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Home My WebLink About01-2786 MATI'HEW DUNN, : IN THE COURT OF COMMON PLEAS OF Plaintiff ~ CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2001. ~7~l~, CIVIL TERM : CIVIL ACTION - LAW CAMILLE GONNOUD DUNN, : Defendant : IN DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. jf you wish to defend against the claims set forth in the following pages, you must take prompt action. You are Warned that jf 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 PaJntJff. You may lose children. money or property or other rights important to you, ncluding custody or visitation of your When the ground for the divorce is indignities or irretrievable breakdown of the .marriage, you may request marriage Counseling. A JJst of marriage Counselors is available m the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 Matthew Dunn, Plaintiff : In The Court of Common Pleas of : Cumberland County, Pennsylvania V. " : No. 2001-~_~,£(.. Civil Term Camille Gonnoud Dunn, : Defendant : Civil Action- Law : In Divorce Mathew Dunn, Plaintiff, by and through his attorneys, SAIDIS, SHUFF, FLOWER & LINDSA¥, respectfully represents: 1. The Plaintiff is Matthew Dunn, who currently resides at 3803 Glennwood Avenue, Camp Hill, Cumberland County, Pennsylvania, where he has resided since August of 1999. 2. The Defendant is Camille Gonnoud Dunn, who currently resides at 1973 Jackson Ave, West Islip, Suffolk County, New York, where she has resided since April 4, 1968. 3. The Plaintiff has been a bona fide resident in the Commonwealth of Pennsylvania for at least six months immediately prfor to the filing of this Complaint. 4. The Plaintiff and Defendant were married on May 5, 1995, at Huntington, Long Island, New York. 5. There have been no prior actions of divorce or for annulment belween the Parties in this or in any other jurisdiction. 6. The Plaintiff avers that he is entitled to a divorce on the ground that the marriage is irretrievably broken and Plaintiff is Proceeding under Sections 3301 (c) and/or (d) of the Divorce Code. 7. Plaintiff has been advised of the availability of marriage counseling and of the right to request that the Court require the parties to participate in marriage counseling, and does not request counseling. WHEREFORE, Plaintiff requests the Court to enter a decree of divorce. SAIDI$, SHUFF, FLOWER & LINDSAY,. P.C. Attorneys for Matthew Dunn, Plaintiff Thomas E. Flower, Esquire iD # 83993 2109 Market Street Camp Hill, PA 17011 / / (717) 737-3405 Date:~- I O I VERIFICATION I, the undersigned, hereby ver~ that the statements made herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unswom falsification to authorities. Matthew Dunn, Plaintiff ...... .~,..' ........ PROTHONOTARY ' COMPLAINT REINSTATED .................... PROIHONOT^R¥ Matthew Dunn, In The Court of Common Pleas of Plaintiff : Cumberland County, Pennsylvania : v. : No. 2001-2786 Civil Term : Camille Gonnoud Dunn, Civil Action - Law Defendant : In Divorce PRAEClPE TO REINSTATE THE COMPLAINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned matter, which was originally filed on May 1, 2001. ^ time-stamped copy of the original complaint is attached hereto. SAIDI$, SHUFF, FLOWER & LINDSAY, P.C. Attorneys for Plaintiff ~omas E. Flower, Esquire \ ID # 83993 2109 Market Street Camp Hill, PA 17011 (717) 737 - 3405 ID: NOW 16'01 12:58 No.O03 P.O? MATTHEW DUNN, IN THE COURT OF COMMON PL 'F. AS Plaintiff OF CUMBERLAND COUNTY, I'ENNSYLVANIA v. No 2001-2786 Civil Term CAMILLE GONNOUD DUNIq, Civil Action - Law Defendant in Divorce PRAE(~IPE TO WITIIDRAW APPEARANCE To thc Prothonotary. Pursu-nt to PA. R.C.P. 1012, 'l'hom~ E F]owcr, E.