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Home My WebLink About06-2799MOHAMED SAFOUAN, Plaintiff VS. WENDI JO SAFOUAN Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. C& a 799 Cu.?l : CIVIL ACTION - LAW : IN DIVORCE NOTICE TO DEFEND AND CLAIM 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 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 the divorce is 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, Cumberland County, 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. 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 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 2 LIBERTY AVENUE CARLISLE, PA 17013 Telephone: (717) 249-3166 BATURIN & BATURIN By: f yyy (11 - HARRY M. BATURIN, ESQUIRE Attorney I.D. No. 83006 2604 North Second Street Harrisburg, PA 17110 Dated: May % 2006 (717) 234-2427 MOHAMED SAFOUAN, Plaintiff VS. WENDI JO SAFOUAN Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. D(, _2 I99 Ctx/ 7-e, : CIVIL ACTION - LAW : IN DIVORCE COUNT I COMPLAINT UNDER SECTION 3301(C) and 3301(D) OF THE DIVORCE CODE AND NOW, this 9th day of May, 2006, comes the Plaintiff, MOHAMED SAFOUAN, by and through his attorneys, the Law Offices of BATURIN & BATURIN, and respectfully represents the following: 1. The Plaintiff is MOHAMED SAFOUAN, an adult individual, sui juris, with a social security number of 161-78-8392, and whose home address is 221 Chestnut Street, Mt. Holly Springs, Cumberland County, Pennsylvania 17065, and has resided there for at least five years. 2. The Defendant is WENDI JO SAFOUAN, an adult individual, sui juris, with a social security number of 198-54-6180, and who currently resides at 221 Chestnut Street, Mt. Holly Springs, Cumberland County, Pennsylvania 17065, and has resided there for a least five years. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. - 1 - 4. The Plaintiff and Defendant were married on April 8, 1999, in Chambersburg, Franklin County, Pennsylvania.. 5. There have been no prior actions for divorce or for annulment between the parties. 6. 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. The Defendant is not a member on active duty of the Armed Forces of the United States of America nor any of its allies. 8. The Plaintiff and Defendant are both citizens of the United States of America. 9. Plaintiff avers that there are is one child under the age of eighteen (18) years bom to this marriage. 10. The Plaintiff avers that the grounds upon which this action is based is that the marriage is irretrievably broken. 11. Plaintiff requests the Court to enter a Decree of Divorce. COUNT II COMPLAINT UNDER SECTION 3301(a)(6) OF THE DIVORCE CODE 12. All of the averments in Paragraphs 1 through 11 are incorporated herein as though each was set forth under Count H as in Count I. 13. In the alternative, Plaintiff avers that the Defendant hath offered such indignities to the person of the Plaintiff, the innocent and injured spouse, so as to render his condition intolerable and life burdensome. -2- WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce dissolving the marriage between the Plaintiff and Defendant and for such further relief as the Court may determine equitable and just. COUNT III CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 401 OF THE DIVORCE CODE 14. All of the averments in Paragraphs I through 13 are incorporated herein as though each was set forth under Count III as in Counts I, 11. 15. Plaintiff and Defendant have acquired property, both real and personal, during their marriage. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce: A. Dissolving the marriage between the Plaintiff and Defendant; B. Equitably distributing all marital property owned by the parties; and C. For such further relief as the Court may determine equitable and just. Respectfully submitted, BATURIN & BATURIN By: Harry M. Baturin, Esquire (Attorney I.D. No. 83006) 2604 North Second Street Harrisburg, PA 17110 (717) 234-2427 Attorney for Plaintiff -3- VERIFICATION I VERIFY THAT THE STATEMENTS MADE IN THIS COMPLAINT IN DIVORCE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, BELIEF AND INFORMATION. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA. C.S. 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. asl aq toe (SEAL) MOHAMED SAFOUAN -4- 0 -c Q o 0 N _ rn z =? ril C C ? rn Q MOHAMED SAFOUAN, Plaintiff VS. WENDI JO SAFOUAN Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2006 2799 Civil Term : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE I, Harry M. Baturin, Esquire, of the law firm of Baturin & Baturin, attorney for the Plaintiff in the above captioned matter, do hereby certify that on May 18 2006, I deposited in the United States Mail, at the United States Post Office, Harrisburg, Pennsylvania, an article of Certified Mail, Return Receipt Requested, marked "Restricted Delivery", a certified copy of the Complaint in Divorce and Notice to Defend and Claim Rights attached thereto, bearing Article No. 7004 1160 0003 3332 1332, addressed to: Wendi Jo Safouan, 221 Chestnut Street, Mt. Holly Springs, PA 17065. The said article of Certified Mail, as shown by the Postal Return Receipt Card was received by the Defendant herein on May 19, 2006, and according to same, was signed by her, to wit: Wendi Safouan, which card is attached hereto and marked as Exhibit "A", along with the deposit slip dated May 18, 2006, for said article of Certified Mail aforementioned. BATURIN & BATURIN By: arry M. Baturin, Esquire Attorney I.D. 83006 2604 North Second Street Harrisburg, PA 17110 (717) 234-2427 (Attorney for Plaintiff) Dated: May 31, 2006 r 1 U.S. Postal Service CERTIFIED MAIL,- RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) M I How' L P P M P-1" $ #4 63 ? 1 Q Certified Fee . $2.41T ? 4 11, ` P \ C3 EEndorHpulred) #1.$5 Os C3 A Fee (=='18R"-.q% ired) #3.74 . r-R Total Postage & Fees $ #$' 58 45(1 6 C3 ° Wendi Jo Safouan ° sneeriy"r'; 22fi1eCnll Strom------------------------ or PO Box No. - --------------------- - - City. State. ZIP+4 - - ---------°--------°------------------ - --------------------- Mt. Holly Springs, PA 17065 ¦ 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 pan return the card to you. ¦ Attach this card to the back of the mailpiece,. or on the front if space permits. Article Addressed to: Wendi Jo Safouan 221 Chestnut Street Mt. Holly Springs, PA 17065 A. X B. C. 13 D. Is davery address MWwd from item I? * If YES, enter dellwy address below: ? No 3. Service Type ? Ceruw mail ? Express mail ? Registered ? Return Reoetpt for Men;handlse ? insured mail ? C.O.D. 4. ReaUicted Delivery? (Fxha Fee) ? vas 2. Article Number (/tartailar from service kLw 7004 116 D D 03 3332 1332 Ps Form 3811, Febrwey 2DO4 Dmws* Return Rsosipt 102W -W4A-1540 EXHIBIT "A" C7 c; "' ? = fr% r cn CJ i MOHAMED SAFOUAN, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2006 2799 WENDI JO SAFOUAN 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 May 17, 2006. 2. The marriage of the 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 in 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. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: >1-) (*..t (Seal) f 6? r 2009 Pli'i ?'' ! v MOHAMED SAFOUAN, Plaintiff VS. WENDI JO SAFOUAN Defendant IN THE COURT OF COMMON PLEAS :CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006 2799 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on MY 11, 2006. 2. The marriage of the 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 in 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. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. A i ?f DATE: WENDI JO SAFOI(JAN 01, 'Ir 2009 VIAY 14 Pill 1: 514 Mohamed Safouan V. Wendi Jo Safouan IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2006 2799 DIVORCE DECREE AND NOW, _.,7'c~ e. ap Zo ~ a , it is ordered and decreed that Mohamed Safouan plaintiff, and Wendi Jo Safouan ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. ~..~~ ~~~ ~~~a~ y By the Court, Co ~ ~ ~ ~ t c~ ~... ~p~, nrta.~ l ~d -~o ~.. ~-~~ ~