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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`