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Home My WebLink About04-0563 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Fredrick Paul Koser, Plaintiff : No. 04 - S'b3 C!"'u~L ~~ : Civil Action - Law vs. : In Divorce Vesta May Koser Defendant -- 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 in divorce or annulment may be 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 the custody or visitation rights 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlY - PENNSYLVANIA Fredrick Paul Koser, Plaintiff : No. 64- Sw (J~~(~~ : Civil Action - Law vs. : In Divorce Vesta May Koser Defendant COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Fredrick Paul Koser who currently resides at 236 Big Pond Road, Shippensburg, Cumberland County, Pennsylvania, since October 15, 1985. 2. Defendant is Vesta May Koser who currently resides at 205 Hamilton Road, Chambersburg, Franklin County, Pennsylvania 17201, since September 29, 2002. 3. Plaintiff and Defendant have been bona fide residents in 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 June 28, 1980, at Newburg Church of God, Newburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a decree of divorce. Respectfully submitted. ,~~ ,,-. , H. Anthony Adams, Esquire Attorney for Plaintiff 128 E. King Street Shippensburg, PA 17257 (717)-532-3270 I verify that the statements made in this Complaint 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~ /or ~ -fad 'f~ Fredrick Paul Koser ~ f::l -lQ. '" -- fJ:. ...0 0 -- ....... s (') ....., ~ D r: = 0 C::J ...::J <c" ...- ,J .." ~ w N -cJ rq f-i,:::n C,J --0 ----.J ,-- p:: ('. I ~~? -- ~::> ~ -T!U ::2 "T, - ;-;2R t:- ,- :2 .z:- :'-~IT! .. '.:. ~."1 :.~:: ~ _/ -< IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Fredrick Paul Koser, Plaintiff : No. 04-563 : Civil Action - Law vs. : In Divorce Vesta May Koser Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 9, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the final decree of divorce after service of notice of intention to request entry of the dl~cree. 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:~ ~~jJad /~ Fredrick Paul Koser Plaintiff (') c -g: ~!T G~'-.," ......--,:' r~ . ':or:::. "-=:::C";. tf.-.(-; ;J>c~,' ~ ......, = = .c- en r'"l -0 I N o ..,., :;1 Ftl:C =,,1=;; _):JC' ::.:1(1., ~;~g:~1 C)l/1 .~.. ::"c :1:1 -< -0 :J;c ~ 01 N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNlY - PENNSYLVANIA Fredrick Paul Koser, Plaintiff : No. 04-563 : Civil Action -- Law vs. : In Divorce Vesta May Koser Defendant 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. Section 4904 relating to unsworn falsification to authorities. Date:~~1 ~~~y~ Fredrick Paul Koser Plaintiff o c S, ""O:.::'_! rl1r.: ~~!~~ ~ <:: ~li? z --I --< ,..., = = ..:- U') fTl -0 I N o To -l ::r:-;l rn~ 3!CfJ 00 -j.,,; 41__h C)-- Zo r;rl1 ::~ :rs '< -0 :J;:: ~ Ul N IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Fredrick Paul Koser, Plaintiff : No. 04-563 : Civil Action - Law vs. : In Divorce Vesta May Koser Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 9, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing of the Complaint and service on Defendant. 3. I consent to the entry of the 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 unsworn falsificati n to authorities. rM'(j, ~....l-"_ . Date:~Ol( J1??cxt. Vesta Mae Koser Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNn' - PENNSYLVANIA Fredrick Paul Koser, Plaintiff : No. 04-563 : Civil Action - Law vs. : In Divorce Vesta May Koser Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECT10N 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. Section 4904 relating to unsworn Isifi tion to authorities. .~~- Date: 11) J 2- j tfV l a \11 _ I . Vesta Mae Koser Defendant --- - --- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Fredrick Paul Koser, Plaintiff vs. Vesta May Koser Defendant : No. : Civil Action - Law : In Divorce AFFIDAVIT OF SERVICE H. Anthony Adams, Esquire being duly sworn according to law deposes and states that a complaint in divorce was mailed to Vesta May j(oser, of 205 Hamilton Road, Chambersburg, Pennsylvania, 17201, certified mail, return receipt requested on February 12/2004 and was accepted on delivery by Dennis Yeager on February 17/ 2004. Sworn to and subscribed this ~ day of February, 2004. bl '{LA t{)tL lJi tI J 1 Notary Public My Commission Expires: / hf'--t}:) NOTARIAL SEAL DEBORAH WARREN. Notary Public Shippensburg. Cumberland County My Commission Expires Nov. 8, 2005 .!l i Ii ~ ~ 0 .g <0 \ij~ ~ :0 ~ en IHl;i !a:og.z 000 ill <0 _ ~ t:J -a !.~ t:J !~ h 18 ~ ~H'~ t:J ~006 ~ .. t:J c.. H.P Atto 49 \ Shi~ (71~ ...--.--" .; . ~ .1.1 ~;&1~ ~ :C:.!!l oi15,!! ~ c:.. ili~~i' _ Ji ~!~Ui s ~ t ~ i~hi~ r~ ~-4 h!H~ !~ LD 1 ~e;c:-"'o u Q..; 02 o~it IilJi 6 : ?rOr) ~ i en t:J t:J !"- I i I I ~ ~ i! ~ ~ a; z ~ '" ~ ,@ ~ ]ll" u.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN1Y - PENNSYLVANIA Fredrick Paul Koser, Plaintiff : No. 04-563 : Civil Action - Law vs. : In Divorce Vesta May Koser Defendant 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: Service was made by Certified Mail Return Receipt Requested on February 12, 2004. The return receipt was signed by Dennis Yeager, Defendant's Roommate, on February 17,2004 not by the Defendant. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code; by the Plaintiff August 27, 2004; by Defendant November 12, 2004. 4. Related claims pending: None. 5. Plaintiff's Waiver of Notice was signed on August 27,2004 and was filed September 2, 2004 and Defendant's Waiver of Notice was signed November 12, 2004 and is filed herewithin. H. Anthony Adams, Esquire Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 ----- - ,.,'" ;f.:ti;f.;f.;f. . . . . . . . ;f.;liil';+:'l;;tiil'+.:t;+.C++.:+;f. ~~;ti~*il';+;~+'~ ~~ ;+;;f.;+;+':++'~~;f.+';f.+'~~~ :+;+;~ il'*-:+:+ , IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY . . , . . . . PENNA. STATE OF . . . . . . . . . Fredrick Paul Koser No. 04-563 Civil VERSUS . . . . . . . Vesta May Koser . . , . , . . . . DECREE IN DIVORCE . . . . . 30' 2004 November AND NOW, IT IS ORDERED AND --' . . , . . . . . . . , . . . . . . . . . . . . . . . . . . . Fredrick Paul Koser DECREED THAT , PLAINTIFF, Vesta May Koser , DEFENDANT, AND 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; None PROTHONOTARY . . . . . . . . . . . . . . . . . . "'"/-1i AmSO?l~ . . . . . ,. 't';+;~ 't';!:'t''t',.; :f.:+' il':+' .. . ~'t:: +':f. . ;+;;f. +.;f.'f:+';+:il':+:'f't''f :+::+'+.'f.;ti:f.:f.'f. ~ :f. Of. '" :+; . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . :f.'f.;t:'f - h? 2. ,h~ ~}t, ~.y-C7 ~? ;Z ~:O14/ ~? /"1l ... ". h,) ;.- c/ Ac/. ;['. c/