HomeMy WebLinkAbout08-7335• A.
JENNIFER A. HONEYSETT, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO.
GEOFFREY S. HONEYSETT,
Defendant IN DIVORCE
NOTICE TO DEFEND
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 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 York County Court House, Carlisle,. Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 Street
Carlisle, PA 17013
(717) 249-3166 or 800-990-9108
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FLOWER WERR &
LINDSAY
AT•Kti'•UW
26 West High Street
Carlisle, PA
SAID
J
Attorn Id. 44,093
26 Wes igh Street
Carlisle, PA 17013
(717) 243-6222
Counsel for Plaintiff
uire
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J&
JENNIFER A. HONEYSETT,
Plaintiff
V.
GEOFFREY S. HONEYSETT,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE UNDER
SECTION 3301(c) or (d) OF THE DIVORCE CODE
1. The Plaintiff is Jennifer A. Honeysett, an adult individual, residing at 5805
Heatherwood Court, Enola, PA 17025.
2. The Defendant is Geoffrey S. Honeysett, an adult individual, residing at 1014
Kent Drive, Mechanicsburg, PA 17050.
3. The Plaintiff and Defendant both have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on July 8, 2000 in Enola,
Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
FLOWER &
LINDSAY
26 West High Street
Carlisle, PA
parties in this or in any other jurisdiction.
6. The Plaintiff has been advised that counseling is available and that she has
the right to request that the court require the parties to participate in counseling.
7. The marriage is irretrievably broken.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 0 S• 7336 e4,- <l 1.2..-.
WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance
with §3301 of the Pennsylvania Divorce Code.
SAIDIS, FLQWER &
Carol I Linds EE
Attorney Id. 693
26 West Hig Stre
Carlisle, PA 1 13
(717) 243-6222
Counsel for Plaintiff
FLOWER ?
LINDSAY
AMEW90 =LAW
26 West High Street
Carlisle, PA
VERIFICATION
I verify that the statements made in the foregoing document are true and correct. I
FLOWER &
LIlVDSAY
26 West High Street
Carlisle, PA
understand that false statements herein are made subject to the penalties of 18 Pa. C.S.
§4904, relating to unsworn falsifications to authorities.
Date: _CO NSW ?2,, &03?
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JENNIFER A. HONEYSETT, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO. (1 7,335
GEOFFREY S. HONEYSETT,
Defendant IN DIVORCE
ACCEPTANCE OF SERVICE
I, Geoffrey S. Honeysett, accept service of the Complaint in the above-captioned
SAIDIS,
FLOWER &
LINDSAY
26 West High Street
Carlisle, PA
matter.
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Date
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PROPERTY SETTLEMENT AND SEPARATION AGREEMENT
THIS AGREEMENT made this S day of NCtM. brpri 2008,
between JENNIFER A. HONEYSETT, of 5805 Heatherwood Court, Enola, Cumberland County,
Pennsylvania 17025, hereinafter referred to as Wife, and GEOFFREY S. HONEYSETT, of
1014 Kent Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050, hereinafter
referred to as Husband.
RECITALS:
R.1: The parties hereto are husband and wife, having been joined in marriage on July 8,
2000 in Enola, Cumberland County, Pennsylvania; and
R.2: The parties hereto desire to settle fully and finally their respective financial and
property rights and obligations including, but not limited to, all matters between them relating to
the ownership of real and personal property, claims for spousal support, alimony, alimony
pendente lite.
R.3: The parties also desire to settle their issues of custody of their minor children,
Kayla M. Honeysett, born March 31, 2003 and Lauren E. Honeysett, born February 15, 2006,
counsel fees and costs, and the settling of any and all claims and possible claims against the
other or against their respective estates.
NOW THEREFORE, in consideration of the covenants and promises hereinafter to be
mutually kept and performed by each party, as well as for other good and valuable consideration
and intending to be legally bound, it is agreed as follows:
(1) SEPARATION: It shall be lawful for each party at all times hereafter to live
separate and apart from the other party at such place or places as he or she from time to time
may choose or deem fit, free from any control, restraint or interference from the other. Neither
1
party will molest the other or endeavor to compel the other to cohabit or dwell with him or her by
any legal or other proceeding. Each party shall be free of the interference, authority or contact by
the other as if he or she was single and unmarried except as maybe necessary to carry out the
terms of this agreement.
(2) DIVORCE: The parties acknowledge that the marriage is irretrievably broken and
that they will secure a mutual consent no-fault divorce decree in the above-captioned divorce
action. Wife will file a Complaint in Divorce and Husband will accept service of the Complaint.
