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Home My WebLink About05-4303 (j NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 8738U 37 SOUTH HANOVER STREET, SUITE 201 CARUSLE PA 17Un (717) 241-4436 ATTORNEY FOR PLAINTIFF Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ANIS ABU-AIADEH, v. : CIVIL ACTION -- LAW ; NO. 05 - .L..f. ~ ~ J, CIVIL TERM : IN DIVORCE NICHOLE L. ABU-AIADEH, Defendant 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 maniage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Gunberland CounryCourthouse, 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 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ANIS ABU-AIADEH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION -- LAW ;NO.05- /j.h")., CIVIL TERM : IN DIVORCE NICHOLE L. ABU-AIADEH, Defendant COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(C) OF THE DIVORCE CODE NOW, comes the plaintiff and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Anis Abu-Aiadeh, an adult individual residing at 560 West North Street, Carlisle Borough, Cumberland County, Pennsylvania 17013. 2. The defendant is Nichole Abu--Aiadeh, an adult individual residing at 156 Oak Hill Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The plaintiff and defendant 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 24,2003, in Carlisle, Gunberland County, 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 said party 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 and for such funher relief as this Honorable Court may deem equitable and just. I verify that the statements made in this complaint 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. A"f l-r ,2005 Anis Abu-Aiadeh, Plaintiff WOLF & WOLF lli/ui/5'i /7 ,2005 0 ..{,Q.. p -- T' -a ~ \t- O ~ - --- D- r ..c ~ ~ ~ ~ \) "'0 ~ n +- -I:- <-.:1 (:'~. r:~ ~ ~ ';;'" -:::(-~ ~ f'''\~;''- " ,O.<;;:'....)~ (j -b.... r-" \'-;J() t.;o) -,,'>, ~n -.-... ,,~-'... ~ '., -:::~ '~.~-~\ ~ (....1-\, rJ 'y ." .~ ...- .~ cP ~ ----- NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ANIS ABU--AIADEH, v. : CIVIL ACTION -- LAW NICHOLE L. ABU-AIADEH, Defendant ; NO. 05 - "1263 : IN DIVORCE CIVIL TERM 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 maniage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of maniage 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. CS. S n 4904 relating to unsworn falsification to authorities. A~I--t:Y ,2005 ~ u-Aiadeh, Plaintiff o (~~; ......;c;' i<'\ :; .....' = = <~1 ? C G) N 0-' -c ~, ---- ~ ..-\ ?f;~ ~OfT', "Y %:~, 'c:jrn ::::l ~1) '.;':: t;? '" o NATHANC. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF ANIS ABU--AIADEH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW ; NO. 05 - ~'6()3 : IN DIVORCE CIVIL TERM NICHOLE L. ABU-AIADEH, Defendant AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RUT.R NO. 1920.4 (a)(l)(i) NOW, Nathan C Wolf, 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 setved upon the defendant on or about 1/ '! / oS- , by certified mail "restricted deIivety," addressed to the defendant at 156 OakHiII Road, Carlisle, Pennsylvania 17013 return receipt No. 70033 /(0 00 o'f 5'1'1/ 35'-"3. 3. hereto. 'That a copy of the sender's receipt and signed receipt for certified mail is attached 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. l~ r~f' /(0,2005 m ..n Ul m M f'- f'- Ul U.S. Postal Service," CERTIFIED MAIL RECEIPT (Domestic Mail Only; No Insurance Coverag~""> Provided) Postage $ c.(i)sF pI':; 711;(; z o o o CertIfied Fee - Retum Reclept Fee (Endorsement RequIred) o Restrfcted Delivery Fee ..-=I (Endorsement Required) M m 09/0912005 $ $8.15 Total Postage & Fees m R ;~:.'!!J.~&.?I=-.l!.h..~.=1/~r!~iL.m___"h'''__h'''' o:.7!i~::;:;..!..2..fe../2.ej?..l6.f{t:d:.....m'h.m...m...... C'Y.SlBtB,z''''tar fS/~ (iff /70/3 . 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 mallpiece, or on the front if space pennits. 1. Article Addressed to: -rv' ich6/e-7JblA.-rj l~deA /5'(,. OtJ-k.. IIi/I Rd, \Url!b/~ f P-t /70/3 o Agent o Addressee C. Date of Delivery [:J Yes o No \ 3. $epice Type 11 Certified Mall [:J Exptess Mall o Registered 0 Return Receipt for MerchandIse o Insured Mail 0 C.O.D. 4. Restricted Delivery'? (E)<tnl Fee) Yes 2. Article NumbElr {Transfer from seMcelabeJ) PS Form 3811, February 2004 7003 3110 0004 5771 3563 Domestic Return Receipt 102595-Q2-M-154Q r-' ","" ~ <I> rn -0 g S '"0 OJ mrn -;i:r.i ~r- th1? 2e' oc:: ~:;(2 .~tj :PC Z ::! - u::> ~ ;;;1 n..~.'~. -01- . ~:;::) '" >~\~~\ ':,"';C) ;;~fn '::::, .~~ -0 - r:--; ,n (/ STACY B. WOLF, ESQUIRE ATIORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATIORNEY FOR PLAINTIFF Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ANIS ABU-AlADEH, v. : CIVIL ACTION - LAW NICHOLE L. ABU-AlADEH, Defendant : NO. 05 - 4303 CIVIL TERM : IN DIVORCE PRAECIPE TO WITHDRAW DIVORCE COMPLAINT TO THE PROTHONOTARY: Please withdraw the Complaint filed by Plaintiff on August 23, 2005, in the above-captioned matter. Respectfully submitted, WOLF & WOLF SeptemberJ(l, 2006 ~~~ BY: -;TACY B. OLF~ ESQUI 10 West High Street Carlisle, PA 17013 717-241-4436 SUPREME COURT ID #88732 Attorney for Plaintiff ~ ~ ~ ""0 t;; g ~. -o~ ~'):, ~~:. :..c:. ".~ f.2..0 ?iO =Q yC~ ~ ~ ~:Q ~~ ~o b ~~~ t> --- ;~ ~ ~ ~ '-R J:'" c:P