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HomeMy WebLinkAbout01-6289MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff DANIELLE M. LYDA, Plaintiff V. RAYMOND R. LYDA, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. Ol-- CIVIL ACTION - 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 ease 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. When the ground for 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 the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania, 17013-3387. 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 (717) 249-3166 MARIA P. COGNETTI & ASSOCIATES MARIA P. COGNETTI, ESQUIRE Attorney I.D. No. 27914 210 Grandvicw Avenue, Suite 102 Camp Hill, PA 17011 TelcphoneNo. (717) 909-4060 Attorney for Plaintiff DANIELLE M. LYDA, : Plaintiff : RAYMOND R. LYDA, : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. {:23 ~ -- /-.~.~ CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) OR (D) OF THE DIVORCE CODE 1. Plaintiff is Danielle M. Lyda, who has resided at 125 Humer Street, Enola, Cumberland County, Pennsylvania. 2. Defendant is Raymond R. Lyda, who has resided at 1839 Creek View Drive, New Cumberland, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at ' least six (6) months immediately previous to the filing of this Complaint. Pennsylvania. 5. 6. 7. The Plaintiffand Defendant were married on April 14, 2000 in York, There have been no prior actions of divorce or for annulment between the parties. Neither of the parties in this action is presently a member of the Armed Forces. The Plaintiff and Defendant are both citizens of the United States. 8. Plaintiffhas been advised of the availability of marriage counseling and that she . may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. 9. Plaintiff avers that there are no children of the parties under the age of eighteen (18). 10. The marriage is irretrievably broken. 11. Al~er ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes the Defendant may file such an Affidavit. 12. In the alternative, Plaintiff will file an Affidavit of Consent and provide the appropriate notices two (2) years from the date of separation. WHEREFORE, Plaintiff respectfully requests the Court to enter a decree of divorce pursuant to Section 330 l(c)(d) of the Divorce Code Dated: Respectfully submitted, Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff VERIFICATION I, DANIELLE M. LYDA, hereby verify and state that the facts set forth in the foregoing document are tree and correct to the best of my information, knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unswom verification to authorities. DANZI~LLE M. LYDA ~ DANIELLE M. LYDA, Plaintiff RAYMOND R. LYDA, Defendant IN THE COLrRT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-6289 CIVIL ACTION - LAW IN DIVORCE DANIELLE M. LYDA, Plaintiff RAYMOND R. LYDA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 00421 S 2001 PACSES Case Number 844103490/30696 IN SUPPORT PETITION TO WITHDRAW APPEARANCE To the Honorable, The Judges of Said Court: AND NOW, comes Petitioner, Mafia P. Cognetti, Esquire, and in support of her Petition to Withdraw Appearance, respectfully represents as follows: 1. Petitioner is Mafia P. Cognetti, Esquire, an attorney with offices located at 210 Grandview Avenue, Suite 102, Camp Hill, Pennsylvania. 2. Respondent is Danielle M. Askey, a/k/a, Danielle M. Lyda who resides at 450 South 3~a Street, Apt. 5, Lemoyne, Pennsylvania. 3. Petitioner was retained by Respondent on or about June 25, 2001 to represent her in connection with her domestic relations matters. 4. A Complaint in Divorce was filed with this Honorable Court on or about November 5, 2001 thereby instituting the above-captioned divorce action. 5. A Complaint in Support was filed with this Honorable Court on or about June 7, 2001 thereby instituting the above-captioned support action. 6. The Petitioner anticipates that there will be prolonged proceedings in all of the above matters. 7. Despite repeated efforts to do so, Petitioner has 'been unable to meaningfully and effectively communicate with Respondent. 8. Petitioner has attempted to repeatedly contact Respondent by both telephone and mail concerning issues in her case. Respondent has refused to respond. 9. Petitioner has at all times attempted to represent Respondent effectively and vigorously to the best of her ability, but it has become impossible for Petitioner to do so. 10. Petitioner asks to withdraw her appearance for Danielle M. Askey, a/k/a, Danielle M. Lyda because, inter alia: a. There appears to be a serious failure to communicate between Respondent and Petitioner.; b. Respondent has failed to timely pay Petitioner's fees and costs as billed in accordance with their fee agreement; c. Respondent has deliberately disregarded her agreement with Petitioner as to fees and costs and withdrawal is allowed pursuant to Rule 1.16(b)(4) of the Rules of Professional Conduct; and, d. Continued representation will result in an unreasonable financial burden on Petitioner. WHEREFORE, Petitioner respectfully requests that her appearance be withdrawn for Respondent and that she be removed from the docket as the attorney of record for Danielle M. Askey, a/kda, Danielle M. Lyda. Date: November 19, 2003 Respectfully Submitted: MARIA P. COGNETTI & ASSOCIATES MAmA ~'. ~O(;~:~T~, ESQUIaE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 VERIFICATION I, Mafia P. Cognetti, hereby verify and state that the facts set forth in the foregoing document are tree and correct to the best of my information, lmowledge and belief. I understand that false statements herein are made subject to the penalties of' 18 Pa. C.S.A. §4904 relating to unswom verification to authorities. --]"ff / ~-~'~5 ~ -- '~~- - ~'Mafia P. Cognetti~ DATE: November 19, 2003 CERTIFICATE OF SERVICE I, Maria P. Cognetti, Esquire, do hereby certify that on this date I served the foregoing Petition to Withdraw Appearance by depositing a tree and exact copy thereof in the United States mail, first class, postage prepaid, addressed as follows: Ms. Danielle Lyda 450 South Third Street Apartment 5 Lemoyne, PA 17043 Jeanne' B. Costopoulos, Esquire Costopoulos & Welch 1400 North Second Harrisburg, PA 17102 Date: November 19, 2003 By: Respectfully Submitted: MARIA P. COGNETTI & ASSOCIATES ~ARi~N~,~F.,T)r i, E S Q Ui '~ Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 DANIELLE M. LYDA, Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA RAYMOND R. LYDA, Defendant CIVIL ACTION - LAW NO. 01-6289 CIVIL TERM ORDER OF COURT AND NOW, this 3rd day of December, 2003, upon consideration of the Petition to Withdraw Appearance, a Rule is hereby issued upon Plaintiff and Defendant to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of this order. ~l~aria P. Cognetti, Esq. 210 Grandview Avenue Suite 102 Camp Hill, PA 17011 ~l~anielle M. Lyda aJk/a Danielle M. Askey 450 South Third Street Apt. 5 Lemoyne, PA 17043 Plaintiff t~anne B. Costopoulos, Esq. 1400 North Second Street Harrisburg, PA 17102 Attorney for Defendant BY THE COURT, /. /,./-! 7~ Wesley Ole~l?., J. ;rc DANIELLE M. LYDA, Plaintiff RAYMOND R. LYDA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-6289 C1VIL ACTION - LAW IN DIVORCE DANIELLE M. ASKEY Plaintiff VS. RAYMOND R. LYDA Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKETNO.: 00421 S 2001 PACSES NO.: 844103490/30696 IN SUPPORT MOTION TO MAKE RULE ABSOLUTE AND NOW comes Petitioner, Maria P. Cognetti, Esquire, and in support of her Motion to Make Rule Absolute, respectfully represents as follows: On November 25, 2003, Petitioner above named filed a Petition to Withdraw Appearance. 2. On December 3, 2003, the Court entered a Rule. to Show Cause against the Respondent, Danielle M. Lyda, directing her to show cause why Maria P. Cognetti should not be permitted to withdraw as counsel. Said Rule was returnable 21) days after service thereof. 3. Service of said Rule was made on Respondent and counsel for Raymond R. Lyda on December 5, 2003. An affidavit of Service attesting to same has been filed to the above number and term. 4. More than 20 days have elapsed since the service of the aforesaid Rule to Show Cause. 5. Up to this point in time no responsive pleading whatsoever has been filed by Respondent or Raymond R. Lyda. WHEREFORE, Petitioner respectfully requests this Honorable Court enter an order making its Rule Absolute. Date: January ~ ,2004 By: Respectfully Submitted: MARIA P. COGNETTI & ASSOCIATES Attorney I.D. No. 27gl-W 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 DANIELLE M. LYDA, Plaintiff RAYMOND R. LYDA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-6289 C1VIL ACTION - LAW IN DWORCE DANIELLE M. ASKEY Plaintiff VS. RAYMOND R. LYDA Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO.: 00421 S 2001 PACSES NO.: 844103490/30696 IN SUPPORT AFFIDAVIT OF SERVICE I, MARIA P. COGNETTI, ESQUIRE, do hereby certify that a tree and correct copy of the Order for Rule to Show Cause regarding Petition to Withdraw Appearance was served upon Danielle M. Lyda and Jeanne' B. Costopoulas, Esquire, counsel for Raymond R. Lyda, on the 5m day of December, 2003. Date: January ,~ ,2004 By: MARIA P. COGNETTI & ASSOCIATES MARIA P. ~OGNI~I, ESQUIRE Attorney I.D. No. 27914 210 Grandvicw Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Swom to and subscribed before me this ~vij day of '_._~3.~L~ ~ 2004. JNotary Public UN [~,~/Comm~ Expires May 16, 2006 DANIELLE M. LYDA, Plaintiff RAYMOND R. LYDA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-6289 CIVIL ACTION - LAW IN DIVORCE DANIELLE M. LYDA, : Plaintiff : RAYMOND R. LYDA, : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 00421 S 2001 PACSES Case ]Number 844103490/30696 IN SUPPORT ,~R OF COUR._T AND NOW, to wit, this ~ day of , '~ 2~Y~3 ) ~ 7 ,2004, upon consideration of the foregoing Motion to Make Rule Absolute of Petitioner, Maria P. Cognetti, Esquire, it is hereby ORDERED AND DECREED that Maria P. Cognetti, Esquire is permitted to withdraw as counsel for Respondent, Dani¢lle M. Askey, a/k/a, Daniell¢ M. Lyda. DANIELLE M. LYDA, Plaintiff RAYMOND R. LYDA, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-6289 CIVIL ACTION - LAW 1N DIVORCE PRAECIPE FOR WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdraw my appearance on behalf of Danielle M. Lyda, the Plaintiff in the above-captioned matter. Date: January 24, 2004 By: MARIA P. COG~NET~& ASSOCIATES MARIA P. COGN~TyI, ESQUIRE Attorney I.D. No. 27914 210 Grandview Avenue, Suite 102 Camp Hill, PA 17011 Telephone No. (717) 909-4060 Attorney for Plaintiff DANIELLE M. LYDA, Plaintiff RAYMOND R. LYDA, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-6289 CIVIL ACTION - LAW DIVORCE NOTICE TO THE PLAINTIFF IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTERAFFIDAVIT WITHIN TWENTY (20) DAYS AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or about March 17, 2001 and have continued to live separate and apart for a period of at least two 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. 4. I hereby verify that the statements made in this affidavit are tree and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Ra~i~"~d R. Lyda~ DANIELLE M. LYDA, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA RAYMOND R. LYDA, Defendant No. 2001-6289 CIVIL ACTION -. LAW : DIVORCE AFFIDAVIT OF NON-MILITARY SERVICE Date: 1. I, Raymond R. Lyda, am the Defendant in the above matter. 2. I personally know that the Plaintiff, Danielle M. Lyda, a.k.a. Danielle M. Askey, is over the age of eighteen (18) years. 3. The Plaintiff is not in the military or naval service of the United States or its allies or otherwise within the provisions of the Soldier's and Sailors Civil Relief Act of 1940 and its amendments. 4. I hereby verify that the statements made in this affidavit are tree and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unswom falsification to authorities. Ra~'~ R. LYda ~ DANIELLE M. LYDA, Plaintiff RAYMOND R. LYDA, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 2001-6289 : : CIV1L ACTION - LAW : 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 fights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. 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 32 South Bedford Street Carlisle, PA 17013-3308 (717) 249-3166 DANIELLE M. LYDA, Plaintiff RAYMOND R. LYDA, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 2001-6289 : : CIVIL ACTION - LAW : DIVORCE COUNTERCLAIM IN DIVORCE UNDER SECTION 3301(d) OF THE DIVORCE COrsE The Defendant, Raymond R. Lyda, by and through his attorney, Jeann6 B. Costopoulos, Esquire, avers the following: 1. The Plaintiff, Danielle M. Lyda, a.k.a. Danielle M. Askey, is an adult individual who currently resides at 450 South Third Street, Apt. 5, Lemoyne, Cumberland County, Pennsylvania 17055. 2. The Defendant, Raymond R. Lyda, is an adult individual who currently resides P.O. Box 83, New Bloomfield, Perry County, Pennsylvania 17068. 3. The plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Counterclaim. 4. The Plaintiff and the Defendant were married on April 14, 2000 in Etters, York County, Pennsylvania. COUNT I - DIVORCE 5. Paragraphs one (1) through four (4) are incorporated herein by reference as if set forth specifically below. 6. There have been no prior actions of divorce or for annulment between the parties other than the Complaint originally filed by Plaintiff at the above term and docket number. 7. The marriage is irretrievably broken. 8. The parties have been living separate and apart since on or about March 17, 2001. WHEREFORE, the Plaintiff respectfully requests this Honorable Court to grant the Defendant relief from the bonds of matrimony and order a Decree in Divorce. RESPECTFULLY SUBMITTED: Dated: BY: J~i~m6 B. Costopoulos, Esquire 5000 Ritter Road, Suite 202, Box 779 Mechanicsburg, Pennsylvania 17055 PA Supreme Court ID No. 68735 Telephone: (717) 790-9546 Fax: (717) 790-6019 ATTORNEY FOR DEFENDANT DANIELLE M. LYDA, Plaintiff RAYMOND R. LYDA, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 2001-6289 : : CIVIL ACTION - LAW : DIVORCE VERIFICATION I, Raymond R. Lyda, hereby verify that the statements made in the foregoing Counterclaim 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: Ra3~fb'~'~. Lyda ~ DANIELLE M. LYDA, Plaintiff Vo RAYMOND R. LYDA, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 2001-6289 : : CIVIL ACTION - LAW : DiVORCE AFFIDAVIT OF SERVICE TO THE PROTHONOTARY: I, Jeann6 B. Costopoulos, Esquire, verify that the Counterclaim in Divorce Under Section 3301 (d) of the Divorce Code, Affidavit Under Section 3301 (d)of the Divorce Code, Affidavit of Non-Military Service, and blank Counter-affidavit under Section 3301 (d) of the Divorce Code were served upon the Plaintiff indicated above February 7, 2004, by first class, Certified Mail No. 7000 1530 0001 6001 7971, postage prepaid, return receipt requested, restricted delivery, pursuant to the requiremems of Pa.R.C.P. § 1930.4. BY: Je os, Esquire 5000 Ritter Road, Suite 202, Box 779 Mechanicsburg, Pennsylvania 17055 PA .