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Home My WebLink About08-7191 STEPHANIE E. CHERTOK, ESQUIRE PA Supreme Court ID: 52651 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 Attorneys for Plaintiff KAREN E. GEYER Plaintiff JACOB E. GEYER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA D8 - 7141 Civo Tem CIVIL ACTION - LAW IN DIVORCE NOTICE To DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case 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 for 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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. Cumberland County Bar Association 32 South Bedford St. Carlisle, PA 17013 (717) 249-3166 OR (800) 990-9108 STEPHANIE E. CHERTOK, ESQUIRE PA Supreme Court ID: 52651 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 Attorneys for Plaintiff KAREN E. GEYER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. JACOB E. GEYER Defendant No.: D F- '? / q' Otd T2? CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER & 3301 (c) OF THE DIVORCE CODE 1. Plaintiff is Karen E. Geyer, who currently resides at 583 F Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Jacob E. Geyer, who currently resides at 583 F Street, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 2, 2004 at Grace United Methodist Church, Carlisle, Cumberland County, Pennsylvania. 6. Plaintiff and Defendant have been separated since October 7, 2008. 7. There have been no prior actions for divorce or for annulment between the parties. 2 8. Divorce is sought pursuant to the provisions of the Divorce Code, §§ 3301(c), in that: a) The marriage is irretrievably broken; 9. 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 such counseling. 10. Neither Plaintiff nor Defendant in this action are a member of the Armed forces. 11. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. Respectfully submitted, %7 Step a ie E. Chertok, Esq. Attorney I.D. No. 52651 61 West Louther St. Carlisle, PA 17013 (717) 249-1177 Attorney for Plaintiff 3 VERIFICATION I, Karen E. Geyer, verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904 relating to unsworn falsification to authorities. Date: ?? V u Ker 4 STEPHANIE E. CHERTOK, ESQUIRE PA Supreme Court ID: 52651 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 Attorneys for Plaintiff KAREN E. GEYER Plaintiff V. JACOB E. GEYER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.. CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Stephanie E. Chertok, Esq., counsel for Plaintiff, hereby certify that a copy of the Complaint for Divorce, directed to Defendant, was served upon Defendant at Defendant's residence, 583 F Street, Carlisle, Pennsylvania 17013, this day of 2008, by first-class mail, postage prepaid, and certified mail, return receipt requested, pursuant to Pa. C.R.P. 1930.4(c). /"Ste anie E. Chertok, Esq. Attorney I.D. No. 52651 61 West Louther St. Carlisle, PA 17013 (717) 249-1177 Attorney for Plaintiff 5 C-_ C= R Uj Fli C-) ni'J 00 ,_? rh C_? ?Y C3 STEPHANIE E. CHERTOK, ESQUIRE PA Supreme Court ID: 52651 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 Attorney for Plaintiff KAREN E. GEYER Plaintiff V. JACOB E. GEYER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.: 08-7191 CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on December 9, 2008, and served on December 9, 2008. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Waiver of Intention to Request Entry of the decree. 4. I acknowledge that the marital settlement agreement, signed by both parties on March a <, 2009, remains binding and is incorporated herein, but shall not merge in a 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: Karen E. Geyer 1 7 -7 3 D t a. A STEPHANIE E. CHERTOK, ESQUIRE PA Supreme Court ID: 52651 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 for Plaintiff KAREN E. GEYER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. JACOB E. GEYER Defendant No.: 08-7191 CIVIL ACTION - LAW IN DIVORCE 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. § 4904 relating to unsworn falsification to authorities. Dated: ?Q50- Kar n E. Geyer r C, STEPHANIE E. CHERTOK, ESQUIRE PA Supreme Court ID: 52651 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 Attorney for Plaintiff KAREN E. GEYER Plaintiff V. JACOB E. GEYER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.: 08-7191 CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT A complaint in divorce under § 3301(c) of the Divorce Code was filed on December 9, 2008, and served on December 9, 2008. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Waiver of Intention to Request Entry of the decree. 4. I acknowledge that the marital settlement agreement, signed by both parties on March A 6' , 2009, remains binding and is incorporated herein, but shall not merge in a 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: - Zs d cob E. Geyer _ ?_ ?' -TI j STEPHANIE E. CHERTOK, ESQUIRE PA Supreme Court ID: 52651 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 Attorney for Plaintiff KAREN E. GEYER Plaintiff V. JACOB E. GEYER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.: 08-7191 CIVIL ACTION - LAW IN DIVORCE 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. § 4904 relating to unsworn falsification to authorities. Dated: 3 2s D J cob E. Geyer __ ? ?7 fis,? ?"? ; r f.r r , 'y ?; _ ?ry •?? ?;: Okla STEPHANIE E. CHERTOK, ESQUIRE PA Supreme Court ID: 52651 61 West Louther Street Carlisle, PA 17013 (717) 249-1177 Attorney for Plaintiff KAREN E. GEYER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. JACOB E. GEYER Defendant No.: 08-7191 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Stephanie E. Chertok, Esq., counsel for Plaintiff, hereby certify that a copy of the Complaint for Divorce, directed to Defendant, Jacob E. Geyer, was served upon Defendant at Defendant's residence, 583 F Street, Carlisle, Pennsylvania 17013, on the t Vh day of December, 2008, by first-class mail, postage prepaid, and certified mail, return receipt requested, pursuant to Pa. C.R.P. 1930.4(c). Attached is documentation evidencing service. Date: o?b a Stephanie E. Chertok, Esquire Attorney I.D. No. 52651 61 West Louther St. Carlisle, PA 17013 (717) 249-1177 Attorney for Plaintiff ,R ?TlPiFn I, ,'I i` - V i n e RIA11 G p .. ti ..a Wmm m a 10.54 0013 Cr Postage $ ?n M C3 Certified Fee Return Receipt Fee 12.70 12 20 09 C3 (Endorsement Required) . 0 p Restricled Delivery F e d) 0 E j La ( ntRequirred j . Q 9 M co Total Postage & Fees $ $5.49 1,'1J?9/2 CO ? CO O C3 N Si P V4,-)o(3 ¦ hams 1. 2. said & Also corrode ¦ add on the reverse so can return the card to you. ¦ Attach card to the back of the mailpiece, or on the front If space permits. 1. Article Addivesead to. F . SA . (,isle r PA 1-101"5 A. Slmbn x _ ! '' C] Aged B. by ( r?s) C. Date f Delivery 01cd? GG sr- f Z /17 D. Is deNrery address different from Rem 1? Yes If YES, enter delivery address below: 0 No TA* owned Mau 0 Express Mau 0 Replstered O Ream Receipt for Meech ndlee 0 Insured Mau 0 C.O.D. 4. Restricted Dauvery? (2:5me Fee) 0 2. ArWeNimber 7008 1830 0003 5941 3620 v??fia+'?erv?lo. r? PS Form 3811, Fetxvary 2004 Domestic Return Receipt 102595.02-WIS40 R*WO *%0 lq6w- *-Apo rv ? ..7Z C;r"l ti r KAREN E. GEYER Plaintiff V. JACOB E. GEYER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No.: 08-7191 CIVIL ACTION - LAW IN DIVORCE To the Prothonotary: PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under § (3301 (c)) E9 9 0 i (d) {i* of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the complaint: December 9, 2008 by Certified and Regular mail. 3. Complete either paragraph (a) or (b). a. Date of execution of the affidavit of consent required by §3301(c) of the Divorce Code: by plaintiff March , '5 2009; by defendant March ;K 2009. b. (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent. 4. Related claims pending: N/A 5. Complete either (a) or (b). a. Date and manner of service of the notice of intention to file Praecipe to transmit record, a copy of which is attached: b. Date plaintiff's Waiver of Notice was filed with the prothonotary: MarchA4, 2009. Date defendant's Waiver of Notice was filed with the prothonotary: March4, 2009. ttorny for Plaintiff ?J t,? ?,,. :,= 3 1,..? ?a "?°7 ?? ?`? 're?? ?-°' _ . fy.}"; .. ? J iwJ R,? ?'w ? /':' 1 ` ? KAREN E. GEYER V. JACOB E. GEYER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-7191 DIVORCE DECREE ?1: X104 •M • /?? I or AND NOW, M90, 9 3t , 9 O , it is ordered and decreed that KAREN E. GEYER plaintiff, and JACOB E. GEYER , 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.") N0NF .. 1. "-s M 7rothonotary Attest: J. J i , Dq Ata&w b