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Home My WebLink About09-7305Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) THOMAS L. ZIMMERMAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW JEAN C. ZIMMERMAN, o9 - 7 3 D 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 against you and a decree in 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 with 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, 1 Courthouse Square, Carlisle, Pennsylvania, 17013-3387. 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 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 BY 46,i? I ? Andrew C. Shee , Esquire PA. I.D. No. 62469 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 717 697-7050 Attorney for Plaintiff Andrew C. Sheely, Esquire 127 S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) THOMAS L. ZIMMERMAN, Plaintiff VS. JEAN C. ZIMMERMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 09 - 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 with a list of qualified professionals who provide such services. Accordingly, if you desire counseling a list of marriage counselors if available in the office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013-3387 Andrew C. Sheely, Esquire 127 S. Market Street P.a. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) THOMAS L. ZIMMERMAN, Plaintiff VS. JEAN C. ZIMMERMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE DIVORCE COMPLAINT 1. Plaintiff is THOMAS L. ZIMMERMAN, an adult individual who currently resides at 2810 Sunset Court, Mechanicsburg, Upper Allen Township, Cumberland County, Pennsylvania. 2. Defendant is JEAN C. ZIMMERMAN, an adult individual who currently resides at 17 Greenspring Drive, Mechanicsburg, Silver Spring Township, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant were residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married in Mansfield, Pennsylvania, on June 14, 1974. 5. There have been no prior actions of divorce or annulment between the parties. 6. Neither party is a member of the armed forces of the United States of America. 7. Plaintiff has been advised of the availability of marriage counseling and understands that he may have the right to request that the court require the parties hereto to participate in counseling. COUNT 1 - DIVORCE - IRRECONCILABLE DIFFERENCES 8. Paragraphs 1 - 7 are incorporated herein as if set forth at length. 9. The marriage between the parties is irretrievably broken. 10. After ninety (90) days have elapsed from the date of filing the divorce complaint, Plaintiff intends to file an affidavit consenting to a divorce and Plaintiff believes Defendant may also file such an affidavit. 11. This divorce action is not collusive. 12. The parties separated on or about August 30, 2008. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from filing of this Divorce Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301(c) of the Pennsylvania Divorce Code. COUNT 2 - DIVORCE - 3301(d) 13. Paragraphs 1 - 12 are incorporated herein as if set forth at length. 14. After a period of two (2) years has elapsed from the date of separation, Plaintiff intends to file his affidavit of having lived separate and apart. 2 WHEREFORE, if two (2) years have elapsed from the date of separation and Plaintiff has filed his affidavit of consent, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301(d) of the Divorce Code. Date: October 2Z , 2009 Respectfully submitted, Andrew C. Sheely, Esquire Attorney for Plaintiff PA ID No. 62469 P.O. Box 95 127 S. Market Street Mechanicsburg, PA 17055 717-697-7050 3 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. Date: October 2-2-- , 2009 G ` Thomas i erman Andrew C. Sheely, Esquire IN S. Market Street P.O. Box 95 Mechanicsburg, PA 17055 PA ID NO. 62469 717-697-7050 (Phone) 717-697-7065 (Fax) THOMAS L. ZIMMERMAN, Plaintiff VS. JEAN C. ZIMMERMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 09 - 7 3 o S Lc ?.?:1 Tt IN DIVORCE AFFIDAVIT Thomas L. Zimmerman, being duly sworn according to law, deposes and says: (1) I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. (2) I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. (3) Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a Divorce Decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Thoma• erman V I'Y 24+31Gy'T G3 r:'tt'.• f e a- 5 2 `/ 9"40 0,5b THOMAS L. ZIMMERMAN, Plaintiff VS. JEAN C. ZIMMERMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 09 - 7305 IN DIVORCE ACCEPTANCE OF SERVICE OF DIVORCE COMPLAINT I, JEAN C. ZIMMERMAN, Defendant, hereby accept service of the Divorce Complaint docketed to the above-captioned matter and hereby declare that I am authorized to do in accordance with the Rules of Civil Procedure. Date: October 331 2009 JE 7 FILEHFICE- OF THE PPOTPr)-NOTARY 2009 NOV -2 AM I I : 32 CUM- :?UUUTY PEP4NS,'r L.VA.NFA