HomeMy WebLinkAbout01-03695
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IN THE COURT OF COMMON PLEAS
. OF CUMBERLAND COUNTY
STATE OF
PENNA.
.
.
.
YVONNE A. COLE,
Plaintiff
NO.36~15
2001
.
.
.
VERSUS
.
.
ISAAC M. COLE,
npfpnd"nr
.
.
.
DECREE IN
DIVORCE
.
.
.
AND NOW,
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Z<ld"Z-, IT IS ORDERED AND
DECREED THAT
Yvonne A. Cole
, PLAINTIFF,
.
AND
Isaac M. Cole
, DEFENDANT,
.
.
.
.
.
.
.
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
.
.
.
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By THE COURT: J .
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PROTHONOTARY .
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YVONNE A. COLE,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DNORCE
ISAAC M. COLE,
Defendant
: NO. 01-3695
CIVIL TERM
To the Prothonotary:
Please transmit the record, together with the following information, to the court for entry of
PRAECIPE TO TRANSMIT RECORD
a divorce decree:
1. Grounds for divorce: Irre1rievable breakdown under Section 3301(c) of the Divorce
Code.
2. Date and manner of service of the complaint: Served on the Defendant by the Erie
County Sheriffs Department. Service was complete upon receipt by Isaac M. Cole, July 26, 2001.
3. Date of execution of the Affidavit of Consent required by S 3301 ( c) of the Divorce
Code:. by Plaintiff - December, 7 2002; by Defendant - November 19, 2001
4. Related claims pending: NONE
5. Date Plaintiff's Waiver of Notice was filed with the Prothonotary: January 2, 2002.
Date Defendant's Waiver of Notice was filed with the Prothonotary: November 27,2001.
Date ,-tll'6/D"L
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FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
717-243-2968
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YVONNE A. COLE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
ISAAC M. COLE,
Defendant
3& 1 S'-
: NO. 2001- CIVIL TERM
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.
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 HA VB 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
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 hearing
or business before the court. You must attend the scheduled conference or hearing.
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YVONNE A. COLE,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
ISAAC M. COLE,
Defendant
~ NO. 200l-3t..q.~IVIL TERM
COMPLAINT
The plaintiff, Yvonne A Cole, by her attorneys, the Family Law Clinic, sets forth the
following causes of action:
DNORCE UNDER 23 Pa.C.S, SECTION 3301 (c). 3301 (d) AND 3301(a)(5)
OF THE DNORCE CODE
I. Plaintiff is Yvonne A Cole, who ctuTently resides at 279 Plaza Drive, Boiling Springs,
Cumberland County, Pennsylvania, 17007, since December 2000.
2. Defendant is Isaac M, Cole, who ctuTently is incarcerated at Albion State Correctional
Facility, prisoner number EM8505, 10745 Route 18, Albion, Pennsylvania 16475-0001, since April
2001.
3. Plaintiff has been a bona fide resident of the Commonwealth for at least six months
immediately previous to the filing of this Complaint.
4, Plaintiff and Defendantwere married on February 25, 1995, in Winston-Salem, North
Carolina.
S. Plaintiff and Defendant have lived separate and apart since February, 2000.
6. There have been no prior actions of divorce or annulment between the parties.
7. The marriage is irretrievably broken.
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8. Plaintiff has been advised that counseling is available and that plaintiff may have the
right to request that the court require the parties to participate in counseling.
9. Plaintiff avers that Defendant, in violation of the laws of Pennsylvania has been
sentenced to imprisonment for a term of two or more years upon conviction of having committed a
cnme.
10. On October 24, 2000, Defendant was sentenced to imprisonment for a term of eighteen
months to four years, to run consecutively with a term of fifteen months to three years. A certified
copy of the sentence is attached as Exhibit A.
11. Plaintiff is an innocent and injured spouse.
WHEREFORE, plaintiff requests the court to enter a decree of divorce dissolving the
marnage.
Date~ 10, 2cf) I
~
Michelle L. An on
Certified Legal Intern
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TH S M. PLACE 'V
ROBERT E. RAINS
TERI L. HENNING
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
(717) 243-2968
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VERIFlCATION
I verify that the statements made in the foregoing Complaint are true and correct. I
understand making any false statement would subject me to the penalties of 18 Pa.C.S. ~ 4904,
relating to unsworn falsification to authorities.
