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Home My WebLink About01-04647~' [N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. HUYNH MAI THAO ~.._ ,:;' VERSUS PHAN THANH CUONG N O. 4647 2001 DECREE 1N DIVORCE AND NOW ,J'~/-~„~,~ 2001 ~~ , IT IS ORDERED AND DECREED THAT HUYNHMAITHAO AND pHAN~ T~NH CUONG ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAINTIFF, ,DEFENDANT, 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; BY THE COURT: // ATTE ,J, PROTHONOTARY ;~- .., .~ HUYN13 MAI THAO, v. PHAN THANH CUONG To the Prothonotary: COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. Ol- 4647 Civil Term CIVIL ACTION-LAW Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD 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 (d) of the Divorce Code. 2. Date and manner of service of the complaint: Mailed complaint; received signed Acknowledgment and Waiver of Service from Defendant; Filed with Prothonotary on August 14, 2001 3. (Complete either paragraph (a) or (b) (a) Date of execution of the affidavit of consent required by § 3301 (c) of the Divorce Code: by plaintiff by defendant (b)(1) Date of execution of the affidavit required by § 3301(d) of the Divorce Code: August 28, 2001; (2) Date of filing and service of the plaintiff's affidavit upon the respondent: August 28, 2001 4. Related claims pending: None 5. Complete either (a) or (b) (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiff s Waiver of Notice was filed with the Prothonotary: A~ust 29.2001 (c) Date Defendant's Waiver of Notice was filed with the Prothonotary: August 29.2001 Respectfully submitted, 1,~,~k9..~.s~ -~~.,..,~- Michael J. Kane Reg. No. 46215 3300 Trindle Rd. Camp Hill, PA 17011 ~] (717)214-3700 - 708'-0'70`7 Attorney for Plaintiff t'} r~a r- ~_ i ___ x::' i i .,7 T7 i : - __ Z.F -C ~: t.::i ~ ~. _ ''°C'' _ _ . C Ci .. f -G _. _ ~avsmuti ._ .. _,.,, ~ , . 7d ~~~~ . HUYNH MAI THAO, v. PHAN THANH CUONG COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. Ol- 4647 Civil Term CIVIL ACTION-LAW Defendant IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twerny days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. The parties to this action sepazated on ~PE~~r ~ 19~~ and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein aze made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsifications to authorities. Date: ~ I ~( Plaintiff / n __. ~- ,.~ = r i7' -• ~,j _ -- _, ~ i ~~ , <:. r=C. = ~ - -- , r` ' c:. =1 ._, .. HUYNH MAI T'HAO, COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. PHAN TIIANH CUONG Defendant NO. Ol- 4647 Civil Term CIVIL ACTION-LAW IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301 (d) OF THE DIVORCE CODE 1. The parties to this action separated on ~~i» O E v ~j 9~ and have continued to live separate and apart for a period of at least two yeazs. 2. The mamage is irretrievably broken. 3. 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. I verify that the statements made in this affidavit aze true and correct. I understand that false statements herein aze made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsifications to authorities. Date: oQ~ (j / / Defendant <~ ~.: c ` c ~._ ~~ ` ~~ ~°. rr,:- c.~ ~,~ , __ ~ , `-;° c;+~ i ~ c;. ~-J Sl,' ~.J ..-- - _.a __~ -< -- ~ ..- -~ .. na~w~w~4sacpaxaxru.. ~I~`~ HUYNH MAI THAO, COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. PHAN THANH CUONG Defendant NO. Ol- 4647 Civil Term CTVII. ACTION-LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) AND § 3301(d) OF THE DIVORCE CODE. 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not he 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 falsifications to authorities. Date: ~ ~ ~ ~ ~ D '~ Plaintiff / HUYNH MAI THAO, COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. PHAN TIIANH CUONG NO. Ol- 4647 Civil Terns CIVIL ACTION-LAW Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) AND § 3301(d) OF THE DIVORCE CODE. 