HomeMy WebLinkAbout05-4378JEFFREY S. UNITIS and, IN THE COURT OF COMMON PLEAS OF
KAREN UNITIS, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
vs. CIVIL ACTION -LAW
NO. 2005- 4/376 Cc? -JaAA'-
LEE ANN GOGGANS and
LLOYD RUSSELL GOGGANS,
Defendants IN CUSTODY
COMPLAINT FOR CUSTODY
NOW COMES JEFFREY S. UNITIS and KAREN UNITIS, by and through their
counsel, SAIDIS, SHUFF, FLOWER & LINDSAY, and state as follows:
1. The Plaintiffs are Jeffrey S. Unitis and Karen Unitis, residing at 1340
Kuhn Road, Boiling Springs, Cumberland County, Pennsylvania 17007.
2. Defendant Lee Ann Goggans resides at 14309 Blue Grass Drive,
Huntersville, North Carolina 28078.
3. Defendant Lloyd Russell Goggans resides at 4 Indian Trail, Lake Dallas,
Texas 75065.
4. The Plaintiffs seek custody of Brandon Russell Goggans, born July 27,
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATrORNEYS•AT•LAW
26 W. High Street
Carlisle, PA
1993. His present residence is with the Plaintiffs, Jeffrey S. Unitis and Karen Unitis,
1340 Kuhn Road, Boiling Springs, Cumberland County, Pennsylvania 17007.
4. The child was not born out of wedlock.
5. The child is presently in the custody of Plaintiffs, who reside at 1340
Kuhn Road, Boiling Springs, Cumberland County, Pennsylvania 17007.
6. During the past five years, the child has resided with the following
persons and at the following addresses:
NAME
Lee Ann Goggans
Jeffrey S. Unitis,
Karen Unitis and children
ADDRESS
14309 Blue Grass Drive
Huntersville, NC
1340 Kuhn Road
Boiling Springs, PA
FROM/TO
2000 - June 2005
June 2005 - Present
7. The mother of the child is Lee Ann Goggans, who resides at 14309 Blue
Grass Drive, Huntersville, North Carolina 28078.
8. She is divorced.
9. The father of the child is Lloyd Russell Goggans, who resides at 4 Indian
Trail, Lake Dallas, Texas 75065.
10. He is divorced.
11. The relationship of the Plaintiffs to the child is that of maternal uncle and
aunt. Plaintiffs currently reside with their children.
12. The relationship of Defendants to the child is that of parents.
13. The Plaintiffs have not participated as a party or witness, or in any other
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATTORNEYS-AT-LAW
26 W. High Street
Carlisle, PA
capacity, in other litigation concerning the custody of the child in this or another
jurisdiction. However, the Defendants were parties to a divorce and custody action in
the 393rd Judicial District, Benton County, Texas. Attached hereto as Exhibit "A" is an
Agreed Final Decree of Divorce which includes a provision providing shared legal
custody to the parents and primary physical custody of the child to Defendant Lee Ann
Goggans.
14. The Plaintiffs do not know of a person not a party to the proceedings who
has physical custody of the child.
15. The best interest and permanent welfare of the child will be served by
2
granting the relief requested because:
a) The parents of the child, Defendants above, are in
agreement that the child's best interest will be
served by permitting him to reside with Plaintiffs
Jeffrey and Karen Unitis.
b) Defendant Lee Ann Goggans is struggling with
illness and must, nevertheless, work two jobs in
order to support herself. Defendant Lloyd Russell
Goggans was in agreement that the child spend the
summer with Plaintiffs Jeffrey and Karen Unitis and
believes that it will continue to be in the child's best
interest to remain residing with Plaintiffs Jeffrey and
Karen Unitis.
c) Both Defendants intend to maintain a close and
loving relationship with the child while he continues
to reside with Plaintiffs.
16. Each parent whose parental rights to the child have not been terminated
and the person who has physical custody of the child have been named as parties to
this action.
WHEREFORE, the Plaintiffs request this Court to grant custody of the child to
the Plaintiffs.
Respectfully submitted,
SAIDIS, SHUFF, FLOWER & LINDSAY
Attorneys for Plaintiffs _
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATTORNEVS•AT•LAW
26 W. High Street
Carlisle, PA
r
Dated: 2- 5 By: /
61
Carol J. Li ds y, Esgl,
ID # 446
26 W. High Street
Carlisle, PA 17013
Telephone: 243-6222
VERIFICATION
I, the undersigned, hereby verify that the statements made herein 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.
{y , FFREY S. UNITIS
Dated:
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATTORMYS•AT•LAW
26 W. High Street
Carlisle, PA
8:29AM;INTER-TES- ;7045223672 # 41 32
y/? 1F
NO. 97-30592-211
IN THE MATTER OF
THE MARRIAGE OF
LLOYD RUSSELL GOGGANS
AND
LEE ANN GOGGANS
AND IN THE INTEREST OF
JENNIFER GOGGANS AND
BRANDON GOGGANS, CHILDREN
II 'z,
§ IN THE DISTRICT C01V9'J'
§ ',•'s. /cam
§ 393rd JUDICIAL DISTRICT,
§
§ DENTON COUNTY, TEXAS
AGREED FINAL DECREE OF DIVORCE
On the _ day of January, 2001, this case came on for hearing.
Appearances
Petitioner, LLOYD RUSSELL GOGGANS, appeared in person, and by and through his
attorney of record, Hardy Burke, and has agreed to the terms of this decree as evidenced by his
signature below.
Respondent, LEE ANN GOGGANS, appeared by and through her attorney of record, lane
Thacker and has agreed to the terms of this decree as evidenced by her signature below.
Record
The record of testimony was duly reported by the Court Reporter of the 393`d Judicial
District Court.
Jurisdiction and Domicile
The Court finds that the pleadings of Petitioner are in due form and contain all the
allegations, information, and prerequisites required by law. The Court, after receiving evidence,
finds that it has jurisdiction of this case and of all the parties and that at least sixty days have
elapsed since the date the suit was filed. The Court finds Petitioner has been a domiciliary of
Texas for at least a six-month period preceding the filing of this action and a resident of the county
in which this suit is filed for at least a ninety-day period preceding the filing of this action. All
persons entitled to citation were properly cited.
Final Decree of Divome (GOGGANS) - Page I
8-,6-05: 8: 29AIdy INTHF-TEL ;7045223672
Jury
A jury was waived, and all questions of fact and of law were submitted to the Court.
Agreement of Parties
The Court finds that the parties have entered into an agreement which is contained in this
decree. To the extent permitted by law, the parties stipulate the agreement is enforceable as a
contract. The Court approves the agreement of the parties as contained in this Final Decree of
Divorce.
Divorce
IT IS ORDERED AND DECREED that LLOYD RUSSELL GOGGANS, Petitioner, and
LEE ANN GOGGANS, Respondent, are divorced and that the marriage between them is
dissolved.
Children of the Marriage
The Court finds that Petitioner and Respondent are the parents of the following children:
Name: JENNIFER GOGGANS
Sex: Female
Birthplace: Dallas, Texas
Birth date: April 19, 1987
Home State: Texas
Name: BRANDON GOGGANS
Sex: Male
Birthplace: Denton, Texas
Birth date: July 27, 1993
Home State: Texas
The Court finds that no other children are expected.
Conservatorship and Support
The Court, having considered the circumstances of the parents and of the children, finds
that the following orders are in the best interest of the children.
# 5/ 32
Final Decree of Divorce (GOGGANS) - Page 2
B-18-05; 8:20AM;!NTER-TEL
;7045223672 ? 61 32
2. the duty to support the children, including providing the children with clothing, food,
shelter, and medical and dental care not involving an invasive procedure;
3. the right to consent for the children to medical and dental care not involving an invasive
procedure;
4. the right to consent for the children to medical, dental, and surgical treatment during an
emergency involving immediate danger to the health and safety of the children; and
5, the right to direct the moral and religious training of the children
IT IS ORDERED that LLOYD RUSSELL GOGGANS, as parent joint managing
conservator, shall have the following rights and duty:
the right to consent to medical, dental, and surgical treatment involving invasive
procedures and to consent to psychiatric and psychological treatment of the
children;
2. the right to represent the children in legal action and to make other decisions of
substantial legal significance concerning the children;
3. the right to consent to marriage and to enlistment in the armed forces of the United
States;
4. the right to make joint decisions concerning the children's education;
5. the right to the services and earnings of the children;
6. except when a guardian of the children's estates or a guardian or attorney ad litem
has been appointed for the children, the right to act as an agent of the children in
relation to the children's estate if the children's action are required by a state, the
United States, or a foreign government; and
7. the duty to manage the estate of the children to the extent the estate have been
created by community property or the joint property of the parents.
IT IS ORDERED that LEE ANN GOGGANS, as parentjoint managing conservator, shall
have the following rights and duties:
1. the exclusive right to determine the primary physical residence of the children without
regard or restriction to geographic location;
Final Decree of Divorce (GOGGANS) - Page 4
8-18-05; 8:29AM;INTER-TEL ;7045223672 # 7/ 32
Joint Managing Conservators
IT IS ORDERED that LLOYD RUSSELL GOGGANS and LEE ANN GOGGANS are
appointed joint managing conservators of the children.
IT IS ORDERED that, at all times, LLOYD RUSSELL GOGGANS and LEE ANN
GOGGANS, as joint managing conservators, shall each have the following rights and duties:
1. the right to receive information from the other parent concerning the health, education,
and welfare of the children;
2. the duty to inform the other parent in a timely manner of significant information
concerning the health, education, and welfare of the children;
3. the right to confer with the other parent to the extent possible before making a decision
concerning the health, education, and welfare of the children;
4. the right of access to medical, dental, psychological, and educational records of the
children;
5. the right to consult with a physician, dentist, or psychologist of the children;
6. the right to consult with school officials concerning the children's welfare and
educational status, including school activities;
7. the right to attend school activities;
8. the right to be designated on the children's records as a person to be notified in case of
an emergency;
9. the right to consent to medical, dental, and surgical treatment during an emergency
involving an immediate danger to the health and safety of the children; and
10. the right to manage the estates of the children to the extent the estates have been
created by the parent or the parent's family.
IT IS ORDERED that, during their respective periods of possession, LLOYD RUSSELL
GOGGANS and LEE ANN GOGGANS, as joint managing conservators, shall each have the
following rights and duties:
1. the duty of care, control, protection, and reasonable discipline of the children;
Final Decree of Divorce (GOGGANS) - Page 3
B-18-OS; B;29AM;) NTEF-TEL
:7045223672 4 8/ 32
2. the right to consent to medical, dental, and surgical treatment involving invasive
procedures and to consent to psychiatric and psychological treatment of the children;
3. the right to receive and give receipt for periodic payments for the support of the children
and to hold or disburse these funds for the benefit of the children;
4. the right to represent the children in legal action and to make other decisions of
substantial legal significance concerning the children;
5. the right to consent to marriage and to enlistment in the armed forces of the United
states;
6. the right to make decisions concerning the children's education;
7. the right to the services and earnings of the children;
8. except when a guardian of the children's estates or a guardian or attorney ad litem has
been appointed for the children, the right to act as an agent of the children in relation to
the children's estate if the children's action are required by a state, the United States, or
a foreign government; and
9. the duty to manage the estate of the children to the extent the estate have been
created by community property or the joint property of the parents.
Residence of Children
LEE ANN GOGGANS shall have the exclusive right to establish the primary residence of
the children without regard or restriction to geographic area.
Property of Children
The parties' children possess no property or assets other than personal effects.
Standard Possession Order
The Court finds that the following provisions of this Standard Possession Order are
intended to and do comply with the requirements of Texas Family Code Sections 153.311 through
153.317. IT IS ORDERED that the conservators shall comply with all terms and conditions of this
Standard Possession Order. IT IS ORDERED that this Standard possession Order is effective
immediately and applies to all periods of possession occurring on and after the signing of this
Standard Possession Order. IT IS ORDERED:
Final Decree of Divorce (GOGGANS) - Page 5
8-i5-05: 6:29AM:INTEF-TEL
a. Definitions:
:7045223672 # 9/ 32
1. In this Possession Order "school" means the primary or secondary school in which
the child is enrolled or, if the child is not enrolled in a primary or secondary school, the public
school district in which the child primarily resides.
2. In this Possession Order "child" includes each child, whether one or more, who is a
subject of this suit while that child is under the age of eighteen years and not otherwise
emancipated.
b. Mutual Agreement or Specified Terms for Possession:
IT IS ORDERED that the joint managing conservators shall have possession of the
child at times mutually agreed to in advance by the parties, and, in the absence of mutual
agreement, it is ORDERED that the joint managing conservators shall have possession of the
child under the specified terms set out in this Possession Order.
IT IS ORDERED AND DECREED that possession of the child by LLOYD RUSSELL
GOGGANS shall be as follows:
A. Parents Who Reside 100 Miles or Less Apart
Except as otherwise explicitly provided in this Possession Order, when LLOYD RUSSELL
GOGGANS resides 100 miles or less from the primary residence of the child, LLOYD RUSSELL
GOGGANS shall have the right to possession of the child as follows:
1. Weekends: On weekends, beginning 6:00 P.M. on the first, third, and fifth
Friday of each month and ending at 6:00 P.M. the following Sunday.
2. Wednesdays: On Wednesday of each week during the regular school term,
beginning at 6:00 p.m. and ending at 8:00 p.m.
3. Sorin¢ Break in Even-Numbered Years: In even-numbered years, beginning at
6:00 p.m. on the day the child is dismissed from school for the school's spring
vacation and ending at 6:00 P.M. on the day before school resumes after that
vacation.
4. Extended Summer Possession by LLOYD RUSSELL GOGGANS
With Written Notice by April 1- If LLOYD RUSSELL GOGGANS gives LEE
ANN GOGGANS written notice by April 1 of each year specifying an extended period or
periods of summer possession for that year, LLOYD RUSSELL GOGGANS shall have
possession of the child for thirty days beginning not earlier than the day after the child's
Final Decree of Divorce (GOGGANS) - Page 6
8-16-05{ 8:29AM{INTER-TEL
47045223672 # 10/ 32
school is dismissed for the summer vacation and ending not later than seven days before
school resumes at the end of the summer vacation in that year, to be exercised in not more
than two separate periods of at least seven consecutive days each, as specified in the
written notice. These periods of possession shall begin and end at 6:00 P.M.
Without Written Notice by April 1- If LLOYD RUSSELL GOGGANS does not
give LEE ANN GOGGANS written notice by April 1 of each year specifying an extended
period or periods of summer possession for that year, LLOYD RUSSELL GOGGANS
shall have possession of the child for thirty consecutive days in that year beginning at 6:00
P.M. on July 1 and ending at 6:00 PM. on July 31.
Notwithstanding the weekend and weekday periods of possession ORDERED for LLOYD
RUSSELL GOGGANS, it is explicitly ORDERED that LEE ANN GOGGANS shall have a
superior right of possession of the child as follows:
1. Snring Break in Odd-Numbered Years In add-numbered years, beginning at 6:00
p.m. on the day the child is dismissed from school for the school's spring vacation
and ending at 6:00 p.m. on the day before school resumes after that vacation.
2. Summer Weekend Possession by LEE ANN GOGGANS If LEE ANN
GOGGANS gives LLOYD RUSSELL GOGGANS written notice by April 15 of
each year, LEE ANN GOGGANS shall have possession of the child on any one
weekend beginning at 6:00 P.M. on Friday and ending at 6:00 P.M. on the
following Sunday during any one period of the extended summer possession by
LLOYD RUSSELL GOGGANS in that year, provided that LEE ANN GOGGANS
picks up the child from LLOYD RUSSELL GOGGANS and returns the child to
that same place.
3. Extended Summer Possession by LEE ANN GOGGANS If LEE ANN
GOGGANS gives LLOYD RUSSELL GOGGANS written notice by April 15 of
each year or gives LLOYD RUSSELL GOGGANS fourteen days' written notice on
or after April 16 of each year, LEE ANN GOGGANS may designate one weekend
beginning no earlier than the day after the child's school is dismissed for the
summer vacation and ending no later than seven days before school resumes at the
end of the summer vacation, during which an otherwise scheduled weekend period
of possession by LLOYD RUSSELL GOGGANS shall not take place in that year,
provided that the weekend so designated does not interfere with LLOYD
RUSSELL GOGGANS' period or periods of extended summer possession or with
Father's Day Weekend.
Final Decree of Divorce (GOGGANS) - Page 7
8-18-05; 8:29AM;INTER-TEL
B. Parents Who Reside More Than 100 Miles Apart
;7045223672 # 11/ 32
Except as otherwise explicitly provided in this Possession Order, when LLOYD RUSSELL
GOGGANS resides more than 100 miles from the residence of the child, LLOYD RUSSELL
GOGGANS shall have the right to possession of the child as follows:
1. Weekends Unless LLOYD RUSSELL GOGGANS elects the alternative period of
weekend possession described in the next paragraph, LLOYD RUSSELL
GOGGANS shall have the right to possession of the child on weekends, beginning
at 6:00 P.M. on the first, third, and fifth Friday of each month and ending at 6:00
P.M. on the following Sunday.
Alternate weekend possession In lieu of the weekend possession described in the
foregoing paragraph, LLOYD RUSSELL GOGGANS shall have the right to
possession of the child not more than one weekend per month of LLOYD
RUSSELL GOGGANS' choice beginning at 6:00 P.M. on the day school recesses
for the weekend and ending at 6:00 P.M, on the day before school resumes after
the weekend, provided that LLOYD RUSSELL GOGGANS gives LEE ANN
GOGGANS 14 days' written or telephonic notice preceding a designated weekend,
and provided that LLOYD RUSSELL GOGGANS elects an option for this
alternative period of possession by written notice given to LEE ANN GOGGANS
within 90 days after the parties begin to reside more than 100 miles apart, as
applicable.
2. Spring Break in All Years- Every year, beginning at 6:00 PM, on the day the child
is dismissed from school for the school's spring vacation and ending at 6:00 P.M.
on the day before school resumes after that vacation.
3. Extended Summer Possession by LLOYD RUSSELL GOGGANS
With Written Notice by April 1- If LLOYD RUSSELL GOGGANS gives LEE
ANN GOGGANS written notice by April 1 of each year specifying an extended period or
periods of summer possession for that year, LLOYD RUSSELL GOGGANS shall have
possession of the child for 42 days beginning not earlier than the day after the child's
school is dismissed for the summer vacation and ending not later than seven days before
school resumes at the end of the summer vacation in that year, to be exercised in not more
than two separate periods of at least seven consecutive days each, as specified in the
written notice. These periods of possession shall begin and end at 6:00 P.M.
Without Written Notice by April 1- If LLOYD RUSSELL GOGGANS does not
give LEE ANN GOGGANS written notice by April 1 of each year specifying an extended
period or periods of summer possession for that year, LLOYD RUSSELL GOGGANS
shall have possession of the child for 42 consecutive days beginning at 6:00 P.M. on June
Final Decree of Divorce (GOGGANS) - Page 8
8-18-05; 8:29AM:INTER-7EL
15 and ending at 6:00 P.M. on July 27 of that year.
{7045223672 # 12/ 32
Notwithstanding the weekend periods of possession ORDERED for LLOYD RUSSELL
GOGGANS, it is explicitly ORDERED that LEE ANN GOGGANS shall have a superior right of
possession of the child as follows:
1. Summer Weekend Possession by LEE ANN GOGGANS- If LEE ANN
GOGGANS gives LLOYD RUSSELL GOGGANS written notice by April 15 of each year,
LEE ANN GOGGANS shall have possession of the child on any one weekend beginning at
6:00 P.M. on Friday and ending at 6:00 P.M. on the following Sunday during any one
period of possession by LLOYD RUSSELL GOGGANS during LLOYD RUSSELL
GOGGANS' extended summer possession in that year, provided that if a period of
possession by LLOYD RUSSELL GOGGANS in that year exceeds thirty days, LEE ANN
GOGGANS may have possession of the child under the terms of this section on any two
nonconsecutive weekends during that period and provided that LEE ANN GOGGANS
picks up the child from LLOYD RUSSELL GOGGANS and returns the child to that same
place.
2. Extended Summer Possession by LEE ANN GOGGANS- If LEE ANN
GOGGANS gives LLOYD RUSSELL GOGGANS written notice by April 15 of each year,
LEE ANN GOGGANS may designate 21 days beginning no earlier than the day after the
child's school is dismissed for the summer vacation and ending no later than seven days
before school resumes at the end of the summer vacation in that year, to be exercised in
not more than two separate periods of at least seven consecutive days each, during which
LLOYD RUSSELL GOGGANS may not have possession of the child, provided that the
period or periods so designated do not interfere with LLOYD RUSSELL GOGGANS'
period or periods of extended summer possession or with Father's Day.
C. Possession Periods Unaffected by Distance Parents Reside Apart
The following provisions govern possession of the child for certain specific holidays and
specific occasions and supersede conflicting weekend or Wednesday periods of possession without
regard to the distance the parents reside apart. LEE ANN GOGGANS and LLOYD RUSSELL
GOGGANS shall have rights of possession of the child as follows:
1. Christmas Holidays - LLOYD RUSSELL GOGGANS shall have possession of the
child in even-numbered years beginning at 6:00 p.m. on the day the child is
dismissed from school for the Christmas School vacation and ending at noon on
December 26, and LEE ANN GOGGANS shall have possession for the same
period in odd-numbered years.
LLOYD RUSSELL GOGGANS shall have possession of the child in odd-numbered
years beginning at noon on December 26 and ending at 6:00 p. m. on the day before
Final Decree of Divorce (GOGGANS) - Page 9
8-18-05; 8:29AM;IN7EF-7EL
;7045223672 # 13/ 32
school resumes after that vacation, and LEE ANN GOGGANS shall have
possession for the same period in even-numbered years.
2. Thanknivine - LLOYD RUSSELL GOGGANS shall have possession of the child
in odd-numbered years, beginning at 6:00 p.m. on the day the child is dismissed
from school before Thanksgiving and ending at 6:00 P.M. on the following
Sunday, and LEE ANN GOGGANS shall have possession for the same period in
even-numbered years.
Child's Birthday - If LLOYD RUSSELL GOGGANS is not otherwise entitled
under this Standard Possession Order to present possession of the child on the
child's birthday, LLOYD RUSSELL GOGGANS shall have possession of the child
beginning at 6:00 P.M. and ending at 8:00 P.M. on that day, provided that
LLOYD RUSSELL GOGGANS picks up the child from LEE ANN GOGGANS'
residence and returns the child to that same place.
If LEE ANN GOGGANS is not otherwise entitled under this Standard Possession
Order to present possession of the child on the child's birthday, LEE ANN
GOGGANS shall have possession of the child beginning at 6:00 P.M. and ending
at 8:00 PM. on that day, provided that LEE ANN GOGGANS picks up the child
from LLOYD RUSSELL GOGGANS' residence and returns the child to that same
place.
4. Father's Day Weekend - LLOYD RUSSELL GOGGANS shall have possession of
the child beginning at 6:00 P.M. on the Friday preceding Father's Day and ending
at 6:00 P.M. on Father's Day, provided that if he is not otherwise entitled under
this Standard Possession Order to present possession of the child, he shall pick up
the child from the residence of the conservator entitled to possession and return the
child to that same place.
5. Mother's Day Weekend - LEE ANN GOGGANS shall have possession of the
child, beginning at 6:00 P.M. on the Friday preceding Mother's Day and ending at
6:00 P.M. on Mother's Day, provided that if she is not otherwise entitled under
this Standard Possession Order to present possession of the child, she shall pick up
the child from the residence of the conservator entitled to possession and return the
child to that same place.
Weekend Possession Extended by Holiday - If a weekend period of possession by
LLOYD RUSSELL GOGGANS coincides with a school holiday during the regular
school term or with a federal, state, or local holiday during the summer months in
which school is not in session, the weekend possession shall end at 6:00 p.m. on a
Monday holiday or school holiday or shall begin at 6:00 p.m. Thursday for a
Friday holiday or school holiday, as applicable.
Final Decree of Divorce (GOGGANS) - Page 10
8-18-05; 8:29AM;IN75R-7EL
General Terms and Conditions
;7045223672 # 14/ 32
Except as otherwise explicitly provided in this Standard Possession Order or unless the
parties agree to other terms and conditions, the terms and conditions of possession of the child that
apply regardless of the distance between the residence of a parent and the child are as follows:
1. Surrender of Child by LEE ANN GOGGANS- LEE ANN GOGGANS is
ORDERED to surrender the child to LLOYD RUSSELL GOGGANS at the beginning of
each period of LLOYD RUSSELL GOGGANS' possession at the residence of LEE ANN
GOGGANS or at the school in which the child is enrolled as applicable.
2. Return of Child by LLOYD RUSSELL GOGGANS- LLOYD RUSSELL
GOGGANS is ORDERED to return the child to the residence of LEE ANN GOGGANS or
at the school in which the child is enrolled at the end of each period of possession, as
applicable.
However, LLOYD RUSSELL GOGGANS shall surrender the child to LEE ANN
GOGGANS at the end of each period of possession at the residence of LLOYD RUSSELL
GOGGANS if:
(i) at the time the original order or a modification of an order establishing
terms and conditions of possession or access LLOYD RUSSELL
GOGGANS and LEE ANN GOGGANS lived in the same county, LLOYD
RUSSELL GOGGANS' county of residence remains the same after the
rendition of the order, and LEE ANN GOGGANS' county of residence
changes, effective on the date of the change of residence by LEE ANN
GOGGANS; or
(ii) LLOYD RUSSELL GOGGANS and LEE ANN GOGGANS lived in the
same residence at any time during a six-month period preceding the date on
which a suit for dissolution of the marriage was filed and LLOYD
RUSSELL GOGGANS' county of residence remains the same and LEE
ANN GOGGANS' county of residence changes after they no longer live in
the same residence, effective on the date the order is rendered.
3. Surrender of Child by LLOYD RUSSELL GOGGANS- LLOYD RUSSELL
GOGGANS is ORDERED to surrender the child to LEE ANN GOGGANS, if the child is
in LLOYD RUSSELL GOGGANS' possession or subject to LLOYD RUSSELL
GOGGANS' control, at the beginning of each period of LEE ANN GOGGANS' exclusive
periods of possession, at the place designated in this Standard Possession Order.
Final Decree or Divorce (GOGGANS) - Page I I
8-18-05; 8:29AM;INTER-TEL
;7045223672 # 15/ 32
4. Return of Child by LEE ANN GOGGANS- LEE ANN GOGGANS is ORDERED
to return the child to LLOYD RUSSELL GOGGANS, if LLOYD RUSSELL GOGGANS
is entitled to possession of the child, at the end of each of LEE ANN GOGGANS'
exclusive periods of possession, at the place designated in this Standard Possession Order.
5. Personal Effects- Each conservator is ORDERED to return with the child the
personal effects that the child brought at the beginning of the period of possession.
6. Designation of Competent Adult- Each conservator may designate any competent
adult to pick up and return the child, as applicable. IT IS ORDERED that a conservator or
a designated competent adult be present when the child is picked up or returned.
7. Inability to Exercise Possession- Each conservator is ORDERED to give notice to
the person in possession of the child on each occasion that the conservator will be unable to
exercise that conservator's right of possession for any specified period.
8. Written Notice- Written notice shall be deemed to have been timely made if
received or postmarked before or at the time that notice is due.
9. School Notice - If a conservator's time of possession of a child ends at the time
school resumes and for any reason the child is not or will not be returned to school, the
conservator in possession of the child shall immediately notify the school and the other
conservator that the child will not be or has not been returned to school.
Provisions for Long Distance Access and Visitation.
Except as otherwise agreed to, the following arrangements for the travel of the children, if
LLOYD RUSSELL GOGGANS resides in excess of 100 miles from the children, shall control:
(1) IT IS ORDERED AND DECREED that LLOYD RUSSELL GOGGANS shall pay
all of the travel expenses, charges, escort fees, and air fares incurred for the
children for transportation from the residence of LEE ANN GOGGANS to the
residence of LLOYD RUSSELL GOGGANS and from the residence of LLOYD
RUSSELL GOGGANS to the residence of LEE ANN GOGGANS EXCEPT for
two (2) times a year, those times to be spring break and Christmas unless otherwise
agreed to in advance by the parties in writing, at which times IT IS ORDERED that
LLOYD RUSSELL GOGGANS shall pay all of the travel expenses, charges,
escort fees, and air fares incurred for the children for transportation from the
residence of LEE ANN GOGGANS to the residence of LLOYD RUSSELL
GOGGANS and LEE ANN GOGGANS shall pay all of the travel expenses,
charges, escort fees, and air fares incurred for the children for transportation from
the residence of LLOYD RUSSELL GOGGANS to the residence of LEE ANN
GOGGANS twice a year as previously stated.
