Loading...
HomeMy WebLinkAbout00-02903 , . Of. '" ,.,"'''' <Ii "'''''''''''''''' "'''' '" "'''''''''' "''''''' "''''''''''''' '" '" "'''' . '" '" "'''''''''';!if!; . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. . SAMUELS. GOSSARD, Plaintiff No. 00-2903 . . VERSUS . . PAMELA S. GOSSARD. . Defendant . . . . DECREE IN DIVORCE . ~ (.:~~A'IVl. AND NOW, tJ". t-, I 2000 ,IT IS ORDERED AND DECREED THAT SAMUEL S. GOSSARD , PLAINTIFF, . AND PAMELA S. GOSSARD , 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; . tJ6,J ~ . ATTEST: ~~~OTHONOTA"~ . By TH . . . .. '" "'''''''''''''''' "''''''' "''''''' '" '" "'''' "'<Ii'" "'''' '" Of. '" '" "'''' ;+; . . . "'"'. ';tj", . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J!.:}" tJtI //~'t:JtJ '",,- ,,,,,,,,_J~,-~,.TI'_ .' ,;;!' \;' , .. . <.. &d~~'~4~ ;1~ ~/ -;$? ~ " '_~", ~"" Rm , ' "~r~"" ,,,.,..., ",.,,- ,,', /,c'", , ,,,,.," -- w_~",-," SAMUEL S. GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-2903 PAMELA S. GOSSARD, Defendant : CNIL ACTION - LAW : DNORCE PRAECIPE TO TRANSMIT 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: irretrievable breakdown under 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: May 15, 2000, pursuant to an Acceptance of Service signed by the Defendant. 3. (b)(1) Date of execution of the affidavit required by 9 3301(d) of the Divorce Code: May 5, 2000; (2) Date of filing and service of the plaintiff's affidavit upon the respondent: filed May 9, 2000, served September 1, 2000 by first class mail. See Certificate of Service; 4. Related claims pending: None. 5. (a) Date and manner of service of the notice ofintentio transmit record, a copy of which is attached: September , 0 , DATE: /b(11{q "' Ie praecipe to class mail. er, squire Supreme Court ill #53200 27 South Arlene Street Post Office Box 6443 Harrisburg, PA 17112-0443 (717) 671-9600 ~_ ~'ll~~!lIii~~ '" .~; " ~.', j,~...i.......~ , ~_Ifl ~, F'_'rv-~ ~..'~ -, (") ~ .-o~_ -~~ ;:-,- d~~:'-' '~~ ~12 -; I'---~ b o :"~~ I") '--' ~ I,J") :::~l ..~, :J:J. -<- . --~~,-"' "-' ' ~,~~=~ ~ C~_ -~" "' ..'...""""'--~, ^ SAMUEL S. GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. tb- ~903 ~ PAMELA S. GOSSARD, Defendant : CIVIL ACTION - 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 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 Court House, Cumberland County Courthouse, One Court House 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 COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, FOURTH FLOOR ONE COURT HOUSE SQUARE CARLISLE, PENNSYLVANIA 17013 (717) 240-6200 SAMUEL S. GOSSARD, Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. (J-f), ol.9/J3 Ct.vd ru-- PAMELA S. GOSSARD, Defendant : CIVIL ACTION - DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Samuel S. Gossard, an adult individual residing at 2127 Yale Avenue, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defendant is Pamela S. Gossard an adult individual residing at 2307 Warneen Way, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. Plaintiff has been a bona fide resident of this Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on August 15, 1976, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither of the parties in this action is presently a member of the Armed Forces on active duty. 7. Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the Court to require the parties to participate in such counseling. 2 \1i-'= ~ H_ "-"'~~~ .~.. ~- -~ ~ ~;- Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued by the Court. 8. Plaintiff avers that the ground on which the action is based is that the marriage is irretrievably broken. 9. Plaintiff requests the Court to enter a Decree of Divorce. WHEREFORE, Plaintiff requests the Court to enter a Decree: (a) Dissolving the marriage between Plaintiff and Defendant; and (b) Such further relief as the Court may determine equitable and just. Dated: rf>jo" Respectfully submitted, //' /0' /.--' f"" e S. Baker, 27 South Arlene Street P.O. Box 6443 Harrisburg,PA 17112-0443 (717) 671-9600 J.D. # 53200 3 1, VERIFICATION I, Samuel S. Gossard, verifY that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that the statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ~fA~ SAMUEL S. GOSSARD 4 .. ~,",."",,,- """"..,;"',,,,",,, SAMUEL S. GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA VB. : NO. OJ - D29CJ..J C0J PAMELA S. GOSSARD, Defendant : CIVIL ACTION - 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 SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or about March 5, 1994, 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! 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: S-S--doClo g~/.c:~ SAMUEL S. GOSSARD , 11~_1\!!.~~!!i~i!llI~!;#~;d,'fIl~,(~-l,[j;11&.!h\1~~lill;t!ittliil,~i '. "', -~, .. .~~. 