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HomeMy WebLinkAbout09-1924 IN THE COURT OF COMMON PLEAS OF CUMBELAND COUNTY, PENNSYLVANIA HEATHER GEYER, :CASE NO. 0~ - Iqc'~~ Civil TprrK v. _ MATTHEW GEYER, :CIVIL ACTION -LAW Defendant : IN DIVORCE NOTICE TO DEFENDAl'~'.t' You have been sued in Court. If you wish to def~H~ 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 in divorce or annulment nay 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 Defendant. You may lose money or property ar other rights important to you, including custody or visitation of your children. When the grounds 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 at the Prothonotary at the Cumberland County Courthouse, Caxlisle, Pennsylvania 17013. 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. Cumberland County Baz Association 32 South Bedford Street Cazlisle, PA 17013 1-800-990-9108 /~ S err D. Coover, Esquire ttorney ID 93285 44 S. Hanover Street Cazlisle, PA 17013 AMERICANS WITH DISABILITIES AS OF 1990 The Court of Common Pleas of Dauphin 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 the office of the Dauphin County Court Administrator, Dauphin County Courthouse, Front & Market Struts, Harrisburg, Pennsylvania. All arrangements must be tliade at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled ~on~ePence or hearing. J. IN THE COURT OF COMMON PLEAS OF CUMBELAND COUNTY, PENNSYLVANIA HEATHER GEYER, :CASE NO. V. MATTHEW GEYER, :CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT IN ~ '~'VORCE 1. Plaintiff is Heather Gey~t who currently resides at 8596 Elliotts Run Road, Three Springs, PA 17264. 2. Defendant is Matthew Geyer who currently resides at 82 S,.M.E., Shippensburg, PA 17257. 3. Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately preceding the filing of this Complaint. 4. Plaintiff and Defendant were mazried on August 11, 2007. 5. There have been no prior actions commenced for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. Plaintiff has been advised of counseling and that she may have the right to request the Court to require the parties to participate in counseling. 7. Plaintiff requests the Court to enter a decree of divorce. CO T1 3301(c l IRRETRIEVABLE BREAKDOWN 8. Pazagraphs 1 through 7 aze incorporated herein by rrence in their entirety. 9. The marriage is irretrievably broken and the parties are estranged due to marital difficulties with no reasonable expectation of reconciliation. WHEREFORE, Plaintiff prays this Honorable Court to issue an Order dissolving the marriage between the parties. COUNT 2 ALIMONY AND~=Ai_:_n4IONY PENDENTE LITE 10. Paragraphs 1 through 9 are incorporated by reference in their entirety. 11. The parties separated on or azound January 14, 2009. 12. Plaintiff lacks sufficient property and income to provide for her reasonable needs in accordance with the standard of living the parties established during the marrrage. 13. Defendant enjoys a respectable income along with benefits from which he is able to contribute to the support and maintenance of Plaintiff as well as alimony in accordance with the Divorce Code. WHEREFORE, Plaintiff requests an order to be entered awarding Plaintiff alimony pendent elite and permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff with regazd to litigation expenses and so that he may remain in the station of life to which he has become accustomed during the marriage. CO_UNT_3 EQUITABLE DISTRIBUTION 14. Paragraphs 1 through 13 are incorporated herein by reference in their entirety. 15. Marital property and debts accumulated during the mazriage. 16. Plaintiff and Defendant are each entitled to a portion of the marital assets and each responsible for the marital debts. WHEREFORE, Plaintiff requests an order to be entered regarding the equitable distribution of the marital assets and marital debts. COUNT 4 COUNSEL FEES 17. Paragraphs 1 through 16 aze incorporated herein by reference in their entirety. 18. Plaintiff has insufficient assets and income to pay for her counsel fees and costs regarding litigation in relate to the within matter. 19. .Defendant enjoys a respectable income along with benefits from which he is able to pay the Plaintiff s counsel fees. WHEREFORE, Plaintiff requests an order to be entered directing for the Defendant to pay the Plaintiff s reasonable counsel fees. Respectfully submitted ~[efi D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717) 960-0075 IN THE COURT OF COMMON PLEAS OF CUMBELAND COUNTY, PENNSYLVANIA HEATHER GEYER, v. MATTHEW GEYER, Defendant CASE NO. : CIVIL ACTION -LAW IN DIVORCE VERIFICATION I, Heather Geyer hereby state that I am the plaintiff in the foregoing action and that the facts contained herein are true, correct and accurate to the best of my knowledge, information and belief. I further understand that false statements made herein are subject to the penalties of 1$ Pa.C.S. § 4904 relating to unsworn falsification to authorities. "~ Heather Geyer Date: ~~~~_- ~_ ~ * ~ Q W D w :.