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HomeMy WebLinkAbout07-1994 Azah M. Abdalla IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- )q94 CIVIL TERM Tarig Dafalla Defendant 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 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, 1 Courthouse Square, Carlisle, Pennsylvania. 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Azah M. Abdalla Plaintiff V. Tarig Dafalla Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 9 9 y CIVIL TERM IN DIVORCE COMPLAINT UNDER 43301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is Zc ? ???? A 0. ? Lc' , who currently resides at 3ti A W 1 oC-? 005 Cumberland County, Pennsylvania. ?0.r?A ??0.- a1lC. wO+k 2. Defendant is who currently fesid8s at 36z- S- -VECr\t S? C 5'`3 C 1 1 C«b 5? S'?e?l?o n Pc" 1I i 3. Z 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on M u tcA'\ 10 . 2-0 o c, at, Lg?Ao-t , C a pro 5. The marriage is irretrievably broken, and the parties separated on Air, l 1u 0 6 6. Therehave been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. i WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Lk_ 11- or Date Plaintiff, Pro Se I, N Zc.? iy\ do.. t1n , verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made 'herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa: C.S. §4904. LA- it- 0 Date: Plaintiff, Pro Se Assisted by: Susan Candiello, Esquire 4010 Glenfinnan Place Mechanicsburg, PA 17055 (717) 724-2278 N L7 _ lilts-' )iYl . 1 , Azah M. Abdalla IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- )qqq CIVII. TERM Tarig Dafalla Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Azah M. Abdalla. Plaintiff, to proceed in forma au eris. I, Susan Candiello, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Attome for PI ntiff 4010 G nfin n Place Mechanics urg, PA 17055 (717) 724-2278 0 v T w, C Azah M. Abdalla IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 199q CIVIL TERM Tarig Dafalla : Defendant IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the Court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. CD AZAH M. ABDALLA , TARIG DAFALLA, PLAINTIFF VS. DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : NO.07-1994 CIVIL TERM : CIVIL ACTION -LAW : ACTION FOR DIVORCE SERVICE OF DIVORCE COMPLAINT BY CERTIFIED MAIL I am an attorney licensed to practice law in the Commonwealth of Pennsylvania. 2. 1 represent.Azah M. Abdalla, Plaintiff in the above-captioned. matter. 3. On April 22, 2007, Azah M. Abdalla, Plaintiff, placed a true and correct copy of the Cornplaint for No-Fault Divorce Under Section 3301(c) of the Divorce Code for delivery with the U.S. Postal Service in Mechanicsburg, Pennsylvania, being Certified/First Class Mail, restricted delivery, return receipt requested, Article No. 7003 0500 0002 6337 9371, and addressed to the Defendant's attorney, Joseph T. Sucee, Esquire, at 325 Pcach4daville Road, Gardners PA 17324. 4. The return receipt card signed by the Defendant's attorney, Joseph T. Sucee, Esquire, showing a date of service of April 26, 21107, is attached hereto as Exhibit "A". 5. Service by certified mail meets the requirements of Pa.R.C.P. 404(2) and Pa.R.C.P. 403. C_7_Toc?? _4V SUSAN KAY C IELLO, Counsel for Plain C? -4 c 1 U M O w G - tplete items 1, 2, and 3. Also complete 7jAk icted Delivery is desired. 0 Agent h 4 if Restr ¦ Print your name and address on the reverse ? F, dressee so that we can return the Card to you. Printed Name) C. a Del' ery ¦ Attach this card to the back of the mailpiece, or on the front if space permits. t D. Is delk y address different from item 1. Article Addressed to: If YES, enter delivery address below: ? No se ` - P TO P 3 Z3 d (ki 3. Service Type (?lJ4,v`ll ? Certified Mail ? E)press Mail ?Yde +n p -? (? ? Registered ? Return Receipt for Merchandise 1 `mil u ?( / 2 *Z? ? Insured Mail ? C.O.D. ( 3 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number 7003 0500 0002 6337 9371 (l Maur from service label) pS Form 3811, February 2004 Domestic Return Receipt i -to-15Q EXHIBIT "A" ID -n . ? CO ?. co l AZAH M. ABDALLA, PLAINTIFF VS. TARIG DAFALLA, DEFENDANT IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 07-1994 CIVIL TERM : CIVIL ACTION - LAW : ACTION FOR DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on or about April I Ph, 2007. A true copy of the Complaint for Divorce was served upon the Defendant, on April 26", 2007. 2. The marriage between 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 in Divorce, after the service of notice of intention to request entry of the decree. 4. I understand that if a claim for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses has not been filed with the Court before the entry of a final Decree in Divorce, the right to claim any of them will be lost. 5. 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. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 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 by the Court. I verify that the Statements 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 unworn falsification to authorities. DATE TARIG DAFALLA fil ?7 ^r? r-n Crt AZAH M. ABDALLA, PLAINTIFF VS. TARIG DAFALLA, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA NO. 07-1994 CIVIL TERM CIVIL ACTION - LAW ACTION FOR DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF 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 if I do not claim them before a divorce is granted. 3. 1 understand that 1 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 unsworn falsification to authorities. DATE TARIG DAFALLA r.a r- ca -'t`I c? ,., •; :77 ALn C-. LJ AZAH M. ABDALLA, PLAINTIFF VS. TARIG DAFALLA, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 07-1994 CIVIL TERM : CIVIL ACTION - LAW : ACTION FOR DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on or about April 11 ", 2007. A true copy of the Complaint for Divorce was served upon the Defendant, on April 26s`, 2007. 2. The marriage between the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. 1 consent to the entry of a final Decree in Divorce, after the service of notice of intention to request entry of the decree. 4. I understand that if a claim for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses has not been filed with the Court before the entry of a final Decree in Divorce, the right to claim any of them will be lost. 5. I have been advised of the availability of marriage counseling, and understand that 1 may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 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 by the Court. I verify that the Statements 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. 1-/ - / -s-= o DATE AZAH M. ABDALLA ^.? - ' ,?-° ?. ?a ? z-i .. ?...b ?. ,. 1wf ? L L t- `Ft^, n •? ??.' U AZAH M. ABDALLA, PLAINTIFF VS. TARIG DAFALLA, DEFENDANT : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 07-1994 CIVIL TERM : CIVIL ACTION - LAW : ACTION FOR DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF 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 if I 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. Section 4904 relating to unsworn falsification to authorities. OS- DATE AZAH M. ABDALLA C7 +v ^C? C -n Azah M. Abdalla Plaintiff V. Tarig Dafalla Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 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: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and Manner of service of the Complaint: Defendant signed Acceptance on 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, ; by Defendant, O 4. Related claims pending: There are no outstanding claims. 5. Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary:' Z I L:- (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: s- Plaintiff's Social'Security Number: (0q - -?b. ?D Defendant's Social Security Number: -bol- 1-830-L C? 4 a, Azah M. Abdal a ?? ?? C. 7.7 tt 'iJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. AZAH M. ABDALLA, PLAINTIFF No. 07-1994 VERSUS TARIG DAFALLA, DEFENDANT DECREE IN DIVORCE *44 41 AND NOW, • 0 2008 , IT IS ORDERED AND Azah M. AbMla DECREED THAT PLAINTIFF, AND TarigDafalla , 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. PROTHONOTARY frill