HomeMy WebLinkAbout03-2534
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:02>> .. ~'3'1CIVIL TERM
AYISHA ABRAHIM,
Plaintiff
SABRY IBRAHIM aka
MOHAMAD MOHAMAD ABBAS,
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 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 marriage
counseling. A list of marriage counselors is available in the
Office of the Prothonotary at the Cumberland County Court House,
High and Hanover Street, Carlisle.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER1S 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.
Court Administrator
Cumberland County Court House
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6200
JOH , ESQUIRE
Supr #53147
300 North Second Stree ,8th Floor
Harrisburg, PA 17101
(717)221-1111
Attorney for Plaintiff
Ay:tSliA ABRPJi:tMr . ff
plaint~
IN 'IRE COURT Of COMMp~~1~~~~~i
CuMBER1.AND COuNTY, 01.'11."
6"- ~ d-~b'-\ cIVIL TERM
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v.
IN DIVORCE
SABR.~ :tBRPJi:tM, aka ,
MoHAMAD MoHAMAD ABBAS,
Defendant
1. Plaintiff is ~yisha Abrahim,an adult individual, who
currentlY resides at 104 November Drive, suite ~2, CamP Hill,
CUmberland County, pennSylvania.
COMP:Ll\,INT ~CTION 3301 c
QF- 3301 (d) OF THE DIV~
2. Defendant is sabry Ibrahim, aka Mohamad Mohamad
Abbas,an adult individual who currentlY resides at 104 November
Drive, Camp Hill,cumberland County, pennsylvania.
3. Plaintiff and Defendant have been bona fide residentS
in the commonwealth for at least six monthS immediately previouS
to the filing of this complaint.
4. The Plaintiff and Defendant became common Law husband
and wife on May 15, 2000, in selinsgrove, snyder county.
pennsylvania.
5. There have been nO prior actions of divorce or for
annulment between the parties.
6. The Plaintiff haS been advised of the availability of
marriage counseling and the Plaintiff may have the right to
request that the court require the parties to participate in
counseling. Having been so advised Plaintiff does not desire tl
Court to order counseling, as evidenced by the ~ffidavit as
attached hereto and made a part hereof marked as "Exhibit ~."
WHEREFORE, Plaintiff requestS your Honorable Court to en'
a decree in divorce.
1. The marriage is irretrievablY broken.
AYISHA ABRAHIM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
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v.
NO: 03 - ;1.S3~
CIVIL TERM
SABRY IBRAHIM aka
MOHAMAD MOHAMAD ABBAS,
Defendant
IN DIVORCE
AFFIDAVIT
I, AYISHA ABRAHIM, Plaintiff, being duly sworn according to
law, depose and say:
(1) I have been advised of the availability of marriage
counselling and understand that I may request that the court require
that my spouse and I participate in counselling.
(2) I 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 counselling prior to a divorce
decree being handed down by the court.
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.
Dated: ~-1)\.JJ.f ;Xc'; /J..-t[,3
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.AYI ABAAHI:7 Plaintiff
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND :SS
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.
DATED: --/}}[Uj J1 L~I ;( C'{)3
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A YISHA ABRAHIM,
Plaintiff
; IN THE COURT OF COMMON PLEAS OF
; CUMBERLAND COUNTY, PENNSYLVANIA
v.
03-2534 CIVIL TERM
~ABRY IBRAHIM aka
MOHAMAD MOHAMAD ABBAS
Defendant
IN DIVORCE
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i PRAECIPE TO TRANSMIT RECORD
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to the Prothonotary:
. Transmit the record, together with the following information,
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o the Court for entry of a divorce decree;
ection 3301 (d) of the Divorce Code. Filed May 29, 2003
I
~ 2. Date and manner of service of the Complaint: See attached Notice and Certified mail,
rated 6-4-03. (Exhibit "A")
I 3. (Complete either paragraph (a) or (b);
i (a) Date of execution of the Affidavit of Consent required
ty Section 3301(c) of the Divorce Code:
i
I
~ (b)(l) Date of Execution of the Plaintiffs Affidavit required by Section 330l(d) ofthe
(vorce Code; February 1, 2005. (Exhibit "B")
b (2) Date of Service ofthe Plaintiffs Affidavit upon Defendant: February 1, 2005, by
1 irst-Class Mail, Postage prepaid.