~llnr~m~, {~nll~t Ir) ~n fiR7q5 Dated: · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. A. Prfnted N~rne) 3. Service Ty0e [] Certified Mail [] Express Mail [] Registered [] Return Receipt for Merchandise [] Insured Mail [] C.O.D. (Transfer froro service laW) PS Form 381 1, August 2001 DANIELLE M. LYDA, Plaintiff Vo RAYMOND R. LYDA, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 2001-6289 : : CIVIL ACTION - LAW : DIVORCE AFFIDAVIT OF SERVICE I, Jeann6 B. Costopoulos, Esquire, verify that the Notice of Intention to File Praecipe to Transmit Record and Request Entry of Divorce Decree (with attached documents) and blank Counter-affidavit under Section 3301(d) of the Divorce Code was served upon the Plaintiff indicated above on March 1, 2004, by tn'st class, Certified Mail No. 7000 1530 0001 6001 8008, postage prepaid, return receipt requested, restricted delivery, pursuant to the requirements of Pa.R.C.P. §1930.4. BY: .-~~- Jeann6 B. Costopoulos, Esquire 5000 Ritter Road, Suite 202, Box 779 Mechanicshur~_ Penn~vlvania 17055 · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 1. Ar[icle Addressed to: 2. Article Number cr ns f o.,so et, 0 0 0 t 3 0 3. Service Type ~ertlfled Mail O Express Mail [] Fle~istefed O Return Receipt for Merchandise Ooot Ool Domestic Return Receipt PS Form 3811, August 2001 DANIELLE M. LYDA, Plaintiff RAYMOND R. LYDA, Defendant : 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2001-6289 CIVIL ACTION - LAW : DIVORCE NOTICE OF INTENTION TO FILE PRAECIPE TO TRANSMIT RECORD AND REQUEST ENTRY OF DIVORCE DECREE TO: Danielle M. Lyda a.k.a. Danielle M. Askey 450 South Third Street, Apt. 5 Lemoyne, PA 17043 VIA CERTIFIED RESTRICTED DELIVERY MAIL NO. 7000 1530 0001 6001 8008 Raymond R. Lyda, Defendant, intends to file with the Court the attached Praecipe to Transmit Record (with attached documents) on or after March 19, 2004, requesting that a ftnal decree in divorce be entered. BY: Jeann6 B. Costopoulos, Esquire 5000 Ritter Road, Suite 202, Box 779 Mechanicsburg, Pennsylvania 17055 PA Supreme Court ID No. 68735 Telephone: (717) 790-9546 Fax: (717) 790-6019 ATTORNEY FOR DEFENDANT DANIELLE M. LYDA, Plaimiff RAYMOND R. LYDA, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 2001-6289 : CIVIL ACTION - LAW : DWORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for Divorce: Irretrievable breakdown under §3301(d) of the Divorce Code. 2. Date and Manner of Service of the Counterclaim: Service by certified mail receipt no. 7000 1530 0001 6001 7971 on February 7, 2004. See attached Affidavit of Service. 3. Date of execution of the Defendant's affidavit required by §3301(d) of the Divorce Code: January 29, 2004; Date of service of the Defendant's affidavit upon the Plaintiff: February 7, 2004 by certified mail receipt no. 7000 1530 0001 6001 7971. See attached Affidavit of Service. 