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Home My WebLink About04-4914DENISE J. FUHRER, Plaintiff, VS. WILLIAM B. FUHRER, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO.O y - tl91 Y CIVIL TERM : 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. When 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 in the Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013 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, TO GET LEGAL HELP SHOULD CONTACT: Cumberland County Lawyer Referral Service 32 South Bedford Street, Carlisle, Pennsylvania 1-(800)-990-9108 COYNE & COYNE, P.C. Coyne, Esquire ,t Street Cla4 Hill, PA 17011-4227 (717) 737-0464 Pa.. Supreme Ct. No. 53788 Attorney for Plaintiff DENISE J. FUHRER : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 0y' L/ 9 // CIVIL TERM WILLIAM B. FUHRER, Defendant. : IN DIVORCE COMPLAINT IN DIVORCE NOW COMES the Plaintiff, Denise J. Fuhrer, by her attorney, Lisa Marie Coyne, Esquire and files this Complaint In Divorce and avers the following in support thereof: 1. The Plaintiff, Denise J. Fuhrer, is an adult individual residing at 12 Flagstone Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, William B. Fuhrer, is an adult individual residing at 308 Glenn Road, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Plaintiff and Defendant are sui juris and have been bona fide residents in the Commonwealth for at least six months previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 1, 1999, in New Cumberland, Pennsylvania and separated on or about February 7, 2003. 5. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 6. There have been no prior actions of divorce or for annulment between the parties. 7. 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. Further, Plaintiff waives her right to request that the parties participate in marriage counseling. 2 COUNT I-REOUEST FOR A NO FAULT DIVORCE 8. Paragraphs 1 through 7 of this Complaint are incorporated by reference. 9. The marriage is irretrievably broken. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 11. At the appropriate time, Plaintiff may submit an affidavit alleging that the parties have lived separate and apart for at least two (2) years. WHEREFORE, if both parties file affidavits consents to a divorce after ninety (90) days have elapsed from the filing of this Complaint, or alternatively if the appropriate time has elapsed since date of separation, Plaintiff respectfully request the Court enter a Decree in Divorce, pursuant to Section 3301(c) or Section 3301(d), as may be appropriate. COUNT H - EOUITABLE DISTRIBUTION 12. Paragraphs 1 through 11 of this Complaint are incorporated by reference. 13. Plaintiff and Defendant have acquired property, both real and personal, and debt during their marriage. 14. Plaintiff and Defendant have been unable to agree as to the equitable division of said property and debt. WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property and debt pursuant to the Divorce Code. 3 COUNT III - ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND EXPENSES 15. Paragraphs 1 through 14 of this Complaint are incorporated herein by reference. 16. Plaintiff has retained counsel and will incur considerable expense in preparation for her case in the employment of counsel, accountant, appraiser, actuary, and the payment of costs. 17. Plaintiff is without adequate funds to support herself and to meet the costs and expenses of this litigation and is unable to sustain herself during the pendency of this action. WHEREFORE, Plaintiff respectfully requests this Honorable Court to order Defendant to pay Plaintiff alimony pendente lite, counsel fees, costs and expenses associated with this divorce action. Respectfully submitted: COYNE & COYNE, P.C. Dated: QI - 2 d `( By: )39 MARIE COYNE, E uire Market Street Hill, PA 1 70 1 1-422 7 737-0464 Pa. S. Ct. No. 53788 Attorney for Plaintiff 4 VERINCATION The facts set forth in the foregoing are true and correct to the best of the undersigned's knowledge, information and belief and are verified subject to the penalties for unswom falsification to authorities under 18 Pa. C.S.A. §4904. Dated: °L z1 e ??r•?__ ?