Ninety days thereafter, the parties will sign Affidavits of Consent and Waiver of Notice Forms,
necessary to finalize the divorce and Wife will transmit the record so that the Decree in Divorce
can be entered.
(3) REAL PROPERTY: The parties are the owners of certain real estate with
improvements thereon erected and known and numbered as 5805 Heatherwood Court, Enola,
Pennsylvania 17025. Wife has refinanced the marital home so that Husband is no longer liable
thereon. Husband has executed a special warranty deed transferring to Wife all his right, title and
interest in the marital home and tendered the Deed to Wife.
Wife shall pay for all household expenses including, but not limited to, mortgages and
liens of record, utility bills, insurance and real estate taxes in connection with said property. With
regard to all such expenses, Wife hereby shall hold Husband harmless and indemnifies him from
any loss thereon.
(4) DEBT:
A. Marital Debt: Husband and Wife acknowledge and agree that there are no
outstanding debts and obligations which are marital or for which the other might be liable
incurred prior to the signing of this Agreement. At the time of the parties' separation in May
2008, any credit card obligations were paid from the balances in the parties' joint checking
account.
2
B: Post Separation Debt: In the event that either party contracted or incurred any
debt since the date of separation on May 28, 2008, the party who incurred said debt shall be
responsible for the payment thereof regardless of the name in which the debt may have been
incurred.
C: Future Debt: From the date of this agreement neither party shall contract or incur
any debt or liability for which the other party or his or her property or estate might be responsible
and shall indemnify and save the other party harmless from any and all claims or demands made
against him or her by reason of debts or obligations incurred by the other party.
(5) MOTOR VEHICLES: Each party relinquishes any right, title and interest he or she
may have to any and all motor vehicles currently in possession of the other party. Husband has
transferred to Wife all his right, title and interest in the 2003 Ford Explorer which shall be Wife's
sole and separate property. Husband has retained a Honda Accord which he leases in his own
name. Wife shall have no obligation for the lease on Husband's Honda Accord. With regard to
the vehicles, the parties will indemnify and hold the other party harmless against any loss
attributable to the vehicle he or she is retaining.
(6) TANGIBLE PERSONAL PROPERTY: The parties hereto mutually agree that they
have effected a satisfactory division of the furniture, household furnishings, appliances, tools and
other household personal property between them, and they mutually agree that each party shall
from and after the date hereof be the sole and separate owner of all such property presently in his
or her possession whether said property was heretofore owned jointly or individually by the parties
hereto. This Agreement shall have the effect of an assignment or bill of sale from each party to
the other for such property as may be in the individual possession of each of the parties hereto.
(7) INTANGIBLE PERSONAL PROPERTY: Each party hereby relinquishes any right,
title or interest he or she may have in or to any intangible personal property currently titled in the
name of or in the possession of the other party, including, but not limited to, stocks, bonds,
3
insurance, bank accounts, individual retirement accounts, employment benefits including
retirement accounts, savings plans, pension plans, stock plans, 401 K plans and the like.
Within five days of the entry of a Decree in Divorce, Wife will pay to Husband $31,500.00
in cash or cashier's check. The amount owed by Wife to Husband takes into account the parties'
calculation of the equity in the marital home, their joint PNC checking account, and joint PNC
investment account as well as certain personal property retained by Wife, but the value of which
the parties have agreed to equally divide. The parties agree that they will close their joint
checking account and that once the payment of $31,500.00 is made by Wife to Husband, the
Smith Barney account shall be equally divided as well. If there are tax consequences attendant
upon the division, the parties will report on their respective Federal and state income tax returns
one-half of the capital gain or loss.
(8) CUSTODY OF CHILDREN: The parties agree that legal custody of their minor
children, Kayla M. Honeysett, born March 31, 2003 and Lauren E. Honeysett, born February 15,
2006, shall be joint, with both parties having the right to make major parenting decisions affecting
the children's health, education and welfare and with each having the right to obtain information
regarding the children from schools, healthcare providers and the like.
Wife shall have primary physical custody of the children subject to partial custody in
Husband at times as the parties can agree. The parties commit themselves to ensuring that they
do nothing which interferes with the love and respect the children have for the other parent and
that they will actively promote that relationship as they have heretofore and as they have agreed.
