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Home My WebLink About00-00632 ~~X):+;<:'::;:€{::~X:::;:+;{>:.z'::X+>::)~{:::;:<<~~~:€{):+;{:,:;:+;;::):€{X+X:):+XX+;{,;;:+;;::::':+x'-::i:n;:+:m;:+K:i:+::i:1X+::ifli:+;,g;:+;{):€;::::K€ig;a,:<r::" ~.~ ~ U jl;'~ ~ c. '-0'" W ~.~ ~.~ ~ ~ ~ ".~ ~ ~ .., ',.". ~ ~"; " ~ ~ i I . ~..=;:":<<<.;. ':~'>>~(':.::.::(:'::.::.::.';:)::.>:::"'.::<<':,-':..::.:.._""'::.~,,'>:+::.:: -"'::+::""'.::+::'., "'.::+;',: -.::+;'- ".::.::. ~ ~.~ j;~~ ~ ~ !l'.~ ~ ~ ~ !'.~. ~~~ ~ ~~ ~.~ ~ ~ i.'~ ~ ~~ ~ ~~ ~ i'~ ~ ~"; ~..~ ~ ,", N . ~.~ ~'s ~ ~ ~'S ~ ~~~ ~ ~.s ~ ;..~ , ~'s ~ i t',,; ~'s , ~", ~ ,l -"; t- ..., ,~. . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE:: OF PENNA. XIN LIN HuANG Versus umu_,mmm I II 'I N o. u.uu,u2.9.(),().~63.,2.,uu__uu,. tti,9 JUYING HUANG DECREE IN DIVORCE ~~W2 '1...'1 200<W AN 0 NOW, . . . . . . . .. .. .. .. . .. .. . .. .. .. . , .. ' .. . , it is ordered and decreed that....... .~~.n. .~~~, .~~a~.g.........................., plaintiff, and. . . . . . . . . ' , . .~~~~.n,g . ~~.a.~~. . . . . . . . . . . . . . . . . . . . . . . . . . . . . " 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; ~ O~ The attached Matrimonial Settlement Agreement is incorporated . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , By Attest: Prothonotary ~ ::.::+::.;::':;'::+::,;;: ::'::+::'.: :::-::+::.-:: :::.::+::<.:;.::.::.' "'::.::'" ': .::+::< '.::+::< >::+}' -- _~i! ~'s * ""'- ~ i ~.~ ~.~ * ~ ~ ~.~ ~.~ J ~,"'~ ~ ~.~ ~ ~.~ ~ N ~ ~ ~.~ ~.~ ~ i ~.~ ~ ~.~ ~~ ~.~ ~ .;.~ ~ ~.~ i ~ ~ ~'S ~ ~ ~.~ ~ '-",' ~ ~.f; ~ ~.~ ~ ~.~ ;:.~ ~ ~ y ~ ~.~ ~ ~.~ ~ .,', ~ '.' J, ~ ~.~ ~ ~ '.' ~ '.' ;'~ ~ w .' l,_ .. ii" i-. .tv ~- .c/O "-'~ -~ 1-" &i~'~~J;Z ~ ~ /~ /1otv pu~ ~ dfI- , ,_ 1lF.lI'~~m ~" _~ :-F1..I!t!I!!IllJIII!I1_ ~,....._I!IIl~" ,~~~ ""111AM",i <, MATRIMONIAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this U'tf, day of ~~ referred to , 2000, by and between XIN LIN HUANG, hereinafter as "Husband" and JUYING HUANG, hereinafter referred to as "Wife". WITNESSETH: WHEREAS, Husband and Wife were lawfully married on December 1, 1987; and o c::> r {....- '_J ~;~ f~; .... -:1 WHEREAS, certain differences have arisen betwee~~he~art~~s ;:s c] '.~---'-'_: Jl as a result of which they have separated and now li~~ep~at~,~~ ):> c- (l...-J ;---:;; ill and apart from one another, and are desirous, therefo~, 8J :~ =< .~ 3! entering into an agreement which will provide for their mutual responsibilities and rights growing out of the marriage relationship; and WHEREAS, Husband, after being properly advised by his attorney, Herschel Lock, and wife, after being requested to obtain legal counsel but choosing not to do so, have come to the following agreement. NOW, THEREFORE, in consideration of the above recitals and the following covenants and promises mutually made and mutually to be kept, the parties heretofore, intending to be legally bound and to legally bind their heirs, successors and assigns thereby, covenant, promise and agree as follows: - 1 - &yj:rfJ ~ ~ 1/l--ts. -'1 ...LiIiIIIljjfij,-",J . 1. SEPARATION: It shall be lawful for each party at all times hereafter to live separate and apart from the other at such place or places as he or she may from time to time choose or deem fit. 2 . INTERFERENCE: Each party shall be free from interference, authority and contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other nor attempt to endeavor to molest the other, nor compel the other to cohabit with the other, nor in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 3. WIFE'S DEBTS: Wife represents and warrants to Husband that since the separation she has not, and in the future she will not, contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. 4. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since the - 2 - UV\jn t:lu-~ ~ 4/ lo--- ~j < separation he has not, and in the future he will not, contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. 5. MUTUAL RELEASE: Subject to the provisions of this Agreement each party waives his or her right to alimony and any further distribution of property inasmuch as the parties hereto agree that this Agreement provides for an equitable distribution of their marital property in accordance with the Divorce Code, its supplements and amendments. Subject to the provisions of this Agreement, each party has released, discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights or demands whatsoever in law or equity, which ~ither of the parties ever had or now has against the other, except any or all cause or causes of action for divorce and except in any or all causes of action for breach of any provisions of this Agreement. Each party also waives their right to request marital counseling pursuant to the Divorce Code. 6. BUSINESS; The parties hereto acknowledge that they are joint - 3 - Cf'^y~ H~ o/~ ~, '"~=.H'~ owners of the restaurant known as New Forest of Mechanicsburg, PA and agree that their joint ownership thereof shall survive the execution hereof and their subsequent divorce. 7. DIVISION OF PERSONAL PROPERTY: All personal property, household furnishings, furniture and the like, savings, retirement accounts or pensions of any sort, as well as any other personalty presently in the possession of each party shall remain the sole and exclusive property of that party. However, this notwithstanding, the parties hereto agree that Husband shall become the sole owner of the 2000 Toyota Tundra, Wife shall become the sole owner of the 1998 Toyota Cienna and Husband shall be solely responsible for paying the debt presently on each. However, specifically as to those stock and bonds presently in Husband's name alone, the parties hereto agree that Husband shall remain their sole owner and Wife shall give up any right, title o~ inte~est therein. Husband and Wife agree that urt xlJ > with the 8 . DIVISION OF REAL PROPERTY: execution hereof Husband shall transfer all of his right, title an interest in and to the marital home known and numbered as 235 Indian Creek Drive, Mechanicsburg, PA to Wife and that thereafter Husband shall be solely responsible for payment of the mortgage presently thereon, this in both of their names and owed to US Bank. ---- ' o \..A-~~ 1fLA~ q?~ - 4 - !lMiIIl!!iiJ 9 . ALIMONY: Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them and are accepted by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance or alimony. Husband and Wife, further, voluntarily and intelligently waive and relinquish any right to seek from the other any payment for support or alimony. 10. ALIMONY PENDENTE LITE, COUNSEL FEES, AND EXPENSES: Husband and Wife acknowledge and agree that the provisions of this Agreement providing for the equitable distribution of marital property of the parties are fair, adequate and satisfactory to them. Both parties agree to accept the provisions set forth in this Agreement in lieu of and in full and final settlement and satisfaction of all claims and demands that either may now or hereafter have against the other for alimony pendente lite, counsel fees or expenses or any other provision for their support and maintenance before, during and after the commencement of any proceedings for divorce or annulment between the parties. The provisions of this Agreement dealing with alimony, alimony pendente lite, counsel fees, spousal support and the like - 5 - 6.A~ H~ ~o/~ ,,,. " .. M1 1iIIII:.iii; are intended by the parties to be in full and complete satisfaction of any statutory marital rights or obligations of the parties. 