Loading...
HomeMy WebLinkAbout02-3711MOHAMMAD ZAFFAR, Plaintiff V. KEIVA LMCALLISTER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. Oa : CIVIL ACTION - LAW : IN 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 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 of other rights important to you, including the 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 at the Office of the Prothonotary. 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 Count I - Divorce 7. The allegations of Paragraphs 1 through 6 are incorporated herein by reference and made a part hereof. 8. This action is not brought through collusion between the Plaintiff and Defendant, but in sincerity and truth for the reasons set forth within. 9. The marriage is irretrievably broken, and the parties are proceeding under Section 3301(c) of the Divorce Code 10. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce decree dissolving the marriage between Plaintiff and Defendant. RESPECTFULL~ SUBMI , Camp Hill, PA 17011 (717) 761-8101 Date: MOHAMMAD ZAFFAR, Plaintiff V. KEIVA L.MCALLISTER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. -- ,9'7l/ o CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW comes the Plaintiff, Mohammad Zaffar, by and through his attorney, Charles Rector, Esquire, and respectfully represents as follows: 1. Plaintiff is Mohammad Zaffar (SS~ 094-84-3562), an adult individual, currently residing at 314 April Drive, Apt. #1, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defendant is Keiva L. McAIlister (SS# 104-62-5431), an adult individual, currently residing at 146 Zanburen Street, Brooklyn, New York, 11211. 3. Plaintiff has been bona fide residents of the Commonwealth of Pennsylvania for a period of six months (6) immediately preceding the filing of the Complaint. 4. York. 5. the parties. 6. Plaintiff and Defendant were married on April 4, 1997, in Queens, New There have been no prior actions for divorce or for annulment between The Plaintiff and Defendant are both citizens of the United States of America. I verify that the statements made herein am 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. Mohammad Zaffer Date:e~- z ?- o~ MOHAMMAD ZAFFAR, Plaintiff V. KEIVA L.MCALLISTER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-3711 Civil Term : : CIVIL ACTION - LAW : IN DIVORCE PROOF OF SERVICE OF DIVORCE COMPLAINT Certified Fee Return Receipt Fee (Endorsement Required) Date: · Cemplete 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. ,N~lcle Addressed to: A. Received by (Please Pdnt Clearly) C. Signature x r,O/ D. I~nYery ~s~ different from item 17 If YES, ent~' delivery address below: I-I yea [] No 3. Service Type ~-Certified Mail [] Express Mail [] Registered [] Return Receipt for Memhandise [] Insured Mail [] C.O.D. 4. Restricted Delivery? (Extra Fee) [] Yes 2. Nticle Number (Copy from service label) _ ~, 7 015, b 5 71,5. 3) 50 PS F~m 13~81 I, Ju~/~g99 Do~: R~urn Rec~pt CharEs Rector, Esquire 1104 Fernwood Avenue, Ste. 203 Camp Hill, PA 17011-6912 (717) 761-8101 102595-00-M-0952 MOHAMMAD ZAFFAR, Plaintiff V. kEIVa L.MCALLISTER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-3711 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 1, 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 in divorce after service of notice of intention to request entry of the decree. WAIVER OF NOTICE OF INTENTION T© .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 that the statements made herein 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: Keiva L. McAIlister MOHAMMAD ZAFFAR, Plaintiff V. KEIVA L.MCALLISTER, Defendant · IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-3711 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT 1, A Cumpic, int in ~vorce und~' Section 3301 (c) of tt3e Divorce Code was flied on August 1, 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 in divorce after service of notice of intention to request entry of the decree. 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 ~ot c!c!:'n thern before a divorce is 9rant~d: 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 herein 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. Mohammad Zaffar Date: ) I i~,?'~L MOHAMMAD ZAFFAR, ' IN THE COURT OF COMMON PLEAS OF Plaintiff ' CUMBERLAND COUNTY, PENNSYLVANIA V. · NO. 02-3711 CIVIL TERM KEIVA L.MCALLISTER, ' CIVIL ACTION - LAW Defendant · 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 a divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: Certified Mail - 8/9/02. 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the Plaintiff 11/22/02, by the Defendant 11/22/02. (b) (1) Date of execution of the plaintiff's affidavit required by Section 3301(d) of the Divorce Code: (2) Date of service of the plaintiff's affidavit upon the Defendant: 4. Related claim pending: None. 5. Complete either (a) or (b) (a) Date and manner of service of the notice of intention to file praecipe t° transmit record, a copy of which is ,.t,ach.,,, .decree is. to be entered und., .sec.,on ° * ~. i.f the , 3301 (d) of the Divorce Code: (b) Date Plaintiff's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary .11/26/02 Date Defendant's Waiver of Notice in § 3301(c) was filed with the Prothonotary .11/26/02. Date: 11/29/02 Charles Rector, Esquire Attorney for the Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND STATE OF ~ COUNTY PENNA. Mohammad Zaffar Versus Keiva L. McAllister DECREE IN DIVORCE AND NOW .... ~cc¢.~.. ¢I-...Z..~ ......1~ .......it is ordered and decreed that ...........~oh.~m~..~E~.~ ..................... plaintiff, and .................~Y~..~:. ~.~.~.[ .................. 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 By The Court'//~ /'/~ / / ~ ~-q x ~ Prothonotary KELLY A. YODER, Plaintiff MARK L. YODER, Defendant Ve IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 02-3768 Civil Term IN 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 conceming 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. Dated: Mark L. Y~ KELLY A. YODER, MARKL. YODER, Plaintiff, Defendant, · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA : : : NO. 02-3768 Civil Term : 6, 2002. AFFIDAVIT OF CONSENT A Complaint in divorce under section 3301 (c) of the Divorce Code was filed on August 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 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. Mark L. ~;fi~r~ KELLY A. YODER, Plaintiff V. MARK L. YODER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3768 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) of the Divorce Code. 2. Date and manner of service of the Complaint: Service was accepted by the Defendant on the 9th day of August, 2002, by signing an Acceptance of Service. Acceptance of Service filed with the court August 16, 2002. 3. Date of execution of the Affidavit of Consent required by § 3301(c) of the Divorce Code: by Kelly A. Yoder, Plaintiff, on November 11, 2002; by Mark L. Yoder, Defendant, on November 11, 2002. 4. Related claims pending: Settled by Agreement dated September 24, 2002. I verify that the statements made herein 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 unswom falsification to authorities. Mohammad Zaffer