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Home My WebLink About09-8845Jamie L. Al-Mosawi, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW V. No. 09- g& t/S el-1111 Mahdi H. Al-Mosawi, Defendant 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 Streets, 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Jamie L. Al-Mosawi, Plaintiff vi. Mahdi H. Al-Mosawi, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 09- WYS IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Jamie L. Al-Mosawi, who currently resides at 80 Potato Road, apartment 1, Cumberland County, Carlisle, Pennsylvania, since on or around August of 2008. 2. Defendant is Mahdi H. Al-Mosawi, who currently receives mail at P.O Box 5500, Chillicothe, Ohio. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on October 18, 2001, in Dayton, Ohio. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken, and the parties separated in April 2007. 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 requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. By: "AV 0- Jamie L. Al-Mosawi, pro se VERIFICATION I, Jamie L. Al-Mosawi, 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: difamie L. Al-Mosawi, Plaintiff Assisted by: Vincent M. Monfredo, Esquire Rominger and Associates 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 lir?S V u C!-?. 1 r, t . Jamie L. Al-Mosawi IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- ?? LK- CIVIL TERM Mahdi H. Al-Mosawi Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Jamie L. Al-Mosawi, Plaintiff, to proceed in forma ap uperis. I, Vincent M. Monfredo, attorney for the party proceeding in forma ap uperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Vincent M. Monfredo, Esquire Attorney for Plaintiff Rominger Law Office 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 ??t?Ll . °'llJ i rTY Jamie L. Al-Mosawi, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW ~~~ No. 09- 8845 :__ Mahdi H. Al-Mosawi, = ~ ~ . __'_ t. Defendant IN DIVORCE ~ ~ ~ `-~' PRAECIPE TO TRANSMIT RECORD _ -L =}_- - ~ _~:? TO THE PROTHONOTARY: ~ `~ ' - j ~,, ~ ~~ ~~~~~ - Transmit the record, together with the following information, to the Court for entry of~a divorce decree: 1. Grounds for divorce: irretrievable breakdown under § 3341(d) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified Green Card/Return Receipt to a Federal Prison. January 4, 2010. 3. Related claims pending: None 4. (1) Date of execution of the Plaintiff s Affidavit required by §3301 (d) of the Divorce Code: June 16, 2010. (2) Date of filing and service of the Plaintiff's Affidavit upon the Respondent: Filed June 18, 2010, Mailed June 21, 2010 to Defendant at a Federal Prison. 5. Date and manner of service of Notice of Intention to Request Entry of Divorce Decree a copy of which is attached. June 21, 2010/First Class Mail. Date: ~' y , 2010 !~_ Vincent M. Monfredo, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID No. 206671 For Plaintiff/Jamie L. Al-Mosawi/pro se Jamie L. Al-Mosawi. Plaintiff v. Mahdi H. Al-Mosawi, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 09- 8845 IN DIVORCE 1~1®'1CICE ®lF' I1~1'I'E1~1TI®1~1 T® RE~ITES'I' El~i'I'IZY ®F DIV®RCE DECREE TO: Mahdi H. Al-Mosawi, Defendant: You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the plaintiffs affidavit. Therefore, on or after July 31, 2010, the plaintiff can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the court an answer with your signature notarized or verified or acounter-affidavit by the above date, the court can enter a f nal decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled conference or hearing. Jamie L. Al-Mosawi, Plaintiff Mahdi H. Al-Mosawi, Defendant :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW No. 09- 8845 IN DIVORCE PROOF OF SERVI CE OF DIVORCE COMPLAINT ^ Complete items 1, 2, and 3. Also compierte iterrr 4 if Restricted DelWery is desired. ^ Prkrt your name and address on the reverse ao that we can return the card to you. ^ Attach this card to the back of the mailpiece, or on the front if space permits. ,. Mtiae Addressed to: ~~~~%~~~ 33 /~~~Xl"! ;`1// C~ ~!/,~o~~, Ord 5~s-~~ d `~G A Sign X ~~ B. Ret~d by (1P fnted~N~he) C. Qate of D. Is delvery address dffferent from ftem r7 U Kes If YES, enter delivery address bebw: ~No ~~ ~, ~~ '`-'• „L ~- ~ .->-, ~~ -~'',' ~: ; - `~} o ~.. v~. ~ ;, 3. type Mled Mall ~D ress Mail ^ Registered I~.R~etur~ Receipt for Mercha~ ^ Insured Mail ^ C.O.D. n~ 4. Restricted Delivery? (Exha Fee) ~p Yes 2. ARIcM Numbed fns~r~n-serwce~l 7DD9 DDBD DDD1 8D44 5291 PS Fonrr 3811, Febniary 2004 Danestfc Retixn Rscelpt ,cnsas-aa--~-,~o ~%1 --P ,i_} IN THE COURT OF COMMON PLEAS OF JAMIE L. AL-MOSAWI :CUMBERLAND COUNTY, PENNSYLVANIA v. MAHDI H. AL-MOSAWI 09-8845 NO. DIVORCE DECREE AND NOW, ~1~aJ~~ 1'1. , 100 , it is ordered and decreed that JAMIE L. AL-MOSAWI plaintiff, and MAHDI H. AL-MOSAWI ,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 •d ~1~ Pr thonota 1~e-F!: