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Home My WebLink About87-0023IN THE COURT OF COMMON PLEA CUMBERLAND COUNTY, PENNSYLVANIA Civil Action - Law No, 23 Civil 1987 FRANCIS A. COCHRAN, Plaintiff WAYNE M, COCHRAN/ Defendant AFFIDAVIT OF SERVICE LAW OFFICES MANCKE, LIGHTMAN & WAGNER 2233 NORTH FRONt StReEt HARRISBURG, PA. 17ILO FRANCIS A. COCHRAN, Plaintiff V. WAYNE M. COCHRAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Civil Action - Law No. 23 CIVIL 1987 IN DIVORCE AFFIDAVIT OF SERVICE AND NOW this ay of January, 1987, comes Gary M. Lightman, Esquire, attorney for the Plaintiff in the above divorce action and states that he served a true and correct copy of the Complaint in Divorce Under Section 201(a) and/or 201(c) of the Divorce Code upon the Defendant, Wayne M. Cochran at his last known address of 111 Skyline Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 by certified mail, addressee only, return receipt requested. Said receipt is attached hereto indicating service was made on January /~) , 1987 Sworn and subscribed to before me this ,/~:?~?day of January, 1987. "i' ."' JAJ~IE A. LENKER, ~.~0'[,?'( PU~_~C B-G~y/M. Light~, ~squire ~ A~torney for Plaintiff 111 Sky'line Drive ~wiicsburg, Pa. 17055 FRANCES A. COCHRAN, Plaintiff Vo WAYNE M. COCHRAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Civil Action - Law No. ~ .~ Civi 1~C~l_j~~ 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 w-itho~ll~ 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 ~ny other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including c~stody 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 Prothono- tary of Cumberland County Courthouse, Carlisle, Pennsylvania. I]~ YO[] 'DO NOT I~ILE A CI,AIM FOI~ ALIMONY, DI'VISION OIi'I~I<OPI~R'I'Y, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY'LOSE TIlE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT t~VE 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 Lawyer Referral Service Court Administrator Cumberland County Courthouse Carlisle, Pennsylvania 17013 717-249-1133 ~NCKE, Jry M. ightman, Esq ire Aqto~n~y for Plaintiff FRANCES A. COCHPAN, Plaintiff Ye WAYNE M. COCHRAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Civil Action - law No. ~ ~ Civil 1OBY~ IN DIVORCE AFFIDAVIT Frances A. Cochran deposes and says: being duly sworn according to law, i. I have been advised of the availability of counseling and understand that I may request th;~t the require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is ava'il.~l~le to me t~pon I~Oqt~e~t. 3. Being so advised, I do not request that the Court require that my spouse and I participate in the counseling prior to a divorce decree being handed down by the Court. I understand that false statements ]~erein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsifica- tion to authorities. Frances A. Cochran FRANCES A. COCHRAN, Plaintiff V. WAYNE M. COCHRAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Civil Action - Law No. Civil 1986 IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 201(a) AND/OR 201(c) OF THE DIVORCE CODE 1. The Plaintiff, Frances A. Cochran, is an adult individual residing at 111 Skyline Drive, Mechanicsburg, Cumberland County, Pennsylvania and has resided there for the past three years. 2. The Defendant, Wayne M. Cochran, is an adult individual residing at 111 Skyline Drive, Mechanicsburg, Cumberland County, Pennsylvania, and has resided at this address for the past three years. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for her entire life, 34 years, and at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 10, 1977 in Fairfield, Adams County, Pennsylvania. 5. There have been no prior actions for divorce or for annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America of its Allies. COUNT I. 8. Paragraphs 1 through 7, inclusive, are incorporated herein by reference and made a part hereof. 9. The marriage is irretrievably broken. 10. the Plaintiff requests the Court to enter a Decree in Divorce pursuant to Section 201(c) of the Divorce Code. COUNT II. 11. Paragraphs 1 through 10 are incorporated herein by reference and made a part hereof. 12. The Defendant has offered such indignities to the innocent and injured Plaintiff as to render her condition intolerable and life burdensome. 13. Plaintiff requests the Court to enter a Decree in Divorce pursuant to Section 201(a)(6) of the Divorce Code. COUNT III. 14. Paragraphs 1 through 13 are incorporated herein by reference and made a part hereof. 15. Plaintiff requests the Court to allow her reasonable alimony pendente lite, counsel fees and expenses pursuant to Section 502 of the Divorce Code and Rule of Civil Procedure 1920.31. COUNT IV. 16. Paragraphs 1 through 15 are incorporated herein by reference and made a part hereof. 17. Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties pursuant to Section 401 of the Divorce Code and Rule of Civil Procedure 1920.33. WHEREFORE, Plaintiff prays your Honorable Court to: (a) Enter a Decree of Divorce under Section 201(a) and/or 201(c) of the Divorce Code; (b) Order an equitable distribution of the marital property; (c) Order payment of alimony pendente lite, counsel fees and expenses as the Court deems just and reasonable; (d) Such other relief as the Court deems just and reasonable. Date: December ~' 1986 FrancescA. Cochran MANCKE, i ~ AN & WAGNER By Gar~ At~rney for Plaintiff CO~ONWEALTlt OF PENI~,~YLVANIA COUNTY OF DAUPtlIN SS Personally appeared before me, a Notary Public in and for the Commonwealth and County aforesaid, the undersigned, bein~ duly sworn accordinl~ to law, deposes and says that the facts set forth in the £oregoin~ Complaint in are true and correct. Divorce Under Section 201(a) and/or 201(c) Frances A. Cochran Sworn and subscribed to before me this ~Z~rJ day of December 198 6 COURT OF COM}~ON PLEA CUMBERLAND COUNTY, PENNSYLVANIA No. ~ ~ Civil ~ IN DIVORCE /~ FP~NCES A. COCHRAN, Plaintiff V. WAYNE M. COCHP~N, Defendant COMPLAINT IN DIVORCE UNDER SECTION 201(a) and/or 201(d) OF THE DIVORCE CODE LAW OFFICES MANCKE, LIGHTMAN & WAGNER 2233 NORTH FRONT STREET HARRISBURG, PA. 17110 WE DO HEREBY CERTIFY THAT THE WITHIN IS A TRUE AND COR- RECT COPY OF THE ORIGINAL FILED IN THIS ACTION BY ATTORNEY LAW OFFICES MANCKE, LIGH'TMAi~ & WAGNER TO YOU ARE HEREBY NOTIFIED TO rILE A WRITTEN RESPONSE TO THE ENCLOSED WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT k~AY BE ENTERE[~ ~GAINST YOU aY ATTOgNEY H 105.157 REV. 8 80 COUNTY Cumberland COMMONWEALTH OF PENNSYLVANIA DEPARTMENT OF HEALTH VITAL RECORDS RECORD OF DIVORCE OR ANNULMENT ~ (CHECK ONE} STATE FILE NUMBER STATE FILE DATE 1. NAME (First) Wayne M. Cochran (Middle) HUSBAND (Last) 2. RESIDENCE Street or R.D. City, BorG. or Twp. County State 111 Skyline Drive. Mechanicsburg, Cumberland Cty. 2. DATE OF BIRTH 4. PLACE Pa OF BIRTH (Mon th) fda y) (Year) 1/3/46 (state or Fore~n ~untry) New York BLACK OTHE pecify) OF THIS 2 w [] MARRIAGE 7. USUAL OCCUPATION dr a f t sman WIFE 8. MAIDEN NAME (First) (Middle) (Last) 10. RESIDENCE Street or R.D. City, BorG, or Twp. County State 111 Skyl±ne Drive, Mechanicsburg, Cumberland Cry, 13. RACE 12. NUMBER WHITE BI-ACK OTHER (Specify) OFT.,S 2 [] [] [] MARRIAGE 15. PLACE OF (County) (stateor Foreign Country) OETH.S Adams County. Pennsylvania MARRIAGE 17A. NUMBER OF CHIL* I1 17B. NUMBER OF DEPENDENT CHIdl 18. PLAINTIFF r~ HUSBAND WIFE OTHER (Specify) DREN THIS 2 DREN UNDER 18 2 [] [] MARRIAGE Pa 9. DATE (Month) (Day) oE 8/25/52 BIRTH 11. PLACE (State or Foreign Country) OF Pennsylvania BIRTH (Year) 14. OCCUPATION nurse 16. DATE OF (Month) (OaF) (Year) TR,S 6/10/77 MARRIAGE I19. DECREE GRANTED TO HUSBAND WIFE OTHER (Specify) 20. NUMBER OF HUSBAND WIFE SPLIT CUSTODY OTHER (Specify) I-2--1 F--I F--1 22. DATE OF DECREE (Month) (Day) (Year] 21. LEGAL GROUNDS FOR D,VO.CEO. ANNU'MENT 201(a) and/or 201(c) 23. DATE REPORT SENT (Month) (Day) (Year) TO VITAL RECORDS of 4. SIGNATURE OF TRANSCRIBING CLERK