HomeMy WebLinkAbout00-06136
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
-
"'0 -
,.
',",,-,--, "'~
-'-,"-
,
. .
.
. .
...
. .
Of. '" "''''
.
.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
PENNA.
CHERYL MARCHI-ZEIGLER,
Plaintiff
No. 00 - 6136 Civil
VERSUS
EDWIN D. ZEIGLER, II
Defendinit
DECREE IN
DIVORCE
AND NOW,
/1?tVUc
"7
z-,O/ , IT IS ORDERED AND
DECREED THAT
Cheryl Marchi-Zeigler
, PLAINTIFF,
AND
Edwin D. Zeigler, II
, 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;
Nilli
ATTEST:
(:?~~
PROTHONOTARY
.
.
'" '" '" "''''
. . .
. .
. .
'1Il,,1
..
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
J.
.
.
.
.
.
.
.
.
.
.
.
,
.
. <.",C<c'.".'""" .'''..CC"...~.dC..
.~ '. _. .,"
- ,-
J -<;'-t)f
3 -~.tJ(
"~' ",,;. "d-._.,,' -'i'" ,,' ,~
< '. Ii ~- ~ t
. .to ~""""
tlvl ~ ~-zj; dl
71/& ~ -J; dfI.
r'_
-""''''".,
"1J!!!!I!!l,,''!''''''''
. c ._.~
=",--
, I".'. "
'-~-'-'-"-IIli_";,
$' II"
,
CHERYL MARCHI-ZEIGLE:R,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
v.
NO.
01- (o13G, L'\vl/
EDWIN D. ZEIGLER, II,
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 ~ 3301 ( c) of the
Divorce Code.
2.) Date and manner of service of the complaint: a true and correct copy of
the Complaint of Divorce was served upon the Defendant, Edwin D.
Zeigler, II on or about September 15th, 2000 by certified mail, retum
receipt requested. Attached hereto, marked as Exhibit "1>\' and
incorporated herein by reference is the return receipt card fQr said service.
3.) Date of execution of the affidavit of consent required by ~ 3301
-
h~_ "lilI!iWililliNi
't.
> '
( c) of the Divorce Code: by Plaintiff, Cheryl Marchi-Zeigler, by Defendant,
Edwin D. Zeigler, II.
4.) Related claims pending: There are no related claims pending for either
the Plaintiff, Cheryl Marchi-Zeigler, or the Defendant, Edwin D. Zeigler, II.
5.) Date Plaintiff's Waiver of Notice was filed with the Prothonotary: The
!)~adayof ~
of the year 2000.
Cc: Cheryl Marchi-ZeiglAr !J1 i" ,)I)
1772 South Meado;Driv'e""'T
Mechanicsburg, PA 17055-5189
Edwin D. Zeigler, II
1'7'72 South Meadow Drive
Mechanicsburg, PA 17055-5189
~r#/
I"""';" ~.L:~.' ,;;.. '~:,
,,--, '3 , ^
.'.,,- i'ili>l~.o...~"";"';"-""""T~'"
~,,:it:J..~~Iilf.~~
.- ~" '
-."
. ',",,' ~,.' ,..~'-
,.",
..A=~
". C._,,...
p'""-,,,", .. . _III
o
c::
~;:.
-oC;:::'
~S~\
?Q?:L
r.::C'
)3:' ~"
zC
....,0
yC=.
Z
-i
-<;
.." .~
.," ,,'~ M<"" ~_~.~, _ _~ ".
',...--
--r,
Gj
1'0
_1
l.g
r>0
.t
,
jii
~j
Ri
"
"']
~
~.
i
~
q
~
( ~
I
;---=;
~
~
- ,~ ~
~--....
~~
'"~--
""'~ . ifa'
..
,
.
CHERYL MARCHI-ZEIGLER,
Plaintiff
v.
IN THE COURT OF COMMO~ PLEAS OF
CUMBERLANDCOUNTY, PENNSYLVANIA
No. 00- 4,/3l.. C,'tJ~L~~
EDWIN D. ZEIGLER, II
Defendant
CIVIL ACTION - LAW
IN DIVORCE AND CUSTODY
NOTICE
TO: Edwin D. Zeigler, II
1772 South Meadow Drive
Mechanicsburg, PA 17055
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 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.
