HomeMy WebLinkAbout05-2310
.
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLV
NO. ()t;- ;n/() (J;u.-(_'-r?:
CIVIL ACTION - LAW
IN DIVORCE
NIA
Lisa M Goodling,
Plaintiff
rv--\
Jeffrey A Goodling,
Defendant
NOTICE
You have been sued in Court, If you wish to defend against the claims set orth
in the following papers, you must take prompt action. You are warned that if you f il to
do so, the case may proceed without you and a Decree in Divorce or annulment rna 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 mon yor
property or other rights important to you, including custody or visitation of your childr n.
When the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselor is
available in the Office of the Prothonotary at the Cumberland County Courtho se,
Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPER Y,
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 Y U
DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHO E
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEG L
HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
(717) 249-3166
Lisa M Goodling,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLV NIA
NO.dS'- dblO (!;o~L'--rffl..-
Jeffrey A Goodling,
Defendant
CIVIL ACTION. LAW
IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Lisa M Goodling, who currently resides at 1841 Spring oad
Carlisle, Cumberland County Pennsylvania 17013.
2. Defendant is Jeffrey A Goodling who presently resides at 1841 S ring
Road Carlisle, Cumberland County Pennsylvania 17013,
3, Plaintiff has been a bona fide resident in the Commonwealth for at last
six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on August 7, 1993, in Cumberl nd
County, Pennsylvania.
5.
parties,
There have been no prior actions for divorce or annulment between the
6.
The Plaintiff is a citizen of the United States of America.
7. The Defendant is not a member of the Armed Services of the Uni ed
States of America.
8. The Plaintiff has been advised of the availability of counseling and that he
Plaintiff may have the right to request that the Court require the parties to participat in
counseling.
COUNT 1
REQUEST FOR A NO.FAUL T DIVORCE UNDER SECTION 3301 Ie)
OF THE DIVORCE CODE
9. The prior paragraphs of this Complaint are incorporated herein y
reference as though set forth in full.
10. The marriage of the parties is irretrievably broken,
WHEREFORE, Plaintiff requests this Honorable Court to enter a d cree
dissolving the marriage between Plaintiff and Defendant;
Respectfully Submitted,
Miller Lipsitt LLC
By:
Lisa M Goodling,
Plaintiff
v,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLV NIA
NO.
Jeffrey A Goodling,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
VERIFICATION
I verify that the statements made in this Divorce Complaint are true and carre t. I
understand that false statements herein are made subject to the penalties of 18 Pa, .S,
S4904 relating to unsworn falsification to authorities.
c ___
DATE: (trYl,J j 1,8\006
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LISA M. GOODLING,
Plaintiff
v.
JEFFREY A. GOODLING
Defendant
TO THE PROTHONOTARY:
.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 05-2310 CIVIL TERM
: CIVIL ACTION - LAW
: IN DIVORCE
ENTRY OF APPEARANCE
Please enter my appearance as attorney for Jeffrey A. Goodling, Defendant, in the above-
captioned action.
Dated:
Attorney for Defendant
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Lisa M Goodling,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-2310 Civil Term
Jeffrey A Goodling,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
ACCEPTANCE OF SERVICE OF DIVORCE COMPLAINT
I, Jeffrey A Goodling, Defendant in the above captioned matter do hereby on the
date indicated below accept service of the divorce complaint filed by Plaintiff, Lisa M
Goodling, to the above term and docket.
Date:
5N los
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A Goodling, Defend t
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
MICHAEL BONK,
CIVIL DIVISION
Plaintiff,
No, 2005-2301
v,
ISSUE NO.:
GEORGE D, BOYER & SONS, INC.,
Defendant,
PRAECIPE FOR SUBSTITUTION OF
APPEARANCE
Filed on Behalf of Defendant,:
GEORGE D, BOYER & SONS, INC.
Counsel for this party:
BRYAN B, CAMPBELL, ESQUIRE
PA I.D, No. 39312
BASHUNE & HUTION
Suit 3500 One Oliver Plaza
210 Sixth Avenue
Pittsburgh, PA 15222
(412) 434-0201
Firm I.D, No.: 150
JURY TRIAL DEMANDED
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
MICHAEL BONK,
CIVIL DIVISION
Plaintiff,
No, 2005-2301
v,
GEORGE D. BOYER & SONS, INC.,
Defendant,
PRAECIPE FOR SUBSTITUTION OF APPEARANCE
TO: Curt Long, Prothonotary
Kindly substitute the appearance of BRYAN B, CAMPBELL, ESQUIRE on behalf of
Defendant, GEORGE D. BOYER & SONS, INC. in the afore-captioned matter, for William C.
Gallishen, Esquire,
JURY TRIAL DEMANDED,
CERTIFICATE OF SERVICE
I do hereby certify that a true and correct copy of the foregoing PRAECIPE FOR
SUBSTITUTION OF APPEARANCE was served via U.S. First Class Mail, postage pre-paid, on
this ~ day of May, 2005, upon the following counsel of record:
Brian Kadlubek, Esquire
223 Fourth Avenue, 10th Floor
Pittsburgh, PA 15222
(Attorneyfor Plaintiff)
BY:
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Lisa M Goodling,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO. 05-2310 Civil Term
Jeffrey A Goodling,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1, A complaint in Divorce under Section 3301(c) of the Divorce Code was
filed on May 5, 2005 and service was obtained upon the defendant service was
obtained upon the defendant by defendant accepting personal service thereof on
May 9,2005,
2, The marriage of the Plaintiff and Defendant is irretrievably broken and
ninety (90) days have elapsed from the date of filing the Complaint and service
upon Defendant of the same.
