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Home My WebLink About10-2298 Anela Grahovic Plaintiff V. Samir Grahovic Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 10-? CIVIL TERM IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS N_ L CJ? --C 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 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, 1 Courthouse Square, 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 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 Anela Grahovic Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 10- CIVIL TERM Samir Grahovic Defendant . IN DIVORCE COMPLAINT UNDER $3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is. De\a CA,G KX) ?C. , who currently resides at VAWA ?ccad\e?? "mac a3\L\ Cumberland County, Pennsylvania. 2. Defendant is ?`Q, C , who currently resides at \tiyn???y v?1tk 'u. U • "`?C1,c 3\00 F\0X-e<'\Ce, "g 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on ?l Jl? ?? \Z?'n ZLO i n at 5. The marriage is irretrievably broken, and the parties separated on 6. There have been no prior actions of divorce or annulment between the parties. 7. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. 1._ 1U) Date Plaintiff, Pro Se I, , verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. §4904. Date: P1AAnLt n„1,n.1)n?o Plaintiff, Pro Se Assisted by: Abraham Prozesky, Esq. 674 Stover Ct. Hummelstown, PA 17036 (717) 982-1532 Anela Grahovic IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 10- CIVIL TERM Samir Grahovic Defendant IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING You have been named as the Defendant in a Complaint in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with Section 3302(d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce being handed down by the Court. A list of professional marriage counselors is available at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from this list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. Anela Grahovic IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 10- J.I-gY' CIVIL TERM Samir Grahovic Defendant IN DIVORCE Fri PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Anela Grahovic Plaintiff, to proceed in forma ap uperis. I, Abraham Prozesky, attorney for the party proceeding in forma ap uperis, certify'that T believe the party is unable to pay the costs and that I am providing free legal services to the party. Abraham Prozles , Attorney for P nti 674 Stover . Hummelstdwn, PA 17036 (717) 982-1532 Anela Grahovic IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA v, NO. 10- 229 8 CIVII. TERM Samir Grahovic . Defendant IN DIVORCE _N a, , .- ~; AFFIDAVIT OF CONSENT `-~ ` ~''' - - ~ r~.-- _~~ ~ 1. A complaint in divorce under §3301(c) of the Divorce Code was filed oar %~ ~v ~ C1 ° ;- .. ---~ '~~ t~, _- 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of divorce. 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. Section 4904 relating to unsworn falsification to authorities. R Date: Z~ Signature: Anela Grahovic, Plaintiff Anela Grahovic IN THE COURT OF COMMON PLEAS`~~~ . Plaintiff CUMBERLAND COUNTY PENNSYL ~ =,~; -,. --, E~.,, c-- --s v. NO. 10- ZZ.~t S CIVIL TERM ~ ` ~"~ rv . - c~.: Samir Grahovic ~ ~~- _ _ - --~ Defendant IN DIVORCE .y_: c~~ ~ • r ... ~, :...., c.... G" ~-c`, WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I 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. I 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 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: °J ~ Signature: ` Anela Grahovic, Plainti ANELA GRAHOVIC IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA V. SAMIR GRAHOVIC ' NO. 10 - 2298 DIVORCE DECREE AND NOW, Ur c,~ _ Z ~ Z_ o ~O , it is ordered and decreed that ANELA GRAHOVIC plaintiff, and SAMIR GRAHOVIC ,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. Prothonotary By the Court, ~~ ti ~ '~°`~`r