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IN THE COURT OF COMMON
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OF CUMBERLAND COUNTY
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KIM RENEE COX
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GREGORY ALAN COX
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Defendant
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DECREE IN
DIVORCE
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AND NOW, ........... .f~.... .~?..... 19. .~~-:-.. it is ordered and
decreed that... .. .,. . ... . ., .~~~. .~~~~~. .~~~.. . . . . ., . .,. ..,.. ., plaintiff.
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are divorced from the bonds of matrimony.
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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;
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hereto and ~s hereby incorporated into this Decree
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KIM RENEE COX, . IN THE COURT OF COMMON PLEAS OF
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Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
:
vs. NO. 1257 CIVIL 1994
GREGORY ALAN COX, .
.
Defendant . IN DIVORCE
.
THE MASTER: Today is Thursday, June 8, 1995.
Present for a Master's hearing scheduled this date is the
Plaintiff, Kim Renee Cox and her counsel Samuel W. Milkes and
Gregory Alan Cox. Mr. Cox is not represented by counsel and
apparently, after discussions between the parties and Mr.
Milkes, the economic claims and the divorce issue have been
resolved and we are going to place an agreement on the record in
the presence of the parties.
A divorce complaint was filed on March 15, 1994,
raising grounds for divorce of irretrievable breakdown of the
marriage and the economic claims of equitable distribution,
alimony, and counsel fees and expenses.
Mr. Milkes has
prepared affidavits of consent which will be signed and dated by
the parties and filed with the Prothonotary this date. The
divorce will then proceed under section 3301(c) of the Domestic
Relations Code.
Mrs. Cox currently is residing at 416 Bloserville
Road, Newville, Pennsylvania. Mr. Cox has indicated in
discussions with the Master that he is living with various
friends but does not have the financial wherewithal to establish
, .
a permanent residence at the present time.
However, Mr. Cox's
mailing address is the address of his parents at 441 North
college street, Carlisle, Pennsylvania.
The parties were married on April 21, 1989, and
separated December 23, 1993. The parties are the natural
parents of two children, Matthew, born August 7, 1990, and
Kayleigh Beth, born June 26, 1992. Mr. Cox is aware that the
Divorce Master does not deal with custody and support issues and
any matters relating to custody and support will be handled in a
separate proceeding either through the Domestic Relations Office
or the custody conciliators of Cumberland county.
Mr. Milkes.
MR. MILKES: with regard to equitable distribution
of the property, the parties have agreed to the following terms.
1. Kim Cox will assign title to the Windsor mobile home,
Vehicle Identification No. 6312251 to Gregory Cox and
present that title to him at the time he retrieves this
mobile home. This mobile home will become solely his
possession. Mr. Cox is to retrieve the mobile home
within two months of today's date at a time agreed upon
by his contacting Samuel Milkes, Attorney for Kim Cox.
If he does not retrieve the mobile home within two months
of today's date Kim Cox is at liberty to dispose of that
mobile home in any manner she sees fit.
2. Kim Cox is also to convey to Mr. Cox the title to the
1975 Chevrolet Blazer. This conveyance will occur as
quickly as possible although the parties do need to
either locate the title or to obtain a duplicate title to
that vehicle,
3. Gregory Cox will also be allowed to retrieve and will be
granted full ownership of various tools currently located
at Kim Cox's residence. These include a variety of
screwdrivers, wrenches, vise grips, as the parties have
previously discussed, They also include bolt cutters.
In addition, Mr. Cox will retrieve and maintain ownership
of his mother's crock pot, various swords, a leather
liner insert, a jewelry case with jewelry, various
Harley Davidson signs, and a 1978 Ford Van, all of which
are currently located Kim Cox's resience. Kim Cox will
cooperate in any fashion necessary with regard to
transfer of title of that vehicle. These items, again,
are to be retrieved by Mr. Cox making arrangements
through Kim Cox's attorney for an agreeable time to
retrieve the possession.
4. The remainder of the possessions whether considered
marital or nonmarital property will remain with the
respective party who is currently in possession of
those items. Those specifically to be retained by Kim
Cox are to include the king size water bed, the slate top
pool table, the washer and dryer, the camcorder, in
addition to other miscellaneous items of household and
personal property currently located at the double-wide
and other mobile homes on the property, and to include
the 1968 Honda motorcycle, the dining room set, and
specifically Mr. Cox will, on today's date, sign over
title to the 1986 Chevrolet S10 pickup truck which is
currently titled in the name of Greg A. and Kim R. Cox
solely into the name of Kim R. Cox. The same provision
with respect to the Pontiac mobile home date 1978
currently in the name of William L. Danner, Sr. but
having been assigned to Greg A. cox, and to include
conveyance of the deed on the property located at 416
Bloserville Road, Newville, Pennsylvania, currently
titled in the name of Gregory Allan Cox and Kim Renee Cox
as husband and wife.
5. Each party is to be responsible for all debts incurred
in their own name since the date of separation and each
party is to maintain payments on any debts currently
solely in their own name regardless of the date the debts
were incurred.
With reference to the PNC Bank repossession of the Ford
Bronco, Mr. Cox is to be responsible for any further
payments to be made on this repossessed vehicle.
6. Gregory Cox, to the extent this has not been completed
and accomplished, will resolve any outstanding
fines or costs connected with the 1982 Ford Bronco.
7. To the extent that any conveyance of title or other
formal conveyances need to occur after today's date in
order to effectuate this agreement, each of the parties
agrees to sign such documents as soon as they are made
available.
8. In consideration of the agreement Kim Renee Cox does
formally waive any claim to alimony, counsel fees, or
costs.
9. Except as herein otherwise provided, each party may
dispose of his or her property in any way and each
party hereby waives and relinquishes any and all rights
he or she may now have or hereafter acquire under the
present or future laws of any jurisdiction to share in
the property or the estate of the other as a result of
the marital relationship including without limitation,
dower, curtesy, statutory allowance, widow's allowance,
right of intestacy, right to take against the will
of the other, and right to act as administrator or
executor in the other's estate. Each will at the request
of the other execute, acknowledge, and deliver any and
all instruments which may be necessary or advisable to
carry into effect this mutual waiver and relinquishment
of all such interests, rights, and claims.
THE MASTER: Mr. Cox, have you been present during
the statement of the agreement on the record?
MR. COX: Yes.
THE MASTER: And do you understand the agreement
that's been placed on the record?
MR. COX: I think so.
THE MASTER: Are you willing to resolve the divorce
and economic issues in accordance with the agreement that has
been stated on the record?
MR. COX: Yes.
THE MASTER: Mrs. Cox, have you been present during
the statement of the agreement on the record?
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MRS. COX: Yes.
THE MASTER: And do you understand the agreement as
stated on the record?
MRS. COX: Yes.
THE MASTER: And are you willing to settle all
outstanding issues with regard to the divorce and economic
claims in accordance with that agreement?
MRS. COX: Yes.
I acknowledge that I have read the above
stipulation and agreement, that I understand the terms of
settlement as set forth herein, and that by signing below I
intend to bind myself to the settlement as a contract obligating
myself to the terms of settlement and subjecting myself to the
methods and procedures of enforcement which may be imposed by
law and in particular Section 3105 of the Domestic Relations
Code.
WITNESS:
DATE:
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Samuel W. MIkes
Attorney for Plaintiff
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KIM RENEE COX,
Plaintiff,
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
v,
:NO, 1257 CIVIL 1994
GREGORY ALAN COX,
Defendant,
:IN DIVORCE
AFFIDA VIT OF CONSENT
1. A Complaint in Divorce under the Divorce code was filed on March 15, 1994,
on the grounds that the marriage of the parties is irretrievably broken,
2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of filing the Complaint,
3, I consent to the entry of a final decree of divorce,
4, 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 the Affidavit are true and correct, I
understand Ihat false statements herein are made subject to the penalties of 18 Pa,C,S, ~
4904 relating to unsworn falsification to authorities,
Date: p.tv (l'lfr
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GREG~ ALAN CO
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KIM RENEE COX,
Plaintiff,
:IN THE COURT OF COMMON PLEAS
:CUMBERLAND COUNTY, PENNSYLVANIA
v,
:NO, 1257 CIVIL 1994
GREGORY ALAN COX,
Defendant,
:IN DIVORCE
AFFIDA VIT OF CONSEN'I:
1. A Complaint in Divorce under the Divorce code was filed on March 15, 1994,
on the grounds that the marriage of the parties is irretrievably broken,
2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
hove elapsed from the dote of filing the Complaint.
3, I consent to the entry of 0 final decree of divorce,
4, I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses if I do not claim them before 0 divorce is gronted,
I verify that the statements mode in the Affidavit ore true and correct. I
understand that false statements herein ore mode subject to the penalties of 18 Pa.C,S, ~
4904 relating to unsworn falsification to authorities,
Dote: J;",()e. 8, 11q~
X~( 'Z/1U!L' Co~
KIM RENEE COX
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: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
: NO. IJ,57 CIVIL 1994
KIM RENEE COX,
Plaintiff,
.
