HomeMy WebLinkAbout06-2937
vs.
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
: No. 010 -,;{937 CilJL'-r~
: CIVIL ACTION - LAW
: IN DIVORCE
ELAINE S. COX,
Plaintiff
ROBERT H. COX, JR.,
Defendant
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 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 at the Cameron County Courthouse, Emporium, Pennsylvania.
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 TIllS 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, P A 17013
(717) 249-3166
vs.
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
: No. 01... - :2.931 CwL '-r~
: CIVIL ACTION - LAW
: IN DIVORCE
ELAINE S. COX,
Plaintiff
ROBERT H. COX, JR,
Defendant
COMPLAINT IN DIVORCE UNDER SECTION 3301(d)
OF THE DIVORCE CODE
The Plaintiff, Elaine S. Cox, through her attorneys, The Law Offices of Patrick F. Lauer, Jr.,
L.L.C., makes the following Complaint in Divorce and, in support thereof, avers as follows:
1. The Plaintiff, Elaine S. Cox, is an adult individual who currently resides at 313
Shady Lane, Enola, Cumberland County, Pennsylvania 17025
2. The Defendant, Robert H. Cox, is an adult individual whose current address is
unknown.
3. The Plaintiff is a bona fide resident of the Commonwealth of Pennsylvania and has
been for at least six months in3mediately prior to the filing of this Complaint.
COUNT I - DIVORCE
4. Paragraphs one through three are incorporated herein by reference.
5. The Plaintiff and the Defendant were married on September 23, 1983,
6. There have been no prior actions of divorce or for annulment between the parties.
7. The marriage is irretrievably broken.
8. The Plaintiff has been advised that counseling is available and that the Plaintiff may
have the right to request that the court require the parties to participate in counseling.
9. This action is not collusive.
10. Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, the Plaintiff, Elaine S. Cox, respectfully requests this Honorable Court to
enter a decree of divorce in this matter.
Respectfully submitted,
Date: CfijUj'(
~~L-
Law Offices of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 200952 Tel. (717)763-1800
ELAINE S. COX,
Plaintiff
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: No.
ROBERT H. COx, JR.,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
VERIFICATION
I veritY that the statements made in this Complaint 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.
Date:~
Signature:_t O~~.~
Elaine S. Cox
- - ,- -
ELAINE S. COX,
Plaintiff
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No.
ROBERT H. COx, JR.,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
NOTICE TO THE DEFENDANT
IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT,
YOU MUST FILE A COUNTERAFFIDA VIT WITHIN TWENTY (20) DAYS AFTER THIS
AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED
AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE
1. The parties to this action separated in September, 2002, and have continued to live
separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if{ do not claim them before a divorce is granted.
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.
DATE: ~
fDo,\M\ ,~ Cr.!/-
Elaine S. Cox
ELAINE S. COX,
Plaintiff
vs.
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
: No. o~-;)..131 c!<I;1
ROBERT H. COX, JR.,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PRTTTTON TO SRRVR PTmSTT A NT TO SPRrJ AT. ORnER OF C:OTTRT
The Petitioner, Elaine S. Cox, through her attorneys, The Law Offices of Patrick F. Lauer,
Jr., respectfully avers the following in support of her Petition to Serve by Publication:
1. The Petitioner is Elaine S. Cox, Plaintiff in the above-captioned divorce action, and
an adult individual residing at 313 Shady Lane, Enola, Cumberland County, Pennsylvania, 17025.
2. The Respondent in this matter is Robert H. Cox, Jr., Defendant in the divorce
action, whose last known address was the marital residence, 313 Shady Lane, Enola, Cumberland
County, Pennsylvania, 17025.
3. The parties were married on September 23,1983.
4. The parties were separated in September, 2002,
5. The Petitioner has had no contact whatsoever with the Respondent for more than
two years.
6. A divorce complaint is being filed simultaneously with this Petition in the
Cumberland County Court of Common Pleas.
7. The whereabouts of the Respondent are currently unknown.
8. In the event Defendant is not found, the Petitioner has no wish to claim any rights
ancillary to her claim for divorce.
9. The Petitioner, through her attorneys, has attempted locate the Respondent pursuant
to the recommendations regarding Service Pursuant to Special Order of Court set forth in
Pennsylvania Rules of Court Rule 430, by employing U.S. Search.com, Inc. who provided a list of
past known addresses. See Exhibit "A", attached and incorporated herein by reference.
Contact was attempted, but unsuccessful, via first class mail with all of the addresses, save for the
marital residence, listed in the U.S. Search Advanced Background Report. See Exhibit "B",
attached and incorporated herein by reference.
10. Contact was attempted, but unsuccessful, at three additional addresses at which the
Petitioner believed the Respondent may have been residing. See Exhibit "C", attached and
incorporated herein by reference,
11. The Respondent is able to competently read and write in the English language to the
best knowledge, information, and belief of the Petitioner.
12. The Petitioner sets forth the following suggested advertisement for publication in
any newspaper of general circulation as may be ordered by the Court: See Exhibit "0" attached and
incorporated herein by reference.
13. The Petitioner knows of no other method of service of process which would have a
better chance of actual notification of the action.
WHEREFORE, the Petitioner, Elaine S. Cox, respectfully requests permission to serve the
Respondent, by advertising a notice of the action once in the in such newspaper of general
circulation as the court may direct; and, if the Defendant has not responded within twenty (20) days
of the date of advertisement, that proper service be deemed to have been made upon the
Respondent, and permitting the Petitioners to pursue the proceedings without further petition to this
Court regarding service of process.
Date:~
Respectfully submitted,
~
Shana M. Pugh, Esqui
Law Offices of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 170114706
ID# 200952 Tel. (717) 763-1800
ELAINE S. COX,
Plaintiff
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No.
ROBERT H. COX, JR.,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
VERIFICATION
I verify that the statements made in this Petition to Serve Pursuant to Special Order of Court
are true and correct. I understand that false statements herein are made subject to the penalties of
18 Pa.C.S. Section 4904, relating to unswom falsification to authorities.
('Co.~.iS.l nj
Elaine S. Cox
II
ELAINE S. COX,
Plaintiff
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No.
ROBERT H. COX, JR.,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
AFFTnA VTT
I have attempted, through my attorney, to contact Defendant by sending first class mail to
the addresses provide by U.S. Search. com as well as to other addresses at which I believed the
Defendant may have been residing.
The last known address of the Defendant is 313 Shady Lane, Enola, Pennsylvania, the
marital residence. The Defendant has not resided at that address since September, 2002. Both my
attorney and I have attempted telephone contact with the Defendant's family members in an attempt
to ascertain the Defendant's whereabouts, We were not able to locate the Defendant. In my last
phone conversation with the Defendant in October of 2003, he indicated that he was residing in
Florida although I have no first hand knowledge of this.
The Defendant and I have two children together, neither ofwhorn have had any contact with
their father since 2003. I have been trying to locate the Defendant since the beginning of February
2004 to collect child support arrearages. I have been unable to do so. I have no knowledge
whatsoever as to the current whereabouts of the Defendant, Robert H. Cox, Jr.
p p[).).~:s, r-Df.
