The URL can be used to link to this page

Home My WebLink About01-2476 FX _. l ,~ '''-'''uJ.;_. ",_'", _A_~b ,:;;:.: ,-'~'_,~":':-;,IJ.,;;:!h,j:k",-~,---"," ';;'_"_ < -'-;.. '--'-';'-;-I- .. . .. . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . . . . . . . . . STATE OF . . PENNA. Lori Ann Golden. . . . plaintiff NO. c0,1,,;U06 . . . . . VERSUS . . . DECREE IN DIVORCE :r;:::p 1" $:CI::J bu e (bc.!/'t ~ . . Alan L. Golden, J:r., . . . . . . Defendant . . AND NOW,--1lvv.oJu.- '1.,.' "').{.X) , IT IS ORDERED AND . DECREED THAT Lori Ann Golden , PLAINTIFF, . . . Alan L. Golden, Jr. , DEFENDANT, AND . . . . 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; . None. . By T~OU . . . . ATTEST: (!4, J. . . . . . . PROTHONOTARY . . . . . . 1....'.-, , " -'. '.~ .j" -", ""oi',,L. "d-., ". I~ ' '. APR 3 02001 tI LORI A. GOLDEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION -LAW : IN DIVORCE AND CUSTODY : NO, 01- A4-7~ CIVIL TERM v. ALAN L. GOLDEN, Jr., Defendant ORDER OF COURT AND NOW, this day of ,2001, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel appear before, , the conciliator, at , on the day of , 200 I, at _ m., 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 permanent order. FOR THE COURT: By: Custody Conciliator 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, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing, , ~ ;,' "3~' v :' j ~~ . ~ . . .-, "~Ole' .c ;,>,. .' 'n'_ I..Ic ";,-,\' '1, ~ LORI A GOLDEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY ALAN L. GOLDEN, Jr., Defendant : NO. Ol-dt+l~ CIVIL TERM 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 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 DO 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 FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, P A 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office, All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. "'C"," l' '~~~_" '-'_'-'_c."_';"';"",_,~,__'I, "'_~'_'_' ,;_1-1 "'.;,;i;';~"~' " '''Jt LORI A. GOLDEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY ALAN L. GOLDEN, Jr., . Defendant : NO. 01- 2'17(, CIVIL TERM DIVORCE COMPLAINT WITH CUSTODY COUNT The plaintiff, Lori A. Golden, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce and custody: COUNT I DIVORCE UNDER 23 Pa.C.S. &&3301(c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Lori A. Golden, who currently resides at 37 Regency Woods, Carlisle, Cumberland County, Pennsylvania, since 1993. 2. Defendant is Alan L. Golden, Jr., who currently resides at 65 TwoTavems Road, Littlestown, York County, Pennsylvania, since 2000. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months innnediately previous to the filing of this complaint. 4. The plaintiff and defendant were married on June 29, 1991 at Mechanicsburg, Pennsylvania. 5. Plaintiff and defendant have lived separate and apart since July 14, 1999. 6. There have been no prior actions for divorce or for annulment between the parties. 7. The marriage 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, WHEREFORE, Plaintiff requests the court to enter a decree of divorce. , I , ", '.~- --~"" " .. .,..-l:.j ,-~ ~-" .. "' . 'o'n.,,!\ . , COUNT II CUSTODY 9. Plaintiffrepeats and realleges paragraphs 1 through 8. 10. Plaintiff seeks custody of the following children: Name Alicia Golden Rebecca Golden Amanda Golden Alan Golden, III Present Residence 37 Regency Woods, Carlisle, PA 17013 37 Regency Woods, Carlisle, PA 17013 37 Regency Woods, Carlisle, PA 17013 37 Regency Woods, Carlisle, PA 17013 None of the children were born out of wedlock. Age 8 7 6 4 The children are presently in the custody of Lori Golden, who resides at 37 Regency Woods, Carlisle, PA 17013. During the past five years, the children have resided with the following persons and at the following addresses: Persons Alicia Golden, Rebecca Golden, Amanda Golden, Alan Golden, III, Lori Golden (mother), Troy Haas (mother's boyfriend), Shawn Leonard (half-brother) Rebecca Golden, Amanda Golden Melanie Aquino (aunt), Bob Aquino (uncle) Alicia Golden, Alan Golden, III wi Alan Golden, lr-, Christy Shoemaker (father's girlfriend), Wayne and Jayne Shoemaker (father's girlfriend's parents) Alicia Golden, Alan Golden, III, Alan Golden, lr- Address 37 Regency Woods, Carlisle, P A 20 Windy Hill Lane Shermansdale, P A 65 Two Taverns Road, Littlestown, P A Trailer in York Springs, PA Dates October 2000 until Present January 2000 until October 2000 July 2000 (?) until October 2000 July 2000 until? " I L-:, , . " , ^:,'- ,,' 0 --, . 'e'--. :',J.ld.",~~: ',>"h .,'"." c; '<" ;J-1t~: Persons Alicia Golden, Rebecca Golden, Amanda Golden, Alan Golden, III, Shawn Leonard, Lori Golden, Alan Golden, Jr. Address 37 Regency Woods, Carlisle, P A Dates 1996 until July 2000 The mother of the children is Lori A. Golden. She is married. The father of the children is Alan L. Golden, Jr.. He is married. 11. The relationship of the defendant to the children is that of father The defendant resides with the following persons: Name Christy Shoemaker Wayne Shoemaker Jwayne Shoemaker Relationship Girlfriend Girlfriend's father Girlfriend's mother 12. The relationship of plaintiff to the children is that of mother. The plaintiff currently resides with the following persons: Name Relationship Troy Haas Alicia Golden Rebecca Golden Amanda Golden Alan Golden, III Shawn Leonard Plaintiff s Boyfriend Plaintiffs and Defendant's Daughter Plaintiffs and Defendant's Daughter Plaintiffs and Defendant's Daughter Plaintiffs and Defendant's Son Plaintiff s Son 13. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court, Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth, or any other state, Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children, " ~I ~- " I > .,_.'' I', ' .' c,'j",,;,, ~ "" ';'", ~ ,,- T .'_. '""H ; ".k,,'.l,k~i'.;":;;:":'.'';~; ~'.::; '-; '->j6J 14. The best interest and permanent welfare of the children will be served by granting the relief requested because: a) Plaintiff is the primary caretaker of the children; b) Plaintiff provides the children with a stable home environment with adequate moral, emotional, and physical surroundings as required to meet the children's needs; c) Plaintiff has permitted and encouraged continuing contact between Defendant and the children and will continue to do so; d) Plaintiff is willing to accept custody of the children; e) Plaintiff continues to perform the parental duties and enj oys the love and affection of the children. 15. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action, WHEREFORE, plaintiff requests the court to grant her shared legal custody and primary physical custody of the children. Respectfully submitted, Date fJpJil ~7 ZOOI JrIH'M1u If! /J4d,,~UL- ichelle L. Ander(c)n Certified Legal Intem ~.PLSiJ ROBERT E. RAlNS TERI L. HENNING Supervising Attorneys FAMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2368 ,I ' I" 0' ';. ,,'l,,;:',-r,,;,;,J" ", ~ :,,'" . ,^' "-: .',' " ;J+;o-~i ~,,~,:c_~;:> ,,:,:,'-'h~' I VERIFICATION I verify that the statements made in this Complaint 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. floll./IJI D te / rYtn; /I -C'Jd-C!fJi Lori A. Golden, Plaintiff l~~~'w-"~;:cilIl/llii.~~~!iiIlL"f;~~,i..,,,,,,J;il:;~~~~~~'''''''"~''''''""' "~"""-IifIIiliIili'~ ~~ .~ - u. ~',~~:..--~,^- ,.'-" ~.~ , ." \ 0 0 () c: .'(j ;Z J'm- ,- -or;:.:) ~'D (per.! ~v <f--r",j N Z-- -c"! w~. -' -<:.2 ~":.: (~J ~C) -0- ~:.~~ ~~ ::zo ....,.0.. >8 i::? Z=-Ir"(j ~ ,:;? ~ {,:, -< . , ~~"& " ~ -- " ~~,~ ,j,-[ ^.' "'~""'--, LORI A. GOLDEN PLAINTIFF V. ALAN L. GOLDEN, JR. DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-2476 CIVIL ACTION LAW IN CUSTODY ORDER OF COURT AND NOW, Thursday, May 03, 2001 , upon consideration ofthe attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. ,the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Wednesday, May 23, 2001 at 10:30 a.m. 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 defme 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 permanent order. The court hereby directs the parties to furnish auy and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: Isl Jacqueline M. Vernt'JI. Esqf;!J Custody Conciliator 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 haviug business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or 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 17013 Telephone (717) 249-3166 ~ ~ - '" ,""~ ~'0 "C' .' :':,!:Ci>1:)Tt'HY lj,- - 011'11\ Y -l\ PH 3: 81 CUM8ERUND COUHW PENNSYLVANIA .5'.tf~1 M ~ M~ ~ ,c: L. .f tf.tJl /1~ P'ta' 4~ ~ ~. 5'I/.tJl ~~ ~ ~ a4 ~ ~#'< , ""... ,~~'" ~;1li!!in!II!II!'H~ '" ~'~"":""">"F ~1lJl*,~lI!lIIl!illitmHl~~~%.-'1'""'\"f~''''''W1,>j;"'''''''j'~":''''~,l, ")~",,p,~P''"--'~''''Y",!.<c-''~'U'''~'rWI!~''''j'<l':<';_'in~J<;::'!';'''*'1INe)!W4~,",;;:;lI~).-;;Wi~:a% . , .'" ,ll ~,' " ': ' ~.,~ w.'- "--O'''1i\' Jy ~ ,. ,. . MAY ~ 32!tlfn tJO LORI A. GOLDEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLANDCOUNTY,PENNSYLVANIA : NO. 2001-2476 CIVIL TERM V. ALAN L. GOLDEN, JR., Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 2.C\. day of ~ , 2001, upon consideration of the attached Custody Conciliation Report, it is 'Ordered and directed as follows: I. Mother, Lori A. Golden, shall have sole legal and primary physical custody of Alicia Golden, born September 3,1992, Rebecca Golden, born September 2, 1993, Amanda Golden, bom December 17,1994, Alan L. Golden, III, born July 23, 19996. 2. Father, Alan L. Golden, Jr., shall have periods of partial physical custody as the parties agree. cc: Michelle L. Anderson, certified legal intem - for Mother Teri L. Henning, Esquire - counsel for Mother Alan L. Golden, Jr. - pro se 65 Two Tavems Road Littlestown, P A 17340 "- ;v-o <\-0\ 0, b'?- o ffiOO!i1!1l~iMi~~"liJfu~:!!i:Eidl!i~!1~;Cd.:ili",;'M@lj,j'M!;''''d'''''&,L;l:;';'''f'<&;'''"'.il<t!!ili\~d:~~ ,-""~...tJf -~ 'C; ,:;) C.....' 'I-;"~ I, .< -~ '.~, 7' t:; ~l~S Y':...,.~ .~- "-- -t~~ -- 'p ;~ ~'"", (.J ;~\ ~. '- ",~~ c_ /",) ~~" '" "'-~" , 1M: ?" ~ ~, .... ~rl<U.lir' , ~- d' ...-= , I 1"1 1.1 r.,! n l'j I-I I, !! II ,I II 'I I: '-I :'i .~ , ~ . '. ,-- ~""'"~ m<' I, " ~ ^,. -, "'''''.o.'';)~, "c"'" LORI A. GOLDEN Plaintiff V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLANDCOUNTY,PENNSYLVANIA : 2001-2476 CIVIL TERM ALAN L. GOLDEN, JR. Defendant : CIVIL ACTION - LAW : IN CUSTODY PRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: I. The pertinent information concerning the Children who are the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Alicia Golden Rebecca Golden Amanda Golden Alan Golden, III September 3, 1992 September 2, 1993 December 17, 1994 July 23, 1996 Mother Mother Mother Mother 2. A Conciliation Conference was held in this matter on May 23,2001. The Mother, Lori A. Golden did not appear but counsel, Michelle L. Anderson, Certified Legal Intern and Teri L. Henning, Esquire of the Family Law Clinic were present on her behalf. Father, Alan L. Golden, Jr., although aware of the conference, did not appear. 3. An Order in the form attached was requested by Mother. 