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HomeMy WebLinkAbout07-0747IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA KATRINA L. SIDDIQUI, PLAINTIFF, V. Civil Action---Divorce Docket No. 4nq -I k7 CL 0 ? L<--? KHAYYAM Z. SIDDIQUI, DEFENDANT, NOTICE TO DEFEND AND CLAIM OF 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. 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 17101 (717) 249-3166 A IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA KATRINA L. SIDDIQUI, PLAINTIFF, Civil Action---Divorce Docket No. V. KHAYYAM Z. SIDDIQUI, DEFENDANT, AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas siguientes, debe tomare accion con prontitud. Se le avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio o anulaminento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otra queja o compensacion reclamados por el demandante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la officina del Prothonotary, en la Cumberland County Bar Association, 2 Liberty Avenue, Carlisle, Pennsylvania 17101. SI USTED NO RECLAMA PENSION ALIMENTICIA. PROPIEDAD MARITAL. HONORARIOS DEABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULIAMIENTO SEA EMITIDO. USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS.USTED DEBELLEVAR ESTE PAPELA UN ABOGADO DE INMEDIATO SI NO TIENEPUEDEPAGAR UN ABOGADO. VAYA O LLAME A LOFFICINAINDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASIS TENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE Carlisle, Pennsylvania 17101 (717) 249-3166 AVAILABILITY OF COUNSELING THE DIVORCE CODE OF PENNSYLVANIA REQUIRES THAT YOU BE NOTIFIED OF THE AVAILABILITY OF COUNSELING WHERE A DIVORCE IS SOUGHT UNDER ANY OF THE FOLLOWING GROUNDS: 23 Pa.C.S. & 3301(a)(6)-------Indignities 23 Pa.C.S. & 3301(c)----------Irretrievable Breakdown; Mutual Consent 23 Pa.C.S. & 3301(d)----------Irretrievable Breakdown; Two year separation where the court determines that there is a reasonable prospect of reconciliation. A list of marriage counselors is available in the Office of the Prothonotary Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. GREGORY S. HAZLETT, ESQUIRE ATTORNEY & COUNSELOR AT LAW Grego . Hazle* Epj ire L Attey for Plaintiff Z est Main Street Mechanicsburg, Pennsylvania 17055 (717) 790-5500 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA KATRINA L. SIDDIQUI, PLAINTIFF, Civil Action---Divorce Docket No. 01 7Y 7 dtzJ V. KHAYYAM Z. SIDDIQUI, DEFENDANT, COMPLAINT UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE PARTIES L Plaintiff is Katrina L. Siddiqui, an adult individual, sui juris an who currently resides 94 Arnold Road, Enola, 17025, in the County of Cumberland, Commonwealth of Pennsylvania. 2. Defendant, is Khayyam Z. Siddiqui, an adult individual, sui juris, who currently resides at 3512 Ada Drive, 17050 Mechancisburg, in the County of Cumberland, Commonwealth of Pennsylvania. JURISDICTION & VENUE 3. Plaintiff has been a resident of the Commonwealth of Pennsylvania for a period of more than 6 months. 4. The parties were married on the 8t" day of May 2005, in the County of Dauphin, Commonwealth of Pennsylvania. 5. Neither the Plaintiff nor the 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 have been no prior actions for divorce instituted by the plaintiff or defendant in this Commonwealth. GROUNDS FOR DIVORCE REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (d) OF THE DIVORCE CODE. 7. For the purposes of section 3301 (d) of the Divorce Code, the parties have been living separate since November 8`h, 2006 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that the plaintiff may have the right to request that the court require the parties to participate in counseling. WHERFORE, plaintiff requests that the Honorable Court grant a decree of divorce pursuant to, and in conformity with 3301 (d) of the Divorce Code. 11. The parties do not have any biological child born within or outside of the marriage. 