HomeMy WebLinkAbout06-5710
Amy 1. Daihl- Gochenauer,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
Robbie J. Gochenauer,
Defendant
CIVIL ACTION - LAW
No.C:I.- ~71{) CIVIL
IN DIVORCE
NOTICE
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
serv.ed, by entering a written appearance personally or by 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
without further notice for any money claimed in the complaint or for any other claim or relief
requested by the plaintiff. You may lose money or property or other rights important to you.
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, High and Hanover Streets, Carlisle.
YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE, IF YOU DO NOT
HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE
TO PROVIDE YOU WITH INFORMA nON ABOUT AGENCIES THAT MA Y OFFER LEGAL
SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. .
Cumberland County Bar Association
32 South Bedford Street
Carlisle, P A 17013
Phone: (717) 249-3166
(800) 990-9108
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the Court, please contact
our office. All arrangements must be made at least 72 hours prior to any hearing or business before
the Court. You must attend the scheduled conference or hearing,
Amy J. Daihl- Gochenauer,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
Robbie 1. Gochenauer,
Defendant
CIVIL ACTION - LAW
No.C:i..-S"IIO CIVIL
IN DIVORCE
COMPLAINT UNDER SECTION 3301(c)
OF THE DIVORCE CODE
1. Plaintiff is Amy J. Daihl- Gochenauer, an adult individual, who resides at 93 SME,
Shippensburg, Cumberland County, Pennsylvania 17257.
2, Defendant is Robbie J. Gochenauer, an adult individual, who resides at P.O. Box 41,3589
Orrstown Road, Apt. 3, Orrstown, Pennsylvania 17244.
3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at
least six months immediately previous to filing of this Complaint.
4. Plaintiff and Defendant were married on September 10, 2002 in Winchester, Virginia.
5. There have been no prior actions of divorce or for annulment between the parties hereto in
this or any other jurisdiction.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised that counseling is available, and that Plaintiff may have the
right to request that the Court require the parties to participate in counseling.
8. Plaintiff requests the Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in
Divorce and such other Orders as may be just and appropriate.
Respectfully submitted,
ROMINGER & WHARE
Date:
1/2,r(ot?
( {
LeA. Tomeo Esquire
155 South Hano er Street
Carlisle, P A 17013
(717) 241-6070
Supreme Court 1.D. # 200198
Attorney for Plaintiff
Amy J. Daihl- Gochenauer,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
Robbie J. Gochenauer,
Defendant
CIVIL ACTION - LAW
No, CIVIL
IN DIVORCE
VERIFICATION
I verify that the statements made in this Complaint Hre true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C,S. 94904, relating to unsworn
falsification to authorities.
Date: 1-c% -cp
Amy 1. Daihl- Gochenauer,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
Robbie J. Gochenauer,
Defendant
CIVIL ACTION - LAW
No. CIVIL
IN DIVORCE
CERTIFICATE OF SERVICE
I, Leslie A. Tomeo, Esquire, attorney for Plaintiff do hereby certify that I this day mailed a
copy of the within Motion upon the following by depositing same in the United States mail, postage
prepaid, at Carlisle, Pennsylvania, addressed as follows:
Robbie J. Gochenauer
3589 Orrstown Road, Apt. 3
P.O. Box 41
Orrstown, Pa 17244
Dated: '1 /1.t I 0 f.
I
Ie A. Tom , Esquire
155 South H ver Street
Carlisle, P A 7013
(717) 241-6070
Supreme Court J.D. # 200198
Attorney for Plaintiff
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Amy J. Daihl- Gochenauer,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
Robbie J. Gochenauer,
Defendant
CIVIL ACTION - LA W
No. 06-5710 CIVIL
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
September 28, 2006.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing 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 herein are made subject to the penalties of 18 Pa. C.S. ~ 4904, relating to
unsworn falsification to authorities.
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Amy 1. Daihl- Gochenauer,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
Robbie J. Gochenauer,
Defendant
CIVIL ACTION - LA W
No. 06-5710 CIVIL
IN DIVORCE
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 fmal 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
statements herein are made subject to the penalties of 18 Pa. C.S. g4904, relating to unsworn
falsification to authorities.
