HomeMy WebLinkAbout06-3454
D.
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Plaintiff
)
)
)
)
)
)
)
)
Case Number: ~ - 3 cfW C-:.vi I
Sherifa D. Zuhur
v.
Judge:
Abmad B. Zalat
Defendant
Notice to Defend and Claim Rights
TO: Ahmad B. Zalat
You have been sued in Court. If you wish to defend against the claim 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
child(ren).
When the grounds for divorce are indignities or irretrievable breakdown of the marriage, you may
request marri~ge counseling. A list of marriage counselors is available in the office of the prothonotary
at Gr\i s Ie ,Pennsylvania.
If you do not file a claim for alimony, division of property, lawyers 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.
Lawyer Referral Service:
~l\;;~l""''''~~:; p,..",~,~"",
~~;;\~ f>~.'~'40~2 ",,-\1, aE'J~.-J S-+,
Phone:Qlll ~~ {;g~l 2"1.Q '3\' 6
Date: Glll\v \S 200.( .
S ~ t.t\ f''lI. ZlI ~('
Print Name (Plaintiff)
~~
Signature ( ainti
Mailing Address: 341 Garland Dr., Carlisle, PA, 17013
Phone: 717-243-2887
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Plaintiff
)
)
)
)
)
)
)
)
Case Number: CJ(, - 3 <f.s y
Sherifa D. Zuhur
V.
Judge:
Ahmad B. Zalat
Defendant
Complaint for Divorce
This suit is brought by Sherif a D. Zuhur, the Plaintiff, Pro Se, Social Security #: 568-784556,
Drivers License/State ID #: 28547932, age 52 years old, who resides at: 341 Garland Dr.,
Carlisle, PA, 17013 with a home phone number of: 717-243-2887.
Defendant is Ahmad B. Zalat, Pro Se, Social Security #: 168-78-3977, Drivers License/State ID
#: 26058915, age 37 years old, who resides at: 19-21 South 4th St., Harrisburg, Pennsylvania,
17010 with a home phone number of: 717-448-9063.
I. RESIDENCY:
The Plaintiff has been a resident of the State of Pennsylvania for the preceding 6 (six) months and
a resident of the county in which this Complaint for Divorce is filed for the preceding 10 (ten)
days.
II. MILITARY STATUS:
The Plaintiff is NOT active in the United States Military.
The Defendant is NOT active in the United States Military.
III. SERVICE OF PROCESS:
A Waiver of Citation will be filed by the Defendant, therefore, no service is necessary at this
time.
IV. JURISDICTION:
The Court has the required jurisdiction to hear this case. Neither party has ever been involved in
any other domestic relations proceedings involving the other party in this or any other
jurisdiction.
V. MARRIAGE:
The parties were married on February 8, 2006 in the city of Carlisle, in the state of Pennsylvania,
and separated on or about, May 15,2006, at which time they separated and ceased to live together
with the intent to tenninate the marriage.
An official marriage license is attached to this Complaint for Divorce for reference.
VI. GROUNDS:
Irretrievable breakdown of the marriage and the spouses intend to file affidavits that they consent
to the divorce.
VII. PREGNANCY:
The Plaintiff is not currently pregnant.
VIII. CIDLDREN:
There are no minor children born or legally adopted of the marriage.
IX. PROPERTY AND DEBT: ,NDN'2'
The property and debt, and other related issues, will be settled by a formal written Marital
Settlement Agreement, which will be submitted to the Court.
X. RETIREMENT ACCOUNTS:
The retirement accounts, and other related issues, will be settled by a fonnal written Marital
Settlement Agreement, which will be submitted to the Court.
XI. SPOUSAL SUPPORT:
The spousal support, and other related issues, will be settled by a fonnal written Marital
Settlement Agreement, which will be submitted to the Court.
XII. HEALTH INSURANCE:
The health insurance, and other related issues, will be settled by a fonnal written Marital
Settlement Agreement, which will be submitted to the Court.
XIII. TAX ISSUES:
The tax issues will be settled by a fonnal written Marital Settlement Agreement, which will be
submitted to the Court.
XIV. PROTECTIVE ORDERS:
There are no protective orders between the Plaintiff and Defendant.
XV. PRAYER:
The Plaintiff respectfully requests this Honorable Court to grant this Divorce pursuant to Section
3301 (c), or on the alternative, Section 3301 (d) of the Divorce Code.
XVI. REPRESENTATION
The Plaintiff has chosen to act as her own attorney in a pro se fashion, and understands that she
has the legal right to representation by an attorney. She fully understands her rights and consider the
tenns of the attached Marital Settlement Agreement to be fair and reasonable.
XVII. VERIFICATION
I verify that the statements made in the Complaint for Divorce are true and correct. I understand
that false statements made herein are subject to penalties of 18 Pa. C.S.A. Section 4904, relating to
unsworn falsification to authorities.
Date:
:)\If\t. \'> 'taa,'
Shpr\-Po. ZUhltf'
Print Name (Plaintiff, Pro Se)
~,~~
Signature (Plaintlh', Pro ~)
Mailing Address: 341 Garland Dr., Carlisle, PA, 17013
Phone: 717-243-2887
COUNTY COURT OF COMMON PLEAS
INTAKE
This form must be filled out If you are rIling a divorce or custody action In the Prothonotary's
Office:
Today's Date:
Case Number::
Please Check One:
ex) Divorce Filing - No Children
U Divorce Filing - With Children Under 18
U Custody Filing - With Children Under 18
Plaintiff Name, Address and Phone:
Name: Sherifa D. Zuhur
Address; 341 Garland Dr., Carlisle, PA, 17013
Phone: 717-243-2887
Defendant Name, Address and Phone:
Name: Ahmad B. Zalat
Address: 19-21 South 4th St., Harrisburg, Pennsylvania, 17010
Phone: 717-448-9063
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Plaintiff
)
)
)
)
)
)
)
)
Case Number:
Sherifa D. Zubur
v.
Judge:
Abmad B. Zalat
Defendant
Affidavit of Verification
THE STATE OF: PA
COUNTY OF: Cumberland
BEFORE ME, Sherifa D. Zuhur, the undersigned authority and the Plaintiff in the above referenced
case, on this day personally appeared who, being by me duly sworn, upon oath says:
My name is: Sherifa D. Zuhur
Social Security #: 568-78-4556
Driver's License! State ID #: 28547932
My mailing address is:
341 Garland Dr., Carlisle, P A, 17013
Phone: 717-243-2887
The facts contained within the foregoing Complaint for Divorce are true and correct to the best of my
knowledge, information, and belief, and that I am authorized to make this affidavit.
Date: ~ ~~
~"-t.r\f'.... Z~V
Print Name (Plaintiff)
S~~:
SWORN TO AND SUBSCRIBED BEFORE ME by the said C 0-...
on this ---l f}
certify which witness my hand and seal of office.
,j\"{;1\t.- ~ to
Njb.~
Notary Seal
My commission expires: at d-J ~
NOtARIAL SEAL
ANN FREMN. '!'!!I~
CARlJ8lE 8OROUGl4, W~ CClUII'IY
MVCOMM\8SIOM~- -
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Plaintiff
)
)
)
)
)
)
)
)
Case Number:
Sherifa D. Zuhur
v.
Judge:
Ahmad B. Zalat
Defendant
Domestic Relations Income and Expense Statement
(Plaintiff)
This affidavit has been completed by Sherifa D. Zuhur, the Plaintiff, and is the actual monthly
financial information as of, ~ Un.... H. , "Lo-Ct' (date)
Information About Plaintiff:
Name: Sherifa D. Zuhur
Social Security Number: 568-78-4556
Driver's License/State ID Number: 28547932
Issuing State: Pennsylvania
Age: 52
Birth Date: August 31, 1953
Current Residence Address: 341 Garland Dr., Carlisle, PA, 17013
Mailing Address: 341 Garland Dr., Carlisle, PA, 17013
Home Telephone Number: 717-243-2887
Name of Employer: Institute ofM. Eastern Studies and Carlisle Barracks
Address of Employment: 341 Garland Dr., Carlisle, PA, 17013
Work Telephone Number: 717-448-9076
A. Statement of Monthlv Income and Deductions
Plaintiff
$ 7 'tit , It
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$~
1. Gross Income Per Month
a. Salary/W ages
b. Draw
c. Bonus
d. Pension
e. Annuitly
f. Social Security
g. Dividends
h. Interest
i. Trusts
j. Public Aid
k. Worker's Compensation
1. Unemployment Compensation
m. Rents
n. Disability Payments
o. Stocks
p. Bonds
q. Other (specifY)
r. Other (specifY)
s. Other (specifY)
-
-
...
....
-
-
-
-
-
-
TOTAL GROSS MONTHLY INCOME...
2. Required Deductions
a. Federal Taxes (based oniexemptions)
b. State Taxes (based on~exemptions)
c. Social Security (or pension equivalent)
d. Mandatory retirement contributions
required by law or as a condition of
employment
e. Union Dues
f. Health Insurance
g. Prior obligation of support actually paid
pursuant to court order.
h. Expenditures for repayment of debts that
represent reasonable and necessary
expenses for the production of income
i. Medical expenditures necessary to preserve
life or health
j. Reasonable expenditures for the benefit of
the child and the other parent exclusive
of gifts (for non-custodial parent only)
TOTAL MONTHLY DiUCTlONS... )
;. 9\'11 f\1I-r ,"c\ud(,.. 1\I..i'A- S..",\,,,C ~:H~"'~~
Plaintiff
$-\0'1 ~ U
$ ?" ,g
$ "'~c; s&
$~$_ 'b"O!O
yrltJ \\0...... $ n
'12..0 ' .S
$
$
$
3~'
$
$ '2 '2J11o
$S'~U.
