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Home My WebLink About00-06935 t "" .' , "' '-, '~~;i CHRISTOPHER G. COLE, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: OD- 1s,9JS G'ulT-~ DJENEVA COULUBALI, 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, PA. 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 PA 17013 (717) 249-3166 -'. ....L 11", "_ .~ , , CHRISTOPHER G. COLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: 60- (,,935 ~~ vs, DJENEVA COULUBALI, Defendant IN DIVORCE COMPLAINT UNDER 1i3301(d) OF THE DIVORCE CODE 1. Plaintiff is CHRISTOPHER Q, COLE, who currently resides at 502 Fourth Street, New Cumberland, County of Dauphin, Pennsylvania, since 1999. 2. Defendant is DJENEVA COULUBALI, who currently resides at an address unknown to Plaintiff. Defendant's last known address was in Silver Springs, Maryland, in 1992. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint, 4. The plaintiff and defendant were married in February, 1992, in Alexandria, County of Alexandria, Virginia. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken, '..... ~' ~,iJ!,,", Oiji "'~~~ ~ I 7. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 8. Neither party is a member of the Armed Forces of the United States of America or any of its allies. 9. Plaintiff requests the court to enter a decree of divorce. 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, S 4904 relating to unsworn falsification to authorities. {}-__1s- <<- C STOPHER G. COLE, PLAINTIFF Date: ~z~~ CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 ATTORNEY FOR PLAINTIFF ...L~ ~GL1;,: - <- ..~ ~~ - ii~",,~' CHRISTOPHER G. COLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. NUMBER: DJENEVA COULUBALI, Defendant IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER lii330l/dl OF THE DIVORCE CODE 1. The parties to this action separated in February, 1992, 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. Section 4904 relating to unsworn falsification to authorities, ~gC C RISTOPHER Q, COLE, PLAINTIFF Date: /{) ~ 0 ( , .- ,~ ~-'"- - .,-... ~ ~, l~'" CHRISTOPHER G. COLE, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: OV' G. ~ 3 S' {3.,;:J z;: DJENEVA COULUBALI, Defendant IN DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE I, Plaintiff herein, do hereby depose and say that I am advised and believe that the above named Defendant is not presently in the active military service of the United States of America and I aver that the Defendant is not a member of the Army of the United States, United States Navy, the Marine Corps, or the Coast Guard, and is not an officer of the Public Health Service detailed by proper authority for duty with the Army or Navy; nor is Defendant engaged in any military or Navy units covered by the Soldiers and Sailors Civil Relief Act of 1940 and designated therein as military service; nor has Defendant, to the best of my knowledge, enlisted in the military service covered by this act. This Affidavit is made under the provisions of the Soldiers and Sailors Civil Relief Act of 1940. 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. Section 4904, relating to unsworn falsification to authorities. DATii4DO cgQ CHRISTOPHER G. COLE, PLAINTIFF ~ ,~" "~, ~~,., -'~'''''"'''~~~-' " "'~ , ~'lj:r"'="rCE O~: T'. ,.. :c,!'r:-Tf1,RY no' ()"T In v .IL \ _ [):"I 2" "ie ~ i: ". ; ... CU,i;:;;:;"",,,,. iV, "I"'Y I~i,-:..J-;:",i ,"'J_, l-","...)Uj~ i PEN0;S\i'LVAi~I;:' ~" - ~......,~,"I,~.t:*j;l!