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Home My WebLink About05-1905IBRAHIM ALHAJ Plaintiff v. MARY ANN ALHAJ Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLV NO. jj-?- /1(0 5- C'Lv 4 CIVIL ACTION- LAW DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the clad set forth in the following pages, you must take prompt action. You are warned that if you fail do so, the case may proceed without you and a decree in divorce or annulment may be entere< 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 rig important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of d marriage, you may request marriage counseling. A list of marriage counselors is available in Office of Court Administrator, 4'h Floor, 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 THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP Court Administrator 4`h Floor, Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 IBRAHIM ALHAJ Plaintiff V. MARY ANN ALHAJ Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL` NO. p g /9,0.5 CIVIL ACTION - LAW DIVORCE COMPLAINT AND NOW, comes Plaintiff, Ibrahim Alhaj, by and through his attorney, W. Abraham, Esquire, Abraham Law Offices, Camp Hill, Pennsylvania, 17011, and files following: COUNT I - DIVORCE (Pursuant to 23 Pa.C.S.A. Section 3301(c)) 1. Plaintiff, Ibrahim Alhaj, is an adult individual who currently resides at 801 D South Market Street, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant, Mary Ann Alhaj, is an adult individual who currently resides at 31 West Keller Street, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 5, 1996 in Amman, Jordan. 5. There have been no prior actions of divorce or for annulment between the parties. VERIFICATION I, Ql 4A4f 7tit k -t4AJ , the undersigned, hereby verify and that I have reviewed the foregoing document and the statements made therein are true and correct to the best of my knowledge, information and belief I further understand that any statements made herein are subject to the penalties of 18 Pa.C.S.A. Section 4404 relating to unworn falsification to authorities. J DATE: CERTIFICATE OF SERVICE I, James W. Abraham, Esquire, the undersigned, hereby certify that I have a true and correct copy of the foregoing document, by certified mail, upon the following at the following address on the date stated herein: Mary Ann Alhaj 31 West Keller St. Mechanicsburg, PA 17055 DATE: 4/14/05 ?f James W. Abraham, Esquire \, ??-' ^d "<1 N ?_) `=^? 0 ?- <n -", ?_ T_ •-.- ?? ?} ? J t \i _ jY 1 '1\\J y ? I L. -a _ :C 1 N l ?? r ` ?` ? ? C: IBRAHIM ALHAJ : IN THE COURT OF COMMON PLEAS Plaintiff : DAUPHIN COUNTY, PENNSYLVANIA V. : NO. 05 -1905 CIVIL TERM MARY ANN ALHAJ 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 14, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of service and filing 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 the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to the unworn falsification to authorities. DATE: 24 - l--) 7 ?Z2? IBRAHI ntiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SETION 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 the statements made in this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to the unworn falsification to authorities. DATE: 6?I - Z 6 - U -? IB A J, Plaintiff ? ., ?? -, IBRAHIM ALHAJ IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 05 - 1905 CIVIL TERM MARY ANN ALHAJ 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 14, 2005. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of service and filing 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 the Affidavit are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to the unsworn falsification to authorities. DATE`?` *C>. ? ._._ Y ANN ALHAJ WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SETION 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 the statements made in this Waiver are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to the unworn falsification to authorities. DAT ?WaY ANN ALHAJ .e++ i OD IBRAHIM ALHAJ : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 05 - 1905 CIVIL TERM MARY ANN ALHAJ : CIVIL ACTION - LAW Defendant : DIVORCE AFFIDAVIT OF SERVICE I, James W. Abraham, Esquire, the undersigned, as attorney for Plaintiff, Ibrahim Alhaj, in the above-captioned action, hereby affirm that the Complaint in Divorce filed herein, was served upon Defendant, Mary Ann Alhaj, by certified mail on April 16, 2005, as verified by the green return receipt card from the US Post Office, which is attached below: ¦ Complete items 1, 2, and 3. Also c6inplets" 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: /kac? 4tv_ '31 U,16-& rELCEWL S F - hi(CFCffAq(CSi3V1?-G ??17af I I A. Received by (Please Print Clearly) i B. Date of Delivery 0. Signature ? nt Addressee D differerke? 1? ? Yes ,r ES, enter IIA address below: ? No U 4Pq 16 2005 13. bk&6"ra_-' mortified Mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 7004 0750 0002 7287 5590 Ps Form 3811, July 1999 Domestic Retum Receipt 102595-MM-0952 DATE: 4/17/07 James W. Abraham, Esquire >1 C7- Fes- ... -1 ..z.s ABRAHAM LAW OFFICES 45 East Main Street, Hummelstown, PA 17036 (717) 566-9380 IBRAHIM ALHAJ : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 05 - 1905 CIVIL TERM MARY ANN ALHAJ : CIVIL ACTION - LAW Defendant : DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the Record, together with the following information, to the Court for the entry of a divorce decree: 1. Ground for Divorce: irretrievable breakdown under Section (x) 3301(c) ( ) 3301(d)(1) of the Divorce Code. 2. Date and manner of service of the Complaint: April 16, 2005 by certified mail: see attached Affidavit of Service. 3. Complete either paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff on 4/26/07; and by Defendant on 4/18/07. (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: (2) Date of filing and service of plaintiff's affidavit upon the Defendant 4. Related claims pending: None. 5. Complete either paragraph (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: (b) Date Plaintiff's Waiver of Notice was filed with the Prothonotary: 5/17/07 . (c) Date Defendant's Waiver of Notice was filed with the Prothonotary: 5/17/07. Respectfully bmitted: James W. Abraham, Esquire Abraham Law Offices 45 East Main Street Hummelstown, PA 17036 (717) 566-9380 DATE: 4/17/07 Attorney for Plaintiff, Ibrahim Alhaj co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. IBRAHIM ALHAJ VERSUS MARY AM AIRM DIVORCE N O . 05 - 1905 DECREE IN AND NOW, hM 13 , 2007 , IT IS ORDERED AND DECREED THAT IBRAHIM ALHAJ , PLAINTIFF, AND MARY ANN ALHAJ ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,DEFENDANT, 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; BY THE COURT: PROTHONOTARY .A _ - r a ` v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DAVID R. HEYDT, Plaintiff V. KATHLEEN HEYDT, Defendant NO. 05-1906 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that on October 16, 2008, 1 served a true and correct copy of the Defendant's Petition Raising Claim for Divorce AND 3301(d) Affidavit upon David R. Heydt, the Plaintiff, by Certified Mail, Restricted Delivery, addressed as follows: David R. Heydt 365A Buttonwood Court Hellam, PA 17406-9058 The Certified Mail return receipt mailing card, or a copy thereof, for the foregoing is attached hereto as Exhibit "A" and made a part hereof. LIFF, ESQUIRE 448 Trindle ad Camp f , PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Defendant a • ¦ 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. Article Addressed to: ifl1??, ?'• ?l eye oCo5N ' A. Signet X ? Agent ? Addressee Bri nted N eJ C. Date of Delivery D. Is delivery address different from item 1? ? Yes If YES, enter delivery address below: ? No ^ e ' 3. Service Type /461-x a-? )d Certified Mail ? Express Mail ? Registered ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. Fee) es 2. Article Number (rrarWwfrom, service h 7005 3110 0004 2994 4511 PS Form 3811, February 2004 Domestic Return Receipt 102595-02-M-1 540 EXHIBIT "A" CERTIFIED MAIL RETURN RECEIPT CARD ci