Elaine S. Cox
~)(l~ bit k
Shelby Nelson
From:
Sent:
To:
Subject:
cservice@ussearch.com
Saturday, April 15, 20061:14 AM
SHELBYNIi:LSON@VERIZON.NET
Search Results - SSN Advanced Background Report
Order Id 74801484
As part of our US Search Customer Commitment we want you to be satisfied
with your results.
If you have any questions regarding these search results, please contact us
via e-mail by visiting the following URL:
http://ussearch.com/support.
Our Customer Service agents will answer your questions in (typically) under 24 hours.
Dear PATRICK F. LAUER, JR.:
Thank you for ordering US SEARCH's SSN Advanced Background Report.
Using the criteria we received, we searched our network of public record
databases to obtain your results.
Please read our Permissible Use and Disclaimer Notices located at the end of
this document.
US SEARCH also offers numerous other searches, including a Criminal Record
search and Business-Related services. For information on the variety of
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SSN Advanced Background Report Results
Subject Information:
Name: ROBERT HOWARD COX JR
Age: 46
Names Associated With Subject:
ROBERT H COX JR Age: 46
ROBERT H COX JR Age: 46
ROBERT H COX JR Age: 47
ROBERT H COX JR Age: 46
ROBERT H COX Age: 47
1
ROBERT H COX
ROBERT H COX
ROBERT H COX
ROBERT H COX JR
Age: 46
Age: 46
Age: 46
Comprehensive Report Summary:
Names Associated With Subject:
9 Found
Bankruptcies:
2 Found
Tax Liens and Judgments:
20 Found
Address (es) Found:
1 Verified and 16 Non-Verified Found,
Possible Properties Owned:
None Found
Possible Relatives:
1st Degree - 8 Found
2nd Degree - None Found
3rd Degree - None Found
Neighbors:
1st Neighborhood - 3 Found
2nd Neighborhood - None Found
3rd Neighborhood - 6 Found
4th Neighborhood - 6 Found
Bankruptcies:
Documents: View Real-Time
Date Filed: 08/10/1999
Disposition: Dismissed
Filing Status: INDIVIDUAL
Case Number: 9921278
Docket
Chapter: 7
Disposition Date: 10/15/1999
Court Location: MAINE - PORTLAND
Debtor Name: COX, ROBERT H
AKAs:
Debtor Address: PO BOX 246, PERU ME 04290-0246
Assets available for unsecured creditors: No
Debtor is self-represented: No
Liabilities: Assets: Exempt:
Attorney: PRO SE,
Trustee: WILLIAM HOWISON, 22 FREE ST, PORTLAND ME 04112
Judge Assigned:
Creditors Meeting Date:
Creditors Meeting Location:
Complaints Deadline:
Claims Deadline:
(207) 775-6371
Documents: View Real-Time
Date Filed: 02/22/1999
Disposition: Dismissed
Filing Status: INDIVIDUAL
Case Number: 9920241
Docket
Chapter: 7
Disposition Date: 05/07/1999
Court Location: MAINE - PORTLAND
Debtor Name: COX, ROBERT H
AKAs:
Debtor Address: 300 MINERAL SPRINGS RD, PERU ME 04290-3223
Assets available for unsecured creditors: No
Debtor is self-represented: Yes
Liabilities: Assets: Exempt:
Attorney: PRO SE,
Trustee: WILLIAM HOWISON, 22 FREE ST, PORTLAND ME 04112 (207) 775-6371
Judge Assigned:
Creditors Meeting Date: 03/30/1999
Creditors Meeting Location: MULTI PURPOSE ROOM, LEWISTON
Complaints Deadline:
2
Claims Deadline:
Tax Liens and Judgments:
Type: JUDGMENT
Court:
Case Number:
Amount: $1,531
Date Filed: 06/25/1992
Debtor: ROBERT COX JR
Debtor Address: MINERAL SPRING RD, WEST PERU ME 04290
Creditor: T AND R ASSOCIATES INC
Type: JUDGMENT
Court:
Case Number:
Amount: $942
Date Filed: OS/21/1992
Debtor: ROBERT H COX JR
Debtor Address: MINERAL SPRING RD, WEST PERU ME 04290
Creditor: APPLICATOR SALES AND SERVICE I
Type: JUDGMENT
Court:
Case Number:
Amount: $ 677
Date Filed: 06/04/1992
Debtor: ROBERT COX
Debtor Address: MINERAL SPRING RD, WEST PERU ME 04290
Creditor: GLEASON MARKETING SERVICES INC
Type: JUDGMENT
Court:
Case Number:
Amount: $789
Date Filed: 07/22/1998
Debtor: ROBERT COX
Debtor Address: PO BOX 246, PERU ME 04290-0246
editor: JOHN LOVELY
Type: JUDGMENT
Court:
Case Number:
Amount: $350
Date Filed: 08/10/1993
Debtor: ROBERT H COX
Debtor Address: 140 MAIN ST, MEXICO ME 04257-1413
Creditor: BEACON SALES CO
Type: JUDGMENT
Court:
Case Number:
Amount: $321
Date Filed: 08/10/1993
Debtor: ROBERT H COX
Debtor Address: 140 MAIN ST, MEXICO ME 04257-1413
Creditor: BEACON SALES CO
Type: JUDGMENT
Court:
Case Number:
Amount: $1,371
3
Date Filed: 06/04/1997
Debtor: ROBERT COX
Debtor Address: PO BOX 243, PERU ME 04290-0243
Creditor: TED BERRY CO INC
Type: JUDGMENT
Court:
Case Number:
Amount: $473
Date Filed: 06/05/1992
Debtor: ROBERT COX
Debtor Address: PO BOX 246, PERU ME 04290-0246
editor: FREUDENBERG SPUNWELS CO
Type: JUDGMENT
Court:
Case Number:
Amount: $614
Date Filed: 05/07/1993
Debtor: ROBERT COX
Debtor Address: 140 MAIN ST, MEXICO ME 04257-1413
Creditor: NASH ELEC CO
Type: JUDGMENT
Court:
Case Number:
Amount: $2,111
Date Filed: 01/06/1995
Debtor: ROBERT COX
