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HomeMy WebLinkAbout03-1864JEEYEON HAN, Vo BRIAN Y. SHIN, Plaintiff · Defendant · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS TO: Brian Y. Shin 1749 Weatherbum Drive New Cumberland, PA 17070 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. When the ground for 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 at the Cumberland County Courthouse, One 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 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, Pennsylvania 17013-3387 PHONE: (717) 249-3166 Document #: 267154.1 JEEYEON HAN, Plaintiff Vo BRIAN Y. SHIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN DIVORCE COMPLAINT IN DIVORCE 1. The Plaimiff, Jeeyeon Han, is an adult individual currently residing at an undisclosed location. She can be reached by her attorney's mailing address at P.O. Box 5300, Harrisburg, Pennsylvania, 17110-0300· 2. The Defendant, Brian Y. Shin, is an adult individual currently residing at 1749 Weatherburn Drive, New Cumberland, Cumberland County, Pennsylvania, 17070. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaim. 4. Plaintiff and Defendant were married on January 1, 2002, in Hershey, Dauphin County, Pennsylvania. 5. States or its allies within the provision of the Congress of 1940 and its amendments. 6. Plaintiff's Social Security Number is 610-74-7210 and Defendant's Social Security Number is 566-59-2179. 7. There have been no prior actions of divorce or for annulment between the parties. 8. Plaintiff has been advised that counseling is available, and that Plaimiff may have the right to request that the Court require the parties to participate in counseling. Neither Plaimiff nor Defendant is in the military or naval service of the United Soldiers' and Sailors' Civil Relief Act of the Document #: 267154.1 There were no children bom of this marriage. 10. reference. 11. 12. 13. Defendant. COUNT I - DIVORCE The averments of paragraphs 1 through 9 hereof are incorporated herein by The marriage is irretrievably broken. The parties have been living separate and apart since January 17, 2003. Plaintiff requests the Court to enter a decree of divorce, divorcing Plaintiff and 14. reference. 15. COUNT II - EQUITABLE DISTRIBUTION The averments of paragraphs 1 through 13 hereof are incorporated herein by During the marriage the parties acquired marital property, assets, and debts which Plaintiff requests the Court to equitably distribute and assign. 16. reference. 17. COUNT III - SUPPORT, ALIMONY~ AND ALIMONY PENDENTE LITE The averments of paragraphs 1 through 15 hereof arc incorporated herein by Plaintiff requires reasonable support and/or alimony pendente lite to adequately sustain herself within the standard of living established during the marriage and to properly and adequately maimain the within action for divorce. Document #: 267154.1 -2- WHEREFORE, Plaintiff requests that this Court enter a decree in divorce, enter an Order equitably distributing marital property, award Plaintiff support, alimony, and alimony pendente lite, and enter any such other Orders as are appropriate and just. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Andrew C. Spears, Esquire Attorney I.D. No. 87737 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Document 14:267154.1 -3- VERIFICATION I, Jeeyeon Han, hereby certify that the facts set forth in the foregoing Complaint in Divorce are tme and correct to the best of my knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. {}4904 relating to unsworn falsification to authorities. Date: Jeeyeon Han Document #: 267154.1 JEEYEON HAN, Vo BRIAN Y. SHIN, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S PETITION FOR ALIMONY PENDENTE LITE 1. Petitioner, Jeeyeon Hah, is the Plaintiff in the above referenced divorce action which was filed simultaneously with this Petition. 2. Petitioner included a Petition for Alimony Pendente Lite (APL) in the Complaint in Divorce when filed. 3. Petitioner requires reasonable support and/or APL to adequately sustain herself within the standard of living established during them marriage and to properly and adequately maintain the within action for divorce. Divorce. Petitioner seeks APL effective the date the claim was filed in the Complaint in Document #: 267157.1 .,CERTIFICATE OF SERVICE I, Andrew C. Spears, Esquire, of the law firm ofMetzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served a tree and exact copy of the Petition for Alimony Pendente Lite with reference to the foregoing action by First Class Mail, postage prepaid, this l.'] )]h .~lCy ~ day of . , ,2003, on the following: Brian Y Shin 1749 Weatherburn Drive New Cumberland, PA 17070 Andrew C.~pear~, Esquire Document #: 267157.1 JEEYEON HAN, Plaintiff/Petitioner VS. BRIAN Y. SHIN, Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2003-1864 CIVIL TERM IN DIVORCE PACSES # 713105443 ORDER OF COURT AND NOW, this day of, 2001, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shadday on June 2, 2003 at IO:30A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Mail copies on Petitioner 6-2-03 to: < Respondent Andrew Spears, Esquire · e~ ~ ..