HomeMy WebLinkAbout06-3488
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vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 0'- - JlfPj> CrCJLf....~~
: CIVIL ACTION - LAW
: IN DIVORCE
TERRY G. ZOOK, JR.
Plaintiff,
JANEL ZOOK,
Defendant.
NOT ICE 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 action within twenty (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, PA 17013
,.
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.O<.,-3'1if'
CIVIL ACTION - LAW
IN DIVORCE
TERRY G. ZOOK, JR.
Plaintiff,
JANEL ZOOK,
Defendant.
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN-NAMED DEFENDANT:
You have been named as the Defendant in a Complaint in a divorce proceeding
filed in the Court of Common Pleas of Cumberland County. This notice is to advise you
that in accordance with Section 3302(d) of the Divorce Code, you may request the court
require you and your spouse to attend marriage counseling prior to a divorce being
handed down by the court. A list of professional marriage counselors is available at the
Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania 17013. You
are advised that this list is kept as a convenience to you and you are not bound to
choose a counselor from this list. All necessary arrangements and the cost of
counseling sessions are to be borne by you and your spouse.
If you desire to pursue counseling, you must make your request for counseling
within twenty days ofthe date on which you receive this notice, Failure to do so will
constitute a waiver of your right to request counseling.
.
KOPE & ASSOCIATES, LLC
BY: SHANE B. KOPE, ESQ.
ATTORNEY 1.0. 92207
4660 Trindle Road, Suite 201
Camp Hill, PA 17011
(717) 761-7573
sbkope~comcast.net
Attorney for Plaintiff
vs,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. Ol. - 3<ff'l G;uJ IfJL~
: CIVIL ACTION - LAW
: IN DIVORCE
TERRY G. ZOOK, JR.
Plaintiff,
JANEL ZOOK,
Defendant.
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, TERRY G. ZOOK, JR. by and
through his attorney, SHANE B. KOPE, ESQ., and makes the following Complaint in
Divorce:
1. The Plaintiff is TERRY G, ZOOK, JR. an adult individual who currently
resides at 34 South East Street, Carlisle, Cumberland County, Pennsylvania, 17013.
2. The Defendant is JANEL ZOOK, an adult individual who currently resides
at 574 West Louther Street, Carlisle, Cumberland County, Pennsylvania, 17013.
3. Both the Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six (6) months immediately previous to the
filing of this Complaint.
4. The Plaintiff and Defendant were married on June 16, 2003 in Carlisle,
Cumberland County, Pennsylvania,
,.
5. The Parties separated on the evening of May 18, 2006 when the Plaintiff
moved out of the home after it was revealed that the Defendant had been having an
adulterous affair.
6. Neither the Plaintiff nor Defendant is in the military service of the United
States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of
the Congress of 1940 and its amendments.
7. There has been no prior action for divorce or annulment instituted by
either of the parties in this or any other jurisdiction.
8, Plaintiff has been advised of the availability of marriage counseling and
the right to request that the Court require the parties to participate in counseling.
COUNT I
REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (e) OF THE
DIVORCE CODE
9. The prior paragraphs of this Complaint are incorporated herein by
reference as though set forth in full.
10, The marriage of the parties is irretrievably broken.
WHEREFORE, if both parties file affidavits consenting to a divorce after (90)
ninety days have elapsed from the date of service of this Complaint, Plaintiff respectfully
requests that the Court enter a Decree of Divorce pursuant to Section 3301 (c) of the
Divorce Code.
,-
COUNT II
REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (d) OF THE
DIVORCE CODE
11. The prior paragraphs of this Complaint are incorporated herein by
reference as though set forth in full.
12. The marriage of the parties is irretrievably broken.
13. The parties are living separate and apart and at the appropriate time
Plaintiff will submit an affidavit alleging that the Parties have lived separate and apart for
at least two (2) years as Specified in Section 3301 (d) of the Divorce Code.
WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree of
Divorce pursuant to Section 3301 (d) of the Divorce Code,
COUNT III
REQUEST FOR A FAULT DIVORCE UNDER SECTION 3301 (a) (6) OF THE
DIVORCE CODE
17. The prior paragraphs of this Complaint are incorporated herein by
reference as though set forth in full.
18. Defendant has committed adulterous affairs and has caused Plaintiff to
suffer such indignities so as to render Plaintiffs condition intolerable and life
burdensome.
19. This action is not collusive as defined by Section 3309 of the Divorce
Code.
WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree of
Divorce pursuant to Section 3301 (a) (6) of the Divorce Code.
,..
COUNT IV
REQUEST FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
UNDER SECTION 3502 (a) OF THE DIVORCE CODE
20. The prior paragraphs of this Complaint are incorporated herein by
reference as though set forth in full.
21. Plaintiff and Defendant have acquired marital property as defined by the
Divorce Code, which is subject to equitable distribution pursuant to Section 3502 (a) of
the Divorce Code.