.
GREGORY ALAN COX,
Defendant.
: IN DIVORCE
.
.
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow Kim Renee Cox, Plaintiff, to proceed in forma
pauperis.
I, Samuel W. Milkes, attorney for the Plaintiff proceeding
in forma pauperis, certify that I believe the party is unable to
pay the costs and that I am providing free legal service to the
party. My representation of the Plaintiff results from a pro
bono referral through Legal Services, Inc. The party's affidavit
showing inability to pay the costs of litigation is attached
hereto.
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I IN THE COURT OF COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I NO. CIVIL 1994
KIM RENEE COX,
Plaintiff ,
.
.
GREGORY ALAN COX,
Defendant.
I IN DIVORCE
.
.
IN FORMA PAUPERIS
1. I, Kim Renee Cox, Plaintiff in the above matter, and
because of my financial condition, am unable to pay the fe~s and
costs of prosecuting or defending the action or proceeding.
2. I am unable to obtain funds from anyone, including my
family and associates, to pay the costs of litigation.
3. I represent that the information below relating to my
ability to pay the fees and costs is true and correct:
Name: I<~ ""1 (;( C {":;> ><
Address: ---.!:LI~ g/()c,er1iLllp, C?P. W~W\J~{leJ6...
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a.
Social Security Number:
b. Employment
If you are presently employed, state:
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Address: 17(} 7 :5' t. r-a rp-r
Employer:
0,-,
Salary or Wages per month: ~.qffi
Type of work: La)Jon'-,
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If you are presently unemployed, state
Date of last employment:
Salary or Wages per month:
Type of work:
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4. Other income within the past twelve months ~one, ~ ~~
Business or profession: A~p\y.
Other self-employment:
Interest:
Dividends I
Pension and annuities I
Social security benefits:
Support payments:
Disability payments:
Unemployment compensation and supplemental
benefits:
Workman's compensation:
Public assistance:
Other:
a.
Other contributions to household support
(Wife) (Husband) Name: 4rp'J'')' 4, (lDX @ti\:>><\I~
If your (wife)(husband) is employed, state
Employer:
Salary or wages per month:
Type of work:
Contributions from children:
Contributions from parents:
Other contributions:
b. Property owned
J -',00
Cash: l !2i
Checking account: ~ Q~rrJ I OCJ()~~ 113.(10
Savings account: '\::r. l"\h-+- ha \)Q .
Certificates of deposit: \')0 rl""~ ho..vEJ J
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Real estate (including home): '11b BbSl:Tv~ lIe.. RJ.
Motor velAicle: Make ('kuv Year ~
Cost: ~~.";:' Amount OWedl ,.,
Stocks; bonds: ~-, n~ \rV"\.\) ~ .
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Other I lAb \ y, '?\" n
Debts and obligations
Mortgage: l.;l4, bCD. <,0 pW- f'~
Rent:
Loans:
Other: &-b,."c-r1-.!uc>O,oo
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d. Persons dependent upon you for support
(Wife)(Busband) Name:
Children, if any:
Name: 111cJJ:.h ",,)
Name:
Age:
Age:
3
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Other persons:
Name:
Relationship:
5. I understand that I have a continuing obligation to
inform the Court of improvement in my financial circumstances
which would permit me to pay the costs incurred herein
6. 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: tJ - J - q4
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Kim Renee Cox L~;
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IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. /(),57 CIVIL 1994
KIM RENEE COX,
Plaintiff,
GREGORY ALAN COX,
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 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, Cumberland County Courthouse,
Carlisle, Pennsylvania 17013.
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 CAN~OT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADMINISTRATOR, FOURTH FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
TELEPHONE: 7l7-240-6200
KIM RENBE COX,
Plaintiff,
: IN THB COURT OF COMMON PLEAS
I CUMBBRLAND COUNTY, PENNSYLVANIA
:
I NO. CIVIL 1994
:
: IN DIVORCB
v.
GREGORY ALAN COX,
Defendant.
.
.
COMPLAINT
AND NOW COMBS the Plaintiff, and alleges as follows:
Plaintiff's First Cause of Action - Divorce
1. The Plaintiff is Kim Renee Cox, who currently resides at
416 Bloserville Road, Newville, Cumberland County, Pennsylvania
17241, since 19B7.
2. The Defendant is Gregory Alan Cox, who currently resides
at 441 North College Street, Carlisle, Cumberland County,
Pennsylvania, and previously at Plaintiff's address, since 19B9.
3. Plaintiff has resided in the Commonwealth of
Pennsylvania in excess of six months immediately previous to the
filing of this Complaint.
4. Plaintiff and Defendant were lawfully married on April
2l, 19B9, in Carlisle, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties in this or any other jurisdiction.
6. Neither party to this action in divorce is currently a
member of the Armed Forces of the United States of America.
7. 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.
8. The marriage between the parties hereto is irretrievably
broken.
9. Plaintiff requests the Court to enter a divorce decree
divorcing the parties.
Plaintiff'. Second Cau.e of Action - Cu.tody
10. Paragraphs 1-9 are incorporated herein.
11. Plaintiff seeks legal and exclusive physical custody of
Matthew Levi, age 3, date of birth 8/7/90, and Kayleigh Beth, age
2, date of birth l/26/92, who currently reside in Newville,
Cumberland County, Pennsylvania 17241.
l2. The children were not born out of wedlock.
13. The children are presently in the custody of their
mother, the Plaintiff.
During the past five years or for their entire lives, the
children have resided with the following persons and at the
following addresses:
From birth to December 2l, 1993: with Plaintiff, Kim Renee
Cox, and Defendant, Gregory Alan Cox at 416 Bloserville Road,
Newville, Cumberland County, Pennsylvania l724lj
From December 21, 1993 to present: with Plaintiff, Kim Renee
Cox, at 416 Bloserville Road, Newville, Cumberland County,
Pennsylvania 1724l.
l4. The mother of the children is the Plaintiff. She is
married to the Defendant and resides with the children.
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15. The father of the children is the Defendant. He is
married to the Plaintiff and does not reside with Plaintiff or
the children.
16. Plaintiff has not participated as a party or witness, or
in another capacity, in other litigation concerning the custody
of the children in this or another Court, other than a Protection
from Abuse proceeding, No. 4017 Civil 1993, in which visitation
by the Defendant was disallowed without further order of court.
17. Other than as stated above, Plaintiff has no
information of a custody proceeding concerning the children
pending in a Court of this Commonwealth.
lB. Plaintiff does not know of any other person or party to
the proceedings who has physical custody of the children or
claims to have custody or visitation rights with respect to the
children.
19. The best interest and permanent welfare of the children
will be served by granting the relief requested because the
Plaintiff is a loving parent able to care for the children and
exclusive custody will afford the children the maximum stability
in their home environment.
20. Each parent whose parental rights to the children have
not been terminated and the person who has physical custody of
the children has been named as a party to this action. There are
no other persons who are known to have or claim a right to
custody or visitation of the children.
Plaintiff's Third Cause of Action - Eauitable Distribution
21. Paragraphs 1 through 20 are incorporated herein.
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22. The parties are the owners of real and personal
property subject to equitable distribution between them as
marital property and are jointly obligated on marital debts and
liabilities.
23. The Plaintiff requests the Court to equitably divide
such items of marital property and marital liabilities between
them.
Plaintiff's Fourth Cause of Action
Counsel Fees. Costs and EXDenses
24. Paragraphs 1 - 23 are incorporated herein.
25. Plaintiff is not in a financial position to meet the
costs and expenses of prosecuting this action and to pay
reasonable counsel fees to her attorney.
26. Defendant is presently capable of full time employment.
He is well able to pay Plaintiff's costs and expenses and counsel
fees in this matter.
Plaintiff's Fifth Cause of Action
Alimonv and Alimonv Pendente Lite
27. Paragraphs I - 26 are incorporated herein.
28. Plaintiff is employed full time at Ross Stores, 1707
Shearer Drive, Carlisle, Pennsylvania. Her hourly rate of pay is
approximately $6.93.
29. The Plaintiff is in need of alimony pendente lite to
maintain herself during the course of this action and of
permanent alimony thereafter.
30. The Defendant is unemployed but is capable of full time
employment and is available for full time employment as a
landscaper or similar work. He was employed with Ron Fink
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Landscaping, Carlisle, Pennsylvania until January 1994, when he
voluntarily quit this job without valid reason. He is
financially able to support his wife and his children.
WHEREFORE, the Plaintiff requests that the Court enter a
decree of divorcei
a. divorcing the Plaintiff and the Defendanti and
b. granting the Plaintiff exclusive legal and
physical custody of the parties' childreni
c. granting equitable distribution of the property of
the parties;
d. awarding Plaintiff reasonable counsel fees,
expenses and costs of suit in this matteri
e. awarding Plaintiff reasonable alimony and alimony
pendente litei and
f. granting such further relief as the Court shall
deem proper and just.
Respectfully submitted,
~\\\\q~
Y: amuel W. Milkes,
JACOBSEN & MILKES
36 South pitt Street
Carlisle, PA l70l3
(717) 249-6427
Attorney No. 30130
.
I hereby verify that the statements made in the foregoing
are true and correct. I understand that false statements herein
are made subject to the penalties of lB Pa.C.S. Section 4904,
relating to unsworn falsification to authorities.
Dated: t.../-i- Q'1
~fL ;Jc: ~
KIM RENEE COX
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I IN THB COUR~ OF COMMON PLEAS OF
I CUMBERLAND COUN~Y, PBNNSYLVANIA
:
I NO. 1257 CIVIL 199~
I
I IN DIVORCB
I
KIM RENBB COX,
Plaintiff
GREGORY ALAN COX,
Defendant
AFFIDAVIT OF SERVICE
I, Samuel W. Milkes, hereby certify that a true and correct copy of
the Complaint in Divorce in the above captioned matter was duly served on
May 16, 1994, upon the Defendant, by personal service on the Defendant in
the presence of his court appointed legal counsel, Darrell C. Dethlefs,
Esquire, at the Cumberland County Courthouse
I hereby verify that the statements made in the foregoing 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 unsworn falsification to
authorities.
Dated: ~~( ~~~
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. Samuel W. I es
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1257 CIVIL 1994
v.
GREGORY ALAN COX,
Defendant
IN DIVORCE
AFFIDAVIT OF SERVICE
I, Linda D. Walterick, hereby certify that a true and correct
copy of a Complaint in Divorce was duly served upon the Defendant,
by personally handing the same to the Defendant, Gregory Alan Cox,
in the presence of his court appointed legal counsel, Darrell C.
Dethlefs, Esquire, in Court Room 4, of the Cumberland County
Courthouse, on this 23rd day of February, 1995.
I hereby verify that the statements made in the foregoing are
true and correct. I understand that false statements herein are
made subject to the penalties of l8 Pa.C.S. 54904, relating to
unsworn falsification to authorities.
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L nda D. Walter~ck
v.
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
I NO. 1257 CIVIL 1994
I
I IN DIVORCE
I
GREGORY ALAN COX,
Defendant
CERTIFICATE OF SERVICE
I, Samuel W. Milkes, hereby certify that a certified copy of
the Order of Court Re: Motion For Appointment of Master and the
Motion For Appointment of Master were served upon the Defendant, by
placing the same for delivery with the united States Post Office,
by first class mail, postage prepaid, on February 24, 1995, to the
Defendant's last known address of 441 N. College Street, Carlisle,
Pennsylvania, l70l3, and I personally delivered a certified copy of
the aforementioned pleadings at approximately 6: 00 P.M. to the
Defendant, at the Cumberland County Prison, IlOl Claremont Road,
Carlisle, Pennsylvania.
Respectfully submitted,
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Esq.
amuel W. ilkes,
JACOBSEN & MILKES
52 E. High Street
Carlisle, PA l70l3
(717) 249-6427
Attorney No. 30130
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KIM RENEE COX,
Plaintiff,
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. IdS, CIVIL 1994
IN DIVORCE
GREGORY ALAN COX,
Defendant.
WAIVER OF COUNSELING
Kim Renee Cox, Plaintiff herein, hereby states and certifies
as follows:
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 Domestic Relations Office, which list is
available to me upon request.
3. Being so advised, I do not request that the Court
require that 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. Section 4904, relating to unsworn
falsification to authorities.
Dated:
4 - 7 - 9 LI
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KIM NEE COX
BY :( '~~~ea ,~:~'il:es,
JACOBSEN & MILKES
52 E. High Street
Carlisle, PA 17013
(717) 249-6427
Attorney No. 30130
Esq.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v.
: NO. l257 CIVIL 1994
.
.
GREGORY ALAN COX,
Defendant
: IN DIVORCE
.
.
PRAECIPE
TO THE PROTHONOTARY, SIRI
Please reinstate the Complaint in Divorce filed in the above
captioned action on March 15, 1994, a copy of which is attached to
this Praecipe, for service upon the Defendant.
Respectfully submitted,
Dated: February 23, 1995
v.
NO. JJ.S7 CIVIL 1994
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KIM RENEE COX,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
GREGORY ALAN COX,
Defendant.
IN DIVORCE
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You have been sued in court. If you wish to defend aga1fust
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.
NOTICE TO DEFEND AND CLAIM RIGHTS
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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, Cumberland County Courthouse,
Carlisle, Pennsylvania l7013.
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.
COURT ADMINISTRATOR, FOURTH FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA 17013
TELEPHONE: 7l7-240-6200
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KIM RENEE COX,
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO.
CIVIL 1994
GREGORY ALAN COX,
Defendant.
IN DIVORCE
COMPLAINT
AND NOW COMES the Plaintiff, and alleges as follows:
Plaintiff's First Cause of Action - Divorce
1. The Plaintiff is Kim Renee Cox, who currently resides at
416 Bloserville Road, Newville, Cumberland County, Pennsylvania
l7241, since 1987.
2. The Defendant is Gregory Alan Cox, who currently resides
at 441 North College Street, Carlisle, Cumberland County,
Pennsylvania, and previously at Plaintiff's address, since 1989.
3. Plaintiff has resided in the Commonwealth of
Pennsylvania in excess of six months immediately previous to the
filing of this Complaint.
4. Plaintiff and Defendant were lawfully married on April
21, 1989, in Carlisle, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties in this or any other jurisdiction.
6. Neither party to this action in divorce is currently a
member of the Armed Forces of the United States of America.
7. 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.
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8. The marriage between the parties hereto is irretrievably
broken.
9. Plaintiff requests the Court to enter a divorce decree
divor~ing the parties.
Plaintiff's second Cause of Action - Custody
10. Paragraphs 1-9 are incorporated herein.
11. Plaintiff seeks legal and exclusive physical custody of
Matthew Levi, age 3, date of birth 8/7/90, and Kayleigh Beth, age
2, date of birth l/26/92, who currently reside in Newville,
Cumberland County, Pennsylvania 1724l.
12. The children were not born out of wedlock.
13. The children are presently in the custody of their
mother, the Plaintiff.
During the past five years or for their entire lives, the
children have resided with the following persons and at the
following addresses:
From birth to December 2l, 1993: with Plaintiff, Kim Renee
Cox, and Defendant, Gregory Alan Cox at 416 Bloserville Road,
Newville, Cumberland County, Pennsylvania l7241;
From December 21, 1993 to present: with Plaintiff, Kim Renee
Cox, at 416 Bloserville Road, Newville, Cumberland County,
Pennsylvania 1724l.
14. The mother of the children is the Plaintiff. She is
married to the Defendant and resides with the children.
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15. The father of the children is the Defendant. He is
married to the Plaintiff and does not reside with Plaintiff or
the children.
~6. Plaintiff has not participated as a party or witness, or
in another capacity, in other litigation concerning the custody
of the children in this or another Court, other than a Protection
from Abuse proceeding, No. 4017 civil 1993, in which visitation
by the Defendant was disallowed without further order of court.
l7. Other than as stated above, Plaintiff rnas- no
information of a custody proceeding concerning the children
pending in a Court of this Commonwealth.
18. Plaintiff does not know of any other person or party to
the proceedings who has physical custody of the children or
claims to have custody or visitation rights with respect to the
children.
19. The best interest and permanent welfare of the children
will be served by granting the relief requested because the
Plaintiff is a loving parent able to care for the children and
exclusive custody will afford the children the maximum stability
in their home environment.
20. Ea~h parent whose parental rights to the children have
not been terminated and the person who has physical custody of
the children has been named as a party to this action. There are
no other persons who are known to have or claim a right to
custody or visitation of the children.
Plaintiff's Third Cause of Action - Eauitable Distribution
21. Paragraphs 1 through 20 are incorporated herein.
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22. The parties are the owners of real and personal
property subject to equitable distribution between them as
marital property and are jointly obligated on marital debts and
liabilities.
23. The PlaintHf requests the Court to equitably divide
such items of marital property and marital liabilities between
them.
Plaintiff's Fourth Cause of Action
Counsel Fees. Costs and EXDenses
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24. Paragraphs 1 - 23 are incorporated herein.
25. Plaintiff is not in a financial position to meet the
costs and expenses of prosecuting this action and to pay
reasonable counsel fees to her attorney.
26. Defendant is presently capable of full time employment.
He is well able to pay Plaintiff's costs and expenses and counsel
fees in this matter.
