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HomeMy WebLinkAbout99-047511 ;? , .. 10 toI SA•ll•:w?rW• W. A. IN THE COURT OF COMMON FLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Versus DANIEL L. GODBER, Defendant JEANNA J. GODBER, __.... ?tt• Plaintiff ..99-4.751. CI.VIL...TERM decreed that .............. .. . ... .................. , plaintiff, i and ....... .............. PANIEL.L.. Q.QPBER ................. defendant, are divorced from the bonds of matrimony. s 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 k been entered; None. .................... ....................... .................. ............ ............................................ i• By rt Attest: J. I O`/ DECREE IN ? DIVORCEzr 161;1.fo- AND NOW...... ! ........ ?. y..... • 19.9.9.... it is ordered and JEANNA G Prothonotary I A l !Ir •? • •'A. •A:• Lt • •:? • •:ti :? • ;1} <? • :?: {E• :?:• {ii •:?:• •:?:• 3:• ;?:• t?:• c?:• •:?:• <K• L! • •'e • :?:• :?: :?? f:. . S i i i i i. is 2 Iii i; i 0 ?i t , /a. /G 9?` G_a/ cF,,sJ .s.??? Z lLL4. yS3r?,y??N JEANNA J. GODBER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-4751 CIVIL TERM CIVIL ACTION - LAW DANIEL L. GODBER, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO: Prothonotary of Cumberland County: Please transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: by certified mail, restricted delivery on August 17, 1999. (See Affidavit of Service filed herein.) 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by the Plaintiff: December 9, 1999; by the Defendant: December 6, 1999. 4. Related pending claims: None. 5. Date of execution of Waiver of Notice in Section 3301(c) Divorce: by the Plaintiff: December 9, 1999; by the Defendant: December 8, 1999. SNELBAKER, B`RENNEMAN 6 SPARE, P. C. LAW OFFICES Ie!%S?1 SNELBAKER. Date: December 9, 1999 By: BRENNEMAN Attorneys for Plaintiff & SPARE II r,4 ?Yn^f ?,-? F_:? ? (!J (. 1 ,`,C:. =l (-j( t= C:fl. CI ..` J_. % 1. .: ?. ` ?:: [; L/ L ????/ C) r,? - C} ?J JEANNA J. GODBER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. CIVIL TERM CIVIL ACTION - LAW DANIEL L. GODBER, Defendant IN DIVORCE N O T I C E 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 for 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 divorce is indignities or irretrievable breakdown of the marriage, 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 marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DECREE OF 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 (717) 249-3166 LAW OFFICES SNELBAKER. BRENNEMAN SNELBAKER, BRENNEMAN & SPARE, P.C. & SPARE II By. vMwele-?-,I Attorneys for Plaintiff JEANNA J. GODBEPlaintiff V. DANIEL L. GODBEDefendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT 1. The Plaintiff in this action is JEANNA J. GODBER, an adult individual residing at 7073 Carlisle Pike, Lot 85, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant in this action is DANIEL L. GODBER, an adult individual residing at 151 Tuckahoe Road, Dillsburg, York (County, Pennsylvania. 3. Both the Plaintiff and Defendant have been bona fide residents of the commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant were lawfully joined in marriage on February 24, 1995 in Florida. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction since the date of the marriage averred in Paragraph 4, above. LAW OFFICES SNELOAKER. 6. Neither party is a member of the armed forces of the BRENNEMAN & SPARE „ United States of America. j 7. The Plaintiff avers as the grounds upon which this faction is based is that the marriage between the parties hereto is irretrievably broken. 8. The Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that Ithe Court require the parties to participate in counseling. 9. The Plaintiff requests this Court to enter a decree of divorce. WHEREFORE, Plaintiff Jeanna J. Godber requests this Court to enter a decree of divorce, divorcing the Plaintiff from the bonds of matrimony heretofore existing between the Plaintiff and Defendant. SNELBAKER, BRENNEMAN & SPARE, P.C. By: Keith O. Brenneman, Esquire 44 West Main Street Mechanicsburg, PA 17055-0318 Telephone: 717-697-8528 Date: August 6, 1999 Attorneys for Plaintiff Jeanna J. Godber "IN OFFICES SNELBAKER, BRENNEMAN & SPARE -2- VERIFICATION I verify that the statements made in the foregoing 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. i ja-La Deanna . Godber August 6, 1999 LAW OFFICES SNELBAKER, BRENNEMAN & SPARE JEANNA J. GODBER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. CIVIL TERM CIVIL ACTION - LAW DANIEL L. GODBER, Defendant IN DIVORCE AFFIDAVIT JEANNA J. GODBER, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to me upon request. 3. Being so advised, I do NOT request that the court LAW OFFICES SNELSAKER, BRENNEMAN & SPARE require my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein: are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. AW)eA -/1 Jeanna J? Godber U (Plaintiff) Date: August 6, 1999 ,. _ lu 2 c, 0 s v ?? JEANNA J. GODBER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-4751 CIVIL TERM CIVIL ACTION - LAW DANIEL L. GODBER, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce code was filed on the 6th day of August, 1999. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. 4. 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. Date: December 9, 1999 L I A,(A4A Jeanna . Godber LAW OFFICES SNELSAKER. BRENNEMAN & SPARE i >. N Y F ! ` 1 a:?. ?? "-?! (_?; _ lL ?'_. ? I :.., _ .j_ .- ? ? , t"?' Q? '"rn ? ? . L... _I[L (: G: '? U cn G+ ? JEANNA J. GODBER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-4751 CIVIL TERM CIVIL ACTION - LAW DANIEL L. GODBER, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on the eth day of August, 1999. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. 4. 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. Date: / ? d LAW OFFIC[. SNELBAKER. BRENNEMAN & SPARE cQ LL,- - , U Cn ? U JEANNA J. GODBER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-4751 CIVIL TERM CIVIL ACTION - LAW DANIEL L. GODBER, Defendant IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(0) 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 I 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. 4. 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. Date: December 9, 1999 l li 11(? L ?? r ll. E Jeanna' . Godber LAW OFFICES SNELOAKER. BRENNEMAN & SPARE CO } ci_ [ 1 JEANNA J. GODBER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-4751 CIVIL TERM CIVIL ACTION - LAW DANIEL L. GODBER, Defendant IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST 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 I 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. 4. 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. Date: Da L. odber LAW OFFICES SNELBAKER. BRENNEMAN & SPARE C ?., a, U JEANNA J. GODBER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99-4751 CIVIL TERM CIVIL ACTION - LAW DANIEL L. GODBER, Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA) . SS. COUNTY OF CUMBERLAND) Keith O. Brenneman, Esquire, being duly sworn according to law deposes and says: that he is a principal in the law firm of Snelbaker, Brenneman & Spare, P. C., being the attorneys for Jeanna J. Godber, the Plaintiff in the above captioned action in divorce; that on August 12, 1999, he did send to Defendant Daniel L. Godber by certified mail, return receipt requested, restricted delivery, a duly certified copy of the Complaint in Divorce which was filed in the above captioned action as evidenced by the attached cover letter of the same date and Receipt for Certified Mail No. Z 489 586 616; that both the Complaint and cover letter were duly received by Daniel L. Godber, the Defendant herein, as evidenced by the return receipt card for said certified mail dated August 17, 1999; that a copy of the aforementioned cover letter dated August 12, 1999 is attached hereto and incorporated by reference herein as "Exhibit All and that the original Receipt LAW OFFICES SNEL6AKER. for Certified Mail and the Domestic Return Receipt are attached BRENNEMAN & SPARE hereto and incorporated by reference herein as "Exhibit B'r; and that the foregoing facts are true and correct to the best of his knowledge, information and belief. z' 4 L "G?2 Keith 0. Brenneman Sworn to and subscribed before me this 23rd day of August, 1999 Notary ubli Notarial Seat Chnshne M White, Not?aaryry Pudic Mechanicsburg Boro Cumberferq cotft MY Commisswn Expires Sao. 17 2001 Member, Penritimnia Aee061atbn d Notetlee LAW OFFICES SNELBAKER, BRENNEMAN a SPARE SNELBAKER. BRENNEMAN 8 SPARE A PROFESSIONAL CORPORATION ATTORNEYS AT TAW dq WEST MAIN STREET MECHANICSBURG. PENNSYLVANIA 17055 RICHARD C. 514ELRAKER P O. BOX 318 KEITH O. BRENNEMAN FACSIMILE 17171 6977681 7V-697.8528 PHILIP H. SPARE August 12, 1999 Daniel L. Godber 151 Tuckahoe Road Dillsburg, PA 17019 Re: Godber v. Godber No. 99-4751 Civil Term, Cumberland County Dear Mr. Godber: Enclosed please find a certified copy of a Divorce Complaint, the original was filed on August 6, 1999. Please be guided accordingly. Yours truly, Keith 0. Brenneman KOB/sz Enclosure CC: Jeanne J. Godber (w/enclosure) Via certified mail, restricted delivery, return receipt requested, parcel No. Z 489 586 616 EXHIBIT A Z 489 586 616 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided, ADO not use for Intemabonal Mall See revwse Sens to D L Sind 8 Number 1 1 T R a? . P?il?sb'u g , PA 17019 r Posts" $ .55 CertlAed Fee 1.40 Special Delivery Fee N RemidedD 2.75 Return a Delive 1.25 c g 8 8 T 8 Fees 5 Gf O SSO!` LL V) o_ l . n ne t Srebra ow addelmw Swvkw I also wish b raoalw de •CSpMre Ileme & 4S. end e0. bkwlrp GOMM (for err •a, = w "a"andSdhmmanrevweeaftw.mmarlwonresenI l xt f " ao u. s e e ra ee): AS " ¦ NaI LSYSknll btlnknd atlas rrrlpw.e, er m sn berk s epSCe dose not 1.0 Addes"@,s ?a Ad*mw Cr" Mm RWW Re4uSen?m IN nWkyq two, an ntlde mndw. AM Restricted Delhrory Iieoep,a Show b lrhao IN wSS aeYV W Sr .nd the den eeae?lea. COrlslrfl PDStrrrasiM for No. W 8. Addressed b: 4a Arkle Number Daniel L. Godber z 489 586 616 4. 3erNce Type 151 Tuckahoe Road ? RegWwW YM csrmw Dillsburg PA 17019 ? FWaesMap ? lrw W ? Ann forMwdrrldr ? coo 7. Date A a? 6?./q?.red By.(Pdnt Aram) e. Add (q,ly Hrgy Nd and tee is Paw) LAW OFFICES a. pApent SNELSAKER, vr% BRENNEMAN & SPARE 9 PS Form 11r Dacanlbar 1 Imawms- ns Domestic Return Receipt EXHIBIT B L ?, ? ? -- <_.- ?-' -:;:._ ? ?; ] 'J Cr. Ll ?r' •%LU li(? . ?`, ?? UI ??