Debtor Address: PO BOX '246, PERU ME 04290-0246
editor: PEERLESS INS CO
Type: JUDGMENT
Court:
Case Number:
Amount: $350
Date Filed: 08/10/1993
Debtor: ROBERT H COX
Debtor Address: 140 MAIN ST, MEXICO ME 04257~1413
Creditor: BEACON SALES CO
Type: JUDGMENT
Court:
Case Number:
Amount: $564
Date Filed: 06/06/1997
Debtor: ROBERT COX
Debtor Address: PO BOX 246, PERU ME 04290-0246
editor: CAREYS HTG
Type: JUDGMENT
Court:
Case Number:
Amount: $1,371
Date Filed: 10/24/1997
Debtor: ROBERT COX
Debtor Address: PO BOX 243, PERU ME 04290-0243
Creditor: TED BERRY CO
Type: JUDGMENT
Court:
Case Number:
Amount: $998
4
Date Filed: 04/04/1997
Debtor: ROBERT COX
Debtor Address: PO BOX 246, PERU ME 04290-0246
editor: COMM ENERGY
Type: JUDGMENT
Court:
Case Number:
Amount: $283
Date Filed: 10/02/1998
Debtor: ROBERT COX
Debtor Address: PO BOX 246, PERU ME 04290-0246
editor: COMMUNITY ENERGY CO
Type :\~ JUDGMENT
Court:
Case Number:
Amount: $789
Date Filed: 07/22/1998
Debtor: ROBERT COX
Debtor Address: PO BOX 246, PERU ME 04290-0246
editor: JOHN LOVELY
Type: JUDGMENT
Court:
Case Number:
Amount: $1,190
Date Filed: 07/14/1992
Debtor: ROBERT COX
Debtor Address: 140 MAIN ST, MEXICO ME 04257-1413
Creditor: WESTERN MAINE CELLULAR
Type: JUDGMENT
Court:
Case Number:
Amount: $442
Date Filed: 10/25/1996
Debtor: ROBERT H COX JR
Debtor Address: PO BOX 246, PERU ME 04290-0246
Creditor: GRAYS FORD
Type: JUDGMENT
Court:
Case Number:
Amount: $1,707
Date Filed: 12/12/1997
Debtor: ROBERT COX JR
Debtor Address: PO BOX 246, PERU ME 04290-0246
editor: FARMINGTON FARMERS UNION
Type: JUDGMENT
Court:
Case Number:
Amount: $2,750
Date Filed: 10/05/1998
Debtor: ROBERT H COX JR
Debtor Address: PO BOX 246, PERU ME 04290-0246
Creditor: EDWARD LAPOINTE
Address Summary:
313 W SHADY LN, ENOLA PA 17025-2245, CUMBERLAND COUNTY (Apr 2001 - Jun 2001)
PO BOX 246, PERU ME 04290-0246, OXFORD COUNTY (Aug 1995 - Oct 2004)
MINERAL SP~, PERU ME 04290, OXFORD COUNTY (Oct 2000)
5
300 MINERAL SPRINGS RD, PERU ME 04290-3223, OXFORD COUNTY (Aug 1992 - Oct 2000)
MINERAL SPRING RD, PERU ME 04290, OXFORD COUNTY (Dee 1980 - Dee 1999)
PO BOX 243, PERU ME 04290-0243, OXFORD COUNTY (Oct 1997)
140 MAIN ST, MEXICO ME 04257-1413, OXFORD COUNTY (Dee 1980 - Jan 1997)
RR 1 BOX 278, SHIPPENSBURG PA 17257, CUMBERLAND COUNTY (Apr 1986 -Jan 1995)
MINERAL SPRNGS RD, PERU ME 04290, OXFORD COUNTY (Sep 1992 -, Dee 1992)
MINERAL SPRINGS RD, PERU ME 04290, OXFORD COUNTY (Aug 1992)
52 BEAVER AVE, LYNNFIELD MA 01940-1710, ESSEX COUNTY (Feb 1984 - Dee 1991)
112R CHESTNUT ST, LYNNFIELD MA 01940-2405, ESSEX COUNTY (Oct 1989 - Dee 1990)
87 PLEASANT ST, MALDEN MA 02148-4907, MIDDLESEX COUNTY (Jan 1990)
112 CHESTNUT ST, LYNNFIELD MA 01940-2405, ESSEX COUNTY (Oct 1989)
RR 1 BOX 278A, SHIPPENSBURG PA 17257, CUMBERLAND COUNTY (Apr. ,1986)
122 MYRTLE ST, MANCHESTER NH , HILLS BOROUGH COUNTY (Apr 1984)
87 PLEASANT, BOSTON MA 00000 (Feb 1982)
Active Address (es) :
ROBERT COX JR - 313 W SHADY LN, ENOLA PA 17025-2245, CUMBERLAND COUNTY (Apr 2001 -
Jun 2001)
COUNTY
COX E (717) 728-9233
Property Ownership Information for this Address
Property:
Parcel Number - 13-1002-215
Book - 00031S
Page - 000577
Lot Number - 10
Name Owner 1 - KUO PIN-HSUN & SW-TSEN H
Address - 313 W SHADY LN, ENOLA PA 17025-2245, CUMBERLAND
6765, CUMBERLAND COUNTY
Owner's Address - 1041 BROOKWOOD DR, MECHANICSBURG PA 17055-
Land Usage - COMMERCIAL CONDOMINIUM
Total Value - $871,200
Land Value - $93,840
Improvement Value - $777,360
Land Size - 81,892
Sale Date - 02/12/1986
Sale Price - $740,000
Legal Description - LOTS 10-11 & UNNUMBERED LOT
Previous And Non-Verified Address (es) :
ROBERT HOWARD COX JR - PO BOX 246, PERU ME 04290-0246, OXFORD COUNTY (Aug 1995 -
Oct 2004)
ROBERT H COX JR - MINERAL SPG, PERU ME 04290, OXFORD COUNTY (Oct 2000)
ROBERT H COX JR - 300 MINERAL SPRINGS RD, PERU ME 04290-3223, OXFORD COUNTY (Aug
1992 - Oct 2000)
1999)
ROBERT H COX JR - MINERAL SPRING RD, PERU ME 04290, OXFORD COUNTY (Dee 1980 - Dee
ROBERT COX - PO BOX 243, PERU ME 04290-0243, OXFORD COUNTY (Oct 1997)
1997 )
ROBERT H COX JR - 140 MAIN ST, MEXICO ME 04257-1413, OXFORD COUNTY (Dee 1980 - Jan
MEXICO TOWN OF
(207) 364-3281
ROBERT H COX JR - RR 1 BOX 278, SHIPPENSBURG pA 17257, CUMBERLAND COUNTY (Apr 1986
- Jan 1995)
ROBERT COX - MINERAL SPRNGS RD, PERU ME 04290, OXFORD COUNTY (Sep 1992 - Dee 1992)
ROBERT COX - MINERAL SPRINGS RD, PERU ME 04290, OXFORD COUNTY (Aug 1992)
GREIG T (207) 562-4368
ROBERT H COX JR - 52 BEAVER AVE, LYNNFIELD MA 01940-1710, ESSEX COUNTY (Feb 1984 _
6
Dee 1991)
MCRAE CLIFFORD (781) 334-5616
Property Ownership. Information for this Address
Property:
Parcel Number - LYNF-000023-000000-002722
Book - 010539
Page - 000586
Name Owner 1
