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HomeMy WebLinkAbout07-1134HAROLD s. IRIAIIN, III, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 24346050 ATTORNEY FOR PLAINTIFF ALMA MRNJIC - MUSIC, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 2007 - 1134 CIVIL TERM SEAD MUSIC, : 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 ALMA HRNJIC - MUSIC, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY1 PENNSYLVANIA ?• : CIVIL ACTION - LAW NO. 2007 - illy CIVIL TERM BEAD HUSIC Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 330"a OF THE DIVORCE CODE NOW, comes the plaintiff, by her attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is ALMA HRNJIC - HUSIC, an adult individual residing in Carlisle and having a mailing address in care of her attorney, Harold S. Irwin, III, Esquire, at 64 South Pitt Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is SEAD HUSIC, an adult individual residing at 537 North Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have been residents 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 18, 2000 in Teocak, Bosnia. 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. March 1, 2007 ALMA HR C - HUSIC, Plaintiff HAROLD S. IRWIN, II Attorney for Plaintiff Supreme Court ID No. 29920 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 ALMA HRNJIC - MUSIC, PlalntNf V. SEAD MUSIC, 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: 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. March 1, 2007 ALMA HR IC - HUSIC, Plaintiff C`h Pl.') d C. -rt _TJ a c-n HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF ALMA HRNJIC - HUSIC, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW : NO. 2007 - 1134 CIVIL TERM SEAD HUSIC, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(I) NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 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 5, 2007, by certified mail addressed to the defendant at 537 North Hanover Street, Carlisle, PA 17013, Certified Mail No. 7004 1350 0003 7147 1595. 3. A copy of the sender's and return receipts are 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. March 6, 2007 Harold S. Irwin, III Attorney for plaintiff 64 South Pitt Street Carlisle, PA 17013 717-243-6090 Supreme Court ID No. 29920 l hn - MAIL, - - Er- t,rh (Domestic For delivery information visit our website at w w.usps.com, w tti --r l OFFICIAL - USE r- Postage 3 $ ` Q t o %ertlfled Fee y C3 Return Reciept Fee Postmark Here (Endorsement Required) C3 Restricted Delivery Fee Ln (Endorsement Required) M Total Postage & Fees O Sent To M 4 fi 17? 'r' 36WAif Apt No.; - ----i --=" or PO Box No. ?J ' - ------------ --- h Clly, Stete,21 I PS For, nstructions -r 'AO ¦ 066"ilte Items 1, 2, and 3. Also complete Item 4 If ResWcted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. . 1. Ardcle Addrewd to: 537 1 '_WIOVER r"L CARLISL7 'D?, 17013 A. Sign h3 X ? Ao? B. Received by (Printed Name) C_Do" D. Is delivery address dNWant from item 1 ?f ? Xes N YES, enter delivery address below. No 3. Service Type kp~ Md ? Ehpm Mail 10 [3 pegfetwed ? Retum Receipt for Merchandise ? Insured Mall ? C.O.D. 4. Restricted Delivery? P ft Fee) ? Yes 2. Ardde Number ( ansferfromwrvAwlet 7004 1350 0003 7147 1595 PS Form 3811, February 2004 Dornsado Rsttxn Receipt 102595-02-M-1540 i EXHIBIT "A" , 3 t (_:Z.) -i rT? ni+ -rt ? r IL? t ?jC7 cn .w ? rn 1 .> Z °? b r, Y HAROLD S. IRURN, 111. ESQUIRE ATTORNEY ID NO. 29M 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243.6050 ATTORNEY FOR PLAINTIFF ALMA HRNJIC - HUSIC, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 2007 -1134 CIVIL TERM BEAD HUSIC, DefaWant : 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 ALMA HRNJIC - HUSIC, Plaintiff v. BEAD HUSIC, Dahndant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2007 -1X134 CIVIL TERM : IN DIVORCE AMENDED COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(d) OF THE DIVORCE CODE NOW, comes the plaintiff, by her attorney, Harold S. Irwin, III, Esquire, and files this amended complaint in divorce against the defendant, representing as follows: 1. The plaintiff is ALMA HRNJIC - HUSIC, an adult individual residing at 20 McBride Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is SEAD HUSIC, an adult individual residing at 537 North Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have been residents 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 18, 2000 in Teocak, Bosnia. 5. Pursuant to the Divorce Code, Section 3301(d), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken and that the parties hereto have lived separate and apart for a period of at least two years. The parties have lived separate and apart since on or about August 2, 2005. 6. The plaintiff avers that she has been advised of the availability of counseling and that said party 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 and for such further relief as your Honorable Court may deem equitable and just. 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. December 5, 2007 -HUSIC, Plaintiff HAROLD S. IRWIN, Attorney for plainti 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 ALMA HRNJIC - HUSIC, Plaintiff V. BEAD HUSIC, DMrndant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2007 - 7734 CIVIL TERM IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements set forth in this affidavit, you must file a counter- affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or about August 2, 2005 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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 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. of 4904 relating to unsworn falsification to authorities. December 5, 2007 AL A HRN C-HUSIC, Plaintiff ALMA HRNJIC - HUSIC, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTYy PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 2007 -1134 CIVIL TERM BEAD HUSIC, Defendant : IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check (i), (ii) or (both): W The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. In understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and sere them on the other parry. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further delay. 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. December , 2007 SEAD HUSIC, Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, you need not file this counterafAdavit. N , a ?" ? ' y J Y ?> t I ('rte} ?,,, cn } ?. y HAROLD S. IRWIN,111, ESQ. ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 24341090 ATTORNEY FOR PLAINTIFF ALMA HRNJIC - HUSICe Plaintiff V. SEAD HUSIC, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTYO PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2007 -1134 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: Separation of the parties for over two years under Section 3301(d) of the Divorce Code (the parties have been separated since August 2, 2005. 2. Date and manner of service of the complaint: The amended complaint in divorce under Section 3301 (d) of the Divorce Code was filed on December 6, 2007 and served upon the defendant on December 13, 2007, by certified mail, restricted delivery addressed to 537 North Hanover Street, Carlisle, PA 17013, certified mail receipt number 7007 0710 0003 2208 3981 (attached as Exhibit A). 3. Date of execution by the plaintiff and service upon the defendant of the affidavit under Section 3301(d) of the Divorce Code: An affidavit under Section 3301 (d) of the divorce code was signed by the plaintiff on December 5, 20076 amd attached to the amended complaint served upon defendant on December 13, 2007; however, defendant has not filed a counter-affidavit. 4. Date of execution by the defendant of the affidavit under Section 3301 (d) of the Divorce Code: An affidavit under Section 3301 (d) of the divorce code was attached to the amended complaint served upon defendant on December 13, 2007. 5. Date of service upon plaintiff of the notice of intention to request entry of a divorce decree: N/A. Plaintiff has executed a waiver of notice, attached hereto as Exhibit B. 6. Date of service upon defendant of the notice of intention to request entry of a divorce decree: Defendant was served with the notice of intention to request entry of a divorce decree on January 7, 2008, by certified mail addressed to 537 North Hanover Street, Carlisle, Pennsylvania, certified mail receipt number 7007 0710 0003 2208 3942 (attached as Exhibit B). Defendant has neither responded nor filed a counter-affidavit. 7. Related claims pending: None. January 29, 2008 HAROLD S. IRWI , III Attorney for Plaint Ca (Domestic Mail Only I ; Provided) ir For delivery informatio n visit . M cp E3 ru Postage 2 $ b 1& ed Fee M C3 Retum Receipt Fee Postmark O (Endorsement Required) Here C3 Restricted Delhrery Fee (Endorsement Re uired) C! M q ti 1 d r-a f%- Total Postage $ Fees I s O Sent To ` l M1 Sireei. Api ?q ................ --------•- or PO Box No. r V City, Z1P+4 ?• ¦ Complete Items 1, 2, and 3. Also complete Item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the gird to you. ¦ Attach this card to the back of the maiipiece, or on the front if space permits. 1. Article Addressed to: SEAD HUSIC 537 N R ,NOV R^ T CARLISLE '?A 17013 A. Signatu 0 Agent x .., B. Paodfied by (Pd111 Al") C. Date of hrery IV/S 7 0 Yes D. is dwvery address different tram item 1 N YES, enter delivery address below: 0 No 3 Type Merl 0 Express Mail 0 Registered 0 Retum Receipt for Merchandise 0 Insured Mall 0 C.O.D. 4. Raehioled Dsh ry9 (Extra Fee) 2. ArtlcieNumber 7007 0710 0003 2208 3981 (Transfer rrom servVice ANap PS Form 3811, Febm" 2w4 DrxrlaNic Pali" Receipt yon-ox-Wluo c ;. EXHIBIT "A" EXHIBIT °g^ ALMA HRNJIC - HUSIC, Plaintiff V. SEAD HUSICt Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2007 -1134 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(0) 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. 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 unswom falsification to authorities. January,'?o 2008 frv ALMA 1P WIC- SIC n t'T , r7l "*s Ln -< M .. r . ?. - . . •. Er For .- livery information visit our website at w ww.usps.comJ, M m C ru l.. , Postage a $ ll ru M A L?rttfled Fee m Postmark Q 0 Return Receipt Fee (Endorsement Required) ` Here C3 Restricted Delivery Fee (Endorsement Required) O rl r`- Total Postage $ Fees @ $ O r?- Sent To ? \ a Apt" o ; Street = X45..-•°•° R ^•-°-•• C3 . , or PO Box No. 15 M I D - ... . - --------------- -- City, State, Z +4 .. 3 4 7 I 't odwI M PS Form 380n n , R ¦ Complete Items 1, 2, and 3. Also complete Item 4 If Restricted Delivery Is desired. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front If space permits. 1. Article Addressed to: SEAD HUGIC 537 N HANOVER ST CARLISLE PA 17013 X C3 Agent Addressee . y (Pttn tecf C M D. Is .y address diMerert from item 17 ? Yes dW1w if YES, enter deiivery address below: ? No A ? 3. 1 13 E)wm man Registered 0 Return Receipt for Merchandise O Insured mail ? C.O.D. 4. Restricted Delivery? Extra Fee) M Yes 2' Nurnbw 7007 0710 0003 2208 3943 ? m ? servAoe kW n Form 3811, Febnwy 2004 Domsedc RNurn Recta 102595-02-nt-1640 EXHIBIT "C° IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ALMA HRNJIC - HUSIC -'Plaintiff VERSUS SEAD HUSIC Defendant No. 2007 - 1134 CIVIL TERM DECREE IN DIVORCE ?Y6,4 ?. AND NOW, ?,, IT IS ORDERED AND DECREED THAT AND ALMA HRNJIC - HUSIC SEAD HUSIC 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 T w ATTEST: J PROTHONOTARY L - C L ?