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Home My WebLink About00-05030MARIE ELIZABETH PARK IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA SS #271-58-4072 V. NO. QV , rwo ?cvC( Lt?/ / JOHN JONG-SOO PARK CIVIL ACTION - LAW Defendant IN DIVORCE SS# 526-75-2958 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 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, 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. E A1H3-C9FFRrPiFfaUSE enr--?3A?- 0_)_ CARLISLE PA 17013 MARIE ELIZABETH PARK Plaintiff SS #271-58-4072 V. JOHN JONG-SOO PARK Defendant SS# 526-75-2958 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO . 00- 5b,36 CtL 7-t,, CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(C) OR 3301(D) OF THE DIVORCE CODE AND NOW, comes the above-named Plaintiff, MARIE ELIZABETH PARK, by her attorneys, Knupp, Kodak & Imblum, P.C., and seeks to obtain a Decree in Divorce from the above-named Defendant upon the grounds hereinafter more fully set forth: COUNT I DIVORCE 1. Plaintiff is MARIE ELIZABETH PARK, an adult individual who currently resides at 29 Gettysburg Pike, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is JOHN JONG-SOO PARK, an adult individual who currently resides at 29 Gettysburg Pike, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on November 22, 1980, in Tucson, Arizona. 5. There have been no prior actions of divorce or for annulment of marriage between the Parties in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree of Divorce. COUNT II EQUITABLE DISTRIBUTION 9. Plaintiff incorporates by reference paragraphs 1 though 8 of this Complaint. 10. Plaintiff and Defendant possess various items of both real and personal marital property which is subject to equitable distribution by this Court. , Plaintiff requests your Honorable Court to equitably distribute all property, both real and personal, owned by the parties. Respectfully submitted, KNUPP, KODAK & IMBLUM, P.C. By: Gary j. Imb1 n Attorney I. N 42606 407 North Ffront Street P.O. Box 11848 Harrisburg, PA 17108-1848 (717) 238-7151 Attorneys for Plaintiff Dated: 7--10 ?? VERIFICATION I, MARIE ELIZABETH PARK, verify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. OD y?°"``-Q DATED: ax MARIE ELIZABETH ARK t n Z G c h o ? C ?O. i7 3 9 a? Fri i r ,d j MARIE ELIZABETH PARK Plaintiff SS #271-58-4072 V. JOHN JONG-SOO PARK Defendant SS# 526-75-2958 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5030 CIVIL TERM . CIVIL ACTION - LAW IN DIVORCE PRAECIPE FOR REINSTATEMENT OF COMPLAINT Please reinstate the Complaint in the above matter. Respectfully submitted, KNUPP, KODAK & IMBLj?M, P. Date: ®29 ,010a Gary J. I um? Attorney I.D. No. 42606 407 North Front Street P.O. Box 1848 Harris bu g, PA 17108 (717) 238-7151 CJ L c_'- °y '.? ?i? °?? -r, - i,' i - (a `c.. :._ 'n C l_i _ ' 'G f? ` F _`s ( 4 MARIE ELIZABETH PARK Plaintiff SS #271-58-4072 V. JOHN JONG-SOO PARK Defendant SS# 526-75-2958 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00-5030 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 13 day of eOTtAj UL , 2000, comes Gary J. Imblum, Esquire, Attorney for Plaintiff, who, being duly sworn according to law, deposes and says that: 1. A Complaint under Section 3301(c) and 3301(d) of the Divorce Code was filed on July 18, 2000. 2. A Praecipe to Reinstate the Complaint was filed on September 6, 2000 and the Complaint was reinstated on September 6, 2000. 3. On October 5, 2000, the reinstated Complaint was served on Defendant by personal service by Charles C. Fisher as evidenced by the Affidavit of Service attached hereto as Exhibit "All and incorporated herein by reference. 1 ti KNUPP, KODAK & I LUM, /.C. i By: Gary J. Imbl Esquire Attorney I. . No. 42606 Attorney fo Plaintiff AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA . :SS. COUNTY OF DAUPHIN On the 5th day of October. 2000 , 1997, I, the undersigned, Charles C. Fisher served upon John Jong-Soo Park a Divorce Complaint by Personal Service at 29 Gettysburg Pike, Mechanicsburg, PA 17055 Charles C. Fisher SWORN TO AND SUBSCRIBED BEFORE ME THIS DAY OF /? ? aoao Notary Public My Commission Expires: Notarial Seal Frances A. Aumiller, Notary Public Harrisburg, Dauphin County My Commission Expires Mar. 16, 2002 Member, Pennsylvania 4se0clati0nor NnfaneS ? i ( -"> C 71 '' f G ys 1. .. G P-- _O lD G