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Home My WebLink About04-4170DARLENE K. EVANS-GOTT, Plaintiff ROBERT MAX GOTT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW 1N DIVORCE NOTICE 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. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Streets, Carlisle. 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 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 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. DARLENE K. : EVANS-GOTT, : Plaintiff : : vi. : : ROBERT MAX GOTT : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW (~r~.~ IN DIVORCE COMPLAINT UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. Plaintiff is Darlene Kathryn Evans-Gott, who currently resides at 2131 Longs Gap Rd., Cumberlan County, Pennsylvania, since September 29, 1999. ~.I,-[~1~/ lOAf ~ Defendant is Robert Max Gott, who currently resides at 2131 Longs Gap Rd., 2. Cumberland County, Pennsylvania, since September 29, 1999. ~__..~,.~1,..~ ~, / ¢~p, 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on June 1, 1993, in Pensarola, Florida. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 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. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Date: August 23, 2004 By: Karl E. Rominger, Esquire Attorney for Plaintiff 155 South Hanover Street Carlisle, PA 17013 Supreme Court I.D. #81924 (717) 241-6070 VERIFICATION 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. ~ 4904, relating to unsworn falsification to authorities. Darlene K. Evans-Gott, Plaintiff DARLENE K. EVANS-GOTT Plaintiff ROBERT M. GOTT Defendant : 1N THE COURT ,OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 4170 - 04 CIVIL TERM : IN DWORCE ACCEPTANCE OF SERVICE I hereby accept service of the Complaim in Divorce on behalf of the Defendant, Robert M. Gott, in the above-captioned action and I certify that I am authorized to do so. Robert M. Gott, Defendant DARLENE K. EVANS-GOTT, Plaintiff V. ROBERT M. GOTT, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 4170 - 04 CIVIL TERM : IN DIVORCE MOTION FOR ALIMONY PENDENTE LITE AND NOW, comes Darlene K. Evans-Gott, by and through her privately retained counsel, Karl E. Rominger, Esquire, and in support of this Motion avers as follows: 1. Plaintiff filed a Divorce Complaint on August 23, 2004. 2. Plaintiff makes a claim for Alimony Pendente Lite in Count II of said Complaint. 3. Plaintiff is unable to provide for, or afford her necessary and reasonable counsel fees, expenses and costs during the pendency of this divorce action, and through its resolution. 4. Plaintiff is unable to sustain herself during the course of this litigation. 5. Plaintiff requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, your Petitioner prays this Honorable Court to award Alimony Pendente Lite in an amount equal to the Pennsylvania State support guidelines. Date: C~ ~- / Respectfully submitted, ROMINGER & BAYLEY /Karl E. Rominger, Esquire 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Plaintiff CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attomey for Darlene Gott-Evans, do hereby certify that I this day served a copy of the Motion for Alimony Pendente Lite upon the following by depositing same in the United States mail, First Class Mail, postage paid, at Carlisle, Pennsylvania, addressed as follows: Rickie Shadday Conference Officer Domestic Relations Office 9 North Hanover Street Carlisle, PA 17013 Dale F. Shughart, Jr., Esquire 35 East High Street, Suite 202 Carlisle, PA 17013 Michael R. Rundle, Esquire Domestic Relations Office 9 North Hanover Street Carlisle, PA 17013 Respectfully submitted, ROMINGER & BAYLEY K~~I E.~omin~'~"--ger,' Esquire 155 S. Hanover Street Carlisle, PA 17013 (717) 241~6070 Supreme Court I.D. # 81924 Attorney for Plaintiff DARLENE K. EVANS-GOTT, Plaintiff V. ROBERT M. GOTT, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO. 4170 - 04 CIVIL TERM : IN DIVORCE PRAECIPE TO ADD ADDITIONAL COUNT IN DIVORCE TO THE PROTHONOTARY: Please add an additional count of Alimony Pendente Lite to the above divorce matter. Karl E. Rominger, Esquire 155 S. Hanover Street Carlisle, PA 17C~13 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Plaintiff DARLENE K. EV ANS-GOTT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW ROBERT M. GOTT, Defendant :NO.4170-04 : IN DIVORCE CIVIL TERM PRAECIPE TO WITHDRAW MOTION FOR ALIMONY PENDETE LITE TO THE PROTHONOTARY: Please withdraw the above captioned Motion for Alimony Pendente Lite by agreement of the parties. Date: January 20, 2005 Respectfully submitted, ROMINGER, BAYLEY & WHARE /'7 // ~'. Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff cc. Rickie Shadday Domestic Relations Conference Officer Michael R. Rundle, Esquire Domestic Relations Dale F. Shughart, Jr., Esquire .." DARLENE K. EV ANS-GOTT Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW ROBERT M. GOTT Defendant : NO. 4170 - 04 : IN DIVORCE CIVIL TERM PRAECIPE TO WITHDRAW DIVORCE ACTION TO THE PROTHONOTARY: Please withdraw the above captioned divorce action by agreement of the parties. Date: January 20, 2005 Respectfully submitted, ROMINGER, BAYLEY & WHARE /7 /,/ Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff cc. Dale F. Shughart, Jr., Esquire In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION DARLENE K. EVANS-GOTT ) Docket Number 04-4170 CIVIL Plaintiff ) vs. ) PACSES Case Number 512107075 ROBERT M. GOTT ) Defendant ) Other State ID Number ORDER AND NOW, to wit on this 7TH DAY OF FEBRUARY, 2005 IT IS HEREBY ORDERED that the 0 Complaint for Support or 0 Petition to Modify or (i) Other ALIMONY PENDENTE LITE filed on 12/27/04 in the above captioned matter is dismissed without prejudice due to: THE PLAINTIFF WITHDRAWING HER REQUEST FOR ALIMONY PENDENTE LITE CONFERENCE. o . !he Complaint or Petition may be reinstated upon written application of the plaintiff petitIOner. ORa: RJ Shad day xc: plaintiff defend8B.t Dale Shughart, Esquire Karl Rominger, Esquire BY THE C 'sub, i~leY "iuDGE Service Type M FOTIn OE-506 Worker ID 21005 ------ " '," -