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Home My WebLink About00-05420 I ,~~ ~ "~ < . . . . "'''' '" '" "'''' "'''' , "'''' '" '" "'''''''''' "'''' "'''' '" '" . . IN THE COURT OF COMMON PLEAS . OF CUMBERLAND COUNTY STATE OF . . USMAN UMAR-ZAI, Plaintiff . . . . . . . VERSUS . DEBORAH UMAR-ZAI, Defendant . . . . . . . . No. DECREE IN DIVORCE . AND NOW, ~ USMAN UMAR-ZAI . . DECREED THAT . . DEBORAH UMAR-ZAI . . AND . PENNA. 2000-5420 ... .;;/ ,.:I..()(J(J, IT IS ORDERED AND , PLAINTIFF, , 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 THE COURT: I . . /1-a. ~~HONOTA': .. "''''''''''''' "'''' "''''''' '" "'''' ,.,:t;"'''' . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " -,,;~, ~'" ", "'''''"'iHMii_.il!i '" J.l*........-' -, ~,~. -" -" , < ,'^"- <' ,,~,. ..-.'-"'" '~lM. ""-~' . ~~' , .. . . i/. tPa? &vi ~ /U-a4,.--b 4 ~ /(.;;p-tZY ~ ~ z9- . =~-- " ,- ,~ '~'.~, L>" ~' : ! l ~:; I,' I;]~ I' (! Ii. 'il:i~ ',: I,' I:" ~ : I ~! !J , ~, ili I ! , , i , i I . .~.Lj, .I " USMAN UMAR-ZAI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL DIVISION - LAW DEBORAH UMAR-ZAI, Defendant : NO. 00-5420 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. Grotntd for divorce: irretrievable breakdown tntder S 3301(c) 3381(<1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the Complaint. Service was made on August 5, 2000 by an Affidavit of Acceptance of Service signed by the Defendant. 3. (Complete either paragraph (a), or (b).) (a) Date of execution of the Affidavit of Consent required by S 3301(c) of the Divorce Code: by the Plaintiff: November 14,2000; by the Defendant: November 14,2000. (b) (1) Date of execution of the Plaintiffs Affidavit required by S 3301(d) of the Divorce Code: (2) Date of servIce of the Plaintiffs Affidavit upon the Defendant: 4. Related claims pending: none 5. (Complete either (a) or (b); (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, and a copy of which is attached: (b) Date of execution of the Waiver of Notice of Intention to File Divorce Decree as required by S 3301(c) of the Divorce Code: by the . tiff: November 14, 2000; by the Defendant: November 14,2000. Date: ) 1-10-0D ~ omas S. Diehl, Esquire Attorney for Plaintiff ,- '" ~ " ''''''- ~, "" ,,,' "~~ - " '~i ["lfilii!), - r. l 'I .~~ "1 :1 't'~ ~:TI l' '1\ )", 'I J; II rj ."', t1 i1 Jl ~l ,,'"- - >"~.o/,_, ~"'~~-'"'~'.~ ,~ "'H' .."'-=,,.,_,_, '0'., "-~_"'__'1"JIl.!IJ " ." .' I, _ J", ,I( .~ W''l!I!II''/I!\WllfflWl1lM~.. 0 C"';i (~ C = "1"'1 < Z u,_ -oc:~- C:::l f1"l[';"" Z::;,~~ ~~- "7 ~ ~ ~:~~. 0 ~~~~, .'1~" Z~ ~'T. ' -.-' ' >C~~' r:",,) Z en ~,< OJ .. ~}lll':lf'1""!IJI_,,,,,..-~,,,~._~,,, " ~ " USMAN UMAR - ZAI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00- f5l..(;;D CIVIL TERM DEBORAH UMAR -ZAI, Defendant : CIVIL ACTION - LAW : INDNORCE 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cmnberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DNISION OF PROPERTY, LAWYER'S FEES OR EXPENSES, BEFORE A DNORCE 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 HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cmnberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 ",,'-"',"_. " ,,'~~ ". . "_'P'_',"{' ~'_ ,'>}' ',c' USMAN UMAR - ZAI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00- Sl/,;W CIVIL TERM DEBORAH UMAR - ZAI, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DNORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DNORCE CODE The Plaintiff, Usman Umar-Zai, through her attorney, Thomas S. Diehl, makes the following Complaint in Divorce, and, in support thereof, avers as follows: I. The Plaintiff, Usman Umar-Zai, is an adult individual who currently resides at 1821 Willow Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, Deborah Umar-Zai, is an adult individual who currently resides at 1821 Willow Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on July 20, 1999 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. r.".1'f"'o\'~"-- , , "'~'''..__ ._, >,"1_ ".,;;"'",_ '", '?''''1'')"",'--, ':' ,~"_~ "~,.',,.,. ," "q,~_.,.'?"_,,,''',r;, _ ",:;~=c"-,., 2';>,' _:"'"~"'_ - '~"'F'- ,,"' 0', , " _..0"'_"'>"" "". . ~ .- .