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HomeMy WebLinkAbout06-0434DAVID R. GONDER, Plaintiff v. NATALIE A. GONDER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA CIVIL ACTION -LAW IN DIVORCE NOTICE ~ ~ ~ ~~~~~ You have been sued in Court. If you wish to defend against the claims set forth in the following papers, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in Divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT IJNCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TIiLEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Cazlisle, Pennsylvania 17013 Phone: (717) 249-3166 - ~~ Jo Ji< Conn ]ly, Jr., Esquire ' J At mey far Plaintiff DAVID R. GONDER, Plaintiff v. NATALIE A. GONDER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA NO. OG - y3 V Cw~-P T<.--- CIVIL ACTION -LAW IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING To the Within Named Defendant: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, One Courthouse Square, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Prothonotary DAVID R. GONDER, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PEN/NA v. :NO. ale - `f3y -~tv~h.~frz-rr~. NATALIE A. GONDER, :CIVIL ACTION -LAW Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE Plaintiff is David R. Gonder, social security no. , who currently resides at 803 Cocklin Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Natalie A. Gonder, social security no. , who cun•ently resides at 349 Stonehedge Lane, Mechanicsbwg, Cumberland County, Pennsylvania 17055. Plaintiffand Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 19, 2004, at Colonel Denning State Park, Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. The Defendant is not a member of the Armed Services of the United States of America or its Allies. 8. The marriage is irretrievably broken. The parties to this action have been separated since December 3Q, 2004. 9. The Plaintiffhas been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 0. Plaintiff requests the Court to enter a Decree in Divorce. 11. Plaintiffavers that she is the innocent and injured spouse, and that the Defendant has offered such indignities to the Plaintiff so as to render her condition intolerable and life burdensome. 12. This action is not collusive. COUNT II CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 13. Plaintiff and Defendant are the owners of various real and personal property, motor vehicles, bank accounts and insurance policies acquired during their marriage which aze subject to equitable distribution by this Court. WHEREFORE, the Plaintiffrequests the Court to enter a Decree: a. dissolving the marriage between the Plaintiff and Defendazit; b. equitably distributing all property owned by the parties hereto; c. for such further relief as the Court may determine equitable and just. Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY,LLP Dated: ~L By: ~ _ .' 1. _ 1~ 1 Jo J. o elly, r. Att ~n I~. #~~15 ~ P.O. Box 650 Hershey, PA 17033-0650 (717)533-3280 Attorneys for Plaintiff David R. Gonder VERIFICATION I verify that the statements made in this Pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relafing to unswom falsification to authorities. Date: I - I ~ - ~ ~ DOow~ d~Go.,e~.,`_ -sv „~ ~. RJ ..fl ~ , ~ ~ A J C ._ ~ ~ -;- r=- DAVID R. GONDER, : IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNA v. : NO.06-434 NATALIE A. GONDER, :CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN ss. AND NOW, this T~ day of February, 2006, personally appeazed before me, a Notary Public in and for the State and County aforementioned, John J. Connelly, Jr., Esquire, who, being duly sworn according to law, deposes and says that a copy of the Divorce Complaint was served on the Defendant, Natalie A. Gonder, on January 28, 2006, by certified mail number 7003 2260 0005 6552 8117, as evidenced by the return receipt card attached hereto and made a part hereof. Sworn to and sulb7scr}bed before me this I ~ day of February, 2006. ~ ~1 Notary P blic COMMONWEALTH OF PENNSYLVANIA Notarial Seal Maria B. Lague, Notary PuW~ Deny Twp., Dauphin County MY Commission Expires Nov. 8, 2009 Member, Pennsylvania Aeaoclation of Notaries ^ Complete items 1, 2, and 3. Also complete kern 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Adtlressetl to: ~Ua~AI~~ A- ~~nc~~~ ~~1~ 5-1-~~~~~ ~a~ ~~kc~n~n~~S~~~2r~ ~~ `~ \'10'5 ^ Atltlres9sa B. ec~ived by (Pn'nted lmeJ C. Date of Delivery D. Is deli l~lserant fmm item 1? ^ Yes If Y er delive dress below: ~No zL. 6 E 3. Serv ~j~ is d F~rass Mall ^ Regist Retum Recelpt for Merchendiae ^Insured Ma ~ C.0.0. 