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Home My WebLink About01-1883MARK A. COX, Plaintiff VS. JESSICA J. COX, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. b I - 19 93 Civil Term ACTION IN DIVORCE 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 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. Where the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 MARK A. COX, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 0 1- I J'F-I Civil Term JESSICA J. COX, ACTION IN DIVORCE Defendant COMPLAINT IN DIVORCI, 1. Plaintiff is Mark A. Cox, an individual sui juris, who has resided at 47 Marilyn Dr., Carlisle, Cumberland County, Pennsylvania, 17013, since 2000. 2. Defendant is Jessica J. Cox, an individual sui juris, who has resided at 14 Cedar St., Mount Holly Springs, Cumberland County, Pennsylvania, 17013, since 2000. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on September 20, 1997 in Mount Holly Springs, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have one child together, namely, Anthony Tyler Ray Cox, date of birth, January 18, 1996. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken; andlor (b) That the Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. 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. §4904 relating to unsworn falsification to authorities. Mark A. Cox, Plaintiff Respectfully submitted, 9 - Zoo i Date: -7-2 9.D e Ad77 s, Esquire No465 5 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF T fl z w C r- : m Q MARK A. COX, Plaintiff VS. JESSICA J. COX, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01 - 1883 Civil Term ACTION IN DIVORCE NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE TO: Jessica J. Cox 14 Cedar St. Mount Holly Springs. Pa. 17065 DATE: February 25, 2002. You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the 3301(d) affidavit. Therefore, on or after March 18, 2002 the Plaintiff can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a Counter-Affidavit by the date above, the Court can enter a final decree in Divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHI H'YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT I ATTACHED TO PHIS NOTICE. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of your counter-affidavit alone does not protect your economic claims. 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 MARK A. COX, Plaintiff VS. JESSICA J. COX, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01 - 1883 Civil Term ACTION IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(4) of the DIVORCE CODE 1. Check either (a) or (b): _(a) I do not oppose the entry of a divorce decree. _(b) I oppose the entry of a divorce decree because: (Check (i),(ii), or both:) _(i) The parties to this action have not lived separate and apart for a period of at least two years. _(ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): _(a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, and expenses if I do not claim them before a divorce is granted. _(b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees, or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-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 unswom falsification to authorities. Date: Jessica J. Cox, Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, you need not file the counter-affidavit. C" MARK A. COX, Plaintiff VS. JESSICA J. COX, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01 - 1883 Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF NO 'ICE OF INTENT AND COUNTER-AFFIDAVIT AND NOW, this March 25, 2002, I, Jane Adams, Esquire, hereby certify that on March 1, 2002, a true and correct copy of PLAINTIFF'S NOTICE OF INTENT AND COUNTER-AFFIDAVIT was served, via certified mail, return receipt requested, addressed to: Jessica J. Cox 14 Cedar St. Mount Holly, Pa. 17065 DEFENDANT Respectfully J e Adams, Esquire .D. o. 79,165 1 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF late items 1, 2, and 3. Also complete ¦ desired. ry' item 4 4 if Restricted Dalive Is ¦ Print your name and address on the reverse so that we can return the card to you. ¦ or on thelfro i t s spa a at i sthe mailpiece, 1. Article Address8d to: ILLY'].l.Xl /y, 6tT am A. Received by r.?I C. 4de- . Clearly) 16 ? Agent imm item 1? ? Yes iss below: 0 No ? Express Mail ? Return Receipt for Merchandise p Insured Man u ••.