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Home My WebLink About07-0716TAM VAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. No. Civil Term LAN T. NGUYEN, : ACTION IN DIVORCE Defendant 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 marriage 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 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 TAM VAN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. No. Civil Term LAN T. NGUYEN, ACTION IN DIVORCE Defendant COMPLAINT IN DIVORCE 1. Plaintiff is Tam Van, a competent adult individual, who has resided at 144 N. Spring Garden St., Carlisle, Cumberland County, Pennsylvania, 17013, since 2000. 2. Defendant is Lan T. Nguyen, a competent adult individual, who also resides at 144 N. Spring Garden St, Carlisle, Pa. 17013. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on November 21, 2003 in Cumberland County, Pennshlvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 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 unworn falsification to authorities. Tam Van, Plaintiff Respectfully submitted, Date: 2 ;d'ane Adams, Esquire garlis 0.79465 uth Pitt Street le, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ?i /V v 7 1 c tr? 0 a C? c_ N c';:> 1 Cb -n C3"S Cr ri nz rte'.-- r? -r, ?7 t"tai TAM VAN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 0) - ?? Civil Term LAN T. NGUYEN, ACTION IN DIVORCE Defendant AFFIDAVIT OF SERVICE AND NOW, this February 13, 2007, I, Jane Adams, Esquire, hereby certify that on February 9, 2007, a certified true copy of the NOTICE TO DEFEND AND DIVORCE COMPLAINT was served upon the Defendant, via certified mail, restricted delivery, return receipt requested at the following address: Lan T. Nguyen 144 N. Spring Garden St. • Complete Items 1, 2, and 3. Also complete Carlisle, Pa. 17013 Item 4 if Restricted Delivery is desired. DEFENDANT • Print your name and address on the reverse so tad we can return the card to you. ¦ Attach this card to the back of the mailpiece, or an the front if space permits. 1. Article Addressed to: A. Signature 13 X _ p ^ ? Addmw B. Received by (Printed Name)_ ` C. Date of D*4wy D. Is delivery address dHferent from item 1? ` U '? If YES, enter delivery address below: `??'+,b LAN T TT G'J? T FEB 0 9 2007 144 'N TORING GARD7N G T CARLISLa ?A 17013 3. Service TV& Md ? EWess Mail 13 Roo' tend ? Return Receipt for Mrarchendbs ? khwrnd Mai O C.O.D. 4. Restricted DelwrtR XXm reel 2. Article Number 7006 2760 0002 7405 8839 maraca from service iabe_ P3 Forth 3811, February 2004 Domestic Return Receipt 102595.624A-IMO Respect ly Sub ane Adams, Esquire o.79465 64 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF C7 CO TAM VAN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : No. 07 - 716 Civil Term LAN T. NGUYEN, : ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on February 6, 2007. 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 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 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: C3- Ta Va , Plaintiff . WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND 43301(d) 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.C.S. §4904 relating to unsworn falsification to authorities. Date: j j /7 771 j Tam an, aintiff vr, ?' , 7 `14 . u TAM VAN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 07 - 716 Civil Term LAN T. NGUYEN, ACTION IN DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on February 6, 2007. 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 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 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: / 0 g 7t L( 1 c7-' Lan T. Nguyen, Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 63301(c) AND §3301(d) OF THE DIVORCE CODE 1. 1 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: / Lan T. Nguyen, Defendant ?S ?3 ?::: "'+? a?? _?' t', _ fi?._ t?yd _? __ ?.?? .} .._ ?? r ..,.5 •• ?} M. TAM VAN, Plaintiff vs. LAN T. NGUYEN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 07 - 716 Civil Term ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Please accept this request to 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: Served certified mail, restricted delivery, received by Defendant on February 9 2007. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: January 5, 2009. By Defendant: January 5, 2009. 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: January 7, 2009. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: January 7, 2009. Date: , 69 Ja Adams, EsTuire I. No. 79465 South St. arlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff ra ? ?? -s? c- Fn -4 f? _ 3 41 .x.« l f ..... .? A } TAM VAN, Plaintiff V. LAN T. NGUYEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07 - 716 Civil Term DIVORCE DECREE AND NOW, ( o;d i , it is ordered and decreed that TAM VAN, Plain ' plaintiff, and LAN T. NGUYEN, Defendant bonds of matrimony. defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE.', Prothonotary Attest: J. ?4