HomeMy WebLinkAbout06-4262
DEBORAH L. CHIN,
Plaintiff,
VS.
KAYON R. CHIN,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
:NO. D(o- a(71 U ?, I erg
: 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 action. You are warned that, if you fail to do so, the
case may proceed without you and a decree of divorce or annulment 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 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, Cumberland County Courthouse, One Courthouse Square, 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.
LAWYER REFERRAL SERVICE
of the Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
Telephone (800)-990-9108
DEBORAH L. CHIN,
Plaintiff,
VS.
KAYON R. CHIN,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO.
: CIVIL ACTION - LAW
: IN DIVORCE
AVISO PARA DEFENDER Y RECLAMAR DERECHOS
USTED HA SHOO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas
expuestas en las paginas seguientes, debe tomar accion con prontitud. se le avisa que si no se
defiende, el caso pude proceder sin usted y decreto de divorcio o anulamiento puede ser emitido
en su contra por las Corte. una decision puede tambien ser emitida en su contra por caulquier
otra queja o compensacion eclamados por el demandante. Usted puede perder dinero, o
propiedades u otros derechos importantes para usted.
Cuando la base para el divorcio es indignidades o rompimiento irreparable del
matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales
esta disponible en la oficina del Prothonotary, en la Cumberland County, One Courthouse
Square, Carlisle, PA 17013.
SI USTED NO RECLAMA PENSION ALIMENTICIA, PROPIEDAD MARITAL,
HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO
FINAL DE DIVORCIO O ANULAMIENTO SEA EMTIDO, USTED PUEDE PERDER
EL DERECHO A RECLAMAR CUALQUIERA DE ELLOS.
USTED DEBE LEVAR ESTE PAPEL A UN ABOGADO DE INMEDIATO. SO
NO TIENE O NO PUEDE PAGAR UN ABOGADO, VAYA O LLAME A LA OFICINA
INDICADA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER ASISTENCIA
LEGAL.
LAWYER REFERRAL SERVICE
of the Cumberland County Bar 4ssociation
32 South Bedford Street
Carlisle, PA 17013
Telefono (0o)-990-919.0
DEBORAH L. CHIN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
VS. :NO. D G - y.2 L .L
KAYON R. CHIN, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW, comes Plaintiff, Deborah L. Chin, by and through his counsel, Linda A.
Clotfelter, who files this Complaint in Divorce and in support thereof states the following:
1. Plaintiff is Deborah L. Chin, (hereinafter "Plaintiff) an adult individual who
resides at 5252 Meadowbrook Drive, Mechanicsburg, Cumberland County, PA 17050.
2. Defendant is Kayon R. Chin, (hereinafter "Defendant"), adult individual who
resides at 5252 Meadowbrook Drive, Mechanicsburg, Cumberland County, PA 17050.
COUNTI
REQUEST FOR DIVORCE UNDER SECTIONS
3301(C) OR 3301(D) OF THE DIVORCE CODE
3. Paragraphs 1 and 2 are incorporated herein by reference as if fully set forth.
4. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for
at least six (6) months immediately previous to the filing of this divorce Complaint.
5. Plaintiff and Defendant were married on June 22, 1990 in Lakewood, Jefferson
County, Colorado.
6. The parties have been separate and apart within the meaning of the Pennsylvania
Domestic Relations Code since May 14, 2006.
7. There are no pending divorce proceedings upon the filing date of this Complaint.
8. Defendant is not a member of the armed forces of the United States or any of its
allies.
9. Plaintiff avers that the marriage is irretrievably broken.
10. Plaintiff has been advised of the availability of counseling and that Plaintiff may
have the right to request that the court require the parties to participate in counseling. Plaintiff
does not desire counseling.
WHEREFORE, Plaintiff respectfully requests that this Court enter a Decree of Divorce
and grant such other relief as this Court deems just and proper.
COUNT H
EQUITABLE DISTRIBUTION
11. Paragraphs 1 through 10 of this Complaint are incorporated herein by reference.
12. During their marriage, Plaintiff and Defendant have acquired various items of
marital property, which are subject to equitable distribution under Sections 3501 et.sea. of the
Divorce Code of 1980.
13. Plaintiff and Defendant have been unable to amicably agree upon the equitable
distribution of the marital property.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter a decree
for divorce; enter an order of court equitably distribute all marital property owned by the parties;
and grant such other relief as this Court deems just and proper.
