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Home My WebLink About10-1018F?\FILES\Chents\13736Goshom\13736.1 Divorce\13736.I.dcom Revised: 2/3/10 3:26PM FILE(??;-FiCE- , ?F TIE P'p * ?'qM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER 2010 FEB -9 AM 9: 29 MARTSON LAW OFFICES I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff TRAVIS A. GOSHORN, Plaintiff V. SANDRA LYNN CONFAIR-GOSHORN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010- /" CIVIL 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. Upon your request, the Court may require you and your spouse to attend up to three sessions. A request for counseling must be made in writing and filed with the Prothonotary within twenty (20) days of receipt of this Notice. 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street a?G,9 Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 a3 7? / r TRAVIS A. GOSHORN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2010- ' 44k CIVIL ACTION - LAW SANDRA LYNN CONFAIR-GOSHORN, : Defendant : IN DIVORCE DIVORCE COMPLAINT UNDER SECTION 3301(C or (D) OF THE DIVORCE CODE 1. Plaintiff is Travis Goshorn, who currently has a mailing address of P.O. Box 108, Spring Run, PA 17262. 2. Defendant is Sandra Lynn Confair-Goshorn, who currently resides at 1215 McCormick Road, Mechanicsburg, Cumberland County, PA 17055. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 23, 2008, in Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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 counseling. 8. When at the appropriate time, Plaintiffwill file an affidavit stating that two years have expired from the date of separation. 9. Plaintiff requests the Court to enter a decree of divorce. WHEREFORE, Plaintiff requests the Court to enter a Decree dissolving the marriage between Plaintiff and Defendant. MARTSON LAW OFFICES By Jennifer L. pears, Esquire 10 East Hi Street Carlisle, PA 17013 (717) 243-3341 Date: February 3, 2010 Attorneys for Plaintiff VERIFICATION The foregoing Divorce Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. I have read the document and to the extent that the document is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. Travis A. Goshorn RECEIVED FEB 0 3 2010 MART SON ~ - F:\FILES\Clirnts\13736 Goshom\13736.1 Divorce\I3736.1.aos Revised: 3/12/IO 8:19AM ftl.EtJ-Q~C~ ?~!~ °~~~~`'~^~~'?-CRY Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS OTTO GILROY2~i~,L~ ~~~ ~: ~ ~ MARTSON LAW OFFICES I.D. 87445 ~Lr;~,r ~~ ;j ~~: 10 East High Street ~r ~ '\~;'• ~ t,',-„ .;~, Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff TRAVIS A. GOSHORN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2010-1018 CIVIL ACTION -LAW SANDRA LYNN CONFAIR-GOSHORN, Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) I hereby certify that a copy of the Complaint in Divorce was mailed to Defendant Sandra Lynn Confair-Goshom at 1215 McCormick Road, Mechanicsburg, PA 17055 on February 9, 2010 by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed "Sandra Confair Goshom" and dated February 12, 2010. ~'"~ pr ~• j~ Jenni ler L. Spears, Esquire Sworn to and subscribed before me this , ~- day of µa,,~h , a.o,o . Notary u lic COMMONyyEALTH OF PENNSYLVANIA Notarial Seel Shelly Brooks, Notary Putrlk Carlisle Boro, Cumberland CourHy CommiNion raa . 6, T013 annrt n of Notaries - •• . ~ ~ p - fti m rn •~ r-R Postage $ ~, ~ s E ~ ~2.8i1 SS Pq Certified Fee ~ ~ 4 '' ~ p Retum Receipt Fee $`7, 3tt ~ d p (Endorsement Required) v /~ W p Fee RestrictedDelhrery l ~ ~ p . (Endorsement Regwred) i ~ . `~lO ~ Total Postage & Fees ~ ~~n' CIS " ~~ r~ ent o ,~' ~ ~ J Sireei, Apr. p ~ / ~ or PO Box No. l~d -------------- -- ----- - City, State. Z!~ L~ ~' -~I/~~G/A/~ ~ /, ^ Complete Items 1, 2, and 3. Also complete A. Signature item 4 if Restricted Delivery is desired. ^ Agent ^ Print your name and address on the reverse ' ~ ^ Addressee so that we can return the card to you. ^ Attach this card to the back of the mailpiece B, Received by (Pdntadpl~te) C D~t f Delivery , or on the front ff space permfts. ~ 1 "C~ le A res sed to: 1. ii's' d~d ~ ~~ D. Is delivery address different from iterr~,1~P^:''Q Yes If YES, enter delivery address E- ~,No ~ ( ~ ~ ~ -~.t~Wlwl(~' C~ n ~ , 1'l_15 '~icC.~si -~t i CSC ~ . , ~ , / ~ ,,_~ a 1~~ 3. Type ~ Certified MaU ^ Express Mail ^ Registered ^ Return Receipt for Mert;handlse ^ Insured Mail O C.O.D. 4. Restricted De)Ivtxy? (Extra Fee) ~ 2. Amide Hktrrtber ~•- (frarwlferfrom srvftve ~ 7 0 0 8 114 ~~ 0^ 1 616 3 3 7 0 8 PS Fomt 3811, Feforu~y 2004 Domestic Return Receipt ~o2se5-o2-~,t-tyto TRAVIS A. GOSHORN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. SANDRA LYNN CONFAIR-GOSHORN NO. 2010-1018 DIVORCE DECREE AND NOW, JG~h ~ ~~ a (~ , it is ordered and decreed that TRAVIS A. GOSHORN SANDRA LYNN CONFAIR-GOSHORN bonds of matrimony. plaintiff, and defendant, are divorced from the 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. By the Court, st: ~, l Prothonotary c~ • 30• I O Cam-+. Co~~ rnc~ IecS +o ~~,~s (~ • 3 0.10 ~o-~ cam. rna~ ~ Q.,d 'r-o a'~e-~-~ .