The URL can be used to link to this page

Home My WebLink About95-01383 -~-~~-~:_~-~~---------_._---- PI~~Y1ftJf -------------------------.-------------------- In lhe Court 01 CGIIIIIIlln Plaa 01 CumberIaad Colmer, Pamsyl\'UIia. q ';) -I ~.3 ' T,erll'\ __________________________ Civil. .9._____ VI. ~(jldJlfb__~------------ ~~ ____._____________________________--L ______ Nil, __________ltl___~l~~~_________________ ----.-....- ---.-. . .. ---.. --------..-..---------.- ....._____.. ._________e'?_~_____ ________ __ ________________________ --------------------- .~~--6----' d'_ li It Pa>_M.M___~_____ _~______ .________________ ....a '_________.__.___________ .~---JL~-----_ --~---<:r. Si ~ 1!J.uR_ ..P.>gL-;~.~...l!!.-....... .~--~~~-~~~~-~~~1f'~1.--dl(!2-----------t114tJgL---{).!L------____ ,__~h~J.t_____p.t_____.~~~JJl~Lt/di!?:--___~~-----.-- -----------------------------.-..-----------------------------------.---------------------------. ---------------------- -- -------------------------- -------------.-----. -- ---------------- To Law t'U(.,e e. /)Ja { k.a/ --------------------------------------- ._:,J ~_~______ 5<<11, -.l Wm?~-!#-~ I UJe,.JtMt" Prolhol\O'tary A~ 19_____ .. f .... - -.- - ..- No. _________________ Term. 19______ ------------------------------------..--- VI. ---------------------------------------- PRAECIPE F"~ed ___________________________ 19______ -_________________________________. .~cty, ---------------------------------------- l,~('" c-' >:;;,"7.-.' ,..,'" J. ~I'l'-' :.r ~~I -. ' c,' , i~, ~~'~;:.J..' ;.~ r.("") Cl "1-1 ~;'(~;~ -:;f; - ::: - <J-, Q;) ,z::o '" ~ ~ ~ '" . f " . --.- JEFFREY R. ZEIGLER, : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY " ~ I I Plain tilT VI CIVIL ACTION - LAW NUMBER: 95 - 1383 CIVIL TERM CHARLOTTE ZEIGLER, IN DIVORCE I- " " Defendant ORDER OF COURT i " I, AND NOW this 7tJ. day of l)ultt.. , 1995, upon consideration of the within - , 3 Petition for Alimony Pendente Lite, Counsel Fees, Costs and Expenses. and on motion of Sally J, Winder, Esquire, attorney for Petitioner, a Rule is granted on Respondent, JEFFREY R. ZEIGLER, to show cause why, ifany he shall have, he should not pay the Petitioner alimony pendente lite, counsel fees, and expenses as set forth in this Petition, Rule returnable on the ~day of _0- ~ ' 1995, at lLJD.. O'clock, A, M, in Courtroom No.-:tC , Cumberland County Courthouse, 4th Floor, Carlisle, Pennsylvania, Service of the within Petition to be made on Respondent's Counsel, Lynn y, MacBride, Esquire, by regular mail. , ; " " , i' By the Court, ./ /,' ;i , / 'W , J, \: i! .\ , \ l \~\~") \ \~v: (\\ \" y\ ;tt f, ~ \J \J I / " \ 7 ., (II ,u , ~,. . (\ ) I II,)' I r 1'/' (~{A.. L '(II Il It ('1.1 {'.l. I {L l It I , j , l ('1''') fA. ..lA,111J (t tJw.J.,-_ rl ~l"" I ' \ -j '. .',,'; \: "!, · ''). . : \'f~' :i _'.1". 55, It! SS Z L 7nr - d WHEREFORE, Petitioner respectfully requests this Honorable Court to grant a Rule upon Respondent to show cause why an Order should not be issued granting the following release: " ;1 a, That Respondent be Ordered to make reasonable payments to maintain Petitioner at the standard of living enjoyed by the parties of the marriage and such further sums as the Court deems reasonable and necessary as alimony pendente lite; that the Respondent be Ordered to pay a reasonable sum for interim counsel fees and at the conclusion of this matter, final counsel fees; that Respondent be required to maintain the presently existing health insurance for Petitioner until the conclusion of this matter, and provide all necessary forms and information for filing of claims and reimbursement of all reimbursable items under the medical benefits program available through his employer. !: b, That Respondent be Ordered to pay a reasonable sum for real estate broker's fees and retirement analysis through an actuary or accountant for determining the value of retirement benefits and such other expert fees as may be designated by Petitioner; and c, Such further relief as may be deemed just and proper, Respectfully Submitted, t1[Q;! .,) ",J-L, SALLY WINDER Counselor Petitioner, CHARLOTIE ZEIGLER :; VEWFICATION I veritY that the statements made in this Petition are true and correct to the best of my personal knowledge and belief. 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: (, I cY'lq s- r~ ~Q~'8(1;/V CHARLOTIE ZEl R i i I i I I ; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeffrey R. Zeigler, ) civil Action - Law Plaintiff, ) (/<.4<-LJ IM'-- ) as /3S3 vs. ) No. ! ) Charlotte Zeigler, ) Defendant, ) In Divorce a v.m. NOTICE TO DEPEND 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 or visitation of your children. When the ground for 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, Cumberland County Court House, Carlisle, Pennsylvania. 