Plaintiff's Fifth Cause of Action
Alimonv and Alimonv Pendente Lite
27. Paragraphs 1 - 26 are incorporated herein.
28. Plaintiff is employed full time at Ross Stores, 1707
Shearer Drive, Carlisle, Pennsylvania. Her hourly rate of pay is
approximately $6.93.
29. The Plaintiff is in need of alimony pendente lite to
maintain herself during the course of this action and of
permanent alimony thereafter.
30. The Defendant is unemployed but is capable of full time
employment and is available for full time employment as a
landscaper or similar work. He was employed with Ron Fink
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Landscaping, Carlisle, Pennsylvania until January 1994, when he
voluntarily quit this job without valid reason. He is
financially able to support his wife and his children.
.WHEREFORE, the Plaintiff requests that the Court enter a
decree of divorce;
a. divorcing the Plaintiff and the Defendant; and
b. granting the Plaintiff exclusive legal and
physical custody of the parties' children;
c. granting equitable distribution or9Che property of
the parties;
d. awarding Plaintiff reasonable counsel fees,
expenses and costs of suit in this matter;
e. awarding Plaintiff reasonable alimony and alimony
pendente lite; and
f. granting such further relief as the Court shall
deem proper and just.
Respectfully submitted,
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JACOBSEN & MILKES
36 South pitt Street
Carlisle, PA 17013
(717) 249-6427
Attorney No. 30130
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I hereby verify that the statements made in the foregoing
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 unsworn falsification to authorities.
Dated: L-/ -,- c,Lj
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KIM RENEE COX
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KIM RENEE OOX, IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
.
.
. CIVIL ACTION - LAW
.
VB. : NO. 1257 CIVIL 1994
GREa)RY AlAN OOX,
Defendant . IN DIVORCE
.
STATUS SHEET
DATE:
ACTIVITIES:
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KIM RENEE COX,
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
vs.
: CIVIL ACTION - LAW
GREX:nRY ALAN COX,
Defendant
: NO, 1257
CIVIL
19 94
IN DIVORCE
ORDER AND NOTICE SETTING HEARING
To:
Kim Renee Cox
Sanuel W. Milkes
Gregory Alan Cox
. Plaintiff
. Counsel for Plaintiff
. Defendant
Counsel for Defendant
You are directed to appear for a hearing to take
testimony on the outstanding issues in the above captioned
divorce proceedings at the Office of the Divorce Master. 9 North
Hanover Street. Carlisle. Pennsylvania, on the 8th day
of June . 1995. at 9:00 a,m.. at which place
and time you will be given tile opportunity to present witnesses
and exhibitr. in support of your case.
By the Court.
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Harold E. Sheely.
.Judge
Date of Order and
Not ice: 2/24/95
By:
Divorce Master
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,
Court Administrator
Fourth Floor. East Wing
Cumberland County Courthouse
Carlisle. PA 17013
Telephone (717) 240-6200
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KIM RENEE COx,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1257 CIVIL 1994
v.
.
.
GREGORY ALAN COX,
Defendant
: IN DIVORCE
ORDER OF COURT
RE: MOTION FOR APPOINTMENT OF MASTER
AND NOW, this ~ay of ~e.),,,"^--\ ~, 1995, upon motion
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of the Plaintiff in this matter, the Mastey is' hereby appointed for the purpose of
resolving the various claims in dispute, as set forth in Plaintiff's Motion,
By The Court,
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KIM RENEE COX,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 1257 CIVIL 1994
v.
.
.
GREGORY ALAN COX,
Defendant
IN DIVORCE
MOTION FOR APPOINTMENT OF MASTER
KIM RENEE COX, Plaintiff, by and through her counsel, Samuel W, Milkes,
Esquire, JACOBSEN & MILKES, moves the Court to appoint a Master with respect
to the following claims:
X Divorce
-X- Alimony
=X= Counsel Fees
X Distribution of Property
-X- Alimony Pendente Lite
- X- Costs and Expenses
1. Discovery is complete as to the claim(s} for which the appointment
of a master is requested,
2, The Defendant has not appeared in the action personally, although
he has been served,
3. The statutory grounds for divorce are ~3301(c) and (d),
4, The action is contested with respect to the following claims:
a. Divorce
b, Equitable Distribution
c, Alimony
d, Alimony Pendente Lite
e, Counsel Fees
f, Costs and Expenses
5, The action does not involve complex issues of law or fact,
6. The hearing is expected to take 3 hours,
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7, Additionnl information, if any, relevant to the motion:
The Defendant does not appear to have a permanent address,
Dated: ~?""'";> , 1995
Respectfully submitted,
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""-BY: Samuel W, Milkes, Esq,
JACOBSEN & MILKES
52 E, High Street
Carlisle, PA 17013
(717) 249.6427
Attorney No. 30130
. .
OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON PLEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240.6535
E. Robert Elicker, II
Divorce Master
Tracl Jo Colver March 1, 1995
Office Maneger/Reporter
Samuel L. Milkes, Esquire
JACOBSEN & MILKES
52 East High Street
Carlisle, PA 17013
w..t Shore
697.0371 Ex!. 6535
Gregory Alan Cox
441 North College Street
Carlisle, PA 17013
RE: Kim Renee Cox vs. Gregory Alan Cox
No. 1257 civil 1994
In Divorce
Dear Mr. Milkes and Mr. Cox:
By order of Court of President Judge Harold E. Sheely
dated February 24, 1995, the full-time Master has been appointed
in the above referenced divorce proceedings.
Upon receipt of the Master's appointment an order and
notice was prepared setting a hearing on June B, 1995, at 9:00
a.m. In order to allow the Master to have an opportunity to
review the issues pending in the case, specifically the economic
claims of equitable distribution, counsel fees and expenses, and
alimony and alimony pendente lite, the Master directs that Mr.
Milkes and Mr. Cox who is apparently representing himself, file
a pre-trial statement in accordance with P.R.C.P. 1920.33(b) at
least two weeks prior to the hearing scheduled in these
proceedings on June 8, 1995.
Very truly yours,
E. Robert Elicker, II
Divorce Master
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Mr. Milkes, Attorney at Law and Mr. Cox, Defendant
1 March 1995
Page 2
NOTE: Sanctions for failure to file the pre-trial statements
are set forth in subdivision (c) and (d) of Rule 1920.33.
THE ORIGINAL PRE-TRIAL STATEMENT SHOULD BE FILED IN THE
MASTER'S OFFICE AND A COPY SENT DIRECTLY TO OPPOSING
COUNSEL.
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1257 CIVll.. 1994
KIM RENEE COx,
Plaintiff
GREGORY ALAN COX,
Defendant
IN DIVORCE
INVENTORY
AND PRE-HEARING STATEMENT
OF
KIM RENEE COX
Pursuant to Rule 1920,33 (a) and (b) of the Pennsylvania Rules of Civil
Procedure, Plaintiff mes the following inventory of all property owned or possessed by
either party at the time this action was commenced, at the time of separation, and all
property transferred within the preceding three years, Additionally, Plaintiff files the
following pre-hearing statement.
Defendant marks on the list below those items applicable to the case at bar and
itemizes the assets on the following pages,
(x) 1.
(x) 2.
() 3,
(x) 4,
(x) 5.
(x) 6,
() 7,
() 8.
(x) 9,
() 10,
(x) 11,
Real property
Motor vehicles
Stocks, bonds, securities and options
Certificates of deposit
Checking accounts, cash
Savings accounts, money market and savings certificates
Contents of safe deposit boxes
Trusts
Life insurance policies (indicate face value, cash surrender value and
current beneficiaries)
Annuities
Gifts
(x) 12,
() 13,
() 14,
() 15,
() 16,
() 17,
() 18,
() 19,
() 20,
() 21,
() 22,
() 23,
(x) 24,
(x) 25,
() 26.
Inheritances
Patents, copyrights, inventions, royalties
Personal property outside the home
Businesses (list all owners including percentage of ownership, and
officer/director positions held by a party with company)
Employment termination benefits- severance pay, worker's compensation
claim/award
Profit sharing plans
Pension plans (indicate employee contribution and date plan vests)
Retirement plans, Individual Retirement Accounts
Disability payments
Litigation claims (matured and unmatured)
MilitaryN.A, benefits
Education benefits
Debts due, including loans, mortgages held
Household furnishings and personalty (include as a total category and
attach itemized list if distribution of such assets is in dispute
Other: Value of education received during the marriage
MARITAL PROPERTY
Defendant lists all property in which either or both spouses have a legal or
equitable interest individually or with any other person as of the date this action was
commenced:
Real Prooertv
One Double-wide mobile home, located at 416 Bloserville Road, Newville, PA
17241. Purchased for approximately $17,900 over two years ago. Wife has made all
payments on this mobile home except five monthly payments of $280,00, in which the
Defendant participated. Wife also borrowed $3,000,00 from an aunt to purchase ihis
home and this amount is still owing,
One single-wide mobile home, located at the same address, purchased in both
spouses names from a person named Failor.