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyers 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 aze made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsifications to authorities. Date: 43 oQg D ~ ~ ~~ / Defe ant ~ ~, r~ - ' .~ •. _,~ _ ry L~s,_- l U; I -~'_ i r __ _ , C l "_ x~ -~ .i=" -< F~ HUYNH MAI THAO, COURT OF COMMON PLEAS Plaintiff' CUMBERLAND COUNTY, PENNSYLVANIA v. NO. Ol- y (®4~ Civil Term CIVIL ACTION-LAW PHAN THANH CUONG Defendant IN DIVORCE NOTICE TO DEFENDANT AND CLAIM OF 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 maybe entered against you by the Court. A judgment may also be entered against you for any 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's office at the Cumberland Coumy Courthouse, 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 MAX LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE TffiS PAPER TO YOUR LAWYER AT ONCE. II! YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUR WHERE YOU CAN GET LEGAL HELP. Office of the Court Administrator Cumberland County Courthouse, 4th Floor Carlisle, PA 17013 (717) 240-6200 The Court of Common Pteas of Cumberland Cou~}+ 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 coact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Michael 7. Kane Reg. No. 46215 Kane and Mackin, LLP 3300 Trindle Rd. Camp Hill, PA 17011 (717)214-3700 Attorney for Plaintiff HUYNH MAI THAO, COURT OF COMMON PLEAS Plaintiff' CUMBERLAND COUNTY, PENNSYLVANIA v. NO. Ol- ~(p ~7 Civit Term CIVIL ACTION-LAW PHAN THANH CUONG Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) AND 3301(D) OF THE DIVORCE CODE COMES NOW, Huynh Mai Thao, through her attorney, Michael J. Kane, Esquire, and avers as follows: COUNT ONE -DIVORCE 1. Plaintiff, Huynh Mai Thao is an adult individual, whose current address is 120 Wesley Dr., Mechanicsburg, Cumberland County Pennsylvania 17055. 2. Defendant is Phan Thanh Cuong, who resides at 33 Honeysuckle Dr., Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married in June, 1993 in VietNam 5. There have been no prior actions of divorce filed in this matter. 6. Neither Plaintiff nor Defendant is a member of the Armed Forces of the United States. Z The marriage is irretrievably broken and the parties are proceeding under Section 3301 (c) and 3301 (d) of the Divorce Code. 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. VJF~REFORE, Plaintiff requests the court enter a decree of divorce. ~R~es1pectfully submitted, VV~~ Michael J. Kane Reg. o. 46215 Kane and Mackin, LLP 3300 Trindle Rd. Camp Hill, PA 17011 (717)214-3700 Attorney for Plaintiff VERIFICATION I, Huynh Mai Thao, hereby verify that the information contained in the foregoing is true and correct to the best of my personal knowledge, information and belief. I further understand that false statements herein aze made subject to the penalties of 18 Pa.C.S. § 4909 relating to unsworn falsification to authorities c~ ~ ~ Date: ~7 f 'J I ~ ~ i l.~-f'' /;Il ~ L _...._ _.. ' Huynh Mai Thao _~ r P -~ ~LJ O _~ v ro (stta, ~'-' ~~ C? 7~ ~ s c... S5 LO ..~ ` , ,, `„ ~': T) ~,C-? ~ r+ =¢ ~~C 11>. P .~ HUYNH MAI THAO, Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. PHAN THANH CUONG Defendant NO. O1- 4647 Civil Term CIVII, ACTION-LAW IN DIVORCE PRAECIPE TO FILE RETURN OF SERVICE TO THE PROTHONOTARY: Please accept for filing this proof of service of the Complaint on the Defendant in the above- captioned case. Respectfully submitted, Michael J. Kane Reg-. No. 46215 Kane and Mackin, LLP 3300 Trindle Rd. Camp Hill, PA 17011 (717) 214-3700 Attorney for Plaintiff -~ h HiJl'NH MAI THAO, COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. Ol- 4647 Civil Term CIVIL ACTION-LAR' PHAN THANH CUONG . Defendant IN DIVORCE ACKNOWLEDGMENT AND ACCEPTANCE OF SERVICE I Phan Thanh Cuong acknowledge that I am the Defendant in the above-captioned case and that I have received a copy of the complaint by first class mail. Date: i ~ ~l By: _ : ,12_ Phan Thanh 'uong 33 Honeysuckle Dr. Mechanicsburg, PA 17055 r_ C ~' ~ cFr _~ - ~' _ C~) ~_, _'~1 ,.-- ._ J~ C~ V) ;~ i ~~ -{ a •