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Home My WebLink About95-00834 . ---I JI U I I \ Lrl I U/ . I ~ . .:+:.' .:.:...:+:. .:+:.-.:+:. .:.:. .:+:.".:.:. ',+:' ".:.:. .:+:. .:+:. .:.;. .:.:. .:.:..:.:. .:+;. .:+:. .:+:. .:+:.:-- ":+:'::':+:.:i':.;'::o:+:'..':+;': ,.:+:.' .:.:..:.:.~.:.>::...!~ ,',.., --........-...... ..... ---......-_.-...-..~ - ." ~ ~ " ~ ~ :.' ~ ~.' IN THE COURT OF COMMON PLEAS ;.~ ~ ,,~ * ~ '.' ~ ~.' ~ ',' OF CUMBERLAND COUNTY ~~~~ ~, "~~~:~;r ~ ',' .'~ ~ ~ '.' ~ '.' ~ ',' STATE OF PENNA. W :.' ~ "~ .', * ~ ',' ~:.. ~ ~ ~.' NI KYOUNG KIM, . . Plnintiff !1 .', ~ ~ ',' ~ '.' N I), 9.?~B~~....c::i v~1...:.~~.m~ ~ '.' w ~.' ~ ~,' w ',' ~ ',0 ,j; ~ ~.' ~ VPI':ill~ ,', ~ l3yONG CIIANC;. KIN, Defendant ~ '.~ ~ '.' ~ !~ .'~ ~ ~.; ~ ~ ',' DECREE IN DIVORCE AND NOW, oo ..~oo ..\ roo ", 199.5.... ", :;'. ~ '.~ ~ ~.~ ,. !ol ~.~ ~ ~.; .', ~ .' It Is ordered and decreed that ",.".,. !'I.~ . ~x~~~~, .K.~~.l" , , , , , . , , . , ,. . , , . " , , . " plaintiff, and......... oo.... oo oo~YP.t'lq, QI,lIl'!9. !<.I,l1oo oooo " oo" .. oo, , oo, defendant, are divorced from the bonds of matrimony, ~ ~.~ .', ~ ~ ~.~ .', ~ ~ '.' ~ :.~ ~ ',' <: .~ ~ " ~ ~.. ~ fJ. .' 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. ..""""..""'."..'..""'.'.'....)'...'."""'.'""". ."'.'.".'..."'..".'.'..':J.".."."".""""'" , II y L., c C J/r I: J W \~'\\,v 0;0 , \ " ~ ^IICsl:.x?"",t".,..~} !' ',:'!o:j'c~(. A:~~".:r',> J, ~ ~ ;67;" : ~7':'~ :.,L ,/(-'" .-9.4 ~ ~ .' ,....). -r- Prothol1ull\ry :;: ''''';/'''j ~ ~~_____L'__'_':!_~__''''''__'' ".. "_". '.. ~ }A;' '#-,,=. ....,;. -:.:. .:.:. ':to:. -:.:. .:.:. .:.:. .:.;. .:<t:. .:.:. .:.;. .:+:. .:.:. .:.:. .:t;. .:.:. .:.:. .:.:. .:+:- .:.:' .:+;. ':~:' .:+:. .:+;. .:t:. .:.:. .:.:. .:+:.' !!! ,~ ~ ~ '.' ~ '.' ~ ~., ,;, !' ~ .. ~ W f.i , MI KYOUNG KIM, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95 -13l/ civil Term IN DIVORCE CHILD CUSTODY PROCEEDING vs. BYONG CHANG KIM, Defendant OF CO~~T _ () ~ ' 1995, upon attached written Agreement of the parties, presented in AND NOW, ORDER this ,-S- day of conjunction with the Praecipe To Transmit the Record for Entry of a Decree of Divorce, it is hereby ordered and decreed as follows: 1. The mother, Mi Kyoung Kim, shall have sole legal custody of the minor child, Michael Min Kim, born March 6, 1992. 2. The mother, Mi Kyoung Kim, shall have primary physical custody of the minor Child, Michael Min Kim. 3. The father, Byong Chang Kim, shall have visitation with and/or partial custody of the minor child, Michael Min Kim, at such time and places as the parties shall ( By the cc Dale F. Shughart, Jr., attorney for Plaintiff -{'''/~l ",,;J1..I7;~/7.J" Byong Chang Kim, Defendant - ",~t<C IIIAj}"I3/1t,/9S (,s/. MI KYOUNG KIM, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95 - 'j..,~ Civil Term IN DIVORCE CHILD CUSTODY PROCEEDING vs. BYONG CHANG KIM, Defendant CUSTODY AGREEMENT This Agreement, made this ~y of February, 1995, by and between Mi Kyoung Kim, who resides at 646 Holly Pike, Mt. Holly springs, PA 17065, hereinafter called "Mother", and Byong Chang Kim, who resides at 230 Long Meadows Drive, Rome, Georgia 30165, hereinafter called "Father", WITNESSETH: WHEREAS, Mi Kyoung Kim and Byong Chang Kim, are the natural parents of the minor child, Michael Min Kim, born March 6, 1992; WHEREAS, the parties have lived separate and apart since November 28, 1992, and the Mother has filed a Complaint in Divorce and for Custody of the minor child, the Father has accepted service of the Complaint, of Plaintiff's Affidavit of Two Year Separation, and of a Defendant's counter-affidavit, and the Father has filed the counter-affidavit offering no contest to the proceedings nor any claim for economic relief and has accepted service of Plaintiff's Notice of Intention to File a praecipe for Entry of a Divorce Decree; and WHEREAS, the Mother is represented by Dale F. Shughart, Jr., Esquire, of Fowler, Addams, Shughart & Rundle, and the Father is not represented by legal counsel. The Father does speak and read " -, " ~ . . '. ,- ..... - :.1 ," ---".' . "" ' ,; . ' " the English language and has been advised of his right to retain legal counsel in this matter. He has knowingly, intelligentlY and voluntarilY chosen not to obtain the advice of legal counsel; and WHEREAS, the parties wish to enter a custody Agreement to become an Order of Court to establish their respective rights to custody, partial custody of and visitation with their son, Michael Min Kim, in the best interest of the minor child. NOW, THEREFORE, the parties hereto, intending to be legally bound hereby, do covenant and agree as follows: 1. The Mother, Mi Kyoung Kim, shall have sole legal custody of the minor child, Michael Min Kim, born March 6, 1992. 2. The Mother shall have primary physical custody of the minor child, Michael Min Kim. 3. The Father shall have visitation with and/or partial custody of the minor child, Michael Min Kim, at such times and places as the parties shall agree. 4. The Mother and Father believe that the terms of this Agreement will serve the child's best interest, but each expressly reserves the right to request to change the custody arrangements in the future should she or he believe this Agreement no longer serves the best interest of the minor child. Should either party feel such change should be made and the parties are unable to agree, each reserves the right to request a hearing to have the matter resolved by the court. 5. The parties agree that the court of common Pleas of cumberland County, pennsylvania, is the court of proper ~ -., jurisdiction and each requests that this Agreement be entered as an Order of Court by the Court of Common Pleas of Cumberland County to the above term and number in conjunction with the entry of a Decree divorcing the parties from the bonds of matrimony_ IN WITNESS WHEREOF, the parties hereto set their hands and seals the day and year first above written. Witness: ..... ..?u' Gt/t!/"fst Mi Ky u 9 K fi.:..- r _D~~~. >>,_>/e~ (' BYong Chang Kim ~ MI KYOUNG KUI, Plaintiff IN 'IliE COURT OF CQ.lMON PLEAS OF CUMBEIlLAND COJfIn'Y, PENNSYLVANIA vs. NO. 95- CIVIL AC'rION IN DIVORCE xl8 CIVIL - LA\~ BYONG CHANG KUI, Defendant 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. Grounds for divorce: irretrievable breakdown under Section $S3}(>(~ 3301 (d)(1) of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the canplaint: Complaint served by personal acceptance of service.by Defendant on February 15, 1995. 3. Canplete either Paragraph A. or B. A.. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by the plaintiff N/A by the d~~~ndant r ._, '. N/A B. (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: February 15, 1995 (2) Date of service of the plaintiff's affidavit upon the defendant: February 15, 1995 4. Related claims pending: None 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(l)(i) of the Divorce Code February IS, 1995 By: FOl~LER, , SHUGHART & RUNDLE for Pl intiff/ H~t Shughart, Jr. ~ ::C e- N N = D: -.. = r.. or ._ ., - 1-: ._, ult'lt: "r ';!t;v., ~ :1:,"'_~ ..