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HomeMy WebLinkAbout10-29680 HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF FiLi , Y ' 2?0 it i -4 12 JNTY 61 Clr DENISE M. TCHORNO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA ?. : CIVIL ACTION - LA NO. 2010 - 19 1# 8 CIVIL TERM RAMADAN ADAM TCHORNO, 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 in 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, Carlisle, Pennsylvania 17013. 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, Pennsylvania 17013 717-249-3166 Q 6b3: saki lw w 436x.oO Rte.# ay15y3 &e .)(.4 13 6I 1 46 DENISE M. TCHORNO, Plaintiff V. RAMADAN ADAM TCHORNO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2010 - CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE NOW, comes the plaintiff, DENISE M. TCHORNO, by her attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is DENISE M. TCHORNO, an adult individual residing at 620 North Bedford Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is RAMADAN ADAM TCHORNO, an adult individual with a mailing address of P. O. Box 10523, Harrisburg, Dauphin County, Pennsylvania 17105. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on November 30, 2009, in Carlisle, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that she has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unswom falsification to authorities. May 3, 2010 ?.?... ?,-- DENISE M. TCHORNO, Plaintiff HAROLD S. IRWIN, III Attorney for Plainti 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 «. . V DENISE M. TCHORNO, Plaintiff v. RAMADAN ADAM TCHORNO, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 2010 - CIVIL TERM IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 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. 1 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. May 3, 2010 1 i DENISE M. TCHORNO, Plaintiff . .+ !=`t_" DENISE M. TCHORNO, Plaintiff v. RAMADAN ADAM TCHORNO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2070 - 2968 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i) May 7, 2010 Harold S. Irwin, Attorney for plai 64 South Pitt Street Carlisle, PA 17013 717-243-6090 HAROLD S. IRWIN, 111, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF 2010P~~~Y 2~ P ~~ ~fl r E+~ P~ ~ S`''!J,'~l`~ lA NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon defendant on or about May 6, 2010, addressed to Ramadan A. Tchorno, at P. O. Box 10523, Harrisburg, PA 17105; Certified Mail No. 7009 1410 0000 1189 9457. 3. A copy of the sender's and signed receipt are attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penaltie~ of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. Supreme Court ID No. 29920 r ~ - - ~' ~ ~~' ~ Postage $ a ~~s ~.. E A ~"~ Certified Fee ~ ~ ~ ~ ~ ~ Retum Receipt Fee . ~O Po ~ ~ OO (Endorsement Required) ~re _,, W p Restricted Delivery Fee ~ (Endorsement Required) ~ A ~~ p S $r0 ~ Total Postage & Fees ~ ~ I ~' . ~ Sent To ~M n p Street, Apt. No.; p or PO Box No. n N City, State, ZIP+4 ~~ /~ ~~ ~J :. ~ J r. ~ ^ Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse so that we can return the card to you. ^ Attu this card to the back of the mailpiece, or on the front if space permits. ^ Agent X Stg_~/'A /'~/~ ^ Addressee B. R$pal1led'6Y (Print~~Hllame) ~ C. Date of Delivery D. Is delivery address different m 11 1. Article Addressed to: v~ If YES, enter delivery ad low: ^ ..1 ~~Yt (/(01 GSM t~f , ~~ D Y~ (/1~ ~ MAY 610; a m ~~ '~~ ~ ~~~2 3 y ~y~ //11 -1 3. S ice Type 1 ~,.AN ~~ ~ ~ ~ / ~ a ~ ~Certrfied Mall ^ ~acpress Mail li't' 'Y I t l ^ Registered ®/Return Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery?(Extra Fee) Yes 2. ~ icle Number , --~-~ ~ ~ ~ ~. ~ Q ~ HOC 11 ~~q~ ransfer from service label t PS Form 3811, February 2004 Domestic Retrxn Receipa ~o2sss-a2-M•isao ; DENISE M. TCHORNO, Plalntlff v. RAMADAN ADAM TCHORNO, ' Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2010 - 2968 CIVIL TERM IN DIVORCE IaOTICE OF INTENTION TO RESUME PRIOR SURNAME Notice is/he~reby given that the DEFENDANT in the above matter: " prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce, C7 ^~ b - ~- ~:, ~~ , - j , ; r ~.