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Home My WebLink About07-6076LAW OFFICES OF ROBERT S. MIRIN DEBRA R. MEHAFFIE, ESQUIRE Attorney I.D. No. 90951 2515 North Front Street Harrisburg, PA 17110 Telephone No. (717) 909-9900 Fax No.: (717) 561-1616 SUSQUEHANNAna comcast.net Attorney for Arthur E. Osipov, Plaintiff ARTHUR E. OSIPOV Plaintiff vs. SVETLANA OSIPOV, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 87- l007 42 iu ? l - CIVIL ACTION - LAW 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 be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property rights 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, One Courthouse Cquare, Carlisle, Pennsylvania 17013-3387. FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS DIVORCE OR ANNULMENT IS GRANTED, YOU MAY IGHT TO CLAIM ANY OF THEM. ER TO YOUR LAWYER AT ONCE. IF YOU DO NOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE 1D OUT WHERE YOU CAN GET LEGAL HELP. iA 'and County Bar Association 32 S. Bedford Street Pennsylvania 17013-3302 (717) 249-3166 • r ARTHUR E. OSIPOV Plaintiff vs. SVETLANA OSIPOV, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION - LAW IN DIVORCE 3AMETbTE, 4TOBbl 3ALL114TMTb VI TPEBOBATb IIPAB BaM npegbABVInM 14CK B Cyge. Ecnm Bbl wenaere 3aU4MTMTb np0TAB Tpe6oBaHWA, CC?0pMynNp0BaHHbIX B cnegpoulm CTpaHMLIax, Bbl ,gOnNCHbI npe,gnpMHATb 6bICTpoe ,geOCTBme. Bbl npe,gynpe>KgeHbl, 4TO, ecnm Bbl He B COCTOAHMM C,genaTb TaK, Cny4ak MOHCeT 66ITb BBegeH npOTMB Bac qnq mo6oro ,gpyroro Tpe60BaHL4A M4 noMoL414, KOTOpyK) Tpe6y10T B 3Tmx 6yMaraX VICTLIOM. Bbl MONCeTe n0TepATb ,geHbrL4 NnL4 npaBa C06CTBeHHOCT14 mnm ,gpyrme npaBa, BaAHble ,qnA BaC, BKMo4aA xpaHeHHe imm noceu4eHi4e Bawmx geTeA. Korga OCHOBaHme AnA pa3Boga - Heysa)KeHme Hnvl HeBocnonHwmoe paCCTpOACTBO 6paK, Bbl MONCeTe npOC14Tb peKOMeH,gaLAmto 6paKa. CnNCOK KOHCynbTaHTOB no 6pa4H0-ceMe0HbIM OTHoweHMAM ,gOCTyneH B ocpwce hpOTOHOTapmO, O,gV1H KBa,gpaT 3gaHMq cyga, Kapnavln, WTaT neHCVInbBaHV1A, 17013-3387. EC1114 Bbl HE PEFVICTPVIPYETE TPEBOBAHVIE K AMMEHTAM, PA3,gE11EHVIE COBCTBEHHOCTVI, f111AT A,gBOKATOB W1114 PACXO,gOB nEPE,g PA3BO,gOM, VIl10 AHHY11VIPOBAHME nPE,gOCTABJ1391OT, Bbl MCIXETE nOTEPATb nPABO TPEBOBATb MOSOFO VI3 HVIX. Bbl,gO11>KHbl B3ATb 3TY BYMAFY BAWEMY A,gBOKATY CPA3Y. EC11VI Bbl HE VIMEETE A,gBOKATA W114 MOXETE n03BO11VlTb CEBE O,gVIH, n00,g14TE B, VI11VI TE11EOOHMPYVITE 0014CY, COOPMYl1VIPOBAHHOMY HVUKE, 4T06bl Y3HATb, F,gE Bbl MO>KETE n011YHHTb K)PAQWL4ECKYK) nOMOLQb. KaM6epneHACKaA ACCOL maLlms KOPACTOB Fpac?CTBa 32 S. Beg(C OpCKaA YnmLAa KapnaHn, WTaT neHCVlnbeaHVIA 17013-3302 (717) 249-3166 n ARTHUR E. OSIPOV Plaintiff vs. SVETLANA OSIPOV, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. O2- G674 6wna- 22, CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) and (d) OF THE DIVORCE CODE 2 3 4 5 6. 7 The Plaintiff is Arthur E. Osipov, an adult individual who resides at 6 Richard Lane, Apartment No. 104, Camp Hill, Cumberland County, Pennsylvania 17011 and whose social security number is 182-74-3394. The Defendant is Svetlaua Osipov, an adult individual whose address is presently unknown, however it is believed that the Defendant resides in Dauphin County as she is employed as a housekeeper at the Sheraton Hotel, 4650 Lindle Road, Harrisburg, Dauphin County, Pennsylvania, 17111. The Defendant's social security number is unknown at this time. Plaintiff and Defendant were married on January 21, 2006 in Cheboksary, Russia. Plaintiff has resided in the Commonwealth of Pennsylvania for a period of at least six (6) months prior to this filing. Defendant is not a member of the Armed Services of the United States or its allies. Plaintiff is a citizen of the United States. It is believed that the Defendant is a resident of the United States and that she holds a green card that was issued on or about May 14, 2007. There have been no prior action for divorce filed in any jurisdiction. r 8. Plaintiff has been advised of the availability of marriage counseling, and has waived said right. 9. There are no minor children born of the marriage. 10. The parties have lived separate and apart since July 6, 2007. 11. Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken. WHEREFORE, Plaintiff respectfully requests that this Court enter a Decree of Divorce and grant such other relief as this Court deems just and proper. Respectfully submitted: LAW OFFICES OF ROBERT S. MIRIN 1D No.