Name Owner 2
Address - 52
- CCM
- MCRAE CLIFFORD C
BEAVER AVE, LYNNFIELD
MA 01940-1710, ESSEX
COUNTY
Owner's Address - 52 BEAVER AVE, LYNNFIELD MA 01940-1710,
ESSEX COUNTY
Land Usage - SFR
Total Value - $436,800
Land Value - $267,500
Improvement Value - $169,300
Land Size - 14,898
Year Built - 1925
Sale Date - 08/21/1990
Sale Price - $212,000
ROBERT H COX JR - 112R CHESTNUT ST, LYNNFIELD MA 01940-2405, ESSEX COUNTY (Oct
1989 - Dee 1990)
ROBERT H COX - 87 PLEASANT ST, MALDEN MA 02148-4907, MIDDLESEX COUNTY (Jan 1990)
ROBERT H COX - 112 CHESTNUT ST, LYNNFIELD MA 01940-2405, ESSEX COUNTY (Oct 1989)
Current phones listed at this address:
ST. MARIA GORETTI'S RECTORY (781) 334-6443
ST MARIA GORETTI'S RECTORY (781) 334-2367
Property Ownership Information for this Address
~Property:
Parcel Number - LYNF-000028-000000-000263
Name Owner 1 - ROMAN CATHOLIC ARCHB
Address - 112 CHESTNUT ST R, LYNNFIELD MA 01940-2405" ESSEX
COUNTY
Owner's Address - 112 CHESTNUT ST, LYNNFIELD MA 01940-2405,
ESSEX COUNTY
Land Usage - RELIGIOUS
Total Value - $990,000
Land Value - $127,300
Improvement Value - $862,700
Land Size - 10,018
Year Built - 1955
Sale Price - $0
ROBERT H COX JR - RR 1 BOX 278A, SHIPPENSBURG PA 17257, CUMBERLAND COUNTY (Apr
1986)
ROBERT H COX - 122 MYRTLE ST, MANCHESTER NH
HILLS BOROUGH COUNTY (Apr 1984)
ROBERT H COX - 87 PLEASANT, BOSTON MA 00000 (Feb 1982)
Possible Properties Owned by Subject:
[None Found]
Possible Relatives:
ELAINE S COX Age: 51
Names Associated with Relative:
ELAINE S WALACH
Active Address (es) :
ELAINE S COX ,- 313 W SHADY LN APT I, ENOLA PA 17025-2260, CUMBERLAND COUNTY
7
(Dee 1999 - Sep 2004)
COX E
(717) 728-9233
Previous And Non-Verified Address (es) :
ELAINE S COX - 112R CHESTNUT ST, LYNNFIELD MA 01940-2405, ESSEX COUNTY (Jan
1989 - Oct 2005)
ELAINE S COX - PO BOX 246, PERU ME 04290-0246, OXFORD COUNTY (Feb ,1997 -
Jun 2001)
ELAINE S COX - RR 1 BOX 278A, SHIPPENSBURG PA 17257, CUMBERLAND COUNTY (Aug
1985 - Jan 1995)
ELAINE COX - 19 CHARLES ST, CONCORD NH 03301-4149, MERRIMACK COUNTY (May
1987 - Dee 1991)
ELAINE S WALACH - 67 HIGH ST, ANDOVER MA 01810-3527, ESSEX COUNTY (Apr 1985
- Dee 1991)
ELAINE S WALACH - 112 CHESTNUT ST, LYNN FIELD MA 01940-2405, ESSEX COUNTY
(Jan 1990)
ELAINE S COX - 122 MYRTLE ST, MANCHESTER NH 03104-6025, HILLSBOROUGH COUNTY
(Jan 1988 - Feb 1988)
ELAINE S COX - 52 BEAVER AVE, LYNNFIELD MA 01940-1710, ESSEX COUNTY (Mar
1985 - Apr 1986)
ELAINE COX
Active Address (es) :
ELAINE COX - 313 W SHADY LN, ENOLA PA 17025-2245, CUMBERLAND COUNTY (Aug
2002 - Jan 2003)
COX E
(717) 728-9233
ROBERT H COX SR Age: 68
Active Address (es) :
ROBERT H COX SR - 297 ERNEST RD, LANDISBURG PA 17040-8908, PERRY COUNTY
(Mar 1987 - Jan 2006)
COX ROBERT H (717) 789-9129
Previous And Non-Verified Address (es) :
ROBERT H COX SR - PO BOX 307, LANDISBURG PA 17040-0307, PERRY COUNTY (Jun
1993 - Jun 2001)
ROBERT H COX SR - RR 2 BOX 307,'LANDISBURG PA 17040-9802, PERRY COUNTY (Jun
1987 - oct 2000)
ROBERT H COX SR - 2 RD, LANDISBURG PA 17040, PERRY COUNTY (Sep 1992 - Jan
1999)
ROBERT H COX SR - RR 1 BOX 278A, SHIPPENSBURG PA 17257, CUMBERLAND COUNTY
(Nov 1979 - Oct 1992)
ROBERT H COX SR - 2 R D BOX 307, LANDISBURG PA 17040, PERRY COUNTY (Oct
1987)
ROBERT H COX SR - 2 R D BOX, LANDISBURG PA 17040, PERRY COUNTY (Oct 1987)
ELAINE COX
Previous And Non-Verified Address (es) :
ELAINE COX - 140 MAIN ST, MEXICO ME 04257-1413, OXFORD COUNTY (Nov 1991)
BARBARA A COX Age: 52
Active Address(es):
BARBARA A COX - 297 ERNEST RD, LANDISBURG PA 17040-8908, PERRY COUNTY (Mar
1987 - 2005)
COX ROBERT H
(717) 789-9129
Previous And Non-Verified Address (es) :
BARBARA A COX - PO BOX 307, LANDISBURG PA 17040-0307, PERRY COUNTY (Sep
1989 - Jun 2001)
BARBARA A COX - RR 2 BOX 307, LANDISBURG PA 17040-9802, PERRY COUNTY (Jan
1988 - Jun 2001)
BARBARA A COX - RR 1, SHIPPENSBURG PA 17257, CUMBERLAND COUNTY (Nov 1979)
ROBERT COX
Previous And Non-Verified Address (es) :
ROBERT COX - PO BOX 246, PERU ME 04290-0246, OXFORD COUNTY (Sep 2000)
8
ELIZABETH S COX
Active Address (es) :
ELIZABETH S COX - 313 W SHADY LN, ENOLA PA 17025-2245, CUMBERLAND COUNTY
(Dee 2005 ~ Mar 2006)
COX E (717) 728-9233
Previous And Non-Verified Address (es) :
ELIZABETH COX - 333 CANDY LN, ENOLA PA 17025, CUMBERLAND COUNTY (NClv 2005 -
Mar 2006)
THERESE PAONE COX Age: 50_f
Names Associated with Relative:
THERESE D PAONE
Active Address (es) :
THERESE PAONE COX - 42 CHESTNUT ST R, LYNNFIELD MA 01940-2532, ESSEX COUNTY
(Ju1 1991 - 2005)
COX T G & T P
(781) 334-5641
Previous And Non-Verified Address (es) :
THERESE P COX - 19 FORD ST, REVERE MA 02151-1502, SUFFOLK COUNTY (Apr 1992
- May 1997)
THERESE P COX - 112 CHESTNUT ST # R, LYNNFIELD MA 01940-2405, ESSEX COUNTY
