HomeMy WebLinkAbout02-5605DANA A. GOSSERT,
Plaintiff
TRACY L. GOSSERT,
Defendant
· IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY PENNSYLVANIA
· NO. 2002- ...~ ~ CIVIL TERM
· IN 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 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may
request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office
at the Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAVVYER'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
TELEPHONE: (717) 249-3166
DANA A. GOSSERT,
Plaintiff
TRACY L. GOSSERT,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY PENNSYLVANIA
· NO. 2002-_.~'~,o3"' CIVIL TERM
: IN DIVORCE
COMPLAINT UNDER SECTION 3301(C) OR (D)
OF THE DIVORCE CODE
Plaintiff, Dana A, Gossert, by his attorney, Lindsay D. Baird, Esquire, sets forth the
following:
1
Plaintiff, Dana A. Gossert, is an adult individual residing at 393 Limestone Road, Carlisle,
Cumberland County, Pennsylvania 17013.
2
Defendant, Tracy L. Gossert, is an adult individual residing at 393 Limestone Road,
Carlisle, Cumberland County, Pennsylvania 17013.
3
The parties were married on June 2, 1990 in Cumberland County, Pennsylvania.
4
Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for
at least six months prior to the commencement of this action.
5
This action is not collusive.
6
There have been no prior actions for divorce or annulment in this or any other jurisdiction
within the knowledge of the Plaintiff.
7
In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties
is irretrievably broken.
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.
COUNT II - EQUITABLE DISTRIBUTION
9
Paragraphs 1 through 8 of the Complaint are incorporated herein by reference set forth in
full.
]0
Plaintiff and Defendant have acquired property, both real and personal during their
marriage from June 2, 1990 until the present.
11
Plaintiff and Defendant have been unable to agree as to an equitable division of said
property.
WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital
property.
WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff
be divorced from the Defendant.
. ' Lind.~,ay D. Baird, Esquire
-- ' Attomey for the Plaintiff
37 S. Hanover Street
Carlisle, PA 17013
717 - 243-5732
I verify that to the best of my knowledge and belief, the statements in the foregoing document
are true and correct. I understand that false statements herein are made subject to the penalties
of 18 PaCS {}4904 relating to unsworn falsification to authorities.
ffo dSay Dare Bai~, Esquire
rney for the~laintiff
DANA A. GOSSERT
PLAINTIFF
TRACY L. GOSSERT
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
~ N
: 02-5605 CIVIL At~TIO LAW
I
1N CUSTODY
:
ORDER OF COURT
AND NOW, Wednesday, November 27, 2002 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before ~queline M. Verney, Esq. , the conciliator,
at 4th Floor, Cnmherland County Courthouse, Carlisle on Tuesday, December 17, 2002 at 9:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permm~ent order.
The court hereby directs the parties to furnish any and all existiug Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: /s/
Jacqueline M. Verney. Esq.
Custody Concihator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business befi)re the court, please contact our office.
All arrangements must be made at least 72 hours prior to any hearing ur business before the court. You must
attend the scheduled conference or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY 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 1'7013
Telephone (717) 249-3166
6S :,Z Nd L~ AO~ Z-O
DANA A. GOSSERT,
Plaintiff
V.
TRACY L. GOSSERT,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 2002-5605 CIVIL TERM
:
: CIVIL ACTION - LAW
:
: IN CUSTODY
ORDER OF COURT
AND NOW, this 13th day of May, 2003, the Conciliator not being contacted for
another Conciliation Conference for 90 days, the Conciliator hereby relinquishes
jurisdiction in this matter.
FOR THE COURT,
~acqff. fline M. Vemey, Esquire, Custod~Conciliator