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Home My WebLink About01-5662HAREEM ANSAR, Plaintiff VS. KALEEM SHEIKH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. o/--~'c~¢'2- ~ 7~-~ CIVIL ACTION - LAW 1N 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 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 the 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, 1 Court House Square, Carlisle, Pennsylvania, 17013-3387. 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 LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 HAREEM ANSAR, Plaintiff VS. KALEEM SHEIKH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. o t- CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER §3301 OF THE DIVORCE CODE 1. Plaintiff is, Hareem Ansar, who currently resides at 200 West Main Street, Shiremanstown, Cumberland County, Pennsylvania. 2. Defendant is, Kaleem Sheikh, who currently resides at 230 Brookville Road, Muttontown, Nassau County, New York. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The Parties were married on September 2, 2000. 5. 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. 6. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 7. The Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff avers that there are no children of the parties under the age of eighteen. 9. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 10. The marriage of the parties is irretrievably broken. 11. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiffintends to file an affidavit consenting to a divome. Plaintiff believes that Defendant may also file such an affidavit. WHEREFORE, if both Parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of the service of this Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce pursuant to Section 3301 (c) of the Divorce Code. Date: EDWAt~r'J~. ~INTI~UB,'~I~ 2650 North Third Street Harrisburg, PA 17110 (717) 238-2200 ID #17441 ATTORNEY FOR PLAINTIFF VERIFICATION 1, Hareem Ansar, hereby swear and affirm that the facts contained in the foregoing Complaint for Divorce are tree and correct and are made subject to the penalties of 18 Pa. C.S. Sec. 4904 relating to unswom falsification to authorities. Date:_ O~/Ic~/6)[ Hareem Ansar HAREEM ANSAR, Plaintiff VS. KALEEM SHEIKH, Defendant * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, * PENNSYLVANIA . * NO. 01-5662 . * CIVIL ACTION - LAW * IN DIVORCE CERTIFICATE OF SERVICE I, Misty D. Lehman, Legal Assistant to Edward J. Weintraub, Esquire, hereby certify that on October 1, 2001, I served a tree and correct copy of the Complaint for Divorce upon Kaleem Sheikh, Defendant, by depositing same, postage pre-paid, Certified Mail, Return Receipt Requested in the United States Mail, Harrisburg, Pennsylvania, addressed as follows: Kaleem Sheikh 230 Brookville Road Muttontown, NY 11545 Mistt~ D. Ldhnhi'an ~' -- - - HAREEM ANSAR, Plaintiff VS. KALEEM SHEIKH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5662 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF DAUPHIN : AND NOW, this 5th day of October, 2001 personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Wendy L. Shive, who being duly sworn according to law, deposes and says that on October 1, 2001, she mailed a certified copy of a Complaint in Divorce, by certified mail, restricted delivery, return receipt requested, to Kaleem Afzal Sheikh, 230 Brookville Road, Muttontown, NY 11545, and the same was received by him on October 3,2001 as indicated by the return receipt card which is attached hereto. dy(~hiv~ Sworn to and subscribed before me on this ~-F~ day of~, 2001. Public ~ I Notn~l .Senl "1 MI~/.D: Leh _n~n, N.o.~ Pu~Ik~ I-lintsourg, uaupnm ~oumy My Commission Exptres Aug. 2, 2004 HAREEM ANSAR, Plaintiff V$, KALEEM SHEIKH, Defendant IN THE COURT OF CO.~IMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION ~ LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divome under Section 3301(c) of the Divorce Code was filed on .... ~1' 7_. ~'~', 0 ) 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree in 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. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsificatio~ Date:'Z- ~--~ ~ u~aze~tr~ne~Kl~, Defendant HAREEM ANSAR, Plaintiff * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, * PENNSYLVANIA vs. * NO. KALEEM SHEIKH, 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 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 divomed 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 unswom falsification to authorities, HAREEM ANSAR, Plaintiff VS. KALEEM SHEIKH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5662 Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on September 28, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree in 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. Hareem Ansar, Plaintiff HAREEM ANSAR, Plaintiff YS, KALEEM SHEIKH, Defendant * IN THE COURT OF COMMON PLEAS * CUMBERLAND COUNTY, * PENNSYLVANIA * * NO. 01-5662 Civil Term . * 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 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. Section 4904 relating to unsworn falsification to authorities. Date: ~o~ -/3 '00_ Hareem Ansar, Plaintiff HAREEM ANSAR, Plaintiff VS. KALEEM SHEIKH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-66-2-~ Civil Term CIVIL ACTION - LAW IN DIVORCE 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: October 3, 2001 via Certified Mail, Restricted Delivery; Affidavit of Service attached. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by plaintiff: February 13, 2002; by defendant: February 8, 2002. 4. Date Waiver of Notice in Section 3301(c) Prothonotary: by plaintiff: Simultaneously with this Praecipe; by defendant: February IL~ ,2002. Divorce was filed with the 5. Related claims pending: None. WHEREFORE, the Court is requested to enter a Final Decree in Divorce in compliance with Section 3301 (c) of the Divorce Code and Pa. R.C.P. 1920.42(a)(1 ). Attorney for Plaintiff HAREEM ANSAR, Plaintiff VS. KALEEM SHEIKH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5662 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF DAUPHIN : AND NOW, this 5th day of October, 2001 personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, Wendy L. Shive, who being duly sworn according to law, deposes and says that on October 1,2001, she mailed a certified copy of a Complaint in Divome, by certified mail, restricted delivery, return receipt requested, to Kaleem Afzal Sheikh, 230 Brookville Road, Muttontown, NY 11545, and the same was received by him on October 3, 2001 as indicated by the return receipt card which is attached hereto. ~V~endy~,~hi¢~ ~-~- Sworn to and subscribed before me on this ~tt't day of C~'7~ F' , 2001. Notar9 Public Notarial Seal Misty D. Lehman, Notary Public Hl~lsburg, Dauphin County My Commission Expires Aug. 2, 2004 ~ .SENDER: .- ' mC, ompie~e items 1 and/or 2 for additional sewices. · Complete items 3, 4a, and · Attach this form to the front of the rnellpiece, or on the back if space does not permit. · Write 'Return Receipt Requested' off lhe maJlpiece below the article number. "The Return Receipt will show to whom the aticle was delivered and the date delivered. 3,...Arlfc~e Addressed to: 5. Received By: (Print~ I~am~) 6. Signature: (A~dr,.~ea orAl,nO PS Form 3811, December 1994 I also wish to receive the following services (for an extra fee): 1. [] Addressee's Address ~ 2. ~..~estricted Delivery ~ Consult poslmaster for fee. -_ 4a. Article Number 4b. Sewice Ty~ o ~ Expr*. Mail ~ ~j~) a Insur~ ~Re~mR~t~ a COD [ / 8. Addres~e's Address (Only/frequest~ ~ and ~e is ~ld) ~ Domestic Return Receipt INTHE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY STATE Of ~ PENNA. HAREEM ANSAR PLAINTIFF VERSUS DEFENDANT NO. Ol-5662 Civil Term AND NOW, DECREED THAT DECREE IN DIVORCE HAREEM ANSAR v v~l~, IT IS ORDERED , PLAINTIFf, AND KALEEM SHEIKH , DEFENDANT, 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. BY TH~ ATTEST: PROTHONOTARY HAREEM ANSAR, Plaintiff VS. KALEEM SHEIKH, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-5662 CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Wendy L. Shive, Legal Assistant to Edward J. Weintraub, Esquire, hereby certify that on March 5, 2002, I served a Ixue and correct copy of the Decree in Divorce upon Rand P. Schwartz, Esquire, counsel for Defendant, by depositing same, postage pre-paid, in the United States Mail, Hagisburg, Pennsylvania, addressed as follows: Rand P. Schwartz, Esquire 1000 Park Boulevard, Suite 205 Massapequa Park, NY 11762-2740 Date: ndy~i(e ' t~