(Mar 1985 - Jan 1997)
THERESE P COX - 73 SEWALL ST, REVERE MA 02151-3159, SUFFOLK COUNTY (Jan
1983 - Dee 1991)
THERESE D PAONE - 480 FOSTER RD, TEWKSBURY MA 01876-2933, MIDDLESEX COUNTY
(May 1986 - Dee 1991)
Neighbors:
Neighborhood:
313 W SHADY LN
COX R
APT H, ENOLA PA 17025-2260, CUMBERLAND COUNTY
(717) 728-9233
Address (es) :
308 W SHADY LN, ENOLA PA 17025-2239, CUMBERLAND COUNTY (Aug 1994 -
Jun 2001)
Residents:
FRANK B ZETTLEMOYER Age: 68
SKIP M ZETTLEMOYER
VIOLA M ZETTLEMOYER
ZETTLEMOYER SKIP (717) 732-1172
306 W SHADY LN # A, ENOLA PA 17025-2239, CUMBERLAND COUNTY (Dee 1999
2005)
Residents:
LESLIE M TAYLOR JR
RODGER N TAYLOR
ROGER TAYLOR
CHRISTI VOGELSONG JR
DONALD V VOGELSONG JR Age: 54
DONNA M VOGELSONG
Current phones listed at this address:
TAYLOR ROGER (717) 728-3594
VOGELSONG DONALD V JR (717) 728-7630
305 W SHADY LN, ENOLA FA 17025-2240, CUMBERLAND COUNTY
Residents:
ARLENE E GERLACH Age: 59
LEON D GERLACH
Current phones listed at this address:
GERLACH ARLENE (717) 732-5052
GERLACH ARLENE (717) 732-8612
Neighborhood:
9
2000)
300 MINERAL SPRINGS RD, PERU ME 04290-3223, OXFORD COUNTY (Aug 1992 - Oct
Neighborhood:
140 MAIN ST, MEXICO ME 04257-1413, OXFORD COUNTY
Current phones listed at this address:
562-9268
MEXICO TOWN OF (207) 364-3281
Address (es) :
137 MAIN ST, MEXICO ME 04257-1412, OXFORD COUNTY
Current phones listed at this address:
SUBWAY SANDWICHES & SALADS (207) 364-2336
VIEWERS CHOICE VIDEO (207) 364-3307
CURVES (207) 364-3333
134. MAIN ST, MEXICO ME 04257-1413, OXFORD COUNTY
Current phones listed at this address:
MEXICO WATER DISTRICT (207) 364-2061
MEXICO WATER DISTRICT (207) 364-7911
MEXICO TOWN OF (207) 364-7971
2006)
148 MAIN ST, MEXICO ME 04257-1413, OXFORD COUNTY (Apr 1995 - Feb
Residents:
M JUDKINS
MARTHA ALBERTA JUDKINS Age: 59
Current phones listed at this address: \ \ .
....MADDY.S PIZZA SHOP (207) 364-2051/ h..sn~ ~ /1M>-.;
JUDKINS ~ (207) 369-0862
131 MAIN ST, MEXICO ME 04257-1412, OXFORD COUNTY ~.
COHEN JERROLD (207)' 364-4611 / do M'.r ~ ~
2006)
157 MAIN ST, MEXICO ME 04257-1412, OXFORD COUNTY (Oct 2003 - Feb
Residen'ts' :
DONALD R OLEARY SR Age: 82
,JULIE A OLEARY
MARILYN K OLEARY
MARILYN R OLEARY Age: 78
O'LEARY DONALD (207) 364-3583
2006)
159 MAIN ST, MEXICO ME 04257-1412, OXFORD COUNTY (Aug 1994 - Jan
Residents:
BEAU P DECOURCY
PETER J DECOURCY
SANDRA R DECOURCY
DECOURCY PETER & SANDRA
Age: 23
Age: 52
(207) 364-2498
Neighborhood: ,
52 BEAVER AVE, LYNNFIELD MA 01940-1710, ESSEX COUNTY (Mar 1985)
Residents:
CLIFFORD C MCRAE Age: 58
KAREN M MCRAE
MCRAE CLIFFORD (781) 334-5616
Address (es) :
51 BEAVER AVE, LYNNFIELD MA 01940-1709, ESSEX COUNTY
Residents:
EVELYN R CARMODY Age: 80
J MICHAEL CARMODY Age: 49
JOS V CARMODY
CARMODY JOS V (781) 334-3405
10
47 BEAVER AVE, LYNNFIELD MA 01940-1709, ESSEX COUNTY
Residents:
BERNICE ELDRED SIMMONS JR
RICHARD D SIMMONS JR
SIMMONS RICHARD D (781) 334-7003
46 BEAVER AVE, LYNNFIELD MA 01940-1710, ESSEX COUNTY
Residents:
ANDREA M BRACONNIER Age: 39
MARK BRACONNIER
BRACONNIER MARK & ANDREA (781) 334-0079
61 BEAVER AVE, LYNNFIELD MA 01940-1709, ESSEX COUNTY (Jul 2000 - Jan
2006)
Residents:
ANDREW S COUKOS Age: 23
HARRY C COUKOS Age: 54
COUKOS HARRY (781) 334-6187
66 BEAVER AVE, LYNNFIELD MA 01940-1710, ESSEX COUNTY (Jan 1979 - Oct
2005)
Residents:
C M SELLERS
CAROLYN M SELLERS Age: 67
SELLERS C M (781) 334-4973
77 BEAVER AVE, LYNNFIELD MA 01940-1709, ESSEX COUNTY
'Residents:
EDW P ROY
EDWARD P ROY Age: 58
IRENE ROY
MARIE L ROY
ROY MARIE L (781) 334-0024
HOW TO USE YOUR SSN Advanced Background Report SEARCH RESULTS.
The following tips and suggestions are intended to help you ,interpret your
search results.
US SEARCH's SSN Advanced Background Report Search service
is designed to help you find particular information about someone. Based upon
the name, current and/or previous address, date of birth and/or approximate
year of birth that you provided, our Search Specialists matched your, search
criteria against our extensive database network.
WHY IS A PHONE NUMBER NOT IN MY SEARCH RESULTS?
It might be no number is registered to a particular address. If the phone
number is unlisted or unpublished, in accordance with the US Search Privacy
Policy, we will not publish the number.
WHAT TYPES OF INFORMATION CAN A SSN Advanced Background Report SEARCH PROVIDE?
Depending on availability, our search can provide you with some or all of the
following types of information:
1. Addresses Associated with Your Search (up to a 10-year history)
11
* Your subject might have lived or reported to have lived at a particular
address.
2. Listed Phone Numbers for Addresses Associated with Your Search
* There might be multiple phone lines at one address.
