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Home My WebLink About05-2110 r ... r . SYLVA K. GOOD, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 0') - ~{(O Civil Term vs. ALAN K. GOOD, ACTION IN DIVORCE Defendant NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in th following pages, you must take prompt action. You are warned that if you fail to do so, the ase may proceed without you and a decree of divorce or armulment may be entered against you the Court. A judgment may also be entered against you for any other claim or relief requested i these papers by the Plaintiff. You may lose money or property or other rights important to y u, including custody or visitation of your children. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU D 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 , . Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SYLVA K. GOOD, vs. No. 0:; - ..l /I oJ Civil Term ALAN K. GOOD, ACTION IN DIVORCE Defendant COMPLAINT IN DIVORCE 1. Plaintiff is Sylva K. Good, a competent adult individual, who resides at 412 N. Pi St., Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Alan K. Good, a competent adult individual, who resides at State Ro te 2014, ShirIeysburg, Pa.. 17260. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for a least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on October 28, 1982 in Mifflin Co ty, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and that plaintiff may have e right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have two children together; however, both are adults. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United St tes of any of its aIlies. - . 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verifY that the statements made in this Complaint are true and correct. I understand hat false statements herein are made subject to the penalties of 18 Pa.C.S. S4904 relating to uns orn falsification to authorities. d) !.v",- , . C) ~-), C {'J Syl 0(1, Plaintiff Date: 4 I ,j, d, , 05'" (1 e Adams, Esquire-. 1. . No. 79465 4 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ~ ~ ......... 10' \)J ~ ~ ~ --.. -- <:::Y --... ~ ......... CJ ~_. \J Q 1'-' ,",;,:,:,,"'J c::.~..' OJ' -- @ C> -11 r'.) ['oJ c'"'l C'J SYLVA K. GOOD, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. oS' - 0I1/() Civil Term vs. ALAN K. GOOD, ACTION IN DIVORCE Defendant NOTICE If you wish to deny any of the statements set forth in this Affidavit, you must file a count r- affidavit within twenty days after this affidavit has been served on you or the statements . I be admitted. AFFIDAVIT OF SEP ARA TION 1. The parties to this action separated in 1986 and have continued to live separate apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose my 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 t at false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to uns orn falsification to authorities. Date:#('('i )~ ~~ . ,'/ 'tt "/ ~... .. Sylva . Good, amtlff r~' ,-~ t~;:.~' \..,..i (;:~ ~-..'l cf' ...-..'" :'.q -;;u ",-" {':.> - (..J~ 1..1:'" SYLVA K. GOOD, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 05-2110 Civil Term ALAN K. GOOD, ACTION IN DIVORCE Defendant AFFlDA VIT OF SERVICE AND NOW, this May 18,2005, I, Jane Adams, Esquire, hereby certifY that on April 28, 2005, a certified true copy of the NOTICE TO DEFEND and COMPLAINT IN DIVORCE AND AFFlDA VIT OF SEP ARA TION were served, via certified mail, restricted delivery, return receipt reque . 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 mallpiece, or on the front jf space permits. Alan Good c/o Joarm Wagne RRl Box 6034 Shirleysburg, Pa. 17260 DEFENDANT 1. Article Addressed to: C. Date of Delive') - ;j;}-o( - D. Is delivery address different from item 1? 