4. Restric[etl Dalivery7 (Extra Fee) ~ 2. Article Number ma,,,~rmmr~ 7003 2263 0005 6552 8117 PS Form 3811, February 2004 Domestic Return Receipt 70259592-M-15A0 DAVID R. GONDER, Plaintiff v. NATALIE A. GO Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.06-434 CIVIL ACTION -LAW IN DIVORCE PRAECII'E TO THE PROTHONOT~ Please change action to Natalie A. name of the Defendant, Natalie A. Gonder in the above-captioned divorce Respectfully submitted, JAMES, SMITH, DIETTERICK & CONNELLY, LLP Dated: A' ~`~'~ By: Attorneys for Plaintiff Hershey, PA 17033-0650 (717)533-3280 c~ N a ~ -n c . ~, ~. ~ ~,, -cap c ~ n1r , U1 1~~'' ~ CT ~(3 ~ r C.~~ .ty ~ "r ~~~ C7 `t.:~ w ~m 5> c. ~ -- ..c ?i?12 FFg 27 p~ 2- ~~ CUFfBERLA~ID ~:QUN i PENNS YI.Vq ~r,q DAVID R. GONDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NATALIE A. GONDER, Defendant CIVIL ACTION -LAW NO. 2006-434 CIVIL TERM IN DIVORCE NOTICE TO DEFENDANT If you wish to deny any of the statements set forth in this Affidavit, you must file a Counter Affidavit within twenty (20) days after this Affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated or about ~3 SG~.n~(Z.~ 01041.E and have continued to live separately and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsification to authorities. Date: o~ j a ~ ~~©l a - ~- Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717)774-1445 2~' ~ ~'l~l~ 2~ ~~+ ~ ~ ~ v ERL i~+h6i]. COUP~~'1' DAVID R. GONDER , Plaintiff v. NATALIE A. GONDER, Defendant ~~I~~'~17'I' OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-434 CIVIL ACTION -LAW PRAECIPE TO WITHDRAW APPEARANCE Please withdraw my appearance on behalf of David R. Gonder in the above-captioned matter. Respectfully submitted, Dated: _ ~ ~ '" ~ ~- PRAECIPE TO ENTER APPEARANCE Please enter my appearance on behalf of David R. Gonder in the above-captioned matter. Dated: riersriey, YA l /U33 (717) 533-3280 Supreme Court LU. 15615 13arbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court I.D. 32317 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717)774-1445 ,.. . . ti ,~' t, !~'! G .r DAVID R. GONDER, Plaintiff v. NATALIE A. GONDER, Defendant TO THE PROTHONOTARY: IN THE NEON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-434 CIVIL ACTION -LAW PRAECIPE TO WITHDRAW Please withdraw the Plaintiffls claim for Equitable Distribution of Marital Property in the above captioned divorce action. Date: May 1, 2012 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717)774-1445 David R. Gonder, Plaintiff v. Natalie A. Gonder, Defendant -~ _ l r r _~~ ~ ~ " 1 :} ' '~~ ~ ~3~1`~~E`~-- j ~ ! 7 ~'S f , , ~i';J r ;.J ~ ~~,:R '~ -' ~ ~ Axe ~ i , v ;" IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-434 CIVII, ACTION -LAW WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statement herein are made subject to the penalties of 18 Pa.C.S.§4904 relating to unsworn falsification to authorities. DATE: y l23 l Zola ~~1~' YS1Cn~ David R. Gonder Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717}774-1445 ` David R. Gonder, Plaintiff v. Natalie A. Gonder, Defendant f ~1- ~ ~' f t ,','~r,~~Y'#t~~- ~~f~'-~ - i m. h;! "f l ~ ~ r.. IN THE-'~CT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-434 GIVII, ACTION -LAW AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on January 23, 2006. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. DATE: 4 ~ 2.312012 ~~ DAVID R. Gonder _ 9 ~ 1 k i t`I S J ~.J !Y i~~:~i~SvL..l~;~IP. DAVID R. GONDER, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2006-434 NATALIE A. GONDER, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on 23 January 2006 and served upon the Defendant within thirty days thereafter. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of both the filing and service of the complaint. 3. I consent to the entry of a final decree in divorce after service of a Notice of Intention to Request Entry of the Decree. 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 in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. /Z~/~Z Dated: _,._.~~ ~ .... ///7 P A ..~ e ~ ~l. NATALIE A. STOU ,~~ Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717)774-1445 fr?; , ~~~ If : ;.~ r, .~ ~,;f. DAVID R. GONDER, Plaintiff v. NATALIE A. GONDER, Defendant IN THE C ~~,~j~'1vfoN PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-434 CIVIL ACTION -LAW JOINT MOTION TO CORRECT DEFENDANT'S NAME AND AMEND CAPTION AND TO REDACT PRIVATE INFORMATION ON PUBLIC RECORD AND NOW, this2 ! day of April, 2012, the parties, through this joint motion of their counsel, request an Order correcting the Defendant's name and amending the caption and redacting private information on the public record. 