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Home My WebLink About02-1986Da'ad Beshara, Plaintiff · IN THE COURT OF COMiMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA v. · NO. 02- I ~'~ CIVIL TERM John Beshara, Defendant · CIVIL ACTION - LAW · IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGH'rR You have been sued in Court. If you wish to defend against' in the following pages, you must take prompt action. You are warnE do so, the case will proceed without you and a decree in divorce or entered against you for any other claim or relief requested in these Plaintiff. You may lose money or property or other rights important custody or visitation of your children· When the ground for the divorce is indignities or irretrievable marriage, you may request marriage counseling. A list of marriage I available in the Office of the Prothonotary at the First Floor, Cumber Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION PROPERTY, LAVVYER'S FEES, OR EXPENSES BEFORE A DIVOI YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT * NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR T OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN G Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 he claims set forth .d that if you fail to ~nnulment may be )apers by the o you, including 3reakdown of the ;ounselors is land County ~F MARITAL {CE IS GRANTED, )NCE. IF YOU DO ELEPHONE THE ET LEGAL HELP. Da'ad Beshara, Plaintiff · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA v. ' NO. 02- J C~ ~O CIVIL TERM John Beshara, Defendant · CIVIL ACTION - LAW 'IN DIVORCE COMPLAINT IN DIVORCE Lancaster Blvd., Mechanicsburg, Cumberland County, Pennsylvani~ 2. Defendant is John Beshara, an adult individual, curr~ Lopax Road, Harrisburg, Dauphin County, Pennsylvania· 17112 3. Plaintiff and Defendant are bonafide residents of th~ Pennsylvania and have been so for at least six months immediately of this complaint. 4. Plaintiff and Defendant were marded on October 29, County, Pennsylvania. 5. There have been no prior actions for divorce or ann Plaintiff is Da'ad Beshara, an adult individual, currently residing at 1075-1z~ ~, 17055. ;ntly residing at 114 6. The Defendant is not a member of the Armed Forces of America, or its Allies. 7. The Plaintiff has been advised of the availability of right to request that the Court require the parties to participate in c( this, the Plaintiff does not desire that the Court require the parti counseling. 8. Defendant is a citizen of the United States of America. of the United States of America, or its Allies. 9· The parties have lived separate and apart since No continue to live separate and apart as of the date of this Complaint. Commonwealth of 3revious to the filing 1992 in Cumberland Jlment between the )f the United States counseling and th( ~unseling. Knowin¢ 9s to participate in Plaintiff is a citizen /ember, 2001, and WHEREFORE, divorce. 10. There has been one (1) minor child born of this marriage: Justine E. Beshara, born March 10, 1994. 11. Plaintiff desires a divorce based upon the belief that iDefendant will, after ninety days from the date of the filing of this Complaint, consent to !his divorce. Plaintiff requests your Honorable Court tc~ enter a decree in COUNT II CUSTODY 12. Paragraphs I through 11 are incorporated herein bi reference as if set forth in their full text. 13. Plaintiff seeks custody of her child, Justine E. Besh~ra, born March 10 1994, currently residing at 1075-14 Lancaster Blvd., Mechanicsl~urg,/ Pennsylvania, 17055. 14. The child is presently in the custody of the Plaintiff. 15. Since the child's birth, the child has resided at the following addresses: Name Address Dates (mother and father) (mother & father) (mother) 714 Harrisburg Pike, Hillsburg, PA 1075-14 Lancaster Blvd., Mechanicsburg, PA 1075-14 Lancaster Blvd, Mechanicsburg, PA 16. The relationship to the Plaintiff to the child if that of nat~ 17. The relationship of the Defendant to the child is that of 18. Plaintiff has not participated as a party or in another ca litigation concerning the custody of the child in this or any other cour March 10, 1999 to 2000 March 9, 2000 to Nov. 2001 ~ovember 2001 to current Jral mother. ~atural father. )acity in any other 19. The best interest and permanent welfare of the child w~ill be served by granting the relief requested because the Plaintiff is the primary caregiver with respect to the child. WHEREFORE, Plaintiff requests your Honorable Court Ito enter an Order granting shared legal custody with both parents and further providing primary physical custody of the minor child with the Mother. i ALSO WHEREFORE, the Plaintiff requests your Honorable Court to enter a Decree in Divorce. Respectfully Submitted TURO LAW OFFICES ~ar~n R. Waltz, E..s~re 28 South Pitt Str"e~et Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Divorce Cc~mplaint are true and correct. I understand that false statements herein made are subje~:t to the penalties of Pa.C.S. §4904 relating to unsworn falsification to authorities. Da~t~/ Da'ad Beshara / CERTIFICATE OF SERVlCF I hereby certify that I served a true and correct copy of the John Beshara, by depositing same, in the United States Mail, first class, postage pre-paid on the day of ~?/',-, / , 2002, from Carlisle, Pennsylvania, address~ed as follows: ffat John Beshara 114 Lopax Road, Harrisburg, Pennsylvania 17112 And Certified, Return Receipt Requested TURO LAW OFFICES /Ga'Fen R. Waltz, Esqu~.~e 28 South Pitt Street'~ Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff TURO LAW OFFICES Da'ad Beshara, Plaintiff John Beshara, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-1986 : : CIVIL ACTION - LAW :IN DIVORCE CIVIL TERM AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of Divorce Complaint filed in the above captioned case upon John Beshara, by certified mail, return receipt requested on April 23, 2002 addressed to: John Beshara 114 Lopax Rod Harrisburg, PA 17112 and did thereafter receive same as evidenced by the attached Post Office receipt card dated April 30, 2002. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE INFORMATION AND BELIEF, 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. Date TURO LAW OFFICES fGalen R. Waltz,~::l~ire 28 South Pitt Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff /.90 ~ Cernc~ ~lem~ 1 ~ndJor 2 for addltior~l sen, ices. C, omC~e'~ems 3, 4a, and 4b. ~/Receh, ed I~y: (P~nt Name) de Addressed to: I ....... --' -~ 6. Signature (Addressee orAgent) I aleo wl~h ~o ~3eh~e the fo#rov- ing services (for an extra fee): 1. [] Addre~aee's Address 2. J~ Restricted Delivery 7001 2510 0009 4b. Service Type [] Registered J~Certified [] Express Mail [] Insured ~ Return Receipt for Merchandise []COD Date of Delive~ / J~ 8. Aedressee's Address (On/y if requested and feeispaid) 2826 9361 Da'ad Beshara, Plaintiff John Beshara, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-1986 CIVIL TERM : CIVIL ACTION - LAW :IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divome 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. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELAT!NG TO UNSVVORN FALSIFICATION TO AUTHORITIES. Da'ad Beshara Da'ad Beshara, Plaintiff John Beshara, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-1986 CIVIL TERM : : CIVIL ACTION - LAW :IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on April 23, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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/ Da'ad Beshara, Plaintiff John Beshara, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-1986 CIVIL TERM : : CIVIL ACTION - LAW :IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) 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 a~limony, 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. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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'ad Beshara ' / / - Da'ad Beshara, Plaintiff John Beshara, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-1986 CIVIL TERM : : CIVIL ACTION - LAW :IN DIVORCE WAIVER OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(C) 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, lawyers 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. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO TIdE PENALTIES OF 18 i=a.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Date ~_~hn Beshara Da'ad Beshara, Plaintiff John Beshara, Defendant : IN THE COURT Of COMMON PLEAS Of : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-1986 CIVIL TERM : : CIVIL ACTION - LAW :IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on April 23, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of the final Decree in Divorce after service of Notice of Intention to request entry of the decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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 /~hh BesharA Da'ad Beshara, Plaintiff John Beshara, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-1986 CIVIL TERM : : CIVIL ACTION - LAW :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 §3301(c) §3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Certified, Return Receipt delivered April 30, 2002. 3. Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code. s,,,_¢~,,j, ~. By Plaintiff: Au~juet 5, 2002 By Defendant: August 15, 2002 4. Related claims pending: None. 5. Date the Waiver of Notice in §3301(c) divorce was filed with the Prothonotary: By Plaintiff: September 5, 2002 By Defendant: September 5, 2002 "GCat~ R. Waltz, E~qL~ire~"' Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF .,~~. PENNA. Da'ad Beshara Plaintiff VERSUS John Beshara Defendant N O. 02 - 1986 AND NOW, DECREED THAT AND DECREE IN DIVORCE , 2002, IT IS ORDERED AND , PLAINTIFF, John Beshara , 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 ATTEST: PROTHONOTARY