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Home My WebLink About01-2233 MAHRA RIt JAWIL~R, · COURT OF COMMON PLEAS · CUMBERLAND COUN.TY, PENNSYLVANIA · CIVIL ACTION-LAW MAHMMOUD F. JAWHAR · Defendant · IN DIVORCE NOTICE TO DEFENDANT AND CLAIM OF 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 claim or relief requested in these papers by the Plaintiff. You may lose money or property or other fights important to you, including custody or visitation of your children. When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's office at the Cumberland County Courthouse, 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 TIlE OFFICE SET FORTH BELOW TO FIND OUR WltERE YOU CAN GET LEGAL HELP. Office of the Court Administrator Cumberland Coumy Courthouse, 4th Floor Carlisle, PA 17013 (717) 240-6200 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. Michael J. Kane Reg. No. 46215 Kane and Mackin, LLP 33 00 Trindle Rd. Camp Hill, PA 17011 (717) 214-3700 Attorney for Plaintiff MAHRA RH JAWHAR · COURT OF COMMON PLEAS Plaintiff · CUMBERLAND COUNTY, PENNSYLVANIA v. · o/- · CIVIL ACTION-LAW MAHMMOUD F. JAWHAR: Defendant · IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) AND 3301(D) OF THE DIVORCE CODE COMES NOW, Mahra Kh Jawhar, through her attorney, Michael J. Kane, Esquire, and avers as follows: COUNT ONE - DIVORCE 1. Plaintiff, Mahra Rh Jawhar is an adult individual, whose current address is 2 Riverview Dr., Enola, Cumberland County Pennsylvania 17025. 2. Defendant is Mahmmoud F. Jawhar, who resides at 2 Riverview Dr., Enola, Cumberland County Pennsylvania 17025. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 25, 1992 in Camp Hill, PA. 5. There have been no prior actions of divorce filed in this matter. 6. Neither Plaintiff nor Defendant is a member of the Armed Forces of the United States. 7. The marriage is irretrievably broken and the parties are proceeding under Section 3301 (c) and 3301 (d) of the Divorce Code. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the fight to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the court enter a decree of divorce. MAHRA RH JAWHAR, : COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA · · v. : NO. : CIVIL ACTION-LAW MAHMMOUD F. JAWHAR - · Defendant · 1N DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Mahra Rh Jawhar, Plaintiff, to proceed in forma pauperis. I, Michael J. Kane, attorney for the party proceeding '.m forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. Respectfully submitted, Michael J. Kan~g. No. 46215 Kane and Mackin, LLP 3300 Trindle Rd. Camp Hill, PA 17011 (717) 214-3700 Attorney for Plaintiff · · IN THE COURT OP COMMON ~LEA$ OP ~/~ ~9/-/~ ~~ ~~~~ P l~nfiff . ' CUMBE~ANO COO~Y, PE~SYLVA~A ' NO. 99- CIVIL TERM ~ ~~ ~ g M ~ f ~~~~Defend~t . AFFIDAVIT IN SUPPORT OF PETITION 1. I am the ~/~/~/7~ in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: Address: 12. (b) Social Security Number: If you are presently employed, state Employer: ~ Address: Salary or wages per month: Type of work: If you are presently unemployed, state Date of last employment: Salary or wages per month: Type of work: · (e) Other in~ome within the past twelve months Business or profession: _ ~//~ - Other self-employment: _ -- Interest: Dividends: Pension and annuities: _ - Social Security benefits: _ - Support payments: DiSability payments: · Unemployment compensation and A _ supplemental benefits: _ Workman's compensation: _ - Public Assistance: Other: - · (d) Other contributions to household support Oli#~)(Husband) Name: _ tq',//~_ - If your (husband)/~i~) is employed, state Employer: _ - · g~ary 'or-wages per. month: ..... -- Type of work: Contributions from children: _ ~! ~ - (e) Property owned Cash' Checking Account: Savings Account: Certificates of Deposit: _ - Real Estate (including home)' ' Motor vehicle: Make Year Cost Amount owed Stocks; bonds: Other: (f) Debts and obligations Mortgage: Rent: Monthly Expenses' (g) Persons dependent upon you for support (Wife) (Husband) Name: Children, if any: Name: Age: 4. I understand that I have a continuing obligation to inform the court of improvement in my financial.circumstances which would permit me to pay the costs incurred herein. 5. 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. 