- F W s 4, ? O. I?T ?i I- Q ? N SU c, N n i f-ri h SHERIFF'S RETURN - REGULAR CASE NO: 2004-04914 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FUHRER DENISE J VS FUHRER WILLIAM B CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT - DIVORCE was served upon FUHRER WILLIAM B the DEFENDANT , at 1945:00 HOURS, on the 30th day of September, 2004 at BOBBY RAHAL TOYOTA LEXUS 6305 CARLISLE PIKE MECHANICSBURG, PA 17050 by handing to WILLIAM B. FUHRER a true and attested copy of COMPLAINT - DIVORCE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.14 Affidavit .00 Surcharge 10.00 .00 36.14 Sworn and Subscribed to before e this z q, day of A.D. / ProNion ary So Answers: R. Thomas Kline 10/01/2004 COYNE & COYNE By : Deputy S riff ?- DENISE J. FUHRER , Plaintiff V. WILLIAM B. FUHRER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4914 CIVIL TERM : CIVIL ACTION -- LAW IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE To the Prothonotary: Please enter the appearance of Elizabeth S. Beckley, Esquire, Thomas A. Beckley, Esquire, and Beckley & Madden, of Counsel, on behalf of Defendant, William B. Fuhrer, in the above-captioned matter. DATED: December 1f9, 2004 Of Counsel BECKLEY & MADDEN 212 North Third Street P.O. Box 11998 Harrisburg, PA 17108-1998 (717) 233-7691 CERTIFICATE OF SERVICE: I hereby certify that on this date a true and correct copy of the foregoing document was served upon the person and in the manner indicated below. FIRST CLASS MAIL Lisa Marie Coyne, Esquire Coyne & Coyne, P.C. 3901 Market Street Camp Hill, PA 17011-4227 DATED: December 16, 2004 rte. ?? . " _{ ? ,. _i _ ?-: A, 1 ??__ F-_,.? (.. j ? *' ? .. G?., 4 rr ' r ? DENISE J. FUHRER, Plaintiff, VS. WILLIAM B. FUHRER, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4914 CIVIL TERM IN DIVORCE PETITION TO WITHDRAW AS COUNSEL FOR PLAINTIFF TO THE HONORABLE, JUDGES OF SAID COURT: AND NOW comes, Lisa Marie Coyne, Esquire, counsel for Plaintiff and avers the following in support of request for permission to withdraw from representation of Plaintiff in this matter. 1. On or about, September 1, 2004, the Plaintiff, Denise J. Fuhrer, engaged the professional services of undersigned legal counsel. 2. Subsequent to entering into that written contract, and after performing a significant amount of legal work on behalf of the Plaintiff, the undersigned submitted repeated requests for payment for services rendered. 3. Plaintiff has failed to remit payment of outstanding invoices due and owing to the undersigned. 4. The undersigned legal counsel requests Court permission to withdraw from representation of Plaintiff in this matter. WHEREFORE, the Petitioner, Lisa Marie Coyne, Esquire, to withdrawal as legal counsel of record for the Plaintiff Respectfully submitted: Dated L .Z6 o CO TiMa , P.C. By: e Coyne , squire ket Street Camp Hill, PA 17011 (717) 737-0464 Pa. Supreme Ct. No. 53788 Petitioner R,1 _• ,64 -r _.1 y DENISE J. FUHRER, Plaintiff, Vs. WILLIAM B. FUHRER, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4914 CIVIL TERM IN DIVORCE RULE TO SHOW CAUSE 4• AND NOW THIS 29 - day of ?., 2006, upon consideration of Lisa Marie Coyne's Petition to Withdraw as Counsel for Plaintiff, a Rule is issued upon the Plaintiff to show cause why Lisa Marie Coyne's Petition to Withdraw should not be granted. This Rule is Returnable Z-c days after service upon the Plaintiff. CF: sa Marie Coyne, Esquire, Peti enise J. Fuhrer, Plaintiff 4 BY THE COURT: Q: i I f 6? Ei r ;fill DENISE J. FUHRER, Plaintiff, VS. WILLIAM B. FUHRER, Defendant. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA :NO. 04-4914 CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the Rule to Show Cause, dated June 29, 2006 was served July 5, 2006 upon the below-referenced individual at the below listed address by way of first class mail, postage pre-paid: Ms. Denise Fuhrer 12 Flagstone Drive Carlisle, PA 17013 Ms. Denise Fuhrer 1290 West Horizon Ridge Parkway Apartment 2417, Building 24 Henderson, NV 89015 Dated: 101, Respectfully submitted, COYNE & COYNE, P.C. BY: ?isa Pane Coyne r a. upreme Ct. No. 53788 3 01 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Petitioner OF THE FP ".:,-' '',Jr)TARY 2009 SEP -2 PPI 3: ! CUP?