5-;)3-01 Date ~%.h- cq ine M. Vemey, Esquire Custody Conciliator ",.. ----j,'.' d', t"" ,--;~-~,'~"-"_:",,,,-,:_i-,,-" .' I~,_", _,_,IJ~',-,,:';~;; '-;.c-'_- '=' ,~,_ '''''':'; -. APR 3 0 2001 if LORI A. GOLDEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION-LAW IN DIVORCE AND CUSTODY ALAN L. GOLDEN, Jr., Defendant : NO. 01- )-47" CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Lori A. Golden, Plaintiff, to proceed in forma pauperis. I, Michelle L. Anderson, Certified Legal Intern in the Family Law Clinic, for the party proceeding in forma pauperis, certifY that I believe the party is unable to pay the costs and that I am providing free legal service to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. eeJ 7/71 V)() I Dae 0.jJidJJJJi- v: /JAldJ j,@L-- Michelle L. Andetson Certified Legal Intern J ~L /\!~ C' RT E. RAlNS THOMAS M. PLACE TERI L. HENNlNG Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 . I -'- ~~: J- '; '" "-"., '",' '^' 'i " ^ ; ,'^ ',',,-1'1 ,,~' ~ i"'[':i: LORI A. GOLDEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY ALAN L. GOLDEN, Jr., Defendant :NO. CIVIL TERM AFFIDAVIT SUPPORTING PRAECIPE FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am the plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding, 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3, I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: Lori A. Golden Address: 37 Regency Woods, Carlisle, PA 17013 Social Security No,: 210-52-3850 (b) Employment If you are presently employed, state Employer: Sheetz Address: Carlisle Pike & Rt. 114, Mechanicsburg, PA Salary or wages per month: $7.50 per hour @ 20 hours per week Type of work: Clerk * Plaintiff will be starting at Giant on April 30, 2001 at $7.20/hr. @ 40 hours per week (c) Other income within the past twelve months Business or profession: Other self-employment: Interest: Dividends: Pension and annuities: Social security benefits: Support payments: Child Support: $944 per month (not yet receiving) Disability payments: L.I.J..," n " ,I ,;' ~ i',i" --I'j .,' " ,,--I "",I Unemployment compensation and supplemental benefits: Workman's compensation: Public Assistance: Other: (d) Other contributions to household support (Wife)(Husband) Name: Troy Haas (Boyfriend) If your (wife)(husband) is employed, state Employer: Rynard & Sheaffer Salary or wages per month: $800 per month Type of work: Masonry laborer Contributions from children: Contributions from parents: Other contributions: (e) Property owned Cash: Checking account: PSECU $5.00 Savings account: PSECU $0.00 Certificates of deposit: Real estate (including home): Motor vehicle: Pontiac Sunfrre Cost, Amount OWlfd $ 10,000; Payment: $252 per month Insurance: $110 per month Stocks; bonds: Other: (f) Debts and obligations Mortgage: $200 per month Rent: Lot rent: $275 per month Loans: Other: *(itemize all other relevant monthly expenses such as heat, electric, food, medical expenses, transportation expenses, food not covered by food stamps when client receives food stamps, etc..) Electric: $40.00 per month Food: $400.00 per month Water / Sewer: $50 per month (g) Persons dependent upon you for support (Wife)(Husband) Name: Children, if any: Name: Age: Shawn Leonard 11 Alicia Golden 8 Rebecca Golden 7 Amanda Golden 6 Alan Golden, III 4 ,j,~" '<'" '" "". ,-,I "" ,,' '1." "...' ~.-Jl"J.;:;~':;,':':-,', j;;;'~ 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subj ect to the penalties of 18 Pa. C. S, 4904, relating to unswom falsification to authorities. DateLfrJ~/t11 CY/li AtJ/don Petitioner ,.-;:~,;..,,,,,,, - ,~,' --..- ~~~m:t'~..i ";';~~~~~;;.'!lj;g;!;iIl~ "'...iIt'~ , '~""' .' ,;.; ',,.J,;', 0 c:.' f:',,~: C =2'- 't:J&> .---" -0 IIi '-0 - rn 1'--1'. :;::0 Z ::.r: N -. ?: r ," g;~:{~: -.J '.,<~~j .,....C,... ~-n ,,'.\ ...,~ ~() -"<- C; :r;g ~ 0 j"n -, ~ 0 ~ ::Q (,:, -<. """.. " ';' "*" ~:i <.: ~f; . ~":Q , ru Cl ...D 0- U.S. Postar Service :, -':,::'.t:~'~' :._',. :': CERTIFIED MAIL RECEiPt ,< ., ,,,,,.J!>, (Domestic Mail Only; No ~~ cownr&e Provide,./l '. . ..-, ,-",,- '1 'I'_~" ~ _ * ...D Postage $ 0- 0- CertifiadFee =r- ea Return Receipt Fee {Endorsemen1 ReqLJrredj ..... Cl Restricted Delivery Fee Cl ~ndomementReqw~ CJ Total Postage & Fees CJ =r- 1"1 0- rr Cl .... PSf'orrnSSOO February2000 J,.,,!~'! .,(~~~~~ LORI A- GOLDEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY ALAN L. GOLDEN, Ir., Defendant : NO. 01-2476 CIVIL TERM PROOF OF SERVICE Understanding that the making of any false statement would subject her to the penalties of 18 Pa. CS. ~4904 (relating to unsworn falsification to authorities), the unclersigned verifies that Michelle L. Anderson mailed a true copy of the Divorce Complaint with Custody count on the Defendant by placing the same in the U,S, Mail, certified no, 70993400001849969602, restricted delivery, return receipt requested, postage prepaid, on the 27th day of April, 2001 addressed as follows: Alan Golden, Jr. 65 Two Taverns Road Littlestown, PA 17340 Sender's receipt no. 70993400001849969602 is attached hereto and incorporated by reference. On or about the 7tl'day of May, 2001, green return receipt no. 70993400001849969602 was delivered to the Family Law Clinic, bearing the signature Alan L. Golden and showing a date of service of May 5, 2001. The return receipt is attached hereto and incorporated by reference. Jw<L 5, 'too I Date Michelle L. Ande on Certified Legal Intern FAMILY LAW CLINIC 45 N, Pitt SL Carlisle, PA 17013 717-243-2968 t . Complete Items 1, 2, and 3. Also complete Item 4 if RestrIcted Delivery Is desired. Wlpri our name and address on the reverse t we can return the card to you. thIs card to the back of the mailpiece, r on the front if space permits. 1. Article Addressed to: x I D. Is delivery ad $S dj ent from item 1? ]f YES, enter delivery address below: o Agent o Addressee DYes o No ftian holdPl1 ( VI' , lJr:5lvvo~-hvCrn3 '2cod t-1'f/I1~ I f(-i- (7816 3. Service Type , %certified Mail 0 ,;xpress Mail ,f) o Registered ~eturn Receipt for MerchandiSe o Insured Mail 0 C,O.D. 4. Restricted Delivery? (Extra Fee) as "1?