~ ,., ;~. .". {',..f VI \ I' I" 14. ':,.r. , lll~ 1.1.1 s. :t~ u. .':,3 ....u '" MI KYOUNG KIM, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95 - t.JI1 civil Term IN DIVORCE ~ ' vs. BYONG CHANG KIM, Defendant 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 counselling. A list of marriage counselors is available in the Office of the Prothonotary at 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 OUT WHERE YOU CAN GET LEGAL HELP. Court Administrator Fourth Floor Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 MI KYOUNG KIM/ plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95 - civil Term vs. BYONG CHANG KIM, Defendant IN DIVORCE COKPL~INT UNDER THE DIVORCE CODE AND NOW/ comes the plaintiff, Hi Kyoung Kim, by her attorneys, Fowler, Addams, Shughart & Rundle, and makes the following Complaint in Divorce. COUNT I - IN DIVORCE UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. plaintiff is Hi Kyoung Kim, an adult individual, who resides at 646 Holly pike, Mt. Holly springs (South Middleton Township), Cumberland county/ pennsylvania 17065, since May 1992. 2. Defendant is Byong Chang Kim, an adult individual/ who resides at 230 Long Meadows Drive, Rome, Georgia 30165, since October 1994. 3. plaintiff has been a bona fide resident in the commonwealth of pennsylvania for at least six (6) months immediately previous to the filing of this Complaint. 4. plaintiff and Defendant were married on November 26, 1989 in pusan, Korea. 5. The parties have lived separate and apart since November 28, 1992, period of more than two (2) years. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. The Plaintiff has been advised of the availability of marriage counselling and that the Plaintiff may have the right to request that the court require the parties to participate in counselling. 9. Plaintiff requests the Court to enter a Decree of Divorce. COUNT II - CHILD CUSTODY 10. The parties are the parents of a minor child, Michael Min Kim, born March 6, 1992. 11. The minor child, Michael Min Kim, has been in the custody of Plaintiff since the separation of the parties. 12. The child was not born out of wedlock. 13. The relationship of the Plaintiff to the child is that of natural mother. 14. The relationship of the Defendant to the child is that of natural father. 15. The mother has not participatec as a party or witness, or in any other capacity in other litigation, concerning the custody of this child in this or any other Court. 16. The mother has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 17. The mother does not know of a person who is not a party to proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. lB. The mother desires, in the best interest and permanent welfare of the child would be served, by ordering that: a. The mother shall have sole legal custodY of the child; b. The mother shall have primary physical custody of the child; c. The father shall have such periods of partial ,custody and/or visitation as the parties may agree. .WHEREFORE, plaintiff requests your Honorable Court to award , _.J Plai~~iff sole legal custody and primary physical custody of the child 'and to award the Defendant reasonable partial custody and/or visitation as may be agreed by the parties. ~-"\-! "... f;.