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Home My WebLink About07-1027r HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF ALEXANDER U. KOYFMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 2007 - 16,27 CIVIL TERM IRINA O. RAZGONOVA, Defendant : IN DIVORCE NOTICE 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 in 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 Courthouse, Carlisle, Pennsylvania 17013. 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, Pennsylvania 17013 717-249-3166 M ALEXANDER U. KOYFMAN, Plaintiff V. IRINA O. RAZOONOVA, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2007 - -1617 CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is ALEXANDER U. KOYFMAN, an adult individual residing at 4 East South Street, Apartment 2, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is IRINA RAZGONOVA, an adult individual with a mailing address of 10528 Democracy Lane, Potomac, Maryland 20854. 3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on August 6, 2005 in Las Vegas, Nevada. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that she has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. February 22, 2007 ALEXANDER U. KOYFMAN, Plaintiff HAROLD S. IRWIN, III Attorney for Plaintiff 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 Ir ALEXANDER U. KOYFMAN, Plaintiff V. IRINA O. RAZOONOVA, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2007 - CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. 1 understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. February 22, 2007 LEXANDER U. KOYFMAN, Plaintiff ?.J n O? c " t c n C? ? O v ` rrl ' -?? } N rn T .F rn co v ... HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF ALEXANDER U. KOYFMAN, Plaintiff V. IRINA O. RAZGONOVA, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2007 - 1027 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(1) NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on March 21, 2007, addressed to the defendant at 10528 Democracy Lane, Potomac, Maryland 20854, Certified Mail No. 7006 2760 0002 7405 8914. 3. Defendant's Acceptance of Service is attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. A March 26, 2007 Harold S. Irwin, III Attorney for plaintiff 64 South Pitt Street Carlisle, PA 17013 717-243-6090 Supreme Court ID No. 29920 i AF ALEXANDER U. KOYFMAN, Plaintiff V. IRINA O. RAZOONOVA, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 - CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I, IRINA O. RAZGONOVA, defendant in this divorce action, hereby certify that I o4ow received a certified copy of the complaint in divorce on or about m? 2007. I verify that the statements made in this acceptance of service 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. 2007 0. ?-- IRINA RAZGONO Defendant q C O O o i FT7 ? ` 'V ? rf ?? ALEXANDER U. KOYFMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 2007 - 1027 CIVIL TERM IRINA O. RAZOONOVA, Defendant : IN DIVORCE AFFDAVIT OF CONSENT 1 • A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter February 23, 2007. Service of the complaint was made upon defendant on or about March 21, 2007(see affidavit of service previously filed). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. 1 consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. September a, 2009 ALEXANDER U. KOYFMAN 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. 1 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. 1 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. September, 2009 ALEXANDER U. KOYFMAN 2063 SEP 22 rIM _ _.. ALEXANDER U. KOYFMAN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 2007 -1027 CIVIL TERM IRINA O. RAZOONOVA, Defendant : IN DIVORCE AFFDAVIT OF CONSENT A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter February 23, 2007. Service of the complaint was made upon defendant on or about March 21, 2007(see affidavit of service previously filed). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended complaint. 3. 1 consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. ?t,.%,Q,. O,?- Septembe?, 2009 IRINA 0. RAZQONO WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (C) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. 1 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. 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. September , 2009 0' P ,W?vq IRINA O. RAZQONOV RLED-OF ICE OF THE PPOTPOINOTARY 20040CT -7 PM 4: 00 PcNNSYEVrINila ALEXANDER U. KOYFMAN, Plaintiff V. IRINA O. RAZOONOVA, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2007 - 1027 CIVIL TERM : 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: On or about March 21, 2007, defendant was served with a copy of the divorce complaint (see Acceptance of Service filed March 26, 2007). 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: September 10, 2009 By the defendant: September 22, 2009 (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: N/A. 4. Related claims pending: None 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: N/A. (b) Date plaintiffs Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: October 8, 2009 Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: October 8, 2009 6. There has been no prior action for divorce or annulment between the parties other than this action which commenced on February 23, 2007. October 8, 2009 HAROLD S. IRWN, III Attorney for Plaintiff FlLCC_; {',r OF 71grE -`:'OVARY 2009 OCT --9 PM 2: 50 Gulr <, -: , - 1 ;;;ivy Pci` NS`!LVAi VA r?S ?n ALEXANDER U. KOYFMAN V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA IRINA R. RAZGONOVA NO. 2007 - 1027 CIVIL TERM DIVORCE DECREE AND NOW, 0 ck , 166 , it is ordered and decreed that ALEXANDER U. KOYFMAN plaintiff, and IRINA R. RAZGONOVA bonds of matrimony. defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE By the Court, ?* -?? Attest: J. tothonotary R V