/~!/~":5W/1JS?J?J!fJ J/tJJlh /l6()j, PS Fom'l 36, r; JUry T999 Domestrc Return Recefpt '/, 102S95-9~M"1789 11"~"" "lai~F"",r~~.~",_~i -~JIilEl;Jr.ii:Wl'i~~.:J'II;1;I.l,gl!!i;t;).J:i'!i"~!f.itkl.dii!BfuIi!>"';'~~l\'i:.'ii1iij~' ~"'--'";.iiii."'~~~-<':"'lIn~ J ~ .'~- ..... o-.~ 'l "tl "', ,., 0 0 0 C s:- ., "'Om C-.. ::;:1 51!n; <= :;c nl:!J z'-'- I r- en S;: -r:~rn U1 :1>0 0:<2 ()(L. ~o :too ::i,:r' ~o :x ,-i..',r/ ;;;0 - 20 c - ""'rn ~ .. ~ c.n 55 \.0 -< iIi "' c :_1 h ," ~" .0 I, L '~. - "7- LORI A. GOLDEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY ALAN L. GOLDEN, JR., Defendant : NO. 01-2476 CNIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: Alan L. Golden, Jr., Defendant You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the 93301 (d) affidavit. Therefore, on or after October 25, 200 I, 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 final 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 will lose forever the right to ask for economic relief The filing of the form counter-affidavit alone does not protect your economic claims, 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 FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. <~,~';;: ~~ , ,:1, ' l) ~> i ," , LORI A. GOLDEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY ALAN L. GOLDEN, JR., Defendant : NO. 01-2476 CIVIL TERM COUNTER-AFFIDAVIT UNDER I) 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): D (a) I do not oppose the entry of a divorce decree. D (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both): D (i) The parties to this action have not lived separate and apart for a period of at least two years, D (ii) The marriage is not irretrievably broken. 2, Check either (a) or (b): D (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, D (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! fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims, 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 Pac C.S. 94904 relating to unsworn falsification to authorities. Date: Alan L. Golden, Jr., Defendant < .. ~~.~ , .c "L;o . -~J~~ ,-,-.;.' ,,- ':: "-'.L NOTICE IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE TillS COUNTER-AFFIDAVIT. ~~~!ilWM*.ili~!i-J"'1!-iiiliM~il&;!~@.t"'~;~'~iW@lii<,~,,,-;l-'~"'U,,,,,'il:!,"'.ae.g,,'tI,k;fd\Ol~";'.' UI!l__lliaIii 1i 'iii' ~ ''" lIl1'l k O~'" c 'c "" ;', . (') 0 c:> c: 'Tl ~,: Z ,-I -U 0:' c;, x: -" rncr,~ ~ fllr Z"c,c -",-n t7i c;. (11 :~~y -<L': ~~~l~ !:2 CJ :P' /5 I! :l:"o .. zO ~2 '? c-Sm z w 'i:;! ~ (u ~ I ","," Uo_",'~ ,=~" "~~~ ~' '" , ,I" 11 : Tefl "j' , LORI A. GOLDEN, Plaintiff ; IN THE COURT OF COMMON PLEAS OF ; CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ; IN DIVORCE AND CUSTODY ALAN L. GOLDEN, lR, Defendant ; NO. 01-2476 CML TERM CERTIFICATE OF SERVICE I, Michelle L. Anderson, hereby certif'y that I am serving a true and correct copy of the Notice of Intention to Request Entry of Divorce Decree on Alan L. Golden, Jr., Defendant, at 65 Two Taverns Road, Littlestown, Pennsylvania 17340, by depositing a copy of same in the United States mail, postage prepaid, this 4'k day of October, 2001. ~LiiMtL- Michelle L. And on Certified Legal Intern FAMILY LAW CLlNIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ~~~~;;icil;;S~i-);!';AA~~:,j,~'ll)Ii!",-"'"1,o;t::i!'"r~"""",;~,;;,~:~.!j;!,,\~}it-'-':I'fMl';~I~'1l'~''''''''''''~'liii~''' "~,~ jli' ,IE ,J! II ,< '~~" ~,,' ,.., ~"'~,~ "'",,>,""',,,,,,,, ,"~ "",,~',-",,,' , -Wlltlol ,.""-.....=~."."L.,.w,",' , ~. "11' 0 c:> ~ c $: ;;C ,,-{ -oeD 0 ~r:'"11 rnfT'; .c ,;lp::: 2::C "orn zr"" (11 ~ho ~~ ~~.::, " ::~C) ~C) :P> p:::'j; ~O ::& "':>0 ",,,0 t? On'! );>C ~ :';2 ,j.) <.;) -< <ttr . ",,"~;j"'" I" ,~ , ,I, ;L ..i !'-u 'I"': LORI k GOLDEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY ALAN L. GOLDEN, JR., Defendant : NO. 01-2476 CIVIL TERM 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 330Hd) OF THE DIVORCE CODE I. The parties to this action separated on July 14, 1999 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 conceming 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, 94904 relating to unsworn falsification to authorities. Date: cg )31/01 , " clt12I < /J11Vn ..mAt'>, Lori A. Golden, Plaintiff ,..,-." - " I", ,j'," "<0 ;,' I : " ~'. "'-~~kj 't LORI A. GOLDEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY ALAN L. GOLDEN, k, Defendant : NO, 01-2476 CIVIL TERM CERTIFICATE OF SERVICE I, Michelle L Anderson, hereby certify that I am serving a true and correct copy of Plaintiffs Affidavit under Section 3301(d) of the Divorce Code on the following person, by depositing a copy of same in the United States mail, postage prepaid, this 10th day of September, 2001: Alan L Golden, Jr. 65 Two Taverns Road Littlestown, P A 17340 ~'-f QiAOW7LJ}1 lAJichelle L. Anderson ./ Certified Legal Intem FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ~~~~i!:l,",\i,~.iIMii.~"'iI:!,.jN;d.$!~~,*&;;'1*'A-1'j;M*\'!-::),U",i";!t.;id-J;,~,,,,-g,4~1J'.1,-"trmf:.J'l'i~J~Wh'"--~1 ~~,.' *- _ ,~,~'~=~'" '0 ~W~ ~~ ~. ~~..~,d.~ .>, ~ ". a~ ! " ',^,.;: C) C 0 C ."ffi -,., U) .-j mrn rT1 -~ z::ti -0 ~:0 "'T1 ZS;; ,'- --Jm (f) _ 0 :~JO ~1S ~36 ~o ,.,. :'I:=H :l:: 00 )>0 - iSm ~ - w ~ -< \0 ::n -< .' '--h~--~~S,,' ' '\ f . -- ~ ',- , , ~" ," I, . - ,"~'~' ,,' . ",.",.',,' ,;:!~",' r n_O """>]"~,'=; '~i"," - ',: ;;";""-~;', : "co.' "-f '"", ',.".;;;..