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Home My WebLink About01-6202 SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA QUAN LY, Plaintiff : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.~~ CIVIL TERM CIVIL ACTION - LAW IN DIVORCE NOTICE 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counselling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, High and Hanover Street, 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, PA 17013 (717) 249-3166 Date: /0/~/01 By: Joia J/./Kope c~ E~ui re Supreme~Court ID # 53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA Vo Plaintiff : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT UA!DER SECTION 3301(c) OR 3301(d} OF THE DIVORCE CODE 1. Plaintiff is Quan Ly, who currently resides at 45 Victoria Way, Camp Hill, Cumberland County, Pennsylvania. 2. Defendant is Juan Lu, who currently resides at 45 Victoria Way, Camp Hill, Cumberland County, 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. 24, and Defendant were married on October 4. The Plaintiff 1995, in China. 5. There have been no prior actions of divorce or for of to request that in counseling. annulment between the parties. 6. The Plaintiff has been advised of the marriage counseling and the Plaintiff may the Court require the parties Having been so advised Plaintiff desire the Court to order counseling. 7. The marriage is irretrievably broken. availability have the right to participate does not SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High S~reet Carlisle, PA WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce. Respectfully submitted, SAIDIS, SHUFF, By: FLOWER & LINDSAY ~eJ~ou~e~DkY'/5~re 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Slreet Carlisle, PA AFFIDAVIT I, Quan Ly, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counselling and understand that I may request that the court require that my spouse and I participate in counselling. (2) I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. (3) Being so advised, I do not request that the court require that my spouse and I participate in counselling prior to a divorce decree being handed down by the court. 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. Dated: Quan Ly, Plain~i~ SAIDIS SHUFF, FLOWER & LINDSAY 26 W. High Street Carlisle, PA VERIFICATION I verify that the statements made in this Complaint 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. Dated: SAIDIS SHUFF, FLOWER & LINDSAY ATFORNEYS*AT*LAW 26 W. High Street Carlisle, PA Quan Ly, : Plaintiff : V. -' . Juan Lu, : Defendant : : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6202 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 29, 2001. 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. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. Juan Lu, Defendant Date: ~l- /dL ~/_~ SAIDIS SHUFF, FLOWER & LINDSAY ATtORNEYS*AT*LAW 26 W. High Street Carlisle, PA Quan Ly, Plaintiff V. Juan Lu, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6202 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 29, 2001. 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. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the Decree. I verify that the statements made in this Affidavit are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. ~~-- Qu~'n Ly, Plai'~ti~ ~ Date: '/ SAIDIS SHUFF, FLOWER & LINDSAY ATrOR~YS*AT,.LAW 26 W. High Street Carlisle, PA Quan Ly, Plaintiff V, Juan Lu, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6202 CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) 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, lawyer's 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 to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities. QU'~n Ly, Plaintif/c/ O Date: ~/~ ~/~..~-- SAIDIS SHUFF, FLOWER & LINDSAY ATTORb~EYS*AT,LAW' 26 W. High Street Carlisle, PA Quan Ly, : Plaintiff : _. V. .' . Juan Lu, : Defendant : .' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-6202 CIVIL ACTION - LAW IN DIVORCE PS Fo,~. 3811, Decea'tber 10~4 ~ic Retu "[~ ! I- SAIDIS SHUFF~ FLOWER & LINDSAY ATI~P.I~/S*AT*IAW 26 W. High Street Carlisle, PA Quan Ly, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 01-6202 _. Juan Lu, : Defendant : CIVIL ACTION - LAW : IN DIVORCE PRAEClPE TO TRANSMIT RECORD To the Prothonotary: 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 3301 (c) 3301(d)(1) of the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: Certified & Restricted mail, Return Receipt requested signed 11-1-01 (attached). 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 the Plaintiff 04-27-02 ; by the Defendant 04-13-02 (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 Plaintiffs affidavit upon the Defendant: 4. Related claims pending: 5. Complete either (a) or (b). (a) (b) None Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Date Plaintiff's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: 05-07-02 Date Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: 05-07-02 Respectfully submitted, Saidis,~ By: J oh n n/a"'>~'. ~ope c~, E{qui;~,~~ Supr{~rfe Cou~...~D # 5314'~ 26 West High'Street Carlisle PA 17013 (717) 243-6222 Counsel for the Plaintiff Quan Ly, Plaintiff VERSUS Juan Lu, Defendant INThe COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of ~ PENNA. NO. 01-6202 Decree IN DIVORCE and NOW, DECREED THAT Quan Ly AND Juan Lu ~r~, IT IS ORDERED AND , PLAINTIff, , 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; None BY THE COURT: / PROTHONOTARY