HomeMy WebLinkAbout05-4613
{~Urcl OF {;;mfV101ll f2E//5, Cl/mI3EK/..J}tJb CdC/I../T"j, PA
,
7:./J R(2 TT-Ie /tj,qRR IA6-f'-
DDm"'.Jle C CooDHAre.r
PLAllvn FP
('liS E Nvmi3Gt?: ~
OS -4&'1.3 (!u.J(L ~
SUD{:rE. ,.
V
T.A rv/ff'Y 5 &-OOD /-Iftwr
bfFE/JDAllfr
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take action within
twenty (20) days after this complaint and notice are served, by entering
a written appearance personally or by an attorney and filing in writing
with the court your defenses or objections to the claims set forth
against you. You are warned that if you fail to do so the case may
proceed without you and a judgment may be entered against you by the
court withou further notice for any money claimed in the complaint or
for any other claim or relief requested ty the plaintiff. You may lose
money or pronerty or other ri~hts important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LA.NER AT ONCE.
HAVE A LAWYER OR CANNOT AFFORED ONE, GO TO OR TELEPHONE
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
IF YOU DO NOT
THE OFFICE SET
CUMBERLAND COUNTY BAR ASSOCIAAION
2 LIBERTY .'YENYE ..3~ SO. iJ€d-+~a.c.(:;-/"
CARLISLE PA 17013
(717) 249 3166 or 1 800 990 9108
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number: 1Jj'. 4(,.13 6~ 0-
Judge:
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle J. Goodhart (Age 8)
Jenna E. Goodhart (Age 5)
Complaint for Divorce
This suit is brought by Dominic C. Goodhart, the Plaintiff, Pro Se, Social Security #: 176-54-
9133, Drivers License/State ID #: 22-328-084, age 34 years old, who resides a 487 Highland
Court, Carlisle, PA 17013 with a phone number of: 717-385-8152.
Defendant is Tammy S. Goodhart, Pro Se, Social Security #: 210-60-9047, Drivers
License/State ID #: 22-132-529, age 35 years old, who resides at: 370 Grahams Woods Road,
Carlisle, PA, 17013 with a phone number of: 717-385-3115.
1. RESIDENCY:
The Plaintiff has been a resident of the State of Pennsylvania for the preceding 6 (six) months
and a resident of the county in which this Complaint for Divorce is filed for the preceding 10
(ten) days.
2. MILITARY STATUS:
The Plaintiff is NOT active in the United States Military.
The Defendant is NOT active in the United States Military.
3. SERVICE OF PROCESS
The Plaintiff will file the Return of Service from the Constable as soon as the Defendant has
been fonnally served.
4. JURISDICTION:
The Court has the required jurisdiction to hear this case. Neither party has ever been involved
in any other domestic relations proceedings involving the other party in this or any other
jurisdiction.
1
5. MARRIAGE:
The parties were married on January 6, 1990 in the city of Carlisle, in the State of
Pennsylvania, and separated on or about, September 15,2002, at which time they separated
and ceased to live together with the intent to terminate the marriage.
An official marriage license is attached to this Complaint for Divorce for reference.
6. GROUNDS:
Irretrievable breakdown of the marriage.
7. PREGNANCY:
The Defendant is not currently pregnant.
8. CHILDREN:
The Plaintiff and Defendant are the parents of the following children born, or legally adopted
of the marriage under the age of eighteen (18) who are not under the continuing jurisdiction
of any other court:
The information about the children is as follows:
Child #1
Full Name: Janelle J. Goodhart
Age: 8
Date of Birth: October 17, 1996
Sex: Female
SS#: 196-76-8234
Child #2
Full Name: Jenna E. Goodhart
Age: 5
Date of Birth: July 7, 2000
Sex: Female
SS#: 210-78-4309
9. CHILD CUSTODY AND VISITATION:
The child custody and visitation arrangements, and other related issues, will be settled by a
formal written Marital Settlement Agreement, which will be submitted to the Court.
10. CHILD SUPPORT:
The child support obligation, and other related issues, will be settled by a formal written
Marital Settlement Agreement, which will be submitted to the Court.
11. PROPERTY AND DEBT:
The property and debt, and other related issues, will be settled by a formal written Marital
Settlement Agreement, which will be submitted to the Court.
12. RETIREMENT ACCOUNTS:
The retirement accounts, and other related issues, will be settled by a formal written Marital
Settlement Agreement, which will be submitted to the Court.
2
13. SPOUSAL SUPPORT:
The spousal support, and other related issues, will be settled by a formal written Marital
Settlement Agreement, which will be submitted to the Court.
14. HEALTH INSURANCE:
The health insurance, and other related issues, will be settled by a formal written Marital
Settlement Agreement, which will be submitted to the Court.
15. TAX ISSUES:
The tax issues will be settled by a formal written Marital Settlement Agreement, which will
be submitted to the Court.
16. PROTECTIVE ORDERS:
There are no protective orders between the Plaintiff and Defendant.
17. PRAYER:
The Plaintiff respectfully requests this Honorable Court to grant this Divorce pursuant to
Section 3301 (c), or on the alternative, Section 3301 (d) of the Divorce Code.
18. REPRESENTATION
The Plaintiff has chosen to act as his own attorney in a Pro Se fashion, and understands that
he has the legal right to representation by an attorney. He fully understands his rights and
consider the terms of the attached Marital Settlement Agreement to be fair, reasonable and in
the best interest of the children.
19. VERIFICATION
I verify that the statements made in the Complaint for Divorce are true and correct. I
understand that false statements made herein are subject to penalties of 18 Pa. C.S.A. Section
4904, relating to unsworn falsification to authorities.
Date: "1 - 0) - 06
Dominic C. Goodhart
Print Name (Plaintiff, Pro Se)
Mailing Address: 487 Highland Court, Carlisle, P A 17013
Phone: 717-385-8152
3
(@riginal Qttrtificatt
I,
John h. lIe. Jr.
HEREBY CERTIFY THAT ON THE sixth DAY
OF January , ONE THOUSAND NINE HUNDRED NINETY
AT Nt. Zion United J.Jethodist Church, 589 Park Dr.. Carlisle, P1i 17013
Dominic Charles Goodhart AND Tammy Sue Sheller
merr fBU f8l{e
Bnitth 1In marriagt
IN ACCORDANCE WITH LICENSE ISSUED BY MARY C. LEWIS,
CLERK OF THE COURT OF COMMON PLEAS, ORPHANS' COURT
DIVISION OF CUMBERLAND COUNT~'lENNSYL~ANIA.
,/1 J ,-' ,/,
:/ " ./ /'
"
i!!i
~
'.
-~~
\
,
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number
Judge:
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle J. Goodhart (age 8)
Jenna E. Goodhart (age 5)
Marital Settlement Agreement
This agreement is made on this _ day of , 200_, between Dominic C.
Goodhart, the Plaintiff, with a social security number of 176-54-9133, who lives at 487
Highland Court, Carlisle, PA 17013 (phone: 717-385-8152) and the county of
Cumberland and Tammy S. Goodhart, the Defendant, with a social security number of
210-60-9047, who lives at 370 Grahams Woods Road, Carlisle, PA 17013 (phone: 717-
385-3115) and the county of Cumberland.
The Plaintiff and Defendant may from time to time throughout this agreement,
individually and collectively, be referred to as "Party" or "Parties" and "Parent" or
"Parents".
The Plaintiff is currently employed by ECI Construction, which is located at, 124
Church St, Dillsburg, P A 17019 (telephone number: 717-432-0864).
The Defendant is currently employed by the VFW Post 477, which is located at 959
Trindle Road, Carlisle, PA 17013 (telephone number: 717-258-4412) and the Clairmont
Nursing home, which is located at, 1000 Clairmont Road, Carlisle, P A 17013 (telephone
number: 717-243-1717).
1. Recitals:
The parties are making this agreement with reference to the following facts:
The parties were married on January 6, 1990 in the City of Carlisle,
Pennsylvania, and separated on or about, September 15, 2002.
As a result of serious disputes, conflict of personalities, and unique goals and
differences, the parties honestly believe that the marriage is irretrievably broken and that
1
there is no possible chance for reconciliation. For this reason each party desires to settle
fully and finally all aspects and rights, by this agreement, of the marital affairs including,
but not limited to; Property and Debt Distribution, RetirementIPensionIProfit
Sharing/401K Accounts, Spousal Maintenance, Child Custody, Visitation, Child
Support, Medical and Health Insurance, Secondary School Expenses, Child care, Tax
Exemptions, and Income Tax Returns.
The parties each hereby acknowledge that there are 2 children born, or legally
adopted of the marriage under the age of eighteen (18).
The information about each child is as follows:
Child # I
Full Name: Janelle J. Goodhart
Age: 8
Date of Birth: October 17, 1996
Sex: Female
SS#: 196-76-8234
Child #2
Full Name: Jenna E. Goodhart
Age: 5
Date of Birth: July 7, 2000
Sex: Female
SS#: 210-78-4309
The parties each now intend by this agreement to settle fully and finally all of
their respective rights and obligations arising out of or related to the marriage that
otherwise could be adjudicated in the above captioned case number.
There is no other pending action filed by either party regarding the dissolution of
the marriage.
The date of execution of this agreement is the day on which the agreement is
signed by both parties.
Any transfer of property, funds, debts and/or documents pursuant to the
agreement shall be made on the date of the execution of this agreement, if not already
done so, unless otherwise specified in this agreement.
The parties both agree to lead separate lives, and, except for the duties and
obligations imposed and assumed under this agreement, each shall be free from
interference and control of the other as fully as ifhe or she were single. The parties each
agree not to molest, interfere with, or harass the other.
2. Property and Debt Distribution:
As of the date of this agreement, the parties each do not possess all of his and her
marital and non-marital property or are either solely responsible for any of the debt that
will be described below.
2
The parties agree that the following marital property shall be the sole and
separate property of Dominic C. Goodhart, the Plaintiff, and Tammy S. Goodhart, the
Defendant transfers and quitclaims any interest that she may have in this marital
property to the Plaintiff: None.
The parties agree that the following marital property shall be the sole and
separate property of Tammy S. Goodhart, the Defendant, and Dominic C. Goodhart, the
Plaintiff transfers and quitclaims any interest that he may have in this marital property to
the Defendant: None.
The parties agree that Dominic C. Goodhart, the Plaintiff, shall pay and
indemnify and hold Tammy S. Goodhart, the Defendant, harmless from the following
marital debts: None.
The parties agree that Tammy S. Goodhart, the Defendant, shall pay and
indemnify and hold Dominic C. Goodhart, the Plaintiff, harmless from the following
marital debts: None.
The parties agree that the following non-marital (separate) property shall be the
sole and separate property of Dominic C. Goodhart, the Plaintiff, and Tammy S.
Goodhart, the Defendant transfers and quitclaims any interest that she may have in this
non-marital (separate) property to the Plaintiff: None.
The parties agree that the following non-marital (separate) property shall be the
sole and separate property of Tammy S. Goodhart, the Defendant, and Dominic C.
Goodhart, the Plaintiff transfers and quitclaims any interest that he may have in this non-
marital (separate) property to the Defendant: None.
The parties agree that Dominic C. Goodhart, the Plaintiff, shall pay and
indemnify and hold Tammy S. Goodhart, the Defendant, harmless from the following
non-marital (separate) debts: None.
The parties agree that Tammy S. Goodhart, the Defendant, shall pay and
indemnify and hold Dominic C. Goodhart, the Plaintiff, harmless from the following
non-marital (separate) debts: Sears Credit Card for $8,500.00. In addition, Tammy S.
Goodhart, will do whatever is necessary to remove Dominic C. Goodhart from her
charge account and establish and individual account and assume all liabilities for the
charges she has made on this account.
The parties both hereby represent and warrant that as of the date of this
agreement, they do not possess any property or interests in property other than the items
listed in this agreement; and that the items set forth and listed in the agreement constitute
full and complete disclosure.
In addition to the items listed in this agreement, if any undisclosed property or
interests in property is discovered subsequently, and a court of competent jurisdiction
determines it to be marital or community property of the parties, such discovery and
detennination shall not invalidate this agreement but, the property or the interest in it
shall at the election of the discovering party (i) be divided equally or equitably in kind or
(ii) be accounted for by the party in possession who may pay to the discovering party a
sum of money to offset an equal or equitable portion.
3
The parties both hereby represent and warrant that except for the debts and
obligations set forth and listed above, each has not incurred any other outstanding debt
or obligation on which the other may become liable, nor has either party incurred any
obligation that could henceforth be enforced against any asset held or received pursuant
to this agreement.
In the event that any outstanding debt or obligation of any kind has been incurred
by either party, other than those listed above (and is hereafter asserted against the other),
the party actually incurring the debt or obligation shall assume and be solely responsible
for paying it and shall hold the other party harmless from all claims with respect to the
debts, obligations, and expenses with respect to those debts.
In the event that the other party becomes a debtor in any bankruptcy or financial
reorganization proceeding of any kind while this agreement is in effect, that debtor party
waives any and all rights to any property held by the other party which is in fulfillment
of this agreement. The debtor party will also convey to the other party that the
bankruptcy or financial reorganization proceeding is going to take place.
The parties acknowledge and agree that the credit history established by them
during their marriage shall be deemed to have the credit history of both parties, not
withstanding ordinary practices of creditors and credit reporting agencies that may have
reported such credit history in the name of one party. Both parties agree to cooperate and
execute any documents as may be required to enable each other to provide to prospective
creditors the full credit history of the parties that was established during the marriage.
The parties each represent to the other that from the date of this agreement each
party shall not charge or incur or cause to be incurred any liability or obligations based
on the credit or name of the other. Each of the parties shall do whatever is necessary to
close immediately all joint accounts.
The parties each forever waive any right to inherit from the other and the right to
receive any property on the death of the other, except as a beneficiary of any life
insurance policy, by reason of a will, codicil, or republication of will by the other party
executed subsequent to the date of this agreement.
