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Home My WebLink About05-2191 BOONEE MOONSUNG SON, Plaintiff IN THE COURT OF COMMON PLE S CUMBERLAND COUNTY, PA v, NO. OS:JICfI CIVIL TERM o ~,;21 q I YUN-SONG LEE, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. If you wish to defend against the clai s set forth in the following pages, you must take prompt action. You are warned that if you f il 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 0 her claim or relief requested in these papers by the Plaintiff. You may lose money or propert or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marr age, you may request marriage counseling. A list of marriage counselors is available in the Of ce of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY F THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB 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 ASSOCIA TION 32 SOUTH BEDFORD CARLISLE, PA 17013 (717) 249-3166 OR (800)990-9108 .. v. IN THE COURT OF COMMON PLE S CUMBERLAND COUNTY, PA NO.())- ..211' CIVIL TERM BOONEE MOONSUNG SON, Plaintiff YUN-SONG LEE, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT 1. Plaintiff is Boonee Moonsung Son, who currently resides at 6111 Springfo d Drive #0-20, Harrisburg, Dauphin County, Pennsylvania. 2. Defendant is Yun-Song Lee, who currently resides at 158-14 Northern B1v ., Flushing, New York. 3. The Plaintiff has been a bona fide resident in the Commonwealth for at Ie t six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 22, 2002, at Manhasset, New York. COUNT I - DIVORCE 5. Paragraphs 1 through 4 of this Complaint are incorporated herein by refere ce as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Divorce is sought pursuant to the provisions of the Divorce Code, ~ 3301(c) and 3301(d), in that: a. The marriage is irretrievably broken. b. Plaintiff and Defendant have lived separate and apart since July 1, 2002, and continue to do so, 8. Plaintiff has been advised that counseling is available and that Plaintiff m have the right to request that the court require the parties to participate in such counseli g. 9. The Plaintiff in this action is a member of the Armed forces. WHEREFORE, the Plaintiff requests the Court to enter a decree of Divorce. COUNT II - EQUITABLE DISTRIBUTION 10. Paragraphs 1 through 9 of this Complaint are incorporated herein by refer nce as though set forth in full. 11. Plaintiff and Defendant have acquired property, both real and personal, du ing their marriage from May 22,2002, until July 1, 2002, the date of their separation, which property is "marital property". 12. Plaintiff and Defendant may have owned, prior to marriage, property whic has increased in value during the marriage and! or which has been exchanged for other property, which has increased in value during the marriage, all of which property is "marit I " property . 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property prior to the filing of this Complaint. WHEREFORE, the Plaintiff requests this Honorable Court to equitably divide all marital property. Respectfully submitted, ABOM & KUTULAKIS, L.L.P. DATE~ lifos !laJij, Kara W. Haggerty' . 36 South Hanover Carlisle, P A 17013 (717) 249-0900 Attorney for Plaintiff ill No. 86914 VERIFICATION r, BOONEE MOONSUNG SON, verify that the statements made in this vorce Complaint are true and correct to the best of my knowledge, information, and bel ef. 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 '2.t AvT~ I j()O$' BOONEE MOONSUNG SON ;r::::, -- ~. v-\ W <><\ v \ o ~ ~ ~ ~, "'. ~ \).) -- G \J (",\ v' ....' .g <.r< ""0 ~ ", -' o ~ --1\':;0': rt1,rf', ~::~,;'-- .-t,' " ~_\.::- L:(~..' ~~,e: Pc:.: "::.<;': :2 \ ~ Q, .~l~ """IT' ../10 .:L 1 ~?lC} ~t'~; ',,':;,(') ~~cn "J:;.... .~ ~ ?' ':.t' '-R c..n o - ---- BOONEE MOONSUNG SON, Plaintiff v. IN THE COURT OF COMMON PLE S CUMBERLAND COUNTY, PA Oj~ ~/'i( NO. CIVIL TERM YUN-SONG LEE, Defendant CNILACTION -LAW IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file counter-affidavit within twenty (20) days after this affidavit has been served on you or th statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on July 1, 2002, and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating t unsworn falsification to authorities. Date: 1.-l- (dpr: \ )s.)O';' ~ BOONEE MOONSUNG SON Q (:'~ :;; M q.. ~ 'f}. ~ .-n ~ t\~~ ~ ~1 t", S:,,), - "'--t"'l 't,:)~ -c) -;~((\ S\ 'V :;1 ~~- "> ..f! ~ -o..:~c 1)j\,:C,' ~r 'f"y '-!.t:. ,< ,-;:,,_. L.(, ~..,-" be: y';? ?. , v. IN THE COURT OF COMMON PLE S CUMBERLAND COUNTY, PA NO. t)5- .2 JC1 (CIVIL TERM BOONEE MOONSUNG SON, Plaintiff YUN-SONG LEE, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER $3301(d) OF THE DIVORCE CODE TO: YUN-SONG LEE You have been sued in an action for divorce. You have failed to answer the campI int or file a counter-affidavit to the ~3301(d) affidavit. Therefore, on June 11,2005, the other party can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the court an answer with your signatur notarized or verified or a counter-affidavit by the above date, the court can enter a final de ree in divorce. A counter-affidavit which you may file with the Prothonotary of the court is attached to this notice. Unless you have already filed with the court a written claim for economic relief, yo must do so by the above date or the court may grant the divorce and you will lose forever e right to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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 CARliSLE, PA 17013 (717) 249-3166 OR (800)990-9108 I verify that the statements made in this affidavit are true and correct. I understa d that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relatin to unsworn falsification to authorities. Date: ~).(JUS- ~/\~ BOONEE MOONSUNG SON BOONEE MOONSUNG SON, Plaintiff IN THE COURT OF COMMON PL S CUMBERLAND COUNTY, PA v. NO. CIVIL TERM YUN-SONG LEE, Defendant CIVIL ACTION - LAW IN DIVORCE COUNTER AFFIDAVIT UNDER ~ 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): o (a) I do not oppose the entry of a divorce decree. o (b) I oppose the entry of a divorce decree because (Check (i), (ii) or both) o (i) The parties to this action have not lived separate and apart for a period of at least two years. o (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): o (a) I do not wish to make any claims for economic relief. I understand th t I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. o (b) I wish to claim economic relief which may include alimony, division property, lawyer's fees or expenses or other important rights. I understand that in addition to check (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do before the date set forth on the Notice of Intention to Request Divorce Decree, the divorc decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~490 relating to unsworn falsification to authorities. Date: YUN-SONG LEE (1 (:;, ~c,:, -'0 (~.