HomeMy WebLinkAbout99-05288:-
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IN THE COURT OF COMMON PLEAS
OFCUMBERLAND COUNTY
.N
STATE OF PENNA.
4ul'n e
ELEANOR E. ZINN,
N O, 99 - 5288 CIVIL TERM
Plaintiff
VERSUS
KENNETH W. ZINN. JR..
Defendant
DECREE IN
DIVORCE
AND NOW, ?)Ct, 1-7 L20E-7 I IT IS ORDERED AND
DECREED THAT Eleanor E. Zinn , PLAINTIFF,
AND Kenneth W. Zinn, Jr. , 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;
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BY AHE COU
ATTEST: - /n J
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TOY AR[ N[R[tY 10111 1[1 TO IL[ADWITHINTO
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T1T[NTY ItD1 DAYt 0/ /[RVIC[ N[R[OIOR
A DtIADLT JDDOM[NT MAY [[ [NT[Rr,D
AGAIN/T YOU. A
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LAW OFFICE
JAMES, SMITH, DURKIN & CONNELLY, LLP : tnNffRKwi o[coneTHAT THIY ITHINi[
-A ORIGINAL FILED IN THIS ACTION,
P. Q 13OX 630
HERSHEY, PENNSYLVANIA 17033-0630 By
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KENNETH W. ZINN, JR.,
Plaintiff
V.
ELEANOR E. ZINN,
Defendant
To the Prothonotary:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA.
NO. 99 - 5288 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
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 ( ) 3301(c)
(XX) 3301(d) of the Divorce Code.
2. Date and manner of service of the Complaint: October 20, 1998 by certified mail
number Z 104-208-621.
Complete either paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent and Waiver of Counseling
required by Section 3301(c) of the Divorce Code: by Plaintiff: ; by Defendant:
(b) (1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of
the Divorce Code: November 30, 2000.
(2) Date of service of the Plaintiffs Affidavit upon the Defendant: December 11,
2000.
4. Related claims pending: None.
5. Date and manner of service of the notice of intention to file Praecipe to Transmit
Record, a copy of which is attached, if the decree is to be entered under Section 3301(d) of the
Divorce Code: December 11, 2000.
6. Date and manner of service of Notice of Intention to file Praecipe to
Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d)
of the Divorce Code: December 11, 2000 by certified mail number 7099 3400 0009 2916 1554.
or, date of execution of Waiver of Notice of Intention to Request Entry of a Divorce Decree
under Section 3301(c) of the Divorce Code: by Plaintiff: ; by Defendant:
and, date of filing of the Waiver of Notice of Intention to Request Entry of a Divorce
Decree: .
Date: o'LS U
JAMES, SMITH, DURKIN & CONNELLY LLP
John *Connply, Jr., Esquire
Atto y for P aintiff
Rom dBox 650
Hershey, PA 17033
(717) 533-3280
PA I.D. No. 15615
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KENNETH W.ZINN, JR., IN THE COURT OF COMMON PLEAS
Plaintiff CAMERON COUNTY, PENNSYLVANIA
V. NO. 98-5974
ELEANOR E. ZINN, CIVIL ACTION - LAW
Defendant DIVORCE
ORDER
AND NOW, this /y day of / 1999, upon consideration of
Plaintiff's Petition to Transfer Pursuant to Pa. R.C.P. 1006(d)(1) and it appearing that the
convenience of the parties and the witnesses would be served thereby, it is hereby ordered that
this action is transferred to the Court of Common Pleas of Cumberland County.
It is further ordered that the Prothonotary shall forward the record to the Prothonotary
of the Court of Common Pleas of Cumberland County as provided under Pa. R.C.P.
1006(d)(3), upon payment by Plaintiff of all costs and fees therefor.
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True and Correct COPY
certified from the
Records of Cameron CO. -
Penna.
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Document 4 155358
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KENNETH W. ZINN, JR., IN THE COURT OF COMMON PLEAS
Plaintiff CAMERON COUNTY, PENNSYLVANIA
V. NO. 98-5974
ELEANOR E. ZINN, CIVIL ACTION - LAW
Defendant DIVORCE
PLAINTIFF'S PETITION TO TRANSFER VENUE
PURSUANT TO PA. R.C.P.1006(d)(1)
Plaintiff, Kenneth Zinn, Jr., files this Petition pursuant to Pa. R.C.P. 1006(d)(1) to transfer
this action to the Court of Common Pleas of Cumberland County for the convenience of the parties
and the witnesses, for the following reasons:
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I. Plaintiff, by his former counsel, instituted this divorce action in Cameron Canty.
2. Both Plaintiff and Defendant reside in Cumberland County, Pennsylvania -
3. Under Pa. R.C.P. 1920.2(a)(1), this action could have been originally iQOught. in
Cumberland Coun O1
ty, since both Plaintiffand Defendant reside in that county.
4. While venue is lawful in the present county, this action should be transferred to
Cumberland County for the convenience of the parties and the witnesses and in the interest of
judicial economy and efficiency.
5. All of the witnesses who may be called in this action, including both Plaintiff and
Defendant, are residents of or work in Cumberland County or the several counties surrounding
Cumberland County.
True and Correct Copy ,
certified from the
Records of Cameron Co.
Penna.
?J'n 1_
Prpt(J
Document #155358
6. The time and expense of bringing these witnesses to this Court for trial or a
Master's hearing in this action and the inconvenience to the witnesses will be substantial should
this action remain in this county.
7. Defendant will not be prejudiced or injured by the transfer of this action to
Cumberland County. In fact, Defendant is currently being represented by pro bono counsel whose
office is located in Cumberland County, Pennsylvania.
WHEREFORE, Plaintiff requests this Court to transfer this action to the Court of Common
Pleas of Cumberland County.
METZGER, WICKEIjfjliAM, KNAUSS & ERB, P.C.
By:
rchard B. Druby, Esq
Attorney I.D. No. 61904
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
to
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q Attorneys for Plaintiff
Dated: 7??G h I _
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True and Correct Copy
certified from the
Records of Cameron Co.
Penna. ?- ,
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-2- Prothonotary 1
Document #155358
VERIFICATION
I, Kenneth W. Zinn, Jr., hereby certify that the facts set forth in the foregoing Plaintiff s
Petition to Transfer Venue Pursuant to Pa. R.C.P. 1006(d)(1) are true and correct to the best of my
knowledge, informationand belief, and that false statements herein are made subject to the
penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsificationto authorities.
Kenneth W. Zinn, Jr.
Date: a-2,9-'71
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True and Correct COPY
certified from the
Records of Cameron Co.
Penna.
Prothonotary Q lie s
Document M 155358
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CERTIFICATE OF SERVICE
AND NOW, this L6 ]?day of July, 1999, 1, Richard B. Druby, Esquire, of Metzger,
Wickersham, Knauss & Erb, P.C., attorneys for Defendant, hereby certify that I served a copy of
the within Plaintiff s Petition to Transfer Venue Pursuant to Pa. R.C.P. 1006(4)(1) this day by
depositing the same in the United States mail, postage prepaid, at Harrisburg, Pennsylvania,
addressed to:
Lindsay Baird, Esquire
37 South Hanover Street
Carlisle, PA 17013-4240
to
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True and Correct Copy
certified from the
Records of Cameron Co.
Penna.
Document# 155359
IN THE COURT OF COMMON PLEAS OF CAMERON COUNTY
Fifty - Ninth Judicial District
NO: 98- 5974
RECORDED: 10/09/98 DEBT: $ 0.00
BOOK: PAGE: 0 SURCHARGE: 10.00
KIND: DIV PRO' 30.50
JCP FEE: 5.00
SAT DATE: 07/19/99
<PLAINTIFF> 1 ZINN KENNETH W JR
<DEFENDANT> 1 ZINN ELEANOR E
OCTOBER 9, 1998 - Plaintiff's Complaint in Divorce filed by JEANNE B.
WIGBELS, ESQ.
SAME DATE: Certified copy of Complaint with endorsement thereon to plead to
same, issued for service upon the defendant.
Verification filed:
JULY 19, 1999 - Plaintiff's Petition to Transfer Venue Puruant to PA.R.C.P.