The parties each waives all right to act as administrator of the other party's estate
and all right to request or petition for the appointment of any person to serve as such
representative or to act as the executor of the other's will, unless expressly named in a
will, codicil, or republication of will by the other party executed subsequent to the date
of this agreement.
3. Marital Home:
There is no martial home.
4. Retirement AccountslPensions/401KsIProfit Sharine: Plans:
The parties each waive all claims, present and future to pension benefits,
retirement funds, 40Ik's, profit sharing plans and accounts of the like.
4
5. Spousal Maintenance:
After careful consideration of the circumstances and all the other tenns of this
agreement, the parties agree to waive any rights or claims that he or she may have now
or in the future to receive ant rehabilitative or permanent spousal maintenance from the
other party.
The parties both agree each will be responsible for his and her own health and
medical insurance coverage.
6. Child Custodv and Visitation:
The parties agree that it is in the best interest of the children that the Plaintiff and
Defendant have joint legal custody of the children, born, unborn or legally adopted of
this marriage. Both parties acknowledge that the actual primary physical residence of the
children may be changed at anytime through proper court procedure or as they mutually
agree.
The parties agree that the parent with who the children reside shall have control
over the minor day-to-day decisions affecting the children.
All decisions pertaining to the education, discipline, health, extracurricular and
summer activities, religious training, medical and dental care, and welfare of the children
will be decided by both parties after reasonable and adequate discussion.
The parties agree to share information about the children openly and free with
one another and agree not to hamper or interfere with the natural and continuing
relationship between the children and the other parent.
The parties agree that the children shonld have as much contact with each parent
and that the children may visit the other parent as often as may be agreed upon.
Although possession time may be scheduled more often, each parent will have the right
to be with the children at the following times:
A. Husband shall have the minor children every Thursday evening commencing at
5:00 p.m. until 9:00 p.m. The husband will pick the children up at the Wife's residence
and the Wife will pick the children up at 9:00 p.m. from the husband's residence.
B. Husband shall have the minor children ovemight every other weekend
commencing at 5:00 p.m. on Friday as presently in effect. During those weeks that
Husband has weekend visitation with the children, he shall pick the children up at Wife's
residence at 5:00 P.M. on Friday and return them home at 6:00 p.m. on Sunday. Except in
the event there is a holiday following the weekend in which the husband is conducting
visitation with the children then said visitation shall tenninate at 6:00 p.m. on Monday.
C. On Thanksgiving Day, 2005, Husband shall have the minor Child, thereafter the
Parties shall alternate spending Thanksgiving Day with the Children.
D. The Christmas Holiday shall be defined as commencing at 5:00 p.m. on December
24th and continuing until 12:00 P.M. December 25th. Commencing in 2006, Husband shall
have the minor Child with him from 5:00 p.m. on December 24th until 12:00 p.m. on
5
December 25th. Thereafter the Parties will alternate spending the Christmas Holiday with
the children.
E. The Christmas Holiday Vacation period shall be defined as commencing at 8:00
am. on December 26th and continuing until 6:00p.m. January 2nd of the following year.
Commencing in 2005, Wife shall have the children for the first Y, of the Christmas Holiday
Vacation and Husband shall have the minor children for the second Y, of the Christmas
Holiday Vacation commencing at 8:00 am. on December 30 until 6:00 p.m. on January 2nd
of the upcoming year. Thereafter the Parties shall alternate spending the Christmas Holiday
Vacation with the minor children.
F. The Spring Vacation Period however designated and established by the Children's
school system. Commencing at 8:00 am. on the first day of the vacation until 6:00 on the
last day of the vacation. Commencing in 2006, Husband shall have the minor children for
the fIrst Y, of the Spring Vacation period and Wife shall have the children for the second Y,
of the Spring Vacation Period. Thereafter the Parties shall alternate spending the Spring
Vacation Period with the minor children.
G. Easter Holiday shall be defined as commencing at 6:00 p.m. on the Saturday before
Easter until 6:00 p.m. on Easter Day. Commencing in 2006, the Husband shall have the
minor children for the Easter Holiday. Thereafter the Parties will alternate spending the
Easter Holiday with the minor children.
H. The minor Child shall spend Mother's Day with the Wife and Father's Day with the
Husband.
I. On Independence Day, 2006, Husband shall have the minor Child from 9:00 am.
until 9:00 p.m. Thereafter, the Parties shall alternate spending Independence Day with the
minor children.
J. In addition to the above Schedule, Husband shall be entitled to have the children for
two (2) weeks during the Children's swnmer vacation. The Husband will have the minor
children for (I) week uninterrupted vacation time during the month or July and again in the
month of August Husband will notify the Wife in writing at least (I) week prior to the
vacation periods.
If either Husband or Wife is unable to be with the Child during the
designated period, he or she shall make this known to the other, in writing at least
one (I) week in advance of the schedule visitation. If scheduled visitation does not
occur, then the Parties shall proceed to the next scheduled visit as stated in this
Agreement.
The parties additionally agree to use their very best efforts to insure that the
children receive the most care, love and affection possible.
The parties agree that it is in the best interest of the children that both parents
have joint/shared legal custody of the children.
All decisions pertaining to the education, discipline, health, extracurricular and
swnmer activities, religious training, medical and dental care, and welfare of the children
will be decided by both parties after reasonable and adequate discussion.
6
The parties agree to share information about the children openly and free with
one another and agree not to hwnper or interfere with the natural and continuing
relationship between the children and the other parent.
7. Parentinl!: PlanlA2reement:
The parties would like to make it known that there is not a parenting
agreement/plan in effect as of the date of this agreement.
8. Child SUDDort:
The parties agree that the Plaintiff will pay the Defendant, as child support, the
total wnount of $450.00 per month for the support of the children as well as the health
insurance premiums for both minor children. As ordered on 1/20/2004 Court of
Common Pleas of Cumberland County, Pennsylvania, Domestic Relations Section,
PACSES Case Number: 665106004, Docket No. 01094 S 2003. The payments are
presently in effect and will continued to be paid in accordance with the Order until the
children reach the age of eighteen (18), dies, becomes self-supporting, or married. The
parties also agree that the child support obligation is subject to modification by the court
at any time.
Since there is more than one child of this marriage, the child support obligation
should be adjusted appropriately as each child reaches the age of eighteen (18).
9. MedicallHealth Insurance:
The parties agree that for as long as the child support payments are being made,
the Plaintiff will carry and maintain health and hospitalization insurance for the
children's benefit. In addition the Defendant will pay the first $250.00 of the uninsured
medicals or expenses not covered by the health insurance for the children in accordance
with court order.
10. Secondarv School Exoenses:
The parties agree that neither parent will be responsible for any secondary
educational tuition and/or related expenses.
II. Child Care:
The parties agree that the Plaintiff will not be responsible for any child care and
related expenses above and beyond the standard monthly child support obligation.
12. Tax ExemDtions:
The parties agree they will each be entitled to claim one child as a dependant on
his and her federal, state, and local tax returns. Effective as of2006 the Plaintiff will
claim Janelle 1. Goodhart and every year thereafter. Effective 2006 the Defendant will
claim Jenna E. Goodhart and every year thereafter.
13. Income Tax Returns:
7
The parties agree that they will file separate federal and state tax returns for the
calendar year in which this agreement is made into effect.
The parties both agree that they will cooperate in the filing of any necessary tax
returns.
For each calendar year after the year this agreement is made into effect, each
party shall file separate federal, state and local income tax returns, in which each shall
include and report all of his or her separate income and shall pay all income taxes due.
The parties each agree to notify the other promptly in the event the IRS or any
state or local taxing authority provides notice of an audit, deficiency, refund, or the
adjustment regarding a tax return that was jointly filed or that should have been jointly
filed. The party receiving such notice from a taxing authority shall provide a copy of the
notice to the other party within 20 days of receiving it.
The parties further agree to cooperate fully with the other in any claims for
refunds or in defending against any deficiencies that may be determined with respect to
joint income tax returns filed (or to be filed). This includes, without limitation, the
making, executing, and filing of amended income tax returns; applications for refunds,
protests, and other instruments; and docwnents as may be required. The costs and
expenses for such will be divided equally between the parties.
14. Professional Fees and Costs:
The parties have not acquired any professional service fees which they desire to
be recognized, mentioned, or distributed by this agreement.
13. Advice of Counsel:
The parties each acknowledge that they have the legal right to representation by
separate attorneys. The parties each fully understand his and her rights and the contents
of this agreement.
The parties each consider the terms of this agreement to be fair and reasonable
and each party accepts sole responsibility for any decisions, and potential repercussions
of those decisions, which are presented as part of this agreement.
16. Mutual Releases:
Each party hereby releases the other from any claim against the other for any
reason occurring prior to this agreement, whether that claim is founded in contract, tort,
or any other basis.
17. Goveminl!: Law:
The parties agree that this docwnent is intended to be a full and an entire
settlement and agreement between them regarding the marital rights and obligations and
that this agreement, and all contents within, shall be interpreted and governed by the
laws of the State of Pennsylvania
8
18. Entire A2reement:
This agreement constitutes the entire and full agreement between the parties. If
any clause is held unenforceable or found to be in any way non-executable, or if a court
alters or holds unenforceable any clause in this agreement, this shall in no way affect or
alter the other clauses in the agreement, which shall remain in full force.
No amendment or modification to this agreement or any judgment, decree or
order based on it shall be valid unless signed and agreed to by both parties or ordered by
the court after a duly noticed hearing.
19. Further Assurances:
The parties shall execute and deliver promptly on request any additional papers,
documents, and other assurances reasonably necessary in connection with the
performance of the obligations set forth in this agreement. In the event that either party
fails or refuses to comply with the provisions of this agreement, the failing party shall
reimburse the other party for all loses and expenses including, but not limited to,
attorney's fees and all costs incurred as a result of such failure.
20. Caotions and Interoretations:
Paragraph captions have been used throughout this agreement for convenience
and reference only and are not intended to be used in the construction or interpretation
of this agreement or any of its provisions. No provision of this agreement is to be
interpreted for or against any party by virtue of the fact that the provision was drafted
by that party or that party's counsel.
21. Submission to Court:
This agreement has been drafted and executed with the intention that it be
submitted by either party to any court before which a Complaint for Divorce may be
pending or initially filed for approval by the court and for incorporation into a Decree of
Divorce.
21. Successions:
The parties each acknowledge that this agreement, and each provision of it, is expressly
made binding upon the heirs, assigns, executors, administrators, representatives and
successors in the interest of each party.
Signed and dated on this
day of
,200_.
Dominic C. Goodhart, Plaintiff
9
Tammy S. Goodhart, Defendant
State of Pennsylvania
County of Cumberland
SWORN TO AND SUBSCRIBED BEFORE ME by the said Dominic C. Goodhart, on
this _ day of , 200---, the undersigned, a Notary Public in and
for said State, personally appeared Dominic C. Goodhart, the Plaintiff, known to me (or
proved on the basis of satisfactory evidence) to be the person whose name is subscribed
to within the instrument and acknowledged that he executed the same.
Witness my hand and official seal.
Notary Public
My commission expires:
Notary Seal:
State of Pennsylvania
County of Cumberland
SWORN TO AND SUBSCRIBED BEFORE ME by the said Dominic C. Goodhart, on
this _ day of , 200---, the undersigned, a Notary Public in and
for said State, personally appeared Dominic C. Goodhart, the Plaintiff, known to me (or
proved on the basis of satisfactory evidence) to be the person whose name is subscribed
to within the instrument and acknowledged that he executed the same.
Witness my hand and official seal.
Notary Public
My commission expires:
Notary Seal:
10
7J (0 -Ii;.
#: ~ -- C) ...,
-a c.::;) (-~.
c.:,,:;', .J
';:_;"1 "
\) C'-:r
--
......... ~ &
f'- -,
~ () -~-,
W )., _h
~ r- -u f"
'.
\J F .-( (,)
€2 (...,)
'- ''7;1
~
AFFIDAVIT OF SERVICE
Commonwealth of Pennsylvania
County of Cumberland
Common Pleas Court
Case Number: 05-4613 CIVIL TERM
Plaintiff:
Dominic C. Goodhart
vs.
Defendant:
Tammy S. Goodhart
For:
Dominic C. Goodhart
Received by Pennsylvania Professional Process Svc. to be served on Tammy S. Goodhart, 370 Grahams Woods
Rd.. Csrlisle, PA 17013 PHONE NUMBER: 385-3115. 1,/.tIJIJi':!.... A. ;';je'K~ --::K' ,being duly sworn.
depose and say that on the J~""lday ~M'lt'<" ,2~at :Q!L.f!..m., executed service by delivering a
true copy of the Summons; Complaint for vorce; Copy of Original Certificate of Marriage; Marital Settlement
Agreement in accordance with state statutes in the manner marked below:
~DIVIDUAL SERVICE: Served the within-named person.
( ) SUBSTITUTE SERVICE: By serving as
( ) POSTED SERVICE: After attempting service on ---1_ at _ and on ---1_ at _ to a conspicuous
place on the property described herein.
( ) NON SERVICE: For the reason detailed in the Comments below.
Military Status: ( ) Yes or ~o If yes, what branch? ,
Marital Status: ~arried or ( )Single NameofSpouse1Y~;A.Jic_ C. f1x:vd.J..J,tJf')
COMMENTS:
I certify that I have no interest in the above action, am of legal age and have proper authority in the jurisdiction in
which this service was made.
Subscribed and Sworn to before me on the 12!:5:.. day
of S~I .~~bytheaffiantwhois
person lIy known to me.
NOrA=ICP.~
tdA' /'J4:{
PROCESS SERVER #
Appointed in accordance
with State Statutes
,....'.;,.w~...
UndaJ, Jw""", ''':(~'Y Plt*:
CarbIe Boro. C\JrrtJerl.. fl CouIlly
..., Camiaoion E"Iires My 23. 2l1)6
_.~A.-.OINo1arioo
Copyright C 1992-2005 Database Services, Inc. - Process Server's Toolbox V5.5i
Pennsylvania Professional ProC888 Svc.
