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HomeMy WebLinkAbout09-6554ANDREW TODD COULSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. _ 655q Ci v i I Term STEPHANIE M. COULSON, Defendant IN DIVORCE NOTICE TO DEFEND 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 at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAI D IS, /Ft0W El34 kIkVDSAY SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA Carol J. Lin a , §quire Attorney I d,44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff ANDREW TODD COULSON, Plaintiff V. STEPHANIE M. COULSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Todd Coulson, an adult individual, residing at 339 Barnstable Road, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Stephanie Coulson, an adult individual, residing at 911 Sadler Court, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 2, 1991 in Carlisle, FLOWER & LINDSAY 26 West High Street Carlisle, PA Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that he has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. • WHEREFORE, Plaintiff requests entry of a divorce decree in his favor in accordance with §3301 of the Pennsylvania Divorce Code. SAIDIS, FLOWER & LINQSAY I, Carol J. Linds quire Attorney Id. 6jW 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff FLOWER & LENDSM 26 West High Street Carlisle, PA VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. e5??? 2?? Andrew Todd Coulson Date: ! U ' l/ ? FLOWER & LINDSAY 26 West High Street Carlisle, PA OF n - 2 SEP 31 PW $338.50 P D AT1`f co a(o347 R?T* a31 a4 I L ANDREW TODD COULSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v• CIVIL ACTION -LAW NO. 09-6554 STEPHANIE M. COULSON, : Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Carol J. Lindsay, Esquire, being duly sworn according to law, hereby deposes and says that on October 13, 2009, I served a true and correct copy of the Complaint in Divorce upon Defendant, by mailing the document to her address at 911 Sadler Court, Carlisle, PA 17013, by Certified U.S. Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient, Stephanie M. Coulson. Respectfully submitted, SAIDIS, LINDS~ nrcortxersanuw 26 West High Street Carlisle, PA Dated: ~ ( (I ~~ I SAIDIS, FLOWER & L~DSAY / l CarbYJ" Lindsa ;°Esq it Attorney Id. 44 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff ^ Complete Items 1, 2, and 3, Also t~mplete item 4 ff Restricted Delivery Is desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mailpiece, or on the front H space permits. t . ArdCle Addressed to: alt ~~~LEr C~©u~~ ~Qrlrs/c~ ~f ~ / ~o ~3 A Signet ` X __ ^ Ac 8. Received by ( ) C. Date of D. is deuvery address difrerent fern Item , ~ D Yes If YES, delivery add bebw: l~"No 3. Type Mall ^ Express Mall Registered ~ ReWm Receipt for MerGhandbe ^ Insured Mail ^ C.O.D. 4: Ifri161~d GeNrrry~ 1Brtra ~ z Article Number 7 0 01 2 510 0 0 0 9 1017 8 9 4 7 (Tiansterlrom servke febeq SAIDIS, FLOWER Sz LINDSAY ~rmnn~ys•,~•uw 26 West High Screec Carlisle, PA PS Form 3811, Fetxuery 2004 Domestic Return Receipt to2se~-a2---n--~sw r, ~i~~? ~'~~tr 7 ~ ~: ~ ~~ ~U r' 1~t .19 ~ (•i I ~ ~ ~.'~.. L ... ~ ...... .., 1~i t ~... ... ... -. ANDREW TODD COULSON, PLAINTIFF V. STEPHANIE M. COULSON, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-6554 CIVIL IN RE: PLAINTIFF'S MOTION TO COMPEL ORDER OF COURT AND NOW, this 11th day of March, 2010, upon consideration of the Plaintiff's Motion to Compel Discovery, IT IS HEREBY ORDERED AND DIRECTED that the Defendant shall provide the information requested in the Plaintiff's Request for Production of Documents on or before April 16, 2010. IT IS FURTHER ORDERED AND DIRECTED that should the Defendant fail to provide the requested information, a hearing on this matter will be held on Wednesday, May 12, 2010, at 3:00 p.m. in Courtroom No. 2 of the Cumberland County Courthouse, Carlisle, Pennsylvania, to determine the imposition of sanctions to include contempt of court. ,jL(arol J. Lindsay, Esquire Attorney for Plaintiff .,~stephanie Coulson, Defendant 911 Sadler Court Carlisle, PA 17013 bas J N GJ ._.' C.