintiff and Defendant are both citizens of the United States. COUNT I REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 10. Paragraphs one through nine are hereby incorporated by reference herein as though fully set forth. 11. The marriage of the parties is irretrievably broken. WHEREFORE, if both parties file affidavits consenting to a divorce after (90) ninety days have elapsed from the date of service of this Complaint, Plaintiff respectfully requests that the Court enter a Decree of Divorce pursuant to Section 3301(c) of the Divorce Code COUNT II REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(d) OF THE DIVORCE CODE 12. Paragraphs one through eleven are hereby incorporated by reference as though fully set forth. 13. The marriage of the parties is irretrievably broken. 14. The parties are living separate and apart and at the appropriate time Plaintiff will submit an affidavit alleging that the Parties have lived separate and apart for at least two (2) years as specified in Section 3301(d) of the Divorce Code. WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree of Divorce pursuant to Section 3301(d) of the Divorce Code. COUNT III REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502(a) OF THE DIVORCE CODE 15. Paragraphs one through fourteen are hereby incorporated herein by reference as though fully set forth. 16. Plaintiff and Defendant have acquired marital property as defined by the Divorce Code, which is subject to equitable distribution pursuant to Section 3502(a) of the Divorce Code. 17. Plaintiff and Defendant have been unable to agree to the equitable distribution of said property, as of the date of filing of this Complaint. 18. Plaintiff requests that the Court equitably divide, distribute, or assign the marital property between the parties. WHEREFORE, Plaintiff respectfully requests that the Court enter an order of equitable distribution of marital property pursuant to Section 3502(a) of the Divorce Code. Respectfully Submitted, KOPE & ASSOCIATES Date: ~ d esle . B m, Esq. VERIFICATION I, Tracy Coffee, the Plaintiff in this matter, have read the foregoing Complaint. verify that my averments in this Complaint are true and correct and based upon my personal knowledge. I understand that any false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsifications to authorities. Dated:~~ 1 ..O SU rr•C~. Vl C~ ~, cr ;~ C (J'1 ~"' r r : ~ r-' ~ Z -- ~^~ .' t r :t: r~ ~'`~: N ~ ~^ . , , ~ c ~ ~ ~' ~~ r ~'1 ~'7 ~ .i ' .~ ''. J ~ ~! ' .. ~+..~ l KOPE & ASSOCIATES, LLC BY: LESLEY J. BEAM, ESQ. ATTORNEY l.D. 91175 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 (beam@kopelaw.com Attorney for Plaintiff TRACY COFFEE, IN THE COURT OF COMMON PLEAS Plaintiff, :CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 07-4589 CYNTHIA COFFEE, :CIVIL ACTION -LAW Defendant. IN DIVORCE ACCEPTANCE OF SERVICE I, Cynthia Coffee, Defendant in the above-captioned matter, hereby accepts service of the Complaint in Divorce. Date: ~ ~~'~ ~ 1U C hia Coffee Y `~' =n ~~ c -~ ~ ,.-~ ~.~- z~ ~ ~ , i~ ..-- ;cw, ..- ; '-, r' ra ' ; Yet -° {.3~t ...w'. ~~ ~" ~~ w JEANN)~ B. COSTOPOULOS, ESQUIRE Attorney I.D. No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone No. (717) 221-0900 TRACY COFFEE, :THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. CYNTHIA COFFEE, Defendant TO THE PROTHONOTARY: No. 07-4589 CIVIL TERM CIVIL. ACTION - AT LAW DIVORCE PRAECIPE TO ENTER APPEARANCE Kindly enter the appearance of Jeanne B. Costopoulos, Esquire, as attorney for Defendant, Cynthia Coffee, in the above captioned matter. Dated: l1 Jeann6 B. Costopoulos, Esquire PA Supreme Court ID No. 68735 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone: (717) 221-0900 ~~ ~+v t- CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing document to the person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of the same with the United States Post Office at Mechanicsburg, Pennsylvania, through first class mail, prepaid, and addressed as follows: Leslie J. Beam, Esquire KOPE & ASSOCIATES, LLC 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 BY: J~ann~ B. Costopoulos, Esquire 5000 Ritter Road, Suite 202 Mechanicsburg, PA 17055 Telephone: (717) 221-0900 PA Supreme Court ID No. 68735 Date: ~~~[~ ...s t/? Z ...- "+ ~ '~ 3 ~++ t;? '~ TRACY COFFEE, Plaintiff v. CYNTHIA COFFEE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No: 07-4589 CIVIL ACTION IN DNORCE PRAECIPE TO WITHDRAW AS COUNSEL Kindly withdraw my appearance as counsel for Tracy Coffee, Plaintiff with regard to the above-captioned matter. Date: ~~ ~ PRAECIPE TO ENTER APPEARANCE AS COUNSEL Kindly enter my appearance on behalf of Tracy Coffee, Plaintiff with regard to the above captioned matter. Date: ~~~ ~~2'~G-rte(..- ~ . `.. Michael M. Jeromins Esquire Attorney I.D. No. 92977 112 Market Street Harrisburg, PA 17101 Telephone (717) 236-9391 Facsimile (717) 236-6602 Attorney EnteringAj~pearance 4660 Trindle Road Camp Hill, PA 17011 Telephone (717) 761-7573 Facsimile (717) 761-7572 Attorney Withdrawing -- ~~ ' ~P ~~~ ra '; °~:, .~ 4 _~` ..r:- • e .. ~s"' ~T ~ ~ .A f ~ r