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HomeMy WebLinkAbout01-4647KANE AND MAnKIN~ LLP HUYNH MAI THAO, PHAN THANH CUONG Plaintiff Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- L} ~t~*~ Civil Term CIVIL ACTION-LAW IN DIVORCE NOTICE TO DEFENDANT AND CLAIM OF 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 by the Court. A judgment may also be entered against you for any 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marTiage counseling. A list of marriage counselors is available in the Prothonotary's office at the Cumberland County Courthouse, 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 OUR WHERE YOU CAN GET LEGAL HELP. Office of the Court Administrator Cumberland County Courthouse, 4th Floor Carlisle, PA 17013 (717) 240-6200 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Michael J. Kane Reg. No. 46215 Kane and Mackin, LLP 3300 Trindle Rd. Camp Hill, PA 17011 (717) 214-3700 Attorney for Plaintiff HUYNH MAI THAO, PHAN THANH CUONG Plaintiff Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- L/~, q7 Civil Term CIVIL ACTION-LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) AND 3301(D) OF THE DIVORCE CODE COMES NOW, Huynh Mai Thao, through her attorney, Michael J. Kane, Esquire, and avers as follows: COUNT ONE - DIVORCE 1. Plaintiff, Huynh Mai Thao is an adult individual, whose current address is 120 Wesley Mechanicsburg, Cumberland County Pennsylvania 17055. 2. Defendant is Phan Thanh Cuong, who resides at 33 Honeysuckle Dr., Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married in June, 1993 in VietNam 5. There have been no prior actions of divorce filed in this matter. 6. Neither Plaintiffnor Defendant is a member of the Armed Forces of the United States. 7. The marriage is irretrievably broken and the parties are proceeding under Section 3301 (c) and 3301 (d) of the Divorce Code. 8. Plaintiffhas 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. WHEREFORE, Plaintiff requests the court enter a decree of divorce. Respectfully submitted, Michael J. Kane Reg.-TNo. 46215 Kane and Mackin, LLP 3300 Trindle Rd. Camp Hill, PA 17011 (717) 214-3700 Attorney for Plaintiff .VERIFICATION I, Huynh Mai Thao, hereby verify that the information contained in the foregoing is true and correct to the best of my personal knowledge, information and belief. I further understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4909 relating to unswom falsification to authorities Huynh Mai Thao PHANTHANH CUONG Plaintiff Defendant : COURT OF COM~ION PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01- 4647 Civil Term CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO FILE RETURN OF SERVICE TO THE PROTHONOTARY: Please accept for filing this proof of service of the Complaint on the Defendant in the above- captioned case. Respectfully submitted, Michael J. Kane Reg. No. 46215 Kane and Mackirg LLP 3300 Trindle Rd. Camp Hill, PA 17011 (717) 214-3700 Attorney for Plaint'~ff PHAN THANH CUONG Plaintiff Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01- 4647 Civil Term · CIVIL ACTION-LAW : IN DIVORCE ACKNOWLEDGMENT AND ACCEPTANCE OF SERVICE I Phan Thanh Cuong acknowledge that I am the Defendant in the above-captioned ease and that I have received a copy of the complaint by first class mail. By: Date: 33 Honeysuckle Dr. Mechanicsburg, PA 17055