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HomeMy WebLinkAbout01-7015ANGELA LYNN GOODYEAR Plaintiff VS. HF, ATH W. GOODYEAR Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO. ~9/- 7~9/0w CIVIL TERM CIVIL ACTION-LAW NOTICE TO DEFEND AND CLAIMS 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 tights 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, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYEWS FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM AN 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 BRI,OW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Lawyer Referral Service 2 Liberty Street Carlisle, Pennsylvania 17013 (717) 249-3166 ANGELA LYNN GOODYEAR : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNA : vs. : NO. CIVIL TERM : HEATH W. GOODYEAR : Defendant : CIVIL ACTION-LAW NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN NAMED DEFENDANT You have been named as a Defendant in a divorce proceeding fried in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with ~3302 (c) or (d) of the Divorce Code, you may request that the court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Cumberland County Courthouse, Cumberland County, Pennsylvania. You're advised that this list is kept as a convenience to you and you're not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. ANGELA LYNN GOODYEAR Plaintiff VS. HEATH W. GOODYEAR Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO.01-70/<~'"CIVIL TERM CIVIL ACTION-LAW DIVORCE COMPLAINT 1. Plaintiff is Angela L. Goodyear who currently resides at 143 Amy Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Heath W. Goodyear, who currently resides at 801 Sand Bank Road, Mount Holly, Cumberland County, Pennsylvania 17065. 3. Angela Goodyear has been a bona fide resident 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 October 11, 1999, at Carlisle, Cumberland County, Pennsylvania. the parties. 6. 7. may have counseling. There have been no prior actions of divorce or for annulment between The marriage is irretrievably broken. Plaintiff has been advised that counseling is available and that Plaintiff the right to request the court to require the parties to participate in Plaintiff requests the court to enter a decree of divorce. Respectfully submitted, ABOM & KUTULA KI$ Date: December 11. 2001 Suite 204 8 South Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff VERIFICATION I, Angela L. Goodyear, hereby verify that the facts set forth in the foregoing Divorce Complaint are true and correct to the best of my knowledge, infomxation and belief. I understand that false statements herein are made subject to the penalties of 18 Pa, C.S. [4904, relating to unswom falsification to authorities. Date: Angela L. Goodyear (3ERTIFICATE OF SERVICE I, Jason P. Kutulakis, Esquire, hereby certify that on this 1 ff~day of December, 2001, a true and correct copy of the within DIVORCE COMPLAINT was served upon Defendant by United States Mail, First Class, postage pre-paid, addressed as follows: Heath Goodyear 801 Sand Bank Road Mt. Holly, PA 17065 Jasor[ P. Kutulakis ANGELA LYNN GOODYEAR Plaintiff VS. HEATH W. GOODYEAR Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO. 01-7015 CIVIL TERM CIVIL ACTION-LAW AFFIDAVIT OF SERVICE I, Jason P. Kutulakis, hereby certify that I served a tree and correct copy of the Complaint Under Section 3301(c) of the Divorce Code, upon the Defendant, by First Class Mail which has not been returned to sender, and by Certified Mail, receipt of which is acknowledged on the attached receipt card on April 11, 2002. Respectfully submitted, ABOM & KUTULAKIS Date: April 17, 2002 n P. I4[utula~is, Esquire omey I.D. No: 80411 Suite 204 8 South Hanover Street Carlisle, PA 17013 Attorney for Plaintiff · 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. · Attach this card to the back of the mailpiece, or on the front if space permits. pS Form ~ A. Received by (Please Print Cleady) Date of DeINe~Y r'3 Yes If YES, enter delive~ address below: [] No Registered Insured Mail ExpreSs. Mai[ [~'~m Receipt for Merchandise C.O.D. Restricted Delivery? (Extra F~e) i"l Yes 102595-00-M-0952 ~ Postage & Fees Pa/dj ( USPS ! · Sender: Please print your name, address, and ZIP+4 in this box · Abom& Kutulakis, L.L.P. 8 S. Hanox~er Street, Suite 204 Carlisle, PA 17013 I'"lll"'llh",,,Ih,lh,,ll,,,Ih,,I,h,,ll,l,l,,I,,llh,,i ANGELA LYNN GOODYEAR Plaintiff VS. HEATH W. GOODYEAR Defendant IN THE COURT OF COMMON PLEAS CUMBEPd-~AND COUNTY, PENNA NO. 01-7015 CIVIL TERM CIVIL ACTION-LAW AFFIDAVIT OF CONSENT 1. A Complaint in divorce under ~3301 (c) of the Divorce Code was filed on December 13, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 unswom falsification to authorities. Date: HEATH W. GOODYEAR ANGELA LYNN GOODYEAR Plaintiff VS. HEATH W. GOODYEAR Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO. 01-7015 CIVIL TERM CML ACTION-LAW 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. 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. ~ 4904 relating to unsworn falsification to authorities. ANGELA LYNN GOODYEAR Plaintiff VS. HEATH W. GOODYEAR Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO. 01-7015 CIVIL TERM CML ACTION-LAW AFFIDAVIT OF CONSENT 1. A Complaint in divorce under ~3301 (c) ot" the Divorce Code was filed on December 13, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days ihave 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 unswom falsification to authorities. ~ ANGELA LYNN GOODYEAR ANGELA LYNN GOODYEAR : IN THE COURT OF COMMON PLEAS Plaintiff : ' CUMBERLAND COUNTY, PENNA : vs. : NO. 01-7015 CIVIL TERM : HEATH W. GOODYEAR : Defendant : CIVIL ACTION-LAW 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 concerrdng 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 un-ill a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is fried 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. [ 4904 relating to unsworn falsification to authorities. Date: ANGELA LYNN GOODYEAR ANGELA LYNN GOODYEAR Plaintiff VS. HEATH W. GOODYEAR Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO. 0~[-7015 CIVIL TERM CIVIL ACTION-LAW PRAECIPE TO TRANSMIT THE RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: Ground for divorce: irretrievable breakdown under ~0301 (c)) 0301 (d)(1)) of the Divorce Code Date and manner of service of the complaint: Certified US M~il, Return Receipl ~Requested 4/17/02_. ~-- o Complete either paragraph (a) or (b): (a) Date of execution of the affidavit of consent required by ~3301 (c) of the Divorce Code: by plaintiff_ 03/15/03 _; by defendant _3/05/03 Related claims pending:~ NONE Complete either paragraph (a) or (b): (b) Date plamtiWs Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: 3/18/03 Date Defendant's Waiver of Notice in ~3301 (0 Divorce was filed with the Prothonotary:~3/11/03 Respectfully submitted, Date: March 27, 2003 ABOM & KUTULAKIS, L.L.P. · v,mra W. Haggerty, Es{[~ ~---~ Attom.ey I.D. No: 86914 Suite 204 8 South Hanover Street Carlisle, PA 17013 (717)249-0900 ~4ttornej for Plaintiff IN STATE OF ANGELA LYNN GOODYEAR, THE COURT OF COIVlMON OF CUMBERLAND COUNTY ~ PENNA. PLAINTIFF VERSUS HEATH W. GOODYEAR, DEFENDANT NO. PLEAS 01-7015 CML TERM DECREED THAT DECREE IN DIVORCE AND NOW,~~~J~::i~~~.~_, iT IS ORDERED AND ANGEI,A LYNN GOODYE. AR , PLAINTIff, AN D HEATH W. GOODYEAR ARE DIVORCED FROM THE BONDS OF MATRIMONY. , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOL1. OWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THiS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; PROTHONOTARY