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Home My WebLink About10-0292PAMELA E. COOVER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. ; n NO. 10 - Al CIVIL lf?-RM?-- BRADLEY S. WHISTLER, 51 nim Defendant CIVIL ACTION - LAW -7, p IN DIVORCE ?' ' -- p. t -r, NOTICE TO DEFEND AND CLAIM RIGHTS `- - tern You have been sued in court. If you wish to defend against the claims set firth i 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 that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. 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 WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 S. Bedford Street Carlisle, Pennsylvania 17013-3302 (717) 249-3166 SNELBAKER & BRENNEMAN, P.C. LAW OFFICES SNELBAKER & BRENNEMAN, P.C. By: Attorneys for Plaintiff 43601.00 PO ATt'y CIc 18(0 I oR3(o07/ AMELA E. COOVER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. Q, ya. CIVIL TERM tRADLEY S. WHISTLER, Defendant CIVIL ACTION -LAW IN DIVORCE COMPLAINT Plaintiff Pamela E. Coover, by her attorneys, Snelbaker & Brenneman, P. C., hereby is this Divorce Complaint as follows: 1. Plaintiff Pamela E. Coover is an adult individual residing at 2505 Cope Drive, iics burg (Upper Allen Township), Cumberland County, Pennsylvania 17055. 2. Defendant Bradley S. Whistler is an adult individual residing at 2505 Cope Drive, Mechanicsburg (Upper Allen Township), Cumberland County, Pennsylvania 17055. 3. Both 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 lawfully joined in marriage on September 8, 2007, in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties I hereto in this or any other jurisdiction since the date of the marriage averred in Paragraph 14, above. 6. Neither party is a member of the armed forces of the United States of America. LAW OFFICES SNELBAKER & BRENNEMAN, P.C. 7. The Plaintiff avers as the grounds upon which this action is based is that the marriage the parties hereto is irretrievably broken. 8. The Plaintiff has been advised that counseling is available and that Plaintiff may have right to request that the Court require the parties to participate in counseling. 9. The Plaintiff requests this Court to enter a decree of divorce. WHEREFORE, Plaintiff Pamela E. Coover requests this Court to enter a Decree of , divorcing the Plaintiff from the bonds of matrimony heretofore existing between the iff and Defendant. WHEREFORE, Plaintiff Pamela E. Coover requests this Court to: (a) enter a decree of divorce, divorcing the Plaintiff from the bonds of matrimony; and (b) order such other relief as this Court deems just and reasonable. SNELBAKER & BRENNEMAN, P.C By: Richard C. Snelbaker, Esquire 44 West Main Street Mechanicsburg, PA 17055-0318 (717) 697-8528 Date: Ja#U*t IL X0(0 Attorneys for Plaintiff Pamela E. Coover -2- LAW OFFICES SNELBAKER & BRENNEMAN, P.C. VERIFICATION I verify that the statements made in the foregoing 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 aul Date:..J2nus^1 <<, -zo (o LAW OFFICES SNELBAKER & BRENNEMAN, P.C. PAMELA E. COOVER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. JQ y CIVIL TERM BRADLEY S. WHISTLER, Defendant CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT PAMELA E. COOVER, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do NOT request that the court require my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to ai Date: 3jJ401"t pit Zola (Plaintiff) LAW OFFICES SNELBAKER & BRENNEMAN, P.C. PAMELA E. COOVER, v. NO. 10-292 CIVIL TERM BRADLEY S. WHISTLER, . Defendant :CIVIL ACTION -LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(d) of the Divorce Code was filed on January 11, 2010. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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. 4. I verify that the statements made in this Affidavit are true and correct. I understand LAW OFFICES SNELBAKER 8C BRENNEMAN, P.C. that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA unsworn falsification to authorities. Date: J~ ~ ~/~ Zoe a `~ ..