-f ~ ~ --~ rn~ n, ~.. ~ 3 ~, ;~ `,w; c_= na ~~~, .. -~ cn ~, ~ ~ By the Court, ANDREW TODD COULSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW NO. 09-6554 STEPHANIE M. COULSON, Defendant IN DIVORCE NOTICE TO DEFEND 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 at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 YO.U CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS SULLlVAN SAIDIS, I~~OWER ~ LINDSAY 26 West High Street Cazlisle, PA ,.~-, ~ ~`• _ ' a ~i yiI{ i~ Il t9 ~!9 ~d ~ ~n~C I CZ Carol J.1in ;Esquire Attorney 1 44 93 26 West Hig Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff 39.S~~d~ a ~G Duo ANDREW TODD COULSON, Plaintiff v. STEPHANIE M. COULSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 09-6554 IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(cl or (dl OF THE DIVORCE CODE 1. The Plaintiff is Todd Coulson, an adult individual, residing at 399 Barnstable Road, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Stephanie Coulson, an adult individual, residing at 911 Sadler Court, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 2, 1991 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the SAIDIS, )FZOWEIt Sz LINDSAY 2G West High Street Cazlisle, PA parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that he has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in his favor in accordance with §3301 of the Pennsylvania Divorce Code. COUNT II EQUITABLE DISTRIBUTION 8. The averments in paragraphs 1 through 7 are incorporated hereto as if fully set forth herein. 9. During their marriage, the parties have acquired certain property, both personal and real. WHEREFORE, Plaintiff requests this Court to equitably divide the marital property. SAIDIS SUI,L!-VAN LAW Carol J. Lindsay ~ Attorney Id. 44 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS, F7AWER ~ LINDSAY 26 West High Street Cazlisle, PA VERIFICATION I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsifications to authorities. Andrew Todd Coulson Date: f~OR~ER'6z I.IlVDSAY ~ w~ x~t- s~ CaeiGk, PA CERTIFICATE OF SERVICE On the a}~ day of ~~,~ , 2010, I, Carol J. Lindsay, Esquire, of the law firm of SAIDIS, FLOWER 8t LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individual, via first class mail, postage prepaid, addressed as follows: Sandra L. Meilton, Esquire Daley, Zucker & Gingrich, LLC 1029 Scenery Drive Harrisburg, PA 17109 SAIDIS, FLOWER 8t LINDSAY Carol J. Lindsay, Esquire Supreme Court ID No. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 F~ RIS,S~ LINDSAY 26 West High Street Carlisle, PA t^? .r V fiii1I70i biJ 201il SE tto 29 IFt {' .tt Sandra L. Meilton, Esquire Daley Zucker Meilton Miner & Gingrich, LLC ^ R E R 1 _ $ 11 ; `;' 1029 Scenery Drive' Harrisburg, PA 17109 (717) 657-4795 smei ltona,dzmmelaw. corn ANDREW TODD COULSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 09-6554 Civil Term STEPHANIE M. COULSON, Defendant IN DIVORCE PETITION FOR ALIMONY, ALIMONY PENDENTE LITE, COUNSEL FEES AND EXPENSES AND NOW comes Defendant, Stephanie M. Coulson, by and through her counsel, Sandra L. Meilton, Esquire, of Daley Zucker Meilton Miner & Gingrich, LLC, and files the within Petition for Alimony, Alimony Pendente Lite, Counsel Fees and Expenses: COUNT I: CLAIM FOR ALIMONY UNDER THE DIVORCE CODE 1. Defendant has inadequate means of support for herself except as provided for by Plaintiff. 