~~~~~(t'~i'1~~~~~"". I~"'~ "~".,~~ -'-" ,_ I, . ~= l " """1" ,~';;:'" -I "j , ,'F,d,,'~,r"i" ~ .... CHRISTOPHER G. COLE : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. DJENEV A COULUBALI : NO. 2000-6935 CNIL TERM ORDER OF COURT AND NOW, this J ~~ day of OCTOBER, 2000, a hearing on Plaintiffs Petition to Serve the Complaint in Divorce by Publication is scheduled for Wednesday, October 25.2000, at 2'30 p m By the Court, Charles E. Petrie, Esquire For the Plaintiff l;:;~~ Jt) - Jq -00 RX~ "" .... "','oO' ""~" . , ,~~ ~'-'" " ~ ,'-~ ~,. ,,~',.- ""'~~!- ,~,n[Hl~'iMII1~".," , '--'""'!^ " " ~~- _ <,' '-;-" " ~ ~_ ~ >~o~~, ~. ,,"-,-,,' ~ H., n C' ...n(\' \f;~' ~:..~ '~:~: ~.~" ;~~~, ,,:'-, ,-, .,.M'~, .~,,~:'~. '-2, ,-" '8.. '".~:lo co :-....) .< ,~d ".~..,,"""- , ^ ~," ~- , NOV 1 3 2000 CHARLES E. PETRIE ATTORNEY AT LAW KELLYP.ROBERTS PARALEGAL 3528 BRISBAN STREET HARRISBURG. PENNSYLVANIA 17111 /';17-561'1930AX 717-561-4121 E~r;.1amlfa~~ . WEBSITE, attypetrie.com November 13, 2000 The Honorable Edward J. Guido Judge of the Court of Common Pleas Cumberland County, Pennsylvania Cumberland County Courthouse Carlisle, Pennsylvania 17013 Re: Christopher Cole v. Djeneva Coulubali -"""""""""""""''''i'=~PfO- "00-"""9' '3' "'''''"t:<;7TT~~''='' lj.:':,':::,:':,:::,::':':(:':?:::::'i::::::::::'::' j:::,~:9:,__:::::4.. ':, ':', ,::"~'Y::,, ':', : ";;;.i::,:,~,:~;:::,y',,:,l,,~,dEfifSlYl ':::::::::,::::::2::}:::,:::'jj;-;' Dear Judge Guido Thank you for your telephone call last week to clarify your requirements in the above divorce matter. As you may recall, Mr. Cole testified at the hearing that his wife told him that she was enrolled in the nursing progranl at George Washington University. I have enclosed a letter from the registrar stating that no such student was enrolled at George Washington University, nor do they have a nursing progranl. Mr. Cole stands by his testimony because this was the information that she provided him. Also enclosed is a copy of the marriage register from Alexandria, Virginia. Ms. Coulubali listed a Washington, D.C., address as her residence. She does not live there currently. Please let me know if there are further steps that we should take to try to find her or if you are satisfied that we have done enough and you will sign the Order for publication. As for the procedure, there are two references in the Rules of Court that have been interpreted to permit publication and/ or waiver of service: L Rule 1920.1 (b) states "Except as otherwise provided in this chapter, the procedure in the action shall be in accordance with the rules relating to a civil action." Rule 430 authorizes service by publication. j '~" "I " =,,,,,"~"<,,,",,;,;~,, . November 13, 2000 The Honorable Edward J. Guido page 2 2. Rule 1930.4 (a)(3) states "Persons who may serve. Original process in all domestic relations matters may be served by the sheriff or a competent adult: , .. (3) or pursuant to special order of court." 3. Rule 1920.4 states ". . . (c) In an action under Section 3301(d) of the Divorce Code, if no appearance has been entered and plaintiff avers that defendant cannot be located after diligent search, the court may waive service of the affidavit." 