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KAREN ELIZABETH GEIDEL,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION . LAW
96-379 CIVIL TERM
VIRGIL EVEREIT GEIDEL,
DEFENDANT
IN DIVORCE
PRAECIPE TO REINSTATE
TO: PROTHONOTARY
Please reinstate the Complaint filed in the above-captioned matter,
Respectfully submitted,
IRWIN, McKNIGHT & HUGHES
By: J
Re ecca R. Hughes, E
60 West Pomfret Stree
Carlisle, PA 17013
Supreme Court 1.0. No: 67212
717-249-2353
Attorney for the Plaintiff,
'Karen Elizabeth Geidel
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KAREN ELIZABETH GEIDEL,
PlalntllT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACI'ION - LAW
96- J2L CIVIL TERM
IN DIVORCE
VIRGIL EVERE'IT GEIDEL,
Defendant
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 actien, 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, Ajudgment 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 in the Office of the
Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania 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 mGHT 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.
Court Administrator
Cumberland County Courthouse
I Courthouse Square, 4th Floor
CarliSle, Pennsylvania 17013
717-249-6200
KAREN ELIZABETH GEIDEL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
v.
.
.
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
96- CIVIL TERM
VIRGIL EVERETI GEIDEL,
Defendant IN DIVORCE
COMPLAINT ~ DIVORCE PURSUANT TO SECTION 330tCs}
OF THE DIVORCE CODE
NOW comes the plaintiff, Karen Elizabeth Geidel. by her attorney, Marcus A. McKnight,
lll, Esquire, and files this complaint in divorce against the defendant, Virgil Everett Geidel,
representing as follows:
1. The plaintiff is Karen Elizabeth Geidel, an adult individual residing at 428 First Street,
Carlisle, Cumberland County, Pennsylvania 17013.
2, The defendant is Virgil Everett Geidel, an adult individual residing at 178 Red Tank
Road, Boiling Springs. Cumberland County, Pennsylvania 17007,
3, The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six
months prior to the filing of this action in divorce,
4, The plaintiff and the defendant were married on September 20, 1986 in Carlisle,
Pennsylvania.
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S, There were three children born to this marriage,
6. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon
which this action is based that the marriage between the parties is irretrievably broken,
7, The plaintiff avers that he has been advised of the availability of counseling and that
said party has the right to request that the court require the parties to participate in counseling.
WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two
parties,
I verity that the facts contained herein are true and correct. I understand that false
statements herein made are subject to the penalties of 18 Pa, C, S. Section 4904 relating to
unsworn falsification to authorities.
~<Jv'W\\ tlt/'O_ru.:t~ .):lu.clll
KA EL~BETH GEIDEL, Plaintiff
~
January I~~. 1996
60 mfret Street
Carlisle, Pennsylvania 17013
(717) 249-2353
Supreme Court ID No. 25476
, .
KAREN ELIZABETH GEIDEL,
PlalntllT
: IN THE COURT OF COMMON PLEAS OF
.
.
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION. LAW
96 - CIVIL TERM
VIRGIL EVERETf GEIDEL,
Defendant IN DIVORCE
PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT
The plaintiff, being duly sworn according to law, deposes and says:
1. 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.
2, I understand that the court maintains a list of marriage counselors in the Prothonotary's
Office, which list is available to me upon request.
3, 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.
I verifY that the statements made in this affidavit are true and correct. I understand that
false statements herein made are subject to the penalties of 18 Pa. C,S, Section 4904 relating to
unsworn falsification to authorities.
January \~'\\... 1996
~Q,'lisi\ (h~tJQ.~\\, j~clLl
KAREN EL BETH GEIDEL, Plaintiff