Respectfully submitted,
Date: ?T V
LAW FIRM OF LINDA A. CLOTFELTER
L' da A. Clotfelter, Esquire
A orney ID No. 72963 0
1 East Trindle Road, Suite 100
Mechanicsburg, PA 17050
(717) 796-1930 telephone
(717) 796-1933 facsimile
Attorney for Plaintiff
DEBORAH L. CHIN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : NO.
KAYON R. CHIN, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
VERIFICATION
I, DEBORAH L. CHIN, verify that the statements in the foregoing COMPLAINT IN
DIVORCE 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 unswom falsification to authorities.
Date: 7 I9 6l, 'J k x
DEBORAH L. CHIN, Plaintiff
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DEBORAH L. CHIN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
VS. : N0424262- n o
KAYON R. CHIN,
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CERTIFICATE OF SERVICE cn
AND NOW, this 7 h day of August, 2006, the undersigned hereby certifies that a true and
correct copy of the foregoing DIVORCE COMPLAINT was served upon the opposing parry by
United States First Class Mail, postage prepaid:
Kayon R. Chin
P.O. Box 65101
Harrisburg, Pa 17106-2101
Respectfully submitted,
LAW FIRM OF LINDA A. CLOTFELTER
A. Clotfelter, Esquire
ev ID No. 72963
3921 East Trindle Road, Suite 100
Mechanicsburg, PA 17050
(717) 796-1930 telephone
(717) 796-1933 facsimile
Attorney for Plaintiff
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DEBORAH L. CHIN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff, : CUMBERLAND COUNTY, PENNSYLVANIA
vs. :NO. 421Q2.
KAYON R. CHIN, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
AFFIDAVIT OF SERVICE
I, Linda A. Clotfelter, Esquire, counsel for Deborah L. Chin, do hereby affirm that the
original return receipt of the Divorce Complaint which was served upon Kayon R. Chin and
signed on August 4, 2006, sent by Certified Mail, Restricted Delivery, Return Receipt
Requested, and which return receipt appears to contain the signature of Kayon R. Chin, is set
forth below. The undersigned understands that the statements herein are made subject to the
penalties of 18 P.S. § 4904 relating to unworn falsification to authorities.
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Respectfully submitted,
LAW OFFICE OF LINDA A. CLOTFELTER
Dated:
4daCIotfelter, Esquire
mey ID No. 72963
East Trindle Road, Suite 100
Mechanicsburg, PA 17050
(717) 796-1930 telephone
(717) 796-1933 facsimile
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DEBORAH L. CHIN,
Plaintiff
V.
KAYON R. CHIN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
"a
NO. 06 4269 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please enter the appearance of Keith 0. Brenneman, Esquire of Snelbaker & Brenneman,
P. C. as attorney for Defendant Kayon R. Chin in the above-captioned action.
SNELBAKER & BRENNEMAN, P. C.
BY:
Keith 0. Brenneman, Esquire
44 W. Main Street
Mechanicsburg, PA 17055
Date: August 18, 2006 (717) 697-8528
Attorneys for Defendant Kayon R. Chin
_XN OFFICES
SNELSAKER &
BRENNEMAN, P.C.
CERTIFICATE OF SERVICE
I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have on the below date,
caused a true and correct copy of the foregoing Praecipe to be served upon the person and in the
manner indicated below:
FIRST CLASS MAIL. POSTAGE PREPAID. ADDRESSED AS FOLLOWS:
Linda A. Clotfelter, Esquire
5021 East Trindle Road
Suite 100
Mechanicsburg, PA 17050
Keith O. Brenneman, Esquire
SNELBAKER & BRENNEMAN, P. C.
44 W. Main Street
P. O. Box 318
Mechanicsburg, PA 17055
(717) 697-8528
Date: August 18, 2006
LAW OFFICES
SNELBAKER &
BRENNEMAN, P.C.
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DEBORAH L. CHIN
vs Case No. 06 - 4262
KAYON R CHIN
Statement of Intention to Proceed
To the Court:
Linda A C1 at f e 1 t er , 'Esquire intends to proceed with the above captioned matter.
