HomeMy WebLinkAbout01-03252
~"
, ,', i_ ,~" I, ' , ',,,,'c,,~~~ ~"':;;';':" ,', " __. -.; ,::;;',,-
..
""
,01:-,'
.
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF
. KathleeR A. Zimmennan,
P1aiRtiff
.
VERSUS
Riekey L. Zimmennan,
Defendant
PENNA.
N 3252 Civil Tenn
O.
2001 .
.
.
.
.
.
.
.
.
.
.
.
.
DECREE IN
DIVORCE
AND NOW,
o Lt, Lc5'" 2S
, ~, IT IS ORDERED AND
DECREED THAT
Kathleen A. Zimmennan
, PLAINTIFF,
AND
Rickey L. ZimmennaJil
, 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 sEEN ENTERED;
None.
A
PROTHONOTARY
..
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
J.
.
~
I
j
i
i
:!^A.
/~ ;;ltttJl
/tJ ;;;'l.t//
F
~
,~,
~^' :.,
~~~ ,~ -"-
, ,~'<O; 1'. :;- ,
":.-''t'"
([\
C{6
M~~~4~
7&~~~~-
#,
.'
~_~,....~,~.....,~~V'!'l''!'l!"~~:m!I!."..-,wr ""
,M'~~
"f :"'_""',-"""WI'
" ~ "~
,
J, .,.;,.;~~-~
~~~'\!i'"
~.__ ".1,
..
....
KATHLEEN A. ZIMMERMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 01 - 3252 Civil Term
RICKEY L. ZIMMERMAN,
Defendant
ACTION IN DIVORCE
MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT, made thi:Z~ day of ~ ,2001, by and between,
KATHLEEN Z. ZIMMERMAN, of Mouni'm?lly Springs, Cumberland County, Pennsylvania, hereinafter
referred to as "WIFE", and RICKEY L. ZIMMERMAN, of Carlisle, Cumberland County, Pennsylvania,
hereinafter referred to as "HUSBAND".
WITNESSETH:
WHEREAS, Husband and Wife were lawfUlly married on September 8, 1992, in Ocean City,
Maryland, and;
WHEREAS, there were no children born of this marriage;
WHEREAS, differences, disputes, and difficulties have arisen between the parties and it is the
intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties
desire to settle their respective financial property rights and obligations as between each other, including
the settling of all matters between them relating to ownership and equitable distribution of real and
personal property; the settling of all matters between them relating to the past, present, and future
support, alimony, and/or maintenance of Husband or Wife; and in general, the settling of any and all
possible claims by one against the other or against their respective estates;
NOW THEREFORE, Wife and Husband, each intending to be legally bound, hereby covenant
and agree as fOllOWS:
1. FULL DISCLOSURE OF ASSETS. Each party warrants that he or she has made a full and
fair disclosure of income, assets, and their valuation prior to the execution of this Agreement as well as
any other fact relating in any way to the subject matter of this agreement. These disclosures are part of
the consideration made by each party for entering into this agreement.
2. ADVICE OF COUNSEL. The Husband is PRO SE. The Wife has employed and had the
benefit or counsel of Jane Adams, Esquire, as her attorney. Each party has carefUlly and completely read
this agreement and has been advised and is completely aware not only of its contents but of its legal
effect. HUSBAND has been advised of his right to counsel, voluntarily elected to forego representation,
and understands that Jane Adams, Esquire is only representing WIFE.
3. SEPARATION. That the parties intend to maintain separate and permanent domiciles and to
live apart from each other. It is the intention and purpose of this agreement to set forth their respective
rights and duties while they continue to live apart from each other. Whereas a Complaint in Divorce was
filed, both parties will agree to a No-Fault Divorce after the applicable ninety (90) day time period has run,
--
'. , l"~ :-,__>
."',';;:"",',.-,
, ",.,
"
.I ' ,
.
