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Home My WebLink About10-1754IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION ELIZABETH ANNE ZELL, Plaintiff v. to-054 O',,'me'K No: _N RCE _ -n IGHTS rv O R ch ?.J -n M DIV JONATHAN MICHAEL ZELL, Defendant NOTICE TO DEFEND AND CLAIM 7- Urn b 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 Cumberland County Courthouse, 1 Courthouse Square, Suite 100, Carlisle, PA 17013. 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 O!S&. oo Px? ATrN co log 4 P-1roa31? I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION ELIZABETH ANNE ZELL, Plaintiff V. JONATHAN MICHAEL ZELL, Defendant No: DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE I. Plaintiff, Elizabeth Anne Zell is an adult individual with an address of 114 Pearl Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant, Jonathan Michael Zell is an adult individual residing at 4606 Northwest 19`h Street, Apartment 19, Oklahoma City, Oklahoma. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on July 23, 2005, in Carlisle, Cumberland County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Service Members' Civil Relief Act of 2003. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The parties have not entered into a written agreement as to equitable distribution of marital property, alimony, alimony pendente lite, spousal support, counsel feels and costs. 8. Plaintiff acknowledges that she has been advised of the availability of counseling between the parties and that she may have the right to request that the court require that parties to participate in such counseling in certain instances. 9. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce pursuant to Section 3301(c) or 3301(d) of the Divorce Code. Date: Girard T. Rickards, Esquire Attorney ID No. 58867 135 South Duke Street York, PA 17401 (717) 845-4038 VERIFICATION Plaintiff verifies that the statements made in this Complaint in Divorce are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Elizabeth ell Date: 21311-0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ELIZABETH ANNE ZELL, No: 10 - 1754 Civil Term Plaintiff DIVORCE v. JONATHAN MICHAEL ZELL, . Defendants c ~ AFFIDAVIT OF CONSENT UNDER SECTION 3301(C) '~ t~ rT; ~ ~' cq... ~ '~ --~ ~ ~~ OF THE DIVORCE CODE ~ ' '' -,_ -t 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filedarc 11 2010 .. -i ~` , and served on March 12, 2010. ~; 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 in divorce. 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. Section 4904 relating to unsworn falsification to authorities. Date: ~~~s/i~ Elizabe a Zell, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ELIZABETH ANNE ZELL, Plaintiff v. JONATHAN MICHAEL ZELL, Defendants No: 10 - 1754 Civil Term [~ o ' DIVORCE ~ ° ~ ~ ~ ~' ~ m ate • NYC.. N - _~3~ . ,. _~ , . ~ ss ~ ~,..' ~~, ;5a~ N ~, ~ -G ..,3 WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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. 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. Section 4904 relating to unsworn falsification to authorities. Date: ~/o?~`~v Elizabe a Zell, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ELIZABETH ANNE ZELL, No: 10 - 1754 Civil Term Plaintiff DIVORCE v. ,,,,, °- `~, ~ c.... ~ ~ ~ JONATHAN MICHAEL ZELL, ; '~' ~ ` " m ~F~ Defendants cn - ~;: .gy ~ ~:' ,r, ~ ~ ~_~ =~- ~~ AFFIDAVIT OF CONSENT UNDER SECTION 3301(C) ~ ~ ~~'~ rrr ~~ OF THE DIVORCE CODE ~ ~ ~ 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 11, 2010 and served on March 12, 2010. 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 in divorce. 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. Section 4904 relating to unsworn falsification to authorities. Date: June 14, 2010 ~i~~ ~/, J athan M. Zell, Defend IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ELIZABETH ANNE ZELL, No: 10 - 1754 Civil Term Plaintiff DIVORCE a n , v. ~ JONATHAN MICHAEL ZELL ' `'~ -- ~` ~" =~ De en ants ~~~ ~~.. .., ,~, r, ..c, ~ , c:,:• c /ten- ~//~` 1.-.- ~ ~ M> ~. WAIVER OF NOTICE OF INTENTION '' TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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. 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. Section 4904 relating to unsworn falsification to authorities. Date: June 14, 2010 J athan M. Zell, Defendant r 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION ELIZABETH ANNE ZELL, Plaintiff v. JONATHAN MICHAEL ZELL, Defendant No: 10-1754 Civil Term DIVORCE N ~ , ~ ~ ~ ~i~ . ~_ ~ ' ~m ' C N ~ r c .~ ~ ~;. _;; ~,~ ~- 'Tr ~~ N rr~ CERTIFICATE OF SERVICE •' '~ ~ ~ I, Girard E. Rickards, attorney for the plaintiff, do hereby certify that on this day I have served the defendant with a true and correct copy of the foregoing Plaintiff s Affidavit of Consent, Defendant's Affidavit of Consent, Plaintiffs Waiver of Notice and Defendant's Waiver of Notice, via first class mail, postage prepaid as follows: Jonathan Michael Zell 3501 Apollo Drive Apartment 242 F Metairie, LA ?0003 Date: June 28, 2010 Girard E. Rickards IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ELIZABETH ANNE ZELL V. JONATHAN MICHAEL ZELL NO 10-1754 Civil Term DIVORCE DECREE AND NOW, ~c~(~. 8 ~ Zoi o , it is ordered and decreed that ELIZABETH ANNE ZELL plaintiff, and JONATHAN MICHAEL ZELL ,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, 7.9 • l O Cu--~. ~ mmcx:- lid -+o `7.9 • t p Ivot; ~ tra:~ 1 ~c~ -Eo ' t~.e-£~. I~; ck.ar c~ S