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Home My WebLink About07-7365Stephanie A. Cooper, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Paul R. Cooper, Defendant NO. 07- 73&5 CIVIL TERM 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 right 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, 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 LAWYER, GO TO OR TELE PHONE 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 St. Carlisle, PA 17013 (717) - 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Stephanie A. Cooper, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Paul R. Cooper, Defendant NO. 07- 726 s' CIVIL TERM DIVORCE COMPLAINT UNDER TITLE 23 Pa C S §§3301(c) and (d) OF THE DIVORCE CODE The plaintiff, Stephanie A. Cooper, by her attorneys, the Family Law Clinic, sets forth the following causes of action in divorce: 1. Plaintiff is Stephanie A. Cooper, who currently resides at 1055 Nanroc Drive, Mechanicsburg, 17055, Cumberland County, Pennsylvania. 2. Defendant is Paul R. Cooper, who currently resides at 408 Centerview Avenue, New Cumberland, 17070, York County, Pennsylvania. 3. Plaintiff has been a bona fide resident of Cumberland County and the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 5, 1994, in Hagerstown, Washington County, Maryland. 5. Plaintiff and Defendant have lived separate and apart since March 27, 2006. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce dissolving the marriage. Respectfully submitted, Date 4?161a D d_7 Legal Intern ROB T E. RAINS THOMAS M. PLACE LUCY JOHNSTON-WALSH ANNE MACDONALD-FOX MEGAN RIESMEYER Supervising Attorneys Family Law Clinic 45 North Pitt Street Carlisle, Pennsylvania 17013 (717) 243-3696 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in this Complaint are true and correct to the best of my personal knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsific n to authorities. Dated: ?? -6 `!/ Stephanie A. Cooper kni 1 Stephanie A. Cooper, Plaintiff V. Paul R. Cooper, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE NO. 07- 73G1S CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Stephanie A. Cooper, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date ' %2 L a 06-7 ROBERT E. RAINS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 r,,?} N I {."t?_? ? 'T ; ,.- _ + i ? ??? - F r _.,?.. - .. } .:.;t i..i?i i{ r* h? ?. } .. Stephanie A. Cooper, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Paul R. Cooper, Defendant NO. 07-7365 CIVIL TERM CERTIFICATE OF SERVICE I, Marc Aoun, Certified Legal Intern, Family Law Clinic, hereby certify that I served a 0) O J N -, 0 0 Ln C w 0 C3 0 0 W, Ir. w .. ti it r? O. cr true and correct copy of the Divorce Complaint on Paul R. Cooper, residing at 408 Centerview Avenue, New Cumberland, Pennsylvania, 17070, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Paul R. Cooper, on the 10'b day of December 2007, as evidenced by the attached green card. r? Q zq M &:- 3' RV C d - ppi N o? o P ao K p ar 9 ? ca S z gam.. 00` 00 Certified Legal Intern Megan esmeYer Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 4 „mow ^r? -P » J r 1? ?+ CD Stephanie A. Cooper, Plaintiff V. Paul R. Cooper, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE NO. 07-7365 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on December 6, 2007. 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. §4904, relating to unsworn falsification to authorities. Date ? Q V a??42 - J*/_ Stephanie A. Cooper, Plaintiff -rts! ?O Stephanie A. Cooper, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Paul R. Cooper, Defendant NO. 07-7365 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on December 6, 2007. 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. §4904, relating to unsworn falsification to authorities. Date r' G ? t? ??c? ? ?? t RCs ' ? ,? ?? ? ?- ? rN Stephanie A. Cooper, Plaintiff V. Paul R. Cooper, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE NO. 07-7365 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 0301(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 unsworn falsification to authorities. Date Step anie A. Cooper, Plaintiff , c r c. N Stephanie A. Cooper, Plaintiff V Paul R. Cooper, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE NO. 07-7365 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(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 unsworn falsification to authorities. Date N f / /:); C t? ?:? 4 ' •-? : , :? 3..x.1' ?? v _, r .4 ;, ? 1? _Y( Stephanie A. Cooper, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Paul R. Cooper, Defendant NO. 07-7365 CIVIL TERM 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(c) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defendant by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Paul R. Cooper, on December 10, 2007. 3. Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff- April 3, 2008; by defendant- April 2, 2008. 4. Related claims pending: none 5. Date plaintiff s Waiver of Notice was filed with the Prothonotary: April 21, 2008. Date defendant's Waiver of Notice was filed with the Prothonotary: April 21, 2008. Date 'Nicole Berman-'' Certified Legal Intern 4 r Anne d-Fox, Es . Supervising Attorneys FAMILY LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Stephanie A. Cooper Plaintiff VERSUS Paul R. Cooper Defendant No. DECREE IN DIVORCE 07 - 7365 AND NOW, VOW144 ':uV Tl4F 0 R IT IS ORDERED AND DECREED THAT Stephanie A. Cooper , P LA I N T I F F, AND Paul R. Cooper ARE DIVORCED FROM THE BONDS OF MATRIMONY. DEFENDANT, 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; PROTHONOTARY u ?O ? '/?` .?P ??. y- ;- Stephanie A. Cooper, Plaintiff V. Paul R. Cooper, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 07 - 7365 CIVIL TERM NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in divorce from the bonds of matrimony on the May 28, 2008, hereby elects to retake and hereafter use her previous name of Stephanie Ann Armstrong, and gives this written notice avowing her intention in accordance with the provisions of 54 Pa.C.S. § 704. Wishes To Be Known As. COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Stephanie A. Cooper 4WI-XYQ? Stephan Ann Armstrong SS. On the day of 2008, before me, a Notary Public, personally appeared Stephanie A. Cooper, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS THEREOF, I have hereunto t my hand and Notarial Seal. ZIA OTAR IC Notarial Sea! Laurie L Wolf, Notary Publio Carlisle Boro, Cumberland County My Commission Expires Feb. 14, 2010 • x CE, W -? r.o G ?t t17 ,?C".? Q w DEC 88 2008,, I STEPHANIE A. COOPER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA • 61 - 7346' V. : NO. ZW 416 CIVIL ACTION - LAW PAUL R. COOPER, Defendant : IN CUSTODY ORDER OF COURT AND NOW, this 22°d of December, 2008, being advised that the parties have reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, acq line M. Verney, Esquire ustody Conciliator .,7 DEC 2 3 ZC% Stephanie A. Cooper, : IN THE COURT OF COMMON PLEAS OF NOW Stephanie Armstrong : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff V. : CIVIL ACTION - LAW IN CUSTODY Paul Cooper, -TV( Defendant : NO. 07-3366- CIVIL TERM ORDER OF COURT AND NOW, this day of , 2005!?, upon consideration of the attached Custody Agreement, it is hereby ordered that custody of the children Anthony Cooper, born April 25, 1995, and Darian Cooper, born August 15, 1997, shall be as follows: 1. Mother and Father shall share legal custody of the children. 2. Mother shall have primary physical custody of the children. 3. Father shall have periods of partial custody of the children. 4. Father shall have custody of Anthony every other weekend and every other major holiday. 5. Father shall have custody of Darian as the parties mutually agree, but at no point shall Darian go to Father's parents' home. 6. Mother and Father shall agree upon drop off and pick up times and locations. 7. Mother and Father shall notify each other of all medical care the children receive while in the parent's care. Mother and Father shall notify the other immediately of medical emergencies which arise while the children are in that parent's care. 8. Neither parent shall do anything which may estrange the children from the other party, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love and respect for the other parent. 9. All previous Court Orders in this matter are vacated. J. 6-?er? ?a;o ?;?, S ?? •6 ???? '+.G ?_af? ??Jl ?VtTt,? ci i ki ?L