12. The parties have not heretofore entered into any written agreement as to support, alimony, or property division. GROUNDS FOR DIVORCE REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 (C) OF THE DIVORCE CODE. 13. The prior paragraphs are incorporated herein by reference. WHEREFORE, provided the parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of the filing and service of this Complaint, plaintiff respectfully requests the Court to enter a decree of divorce pursuant to section 3301(c) of the Divorce Code. GREGORY S. HAZLETT, ESQUIRE ATTORNEY & COUNSELOR AT LAW urego HazletY,uire ``- Atto ey for Plaintiff 7 est Main Street 'F Mechanicsburg, Pennsylvania 17055 (717) 790-5500 VERIFICATION I verify that upon personal knowledge or information and belief 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. & 4904, relating to unsworn falsification to authorities. j Katrina L. Siddiqui, Plaintiff Date: 5 ?? D OV N Q V a- SEPARATION AND PROPERTY SETTLEMENT AGREEMENT OF KATRINA L. SIDDIQUI AND KHAYYAM Z- THIS AGREEMENT, made this __j2__, day of S3 1C rA /0 2007 by and betwe Katrina L. Siddiqui, hereinafter referred to as "Wife", and KHAYYAM Z. SIDDIQUI, hereinafter referred to as " Husband". WITNESSETH: WHEREAS, Husband and Wife were lawfully married on May e, 2005 and WHEREAS, certain differences have arisen between the parties as a result of which they have separated and now live separate and apart from one another, and are desirous, therefore, of entering into an agreement which will provide for support, distribute their marital property, and will provide for their mutual responsibilities and rights growing out of the marriage relationship; and WHEREAS, the parties hereto, after being properly advised, have come to the following agreement. NOW, THEREFORE, in consideration of the above recitals and the following covenants and promises mutually made and mutually to be kept, the parties heretofore, intending to be legally bound and to legally bind their heirs successors and assigns thereby, covenant, promise and agree as follows: 1. SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other at such place or places as he or she may from time to time choose or deem fit. 2. INTERFERENCE: Each party shall be free from interference, authority and contact by the other as fully as if he or she was single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other nor attempt to endeavor to molest the other, nor compel the other to cohabit with the other, nor in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other in all respects as if he or she were single and unmarried 3. WIFE S DERTS• Wife represents and warrants to Husband that, she has not, and in the future she will not, contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save Husband harmless from any and all claims and demands made against him by reasons of debts or obligations incurred by her subsequent to the entry of the divorce decree. 4. HITSRAND'S DFRTS: Husband represents and warrants to Wife that, he has not, and in the future he will not, contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife harmless from any and all claims and demands made against her by reasons of debts or obligations incurred by him. 5. OUTSTANDING .10M DERTS• It is represented as between the parties that there are joint debts as between the parties that were incurred prior to the effective date of this agreement which is comprised of a Beneficial Finance loan and it is hereby understood, and agreed upon, that each party shall contribute agree to distribute the debt as hereinafter provided. 6. M[TTITAT, RELEASE: Subject to the provisions of this Agreement, each party waives his or her right to alimony and any further distribution of property inasmuch as the parties hereto agree that this Agreement provides for an equitable distribution of their marital property in accordance with the Divorce Code of 1980, as amended. Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights or demands whatsoever in law or equity, which either of the parties ever had or now has against the other, and except in any or all causes of action for breach of any provisions of this Agreement. Each party also waives his or her right to request marital counseling pursuant to Section 202 of the Divorce Code. 7. VOLITART F DISTRiR MON OF MARUAL PROPERTY: The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in Section 401 of the Pennsylvania Divorce Code, and taking into account the following considerations: the length of the marriage; the age, health , station, amount and sources of income, vocational skills, employability, estate, liabilities and needs of each of the parties; the contribution of each party to the education, training or increased earning power of the other party; the opportunity of each party for future acquisitions of capital assets and income; the sources of income of both parties' including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each party in the acquisition, preservation, depreciation or appreciation of the marital property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of living of the parties established during the marriage; and the economic circumstances of each party at the time the division of property is to become effective. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, funds or other property not constituting marital property. The division of property under this Agreement shall be in full satisfaction of all marital rights of the parties. 2 A. DISTRIMMON OF PERSONAL PROPERTY The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such tangible personal property presently in his or her possession. Except as otherwise provided by the terms of this Agreement, the parties hereto have divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital property. Neither party shall make any claim to any such items of marital property of either party, which are now in the possession and/or under the control of the other. Should it become necessary, the parties each agree to sign, upon request, any titles or documents necessary to give effect to this paragraph. Property shall be deemed to be in the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the signing of this Agreement and, in the case of intangible personal property, if any physical or written evidence of joint ownership, such as passbook, checkbook, policy or certificate of insurance or other similar writing is in the possession or control of the party. Husband and Wife shall each be deemed to be in the possession and control of his or her own individual pension or other employee benefit plans or retirement benefits of any nature with the exception of Social Security benefits to which either party may have vested or contingent right or interest at the time of the signing of this Agreement, and neither will make any claim against the other for any interest in such benefits. From and after the date of the signing of this Agreement, both parties shall have complete freedom of disposition as to his/her separate property and any property which is in their possession or control pursuant to this Agreement and may mortgage, sell, grant, convey, or otherwise encumber or dispose of such property, whether real or personal, whether such property was acquired before, during or after the marriage, and neither Husband nor Wife need join in, consent to, or acknowledge any deed, mortgage, or other instrument of the other pertaining to such disposition of property. $. REAL PROPERTY: There is no known real property owned by the parties jointly or otherwise that is the subject of distribution. 9. VFTUCLF Each party shall retain full ownership and possession of, both legal and equitable of the motor vehicles that are currently within their possession and shall waive any and all claims to each other's motor vehicle and maintain all expenses relative to their ownership and operation of said vehicles. 10. SUPPORT-, Both husband and wife hereby agree to waive all rights to seek spousal support, alimony, alimony Pendente Lite, Cost & Expenses, or any other support of any kind, from the other. 3 11. OUTSTANDING DEBT: Husband hereby agrees to pay the sum of five thousand four hundred dollars ($5,400.00) dollars in a lump sum payment directly to Beneficial Finance Company. Wife will attempt to refinance the balance left remaining to Beneficial Finance Company, subsequent to Husband's lump sum payment to the same, in an effort to remove husband's name from this account. In the event that Wife is unable to refinance the remaining balance of the loan she agrees to pay the sum of two hundred dollars $200.00 dollars per month to be paid to Beneficial Finance Company until the remaining outstanding balance is paid in full. 12. PENSION PLAN: Each party waives and forever releases the other of and from any and all claims which either may have against the other's pension, 401K plan, retirement plan or any other retirement plan, benefit or employee benefit or benefits or any other interest, whether or not same may have accumulated or appreciated during the parties' marriage. Additionally, the parties waive their interest in any and every interest bearing accounts whatsoever and wheresoever located and which may have accumulated prior to, during, and subsequent to the marriage which is otherwise not specifically mentioned herein. 13. COUNSEL FEES AND EXPENSES: Husband and wife shall not seek any compensation from the other spouse for Counsel Fees and Expenses. Husband and Wife Acknowledge and agree that the provisions of this Agreement providing for the equitable distribution of marital property of the parties are fair, adequate and satisfactory to them. Both parties agree to accept the provisions set forth in this Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands that either may now or hereafter have against the other for alimony pendente lite, counsel fees or expenses or any other provisions for their support and maintenance before, during and after the commencement of any proceedings for divorce or annulment between the parties. 