~ :' Date of Order: May 1, 2003 Shaatday, Conference Officer / YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AI~ REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 JEEYEON HAN, Vo BRIAN Y. SHIN, Plaintiff · Defendant · IN THE COURT OF cOMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW m - IN DIVORCE PLAINTIFF'S PETITION FOR ALIMONY PENDENTE LITE 1. Petitioner, Jeeyeon Han, is the Plaintiff in the above referenced divorce action which was filed simultaneously with this Petition· 2. Petitioner included a Petition for Alimony Pendente Lite (APL) in the Complaint in Divorce when filed. 3. Petitioner requires reasonable support and/or APL to adequately sustain herself within the standard of living established during them marriage and to properly and adequately maintain the within action for divorce· 4. Petitioner seeks APL effective the date the claim was filed in the Complaint in Divorce. Document #: 267157.1 WHEREFORE, Petitioner requests pendente lite in this matter. that this Court enter an Order awarding alimony METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Dated: By Andrew C. Spears, Esquire Attorney I.D. No. 87737 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Document #: 267157.1 VERIFICATION I, Jeeyeon Han, hereby certify that the facts set forth in the foregoing Petition for Alimony Pendeme Lite are tree and correct to the best of my knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities. Date: oL/'/ Iq /z-oo3 JeeyeonHan Document #: 267157.1 CERTIFICATE OF SERVICE I, Andrew C. Spears, Esquire, of the law firm of Metzger, Wickersham, Knauss & Erb, P.C., hereby certify that I served a tree and exact copy of the Petition for Alimony Pendente Lite with reference to the foregoing action by First Class Mail, postage prepaid, this iq day of CVCy, \, ,2003, on the following: Brian Y Shin 1749 Weatherbum Drive New Cumberland, PA 17070 Andrew pear-s, Esq"~re Document #: 26715 7.1 JEEYEON HAN, BRIAN Y. SHIN, Plaintiff · Defendant · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS TO: Brian Y. Shin 1749 Weatherbum Drive New Cumberland, PA 17070 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. When the ground for 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 at the Cumberland County Courthouse, One 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 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, Pennsylvania 17013-3387 PHONE: (717) 249-3166 Document #: 267154.1 JEEYEON HAN, Vo BRIAN Y. SHIN, Plaimiff · Defendant ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW - IN DIVORCE COMPLAINT IN DIVORCE 1. The Plaintiff, Jeeyeon Han, is an adult individual currently residing at an undisclosed location· She can be reached by her attorney's mailing address at P.O. Box 5300, Harrisburg, Pennsylvania, 17110-0300. 2. The Defendant, Brian Y. Shin, is an adult individual currently residing at 1749 Weatherbum Drive, New Cumberland, Cumberland County, Pennsylvania, 17070. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on January 1, 2002, in Hershey, Dauphin County, Pennsylvania. 5. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provision of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 6. Plaintiff's Social Security Number is 610-74-7210 and Defendant's Social Security Number is 566-59-2179. 7. There have been no prior actions of divorce or for annulment between the parties. 8. 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. Document #: 267154.1 There were no children bom of this marriage. 10. reference. 11. 12. 13. Defendant. COUNT I - DIVORCE The averments of paragraphs 1 through 9 hereof are incorporated herein by The marriage is irretrievably broken. The parties have been living separate and apart since January 17, 2003. Plaintiff requests the Court to enter a decree of divorce, divorcing Plaintiff and 14. reference. 15. COUNT II - EQUITABLE DISTRIBUTION The averments of paragraphs 1 through 13 hereof are incorporated herein by During the marriage the parties acquired marital property, assets, and debts which Plaintiff requests the Court to equitably distribute and assign. 16. reference. 17. COUNT III - SUPPORT~ ALIMONY~ AND ALIMONY PENDENTE LITE The averments of paragraphs 1 through 15 hereof are incorporated herein by Plaintiff requires reasonable support and/or alimony pendente lite to adequately sustain herself within the standard of living established during the marriage and to properly and adequately maintain the within action for divorce. Document #: 267154.1 -2- WHEREFORE, Plaintiff requests that this Court enter a decree in divorce, enter an Order equitably distributing marital property, award Plaintiff support, alimony, and alimony pendente lite, and enter any such other Orders as are appropriate and just. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. By Andrew C. Spears, Esquire Attorney I.D. No. 87737 P.O. Box 5300 Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff Document #: 267154.1 -3- VERIFICATION I, Jeeyeon Hah, hereby certify that the facts set forth in the foregoing Complaint in Divorce are true and correct to the best of my knowledge, information and belief, and that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom falsification to authorities. Date: Jeeyeon Han Document #: 267154. I In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION JEEYEON HAN ) Docket Number 03-1864 CIVIL Plaintiff ) vs. ) PACSES Case Number 713105443 BRIAN y. SHIN ) Defendant ) Other State ID Number ORDER OF COURT You, ~RIm~ y. SHIN plaintiff/defendant of 1749 WEATHERBURN DR, NEW CUMBERLAND, PA. 17070-2219-49 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N FdkNOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the JUNE 17, 2003 at i:30PM for a hearing. You are further required to bring to the hearing: ~W~ 1. a true copy of your most recent Federal Income Tax Return, including 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available to yogtn 5. information relating to professional licenses 6. other: Form CM-509 Service Type M Worker ID 21302 ~ v. SHIN PACSES Case Number: 713105443 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: 6-g~0% ~ e: 5 JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. 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 MAY GET LEGAL HELP: CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE pA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUMBER~U~D County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Service Type I4 Form CM-509 Worker ID 21302 In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION JEEYEON HAN ) Docket Number 03-1864 CIVIL Plaintiff ) vs. ) PACSES Case Number 713105443 BRIAN y. SI-IIN ) Defendant ) Other State ID Number ORDER OF COURT You, JEEYEON aaN plaintiff/defendant of C/O ANDREW SPEARS, ESQ, PO BOX 5300, HARRISBURG, PA. 17110-0300 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOblESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the JUNE 17, 2003 at l:30pM for a hearing. You are further required to bring to the hearing: 1. a tree copy of your most recent Federal Income Tax Return, including W-2d~ 2. your pay stubs for the preceding six (6) months, ~'~. 3. verification of child care expenses, and · proof of medical coverage which you may have, or may have available ~//yo~ ~ '~' 5. information relating to professional licenses 6. other: Service Type M Form CM-509 Worker ID 21302 1432Xl ¥. SHIN PACSES Case Number: 713105443 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: }-3 03 YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. 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 MAY GET LEGAL HELP: CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of CUIqBERId~f'q'D County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Service Type Iq Worker ID 21302 JEEYEON HAN, Plaintiff BRIAN Y. SHIN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-1864 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE I, Andrew C. Spears, Esquire, counsel for Plaintiff, Jeeyeon Han, in the above captioned action, hereby certify that a true and correct copy of the Complaint in Divorce was served upon John J. Connelly, Jr., Esquire, counsel for Defendant, Brian Y. Shin, on May 16, 2003. Attached hereto, marked as Exhibit "A", and incorporated herein by reference is the Acceptance of Service signed by John J. Connelly, Jr., Esquire for said service. METZGER, WICKERSHAM, KNAUSS & ERB, P.C. Dated: By AndrQev~ . S~'~p e ars, E' E~ss quire~ Attorney I.D. No. 87737 P.O. Box 5300 3211 North Front Street Harrisburg, PA 17110-0300 (717) 238-8187 Attorneys for Plaintiff 282074-1 JEEYEON HAN, Plaintiff V. BRIAN Y. SHIN, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 03-1864 CIVIL TERM IN DIVORCE ACCEPTANCE OF SERVICE I, John J. Connelly, Jr., Esquire, counsel for Defendant Brian Y. Shin, hereby certify that I am authorized to accept service of the Complaim in Divorce on behalf of my client and do so this By: ~ [ J~l~ 'J.C o~~ x,-Jadn~, Dietterick lry 134 Sipe Avenue Hummelstown, PA 17036 (717) 533-3280 Attorney for Defendant 280941-1 JEEYEON HAN Plaintiff BRIAN Y. SHIN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-1864 CIVIL TERM : : CIVIL ACTION - LAW : IN DIVORCE ENTRY OF APPEARANCE Kindly enter my appearance on behalf of plaintiff, Jeeyeon Han, in the above- captioned matter. Date: June 16, 2003 Respectfully submitted, TURNER AND O'CONNELL 4415 North Front Street Harrisburg, PA 17110 (717) 232-4551 JEEYEON HAN, Plaintiff VS. BRIAN Y. SH1N, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 03-1864 CIVIL TERM CIV1L ACTION - LAW IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please mark the above captioned action "discontinued." Date: Jtme 16, 2003 Timothy, J. O'Connell, Esquire TURNER AND O'CONNELL 4415 North Front Street Harrisburg, PA 17110 (717) 232-4551 Attorney for plaintiff In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION JEEYEON H3AxI ) Docket Number Plaintiff ) vs. ) PACSES Case Number BRIAIg Y. SHIN ) Defendant ) Other State ID Number 03-1864 CIVIL 713105443 ORDER AND NOW, to wit on this 8TH DAY OF AUGUST, 2003 IT IS HEREBY ORDERED that the C) Complaint for Support or C) Petition to Modify or (~) Other REQUEST FOR APL CONFERENCE filed on APRIL 23, 12003 in the above captioned matter is dismissed without prejudice due to: THE DIVORCE COMPLAINT BEING WITHDRAWN. C) The Complaim or Petition may be reinstated upon written application of the plaintiff petitioner. BY THE COURT: JUDGE Form OE-506 Service Type M Worker ID 21005