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Home My WebLink About10-1757JOSEPH R. GOODRUM Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: /O I7S7 (?/Yi l ANGELA S. GOODRUM c Defendant CIVIL ACTION - LAW _ IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against e 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 ?m 0A rn .n 'ew - 43 ?",7 - G C" A l / t" - 5 fi eusmly C? 1 t(3 JOSEPH R. GOODRUM Plaintiff V. ANGELA S. GOODRUM Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 10 - l 7 -5- 7 c N? l -f -fA CIVIL ACTION - LAW IN DIVORCE ORDER OF COURT You, Angela S. Goodrum, have been sued in court to obtain custody of the children: Gavriella E. Goodrum and Anaielle L. Goodrum You are ordered to appear in person at: on the day of _ , 2010 at M. for () a conciliation or mediation conference, () a pretrial conference, () a hearing before the court. If you fail to appear as provided by this order, an order for partial custody may be entered against you, or the court may issue a warrant for your arrest. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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. Court Administrator Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 (717) 240-6100 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. BY THE COURT: Date: J. JOSEPH R. GOODRUM Plaintiff V. ANGELA S. GOODRUM Defendant COMPLAINT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: jQ -- 17 S7 c:v? I It/-,, CIVIL ACTION - LAW IN DIVORCE AND NOW, comes Plaintiff by and through his counsel, Andrew H. Shaw, and brings this Custody Complaint: 1. Plaintiff is an adult individual residing at 635 N. East St., Carlisle, Cumberland County, Pennsylvania. 2. Defendant, Angela S. Goodrum, is an adult individual residing at 635 N. East St., Carlisle, Cumberland County, Pennsylvania. COUNT I - DIVORCE 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 February 14, 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, Sections 3301(c), and 3301(d), in that the marriage is irretrievably broke. 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. 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. COUNT U - CUSTODY 10. Plaintiff incorporates Paragraphs 1 through 9 as if set forth more fully herein. 11. Plaintiff seeks custody of the following children (hereinafter "Children"): a. Gavriella E. Goodrum; age 2 years old (DOB: May 11, 2007) b. Anaielle L. Goodrum; age 1 year old (DOB: September 26, 2008) 12. The Children were not born out of wedlock. 13. The Children are currently residing with Plaintiff and Defendant at 635 N. East St., Carlisle, Pennsylvania. 14. During the past five years, the Children have resided with the following persons and at the following address: a. Gavriella E. Goodrum: 1. 47-443 Ahuimanu Rd., Kaneohe, HI 96744. With Plaintiff and Defendant, (Birth to Thanksgiving 2007); 2. 47-739 Kamehameha Highway, Kaneohe, HI 96744. With Plaintiff and Defendant, (Thanksgiving 2007 to February 2009); 3. 13 Hilltop Dr. Mt. Holly Sp. Pa 17065. Resided with Defendant's mother, (February 24, 2009 to May 2009); 4. 635 N. East St. Carlisle, PA 17013,With Plaintiff and Defendant (May 2009 to present). b. Anaielle L. Goodrum: 1. 47-739 Kamehameha Highway, Kaneohe, HI 96744. With Plaintiff and Defendant, (Birth to February 2009); 2. 13 Hilltop Dr. Mt. Holly Sp. Pa 17065. Resided with Defendant's mother, (February 24, 2009 to May 2009); 3. 635 N. East St. Carlisle, PA 17013, With Plaintiff and Defendant (May 2009 to present). 15. Plaintiff is the father of the Children, and is currently married to, but separated from, Defendant. 16. Defendant is the mother of the Children. IT Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the Children in this or another court. 18. Plaintiff has no information of a custody proceeding concerning the Children pending in a court of this Commonwealth or any other state. 19. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the Children or claims to have custody or visitation rights with respect to the Children. 20. The best interests and permanent welfare of the Children will be served by granting the relief requested because of the following facts: a. Defendant does not intend to take custody of the Children; b. Plaintiff has solely cared for the Children since birth. 21. Each parent whose parental rights to the Children have not been terminated and the person who has physical custody of the Children have been named as parties to this action. There are no other persons known to have or claim a right to custody or visitation of the Children. WHEREFORE, Plaintiff requests this Court award sole legal and physical custody of the Children to Plaintiff, and award periods of visitation to the Defendant, as the parties mutually agree. Respectfully submitted, Date: 3 - / (` lo By: Andrew H. Shaw, Esquire Sup. Ct. ID No.: 87371 200 S. Spring Garden St., Suite 11 Carlisle, PA 17013 (717) 243-7135 (717) 243-7872 (facsimile) Attorney for Plaintiff VERIFICATION I, Joseph R. Goodrum, 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: J ph R. Goodrum IL 1W JOSEPH R. GOODRUM Plaintiff V. ANGELA S. GOODRUM Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: m I7 ?? C.,vy I I C ?i4 c CIVIL. ACTION - LAW T, a C= 77 ? IN DIVORCE -- -`? -- C, ?i T' CUSTODY STIPULATION = :- R, l•` /?? < THIS AGREEMENT, made this )1 day of , 2010, by and between JOSEPH R. GOODRUM, (hereinafter referred to as "Plaintiff/Father"), and ANGELA S. GOODRUM (hereinafter referred to as "Defendant/Mother'). WHEREAS, Plaintiff and Defendant are parents of two minor children, namely: Gavriella E. Goodrum, age 2 years, having been born May 11, 2007, and Anaielle L. Goodrum, age 1 year, having been born September 26, 2008. WHEREAS, the parties agree to have an Order entered upon the following terms: NOW, THEREFORE, in consideration of the mutual promises hereinafter set forth, and intending to be legally bound hereby, it is agreed by and between the parties hereto as follows: 1. Father shall enjoy sole legal custody. 2. Father shall have primary physical custody of the Children. Mother shall enjoy periods of visitation as the parties mutually agree. 3. Both parents are encouraged to accommodate the reasonable request of the other parent for alteration of any agreed-upon schedule, as the circumstances and best interests of the children require. k .. -i 4. The parties hereby stipulate and request that this Custody Stipulation be made an Order of Court without Ae parties having to appear in open court. VI T!- --- J PH R. GOODRUM, Plaintiff/Father AN LA S. GOODRUM, Defendant/Mother 2 ti MAR I 2 2010 I-- JOSEPH R. GOODRUM Plaintiff V. ANGELA S. GOODRUM Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: # - /75-7 CIVIL ACTION - LAW IN DIVORCE CUSTODY ORDER AND NOW, this ? day of A 0,r V\o% 2010 it is hereby Ordered and Decreed that the Custody Stipulation signed on March 11, 2010 by Plaintiff, Joseph R. Goodrum, and Defendant, Angela S. Goodrum, is hereby entered as an Order of Court. By the Court: ?Ik J. 1 JOSEPH R. G IN THE COURT OF COMMON PLEAS OF RUM :CUMBERLAND COUNTY, PENNSYLVANIA ANGELA S. GC~ODRUM No. 10-1757 DIVORCE DECREE AND NOW, _ JOSEPH R. GC 1u Z DRUM ~0 ~~ , it is ordered and decreed that ANGELA S. GC bonds of m DRUM plaintiff, and defendant, are divorced from the Any existing~spousal support order shall hereafter be deemed an order for alimony pendente I~te if any economic claims remain pending. The court regains jurisdiction of any claims raised by the parties to this action for which a final or er has not yet been entered. Those claims are as follows: (If no claims remain indi ate "None.") None. By the Court, Attest: J. P othonotary -7.ao.to ~ moo. ~ o Cs,~--~ _ ~'`~- tom;, l e.c~ fU~fi~ Y~a.:1~c~ ~-o -4a fla-l~. S~ncx~ ~_