...lr
B. Monthlv Livinl1 Expenses
1. Household
a. Mortgage or Rent
b. Taxes, assessments, and insurance
c. Maintenance and repairs
d. Heat/fuel
e. Electricity Iht., 't
f. Telephone
g. Water and sewer
h. Refuse removal
i. Laundry/dry cleaning
j. Maid/cleaning service
k. Furniture and appliance replacement
1. Food (groceries, etc.)
m, Tobacco products
n. Alcohol products
o. Other (specify)
Subtotal Household Expenses...
2. Transportation
a. Gasoline
b. Repairs
c. InsurancelLicense
d. Payments/Replacement
e. Alternative Transportation
f. Other (specify '.
..L-
Subtotal Transportation Expenses...
3. Personal
a. Clothing
b. Grooming
c. Medical (doctors)
d. Insurance
e. Spousal Support ::;rt~e) d .c. \ t"
f. Other (specify) Ut:0I' al\ ~
Subtotal Personal Expenses...
~1WIl\1
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
$
Plaintiff
\2.'1'1. 10
I 1 ~,.
lot"....
'1& to
I' 0 ..
I so '0
~.. '0
2 'i ...
'2JJ"
n
()
5 ~ 0 "
S.,
.~
(j
'2..'1'1.100
$
$
$
$
$
$
$
Plaintiff
,\'2..'0
..
\~~..o
-oe
-
lh<600
$
$
$
$
$
$
Plaintiff, 0
~110.,
25""
\ nO 00
,1
$-----U-.5-
4. Miscellaneous Plaintiff
a. Clubs/Entertainment $ -
b. Newspaper/Magazines $ ...
c. GiftslDonations $ ...
d. Vacations $ -
e. Other (specify) c:,,' k. 1V $ ~, .'
5' ..
Subtotal Misc. Expenses... $
5. Children
a. Clothing
b. Grooming f' \ I ,,"v ll... It \J u.. - ....+ R:
c. Education 'Wt' '2. 't.. u'"'''"''' 'r 't
. -+t\.'~ 'IW\.a.rt1'""
d. Medical (doctors) v
e. Allowance
f. Child care
g. Baby-sitters
h. Lessons
i. Clubs/Summer Camp
j. Entertainment
k. Support (other childen)
I. Other (specify) (..01'....0.... S...oI\"tj
Snbtotal Child Expenses...
TOTAL MONTHLY EXPENSES...
C. Debts Requirine Reenlar Payment
Plaintiff:
1. creditor:~~i~'~ Balance: $_\'!. 0 CI Mon. Min.$
2. Creditor: l kl'" \eA:; Balance: $ j \ ~ 0 G Mon. Min.$
3. Creditor:____ _ _ Balance: $ ")... q 0 Mon. Min.$
4.Creditor:--.J)",~J Vn... Balance: $ 2nCt"1 Mon.Min.$
5. Creditor: l"~....t I (;.to.. E Balance: $----1n-Mon. Min.$
~. O~h",*"u~-.! '150
1. 'IS."..,...... '30"7
TOTAL MONTHLY DEBT EXPENSES...
D. Cnmmnlative Overview
Plaintiff
$ .!O · ·
$ l!\ .,
$ 7~O o.
$ ~O 00
$ 2.() 0'
$ -
$ \~O '"
$ "'1"
$ l'"
$ .... ^ ...
$ ~
$~"
$ lO'lS"
$
Plaintiff .'
~ 'i3-)
~o"
1 $1; ..
!:o "
5''1''
it, II
ISO"
o ..
I Plaintiff
$ , I? d
INCOME AVAILABLE PER MONTH...
(income less expenses and debt)
Plaintiff
$ 523S"
$~'"
$ "'2..0.
$~.'
$~."
1. Total Itemization & Calculation
TOTAL MONTHLY INCOME...
TOTAL MONTHLY EXPENSES...
TOTAL MONTHLY DEBT...
(income less expenses)
I verify that the statements made in this affidavit are true and correct. I understand that false statements
here-in are made suhject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to
authorities.
Date:
<A~iffo\. 7.."",,...
Plaintiff (print name)
~.....~""'
PI~gnatUre,
Prepared By: Sherif a D. Zuhur
Address: 341 Garland Dr., Carlisle, P A, 17013
Phone: 717-243-2887
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Plaintiff
)
)
)
)
)
)
)
)
Case Number:
Sherifa D. Zuhur
v.
