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Home My WebLink About08-5146 SCOTT R. GOSHORN, Plaintiff V. JENNIFER L. GOSHORN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: ?F SIUU ?iV? I rM CIVII. 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 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, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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 South Bedford St. Carlisle, PA 17013 (717) 249-3166 OR (800) 990-9108 SCOTT R. GOSHORN, Plaintiff V. JENNIFER L. GOSHORN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: CIVIL ACTION - LAW IN DIVORCE COMPLAINT 1. Plaintiff is Scott R. Goshorn, who currently resides at 423 N. East Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Jennifer L. Goshorn, who currently resides at 7 S. Hanover Street, Apartment 2, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 12, 2005. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Divorce is sought pursuant to the provisions of the Divorce Code, § 3301(c), and §3301(d) in that: The marriage is irretrievably broken. 7. 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 such counseling. v 8. Plaintiff does not request counseling, pursuant to §§3301(c) and 3301(d) of the Divorce Code. 9. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. Respectfully Date: L,2 7- 0 S Afidrew H. Shaw, Esquire 200 S. Spring Garden Street Suite 11 Carlisle, PA 17013 (717) 243-7135 (717)243-7872 facsimile Attorney for Plaintiff VERIFICATION I, Scott R. Goshorn, 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. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Date: ?-Z-Ov LA3 ./J? d, 4 IL , cAcott'R. -M horn N ?) CJ C) T_i t Y::: r tsTM ' - 5h K„W T! v a7s ¢" V ?} 2 ....... t?? ' ?s !A SCOTT R. GOSHORN, Plaintiff V. JENNIFER L. GOSHORN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 0&5146 CIVIL ACTION - LAW IN DIVORCE PROOF OF SERVICE I, Andrew H. Shaw, Counsel for the Plaintiff, Scott R. Goshorn, hereby certify that a true and correct copy of the Divorce Complaint in the above captioned case was served upon Defendant via First Class Mail on September 27, 2008. A copy of the Acceptance of Service is attached. Q aC Date: oC PA Sup. Ct. ID Num. 87371 200 S. Spring Garden St., Suite 11 Carlisle, PA 17013 717-243-7135 Counsel for Plaintiff 4 1? SCOTT R. GOSHORN, Plaintiff V. JENNIFER L. GOSHORN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 0&5146 CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Jennifer L. Goshorn, hereby accept service of the Divorce Complaint. Date: 4-? '? CERTIFICATE OF SERVICE I, Andrew H. Shaw, Esquire, do hereby certify that a true and correct copy of the following document, Proof of Service, was served this date on the below named, by placing same in the United States mail, first-class, postage prepaid thereon, addressed as follows: Jennifer L. Goshorn 7 S. Hanover Street, Apt. 2 Carlisle, PA 17013 Date: P --'z 7 - Q R Sup. Ct. I.D. No. 87371 200 S. Spring Garden Street Carlisle, PA 17013 (717) 243-7135 (phone) (717) 243-7872 (facsimile) Attorney for Plaintiff ?_ ? i .3 C . -xZ ,? i,i t,~??' C/1 ?'? r-n ' ' ? t"t1 ?---?"' -,- i`t' :? `, ?? 3- ,. y ? ? ._. ?..;An ., e . ?? ?? SCOTT R. GOSHORN, Plaintiff V. JENNIFER L. GOSHORN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 08-5146 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301 (c) of the Divorce Code was filed on August 27, 2008. 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 the decree. 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. § 4904 relating to unsworn falsification to authorities. Dated: (?f( P7 OF THE F' Y E009 Jt1 122 F 2'. u SCOTT R. GOSHORN, Plaintiff V. JENNIFER L. GOSHORN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 08-5146 CIVIL ACTION - LAW IN DIVORCE 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 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. A DATE: Goshorn, Defendant FILED OF THE F 1,1,;n?,OTARY 2009 9 JILj N 22 F ?i 2: 13 J tavt• '..'u'?? Ty SCOTT R. GOSHORN, Plaintiff V. JENNIFER L. GOSHORN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 08-5146 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301 (c) of the Divorce Code was filed on August 27, 2008. 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 the decree. 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. § 4904 relating to unsworn falsification to authorities. Dated: I (b_- tt R. G shorn, Plaintiff FILED-,,-,,--"r(CE 20€9 AN 22 PH 2: 34 j lP R. SCOTT R. GOSHORN, Plaintiff V. JENNIFER L. GOSHORN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 08-5146 CIVIL ACTION - LAW IN DIVORCE 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 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: tb ?Ift oshorn, Plaintiff OF THE F "I"', ?:',l.? 4 iii-• i,?4 SCOTT R. GOSHORN, Plaintiff V. JENNIFER L. GOSHORN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO: 08-5146 CIVIL ACTION - LAW 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 Divorce: Irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of Service signed by Defendant on September 27, 2008. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code: by Plaintiff on June 10, 2009; by Defendant on June 10, 2009; 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice was filed with the Prothonotary's Office: June 12, 2009. Date Defendant's Waiver of Notice was filed with the Prothonotary's Office: June 12, 2009. / a Date: By: j Zt, Andrew H. Shaw, Esquire Attorney I.D. # 87371 200 Spring Garden Street, Ste. 11 Carlisle, PA 17013 Attorney for Plaintiff A - CERTIFICATE OF SERVICE I, Andrew H. Shaw, Esquire, do hereby certify that a true and correct copy of the following document, Praecipe to Transmit Record, was served this date on the below named, by placing same in the United States mail, first-class, postage prepaid thereon, addressed as follows: Jennifer L. Goshorn 7 S. Hanover Street, Apt. 2 Carlisle, PA 17013 r^' Date: ?., ( ?J L Sup. Ct. I.D. No. 87371 200 S. Spring Garden Street Carlisle, PA 17013 (717) 243-7135 (phone) (717) 243-7872 (facsimile) Attorney for Plaintiff ,T TH TARY 20H JUN 22 P 2: 3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT R. GOSHORN V. JENNIFER L. GOSHORN DIVORCE DECREE , it is ordered and decreed that AND NOW, ALW-Ap SCOTT R. GOSHORN plaintiff, and JENNIFER L. GOSHORN , 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. 08-5146 D Prot onotary 0,7 Xao IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW r?V l Plaintiff FILE NO. U/ 20A VS. 1??t6 60?k/oDq Defendant IN DIVORCE o A c w 0 b tau NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the 30 day of , hereby elects to resume the prior surname of N d \ and gives this written notice pursuant to the provisions of 14 P.S. 704. DATE: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND V Signature gna of name big resumed : SS. On the 20411 day of A. L(.5- 20 before me, a Notary Public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. Y21 _J Notary Pub$c 0.00 Pis CASH ? ilrl 1Z#a74704,