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HomeMy WebLinkAbout05-3071 , , STEVE H. KIM, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. :Jl1J~- 3071 Cl~,'1 SYUNG KIM, Defendant CIVIL ACTION - 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 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, Room 101, Dauphin County Courthouse, Harrisburg, Pennsylvania, 17101 IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA WYER'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 LAWYER REFERRAL SERVICE Court Administrator 4th Floor Cumberland County Courthouse Carlisle, PA 17013 (71 7) 240-6200 , STEVE H. KIM, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CJj'.367/ (!w.; ~ SYUNG KIM, Defendant CIVIL ACTION - DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE TO THE HONORABLE, THE JUDGES OF SAID COURT: AND NOW, comes Plaintiff, Steve H. Kim, by and through his attorney, Gary 1. Kelley, and represents as follows: DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Steve H. Kim, who currently resides at 2 Tumeric Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050 and has resided there in excess of six (6) months. 2. Defendant is Syung Kim, whose last known address is 6348 Berrington Road, Mechanicsburg, Cumberland County, Pennsylvania] 7050 and has resided there in excess of six (6) months. 3. Both Plaintiff and Defendant have been bona fide residents in 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 I, 1997 in Fairfax, Virginia. 5. There have been no prior actions of divorce or for annulment between the parties. 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. WHEREFORE, Plaintiff requests this Court to enter a divorce decree divorcing the parties from the bonds of matrimony. Respectfully submitted, G I 46 01 l119N.Fro eet Harrisburg, PA 17102 (717) 238-1484 Attorney for Plaintiff . . VERIFICATION I verify that the statements made in this Complaint 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 falsification to authorities. _~A1okr~ ,...., <;f. 0 ~ ~..:: :i! ~ ~ <- ~ '- C"- rn~ :;;,:: 7";:: ~ -;J~ :9 ~ <.11 (-:::~ .) :"C :~{ V', P' C)(~ ~ St;;, C> :;1i: -:?;;tn c> 9-::> C ~ C',: Cf? >:-::\ ~ ~ ~~- .r:- J?:; ::.2 :.< <::) ~ - - ~ STEVE H. KIM, Ptaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2005-3071 SYUNG KIM, Defendant CIVIL ACTION - DIVORCE AFFIDA VIT OF CONSENT 1 A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on june 15, 2005.. 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. 1 consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the Decree. 4. I understand that [ may lose rights concerning alimony, division of property, lawyer's fees or expenses if [ 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. Section 4904 relating to nnsworn falsification to authorities. Date IJl0 r STEVE H. KIM, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2005-3071 SYUNG KIM, Defendant CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on june 15,2005.. 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 of the Decree. 4. 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. Section 4904 relating to unsworn falsification to authorities. Date: /I /14/ OtJ" I I /~MIl1drn KlrY} STEVE H. KIM, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2005-3071 SYUNG KIM, Defendant CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE 1. I consent to the entry of a final Decree of Divorce without notice. 2. 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. 3. I understand that I will not be divorced 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 filed with the Prothonotary. I verify that the statements made in this Affidavit are tme and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date old f I STEVE H. KIM, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA v. No. 2005-3071 SYUNG KIM, Defendant CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE 1. I consent to the entry of a tlnal Decree of Divorce without notice. 2. r understand that I may lost: rights concerning alimony, division of property, lawyer's fees or expenses if r do not claim them before a divorce is granted. 3. r understand that I will not be divorced 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 filed with the Prothonotary. 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. Section 4904 relating to unsworn falsification to authorities. Date: III ::fJ-i! 0 i) I I ~ Yl1-kim STEVE H. KIM, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2005-3071 SVUNG KIM, Defendant CIVIL ACTION - DIVORCE CERTIFICATE OF SERVICE I. G8ry L. Kelley, counsel for the Plaintiff in the above matter do hereby certify that 1 served a true and correct copy of the Divorce Complaint in this matter upon the Defendant by an Acceptance of Service executed on June 19, 2005. ., ; l': L 1"( ~,-,' . c-) /j Date _~:~___ I , ..-" >-j- .!~, Gary L. K\:liey 10 No. 46801 1119 North Front Street Harrisburg, P A 17102 (717) 238.1484 Attorney for Plaintiff STEVE H. KIM, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 2005-3071 SYUNG KIM, Defendant CIVIL ACTION - DIVORCE ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint in the above-captioned matter on behalf of the Defendant and hereby certify that I am authorized to do so. ~) 10 los- ~d~~~J 'rrc '.:t ,k 117) Date , ~.- . STEVE H. KIM, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2005-3071 SYVNG KIM, Defendant CIVIL ACTION - DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 330 I (c) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of Service executed by Defendant on June 19,2005. 3. (a) Date of execution of the Affidavit of Consent required by Section 330t(c) of the Divorce Code: by Plaintiff on December 15, 2005; and by Defendant on November 24, 2005. 4. Related claims pending: None. 5. (a) Date plaintiff's Waiver of Notice was filed with the prothonotary: December 15, 2005. .-~ . (b) Date defendant's WaIver of Notice was filed with the prothonotary: December 15,2005. Date ~~_ G Y L. oI1,f!!6 - -- ID N. 6801 l 1119 North Front Street Harrisburg, PA ]7102 (717) 238-1484 Attorney for Plaintiff ,+,'+':+'++ . . . . + . . + . . . . . . . . . . . . . + . . . . . . + . . + + + + + + + + + + + .+ + + + . + + + + + + + + + + + + + . + + + + + + + + . + + + + + + + + + . + + + + + + + + + + + + + + + + . + + + + + +. + + + + + + + + + + + + . + + + + + . + . + . . . + . + + + + . + + . + . . + + + + . + + + + . + . + + + . . '+ :+. :+. + + :+. '+ Of. + 'f. '+' + + :+:+ + :+::+:Of.++ +:+::€Of.:+.:f.:€ .. +;+; + +:€+ 'f.+ + +:+. 'f.:+' + +:+.:+. +:+.:+::+::+.:+.:+. + .. . .. ... . .. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. Steve H. Kim No. 2005-3071 VERSUS Syung Kim DECREE IN DIVORCE AND NOW, Z4. ,.- ,ZA"'> ,IT IS ORDERED AND 7),., - -k- DECREED THAT Steve H. Kim . PLAINTIFF, AND Syung Kim , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. +:+.+:+.+++++:+. + + . . . + . + + . + + + . + + + + + + . + + + . + . . + . . + . + + + . + . + + . . + . + + + THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT None BY THE CO~7t4- d " .~ , ~ "p"a'HO"O""' :+.:+. '+ + . .. :+:'++:+::+:++:+.'++:+: +:+::+. + .. .. .. . :+::+:+++'+:+. . .. :+.:+: '+' + +:+::+: . . J. . /h'? 7 ~;r7W.T?->;J4L. .)(/ ye t=:' WP fp" :2 /fT'.';7W ~/,PP ;?/' LT ~. . . .p,,"'-.