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HomeMy WebLinkAbout05-2248 JERAMIAH D. GEYER, Plaintiff : IN THE COURT OF COMMON PLEAS F CUMBERLAND COUNTY, PENNSYL V NIA v. CIVIL ACTION - LAW AMBER J. GEYER, Defendant : NO. OS', .).,) If I : IN DIVORCE CIVIL TERM 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, t will proceed without you and a decree of divorce or annulment may be entered against y u for any claim or relief requested in these papers by the Plaintiff. You may lose money or prop rty or When the ground for the divorce is indignities or irretrievable breakdown of the ma other rights important to you, including custody or visitation of your children. you may request marriage counseling. A list of marriage counselors is available in the Of ce of the Prothonotary at Cumberland County Courthouse, Carlisle, Cumberland C ty, Pennsylvania, 17013. YOU SHOULD TAKE THIS PAPER TO YOUR LA WYER AT ONCE. IF YOU DO HA VE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. OFFICE CAN PROVIDE YOU WITH INFORMA nON ABOUT HIRING A LA WYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAYBE ABL PROVIDE YOU WITH INFORMA nON ABOUT AGENCIES THAT MAY OFFER LE SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 .. JERAMIAH D. GEYER, Plaintiff : IN THE COURT OF COMMON PLEAS F CUMBERLAND COUNTY, PENNSYL V NIA v. Defendant CIVIL ACTION - LAW NO. 0.5-, j.1 V J' IN DIVORCE CIVIL TERM AMBER J. GEYER, COMPLAINT IN DIVORCE NO FAULT 1. Plaintiff is Jeramiah D. Geyer, an adult individual currently residing at 25 Pr spect Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Amber J. Geyer, an adult individual currently residing at 243 alnut Bottom Road, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has b n so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on January 5, 2003, Cumberland Co nty, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parti s. 6. Neither the Plaintiff nor the Defendant are members of the United States A ed Forces or its Allies. . ..... 7. Plaintiff has been advised of the availability of counseling and the right to req est that the Court require the parties to participate in counseling. Knowing this, Plaint ff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, nine (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuan to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, \\ o,AJ\Jl h '\l Ji '\.,"" i\ - oJ '" I ~ " Hannah Herman-Snyder, Esquire Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verifY that the statements made in the foregoing document are true and co understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsifications to authorities. DATE: ~-dS"-"cJS- ~/):~ .-1eramiah D. Geyer, P a ntiff y" \~ f'~ '-. ". ~ ~ ~ .... v.. <: c ~ JT s., --..... ~ <> '0 (") C'. .- :::':i -" o -rl --/ ::t,., fi 1 r::= -.. Iii ~;c:O ;:~j ~;: ~,-.i::;~} -.-::.- '..., .J ,or) j';J :;;:.~ -~J -< rV... '. \----~ .~ , JERAMIAH 0, GEYER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW Defendant : NO, 05-2248 : IN DIVORCE CIVIL TERM AMBER J. GEYER, AFFIDAVIT OF SERVICE AND NOW, this \q"" day of May, 2005, comes Hannah Herman-Snyder, Esquire, counsel of record for Plaintiff, and states that a true and attested copy of a Complaint in Divorce was sent to Defendant, Amber J, Geyer, at her address of 156 Sassafras Lane, Elizabethtown, PA 17022 by certified mail, restricted delivery, return receipt requested. A copy of said receipt is attached hereto indicating service was made on May 14,2005, ~::~n A~~~~S~~d~r,~~~~(e~\ Attorney for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to before me this /7'~ day of /)/aA.! ,2005 , . <eolJ.,,~ ( N NOTARIAL SE~l ROE11IJ 1l0SHORM. NQ1ARYPU8~~T'i :~~IJ~~~I~.~~~~B/sRkt~~ ~~ 2001 . . ~ =r m L1l m ce",:::t:::J~3 d ~~~-- f:~:~'~ Return Receiptfen I ~ , ~Q ~ ;::'; IErldOrSementReqlllred,1 -L'_(__ ,I, '(.:2:,2,<t? ,r.," t:J ReSlnl;tedOellvef\j.~ee ? cO 1 r-:\ %" ). CJ (Endorsement Required,' , _.-L..~_L, ____ _~....~\.',;'~~ ...':f'~ Total Postage & Fees [U!J.-5'_J \,~.,,:~~.../ 0- r- r- eo CJ CJ CJ r-I CJ r- ~ se"tTO.4~J__&ic _ -u- s'met.~t30};::tBun;.,;ru uQfb'rr1~1 L Or, ate, ZIP~4 'A ( 0 - 1. Article Addressed to: ,4nJu1 (} J-L-f 3 Wf.)JJ r!a}t.,A5Ie{ fl1- /70/3 o Ex~ Mall [J Return Receipt for Merchandlee OC,O,O. 4. Restncted DelIveIy'/ (Extra Fee) .. 