,
I
1 (3) Date of Service of the Notice of Intention and Counter-Affidatvit: March 1, 2005, by
lirst-Class Mail, Postage prepaid. (Exhibit "C")
I
4. Related claims pending: None
,
Respectfully submitted,
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JohnnaJ. Kope~ky, Esquir~.
v . C"'/
Shagm & Anstme LL
300 North Second Street, 8th Floor
Harrisburg, P A 1710 1
(717) 221-1111
Attorney for Plaintiff
. 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:
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3. Sel}ice Type
lY' Certified Mail 0 Express Mail
o Registered 0 Return Receipt for Merchandise
o Insured Mail 0 C.O.D.
4. Restricted Delivery? (Extra Fee) IiJ"Yes
2. Article Number (Copy from service fabeQ
1001.. 0'-\.100 0Cl02 1tR~ -J"l,cn
PS Form 3811, July 1999 Domestic Return Receipt
102595.99-M.1789
rjri IL:W( (1
A YISHA ABRAHIM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY PENNSYLVANIA
: NO. 03-2534 CIVIL TERM
SABRY IBRAHIM aka
MOHAMAD MOHAMAD ABBAS,
Defendant: IN DIVORCE
NOTICE TO THE DEFENDANT
If you wish to deny any of the statements set forth in this affidavit, you
must file a counteraffidavit within twenty days after this affidavit has been served
on you or the statements will be admitted.
PLAINTIFF'S AFFIDAVIT UNDER SECTION 330l(d) OF THE
DIVORCE CODE
1. The parties to this action separated on January 20,2005, and have continued to live separate
and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3, 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.
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. Section 4904 relating to
unsworn falsification to authorities.
pruev'-l
2005
L~l tJ m,', J3
AYISHA ABRAHIM
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO: 03-2534 CIVIL TERM
SABRY IBRAHIM aka
MOHAMAD MOHAMAD ABBAS
Defendant
: IN DIVORCE
NOTICE OF INTENTION TO REOUEST
ENTRY OF DIVORCE DECREE
TO: SABRY IBRAHIM aka
Mohamad Mohamad Abbas
104 November Drive, Suite #2
Camp Hill, P A 17011
You have been sued in an action for divorce. You have failed to answer the Complaint or
file a Counter-Affidavit to the Plaintifrs Affidavit. Therefore, on or after March 21, the Plaintiff
can request the Court to enter a Final Decree in Divorce.
If you do not file with the Prothonotary of the Court an Answer with your signature
notarized or verified or a Counter-affidavit by the above date, the Court can enter a Final Decree
in Divorce. Unless you have already filed with the Court a written claim for economic relief, you
must do so by the above date or the Court may grant the divorce and you will lose forever the
right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH
THE PROTHONOTARY OF THE COURT IS ATTACHED TO THE NOTICE.
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 HELP.
J I ,
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Court Administrator
Cumberland County Courthouse
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6200 . . /(,,/:..).~
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JO~~J.I<:~~:~~: ESqpr~
Supreme Court Id #53147
300 North Second Street,8th FL
Harrisburg, PA 17101
(717) 221-1111
Attorney for Plaintiff
C;,:H,I]l"( . (
A YISHA ABRAHIM ,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
SABRY IBRAHIM aka
MOHAMAD MOHAMAD ABBAS
Defendant
: NO. 03-2534
CIVIL TERM
: IN DIVORCE
COUNTER-AFFIDAVIT UNDER SECTION 330Hd)
OF THE DIVORCE CODE
L 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):
(i) The parties to this action have not Jived
separate and apart for a period of at least
three 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
r lief. 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.
(b) I wish to claim economic relief which may
1 clude alimony, division of property, lawyer's fees or expenses or other important rights.
I verify that the statements made in this counter-affidavit are true and correct. I understand that
Jse statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn
Isification to authorities.
ATED:
onCE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any
c aim for economic relief, you need not file this counter-affidavit.
