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HomeMy WebLinkAbout07-7137? R i Keri M. Falih Plaintiff V. Youssef Falih Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- ?137 CIVIL TERM : 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 Keri M. Falih Plaintiff V. Youssef Falih Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- '?J 3 7 CIVIL TERM IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is ??1 who currently resides at 11i P14. Cumberland County, Pennsylvania. 2. Defendant is ?6)cz--Se-P PM I , who currently resides at 3. Plaintiff has been a bona fade 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 Rug ?i ace k at 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of N/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. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. ?1- a? aa - -ba L- m ja? Date Plaintiff, Pro Se I, L? -6 M Ta v t11 , 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. kVr4k - ama Date: hnt-ml Plaintiff, Pro Se Assisted by: Barbara Sumple-Sullivan, Esq. Law Firm of Barbara Sumple-Sullivan 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 .A6 Keri M. Falih IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 7,(37 CIVIL TERM Youssef Falih 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. C? rv J ?? C'I i i s ? ._ ltJ ) ? r- f ? a r'x t-. yy 1 . , Keri M. Falih Plaintiff V. Youssef Falih Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 7/3 7 CIVIL TERM IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Keri M. Falih, Plaintiff, to proceed in forma au ens. I, Barbara Sumple-Sullivan, 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. Attorney for Plaintiff Law Firm of Barbara Sumple-Sullivan 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 ' C7 C = p -n ° N 1 1 b :nv _ owBe Keri M. Falih, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 07-7137 CIVIL TERM Youssef Falih, Defendant IN DIVORCE PRAECIPE TO RE-INSTATE TO THE PROTHONOTARY: Please re-instate the Complaint filed in the above-captioned matter. Respectfully submitted, Dated: Janu IV , 2008 8arbara Sumple-Sullivan, Esquire 749 Bridge Street New Cumberland, PA 17070-1931 (717) 774-1445 Supreme Court I.D. No. 32317 L-71 Keri M. Falih Plaintiff V. Youssef Falih Defendant s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 713-7 IN DIVORCE CIVIL TERM NOTICE TO DEFEND AND CLAIM RIGHTS v O =r C:) i N =r? ?% 0 -1 ?Y 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. i Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Keri M. Falih Plaintiff V. Youssef Falih Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO.07-fit 3'7 CIVIL TERM IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is ??(1 altvn , who currently resides at Cumberland County, Pennsylvania. 2. Defendant is ?6)?segPMI? , who currently resides at 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 Ruo 00 1 at 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of A/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. r a 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. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. a in kor? r Mir, Date Plaintiff, Pro Se r (? i I, K er.?, M kI y 111 , 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. Date: Plaintiff, Pro Se Assisted by: Barbara Sumple-Sullivan, Esq. Law Firm of Barbara Sumple-Sullivan 549 Bridge Street New Cumberland, PA 17070 (717) 774-1445 0 a Keri M. Falih IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- l 3'1 CIVIL TERM Youssef Falih 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. :+? r,? `? ? .:? '_ ?> r? _?,7 ? r ?T +.::; ~?? r "J ?? ? ._ ` i i:?z . - - i ' t ? ? ? Keri M. Falih Plaintiff V. Youssef Falih Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 07- 7137 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 and Acknowledgment of Service form on January 31, 2008 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, May 29, 2008 ;by Defendant, May 20, 2008 4. Related claims pending: There are no outstandin clg aims. 5. Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: May 30, 2008. (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: May 30, 2008 Dated: May 29, 2008 a Sumple-Sullivan, Esquire for Keri M. Falih C?7 _ c3 -ry 77r .w: Keri M. Falih IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- -7 /6 7 CIVIL TERM Youssef Falih Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Youssef Falih (Defendant), accepted service of a true and correct copy of the Complaint in Divorce under section 3301 (c) of the Divorce Code on the date written below. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. 671-31,00 Date 1.17 Wl Gfl .' Keri M. Falih IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 7137 CIVIL TERM Youssef Falih Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on November 29, 2007 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety 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 divorce. 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 o 18 a. S. Section 4904 relating to unsworn falsification to authorities. Date: 62 Signature: Youssef F 1h, De ndant td j? (2, = co `s-) --z n7 -r Cl) Keri M. Falih IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 7137 CIVIL TERM Youssef Falih 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 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 unswom falsification to authorities. F Date: 09 Signature: Youssef alih, Defer ant 71 'Ift. Keri M. Falih IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 7137 CIVIL TERM Youssef Falih : Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on November 29, 2007 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety 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 divorce. 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 authoriti s. Date: 5/29/08 Signature: Keri M. Falih, Plaintiff ? , ?-., ' ,, ? - _ . -_ ?: c?::> _ ,'_ >> ? . , =, ?? "?, ?, ;.? Keri M. Falih IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 07- 7137 CIVIL TERM Youssef Falih 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 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: 5/29/08 Signature: Keri M. Falih, Plaintiff CD IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. a - KERI M. FALIH, r Plaintiff VERSUS YOUSSEF FALIH, No. Defendant 07 - 7137 DECREE IN DIVORCE ? Zoog w-?- , , IT IS ORDERED AND AND NOW, 3 Keri M. Falih DECREED THAT PLAINTIFF, Youssef Falih AND , 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.000RT A TT PROTHONOTARY 4?v 7- rV-7 0