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Home My WebLink About09-25560 LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: Isaylor(&-pirlaw.com THU NGUYEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW LISA N. PHAN, NO. 2009- o165(p CIVIL TERM 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 Prothonotary at Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania, 17013. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Please of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. 2 LAW OFFICES OF PETER J. RUSSO, P.C. BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: IsaylorO-r)* law.com Attorneys for Plaintiff THU NGUYEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW LISA N. PHAN, NO. 2009. SSG CIVIL TERM Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE Plaintiff is Thu Nguyen, an adult individual who has resided at 1171 Summerwood Drive, Harrisburg, Dauphin County, Pennsylvania since on or about February of 2009. 2. Defendant is Lisa N. Phan, an adult individual who has resided at 3906 Golfview Drive, Mechanicsburg, Cumberland County, Pennsylvania since on or about November of 2000. 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. Plaintiff and Defendant were married on October 15, 1994, in Harrisburg, Dauphin County, Pennsylvania. 5. Plaintiff and Defendant separated on November 1, 2008. 3 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and Plaintiff may have the right to request that the court require the parties to participate in counseling. COUNT I -- DIVORCE 9. The prior paragraphs of this Complaint are incorporated by reference as though fully set forth herein. 10. Plaintiff avers that the marriage between the parties is irretrievably broken. 11. Plaintiff requests the court to enter a decree in divorce. WHEREFORE, Plaintiff prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: That a decree in divorce be entered dissolving the marriage between the two parties. LAW OFFICES OF PETER J. USSO, P.C. Date: Attorneys for I intiff Peter J. Russo, Esquire ID #72897 ,--,,o*-1izabeth J. Saylor, Esquire ID #200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 PH: (717) 591-1755 FX: (717) 591-1756 4 VERIFICATION I, Thu Nguyen, verify that the statements made in the foregoing document(s) are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unsw orn falsification to authorities. Date: t? 1 t Thu Nguyen 5 X11 f?iJ DF Y 20,09 APIA 23 AN I I. 114, CUL ' ` YJ 4 338. 50 pa sk7w C.?? 3tga .&# 17,cS * C;i.. t 4119A iy?0 0 LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff BY: Elizabeth J. Saylor, Esquire PA Supreme Court ID: 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: Isaylor -Dpiriaw.com THU NGUYEN, : IN THE COURT OF COMMON PLEAS OF Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW LISA N. PHAN, NO. 2009- 2556 CIVIL TERM Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Amber L. Southard, hereby certify that I am on this day serving a copy of the foregoing documents upon the person(s) and in the manner indicated below: US Regular Mail; and Certified Mail, Restricted Delivery, Return Receipt Requested, and addressed as follows: Lisa N. Phan 3906 Golfview Drive Mechanicsburg, PA 17050 d Amber L. Southard, Paralegal Date: ZZ og 6 ,. . . i Aempkfo items 1, 2, and & Also oompieb OWn 4 M feet labd Ddvery b do ed. * P* t your Hems and addmos on the reverse so that we can return the c m d to you. ¦ Aftd this owd to the back of the mdpkm, or on the front if space permits. 1. AAds Addramd to: X _ /1/? / o AWW r, RscW jr (P?Mried Marne} I C. Date of DWvery D. Is ddvary er' ' clan rrt from kern ?I? ? Yet B YES, enter daavary address below: 13 No Lisp. N. P?z1 3?C? GO1FvieW Qr . 1 Chan iCSbUrC? , P? 11O5p .er,W MrA o ?rese Meg O ReRI N I" j(Pak m RsoW for Mwdw Ww O kwcesd and C3 C.O.D. 4. R i m"W ed Ddvary? 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