The URL can be used to link to this page

Home My WebLink About10-0383Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) RLED-0 R(*,P Or THE i`l i "12TARY DIANE LYNNE GOLDEN, IN THE COUR41 NCbi1NI0'ff' k1dAS OF Plaintiff CUMBERLAND OUNTY, PENNSYLVANIA .. 1L??i?lt{ vs. CIVIL ACTION HARRY RAYMOND GOLDEN, 10 - 393 (it o lk"-FSS/Z? 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 against you and a decree in 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 with 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 at the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania, 17013-3387. 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. >. in YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO %OT,?HA - A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE t-uWFME,, FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. L CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET ;.; CARLISLE, PENNSYLVANIA 7013 (717) 249-3166 v} N BY ° CJ Andrew C. Sheely, Es ire PA. I.D. No. 62469 127 S. Market Street 1?35?,00 P.O. Box 95 3 9.So Mechanicsburg, PA 17055 39.50 717 697-7050 Attorney for Plaintiff 131.00 CL11 e+--k 3 c, t 7 Kwr- Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) DIANE LYNNE GOLDEN, Plaintiff VS. HARRY RAYMOND GOLDEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 10 - IN DIVORCE NOTICE OF RIGHT TO COUNSELING YOU are one of the parties in the above-captioned action in divorce. By virtue of Section 202 of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the availability of counseling and upon request of either provide both parties with a list of qualified professionals who provide such services. Accordingly, if you desire counseling a list of marriage counselors if available in the office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) DIANE LYNNE GOLDEN, Plaintiff VS. HARRY RAYMOND GOLDEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 10 - 3 K3 Cv ` I erM IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is DIANE LYNNE GOLDEN, an adult individual who currently resides at 301 South Chestnut Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is HARRY RAYMOND GOLDEN, an adult individual who currently resides at 139 Virginia Avenue, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant were residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married in Williamsburg, Virginia, on May 10, 2001. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the United States of America. 7. Plaintiff has been advised of the availability of marriage counseling and understands that she may have the right to request that the court require the parties hereto to participate in counseling. COUNT 1 - DIVORCE - IRRECONCILABLE DIFFERENCES 8. Paragraphs 1 - 7 are incorporated herein as if set forth at length. 9. The marriage between the parties is irretrievably broken. 10. After ninety (90) days have elapsed from the date of filing the divorce complaint, Plaintiff intends to file an affidavit consenting to a divorce and Plaintiff believes Defendant may also file such an affidavit. 11. This divorce action is not collusive. 12. The parties separated on or about November 6, 2008. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from filing of this Divorce Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301(c) of the Pennsylvania Divorce Code. COUNT 2 - DIVORCE - TWO YEAR SEPARATION 13. Paragraphs 1 - 12 are incorporated herein as if set forth at length. 2 14. After a period of two (2) years has elapsed from the date of separation, Plaintiff intends to file her affidavit of having lived separate and apart. WHEREFORE, if two (2) years have elapsed from the date of separation and Plaintiff has filed her affidavit of consent, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301(d) of the Divorce Code. COUNT 3 - DIVORCE - FAULT GROUNDS 15. The allegations in Paragraphs 1 - 14 are incorporated herein and made a part hereof. 16. Defendant committed adultery during the course of the marriage. WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301(a)(2) of the Divorce Code. COUNT 4 - CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 17. The allegations in Paragraphs 1 - 16 are incorporated herein and made a part hereof. 18. Plaintiff and Defendant are the owners of various personal property, motor vehicles, bank accounts, retirement accounts, retirement assets and insurance policies acquired during their 3 marriage. 