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Home My WebLink About00-07202 '" to , , , ~ ~~ ~ ~~ ~ ~ ~ , '" '" '" 1li '" , , " , IN THE COURT OF COMMON PLEAS , , , OF CUMBERLAND COUNTY , PENNA. , , , , , , STATE OF TERRY G. ZOOK, JR. , , , , , , Plaintiff No. 2000 - 7202 , VERSUS SARAH R. ZOOK , , Defendant , , , , DECREE IN DIVORCE , , , , , , , 'it. , \ (0 ~A. ' .,,()~ IT IS ORDERED AND , , , , , 10 ZOOK, JR. , DECREED THAT , PLAINTIFF, , , , SARAH R. ZOOK , DEFENDANT, AND , , , 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; Pvvperty Settlement Agreement dated February 21, 2002 is incorporated into this Order. , , . , '" '" ;+;:f. , ., , , . ~ J. ~~~ROTHONOTART , , , , , , " , ~':- , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , . . , , , . . . . . -,,~~~~~~'~ ~'C16 'O;;J.. 1",;lJ <:?ol . ,~,' . ~ ..~~ "' ~"'"''' '"I."mlii''~']lli'C''' ,~-..~ ",,",;..?~";"i'"J,"ff." ',-,-_"""~";""""",,,--,,,-,,,,,,'""'A.'"~~' . ..... 1...___ .~~ it:' .~' .. ( tJd-~~~4~ ~~ha7f~ ~ ""-m ~~~~ ""~~~",,I",," , -~-~ ".,....."'~._'''' ,," ~.,,,~. e, "~_1IlIi!!'P ~"_.~ I - ~ -. - ""~ ~i\N_t:€i~_ '. t r PROPERTY SETTLEMENT AGREEMENT r~ THIS IS AN Agreement made this .:2 ( Slday of )limfuy, 2002, by and between Teny G. Zook, Jr., (hereinafter referred to as Husband) and Sarah R. Zook, (hereinafter referred to as Wife). WHEREAS, Husband and Wite were married on November 30, 1996; and WHEREAS, various differences have arisen between Husband and Wife, whereby they have been living separate and apart; and WHEREAS, the Husband has commenced a divorce action against Wife docketed at No. 2000 - 7202 in Cumberland County, Pennsylvania; and WHEREAS, the parties desire to enter into an amicable settlement to provide for all of the property rights of the parties and to dispose of the rights and obligations of each to the other in respect to support, maintenance, alimony, counsel fees, equitable distribution, and all other rights and obligations under the Divorce Code of 1980, as amended, and it is the intention and agreement of the parties that this Agreement be a full, complete and final settlement of all of those rights and obligations under said Divorce Code; and NOW, THEREFORE, for and in exchange of mutual considerations, and intending to be bound by the provisions hereof, the parties agree that their recitals form a part of this Agreement and waive any right to counseling under the Divorce Code of 1980, as amended, and right to counsel fees, costs, alimony, support, maintenance, and any other rights under the said Divorce Code not provided for herein and agree as follows: I The parties agree that it shall be lawful for each party, at all times hereafter, to live separate and apart from the other, at such place or places as he or she may, from time to time, choose or deem fit. Each party shall be free from interference, authority or contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreemenf Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart, from the other. ......... ~ --~ I" .~ "-..~;;,~,"~, " . ! 2 The parties agree that they have adequately distributed all personal property owned by the parties, and each party hereby waives any further claim with respect to any items of personal property in the other party's possession. The parties also agree that this distribution has been an equitable distribution of marital property and that there is no further marital property that needs to be distributed by the parties. 