-
The parties have attempted to divide their matrimonial property in a manner which conforms to a
just and right standard, with due regard to the rights of each party. It is the intention of the parties that
such division shall be final and forever determine their respective rights, The division of existing marital
property is not intended by the parties to constitute in any way a sale or exchange of assets.
4. FREEDOM FROM INTERFERENCE. Further, the parties agree to continue living separately
and apart from each other at any place or places that he or she may select. Neither party shall harass,
annoy, injure, threaten, or interfere with the other party in any manner whatsoever. Each party may carry
on and engage in any employment, profession, business or other activity as he or she may deem
advisable for his or her sole use and benefit. Neither party shall interfere with the uses, ownership,
enjoyment, or disposition of any property now owned and not specified herein or property hereafter
acquired by the other.
5. SUBSEQUENT DIVORCE. The parties hereby acknowledge that WIFE has filed a Complaint
in Cumberland County, claiming that the marriage is irretrievably broken under the no-fault mutual consent
provision of Section 3301 (c) of the Pennsylvania Divorce Code. HUSBAND hereby expresses his
agreement that the marriage is irretrievably broken and expresses his intent to execute any and all
affidavits or other documents necessary for the parties to obtain an absolute divorce pursuant to Section
3301{C) of the Divorce Code. The parties hereby waive all rights to request Court Ordered counseling
under the Divorce Code. It is further specifically understood and agreed by the parties that the provisions
of this Agreement relating to equitable distribution of property of the parties are accepted by each party as
a final settlement for all purposes whatsoever, as contemplated by the Pennsylvania Divorce Code.
Should a decree, judgment, or order of separation or divorce be obtained by either of the parties
in this or any other state, 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 or 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 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 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.
6. DATE OF EXECUTION. The "date of execution" or "execution date" of this agreement shall
be defined as the date upon which it is executed by the parties if they have each executed the Agreement
on the same date. Otherwise, the "date of execution" or "execution date" of this Agreement shall be
defined as the date of execution by the party last executing this Agreement.
7. DISTRIBUTION DATE. The transfer of property, funds, and/or documents provided for herein
shall only take place on the "distribution date" which shall be defined as the date of execution of this
Agreement unless otherwise specified herein.
8. MUTUAL RELEASE OF ALL CLAIMS. HUSBAND and WIFE each do hereby mutually
remise; release, quit-claim and forever discharge the other and the estate of the other, of and from any
and ail rights; titles, and interests, or claims in or against the property (including income and gain from
property hereafter accruing) of the other or against the estate of such other, or whatever nature and
wheresoever situate, which she or he now has or at any time 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 curtesy, or claims in the nature of dower or curtesy of
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
, <
=~ .~ '",' ..;.~ llll ,. '. ','
,(,'... '. ' ',~
'1\';'-'
...' "".,
,
all other rights of a surviving spouse to participate in the decease 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 rights which Wife may have or at any time 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 any 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 thereof.
9. WARRANTY OF DEBTS AND FUTURE OBLIGATIONS. Each party warrants represents that
they have not contracted any debt or liability for the other or which the estate of the other party may be
responsible or liable, and except only for the rights arising out of this agreement, neither party will
hereafter Incur any liability whatsoever for which the other party or the estate of the other party, will be
liable. Each party agrees to indemnify or hold harmless from and against all future obligations of every
kind incurred by them, including those for necessities.
10. OUTSTANDING JOINT DEBTS.
(a) Wife agrees that the following debts are her own personal responsibility and therefore agrees
to completely and finally pay on the following debts and obligations.
Beneficial National BanklHRS USA credit card (K-mart)
WFNN Bank credit card (Dressbarn)
Sears credit card.
Modern Home Appliance Company (washer and dryer)
United Consumer Financial Services (Kirby Sweeper)
(b) Husband agrees that the following debts are his own personal responsibility and therefore
agrees to completely and finally pay on the following debts and obligations.
