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Home My WebLink About00-02122 , WAYNEF. SHAPE Attorney at Law 53 West Pomfret Street Carlisle. Pennsylvania 17013 , '\!'i>,~~ DENNIS V. LANDI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW v. : NO. OO-,.uJ~CIVIL TERM LYNNE E. LANDI, Defendant : 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 in the Office of the Prothonotary at CUMBERLAND COUNTY COURTHOUSE. CARLISLE. PENNSYLVANIA 17013 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: 717-249-3166 4'/~ r~ Wayne . Shade, Esqmre Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff - _ _~ ~~_'=",_"[_'d. ~ WAYNEF.SHADE Attorn~ at Law 53 West Pomfret Street Carlisle, pennsylvania 11013 I" DENNIS V. LANDI, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW v. : NO. OO-.2/,J..2CIVIL TERM LYNNE E. LANDI, Defendant : IN DIVORCE COMPLAINT 1. Plaintiff in this Action in Divorce is DENNIS V. LANDI, an adult individual who resides at 607 Brad Street, Shippensburg, Cumberland County, Pennsylvania 17257. 2. Defendant is LYNNE E. LANDI, an adult individual and citizen of the United States of America who resides at 607 Brad Street, Shippensburg, Cumberland County, Pennsylvania 17257. 3. Defendant has been a bona fide resident of Cumberland County, Pennsylvania, for more than six months previously to the filing of this Complaint and continuing to the commencement of this Action in Divorce. 4. Plaintiff and Defendant were lawfully joined in marriage on March 12, 1971, in Cumberland County, Pennsylvania. ~' , , - ~ WAYNEF.SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 ,~ .,= 5. Plaintiff avers as the grounds on which this action is based that the marriage of the parties is irretrievably broken. 6. There have been no prior actions for divorce or annulment of this marriage in Pennsylvania or in any other jurisdiction. 7. Both parties to this Action in Divorce are legally capable of managing their own concerns. 8. Defendant herein is not a member of the armed forces of the United States of America. 9. There are two minor children of this marriage, namely, Rachael C. Landi, born November 20, 1983, and Jorgan R. Landi, born March 29, 1990. 10. 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. -2- J WAYNEF.SHADE Attorney at Law 53 West Pomfcet Street Carlisle, Pennsylvania 17013 ~,",~,~- - WHEREFORE, Plaintiff demands judgment dissolving the marriage between the parties. ~+r/ E~ Wayne . Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff -3- 'I' I I - , WAYNEF, SHADE Attorney at Law 53 West Pomfret Street Carlisle, Pennsylvania 17013 '11.""""" I verifY that the statements made in this pleading 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: April 3, 2000 ~uL. Dennis V. Landi """,,""" r~ . f.J ..cl(, \>of;' -.0, --J '<: " " .' " O'r ~.o o ;::~~; ZJ] ~~~;, ~~~l ..c.~_ ::! C':J C> , .,.,. '-,j ,"J I -J o ., ml ~:f1~ '~J,6 ',.> i .~,~S? ~~'(>~ '-'-")ffl S :c" :2: :ry. :2;':: :J"j \8 -:6 ~ ~ .. c v- C -J :'\ 0", 2: ~ ~' Y--1.' \ ". ~~...,.,. l'!II!~,." ~ "li!!W-lIf!Il!'1I''''''i11'''''''ff':!'f;~~''11*1^!'''_~~fT''i'.-,"r",~,m'';i!!l!l(ffl!i'!J~~~~UNi~'~~, WAYNEF. SHADE Attorney at Law 53 West Pom:fret Street Carlisle, Pennsylvania 17013 '!:~ DENNIS V. LANDI, Plaintiff v. LYNNE E. LANDI, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW : NO. 00-2122 CIVIL TERM : IN DIVORCE PRAECIPE TO DISCONTINUE TO THE PROTIIONOTARY: Please enter Plaintiffs voluntary discontinuance of the proceedings in the above- captioned matter. Date: May 8, 2001 "1 ~ Fd2.tJ, Wayn . Shade, Esquire Supreme Court No. 15712 53 West Pomfret Street Carlisle, Pennsylvania 17013 Telephone: 717-243-0220 Attorney for Plaintiff .' ,; 'H~ ..".,,- ~~ ,_ !II1!Il - 0 CO Cl C -q ~ Z -ocr] :P;t.o q]r~"\ .-< -'_ _.~.f I Z'C. Gf),,~-,: \JO ~<L_ ':;! C.2C:l ~TI -r~ ~~o ..J.;;.. ~, ~-(~, ~ ~_.~- '-.J 'S-'? J"c ~ ,;:0 ~~_\~r-:'''?"''''''''''''*'''''~l!l1'-~!l<IIl!fll!!llIli!~<!I!IIJ;I!"~!DJfilJPm!!lfflIJllll!!ItI'!~'!lf1!~