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Home My WebLink About04-2584 GLENN E. STAMBAUGH, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW ~ NO. () L(' c2)(stf : IN DIVORCE CIVIL TERM BINGHUI HELEN WU, Defendant 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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, Carlisle, Cumberland County, Pennsylvania, 17013. 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, Pennsylvania 17013 (717) 249-3166 GLENN E. STAMBAUGH, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW BINGHUI HELEN WU, Defendant : NO. 04, zS'it; : IN DIVORCE CIVIL TERM COMPLAINT IN DIVORCE NO FAULT I. Plaintiff is Glenn E. Stambaugh, an adult individual currently residing at 1171 Claremont Road, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Binghui Helen Wu, an adult individual currently residing at 9417 E. Lemon Avenue, .Temple City, California 91780 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on January 5, 1993, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens ofthe United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date ofthe filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, /hA:l(jI(AA ]Vl~ M~r;,h,rt las, EsqUIre Attorney Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 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. Section 4904, relating to unsworn falsifications to authorities. DATE: J~ ~ .lOCI 'I . ~.,'R~ [, AU~ GLENN E. STAMBAUGH, Plaintiff (~fr - 0j - -0 ....... ....r-, --.J Vv f" r ~\ <:::' - '(-'v ~ ?+- U '-"1 ~, --- <:;:Y) '-> ~ \<.' /"'"'~, I,? .- ., (' -I, -".~ GLENN E. STAMBAUGH, . Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW BINGHUI HELEN WU, Defendant : NO. 04-2584 : IN DIVORCE CIVIL TERM AFFIDAVIT OF SERVICE l-"- AND NOW, this :z.. -4 day of June, 2004, comes Marylou Matas, Esquire, counsel of record for Plaintiff, Glenn E. Stambaugh, and states that a true and attested copy of a Complaint in Divorce was sent to Defendant, Binghui Helen Wu, at 9417 East Lemon Avenue, Temple City, California 91780, by certified mail, restricted delivery, n:turn receipt requested. A copy of said receipt is attached hereto indicating that service was made on June 14, 2004 oU..<.., (,LC ~ f/ v,,-1:r.<<J Mary tas, Esqm.re Attorney r Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, P A 17013 (717) 243-5551 (800) 347-5552 Sworn and sUbscr~to before e this _ day of ,2004 lIOT _ _.J.IEH~~A!l!,!'Il8UC ......... 8ORO~!!!!"!I'tIIUlI !lOIlIITr '~~------ ~J.,...K' ". "::; JIJ!". :r 0<:1 ...a IT" ~v~c ,~, C ~ .q"~",, .' , J' r HerB, --0 ' 0' /. _..._~x.:" / ...'/ :r IT" ...a :r Postage Certified Fee ru Return Receipt Fee C (Endorsement Required) C RestrIcted Delivery Fee C (Endorsement Required) C Total Postage & Fees m U'l .-'l c c c r'- __ -----1 c c " -Of (1)\ "7 t1 -~ r:' "" ? L 'j l""'-:J ,....:, " J?' ;,:::: () ->1 ,;,-' <..1' ...., -' r'..) C;) \J) GLENN E. STAMBAUGH, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. ; CIVIL ACTION - LAW BINGHUI HELEN WU, Defendant : NO. 04-2584 ; IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT I. A. Complaint in Divorce under ~3301 (c) of the Divorce Code was filed on June 9,2004, and served on June 14,2004.. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from 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 ofthe decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT 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: /7 4d .2..00,/ ~b~L- _~ GLENN E. STAMBAUGH, Plain iff ,- .s (') N <OL L:.J <h c-., ...,:-..:;, ("" GLENN E. STAMBAUGH, Plaintiff : IN THE COURT OF COMMON PLEAS OF ; CUMBERLAND COUNTY, PENNSYL VANIA v. : CIVIL ACTION - LAW BINGHUI HELEN WU, Defendant ; NO. 04-2584 : IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUEST THE ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorc:e is granted. 3. I understand that I will not be divorce 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 files with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. g4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE; 17 ~ 200;1 ~C~I-~ GLENN E. STAMBAUGH, aintiff --'" ::~ ""'" c:.> (~. '1.2 -;'"1 (/) ;-:' N c.) -0 r- -l GLENN E. STAMBAUGH, Plaintiff ; IN THE COURT OF COMMON PLEAS F ; CUMBERLAND COUNTY, PENNSYLV NIA v. : CIVIL ACTION - LAW BINGHUI HELEN WU, Defendant ; NO. 04-2584 ; IN DIVORCE CIVIL TERM AFFIDAVIT OF CONSENT 1. A. Complaint in Divorce under 93301 (c) of thc Divorce Code was filed 0 Junc 9,2004, and served on June 14,2004.. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninet (90) days have elapsed from the date of filing and service of the Complaint. 3, I consent to the entry of a final Decree of Divorce after service of noti e of intention to request entry ofthe decree. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDA IT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HE IN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. 94904 RELATING 0 UNSWORN FALSIFICATION TO AUTHORITIES. -r....,.,..,....... Uh.l n: II / ~ !~~vr; ( ( P )~1-, /cv'\' l J-f, t{At BINGH ELEN WU, Defendant c~ \~ -) ,-...- ~' c:- GLENN E. STAMBAUGH, Plaintiff ; IN THE COURT OF COMMON PLEAS F ; CUMBERLAND COUNTY, PENNSYLV NIA v. ; CIVIL ACTION - LAW BINGHUI HELEN WU, Defendant ; NO. 04-2584 ; IN DIVORCE CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE U~,,])ER &330l(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of pro lawyer's fees or expenses if! do not claim them before a divorce is granted. 3. I understand that I will not be divorce until a divorce decree is entered b the Court and that a copy of the decree will be sent to me immediately after it is files with the Prothonotary . I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDA IT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HERE ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa,C.S, S4904 RELATING 0 UNSWORN FALSIFICATION TO AUTHORITIES. DATE: Ir/;;J-6 J~ 1 I " J~, t.cA-{ - c.:-" GLENN E. STAMBAUGH, Plaintiff ; IN THE COURT OF COMMON PLEAS 0 ; CUMBERLAND COUNTY, PENNSYL V IA v. ; CIVIL ACTION - LAW BINGHUI HELEN WU, Defendant : NO. 04-2584 : IN DIVORCE CIVIL TERM PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the court for entry of a divorce decree: I. Ground for divorce: Irretrievable breakdown under !/330 I (c) 3391(0)(1) of tile Diveree Ceoe. (Strike out inapplicable section). 2. Date and manner of service of the Complaint; certified mail, restricted de live to Defendant on June 14, 2004 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by !/3301 (c) of the Div rce Code; by Plaintiff: September 17, 2004 by Defendant: November 26, 200 (b) (I) Date of execution of the affidavit required by 93301 (d) of the Divorce Code; (2) Date of filing and service of the plaintiff's affidavit upon the respondent; 4. Related claims pending: none 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file Praecipe to Trans it record, a copy of which is attached; (b) Date of plaintiff's Waiver of Notice in !/3301 (c) Divorce was filed with t e Prothonotary: September 23, 2004 Date defendant's Waiver of Notice in !/330I (c) Divorce was filed with t e Prothonotary: December 10, 2004 ) \ it,,/ Marylo !It~s, Esquire GRIFFIE & ASSOCIATES Attorney for Plaintiff I.,' ,:~ ;- ;t;:+;:+~~lf . . . . . . " . . :+: :+: +;:t:.. ;to; 'f. '+' 'f.;to; ;to; Of.:+::+:+: .. 'f. +.:+:+::+::+:+::+:+:+::+:+: '+':+ "';+::+ '+:+ '" ;+:'+';+::+:+:+:'+':+:'+' . " " . . " . " . " " . " . . . " " . . " . . . . " . . . . . if.:+::Ii:+::+::Ii:+:;+:;+: :+;+::+:;+::+. IN THE COURT OF COMMON PLEA OFCUMBERLANDCOUNTY . . . . . . . PENNA. STATE OF . GLENN E. STAMBAUGH, . . . . . . No. 04-2584 Civil Term plrl;ntiff VERSUS . BINGHUI HET.F.N WH. . . . . . . . . . , . . " Defendant . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . '. . .. .. .. . .. .. .. . . . + :+::+ + '+' + +' '+' + + 'f.:+ + + +'+ DECREE IN DIVORCE . . . . . . ~c;:J,A,M ~" , IT IS ORDERED AND AND NOW, ~,~ . . . . . . . . . . . . . . . . " . . " . . Glenn E. Stambaugh DECREED THAT , PLAI NTI FF, Binghui Helen Wu , DEFENDANT AND ARE DIVORCED FROM THE BONDS OF MATRIMONY, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED: . . . . . . . . " None. PROTHONOTA Y . . " . . . Am2J~ . " . . . . . . . . ++ '1':+:+:+:+ :+ :Io':+' :Io''+''f.:+:+::++ + '>'++'+++'+:+:++:+ :+:+'f.'f++.++''i':+:'f'i':+ :++++ '+' 'f +':+: 'f J, _ L, 4' ~ ~i'L, n(}' IX- e/ 111" / I'"{I ~" 0:'- ~ fp '? I"'T"'" ,/,/,;p r7;4- . et . ."':" . '. - --