Vehicles
One 1986 Blazer SolO Pickup truck, titled in both names and purchased during
the marriage, This is the wife's only means of transportation and is currently in her
possession, This vehicle was paid for by wife. There is owing on this vehicle the
remainder of a $3,000,00 credit card debt, used to purchase a new motor for the
vehicle and being paid solely by wife. Wife also spent $300.00 to repair this vehicle
after its removal by husband since the separation, and contrary to a protection from
abuse order.
One 1975 Blazer, titled in both names and purchased during the marriage,
having a value of approximately $800.00.
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One 1978 Ford van, which has no title that is known of but which was
purchased by the parties during the marriage by a trade, having a value of
approximately $600,00,
Other Pronertv
One king-size waterbed, purchased during the marriage for approximately
$1,600,00, and currently in the possession of wife, This item continues to be, and has
been paid for solely by wife,
One slate-top pool table, purchased during the marriage by wife from a family
member for $250,00,
One washer and one dryer. The washer is being paid for by wife and had a
purchase price of $600,00, The dryer was a gift to husband and wife,
One camcorder, purchased by wife during the marriage for the amount of
$l,200,OO,
NON-MARITAL PROPERTY
The real estate located at 416 Bloserville Road, Newville, PA 17241. This real
estate was a gift to wife from her father, before the marriage. Wife made
approximately $6000,00 in improvements before the marriage to allow for water and
sewer, The property was transferred to both names during the marriage but such
transfer was not intended as a gift. Rather, it was for the purpose of the parties being
able to obtain credit together.
One single-wide mobile home, located at the same address, purchased in wife's
maiden name, Kim Moore, before the marriage.
Tools of husband, which husband possessed before the marriage and which
husband has retrieved.
One 1968 Honda motorcycle, purchased by wife before the marriage and title in
wife's name only,
One dining room set, inherited by wife during the marriage,
PROPERTY TRANSFERRED
One 1982 Ford Bronco which was repossessed and which had been in the
possession of husband. This vehicle was purchased in both names during the
marriage, Wife borrowed $1,648,00 to pay on this item, in order to avoid the
repossession affecting her credit record, as per the attached document.
EXPERTS
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Wife does not anticipate the need to call experts,
WITNESSE..5.
Wife expects that she will be the only witness at this hearing.
~XHIBITS
Attached are exhibits which Plaintiff intends to offer at the IIUlllter's hearing.
GROSS INCOME, NET INCOME, AND EXPENSES
Wife's current gross income is $618.40 every two weeks, Her net income is
$448,46. From this amount, she pays health insurance of $26,00, to cover her two
children and herself. This is her sole source of support.
Husband's income is unknown, He is currently in support arrears in the
amount of $4,674,00, payable through the Domestic Relations office of Cumberland
County,
PENSION/RETIREMENT
Wife has a 401k plan, with a current value of $890,86, She started paying into
this plan three years ago, Wife also has a life insurance policy, payable to the children,
which she began to pay into three years ago.
ALIMONY
Wife claims alimony from husband, based upon the dire financial circumstances
which have been imposed upon her due to his actions,
COUNSEL FEES
Wife claims ongoing counsel fees for her pursuit of this divorce action,
TANGIBLE PERSONAL PROPERTY
Wife claims entitlement to various items of marital tangible personal property
remAining at the residence and not described above.
MARITAL D~
The debts listed above, relating to the double-wide mobile home, the Ford Bronco,
The S-10 pick up truck., and the washer all constitute marital debts. Other debts
existed during the marriage but have been paid off during the marriage,
~ROPOSED RESOLUTION
The real property should revert to wife, as should the double-wide and single-
wide mobile home purchased before the marriage, Husband may retain the Failor
single-wide mobile home, The S-10 pick up truck should revert to wife, as should the
1975 Blazer and the motorcycle, The Ford van may be retained by husband. All
personal property now at wife's residence, to include the waterbed, pool table, washer
and dryer, and pool table, camcorder, and dining room set will be retained by wife,
Husband will retain all tools now in his possession, Husband is to reimburse wife
$1648,00 which she paid toward the repossessed Ford Bronco, Husband is to pay
wife's counsel fees, Husband is to pay wife $200.00 monthly alimony,
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BY: Samuel W. Milkes, Esq.
JACOBSEN & MILKES
52 E, High Street
Carlisle, PA 17013
(717) 249.6427
Attorney No. 30130
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CARLISLE POLICE DEPARTMENT
53 West South Street
Carlisle, PA 17013
Phone
(717) 243-5252
COX, GREGORY/ KIM,
416 BLOSERVILLE ROAD
NEWVILLE, PA 17241
A Warrant for your arrest has been received by this department,
It was issued by: Paula P. Correal
16 W HIGH 2ND FLOOR
Carlisle 1 PA 17013
for the violation: PARKING ON PRIV PROP W/O CONSENT
You are requested to make payment in the amount of S
43.00, payable to
the above mentioned Magistrate and delivered to the Magistrate's address.
Your failure to comply with this request will result in a personal contact
by a member of this Department or a Pennsylvania State Constable, resulting
in additional costs, at your residence or place of employment.
If you have any questions regarding this matter, contact the
CARLISLE POLICE DEPARTMENT or the District Magistrate's office,
in person or by telephone at the above addresses. The District Magistrate's
phone number is (717) 243-0292 .
Sincerely 1
.~<<- ( ,~
CARLISLE POLICE DEPARTMENT
Carlisle, PA 17013
-
(, JuJ:y 14, '1994
DOHE5TlC K"LATlONS ol'nCL; - CONFERF.NCE 5UHHAR'i
"0: JUlJlle Bavley
ilK NO,
22.100
April 15. 1994
FRO~I:
Richard J. Breski. Jr.
DATE:
KIM R. COX
, PLAtNTlI'l"
v,
NO,
1253 OF
lqcn
t:Rp'mRV Af.AN mY
. Il~FI;NllANT
Attorney for Plaintiff:
n/A
Hearing held:
n/14
Attorney for Defendant:
n/14
Action: Support for ~ >iHlP ~
Present Order requires defendant
Paid Last on: never oaid
chUd(ren)
to pay $ 72.00 oar week olus 55.00 on "......",...
Defendant emp loyed by unknown
Plaintiff elll(lloyed by unknown
employs a baby-sieter @ $ per
is (noe) receiving public assistance of $
Nets: $
Nets: $
per
per
per
Commenes: Defenrumt has failed to ao,....,,,r for enforcenent hpl'lrina And his notice was
not reMlrnM.
Defendant has made no na~nts on this order And hAs f"il..d to
correst)Ond with the D:xrestic RelAtions Office ~rrlin9 his ~lnvmP.nt stAtus
and f1.1\V'lT'ent' nn ;:lI~.A~.
ArreArs to date total 51.224.00.
REFERRED FOR NJN-cc:MPLTANCE
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KIM R, COX,
rN TIm COURT OF cot+fON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
crvrL ACTION - LAW
NO, 4017 CIVIL 1993
PROTECTION FROM ABUSE AND CUSTODY
Plaintiff
v.
GREG A. COX,
Defendant
AND NOW,
PROTECTIVE ORDER
this ~ of March, 1994, after a hearing
in the above case
on February 9, 1994, and upon finding that the defendant, Greg A. Cox, abused the
plaintiff. the following order is entered:
1, The defendant, Greg A. Cox, is enjoined from physically abusing the
plaintiff, Kim R. Cox, or from placing her in fear of abuse.
2, The defendant is enjoined from having any direct or indirect contact
with the plaintiff including, but not limited to, telephone and written.
3, The defendant is ordered to refrain from harassing and stalking the
plaintiff and from harassing the plaintiff's family and her minor children.
4, The defendant is prohibited from entering the plaintiff's place of
employment or the day care facilities of her children,
5, The defendant is prohibited from removing, damaging, destroying or
selling any property owned by the plaintiff or jointly owned by the parties,
6, . The defendant is excluded from the premises located at 416
Blosservi1le Road, Newville, CUmberland County, Pennsylvania,
7, The defendant is ordered to stay away from any residence the
plaintiff may in the future establish for herself,
8, The defendant shall have no visitation with the parties' children
pending the defendant's request for visitation through the court and the entry
of a subsequent Court Order,
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9, The defendant's weapons shall remain in the custody of the CUmberland
County Sheriff's Department or the Pennsylvania State Police pending further
Order of Court,
10. This Order shall remain in effect for a period of one year,
11. The Pennsylvania State Police and the Car lis Ie Police Department
shall be provided with certified copies of this Order by the plaintiff's attorney
and may enforce this order by arrest for indirect criminal contempt without
warrant upon probable cause that this Order has been violated, whether or not the
violation is committed in the presence of the police officer. rn the event that
an arrest is made under this section, the defendant shall be taken without
unnecessary delay before the court that issued the order, When that court is
unavailable, the defendant shall be taken before the appropriate district
justice, (23 P.S, ~ 6113),
By the Court,
~'/~ t..
ar ld E, Sheely, President
Joan Carey
Attorney for Plaintiff
LEGAL SERVICES, INC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
. "
TRUe COpy FROM RECORD
In Testimony wherlld, I here until Slit my hand
and the ~ et said Court at Cc1rtisle Fa,
This 'I day r.~' ~V'
. Yr" () '/11. ~~.. ~
, " P\'ltt!lonotary
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KIM R. COX.
rN nm COURT OF COMMON PLEAS OF
CtJMBERLAND COlJNTY J PENNSYLVANIA
NO, 93 - 4017 CIVIL TERM
PROTECTION FROM ABUSE AND CUSTODY
Plaintiff
v,
GREG A. COX,
Defendant
CUSTODY ORDER.
