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HomeMy WebLinkAbout06-0435BENJAMIN T. GEOGHAN, Plaintiff V. HEATHER A. GEOGHAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Odo - 42S CIVIL ACTION - LAW IN DIVORCE NOTICE 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 judgement may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at: The Office of the Prothonotary, Dauphin County Courthouse, Front and Market Streets, Harrisburg, Pennsylvania 17101. 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, PENNSYLVANIA 17013 (717) 249-3166 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 BENJAMIN T. GEOGHAN, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. HEATHER A. GEOGHAN, CIVIL ACTION -LAW Defendant IN DIVORCE NOTICIA LE HAN DEMANDADO A USTED EN LA CORTE. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar Una apariencia escrita o en persona o por abogado y archivar en la Corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la Corte tomaro medidas y puede entrar Una orden contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en la petition do demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX(717)236-2817 BENJAMIN T. GEOGHAN, Plaintiff V. HEATHER A. GEOGHAN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. OL - q-qS CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) or (D) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Benjamin T. Geoghan by and through his attorneys, Meyers, Desfor, Saltzgiver & Boyle and tiles the following Complaint in Divorce and in support thereof avers as follows: 1 2 3 4 5. 6. 7. 8. Plaintiff is Benjamin T. Geoghan an adult individual who currently resides at 234 Birch Lane, Carlisle, Pennsylvania. Defendant is Heather A. Geoghan an adult individual who currently resides at 493 State Street, Enola, Pennsylvania. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. The Plaintiff and Defendant were married on June 27, 1998 in Fort Ritchie, Maryland. There have been no prior actions of divorce or annulment between the parties. The marriage is irretrievably broken. The Defendant is not a member of the United States Army or its allies. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request the court require the parties to participate in counseling, being so MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717)236-9428 • FAX(717)236-2817 advised, Plaintiff waives that right. 9. Plaintiff requests the Court to enter a Decree of Divorce pursuant to Section 3301(C) or 3301(D) of the Divorce Code. WHEREFORE, Plaintiff, Benjamin T. Geoghan, respectfully requests this Honorable Court enter a Decree in Divorce pursuant to Section 3301(C) or 3301(D) of the Divorce Code. Respectfully submitted, Catherine A. Boyle, Esquire MEYERS, DESFOR, SALT IVER & BOYLE Attorney I.D. 976328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for Plaintiff 4 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 VERIFICATION I, Benjamin T. Geoghan , verify that the statements made in this Complaint in Divorce 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. Section 4904, relating to unsworn falsification to authorities. Dated: 1/19/2006 X) Plaintiff ( ) Defendant MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236 2817 n ? ? ? ? - `? d ,..z `? w ??' ?`-- C.. BENJAMIN T. GEOGHAN, Plaintiff vs. HEATHER A. GEOGHAN, Defendant NO. 06-435 CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE OF COMPLAINTINDIVORCE I, Edward F.V. Pietrowski, Esquire, counsel for Heather A. Geoghan, defendant in the above-captioned matter, hereby certify that I have accepted service of Complaint in Divorce on behalf of Heather A. Geoghan which was filed by plaintiff, Benjamin T. Geoghan to the above term and number and that I am authorized to do so. Date b0 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA 97. Edward F.V. Pietrwowski, Esquire PIETROWSKI & PIETROWSKI, P. C. 116 North Washington Avenue Suite 3-B, Kane Building Scranton, PA 18503-1812 Attorney ID# 19614 Attorney for Defendant, Heather A. Geoghan c ?, o , n r BENJAMIN T. GEOGHAN, Plaintiff/Counterclaim Defendant VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-435 Civil Term HEATHER A. GEOGHAN, CIVIL ACTION - LAW Defendant/Counterclaim Plaintiff IN DIVORCE NOTICE 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 Defendant/Counterclaim Petitioner. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, ATTORNEY'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, PENNSYLVANIA 17013 1-800-990-9108 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland 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 our office. 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. PIETROWSKI & PIETROWSKI, P.C. Date: Z 3 / B ward F.V. Pie owski, Esquire Attorney for Defendant/Counterclaim Plaintiff 116 N. Washington Avenue Suite 2J Scranton, PA 18503 Telephone: (570) 344-9633 Fax: (570) 344-9635 Email: pietrowskilawz@,verizon.net Attorney ID# 19614 BENJAMIN T. GEOGHAN, IN THE COURT OF COMMON PLEAS Plaintiff/Counterclaim Defendant : CUMBERLAND COUNTY, PENNSYLVANIA VS. HEATHER A. GEOGHAN, Defendant/Counterclaim Plaintiff NO. 06435 Civil Term CIVIL ACTION - LAW IN DIVORCE ANSWER AND COUNTERCLAIM TO COMPLAINT IN DIVORCE UNDER SECTION 3301(C) OR (D) OF THE DIVORCE CODE AND NOW, comes defendant/counterclaim plaintiff, Heather A. Geoghan, by and through her attorneys, Pietrowski & Pietrowski, P.C., and hereby answers the Complaint in Divorce filed by plaintiff/counterclaim defendant, Benjamin T. Geoghan and counterclaims as follows: ANSWER TO COMPLAINT IN DIVORCE 1. Admitted. At the time of the filing of the Complaint, the plaintiff/counterclaim defendant, Benjamin T. Geoghan did reside at 234 Birch Lane, Carlisle, Pennsylvania. However, at the time of the filing of this Answer, the Plaintiff/Counterclaim Defendant is residing at 326 Walnut Lane, Carlisle, Cumberland County, Pennsylvania. 2. Admitted. It is admitted that the defendant/counterclaim plaintiff Heather A. Geoghan is an adult and competent individual currently residing at 493 State Street, Enola, Cumberland County, Pennsylvania. 3. Admitted. It is admitted that both the Plaintiff/Counterclaim Defendant and the Defendant/Counterclaim Plaintiff have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately preceding the filing of the Complaint as well as this Answer and Counterclaim. 4. Admitted. It is admitted that the Plaintiff/Counterclaim Defendant and the Defendant/Counterclaim Plaintiff were married on June 27, 1998 in Fort Ritchie, Maryland. 5. Admitted. The current action is the only action of divorce or annulment between the parties. 6. Admitted. It is admitted that the marriage is irretrievably broken. 7. Admitted. It is admitted that the Defendant/Counterclaim Plaintiff is not a member of the United States armed forces or its allies. 8. Defendant/Counterclaim Plaintiff, Heather A. Geoghan has been advised that marriage counseling is available and that she may have the right to request this Honorable Court to require the parties to participate in counseling. 9. Neither admitted nor denied. WHEREFORE, defendant/counterclaim plaintiff, Heather A. Geoghan respectfully requests that this Honorable Court dismiss the Complaint In Divorce filed by plaintiff/ counterclaim defendant, Benjamin T. Geoghan. COUNTERCLAIM IN DIVORCE 10. Defendant/Counterclaim Plaintiff, Heather A. Geoghan, incorporates by reference her answers to Paragraphs 1 through 9 inclusive as though the same were set forth herein at length. 11. Defendant/Counterclaim Plaintiff avers that in violation of their marriage vows plaintiff/counterclaim defendant, Benjamin T. Geoghan has offered such indignities to Defendant/Counterclaim Plaintiff, the injured and innocent spouse, so as to render her condition intolerable and her life burdensome. 