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HomeMy WebLinkAbout09-1521W RICHARD E. COPENHAVER, Plaintiff vs. DEMBIE COPENHAVER, Defendant IN THE COURT OF COMMON PLEAS O CUMBERLAND COUNTY PENNSYLVANIA CIVIL ACTION - LAW hii NO. e) V / S?- / C IN DIVOR E You have been sued in court. If you wish to defend against t foregoing pages, you must take prompt action. You are warned tha case may proceed without you and a decree in divorce or annulmer you by the court. A judgment may also be entered against you for requested in these papers by the Plaintiff. You may lose money or important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable marriage, you may request marriage counseling. A list of marriage the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION C LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNU YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ( HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEP FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HE Cumberland County Bar Association 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 Telephone: (717) 249-3166 e claims set forth in the if you fail to do so, the may be entered against ny other claim or relief property or other rights of the is available in PROPERTY, RENT IS GRANTED, IF YOU DO NOT THE OFFICE SET it ii I RICHARD E. COPENHAVER, ) IN THE COURT OF COMMON Plaintiff ) PLEAS O CUMBERLAND COUNTY, PENNSYLVANIA vs. ) CIVIL AC ION - LAW NO. Q -/3'01 C u1 / DEMBIE COPENHAVER, ) Defendant ) IN DIVORCE TO THE WITHIN-NAMED DEFENDANT: You have been named as the Defendant in a Complaint in a d ivorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is t advise you that in accordance with Section 3302 (d) of the Divorce Code, you may requ est that 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 t he Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are adv ised that this list is kept as a convenience to you and you are not bound to choose a counsel or from this list. All necessary arrangements and the cost of counseling sessions are to a borne by you and your spouse. If you desire to pursue counseling, you must make your reques t for counseling within twenty days of the date on which you receive this notice. Failure to o so will constitute a waiver of your right to request counseling. ill it il RICHARD E. COPENHAVER, ) IN THE COURT OF COMMON Plaintiff ) PLEAS O CUMBERLAND COUNTY, PENNSYLVANIA VS. ) CIVIL AC ION - LAW NO. 0 - l S off- t c.tv. DEMBIE COPENHAVER, ) Defendant ) IN DIVOR E COMPLAINT IN DIVORCE AND NOW comes the above-named Plaintiff, RICHARD E. C PENHAVER, by his attorney, Samuel L. Andes, and makes the following Complaint in Divorce: 1. The Plaintiff is RICHARD E. COPENHAVER, an adult individual who currently resides at 279 Steelstown road in Newville, Cumberland County, Pennsylvania. 2. The Defendant is DEMBIE COPENHAVER, an adult individual whose last known address, to the best of Plaintiffs knowledge was 602 East Varton Street in Greenwood, Mississippi 38930. 3. Both the Plaintiff and Defendant have been bona fide residents of 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 16 November 1962 in Denver, Colorado. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of marriage c unseling and the Plaintiff may have the right to request that the Court require the parties to pa icipate in counseling. 8. The Plaintiff requests this Court to enter a Decree in Divorce. WHEREFORE, Plaintiff requests this Court to enter a Decree i Divorce pursuant to the Divorce Code of Pennsylvania. ?. --j"I I it - r-WUI I AD= U15 I KIBI 9. During the course of the marriage, the parties have property, both real and personal, which are held in joint names and each of the parties hereto. WHEREFORE, Plaintiff prays this Honorable Court, after req Defendant, to equitably divide the property, both real and personal, hereto as marital property. ,-d numerous items of the individual names of iring full disclosure by the wned by the parties Saftel L. Andes Attorney for Plaintiff Supreme Court ID #'7225 525 North 12th Street Lemoyne, Pa 17043 (717) 761-5361 1. I verify that the statements made in this Complaint are true a d correct. I understand that any false statements in this Complaint are subject to the penalti s of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: ""fin E. 4J' a +a r? s ? 1?. to P ?v n c r rv .r, 0 rl RICHARD E. COPENHAVER, Plaintiff vs. DEMBIE COPENHAVER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA } CIVIL ACTION - LAW NO. 09-1521 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE AND ENTRY OF APPEARANCE I hereby enter my appearance for the Defendant, Dembie Copenhaver, in the above- captioned action. I acknowledge receipt of a true and correct copy of the Complaint in Divorce filed in the above action on behalf of the Defendant on / / t2_t32 /7 , 2009. Stacy Wolf, E quire Attorney for Defendant Supreme Court ID # ?$ 7?? 7 i` cb -- RICHARD E. COPENHAVER, V. DEMBIE COPENHAVER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2009-1521 CIVIL TERM DIVORCE DECREE AND NOW, G~d,da Zo ~4D~ , it is ordered and decreed that RICHARD E. COPENHAVER, plaintiff, and DEMBIE COPENHAVER, ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE By the Court, rb •a ~