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Home My WebLink About02-2619IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA ½ONNIE BINTAVIHOK, Plaintiff Vo BINTAVIHOK, Defendant : : CIVIL ACTION - LAW : DIVORCE NOTIC~ YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt ~ction. You are warned that if you fail to do so, the case may ~roceed without you and a decree of divorce or annulment may be :ered 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 at the Cumberland County Courthouse, Carlisle Pennsylvania- IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE ~HIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO 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 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 IN THE COURT OF COMMON PLEAS OF CUMBERLAiqD COUNTY, PENNSYLVA/qIA BONNIE BINTAVIHOK, Plaintiff BINTAVIHOK, Defendant : CIVIL ACTION - LAW · DIVORCE COMPLAINT AND NOW, this ~0~ day of~[, _, 2002, comes the Plaintiff, BONNIE BINTAVIHOK, by her attorney, DIANE G. RADCLIFF, ESQUIRE, and files this Complaint in Divorce of which the following is a statement: COUNT I: DIVORC~ 1 The Plaintiff is Bonnie Bintavihok, an adult individual residing at 601 Louisa Lane, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant is Panuwat Bintavihok, an adult individual residing at 4 Adams Street, Enola, Cumberland County Pennsylvania 17025. 3. Plaintiff and/or Defendant have been bona fide residents of the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on February 11, 1981 at Houston, Texas. 5. There have been no prior actions of divorce or annulment between the parties. Plaintiff has been advised of the availability of counseling DIANE G. RADCLIFF 3448 TRINDLE ROAD CA/vIP HILL, PA 17011 (717) 737-0100 -2- and the right to request that the court require the parties to participate in counseling. The Defendant is not a member of the Armed Services of the united States or any of its Allies. The Plaintiff avers that the grounds on which the action is based are: a. Section 3301(c): The marriage is irretrievably broken; b Section 3301(d).: The marriage is irretrievably broken and · The parties ar~ now living separate a~d a~a~io~n~ the parties have lived separate and apart ~or a ~ two years, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable court to enter a ~cree in divorce, divorcing the Plaintiff and Defendant. Respectfully submitted, ~E G~RA~Du~F~, E~QU~P,E 3~ Tri~le Road I PA 17011 \ Supreme court ID ~ 32112 Phone: (717) 737-0100 Fax: (717) 975-0697 DIANE G. RADCLIFF 34~8 TR1NDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 -3- VERIFICATION BONNIE BINTAVIHOK verifies that the statements made in this Complaint are true and correct. BONNIE BINTAVIHOK understands that false statements herein are made subject to the penalties of 18 ?a.C.S. Section 4904, relating to unsworn falsification to [thorities- ~ONNIE BINTAVIHOK DIANE G. RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 -4- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BONNIE BINTAVIHOK, Plaintiff Vo PANUWAT BINTAVIHOK, Defendant : NO. 02-2619 CIVIL TERM : : CIVIL ACTION - LAW : DIVORCE ~ERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the Complaint in Divorce has been served upon the Defendant, Panuwat Bintavihok, by Certified Mail, Restricted Delivery on June 3, 2002, 2001. The return receipt is attached hereto as Exhibit "A" and made a part hereof. Respectfully submitted, ESQUIRE/ Camp Hill, PA 17011 Phone: (717) 737-0100 Fax: (717) 975-0697 Supreme Court ID # 32112 Attorney for Plaintiff - i - · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Pdnt your name and address on the reverse so that we can return the card to you. . · Attach this card to the back of the mailpiace, or on tile front if space permits. 