(9) CHILD SUPPORT: Husband shall pay to Wife for the use, benefit, support and
maintenance of their minor children, the sum of One Thousand Five Hundred and 00/100
($1,500.00) Dollars per month which payment shall be made in two equal installments due the first
(1st) and fifteenth (15th) day of each month. Husband shall provide health insurance (including
medical, vision and dental coverage), major medical or equivalent coverage for the benefit of the
4
minor children so long as he is obligated to contribute to their support and as long as it is available
to him through his employment. The parties shall equally share medical and/or dental expenses
unreimbursed by insurance. The parties agree to recalculate the amount of child support owed on
an annual basis and will provide their Federal income tax returns to each other on or about May
15 of each year and will, on September 1 of each year, recalculate the amount of support as set
out in the Pennsylvania Support Guidelines. In the event that there is a substantial change in
circumstances, the parties agree that they may immediately recalculate the amount of child
support owed.
Husband will reimburse Wife for 50% of the cost of out of pocket extracurricular activity
expense such as dance class, swim lessons, music lessons, sports and the like. Such costs shall
include registration fees, uniforms, necessary equipment and other mutually agreed upon costs
related to the children's participation in a given sport or activity.
(10) EDUCATIONAL SUPPORT: The parties agree that they will equally divide the
cost of tuition, room, board, books and other related costs for the post-secondary education of
their children after the application of any financial aid in the form of grants to which the children
may be entitled.
(11) WAIVER OF ALIMONY: The parties acknowledge that each has income and
assets satisfactory to his and her own reasonable needs. Each party waives any claim he or
she may have one against the other for alimony, spousal support or alimony and alimony
pendente lite. Nevertheless, Husband will maintain medical and dental coverage for Wife until
December 31, 2008, at which time Wife will provide her own medical and dental coverage.
(12) ADVICE OF COUNSEL: The parties hereto acknowledge that each has been
notified of his or her right to consult with counsel of his or her choice, and have been provided a
copy of this agreement with which to consult with counsel. Wife is represented by Carol J.
Lindsay, Esquire and Husband has been advised that he or she may be represented by counsel
5
of choice. Each party acknowledges and accepts that this agreement is, under the circumstances,
fair and equitable, and that it is being entered into freely and voluntarily after having received such
advice and with such knowledge as each has sought from counsel, and the execution of this
agreement is not the result of any duress or undue influence, and that it is not the result of any
improper or illegal agreement or agreements. Wife's counsel shall prepare a Complaint in Divorce
and process the divorce to obtain the Decree. She shall also prepare the Marital Settlement
Agreement. The parties have agreed to equally share the cost for Wife's counsel to perform
these duties and the filing fees charged by the Court for the divorce, leaving Wife alone the
obligation to pay her counsel for any other advice or consultation. By September 30, 2008,
Husband will provide Wife an advance of $500.00 on account of costs for document preparation
and processing as set out herein. In the event that the cost charged by Wife's attorney does
not equal $1,000.00 or more, Wife will refund a proportionate share of Husband's payment to him
within thirty (30) days of the entry of the Decree in Divorce.
(13) ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the other party any and all further
instruments that may be reasonably required to give full force and effect to the provisions of this
Agreement.
(14) INCOME TAX: The parties have heretofore filed joint Federal and State Tax
returns. Both parties agree that in the event any deficiency in Federal, state or local income tax is
proposed, or assessment of any such tax is made against either of them, each will indemnify and
hold harmless the other from and against any loss or liability for any such tax deficiency or
assessment and any interest, penalty and expense incurred in connection therewith. Such tax,
interest, penalty or expense shall be paid solely and entirely by the individual who is finally
determined to be the cause of the misrepresentations or failures to disclose the nature and extent
of his or her separate income on the aforesaid joint returns.
6
(15) BANKRUPTCY: The parties hereby agree that the provisions of this Agreement
shall not be dischargeable in Bankruptcy and expressly agree to reaffirm any and all obligations
contained herein. In the event a party files such bankruptcy and pursuant thereto obtains a
discharge of any obligations assumed hereunder, the other party shall have the right to declare
this Agreement to be null and void and to terminate this Agreement in which event the division of
the parties' marital assets and all other rights determined by this Agreement including alimony
shall be subject to court determination the same as if this Agreement had never been entered
into.
(16) COMPLETE DISCLOSURE: The parties do hereby warrant, represent,
acknowledge and agree that each is fully and completely informed of, and is familiar with, the
wealth, real and personal property, estate and assets, earnings and income of the other and has
made any inquiry he or she desires into the income or estate of the other and received any such
information requested. Each has made a full and complete disclosure to the other of his and her
entire assets, liabilities, income and expenses and any further enumeration or statement thereof in
this Agreement is specifically waived.
(17) RIGHTS AND RESPONSIBILITIES: Husband and Wife acknowledge that each of
them has read and understand his and her rights and responsibilities under this Agreement and
that they have executed this Agreement under no compulsion to do so but as a voluntary act.
(18) FULL SETTLEMENT: Except as herein otherwise provided, each party hereby
releases the other from any and all claims, or demands up to the date of execution hereof. It is
further specifically understood and agreed by and between the parties hereto that each party
accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all
of said party's rights against the other for past, present and future claims on account of support,
maintenance, alimony, alimony pendente life, counsel fees, costs and expenses, equitable
distribution of marital property and any other claims of the party, including all claims which have
7
been raised or may be raised in an action for divorce.
(19) RELEASE OF ALL CLAIMS: Except as may be otherwise specifically provided in
this Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each
hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs,
representatives, assigns and estate, from and with respect to the following:
A. All liability, claims, causes of action, damages, costs, contributions and
expenses or demands whatsoever in law or in equity;
B. All rights, title, interest or claims in or to any property of the other, whether
real, personal or mixed and whether now owned or hereafter acquired;
C. All rights of courtesy and dower and all claims or rights in the nature of
courtesy and dower;
D. All widow or widower's rights;
E. All right, title, interest or claim in or to the other's estate, whether now
owned or hereafter acquired, including but not limited to all rights or claims:
(1) to take against the other's will;
(2) under the laws of intestacy;
(3) to a family exemption or similar allowance;
and
(4) all other rights or authority to participate or intervene in a deceased
spouse's estate in any way, whether arising under the laws of Pennsylvania or any
other country, territory, state or political subdivision.
F. All rights or claims to any accounting;
G. All rights, claims, demands, liabilities and obligations arising out of or in
connection with the marital relationship or the joint ownership of property, whether real, personal
or mixed;
8
H. All rights, claims, demands, liabilities and obligations arising under the
provisions of the Pennsylvania Divorce Code, as the same may be amended from time to time,
and under the provisions of any similar statute enacted by any other country, state, territory or
political subdivision;
1. All rights, claims, demands, liabilities and obligations each party now has, or
may hereafter have, against or with respect to the other.
(20) GOVERNING LAW: This Agreement shall be construed under the law of the
Commonwealth of Pennsylvania. If any provision of this Agreement is determined to be invalid or
unenforceable, all other provisions shall continue in full force and effect.
(21) INCORPORATION INTO DECREE: In the event that either of the parties shall
recover a final judgment or decree of absolute divorce against the other in a court of competent
jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance
but shall not be merged into such judgment or decree and this Agreement shall survive any such
final judgment or decree of absolute divorce and shall be entirely independent thereof.
(22) BREACH: In the event that either party breaches any provision of this Agreement,
he or she shall be responsible for any and all costs incurred to enforce the Agreement, including,
but not limited to, court cost and counsel fees of the other party. In the event of breach, the other
party shall have the right, at his or her election; to sue for damages for such breach or to seek
such other and additional remedies as may be available to him or her.
(23) ENTIRE UNDERSTANDING: This Agreement constitutes the entire understanding
between the parties and there are no covenants, conditions, representations, or agreements, oral
or written, of any nature whatsoever, other than those herein contained.
(24) AGREEMENT BINDING ON PARTIES AND HEIRS: This Agreement shall bind
the parties hereto, their respective heirs, executors and assigns.
9
IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto
set their hands and seals the day and year first written above.
WITNESS:
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Geo oneyse
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF D6wfohi q
: ss
On this, the g day of NGP-W\ber , 2008, before me, the undersigned
officer personally appeared JENNIFER HONEYSETT, known to me (or satisfactorily proven) to
be the person whose name is subscribed to the within instrument, and acknowledged that she
executed the same for the purposes therein contained.
In Witness Whereof, I have hereunto set my hand and official seal.
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title of Officer
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COMMONWEALTH OF PENNSYLVANIA lxvw+r??D
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COUNTY
OF "On this, the 1b day of Povehk" , 2008, before me, the undersigned
officer personally appeared GEOFFREY HONEYSETT, known to me (or satisfactorily proven)
to be the person whose name is subscribed to the within instrument, and acknowledged that he
executed the same for the purposes therein contained.
In Witness Whereof, I have hereunto set my hand and official seal.
(SEAL)
Title of G r ly /(C
10 COMMONWEAU h OF PENNSYLVANIA
NOTARIAL SEAL
CHERYL R. GARMAN, Notary Public
Camp HIM Boro, Cumberland County
My Coy emission Expires May 20, 2012
OF lKr-
2849 APR { 7 H 3: 13
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JENNIFER A. HONEYSETT,
Plaintiff
V.
