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Home My WebLink About08-0956KENNETH F. LEWIS, ESQUIRE I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DANIEL DOLAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. c0g? 9S? SOMJIT DOLAN, CIVIL ACTION Defendant DIVORCE/CUSTODY 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 at: 1 Courthouse Square, Carlisle, PA 17013 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 OR (800) 990-9108 DANIEL DOLAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA SOMJIT DOLAN, CIVIL ACTION Defendant DIVORCE/CUSTODY COMPLAINT FOR DIVORCE & CUSTODY A-W4. a au-Iau1L ulvorce Under 6 of the Domestic Relations Code 1. Plaintiff is DANIEL DOLAN, who currently resides at 2001 Rupley Road, Apt. #106, Camp Hill, Cumberland County, PA 17011. 2. Defendant is SOMJIT DOLAN, who resides at 1206 Richmond Drive, Stafford, VA 22554. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 21, 2003 in Thailand. 5. There have been no prior actions for divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. WHEREFORE, Plaintiff respectfully requests this Court to enter a Decree of Divorce pursuant to S 3301(c) of the Domestic Relations Code. COUNT II--= CUSTODY 8. Plaintiff hereby incorporates Paragraphs 1 through 7 of him Complaint as if fully set forth herein. 9. Plaintiff seeks shared legal and physical custody of the following children: ANGELINA DOLAN (born 8-9-01) and MARIA DOLAN (born 10-8-04). 10. For the last five years, the children have resided with the following parties at the address provided: dad address listed in paragraph #1 6/06-present dad/mom North 6th Street, Harrisburg 6/05-6/06 dad/mom Springford Drive, Harrisburg 6/04-6/05 dad/mom 1000 Harvard Rd, Monroeville, PA 12/03-6/04 11. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning the custody of the children in this or another court. 12. Plaintiff has no information of a custody preceding concerning the child pending in any Court of this Commonwealth. 13. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 14. The parties and the paternal grandparents have entered into a custody agreement which all believe is in the above- mentioned children's best interests. Plaintiff requests that the agreement be made an Order of Court and is submitting the agreement for the Court's approval concurrently with this Complaint. 15. Each parent whose parental rights to the children have not been terminated and the person who has physical custody of the children has been named as a party to this action. WHEREFORE, Plaintiff requests the Court to enter a custody Order pursuant to the parties' written agreement. OJOY 01h ` DATE. KEN TH F. LEWIS, ESQUIRE Att rney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff VERIFICATION I hereby verify that the statements made in the foregoing document are true and correct to the best of my knowledge, information and belief. 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: 1/3 o/0 a D NIE DOLAN R 'J cWt ? ? I t lJ ? ' ?S . CUSTODY STIPULATION AND NOW, this ?y h day of 3-an vaf , 2008, the I undersigned stipulate to the following provisions being made an order of Court: 1. PATRICK DAVID DOLAN, RITA DOLAN, DANIEL DOLAN and SOMJIT DOLAN shall share legal custody of ANGELINA DOLAN (born 8-9- 01) and MARIA DOLAN (born 10-8-04). 2. PATRICK DAVID DOLAN and RITA DOLAN, the paternal grandparents shall share primary physical custody of the children with the children's Father, DANIEL DOLAN. 3. Mother, SOMJIT DOLAN, shall have periods of partial physical custody at mutually agreed upon times. All the undersigned recognize the importance of the children maintaining strong relationships with their father, mother and paternal grandparents and will act accordingly with regard to permitting liberal visits and telephone contact. v WITNESS DANIEL DOLAN WITNESS WITNE S x ? )4: ? 2 TNESS SOMJI DOLAN i Ang&43?,-, PATRICK DAVID DOLAN RI DOLAN C? o n rrt r - -21 Q KKC U V FEB 18 DANIEL DOLAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND! COUNTY, PENNSYLVANIA V. NO. DR4 --15CJ ?lJ?{ SOMJIT DOLAN, CIVIL ACTION Defendant CUSTODY ORDER AND NOW, this /4" day of February, 2008, upon Stipulation attached hereto, it is Ordered and Decreed as follows: 1. PATRICK DAVID DOLAN, RITA DOLAN, DANIEL DOLAN and SOMJIT DOLAN shall share legal custody of ANGELINA DOLAN (born 8-9- 01) and MARIA DOLAN (born 10-8-04). 