Loading...
HomeMy WebLinkAbout04-0894Soknouv Cheam, Plaintiff V. Nak Chhoeung, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. Oy - ?9y (21(' C- ? 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 papers, 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 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 Prothonotary at the Cumberland County 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 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 Attorney for Soknouv Cheam, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. Nak Chhoeung, : CIVIL ACTION -LAW Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Soknouv Cheam, who currently resides at 64 Skyline Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Defendant is Nak Chhoeung who presently resides at 64 Skyline Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on November 18, 1995, in Cumberland County, Pennsylvania, 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America. 8. Plaintiff avers that there are four children of the parties under the age of eighteen. 9. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT 1 REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 10. The prior paragraphs of this Complaint hereby incorporated by reference as if fully set forth herein at length. 11. The marriage of the parties is irretrievably broken. COUNT II REQUEST FOR EQUITABLE DISTRIBUTION OF PROPERTY UNDER §3502 OF THE DIVORCE CODE 12. The prior paragraphs of this Complaint hereby incorporated by reference as if fully set forth herein at length. 13. The parties have acquired certain property and assets which constitute marital property. 14. In the event the parties are unable to resolve distribution of marital property by way of an agreement, then this Honorable Court is authorized to equitably divide, distribute or assign marital property between the parties in such proportion as the Court deems just after consideration of all relevant factors. COUNT III REQUEST FOR ALIMONY UNDER §3701 OF THE DIVORCE CODE 15. The prior paragraphs of this Complaint are hereby incorporated by reference as if fully set forth herein at length. 16. Plaintiff is unable to sustain herself during the course of litigation and to prosecute this divorce action. 17. Plaintiff lacks sufficient income and property to provide for her reasonable needs and is unable through appropriate employment to provide for those reasonable. COUNT IV REOUEST FOR ALIMONYPENDENTE LITE, COUNSEL FEES AND EXPENSES UNDER 43702 OF THE DIVORCE CODE 18. The prior paragraphs of this Complaint are hereby incorporated by reference as if fully set forth herein at length. 19. Plaintiffis unable to payher counsel fees, costs and expenses and Defendant, Nak Chhoeung, is full well and able to pay them. WHEREFORE, Plaintiff requests this Honorable Court to enter an Order: a) dissolving the marriage between Plaintiff and Defendant, and; b) equitably distributing all marital property pursuant to section 3502 of the Divorce Code, and; C) awarding Plaintiff alimony pendente lite until final hearing and thereupon to enter an order of alimony in her favor pursuant to §3701 and §3702 of the Divorce Code and ordering Defendant, Nak Chhoeung, to pay the reasonable counsel fees, costs and expenses of Plaintiff. Respectfully Submitted, vster, BY: CKeller, Esquire Supreme Court ID# 86889 Attorney for Plaintiff 101 South Market Street Mechanicsburg, Pennsylvania 17055 (717) 790-5451 VERIFICATION I verify that the statements made in the attached complaint 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: Z /,a q10 14411 ? C- L ? Soknouv Cheam r 70 b ? C Q oO c p G.. r` Soknouv Cheam, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 04-894 Civil Term Nak Chhoeung, : CIVIL ACTION - LAW Defendant : IN DIVORCE ACCEPTANCE OF SERVICE I, Nak Chhoeung, the above-named Defendant, hereby accept service of the Complaint in Divorce in the above-captioned matter. Date: B -'3j Mechanicsburg, PA 17050 V? unyu„c.v..vc ?' _? r.] ?`.J C _: C a j_ ? . ?:: ?I_: '?. ... ?.r(?) l_ I N , ?[^ , ? Ct1 ?, Curtis R. Long Prothonotary (Office of the Protbonotarp Cumberlaub Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 014 - S 911 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