Loading...
HomeMy WebLinkAbout04-3878 BEVERLY J. GEIGER, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. oll. j67~ C,;.,J .1:_ GERALD A. GEIGER, Defendant COMPLAINT 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 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 2 Liberty A venue Carlisle, PA 17013 (717) 249-3166 BEVERLY J. GEIGER, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. O'f. 3~/r ~ TL- COMPLAINT IN DIVORCE GERALD A. GEIGER, Defendant COMPLAINT UNDER SECTION 3301(c) AND SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Beverly J. Geiger, who currently resides at 3502 Ada Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant is Gerald A. Geiger, who currently resides at 3502 Ada Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. The parties have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on April 11, 1981, in Camp Hill, Pennsylvania. 5. Plaintiff avers that there are children of the parties under the age of eighteen (18), namely: Lauren Geiger (date of birth 8/5/87) and Jennifer Geiger (date of birth 6/5/90). 6. There have been no prior actions of divorce or for annulment between the parties. 7. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. The marriage is irretrievably broken. 9. Neither Plaintiff nor Defendant is in the military service of the United States. 10. The parties separated on March 1, 2004. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. COUNT I EQUITABLE DISTRIBUTION 11. Paragraphs 1 through 10 are incorporated herein by reference. 12. The Plaintiff and Defendant have legally and beneficially acquired property, both real and personal, during their marriage. 13. The Plaintiff and Defendant have been unable to agree as to equitable distribution of the said property to the date of the filing of this Complaint. WHEREFORE, the Plaintiff, Beverly J. Geiger, requests this Court to equitably divide all marital property. COUNT II ALIMONY 14. Paragraphs 1 through 13 are incorporated herein by reference. 15. Plaintiff lacks sufficient property to provide for her reasonable means and is unable to support herself and the remaining minor children, namely Lauren Geiger and Jennifer Geiger, through her employment. 16. Plaintiff requires reasonable support to adequately maintain herself and the minor children in accordance with the standard of living established during the marriage. WHEREFORE, Plaintiff requests the Court to grant alimony to Plaintiff as is deemed appropriate. COUNT III ALIMONY PENDENTE LITE AND COUNSEL FEES, COSTS AND EXPENSES 17. Paragraphs 1 through 16 are incorporated herein by reference. 18. Plaintiff is unable to sustain herself during the course of litigation. 19. Plaintiff lacks sufficient property to provide for her reasonable needs, and is unable to sustain herself through appropriate employment. 20. Plaintiff is in need of alimony during the pendency of this divorce proceeding to adequately defend and prosecute her claim. 21. Plaintiff is without sufficient means to pay counsel fees, expenses, and costs relative to this proceeding, including the employment of any necessary experts or the obtaining of any appraisals. 22. Plaintiff requests the Court to allow her reasonable alimony, alimony pendente lite, counsel fees, costs and expenses, pursuant to Section 502 of the Divorce Code, and Rule of Civil Procedure 1920.13. WHEREFORE, Plaintiff, Beverly J. Geiger, requests the Court to compel the Defendant, Gerald A. Geiger, to pay alimony pendente lite and to grant counsel fees, costs and expenses of investigation, preparation, evaluation, and any other matter necessary to the proper determination of this case. COUNT IV CUSTODY 23. Paragraphs 1 through 22 are incorporated herein by reference. 24. The parties are the parents of two unemancipated children: Lauren Geiger (date of birth 8/5/87) and Jennifer Geiger (date of birth 6/5/90). The children were not born out of wedlock. The children presently reside with both parents at 3502 Ada Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. During the past five (5) years, the children have resided with the following persons and at the following addresses: NAME RESIDENCE DATE Beverly and Gerald Geiger, and Jacqueline Geiger 3502 Ada Drive Mechanicsburg, PA 17050 1989 - present The mother of the children is Beverly J. Geiger, currently residing at 3502 Ada Drive, Mechanicsburg, PA 17050. She is married. The father of the children is Gerald A. Geiger, currently residing at 3502 Ada Drive, Mechanicsburg, PA 17050. He is married. 