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Home My WebLink About03-3800F:\FMVS\DATAFIU\Genasl\DOCUmcm Amhiv6GEND0002\10322<DM I/cny C.e d: 10/14/02W 46:48 PM Revised: 08/06/03 10.122] AM 10322.1 SCOTT M. GOTTHARD, Plaintiff V. BLANCA L. GOTTHARD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- J$o G CIVIL ACTION-LAW 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 ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pa. 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 desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 SCOTT M. GOTTHARD, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. QX 01 - S60o CIVIL ACTION-LAW BLANCA L. GOTTHARD, Defendant IN DIVORCE COMPLAINT Plaintiff is Scott M. Gotthard, who currently resides at 15 South Baltimore Avenue, Mt. Holly Springs, PA 17065. 2. Defendant is Blanca L. Gotthard, who currently resides at 15 South Baltimore Avenue, Mt. Holly Springs, PA 17065. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 1, 1998, in Cumberland County Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a decree of divorce. MARTSON DEARDORFF WILLIAMS & OTTO Bya Thomas J. Willi s, Esquire L D. Number 17, 12 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Date: g/-4l03 Attorneys for Plaintiff VERIFICATION The foregoing Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. F Scott M. Gotthard F\FILES\DAYAFILE\Gendoc V 0322-..I ?n r ? o ? N ?QQ ?O a r> n S F:\FILES\DATAFILE\Gmeral\DO,.rt ,,\10322-2a Ijlb CmeW 1115103 9 3915 AM Rev d. 10203 448.22 PM 9888.2 SCOTT M.GOTTHARD, Plaintiff V. BLANCA L. GOTTHARD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03- 3800 CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF SERVICE, COMMONWEALTH OF PENNSYLVANIA . COUNTY OF CUMBERLAND SS I hereby certify that a copy of the Complaint in Divorce was mailed to Defendant Blanda L. Gotthard at 9034 Sunset Blvd., Sutie 106, Los Angeles, CA, 90069 on September 10, 2003, by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed "Blanca Gotthard" and dated September 22, 2003. Thomas J. liams, Esquire Sworn to and subscribed before me this October 3, 2003. r Notary Public NOTARIAL SEAL E L. MYERS, NOTARY BORO, COUNTY OF CUMESSION IXPIRES MAY 27 Rg 0 m m r=1 O N j O' ra 0 rq m o? 0 N U S . . Post al Ser vice, ,, CE RTIF IED MAI L ,,., REC EIPT (Do me ti s c m ail Only; No ins uranc C For d nli.-:s ...__.:__ e overage P rovided) --i Ut ? t C ..l b? 3s tC> -c F.TILFS ATAFILO\6eo¢raI?wne ,10322-2.wn?1b Crc ted 12/17/03 8'.25AM Rev.nd: 12/17/03 8'.41AM SCOTT M. GOTTHARD, Plaintiff V. BLANCA L. GOTTHARD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-3800 CIVIL ACTION-LAW IN DIVORCE, AFFIDAVIT OF CONSENT 20031. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on August 6, . 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division ofproperty, lawyer's fees or expenses if I do not claim them before a divorce is granted. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND 3301 d OF THE DIVORCE CODE 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, lawyers 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. I verify that the statements made in this affidavit and waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unworn falsification to authorities. Date: &I? e?ndtr;? z o0 3 Scott M. Gotthard, Plainti N_ -c1 G X o0 i - C-> -? O IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CENDANT MORTGAGE CORPORATION RECEIVED MAY ] 1 2005 Plaintiff CIVIL DIVISION V. NO. 03-3880 CIVIL TERM CHRISTOPHER L. SANDEREON, A/K/A CHRISTOPHE SANDERSELL Defendant ORDER AND NOW, this P"Iday of , 2005, upon consideration of Plaintiffs Motion for Service of Notice of Sale Pursuant to Special Order of Court and the Affidavit of Good Faith Investigation attached thereto, it is hereby ORDERED that Plaintiff may obtain service of the Notice of Sale on the above-captioned Defendant, CHRISTOPHER L. SANDEREON, A/K/A CHRISTOPHE SANDERSELL , by mailing a true and correct copy of the Notice of Sale by certified mail and regular mail to 464 WOLFS BRIDGE ROAD, CARLISLE, PA 17013, . Service of the aforementioned mailings is effective upon the date of mailing and is to be done by Plaintiffs attorney, who will file with the Prothonotary's Office an Affidavit of service. BY J. a. G y 0 :r'? (IA 7? in r. "7 Curtis R. Long Prothonotary Office of the i3rotbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 0.3 ^ 38(216 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573