Judge:
Ahmad B. 1,alat
Defendant
Domestic Relations Income and Expense Statement
(Defendant)
This affidavit has beeu completed by Ahmad B. Zalat, the Defendant, and is the actual monthly
financial information as of, "0lJ1\L \S ,"2.1)0 , (date)
Information About Defendant:
NlUIle: Ahmad B. Zalat
Social Security Number: 168-78-3977
Driver's License/State ID Number: 26058915
Issuing State: Pennsylvania
Age: 37
Birth Date: November 24, 1968
Current Residence Address: 19-21 South 4th St., Harrisburg, Pennsylvania, 17010
Mailing Address: 341 Garland Dr., Carlisle, Pennsylvania, 17013
Home Telephone Number: 717-448-9063
NlUIle of Employer: Country Oven Restaurant
Address of Employment: 1245 Harrisburg Pike, Carlisle, Pennsylvania, 17013
Work Telephone Number: 717-448-9063
A. Statement of Monthly Income and Deductions
1. Gross Income Per Month I, T C~t.t.1\ Defendant
a. Salary/Wages ~rM. C~ $ I} 000 ...
b. Draw $ -
c. Bonus $ -
d. Pension $ ...
e. Annuitly $ -
f. Social Security $
g. Dividends $
h. Interest $
i. Trusts $ -
j. Public Aid $
k. Worker's Compensation $ -
1. Unemployment Compensation $ -
m. Rents $ -
n. Disability Payments $
o. Stocks $
p. Bonds $ -
q. Other (specifY) $ .....
r. Other (specifY) $ -
s. Other (specifY) $ -
TOTAL GROSS MONTHLY INCOME... $ \ 600f1l
2. Required Deductions Defendant
a. Federal Taxes (based on~exemptions) $ I D"
b. State Taxes (based on_exemptions) $ 1"
c. Social Security (or pension equivalent) $ ~.
d. Mandatory retirement contributions
required by law or as a condition of
employment $ $
e. Union Dues $ -
f. Health Insurance
g. Prior obligation of support actually paid $
pursuant to court order.
h. Expenditures for repayment of debts that
represent reasonable and necessary $
expenses for the production of income
i. Medical expenditures necessary to preserve $
life or health
j. Reasonable expenditures for the benefit of
the child and the other parent exclusive $ -
of gifts (for non-custodial parent only) 30'0
$
TOTAL MONTHLY DEUCTlONS...
B. Monthlv Living Expenses
1. Household
a. Mortgage or Rent
b. Taxes, assessments, and insurance
c. Maintenance and repairs
d. Heat/fuel
e. Electricity
f. Telephone
g. Water and sewer
h. Refuse removal
i. Laundry/dry cleaning
j. Maid/cleaning service
k. Furniture and appliance replacement
1. Food (groceries, etc.)
m. Tobacco products
n. Alcohol products
o. Other (specifY)
Defendant
$ .~()llItO
$ ~ /P'
$ () ,.
$ C> 00
$ 0 ,0
$ 0 01
$ () ,.,
$ 0 If
$ C) ,.
$ 0 ,.
$ ~O
$ 30~ "v..'
~ (j ,.,11l
$ ~ /to
$~.O
Subtotal Household Expenses...
2. Transportation
a. Gasoline
b. Repairs
c. Insurance/License
d. Payments/Replacement
e. Alternative Transportation
f. Other (specifY)
$
$
$
$
$
$
$
Defendant
1..0 b"
. .
o ,e
@u
8 ..
o ..
11)0 ..
Subtotal Transportation Expenses...
3. Personal
a. Clothing
b. Grooming
c. Medical (doctors)
d. Insurance
e. Spousal Support (past marriage)
f. Other (specifY)
Defendant
$ 30 ' ·
$ ISO 0
$ '20 It
$ ()
$ 6
$
6..
$~
Subtotal Personal Expenses...
4. Miscellaneous Defendant
a. ClubslEntertainment $ -
b. Newspaper/Magazines $ -
c. Gifts/Donations $ -
d. Vacations $ -
.. -~
e. Other (specifY) $
Subtotal Misc. Expenses... $ .. O:aO
5. Children Defendant
a. Clothing $
b. Grooming $
c. Education $
d. Medical (doctors) $
e. Allowance $
f. Child care $
g. Baby-sitters $
h. Lessons $
i. Clubs/Summer ClUIlp $
j. Entertainment $ _ Ai II
k. Support (other childen) , $ 0
1. Other (specifY) $
Subtotal Child Expenses... $ o to
TOTAL MONTHLY EXPENSES...
$
D(,~~ ,
Co Debts Requirinl! Rel!ular Payment
Defendant:
1. Creditor:
2. Creditor:
3. Creditor:
4. Creditor:
5. Creditor:
(\u"'l,
Mon. Min.$
Mon. Min.$
Mon. Min.$
Mon. Min.$
Mon. Min.$
Balance: $
Balance: $
Balance: $
Balance: $
Balance: $
TOTAL MONTHLY DEBT EXPENSES...
$
Defendant.
o 0
D. Cummulative Overview
1. Total Itemization & Calculation
TOTAL MONTHLY INCOME...
TOTAL MONTHLY EXPENSES...
TOTAL MONTHLY DEBT...
(income less expenses)
Defendant _ 0
~~.
$ 9=.'.
$ It
[35 u
INCOME AVAILABLE PER MONTH...
(income less expenses and debt)
$
I verifY that the statements made in this affidavit are true and correct. I understand that false statements
here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to
authorities.