- . ~ -n -r- ; ~' ~ r~~~ r ~ >-, n r7 ~ , 'a . ... ~, a f._s 7 - ~, J ` _ : ~+ .. `" -., - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HEATHER GEYER, Plaintiff CIVIL ACTION AT LAW CASE NO. 2009-1924 V. MATTHEW GEYER, Defendant IN DIVORCE PETITION FOR ALIMONY PENDENTE LITE AND NOW, comes Plaintiff, Heather Geyer, by and through her attorney, Sheri D. Coover, Esquire- files the following Petition for Alimony Pendente Lite and in support thereof avers as follows: 1. Petitioner, Heather Geyer, is a competent adult individual who resides at 8596 Elliott Run Road, Three Springs, Pennsylvania. 2. Petitioner's date of birth is May 6, 1986 and her social security number is 376-11-8960. 3. Respondent Matthew Geyer is a competent adult who resides at 82 S.M.E., Shippensburg, Pennsylvania. 4. Respondent's date of birth is February 11, 19$6 and his social security number is unknown. 5. A divorce complaint which contained claims for Divorce, Alimony, and Alimony Pendente Lite was filed under the above-captioned docket number on March 27, 2009. A true and correct copy of the Divorce Complaint is attached to this petition. WHEREFORE, Petitioner requests that this Court order Alimony Pendente Lite. submitted, he D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Cazlisle, PA 17413 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HEATHER GEYER, Plaintiff V. MATTHEW GEYER, Defendant CIVIL ACTION AT LAW CASE NO. 2009-1924 IN DIVORCE VERIFICATION I, Sheri D. Coover, Esquire state that I am the Attorney for the Plaintiff in this action and that I sign this affidavit as an attorney because I have sufficient knowledge or information and belief based upon my investigation of the matters averred or denied in the foregoing document and that this statement is made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to autho ' ' s. Date: ~ J ~1' Z ~~ Sh oover, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA HEATHER GEYER, :CIVIL ACTION AT LAW Plaintiff CASE NO. 2009-1924 v. MATTHEW GEYER, IN DIVORCE Defendant CERTIFICATE OF SERVICE I, Sheri D. Coover, Esquire hereby certify that on this 11~' day of August, 2009, I caused the foregoing PETITION FOR ALIMONY PENDENTE LITE to be served upon counsel for the Defendant by United States First Class mail addressed as follows: Stacy B. Wolf, Esquire 10 West High Street Carlisle, PA 17013 submitted, Sheri D. Coover, Esquire Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 . IN THE COURT OF COMMON PLEAS OF CUMBELAND COUNTY, PENNSYLVANIA nn HEATHER GEYER, :CASE NO. Oq - ~ qa'{ l.: ~ v.1 Iern1 v. MATTHEW GEYER, :CIVIL ACTION -LAW ~ ~ .~ Defendant IhT DIVORCE _ . ..~ ~s -r ~~ r`r~ -n NOTICE TO DEFENDANT ~ ~~~ -; ~~; . -~ „ _ _ ~ ~:-, You have been sued in Court. If you wish to defehd against the claims set-fortl~m `1 ~=' the following pages, you must take prompt action. You are warned that if you fail too % '~ so, the case may proceed without you, and a decree in divorce or annulment=nay ~e 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 Defendant. You may lose money or property or other rights important to you, including custody or visitation of your children. When the grounds 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 at the Prothonotary at the Cumberland County Courthouse, Carlisle, . Pennsylvania 17013. 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 1-800-990-9108 /~ S eri D. Coover, Esquire ttorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 • • AMERICANS WITH DISABILITIES AS OF 1990 The Court of Common Pleas of Dauphin 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 the office of the Dauphin County Court Administrator, Dauphin County Courthouse, Front & Mazket Streets, Harrisburg, Pennsylvania. 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. J. • • IN THE COURT OF COMMON PLEAS OF CUMBELAND COUNTY, PENNSYLVANIA HEATHER GEYER, V. MATTHEW GEYER, Defendant CASE NO. CIVIL ACTION -LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Heather Geyet who currently resides at 8596 Elliotts Run Road, Three Springs, PA 17264. 2. Defendant is Matthew Geyer who currently resides at 82 S.M.E., Shippensburg, PA 17257. 3. Plaintiff has been a bona fide resident in the Commonwealth of • Pennsylvania for at least six months immediately preceding the filing of this Complaint. 4. Plaintiff and Defendant were married on August 11, 2007. 5. There have been no prior actions commenced for divorce or annulment of marriage between the parties in this or any other jurisdiction. 6. Plaintiff has been advised of counseling and that she may have the right to request the Court to require the parties to participate in counseling. 7. Plaintiff requests the Court to enter a decree of divorce. COUNT 1 3301(c) IRRETRIEVABLE BREAKDOWN 8. Paragraphs 1 through 7 are incorporated herein by r~fi~rence in their entirety. 