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HomeMy WebLinkAbout06-3979 . FRIEDMAN & KING, P.C. John F. King, Esquire ID #61919 600 N. Second Street Penthouse Suite P. O. Box 984 Harrisburg, PA 17108 Tel.: (717) 236-8000/Fax: (717) 236-8080 Attorney for Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 01. - .391'( (3t>i<-r-€lL'YY"\ CIVIL ACTION - LAW IN DIVORCE MICHELLE E. EKWE, Plaintiff PIERRE CHRISTIAN EKWE, Defendant 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 Courthouse, I Courthouse Square, Carlisle PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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, PA 17013 1-800-990-9108 717-249-3166 Respectfully submitted, FRIEDMAN & KING, P.C. J MICHELLE E. EKWE, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. ()(c- 3979 e;v~L /~ CIVIL ACTION - LAW IN DIVORCE PIERRE CHRISTIAN EKWE, Defendant COMPLAINT UNDER SECTION 330Hc) AND SECTION 330Hd) OF THE DIVORCE CODE 1. Plaintiff is Michelle E. Ekwe, who currently resides at 635 Heritage Court, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant is Pierre Christian Ekwe, who currently resides at 23 Fourth St., 2nd Floor, Ridgefield Park, New Jersey 07660. 3. The Plaintiff has been a bona fide resident in the Conunonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 12, 2001, in Ridgefield Park, New Jersey. 5. Plaintiff avers that there are no children of the parties under the age of eighteen (18). 6. There have been no prior actions of divorce or for annulment between the parties. 7. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. The marriage is irretrievably broken. 9. Neither Plaintiff nor Defendant is in the military service of the United States. 10. The parties separated on December 21,2005. . , ~ WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, FRIEDMAN & KING, P.C. JfJ~1 a& ) 17108 RSFlbp . ,I VERIFICATION I, Michelle E. Ekwe, hereby acknowledge that I am the Plaintiff in the foregoing action; that I have read the foregoing Complaint in Divorce; and the facts stated therein are true and correct to the best of my knowledge, information and belief. I understand that any false statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. ~!S~~ ~ ~turc Dated: M 10) dfX) (p o ~ ~ F- ::c r \\ 9 - ~ lY ~ ~ v ~ ~ ~ - J . ;~~ '~~."'. ::;-~ -c. ,'" :\\ _"OJ -- 1"5 .. r:: ( """ _.,1' v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-3979 Civil Term MICHELLE E. EKWE, Plaintiff PIERRE CHRISTIAN EKWE, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDA VIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : SS: COUNTY OF DA UPHIN Personally appeared before me, a Notary Public, in and for said Commonwealth and County, John F. King, Esquire, Attorney for the Plaintiff, who, being duly sworn according to law, deposes and says that a Certified copy of the Complaint in Divorce in the above-captioned matter was served upon Defendant, Pierre Christian Ekwe, by Certified Mail, Restricted Delivery, on July 15, 2006, as evidenced by/the att~ched Certified Mail card. '"'-' ~,<7' ,.,r........ ' ..~,- -"'.... " Sworn and subscribed to before me this ~(g~ day of Oc;tc _ , 2006. 73~'C~~1 Notary Public COMMON~\T,bl D" OF.L~::;:,:.C:i.L~J,i\~l!\ N<H'ARIAl SEt,1. ~ BARBARA E. PALMER, Notary Public City of Harrisbmg, Dauphh County My Commiss,:)[l Expire::: t.}'~i\, 2009 "" ".,,>,"'" ...~...,.,."."".. ~,."",~....war.._,""""""<,,,~,",,.,...,,~..,.._,,; .,.p,'",.".",,,.,,',,,....., . 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. 1. Article Addressed to: D. Is delivery address different from item 1? If YES, enter delivery address below: ~tr. Pierre 01ristian Ekwe 23 Fourth St., 2nd Floor Ridgefield Park, NJ 07660 3. Service Type YlAI Certified Mail 0 Express Mail o Registered Xl Return Receipt for Merchandise 2. Article Number (T/'ansfer from service label) PS Form 3811, February 2004 7004 0750 0002 8071 9572 Domestic Return Receipt 102595-02.M-1540 ~'~:~ g ?::. -otT.' niP: Z'':P -.;: S~~ ~~..< ~C ~C'; c:() ....-c:: ~ f"o'oo3 g <::t"' o n -l - co -0 :x r ~ :C me -om ~r-n ~J T qo :::;.l-., "",'~-t;.\ 00 Zrn o .::..t ":;:::>- ~ o ---- MICHELLE E. EKWE, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-3979 Civil Term PIERRE CHRISTIAN EKWE, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 12, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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 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. DATED:O~~IG./ ,f{,fM Jt r4 ~tr--- ichelle t. kw, laintiff 0 I"-..> 0 c= c: c::;) .." ~". t::r' s.- O ::t ""0 lJ: ! m(n n r*i:O Z..:!" -t -ofTI -.yo-".- . "'..::.. '- :0'1' ~,"~ 0:> On ~;::;..-, --\- ~'- ' ....,..,. >:(.o._'i -0 "'::; ::n 3: ~...o ~(') 0f11 )> :::. .:r;- ~ 1..... ~ 0 ?E .< MICHELLE E. EKWE, Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-3979 Civil Term PIERRE CHRISTIAN EKWE, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) AND 3301(D) 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. 4. 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:Oc~,,-ICo dt~t J ~ ,lJi ~ ~A~ Michelle E. Ekwe, laintiff--- (") ,...", 0 = c = " 0--. ~ 0 ~.~ -Om n r.p q:! --l -of;. ....--~. ..... . -;t> r- -:00 en} co be -<A: .~' ,> r:::c ~,., -:1>r- -0 ;5 -n :3t ~.~o z~' 6m ._(-, Pc .r:- s;! ~ 0 5J -< MICHELLE E. EKWE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-3979 Civil Term PIERRE CHRISTIAN EKWE, Defendant CIVIL ACTION - LA W IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 12, 2006 . 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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 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. DA TED: O.J:ct-l/\.. ((p / o-uk ~~ ~'. ~ Pierre Christian Ekwe, Defendant e r-...:J 0 ~ c:::> -n s:: c:r> ""OW <::) ~:n C? qJ..P -l _,"'....J..' -aMi zr" <.n. ",,,. 86 :::$ .': co f;2C-:; -0 :r.: .,., ~.~ d::!1 .... :x c ZO ~~ .r- om ~ 0 );! ~ ----- MICHELLE E. EKWE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY , PENNSYLVANIA v. NO. 06-3979 Civil Term PIERRE CHRISTIAN EKWE, Defendant CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 3301(C) AND 3301(D) 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. 4. 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. DateCtJt,.(J-L-... (~/ dub ~~~, Pierre Christian . kwe, Defendant g $:: -00) J'11fii Z''''''' zt: tQ~" ~"':- \"", :.:::: -- ~Q /,-.U '>c: ~ ~ o C'? --' CP -0 ::J: ;::- .. Q ~ :i! rn~ -orn ~I:? ~~ _~...... 4t rJ -- b~ .;;;-s ~ --------- MICHELLE E. EKWE, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 06-3979 Civil Term PIERRE CHRISTIAN EKWE, Defendant CIVIL ACTION - LA W IN DIVORCE 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 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On July 15, 2006 by Certified Mail, Restricted Delivery. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, October 16, 2006; by Defendant, October 16, 2006. 4. Related claims pending: There are no related claims pending. 5. Date Plaintiff's Waiver of Notice was filed with the Prothonotary: October 17,2006. Date Defendant's Waiver of Notice was filed with the Prothonotary: October 17, 2006. //--) C~/.. ./1{ . <1.) /~( I John . King, E~quire AJtorney for Plai~.._.. (') r--.) = ~ c = s: 0"' '"0 (.1:"; 0 ~ S2n-, n rn~ -:: ~'~ -f 6J J" ;B~ -<' ::'~ CO ~"l ~C ~Q ." .,- -f"1 ::K i'5:JJ --.( .' 20 .).-....e .r:- Om ...,.- -. ~ 0 ~ -< ~T. Of. Of. Of. Of. :f. Of. Of. Of. :+ Of. Of. :+ :+ T. T. :+ :+ :+ :f. Of. Of. :+ :+ Of. :+ :+ :+ :+ Of. Of. :+ Of. :+ :+ :+ Of. :+ :+ :+ :+ :+ :+ :+ :+ :+ T. :+ :+ :+ :+ :+ +. :+ +. :+ +. :+ :+ :+ :+ :+ :+ :+ Of. :+ +. :+ :+ :+ Of. :+ :+ Of. 0f.0f. Of. Of. Of. :+ :+:+ :+ :+ :+ Of. :f. Of.:+:+:+ Of. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. MIa-IELLE E. EKWE, Plaintiff No. On- 7\q7q ri ,ri 1 TenTI VERSUS PIERRE GIRl STIAN EKWE, fufendant DECREE IN DIVORCE AND NOW, () j: . ~~ . , IT IS ORDERED AND 2006 DECREED THAT Mi che lIe E. Ekwe , PLAI NTI FF, AND Pierre Christian Ekwe , 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; ~ ~ r , ATT PROTHONOTARY :+ :+ :+ :+ :+ :+ :+ :+ :+ :+ :+ :+ :+ :+ :+ J. :+:+ :+ :+ :+ :+ :+ :+:+:+ :+:+:+:+:+:+:+:+ :+:+:+:+:+ :+:+:+:+:+:+ :+:+:+:+:+:+:+:+:+:+:+:+:+:+:+:+:+:+:+:+:+ :+:+:+? -h 2 ~ ~ "lil1e.Q/ ~ r ~ /p"'!YvtI ~ -rrJ 9cl. ?e- <1/ .- .. ."~ .t . J.