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Home My WebLink About04-3331JOHN E. GOSHORN, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY v. DOCKET NO. dt"~ -333I l..lU~~~~~'' TYRA Y. GOSHORN, CIVIL ACTION -LAW Defendant COMPLAINT IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS TO: Tyra Y. Goshom P. O. Box 134 Newburg, PA 17240 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 aze warned that if you fail to do so, the case may proceed without you and a Decree of Divorce or annulment maybe 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. When the grow3d for divorce is indignities or irretrievable breakdown of the marriage, you may request mamage counseling. A list of marriage counselors is available in the office of the Prothonotary at the Cumberland County Courthouse, One Courthouse Squaze, Carlisle, Pennsylvania. 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. Bedford Street Carlisle, PA 17013 PHONE: 1(800) 990-9108 306668-1 JOHN E. GOSHORN, v. DOCKET NO. Q y- ~-~3 ~ TYRA Y. GOSHORN, CIVIL ACTION -LAW Defendant COMPLAINT IN DIVORCE DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is John E. Goshorn currently residing at 16 Lenwood Park, Shippensburg, Franklin County, Pennsylvania, 17257. 2. Defendant is Tyra Y. Goshom currently residing at P. O. Box 134, Newburg, Cumberland County, Pennsylvania, 17240. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 17, 1995 in Cumberland County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provision of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY 306668-1 6. There have been no prior actions of divorce or for annulment instituted by either of the parties in this or any other jurisdiction. 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. Plaintiff avers that there were no children born of this mamage. COUNTI REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 9. The averments of Paragraphs 1 through 8 hereof are incorporated herein by reference. 10. The marriage of the parties is irretrievably broken. 11. After ninety (90) days have elapsed from the date of the filing and service of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. WHEREFORE, if both parties file Affidavits consenting to a divorce after ninety (90) days have elapsed from the filing and service of this Complaint, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to § 3301(c) of the Divorce Code. 306668-1 COUNT II REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (d) OF THE DIVORCE CODE 12. The averments of Paragraphs 1 through 11 hereof are incorporated herein by reference. 13. The marriage of the parties is irretrievably broken. 14. The parties are living separate and apart; and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two years as specified in § 3301(d) of the Divorce Code. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to § 3301(d) of the Divorce Code. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By G Andrew C. Spears, Esquire Attorney I.D. No. 87737 P.O. Box 5300 Harrisburg, PA 1 7 1 1 0-03 00 (717)238-8187 Attorneys for Plaintiff Dated: ~ I ~ vL~ 306668-1 VERIFICATION I, John E. Goshom, hereby certify that the facts set forth in the foregoing Complaint in Divorce aze true and correct to the best of my knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsification to authorities. ~.~~~~ J E Goshom Date: (~ ~ ~/2fj0~ 306668-1 ~ ~ ~ ~ . O ~' a b ~ J ~-~ ~ ~:~ r t~ N _ ^ ~l C__ i.. _ !_.. --~ ~-.-1T ~ 1 ..,, I w7 , CJ ~ j ~' ._~ n ~ '~ f~: Cj _. LJ P:APILLSVDATAPILEVGeneralACurtenvA113]1 <2prc1 Created'. 9Q0/Oa O.OfiPM Revisal. J/16/05 PSOPM Jennifer I,. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO I.D. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JOHN E. GOSHORN, Plaintiff v. TYRA Y. GOSHORN, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON CUMBERLAND COUNTY. PEl NO. 04-3331 CNIL ACTION -LAW IN DIVORCE PRAECIPE Please withdraw the appearance ofMetzger Wickersham Knauss & Erb on in the above matter. METZGER WICKERSHAM KNA Andrew C. Spears, Esgc I.D. No. 3211 North Front Street P.O. Box 5300 Harrisburg, PA ] 7110 (717) 238-8187 Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO Plaintiff in the above matter. Date: ~I I, ~ I O l MARTSON DEARDORFF By Jenni~j~r L1Spears, Esquire LD. 0.87445 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff IOF VANIA ofPlaintiff ERB behalf of OTTO CERTIFICATE OF SERVICE I, 'fricia D. Eckemoad, an authorized agent for Martson Deardorff Williams certify that a copy of the foregoing Praecipe was served this date by depositing Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Ms. Tyra Y. Goshorn P.O. Box 134 Newburg, PA 17240 MARTSON DEARDORFF Ten East High Street Carlisle, PA 17013 (717)243-3341 Dated: ~ Gil ~~i, zCY~J~ Otto, hereby in the Post & OTTO o ~ ~" x f-; ~ ~'iR ~- -`'~ { . ;pc . ~ ~ i a.. . ~' f ~ -~ Tr t } ~.~. ~ ~~ J* r ~ fV 7 ;, .. . u •~ '~ N ;- ~ ~JJ~.a2.aos 9/20/Oa OD6PM 5/2/05 3d6PM ennifer L. Spears, Esquire 4ARTSON DEARDORFF WILLIAMS & OTTO D. 87445 0 East High Street 'azlisle, PA 17013 117) 243-3341 ,ttornevs for Plaintiff E. GOSHORN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-3331 CIVIL ACTION -LAW Y. GOSHORN, Defendant IN DIVORCE AFFIDAVIT OF SERVICE TH OF PENNSYLVANIA ) OF CUMBERLAND SS. I hereby certify that a copy of the Complaint in Divorce was mailed to Defendant Tyra Y. Thorn at P.O. Box 134 Newburg, PA 17240 on July 19, 2004, by certified mail, restricted very, return receipt requested. Attached is the Post Office return receipt signed "Tyra Y. Goshorn," and dated July 21, 2004. rn to and subscribed re me this "3~~(~ day of 2004. 11 ')I, ~ 1 Ltii 1 /l ~'~-/.2s~-C~' COMMONWkALi 4i 0E PENNSYLVANIA Notarial Seal Mary M. Price, Notary Public Carlisle Boro. Cumberland County My Commission Expires Aug. 18, 2007 Member. Ponnsvivama Association of Notaries __ Je i r L. Speazs, Esquire ar. CERTIFIED MAILrM REGEIP ~ (Domestic Mail Only; Nolnaurance Coverage Provided) _~ r_ S fU /+-.. (` M1 ~ - / ~ Postage ~ t~ $ ` ~, ~ ~ ,~ . ~ ~ Q p CeKitieC fee ur ~. I _' ~ g I V;1' p Remm ReoiePt Fee ere cti (Entloreament Required) ~~ ~ Residcted Delivery Fee V.' ~ i tEndorsement Required) . : ~ ~ ~/1~~-1 ~, t,.t Total Postage 8 Fees $ _, Rl _- O Senl o ° 7 ... y...__-...l~Yr~t --.- .. r - -------.. S`treat Rpt. No, ~/ ar PO BOxN ~ ~ ~! ~~~- 1 ~7 City, $Ya[e. ZlPa4 ~~f ~ /@I~~ ~ F' ~~ l ~eC. ~ V :, " ^ Complete items 1, 2, and 3. Also complete item 4 if Restricted l)elWery is desired. ^ Print your name and address on the reverse so that we can return the cant to you. ^ Attach this cans to the back of the mailpiece, or on the front ff space permits. t. anroie addressed to a~SiBr+='~. X ' ^ a®ent ^ Adds e. Received by rPd d Name/ o. Date of Der D. Ys delivery address different from ream 1? ^ Vea It YES, abler delivery atltlress below: ^ No y ~.~~t( p~. i3~ /} ~ ( 3. Type ~,~ ~' ~J ' /7 ^ / ~~'7 ~ Certified Mall ~/N ^ Repiateratl ^ Insured Mall 4. Restricted Delive z. articleNUmber 7pp2 3150 0~~6 I(ransier from service /ebep PS Form 3811, A&gli5t 2061 Domestic Retum Receipt ^ Exp MaU alum Receipt for Merchandise ^ C.O.D. M (Exaa Fed) ^ Yes 7724 8264 tozsasga-m-tsao i ~ ti~ I~ <7 cs. -n ._{ - _ r T, Itll_ --a _ _..Y; ter; W ~~ (] __ ~_ r .. P. V ILESIpATAFILE1GenercllCwrcnN U] 142.con Ueazed 9/2N04 UDfiPM Revised. SR/OS 3.1 IP`A Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD. 87445 PO East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff E. GOSHORN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-3331 CNIL ACTION -LAW TYRA Y. GOSHORN, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on July 9, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 unsworn :'falsification to authorities. Data: 5 ~ 5 ~ 0 5 ~0. ~ - ~/~~~ Tyra Y. Goshorn, Defendant hJ ~' .rmayy ~ 1 l .J 1{ (~~ ~{ ...n ~~ ~L ~_..' ar. ~% (. i~ `- '- ~ ('~~~ 1 ~ ~~ ~~ "_~.. Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JOHN E. GOSHORN, v. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3331 CNIL ACTION -LAW TYRA Y. GOSHORN, Defendant IN DNORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &33010 AND § 3301(d~ OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice, 2. I understand that I may lose rights concerning alimony, division ofproperty, lawyer's fees or expenses if I do not claim them before a divorce is granted. 