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HomeMy WebLinkAbout03-2564HANA KARAHODZA, Plaintiff VS. HARIS KARAHODZA, Defendant · No. 03. · ACTION IN DIVORCE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Civil Term 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 HANA KARAHODZA, Plaintiff VS. HARIS KARAHODZA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ·No. o ~- .2. ~-t. ¥ Civil Term ·ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Hana Karahodza, a competent adult individual, who has resided at 106 E. Willow St., Carlisle, Cumberland County, Pennysylvania, since 2001. 2. Defendant is Hafts Karahodza, a competent adult individual, who has resided at 1001 Prarie St., Sioux Falls, South Dakota, since 1998. 3. Plaintiff has been a bona fide resident of the Cormnonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on November 26, 2000 in Sioux Falls, South Dakota. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint are tree 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. Hana Karahodza, Plaintiff Date: ,,~Respectfully submitted, I.D//No. 79465 3~South Pitt Street x-.__..~'~Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF HANA KARAHODZA, Plaintiff VS. HARIS KARAHODZA, Defendant · IN THE COURT OF COMMON PLEAS i CUMBERLAND COUNTY, PENNSYLVANIA No. Civil Term ACTION IN DIVORCE To the Prothonotar~ NOTICE TO RESUME PRIOR SURNAME. Notice is hereby given that the Plaintiff in the above matter: X prior to the entry ora Final Decree in divorce. OR ~ after the entry of a Final Decree in Divorce hereby elects to resume the prior surname of ZUKANOVIC and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. s704. HA}gA KARA~---~ODZA, former nfime¥----- HANA ZUK~F]~Vi~-~ Signature of Nal~ being resumed. COMMONWEALTH OF PENNSYLVANIA ) COUNTy OF CUMBERLAND ):ss ) On this th .~.-.'~/~--I , personall armeare ~,t^ v- ^ r, A ,,,.,,..~~2003 before me, the undersi ned officer, Y ~-~- d HA~,~ '~v,~-xnu~z,A/tt$~NA ZUKA~,T~.,,,.-~ g · ~,av~.. personally know to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained· IN WITNESS WHEREOF, I h~ HANA KARAHODZA, Plaintiff VS. HARIS KARAHODZA, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 03 - 2564 Civil Term : : ACTION IN DIVORCE AFFIDAVIT OF SEPARATION 1. The parties to this action separated July 17, 2001 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 my rights conceming alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. I verify that the statements made in this affidavit are tree 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: I 10 , Hana Karahodza, Plaintiff HANA KARAHODZA, Plaintiff VS. HARIS KARAHODZA, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 03 - 2564 Civil Term : : ACTION 1N DIVORCE pRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the Complaint in the above-captioned matter. Date: Respectfully submitted, s, Esqu' 465 36 South Hanover Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF HANA KARAHODZA, Plaintiff VS. HARIS KARAHODZ,~¢fendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 03 - 2564 Civil Term : : ACTION IN DIVORCE PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: AND NOW, this case discontinued. day of November, 2003, please mark the above-captioned Respectfully Submitted, s, Esquire · 79465 36 South Pitt St. Carlisle, Pa.. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF