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Home My WebLink About94-06368 ,~ .~ o '. ,j l ,0 \.!) t:S " ... ( ) I r , , j 00 " f"() ~ , d: . ~ , " " , , , , " 'I I', , I,;, , ,I I , " , ,,; .."l " , ., , , ',II ," ,I , " " , "I ,',' 'I , , :rl ." ,'1 , , .;" I " , I', '1. , , " , , ,1'1 q' ,.' " " " " I l \ I , " '1, , , I ~ '., , , " '\' -,.I ',f 1,'\' ;1:, " :',( ;"''', ""I' 'I'.,' I' \ ':'-~ , , " . .- ------------------~~~~~~-~--~~ 8 ~ . : IN THE COURT OF COMMON PLEAS : . OF CUMBERLAND COUNTY . . . : STATE OF ~ PENNA. I . ~ . . . . ROBERT C. de GOMAR, 11 ' . plaintif f ;: N ().~,~~~3.~~"CIY,~,~",," : . Vel'S!" . . MARTI L. de GOMAR, . . Defendant . ~ I : DECREE IN : :l 0 I V 0 R C E . : ANONOW."~!.~~"'~,.,,,,.,.19.~?,,,, it is ordered and : .' decreed that ""',~E~:.,C~,~~"~?:_',~~~.,,..,',....,.,.,",. plaintiff, i . . . and . " " , " .t-!~RTI" r,. ~ "d.e , ~~,~A~!, , " " " " " " , , . . " , " , ". 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; \IOu... · , . : .. " " .:he, S't~;ull,la:~::"a;d, ,Aq~~:,menj.' t, ,o~, ~,h,~ , p:.r.;je~, ~"~~t~.~,, ,," ' . !! . ' , , , , , n\l9\.111.t. .. " ,. u, ", ,.11, ,11E1fl!, ,y" n,C,QJ;PP,r.,II1;~,. ,y:>, ~ ~. P,E1qt:\!l~, , . . ., ~ a d e Court shall retain jurisdiction th eof: . . * ~ D y T~"V'("A 8 . , :\ . . Alle.t:.~~~ (" /~(~~ J. 18 _ ~1''''< K x;~ 4ft I" ~ - ,7 Prothonotary '10 ____ I: . - --------------------- f. 7.9,r~, (~,~~ 4 #~ f. '),k. '71~ A*i'4" ~ 4/~ . .. . -' '. .. . , . ROBERT C. de GOMAR, I IN THE COURT OF COMMON PLEAS OF Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA Vs. I CIVIL ACTION - LAW I MARTI L. de GOMAR, I NO. 94-6368 CIVIL Defendant I STIPULATION AND AGRBBMBNT or THB PARTIBS The parties hereto by this Stipulation and Agreement agree that the following provisions shall be incorporated in and made a part of any decree of divorce rendered in this cause and shall be binding upon the parties: l. Marti L. de Gomar, given the parent's living arrangements, shall have care, custody and control over the minor child of the parties, Kristin N. de Gomar, who shall reside with the wife subject to visitation with the husband set forth herein. 2. Robert C. de Gomar, shall have the right of access to and visitation with said minor child at such reasonable times and upon such terms as the parties shall mutually agree upon. 3. Robert C. de Gomar agrees to pay as child support $200.00 per month which sum is based upon and consistent with his current income, expenses and ability to pay. 4. Marti L. de Gomar shall have as her sole and separate property the 1982 Toyota Celica automobile which she now has in her possession. .. " -.' . ~ 5. The parties agree that all property belonging to the ~arties have been divided to the satisfaction of both parties and the parties hereto agree that each shall keep their personal belongings and personal property which they had prior to said marriage. 6. The parties agree that all household goods have been previously divided. 7. Except as herein provided, the parties hereby release and discharge one another from any and all other liabilities and obligations and expressly waive and release any claim of, or for, equitable distribution of property, alimony, and/or other marital right of every nature. IN WITNESS WHEREOF, the parties hereto have hereunto set " their hands and this /'8(;;l., day of {h.J~f- , 1995. '/1 . 