22. Plaintiff and Defendant have been unable to agree to the equitable
distribution of said property, as of the date of filing of this Complaint.
23, Plaintiff requests that the Court equitably divide, distribute, or assign the
marital property between the parties.
WHEREFORE, Plaintiff respectfully requests that the Court enter an order of
equitable distribution of marital property pursuant to Section 3502 (a) of the Divorce
Code,
Respectfully Submitted,
Dated: 0 J Iz ~
KOPE
I, Terry G. Zook, Jr. the Plaintiff in this matter, have read the foregoing
Complaint. I verify that my averments in this Complaint are true and correct and based
upon my personal knowledge. I understand that any false statements herein are made
subject to the penalties of 18 Pa. C.S. 4904 relating to unsworn falsifications to
authorities.
Dated: 15" ~\.ll'lL DC.
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DAL.ESANDRO MIL.IMAN
& ASSOCIATES. LLC
E B. KOPE, ESQ,
NEY 1.0. 92207
rlndle Road, Suite 201
Cam Hili, PA 17011
(717) 81-7573
AtlDlMy for PI.intllr
G. ZOOK, JR.
Plaintiff,
: IN THE COURT OF COMMON PLEAS
; CUMBERLAND COUNTY, PENNSYlVANIA
.
,
; NO. 06-3488
.
: CML ACTION -LAW
: IN DIVORCE
ACCEPTANCEOFSER~E
, Janel Zook, Defendant in the above-captloned matter, hereby accepta &eIVk:e
JANE ZOOK,
Defendant
of the omplalnt in Divort:8 In the above captioned mlltler.
Date:
-
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7)1017
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KOPE & ASSOCIATES, LLC
BY: SHANE B. KOPE, ESQ.
ATTORNEY 1.0. 92207
4660 Trindle Road, Suite 201
Camp Hill, PA 17011
(717) 761-7573
sbkoDecmcomcastnet
Attorney for Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-3488
CIVIL ACTION - LAW
IN DIVORCE
TERRY G. ZOOK, JR.
Plaintiff,
JANEL ZOOK,
Defendant.
AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on June 19,
2006.
2. The Complaint was served by Acceptance of Service signed by the Defendant on July
14,2006 and filed with the court on July 20,2006,
3, The marriage of plaintiff and defendant is irretrievably broken and at least ninety (90)
days have elapsed from the date of filing and service of the complaint.
4. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the 'decree,
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
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KOPE & ASSOCIATES, LLC
BY: SHANE B. KOPE, ESQ.
ATTORNEY I.D. 92207
4660 Trindle Road, Suite 201
Camp Hill, PA 1701'1
(717) 761-7573
sbkoDe(lilcomcast.net
Attorney for Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-3488
TERRY G. ZOOK, JR.
Plaintiff,
JANEL ZOOK,
Defendant.
CIVIL ACTION - LAW
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 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
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KOPE & ASSOCIATES, LLC
BY: SHANE B. KOPE, ESQ.
A TIORNEY 1.0. 92207
4660 Trindle Road, Suite 201
Camp Hill, PA 17011
(717) 761-7573
sbkope@comcast.net
Attorney for Plaintiff
TERRY G. ZOOK, JR.
Plaintiff,
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-3488
JANEL ZOOK,
Defendant.
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on June 19,
2006.
2. The Complaint was served by Acceptance of Service signed by the Defendant on July
14,2006 and filed with the court on July 20,2006.
3. The marriage of plaintiff and defendant is irretrievably broken and at least ninety (90)
days have elapsed from the date of filing and service of the complaint.
4. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
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: 5r1' II 'Ltw,
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201- 91-%7
Social Security Number
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KOPE & ASSOCIA lES, LLC
BY: SHANE B. KOPE, ESQ.
ATTORNEY 1.0. 92207
4660 Trindle Road, Suite 201
Camp Hill, PA 17011
(717) 761-7573
sbkope@comcast.net
Attorney for Plaintiff
TERRY G. ZOOK, JR.
Plaintiff,
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-3488
JANEL ZOOK,
Defendant.
CIVIL ACTION - LAW
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 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: ~Jt I {~ ZD06
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Social Security Number
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IN THE COURT OF COMMON PLEAS
Terry G. Zook, Jr.
VS.
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Janel Zook
NO. 06-3488
CIVIL TERM
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:
x Irretrievable breakdown under ~3301 (c)
3301 (d)(1) of the Divorce Code.
(Strike out inapplicable section).