-;..;;i-'~i; " LORI A. GOLDEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY ALAN L. GOLDEN, Jr., Defendant : NO. 01-2476 CIVIL TERM PRAECIPE TO REINSTATE THE COMPLAINT To the Prothonotary: Please reinstate the complaint in the above-captioned case, .... Date: May 29, 2001 ~~ (}j;{dJ)fl- , /' Michelle L. Andersoil Certified Legal Intern ~ L i,,-,./ Thomas M, Place Robert E. Rains Teri L. Henning Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 III ~,.> -""'1.iJ~~,~il1liil:]!li" "!t.il~~!~I.jM.~__>li\!aiUWr.I!I~~;;W",~~ik"'''~'~ lQ1llMJ "iii. ~1iIt~ '"',' "'.c. " c, ,~,~ <7'~.L="c,~^~ ~" ," ",>~..m"__,,^~~, ,_^ "A^"".~_ ,.,_~, ^--, ~.' ',~",'''', (J ~~ riH+~ -;7'.---- "'--,-' t~5;: ~e~." ~~ =2 C) -""~ ~.., .-' ...r" ~",,) 1.~!~) :;-? :,) ~ .. i ~ 4 :;;~! _.~I -, I;;: fI' ~ . ~, --'-"'~" ~~'~"""-'-~~ I,L","~.~ "'-".1), SHERIFF'S RETURN - NOT SERVED CASE NO: 2001-02476 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND GOLDEN LORI A VS GOLDEN ALAN L JR R. Thomas Kline , Sheriff , who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT , to wit: GOLDEN ALAN L JR but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT - DIVORCE NOT SERVED , as to the within named DEFENDANT , GOLDEN ALAN L JR RETURN NOT SERVED AS PER FAMILY LAW CLINIC 6/6/01. Sheriff's Costs: Docketing Not Served Out of County Surcharge 18.00 5.00 l8.00 10.00 .00 51. 00 ~~~ R. HOMAS KLINE , SHERIFF OF CUMBERLAND COUNTY 06/06/2001 Sworn and subscribed to before me this .J 1-...1-- day of 9,-.--, :40~ A.D. C )Jh:' C' nA ji. j AtpiJ Pr t notary . ,",' ~~ ,~ c- c "'J i ,'=" '.,~~__," j, ,;"" ,,,~ ,-:;;"ij: I ~ORI A. GOLDEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LAW IN DIVORCE AND CUSTODY (') <;; o t~..J t -, i ALAN L. GOLDEN, Jr., Defendant : NO. 01- ;..f.t 7(.. CIVIL TERM po ~tl ;~ ~f-. ~ ~6' I:2c, -..,.c' :2:1~ ~c Z =< _:, ':::: --0 , } ,-~ -.-:-: ~-i', -co ~ :::> - - ~,\:~ -". ';I:l. -- PRAECIPE TO PROCEED IN FORMA PAUPERIS -- To the Prothonotary: Kindly allow Lori A. Golden, Plaintiff, to proceed in forma pauperis. I, Michelle L. Anderson, Certified Legal Intern in the Family Law Clinic, for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. ~Y:,\iR 1:7, YJ))D I Dae ~. 1jjllllJ)l t!udJMUL- ichelle L. An. on Certified Legal Int~ J .~L Id~ RT E. RAINS THOMAS M. PLACE TERI L. HENNING Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 ~ . , 1,~"m~",1!1~'''H>h:!ffiS<;I-J!~Hic:E.,jL'&'1'''1(,''-~~4.<;'j&:,'*;:'')i;\'itib~,'",,:,'d< ~ @b @ ~ ',' ~~,~ ,n ",;'"-l!"""":'I""&","Jii,,,,,,<0'~'0'>',,-b'oi,i;;:"':J;.Iii1illi~~1i&~~";;'\t,jMl",@~~;j~~~1Il. _. ,~" " ," ,...1 <, L ~IUtillllltllij"'i5L " iffi! ~, , I , ~ ~ @b ee)) ~ n .~ ' ~ -'-"'11.1' . \ c ~ . , . LORI A GOLDEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY () 0 0 c ,". $: -r- _..... . -ac', " : NO. 01- )4" CIVIL TERM ~~; ~ ~l; (/'J 0.::_: -.J _, NOTICE TO DEFEND AND CLAIM RIGHTS ~~. ~ ~t]j , -::-.....1 ~-;:c:. N ~.-:;;nl - -c ~ You have been sued in court. If you wish to defend against the claims set fOl~ tIie g following pages, you must take prompt action. You arewamed that if you fail to do so, thecase -.. may proceed without you and a decree of divorce or annuImentmay be entered against you by the court. Ajudgment may also. be entered against you for any other claim or relief requested in these: papers by the pliii.,.tiff. Y oa may 100:: money or property or .other rights important to you, including custody or visitation of your children. ALAN L. GOLDEN, Jr., Defendant When the ground for the divorce is indignities or iIretrievable breakdown of the maniage, you may request maniage counseling. A list ofmaniage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania IF YOU DO 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 FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For infmmation about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. ~ , , .' " !"~".... \. LORI A. GOLDEN, Plaintiff : IN TIm COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY ALAN L. GOLDEN, Jr., . Defendant : NO. CIVIL TERM DIVORCE COMPLAINT WITH CUSTODY COUNT The plaintiff, Lori A. Golden, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce and custody: COIlNT I DIVORCE UNDER 23 Pa.C.S. 66330I(c) AND 330Hd) OF THE DIVORCE CODE 1. Plaintiff is Lori A. Golden, who currently resides at 37 Regency Woods, Carlisle, Cumberland County, Pennsylvania, since 1993. 2. Defendant is Alan L. Golden, Jr., who currently resides at 65 TwoTavems Road, Littlestown, York County, Pennsylvania, since 2000. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. The plaintiff and defendant were married on June 29, 1991 at Mechanicsburg, Pennsylvania. 5. Plaintiff and defendant have lived separate and apart since July 14, 1999. 6. There have been no prior actions for divorce or for annulment between the parties. 7. The marriage 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. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. ~ ( L ~ ^ j ""~' , ".r:.;r' 'l&, ""'[ (' ~ COUNT II CUSTODY 9. Plaintiff repeats and realleges paragraphs 1 through 8. 