Husband will pay all medical and dental bills relating to his care.
Montgomery Wards credit card.
Lowe's credit card.
11. DIVISION OF PERSONAL PROPERTY. Husband and Wife do hereby acknowledge that
they have previously divided their tangible personal property including, but without limitation, jewelry,
clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works
of art, and other personal property. Except as may otherwise be provided in this Agreement, Wife agrees
that all of the property of Husband or in his possession shall be the sole and separate property of
Husband; and Husband agrees that all of the property of Wife or in her possession shall be the sole and
separate property of Wife. The parties do hereby specifically wavier, release, renounce, and forever
abandon whatever claim, if any, he or she may have with respect to the above items which shall become
the sole and separate property of the other.
12. MOTOR VEHICLES. With respect to the motor vehicles, owned by one or both of the
parties, they agree as follows:
(a) The 1998 Plymouth Neon shall be and remain the sole and exclusive property of Wife.
(b) The 1995 Mitsubishi Miti-max Truck shall be and remain the sole and exclusive property of
Husband.
L" <c'
I...
", " -,-","',r
.. .,
.'
Each party agrees to be solely responsible for the amounts presently due and owing against his or
her respective automobiles, The titles to the said motor vehicles shall be executed by the parties, if
appropriate for effecting transfer as herein provided, within thirty days of the execution of this agreement,
or within thirty days of retum of the title from the respective loan or finance company, The parties will
cooperate in completing all paperwork to effectuate the intent of this agreement.
13. MUTUAL WAIVER OF EMPLOYMENT BENEFITS. The parties agree to waive any and all
rights they have in and to each other's employment benefits, including but not limited to both parties
pensions, retirement plans, Incentive Savings Plans and 401 k accounts. The parties agree never to
assume any claim to such benefits of the other at any time in the future.
14. ALIMONY, ALIMONY PENDENTE LITE and LEGAL FEES. Each party hereby waives any
right to alimony pendente lite, and each party agrees to be responsible for his or her own legal fees and
expenses. The parties herein acknowledge that by this Agreement, they have respectively secured and
maintained a substantial and adequate fund with which to provide for themselves sufficient financial
resources to provide for their comfort, maintenance, and support in the station of life to which they are
accustomed. Wife and Husband do hereby waive, release, and give up any rights they may respectively
have against the other for alimony, support, or maintenance. It shall be from the execution of this
Agreement the sole responsibility of each of the respective parties to sustain themselves without seeking
any support from the other party.
15. INCOME TAX RETURNS. Husband and wife represent to each other that to the best of their
knowledge all tax returns and other documents required to be filed with the Internal Revenue Service for
calendar years 1992 through 2000 have been filed and that no notices have been received from the
Internal Revenue Service which remain unresolved. Each party further represents to the other that to the
best of his or her knowledge, the information set forth in the joint tax return for these calendar years was
and remains accurate as relates to his or her sole income and acknowledges that the other party relied on
such representations in signing those retums. Therefore, if any deficiency in federal, state, or local
income taxes is proposed, or any assessment of any such tax is made against the other party by reason
of his or her having joined in the filing of joint federal, state or local income tax returns, Husband and Wife
shall indemnify and hold harmless the other against and from any and all tax, interest, penalty, or expense
relating from any such tax deficiency, including reasonable counsel and accounting fees, and such tax,
interest, and penalties or expenses shall be paid solely and entirely by the responsible party as
determined to be attributable to that party on account of misrepresentation or failure to disclose relevant
information of income on the aforesaid joint returns.
The parties agree that they will split in equal shares any tax refund paid to them by the IRS up
until the dllte of the final Divorce Decree.
16. HEAL THINSURANCE. The parties shall maintain and shall be responsible for payment of
their own separate health insurance policies.
17. WAIVER OR MODIFICATION TO BE IN WRITING. No modification or waiver of any of the
terms hereof shall be valid unless in writing and signed by both parties, and no waiver of any breach
hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar
nature.