11. WAIVERS OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire, under the present laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, curtsy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, execute, acknowledge and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 12. TAX RAMIFICATIONS: The parties have negotiated this Agreement with the understanding and intention to equally divide their marital property. The parties have determined that such equal division conforms to all rights and just standards with regard to the rights of each party. The division of existing marital property is not intended by the parties to constitutes or any way a sale - 6 - UvA--y/~ r+~ ~~'i~ ,. '~. or exchange of assets. It is understood that the property transfer described in this Agreement fall within the provisions of Section 1041 of the Internal Revenue Code, and as such will not result in the recognition of any gain or loss upon the transfer by the transferor. 13. SUBSEOUENT DIVORCE: A Complaint in Divorce has been be filed by Husband. Husband and Wife each agree to sign contemporaneously with the execution hereof an Affidavit of Consent and Waiver of Notice of Intent to File for Divorce to be filed in said divorce action. The parties further agree that each of them shall be responsible for their own attorney's fees, if any there be. In the event such divorce is concluded, Wife shall be entitled to receive a copy of the Decree In Divorce for the normal fee charged by the Prothonotary. In the event such divorce action is concluded, the parties shall be bound by all the terms of this Agreement, which shall be incorporated by reference into the Divorce Decree, but, notwithstanding such incorporation, this Agreement shall not be merged in such Decree, but shall in all respects survive the same and be forever binding and conclusive upon the parties. 14. CUSTODY: '/- {J Jtfe parties children, Han_wei and hereto are the natural parents of two minor Alan, and the parties agree that they shall share joint physical and legal custody of their children with - 7 - J~~11 tl~ ~~~ '....~~.i Wife being their primary physical custodian subject to Husband's rights to free and liberal periods of temporary custodian as may be agreed to by and between him and Wife. 15. BREACH: If either party breaches any provision of this Agreement, the other party shall have the right, at his or her option, remedies or relief as may be available to him or her, and the party breaching this contract should be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 16. ADDITIONAL INSTRU~~NTS: Each of the parties shall from time to time, at the request of the other,execute, acknowledge and deliver to the other party any and all further instruments that may be required to give full force and effect to the provisions of this Agreement. 17. VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to Husband by his counsel while Wife has declined legal representation, and each party acknowledges that the Agreement is understood by them, is fair and equitable, that it is being entered into voluntarily, with full knowledge of the assets of both parties, and that it is not the result of any - 8 - J--01.1"1t VllA~ ~d7~ ,C ~" ~ IIIlliE'_"1 duress or undue influence. The parties acknowledge that they have been furnished with all information relating to the financial affairs of the other which they have requested. 18. ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or understandings other than those expressly set forth herein. Husband and wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other relevant factors which have been taken into consideration by the parties. Both parties hereby accept the provisions of this Agreement with respect to the division of property in lieu of and in full and final settlement and satisfaction of all claims and demands that they may now have or hereafter have against the other for equitable distribution of their property or for alimony, alimony pendente lite, counsel fees or costs by any court of competent jurisdiction pursuant to the Divorce Code or any other laws. Husband and Wife each voluntarily and intelligently waive and relinquish any right to seek a court ordered determination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement. - 9 - ~v-1~ l41.^-~ ~~~~. ~;- 19. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. 