HomeMy WebLinkAbout08-3251
Kerriann Good IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. NO. 08- 3a5 j CIVIL TERM
Stephen O. Good
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 adecree
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 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 Courthouse, 1 Courthouse Square, 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 Bar Association
32 S. Bedford Street
Carlisle, PA 17013
(717) 249-3166
w
Kerriann Good
Plaintiff
V.
Stephen O. Good
Defendant
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY PENNSYLVANIA
NO. 08- CIVIL TERM
IN DIVORCE
COMPLAINT UNDER -3301(c) or (d) OF THE DIVORCE CODE
-111, h31111!!!1!11 1. Plaintiff is , who currently resirlPC nt
2
u, 1% 11
3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at
least the six months prior to the filing of this Complaint.
4. Plaintiff and Defendant were married on flC 1l ???
at
5. The marriage is irretrievably broken, and the parties separated on
6. There have been no prior actions of divorce or annulment between the parties.
7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the
military service of the United States of America, but is in fact living at the address
given in Paragraph 2 above.
Uumberland County, Pennsylvania.
Defendant is _S?Pf?he , who currently resides at
v
r
A
8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have
the right to request that the Court require the parties participate in counseling.
WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce.
Date Plaintiff, Pro Se
verify that the statements made in this Complaint
are true and correct to the best of my knowledge, information, and belief. I understand that false
statements made herein are subject to the penalties for unsworn falsification to authorities' as
provided in 18 Pa. C.S. §4904.
Date:
Plaintiff, Pro Se
Assisted by:
Thomas J. Williams, Esq.
Martson, Deardorff, Williams & Otto
10 E. High Street
Carlisle, PA 17013
(717) 243-1383
c?
c
Kerriann Good
Plaintiff
V.
Stephen O. Good
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
NO. 08- 3,x51 CIVIL TERM
. IN DIVORCE
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, Kerriann Good. Plaintiff, to proceed in forma au eris.
I, Thomas J. Williams, attorney for the party proceeding in forma 12auperis, certify that I
believe the party is unable to pay the costs and that I am providing free legal services to the
party.
Thomas J. Will s, Esquire
Attorney for Plaintiff
Martson, Deardorff, Williams & Otto
10 E. High Street
Carlisle, PA 17013
(717) 243-3341
I
a
{ y
s r.
?~i g
co
Kerriann Good IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. NO.08 37.5 CIVIL TERM
Stephen O. Good
Defendant IN DIVORCE
AFFIDAVIT OF SERVICE
I, # • i[ J. Vljj(JK?eing duly sworn according to law, depose and say that on
I LM e (Date of signing of the green card by spouse), I served a true and
correct copy of the Divorce Complaint upon the Defendant, by Certified Mail, Restricted
Deliver. addressed as follows:
The Certified Mail Return Receipt Mailing Card ("Green Card"), for the foregoing is attached
hereto and made a part hereof. ?a. ?tlL
S' ture
S i jGI%1?
Printed Name
Sworn to and subscribed before me a
Notary Public in and for Cumberland
Countj yennsyly is
this eday of tL 2001,
,%%,'WA0NWEf" :r= PENNSYLVANIA
Seal
Shelly fivers rotary Public
Carlisle Born Comerland County
Mtv Commissior ,r s Aug. 5, 2009
.:,. t! F•v1 .i 3...6 ,,.n of Rotaries
ARY PUBLIC
My commission expires:
I. .,
%%.X vMAXkt
''%
A.
X 0 A 9W
0
B. Received by.(Printed Abm) of 01
D. "Yes
ter,
0 No
,y?,e pS - M
1 Is.
Certified Mall C? Maid
1 P 1 0 Repwww 0 Return Receipt for mwdwdise
I A 1?V{ ! O Insured Mail 0 C.C.D.
4. Restricted Delivery? Pft Fee) Yes
2. Ar ide Number
(rrm+siftrnserWoe/abeQ 7003 3110 0004 5772 5641
PS Form 3811, Febhwy 204 Do, 111ti Rebim
102585-02-Md540
¦ Complete Items 1, 2, and 3. Also complete
item 4 If Restricted Delivery is desired.