3. Texas (1968 through 1998) and Nevada (1985 through 1999) Marriage and
Divorce Records; California (1963 through 1985) Marriage Records
(Based on name only)
* Your subject's name was identical to a name on a marriage record,
and he/she is either currently:
legally married
married but separated
no longer married
a different person even though ~heir name matched the name on a
marriage record
4. Relatives Living at the Same Address
* Individuals with the same Last Name and Physical Address
5. Others Who Have Used the Same Address
They could be:
a) Roommates
b) Current & Previous Residents at the same address
c) Other Apartment/Condominium Residents (if applicable)
6. Neighbors (including Available Listed Phone Numbers)
7. Bankruptcies, Tax Liens and Civil Judgments (when and where actions were
filed, judgment amount - Liens & Judgments current availability limited to
31 states, see our web site for a list)
8. Property Ownership (purchase date/description - current availability limited
to 47 states, see our web site for a list)
9. Property Value (purchase price, current value - current availability limited
to 47 states, see our web site for a list)
10. US Coast Guard Documented Vessel
11. FAA Pilots Licenses & FAA Aircraft Registrations
12. DEA Controlled Substances Licenses
13. Local and National Media Web-Based Search on Your Subject, over 675 sources,
including:
Major U.S. Newspapers
Major Magazines and Trade Publications
Web Sites and News Wire
14. Onsite Civil Records Associated with Your Search Subject (where available
for counties included in your order) :
Court, County & State
Names of Plaintiff & Defendant
Case Number
Cause of Action
Status Date & Type
Amount
15. National Death Index (Name, date of birth, date deceased)
NEED HELP?
If you have a question about your search results based on the search criteria that you
provided,
contact our Customer Service Center bye-mail by using the form on the following URL
12
http://ussearch.com/support.
Our Customer Service Agents will answer your question in (typically) under 24 hours.
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For information about new services, please visit www.ussearch.com. You can
order services directly from our website. through our 'secured Internet server.
If you pre,fer to' order services by phone, _ please call our Sales Department
toll-free at (800) 987-7327. (Additional charges apply to all
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PERMISSIBLE USE NOTICE
US SEARCH has provided the following information to you pursuant to our Consumer
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As an authorized client and user of services by US SEARCH, you agree that you
intend to use any and all information provided to you by US SEARCH and its
employees ONLY for a use which will clearly cause no emotional or physical
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of the 'FCRA, and similar state statutes.
DISCLAIMER NOTICE
US SEARCH does not warrant the accuracy, timeliness or completeness of any o~
the data available through telephonesal,es or. sales made over the Internet via
US SEARCH's web,site. Any information purchased from US SEARCH may not be used
for purposes such as deciding whether to hire an individual for employment or
for determining an individual's eligibility. to receive insurance. To the
fullest extent permitted by law, the information is provided AS IS, WITHOUT
WARRANTY OF ANY KIND, EXPRESS OR IMPLIED, INCLUDING BUT NOT LIMITED TO FITNESS
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NON-INFRINGEMENT.
US SEARCH.com Inc., 600 Corporate Pointe, Suite 220, Culver City, CA 90230
Fax: 310-823-5726, E-Mail: cservice@ussearch.com
13
Shelby Nelson
From:
Sent:
To:
Subject:
cservice@ussearch.com
Friday, April 14, 20069:38 AM
SHELBYNELSON@VERIZON.NET
Search Results - SSN Advanced Background Report
Order Id 74801484
Dear PATRICK F. LAUER, JR.:
We are unable to complete your SSN Advanced Background Report
search with the information that you have provided. Please reply to
this message with the information requested below. We will proceed with
'your search when we receive the additional information requested. Simply
reply to this message to provide your information. If you have any
questions, please contact our Customer Service Center by visiting the following
URL:http://ussearch.com/support, or bye-mail: cservice@ussearch.com.
ADDITIONAL INFORMATION REQUESTED (any information in addition to this
will further help us refine your search)
Based on the search criteria you provided, we are unable tp complete your search. In
order to get you the results you desire, please provide as much of the fallowing as you
can in a reply to this e-mail:
1. Exact full name and description of whether it is a current name 'or a former name.
2. Middle name or Middle Initial
3. As much information as you can provide about the persons Exact Date of Birth.
4. As much information as you can provide about the persons last known address.
5. Confirm the SSN provided
6. Any additional information you feel would be helpful in your search.
It is our desire to complete your search to your satisfaction t please help us do that by
giving us as much information as you can.
We at USSearch.com are happy to be of service to you. Thank you for
trusting USSearch.com with all your searching needs!
NEED HELP?
If you have a question about your search results based on the search criteria that you
provided,
contact our Customer Service Center bye-mail by using the form on the following URL
http://ussearch.com/support.
Our Customer Service Agents will answer your question in (typically) under 24 hours.
WHAT'S NEW AT US SEARCH?
1
For information about new services, please visit www.ussearch.com. You
can order services directly from our website through our secured Internet
server. If you prefer to order services by phone, please call our Sales
Department toll-free at (800) 987-7327. (Additional charges apply to all
operator-assisted phone orders.)
US SEARCH.com Inc., 600 Corporate Pointe, Suite 220, Culver City, CA 90230
Fax: 310-823-5726, E-Mail: cservice@ussearch.com
2
Shelby Nelson
From:
Sent:
To:
Subject:
Customer Service [cservice@ussearch.com]
Saturday, April 15, 2006 1 :20 AM
Shelby Nelson
Re: RE: Search Results - SSN Advanced Background Report (KMM3406851V77091 LOKM)
Dear Shelby Nelson,
Thank you for your e-mail; we appreciate your inquiry and value your
concerns.
We have submitted your additional information for Robert Howard Cox to
our Search Department for completion. Please be assured that US Search
is working hard to fulfill your order and it will be completed within
approximately 24-48 hours. Once finished, the results will be sent to
you via email.
Should you have any further questions, please contact our customer
service center via e-mail (simply reply to this message) .
Sincerely I
Simone L.
Customer Service
US Search
A First Advantage Company
"The Strength behind your Decisions"
http://www.ussearch.com
Original Message Follows:
Please search for the following:
Robert Howard Cox, Jr. may have an alias of Robert Howard Cox not using Jr.
Date of Birth: July 23, 1959
SSN: 021-50-9790
Married Elaine Susan (Carter maiden name) Cox on 9/23/83
-----Original Message-----
From: cservice@ussearch.com [mailto:cservice@ussearch.com]
Sent: Friday, April 14, 2006 9:38 AM
To: SHELBYNELSON@VERIZON.NET
Subject: Search Results - SSN Advanced Background Report
1
Order Id 74801484
Dear PATRICK F. LAUER, JR.:
We are unable to complete your SSN Advanced Background Report
search with.the information that you have provided. Please reply to'
this message with the information requested below. We will proceed with
your search when we receive the additional information requested. Simply
reply to this message to provide your information. If you have any
questions, please contact our Customer Service Center by visiting the
following
URL:http://ussearch.com/support, or bye-mail: cservice@ussearch.com.
ADDITIONAL INFORMATION REQUESTED (any information in addition to this
will further help us refine your search)
Based on the search criteria you provided, we are unable to complete your
search. In order to get you the results you desire, please provide as much
of the following as you can in a reply to this e-mail:
1. Exact full name and description of whether it is a current name or a
former name.
2. Middle name or Middle Initial
3. As much information as you can provide about the persons Exact Date of
Birth.
4. As much information as you can provide about the persons last known
address.
