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HomeMy WebLinkAbout05-5962 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff : S1-<:..f\.\,rv(,e. L. Coofd: No. OS -s9 t.. ~ v. : Civil Term : IN DIVORCE Defendant : Qxy\')c,IYrl (\ t='. CC;o~e..{ NOTICE TO DEFEND AND CLAIM RIGHT~ YOU HA VE 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 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 Coutthouse Square, Carlisle, Pennsylvania, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OF 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 2 Liberty A venue Carlisle, P A 17013 (717) 249-3166 , Plaintiff S~f\'\v..'i\~ L. ~~~.< IN THE COURT OF COMMON PLEAS CUMBERALND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DIVORCE Defendant No. OS' - S9/,...). 0e.(lj<^m,n \=" CoofVI NOTICE OF AVAILABILITY OF COUNSELING (FW'LL 'L-~W"), You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302( d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the Court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you ,rod your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. .' ~ Plaintiff ~\-e.f l1c..A\e, L. LOo{d v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYI. V ^""IIA No. OS ,SqG.?-C1VIL TERM Defendant : \2:>e.. u...'y;.. <Y'i I n ~. CoD f e.X IN DIVORCE COMPLAINT UNDER &3301(c) or (d) OF THE DIVORCE CODE I. PlaintiffisS,\-", {)\'1IA\AAC". LaO~e/. who currently resides at ~l 0ycr..cl. ~+--. We.\Al '1l \ le PA \ l ~~y I / Cumberland County, Pennsylvania. 2. Defendant is ~ (\',r, <<11 (\ LN'\ge / , who currently resides at .J I So ~t-. C~\( mCXWe:")\i'1 \ (~'> T vrl. ffio'1) {l.fc,\J.,r-.+y 'i/,,151l 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. tJl!.\A1\'\\~t" . 9A- / married on fYh ,-/-1.!::1.,-19Q I at 4. Plaintiff and Defendant were 5. The marriage is irretrievably broken, and the parties separated on ~I J'f) / ;),Da S' 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his /her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. '. , 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right t9 request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. \ \- \l.- 05 Date ~~.~Vtc,. -_t ~-1 Plainti f, Pro Se I, ~\-c- Ph: v...:..... (.~ p-- .r , verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. S4904. \ \- \1- 0.") Date: h: ~ Yb - (' C:r--. f<-/ Plainti , Pro Se Assisted by: MIDPENN LEGAL SERVICES PRO SE DIVORCE CLINIC (717) 243-9400 .-'~. -, 'c;.-\ '.:0'" ~ '-cJ ..- -' /' ..- .' -'C eJ' ,s-, ------- ------- . Plainti ff ~\-<.~\"a..V\\e. L. Cccpe.,y : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYL VANIA v. : NO. 05 - S9/..~IVIL TERM Defendant : DIVORCE ~V\')o.V\''\'tf\~. Loofe.( PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, S\- c:. f ~11l V\"le' l. COl'o.fld Plaintiff, to proceed in forma paupens. I, Valene J. Faden, attorney for the party proceeding in forma lli\llPeris, certify that I believe the party is unable to pay the costs and that I am providing free kgal services to the party. () -i\ ,A -- :;,'\ ", i::::~ -- .....l ~". --;::. .' {'\ Cr' ------- , " Plaintiff St.C-f~vi.le. L. L.oare-y IN THE COURT OF COlvL'\[ON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA No. Q4: CIVIL TERM 0'..>- <.J7GJ. (!.-;~'I/ IN DIVORCE Defendant ~V\)Q1')tiVl ~ Loope.1" ACCEPTANCE OF SERVICE I, DEFENDANT, accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904, relating to unsworn falsification to authorities. \(, - IG - 0<;'" ~O" \ ' w.,;~ , Defenllant ~, ta;~ Date (') s "",'~ -;::>~\ Qi\' ,....> "'" c;o "-,, c;:l 'M ~)/' S;~"- ~~-\ :' ::;~~ s;; -, :;,~ - \.P ~ ~- ," o -t1 -\ ::r:.-n p"\~ --t"Jp.3, ~(_:~~~); -.... --<-, (5~~ -';7"-"' :'Ff'f' S ~ :;<:: q -'=" -'=" ~ STEPHANIE L. COOPER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERALND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW DIVORCE BENJAMIN F. COOPER, Defendant No. 05-5962 AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on November 17,2005. 