• .Print your name and address on the reverse
so that we can return the card to you.
f Attach this card to the back of the mailplece,
or on t1w front If space permits.
1. Atllolr Ad" to:
hi l
ao7 ixPd ??Q?rL
Z
rl
.0
Lr) (Domestic Only; No Insurance coverage Provided)
r1J
r?
00
Postage s o.70 09
cereeed Fee $2.20
E3 ,
C3
r-I cFnd rn° Required) ?8 w
rrt Total Postage & Fees $ s
W
M
0
M o
t
":J
Kerriann Good IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. NO. 08- '? I CIVIL TERM
Stephen O. Good
Defendant IN DIVORCE
ACCEPTANCE OF SERVICE
I, _ Stephen O. Good (Defendant), accepted service of a true and correct copy of the
Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below.
I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904,
relating to unsworn falsification to authorities.
?/ 0/00 44
Date Stephen XOGood, Defendant
i
to
CA
tsx
Kerriann Good IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. NO. 08- 31151 CIVIL TERM
Stephen O. Good
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A c mplaint in divorce under §3301(c) of the Divorce Code was filed on
0 0
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 after service of notice of
intention to request entry of divorce.
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: 1 s'QV Signature: ( I mm(AV/ un
Kerriann Good, Plaintiff
i
?:T
". _? _?
i
? ;
-?? = .
?? v ',
t r..' .-f
?- c.. ..
?.., =?.;
-, .?"
Kerriann Good IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. NO.08-,325-/ CIVIL TERM
Stephen O. Good
Defendant IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER 43301(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.
I verify that 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: 9 Signature: 1-17 1-1-1h
Kerriann Good, Plaintiff
? ,
?,
c. ?.??
f,„+`°?
..,..
r.
,
.w, •, r=rt
?
,? , _
? .,?''=
'°'
fit, ?::
Kerriann Good IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY PENNSYLVANIA
V. NO.08-,3a5-/ CIVIL TERM
Stephen O. Good
Defendant IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under §3301(c) of the Divorce Code was filed on
all -0 3
0
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 after service of notice of
intention to request entry of divorce.
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: 0q Signature:
Stephen O. Good, Defendant
'TARY
2I9 9 f I A 2 1 Ff ': 4
t
Kerriann Good
Plaintiff
V.
Stephen O. Good
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
NO.08-,3,j / CIVILTERM
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER §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. 1 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 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• 6 oNO Signature:
Stephen O. Good, Defendant
OF T-C-
2uu91" i ii `s' 21 P'i; ?? Ll''
Kerriann
V.
Stephen O.
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY PENNSYLVANIA
NO.08AZI CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To The
the record, together with the following information, to the Court for
entry of a d?vorce decree:
1. round for divorce: Irretrievable breakdown under Section 3301(c) of the
2. ate and Manner of service of the Complaint: Defendant signed Acceptance
i-- _j_A.. m"t of QPruirP fnrm nn ?Iwf 3U. 206f
3. Date of execution of the Affidavit of Consent required by Section 3301(c) of
the Divorc Code: by Plaintiff, 3 10 ; by Defendant, Oq
4. Related claims pending: There are no outstanding claims.
5. Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with
the Prothonotary: q151b..9
(c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed
with the P othonotary:
Plaintiff ,? Social Security Number:
is Social Security Number:
WAWA cal
aa?- L( 5-a_( a
Kerriann Good
OF THE f E ' >. T,-
2009 JUN -2 Ail S: 2:'a
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
KERRIANN GOOD
V.
STEPHEN O. GOOD
DIVORCE DECREE
AND NOW, zos , it is ordered and decreed that
KERRIANN GOOD , plaintiff, and
STEPHEN O. GOOD , 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.
NO. 08-3251
•
By the Court,
Attest- l J
rothonotary
to ? ? °l?y' `7ld?o ??a?? ? G`