12. Defendant/Counterclaim Plaintiff avers that this allegation is not made out of levity nor collusion between the parties but in sincerity and truth for the causes mentioned herein. COUNT II - DIVORCE - 3301(d) 13. Defendant/Counterclaim Plaintiff, Heather A. Geoghan, incorporates by reference Paragraphs 1 through 12 inclusive as though the same were set forth herein at length. 14. Defendant/Counterclaim Plaintiff avers that the parties to this action separated on June 14, 2005 and have continued to live separate and apart for a period of at least two (2) years and that the marriage is irretrievably broken. 15. Defendant/Counterclaim Plaintiff requests that this Honorable Court enter a decree of divorce. COUNT III - EQUITABLE DISTRIBUTION 13. Defendant/Counterclaim Plaintiff incorporates herein Paragraphs 1 through 12 as though the same were set forth herein at length. 14. During the course of their marriage, the parties have acquired marital property which is subject to equitable distribution under the Divorce Code. Defendant/ Counterclaim Plaintiff requests that this Honorable Court enter an Order disposing of the said property rights and interests of the parties. COUNT IV - COUNSEL FEES, EXPENSES & COSTS 15. Defendant/Counterclaim Plaintiff incorporates herein Paragraphs 1 through 14 as though the same were set forth herein at length. 16. Defendant/Counterclaim Plaintiff has been required to seek legal counsel and incur legal expenses to protect her rights in this matter and does not have sufficient funds to pay the same. Plaintiff/Counterclaim Defendant, Benjamin T. Geoghan has sufficient funds to pay for Defendant/Counterclaim Plaintiffs counsel fees, expenses, and costs and this Honorable Court is requested to require Plaintiff/Counterclaim Defendant to pay the same. WHEREFORE, the defendant/counterclaim plaintiff, Heather A. Geoghan, prays that this Honorable Court grant the following relief: A. Enter a Decree in divorce dissolving the marriage of the parties pursuant to Section 3301(c) of the Divorce Code; B. ® Enter a Decree in divorce dissolving the marriage of the parties pursuant to Section 3301(d) of the Divorce Code; C. ® Equitable distribution of all property acquired by the parties during their marriage; D. ® Reasonable Counsel fees, expenses, and costs; E. ® Such other relief as the Court may deem fit. Respectfully submitted, Pietrowski & Pietrowski, P.C. Date: BY: ward F.V. owski, Esquire Attorney for Defendant/Counterclaim Plaintiff 116 N. Washington Avenue Suite 2J Scranton, PA 18503 Telephone: (570) 344-9633 Fax: (570) 344-9635 Email: pietrowskilawz@,verizon.net Attorney ID# 19614 BENJAMIN T. GEOGHAN, IN THE COURT OF COMMON PLEAS Plaintiff/Counterclaim Defendant : CUMBERLAND COUNTY, PENNSYLVANIA VS. HEATHER A. GEOGHAN, Defendant/Counterclaim Plaintiff NO. 06-435 Civil Term CIVIL ACTION - LAW IN DIVORCE VERIFICATION I, Heather A. Geoghan verify that I am the defendant/counterclaim plaintiff in the above- captioned matter and that the plaintiff/counterclaim defendant, Benjamin T. Geoghan is not a member of the Armed Forces of the United States of America. I further verify that the statements made in the foregoing Answer to Complaint in Divorce and Counterclaim are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. Date: He er A. Geoghan, defen counterclaim VV plainti BENJAMIN T. GEOGHAN, IN THE COURT OF COMMON PLEAS Plaintiff/Counterclaim Defendant : CUMBERLAND COUNTY, PENNSYLVANIA vs. HEATHER A. GEOGHAN, Defendant/Counterclaim Plaintiff NO. 06-435 Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT TO COMPLY WITH RULE 1920.45(D)(1) INDICATING AWARENESS AND AVAILABILITY OF MARRIAGE COUNSELING I, Heather A.Geoghan, being duly sworn according to law, deposes and says that I am the defendant/counterclaim plaintiff in the above divorce matter, which was filed in accordance with Section 3301(c) of the Divorce Code, and that I am aware of the availability of marriage counseling as provided by the Divorce Code, and does not wish to obtain or secure the same. Date: ?