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Home My WebLink About01-03994IN TT-IE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA HOLLY M. ZEDAKER, Plaintiff vs. ROBERT M.ZEDAKER, Defendant * * CIVIL ACTION - LAW 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 Sq THE CASE MAY PROCEED WITHOUT YOU AND A DECREE OF DIVORCE OR ANN[LMENT MAY BE ENTERED AGAINST YOU BY THE COURT. A NDGMENT 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 THE 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, 1 COURTHOUSE SQUARE, CARLISLE, PA 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 LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717)249-3166 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA HOLLY M. ZEDAKER, Plaintiff * vs. * * ROBERT M.ZEDAKER, Defendant NO. ~ l- 3 99Y ~ev~e ~iw.. CIVIL ACTION - LAW IN DIVORCE COMPLAIINT IN DIVORCE COUNTI 1. The Plaintiff is Holly M. Zedaker, who currently resides at 2806 Fairview Road, Camp Hill,. Cumberland County, Pennsylvania since May of 2001. 2. The Defendant is Robert M. Zedaker who currently resides at 4665 Pheasant Run North, Reading, Berks County, Pennsylvania since June of 1982. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on Mazch 13, 1976 in New Cumberland, Cumberland County, Pennsylvania. 5. There is one minor child of the parties: Alexis Ann Zedaker; D.O.B. 03/02/1985. 6. There have been no prior actions of divorce or annulment between the parties. 7. Neither party is presently a member of the Anned Forces on active duty. 8. The parties have not entered into a written agreement as to alimony, counsel fees, costs, and property division. 9. Plaintiffhas been advised that counseling is available and that plaintiffmay have the right to request that the court require the parties to participate in counseling. Beirig so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued by the Court. 10. The cause of action and sections of Divorce Code under which Plaintiff is proceeding are: (a) §3301(c). The marriage of the parties is irretrievably broken. 11. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, the Plaintiffrequeststhe Court enter an Order dissolving the marriage between the Plaintiff and Defendant. COUNT II -- ALIMONY PENDENTE LITE. COUNSEL FEES. COSTS AND EXPENSES 12. Paragraphs one (1) through twelve (12) are incorporated herein by reference as though set forth in full. 13. Plaintiffhas employed counsel, but is unable to pay the necessary and reasonable attorney's fees for said counsel. 14. Plaintiff is unable to sustain herself during the course of this litigation. WHEREFORE, Plaintiff requests the Court enter an award of Alimony Pendente Lite, interim counsel fees, costs and expenses, until final hearing and thereupon award such additional counsel fees, costs and expenses as deemed appropriate. Dated: d/ Respectfully submitted, WILEY, LENOX, COLGAN & MARZZACCO, P.C. ~r ~ Christine J. Tay squire 1 South Baltimore Street Dillsburg, PA 17019 (717) 432-9666 I.D. # 82204 VERIFICATION I, }-~p~~, ~ 1'~ . ~e d g~(, verify that the statements made in this document are true and correct to the best of my lmowledge, information, and belief. 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: (p//~ ~~ ~-~ ~~ ~ `~ ion ~ ~~~~~ U, ~ ~ ~ i yt ~ ~ _~ ~ M Q C7 ~ • -~. C: _ -` ,~~ [_ ~ rf: -t f ' .~ r _ ~ : - ~ ~ ~~ ~s ~~-m ~R ... I .. ~~'* i a ~> "v`: r 's. k° nx~n^aR,as a _ ' Ht!w ae e'E, "tS=-eR~H 9 =h~F?"~F;w HOLLY M. ZEDAKER, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION -DIVORCE NO. 01-3994 CIVIL TERM ROBERT M. ZEDABER, IN DIVORCE DefendanURespondent DR# 30909 Pacses# 992103712 ORDER OF COURT AND NOW, this 9th day of August, 2001, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby duetted that the parties and their respective counsel appeaz before RJ. Shaddav on September 14.2001 at 9:00 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11® (4) verification of child caze expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appeaz for the conference or bring the required documents, the Court may issue a warrant for your arrest. Mail copies on Petitioner 8-9-O1 to: < Respondent Christine Taylor, Esquire Thomas Binder, Esquire Date of Order: August 9, 2001 BY THE COURT, Geacge E. Hoffer, President Judge - /~ R. J. hadday, Conference Officer YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717)249-3166 ~.~,,,~ d~N~~n~~s~n~~~v~~n~ ~~~~~ y.r .fit ~~R~1~0 ~' ''S~ '~ ~',',_ ~ f(9 f[k'.bsfl - -fix _ .$iM,. 3#±'8~~~~ ~o- .i':" +F i:.~-.. e ^rvh rf:446b RC..5"'EC92.~jii ~,~ s:d":`1Jilk'*`M19'ifl~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA HOLLY M. ZEDAI{ER, * NO.Ol-3994 Plaintiff vs. * CIVIL ACTION - LAW IN DIVORCE ROBERT M. ZEDAKER, Defendant PETITIO FOR ALIMONY PENDENTE LITE. COUNSEL FEE5. COSTS AND TO THE HONORABLE JUDGES OF SAID COURT: AND NOW, to wit, this 29th day of June, 2001, comes the Plainit$ Holly M. Zedaker, (hereinafter "Petitioner") by her attorney, Christine J. Taylor, Esquire of Wiley, Lenox, Colgan, & Marryacco, P.C., and files the instant Petition and respectfully presents the following: On June 27, 2001, Plaintiff filed a Complaint in Divorce based upon the irretrievable breakdown of the parties' marriage. A copy of the Divorce Complaint is attached hereto as Exlnlrit "A." 2. The parties were married in 1976 and two children were produced during the marriage. Petitioner has not worked in a full time position since the parties' children were born as she stayed at home to raise the two children. 