Date: U\SM.. \ S ) 2.00 f
fthlY\f.J ZIA'~
DZj(p;nt;:Jt
Defendant (signature)
Prepared By: Ahmad B. Zalat
Address: 341 Garland Dr., Carlisle, Pennsylvania, 17013
Phone: 717-448-9063
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Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Sherifa D. Zuhur
Plaintiff
)
)
)
)
)
)
)
Case Number: OG.-S ~ SLr
v.
Ahmad B. Zalat
Judge:
Defendant
ACCEPTANCE OF SERVICE
I acknowledge service and receipt of the Complaint for Divorce filed in the Court of Common
Pleas, Cumberland County, Pennsylvania. In addition to the Complaint, I was served with
complete copies of the Affidavit of Verification, the Plaintiffs and Defendant's Domestic
Relations Income and Expense Statements, and the Notice to Defend and Claim Rights.
I have been informed ofthe law suit filed in this matter and was provided with information on
marriage counseling, and the address of an attorney referral service for Cumberland County.
Date: '0\7" tJ \ <l ) ~OD b
Signature J,pJ e~
Address of Service:
~~ \ ~rlG..J ,,~
Co..("\,'~tt. p~^ 5\1 I v~~~''L l18\)
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Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Sherifa D. Zuhur
Case Number: CJ b- S~S'\
Plaintiff
)
)
)
)
)
)
)
Judge:
v.
Ahmad B. Zalat
Defendant
Marital Settlement Agreement
This agreement is made on June 15,2006 between
Sherifa D. Zuhur, the Plaintiff, with a social security number of 568-78-4556,
who lives at 341 Garland Dr., Carlisle, PA, 17013 (home phone: 717-243-
2887) and the county of Cumberland and Ahmad B. Zalat, the Defendant,
with a social security number of 168-78-3977, who is currently staying with
friends in the county of Cumberland at an unknown address (cell phone: 717
- 448-9063)
The Plaintiff and Defendant may from time to time throughout this
agreement, individually and collectively, be referred to as "Party" or
"Parties".
The Plaintiff is currently employed in a civilian status by the U.S. Army War
College, Carlisle Barracks
The Defendant is employed by Country Oven Restaurant.
I. Recitals:
The parties are making this agreement with reference to the
following facts:
The parties were married on February 8,2006 in the city of Carlisle,
in the state of Pennsylvania, and separated on or about, May 15,
2006.
As a result of serious disputes, conflict of personalities, and unique
goals and differences, the parties honestly believe that the marriage is
irretrievably broken and that there is no possible chance for
reconciliation. For this reason each party desires to settle fully and
finally all aspects and rights, by this agreement, of the marital affairs
including, but not limited to; Property and Debt Distribution,
Retirement/PensionlProfit Sharing/401k Accounts, Spousal
Maintenance, and Income Tax Returns.
There are no children born or legally adopted of the marriage under
the age of eighteen (IS).
The parties each now intend by this agreement to settle fully and
finally all of their respective rights and obligations arising out of or
related to the marriage that otherwise could be adjudicated in the
above captioned case number.
There is no other pending action filed by either party regarding the
dissolution of the marriage.
The date of execution ofthis agreement is the day on which the
agreement is signed by both parties.
Any transfer of property, funds, debts and/or documents pursuant to
the agreement shall be made on the date of the execution of this
agreement, ifnot already done so, unless otherwise specified in this
agreement.
The parties both agree to lead separate lives, and, except for the
duties and obligations imposed and assumed under this agreement,
each shall be free from interference and control of the other as fully
as ifhe or she were single. The parties each agree not to molest,
interfere with, or harass the other.
II. Property and Debt Distribntion:
As of February S, 2006, the parties have each possessed his and her
marital and non-marital property and have been responsible for the
marital and non-marital (separate) debt that will be described below.
The parties agree that the following marital property shall be the sole
and separate property of Ahmad B. Zalat, the Defendant, and Sherifa
D. Zuhur, the Plaintiff transfers and quitclaims any interest that she
may have in this marital property to the Defendant:
None.
The parties agree that the following marital property shall be the sole
and separate property of Sherifa D. Zuhur, the Plaintiff, and Ahmad
B. Zalat, the Defendant transfers and quitclaims any interest that he
may have in this marital property to the Plaintiff:
Any possible portion of341 Garland Dr. Carlisle..
The parties agree that Ahmad B. Zalat, the Defendant, shall pay and
indemnify and hold Sherifa D. Zuhur, the Plaintiff, harmless from the
following marital debts:
None.
The parties agree that Sherifa D. Zuhur, the Plaintiff, shall pay and
indemnify and hold Ahmad B. Zalat, the Defendant, harmless from
the following marital debts:
None.
