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HomeMy WebLinkAbout01-4614LAW OFFICES SNELBAKER BRENNEMAN & SPARE MICHAEL L. COYLE, AUDRA L. COYLE, Plaintiff Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ot~6lff CIVILTERM CIVIL ACTION - LAW 1N 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 divorce is indignities or irretrievable breakdown of the marriage, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. 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 WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 SNELBAKER, BRENNEMAN & SPARE, P.C. By: Attorneys for Plaintiff LAW OFFICES MICHAEL L. COYLE, Plaintiff V. AUDRA L. COYLE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. o t- '4 t. ~ ¥ CIVIL TERM CWIL ACTION - LAW IN DIVORCE COMPLAINT COUNT I - DIVORCE 1. Plaintiff MICHAEL L. COYLE is an adult individual residing at 391 Crossroad School Road, Newville, Cumberland County, Pennsylvania. 2. Defendant AUDRA L. COYLE is an adult individual residing at 391 Crossroad School Road, Cumberland County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiffand Defendant were lawfully joined in marriage on May 4, 1996 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the ~arties hereto in this or any other jurisdiction since the date of the marriage averred in 'aragraph 4, above. SNELBAKER BRENNEMAN SPARE 6. Neither party is a member of the armed forces of the United States of America. 7. The Plaintiff avers as the grounds upon which this action is based is that the marriage between the parties hereto is irretrievably broken. 8. The 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. 9. The Plaintiff requests this Court to enter a decree of divome. COUNT II - EQUITABLE DIVISION OF PROPERTY 10. The Plaintiff and Defendant have legally and beneficially acquired property and debt during their marriage from May 4, 1996. 11. The Plaintiff and Defendant have not agreed as to any equitable distribution of their property and debts. 12. The Plaintiff requests this Court to equitably divide all marital property and debts pursuant to Section 3502 of the Pennsylvania Divorce Code. WHEREFORE, the Plaintiffrequests this Court to: (a)enter a decree of divorce, divorcing the Plaintiff from the bonds of matrimony; (b) order equitable distribution of marital property; and -2- (c) order such other relief as this Court deems just and reasonable. LAW OFFICES SNELBAkEr. B~ENNEMAN & SPARE Date: August 2, 2001 SNELBAK. ER, BRENNEMAN & SPARE, P.C. Keith O. Brermeman, Esquire 44 West Main Street Mechanicsburg, PA 17055-0318 Telephone: 717-697-8528 Attorneys for Plaintiff -3- LAW OFFICES SNEIBakER. BRENNEMAN & SPARe VERIFICATION I verify that the statements made in the foregoing Complaint are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4909 relating to unsworn falsification to authorities. ? /M~chael L. Coyle Date: August 2, 2001 LAW OFFICES SNELBAKeR, BRENNEMaN & SPARE MICHAEL L. COYLE, AUDRA L. COYLE, Plaintiff Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT MICHAEL L. COYLE, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do NOT request that the court require my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. yle Date: August 2, 200121 LAW OFFICE OF SUSAN KAY CANDIELLO, B.S.N., M.S.N., J.D. 5021 EASY TRINDLE ROAD, SUITE 100, MECHANICSBURO, PA 17050 MICHAEL L. COYLE, PLAINTIFF VS. AUDRA L. COYLE, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : : NO. 01-4614 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE pRAECIPE FOR ENTRY OF APPEARANCE Please enter my appearance on behalf of the Defendant, Audra L. Coyle. Dated: August [~ ,2001 Respectfully submitted, LAW FIRM OF SUSAN KAY CANDIELLO, P.C. Susan Kay Ca~ I~"'l~squire PA I.D. # 649~8 5021 East Trindh ~.~d Suite 100 Mechauicsburg PA 17050 (717) 796-1930