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Home My WebLink About10-21720 . ,y LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com Attorneys for Plaintiff NATALIYA ALIGIMANTO FAZYLOVA k/n/a NATALIE ALGIS Plaintiff V. YUNATAN MIK HAILOVICH EAZY-L-O-Y- Defendant 2019 111AR 30 AN, 8: 01 Ct;;r?? ? _ ???iTY Y? r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2010- a717Q CIVIL TERM 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 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 Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania, 17013. /C? 3Sj0 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, 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 32 South Bedford Street Carlisle, PA 17013 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Please 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. 2 LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com Attorneys for Plaintiff NATALIYA ALIGIMANTO FAZYLOVA k/n/a NATALIE ALGIS Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. . YUNATAN MIK HAILOVICH FAZYLOV . Defendant CIVIL ACTION - LAW NO. 2010- CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Nataliya Aligimanto Fazylova k/n/a Natalie Algis, an adult individual who has resided at 178 Rich Valley Road, Mechanicsburg, Cumberland County, Pennsylvania since on or about May of 2003. 2. Defendant is Yunatan Mikhailovich Fazylov, an adult individual who has resided at 8433 125th Street, Kew Garden New York since on or about April 26, 2006. 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. Plaintiff and Defendant were married on May 23, 1998 in Uzbekistan. 5. Plaintiff and Defendant separated in January of 2003. 3 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken 8. Plaintiff has been advised that counseling is available and Plaintiff may have the right to request that the court require the parties to participate in counseling. 9. Plaintiff avers that the marriage between the parties is irretrievably broken. 10. Plaintiff requests the court to enter a decree in divorce. WHEREFORE, Plaintiff prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: That a decree in divorce be entered dissolving the marriage between the two parties. LAW OFFICES OF PETER J. RUSSO, P.C. Date: 3 2-S I? Attorneys for P Peter J. Russo, Esquire I D # 72897 Elizabeth J. Saylor, Esquire ID # 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 PH: (717) 591-1755 FX: (717) 591-1756 4 VERIFICATION 1, Natalie Algis, verify that the statements made in the forgoing document are true and correct to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904 relating to unswom falsification to authorities. Dated:3 ? Z31 la NATALIE ALGIS O ~ LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com Attorneys for Plaintiff NATALIYA ALIGIMANTO FAZYLOVA k/n/a NATALIE ALGIS Plaintiff v. YUNATAN MIKHAILOVICH FAZYLOV Defendant FlLE~'-~:;rfi E 1F TIDE ~';,,^TH~`~'' "; y`~Af?Y ZffiQ JtJial -8 ~~ l i ~ i~~ ~EI ti~11'ir~ ~''ri,°~li~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0.2010- 2172 CIVIL TERM IN DIVORCE AFFIDAVIT OF GOOD FAITH INVESTIGATION I, Peter J. Russo, Esquire, being duly sworn according to law, deposes and says the following: 1. I am the Plaintiff's attorney in the above action. 2. At my direction an investigation was conducted into the whereabouts of the above captioned Defendant, pursuant to Pa R.C.P. 430. The efforts to locate the Defendant included inquiry and/or inspection into past addresses and locations of the Defendant and/or his relatives, heirs and/or assigns via: a. the postal authorities; b. Internet searches; c. attempted personal service by process server; and d. personal inquiries. 3. After such inspection, I have been unable to locate the whereabouts of the named Defendant. 4. The allegations in the foregoing Affidavit are true and correct to the best of my personal knowledge, information and belief. LAW OFFICES OF PETER J. RUSSO, P.C. i ~- Date: ~ (~ ~ ~ ~ - Attorneys for Plaintiff Peter J. Russo, Esquire I D # 72897 Elizabeth J. Saylor, Esquire ID # 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 PH: (717) 591-1755 FX: (717) 591-1756 Sworn to and subscribed before me this ~ day of n e.._, 2010. L~11 ~Z-- Notary Pu lic COMMONWEALTH OF PENNSYLVANIA Notary Seel Ashley Sipe, Notary Publk Hampden lYvp., Cumbeiiand County My Cam B~Ires Ocrt. 12, 2011 Member. Pentn~MaNa Assodadon d NOterlec LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo, Esquire PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com Attorneys for Plaintiff NATALIYA ALIGIMANTO FAZYLOVA k/n/a NATALIE ALGIS Plaintiff v. YUNATAN MIKHAILOVICH FAZYLOV Defendant ~i~fOQCT29 PM f; ~~; OUMQERLA€~E~ Ct~Ui~~'~ ~;~ ~LP/~dSYLVkI~i,~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW N0. 2010- 2172 IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, yoU must file a counter-affidavit within twenty days after this affidavit has been served on ybu or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated in January of 2003. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division, division of property, lawyer's fees or expenses if I do no claim them before a di~rorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that fialse statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unswom falsification to authorities. Date: /O .Q/ JO Nataliya Aligimanto Fazytova k/Na '~ Natalie Algis 2 NATALIYA ALIGIMANTO FAZYLOVA k/n/a NATALIE : IN THE COURT OF COMMON PLEAS OF ALGIS CUMBERLAND COUNTY, PENNSYLVANIA V. YUNATAN MIKHAILOVICH FAZYLOV NO. 2010- 2172 DIVORCE DECREE AND NOW, be-g-, 1 , 2.O 10, it is ordered and decreed that NATALIYA ALIGIMANTO FAZYLOVAWNa NATALIE ALGIS , plaintiff, and YUNATAN MIKHAILOVICH FAZYLOV bonds of matrimony. , defendant, are divorced from the 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, Prothonotary evi - r cagy ? ?r ?_?