HomeMy WebLinkAbout99-05346
Al
v
a
w
d
)LL
Z
lei
O`
i
i
s
i
j
i
i
ZL?
IN THE COURT OF COMMON PLEAS
OF
CUMBERLAND
STATE OF
EUGENE M. FLECK .
Vcr,u,
MI-YONG FLECK
COUNTY
PENNA.
DECREE IN
D I V 0 R C E
AND NOW, ......... A.44.1?,., - .... !q-. , 19. ff - -, it is ordered and
decreed that . Eugene, pt,. Fleck, plaintiff,
r and .......... Mi-Yong Fleck ................................ defendant,
are divorced from the bonds of matrimony.
r
i
ti
A
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;
............... NONE......................................
................
By Th Court.
Attest: J.
i
Prothonotary •e'
i
/3 99 e:V C'm? /viz. tvo? !
EUGENE M. FLECK : IN THE COURT OF COMMON PLEAS
PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA
VS. '
99-5346 CIVIL TERM
MI-YONG FLECK DEFENDANT
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, together with the following information,
to the Court for entry of a Divorce Decree:
1. GROUNDS FOR DIVORCE: Irretrievable breakdown under section
.(r ) 3301 (c) or ( ) 3301 (d) (1) of the Divorce Code.
(Check Applicable Section).
2. DATE AND MANNER of service of the Complaint:
Pr,RQA"XT - 1. 1999
3. COMPLETE EITHER PARAGRAPH (a) or (b).
(a) Date of execution of the Affidavit of Consent required
by Section 3301(c) of the Divorce Code:
By Plaintiff:--- 12/,499 ; by Defendant 12/2/99
(b) (1) Date of execution of the Plaintiff's 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: NONE
5.
DATE AND MANNER OF SERVICE OF THE NOTICE
FILE PRAECIPE TO TRANSMIT RECORD, a copy
attached, if the Decree is to be entered
3301(d) (1) (1) of the Divorce Code
WAIVER OF NOTICE WAS SIGNED ON
ES M. BACH, ESQ.
A.torney I.D. No. 18727
3 2 S. Sporting Hill Road
Mechanicsburg, PA 17055
(717) 737-2033
Attorney for Plaintiff
OF INTENTION TO
of which is
under Section
l L 1 1
C
L"`
Li Ci U
EUGENE M. FLECK
PLAINTIFF
vs.
MI-YONG FLECK
DEFENDANT
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
No. 99-5346
CIVIL ACTION
IN DIVORCE
CERTIFICATE OF PERSONAL SERVICE
I
, JAMES M. BACH, being duly sworn according to law, say
that
alongtwithDefendant
NOTICEherein
DEFEND andserved
CLAIMcopy
RIGHTS,satd COMPLAINT
on the 1st day or September
3 anQlt p.m, by handing to the
attested copy of the same and at the
Defendant's attention to the contents
to Plead" endorsed thereon.
DATE: _na BY:
19 99
Defendant a true and
name time directing the
thereof and the "Notice
J S M. BACH, ESQ. -
Attorney I.D. No. 18727
352 South Sporting Hill Road
Mechanicsburg, PA 17055
717-737-2033
tD jin
?=fl
L
c CIN
cn
Eugene M. Fleck,
Plaintiff
VS.
Mi Young Fleck,
Defendant
,, v r }t'FI }J?p?C. brr a .v.
JAMES M: BACH (717
`'
7RNEY AND COUNSELOR AT LAW
2 SOUTH SPORTING HILL ROAD
ECHANICSBURG,PENNA 17055
?a
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. CI'r- r UG l -?
CIVIL ACTION -LAW
IN DIVORCE
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 in 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 grounds for divorce are 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:
Office of the Prothonotary
Cumberland County Court House
One Courthouse Square
Carlisle, Pennsylvania, 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS FEES, OR EXPENSES, BEFORE A DIVORCE OR ANNULMENT IS
GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THESE.
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 17013-3387
717-249-3166
1
4&._."
Eugene M. Fleck,
Plaintiff
VS.