# a )NTY PENII'?,,' 'l N;`sp`a:"A DENISE J. FUHRER, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO.04-4914 CIVIL TERM WILLIAM B. FUHRER, Defendant. : IN DIVORCE PETITION TO MAKE RULE ABSOLUTE TO THE HONORABLE, JUDGE KEVIN A. HESS: AND NOW comes, Petitioner, Lisa Marie Coyne, Esquire, and avers the following in support of request for Rule Absolute to Permit Petitioner's withdrawal of representation of Plaintiff in this matter. 1. On June 27, 2006, Petitioner, Attorney Lisa Marie Coyne, filed a Petition to Withdraw as Counsel for Plaintiff. 2. On June 29, 2006, Judge Hess, of this Honorable Court issued upon the Plaintiff, Denise J. Fuhrer, a Rule to Show Cause why the Petitioner should not be permitted to withdraw as counsel to the Plaintiff. (A copy of the Order is attached as Exhibit "A"). 3. On July 5, 2006, the Petitioner, Lisa Marie Coyne, Esquire, served a true copy of the Rule to Show Cause upon the Plaintiff, Denise J. Fuhrer. 4. Plaintiff did not respond to or answer the Rule to Show Cause and twenty days have elapsed since service of the Rule to Show Cause was made upon the Plaintiff. DENISE J. F_"HRER, Plaintiff, vs. WILLIAM-B )UHRER, Defendant. I5 THE COURT OF CON MON PLEAS OF CUMBERLA-N-u COi Nw, PENNSYLVANIA : NO. 04-4914 IN DIVCoRCI, RULE TO SHOW CAUS'IF Al*,T) No N THIS day of 2006, upon consideratior iii Li-;a N [arie 'o)me; s.P,cgEon..ro, Withdraw as (,,, zm; r:l for Plaintiff, a Rule is issued upon _ the Plaintiff cc show cause why Lisa Marie Coyne' s Petit on tc fit' th.dra x should not be granted. This Rule is Retarmkle l days after service upon the Plaints f. BY 'I HI3 ?OUR.T: J. CF: Lisa N13n.c : ay-ie, Esquire, Petitioner Deviso I Fulrer, Plaintiff TRUE COPY FROM RECORD In l' ast i mny whereof, t hero unto set my hand . and t SEMI f said Cou et Aisle, Pa. TK, l=n?ti ?? 1? P-? • :. •P notary i CERTIFICATE OF SERVICE I, Lisa Marie Coyne, Esquire, of Coyne & Coyne, P.C., hereby certify that true copy of the foregoing Rule Absolute was served this date upon the below-referenced individual at the below listed address by way of first class mail, postage pre-paid: Ms. Denise Fuhrer 12 Flagstone Drive Carlisle, PA 17013 Ms. Denise Fuhrer 1290 West Horizon Ridge Parkway Apartment 2417, Building 24 Henderson, NV 89015 Dated: q 3 Q Respectfully submitted, COYNE & COYNE, P.C. BY: ?--- 4epre 'e Co e, Esqu' me Ct . No. 537 8 3901 Market Street Camp Hill, PA 17011-4227 (717) 737-0464 Petitioner p .1 OF AVM,,',AFS 9 P -4 Ph 3: 02 OACERLk .0 COUNTY PEN ?Y?VN? A W i ? DENISE J. FUHRER, Plaintiff, VS. WILLIAM B. FUHRER, Defendant. AND NOW this IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-4914 CIVIL TERM : IN DIVORCE RULE ABSOLUTE S' day of -'-?a i?,-t - , 2009, it appearing that on July 5, r 2006, Petitioner served upon Plaintiff, Denise J. Fuhrer , a Rule to Show Cause why her Attorney Lisa Marie Coyne should not be permitted to withdraw as his counsel, and the Plaintiff did not answer or reply to said Rule within twenty (20) days of service of same, Petitioner, Lisa Marie Coyne, Esquire is hereby granted permission to withdraw as counsel of record for the Plaintiff, Denise J. Fuhrer. BY THE COURT: r f Cc: v -"Lisa Marie Coyne, Esquire, Petitioner ? Denise J. Fuher, Plaintiff Kevin A!Uess, Judge FILED-C FFICE OF THE MO HNOTAPY 2999 SEA' -9 Fri 4: 0 J N, LVIIIIN A DENISE J. FUHRER, Plaintiff, VS. WILLIAM B. FUHRER, Defendant. TO THE PROTHONOTARY: i i : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO.04-4914 CIVIL TERM IN DIVORCE PRAECIPE Please withdraw the appearance of Coyne & Coyne, P.C. of behalf of the Plaintiff, Denise J. Fuhrer in the above matter. COYNE & COYNE, P.C. By: 1. - "T - Li Marie Coyne, squire 39 1 Market Street amp Hill, PA 17011-4227 (717) 737-0464 Pa. S. Ct. No. 53788 FILED- THE P'Y`, -,TARY OF 2009 SE#P 2#4 Fll 1: 19 Ll ?? (David D. Bueff Prothonotary XirkS. Sohonage, ESQ Soricitor <i J 0 V nF C % 7750 2nd Deputy Prothonotary Office of the Prothonotary Cumberland County, 1n- ennsyrvania JOY - Y CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 30T' DAY OF OCTOBER, 2012, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R. C. P. 230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY Renee X Simpson 15` deputy prothonotary Z?l O?' Irene E. Morrow One Courthouse Square 0 Suite 100 • Car(sfe, Pq 17013 • (717) 240-6195 0 Fa.X (717) 240-6573