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IN THE COURT OF COMMON PLEAS e
OF CUMBERLAND COUNTY
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STATE OF PENNA. F
TRACY L. ZIMMERMAN to
• I N c ?. 99,,660.3 ... ........
Plaintiff
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MICHAEL J. ZIMMERMAN, _ o
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Defendant 0
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DECREE IN f
`r DI V 0 R C E
E AND NOW,....it1 71). L? .. ............. it is ordered and
decreed that ...TRACY. .t+•..2ZkIMERMAN ......................... plaintiff,
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and ............. MICHAEL. J....ZIMMERMAN..................... defendant, f°
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are divorced from the bonds of matrimony.
The court retains jurisdiction of the following claims which have ,o
been raised of record in this action for which a final order has not yet c
been entered;
None
...............................................................
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IN T11E COJRT OF CCXVON PLEAS OF
CU4BERIJu%1D COUNTY, PENNSYLVANIA
TRACY L. ZIMMERMAN,
Plaintiff
VS.
"O. 99-6603 CIVIL 1.999
MICHAEL J. ZIMMERMAN,
Defendant-
PRAECIPE TO TRANSMIT RECORD
To the Prothonotarv:
Transmit the record, together with the following information, to the court
for entrv of a divorce decree:
1. Grounds for divorce: irretrievable breakdown under Section 3301 (c)
,33?Rk:L kkkDcof the Divorr_e Code. (Strike out inapplicable section)
2. Date and manner of service of the canplaint: November 6, 1999 ?g
confirmed via Acceptance of Service
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 the plaintiff February 23, 2000
by the defendant February 12 2000
B. (1) Date of execution of the plaintiff's affidavit required by
Section 3301 (d) of the Divorce Code:
(2) Date of service of the plaintiff's affidavit upon the defendant:
N. A.
4. Related claims pending:
5. Indicate date and manner of service of the notice of intention to file
praecipe to transmit record, and attach a copy of said notice under Section
3301 (d)(1)(i) of the Divorce Cade N.A. See Waivers of Notice to Intention
Attorney for Plaintiff lftkxXjAxx
Stephen B. Lipson
TRACY L. ZIMMERMAN,
Plaintill'
V.
MICHAEL. ZIMMERMAN,
Defendant
IN TI lli COURT OF COMMON PLEAS OI'
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. W-6v !0i 3
IN DIVORCE:
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. Ifyou wish to defend against theclaims 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 for
any other claim or relief requested in these papers by the Plainti0: You may lose money or
property or other rights important to you.
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 Court House, High and Hanover Streets. Carlisle.
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 IIELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
Phone. (717) 249-3166
TRACT' L. %I UNI RNIAN,
Plaintill'
IN TI Ili COUR'T' OU COMMON PLLAS OF
CUMI1HItLAND CO(1NTY, PENNSYLVANIA
C'1 VI 1, ACTION - LAW
MICHAELJ. ZIMMERMAN- : NO. '-
Defendant : IN I)IVORCI:
COMPLAINT UNDER SECTIONS 3301(c) and 3301(d)
Of THE. DIVORCE. CObE
1. Plaintiff is Tracy L. Zimmerman, an adult individual who currently resides at 9 Wood
Lane, Carlisle. Cumberland County, Pennsylvania. I'lainliffhas resided at said address since
November 29, 1998.
2. Defendant is Michael J. Zimmerman. an adult individual who currently resides at 575
North Lucerne Blvd., Los Angeles, California. Defendant has resided at said address since April
24, 1998.
3. Plaintiffhas been a bona fide resident ol'the Commonwealth for at least six months
immediately previous to the filing of this Complaint.
4. Plainzill'and Defendant were married on December 3, 1994 in Las Vegas. Clark
County, Nevada.
5. Thera have been no prior actions for divorce or annulment between the parties hereto
in this or any otherjurisdiction.
6. 'The marriage is irretrievably broken.
7. Plain tilravers that she has been advised ol'the availability ofcounseling. and that she
may have the right to request that the Court require the parties to participate in counseling.
