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Home My WebLink About06-4913 4. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - DIVORCE NO. 01., -.qC:;/~ Cio(.-Ll~ SEHERZADA SAFIC Plaintiff v. MIRHAD KURTOVIC Defendant 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, then 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 right important to you, including custody or visitation of your children. When the grounds for 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 of the Lancaster County Courthouse, 50 North Duke Street, Lancaster, 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. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE SEHERZADA SAFIC Plaintiff NO. D'- - I{913 eiolL'Y~ vs. MIRHAD KURTOVlC Defendant DIVORCE COMPLAINT UNDER SECTION 3301@ OR 3301 (D) OF THE DIVORCE CODE 1. Plaintiff is Seherzada Safic, an adult individual who currently resides at 488 Petersburg Road, Carlisle, Pennsylvania 17013, Cumberland County, Commonwealth of Pennsylvania. 2. Defendant is Mirhad Kurtovic, an adult individual who currently resides at 17 Cedar Hill Estates, Cedar Hill, MO 63016. Defendant is not in the military. 3. Plaintiff has been bona a fide resident of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on September 28, 2005 in Carlisle, Pennsylvania. 5. There have been no other actions for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised that counseling is available and that the Plaintiff may have a right to request the court to require the parties to participate in counseling. \ ( . 8. Plaintiff requests the Court to enter a decree of divorce. I verify that the statements made in this Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. (~~~ Seherzada Safic Date: (Ji! ~9 /t91f' ~ p--- Osvaldo Espinosa, Esquire Attorney for Plaintiff ID #78158 129 E. Orange Street, Second Floor Lancaster, PA 17602 (717) 293-1400 ~ - ...0 - ..0 ..Q ~ .' 't. ("::i ~ J:::: \"'" ~ ;0.. - .t) o .. S ~~ f- ! g ~, C1-.. ~fT~ '.-7"'r 7~-~, ~'" "\':.-, '2 ,. ';>C.,; Z.-. --1".,.2 Y-C Z. :<1 ~ ~ ~ ~ ~ {1'~ c:> -q \'3 ~ ~Q. -:J} -0 ~O ::J' \:5 rn '-^' .-, ., ?f! '-^' :;.:: .r:- ~ ( " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - DIVORCE SEHERZADA SAFIC Plaintiff NO. 06-4913 CIVIL TERM v. MIRHAD KURTOVIC Defendant DIVORCE AFFIDAVIT OF SERVICE OSV ALDO ESPINOSA, ESQUIRE, being duly affirmed according to law deposes and says that pursuant to Pennsylvania Rule of Civil Procedure 403 and 1930.4, he caused to be served by Certified mail, Restricted Delivery, Return Receipt Requested, a certified copy of the Complaint in Divorce endorsed with Notice to Defend to Mirhad Kurtovic, at his address of 17 Cedar Hill Estates, Cedar Hill, MO 63016. Said documents, identified by Postal Receipt No. 7005 1820 0002 2733 2622, were delivered to the addressee on September 5, 2006. A copy of the cover letter along with the original of the Postal Receipt for Certified Mail and the Return Receipt are attached hereto as proof of service. 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: 9-22-06 MDtlJ ~--- Osvaldo Espinosa, Esquire Attorney for Plaintiff 129 E. Orange Street, Second Floor Lancaster, PA 17602 (717) 293-1400 Attorney J.D. 78158 .. SENDER. COMPLETE THIS SECTION . Complete items 1, 2, and 3. Also complete item 4 If Restricted Delivery is desired. . Print yGlJr 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: A. Signature x o Agent o Addressee C. Date of Delivery CJ - -Vir D. Is delivery address different from item 1? 0 Yes If YES. enter delivery address below: 0 No ..... ""ad Kurtovic 11 Cedar Hill States Cedar Hill, MO 63016 3. ~ce Type &CertIfled Mall 0 Express Mall o Registered 0 Return Receipt for Merchandise o Insured Mall 0 C.O.D. 4. Restricted Delivery? (Extra Fee) Yes 2. Article Numbel (nansfer from , PS Form 3811. February 2004 . 7005 1820 0002 2733 2622 DomestIc Relum Receipt 102595-02-M-154O i '.-- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE SEHERZADA SAFIC Plaintiff NO. (){.. -l.flt!:J e.; u,L ~ ~ v. MIRHAD KURTOVIC Defendant 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, then 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 right important to you, including custody or visitation of your children. When the grounds for 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 of the Lancaster County Courthouse, 50 North Duke Street, Lancaster, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY, LAWYERS' FEES OR EXPENSES BEFORE A DIV~CE?:~OR~1 ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIMf'J\NY~OF~~ ,-- THEM :~)i' ~:j i :lt~ . ;~.~~.~ t. f'~) l,-:~ ~,; W :_I~l YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.;: IF Y-6>U ...,ij .!::: C. - -;,;.... : ~..~ C) DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, G~~~O 3>R {~r.. TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHE~ XQU ~:D CAN GET LEGAL HELP. - v', .< Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 (717) 249-3166 g -.... 0')~;' s,t)..,. r'- ~ -r~"" ( ~.. t:>- ~C z 2 ~ ~ ~ -0 ~ . ) 0'1, .-1 :~~) " \._: .t" .:',., -0 ~ c..:> . . o U1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE SEHERZADA SAFIC Plaintiff NO. 06-4913 CIVIL TERM VS. MIRHAD KURTOVIC, Defendant DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 23, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and of service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of the 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: l.<j?O fC Sehe~~ ~'/ ("') ~; ~-,.,.." r-l c:> = cr- Cl in cJ N o -n -I :1:-n P'r:: -or.:; -rJ t:;:1 C~C:-~ ~ ~:.. .. , ?~~ '-.j ..-\ ~15 :.<. - - N W IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE SEHERZADA SAFIC PlaintitT NO. 06-4913 CIVIL TERM VS. MIRHAD KURTOVIC, Defendant DIVORCE WAIVER OF NOTICE 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, 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 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: ,;2f.//~t?6 ~ /#/ ( ~ C Seherzada Safic r--.:l C,:. ...=:J 0-. o M (; N o -n :;:l fl1 :D S; c; ~: -4... l'0 c...:' .' .. SEHERZADA SAFIC Plaintiff VS. MIRHAD KURTOVIC, Defendant DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on August 23, 2006. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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. Date: , v118/0 (: J%iMI ~tIov~ Mirhad Kurtovic (") C' ~. ....... ~~"::: ,..,.;) = = 0" o r1 n N o -n ~-n rnr=:, ""'iJr.!J -h,-;-' />'.1,-'-) ':::2~~ ;ts ~;~ --; ~ .:g -... ~ ............ r'-' .t:"" ~ "'1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - DIVORCE MIRHAD KURTOVIC, Defendant DIVORCE SEHERZADA SAFIC Plaintiff NO. 06-4913 CIVIL vs. WAIVER OF NOTICE 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. 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 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: I 2J( cr ~ f fj,'rIvJ tfwiot/(~ Mirhad Kurtovic ,....., = c:::;:) 0' o n (""') 1'-' o 11 .-' :C-r. nl.-'~ r- -VfT1 ~J:J C" ~~1 () ~~ f.1.~ .:::, ~,;; ~n .-< :...~ :!K: f'.) ..c'.' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE SEHERZADA SAFIC Plaintiff NO.06-4913 CIVIL TERM VS. MIRHAD KURTOVIC, Defendant DIVORCE AFFIDAVIT THAT THE DEFENDANT IS NOT IN THE MILITARY SERVICE PURSUANT TO THE SOLDIERS AND SAILORS RELIEF ACT OF 1918. RE-ENACTED IN 1940 Seherzada Safic, being duly sworn, according to law deposes and says that the following facts are true and correct to the best of her knowledge and belief: Mirhad Kurtovic is not in the military or Naval Service, based on the following facts, as of the date of this Affidavit: Age of the Defendant: 33 y.o. Present place of employment: unknown Present Place of Residence: 17 Cedar Hills Estate, Cedar Hill, MO 63016 ~# ~ ,r Seherzada Safic Sworn to and subscribed before me this 20th day of December, 2~e Notary Public -- Notarial Seal .osvaldo Espinosa, Notary Public I' City of L~ncaster, Lancaster County My Commission Expires Nov. 24, 2007 , M~~,h~r P ,. _J ,... -.., ennsy vania Association of N:;;,?~;',::3 ~ c..? 0" q r. (""? N - ~J1 ....,.'."" ...c- - o -1'1 :=? fi;~ -T"~ OJ, ~~::] \"i"# ,-~), (.:) ..~:~ :~~\ ~Ji~~ ~?, :::.:\ .~ -- .. N ~:.,~. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL ACTION - DIVORCE SEHERZADA SAFIC Plaintiff NO. 06-4913 CIVIL TERM VS. MIRHAD KURTOVIC, Defendant 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. Grounds for divorce: irretrievable breakdown under ~ 3301 (c) of the Divorce Code. 2. Date and manner of service of complaint: Defendant accepted service of certified mail, restricted delivery on September 5, 2006. 3. Date of execution of the Affidavit of Consent required by ~ 3301 of the Divorce Code: By Plaintiff: 12/20/06 By Defendant: 12/18/06 <<Jv~ ~----- Osvaldo Espinosa, Esquire Attorney For Plaintiff ,/ )......... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-DIVORCE SEHERZADA SAFIC Plaintiff NO. 06-4913 CIVIL TERM VS. MIRHAD KURTOVIC, Defendant DIVORCE CERTIFICATE OF SERVICE I, Osvaldo Espinosa Esquire, certify that I have caused to be served in the manner and date specified below a true and correct copy of the foregoing Praecipe to Transmit Record, upon the following individual: Mirhad Kurtovic 17 Cedar Hill Estates Cedar Hill, MO 63016 U.S. mail, first class, postage prepaid. Date: 12-20-06 ~ r,-- Osvaldo Espinosa, Esquire Attorney for Plaintiff (') c -;ow -::., '"'()~ mr" z~.:> '/. U?}'. ..c:'..,.. ~.' !:<'. }:.8 Pc:: "7' :,2 -'-, l"-..) c::;:> c::;:> ~ <- > z: I '"' o -n ~~ :at( '-~Q -~"'"'T, :t: .1 Qo (jm -t ~ -0 ::E: - .. "" o ~~ ~~ ~~~~~~~ ~ ~~~~~~ ~ ~ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF SEHERZADA SAFIC PENNA. No. 06-4913 CIVIL TERM Plainfiff VERSUS MIRHAD KURTOVIC Defendant DECREE IN DIVORCE ~ AND NOW,This 1/ day of :12/'hJ 7.) 1-' 2~'7, IT IS ORDERED AND DECREED THAT SEHERZADA SAFIC AND MIRHAD KURTOVIC ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAI NTI FF, , DEFENDANT, 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; ATTE J. ,/~ ;2 ~7'?:W/ ?;?~)t) /, ,/ eDR4if/e:;J ~ ft:-:'?:Z' /!/,PV~) ):-77{) .... (V' f...j ./ ,-c' i...i /