The URL can be used to link to this page

Home My WebLink About10-1750 ROBERT L. ZEIGLER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO./ Q -- 75-v N n , CIVIL - DIVORCE ;; =1C GERALDINE A. ZEIGLER, ' Defendant NOTICE TO DEFEND CD 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 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 first floor in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. 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 LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 s3Sa. d6 ek ?V /6 4 ROBERT L. ZEIGLER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. JQ.- 1 7 5'd C 6^j. CIVIL-DIVORCE GERALDINE A. ZEIGLER, Defendant COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Robert L. Zeigler, by his attorney, John M. Kerr, Esquire, pursuant to Section 3301(c) & 3301(d) of the Pennsylvania Divorce Code, and seeks to obtain a Decree in Divorce from the Defendant, Geraldine A. Zeigler, upon the grounds set forth: COUNT I - NO-FAULT DIVORCE UNDER §3301(c) or 3301(d) Y Uw?? otul Merr 5020 Rites Road Suite 108 McCfl W_SbUt9, PA 17055 PmNe: 717.766.4008 FAx: 717.766.4066 1. The Plaintiff, Robert L. Zeigler, is an adult individual residing at 1478 Boiling Springs Road, Boiling Springs, Cumberland County, Pennsylvania 17007. 2. The Defendant, Geraldine A. Zeigler, is an adult individual residing at 915 Sand Bank Road, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 6, 1990 in Harrisburg, Pennsylvania. 5. Defendant separated from Plaintiff on September 1, 2008. 6. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 7. The Plaintiff and Defendant are both citizens of the United States of America. 8. The Defendant is not a member of the United States Armed Forces. The cause of action and section of•Divorce Code under which Plaintiff is proceeding is that the marriage is irretrievably broken under 23 Pa. Const. Stat. §3301(c) or 3301(d). 10. Plaintiff requests this Honorable Court to enter a decree of divorce pursuant to Section 3301(c) or 3301(d) of the Divorce Code. WHEREFORE, it is requested that the Court enter a decree of divorce under either §§ 3301(c) or 3301(d) of the Divorce Code. Respectfully submitted, 940,4 Zhn M. Kerr, Esquire I. D. #26414 Law Office of John M. Kerr, Esquire 5020 Ritter Road Suite 109 Mechanicsburg, PA 17055 (717) 766-4008 kerriaw@comcast.net Dated: March 10, 2010 OL M. e1r 5020 Ritter Road suite 108 MediarUcsblIIg, PA 17055 PHors: 717.788.4008 FAX: 717.766.4066 w VERIFICATION The undersigned, Robert L. Zeigler, hereby states that he is the Plaintiff in the foregoing Divorce action and, as such, is authorized to execute this Verification and that any factual statement contained in the preceding "Complaint in Divorce" is true and correct to the best of his knowledge, information and belief. He understands that false statements are subject to the penalties prescribed at 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Robert L. Z &r le)- / -7?O P. O. Box 9 Shertnansdale, Pa 17090 Phone: 717-2155793 ???w /? Fax. 717-582-3495 UC - '77 ' e-mail: ludanoleoDoDmcast.net ?7w r/?r4 s ;vi - _ 1,. AffkkvR Of Service I, Leo F. Luciano, hereby verify that on the date and time set below, I personally hand- served the subpoena to Kevin Preston at 915 Sand Bank Road, Mount Holly Springs, Pa. 17065. Mr. Preston acknowledged that Mrs. Geraldine Zeigler lived with him and Mrs. Zeigler was at hone but was unable to come to the door. Mr. Preston assured me he would give Mrs. Zeigler the Complaint in divorce. On the 2nd day of April, 2010 at 9:08 a.m. 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 unworn falsification to authorities. By: Se9 C- R-?;zzz' Leo F. Luciano Luciano Investigative Services, LLC P.O. Box 9 Shermansdale, Pa. 17109 SWORN to and subscribed before me this 1?day of Ht' Q i t 2010 Notary Publ COMMONWEALTH OF PENNSYLVANIA NOTNM SEAL, MARY Mkt C. t3AR8MFA NOTARY PUBLIC SILVER SPRINQ rm.., CUMB m*v COUNTY MY COMMISSION E? m p 13, 2012 ROBERT L. ZEIGLER, Plaintiff V. GERALDINE A. ZEIGLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-1750 CIVIL - DIVORCE ?- p PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE Y Law Offim of ohn M.err 5020 latter Road Suite 109 MedW*Sbtx9, PA 17055 Rt : 717.766.4008 FAx: 717.766.4066 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 11, 2010. 2. The marriage of the plaintiff and the Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 1 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. Dated: ( 110 Signature: ROBERT L. ZEIGLER, Plaintiff V. GERALDINE A. ZEIGLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-1750 CIVIL- DIVORCE - « i ELI ,s- WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. 1 consent to entry of a final decree of divorce without notice. 2. 1 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. 1 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. 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: Robert ?-Rgler, Plaintiff Law Office of Yohn M.15err 5020 R111U Road State 108 MBd1 9csbuM. PA 17055 Ftior>e: 717.766.4008 FAx: 717.766.4066 ROBERT L. ZEIGLER, Plaintiff V. GERALDINE A. ZEIGLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-1750 CIVIL - DIVORCE _a S'r1 -s. r F?, DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March ?w«?;?eof ohn M.?err 5020 Rt" Road Suite 108 MedMICOW, PA 17055 Priarac: 717.766.4008 FAx: 717.766.4066 11, 2010. 2. The marriage of the plaintiff and the Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. E_ 4. 1 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. Dated: lU J1? ; "T a?? (? Signature: ROBERT L. ZEIGLER, Plaintiff V. GERALDINE A. ZEIGLER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO 10-1750 . LQ 71 7,7 ,f I CIVIL - DIVORCE '- :j WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. 1 consent to entry of a final decree of divorce without notice. 2. 1 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. 1 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. 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: P a, 14t 4 01 0 - Geraldine A. Ze' er, D endant Kl? Law Of(im of ohn M.?err 5020 FWM Road Suite 109 Medwksh ug, PA 17055 PHom: 717.788.4008 FAx: 717.788.4088 ROBERT L. ZEIGLER VS. GERALDINE A. ZEIGLER IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 10 - 1750 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: -air Irretrievable breakdown under § (3301(c)) and § (33444)(1)) of the Divetee-6ode. a(Strike out inapplicable section.) 2. Date and manner of service of the complaint: - hand-served on April 2, 2010 by Leo Luciano at 9:08 a.m. 3. Complete either paragraph (a) or (b).a (a) Date of execution of the affidavit of consent required by § 3301(c) of the Divorce code: by plaintiffI l/15/10 ; by defendant 11/14/10 (b) (1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's § 3301(d) affidavit upon the respondent opposing party: 4. Related claims pending: none 5. Complete either (a) or (b) (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date plaintiff's Waiver of Notice was filed with the Prothonotary: 11/17/10 Date defendant's Waiver of Notice was filed with the Prothonotary: 11/17/10 Attorney for Plaintiff4)*fsad" ' f ROBERT L. ZEIGLER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. GERALDINE A. ZEIGLER NO. 10 - 1750 DIVORCE DECREE AND NOW, tI ovt mlot f 11 , 100 , it is ordered and decreed that ROBERT L. ZEIGLER plaintiff, and GERALDINE A. ZEIGLER , 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, ltk,? ?!l Attest: J. Prothonotary 0 - a A4Y J. k C°!'Y