HomeMy WebLinkAbout14-3338 •.'� f Hp PRO i i 6W"o it;F1 s
Jt ,�Ll .
CUMBERLAND
PENNSYLVANIA
Julie Ann Moussa IN THE COURT OF COMMON PLEAS
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V. DOCKET NO. 111, 333Cl o l e
Abdoul Kader Moussa +tel
DEFENDANT CIVIL ACTION - DIVORCE
COMPLAINT UNDER SECTION 330.1(c) OR 3301(d)
OF THE DIVORCE CODE
TO THE HONORABLE, THE .JUDGES OF SAID COURT:
AND NOW, comes Plaintiff, Julie Ann Moussa, by and through her attorneys, SMIGEL,
ANDERSON & SACKS, LLP, and represents as follows:
COUNT
DIVORCE UNDER SECTION 3301(c) OR 3301(d)
OF THE DIVORCE CODE
1. Plaintiff is, Julie Amt Moussa, who currently resides at 1129 Harrisburg Pike Lot3,
Carlisle, Cumberland County, Pennsylvania 17013 and has resided there since on or about October
2012.
2. Defendant is, Abdoul Kader Moussa, who currently works at Giant, 1621 Industrial Drive,
Carlisle, Cumberland County, Pennsylvania 17013 and has worked there since on or about 2009. His
home residence is unknown at this time.
3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth for at
least six (6) months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on 9/11/07, at Magisterial District Court 12-3-
02 by Judge Gregory D. Johnson.
5. There have been no prior actions of divorce or for annulment between the parties.
4363. 75- p/j 7-
e as
� 306 r7o2
d►
6. The marriage is irretrievably broken.
7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right
to request that the Court require the parties to participate in counseling.
8. Plaintiff avers that there are no children of the parties under the age of 18.
9. Plaintiff and Defendant have been separated and living separately since 12/24/2011.
10. Both Plaintiff and Defendant both agree to this divorce without any restrictions.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter a
decree of divorce under §3301(c) or §3301(d) of the Divorce Code.
Date: ,510M Plaintiff Signature:
Dater _ I Defendant Signature: