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HomeMy WebLinkAbout04-2900HAROLD S. IRWIN, III, E~CIUilI~ ATTORNEY ID NO, 29920 64 ~QUTH Prrr STREET CARL~L! FA 17013 ATTORNEY FOR PLAINTIFF CHARLES M. ZIMMERMANy Pl,,Intlff : IN THE COURT OF COMMON PLEAS OF : CUMBERLANO COUNTY, PENNSYLVANIA : c~w- ACTaON_- LAW : NO. 04 - '~ ~__~_C~_ CIVIL TERM MARIAN C. ZIMMERMAN~ : Defendant : IN 01VORCE 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 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 dghts 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, Cumberland County Courthouse, Carlisle, Pennsylvania 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 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-243-3t66 CHARLES M. ZIMMERMAN, Plaintiff V, MARIAN C. ZIMMERMAN~ Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : CIVIL ACTION - LAW : NO. 04 - .~,~z.~ CIVIL TERM : : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 (c) OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, Ill, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is CHARLES M. ZIMMERMAN, an adult individual residing at 16 Wood Lane, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is MARIAN C. ZIMMERMAN, an adult individual whose last known address is 24 South Baltimore Street, Mt. Holly Springs, Cumberland County, Pennsylvania 17065. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were married on September 20, 1996, in Hagerstown, Maryland. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the dght to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. I vedfy that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unswom falsification to authorities. June 22, 2004 HAROLD S. IRWIN, II1~ J Attorney for Plaintiff ~ 64 South Pitt Street Carlisle, Pennsylvania 17013 (7t7) 243-6090 Supreme Court ID No. 29920 CHARLES M. ZIMMERMAN~ Plaintiff V. MARIAN C. ZIMMERMAN~ Defendant : IN THE COURT OF COMMON PLEA8 OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 04 - ,~'~ CIVIL TERM : · ' IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, 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 Prothonotary's 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. June 22, 2004 ~M. Z~ CHARLES M. ZIMMERMAN, Plelntlff V. MARIAN C. ZIMMERMAN, Defendant : IN THE COURT OF COMMON PLEA8 OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : CIVIL ACTION - LAW : NO. 04- ~.~6_ CIVILTERM ., : IN DIVORCE ACCEPTANCE OF SERVICE I, Marian C. Zimmerman, defendant in this divorce action, hereby certify that I received a copy of the complaint in divorce on or about June 23, 2004 by personal service upon me at 64 South Pitt Street, Carlisle, PA 17013. I verify that the statements made in this acceptance of service 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. June 23, 2004 MARIAN C. ZI~IMERMAN~/ CHARLES M. ZIMMERMAN, Plaintiff V, MARIAN C. ZIMMERMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04 - 21)00 CIVIL TERM IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about June 23, 2004. Service of the complaint was made on or about June 23, 2004, by personal service (see Acceptance of Service filed June 24, 2004). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unswom falsification to authorities. SEPTEMBEI;~,~, 2004 CHARLES M. ZIMMERMAN, Plaintiff MARIAN C. ZIMMERMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ., : CIVIL ACTION - LAW : NO. 04 - 2900 CIVIL TERM : : IN DIVORCE WAIVER OF NO_T~I~E~O~F~INTENTIp~N~T~ REQUEST E_~NTRY ~F~ A DIVORC_E~_J~R~KE UNDER 8E~C~T~ON 33__0_~ (C~_ OF TfiE__~DI_~VOR~CE_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. 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. September~q..7,2004 CHARLES M. Zl CHARLES M. ZIMMERMAN, Plaintiff MARIAN G. ZIMMERMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 04 - 2900 CIVIL TERM : : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, 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 Prothonotary's 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. I verify that the statements made in this affidavit are true and correct. understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. Septernber~;~, 2004 CHARLES M, ZIMMERMAN CHARLES M. ZIMMERMAN~ Plaintiff MARIAN C. ZIMMERMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .. : CIVIL ACTION - LAW : NO. 04 - 2900 CIVIL TERM ; : IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divome under Section 3301(c) of the Divorce Code was filed in this matter on or about June 23, 2004. Service of the complaint was made on or about June 23, 2004, by personal service (see Acceptance of Service filed June 24, 2OO4). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. September,,~,~-, 2004 CHARLES M. ZIMMERMAN, Plaintiff MARIAN C. ZIMMERMAN~ Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04 - 2900 CIVIL TERM IN DIVORCE DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, 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 Prothonotary's 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. September/~-~, 2004 N C. ZIMMERM~3~I CHARLES M. ZIMMERMAN~ Plaintiff V. MARIAN G. ZIMMERMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; : CIVIL ACTION - LAW : NO. 04- 2900 CIVIL TERM : : IN DIVORCE CHARLES M. ZIMMERMAN, Plaintiff MARIAN C. ZIMMERMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04 - 2900 CIVIL TERM IN DIVORCE 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 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, 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. September ~2004 ZIMMERM,~N HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 04 SOUTH pITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF CHARLES M. ZIMMERMAN, Plaintiff MARIAN G. ZIMMERMAN, DefendRnt : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA _. : CIVIL ACTION - LAW : NO. 04 - 2900 CIVIL TERM : : IN DIVORCE 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: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about June 23, 2004, defendant was personally served with a copy of the divorce complaint (See Acceptance of Service filed June 24, 2004). Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301 (c) of the Divorce Code: By the plaintiff: September '~,,7 ,2004 By the defendant: September '~,~'~, 2004 (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiff's affidavit upon the defendant: N/A. 4. Related claims pending: None September ~_.~,, 2004 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: N/A. (b) Date plaintiff's Waiver of Notice in Section 3301(c) divorce was flied with the Prothonotary: September ~--7-, 2004 Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: September '~'~, 2004 IN THE COURT OF COMMON PLEAS CHARLES M. ZIMMERMAN, Plaintiff OF CUMBERLAND COUNTY STATE OF PENNA. NO. 04 - 2900 CIVIL TERM VERSUS MARIAN C. ZIMMERMAN, Defendant DECREE IN DIVORCE AND NOW, ,~¢...."~T, ~E~ DECREED THAT Charles M. Zimmerman AND Marian C. Zimmerman 2004 , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; none. BY THE COURT: ~O ~./~ /~~ PROTHONOTARY