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HomeMy WebLinkAbout07-2973A CARL F. GOSHORN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007 - CIVIL TERM KAREN H. GOSHORN, CIVIL ACTION-LAW Defendant 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 in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 1* CARL F. GOSHORN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2007 - ag?'a CIVIL TERM KAREN H. GOSHORN, CIVIL ACTION-LAW Defendant IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is Carl F. Goshorn, an adult individual who currently resides at 476 Mountain Road, Boiling Springs, Cumberland County, Pennsylvania, 17007. 2. Defendant is Karen H. Goshorn, an adult individual who currently resides at 476 Mountain Road, Boiling Springs, Cumberland County, Pennsylvania, 17007. 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 27, 1997 at Kings Gap, 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. The Plaintiff has been advised of the availability of counseling and that he 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. WHEREFORE, the Plaintiff requests the court to enter a decree of divorce in favor of the Plaintiff and against the Defendant. COUNT I -EQUITABLE DISTRIBUTION 9. Plaintiff hereby incorporates by reference paragraphs 1 through 8 above. 10. The parties have acquired real estate, personal property, including automobiles, bank accounts and other items of miscellaneous property during the course of their marriage, some of which is marital property. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree which effects an equitable distribution of marital property. COUNT II - CUSTODY 11. Plaintiff hereby incorporates by reference all of the averments contained in paragraphs 1 through 10 of this Complaint. 12. The parties have two children of their marriage, Hunter J. Goshorn, born August 26, 1998, age 8 and Onnika R. Goshorn, born August 23, 2001, age 5. The children were born in wedlock. The children are presently in the custody of Plaintiff and Defendant at 476 Mountain Road, Boiling Springs, Cumberland County, Pennsylvania, 17007. During the past five years, the children have resided with the following persons at the following addresses: Persons Residences Dates Carl and Karen Goshorn 476 Mountain Road Boiling Springs, Pennsylvania 1998- Present The natural father of the children is Carl F. Goshorn, currently residing at 476 Mountain Road, Boiling Springs, Cumberland County, Pennsylvania, 17007. He is married to the Defendant. The natural mother of the children is Karen H. Goshorn, currently residing at 476 Mountain Road, Boiling Springs, Cumberland County, Pennsylvania, 17007. She is married to the Plaintiff. 13. The relationship of the Plaintiff to the children is that of natural father. The plaintiff currently resides with the following persons: Names Relationship Karen H. Goshorn Wife Jonathan Howard Step-Son Hunter J. Goshorn Son Onnika R. Goshorn Daughter 14. The relationship of the Defendant to the children is that of natural mother. The defendant currently resides with the following persons: Names Relationship Carl F. Goshorn Husband Jonathan Howard Son Hunter J. Goshorn Son Onnika R. Goshorn Daughter 15. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 16. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: none. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order awarding the paries shared legal and physical custody of the children. Date: f' iii` J7, Z-oo -7 Respectfully submitted, O'BRIEN, BARIC & SCHERER Ip ".46 Mich el A. Scherer, squire I.D.# 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff VERIFICATION I verify that the statements made in this Divorce Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. § 4904, relating to unsworn falsification to authorities. Date: d Carl F. shorn ?XJ w CID CARL F. GOSHORN, Plaintiff V. KAREN H. GOSHORN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 2973 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE ACCEPTANCE OF SERVICE h? AND NOW, this day of, , 2007, I, Karen H. Goshorn accept service of the Divorce Complaint in the above-captioned case. Karen H. Goshorn [`? h] L-? ? .-rte ?'`.; .,... t"r'? ?; . ?? 'ri l i _ ? ?.1 ?.,...? y_ "'? CARL F. GOSHORN, Plaintiff V. KAREN H. GOSHORN, Defendant CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly mark the above-captioned action as discontinued. Date: November 25, 2008 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2007 - 2973 CIVIL TERM Respectfully submitted, O'BRIEN, BARIC & SCHERER 04k Michael A. Scherer, Esquire I. D. # 61974 19 West South Street Carlisle, PA 17013 (717) 249-6873 Attorney for Plaintiff mas.dir/domestic/goshorn/discontinue.pra CERTIFICATE OF SERVICE I hereby certify that on day of bjbVt.Yri&9--,, , 2008, I, Andrea M. Barrick, secretary at O'Brien, Baric & Scherer, did serve a copy of the Praecipe To Discontinue, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Karen H. Goshorn 476 Mountain Road Boiling Springs, Pennsylvania 17007 Andrea Barrick ?^. h?9 _._ ,? T •'Yi f» ?w. i < , ...... J .• c.....