4. Rule 1920.42 (e) states "Notice of intention to request entry of divorce decree shall not be required prior to entry of a divorce decree (2) under !33301(d) where the court finds that no appearance has been entered on defendant's behalf and that defendant cannot be located after diligent search." We are asking for an order to publish the Complaint and Affidavit in Silver Springs, Maryland, in a newspaper of general circulation. We ask that you waive any requirement to publish the notice to request entry of divorce decree. Your attention to this matter is appreciated. Very truly yours ~c~ Charles E. Petrie CEP jkpr Enclosures In. ~~ " ,:.. "T , , The _.c~r2:e was~~n um~~TONl~Y OFFICE OF THE REGISTRAR November 2,2000 Charles E. Petrie Attorney at Law 3528 Brisban Stre~t Harrisburg, P A 17111 Dear Mr, Petrie: I" , , " -'~ 'I.',,' I am responding to your letter of October 30, 2000 in which you requested information regarding Djeneva Cou1ubali, After a thorough search of our records, we were unable to find a student record for this individual. You mentioned in your letter that Ms, Cou1ubali was in the Nursing program and The George Washington University does not have a Nursing program, perhaps she attended Georgetown University, Sincerely, ~~ Helen Klepac Associate Registrar ~ ", ~. , ' .., ' l' -"'''' .",'".',J',l,,:;] >"-,,Y':,'f ;~" ::,'''' , ,~, \;".,,,-/,:', <c:",.: ,. "- '.:ff> ';: :;.i t ~}::., ~-':.--.c; .,"-.! '. .,' .J".';:" '; ';,,': " , (' i'< \ ~ -, "." !'i, ",,' I ,t ':,. 2121 I STREET, N,W. . SUITE 101 . WASHINGTON, DC 20052 . (202) 994-4900 .~; : OCT-31-2000 09:37 . , . $"&!!U -QM<""..,....,. TOOf'fICW6: - ....... -...- - ItIium IIIIh _ - ... - '"27,1 .........,..,. -- i _aa.,..., .... QIta-of'" i n n q J! I I J J I I , '"'-~, , HARRISBURG STOR :E CO 71777407\/4 COMMONWIALTH OF YlRGllllIA .....RlAGI........ ',,'~.L =.. ~~~~ -'~'~~,< P,01/01 QAClJIt 72/221 ~ _ClTVOA CF AlexjSndria 323 ,.~ '''', ,-, 'lori' Chrt.stopher Glellll Cole allOTiCFlII'""f_Ctv,lW' ~,PUlCEOI' '_"'_'_1 December 17 191,2' seaeh ettE! .~_ 1llC_...., 7._$'Ill1llll..t..lJi"" P rllt ,_0_0 IlL _ AESIOENCE:,8'mEEI'RT._ 226 Co6t Hollow bad f' A~"'lf __ .... I ltd. I ) York ' PIlilll8}"lvan1a 2._ 20 Il.IIACE Caucaa:l.an -.. - ~~~~: .. """-""- I", Dill.bur I 10. HME OIF M'ItCA W:U1iaa F. Cole t t.ll,.lu. MAfiN Duara KeCUellU1 - U"'ot5+1 12; _ ""- ,NWllIiN- I ,._, ,"") ,-, f'tII) D eneba Coul:l.ba1 13:. AGE 14.-QQE~,tIIR1"Ht"""'" DIy; ....J 26 ...... JUIl8 10, 1966 ...rw:a l7'lk~'ItI/,-- Black Plrat.. ",fiiOIJCI'f1ClN Semenl8rY.'~I, CaIIetI .'UlItML :S1MtJ OR'RT. ~CWIt,.,.., ~./ ""Of$+' 4 __, I 6040 14th Stree,t N.W. 11124 .. ern OR1UWr4 .200, (" 1 ~""..............J ,lilOd. lOA . I Wash ton' I 1l1str1ct of (:01Ul11b14 2', ,01'_ 22.FUU._'_OF_R KrS6011lllCoultbal !f4rle tou1ae ,Har1ko IJ9EN8I!O'IllPERfORM_ "" "IHGlEUC'" . pewqi~=,' _~' IlAlllE March I, 1'193 , 1.JCInIeI,i.... SIal) 'Dava NJtiIif'ilUMMi 0. __",CIMlot co.nt__ "j 'l'~~ 2Oll'YJlEOF """MOllY CNl1.lO IlEUCllOU& [J ,2&;~E vJ:1tIiOtlt.y~ 1993 2S~ It.'f:IBl8rir" - _,JOIN&\> ABCMi,__"'_ONMllIo7i"""'AT PLACESl'EClFIEl), 01'. C""O.Q~""'~;~~~.~. ~ APPOINT BE ALEXANDRIA 1987 f................... ,_..__.....CiocoOl"""".., _CF - -..""'. (iNIy,or cwtIrl .-.. _ OF I3FPICIONT CULLSW 8. JONES, JR. 111 S. PATUeR STRBBT,AL8XANDRIA, VIRGINIA 22314-3826 '..-rO'lOufel'tiirftJ/rj r""Otf/tlt!tnl r.....J ACOPYTES~ ~ DfPU1Y CI8I TOTAL P.01 ~. . ,~ 0'_; . -" "-'~' .' " . -'".-', k n ,-'",,', ,"'- , j -~--'- ..i{ '. .~J CHRISTOPHER G. COLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. DJENEVA COULUBALI, Defendant NUMBER: 00- '" 'i'lS CIVIL TERM IN DIVORCE AND NOW, this ORDER JA dayof ~ ,2000, upon consideration of the within Motion and Plaintiffs Affidavit of Investigation, it is hereby Ordered that Plaintiff may serve Defendant with the Complaint in Divorce and Plaintiffs Affidavit Under Section 3301 (d) of the Domestic Relations Code by publishing said documents in a newspaper of general <;.,'LI/fL ~p~ N' ~ circulation in M9RtgilHi~ry 03tlUty, Maryland. Pursuant to Pennsylvania Civil Procedure Rule 1920.42(e)(2), it shall not be necessary to file or publish a Notice of Intention to Request Entry of Divorce decree. JUDGE !.