48 W. High St.
P.O. Box 1148
Carlisle, PA 17013
(717) 960-9260
Our Job Serial Number: 2005000275
'.~\.
,~ ,
~: ,', .....
"-.1 .' ~ ~ ,~
;. .... ,\ ~.
.,,;
",,';'
'..) >;... ,~,,'.
'.'~'" t, . .,~,'f
~.'-
:-,,,,',,\,,-,,,,,,,,,,;:
0 .....,
= 0
C c"" "Tl
0""
~.~ </) ~""1"1
,,<
-0 lilp
N \1(11
~hC1
en 'F~; f~?
'V ~~fA
-~...
~) '-'
--I
,0:...., ...,..".
;=-~ 0 :'b
0'. -<
"
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number: 05-4613 Civil Term
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle J. Goodhart (age 9)
Jenna E. Goodhart (age 5)
Marital Settlement Agreement
This agreement is made on this.-.-L day of DeLe "'l oe('2005, between Dominic C.
Goodhart, the Plaintiff, with a social security number of 176-54-9133, who lives at 487
HigWand Court, Carlisle, PA 17013 (phone: 717-385-8152) and the county of
Cumberland and Tammy S. Goodhart, the Defendant, with a social security number of
210-60-9047, who lives at 370 Grahams Woods Road, Carlisle, PA 17013 (phone: 717-
385-3115) and the county of Cumberland.
The Plaintiff and Defendant may from time to time throughout this agreement,
individually and collectively, be referred to as "Party" or "Parties" and "Parent" or
"Parents" .
The Plaintiff is currently employed by ECI Construction, which is located at, 124
Church Street, Dillsburg, PA 17019 (telephone number: 717-432-0864).
The Defendant is currently employed by the VFW Post 477, which is located at 959
Trindle Road, Carlisle, P A 17013 (telephone number: 717-258-4412) and the Clairmont
Nursing home, which is located at, 1000 Clairmont Road, Carlisle, PA 17013 (telephone
number: 717-243-1717).
I. Recitals:
The parties are making this agreement with reference to the following facts:
The parties were married on January 6, 1990 in the City of Carlisle,
Pennsylvania, and separated on or about, September 15, 2002.
Plaintiff's Initial: ~
Defendant's Initials:-m-
Page 1 of 11
As a result of serious disputes, contlict of personalities, and unique goals and
differences, the parties honestly believe that the marriage is irretrievably broken and that
there is no possible chance for reconciliation. For this reason each party desires to settle
fully and finally all aspects and rights, by this agreement, of the marital affairs including,
but not limited to; Property and Debt Distribution, Retirement/PensionJProfit
Sharing/401K Accounts, Spousal Maintenance, Child Custody, Visitation, Child
Support, Medical and Health Insurance, Secondary School Expenses, Child care, Tax
Exemptions, and Income Tax Returns.
The parties each hereby acknowledge that there are 2 children born of the
marriage under the age of eighteen (18).
The information about each child is as follows:
Child # 1
Full Name: Janelle J. Goodhart
Age: 9
Date of Birth: October 17, 1996
Sex: Female
SS#: 196-76-8234
Cbild #2
Full Name: Jenna E. Goodhart
Age: 5
Date of Birth: July 7, 2000
Sex: Female
88#: 210-78-4309
The parties each now intend by this agreement to settle fully and finally all of
their respective rights and obligatious arising out of or related to the marriage that
otherwise could be adjudicated in the above captioned case number.
There is no other pending action filed by either party regarding the dissolution of
the marriage.
The date of execution of this agreement is the day on which the agreement is
signed by both parties.
Any transfer of property, funds, debts and/or documents pursuant to the
agreement shall be made on the date of the execution of this agreement, if not already
done so, unless otherwise specified in this agreement.
The parties both agree to lead separate lives, and, except for the duties and
obligations imposed and assumed under this agreement, each shall be free from
interference and control of the other as fully as if be or she were single. The parties each
agree not to molest, interfere with, or harass the other.
Plaintiff's Initial: '~
Defendant's Initials: ~
Page 2 of 11
2. Prooertv and Debt Distribution:
As of the date of this agreement, the parties each do not possess all of his and her
marital and non-marital property or are either solely responsible for any of the debt that
will be described below.
The parties agree that the following marital property shall be the sole and
separate property of Dominic C. Goodhart, the Plaintiff, and Tammy S. Goodhart, the
Defendant transfers and quitclaims any interest that she may have in this marital
property to the Plaintiff: None.
The parties agree that the following marital property shall be the sole and
separate property of Tammy S. Goodhart, the Defendant, and Dominic C. Goodhart, the
Plaintiff transfers and quitclaims any interest that he may have in this marital property to
the Defendant: None.
The parties agree that Dominic C. Goodhart, the Plaintiff, shall pay and
indemnify and hold Tammy S. Goodhart, the Defendant, harmless from the following
marital debts: None.
The parties agree that Tammy S. Goodhart, the Defendant, shall pay and
indemnify and hold Dominic C. Goodhart, the Plaintiff, harmless from the following
marital debts: None.
The parties agree that the following non-marital (separate) property shall be the
sole and separate property of Dominic C. Goodhart, the Plaintiff, and Tammy S.
Goodhart, the Defendant transfers and quitclaims any interest that she may have in this
non-marital (separate) property to the Plaintiff: None.
The parties agree that the following non-marital (separate) property shall be the
sole and separate property of Tammy S. Goodhart, the Defendant, and Dominic C.
Goodhart, the Plaintiff transfers and quitclaims any interest that he may have in this non-
marital (separate) property to the Defendant: None.
The parties agree that Dominic C. Goodhart, the Plaintiff, shall pay and
indemnify and hold Tammy S. Goodhart, the Defendant, harmless from the following
non-marital (separate) debts: None.
The parties agree that Tammy S. Goodhart, the Defendant, shall pay and
indemnify and hold Dominic C. Goodhart, the Plaintiff, harmless from the following
non-marital (separate) debts: Sears Credit Card for $8,500.00. In addition, Tammy S.
Goodhart, will do whatever is necessary to remove Dominic C. Goodhart from her
charge account and establish and individual account and assume all liabilities for the
charges she has made on this account.
The parties both hereby represent and warrant that as of the date of this
agreement, they do not possess any property or interests in property other than the items
Plaintiff's Initial: -9.k--
Defendant's Initials: ~
Page 3 of 11
listed in this agreement; and that the items set forth and listed in the agreement constitute
full and complete disclosure.
In addition to the items listed in this agreement, if any undisclosed property or
interests in property is discovered subsequently, and a court of competent jurisdiction
determines it to be marital or community property of the parties, such discovery and
determination shall not invalidate this agreement but, the property or the interest in it
shall at the election of the discovering party (i) be divided equally or equitably in kind or
(ii) be accounted for by the party in possession who may pay to the discovering party a
sum of money to offset an equal or equitable portion.
The parties both hereby represent and warrant that except for the debts and
obligations set forth and listed above, each has not incurred any other outstanding debt
or obligation on which the other may become liable, nor has either party incurred any
obligation that could henceforth be enforced against any asset held or received pursuant
to this agreement.
In the event that any outstanding debt or obligation of any kind has been incurred
by either party, other than those listed above (and is hereafter asserted against the other),
the party actually incurring the debt or obligation shall assume and be solely responsible
for paying it and shall hold the other party harmless from all claims with respect to the
debts, obligations, and expenses with respect to those debts.
In the event that the other party becomes a debtor in any bankruptcy or financial
reorganization proceeding of any kind while this agreement is in effect, that debtor party
waives any and all rights to any property held by the other party which is in fulfillment
of this agreement. The debtor party will also convey to the other party that the
bankruptcy or financial reorganization proceeding is going to take place.
The parties acknowledge and agree that the credit history established by them
during their marriage shall be deemed to have the credit history of both parties, not
withstanding ordinary practices of creditors and credit reporting agencies that may have
reported such credit history in the name of one party. Both parties agree to cooperate and
execute any documents as may be required to enable each other to provide to prospective
creditors the full credit history of the parties that was established during the marriage.
The parties each represent to the other that from the date of this agreement each
party shall not charge or incur or cause to be incurred any liability or obligations based
on the credit or name of the other. Each of the parties shall do whatever is necessary to
close immediately all joint accounts.
The parties each forever waive any right to inherit from the other and the right to
receive any property on the death of the other, except as a beneficiary of any life
insurance policy, by reason of a will, codicil, or republication of will by the other party
executed subsequent to the date of this agreement.
Plaintiffs Initi~l.: ~
Defendant's ImtJals: $-
Page 4 of 11
The parties each waives all right to act as administrator of the other party's estate
and all right to request or petition for the appointment of any person to serve as such
representative or to act as the executor of the other's will, unless expressly named in a
will, codicil, or republication of will by the other party executed subsequent to the date
of this agreement.
2. Marital Home:
There is no martial home.
3. Retirement AeeouDtslPeDsionS/401KsIProfit ShariD!!. Plans:
The parties each waive all claims, present and future to pension benefits,
retirement funds, 4OIk's, profit sharing plans and accounts of the like.
4. Snousal Maintenance:
After careful consideration of the circumstances and all the other terms of this
agreement, the parties agree to waive any rights or claims that he or she may have now
or in the future to receive ant rehabilitative or permanent spousal maintenance from the
other party. The parties both agree each will be responsible for his and her own health
and medical insurance coverage.
6. Child Custody and Visitation:
The parties agree that it is in the best interest of the children that the Plaintiff and
Defendant have joint legal custody of the children, born of this marriage. Both parties
acknowledge that the actual primary physical residence of the children may be changed
at anytime through proper court procedure or as they mutually agree.
The parties agree that the parent with who the children reside shall have control
over the minor day-to-day decisions affecting the children.
All decisions pertaining to the education, discipline, health, extracurricular and
summer activities, religious training, medical and dental care, and welfare of the children
will be decided by both parties after reasonable and adequate discussion.
The parties agree to share information about the children openly and free with
one another and agree not to hamper or interfere with the natural and continuing
relationship between the children and the other parent.
The parties agree that the children should have as much contact with each parent
and that the children may visit the other parent as often as may be agreed upon.
Although possession time may be scheduled more often, each parent will have the right
to be with the children at the following times:
Plaintiff's Initial: ~
Defendant's Initials: ~
Page 5 ofll
A. Husband shall have the minor children every Thursday evening commencing at
5:00 p.m. until 9:00 p.m. The husband will pick the children up at the Wife's residence
and the Wife will pick the children up at 9:00 p.m. from the husband's residence.
B. Husband shall have the minor children overnight every other weekend
commencing at 5:30 p.m. on Friday as presently in effect. During those weeks that
Husband has weekend visitation with the children, he shall pick the children up at Wife's
residence at 5:30 P.M. on Friday and return them home at 6:00 p.m. on Sunday. Except in
the event there is a holiday following the weekend in which the husband is conducting
visitation with the children then said visitation shall terminate at 6:00 p.m. on Monday.
C. On Thanksgiving Day, 2005, Husband shall have the minor Child, thereafter the
Parties shall altemate spending Thanksgiving Day with the Children.
D. The Christmas Holiday shall be defmed as commencing at 5:00 p.m. on December
24th and continuing until 12:00 P.M. December 25th. Commencing in 2006, Husband sball
have the minor Child with him from 5:00 p.m. on December 24m until 12:00 p.m. on
December 25th. Thereafter the Parties will alternate spending the Christmas Holiday with
the children.
E. The Christmas Holiday Vacation period shall be defined as commencing at 8:00
am. on December 26th and continuing until 6:00 p.m. January 2nd of the following year.
Commencing in 2005, Wife shall have the children for the first Yo of the Christmas Holiday
Vacation and Husband shall have the minor children for the second 'Iz of the Christmas
Holiday Vacation commencing at 8:00 a.m. on December 29 until 6:00 p.m. on January 2nd
of the upcoming year. Thereafter the Parties shall alternate spending the Christmas Holiday
Vacation with the minor children.
F. The Spring Vacation Period however designated and established by the Children's
school system. Commencing at 8:00 am. on the first day of the vacation until 6:00 on the
last day of the vacation. Commencing in 2006, Husband shall have the minor children for
the first Yo of the Spring Vacation period and Wife shall have the children for the second Y.
of the Spring Vacation Period. Thereafter the Parties shall altemate spending the Spring
Vacation Period with the minor children.
G. Easter Holiday shall be defined as commencing at 6:00 p.m. on the Saturday before
Easter until 6:00 p.m. on Easter Day. Commencing in 2006, the Husband shall have the
minor children for the Easter Holiday. Thereafter the Parties will alternate spending the
Easter Holiday with the minor children.
H. The minor Child shall spend Mother's Day weekend with the Wife and Father's Day
weekend with the Husband.
I. On Independence Day, 2006, Husband shall have the minor Child from 9:00 am.
until 9:00 p.m. Thereafter, the Parties shall alternate spending Independence Day with the
minor children.
Plaintiff's Initial:\) (,
Defendant's Initials: \Gi
Page 6 of 11
J. In addition to the above Schedule, Husband shall be entitled to have the children for
two (2) weeks during the Children's summer vacation. The Husband will have the minor
children for (I) week uninterrupted vacation time during the month or July and again in the
month of August. Husband will notifY the Wife in writing at least (I) week prior to the
vacation periods.
If either Husband or Wife is unable to be with the Children during the
designated period, he or she shall make this known to the other, in writing at least
one (I) week in advance of the schedule visitation. If scheduled visitation does not
occur, then the Parties shall proceed to the next scheduled visit as stated in this
Agreement.
The parties additionally agree to use their very best efforts to insure that the
children receive the most care, love and affection possible.
The parties agree that it is in the best interest of the children that both parents
have joint/shared legal custody of the children.
All decisions pertaining to the education, discipline, health, extracurricular and
summer activities, religious training, medical and dental care, and welfare of the children
will be decided by both parties after reasonable and adequate discussion.
