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Home My WebLink About08-4874F ATEF MOHAMED HUSSEIN, Plaintiff V. JENNIFER LYNN ENGEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 7y 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 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 grounds for divorce are indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of the marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, Pennsylvania 17013 717.249.3166 ATEF MOHAMED HUSSEIN, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0 g- - qqg 7 y c rv I C t, JENNIFER LYNN ENGEL, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE NOW COMES the Plaintiff, Atef Mohamed Hussein, by and through his attorney, Robert T. Balaban, Esquire, and brings this Complaint in Divorce and in support thereof avers: 1. Plaintiff is Atef Mohamed Hussein, who currently resides at 238 Henderson Street, Carlisle, County of Cumberland, Commonwealth of Pennsylvania. 2. Defendant is Jennifer Lynn Engel, whose last known address is 104 S. Locust Street, Shiremanstown, County of Cumberland, Commonwealth of Pennsylvania. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant are husband and wife and were lawfully married on April 15, 2004, in Harrisburg, Dauphin County, Commonwealth of Pennsylvania. 5. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 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. 8. Plaintiff and Defendant are without any children. COUNTI REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 9. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the filing of this Complaint, Plaintiff respectfully requests this Honorable Court to enter a Decree of Divorce, pursuant to Section 3301(c) of the Divorce Code. COUNT II REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(d) OF THE DIVORCE CODE 11. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 12. At the appropriate time, Plaintiffmay submit an affidavit alleging that the parties have lived separate and apart for at least two (2) years. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree of Divorce, pursuant to Section 3301(d) of the Divorce Code, at the appropriate time. Respectfully submitted, Dated: M0612,aoL / - 4A_ Robert T. Balaban, Esquire 27 N. Front Street Harrisburg, PA 17101 717.920.9565 Attorney for Plaintiff 2 VERIFICATION I, Atef Mohamed Hussein, verify that the statements made 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 made are subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Dated: o$ • 06 • o RzV-E \lvSSm N Atef Mohamed Hussein N v V N C_ c c`7 z Q 4-jf,[- ?U?3FITAJ VS. & (r? L In the Court of Common Pleas of Cumberland County, Pennsylvania No. U? 1 Civil. 19 ? etifil 4- To Prothonotary 19 Attorney for Plaintiff O"ARY SE 12, 9: 12 to 4 ?cL A KJ- No. Term, 19 vs. PRAECIPE Filed 19 Atty. Aj, Ei, VS. ti F (Y-F2- (- In the Court of Common Pleas of Cumberland County, Pennsylvania No. 'U? Civirg2 e7 To Prothonotary 19 Attorney for Plaintiff fit No. 2000 OCT r r W _ t ?ti ,f1Ay '4Ey o S-u ? 41 Filed Term, 19 vs. PRAECiPE 19 Atty. S VS. ! L f?4 d rL l2? To In the Court of Common Pleas of Cumberland County, Pennsylvania No. - L - U zt Civil. M OU Z. oUf Prothonotary 19 _ Attorney for Plaintiff 4- -T ,A-?- l3A/,-' No. Term, 19 --- vs. PRAECYPE 19 Filed Atty. i -- ! 7T °C1 ATEF MOHAMED HUSSEIN, Plaintiff V. JENNIFER LYNN ENGEL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-4874 Civil Term CIVIL ACTION - LAW IN DIVORCE Praecipe to Reinstate Complaint To: Dated: Curtis R. Long, Prothonotary Kindly reinstate the above-captioned Complaint. Respectfully submitted, 1216) 266 8 ? -- Robert T. Balaban, squire PA I.D. No. 68920 27 N. Front Street Harrisburg, PA 17101 717.920.9565 Attorney for Plaintiff d ? ? 5L, 8 '?'?.....Y-'. r!? ?. r' ???. D '? ?-? r.s ?? ?_ .?' '?'?? ? f . 4`k <__. ? ?'?' iv ,,,? -< 1t . k ATEF MOHAMED HUSSEIN, Plaintiff V. JENNIFER LYNN ENGEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-4874 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Jennifer Lynn Engel, hereby accept service of the "Complaint in Divorce." I certify that I am the Defendant in the above-captioned matter and have hereby accepted service of this Complaint. Respectfully submitted, Dated: 12- 111 1zoo 5 By _4jtftm? Je fer L Engel 99 Dogwood Lane Dillsburg, PA 17019 C. - f ATEF MOHAMED HUSSEIN, Plaintiff V. JENNIFER LYNN ENGEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-4874 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that I am this day serving a true and correct copy of the foregoing document upon the person and in the manner below indicated. Service By First Class U.S. Mail, Postage Prepaid, Addressed As Follows: Robert T. Balaban, Esquire 27 N. Front Street Harrisburg, PA 17101 Dated: l Z 1 L S 12V u g Respectfully submitted, By Jennifer LyFm Enge ,o Se 99 Dogwood Lane Dillsburg, PA 17019 t-.? c, ,_s C'? ?? ;^+,? _... . r °M? . ?, '' `„`" ATEF MOHAMED HUSSEIN, Plaintiff V. JENNIFER LYNN ENGEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-4874 Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 14, 2008 and this complaint in divorce was reinstated on September 12, 2008, October 10, 2008, November 07, 2008 and December 05, 2008, and was subsequently served upon the Defendant on or about December 15, 2008 and the acceptance of service was filed on December 22, 2008 before this Honorable Court. 