20. INDEPENDENT SEPARATE COVENANTS: It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 21. APPLICABLE LAW: This Agreement shall be construed under the law of the Commonwealth of Pennsylvania. 22. VOID CLAUSES: If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition or provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and continue in full force and operation. 23. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the - 10 - J,-,-~ l-'u.~ ~J/~ " . ''III;alsli. benefit of the parties hereto and their respective heirs., executors, administrators, successors, and assigns. 24. MODIFICATION AND WAIVER: A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written. WITNESS: ~ \;J' (j~ ~ 0L-, . XIN LIN HUANG - c2:5 Jl.A.Yl~ Hf..A..~ JUYING HUANG - 11 - .\ IIWMil:>: AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ) . COUNTY OF DAUPHIN ) SS: On this, the ) LA If h day of ~ ' 2000, before me, a Notary Public, the undersigned officer, personally appeared XIN LIN HUANG known to me (or satisfactorily proven) to be the same person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. IJ~~~~ %~C Notary Public NGYArIAlSfAL . CONNIe L FAlINE!.,'^"\. ....., NIle Ho...1 bur" DlIuph/n r'~ AIr ~ ". fopba......... . 'liMIlj", AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA ) . SS: COUNTY OF DAUPHIN ) On this, the !!J Jth day of ~ , 2000, before me, a Notary Public, the undersigned officer, personally appeared JUYING HUANG known to me (or satisfactorily proven) to be the same person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal. ~~tU~!4~ Notary Public NOfArlAl SIAL ,."', CONNIE L FAHNmlXIr. ....., NIle ,...... .. DlIuph/n c......, AIr~ .. l..........lIllIlI ~~-" ~~-~ ~. -",,~ '"""'"~ 1iiti!iJj" XIN LIN HUANG, f ... Plaintiff IN THE COURT OF CCMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-632 CIVIL 'TERfII~ vs. JUYING HUANG, Defendant CIVIL ACTION - LAW ACTION 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. Grounds for divorce: irretrievable breakdown under Section 3301 (c) :S8ill:]c~li.jcQ&) of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the complaint: February 4, 2000 Certified Mail, Return Receipt Requested 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 June 1, 2000 by the defendant May 23, 2000 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 claims pending: None 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(l)(i) of the Divorce Code ~)a( Herschel Lock, Esq Attorney for PlaintiffjIEflllllldiK1lt 1- iliIlIIll!iII~~I~"'''''' ""'~-""'''''~i;!Mi!lJj"jj,:l;*",I~I..''''.';,;;!lg,-,_,",jL~ilIiWil''''''''"'~~ '~_t!lO- ,~... . , "" i , (') <:::) 0 C a S q lie) ,- m-.~ '-, ~~i=: --"'. 1 "- f-;~ ,'o,,) ) n; (f) -- (.::J 1-") ~6 t~S ~- :::c" zC"::' ::i'v; --c' .~,;C) Pc co ,6rl1 z ~ ~ r-- -c: en -< ..~~~- - ~, XIN 'LIN HUANG, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . . vs. NO. 2000 -?3..::1.. CIVIL TERM : JUYING HUANG, Defendant CIVIL ACTION - LAW 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 ybu 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, 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 LOST 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. COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, 4TH FLOOR ONE COURTHOUSE SQUARE CARLISLE, PA 17013-3387 (717) 240-6200 """",,. , lilt:..}: XIN LIN HUANG, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000 - (, 3.z.. CIVIL TERM JUYING HUANG, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN NAMED DEFENDANT: YOU HAVE BEEN NAMED AS DEFENDANT in a divorce proceeding filed in the Court of Common Pleas of Cumberland County, Pennsylvania. This Notice is to advise you that, in accordance with Section 202 of the Divorce Code, you may request that the Court require you and your spouse to obtain marriage counseling prior to a divorce decree being handed down by the Court. A list of professional marriage counselors is available at the Office of the Prothonotary, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania 17013. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. PROTHONOTARY - 'IlIiioJ,J XIN LIN HUANG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000 - (,3.:u CIVIL TERM JUYING HUANG, Defendant . . CIVIL ACTION - LAW ACTION IN DIVORCE : COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW, comes the Plaintiff XIN LIN HUANG, by his attorney, Herschel Lock, and seeks to obtain a Decree in Divorce from the bonds of matrimony with the above-named Defendant, and avers the following: 1. Plaintiff Xin tin Huang is an adult individual residing at 235 Indian Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant Juying Huang is an adult individual residing at 235 Indian Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Both Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on December 1, 1987 in Fuzhou, China. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Defendant is not a member of the Armed Services of the united States or any of its Allies. <^ ~,j 8. Plaintiff has been advised of the availability of counseling, and understands that he has the right to request the Court to require the parties to participate in counseling. WHEREFORE, Plaintiff respectfully requests the Court to enter a Decree in Divorce. DATED: 2/1/00 Jt HERSCHEL LOCK, QUIRE ATTORNEY FOR PLAINTIFF 3107 North Front Street Harrisburg, PA 17110 (717) 238-6661 - '~;- VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 2/1/00 ~/~~~3~ XIN LIN HUANG .0 b..Jid~~..c:.lihJliillll'<~ ,~ ." ," . "'._~ililWIIIlI'-"-~ -'-"> j, ,< ,< - ,~ ~ ........ ~C< ~ &' ~ ~ \~B \ ~ ~ ~, '" , ~ , ,~ - o c ~~ ~~~i -,..;: ~.,.t'-'" ~ """< ~>(_. ~c: ?;j .1 en ~ c, o -., M c:o I (.,...) Q -T' ".:::-J !- ~''j ,;;g -,::1-;1 '\."-' s: i(~, ~:j{~ ~~I-rl .;'; ~ ~D ~? > .~_.._. ,I "'10 ~ " w'-il"1 ...... JiQ.llIit XIN LIN HUANG, . IN THE COURT OF COMMON PLEAS . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. : NO. 2000-632 CIVIL TERM JUYING HUANG, : CIVIL ACTION - LAW Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICE Herschel Lock deposes and says: 1. That he is an adult individual residing in Dauphin County, Pennsylvania. 2. That on February 4, 2000, he sent by Certified Mail, Return Receipt Requested from Harrisburg, Pennsylvania P160-940-499 the Complaint in Divorce in the above-captioned case to: Juying Huang 235 Indian Creek Drive Mechanicsburg, PA 17055 3. That on February 9, 2000, Juying Huang signed the receipt No. P160-940-499 which is attached to this Affidavit. DATED: 6/5/00 ~ch\ BY: HERSCHEL LOCK, ESQUIRE ATTORNEY FOR PLAINTIFF 3107 North Front Street Harrisburg, PA 17110 (717) 238-6661 Sworn to and subscribed before me this 5th day of June , 2000. C~j/~ 9Jd~ Notary Public NOfAIIAl SEAl. CONN! L i'AllNEsroar. Motaoy FullIlc 11a""~_ ... DaupIin ColIlIIy "., CDmmilll4n ExpiI8l /Irq 22. lIClO3 ~:;' l .. , ." .'~ .,.,,", ~~ ....;1." + .i~ : Ii' ;&; .. :t! := f :GI ::5 'c ,0 ... ! 'a. :E o jU , :.~_ 1 andfor 2 for additional services. '_:'. rnP.me items 3. 4a, and.4b. _ Print,',yaur name ,and .address on the reverse of this form so that we can, return this card,:tcryou. ~~;y~,.:;:; '," . -Att~ this 'form to the-frOnt of the mallpie~, or on the back 11 space does not penWt." , . -Write-Return Receipt Requested- on the mail piece below the article number. .Thdl~tum Receipt Will show to whom the article was delivered~'and;tt\e date deliVered. ~--- tlI-~, I also wish to raceivelhe following 'setvlces(for an extra fee): !i 1. 0 Addressee's Address l 2, 0 Restricted Delivery Ul Consult postmaster ~ lee. 'f 4a. Article Number &! P160-940-499 c ~ " 1> II: <II C 'ii " ~ .e ~ ... Ii .c ... ~ertlfied 5. Received By: (Prinl Name) 4b. Service Type o Registered o Express Mall 0 Insured o Return Recelpffor Merchandise 0 COD 7. Date 01 Delivery 8, Addressee's Addr9S$ (Only il,aquested aildfee is paid) ~ ! ~i s:n~i (A~efS AD,!,,') , :' ~ i .~'UL, .' . ; .j' '. ~ - PSFeFlll . :1, Dece er 1994 !i l\ II!, ipt --~--,~~_...._~ P lbD 940 If'!'! I US Postal Service . Receipt for~rtif{ed Mail No Insurance. Covera:!!Je Provided. o 0/ t '" '" '" - on use or International Mail (See reversel Sent to I .T.., "..