The parties agree that the following non-marital (separate) property
shall be the sole and separate property of Ahmad B. Zalat, the
Defendant, and Sherifa D. Zuhur, the Plaintiff transfers and
quitclaims any interest that she may have in this non-marital (separate)
property to the Defendant:
PNC Bank Account 5001081976, Commerce Bank (Carlisle)
Savings Account 10"2. t:: (; ~ ft S"
Bank Misr Account (approx. $8,000)
Dodge Caravan 1994
Land in al-Beheira, Egypt
Apartment in Alexandria, Egypt
The parties agree that the following non-marital (separate) property
shall be the sole and separate property of Sherif a D. Zuhur, the
Plaintiff, and Ahmad B. Zalat, the Defendant transfers and quitclaims
any interest that he may have in this non-marital (separate) property
to the Plaintiff:
Bank Accounts: Commerce Bank# 53670484
checking and savings
MIT Federal Credit Union accounts Personal under
Sherifa Zuhur and joint account with
Natasha Zuhur
341 Garland Drive, Carlisle P A 17013
Royalty income for publications
Partnership (shares offather) in Western Investment Real
Estate Trust. Approx. $1200 per year.
2004 VW Beetle
The parties agree that Ahmad B. Zalat, the Defendant, shall pay and
indemnify and hold Sherifa D. Zuhur, the Plaintiff, harmless from the
following non-marital (separate) debts:
None
The parties agree that Sherifa D. Zuhur, the Plaintiff, shall pay and
indemnify and hold Ahmad B. Zalat, the Defendant, hannless from
the following non-marital (separate) debts:
Mortgage on 341 Carlisle $121, 500 approx.
Washington Mutual secondary credit line on house $13,000
MIT Fed. Credit Union used car loan $11,000
American Express $2100
MIT Visa $1400
United Visa $2300
otehr credit cards approx. $500
The parties both hereby represent and warrant that as ofthe date of
this agreement, they do not possess any property or interests in
property other than the items listed in this agreement; and that the
items set forth and listed in the agreement constitute full and
complete disclosure.
In addition to the items listed in this agreement, if any undisclosed
property or interests in property is discovered subsequently, and a
court of competent jurisdiction determines it to be marital or
community property of the parties, such discovery and determination
shall not invalidate this agreement but, the property or the interest in
it shall at the election of the discovering party (i) be divided equally
or equitably in kind or (ii) be accounted for by the party in possession
who may pay to the discovering party a sum of money to offset an
equal or equitable portion.
The parties both hereby represent and warrant that except for the
debts and obligations set forth and listed above, each has not incurred
any other outstanding debt or obligation on which the other may
become liable, nor has either party incurred any obligation that could
henceforth be enforced against any asset held or received pursuant to
this agreement.
In the event that any outstanding debt or obligation of any kind has
been incurred by either party, other than those listed above (and is
hereafter asserted against the other), the party actually incurring the
debt or obligation shall assume and be solely responsible for paying it
and shall hold the other party hannless from all claims with respect to
the debts, obligations, and expenses with respect to those debts.
In the event that the other party becomes a debtor in any bankruptcy
or financial reorganization proceeding of any kind while this
agreement is in effect, that debtor party waives any and all rights to
any property held by the other party which is in fulfillment of this
agreement. The debtor party will also convey to the other party that
the bankruptcy or financial reorganization proceeding is going to take
place.
The parties acknowledge and agree that the credit history established
by them during their marriage shall be deemed to have the credit
history of both parties, not withstanding ordinary practices of
creditors and credit reporting agencies that may have reported such
credit history in the name of one party. Both parties agree to
cooperate and execute any documents as may be required to enable
each other to provide to prospective creditors the full credit history of
the parties that was established during the marriage.
The parties each represent to the other that from the date ofthis
agreement each party shall not charge or incur or cause to be incurred
any liability or obligations based on the credit or name of the other.
Each of the parties shall do whatever is necessary to close
immediately all joint accounts.
The parties each forever waive any right to inherit from the other and
the right to receive any property on the death ofthe other, except as a
beneficiary of any life insurance policy, by reason of a will, codicil,
or republication of will by the other party executed subsequent to the
date ofthis agreernent.
The parties each waives all right to act as administrator of the other
party's estate and all right to request or petition for the appointment
of any person to serve as such representative or to act as the executor
of the other's will, unless expressly named in a will, codicil, or
republication of will by the other party executed subsequent to the
date ofthis agreement.
III. Marital Home:
None as defined.
IV. Retirement Accounts/Pensions/401ks/Profit Sharin!!: Plans:
The parties each waive all claims, present and future to pension
benefits, retirement funds, 401Ks, profit sharing plans and accounts
of the like.
V. Spousal Maintenance:
After careful consideration of the circumstances and all the other
terms of this agreement, the parties agree to waive any rights or
claims that he or she may have now or in the future to receive any
rehabilitative or permanent spousal maintenance from the other party.
The parties both agree each will be responsible for his and her own
health and medical insurance coverage.
VI. Income Tax Returns:
The parties agree that they will file joint federal, state and local tax
returns for the calendar year in which this agreement is made into
effect.