3 A The parties are the natural parents of Nicholas R. Zook, born March 12, 1999 and . Natasha C. Zook, born June 25, 1996. The parties agree that they shall share legal and physical custody ofthe two minor children. 4 As of the time of this Agreement, Father agrees to pay to Mother the sum of$125.00 per week for support of the minor children. 5 Each party hereby represents they have disclosed all of the marital assets to the other party in the negotiations for the consummation of this Agreement. 6 The parties agree to execute the Consent Affidavits in order to finalize the divorce, the Wife agrees to proceed with finalizing the divorce case. 7 Both parties shall incur their own legal expenses with respect to this divorce litigation. 8 The parties agree that they will not contract or incur any debt or liability for which the other party might be responsible and shall indemnifY and save the other party harmless from any and all claims or demands made against th!\t party by reaBOn of such debts or obligations incurred.by the other party. ~ ~~ . --.~ ,~< ~ " . .~~+r, , . 9 Should a decree, judgment or order of separation or divorce be obtained by either of the parties in this or any other sate, country, or jurisdiction, each of the parties hereby consents and agrees that this Agreement and all of its covenants shall not be affected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order or further modification and revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the parties shall remarry, it being understood by and between the parties hereto that this Agreement shall survive and shall not be merged into any decree, judgment, or order of divorce or separation. It is specifically agreed, however, that a copy of this Agreement or the substance of the provisions thereof, may be incorporated by reference into any divorce, judgment or its decree. This incorporation, however, shall not be regarded as a merger, it being the specific intent of the parties to permit this Agreement to survive any judgment and to be forever binding and conclusive upon. the parties. 10 Husband and Wife do hereby mutually remise, release, quit claim or forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, from any and all rights, title and interest, or claims in or against the estate of such other, of whatever nature and wherever situate, which he or she now has or at anytime hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or courtesy of claims in the nature of dower or courtesy, or widow's or widower's rights, family exemption or similar allowance or under the intestate laws; or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testamentary or all or other rights of the surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania, any state, commonwealth or territory of the United States, or any other country or any right which either party may now have or at anytime hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. It is the intention of Husband and Wife to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provision thereof. II Each of the parties shall, from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments or documents that may be reasonable required to give full force and effect to the provisions of this Agreement. iI."-""'....~, .