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. 1i4904 relating to unsworn falsification to authorities. /'-:' '.!;... - , Jt-ot V)C~ . l.-nQ~Jy STEPH NIE 1. COOPER, Plaintiff DATE: 3- ,:)..4 - 01.0 ,-.,. , --. -' \"<:- .' r"'\ STEPHANIE L. COOPER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERALND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW DIVORCE BENJAMIN F. COOPER, Defendant No. 05-5962 AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on November 17, 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 ofa 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 I 8 Pa, C,S. 1i4904 relating to unsworn falsification to authorities. DATE: ~'2H"O~ 'D.. J'~ ~. ~~~ BENJA IN F. COOPER, efendant ::~:tl ,-') :\'\ -- -.._! (.,.f STEPHANIE L. COOPER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERALND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW DIVORCE BENJAMIN F. COOPER, Defendant No. 05-5962 WAIVER OF NOTICE OF INTENTION TO REOUEST 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 loose rights concerning alimony, division of property, lawyers 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. 94904 relating to unsworn falsification to authorities. DATE: 3 - ), <..../- 01.:" &" ~ ly~ I I . a.1) , Coo~~ STEP ANTE 1. COOPER, Plainti , >f1 ..... .,-,'~ ','; __J f-.-) (,.J - STEPHANIE L. COOPER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERALND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DIVORCE BENJAMIN F. COOPER, Defendant No. 05-5962 WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 loose rights concerning alimony, division of property, lawyers 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. 94904 relating to unsworn falsification to authorities. DATE: 3 - 2S0<C1 \1o,~'::~ \. Coo?U"- BENJA IN F. COOPER, Defendant r~.--' "..;._' ~> ::;! ,I; -, J'.,,) c.) STEPHANIE L. COOPER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERALND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW DIVORCE BENJAMIN F. COOPER, Defendant No. 05-5962 PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: I. Grounds for divorce: irretrievable breakdown under Section 330 I (c) of the Divorce Code. 2. Date and manner of service of Complaint: Acceptance of Service executed by Defendant on December 10,2005. 3. Date of execution ofthe Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: March 24, 2006; by Defendant: March 28, 2006. 4. Related claims pending: there are no claims pending. 5. Date Plaintiff's and Defendant's Waivers of Notice were filed with the Prothonotary: April 7, 2006. /' / . :1.._____ /'? DATE: I," , ,;1'- U , 7 ,"\ ~\ , .VLi I, ,/ - l~ijr! )4/ Valerie J. Faden, I.D. # 87442' 2807 Market St. Camp Hill, PA I70l I (717) 920-9460 Attorney for Plaintiff .: _1 ("",) (.,j . ~ ........ + + + + + + + + + + + + + + + + :f;+"t;:f:t':f.:f +7'f:+':+';+: :f. + + + + + + + + + + + + + + + + + + + + + + + + '" ++ :+::t:+.:f. :+;:f.:+;:+':+:f. if.:+;:+; '+::t;'fO+; :+: :+: :f.:f.:+;'f :+::+::+::+:~ :+;:+:++:+::+::f.:+:++:t+:+:+::+;:+:++:+::+;+~ + + + + + + + + + + + + + + + + + + + Civil Term + + + + + + + + + + + + + + + + + + IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY Stephanie L. Cooper PENNA. STATE OF No. 05-5962 Plaintiff + + + + + + + + VERSUS Benjamin F. Cooper Defendant + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + DECREE IN DIVORCE A p_uJ 12- ?./Y')h. IT IS ORDERED AND AND NOW, Stephanie L. Cooper DECREED THAT , PLAINTiFF, Beniamin F. AND 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; There are no claims pending. THEtJ; ~ oft By AT ST: /' J. ~~P"O'HONOTA"' :i''f:t'f + '+'+ '+':+':+: 'f:+::+: + :+:+++'f:t' :+: +++ 'f:+:++++:f.+:+:+ + ++ 'f Of '+' '+' + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + '*' '+' ++ _ ~/ .? /r;nM:/ ??""1A -'7~ -py)' /:P"~-><1 ~uI ,/'9 .' . ", ,,7,/ '.5<: - h -7:1' yC.ft