~,. ~ f -- f tl t- ._ ._ ~: ~ . .~ -- . 7 w ,... ~= dated ,hereby elects to resume the prior surname of LARA M. WATSON and gives this written notice avowing her intention pursuant to the provisions of 54 P.S. Section 704. ;" ~' ~~ ~Gf~tG2~~ (SEAL) Signature -DENISE M. TCHORNO ,`/~ L`'~ d~2/ ~~ G ~ (SEAL) Signature of Name Being Resumed DENISE M. WHITZEL On the 21ST day of July, 2010, before me, a notary public, personally appeared the above affiant, known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. In witness whereof, I have hereunto set me hand and. offic' I seal. Cp~(pWWPAL'fH OF PENNSYLVANIA NOTARIAL SEAL Harold S. (twin lii, Esq, Notary Public Cadisle,A~mbedandCour-ty otary Public M won 'tes February 06> 2011 ~.~,~ a ~ ~~. ~ qty ~rw~ti c/[ ~ / 3 .ids ~~ a-ys ~ y~ DENISE M. TCNORNO, : IN THE COURT OF COMMON PLEAS OF PlalntiM :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW n NO. 2010 - 2968 CIVIL TERM =C ~:, -~5 RAMADAN ADAM TCFIORNO, ~''~ `~ .,_; ,, ~.~~~ Dnhndant : IN DIVORCE _ _ `t: ~ ":=;_ <r"1 ~\ AFFDAVIT OF CONSENT ~ ~' 3 s , j~ 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this ma~er on °or .. about May 4, 2010. Service of the complaint was made upon the defendant on or abort Ms y, 6 ~=--' 2010 (see affidavit of service previously filed). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. / ---` August S 2010 E~ ~ ~! ~G2~7G~' DENISE M. TCHORNO WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 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 the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to th_e .penalties of 18 Pa.C.S. Section 4904 relating to unswom_falsification to authorities. August ~, 2010 ~ ~~Lt.2.P ~~ ~~~~~c'C'-" DENISE M. TCHORNO DENISE M. TCHORNO, iPlaintlH v. RAMADAN ADAM TCHORNO, Dehndant IN THE COURT Off COMMON PLEAS Off CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 2070 - 2968 CIVIL TERM e IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about April 2, 2010, defendant was served with a copy of the divorce complaint (see Acceptance of Service previously filed). 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: August 5, 2010 By the defendant: August 9, 2010 (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiffs affidavit upon the defendant: N/A. 4. Related claims pending: None 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A. (b) Date plaintiffs Waiver of Notice in Section 3301 (c) divorce was filed with the Prothonotary: August 5, 2010 Date defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: August 12, 2010 6. There has been no prior action for divorce or annulment between the parties other than this action which commenced on May 4, 2010. August 12, 2010 HAROLD S. IRWIN, III c~~ ~ ;:, ~` Attorney for Plaintiff .-- o .,-w .-.-~ -~ , {- - -- ._ __ ~w. W ~.~_.... _ .. '~ .. ~ ~ ~u c. ~_1, _F" TC. ~'"' ~ ~ j1J DENISE M. TCHORNO, ~~ h ,~ IN THE COURT .OF COMMON PLEAS OF `' ' lYl}IND COUNTY, PENNSYLVANIA Plslntiff' : s. ~ C v. RAMADAN ADAM TCHORNO, Deiendsnt :CIVIL ACTION -LAW NO. 2010 - 2968 CIVIL TERM IN' DIVORCE AFFDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about May 4, 2010_. Service of the complaint was made upon the defendant on or about May 6, 2010 (see affidavit of service previously filed). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after se of notice of ' tentio to request entry of the divorce. /~, , ~~ August ~, 2010 UNDER SECTION $301(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 ndt 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 and d that false statements herein are made subject to the penalties of 18 Pa.C.S. S cti 4904 r g unswom falsification to authorities. i%~~i . August ~, 2010 IN THE COURT OF COMMON PLEAS OF DENISE M. TCHORNO :CUMBERLAND COUNTY, PENNSYLVANIA V .: .. RAMADAN ADAM TCHORNO - 2010 - 2968 NO. DIVORCE DECREE AND NOW, vS 11 , ~~1~ , it is ordered and decreed that DENISE M. TCHORNO plaintiff, and- , RAMADAN ADAM TCHORNO ,defendant, are divorced ftom 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, ~ • J ~ • ~ d ~. C~cx~. i~o~ I~.c~ ~ ~ 1 rcv ~ ~ ~..c~~ c~ cam.. $ • ('7• ! a ~~~ ~cc,;, le.~ --~, sue.