-,j ~' '-'",'~-;"_''<i",,,,~,';' ., , 12 A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same fonnality as this Agreement. The failure of either party to insist upon the strict perfonnance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 13 This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 14 It is specifically understood and agreed by and between the parties thereto that each paragraph hereof shall be deemed to be a separate and independent agreement. 15 If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her and the party breaching this Agreement shall be responsible for payment of legal fees and costs incurred by the other in enforcing the rights under this Agreement, or in seeking such other remedies or relief as may be available to him or her. 16 , i I This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 17 If any tenn, condition, clause or provision of this Agreement shall be detennined or declared to be void or invalid in law or othelWise, then only that tenn, condition, clause or provision shall be stricken from this Agreement, and, in all'other respects, this Agreement shall be valid and continue in full force, effect and operation. 18 Except as otherwise set forth herein, this Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. - ",,",",6d,L'::~'b' v , . IN WI1NESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. WI1NESS :::4 7 ~ Sarah ~ '> -- .. < ;;"~ '~ujjjdi. - '''.........'=''" S~~l~~k'l@l-~iF,H:illili.~l'"\J:&;".:!ilj,~_-f'I~i';<~"'"-~''''''''''E''''~~I~jjMd!li\IllIli.ill~I~.1i!O ~~l,eiiiim- "h ,""'- "--,"",<<" -'~-~'~-'"-= d._ _. ," ~, ,,-,. . - ",_f ~, "_'^ , <<,_e" . ". '-1 ~ ~~._'" o C- vt~ 'T!;;~--; ""7" 7,::r; (/) "1-_ -, ~ ~- ~(~:j - c ;::- ::J , , a r" ~.- r~ N o " :;! i-:l:!J -~lTn ~-:? --=:z~) -,~~'H :";. (-, orri ~ :v -< :,:;", :.s: I.CJ U1 '^ __~'M~ __ ..n ,,' ^,<< -, -:.4,- .. --~> ".'..;' "_"_.c",_"'~-"".._"+_,,.~',, ~",.,,,-,- ,-.-.' -.-: ,"; ~F:, . .' \ TERRY G. ZOOK, Plaintiff, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v : NO: 00 - 7202 CIVIL TERM SARAH R. ZOOK, Defendant, : 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 (x)3301(c) ()3301(d)(I) of the Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complaint: Defendant Sarah R. Zook acknowledges service ofthe Complaint through her attorney Henry F. Coyne on June 9, 2001. 3. (Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff: March IS, 2002; Defendant: February 21, 2002. (b) (I) Date of execution of the Plaintiffs affidavit required by Section 3301(d) of the Divorce Code:_; (2) Date ofservice ofthe Plaintiff's affidavit upon the Defendant:_. 4. Related claims pending: None. ,- .' , ~~ -, '~;""" - "" - "..;--, ,^" --"d_",J",..~-~- ,'. "~~.","-,--, .' '-',';.'l-._,',. ~~i . .., 5. Complete either (a) (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: March 15, 2002. (c) Date Defendant's Waiver of Notice in ~3302(c) Divorce was lliIed with the Prothonotary: February 25, 2002. Hubert X. Gilroy, E uire Attorney for Plai Iff Broujos & Gilroy, PC 4 North Hanover Street Carlisle, PA 17013 717-243-4574 _ .~, J -, ~"="N '"""'....~..-,;l~,...'~ ~'iil.~~~ -~~,,- ,-. ,-, <'''~'" =~--~ ~"~ .- ,-, ~ ^ "'. . (") a ,~ C r'v ,.' ;0- -;1 -or{~ S:: .~ IT] C" i:::::: ~~'~-! ,] :2 r\,) " ~~ ~~~ .- ~ ~r' r2c: r-., > ;,-r::'.'" ::0;:' :2.'" C) -.- ,-} i~ s:;c -..,;" (') C lO (-] rll Z -, :;! .:n ,. :0 .r.- -< -- ,: , ".-, '-___' _"<_ ,x__." ',__, ',__ ,_~ TERRY G. ZOOK, JR., Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL DIVISION - LAW : NO. 2000 - ?'.'kI.1., CIVIL : IN DIVORCE v SARAH R. ZOOK, 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 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 , ",,'-z.'