~~ J J.-~-OO RXS 'c." ",,0.' ,,""CC",,~, 1'0' c o"eel " ".,- '-,c-, ;>1< 0' -~',~ ';,,;.. .",-',j',,, 'j,:' CHRISTOPHER G. COLE, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NUMBER: 00- t:: 9 3~ CIVIL TERM DJENEVA COULUBALI, Defendant IN DNORCE MOTION NOW COMES the Plaintiff, CHRISTOPHER G. COLE, by his attorney, Charles E. Petrie, and respectfully represents as follows: 1. That Plaintiff is CHRISTOPHER G. COLE, an adult individual currently residing at 502 Fourth Street, New Cumberland, County of Cumberland, Pennsylvania, 2. That Defendant is DJENEVA COULUBALI, an adult individual whose last known address was in Silver Springs, County of Montgomery, Maryland. 3. That Plaintiff has not seen or heard from Defendant since February, 1992. 4. That Plaintiff has executed an Affidavit of Investigation setting forth the steps taken by Plaintiff in his attempt to locate Defendant. WHEREFORE, Plaintiff respectfully requests that Your Honorable Court enter an Order permitting Plaintiff to serve Defendant with the Complaint in Divorce and Plaintiffs Affidavit Under Section 3301(d) of the Domestic ~ " ,~ ~ ~,~~-""' .~ "-," ~. ;:q CD-i"\;:'Y'C: I I,.",,;, .~I, r,VI_ OF Tt,: ?F:CTHONOTARY 00 DEe -I AM 9108 CUMBERlN~D COUNTY PENNSYLVANIA i'__'c,'Y ''-;'~;~;i "" .'.,., " _ ,~ I, ,,' 0_ ~'<,,< . . , ~<'~'.-'-"-~ "".,. ..,.,' ,,",^,"-'- I'" ,.;;,.." ~P~;~_"d~_;d " --" r'l c'''-,,__.',"'..- " ,. ~k-.> "" " .'~ Relations Code to obtain a Decree in Divorce by publishing said documents in a newspaper of general circulation in Montgomery County, Maryland. Respectfully submitted, ~4~t!~ CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff O~ '-. '.'<'-'- '<,. I " I': - ,~, ^ .' ~ __~,' c_ -' I, -' - ",;;; - ~ ',",,",,','- ',^~, ,'- . '<~l CHRISTOPHER G. COLE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. NUMBER: 98-3351 DJENEVA COULUBALI, Defendant IN DIVORCE AFFIDAVIT OF INVESTIGATION CHRISTOPHER G. COLE, duly sworn, hereby deposes and says: 1. That he is the Plaintiff in the above-captioned divorce case. 2. That he was married to the Defendant, DJENEVA COULUBALI, in February, 1992. 3. That the parties separated during the month of February, 1992. 4. That the last known residence of the Defendant known to Plaintiff was in Silver Springs, County of Montgomery, Maryland. Plaintiff last saw Defendant at this address in February, 1992, 5. That Plaintiff has inquired into Defendant's whereabouts by examining the Silver Springs, Maryland, telephone directory; by contacting the Maryland Motor Vehicle Bureau and by contacting the Montgomery County Voter Registration Bureau. 6. Plaintiff does not know of any relatives of Defendant who might have information concerning Defendant's present whereabouts. 7. That Plaintiff heard that Defendant may have relocated to France. <.I ~C" , , ""~, ", , '"",, '" o;.r 'Ii I , :1 ",,~---~,- . , ,'- , " , "' ~'"ia1 8. That Plaintiff has no other information concerning the whereabouts of the Defendant. Respectfully submitted, €'~~-~~~ CHARLES E. PETRIE 3528 Brisban Street Harrisburg, PA 17111 (717) 561-1939 Attorney for Plaintiff ,"- , (""-",k,',, , " ':"':'<'__i;,I,~.- ,. '. '~,'" ,-",J',' -;:: :~ COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I verify that the statements in the foregoing Motion and Affidavit 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. (~'r() D DAT Cg<2_ CHRISTOPHER G. COLE "'l I t, ":..cJ ~, o. 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