~ C Pamela E. Coover C') ^' _ c~- `~ _ ~' ~ ~ . ~~ r ~'i 't~ i~ . ~ .. ` ~ j a 1 _ l ..Y~ ...i 'r~ ~~ (V -.j r7'I ~ r ~ n... ~ PAMELA E. COOVER, v. ~ BRADLEY S. WHISTLER, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-292 CIVIL TERM Defendant :CIVIL ACTION -LAW IN DIVORCE PLAINTIFF'S 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. 4. I verify that the statements made in this affidavit are true and correct. I understand LAW OFFICES SNELBAKER EC BRENNEMAN. F.C. that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: Ju he ~{, Zo ~a e~ ~:,, (Ti r ,- r, -\ ("~ J~ .. e'"~ ,~h ~_ ,~ C_.' .-~-, v 4 C !~ ~..f ~.? U.. ~% `, ..L "~ ~ , y P' ~ 1't? PAMELA E. COOVER, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 10-292 CIVIL TERM BRADLEY S. WHISTLER, . Defendant :CIVIL ACTION -LAW iN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(d) of the Divorce Code was filed on ~ January 11, 2010. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the 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. 4. 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: v `~ ' °2~/~ ~, C C" '^) J " G~ ~ ~' ' T ~_ r~%= ~~ _ T .a .:a'. . r' C1' _x7 r~:~ •-~. LAW OFFlCES SNELBAKER 8C BRENNEMAN, P.C. PAMELA E. COOVER, v. IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-292 CIVIL TERM BRADLEY S. WHISTLER, . Defendant :CIVIL ACTION -LAW IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECRF,E 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. 4. I verify that the statements made in this affidavit are true and correct. I understand LAW OFFICES SNELBAKER SC BRENNEMAN, P.C. that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date: ~-,~.~~~/C,~ S n c '_~ fS ~lr j~_: ~~ t~ ~~ _~ 4 C._. C 1 1~ _~ U: r~ ;.::. ~`i T 'ri ?'~ I~ "TJ ! i , f`, ~. ~~_, ti'l t~' _; ...C PAMELA E. COOVER, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 10-292 CIVIL TERM BRADLEY S. WHISTLER, . Defendant :CIVIL ACTION -- LAW IN DIVORCE ACCEPTANCE OF SERVICE I, BRADLEY S. WHISTLER, Defendant in the above captioned action do hereby accept service of Complaint in Divorce and acknowledge receipt of a certified copy thereof. Date: / ~ ~~~~ , 2010 Bradley S. Whis (Defendant) fV -. ~ C O 'Y_l t.', t..._ C-~ t ~ - ~- "r1 ` ::_ ~ x 1'1 ~-- 1 ~ ~~' n (~ ~ . \„ ~ ~ ,. ._ s.. •• CS ~ =~: :7J R- •< LAW OFFICES SNELBAKER EC BRENNEMAN, P.C. PAMELA E. COOVER, Plaintiff v. BRADLEY S. WHISTLER, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-292 CIVIL TERM CIVIL ACTION -- LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO: Prothonotary of Cumberland County: Please transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: personal acceptance of service on January 11, 2010 (see Acceptance of Service filed herewith). 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by the Plaintiff June 4, 2010; by the Defendant: June 3, 2010. 4. Date of execution of Waiver of Notice in Section 3301(c) Divorce: by the Plaintiff: June 4, 2010; by the Defendant: June 3, 2010. 5. Related pending claims: None. LAW OFFICES SNELBAKER 8C BRENNEMAN, F.C. Date: June 7, 2010 SNELBAKER & BRENNEMAN, P. C. By: A''RZS"rneys for Plai~iff o ~' [;}rte C__ ,~ ~.,,J • f; 7 .L. {_ : ~ .. ~. ~.. ~_.1,~.. r° c. N -~ ~1 ~-- I ~ ~ •~ G1 -<- PAMELA E. COOVER V. BRADLEY S. WHISTLER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N O. 10-292 DIVORCE DECREE AND NOW, ~lw..~. ` ~ ~m ~ ° , it is ordered and decreed that PAMELA E. COOVER BRADLEY S. WHISTLER bonds of matrimony. plaintiff, and defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. NpNE 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.") t1o~E The parties' Post-Nuptial Agreement dated January 11, 2010 is incorporated but not merged into this Decree. By the Court, ~ . $- t d Ce..r~ . Cod tY~G:, `1 ~~ ~ - 8'- jp ~o-i~ c~ ma.~~~ -~o