25. The relationship of the Plaintiff to the children is that of Mother. The Plaintiff currently resides with the following persons: NAME RELATIONSHIP Gerald A. Geiger Husband Lauren Geiger Daughter Daughter Daughter (age 19) Jennifer Geiger Jacqueline Geiger 26. The relationship of the Defendant to the children is that of Father. The Defendant currently resides with the following persons: NAME RELATIONSHIP Beverly J. Geiger Wife Lauren Geiger Daughter Daughter Jennifer Geiger Jacqueline Geiger Daughter (age 19) Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the children or claims to have custody or visitation rights with respect to the children. 27. The best interest and permanent welfare of the children will be served by granting the relief requested because: A. Plaintiff/Mother has been the primary caregiver of the children since their birth. B. Plaintiff/Mother's employment with the Cumberland/Perry Vo-Tech allows her significantly more time at home, as compared to Defendant/Father. 28. Each parent whose parental rights to the children have not been terminated, and the person who has physical custody of the children, have been named a party to this action. WHEREFORE, Plaintiff requests the Court to grant custody of the children to Plaintiff. Respectfully submitted, Date: Ohfu4- c:;, ~y ?' ;;; F. K;,'g. _;" (~~ N. Second Street enthouse Suite P. O. Box 984 Harrisburg, PA 17108 (717) 236-8000 JFK/bp:divorce\geiger .div VERIFICATION I, Beverly J. Geiger, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Complaint in Divorce; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. B'&l f/J"-I GA.b./ 9/!I~-<~ ever yJ. oeiglr 0' Dated: ~ ~~y. BEVERLY J. GEIGER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 04-3878 CIVIL ACTION LAW GERALD A. GEIGER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, August 11,2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. at 301 Market Street, Lemoyne, PA 17043 on Tuesday" September 21, 2004 , the conciliator, at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 honrs prior to scheduled hearinll. FOR THE COURT. By: /s/ Melissa P. Greevy. Esq. Custody Conciliator mhc The Court of Common Pleas of Cumberland County is requin:d by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our oflice. 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT Al"FORD 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, Pennsylvania 1 7013 Telephone (717) 249-3166 ~~ ~ ~' ~ /J(J.J/.,$ .~:z~ ~ hO-Jf.j> ~ !tv p ~f/ T~ ~.n )j{J.II.j> 82 :8 l!d II 5nnOOZ J,J.1\'lC;\iOi-;'i.oC'd 3Hl :!O 3:Jl:!:.~o-a31!::I Plaintiff OCT 1 2 Z~a4f IN THE COURT OF COMMON PLEAS OF CUMBEHLAND COUNTY, PENNSYLVANIA NO. 04-3878 CIVIL TERM CIVIL ACTION - LAW BEVERLY J. GEIGER, v. GERALD A. GEIGER, IN CUSTODY Defendant ORDER TO RELINQUISH JURISDICTION AND NOW, this 7'h day of October, 2004, counsel for the parties having agreed to cancel the Custody Conciliation Conference scheduled for September 21, 2004, the Conciliator hereby relinquishes jurisdiction of the above captioned matter. FOR THE COURT: .-k A)}S1?ML~ Melissa leel Greevy, Esquire Custody Conciliator :237025 "" ~j; .;;;:- C' <. r" '-." ""~I Lv C) . . III , . BEVERLY J. GEIGER, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3878 IN CUSTODY GERALD A. GEIGER, Defendant STIPULATION AND NOW, come the above-named parties, this 16th day of November, 2004. and state as follows: WHEREAS, the parties wish to enter into an agreement relative to the legal and physical custody of the children, Lauren Geiger (date of birth 8/5/87) and Jennifer Geiger (date of birth 6/5/90); and WHEREAS, both parties have been provided an opportunity to review this Stipulation with the counsel of their choice prior to signing; and THEREFORE, in consideration of the mutual covenants, promises, and agreements as hereinafter set forth, and intending to be legally bound hereby, the parties agree as follows: SIIARED LEGAL AND PHYSICAL CUSTODY. The parties agree to shared legal and physical custody of the said minor children. The parties agree that major decisions concerning the children, including, but not necessarily limited to, the childrens' health, welfare, education, religious training and upbringing shall be made by them jointly, after discussion and consultation with each other, with a view toward obtaining and following a harmonious policy in the childrens' best interest. Each party agrees not to impair the other party's rights to shared legal custody of the children. Each party agrees