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Home My WebLink About04-3004 Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA JAMIE L. COOPER vs. CNIL ACTION - LAW DIVORCE WILLIAM J. COOPER Defendant NO. 04 - 306'-{ c.l(.)~l'--T~ NOTICE 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 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 ofthe marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at Dauphin County, Front and Market Streets, Harrisburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DNISION 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 LA WYER 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 Plaintiff, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JAMIE L. COOPER vs. CNIL ACTION - LAW DIVORCE WILLIAM J. COOPER Defendant NO. OL[-,]Cx:N C;o~L'TE./L~ COMPLAINT IN DIVORCE I. Plaintiff Jamie L. Cooper who currently resides at 507 A Ross Avenue, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant is William J. Cooper who currently resides 318 North Main Street, Manchester, York County, Pennsylvania 17345. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 21, 1994, in Hanover, Virginia. 5. No children were born oftms marriage. 6. Neither Plaintiff nor Defendant are in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and it amendments. 7. There have been no prior actions of divorce or for annulment between the parties. 8. The marriage is irretrievably broken. 9. The parties have been living separate and apart since August 2003. 10. Plaintiff has been advised that counseling is available and that Plaintiffmay have the right to request that the court require the parties to participate in counseling. II. Plaintiff requests the court to enter a Decree of Divorce divorcing Plaintiff and Defendant. WHEREFORE, Plaintiff requests that this Court enter a Decree in Divorce divorcing Plaintiff and Defendant and such other Orders as are just and appropriate. Respectfully submitted, Date: {; -d3-~tf C/lJ~d (j&~ Melissa L. Van Eck, Esquire Attorney ID No. 85869 7800 A Allentown Blvd. Suite B P.O. Box 6662 Harrisburg, PA 17112 (717)540-5406 Attorney for Plaintiff VERIFICATION I, Jamie L. Cooper, verifY that the statements made in the foregoing COMPLAINT in DIVORCE are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are mad subject to the penalties of 18 Pa. C.S. 94904, relating to unsworn falsification to authorities. D", (f /0'1 P:'!~dCupe/( f:j P -4Q. '\. -- ~ ~ 0 (;; . t - U) c5 f0 () r---., ti"" ~ , Vv . , --J --" ~., -, ( b _.-- -+-. - -:t:- r ' ( v Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JAMIE L. COOPER VS. CIVIL ACTION - LAW DIVORCE WILLIAM J. COOPER Defendant NO. 04 - 3004 Civil Term PETITION FOR SPECIAL RELIEF PURSUANT TO SECTION 3505 OF DIVORCE CODE The Petition of Plaintiff, Jamie L. Cooper, by and through her attorneys, Van Eck & Van Eck, P.C. for Special Relief Pursuant to Sections 3505 of the Divorce Code is as follows: PARTIES I. Petitioner/Plaintiff is Jamie L. Cooper who currently resides at 120 Fort Hunter Road, Harrisburg, Dauphin County, 17110. 2. Respondent/Defendant is William J. Cooper who currently resides at 318 North Main Street, Manchester, York County, Pennsylvania, 17345, BACKGROUND 3. Petitioner and Respondent were married on March 21, 1994, in Hanover Virginia. 4. The parties separated in August 2003. 5. On June 28, 2004, Petitioner filed a Complaint in Divorce. 6. Since the date of separation, Respondent has resided in the marital residence and agreed to the financial responsibilities of such. 7. On December 16,2004, Petitioner sent a proposed Martial Settlement Agreement to Respondent. 