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 at the Cumberland County Courthouse, One Courthouse Square, 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 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
Document #: 181497.1
-
..._~
~ ~. ~~~L
."
i '-~"'"''''illli\'
~
,
"
CHERYL MARCHI-ZEIGLER,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLANDCOUNTY, PENNSYL V ANlA
No. tHJ- (.,/3(.. C,U;J. 7~
EDWIN D. ZEIGLER, II
Defendant
CIVIL ACTION - LAW
IN DIVORCE AND CUSTODY
COMPLAINT IN DIVORCE AND FOR CUSTODY
1. The Plaintiff is Cheryl Marchi-Zeigler, an adult individual currently residing at
1772 South Meadow Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055 since
1997.
2. The Defendant is Edwin D. Zeigler, II, an adult individual who currently
resides at 1772 South Meadow Drive, Mechanicsburg, Cumberland County, Pennsylvania,
17055 since 1997.
COUNT I - IN DIVORCE
3. The Defendant has been a bona fide resident in 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 October 8, 1983 in
Mechanicsburg, Cumberland County, Pennsylvania.
5. Neither Plaintiff nor Defendant is in the military or naval service of the United
States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of
Congress of 1940 and its amendments.
6. There have been no prior actions of divorce or for annulment between the
parties.
Document #: 181497.1
m_ ~_~,.I
.,
.-
-.,-, -.
,,~
~,
~
..
7. Plaintiff has been advised that counseling is available and that Plaintiff may have
the right to request that the Court require the parties to participate in counseling.
8. Two children were born of the marriage, Tyler D. Zeigler, d.o.b. 7/8/84 and
Nicole M. Zeigler, d.o.b. 1/8/88.
9. The marriage is irretrievably broken.
10. Plaintiff requests the Court to enter a Decree in Divorce divorcing Plaintiff and
Defendant.
WHEREFORE, Plaintiff request that this court enter a Decree in Divorce, and
such other orders as are appropriate.
COUNT II - IN CUSTODY
11. Plaintiff seeks custody of the following children:
Name
Tyler D. Zeigler
Nicole M. Zeigler
Present Residence
with Plaintiff
with Plaintiff
Al!e
16 (d.o.b. 7/8/84)
12 (d.o.b. 1/8/88)
The children were born during the marriage of Plaintiff and Defendant and the children
are presently in the custody of Plaintiff who resides at 1772 South Meadow Drive,
Mechanicsburg, Cumberland County, Pennsylvania, 17055.
During the past five (5) years, the children have resided with the following persons and
at the following address:
Plaintiff and Defendant - 1772 South Meadow Drive, Mechanicsburg, Pennsylvania
1995 - Present.
Document #: 181497.1
-
~~~ .
.
L_
. "'"""--"""'l!;1i;
~
,
~
The mother of the children is Cheryl Marchi-Zeigler currently residing at 1772 South
Meadow Drive, Mechanicsburg, Pennsylvania.
She is married to Defendant.
The father of the children is Edwin D. Zeigler, II currently residing at 1772 South
Meadow Drive, Mechanicsburg, Pennsylvania.
He is married to Plaintiff.
12, The relationship of Plaintiff to the children is that of natural mother. The
Plaintiff currently resides with the following persons:
~
Defendant
Tyler D, Zeigler
Nicole M. Zeigler
Relationship
Husband
Son
Daughter
13. The relationship of Defendant to the children is that of natural father. The
Defendant currently resides with the following persons:
Name
Cheryl Marchi-Zeigler
Tyler D. Zeigler
Nicole M. Zeigler
Relationship
Wife
Son
Daughter
14. Plaintiff has not participated as a party or witness, or in another capacity, in
other litigation concerning the custody of the children in this or another court.
Plaintiff has no information of a custody proceeding concerning the children
pending in a court of this Commonwealth or any other state.
Document #: 181497.1
-.
,
"
-~"~ ~"' "......=
,~ ' .0 .
"'C"-'_"_~
..
..
Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the children or claims to have visitation rights with respect to the children.
15. The best interest and permanent welfare of the children will be served by
granting primary legal and physical custody to Plaintiff.
16. Each parent whose parental rights to the children have not been terminated and
the person who has physical custody of the children have been named as parties to this action.
All other persons, named below, who are known to have or claim a right to custody or
visitation of the children will be given notice of the pendency of this action and the right to
intervene:
Name
Address
Basis of Claim
N/A
WHEREFORE, Plaintiffrequests the Court to grant custody of the children to her.