not to attempt to alienate the affections of the children from the other party. Each party shall promptly notify the other of any activity or circumstance .. " concerning their children that could reasonably be expected to be of concern to the other. Day to day decisions shall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from any doctor, dentist, teacher, professional or authority and to have copies of any reports given to either party as a parent. Actual physical custody of the children will be determined from time to time between the parties. However, should they have an inability to reach such an agreement, the children will reside in each party's home on a "week on - week off' basis, with the week commencing on Monday at the time which the school day would normally end, and ending on the following Monday at the time which the school day would normally end. HOLIDAYS. Holiday visitation will be agreed to between the parties from time to time. VACATION. Each party will have the right, should they so choose, to have two uninterrupted weeks of visitation with the c:hildren for vacation purposes, with thirty (30) day notice to be given to the other party. TELEPHONE CONTACT WITH CIDLDREN. Each party shall allow regular telephone contact between the other party and the subject minor children during their periods of custody. ,,' I . ' ,. DISPARAGING REMARKS. Neither Father nor Mother shall make any disparaging remarks regarding the other parent in the presence of the children. Such as those that might tend to alienate the affections of the children toward the other parent. Also, each parent shall inform relatives and friends to also refrain from making any disparaging remarks regarding either parent in the presence of the children. HOME ENVIRONMENT. It j,s agreed between the parties that each of them shall take whatever steps are necessary to ensure that the subject minor children live in an environment free from the use of alcohol and tobacco products during their custodial periods. WHEREFORE, the parties intending to be legally bound thereby, and with the desire that this Stipulation be entered as an Order of Court at the request of either party, hereby set their hand and seals and on the date first written above. e?f John,. KIng, EsqUIre'" Attorney for Beverly ;:Jiger Be~C;/Jy . Ger~ ~ ~I/ / , p. QrctW'gner, Esquire ~~I for Gerald A. GeIger (...-,~' kip: domestic\geiger. stp .... ("1 r-<> ,":;-'1 0 ,: " .J.:- '"11 roo.> --1 i . i - ,. id ".-"..., C) ;::: t':) , , ) 1 --,,'.1 .. , =",: .~ ) .] h I ! I j , ,:~ ( . ) "v .-. j <- 'r \, 'V DE C 2 2 2004 ./>1 '-f'" v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3878 IN CUSTODY BEVERLY J. GEIGER, Plaintiff GERALD A. GEIGER, Defendant ORDER OF COURT AND NO\V, TO WIT, thi~ Z. "" day of __.___-;p~ ___ _,2004, it is hereby ORDERED and DECREED that the attached Stipulation for Custody, dated November 16, 2004, is adopted in its entirety and incorporated herein as a.n Order of Court. BY THE COURT: ~ /-14. J. ~rO~ \tJ c."'" ,) rtJ . \ 1 . j I . Ii ! "I . ~, , t -) Lv ~<, '= !~~,JZ , ... ., ~ BEVERLY J. GEIGER, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 04-3878 IN CUSTODY GERALD A. GEIGER, Defendant STIPULATION AND NOW, come the above-named parties, this 16th day of November, 2004. and state as follows: \VHEREAS, the parties wish to enter into an agreement relative to the legal and physical custody of the children, Lauren Geiger (date of birth 8/5/87) and Jennifer Geiger (date of birth 6/5/90); and WHEREAS, both parties have been provided an opportunity to review this Stipulation with lhe counsel of their choice prior to signing; and THEREFORE, in consideration of the mutual covenants, promises, and agreements as hereinafter set forth, and intending to be legally bound hereby, the parties agree as follows: SIIARED LEGAL AND PHYSICAL CUSTOI>V. The parties agree to shared legal and physical custody of the said minor children. The parties agree that major decisions concerning the children, including, but not necessarily limited to, the childrens' health, welfare, education, religious training and upbringing shall oe made by them jointly, after discussion and <:onsultation with each other, with a view toward obtaining and following a harmonious policy in the childrens' best interest. Each party agrees not to impair the other party's rights to shared legal custody of the children. Each party agrees not to attempt to alienate the affections of the children from the other party. Each