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Home My WebLink About06-6980 /r Michael A. Hynum, Esquire Supreme Court ID #85692 Hynum Law 315 Bridge St., Lower Level New Cumberland, PA 17070 (717) 774-1357 RYAN J. ZIRKLE, V. IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 69P6 DANICA A. ZIRKLE, Defendant CIVIL ACTION -LAW IN DIVORCE 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 ant 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 Domestic Relations 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 1-800-990-9108 W? .. Michael A. Hynum, Esquire Supreme Court ID #85692 Hynum Law 315 Bridge St., Lower Level New Cumberland, PA 17070 (717) 7741357 RYAN J. ZIRKLE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA ?-ham V. NO. L . l DAN ICA A. ZIRKLE, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Ryan J. Zirkle, an adult individual residing at 952 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania 17043. 2. Defendant is Danica A. Zirkle, an adult individual residing at 4210 Elmerton Avenue, Lower Paxton Township, Dauphin County, Pennsylvania 17109. 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 August 9, 2003, in Fairview Township, Cumberland County, Pennsylvania. 5. There is one minor child born of this marriage; namely, Avelina R. Zirkle, born 7/20/04- 6. The parties separated on September 3, 2006. 7. There are no previous actions for divorce or annulment filed by either party. g. Neither Plaintiff nor Defendant is in the military or naval 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. 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 Plaintiffs 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 §3301 of the Pennsylvania Divorce Code. WHEREFORE, Plaintiff, RYAN J. ZIRKLE, prays this Honorable Court to enter judgment: A. Awarding Plaintiff a decree in divorce; and B. Awarding other relief as the Court deems just and reasonable. Date: Michael A. Hynu uire Supreme Court ID # 5 92 Hynum Law 315 Bridge St., Lower Level New Cumberland, PA 17070 Attorney for Plaintiff Michael A. Hynum, Esquire Supreme Court ID #85692 Hynum Law 315 Bridge St., Lower Level New Cumberland, PA 17070 (717) 774-1357 RYAN J. ZIRKLE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA NO. V. DANICA A. ZIRKLE, CIVIL ACTION - LAW Defendant IN DIVORCE VERIFICATION I, RYAN J. ZIRKLE, 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. Date: 14 0 0 G er \ g l a 1 ?J J?l n C ? G, I Ti [? C7 O--b t_ to ? Michael A. Hynum, Esquire Supreme Court ID #85692 Hynum Law 315 Bridge St., Lower Level New Cumberland, PA 17070 (717) 774-1357 RYAN J. ZIRKLE, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-6980 Civil Term DANICA A. ZIRKLE, CIVIL ACTION - LAW Defendant ; IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I, DANICA A. ZIRKLE, do hereby acknowledge service of a true and correct copy of the Complaint in Divorce in the above-captioned matter, pursuant to Pennsylvania Rule of Civil Procedure No. 402(b). Date: ` -T; i.? Ryan J. Zirkle, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Danica A. Zirkle, Defendant : NO. 06-6980 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on December 5, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 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. §4904, relating to unsworn falsification to authorities. Date ?' r.,, __ ``-? _ .? a,, C?? . ?? ? -r _._. _ i i???'?_ f"°?? C,?..; ?r _.y '... ' ?? Yt. C'` :;;C . ? (,. Ryan J. Zirkle, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Danica A. Zirkle, Defendant : NO. 06-6980 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(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. §4904 relating to unworn falsification to authorities. 'Ul/l n - 9 Date t `= r wa Ryan J. Zirkle, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Danica A. Zirkle, : Defendant : NO. 06-6980 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on December 5, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 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. §4904, relating to unsworn falsification to authorities. Date ?.?, ?? ?? ? --, C? ?:? ms's C _ ?,? ? G? J -`f ?. ..?. ??.._ ? ? , tMa .?-, ?, Ryan J. Zirkle, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Danica A. Zirkle, Defendant : NO. 06-6980 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(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. §4904 relating to unworn falsification to authorities. o?C?d ? Date t yl -e, JO ? ? ?' ? .?, ?- . ,? c? ..., ?? ^; > r?, -? ?_. Ryan J. Zirkle, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. Danica A. Zirkle, Defendant CIVIL ACTION- LAW IN DIVORCE No. 06-6980 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please 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) of the Divorce Code. 2. Date and manner of service of the complaint: Defendant served by U.S. mail on or about January 12, 2007. 3. Date of execution of the Affidavit of Consent required by §3301 (c) of the Divorce Code: by Plaintiff - June 10, 2008; by Defendant - June 20, 2008. 4. Related claims pending: None. 5. Date Plaintiff s Waiver of Notice was filed with the Prothonotary: June 30, 2008. 6. Date Defendant's Waiver of Notice was filed with the Prothonotary: June 25, 2008. G 13ojos Date Angel B adley C Certified Legal Intern MegaVUesmeyer Supervising Attorney FAMILY LAW CLINIC 45 N. Pitt Street Carlisle, PA 17013 717-243-2968 Fax: 717-243-3639 Attorney for Plaintiff C3 rm_? .?? ?, C?: e=: s r_.:y ` ° ., i 1 4?? y i ,,.? ?' .. ...;' GJ r .1.7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. RYAN J. ZIRKLE, = Plaintiff VERSUS DANICA A. ZIRKLE Defendant No. DECREE IN DIVORCE 6980 2006 AND NOW, -1 ? 7 ityp IT IS ORDERED AND DECREED THAT RYAN J. ZIRKLE AND DANICA A. ZIRKLE ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, 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: ATTFST: ) ?. 1 J. ??A- r i 1.&114 PR ONOTARY 7 Y ? , 0'7- ? ;`7 1/< , y C2 ? L Ak f- /&O-f ? 412 5a -