PrintNameLinda A. Clotfelter Sign Name kJ 11
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Date: 9 O -! Attorney f o r eborah L . Chin, pl a i nt i f f
Explanatory Comment
The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of
inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit
comment.
1. Rule of civil Procedure
New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the
scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously
governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2 is
tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting
local rules.
This rule was promulgated in response to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 360,710 A.2d
1104 (1998) in which the court held that "prejudice to the defendant as a result of delay in prosecution is required
before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 1901."
Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The
general policy of the prompt disposition of matters set forth in subdivision (a) of that rule continues to be applicable.
II Inactive Cases
The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the
court. After giving notice of intent to terminate an action for inactivity, the course of the procedure is with the parties.
If the parties do not wish to pursue the case, they will take no action and "the Prothonotary shall enter an order as of
course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter, he or she
will file a notice of intention to proceed and the action shall continue.
a Where the action has been terminated
If the action is terminated when a party believes that it should not have been terminated, that party may proceed
under Rule230(d) for relief from the order of termination. An example of such an occurrence might be the termination
of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file
the notice of intention to proceed.
The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of
the entry of the order of termination on the docket, subdivision (d)(2) provides that the court must grant the petition and
reinstate the action. If the petition is filed later than the thirty-day period, subdivision (d)(3) requires that the plaintiff
must make a show in to the court that the petition was promptly filed and that there is a reasonable explanation or
legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of
termination on the docket and for the failure to file the petition within the thirty-day period under subdivision (d)(2).
B. Where the action has not been terminated
An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may
have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue the remedy of a
common law non pros which exits independently of termination under Rule 230.2.
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OF THE PROT", 40TARY
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DEBORAH L. CHIN,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2006-4262
KAYON R. CHIN,
TO THE COURT:
Defendant
STATEMENT OF INTENTION TO PROCEED
Defendant Kayon R. Chin intends to proceed with the above-captioned matter.
SNELBAKER & BRENNEMAN, P. C.
Date: October 5, 2009
By:
Keith O. Brenneman, Esquire
44 W. Main Street
Mechanicsburg, PA 17055
(717) 697-8528
Attorneys for Defendant Kayon R. Chin
LAW OFFICES
SNELBAKER &
BRENNEMAN, P.C.
CERTIFICATE OF SERVICE
I, KEITH O. BRENNEMAN, ESQUIRE, hereby certify that I have, on the below date,
caused a true and correct copy of the foregoing Statement to be served upon the person and in the
manner indicated below:
FIRST CLASS MAIL POSTAGE PREPAID ADDRESSED AS FOLLOWS:
Linda A. Clotfelter, Esquire
5021 East Trindle Road
Suite 100
Mechanicsburg, PA 17050
SNELBAKER & BRENNEMAN, P.C.
By:
Keith O. Brenneman, Esquire
44 W. Main Street
P. O. Box 318
Mechanicsburg, PA 17055
(717)697-8528
Attorneys for Defendant Kayon R. Chin
Date: October 5, 2009
LAW OFFICES
SNELBAKER &
BRENNEMAN, P.C.
FILED-C?+ICE
OF THE RROTH NOTARY
2009 OCT -5 PH 12: 19
PEWYIVAW.
DEBORAH L. CHIN,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
vs. 4 a ~Z,
KAYON R. CHIN, N0.2~6'~'~ 20
Defendant
MOTION FOR APPOINTMENT OF MASTER
Karon R. Chin, Defendant ,moves the court to appoint a master with respect to
the following claims:
~X Divorce OX Distribution of Property
^ Annulment ^ Support
^ Alimony ^ Counsel Fees
^ Alimony Pendente Lite ^ Costs and Expenses
and in support of the motion states:
I. Discovery is complete as to the claims (s) for which the appointment of a master is requested.
2. The defendant has appeared in the action (personally) (by his attorney,_
Keith O. Brenneman ,Esquire).
3. The staturory ground (s) for divorce ere
Section 3301(c) or Section 3301(d).
4. Delete the inapplicable paragraph (s): A ~ B ® C ^
a. The action is not contested. ~""~ ~'
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b. An aereement has been reached with respect to the followine claims: ~ ---
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C. The action is contested with respect to the following claims: ~`~'
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Equitable distribution ._,~ - ~ -"~
5. The action does not involve complex issues of law or fact. = a '°'"' ~''
6. The hearing is expected to take four (a) bows Vi=a gyp,
7. Additional information, if anv, relevant to the motion: - -
Date: October t 1, 2010
Attorney for Defendant
Keith O. Brenneman
Print Name
ORDER APPOINTING MASTER
AND NOW
20 ,
is appointed master with respect to the following claims:
By the Court,
Esquire,
7.
