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Wherefore. Defendant requests that Plaintin's Complaint be dismissed.
NEW MAT.IER
8. The allegations of paragraphs one through seven of Plaintiff's Complaint and
Defendant's answers thereto arc incorporated herein by reference.
9, During the time that Plainlin'represented Defendant. Defendant was engaged in
divorce and child custody litigation in the Courts of Common Pleas of both Dauphin County and
Perry County. Pennsylvania.
10, During the course of that litigation, Defendant gave Plaintilfinstructions regarding
her position on certain issues involving. the children's father's contact with the children. Despite
those instructions, Plaintiff negotiated a settlement with opposing counsel that was not in
accordance with the instructions given to him by Defendant. which resulted in an awkward and
unworkable custody arrangement. that despite her subsequent efforts. Defendant has not been
able to alter.
II. During the course of that same litigation, Plaintiff advised Defendant not to seek
special relief to preserve her interest in jointly owned real estate. Defendant followed Plaintiff's
advice. Subsequently as a result of her husband's failure to pay the martgage. the real estate was
sold at sheriff's sale incident to a mortgage foreclosure proceeding, and Defendant lost her share
of the equity in the property.
12. As a result of Defendant's poor advice and inadequate representation, Defendant
suffered damage in at least the amount claimed by Plainlin'in this action.
13, In the alternative. Plaintiff's poor advice and inadequate representation rendered
his legal services worthless to Defendant. and Plaintiffs is not entitled to recover the amount
claimed.
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