1006(d)(1) Filed. Entire filed sent to judge.
JULY 20, 1999 - ORDER OF COURT FILED.
AND NOW, this 19th of July, 1999, upon consideration of Plaintiff's Petition
to Transfer Pursuant to Pa. R.C.P. 1006(d)(1) and it appearing that the
convenience of the parties and the witnesses would be served thereby, it is
hereby ordered that this action is transferred to the Court of Common Pleas
of Cumberland County.
It is further ordered that the Prothonotary shall forward the record to the
Prothonotary of the Court of Common Pleas of Cumberland County as provided
under Pa. R.C.P. 1006(d) (3), upon payment by Plaintiff of all costs and fees
therefor.
BY THE COURT
/s/ Vernon D. Roof, President Judge
True and Correct COPY
certified from the
Records of Cameron Co.
Penna.
Prothonotary
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KENNETH W. ZINN, JR.,
Plaintiff
V.
ELEANOR E. ZINN,
Defendant
IN THE COURT OF COMMON PLEAS
CAMERON COUNTY, PENNSYLVANIA
No. / 5-77Y
CIVIL ACTION • LAW
DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to wish to defend against the claims set'fordr,in
the following pages, you must take prompt action. You are warned that if you fail to do so, the
case may proceed without you, and a decree of divorce or annulment may be entered against you
by the court. A judgment may also be entered against you for any other claim or relief requested
in these papers by the Plaintiff. You may lose money or property or other rights important to
you, including custody or visitation of your children.
When the ground for 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 Cameron County Courthouse, Emporium, 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.
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DAVID J. REED, PROTHONOTARY
CAMERON COUNTY COURTHOUSE
EAST FIFTH STREET Trite and Con*d Ccpy
EMPORIUM, PENNSYLVANIA 15834 certified from the
TELEPHONE: (814) 486-3349 Records of Cameron CO-
Penna.
Prothonotary
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KENNETH W. ZINN, JR.,
Plaintiff
V.
ELEANOR E. ZINN,
Defendant
IN THE COURT OF COMMON PLEAS
CAMERON COUNTY, PENNSYLVANIA
No.c
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CIVIL ACTION - LAW -
DIVORCE
i
COMPLAINT IN DIVORCE UNDER
SECTIONS 3301(c) or 3301(d) OF THE DIVORCE CODE
The Plaintiff, Kenneth W. Zinn, Jr., by and through his attorney, Jeann6 B. Wigbels,
Esquire, avers the following:
1. The Plaintiff , Kenneth W. Zinn, Jr., is an adult individual who currently resides at 2951
Croyden Road, Harrisburg, Dauphin County, Pennsylvania.
2. The Defendant, Eleanor E. Zinn, is an adult individual who currently resides at 833A
Market Street, Lemoyne, Cumberland County, Pennsylvania.
3. The Defendant and the Plaintiff have been bona fide residents of the Commonwealth of
Pennsylvania for at least six months immediately prior to the filing of this Complaint.
4. The Plaintiff and the Defendant were married on July 14, 1989 in Harrisburg, Dauphin
County, Pennsylvania.
COUNT I - DIVORCE
5. Paragraphs one (1) through four (4) are incorporated herein by reference as if setforth
True and Coned Copy
specifically below. Certified from the
Records of Cameron Co.
Penna.
,;hn?n,ary " J
6. There have been no prior actions of divorce or for annulment between the parties.
7. The marriage is irretrievably broken.
8. The Plaintiff has been advised that counseling is available and that the Plaintiff mad; -
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have the right to request that the court require the parties to participate in counseling.
9. This action is not collusive. - -77
WHEREFORE, the Plaintiff respectfully requests this Honorable Court gr?nf the Plaintiff
relief from the bonds of matrimony and order a Decree in Divorce.
Jear# B. Wigbels, Esquire
WI BELS & WELCH
1400 North Second Street
Harrisburg, Pennsylvania 17102
PA Supreme Court 1D No. 68735
Telephone: (717) 221-0900
Dated: ...mZj§r Fax: (717) 221-0904
True and Correct COPY
certified from the
Records of Cameron CO-
Penna.
