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HomeMy WebLinkAbout10-3007COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS 2, ! Q ? I _ J CUMBERLAND COUNTY, PENNSYLVANIA TUAN A. NGUYEN, § ' Plaintiff § V. § NO. 10-3m7 C?vi1' p rin DA-PHI PHUONG DAI TANG, § CIVIL ACTION - IN DIVORCE 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 may proceed without you and a decree in 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 Court Administrators Office at the Cumberland County Courthouse, 4' Floor, 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 IS GRANTED OR ANNULMENT, 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 LAWYER REFERRAL SERVICE Court Administrator Cumberland County Courthouse, 4t' Floor Carlisle, PA 17013 (717) 240-62003Q1.50 Pu A'?fi( C01 IDl loco e ay l c,c,? COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TUAN A. NGUYEN, § Plaintiff § V. § DA-PHI PHUONG DAI TANG, § Defendant § NO. CIVIL ACTION - IN DIVORCE AVISO PARA DEFENDER Y RECLAMAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quej as expuestas en las paginas siguientes, debe tomar action con prontitud. Se le avisa que si no se defiende, el caso puede proceder sin usted y decreto de divorcio o anulamiento puede ser emitido en su contra por la Corte. Una decision puede tambien ser emitida en su contra por cualiquier otra queja o compensation reclamados por el demadante. Usted puede perder dinero, o propiedades u otros derechos importantes para usted. Cuando las base para el divorcio es indignidades o rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en: Court Administrators Office at the Cumberland County Courthouse, 4'li Floor, 1 Courthouse Square, Carlisle, Pennsylvania 17013. SI USTED RECLAMA PENSION ALIMENTICIA, PROPIEDAD MATRIMONIAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DIVORCIO O ANULAMIENTO SEA EMITIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS. USTED DEBE LLEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SI NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 LAGUNA REYES MALONEY, LLP 1 1 19 NORTH FRONT STREET, HARRISBURG, PA 1 7 1 02 TEL.: (7 1 7) 233-5292 / FAx: (7 1 7) 233-5394 LRMgA STANFORDALUMNI.ORG ATTORNEYS FOR PLAINTIFF COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TUAN A. NGUYEN, § Plaintiff § V. § DA-PHI PHUONG DAI TANG, § Defendant § NO. CIVIL ACTION - IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, Tuan A. Nguyen, by and through his attorneys, Laguna Reyes Maloney, LLP, and represents as follows: 1. Plaintiff, Tuan A. Nguyen, is an adult individual currently residing 120 Lighthouse Dr., Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant, Da-Phi Phuong Dai Tang, is an adult individual currently residing at 120 Lighthouse Dr., Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Plaintiff and Defendant are both bona fide residents of the Commonwealth of Pennsylvania, Cumberland County, and have been so for at least six months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married in Vietnam on March 12, 1996. 5. Plaintiff and Defendant are citizens of the United States of America. 6. Neither party is a member of the Armed Forces of the United States of America or its Allies. 7. Plaintiff avers that there are two minor children of the parties, namely: Nhan Phuong Nguyen, born December 18, 1998 and Dakota Nguyen, born March 22, 2006. 8. The marriage is irretrievably broken: Plaintiff and Defendant have lived separate and apart since approximately May 4, 2010 and continue to live separate and apart as of the date of filing this Complaint. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. 9. There have been no prior actions of divorce or for annulment between the parties. 10. 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. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 11. Plaintiff requests the Court to enter a decree of divorce. COUNTI GROUNDS FOR DIVORCE: ADULTERY Divorce Code Section 3301(a)(2) 12. Paragraphs 1 through 11 are incorporated herein by reference as if set forth in their full text. 13. The averments contained within this Complaint are not collusive. 14. Defendant has committed adultery. COUNT II INDIGNITIES 3301(a)(6) of the Divorce Code 15. Paragraphs 1 through 14 are incorporated herein by reference as if set forth in their full text. 16. The averments under this complaint are not collusive. 17. Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render his condition intolerable and life burdensome. COUNT III EQUITABLE DISTRIBUTION 3502(a) of the Divorce Code 18. Paragraphs I through 17 are incorporated herein by reference as if set forth in their full text. 19. Plaintiff and Defendant are joint owners of various items of realty, personal property, furniture, and household furnishings acquired during their marriage which are subject to equitable distribution. 20. Plaintiff and Defendant have incurred debts and obligations during their marriage which are subject to equitable distribution WHEREFORE, Plaintiff prays that a judgment be entered in favor of the Plaintiff against the Defendant as follows: a. As to Count I and II, that a decree in divorce be entered divorcing Plaintiff from the bonds of matrimony between the said Plaintiff and Defendant. b. As to Count III, that this Honorable Court enter a decree equitably dividing the parties' property and equitably apportioning the debts incurred by the parties. C. Such other additional relief as the Court deems necessary and appropriate. Respectfully submitted, C. Reyes alo y, Esquire r eme Court I. o.: 78075 Attorney for Plaintiff LAGUNA REYES MALONEY, LLP 1119 North Front Street Harrisburg, PA 17102 (717) 233-5292 VERIFICATION I verify that the statements made in this divorce complaint are true and correct. I understand that false statements made herein may subject me to penalties of Pa.C.S. §4904 relating to unworn falsification to authorities. 5- 4 - o ,010 Date Tuan A. Nguyen ~~ I LAGUNA REYES MALONEY, LLP ~ "~'~ ' ~`*?`' I 1 1 9 NORTH FRONT STREET, HARRISBURG, PA 17 102 i7-U ! 0 + 1' TEL.: (71 7) 233-5292 /FAX: t71 7) 233-5394 ~ + ++ i<.;^ ~ - ~~G 5 ~wr ~o ~09 ATTORNEYS FOR PLAINTIFF G~.t~~ l J I `r COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TUAN A. NGUYEN, § Plaintiff § v. § DA-PHI PHUONG DAI TANG, § Defendant § No. I o- 3 O ®~ c~ v~ i ~7e--~ri CIVIL ACTION - IN DIVORCE PLAINTIFF'S INVENTORY Pursuant to Pa.R.C.P. 1920.75, Plaintiff files the following inventory of all property owned or possessed by either party at the time this action was commenced and all property transferred within the preceding three years. Plaintiff verifies that the statements made in this inventory are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date fi~'~ ~ Tuan A. Nguyen, Plainti ASSETS OF THE PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. ( /) 1. Real Property (/) 2. Motor vehicles ( ) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit ( /) 5. Checking accounts, cash (/) 6. Savings accounts money market and savings certificates ( ) 7. Contents of safe deposit boxes ( ) 8. Trust ( /) 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) ( ) 10. Annuities ( ) 11. Gifts (') 12. Inheritances ( ) 13. Patent, copyrights, inventions, royalties ( ) 14. Personal property outside the home ( ) 15. Business (list all owners, including percentage of ownership, and officer/director positions held by a parry with company) ( ) 16. Employment termination benefits -severance pay, worker's compensation claimlaward ( ) 17. Profit sharing plans (/) 18. Pension plans (indicate employee contribution and