Loading...
HomeMy WebLinkAbout06-2646 RADHIKA KUNREDDY, Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No. O('.;l.l. 'H.CIVIL TERM v. CIVIL ACTION - DIVORCE SUBOODH MANDA, Defendant NOTICE TO DEFEND AND CLAIM OF RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, 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 grounds for the divorce are 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 at the York County Courthouse. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle,PA 17013-3387 (717) 249 - 3166 AMERICAN WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of York Connty, Pennsylvania is required by law to comply with the American with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact the county at (717)771-9099. For those having a hearing impairment, please contact the DEAF CENTER at (717) 848 - 6765 TDD. 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. ~ . . RADIDKA KUNREDDY, Plaintiff : COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA v. SUBOODH MANDA, Defendant ; No 0 l.. . .;/ (. 'f c.. : CIVIL ACTION-LAW COMPLAINT IN DIVORCE PUSUANT TO SECTION 330UC) OR SECTION 3301 (p) OF TIlE DIVORCE CODE 1. The Plaintiff Radhika Kunreddy is an adult individual with an address of Camp Hill, P A 17011 2. The Defendant Suboodh Manda is an adult individual with an address of 700 TE Carriage Road, Carriage Park Apartments, Pittsburgh, P A 15220 3. The Defendant has been a resident of the Commonwealth of Pennsylvania for at least six (6) months immediately preceding the filing of the Complaint. 4. The parties were married on March 21,2003 in India. 5. The Plaintiff is not a citizen of the United States of America. The Defendant is not a citizen of the United States of America. 6. The Plaintiff has been advised of the availability of counseling and that she and the Defendant may have the right to request that the Court require the parties to participate in such counseling. COUNT I REOUEST FOR DIVORCE DUE TO IRRETRIEVABLE BREAKDOWN UNDER 330HC) OF TIlE DIVORCE CODE 7. Paragraphs 1- 6 of this Complaint are incorporated herein by reference as though set forth in full. 8. The marriage of the parties is irretrievably broken. 9. After ninety (90) days have elapsed from the date of filing of this Complaint, the Plaintiff intends to file an affidavit consenting to a divorce. .' . 10, The plaintiff has been advised of the availability of counseling and that she and the Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, the Plaintiff respectful1y requests the Court to enter a Decree in Divorce pursuant to 3301 (C) of the Divorce Code. COUNT n REOUESTFOR DIVORCE DUE TO IRRETRIEVABLE BREAKDOWN UNDER 3301(D) OF THE DIVORCE CODE 11. Paragraphs 1 - 10 of this Complaint are incorporated herein by reference as though set forth in full. 12. The Marriage of the parties is irretrievably broken. 13. After a period of two (2) years has elapsed from the date of separation, the Plaintiff intends to file an affidavit of having lived separate and apart. 14. The Plaintiff has been advised of the availability of counseling and the Plaintiff and the Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, the Plaintiff respectfully requests the Court to enter a Decree in Divorce pursuant to 3301 (D) of the Divorce Code. Date: '-(/2%f {, Michael J. Pykosh, squire Law Office of Darren C. Dethlefs Attorney for the Plaintiff 2132 Market Street Camp HiD, P A 17011 (717)975 - 9446 )lttr.ld.~0.S8851 .- . VERIFICil nON I, R a d ~ J-<.o.. 11 un v-ed d ~ ,verify that the statements made in this document are true and correct to my personal knowledge, information and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: eJl.-/ /2-6/ V 6 ~ \. ~ g. q. ~ ? ~ ~ -ocP ~ t9tXI ~ ~~ k..-!'.:- I Z-~, 'n:.. ~ (I) oJ,.; o.D .~~ 2:" ~C: -'0 %~ d - \,.. 1?T C) '::J'. ,""c.' f:? , ..;, '" 'PC "" '""' 11'. .. ~ cJ\ ~ <"' '" 0 ~ ..c 0 '~ , RilDIDKA KUNREDDY, Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY No. c;6-Z,6,..dcIVIL TERM v. CIVIL ilcTION - DIVORCE SUBOODH MilNDA, Defendant CERTIFICATE OF SERVICE I, Brian K. Zellner, Esquire, hereby certify that on the 13th day of May , 2006, I served a copy of the Complaint in Divorce on the Defendant as evidenced by the certified return mail receipt which is attached hereto. Date: <!f1!Ob 111{~ Michael J. Pykosh, Esquire Brian K. Zellner, Esquire ilttorney for the Plaintiff Attorney Id. No. 58851 2132 Market Street P.O. Box 368 Camp Hill, P A 17001 - 0368 . ,'" SENDER: .. . Complete ltetM 1 andIor 2 ror additional seTVices. t . Complete items 3,48, and 4b. I . Prmt your name and address on the reverse of this form so that we can return this C8rd to you. . Atlach this form to the front of the maHplece, or on the back it space does not . ~;Retum R9C8Ipt RequestedM on the mallpiece below the 'artiCle number. . The Retum Receipt win show to whom the article was del~ and the date de""""'. 3. Article Addressed to: S",JOclJ-t.. ;4"'~d. 7 (}() IE C~"~#(;e RJ. (,~YMi~ P....