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Home My WebLink About94-06262 r\ <~ "'~ \1) L ,~ f ",,!,I, ! , i1,- "'t i-i. , "'1 , ,.-.J.".'[ 'r ' ;,i"L',:,'" ,', ,....' .'~".::.,.::.:." .".-,r.. "L po,! It , J,\ Jr, ~;:'/i' ,1:1" -1,1.:.., 11.\'11';', ~' Of,,. , f.\.:i 'I.ttl,: ~~,I i ~n}' F:, ,:1'1' '. !~ J::. J " r) ~ ~ ~ . :r. )- . f: . , , ' . , , , IIi . 'q " " , , ',,11 , ., , ,I, ' " I,J, ," " . ,It " , , '" ,",' , , , ,I, ''''1 ,I" ,,' , i I' " .., , " ,; I" . , ,L " I,. ,t, "'t " " , , I, i I j .'i " ," I: ;!' "'lli\ " _,~';:rU,J ,', ,"'J qt I, \','\'-'j/:\ ~o.i.:r '. .4i~ "','~tl.~~ I:' :J ''-''''i.'',.il ,.:Jo&.ii:l IfO'f~ " ~ . . . - .. .. .. .. .. ... ... .. ... .. - .. .. ... .., ... ... ... .l<<. ) _ ,.,:.- ;....... ... __:_;1 . -~ - -~_,_._'~~'-~-'-_.- ~-l' , . . . . . . * . . . . . ~ . 8 . . . . . . . . . '. . . . . . , . . . . !1____._ _. ~-_... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF .. PENNA. JOSEPH GEARY N n. ..9~.~626.2 .CIVI.~.T.~R..~. 19 Vt'I';'H1:i KELLY A. GEARY I I DECREE IN DIVORCE AND NOW,. ,".an~u".'1" .t.~........ 19 9?.... it is ordered and decreed that. . . . . . . . . . . . .JO.S.E.PJ{ .G.EAR.Y. .. . . . . . . . . . . . . . ... . . . . . ., plaintiff, and............ ..."ELLy..\\..GE.\\RY..................... 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; . . . . . ~9~"... . . . ...... ..".............,............ ", ~ '" ,'-' . ~ ~ ~ :..:. I':' . ....... ..... ..~ '.<<' ..... ':'.' ..... ':..' .:<<. '.... ..... .::<<;. .:c. Dy The c~ "O~ /. Alles!: \.. f~ C:; ,'J?.J J. . ~{l.ItI.:Lt' (' ~/, ./~'AJ-A....-r7 ~ '17';' lid )/ .~& iJ (. ,.L Prothonotary '. . x..;;;-",7 . . . . . . 8 . . . . . . . . ~I . . . . . ~ . 8 . . . . M I. .. . ~ ., , " ,. " , , !A >- "" .>- ., ... 1I1 i. ..~ (.') ::;' ~ "r ,:;: <~, ,:. :.':.:.... -'1 ,'! :'i ;; co 0., , ".") I ,,-:_J"' 'Jlll~ .1;'';)1.<.; ~* .:).:~ .....:::J Qc..~, .. " 'L, J , ,. ~. .. ., ,- IE u.r; ~~... _ O:;l.":'Z N ~,;u..i li_ :J: C:) ~. N c;-)~:;~-~ ':' '" .1(,'1 ,J...y:'.:r. ......... .,)'''''.1:. 1,<,.,1',) l,~l\.. :I ~v ~. ii, ~ \0 ~.:) '0 ,,~ ....... o ..., ~ ~ -... \~\ ~ ~ t::- r1 ~ " ~ ""' ~ " l'ol ~\~ ,..J , p" p ~ (\....J '" - I z < ! ! :I i E: a 1~"'lii ~1.;~;: .5~j~ll f = f ~ = :I; ., " . - ----- -- ----.- " . . , " . . . .. JOSEPH GEARY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW I NO. q 4- ~~~;;;. (I {..AJ.-(..{_ ~ n-- v. KELLY A. GEARY, Defendant 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 ma)' 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 Court House, Carlisle, PA 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, 00 TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Fourth Floor Cumberland County Courthouse Carlisle, PA 17013 Telephone No. (717) 240 - 6200 .b~d:~ Attorney for Plaintiff HEPFORD, SWARTZ & MORGAN P . 0 . Box 889 Harrisburg, PA 17108 (717) 234-4121 . '. JOSEPH GEARY, Plaintiff IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. v. KELLY A. GEARY, Defendant IN DIVORCE COMPLAINT UNDER SECTION 33011dl OF THE DIVORCE CODE 1. Plaintiff is Joseph Geary, an adult individual who is sui juris and resides at 8633 St. Rt. 44, Ravenna, Ohio 44266. 2. Defendant is Kelly A. Geary, an adult individual who is sui juris and resides at 600 Bridge Street, New Cumberland, cumberland County, Pennsylvania. The present whereabouts of the Defendant. Kelly A. Geary, to the knowledge of the Plaintiff, is the same, 3. Defenc;iant has been a bona fide resident in the Commonwealth of pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 10. 1981, in Cumberland County, Pennsylvania. 5. There was a prior action of divorce between the parties instituted on May 19, 1987, instituted in York County, Pennsylvania, docketed to No. 87SU01979-02D. This action was . . . . stricken by York County Court of Common Pleas in 1990 for inactivity. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff avers that the grounds on whi~h the action is based is that the parties hereto have lived separate and apart for a period in excess of seven (7) years since May of 1987, and that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the Court to enter a Decree: A. Dissolving the marriage between Plaintiff and Defendant; and B. For such further relief as the Court may determine equitable and just. HEPFORD, SWARTZ & MORGAN By: ~"' ~~//~-W -, San ra L. Me ton - P.O. Box 889 Harrisburg, PA 17108 (717) 234-4121 Attorneys for Plaintiff , . . , '. ..' I, JO..ph Go'''' .C'OOW1.... tI.-t t"" "ct. .t.... '0 t"" withiO docOmoot .,. "U. .0' CO".Ct to t"" .... of ..., knowledge, information and belief. VERIFICATION I uo..,.t.od th.t .oy f.1.' .t.t...ot. h.'.'o .'. .... subj.ct to tho p...,t'.' of " ...C." ..0t'00 .,0' ,.,.t'O' to unsworn falsification to authorities. DATED: "25 L),; f'/ .' . .' .' " JOSEPH GEARY, Plaintiff I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE v. KELLY A. GEARY, Defendant NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counteraffidavit within twenty day. after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(dl OF THE DIVORCE CODE NOTICE 1. The parties to this action separated in May, 1987 and have continued to live separate and apart for a period in excess of seven 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 Complaint are true and correct. 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. Date: ~5 O.:..} 17/ s p Gearr~itt~ JOSEPH GEARY, Plaintiff IN THE COURT OF COMMON PLEAS I CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 94-6262 Civil Term v. KELLY A. GEARY, Defendant IN DIVORCE NOTICE OF INTENTION TO REOUEST ENTRY OF DIVORCE DECREE TO: Kelly A. Geary, Defendant You have been sued in an action for divorce. You have failed to answer the complaint or file a counteraffidavit to the plaintiff's affidavit. Therefore, on or after January 5, 1995, the plaintiff can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counteraffidavit by the above date, the court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTERAFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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. Court Administrator Fourth Floor Cumberland County Courthouse Carlisle, PA 17013 Telephone No. (717) 240-6200 . JOSEPH GEARY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION - LAW v. KELLY A. GEARY, Defendant NO. 94-6262 Civil Term 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(d) of the Divorce Code. 2. Date and manner of service of the complaint: November 18, 1994, certified mail. 3 . (1) Date of execution of Plaintiff's affidavit required by Section 3301(d) of the Divorce Code: October 25, 1994; (2) Date of service of Plaintiff's affidavit upon the Defendant: November 18. 1994, certified mail. 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under Section 3301 (d) (1) (i) of the Divorce Code. U.S. mail. mailed on December 14. 1994 to Defendant. . ,,,_....~;....... Dated:/A-/<(- 9'1 Sandra L. Meilton, Attorney for Plaintiff Ii , . . ",' " " , 1.1 . CERTIFICATE OF SERVICE U.fPl n / AND NOW, this 17 day of } J"u''''.!t.VA... , 1994, I, Gloria M. Rine, Legal Assistant to Sandra L. Meilton, Esquire, for the firm of Hepford, Swartz & Morgan, hereby certify that I have this day served a copy of the Notice of Intention to Request Entry of Divorce Decree and a copy of the Praecipe to Transmit Record, along with a blank form of Defendant's Counter-Affidavit under Section 3301(d) of the Divorce Code, by mailing same by first class mail, postage prepaid, addressed as follows: Mrs. Kelly A. Geary 600 Bridge Street New Cumberland, PA 17070 ~,'jzL G or a M. 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