AND NOW, this ~ay of April, 1994, pursuant to a hearing in the above-
captioned matter held on February 9, 1994, the following Order is entered with
regard to custody of the parties' children, Matthew L, COx and Kayleigh B, COx.
1, The plaintiff, Kim R. Cox. shall have primary physical and legal
custody of the parties' children,
2, The defendant, Greg A. COx, shall have no partial custody or
visitat ion wi th the part ies' chi 1dren unt it such relief is requested by the
defendant and would be granted pursuant to a subsequent Order of COurt.
3. This Order shall remain in effect until either party petitions to
have it changed.
By the COurt,
1.s/~C'~
Harold E. Sheely, Preside t Judge
TRUE COpy FROM RECO~D
In T~:;t'm:r.'1 '..:,: ~;, I h;,re unto set my,hand
and lhe seal of said Court at Carlisle, Pa,
This .....ld..~. day Of....O(:.;q,.g..:..., 19.9.!f...
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RECElt;J 0 C.T . 2 8 1~~)'
M.a.s. ASsocxATms, ~NC.
1000 MAPLmwooo OR
SUXTm 207
MAPLm SHAom, Nmw JmRSBY 08052
:1.-609-667-5566
~AX 1-609-667-5526
~Aca~MXLm TaANSMXTTAL
------...--------------
The documents accompany1ng tn1s telecopy transm1ss10n contain 1nformation
from M.R.S. Associates, Inc, which is confidential and/or propr1etary.
The 1nformation 1s intended only for the use of the individual or ent1ty
named below, If you are not the intended recipient, you are hereby notified
that any disclosure, copying, distribution or the taking of any action in
reliance on the contents of th1a telecopy is str1ctly proh1b1ted. If you
have received this telecopy in error, please not1fy us 1mmed1ately by phone.
ASSOCIATES I NC
::. ~1J1f:/il!;J . Ql~ -
FAX NUMBBR.(7/7)~
DATI. 10'" UJ.'.I(
/17
~II ~e ;j;;cK 7fjal4-Y /111111 c.~ Mt_r-r-#=,
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M.R.S. ASSOC~ATmS, XNC.
1000 MAPLEWOOC CRXVm
SUJ:Tm 207
MAPLE SHACE, NEW JERSEY 08052
1-609-667-5566
OCT 28, 1994
KIM MOORE
441 N COLL!GS ST
CARLISLS, PA 11013
OUR CLIENTI
PNC BANK (S,C.)
CLT ACCT'05l741603
OUR ACCT. , 032164
ORIG. BAL.. $3295.83
SETT. AMT,I 81648.00
032164 04
Dear KIM MOORE,
Pursuant to our telephone conversatlon of OCT 28, 1994
M,R,S, Assoclates, Inc., has been retalned to serve as agents on
behalf of PNC BANK (s.c.).
Etfect1ve lmmedlately, M.R.S, Assoclates, Inc.
has authorlzat10n to accept 81648.00 as
settlement"ln full on the above referenced account 1f
consumated on or betore 10/31/94.
Upon recslpt ,of81648.00, you W111 be '
released of any further obl1gat10n to PNC BANK (S.C.)
r8ljJardlnfjJ the above referenced account.'
Thank you for your prompt attent10n to th1s matter.
THIS IS AN ATTSMPT TO COLLECT A DBBT AND ANY
INP'OlU1ATION OBTAINED WILL BE USED FOR THAT PURP08Jl:.
UPON COMPLETION Oll' THill SB'l'TLEMBNT, l/OUR CREDIT WILL Bill JlMl!lNDBlD
TO RBll'LIllCT A SI!:TTLIW' ACCOUNT .
SF/rat
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
I NO. 1257 CIVIL 1994
I
I IN DIVORCE
I
KIN RENEE COX,
Plaintiff
GREGORY ALAN COX,
Defendant
CERTIFICATE OF SERVICE
I, Nancy J. Nixon, hereby certify that a true and correct copy
of the Inventory and Pre-Hearing Statement of Kim Renee Cox was
served upon the Defendant, by placing the same for delivery with
the United states Post Office, by first class mail, postage
prepaid, on June l, 1995, to the Defendant's last known address of
441 N. College Street, Carlisle, Pennsylvania, 170l3.
Respectfully submitted,
biOI ~5
Dated
~~~~ ~~~
ny, ---;{jcJn/t/:-I7~ ~c;~
Custody Concil~ator ~~ '
YOUR 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.
OFFICE OF THE COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PA l70l3
(717) 240-6200
KIM RENEE COX,
Plaintiff,
: IN THE COURT OF COMMON PLEAS
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I No.1;;' ')7 CIVIL 1994
:
: IN DIVORCE
:
v.
GREGORY ALAN COX,
Defendant.
ORDER OF COURT
AND NOW, this ~ day of
M", l h.
, 1994, upon
consideration of the attached Complaint, it is hereby directed
that the parties and their respective counsel appear before
~hl-{'" y, (.,...-', I r()~, t'CA. , the Conciliator, at
4~ h. ~ loor (u.",,6. {~.., ( o..,rlh~', on the 0:;2nc/ day of
l1f'r; \ , 1994, at Cj';3o o'clock -II-.m., for a Pre-
Hearing Custody Conference. At such conference, an effort will
be made to resolve the issues in dispute; or if this cannot be
accomplished, to define and narrow the issues to be heard by the
Court, and to enter into a temporary order. Failure to appear at
the conference may provide grounds for entry of a temporary or
permanent order.
FOR THE COURT,
HAft ZI 10 3Z AH '9~
. :dICE
ei ,.,.. i!1I0k~H~~
r.lIHl,r'cJIiO C('~Hrv
f lkhSr~.,."IA
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
KIM RENEE COx,
Plaintiff
v,
NO, 1257 CML 1994
GREGORY ALAN COx,
Defendant
AFFIDAVIT OF SERVICE
I, Roberta A, Hockenberry, hereby certify that a true and correct copy of the
Complaint and Waiver of Counseling in the above-captioned matter was duly served
upon the Defendant, Gregory Alan Cox, by depositing it in the U,S. Mail, certified,
restricted, return receipt requested, on March 15, 1994, addressed as follows:
Gregory Cox
44l N. College St,
Carlisle, PA 17013
The return receipt card was signed on the l6th day of
March, 1994. The return receipt card is attached as Exhibit "A."
I hereby verify that the statements made in the foregoing 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 unsworn falsification to authorities,
Dated: May 5, 1994
P 214 465 sua
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__ No Insulancl' em ('/ilgc Provided
..~a."':'':;~~ 00 not use fne Irul'm.lt.onal Mail
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"441' N. College St.
"Ca'rHs1e, PA 17013
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IN THE COU
CUMBERLAND COUN'lY, PENNSYLVANIA
NO, 1267 ClVlL 1994
KIM RENEE COx.
Plaintiff,
GREGORY ALAN COx.
Defendant,
IN DlVORCE
PRAECIPE
COMES NOW, the Plaintiff Kim Renee Cox, by her counsel, Samuel W,
Milkes, Jacobsen & Milkes, and formerly praecipes to withdraw the custody count
contained within her divorce complaint med before this Court on March 15, 1994,
This count is withdrawn in light of the attached Custody Order entered by the
Honorable Harold E, Sheely on April 11, 1994, in the protection from abuse action
filed by Plaintiff at No, 93-4017 Civil Term.