The parties both agree that they will cooperate in the filing of any
necessary tax returns and if any tax refunds are due on jointly filed
returns they shall be divided equally.
For each calendar year after the year this agreement is made into
effect, each party shall file separate federal, state and local income
tax returns, in which each shall include and report all of his or her
separate income and shall pay all income taxes due.
The parties each agree to notify the other promptly in the event the
IRS or any state or local taxing authority provides notice of an audit,
deficiency, refund, or the adjustment regarding a tax return that was
jointly filed or that should have been jointly filed. The party receiving
such notice from a taxing authority shall provide a copy of the notice
to the other party within 20 days of receiving it.
The parties further agree to cooperate fully with the other in any
claims for refunds or in defending against any deficiencies that may
be determined with respect to joint income tax returns filed (or to be
filed). This includes, without limitation, the making, executing, and
filing of amended income tax returns; applications for refunds,
protests, and other instruments; and documents as may be required.
The costs and expenses for such will be divided equally between the
parties.
VII. Professional Fees and Costs:
The parties have not acquired any professional service fees which
they desire to be recognized, mentioned, or distributed by this
agreement.
VIII. Advice of Counsel:
The parties each acknowledge that they have the legal right to
representation by separate attorneys. The parties each fully
understand his and her rights and the contents of this agreement.
The parties each consider the terms of this agreement to be fair and
reasonable and each party accepts sole responsibility for any
decisions, and potential repercussions of those decisions, which are
presented as part of this agreement.
IX. Mutual Releases:
Each party hereby releases the other from any claim of action that
either may have against the other for any reason occurring prior to
this agreement, whether that claim is founded in contract, tort, or any
other basis.
X. Governinl!. Law:
The parties agree that this document is intended to be a full and an
entire settlement and agreement between them regarding the marital
rights and obligations and that this agreement, and all contents within
and attached, shall be interpreted and governed by the laws of the
State of Pennsylvania.
XI. Entire Al!.reement:
This agreement constitutes the entire and full agreement between the
parties. If any clause is held unenforceable or found to be in any way
non-executable, or if a court alters or holds unenforceable any clause
in this agreement, this shall in no way affect or alter the other clauses
in the agreement, which shall remain in full force.
. .
No amendment or modification to this agreement or any judgment,
decree or order based on it shaH be valid unless signed and agreed to
by both parties or ordered by the court after a duly noticed hearing.
XII. Further Assurances:
The parties shaH execute and deliver promptly on request any
additional papers, documents, and other assurances reasonably
necessary in connection with the performance of the obligations set
forth in this agreement. In the event that either party fails or refuses
to comply with the provisions of this agreement, the failing party
shall reimburse the other party for all loses and expenses including,
but not limited to, attorney's fees and all costs incurred as a result of
such failure.
XIII. Captions and Interpretations:
Paragraph captions have been used throughout this agreement for
convenience and reference only and are not intended to be used in the
construction or interpretation of this agreement or any of its
provisions. No provision ofthis agreement is to be interpreted for or
against any party by virtue of the fact that the provision was drafted
by that party or that party's counsel.
XIV. Submission to Court:
This agreement has been drafted and executed with the intention that
it be submitted by either party to any court before which a Complaint
for Divorce may be pending or initially filed for approval by the court
and for incorporation into a Decree of Divorce.
XV. Verification/Disclosure:
The parties both have reviewed this agreement cooperatively and
each party has fully and honestly disclosed to the other the extent of
his or her assets, income, and financial situation, and therefore enter
into this agreement reliance thereupon.
Attached to this agreement is a completed Domestic Relations
Incorne and Expense Statement for each party to further present to
each other and the court his and her current income, expenses.
property and debts.
XVI. Successions:
The parties each acknowledge that this agreement, and each provision
of it, is expressly made binding upon the heirs, assigns, executors,
administrators, representatives and successors in the interest of each
party.
Signed and dated on ~,df,
~ g~l C'~ 1.~" ~tuJ-Zili.t
Prmt Name (De~
k.J f).
Signature (Defendant)
~\~ "L\'It
Print Name (Plaintiff)
1?~~
Ignature (PI ff)
Su=ta\f\~e '0l Be\~€Vl
~:t~e:~~Na~e1Vl ~
~ure
S \-\eR.. \ Su ((o€-l2-T-I-\e.cki'l1AI-'
Witness #2 Name
c-;-.\).;~:- -.",-~~----~~
Witness #2 Sign~-
State of Pe.t\1\& *" II j"I
County of ~wlUr:! ''''U
SWORN TO AND SUBSCRIBED BEFORE ME by the said
On J, ~ 1'-/ ,20~, before me, the undersigned, a
Notary Pu hc m and for saId State, personally appeared Ahmad B. Zalat, the
Defendant, known to me (or proved on the basis of satisfactory evidence) to
be the person whose name is subscribed to within the instrument and
acknowledged that he executed the same.
Witness my hand and official seal.
