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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 (") ~ <;~ ":~" ~ (":) " 1- -.... ~ ~ -~'- . -- -- 'a ~ ~ -3t f' f! () ~ J. r-:> 0 ~ -n '~ :t-n ~ r.....' rnr~ -'u -d C1 N -', ~ - ":t::> CP ' ;'\(2 ~~ .;; -c; ,-2;:~) -' J:,.. ,on ....P :;\' t.:? ~-;.o :J'~ r--'> ...... -' 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. Date: /;'-rJq-o~ 2 ~ ~ ~ ~ ~:g ..... c;:;... -u tOp rnrn ~ Z-ll ~~ ZC \ (.f.l e. cJ\ =<'jII<.. ~~ ~c -0 ~C) :.c. ~ --'0 e,..') 9 '"'pC ~ .' ~ cJ\ Q) 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. Date: !~ J 7-tJ~ ~rl.' .rJ 2, ~ ""=n .... ~ ;,- ~ c;..... '. ~~ ~ " itl -' k;":C ~.t; #'~ ". " t:.n 'T'. ..... ~:n,. ;:..(-;;- ~ t.:2. ....,' '"'0 n 'J?: (1 -;S'. ,(fl bO (..) A y'C:: .' ~ ~ $ 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 ~~~~ <2 ~ --otp ""'"'rn \.J,j ,,~" ~~ :::.(:..:. r:;O :.:::: ~o ~Q y~ ~ q. ~ ~~", ~ . ~ ~. ~~ v, ~ \D 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. Date: / /J/d? / / ~ (, -ieJ.~ ch~, en~==- .-./ $2 ~ --otQ D;~1' ~c:, mY;. :.(. ~.:.-" tL.C.i z.c; __u yC ~ ~ ~ ~ i~ \ ~ (J\ Q ~:a ~ %~ c,..) ~ .' ~ (J\ ~ u;J Amy J. Daihl- Gochenauer, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. Robbie J. Gochenauer, Defendant CIVIL ACTION - LAW No.06-571O CIVIL IN DIVORCE PROOF OF SERVICE I" ,'llilW".,.....~~ ---.....,.. ,-_.~.-' ... ~.. .,-idte Items 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. . Print your name and address on the reverse 10 that we can return the carcI to you. . Attach this carcI to the back of the mallpiece, or on the front If space permits. 1. Nticle Addressed to: \ZDb'olL ), GDchenaud ~t9 ()rrcS~ t2ead ftpt-, 3 3. ServlceType ~ Mall [] Express Mall o RegIstenJd ~m Recetpt for Me.oo.dII Qf1). .~ 4. AMbIct$d ~ /BlfnI Fee) t7otf4" !ft ?~d6h~~I?~l?f~721 _... eom.tIc Ram RIceIpt 1021llli . M 1l54O , (") ~ ~ -u~ = -..4 <- ~:n mffl :x> 2:1:) :;;r;: ~1T1 z:c- I wJ3:, :uO ;:$6 co S~6 ,"'::: -0 :~.L:rl ';,;n ...,... c:>~ !=~ ~ ~.( ) J;~ om ~ --I (11 ~ C-., -< 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 g s: "'ocr..' 0.1 i{ 2(-'" (I) )..: ~t, ~, J;> " z-~) 5-~" ~ ::2 ... f"o.,:) ~ ~ --' ~ ~ I 0) ~ ~:n ~f;ij ~~ ~ ~~ - ~ ;;, ~ 0'"> ?~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~+.~+.~+.~~~~~~~~~~+.~+.~~+.~ 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 ° C:7 ~' "l"3 l~7 ~, • ~, ~- ~~ ~ -ra ~.._ _- ~-~ :., 3 i_~ :~ ~~ rn ~~ ~_' ~. __;- t~~~~ ~Er 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 ~~ .r~ 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: ~ Il. oo Pa A,~1 e~'~ ~saR ~~`~ja.o8ly