The parties agree to share infonnation about the children openly and free with
one another and agree not to hamper or interfere with the natural and continuing
relationship between the children and the other parent.
7. Parentinll PlaDlAllI'eement:
The parties would like to make it known that there is not a parenting
agreement/plan in effect as of the date of this agreement.
8. Child SUPPort:
The parties agree that the Plaintiff will pay the Defendant, as child support, the
total amount of $450.00 per month for the support of the children as well as the health
insurance premiums for both minor children. As ordered on 1/20/2004 Court of
Common Pleas of Cumberland County, Pennsylvania, Domestic Relations Section,
P ACSES Case Number: 665106004, Docket No. 01094 S 2003. The payments are
presently in effect and will continued to be paid in accordance with the Order until the
children reach the age of eighteen (18), dies, becomes self-supporting, or married. The
parties also agree that the child support obligation is subject to modification by the court
at any time.
Since there is more than one child of this marriage, the child support obligation
should be adjusted appropriately as each child reaches the age of eighteen (18).
Plaintiff's Initial: ~
Defendant's Initials: ~
Page 7 of 11
9. M~icallHealthlDentallnsurance:
The parties agree that for as long as the child support payments are being made,
the Plaintiff will carry and maintain health and hospitalization insurance for the
children's benefit. In addition the Defendant will pay the first $250.00 of the uninsured
medicals or expenses not covered by the health insurance for the children in accordance
with court order. The Plaintiff and the Defendant will split the cost of the children's
dental bills equally.
10. Secundarv ~hool Exnenses:
The parties agree that neither parent will be responsible for any secondary
educational tuition and/or related expenses.
11. Child Care:
The parties agree that the Plaintiff will not be responsible for any child care and
related expenses above and beyond the standard monthly child support obligation.
12. Tax Exemptions:
The parties agree that the Defendant will be entitled to claim the children as
dependants on her federal, state, and local tax returns.
13. Income Tax Returns:
The parties agree that they will file separate federal and state tax returns for the
calendar year in which this agreement is made into effect.
The parties both agree that they will cooperate in the filing of any necessary tax
returns.
For each calendar year after the year this agreement is made into j~ffect, each
party shall file separate federal, state and local income tax returns, in which each shall
include and report all of his or her separate income and shall pay all income taxes due.
The parties each agree to notify the other promptly in the event the IRS or any
state or local taxing authority provides notice of an audit, deficiency, refund, or the
adjustment regarding a tax return that was jointly filed or that should have: been jointly
filed. The party receiving such notice from a taxing authority shall provide a copy of the
notice to the other party within 20 days of receiving it.
The parties further agree to cooperate fully with the other in any claims for
refunds or in defending against any deficiencies that may be determined with respect to
joint income tax returns filed (or to be filed). This includes, without limitation, the
Plaintiff's Initial: ~
Defendant's Initials: ~
Page 8 of 11
Court of Common Pleas, Cumberland County, Pennsylvania
In Re tbe Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number: 05-4613 Civil Term
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle J. Goodhart (age 9)
Jenna E. Goodhart (age 5)
AFFIDAVIT OF VERIFICATION
THE STATE OF: Pennsylvania
COUNTY OF: Cumberland
BEFORE ME, Dominic C. Goodhart, the undersigned authority and the Plaintiff in the above
referenced case, on this day personally appeared who, being by me duly sworn, upon oath say:
My name is: Dominic C. Goodhart
Social Security #: 176-54-9133
Driver's License #: 22-328-084
My mailing address is: 487 Highland Court, Carlisle, P A 17013
Phone: (717) 385-8152
The facts contained within the foregoing Complaint for Divorce are true and correct to the best of my
knowledge, information, and belief, and that I am authorized to make this affidavit.
Signed and dated on this \ day of \)e<..~".,be , 2005.
~~.G~
State of Pennsylvania
County of Cumberland
SWORN TO AND SUBSCRIBED BEFORE ME by the said Dominic C. Goodhart, on this L
day of{1('( \ }lll-i:" , 2005, the undersigned, a Notary Public in and for said State, personally
Page I of2
appeared Dominic C. Goodhart, the Plaintiff, known to me (or proved on the basis of satisfactory
evidence) to be the person whose name is subscribed to within the instrument and acknowledged that
he executed the same.
Witness my hand and official seal.
,Lunch.. /71( (/IJ i/r1----
Notary Public
My commission expires:
Notary Seal:
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
LINDA McCLELLAN, Notary Public
Boro of Carlisle, Cumberland County
My Commission Expires ~:~, 26'.2(}()Y
Page 2 of2
'.---
".^
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number: 05-4613 Civil Term
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle J. Goodhart (age 9)
Jenna E. Goodhart (age 5)
AFFIDAVIT OF VERIFICATION
THE STATE OF: Pennsylvania
COUNTY OF: Cumberland
BEFORE ME, Tammy S. Goodhart, the undersigned authority and the Defendant in the above
referenced case, on this day personally appeared who, being by me duly sworn, upon oath say:
My name is: Tammy S. Goodhart
Social Security #: 210-60-9047
Driver's License #: 22-132-529
My mailing address is: 370 Grahams Woods Road, Carlisle, PA 17013
Phone: (717) 385-5112
The facts contained within the foregoing Complaint for Divorce are true and correct to the best of my
knowledge, information, and belief, and that I am authorized to make this affidavit
Signed and dated on this I day of .JR Hl'r\ b U)005.
~.
--- ^ cd
lru'1A ~'jf&
Tammy S. Defendant
County of Cumberland
State of Pennsylvania
SWORN TO AND SUBSCRIBED BEFORE ME by the said Tammy S. Goodhart, on this -L day
of Otf'f m bJ/\ , 2005, the undersigned, a Notary Public in and for said State, personally appeared
Page 1 of2
Tammy S. Goodhart, the Defendant, known to me (or proved on the basis of satisfactory evidence)
to be the person whose name is subscribed to within the instrwnent and acknowledged that he
executed the same.
Witness my hand and official seal.
,~~'l.l/;( 77 J(,(fdl(j,J-.
Notary Public
My commission expires:
Notary Seal:
::;Oi;riwillNWEAl1H OF PENNSYLVANIA
NOTARIAL SEAL
LINDA McCLELLAN, Notary Public
Bora of Carlisle, Cumberland County
My Commission E ,Ires Oct 26 2009
Page 2 of2
",'~--'
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number: 05-4613 Civil Tenn
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle J. Goodhart (age 9)
Jenna E. Goodhart (age 5)
(/1__ L ~
Dominic C. Goodhart, Plaintiff
ACKNOWLEDGEMENT BY THE PLAINTIFF
THE STATE OF: Pennsylvania
COUNTY OF: Cumberland
Before me, a Notary Public, the undersigned officer, personally appeared Dominic C. Goodhart,
known to me to be the person whose name is subscribed to this written instrument, and
acknowledge that he executed the same for the purposes therein contained.
A Complaint for Divorce under Section 301 (c) of the Divorce Code was filed on September 7,
2005.
I, the Plaintiff, agree that the marriage of the Plaintiff and the Defendant is irretrievably broken and
ninety (90) days have elapsed from the date of the filing of the Complaint for Divorce. All
infonnation contained within the attached documentation is true and correct to the best of my
knowledge, infonnation and belief.
It is my desire to file with the Cumberland County Court of Common Pleas the attached Marital
Settlement Agreement and to be bound fully and completely by the tenns and conditions as set
forth within said Marital Settlement Agreement documentation.
Signed and dated on this \
day of [) (<-en. 6 t'n2005.
State of Pennsylvania
County of Cumberland
SWORN TO AND SUBSCRIBED BEFORE ME by the said Dominic C. Goodhart, on this-L
day of J.l( 'f n', ~ C ~ , 2005, the undersigned, a Notary Public in and for said State, personally
Page I of2
AI
,
.
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number: 05-4613 Civil Term
v.
~bnilllwJ-
y S. odhart, Defendant
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle J. Goodhart (age 9)
Jenna E. Goodhart (age 5)
ACKNOWLEDGEMENT BY THE DEFENDANT
THE STATE OF: Pennsylvania
COUNTY OF: Cumberland
Before me, a Notary Public, the undersigned officer, personally appeared Tammy S. Goodhart,
known to me to be the person whose name is subscribed to this written instrument, and
acknowledge that she executed the same for the purposes therein contained.
A Complaint for Divorce under Section 301 (c) of the Divorce Code was filed on September 7,
2005.
I, the Defendant, agree that the marriage of the Plaintiff and the Defendant is irretrievably broken
and ninety (90) days have elapsed from the date of the filing of the Complaint for Divorce. All
information contained within the attached documentation is true and correct to the best of my
knowledge, information and belief.
It is my desire to file with the Cumberland County Court of Common Pleas the attached Marital
Settlement Agreement and to be bound fully and completely by the terms and conditions as set
forth within said Marital Settlement Agreement documentation.
Signed and dated on this --L-- day of ~ 2005.
County of Cumberland
State of Pennsylvania
SWORN TO AND SUBSCRIBED BEFORE ME by the said Tammy S. Goodhart, on this-L
Page 1 of2
....lI!' '.
.
day of l:let I? h1 b.i ^- , 2005, the undersigned, a Notary Public in and for said State, personally
appeared Tammy s. Goodhart, the Defendant, known to me (or proved on the basis of
satisfactory evidence) to be the person whose name is subscribed to within the instrument and
acknowledged that he executed the same.
Witness my hand and official seal.
c~ /Yy,(r. /)1d: hlftJ ']A.
Notary Public
My commission expires:
Notary Seal:
;;OMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
LINDA McCLELlAN. Notary Public
Boro of Carlisle, Cumberland County
My Commission EXIliras Oct. 26. 2009
Page 2 of2
----
----.-
...../-:'
--
-
... -
,
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number: 05-4613 Civil Term
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle J. Goodhart (age 9)
Jenna E. Goodhart (age 5)
AFFIDAVIT OF CONSENT BY THE PLAINTIFF
THE STATE OF: Pennsylvania
COUNTY OF: Cumberland
1. A Complaint for Divorce under Section 3301 (c) of the Divorce Code was filed on
September 7, 2005.
2. The marriage of the Plaintiff and Defendant is irretrievably broken
and ninety (90) days have elapsed from the date offiling the Complaint for
Divorce.
3. 1 consent to the entry of the fmal Decree of Divorce after service
of intention to request entry of the Decree of Divorce.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER SECTION 3301 (e) OF THE
DIVORCE CODE.
1. I consent to the entry of a fmal Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, distribution
of debts, child custody, visitation, child support, lawyer's fees, or expenses if! do not claim
them before a Decree of Divorce is granted by the Court.
3. I understand that I will not be divorced until a Decree of Divorce is entered by the Court
and that a copy of the Decree of Divorce will be sent to me immediately after it is filed with the
prothonotary.
Page lof2
. -
I verify that the statements made in this affidavit are true and correct. I understand that fulse
statement here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to
unsworn falsification authorities.
Signed and dated on this \
day of \)('u".,b"r,2005.
-R -- (~-
ominic C. Goodhart, PlamtIff
State of Pennsylvania
County of Cumberland
SWORN TO AND SUBSCRIBED BEFORE ME by the said Dominic C. Goodhart, on this ---.L
day of DI(,. illlJ.C\ ,2005, the undersigned, a Notary Public in and for said State, personally
appeared Dominic C. Goodhart, the Plaintiff, known to me (or proved on the basis of satisfactory
evidence) to be the person whose name is subscribed to within the instrument and acknowledged
that he executed the same.
Witness my hand and official seal.
n:7HJ"lC{a /) Jr (/ti'f!fa;i
Notary Public
My commission expires:
Notary Seal
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAl
LINDA MCCLELlAN. Notary Public
:Oro of Carlisle, CUmberland County
y Commission f Ires Oct. 26 2009
Page 2 of2
'"
11
,
Dominic C. Goodhart
Plaintiff
Case Number: 05-4613 Civil Term
.~
,.
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle J. Goodhart (age 9)
Jenna E. Goodhart (age 5)
AFFIDAVIT OF CONSENT BY THE DEFENDANT
THE STATE OF: Pennsylvania
COUNTY OF: Cumberland
1. A Complaint for Divorce under Section 3301 (c) of the Divorce Code was filed on
September 7, 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 for
Divorce.
3. 1 consent to the entry of the final Decree of Divorce after service
of intention to request entry of the Decree of Divorce.
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF
A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE
DIVORCE CODE.
J. 1 consent to the entry ofa final Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, distribution
of debts, child custody, visitation, child support, lawyer's fees, or expenses if I do not claim
them before a Decree of Divorce is granted by the Court.
3. I understand that I will not be divorced until a Decree of Divorce is entered by the Court
and that a copy of the Decree of Divorce will be sent to me immediately after it is filed with the
prothonotary.
Page 1 of2
Iv~
oodhart, Defendant
.
.l ~
1 verify that the statements made in this affidavit are true and correct. I understand that false
statement here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to
unsworn falsification authorities.
Signed and dated on this ~ day of _ ~'\ , 2005.
State of Pennsylvania
County of Cumberland
SWORN TO AND SUBSCRIBED BEFORE ME by the said Tammy S. Goodhart, on this ~
day of 0..('<" '" 6..v\ , 2005, the undersigned, a Notary Public in and for said State, personally
appeared Tammy S. Goodhart, the Defendant, known to me (or proved on the basis of
satisfactory evidence) to be the person whose name is subscribed to within the instrument and
acknowledged that he executed the same.
Witness my hand and official seal.
oIA/lru rhr (!f!t1ffl />'-../
Notary Public
My commission expires:
Notary Seal
<;OMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
LINDA McCLELLAN, Notary Public
Boro of Carlisle, Cumberland County
Commission E ires Oct. 26 2009
-, _. ~..
Page 2 of2
,\
(..'
(,."'
c
Dominic C. Goodhart
Plaintiff
Case Number: 05-4613 Civil Term
~ ..