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By:~<(26b/~.~P
Karl R. Hildabrand, Esquire
Attorney 1.D. No. 30102
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorneys for Plaintiff Cheryl Marchi-Zeigler
Dated: September ~ 2000
Document #: 181497.1
I,
~~
l._.__
-,..
~
~
VERIFICATION
I, Cheryl Marchi-Zeigler, do hereby verify that the facts set forth in the foregoing Complaint
are true and correct to the best of my personal knowledge or information and belief. I understand
that false statements hereilJJ are made subject to the penalties of 18 Pa.C.S. 94904, relating to
unsworn falsification to authorities.
Date: 8 -I-f-f/Jt/J
,
~i~~
Document #: 181497.1
_:til - ~"
- '--, --,'-- - '6,' ~-~- JIit.olioiiiritli'
CHERYL MARCHI-ZEIGLER,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
v.
NO. 00- ~JJ/.;J
EDWIN D. ZEIGLER, II,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
A Complaint in Divorce under ~ 3301 ( c) of the Divorce Code was filed on
September ih of the year 2000.
WHSREAS, the marriage of Plaintiff, Cheryl Marchi-Zeigler, and the Defendant,
Edwin D. Zeigler, II, is irretrievably broken and ninety (90) days have elapsed from the
date of filing and service of the Complaint In Divorce.
I, Cheryl Marchi-Zeigler, the Plaintiff, consent to the entry of a final decree of
divorce after service of notice of termination of intention to request entry of the decree.
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 I,Jnsworn falsification to authorities.
J. - dlrr/JI
Date
~~
Cheryl Marchi-Zeigler
,,_;_5. :;'~n l -," '"-.... """""''''--"'''''''.....~'i~'!l' .~""fiij~i!lil~~~,_,JlMWit~il~M~.'1lil!j,~J!;,;U-'
--""'..>" -~,
-
<..,.
.r,
-, ~, '^
II!I.\d II ~,.
"
.,
I' j'-~"'--""mJ~---- ~ " ~
,..
()
l"-"<
?;;;
-C~'"
1'1"'- (j"
#f'f'
~~;
$C~,'
$8
2:
---I
-<
~Q
:n
!\O
;'
'f
~
,I
~
i!
~
I'
i
~
!
C)
":)
'"
.."
'71
CD
t\,)
0',
1.
;.u.iIiI.
,,' -
~Il!\<'
,,..N
CHERYL MARCHI-ZEIGLER,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
v.
NO. 00 - w /r3&
EDWIN D. ZEIGLER, II,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
Entry of a Divorce Decree under
~ 3301 ( c) and ~ 3301 ( d) of the Divorce Code
I, the Plaintiff, Cheryl Marchi-Zeigler, II, consent to the entry of a final decree of
divorce without notice.
I, Cheryl Marchi-Zeigler, 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, Cheryl Marchi-Zeigler, understand that I will not be divorced until a divorce
decree is entered by the Court of Common Pleas of Cumberland County, Pennsylvania
and that a copy of the decree will be sent to me immediately at the address below after
it is filed with the Prothonotary.
I, Cheryl Marchi-Zeigler, agree to the terms of the Agreement, marked Exhibit A,
signed by the Defendant, Edwin D. Zeigler, II, and myself on August 7th of the year 2000
_,,"w
,~- -
, -+ -
d >"--- - <~ '_,e - "'_-~~ =~. ..:'i<l!iori.
,..1'\1.
and where before a commissioned Notary Public our signatures were witnessed on the
12th day of December of the year 2000.
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.
g;;, -J'T-rjJl
Date
JjJ~Y~~ )
Plaintiff .
Chery arch i-Zeigler
Cc: Cheryl Marchi-Zeigler
1772 South Meadow Drive
Mechanicsburg, PA 17055-5189
Edwin D. Zeigler, II
1772 South Meadow Drive
Mechanicsburg, PA 17055-5189
;' :'" ',>>,,~ J "' ~~'IlWr:ilf
~."'-"'"'~'!'llli,j~cl~~_~'i;fr:;e"",iM#",,lliHl-~!lIIl~ "'"'
=~
,~-"~, -~-
": ,~"" q~
~
".
-"~
'1'=
. ~ ~
,~-
-~
:~
i'
" iJ
_. ..i~
~~
1~
Ii;
I'
~
Ii
i
~
l
l
0 C
r'.-
7 -"
"'-.
<i;Jt"":,-> :-j'\
rn,,"," '2:;
Z::;~:
zr~' j',)
(0 J-' 0-_;
::.S r~)
,~ -.",-
.~
2 .r-,
L
p C \D (---'
---.
~ ",.;
~"
c:: -<
~ ,~, ~ ^ -~ -
~. <~)
,-' ,
-,- "
iiIIl.-fu,
CHERYL MARCHI-ZEIGLER,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
v.
NO. 00- 10103&
EDWIN D. ZEIGLER, II,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
A Complaint in Divorce under ~ 3301 ( c) of the DiVorce Code was filed on
September 7th of the year 2000.
WHEREAS, the marriage of Plaintiff, Cheryl Marchi-Zeigler, and the Defendant,
Edwin D. Zeigler, II is irretrievably broken and ninety (90) days have elapsed from the
date of filing and service of the Complaint in Divorce.
I, Edwin D. Zeigler, II, the Defendant, consent to the entry of a final decree of
divorce after service of notice of termination of intention to request entry of the decree.
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.
J- ;}7- ;)60 1
Date
Defendant
Edwin D. Zeigler, II
'","~_o
-JaJi- -""-~, "~i'f~ii!illl\f<!llIlM~i!lj~!l1ii!&lll!g~m:i&W~fu:~~--44'''''~U!: ""-; ~~,
'-
~,., -" ,
~.. ." '.~' , .<,
'." ,>- ~-
.~..,-~.,"
r)
-V~~
92~]~:'
~f)
."'-
'5~ ~~
-L-.
)0>,-
~
Z
..-j
--<.
.."
'., - =<~-~
c7.>
-,.,
'-!~j
c:;.:'l
" .
~-..)
\{;;J
':2j
~~
:J::!
-<;.
<::>
..
'" ~" j
Jlj~' -,,~,
;, -\.
CHERYL MARCHI-ZEIGLER,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
v.
NO.
DD-UiJJ~
EDWIN D. ZEIGLER, II,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
Entry of a Divorce Decree under
~ 3301 ( c) and ~ 3301 ( d) of the Divorce Code
I, the Defendant, Edwin D. Zeigler, II, consent to the entry of a final decree of
divorce without notice.
I, Edwin D. Zeigler, II, 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, Edwin D. Zeigler, II, understand that I will not be divorced until a divorce decree
is entered by the Court of Common Pleas of Cumberland County, Pennsylvania and
that a copy of the decree will be sent to me immediately at the address below after it is
filed with the Prothonotary.
I, Edwin D. Zeigler, II, agree to the terms of the Agreement, marked Exhibit A,
signed by the Plaintiff, Cheryl Marchi-Zeigler, and myself on August 7th of the year 2000
,,"-
~" -
,
-
'-'........,""
, ~~i""'_,f
I. ~
and where before a commissioned Notary Public our signatures were witnessed on the
12th day of December of the year 2000.
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.
9 4904 relating to unsworn falsification to authorities.
1;2-1,;) -00
Date
;2 ~rJ7-020:?1
adl~
if Defendant
!Iv IJCI:t;::~gl"'"
Cc: Cheryl Marchi-Zeigler
1772 South Meadow Drive
Mechanicsburg, PA 17055-5189
Edwin D. Zeigler, II
1772 South Meadow Drive
Mechanicsburg, PA 17055-5189
_1"
.J-",.-- =_
,"', '~,- ,
-'-'<
Dl
; .-'"
Before me, a Notary Public, in and for said County and Commonwealth,
personally appeared EDWIN D. ZEIGLER, II, who I due fOrm oflaw acknowledge the
above Waiver of Notice ofIntention to Request to be his act and deed and desire that the
same be recorded as such.
WlTNESS my hand and notarial seal the /.2.k.. day of /)ecU1>k
,2000.
Chit$;.