Final Decree of Divorce (GOGGANS) - Page 12
B-18-O5; 8:29AM;IN7ER-7EL
;7045223672 # 16/ 32
(2) If LLOYD RUSSELL GOGGANS desires to take possession of the children at an
airport near his residence, LLOYD RUSSELL GOGGANS shall state in an notice
letter to LEE ANN GOGGANS the following facts:
(a) The airport where LEE ANN GOGGANS is to surrender the children;
(b) The date and time of the flight on which the children are schedule to leave;
(c) The airline and flight number of the airplane on which the children are
scheduled to leave;
(d) The airport where the children will return to LEE ANN GOGGANS at the end
of the period of possession;
(e) The date and time of the flight on which the children are scheduled to return to
that airport; and
(f) The airline and flight number of the airplane on which the children are
scheduled to return to LEE ANN GOGGANS at the end of the period of
possession.
(3) Flight Arrangements. LLOYD RUSSELL GOGGANS shall make airline
reservations for the children only on major commercial passenger airlines. Further,
LLOYD RUSSELL GOGGANS shall make airline reservations for the children on
flights that depart from a commercial airport near the residence of LEE ANN
GOGGANS that offers regularly scheduled passenger flights to various cities
throughout the United States on major commercial passenger airlines.
LEE ANN GOGGANS shall deliver the children to the airport from which the
children are scheduled to leave at the beginning of each period of possession at
least one hour before the scheduled departure time and shall surrender the children
to a flight attendant who is employed by the airline and who will be flying on the
same flight on which the children are scheduled.
LEE ANN GOGGANS shall take possession of the children at the end of LLOYD
RUSSELL GOGGANS's period of possession at the airport where the children are
scheduled to return and at the specific airport gate where the passengers from the
children's scheduled flight disembark.
LEE ANN GOGGANS shall be responsible for all costs associated with the
delivery of the children to and from the airport near her residence.
Final Decree of Divorce (GOGGANS) - Page 13
B-18-05; 8:29AM.INTER-7EL
;7045223672 0 17/ 32
LLOYD RUSSELL GOGGANS shall take possession of the children at the
beginning of each period of possession at the airport where the children are
scheduled to arrive and at the specific airport gate whether the passengers from the
children's scheduled flight disembark.
LLOYD RUSSELL GOGGANS, at the end of each period of possession, shall
deliver the children to the airport where the children are scheduled to depart at least
one hour before the scheduled departure time and surrender the children to a flight
attendant who is employed by the airline and who will be flying on the same flight
on which the children are scheduled to return.
LLOYD RUSSELL GOGGANS shall be responsible for all costs associated with
the delivery of the children to and from the airport near his residence.
(4) Missed Flight. Any conservator who has possession of the children at the time
shall notify the other conservator immediately if the children are not placed on a
scheduled flight at the beginning or end of a period of possession. If the children
should miss a scheduled flight, the conservator having possession of the children
when the flight is missed shall schedule another non-equipment change flight for
the children as soon as is possible after the originally scheduled flight and give the
other conservator notice of the date and time of that flight.
(5) Miscellaneous Expenses. The expenses of a conservator incurred in traveling to
and from an airport, as well as related parking and baggage handling expenses, are
the sole responsibility of the conservator delivering or receiving the child at the
airport.
(6) Reimbursement of Expenses. IT IS ORDERED that LLOYD RUSSELL
GOGGANS shall purchase airline tickets as described hereinabove and send a copy
of the receipt, along with the return tickets to LEE ANN GOGGANS. IT IS
ORDERED that within 10 days of her receipt of the same, LEE ANN GOGGANS
shall reimburse LLOYD RUSSELL GOGGANS for one-half the cost of such
tickets on two (2) occasions per year, those occasions being spring break and
Christmas unless otherwise agreed to in advance by the parties in writing.
Miscellaneous
The parties have agreed and IT IS ORDERED that the two children shall travel together
until the younger child reaches the age of 13.
This concludes the Standard Possession Order.
Final Decree of Divorce (GOGGANS) - Page 14
8-18-05; 8:29AM;INTER-TEL
Child Suimort
;7045223672 4 18/ 32
IT IS ORDERED that LLOYD RUSSELL GOGGANS is obligated to pay and shall pay to
LEE ANN GOGGANS child support of $382.50 per month, with the first payment being due and
payable on March 1, 2001 and a like periodic payment of $382.50 being due and payable on the 1"
day of each and every calendar month thereafter until the first month following the date of the
earliest occurrence of one of the events specified below:
1. any child reaches the age of eighteen years, provided that, if the child is fully enrolled in
an accredited secondary school in a program leading toward a high school diploma, the
periodic child-support payments shall continue to be due and paid until the end of the
month in which the child graduates;
2. any child marries;
3. any child dies;
4. any child's disabilities are otherwise removed for general purposes; or
5. further order modifying this child support.
Thereafter, LLOYD RUSSELL GOGGANS is ORDERED to pay to LEE ANN
GOGGANS child support of $297.50 per month, due and payable on the I st day of the first month
immediately following the date of the earliest occurrence of one of the events specified in items I
through 4 above and a like sum of $297.50 due and payable on the 1st day of each month
thereafter until the next occurrence of one of the events specified above t which time the child
support obligation shall cease.
Withholding from Earnings
IT IS ORDERED that any employer of LLOYD RUSSELL GOGGANS may be ordered to
withhold from earnings for child support from the disposable earnings of LLOYD RUSSELL
GOGGANS for the support of the children.
Withholding as Credit against Support Obligation
IT IS FURTHER ORDERED that all amounts withheld from the disposable earnings of
LLOYD RUSSELL GOGGANS by the employer and paid in accordance with the order to that
employer shall constitute a credit against the child-support obligation. Payment of the full amount
of child support ordered paid by this decree through the means of withholding from earnings shall
discharge the child-support obligation. If the amount withheld from earnings and credited against
the child-support obligation is less than 100 percent of the amount ordered to be paid by this
Final Deane of Divorce (GOGGANS) - Page 15
8-18-05; 8:29AM;INTER-TEL ;7045223672 # 19/ 32
decree, the balance due remains an obligation of LLOYD RUSSELL GOGGANS, and it is hereby
ORDERED that LLOYD RUSSELL GOGGANS pay the balance due directly to the registry of the
court specified below.
Payment To Local Registry
IT IS ORDERED that all payments shall be made through Denton County District Clerk's
Office, Child Support Division, 1450 E. McKinney, Denton, Texas 76201 and then remitted by
that agency to LEE ANN GOGGANS for the support of the children. IT IS FURTHER
ORDERED that LLOYD RUSSELL GOGGANS shall pay, when due, all fees charged by that
agency except envelope fees which shall be the responsibility of LEE ANN GOGGANS.
Change of Employment
IT IS FURTHER ORDERED that LLOYD RUSSELL GOGGANS shall notify this Court
and LEE ANN GOGGANS by U.S. certified mail, return receipt requested, of any change of
address and of any termination of employment. This notice shall be given no later than seven days
after the change of address or the termination of employment. This notice or a subsequent notice
shall also provide the current address of LLOYD RUSSELL GOGGANS and the name and
address of his current employer, whenever that information becomes available.
Clerk's Duties
IT IS ORDERED that, on the request of a prosecuting attorney, the attorney general, LEE
ANN GOGGANS, or LLOYD RUSSELL GOGGANS, the clerk of this Court shall cause a
certified copy of the "Employer's Order to Withhold from Earnings for Child Support" to be
delivered to any employer. IT IS FURTHER ORDERED that the clerk of this Court shall attach a
copy of subchapter C of chapter 158 of the Texas Family Code for the information of any
employer.
Health Care
IT IS ORDERED that health insurance shall be provided for the children as follows:
I.LLOYD RUSSELL GOGGANS' Responsibility- It is the intent and purpose of this
decree that LLOYD RUSSELL GOGGANS shall, at all times, provide medical support for the
children. IT IS THEREFORE ORDERED that, as additional child support, LLOYD RUSSELL
GOGGANS shall provide medical support for the parties' children, for as long as child support is
payable under the terms of this decree, as set out herein.
2, Definitions- "Health insurance" means insurance coverage that provides basic
health-care services, including usual physician services, office visits, hospitalization, and
laboratory, X-ray, and emergency services and may be provided in the form of an indemnity
Final Decree of Divorce (GOGGANS) - Page 16
8-16-05; 8129AM;INTER-TEL :7045223672 # 20/ 32
insurance contract or plan, a preferred provider organization or plan, a health maintenance
organization, or any combination thereof.
"Through employment" means through the party's employment or membership in a union,
trade association, or other organization.
3. Insurance through LLOYD RUSSELL GOGGANS' Employment, Union, Trade
Association, or Other Organization- The Court finds that the children are currently enrolled as a
beneficiary of a health insurance plan provided through LLOYD RUSSELL GOGGANS'
employment or membership in a union, trade association, or other organization. IT IS ORDERED
that LLOYD RUSSELL GOGGANS shall, at his sole cost and expense, keep and maintain at all
times in full force and effect the health insurance coverage that insures the parties' children
through LLOYD RUSSELL GOGGANS' employer, union, trade association, or other
organization for as long as it is offered by his employer, union, trade association , or other
organization. If his employer, union, trade association, or other organization subsequently
changes health insurance benefits or carriers, LLOYD RUSSELL GOGGANS is ORDERED to
obtain and maintain coverage for the benefit of the children on successor company or through such
health insurance plan as is available through other employment, union, trade association, or other
organization or other insurance provider.
4. Conversion of Policy- IT IS ORDERED that if the party through whose employment, or
membership in a union, trade association, or other organization health insurance has been provided
for the children is leaving that employment, union, trade association, or other organization or for
any other reason health insurance will not be available for the children through the employment or
membership in a union, trade association, or other organization of either party, the parry leaving
employment or losing coverage shall, within ten days of termination of his or her employment or
coverage, convert the policy to individual coverage for the child in an equal to or exceeding the
coverage at the time his or her employment or coverage is terminated. Further, if that health
insurance was available through LEE ANN GOGGANS' employment or membership in a union,
trade association, or other organization, LLOYD RUSSELL GOGGANS shall reimburse LEE
ANN GOGGANS for the cost of the converted policy as follows: LLOYD RUSSELL GOGGANS
is ORDERED to pay to LEE ANN GOGGANS at her last known address the cost of insuring the
children under the converted policy, on the first day of each month after LLOYD RUSSELL
GOGGANS receives written notice of the premium from LEE ANN GOGGANS for payment.
Accompanying the first such written notification and any subsequent notifications informing of a
change in the premium amount, LEE ANN GOGGANS is ORDERED to provide LLOYD
RUSSELL GOGGANS with documentation from the carrier of the cost to LEE ANN GOGGANS
of providing coverage for the children.
5. If Policy Not Convertible- If the health insurance policy covering the children is not
convertible and if no health insurance is available for the child through the employment or
membership in a union, trade association, or other organization of either party, IT IS ORDERED
that LLOYD RUSSELL GOGGANS shall purchase and maintain, at his sole cost and expense,
Final Decree of Divorce (GOGGANS) - Page 17
E-16-05; 8:29AM;)N7ER-7EL ;7045223672 4 211 32
health insurance coverage for the children equal to or exceeding the coverage at the time his or
her employment or coverage is terminated. LLOYD RUSSELL GOGGANS is ORDERED to
provide verification of the purchase of the insurance to LEE ANN GOGGANS at LEE ANN
GOGGANS' last known address, including the insurance certificate number and the plan summary
no later than 10 days following the issuance of the policy.
6. Claim Forms- Except as provided in paragraph 8 below, the party who is not carrying
the health insurance policy covering the children is ORDERED to submit to the party carrying the
policy, within ten days of receiving them, any and all forms, receipts, bills, and statements
reflecting the health-care expenses the party not carrying the policy incurs on behalf of the
children.
The parry who is carrying the health insurance policy covering the children is ORDERED
to submit all forms required by the insurance company for payment or reimbursement of
health-care expenses incurred by either party on behalf of the children to the insurance carrier
within ten days of that party's receiving any form, receipt, bill, or statement reflecting the
expenses.
7. Constructive Trust for Payments Received- IT IS ORDERED that any insurance
payments received by the party carrying the health insurance policy covering the children from the
health insurance carrier as reimbursement for health-care expenses incurred by or on behalf of the
children shall belong to the parry who incurred and paid those expenses. IT IS FURTHER
ORDERED that the party carrying the policy is designated a constructive trustee to receive any
insurance checks or payments for health-care expenses incurred and paid by the other party, and
the parry carrying the policy shall endorse and forward the checks or payments, along with any
explanation of benefits received, to the other party within three days of receiving them.
8. Filing by Party Not Carrying Insurance- In accordance with article 3.51-13 of the
Texas Insurance Code, IT IS ORDERED that the party who is not carrying the health insurance
policy covering the children may, at that party's option, file directly with the insurance carrier
with whom coverage is provided for the benefit of the children any claims for health-care
expenses, including, but not limited to, medical, hospitalization, and dental costs.
9. Secondary Coverage- IT IS ORDERED that nothing in this decree shall prevent either
party from providing secondary health insurance coverage for the children at that party's sole cost
and expense. IT IS FURTHER ORDERED that if a party provides secondary health insurance
coverage for the children, both parties shall cooperate fully with regard to the handling and filing
of claims with the insurance carrier providing the coverage in order to maximize the benefits
available to the children and to ensure that the party who pays for health-care expenses for the
children is reimbursed for the payment from both carriers to the fullest extent possible.
10. Compliance with Insurance Company Requirements- Each party ORDERED to
conform to all requirements imposed by the terms and conditions of the policy of health insurance
Final Decree of Divorce (GOGGANS) - Page 18
8-18-05; B:29AM;IN7EP-TEL ;7045223672 # 22/ 32
covering the children in order to assure maximum reimbursement or direct payment by the
insurance company of the incurred health-care expense, including but not limited to requirements
for advance notice to carrier, second opinions, and the like. Each parry is ORDERED to attempt
to use "preferred providers," or services within the health maintenance organization, if applicable;
however, this provision shall not apply if emergency care is required. Disallowance of the bill by
a health insurer shall not excuse the obligation of either party to make payment; however, if a bill
is disallowed or the benefit reduced due to the failure of a party to follow procedures or
requirements of the carrier, that parry shall be wholly responsible for the increased portion of that
bill.
If health insurance coverage for the children is provided through a health maintenance
organization (HMO) or preferred provider organization (PPO), the parties are ORDERED to use
health-care providers who are employed by the HMO or approved by the PPO whenever feasible.
If healthcare expenses are incurred by using that HMO or PPO plan, LEE ANN GOGGANS is
ORDERED to pay 50 percent and LLOYD RUSSELL GOGGANS is ORDERED to pay 50
percent of all reasonable and necessary health-care expenses not paid by insurance and incurred by
or on behalf of the parties' children, including, without limitation, any co-payments for office
visits or prescription drugs, the yearly deductible, if any, and medical, surgical, prescription drug,
mental health-care services, dental, eye care, ophthalmological., and orthodontic charges, for as
long as child support is payable under the terms of this decree. If a party incurs health-care
expenses for a child by using the services of a health-care providers not employed by HMO or
approved by the PPO, except in an emergency, without the written agreement of the other party,
the party incurring the services is ORDERED to pay 75 percent and the other party is ORDERED
to pay 25 percent of all reasonable and necessary health-care expenses not paid by insurance and
incurred by or on behalf of the parties' child, as set out above.
If a party incurs health-care expenses for a child by using the services of health-care
providers not employed by the HMO or approved by the PPO in an emergency or with the written
agreement of the other party, the party incurring the services is ORDERED to pay 50 percent and
the other party is ORDERED to pay 50 percent of all reasonable and necessary health-care
expenses not paid by insurance and incurred by or on behalf of the parties' child, as set out above.
If the children are enrolled in a health-care plan that is not an HMO or PPO, LEE ANN
GOGGANS is ORDERED to pay 50 percent and LLOYD RUSSELL GOGGANS is ORDERED
to pay 50 percent of all reasonable and necessary health-care expenses not paid by insurance and
incurred by or on behalf of the parties' children, including, without limitation, the yearly
deductible, if any and medical, surgical, prescription drug, mental health-care services, dental, eye
care, ophthalmological, and orthodontic charges, for as long as child support is payable under the
terms of this decree.
11. Payment of Uninsured Expenses- IT IS ORDERED that the party who pays for a
health-care expense on behalf of the children shall submit to the other party, within ten days of
receiving them, all forms, receipts, bills, and explanations of benefits paid reflecting the uninsured
Final Decree of Divorce (GOGGANS) - Page 19
8-18-05: 8:20AMVINTER-TEL :7045223672 # 23/ 32
portion of the health-care expenses the paying party incurs on behalf of the children. IT IS
FURTHER ORDERED that, within 10 days after the nonpaying party receives the explanation of
benefits stating benefits paid, that party shall pay his or her share of the uninsured portion of the
health-care expenses either by paying the health-care provider directly or by reimbursing the
paying party for any advance payment exceeding the paying party's share of the expenses.
12. Exclusions- The provisions above concerning uninsured expenses shall not be
interpreted to include expenses for travel to and from the health-care provider or nonprescription
medication.
13. Reasonableness of Charges- IT IS ORDERED that reasonableness of the charges for
health-care expenses shall be presumed on presentation of the bill to a party and that disallowance
of the bill by a health insurer 'shall not excuse that parry's obligation to make payment or
reimbursement as otherwise provided herein.
14. Information Required- IT IS ORDERED that a parry providing health insurance shall
furnish to the other party the following information no later than the thirtieth day after the date the
notice of the rendition of this decree is received:
(a) the Social Security number of the party providing insurance;
(b) the name and address of the employer of the party providing insurance;
(c) whether the employer is self-insured or has health insurance available;
(d) proof that health insurance has been provided for the children; and
(e) the name of the health insurance carrier, the number of the policy, a copy of the policy
and schedule of benefits, a health insurance membership card, claim forms, and any other
information necessary to submit a claim or, if the employer is self-insured, a copy of the
schedule of benefits, a membership card, claim forms, and any other information necessary
to submit a claim.
IT IS FURTHER ORDERED that any party carrying health insurance on the children shall
furnish to the other party a copy of any renewals or changes to the policy no later than the fifteenth
day after the renewal or change is received.
IT IS FURTHER ORDERED that a party providing health insurance shall provide to the
other party any additional information regarding health insurance coverage that becomes available
to the party providing insurance. IT IS FURTHER ORDERED that the information shall be
provided no later than the fifteenth day after the date the information is received.
Final Decree of Divorce (GGGGANS) - Page 20
8-18-05; 8.29AM;INTER-TEL ;7045223672 # 24/ 32
15. Order to Employer Entered- On this date an "Employer's Order to Withhold from
Earnings of Child Support" was entered by the Court.
16. Termination or Lapse of Insurance- If the health insurance coverage for the
children lapses or terminates, the party who is providing the insurance is ORDERED to notify the
other party no later than the fifteenth day after the date of termination or lapse. If additional health
insurance is available or becomes available to LLOYD RUSSELL GOGGANS for the children,
LLOYD RUSSELL GOGGANS must notify LEE ANN GOGGANS no later than the fifteenth day
after the date the insurance becomes available. LLOYD RUSSELL GOGGANS must enroll the
children in a health insurance plan at the next available enrollment period.
17. Place of Transmittal- IT IS ORDERED that all bills, invoices, statements, claims,
explanations of benefits, insurance policies, medical insurance identification cards, other
documents, and written notices, as well as payments, required to be transmitted by one party to the
other under the health-care coverage and health insurance provisions of this decree shall be
transmitted by the sending party to the residence of the receiving party.
18. Warning- A parent ordered to provide health insurance who fails to do so is liable
for necessary medical expenses of the child, without regard to whether the expenses would have
been paid if health insurance had been provided.
No Credit for Informal Payments
IT IS ORDERED that the child support as prescribed in this decree shall be exclusively
discharged in the manner ordered and that any direct payments made by LLOYD RUSSELL
GOGGANS to LEE ANN GOGGANS or any expenditures incurred by LLOYD RUSSELL
GOGGANS during his periods of possession of or access to the children, as prescribed in this
decree, for food, clothing, gifts, travel, shelter, or entertainment are deemed in addition to and not
in lieu of the support ordered in this decree.
Support as Obligation of Estate
IT IS ORDERED that the provisions for child support in this decree shall be an obligation
of the estate of LLOYD RUSSELL GOGGANS and shall not terminate on the death of LLOYD
RUSSELL GOGGANS. Payments received for the benefit of the children from the Social Security
Administration, Department of Veterans Affairs, other government agency, or life insurance shall
be a credit against this obligation.
Information Re ag_rding Parties and Children
The information required for each party by section 105.006(a) of the Texas Family Code is
as follows:
Final Decree of Divorce (GOGGANS) - Page 21
8-18-05; 8:29AM;INTER-7EL
Parents
17045223672 # 25/ 32
Name: LLOYD RUSSELL GOGGANS
Social Security number: 461-39-3357
Driver's license number and issuing state: 00393781 TX
Current residence address: #4 Indian Trail
Lake Dallas, Texas 75065
Mailing address: same
Home telephone number: (940) 321-5237
Name of employer: Jim Shirey
Address of employment: Denton, Texas
Work telephone number: (940) 320-1077
Name: LEE ANN GOGGANS
Social Security number: 342-58-7311
Driver's license number and issuing state: 02401238 TX
Current residence address: 10312 Friarsgate
Huntersville, North Carolina 28078
Mailing address:
Home telephone number:
Name of employer:
Address of employment:
Work telephone number:
same
(704) 987-8027
Children
Name: JENNIFER GOGGANS
Social Security number: 645-30-1486
Driver's license number and issuing state: N/A
Current Resident Address: 10312 Friarsgate
Huntersville, North Carolina 28078
Mailing address:
Home telephone number:
Name:
Social Security number:
Driver's license number and issuing state:
Current Resident Address:
Mailing address:
Home telephone number:
same
(704) 987-8027
BRANDON GOGGANS
N/A
10312 Friarsgate
Huntersville, North Carolina 28078
same
(704) 987-8027
Final Decree of Divorce (GOGGANS) - Page 22
8-t8-D5: B:29AM;INTER-TEL ;7045223672 # 26! 32
Required Notices
EACH PERSON WHO IS A PARTY TO THIS ORDER IS ORDERED TO NOTIFY EACH
OTHER PARTY, THE CLERK OF THIS COURT, AND THE STATE CASE REGISTRY OF ANY
CHANGE IN THE PARTY'S CURRENT RESIDENCE ADDRESS, MAILING ADDRESS, HOME
TELEPHONE NUMBER, NAME OF EMPLOYER, ADDRESS OF EMPLOYMENT, DRIVER'S
LICENSE NUMBER, AND WORK TELEPHONE NUMBER, THE PARTY IS ORDERED TO GIVE
NOTICE OF AN INTENDED CHANGE IN ANY OF THE REQUIRED INFORMATION TO EACH
OTHER PARTY, THE COURT, AND THE STATE CASE REGISTRY ON OR BEFORE THE 60TH
DAY BEFORE THE INTENDED CHANGE. IF THE PARTY DOES NOT KNOW OR COULD NOT
HAVE KNOWN OF THE CHANGE IN SUFFICIENT TIME TO PROVIDE 60-DAY NOTICE, THE
PARTY IS ORDERED TO GIVE NOTICE OF THE CHANGE ON OR BEFORE THE FIFTH DAY
AFTER THE DATE THAT THE PARTY KNOWS OF THE CHANGE.
THE DUTY TO FURNISH THIS INFORMATION TO EACH OTHER PARTY, THE COURT,
AND THE STATE CASE REGISTRY CONTINUES AS LONG AS ANY PERSON, BY VIRTUE OF
THIS ORDER, IS UNDER AN OBLIGATION TO PAY CHILD SUPPORT OR ENTITLED TO
POSSESSION OF OR ACCESS TO A CHILD.
FAILURE BY A PARTY TO OBEY THE ORDER OF THIS COURT TO PROVIDE EACH
OTHER PARTY, THE COURT, AND THE STATE CASE REGISTRY WITH THE CHANGE IN THE
REQUIRED INFORMATION MAY RESULT IN FURTHER LITIGATION TO ENFORCE THE
ORDER, INCLUDING CONTEMPT OF COURT. A FINDING OF CONTEMPT MAY BE PUNISHED
BY CONFINEMENT IN JAIL FOR UP TO SIX MONTHS. A FINE OF UP TO $500 FOR EACH
VIOLATION, AND A MONEY JUDGMENT FOR PAYMENT OF ATTORNEY'S FEES AND COURT
COSTS.
Notice shall be given to the other party by delivering a copy of the notice to the party by
registered or certified mail, return receipt requested. Notice shall be given to the Court by
delivering a copy of the notice either in person to the clerk of the Court or by registered or
certified mail addressed to the clerk. Notice to the State Case Registry shall be given by delivering
a copy of the notice either in person or by registered or certified mail to the Registry.
IT IS ORDERED that each parent shall have the duty to inform the other parent if the
parent resides with for at least thirty days, marries, or intends to marry a person who the parent
knows is registered as a sex offender under chapter 62 of the Code of Criminal Procedure (as
added by chapter 668, Acts of the 75" Legislature, Regular Session, 1997) or is currently charged
with an offense for which on conviction the person would be required to register under that
chapter. IT IS ORDERED that this information shall be tendered in the form of a notice made as
soon as practicable, but not later than the fortieth day after the date the parent begins to reside with
the person or on the tenth day after the date the marriage occurs, as appropriate. IT IS ORDERED
that the notice must include a description of the offense that is the basis of the person's
requirement to register as a sex offender or of the offense with which the person is charged.
WARNING: A PERSON COMMITS AN OFFENSE PUNISHABLE AS A CLASS C
MISDEMEANOR IF THE PERSON FAILS TO PROVIDE THIS NOTICE
Final Decree of Divorce (GOGGANS) - Page 23
8-18-05; 8:2GAM;iNTER-TEL
Warnings to Parties
;7045223572 # 27/ 32
WARNINGS TO PARTIES: FAILURE TO OBEY A COURT ORDER FOR CHILD
SUPPORT OR FOR POSSESSION OF OR ACCESS TO A CHILD MAY RESULT IN FURTHER
LITIGATION TO ENFORCE THE ORDER, INCLUDING CONTEMPT OF COURT. A FINDING
OF CONTEMPT MAY BE PUNISHED BY CONFINEMENT IN JAIL FOR UP TO SIX MONTHS,
A FINE OF UP TO $500 FOR EACH VIOLATION AND A MONEY JUDGMENT FOR PAYMENT
OF ATTORNEY'S FEES AND COURT COSTS.
FAILURE OF A PARTY TO MAKE A CHILD SUPPORT PAYMENT TO THE PLACE
AND IN THE MANNER REQUIRED BY A COURT ORDER MAY RESULT IN THE PARTY'S
NOT RECEIVING CREDIT FOR MAKING THE PAYMENT.
FAILURE OF A PARTY TO PAY CHILD SUPPORT DOES NOT JUSTIFY DENYING
THAT PARTY COURT-ORDERED POSSESSION OF OR ACCESS TO A CHILD. REFUSAL BY A
PARTY TO ALLOW POSSESSION OF OR ACCESS TO A CHILD DOES NOT JUSTIFY
FAILURE TO PAY COURT-ORDERED CHILD SUPPORT TO THAT PARTY.
Division of Marital Estate
The Court finds that the following is a just and right division of the parties' marital estate,
having due regard for the rights of each party and the children of the marriage.
Property to Husband
IT IS ORDERED AND DECREED that the husband, LLOYD RUSSELL GOGGANS, is
awarded the following as his sole and separate property, and the wife is divested of all right, title,
interest, and claim in and to that property:
H-1. All clothing, jewelry, and other personal effects in the possession of the husband
or subject to his sole control.
14-2. All sums of cash in the possession of the husband or subject to his sole control,
including funds on deposit, together with accrued but unpaid interest, in banks, savings
institutions, or other financial institutions, which accounts stand in the husband's sole name
or from which the husband has the sole right to withdraw funds or which are subject to the
husband's sole control.
H-3. All sums whether matured or unmatured, accrued or unaccrued, vested or
otherwise, together with all increases thereof, the proceeds therefrom, and any other rights
related to any profit-sharing plan, retirement plan, Keogh plan, pension plan, employee
stock option plan, 401(k) plan, employee savings plan, accrued unpaid bonuses, disability
plan, or other benefits existing by reason of the husband's past, present, or future
employment.
Final Decree of Divorce (GOOGANS) - Page 24
8:29AM;'NTER-TEL ;7045223672 4 23/ 32
H-4. All household furniture, furnishings, fixtures, goods, art objects, collectibles,
appliances, and equipment in the possession of the husband or subject to his control.