0-n1honote?V
KENNETH W. ZINN, JR., IN THE COURT OF COMMON PLEAS
Plaintiff CAMERON COUNTY, PENNSYLVANIA
V. No.
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ELEANOR E. ZINN : CIVIL ACTION - LAW
Defendant DIVORCE
-77
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VERIFICATION
I, Kenneth W. Zinn, Jr., hereby verify that the statements made in the foregoing Divorce
Complaint are true and correct. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. §4904, relating to unworn falsification to authorities.
Date: 1 0 - Ll - 9 ? Signature:
Kenneth W. Zinn, Jr.
True and Correct COPY
certified from the
Records of Cameron CO-
Penna.
PrI)tfrOr?4?ry ' ?F ..
To LAw OFFICE
YOU ARE HERESY NOTIFIED TO ILIAD TO • ??CO WE HERESY CERTIFY THAT THE WITHIN 12
THE ENCLOSED WITHIN JAMES, SMITH, DURKIN & CONNELLY, LLT, .. A TADS AND CORA[CT colt Or THE
YW[NTT DO DAYS OF E[RVICE HEREOF OR N ORIGINAL IIL[DINTHIS ACTION.
A DEFAULT JUDGMENT MAY St ENTERED P. Q BOX 630 r
AGAINST YOU. SY
[r HERSHEY, PENNSYLVANIA 1`703341630 ATTOMMEN
AT 11
KENNETH W. ZINN, JR., : IN THE COURT OF COMMON PLEAS
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 99-5288 CIVIL TERM
ELEANOR E. ZINN, : CIVIL ACTION - LAW
DEFENDANT : IN DIVORCE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
SS.
AND NOW, thisjjjj-day of;k&fY AJL) , 2000, personally appeared before
me, a Notary Public in and for the State and County aforementioned, John J. Connelly, Jr., Esquire,
who, being duly swom according to law, deposes and says that a copy of the Complaint in Divorce
was served on the Defendant, Eleanor E. Zinn, on by certified mail number Z 104 208 621,
addressee only, return receipt requested, as evidenced by the return receipt card attached hereto and
made a part hereof.
Sworn to and subscribed
before me this ?L
day of,t p ?U, 2000.
Notary Public
NOTARIAL SEAL
Jean L. Kosier, Notary Public
City of Hummelstown,County of Dauphin
My Commission Expires Feb. 9, 2004
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KENNETH W. ZINN, JR.,
Plaintiff
V.
ELEANOR E. ZINN,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5288 CIVIL TERM
CIVIL ACTION- LAW
IN DIVORCE
NOTICE OF INTENTION TO RFOI TEST ENTRY OF DIVORCE I)EME
TO: Eleanor E. Zinn, Defendant
822A Market Street
Lemoyne, PA 17043
You have been sued in an action for divorce. You have failed to answer the Complaint or
file a Counter-Affidavit to the Section 3301(d) Affidavit. Therefore, on or after December 25,
2000, the other party can request the court to enter a final Decree in Divorce.
If you do not file with the Prothonotary of the court an Answer with your signature
notarized or verified of a Counter-Affidavit by the above date, the court can enter a final Decree
in Divorce. A Counter-Affidavit which you my file with the Prothonotary of the court is
attached to this notice.
Unless you have already filed with the court a written claim for economic relief, you
must do so by the above date or the court may grant the divorce and you will lose forever the
right to ask for economic relief. The filing of the form Counter-Affidavit alone does not protect
your economic claims.
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 `'HERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Phone: (71;
Hershey, PA 17033
(717) 533-3250
PA I.D. No. 15615
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KENNETH W. ZINN, JR., : IN THE COURT OF COMMON PLEAS
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA.
