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Home My WebLink About04-4112 Plaintiff, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA qoiL lfRYY\.. ".. : CIVIL ACTION - LAW LONDA COULTER, v. : NO: ()Ll- 411;)..... MICHAEL COULTER, : IN DIVORCE Defendant. 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 in divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for another 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 00 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 TIllS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORlH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LffiERTY AVENUE Carlisle, P A 170 I3 (717) 249-3166 LONDA COULTER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff, : NO: 04- 4//)... C;u~L '--r'in..~ v. : CIVIL ACTION - LAW MICHAEL COULTER, : IN DIVORCE Defendant. COMPI.AIN'TIN'DIVORCR AND NOW, comes the Plaintiff, Londa Coulter, by and through her attorneys, Mancke, Wagner & Spreha, and fIles the following Complaint in Divorce: 1. The Plaintiff, Londa Coulter, is an adult individual currently residing at 38 Oneida Road, Camp Hill, Cumberland County, Pennsylvania. 2. The Defendant, Michael Coulter, is an adult individual currently residing at 4524 Linden Avenue, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have both been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months prior to the fIling of this Complaint. 4. Plaintiff and Defendant are husband and wife having been married on October 15, 1989, in Las Vegas, Nevada. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. Neither Plaintiff nor Defendant are members of the Armed Forces of the United States or any of its Allies. 7. Plaintiff has been advised of the available of counseling and that she has the right to request that the Court require both parties to participate in counseling. 8. The Plaintiff avers as grounds on which this action is based are: A. That the marriage is irretrievably broken pursuant to ~330 1 (c) of the Divorce Code; and B. That as of April I, 2006, the parties will have lived separate and apart for a period of at least two (2) continuous years pursuant to ~3301(d) of the Divorce Code. WHEREFORE, Plaintiff prays this Honorable Court to enter a Decree in Divorce. Respectfully submitted, Mancke, Wagner/& Spreha By {, ~~ "-- P. Richard Wagner, Esquire I.D. #23103 2233 North Front Street Harrisburg, P A l7Il 0 (717) 234-7051 Attorneys for Plaintiff Date: 0/ i tlt.j VERIFICJ\TION 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. Section 4904, relating to unsworn falsification to authorities. (/fJfcWdiA DATE: A/ vi 0 <( . (J ~ t 'i ~ ~ -e () ~ 0 ::U -~; .c. o " ---, LONDA COULTER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. : NO. 2004-4112 CIVIL TERM : CIVIL ACTION - LAW MICHAEL COULTER, : IN DIVORCE Defendant. AFFIDAVIT OF CONSENT I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 19, 2004. 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. 4. 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. 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. DATE: IV/5/ /1'/ . I , ~(;. / ~ "/ ...' ~wc LONDA COULTER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff, v. : NO. 2004-4112 CIVIL TERM : CIVIL ACTION - LAW MICHAEL COULTER, : IN DIVORCE Defendant. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 19,2004. 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 fmal decree of divorce after service of notice of intention to request entry of the decree. 4. 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. DATE: .,r;s/~~/","I- ~,~~I dv/b- Micha Coulter LONDA COULTER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA Plaintiff, v. : NO. 2004-4112 CIVIL TERM : CIVIL ACTION - LAW MICHAEL COULTER, : IN DIVORCE Defendant. WAIVER OF NOTICE OF INTENTION TO REOUEST 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! 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 veri1)r 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: U//61N , LONDA COULTER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTy, PENNSYLVANIA Plaintiff, v. : NO. 2004-4112 CIVIL TERM : CIVIL ACTION - LAW MICHAEL COULTER, : IN DIVORCE Defendant. WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THF: 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 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. ~~du4~ Michael oulter DATE: "'*!./~~/t1 f ..-. LONDA COULTER, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. NO: 2004-4112 CIVIL CIVIL ACTION - LAW MICHAEL COULTER, IN DIVORCE Defendant. CERTIFICATE OF SERVICE I, Debra K. Spinner, Secretary in the law firm of MANCKE, WAGNER and SPREHA, do hereby certify that on this date a copy of the COMPLAINT IN DIVORCE was served upon the following person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing the same in the United States mail, Harrisburg, Pennsylvania, certified, restricted delivery, return receipt requested, and addressed as follows: Mr. Michael Coulter 4524 Linden Court Mechanicsburg, PA 17055 By J/d,.{k':'(. ,XPO=-1;' I Debra K. Spinn~r, Secretary MANCKE, WAGNER & SPREHA 2233 North Front Street Harrisburg, PA 17110 P. Richard Wagner, Esquire Attorney for Plaintiff DATE: 08/30/04 U.S. Postal Service," ~~s~~~~~~/~~~~~~e~:~ Provided) f'- Postage :T D Certified Fee o o Return Reciept Fee (Endorsement Required) o Aestricled Delivery Fee E:O (Endorsement Required) ...II r'l Total Postage & Fees rn o o f'- ,II . II . Complete Items 1, 2, and 3. Also complete ttem 4 W Restricted Delivery Is desired. . ,Printl!l!.1r Mine and add""", on the reverse that'we can return the card to you. . ch this card to the back of the mallpleoe, on the front W spaoe pennlls. 1. Mr. Michael Coulter 4524 Linden Court Mechanicsburg, PA 17055 J Postmark Here aSau ~R~;~M~hand~ CJ Insured Mall ~~ I '4. Restricted DelIve1y? (EdnI Fee) .. 2. ArtlcleNumber 7003 1680 0004 7891 4642 (Transfer from PS Fonn 3811 i February 2004 Dcmsetlc Retum Receipt 102595-02-M-154D ; LONDA COULTER, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. : NO: 2004-4112 - CIVIL TERM : CIVIL ACTION - LAW MICHAEL COULTER, : IN DIVORCE Defendant. PRAECIPE TO TRANSMIT THE RECORD TO THE PROTHONOTARY: TRANSMIT the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: irretricvable breakdown under Section 3301(c), 3301(d) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the Complaint: August 30, 2004, by certified mail, restricted delivery, return receipt requested. 3. (Complete either paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By Plaintiff: 12/12/04 By Defendant: 12/15/04 (b) (I) Date of Execution of the Plaintiff's Affidavit required Section 3301(d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit unto the Defendant: 4. Related claims pending: None 5. (Complete ether (a) or (b).) (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit the Record, and attach a copy of said Notice under Section 3301(d) (1)(i) of the Divorce Code: (b) Date Plaintiff's Wavier of Notice was filed with the Prothonotary: 12/16/04 (c) Date Defendant's Waiver of Notice I with the Prothonotary: 12/16/04 ?~~~~~~~ ~~+~~~~~~~~~+~~~~+~~~~+~~~+~+~+~~~+~+++~~~~+++++.+~~~+.~~+++.~~~+~~~~~+~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ++ +. +. +. + +. + ~ + ~ ~ ~ '+' '+' '+' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ~~+~+~~+~++++~++.+.++.++.+++++.+++++++~+++++++++++++++++++++++++++? IN THE COURT OF COMMON PLEAS STATE OF LaNDA COULTER VERSUS MICHAEL COULTER AND NOW, DECREED THAT AND OFCUMBERLANDCOUNTY PENNA. No. 2004-4112 - CIVIL DECREE IN DIVORCE Jz.nU2..11 S LaNDA COULTER Zo~ , IT IS ORDERED AND . PLAINTIFF, MICHAEL COULTER _, DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT NONE PROTHONOTARY J. _ ~ Z ~77t# 7~/L, -7v f1I / J:~~ p:% ~~.~/ ~t;,l ~7(7f7(./