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Home My WebLink About08-3866I? ?j KULWANT KAUR, Plaintiff VS. HARJIT SINGH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. D? - 38(0(0 Civi i ?Gr'llrt : 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 action. You are warned that, if you fail to do so, the case may proceed without you and a decree of divorce or annulment 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, One 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. LAWYER REFERRAL SERVICE of the Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone (800) 990-9108 KULWANT KAUR, Plaintiff VS. HARJIT SINGH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. : CIVIL ACTION - LAW : IN DIVORCE AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas seguientes, debe tomar accion con prontitud. se le avisa que si no se defiende, el caso pude proceder sin usted y decreto de divorcio o anulamiento puede ser emitido en su contra por las Corte. una decision puede tambien ser emitida en su contra por caulquier otra queja o compensacion eclamados por el demandante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County, One Courthouse Square, Carlisle, PA 17013. SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMTIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SO NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. LAWYER REFERRAL SERVICE of the Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telefono (800) 990-9108 r KULWANT KAUR, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. :NO. 0,F- 3P?. 4 P 7"Z, HARJIT SINGH, : CIVIL ACTION - LAW Defendant : IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes Plaintiff, Kulwant Kaur, by and through her counsel, Linda A. Clotfelter, Esquire, who files this Complaint in Divorce and in support thereof states the following: 1. Plaintiff is Kulwant Kaur, (hereinafter referred to as "Plaintiff'), an adult individual who resides at 77 Honeysuckle Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant is Hadit Singh, (hereinafter referred to as "Defendant"), an adult individual who resides at 44 Bayberry Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. The parties have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this divorce Complaint. 4. Plaintiff and Defendant were married on January 28, 2003, in Cumberland County, Pennsylvania. 5. The parties have been separate and apart within the meaning of the Pennsylvania Domestic Relations Code since June 10, 2008. 6. There are no pending divorce proceedings upon the filing date of this Complaint. 7. Plaintiff avers that the marriage is irretrievably broken. 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 to participate in counseling. Plaintiff does not desire counseling. 9. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff respectfully requests that this Court enter a Decree of Divorce and grant such other relief as this Court deems just and proper. Date: (Y. Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER J da A. Clotfelter, Esquire orney ID No. 72963 5021 East Trindle Road, Suite 1 Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile Attorney for Plaintiff VERIFICATION I, KULWANT KAUR, verify that the statements in the foregoing COMPLAINT IN DIVORCE 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. § 4904, relating to unworn falsification to authorities. Date: b 12 ?1 10 zvv ? KULWANT KAUR, Plaintiff Ix rr 0 w KULWANT KAUR, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. :NO. 08-3866 CIVIL TERM HARJIT SINGH, : CIVIL ACTION - LAW Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, HARJIT SINGH, Defendant in the above-captioned matter, hereby accept service of the Complaint Under Section 3301(c) or 3301(d) of the Domestic Relations Code. Date: ? e 4-6 00 Harjit S' gh, Defendant 44 Bayberry Drive Mechanicsburg, PA 17050 KULWANT KAUR, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 08-3866 CIVIL TERM HARJIT SINGH, : CIVIL ACTION - LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this I day of July, 2008, the undersigned hereby certifies that a true and correct copy of the foregoing ACCEPTANCE OF SERVICE was served upon the opposing party by United States First Class Mail, postage prepaid as follows: Harjit Singh 44 Bayberry Drive Mechanicsburg, PA 17050 Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER By: A?/- S. on A. She r, P al 5021 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile C J ?, ?ffL C d .^ L a.Xb dam' £? --?- .? { a KULWANT KAM : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 08-3866 HARJIT SINGH, : CIVIL ACTION - LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed June 30, 2008. 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 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. Section 4904, relating to unsworn falsification to authorities. Date: l Kol KULWANT KAUR, Pla tiff r7 e,T± ?- } .:r ..ru .sr?i KULWANT KAUR, Plaintiff VS. HARJIT SINGH, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-3866 CIVIL ACTION - LAW : 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. //--Z?- Date: 16 )(Ito KULWANT KAUR, Plaintiff c'3 _ ??,. ?` c °a ---? ? --r, ?. =`-:; . _ ., . . .. ?? -?. r.. ?,.,; KULWANT KAUR, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 08-3866 HARJIT SINGH, : 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 June 30, 2008. 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 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. Section 4904, relating to unworn falsification to authorities. of d.,& .4 Date: HARJIT S GH, Defen t D :L., r; KULWANT KAM Plaintiff VS. HARJIT SINGH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 08-3866 : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 4 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 unworn falsification to authorities. Date: Jim HARJIT S GH, Defendal? yam") ?,: ..+..,? tiv-? am' ?4 '?' << C --^l _? ?^ #»•?? CX7 -.} 1. ' y +z ??n „«?;, -," ? ; C1 'i ?~ ..i1 KULWANT KAUR, Plaintiff VS. HARJIT SINGH, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-3866 : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Kindly transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. The ground for divorce is irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. The Complaint was filed on June 30, 2008. 3. Date and manner of Service of the Complaint: July 6, 2008, by Acceptance of Service filed on July 9, 2008. 4. The Plaintiffs Affidavit of Consent was executed by the Plaintiff on October 19, 2008, and filed on October 28, 2008. The Defendant's Affidavit of Consent was executed on October 18, 2008, and filed on October 28, 2008. 5. Plaintiff executed a Waiver of Notice of Intention to Request Entry of a Divorce Decree under 3301 (c) of the Divorce Code on October 19, 2008, and said waiver was filed on October 28, 2008. Defendant executed a Waiver of Notice of Intention to Request Entry of a Divorce Decree under 3301 (c) of the Divorce Code on October 18, 2008, and said waiver was filed on October 28, 2008. 6. There are no related claims pending. Respectfully submitted, FIRM OF LINDA A. CLOTFELTER Date: 11 ? d L da A. Clotfelter, Esquire A orney I.D. No. 72963 21 East Trindle Road, Suite 100 Mechanicsburg, PA 17050 (717) 796-1930 telephone (717) 796-1933 facsimile 1? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. KULWANT KAUR Plaintiff VERSUS HAFM SINGH Defendant No. 08-3866 DECREE IN DIVORCE AND NOW, ?6V l 2008 IT IS ORDERED AND KULWANT KAUR DECREED THAT AND HARJIT SINGH ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, 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. -- kvx V. v,P , sue vim'"" ..o, ,