~,'~
'" ,_ "II ..
I
.
18. MUTUAL COOPERATION. Each party shall, at any time and from time to time hereafter,
take any and all steps and execute, acknowledge, and deliver to the other party any and all further
instruments and/or documents that the other party may reasonably require for the purpose of giving full
force and effect to the provisions of this Agreement
19. APPLICABLE LAW. The Agreement shall be construed in accordance with the laws of the
Commonwealth of Pennsylvania which are in effect as of the date of execution of this Agreement.
20. INTEGRATION. This Agreement constitutes the entire understanding of the parties and
supersedes any and all prior agreements or negotiations between them, There are no representations or
warranties otYler than those expressly set forth herein.
21. OTHER DOCUMENTATION. Wife and Husband covenant and agree that they will forthwith
execute any and all written instruments, assignments, releases, satisfactions, deeds, notes, or such other
writings as may be necessary or desirable for the proper effectuation of this Agreement
22. NO WAIVER OF DEFAULT. This Agreement shall remain in full force and effect unless and
until terminated under and pursuant to the terms of this Agreement The failure of either party to insist
upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such
party hereafter to enforce the same, nor shall the waiver of any default or breach of any provision hereof
by construed as a waiver of any subsequent default or breach of the same or similar nature, not shall it be
construed as a waiver or strict performance of any other obligations herein.
23. SEVERABiliTY. If any term, condition, clause, or provision of this Agreement shall be
determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause, or
provisions shall be stricken from this Agreement; and in all other respects, this Agreement shall be valid
and continue in full force, effect, and operation. Likewise, the failure of any party to meet his or her
obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the
conditions precedent, shall in no way avoid or alter the remaining obligations of the parties,
24. BREACH. If either party breaches any provisions of this agreement, the other party shall
have the right, at his or her election, to sue for damages for such breach, or seek other remedies or relief
as may be available to him or her, and the party breaching this contract should be responsible for payment
of legal fees and costs incurred by the other in enforcing their rights under this agreement
25. INFORMED AND VOLUNTARY EXECUTION. Each party to this agreement acknowledges
and declares that he or she is fully informed as to the facts relating to the subject matter of this
agreement, is entering into this agreement voluntarily, free from fraud, undue influence, coercion or
duress of any kind, has given careful thought to the making of this agreement, has carefully read each
provision of this agreement, and fully and completely understands each provision of this agreement
IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year
first above written:
WITNESS:
~h~AJ(j~
THLEEN A ZIMME AN, Plaintiff
Date: ~.,g; ~Cl::1 I
" ~ ,
" I..
,", ,~" C'.~ '.;.; ~~ "",c.:''ii~
,
,
~' ,p- 8"
.. .
COMMONWEALTH OF PENNSYLVANIA )
):ss
COUNTY OF CUMBE~D . )
On this, th(:) day of ~, 2001, before me, the undersigned officer,
personally appeared KATHLEEN A. ZIMMERMAN known to me, (or satisfactorily proven) to be the person
whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for
the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
SEAL
NOTARIALSEAL
JANE E. ADAMS. Notary PublIc
Carlisle Boro;,CUmberland ~ _
. My Comll'lissiOn Eiqll~" <'.ajlt. UOlM
.'-
'/J1;U(
N, Defendant
-4~-
Witness
IJ~
Date: S qTOl's u.. <;}Cc f .;><JoJ
COMMONWEALTH OF PENNSYLVANIA )
):ss
COUNTY OF CUMBERLAND )
On this, the <;><oib.day of 'O€{71A8(J,t. ,2001, before me, the undersigned officer,
personally appeared RICKEY L. ZIMMERMAN known to me, (or satisfactorily proven) to be the person
whose name is subscribed to the within instrument, and acknowledged that he/she executed the same for
the purposes therein contained. -
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
My commission expires: ~ 0 v EAt6 CL I ~ &co 3
SEAL
NoIarIal8aaI
Mary J. GouIfer. NcI8lY PuIiIIo
Silver Spring 1\vp., CumbeIfaRd CounIV
~lj Commle8lori Expkes Nov. 17. 2008
Memht:!r ~"',"''''l;.' ~:;:>5,:~ "of otarfes
~li~"1IiIIliI>~Mi!ll1;I"l!~kiiit'~'!!:{';;:i,;!;~~-illr.~~.I:i<ti'iv",.'~~:i-"I,;i-'.~J~,'""",-li,o,_,",;l~'>~%',"c',;l,.,)<t<.-"0li'~ill~J~,_ilID_~iijllll~~:~.Mli
~
~,.,
,~~ , ,
~"'^,d~~,.",."u,.,__~ ~,.~,
~,-,
()
~.;:
11 r:-;;
;;2 Lt.~
0'~
.-<" -
!::.:(:,
~~l
~;::C)
-S~
~-- "
I
- , I
J I
I
I
I
I
!