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Amy J. Daihl- Gochenauer,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
Robbie 1. Gochenauer,
Defendant
CIVIL ACTION - LA W
No.06-5710 CIVIL
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
September 28,2006.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90-) days
have elapsed from the date of filing 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 herein are made subject to the penalties of 18 Pa, C.S. ~ 4904, relating to
unsworn falsification to authorities.
Date: 1/.7 /0 7
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Amy 1. Daihl- Gochenauer,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
Robbie J. Gochenauer,
Defendant
CIVIL ACTION - LAW
No.06-5710 CIVIL
IN DIVORCE
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
statements herein are made subject to the penalties of 18 Pa. C.S. g4904, relating to unsworn
falsification to authorities.
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Amy J. Daihl- Gochenauer,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
Robbie J. Gochenauer,
Defendant
CIVIL ACTION - LAW
No.06-571O CIVIL
IN DIVORCE
PROOF OF SERVICE
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Amy J. Daihl- Gochenauer,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
Robbie J. Gochenauer,
Defendant
CIVIL ACTION - LA W
No,06-5710 CIVIL
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of a
divorce decree:
1. Grounds for divorce: irretrievable breakdown under ~ 3301(c) of the Divorce
Code.
2. Date and manner of service of the Complaint: September 28, 2006, was served on
Defendant by Certified Mail signed on September 29,2006 (attached hereto as
Proof of Service).
3. Date of execution of the Affidavit of Consent required by ~ 330 I (c) or The
Divorce Code: by the Plaintiff, December 29,2006; by the Defendant, January 3,
2007.
4. Related claims pending: None.
5. (b) Date Plaintiffs Waiver of Notice in ~3301(c) Divorce was filed with the
Prothonotary: January 5, 2007.
Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the
Prothonotary: January 5, 2007.
Date: January 8, 2007
Les Ie . Tomeo, E
155 South Hanover
Carlisle, PAl 70 13
(717) 241-6070
Supreme Court ID No. 200198
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNT'{
STATE ()F
PENNA.
~my.T naihl f:'-.od:lena.ller
No.
2006 S710
Plaintjff
VERSUS
Robbie J. Go'ehenauer
Def.@1dant
DECREE IN
DIVORCE
AND NOW,
J~Y\v6.~ 'i
'\
IT IS ORDERED AND
"C07
,--,
DECREED THAT
Amy J. Daihl-Gochenauer
, PLAI NTI FF,
AND
Robbie J. Gochenauer
, DEFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY,
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
Nonp
By THE COURT:
''t
ATTEST:
PROTHONOTARY
J,
, ~/ '2 A?f-1Ji.'V/ {'t~t 't, (. ,) L)
r?;;nutf:' P'7 ~fln>1/' t~) r?J L!7 L. / ·
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
Amy J. Daihl-Gochenauer
Plaintiff
Vs
Robbie J. Gochenauer
Defendant
File No. 2006-5710
IN DIVORCE °
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NOTICE TO RESUME PRIOR SURNAME ~ c_T +~:`
~ ~,~•,
Notice is hereby given that the Plaintiff/~' in the above matter, _.
[select one by marking `~c"]
prior to the entry of a Final Decree in Divorce,
or x after the entry of a Final Decree in Divorce dated O 1 / 09 / 2007 ,
hereby elects to resume the prior surname of Daihl ,and gives this
~~
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written notice avowing his /her intention pursuant to the p 'sio of 54 P. 7
Date: ~~~-~~Q
. d„
e
Signature f eing resumed
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF CUMBERLAND )
On the I~ay of , Zp~ 10 before me, the Prothonotary or the
notary public, personally appeazed above affiant known to me to be the person whose
name is subscribed to the within document and acknowledged that he /she executed the
foregoing for the purpose therein contained.
In Witness Whereof, I have hereunto set my hand hereunto set my hand and
seal.
otary Public:
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