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DEBORAH L. CHIN,
Plaintiff
VS.
KAYON R. CHIN,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVAN.
NO. 06-4262
CIVIL ACTION - LAW
IN DIVORCE
Prior Judicial Assignment: None
rn ai C_
Concurrence - Counsel for Defendant, Keith O. Brenneman, Esquire, presumably d of r -
concur with this Motion.
- Respondent/Plaintiff, Deborah L. Chin has been non-responsive to nd& so -v
we presume she does not concur with this Motion.'
PETITION TO WITHDRAW APPEARANCE
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1. Petitioner is Linda A. Clotfelter, Esquire, (hereinafter "Petitioner") counsel ?f
record for Plaintiff, Deborah L. Chin.
2. Respondent is Deborah L. Chin, (hereinafter "Respondent"), Plaintiff in
above-captioned matter.
3. Petitioner and Respondent have reached an impasse in their
relationship.
4. Petitioner asks to be released from this case to permit her to devote her time
other clients.
5. Petitioner, a sole practitioner will face significant hardship if her request
withdraw as counsel is denied.
6. Denying Petitioner's request to withdraw as counsel will further
damage Petitioner and her business.
7. It is presumed that opposing counsel, Keith Brenneman, Esquire does not conc4
with this request as he was non-responsive to correspondence seeking concurrence.
8. Petitioner sought Respondent's concurrence/nonconcurrence during a
telephone conversation but she would not take a position on either. She was to provide a
response but Petitioner has not heard from Respondent.
9. There are currently no proceedings scheduled in this case, but a Motion
Appoint Divorce Master was filed by Defendant's counsel October 11, 2010. No Order
Appointment was entered.
10. Petitioner now seeks leave of court to immediately withdraw as counsel
Respondent in this proceeding.
WHEREFORE, Petitioner respectfully requests the Court grant her leave to withdraw
appearance on behalf of Deborah L. Chin and terminate her representation of Deborah L. Chin.
Respectfully submitted,
LAW FIRM OF LINDA A. CLOTFEL
Date: 14 Q 1,6
L DA A. CLOTFELTER, Esquire
A orney I.D. 72963
-3021 E. Trindle Road, Suite 100
Mechanicsburg, PA 17050
(717) 796-1930 telephone
(717) 796-1933 facsimile
DEBORAH L. CHIN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA.
VS. : NO. 06-4262
KAYON R. CHIN, : CIVIL ACTION - LAW
Defendant : IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this day of July, 2012, the undersigned hereby certifies that a
and correct copy of the foregoing PETITION TO WITHDRAW APPEARANCE was
upon the interested parties by United States First Class Mail, addressed as follows:
Keith Brenneman, Esquire
44 West Main Street
Mechanicsburg, PA 17055
(Attorney for Defendant)
Deborah L. Chin
5252 Meadowbrook Drive
Mechanicsburg, PA 17050
(Respondent)
Respectfully submitted,
LAW FIRM OF LINDA A. CLOTFELTER
L da A. Clotfelter, Esquire
orney ID No. 72963
021 East Trindle Road, Suite 100
Mechanicsburg, PA 17050
(717) 796-1930 telephone
(717) 796-1933 facsimile
D AH L. CffiN, : IN THE COURT OF C+IlMMM FLUS OF
CU 49BRULAND COUN TY, P1T4M Y"T.VAM1A
vs. : NO. 964262 c
KAYON IL CMN, : CIVIL ACTION - LAW M
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AND NOW this day of 2012, upon consideration of the
Petition of Linda A. Clotfelter, Esquire, to withdraw as counsel for the Plaintiff, a Rule is issued
upon all parties to show cause why the Petition should not be granted, returnable oW 0 days
from date of service.
BY THE COURT:
? Linda A. Clotfelter, Esquire, 5021 E. Trindle Road, Suite 100, Mechanicsburg, PA 17050,
Attorney for Plaintiff
Keith Fie, 44 W. Main Sftet, Mechanicsburg, PA 17055, Attorney for
Delendamt
/ Deborah L. Chin, 5252 Mea&mbrook Drive, Mechanicsburg, PA 17050, Respondent
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DEBORAH LC?, ?2 AM ?, ; ?Q
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VS.