GEOFFREY S. HONEYSETT,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 08-7335 CIVIL TERM
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on
December 17, 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. 1 consent to the entry of a final Decree in 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 to the best of
my knowledge, information and belief. 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: 4 sm??
e A. Hone sett
PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDERb 3301 (c) OF THE DIVORCE CODE
I consent to the entry of a final Decree of Divorce without notice.
IRIS &
LIlVDSAY
.W
26 West High Street
Carlisle, PA
2. 1 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. 1 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 to the best of
my knowledge, information and belief. 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:
J ni r A. Hon ys tt
FILED-Gt"ciCE
OF THE M-03-11,C)NOTARY
2004 APR 17 PM 3: 12
U "UN Y
JENNIFER A. HONEYSETT,
Plaintiff
V.
GEOFFREY S. HONEYSETT,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 08-7335 CIVIL TERM
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on
December 17, 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. 1 consent to the entry of a final Decree in 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 to the best of
my knowledge, information and belief. I understand that false statements herein are made
subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities.
A
Date:
Ge ey S. Hone ,,?
DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A
DIVORCE DECREE UNDER4 3301 (c) OF THE DIVORCE CODE
I consent to the entry of a final Decree of Divorce without notice.
IRIS &
LINDSAY
26 West High Street
Carlisle, PA
2. 1 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. 1 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 to the best of
my knowledge, information and belief. 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: r lo 1
Geo S: H Re set .__
FILED-D? TICE
OF THE °^'-)T'-?r,";JTAPY
2009 APR 17 PH 3* 12
CUPv ' iY
_'.IAR?I \
SAIDIS,
FLOWER &
LINDSAY
26 West High Street
Carlisle, PA
JENNIFER A. HONEYSETT,
Plaintiff
V.
GEOFFREY S. HONEYSETT,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 08-7335 CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Kindly transmit the record, together with the following information, to the Court for
entry of a Decree in Divorce:
1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the
Divorce Code.
2. Date and manner of service of the Complaint: Defendant accepted service of
the Complaint on December 17, 2008. An Acceptance of Service was filed with the Court on
December 22, 2008.
3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code
was signed:
By Plaintiff: April 13, 2009
contemporaneously herewith.
By Defendant: April 9, 2009
contemporaneously herewith.
and filed with the Prothonotary
and filed with the Prothonotary
4. Related claims pending: The terms of the Property Settlement and Separation
Agreement dated xxx are incorporated, but not merged, into the Decree in Divorce.
5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was signed:
By Plaintiff: April 13, 2009 and filed with the Prothonotary
contemporaneously herewith.
By Defendant: April 9, 2009 and filed with the Prothonotary
contemporaneously herewith.
SAIDIS, FLOWER 8,.KNDSAY
Carol J. Lin ay Esquire -
Supreme C D No. 44693
26 West High Street
Carlisle, PA 17013
717-243-6222
Attorney for Plaintiff
FILED-jau FICE
OF THE PP0TH-^?V!AARY
2DO9 APR 1 ? € H 3'. 12
rep; , .. -.
Jennifer A. Honeysett
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
Geoffrey S. Honeysett
NO. 08-7335
DIVORCE DECREE
AND NOW, it is ordered and decreed that
Jennifer A. Honeysett , plaintiff, and
Geoffrey S. Honeysett , 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.")
The terms of the attached Marital Settlement Agreement, dated December 8,
2008, are incorporated, but not merged, into this Decree in Divorce.
Prothonotary
Attest: J.
??a. ate..
`11?,
J THE P 07HQ11OTAit',
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY orill ��VANIIAiti 2•
CIVIL DIVISION CUMBERLAND COUNTY
PENNSYLVANIA
JENNIFER A. HONEYSETT
Plaintiff : File No. 08-7335
vs.
IN DIVORCE
GEOFFREY S. HONEYSETT •
Defendant
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff/Defendant in the above matter,
(select one by marking"X").
prior to the entry of a Final Decree in Divorce,
or X after the entry of a Final Decree in Divorce dated 4/21/09 , hereby elects to resume
the prior surname of JENNIFER A. ESSER ,and gives this written notice avowing
his/her intention pursuant to the provisions of 54 P.S. §704.
Date: `d- t3
Ai £' A.
Signature
6L( / A .
$,nature of name being resumed
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DA...1 W
On the � day of 'b2t.2.vl/l1'}t , 0-013 , before me, the
Prothonotary or a Notary Public, personally appeared the 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 an official seal.
i)./(4y
Prothonotary or Notary Public
Commonwealth of Pennsylvania
NOTARIAL SEAL
PAMELA PRICE,NOTARY PUBLIC a'3'
City of Harrisburg,Dauphin County ^
My Commission Expires May 25,2014 (�
Ct,4.1P3151
1