Mi Young Fleck,
Defendant
AN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 49 . 5 3y4 GtwQ T.?
: CIVIL ACTION - LAW
: IN DIVORCE
AND NOW comes the Plaintiff, by Attorney JAMES M. BACH, and avers as follows:
1. Plaintiff is EUGENE M. FLECK, who currently resides at 307 Keith Road, Mechanicsburg,
Pennsylvania.
2. Defendant is MI YOUNG FLECK, who currently resides at 307 Keith Road, Mechanicsburg,
Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six
months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on January 31, 1987.
5. There have been no prior actions of divorce or annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of counseling and also the Plaintiff may have the
right to request that the Court require the parties to participate in counseling, and after being
so advised, Plaintiff does not desire counseling.
WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce.
Respectfully submitted,
DATE 3-4
sy Lt' EL
JA ES M. ACH, ESQUIRE
At rney I.D.# 18727
352 S. Sporting Hill Road
Mechanicsburg, PA 17055
(717)737-2033
I verify that the statements made in this Complaint are true and correct. I understand that
false statements herein made are subject to penalties of 18 PA. C.S. section 4904, relating to
unsworn falsification to authorities.
Date:50 nuCoSTO - ?
EUGENE M. FLECK
Plaintiff
C?l
?~ ? V v
ti
I, lT -? ??_ )
y
o
eI.
EUGENE M. FLECK,
Plaintiff
VS.
MI YOUNG FLECK,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5346
: CIVIL ACTION -LAW
: IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301 (Q OF THE DIVORCE CODE
(1) A Complaint in Divorce under §3301(c) of the Divorce Code was filed on JULY 14,
1999.
(2) The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing and service of the Complaint.
(3) I consent to the entry of a final decree of divorce, without formal notice of the intention to
request entry of divorce decree.
(4) 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.
(5) 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 unswom
falsification to authorities.
December , 1999
SD ATE
PLAINTIFF: EUGENE M. FLECK
L
' I
L ?.
J..?
J
C_S _
Ilu
LL
i LL
L"
C` u? U
EUGENE M. FLECK,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : NO. 99_5346
MI YOUNG FLECK, : CIVIL ACTION -LAW
Defendant : IN DIVORCE
AFFIDAVIT OF CONSENT AND
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(CC) OF THE DIVORCE CODE
(1) A Complaint in Divorce under §3301(c) of the Divorce Code was filed on JULY 14,
1999.
(2) The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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, without formal notice of the intention to
request entry of divorce decree.
(4) 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.
(5) 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 unswom
falsification to authorities.
December 2 , 1999 /t Ll A-/z / `1_z
DATE
DEFENDANT: MI YOUNG FLECK
_' C
i
u ir' ?
L l i ;^
i_
C,i ?.- i0 ''iIJ
C..
(_:
liiJ
L r0.
i L
U i _?
l?
+ SEP 1 5 1999
Eugene M. Fleck,
Plaintiff
V9.
Mi Young Fleck,
Defendant
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY,
: PENNSYLVANIA
NO. CI y - s?? IJ
CIVIL ACTION-LAW
IN DIVORCE
6
AND NOW on this l day of 1M, it is hereby
ordered and directed as follows:
I. Primary physical and legal custody of 12QLQRPS S FLECK shall in all times
hereinafter be with the father, F. N M FLECK, subject however to
reasonable periods of temporary visitation in the MOTHER as set forth in the
Custody Agreement.
B
-?-- i -I. , 'I , 'k-;: I ?)
JAMES M. BACH ? (717) 737-2033
ATTORNEY AND COUNSELOR AT LAW
352 SOUTH MECHANICSBURGN ENNA 7055
I
f
t
4
54011 VNN3d 'oHf18S01NVH03W
OVOH IIIH ONIlHOdS HAGS Z46
MVl 1V H013SNf100 ONV A3NHOl1V
EEOZIEL WL H3V8 -W S3WVP
(717) - -737.2033
JAMES M. BACH
ATTORNEY AND COUNSELOR AT LAW
352 SOUTH SPORTING HILL ROAD
MECHANICSBURG, PENNA 17055
1
f
? I
Eugene M. Fleck, : IN THE COURT OF COMMON PLEAS
Plaintiff : OF CUMBERLAND COUNTY,
: PENNSYLVANIA
VS.