Date: --6L.l3:12J
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CHARUE:' (2fAGcitiAii1Ar'i'lIDASSAULT
BY VEHICLE WHILE DUI
(3)ACCIDENTS INVOLVING
DEATH OR E'ERSONAL INJURY
(4)ACCIDENTS INVOLVING
DEATH OR PERSONAL INJURY WHILE
NOT PROPERLY LICENSED
(5) DUI
(6)OPERATION OF VEHICLE
WITHOUT OFFICIAL CERTIFICATE OF
INSPECTION (SUMMARY)
(7) IMMEDIATE NOTICE OF
ACCIDENT TO POLICE DEPARTMENT
(SUMMARY)
(8)DUTY TO GIVE
INFORMATION AND RENDER AID
(SUMMARY)
(9)RECKLESS DRIVING
(SUMMARY)
(10)DRIVING VEHICLE AT
SAFE SPEED (SUMMARY)
(ll)DRIVING ON ROADWAYS
LANED FOR TRAFFIC (SUMMARY)
(12)DUS (SUMMARY)
(13)REGISTRATION AND
CERTIFICATE OF TITLE REQUIRED ~
(SUMMARY) ? ~
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AFFIANT: TPR 0 JASON CARBA:qOHi [?i
ISAAC MATTHEW COLE
OTN: E923389-5
IN RE: SENTENCING
ORDER OF COURT
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AND NOW, this 24th day of October, 2000, the
defendant, Isaac Matthew Cole, having previously been found
guilty after a jury trial, and now appearing for sentence
together with private counsel, Karl Rominger, Esquire, the court
being in receipt of a pre-sentence investigation report,
Sentence of the court on Count 13, Registration and
Certification of Title Required, a summary offense, is that the
defendant pay the costs of prosecution and a fine of $75.00.
Sentence of the court on Count 12, Driving Under
Suspension, ~a summary offense, is that the defendant pay the
costs of prosecution, a fine of $200.00, a CAT Fund surcharge of
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$30.00, and an EMS assessment of $10.00.
CO~E
COMMONWEALTH V. ISAAC
Sentence of the court on Count 11, Driving on
Roadways Laned for Traffic, a summary offense, is that the
defendant pay the costs of prosecution, a fine of $25.00, a CAT
Fund surcharge of $30.00, and an EMS assessment of $10.00.
Sentence of the court on Count 10, Driving Vehicle at
Safe Speed, a summary offense, is that the defendant pay the
costs of prosecution, a fine of $25.00, a CAT Fund surcharge of
$30.00, and an EMS assessment of $10.00.
Sentence of the court on Count 9, Reckless Driving, a
summary offense, is that the defendant pay the costs of
prosecution, a fine of $200.00, together with a CAT Fund
surcharge of $30.00, and an EMS assessment of $10.00.
Sentence of the court on Count 8, Duty to Give
Information and Render Aid, a summary offense, is that the
defendant pay the costs of prosecution and a fine of $25.00.
I
Sentence of the court on Count 7, Immediate Notice of
Accident to Police Department, a summary offense, is that the
defendant pay the costs of prosecution and a fine of $25.00.
Sentence of the court on Count 6, Operation of
vehicle Without Official Certificate of Inspection, a summary
offense, is that the defendant pay the costs of prosecution and
a fine of $25.00.
Sentence of the court on Count 2, Aggravated Assault
by Vehicle While Driving under the Influence, is that the
defendant pay the costs of prosecution, make restitution in the
amounts as set forth in the pre-sentence investigation report,
said restitution to be ongoing, subject to the defendant's right
to request a hearing in that matter, that he pay a CAT Fund
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COMMO~EALTH v. Ij~AAC WI.'I'THEW COLE
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surcharge of $30.00, an EMS assessment of $10.00, and undergo
imprisonment in a State Correctional Institution for a period of
not less than one and a half nor more than four years.
Sentence of the court on Count 3, Accidents
Involving Death or Personal Injury, and Count 4, Accidents
Involving Death or Personal Injury While Not Properly Licensed,
said sentences to run concurrent one with the other, but
consecutive to the sentence at Count 2, is that the defendant
pay the costs of prosecution, on each count a CAT Fund surcharge
of $30.00, and an EMS assessment of $10.00, and undergo
imprisonment in a State Correctional Institution for a period of
not less than fifteen months nor more than three years.
Sentence of the court on a count of Driving under the
Influence is that the defendant pay the costs of prosecution, a
fine of $300.00, a CAT Fund surcharge of $50.00, an EMS
assessment of $10.00, and undergo imprisonment in a State
Correctional Institution for a period of not less than three nor
more than twenty-~our months. This sentence to run concurrent
.
with the other sentences herein imposed.
The sentences herein imposed shall run consecutive to
any sentence that the defendant is currently serving,
A. TRUE COPY FROM RECORO By the Court,
In Testimony Whofere~fd' I ~~~':a~~~~: p":.nd
and the seal sal J'2 I 0 /
Th'IS qt" day of ,2 ~ A #....
Hess, J.
Jonathan Birbeck, Esquire
Assistant District Attorney
Q)piumailedonJ Q' Z(~19n
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Kar Rom1nger, squ1re
For the Defendant
probation
Victim-Witness Office
Sheriff, SCIC, CCP :bg
Copies delivered on l D-lJ Q -().J
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PLAINT REINSTATED
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YVONNE A. COLE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
ISAAC M. COLE,
Defendant
: NO. 01-3695 CIVIL TERM
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under ~~ 3301 (c), 3301 (d) and 3301(a)(5) of the Divorce
Code was filed on June 15,2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
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. ~4904, relating to unsworn
falsification to authorities.
Date /J.j7/~1
REC~IVED DEe 2 1 208t
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YVONNE 1\.. COLE,
Plaintiff
* IN THE COU~T OF COMMON PLEI\.S
OF CUMBERLI\.ND COUNTY,PI\.
*
vs.
* CIVIL I\.CTION - LI\.W
* DIVORCE
ISAI\.C M. COLE,
Defendant
* NO: 2001-36g~
*
I\.FFIDAVIT OF CONSENT
1. A complaint in divorce was file on June 15, 2001,
and I was served with the Complaint by Erie County Sheriff's
Department on July 19, 2001.
2. The marriage of Plaintiff and Defendant is
irretrievably broken and ninety (gO) days have elapsed from
the filing and service of the Complaint.
3. I consent to the entry of a final decree in divorce
after service of notice of intention to request entry of the
decree or waiver thereof.
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.I\.. ~ 4g04
relating to unsworn falsification to authorities.
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DEFENDI\.NT
Isaac M. Cole
ID # EM 8505
SCI I\.lbion
10745 ~oute 18
I\.lbion, PI\. 1n475-0002
DATE: November 19, 2001
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CERTIFICATE OF SERVICE
I, Isaac M. Cole, hereby certify that a true and correct
copy of the Affidavit of Consent to divorce has been served
this ~ day of November, 2001, by First Class mail on:
1. Prothonotary
Cumberland County
One Courthouse Square
Carlisle, PA 17013-3387
2. Family Law Clinic (Representing Plaintiff)
Michelle L. Anderson (Intern)
45 North Pitt Street
Carlisle, PA 17013
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DEFENDANT
Isaac M. Cole
EM 8505 SCI-Albion
10745 Route 18
Albion, PA 16475-0002
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YVONNE A. COLE,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE
ISAAC M. COLE,
Defendant
: NO. 01-3695
CIVIL TERM
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
113301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. 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.
3. I understand that I will not be divorced until a divorce decree is entered by the
Court and that a copy of the decree will be sent to me immediately after it is filed with the
prothonotary .
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. ~4904 relating to
unsworn falsification to authorities.
Date
1tJ,/7jOJ
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Yvo e A. Cole, laintlf
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YVONNE A. COLE, * IN TBE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY, PA
*
*
vs. CIVIL ACTION - LAW
*
DIVORCE
ISAAC M. COLE, *
Defendant NO: 2001-36')5
*
WAIVER OF NOTICE OF INT,ENTION TO REQUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce
without notice.
2. 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.
3. I understand that I will not be divorced until a
divorce decree is entered by the Court and a copy of the
decree will be sent to me immediately after it is filed with
the prothonotary.
