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Home My WebLink About02-3521KATHY L. KAHL1L, Plaintiff MOHAMED KAHALIL SALEH KHALIL. Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA : Civil Action - Law : 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, the case may proceed without you and a decree of divorce or annulment may be entered against you by thc Court. A judgment may also be entered against you for any other claim or relief or property or other rights important to you, including custody or visitation or your children. When the ground 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, Dauphin County Courthouse, Harrisburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S 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. DAUPHIN COUNTY LAWYER REFERRAL SERVICE 213 NORTH FRONT STREET HARRISBURG, PENNSYLVANIA 17101 717-232-7536 KATHY L. KAHLIL, Plaintiff MOHAMED KAHALIL SALEH KHALIL. Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA 02- : Civil Action - Law : Divorce COMPLAINT IN DIVORCE AND NOW comes Plaintiff, Kathy L. Kahlil, by her attorney, Kathy M. Shughart, and files this Complaint, based upon the following: 1. Plaintiff, Kathy L. Kahlil, born October 1, 1959, is an adult individual and national of the United States &America, who currently resides at 3210 D Wakefield Road, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant, Mohamed Kahlil Saleh Khalil, born April 28, 1955, is an adult individual and national of Egypt, who is in the United States &America pursuant to a Visitor's Visa, and whose current address is an apartment in Camp Hill, Cumberland County, Pennsylvania, the precise address is unknown. Plaintiff and Defendant were married on November 3, 2001 in Dauphin County, Pennsylvania. 4. 5. 6. The parties separated on July 2, 2002. There are no children of this marriage. Plaintiffand Defendant have been bona fide residents of this Commonwealth for at least six (6) months immediately prior to the filing of this Complaint. 7. There are no pending actions in divorce or annulment in this jurisdiction or in any other jurisdiction brought by either Plaintiff or Defendant above-named. 8. Neither Plaintiff nor Defendant is presently a member of the Armed Forces on active duty. 9. Plaintiffhas been advised of the availability of counseling and that Plaintiffmay have the fight to request that the court require the parties to participate in counseling. 10. Plaintiff avem that the marriage is irretrievably broken. 11. The parties have been living separate and apart. At a subsequent time, Plaintiff may submit an Affidavit that the parties have lived separate and apart for at least two (2) years. 12. Plaintiff avers that Defendant has offered such indignities to the person of the Plaintiff so as to render Plaintiff's condition intolerable and Plaintiff's life burdensome. WHEREFORE, Plaintiff requests your Honorable Court to enter a Decree of Divorce from the bonds of matrimony. Respectfully submitted, ~Kathy~. Shughart ~ Attorney for Plaintiff P.O. Box 6315 27 South Arlene Street Harrisburg, PA 17112-0315 (717) 540-8511 Supreme Court #39779 VERIFICATION I verify that the statement made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that the statements therein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. KATHY L. KAItLIL, Plaintiff VSo MOHAMED KAHALIL, SALEH KAHLIL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-3521 : : CIVIL ACTION - LAW : : DIVORCE AFFIDAVIT OF SERVICE I, Kathy M. Shughart, Esquire, hereby certify that a tree and correct copy of the Complaint for Divorce was served on the Defendant by Richard Kreitzer, Process Server, on July 25, 2002, at the Defendant's place of employment at: The Four Seasons Restaurant Camp Hill, Pennsylvania The Affidavit of Process Server is attached hereto as Exhib!I "A". K~thy l~I. ~hughart, Esq '~e 27 S. Arlene Street P.O. Box 6315 Harrisburg, PA 17112-0315 (717) 545-8511 Attorney for Plaintiff Sworn to and subscribed before me this 1~ day of 5e,o4-ern~o'£ ,2002. '- l~lotary Publid (~3 NOTARIAL SEAL [ MELISSA A. POLING, Notary Public ~ Lower Paxton Twp., Dauphin County ! My Commission Expires Sept. 1,20031 Affidavit, of Process Server /p DEFENDANT/RESPONDENT CASE # I declare that I am a citizen of the United States, over the age of eighteen and not a party tO this action. And that within the boundaries of the state where service was effected. I was authorized by law to perform said service. Service: Iserved ~Ojl~:)~'~) )~J"~"~- -~/--~4 ~'~ NAME OF PERSON/ENTITY BEING SERVED w,th the (documents) ~iv0~ ~Z~ .