~ 8. Plaintiff is a citizen of Pakistan, and Defendant is a citizen of the United States of America. 9. The parties' marriage is irretrievably broken. WHEREFORE, the Plaintiff, Usman Umar-Zai, respectfully requests your Honorable Court to enter a decree in divorce pursuantto 23 P.S. !}3301(c) or 330l(d) of the Divorce Code. Respectfully submitted, f) - :J-c.V Date: tJ yvPJ ; , ~I ;, r1i 'il Thomas S. Diehl Attorney for the Plaintiff One West High Street Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 -FAX , J.! JI w 1\' J' ~"':;" ., ~ . '""'-"""_'~'P""''-h__.'"'' '1""'" .."" '"'"n_';~~"3<<""'i._"", __ __ ,'~!'~~""', ,'V_,~_~ _"~, ~'H -- ,,-_ __ '<7_~ -~" "', ." ',- _ .-," "','" '"_.'_,~+-'-'", ", '.' __" .~'", ", '^, .<.' ""l ",_","~;." .' ._f'n". :~ 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. ~ 4904, relating to unsworn falsification to authorities. -,~ ;,,";"', 't'~'" ,"','7-,'"",_,1'~' > "'," -''''~/' "''''''''"'"'',',",.x _. '", ""', """,_~ "" -' """"~""-_'''t" _~ ',', 0," -,~--"" ""'_'''''''''_~'''''''"_,'f-';'' .,,<"'.,1".' "~"".' " - USMAN UMAR - ZAI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-5420 CIVIL TERM DEBORAH UMAR - ZAI, Defendant : CIVIL ACTION - LAW : IN DNORCE ACCEPTANCE OF SERVICE I, DEBORAH UMAR-ZAI, do hereby acknowledge that I accepted service of the Divorce Complaint Under Section 3301(c) or 3301(d) of the Divorce Code filed to the above- --- term and number on the 0 day of August 20000. Ii-" i " - ,-~"~_O'~"'i,c",:,",,,,-, __r,<_,,~,,_ - -,- ,"!i'"""",,,::-, n_ -f-P~_-' .',_",>r "'""'-"., ,,:' ~,;--"-:~_,,, ''''\';"''',<"o:",-',r>'f,),_~~,''__~>'F' '"",,' ~_,'" "",' ~"_"""'''H~","", , _. _~' ,,,",, ' "-',_3,"'__" __ or " ~-- C) 0 0 c 0 " $: "'" ~--< ""Dca c: T:tJ Ji1rn <:n lT1 f- Z::v -"'Jrn Zl; ::by ~::z~ 9c) \<0 v ,~"=H ~.-, ::r. ,-.Jo ':5 'Zrn =, l);> 0 )>c ~-, :z :fl ~ ::2 ...... -','.-'- ,,,,JIltI:,,,_',;r" ~~ ~~'"'-""> ... USMAN UMAR - ZAI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-5420 CIVIL TERM DEBORAH UMAR - ZAI, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under S330I(c) of the Divorce Code was filed Dn August 3, 2000. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date offiling and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce after service of notice Df 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. S 4909 relating to unsworn falsification to authorities. -ZAI, Plaintiff Date: // p~ /00 , , USMAN 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 in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees Dr expenses if! dD 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 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. 4909 relating to unsworn falsification to authDrities. Date: I//'/!;/OO , ' USMAN U -Z I, Plaintiff ":-,;, . " ,-, '",.',"-",,,.,,,, " ..r,r, " """ - . ,.,~.~" ~"~~,'~',>>"q'^">~_~~",,, ","'k" ~" ".,. ""<_,.,,,.. ..R~",""."',,,,_" ,,->\,~.,-r.:,,/, i" (") C) C Cl ~~,: -~ "".- -Or"'. ,:;:, --,.- m6"; ,,~.::: 2:1:' 2r-~ ~~; c.r Pn L("'; D 5>C: ;-~ p ~ 0"> __",,~~.fi!~~l~~I.!!f!IIIP.I ","- USMAN UMAR - ZAI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-5420 CIVIL TERM DEBORAH UMAR - ZAI, Defendant : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under 9330l(c) of the Divorce Code was filed on August 3, 2000. 2. The marriage of the 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 i' ,I ! i 1 I' " 'li Ii ';1 " :1 ;\ 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. 9 4909 relating to unsworn ~y" ,moo,,:: 2000 1/2Ild~-$' D ORAH UMAR-ZAI, Defendant 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 in Divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 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 I a.C.S. 9 4909 relating to unsworn falsificap6Il}o authorities'/7 " D:::) ~r I~ ZOO" rqit I ,~~ , - ~. ~,,' ,,' -"T",~ .,. . <,~.,~",,<,<,,~~~. ~""~~",~,,, " ~",,"n,,~.. , -. .. .'0 ~ ..........~,,"" ,,,' ~"'''"''',,,'',~,~,,,'~ o c: ;;:: Ut""" 1'1l-;:~ :z'-,,~ zt" ~ ~~~~ :i;C' ;;So >c: ~ r:- '..j ", o o ". ~~ (J; .x~; _is. c-! ",';; iJIii'lIIP'9MlJUJI[ ,.,~ _., ~.;M!M". ". ,", ~,' ---~\.""~~'"", "'::' '-'-::-~'-" . ',>'. ,,~