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HomeMy WebLinkAbout08-5493CHUNG JA CHUNG, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL DIVISION - LAW SUNG JO CHUNG, NO. 0 g' "13 CIVIL TERM Defendant IN DIVORCE NOTICE TO DEFEND 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 Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, FLOWER & LINDSAY F NVM & LINDSAY 26 West High Street Carlisle, PA MAP?du atas, Esquire Supre ourt ID #84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff CHUNG JA CHUNG, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL DIVISION - LAW SUNG JO CHUNG, NO. ®$ = 5 y?l 3 CIVIL TERM Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Chung Ja Chung, an adult individual residing at 901 Cavalry Road, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Sung Jo Chung, an adult individual residing at 901 Cavalier Road, Carlisle, Cumberland County, Pennsylvania 17013. 3. The Plaintiff and Defendant both have been bona fide residents 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 April 3, 1978 in Korea. 5. There have been no prior actions of divorce or for annulment between the parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that she has IS C? 26 West High Street Carlisle, PA the right to request that the court require the parties to participate in counseling. Knowing this, Plaintiff does not desire counseling. 7. The parties' marriage is irretrievably broken. 8. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 9. Plaintiff and Defendant are citizens of the United States of America. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 (c) or (d) of the Pennsylvania Divorce Code. Respectfully submitted, SAIDIS, FLOWER & LINDSAY Maryl atas, Es "quire Supre Court ID #84919 26 West High Street Carlisle, PA 17013 (717) 243-6222 Dated: Counsel for Plaintiff CIS & LINDSAY 26 West High Street Carlisle, PA VERIFICATION I verify that the statements made in the foregoing document 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. Chung Ja Chung Date: C,/ l5 /ob FLOSAMWERR & I IS, LENDS" 26 West High Street Carlisle, PA 8 ?_ Cwy [ti CHUNG JA CHUNG, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL DIVISION - LAW SUNG JO CHUNG, NOS Og -S?fg3 CIVIL TERM Defendant IN DIVORCE ACCEPTANCE OF SERVICE i, SUNG JO CHUNG, Defendant, accept service of the Divorce Complaint in the above-captioned matter. r %LAr L7 f Date SUNG JO C HUNG SAIDIS, FLOVVFR & LINDSAY ,eruw 26 West High Street Carlisle, PA r? C._ w t1? ? ?n t Y t3c CHUNG JA CHUNG, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL DIVISION - LAW SUNG JO CHUNG, NO. 2008-5493 CIVIL TERM Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed September 16, 2008. 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 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 SAIDIS, FLOWER & LIlVDSAY 26 West High Street Carlisle, PA Notary Public C, C ? J=6 7 to 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. 1 e Date: ? - n State of Pennsylvania County of Cumberland CHUNG JA CHUNG :SS. On this, the 01 day of 2008, before me, the undersigned officer personally appeared CHUNG JA CHUNG, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ? ? i ?? ?? d , '? ? ? ? ?,? Q ';, ? i _, ? ? ? .? ? ' -? v_. .r° '. ? ?t '?1 "' f ?w 1 ?wn CHUNG JA CHUNG, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL DIVISION - LAW SUNG JO CHUNG, NO. 2008-5493 CIVIL TERM Defendant IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER4 3301 (cl OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. 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. 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 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. AA- Date: State of Pennsylvania County of Cumberland : CHUNG JA CHUNG :SS. On this, the Aga day of aLe-L-«-t?c?C ?-r 2008, before me, the undersigned officer personally appeared CHUNG JA CHUNG, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. SAMIS, FLONVERR & LINDS" 26 West High Street Carlisle, PA tary Public I KCSEAL BARBARA B. STB81., Notoy Mile Carlisle 801% C mberlesd C,aee,, PA M Cortamsdoo EXPIM Jimie'f 11 ca r. ii Il 21 Co ERICK E. MYERS, Plaintiff VS. GRACIE MYERS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-5494 CIVIL TERM r r,. CIVIL ACTION -LAW c. IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING ..c cs> tj 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on September 16, 2008. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed since the date of filing and service of the Complaint. 3. I consent to the entry of a Final Decree of Divorce after service of notice of intention to request entry of the decree. 4. I have been advised of the availability of marriage counseling and understand that I may request that the Court require that my spouse and I participate in counseling. I further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I participate in counseling prior to a decree being handed down by the Court. 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. Section 4904, relating to unsworn falsification to authorities. Date: OKW&e ?q 200?_ v r- CD W ERICK E. MYERS, Plaintiff VS. GRACIE MYERS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2008-5494 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE o r°n rn c:::1 rn -c WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1. 2. rx? I consent to the entry of a Final Decree of Divorce without further notice. 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. 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. Date: DECrr-Ml fit'. ?? , 200 C. w :- - ---:, F7 `' C l .< a I CHUNG JA CHUNG, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL DIVISION - LAW SUNG JO CHUNG, NO. 2008-5493 CIVIL TERM Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed September 16, 2008. 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. A 3. 1 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 SAIDIS, FLOWER & LINDSAY AITOREM0 26 West High Street Carlisle, PA N-? r--L? Notary P lic COMMONWEALTH OF PENNSYLV 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. Date://, State of Pennsylvania : County of Cumberland : :SS. SU J4cuN--G O n this, the 3 day of 11W, , 2008, before me, the undersigned officer personally appeared SUNG JO CHUNG, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. Now6alSaw Maureen ROaado, Notary Puck Carlisle fto, Cumberland County my common Ex 'va ,Jam is, 2012 Member, Pennsylvania Associstlon s f -r ?m CHUNG JA CHUNG, Plaintiff V. SUNG JO C?HUNG, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW NO. 2008-5493 CIVIL TERM IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER6 3301 W OF THE DIVORCE CODE 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. I verify that the statements made in this Affidavit are true and correct to the best of my SAIDIS, FLOWER & IDWS" 26 West High Street Carlisle, PA C_ Notary P blic COMMONMALii-LO 'c:NNS't1_VANIA Notarial Seal aureen Rosado, Notary Pabliw rlsle Boro, Cumberland County omm ission Expires Jan. 18; 2012 LM Member, Pennsylvanla Asprx%; +r.=: Nolwiea 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 aut. rities. Date: D SUNG JO CfIUNG4 State of Pennsylvania County of Cumberland :SS. On this, the 3 day of 6)?tn , 2008, before rne, the undersigned officer personally appeared SUNG JO CHUNG, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ter. 35 ?1 ?. W. CHUNG JA CHUNG, Plaintiff V. SUNG JO CHUNG, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on September 18, 2008, via regular mail. Proof of service was filed with the Court on September 26, 2008. 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was executed: 4. Related claims pending: None. SAIDIS, FLOWER & LIlVDSAY 26 West High Street Carlisle, PA 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was executed: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION - LAW NO. 2008-5493 CIVIL TERM IN DIVORCE By Plaintiff: On December 29, 2008 and filed with the Prothonotary on December 30, 2008. By Defendant: On January 3, 2009 and filed with the Prothonotary on January 6, 2009. By Plaintiff: On December 29, 2008 and filed with the Prothonotary on December 30, 2008. By Defendant: On January 3, 2009 and filed with the Prothonotary on January 6, 2009. SAIDIS, FLOWER & LINDSAY .- Marylou! tas, EWre Supreme Court ID No. 84919 26 West High Street Carlisle, PA 17013 717-243-6222 Attorney for Plaintiff N c r% 'i r,° IN THE COURT OP'COMMON PLEAS OF CHUNG JA CHUNG :,CUMBERLAND COUNTY, PENNSYLVANIA V. SUNG JO CHUNG NO. 2008-5493 DIVORCE DECREE AND NOW, _T4_, 1.2* , -Zqd , it is ordered and decreed that CHUNG JA CHUNG , plaintiff, and SUNG JO CHUNG , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE Prothonotary By the Court, . 0a11 CF% ni