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HomeMy WebLinkAbout99-03250i? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. BIN SHENG LI .Plaintiff Versus ...UENG.MU. SAI ................ .................. ................ _............ .......... ...De f end ant.. . No . .... 29-.3.2.5.0 .................. III .......... II DECREE IN DIVORCE AND NOW, ... ? ..Z I„ , .. , . • , 19. L.?, it is ordered and decreed that . . . . . . Sin . Sheng.Li ................................ plaintiff, ........ and ............ Zhen&• Wei Bai ................................ . 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; i/ovua--- tg P a F ?x Aoy-ex#et... apausal_suppurt order shall- her?inafSer-be daeme. ex .................-or-d .......................... 4tP0AY'-1t :.....ny-aconam<_c_caaims remain Pending;........... s By Th'c Court Attest ttt :• Prothonotary 9W ?JG M:• •7K• •x• •?lt- tr,• •x..,?¢..?, w. :?: .?. .?. :?: e. .?? •.?. .?, x, s.....e •w. .?, tr.... ?. .+ ?. .. '.. ? y.. , ?a.s9 ??. c???„r??./ ???,?? ??? BIN SHENG LI, Plaintiff vs. ZHENG WEI BAI, Defendant THEPROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3250 CIVIL CIVIL ACTION-LAW 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 Section (X) 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of Service signed by Defendant on June 9, 1999. (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff: September 14, 1999 by Defendant: September 14, 1999 (b) (1) Date of execution of the Plaintiffs 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: No economic claims have been raised. 5. (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 of Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with Prothonotary: Filed contemporaneously herewith Date of Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: Filed contemporaneously herewith JOHN W/PU( CCT:L, JR. ESQ. 7 C z C. u- ?'i' W ii??W ru 1-' '^ r VI 's O U U ? J • `l V ~ M ? V m V r d F z z a w K w W y v a 0 O W D m P4 F G O w ? G W ^- [[?? Z W s, r G H ' u O • y H O ti F W F V 2 F d H - ] O w a w m cz d i E-4 U a U W w p £ d 0 V a H y V) PCI ' i A > ,?ee.. D z w H U J H w m N o6u.e•iblal.e• eb ra.,e CNIYb01 U]rletl!I6 `YJ6101Y16 :1Y 1 p BIN SHENG LI, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA Vs. : NO. 1 ? 30,0 CIVIL ACTION-LAW ZHENG WEI BAI, 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 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 Court Administrator, Cumberland County Courthouse, Hanover Street, Carlisle, PA. 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 j 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 L BIN SHENG LI, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Vs. ZHENG WEI BAI, Defendant : NO. 99. 2J YO et7-IL , : CIVIL ACTION-LAW : IN DIVORCE NOTICE OF AVAILABILITY OF COUNSELING TO THE WITHIN NAMED DEFENDANT: You have been named as the Defendant in a divorce proceeding filed in the Court of Common Pleas of Cumberland County. This notice is to advise you that in accordance with §3302(c) or (d) of the Divorce Code, you may request that the Court require you and your spouse to attend marriage counseling prior to a divorce decree being handed down by the court. A list of professional marriage counselors is available at the Cumberland County Court House, Carlisle, Cumberland County, Pennsylvania. 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 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 BIN SHENG LI, Plaintiff VS. ZHENG WEI BAI, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. V9- x.750 044,j '7 ." _ CIVIL ACTION-LAW IN DIVORCE COMPLAINT 1. The Plaintiff Bin Sheng Li is an adult individual whose residence is 4968 Erbs Bridge Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant Zheng Wei Bai is an adult individual whose residence is c/o Ling Shenchinc Tze Temple, 17102 NE 40`' Street, Redmond, Washington 98052. 3. The Plaintiff has been a bonafide resident in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 10, 1961. 5. There have been no prior actions of divorce or annulment between the parties. 6. The Plaintiff avers that there are no children of the parties under the age of 18. 7. The Plaintiff in this action is not a member of the Armed Forces. 8. The Plaintiff is a citizen of the United States. 9. The Plaintiff has been advised of the availability of marriage counseling and that he may have the right to request the court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the court require the parties to participate in counseling prior to a divorce decree being handed down by the court. 10. The Plaintiff avers the grounds on which the action is based is that the marriage is irretrievably broken. WHEREFORE, the Plaintiff requests the Court to enter a decree of divorce. Respectfully submitted, BY Jo W. Purcell, Jr., Esc I. . #29955 , 719 North Front Street Harrisburg, PA 17102 (717) 234-4178 VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce 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. Dated: May 25, 1999 Bin Sheng Li BIN SHENG LI, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 99-3250 CIVIL ZHENG WEI BAI, : CIVIL ACTION-LAW Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, Zheng Wei Bai, the Defendant, hereby swear and affirm that I received a certified copy of the Complaint in Divorce with Notice to Defend and Claim Rights and Notice of Availability of Counseling from John W, Purcell, Jr,, attorney for the Plaintiff. I, hereby accept service and waive any further service upon me. Zheng Wei Bai Defendant Sworn to and subscribed before me this ` _a`, day of 1999 N ary ub'lic NOTARIAL SEAL CHERYL L DeVERE. Notarv 1-- City of Harnsburg. Dauphin Cci.?r. M Commission Expires May! Aug: , r ra 1i-? •? C1• Gl ,J r. r Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 99-3250 CIVIL ZHENG WEI BAI, : CIVIL ACTION-LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the divorce Code was filed on May 28, 1999. 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. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §330 1(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 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. 1 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: September 14, 1999 7 , Bin Sheng Li U °• 'C CU ` u-; ; rLZ ? nLu c BIN SHENG LI, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 99-3250 CIVIL ZHENG WEI BAI, : CIVIL ACTION-LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the divorce Code was filed on May 28, 1999. 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. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 1 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. 1 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. verify that the statements made in this Affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsification to authorities. L-- Date: September 14, 1999 ZHENG WEI BAI en ''1 0 7 J_ _ ti u l V C l . c BIN SHENG Ll, Plaintiff Vs. ZHENG WEI BAI, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3250 CIVIL CIVIL ACTION-LAW IN DIVORCE PRAECIPE The Social Security Number of the Plaintiff is 610-44-9870, and the Social Security Number of the Defendant is 609-60-4125. Respectfully submitted, PURCELL,KRUG & HALLER BY Jolyp. Purcell, Jr. 1,0/29955 1x19 North Front Street Harrisburg, PA 17102 Attorney for the Plaintiff urn ???; C c^ r O? , _ ' Ci. T- CL. C_l ?1 T L'I V) U_ U a% Q1 ?