KAYON R. CHIN,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVAN
: NO. 06-4262
: CIVIL ACTION - LAW
: IN DIVORCE
AFFIDAVIT OF SERVICE
I, Linda A. Clotfelter, Esquire, do hereby affirm that the Rule dated July 26, 2012,
copy of which is attached) was sent by United States First Class Mail, postage prepaid, addres,
as follows. The undersigned understands that the statements herein are made subject to
penalties of 18 P.S. § 4904 relating to unworn falsification to authorities.
Keith Brenneman, Esquire
44 West Main Street
Mechanicsburg, PA 17055
(Attorney for Defendant)
Dated: -73 A O I
Deborah L. Chin
5252 Meadowbrook Drive
Mechanicsburg, PA 17050
(Respondent)
Respectfully submitted,
LAW OFFICE OF LINDA A. CLOTFELTER
L da A. Clotfelter, Esquire
A orney ID No. 72963
21 East Trindle Road, Suite 100
Mechanicsburg, PA 17050
telephone (717) 796-1930
facsimile (717) 796-1933
Attorney for Plaintiff
BY THE COURT:
J.
DEBORAH L. CHIN,
Plaintiff
VS.
KAYON R. CHIN,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 06-4262
CIVIL ACTION - LAW .?._,
IN DIVORCE `--
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2012, upon consideration of
AND NOW this C2day of
Petition of Linda A. Clotfelter, Esquire, to withdraw as counsel for the Plaintiff. a Rule is iss
upon all parties to show cause why the Petition should not be granted, returnable --;zy
from date of service.
Distribution:
Linda A. Clotfelter, Esquire, 5021 E. Trindle Road, Suite 100, Mechanicsburg, PA 17
Attorney for Plaintiff
Keith Brenneman. Esquire, 44 W. Main Street, Mechanicsburg, PA 17055. Attorney
Defendant
Deborah L. Chin, 5252 Meadowbrook Drive. Mechanicsburg, PA 17050, Respondent
TRUE COPY FROM RECORI
In Testimony whereof, l here unto set my
and the seal of said at artisle, Pa.
This day of 201
Prothon
DEBORAH L. CHIN, : IN THE COURT OF COMMON PLEAS OF
plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
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~s. : No..oz.a~--
KAYON R. CHIN, :CIVIL ACTION -LAW
Defendant : IN DIVORCE
Prior judicial assignment: None ~~ ~ "'
Concurrence/Nonconcurrence: See paragraph 3 below ~~ N
PETITIONER'S MOTION TO MAKE RULE ABSOLUTE <® -v ~,~~
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Linda A. Clotfelter, Esquire, filed a Pet
Petitioner
2012
On July 24
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Withdraw Appearance and on July 26, 2012, a Rule was issued upon Plaintiff to show cause w y
the relief requested should not be granted.
2. On July 31, 2012, Petitioner served Plaintiff with the Rule to show cause on the
Petition to Withdraw Appearance and terminate representation as Plaintiff "s counsel.
As per the Rule dated July 26, 2012, the 21-day return date was passed without
answer by Plaintiff, and Petitioner now seeks to have the Rule made absolute.
WHEREFORE, Petitioner respectfully requests the Court to make the Rule absolute
to grant her permission to withdraw as counsel for Plaintiff, Deborah L. Chin, in the above-
captioned proceeding.
Date: $ h7 1
Respectfully submitted,
LAW FIRM OF LINDA A. CLOTFEL'
da ~.~Clotfelter, Esquire
ttorney ID No. 72963
5021 East Trindle Road, Suite
Mechanicsburg, PA 17050
(717) 796-1930 telephone
(717) 796-1933 facsimile
DEBORAH L. CHIN,
Plaintiff
vs.
KAYON R. CHIN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 02-4262
'~
:CIVIL ACTION -LAW ~I
IN DIVORCE '~
VERIFICATION
I, Linda A. Clotfelter, Esquire, verify that the statements in the foregoing Peti
Rule to Make Motion Absolute are true and correct to the best of my knowledge,
and belief. I understand that false statements herein are made subject to the penalties of 18
C.S. § 4904, relating to unsworn falsification to authorities.
