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IN THE COURT OF COMMON PLEAS OF THE FIFTY-NINTH JUDICIAL DISTRICT OF PENNSYLVANIA Plaintiff vs. Defendant * * * * * * * COUNTY BRANCH ELK/CAMERON CIVIL ACTION LAW NO. COMPLAINT FOR DIVORCE 3301(c)
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Applicant was first introduced as a "Attorney" and Applicant first became "Petitioner" and Applicant became "Plaintiff" in July, 2010. Applicant's current residence is in Bucks County. 2. Plaintiff is Plaintiff has been married four times. The dates of the first, second and three subsequent marriages are as follows: Date of Marriage Applicant's Current Full Name Plaintiff's Current Full Name 1. Applicant is a Plaintiff of record. 2. Applicant is Plaintiff's spouse for one and one-half years. The divorce court entered a permanent order for the dissolution of petitioner-Patty El-Khouir's first marriage in May, 2003. 3. Plaintiff is Plaintiff's spouse for seven years. This marriage has been annulled and the divorce proceedings are pending on appeal. 4. Both Pat-Ellie and Pathe-Marie El-Khouir are represented by the El Khouir Law Firm of Philadelphia and their current address is in Philadelphia. 5. Applicant is a Plaintiff of record in this action for the second time. 6. Applicant is Plaintiff's current spouse and this marriage was entered into in June, 2005 and terminated on the eve of petitioner's third attempt at marriage. 7. The last of three marriages to Pathe-Marie El-Khouir, who is a native of Lebanon and who is a resident of Philadelphia, occurred on September 24, 2012 and was dissolved on August 31, 2013. 8. Applicant is a Plaintiff of record in this action for the third time. 9. Applicant is Plaintiff's spouse for one and one-half years. The December 27, 2010 marriage between Pathe-Marie El-Khouir and Applicant is one such dissolution from August 31, 2013. 10. The April 21, 2011 marriage between Pathe-Marie El-Khouir and Applicant is one such dissolution from August 31, 2013. 11. Applicant is a Plaintiff of record in this action for the fourth time. 12. Applicant is a Plaintiff's spouse for seven years. Petitioner-Patricia Marie El-Khouir filed a petition for dissolution of marriage in July, 2013. This petition is presently pending before the Court. 13. Applicant is a Plaintiff's spouse for one year. In January 2007, Applicant and his current spouse were married in Lebanon on November 6, 2007. 14. Applicant is a Plaintiff's spouse for one month. In January 2007, Applicant and his current spouse were mar- ried in Lebanon on November 6, 2007. 15. Applicant is a Plaintiff's spouse for
Plaintiff requests that court file the following documents: Affidavit, and Complaint and Summons, as listed in Part IV of this Complaint. A valid order will be issued where: The alleged spouse is under age 18 (“Minor”), The spouses have been together since they knew each other (“Serves as a marriage of convenience”) or Has lived together since the time of the marriage (“Has been a member of a recognized domestic partnership since the marriage) OR Has resided there since “the date of the parties' marriage, which is the date of commencement of an action” I request you to deny this motion in its entirety.
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Getting a divorce in Pennsylvania is actually simpler than you might think neither spouse must be a resident of Pennsylvania for at least six months before filing the divorce may be filed in a county where the defendant resides the plaintiff resides if the defendant does not live in Pennsylvania the marriage home was if the plaintiff continuously resided in the same county prior to six months after separation and if the defendant agrees the plaintiff resides five to six months after separation and if neither spouse lives in the county of the marriage home either spouse lives and after six months following the separation either spouse lives once the residency requirement is completed a legal grounds for divorce must be established both general and no-fault divorce are acceptable grounds for divorce the no-fault reasons are irretrievable breakdown of the marriage with the spouses living separate apart without cohabitation for two years or irretrievable breakdown of the marriage and the spouses have both filed affidavits that they consent to the divorce in the case of no-fault ground the court may delay the case for 90 to 120 days if it appears that there is a reasonable chance for reconciliation and 90 days must elapse after the filing for divorce before the court will grant a divorce the general reasons for divorce are adultery bigamy imprisonment for two or more years' confinement for incurable insanity for 18 months willful desertion for one year cruel in a human treatment endangering the life of the spouse and personal indignities Pennsylvania does not require a parenting plan for child custody joint or sole custody may be awarded based on the best interests of the child and consideration of which parent is more likely to encourage and allow frequent and continuous contact including physical access between the other parent and the child whether either parent has engaged in any violent criminally sexual abusive or harassing behavior the preference of the child and any factor that affects the child's physical intellectual and emotional well-being both parents may require attending to counseling sessions regarding child custody the recommendations of the counselor may be used in determining child custody in shared custody the court may also require a written plan for child custody submitted to the court either or both parents may be ordered to provide child support according to their ability to pay the considerations by statute are the net income of the parents the earning capacity of the parents the assets of the parents any unusual needs of the child or the parents and any extraordinary expenses' child support may be paid through the Domestic Relations section of the court there are official child support guidelines available and these are presumed to be correct unless there is a showing that the amount will be unjust or inappropriate for the circumstances of the case the court may require health insurance coverage be provided for any child if...
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