~,(~
Not y Pub IC
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
RODNEY E. HIGHLANDS, Notary Public
Bora 01 Carlisle, Cumberland County
My Commission Expires March 1, 2008
~
.
Notary Seal
My commission expires:
M'N,.(., L~q
State of J~
County ~[.~i.,,4.~
SWORN TO AND SUBSCRIBED BEFORE ME by the said
On 1/ l'f , 20 ~, before me, the undersigned, a
Notary Public in and for said State, personally appeared Sherifa D. Zuhur,
the Plaintiff, known to me (or proved on the basis of satisfactory evidence) to
be the person whose name is subscribed to within the instrurnent and
acknowledged that she executed the same.
Witness my hand and official seal.
Not~U~iC ~
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
RODNEY E. HIGHLANDS. Notary Public
Boro of Carlisle, Cumberland County
My Commission Expires Marcl11. 2008
Notary Seal
My commission expires: M.....L ~1itJ'6
J
....
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Sherifa D. Zuhur
Case Numher: 0 b - ~"s. ~
Plaintiff
)
)
)
)
)
)
)
)
v.
Judge:
Ahmad B. Zalat
Defendant
AFFIDA VIT OF CONSENT (ft'\Il1tdf' )
THE STATE OF: Pennsylvania
COUNTY OF; Dauphin and Cumberland
1. A Complaint for Divorce under Section 3301 (c) of the Divorce Code was filed on
{,o,w./V(
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing the Complaint for Divorce.
3. I consent to the entry of the final Decree of Divorce after service of intention to request entry of the
Decree of 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 the entry of a [mal Decree of Divorce without nollce.
2. [understand that I may lose rights concerning alimony, division of property, distribution of debts,
lawyer's fees, or expenses ifI do not claim them before a Decree of Divorce is granted by the Court.
3. [understand that I will not be divorced until a Decree of Divorce is entered by the Court and that a
copy of the Decree of Divorce 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
here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to
authorities.
t}30 la6
I I ,
S~\<:(i~ Zv~Vr
Print N lUIle (
Datr'
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Signature(j'. . '\ v \
,
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.------
. .
.
Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Plaintiff
)
)
)
)
)
)
)
)
Case Number: C) b - ~'\ S ~
Sherifa D. Zubur
v.
Judge:
Ahmad B. Zalat
Defendant
AFFIDA VIT OF CONSENT (Defendant)
THE STATE OF: Pennsylvania
COUNTY OF: Dauphin and Cumberland
1. A Complaint for Divorce under Section 3301 (c) of the Divorce Code was filed on
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing the Complaint for Divorce.
3. I consent to the entry of the final Decree of Divorce after service of intention to request entry of the
Decree of Divorce.
WAIVER OF NOTICE OF INTENTION TO
REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301 (c) OF THE DIVORCE CODE.
I. 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, distribution of debts,
lawyer's fees, or expenses if! do not claim them before a Decree of Divorce is granted by the Court.
3. I understand that I will not be divorced until a Decree of Divorce is entered by the Court and that a
copy of the Decree of Divorce will be sent to me inunediately 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
here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to
authorities.
Dai"\ K1301a~
n~~ . Z,\"\t
Print Name (Defendant)
~Le) ~~kt
Signature (Defendant)
-..----
co'"
C.,'\ ::.-;:J
(,"I
c~
.-------
IN THE COURT OF COMMON PLEAS
ZUklJR.
VS. zA- W\T
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
NO. (] 6- :; 115 ~
CIVIL TERM
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 93301 (c)
3301 (d)(1) of the Divorce Code.
(Strike out inapplicable section).
2.
Date and manner of service of the complaint:
:J\Jfle:. 1 8" ~o 0 6
3. Complete either paragraph (a) or (b).
(a) Date of execution of the affidavit of consent required by S3301 (c) of the Divorce Code:
by plaintiff '? j"3 o! 0' ; by defendant '1/30/1('
(b) (1) Date of execution of the affidavit required by S3301 (d)
of the Divorce Code: t.) / I b / () fj
lb I I
(2) Date of filing and service of the plaintiff's affidavit upon the respondent:
(,/\6/06
. .
4. Reiated claims pending:
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 of plaintiff's Waiver of Notice in S3301 (c) Divorce was filed with
the Prothonotary: Vi I II/Or;
Date defendant's Waiver of Notice in 93301 (c) Divorce was filed with
the Prothonotary: 00,. hI Jo G
(/)
~\
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~~ ~~~~~~~~~~~~~~~~~ ~ ~~~~~
~ ~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE OF
PENNA.
S"tL\t.;9. Z,,\,.,.
No. ~,~'1 St.t
VERSUS
~~~ t\ 7,,1~
DECREE IN
AND NOW,
DIVORCE
S~ \7
~ \.V\ t~ ?\)\..~"
f\~~ 7:~.\,,!
, DEFENDANT,
~ IT IS ORDERED AND
DECREED THAT
, PLAI NTI FF,
AND
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 E'tVRED;
~
PROTHONOTARY
J.
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