2. Article Nomber ~~~ PS Form 38' 1, August 2001 7MtJ " I &170, {J(jDI DomooIIc IIeIum Roc:eIpt 5? 179, 3"1 '1'1 102595"02.M-1lS4O 0? .~~; \..:) 2c5 -~;i} -:? :::=j -, "., ~ "-:J ,;1 JERAMIAH D, GEYER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION -- LAW Defendant : NO, 05-2248 : IN DIVORCE CIVIL TERM AMBER 1. GEYER, AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under S3301 (c) of the Divorce Code was filed on May 2, 2005, and service was made on May 14,2005, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service ofthe Complaint. - 3, I consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa,C.S, S4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES, DATE: '1-/7 -(J.)' ~h:~ 1ERAMIAH D, G~ER, Plaintiff t":?} '~ <5' ~ c;;.) ~ \'?"'l o ( , ~' .t--, ~.:( ~ #.....~ ..-(\ "'Y'\-t' t\ ..r('\ "'('),'0 "\." \ ;:2? (i\ 'c)n \?;' ,\.... .~ ';:..:;:- ':'-' ...... .' ...... <=' - JERAMIAH 0, GEYER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION - LAW Defendant : NO, 05-2248 : IN DIVORCE CIVIL TERM AMBER], GEYER, WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE 1, I consent to the entry of a final decree in divorce: without notice, 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses in 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa,C.S, 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES, DATE: '1-17-()S- ~;O.~ ,1ERAMIAH D. G R, Plaintiff C t-o:_ ~ ~ :rJ?'" cc- G) C..., 0.... Q, ~-r\ -,1.~ f. \~ ~l:J\O :l~J?\ ':::.\ "'r"'" "j? :..:.:: -- -- .' -' -' PROPERTY SETTLEMENT AGREEMENT THIS AGREEMENT, made this ,:;"q"" day of '-Al>..~l~.,-t ,2005, by and between JERAMIAH DA VID GEYER, of Cumberland County, Pennsylvania, party of the first part, hereinafter referred to as "Husband", AND AMBER JEAN GEYER, of Cumberland County, Pennsylvania, party of the second part, hereinafter referred to as "Wife", WITNESSETH: WHEREAS, the parties hereto are husband and wife, having been married on January 5, 2003, in Cumberland County, Pennsylvania; and WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Wife and Husband to live separate and apart, and the parties hereto are desirous of settling their respective financial rights and obligations as between each other, and to finally and for all time to settle and determine their respective property and other rights growing out of their marital relations; and wish to enter into this Separation and Property Settlement Agreement; and WHEREAS, both and each of the parties hereto have had the opportunity to be advised of their legal rights and the implications of this Agreement and the legal consequences which may and will ensue from the execution hereof; and WHEREAS, Wife acknowledges that she has had the opportunity to be thoroughly conversant with and know accurately the size, degree, and extent of the estate and income of Husband and Husband acknowledges that he has had the opportunity to be thoroughly conversant with and know accurately the size, degree, and extent of the estate and income of Wife; NOW, THEREFORE, in consideration of the premises and of the mutual promises, covenants and undertakings hereinafter set forth which are hereby acknowledged by each of the parties hereto, Wife and Husband, each intending to be legally bound hereby, covenants and agree as follows: }, The parties shall be equally responsible for the repayment of the debt due and owing to Members' First, account no, 195924, Each party shall pay $87,00 twice monthly directly to Members' First. Payments shall be made in such a manner until the debt is satisfied in its entirety. 2. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania, which are in effect as of the date of execution of this Agreement. 