HomeMy WebLinkAbout01-03806SUN CHA STEINER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. QtU' LC
KENNETH R. STEINER, CIVIL ACTION - LAW
Defendant 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 of other rights important to you, including the 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 at the Office of the Prothonotary.
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, PA 17013
717-249-3166
SUN CHA STEINER, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. NO. CJ- 3ko(,
KENNETH R. STEINER, CIVIL ACTION -LAW
Defendant IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the Plaintiff, Sun Cha Steiner, by and through her attorney,
Charles Rector, Esquire, and respectfully represents as follows:
1. Plaintiff is Sun Cha Steiner (SS# 213-64-1288), an adult individual,
currently residing at 1104 Floribunda Lane, Mechanicsburg, Cumberland County,
Pennsylvania, 17055.
2. Defendant is Kenneth R. Steiner (SS# 191-40-8321), an adult individual,
currently residing at 1104 Floribunda Lane, Mechanicsburg, Cumberland County,
Pennsylvania, 17055.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth
of Pennsylvania for a period of six months (6) immediately preceding the filing of the
Complaint.
4. Plaintiff and Defendant were married on March 15, 1968, in Seoul, Korea.
5. There have been no prior actions for divorce or for annulment between
the parties.
6. The Plaintiff and Defendant are both citizens of the United States of
America.
Count I - Divorce
7. The allegations of Paragraphs 1 through 6 are incorporated herein by
reference and made a part hereof.
8. This action is not brought through collusion between the Plaintiff and
Defendant, but in sincerity and truth for the reasons set forth within.
9. The marriage is irretrievably broken, and the parties are proceeding
under Section 3301(c) of the Divorce Code. In the alternative, Defendant has offered
such indignities to Plaintiff, the innocent and injured spouse, as to render her condition
intolerable and her life burdensome.
10. 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.
WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce decree
dissolving the marriage between Plaintiff and Defendant.
Date: t l5 ?l
RESPECTFULLY SUBMITTED,
Ch`8rfes Rector, Vsku
1104 Fernwood ven
Camp Hill, PA 17011
(717) 761-8101
Ste. 203
I verify that the statements made herein 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.
Ac
Sun Cha Steiner
Date: toS/? <
SUN CHA STEINER,
Plaintiff
V.
KENNETH R. STEINER,
Defendant
¦ Print yoilrname and address on the reverse
so that we can return the card to you.
¦ Attach this card to the back of the mailplece,
or on the from if space permits.
1. Article Addressed to:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-3806 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
PROOF OF SERVI
C.
Date
D. 11 delivery address different from item 1? ? Yes
If YES, enter delivery address below: ?'No
rvice Type
rtified Mail ? Express Mail v
Registered ? Return Receipt for Merchandise C
? Insured Mail ? C.O.D.
4. Restricted Delivery? (Extra Fee) ? Yes ee<
2. Article Number (Cop from label) C
PS Form X811; J 1 bam?stif RetclmtAeee?pt - . _ _.. . _ 142595-004,0110 I
RESPECTFULLY SUWAITTED
Z 353 129 592
US Postal Service
Receipt for Certified Mail
No Insurance Coverage Provided.
Uo nd use for International Mail See reverse
Semen
streel3 D
ZIP
Posge
a c
$, W
Certified Fee
49" Delivery Fee
Restricted Delivery Fee
Astum Receipt Shred to
Vftm
& Delia Delivered
.
6
` '
0''
;
,_ IlecdgSYnwigbWhom,
RAae,&AddraaWsA&k=
TWAL Postage & Fees Is 2o?
Poeanark"Date
q0)
0-A _ ll.,--?, . L? _6l
Date:
Charles Rector, Esquire
1104 Fernwood Avenue, Ste. 203
Camp Hill, PA 17011-6912
(717) 761-8101
Attorney for Plaintiff
V-
w
In The Court of Common Pleas of
Cumberland County, Pennsylvania
STEINER SUN CHA
VS
STEINER KENNETH R
File No. 2001-03806
STATEMENT OF INTENTION TO PROCEED
To the Court:
Sun Cha Stainer intends to proceed with the above captioned matter.
Date: 9 IISA
Attorney for P1 i n-Vi
c,
`
r_. o -
?:_ ?? ?
?)
c_ e?
e-[ n ° a
cs°;
Curtis R. Long
Prothonotary
office of the vrotbonotarp
Cumberlaub Cuuntp
Renee K. Simpson
Deputy Prothonotary
John E. Slike
Solicitor
e)/ " 3 g ac CIVIL TERM
ORDER OF TERMINATION OF COURT CASES
AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF
INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE
CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA
R C P 230.2.
BY THE COURT,
CURTIS R. LONG
PROTHONOTARY
One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573