2. Date and manner of service ofthe complaint:Acceptance of ~prvirp[,Tll1y 1.1, 1006
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by ~3301 (c) of the Divorce Code:
by plaintiff 9/1 1 /2006 ; by defendant R /4 / ? () () 6
(b) (1) Date of execution of the affidavit required by ~3301 (d)
of the Divorce Code:
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
4. Related claims pending: Nonp
5. 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:
(b) Date of plaintiff's Waiver of Notice in ~3301 (c) Divorce was filed with
the Prothonotary: 9 /1 4 / ? () () h
Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with
the Prothonotary: 8/1 5/2006
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TERRY G. lOOK, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
JANEL lOOK,
Defendant
NO. 06-3488 CIVIL TERM
ORDER OF COURT
AND NOW, this 26th day of October, 2006, upon consideration of Plaintiffs
praecipe to transmit the record in the above-captioned matter, and it appearing that
Defendant's affidavit of consent was filed before the 90-day waiting period, a divorce
decree will not be entered at this time, without prejudice to the parties' rights to correct
the deficiency and file a new praecipe to transmit the record.
BY THE COURT,
.,shane B. Kope, Esq.
4660 Trindle Road
Suite 201
Camp Hill, PA 17011
Attorney for Plaintiff
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KOPE & ASSOCIA lES, LLC
BY: SHANE B. KOPE, ESQ.
ATTORNEY 1.0. 92207
4660 Trindle Road, Suite 201
Camp Hill, PA 17011
(717) 761-7573
sbkope@comcast.net
Attorney for Plaintiff
TERRY G. lOOK, JR.
Plaintiff,
VS.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
t\lO. 06-3488
JANEL lOOK,
Defendant.
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on June 19,
2006.
2. The Complaint was served by Acceptance of Service signed by the Defendant on July
14,2006 and filed with the court on July 20,2006.
3. The marriage of plaintiff and defendant is irretrievably broken and at least ninety (90)
days have elapsed from the date of filing and service of the complaint.
4. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
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: '2. N-<J 2.cDb
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KOPE & ASSOCIA lES, LLC
BY: SHANE B. KOPE, ESQ.
ATTORNEY 1.0. 92207
4660 Trindle Road, Suite 201
Camp Hill, PA 17011
(717) 761-7573
sbkope~comcast.net
Attorney for Plaintiff
TERRY G. lOOK, JR.
Plaintiff.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COU~TY, PENNSYL VA.N!A
VS.
NO. 06-3488
JANEL lOOK,
Defendant.
CIVIL ACTION - LAW
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 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
prvthonotary.
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: 2 ^1c.'J wC6
.
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Social Security Number
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KOPE & ASSOCIATES, LLC
BY: SHANE B. KOPE, ESQ.
ATTORNEY J.D. 92207
4660 Trindle Road, Suite 201
Camp Hill, PA 17011
(717) 761-7573
sbkope@comcast.net
Attorney for Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-3488
TERRY G. lOOK, JR.
Plaintiff,
JANEL lOOK,
Defendant.
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on June 19,
2006.
2. The Complaint was served by Acceptance of Service signed by the Defendant on July
14,2006 and filed with the court on July 20,2006.
3. The marriage of plaintiff and defendant is irretrievably broken and at least ninety (90)
days have elapsed from the date of filing and service of the complaint.
4. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
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: /J /~ f {} h
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Social Security Number
RECEIVED
NO~ 2 2 2006
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KOPE & ASSOCIATES, LLC
BY: SHANE B. KOPE, ESQ.
ATTORNEY I.D, 92207
4660 Trindle Road, Suite 201
Camp Hill, PA 17011
(717) 761-7573
sbkope~comcast.net
Attorney for Plaintiff
vs.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-3488
TERRY G. lOOK, JR.
Plaintiff,
JANEL lOOK,
Defendant.
CIVIL ACTION - LAW
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 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
~1YI, avk
Janel Zook 11 V h
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IN THE COURT OF COMMON PLEAS
TERRY G. ZOOR, JR.
VS.
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
JANEL ZOOR
NO. 06-3488
CIVIL TERM
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 ~3301 (c)
~t~){<<WR<<~!ldac
(Strike out inapplicable section),
2. Date and manner of service of the complaint: Acceptance of Service
signed July 14, 2006 and filed Julv 20, 2006
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by ~3301 (c) of the Divorce Code:
by plaintiff 11 /2 f 2 00 6 ; by defendant 11 /21 /200 6
(b) (1) Date of execution of. the affidavit required by ~3301 (d)
of the Divorce Code:
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
4. Related claims pending: None
5, 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:
(b) Date of plaintiff's Waiver of Notice in ~3301 (c) Divorce was filed with
the Prothonotary: 11 /1 5/2006
Date defendant's Waiver of Notice in ~3301 (c) Divorce was filed with
the Prothonotary: 11 /27 /200 fi
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IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
PENNA.
STATE OF
TERRY G. ZOOK, JR
No.
06-3488
VERSUS
JANEL ZOOK
DECREE IN
DIVORCE
AND NOW,
Dc!..l... l\
, 1.OCb, IT IS ORDERED AND
DECREED THAT
TERRY G. ZOOK, JR
, PLAI NTI FF,
JANEL ZOOK
, DEFEN DANT,
AND
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
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