date plan vests) ( ) 19. .Retirement plans, Individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. Military/V.A. benefits ( ) 23. Education benefits (/) 24. Debts due, including loans, mortgages held ( /) 25. Household furnishings and personalty (include as a total category and attach itemized list if distribution of such assets is in dispute) ( ) 26. Other (1) Marital Property Pa.R.C.P. 1920.75 Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Number Description of Property Name of All Owners 1. Marital residence Tuan A.Nguyen Da-Phi Phuong Dai Tang 2. 2007 Nissan Murano Tuan A.Nguyen Da-Phi Phuong Dai Tang 2. 2008 Nissan Quest Tuan A.Nguyen Da-Phi Phuong Dai Tang 5. PSECU -Checking Account Tuan A.Nguyen Da-Phi Phuong Dai Tang 6. PSECU -Savings Account not yet determined 9. Life Insurance Policy (no cash surrender value) Tuan A.Nguyen 18. 401k Pension Plan with Fry Communications Tuan A.Nguyen (2) Non-Marital Pro~er~ty Pa.R.C.P. 1920.75 Plaintiff lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: Item Number Description of Property Reason for Exclusion None (3) Pro~ertX Transferred Pa.R.C.P. 1920.75 Item Number Description of Property Date of Transfer Consideration Person to Whom Transferred None (4) Liabilities Pa.R.C.P. 1920.75 Item Number Description of Property. Names of all Creditors Names of all Debtors 24. Marital residence Chase Tuan A.Nguyen P.O. Box 9001123 Da-Phi Phuong Dai Tang Louisville, KY 40290-1 1 23 24. Visa Credit Cazd not yet determined Tuan A.Nguyen Da-Phi Phuong Dai Tang 24. Caz Loan not yet determined Tuan A.Nguyen Da-Phi Phuong Dai Tang COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TUAN A. NGUYEN, § Plaintiff § ~• § NO. 10-3007 Civil Term DA-PHI PHUONG DAI TANG, § CIVIL ACTION - IN DIVORCE Defendant CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of Plaintiff's Inventory upon the Defendant via first-class U.S. mail addressed as follows: Ms. Da-Phi Phuong Dai Tang 120 Lighthouse Dr. Mechanicsburg, PA 17050 August 3, 2010 L a C. Reyes Ma ney, Esquire COMMONWEALTH OF PENNSYLVANIA 03 Xh- COURT OF COMMON PLEAS X C-, � ' r, CUMBERLAND COUNTY, PENNSYLVANIAN r- -ri TUAN A. NGUYEN, § C)r-j Plaintiff § v V. § NO. 10-3007 DA-PHI PHUONG DAI TANG, § CIVIL ACTION - IN DIVORCE Defendant § PETITION FOR LEAVE TO WITHDRAW AS COUNSEL AND NOW, comes Laura C. Reyes Maloney, Esquire and respectfully presents as follows: 1. Petitioner is Laura C. Reyes Maloney, Esquire, having as her principal place of business 1119 N. Front St., Harrisburg, PA 17102. 2. Respondent is Tuan A.Nguyen,Plaintiff in the above-captioned divorce case. 3. Petitioner was retained by Respondent to represent him in his divorce proceedings. 4. Petitioner has undertaken said representation,but is unable to continue for the following reasons: a. Respondent has generally failed to reply to Petitioner's various attempts to contact him. b. On October 18, 2012, Petitioner sent a letter to Respondent indicating that she attempted to reach him by telephone and was unable to leave a message. In addition, Petitioner left a message with Respondent's sister to return Petitioner's call. c. On December 13, 2012, Petitioner sent another letter to Respondent indicating that since Respondent had not contacted Petitioner,Petitioner had to stop working on his case unless/until Petitioner and Respondent met in person to reach some other agreement. d. Since..Petitioner's-various attempts to contact Respondent, Petitioner has not received any response from Respondent. e. There has been a serious failure of communication between Petitioner and Respondent. f, Petitioner is unable to effectively represent Respondent. g. The representation has been rendered unreasonably difficult by the Respondent and, therefore, withdrawal is allowed under Rule 