4904, relating to unswom falsification to authorities. [] Complete items 1, 2, and 3. Also complete A. Received by (Please P#nt Clea#y) lB. Date of D~livery item 4 if Restricted Delivery is desired. · ia Print your name and address on the reverse /-~/',~c/~O,/ so that we can return the card to you. C. Signature ' ' ~ Attach this card to the back of the mailpiece, ~~_~_ ~ ~ Agent or on the front if space permits. ~ Addresscc 1. AAicle ~ddressed to: D. Is delivew addre~ di~erent from item 17 ~ Yes If YES, enter delivew address below: ~ No. ~ Registered ~ Return Receipt for Merchandise ¢ ~ ¢ ~~ / 7O ~ ¢ a Insured Mail U C.O.D. ' 4. Restricted .Delivew? (~tm F~) ~ Yes 2. A~icle Number (Copy from se~ice labeO PS Form 9" Domestic Return Receipt. 102595-99-M-1789 ..... . :. .. ., ............. ~ ............. .... ................ MAHRA RH JAWHAR, · IN THE COURT OF COMMON PLEAS Plaintiff ' CUMBERLAND COUNTY, PENNSYLVANIA vs. · NO. 01-2233 CIVIL MAHMMOUD F. JAWHAR, · CIVIL ACTION- LAW Defendant · IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on April 17, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the complaint. 3. I consem to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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 unswom falsification to authorities. Mahra RH Jawhar //-"°/"-~ Social Security No. .. MAHRA RH JAWHAR, · 1N THE COURT OF COMMON PLEAS Plaintiff ' CUMBERLAND COUNTY, PENNSYLVANIA vs. · NO. 01-2233 CIVIL MAHMMOUD F. JAWHAR, · CIVIL ACTION- LAW Defendant · IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on April 17, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) 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 the decree. 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 unswom falsification to authorities. Date: '1/~/~ iD"5 Mahmmoud F. Jawhar Social Security No. 2~10-60-5906 MAHRA RH JAWHAR, ·IN THE COURT OF COMMON PLEAS Plaintiff ·CUMBERLAND COUNTY, PENNSYLVANIA vs. :NO. 01-2233 CIVIL : MAHMMOUD F. JAWHAR, : CIVIL ACTION - LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: Mahra RH Jawhar MAHRA RH JAWHAR, ·IN THE COURT OF COMMON PLEAS Plaintiff 'CUMBERLAND COUNTY, PENNSYLVANIA vs. ·NO. 01-2233 CIVIL MAHMMOUD F. JAWHAR, ·CIVIL ACTION- LAW Defendant ·IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree in 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 A~davit 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 unswom falsification to authorities. Date' ~ ~ ]//$'/fl.~O~ Mahmmoud F. Jawhar Social Security No. 210-60-5906 Z ;.."_,"'_:~ :~':-"' : ! :' .,. zE." ~ !--,-- ~ ~ ".~..4 ':-'7.- :.'? ('7: :Z~E;'' ~ .~ 0 :' ';' -'~"~ · .'....., r. ~ ,~,~ :':..:.-. MAHRA RH JAWHAR, · IN THE COURT OF COMMON PLEAS Plaintiff · CUMBERLAND COUNTY, PENNSYLVANIA v. · NO. 01-2233 CIVIL MAHMMOUD F. JAWHAR, · CIVIL ACTION- LAW Defendant · IN DIVORCE .PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for emry 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: May 3,2001--See Retum Receipt Service 3. Date of execution of the affidavit of consent required by Section 3301c of the Divorce Code: by plaintiff.' November 6, 2003 and filed herewith; by defendant: November 6, 2003, and filed herewith 4. Related claims pending: none 5. Date of plaintiff's Waiver of Notice in Section 3301 c Divorce' dated November 6, 2003 and filed herewith. Date of defendant's Waiver of Notice in Section 3301 c Divorce: dated November 6, 2003, and filed herewith Timothy J. O'Connell, Esquire Turner and O'Connell 4415 North Front Street Harrisburg, PA 17110 (717) 232-4551 Attorney for plaintiff IN THE COURT OF COMMON PLEAS Of CUMBERLAND COUNTY STATE OF ~ PENNA. / ...... ~~' '~'''a'~ ................................................... ;:'4 "' i/ ,.., ~ ,~V~%H~;fTJD F. JKWHAR DECREE IN DIVORCE ~ AND NOW, .......... . .~,:r...~,~--~...../.'(. :.., ×1~003 .... it is ordered and ~ decreed that . ~ra Rh Jawhar plaintiff · , · · · · · · · · · · · · , · · · · , · · · · , · · · · · , · , · · · · · · · · · · · · · · · · · i I ~ ., defendant, ~ and .....~'e~~. :r... ~~r ................................. ~ are divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered' ' · · ~ . .n.o.n.e ..................................................................... ' ~ By The Cour~ ~ ',~~=-~'~'-'-' j Prothonotary ~ ..... -, ........ '- ""': ....... '.:4~:. '-,~,' -:4~,.. '~,~'~.'. -'~,~'~'- .'~ ',;'