10. Plaintiff seeks custody of the following children: Name Alicia Golden Rebecca Golden Amanda Golden Alan Golden, III Present Residence 37 Regency Woods, Carlisle, PA 17013 37 Regency Woods, Carlisle, PA 17013 37 Regency Woods, Carlisle, PA 17013 37 Regency Woods, Carlisle, FA 17GB Age 8 7 6 4 None of the children were born out ofwedlocL The children are presently in the custody of Lori Golden, who resides at 37 Regency Woods, Carlisle, PA 17013. During the past five years, the children have resided with the following persons and at the following addresses: ,.. ~-...., ~~ 1 ~"il;;;!, ,I 1 '~ . . (- . ~-" {} , . Persons Alicia Golden, Rebecca Golden, Amanda Golden, Alan Golden, ill, Shawn Leonard, Lori Golden, Alan Golden, Jr. Dates 1996 until JUly 2000 Address 37 Regency Woods, Carlisle, P A The mother of the children is Lori A. Golden. She is married. The father of the children is Alan L. Golden, Jr.. He is married II. The relationship of the defendant to the children is that of father. The defendant resides with the following persons: Name Christy Shoemaker Wayne Shoemaker Jwayne Shoemaker Relationshiu Girlfriend Girlfriend's father Girlfriend's mother 12. The relationship of plaintiff to the children is that of mother. The plaintiff currently resides with the following persons: Name Relationshiu Troy Haas Alicia Golden Rebecca Golden Amanda Golden Alan Golden, ill Shawn Leonard Plaintiff's Boyfriend Plaintiff's and Defendant's Daughter Plaintiff's and Defendant's Daughter Plaintiff's and Defendant's Daughter Plaintiff's aadDefendant's Son - Plaintiff's Son 13. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth, ot any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims .to have custody or visitation rights with respect to the children. .- t. i,., i' .' \- '4. . The best interest and permanent welfare of the children will be served by granting the relief requested because: a) Plaintiff is the primary caretaker of the children; b) Plaintiff provides the children with a stable home environment with adequate moral, emotional, and physical SUlTOundingS as required to meet the children's needs; c) Plaintiff has permitted and encouraged continuing contact between Defendant and the children and will continue to do so; d) Plaintiff is willing to accept custody of the children; e) Plaintiff continues to perform the parental duties and enjoys the love and affection of the children. 15. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, plaintiff requests the court to grant her shared legal custody and primary physical custody of the children. Respectfully submitted, Date Ophll ~,7f ZOOI J/JJiduY? ()hlfiU.vl' . chelle L. AndettOn Certified Legal Intem ;).MPf;-/J ROBERT E. RAINS TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2368 1 RUE COpy FROM RECORD In T astimony wnereol, I here unto set my hand and tlle.seal of said Court!!. CC~~~rr . Pa, fhis.....:.) 7 _da of~v~ . <<'~ ;.e.~ _ . .. ~ Prothonotary I , ,"'-- .' , j!," ~~-^ "-', "~1':,:; ". c VERIFICATION I verify that the statements made in this Complaint are true and correct I understand that false statements herein are made subject to the penalties of 18 PaC.S. ~ 4904, relating to unsworn falsification to authorities. fI oil.. /111 Dte I rY{IIj,fJ ~a'hM Lori A. Golden, Plaintiff " . '"N!; ~ ,,~",.:.d.'it-r'" -"ij~;m1i!~>lJj[~'~~~;::!~~Wtt7~tir-_!!ItIiii!iltiftflL\i:r'vr '!lW~r;~~"' ~ fE C .J !..nni ~ . ,~~"~.~~ ,", ...," ..' b.~ ~. i.. [j!J cC ~iW 'nt~ ~. ......" 1:, ;;! ;0 -< f~ ;o~" m:~' z; ,VJ : '-I: >~ -f5~ &; 3' .- '" c ~_ "~~, ,,,,,,,,' LORI A GOLDEN, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY ALAN L. GOLDEN, JR., Defendant : NO. 01-2476 CIVIL TERM CERTIFICATE OF SERVICE I, Michelle L. Anderson, Certified Legal Intem, the Family Law Clinic, hereby certify that I am serving a true and correct copy of the Praecipe to Transmit the Record and the Vital Statistics form on Alan L. Golden, Jr., Defendant, at 65 Two Taverns Road, Littlestown, P A 17340, by depositing a copy of same in the United States mail, postage prepaid, this 15'" day of November, 2001. ~ r lJM1f11U 'f fhJ Jjh<Jj1 - \../Michelle L. AndersW Certified Legal Intem FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 - 10:. , I " , LORI A. GOLDEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN DIVORCE AND CUSTODY ALAN L. GOLDEN, JR., Defendant : NO. 01-2476 CIVIL TERM AMENDED CERTIFICATE OF SERVICE I, Michelle L. Anderson, Certified Legal Intem, the Family Law Clinic, hereby certify that I served a true and correct copy of the Praecipe to Transmit the Record and the Vital Statistics form on Alan L. Golden, Jr., Defendant, at 65 Two Taverns Road, Littlestown, P A 17340, by depositing a copy of same in the United States mail, postage prepaid, the 16th day of November,200L JJ~~tij)tfl)1 Michelle L. Ande on Certified Legal Intem FAMIL Y LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 "- ~>''- ,="k'''~''J1j1fJ!'~~ii!iiliw'~~gr,~~,hM''cU..\kiA'_"!#;W,,,;~~~~MII\iiiiI ;_J,~~~~fJLJl[L",_ ~,>~a "~ ~ ~,< ~" _~, " ,,"~,'~..,'''''; -<""I"''!'J ,\'<'1";;;, ,~.~~,"o 37, ,'--o'Td,.n,,',""". ,,~';'\,.~~ V ~. '~'l~IlilIii\~'< " '.' " '<<<' ~ ~ ,,"'." "~""';'""",,",,,J"I." " '-^- ~, 0 0 0 C -1'1 :? - ~."" d_ '"OeD C":) - mcn .~-C: Zp N ;i~~; z:~_, (:::J , ;'~1~~!1 (f}?';" =<6; !;20 :J:-~ ~ri~ :;;0 > ~9 - - ,-- ~ z: 0:- J;;; ~ -S -l ~ ~ ,__"iilli!' ","J_-" '-,', 1..1, , ""' .'1L.,."_ >1 _ '",<.,: LORI A. GOLDEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION -LAW : IN DIVORCE AND CUSTODY ALAN L GOLDEN, JR, Defendant : NO. 01-2476 CIVIL TERM 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 S3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: May 5, 2001 by certified U.S. mail, postage prepaid, restricted delivery, return receipt requested. 3. Date of execution of the affidavit required by s3301(d) of the Divorce Code: August 31,2001. Date offiling and service of the plaintiffs affidavit upon the respondent: September 10, 2001. 4. Related claims pending: none. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy ofwbich is attached: October 4,2001 by U.S. mail, postage prepaid. Date: November 15, 2001 Michelle L. Ande n Certified Legal Intem for Plaintiff ~ L!\/ ~ T S M. PLACE v ROBERT R RAlNS TERI L HENNlNG Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 )Pi~~~'~'i.i>:~8ii>!l2i.W-i[\i'd';';'~1;~~im~"".K"l;;t~i,j)';A;;:;;i"Z';;~K~"'A;;i,C"glfl,j-4'-';qw~'1l;~IlOIiIilill&;JU~ '.' '~" "1 ,~\,,;; ~tr~~ 'e,:.;-"t',:, ,~~,=" :~~~,Il.,jJ~t;~,~lJJ-L"";~",:j1,LJJ~m.