3. I consent to the entry of a Final Decree in Divorce after service of notice of
intention to request entry of the decree.
4. I have been advised of the availability of marriage counseling, and
understand that I may request that the Court require that my spouse and I
participate in counseling. I further understand that the Court maintains a list of
marriage counselors in the Prothonotary's Office, which list is available to me
upon request. Being so advised, I do not request that the Court require that my
spouse and I participate in counseling prior to a divorce decree being handed
down by the Court.
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.A, Section 4904, relating to unsworn falsification to authorities.
Date 101 706 ci.mf;fi~~
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Lisa M Goodling,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO, 05-2310 Civil Term
Jeffrey A Goodling,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. 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 herein in this affidavit are true and
correct. I understand that false statements are made subject to the penalties of
18 Pa, C,S, A. Section 4904, relating to unwor falsification of authorities,
Date:
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Lisa M Goodling,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-2310 Civil Term
Jeffrey A Goodling,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was
filed on May 5, 2005 and service was obtained upon the defendant service was
obtained upon the defendant by defendant accepting personal service thereof on
May 9, 2005,
2, The marriage of the Plaintiff and Defendant is irretrievably broken and
ninety (90) days have elapsed from the date of filing the Complaint and service
upon Defendant of the same.
3, I consent to the entry of a Final Decree in Divorce after service of notice of
intention to request entry of the decree.
4, I have been advised of the availability of marriage counseling, and
understand that I may request that the Court require that my spouse and I
participate in counseling. I further understand that the Court maintains a list of
marriage counselors in the Prothonotary's Office, which list is available to me
upon request. Being so advised, I do not request that the Court require that my
spouse and I participate in counseling prior to a divorce decree being handed
down by the Court.
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,SA Section 4904, relating to unsworn falsification to authorities.
Date:
/(}!q(tJ5
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A Goodling /
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Lisa M Goodling,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05-2310 Civil Term
Jeffrey A Goodling,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301{c) OF THE DIVORCE CODE
1, 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 herein in this affidavit are true and
correct. I understand that false statements are made subject to the penalties of
18 Pa. C.S, A. Section 4904, relating to unworn falsification of authorities.
Date:
ft}/q (0$'
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Lisa M Goodling,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 05.2310 Civil Term
Jeffrey A Goodling,
Defendant
CIVIL ACTION. LAW
IN DIVORCE
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 Section 3301 (c) of the
Divorce Code,
2, Date and manner service of the Complaint: Defendant accepted personal service
of a CERTIFIED COPY OF THE COMPLAINT IN DIVORCE on May 9, 2005.
3. Date of execution of the Affidavit of Consent and Waiver of Notice of Intention
Request Entry of a Divorce Decree required by Section 3301 (c) of the Divorce Code:
by Plaintiff: October 7,2005
by Defendant: October 9, 2005
Time Stamped date of Waiver of Notice of Intention Request Entry of a Divorce Decree
required by Section 3301 (c) of the Divorce Code:
by Plaintiff: October 14, 2005
by Defendant: October 14, 2005
4, Related claims pending: There are no related claims pending.
Respectfully Submitted,
Miller Lipsitt LLC
~A..",'--------
By:
James A Mill r, Esquire
Attorney for laintiff
2157 Mar t Street
Camp ill, PA 17011
(717) 737-6400
~~++++~+~++++++++++++~+~~~~++++++++~~+~++~+~++~~++++~+~+~+~+~++++++++++++++++~
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: IN THE COURT OF COMMON PLEAS :
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: OF CUMBERLAND COUNTY :
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+ STATE OF PENNA, +
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: Lisa M Goodling :
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No. 05-2310 +
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Plaintiff
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VERSUS
Jeffrey A Goodling
Defendant
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DECREE IN
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DIVORCE
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r:;io~r, IT IS ORDERED AND
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AND NOW,
}J~I
Lisa M Goodling
DECREED THAT
, PLAINTIFF,
Jeffrey A Goodling
, DEFENDANT,
AND
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;
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PROTHONOTARY
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Lisa. M Goodling,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 05-2310 Civil TeRn
Jeffrey A Goodling,
Defendant
CIVIL ACTION. LAW
IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff I defendant in the above matter,
[select one bymarlcing ''xl
_ prior to the entry of a Final Decree in Divorce,
or X- after the entry of a Final Decree in Divorce dated NO\'~n\lDe.,r I, ~oo5
hereby elects to resume the prior surname of 1ome. '-0 'I ' and gives this
written notice avowing his I her in1ention p. _ t to th p of 54 P .S. 704.
Date: O:tVbtv 11, )()O I.t "
o
vnc .' .
Signature ofname being res
COMMONWEAI-TIi 0.1" PENNSY~V ANIA )
COUNTY OF {'Pm 6 ele. #N d
On the /7 #day of tJcf~" t',f' , 200.f, before me, the Prothonotary or the
notary public, personally appeared the above affiant known to me to be the person whose
name is subscribed to thewitbin document and acknowledged that he I she executed the
foregoing for the purpose therein contained.
In Wi1ness Whereof, I have hereunto set my hand hereunto set my hand and official
seal.
G:n~~
Notary Public
COMMONWEALTH, OF PENNSYLVANIA
i\lot';lMl Seal
Martin RiP.':;Qil Notary Public
Mechanicsburg Boro. ClmberlancJ County
My Commission Expires July 27, 2008
Member. Penn.:;ylvania Asscciatlon Of Notaries
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