~-- Street ~ ~lInb.r 235 Indian Creek Dr. P~ice,~I.,&.zIPC~. ec anlCS urg, PA 17 Postage $ S-S Certified Fee f.'1tJ Special Delivery Fee Restricted Delivery Fee.. Retum Receipt Showing to J.?5 Whom & Date Deliv.ered Relum Receipt Showing to~, Date, & Addressee's Addl'fl51& TOTAL Postage & Fees $ r.p<e; POSbn8Jk or Date 2/4/2000 55 ~ c o CD ... E 6 IL (J) 0.. ,iiM ~ ~ ~iIr ""O~",,-,,_~ ..J!!r - '~,w~iiIIlila~ ill ..",- .>"~~.~~ ...4oll... ~. ~ 0 0 .~ <'~ ~') "-) ,., Ii; :::~ ::J ..<- ;".) ',,-n C::J '~,Cj , ~ '_.-I ~ ,j:,;. f;~~ -" -- '" - ~ :f; >"2 9.' -:;,-;.(") ~ csrn =< 1:- ;g (7\ -< I A ,.1 \ I. ~ ~~.u"""" ---LlllillUj!:~j XIN LIN HUANG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000-632 CIVIL TERM JUYING HUANG, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE AFFIDAVIT OF CONSENT Personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, XIN LIN HUANG, who, being duly sworn according to law deposes and says that: 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 3, 2000. 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. after service decree. I consent to the entry of a final decree of divorce of notice of intention to request entry of the 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. Section 4904 relating to unsworn falsification to authorities. Date: G /t /OD ~ XIN LIN HUANG ~?~ Sworn to and subscribed bef e me this lor day of , 2000. NOTARIAl. SEAl. SUZANNE M. DEOERER. Nelary Pubflc Camp till. C\IIllbelland COUnty My ComnlIIalon Expires Aug. 20. 2001 ii~ .. -1oIiIIIIll ~. .'._~"'iIil"".!l;ilar~ ".. 1fj1lP'~~' (') C ? -oU} fpln- :<- -,-) <c-~ f?fj -2;: ~" ~lJ ~r-' ~ :::;: ". "" w. ~ c- <y, o c::> S '.-.~ :;::e: I"') -'rl ., ,-'.) (:::J 1fT? . ~];::J :~-~(S 7""i\ r~Ji~ :;:;! ;;~ '""" ~ -< . ." ~~ -- "- ~ ~,! XIN LIN HUANG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : vs. NO. 2000-632 CIVIL TERM JUYING HUANG, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE WAIVER OF NOTICE OF INTENT TO REQUEST ENTRY OF 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. division of them before I understand that I may lose rights concerning property, lawyer's fees or expenses if I do not a divorce is granted. alimony, claim 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. Section 4904 related to unsworn falsification to authorities. DATED: ~/J /CfD ~~ XIN LIN HUANG r.....; ..c.."",,' ~ "~Illilli!illiI!lOC!llW~>'''~l- p-~~~ ~"= 'I I (') <:::) <:) C C;::J '. ~ t 1'J D~~ '- rllr~"', ;~: "'q <::::. j==::'; ~5~~; t'-J H,~ '-<."~ 0 ~c; .:t'1I. >-. '~~if5 ?Q -- ,'~CJ s:9 ~~~I in .PC' 2: ..,.. ~ ::< :D (]) -< b~__.. "O"""-"~~~~., XIN LIN HUANG, IN THE COURT OF COMMON PLEAS Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. . NO. 2000-632 CIVIL TERM . JUYING HUANG, CIVIL ACTION - LAW Defendant ACTION IN DIVORCE AFFIDAVIT I, XIN LIN HUANG, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4909 relating to unsworn falsification to authorities. ~/? ~~" /) XIN LIN HUANG Sworn to and subscribed bewre me this Ii5\- day o~ ' 2000 . Yl/?/I/ & jj~uu N ry Pu ~c NOTARIAL SEAl SUZANNE M. DEoeRER. Nelary Public Camp HUI. CIImbei1and County My COmmlaslon Expires Aug, 20. 2001 ~i.iiIi; "\ill .. ~~fi~-~' ,. "^ ,_J o. ~ '" ~" (') <:::> c: (:;:,), 9 ~~:. rif fEl S , '..- ~:{: -.. i;;' ,'-"- -q 03 !;~ ,'\;) - --, ;--T~ :-<-~-- 0 :::io "-13 :;c::: -' .~' (1,. :::r:;;(] ~ ~.~. '"-'" -,'-.. 5~ ZC' ~ ;E;:) c: '?? Z C'jfll ::< ~ ~ O"t :fj -< i --=- "~ .""~ ~-'iIlot'. XIN LIN HUANG, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . vs. : NO. 2000-632 CIVIL TERM : JUYING HUANG, : CIVIL ACTION - LAW Defendant . ACTION IN DIVORCE . AFFIDAVIT OF CONSENT Personally appeared before me, a Notary Public in and for the aforesaid Commonwealth and County, JUYING HUANG, who, being duly sworn according to law deposes and says that: 1. A Complaint in Divorce under Section 330l(c) of the Divorce Code was filed on February 3, 2000. 