14. WATVF,RS OF CLAIMS AGAINST ESTATES! Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or estate of the other as a result of the marital relationship, including without limitation, dower, curtesy, statutory allowance, widow's allowance, intestate share, right to take against the will of the other, and right to act as administrator or executor of the others estate. Each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 4 15. STTRSEQIJENT DIVORC'F.: Should a Divorce Complaint be initiated by either party against the other it is specifically understood and agreed to by the parties herein that the parties shall be bound by all the terms, conditions, and restrictions of this Agreement which shall be incorporated by reference into the Divorce Decree, shall not be merged into the Divorce Decree, and shall not be modified, but shall in all respects survive the same and be further binding and conclusive upon the parties. It is the intention of the parties that the Agreement shall survive any action for divorce which may be instituted and prosecuted by either party and no order, judgment or decree of divorce, temporary, final or permanent shall affect or modify the financial terms of this Agreement. This Agreement may be incorporated in but shall not merge into any such judgment or decree of final divorce, but shall be incorporated for the purposes of enforcement only. 16. BREACH AND ENFORCEMENE A. It is expressly understood and agreed by and between the parties hereto that this Agreement may be specifically enforced by either Husband or Wife in Equity, or in Law and the parties hereto agree that if an action to enforce this Agreement is brought in Equity by either party, the other party will make no objection on the alleged ground of lack of jurisdiction of said Court on the ground that there is an adequate remedy at law. The, parties do not intend or purport hereby to improperly confer jurisdiction on a Court in Equity by this Agreement, but they agree as provided herein for the forum of Equity in mutual recognition of the present state of the law, and in recognition of the general jurisdiction of Courts in Equity over agreements such as this one. B. Notwithstanding anything to the contrary herein, Husband and Wife may also proceed with an action at law for redress of his or her rights under the terms of this Agreement, and in such event it is specifically understood and agreed that for and in specific consideration of the other provisions and covenants of this Agreement, each shall waive any right to a jury trial so as to expedite the hearing and disposition of such case and so as to avoid delay. C. Each party further hereby agrees to pay and to save and hold harmless the other party from any and all attorney's fees and costs of litigation that either may sustain, or incur or become liable for, in any way whatsoever, or shall pay upon, or in consequence of any default or breach by the other of any of the terms or provisions of this agreement by reason of which either party shall be obliged to retain or engage counsel to initiate or maintain or defend proceedings against the other at law or equity or both in any way whatsoever; provided that the party seeks to recover such attorney's fees, and costs of litigation must first be successful in whole or in part, before there would be any liability for attorney's fees and costs of litigation. It is the specific agreement and intent of the parties that a breaching or wrongdoing party shall bear the burden and obligation of any and all costs and expenses and counsel fees incurred by himself or herself as well as the other party in endeavoring to protect or enforce his or her rights under this Agreement. 5 17. AMMONA .INSTRTTMF.NTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. 