Date:
L da A. Clotfelter, Esquire
orney ID No. 72963
021 East Trindle Road, Suite 1
Mechanicsburg, PA 17050
(717) 796-1930 telephone
(717) 796-1933 facsimile
s
DEBORAH L. CHIN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANL~A
vs. : NO. 02-4262
KAYON R CHIN, :CIVIL ACTION -LAW
Defendant : IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this h ~~ day of , 2012, the undersigned hereby
that a true and correct copy of the foregoing Petitioner's Motion to Make Rule Absolute
served upon the opposing party by United States First Class Mail, postage prepaid, addressed
follows:
Keith Brenneman, Esquire
44 West Main Street
Mechanicsburg, PA 17055
(Attorney for Defendant)
Deborah L. Chin
5252 Meadowbrook Drive
Mechanicsburg, PA 17050
(Respondent)
Respectfully submitted,
LAW FIRM OF LINDA A. CLOTFELTER
L da A. Clotfelter, Esquire
orney ID No. 72963
021 East Trindle Road, Suite 1
Mechanicsburg, PA 17050
(717) 796-1930 telephone
(717) 796-1933 facsimile
r
DEBORAH L. CHIN, : IN THE COURT OF COMMON PLEAS OF
p~~g :CUMBERLAND COUNTY, PENNSYLVANIA
-c~ a
v
. ,
s
KAYON R CHIN, : CIVII.. ACTION -LAW ~ ~ ~
DefendAnt : IN DIVORCE ~~, r- ~~,
-n
~
~~.~ ~ ~
~~
~~ ~
AND NOW, this ~~~ day of .-~ 2012 upon consideration of
Petitioner's Motion to Make Rule Absolute, said motion is hereby GRANTED.
BY THE COURT,
G~~
Distribution:
,/ Linda A. Clotfelter, Esquire, 5021 E. Trindle Road, Suite 100, Mechanicsburg, PA 17050,
Attorney for Plaintiff
/ Keith Brenneman, Esquire, 44 W. Main Street, Mechanicsburg, PA 17055, Attorney for
Defendant
/ Deborah L. Chin, 5252 Meadowbrook Drive, Mechanicsburg, PA 17050, Respondent
~~;es m~.~l~d ~f~/~a
~~
05/02/2013 09:50 7176977661 SNELBAKER BRENNEMAN PAGE 02/02
lww
4o,
PE
Keith O. Brenneman,Esquire
Snelbaker&, Brenneman,P.C.
44 West Main Street
Mechanicsburg,PA. 17055
(717)697-8528
Attorneys for Defendant Kayon R.Chin
DEBORAH L. CHIN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA
V.
NO. 2006-4262
KAYON R. CHIN,
Defendant CIVIL ACTION - LAW
IN DIVORCE-
PLAINTIFF'S AFFIDAVIT OF CONSENT
UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301(c)of the Divorce Code was filed on July
28. 2006.
2. The marriage of the Plaintiff and the Defendant is irretrievably broken and.ninety(90)
days have elapsed.from the date of the 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 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 to
unsworn falsification to authorities.
LAW OFFICM.
$NELDAKER 8c Date: j`�
BRENNEMAN, P.C. �J Deborah L. Chin
05/02/2013 09:50 7176977681 SNELBAKER BRENNEMAN PAGE 01/02
PP
X6113 mm 10
CUMBERLAND CDU�l
PENNSYLVANIA.
Keith 0.Brenneman,Esquire
Snelbaker&'Brenneman,P.C.
44 West Main Street
Mechanicsburg,PA. 17055
(717)697.8528
Attorneys for Defendant.Kayon.R.Chin
DEBORAH L. CHIN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY,PENNSYLVANIA
V.
NO. 2006-4262
KAYON R. CHIN,
Defendant CIVIL, ACTION - LAW
: IN DIVORCE
PLAINTIFF'S WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. 1 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.
4. 1 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 to
unsworn.falsification to authorities.
LAW OFMCE3
SNELBAKER&
BRENNEMAN. F.C. Date:
Deborah L. Chin
PROTHON0 ,
2013 MAY 17 PM f;
CUMBERLAND COUNTY
PENNSYLVANIA
DEBORAH L. CHIN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2006-4262
KAYON R. CHIN,
Defendant CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE
TO THE PROTHONOTARY:
Please withdraw the claim for equitable distribution raised by me in the above action.
