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Home My WebLink About08-5506 Walker, Connor & Johnson LLC 247 Lincoln Way East Chambersburg PA 17201 (717) 262-2185 (717) 262-2187- Fax IN THE COURT OF COMMON PLEAS OF CUMBERALND COUNTY, PENNSYLVANIA Larry L. Zinn, Jr., Plaintiff, ) Defendant, ) Civil Action - Law vs. Stacy L. Zinn, No. dIn Divorce a v.m. 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 pages 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 of the Cumberland County Courthouse, First Floor, 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Pennsylvania Bar Association Lawyer Referral Service 1-800-692-7375 (PA Only) or (717) 238-6715 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Franklin County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangement must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. mop Ift Larry L. Zinn, Jr. VS. Stacy L. Zinn, Walker, Connor & Johnson LLC 247 Lincoln Way East Chambersburg PA 17201 (717) 262-2185 (717) 262-2187- Fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, ) Defendant, ) Civil Action - Law No. In Divorce a v.m. COMPLAINT UNDER SECTION 3301(c) OR 3301 (d) OF THE DIVORCE CODE 1. Plaintiff is Larry L. Zinn, Jr., a sui juris adult who currently resides at 101 Vaughn Road, Shippensburg, Cumberland County, Pennsylvania, since January, 2007. 2. Defendant is Stacy L. Zinn, a sui juris adult, who currently resides at 10 West Springville Road, Boiling Springs, Cumberland County, Pennsylvania, since approximately October, 2007. 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 July 25, 1990 in Newville, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment of this marriage between the parties except the action represented by this Complaint. 6. The marriage is irretrievable broken. 7. Neither the Plaintiff nor Defendant is a minor or incompetent. 8. Plaintiff has been advised that counsel is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff respectfully requests your Honorable Court to enter a decree of divorce. 2 AIP qb VERIFICATION I verify that the statements made in the foregoing document 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: i 5 I(OB ,?2 I;- a . tarry -L. Zmn, J . Walker, Connor & Johnson, LLC DATE: By: M a B. Walker, IRsquir Aftomey I.D. # 15989 247 Lincoln Way East Chambersburg PA 17201 (717) 262-2185 Attorney for Plaintiff 4 V l C'a r`. M1!7 ?? na V?y I! " j 0--t> WALKER, CONNOR A JOHNSON LLC 247 Lincoln Way East Chambersburg PA 17201 (717) 262-2185 (717) 262-2187-Fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Larry L. Zinn, Jr., ) Civil Action - Law Plaintiff, ) VS. ) No. 08-5506 - Civil Term Stacy L. Zinn, ) Defendant, ) In Divorce a v.m. AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN SS: Martha B. Walker, Esquire, being duly sworn according to law, deposes and says that she is the attorney for the Plaintiff, Larry L. Zinn, Jr., in the above-captioned matter; that she did serve a true and attested copy of the Complaint in Divorce Under Section 3301(c) or 3301(d) of the Divorce Code by hand-delivering same to Stacy L. Zinn, Defendant, on September 24, 2008 at the Cumberland County Domestic Relations Office, 13 North Hanover Street, Carlisle, PA 17013. WALKER, CONNOR & JOHNSON, LLC ?.i By: '71k4 artha B. Walker, Esquire ttorney for Plaintiff Attorney I.D. #15989 247 Lincoln Way East Chambersburg, PA 17201 (717) 262-2185 Sworn to and subscribed before me ? ? ?? ? ? ?. < -ar ? ? Y.: ? . `? Walker, Connor & Johnson LLC 247 Lincoln Way East Chambersburg PA 17201 (717) 262-2185 (717) 262-2187-Fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Larry L. Zinn, Jr., ) Civil Action - Law Plaintiff, ) VS. ) No. 08-5506 -Civil Term Stacy L. Zinn, ) Defendant, ) In Divorce a v.m. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce Under Section 3301(c) or 3301(d) of the Divorce Code was filed on September 17, 2008. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of both 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 6 3301(c) OF THE 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, 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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. -12 11 Date: d(S oq Larry L. inn, ain ff ALED-OFFICE OF THE PRAOTHI NOTARY 2009 APR 15 AM 11 : 15 r ENKCSYL N IIA Walker, Connor & Johnson LLC 247 Lincoln Way East Chambersburg PA 17201 (717) 262-2185 (717) 262-2187 - Fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Larry L. Zinn, Jr., ) Civil Action - Law Plaintiff, ) vs. ) No. 08-5506 - Civil Term Stacy L. Zinn, ) Defendant, } In Divorce a v.m. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce Under Section 3301(c) or 3301(d) of the Divorce Code was filed on September 17, 2008. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of both 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY 0E A DIVORCE DECREE UNDER SECTION & 3301(c) OF THE DIVORCE (CODE I . 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, 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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904, relating to unsworn falsification to authorities. Date: y f/5 /of Stacy L. Zio, Defen t OF THE rmt-TRIC)NMARY 2009 APR 15 AM 11: 15 OINTY FFNi ,S LVANIA WALKER, CONNOR & JOHNSON LLC 247 Lincoln Way East Chambersburg PA 17201 (717) 262-2185 (717) 262-2187 - Fax IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Larry L. Zinn, Jr., VS. Stacy L. Zinn, To the Prothonotary: Plaintiff, ) Defendant, ) Civil Action - Law No: 08-5506 - Civil Term In Divorce a v.m. PRAECIPE TO TRANSMIT RECORD 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. 2. Date and manner of service of the Complaint: September 24, 2008 - Hand-delivered to Defendant by Plaintiffs attorney. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, April 15, 2009; by Defendant, April 15, 2009. 4. Related claims pending: Resolved through private Agreement; 5. (a) Date Plaintiff s Waiver of Notice in Section 3301(c) Divorce was filed with Prothonotary: April 15, 2009. (b) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: April 15, 2009. WALKER, CONNOR & JOHNSON LLC BY: Anne S. Johnso squire For Martha B. Walker Attorney I.D. # (m Gj r?l du 11) 247 Lincoln Way East Chambersburg, PA 17201 (717) 262-2185 Attorney for Plaintiff F LED CF TF er 2, 0 9 sil R 22 PHI a*- t00' ,? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Larry L. Zinn, Jr. V. Stacy L. Zinn NO. 08-5506 -Civil Term DIVORCE DECREE AND NOW, AM lez , it is ordered and decreed that Larry L. Zinn, Jr. plaintiff, and Stacy L. Zinn , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") WOO--- By the Court, Attes't'" 1 J. Prothonotary ?as Of 44 W44AV