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Home My WebLink About04-6341 d Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 SUSAN W. ZIMMERMAN, Plaintiff v. IN THE COURT OF CONIMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . NO. 04- b311/ C;u~ C-ru__-", CIVIL ACTION - LAW IN DIVORCE LAWRENCE B. ZIMMERMAN, Defendant NOTICE TO DEFEND AND-CLAIM RIGHTS 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 and visitation of your children. When the grounds for a 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's Office at the County Courthouse. 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) 249-3166 Barbara Sumple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 SUSAN W. ZIMMERMAN, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA NO. 64- W4/ C!ioL '-r"i'ILi CIVIL ACTION - LAW IN DIVORCE LAWRENCE B. ZIMMERMAN, Defendant COMPLAINT IN DIVORCE 1. Plaintiff is Susan W. Zimmerman, an adult individual residing at 27 Sycamore Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant is Lawrence B. Zimmerman, an adult individual residing at 119 South Market Street, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4. The Plaintiff and Defendant were married on June 6, 1992 in Mechanicsburg, Cumberland County, Pennsylvania. o 5. There are two (2) minor children born of this marriage, namely Jacob Zimmerman, born May 7, 1994 and Elizabeth Zimmerman, born April 3, 1996. 6. The parties separated on September 1,2004. 7. The Plaintiff previously filed for divorce on February 26,2003 under York County Docket No. 2003-SU-00951-02D. 8. Neither Plaintiff nor Defendant is in the military or naval service ofthe United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 9. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT 10. The averments in paragraphs 1 through 9, inclusive, of Plaintiff's Complaint are incorporated herein by reference thereto. 11. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with 9 3301 of the Pennsylvania Divorce Code. INDIGNITIES 12. The averments in paragraphs 1 through 11, inclusive of Plaintiff's Complaint are 2 incorporated herein by reference thereto. 13. Plaintiff is the innocent and injured party, and Defendant has offered such indignities to the person of the Plaintiff and has been mentally cruel to her so as to make her life burdensome and her condition intolerable, in violation of the marriage vows and of the laws of the Commonwealth. WHEREFORE, Plaintiff requests this Court to enter a decree in divorce in accordance with the Pennsylvania Divorce Code. COUNT II EQUITABLE DISTRIBUTION 14. The averments in paragraphs 1 through 13 of Plaintiff's Complaint are incorporated herein by reference thereto. 15. The Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties in such proportion as the Court deems just after consideration of all relevant factors. WHEREFORE, Plaintiff requests this Court to equitably divide said property in accordance with Section 401 (d) of the Pennsylvania Divorce Code. COUNT m SUPPORT. ALIMONY PENDENTE LITE AND ALIMONY 16. The averments in paragraphs 1 through 15, inclusive, of Plaintiff's Complaint are 3 incorporated herein by reference thereto. 17. Plaintiff requires reasonable support to adequately sustain herself with the standard of living established during the marriage. WHEREFORE, Plaintiff requests an award of Support, Alimony and Alimony Pendente Lite. COUNT IV ATTORNEY'S FEES AND COSTS 18. The averments in paragraphs 1 through 17, inclusive, of Plaintiffs Complaint are incorporated herein by reference thereto. 19. Plaintiff is unable to sustain herself during the course of this litigation and has employed Barbara Sumple-Sullivan, Esquire as counsel, but is unable to pay the necessary and reasonable attorney's fees for said counsel, and the necessary and reasonable costs and expenses. WHEREFORE, Plaintiff requests an award of counsel's fees and expenses. WHEREFORE, Plaintiff, Susan W. Zimmerman, prays this Honorable Court to enter judgment: A. Awarding Plaintiff a decree in divorce; B. Awarding Plaintiff support, alimony and alimony pendente lite; C. Awarding Plaintiff counsel fees, costs and expenses; 4 D. Equitably distributing the marital property; and E. Awarding other relief as the Court deems just and reasonable. Dated: December ~W04 ---- Z- ;/Barbara Sumple-Sullivan, Esquire { Attorney for Plaintiff 549 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court J.D. No. 32317 5 Barbara Sump1e-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 SUSAN W. ZIMMERMAN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. LAWRENCE B. ZIMMERMAN, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT REGARDING COUNSELING 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 Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not require that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A Section 4904 relating to unsworn falsification to authorities. Dated: I J.