Deborah L. Chin, pro se
Date:��/��
2913 HAY 21 P _Z' 51
CUMBERLAND MAUy
PENNSYLVANIA
Keith O. Brenneman,Esquire
Snelbaker&Brenneman,P.C.
44 West Main Street
Mechanicsburg,PA 17055
(717)697-8528
Attorneys for Defendant Kayon R. Chin
DEBORAHH L.-CHIN�T, I'N THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 2006-4262
KAYON R. CHIN, :
Defendant CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT
UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on July
28, 2006.
2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of the 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 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 to
unsworn falsification to authorities.
LAW OFFICES
SNELBAKER&
BRENNEMAN, P.C. Date: j t /2p 15
Kayon R. Chin
PEi��SYL�fa�lR
Keith O.Brenneman,Esquire
Snelbaker&Brenneman,P.C.
44 West Main Street
Mechanicsburg,PA 17055
(717)697-8528
Attorneys for Defendant Kayon R. Chin
DEBORAH L. CHIN, IN THE COURT OF COMMON PLEAS OF
Plaintiff: CUMBERLAND COUNTY, PENNSYLVANIA
V. :
NO. 2006-4262
KAYON R. CHIN,
Defendant CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S WAIVER OF NOTICE OF INTENTION
TO REQUEST ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301(c) OF THE DIVORCE CODE
1. 1 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 1-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.
4. 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 to
unsworn falsification to authorities.
LAW OFFICES
SNELBAKER& y-
BRENNEMAN, P.C. Date: ,("/ lit �zo /3
Kayon R. Chiti
DEBORAH L. CHIN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. 06 - 4262 CIVIL
KAYON R. CHIN,
Defendant IN DIVORCE
ORDER OF COURT
AND NOW, this
day of
2013, the Master was advised by counsel by letter dated May 20,
2013, that the parties have agreed to settle economic issues by
waiving all claims against each other. The Plaintiff filed a
praecipe on May 17, 2013, withdrawing her claim for equitable
distribution. There being no economic claims pending, and the
parties having signed affidavits of consent and waivers of
notice of intention to request the entry of the divorce decree
so that the divorce can conclude under Section 3301 (c) of the
Domestic Relations Code, the appointment of the Master is
vacated.
BY THE COURT,
KeA A. Hess, P.J.
cc: 11Deborah L. Chin (Pro se) ft
�P1 'ntiff
Keith O. Brenneman -<>
Attorney for Defendant
Z'n
„3 f Fr 18 f' 1 f' t
Lti`ti EtG `l i' 1 t •
PENNSYLVANiii�
DEBORAH L. CHIN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 2006 - 4262
KAYON R. CHIN,
Defendant : CIVIL ACTION—LAW
: IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Please transmit the record of this case, together with the following information to
the Court for the entry of a Divorce Decree:
1. Grounds for divorce: irretrievable breakdown under Section 3301(c) of the
Divorce Code.
2. Date and manner of service of the Complaint: August 4, 2006 (see Affidavit
of Service signed by Plaintiffs counsel and filed in this action and dated
August 7, 2006).
3. Date of execution of the affidavit required by Section 3301(c) of the Divorce
Code: by Plaintiff: May 11, 2013; by Defendant: May 11, 2013.
4. Related pending claims: None.
5. Date of Plaintiffs waiver of notice in Section 3301(c) divorce filed with the
Prothonotary: May 11, 2013.
6. Date of Defendant's waiver of notice in Section 3301(c) divorce filed with the
Prothonotary: May 11, 2013.
Date: December 18, 2013
Keith O. Brenneman, Esquire
Snelbaker& Brenneman, P. C.
LAW OFFICES 44 West Main Street
SNELBAKER& Mechanicsburg PA 17055
BRENNEMAN, P.C. Attorneys for Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
DEBORAH L. CHIN
•
•
V.
•
KAYON R. CHIN • NO. 2006-4262
DIVORCE DECREE
AND NOW, 23 , 203 , it is ordered and decreed that
DEBORAH L. CHIN , plaintiff, and
KAYON R. CHIN , 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.")
None.
By the e.
Attest: J.
s° _
Prothonotary
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