Notary Public
My commission Expire
Notarial Seal
Marlin R1pson" fJOt3ry Public
lower P,ilen lli1..'p~, Cumberlanr;1 County
My Comm~s8;:JrI 8<pb:s July ~?7, 2004
Member, P9fm:~i\j3!'iT3Asi(8T::itlOil of Notaries
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
",,;, ,I
.~~ ~ ..<
-"
[[If'-IiUil:m!i!~,",,Wili$l!l~~l!m'~_~~~~,~ij~-- "'
--,
,'.low", ~
,-,-< "-<~'
-"
d
SR"
,
"
C:J
o
C
,:r~:
~f',')_
rnn:
z.~,::"
2'\..,.
~.~~.
-:r.;C'
~~~
.";1'
:2
"'""
'-"f\
',:"_"0
r0
0'"'\
,-~
, .~~-"
:::~':
~.~"
,,,!
r..,
;;i
~1
'1
~.
~"
rn
~
i'
i
~!
I:
,
'i
~
'..- ~
-;-1
'c-
--",',
"",-,
'-,.-
"'.9
:.Jl
fV
- :-:~ (-,l
.::....-r.
-.....,
.,.;:C)
'~~\-\\
~
-<.
,~"
~....-
L "-"~-""":cR
-" JIiI
-
~'.->t![;...1
...
CHERYL MARCHI..zEIGLER,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
NO. 00 - /..o/J!.;;
CIVIL ACTION - LAW
IN DIVORCE
AGREEMENT
EDWIN D. ZEIGLER, II,
Defendant
It is hereby agreed between Cheryl Marchi-Zeigler, hereinafter party of the first
part and Edwin D. Zeigler, II, hereinafter party of the second part, in consideration of the
mutual promises, agreements and undertakings set forth herein as follows:
1. All of the maintenance, upkeep, renovations and remodeling of the
primary residence of the party of the first part will be performed and completed by the
party of the second part. The material costs shall be reimbursed by party of the first
part to party of the second part upon presentation of reasonable documentation and/or
receipts. The work described herein shall be performed by party of the second part in a
reasonably timely manner with the start date of each project to commence no later than
sixty (60) days after request by party of the first part. The requirements of this
paragraph will remain in full force and effect until the party of the first part shall remarry.
2. All expenses incurred by party of the first part for the parties children,
Tyler D. Zeigler (d.o.b. 7/8/84), and Nicole M. Zeigler (d.o.b. 1/8/88), shall be divided
equally between the parties. ("Expenses" as used in this paragraph shall not include
basic living expenses such as food, utilities and housing). The party of the first part will
maintain receipts and/or proof of payment for both children's expenses. These receipts
will be presented to the party of the second part on or before the 10th of each month
with payment of 50% of the total expenses presented to be paid by party of the second
part to party of the first part on or before the last day of that month.
Document #: 181501.1
Exhibit A
,,~~_..,
.. L""':'
, .
.ii~
. t/l~I,
1./
3. The party of the second part hereby agrees to contribute 50% of all
expenses related to the education of both minor children. These expenses shall
include, but not limited to tuition, room and board, books, supplies and other necessary
living expenses. The expenses incurred through the completion of high school shall be
included with the monthly expenses described above in paragraph 2 which shall be
reimbursed by party of the second part to party of the first part with the other expenses
described above. Payment of expenses for college or other post high school education
shall be paid pursuant to the payment requirements of the school or institution involved
and shall be due on or before the designated dates of said school or institution.
4. The aforesaid agreement shall be binding and enforceable pursuant to the
Uniform Written Obligations Act.
J-1- i~rjJy3
Date
~~
<?5 -7-~
Date
COMMONWEALTH OF PENNSYLVANIA
ss
COUNTY OF CUMBERLAND
Document #: 181501.1
J<~
.
-1;1;;"1
Before me, a Notary Public, in and for said County and Commonwealth,
Personally appeared CHERYL MARCH-ZEIGLER, who in due form of law acknowledge
the above Agreement to be her act and deed and desire that the same be recorded as
such.
WITNESS my hand and notarial seal the /.:z,k day of })eu tnJ~ 2000.
Ok~
COMMONWEALTH OF PENNSYLVANIA
Notary Public '_ . R~.;'t~~a!,~~~1 ,.
. . E . Mttftl,n . tli.''''''.il I, I \!u),dty Public
My commiSSion IJlfiElS Alien .fw~.. Gwr,l,erland County
My Comm;ss;(',;'l E;.q);res July 27', 2004
Member, pennsyivaniaAssoCiation01 Notaries
SS
COUNTY OF CUMBERLAND
Before me, a Notary Public, in and for said County and Commonwealth,
Personally appeared EDWIN D. ZEIGLER, II, who in due form of law acknowledge the
above Agreement to be his act and deed and desire that the same be recorded as such.