--I ",Ci',_,_,_" a;,,- TERRY G. lOOK, JR., Plaintiff v : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL DIVISION - LAW SARAH R. lOOK, : NO. 2000 - 7"]().2 CIVIL Defendant : IN DIVORCE COMPLAINT Plaintiff, Terry G. look, by his attorneys, Broujos 8r Gilroy, P.c., sets forth the following: 1 Plaintiff, Terry G. look, is an adult individual residing at 34 East Street, Carlisle, Cumberland County, Pennsylvania. 2 Defendant, Sarah R. look, is an adult individual residing at 415 Hummel Avenue, Lemoyne Pennsylvania. 3 The parties were married on November 30, 1996, in Cumberland County. 4 Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the commencement of this action. 5 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. ~~~ ' -. . -, '~- ,- -,,,, "" : I 'e ',,',,-,J '-".'""'--,--".~~".~-,,, -. '~e; 6 In accordance with Section 3301 (c) of the Divorce Code, the marriage between the parties is irretrievably broken. 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. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. BROUJOS &: GILROY, P.c. By Hubert X. i1roy, Esquire Attorney r Plaintiff 4 North anover Street Carlisle, A 17013 717-2 3-4574 ,---' ",1-, 1:~k'j~::;;J>-,,-: . ',-,--',C " < < "I I I I I verify that the statements in the foregoing pleading 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. TorryG~ 2-< - k" H_'_.,-"'-" Ii~~- ~." -"......""'-~~'~ ' ~ .')~_. ( , ':rl._ i::' ~...............,' . . ti~if.. "l'NT REINSTATED . (1 '1Y.Y.fk~.t~" ..... .' . 'p1iiOiFHONOfARY ....~"~;,....'..,r.. ...... . ~ , ~,--,,,,"- " " . ,._._', ,9, r,"_~" ,,,~___ . ,__, "' ;.",' ,-- -"'":,~~~~-""" '. ~, ~iliiliillllM -;;p{2 fk. '{ o 5 1J-...o ~ {"' -- -0, ...,. ...... - ~ ~~ &Q~ ,'iD p~ rt 1 ,._~~" -~~~ ,'M o t ""l"'f'-- n'''i,.' ~~~-: ~~~.: ~:2 ~ ....~ . ... ",. C:... C';, C') "0' i"l :~J ~"-,: 0:.\ '!=~f8 ' ,'.---" ....".....) :b ~--" t, '---,-'! '--;t-S t-:5,n ..j ". 5J -< -,., ::> [0 .~-";-- 0._ ~'""-' ~" . . , , , TERRY G. ZOOK, Plaintiff, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v NO: 00 - 7202 CIVIL TERM SARAH R. ZOOK, Defendant, : IN DIVORClE AFFIDAVIT OF SERVICE I, Hubert X. Gilroy, being duly sworn according to law do depose and state that a copy of the Complaint and Notice to Plea filed in the above referenced matter was served on Defendant Sarah R. Zook, by Attorney Henry F. Coyne. A copy of the Praecipe is attached hereto and marked Exhibit A. 7/~/ (;:2 DATE ~ Hubert X. Gilr , Esquire Attorney for aintiff Broujos & i1roy, P.C. 4 North Hanover Street Carlisle, P A 17013 717 - 243-4574 Sworn and subscribed before me this ~....I. /: day Of~~ ' 2002 &uJ~ Notarial Seal Bridget Ann Corcoran. Notary Public Carlisle BalO. Cumberland County My CommiSsion Expires June 10. 2006 Memb8I,l'eIlIlSYIV8IllaAs8OCl8llDnofNoflUl8B ".""'_M . .. ,,-, "'~~- ~ . TERRY G. ZOOK, Plaintiff, VS. SARAH R. ZOOK, Defendant. TO TIIE PROtHONOTARY: J - , . : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PA : NO. 00-7202 CIVIL TERM : IN DIVORCE' PRAECIPE Kindly enter my appearance of behalf of the Defendant, Sarah R. Zook. On June 9, 2001, I accepted service of the Complaint. Dated: J.. l' ~ .lo.~ Respectfully Submitted: COYNE & COYNE, P.C. ~. '~-^."""",~;.~, BY: Henry F. Co e,. squire 3901 Market treet Camp Hill, P A 17011 (717) 737-0464 Pa. Supreme Ct. No. 53788 Attorney For Defendant ~""1t~: TJ I '.Ii.. "'l'"~~~~jjj~~~~i~~.1'<klffiliM!ffi,;!L[ill.1J\liJK'~5,~!tiilll!~!..,d" J.'!.tl -, ,,,,,,,.,, <. '",r,,~, .,_"" ,~-~- ..--,' , _ .