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Home My WebLink About04-3500 o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - LAW J~\ietz.~ Plaintif! :No.04..j5oo Civil Term v. If 0. \j \s (fl.l.(xro.5(2, De-tendant : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HA VE 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 ofthe marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'S FEES OR EXPENSES BEFORE A DIVORCE OF 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, P A 17013 (717) 249.3166 J\).\~ €. f.- ZG.n~ Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. No. 04- CML TERM \(o..~6 (\I z. o.V\~ Se.. Defendant IN DIVORCE COMPLAINT UNDER ~3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is Ju\ \'€. C- 7_oV'lC) . ~ C\ mead..'oroo'L G( +- . who currently resides at ~u..J CUn'\'a..or\ o.nd Po.. Cumberland County. Pennsylvania. J: D ~ f'S 38qq 2. Defendant is\('(}.,\lIS rn /'f\rr<j ,who currently resides at S,CI ~a:'X...U~I~ Qo 00)( A Bp\\e.. +on+e_ ffi. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. D,J io..nlc l-\h<j Qo.. (\l~~ ~~ Iqq~ at 4. Plaintiff and Defendant were married on 5. The marriage is irretrievably broken, and the parties separated on Fe.'o ~OOt..j 6. There have been no prior actions of divorce or annulment between the parties. :ae none cr\ter 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce, 1- IS-OL\ Date a. L\ ,~ f, /IX1J'<lOr :R)aintiff, Pro Se U- 0 I, q -v-Lo ~~]'{\?J , verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. ~4904. 1- \S-o'-\ Date: ~~S~~ Assisted by: MID PENN LEGAL SERVICES PRO SE DIVORCE CLINIC 8 Irvine Row Carlisle, Pennsylvania 17013 (717) 243-9400 " r-.' , ' , .. -,) ',~::) (..'; .,-~! \--\ 7'\ ~ o IN THE COURT OF COMMON PLEAS Plaintiff Ju. he. 6,: OF CUMBERLAND COUNTY, l.aro :.'. PENNSYLVANIA . J 350'> v. NO. 04' CIVIL TERM Ir 0.\.1\:' f'\I Zana.Se.: Defendant J : DNORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, c\u\\€. [. 7 .o.Yl~ ,Plaintiff, to proceed in forma pauperis. I, Jessica Diamondstone, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. dff- Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ,-, ,-..... ,'.:..J ..') III '1'0 CODa'l' or COMMoN PLDS or CUllBbLAlm COUll'l'Y PBKNS!LVARIA CIVI~-LAW JULIJ: E. lARa, . Plaintiff, . . No. 0'1-3500 Civil 'I'ent V. . . III DI"ORCE 'I'IlAVIS M. IAIfG SR. . Defendant. I CO(l,uU-APFIDAVI'I' UIID~ 3301 W or '!'lIB DIVORCE I 1. Check either (a) or (b): (a) I do not oppo.e the entrey o:f a divorce decree. (~oPpo.e the entry of a divol~ce decree becau.e (Check (I), (~or both: (~he partie. to this action have not lived .eparate and apart for a period of at least two ye'ars. (~e marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any' claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyers fees or 'Iuc:penses if I do not - clai. the. be;pre a divorce is granted. (~ whh to claim econOmic relief which may include alimony, divlslon of property, lawyer's fees and expenses or other lmportant rlghts. I mu.t also fl1e all my economlc claims wlth the prothono I understand that ln addltion to checking (b) above, tary ln writing and serve thelll on the other party. If I fall to do so before the date set forth on the Notice of Intention to aequest for Divoce Decree, the divorce dlecree may be entered without further notice to me, and I shall be unable thereaf ter to fl1e and economic clalms. CElt'l'IPICA'1'I!: or SDnCl: - that on July 30, 2004, an original copy ofl I, Defendant Travis M. Zang Sr, pro se, hereby certify Clowlter:-Affidayit under: S 3301 (d) elf '!'be Dber:ce Code was _iled tOI Prothonotary, Court of CO'lRftlon Pleas of Cumberland County 1 Courthouse Square Carli.le, PA and one copy tOI Julie E. Zang, pro .e plaintiff C/O Midpenn Legal Servi,ee. Pro .e Divorce Clinic !l Irvine Row Carli.le, PA 17013 by placing them Into separate envelopes ~lnd l1Iailing them via the normal procedures at SCI-Roekvlew. Respec~tful1y sUbmitted, Travis M. Zang SR IFS-3!l99 Box A Bellefonte, PA 16823 defendant requests. to PaRCivp 3302 (relating to counseling') and for which the 3. Mr. and Mrs. Zang are entitled to counseling according YBRIPlCA'l'IO. I Verify that the stAtementa .ad41 in this Counterclaim_ affidavit are true and correct. I under.ltand that false state ments of any kind are made subj ect to the penal ties of 18 Pa. C.s.