1. Petitioners are Plaintiff and Defendant in the above captioned matter. 2. On August 16, 2006, Defendant, through prior counsel, filed a Praecipe to Correct Defendant's Last Name, but no change was made of record. 3. Defendant's correct and legal name is "Natalie A. Stoup", but was incorrectly listed as "Natalie A. Gonder." 4. Further, the Divorce Complaint document found on the public access docket search records lists the parties' social security numbers and birthdates. 5 6. The parties do not desire to make this information available for public access and request the information be redacted. No judge has been assigned to this matter. 7. Both attorneys, Barbara Sumple-Sullivan, Esquire for Plaintiff and Samuel L. Andes, Esquire for Defendant join in this Motion. WHEREAS, Petitioners respectfully request the Court change Defendant's name to "Natalie A. Stoup" and correct the case caption to reflect same. Petitioners also request the Court redact any and all public listings of the parties' social security numbers and dates of birth. Date: Barbara Sumple-Sullivan, Esquire Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court ID No. 32317 S L. s, Esquire Attorney for Defendant 525 North 12th Street P.O. Box 168 Lemoyne, PA 17043 (717) 761-5361 Supreme Court ID No. 17225 Bazbaza Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717)774-1445 .: i'; ,~, si~d: ~ ~~~~ ; ~~i~Y -2 ~+~~ III V; ~mi1~~S~~FtLMi~Ci CQ~~~dT' DAVID R. GONDER, Plaintiff v. NATALIE A. GONDER, Defendant I1V"I'HL-«1RT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-434 CIVIL ACTION -LAW PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under X3301 (c) of the Divorce Code. 2. Date and manner of service of the complaint: January 28, 2006. 3. Date of execution of the Affidavit of Consent required by ,¢ 3301 (c) of the Divorce Code: by Plaintiff April 23, 2012; by Defendant: April 26, 2012. 4. Related claims pending: All claims have been withdrawn. 5. Date Plaintiffs Waiver of Notice in ~3301(c) Divorce was filed with Prothonotary: May 2, 2012. Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with Prothonotary: May 2, 2012. ^ Dated: May 1, 2012 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070-1931 (717)-774-1445 Supreme Court ID #32317 Attorney for Defendant Bazbaza Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717)774-1445 DAVID R. GONDER, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NATALIE A. GONDER, Defendant NO. 06-434 CIVIL ACTION -LAW CERTIFICATE OF SERVICE I, Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing Plaintiffs Praecipe to Transmit Record, in the above-captioned matter upon the following individual by first class mail, postage prepaid, addressed as follows: Mr. Samuel Andes 525 North 12th Street P.O. Box 168 Lemoyne, PA 17043 DATED: May 1, 2012 ~Barbarple-Sullivan, Esquire 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 Supreme Court I.D. No. 32317 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAVID R. GONDER V. NATALIE A. STOUP NO. 06-434 DIVORCE DECREE ~ Zvc'i AND NOW, , it is ordered and decreed that DAVID R. GONDER , pl intiff, and NATALIE A. STOUP ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE By the o , Abmas A. Placey ~~ Comrrfiota,P.~ea~7ud~e Prothon M~a,Yro' ~0~ rn,~. /e . Sv/~aa~ 7„"` Ns ,~ Barbara Sumple-Sullivan, Esquire ~~ ~ 2 MA Y 14 PM 3~ ~ Supreme Court #32317 CUM~EE7LAt~0 ~G~~~.,€P 549 Bridge Street P~ NN S Y LVA K I A New Cumberland, PA 17070 (717)774-1445 DAVID R. GONDER, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-434 NATALIE A. GONDER, :CIVIL ACTION -LAW Defendant ORDER GRANTING MOTION TO CORRECT DEFENDANT'S NAME AND AMEND CAPTION AND TO REDACT PRIVATE INFORMATION ON PUBLIC RECORD AND NOW, to wit, this ~~day of , 2012, upon consideration of the attached Joint Motion to Correct Defendant's Name and end Caption and to Redact Private Information on Public Record, it is hereby ordered, adjudged, and decreed that: 1) The caption shall change Defendant's name to "Natalie A. Stoup;" and 2) All reference to and identification of the parties, David R. Gonder's and Natalie A. Stoup's, social security numbers and dates of birth shall be redacted from the public record. BY THE COURT: _. Thomas .Pace . Common Pleas Judge Distribution: `/Barbara Sumple-Sullivan, Esquire, 549 Bridge Street, New Cumberland, PA 17070 ~amuel L. Andes, Esquire, P.O. Box 168, Lemoyne, PA 17043 /yJ~! •%~ ( ~/i~~/2