HomeMy WebLinkAbout04-3501VICKI A. ZINN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v CIVIL ACTION - LAW SHANE A. ZINN, NO. 2004 - 3S01 latxl "
Defendant DIVORCE
NOTICE TO PLEAD
You have been sued in Court. If you wish to defend against the claims set forth in the
following pages, you must take action within (20) days after this complaint and notice are
served, by entering a written appearance personally or by attorney and filing in writing with
the Court your defenses or objections to the claims set forth against you. You are warned that
if you fail to do so the case may proceed without you and a judgment may be entered against
you by the Court without further notice for any money claimed in the complaint or for any
other claim or relief requested by the Plaintiff. You may lose money or property or other
rights important to you.
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
32 South Bedford Street
Carlisle, Pennsylvania
717-249-3166
VICKI A. ZINN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v
CIVIL ACTION LAW
SHANE A. ZINN, : NO. 2004 - 3S01 ?t UL
Defendant : DIVORCE
COMPLAINT
Plaintiff, Vicki A. Zinn, by her attorneys, Broujos & Gilroy, P.C., sets forth the following:
1
Plaintiff, Vicki A. Zinn, is an adult individual residing at 659 Hamilton Street, Carlisle,
Cumberland County, Pennsylvania, 17013.
2
Defendant, Shane A. Zinn, is an adult individual residing at 1194 Green Spring Road,
Newville, Cumberland County, Pennsylvania, 17241.
3
Plaintiff and Defendant were married on September 14, 1996 in Newville, Cumberland
County, Pennsylvania.
4
Both Plaintiff and Defendant have resided continuously in the Commonwealth of
Pennsylvania and in Cumberland County for at least 6 months prior to the commencement of
this action.
5
There have been no prior actions for divorce or for annulment of this marriage.
6
The marriage is irretrievably broken.
WHEREFORE, the Plaintiff requests your Honorable Court to enter a decree divorcing her
from Defendant.
BROUJOS & GILROY, P.C.
By
Hubert X. Gil y, Esquire
Attorney for laintiff
Broujos & Gilroy, P.C.
4 North Hanover Street
Carlisle, PA 17013
717-243-4574
I verify that the statements made in the foregoing document 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 unworn falsification to authorities.
DATE: n4- ? V? A _?-4?
?c A. Zinn
7j- -609.
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VICKI A. ZINN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
SHANE A. ZINN,
NOTICE
if you wish to deny any of the statements set forth in this affidavit, you must file a counter-
affidavit within twenty days after this affidavit has been served on you or the statements will
be admitted.
AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE
1. The parties to this action separated on June 11, 2004 and have continued to live
separate and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. 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.
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 unworn falsification to authorities.
DATE:
: NO. 2004-3501
Defendant : CIVIL ACTION - LAW
VI A. ZI , P intiff
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Curtis R. Long
Prothonotary
Office of the Vrotbonotarp
(Cutnbertanb Countp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
6 14 - 3961 CVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573