V. N0.99.5388 CIVIL TERM
ELEANOR E. ZINN, CIVIL ACTION - LAW
Defendant : IN DIVORCE
CERTIFMCAT OFS RVI
I, John J. Connelly, Jr., Esquire, of James, Smith, Durkin & Connelly, attorney for the
Plaintiff, Kenneth W. Zinn, hereby certify that I have served a copy of the foregoing Notice of
Intention to Request Entry of Divorce Decree, 3301(d) Affidavit, and Defendant's Counter-
Affidavit Under Section 3301(d) of the Divorce Code on the following on the date and in the
manner indicated below:
U.S. FIRST CT eSC CERTIFIED Merr
Eleanor E. Zinn, Defendant
S22A Market Street
Lemoyne, PA 17043
DATE:
JAMES, SMITH, Dl
Bv: ?.-
Jolm J. Gorlnelly? Jr.,
Post Office Box 65(
Hershey, P A 17033
(717) 533-3280
PA I.D. No. 15615
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KENNETH W. ZINN, JR.,
Plaintiff
v.
ELEANOR E. ZINN,
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLV.A -1A
NO.99-5288 CIVIL TERM
: CIVIL ACTION - LAW
: IN DIVORCE
DEFENDANT'S COUS7ER-AFFIDAVIT IND RSE 110N3301(d)OF
THE DIVORCE OD
1. Check either (a) or (b):
_(a) I do not oppose the entry of a divorce decree.
._(b) I oppose the entry of a divorce decree because
(Check (i), (ii) or both):
(i) The parties to this action have not lived separate and apart for a period of at least
two years.
- (ii) The marriage is not irretrievably broken
2. Check either (a) or (b):
_(a) I do not wish to make any claims for economic relief. I understand
that I may lose rights concerning alimony, division of proper Y, lawyer's fees of expenses if I do not
claim them before a divorce is -aranted.
_(b) I wish to claim economic relief which may include alimony, division
of property, lawyer's fees or expenses of other important rights.
•I
I understand that in addition to checking (b) above, I must also file all of my economic
claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before
the date sut forth on the Notice of Intention to Request Divorce Decree, the Divorce Decree may be
entered without further delay.
I verify that the statements made in this counter affidavit are true and correct. I understand
that false statements herein are made subject to the penalties of 1 S Pa.C.S. 4904 relating to unswom
falsification to authorities.
Date:
Eleanor E. Zinn, Defendant
NOTIC E' IF YOU D NOT W IS H T O OPP CF THE Ft. ), OF 4
DIVOR CE DECREE AN D Y Q 11 D O NO T 'AT H TO MA KE ANY CLAIM
FOR ECONOMIC RELI EF YO U NEF n NO T FILE T HIS COUNT7,R
AFFID AVIT.
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KENNETH W. ZINN, JR.,
Plaintiff
V.
ELEANOR E. ZINN,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5288 CIVIL TERM
CIVIL. ACTION - LAW
IN DIVORCE
NOTICE TO THE DEFENDANT
If you wish to deny any of the statements set forth in this Affidavit, you must file a
Counteraffidavit within twenty (20) days after this Affidavit has been served on you or the
statements will be admitted.
P -. LN- IFF'S 4VIT TU-NME
R
SECTION 3301(d) OF THE DIVORCE CODE
1. The parries to this action separated since September of 1998, and have continued to
live separate and apart for a period of at least two (2) years.
2. The marriage is irretrievably broken.
I I understand that I may lose rights concerning alimony, division of property,
lavtyer's fees or expenses if I do not claim them before a divorce is granted.
I verify that the statements made in tins Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unworn falsification to authorities.
Date: 11- 3 o - o c /Lc _ s v Zv. '2A ,_
Kenneth W. Zinn, Jr., Plaintiff
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TO LAW OFFICE _--
YOU ARC "CARRY NOTIFIED TO FLEAD TO
THE ENCLOSED WITHIN 7?LA [)M,? T WC HERESY CERTIFY THAT THE WITHIN IE
TWENTY DD DAYS OF 99MCE HEREOF OR JAm , O ffH, DURKIN & CONNELLY, LLP A TRUE AND CORREOT Copy W THE
-A DEFAULT JUDGMENT MAY CE C"ho ORIGINAL FILED IN THIS ACTION.
AGAIREr You. P. Q Box 450 ,Er _.-
Er ArraRHEY HERSHEY, PENNSYLVANIA rM33fi6" A lG
KENNETH W. ZINN, JR.,
Plaintiff
V.