party shall promptly notify the other of any activity or circumstance concerning their children that could reasonably be expected to be of concern to the other. Day to day decisions ~hall be the responsibility of the parent then having physical custody. With regard to any emergency decisions which must be made, the parent having physical custody of the children at the time of the emergency shall be permitted to make any immediate decisions necessitated thereby. However, that parent shall inform the other of the emergency and consult with him or her as soon as possible. Each party shall be entitled to complete and full information from MY doctor, dentist, teacher, professional or authority and to have copies of any reports given ~o either party as a parent. Actual physical custody of the children will be determined from time to time between the parties. However, should they have an inability to reach such an agreement, the children will reside in each party's home on a "week on - week off' basis, with the week commencing on Monday at the time which the school day would normally end, and ending on the following Monday at the time which the school day would normally end. HOLIDAYS. Holiday visitation will be agreed to between the parties from time to time. VACATION. Each party will have the right, should they so choose, to have two uninterrupted weeks of visitation with the children for vacation purposes, with thirty (30) day notice to be given to the other party. TELEPHONE CONTACT WITH CHILDREN~ Each party shall allow regular telephone contact between the other party and the subject minor children during their periods of custody. :. / .'" j .... DISPARAGING REMARKS. Neither Father nor Mother shall make any disparaging remarks regarding the other parent in the presence of the children. Such as those that might tend to alienate the affections of the children toward the other parent. Also, each parent shall inform relatives and friends to also refrain from making any disparaging remarks regarding either parent in the presence of the children. HOME ENVIRONMENT. It i.s agreed between the parties that each of them shall take whatever steps are necessary to ensure that the subject minor children live in an environment free from the use of alcohol and tobacco products during their custodial periods. WHEREFORE, the parties intending to be legally bound thereby, and with the desire that this Stipulation be entered as an Order of Court at the request of either party, hereby set their hand and seals and on the date first written above. / Yiwua fl.' Beverly J. ~f.jfl ~LA./ ~?2 Gerald A. Geiger kip: domestic\geiger. stp .: ,- ., C r-_) ~:. ~) ( :.} .: " -'- OJ f 1 :-;~ I I C') I 'i I f' .) ; , 'I. " - ;'1 :,:,. ( j , ., -. ( ,- 'j ~~, ~~ v. : IN THE COURT OF COMMON PLEA : CUMBERLAND COUNTY, PENNSYL ANIA NO. 04-3878 COMPLAINT IN DIVORCE BEVERLY J. GEIGER, Plaintiff GERALD A. GEIGER, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330l(c) of the Divorce Code s filed on August 9,2004, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ni ety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of Noti of Intention to Request Entry of the 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. ~ 904 relating to unsworn falsification to authorities. DATED: , , /i/,' '"; Ii} LJ j ,.'J. L- f!/ l v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL NIA NO. 04-3878 COMPLAINT IN DIVORCE BEVERLY J, GEIGER, Plaintiff GERALD A. GEIGER, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301 C AND 3301 OF THE DIVORCE COD 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 pro erty, 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 entere by the Court, and that a copy of the Decree will be sent to me immediately after it is filed wi the Prothonotary. 4, I verify that the statements made in this Affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 9 4 04 relating to unsworn falsification to authorities. Date: 1;1- /! u ) c y (1 (- r-:'f '~j.~ ,j.::- C:--' c'n 'C-') rV .....,0 o ~'>l .-\ '{1:n {..., :7~;)j; .' t"'. ,~', -'. ...-r' - ....,...' ~~ r-) ...:,\n -~~" 'f! ),-; ".) ~ t -. BEVERLY J, GEIGER, Plaintiff : IN THE COURT OF COMMON PLEA : CUMBERLAND COUNTY, PENNSYL ANIA NO. 04-3878 COMPLAINT IN DIVORCE v. GERALD A. GEIGER, Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330l(c) of the Divorce Code s filed on Augus! 9, 2004. 