\ ('f;,\ , .~{,~ ;:>'- '0~~~:; c.\....- ~....., -r.- ~~.,.:. . b'c: Y _i :1 ~ ~ ~ ~~ ?:l ~.'i2 ~ ("'..) ,~~. --l _C"" .-'n --:~)F_") (;:::::"'1"(\ D -~'..... 1r) ';4 ~ ..p .' <.fI c:P _. ,~"..,~ ,~. "~U.!". ,.,..., < ,.........~ ()s- ~{q ( Registered No. 2005 - 6041 NOTARIAL CERTIFICATE SOGONG LAW AND NOTARY OFFICE 35, Bukchang-Dong, Chung-Ku, Seoul, Korea llHf~~ ~ 111111'-1 Or? ,{}Ul~~ '{}1tl~i!l^1@~ ~* lfl ~ llJ ~rJ1- llJ~ro1 ;!-~%S!l ~ {}5oJ'tl .lJly,~-lt-"'ll 1lJ {} >'J OJ 01%"'~ "''''''''"'"'11 _. ~ . 01 -c. ~~ .-\-\71 Z005\! 5~ 60.1 .i..~ 10.J,1 40* 1lJ{}5oJ'li ol%"'J ol~~i'-~~~ plll'~~ 'tl"'t~i'- 01~'tl-i- ~13301(d)iiJ- '}! ~330l~ojlS1~ o!~ {}5oJ:W-)(!.-\-\oJ! -qJ~ 0!S1{}5oJ.-\-\~ ~~iil {j~-at':l~ ~ ~u.l%. ~*OJA .-\-j71Z005\! 5~ 6'l! ~*)(t ~~"'J kJ~~~.I.! "t~T i'-~T 13't!.)(1 2* ~:iJ- 1588-1148 01O-8Z13-0011 " BOONEE MOONSUNG SON, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNIT, P A NO. OS:-.2/ q / CIVIL TERM YON-SONG LEE, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I hereby certify that I did personally serve a true and correct copy of the Complaint in Divorce, Notice of Intention to Request Entry of a Divorce Decree Under ~3301 (d) of the Divorce Code and Affidavit Under Section 3301(d) of the Divorce Code in the above-captioned case upon the defendant, Yun-Song Lee on the ~day of M.1 ,2005, at ,,,, 4-t\M. ..', .H~i' i:",,:, "";;':'~~:::':'::;I Respectfully submitted, DATE -6 bJ."M lOot) \ NAME 1r4-'a ' \(,w-. , J"" {7vf (i'vt ADDRESS ~1"'tJ,J~,,,\ ~'t.t ~~{: l>'~21 )6 5, .L.J S"'j' K~ cr,^ 5o~ 1,)';0\ Jou I:'::, ..l'~~ ~\. PHONE \ 7~~' t\ ~ ~ (Jlu - Y/U ~. CUll . SOGONG LAW AND NOTARY OFFICE .<f1 18Qoj~~ -%l~3l} %.<f1\'l:l.i~ ~ ^i '2fwLJ r:j- . I swear that the attached translation is true to the original. 2005\:1 5~ 10~ May 10, 2005 ^i '2f~ :) \~ ;;;7\ -?--"Xa.. 0"- CJ ~cl "~ }/~JI)'Un' ~u6 Signature HAN, HYUNG-HYUB eel a. 2005';1 ~l 6041 ~ Registered No. 2005 -6041 01 c ::;z.. 0' Notarial Certificate .<f1 ~t>J~;: ~31 ~1J.oJl^i .<f1 18Qoj~ol'll" J).~.g. ,,1 A} 01 ol.Q...Q.. "'1.01 i>1.:JJ.""JM.0)i.Ji6P' L.:. l.!.- -'-'f d -r1 'W- p '2. ~ 1....:. r __ ~"_'; ^i ~ 'i' 'Zl i>} 9J. r:j- . HAN, HYUNG-HYUB personally appeared before me, confirmed that the attached translation is true to the original and subscribed his (her) name. 2005 'd 5~ 10~ This is hereby attested on this 10th day of May 2005 at this office. 0] ^1--'i'-J::oJ]^l ~ ~~~t:}, .:g."6-~7l- ~.:g.~%'il~^l-!f-~ ^i%~ ~^l %-1'- ~%% 351tlAl SOGONG LAW AND NOTARY OFFICE 35,Bukchang-Dong,Chung-Ku,Seoul,Korea -t'-~'E''if1i!!~^} ,~:;e,=~ ~~ 'if) r.':"'-"':1m,',' /', F' " (/ ~" . i::" "' "IV'>, ,I' " " "c,>_,_, , ",-,' "',<-"-, ( I~jji;;i;.!itm)l'~" ~jW tf;;.....~, " Attorney-at-Law NAM-KYU LEE ~'\ / .. ::.:': i. \ ~>~~~ -- )0\.'-"- j" .' ,.'-::'~T~'~;:; ~ , ~ ~ This office has been authorized by the Minister of Justice, the Republic of Korea to act as Notary Public since October 12, 1974 under Law No.2254. , '> , . BOONEE MOONSUNG SON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. NO. oS~ 2.lq I CIVIL TERM CIVIL ACTION - LAW IN DIVORCE YON-SONG LEE, Defendant AFFIDAVIT OF SERVICE I hereby certify that I did personally serve a true and correct copy of the Complaint in Divorce, Notice of Intention to Request Entry of a Divorce Decree Under ~3301 (d) of the Divorce Code and Affidavit Under Section 3301 (d) of the Divorce Code in the above-captioned case upon the defendant, Yun-Song Lee on the ~daY of t\j ,2005, at ~~,~ 4t\M. Respectfully submitted, D~~ -6 ~M l.t>ot; \ ~l~E 7J,~'0 ,K~"",, :)IA'" r;"'f (ftIV AbbRESS ,.(~:1;I~A ~'t ~~~ \~'~!:21 '}g, 5~ jO"\V~D &'" So~tJe"l \:)U(j I~ .),.J S\. PHONE \7t~- t\ ~ ~ Olu - 'bl-l? - oU/l g .~ ""Ocr} nllt. Z':c '~:Y ( t1 }~~ -<.,., t.2. (.~ :F;G ~u ,pC ~ ~ ~ '5'\ ~ -;;e. I c..;> -Q ~ ~ o Cl) ~-T'1 n1f': -CJC ~6 :i~-':;:.\ f::;--:::" Z:?f, Q -'" "r:- .,~ -. -<. BOONEE MOONSUNG SON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A v. NO. 05-2191 CIVIL TERM YON-SONG LEE, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT THE RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground(s) for divorce: irretrievable breakdown under ~3301(d)(1) of the Divorce Code. 2, Date and manner of service of the Complaint: Affidavit of Service of Divorce Complaint indicating personal service on May 6, 2005, and filed with the Prothonotary on June 3, 2005. 3. Complete either paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by ~3301 (c) of the Divorce Code: by Plaintiff N / A; by Defendant N / A. (b)(1) Date of execution of the Affidavit required by ~3301(d) of the Divorce Code: April 27. 2005; (2) Date of filing and service of the Plaintiff's affidavit upon the Respondent: filed April 27. 2005 and served May 6. 2005. 4. Related claims pending: NONE, 5. Complete either paragraph (a) or (b): (a) Date and manner of service of the Notice of intention to file Praecipe to Transmit Record, a copy of which is attached: May 6, 2005, by personal semce. (b) Date Plaintiffs Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: N / A Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: N / A. Respectfully submitted, ABOM & KUTULAKlS, L.L.P DATE...Q1J 22/ D5 ~(O~ Kara W. Haggert~, quir;' 36 South Hanover' treet Carlisle, Pennsylvania 17013 (717) 249-0900 Attornry for Plaintiff ID #86914 BOONEE MOONSUNG SON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA v. NO. 05-2191 CIVIL TERM YUN-SONG LEE, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO WITHDRAW AND DISMISS TO THE PROTHONOTARY: Please withdraw and dismiss Plaintiff's count for Equitable Distribution in the above-referenced divorce action, Respectfully submitted, ADOM & KUTULAKI5, L.L.p. I)ate: ~ I~D Kara W. Haggerty, e 36 South Hanover Street Carlisle, P A 17013 (717) 249-0900 Attomry for Plaintiff BOONEE MOONSUNG SON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A v. NO. 05-2191 CIVIL TERM YUN-SONG LEE, Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVI~ AND NOW, this 23IUJ day of September, 2005, I, Kara W, Haggerty, Esquire, by and through ABOM & KUTULAKIS, L.L.P. hereby certify that I did serve a true and correct copy of the foregoing Praecipe to Withdraw and Dismiss, upon