WITNESS my hand and notarial seal the ~ day of !Jecre/11Je/[, 2000.
~...~
Notary Public
My commissi .
Nolanal Seal ]
Martin E;D~lQn, Nr;Uuy Public
Lower AH;~r.t '!\\.';;".:~;tpn~Je:lan<1 County
My ComrmSSK,,;'j f:.\.pl:es vuly 27, 2004
Member, p~l:~syr/.s\'~S:':~X:::3ttonot NotarieB
Document #: 181501.1
l' ~.,,' ~,.'. J "<
~~ 0
lii~~~~rlJ\10~M~~IOO.i~an~;jj:~'-!!.y~a~
~ ~'" I~~~ ..
~.,
.
~=~jj
"j;,:l
o
~~
-of:~;
nll':'~
"7'-;-
~~;'-
.51~~'
f::: -"'
~8
PC
z
=<'
,';--
.....~;
"-r:\
""'"
;<,;0
;"0)
,
~- i
~,1
ij
I
I
I
I
i
"
::::...-;:
.-"..~
'!?
o
1
.,,',_n
=, ~I
1, .
..
..
CHERYL MARCHI-ZEIGLER,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
v.
NO. 00- <../J'- Co~C
CIVIL ACTION - IN CUSTODY
EDWIN D. ZEIGLER, II,
Defendant
ORDER
AND NOW, this I ~ day of ~ 2000, upon review and
consideration of the Custody Agreement of the parties, a copy of which is attached
hereto, said Agreement is hereby approved, adopted, merged and incorporated herein
as the Order of this Court.
BYT
cc: Karl R. Hildabrand, Esquire
Counsel for Plaintiff
3211 North Front Street
P.O. Box 5300
Harrisburg, PA 17110-0300
"-"....'"' E. C~/d') 'J"d')
. ArfJ
t~"i\~
Edwin D. Zeigler, II
1772 South Meadow Drive
Mechanicsburg, PA 17055
Document #: 181501.1
-
U=~''''-';'~
~~"=-"
.
"~
..~
.-" ,-~
~.;~W'IiI_!
-. .
"
~ ..
CHERYL MARCHI-ZEIGLER,
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PA
v.
NO.
EDWIN D. ZEIGLER, II,
Defendant
CIVIL ACTION - IN CUSTODY
CUSTODY AGREEMENT
WHEREAS, Cheryl Marchi-Zeigler, hereinafter referred to as "MOTHER" and
Edwin D. Zeigler, II, hereinafter referred to as "FATHER" are the natural parents of two
(2) minor children, Tyler D. Zeigler (d.o.b. 7/8/84) and Nicole M. Zeigler (d.o.b. 1/8/88);
and,
WHEREAS, FATHER and MOTHER desire to make arrangements for the
custody and visitation of said children; and
WHEREAS, both parties have been advised by counselor have had the
opportunity to so be advised by counsel; and
WHEREAS, the parties intend to submit this Custody Agreement to the Court of
appropriate jurisdiction for merger into a court order approving said agreement;
NOW THEREFORE, it is hereby stipulated and agreed as follows;
1. MOTHER shall have primary legal and physical custody of the children.
2. FATHER shall have such visitation with the children as shall be agreed
between the parties.
Document #: 181501.1
-'J= ~
ii~ ~
~.Ik
-.
...
~
3. This agreement shall be effective immediately upon signature by both
parties and its validity is not contingent upon Court approval.
8-'1- :L0f!Xj)
?
j"-l_~"
Date
<j -7-c206o
Date
Document #: 181501.1
-
s~
.
.~...._.~ = ,-< -
~ ,
, ,
- ~" "'~-- ,1-;' ,,~u' ~ ~' -...1, ~1i
...
..
,
CHERYL MARCID-ZEIGLER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 00-6136
EDWIN D. ZEIGLER, IT,
Defendant
CIVIL ACTION - IN DIVORCE AND CUSTODY
AFFIDAVIT OF SERVICE
I, Karl R. Hildabrand, Esquire, counsel for Plaintiff Cheryl Marchi-Zeigler, hereby certify that a
true and correct copy of the Complaint in Divorce was served upon Defendant Edwin D. Zeigler, II on or
about September 15, 2000 by certified mail, return receipt requested. Attached hereto, marked as Exhibit
"A" and incorporated herein by reference is the return receipt card for said service.
