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Home My WebLink About04-0226~kDA~4M. HOROWITZ, Plaintiff vs. GULNOR3% HOROWITZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 04- ~ CIVIL TERM IN DIVORCE NOTICE TO DEFEND ~ 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 the divorce is indignities or irretrievable breakdow~ of the marriage, you may request marriage counselling. A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County Courthouse, 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 GPJtNTED, 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 ADA_MM. HOROWITZ, Plaintiff vs. GULNORA HOROWITZ, Defendant : 04- aX& CIVIL TERM : IN DIVORCE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW COMPLAINT UNDER SECTION 3301(c) or $301(d) OF THE DIVORCE CODE Carlisle (North Pennsylvania 17013 since United States Air Force Force Base, Virginia. Ai~D NOW, comes the Plaintiff, Adam M. Horowitz, by his attorney, Dale F. Shughart, Jr. and states the following complaint. 1. The Plaintiff is Adam M. Horowitz, an adult individual, whose legal residence and place of domicile is 75 Chester Street, Middleton Township), Curaberland County, 1985. Plaintiff is currently in the on active duty assigned to Langley Air 2. The Defendant is Gulnora Horowitz, an adult individual, whose legal residence and place of domicile is 75 Chester Street, Carlisle (North Middleton Township), Cumberland County, Pennsylvania 17013 since June, 2001. Her current military address is 502 Derby Run, Yorktown, Virginia 23693. 3. Plaintiff and Defendant have both been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 17, 2001 in Tashkent, Uzbekistan. 5. There have been no prior actions annulment between the parties. 6 o marriage request counselling. WHEREFORE, of Divorce. of divorce or for The marriage is irretrievably broken. The Plaintiff has been advised of the availability of counselling and that the Plaintiff may have the right to that the court require the parties to participate in the Plaintiff requests the Court to enter a Decree I verify that the statements made in this Complaint 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: ;~ ~A/ 2004 Carlisle, PA 17013 (717) 241-4311 Attorney I.D. 19373 203 SHERIFF'S RETURN - U.S. CASE NO: 2004-00226 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND HOROWITZ ADAM M VS. HUROWITZ GULNOR-A CERTIFIED MAIL R. Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEPENDANT ,HUROWITZ GULNORA by United States Certified Mail postage prepaid, on the 16th day of January ,2004 at 0000:00 HOURS, at 502 DERBY RUN YORKTOWN, VA 23693 , a true and attested copy of the attached COMPLAINT - DIVORCE Together with , The returned receipt card was signed by SIGNATURE ILLEGIBLE 01/20/2004 Additional Comments: on Sheriff's Costs: Docketing 18.00 Service 4.42 Affidavit .00 Surcharge 10.00 .0O 32.42 Paid by DALE F SHUGHART JR Sworn and subscr~d to before me this 2'~~ day ~3D~ A.D. ~rbthonotary Sheriff of Cumberland County on 01/23/2004 ADAM M. HOROWITZ, SSN: 600-10-9363 GULNORA HOROWITZ, SSN: 240-97-3610 Plaintiff, Defendant. IN THE COURT OF COMMON PLEAS OF' CUMBERL4kND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 04 -226 CIVIL TERM IN DIVORCE MOTION TO CONTEST JURISDICTION. COMES NOW the Defendant appearing specially to contest jurisdiction in states as follows: 1. Parties were married in Tashkent, Uzbekistan in May 17, 2001. 2. The Parties have cohabitated in Yorktown, Virginia since August 1, 2002 up to and including current time, and own a home, as well as marital property located in Virginia. 3. Defendant is not a resident or domiciliary of Pennsylvania. Since arriving in the United States on June 29, 2001, the Defendant has resided in Virginia. 4. Defendant has filed a Bill of Complaint seeking a divorce in Circuit Court for the County of York, Commonwealth of Virginia (see attached). 5. Your Plaintiff claims Pennsylvania as tUs home state for military purposes, but is actually a domiciliary of Commonwealth of Virginia (and has been for the past two years). 6. The Circuit Court for the County of York,, Virginia has personal jurisdiction over both the Plaintiff and the Defendant and the subject matter jtcrisdicfion over the properties of the parties. 7. Commonwealth of Pennsylvania is not a convenient forum for the Defendant and Pennsylvania lacks personal jurisdiction over the Defendant. Wherefore your Defendant, appearing specially to contest jun'sdiction, prays that Plaintiff s Complaint under Section 3301 be dismissed. By 502 Derby ~wn, Virgnia 23693 Tel (757) 254-4023 Attorney Captain Kathleen J. Hartman 33 Sweeney Blvd., Langley AFB, Virginia 23665 Tel (757) 764-3280 CER TIFIC~I TE I, Gulnom Horowitz, do hereby certify that the lxue copy of the above Motion was mailed to Dale F. Shughart, Jr., this r~-~ day of February, 2004. ADAM M. HOROWITZ, Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW GULNORA HOROWITZ,: Defendant NO. 04-226 CIVIL TERM ORDER OF COURT AND NOW, this 15th day of March, 2004, upon consideration of Defendant's Motion To Contest Jurisdiction, a Rule is hereby issued upon Plaintiff to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, ~/Dale F. Shughart, Jr., Esq. 35 East High Street Suite 203 Carlisle, PA 17013 Attorney for Plaintiff ~'Gulnora Horowitz 502 Derby Run Yorktown, VA 23662 Plaimiff, Pro Se ~rCaptain Kathleen J. Hartman 33 Sweeney Blvd. Langley AFB, VA 23665 XIq~sley Oler~r., '/~- J. :rc ADAM M. HOROWITZ, Plaintiff vs. GULNORA HOROWITZ, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 04-226 CIVIL TERM IN DIVORCE Dear Sir: Plaintiff, Adam M. DISCONTINUANCE Horowitz is a legal resident of the Commonwealth of Pennsylvania serving on active duty in the United States Air Force, currently stationed in the Commonwealth of Virginia. Said Plaintiff has, nevertheless, agreed to submit to the jurisdiction of the Commonwealth of Virginia as a more convenient forum for litigation of a divorce and other matters in issue between him and the Defendant, Gulnora Horowitz. Based upon the foregoing, the above captioned action is hereby discontinued. Re spe ct fully su~l~i~ted, ~ug~ha' Carlisle, PA 17013 (717) 241-43ll Attorney for Adam M. Horowitz CC: Honorable J. Wesley Oler, Jr. Capt. Kathleen J. Hartman, Attorney 33 Sweeney Boulevard Langley AFB, Virginia 23665 Marc P. Messier, Esquire, 305 Main Street Newport News, Virginia 23601 for GuZLnora Horowitz ADAM M. HOROWITZ, Plaintiff GULNORA HOROWITZ,: Defendant : 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 04-226 CIVIL TERM ORDER OF COURT AND NOW, this 26th day of March, 2004, upon consideration of Defendant's Motion To Contest Jurisdiction and of the Discontinuance filed on behalf of Plaintiff, Defendant's motion is deemed moot and the Rule issued by this court on March 25, 1004, is discharged. Dale F. Shughart, Jr., Esq. 35 East High Street Suite 203 Carlisle, PA 17013 Attorney for Plaintiff Gulnora Horowitz 502 Derby Run Yorktown, VA 23693 Defendant Courtesy copies: Marc P. Messier, Esq. 305 Main Street Newport News, VA 23601 BY THE COURT, J. Wesley Oldie., J. Kathleen J. Hartman, Esq. 33 Sweeney Blvd. Langley AFB, VA 23665 :re