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Home My WebLink About05-0144 'I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRADLEY S. COY, Plaintiff CIVIL ACTION - LAW v. NO. Dtj- /i.f-tf ~ RENEE S. COY, Defendant 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 grounds 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 at Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PAl 7013. 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 WEIGLE & ASSOCIATES. Pc. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257,1397 II. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRADLEY S. COY, Plaintiff CIVIL ACTION - LAW v. NO. RENEE S. COY, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, comes the above named Plaintiff, Bradley S. Coy, by and through his attorneys, Weigle & Associates, P.c., and Richard L. Webber, Jr., Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff, Bradley S. Coy, is an adult individual presently residing at 158 Neil Road, Shippensburg, Cumberland County, Pennsylvania 17257, since August 29,2004. 2. Defendant, Renee S. Coy, is an adult individual presently residing at 134 Cleversburg Road, Shippensburg, Cumberland County, Pennsylvania 17257, since December, 2003. 3. The Plaintiff and Defendant are nationals and citizens of the United States of America, and both have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of the Complaint in Divorce. 4. The Plaintiff and Defendant were married on August 21, 1999, in Shippensburg, 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 the Plaintiff may have the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. 8. The parties have lived separate and apart since August 22,2004. 9. The Plaintiff requests the court to enter a decree of divorce. WEIGLE & ASSOCIATES. Pc. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257,1397 11- WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony and for such other and further relief to which Plaintiff shall be entitled. WEIGLE & ASSOCIATES, P.C. By: ~/(~-/~ A Richard L. Webber, Jr., Esquire .-'" / Attorney for Plaintiff Attorney ID #49634 126 East King Street Shippensburg, P A 17257 Telephone 717-532-7388 WEIGLE & ASSOCIATES, P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 t VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce 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. Dated: }-7-0S- ~/I , I '5' ~ Bradle . Coy, P~ WEIGLE & ASSOCIATES. P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257,1397 ,r.r:'~. \~ sJ - J") ~ ~ ~ ~. D- d"\ c' (") ~.; ~ ~'^', -< ~ r-'l c-=> c::> coOn C- :r~D- -',JO' -- o -n --I :L'""T1 1\1F" -.-~ rn :.jC( ( :U :f :';i :~n ..-:~. rn , i ~~ "'J :<. I ....j ~ - ., w f'v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRADLEY S. COY, Plaintiff CIVIL ACTION - LAW v. NO. 05-144 Civil RENEE S. COY, Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND Patricia A, Frey, being duly sworn according to law, deposes and says that on January 18,2005, a true and attested copy of Notice to Defend and Claim Rights with Complaint in Divorce was served upon the Defendant, Renee S, Coy, Manner of service: by mailing the same postage paid, certified mail, addressee only, and return receipt requested, at Shippensburg, Pennsylvania, addressed as follows: Renee S, Coy 134 Cleversburg Road Shippensburg, PA 17257 The return receipt signed by the Defendant is evidence of delivery to her and is attached hereto as "Exhibit A." ~/A%~/l.~ Patricia A. Frey '. Sworn to and subscribed before me this 20th day of January, 2005, JJ~~ I.. 10lljL Notary Puqlic NO'IMIoloL M. M1IIICII\ L 1CME Ncltaoy NlIc 9_ . _ 1Il1lGIICIQJllH,aJIIENNCICQMY Mv~.__Jun 7. 2008 WEIGLE & ASSOCIATES, Pc. - ATTORNEYS AT LAW - 126 EAST KING ~;TREET - SHIPPENSBURG, PA 17257-1397 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA BRADLEY S. COY, Plaintiff CIVIL ACTION - LAW v. NO. 05-144 Civil RENEE S. COY, Defendant IN DIVORCE PROOF OF SERVICE 0- .-'I l'- <0 m 0- ~ <0 U,S, Postal Service CERTIFIED MAIL RECEIPT (Domestic Mall Only; No Insurance Coverage Provided) o o o CJ Return Reciept Fee (Endorsement Required) C Restr1cted Delivery Fee o (Endorsement Required) lJ') o Certified Fee Postmark q )~ Here "~ Total Postage & Fees $ m o to.} ~ ~;;..(".&'m~!l__oS.'mJ;oO.}'....__m:o~,,' .oo____mmmmmo__o ~:~lp;pLe.v.er.s.h=-s--Road----mm--o.ommm..momo 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: Renee S. Coy 134 Cleversburg Road Shippensburg, PA 17257 3. Se~ Type lJI't;ertified Mail o Registered o Insured Mail o E;.w6ress Mail ~eturn Receipt for Merchandise DC,O,Q, .; ~s 4. Restricted Delivery? (Extra Fee) 61h,'n\~ A 2. Article Number (Transfer from service label) PS Form 3811 , Augusl2001 7003 0500 0000 8493 8719 Domestic Return Receipt 102595.Q2-M-1540 WEIGLE & ASSOCIATES, RC ATTORNEYS . . - AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 {. .