-z (3 fo? He ther A. Geoghan, de en t/counterclaim plain iff Sworn to and subscribed before me, a Notary Public, this 13s' day of February, 2009. ?gotary Public ?TH OF PENNSYLVANIA 1&ftfW Saw EdwOrd F. V. PWOwSW NOWY PubMc ion Ex?, NOV. 30.1012 Assod? BENJAMIN T. GEOGHAN, Plaintiff/Counterclaim Defendant VS. NO. 06-435 Civil Term HEATHER A. GEOGHAN, CIVIL ACTION - LAW Defendant/Counterclaim Plaintiff IN DIVORCE AFFIDAVIT I, Heather A. Geoghan, the defendant/counterclaim plaintiff in the above matter state that: There are no children born of this marriage who are now under the age of eighteen (18) years of age. X The following children born of this marriage is presently under the age of eighteen (18) years: B.T.R.G. (d.o.b.10/21/98) M.A.G. (d.o.b.04/24/01) S.P.G. (d.o.b.04/24/01) I verify that the above-statements are true and correct, and are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unworn falsification to authorities. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Hea er A. Geo an, defend counterclaim plaint ?\ Q ti7 n ? ~`b 1 Q?h ?7 C'? ra ? ni ?? ? -. k T'1 .. ? ? BENJAMIN T. GEOGHAN, Plaintiff/Counterclaim Defendant vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-435 Civil Term HEATHER A. GEOGHAN, CIVIL ACTION - LAW Defendant/Counterclaim Plaintiff IN DIVORCE NOTICE TO PLAINTIFF/COUNTERCLAIM DEFENDANT IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY (20) DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE DEEMED ADMITTED. DEFENDANT/COUNTERCLAIM PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on June 14, 2005 and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. 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. I verify that the statements made in this Affidavit are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. -?-z 1) Date: 3 f 0 (? Heather A. Geo an, def t/ counterclaim plaintiff n ?. .o ? ? . ,, ,_ N ;?"' :?µ ? BENJAMIN T. GEOGHAN, IN THE COURT OF COMMON PLEAS Plaintiff/Counterclaim Defendant CUMBERLAND COUNTY, PENNNSYLVANIA VS. NO. 06-435 Civil Term HEATHER A. GEOGHAN, CIVIL ACTION - LAW Defendant/Counterclaim Plaintiff IN DIVORCE PROOF OF SERVICE I, Barbara A. Arens, legal secretary for the law firm of Pietrowski & Pietrowski, P.C., hereby affirm that I did serve a true and correct copy of Answer and Counterclaim to Complaint in Divorce Under Section 3301(c) or (d) of the Divorce Code upon the plaintiff/counterclaim defendant, Benjamin T. Geoghan, 326 Walnut Lane, Carlisle, PA 17015-7821 by United States certified mail, number 7007 0220 0002 7647 9788, return receipt requested, postage prepaid at Scranton, PA this 24t` day of February, 2009. -2)D? c.,.,ti, .??' Barbara A. Arens Legal Secretary (Domestic Mad (1),11V No insurance C •. .. overage co N 1 L U S E r` - -0 Postap S / f2.70 ;11 Q Certlfled Fee ru tmark % O $2.20: ps Here r3 (Erdorsemart Rewired) O Restrlcled DeNvery Fee $0.00 C3 (Endorsement ReQuired) rU 07 $6 02 ' XU Total Postage & Fees . $ O serit Benjamin Geoghan p !*tr A W; r%- or POB"No. 326 Walnut Lane - ------------------------------------- -------------------------- Carlisle ----------- cny srao?.z?wa PA 17015-7821 , ALEa-OF KBE OF THE PROTHONOTARY 2009 MAY -6 PH 1: 23 BENJAMIN T. GEOGHAN, IN THE COURT OF COMMON PLEAS Plaintiff/Counterclaim Defendant : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 06-435 Civil Term HEATHER A. GEOGHAN, CIVIL ACTION - LAW Defendant/Counterclaim Plaintiff IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY DIVORCE DECREE TO: Benjamin T. Geoghan 326 Walnut Lane Carlisle, PA 17015 Heather A. Geoghan, defendant/counterclaim plaintiff, intends to file with the Court the attached Praecipe to Transmit Record on or after May 