I verify that the statements made herein are true and
correct. I understand that false statements herein are made
subject to the penalties of 18Pa.C.S.A. ~ 4904 relating to
unsworn falsification to authorities.
DATE: November 19, 2001
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DEFENDANT
Isaac M. Cole
EM 8505 SCI-Albion
10745 Route 18
Albion, PA 16475-0002
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CERTIFICATE OF SERVICE
I, Isaac M. Cole, hereby certify that a true and correct
copy of the Waiver of Notice of Intention to Request Entry
of a Divorce Under Section 3301(c) has been served this 19
day of November, 2001, by First Class mail on:
1. Prothonotary
Cumberland County
One Courthouse Square
Carlise, PA 17013-3387
2. Family Law Clinic (Representing Plaintiff)
Michelle L. Anderson
45 North Pitt street
Carlisle, PA 17013
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DEFENDANT
Isaac M. Cole
EM 8505 SCI-Albion
10745 Route 18
Albion, PA 16475-0002
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SHERIFF'S RETURN - OUT OF COUNTY
. ,. ;;::J;;SE NO: 2001-03695 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COLE YVONNE A
VS
COLE ISAAC M
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
COLE ISAAC M
but was unable to locate Him
in his bailiwick. He therefore
deputized the sheriff of ERIE
County, Pennsylvania, to
serve the within COMPLAINT - DIVORCE
on July
26th , 2001 , this office was in receipt of the
attached return from ERIE
Sheriff's Costs:
Docketing
Out of County
Surcharge
18.00
9.00
10.00
.00
.00
37.00
00/00/0000
s~
R. omas Kline ~
Sheriff of Cumberland County
Sworn and subscribed to before me
this ~I&,; day Of()"J~
.2oc>1 A.D.
(~L ,Q. 7hJ/L. s ~
Prothonotary
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SHERIFF'S RETURN - REGULAR
GASE NO: 2001-03695 '1'
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF ERIE
YVONNE A COLE
VS
ISAAC M COLE
DEPUTY SCOTT STEVA
, Deputy Sheriff of ERIE
County, Pennsylvania, who being duly sworn according to law,
says, the within REINSTATED NOTICE/COMPLAI was served upon
COLE ISAAC M #EM8505
the
DEFENDANT
, at 1439:00 Hour, on the 19th day of July
, 2001
at SCI ALBION
10745 RT 18
ALBION, PA 16475
by handing to
ISAAC M, COLE
a true andpttested copy of REINSTATED NOTICE/COMPLAI together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
.00
.00
.00
.00
.00
.00
So Answers:
h lluAALL'
Bo Merski, Sheriff of
Ul,~
Deputy Sheriff
00/00/0000
Erie County
By
Sworn and Subscribed to before
me this r5(.:j~ay of rr;
~V7J / A.D.
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Not Notarial Seal
Barbarll o. rumer, NoIary Pub!lC
En., Erle County 7.......
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In The Court of Common Pleas of Cumberland County, Pennsylvania
Yvonne A. Cole
VS.
Isaac M. Cole
SERVE: Isaac M. Cole
No.
01
3695 civ; 1
Now,
July 16, 2001
, I, SHERIFF OF CUMBERLAND COUNTY, P A, do
hereby deputize the Sheriff of
Erie
County to execute this Writ, this
deputation being made at the request and risk ofthe Plaintiff.
~~;~
Sheriff of Cum berland County, P A
Affidavit of Service
Now,
,20_, at
o'clock
M. served the
within
upon
at
by handing to
a
copy of the original
and made known to
the contents thereof.
So answers,
Sheriff of
County, PA
Sworn and subscribed before
me this day of , 20_
COSTS
SERVICE
MILEAGE
AFFIDA VIT
$
$
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YVONNE A. COLE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION-LAW
IN DIVORCE
ISAAC M. COLE,
Defendant
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c:
: 3ft,q5' -o~
: NO. 2001- CIVIL TERMS2~;-'
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PRAECIPE TO PROCEED IN ~ ~j
FORMA PAUPERIS ~ ~
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To the Prothonotm)':
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Kindly allow Yvonne A. Cole, Plaintiff, to proceed in forma pauperis.
I, Michelle L. Anderson, Certified Legal Intern in the Family Law Clinic, for the party
proceeding in forma pauperis, certif'y that I believe the party is unable to pay the costs and that I am
providing free legal service to the party. The party's affidavit showing inability to pay the costs of
litigation is attached hereto.
; ) /, .b"A1(~ ftJJL-
~derso
Certified Legal Intern
~,~~V
~ E. RAINS
THOMAS M. PLACE
TERI L. HENNING
Supervising Attorneys
DateJ.uu Iq 2ml
.
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
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YVONNE A. COLE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CNIL ACTION - LAW
: IN DNORCE
ISAAC M. COLE,
Defendant
: NO. 01-
CNIL TERM
AFFIDAVIT SUPPORTING PRAECIPE FOR LEAVE
TO PROCEED IN FORMA PAUPERIS
1. I am the Plaintiff in the above matter and because of my financial condition am
unable to pay the fees 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 oflitigation.
3. I represent that the information below relating to my ability to pay the fees and costs
is true and correct.
(a) Name: Yvonne A. Cole
Address: 279 Plaza Drive, Boiling Springs, P A 17007
Social Security No.: 241-57-7427
(b) Employment
If you are presently employed, state
Employer: Diversco
Address: 2001 Harrisburg Pike, Carlisle, Pennsylvania 17013
Salary or wages per month: $8.25 per hour@ 14 hours per week
Type of work: Janitorial
If you are presently unemployed, state
Date oflast employment:
Salary or wages per month:
Type of work:
(c) Other income within the past twelve months:
Job Center: Clerical Aide; $5.15 per hour at 20 hours per week
Tressler Lutheran Church: Assistant Teacher; $5/15 per hour at 20 hours per
week
AFFES / PX Building: Cashier; $6.50 per hour at 35 to 40 hours per week
Business or profession:
Other self-employment:
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Interest:
Dividends:
Pension and annuities:
Social security benefits:
Support payments: Order for $175 per month; receiving $10 per month
Disability payments:
Unemployment compensation and supplemental benefits:
Workman's compensation:
Public Assistance: $279 bi-weekly (cash assistance); $279 per month (food
stamps)
(d) Other contributions to household support
(Wife)(Husband) Name: None
If your (wife)(husband) is employed, state
Employer:
Salary or wages per month:
Type of work:
Contributions from children:
Contributions from parents:
(e) Property owned
Cash:
Checking account: No
Savings account: No
Certificates of deposit:
Real estate (including home):
Motor vehicle:
Cost, Amount Owed $
Stocks; bonds:
(f) Debts and obligations
Mortgage:
Rent: $22 per month (Subsidized housing)
Loans:
Other: Food: $150 per month
Electric: $60 per month
Phone: $50 per month
Fines: $50 per month
Medical Expenses:
Persons dependent upon you for support
(Wife)(Husband) Name:
Children, if any:
Name:
Nathaniel Combs
Shayna Cole
Micaela Cole
Loren Cole
Age:
9
2 years II months
2 years
5 months
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Other persons:
Name:
Relationship:
4. 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.
5. 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. 4904, relating to unsworn
falsification to authorities.
Date~p-13- 01
YVo!n~~itier' ~
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YVONNE A. COLE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
ISAAC M. COLE,
Defendant
: NO. 01-3695
CIVIL TERM
CERTIFICATE OF SERVICE
I, Gina M. Carnes, hereby certify that I am serving a true and correct copy of the
Plaintiffs Affidavit of Consent and Waiver of Notice on Isaac M. Cole at Number- EM-805,
Unit/Side E-A 39, 10745, Route 18, Albion, PA 16475-0002, by depositing a copy ofthe same in
the United States mail, this 2nd day of January 2, 2002.
Date:t! s!O;J-
Gina M. Cames
Certified Legal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
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YVONNE A. COLE,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
: CIVIL ACTION - LAW
: IN DIVORCE
ISAAC M. COLE,
Defendant
: NO. 01-3695
CIVIL TERM
CERTIFICATE OF SERVICE
I, Bryon R. Kaster, hereby certify that I served a true and correct copy of the Praecipe to
Transmit Record and Divorce Information Sheet for Plaintiff, Yvonne A. Cole, on Isaac M. Cole at,
Number EM-8505, Unit Side, 10745, Route 18, Albion, PA 16475-002, by depositing a copy of the
same in the United states mail, this ~ day of April, 2002.