18. Vn JJNTARV F.XF,CTTTTON: The provisions of this Agreement and their legal effect have been completely reviewed by the parties, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any duress or undue influence. The parties acknowledge that they have been furnished with all information relating to the financial affairs of the other which has been requested by each of them. 19. ENTIRE. ACRFF.MF.NT: This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the division and distribution of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other relevant factors which have been taken into consideration by the parties. Both parties hereby accept the provisions of this Agreement with respect to the division of property in lieu of and in full and final settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for equitable distribution of their property by any court of competent jurisdiction pursuant to Section 401(d) of the Divorce Code or any other laws. Husband and Wife voluntarily and intelligently waive and relinquish any right to seek a court ordered determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing any provision of this Agreement. 20. DISCLOSURE: Husband and Wife each represent and warrant to the other that he or she has made a full and complete disclosure to the other party of all assets of any nature whatsoever in which such party has an interest, the sources and amount of the income of such party or every type whatsoever and of all other facts relating to the subject matter of this Agreement. 21. MODIFICATION AND WAIVER* A modification and waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 6 22. PRIOR AGRFFAWM- It is understood and agreed that any and all property settlement agreements which may or have been executed prior to the date and time of this Agreement are null and void and of no effect as well as any verbal agreements or representations occurring prior to the effective date of this instrument. 23. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 24. INDEPENDENT SEP A R ATE. COVENANTS! It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 25. APPIWARLE LAW: This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 26. VOID C .ATISF.S: If any terms, conditions, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force, effect and operation. 27. AGREEMENT BINDING ON HEIRS, This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 7 IN WITNESS WHEREOF, the parties hereto have set their hand and seals the day and year first above written. Itatrina L. Siddiqui Commonwealth of Pennsylvania County of On this, the I?- day of SCQYAff A.D.2007, before me a Notary Public appeared Katrina L. Siddiqui,, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Seal COMMONWEALTH OF PENNSYLVANIA r Notarial Seal Title of ficeK ty L. Magam, Notary Public tag PeFnsboro Twp., Cumberland County My CornmIssion Expires May 30, 2009 Member, Pennsylvania Association of Notaries ><ddiqui Commonweal of Pennsylvania County of On this, the [S ,day of OQZ% ?_A.D.2007, before me a Notary Public appeared Khayyam Z. Siddiqui, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. mbwmk? Seal I LOombl(O 014 Title of Officer COMMONWEALTH OF PENNSYLVANIA Notarial Seal Cathy L. Youngblood, Notary Public Lemoyne Boro, Cumberland County My Commission Expires June 22, 2010 R Member. Pennsylvania Association of Notaries -+J C„3 -1 ' l llr' 1 ?l ? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA KATRINA L. SIDDIQUI, PLAINTIFF, V. KHAYYAM Z. SIDDIQUI, DEFENDANT, Civil Action---Divorce Docket No. 2007-747 CERTIFICATE OF SERVICE I, Gregory S. Hazlett, Esquire, hereby certify that on the 16th day of February 2007 by way of Acceptance of Service, I made service of the foregoing Divorce Complaint and related documentation, upon the following interested parties listed hereunder by way of first class mail postage prepaid. KHAYYAM Z. SIDDIQUI 3512 ADA DRIVE MECHANICSBURG, PA. 17050 GREGORY S. ZLE T =-. z I W, squir ain Street Mechanicsburg, PA. 17055 717-790-5500 `x.7 a IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA KATRINA L. SIDDIQUI, PLAINTIFF, : Civil Action---Divorce Docket No. 2007-747 V. KHAYYAM Z. SIDDIQUI, DEFENDANT, CERTIFICATE OF SERVICE I, Gregory S. Hazlett, Esquire, hereby certify that on the 17th day of February 2007 by way of Acceptance of Service, I made service of the foregoing Divorce Complaint and related documentation, upon the following interested parties listed hereunder by way of first class mail postage prepaid. GREGORY S. HAZLETT C-j r ; r;a IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA KATRINA L. SIDDIQUI, PLAINTIFF, Civil Action---Divorce Docket No. 2007-747 V. KHAYYAM Z. SIDDIQUI, DEFENDANT, I, Khayyam Z. Siddiqui, accept service of the Complaint in Divorce, Notice to Defend and Notice of Availability of Counseling in the above-captioned matter. I acknowledge that I am the Defendant in said matter or that I am authorized to accept on behalf of the Defendant. V Date Kh . id , Defendant or Authorized Agent Mailing Address ?'1t """' .?• ?-`-" ` ? ? f`?j? r= ":"777-j `'? ;? ?; 4 w, :yam • •`? ' ? ! ?`l:? {" Pq '-yty?wi ?..`, ^ V .,?... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA KATRINA L. SIDDIQUI, Plaintiff, V. No. 2007-747 : Civil Action - Divorce KHAYYAM Z. SIDDIQUI, ; Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 7'`, 2007, and served upon defendant on February 16th, 2007, by way of an Acceptance of Service. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of service of the divorce Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. 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. Cons. Stat. S 4904 relating to unsworn falsification to authorities. Date: Z 1 ', ant ?> C' J Mn ?:7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA KATRINA L. SIDDIQUI, Plaintiff, V. : No. 2007-747 : Civil Action - Divorce KHAYYAM Z. SIDDIQUI, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF 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. 4. 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 unswurn alsi ication to authorities. Date: / f ' JCi . S' i ', Defendant C) Pv tiw _A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA KATRINA L. SIDDIQUI, Plaintiff, V. KHAYYAM Z. SIDDIQUI, Defendant : No. 2007-747 : Civil Action - Divorce WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF 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. 4. 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: Katrina L. Siddiqui, Pla' tiff n ` r-- s C--:3 ("D ( , i > -r ! - C-) i c n A:o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA KATRINA L. SIDDIQUI, Plaintiff, No. 2007-747 V. KHAYYAM Z. SIDDIQUI, Defendant : Civil Action - Divorce AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 7th, 2007, and served upon defendant on February 16th, 2007, by way of an Acceptance of Service. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of service of the divorce Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. 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. Cons. Stat. S 4904 relating to unsworn falsification to authorities. Date: 11 14drA / . atrina L. iddiqui, Plaint' C"7 ? c'7 - - . - f -r7 C-1 -t rrs } - C'n IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, COMMONWEALTH OF PENNSYLVANIA KATRINA L. SIDDIQUI, PLAINTIFF, Civil Action---Divorce Docket No. 2007-747 V. KHAYYAM Z. SIDDIQUI, ; DEFENDANT, PRAECIPE TO TRANSMIT THE RECORD To the Prothonotary: Please Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301(C) of the Divorce Code. 2. The complaint in Divorce was filed on the 7th, day of February 2007 and served by way of Acceptance of Service 16th, day of February 2007. 3. The plaintiff, signed her Affidavit of Consent and Waiver of Notice of Entry of a Divorce Decree on the 28th day of November 2007 which is attached hereto. 4. The defendant signed his Affidavit of Consent and Waiver of Notice on the 28th day of November 2007. 5. There are no related claims pending as between the parties hereto and listed herein to the extent that all marital issues have been settled by way of a marital separation agreement dated the 12th day of September 2007. 6. The defendant signed a Waiver of Notice of Intention to Request Entry of Divorce Decree on the 28th day of November 2007 a copy of which is attached hereto. .Date: 12/5/2007 GREGORY,%oWAZLETT Attor for"gl 7 st Main Street v echanicsburg, PA. 17055 Phone: 717-790-5500 l.y t"^ -? `r+: r r? '°'i .. r.)! ?;. .1.? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. KATRINA L. SIDDIQUI No. 2007-747 PLAINTIFF VERSUS KHAYYAM Z. SIDDIQUI DEFENDANT DECREE IN DIVORCE 1 2007 AND NOW, , IT 1S ORDERED AND DECREED THAT KATRINAI S1Dn1 U1, , PLAINTIFF, AND KHAYYAM Z SIDDIQUL 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; The Marital Separation Agreement executed on the 12th day of September, 2007 shall be Incorporated into the Divorce Decree and shall ATTEST: J. PROTHONOTARY • 40 ) t _ e.7! Jico- -el IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA f I !la- L ??? u.? - Plaintiff Vs File No. 9 06? -- --7 IN DIVORCE efendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree Divorce dated 12 hereby elects to resume the prior surname of i AA, and gives this written noti e a owing his / her intention pursuant to th?pro?visio 54 S. 704. Date: ,2 O R? u? Signature ignature of name rein sumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CAo6r k nJ ) On the 4 day of c , 200 9 before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. PENNSYLVANIA NW EALTH OF ff agar„ Notary Imo. ro Twc ountY My Commission a. )gy 09 Member, PennsylvaMa Association of Notaries ?*s r w A\uy VV p? fvV^, 1 ,J ea y a .