5, 2009 , requesting that a final decree in divorce be entered. Pietrowski & P' wski, P.C. BY: ?,. Edward F.V. Pietrowski, Esquire I Attorney for Defendant/Counterclaim Plaintiff 116 N. Washington Avenue Suite 2J Scranton, PA 18503 Telephone: (570) 344-9633 Fax: (570) 344-9635 Email: tnietrowskilawz(a,verizon.net Attorney ID# 19614 OF THE PROTH,0NOTARY 2009 MAY - 6 PM 1: 2 3 CUP,r BENJAMIN T. GEOGHAN, IN THE COURT OF COMMON PLEAS Plaintiff/Counterclaim Defendant : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 06-435 Civil Term HEATHER A. GEOGHAN, CIVIL ACTION - LAW Defendant/Counterclaim Plaintiff IN DIVORCE AFFIDAVIT OF CONSENT 1. The parties to this action separated on June 14, 2005 and continued to live separate and apart for a period of at least two years. 2. The marriage of the Plaintiff and Defendant is irretrievably broken. 3. 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. 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 S-9- Oct 7d,, 1,#?? "Mh6a4 Heather A. Geoghan, de dant/ counterclaim plainti f FILED-OFFICE OF THE P?07-'")NIOTARY 2009 MAY -6 Pli 1: 23 culvac; D,lN,2 x I2VANlA BENJAMIN T. GEOGHAN, IN THE COURT OF COMMON PLEAS Plaintiff/Counterclaim Defendant : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 06-435 Civil Term HEATHER A. GEOGHAN, CIVIL ACTION - LAW Defendant/Counterclaim Plaintiff IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(d) OF THE DIVORCE CODE 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 unworn falsification to authorities. Date 5- 5' -0g -ki He they A. Geoghan, de dant/ counterclaim plaintiff OF TH5 PqOT ''n',IOTARY 1009 MAY --b Pti 1: 23 GUS k P lJNS",, Lk,VV°J?A BENJAMIN T. GEOGHAN, Plaintiff/Counterclaim Defendant vs. HEATHER A. GEOGHAN, Defendant/Counterclaim Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-435 Civil Term CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO: PROTHONOTARY: Please transmit the record, together with the following information to the Court for entry of a Divorce Decree under Section 3301 (d) of the Divorce Code. 1. A Complaint in Divorce was filed by Plaintiff/Counterclaim Defendant on January 23, 2006. 2. The Defendant/Counterclaim Plaintiff is aware of the availability of counseling which was averred: In Defendant/Counterclaim Plaintiff's Complaint for Divorce (Pa. R.C.P. 1920.12 (a)(8)1 ®Yes 3. Defendant/Counterclaim Plaintiff's Affidavit and Notice Under Section 3301 (d) was filed on February 13, 2009 4. Plaintiff/Counterclaim Defendant's Counter-Affidavit Under Section 3301(d) stating that he is unopposed to the entry of a divorce decree and that he does not wish to make any claims for economic relief was filed on Plaintiff/Counterclaim Defendant has refused to file any paperwork in this matter. 5. Two (2) copies of Vital Statistics were filed on February 13, 2009 with the Answer and Counterclaim in Divorce. 6. Proposed Decree in file ®Yes FjNo 7. There are no monies being held in escrow in the event that a Master is needed for this Divorce proceeding. 8. Related claims pending: None 9. The surcharge for the Children' Trust Fund has not been paid. Respectfully submitted: Date: 5-'5- - Oq Pietrowski & Pietrowski, P.C. BY. dward F.V. I?towski, Esquire Attorney for Defendant/Counterclaim Plaintiff 116 N. Washington Avenue Suite 2J Scranton, PA 18503 Telephone: (570) 344-9633 Fax: (570) 344-9635 Email: pietrowskilawz&verizon.net Attorney ID# 19614 FILED-OF'F CE OF THE PROTHONOTARY 2009 MAY -6 PM 1: 24 Benjamin T. Geoghan IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Heather A. Geoghan NO. 06-435 Civil Term DIVORCE DECREE AND NOW, GL /d , 400q , it is ordered and decreed that Benjamin T. Geoghan plaintiff, and Heather A. Geoghan , 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.") By the Court, .\-? ?_a Attest: J. rothonotary ? ? `?? ?yiGL? . 1 ? r o9 ? ?r .? ,? ?, ???' ...?- 1? °D? `?'l ? , ?, '-?.? ..