2. Defendant is employed as a substitute teacher for several Cumberland County school districts. She earns approximately $400 to $600 per month. 3. Plaintiff is employed as a consultant with Oracle Corporation. He has substantial income sufficient to meet his needs and Defendant's needs. Co?,a? COUNT II: CLAIM FOR ALIMONY PENDENTE LITE, COUNSEL FEES AND EXPENSES UNDER THE DIVORCE CODE 4. Defendant does not have sufficient funds to support herself and pay counsel fees and expenses incidental to this action. Plaintiff is full well and able to pay Defendant Alimony Pendente Lite, counsel fees and expenses incidental to this divorce action. WHEREFORE, Defendant requests the Court to: A. Direct the Plaintiff to pay Alimony to the Defendant; B. Direct the Plaintiff to pay Alimony Pendente Lite and Defendant's counsel fees and the costs of this proceeding; and C. Grant such further relief as the Court may determine equitable and just. Respectfully submitted, DALEY ZUCKER MEILTON MINER & GINGRICH, LLC B I andra L ilt (I.D. #3256) Lindsay Gingrich Maclay (I.D. #87954) 1029 Scenery Drive Harrisburg, PA 17109 Date: September 28, 2010 ATTORNEYS FOR DEFENDANT VERIFICATION I, Stephanie M. Coulson, verify that the statements made in the attached document 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. Stephanie M. Coulson Dated: q,16,1} CERTIFICATE OF SERVICE AND NOW, this 28th day of September, 2010, I, Gloria M. Rine, Paralegal to Sandra L. Meilton, Esquire, for the firm of Daley Zucker Meilton Miner & Gingrich, LLC, hereby certify that I have this day served a copy of the within document, by mailing same by first class mail, postage prepaid, addressed as follows: Carol J. Lindsay, Esquire 26 West High Street Carlisle, PA 17013 4 G oria M. Rine Sandra L. Meilton, Esquire Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive, Harrisburg, PA 17109 (717) 657-4795 smeilton _dzmmgfaw.com ~^; ~~IL~^FC~ry-O~~IC~. V +~ ~ 6 e ~ C` ~1 tJ C a`3 ~"3 P.~ t~'"~ 3 i1 !`+ `,f .~:er;. ~r: ~ ~ i~l~' OCT 22 ~~1 #0~ ~' ANDREW TODD COULSON, Plaintiff v. STEPHANIE M. COULSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW No. 09-6554 Civil Term IN DIVORCE INVENTORY AND APPRAISEMENT OF STEPHANIE M. COULSON I, Stephanie M. Coulson, file the following inventory and appraisement of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. I verify that the statements made in this inventory and appraisement 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. Steph nie M. Coulson, Defendant ASSETS OF PARTIES Defendant marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. If an item has been appraised, a copy of the appraisal report is attached. (X) 1. Real property (X) 2. Motor vehicles (X) 3. Stocks, bonds, securities and options () 4. Certificates of deposit {X) 5. Checking accounts, cash (X) 6. Savings accounts, money market and savings certificates () 7. Contents of safe deposit boxes () 8. Trusts (X) 9. Life Insurance policies {indicate face value, cash surrender value and current beneficiaries) () 10. Annuities () 11. Gifts () 12. Inheritances () 13. Patents, copyrights, inventions, royalties () 14. Personal property outside the home () 15. Businesses (list all owners, including percentage of ownership, and officer/director positions held by a party with company) () 16. Employment termination benefits -severance pay, workman's compensation claim/award () 17. Profit sharing plans () 18. Pension plans (indicate employee contribution and date plan vests) (X) 19. Retirement plans, Individual Retirement Accounts () 20. Disability payments () 21. Litigation claims (matured and unmatured) () 22. Military/V.A. benefits () 23. Education benefits () 24. Debts due, including loans, mortgages held (X) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) (X) 26. Other MARITAL PROPERTY Defendant lists all marital prope-ty 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: Item Number Description of Property Names of all Owners 1. 