••.••. 4. Restricted Delivery? (Extra Fee) [I Yes -1?? 3` ?`??G?a`?g 2. ARicle,Number ce label) a5-10 1e2595-01-M-1424 (Rensfer from servi Domestic Return Receipt ac Form 3811, March 2001 UNITED STATES POSTAL SERVICE 111111 First-Class Mail Postage & Fees Paid LISPS Permit No. G-10 • Sender: Please Print your name, address, and ZIP+q in this box an 03 ?nr???nr???urrrr ??rr?-ur??n ase PH R?d by (Fle a /rly) I8, tems 2, and 3. Also complete red. ¦ complete, if Restricted Delivery is desi rse item address on the reveur nar^e and piece, ?. ? print V1 you. so that we can return the card to Attach this c9rd to the baeVcnots he mailD or on the front if space p 1. Article Addressed to: ice- 171 ?V V le Number (Copy from service label) 2. Artro ? wmm? ie of Delivery Agent ? Add yes yes F s Jiff ant tr m rem t? 0 No ry addres dress below. enter d e-Y 3. Se Nice Type i] cert'rfied Mail [I Registered ?- Insures (4 Restricted Deliv ? Express mail t,,, Merchandise ? Return Receip ? C.O.D. C3 Yes ary? (Extra Fee) ), ? Domestic Return fieceipt. . 102595-p0-M"0952 pS For my 1999 UNITED STATES POSTAL SERVICE First-Class Mail PosPStage $ Fees paid US ' Sender: Please Permit No. G-10 print your na me, address, and ZIP+4 in this box MARK A. COX, Plaintiff VS. JESSICA J. COX, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01 - 1883 Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF NOTICE TO DEFEND AND COMPLAINT. AND NOW, this April 9, 2001, I, Jane Adams, Esquire, hereby certify that on April 4, 2001, a true and correct copy of the NOTICE TO DEFEND AND COMPLAINT were served, via certified mail, restricted delivery, return receipt requested, addressed to: Jessica J. Cox 14 Cedar St. Mount Holly, Pa. 17065 DEFENDANT Respectfully Submitted: LV. No. 79,465 7 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF MARK A. COX, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 1 ?3 Civil Term JESSICA J. COX, ACTION IN DIVORCE Defendant AFFIDAVIT OF SEPARATICIN The parties to this action separated on November 2, 1999 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose my 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. Date: 1-17 -OZ ark A. Cox, Plaintiff yr rnrr z _x= r a e r v G 7 ? iy, rn C.J K MARK A. COX, Plaintiff vs. JESSICA J. COX, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01 - 1883 Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF AFFIDAVIT OF SEPARATION AND NOW, this February 5, 2002, I, Jane Adams, Esquire, hereby certify that on February 1, 2002, a true and correct copy of PLAINTIFF'S AFFIDAVIT OF SEPARATION was served, via certified mail, return receipt requested, addressed to: Jessica J. Cox 14 Cedar St. Mount Holly, Pa. 17065 DEFENDANT Respectfully Submitted: 4 1 J e Adams, Esquire D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ' ¦ Complete items 1, 2: and 3. Also complete Rem 4 if Restricted Delivery Is desired. ¦ Print your name and address on the reverse go that we can return the card todyou. ¦ Attach this card to th9 back of the mailplem. or on the front If space Perms. 1. Article Addressed to: N YES, lam ? Agent 3. SaMce Express MCI Ned ? Return Receipt fa Memhendise In D. ? sured Mail ? C.O 4. Restricted Delivery? (Extra Fee) ? Yee 2. Article Number (rrens/er ircm service label) 70? ! Y? )0001 PS Form 3811, March 2001 Domest? Return Receipt 10259501M-1424 0 o C ev ' v C k, r' Ci7 GJ?` r C71 P i3 - J 4>' - -C MARK A. COX, Plaintiff VS. JESSICA J. COX, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01 - 1883 Civil Term ACTION IN DIVORCE PRAECIPE TO TRANSMIT REC(L 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(d) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail, restricted delivery return receipt requested delivered on• April 4 2001 Affidavit of Service was filed April 9. 2001, 3. Date of execution of the affidavit required by §3301(d) of the Divorce Code: By Plaintiff: January 17. 2002, Date of filing and service of the plaintiffs affidavit required by §3301(d) of the Divorce Code on respondent: Filed: January 22. 