~ (1-S{7i
Respectfully submitted,
~~
BY: Samuel W. Milkes, Esq,
JACOBSEN & MILKES
36 South Pitt Street
Carlisle, PA l70l3
(717) 249-6427
Attorney No, 30130
:.-
.-
KIM RENEE COx,
Plaintiff.
rN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 12117 CIVrL 1994
IN DIVORCE
v,
GREGORY ALAN COx,
Defendant,
CERTIFICATE OF SERVICE
I, Samuel W, Milkes, Esq, hereby certify that a true and correct copy of the
Praecipe and Proposed Order, in the above-captioned matter, was duly served upon the
Defendant, Gregory Alan Cox, by depositing it in the U,S. Mail, on April 13, 1994,
addressed as follows:
Gregory Alan Cox
441 North College Street
Carlisle, PA 17013
I hereby verify that the statements made in the foregoing 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 unsworn falsification to authorities,
,fZ..~
Dated: 1f //3/ <j '-/
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KIM RENEE COx,
Plaintiff
v,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 1257 CML 1994 /
IN DIVORCE
GREGORY ALAN COx,
Defendant
KIM R, COx,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 93-4017 CML TERM
PROTECTION FROM ABUSE AND
CUSTODY
v,
GREG A, COx,
Defendant
RULE TO SHOW CAUSE
AND NOW, this 5~y of May, 1994, upon presentation and consideration
of the Petition ofthe Plaintiff, a Rule is issued upon the Defendant to show cause why
he should not be found in indirect criminal contempt of the Court's Protection from
Abuse Order and further why the Petition for Special Relief under the divorce action
should not be granted, This Rule is returnable at a hearing scheduled for the fJ:!J
day of ".,~, ~ , 1994, at 9 : .~t11' ni" in courtroom number ~ ,Cumberland
. , ~
County Courthouse, Carlisle, Pennsylvania.
BY THE COURT,
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v,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
NO, 1257 CML 1994
IN DIVORCE
KIM RENEE COx,
Plaintiff
GREGORY ALAN COx,
Defendant
KIM R, COx,
Defendant
: IN THE COURT OF COMMON PLEAS
:CUMBERLANDCOUNTY,PENNSYLVANIA
NO, 93-4017 CML TERM
PROTECTION FROM ABUSE AND
CUSTODY
Plaintiff
v,
GREG A. COx,
PETITION FOR INDmECT CRIMINAL CONTEMPT
OF PROTECTION FROM ABUSE ORDER AND
PETITION FOR SPECIAL RELIEF UNDER THE DIVORCE CODE
COMES NOW, the Plaintiff in the above-captioned divorce matter, by and
through her counsel, Samuel W, Milkes, Jacobsen & Milkes, and petitions this
Honorable Court for special relief, directing that the Defendant return to Plaintiff the
Chevrolet S-10 Blazer and rmding the Defendant in contempt of the Protection from
Abuse Order, due to his taking possession of said Blazer. In support of this request,
Plaintiff avers as follows:
1. The parties are married but have been separated since December 21,
1993,
2, On March 4, 1994, a Protection From Abuse Order was entered by the
Honorable Harold E, Sheely, President Judge, Within this Order, which is attached,
, .
at paragraph 5, the Defendant is prohibited from "removing, damaging, destroying, or
selling any property owned by the Plaintiff or jointly owned by the parties,"
3, On April 29, 1994, through a friend, employee, or other associate, the
Defendant entered upon the Plaintiff's place of employment and removed her 1986
Chevrolet S-10 Blazer, license plate number USA-755, and, contained within the
vehicle, he also removed various tapes of Plaintiff, items of children's clothing, and the
warranty card on the motor contained within this vehicle.
4. Defendant, Gregory Alan Cox, has a 1984 Ford Bronco which is available
to him and which he has been driving,
5, Both of the above-described vehicles are titled jointly in the parties
names,
6, Since their purchase, the Chevrolet S-10 Blazer has been the vehicle used
by Plaintiff and the Bronco has been the vehicle used by Defendant,
7, Since their purchase, Plaintiff has made payments upon the Chevrolet
S-10 Blazer and Defendant has made payments upon the Bronco,
8, Since the separation of the parties, it became necessary to install a new
engine in Plaintiff's Chevrolet S-10 Blazer. This was at a cost of approximately $2,700,
which was fully incurred by Plaintiff, and financed on a VISA card in Plaintiff's name
only, Plaintiff continues to make payments on this debt,
9. The Defendant, through his actions, has left the Plaintiff without a
vehicle with which to transport the parties' two children, who are in her custody, and
has left the Plaintiff without a vehicle with which to transport herself back and forth
to employment at Ross Distribution, 1707 Shearer Drive, Carlisle, Pennsylvania.
12, It is believed, and therefore averred, that Gregory Alan Cox is under a
10, It is believed, and therefore averred, that Gregory Alan Cox has no special
use for a vehicle, given that he has his own vehicle available and is unemployed,
11, It is believed, and therefore averred, that Gregory Alan Cox is not insured
to drive the Chevrolet S-10 Blazer.
driver's license suspension or that his license is about to be suspended,
WHEREFORE, for the above-referenced reasons, the Plaintiff respectfully
requests that a Rule be issued upon the Defendant to show cause why he should not
be found in indirect criminal contempt of the Protection From Abuse Order and
further why the special relief requested in the divorce action, in the form of an order
directing that he immediately return the Chevrolet S-10 Blazer, the tapes, the
children's clothing, and the warranty card to Plaintiff and that he refrain from
retrieving or in any manner using or gaining access to this Blazer in the future, should
not be entered,
Respectfully submitted,
s1Af(C'f\
Samuel W, Milkes, Esquire
JACOBSEN & MILKES
36 South Pitt Street
Carlisle, PA 17013
(717) 249.6427
Attorney No, 30130
I.~ ~ ~.,..
'.
I hereby verify that the statements made in the foregoing 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 unsworn falsification to authorities,
s-(A\\ ~
~ if,;7 .{f..
KIM NEE CO
(~)V
r
KIM R, COX,
rN TIm COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
crvrL ACTION - LAW
Plaint iff
v,
NO, 4017 crvrL 1993
GREG A, COX,
PROTECTION FROM ABUSE AND CUSTODY
Defendant
A.'lD NOW,
PROTECTrVE ORDER
this ~ of March, 1994, after a hearing in the above case
on February 9, 1994, and upon finding that the defendant, Greg A, Cox, abused the
plaint iff, the following order is entered:
1, The defendant, Greg A, Cox, is enjoined from physically abusing the
plaintiff, Kim R, Cox, or from placing her in fear of abuse,
2, The defendant is enjoined from having any direct or indirect contact
with the plaintiff including, but not limited to, telephone and written,
3, The defendant is ordered to refrain from harassing and stalking the
plaintiff and from harassing the plaintiff's family and her minor children.
4, The defendant is prohibited from entering the plaintiff's place of
employment or the day care facilities of her children.
5, The defendant is prohibited from removing, damaging, destroying or
selling any property owned by the plaintiff or jointly owned by the parties.
6, The defendant is excluded from the premises located at 416
Blosserville Road, Newville, CUmberland County, Pennsylvania.
7. The defendant is ordered to stay away from any residence the
plaintiff may in the future establish for herself.
8. The defendant shall have no visitation with the parties' children
pending the defendant's request for visitation through the court and the entry
of a subsequent Court Order.
~6'/-~ t ~t1.~_
ar Id E, Sheely, President Judge
9, The defendant's weapons shall remain in the custody of the CUmberland
County Siler I ff' s Department or the Pennsylvania State Pol ice pending further
Order of Court.
10, This Order shall remain in effect for a period of one year,
11. The Pennsylvania State Police and the Carlisle Police Department
shall be provided with certified copies of this Order by the plaintiff's attorney
and may enforce this Order by arrest for indirect criminal contempt without
warrant upon probable cause that this Order has been violated, whether or not the
violation Is committed in the presence of the police officer, rn the event that
an arrest Is made under this sect ion, the defendant shall be taken wi thout
unnecessary delay before the court that issued the order. When that court is
unavai lable, the defendant shall be taken before the appropriate district
justice, (23 P,S, 9 6113),
By the Court,
Joan carey
Attorney for Plaintiff
LF.OAL SERVICES, INC.
a rrvine Row
Carlisle, PA 17013
(717) 243-9400
TRue COpy FROM RECORD
In Testimony wher!!lli. I here unto set my hand
and ltle ~ cf :lala Court at Carlisle. Pa,
This <I day of ~' 111 Q<(
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, ~onotary
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MAY 16 m4cl.
KIM RENEE COX,
Plaintiff
IIN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
v
.
.
:NO. 1257 - CIVIL - 1994
.
.
GREGORY ALAN COX,
Defendant
.
.
:CIVIL ACTION - CUS'l'ODY
COURT ORDBR
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AND NOW, this /() day of hA-'f ' 1994, the Conciliator being
advised that the final Order for Custody was entered at the
Protection from Abuse Case at Docket No. 4017-1993, the Conciliator
relinquishes jurisdiction.
Hubert X. Gilroy, Esquir
Custody Conciliator
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTYPENNSYLVAN~
KIM RENEE COx,
Plaintiff
v,
NO, 94.1257 CML TERM II
IN DIVORCE
GREGORY ALAN COx,
Defendant
KIM R, COx,
Plaintiff
v.
NO, 93-4017 CML TERM
GREG A, COx,
Defendant
PROTECTION FROM ABUSE AND
CUSTODY
PRAECIPE
To the Prothonotary:
Please note my change of address effective immediately.