H-5. All policies of life insurance (including cash values) insuring the husband's life.
H-6. All brokerage accounts, stocks, bonds, mutual funds, and securities registered in
the husband's name, together with all dividends, splits, and other rights and privileges in
connection with them.
H-7. The 1997 Chevrolet Pickup motor vehicle, vehicle identification number
together with all prepaid insurance, keys, and title documents.
Property to Wife
IT IS ORDERED AND DECREED that the wife, LEE ANN GOGGANS, is awarded the
following as her sole and separate property, and the husband is divested of all right, title, interest,
and claim in and to that property:
W-1. All clothing, jewelry, and other personal effects in the possession of the wife or
subject to her sole control, save and except Petitioner, LLOYD RUSSELL GOGGANS'
personal clothing.
W-2. All sums of cash in the possession of the wife or subject to her sole control,
including funds on deposit, together with accrued but unpaid interest, in banks, savings
institutions, or other financial institutions, which accounts stand in the wife's sole name or
from which the wife has the sole right to withdraw funds or which are subject to the wife's
sole control.
W-3. All household furniture, furnishings, fixtures, goods, art objects, collectibles,
appliances, and equipment in the possession of the wife or subject to her control, save and
except the Armoir awarded to Petitioner, LLOYD RUSSELL GOGGANS.
W-4. All sums whether matured or unmatured, accrued or unaccrued, vested or
otherwise, together with all increases thereof, the proceeds therefrom, and any other rights
related to any profit-sharing plan, retirement plan, Keogh plan, pension plan, employee
stock option plan, 401(k) plan, employee savings plan, accrued unpaid bonuses, disability
plan, or other benefits existing by reason of the wife's past, present, or future employment.
W-5. All policies of life insurance (including cash values) insuring the wife's life.
W-6. All brokerage accounts, stocks, bonds, mutual funds, and securities registered in
the wife's name, together with all dividends, splits, and other rights and privileges in
connection with them.
Final Decree of Divorce (GOGGANS) - Page 25
B-18-05; 8.29AM:IN7ER-TEL
;7045223672 * 29; 32
W-7. The 1991 Maxima motor vehicle, vehicle identification number
, together with all prepaid insurance, keys, and title
documents.
Debts to Husband
IT IS ORDERED AND DECREED that the husband, LLOYD RUSSELL GOGGANS,
shall pay, as a part of the division of the estate of the parties, and shall indemnify and hold the
wife and her property harmless from any failure to so discharge, these items:
H-1. The balance due, including principal, interest, and all other charges, on the
promissory note payable to Ford Credit Union and given as part of the purchase price of
and secured by a lien on the 1997 Chevrolet Pickup motor vehicle awarded to the husband.
H-2. The balance due, including principal, interest, and all other charges, on the
promissory note payable to Conseco Finance and given as part of the purchase price of and
secured by a lien on the 1997 Chevrolet Pickup motor vehicle awarded to the husband.
H-3. Any and all debts, charges, liabilities, and other obligations incurred solely by the
husband from and after July 8, 1998 unless express provision is made in this decree
to the contrary.
Debts to Wife
IT IS ORDERED AND DECREED that the wife LEE ANN GOGGANS shall pay, as a
part of the division of the estate of the parties, and shall indemnify and hold the husband and his
property harmless from any failure to so discharge, these items:
W-1. Any and all debts, charges, liabilities, and other obligations incurred solely by the
wife from and after July 8, 1998 unless express provision is made in this decree to
the contrary,
Final Decree of Divorce (GOGGANS) - Page 26
6-IS-05: 8?28AM;INTEF-TEL
Armoire
;045223692 # ao/ 32
The parties have agreed and IT IS ORDERED that the Armoire shall be a gift from LEE
ANN GOGGANS and LLOYD RUSSELL GOGGANS to Jennifer Goggans.
Marital Residence
The parties have agreed and IT IS ORDERED that the parties shall remain tenants in
common and each shall own an undivided fifty percent (50%) interest in the 1987 Clayton
manufactured home located at 3900 Teasley Lane, Lot 200, Denton, Texas until the home is sold.
Until the property is sold, the parties have agreed and IT IS ORDERED that each party shall each
pay fifty percent (50%) of all costs associated with the property including mortgage, maintenance,
repairs, ad valorem taxes, property insurance, lot rent, and utilities.
The parties agree and IT IS ORDERED that upon the sale of the property, that the
proceeds realized from the sale shall be disbursed as follows:
a. The usual and customary closing costs, including but not limited to the costs of the
title insurance policy, survey, and real estate agent's commission;
b. All other debts associated with this home;
C. All remaining proceeds shall be paid to Mr. and Mrs. Edward Unitis for repayment
of monies lent to Petitioner and Respondent during the marriage.
Notice
IT IS ORDERED AND DECREED that each party shall send to the other party within
three days of its receipt a copy of any correspondence from a creditor or taxing authority
concerning any potential liability of the other party.
Attornev's Fees
To effect an equitable division of the estate of the parties and as a part of the division, and
for services rendered in connection with conservatorship and support of the children, each party
shall be responsible for his or her own attorney's fees incurred as a result of legal representation in
this case.
Division of Undisclosed Assets and Liabilities
IT IS ORDERED AND DECREED that any assets of the parties not awarded or divided by
this Final Decree of Divorce are subject to future division as provided in the Texas Family Code.
Final Decree of Diva= (GOGGANS) - Page 27
8-16-05; 8:29AW INTER-TEL ;7045223672 9 31/ 32
IT IS FURTHER ORDERED AND DECREED, as a part of the division of the estate of
the parties, that any community liability not expressly assumed by a party under this decree is to
be paid by the party incurring the liability, and the party incurring the liability shall indemnify and
hold the other parry and his or her property harmless from any failure to so discharge the liability.
No Alimony
IT IS ORDERED AND DECREED that no provision of this decree shall be construed as
alimony under the Internal Revenue Code, except as this decree expressly provides for payment of
maintenance or alimony under the Internal Revenue Code.
Court Costs
IT IS ORDERED AND DECREED that costs of court are to be borne by the party who
incurred them.
Resolution of Temporary Orders
IT IS ORDERED AND DECREED that Petitioner and Respondent are discharged from all
further liabilities and obligations imposed by the temporary order of this Court rendered on May
30, 2000.
Execution of Documents
IT IS ORDERED AND DECREED that each party will, within ten days of receiving
written notice from the other party, execute and deliver to the other party any deeds, bills of sale,
assignments, consents to change of beneficiaries of insurance policies, tax returns, stock powers
and other documents and will do or cause to be done any other reasonable and necessary acts and
things as may be necessary to effectuate the provisions and purposes of this decree. If either party
fails to comply with this provision, that party will pay to the other all attorney's fees, costs, and
other expenses reasonably and necessarily incurred as a result of that failure.
DischarLye from Discoverv Retention Requirement
IT IS ORDERED AND DECREED that the parties and their respective attorneys are
discharged from the requirement of keeping and storing the documents produced in this case in
accordance with rule 19l.4(d) of the Texas Rules of Civil Procedure.
Clarifying Orders
Without affecting the finality of this Final Decree of Divorce, this Court expressly
reserves the right to make orders necessary to clarify and enforce this decree.
Final Decree of Divome (GOGGANS) - Page 28
8-18-05; 8:29AM;1NTER-7EL ;7045223672
Relief Not Granted
IT IS ORDERED AND DECREED that all relief requested in this case and not expressly
granted is denied.
Date of Judgment
SIGNED on? L, 2001.
JUDGE PRESIDING
A EED AS TO FORM AND SUBSTANCE:
Llo Russe Go
L e Ann Goggans, Re ndent
APPROVED AS TO FORM ONLY:
Hardy Burk
Attorney for Petitioner
Jane hacker
Attorney for Respondent
,-mm'- 'oATRiIT,ANT)CnRRr
$ y CrcoPy
?fl$'+?ON .o7?rmE:::R)ADF,157T:??
# 32/ 32
Final Decree of Divorce (GOGGANS) - Page 29
h ^Git,
cn
c_,
JEFFREY S. UNITIS and,
KAREN UNITIS,
Plaintiffs
vs.
LEE ANN GOGGANS and
LLOYD RUSSELL GOGGANS,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2005 - 4378 CIVIL TERM
IN CUSTODY
STIPULATION OF THE PARTIES
????h lam/
This Stipulation is made this day of A6gust 2005, by and among the
parties in the captioned case, JEFFREY S. UNITIS and KAREN UNITIS, maternal
uncle and aunt and Plaintiffs above (hereinafter "Jeff and Karen"), LEE ANN
GOGGANS, mother and Defendant above (hereinafter "Lee Ann"), and LLOYD
RUSSELL GOGGANS, father and Defendant above (hereinafter "Rusty").
1. The Plaintiffs are the maternal uncle and aunt of BRANDON RUSSELL
GOGGANS, born July 27, 1993, and Lee Ann and Rusty are Brandon's parents.
2. Brandon has spent the summer of 2005 living with Jeff and Karen and
wishes to continue to reside with Jeff and Karen.
3. Lee Ann and Rusty believe it will be in Brandon's best interests for him to
SAIDIS
SHUR FLOWER
& LINDSAY
26 W. High Street
Carlisle, PA
continue to reside with Jeff and Karen, although it is their intention to maintain close
and loving contact with Brandon.
4. The parties will share legal custody of Brandon.
5. Jeff and Karen will have primary physical custody of Brandon, and Lee
Ann and Rusty shall have partial custody of Brandon at times the parties can agree.
The parties intend that the terms of this Stipulation be entered as a Court
SAIDIS
SHUFF, FLOWER
& LINDSAY
26 W. High Street
Carlisle, PA
Order. The parties understand that at any time they can seek modification of this
Order through the Court of Common Pleas of Cumberland County, Pennsylvania.
