The Law Office of Maryann Q. Modesti, P.C.
By: Maryann Q. Modesti, Esquire
Attorney I.D. No. 34700
790 Penllyn Pike, Suite 100
P.O. Box 820
Blue Bell, Pennsylvania 19422
(215) 283-5055
Attorney for Plaintiff
IN THE COURT OF COMMON PLEAS OF
DELAWARE COUNTY, PENNSYLVANIA
LINDA TRIMBLE NO. 2024-011112
Plaintiff
vs.
JOHN WALTER HENNON
Defendant IN DIVORCE
NOTICE OF INTENTION TO FILE PRAECIPE TO TRANSMIT
RECORD UNDER SECTION 3301(d) OF THE DIVORCE CODE
TO: Defendant, JOHN WALTER HENNON
You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the Affidavit to Establish Presumption of Consent under Section 3301(c)(2) of the Divorce Code or the Affidavit under Section 3301(d) of the Divorce Code. Therefore, on or after January 2, 2026, the other party can request the court to enter a final decree in divorce or, if there are unresolved ancillary claims, an order approving grounds for divorce as indicated on the proposed Praecipe to Transmit Record, which is attached.
If you do not file an answer with your signature notarized or verified by the above date, the court can enter a final decree in divorce or, if there are unresolved ancillary claims, an order approving grounds for 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 or an order approving grounds for divorce and you may lose forever the right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims.
YOU SHOULD TAKE THE PAPER TO YOUR LAWER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICE TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
LAWYER REFERENCE SERVICE
FRONT AND LEMON STREET
MEDIA, PA 19063
(610) 566-6625
Maryann Q. Modesti, Esquire
By:_____________________________
Date: December 12, 2025
December 12 2025
LGSC0415161