8. PlaintifTavers that the grounds upon which this action is based arc:
(A) That the marriage is irretrievably broken (§3301(c));
(B) That the parties have lived separate and apart since April 24. 1998 and that the
marriage is irretrievably broken. When the two year separation period has expired.
Plaintiff shall file the appropriate Affidavit under § 3301(d).
9. Plaintiff requests the Court to enter a Decree in Divorce.
I 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. §4904, relating to unsworn
falsification to authorities.
---
Dated:
Tracy L. Zimmennai?, Plaintiff
--
By:/r
Stephen B. Lipson, Esquire
Attorney for Plaintiff
501 S. Hanover Street
Carlisle, PA 17013
(717) 249-3929
TRACY L. ZIMMERMAN,
Plaintill'
V.
MICIIAIiLJ. ZIIMMERMAN.
Defendant
IN'TIIL• COURT OF COMMON PLEAS OI'
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-6603
IN DIVORCI?
AFFIDAVIT OF CONSENT
A Complaint in Divorce wider $ 3301(c) ofthe Divorce Code was filed on November
1, 1999.
2. The marriage ol'Plaintill'and Defendant is irretrievably broken and ninety (90) days
have elapsed from life date o f filing and service of the Complaint.
3. 1 consent to the entry or a final decree of divorce.
4. 1 understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if f do not claim them betbre a divorce is granted.
1 verify that life statements made in this Aflidavil are true and correct. I understand that
false statements herein are made subject to the penalties of'] 8 Pa. C.S. §4904, relating to unsvvorn
falsification to authorities.
^l
Date: G•`.
Tracy L. L.inunernlan.-Plainfiff
SWORN AND SUBSCRIBED to belbre me this -
day o f
-000.
=B, [AL _
ot:::yPublic ----Notary Public
---
of Cumbarlnnd
, Jan i5. 230-1
TRACY L. ZIMMERMAN,
Plaintiff
V.
MICHAEL ,1. ZIMMERMAN,
Defendant
IN THE- COURT' OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION-LAW
NO. 99-6603
IN DIVORCF.
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on November
1, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if 1 do not claim them before a divorce is granted.
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: 11d
Michael J. Zim Lerman, Defendant
SWORN AND SUBSCRIBED to before me this day of
, 2000.
JUME M°JJRE % (SEAL)
f „'1 Commissicn n 1197634 Notary P bl'
..o1,xy Pubic-Califomla
Lcs/,nyetes Co:nry
1.. hiv C.o?.m. Esd%•us Ocl9, 7,X12
V
'TRACY L. ZIMMERMAN,
Plaintill,
V.
MICIIAEL.1. ZIMMERMAN,
Delbndant
: IN "I.1IE COUIZT OF COMMON PLEAS OF
: Cllh-1131:IZI.AND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAN
NO. 99-6603
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER SECTION 3301(C) OF THE DIVOIZCE COINE
1. 1 consent to the entry ofa final decree in divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's
Ices, or expenses if I do not claim them before a divorce is granted.
3. 1 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 verily 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.
l•
Date:
(L:.._.i
"Tracy L. Limhncrman,_I'13intifr
SWORN AND SUBSCR113ED to belbre me this day of
% c.e, ,. ; .2000.
110TARIAL SEAL
phO n B. Lipson, Notary Public - --
5C,p j
Carlzle Boiouyh, Ccunty et CurnbarlrnA Notary Ptlblll'
i,ly Ccrnmi?siun Expnes Jan. 15, 2004 SEAL)
TRACY L. ZIMMERMAN,
Plaintill'
V.
MICHAEL 3. ZIM[MF.RMAN,
Defendant
IN THE COURT' 01' COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-6603
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE
DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees, or expenses if 7 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
.1.
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falsification to authorities.
awAlm- =1
Cbnnnledaf fI 11i711?6'.=
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?f C NpaleYppaury::_
Date: '91olou
Michael J. Z'mmerman, Defendant
SWORN A.ND SUBSCRIBED to lx;f'ore me this day of
2000.