A YISHA ABRAHIM
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
SABRY IBRAHIM
aka MOHAMAD
MOHAMAD ABBAS
NO. 2003-2534 CIVIL TERM
ORDER OF COURT
AND NOW, this 11 TH day ofMA Y, 2005, it appearing that the Section 3301 (d)
Affidavit alleges a separation date less than two years, the request for the cntry of a
divorce decree is denied without prejudice.
,
By the Court)
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~a 1. Kopecky, Esquire
For the Plaintiff
Edward E, Guido, J.
,j
,;Sabry Ibrahim
] 04 November Drive, Suite #2
Camp Hill, Pa. 1701 I
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A YISHA ABRAHIM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY PENNSYLVANIA
: NO, 03-2534 CIVIL TERM
SABRY IBRAHIM aka
MOHAMAD MOHAMAD ABBAS,
Defendant: IN DIVORCE
NOTICE TO THE DEFENDANT
If you wish to deny any of the statements set forth in this affidavit, you
must file a counteraffidavit 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 January 20,2003, and have continued to live separate
and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or
expenses in do not claim them before a divorce is granted.
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. Section 4904 relating to
unsworn falsification to authorities.
"
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-
A YISHA ABRAHIM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
03-2534 CIVIL TERM
SABRY IBRAHIM aka
MOHAMAD MOHAMAD ABBAS
Defendant
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:
I. Ground for divorce: Irretrievable breakdown under Section
Section 3301(d) of the Divorce Code. Filed May 29,2003
2. Date and manner of service of the Complaint: See attached Notice and Certified mail,
dated 6-4-03. (Exhibit "A")
3. (Complete either paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent required
by Section 3301(c) of the Divorce Code:
(b)(1) Date of Execution ofthe Plaintiffs Affidavit required by Section 330l(d) of the
Divorce Code: February 1, 2005. (Exhibit "B")
(2) Date of Service of the Plaintiffs Affidavit upon Defendant: February I, 2005, by
First-Class Mail, Postage prepaid.
(3) Date of Service of the Notice oflntention and Counter-Affidatvit: March I, 2005, by
First-Class Mail, Postage prepaid. (Exhibit "C")
4. Related claims pending: None
Attorney for Plaintiff
Respectfully submitted,
~.
AYISHA ABRAHIM,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
~a1 - ;tSJ'bVIL TERM
IN DIVORCE
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SABRY IBRAHIM aka
MOHAMAD MOHAMAD ABBAS,
Defendant
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NOTICE 5;;5::' ~?
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You have been sued in court. If you wish to defend~g~fhst<
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.
t..c~
When the ground for the 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 at the Cumberland County Court House,
High and Hanover Street, Carlisle.
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.
Court Administrator
Cumberland County Court House
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6200
"-
JO , ESQ~I~
Supr #53147~.
300 North Second Stree ,8th Floor
Harrisburg, PA 17101
(717) 221-1111
Attorney for Plaintiff
E.)l h; b\ t- A.
AYISHA ABRAHIM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
94
CIVIL TERM
SABR~ IBRAHIM, aka ,
MOHAMAD MOHAMAD ABBAS,
Defendant
IN DIVORCE
COMPLAINT UNDER SECTION 3301(c)
OR 3301(d) OF THE DIVORCE CODE
1. Plaintiff is Ayisha Abrahim, an adult individual, who
currently resides at 104 November Drive, Suite #2, Camp Hill,
Cumberland County, Pennsylvania.
2. Defendant is Sabry Ibrahim, aka Mohamad Mohamad
Abbas,an adult individual who currently resides at 104 November
Drive, Camp Hill,Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents
in the Commonwealth for at least six months immediately previous
to the filing of this Complaint.
4. The Plaintiff and Defendant became Common Law husband
and wife on May 15, 2000, in Selinsgrove, Snyder County,
Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties.
6. The Plaintiff has been advised of the availability of
marriage counseling and the Plaintiff may have the right to
request that the Court require the parties to participate in
counseling. Having been so advised Plaintiff does not desire the
Court to order counseling, as evidenced by the Affidavit as
attached hereto and made a part hereof marked as "Exhibit A."