-<. Respectfully sUbmitted, FOWLER, ADDAMS, SHUGHART & RUNDLE By' /rJ2fr.5kJ VERIFICATION Mi Kyoung Kim hereby verifies that the facts set forth in the foregoing complaint are true and correct to the best of her knowledge, information and belief, and understands that false statements herein are made subject to the penalties of 1B pa. C.S. 54904 relating to unsworn falsifications. ~z,' ~ ~ DATE: February Jt, 1995 L.I") en - "".. "'>- ~.~~I ~ ~~~j~~~ ~ . .' .; ',I ,., -., ~ . I .... ~ . : :.":; ~ l~"': In (" ~''::::J .1. ., I,. l.~' '.:.' m ..... ...... ~~ 'S ~ ~l~ '''::/ ~ '" \\ \ ~ ~ ~ ~ 'v\ \;l c::: ~ ~ K Ii ~ ~ f'. \\ ... MI KYOUNG KIM, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95 - 1fJY' civil Term IN DIVORCE vs. BYONG CHANG KIM, Defendant NOTICB If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(4) OF THE DIVORCE CODE 1. The parties to this action separated on November 28, 1992, and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage is irretrievably broken. 3. 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. S4904 relating to unsworn falsification to authorities. Witness: ,/ L ))1 Jh oO~ I~ 714 J!.U ./ I DATE: flJ- /5" .. . '"il, )<//71/1 Mi KyouUij' K,!m )~~ . . , 1995 MI KYOUNG KIM, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. 95 - Civil Term BYONG CHANG KIM, Defendant IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because fr- .., \c'..) (Check (i), (H) or both) : (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. (';..) .2-. Check either (a) or (b) :; ,. ~_ c. (a) I do not wish to make any claims for economic :relief. I understand that I may lose rights concerning ~limony, division of property, lawyer's fees or expenses 'if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of Pa. C.S. 54904 relating to unsworn falsification to authorities. witness: Date: Byong Chang Kim NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counter-affidavit. Ln en - :c c... '" ::r ~>- ~~ &41 t; ~:::3 ., ~xc'::; \4.Io.;rJ.. I...:r..~.-_ 01--=.'.' . 1."...-:)- ( ., ,~: .J I Jl ~~ iJ. l~_. :;; --..jWw ~"'.r.~I1. ,.- ~B o Ln .. CD ~ MI RYOUNG RIM, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95 -"83'1 civil Term IN DIVORCE vs. BYONG CHANG KIM, Defendant ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint, Plaintiff's Affidavit of Two Year Separation and Defendant's Counter- affidavit under section 3301(d) of the Divorce Code. ('..- """'1 -' Date: F~bruary' /~, 1995 r."\ ij,~(./ ( BYOng((3hang Kim 4C:. lJ.;11ft)f:~~fS~ . ) A ,)0 '(51/1 ~t~~~~-Z. IlI"t ~ if: '0' ~ N ;-,. ""... :: ~~' u.~',~. ;;:,- .r =;r.~':;' 1_04:-J ~~ :I:.:)~" ?":"7 " _.l......,')P ~~(::I~~ .! t'J1.i:.-: '..._:~l:i.' I"'~ o Ln CD ~ . .~.... 0,_- ", . MI KYOUNG KIM, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95 - ~ 3 L/ civil Term IN DIVORCE vs. BYONG CHANG KIM, Defendant NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: BYONG CHANG KIM, DEFENDANT Mi Kyoung Kim, Plaintiff, intends to file with the court the attached Praecipe to Transmit Record on or after March i, 1995 requesting that a final decree in divorce be entered. ;:__Tn ,'/'f ..:.J JJi!! f ~.0::: Attorney for Plaintiff ,t_l Date: "February /5 , 1995 h.J (;." ..,- """"-"- ~ 1:;":.>- "U ,.. ~ - .' .-'''''~''I"'T.~. ~ ., " ~ --..&.i-.....;.~~~_.. . _ ' . .' } ~.-.,J...... ._.~"...~~fi'.~~ '__ . , ' . ',' I ",' ", . - , MI KYOUNG KIM, Plaintiff IN TIlE COURT Of C<J1MON PLEAS OF' CUMBERLAND COUNTY, PENNSYLVANIA NO. 95- '63l/ CIVIL AC'rION IN DIVORCE CIVIL - I,AW xl8 vs. BYONG CHANG KIM, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: L Grounds for divorce: irretrievable breakdown under Section 28S~>(lC:lJ 3301 (d)(l) of the Divorce Code. (Strike out inapplicable section) 2. Date and manner of service of the canplaint: Complaint served by personal acceptance of service.by Defendant on February l5, 1995. 