`90951 2515 N. Front Street Harrisburg, PA 17110 Tele: (717) 909-9900 Fax: (717) 561-1616 Susquehanna@comcast.net VERIFICATION I, Arthur E. Osipov, verify that the statements made in this Divorce Complaint are true Date: 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. !C, -/4 2007 Date Arthur E. Osipov, Plaintiff ?- ? ? W J rr1 i G, _GI"V1Ce ; Affi(??Y3f 0 Date: oCT _ lo 2-u07 Name: SVELTANA OSIPOVA Case # or File # 07-6076 (Civil - Divorce) I hereby certify that the above named or his/her authorized agent has been personally served with the following document(s): Divorce Complaint by: Vf handing a copy to named: [ ] handing a copy to an adult member of the family with whom he/she resides; or to an Adult person in charge of such residence; j ] handing a copy to the named's agent in charge of the named's place of business. [ ] handing a copy at the residence of the named: to the clerk or manager of the place of lodging at which he/she resides. [ ] handing a copy to who accepted service on behalf of the named and certifies by signature he/she is authorized to do so Signature . A T Strickler declares under penalty of perjury, under the laws of the United States of America, and pursuant to Rule 18 Pa. C.S ., Sec 4904, the forgoing information contained in the Affidavit of ervice is ttu a 8 G%Ok 2001 Si tore of S fficer Date/Time Served c . CONS TA lL A. TED STRICKLER DMPHIN MH 2?1Q? AYTE Qurv1. 1. A __ C3 C may'': tV '??C?= a w; i 14 ARTHUR E. OSIPOV IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 07-6076 - Civil Term SVETLANA OSIPOV, CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 15, 2007. 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 the intention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees and expenses if I do not claim them before a divorce is granted. 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 unworn falsification to authorities. Date: O? a? 20PA Svetlana Osipova, Defend 1 i..? APP ARTHUR E. OSIPOV IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 07-6076 - Civil Term SVETLANA OSIPOV, CIVIL ACTION - LAW Defendant 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 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. § 4904 relating to unsworn falsification to authorities. Date: D??oT/2oD? ?C/2? -?_T Svetlana Osipova, Defendan na t c.-^ cx) TI ril ARTHUR E. OSIPOV, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 07-6076 - Civil Term SVETLANA OSIPOVA, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1 • A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on October 15, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of the 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 unsworn falsification to authorities. Date Arthur E. Osipov, Plaintiff N r 4{ .> rr cr, ARTHUR E. OSIPOV, ainti : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 07-6076 - Civil Term SVETLANA OSIPOVA, : CIVIL ACTION - LAW Defendant : 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 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 Waiver of Notice are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. Date C?,?. ?? f . D 8 Arthur E. Osipov, Plaintiff {'? rv co 'a7 r ? - r- f A y ARTHUR E. OSIPOV, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 07-6076 - Civil Term SVETLANA OSIPOVA, : CIVIL ACTION - LAW 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: 1. Ground for divorce: Irretrievable breakdown under § 3301(c) of the Divorce Code. 2. Date and Manner of service of the complaint: By Constable, hand delivery on October 18, 2007. 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by Plaintiff May 21, 2008; by Defendant on April 7, 2008. 4. Related claims pending: None 5. Date Plaintiff's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: May 23, 2008. Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: May 1, 2008. -?-kq Date Lo ? for Arthur E. Osipov, Plaintiff ?, ?:, - ?? ?..::, . •- -t y ? -- K IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ARTHUR OSIPOV? Plaintiff NO. 07 6076 VERSUS SVETLANA OSIPOVA Defendant DECREE IN DIVORCE AND NOW, ?,rwc 3' , Zaa t , IT IS ORDERED AND DECREED THAT ARTHUR OSIPOV , PLAINTIFF, AND SVETLANA OSIPOVA ,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: 14 ATTES J. PROTHONOTARY . .,