-;"",~,'''"''7-~ -" liliilr~ ........,mQ$!,i:J!lII.H . " =~ .~"~l) Jlil;! ,..". ~-- J"' . 0 0 0 C 1'"",) ~1 . -1 vt'_rj c rflr'7'-: r- ci ~ 7-;"'; Z~ Co,) I" S~~~ .1="- 'jl~ ,2 I.~' r::: c ,~ ~ :t:1'" -',' '!r c";---': () ~ ,.~() ..,,;--- CI S> C w (Srn z U1 :P! =< ~ ~ - ~~ . jii,'_', c,;:-,<J,~,'_'. -,' -,-,-~,--""-,."",",,'q;--,,, ',_ . ) l ~ . ... TERRY G. ZOOK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : 00 - 7202 CNlL TERM SARAH R. ZOOK, Defendant' : IN DNORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on October 18,2000 and reinstated on June 8, 2001. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date ofthe filing ofthe Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. I understand that r may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 6. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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. 94904 relating to unsworn falsification to authorities. Date: IS }1Q/L ~ Zf:b7 -- ) ,/ /- ~-( Terry ~k aintiff ".. -IIi" -', ;,,~.- . " ,'" ~--" ",--- ~- . .~,:':":" ~~_~,,~.....L ---,";;,"-~. ) 1 ,"' ..~, ~'"'. .,--" ,,' ,-~,,','G-_';-'&' _~,'YC'-"-^'~'''' ,,- -- .,;c~.",",",-~oi'" ' ". " ,-" ~ . 0 C) ('I C. f0 "1',\ ~. ~-O 0",' -n:7:. !J" Li ; -,~'.~'J Z Z ~... (() () -< ->' [~i r:= C-' :t~~ ;t>, C~, ; <'- C.) 5> c C) ':~) 2: c- ~~"~ -i ~, --<. co -. -~ ~ . . .,., 3301 (c).ool TERRY G. lOOK, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v : 00 - 7202 CIVIL TERM SARAH R. lOOK, Defendant : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on October 18,2000 and reinstated on June 8, 2001. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about June 2001. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 6. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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. S4904 relating to unsworn falsification to authorities. Date: :2 ';Z J '0 d-.. ~ah~.- '''''"''" < .~-~~ _..,l 1'." . <"~ lk .. TERRY G. lOOK, Plaintiff v : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000 - 7202 SARAH R. lOOK, Defendant : IN DIVORCE PRAECIPE To the Prothonotary: Please reinstate the complaint filed in the above matter. Respectfully submitted, ~ -I'IUbert X. Gilroy, Esquire Attorney for Plaintiff Broujos &: Gilroy, P.c. 4 North Hanover Street Carlisle, PA 17013 (717) 243-4574 r~ iiIII~~OOi!i!Illmitill~~mrll~iIi~n_!l!.....iIiiiJ rmllllillH ( L ",' >",,^,"~"_ ,'"'. .__~.~.~._ . -<'.",. ,~ ",""'- - _."-<._'-).,~ J 0 C) c: 0 ;e- -c, -u-. k mQ:) ~--r ZTn c_ ,./- ::r' :;;e ;';~i;~J ~s: I -'r:.11-n ?? ?:~ CO ~~~'-(~' ~o =E J> 20 jd"-i--{ 5>0 ~., j?]() ~ I>? 6m c- ';;;' (AI ::'5 "< " ~ - 1 , TERRY G. ZOOK, Plaintiff, .. JC"" 'I '"' , ~ _. ',. ~ : IN THE COURT OF COMMON PLEAS :OFCUMBERLANDCOUNTY,PA VS. : NO. 00-7202 CIVIL TERM SARAH R. ZOOK, Defendant. : IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Kindly enter my appearance of behalf of the Defendant, Sarah R. Zook. On June 9, 2001, I accepted service of the Complaint. Respectfully Submitted: COYNE & COYNE, P.C. Dated:il ~ BY: Henry F. Co e, squire 3901 Market treet CampHill,PA 17011 (717) 737-0464 Pa. Supreme Ct. No. 53788 Attorney For Defendant iiid~'~ti..;: - "~~"~"'~~oilliilJllili - . -iilill >r""' .,~~, 'Jijili]i!lIJI..jgjlOc~~~~illliii"''-\..''''"''~ .d - -- _ '_"-' ,,_, _, ~_'~"_F~' ,"'" .. ~_ """,, -", ~. . .~ ~o ~.. o c < "0 ii' rllr:"' Z" zr::'" 0:" -<.<. ~-..:C- ~~:~ 5c~ z ~ I o N <- C , I o ."r1 :I! ,- ''-;~:8 : ~;~ (-) . ,- -" ;-=----T ~'t) ~::);-r -, > :rJ -< ~rn (...,) eo