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. after service decree. I consent to the entry of a final decree of divorce of notice of intention to request entry of the 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. Section 4904 relating to unsworn falsification to authorities. Date: )' I2-Y~ ~ ~ -;r l/l-;0? .' JUYING ~ Sworn to and subscribed before me this ~3 day /1// ~( , 2000~ U1Jut;tu f5(~J^~ Notary Public NOTARIALSOC" Chrlstle L. Underkoffler, Notary Public Camp Hili, Cumberland County My Commission ~plres June 24, 2002 . _, __ .'r~._'''" .. ..'. '~""""",, .........1. will.. .. "'~-"""'_iI ~ '-~ '~---\llIlIIII!IllMI-' ,~ B _~ ,~- , ~ [-, I () 0 0 C- O ~ "'" ~ -o~ 1--7::::: mG '~"I. .. 'Ti ::? !.J... """- ., I-'~ -._C: 655:-- r-..,) Gl a ~J ;$~e_ (S :':~"--' """ --'-rl SC) ~?:~ 5;0 9? S;;; ~ .c, c- :;f (J', "<: . ~~ -~~, XIN LIN HUANG, Plaintiff . . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2000-632 CIVIL TERM JUYING HUANG, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE WAIVER OF NOTICE OF INTENT TO REQUEST ENTRY OF 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. division of them before I understand that I may lose rights concerning alimony, property, lawyer's fees or expenses if I do not claim 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. Section 4904 related to unsworn falsification to authorities. DATED:!J bs/oo 3lA&)-~ JUYING H G' iiM ' .. i:>dJil_ ~-""'___~Iilillilllil. -~ " r" $ -o-'-~ n, 0/ ~[P "c( !:;j",.,"-" ~~2:. ",0 ;ft() ~(-.., -r;:: :;j o o ,S, ~.~ """'- .0 i7 ---1 > J;:" -:".. -:... :;J.i _,!;i'P:,J j}~} ~7:i .:1:; &,,- 1"\.1 C;:; OJ '. ~ (7) I '-"~W\1;< . . XIN LIN HUANG, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . . vs. NO. 2000-632 CIVIL TERM JUYING HUANG, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE AFFIDAVIT I, JUYING HUANG, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. 2. I understand that the Court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me upon request. 3. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the Court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4909 relating to unsworn falsification to authorities. -' ~ VvV. k1- JUYt~G . Sworn to and subscribed befoll~me this ::?3 day of 7(7tUj; , 2000. (!IVadl1 f;Y ~dp;)jrl~ Notary Public NOTARIAL SEAL Christle L. Underkoffler, Notary Publtc Camp Hili, Cumbertand COunty My commission Expires June 24, 2002 ..' ~- .' -.....~_. " ~~---".'\t ~""lllliltiiil_ kliiin . ~ ~-~. " ~ , I . 0 Q C, c: a --"1 ~, C._ ~". -OCt; c::: M1rT ~;=: 2:p ,r=; 2:: r-- N l:::J (/).;~~ a '.. , , I -<~ ',. r-e> '-.../ ~. t2: " zt::, .....L. ~ic~; -.,._1-'; r:? ;::.:.:;m Pc:' 'J -., ~ ~' '" ..-'---' :::u (,,"'l -< 0; ...;,',~ . 1Ii....i,,', . .... .... ~ XIN LIN HUANG, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2000-632 CIVIL TERM . . JUYING HUANG, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Plaintiff's Social Security #087-72-0150 Defendant's Social Security #131-76-6360 DATED: 6/5/00 ~ J,/( HERSCHEL LOCK, ESQUIRE Attorney for Plaintiff 3107 North Front Street Harrisburg, PA 17110 (717) 238-6661 Supreme Court No. 22691 jiiliml"-- , ~~, -. ,,~ > ilI.IllJ2i.1 ~"ilIriIif'-'- .~~.~'~;:.b;"\7'IIIiliIDI'I!:IlIi~~H~,iii~ .1 . "'< " .~ .,. (') (,:) () c:: C;:) ;;:~. Ti ""DcrJ '~\ rllp1 ~~.. .,,~ i'0 (:..) :s:C' J;...'" ~.- ~-,::) 2~r-', ., 58 -. ~;:?0 co ;,-) rn Z --I ::;! c:- ~r~ en _D -< ,,~ ......~ ~ "" _ ~ L.._' '~~IIl!tql)lL'j , XIN LIN HUANG, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . . vs. . . NO. 2000-632 CIVIL TERM JUYING HUANG, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE ORDER AND NOW, this !2.$ day of vQv"l~ lie~tcmber, 2000 upon review of the within Petition IT IS HEREBY ORDERED AND DECREED that the Decree in Divorce entered in the above referenced matter on June 27, 2000 be confirmed as a final Decree in Divorce. -x"'7, / // /' .' I/' . ORDER J. I II _"""'~!!"'''''---.~" - , "~"""""i'"""",,~~IlI'i\1llll!llllm> ~~ l ,-' F~': - ~~,~~~,J~~':~~~~~~f:i:JT NiY "C) '\If' ? 