HomeMy WebLinkAbout03-3758DEBORAH LYNN ZEIGLER,
Plaintiff,
STEVEN TODD ZEIGLER,
Defendant
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
No. _
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
TO:
Steven Todd Zeigler
562 Latimore Valley Road
York Springs, PA 17372
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 fall 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.
When the ground for divome 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, Courthouse Square, 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
249-3166
1-800-990-9108
284777-1
DEBORAH LYNN ZEIGLER,
Plaintiff,
STEVEN TODD ZEIGLER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW_
No. oa
IN DIVORCE
COMPLAINT IN DIVORCE
1. The Plaintiff, Deborah Lynn Zeigler, is an adult individual currently residing at
535 Bedford Court, Mechanicsburg, Cumberland County, Pennsylvania, 17050.
2. The Defendant, Steven Todd Zeigler, is an adult individual currently residing at
562 Latimore Valley Road, York Springs, Adams County, Pennsylvania 17372.
3. Plaimiff has been a bona fide resident of the Commonwealth for at least six
months immediately prior to the filing of this Complaint.
4. Plaintiff and Defendant were married on November 23, 1996 in Franklintown,
York County, Pennsylvania.
5. Neither Plaintiff nor Defendant is in the military or naval service of the United
States or its allies within the provision of the Soldiers' and Sailors' Civil Relief Act of the
Congress of 1940 and its amendments.
6. Plaintiff's Social Security number is 301-64-3279, and Defendant's Social Security
number is 174-70-9116.
7. There have been no prior actions of divorce or for annulment between the parties.
8. 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.
284777-1
10.
11.
12.
Defendant.
9. There were two children bom of this marriage: Gavin Todd Zeigler (DOB
6/29/99; SS# 191-78-4593) and Ethan Robert Zeigler (DOB 11/14/01; SS# 181-80-9373).
The marriage is irretrievably broken.
The parties have been separated since July 18, 2003.
Plaintiff requests the Court to enter a decree of divorce, divorcing Plaintiff and
WHEREFORE, Plaimiff requests that this Court emer a decree in divorce and any such
other Orders as are appropriate and just.
Dated:
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
By Brace J. Warshawsky, Esqfi4f~fi
Attorney I.D. No. 58799 ~
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorneys for Plaintiff
284777-I
VERIFICATION
I, Deborah Lynn Zeigler, hereby certify that the facts set forth in the foregoing Complaint in
Divorce are true and correct to the best of my knowledge, information and belief, and that false
statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom
falsification to authorities.
Date:
284777-1
DEBORAH LYNN ZEIGLER,
Plaintiff,
STEVEN TODD ZEIGLER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERt,AND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 03-3758
IN DIVORCE
ACCEPTANCE OF SERVICE
I, STEVEN TODD ZEIGLER, Defendant, accept service of the Divorce Complaint in the
above referenced matter.
Dated: August 5, 2003
562 Latimore Valley Road
York Springs, PA 17372
288263-1
DEBORAH LYNN ZEIGLER,
Plaintiff,
STEVEN TODD ZEIGLER,
Defendant
IN THE CO -v ~,~, -
· UR~ uv COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
C1VIL ACTION - LAW
NO. 03-3758 CIVIL TERM
IN DIVOR CE
A~FFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
August 4, 2003 and served upon Defendant on August 5, 2003.
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 after service of Notice of
Intention to Request Entry of the Divorce.
I verify that the statements made m this Affidavit are tree and correct. I understand that any
false statements herein are made subject to the penalties of 18 Pa.C.S., Section 4904, relating to
unswom falsification to authorities.
Dated:
Steven Todd Zeigler
291767-1
DEBORAH LYNN ZEIGLER,
Plaintiff,
STEVEN TODD ZEIGLER,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 03-3758 CIVIL TERM
IN DIVORCE
WA/VER OF NOTICE OF INTENTION TO RE UEST
ENTRY OF DIVORCE UNDER SECTION 3301 c OF DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose fights concerning alimony, division of property,
lawyers' fees or expenses ifI 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 any
false statements herein are made subject to thc penalties of 18 Pa.C.S., Section 4904, relating to
unswom falsification to anthoritics.