1.16(b)(5) and(6) of the Rules of Professional Conduct. VMEREFORF, Petitioner respectfully requests leave to withdraw her appearance as attorney for Respondent. Respectfully submitted, Za C. Reyes oney, Esquire Supreme Court I.D. No. 78075 LAGUNA REYES MALONEY, LLP I I 19,North Front Street Harrisburg, PA 17102 (717) 233-5292 2 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TUAN A. NGUYEN, § Plaintiff § r V. § NO. 10-3007 DA-PHI PHUONG DAI TANG, § CIVIL ACTION - IN DIVORCE Defendant § CERTIFICATE OF SERVICE I, Laura C. Reyes Maloney, do hereby certify that I served a true and correct copy of the Petition for Leave to Withdraw as Counsel,proposed Order, and proposed Rule to Show Cause filed in the above-captioned matter upon the Respondent and Defendant via first-class U.S. mail, addressed as follows: Mr. Tuan A. Nguyen 120 Lighthouse Dr. Mechanicsburg, PA 17050 Ms. Da-Phi Phuong Dai Tang 120 Lighthouse Dr. Mechanicsburg, PA 17050 Date LaVAa C. Reyes M to ey, Esquire 3 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TUAN A. NGUYEN, § Plaintiff § V. § NO. 10-3007 § DA-PHI PHUONG DAI TANG, § CIVIL ACTION - IN DIVORCE Defendant. § .RULE TO SHOW CAUSE AND NOW, this day of1gK.AM , 201.3, a rufe is hereby issued upon both parties to show cause why the attached Petition for Leave to Withdraw as Counsel should not be granted. This rule is returnable days from date of service. BY THE CO J2 J. a_- *tixw CD C- ✓ ura C. Reyes Maloney, Esquire, 1119 N.Front St.,Harrisburg, PA 17102 .Tuan A.Nguyen, 120 Lighthouse Dr., Mechanicsburg, PA 17050 Ms.Da-Phi Phuong Dai Tang, 120 Lighthouse Dr., Mechanicsburg,PA 17050 T 10 La P111 L3EF LL COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TUAN A. NGUYEN, § Plaintiff § v. § NO. 10-3007 DA-PHI PHUONG DAI TANG, § CIVIL ACTION - IN DIVORCE Defendant § MOTION TO MAKE RULE ABSOLUTE AND NOW, comes the Movant, Laura C. Reyes Maloney, Esquire, and moves this Honorable Court to grant her Motion to Make Rule Absolute and,in support thereof,presents the following: 1. On August 9, 2013, the undersigned filed her Petition for Leave to Withdraw as Counsel and served it upon the Respondent,Tuan A.Nguyen,via first-class U.S. mail. 2. On August 14, 2013, this Honorable Court issued and distributed a Rule to Show Cause upon both parties to show cause why the Petition for Leave to Withdraw as Counsel should not be granted. 3. The Rule to Show Cause was returnable 20 days from date of service. 4. On August 21, 2013, the undersigned served the Rule on both parties (see Certificate of Service, Exhibit"A"). 5. As of the date of filing this Motion, the parties have not responded to the Court's Rule and it appears that none will be forthcoming. WHEREFORE, Movant respectfully requests that this Honorable Court grant her Motion to Make Rule Absolute and grant her leave to withdraw as counsel for Respondent. Respectfully submitted, -..,R L a C. Reyes ,a . ey, Esquire Supreme Court I. 11. ••o. 78075 LAGUNA REYES MALONEY, LLP 1119 North Front Street Harrisburg, PA 17102 (717) 233-5292 2 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TUAN A. NGUYEN, § Plaintiff § v. § NO. 10-3007 DA-PHI PHUONG DAI TANG, § CIVIL ACTION -IN DIVORCE Defendant § CERTIFICATE OF SERVICE I, Laura C. Reyes Maloney, do hereby certify that I served a true and correct copy of the Rule to Show Cause issued on August 14, 2013 upon both parties via first-class U.S. mail, addressed as follows: Mr. Tuan A. Nguyen 120 Lighthouse Dr. Mechanicsburg, PA 17050 Ms. Da-Phi Phuong Dai Tang 120 Lighthouse Dr. Mechanicsburg, PA 17050 August 21, 2013 La . C. Reyes (4iii ey, Esquire COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TUAN A. NGUYEN, § Plaintiff § v. § NO. 10-3007 DA-PHI PHUONG DAI TANG, § CIVIL ACTION - IN DIVORCE Defendant § CERTIFICATE OF