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle J. Goodhart (age 9)
Jenna E. Goodhart (age 5)
DECLARATION UNDER THE UNIFORM CHILD
CUSTODY JURISDICTION ACT
We, the undersigned, Plaintiff and Defendant, are the parties of this proceeding to determine the
custody arrangements of 2 children, and upon oath state the following 1. There are 2 minor children
subject to this child custody proceeding. The names, social security numbers, sexes, ages, birth
dates, are as follows:
Child #1
Full Name: Janelle J Goodhart
Age: 9 .
Birth Date: October 17,1996
Birth Place: Carlisle, P A
Sex: FemaJe
SS#: 196-76-8234
Current Address: 370 Grahams Woods Road, Carlisle, P A 17013
Length of Residence: 3 months
Currently Resides With: Tammy S. Goodhart
Previous Address #1: 38 Betty Nelson Court, Carlisle, PA 17013
Resided With: Tammy S. Goodhart
Child#2
Full Name: Jenna E Goodhart
Age: 5
Birth Date: July 7, 2000
Birth Place: Carlisle, P A
Sex: Female
SS#: 210-78-4309
Current Address: 370 Grahams Woods Road, Carlisle, PA 17013
Length of Residence: 3 months
Currently Resides With: Tammy S. Goodhart
Previous Address #1: 38 Betty Nelson Court, Carlisle, P A 17013
Resided With: Tammy S. Goodhart
Page 1 of3
Mail Address: 370 Grahams Woods Road
Carlisle, P A 17013
(717)385-3115
.--- ~ .
~'\\l'1)~ ~nthQ\..lr-
T y S. odhart, fendant
[~- \ -OS-
2. We state that neither of us have participated as a party or a witness or in any other capacity in
any other litigation or child custody proceeding in this state or elsewhere concerning the custody
of the children subject to this proceeding.
3. We state that neither of us have any information concerning any other litigation or custody
proceeding in this state or elsewhere concerning the child custody of the children subject to this
proceeding.
4. We state that neither of us knows of any other person who is not a party to this proceeding
who has physical or legal child custody or claims to have child custody or visitation rights of any
child subject to this proceeding.
VERIFICATION
The facts contained within the foregoing are true and correct to the best of my knowledge,
information, and belief, and that I am authorized to make this affidavit.
Signed and dated on this (
dayof De...,,,h-lr, 2005.
ff- C ~. /;2_/_U)r
Dominic C. Goodhart, Plaintiff
Mail Address: 487 Highland Court
Carlisle, P A 17013
Phone: (717) 385-8152
Phone:
State of Pennsylvania
County of Cumberland
SWORN TO AND SUBSCRIBED BEFORE ME by the said Dominic C. Goodhart, on
this -!--- day of 0,(.( >yO I2cA ,2005, the undersigned, a Notary Public in and
for said State, personally appeared Dominic C. Goodhart, the Plaintiff, known to me (or
proved on the basis of satisfactory evidence) to be the person whose name is subscribed
to within the instrument and acknowledged that he executed the same.
Witness my hand and official seal.
Notary Seal:
'-x!l. t)(JVj j J k( 6 f f,'h.
Notary Public
COMMONWEALTH OF PENNSYLV commission expires:
NOTARIAL SEAL
LINDA McCLELLAN, Notary Public
Boro of Carlisle, Cumberland County
~L~~sio'!..~XIlires Oct;~l~06f3
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number: 05-4613 Civil Term
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle J. Goodhart (age 9)
Jenna E. Goodhart (age 5)
Domestic Relations Income and Expense Statement ofthe Plaintiff
This affidavit has been completed by Dominic C. Goodhart, Plaintiff, and is the actual
monthly financial information as of OeG 0 I , 2005.
Information About Plaintiff:
Name: Dominic C. Goodhart
Social Security Number: 176-54-9133
Driver's License/State ID Number: 22-328-084
Issuing State: P A
Age: 34
Birth Date: February 21,1971
Current Residence Address: 487 Highland Court, Carlisle, P A 17013
Mailing Address: 487 Highland Court, Carlisle, P A 17013
Telephone Number: 717-385-8152
Name of Employer: ECI Construction
Address of Employment: 124 Church St, Dillsburg, Pa, 17019
Work Telephone Number: 717-432-0864
A. Statement of Monthlv Income and Deductions
1. Gross Income Per Month
a. Salary/Wages
b. Draw
c. Bonus
d. Pension
$ ?7;).O
$ 0
$ 0
$ CJ
10f4
e. Annuity $ 0
f. Social Security $ ('J
g. Dividends $ 0
h. Interest $ 0
i. Trusts $ 0
j. Public Aid' $ 0
k. Worker's Compensation $ 0
J. Unemployment Compensation $ n
m. Rents $ 0
n. Disability Payments $ 0
o. Stocks $ 0
p. Bonds $ 0
q. Other (specify) $ 0
TOTAL GROSS MONTHLY INCOME $ ;:7"). 0
2. Required Deductions
a. Federal Taxes $ ). w1
b. State Taxes $ qO
c. Social Security $ iy3
d. Medicare Taxes $ L-r;
d. Local Taxes $ in
e. Unemployment Taxes $ .'1,
f. Mandatory Retirement Contributions $ 0
g. Union Dues $ 0
h. Health Insurance $ "'i{
i. Prior Obligation of Support actually paid $ I...{i,)
j. Expenditures of repayment of debts $ 0
k. Other (specify) $ (;I
TOTAL MONTHLY DEDUCTIONS $ I)Sc:'
B. Monthlv Livine Exoenses
1. Household
a. Rent $ C;r:f()
b. Taxes $ 0
c. Maintenance and Repairs $ 0
d. Heat/Fuel $ 1..00
e. Electricity $ joo
f. Telephone $ /40
g. Water and Sewer $ ioO
h. Refuse Removal $ 0
i. Laundry/Dry Cleaning $ CJ
j. Cleaning Service $ 0
20f4
k. Furniture/Appliance Replacement $ (j
L Food $ i-( 00
m. Tobacco Products $ ').Do
n. Alcohol Products $ 0
o. Other (specify) $ 0
SUBTOTAL OF HOUSEHOLD EXPENSE $ ibID
2. Transportation Expense
a. Gasoline $ ').L{o
b. Repairs $ 0
c. Insurance/License $ 170
d. Payments/Replacements $ V> (] 5'
e. Alternative Transportation $ ()
f. Other (specify) $ 0
SUBTOTAL OF TRANSPORTATION EXPENSE $ 1015"
3. Personal Expense
a. Clothing $ 5"0
b. Grooming $ ()
c. Medical (doctors) $ 0
d. Insurance $ 0
e. Spousal Support (past marriage) $ 0
f. Other (specify) $ 6
SUBTOTAL OF PERSONAL EXPENSE $ 50
4. Miscellaneous Expense
a. Clubs/Entertainment $~
b. Newspapers/Magazines $ ()
c. Gifts/Donations $ 0
d. Vacations $ ()
e. Other (specify) $ 0
SUBTOTAL OF MISCELLANEOUS EXPENSE $ JOO
S. Children
a. Clothing $ 0
b. Grooming $ ()
c. Education $ 0
d. Medical (doctors) $ 6
e. Allowance $ b
30f4
f. Child Care $ "
g. Baby Sitters $ (I
h. Lessons $ tJ
i. Clubs/Summer Camp $ "
j. Entertainment $ (y
k. Support (other children) $ 0
J. Other (specify) $ 0
SUBTOTAL CHILD EXPENSES $ 0
TOTAL MONTHLY EXPENSES $ 3/'lb
C. Debts R~uirinl!: RetlUlar Payment
1. Creditor: membe.{ I ::.1
2. Creditor:
3. Creditor:
4. Creditor:
5. Creditor:
Balance $ ::: 000
Balance $
Balance $
Balance $
Balance $
Mon. Min. $ i 00
Mon. Min. $
Mon. Min. $
Mon. Min. $
Mon. Min. $
TOTAL MONTHLY DEBT EXPENSE
D. Cummulative Overview
1. Total Itemization & Calculation
TOTAL MONTHLY INCOME
TOTAL MONTHLY EXPENSE
TOTAL MONTHLY DEBT
INCOME AVAILABLE PER MONTH
(income less expenses and debt)
$ }. );)..0
$ 11710
$ j 00
$ -:> S"
I verify that the statements made in this affidavit are true and correct. I understand that false statements
here-in are made subject to penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to
authorities.
Signed and dated on this f day of veL
,2005.
J!~ G / 9
minic C. Goodhart, Plaintiff
Mail Address: 487 Highland Court
Carlisle, PA 17013
Telephone: 717-385-8152
40f4
,..\
~",
"
. .
. .
~.'
......~
i
Court of Common Pleas, Cumberland County, Pelllnsylvania
In Re the Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number: 0 'i-4613 Civil Term
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle 1. Goodhart (age 9)
Jenna E. Goodhart (age 5)
Domestic Relations Income and Expense Stateme:lt of the Defendant
This affidavit has been completed by Tammy S. Goodhart, Defendant, a ad is the actual
monthly financial information as of I ;:L\-l ' 2005.
Information About Plaintiff:
Name: Tammy S. Goodhart
Social Security Number: 210-60-9047
Driver's License/State ID Number: 22.132-529
Issuing State: P A
Age: 36
Birth Date: October 12, 1969
Current Residence Address: 370 Grahams Woods Road, Carlisle, PA 17013
Mailing Address: 370 Grahams Woods Road, Carlisle, PA 17013
Telephone Number: 717-385-3115
Name of Employer: Clairmont Nursing Home
Address of Employment: 1000 Clairmont Road, Carlisle, P A 17013
Work Telephone Number: 717-243-1717
Name of Employer: VFW Post 477
Address of Employment: 959 Trindle Road, Carlisle, P A 17013
Work Telephone Number: 717-258-4412
A. Statement of Monthly Income and Deductions
1. Gross Income Per Month
a. SalarylWages
b. Draw
$ 10 7~~'-
$ /-
10f4
,
. ,
c. Bonus
d. Pension
e. Annuity
f. Social Security
g. Dividends
h. Interest
i. Trusts
j. Public Aid'
k. Worker's Compensation
I. Unemployment Compensation
m. Rents
n. Disability Payments
o. Stocks
p. Bonds
q. Other (specify)
TOTAL GROSS MONTHLY INCOME
2. Required Deductions
a. Federal Taxes
b. State Taxes
c. Social Security
d. Medicare Taxes
d. Local Taxes
e. Unemployment Taxes
f. Mandatory Retirement Contributions
g. Union Dues
h. Health Insurance
i. Prior Obligation of Support actually paid
j. Expenditures of repayment of debts
k. Other (specify)
TOTAL MONTHLY DEDUCTIONS
B. Monthly LiviD!! EXDenses
1. Household
a. Rent
b. Taxes
c. Maintenance and Repairs
d. Heat/Fuel
e. Electricity
f. Telephone
g. Water and Sewer
h. Refuse Removal
2of4
$
$
$
$
$
$
~~
$/
$ /A
$ ./
$ //
$/,/
$/
--
$ ID 70 .
$ $.~-
$ :;:. -
$_L .~C
$ /1). -.
$~
$ '-
$ -----
$ I~,DD
$
$
$
$
$
jliY:. -
306,-
/~
$/
$ . .I OQ__ Qf)
$~
$ ./"
$ ~
~
$
$
$
. ,
30f4
d. Medical (doctors)
e. Allowance
f. Child Care
g. Baby Sitters
h. Lessons
i. Clubs/Summer Camp
j. Entertainment
k. Support (other children)
I. Other (specify)
$ ~
$
$
$ --;>
$
$ /d
$ -//
$
$ /
~O, .-
$
$ 122'i1'-
SUBTOTAL CHILD EXPENSES
TOTAL MONTHLY EXPENSES
C. Debts ReQuirine: Ree:ular Payment
1. Creditor: SeCVl../.)
2. Creditor:
3. Creditor:
4. Creditor:
5. Creditor:
Balance $
Balance $
Balance $
Balance $
Balance $
Mon. Min. $ f) L~.-"
Mon. Min. $
Mon. Min. $
Mon. Min. $
Mon. Min. $
TOTAL MONTHLY DEBT EXPENSE
D. Cummulative Overview
1. Total Itemization & Calculation
TOTAL MONTHLY INCOME
TOTAL MONTHLY EXPENSE
TOTAl, MONTHLY DEBT
INCOME AVAILABLE PER MONTH
(income less expenses and debt)
$
$
$
-
ID70.
/ ;);;?~. .-
tN(J -"
-3cr8:-
$
I verify that the statements made in this affidavit are true and correct. I understand that false statements
here-in are made subject to penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to
authorities.
Signed and dated on this ~ day of 't!7 .c~ 2005.
CJ~~
Mail Address: 370 Grahams Woods Road
Carlisle, P A 17013
Telephone: 717-385-3115
40f4
I.:)
.J
j
r... .
~
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number: 05-4613 Civil Term
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle J. Goodhart (age 9)
Jenna E. Goodhart (age 5)
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Kindly Transmit the Record, together with the following information, the Court for entry of a Decree
of Divorce:
I. Ground for Divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code.
2. Date and Manner of Service of the Complaint for Divorce:
Approximate date of service: September 12, 2005
Type of service: constable
3. Complete Paragraph (a) or (b):
(a) date of execution of the Affidavit /Consent Waiver required by Section 3301 (c) of the Divorce
Code:
By Plaintiff: tf!::. c.- ~ 12-' -0 S--
By Defendant:\fr{1ilI.I'?\';?(-:::1In)7U'\~ IOJ ./- (!.!J-
(b) date of execution ofilfe Affidavit /Consent Waiver required by Section 3301 (d) of the Divorce
Code:
By Plaintiff:
By Defendant:
4. Related Claims Pending: None.
Signed and dated on this / day of [)EC
,2005.
Page 1 of2
.
".
Mail Address: 487 Highland Court
Carlisle, P A 17013
Phone: (717) 385-8152
Mail Address: 370 Grahams Woods Road
Carlisle, PA 17013
Phone: (717)385-3115
iif- c.----9- I? - /- oS-
minic C. Goodhart, Plaintiff
~
Page 2 of2
'J--I - 05,-
DOMINIC C. GOODHART
V.
TAMMY S. GOODHART
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2005 - 4613 CIVIL TERM
ORDER OF COURT
AND NOW, this 7TH day of DECEMBER. 2005, it appearing to the court that the
affidavits of consent were executed and filed within ninety (90) days of the service of the
divorce complaint in violation of Pa. Rule of Civil Procedure 1920.42 (b), the request for
the entry of a final divorce decree is DENIED without prejudice.
,Dbminic C. Goodhart
& 487 Highland Court
Carlisle, Pa. 17013
/fa"mmy S. Goodhart
370 Grahams Woods Road
Carlisle, Pa. 17013
:sld
.~
Edward E. Guido, 1.
("
~
) \'
! .'~
/-------
..
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number: 05-4613 Civil Term
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle J. Goodhart (age 9)
Jenna E. Goodhart (age 5)
AFFIDAVIT OF VERIFICATION
THE STATE OF: Pennsylvania
COUNTY OF: Cumberland
BEFORE ME, Dominic C. Goodhart, the undersigned authority and the Plaintiff in the above
referenced case, on this day personally appeared who, being by me duly sworn, upon oath say:
My name is: Dominic C. Goodhart
Social Security #: 176-54-9133
Driver's License #: 22-328-084
My mailing address is: 487 Highland Court, Carlisle, P A 17013
Phone: (717) 385-8152
The facts contained within the foregoing Complaint for Divorce are true and correct to the best of my
knowledge, information, and belief, and that I am authorized to make this affidavit.
Signed and dated on this 19th day of December, 2005.
//v C ..-9-
OO'minic C. Goodhart, Plaintiff
County of Cumberland
SWORN TO AND SUBSCRIBED BEFORE ME by the said Dominic C. Goodhart, on this 19th day
of December, 2005, the undersigned, a Notary Public in and for said State, personally appeared
State of Pennsylvania
Page 1 of2
C) ....,
c = ~
~
on
\- = -l
,.,.\ ...,..
" f'n:D
N -.,j:;:;
::'/J~
0 ,...,T
"--iC)
-~ "r -r,
, ~:+- -n
'':0
t';-:' (51"11
~--1
._~ U1 ~.
U> .<
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number: 05-4613 Civil Term
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle J. Goodhart (age 9)
Jenna E. Goodhart (age 5)
AFFIDAVIT OF VERIFICATION
THE STATE OF: Pennsylvania
COUNTY OF: Cumberland
BEFORE ME, Tammy S. Goodhart, the undersigned authority and the Defendant in the above
referenced case, on this day personally appeared who, being by me duly sworn, upon oath say:
My name is: Tammy S. Goodhart
Social Security #: 210-60-9047
Driver's License #: 22-132-529
My mailing address is: 370 Grahams Woods Road, Carlisle, PA 17013
Phone: (717) 385-5112
The facts contained within the foregoing Complaint for Divorce are true and correct to the best of my
knowledge, information, and belief, and that 1 am authorized to make this affidavit.
Signed and dated on this 19th day of December, 2005.
County of Cumberland
SWORN TO AND SUBSCRIBED BEFORE ME by the said Tammy S. Goodhart, on this 19th day
of December, 2005, the undersigned, a Notary Public in and for said State, personally appeared
State of Pennsylvania
Page 1 of2
.....,
=
=
c.n
CJ
r-1
"
N
Cl
o
"
:rJ.."
n'F
-om
:nO
(5L
-:;JS?
,'-):!l
"'0
t)rn
:-=-4
~~
.<
~
'!?
C>
c:>
~
~
,
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number: 05-4613 Civil Term
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle J. Goodhart (age 9)
Jenna E. Goodhart (age 5)
ACKNOWLEDGEMENT BY THE PLAINTIFF
THE STATE OF: Pennsylvania
COUNTY OF: Cumberland
Before me, a Notary Public, the undersigned officer, personally appeared Dominic C. Goodhart,
known to me to be the person whose name is subscribed to this written instrument, and
acknowledge that he executed the same for the purposes therein contained.
A Complaint for Divorce under Section 301 (c) of the Divorce Code was filed on September 7,
2005.
I, the Plaintiff, agree that the marriage of the Plaintiff and the Defendant is irretrievably broken and
ninety (90) days have elapsed from the date of the filing of the Complaint for Divorce. All
information contained within the attached documentation is true and correct to the best of my
knowledge, information and belief.
It is my desire to file with the Cumberland County Court of Common Pleas the attached Marital
Settlement Agreement and to be bound fully and completely by the terms and conditions as set
forth within said Marital Settlement Agreement documentation.
Signed and dated on this 19th day of December, 2005.
c~
County of Cumberland
State of Pennsylvania
SWORN TO AND SUBSCRIBED BEFORE ME by the said Dominic C. Goodhart, on this 19th
day of December, 2005, the undersigned, a Notary Public in and for said State, personally
Page 1 of2
.
.
..
appeared Dominic C. Goodhart, the Plaintiff, known to me (or proved on the basis of satisfactory
evidence) to be the person whose name is subscribed to within the instrument and acknowledged
that he executed the same.
Witness my hand and official seal.
~'"
\
Notary Pulilic
My commission e
Notary Seal:
c,,;..WiONWEAllt1 OF PENNSYLVANiA
\ NO'"""", SEAL
DAWN M. SH.,' .... Notary Public
Boro of CnF., .,,'''e~and Counly
"y r-o....,(l",:~~;I()n:;.~J'i"!:\:. Nov. 28, 2O'Jt.
\ IV. ..... .",' ','
Page 2 of2
'"
=
(::")
e,r,
c;
-n
.-J
I::rJ
rnr:-:....
:.-qm
,')'?
;;";1 ~F~
'f:j~
:u
-<
o
r-;"'j
C)
r'..)
CJ
-0
(.,J
o
CJ
.
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number: 05-4613 Civil Term
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle J. Goodhart (age 9)
Jenna E. Goodhart (age 5)
ACKNOWLEDGEMENT BY THE DEFENDANT
THE STATE OF: Pennsylvania
COUNTY OF: Cumberland
Before me, a Notary Public, the undersigned officer, personally appeared Tammy S. Goodhart,
known to me to be the person whose name is subscribed to this written instrument, and
acknowledge that she executed the same for the purposes therein contained.
A Complaint for Divorce under Section 301 (c) of the Divorce Code was filed on September 7,
2005.
I, the Defendant, agree that the marriage of the Plaintiff and the Defendant is irretrievably broken
and ninety (90) days have elapsed from the date of the filing of the Complaint for Divorce. All
information contained within the attached documentation is true and correct to the best of my
knowledge, information and belief.
It is my desire to file with the Cumberland County Court of Common Pleas the attached Marital
Settlement Agreement and to be bound fully and completely by the terms and conditions as set
forth within said Marital Settlement Agreement documentation.
Signed and dated on this 19th day of December, 2005.
County of Cumberland
State of Pennsylvania
SWORN TO AND SUBSCRIBED BEFORE ME by the said Tammy S. Goodhart, on this 19th
Page 1 of2
.
day of December, 2005, the undersigned, a Notary Public in and for said State, personally
appeared Tammy S. Goodhart, the Defendant, known to me (or proved on the basis of
satisfactory evidence) to be the person whose name is subscribed to within the instrument and
acknowledged that he executed the same.
Witness my hand and official seal.
Notary Pub ic
My commission expires:
Notary Seal:
CGiioiv,ONWEALTH OF PENNSYLV"hjiA
NOTARIAL SEAL
DAWN M. SHUGHART. Notary Public
Boro of Carlisle, Cumbertand Counly
M~kommlsslanExplres Nov. 2~~
-.--' "-',---'" ...--.------.......-
Page 2 of2
.-,-
"
,.....,
=
~cg
o
.,
~-n
n1-
r-
-om
:;J?
':..:{U
.:~~:8
:>0
('jm
"'"
~
-<
'='
it'l
("")
f'.'
CJ
:J~
(..J
o
CO
,
.'
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number: 05-4613 Civil Term
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle 1. Goodhart (age 9)
Jenna E. Goodhart (age 5)
AFFIDAVIT OF CONSENT BY THE PLAINTIFF
THE STATE OF: Pennsylvania
COUNTY OF: Cumberland
1. A Complaint for Divorce under Section 3301 (c) of the Divorce Code was filed on
September 7, 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 for
Divorce.
3. I consent to the entry of the final Decree of Divorce after service
of intention to request entry of the Decree of 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 fmal Decree of Divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, distribution
of debts, child custody, visitation, child support, lawyer's fees, or expenses if I do not claim
them before a Decree of Divorce is granted by the Court.
3. I understand that I will not be divorced until a Decree of Divorce is entered by the Court
and that a copy of the Decree of Divorce will be sent to me immediately after it is filed with the
prothonotary.
Page 1 of2
."
I verify that the statements made in this affidavit are true and correct. I understand that false
statement here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to
unsworn falsification authorities.
Signed and dated on this 19th day of December, 2005.
d::;G:~
State of Pennsylvania
County of Cumberland
SWORN TO AND SUBSCRIBED BEFORE ME by the said Dominic C. Goodhart, on this 19th
day of December, 2005, the undersigned, a Notary Public in and for said State, personally
appeared Dominic C. Goodhart, the Plaintiff, known to me (or proved on the basis of satisfactory
evidence) to be the person whose name is subscribed to within the instrument and acknowledged
that he executed the same.
Witness my hand and official seal.
~
Notary Public
My commission e pires:
Notary Seal
"M' "-"WEA'JH O! :'c>''';;;','~VAN\A
'_'~_ ,....,4yl\.)I~ L ,,~,.'_,__
- NOTARIAL Si: ,,'
DAWN M. SHUGHARl "',,'o'Y Public
Boro of Carlisle. Cumbel .GndCoun1Y
,. , "",;-;-:;nlsslon E)(plres NOV., 16. 2006
..,.,~._----~"'"
Page 2 of2
p
~'. ,>~
I ~
,-.,
=
<:;::)
en
<::::J
rq
(-,j
1'\)
CJ
o
"
-l
::C"
r-/l;:==
:g9
)6
~:1~i
')('5
,,-'-)fTJ
;---=-t
1:;....
~lJ
-<
:<!
(:..?
C)
C)
....~,
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number: 05-4613 Civil Term
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle 1. Goodhart (age 9)
Jenna E. Goodhart (age 5)
AFFIDAVIT OF CONSENT BY THE DEFENDANT
THE STATE OF: Pennsylvania
COUNTY OF: Cumberland
1. A Complaint for Divorce under Section 3301 (c) of the Divorce Code was filed on
September 7, 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 for
Divorce.
3. I consent to the entry of the final Decree of Divorce after service
of intention to request entry of the Decree of 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, distribution
of debts, child custody, visitation, child support, lawyer's fees, or expenses if! do not claim
them before a Decree of Divorce is granted by the Court.
3. I understand that I will not be divorced until a Decree of Divorce is entered by the Court
and that a copy of the Decree of Divorce will be sent to me immediately after it is filed with the
prothonotary.
Page 1 of2
".
..
I verify that the statements made in this affidavit are true and correct. I understand that false
statement here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to
unsworn falsification authorities.
Signed and dated on this 19th day of December, 2005.
k
State of Pennsylvania
County of Cumberland
SWORN TO AND SUBSCRIBED BEFORE ME by the said Tammy S. Goodhart, on this 19th
day of December, 2005, the undersigned, a Notary Public in and for said State, personally
appeared Tammy S. Goodhart, the Defendant, known to me (or proved on the basis of
satisfactory evidence) to be the person whose name is subscribed to within the instrument and
acknowledged that he executed the same.
Witness my hand and official seaL
~
Notary Public
My commission expIres:
Notary Seal
--." 'O'I"WEI-' "" C" "'t',NSYLVANIA
1...,.".IIVlIV1" ",'". .,-".~-~
NOTf- ,~i '. 'j'.AL
DAWN M. SHU"," .\ ,jory Public
Bo;o of Ca~lsle,:;u""",'an(ll1d County
.... ~-~mIMlon '." ."", '''0V, 28. 2006
",,'."~'111 ;JoI;l... ," ...____
Page 2 of2
0 '''''
,.--- = 0
'. =
<'~ "" 'Tl
0 :r!
rq
c-) hl.:!J
'" j-
"m
a "19
()o
-0 :T1...
r~ ::!: ;~~2 :r:l
~o
"'" elm
-...1 '0-1
0 .l~
'. ~n
co .-<
-
, .
,
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number: 05-4613 Civil Term
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle J. Goodhart (age 9)
Jenna E. Goodhart (age 5)
DECLARATION UNDER THE UNIFORM CHILD
CUSTODY JURISDICTION ACT
We, the undersigned, Plaintiff and Defendant, are the parties of this proceeding to determine the
custody arrangements of 2 children, and upon oath state the following 1. There are 2 minor children
subject to this child custody proceeding. The names, social security numbers, sexes, ages, birth
dates, are as follows:
Child #1
Full Name: Janelle J Goodhart
Age: 9 .
Birth Date: October 17,1996
Birth Place: Carlisle, P A
Sex: Female
SS#: 196-76-8234
Current Address: 370 Grahams Woods Road, Carlisle, PA 17013
Length of Residence: 3 months
Currently Resides With: Tammy S. Goodhart
Previous Address # I: 38 Betty Nelson Court, Carlisle, P A 17013
Resided With: Tammy S. Goodhart
Child#2
Full Name: Jenna E Goodhart
Age: 5
Birth Date: July 7, 2000
Birth Place: Carlisle, P A
Sex: Female
SS#: 210-78-4309
Current Address: 370 Grahams Woods Road, Carlisle, P A 17013
Length of Residence: 3 months
Currently Resides With: Tammy S. Goodhart
Previous Address #1: 38 Betty Nelson Court, Carlisle, PA 17013
Resided With: Tammy S. Goodhart
Page 1 of3
- .