911 Sadler Court Joint Carlisle, PA 17013 2. 2001 Chrysler Town and Country Joint 2. 2000 BMW Husband 3. Scottrade Oracle Corporation Stock Husband (168 shares as of 6130/08) 5. Members First Federal Credit Union Joint Checking account (Acct. #33853) 6. Members First Federal Credit Union Wife Savings account (Acct. #54612) 6. Fidelity Investment Account Husband (Acct. #XXX-XX8746) 9. Marital portion of ING life insurance policy Husband 19. Fidelity (Oracle) 401(K) Husband 19. Scottrade IRA Husband 25. Household goods Joint 26. Marriott Reward Points Husband NON-MARITAL PROPERTY Defendant lists all marital property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: Name of Reason for Item Number Description of Property all Owners Exclusion 3. Scottrade (Oracle stock) Husband Post-separation post-separation activity 6. Members First Federal Credit Wife Post-separation Union Savings account (post- separation activity) 9. ING life insurance policy Husband Premarital (premarital portion) 19. Retirement accounts Husband Post-separation (contributions and increases in value) 26. Smith Barney account Wife Account opened after date of separation PROPERTY TRANSFERRED Defendant lists all property in which either or both spouses had a legal or equitable interest individually or with any other person and which has been transferred within the preceding three years: Item Number Description of Property Names of all Owners 2. 1997 Toyota Camry. This vehicle received hail Joint damage. Kemper Insurance Company has "totaled" the vehicle and taken possession of it. The parties are to receive $2,600 from the insurance company and have agreed to use said funds for the purchase of a vehicle for their daughter, Laura. LIABILITIES OF PARTIES Defendant lists all liabilities of either or both spouses alone or with any person as of the date action was commenced: Name of Names of Description of Debt Creditor All Debtors Mortgage against Members First Joint Marital residence Federal Credit Union Credit Card Bank of America (Acct. #2623) Wife Credit Card Visa (Acct. #8537) Husband Credit Card Members First (#2763) Wife Credit Card L.L. Bean (#6804) Wife CERTIFICATE OF SERVICE AND NOW, this 22nd day of October, 2010, I, Gloria M. Rine, Paralegal to Sandra L. Meilton, Esquire, for the firm of Daley Zucker Meilton Miner & Gingrich, LLC, hereby certify that I have, this day, served the within Inventory and Appraisement on Plaintiff, by hand delivery, addressed to: Carol J. Lindsay, Esquire Saides Sullivan Law 26 West High Street Carlisle, PA 17013 (hand delivered) Gloria .Rine c ~ Sandra L. Meilton, Esquire Daley Zucker Meilton Miner & Gingrich, LLC 1029 Scenery Drive, Harrisburg, PA 17109 (717) b57-4795 smeilton ,dzmmglaw.com FI~.~Q-[~= Fl~~ J 1` i r .~.~~k ANDREW TODD COULSON, Plaintiff v. STEPHANIE M. COULSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.09-6554 Civil Term IN DIVORCE INCOME AND EXPENSE STATEMENT Attached hereto is the Income and Expense Statement of Defendant submitted pursuant to Pa. R.C.P. No. 1920.31. Sandra L. Meilton Attorney for Defendant INCOME AND EXPENSE STATEMENT OF STEPHANIE M. COULSON INCOME Employer: NOTE: Defendant works at a substitute teacher at Bible Address: Baptist School; Carlisle Area School District, South Type of Work: Middleton School District and Big Spring School District Payroll Number: Pay Period (weekly, biweekly, etc.): Gross Pay per Pay Period: $400 to $600 each month Itemized Payroll Deductions: Federal Withholdin $ Social Securi Local Wa e Tax State Income Tax Retirement Savin s Bonds Credit Union Life Insurance Health Insurance Other (s eci ) Net Pay per Pay Period: (see attached ay stubs) $270.11 (lthPr Tnrnme~ Weekl Monthl Yearl Interest/Dividends $ $ $ Pension/Annuit Social Securi Rents/Royalties Ex ense Account Gifts Unemployment Comp. Workmen's Com . Child & Spousal Su ort 3,000.00 Total $ $3,000.00 $ TOTAL INCOME $3,450.00 (approximately) BIG SPRING SD ~ 45 MOUNT ROCK ROAD ~ NEWVII;LE, PA 17241 COULSON, STEPHANIE M 00093552 10/14/2010 0.00 0.00 .3.00 0.00 Single 1~ 0.00 285.00 285.00 Pay YTD ~. 285.00 764 00 0.00 I. 67 4.13 8.75 0.23 ;. ,; O. OG 47.12 it . Q`2 ~ 23 .34 . 60 ~y - Pay YTD ~~m ""~~~8.28''~ <~~ - '~~4.~6 ~ 2r:38 ~ '0.00 - ~ ,:0.00 ~- ~~~~4 00 12.16 57.02 0.00 10.00 . 0.00 Earnings Statement BIBLE BAPTIST CHURCH 201 W MAIN STREET SHIREMANSTOWN, PA i70i 1 'Taxable Marital Status: Married Exemptions/Allowances; Federal: 0 PA: N/A Period Ending: 10/09(2010 Pay Date: 10/15/2010 00000000009 STEPHANIE M COULSON 911 SADLER COURT CARLISLE PA 17013 J~ ~ Social Security Number: XXX-XX-3552 Earnings rate Flours this" period yoar to date Other Benefits and Other 50.00 314.00 Information this period" ", toter to date :etss:>~!'.~:.?~.'>~><;,=:>s:`:::::<:>'s`:<><::::>:. ~:~~#~0 922.00 401 K Max Eli C 50.00 Deductions Statuto Social Security Tax -3.10 57.16 Medicare Tax -0 , 73 ~ 13.37 PA State Income Tax -1.54 28.31 Carlisle Asd Income Tax -0.80 14.75 Other lrstb -2.00 10.00 Save -41.83 Your federal taxable wages this period are $50.00 ,~,,, ,., _, _ ,,,. _ w w 2 w - - F- ;r. y : ,. ... ., t ~. ._ ,~ ..,.,, ~... ~~' . _ ,, :, , ,. -. i ,; ~% _, ,_ :: BIB~~ BAPTIST CHURi~I-( , Advice numbee, 0000010009; ~ / ~~ ., 2Q1 1N~JIAAIN STJ:iEE7' , P,ay date-` ~ 1,0/15/2010,., t ~~ ,,. , ~~ SH1RE11IIAN~TOV~lIV, PA 70~ t 1 ' _ - y ,, _ , . _ _ _ - ~ ~ - .. _ _ .. ~,5 - Deposlfed`fo the~account of° _ _ ~-account numtyer ~ `transit ABA amount ' ~ ~ STEPHANIE~LA~.COULSQN . ,.. _ _ _ ~c4612 x xxx xxxx $41 .83 .. - \ t~ ` ~ r > , ~ . ~~~ - _ _ =- , N4N- NEGOTIABLE , ; ,~ _. __ ~ ~~ ,. i - ~raa rittir.;i~~ial nncu~ii(cair,in;: nni , c%ri~iri, ~ ni -~__ ~; .,,~ ~.~-r _.c c. ~.. ,~ n.n°~. n r _. ~.~ .'~:~~ ,~~ ~ ...~..~.. ..~.. .:~.,.. , .,.,.~...~ - ~ Crl 5C Cr7 z r~ ~b ~ ~ b br~ a p~ ~ x o d d~ ~ ~ ~ ba o x o ~ O o ~ ~. C7 ~ ~ ~ ~ o ~ ~ o ~, c~ ~ ~ ~, ~ Z ~ ~ ~ ~ ~ ~ ~ ~ n ~ ~ ~ ~ to ~ ~' H z ~ ~, ~. ~ ~ ~ C ... ~ r ,, ~ ~ o O C ~ ~ a ~ ~ ~ o. rn ~ p ~ z ~~ "~ --~ r ~ ~ o y~ " ~' ~ ~ b '~ ~ ~ ~-- O z * °° ~ ° o ~ W ~ N vi N ~ '~ N ~ .P "~ ~ O ~ 'O z o x o r o ,,,~ o w ~ o o ~ o ~ o O ~ o 0 0 0 0 0 ~ ~~ ~ ~~ ~~ ~~"~~ ~~a ~~ o ~ ~ ~~o o ~a~ * ~ ~ i ffi O O O N ~• G a. N C n O 7S" ~ n ~' v' ~ "~ ~ ~ ~ N ~ ..~ W O ~ ~ ~ O p ~ ~ ~ ~ ~ ~ U~Q v ~ UQ ~ ~ ~ ~ C W `DO _ `C Q ~ ~'~~ "~ ~~ ~ ~ ~ C -Oi N ~ ~ ~ (D [D O O "~ ~ U4~ N n J v~ n ti A~ ~ r-h P~ O a' `~ O c7" ~ D ~' 'd ~ .. ~ ~ ~. O "a C .-. ~ ~' --.. ~ ~ '"'' o ~ a~ ~ 6s ~-- co ~ ~ ~~ ~ ~' ~ o ° ~' o -~ a~oao~~ ~ ~ ~ ~ ~ ~o ~~ oo ~ ~'+ as ~~ t'~~~ ~ C""~~ o t~"~~o ~ n ~ a n ~ ~ ~ ~ ~ ~ ~ ~ Z ~' ~ ~ A' ~ v~ ~ ~ ~ ~ O. ~. V1 ~ p O N ~O _~ wCrn cNn~awa ooo~ oo w v W N O N O O O Q x ,~ ~~ ~' ~' ~~ ~ a ~~ ~~ o ~~~~ ~ ~ ~ ~ ,~. o '~ ~ a ~' o ~~ z o d a a ~' ~. O O ~I ~~ ~_ b w ~. 