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Home My WebLink About02-3848NOKEO MANIVANI-I, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02- CIVIL ACTION- LAW KEO MANIVANH, Defendant IN DIVORCE COMPLAINT 1. Plaintiffis Nokeo Manivanh, who currently resides at 141 West High Street, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Keo Manivanh, born Keo Norisan, who currently resides at 1828 South 18th Street, Philadelphia, Philadelphia County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff.and Defendant were married on or about December 1, 1979 in Thailand. 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. ;T~WILLIAMS Cad C. Risch Ten East High Street Carlisle, PA 17013 (717) 243-3341 & OTTO Date: ¢-~/~/~3 ~. Attorneys for Plaintiff VERIFICATION The foregoing Divorce Complaint is based upon information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document is that of counsel and not my own. ! have read the document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relied upon counsel in making this verification. This statement and verification are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities, which provides that if 1 make knowingly false averments, I may be subject to criminal penalties. ~l~eo Manivanh - NOKEO MANIVANH, Plaintiff KEO MANIVANH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02- 3 r//-ff C1VILACTION-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 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 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 at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Pa. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 Ctea~d: 08/12/02 Io:Ig:08AM 10702.1 NOKEO MANIVANH, Plaintiff KEO MANIVANH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3848 CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Keo Manivanh, Defendant in the above divorce action filed in the Court of Common Pleas of Cumberland County, hereby accept service of said Divorce Complaint on the 4 th day of September ,2002. Keo Manivanh F:\FiLES'~DATAFILE~Gendoc.cur\10702-con. I/tde Created: 08/12/02 10:I9:08AM Revised: 12/10/02 II:50:41AM 10702.1 NOKEO MANIVANH, Plaintiff V. KEO MANIVANH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLANT) COUNTY, PENNSYLVANIA NO. 02-3848 CIVIL ACTION - LAW IN DWORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on August 13, 2002. I aclmowledge receiving a true and correct copy of the Divorce Complaint, said copy being served upon me on September 4, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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. 4. I understand that I may lose fights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(C) AND § 3301(d) OF THE DIVORCE CODE 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, lawyers 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 and waiver 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. Date: Keo Manivanh, Defendant NOKEO MANIVANH, Plaintiff V. KEO MANWANH, Defendant 13,2002. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3848 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on August The marriage of Plaintiffand Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree ofdivome. 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER _~3301(c) AND § 3301 (d) OF THE DIVORCE CODE 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, lawyers 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 and waiver are true and correct. 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: 1~ ' - 'vanh, t laintiff F:\FiLES\DATAFILE\Gendoc cur\10702-1 praftde Created: 08/12/02 10:I9:08AM Revised: 12/31/02 10:02:21 AM 107021 NOKEO MANIVANH, Plaintiff V. KEO MANIVANH, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-3848 CIVIL ACTION - LAW IN 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 3301(c) of the Divorce Code. Date and manner of service of the complaint: See Acceptance of Service as filed. Date of execution of the Plaintiff's affidavit of consent required by Section 3301 (c) of the Divorce Code; December 14, 2002; by the Defendant; December 14, 2002. in §3301(c) Divorce was filed with the 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice Prothonotary: December 20, 2002. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: December 20, 2002. MARTSON DEARD, QRFF WILLIAMS & OTTO Carl C. Risch, Esquire Ten East High Street Carlisle, PA 17013 (717) 243-3341 Date: December 31, 2002 Attorneys for Plaintiff IN THE COURT OF OF CUMBERLAND STATE OF ~ COMMON COUNTY PENNA. PLEAS ..NOKEO_.MANI~ANH ..................................................... PLAINTIFF Versus KEO I~NIVANH DEFENDANT No. 02-3848 19 DECREE IN DIVORCE AND NOW .... ~~... ~ ..... ~g..~.0.0i, it is ordered and decreed that ................. ~.o.~.~.o...~.~.~.~.~?.~. ................... plaintiff, and ........................... .~.~.0...~..~¥.~.~.~ ................... de~endant, are divorced from the bonds ot 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: NONE. I PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and sul~itt~ J~ duplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please 1/st the within matter for the next Ar~t Court. CAPTION OF CASE (entire caption must be stated in full) LARRY W WILKINSON, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA THE HOUSING AUTHORITY OF THE COUNTY OF CUMBERLAND; CHRISTOHPER GULOTTA; SUE A. WOLF; CATHERINE MOWERY; AND YVONNE HECKLER ( Plaint J-f f ) ( Defendant ) No. 02-3841 civil 19 State matter to be argued (i.e., plaintiff's motion for new trial, defendant's demu~ier to cc~laint, etc. ): Defendants' Preliminary Objections 2. Identify counsel whowiLl argue case: (a) for plaintiff: John 3. Baranski, Jr., Esquire Address: 17 East Market Street York, PA 17401 (b) for defendant: Allen C. Warshaw, Esquire ~]dress: 240 North Third Street Suite 600 Harrisburg, PA 17101-1503 3. I w~]l notify ~]lparties in writingwithin t~a~days that th_is case has been listed for ar~t. Christopher C. Houston, Esq. 114 N. Hanover Street Carlisle, PA 17013 4. Arg~nent Court Bate: 3/~/03 March 26, 2003 Christopher C. Houston, Esq. Attorney for Defendant Housin~ Authority of th