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Home My WebLink About04-61530 WILLIAM E. GOOD, Plaintiff V. DIANE C. GOOD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 04- 9IS=3 CIVIL TERM NOTICE TO DEFEND AND CLAIM 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 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, Cumberland County Courthouse, 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, 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 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. WILLIAM E. GOOD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE DIANE C. GOOD, Defendant : NO. 04- CIVIL TERM DIVORCE COMPLAINT WITH EQUITABLE DISTRIBUTION COUNT The plaintiff, William E. Good, by his attorneys, the Family Law Clinic, sets forth the following cause of action in divorce and equitable distribution: COUNT ONE DIVORCE UNDER 23 Pa.C.S. §§3301(c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is William E. Good, who currently resides at 46 East Pomfret Street, Carlisle, Cumberland County, PA 17013 since October 16, 2002. 2. Defendant is Diane C. Good, who currently resides at 1106 Karen Drive East, Carlisle, Cumberland County, PA 17013, since approximately October 1983. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on December 24, 1983 at Carlisle, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since approximately October 16, 2002. 6. There have been no prior actions for divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. 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. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. COUNT II EQUITABLE DISTRIBUTION 9. Plaintiff repeats and realleges paragraphs one through eight. 10. Plaintiff and Defendant have acquired property during their marriage, including, but not limited to, various personal belongings, a mobile home, real estate, and a pension from Lear Corporation in Carlisle, Cumberland County, Pennsylvania. WHEREFORE, Plaintiff requests the court to enter a decree dividing the property equitably between the parties and such relief as the court deems just. Respectfully Submitted, DATE 2A 75 f d j 4AWR LOE S HA R. E Certified Legal Intern A? DONALD-FO)( LUCY JOHNSTON-WALSH THOMAS M. PLACE Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date ?? ? d Plaintiff -*U William Good A IA % c'-a Cv t:? r:l? s \ WILLIAM E. GOOD, Plaintiff V. DIANE C. GOOD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 04- 0-'?'3CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow William E. Good, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date J??g o? spectfully su m tted, CR. GRE Certified Legal Intern ANNE ONALD-FOX LUCY J01 NSTON-WALSH THOMAS M. PLACE Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 • 'r j WILLIAM E. GOOD, Plaintiff V. DIANE C. GOOD, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 04- & CIVIL TERM NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter- affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on October 16, 2002 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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 / -04/ $ /,Dq ® ,p - -? William E. Good Plaintiff i , ! iµ7 ry ?- C ? -ra ?ri B ki ' r ip, WILLIAM E. GOOD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE DIANE C. GOOD, Defendant : NO. 04- 6153 CIVIL TERM CERTIFICATION OF SERVICE I, Carlesha R. Green, Certified Legal Intern, Family Law Clinic, hereby certify that I am serving a true and correct copy of the Complaint for Divorce on Diane Good residing at 1106 Karen Drive East, Cumberland County, Walnut Bottom, Pennsylvania, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested. Service was complete upon receipt by Diane Good on December 9, 2004, as evidenced by the attached green card with the article number 7003 31 10 0004 5774 2693. Carlesha R. Gri Certified Legal FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 p?+ l r? ? .? r•:' . a ?' r` 1 ? , r.? ...t_i i . p i, _ s,- (, .,; 4 l„'? ` , WILLIAM E. GOOD, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE DIANE C. GOOD, Defendant : NO. 04- 6153 CIVIL TERM CERTIFICATION OF SERVICE I, Rene M. Gomall, Certified Legal Intern, Family Law Clinic, hereby certify that the Family Law Clinic served a true and correct copy of the Complaint for Divorce on Diane Good residing at 1106 Karen Drive East, Cumberland County, Walnut Bottom, Pennsylvania, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested. Service was complete upon receipt by Diane Good on December 9, 2004, as evidenced by the attached green card with the article number 7003 3110 0004 5774 2693. R e M. Gornall Certified Legal I ern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 L S. Postal Service.., ERTIFIED MAILr,., RECEIPT omestic Mail Only; No Insurance Coverag± Provides OFFI C IAL U M1 Ott Postage s 7 . C3 Certified FW E3 Retum Realepl Fee (EMore9meM R!Zmd) 7 ?;2+ara * }' t ) ^ Restricted Delivery Fee dl n M (Endorsarnera RequIMd) ? Total Postage & Fees i s It co FjWW O o y? 7 y !'J n/ ¦ 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. 1. Article Addressed to: ? c wrLe ?Lw?2 A. Received by (Please Print Clserly) I lB. Dete Dalive 1 C. Sign X ? Agent ? Addressee d ad(r,'& L em 1? ? Yes If YES, enter delivery address below: ? No 3. Service Type Certified Mail ? Express Mail Ragistered x) Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) -VYes 2. Article Number (Copy from service label) -oo,3 3,id Oc?`/ S??y a? /3 PS Form 3811, July 1999 Domestic Return Receipt 102595-99-M-1789 _., ?., =; r? ' ? -,, r,. -- _ .?;? - - ?' ? r„ ?. Curtis R. Long Prothonotary office of the Vrotbonotarp Cumberlattb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor Oq - 1 / S3 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6571