3. Canplete either Paragraph A. or B. A. . Date of execution of the affidavit of consent required by Section 3301 (c) of 'the Divorce Code: by the plaintiff , .' N/A L' by the defendant N/A B;t1 (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: February l5, 1995 (2) Date of service of the plaintiff's affidavit upon the defendant: February 15, 1995 4. Related claims pending: None 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 3301 (d)(l)(i) of the Divorce Code Pcbruary 15, 1995 By: FOWI,ER, ADDAMS, SIIUGIIAll'r [, RUNDLE J:J~~ Y. )~ I , IUl'1l -. - ,. "'~ ..~ "": t- .ol. ~~'l~.'. l:.:,~r_'::i h.. :1:,':1;" O~:- ~r ' ':i Jcn " IJ.~ ..1 ~ ~, :,i,;~ '.. ~ ::0::: ""- m ,., N lJ'l '" w ~ r" :~ ~:;,:' MI KYOUNG KIM, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. 95 - '1?Jl[ Civil Term BYONG CHANG KIM, Defendant IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THB DIVORCB CODB 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because . '" ',,4 (Check (i), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. ;\,1 (,..-'1 ~d ,,'2. Check either (a) or (b) .~1;:; ::-../ . (a) I do not wish to make any claims for economic ''ielief. 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. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of Pa. C.s. 54904 relating to unsworn falsification to authorities. witness: Byong Chang Kim Date: NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counter-affidavit. LI"> en :c: a- U> .... N ). >- "'-I'.' ..l,. ,.. ,1 UI (-' ;~'.r ~~C .t k.. "", ,... _'- H Ol_-:~'... 1J'> - " 11'00" Iii '~'l.: ...;....H I' .~.j 1>_..,; -' .., ... '-"- ~ " MI KYOUNG KIM, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. 95 - 93') civil Term BYONG CHANG KIM, Defendant IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(dl OF THE DIVORCE CODE 1. Check ~(al (bl either (a) or (b): I do not oppose the entry of a divorce decree. I oppose the entry of a divorce decree because (Check (i), (il) or both) : (i) The parties to this action have not lived separate and apart for a period of at least two years. . (ii) The marriage is not irretrievably broken. j. ~ ~ Check either (a) or (b) ;~~(a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them befor.e a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of Pa. C.S. 54904 relating to unsworn falsification to authorities. Witness: -~~ ~~A~/ (. ~, B ng Chang Kim Date: ~~C/9C , NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you need not file this counter-affidavit. ~ - >-.. '" ,- """ ,- -,.' U.1""'~IJ. "2.~U~~ ~"";t.~':.. ,.-;T... , J ',.~ if) ..:_J:r. ~.J ;"~:i~ ;"'!\.l!~. '. .1,:1.: I' ;J ~.'" o ~ tJ) ,.. N lJ"> - co .... ..... . MI KYOUNG KIM, Plaintiff vs. BYONG CHANG KIM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 95 - r.o?{ Civil Term IN DIVORCE ACCEPTANCB OF SBRVICB I accept service of the Notice of Intention to Request Entry ,. of Divorce Decree under section 3301(d) of the Divorce Code with "" ...' a copy-of the Plaintiff's Praecipe to Transmit and Defendant's J counterJ-affidavit attached thereto. ,," .., l.r- Date: :~bruary I r; , 1995 r.,,,"-> 4 .... WI ZJ//0J:}t ,$~~ ~. 0<<-// l //-:. ./p '7 Byong chang Kim ~ - >-.. "',- ..'( ... l4J ti ~:' :' (.)uo-"::c- -0(.;..... ~"::'t::..~ c-:.r-7,.h .-;....Vl ";:'''= ~:! ;.r: "1"""7 -'....j\;!..., ".;.r.~:c... .... .. ::> u..., <:> lE .... ,.,. ('"I') l.n - ... ..... w..