0 Yes If YES, enter delivery address below: 0 No )~a"- GO(\d c:/o 3 oC J1 n. LJa(j ^ Pr rZ-? r /3u f.. (,.,o3'{ $h , r ley.s 6-. r Z1' ~/1 ( r7dh) 3. Service Type Ji' Certified Mail o Registered o Insured Mail o Express Mail o Return Receipt for Merchandis~ o C.O.D. 4. Restricted Delivery? (Extra Fee) DYes 2. Article Number (Transfe' from service/eb.O 7('LJ I.j 13';D rf)D 2, II" ~ 7(;;03 PS Form 3811, August 2001 Domestic Return Receipt 102595-01-M-Z5< ams, Esquire . 79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF -J ::;.~,,-:', ~~,) (.""7) (.;"\ :..::-.: -.- Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SYLVA K. GOOD, vs. No. 05 - 2110 Civil Term ALAN K. GOOD, ACTION IN DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under &330lld) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered bv certified mail. restricted- deliverv. Delivered on: Aoril28. 2005. 3. Date of execution of the affidavit required by ~3301(d) of the Divorce Code: By Plaintiff: April 20, 2005. Date of filing and service of the plaintiff's affidavit of separation required by ~3301(d) of the Divorce Code on respondent: Filed: Aoril22. 2005. Served on Defendant: Amil 28. 2005. Affidavit of Service filed: Mav 20. 2005 4. Related claims pending: No claims raised. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which was filed of record with the Prothonotary: Served via certified mail. return receiot reauested. on Mav 21. 2005. Defendant executed a Waiver of Notice on Mav 23. 2005: both were filed with the Prothonotarv on Mav 24. 2005. Date:~I~'5 )bS- J ne Adams, Esquire .D. No. 79465 64 S. Pitt St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff Q f......) (::;) '::-:::~ ('_Il r~) T1 -I ~~p2 =-::i[j' '"~',. [',J- e:'j c_ --', ) ('::.; it; -, (,.0 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '. . .' . . . . . ;t; :I;;t;;f. :f.:t::+::t: . . ... . .. . IN THE COURT OF COMMON PLEAS . . . OF CUMBERLAND COUNTY Sylva K. Good, Plaintiff PENNA. . . STATE OF . . . . . . . . . . . . . No. No. 05 - 2110 Civil Term VERSUS . . . . . Alan K. Good, Defendant . . . DECREE IN DIVORCE AND NOW, ) \9~ - \ , IT IS ORDERED AND , ~ ~~ DECREED THAT Sylva K. Good , PLAINTIFF, AND Alan K. Good , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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. J. BY PROTHONOTARY . . . . Of. ;f:+::f'+' :+::+::+:'f . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .' . b fZ.. /'t? 'z:'" ~ .5cl I -? Pmt?JV ~? ~ ~? p{J 50. / -9 .. -;" ~ .' ~ SYLVA K. GOOD, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA vs, No. 05 - 211O Civil Term ALAN K, GOOD, ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this May 23, 2005, I, Jane Adams, Esquire, hereby certifY that on May 21, 2005 a certified true copy of the NOTICE OF INTENT TO REQUEST FINAL DIVORCE DECREE, and COUNTER-AFFIDAVIT were served, via certified mail, restricted delivery, return receipt requesteo. aoor".."o to' Alan Good c/o Joann Wagner RRI Box 6034 Shirleysburg, Pa, 17260 DEFENDANT . Complete items 1, 2, end 3. Also complete Item 4 If Restricted Delivery Is desired, . Print your nams and address on the reverse so that ws can retum the card to you, . Attach !/lis card to the back of the m~i1plece, or on ti'Ie front W spaca pennits, 1, Article Addressed to: ^)o.h k .Good, % ~A/l1) Wr 5 tu..tt ~, l..OIY ~~'\t'"I~.4vt~" PA I7ZbD 3, SsrvIce '!\'PO . Certified Mall O~ 0....._ o Express Mall o Rebm Receipt for Men:hand/sl o c.o.D. 4. Fb.411 JOIHwwy?__IWJ C.. 2, ArtIcloNumbst 7004 1350 0003 7143 7058 (lhInster from _lobeI) PS Fonn 3811, February 2004 DomelIItc AeIum ~ 1_1M KespeclIUuy ~ut>mItted: J e dams, Esquire I. , 0, 79465 64 South Pitt Street Carlisle, Pa, 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF r--,) ,~ ij; ::~ ;\~ :,,) f'.,) (.,. U,'