8. Petitioner agreed to sign over her rights to the martial residence without acquiring any equity in the proposed Martial Settlement Agreement in exchange for Respondent formally removing Petitioner from the financial obligation of such. 9. Respondent is now unwilling to cooperate with Petitioner and has refused to sign the proposed Martial Settlement Agreement. 10. Respondent has additionally made threats to Petitioner that he intends to walk away from the marital residence. II. Respondent's threats are a clear attempt to financially burden Petitioner and dispose of and encumber marital property. 12. Section 3505(a) of the Divorce Code provides that an injunction may issue "where it appears to the court that a party is about to.. . dispose of, alienate or encumber property in order to defeat equitable distribution." WHEREFORE, Petitioner/Plaintiff, Jamie L. Cooper, respectfully requests this Honorable Court to grant the sale of the marital residence, require Respondent/Defendant to cooperate in executing any and all documents necessary to lost and/or sale the aforesaid martial residence and order any net proceeds from the sale of the marital residence be equally divided among parties. Respectfully submitted, V AN ECK & VAN ECK, P.C. Date: i / n - D5 ~ (j VOJh?l_ Melissa Van Eck, Esquire Attorney ID No.: 85869 7800 A Allentown Blvd. Suite B. Harrisburg, PA 17112 (717) 540 - 5406 VERIFICATION I, Jamie L. Cooper, verify that the statements made in the foregoing PETITION FOR SPECIAL RELIEF PURSUANT TO SECTION 3505 OF THE DIVORCE CODE 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. S4904, relating to unsworn falsification to authorities. Date: J!J4!05 I I CERTIFICATE OF SERVICE I, Melissa L. Van Eck, Esquire, counsel for Jamie L. Cooper, Plaintiff in the above- captioned action, hereby certify a true and correct copy of the foregoing Praecipe to Amend Divorce Complaint to Include Count for Equitable Distribution was served upon William J. Cooper by depositing same in the United States mail, first class, on January ~ 2005, addressed as follows: William J. Cooper 318 North Main Street Manchester, P A 17345 Date:~ By: Me issa L. Van Eck, Esquire J.D. # 85869 7800 A Allentown Blvd. Suite B. Harrisburg, PA 17112 (717) 540 - 5406 ~-~.~) ~.:_.._::) ,."r' --. r'"f1 C:..1 I :; --:;1 :J:-- (-~) f....,) -- .----- JAMIE L. COOPER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION ~- LAW DIVORCE WILLIAM J. COOPER Defendant NO. 04 - 3004 Civil Term PRAECIPE TO AMEND DIVORCE COMPLAINT TO INCLUDE COUNT FOR EQUITABLE DISTRIBUTION I. Petitioner is Jamie L. Cooper ("Petitioner") who currently resides at 120 Fort Hunter Road, Harrisburg, Dauphin County, 17110. 2. Respondent is William 1. Cooper ("Respondent") who currently resides at 318 North Main Street, Manchester, York County, Pennsylvania, 17345. 3. On June 28, 2004, Petitioner filed a Complaint in Divorce. 4. During the marriage, the parties acquired martial property, assets and debts. 5. Petitioner requests the Court to equitably distribute and assign the martial property, assets and debts between the parties. WHEREFORE, Petitioner requests this Honorable Court to amend the Divorce Complaint to include a Count for Equitable Distribution, enter an Order equitably distributing martial property and such other orders as may be just and appropriate. Respectfully submitted, ~~ci.ltuM Melissa Van Eck, Esquire Attorney ID No.: 85869 7800 A Allentown Blvd. Suite B. Harrisburg, P A ] 7112 (717) 540 - 5406 VERIFICATION I, Jamie 1. Cooper, verifY that the statements made in the foregoing PRAECIPE TO AMEND DIVORCE COMPLAINT TO INCLUDE COUNT FOR EQUITABLE DISTRIBUTION 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. g4904, relating to unsworn falsification to authorities. Date: J IN 10.5 I ( ~vf~ . . .