?? (SEAL)
// Notary Pub v
s n?d?
4,1. 41a, &12,112
TRACY L. ZIMMERMAN,
V.
: IN THE COURT OF COMMON PLEAS OF
Plaintiff' : CUM13EIZLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
MICHAEL.I. ZIMMERMAN,
Defendant
NO. 99-6603
IN DIVORCE
CERTIFICATE OF SERVICE
Stephen B. Lipson, Esquire, hereby certifies that he is counsel for the Plaintiff, Tracy L.
Zimmerman, in the above-captioned action. On November 4, 1999, he did deliver for mailing at
the United States Post Office in Mt. I folly Springs, Pennsylvania, both by certified mail, restricted
delivery, as well as by first class mail, postage prepaid, a true and correct copy of Plaintiff's
Complaint under Section 3301 (c) of the Divorce Code in the above-captioned action. Said copy
of the Complaint was duly endorsed with a Notice to Defend and Claim Rights.
Declarant further says that on the 4th day of November, 1999 he did receive a receipt for
certified article no. Z 013 263 832, as well as a Certificate of Mailing for the first class mail. The
first class mail was not returned, but when the United States Postal Service returned the receipt
card it was signed by one "James Farr'. The return receipt card and the Certificate of Mailing are
attached hereto as Plaintiffs Exhibit "A" and made a part hereof.
To confirm that Defendant actually received the certified copy of the Complaint (as is
presumed from the non-return of the first class mail), Declarant sent an Acceptance of Service to
Defendant Michael J. Zimmerman. This document was signed by Defendant on November 22,
1999 and returned to Declarant in the envelope provided by Declarant. These documents are
attached hereto as Plaintitl's Exhibit " ll- and made it part hereof:
Stephen B. Lipson
Counsel lbr Plaintill; Tracy L. Zimmerman
501 S. I lanover Street
Carlisle, PA 17013
(717) 249-3929
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e •sYdte'Retum Recalpt ReQlrealed'On the maepiece below
$ •The Rettun Receipt will ehow to whom ft aelde was do
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575 North Lucerne Blvd.
Los Angeles,-,9A 90004
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PS Form 3811, December 1994
Z 013 263 832
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TRACY L. ZIMM ERMAN,
Plainlill'
v.
MICHAEL,I_ ZIMMERMAN,
Defendant
IN '1'1-Ili COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL AC'T'ION - LAW
NO. 99-6603
IN DIVORCE
ACCEPTANCE OF SERVICE
I accept service of the Complaint under Sections 3301 (c) and 3301 (d) of the Divorce
Code, Said Complaint wns received by me on November 6, 1999.
Dated: / 1 j_
c
Michael J. Zimmerman, Defendant
575 North Luzerne Blvd.
Los Angeles, CA 90004
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'T'Y, PENNSYLVANIA
CIVIL ACTION - LAW
TRACY L. ZIMMERMAN.
Plai-nti.ff
VS.
MICHAEL J. ZIMMERMAN,
Defendant
File No. 99-6603
IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff /ftfXXi3?ppt in the
above matter, having been granted a Final Decree in Divorce on the
LS f day of -, I` , pg-2-C60, hereby elects to resume the
prior surname Of TRACY LYNNE STULL and gives
this written notice pursuant to the provisions of 54 P.S. S 704_
DATE:
Signature______)
ICU,
Signaturelof name being resumed
COMMONWEALTH OF PENNSYLVANIA:
SS.
COUNTY OF CUMBERLAND
On the /-?' ;//- day of l I cc?.
_ 1.9 , before me, a
Notary Public, personally appeared the above affiant known to me to
be the person whose name is subscribed to the within document and
acknowledged that hot/she executed the foregoing for the purpose
therein contained.
seal. In Witness Whereof, I have hereunto set my hand and official
.
NOTARIALSEAL Notary Public
Stephen B. Linnon, Notary Public
Carlslo Borough. County o: Cumberland
IAy Commission Expires Jan. 55, 2004
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