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 on the Defendant. 3. I consent to the entry of a final decree of divorce either after service of a "Notice of Intention to Request Entry of the Decree" or upon the filing of the "Waiver of the Notice of Intention to Request Entry of the Decree." 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and I do not request that the Court require my spouse and I to participate in counseling prior to the divorce becoming final. a FILED-v Ir , , ? .. OF *PH"' OTARY 2009 AFIR 23 AM I0: 0 4 is ATEF MOHAMED HUSSEIN, . Plaintiff V. JENNIFER LYNN ENGEL, . Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-4874 Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 14, 2008 and this complaint in divorce was reinstated on September 12, 2008, October 10, 2008, November 07, 2008 and December 05, 2008, and was subsequently served upon the Defendant on or about December 15, 2008 and the acceptance of service was filed on December 22, 2008 before this Honorable Court. 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 on the Defendant. 3. I consent to the entry of a final decree of divorce either after service of a "Notice of Intention to Request Entry of the Decree" or upon the filing of the "Waiver of the Notice of Intention to Request Entry of the Decree." 4. I have been advised of the availability of marriage counseling and understand that the Court maintains a list of marriage counselors and that I may request the Court to require my spouse and I to participate in counseling and I do not request that the Court require my spouse and I to participate in counseling prior to the divorce becoming final. W. 5. 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. I verify that the statements made in this affidavit are true and correct. I understand that false falsification to authorities. Dated: 'l / _? Amu ?' -,(:L Je 'fer L Enge 80 Mohn Street, Apt. #2 Harrisburg, PA 17113-2076 Defendant statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unworn 2 ? q i.r? V? I !_ OF i { E i ^i i? HE 2009 AP 23 A,'-,110: 05 z a, a 1. U l ATEF MOHAMED HUSSEIN, Plaintiff V. JENNIFER LYNN ENGEL, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 08-4874 CIVIL TERM 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 unworn falsification to authorities. Dated: By I]kl?t-t SSPiN 4 ! o b J G? Atef Mohamed Hussein 238 Henderson Street Carlisle, PA 17013 Plaintiff FILED- ; ?; OF THE Pr ", :Y"OTARY 2009 APR 23 z i 10: 05 JIA ATEF MOHAMED HUSSEIN, Plaintiff V. JENNIFER LYNN ENGEL, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, : PENNSYLVANIA : NO. 08-4874 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §33010 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. i ? Dated: By R'?C Je eL Engel ,1 7 2/, 802 Mohn Street, Apt. #2 Harrisburg, PA 17113-2076 Defendant FILE -,(, « ?u nil: THr 71,? 2009 APR 23 Ali' 10: 05 ATEF MOHAMED HUSSEIN, Plaintiff V. JENNIFER LYNN ENGEL, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, . PENNSYLVANIA . NO. 08 - 4874 Civil Term CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To: Curtis L. Long, Prothonotary: Kindly transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Grounds for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on December 15, 2008 and acceptance of such service was filed with this Court on December 22, 2008. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code was made by the Plaintiff on April 06, 2009 and by the Defendant on April 04, 2009. 4. No related claims are pending. 5. Plaintiff's Waiver of Notice was filed with the Prothonotary on April 23, 2009 and Defendant's Waiver of Notice was filed with the Prothonotary on April 23, 2009. DATED: 044V 12004 Respectfully submitted, Robert T. Balaban, Esquire 27 N. Front Street Harrisburg, PA 17101 717.920.9565 Attorney for Plaintiff IMY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ATEF MOHAMED HUSSEIN V. JENNIFER LYNN ENGEL NO. 08 - 4874 CIVIL TERM DIVORCE DECREE AND NOW, dI , it is ordered and decreed that ATEF MOHAMED HUSSEIN plaintiff, and JENNIFER LYNN ENGEL , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. Prothonotary E Attest: J ?'? •C?s node ?,??D? ? A