2002. Served on Defendant: February 1. 2002. Affidavit of Service filed: February 5. 2002, 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Plaintiffs orieinal notice of intent and counter-affidavit was served on Defendant on March 1 2002 via certified mail return receipt requested : notice an d affidavit of service attached Respectfully Date: 7aar No . 79465 South Hanover St. lisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff MARK A. COX, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 01 - 1883 Civil Term JESSICA J. COX, ACTION IN DIVORCE TO? DDATE: February 25, 2002. You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the 3301(d) affidavit. Therefore, on or after March 18, 2002 the Plaintiff can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a Counter-Affidavit by the date above, the Court can enter a final decree in Divorce. Unless you have already filed with the Court a written claim for economic relief, you must do so by the above date or the Court may grant the divorce and you lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH[ YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief The filing of your counter-affidavit alone does not protect your economic claims. 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 Jessica J. Cox 14 Cedar St. Mount Holly Springs Pa 17065 MARK A. COX, Plaintiff VS. JESSICA J. COX, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA No. 01 - 1883 Civil Term ACTION IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 33010 of the DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because: (Check (i),(ii), or both:) _(i) The parties to this action have not lived separate and apart for a period of at least two years. _(ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, and expenses if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees, or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. I verify that the statements made in this counter-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: Jessica J. Cox, Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, you need not file the counter-affidavit. SEND ¦ Comp, ltem q ¦ Print yo so that % Attach th or on the 1. Art?1 J ?E 2. Article Number (rram'-' "7 i PS Form 3811, March Z IN THE COURT C QTY PENNSYLV ASIA CUMBERLAN M D ARK A COX, Plaintiff No 01 - Is83 Civi/Teru? vs. ACTION IN DNORCE JESSICA 1• Coy" efendant hereby certitat 2002, 1, Jane Adams,EsA'nre' ?r AND AND NOW, this March 25, OTICE OF of PLAINTIFF' S N , addressed to: on Marc,, ,2002, a true and correct copy receipt re4u 1 IJI?ITER AFFIDAVIT ,Was served, via certified mail, return CO Jessica J. CO. 14 Cedar St' 11065 M°nt't golly, Pa' DEFENDANT -d: Respectful], St. 1\1#&3 Cad, ?j I OR PLAINTIFF A'1 y? (,_? ?I ?._. .. _? "T . C T : 1 .• 1 \ ? ?? .) <nJ -? ¦ 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 Addrewed to: 14 v` UI' A. Received by Is Cleady) I B. n Rem'17 ? Yes below: ? No ? Express Mail ? Registered ? Return Receipt for Merchandise AMP ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number (Transfer Irom service label) / fJ? lM? 1 lO _l [.? PS Form 3811, March 2001 Domestic Return Receipt 102595-01-M-1424 IN THE COURT OF COMMON PLEAS Mark k. Cox, OF CUMBERLAND COUNTY OIL STATE OF PENNA. Plaintiff VERSUS Defendant _ No. 1883 Civil Term 2001 DECREE IN DIVORCE AND NOW, UY 2J' L6 ZS , Tea, IT IS ORDERED AND DECREED THAT AND Jessica J. Cox ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, 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. BY THE COURT: ATT T: J. PROTHONOTARY 7?w Zvo- ye° f' ""V'? ,?N.J? zo ??r? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Vs File No. ??bC'? - d 3 IN DIVORCE SSis? ) 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 hereby elects to resume the prior surname of -?)w ,r c \ , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Date: Si Si a of name eing resumed ) COMMONWEALTH OF PENNSYLVANIA COUNTYOFqLg. On the 1??day of9200_ , 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. Notary Public NOTARIAL SEAL PROTHONOTARY, NOTARY PUBLIC I MY COMMI EXPIRES CARLISLE C 1SMBER AND COUNTY JANUARY OUSE 4,2010 O ?p r7l es t`i i . f v