19. Plaintiff and Defendant are the owners of real property acquired during their marriage. 20. Plaintiff and Defendant have acquired various marital debts during the period of their marriage. WHEREFORE, Plaintiff requests your Honorable Court equitably distribute the parties marital property, including marital debt, and including any such further relief as the Court may determine equitable and just. COUNT 5 - ALIMONY/ALIMONY PENDENTE LITE 21. The allegations in Paragraphs 1 through and including 20 are incorporated herein and made a part hereof. 22. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 23. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. 24. Defendant has earns and has an earning capacity at a much income than Plaintiff. WHEREFORE, Plaintiff requests your Honorable Court to enter an award of alimony pendente lite until final hearing and hereafter enter an award of alimony permanently thereafter. 4 Respectfully submitted, Date: January /Y, 2010 le? Andrew C. Sheely, E /re Attorney for Plain PA ID No. 62469 P.O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 717-697-7050 5 Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) DIANE LYNNE GOLDEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. HARRY RAYMOND GOLDEN, Defendant CIVIL ACTION - LAW 10 - 3 8'3 c IN DIVORCE AFFIDAVIT Diane Lynne Golden, being duly sworn according to law, deposes and says: (1) I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. v bo aw Diane Lynne olden VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: January 2010 "J- dkj Diane Lynne Golden ~~ ~..; , Andrew C. Sheely, Esquire tn ~ 127 S. Market Street a~i9 J~il ~2 ~(~ {~!v'O P.O. Box 95 I+~' Mechanicsburg, PA 17055 PA ID N0. 62469 ~ ~s•'-- - ~ ~`' ~1.3'7i_....:.._. -. c_.' li:.~l.. 717-697-7050 (Phone) r'%-, ~~.,,`'ir~tir~.'`~~4h` 717-697-7065 (Fax) DIANE LYNNE GOLDEN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW HARRY RAYMOND GOLDEN, 10 - 383 Defendant IN DIVORCE AFFIDAVIT OF SERVING COMPLAINT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND ANDREW C. SHEELY, being duly sworn according to law, deposes and says that a true and correct copy of the Divorce Complaint in the above-captioned matter to be served upon HARRY RAYMOND GOLDEN, Defendant, by Certified Mail, Return Receipt Requested, as indicated by the attached receipt card on January 16, 2010. 'l ~J REW C. SHEELY SWORN to and subscribed before me this L~-f~- day o`f January, 2010 Notary ~lic My Commission Expires: ...~ ~{~~Il~, PAC 'may nNoq-.19,~10 ^ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print xour name and address on the reverse so thgt we can return the card to you. ^ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: HARRY RAYMOND GOLDEN RESTRICTED DELIVERY ADDSSEE ONLY 139 VIRGINIA AVENUE CARLISLE, PA 17013 A. Received by (P/eli~,Print-,{ B:~ D~ gfrpflt'Wery C. Signature r ' X ~ ^ Agent ^ Addressee D. Is deliv a Tess different from item 1? ^ Yes If YES, enter delivery address below: ^ No 3. Service Type ~ Certified Mail ^ Express Mail ^ Registered ^ Return Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted DeU'yery? (Extra Fee) ~ Yes 2. Article Number (Copy from service label) 7 0 01 2 510 O D 0 0 3 D 2 9 2 0 4 2 PS Form 3811, JUIy 1999 Domestic Return Receipt 102595.00-M-0952 USPS - Trac~C & Confirm ~~~Trr ~~~~`~ i~~» ~fi 1/18/10 9:25 AM Home (Help. I Sion In ..~..:.~ t ... ~.~ .. .. Track $~ Confirm FA s ~`r~c~C ion#rrn ~~ ~~~ Label/Receipt Number: 7001 2510 0000 3029 2042 Class: First-Class Mail® Service(s): Certified Mail TM Restricted Delivery Return Receipt Status: Delivered Your item was delivered at 4:40 PM on January 16, 2010 in CARLISLE, PA 17013. Detailed Results: * Delivered, January 16, 2010, 4:40 pm, CARLISLE, PA 17013 ^ Acceptance, January 15, 2010, 5:39 pm, MECHANICSBURG, PA 17055 Enter LabellReceipt Number. f .. ... ?. (Ate Icaitort Options Track & Confirm by email Get current event information or updates for your item sent to you or others by email. ~~ Site Map Customer 5erv€ce Forms Gov't Services Careers Privacy Policy Terms of Use Business Customer Gatevrav Cr,~f r€~~.' 2! 9 ll~~~ ~9l ic~frts 1~~~~~rt~ecl. i~3~ F~~Ef,l-t ~u~ ~{? L~at~ (:.{ t http://trkcnfrml.smi.usps.comJPTSlnternetWeb/InterLabellnquiry.do Page 1 of 1