-,i , ~ c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRADLEY S. COY, Plaintiff CIVIL ACTION - LAW v. NO. 05-144 CIVIL RENEE S. COY, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under S 3301(c) of the Divorce Code was filed on January 7,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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. ~5 Bfadley S. , aintiff:.-s Dated: /-)-6" 7 WEIGLE & ASSOCIATES, P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257,1397 t;:::?, s c.- ~ ..,... ~ o -\'\ --0 ~ :t. -.-, 1I'f'"" _,..-, r\'~ .~_;':j(~;l '3 C> \_~ -~.\ :,'.:~!(~ ~;{' '~ - cf' , ,'^ v'" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRADLEY S. COY, Plaintiff CIVIL ACTION - LAW v. NO. 05-144 CIVIL RENEE S. COY, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under ~ 3301(c) of the Divorce Code was filed on January 7,2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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. ~ 4904 relating to unsworn falsification to authorities. Dated: //CA~/07 / I /~u, ~ Renee S. Coy, Defendant WEIGLE & ASSOCIATES. Pc. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 f".,) = = --J C- :::::.~:J ~ N \..0 ~ :;:l ;;;fl ::D t r-' -.7 it1 .,...jO ;:~~3 t) 'T~ :!i .)-~,~' : '7() ~'2tm ',:> ~ -0 ~ (fl .r:- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BRADLEY S. COY, Plaintiff CIVIL ACTION - LAW v. NO. 05-144 CIVIL RENEE S. COY, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 6 3301(c) AND 6 3301(d) 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. 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. Dated: ./_ ,..)L_ '7 / v J ~ ~5.~ Bradley S. oy, Plain~ WEIGLE & ASSOCIATES. PC, - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257,1397 rc;; :e. <- -:;:::- ~ ~ ~ .-1 -t'"; ~r: \i _~, -0\;....., .--~J...-( /3 ~j;\ ,.C'\ 0") '''::h, ',3 .......--~ <':0 :::.(. ~ ::;- - U' c...J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA BRADLEY S. COY, Plaintiff CIVIL ACTION - LAW v. NO. 05-144 CIVIL RENEE S. COY, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER 6 3301(c) AND 6 3301(d) 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. 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. Dated: I /::2:; /D7 / I WEIGLE & ASSOCIATES, P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257,1397 rc; s '- -:;;'" ~ {'V ....D ~ :t.-.. rl"'e, ~,9\6 'A(~, ~.' ".'! ......-' i \ '.:r~\ ':'C\ -j....# $~~O ::..::. ...., ~ - c.f\ c.,.) BRADLEY S. COY , Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v CIVIL ACTION - LAW NO. 05-144 RENEE S. COY, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under ~ 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: January 18, 2005, by mailing U.S. Certified Mail, Restricted Delivery, Return Receipt Requested, at Shippensburg, Pennsylvania, addressed to Defendant, Renee S. Coy, 134 Cleversburg Road, Shippensburg, Pennsylvania 17257. 3. Date of execution of the affidavit of consent required by ~ 3301(c) of the Divorce Code: by Plaintiff, January 25,2007; by Defendant, January 25,2007. 4. Related claims pending: None. 5. Date Plaintiffs Waiver in ~ 3301(c) Divorce was filed with the prothonotary: January 29, 2007 Date Defendant's Waiver of Notice in ~ 3301(c) Divorce was filed with the prothonotary: January 29,2007 WEIGLE & ASSOCIATES, P.c. Date: 1 1).1 (0 7 o '1 vv--L 4- Richard L. Webber, Jr., Esquire Attorney for Plaintiff Attorney ID #49634 126 East King Street Shippensburg, P A 17257 Telephone (717)532-7388 WEIGLE & ASSOCIATES, p.c, - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257,1397 ;f. ;f. ;f. ;f. ;f. ;f. ;f. ;f. ;f. ;f. ;f. ;f. ;f. ;Ii ;f. ;Ii ;Ii if. ;f. ;Ii ;Ii ;f. if. if. ;t; '" ;Ii"''''", '" ;t; IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. BRADLEY S. COY Plaintiff No. 05-144 CIVIL VERSUS RENEE S. COY Defendant DECREE IN DIVORCE AND NOW, 1~~ , ?007 , IT IS ORDERED AND 70" DECREED THAT BRADLEY S. COY , PLAI NTI FF, AND RENEE S. COY , 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 if. if. '" '" ;Ii '" if. if. ;f. if. if. if. if. if. if. if. if. if. if. '" Ellif.;f. ~ OUR/;/L PROTHONOTARY if. if. if. ~ if. ff.if. if. if. if. if. if. if. ~ J. if. if. if. if. ff. ff. '" if. '" '" if. '" if. ff. if. '" '" . #;C7 f. /(/'1.:1"1 ~J.(., arT:.. e ~ fp ~~'~,?.pp LO. t e , , . . ". . < . \, "