4. Petitioner avers that Respondent, Robert M. Zedaker, currently earns approximately $85,000 per year, excluding any bonuses he may receive. 5. Petitioner is unable to sustain herself during the course of this litigation. 6. Petitioner has retained legal counsel and is unable to pay the necessary and reasonable attorney's fees for said counsel. WFIEREFORE, Petitioner respectfully requests this Honorable Court to schedule a conference so that an appropriate award of alimony pendeme lite, counsel fees, costs and expenses maybe entered pending the divorce action. Dated: ~ Respectfully submitted, ~ /_" Christine J. Taylof, Esgt WII.EY, LENOX, COL & MARZZACCO P.C. 1 South Baltimore Street Dillsburg, PA 17019 (717)432-9666 I.D. #82204 VERIFICATION I, -loll u N • ~ c~ak.e c ,verify that the statements made in this document are true and correct to the best of my lrnowledge, information, and belief. 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: ~0/ /~' ~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUN'T'Y, PENNSYLVANIA HOLLY M.ZEDAKER, * NO• QI'c~970"`I ~tU~`, / Plaintiff vs. * CIVIL ACTION - LAW IN DIVORCE ROBERT M. ZEDAI~ER, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS YOUHAVE 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 1N THESE PAPERS BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU, INCLUDING CUSTODY OR VISITATION OF YOUR CHII.DREN. WHEN 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 IN THE OFFICE OF THE PROTHONOTARY AT THE CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA 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 LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA. HOLLY M. ZEDAKER, * N®• Plaintiff vs. * CIVIL ACTION - LAW IN DIVORCE ROBERT M. ZEDAKER, Defendant COMPLAINT IN DIVORCE OC UNTI 1. The Plaintiff is Holly M. Zedaker, who currently resides at 2806 Fairview Road, Camp Hill, Cumberland County, Pennsylvania since May of 2001. 2. The Defendant is Robert M. Zedaker who currently resides at 4665 Pheasant Run North, Reading, Berks County, Pennsylvania since June of 1982. 3~ P~and Z?efendant have been bona fide residents in the Commonwealth for at least six m¢nths h k `C \ ~' .~.. 4 T~ 1}laintitl' and Defendant were married on March 13, 1976 in I3ew Cumberland, Cumberland County, Pennsylvania. 5. There is one minor child of the parties: Alexis Ann Zedaker; D.O.B. 03/02/1985. 6. There have been no prior actions of divorce or annulment between the parties. 7. Neither party is presently a member of the Armed Forces on active duty. 8. The parties have not entered into a written agreement as to alimony, counsel fees, costs, and property division. 9. Plaintiffhas been advised that counseling is available and that plaintiffmay have the right to request that the court require the parties to participate in counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued by the Court. 10. The cause of action and sections of Divorce Code under which Plaintiff is proceeding aze: (a) §3301(c). The marriage ofthe parties is irretrievably broken. 11. Plaintiff requests the court to enter a decree of divorce. `r WHEREFORE, the Plaintiffrequestsrhe Court enter an Order dissolving the marriage between the Plaintiff and Defendant. COUNT II -- ALIMONY PENDENTE LITE. COUNSEL FEES. COSTS AND EXPENSES 12. Paragraphs one (1) through twelve (12) are incorporated herein by reference as though set forth in full.. 13. Plaintiffhas employed counsel, but is unable to pay the necessazy and reasonable attorney's fees for said counsel 14. Plaintiff is unable to sustain herself during the course of this litigation. WHEREFORE, Plaintiff requests the Court enter an awazd of Alimony Pendente Lite, interim counsel fees, costs and expenses, until Sna1 hearing and thereupon awazd such additional counsel fees, costs and expenses as deemed appropriate. Respectfully submitted, V6~ILEY, LENOX, COLGAN & MAR7,7,ACC0, P.C. r ~ ' Dated: ~ d/ U Christine J. Tay squire 1 South Baltimore Street Dillsburg,PA 17019 (717)432-9666 .___ LD. # 82204 m... ~ . _ _._... _ t, VERITICATION I, ~p~ N • ~e e~af.e~ ,verify that the statements made in this document are true and correct to the best of my knowledge, information, and belief. 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: (P~~ LCT~ n _, n" -f' - -G (% -, i <. In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION HOLLY M. ZEDAKER vs. ROBERT M. ZEDAKER Plaintiff Defendant AND NOW, to wit on this Docket Number 01-3994 CIVIL ) PACSES Case Number 9921o371z Other State ID Number ORDER 25TH DAY OF APRIL, 2003 IT IS HEREBY ORDERED that the Q Complaint for Support or Q Petition to Modify or ®Other ALIMONY PENDENTE LITE REQUEST filed On AUGUST 8, 2001 in the above captioned matter is dismissed without prejudice due to: THE PLAINTIFF NOT PURSUING THE MATTER THROUGH THE CUMBERLAND COUNTY DOMESTIC RELATIONS SECTION SINCE THE SEPTEMBER 20, 2001 BERKS COUNTY ORDER TO STAY THE MATTER. ® The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. DRO: RJ Shadday xc: plaintiff defendant Thoims Binder, Esquire Christine Taylor, Esquire Service Type M "~ h' BY THE COURT: .. ! G+ Edgar B. Bayley GE Form 0E-506 Worker ID 21005 z ~.~'~ ``' =d Utz ~~ `r ~ e r" ~ G V _}