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Home My WebLink About02-4085JACK B. COOPER, SR., Plaintiff FAYE B. COOPER, : Defendant : : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW 2002 - CIVIL TERM IN DIVORCE NOTICE 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 in divome 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 fights important to you, including custody or visitation of your children. When the ground for divorce is indignities or/rretrievable 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 CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any heating or business before the court. You must attend the scheduled conference or hearing. JACK B. COOPER, SR., Plaintiff FAYE B. COOPER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAWz) 2002 - CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(c) OF ..THE DIVORCE CODE NOW comes the plaintiff, Jack B. Cooper, Sr., by his attorney, Marcus A. McKnight, III, Esquire, and files this complaint in divorce against defendant, Faye B. Cooper, representing as follows: 1. The plaintiff is Jack B. Cooper, Sr., an adult individual residing at 2215 Biglerville Road, #Lot 26, Gettysburg, Pennsylvania 17325 2. The defendant is Faye B. Cooper, an adult individual residing at 6280 Carlisle Pike, Lot #529, Mechanicsburg, Pennsylvania 17050. 3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divome. 4. The plaintiff and the defendant were married on December 5, 2001 in Leesburg, Virginia.. 5. There have been no prior actions ofdivome or for annulment between the parties. 6. There were no children bom to this marriage. 7. Pursuant to the Divome Code, Section 3301(c), the plaintiffavers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 8. The plaintiff avers that he has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. Date: August 26, 2002 Respectfully submitted, IRWIN, MsKNIGHT & HUGHES BY: ~~Esquire torney for lal~.~ff West Pomfret Professional Building 60 West Pomfret Street Carlisle, Pennsylvania 17013 -3222 (717) 249-2353 Supreme Court I.D. No. 25476 VERIFICATION The foregoing Complaint is based upon information which has been gathered by counsel and myself in the preparation of this action. I have read the statements made in this document and they are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unswom falsification to author/ties. cK .'coov , sR: Date: August 26, 2002 JACK B. COOPER, SR., Plaintiff FAYE B. COOPER, Defendant : IN THE COURT OF COMMON PLEAS OF : i CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : 2002 - CIVIL TERM .. IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that thc court require that my spouse and I participate in counseling. I understand that the court mamtams a hst of marriage counselors in thc Prothonotary's 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: August 26, 2002 JACK B. COOPER,SR. : IN THE COURT OF COMMON PLEAS OF Plaintiff Vm FAYE B. COOPER, Defendant : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 2002-4085 CIVIL TERM IN DIVORCE AFFID.4 I/IT OF SERVICE OF COMPLAINT PURSUANT TO P~4. R.C.P. RULF~ NO. 1920.4 (a)(1)(i) COMMONWEALTH OF PENNSYLVANIA : : SS: COUNTY OF CUMBERLAND : NOW, Marcus A. McKnight, llI, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the captioned action in divorce. 2. That a certified copy of the Complaint in Divorce was served upon the defendant on September 5, 2002, by certified, restricted delivery mail, addressed to her at 6280 Carlisle Pike, Lot 529, Mechanicsburg, Pennsylvania 17055, with Remm Receipt Number 7001 2510 0009 2828 3862. 3. That the said receipt for certified mail is signed and attached hereto and made a part hereof. I verify that the statements made in this affidavit are tree and false statements herein made are subject to the penalties of unsworn falsification to authorities Date: September 9, 2002 corre~. I understand that 04, relating to IVlARLIUiS A. McK~IlGI~T, III, ~ Attorney for Plain{~iff-~ Return Receipt Fee (Endomeme~t Required) I, '~ ~ ReetH~ed I (Endomement R '"'""°'~"- $ ~', S~ SE Postmark Here 62~0 ~ t~Tm~ [a)~ 529 ]~C~ ~A t7050 PS Form 3811, March 2001 2510 OOOq 21r28 3862 ~,_ _£-_'_ ~ FAYE B. COOPER, Vo JACK B. COOPER, Plaintiff, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO. 2002 - 4085 CIVIL ACTION - DIVORCE PRAECIPE TO ENTER APPEARANCE Kindly enter the appearance of Gerald $. Robinson, Esquire, on behalf of the Plaintiff in thc above-captioned matter. Date: September 13, 2002 Respectfully submitted, ROBINSON & GERALDO Attorney I.D. No. 27423 4407 North Front Street P.O. Box 5320 Harrisburg, PA 17110 (717) 232-8525