~ NAME at [] Home ~Business _ ~:~'~ ~'/~-~,"~,r on ~ - ~ .I--0 1. DATE at //:t J-" RELATIONSHIP Thereafter copies of the documents were mailed by prepaid, first class mail on DATE from CITY STATE Manner of Service: ~yy personally delivering copies to the person/authorized agent of entity being served. [] By leaving, during offiCe hours, copies at the office of the person/entity being served, leaving same with the person apparently in charge thereof. [] By leaving cop~es at the dwelling house or usual place of abode of the person being served, with a member of the household 18 or older and explaining the general nature of the papers. [] By posting copies in a conspicuous manner to the address of the person/entity being served. Non-Service: After due search, careful inquiry and diligent attempts at the address(es) listed above, I have been unable to effect process upon the person/entity being served because of the following reason(s): (3 Unknown at Address [] Evading n Moved, Left no Forwarding (3 Other: [] Address Does Not Exist [] Service Cancelled by Litigant (3 Unable to Serve In a Timely Fashion Service Attempts: Service was attempted on: ( ) ( ) DATE T~ME DATE T~ME ( ) ( ) ,( ) DATE TIME DATE TIME DATE I declare under penalty of perjury.that the inform.a~ion contained herein is_true and correct and this.~ffidavit was State of ~wJ'.~,~L~O,~SIGNATURE OT;I~CESS SERVER County of subscribed and sworn before me. a notary public, this 31 day of J'~/-~ 2~ ~,,~.-~ TIME Glasses: ~/.~" executed on WITNESS MY HAND AND OFFICIAL SEAL TO FORM 2 NATIONAL ASSOCIATION OF PROFESSIONA~~'I~II~/"~ NOT! KATHY L. KAHLIL, Plaintiff MOHAMED KAHALIL SALEH KItALIL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA :NO: 02-3521 : Civil Action - Law : Divorce AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 24, 2002. 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. 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 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..,~ection 4904 relating to unswom falsification to authorities. /.~7~ ~.~~1~. Date: /t0/~ ~",/~ ..~ MOHAMED~~ALEH KHALIL, 'I~efendant KATHY L. KAHLIL, Plaintiff MOHAMED KAHALIL SALEH KHALIL. Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA :NO: 02-3521 : Civil Action - Law : 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 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 the statements made in this affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. section 4904 relating to unsworn falsification to authorities. Date: MOHAMED KAH~LIL SALEH KHALIL, Defendant KATHY L. KAHLIL, Plaintiff MOHAMED KAHALIL SALEH KHALIL. Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA :NO: 02-3521 : Civil Action - Law : 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 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 the statements made in this affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. section 4904 relating to unsworn falsification to authorities. KA~IY--L. KA~LIL, Plaintiff KATHY L. KAHLIL, Plaintiff Vo MOHAMED KAHALIL SALEH KHALIL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, : PENNSYLVANIA :NO: 02-3521 : Civil Action - Law : Divorce AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on July 24, 2002. 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. 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 the statements made in this aftidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: KA¥I-iY L. I~/:HLIL, Piaintiff KATHY L. KAHLIL, Plaintiff VS. MOHAMED KAHALIL SALEH KAHLIL, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-3521 : CIVIL ACTION - 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: Code. 2. irretrievable breakdown under 3301 (c) of the Divorce Date and manner of service of the complaint: July 25, 2002, by Richard Kreitzer, Process Service. Attached is the Affidavit of Service signed by the Process Server. 3. (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff on October 24, 2002; by the Defendant on October 24, 2002. 4. Related claims pending: None. 5. (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Same as this Praecipe. Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Same as this Praecipe. // [0 -~ -C) ?-~ Kathy M. Shughart, Esquire 27 South Arlene Street Post Office Box 6315 Harrisburg, PA 17112 (717) 540-8511 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF *~~ PENNA. KATHY KAHLIL, Plaintiff VERSUS MOHAMED KAHALIL SALEH KAHLIL, Defendant N o. 02-3521 DECREE IN DIVORCE AND NOW, 2002 It IS ORDERED AND DECREED THAT AND ~AT~¥ ~A~T,TT, MOHAMED KAHALIL SALEH KAHLIL , PLAINTIFF, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FO1. LOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; BY TH,~::OURT: / ATTEST: · /~ PROTHONOTARY