~¢lUirC, hereby wilhdraws his appearance ~ attorney for Matthew Dram, thc Pl**~intffl' m th~ alx~vc c~q~tioned matter. Thoma.,~ E Fh~w~' SAIDIS, SIIUFF, FLOWER & LINDSA¥, P.C. 21 O0 Market Stre~ Camp Hill, PA 17011 PRA£Cl~ TO ENTER ~I'PEAR&NCE To th* Pmthonom'y: Please ¢m¢~ Ibc appeamn¢~ of the Family Law Clinic tm behalf of Matthew Dunn, thc Plaintiff, in lhe above captioned matter. C~¢d~... t~---Leg"l In~~ ~II~ERT It. RAINS TltOMAR M. 'I'I!.RI L. IIENNING Supervising Attomcy~ F^MIL¥ i.AW CLINIC 45 N(~lh Pitt Street Cra'Ii'dc, PA 1701] (7 ~ 7) ~4~-;~0~,~ RECEIVED 1 MA'ITHEW DUNN, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 2001-2786 Civil Term CAMILLE GONNOUD DUNN, Civil Action - Law Defendant In Divorce CERTIFICATE OF SERVICE I, Lily L. Cheung, of the Family Law Clinic, hereby certify that I am serving a true and correct copy of the Praecipe to Withdraw/Enter Appearance on the following persons at the addresses indicated below by depositing a copy of the same in the United States mail, First Class, postage prepaid, this 7-~ay of November, 2001. Camille Gonnoud Dunn 1973 Jackson Ave. West Islip, NY 11795-1931 Thomas E. Flower, Esq. 2109 Market Street Camp Hill, PA 17011 Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 MATTHEW DUNN, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, : PENNSYLVANIA v. : No. 2001-2786 Civil Term : CAMILLE GONNOUD DUNN, : Civil Action - Law Defendant : In Divorce PRAI~CIPE TO REINSTATE TIlE COMPLAIiN~Y To the Prothonotary: Please reinstate the complaint in the above-captioned case. Certified Legal Intern Robert E. Rains SUPERVISING ATTORNEYS Teri L. Henning STAFF ATTORNEY FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 Attorneys for Plaintiff Dated: tt]Z.~/ol MATTHEW DUNN, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, : PENNSYLVANIA v. : No. 2001-2786 Civil Term CAMILLE GONNOUD DUNN, : Civil Action - Law Defendant : In Divorce PRAECIPE TO REINSTATE THE COMPLAINT To the Prothonotary: Please reinstate the complaint in the above-captioned ease. Lil~t L. Clleung Certified Legal Intern Robert E. Rains SUPERVISING ATTORNEYS Teri L. Henning STAFF ATTORNEY FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 Attorneys for Plaintiff Dated: MATTHEW DUNN, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, : PENNSYLVANIA v. : No. 2001-2786 Civil Ti:tm CAMILLE GONNOUD DUNN, : Civil Action - Law Defendant : In Divorce PRAECIPE TO REINSTATE THE COMPLAINT To the Prothonotary: Please reinstate the complaint in the above-captioned case. LiI~L. Cheung Certified Legal Intern Robert E. Rains SUPERVISING ATTORNEYS Lucy Johnston-Waish STAFF ATTORNEY FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 Attorneys for Plaintiff MATI~HEW DUNN, : IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, : PENNSYLVANIA v. : No, 2001-2786 Civil Term CAMILLE GONNOUD DUNN, : Civil Action - Law Defendant : In Divorce RETURN OF SERVICE I, Lily L. Cheung, hereby certify that I am a competent adult and that I served a true and correct copy of the Complaint for Divorce on the Defendant, Camille Gonnoud Dunn, by hand delivery at the Cumberland County Prison, 1101 Claremont Road, Carlisle, PA 17013, on the [ day of April, 2002, at I verify that the statements made in this Return of Service 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. Certified Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968