The URL can be used to link to this page

Home My WebLink About04-0468 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DZEVAD CELEBIC, Plaint/ff : : v. : CIVIL ACTION _ LAW : N0.2004_ AZRA JAHIC, : Defendant : : IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. I · followingpages, you must*o~- .... f you wish to defend aoai-o, ~,- , · "~c prompt action y,, .......... ~, .,,~, ute claims set forth in proceed without you . v,, ,~= warnea treat if you fail to do so, the case ma~ and a decree of divorce or annulment may be entered agains, --- - th - A judgment may also be entered aaainst , you oy e court. by the Plaintiff. Yo,,,~,,~^- '~ Y°U f°r any other claim or r .. = . , ..... y ~uae money or property or other rio, bts im,~,,~lef, ~reque°t.ed m these papers or vmitat/on of your children. o v,,~ ,ant *o you, including custody When the ground for the divorce is indignities or ' · you may request marriage counseling. A list irretrievable breakdown of the marriage, kept as a convenience to you and you are nolfbmoarriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is necessary arrangements and the co * ,,c ...... · trod. to choose a counselor fr · s, ,,~,~uuuaenng sessions are to be bo,--~ h ...... om the hst. All If you desire to pursue counseling, you must make your request for counseling · -,~ oy.~ uu and your spouse. days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling, within twenty (20) IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE NOT HAVE A LAWYER THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO 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 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DZEVAD CELEBIC, Plaintiff CIVIL ACTION - LAW v. NO. 2004- AZRA JAHIC, Defendant IN DIVORCE COMPLAINT IN DIVORCE AND NOW, this 4th day of February, 2004, comes Plaintiff, Dzevad Celebic, by and through his attorneys, Hanft & Knight, P.C., and files the following Complaint in Divorce, and in support thereof avers as follows: 1. The Plaintiff is Dzevad Celebic, who resides at 135 Center Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Azra Jahic, who resides at 91 Knoll Street, Waterbury, Connecticut 06705. 3. The Plaintiff and Defendant are sui juris, and Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania and has so been for a period of more than six (6) months immediately preceding the filing of this Complaint in Divorce. 4. The parties were married on December 24, 2002 in Waterbury, Connecticut. 5. The marriage is irretrievably broken. The foregoing facts are averred and brought under Section 3301(c) or 3301(d) of the Divorce Code of 1980, as amended. 6. The Plaintiff has been advised of the availability of counseling, and that the Plaintiff may have the right to request that the Court require the Parties to participate in counseling, and Plaintiff waives same. WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce, divorcing the Plaintiff from the Defendant. Respectfully submitted, HANFT & KNIGHT, P.C. Sean M. Shultz, Esquire Attorney ID No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 Attorneys for Plaintiff VERIFICATION The foregoing Complaint in Divorce is based upon information which has been gathered by my counsel in the preparation of the Complaint in Divorce. The language of the document is that of counsel and not my own. I have read the Complaint in Divorce and to the extent that the document is based upon information which I have given to my ounsel, it is true and correct to the best of my knowledge, information and belief. To the extent tha of counsel, ~the content of the document is that I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if I make knowingly false averments, I may be subject to criminal penalties. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DZEVAD CELEBIC, Plaintiff CiVIL ACTION - LAW v. NO. 2004- 468 AZRA JAHIC, Defendant 1N DIVORCE ACCEPTANCE OF SERVICE I, Azra Jahic, the Defendant in the above captioned matter, hereby accept service of the Complaint in Divorce filed on February 4, 2004, in the above captioned matter. Azl~JJahic Dated: k'-~b IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DZEVAD CELEBIC, : Plaintiff : CIVIL ACTION - LAW : v. : NO. 2004-468 CIVIL TERM : AZRA JAHIC, : IN DIVORCE Defendant : AFFIDAVIT OF CONSENT STATE OF PENNSYLVANIA ) : SS. COUNTY OF CUMBERLAND ) 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 4, 2004. 2. The marriage of Plaintiffand 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 the Decree. 4. 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 prior to a Divorce Decree being handed down by the Court. I verifij 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 unswom falsification to authorities. Dzevad Celebic Sworn to and subscribed before me lhis ] 5'P"--" AlaY ° f ,-'~'X I'.,/ ,2004. I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DZEVAD CELEBIC, Plaintiff CIVIL ACTION - LAW v. : NO. 2004-468 CIVIL TERM : AZRA JAHIC, : IN DIVORCE Defendant : AFFIDAVIT OF CONSENT STATE OF ~_.~['~ ) COUNTYOF /~r..J ~,,~ ) 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on February 4, 2004. 2. The marriage of Plaintiffand 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 ora final Decree of Divorce after service of notice of intention to request entry of the Decree. 4. 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 prior to a Divorce Decree being handed down by the Court. 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 unswom falsification to authorities. S~y, em-'T~'~d sub.scribed before me this otary Public ~ "-''"'~':" ' :~"~ ....... z 7. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DZEVAD CELEBIC, : Plaintiff : CIVIL ACTION - LAW : v. : NO. 2004~468 CIVIL TERM .' AZRA JAHIC, : IN DIVORCE Defendant : WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRV OF A DIVORCE DECREE UNDER ~3301(C) OF THE DIVORCE CODE 1. I consent to the entry ora final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 veri~ 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: ~11~/0~ 'Dzevad Celebic IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DZEVAD CELEBIC, : Plaintiff : CIVIL ACTION - LAW : v. : NO. 2004-468 CIVIL TERM : AZRA JAHIC, : IN DIVORCE Defendant : WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER t~3~1(CI OF THE DIVORCE CODE 1. I consent to the entry ora final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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:-~l'~/oe,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DZEVAD CELEBIC, : Plaintiff : : CIVIL ACTION - LAW v. : NO. 2004-468 : AZRA JAHIC, : Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORn To the Prothonotary: Please transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: irrelxievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner ofservice of the Complaint: hand delivery to Defendant on February 7, 2004. 3. Date of execution of the Plaintiff's Affidavit of Consem required by Section 3301 (c) of the Divorce Code; July 15, 2004; by the Defendant; July 7, 2004. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: July 20, 2004. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: July 20, 2004. Date: July 19, 2004 Attorney I.D. No. 90946 19 Brookwood Avenue, Suite 106 Carlisle, Pennsylvania 17013-9142 (717) 249-5373 F~Us~rFold~.Fitm Docs'GmdocsC'O04~34all.lpm~cipc.wpd Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of ~ PENNA. i~ Er-AD Plaintiff N o. 2004-468 VERSUS AZPA JAHICw Defe~nt DECREE IN DIVORCE AND NOW,~ ~'E" 2004 , It IS ORDERED AND DECREED THAT DZEV'AD r'k-~,'k"~RT(~ __, PLAINTIFF, AZP, A J'AHIC 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; / BY THE COURT: / )TARY