#./l amie 1. Cooper CERTIFICATE OF SERVICE I, Melissa L. Van Eck, Esquire, counsel for Jamie L. Cooper, Petitioner in the above- captioned action, hereby certify a true and correct copy of the foregoing Petition for Special Relief Pursuant to Section 3505 of the Divorce Code was served upon William J. Cooper by depositing same in the United States mail, first class, on January K 2005, addressed as follows: William J. Cooper 318 North Main Street Manchester, P A 17345 Date: _HCl ,05 By: tit.. d , M&l L. VanEck, Esquire J.D. # 85869 7800 A Allentown Blvd. SuiteB. Harrisburg, PA 17112 (717) 540 - 5406 -1.C; o '1--> ~ Il D \) -- ~ ~ % ~ ~ r~ w 0>?- r ~J c~, """"r1 1'''1 CD 1 ._.1 i.. ,! -'l\ (/? I'" f'-.,';. 5 FEB 07 2005f-'^ JAMIE L. COOPER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -- LAW DIVORCE WILLIAM J. COOPER Defendant NO. 04 - 3004 Civil Term RULE TO SHOW CAUSE AND NOW, this ~ day of P.h-, 2005, a rule is hereby issued upon Defendant, William J. Cooper, to show cause why the Petition for Special Relief Pursuant to Section 3505 of the Divorce Code should not be granted. Rule returnable I D days from service. J. \)~ ,\ 1 . ~\ '-",\,J. 0'" ,- ~".,,:l r~:\ ....,.,,,).... 'rj:'> <,-'" Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JAMIE L. COOPER VS. CIVIL ACTION .- LAW DIVORCE WILLIAM J. COOPER Defendant NO. 04 - 3004 Civil Term PETITION FOR SPECIAL RELIEF PURSUANT TO SECTION 3505 OF DIVORCE CODE The Petition of Plaintiff, Jamie L. Cooper, by and through her attorneys, Van Eck & Van Eck, P.C. for Special Relief Pursuant to Sections 3505 of the Divorce Code is as follows: PARTIES I. PetitionerlPlaintiffis Jamie L. Cooper who currently resides at 120 Fort Hunter Road, Harrisburg, Dauphin County, 17110. 2. Respondent/Defendant is William J. Cooper who currently resides at 318 North Main Street, Manchester, York County, Pennsylvania, 17345. BACKGROUND 3. Petitioner and Respondent were married on March 21, 1994, in Hanover Virginia. 4. The parties separated in August 2003. 5. On June 28, 2004, Petitioner filed a Complaint in Divorce. 6. Since the date of separation, Respondent has resided in the marital residence and agreed to the financial responsibilities of such. 7. On December 16,2004, Petitioner sent a proposed Martial Settlement Agreement to Respondent. 8. Petitioner agreed to sign over her rights to the martial residence without acquiring any equity in the proposed Martial Settlement Agreement in exchange for Respondent formally removing Petitioner from the financial obligation of such. 9. Respondent is now unwilling to cooperate with Petitioner and has refused to sign the proposed Martial Settlement Agreement. 10. Respondent has additionally made threats to Petitioner that he intends to walk away from the marital residence. II. Respondent's threats are a clear attempt to financially burden Petitioner and dispose of and encumber marital property. 12. Section 3505(a) of the Divorce Code provides that an injunction may issue "where it appears to the court that a party is about to. . . dispose of, alienate or encumber property in order to defeat equitable distribution." WHEREFORE, Petitioner/Plaintiff, Jamie L. Cooper, respectfully requests this Honorable Court to grant the sale of the marital residence, require Respondent/Defendant to cooperate in executing any and all documents necessary to lost and/or sale the aforesaid martial residence and order any net proceeds from the sale of the marital residence be equally divided among parties. Respectfully submitted, VAN ECK & VAN ECK, P.C. Date: i-- n -05 V11lMM. d VOl itlJ Melissa Van Eck, Esquire Attorney ID No.: 85869 7800 A Allentown Blvd. Suite B. Harrisburg, P A 17112 (717) 540 - 5406 VERIFICATION I, Jamie L. Cooper, verify that the statements made in the foregoing PETITION FOR SPECIAL RELIEF PURSUANT TO SECTION 3505 OF THE DIVORCE CODE 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. g4904, filIating to unsworn falsification to authorities. Date: 1114/05 I I 2/rt ~ ie L. Cooper CERTIFICATE OF SERVICE I, Melissa L. VanEck, Esquire, counsel for J arnie L. Cooper, Plaintiff in the above- captioned action, hereby certify a true and correct copy of the foregoing Praecipe to Amend Divorce Complaint to Include Count for Equitable Distribution was served upon William J. Cooper by depositing same in the United States mail, first class, on January ~ 2005, addressed as follows: William J. Cooper 318 North Main Street Manchester, P A 17345 Date:~ 'J! ~ \~ By. . V Me issa L. Van Eck, Esquire I.D. # 85869 7800 A Allentown Blvd. Suite B. Harrisburg, PA 17112 (717) 540 - 5406 .,........\ en (,,~:" '\\ J:;- ( ~) , \-,. -- JAMIE L. COOPER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW DIVORCE WILLIAM J. COOPER Defendant NO. 04 - 3004 Civil Term MOTION TO MAKE RULE ABSOLUTE The Motion of Plaintiff, Jamie L. Cooper, by and through her attorneys, Van Eck & Van Eck, P.C., to Make Rule Absolute is as follows: I. Plaintiff is Jamie L. Cooper who currently resides at 120 Fort Hunter Road, Harrisburg, Dauphin County, 17110. 2. Defendant is William J. Cooper who currently resides at 318 North Main Street, Manchester, York County, Pennsylvania, 17345. 3. On February 4,2005, Plaintiff filed a Petition for Special Relief Pursuant to Section 3505 of Divorce Code (hereinafter "Petition for Special Relief'). 4. On February 8, 2005, the Court issued an Order compelling Defendant to show cause as to why the Petition for Special Relief should not be granted within ten days of service (hereinafter "Order"). , 5. On February 10,2005, Plaintiff served Defendant with the Order and the Petition for Special Relief by certified and regular mail. A true and correct copy of the correspondence serving the document to Defendant is attached hereto and incorporated herein as Exhibit "A". 6. On March 3, 2005, service by certified mail was returned to Plaintiff's attomey as unclaimed. A tme and correct copy of the correspondence serving the document to Defendant is attached hereto and incorporated herein as Exhibit "B". 7. Fifteen days have pasted since the date of service and the ordinary mail has not been returned to Plaintiff's attorney. 8. Pursuant to Rule 403 of the Pennsylvania Rules of Civil Procedure, "[s Jervice by ordinary mail is complete if the mail is not returned to the sender within fifteen days after mailing." 9. Defendant has not shown cause within ten days of service as specified in the Order. WHEREFORE, Plaintiff, Jamie 1. Cooper, respectfully requests this Honorable Court to make the Rule absolute and grant the sale of the marital residence, require Defendant to cooperate in executing any and all documents necessary to list and/or sale the aforesaid martial residence described in the Petition for Special Relief and order any net proceeds from the sale of the marital residence be equally divided among parties. Respectfully submitted, VAN ECK & VAN ECK, P.c. Date: ,3-11'01$ ~d~!Jd Melissa Van Eck, Esquire Attorney ID No.: 85869 7800 A Allentown Blvd. SuiteB. Harrisburg, PA 17112 (717) 540-5406 -f:.LLFHO~~E (717) S.Hl-S.106 ;:,6..'