1\ ~( . " .' /, " (,.1" '", Ro ert C. de Gomar / . ;j ] ,~ \.' I (/;.1 ,!..U7JlI/ tne99 ) WI ~~ ~.:.t:" 1ioalI~~ ~~~ 0:&:":';;11' 1-': O(J.~~ ,~. L" (:~ ....l ' I;_"""/!- ",,,,,(,1"/ I J:.I:'" \' " : ',-~~ l; I :e <>- ~ - ro") .! " :,,:;...0" " - .. ..'. . ROBERT C de GOMAR1 Plainhff IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I NO. 94-6368 CIVIL I Vs. MARTI L. de GOMAR, Defendant . . PRAECIPE TO TRANSMIT RBCORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: irretrievable breakdown under of the Divorce Code. (Strike out 1. Ground for divorce: Section (201(c))) k~k~kkk)) inapplicable section.) 2. Date and manner of service of the complaint: Certified Restricted Delivery, Return Receipt Requested cn November 15, l~94. 3. (Complete either paragraph (a) or (b).) (a) Date of execution of the Affidavit of Consent required by Section 20l(c) of the Divorce Codel by Plaintiff Auqust 31, 1995 ; by Defendant Auqust 18, 1995 (b)(l) Date of execution of the Plaintiff's Affidavit required by Section 20l(d) of the Divorce Code: N/A ; (2) Date of service of the Plaintiff's Affidavit upon the Defendant: NiA 4. Related claims pending: None 5. Date file praecipe the decree is Divorce Code. and manner of service of the notice of intention to to transmit record, a copy of which is attached, if to be entered under Section 20l(d)(1)(i) of the N/A Date: August 31, 1995 ,'I' . . .. ROBERT C. de GOMAR, Plaintiff IN THE COURT OF COMMON PLEAS or CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW VS. MARTI L. de GOMAR, Defendant NO. 94- W 3"rs- IN DIVORCE CIVIL COMPLAINT UNDER SBCTIONS 3301(A AND 3301 C or THE DIVORCB CODB COMES NOW, the Plaintiff, by Edward W. Harker, his Attorney And respectfully represents as follows: l. The Plaintiff, ROBERT C. de GOMAR, currently resides at 1125 Columbus Avenue, Apartment A5, Lemoyne, Cumberland County, Pennsylvania l7043, since August 31, 1993. 2. The Defendant is MARTI L. de GOMAR, who currently resides at l04 North Jones Street, Enterprise, Coffee County, Alabama, 36330, since October 8, 1994. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 13, 1993, in Camp Hill, Cumberland County, Pennsylvania. 5. Ther.e has not been a prior act.ions of divorce or annul- ments between the parties. COUNT I 6. The marriage is irretrievably broken. '1' ..,... ~j ~ ~ . "',,1.. .... or::: ~ . ;;r ,..", ~ ".. "'I' OJ -3 ~ ~ I '"( .). (';;, \t1 - :~ ~ I.) ~ 1\, -~ to- ~- ... ~ ~ 4ft l ~ ! 1M ~ ~ ! ,~li ~Il" i~Ai '. . . IlXHIBIT "A" .",. en >~ >- ~ ~J. " " = '" I ""~ " r_'. , . .... <::> , I ,~;r , " , .1-: f..:l , >,:\, c.. ;-)' ,~ '.,' , , " , ROBERT C. de GOMAR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN DIVORCE CIVIL ACTION - LAW NO. 94-6368 IN DIVORCE I I I Vs. MARTI L. de GOMAR, Defendant APPIDAVIT OP CONSBNT l. A Complaint in divorce under Section 330l(C) of the Divorce Code was filed on November 9, 1994. ~~ The marriage of Plaintiff and Defendant is irretrievably broke~~nd ninety days have elapsed from the date of filing of the COlJlplaint. 3, I consent to the entry of a final decree of divorce. 'i'~ 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. 5. I do not wish to request marriage counseling. 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. t\,c 1\ (C Dated: '~\I~".'\ .) ,~'\I') l j.JJ-..' I \ {CT ( "e./~}.." - Ro ert C. de Gomar, Plaintiff Sworn to and subscribed before me this\\'~\ day of ~\.\'-\'-\"''''I. 1995. , .-:-) .-(, ",'1: \;..',.\.\...' \1 \ 'l'-u\'L' 1._ Notary PUblic ...... ......'_,IOWW MUC .... _, elf" T1f'l.._. M .. "'''10' IllN. ......14, _ , t , " 'I' tA :II:' ~ ~ .... ~... .. '" ""',"J'.:,"!" U:at.:..,.r ~O""" I' '-O.'-~ ,,".) j~' .r.' I "i, ~;, . ,,_' Jr .,~I:r. ,llL.l , 'z.'''- '.;) ~~ - - ...., Jf ROBERT C. de GOMAR, Plaintiff I I I IN THE COUR~ OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IN DIVORCE CIVIL ACTION - LAW NO. 94-6368 IN DIVORCE Vs. MARTI L. de GOMAR, Defendant : AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 330l(C) of the Divorce Code was filed on November 9, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 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 do not wish to request marriage counseling. ., ~..' 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. Dated: " I / Ii elf ('It'd fll}_) ~ Gomar, Defendant Sworn to and subscribed before me this /;;,,, day of ,1,,,v.,r 1995. ,\1 , , .....-. .., ",,) , ,~ I, 'J" " ,', , . LA !: ~ ...... ... .. ...", 1>-..;.., ....".1.; ..., U <ok 'c..... t;:.' II? Co'::: h.. 'r:.b . l'~ "".Y ..;.' "lfJ ~ T ;. J' ,. , , - - ...., , I'~ ,., , C, It. '.;\ '..' Jf I, , \;. DEe 1 9 ~ ROBERT C. de GOMAR, . IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLANO COUNTY, PENNSYLVANIA . vs. CIVIL ACTION - LAW . MARTI L. de GOMAR, NO. 94-6368 CIVIL Defendant . IN DIVORCE . ANSWER TO COMPLAINT FOR DIVORCE , The Defendant, Marti L. de Gomar, appears personally and through her attorney, Richard (Cracker) Waldrop, a practicing sttorney in the State of Alabama, and files this her answer as fo11oll/s: 1. She admits the allegations of paragraph one. 2. She admits the allegations of paragraph tll/o. 3. ~he admits the allegations of paragraph three. 4. She admits the allegations of paragraph four. 5. She does not admit or deny the allegations of paregraph five. 6. She denies the allegations of paragraph six. 7. She does not admit or deny allegations of paragrsph seven. 8. She denies allegations of paragraph nine. 9. She denies allegations of paragraph ten. Defendant denies any and all other material allegations of the Plaintiff's Complaint and demands strict proof thereof. This is the ~day of December, 1994. BY: , Richa d Attorney for Defendant p. O. Box 27 Enterprise, AL 36331 (205) 393-2288 \,i,., .1'_ . \' CERTIFICATE OF SERVICE I. Richard (Cracker) Waldrop, do hereby certify that I have this day msiled a copy of the fOfegoing Answer to Complaint for Oi~orc., postage prepaid and properly addressed. to Edward W. Harker, Esquire, Supreme Court 1.0. 06362, Attorney for Plaintiff, at his office address of One West High Streat, Carlisle, PA 17013. This is the 11 'ft day of Decembar, 19 .,r " "'~ ,t-:r I - -, '. " ~ , " " , L .r ....t " ".l '" M 'I' 'I 'j~ : , , """'1 .. ~ I; ~ Ii \".. .L " .... ~ ~, ,.. ,.' = , " . I