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Home My WebLink About10-3654LAWRENCE F. GOODMAN, SR., Plaintiff VS. FRANCES P. GOODMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-,3/, -S-Y CIVIL TERM CIVIL ACTION -LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS Q G o YOU HAVE BEEN SUED IN COURT. If you wish to defend against the cls set forth in the following pages, you must take prompt action. You are warned that i t fail to do so, the case may proceed without you and a decree of divorce or annulment be entered against you by the court. A judgment may also be entered against you for an 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 marriage, you must request marriage counseling. A list of marriage counselors is avail- able in the Office of the Prothonotary at CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 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. -v 0 I 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 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 4' MAX J. SMITH, JR., squire JARAD W. HANDELMAN, Esquire Attorney for Plaintiff P.O. Box 650 Hershey, PA 17033 (717) 533-3280 S3SaDO Pd j' A4k'J_y34 766 Max J. Smith, Jr., Esquire Attorney I.D. #32114 Jarad W. Handelman, Esquire Attorney I.D. #82629 James, Smith, Dietterick & Connelly, LLP P.O. Box 650 Hershey, PA 17033 Telephone: 717-533-3280 Fax: 717-533-2795 e-mail: mis(a,isdc.com LAWRENCE F. GOODMAN, SR., Plaintiff vs. FRANCES P. GOODMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO.2010- 3j`f CIVIL TERM CIVIL ACTION -LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the Plaintiff, LAWRENCE F. GOODMAN, SR., by his attor- ney, MAX J. SMITH, JR., Esquire, and seeks to obtain a Decree in Divorce upon the grounds hereinafter more fully set forth: 1. The Plaintiff, LAWRENCE F. GOODMAN, SR., is an adult individual and citizen of the United States of America, who resides at 440 Hilton Head Avenue, Carlisle, Cumberland County, Pennsylvania 17015. 2. The Defendant, FRANCES P. GOODMAN, is an adult individual and citizen of the United States of America, who resides at 602 Smithfield Court, East Stroudsburg, Monroe County, Pennsylvania 18301. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on or about June 7, 2003, in East Stroudsburg, Pennsylvania. Plaintiff avers that there are no children of the parties under the age of 18. 6. Neither Plaintiff nor Defendant is a member of the United States Armed Services. 7. Plaintiff and Defendant have both been advised of the availability of marital counseling and that each may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff avers that there has been one prior action for divorce which was discontinued by reason of inactivity. 9. Plaintiff avers that the marriage is irretrievably broken, pursuant to Section 3301(c) of The Pennsylvania Divorce Code Act 206 of 1990. 10. Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render his condition intolerable and life burdensome, pursuant to Section 3301(a)(6) of The Pennsylvania Divorce Code Act 206 of 1990. 11. This action is not collusive. WHEREFORE, Plaintiff prays your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. Respectfully submitted, L' Date. June 3, 2010 _i MAX J. SMITH, JR., squire I.D. No. 32114 JARAD W. HANDELMAN, Esquire I.D. No. 82629 James, Smith, Dietterick & Connelly LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 I 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. C.S. Section 4904, relating to unsworn falsification to authorities. 2Qf0 J~~ 3Q ~'~ f2~ 51 Nichole M. Staley O'Gorman, Esquire ID #79866 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 nstaley@pkh.com Pct ~i4C,~~~t~ ~:' LAWRENCE F. GOODMAN, SR., Plaintiff v. FRANCES P. GOODMAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2010-3654 CIVIL ACTION -LAW IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: PLEASE enter the appearance of Nichole M. Staley O'Gorman, Esquire, as counsel for the Defendant, Frances P. Goodman, in the above-captioned action. PUR ELL, KRUG & HALLE By: l Nichole . Stal o man, Esquire ' I D #79 6 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney for Defendant DATE: ~ ~ ~(, f - 1 CERTIFICATE OF SERVICE I, Kimberly S. DeFalco, Legal Assistant to Nichole M. Staley O'Gorman, hereby certify that a true and correct copy of the foregoing document was served upon the Plaintiff, by sending a copy of the same via first class U.S. Mail to: Max J. Smith, Jr., Esquire James Smith Dietterick & Connelly LLP 134 Sipe Avenue Hummelstown, PA 17036 ~.~ Kimberly S. D Fal o, Legal Assistant to Nichole M. Staley O'Gorman, Esquire PURCELL, KRUG & HALLER I.D. No. 7986 DATE: ~~~~~`~O LAWRENCE F. GOODMAN, SR., IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. N0.2010-3654 CIVIL TERM ::~ FRANCES P. GOODMAN, :CIVIL ACTION -LAW 7 Q .~ ;„,. Defendant IN DIVORCE ~;'_-~ ~ ~; -_ ,~, ~~: ~, ~; '~t: . _ .__ PRAECIPE ~: - _ _, .. _ ,__ TO THE PROTHONOTARY: ~ ~ c Please formally discontinue the Complaint in Divorce that was filed by the Plaintiff, Lawrence F. Goodman, Sr. on June 3, 2010. Thank you. Date: February 26, 2010 MAX J. SMITH, ., Esquire LD. No. 32114 JARAD W. HANDELMAN, Esquire I.D. No. 82629 James, Smith, Dietterick & Connelly rrr P.O. Box 650 Hershey, PA 17033 (717) 533-3280