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HomeMy WebLinkAbout09-2534 RONALD R. ZERANCE, Plaintiff V. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA OQ - 0?63? C i v i l ?C,t? : NO. CV DV CHERYL A. ZERANCE, Defendant : IN DIVORCE 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 papers by the plaintiff. You may lose money or property or other rights important to you, including custody 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 at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Cumberland County, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 RONALD R. ZERANCE, Plaintiff V. CHERYL A. ZERANCE, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. CV DV IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Ronald R. Zerance, who currently resides at 1027 Swarthmore Road, New Cumberland, Cumberland County, Pennsylvania, 17070 since April 20, 1987. 2. Defendant is Cheryl A. Zerance, who currently resides at 866 Monroe Street, Bressler, Dauphin County, Pennsylvania, 17113 since December, 2008. 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 August 21, 1968 at Steelton, Pennsylvania. 5. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 6. Neither Plaintiff nor Defendant is a member of the Armed Forces of the United States of America or any of its Allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940, 50 U.S.C.A. § 410 et seq. and its amendments. 7. 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. COUNT 1 REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(C) OF THE DIVORCE CODE The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 9. The marriage of the parties is irretrievably broken. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree of divorce pursuant to Pa. Cons. Stat. § 3301(c) of the Divorce Code. COUNT II EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502(A) OF THE DIVORCE CODE 10. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 11. The parties have acquired certain property and assets which constitute marital property. 12. In the event that the parties are unable to resolve distribution of marital property byway of an agreement, then this Honorable Court is authorized to equitably divide, distribute or assign marital property between the parties in such proportions as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff respectfully requests the Court to enter an order of equitable distribution of all marital property pursuant to Pa. Cons. Stat. § 3502(a) of the Divorce Code. Respectfully submitted, Suzanne riday, Esquire Attorney for Plaintiff Nauman, Smith, Shissler & Hall, LLP 200 N. Third Street, 18`h Harrisburg, PA 17101 (717) 236-3010 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. Cons. Stat. Ann. § 4904, relating to unswom falsifications to authorities. Date: Plainti ttome f r Plain ff Hi?D F E t'SC 11,.11- pn`? 2099 APR 22 Pi`l 1' 33 +3(04.50 Pb A-MY C1C.? 35a.o'1 RONALD R. ZERANCE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-2534 - CIVIL TERM CHERYL A. ZERANCE, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE I, Sherry A. May, Paralegal, hereby verify that on 25th day of April, 2009, I served the Defendant with a true and correct copy of the Divorce Complaint by one of the following methods: Service was made by United States Postal Service, first class mail, postage prepaid, certified, restricted delivery, return receipt requested to the Defendant, on the 25th day of April, 2009. The return receipt signed by the Defendant is attached hereto. ? The Defendant was personally served with a true and correct copy of the above pleading by hand-delivering the same to the Defendant by someone other than the Plaintiff. Personal service was made at the following location and time: on the _ day of , 2009, at o'clock. (PERSONAL SERVICE CAN NOT BE MADE BY PLAINTIFF.) 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: April 29, 2009 Signature of th erson who Ma rice ¦ Cc#ipk" kernel, 4 acrd 3. Alm oetf0ete tteti Off PAWded D*MY Is dedred. ¦ Ptint your nears and address W the reverse so that we am Tatum to card ?o you. rr?aN ¦ Attach this card to the bank of 'V* or on the front K apace pemtits. 1. Article Addressed to: n c s S L PA I'1 t L3 2. Ar" Number Ps F64n 3811, Febntmry 2ow A. X ° r- wee B. Recelwd (PrbW MWW) C. Date of Dellmy i .O' D. addlese mom. tram ram i ? Yes if YES, enter delivey address below: 0 No )kp,OW ype MaN E3 MeN 0 RegWemd 0 for Meng wOme p insured Mall i? C.O.D. 4. Reehided DeWwy? P" Fes) 7006 2150 0002 5370 9065 Ma. , For delivery mfonr moll' r%- m Postage Ln Certified Fee ru 0 Retum Receipt Fee O (Endorsement Required) 0 Restricted Delivery Fee O (Endorsement Required) u1 r-I Total Postage & Fees rti C Sent To - C3 e , M1 or PO sax No. ----- .a.' _.06 OF THE F 10TARY A Mg APR 30 AM I I *. 54 r? i ??l RONALD R. ZERANCE V. CHERYL A. ZERANCE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-2534 Civil Term DIVORCE DECREE AND NOW, ~~~ h 1 ©~ 6 , it is ordered and decreed that RONALD R. ZERANCE CHERYL A. ZERANCE bonds of matrimony. plaintiff, and defendant, are divorced from the 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.") None By the Court, U ~~