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HomeMy WebLinkAbout09-0065 STAGY B. WOLF, ESQUIRE ATTORNEY ID N0.88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ANIS ABU-AIADEH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NICHOLE L. ABU-AIADEH, Defendant CIVIL ACTION -LAW N0.09 -~ ~ ~ CIVIL TERM IN DIVORCE NOTICE 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 in divorce or annulment maybe 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, 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 TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 .~ STAGY B. WOLF, ESQUIRE ATTORNEY ID N0.88732 10 WEST HIGH STREET CARLISLE PA 17013 tn7) tai-a436 ATTORNEY FOR PLAINTIFF ANIS ABU-AIADEH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NICHOLE L. ABU-AIADEH, Defendant CIVIL ACTION -LAW N0.09 - ~ ~ s CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(Cl OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Anis Abu Aiadeh, an adult individual residing at 829 Nesbit Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Nichole Abu Aiadeh, an adult individual residing at 829 Nesbit Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. The plaintiff and defendant have been residents of the Commonweahh of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on November 24, 2003, in Carlisle, Cumberland County, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievablybroken. 6. The plaintiff avers that he has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties and for such further relief as this Honorable Court may deem equitable and just. I verifythat 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. Section 4904, relating to unsworn falsification to authorities. A ~ tU , 2009 WOLF & WOLF .JICv~ u.A.~'' ~O , 2009 BY: STACY B. OLF, ESQUIRE Supreme Court ID #88732 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Attorney for Plaintiff ~. ~- W W c ~- ~ _~ --, ..ate ~- ~," :ter -~ `-?~ ~~ ._._ ~ r; -',1 ' 1 4?? ~i' ~> , _ ;, ~ . --e STAGY B. WOLF, ESQUIRE ATTORNEY ID N0.88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ANIS ABU-AIADEH, v. PlaintiR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NICHOLE L. ABU-AIADEH, Defendant N0.09 -~YD ~ ~ CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being dulysworn according to law, deposes and says: 1. I have been advised of the availability of Inalriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of mamage counselors in the Prothonotar~s Office, which list is available to me upon request. 3. Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down. I verifythat the statements made in this affidavit are true and cornea. I understand that false statements herein made are subject to the penalties of 18 Pa. GS. Sectioni96~r€lating to unsworn falsification to authorities. ~An~ ~ , 2009 c~J C ~ ~~ ~~ ~. ~ „~ ' ~" '. ' '~ i ; ~.. ~- .~. :~,i > ~t-r .~ -:~ a ~f ~ ~