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HomeMy WebLinkAbout03-1330IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VALERIE J. BEN-SKANDER, Plaintiff Vo MOHAMED H. BEN-SKANDER, Defendant ACTION IN 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 counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland county court House, High Street, Carlisle, PA 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. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VALERIE J. BEN-SKANDER, Plaintiff MOHAMED H. BEN-SKANDER, Defendant NO. 2003- ACTION IN DIVORCE AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si usted desea defenderse de las quejas expuestas en las paginas siguientes debe tomar accion con prontitud. Se de divorcio o anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualquier otea queja o compensacion reclamados por el demandante. Usted puede perder dinero, o proopiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompiemiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County Courthouse, High Street, Carlisle, PA 17013. SI USTED NO RECLAMA PENSION ALIMENTICIA. PROPIEDAD MARITAL. HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMITIDO. USTED PURDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABODADO DE INMEDIATO. SI NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABA JO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. Lawyer Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VALERIE J. BEN-SKANDER, Plaintiff Ve MOHAMED H. BEN-SKANDER, Defendant NO. 2003. ACTION IN DIVORCE COMPLAINT AND NOW COMES, this 14th day of March, 2003, the Plaintiff, VALERIE J. BEN~- SKANDER, by her attorney, Joseph A. Kalasnik, Esquire, and files the within Complaint, to wit: 1. The Plaintiff is Valerie J. Ben-Skander, who currently resides at 4 Gustin Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2. The Defendant is MOHAMED H. BEN-SKANDER, who currently resides at 534 Hummel Avenue, Apt. No. 2, Lemoyne, Cumberland County, Pennsylvania. 3. Plaintiff is a citizen of the United States. Defendant is a non-citizen of the United States with asylum status Both parties have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the signing of this Complaint. 4. The parties were married on June 6, 1998, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior 'actions for divorce or for annulment between the parties in this or any other jurisdiction. 6. There is no collusion between the parties in regard to this proceeding. 6. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that theCourt require the parties to participate in counseling. WHEREFORE, the Plaintiff request the Honorable Court to enter a Decree of Divorce on behalf of the Plaintiff and against the Defendant. Date: March 19, 2003 /.~Respectfully submitted, ~seph ~. Kalasnik, Esquire 5ttomey for Plaintiff MENGES, GENT & McLAUGHLIN, LLP 1157 Eichelberger Street Hanover, PA 17331 (717) 632-1784 Supreme Court ID #76063 VERIFICATION 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. LERIE J. BEI~/~KAI~DER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VALERIE J. BEN-SKANDER, Plaintiff MOHAMED H. BEN-SKANDER, Defendant NO. 2003-1330 ACTION IN DIVORCE AFFIDAVIT OF SERVICE I, Joseph A. Kalasnik, attorney for the above Plaintiff, do hereby certify that on April 23, 2003, a true and correct copy of the Divorce Complaint in the above captioned action, was served on the Defendant, Mohamed H. Ben-Skander, by United States Mail, certified, restricted delivery, return receipt requested, as evidenced by the attached certified mail return receipt. April 28, 2003 //3oseph%. Kalasnik v//Attomey for Plaintiff 1157 Eichelberger St. Hanover, PA 17331 (717) 632-1784 Sup. Ct. I.D. #76063 Sworn to and subscribed before me, the day and year aforesaid. My Commission Expires: Notadal Seal Sharo~ L Gossman, Notary Public . _ I:~'mTwp.,YorkCouffiy My Commission Expires Nov. 3, 2003 hOOD · 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: 2. Arficl Ps X different from item 17 q~] Yes If YES, enter delivery address below: [] No 3. Service Type --~"~"~ified Mall [] Express Mail [] Registered [] Return Receipt for Memhandise [] Insured Mail [] C.O.D. 4. Restricted Deliverv? (E;~tra Fee) []Yes 595-00-M-0952 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VALERIE J. BEN-SKANDER, Plaintiff MOHAMED H. BEN-SKANDER; Defendant NO. 2003-1330 ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on March 26, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of 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. §4904 relating to unswom falsification to authorities. Date'~.~.~,4 ....~% t:a~Ot~---~ VALERIE BE~SKANDER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VALERIE J. BEN-SKANDER, Plaintiff VS. MOHAMED H. BEN-SKANDER, Defendant CIVIL ACTION - LAW No.: 2003-1330 ACTION IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301 (c~ OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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. §4904 relating to unsworn falsification to authorities. VXLEPdE J. ]~q-SKANDER, Plaint' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VALERIE J. BEN-SKANDER, Plaintiff MOHAMED H. BEN-SKANDER, Defendant NO. 2003-1330 ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on March 26, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of 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. §4904 relating to unswom falsification to authorities. Date: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VALERIE J. BEN-SKANDER, Plaintiff MOHAMED H. BEN-SKANDER, Defendant CIVIL ACTION - LAW No.: 2003-1330 ACTION IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §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 ifI 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. §4904 relating to unswom falsification to authorities. MOHAMED H. BEN-SKANDER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VALERIE J. BEN-SKANDER, Plaintiff MOHAMED H. BEN-SKANDER, Defendant NO. 2003-SU-1330 ACTION IN DIVORCE PRAECIPE TO TRANSMIT REC, ORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Grounds for divorce: Irretrievable breakdown untder §3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified Mail Return Receipt Requested, dated April 23, 2003 and via U.S. First Class Mail. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code: by Plaintiff- July 24, 2003; by Defendant - July 26, 2003. Related claims pending: All economic claims scuttled pursuant to oral agreement by the parties. 5. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: July 30, 2003. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: August 5, 2003. Date of execntion of Defendant's Waiver of Notice of Intent: July 26, 2003. Date of execution of PlaintiXTs Waiver of Notice of Intent: July 24, 2003. Please submit all papers in this case to the Cj~.krt for entry of an appropriate decree. Dated: July 31, 2003 J~eph A. Kalasnik, Esquire ~Ienges, Gent & McLaughlin, LLP v 1157 Eichelberger Street Hanover, PA 17331 (717) 632-1784 Sup. Ct. I.D. 76063 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF .~. PENNA. VALERIE J. BEN-SKANDER VERSUS MOHAMED H. BEN-SKANDER NO. 1330 of 2003 DECREE IN DIVORCE AND NOW, ~'~g.~J~. : t~~ DECREED ThAt VALERIE J. BEN-SKANDER MOHAMED H. BEN-SKANDER AND , ~ IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE SEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE BY THE COURT: ATTeS- PROTHONOTARY