2. PATRICK DAVID DOLAN and RITA DOLAN, the paternal grandparents shall share primary physical custody of the children with the children's Father, DANIEL DOLAN. 3. Mother, SOMJIT DOLAN, shall have periods of partial physical custody at mutually agreed upon times. All the undersigned recognize the importance of the children maintaining strong relationships with their father, mother and paternal grandparents and will act accordingly with regard to permitting liberal visits and telephone contact. BY THE COURT: J. _,DISTRIBUTION: enneth F. Lewis, Esq., 1101 N. Front St., Hbg., PA 17102 ?omjit Dolan, 1206 Richmond Drive, Stafford, VA 22554 0-0 t l -v eroa c LFr-C .2"/2-0/408 tz-x) t? ? ?-?+'? r. ?? KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DANIEL DOLAN, SOMJIT DOLAN, Plaintiff V. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND /COUNTY, PENNSYLVANIA NO. 0 sb ci4Vi, I CIVIL ACTION DIVORCE/CUSTODY ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint. DATE: L- 1 (' Ch -sj SOMJI DOLAN 1206 Richmond Drive Stafford, VA 22554 '^ vzo { _Y RM KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DANIEL DOLAN, Plaintiff V. SOMJIT DOLAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 956 Civil CIVIL ACTION DIVORCE/CUSTODY AFFIDAVIT OF CONSENT 1. A Complaint in Divorce was filed under Section 3301 (c) of the Divorce Code on February 11, 2008. 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 in Divorce after service of notice to intention to request entry of the decree. 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: q- ob -- Z?iL DA E D LJ 0 N 4 1 KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DANIEL DOLAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08 - 956 Civil CIVIL ACTION DIVORCE/CUSTODY V. SOMJIT DOLAN, Defendant 1. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE I consent to 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 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. 4. I verify that the statements made in the foregoing document 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: ?' DANIEL DOLAN C? nV -? ??^; ? ?. ?... __ ? -? ??.s ?`:. ? ?? ? .???? ? KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DANIEL DOLAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08 - 956 Civil SOMJIT DOLAN, CIVIL ACTION Defendant DIVORCE/CUSTODY AFFIDAVIT OF CONSENT 1. A Complaint in Divorce was filed under Section 3301 (c) of the Divorce Code on February 11, 2008. 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. 1 consent to the entry of a Final Decree in Divorce after service of notice to intention to request entry of the decree. 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. .S- Dated: 9 SOMJI DOLAN 4 To, KENNETH F. LEWIS, ESQUIRE Attorney I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff DANIEL, DOLAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. . NO. 08 - 956 Civil SOMJIT DOLAN, CIVIL ACTION Defendant DIVORCE/CUSTODY WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. I consent to 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 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. 4. I verify that the statements made in the foregoing document 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: SOMJIT OLAN ti' DANIEL DOLAN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 08 - 956 Civil SOMJIT DOLAN, CIVIL ACTION Defendant DIVORCE/CUSTODY 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 W 3301(c) () 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of Service dated 2/16/08 and filed 3/3108. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code and Waiver of Notice of Intention to Request Entry of a Divorce Decree: by the Plaintiff on 9/10/08; by the Defendant on 9/8108 (all filed concurrently with this Praecipe. 4. Related claims pending: NONE, no economic relief requested in Complaint. DATED: 9/12/08 KE TH F. LEWIS, ESQ. Att me I.D. #69383 1101 North Front Street Harrisburg, PA 17102 (717) 234-3136 Attorney for Plaintiff C rv ` ig: co r €?i 4 yCl ? ? no 0 w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. QA N E!. No.Ot 9si 'V'I S00111T`pQ4Z DECREE IN DIVORCE AND NOW, fOf , IT IS ORDERED AND DECREED THAT IF1 POIAN PLAINTIFF, 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; lq/#q - -)04? f -O? pf;W2,1? ?kT