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 JJOSE 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. COURT ADMINISTRATOR CUMBERLAND CO COURTHOUSE 4th FLOOR 1 COURTHOUSE SQUARE CARLISLE PA 17013 3387 (717) 240 6200 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Franklin County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Jeffrey R. Zeigler, ) Civil Action - Law Plaintiff, ) ) vs. ) No. ) Charlotte Zeigler, ) Defendant, ) In Divorce a v.m. COMPLAINT UNDER SECTION 3301(C) or THE DIVORCB CODB 1. Plaintiff is Jeffrey R. Zeigler, who currently resides at 35 Fish Hatchery Road, Shippensburg, Cumberland County, Pennsylvania 17257 since July 19, 1986. 2. Defendant is Charlotte Zeigler, who currently resides at 35 Fish Hatchery Road, Shippensburg, Cumberland County, Pennsylvania 17257 since July 19, 1986. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 14, 1972 at Shippensburg, Cumberland County, Pennsylvania. 5.: There have been no prior actions of divorce or for annul~~nt between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised that counseling is available and that Plai~tiff may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a decree of divorce. I verify that the statements made in this Complaint 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. 0;:~f~ ~J. ;..,~ -~~~ .,- Je,d~y it. Zeigler, Plaintiff WALKER, VAN HORN & ASSOCIATES, P.C. Dated: 3- /5-9'5' By: C2\l-e~ C'). -J.:) -::. ~ I '" ~\ I C, N ~ ;rs "- "" c...\J & ~, c:: 0, (../\ \ ~\' \ l '-, ('01 n '.""> .~I ~ .~ cr, ~n:~::-: ~=l~j ~ ..- t.,.. -. .'1 ':':l2~~; ... ~ ~'PI op. _..{ ",.. :.:.:; i!'= :0 UJ \..N c...> tii ...... ::II: - ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA civil Action - Law Jeffrey R. Zeigler, ) Plaintiff, ) ) vs. ) ) Charlotte Zeigler, ) Defendant, ) No. 95-1383 civil ........~' (1 .', In Divord$-~' ..~m. Term ,...-- AFFIDAVIT OF SERVICE ,<: ", :', ~ l '. /' (" ; ~>>( , !n-;:J -<,;;) i.1 COMMONWEALTH OF PENNSYLVANIA ) ) SS: ) '\/ .. COUNTY OF FRANKLIN .!' Lynn Y. MacBride, Esquire, being duly sworn according to law, deposes and says that she is the attorney for the Plaintiff, Jeffrey R. Zeigler, in the above-captioned matter; that she did serve a true and attested copy of the Complaint in Divorce Under Section 3301(c) of the Divorce Code by mailing the same to Charlotte Zeigler, Defendant, by certified mail, restricted delivery, article number Z 124 169 868 on March 17, 1995, to her mailing address of 35 Fish Hatchery Road, Shippensburg, Pennsylvania 17257; that said certified mail article was delivered to Defendant, Charlotte Zeigler, on March 18, 1995, all as appears from the receipt for certified mail and the return receipt attached hereto; and further the Defendant saith not. WALKER, VAN HORN & ASSOCIATES, P.C. By: L Attorney- re Sworn and subscribed to before me this ,~~tA day of March, 1995. "X 1 '-I: /;} "'"2 :J. "-)'1.. t "J . F}~ . ?, ,.~-r Notary Public / tlOTARlAL SEAL B~NITA R. l,k:J~W /Jotary PublIC ...t'I(1"r1~tSbv9 r':lr,k!,n COllnry --~y Com_"2.'.!ton f:tr.HI'i ('lei 2. 1998 / " ' / / / y' , .:;.) .. ',) ~'.'~n ,. " ,JEFFREY R, ZEIGLER, Plainti ff IN THE COIIRT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. CHARLOTTE ZEIGLER Defendant 95-1383 CIVIL TERM .o.RD.EfLJlE.....c,OU.RI AND NOW. this 8th day of August. 1995, this matter having been called on a hearing on a petition of defendant for alimony pendente lite. counsel fees, and costs and expenses, and the parties having reached an agreement to resolve the issues presently before the Court, IT IS ORDERED: 1, Husband will pay when due the expenses regarding the upkeep of the marital residence, to include mortgage, utilities, taxes, and insurance, 2, Husband will pay health insurance coverage for wife, and will pay for any unreimbursed portion of her prescription costs, 3, Husband will pay routine unreimbursed medical bills of wife to include paying completely the approximate outstanding amount of $6,500,00, 4, Husband will pay for wife's car insurance and her Gulf credit card for gasoline expenses, 5, first of each Husband will pay wife $87,OO;per month month retroactive to AugUS~l. 1995, courl. cash on the Lynne MacBride, Esquire For Plainti ff Sally J, Winder, Esquire For Defendant Cc-lf"-- ~c,&'.. 8tj III q,,' / ,g, {J, :prs