Loading...
HomeMy WebLinkAbout09-7838LISA M. ZUBER, Plaintiff V. CRAIG J. ZUBER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 f, `7 Q'3 ?? c tv% 1 -f-ts?• CIVIL ACTION -LAW 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 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA. 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, 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 Jo . King, Esq. K? E-3 JOHN F. KING LAW, P.C. John F. King, Esquire ID #61919 19 S. Hanover Street Attorney for Plaintiff Suite 103 Carlisle, PA 17013 Tel.: (717) 258-4343/Fax: (717) 422-5526 LISA M. ZUBER, IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. 9- 7T3?' c-?;( V. CRAIG J. ZUBER, CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Lisa M. Zuber, who currently resides at 7 E. Front Street, Suite 200, Shiremanstown, PA, Cumberland County, 17011. 2. Defendant is Craig J. Zuber, who currently resides at 2145 Lambs Gap Road, Enola, PA, Cumberland County, 17025. 3. The parties have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 26, 2003, in Mt. Carmel, PA. 5. There have been no prior actions of divorce or for annulment between the parties. 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. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, JOHN F. KING LAW, P.C. -')J? -14, Date: November, 2009 J F. King, Esquire 19 S. Hanover Street Suite 103 Carlisle, PA 17013 (717) 258-4343 VERIFICATION I, Lisa M. Zuber, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Divorce Complaint; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. q Lf-?a M. /?U ?'Y)) i a M. Zuber Dated: -I I - I C)` 09 2Cn 9 go V 12 Pik 12• %3 1 A r y 5-3-3 sue, C) ? A edlt c? j7? 3 ,,p ,? ?, 3 3 7b LISA M. ZUBER, Plaintiff v. CRAIG J. ZUBER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.09-7838 n, ~ a CIVIL ACTION -LAW 'Q_~~ c IN DIVORCE ~ ~; ~..- w PRAECIPE TO TRANSMIT RECORD To the Prothonotary: ~' -c~ ~` J ~ww- •w Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Acceptance of service on November 16, 2009. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff 5/24/10; by Defendant 3/2/10 and filed on 3/16/10. 4. Related claims pending: There are no related claims pending. 5. (Complete either (a) or (b).) (a) Date and manner of service of the notice of intention to file praecipe to transnut record, a copy of which is attached: N/A (b) Date Plaintiffs Waiver of Notice was filed with the Prothonotary: 6/1/10 Date Defendant's Waiver of Notice was filed with the Prothonotary: 6/1/10 hn F. King, Esquire nom' _~ ',; t .s -,~-. ~y.i~_~ -~FTr ~~ ~~ LISA M. ZUBER, Plaintiff v. CRAIG J. ZUBER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA N0.09-7838 CIVIL ACTION -LAW n N °- IN DIVORCE -~t-r~ ~ s~ z,~.; '- ~, ~t~.j= ! W .~.._ 't3 %~ AFFIDAVIT OF SERVICE W COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ss n ~Yi s.:-~y ~ ~? '-~C7 Personally appeared before me, a Notary Public, in and for said Commonwealth and County, John F. King, Esquire, Attorney for the Plaintiff, who, being duly sworn according to law, deposes and says that a Certified copy of the Complaint in Divorce ' above-captioned matter was served upon Defendant, as evidenced by the attached A e~c`~i~'-~ F. King, Esquire Sworn and subscribed to before me this ~_ day of ~ 2010 Notary Pu ' c COMMONWEALTH OF PENNSYLVANIA NOTARIAL SEAL SHARRY D. SEMANS, Notary Public City of Hamsburg, Dauphin County M am .I ~` LISA M. ZUBER, Plaintiff v. CRAIG J. ZUBER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-7838 ~ ~ ;,:, ` ~, n :CIVIL ACTION -LAW ~ ~ IN DIVORCE ~~. ~ -<4: w .-3 ACCEPTANCE OF SERVICE -~ n~ c,~ I, Craig J. Zuber, hereby acknowledge that I received a copy of the Divorce Complaint filed in the above matter on ~ ( ~ ~ ~&~~ (dat received) Craig . LISA M. ZUBER, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY , PENNSYLV ANIA v• N0.09-7838 t~ =' 0 ~ CRAIG J. ZUBER, :CIVIL ACTION -LAW ~ ~ ~~; c, , ~~ Defendant IN DIVORCE ~~-; ~"' n `-?~ ~~ R' AFFIDAVIT OF CONSENT w A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on November 12, 2009. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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. 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. ..-- /~ P.ate~l: ~ ~~ - L . Zuber, Plaint' f LISA M. ZUBER, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVA NIA v. NO. 09-7838 C ~ q ~,s -s'1 ~~i" CRAIG J. ZUBER, :CIVIL ACTION -LAW z-~z;< x ~~ Defendant IN DIVORCE ~~' ~ _ ~. s..s W WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DF,CREE UNDER 3301(C) AND 3301(D) 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. 4. 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: i7 '~" ~ ~G' L s . Zuber, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA M. ZUBER V. CRAIG J. ZUBER NO 09-7838 DIVORCE DECREE AND NOW, c'Jrs..~. 8 ' 2a ~o , it is ordered and decreed that LISA M. ZUBER plaintiff, and CRAIG J. ZUBER ,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.") None. By the Court, Attes . ~ J. ~/ D rothonotary (o • g"• I O ~•g~to c.~u-~. coF`d ,Ucx1; c~ tna;t~.d ~tQa -to ~;n~.