"Cj
-<
C';;:J
a
Cd
--"
:~..:;
--:.,.)
(::)-
, '
~~''''l
,:l'.'1
,"
TI
..., -,,"" ,',
:nlllimiliF' ,"~" ~ ;iU~,
.
,<
,,'
KATHLEEN A. ZIMMERMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 01 - 3252 Civil Term
RICKEY L. ZIMMERMAN,
Defendant
: ACTION 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 the service of the Complaint: Delivered by certified mail.
restricted delivery. return receipt requested. delivered on: June 8, 2001.
3. Date of execution of the affidavit of consent required by 3301 (c) of the
Divorce Code:
By Plaintiff:
October 10, 2001.
By Defendant:
October 11, 2001.
4. Related claims pending: None.
5. Date Defendant's Waiver of Notice in 93301 (c) Divorce was filed with the
Prothonotary: October 11, 2001.
Date Plaintiff's Waiver of Notice in 93301 (c) Divorce was filed with the
Prothonotary: October 11, 2001.
Date: ~ a ' \. <\ \ 0 \
Jae Adams, Esquire
. No. 79465
1 '- South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
Attorney for Plaintiff
(""'''~HJ'"-~..:......a..''''~iitda~~''''~~~
~.ft
,~., ~A.___.,
_1~+,.~i'il\\-t.g~~~~~M~ii:~-'-'>-'''''"~''~~~'
~:_,
~,
~~"'""-"'l.
~
~"","""". ""
1M
.'
.
0 0 0
C .,
<:'" -c:> "'--l
-og;; n ~1; j~
OJ' -I
""::C ,
Z\;, -c.,UJ
S9"~ \.0 ~~::::::.J
r::(;) -~(~}
:<: .- --0 ' "
> z g~~
zO
-0 c"5rf'l
::PC
~ --I
N ~
0
'Q)
, ,'~
<'c
'" ",-"J'I'
,
\
KATHLEEN A. ZIMMERMAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO.OI- 3,J.$;;L
Civil Term
RICKEY 1. ZIMMERMAN,
Defendant
: ACTION IN DIVORCE
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.
Where the ground for the divorce is indignities or irretrievable breakdown of the
marriage, you may request marriage counseling. A list of marriage counselors is available at the
Office of the Prothonotary, Cumberland County Courthouse.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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
, .
.
""'"
. <' ..
\
KATHLEEN A. ZIMMERMAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 01- 3.< S:2../
Civil Term
RICKEY 1. ZIMMERMAN,
Defendant
: ACTION IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Kathleen A. Zimmerman, a competent adult individual, who has resided at
11 Midland Drive, Mount Holly Springs, Cumberland County, Pennsylvania, 17065, since
August 2000.
