HomeMy WebLinkAbout09-0769DONALD R. ZENDT,
Plaintiff
vs.
JULIE A. ZENDT,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
NO: Oq- '7~ 1,~1Vi l T+P.r1M
CIVIL ACTION - IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGI~TS
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 ydu 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 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 in Cumberland County.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIV~,ISION OF PROPERTY,
LAWYER'S FEES. OR EXPENSES BEFORE A DIVORCE ~ OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OE THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYEI~~ 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.
Lawyers' Referral Service or
100 South Street, P.O. Box 186
Harrisburg, PA 17108
1-800-692-7375
Dated: February 10, 2009
1~IidPenn Legal Services
213 N. Front Street
~-Iarrisburg, PA 17101
_1-800-932-0356
Jerry A ott, Esquire (# 47624)
227 N. i Street, PO Box 116
Dunc ~~, PA 17020
717-83 0'87
(Alto y for Donald Zendt)
DONALD R. ZENDT, IN THE COURT OF COMMON PLEAS
Plaintiff OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs. ,
NO:
JULIE A. ZENDT, ,
Defendant CIVIL ACTION -LAW IN DIVORCE
NOTICE OF RIGHT TO COUNSELING
You are one of the parties in the above captioned action in Divorce. By virtue of Section 202
of the Pennsylvania Divorce Code, it is a duty of the Court to advise both parties of the availability
of counseling and upon request of either provide both parties a list of qualified professionals who
provide such services.
Accordingly, if you desire counseling, please advise in writing promptly by replying to:
Prothonotary, Cumberland County Courthouse.
Deputy Prothonotary
DONALD R. ZENDT,
Plaintiff
vs.
JULIE A. ZENDT,
Defendant
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION. -LAW IN DIVORCE
COMPLAINT UNDER § 3301(c) OR ~ 3301(d) OF THE DIVORCE CODE
1. Plaintiff is Donald R. Zendt, who currently resides at 20 Main Street, Lewistown, PA
17044.
2. Defendant is Julie A. Zendt, who currently resides at 165 S. Enola Drive, Enola, PA
17025.
3. Plaintiff and defendant have been bona fide residents in the Commonwealth for at
least 6 months immediately previous to the filing of this Complaint.
4. The plaintiff and defendant were married on May 18, 2002, in Marysville, PA.
5. There have been no prior actions of divorce or for annulment instituted by either of
the parties in this or any other jurisdiction.
6. The plaintiff has been advised of that counseling is available and that plaintiff may
have the right to request that the court require the parties to participate in counseling.
7. The marriage is irretrievably broken.
8. Plaintiff requests the court to enter a decree of divorce.
9. Plaintiff avers that there was one child under the age of 18 dears born of this marriage,
but that the child is in the custody of Cumberland County Children and Xouth Services pending an
adoption if the adoption has not already taken place. There are no custody issues.
10. After 90 days have elapsed from the date of filing of this Complaint, plaintiff intends
to file an Affidavit consenting to a divorce. Plaintiff believes that defendant may also file such an
affidavit.
WHEREFORE, if both parties file affidavits consenting to a divorce after 90 days have
elapsed from the date of filing of this Complaint, plaintiff respectfully requests the court to enter a
decree of divorce pursuant to § 3301(c) of the Divorce Code.
Jerry A. ilp , ~sq re
Supre C ID #4 624
227 N gh Street, P.O. Box 116
Duncanno , PA 17020
717-83
Dated: February 10, 2009
for Plaintiff)
4
I verify that the statements made in the foregoing documents 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.
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