Dated:
Steven Todd Zeigler
291767-1
DEBORAH LYNN ZEIGLER,
Plaintiff,
STEVEN TODD ZEIGLER,
Defendant
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION . LAW
NO. 03-3758 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
August 4, 2003 and served upon Defendant on August 5, 2003.
2. The marriage of Plaintiffand 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 af[er service of Notice of
Intention to Request Entry of the Divorce.
I verify that the statements made in this Affidavit are true and correct. I understand that any
false statements herein are made subject to the penalties of 18 Pa.C.S., Section 4904, relating to
unswom falsification to authorities.
Dated:
eoorah Lynn Zeiglerc/ /~~
291767-1
DEBORAH LYNN ZEIGLER,
Plaintiff,
STEVEN TODD ZEIGLER,
Defendant
1N THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 03-3758 CIVIL TERM
IN DIVORCE
~E OF INTENTION TO RE UEST
ENTRY OF DIVORCE UNDER SECTION 3301 c OF DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property,
lawyers' fees or expenses ifI do not claim them before a divorce ks granted.
3. I understand that I will not be divorced until a diw)rce 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 any
false statements herein are made subject to the penalties of 18 Pa.C.S., Section 4904, relating to
unswom falsification to authorities.
Dated:
X~)eborah Lynn Ze~gl~ d dj
291767-1
IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE Of PENNA.
DEBORAH LYIq~: ZEIGLER
VERSUS
S'J_'EVEN TODD ZEZGLER
N O. 03-3758
AND NOW,
DECReeD THAT
DECREE IN
DIVORCE
DEBORAH LYNN ZEIGLER
, IT IS ORDERED AND
, PLAINTIFF,
AND
ST~V~N TODD ZEIGLER
, 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;
ATTEST:
PROTHONOTARY
DEBORAH LYNN ZEIGLER,
Plaintiff,
V.
STEVEN TODD ZEIGLER,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 03-3758 CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Kindly transmit the record, together with the following information, to the Court for entry
of a Divorce Decree:
Ground for divorce:
Irretrievable breakdown under Section 3301(c) of the Divorce Code.
Date and manner of service of Complaint: A Complaint in Divorce was filed on
August 4, 2003, and served on Defendant on August 5, 2003. An Acceptance of
Service was filed on September 19, 2003.
Complete either paragraph (a) or (b):
(a)
Date of execution of Plaintiff's and Defendant's Affidavits of Consent
required by Section 3301 (c) of the Divorce Code:
Plaintiff:
Defendant:
January 26, 2004, filed January 29, 2004.
January 26, 2004, filed January 29, 2004.
(b)(1) Date of execution of Plaintiff's Affidavit required by Section 3301 (d) of the
Divorce Code: NA
(2)
Date of filing and service of the Plaintiff's Affidavit upon the respondent:
Filing: NA
Service: NA
297211-1
Complete the appropriate paragraphs:
(a) Related claims pending: None
(b) Claims withdrawn:
None
(c) Claims settled by agreement of the parties: All
(d)
State whether any written agreement is to be incorporated into the Divorce
Decree: N/A
(a)
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)( 1 )(i) of the Divorce Code:
Service: NA
Co)
Date PlaimiWs Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: January 29, 2004
Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the
Prothonotary: January 29, 2004
Dated:
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
Brt~e JfWarshawsky, Esquir/~J
Attorney I.D. No. 58799 ~
P.O. Box 5300
Harrisburg, PA 17110-0300
(717) 238-8187
Attorneys for Plaintiff
297211-1
DEBORAH LYNN ZEIGLER,
Plaintiff,
V.
STEVEN TODD ZEIGLER,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 03-3758 CIVIL TERM
Defendant : IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this~_~day of January, 2004 I, Bruce J. Warshawsky, Esquire, of Metzger,
Wickersham, Knauss & Erb, P.C., attorneys for Plaintiff, Deborah Lynn Zeigler, hereby certify that
I served a copy of the Praecipe to Transmit Record this day by depositing the same in the United
States mail, postage prepaid, at Harrisburg, Pennsylvania, addressed to:
Steven Todd Zeigler
562 Latimore Valley Road
York Springs, PA 17372
METZGER, WICKERSHAM, KNAUSS & ERB, P.C.
297211-1