-/ I () ( U Y ~{j ,~k1/La{ SUSAN W. ZIMMERMAN Barbara Sump1e-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 SUSAN W. ZIMMERMAN, Plaintiff IN THE COURT OF COMMON PLEAS CUJ\1BERLAND COUNTY, PENNSYLVANIA v. : NO. LAWRENCE B. ZIMMERMAN, Defendant CIVIL ACTION - LAW IN DIVORCE VERIFICATION I, SUSAN W. ZIMMERMAN, hereby certify that the facts set forth in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to authorities. Dated: I~/O ({l-f ~ -~ l U) 9vu.,.~ SU . IMMERMAN P -Itl( it) RJ '"'<l #. 'i -.... C1 5'- ...0 .......... 6"- 0 c; (") !'-~1 0 C":;:') ~ . C f..:. .:-.~ -;"' "{) V) V") ..s;- D -, C::l ---( -<:: ~ () C; D I I f'I"1 :\~ C) I' , [p - Ie, -':,1 I .' , -"1 I _l :'.'1\ , " I. I tv :r,. (~I , - :J~: , Ft " )c. , ~ : .~ (< I \Cl I ::t:> -"I c..!1 t ~ -< 0" "'I- ~ "-.( ~ If SUSAN W. ZIMMERMAN, Plaintiff IN THE COURT OF COMMON PLEAS YORK COUNTY, PENNSYLVANIA v. : NO. 04-6341 LAWRENCE B. ZIMMERMAN, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDA VIT OF SERVIC:E~ I, Barbara Sumple-Sullivan, Esquire, do hereby certify that I served a copy of the Complaint In Divorce in the above-captioned matter by United States Mail, Restricted Delivery, Certified No. 7003 05000001 65586020, Return Receipt Requested, on the above-named Defendant, Lawrence B. Zimmerman, on or about December 29, 2004 at Defendant's last known address: 119 South Market Street, Mechanicsburg, PA 17055. The original receipt and return receipt card are attached hereto as Exhibit "A". I hereby certify that the facts set forth above are true and correct to the best of my ,. knowledge, information and belief I understand that any false statements made herein are subject to penalties of 18 Pa. C.SA ~4904 relating to unsworn f~sifi6,9 aut rities. // / ....."L I B~l le- ullivan, Esquire 549 Bridg(~ Street New Cumberland, P A 17070-1931 (717)-774-.1445 Supreme Court ill #32317 Attorney fc)r Plaintiff Dated: I d-. - &) - O~ ~. 7003 d ~ ......1IIIlIIliIl __~l----~- -.- -- . mm...-\ U.S. Postal Service" CERTIFIED MAIL, RECEIPT (Domestic Mail Only; No Insurance Coverage ProvideCl) c:J ru c:J ..D o::ti U1 L11 ...Q '....:I t:l o t:l o o Ul o ITI o t:l I"'- . .. . , . . ... :" . , I h' < ~ I lE_tsdG M 17is$ '-;, ' .. - - Postage $ 10.110 Certified Fee $2.30 0070 ~_.-_ ~~~~ Return Reciept Fee $1.75 ,,'~~ '9,/~ (Endorsement Required) ~~'WUt "1"' Restrtcted Delivery Fee $3.50 C :J. () \ n\ (Endorsement Required) \J~ ~:4 );?I Total Postage & Fees $ $8.15 /--~/ Exhibit "A" -:.' r; r1 ~ r --7' - ..~- ;,< <.. (/) . :/ C:l: 0.- ~~~:-; :;:>-C ~ o G '" r-> = = <J\ <- :P' Z I W .. -0 ::1: r.:-? r N ~ .~ :Coon rllp -Om :n9 S~. ..;---1'1 QB ,-:::') rt1 :::-\ :r ~ Barbara Sump Ie-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 SUSAN W. ZIMMERMAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-6341 LAWRENCE B. ZIMMERMAN, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO WITHDRAW TO THE PROTHONOTARY: PLEASE WITHDRAW Plaintiff's Divorce Complaint and close this action without 7 prejudice. // /.-/ DATE: ...-/ ~ October -' 2005 Barbara Sumple-Sullivan, Esquire 549 Bridge Street New Cumberland, P A 17070-1931 (717) 774-1445 Supreme Court LD. 32317 Attorney for Plaintiff Barbara Swnple-Sullivan, Esquire Supreme Court #32317 549 Bridge Street New Cwnberland, P A 17070 (717) 774-1445 SUSAN W ZIMMERMAN, Plaintiff : IN THE COURT OP COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 04-6341 LAWRENCE B. ZIMMERMAN, Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Laura J. Hughes, Secretary to Barbara Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true and correct copy of the foregoing Praecipe to Withdraw Plaintiff's Divorce Complaint, in the above-captioned matter upon the following individual by first class mail, postage prepaid, addressed as follows: Melissa Peel Greevy, Esquire Johnson, Duffie, Stewart & Weidner 301 Market Street P.O. Box 109 Lemoyne, P A 17043 DATED: October 5, 2005 Laura J. Hu e, Secr to Barbara Sump e-Sullivan, Esquire 549 Bridge Street New Cumberland, P A 17070 (717) 774-1445 C) (- .-' = c:-) cf> o ,) __I \ -' -,) ~ 9..,-, rnb, :0lci -j,tS ~-, :': ~ :).~.oi; ') ':...-'1 --1-:->- _J :.<:;, r:':' ('0 . " : v. DEe 3 0 ZOpS IN THE COURT OF COMMON PLEAS 11>~ CUMBERLAND COUNTY, PA NO.05-6341 j BAMBIE R. SHENCI<., and minor Child, Kandice May Lower SHANE M. LOWER CIVIL ACTION-LAW PROTECTION FROM ABUSE SHANE M. LOWER IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. NO. 04-1466 BAMBIE SHENCI<::. CIVIL ACTION-LAW IN CUSTODY ORDER OF COURT AND NOW, this ."?O day of December, 2005, upon consideration of the attached Motion for Contempt Petition to be Heard by Custody Conciliator Pursuant to Cumberland County Local Rule 1915.12-1, it is ORDERED and DECREED that the Motion is GR.ANTED. The Petition for Contempt shall be heard by custody conciliator, Melissa Peel Greevy, Esquire, on January 6, 2006, at 9:30 AM at 1901 State Street, Camp Hill, Pennsylvania 17011. Kara W. Haggerty, Esquire . _o...o. A.' 3' I ~ /.rv~ /;J.o. -6:, /) Shane Lower, South Houck Road & Count Street, Apt. 4, Harrisburg, p" 17109r OR 218 Locust Street, Halifax, PA 17032