9. The marriage is irretrievably broken and the parties aze estranged due to marital difficulties with no reasonable expectation of reconciliation. WHEREFORE, Plaintiff prays this Honorable Court to issue an Order dissolving the marriage between the parties. COUNT 2 ALIMONY AND ALIMONY PENDENTE LITE 10. Pazagraphs 1 through 9 are incorporated by reference in their entirety. 11. The parties separated on or azound January 14, 2009. 12. Plaintiff lacks sufficient property and income to provide for her reasonable needs in accordance with the standard of living the parties established during the marnage. 13. Defendant enjoys a respectable income along with benefits from which he is able to contribute to the support and maintenance of Plaintiff as well as alimony in accordance with the Divorce Code. WHEREFORE, Plaintiff requests an order to be entered awazding Plaintiff alimony pendent elite and permanent alimony in such sums as are reasonable and adequate to support and maintain Plaintiff with regazd to litigation expenses and so that he may remain in the station of life to which he has become accustomed during the marriage. COUNT 3 EQUITABLE DISTRIBUTION 14. Pazagraphs 1 through 13 aze incorporated herein by reference in their . entirety. 15. Marital property and debts accumulated during the marriage. 16. Plaintiff and Defendant aze each entitled to a portion of the marital assets and each responsible for the marital debts. WHEREFORE, Plaintiff requests an order to be entered regarding the equitable distribution of the marital assets and mazital debts. COUNT 4 COUNSEL FEES i 7. Paragraphs 1 through 16 are incorporated herein by reference in their entirety. 18. Plaintiff has insufficient assets and income to pay for her counsel fees and costs regazding litigation in relate to the within matter. 19. .Defendant enjoys a respectable income along with benefits from which he is able to pay the Plaintiff's counsel fees. WHEREFORE, Plaintiff requests an order to be entered directing for the Defendant to pay the Plaintiff s reasonable counsel fees. Respectfully submitted Uf1G11 L. ~,uuvv~, ~sduirc Attorney ID 93285 44 S. Hanover Street Carlisle, PA 17013 (717)960-0075 • • IN THE COURT OF COMMON PLEAS OF CUMBELAND COUNTY, PENNSYLVANIA HEATHER GEYER, v. MATTHEW GEYER, Defendant CASE NO. CIVIL ACTION -LAW IN DIVORCE VERIFICATION I, Heather Geyer hereby state that I am the plaintiff in the foregoing action and that the facts contained herein are true, correct and accurate to the best of my knowledge, information and belief. I further understand that false statements made herein aze subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. ~.~ 4~ -- Heather Geyer Date: ~ (~ _ • nr C1~~~ t '~. ~'I ~ 'I".s- E '~ 7t I r r 'Y,~~ ~;_' ~ ~~-~t,F_ ;, ,; ~; ~~~ `/ /v Old--fJ HEATHER GEYER, THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-1924 CIVIL TERM MATTHEW GEYER, IN DIVORCE Defendant/Respondent PACSES NO: 261111073 ORDER OF COURT AND NOW, this 1 lth day of August, 2009, upon consideration of the Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before Charles C. Carothers, IV on August 24.2009 at 1:30 P.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you. VS. CIVIL ACTION -DIVORCE If you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. Copies mailed to: Petitioner Respondent Sheri D. Coover, Esq. Stacy B. Wolf, Esq. BY THE COURT, Date of Order: August 11, 2009 ~ ~ £~~~ M. L. Ebert, Jr., J e YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 cc361 F~` ~.L-`. ~` ,. 2Qti3 ~~~~~ ~ ~ t`a`i ~ ~} :I. ~ IN THE COURT OF COMMON PLEAS ~ ~ OF CUMBERLAND COUNTY, PENNSYLVANIA ~~ rt7 rr-; ~., HEATHER GEYER, :CASE NO. 09-1924 ~,~-,'~ ~ r ~~ ~ v. ~. z ~ -o 3 ~ Wi MATTHEW GEYER, :CIVIL ACTION -LAW t- ~ N w " Defendant IN DIVORCE `' AFFIDAVIT OF CONSENT ~. A complaint in divorce under § 3301(c) of the Divorce Code was filed on March 27, 2009. ~. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. ~I~erify that the statements made in this affidavit aze true and correct. 1 understand that false statements herein aze made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: v~ C~ Plaintiff Heather Geyer r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA n HEATHER GEYER, V. MATTHEW GEYER, Defendant CASE NO. 09-1924 m r C,' ~~, t--, CIVIL ACTION -LAW IN DIVORCE _~ C..f' a 1 Z r3 w ti r WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE 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. Date: Plaintiff Heather Geyer HEATHER GEYER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. MATTHEW GEYER NO. 09"1924 DIVORCE DECREE AND NOW, ~ ~~L,~ ~.~ ~~~~ , it is ordered and decreed that HEATHER GEYER plaintiff, and MATTHEW 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.") None. By the Court, ,v~ Attest: ~ • Prothonotary -~~~~-o c~ ~ ~~ ~-~ Ili tai c~e. l~-taxi (e~ --~ ~ C~o~,~-e.~ ~~