NOTICE OF SUMMONS – PHUONG NGUYEN

STATE OF MICHIGAN
BERRIEN TRIAL CT
JUDICIAL CIRCUIT
SUMMONS
CASE NO. 22-002087-DO-R
Court address
811 Port St., St. Joseph, MI 49085
Court telephone no.
269.983.7111
Plaintiff
PHUONG NGUYEN
4815 Pleasant Meadow Wood
St. Joseph , MI. 49085
(269)769-3817
Plaintiff’s attorney,
Kelly G Lambert III (P43874)
Law Offices of Kelly G Lambert IIl. PC
1444 Michigan St., NE, Ste. #9
Grand Rapids Michigan 49503
v
Defendant
HlEP KIM NGUYEN
313 Lot N
Nguyen Kim Apartment
Ward 7, District 10, HCMC
Vietnam
NOTICE TO THE DEFENDANT: In the name of the people of the State of Michigan you are notified:
1. You are being sued.
2. YOU HAVE 21 DAYS after receiving this summons and a copy of the complaint to file a written answer with the court and serve a copy on the other party or take other lawful action with the court (28 days if you were served by mail or you were served outside this state).
3. If you do not answer or take other action within the time allowed, judgment may be entered against you for the relief demanded in the complaint.
4. If you require special accommodations to use the court because of a disability or if you require a foreign language interpreter to help you fully participate in court proceedings. please contact the court immediately to make arrangements.
Issue date: 4-20-22
Expiration date: 5/3/22
Signed: Sharon Tyler, Court clerk
STATE OF MICHIGAN
IN THE CIRCUIT COURT
FOR THE COUNTY OF BERRIEN
Hon.
Case No. 21- -DO
VERIFIED COMPLAINT
FOR DIVORCE
PHUONG NGUYEN,
Plaintiff,
v
HIEP NGUYEN,
Defendant.
_______________________________

KellyG Lambert III (P43874)
Attorney for Plaintiff
Law Offices of Kelly G Lambert III, P.C.
1444 Michigan NE, Ste. 9
Grand Rapids, MI 49503
(616) 732-8888

Hiep Kim Nguyen
Defendant
313 Lot N
Nguyen Kim Apartment
Ward 7, Dist. 10 HCMC
Vietnam
______________________________

NOW COMES Plaintiff, Phuong Nguyen, and states for her Complaint for Divorce as follows:
1. The parties were married on January 24, 2014, in Vietnam.
2. The name of the Plaintiff before the marriage was Phuong Nguyen.
3. The Plaintiff has resided more than 10 days in Berrien County, Michigan, and in the State of Michigan for more than 180 days immediately preceding the filing of this Complaint.
4. The parties have no minor children.
5. There has been a breakdown of the marriage relationship to the extent that the objects of matrimony have been destroyed, and there remains no reasonable likelihood that the marriage can be preserved.
6. The parties do not own real property.
7. The parties have incurred marital debts and assets.
8. Upon information and belief, Plaintiff is not pregnant.
WHEREFORE, PLAINTIFF PRAYS:
a. that the marriage between the parties be dissolved and a divorce decreed;
b. that the property and debts of the parties be divided and awarded; and
c. that she may have such other relief as shall appear to be equitable between the parties.
Dated:
Respectfully submitted,
Law Offices of Kelly G Lambert III, PC
Signed: Kelly G Lambert III (P43874)
Attorney for Plaintiff
VERIFICATION STATEMENT
I, Phuong Nguyen, verify that I have read the above Complaint and I hereby
verify the content to be true to the best of my knowledge, information and belief.
Dated: 12/31/2021
Signed: Phuong Nguyen
Plaintiff
(05-26)