Date: 1/~!o "'-
~Z~'
Bry . Kaster
Ce . fied Legal Intern
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
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YVONNE A. COLE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION-LAW
IN DIVORCE
ISAAC M. COLE,
Defendant
: NO. 2001- 3&tsNlL TERM
PRAECIPE TO PROCEED IN
FORMA PAUPERIS
To the Prothonotary:
Kindly allow Yvonne A. Cole, Plaintiff, to proceed in forma pauperis.
I, Michelle L. Anderson, Certified Legal Intern in the Family Law Clinic, for the party
proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that 1 am
providing free legal service to the party. The party's affidavit showing inability to pay the costs of
litigation is attached hereto.
Date J..uu I q 'leol
~.f~
Certified Legal Intern J
~RA~ tv
THOMAS M. PLACE
TERI L. HENNING
Supervising Attorneys
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
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YVONNE A. COLE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
; NO. 01-3t.9t CIVIL TERM
ISAAC M. COLE,
Defendant
AFFIDAVIT SUPPORTING PRAECIPE FOR LEAVE
TO PROCEED IN FORMA PAUPERIS
1. I am the Plaintiff in the above matter and because of my financial condition am
unable to pay the fees 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.
(a) Name: Yvonne A. Cole
Address: 279 Plaza Drive, Boiling Springs, PA 17007
Social Security No.: 241-57-7427
(b) Employment
If you are presently employed, state
Employer: Diversco
Address: 2001 Harrisburg Pike, Carlisle, Pennsylvania 17013
Salary or wages per month: $8.25 per hour@ 14 hours per week
Type of work: Janitorial
If you are presently unemployed, state
Date oflast employment:
Salary or wages per month:
Type of work:
(c) Other income within the past twelve months:
Job Center: Clerical Aide; $5.15 per hour at 20 hours per week
Tressler Lutheran Church: Assistant Teacher; $5/15 per hour at 20 hours per
week
AFFES / PX Building: Cashier; $6.50 per hour at 35 to 40 hours per week
Business or profession:
Other self-employment:
.'
".:
..
.., ,'" 'j~~'--~'-
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Interest:
Pividends:
Pension and annuities:
Social security benefits:
Support payments: Order for $175 per month; receiving $10 per month
Disability payments:
Unemployment compensation and supplemental benefits:
Workman's compensation:
Public Assistance: $279 bi-weekly (cash assistance); $279 per month (food
stamps)
(d) Other contributions to household support
(Wife)(Husband) Name: None
If your (wife)(husband) is employed, state
Employer:
Salary or wages per month:
Type of work:
Contributions from children:
Contributions from parents:
( e) Property owned
Cash:
Checking account: No
Savings account: No
Certificates of deposit:
Real estate (including home):
Motor vehicle:
Cost, Amount Owed $
Stocks; bonds:
(f) Debts and obligations
Mortgage:
Rent: $22 per month (Subsidized housing)
Loans:
Other: Food: $150 per month
Electric: $60 per month
Phone: $50 per month
Fines: $50 per month
Medical Expenses:
Persons dependent upon you for support
(Wife)(Husband) Name:
Children, if any:
Name:
Nathaniel Combs
Shayna Cole
Micaela Cole
Loren Cole
Age:
9
2 years 11 months
2 years
5 months
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Other persons:
Name:
Relationship:
4. I understand that I have a continuing obligation to inform the court of improvement
in my fmancial circumstances which would permit me to pay the costs incurred herein.
5. 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. 4904, relating to unsworn
falsification to authorities.
Date_lrI3- 01
l ~Y\~ A. Co.QQ.
Yvonne . Cole, Petitioner
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YVONNE A. COLE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: IN DIVORCE
ISAAC M. COLE,
Defendant
: NO. 2001-3695
CML TERM
PRAECIPE TO REINSTATE COMPLAINT
To the Prothonotary:
Please reinstate the above-captioned complaint.
July 13, 2001
/JJJMiLcf ()~
VMichelle L. Anderson /
Certified Legal Intern
7 ~
~~~~--
T' SM. PLAC
ROBERT E. RAINS
TERI L. HENNING
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA.17013
717-243-2968