~ 4904, relating to unsworn falsification to authori Ues. July 30, 2004 Respectfully submitted, ./ ~~~ -2- >- lr r<~ Ji;i() ~'F~? c5('.,:',; ,', CCf': liJO." ~~L~ ,:!:: u_ Q N (:) ::.) ,",,'.r: -"- c::~ C:;;J '" e- M ~ "'"' c: ,-- !:~:: ~) Julie E. Zang Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTI' PENNSYL V ANlA v. No. 04-3500 CIVIL TERM Travis M. Zang Sr., Defendant IN DIVORCE ACCEPTANCE OF SERVICl!~ I, Travis M. Zang Sr., accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsification to authorities. '6 - If - 0 c( Date -7'------~ ;2:l.~ Travis M. Zang Sr" enoant / ,..., ~g .J::~ :C;1'.1> '-,..~" G'"; 0'"\ "Q "'~", ., -.. (J1 '-'" o Julie E. Zang Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. No. 04-3500 CIVIL TERM Travis M. Zang, Sr. Defendant IN DIVORCE AFFIDAVIT OF CONSENT I. A complaint in divorce under g330 I (c) of the Divorce Code was filed on ay 28, 2004. 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety ays 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 divorce. I verify that the statements made in this affidavit are true and correct. I unders nd that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 904 relating to unsworn falsification to authorities. Date: !r 1D ~ 05 Signature: Jul' c' c $. "'o,E: o;\_~ ' .4- .,,--. 2C ~~; ~~ 'J?C:; ...-( , j.~C ~j -< ....' c:;> 0= ,",' :;;r:. ~ f"..) rv -0 ~ C) ...,. .... :>:.,-, rnp "-'drn ~j9 (~~; (l~~ ~.t: -1"1 '~t,J'~ ~~ <~j :.--::; v.) Julie E. Zang Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. No, 04-3500 CIVIL TERM Travis M. Zang, Sf. Defendant IN DIVORCE I. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division ofprope fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered b and that a copy of the decree will be sent to me immediately after it is fi Prothonotary. c A , lawyer's the Court d with the I verify that statements made in this affidavit are true and correct. I und rstand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94 4 relating to unsworn falsification to authorities. Date: 3 -\0 - O~) Signature: Juli ~, "'" ~ :;J: ~ "" "" Q L- S. -0,-1\ r'i~1\;" ~~;o: U:J"?" .~t: 1zj, ;;:"'C~ 2- ':2 """ ';;$. o -n .-\ :;1:..,-. r\1--:::: -0 (n :py (.)C) .,.-\ ~( -1~ ~l!' Dr:::' .~~t'-\ ~t r :D. - ....> ~ - ~ 1<n-(P~-112.2 Julie E. Zang Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. No. 04-3500 CIVIL TERM Travis M. Zang, Sr. Defendant IN DIVORCE AFFIDAVIT OF CONSENT I. A complaint in divorce under ~3301(c) ofthe Divorce Code was filed on May 28, 2004. 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety 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 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: '{. JS - oS-- Signature: -Z:;./- _/l.~ travis M, Zang, Sr., Dc;.tt"ntfifut '-- ~ --tl(:P: -(' 'i'; ~, ~'.t ~~,.. \..c.C) ,%(' ._c yC ~ - ~ ~ <e, ~ , C1' ~ '-R r" u:> q.. ~~ ~~, ,,,\.----{". ~'$f, r:/ -'^ ~ Julie E. Zang Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. No. 04-3500 CiVIL TERM Travis M. Zang, Sr. Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &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 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. 94904 relating to unsworn falsification to authorities. Date: '(;;.S-oS- Signature:0. ~ - ~~ Travis M. Zang, Sr., efi dant t ... . a ~ q. ~ '&\ ~ 5<.. 'e ~~ '8;-0:> q~l\ ~ "'~ \ !