HomeMy WebLinkAbout09-4433KENDRA VERNON,
Plaintiff
V.
MEHANY MOUSA,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2009- A(1{13 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 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 Court House, High and Hanover Street, Carlisle.
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.
Court Administrator
Cumberland County Court House
1 Courthouse Square
Carlisle, PA 17013
(717) 240-6200
JOHNN?"i?. KOPEPKY, ESQUI
Supreme Court ID #53147
120 South Street
Harrisburg, PA 17101
(717)221-1111
KENDRA VERNON,
Plaintiff
V.
MEHANY MOUSA,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2009- yN33 CIVIL TERM
: IN DIVORCE
COMPLAINT UNDER SECTION 3301(c)
OR 3301(d) OF THE DIVORCE CODE
1. Plaintiff is Kendra Vernon, an adult individual, who currently resides at 907 Chester
Road, Apt. D, Enola, Cumberland County, Pennsylvania.
2. Defendant is Mehany Mousa, an adult individual who currently resides at 5 Gharb El
Nady El Bahary, Souhag, Egypt.
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 were married on December 21, 2007, in Hummelstown,
Dauphin County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The Plaintiff has been advised of the availability of marriage counseling and the
Plaintiff may have the right to request that the Court require the parties to participate in
counseling. Having been so advised Plaintiff does not desire the Court to order counseling, as
evidenced by the Affidavit as attached hereto and made a part hereof marked as "Exhibit A."
7. The marriage is irretrievably broken.
WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce.
Respectfully submitted,
Johnna . Kopecky, Esquire
Supreme Court ID #53147
120 South Street
Harrisburg, PA 17101
(717) 221-1111
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KENDRA VERNON,
Plaintiff
V.
MEHANY MOUSA,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
2009- 4111M CIVIL TERM
: IN DIVORCE
AFFIDAVIT
I, Kendra Vernon, Plaintiff, being duly sworn according to law, depose and say:
(1) 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.
(2) I understand that the court maintains a list of marriage counselors in the Prothonotary'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 by the court.
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.
Dated: !, 2 /.`.5??-.??
Kendra Vernon, Plaintiff
VERIFICATION
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF DAUPHIN :SS
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. Section 4904 relating to unsworn
falsification to authorities.
DATED: 0 (0 - z, ? _2 "I
c, o
Kendra Vernon, Plaintiff
IT2: 17