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Home My WebLink About09-5835l? LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff BY: Peter J. Russo PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com MIDORI TRIPPETT-McCAUSLIN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW DONALD JOHN McCAUSLIN, : NO. OR- 68,56 CIVIL TERM 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 nent may also be entered against you for any other claim or relief requested in these papers ?ud 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, 1 Courthouse Square, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Please of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. 2 V LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com MIDORI TRIPPETT-McCAUSLIN, Plaintiff V. DONALD JOHN McCAUSLIN, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 01- SP3 CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, COMES, the Plaintiff, Midori Trippett-McCauslin by an through her attorneys, Law Offices of Peter J. Russo, P.C. and avers the following in support of her complaint in divorce: 1. Plaintiff is Midori Trippett-McCauslin, an adult individual who has resided at 7329 Wertzville Road, Carlisle, Cumberland County, Pennsylvania since approximately 2001. 2. Defendant is Donald John McCauslin, an adult individual who has resided at 7329 Wertzville Road, Carlisle, Cumberland County, Pennsylvania since approximately 2001. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on February 18, 2000, in Carlisle, Cumberland County, Pennsylvania. 3 5. Plaintiff and Defendant separated on July 5, 2009. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and Plaintiff may have the right to request that the court require the parties to participate in counseling. COUNT I -- DIVORCE 9. The prior paragraphs of this Complaint are incorporated by reference as though fully set forth herein. 10. Plaintiff avers that the marriage between the parties is irretrievably broken. 11. Plaintiff requests the court to enter a decree in divorce. WHEREFORE, Plaintiff prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: That a decree in divorce be entered dissolving the marriage between the two parties. LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for am i Peter J. Russo, Esquire ID # 72897 Elizabeth J. Saylor, Esquire ID # 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 PH: (717) 591-1755 FX: (717) 591-1756 Date: ?_'n 4 MIDORI TRIPPETT-McCAUSLIN, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW DONALD JOHN McCAUSLIN, : NO. CIVIL TERM Defendant : IN DIVORCE VERIFICATION I, Midori Trippett-McCauslin, verify that the statements made in the foregoing document(s) are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: q Lo -????? Midori Trippett-McCauslin 5 PROTi-IONOTARY 2069 AUG 25 AM 10: 26 IN7 4&M . 50 Pj:s ATTY ut 3304 wr* aa47o5 LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com MIDORI TRIPPETT-McCAUSLIN, Plaintiff V. DONALD JOHN McCAUSLIN, Defendant Attorneys for Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 09-5835 IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complain in divorce originally filed in the above stated action on August 25, 2009. LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for amtiff C Peter J. Russo, Esquire ID #72897 Elizabeth J. Saylor, Esquire ID # 200139 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 PH: (717) 591-1755 FX: (717) 591-1756 Date: ?O13(ZL)j i " --- • LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com MIDORI TRIPPETT-McCAUSLIN, Plaintiff V. DONALD JOHN McCAUSLIN, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 09-5835 IN DIVORCE CERTIFICATE OF SERVICE I, Ashley R. Sipe, hereby certify that I am on this day serving a copy of the Praecipe to Reinstate Complaint upon the person(s) and in the manner indicated below: Certified Mail Returned Receipt Restricted Delivery to and/or via Personal Service on Donald John McCauslin 7329 Wertzville Road Carlisle, PA 17013 ?ANVA Z . ? Ashley U. Sipe, Paralegal Date: 10130t Q9 '7 THE F" TL-'?`°?10FAli 2009 OV --4 Ph 2= 5 ! RLi %%-S','} Yr"> 1,A, $10.00 PA fl zT 1 ? 3+ toa a3a9g5 ~.., ' R LAW OFFICES OF PETER J. RUSSO, P.C. BY: Peter J. Russo PA Supreme Court ID: 72897 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Telephone: (717) 591-1755 Facsimile: (717) 591-1756 Email: prusso@pjrlaw.com MIDORI TRIPPETT-McCAUSLIN, Plaintiff v. DCl~T ~. T ra, r.r1i TT~T ~1.! r+ ~ ~ TCri rl\I 11. ~c~iJt/.1 t11i1 Lrii.L~a.~vi~.ii v, Defendant Attorneys for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW UT''- nn C(~7.~ ~~~711 TEA-'T71~~ IN DIVORCE AFFIDAVIT OF SERVICE I, ~, )nfjnG ~ ~,~~c~~,r ,being duly sworn according to law, that I am over 18 years of age and not a party to the above-captioned action, served and made known to r---.., 1 '' ,~ on the ~th day of ~~L.OI)~~~~ ~' , 2009 at I~ a.m/~at a Complaint Under Section 3301 (c) or 3301 (d) of the Divorce Code and Praecipe to reinstate the Complaint issued in the above entitled case in the manner described below: ~~ ~~ ~~ Personally delivered them into the hands of the person to be served Adult family member with whom that person resides. Relationship is Agent or person in charge of person's office or usual place of business Other. Description of Recipient Sex: ~~~~ Facial Hair: (~,~ ,~ Age: ~~ Skin Color: ~~~~"~ ~ O /! Height (approx.): ~~ O Hair Color: I..,~t?~r~C ~~% Weight (approx.): ~ 'J~ r r _,, ..._.__ _ ~~ ~~ c~ a., ignature ~~`~~ ~~ Title Badge/ID # (if any) Address: 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 Phone Number: (717) 591-1755 ,.!~ ~ i~ t'Ih ~'~' T'-'" '~~~Rr' 2GG9P~u!i 30 f ii 3~ 23