\: ;J17:, S4C1-5.W7 VAN ECK & VAN ECK, PC ATTORNEYS AT LJI,V! P.O. BOX 6662 7810 Al.LENTOWN BLVD, SUITE 3 HARRISBURG, PA 17112 i~,-rnilli 'nnlc~J"C(l,nC:-t,;L_:-iCC February 10, 2005 VIA CERTIFIED AND REGULAR MAIL William J. Cooper 319 North Main Street Manchester, P A 17345 Re: Jamie L. Cooper v. William J. Cooper Docket No.: 04-3004 Civil Term Dear Mr. Cooper: Enclosed find a Petition for Special Re!iefthat has been filed in the above referenced matter. Please note that you have 10 days to respond to this Petition or the relief requested will be granted by the couti. Please take this to an attorney at once. V cry truly yours. VAN ECK & V AN ECK, r.c. , '.; . ,," ,.\.,j \( ii' !. l [..1.(( j: \./ C", i'\.. C(, t' Melissa L. 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" \I ~. . 0 " w . . ~ CERTIFICATE OF SERVICE I, Melissa L. Van Eck, Esquire, counsel for Jamie L. Cooper, Plaintiff in the above- captioned action, hereby certify a true and correct copy ofthe foregoing Motion to Make Rule Absolute was served upon William J. Cooper by depositing same in the United States mail,. first class, on March --H- 2005, addressed as follows: William J. Cooper 318 North Main Street Manchester, P A 17345 Date: \..~ -11-05 By: ~ rllfutft~ Melissa L. Van Eck, Esquire \.D. # 85869 7800 A Allentown Blvd. SuiteB. Harrisburg, P A 17112 (717) 540-5406 t) M R 1 Ii 2005 t ~ Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL ANIA JAMIE L. COOPER VS. CIVIL ACTION - LAW DIVORCE WILLIAM J. COOPER Defendant NO. 04 - 3004 Civil Term ORDER AND NOW, this;~ day of ~ , 2005, upon consideratio ofthe Petition for Special Relief filed on behalf of Petitioner Jamie L. Cooper, it is hereby RDERED and DECREED that: I. The martial residence shall be listed for sale. 2. Defendant, William J. Cooper, shall cooperate in executing an and all documents necessary to list and/or sell the property. 3. Any net proceeds from the sale of the martial residence shall b divided equally among the parties. ~~( ~' '- (' ,O'J ,rifC\ .") o J. II ; I ;;<1 82 ~'n1SnOZ AHvlC:';--XJ:-HGH,j 3Hl ::0 3;)L~~\J-C!318 - ~. "\- Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JAMIE L. COOPER VS. CIVIL ACTION - LAW DIVORCE WILLIAM J. COOPER Defendant NO, 04 - 3004 Civil AFFIDAVIT OF SERVICE I do hereby state that I served a true and correct copy of the Complaint in Divorce, in the above captioned matter, by placing the same in the United States mail, first-class, postage prepaid, certified mail, return receipt requested, in Harrisburg, Pennsylvania, and delivered on July 10, 2004, as per the attached return receipt card, addressed to: William 1. Cooper 318 N. Main Street Manchester, PA 17345 Respectfully submitted, ~a~j Melissa L. VanEck, Esquire Attorney ID No. 85869 7810 Allentown Blvd. Suite B Harrisburg, PA 17112 (717)540- 5406 Attorney for Plaintiff Date: , EXHIBIT "A" , SENDER: COMPLETE THIS SECTION . Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. . Print your name and address on the reverse so that we can return the card to you, . Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: \..0\ \\\()SY\ ~. Coo\XY 3\8 \0. ~I'\ 3-. ~<\c:.~'C,-\<.;r \ ~ \ -gl.-{ ~ 3'~ 2. Article Number (Transfer from service lab. . PS Form 3811, August 2001 . . . . A. Signature x D. Is delivery address different Worn item ';I If YES, enter delivery address below: 31 S p..~tfil;J 3.~S rvice Type ertified Mail 0 Express Mail Registered ~." n I!t fll'-U^.....h~ise o Insured Mail 0 C.O.D. 7002 3150 0001 4960 5175 4. Restricted Delivery? (Extra Fee) Domestic Return Receipt DYes 1 02595-02-M-l 035 -------- Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JAMIE L. COOPER VS. CIVIL ACTION - LAW DIVORCE WILLIAM J. COOPER Defendant NO. 04 - 3004 Civil Term AFFIDAVIT OF CONSENT 2. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 28,2004. 4. 