3, This Agreement constitutes the entire understanding of the parties and supercedes any and all prior Agreements or negotiations between them, There are no representations or warranties over those expressly set forth herein. IN WITNESS WHEREOF, the parties have set forth their hands and seals to two counterparts of this Agreement, each of which shall constitute an original, the day and year first above written, WITNESSES: ~ctr ~ f-17-05~ ~~;';'A A~ Date 4ERAMIAH 0, GIYffiR ~ "JJ( ~0 S a ~L>( ~'(/k ~ Date AMBER], GE R 0 COMMONWEALTH OF PENNSYLVANIA COUNTY OF Cu,~h1a-J- Onthis J{~dayof ~~ 2005, before me, the undersigned officer, personally appeared JERAMIAH D, GEYER, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that he executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Notary Public NOTARIAL SEAL flOB",!. GOSHORN, NOTARY PIlBl.IC CARLISLE BORe. CUMBERLAND COUNTY MY COMMISSION EXPIRES APRI1I7 2007 COMMONWEALTH OF PENNSYLVANIA COUNTY OF Oau.ph; Y'\ On this f) q day of lltr 2005, before me, the undersigned officer, personally appeared AMBER 1. GEYER, known to me (or satisfactory proven) to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purpose therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ~liwf) Notary Pub COMMONWEAlTH OF PENNSYLVANIA Notarial Seal WertJi M. Groh, NotaJy Public Swatara Twp., Dauphin County M'i Commlsslon Expiras June 2, 2009 1Hmbor. -~ Associallon of Notaries -" .-.- : '"' , '~, _' "J .. 5-~ c., C~ (,;"":> <.:..1"1 ~fJ.. :....,.. o -n ..-; -c., f'I"'~ll~~_ -~~: ~ ~,'--) I'i-! (:<: cr" - JERAMIAH D. GEYER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW Defendant : NO. 05-2248 : IN DIVORCE CIVIL TERM AMBER 1. GEYER, AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 93301 (c) of the Divorce Code was filed on May 2, 2005, and service was made on May 14,2005, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 notice of intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. 1 UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C,S. 94904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: ~ - ;)C(~05 Ci1v1.-t19j</0/~\ AMBER J. GEYER, Difendant \......., C-' () C~I -on C.n ,,-',,", >>, c,) , -, ~" JERAMIAH D. GEYER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW AMBER J. GEYER, Defendant : NO, 05-2248 : IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE I, I consent to the entry of a final decree in divorce without notice. 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT, I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa,C.S. 1)4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES, DATE: 'f)-)DI-O '> I' ! (jJj eLl \-1. ( I _/~LJr- "- AMBER J. GEYER, Defdrldant "" <:~ C") 8i ~n r/') =:! 1l1::t! /"-.- ~"0c-;:; c.,J .r:- <'fi' JERAMIAH 0, GEYER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW Defendant NO, 05-2248 : IN DIVORCE CIVIL TERM AMBER J. GEYER, PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the court for entry of a divorce decree: I, Ground for divorce: Irretrievable breakdown under ~3301(c) 3391(d)(I) eftae Divortle Ceee, (Strike out inapplicable section), 2. Date and manner of service of the Complaint: certified mail/restricted delivery on May 14,2005, 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: August 17,2005 by Defendant: August 29, 2005 (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: none 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 of plaintiff's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: August 26, 2005 Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with the Prothonotary: September I, 2005 ~(\i\r",l\ '\.l ~)\.J\\"f,. <1n"\,, \ 11 Hannah Herman-Snyder, Esquire GRIFFIE & ASSOCIATES Attorney for Plaintiff t:-~ t;'? ~ ".' -J - . . . . . + . . + . . + + . + . + . . + . . . . + + . . + . + . + + + + . + + + . . . + . + . + . . . . . + . . + . . + + . . . + +;t:'f.:f'f. . . + . . IN THE COURT OF COMMON PLEAS . . . + . . :f.+;;t: ;ji'f.'f.+. *' +. 'to: '+ '+:~ + . . + . . + . . OF CUMBERLAND COUNTY STATE OF PENNA, + . . JERAMIAH D. GEYER, . . . . . + + + + + Plaintiff VERSUS AMBER J. GEYER, + + + + + n",fom']ant AND NOW, + + + . . . + . . . . + + + . + . 05-2248 CIVIL TERM No. . . + DECREE IN DIVORCE + . . + . + ~~ or ;:0/1 f.,tlt. ,(j()f, IT IS ORDERED AND . . + . . DECREED THAT Jeramiah D. Geyer , PLAINTIFF, . AND + . Amber J. Geyer , 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; . . . . . The parties' Property Settlement Agreement dated August 29, + + ++ + . . . . + . + + + + . . . . . + . + + + ATTESTL?~ J, PROTHONOTARY + +. + ... . . . :f'f'f.+. iof'f.:f;t: + ;t'+.;t: ;f:f.:f.+. . ~ f /f) ,p,y ~u, .50 rJ ~ ?~~ p1!~~;P'P 5(l'~:~ . ..' .., . '~..