2. The marriage of Plaintiff dnd Defendant is irretrievably broken and ni ety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a final decree of divorce after service of Noti of Intention to Request Entry of the Decree. I vt'rify 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. g 904 relating to unsworn falsification to authorities. DATED: (,). If ole ~l , ~i /,'Mt / /v Ge(ald A. Geiger ' v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL NIA NO. 04-3878 COMPLAINT IN DIVORCE BEVERLY J. GEIGER, Plaintiff GERALD A. GEIGER, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301 C AND 3301 D OF THE DIVORCE CO 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 pro erty, 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 enter by the Court, and that a copy of the Decree will be sent to me immediately after it is filed w h the Prothonotary, 4, I verify that the statements made in this Affidavit are true and correct. understand that fa!~e statements herein are made subject to the penalties of 18 Pa. C.S. g 904 relating to unsworn falsification to authorities. Date: /,) /; 0 ! 0 '1 .J ?? ( /hc4L ~q/o/\J Gerald A, Geiger, Defendant ....'("i ....,... -,- o .-;:.\ -1.-<"', \-.'f~t ~(.:...<. -~J "-;/ '(:),() -,~':-':":~\ \':),"C) /)(l' '::\ Po:"," r" c~~) (':"' ,;;c" <-"J f"" ('~ \",' -.P <;? 1-- ~:3~ c,;- -- ~ v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL V NIA NO. 04-3878 COMPLAINT IN DIVORCE BEVERLY J, GEIGER, Plaintiff GERALD A, GEIGER, Defendant AFFIDA VII OF SERVICE COMMONWEALTH OF PENNSYLVANIA : SS: COUNTY OF DAUPHIN Personally appeared before me, a Notary Public, in and for said Common ealth and County, John F, King, Esquire, Attorney for the Plaintiff, who, being duly sworn according to law, deposes and says that a Certified copy of the Complaint in Divorce in e above-captioned matter was served upon Defendant, Gerald A. Geiger, by Certified Mail, Restricted Delivery, on August 17, 2004, as eVidenced~l)eiitta~ed Ce~9fied Mail car "~B- / (JOhn F. King, squirt) Sworn and subscribed to before rk this ,2 '10:- da71f. U,fM! /' ,2004. f~:;!:;';6k A ~Vlr NOTARIAl. SEAL BELINDA A SCHOR\' NoIofy PublIc C1TV Of HARRISBURG, DAUPHIN COUNTY My Commllllon Expll.."P 27, 2008 , . Complete Items 1, 2, and 3, Also complete ttem 4 n RestricIed DelIVery Is deslrIIII. . Prlnt your name and addrllSS on thel&V...... so that we can return the card to you, . Attach this card to the back of the meIlpleoe, or on the front n space permfl$, };;;;~ ~ '!>~ab- ~ ~)f~r7O)b 3._~ ':>. ~:" 01 ,- Fee) 2, ArtIcle Nu'- -1.""V ^ '1.c7\ (rransfortrom_1sbeI) J...J.Jr \,J IJ"" PSFo.tn 1~200 'llorIlMIo_~ 102595-02-M-1540 C' f -at C!)l zt U)d F;c :::;c:. '~;;1' '~c 5>c :z-, -< <....:'.' ....' c::::. C::J ""' C' .;:-r~1 (-') r.....) u) .~--....) ~.(-. -~ .,'", c..." .,', - v, : IN THE COURT OF COMMON PLE S : CUMBERLAND COUNTY, PENNSY VANIA NO, 04-3878 COMPLAINT IN DIVORCE BEVERLY J, GEIGER, Plaintiff GERALD A, GEIGER, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for e try of a divorce decree: . 1, Ground for divorce: irretrievable breakdown under Section 3301(c) of the Di orce Code, 2, Date and manner of service of the complaint: On August 17, 2004 by certifie mail, restricted delivery, 3, Date of execution of the Affidavit of Consent required by Section 330l(c) of e Divorce Code: by Plaintiff, Dec, 10,2004; by Defendant, Dec. 10,2004, 4, Related claims pending: There are no related claims pending, 5. Date Plaintiff's Waiver of Notice was filed with the Prothonotary: Dee, 29, 2 04. Date Defendant's Waiver of Notice was filed with the Prothonotary: Dee, 29, 004. .( / ---~ /. <.....;..':-1--:;,;. { JC\.Jv'- Jo.hn F, King, Esquire 4ttorney for Plaintiff ;. j,(!r \./ , / GO'<...-( ,-) ,:;:;) :2 C' c'.\ ,-, \"0) ,,0 ~:.:~ -"" -;-; C' .:(\ __I ~. ft\~l , :c~J~~'. (")':,,") _,:,..1..) t~Sf>1 ~. -'" <;'? < 0' --- - . .. l+:::t: ;Ii ;t; .. . . . . .. ;t;;f. :+; ;!i'f. "':f.:t::t: ... .. .. . IN THE COURT OF COMMON PLEA . . . OFCUMBERLANDCOUNTY STATE OF . . . . BEVERLY J. GEIGER. . . Plaintiff . . . . . VERSUS . . . . . . . . . . . . . . . . GERALD A. GEIGER, Uofenclant . . . . . . . . . . AND NOW, DECREED THAT . . . . . AND . . PENNA, No. 04-3878 DECREE IN DIVORCE I?c...,,~ ). 1 .:Jr 'I.' HI . -, IT IS ORDERED AND Beverly J. CBiger , PLAINTIFF, CBrald A. CBiger , 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; . . . . . . . . . . . . . . . . . . . . . . . . . . . . I,J~ ATTEST: PROTHONOTA Y . . . . .. .. .. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . . . . . . ;t;:f. ,.,'fi / ,I'.- ...,.- ~ fl5'1 ~('./ gz" ~ /'{/- / _ / _.....- 4-,/;/ -;:'17 50-51 ~1.p P 1--'"[/' . . -----