METZGER, WICKERSHAM, KNAUSS & ERB
B~~~&~-,"~ ~
Karl R. Hildabrand, Esquire (
Attorney I. D. 30102
Attorneys for Plaintiff
3211 North Front Street
Harrisburg, PA 17110-0300
Attorney for Plaintiff
Document #: 185326.1
-~~.-""'"
..
~.
0>
''0
, .-
J "'
10>
',.') ~
. >
'I!!
. -~'--j ~
Ie
'0
" '0
'0>
'ii
'E.
E
o
"
.
~~ '
...
70-407
d'
,.;....,:...",-
,
SENDER:
. Complete items 1 and/or 2 for additional services.
. Complete Items 3, 4a, and 4b.
. Print your name and address on the reverse of this form so thaf we can return this
carel to you.
. Attach this fonn to the front of the mallpiece, or on the back if space does not
. ""wit
IiWms -Return Receipt Requested" on the mailplece below the article number.
..T!W,f.letum Receipt will show to whom the article was delivered and the date
delivered.
5. Received By: (Prinf Name)
~
:>
g,
.!!l
I also wish to receive the
following services (for an
extra fee):
1. 0 Addressee's Address
2. 0 Restricted Delivery
Consult postmaster for fee.
4a. Article Number
1833 4879
7099 3400 0014
4b. Service Type
41"" Registered
Express Mail
Return Receipt for Merchandise
? Date of Delivery
3. Article Addressed fo:
Edwin D. Zeigler,
1772 South Meadow
Mechanicsburg, PA
IX! Certified
o Insured
o COD
8. Addressee's Address (Only if requested
and fee is paid) .
~ ~
-,~~" ll..l:Io'..!iIl",""
,.
~ """
'1:
0> ;.
Ul ~,
c.
1l
0>
a:
e
~
:>
'ii
a:
Ol
e
7ii
:>
~
.l2
:>
0
,.,
...
e
..
'"
I-
102595-98-8-0229 Domestic Return Receipt
Exhibit "A"
- ~
.H '._
,,"
j" j. ',-
'~" ~,
- -~,
"~-<- ~'-'~..l
"
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
..
>'~~ff
~,
:
File No.
00 - U 10.3 f.p '--6A).d0
vs.
IN DIVORCE
~hD^~I
)Defendant
:
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby.,given that the Plaintiff/Defendant in the
above matter, having been granted a Final Decree in Divorce on the
7J::h.- day of ~.. ,~jJ)O/, hereby elects to resume the
prior surname of ~ ~ ~ ' and gives
this written notice pursuant to the ovis10ns of 54 P.S. S 704.
DATE: ~
II) 200 I
~S~
~il~e~;!med
COMMONWEALTH OF PENNSYLVANIA:
: 55.
COUNTY OF CUMBERLAND
On the . } I,;t). day of /JYi ~ ' --H"';J::)(J/, before me, a
Notary Public, personally appeared ~e above affiant known to me to
be the person whose name is subscribed to the within document and
acknowledged that he/she executed the foregoing for the purpose
therein contained.
In Witness Whereof, I have hereunto set my hand and official
seal.
-I2;t:~UJ- A J:p~
. Notary Public
NOTARIAL SEAL
PATRICIA A. SHAnO, Notary Public
Carlisle Boro, Cumberland'County
My Commission Expires December 17, 2001
~~iiii.-"-Ji.j_B~UX~~iW~~;O:""",-",-~':;'l;jfilil;a'''''.ik'bJe.j~:i-~;~i{l1~D~ ( ~," - --....;.,;.~~-
.-p- ,'"
- ~. ~.
--.-'-
'li/lI"-
ilillI
~ !!
oij
;
!
0 C C)
C .-r;
.:::: -"'" ---.,
-{Q. -OLD :;:::;"'"
t 92~~ ,-
~ ;?~~
8 .L
~CJ -0
..... ~Q -"'" ';'~~Cj
..... ::;::-\......1 ~~ -:-'--, p-'~
.... ov FC ~.
~ -/ -,
.,.. ~t:,..
,- On
~ =<
~\ r -< (:0
~
.
'1