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. 5. 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.g 4904 relating to unsworn falsification to authorities. Date: 7/;0 /{)Cp / I JAMIE L. COOPER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW DIVORCE WILLIAM J. COOPER Defendant NO. 04 - 3004 Civil Term WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301 (C) OF THE DIVORCE CODE 4. I consent to the entry of a final Decree of Divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 6. 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.s 4904 relating to unsworn falsification to authorities. Date: 7/JO /0(1) I I JAMIE L. COOPER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW DIVORCE WILLIAM J. COOPER Defendant NO. 04 - 3004 Civil Term AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 28, 2004. 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.s 4904 relating to unsworn falsification to authorities. Date: ---:kr Iy 0 ~ () (0 JAMIE L. COOPER Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW DIVORCE WILLIAM J. COOPER Defendant NO. 04 - 3004 Civil Term WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301 (C) OF THE DIVORCE CODE I. 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.s 4904 relating to unsworn falsification to authorities. Date: ~ (\I {) 7 {)(;, / ~- L;, /./?, . " - /.~ ~~ ' '~~- . ~ ----- William J. CoBi?6 . / Defendant r ... JAMIE L. COOPER IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff VS. CIVIL ACTION - LAW DIVORCE WILLIAM J. COOPER Defendant NO. 04 - 3004 Civil PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of an appropriate decree: Code. I. Ground for divorce: irretrievable breakdown under Section (330 I ( c) of the Divorce 2. Date and manner of service of the complaint: Served via certified mail on July 10, 2004. Affidavit of Service filed simultaneously with this Praecipe. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301(c) ofthe Divorce Code: by plaintiff on July 10, 2006; by defendant July 7, 2006. (b)(l) Date of execution of the plaintiffs affidavit required by Section 3301(d) of the Divorce Code: N/A; (2) Date of service of the plaintiffs affidavit upon the defendant: N/ A. 4. Related claims pending: None. .' Date: 5. Complete either (a) or (b). a. Date and manner of service of the notice of intention to file praecipe a copy of which is attached: b. Date Plaintiffs Waiver of Notice was filed with the Prothonotary: Executed on July 10,2006; filed simultaneously with this Praecipe. Date Defendant's Waiver of Notice was filed with the Prothonotary: Executed on July 7, 2006; filed simultaneously with this Praecipe. Respectfully submitted, t1/Jry~ Melissa L. VanEck, Esquire Attorney ID No.: 85869 7810-B Allentown Blvd Harrisburg, PA 17112 (717) 540-5406 CERTIFICATE OF SERVICE I, Melissa L. Van Eck, Esquire, counsel for Jamie L. Cooper, Plaintiff in the above- captioned action, hereby certify that a true and correct copy of the foregoing Praecipe to Transmit was served upon William J. Cooper, by depositing same in the United States mail, first class, on July;;:1, 2006, addressed as follows: William J. Cooper 4335 Board Road Manchester, P A 17345 Date: rJ /).1 ' (J(Q ~QiiMd 7810-B Allentown Blvd Harrisburg, PA 17112 Telephone: 717-540-5406 Fax: 717-540-5407 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF JAMIE L. COOPER VERSUS WILLIAM J. COOPER . . AND NOW, PENNA. No. l)4-3004-C'V . . . DECREE IN DIVORCE /h-r I q ;;.:5"1 j).A1. ' ,Joct. , IT IS ORDERED AND DECREED THAT J"MTE L. COOPER AND , PLAINTIFF, WILLIAM J. COOPER , 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. . . . J. .~ 2 P?P'~"" ~ --n~ ~.p. /'~.,~..~.~ ~. L-~ ~. I..: -:!>