0 z x ~~ ~ '~ a ~ ~ ~ d ~ ~ ~ ' ~ ~ y y i-r O z ~o v, ~o ov w~ Ov0 r~-+ ~ ~, ~ ~ irr~~ O c!i O O o d N ~ 0 ~, + ~. ~ 0 `~ ~~ o 0 ~~ ~ ~ ,~ ~ ~ ~~~ ~ ~ ono z -~ o ~ ~- ~ o ~ ° ~'~~ ~ ., . o ~ ~`co ~ ~ y ~ ~ ~ ~ ~~ ~~~ O PROPERTY OWNED Descri tion Value Husband Wife Joint Checking See Inventory and Accounts A raisement Savings See Inventory and Accounts A raisement Credit Union See Inventory and A raisement StocksBonds See Inventory and A raisement Real Estate See Inventory and A raisement Other See Inventory and A raisement TOTAL INSURANCE Com an Polic No. Husband Wife Child Hospital Blue Cross Other United Healthcare I.D. #828252778 X X X Medical Other United Healthcare I.D. #828252778 X X X Other Health/Accident Disabilit Income Dental Other Vision X X X I understand that the statements made herein are subject to the penalties of 18 Pa. C.S. § 49Q4 related to unsworn falsification to authorities. _ ~ ~~ Stephanie M. Coulson I verify that I have reviewed this form with my client and to the best of my knowledge the answers herein are true and correct. andra L. Meilton Attorney for Defendant • CERTIFICATE OF SERVICE AND NOW, this 22nd day of October, 2010, I, Gloria M. Rine, Paralegal to Sandra L. Menton, Esquire, for the firm, Daley Zucker Menton Miner & Gingrich, LLC., hereby certify that I have, this day, served the within document on counsel for Plaintiff, by hand delivery, addressed to: Carol J. Lindsay, Esquire Saidis Sullivan Law 26 West High Street Carlisle, PA 17013 s ~~ G1 is M. Rine �? i.-o- )F F 1 C Andrew Todd Coulson H j5 O vs SEP 26 PM 1, CaseNo. 09-6554 Civil Term CUMBERLAND COUNTY Stephanie M. Coulson PENNSYLVANIA Statement of Intention to Proceed To the Court: Stephanie M. Coulson intends to proceed with the above captioned matter. Print Name Sandra L. Meilton Sign Name ' Date: 9/25/13 Attorney for Defendant, Stephanie M. Coulson Explanatory Comment The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit comment. I.Rule of civil Procedure New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2 is tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting local rules. This rule was promulgated in response to the decision of the Supreme Court in Shop v.Eagle, 551 Pa. 360,710 A.2d 1104 (1998) in which the court held that"prejudice to the defendant as a result of delay in prosecution is required before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 1901." Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The general policy of the prompt disposition of matters set forth in subdivision(a)of that rule continues to be applicable. II Inactive Cases The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the court. After giving notice of intent to terminate an action for inactivity,the course of the procedure is with the parties. If the parties do not wish to pursue the case, they will take no action and"the Prothonotary shall enter an order as of course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter,he or she will file a notice of intention to proceed and the action shall continue. a. Where the action has been terminated If the action is terminated when a party believes that it should not have been terminated, that party may proceed under Rule230(d)for relief from the order of termination. An example of such an occurrence might be the termination of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file the notice of intention to proceed. The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of the entry of the order of termination on the docket,subdivision(d)(2)provides that the court must grant the petition and reinstate the action. If the petition is filed later than the thirty-day period, subdivision(d)(3)requires that the plaintiff must make a showing to the court that the petition was promptly filed and that there is a reasonable explanation or legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of termination on the docket and for the failure to file the petition within the thirty-day period under subdivision(d)(2). B. Where the action has not been terminated An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue the remedy of a common law non pros which exits independently of termination under Rule 230.2.