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file Praecipe to Transmit Record, a copy of which is attached: Service by certified mail on by certified mail receipt no. 7000 1530 0001 6001 8008. See attached Affidavit of Service. Dated: BY: Jean~6 B. Costopoulos, Esquire 5000 Ritter Road, Suite 202, Box 779 Mechaniesburg, Pennsylvania 17055 PA Supreme Court ID No. 68735 Telephone: (717) 790-9546 Fax: (717) 790-6019 ATTORNEY FOR DEFENDANT DANIELLE M. LYDA, Plaintiff RAYMOND R. LYDA, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2001-6289 : : CIVIL ACTION - LAW : DIVORCE AFFIDAVIT OF SERVICE TO THE PROTHONOTARY: I, Jeann6 B. Costopoulos, Esquire, verify that the Counterclaim in Divorce Under Section 3301(d) of the Divorce Code, Affidavit Under Section 3301(d) of the Divorce Code, Affidavit of Non-Military Service, and blank Counter-affidavit under Section 3301 (d) of the Divorce Code were served upon the Plaintiffindicated above February 7, 2004, by first class, Certified Mail No. 7000 1530 0001 6001 7971, postage prepaid, return receipt requested, restricted delivery, pursuant to the requirements ofPa. R.C.P. §1930.4. Dated: BY: Jeann6 B. Costopoulos, Esquire 5000 Ritter Road, Suite 202, Box 779 Mechanicsburg, Pennsylvania 17055 PA Supreme Court ID No. 68735 Telephone: (717) 790-9546 Fax: (717) 790-6019 ATTORNEY FOR DEFENDANT · Complete items 1, 2, and 3./Uso complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. (Transfer from service label) A, Signature If YES, enter delivery address below: [] NO 3. Service Type [~ Certified Mail [] Express Mail [] Regaitered [] Return Receipt for Merchandise _~ Insured Mail [] C.O.D. Restricted Delivery? (Extra Fee) Domestic Return Receipt 102595 O1-M-2509 DANIELLE M. LYDA, Plaintiff V. RAYMOND R. LYDA, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 2001-6289 CIVIL ACTION - LAW DIVORCE .AFFIDAVIT OF SERVICE I, Jeaun6 B. Costopoulos, Esquire, verify that the Notice of Intention to File Pmecipe to Transmit Record and Request Entry of Divome Decree (with attached documents) and blank Counter-affidavit under Section 3301(d) of the Divorce Code was served upon the Plaintiff indicated above on , by first class, Certified Mail No. 7000 1530 0001 6001 8008, postage prepaid, return receipt requested, restricted delivery, pursuant to the requirements ofPa. R.C.P. §1930.4. Dated: BY: anne B. Costopoulos, Esquire 5000 Ritter Road, Suite 202, Box 779 Mechanicsburg, Pennsylvania 17055 PA Supreme Court ID No. 68735 Telephone: (717) 7!90-9546 Fax: (717) 790-6019 ATTORNEY FOR DEFENDANT DANIELLE M. LYDA, Plaintiff RAYMOND R. LYDA, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 2001-6289 : : CIVIL ACTION - LAW : DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for Divorce: Irretrievable breakdown under §3301(d) of the Divorce Code. 2. Date and Manner of Service of the Counterclaim: Service by certified mail receipt no. 7000 1530 0001 6001 7971 on February 7, 2004. See attached Affidavit of Service. 3. Date ofexecntion of the Defendant's affidavit required by §3301(d) of the Divorce Code: January 29, 2004; Date of service of the Defendant's affidavit upon the Plaintiff: Februaw 7, 2004 by certified mail receipt no. 7000 1530 0001 6001 7971. See attached Affidavit of Service. 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file Praecipe to Transmit Record, a copy of which is attached: Service by certified mail on March 1, 2004 by certified mail receipt no. 7000 1530 0001 6001 8008. See attached Affidavit of Service. Dated: 5000 Ritter Road, Suite 202, Box 779 Mechanicsburg, Pennsylvania 17055 PA Supreme Court ID No. 68735 Telephone: (717) 790-9546 Fax: (717) 790-6019 ATTORNEY FOR DEFENDANT IN THE COURT OF COMB4ON PLEAS OF CUMBERLAND COUNTY STATE OF DANIELLE M. LYDA, Plaintiff VERSUS RAYMOND R. LYDA, Defendant PENNA. NO. 2001-6289 CIVIL TERM DECree 1N DIVORCE AND NOW, DECREED THAT AND DANIELLE M. LYDA , ~.~__~, IT IS ORDERED AND , PLAINTIFF, RAYMOND R. LYDA ,DEFENDANT, ARE DIVORCED PROM THE BONDS OF 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. BYTHe COURT: /7 // [ ATTES~ J' :~ROTHONOTARY