HomeMy WebLinkAbout09-6805NO HO, : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
VINH THANH GIANG,
Defendant
No. 64 -4aOIT 0utL?f2
1
CIVIL ACTION - LAW
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 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
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
NO HO, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. No.
VINH THANH GIANG, CIVIL ACTION - LAW
Defendant : IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTIONS 3301(c) OR 3301(d)
OF THE DIVORCE CODE
AND NOW, comes the Plaintiff, No Ho, by and through her attorneys, Foreman &
Caraciolo, P.C., and makes the following Complaint in Divorce and, in support thereof,
avers as follows:
1. The Plaintiff, No Ho, is an adult individual who currently resides at 112
April Drive, Camp Hill, Pennsylvania 17011.
2. The Defendant, Vinh Thanh Giang, is an adult individual who currently
resides at 112 April Drive, Camp Hill, Pennsylvania 17011.
3. The Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six months immediately prior to the filing of
this Complaint.
4. The Plaintiff and the Defendant were married by formal ceremony on
September 21,1991 in Camp Hill, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties.
6. The marriage is irretrievably broken.
7. The Plaintiff has been advised that counseling is available and that the
Plaintiff may have the right to request that the court require the parties to participate in
counseling.
8. This action is not collusive.
10. There are no minor children born of the marriage.
WHEREFORE, the Plaintiff, No Ho, respectfully requests that this Honorable
Court enter a decree of divorce in this matter.
I o/ 9 /0?
Dat
Respectfully Submitted,
FOREMAN & CARAU
Bruce D. Foremah, L%quire
Attorney I.D. #21193
I, P.C.
Veterans Building
112 Market Street, Sixth Floor
Harrisburg, PA 17101
Telephone (717) 236-9391
Attorney for Plaintiff
Bruce D. Foreman, Esquire
Attorney ID No. 21193
Foreman & Caranolo, P.C.
112 Market Street, 6- Floor
Harrisburg, PA 17101
(717) 236-9391 Telephone
(717) 236-6602 Facsimile
bruce@ffclaw.net
Attorney for Plaintiff
NO HO,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
VINH THANH GIANG,
Defendant
. No.
CIVIL ACTION - LAW
IN DIVORCE
VERIFICATION
I verify that the statements made in this Complaint 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 unworn falsification to
authorities.
Date
A
II 11 ? ??!J 1
NO HO, Plaintiff
C?
FLE o._ F
20,39 OCT 13 Ph 2: 15
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NO HO,
Plaintiff,
V.
VINH THANH GIANG,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 09 - 6805
CIVIL ACTION - LAW
IN DIVORCE
PROOF OF SERVICE
I hereby certify that I have served upon the party listed below, a true and correct copy of
the Divorce Complaint filed on October 13, 2009 in the above captioned matter, by Certified
Mail, Return Receipt Requested, Postage Prepaid and addressed as follows:
Vinh Thanh Giang
112 April Drive
Camp Hill, PA 17011
As is evidenced by the attached copy of the signed Domestic Return Receipt card.
Respectfully submitted,
FOREMAN & CARACIOLO, P.C.
---Date --- Bruce . Fore , Esquire
Attorney ID No. 21193
112 Market Street, 601 Floor
Harrisburg, PA 17101
Telephone (717) 236-9391
Facsimile (717) 236-6602
(,
EXHIBIT "A"
¦ Complete Rams 1. 2, and 3. Also complete
Item 4 N Reid Delivery Is desired.
¦ Print your name and address on the reverse
so that we can return the card to you.
¦ Attach this card to the hack of the mailpleoe,
or on the front N space permits.
\1. Article Addressed to:
x /,7
(PtfjM%d-fYairie)
B.' R?Wmj Py (
I C? F,?gOe Delivery VY /?
D. is delivery address differerd from Item 1 T ? Yes
If YES, enter delivery address below: XI No
r
Type
X C tlfieed man 0 express Meg
? Registered WRetum Receipt for Merchandise
13 Insiued M? C.O.D.
4. Restrkted Denvery9 (Extra Fee) p Yes
2. Number
-7008 3230 0002 7665 1976
f '>m+r+ sarvxx? late
Ps Forr3811, February 2oo4 Domestic Retum Receipt 10¢595-02-M-150
iLIrz'D
OF 'Fri" PF
2004 0CT 20 PH €2: 19
CIJf `.;
Bruce Foreman, Esquire
FOREMAN & CARACIOLO, P.C.
Attorney ID No. 21193
112 Market Street, 6w Floor
Harrisburg, PA 17101
(717) 236-9391- Telephone
(717) 236-6602 - Facsimile
bruce@ffclaw.net
Attorney for Plaintiff
NO HO,
Plaintiff,
V.
VINH THAriH GIANG,
Defendant.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 09 - 6805
CIVIL ACTION LAW
IN DIVORCE
ACCEPTANCE OF SERVICE
I, Vinh Thanh Giang, Defendant in the above-captioned matter, do hereby certify that on
the date written below, I have accepted service of Plaintiff's Complaint in Divorce, filed to the
above-captioned term and number.
I e 42-6 ,
Date V' Thanh Giang
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO HO
V.
VINH THANH GIANG NO 09-6805
DIVORCE DECREE
AND NOW, ~ Za (~ , it is ordered and decreed that
NO HO
VINH THANH GIANG
,plaintiff, and
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.")
The Marriage Settlement Agreement of the parties is incorporated, but does not merge with
this decree.
r~~uwiw~aiy
By the Court,
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