.
2. We state that neither of us have participated as a party or a witness or in any other capacity in
any other litigation or child custody proceeding in this state or elsewhere concerning the custody
of the children subject to this proceeding.
3. We state that neither of us have any information concerning any other litigation or custody
proceeding in this state or elsewhere concerning the child custody of the children subject to this
proceeding.
4. We state that neither of us knows of any other person who is not a party to this proceeding
who has physical or legal child custody or claims to have child custody or visitation rights of any
child subject to this proceeding.
VERIFICATION
The facts contained within the foregoing are true and correct to the best of my knowledge,
information, and belief, and that I am authorized to make this affidavit.
Signed and dated on this 19th day of December, 2005.
{::::c. ~O~ff
Mail Address: 487 Highland Court
Carlisle, PA 17013
Phone: (717) 385-8152
Mail Address: 370 Grahams Woods Road
Carlisle, PA 17013
Phone: (717) 385-3115
State of Pennsylvania
County of Cumberland
SWORN TO AND SUBSCRIBED BEFORE ME by the said Dominic C. Goodhart, on
this 19th day of December, 2005, the undersigned, a Notary Public in and
for said State, personally appeared Dominic C. Goodhart, the Plaintiff, known to me (or
proved on the basis of satisfactory evidence) to be the person whose name is subscribed
to within the instrument and acknowledged that he executed the same.
.w.im~\m.v.'Ah"ncl ancl.official seal.
__....I...VI..Wt:J rm-OFPENNSYlVi\'I,
NOTARIAL SEAL
DAWN M. SHUGHART. Notary Public
!:iura of Carlisle. Cumberland County
rv,'L<:.:ommlsslon Explr~ Nov. 2~..;>oo!'\
Notary Seal:
\
L~ML )}i \/ AL)
Notary Public ,J
My commission expires:
Page 2 00
State of Pennsylvania
County of Cumberland
SWORN TO AND SUBSCRIBED BEFORE ME by the said Tammy S. Goodhart, on
this 19th day of December, 2005, the undersigned, a Notary Public in and
for said State, personally appeared Tammy S. Goodhart, the Defendant, known to me
(or proved on the basis of satisfactory evidence) to be the person whose name is
subscribed to within the instrument and acknowledged that he executed the same.
Witness my hand and official seal. '
. I
l\~ /Yl it;!')
Notary Public )
My commission expires:
Notary Seal:
.:':'~,~::':):~WEALTH OF PENNSYLVANIA
---- NOTARIAL SEAL
DAWN M. SHUGHART. Notary Public
buRl uf CarlISle. Cumberland County
~,,, r-')~mlS$!on Expires Nov. 28, 2006
Page 3 00
o
>-
-,
....,
=
=
C~
=
1'1
c>
o
-rl
-....
Mi::D
-oF,;
25?
~!_~3}
<:.0
!..srn
:};!
:D
.<
r",)
CJ
-0
-,".~
<.::.'
c::>
o
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number: 05-4613 Civil Term
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle J. Goodhart (age 9)
Jenna E. Goodhart (age 5)
Marital Settlement Agreement
This agreement is made on this 19th day of December, 2005, between Dominic C.
Goodhart, the Plaintiff, with a social security number of 176-54-9133, who lives at 487
Highland Court, Carlisle, PA l7013 (phone: 717-385-8152) and the county of
Cumberland and Tammy S. Goodhart, the Defendant, with a social security number of
210-60-9047, who lives at 370 Grahams Woods Road, Carlisle, PA 17013 (phone: 717-
385-3115) and the county of Cumberland.
The Plaintiff and Defendant may from time to time throughout this agreement,
individually and collectively, be referred to as "Party" or "Parties" and "Parent" or
"Parents" .
The Plaintiff is currently employed by ECI Construction, which is located at, 124
Church Street, Dillsburg, P A 17019 (telephone number: 717-432-0864).
The Defendant is currently employed by the VFW Post 477, which is located at 959
Trindle Road, Carlisle, P A 17013 (telephone number: 717-258-4412) and the Clairmont
Nursing home, which is located at, 1000 Clairmont Road, Carlisle, P A 17013 (telephone
number: 717-243-1717).
1. Recitals:
The parties are making this agreement with reference to the following facts:
The parties were married on January 6,1990 in the City of Carlisle,
Pennsylvania, and separated on or about, September 15, 2002.
Plaintiff's Initial: ~
Defendant's Initials: ~
Page 1 of II
. .
As a result of serious disputes, conflict of personalities, and unique goals and
differences, the parties honestly believe that the marriage is irretrievably broken and that
there is no possible chance for reconciliation. For this reason each party desires to settle
fully and finally all aspects and rights, by this agreement, of the marital affairs including,
but not limited to; Property and Debt Distribution, RetirementJPensionIProfit
Sharingl40lK Accounts, Spousal Maintenance, Child Custody, Visitation, Child
Support, Medical and Health Insurance, Secondary School Expenses, Child care, Tax
Exemptions, and Income Tax Returns.
The parties each hereby acknowledge that there are 2 children born of the
marriage under the age of eighteen (18).
The information about each child is as follows:
Child # 1
Full Name: Janelle J. Goodhart
Age: 9
Date of Birth: October 17, 1996
Sex: Female
SS#: 196-76-8234
Child #2
Full Name: Jenna E. Goodhart
Age: 5
Date of Birth: July 7, 2000
Sex: Female
SS#: 210-78-4309
The parties each now intend by this agreement to settle fully and finally all of
their respective rights and obligations arising out of or related to the marriage that
otherwise could be adjudicated in the above captioned case number.
There is no other pending action filed by either party regarding the dissolution of
the marriage.
The date of execution of this agreement is the day on which the agreement is
signed by both parties.
Any transfer of property, funds, debts and/or documents pursuant to the
agreement shall be made on the date of the execution of this agreement, if not already
done so, unless otherwise specified in this agreement.
The parties both agree to lead separate lives, and, except for the duties and
obligations imposed and assumed under this agreement, each shall be free from
interference and control of the other as fully as if he or she were single. The parties each
agree not to molest, interfere with, or harass the other.
Plaintiff's Initial: ~
Defendant's Initials: ~
Page 2 of 11
2. ProDertv and Debt Distribution:
As of the date of this agreement, the parties each do not possess all of his and her
marital and non-marital property or are either solely responsible for any of the debt that
will be described below.
The parties agree that the following marital property shall be the sole and
separate property of Dominic C. Goodhart, the Plaintiff, and Tammy S. Goodhart, the
Defendant transfers and quitclaims any interest that she may have in this marital
property to the Plaintiff: None.
The parties agree that the following marital property shall be the sole and
separate property of Tammy S. Goodhart, the Defendant, and Dominic C. Goodhart, the
Plaintiff transfers and quitclaims any interest that he may have in this marital property to
the Defendant: None.
The parties agree that Dominic C. Goodhart, the Plaintiff, shall pay and
indemnify and hold Tammy S. Goodhart, the Defendant, harmless from the following
marital debts: None.
The parties agree that Tammy S. Goodhart, the Defendant, shall pay and
indemnify and hold Dominic C. Goodhart, the Plaintiff, harmless from the following
marital debts: None.
The parties agree that the following non-marital (separate) property shall be the
sole and separate property of Dominic C. Goodhart, the Plaintiff, and Tammy S.
Goodhart, the Defendant transfers and quitclaims any interest that she may have in this
non-marital (separate) property to the Plaintiff: None.
The parties agree that the following non-marital (separate) property shall be the
sole and separate property of Tammy S. Goodhart, the Defendant, and Dominic C.
Goodhart, the Plaintiff transfers and quitclaims any interest that he may have in this non-
marital (separate) property to the Defendant: None.
The parties agree that Dominic C. Goodhart, the Plaintiff, shall pay and
indemnify and hold Tammy S. Goodhart, the Defendant, harmless from the following
non-marital (separate) debts: None.
The parties agree that Tammy S. Goodhart, the Defendant, shall pay and
indemnify and hold Dominic C. Goodhart, the Plaintiff, harmless from the following
non-marital (separate) debts: Sears Credit Card for $8,500.00. In addition, Tammy S.
Goodhart, will do whatever is necessary to remove Dominic C. Goodhart from her
charge account and establish and individual account and assume all liabilities for the
charges she has made on this account.
The parties both hereby represent and warrant that as of the date of this
agreement, they do not possess any property or interests in property other than the items
Plaintiffs Initial: D'
Defendant's Initials: - \ <;
Page 3 of 11
listed in this agreement; and that the items set forth and listed in the agreement constitute
full and complete disclosure.
In addition to the items listed in this agreement, if any undisclosed property or
interests in property is discovered subsequently, and a court of competent jurisdiction
determines it to be marital or community property of the parties, such discovery and
determination shall not invalidate this agreement but, the property or the interest in it
shall at the election of the discovering party (i) be divided equally or equitably in kind or
(ii) be accounted for by the party in possession who may pay to the discovering party a
sum of money to offset an equal or equitable portion.
The parties both hereby represent and warrant that except for the debts and
obligations set forth and listed above, each has not incurred any other outstanding debt
or obligation on which the other may become liable, nor has either party incurred any
obligation that could henceforth be enforced against any asset held or received pursuant
to this agreement.
In the event that any outstanding debt or obligation of any kind has been incurred
by either party, other than those listed above (and is hereafter asserted against the other),
the party actually incurring the debt or obligation shall assume and be solely responsible
for paying it and shall hold the other party harmless from all claims with respect to the
debts, obligations, and expenses with respect to those debts.
In the event that the other party becomes a debtor in any bankruptcy or financial
reorganization proceeding of any kind while this agreement is in effect, that debtor party
waives any and all rights to any property held by the other party which is in fulfillment
of this agreement. The debtor party will also convey to the other party that the
bankruptcy or fmancial reorganization proceeding is going to take place.
The parties acknowledge and agree that the credit history established by them
during their marriage shall be deemed to have the credit history of both parties, not
withstanding ordinary practices of creditors and credit reporting agencies that may have
reported such credit history in the name of one party. Both parties agree to cooperate and
execute any documents as may be required to enable each other to provide to prospective
creditors the full credit history of the parties that was established during the marriage.
The parties each represent to the other that from the date of this agreement each
party shall not charge or incur or cause to be incurred any liability or obligations based
on the credit or name of the other. Each of the parties shall do whatever is necessary to
close immediately all joint accounts.
The parties each forever waive any right to inherit from the other and the right to
receive any property on the death of the other, except as a beneficiary of any life
insurance policy, by reason of a will, codicil, or republication of will by the other party
executed subsequent to the date of this agreement.
Plaintiff's Initial: 11 ~
Defendant's Initials: \b}
Page 4 of 11
The parties each waives all right to act as administrator of the other party's estate
and all right to request or petition for the appointment of any person to serve as such
representative or to act as the executor of the other's will, unless expressly named in a
will, codicil, or republication of will by the other party executed subsequent to the date
of this agreement.
2. Marital Home:
There is no martial home.
3. Retirement AccountslPensions/401KslProfit Sharinl! Plans:
The parties each waive all claims, present and future to pension benefits,
retirement funds, 401k's, profit sharing plans and accounts of the like.
4. Spousal Maintenance:
After careful consideration of the circumstances and all the other terms of this
agreement, the parties agree to waive any rights or claims that he or she may have now
or in the future to receive ant rehabilitative or permanent spousal maintenance from the
other party. The parties both agree each will be responsible for his and her own health
and medical insurance coverage.
6. Child Custody and Visitation:
The parties agree that it is in the best interest of the children that the Plaintiff and
Defendant have joint legal custody of the children, born of this marriage. Both parties
acknowledge that the actual primary physical residence of the children may be changed
at anytime through proper court procedure or as they mutually agree.
The parties agree that the parent with who the children reside shall have control
over the minor day-to-day decisions affecting the children.
All decisions pertaining to the education, discipline, health, extracurricular and
summer activities, religious training, medical and dental care, and welfare of the children
will be decided by both parties after reasonable and adequate discussion.
The parties agree to share information about the children openly and free with
one another and agree not to hamper or interfere with the natural and continuing
relationship between the children and the other parent.
The parties agree that the children should have as much contact with each parent
and that the children may visit the other parent as often as may be agreed upon.
Although possession time may be scheduled more often, each parent will have the right
to be with the children at the following times:
Plaintiffs Initial: \) (;
Defendant's Initials: T~
Page 5 of 11
A. Husband shall have the minor children every Thursday evening commencing at
5:00 p.m. until 9:00 p.m. The husband will pick the children up at the Wife's residence
and the Wife will pick the children up at 9:00 p.m. from the husband's residence.
B. Husband shall have the minor children overnight every other weekend
commencing at 5:30 p.m. on Friday as presently in effect. During those weeks that
Husband has weekend visitation with the children, he shall pick the children up at Wife's
residence at 5:30 P.M. on Friday and return them home at 6:00 p.m. on Sunday. Except in
the event there is a holiday following the weekend in which the husband is conducting
visitation with the children then said visitation shall terminate at 6:00 p.m. on Monday.
C. On Thanksgiving Day, 2005, Husband shall have the minor Child, thereafter the
Parties shall alternate spending Thanksgiving Day with the Children.
D. The Christmas Holiday shall be defined as commencing at 5:00 p.m. on December
24th and continuing until 12:00 P.M. December 25th. Commencing in 2006, Husband shall
have the minor Child with him from 5:00 p.m. on December 24th until 12:00 p.m. on
December 25th. Thereafter the Parties will alternate spending the Christmas Holiday with
the children.
E. The Christmas Holiday Vacation period shall be defined as commencing at 8:00
am. on December 26th and continuing until 6:00 p.m. January 2nd of the following year.