ELEANOR E. ZINN,
Defendant
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNA
NO. 99 - 5288 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
Please enter the following social security numbers in the above-captioned divorce action:
Kenneth W. Zinn, Jr. - 194-56-6485
Eleanor E. Zinn -196-48-4868
JAMES, SMITH, DURKIN & CONNELLY LLP
Date: 1c) ?- By:
John
Hershey, PA 17033
(717)533-3280
PA I.D. No. 15615
Esquire
YOU ADS HERBERT NOTIFIED TO READ TO LAW OFFICE
It
CKATIFY THE WITHIN
CORR ECT cC oTHAT n OF TXE
THE ENCLOSED WITHIN o. WE HEEOY
TWENTY lm DAVE OF SEIIVICE HEREOF 011 JAMES,SMITH, DURKIN OL ?ONNB.I.Y, LLF A TRUE AND D .
A DEFAULT JUOOMENT MAY BE ENTEEEG` ORIGINAL RL[D IN N THIS TXIt ACTION. 4.
AGAINST YOU. = PQBOX 650 BY' .l .5.,,
ATTORNEY
tr HERSHEY, PENNSYLVANIA 17033-06M
KENNETH W. ZINN, JR., : IN THE COURT OF COMMON PLEAS
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
V. :NO. 99-5288 CIVIL TERM
ELEANOR E. ZINN, : CIVIL ACTION - LAW
DEFENDANT : IN DIVORCE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
SS.
AND NOW, this ,2g3, day of ?l , QOX X)c) + 2000, personally appeared before
me, a Notary Public in and for the State and County aforementioned, John J. Connelly, Jr., Esquire,
who, being duly sworn according to law, deposes and says that a copy of the Notice of Intention to
Request Entry of Divorce Decree, Plaintiffs Affidavit, and Defendant's Counter-Affidavit was
served on the Defendant, Eleanor E. Zinn, on December 11, 2000 by certified mail number 7099
3400 0009 2916 1554, addressee only, return receipt requested, as evidenced by the return receipt
card attached hereto and made a part hereof.
Swam to and subscribed
before me this Aad-
day of u , 2000
Notary Public '
NOTARIAL SEAL
Jean L. Kosier, Notary %b) lic
City of Hummelstown,County Dauphin
my commission Expires Feb. 9, 2004
t
e Complete Items 1, 2, and 3. Also complete
item 4 if Restdcted Delivery is desired.
• print your name and address on the reverse
so that We can return the card to you.
¦ Attach this card to the back of the mailPlece,
or on the front if space Permits.
1. Angle Addressed to: r
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?mvv?E PA I?o4f.
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-Yees
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NO
D. Is delivery Merenl em 17'-a? s
": (No
If VES, enter tlelivery addre?
3. Service TYPa
Certified Mail ? Express Mail
? Registered ? Return Receipt for Merchandise
? Insured Mail ? C.O.D. Yes
4. Restricted Delivery? (Extra Fee-) -
10251119¢M•11e6
Return ReteiPI
Domestic
PS Form 3811, July 1999
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KENNETH W. ZINN, JR., IN THE COURT OF COMMON PLEAS
Plaintiff COUNTY, PENNSYLVANIA
V. NO. 99. "11'd'C'_u P T1--
ELEANOR E. ZINN, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
PRAECIPE TO WITHDRAW APPEARANCE
TO THE PROTHONOTARY:
Please withdraw my appearance as counsel for the Plaintiff, Kenneth W. Zinn, Jr., in the
above-captioned action.
Date: T'3 Q
JAMES, SMITH, DURKIN & CONNELLY
,I
By.
PRAECIPE FOR ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance of John J. Connelly, Jr., Esquire on behalf of the Plaintiff,
Kenneth W. Zinn, Jr., in the above-captioned action.
Dater ?-/I_yy
,Klchard B. Druby, Es4u
3211 North Front Street
Harrisburg, PA 17110
(717) 238-8187
PA I.D. No. 61904
Jofin Connell Jr., Esquire
host i?e Box 60
(717) 533-3280
PA I.D. No. 15615
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