~ th.,. c1' ~t ~ ~?Q ~'2, ~R- -P. 9- G ~ ~ ~ ::..G . Julie Ellen Zang Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL V ANlA v. Travis M. Zang Sr., No. 04-3500 CIVIL TERM IN DIVORCE Defendant 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 330 l( c) ofthe Divorce Code. 2. Date and Manner of service of the Complaint: Defendant signed Acceptance and Acknowledgment of Service form on AUl!ust 11. 2004. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, March 10,2005; by Defendant, July 5, 2005. 4. Related claims pending: There are no outstanding claims. 5. Date Plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: March 22, 2005. (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: July 7, 2005. Plaintiff's Social Security Number: 187-64-7128 Defendant's Social Security Number: Unknown / Jessica Dia Attorney fo Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 :7:~:j - r.:.: if," ~ Q 5" ::,P,tt: ~ ~ c..... c:- r I co fii :o-l :t:_ n,S! ,..- :;Qrn d? ~:!! r;; '~'?i ',"'-')" ~~ QI'n -, S~ ~ ...., .h. .::i:' ':9 <i:l Julie E. Zang Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA v. No. 04-3500 CIVIL TERM Travis M. Zang, Sf. Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under g3301(c) ofthe Divorce Code was filed on May 28, 2004. 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety 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 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: 1- 6S -oS Signatur~. _- Travis M. Zang, Sr" Defi Q s; Q?)f ~ '8> 'e, r \ -' ~ %~ ~~. -,- ""(, q~ ..-0 ..,.{ ~ '(?- --:: '::~ '3, - Julie E. Zang Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. No. 04-3500 CIVIL TERM Travis M. Zang, Sf. Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3.301(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 in 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 statements made in this affidavit are tme and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities. Date: 7 -os -os / " /0:/; /A Signatur~~c.---- // ' ~ Travis M. Zang, Sf., ndant - ~" ".,.-." r~:>t>..'" -'. .' -". ,- .,...,~~",~" 'i.~'':.'"'' ,,~.:' .. ...'tf..; .. '2. "" <:-;:"p ~ 'iJ. 'e; r \ -' '~L\:-' -';';;::;' ..-~ /..--~ cn. ./- -,. <L:,C '?~::;;;~ -0':1' :2. q. ~~ ~r<' o~ "1 -r' -5-....0 QQ tY~' .:A ~ c;;.. "" "'" ~ -- .' . . ;F.;+: Of. ~'+' . . . . . .. . . . . . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY . . . . . . . . . . STATE OF PENNA. . . . . . . . . . . . . . . . . . . . . . . Julie Ellen Zang . . . . . Plaintiff N 04-3500 O. . VERSUS . . . . Travis M. Zang Sr. Defendant . . . . . . . . . . DECREEINI DIVORCE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8th Day of July Julie Ellen Zang 2005 AND NOW, , IT IS ORDERED AND . DECREED THAT , PLAINTIFF, . . . . Travis M. Zang Sr. . . AND , 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; . . ).k loll. . . . . . . . . . . :t' Of.:+' :+' Of Of Of. Of Of.;F.,.,+ . . . OUR~d . . . . . . . . . . . . J. . . . . . . . . . . PROTHONOTARY . . . . .. .. . . . -;:Ip:? ~ ~ ~.;IL 5';<' ?~ ~p;i 50' j1L .," .. ..'\"' 4& '~ :".,,"- .',," - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA -03soo Plaintiff Vs File No. IN DIVORCE efendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "XI prior to the entry of a Final Decree in Divorce., _ or after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of ?'?Cu ' and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Date:_ Sig a ure 0 Y1? Signature of name being esumed COMNVIONWF?LTH OF PENNSYLVANIA COUNTY OF1 /,, IN ..0 On they of J;.-?. c/Z- , 201 - I &, before me, the Prothonotary or the notary public, personally appeared the above affiant known. to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. Prothonotary or otary Public Mr co?la? ?iw a?? d J?M..1111 RLED-40-TCE A1?V r1? T it 1.- ?l-hT'T ;c,-N--7 AMII:3E CUMB €',., IrJL?iv1 PENNSYLVAN A A» e„r,!ht?;".fit?h?l hn?t ?'Y:v t ?;«,..,?tt•:s? ?? .? SJ [it'n'W?lt y{tif tit ? dsk..j`,A tKll?i..+ ??"