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Home My WebLink About00-02080 .,." . . . ",,--- -..'. . ,-" ' . . . .. . IN THE COURT OF COMMON PLEAS . . OF CUMBERLAND COUNTY STATE OF . . ANITA LOUISE ZINN, . Plaintiff . VERSUS . . RICHARD LEE ZINN, . . Defendant . . . . . . AND NOW, . PENNA. No, 2000 - 2080 DECREE IN DIVORCE CIVIL ~B:'.?tA~ . p{ IT IS ORDERED AND -::r~l'J I f' DECREED THAT ANITA LOUISE ZINN . . AND RICHARD LEE ZINN . ARE DIVORCED FROM THE BONDS OF MATRIMONY. . . . , PLAINTIFF, DEFEN DANT, 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; NONE . . . . . . . . . . . . . . -~ B ATTE. "a ~ ~ . . . .. . J, PROTHONOTARY .. . . j~ k ~-'''''i4f . . . . . . . . . . . . . . . . . . . . . . ~ .. "",""N', ,,"'",.~" ~.<" ---. 'on ~~, ,--" "iiiIiiiiii " , " -.~.'fI- " ~ ... - } ., -{ <.-It- /1(; ~ ~- ~. ~ Ca1'~ /t(} tJ.) ~ ~'~~. ~_., ,~" .."~"' ~~ . ,_I,~:""",~.._............~~l III "'. , ,'olBWi .~~ " " .J '~ , c--J""""_ ___"J - ~.~,;" - .-J-, "'.:);,' ANITA LOUISE ZINN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - 2080 CIVIL TERM RICHARD LEE ZINN, Defendant CIVIL ACTION - LAW DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section 3301 (d) (1) of the Divorce Code. 2. Date and manner of service of the complaint: April 7, 2000, Acceptance of Service by Defendant. 3. (a) (1) Date of execution of the affidavit required by section 3301(d) of the Divorce Code: June 20, 2002; (2) Date of filing and service of the plaintiff's affidavit upon the respondent: Filed on July 2, 2002, served June 24, 2004. 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: U.S. Mail, November 24, 2004. ~'W~.~ Thomas D. Gould Attorney for Plaintiff ...: " .""'...... lI!I!!II. __~ L~~~ ,"-; '- "".~~_o_~~ - ~ -._~~;;,/ ld~iIIiIIilliIj () ,~. ~ l?t~ f?J!:r-: ~~~_i ..".--:. r'" ~'...../ )5. :c::C; 'h0 .- c:: .~ , MiIiiMIIiI'-"' "'. ""'~ "'" = ~ c.:... :..; ;;e I (,.) ""1:> ::Jl: N -. ff? ::0-1 ffl:n r- IE O. :rI ~(') bf>1 ~ :::0 -<:: '.J'l Co 1m ~ --- '....,.~ ANITA LOUISE ZINN, PLAINTIFF v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000 -.;lc;i) CIVIL TERM RICHARD LEE ZINN, DEFENDANT IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BE;EN 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 Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Court Administrator' s Office, Fourth floor, Cumberland County Courthouse, Hanover and High Streets, 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 I" , ~ . '~"~-':'. ANITA LOUISE ZINN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - ..74ft) CIVIL TERM RICHARD LEE ZINN, DEFENDANT IN DIVORCE COMPLAINT UNDER SECTION 3301(0) OR 3301(d) OF THE DIVORCE CODE IN DIVORCE l. The Plaintiff is Anita Louise Zinn who resides at 57 State Road, Mechanicsburg, Cumberland County, Pennsylvania l7055. 2. The Defendant is Richard Lee Zinn who resides at 57 State Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on February 19, 1999 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. , " ""'....~,,-'" 8. The Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 9. Plaintiff requests the court to enter a decree of divorce. L'I/J D. ~ Thomas D. Gould Attorney for Plaintiff LD. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 VERIFICATION 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 l8 Pa. C.S. 4904, relating to unsworn falsification to authorities. Date: t--\,-S-OO Um;~ Ln,JI D~ ~Unm Anita Louise Z n - '"" ~~ID;J;., ~ ANITA LOUISE ZINN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 -..2cro CIVIL TERM RICHARD LEE ZINN, DEFENDANT IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Please allow Anita Louise Zinn to proceed in forma pauDeris. I, Thomas D. Gould, referral attorney for Legal Services on behalf of Anita Louise Zinn, certify that I believe that Anita Louise Zinn is unable to pay the costs and that I am providing free legal services to Ms. Zinn. Ms. Zinn's affidavit showing her inability to pay the costs of litigation is attached hereto. Date: ~/s-~i') ~2>.~ Thomas D. Gould Attorney for Plaintiff 1. D. # 36508 2 East Main Street Shiremanstown, PA 17011 (717) 731-1461 ."'~ "" . ,'_t, 'liWillI-~,' FI~E'Not851 04/05 '00 08:40 ID:LEGAL SERVICES, INC. FAX:7172438026 PAGE 3 ANITA LOUISE ZINN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. RICHARD LEE ZlNN, : NO, - CIVIL TERM Defendant AFFIDA VIT IN SUPPORT OF PETITION FOR LEA VB TO PROCEED IN FORMA PAUPERIS 1. I am theplaintiffin the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: Anita Louise Zinn Address: 57 State Road, Mechanicsburg, PA 17055 (b) Social security Number: 209-46-0406 If you are presently employed, state Employer: N/A Address: Salary or wages per month: Type of work: If you are presently unemployed, state Date of last employment: 11/26/98 Salary or wages per month: $ 7. OO/hr Type of work: Cler,<: FILE No.851 04/05 '0008:40 ID:LEGAL SERVICES, INC. , (c) Other income within the past twelve months Business or profession: None Other self-employment: None Interest: None Dividends: None Pension and annuities: None Social Security benefits: Daughter' s Support payments: None Disability payments: None Unemployment compensation and supplemental benefits: None Workman's compensation: None Public Assistance: None Other: None (d) Other contributions to household support (~te~Husband) Name: Richard L. Zinn If your (husband) 0WiI~ is employed, state Employer: None Salary or wages per month: N/A Type of work: N/A ,"~- -- FAX:7172438026 Contributions from children: s. S. Dauqhter receives Social Security (e) Property owned Cash: None Checking Account: None Savings Account: None Certificates of Deposit: None PAGE 4 -"'""'''1 I I I I i , I , , FILE No.851 04/05 '0008:41 ID:LEGAL SERVICES. INC. , . <.-... t, 'I',~~'~ " FAX:7172438026 PAGE 5 . " Real Estate (including home): None Motor vehicle: Make None Year Cost Amount owed Stocks; bonds: None Other: (t) Debts and obligations Mortgage: Rent: $880.00 being evicted 4/7/00 Loans: Monthly Expenses: (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if anv: f: Name: Erin Kingston Age: 12 4. I understand that I have a continuing obligation to inform the court of improvement in my . : financial circumstances which would permit me to pay the costs incurred herein. .\.. .' ., S. 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. t 1 '. , -~ Date: L\- S - 00 ~k.~~MOlmm -f I f{ , " , r ,~- . , I .t- " ;!:i:illll' ,~ "'. ~ "'"--~~~lCilIfritWlid - ~......J,_ '''.-~'~A!llilII_IIl'''''J."", ,. .... ~ii ,'&" ". ,.' ~-, ~. . , ~ () C) 0 C C) -"-1 :-;::,. :::.~ :,;J -orr:; -0 . '..-n rnfT N ,.:1p Z:",:) \ ?;~ LC ~2: 01 ~C" .'"'0- 'c-.--n 2'~O ::I= (~c-?(~ L_{~, N (~)rn PC -! ~ -~, :J.J Ul "< . -"'---- ,. ,'~ ,; ~--"- ,-- '" ,,,->--,,- "-- - ANITA LOUISE ZINN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - 2080 CIVIL TERM RICHARD LEE ZINN, DEFENDANT IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on April 7, 2000 and have continued to live separate and apart for a period of at least two 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 herein are made subject to the penalties of l8 Pa.C.S. 4904 relating to unsworn falsification to authorities. Date: Y.l/J1.fl dLJ, 0 Z- I ()/)1j-b) ,l ):.~/J7/ Ani L. Zinn . oolliJ _J ~'" ~''''''''',"-, l!!I"L~, i\rWiili ~~:fJii;j <" 4- \ ~V'l_lliillitii.fi:tamIlilllW~'~. ~, ~^ ~ "'~-~ -< - _iii ., ." ,"," ~'--' o C ? "~, ~ [~~~ !l'f'i Z::rJ ~C ~~i~ c.......; " 2::t~'7 5~ ::7 :3 , -" ~:,l I I I ^~ N (- c: r- o -n ;~ --,. I. g~~ ~ -< I 1'0 " ::rf:: '~ (P ANITA LOUISE ZINN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - 2080 CIVIL TERM RICHARD LEE ZINN, DEFENDANT IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: RICHARD L. ZINN You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit. Therefore, on or after December 15, 2004, 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 counter- affidavit 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 COUNTER-AFFIDAVIT 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. Lawyer Referral Service Cumberland County Bar Association 32 Bedford Street Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 ilIlI''''''"' ""~ - fllilll"'l~iiiIiIiiIl1i''-"'' ~fj~~~~""'-""~.iiiI:IiI-i~"~'<~'~"~'<-~W.~ ~."-^~'" () c:: ;;;~ -r;U1 t;!,!fD ;;E r~'"':' (I) b ]:S: ;z: ,",0 )';;,~ .;;~};' j5;,~ ? -3 -, -0 ::Jl: N -. C.I'l ~ ,~.~'"""' -iIlRti ~ ~ c.:... ::to. ;;e , (,.) 'i? ~ Ol-.:Q r- :8[5,,[11 o :E"i"i o:n <:[:2 (J"~ {iiJ --<: 01 - ," '-,-L c' "c' """ < ANITA LOUISE ZINN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - 2080 CIVIL TERM RICHARD LEE ZINN, DEFENDANT IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both) ; (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this counter-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: RICHARD L. ZINN .-';' 1- '"^'" ,-, lli.*'~.ltiMIIIiidOJ'I' "~~...-.,,~.-..;.I""'~ilil<~ ~~~~ .V ".~ . rr't"'- f' " " ill r ~ '~ ,- t~ .'; b",,~ ._ ,. . .~ 0 '" = 0 C = -n s: "'" -elCO C- -.... rp r~~ "'"' :r: z m.:D ""- ~~. r ZC I :gfTl ~;.f' _ 0 w ~Q. ~(:.: )>,...... -0 ~~ z'(j :x 5,.::;c r:? :z: :;;;! :::< en :D 0) -< ~, ' _........~~ ~ 0" .. ANITA LOUISE ZINN, PLAINTIFF IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2000 - 1oJlO CIVIL TERM RICHARD LEE ZINN, DEFENDANT IN DIVORCE ACCEPTANCE OF SERVICE I, Riohard Lee Zinn, accept service of the Complaint In Divoroe in the above captioned matter. Dated: ~ /}-c2CJo() 7&'k~~~ Riohard Lee Z 57 State Road Mechanicsburg, PA l7055 DEFENDANT iilIi"1. ',~~" "~~~- ~&rml"'''--^''-''' ~~~,= -" ..~. ~, ~,~ '-"'A>"iii~iiiiiIWH..r~- ~iW'~- ,#JII~\ it, , ' -.~",. ". ~,-^ - "II! 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