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Home My WebLink About04-3520 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 04- '3')~o c.J\i~1 MICHELLE E. COLEMAN, PLAINTIFF DAVID A. COLEMAN, DEFENDANT : CML ACTION - LAW : IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, 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 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, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION 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 Phone: (717) 249-3166 da~ Attorney for Plaintiff MICHELLE E. COLEMAN, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. DAVID A. COLEMAN, DEFENDANT : CNIL ACTION - LAW : IN DNORCE NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, One Courthouse Square, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. lJlCmdi ~.I ~A P8~~~ ;;d 1/ikulIJtfrJ v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA : NO. ot{- 35'..7.0 MICHELLE E. COLEMAN, PLAINTIFF DAVID A. COLEMAN, DEFENDANT : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Michelle E. Coleman, who currently resides at 900 Drexel Hills Boulevard, New Cumberland, Cumberland County, Pennsylvania 17070. 2. Defendant is David A. Coleman, who currently resides at 205 South Second Street, Wormleysburg, Cumberland County, Pennsylvania 17043. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 23, 1995, in Mechanicsburg, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 8. The marriage is irretrievably broken. 9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. The parties to this action have been separated since June of2004. 10. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, the Plaintiff requests the Court to enter a Decree in divorce dissolving the marriage between the Plaintiff and Defendant. Date ~ /7/ :<O~ "" JAMES, SMITH, DIETTERICK & CONNELLY B~ d/fk Susan M. Kadel, Esquire Attorney for Plaintiff Post Office Box 650 Hershey, PA 17033 (717) 533-3280 P A J.D. No. 44837 VERIFICATION I, Michelle E. Coleman, 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. Section 4904, relating to unsworn falsification to authorities. Date: 1 flff/~cf v1YUch&l~ Michelle E. Coleman (~ ~..) \; '* 0 - ~ -0 () :t::: . ~: cg '2 -, VI ~ ~ w z5 -.c f"'<:... 'tl " ~ .--.01 (, . \~ ;.1 C:. MICHELLE E. COLEMAN, PLAINTIFF v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA ; NO. OLf-'?{;ll c,iA DAVID A. COLEMAN, DEFENDANT : CNIL ACTION - LAW : IN DNORCE AFFIDAVIT OF SERVICE; Susan M. Kadel, Esquire, being duly sworn according to law, deposes and says that she is the attorney for Plaintiff in the above-captioned action; that on July 27, 2004, she mailed a true and correct copy of the Complaint in Divorce to the Defendant, at the Defendant's last known address, by certified mail, postage prepaid, return receipt requested and evidenced by return receipt card No. 7003-2260-0005-6552_8490; that on July 29, 2004, the Complaint was received at the Defendant's last known address as evidenced by attached Acceptance of Service form, with Defendant's signature affixed thereon; and that the facts set forth in the within Affidavit are true and correct to the best of her information and belief. JAMES, SMITH, DJrEITERICK & CONNELLY Date 8- 6H-{5lJ By:> A~7~CJ ~ Esquire Attorney for Plaintiff Post Office Box 650 Hershey, P A 17033 (717) 533-3280 PA J.D. No. 44837 Sworn ~~ subscribed before-.E. this g" ~ay of -AU9U5T ' 2004 NOlIlriaJ Seal Amy 1. Shugar.i, NOIlIry Public Camp Hm Bani, Cumberland County My Comurissiun Expires Apr. 1 R, 2006 · Complete items 1, 2, and 3. Also complete item 4 if 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 if space permits. 1. Article Addressed to: -' D. is delivery addn3SS different from item 1? 0 es If YES, enter dnlivery address below: 0 No lb\l1a Co/erno () 2r1P S:WhSeWrds;-. ~ormJeVbt~ tPA- 17(:) 3~lce Type Certified Mall~ExPress Mail o egistered Return Receipt for Merchandise o Insured Mail C.O.D. ""- Restricted Delivery? (Extra Fee) ~es 7003 2260 0005 6552 8490 2. Article Number (Transfer from service label) PS Form 3811 , August 2001 Domestic Return Receipt 102595-01-M-2509 CJ a- .:r- oO U.S. Postal SerVice,,, CERTIFIED MAIL RECEIPT (Domestic Mall Only, No Insurance Coverage ProVided) ~ OFFICI ~ ~6 c.tifted~ CJ CJ ~""= CJ -Oel!verYFeo rtl 101dot_.___) rtJ rn CJ CJ f'- " USE ~--"'.,.::..-.... /'."\ :'4", 0[J?~\~;J?i)~ -, 1'\' \" ;.V ....,_~. '~, ,. ''->'\ \-~" 1>)/ ~~c., "h '\j'''''/ ".._~_.~-,--", 8 ...~ 0 "'" <;';::l 11 ?:: ..- ." FD "'"' :1:'.." rrlT1 c:::: Z;:rJ en !"11p -'~ -on' .c._ C~) (j) , ~(JO ~c5 i~') j ~.,O -"""-1', ~R ::r~ i~?~~ 3: 'P. (Sin ~~ &" :0 U'I -< MICHELLE E. COLEMAN, Plaintiff V. DAVID A. COLEMAN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 04-3520 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO ENTER APPEARANCE Please enter my appearance on behalf of the Defendant, David A, Coleman, in the above-captioned matter, Date: lo/Jr/a't . RESPECTFULLY SUBMITTED, C-- ~, - o c- f~ ~f:; ~t; (~~ t:;~() .... c- ~ =2 ,....;) = c:.::.> ..r::- o ("") ...... N U) -U :ll: ':-? c..n (X) o 11 ~ rn ::D :0 hi 89 ~. 6 ..,..,. -,' ~5 om ~ .n .-< MICHELLE E. COLEMAN, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 04-3520 Civil DAVID A. COLEMAN, DEFENDANT : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 21, 2004. 2. The maniage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of both the 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. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~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! 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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. g4904, relating to unsworn falsification to authorities. Date: ~ k~~ 1Utdd& ;: ~ Michelle E. Coleman, Plaintiff --.. (') ...., = ~ c = :C"'" c.n 92~~ <- ~~ c::: :z rn 2::C I -u ~~r CT\ 136 r:c :;; -I.,. z(~ :r.'" cr: ..,{ :x 0-- 'j;-t) - zc~ lOt:::: - ()r Z -I -'1 ,f:'" r- .:0 -<. N -< MICHELLE E. COLEMAN, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 04-3520 Civil DAVID A. COLEMAN, DEFENDANT : CIVIL ACTION ~ LAW : IN DIVORCE AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 21,2004. 2. The marriage of the Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of both the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of!ntention to request entry of the Decree. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER li3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. g4904, relating to unsworn falsification to authorities. Date: -s-1t7 h ~ L2/V;Y"l$~ David A. Coleman, Defendant ------ () c: 2.':" ""Qi-r;: rp:\ ,! ~7 d: z<~, ~c[::. ~f:.~:, J:>c: ~ ~ ~ ~ z , 0\ ". :% ~ ~~ ::;So 06 -\-1'"' ::c ..,\ r..J-- '-.rQ 51' . -"-\ ';2: :Q - - z;- N ,- MICHELLE E. COLEMAN, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-3520 Civil DAVID A. COLEMAN, DEFENDANT : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: I. Ground for divorce: irretrievable breakdown under Section (XX) 3301(c) () 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: July 29,2004, by restricted, certified mail number 7003 2260 0005 6552 8490. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent and Waiver of Counseling required by Section 3301(c) of the Divorce Code: by Plaintiff: May 23, 2005; by Defendant: May 17,2005. (b) (1) Date of execution of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit upon the Defendant: 4. Related claims pending: None ,- 5. Date and manner of service of the notice of intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 330l(d) of the Divorce Code: 6. Date and manner of service of Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d) of the Divorce Code: or, date of execution of Waiver of Notice ofIntention to Request Entry of a Divorce Decree under Section 3301(c) of the Divorce Code: by Plaintiff: May 23, 2005; by Defendant: May 17, 2005. and, date of filing of the Waiver of Notice of Intention to Request Entry ofa Divorce Decree: Plaintiff's and Defendant's Waiver are being filed simultaneously with this Praecipe. JAMES, SMITH, DIETTERlCK & CONNELLY, LLP Date: ~ .2,.,.J d/:> , ""4.{f~ Sus . Kadel, Esquire Attorney for Plaintiff Post Office Box 650 Hershey, PA 17033 (717) 533-3280 PA J.D. No. 44837 (j ,..., = ~ c = :~ "" :VCI1 Co- :r::!:l rHrr c:: -,. .-. 2: m,- ~.~;~. I -om 0'\ 80 r~L; -...6 ;:.. ~-r. )> -- ("5::!J "-:?'~ .> ::Jl: .0;::. C) ''',::~o >c: cjrn ~ -, .&:- i:; , N -< " "" " IN THE COURT OF COMMON PLEAS " OF CUMBERLAND COUNTY STATE OF MICHELLE E, COLEMAN . PLAINTIFF VERSUS DAVID A. COLEMAN DEFENDANT AND NOW, PENNA. N 04-3520 O. CIVIL DECREE IN DIVORCE .T ,.....c. 'i? ...... 2,005. , IT IS ORDERED AND " DECREED THAT MICHELLE E. COLEMAN PLAI NTI FF, AND DAVID A. COLEMAN , 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; J. PROTHONOTARY " " " " " " " " " " " " " " " " " " " " " " " " " " " " " . " '. " " . " " " " " " " " " " " " " " " " " " " ~IP~ ~~ p#J} r :r ~ ~#7rfl y? N'l .' .,' ;" or .. ------