Commencing in 2005, Wife shall have the children for the first \I.z of the Christmas Holiday
Vacation and Husband shall have the minor children for the second \I.z of the Christmas
Holiday Vacation commencing at 8:00 a.m. on December 29 until 6:00 p.m. on January 2nd
of the upcoming year. Thereafter the Parties shall alternate spending the Christmas Holiday
Vacation with the minor children.
F. The Spring Vacation Period however designated and established by the Children's
school system. Commencing at 8:00 am. on the first day of the vacation until 6:00 on the
last day of the vacation. Commencing in 2006, Husband shall have the minor children for
the first \I.z of the Spring Vacation period and Wife shall have the children for the second \I.z
of the Spring Vacation Period. Thereafter the Parties shall alternate spending the Spring
Vacation Period with the minor children.
G. Easter Holiday shall be defined as commencing at 6:00 p.m. on the Saturday before
Easter until 6:00 p.m. on Easter Day. Commencing in 2006, the Husband shall have the
minor children for the Easter Holiday. Thereafter the Parties will alternate spending the
Easter Holiday with the minor children.
H. The minor Child shall spend Mother's Day weekend with the Wife and Father's Day
weekend with the Husband.
I. On Independence Day, 2006, Husband shaJJ have the minor Child from 9:00 am.
until 9:00 p.m. Thereafter, the Parties shall alternate spending Independence Day with the
minor children.
Plaintiff's Initial: ~'b b
Defendant's Initials: l<S
Page 6 of 11
J. In addition to the above Schedule, Husband shall be entitled to have the children for
two (2) weeks during the Children's summer vacation. The Husband will have the minor
children for (I) week uninterrupted vacation time during the month or July and again in the
month of August. Husband will notify the Wife in writing at least (I) week prior to the
vacation periods.
If either Husband or Wife is unable to be with the Children during the
designated period, he or she shall make this known to the other, in writing at least
one (I) week in advance of the schedule visitation. If scheduled visitation does not
occur, then the Parties shall proceed to the next scheduled visit as stated in this
Agreement.
The parties additionally agree to use their very best efforts to insure that the
children receive the most care, love and affection possible.
The parties agree that it is in the best interest of the children that both parents
have joint/shared legal custody of the children.
All decisions pertaining to the education, discipline, health, extracurricular and
summer activities, religious training, medical and dental care, and welfare of the children
will be decided by both parties after reasonable and adequate discussion.
The parties agree to share information about the children openly and free with
one another and agree not to hamper or interfere with the natural and continuing
relationship between the children and the other parent.
7. Pareotiol! Plan! Al!reement:
The parties would like to make it known that there is not a parenting
agreement/plan in effect as of the date of this agreement.
8. Child Support:
The parties agree that the Plaintiff will pay the Defendant, as child support, the
total amount of $450.00 per month for the support of the children as well as the health
insurance premiums for both minor children. As ordered on 1/20/2004 Court of
Common Pleas of Cumberland County, Pennsylvania, Domestic Relations Section,
PACSES Case Number: 665106004, Docket No. 01094 S 2003. The payments are
presently in effect and will continued to be paid in accordance with the Order until the
children reach the age of eighteen (18), dies, becomes self-supporting, or married. The
parties also agree that the child support obligation is subject to modification by the court
at any time.
Since there is more than one child of this marriage, the child support obligation
should be adjusted appropriately as each child reaches the age of eighteen (18).
Plaintiff's Initial: "i) t
Defendant's Initials: - \~
Page 7 of 11
.'
9. MedicaJIHealthlDental Insurance:
The parties agree that for as long as the child support payments are being made,
the Plaintiff will carry and maintain health and hospitalization insurance for the
children's benefit. In addition the Defendant will pay the first $250.00 of the uninsured
medicals or expenses not covered by the health insurance for the children in accordance
with court order. The Plaintiff and the Defendant will split the cost of the children's
dental bills equally.
10. Secondary School Exoenses:
The parties agree that neither parent will be responsible for any secondary
educational tuition and/or related expenses.
11. Child Care:
The parties agree that the Plaintiff will not be responsible for any child care and
related expenses above and beyond the standard monthly child support obligation.
12. Tax Exemotions:
The parties agree that the Defendant will be entitled to claim the children as
dependants on her federal, state, and local tax returns.
13. Income Tax Returns:
The parties agree that they will file separate federal and state tax returns for the
calendar year in which this agreement is made into effect.
The parties both agree that they will cooperate in the filing of any necessary tax
returns.
For each calendar year after the year this agreement is made into effect, each
party shall file separate federal, state and local income tax returns, in which each shall
include and report all of his or her separate income and shall pay all income taxes due.
The parties each agree to notifY the other promptly in the event the IRS or any
state or local taxing authority provides notice of an audit, deficiency, refund, or the
adjustment regarding a tax return that was jointly filed or that should have been jointly
filed. The party receiving such notice from a taxing authority shall provide a copy of the
notice to the other party within 20 days of receiving it.
The parties further agree to cooperate fully with the other in any claims for
refunds or in defending against any deficiencies that may be determined with respect to
joint income tax returns filed (or to be filed). This includes, without limitation, the
Plaintiff's Initial: ~
Defendant's Initials: \J1
Page 8 of 11
" ..'
making, executing, and filing of amended income tax returns; applications for refunds,
protests, and other instruments; and documents as may be required. The costs and
expenses for such will be divided equally between the parties.
14. Professional Fees and Costs:
The parties have not acquired any professional service fees which they desire to
be recognized, mentioned, or distributed by this agreement.
15. Advice of Counsel:
The parties each acknowledge that they have the legal right to representation by
separate attorneys. The parties each fully understand his and her rights and the contents
of this agreement.
The parties each consider the terms of this agreement to be fair and reasonable
and each party accepts sole responsibility for any decisions, and potential repercussions
of those decisions, which are presented as part of this agreement.
16. Mutual Releases:
Each party hereby releases the other from any claim against the other for any
reason occurring prior to this agreement, whether that claim is founded in contract, tort,
or any other basis.
17. GovernineLaw:
The parties agree that this document is intended to be a full and an entire
settlement and agreement between them regarding the marital rights and obligations and
that this agreement, and all contents within, shall be interpreted and governed by the
laws of the State of Pennsylvania.
18. Entire Aereement:
This agreement constitutes the entire and full agreement between the parties. If
any clause is held unenforceable or found to be in any way non-executable, or if a court
alters or holds unenforceable any clause in this agreement, this shall in no way affect or
alter the other clauses in the agreement, which shall remain in full force.
No amendment or modification to this agreement or any judgment, decree or
order based on it shall be valid unless signed and agreed to by both parties or ordered by
the court.
Plaintiff's Initial: ~ c;.
Defendant's Initials: ~
Page 9 of 11
'----
19. Further Assurances:
The parties shall execute and deliver promptly on request any additional papers,
documents, and other assurances reasonably necessary in connection with the
performance of the obligations set forth in this agreement. In the event that either party
fails or refuses to comply with the provisions of this agreement, the failing party shall
reimburse the other party for all loses and expenses including, but not limited to,
attorney's fees and all costs incurred as a result of such failure.
20. Cantions and Internretations:
Paragraph captions have been used throughout this agreement for convenience
and reference only and are not intended to be used in the construction or interpretation
of this agreement or any ofits provisions. No provision of this agreement is to be
interpreted for or against any party by virtue of the fact that the provision was drafted
by that party or that party's counsel.
21. Submission to Court:
This agreement has been drafted and executed with the intention that it be
submitted by either party to any court before which a Complaint for Divorce may be
pending or initially filed for approval by the court and for incorporation into a Decree of
Divorce.
21. Successions:
The parties each acknowledge that this agreement, and each provision of it, is expressly
made binding upon the heirs, assigns, executors, administrators, representatives and
successors in the interest of each party.
Signed and dated on this 19th day of December, 2005.
11---- C ____9-
D<Yntinic C. Goodhart, Plaintiff
~.
\ill ' ,~~~
Tariuny S., ,fendant
State of Pennsylvania
County of Cumberland
SWORN TO AND SUBSCRIBED BEFORE ME by the said Dominic C. Goodhart, on
this 19th day of December, 2005, the undersigned, a Notary Public in and
Page 10 of11
for said State, personally appeared Dominic C. Goodhart, the Plaintiff, known to me (or
proved on the basis of satisfactory evidence) to be the person whose name is subscribed
to within the instrument and acknowledged that he executed the same.
Witness my hand and official seal.
.:()~.~~!.CNWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
DAWN M. SHUGHART. Notary Public
burG of Cartisle. Cumbertand County
My Commission Explres Nov. 28, 2006
,~----_.,-,-,-"--_......_,.._...._._-----
Notary Public
My commission expires:
Notary Seal:
State of Pennsylvania
County of Cumberland
SWORN TO AND SUBSCRIBED BEFORE ME by the said Tammy S. Goodhart, on
this 19th day of December, 2005, the undersigned, a Notary Public in and
for said State, personally appeared Tammy S. Goodhart, the Defendant, known to me
(or proved on the basis of satisfactory evidence) to be the person whose name is
subscribed to within the instrument and acknowledged that he executed the same.
Witness my hand and official seal.
Notary Public
My commission expires:
Notary Seal:
..~." '~'''''<''',H m PENNSYLVANIA
,-,.~'.l..nL
- -'"NOTARiAL SEAL
, pAIN'" M. SHUGHART. Notary Public
bufO uf CartlSle. cumbertand CO~
~,.. ,...,,~~'IJlsj;\on..BIDJw.5.-Nov. 28.
Page 11 of 11
L-__
':
()
...:
~.)
C._,
r::-.-;:.
1.:...,..,
o
.,
=r
r-ll:JJ
:T'h1
(:10
:;j~~l
/S ~~d
:.()
l~jrn
:--1
ul>
~'.o
-<
(::-t
1'"'1
C)
f',)
o
..."
3:
C."
l-::'!
CJ
" .
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Dominic C. Goodhart
Plaintiff
Case Number: 05-4613 Civil Term
v.
Tammy S. Goodhart
Defendant
And in the interest of (minor children)
Janelle 1. Goodhart (age 9)
Jenna E. Goodhart (age 5)
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Kindly Transmit the Record, together with the following information, the Court for entry of a Decree
of Divorce:
1. Ground for Divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code.
2. Date and Manner of Service of the Complaint for Divorce:
Approximate date of service: September 12, 2005
Type of service: constable
3. Complete Paragraph (a) or (b):
(a) date of execution of the Affidavit IConsent Waiver required by Section 3301 (c) of the Divorce
Code:
By Plaintiff: December 19, 2005
By Defendant: December 19, 2005
(b) date of execution of the Affidavit IConsent Waiver required by Section 3301 (d) of the Divorce
Code:
By Plaintiff:
By Defendant:
4. Related Claims Pending: None.
Signed and dated on this 19th day of December, 2005.
Page 1 of2
r
,
Mail Address: 487 Highland Court
Carlisle, PA 17013
Phone: (717) 385-8152
Mail Address: 370 Grahams Woods Road
Carlisle, P A 17013
Phone: (717)385-3115
pt~ C ~
Dominic C. Goodhart, Plaintiff
Page 2 of2
(')
;.-
l
r
"->
':'::;;;:)
=
::..."
(:)
'Tl
:::l
f1~:O
-o~
;.)9
'"1 (j.
~':5 :'T~
-;--0
iSm
;r;!
.n
-<
=
in
C)
['0.)
a
"
::.'.:
~^?
o
o
.'
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
:f.:f. :+.:f.:f.:f. 'Ii
'Ii :f.:f.:f.'li:f.'li:f.
..
..
'li'li:t::+:
:+::f.:+::+::+::+: :+;:+:;f:+.:+.:+::f.:f.
'Ii:f.:f.:+; '+:+: '+ 'Ii:+':+:
+:f.:f.+:f.+:++
.
.
.
.
.
.
.
.
IN THE COURT OF COMMON
PLEAS
OF CUMBERLAND COUNTY
STATE OF
DL'/Yl i A1 i t:!-
c.
Go" i'> "tART
;t
.
.
.
.
.
.
.
.
.
.
.
.
.
,
.
.
.
,
.
,
.
.
.
.
.
.
,
.
,
.
.
.
.
,
.
,
.
.
,
.
.
.
,
.
.
.
.
. ATTEST;
.
.
.
.
,
.
.
.
.
.
~:f.:+':f. ++:+.'li:+.:+.:+.:f.:+.:f.:+.+ :f.:+.:+. :+.+.+:+. ++:+.:f.:+.:f.:+.:+.:f.:+.:+.:+.:f.:+.+:+.:f. :+.:f.:f.:+.:f.:+.
Vi tlIlJTII'" t=-
VERSUS
-r;. rYJ N1 Y
:5
(;. ,,In'' I-IJ'tRr
DF: F'IE N l:>ti /', T
DECREE IN
.
.
.
.
.
.
.
.
.
,
.
.
,
.
.
.
.
.
.
.
.
.
.
.
.
.
.
,
.
.
.
.
.
.
.
.
.
.
.
.
.
,
.
,
.
,
.
.
.
.
.
.
.
.
,
.
,
.
.
.
.
.
.
,
.
.
.
.
.
.
.
.
,
.
.
,
.
.
.
,
.
,
.
.
J. '
.
,
.
,
.
,
PROTHONOTARY ,
,
.
.
:+.:+.:+.+:+.+:+:+:+.+:+.++:+.+++++++:+.+:+.+?
PENNA.
No.
C,VIL Ti;i</VI
0,;;" "n 1.'3
DIVORCE
-e:Jf / I. ''/O!.tV{
;W;
AND NOW,
~
, IT IS ORDERED AND
DECREED THAT
Do (Y) II.) It'
AND
-
I "tmfll V
I
.<\
.JI
c.
&-/?o.'" I-I/AR,
, PLAINTIFF,
(,.."'r1,.., 111'11'<.'-
. DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
YET BEEN ENTERED;
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
,1 vv--L
/C
~YTH
~;7;). tf?(T'",:"7/ ~7;A 5IY ~ (";/
Jj.4 ? ~U( #;;:'9 517, tC'e/
.o?
'*,
. .