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HomeMy WebLinkAbout06-6636 ... Holly D Geesey, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. IY. - ~~b C ~c.J~L I ~ CIVIL ACTION - LAW IN DIVORCE Douglas M Geesey, Defendant NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, 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 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 Cumberland County Courthouse, Carlisle, Pennsylvania. 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 ... Holly D Geesey, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO....QL- - ~l.,...~b 0lo\.L Douglas M Geesey, Defendant : CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Holly D Geesey, who currently resides at 128 West Portland Street, Number 7, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Douglas M Geesey who presently resides at 20 South Baltimore Street, Franklintown, York County, Pennsylvania 17323. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 30 2002, in Lancaster County, Pennsylvania. 5. parties. There have been no prior actions for divorce or annulment between the 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America. 8. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT 1 REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 9. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 10. The marriage of the parties is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to: a) enter a decree dissolving the marriage between Plaintiff and Defendant; Respectfully Submitted, Miller Lipsitt LLC By: Holly D Geesey, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Douglas M Geesey, Defendant CIVIL ACTION - LAW IN DIVORCE VERIFICATION I verify that the statements made in this Divorce Complaint 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: /6 12 f1I ~& rJtiA1'v Holly D Geesey, Plaintiff 0 (:) ~ 1 ~ -... ..c I'-.;l D c:;, 0 c..:":-;) -n c.'"' . ~y~ -"~.,.. '- ~ Vl c.") ..u;': ~ ~ \) f11 0'1 ? ~ C~. ~ --n ..,;:J ':t:> 2 .~h, '-:J ~ w ::':::..t '1;>- (.J :n C':l -< -L.. Holly D Geesey, Plaintiff v. Douglas M Geesey, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-6636 Civil Term CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE OF DIVORCE COMPLAINT I, Douglas M Geesey, Defendant in the above captioned matter do hereby on the date indicated below accept service of the divorce complaint filed by Plaintiff, Holly D Geesey, to the above term and docket. Date: November 17 2006 nt (') c::. > .."'\.} ()) lJ;q ~:::;; ~~ (i~i r;::, ~-~" r-'t <:::::> = --' ::;p;: ~ ?:' , co ~~ _i<"_" ;~.;. -0 --::;'<" ~ ::?-n P'~ -d :-, :,rJ ,/ 1~ ~,--, I ~ ~ (,n u:> Holly D Geesey, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-6636 Civil Term Douglas M Geesey, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on November 16 2006 and service was obtained upon the defendant by defendant accepting service thereof on November 17 2006. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint and service upon Defendant of the same. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. 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.A. Section 4904, relating to unsworn falsification to authorities. Date: February 19 2007 ~ = = --i ::It. ~ ?O I co -c ~t... -~ o -n .-t -r""...,-. ffi~ -l~)~~ -.:b"-i...l .~~ '?:Q ~ (J1 \.P Holly D Geesey, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-6636 Civil Term Douglas M Geesey, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 eel 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 herein in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. A. Section 4904, relating to unworn falsification of authori 'es. ~ Date: February 19 2007 o c s: -z.., Cl~'; fl~1r> Z~';l L~ . U} -'~". -::; t::;-.:: "'f:'" ;:;'-;''' S );~ 1"--' = :3 ':l!: -'"'!"'p ::0 I c:::> ~ ~-n me -{)1.':'::' -q(--' ~~(~) ~..:.- \' ~:;i.~; f;\ '::::'\ ~ :Q. -0 -<ft' -- (.1'1 ....0 Holly D Geesey, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-6636 Civil Term Douglas M Geesey, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on November 16 2006 and service was obtained upon the defendant by defendant accepting service thereof on November 17 2006. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint and service upon Defendant of the same. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling, and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I verify that the statements made in this Affidavit are true and correct. I understand that false statements her' are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to unsw n Isifica!' n~nutho ities. Date: February 192007 rift Geesey o c ~ -aCe. 1"\1\; 2.'(" 01 ~, ~ g ~ ::;t ~ 1 CP ~:' i~ "'j.;,e: ~3 -... ~ -c .-\ :I:-n [11f': -orn ":nY (~ t-? ;:;tr~ :-~ ~~ ~ > - (.)1 ..s::> Holly D Geesey, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-6636 Civil Term Douglas M Geesey, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 eel 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 herein in this affidavit are true and correct. I understand that false statements are m , subject to the penaltie of 18 Pa. C.S. A. Section 4904. relatin9to unworn falsifica on <>( authori j~/J Date: February 19 2007 ~"'VL Geesey 2 ~ ""'0 fU. ~~\T (,I~ <: ~L ...,..... _.-'- 7;:b Yi:':: ?' -, ::2. ,.....:t ~ ~ 'P'" ;tJ , co -0 ~ ~ ~-n f11 f: '"0\5 ~~~ ~? 1.""i'\ :j~;~~ '-:.-\ ~E :.<. - cf\ \.0 Holly D Geesey, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-6636 Civil Term Douglas M Geesey, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner service of the Complaint: A complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on November 16 2006 and service was obtained upon the defendant by defendant accepting service thereof on November 17 2006. 3. Date of execution of the Affidavit of Consent and Waiver of Notice of Intention Request Entry of a Divorce Decree required by Section 3301 (c) of the Divorce Code: by Plaintiff: February 19 2007 by Defendant: February 19 2007 Time Stamped date of Waiver of Notice of Intention Request Entry of a Divorce Decree required by Section 3301(c) of the Divorce Code: by Plaintiff: contemporaneously filed with the filing hereof by Defendant: contemporaneously filed with the filing hereof 4. Related claims pending: There are no related claims pending. Respectfully Submitted, o c:- -:.,,'1?' --0(7, ~......... :' ~ ,~ ; ~;;;. ,. ~(r.: ~ (;;;? ;:...J ~ ? ~;O \ cP \-<.. "}';:. q"l ..A ~':!2 -<J~) "')),"-~ .)(') ..:~ "......,~." .\.,.,'-f, ~-:~~C~ .~~~~)~ ~,2.; "?1? :~ -\:1 _'fT' -~ - U\ "" iti itiiti itiitiitiitiitiitiitiiti~~if.if. ~if.if.~if.itiif.iti if.if.~~~~if.if.if.if.if.~~if.~if.~if.if.itiif.if.~iti~if.~if.~~itiitiiti~~~~if.~~~~~~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ if. ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ iti ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ Of. ~ ~ ~ ~ ~ Of. Of. '" Of. Of. Of. '" iti Of. ~ Of. '" '" '" '" Of. Of. Of. '" '" ~ '" Of. '" '" '" Of. '" '" '" '" Of. '" '" '" '" '" '" '" '" ~~~~~~~~~T.~T.~~T.~T.~~~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Holly D Geesey Plaintiff No. 06-6636 VERSUS Douglas M Geesey Defendant DECREE IN DIVORCE AND NOW,~ (~ ,~1, IT IS ORDERED AND DECREED THAT Holly D Geesey , PLAI NTI FF, AND Douglas M Geesey , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN TH IS ACTION FOR WH ICH A FI NAL ORDER HAS NOT YET BEEN ENTERED; tJg~ By T J. , ~ -? ~vw ~ (.0, 1/ 'f: ~ ~ ~ ~ -f""l (0'1/'[' . -1 . ,.~.:.- . ,. . ..; .'-., ~,-;; t... ,I" .'.... ".".