8. "" "~~mm~~!JliI'- 0 <:::> c C) 0 ;:-;"',.> "1 "'T" ~~o. .J1b f-n~~; -; :1;;.. 'Or ?i;p -< i-i1;J2 CO}> I -On, _ '"7~ '.D ''"0 C:t..~,~ {''5 t ~ - -0 "::,0 ,~ ::C:fj ;?; (< :Y;;: O~ 'r::. (~, ry -,0 -C Of'q :z );! '-j -< '0 ::0 -< .. '.Ii 'I I -:,r=''''" " ~o.~."'_ - ~ ,.- -....... ~.. SAMUEL S. GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. . A- . 17 : NO. m.~~03 ~ . PAMELA S. GOSSARD, Defendant : CIVIL ACTION - DIVORCE C:J C) :Jt "'" :..c 1 I.D o -O~S FT1['"' 2-n z(: (j)..-:< 0<":- yC) -'0 .....::;...... ~ 0rC.t If you wish to deny any of the statements set forth in this affidavit, you~t fi~ a counter-affidavit within twenty days after this affidavit has been served on y or the statements will be admitted. NOTICE AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or about March 5, 1994, 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! 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: S;--,S"-Je,c?u !S~/,c:AJ~~ SAMUEL S. GOSSARD """"""'~~,",_d,,",'_ o -'11 -",'j 1'\\;:2 ,:s~l:Yl ,_,0 '~iJ9i . c~-n ~;={ (-') 6fr. -, S5 "< ._~"",""~ , J ~"'~ ~-_"""-""d.- ~ CERTIFICATE OF SERVICE I hereby certify that on this 1 st day of September, 2000, a true and correct copy of the foregoing document was served on the following person by United States Mail, postage prepaid, addressed as follows: Pamela S. Gossard 2307 W arneen Way Mechanicsburg, PA 17055 lane S. Baker, Esquire Supreme Court ill 53200 27 South Adeue Street Post Office Box 6443 Harrisburg, P A 17112-0443 (717) 671-9600 '"" -, "~ "J",",hi.--~~_.:. " SAMUEL S. GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 00-2903 CIVIL PAMELA S. GOSSARD, Defendant : CIVIL ACTION - LAW : DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF ~ 3301(d) DIVORCE DECREE TO: PAMELA S. GOSSARD DEFENDANT You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the !l3301(d) affidavit. Therefore, on or after October 12, 2000, the other party can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a [mal decree in divorce. A counter-affidavit which you may file with the prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will10se forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claim. 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 COURT ADMlNlSTRATOR Cumbedand County Court House, Fourth Floor One Court House Square Carlisle, P A 17013 (717) 240-6200 " .c. ~~ -'-- ~.- ''')". I~ -"-~ SAMUEL S. GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 00-2903 CIVIL PAMELA S. GOSSARD, Defendant : CIVIL ACTION - LAW : DIVORCE COUNTER-AFFIDAVIT UNDER ~3301 (d) OF THE DIVORCE CODE 1. Check either ( a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree. (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decrees may be entered without further delay. "'-" ~~ ~. - " .~. I=~ 'lili~ - ,_.....-k I verify that the statements made in this counter-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: PAMELA S. GOSSARD, DEFENDANT NOTICE: IF YOU DO NOT WISH TO OPPOSE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE TmS COUNTER-AFFIDAVIT. - ..--~. '. J>J~~ CERTIFICATE OF SERVICE I hereby certify that on this 'Z-( day of ~ , 2000, a true and correct copy of the foregoing document was served on the following person by United States Mail, postage prepaid, addressed as follows: Pamela S. Gossard 2307 Warneen Way Mechanicsburg, PA 17055 Diane S. Baker, Esquire Supreme Court ill #53200 27 South Arlene Street Post Office Box 6443 Harrisburg, PA 17112-0443 (717) 671-9600 [f~_N _ ,,', ""J"_ . ,w>~%;c"";*,,,;fr~~-"'--"'~~--l Ii (Ii ~ '---." ~~'-, " , "~..f III_ ' Q \_-- ". C",I c'::J '::.:J -~-'~ --". 0,) '-', ;:::- U'i ~--) ':,(-;1 ~~"'- h'.' l I I i I , ~, ' , I !' !: I, I t. P - ~ ~ >'1 I I I' i I, i~ , "7"- 9;jr~ (:.,,-'i .-< j-": < ~2<:, )..>l"':" Z =< _n ,~_, ~~, ,'"." =~.,,",,_,JL_JLL_..J~~_, ~lI1[f~Ult)-,_-,-~"J,^ ~-, - " ,= . SAMUEL S. GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 00-2903 CIVIL PAMELA S. GOSSARD, Defendant : CIVIL ACTION - DIVORCE ACCEPTANCE OF SERVICE I, PAMELA S. GOSSARD, Defendant in the above-captioned matter, have accepted service of the Complaint in Divorce as of this, the /.5-- day of 711, ,2000. ~,~AC~d . PAMELA S. GOSSARD J3c 7 Wo.{'c-el') ~r Address ~L... ~CI.-, n Q sa ~,' [-J -,- iIi:iIII~ma'tin~M~iiI' =m~' . ~" .J~" ,i "JiiIliilUf ~" " """--~ ?=? ~ 'i' n';"): ~;., ?}J - r'~ ~: - '-'>~';-- ::".~:: ~ ' ).:,.!~- , ::Cj -< - '" ~] fi Ii Ii II fi I' Ii !I ,I II :1 II II :1 'i I, II ,I 'J !I ,:::::') ':^~ .-.1 -",J (.5' :1 !i ~ ~ en Ii II II ~ ii - ,-,,~~ ..-)~~- "-, - " 1............._" "~ ~ SAMUEL S. GOSSARD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-2903 CIVIL PAMELA S. GOSSARD, Defendant : CIVIL ACTION - DIVORCE 1. Plaintiff's social security number is 175-48-6418. 2. Defendant's social security number is 196-48-4331.