(c ~h P,t/:?L-:JL, I~ If, ~ 1 also wish to receive the following services (for an extra fee): 1. D Addressee's Address 2, D Restricted Delivery Consult postmaster for fee. A,.. ""'l...l,.. ""......h..... 7005 1160 0002 3088 9217 4b, Service Type D Registered D Express Mail Return Receipt for M6r<:handise te of Delivery -<> 'P ~rtlfied D Insured DeOD essee's Address (Only If requested fee is peid) ,~ i I r 1 ~ I J 'pt g -y -r.,~r 11"1T'1 \ 7" it,l: -:5 \"': :~(?~.) 7C ~ ~ """ <T' % ~ , . - ~ '::C..... ", r=: -om cn\? i;3c) >:H :'5 .~.- "'7 B ::4 ~ cP ~ - - <.1' W RADHIKA KUNREDDY, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2646 CIVIL TERM SUBOODH MANDA, Defendant CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on or about May 18, 2006. 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. 4. I understand that if a claim for alimony, alimony pendente lite, marital property, counsel fees, or expenses has not been filed with the Court before the entry of a final decree in divorce, the right to claim any of them will be lost. 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.SA Section 4904 relating to unsworn falsification to authorities. Date: ~'I/ /2.066 SUboo~fendant {,"") -'t~ __A ," . .(3. .~- { J"'\ RADHIKA KUNREDDY, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2646 CIVIL TERM SUBOODH MANDA, Defendant CIVIL ACTION - 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 entry of a final decree of divorce without notice. 2. I understand that I may Jose 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 a decree will be sent to me immediately after it is filed with the Prothonotary. 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.SASection 4904 relating to unsworn falsification to authorities. Date: q 111 ) 2Ci>6 ~~J~ Saboodh Manda, Defendant -TI : ,.-, ::::1 \ ,-:. ( -.' ,r oe)~""AL RADHIKA KUNREDDY, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2646 CIVIL TERM SUBOODH MANDA, Defendant CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT 1, A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on or about May 18, 2006. 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. J consent to the entry of a final decree of divorce. 4. I understand that if a claim for alimony, alimony pendente lite, marital property, counsel fees, or expenses has not been filed with the Court before the entry of a final decree in divorce, the right to claim any of them will be lost. 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.SA Section 4904 relating to unsworn falsification to authorities. Date: 10 I" I 06 ~ Radhika Kunreddy, Plaintiff o ~;; "--', ';;;;(\ CI \. ~ - G' -\J -- r;r\ C.., ol2!~'WAl RADHIKA KUNREDDY, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-2646 CIVIL TERM SUBOODH MANDA, Defendant CIVIL ACTION - 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 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 a decree will be sent to me immediately after it is filed with the Prothonotary . 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.A.Section 4904 relating to unsworn falsification to authorities. Date: 10) II I 0 6 . ~ -.. Radhika Kunreddy, Plaintiff (') S'; 1"'-:> -~ 'c:-~ o. -"~;. 0'" ~ RADHIKA KUNREDDY, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2646 CIVIL TERM SUBOODH MANDA, Defendant CIVIL ACTION - LAW DIVORCE ACTION PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under Section (x) 3301 C ( ) 3301 D of the Divorce Code. (Check applicable code) 2, Date and manner of service of the complaint: Certified Mail on Mav 13. 2006. Certificate of Service and Qreen card were filed. 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 10-11-06; by defendant 9-11-06. (B) (1) Date of execution of the plaintiffs affidavit required by Section 3301 (D) of the Divorce Code: N/A; (2) Date of filing and service of the plaintiff's affidavit upon the respondent N/A. 4. Related claims pending: None 5. (Complete either (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 plaintiffs Waiver of Notice in ~ 3301 (c) Divorce was filed with the Prothonotary: 10-11-06 Date defendant's Waiver of Notice in 9 3301 (c) Divorce filed with the Prothonotary: 9-11-06 Michael . Posh, Esquire Attorne Identification No. 58851 2132 Market Street Camp Hill, PA 17011 (717) 975-9446 Attorney for Plaintiff r-' C~, C=::1 c:r- -""::'? .....~- ~ N -l s: C Ln '" :Ii "'''':Ii ~ "'''' '" "''''~ '" "':Ii~"'''':Ii :Ii:li:li"''''''''''~'''~:Ii :Ii~'" :Ii :Ii ,.,'" '" "'''':Ii '" IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. Radhika Kunreddy, No. 06-2646 Plaintiff VERSUS Suboodh Marrla, Deferrlant DECREE IN DIVORCE AND NOW,_~t0'" t ) 7 2006 , IT IS ORDERED AND DECREED THAT Radhika Kunreddy , PLAINTIFF, AND Suboodh Marrla , DEFENDANT, 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; None J. .C~OTHONOTARY "'''' :Ii '" '" "'''':Ii'''''' "'''''''''',.,,.,''''''~''''''''' "'''''''''''''~'''~''':f. '" "'''',.,,.,~~~ "'''',.,,., '" ~;+o"'~ . h '?- /'P'~ ~ -:p. h-t:r ~ pp ~4.,7 -;n; ,?~.I>-el . --'. ..