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HomeMy WebLinkAbout02-4978SCOTT L. YUNG, VS. MELISA J. YUNG, Plaintiff Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :No. ~,,~'-tt/~?Tff Civil Term :ACTION 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 or other rights important to you, including custody or visitation of your children. Where the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of maxriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 SCOTT L. YUNG, VS. MELISA J. YUNG, Plaintiff Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA :No. Oo2- - q q"t F : :ACTION IN DIVORCE Civil Term COMPLAINT UNDER SECTION 3301 of the DIVORCE CODE 1. Plaintiff is Scott L. Yung, who currently resides at 9 Millers Gap Road, Enola, Cumberland County, Pennsylvania, 17025. 2. Defendant is Melisa J. Yung, who currently resides at 75 N. 34th Street, Harrisburg, Dauphin County, Pennsylvania, 17109. 3. Plaintiff and Defendant have bene bona fide residents of the Commonwealth for at least 6 immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on September 23, 2002 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff and Defendant have no children together. 9. Neither Plaintiff and Defendant are a member of the military. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken; WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I verify that the statements made in this Complaint 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. Respectfully submitted: ATTORNEY FOR PLAINTIFF SCOTT L. YUNG, VS. MELISSA J. YUNG, Plaintiff Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COLrNTY, PENNSYLVANIA : : No. 02 - 4978 Civil Term : :ACTION IN DIVORCE : _AFFIDAVIT OF SERVICE OF NOTICE TO DEFEND AND COMPLAINT AND NOW, this October 21, 2002, I, Jane Adams, Esquire, hereby certify that on or about October 19, 2002, a certified true copy of the NOTICE TO DEFEND AND COMPLAINT was served, via certified mail, restricted delivery, return receipt requested, addressed to: Melisa J. Yung 75 N. 34th Street Harrisburg, Pa. 17109 DEFENDANT Respectfully Submitted: 36~gouth Pitt Street ~-Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF · yes UNITED STATEs POSTAL · Sender: Please Pdr address, ' and E~ p~.4 ~TOP, NL:Y.AT S. PrTT 8TRE[~¢ ~,ARLISLE, PA SCOTT L. YUNG, VS. MELISSA J. YUNG, Plaintiff Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 02 - 4978 Civil Term :ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on October 14, 2002. 2. The mardage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the 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 vedfy that the statements made in this affidavit are true and correct. I also understand that falsificationfalse statementSto authorities.herein are made subject to the penalties,,~f 1Ji~P .C~,Ma/[ 4904, relating to unsworn Date: ~ '[c~ ' c'~ ~ ~ WAIVER OF NOTICE O TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to 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. CAS. §4904 relating to unsworn falsification to authorities. [.!~.~ ~ Date: ~, [ct .~->~ ~'reliss~g'J'--Yu~. SCOTT L. YUNG, VS. MELISSA J. YUNG, Plaintiff Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · No. 02 - 4978 Civil Term :ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on October 14, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a final decree of divome 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 also understand that false statements herein are made subject to the penalties of 18 Pa.C..S. 4904, relating to unsworn falsification to authorities. Date: WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODF 1. I consent to 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: ~.~--~/~,-~.~ ~ ~ ,~~~~ ~ / ~cott L. Yang, Defenda~ ~ SCOTT L. YUNG, VS. MELISA J. YUNG, Plaintiff Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · No. 02 - 4978 Civil Term :ACTION IN DIVORCE PRAEClPE 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 the service of the Complaint: Delivered ~by certified mail, restricted delivery, return receipt requested, delivered on: 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: By Defendant: '~-J9--O ~:~ 4. Related claims pending: None· 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: Date Plaintiff's Waiver of Notice in {}3301(c) Divorce was filed with the Prothonotary: '~"~ -- ~ i -- O ~ Respectfully Submitted: Date: '*~-"~ 36 S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ..~.. PENNA. Scott L. Yung, Plaintiff VERSUS Melisa L. Yung, Defendant No. No. 02 - 4978 Civil Term DECREE IN DIVORCE AND NOW, ~l~,;I ~ , ~{1~, it IS orderED AND Scott L. Yung, Plaintiff , PLAINTIFF, DECREED THAT AND Melisa L. Yung, Defendant , 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. THE COUrt: BY ~ · ATTE.~ ROTHONOTARY SCOTT L. YUNG, VS. MELISA J. YUNG, Plaintiff Defendant · IN THE COURT OF COMMON PLEAS · CUMBERLAND COUNTY, PENNSYLVANIA · No. 02 - 4978 Civil Term :ACTION IN DIVORCE PRAECIPE FOR NAME CORRECTION TO THE PROTHONOTARY: Please be advised that the correct spelling of Defendant's first name is MELISA, not MELISSA. Kindly correct the caption of the case as set forth above. Respecffully Submitted: e Adam~ ~. ~ ~946 ' 36 S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff IN THE COURT OF COMNION PLEAS OF CUMBERLAND COUNTY STATE Of ~% PF_NNA. Scott L. Yun~, Plaintiff VERSUS Melisa J. Yung~ Defendant NO. 02 - 4978 Civil Term DECREE IN DIVORCE AND NOW DECreed THAT Scott L. Yung , ~..~"~ IT IS ORDERED AND , PLAINTIFF, AND Melisa J. Yung , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE SEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. BY THE COURT: at~: ' ' ~ "" J' ~~ PROTHONOTARY