7. The marriage is irretrievably broken.
WHEREFORE, Plaintiff requests Your Honorable Court to enter
a decree in divorce.
AYISHA ABRAHIM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
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v.
NO:
CIVIL TERM
-
SABRY IBRAHIM aka
MOHAMAD MOHAMAD ABBAS,
Defendant
IN DIVORCE
AFFIDAVIT
I, AYISHA ABRAHIM, Plaintiff, being duly sworn according to
law, depose and say:
(1) I have been advised of the availability of marriage
counselling and understand that I may request that the court require
that my spouse and I participate in counselling.
(2) I 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 counselling prlor to a divorce
decree being handed down by the court.
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.
Dated: -
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AYISHA ABRAHIM-
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Plaintiff
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND :SS
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.
DATED:
7, ...,
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SENDER: COMPLETE THIS SECTION
<t
COMPLETE THIS SECTION ON DELIVERY
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 jf space permits.
1. Article Addressed to:
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D. Is delivery address different from item 11 ()ttYes
If YES, enter delivery address below: 0 No
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3. Se~ce Type
~ Certified Mail
o Registered
o Insured Mail
o Express Mail
o Return Receipt for Merchandise
DC.OD.
4. Restricted Delivery? (Extra Fee)
SJ"Yes
2. Article Number (Copy from service label)
7001. O'-llllO 0C02. 1tfIfl ;l"~i
PS Form 3811, July 1999 Domestic Return Receipt
1Q2595-99-M-1789
A YISHA ABRAHIM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY PENNSYLVANIA
: NO. 03-2534 CIVIL TERM
SABRY IBRAHIM aka
MOHA,'\1AD MOHAMAD ABBAS,
Defendant: IN DIVORCE
NOTICE TO THE DEFENDANT
If you wish to deny any of the statements set forth in this affidavit, you
must file a counteraffidavit 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 January 20,2003, and have continued to live separate
and apart for a period of at least two years.
2. The marriage is irretrievably broken.
3. 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.
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. Section 4904 relating to
unsworn falsification to authorities.
fxhl'bit 6
A YISHA ABRAHIM
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO: 03-2534 CIVIL TERM
SABRY IBRAHIM aka
MOHAMAD MOHAMAD ABBAS
Defendant
: IN DIVORCE
NOTICE OF INTENTION TO REOUEST
ENTRY OF DIVORCE DECREE
TO: SABRY IBRAHIM aka
Mohamad Mohamad Abbas
104 November Drive, Suite #2
Camp HilI, PA 17011
You have been sued in an action for divorce. You have failed to answer the Complaint or
file a Counter-Affidavit to the Plaintiffs Affidavit. Therefore, on or after March 21, the Plaintiff
can request the Court to enter a Final Decree in Divorce.
If you do not file with the Prothonotary of the Court an Answer with your signature
notarized or verified or a Counter-affidavit by the above date, the Court can enter a Final Decree
in Divorce. Unless you have already filed with the Court a written claim for economic relief, you
must do so by the above date or the Court may grant the divorce and you will lose forever the
right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH
THE PROTHONOTARY OF THE COURT IS ATTACHED TO THE NOTICE.
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 HELP.
Court Administrator
Cumberland County Courthouse
I Courthouse Square
Carlisle, PA 17013
(717) 240-6200 ( " ,
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. . ,.-,.,
Johr,ma J. Kopecky, Esquire
Supreme Court Id #531 ,r7
300 North Second Street,8th FL
Harrisburg, PA 17101
(717) 221-1111
Attorney for Plaintiff
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IN THE COURT OF COMMON PLEAS
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OFCUMBERLANDCOUNTY
STATE OF
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VERSUS
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AND NOW,
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DECREED THAT
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AND s.,..b"'J
DECREE IN
DIVORCE
c..:fI F 14 A.t11 .
:;Jd/Jf"IT IS ORDERED AND
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, PLAINTIFF,
aJW>.- tno~lh6~ ~ls,...i,EFENDANT,
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLl_OWING CLAIMS WHICH HAVE
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
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YET BEEN ENTERED;
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