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HomeMy WebLinkAbout06-6519INDIRA HRNJIC, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. / ELVIR HRNJIC, &04 Defendant IN DIVORCE NOTICE TO DEFEND 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 at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, FLOWER & LINDSAY ATTORNEYS-AT-LAW 26 West High Street Carlisle, PA SAIDIS, FLOWER & LINDSAY Carol J. Linz Wuire 46 3 Attorney Id2M7013 26 West eet Carlisle, (717) 243-6222 Counsel for Plaintiff INDIRA HRNJIC, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 0 60W ELVIR HRNJIC, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE SAMIS, FWNWR& LINDSAY nrroWEVS-nruw 26 West High Street Carlisle, PA 1. The Plaintiff is Indira Hrnjic, an adult individual, residing at 1693 Douglas Drive, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Elvir Hrnjic, an adult individual, residing at 446 First Street, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 3, 1999 in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that she has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance Respectfully submitted, SAIDIS, FCOWERI& LPWY SAIDIS, FLOWER & LINDSAY MUIMMY AT lAW 26 West High Street Carlisle, PA with §3301 of the Pennsylvania Divorce Code. Dated: Cl ya Carol J. Linde; ° Muire Attorney Id. 469 26 West Hi eet Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. Indira Hrnjic Date: 111.0 SAID11S, FLOWER & LINDSAY ATMINMAT-LAW 26 West High Street Carlisle, PA 0 1 W `V?A\ V 717 ?rrt 1? - INDIRA HRNJIC, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 06-6519 ELVIR HRNJIC, Defendant IN DIVORCE PRAECIPE TO REINSTATE DIVORCE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the attached Divorce Complaint originally filed in the above captioned case on November 8, 2006. Respectfully submitted, SAIDIS, FLOWER & LINDSAY Carol J. i n d s a iy, squ e Attorney Id. 44693 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS, FLOWER & LINDSAY ATTORNM-AT•IAW 26 West High Street Carlisle, PA INDIRA HRNJIC, Plaintiff V. ELVIR HRNJIC, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW, NO. IN DIVORCE SAIDIS, FLOWER & LUNDSAY ATMRNRS•AT•IAW 26 West High Street Carlisle, PA NOTICE TO DEFEND -` YOU HAVE BEEN SUED IN COURT. If you wish to defend against; the Claims s'df forth in the following pages, you must take prompt action. You are warned tiat if you fabto do so, the case may proceed without you and a decree of divorce or annafhent-maylbe 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 at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, FLOWER & LINDSAY Carol J. Lin s Esquire Attorney Id.;A46 3 26 West igh reet Carlisle, 7013 (717) 243-6222 Counsel for Plaintiff INDIRA HRNJIC, Plaintiff V. ELVIR HRNJIC, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Indira Hrnjic, an adult individual, residing at 1693 Douglas Drive, Carlisle, Cumberland County, Pennsylvania. 2. The Defendant is Elvir Hrnjic, an adult individual, residing at 446 First Street, Carlisle, Cumberland County, Pennsylvania. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 3, 1999 in Carlisle, SAIDIS, FLOWER & LINDSAY ArroenM•AT•LAW 26 West High Street Carlisle, PA Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that she has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code. Respectfully submitted, SAIDDIS, F ER L!N Y / JA`rn ill f i Carol J. Lindsay _ squire Attorney Id-.4469 26 West Hi eet Carlisle, PA 17013 (717) 243-6222 Dated: Counsel for Plaintiff SAIDIS, FLOWER & LINDSAY ATMMUS-AT•IAW 26 West High Street Carlisle, PA VERIFICATION I verify that the statements made in the foregoing document are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsifications to authorities. Indira Hrnjic Date: 1) 'T 0 (P SAMIS, FLOWER & LINDSAY ATIDRNM AT•IAW 26 West High Street Carlisle, PA INDIRA HRNJIC, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW NO. 06-6519 ELVIR HRNJIC, Defendant : IN DIVORCE PRAECIPE TO REINSTATE DIVORCE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the attached Divorce Complaint originally filed in the above captioned case on November 8, 2006. Respectfully submitted, SAIDIS, Carol J. Lindsay, Es Attorney Id. 4469 26 West High Str Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS, FI ONWR & LINDSAY anom4F&A3-1Aw 26 West High Street Carlisle, PA r.a C _ 1 INDIRA HRNJIC, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 06-6519 ELVIR HRNJIC, Defendant IN DIVORCE AFFIDAVIT I, Robert W. Lindsay, Constable, an adult individual not a party to the above-referenced action, being duly sworn according to law, hereby deposes and says that on 1 ` (2:? 2007, at _ Q AN/PM, I served a Divorce Complaint, by hand delivering the document to Elvir Hrnjic at a;qGZrrb- Pennsylvania. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unsworn falsification to Robert W. Lindsay, Constable P.O. Box 224 Shippensburg, PA 17257 SAIDIS, FLOWER & LESDS" 26 West High Street Carlisle, PA Dated: Sworn to and su cri ed before me this l5' day o LIQAC 09' NOTARIAL SEAL MERLENE L MARKM NOTARY PUBLIC CARLISLE, CUMBERLA?lO COUNTII; FA MY COMAMSSION EXPIRES JUNE 2010 C= Q r? s. 3! CD ? -- 4 oo INDIRA HRNJIC, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 06-6519 ELVIR HRNJIC, Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on November 8, 2006. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. 1 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unswom falsification to authorities. Date: 62-2Q, a;?? j Indira Hrnjic PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER4 3301 (c) OF THE DIVORCE CODE 1. I consent to the entry of a final Decree of Divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, !a--A,9r's fees or expenses if I do not cl3!m them. before a divorce -is granted. 3. 1 understand that I will not be divorced until a Divorce Decree is entered by the SAWIS, FLOWER & LENDS" 26 West High Street Carlisle, PA 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unswom falsification to authorities. Date: ro L7 p ?-- t C Indira Hrnjic 3UN 2 9 ZO a :? r n INDIRA HRNJIC, Plaintiff V. ELVIR HRNJIC, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-6519 IN DIVORCE AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on September 28, 2006 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 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. I verify that the statements made in this affidavit are true and correct. I understand SAIDIS, FLOWER & LINDSAY nrrow?YS.nruw 26 West High Street Carlisle, PA that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Dated: 9 --w- 0 8 Indira Hrnjic CIO . Gti INDIRA HRNJIC, Plaintiff v. ELVIR HRNJIC, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-6519 IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE To: Elvir Hrnjic Indira Hrnjic, Plaintiff, intends to file with the Court the attached Praecipe to Transmit Record on or after January 7, 2009, requesting that a final Decree in Divorce be entered. Respectfully submitted, SAIDIS, FLOWER &_LII)(DSAY Carol J. Lindsay-, Es ire Supreme Court o. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 SA DIS, (FLOWER & LINDSAY 26 West High Street Carlisle, PA s -1 i INDIRA HRNJIC, Plaintiff V. ELVIR HRNJIC, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 06-6519 IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant was served with the Divorce Complaint by Constable on March 15, 2007. Proof of service was filed with the Court on March 19, 2007. 3. Date of the execution of the Affidavit required by Section 3301(d) of the Divorce Code: September 30, 2008; Date of filing and service of the Plaintiffs Affidavit upon the Respondent: November 17, 2008. 4. Related claims pending: None. 5. Date and manner of service of the Notice of Intention to file Praecipe a copy of which is attached: December 18, 2008. SAIDIS, FLOWERA-?I"AY SAIDIS, LENDS ATIOMYS-AX-1AW 26 West High Street Carlisle, PA uire CaYei'J. Lind- ` rTK Supreme C urt I No. 44693 26 West H' h S et Carlisle, PA 17013 717-243-6222 C7 o r° pq Cfl `? rn 4 INDIRA HRNJIC, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 06-6519 ELVIR HRNJIC, Defendant IN DIVORCE COUNTER-AFFIDAVIT UNDER 63301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (check (i), (ii) or both) W The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-affidavit are true and correct. I SAID?IS, FLOWER & LINDSAY ATIOMM"AMIAW 26 West High Street Carlisle, PA understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Dated: / 2-1 / 7-/o'V 1?fz V, Elvir Hnjlc NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you should not file this counter-affidavit. v ? _• 1 l r_"? C.ti} ?SJ INDIRA HRNJIC V. ELVIR HRNJIC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-6519 DIVORCE DECREE AND NOW, T' 016v%ac?.ry , M009 ', it is ordered and decreed that INDIRA HRNJIC , plaintiff, and ELVIR HRNJIC , 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. By the Court, lv? ? \ Attest: J. Prothonotary jp- r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 1NZ?\RA "PING Plaintiff Vs File No. Q G 6 S l IN DIVORCE EL'j KR?vZIC . Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] prior to the entry of a Final Decree in Divorce, or after the entry of a Final Decree in Divorce dated Q h? hereby elects to resume the prior surname of ?C>n*12v tc and gives this written notice avowing his / her intention pursuant to the provisions of 54 P.S. 704. Date: C" /o G1 I'?r? Signatur Signature of name b i resumed COMMONWE LTH OF PENNSYLVANIA ) COUNTY OF On the A044,day of & )LAA.2,E , 2000, before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. Notary Public' NOTARIAL SEAL PROTHONOTARY, NOTARY PUBLIC CARLISLE CUMBERLAND COUNTY COURTHOUSE MY COMMISSION EXPIRES JANUARY 4, 2010 RLED-(,,F icE OF T PPOTPC TARY 2009 JUN -4 PM 1: 53 F?