NO.
Mi Young Fleck,
Defendant CIVIL ACTION- LAW
IN DIVORCE
CUSTODY AGREEMENT
S
This Agreement entered in this day of
1999, by and between MT YoNQ F K (hereinafter referred to as
MOTHER) and EUGENE M. FI?FCK ( hereinafter referred to as FATHER).
WHEREAS MT YON• PLF-QK and Ft,.N. M. FLECK were lawfully
married at one time, but the parties are currently separated and
a divorce action is pending.
WHEREAS a CHILD was born of this marriage namely DOLORES S.
FLECK, born on or about the 24? day of November, 1986.
WHEREAS MOTHER and FATHER intend to settle, by this
document, their custody and visitation rights absolutely.
NOW THEREFORE in consideration of the mutual covenants and
promises contained herein, custody and visitation between MOTHER
and FATHER in regards to this CHILD is set forth hereinafter:
ITEM 1. Primary physical and legal custody of DOLORES S. FLECK,
born on or about 2_42 day of November, i 986, shall in all times
hereinafter be in the FATHER EUGENE M. FLECK, subject however to
I
reasonable periods of temporary visitation in the MOTHER as set
forth hereinafter.
1
ITEM 2. MOTHER shall have visitation every other weekend
commencing on Friday evening at 6:00 p.m. and ending on Sunday
evening at 6:00 p.m. MOTHER shall have overnight visits with her
DAUGHTER unless the DAUGHTER indicates that she does not want to
stay overnight or feels uncomfortable about staying overnight.
The issue of overnight visitation is to be settled between MOTHER
and DAUGHTER, and no other person.
ITEM 3. In the event this Agreement is breached by either
party, then the breaching party is responsible for attorney fees
I
and Court costs of the other party.
ITEM 4. This constitutes the entire Agreement between the
parties. This Agreement may not be modified unless it is in
writing and signed by both parties. This Agreement shall be
construed under the laws of the Commonwealth of Pennsylvania.
ITEM 5. It is the intention of these parties that this
Agreement will have the full force and effect of a lawful court
order. The parties acknowledge that this Agreement may be
enforced to the same extent as though it has been an Order of the
Court, and the parties hereby expressly invoke and acknowledge
the applicability of Section 401.1 of the Pennsylvania Divorce
Code in furtherance hereof.
IN WITNESS WHEREOF, the parties hereto have set their hands
and seals the day and year first above written.
WI SS E
0 H
WI ESS
(FATHER)
Respectfully submitted,
Date: ORNEY JAMES M. BACH
ttorney I.D. #18727
352 South Sporting Hill Road
Mechanicsburg, PA 17055
(717) 737-2033
Attorney for Plaintiff
c
'I
1
? W
? 1^
V
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY
CIVIL ACTION - LAW
PENNSYLVANIA
Plaintiff
vs.
?ll Vow----r?? lL
Defendant
File No. -!11 - S-'?/- 4
IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff/Defendant in the
above matter, having been granted a Final Decree in Divorce on the
day of c' hereby elects to resume the
prior surname of
and gives
this written notice pursuant to the provisions of 54 P.S. S 704.
DATE:3
i
J ignature
O
S gn re of name being resumed
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND SS.
On the
day of U U(?, before me, a
Notary Public, personally appears the above affiant known to me to
be the person whose name is subscribed to the within document and
acknowledged that he/she executed the foregoing for the purpose
therein contained.
In Witness Whorcof, I have hereon Lo set
seal. my hand and official
NOTARIAL SEAL
JODY S. SMITH. NOTARY PUBLIC
J
Carlisle Boro. Cumberland County Q ----
Nola ry I'ubl LC
My Commission Expires April 4, 2005
Y 1
CC ?
i.
? ?
;' i
' ???
? J
?
)
f ?? ? \
?
?U .? U