the below listed counsel of record and/or parties by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Yun-Song Lee c/o Young Min Kim Y 00 and Kim, PC 39-01 Main Street, Suite 607 Flushing, NY 11354 Date: September 23, 2005 ADOM & li7JTULAKIS, L.L.P. (~) Kam W. Haggerty ;,.' " > Q. ;;,,, ~ ~-<:I U' t-n?" ~ 1)~, ~ (~Sr, c..;> :C.' cD ~ <~-~ -::;; C?,. '-? ?i s::- .p o c: . RECEl'/EO S:P 2 S ~005'r' roo' - - d"'~ G3' '3"3\1 ~':'(l:.j HI..J a . . . . . . IN THE COURT OF COMMON PLEAS . . OF CUMBERLAND COUNTY STATE OF . BOONEE MOONSUNG SON Plaintiff . . . . VERSUS . YITN-SONG LFF . . Defendant . . . . . . . . AND NOW, DECREED THAT . . AND . . . . . . PENNA. No. 05-2191 CIVIL DECREE IN DIVORCE ~)7 ~~ )::1lf.wt , , IT IS ORDERED AND BOONEE MOONSUNG SON , PLAINTIFF, YON-SONG LEE , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY, . . . . . THE COURT RETAINS JURISDICTION OF THE FOL.LOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; . . . . . . . . . . . . . . . . . . . . . . . . . . . ,J iN G By PROTHONOTARY . . :f.'f 'f Of' :E . ~. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . J. . . . . .' .;k t: ~?"'" -'~. 2C" · ~4J fP' I! rr- J..w I"'J 5P' se. . ..... s - RCCE"'-CI C"~ " ~ , cs,IL . ~ '" i:..; "~i ~ '0 ,3 'y1'\ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA BOONEE MOONSUNG SON, Plaintiff v. NO. 05-2191 CIVIL TElThi YUN-SONG LEE, Defendant CIVIL ACTION - LAW IN DIVORCE ORDER OF COURT AND NOW, upon consideration of the attached Praecipe to Withdraw and Dismiss, it is hereby ordered that Plaintiff's count for Equitable Distribution is withdrawn and dismissed. J. viara W. Haggerty, Esquire ABOM & KUTULAKIS, L.L.P. 36 South Hanover Street Carlisle, P A 17013 ~n-Song Lee c/o Young Min Kim Y 00 and Kim, PC 39-01 Main Street, Suite 607 Flushing, NY 11354 ~?~ ~J! ~r- o vlN~l!ClASNN3d "Ni""- ^'" ., "W'UN' /U,. ,r,./,1 , ! ~. ':_':.' i::;1 ,~! kJ IS :2 ~~d L"G d3S SOOl AblllONOHJCJUd 3Hl :10 3JllJO-C13ll:J - BOONEE MOONSUNG SON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A v, NO. 05-2191 CIVIL TERM YUN-SONG LEE, Defendant CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO WITHDRAW AND DISMISS TO THE PROTHONOTARY: Please withdraw and dismiss Plaintiff's count for Equitable Distribution in the above-referenced divorce action. Respectfully submitted, ADOM & KUTULAKI5, L.L.P. Date:~ ..~. Kara W. Haggerty, uire 36 South Hanover Street Carlisle, P A 17013 (717) 249-0900 Attornry for Plaintiff -. BOO NEE MOONSUNG SON, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, P A v. NO. 05-2191 CIVIL TERM YUN-SONG LEE, Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 23RD day of September, 2005, I, Kara W. Haggerty, Esquire, by and through ABOM & KUTULAKIS, L.L.P. hereby certify that I did serve a true and correct copy of the foregoing Praecipe to Withdraw and Dismiss, upon the below listed counsel of record and/or parties by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following: Yun-Song Lee c/o Young Min Kim Y 00 and Kim, PC 39-01 Main Street, Suite 607 Flushing, NY 11354 Date: September 23, 2005 ADOM & KUTULAKI5, L.L.P. (~ Kara W. Haggerty .~ n ......' ~ = G = cJ' " <', ~." f"q " n1r-..; f''> -om ~.n\::;:; w C~(":) , .,~ -I' -n ;;,:s:D ~ ~ ',_0 , , (jrn '...- Y? ",-I J<.:~ S; :~ r u:> -<