Respectfully submitted,
~~
BY: Samuel W, Milkes, Esquire
JACOBSEN & MILKES
52 East High Street
Carlisle, PA 17013
(717) 249-6427
Attorney No, 33130
Counsel for Plaintiff
Kim Renee Cox
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I CUMBERLAND COUNTY, PENNSYLVANIA
I
I NO. 1257 CIVIL 1994
I
I IN DIVORCE
I
v.
GREGORY ALAN COX,
Defendant
AMENDED CERTIFICATE OF SERVICE
I, Samuel W. Milkes, hereby certify that a certified copy of
the Order of Court Re: Motion For Appointment of Master and the
Motion For Appointment of Master were served upon the Defendant, by
placing the same for delivery with the United states Post Office,
by first class mail, postage prepaid, on March 'j, 1995, to the
Defendant's last known address of 416 Blosserville Road, Newville,
Pennsylvania, 17241, and I personally delivered a certified copy of
the aforementioned pleadings on February 24, 1995, at approximately
6:00 P.M. to the Defendant, at the Cumberland County Prison, llOl
,
Claremont Road, Carlisle, Pennsylvania.
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Respectfully submitted,
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'BY: Samuel W. 'Milkes, Esq.
JACOBSEN & MILKES
52 E. High Street
Carlisle, PA l70l3
(717) 249-6427
Attorney No. 30130
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KIM RENEE COX,
Plaintiff
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.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
:
vs. NO. 1257 CIVIL 1994
GREGORY ALAN COX,
Defendant IN DIVORCE
THE MASTER: Today is Thursday, June 8, 1995.
Present for a Master's hearing scheduled this date is the
Plaintiff, Kim Renee Cox and her counsel Samuel W. Milkes and
Gregory Alan Cox. Mr. Cox is not represented by counsel and
apparently, after discussions between the parties and Mr.
Milkes, the economic claims and the divorce issue have been
resolved and we are going to place an agreement on the record in
the presence of the parties.
A divorce complaint was filed on March 15, 1994,
raising grounds for divorce of irretrievable breakdown of the
marriage and the economic claims of equitable ~istribution,
alimony, and counsel fees and expenses.
Mr. Milkes has
prepared affidavits of consent which will be signed and dated by
the parties and filed with the prothonotary this date. The
divorce will then proceed under Section 3301(c) of the Domestic
Relations Code.
Mrs. Cox currently is residing at 416 Bloserville
Road, Newville, Pennsylvania. Mr. Cox has indicated in
discussions with the Master that he is living with various
friends but does not have the financial wherewithal to establish
a permanent residence at the present time.
However, Mr. Cox's
mailing address is the address of his parents at 441 North
College street, Carlisle, Pennsylvania.
The parties were married on April 21, 1989, and
separated December 23, 1993. The parties are the natural
parents of two children, Matthew, born August 7, 1990, and
Kayleigh Beth, born June 26, 1992. Mr. Cox is aware that the
Divorce Master does not deal with custody and support issues and
any matters relating to custody and support will be handled in a
separate proceeding either through the Domestic Relations Office
or the custody conciliators of Cumberland County.
Mr. Milkes.
MR. MILKES: with regard to equitable distribution
of the property 1 the parties have agreed to the following terms.
1. Kim Cox will assign title to the Windsor mobile home,
Vehicle Identification No. 6312251 to Gregory Cox and
present that title to him at the time he retrieves this
mobile home. This mobile home will become solely his
possession. Mr. ,Cox is to retrieve the mobile home
within two months of today's date at a time agreed upon
by his contacting Samuel Milkes, Attorney for Kim Cox.
If he does not retrieve the mobile home within two months
of today's date Kim Cox is at liberty to dispose of that
mobile home in any manner she sees fit.
2. Kim Cox is also to convey to Mr. Cox the title to the
1975 Chevrolet Blazer. This conveyance will occur as
quickly as possible although the parties do need to
either locate the title or to obtain a duplicate title to
that vehicle.
3. Gregory Cox will also be allowed to retrieve and will be
granted full ownership of various tools currently located
at Kim Cox's residence. These include a variety of
screwdrivers, wrenches, vise grips, as the parties have
previously discussed. They also include bolt cutters.
In addition, Mr. Cox will retrieve and maintain ownership
of his mother's crock pot, various swords, a leather
liner insert, a jewelry case with jewelry, various
Harley Davidson signs, and a 1978 Ford Van, all of which
are currently located Kim Cox's resience. Kim Cox will
cooperate in any fashion necessary with regard to
transfer of title of that vehicle. These items, again,
are to be retrieved by Mr. Cox making arrangements
through Kim Cox's attorney for an agreeable time to
retrieve the possession.
4. The remainder of the possessions whether considered
marital or nonmarital property will remain with the
respective party who is currently in possession of
those items. Those specifically to be retained by Kim
Cox are to include the king size water bed, the slate top
pool table, the washer and dryer, the camcorder, in
addition to other miscellaneous items of household and
personal property currently located at the double-wide
and other mobile homes on the property, and to include
the 1968 Honda motorcycle, the dining room set, and
specifically Mr. Cox will, on today's date, sign over
title to the 1986 Chevrolet S10 pickup truck which is
currently titled in the name of Greg A. and Kim R. Cox
solely into the name of Kim R. Cox. The same provision
with respect to the Pontiac mobile home date 1978
currently in the name of William L. Danner, Sr. but
having been assigned to Greg A. cox, and to include
conveyance of the deed on the property located at 416
Bloserville Road, Newville, Pennsylvania, currently
titled in the name of Gregory Allan Cox and Kim Renee Cox
as husband and wife,
5. Each party is to be responsible for all debts incurred
in their own name since the date of separation and each
party is to maintain payments on any debts currently
solely in their own name regardless of the date the debts
were incurred.
With reference to the PNC Bank repossession of the Ford
Bronco, Mr. Cox is to be responsible for any further
payments to be made on this repossessed vehicle.
6. Gregory Cox, to the extent this has not been completed
and accomplished, will resolve any outstanding
fines or costs connected with the 1982 Ford Bronco.
7. To the extent that any conveyance of title or other
formal conveyances need to occur after today's date in
order to effectuate this agreement, each of the parties
agrees to sign such documents as soon as they are made
available.
8. In consideration of the agreement Kim Renee Cox does
formally waive any claim to alimony, counsel fees, or
costs.
9. Except as herein otherwise provided, each party may
dispose of his or her property in any way and each
party hereby waives and relinquishes any and all rights
he or she may now have or hereafter acquire under the
present or future laws of any jurisdiction to share in
the property or the estate of the other as a result of
the marital relationship including without limitation,
dower, curtesy, statutory allowance, widow's allowance,
right of intestacy, right to take against the will
of the other, and right to act as administrator or
executor in the other's estate. Each will at the request
of the other execute, acknowledge, and deliver any and
all instruments which may be necessary or advisable to
carry into effect this mutual waiver and relinquishment
of all such interests, rights, and claims.
THE MASTER: Mr. Cox, have you been present during
the statement of the agreement on the record?
HR. COX: Yes.
THE MASTER: And do you understand the agreement
that's been placed on the record?
MR. COX: I think so.
THE MASTER: Are you willing to resolve the divorce
and economic issues in accordance with the agreement that has
been stated on the record?
MR. COX: Yes.
THE MASTER: Mrs. Cox, have you been present during
the statement of the agreement on the record?
,
.
MRS. COX: Yes.
THE MASTER: And do you understand the agreement as
stated on the record?
MRS. COX: Yes.
THE MASTER: And are you willing to settle all
outstanding issues with regard to the divorce and economic
claims in accordance with that agreement?
MRS. COX: Yes.
I acknowledge that I have read the above
stipulation and agreement, that I understand the terms of
settlement as set forth herein, and that by signing below I
intend to bind myself to the settlement as a contract obligating
myself to the terms of settlement and subjecting myself to the
methods and procedures of enforcement which may be imposed by
law and in particular Section 3105 of the Domestic Relations
Code.
WITNESS:
t.2~
Attorney for Plaintiff
DATE:
,
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K m Renee Cox
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Gr go y Alan Cox
KIM RENEE COX,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO.
1257 CIVIL 1994
GREGORY ALAN COX,
Defendant
IN DIVORCE
ORDER OF COURT
AND NOW, this J 2. ,- J{
day of
l~
, 1995,
the parties and counsel having entered into an agreement and
stipulation resolving the economic issues on June 8, 1995, the
date set for a Master's hearing, the agreement and stipulation
having been transcribed and subsequently signed by the parties
and counsel, the appointment of the Master is vacated, and
counsel can conclude the proceedings by the filing of a praecipe
to transmit the record with the affidavits of consent of the
parties so that a final decree in divorce can be entered.
BY THE COURT,
P.J.
cc: Samuel W. Milkes
Attorney for Plaintiff
Gregory Alan Cox
Pro Se
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