SERVICE I hereby certify that on this day I caused a true and correct copy of the Motion to Make Rule Absolute to be served upon the parties via first-class U.S. mail, addressed as follows: Mr. Tuan A. Nguyen 120 Lighthouse Dr. Mechanicsburg, PA 17050 Ms. Da-Phi Phuong Dai Tang 120 Lighthouse Dr. Mechanicsburg, PA 17050 February 11, 2014 11111. L a C. Reyes Qiney, Esquire 3 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TUAN A. NGUYEN, § Plaintiff § v. § NO. 10-3007 DA-PHI PHUONG DAI TANG, § CIVIL ACTION - IN DIVORCE Defendant § ORDER OF COURT AND NOW, this /90ay of , 2014, upon consideration of the Petition for Leave to Withdraw as Counsel and the Motion to Make Rule Absolute, it is hereby ORDERED and DECREED that Laura C.Reyes Maloney,Esquire,is granted leave to withdraw as counsel for Tuan A. Nguyen. BY THE J. i mca -rl - ;-. tom-,. W x - a C/3 r , DISTRIBUTION r- <� 4aura C.Reyes Maloney, Esquire, 1119 N. Front St.,Harrisburg,PA 17102 yP ' CT! .. Tuan A.Nguyen, 120 Lighthouse Dr.,Mechanicsburg,PA 17050 s. Da-Phi Phuong Dai Tang, 120 Lighthouse Dr.,Mechanicsburg,PA 17050 1 /1241.1-F-CE • COMMONWEALTH OF PENNSYLVANIA ri, COURT OF COMMON PLEAS ��o FEB j �}. CUMBERLAND COUNTY, PENNSYLVANIA 4 Pf 2- j P��'1 +,r�t7 C� TUAN A. NGUYEN, § rV L Y�Vq ,� z p` Plaintiff § v. § NO. 10-3007 DA-PHI PHUONG DAI TANG, § CIVIL ACTION - IN DIVORCE Defendant § PRAECIPE TO WITHDRAW APPEARANCE Pursuant to the Order of February 19,2014,please withdraw the appearance of Laura C. Reyes Maloney, Esquire, as counsel for Tuan A. Nguyen, the Plaintiff in the above- captioned case. Respectfully submitted, a C. Reyes : o -y, Esquire Supreme Court I.D. No.: 78075 LAGUNA REYES MALONEY, LLP 1119 North Front Street Harrisburg, PA 17102 (717) 233-5292 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TUAN A. NGUYEN, § Plaintiff § v. § NO. 10-3007 DA-PHI PHUONG DAI TANG, § CIVIL ACTION - IN DIVORCE Defendant § CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Praecipe for Withdrawal of Appearance filed in the above-captioned matter upon the parties,via first-class U.S. mail, addressed as follows: Mr. Tuan A. Nguyen 120 Lighthouse Dr. Mechanicsburg, PA 17050 Ms. Da-Phi Phuong Dai Tang 120 Lighthouse Dr. Mechanicsburg, PA 17050 Date L u C. Reyes ail,ey, Esquire \r. COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TUAN A. NGUYEN, Plaintiff v. DA -PHI PHUONG DAI TANG, Defendant NO. 10-3007 CIVIL ACTION - IN DIVORCE PLAINTIFF'S STATEMENT OF INTENTION TO PROCEED TO THE COURT: Please note that Plaintiff, Tuan A. Nguyen, intends to proceed with the above - captioned matter. December 17, 2014 Respectfully submitted, La C. Reyes Male Esquire Supreme Court I.D. No.: 78075 Attorney for Plaintiff LAGUNA REYES MALONEY, LLP 1119 North Front Street Harrisburg, PA 17102 (717) 233-5292 COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TUAN A. NGUYEN, Plaintiff v. DA -PHI PHUONG DAI TANG, Defendant NO. 10-3007 CIVIL ACTION - IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that I served a copy of the Plaintiffs Statement of Intention to Proceed in the above -captioned matter upon the Defendant via first-class U.S. mail, addressed as follows: December 17, 2014 Ms. Da -Phi Phuong Dai Tang 120 Lighthouse Dr. Mechanicsburg, PA 17050 Lura C. Reyes M:lone Esquire COMMONWEALTH OF PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA TUAN A. NGUYEN, Plaintiff v. DA -PHI PHUONG DAI TANG, Defendant To the Prothonotary: NO. 10-3007 CIVIL ACTION - IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT • Pursuant to Pa.R.C.P. No. 401(b)(1), please reinstate the Complaint in the above - captioned matter. Lira C. Reyes ' alo -y, Esquire Supreme Court I.D. No. 78075 Attorney for Plaintiff LAGUNA REYES MALONEY, LLP 1119 North Front Street Harrisburg, PA 17102 (717) 233-5292