8 I ", r~ ,,,: i_, V". ,. ~ p;r, ?: S I . I_ 1_. CUI\l"...":',..:.. ':."0 [)JUNTY , '111_''- \.- .. , . . PE(\INSYLVil"Nlf\ ~ .y.' ;'1";"7-- ,I __ --i' 1. ~_~""'F'~~~_~ "'> lJ\I!~~'r<~m:r.l~1Il1"'FP""'''''''~''''i'2''''Nf'!f''iI'l''~~~l:!Il!lilill~~IUIl!i~~~ - - os - ~ ~c 1i:!:J.ili~.'c XIN LIN HUANG, Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA . . vs. : NO. 2000-632 CIVIL TERM . . JUYING HUANG, Defendant CIVIL ACTION - LAW ACTION IN DIVORCE PETITION FOR CONFIRMATION OF FINAL DECREE IN DIVORCE AND NOW, comes the Plaintiff XIN LIN HUANG, by his attorney, Herschel Lock, and Defendant Juying Huang, Pro Se, and files their Petition as follows: 1. Plaintiff Xin Lin Huang is an adult individual residing at 6002 Robert Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant Juying Huang is an adult individual residing at 235 Indian Creek Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. February 3, 2000, Plaintiff filed a divorce action under Section 3301(c) of the Divorce Code against Defendant, this to the above term and number. 4. As a result of said action, a Decree in Divorce was issued on June 27, 2000. (See Exhibit "A" attached hereto) 5. Because both Plaintiff and Defendant were born in China and may wish to remarry there, a problem has apparently arisen whereby China's bureaucratic interpretation of the Cumberland County, Pennsylvania, United States of America Decree in Divorce entered herein has caused its government and its officials to be uncertain that the Decree in Divorce entered in the case is ,-~ """""'"" " "~ <>.....>M~' actually a final divorce decree. 6. Resultingly, Plaintiff wishes to make it clear to the Chinese government that the Decree in Divorce entered herein on June 27, 2000, is in fact a final divorce decree. WHEREFORE, Plaintiff prays your Honorable Court to enter an Order confirming that the Decree in Divorce entered herein on June 27, 2000, is a final Decree in Divorce and fully breaks the bonds of matrimony between Plaintiff xin Lin Huang and Defendant Juying Huang. Respectfully submitted, DATED: ~J:lIO() I ~ Jet( HERSCHEL LOCK, ESQUIRE ATTORNEY FOR PLAINTIFF 3107 North Front Street Harrisburg, PA 17110 (717) 238-6661 '"_""""""''''"L....-.''=~'_~ - -. rl"", w, .:.-..<,~... ~ "~"""""'~"-, '"'~!1li:11i@1,iIlIIi!Ii"..~ "., " .:+>" '.::.;.' '-:+;'.:" .=+>: ".:::+;.:: '.::..,.;." '::+:;.'~>::<<~ :".::~'.:' ~::.~.::..,::.::;;:::.::.:.:' ,"~::.;',: ','::,€:o :>::c.:::--::+:.: "'.::.;..: ::-.::.:. :.-::<<',. {.:;'::'~;::':,~.::~~)("':{::~::€~:1::~::.::~~::~::.::~:::::~::.;~,:X.::;.:::.::.X>::.::;;:);. ~ (~ ------------- -. . il ~.;.~ .' ~.~ :,~,: ~ ~ ~ $1 ~I ~I ~.';Ii '.' ~I ~I ~( ~~ ':'/ ~i . , ~I ,.) :1 ~I vI ~( '.'\ ~( '.'( , ~\ ~' -"J ~i '.'! ~i :::( ~I '.'\ ~) ~.' i ~( '.'1 ~I ~~ ~l ~ ..' ~ ~ ~ ~ ~ ;.~ ~ :.' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ~ ~l ~ i ~.~ t~ I': I~. .. , ~rf: 1 ~.~ i. )~ ) " / ~.~ ~~ , . II~ .. , . ~ $ !~ ) . ;~ ,. ;~ . , \~ i;., :$ :~ ',~ '" ,~ ;~ :* ~ ".' ~ ;~ ;~ I.', :~ ;~ ..., ~ .~ ~ :~ , , ;~ :~ @ !s/Edgar.E,Eayley J . ~ : ~tt~st:~ . . ~ ~ Prothonotary I ~ ~ ,~ ~ CERTIFIED COPY ISSUED JUNE 28, 2000 , i! ~~~-~.~~.~_.~.~._~.~.~-----,~.~:~~:_~~,~~~ XIN LIN HUANG 1\ (). ..z..o.~,?~,~.3.,2 )((X . . Yel'.;::lLS JUYING HUANG DECREE IN DIVORCE AND NOW, ..' ;J!lP!", 27.., .,."...20.00, 'JX9t"..,., it is ordered and decreed that ... and,.,..,.."..... . , . X.in. Li,n . Hua.ng. . . . . . . . . . . . , . , . . , . Juying Huang . ., plaintiff, defE:mdrmt, me divorced from the bonds of matrimony. The court retains iurisdiction of the following clnims which hove been roised of record in this action for which a final order hos not yet been entered; None The attached Matrimonial Settlement Agreement is incorporated ...............,.............. '.,...",................, .............. By The Court: EXHIBIT "A" ~u...-..~ ~ ,., , ~ .~.~"~~c VERIFICATION I verify that the statements made in the foregoing Petition are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. DATED: 8/28/00 ~....~y~ XIN LIN HUANG