~~,,, ~'i-_},I','(~"'",,,,,,-,",,Mn',>;t,, ,,'-"i,n;' ,',' ,~,r ,0 'c 'f'''~"-,,','^_', "',~" ',' ,'"' ",~~,",,^, " , [W ,...d"'lMlIl' "' '" ~ ,"~",..., ,..:,. - ~'l"" 0 0 0 C ."'t'l :?" Z :::! ~~ C) Z:b <: {;-1;1] ZS;- :gtS ~.dE <J1 ~~.,:~ {l.) r.:;O ~ ;J::H j;; 20 -""" ,,--20 -0 :5 >c: arn Z --,I =< W 53 (J1 -< ,J!! LORI A. GOLDEN PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, 01-2476 CIVIL ACTION LAW ALAN L. GOLDEN, JR. DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Thursday, AU2ust 04, 2005 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueliue M. Verney, Esq. , the conciliator, at 4th Floor, Cumherlaud County Courthouse, Carlisle on Thursday, Septemher 15, 2005 at 8:30 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 permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: Isl Tacqueline M. Verney. Esq. ,Y Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For infonnation about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IFYOUDONOT 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 . ~~ , ~-'>'-" , ~, ~,~- <~ ~. -'~, RLEl)-()j::;::jCE rF -) !-Ie D:~Y'Yr'I,!n;\!'Y:-'\nv ,~) .1 iL. I 'I'.c',! [,"~:"j,-, '~'" . - IY' '_'. ["1 20n~J hUG....j (ii ",1' J,,- C'-' :li:'i: ~ .),>,/:\lTY :f~o5' tW-~~~4~ ~ -s- 05 '7l~ ~ z; "aft' ~5"05 ~ ~ ~ a1-~ ~, ,,__,.,e' .=__~~ -, - ~;;?75 ~/&"~ ~ ",,.,J "'0''l''{i'1'""},q';;J-';j"f-';;~''~~;;~f''!S'',,'mg'''''~,~H1i?i,~,,j,:qW!f1l<:~"'''Pf''''f9"~;ff~fiY:'''-' ,===""":........~l~""'~~jf1l~i~!if:-%-""-w.J;":i""";','>~""'m._'~;; ,1lT.i~-,",~~'-<=-"""--'~'"''''''''''''''''''''''''-' ~rrj , ,j ~~,,~ " j RECEIVED AUG 03 200s V , LORI A. GOLDEN, Plaintiff/respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2001-2476 CIVIL TERM ALAN L. GOLDEN, JR., Defendant/petitioner CIVIL ACTION - CUSTODY NOTICE AND ORDER OF COURT You, Lori A. Golden, have been sued in court to obtain custody, partial custody or visitation of the children, Alicia, Rebecca, Amanda, and Alan III. You are ordered to appear in person at _ . on , 2005, at .m" for [] a conciliation or mediation conference. [] a pretrial conference. [] a hearing before the court. If you fail to appear as provided by this order, an order for custody, partial custody or visitation may be entered against you or the court may issue a warrant for your arrest. 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. Taryn Dixon, Court Administrator One Courthouse Square Carlisle, P A 17013 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. BY THE COURT: J ". '-*' ,~k" .', .. LORI A GOLDEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA vs. NO. 2001-2476 CIVIL TERM ALAN L. GOLDEN, JR., Defendant CIVIL ACTION - CUSTODY ORDER OF COURT AND NOW, this day of ,2005, upon consideration of the attached petition, it is hereby directed that the above parties and their respective counsel appear before Esquire, the conciliator, at Pennsylvania, on the _ day of ,2005, at AM./P.M. for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or, ifthis 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 be present at the conference. Failure to appear at the conference may provide grounds for the entry of a temporary or permanent order. FOR THE COURT: By: Custody Conciliator 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 FlND OUT WHERE YOU CAN GET LEGAL HELP. THE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 1-800-990-9108 ~.} ~bi;.~"'~' - I,,,; ~k.'-' , , ~' , " LORI A. GOLDEN, Plaintiff/respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. NO. 2001-2476 CIVIL TERM ALAN L. GOLDEN, JR., Defendant/petitioner CIVIL ACTION - CUSTODY PETITION TO MODIFY CUSTODY To the Honorable Judges of said Court: Petitioner, Alan L. Golden, Jr., by his attorney, Jerry A. Philpott, Esquire, files this petition and respectfully represents the following: 1. Petitioner is Alan L. Golden, Jr., the father of the subject children, Alicia Golden, Rebecca Golden, Amanda Golden, and Alan L. Golden, III, who resides at 1745 Gilbert Road, Conway, South Carolina 29527. 2. Respondent, Lori A. Golden, is the other parent of the children, who resides at RR 1, Box 269-B, Loysville, PA 17047. 3. On May 29,2001, the Honorable Edgar B. Bayley, Judge, entered a custody order, a copy of which is attached as Exhibit A, granting respondent sole legal and primary physical custody of all four children. 4. Since the entry of Exhibit A, the following substantial circumstances and facts have changed, giving rise to this petition: Three of the children involved had been placed with family members in South Carolina at the urging of Perry County Children and Youth Services. These children are now living with petitioner in South Carolina. The fourth child, Alan III, still resides with his mother in Perry County, in a situation that is not good for him, for the same reasons as Perry " ,'~"~ ,~,~' ~I " " . , ~ - : -; , ~' l L~" :$,,- County Children and Youth urged placement of the other children in other homes. 5. As a result of the foregoing, the existing provisions regarding custody are no longer in the best interest and welfare of the children. 6. The best interests and welfare ofthe children will be promoted by a modification of the existing provisions regarding custody for the above reasons. WHEREFORE, your petitioner respectfully prays that this Honorable Court modifY custody to give petitioner primary physical custody. Dated: July 29,2005 Exhibit A Court order of May 29, 200 I '< ..~~~ 07/26/2005 09:39 8434881007 " DRAGONFLIES ~......... W i ~ . . 