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HomeMy WebLinkAbout03-6101BRANDY M. GOSSERT, Plaintiff ROCKY E. GOSSERT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2003- ~! o t CIVIL TERM 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 fights 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 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, 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 TI-~S 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 BRANDY M. GOSSERT, Plaintiff ROCKY E. GOSSERT, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2003- ~ I o t CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE The Plaintiff, Brandy M. Gossert, through her attorney, Thomas S. Diehl, makes the following Complaint in Divorce, and, in support thereof, avers as follows: 1. Plaintiff is Brandy M. Gossert, an adult individual currently residing at 22 Town Mills, Shippensburg, Cumberland County, Pennsylvania 17257. 2. Defendant is Rocky E. Gossert, an adult individual currently residing at 86 Chestnut Grove Road, Shippensburg, Cumberland County, Pennsylvania 17257. 3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on October 12, 1998, in Shippensburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. WHEREFORE, the Plaintiff, Brandy M. Gossert, respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. § 3301(c) or 3301(d) of the Divorce Code. Date: OCT 2 3 2003 Respectfully submitted, One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX 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. M. GOSSERT, Plaintiff BRANDY M. GOSSERT, Plaintiff ROCKY E. GOSSERT, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003-6101 CIVIL TERM IN DIVORCE TO THEPROTHONOTARY: PRAECIPE. WITHDRAWAL OF APPEARANCE Please withdraw my appearance on behalf of the Plaintiff in the above-captioned matter. Date: Respectfully submitted, Thomas S. Diehl, Esquire 1 West High Street P.O. Box 1290 Carlisle, PA 17013 ENTRY OF APPEARANCE Please enter my appearance on behalf of the Plaintiff in the above-captioned matter. Date: Respectfully submitted, 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 BRANDY M. GOSSERT, Plaintiff VS. ROCKY E. GOSSERT, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003-6101 CIVIL TERM : CIVIL ACTION - LAW : 1N DIVORCE _PRAECIPE TO THEPROTHONOTARY: Please reinstate the Divorce Complaint previously filed in the above-captioned action. Respectfully submitted, GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 BRANDY M. GOSSERT, Plaintiff/Petitioner ROCKY E. GOSSERT, Defendant/Respondent : iN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2003-6101 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this ~ ~ ~z'-~ay of March, 2004, cornes Bradley L. Griffie, Esquire, counsel of record for Plaintiff, Brandy M. Gossert, and states 'that a true and attested copy of a Complaim in Divorce, was sent to Defendant, Rocky E. Gossert, at 86 Chestnut Grove Road, Shippensburg, PA 17257, by certified mail, restricted delivery, remm receipt requested. A copy of said receipt is attached hereto indicating that service was made on March 19, 2004 ~.~fie,. Esquire ~ff~r Plainltiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed t~o before/rte thi§ ~ day of ~ ~r'l.. ,~ , 2004 Ir'v- N~Y P~LIC m .11 I II IIIIIII It BRANDY M. GOSSERT, Plaintiff ROCKY E. GOSSERT, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CIVIL TERM NO. 2003-6101 IN DIVORCE AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under §3301 (c) of the Divorce Code was filed on November 20, 2003, reinstated on March 11, 2004, and served on March 19, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND COP, RECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHOR/TIES. DATE: ' B~N~DY. ~OSSERT, Plaintiff BRANDY M. GOSSERT, Plaintiff Vo ROCKY E. GOSSERT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION ~ LAW CIVIL TERM NO. 2003-6101 1N DIVORCE AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under §3301 (c) of the Divorce Code was filed on November 20, 2003, reinstated on March 1 I, 2004, and served on March 19, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND COI(RECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION 7'0 AUTHORITIES. DATE: ROC~KKY~. GO~SS~t BRANDY M. GOSSERT, Plaintiff ROCKY E. GOSSERT, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2003-6101 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST THE ENTRY OF A DIVORCE DECREE UNDER .~3301(c) OF TIlE DIVORCE CODE 1. I consent to the entry ora final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ill do :not claim them before a divome is granted. 3. 1 understand that I will not be divorce until a divome decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is files with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND COICRECT. ! UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNS WORN FA ',.'.;1 FI CA T1ON TO AUTHORITIES. BRANDY h,E~OSSERT, Plaintiff BRANDY M. GOSSERT, Plaintiff ROCKY E. GOSSERT, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 2003-6101 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST THE ENTRY OF A DIVORCE DECREE UNDER .~3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenscs it' [ do not claim them before a divorce is granted. 3. I understand that i will not be divorce 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 files with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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. DAVE: ROCKY EtTGOS SEt~YF, De fendant BRANDY M. GOSSERT, Plaintiff ROCKY E. GOSSERT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2003-6101 CIVIL TERM IN DIVORCE 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 divome: Irretrievable breakdown under §3301 (c) 3301(d)(1) of tho Divorcc Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint: Certified mail, restricted delivery on March 19, 2004. 3. Complete either paragraph (a) or (b), (a) Date of execution of the Affidavit of Consent required by §3301 (c) of the Divorce Code: by Plaintiff: June 22, 2004 by Defendant: June 23, 2004 (b) (I) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: none 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file Praecipe to Transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in {}3301 (c) Divorce was filed with the Prothonotary: June 25, 2004 Date defendant's Waiver of Notice in §3301 (c) Divorce was flied with the Prothonotary: June 25, 2004 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS BRANDY M. GOSSERT, plaintiff OFCUMBERLANDCOUNTY STATF- OF PEN NA. No. 2003-6101 Civil Term VERSUS ROCKY E. GOSSERT, Defendant DECREE IN AND NOW, DECREED THAT DIVORCE Bran~ M. Gosser , PLAINTIFF, Rocky E. Gossert AND ,DEFENDANT, 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; ATT ~)~ J.