(:)? -- O Z- oS
Date
Date '-!
Date
Da
COMMONWEALTH OF PENNSYLVANIA
LOY9.0USSELL G
ss.:
COUNTY OF CUMBERLAND
On this A10F day of* 2005, before me, the undersigned officer,
personally appeared JEFFREY S. UNITIS and KAREN UNITIS, known to me (or
satisfactorily proven) to be the persons whose names are subscribed to the within
Stipulation and acknowledged that they executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
lu- r?
N Vary Pu c
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Sara 1. Ensinger, Notary Public
Camp Hill Boro, Cumberland County
My Commission Expires Oct. 17, 2005
UNITIS
KA N UNITIS
? "AAna-rc
ANN GOGGA S
Member, Pennsylvania A somolion of Notaries
STATE OF NORTH CAROLINA
ss.:
COUNTY OF
On this day of August, 2005, before me, the undersigned officer,
personally appeared LEE ANN GOGGANS, known to me (or satisfactorily proven) to
be the person whose name is subscribed to the within Stipulation and acknowledged
that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
SAIDIS
.HUFF, FLOWER
& LINDSAY
ATPORNEYS•AT•LAW
26 W. Nigh Street
Carlisle, PA
.`GtiA e.. ''• .
G
o Y•Y
QP ;' NOTAR' , O
PU841C i
w
My Comm. Explroai U
y •. MaY 24, 2010 j ?
Notary Public
STATE OF TEXAS
COUNTY OF 3>4u4r*--.
ss.:
On thisa54clay of August, 2005, before me, the undersigned officer,
personally appeared LLOYD RUSSELL GOGGANS, known to me (or satisfactorily
proven) to be the person whose name is subscribed to the within Stipulation and
acknowledged that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
.nR'pY°GW y
/ • 4s SHARON BIRD
! ,ifs Notary Public, State of Texas
*'lrEpf,T EiPrI Nly Comm. Expires 08119108 Notary Public
"'
?`` ` ' O
-n
C <?? .-?
cn
'w -;-. -n
pn
,-,i?'
;:7
i
N .' !,
Yv ) "??=.
??
Y '? .•
?
-
? .!
JEFFREY S. UNITIS AND KAREN UNITIS IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. 05-4378 CIVIL ACTION LAW
LEE ANN GOGGANS AND LLOYD
RUSSELL GOGGANS IN CUSTODY
DEFENDANT
ORDER OF COURT
AND NOW, Tuesday, August 30, 2005 upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator,
at 4th Floor, Cumberland County Courthouse, Carlisle on Thursday, September 29, 2005 at 9:30 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing; Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: !s/ jacr?ueBne M. Verney, Esg.
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilites 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.
YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY 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, Pennsylvania 17013
Telephone (717) 249-3166
0:Z I'd I C "),AV SNZ
r:d'd1 i l: U ',:1 -r! 30
JEFFREY S. UNITIS and
KAREN UNITIS,
Plaintiffs
vs.
LEE ANN GOGGANS and
LLOYD RUSSELL GOGGANS,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2005 -- 4378 CIVIL TERM
IN CUSTODY
STIPULATION OF THE (PARTIES
c??ion ko.?
This Stipulation is made this day of Bast 2005, by and among the
parties in the captioned case, JEFFREY S. UNITIS and KAREN UNITIS, maternal
uncle and aunt and Plaintiffs above (hereinafter "Jeff and Karen"), LEE ANN
GOGGANS, mother and Defendant above (hereinafter "Lee Ann"), and LLOYD
RUSSELL GOGGANS, father and Defendant above (hereinafter "Rusty").
1. The Plaintiffs are the maternal uncle and aunt of BRANDON RUSSELL
GOGGANS, born July 27, 1993, and Lee Ann and Rusty are Brandon's parents.
2. Brandon has spent the summer of 2005 living with Jeff and Karen and
wishes to continue to reside with Jeff and Karen.
3. Lee Ann and Rusty believe it will be in Brandon's best interests for him to
SAIDIS
SHOFF, FLOWER
& LINDSAY
26 W. High Street
Carlisle, PA
continue to reside with Jeff and Karen, although it is their intention to maintain close
and loving contact with Brandon.
4. The parties will share legal custody of Brandon.
5. Jeff and Karen will have primary physical custody of Brandon, and Lee
Ann and Rusty shall have partial custody of Brandon at times the parties can agree.
The parties intend that the terms of this Stipulation be entered as a Court
SAIDIS
3HUFF, FLOWER
& LINDSAY
ArMRNEYS•AT•LAW
26 W. High Street
Carlisle, PA
Order. The parties understand that at any time they can seek modification of this
Order through the Court of Common Pleas of Cumberland County, Pennsylvania.
?? -- o Z- oS
Date
1!J g-
Date '
Date
?
i -I I P IS
aD
?t ? Gl
UNITIS
KA N UNITIS
E ANN GOGGA S
LOY SS LE G
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS.:
On this day of*s 2005, before me, the undersigned officer,
personally appeared JEFFREY S. UNITIS and KAREN UNITIS, known to me (or
satisfactorily proven) to be the persons whose names are subscribed to the within
Stipulation and acknowledged that they executed the same for the purposes therein
contained.
IN WITNESS WHEREOF, I hereunto set my, hand and official seal.
_ A,
Nofary Pu c
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Sara J. Ensinger, Notary Public
Camp Hill Boro, Cumberland County
My Commission Expires Oct. 17, 2005
Member, Pennsylvania AssnnAlion of Notaries
STATE OF NORTH CAROLINA
ss.:
COUNTY OF Q-CbocnA5-
On this' day of August, 2005, before me, the undersigned officer,
personally appeared LEE ANN GOGGANS, known to me (or satisfactorily proven) to
be the person whose name is subscribed to the within Stipulation and acknowledged
that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
SAIDIS
SHUFF, FLOWER
& LINDSAY
26 W. High Street
Carlisle, PA
•`?P?C, N B. y.O`y''s
4r NOTARY
PUBLIC
% My Gom 4,201 ,,
'''o,99US OO
Notary Public
STATE OF TEXAS
COUNTY OF 3>0u4r+--
ss.:
On this5k54"cday of August, 2005, before me, the undersigned officer,
personally appeared LLOYD RUSSELL GOGGANS, known to me (or satisfactorily
proven) to be the person whose name is subscribed to the within Stipulation and
acknowledged that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
fQ:U!1.....,.
"y SHARON 61RD
/s Notary Public, State of Texas
MyCamm.Expins08119/08 Notary Public
i"' G' ?3
C <J+ ,-i
?
?
? .?
.
f V % (.?)
Y ?
(Cl
?'
?
?
r ?-G
.., ?i
RECE1`: E3 S_-P C 21 225
JEFFREY S. UNITIS and, IN THE COURT OF COMMON PLEAS OF
KAREN UNITIS, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiffs
vs. CIVIL ACTION -LAW
NO. 2005 - 4378 CIVIL TERM
LEE ANN GOGGANS and
LLOYD RUSSELL GOGGANS,
Defendants IN CUSTODY
ORDER OF COURT
AND NOW, to wit, this L ,;+ day of September, 2005, upon consideration of
the attached Custody Stipulation, it is hereby ORDERED and DECREED that same
is hereby made an Order of Court.
BY THE COURT:
J.
SAIDIS
SIIIIF$ FLOWER
& LINDSAY
ATTOR YS-AT•IAW
26 W. High Street
Carlisle, PA
s??y
O -,.? so t° 6
IU
SAIDIS
;HUFF, FLOWER
& LINDSAY
JEFFREY S. UNITIS and,
KAREN UNITIS,
Plaintiffs
vs.
LEE ANN GOGGANS and
LLOYD RUSSELL GOGGANS
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2005-4378 CIVIL TERM
IN CUSTODY
ACCEPTANCE OF SERVICE
I, LLOYD RUSSELL COGGANS, Defendant, accept service of the Complaint
in Custody in the above-captioned matter.
Date:
26 W. High Street
Carlisle, PA
?-o f L
i
c: 7
?n -c. -?,
r , <'_
;'.
T : ?? ?=?
;
;ri
,
,
-,
.. s3
,- ..?
"_ r„
JEFFREY S. UNITIS and,
KAREN UNITIS,
Plaintiffs
vs.
LEE ANN GOGGANS and
LLOYD RUSSELL GOGGANS,
Defendants
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 2005 - 4378 CIVIL TERM
IN CUSTODY
ACCEPTANCE OF SERVICE
I, LEE ANN COGGANS, Defendant, accept service of the Complaint in
SAIDIS
'HUFF, FLOWER
& LINDSAY
AWORMYPAPLAW
26 W. High Street
Carlisle, PA
Custody in the above-captioned matter.
Date: (13- 31-ns: - C?: ew
Lee Ann Goggans
N
?s
T_
MF?
tic)
r?
- '
rn
LOWER ALLEN TOWNSHIP
Plaintiff
V.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PA
MUNICIPAL LIEN
SHIRLEY S. BAKER NO. 2006-4378 MLD
Defendant
PRAECIPE TO SATISFY MUNICIPAL LIEN
TO THE PROTHONOTARY:
Kindly mark the above referenced Municipal Lien as satisfied, Principal,. Interest and
Costs having been paid in full.
Respectfully submitted,
DALEY ZUCKER MEILTON
MINER & GINGRICH, LLC
By: 42?? /L--
SteP. Miner, Esquire
Attorney I.D. No. 38901
1035 Mumma Road, Suite 101
Wormleysburg, PA 17043
(717) 724-9821
Attorneys for Plaintiff
Dater August 9, 2007
e7
c ? o
-„
? T?? ? T?T
-L
G? ? ? d ?'` .?- ? m
A- ? ? ? ? s
.
P
? ?
?.