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Home My WebLink About10-4080John W. Purcell, Jr., Esquire ID #29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell c@pkh.com pI Fr L IJ '. A Trr• f?; 20th V'vii i 7 F?'I 2: 20 / }! Al" PRAVEEN C. DANDAMUDI, Plaintiff V. CHANDANA KALAGARA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 16 - q09d CIVIL ACTION -LAW 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, Cumberland County Courthouse, One Courthouse Square, Room 100, Carlisle, PA 17013-3387. 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. 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 REDUCE FEE OR NO FEE. -y_-4z'2 R40-02V3 go/ CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 1249-3166 AVISO USTED HA SIDO DEMANDADO/A EN CORTE. Si usted desea defenderse de las demandas que se presentan mas adelante en las siguientes paginas, debe tomar accion dentro de los pr6ximos veinte (20) dias despuas de la notificaci6n de esta Demanda y Aviso radicando personalmente o por medio de un abogado una comparecencia escrita y radicando en la Corte por escrito sus defensas de, y objecciones a, las demandas presentadas aqui en contra suya. Se le advierte de que si usted falla de tomar acci6n como se describe anteriormente, el caso puede proceder sin usted y un fallo por cualquier suma de dinero reclamada en la demanda o cualquier otra reclamacion o remedio solicitado por el demandante puede ser didtado en contra suya por la Corte sin mas aviso adicional. Usted puede perder dinero o propiedad u otros derechos importantes para usted. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO INMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME 0 VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE INFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENCIAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO 0 BAJO COSTO A PERSONAS QUE CUALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 South Bedford Street Carlisle, PA 17013 (717) 1249-3166 (800) 990-9108 John W. Purcell, Jr., Esquire ID #29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 2344178 jpurcell@pkh.com PRAVEEN C. DANDAMUDI, Plaintiff V. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CHANDANA KALAGARA, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW COMES Plaintiff, Praveen C. Dandamudi, by his attorneys, Purcell, Krug & Haller, and who avers as follows: DIVORCE PURSUANT TO SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Praveen C. Dandamudi , an adult individual whose current address is 302 Georgetown Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant is Chandana Kalagara, an adult individual whose current address is 302 Georgetown Road, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4 5 parties. 6 Forces. 7 8 9 Plaintiff and Defendant were married on February 8, 2006, in India. There have been no prior actions in divorce or annulment between the Neither of the parties in this action is presently a member of the Armed Neither the Plaintiff nor the Defendant are citizens of the United States. The marriage is irretrievably broken. Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree in Divorce. DATE: (2A 41 c) PURCELL, KRUG & HALLER By: ohn . Purcell, Jr., Esquire hLW9955 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 Attorney for Plaintiff 2 VERIFICATION I verify that the statements made in the foregoing 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. Dated: 6 111 -L4- d Praveen C. Dandamudi ~- , ;t: 2DIQ J~ ZS ~ 10~ ~7 John W. Purcell, Jr., Esquire ID #29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell@pkh.com pl`N v.=;Yl.'v'r`i~f~ PRAVEEN C. DANDAMUDI, Plaintiff v. CHANDANA KALAGARA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 10-4080 CIVIL CIVIL ACTION -LAW IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN I, John W. Purcell, Jr., Esquire, Attorney for the Plaintiff, Dandamudi, in the above action, hereby swear and affirm that on the 18th day of June, 210, I sent, by certified mail, return receipt requested, restricted delivery, a Complaint in Divorce to the Defendant, Chandana Kalagra. The Return Receipt Card signed by the Defendant on June 22, 2010, is attached hereto as Exhibit "A". Sworn and subscribed to before me this ~~d~ay of ~~.~. ti~ , 2010. N Kimberly S. DeFalco, Notary Public City of Harrisburg, DaupMn County ly Commission Expires Jan. 17, 2013 ^ 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. ^ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: Chandana Kalagara 302 Georgetown Road Mechanicsburg, PA 17050 A. Signature ~nn,, ...'~~, ~~ ~~ ~/f~~ ~~ ti` ^ Agent X l~J~"v~Clt.V~ ` 1` ^ Addressee B. Received by (Printed Name) C. to of livery 0 D. Is delivery address different. If YES, ente~ ~~ ~~ ,~ ~~~ 3. Service Type ~Certifted Mail ^ Express MaN ^ Registered ~ Return Receipt for Merchandise ^ Insured Mail ^ C.O.D. 4. Restricted Delivery? (Extra Fee) ~Y~ 2. Article Number (Transfer from servloe fabe!) 7 0 5 3110 ~ O i7 0 112 8 2 9 7 7_ PS Form 3811, February 2004 Domestic Return Receipt 102595-o2-M-i5ao PRAVEEN C. DANDAMUDI, Plaintiff VS. CHANDANA KALAGARA, Defendant IN THE COURT OF COMMON PL S- CUMBERLAND COUNTY, PEN NV11A ,'.. NO. 10-4080 CIVIL CIVIL ACTION-LAW IN DIVORCE NOTICE TO THE DEFENDANT IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY (20) DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. DEFENDANT'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE The parties to this action separated on June 22, 2010 and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. 1 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. 