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Home My WebLink About09-0625MOHAMMAD D. ALIZADA, Plaintiff V. MARIMA F. ALIZADA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 09 - (O&S C Zvi le r? : CIVIL ACTION- 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 ground for the 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 at the 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 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, PA 17013 (717) 249-3166 ¦ z MOHAMMAD D. ALIZADA, Plaintiff V. MARIMA F. ALIZADA, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :No. 0 4- 6 d S CIVIL ACTION -DIVORCE DIVORCE COMPLAINT The Plaintiff, Mohammad D. Alizada, by and through his attorneys, The Law Offices of Patrick F. Lauer, Jr., L.L.C., makes the following Complaint in Divorce: COUNT I - NO-FAULT DIVORCE - §§ 3301(c) or 3301(d) 1. The Plaintiff, Mohammad D. Alizada, is an adult individual who currently resides at 427 First Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant, Marima F. Alizada, is an adult individual who currently resides at 427 First Street Carlisle, Cumberland County, Pennsylvania 17013. 3. The Parties have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The parties were married on November 29, 1990, in Moscow, Russia. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that the plaintiff may have the right to request that the court require the parties to participate in counseling. 8. This action is not collusive. WHEREFORE, the Plaintiff requests this Honorable Court enter a Decree of Divorce in this matter. Respectfully submitted, Marlin L. ey, Esquire Law ices f Patrick F. Lauer, Jr., L.L.C. 2108 Market Street, Aztec Building u Camp Hill, Pennsylvania 17011-4706 Date: z 4- Z ID# 84745 Tel. (717) 763-1800 MOHAMMAD D. ALIZADA, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. MARIMA F. ALIZADA, CIVIL ACTION - DIVORCE Defendant 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: Mohammad D. Alizada ? V r'C- ''? MARIAM ALIZADA, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA V. Docket No. 2009 -625 PACSES No. 037110700 MOHAMMAD ALIZADA, CIVIL ACTION - LAW Defendant. IN DIVORCE PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Please withdraw the appearance of Marlin L. Markley, Esquire on behalf of the Defendant in the above-captioned action as Mohammad Alizada is entering his appearance Pro Se. Date: z o o " Mar ' Markley, Esquire Fore , Foreman & Caraciolo, PC 112 Market Street, 61 Floor Harrisburg, PA 17101 ID# 84745 Tel. (717) 236-9391 Facsimile (717) 236-6602 PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Mohammad Alizada, Pro Se in the above-captioned action. Respectfully submitted, Date: 5 Mohammad Alizada, Pro Se 1440 Simpson Ferry Road New Cumberland, PA 17070 Tel. (717) 258-4424 RID-OF OF T PROTHONOTARY 2089 MAY -6 PH 2: 48 NTY PENNSYLV NIM. LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 KOPE & ASSOCIATES, LLC 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 (beam@kopelaw.com MOHAMMAD D. ALIZADA, Plaintiff, vs. MARIMA F. ALIZADA, Defendant, Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-625 CIVIL ACTION -LAW IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY: Please enter my appearance on behalf of M above-captioned divorce matter. )a 1.20 DA D. Alizada, Plaintiff in the . BEAM, ESQUIRE ,sociates. LLC 4660 Trindle Road Ste 201 Camp Hill, PA 17011 Supreme Court ID# 91175 # . N6 MOHAMMAD D. ALIZADA, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 09-625 MARIMA F. ALIZADA, CIVIL ACTION - LAW Defendant, IN DIVORCE CERTIFICATE OF SERVICE I, Lesley J. Beam, do hereby certify that on this 2jr day of May, I served a true and correct copy of the foregoing Praecipe for Entry of Appearance via regular U.S. First Class mail, postage prepaid, addressed as follows: Frank C. Sluzis, Esquire Scaringi & Scaringi 2000 Linglestown Road Suite 106 Harrisburg, PA 17110 and Marlin L. Markley, Esquire 2108 Market Street Aztec Building Camp Hill, PA 170,E l lley J. Want, Esq. I.D. 9117 4660 Tri le Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 .+- , -% r T°rF,- ??--tt ? C LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 KOPE & ASSOCIATES, LLC 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 (beam@kopelaw.com Attorney for Plaintiff MOHAMMAD D. ALIZADA, : IN THE COURT OF COMMON PLEAS Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 09-625 MARIMA F. ALIZADA, 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 February 6, 2009. 2. The Complaint was served by certified mail signed for by Defendant on February 27, 2009. 3. The marriage of plaintiff and defendant is irretrievably broken and at least ninety (90) days have elapsed from the date of filing and service of the complaint. 4. i consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of the Divorce Decree. 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: 5 -29-o? 01A&L Mohammad D. Alizada F i L E L OF THE P,' T.AqY 2009 AN 15 F rrl 1: 4 4 d ,,, '' W y? 1} l fJ ?, L??§ ! LESLEY J. BEAM, ESQ. ATTORNEY I.D. 91175 KOPE & ASSOCIATES, LLC 4660 Trindle Road, Suite 201 Camp Hill, PA 17011 (717) 761-7573 (beam@kopelaw.com MOHAMMAD D. ALIZADA, Plaintiff, VS. MARIMA F. ALIZADA, Defendant, Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 09-625 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in divorce without notice. 2. 1 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. 1 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: Z Mohammad D. Alizada F 1L'Eir ..f 11 i 4tJ L.. CF THE P ''-`,'"APY 2009 JUN 15' ' 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Mohammad D. Alizada v. Marima F. Alizada NO, 09-625 DIVORCE DECREE AND NOW, nli-S~~ ! ~ ad~Q , it is ordered and decreed that Mohammad D. Alizada ,plaintiff, and Marima F. Alizada ,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 By the Court, ~' Attest: J. Prothonotary g~~~v~c~t-c~~~ r. i { ~ Y ~ ' ..,, ~ ~ ~~ i In The Court Of Common Pleas Of Cumberland County Prothonotary's Office ALIZADA MARINA F 427 FIRST STREET CARLISLE PA 17013 ALIZADA MOHAMMAD D ** VERSUS ** ALIZADA MARINA F Civil Action No.: 2009-00625 Plaintiff Defendant You are hereby notified that a Decree in Divorce was entered in the above captioned case on August 18, 2009. This letter should not be used in place of the actual Decree. If you desire a certified copy of this Decree, you can obtain the same by coming into our office. Please bring this letter with you. The fee is $14.00 cash or money order. --- - - Law Offices of :CK F. LAVER, JR., LLC 2108 Market Street Camp Hill, PA 17011 oq-~a5 ,~p'(ES P0.Sr ~` v 9 // ~~ ~W ~ ~~~* ~%~ ~ ~~PITNEY BOWES 02 1P $ 000.44° 0002616435 AUG 20 2009 MAILED FROM ZIP CODE 17011 ~~~~r~ ~' ;-;,,a~~ Prothonotary's Office ~ ~ ~ r ~ Cumberland County Courthouse ~ t G ~~~ ~ Z '~ ~~` ~'~ ~(j'~ ~~~~ One Courthouse Square Carlisle PA 17013 r f ,.:till ~_..y 7'-~~~~~~~ I v i~~..}~."~~:~•~~. :+:! ...•e^s. :l.. 1lFtlil}!lil~!}3F