1. Article Addressed to: Is dellvepy' address different t If YES, e~ter deliver 3. Service Type ~,~ Certified Mail [] m Mail [] Registered [] [] Insured Mail [] C.O.D. 2. Article Number (Copy from service label) PS Fo~ 3811, July 1999 ~mestic Return R~eipt Agent r'l yse for Merchandise Restricted Delivery? (Extra Fee) ~j~ Yes 10259S-99-M- 1789 EXHIBIT "A" RETURN RECEIPT - 2 - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BONNIE BINTAVI HOK, Plantiff Vo PANUWAT BINTAVIHOK, Defendant NO. 02-2619 CIVIL TERM CIVIL ACTION - LAW DIVORCE AFFIDAVIT OF CONSEI~T o A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 30, 2002. 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. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. 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. Dated: BONNIE BINTAVIHOK BONNIE BINTAVIHOK, Plantiff Vo PAN-UWAT BINTAVIHOK, Defendant o IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2619 CIVIL TERM CIVIL ACTION - LAW DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c~ OF THE DIVORCE CODR I consent to the entry of a final decree in divorce without notice. 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 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. Dated: BONNIE BINTAVIHOK IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BONNIE BINTAVIHOK, Plantiff Vo PANUWAT BINTAVIHOK, Defendant NO. 02-2619 CIVIL TERM CIVIL ACTION - LAW DIVORCE AFFIDAVIT OF CONSENT o A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 30, 2002. 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. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. 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. Dated: ~~/~- ~ p/~~~i~ T S IN'T'AVI HOk IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BONNIE BINTAVIHOK, Plantiff PANUWAT BINTAVIHOK, De fendant NO. 02-2619 CIVIL TERM CIVIL ACTION - LAW DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UN-DER SECTION 3301~c~ OF THE DIVORCE CODE I consent to the entry of a final decree in divorce without 2 o notice. 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 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. Dated: ~-- t~ "-" O~ ~~IHOK ~ BONNIE BINTAVIHOK, Plaintiff Vo PANUWAT BINTAVIHOK, Defendant TO THE PROTHONOTARY: Transmit the record, entry of a divorce decree: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2619 CIVIL TERM CIVIL ACTION -LAW DIVORCE PRAECIPE OF TRANSMIT RECORD 3 o together with the following information, to the court for A. Date of Service: N/A B. Manner of Service: N/A OR DATE WAIVER OF NOTICE IN SECTION PROTHONOTARY: a. Plaintiff's Waiver: 9/16/02 b. Defendant's Waiver: 9/19/02 GROUND FOR DIVORCE: Irretrievable breakdown under Section 3301 (c)of the Divorce Code. DATE AND MANNER OF SERVICE OF THE COMPLAINT: A. pate: May 30, 2002 B. Manner: Certified Mail/Restricted Delivery DATE OF EXECUTION OF THE AFFIDAVIT OF CONSENT REQUIRED BY SECTION 3301 (C) OF THE DIVORCE CODE: A. Plaintiff: September 14, 2002 B. Defendant: September 16, 2002 DR DATE OF EXECUTION OF THE PLAINTIFF'S AFFIDAVIT REQUIRED BY SECTION 3301(D) OF THE DIVORCE CODE AND DATE OF SERVICE OF THE PLAINTIFF'S 3301 (D) AFFIDAVIT UPON THE DEFENDANT: A. Date of Execution: N/A B. Date of Filing: N/A C. pate of Service: N/A RELATED CLAIMS PENDING: No issues have been raised in this case, and no issues are pending. DATE AND MANNER OF SERVICE OF THE NOTICE OF INTENTION TO FILE PRAECIPE TO TRANSMIT RECORD, A COPY OF WHICH IS ATTACHED, IF THE DECREE IS TO BE ENTERED UNDER SECTION 3301(D) (I) (I) OF THE DIVORCE CODE: 3301 (C) DIVORCE WAS FILED WITH THE Camp /~, pA 17011 Supreme Court ID # 32112 Phone: (717) 737-0100 Attorney for Plaintiff IN THE COURT OF COMMON OF CUMBERLAND COUNTY STATE OF BONNIE BINTAVIHOK, Plm~nriff VERSUS PANUWAT BINTAVIHOK, Defendant PENNA. No. 02-2619 PLEAS C~ DECREE IN AND NOW, DIVORCE , 2002 , IT IS OrDEreD AND DECREED That BONNIE BINTAVIHOK , PLAINTIFF, AND PANUWAT BINTAVIHOK , DEFENDANT, 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; No issues have been raised, and no issues are outstanding. ATTEST: