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HomeMy WebLinkAbout94-05135 , I " I .i " 'ii , I Ii I' I, ~ .<} I, I I , I ,I I" ,I I" , I I I' II I \ ., -7 1,1 I.' I 'I " J " --5 I ,I '. .- '- ] ~ I , " I c..o I IiI I, I " I I, ' I I' I, , I I~ " J, r- , I " I I , I \ I I , , I .1 " I " - i I , I I I :r- . I 0-( 01 <I I ______~_____________t_~._____.~ . ---~_.._-_._---_.. ""-'- ....... '-->" , ".-... ,.., ..... ......-.....'.....-...-. . . : IN THE COURT OF COMMON PLEAS : 8 OF CUMBERLAND COUNTY . 8 8 8 ~ . .' STATE OF ~~.. PENNA, 8 8 8 : CYNTHIA J. GOODRICH, N' I), .5:P?"..,... : * Plain~iffqVP~.. 19 94 * 8 \,,,,,,,1., 8 8 ROBERT J. GOODRICH, JR., 8 . Defendant . ~ " 8 . * 8 DECREE IN * 8 DIVORCE . 81 . ~ AND NOW. ' , ,l>.c~~~,~, ,~.t. , , , , , , , , " 19,1. Y. '. It Is ordered and ! 8 decreed that", , , , , , , ",C;Yn,tMfI,J:. ,Op,qqr~,c,h, , . , , '" .", ", plaintiff. 8 . and""",,,,,,,,,,,,,, R,obe!"t,,~~, G,o?d!"i,~h" ,~r~".""" defendant. : 8 are divorced from the bonds of matrimony. 8 8 8 8 The court retains jurisdiction of the following claims which have 8 8 been raised of record in this action for which a final order has not yet ~ " been entered; , ~ I~ 8 no claims pending I~ 8 """""""""""""""""""""""""",""""""""""', I~ 8 ""'''''''''''''''''''''''''''''''''''''''''',,' '~ ~ ~ : ny The t!L'K oA, l :: 8 Altul, U.k.'~I-" c~ ckJ~.a, ~~4 :~ . d. .' x-:/~, K, ~4- I:: . 7' ,/ mA Prothonotary I: ~-_-_"_:_ .... _.....1ii-~;::c...i.;~.:C;~:+;~ ,:+:, ':+;, ':+:' .>>;. .:.c. ,*, .>>:',~:':;.;, ,:+;: -It;, ,>>;, ':.;,,*' ,J . CYNTHIA J. GOODRICH, I IN THE COURT OF COMMON PLEAS OF I Plaintitt I CUMBERLAND COUNTY, PENNSYLVANIA I VB. I 94 - ,7/ 3 ':J CIVIL TERM I ROBERT J. GOODRICH, JR. I LAW - DIVORCE I Detendant I NOTICI TO DI'.ND AND CLAIK RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the tollowing pages, you must take prompt action. You are warned that if you fail to do 80, the ca.e may proceed without you and a decree of 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 tor the divorce is indignities or irretrievable breakdown ot the marriage, you may request marriage counseling. A liBt of marriage counselorB is available in the Ottice of the Prothonotary at the Cumberland County Courthouse, First Floor, Carlisle, Pennsylvania 17013, Telephone: (717)-240- 6195. 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 ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Cumberland County Courthouse Fourth Floor Carlisle, PennBylvania 17013 Telephone (717)-240-6200 CYNTHIA J. GOODRICH, I IN THE COURT OF COMMON PLEAS OF I Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I VS. I 94 - r.'/ ~~- CIVIL TERM ..::;J ~. I ROBERT J. GOODRICH, JR. I LAW - DIVORCE I Defendant I COMPLAINT The plaintiff by her attorney, MURREL R. WALTERS, III, ESQUIRE, brings this action in divorce for a Decree of Divorce from the bondB of matrimony and respectfully represents: 1. The plaintiff is CYNTHIA J _ GOODRICH, an adult individual, who currently reBides at 517 state street, West Fairview, Cumberland County, Pennsylvania. 2. The defendant is ROBERT J. GOODRICH, JR., an adult individual, who currently resides at 517 state street, West Fairview, Cumberland County, Pennsylvania. 3. Plaintiff and defendant are both bona fide residents of the Commonwealth of Pennsylvania and have been for at least Bix (6) months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on October 9, 1993 in Erie, PA, 5. There have been no prior actions of divorce or for annulment between the parties. 6. The plaintiff avers that the marriage is irretrievably broken. ~ .,.. ~ ~ , :c I t a.... 0 0-1 ~':.:J ~ ., ....., .l- t 'n., ~ ~ ... ~ VI , ' , , CYNTHIA J. GOODRICH, I IN THE COURT OF COMMON PLEAS OF I Plaintitf I CUMBERLAND COUNTY, PENNSYLVANIA I va. I 94 - 5135 CIVIL TERM I ROBERT J. GOODRICH, JR. I LAW - DIVORCE I Defendant I AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 5 3301(c) of the Divorce Code was filed on September 13, 1994. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the court before the entry of a final decree in divorce, the right to claim any of them will be lost. 5. I have been adviBed of the availability of marriage counseling and I understand that I may request that the court require that my spouse and I participate in counseling. 6. I understand that the court maintains a list of marriage counselors at its DomeBtic Relations Office, which list is available to me upon request. 7. Being so adviBed, I do not requeBt that the court require my spouse and I participate in counseling prior to a divorce decreQ being handed down by the court. 8. I acknowledge that I personally accepted a copy of the Divorce Complaint on September 19, 1994. I, ROBERT J. GOODRICH, JR., verify that the statements made in this Affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa, C.S. 54904, relating to unsworn falsification to authorities. t:}i-~4"H'l,..6q /L( (</ ~I ,( JR. ;,i!; ,. " ., . ., :w: ,,- 0 '.. ." -:r " , n ,- ... . c ... ':. = ,', " , ':' " , CYNTHIA J. GOODRICH, I IN TH! COURT OF COMMON PLEAS OF I Plaintitt I CUMBERLAND COUNTY, PENNSYLVANIA I v.. I 94 - 5135 CIVIL TERM I ROBERT J. GOODRICH, JR. I LAW - DIVORCE I Detendant I AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) ot the Divorce Code was tiled on September 13, 1994. 2. The marriage ot plaintitf and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing of the Complaint. 3. I conBent to the entry of a final decree of divorce. 4. I understand that if a claim for alimony, alimony pendente lit.e, marital property or counsel fees or expenses has not been filed with the court before the entry of a final decree in divorce, the right to claim any of them will be lost. I, CYNTHIA J. GOODRICH, verify that the statements made in this Affidavit are true and correct. I understand that false statements herein made are Bubject to the penalties of 18 Pa, C.S. 14904, relating to unsworn falsification to authorities. ~ eC...."" (".,v ,~( ('t'( Y ~; g 4~:l CYN HIA J.VGOODRICH " dI; '~~ ,.. >T. ~.. . ,,' :c , 0... "" N " .,. , , ~ " " .. , ... i'_~ ,'!{ " " " , , "