2. Defendant is Rickey 1. Zimmerman, a competent adult individual, who has resided at
49 E. North Street, Apt 3, Carlisle, Cumberland County, Pennsylvania, 17013, since May 2001.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at
least 6 months immediately previous to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on September 8, 1992 in Ocean City,
Maryland.
5. There have been no prior actions of divorce or for annulment between the parties.
6. 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.
7. Plaintiff and Defendant have no children together.
8. Plaintiff and Defendant are both citizens of the United States of America.
9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States
of any of its allies.
'"'
:nil~l:>~iii~*~:
~"
'.,
. ""
'-'-'>"~-."""""W~i'-'
a __ -, ..
10. The Plaintiff avers that the grounds on which this action is based are:
(a) That the marriage is irretrievably broken; and/or
(b) That the Defendant has offered such indignities to the Plaintiff, the innocent
and injured spouse, as to render her condition intolerable and life burdensome.
WHEREFORE, Plaintiff requests the court to enter a decree in divorce.
1 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 18 Pa.C.S. 94904 relating to unsworn
falsification to authorities.
j(pAJt'''A) O~~
Kathleen A. Zimmerm , lamtIff
Date: ? ;;2-~. 01
Respectfully submitted,
~
J.D. No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
,Ii:'",' . <.__c", )-0",.... '<- ~~~~~~IlI,.j~~~_$,'J~'~",,\W.N.kiUfii~la!-JI#!~~~Jtiilllill;l'.ij!lllIIn.lni~~/t~'--=..;. ~
r~
"
~~~4j
\'
.~=,~-~
..-
. ~.-,=-
C)
~-
i~t~
~t:
:'-..>-(~,
5~:
:-;j
~,
.,
"
1",--.)
t,.c,
~TI
t~~
:::>
'-.J
.Ill' .' .....
I
~:~:!
:U
-<.,:
~
~
.
'\
~
--
~
'd
os
--
..j
~ 1\
~ ~
t:
r
it
''''f'-
-
~~
.
KATHLEEN A. ZIMMERMAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: No. 01 - 3252 Civil Term
RICKEY 1. ZIMMERMAN,
Defendant
: ACTION IN DIVORCE
AFFIDAVIT OF SERVICE OF
NOTICE TO DEFEND AND COMPLAINT.
AND NOW, this June 11,2001, I, Jane Adams, Esquire, hereby certify that
on June 8, 2001, a true and correct copy ofthe NOTICE TO DEFEND AND COMPLAINT
were served, via certified mail, restricted delivery, return receipt requested, addressed to:
Rickey 1. Zimmerman
49 N. East Street, Apt 3
Carlisle, Pa. 17013
DEFENDANT
Respectfully Submitted:
an Adams, Esquire
I . No. 79465
117 South Hanover St.
Carlisle, Pa. 17013
(717) 245-8508
ATTORNEY FOR PLAINTIFF
~~ - . iltIi!~'iih
-
~
i<lI<illifil,llitiWii!IiIiii~~~~"~~;~~"'",:~...:m-"""I0ri"",Q:i!iJiI~~!Wll:l~r..-.,,,,,,,""'Ill'-"'--'-' ~,.,
..
uL .
V--""\~
-~~""~,;\::;,~_?,,,,~;;;::~.,., ~~,,,,,~_<~LL-,,,.,, ,',C," ""'""~,'_?_'~,, ~,~_~,' ',." .."""="'_, ''''''>'_" '^~. _'_',,""", _,~~
"'~.'
Ni:l.J
,"''''''''~ ,;J.'= ~,' -w-__'
(")
c::
?
~.-"
va:-
~m
_ ::C
<C
C/j ,.1:':'-
;:5.",:
'0
~
<0
~()
2
:';!
N
c;:,
.
.
o
-
:.:,)
11
:::g~JJ
~-
~~
..~
J'"
:;0
-;:
<:....
~
"
::it
~
-=
<'"
".' ""','
"""".f-,
, -.. " (~-,-- '- ,,'>
" ." ,_~. "''--<__o~ .",," t ,"d,' , .
;0 .&mp~eitein's i, 2, and 3. Also complete
it_~:m -4 if Restricted Delivery is desired.
. Print your name and, address on the reverse
so that we can return the card to you.
. Atta',p1 this card to the back of the mailpiece, X
or on tl:l,e front if space permits.
1. Article Addressed to:
Il-;C~e;:r L . 27fl1fJA~),ruJ)M
fCf. /U .~ Sj}.edlf{f.3
~1?4/7o/.3
o Agent
o Addressee
Dyes
o No
tfrom item 1?
. ery address below:
o Express Mail
o Return Receipt for Merchandise
o C.O.D.
I I '
\ \ ~
10259S-OO-M-0952
~ .
=.";J,~"""_;,,
-" ~M;;,<;oo~;-,
KATHLEEN A. ZIMMERMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 01 - 3252 Civil Term
RICKEY L. ZIMMERMAN,
Defendant
ACTION IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301 (c) of the Divorce Code was filed on
lIJag-a CJ/ ~O() I . .
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed
from the date of the filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to request
entry of the decree.
I verify that the statements made in this affidavit are true and correct. I also understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unsworn falsification
to authorities.
Date: 10' (0 ' d I
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER 633011cl OF THE DIVORCE CODE
1. I consent to entry of a final decree of divorce without notice.
2. 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.
3. 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.
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.
Date: /o./d.rJ/
~
-"
""" ,,~,
~,<~ > .-,',,-,J-'>' '__~;h~'
~1!~iJil:~~.~1i4"ffj_,;e_'I;:,"jo;::l'I,,",,-,"-I;;,,;~iii\J:(MIil,,~ii!;%liiO_lliI_
, ".".-,,^,% ,~. ,,,"'''< ~- . -
_ex_;-" '~_"'___ ... ~w.
n
~-,
,.~ __ =""~ _'''rl
.......~
(")
*
~B~
7r::--
~i,-
;?: cc;:~'
=,,-=::: ;
~c
.2::
:;~
__ ,C _~
"iI
c-;
"
.~
~
.""'~
, ,
~'-:
--t-:;
~:,.)
~~
-...."'
-<:
.
~
. l ~
"","", r- -....w...."'..>t_;:
KATHLEEN A. ZIMMERMAN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 01 - 3252 Civil Term
RICKEY L. ZIMMERMAN,
Defendant
ACTION IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on
~;?~, :J>CDI .
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed
from the date of the filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to request
entry of the decree.
I verify that the statements made in this affidavit are true and correct. I also understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. 4904, relating to unswom falsification
to authorities.
Date: I () ./ ( . () I
WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER 63301/c\ OF THE DIVORCl: CODE
1. I consent to entry of a final decree of divorce without notice.
2. I understand that I may lose rights conceming alimony, division of property, lawyer's fees or
expenses if I do not claim them before a divorce is granted.
3. 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.
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 unswom falsification
to authorities.
Date:
(0 -l/tO/
'it~~~
, Defendant
'jWllltlllii:,~.~~m-_~r.l!iHl!~il.IDW,i...wJ-"d,;,d;:;'!,-""'~'lli,,~''',&lli:.~~I"",j,,;.!:,,,""'m''''f.1,~jl:Jlli~iM~~~-lI8;!~~'~ ~iltm~~~~
~itj~u-:
~L
'/:;-<,~
v
",'~, " , ..,~-' '. ~_ .~e~~w, ~_,_, ___."m''''
~"'.
.., """-- -".~,
"-_~"_~'~"m___
.1
_~'_~~".- ~~ d..
l~.iiil ""~
-CC.":'
~~r
~-
({) -.
-</
~c
~~~
~
--'j.
-<
o
..~..
~-;:
C:)
II1IKiI
,t~
=>
~
:r.
:_)
'--,
~-
:.')
':-0
~