'l~, PAGE 01 I verity that the statements made in this PetitiQll to ModifY Custody are true and com:tt~ I understand that false- matemems herein ar~ t:\;)..k fl~t!~;i~n ~{. ~b.: :l,'lr"::k.... \"~ i ~~ Pa. C. S. "4 rclati falsifi ion to aUlhotillcs. 1I '1 Alan L volden, k Petitioner 07/1.S/2l'l05 J$c28 ~. 8434881087 DRAGONFLIES .. ~"":C. 'C ~"'" . ....'1/.\;., : IN THE COURT OF COMMON PLLJ\S OF : CUMBERLAND COUNTY ,PENNSYLV ANlA LORI A. GOLDEN. Plaintiff v. : NO.2001-2476 CIVIL TERM : ALAN L. GOLDEN. JR.. Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW. this ;( 9 day of consideration of the attached Custody Concilla) un follows: 2001, upon epotl. it i~ onkJ'ed fuld directed as . 1. Mother. Lori A.. Golden, shall have sole legal and primary physical .. custody of Alicia Golden. born September 3, 1992, Rebecca Golden. born September 2, 1993, Amanda Golden, born December 17, 1994, Alan L. Golden, III. born Juiy 23, 19996. 2. Father, Alan L Golden, Jr.. shall have periods of partial physical custody as the parties agree. BY THE COURT, . ,< . ,...-1 J i 'nEitr' ; ui, _lL-' C' .~. i) ''';'; , . . .... '::if) . ~/ , / '. ~ \,1 'i' c:; ~ I I" J. .." J\.lichelle L _>\ndeF..on. cero1iet.l. legal intern - tOr Mother Ten L. Henning, Esquire- oounsel fur Mcther AJan L. Golden, Jr. - pro- se . 65 Two Taverns Road Litll.:stown, PA 17340 j A '\"~fJE COpy fR?M r-:--:---:RD in "Z~'~" n'f '.\Iher"-tlf, I Ut\, . .1\Y halld ~nd lil<' ai at utid ~I'S\'" PJ. ,!, q _11 I hi.t/ -_.2...J.1" day Of.-l",< ~ ~! ~ -i\"il:7t,,:,/ " I. _t.,~". .a,.!J.. h":'~,l....~.\..'. / . PrDliul7CWlf, !/ EXHIBIT :,:illi:ii1~~i~,ljM,~~~~,:,,;!:{,;i!cL'1:,j~O,~";)-k;\i4':Wt!J!l>,;!l':,i'""'",!,', >"''-'''''~'~~LF?..j'c:,--,:;,'> ,<_';ht;-',f&~~jj~"'i:..1;~~~m~~~~~~~~~ -' ~IW-"~ ',",", .....::: , -. ,'"' p 0 ~ ~ i G ....... ~ (). 0 '" l) c: C'..:J (J \)' <:::::) " Ln ,1 tOP f' f-., .~,"'" --l ~ C= :r: .,., ...0 ~ G"") rnr-== ...c [~J~ ~ -r.:'i ~ -c- ;~~~ "';;,<, , ~:: c.) (~Srn -, -,~ ~. ~ '~ 'Z w '< ci 'I( ~~ __0, J'L, .'., ' ,;,:,..,jl ~" '--"il1Ilit'tiNl'_-r~': LORI A. GOLDEN, Plaintiff RECEIVED S[P 1 Z ~OOr : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2001-2476 CIVIL TERM ALAN L. GOLDEN, JR., Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 12th day of September, 2005, being advised that the parties have reached a stipulated agreement, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, /Jl,~ ine M. Verney, Esquire, C tody Conciliator ~''''''"''''''''~''';~'1ii~!~I;jR1,;1!llit:~~#&-jtJi{"",,,,.,:ffi,I!)~'",~Wli.~~o;<'''''"~ _,. ,,~,~_" ,~o~. ~,<_>~,"">,_,,,,,,,,~',~ ~, It) ;/:Ji1l ~'-'" ., '"" ,,' ",Or <'__ ," ,__~~" ,"" "",, "". .,. 'l' '"~ ,'",' ~~ :~ ~ ", "'"', _,I f'o' c;.., =, e".1 o 'Tl -l ~:;,-rl lHt= ;gt::; ~~2 ~;2c) 6Ci1 -( 55 -< 0., P'"1 <; v N 0:> ,,"~~~~ _. ... .".. '" ,~' ^ " ., ',i , U ," .' ,,'"'~ ~it" ~ft~~~IHO SEP 1510llS ? LORI A. GOLDEN, Plaintiff/respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. NO. 2001-2476 CIVIL TERM ALAN L. GOLDEN, JR., Defendant/petitioner CIVIL ACTION - CUSTODY CUSTODY ORDER AND NOW, upon agreement of the parties, IT IS ORDERED THAT they shall share legal and physical custody, with father, Alan L. Golden, Jr. , having primary physical custody of Alicia and Amanda during the school year, and mother, Lori A. Golden, having primary physical custody of Rebecca and Alan III during the school year. During the summer they will share custody by arranging to have all four children be together, half the summer with mother and half the summer with father. They will split the burden of transportation equally. r J. /",~J'~' ~~/~) / BY/'YHE COUR (i ) ~~I<k'fllllt'il!i.[;h'~~Fj~,,,~i'@~~I11~~~~,it1i>-'il,"f~;rm-:.-0i;%*I<r:N~.l:"i;:Jr,~'i'~~ll1'~'~ '1lll:illlilllll: ~ M ~ f-" ~~ ::J<( :lC Of;: ~~ ..... "-...." ~ """':::1 0 .:~~5= :';<"IJ) N ~-~ ,-""~- 0.. .'c' -'~ o:LIJ ~,., "'...::.. W UJLLi iE tI) COCL f.J... ..,." ~ = ::J 0 <= U c-.o ~,~, ,~",~~'~. ,~, ~' <', ,'." "~, , ,,' "'''~'''' C"'''' _ ',__' . ,,, "'", '''''''' ", ~ ,"" , -~, ""~, "'.I.ti ~ s ~~ ,,' ~J~ .'~ -'., ~"^,,,." >~ , '_n' ,,"__~ ,. ..,",' .~ , ... ,.r' .. '<_'H,: I~ .1 , '<' l:. ',~ ' ~~ .":f , ';1 . ,.,. ... .... LORI A. GOLDEN, Plaintiff/respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA vs. NO. 2001-2476 CIVIL TERM ALAN L. GOLDEN, JR., Defendant/petitioner CIVIL ACTION - CUSTODY STIPULATION FOR AN AGREED ORDER OF CUSTODY To the Honorable Judges of said Court: COME NOW the above parties, and stipulate as follows, and ask the Court to enter their agreement as an ordeL The parties are the parents of four children: Alicia Golden, Rebecca Golden, Amanda Golden, and Alan L. Golden, III. Father lives in South Carolina; mother, in Pennsylvania. They agree that they shall share legal custody of the children. They further agree that they shall share physical custody equally, with father, Alan L. Golden, Jr. , having primary physical custody of Alicia and Amanda during the school year, and mother, Lori A. Golden, having primary physical custody of Rebecca and Alan III during the school year. During the summer they will share custody by arranging to have all four children be together, half the swnmer with mother and half the summer with father. They will split the burden of transportation equally, rimes of the year for the children to be together. c;/;zt rJ (:;?YO"tfn Lori A. Golden """- '~~~~--i~~$,;(",'~;"'--"""-;A"~~il"O"':lj,;ifi,,ilc,;,~~.;b1;1lh",,"!i.-::'~'1'--, ~ ,,'," ","",,;,L;)l?"-ii, "iJ'O'i'J~;"~@~&M~~ili!;,mMlli';.'!ctJ:If>,~llI1liJf~:,UiJ_ilU':J. """"Ail~ ~'!iAlt'~ .~"~~ ~J ;.:i.. ",...0...,. ~"""',,"' <<- ,~, ~ ~"~ ~v ,~ ,,, o ~~-::: =~3 - 01 .. .. "" c::r. c) <J' (/) t~q -C} o -n --; r.l_ ~]~ .~~~~ ~i''' ~~ -< r t,' (",,) 1'-:> 1'0 ~~