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. Dated: ?o2?I2a/? P veen C. Dand mudi M John W. Purcell, Jr., Esquire ID #29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell@pkh.com PROTHONOTAR ',012 JUL 25 PM 2: 58 IcU PENNSYLDVAN A TY PRAVEEN C. DANDAMUDI, Plaintiff V. CHANDANA KALAGARA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV NIA : NO. 10-4080 CIVIL CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF PROCESS SERVER Purcell & Haller By urcell, Jr. CgIZ29955 1719 North Front Street Harrisburg, PA 17102 Date: Affidavit of Process Server IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA (NAME OF COURT) A PRAVEEN C. DANDAMUDI VS CHANDANA KALAGARA 0 10-4080 N I DAVID OLMSTEAD being first duly sworn, depose and say: that I am over the age of 18 yea s and not a party to this action, and that within the boundaries of the state where service was effected, I was authorized y law to perform said service. Service: I served CHANDANA KALAGARA NAME OF PERSON / ENTITY BEING SERVED with (list documents) Plaintiff s Affidavi Under Section 3301(d) of the Divorce Code (s a attached) by leaving with CHANDANA KALAGARA DEFENDANT At NAME RELATIONSHIP ADDRESS CITY / STATE i AM-11 Al I DnIKITC f_T PLAINFIELD. INDIANA 46168 CITY / 7-19-2012 T 215PM DATE TIME 0 Inquired if subject was a member of the U.S. Military and was informed they are not. Thereafter copies of the documents were mailed by prepaid, first class mail from CITY STATE ZIP DATE Manner of Service: 0 Personal: By personally delivering copies to the person being served. ? Substituted at Residence: By leaving copies at the dwelling house or usual place of abode of the person served with a member of the household over the age of and explaining the general nature of the r ? Substituted at Business: By leaving, during office hours, copies at the office of the person/entity being sE the person apparently in charge thereof. ? Posting: By posting copies in a conspicuous manner to the front door of the person/entity being served. Non-Service: After due search, careful inquiry and diligent attempts at the address(es) listed above, I have be unable to effect process upon the person/entity being served because of the following reason(s): ? Unknown at Address ? Moved, Left no Forwarding ? Service Cancelled by Litigant ? Unable to Serve in Timely F ? Address Does Not Exist ? Other Service Attempts: Service was attempted on: (1)7/16/2012 800AM (2) 7/17/2012 20OPM DATE TIME DATE TIME (3) 7/18/2012 800AM (4) 7/19/2012 215PM (5) DATE TIME DATE TIME DATE TIME Description:. Age30 SexF RaceME Height 5'6" Weight 120 Hair BLK Beard N Glasses SIGNATU F PROCESS SERVER SUBSCRIBED AND SWORN to before me this 19 day of JULY , 2012, by IN DL Proved to me on the basis of satisfactory evidence to be the person(s) who ared fore me TAY OLIN ,AD NOTARY PU!?si Ir NATURE OF NOTARY PUBLIC INDIANA STATE 71 I` ,-D1;^,NA NOTARY PUBLIC for the state of S MyCom-kzeion E) cc ,., , 2018 FORM 2 NATIONAL ASSOCIATION OF PROFESSIONAL PROCESS SERVERS with PRAVEEN C. DANDAMUDI, Plaintiff VS. CHANDANA KALAGARA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVA.NIP NO. 10-4080 CIVIL CIVIL ACTION-LAW IN DIVORCE NOTICE TO THE DEFENDANT IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY (20) DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on June 22, 2010 and have continu( to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. 1 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. 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. Section 4904 relating to unsworn falsification to authorities. Dated: C. Dandamudi, Plaintiff . J PRAVEEN C. DANDAMUDI, Plaintiff VS. CHANDANA KALAGARA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAN NO. 10-4080 CIVIL CIVIL ACTION-LAW IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a Divorce Decree. (b) I oppose the entry of a Divorce Decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I lose rights concerning alimony, division of property, lawyer's fees or expenses if I do claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of pro lawyer's fees or expenses or other important rights. I verify that the statements made in this counteraffidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. [S. f- Section 4904 relating to unsworn falsification to authorities. Date: Defendant NOTICE: If you do not wish to oppose the entry of a Divorce Decree and you do not wish to make any claim for economic relief, you need not file this Counteraffidavit. PRAVEEN C. DANDAMUDI, Plaintiff VS. CHANDANA KALAGARA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANI, NO. 10-4080 CIVIL CIVIL ACTION-LAW IN DIVORCE DEFENDANT'S COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): _%Z(a) I do not oppose the entry of a Divorce Decree. -5.; (b) I oppose the entry of a Divorce Decree because (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a pe of at least two years. (ii) The marriage is not irretrievably broken. 0 T h^7 2. Check either (a) or (b): a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do n claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of lawyer's fees or expenses or other important rights. I verify that the statements made in this counteraffidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.$. Section 4904 relating to unsworn falsification to authorities. Date: a_o?? V, efendant NOTICE: If you do not wish to oppose the entry of a Divorce Decree and you do not wish to make any claim for economic relief, you need not file this Counteraffidavit. PRAVEEN C. DANDAMUDI V. CHANDANA KALAGARA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 10-4080 CIVIL oivoRCE a~crE ~"~~ ,'~,f'~o, rrI . AND NOW, ~°~ , it is ordered and decreed thalt PRAVEEN C. DANDAMUDI ,plaintiff, and CHANDANA KALAGARA ,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 C Attest: J. ~ ~,J t , ~~ `_ Prothonot fmh~t ~..1 ~~~ ~~~ fi ce ~' ~o p~ .~~ ~1~~' ~ c,/~o~~ y