5. Confirm the SSN provided
6. Any additional information you feel would be helpful in your search.
It is our desire to .complete your search to you~ satisfaction I please help
us do that by giving us as much information as you can.
We at USSearch.com are happy to be of service to you. Thank you for
trusting USSearch.com with all your searching needs!
NEED HELP?
If you have a question about your search results based on the search
criteria that you provided,
contact our Customer Service Center bye-mail by using the form on the
following URL http://ussearch.com/support.
Our Customer Service Agents will answer your question in (typically) under
24 hours.
WHAT'S NEW AT US SEARCH?
For information about new services, please visit www.ussearch.com. You
can order services directly from our website through our secured Internet
server. If you prefer to order services by phone, please call our Sales
Department toll-free at (800) 987-7327. (Additional charges apply to all
operator-assisted phone orders.)
US SEARCH.com Inc., 600 Corporate Pointe, Suite 220, Culver City, CA 90230
Fax: 310-823-5726, E-Mail: cservice@ussearch.com
2
Page 1 of 1
Shelby Nelson
From: US Search [confirmation@ussearch.com]
Sent: Friday, April 14, 2006 9:26 AM
To: shelbynelson@verizon.net
Subject: Order Confirmation
Dear Patrick F. Lauer, Jr.,
Thank you for your order with US SEARCH. Your order was received on 04/14/200606:26:28 AM PDT. Your
order summary follows:
You have chosen the following item(s):
Product/Service Ordered: SSN Advanced Background Report
Delivery Method: E-mail
Processing Time: 24-hour
Click here to view vour order status.
For future reference, please print this page or record the following order confirmation and tracking numbers:
Order Confirmation #: 74801484 I Order Tracking #: 011 G36X8
In appreciation of your order, US SEARCH would like to provide you with
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-------------------------------------------------------------------------------------------------------
4/14/2006
-----
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EXHIBIT 0
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ELAINE S. COx,
Plaintiff
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No.
ROBERT H. COX, JR.,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
NOTICE: To Robert H. Cox, Jr.. You have been sued for divorce by the Plaintiff, Elaine S. Cox,
on the grounds of irretrievable breakdown of the marriage. If you wish to defend, you must enter a
written appearance personally or by attomey and file your defenses or objections in writing with the
Court. You are warned that if you fail to do so the case may proceed without you and a judgment
may be entered against you without further notice for the relief requested by the plaintiff. You may
lose money or property or other rights important to you.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S
FEES, OR EXPENSES BEFORE A DIVORCE IS GRANTED, YOU MAY LOSE THE RIGHT
TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS NOTICE 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, PA 17013
(717) 249-3166
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RECEIVED MAY?' 3 ..,,~~
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ELAINE S. COX,
Plaintiff
: IN THE COURT OF COMMON PLEAS
.CUMBERLAND COUNTY, PENNSYLVANIA
: No. 01.. ~937 CwL"t-~
: CIVIL ACTION - LA W
: IN DIVORCE
vs.
ROBERT H. COX, JR.,
Defendant
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 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 at the Cameron County Courthouse, Emporium, Pennsylvania.
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 TIllS 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, P A 17013
(717) 249-3166
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3:JEjO-031\:l
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ELAINE S. COX,
Plaintiff
vs.
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
: No. 01- - :2.131 Cl.>L 't~
: CIVIL ACTION - LA W
: IN DIVORCE
ROBERT H. COX, JR.,
Defendant
COMPLAINT IN DIVORCE UNDER SECTION 3301(d)
OF THE DIVORCE CODE
The Plaintiff, Elaine S. Cox, through her attorneys, The Law Offices of Patrick F. Lauer, Jr.,
L.L.C., makes the following Complaint in Divorce and, in support thereof, avers as follows:
1. The Plaintiff, Elaine S. Cox, is an adult individual who currently resides at 313
Shady Lane, Enola, Cumberland County, Pennsylvania 17025
2. The Defendant, Robert H. Cox, is an adult individual whose current address is
unknown.
3. The Plaintiff is a bona fide resident of the Commonwealth of Pennsylvania and has
been for at least six months immediately prior to the filing of this Complaint.
COUNT I - DIVORCE
4. Paragraphs one through three are incorporated herein by reference.
5. The Plaintiff and the Defendant were married on September 23, 1983.
6. There have been no prior actions of divorce or for annulment between the parties.
7. The marriage is irretrievably broken.
8. The Plaintiff has been advised that counseling is available and that the Plaintiff may
have the right to request that the court require the parties to participate in counseling.
9. This action is not collusive.
10. Plaintiff requests the court to enter a decree of divorce.
. .
WHEREFORE, the Plaintiff, Elaine S. Cox, respectfully requests this Honorable Court to
enter a decree of divorce in this matter.
Respectfully submitted,
Date: C1i1lar
QJ~~ /
Shana M. Pugh, Esqui ------
Law Offices of Patrick F. Lauer, Jr.
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 200952 Tel. (717) 763-1800
II
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ELAINE S. COX,
Plaintiff
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No.
ROBERT H. COX, JR.,
Defendant
: CIVIL ACTION - LA W
: IN DIVORCE
VERIFICATION
I verify that the statements made in this Complaint 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.
Date:~
Signature: r ~.l:S'~
Elaine S. Cox
ELAINE S. COX,
Plaintiff
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No.
ROBERT H. COX, JR.,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
NOTICE TO THE DEFENDANT
IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT,
YOU MUST FILE A COUNTERAFFIDA VIT WITHIN TWENTY (20) DA YS AFTER THIS
AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED
AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE
1. The parties to this action separated in September, 2002, and have continued to live
separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. 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.
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.
DATE: ~
CDo.'-M\ ,~. ~!Y
Elaine S. Cox
'I
ELAINE S. COX,
Plaintiff
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
; No. 01.0 - ltj ~ 7 L~; '-'il
vs.
ROBERT H. COX, JR.,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
ORDRR
AND NOW, this .I'" day of fV)""1
2006, it is hereby Ordered and Decreed that the
Petitioner, Elaine S. Cox, is permitted to attempt service upon the Respondent, Robert H. Cox, Jr.,
in the above-captioned divorce action by advertising a notice of the action once in the
fJafy10 r
Newspaper, the newspaper of general circulation in the area in which the
Defendant may be residing. If the Defendant has not responded within twenty (20) days of he date
of advertisement, proper service will be deemed to have been made upon the Defendant, and the
Petitioner may pursue the proceedings without further petition to this Court regarding service of
process.
BYTHECOU~l
T.
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ELAINE S. COX,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 06 - 2937 CIVIL TERM
ROBERT H. COX, JR.,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVTT OF SF,RVTCF
AND NOW, this 25th day of July, 2006, I, Shana M. Pugh, Esquire, hereby state that by
Order of Court dated May 26, 2006, I attempted to serve the Defendant by publication in the Patriot
Newspaper. Proof of Notice of Publication is hereby attached.
Respectfully submitted,
I>ate:(ZJ,t~5'L:,~
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;:,nana M. Pugh, Esqui
Law Offices of Patrick F. Lauer, Jr., LLC
2108 Market Street, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 200952 Tel. (717) 763-1800
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THE PATRIOT NEWS
THE SUNDAY PATRIOT NEWS
Proof of Publication
Under Act No, 587, Approved May 16, 1929
Commonwealth of Pennsylvania, County of Dauphin} ss
Joseph A. Dennison, being duly sworn according to law, deposes and says:
1Mt he is the Assistant Controller of The Patriot News Co" a corporation organized and existing under the
laws of the Commonwealth of Pennsylvania, with its principal office and place of business at 812 to 818 Market
Street, in the City of Harrisburg, County of Dauphin, State of Pennsylvania, owner and publisher of The Patriot-
News and The Sunday Patriot-News newsp~pers of general circulation, printed and published at 812 to 818 Market
Street, in the City, County and State aforesaid; that The Patriot-News and The Sunday Patriot-News were
established March 4th, 1854, and September 18th, 1949, respectively, and all have been continuously published ever
since;
That the printed notice or publication which is securely attached hereto is exactly as printed and published
in their regular daily and/or Sunday! Metro editions which appeared in the 7th day(s) of June 2006. That neither he
nor said Company is interested in the subject matter of said printed notice or advertising, and that all of the
allegations oflhis statement as to the time, place and character of publication are true; and
That he has personal knowledge of the facts aforesaid and is duly authorized and empowered to verify this
statement on behalf of The Patriot-News Co, aforesaid by virtue and pursuant to a resolution unanimously passed
and adopted severally by the stockholders and board of directors of the said Company and subsequently duly
recorded in the office for the Recording of Deeds in and for said County of Dauphin in Miscellaneous Book "MOO,
Volume 14, Page 317,
PUBLICATION
COPY
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s;;;;;;;;;;;;;.Q~~;;;:.
?5f/:'':J, Notarial Seal .
Teny L Russell, Notary Public
City Of Harrisburg, Dauphin ounty
Commlss Expires J ,20tO
~ anla 66 ' nof Nolarie.
NOT PUBLIC
THE LAW OFFICES OFPATRICKF, LAUER, JR" LLC
2108 MARKET STREET, AZTEC BUILDING
CAMP HILL, PA, 17011
~O.t patriot-Ntws
Now you know
Order Confirmation
Customer
THE LAW OFFICES OF PATRICK F, LAUER,
Orderer Account Number
116076
Paver
Paver Account Number
118078
THE LAW OFFICES OF PATRICK F, LAUER, JR, LlC
2108 MARKET STREET,AZTEC BUILDING
Camp Hill PA 17011 USA
Ad Order Number 0001517807
Sales Reo. rhollon
Order Taker rho lIon
Order Source Fax
Soecial PricinQ None
PO Number DIVORCE BY ELAIN S, C
Ordered Bv SHANA PUGH
Customer Fax
Customer EMail
Customer Phone 717-763-1800
Paver Phone 717-763-1600
Tear Sheets
o
Proofs
o
Affidavits
1
Blind Box
Promo Tvoe
Invoice Text
Materials
Total Ad Cost
$191,33
Pavment Amount
$0,00
$191,33
Pavment Method
Amount Due
Ad Number Ad Tvoe
0001517807-0' Legal Liners
Ad Size
: 1,0 X 43 Li
Color
<NONE>
Production Method Production Notes
Ad Booker
Run Dates
Product Information
Classification # Inserts
PNCO: :Full Run
812-Miscellaneous Legal Notice~ 1
617/2006
Run Schedule Invoice Text
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No
6/7/20068:55:15AM
1
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ELAINE S. COX,
Plaintiff
RECEIVED MAY 23 20r
: IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No.
i,
ROBERTJI.COX,JR., ,
.' Defendant
: CNIL ACTION - LAW
: IN DNORCE
OROF,R
AND NOW, this jJj}day of~ 2006, it is hereby Ordered and Decreed that the
Petitioner, Elaine S. Cox, is permitted to lttetPt service upon the Respondent, Robert H. Cox, Jr.,
above-captioned divorce action by advertising a notice of the action once in the
Newspaper, the newspaper of general circulation in the area in which the
Defendant may be residing. If the Defendant has not responded within twenty (20) days of he date
Qf advertisement~ proper service will be deem.ed to have been made upon the Defendant, and the
Petitioner may pursue the proceedings without further' petition to this Court regarding service of
process.
TRUE COpy FROM RECORD
III T imony whereof, I hE~'e unto szt my hand
and ~ we!!'SL!l}t #f~sle, Pa.
lb" "mJS'.dj;~If!1!(_" ""
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ELAINE S. COX,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 06 - 2937 CIVIL TERM
ROBERT H. COX, JR.,
Defendant
: CIVIL ACTION - LAW
: IN DIVORCE
PRAFCTPF TO TRANSMIT RF,('ORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry
of a divorce decree:
1. Ground for divorce: irretrievable breakdown under S 3J01(c) S 3301(d)(1) of the
Divorce Code. (Strike out inapplicable section)
2, Date and Manner of service of the Complaint: Service by publication in the
Patriot Newspaper on June 7, 2006. See attached Proof of Publication.
3. (Complete either paragraph (a) or (b))
(a) Date of execution of the affidavit of consent required by S 3301(c) of
the Divorce Code: by the Plaintiff
by the Defendant
(b) Date of execution of the affidavil required by S 3301(d) of the
Divorce Code: M~y 1 R, 700h ;
Date of filing of the Plaintiffs affidavit upon the respondent:..May
77, 700h;
Date of service of the Plaintiffs affidavit upon the respondent: June
7, )OOh hy pllhli,,~tion in the PMriot Newsp~per ,
4. Related claims pending: None No cl~ims ra;",,]
5. (Complete either paragraph (a) or (b))
(a) Date and manner ofservic.e ofthe Notice ofIntention to File Praecipe to
Transmit Record, a copy of which is attached, Pnrsmnt to RlIle
19)0 4)(e)(?) the Noti"e is not re<:JllirecJ prior to entry of a divOT"e decree
(b) Date Plaintiffs Waiver of Notice in S 3301(c) Divorce was filed with
the prothonotary:
Date Defendant's Waiver of Notice in S 3301(c) Divorce was filed
with the prothonotary:
Respectfully submitted,
1\"
Date: (J( ;;--:. (([
Shana M. Pugh, Esqu'
Law Offices of Patrick F. Lauer, Jr., LLC
2108 Market Slreet, Aztec Building
Camp Hill, Pennsylvania 17011-4706
ID# 200952 Tel. (717) 763-1800
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
ELAJ:IIE S. COX,
Plaintiff
VERSUS
RQRRIIIfI B~ l"nY, JR.,
Defen~.nt
AND NOW,
DECREED THAT Elaine S. COx
AND ao-rt B. COx. Jr.
PENNA.
No. 06 - 2937 CIVIL ftJUI
DECREE IN
DIVORCE
~... r ~.!J' , YO f- ,IT IS ORDERED AND
, PLAINTIFF,
, 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;
NDIi€.
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