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Home My WebLink About08-2237JEFFREY S. KOOSER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JACQUELINE KOOSER, : NO. 2008 -.).237 CIVIL TERM Defendant DIVORCE NOTICE TO DEFEND 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 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, I Courthouse Square, 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 A 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. Pennsylvania Lawyer Referral Line Lawyer Referral Services Telephone: 1-800-692-7375 (PA ONLY) or 717-238-6715 JEFFREY S. KOOSER, Plaintiff V. JACQUELINE KOOSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2008 alV CIVIL TERM : DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE NOW comes Plaintiff and for cause of action against Defendant who says: 1. Plaintiff is Jeffrey S. Kooser, who resides in Shippensburg, Cumberland County, Pennsylvania with a street and mailing address of 73 Sandbank Road, Shippensburg, Pennsylvania 17257. 2. Defendant is Jacqueline Kooser, who resides in Olyphant, Lackawanna County, Pennsylvania, with a street and mailing address of 665 East Scott Street, Olyphant, 18447. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this complaint. 4. Plaintiff and Defendant were married on December 18, 2004, in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request the court to require the parties to participate in counseling. 8. Defendant is not a member of the Armed Services of the United States or any of its allies. 9. The causes of action and sections of the Divorce Code under which the Plaintiff is proceeding are: A. Section 3301(c): The marriage is irretrievably broken. B. Section 3301(d): The marriage is irretrievably broken and the parties have been living separately and apart since June 7, 2007. If the parties do not agree to proceed under Section 3301(c) of the Divorce Code, then Plaintiff will submit an Affidavit alleging that the parties have lived separately and apart for at least two (2) years and that the marriage is irretrievably broken. WHEREFORE, Plaintiff respectfully requests your Honorable Court to enter a Decree of Divorce, divorcing the parties from the bonds of matrimony. Respectfully Submitted, Paul M. Ferguson Supreme Ct. No.: 203293 Attorney for Plaintiff Neuharth Law Offices 232 Lincoln Way East P.O. Box 359 Chambersburg, PA 17201 (717) 264-2939 11, VERIFICATION I verify that the statements made in this document 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. Section 4904, relating to unworn falsification to authorities. 411210V Date Jeffrey S. Kooser C c? CZ C= a JEFFREY S. KOOSER, Plaintiff V. JACQUELINE KOOSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2008 - 2237 CIVIL TERM DIVORCE AFFIDAVIT OF SERVICE I, Paul M. Ferguson, of Neuharth Law Offices, hereby state that on April 10, 2008, I mailed by First Class U.S. Mail and by Certified Mail, No. 7007 2560 0002 5856 0168, Return Receipt Requested, Addressee Only, a copy of the Complaint in Divorce to Defendant Jacqueline Kooser at 665 East Scott Street, Olyphant, Pennsylvania 18447, the last known mailing address of Defendant, which documents were received on April 12, 2008, as evidenced by the attached Domestic Return Receipt. (See Attached Exhibit A). 5- Paul M. Ferguson Supreme Ct. ID #: 203293 Attorney for Plaintiff Neuharth Law Offices 232 Lincoln Way East P.O. Box 359 Chambersburg, PA 17201 (717) 264-2939 7- jr- ¦ Complete items 1 2 and 3 Also complete A. Item 4 If Restricted Delivery Is desired. 0 Agent ¦ Print your name and address on the reverse 0 Addressee so that we can return the card to you. Printed ) C. Date of Delhwy ( ¦ Attach this card to the back of the maiipiece, Ito M, 4 0111 / 11 011P or on the front If spade permits. , D. Is (very address d from item 1? 0 Y? ' 1. Article Addressed to: If YES, enter delivery address below: 0 No " S?'• bbS ?GQS?' ?CA`H ?1 O! u p Kant, p I iq I g'14+ ?J 3. Service Type ` 1.cerwi d Mail 0 Bpm Man 1 0 Registered 0 Return Receipt for Merchandise 0 Insured man 0 C.O.D. 4. Restricted Delivery? (Exile Fee) 2 Article Number (ransferfrom seryk 7007 2560 0002 5856 0168 PS Form 3811, F®b vary 2004 DonrasHc Rwurn.Aawlpt eeaws ce ra lsoo Exhibit A C -7 ? ? ?'^ ? f ' ' I ': t. "? _ C) (1?tt ? ry a ??.ti. ??. ?._. °YT ?.. JEFFREY S. KOOSER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JACQUELINE KOOSER, : NO. 2008 - 2237 CIVIL TERM Defendant DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on April 9, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and 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. 4. 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. 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 unworn falsification to authorities. 1/7 o1 Date Jeffrey S. K oser ?'? ? ?- t"? 7 t" ? ???.?, ,, r ?- ? ? err t r` --^i ..? ? •? ? JEFFREY S. KOOSER, Plaintiff V. JACQUELINE KOOSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2008 - 2237 CIVIL TERM : 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 Waiver 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. 7/17/os /?- ?--L Date Jeffrey . Koo er ? ? ? ? --n ? ?? ? . ? -- ??:; ? ?, ?? 1 ' ?? _r-- -??, ? 1 . -?i 1 : y f?,? ? y JJ ? ?.+? l ? ?w JEFFREY S. KOOSER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JACQUELINE KOOSER, : NO. 2008 - 2237 CIVIL TERM Defendant DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on April 9, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and 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. 4. 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. 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. 7 F ate J qu ne Kooser C=Z n 0o j may,: ?,,., t?J ..E3 JEFFREY S. KOOSER, Plaintiff V. JACQUELINE KOOSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2008 - 2237 CIVIL TERM : 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 Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unworn falsification to authorities. " 6-1 1- 100? /-? f 9S " , 0 0-? , AO,04,ti- ?ate J qu i e Kooser S ri Y? JEFFREY S. KOOSER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW JACQUELINE KOOSER, : NO. 2008 - 2237 CIVIL TERM Defendant 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: Ground for Divorce: Irretrievable breakdown under 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on April 12, 2008. 3. Date of execution of the Affidavit of Consent required by 3301(c) of the Divorce Code: by Plaintiff: July 17, 2008; by Defendant: July 17, 2008. 4. Related claims pending: None. 5. Date Plaintiff s Waiver of Notice in 3301 Divorce was filed with the Prothonotary: July 23, 2008. Date Defendant's Waiver of Notice in 3301 Divorce was filed with the Prothonotary: July 23, 2008. Paul M. Ferguson Supreme Ct. No.: 203293 Attorney for Plaintiff Neuharth Law Offices P.O. Box 359 232 Lincoln Way East Chambersburg, PA 17201 (717) 264-2939 C. t 4?? ', IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. JEFFREY S. KOOSER, Plaintiff VERSUS JACQUELINE KOOSER, Defendant No. 2008 -2237 DECREE IN DIVORCE IT IS ORDERED AND AND NOW,. d9 DECREED THAT Jeffrey S. Kooser PLAINTIFF, AND Jacqueline Kooser 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; NONE PROTHONOTARY emu, gyp, o? G. lop a ` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA S. 6one-r Plaintiff Vs File No. 400L c" 37 IN DIVORCE P- koCL5 &- r , Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/ defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated Aqy A/W hereby elects to resume the prior surname of and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S 704. Date: I"p?' Signature P 13 j I t -?JIK P n'? -4r-1 pit] Si ture of name being resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF On the day of See , 200T . before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. ca?eo DONNA WjLLLqAg ?- NO SwWon, Lmck?inna?County Public Jan. 14; 2010 cry r c- s, c_ .a W h, r ?a _i