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 waiver 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: J ~ ~ ~ ' `/,~'IGi ~ _JV~-v.r~ ~-~,TL~'~ Tyra Y. Goshorn, Defendant „ r-i " ( C i i '~~ ....i : , y :. ~. r r - ~, `, -" ca -, Jennifer L. Speazs, Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JOHN E. GOSHORN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-3331 CNIL ACTION -LAW TYRA Y. GOSHORN, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on July 9, 2004. 2. The marriage ofPlaintiff and Defendant is irretrievably broken and ninety 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 ofthe 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 unsworn falsification to authorities. Date: ~ . ~ "' ~ -~ `~q/ Jo E. Goshorn, Plaintiff ~,~ Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD. 87445 10 East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff JOHN E. GOSHORN, v. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3331 CIVIL ACTION -LAW TYRA Y. GOSHORN, Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301 (c) AND X3301 (dl OF THE DIVORCE CODE 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 waiver 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: -S'.S~- E1 ~, N~~ .~w^'1~.~-- ?o E. Goshom, Plaintiff ro l c : i ~.. [.= FiPoLLSIDATAFILFIGweral\Currentl.l ta]t 61pra2 Crwrod 921V04 0:06PM kevisW J!3/06 2DPM Jennifer L. Spears, Esquire MARTSON DEARDORFF WILLIAMS & OTTO LD. 87445 10 East High Street Carlisle, PA 17013 (7l7} 243-3341 Attorneys for Plaintiff JOHN E. GOSHORN, v. Plaintiff TYRA Y. GOSHORN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3331 CNIL ACTION -LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit therecord, together with the fol lowing information, to the court for entry of a divorce decree: Ground for divorce: irretrievable breakdown under Section 3301(c) ofthe Divorce Code. 2. Date andmannerofserviceofthecomptaint: Viacertifiedmail,restricteddeliveryon July 21, 2004. Date ofexecution ofthe Plaintiff s affidavit ofconsent required by Section 3301(c) ofthe Divorce Code; May 5, 2005; by the Defendant; May 5, 2005; 4. Related claims pending: No claims were raised. 5. DatePlaintifPsWaiverofNoticein§3301(c)DivorcewasfiledwiththeProthonotary: May 12, 2005. Date Defendant's W giver ofNotice in §3301(c) Divorce was filed with the Prothonotary: May ] 0, 2005. Date: March, 2006 MARTSON DEARDORFF WILLIAMS & OTTO By Jennif L Spears, Esquire Ten E st igh Street Carlisle, PA 17013 (717)243-3341 Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLANDCOUNTY STATE OF ~ PENNA. ~ .,,,, ~ ~_ - ~,~. JOHN E. GOSHORN N O. 04-3331 VERSUS TYRA Y. GOSHORN DECREE IN DIVORCE AND NOW, X7"7 Gk.t/+ T ,.200 (i IT IS ORDERED AND DECREED THAT JOHN E. GOSHORN PLAINTIFF, AND TYRA Y. GOSHORN ARE DIVORCED FROM THE BONDS OF MATRIMONY. DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. BY THE COURT: ATTE ~ J ROTHONOTARY t .~~ 1.. ry IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY -PENNSYLVANIA John E. Goshorn, : No. Z~y- ~ 333 j Plaintiff . Civil Action -Law vs. In Divorce Tyra Y. Goshorn . Defendant . NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Defendant in the above matter, having been granted a Final Decree in Divorce on the 7th day of March, 2006, hereby elects to resume the prior name of Tyra Y. Burkholder, and gives this written notice pursuant to the provisions of 54 P.S. Section 704. Date: ~ )(0/0~ 1 ~ GZ- ~5~6~.-'1 Tyra Y. Goshorn Tyra Y. Burkholder F~ ACKNOWLEDGEMENT COMMONWEALTH OF PENNSYLVANIA: :SS COUNTY OF CUMBERLAND On the f ~ day of May, 2007 before me, a Notary Public, personally appeared the above affiant Tyra Y. Goshorn requesting to resume the name of Tyra Y. Burkholder known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing document for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and ofFcial seal. CO W,~"C~H OF PENNSYLVANIA Naaaria~ Seat ~r8 eland bCouniy Nly C~ommtasbn Expires May 31,2010 Notary Pubic My Commission Expires: n ~ ~ _ }~ ~~' ,_ ~ ,a ' ~,, ~ , ; c. ~" ~ ' ,1 ~n ~ c:~ -- ~ ^` ~