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HomeMy WebLinkAbout09-2980I).- is 1.6" MELISSA S. ZEIGLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. - a't9`dD Cam" DANIEL L. ZEIGLER, Defendant : IN DIVORCE NOTICE 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 also 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 at the Cumberland County Court House, High and Hanover Streets, Carlisle. IF YOU SO 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 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland 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 arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. MELISSA S. ZEIGLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : Civil Action- Law No. 0 9. a 9 IF ?c??. DANIEL L. ZEIGLER, Defendant : IN DIVORCE COMPLAINT UNDER SECTIQNS 3301W or_ 3301(4) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Melissa S. Zeigler, by and through her counsel, Michael J. Whare, Esquire and avers as follows: 1. Plaintiff is Melissa S. Zeigler, an adult individual, who currently resides at 1431 Timber Brook Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant is Daniel L. Zeigler, an adult individual, who currently resides 32 Terri Drive, Carlisle, Cumberland County, Pennsylvania 17015. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 26, 2003, in Mechanicsburg, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. Respectfully submitted, Date: Michael I Whare, Esquire 37 East Pomfret Street Carlisle, PA 17013 Supreme Ct. Id No. 89028 Attorney for Plaintiff MELISSA S. ZEIGLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v : Civil Action- Law No. DANIEL L. ZEIGLER, Defendant IN DIVORCE VERIFICATION 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.CS. 4904 relating to unworn falsification to authorities. Date: ?5 1 I M a SqZei er, Plai BLED-+3rACE OF THE PROTHONOTARY 2009 MAY 12 AM 11: 00 f, . IL I ., CU?,? < PE' INSYLV,` J l- .-o7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ISS A J, Z1;IC' L,-r- Plaintiff Vs File No. N • 2A'60 l IN DIVORCE 1 ? G V 1 Ci Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated , hereby elects to resume the prior surname of 1 1 rLNt- R- , and gives this written notice avowing his / her intention purs anto the prov is of 54 P. 704. Date: US 3 D? Giature e Sig (jy1 "S Si ature of name ing resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CcA- U1 a?A 4 On the 13 day of y , 200 1, before me, the Prothonotary or the 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 he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. Notary ublic NOTARIAL SEAL PROTHONOTARY, NOTARY PUBLIC CARLISLE CUMBERLAND COUNTY COURTHOUSE MY COMMISSION EXPIRES JANUARY 4. 2010 ?r1,?1?; ?°=rive OF THE pt-r- -`-'C-N" i APY 2009 A,Y € 3 At 6: 3Q Pl qe a SUS{ Z