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Home My WebLink About08-3243IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA Ronald Goforth Plaintiff V. Bobbi Goforth Defendant : CIVIL ACTION - LAW NO. 3- 3x43 : IN DIVORCE 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 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 Court House, 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 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 Lawyers Referral Services Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA Ronald Goforth Plaintiff CIVIL ACTION - LAW V. p_ 3z Y3 NO. CIVIL TERM Bobbi Goforth Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE AND NOW, comes the above-named Plaintiff seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff is Ronald Goforth, who currently resides at 3624 Lisburn Road Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is Bobbi Goforth, who currently resides at 4934 Norrisville Road, White Hall, Maryland. 3. Plaintiff has been bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and defendant were married on August 3, 2005 York County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither plaintiff nor defendant is in the Armed Forces of the United States or any of its allies. 7. The marriage is irretrievably broken. g. 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, Ronald Goforth, prays that a decree in divorce be entered dissolving the marriage between the two parties. Respectfully Submitted, Wm. C. Felker, Esquire For Plaintiff ID # 67999 P.O. Box 1401 Camp Hill, PA 17001 717-512-0647 a I verify that the statements made in this Complaint are true and correc. of 18 Pa.C St § understandre ating to false statements herein are made subject to the penalties unsworn falsification to authorities. Date: Ronald J. Go orth 00 27 J - i , . 7 ¦ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ¦ Print your name and address on the reverse so th we can return the card to you. ¦ Attadis card to the back of the mailpiece, or on1he front if space permits. 1. Article Addressed to: y? A. Signature ? Agent ? Addre Del B. Received b Printed Name D to 160 (-. D. Is delivery address different from item i . Yes If YES, enter delivery address below: No 3. Se ' e Type Certified Mail 0 Express Mail 0 Registered 0 Return Receipt for Merchandise 0 Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Number (Transfer from service label) 7006 0100 0000 3495 9291 PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1540 UNITED STATES P9k3 A'Yw%RF MD :1 (15 KJ N 21 ? . PM rr • Sender: Please print your name, address, and ZIP4"is box • ?I-T C ?? IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA Ronald Goforth Plaintiff :CIVIL ACTION - LAW V. :DIVORCE Bobbi Goforth :NO. 08-3243 CIVIL TERM Defendant AFFIDAVIT OF SERVICE BY CERTIFIED MAIL AND NOW THIS 17TH day of March 2009, I William Felker, Esquire, attorney for plaintiff, hereby certify that I have served a true and correct copy of the Complaint filed in the above-captioned matter along with a Notice to Defend and Claim Rights upon the defendant, Bobbi Goforth, by certified, return receipt, restricted delivery United States first class mail, to the following address: Bobbi Goforth 4934 Norrisville Road White Hall, MD 21161 The signed receipt is hereto attached. P * ? m. C. Felker Attorney for Plaintiff 67999 P.O. Box 1401 Camp Hill, Pennsylvania 17001 717-512-0647 S?? -;, -;'f1 ?^t t. d. ?;? ,..t ' ? t ? s y ??- y' N ? :c ? a IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA Ronald Goforth Plaintiff :CIVIL ACTION - LAW V. :DIVORCE Bobbi Goforth :NO. 08-3243 CIVIL TERM Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on May 22, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of both 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. 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 my 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. 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. Section 4904 relating to unsworn falsification to authorities. 0'2 8 ox Date: '6 C ' e &to, A "-) Bobbi U L c?7 -t"i . a.r IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA Ronald Goforth Plaintiff :CIVIL ACTION - LAW V. :DIVORCE Bobbi Goforth :NO. 08-3243 CIVIL TERM Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on May 22, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of both the filing and service of the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of the Decree. 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 my 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. 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. Section 4904 relating to unsworn falsification to authorities. Date: 9 Ronald Goforth ?? ? `? :? ,; r ,_-- t_v C? ?, i.:i ' --5 .. a?- f ?? ..f, ?? IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA Ronald Goforth Plaintiff Bobbi Goforth Defendant To the Prothonotary: V. :CIVIL ACTION - LAW :DIVORCE :NO. 08-3243 CIVIL TERM PRAECIPE TO TRANSMIT RECORD 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 the complaint June 05, 2008 by certified, return receipt, restricted delivery United States first class mail. 3. Date of execution of the affidavit of consent required by section 3301(c) of the Divorce Code: by plaintiff on February 17, 2009; by defendant on February 18, 2009. 4. Related claims pending: none. 5. Date plaintiff's Waiver of Notice in section 3301(c) Divorce was filed with the prothonotary: March 19, 2009. Date defendant's Waiver of Notice in section 3301(c) Divorce was filed with the prothonotary: March 19, 2009. Date: March 17, 2009 Wm. C. Felker Attorney for Plaintiff 67999 P.O. Box 1401 Camp Hill, Pennsylvania 17001 717-512-0647 ho3 ?o -_i 71 1. _. ? Ronald Goforth V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Bobbi Goforth NO. 08-3243 Civil Term DIVORCE DECREE AND NOW, it is ordered and decreed that Ronald Goforth plaintiff, and Bobbi Goforth , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (if no claims remain indicate "None.") None B e Court, Attest: J. er- rothonotary f4V