HomeMy WebLinkAbout04-6465
JAY DAINTY,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
Vs.
CIVIL ACTION - DIVORCE
NO. CIVIL TERM
JACQUELINE DAINTY
Defendant
IN DIVORCE
NOTICE
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 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
32 BEDFORD STREET
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
SAIDIS SAIDIS, SHUFF, FLOWER & LINDSAY
SHUFF, FLOWER
& LINDSAY Attorneys fo Plaint
ATTORNEYS-AT-LAW
1
26 W. High Street
C
PA
li
l
By.
ar
s
e,
Cy rol . Lindsa , Esquire
# 693
26 West High Street
Carlisle, PA 17013
(717) 243-6222
JAY DAINTY,
Plaintiff
VS.
JACQUELINE DAINTY
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. CIVIL TERM
IN DIVORCE
COMPLAINT
Jay Dainty, Plaintiff, by attorneys, SAIDIS, SHUFF, FLOWER & LINDSAY, respectfully
represents:
1. The Plaintiff is Jay Dainty, who currently resides at 1325 White Birch Lane,
Carlisle, Cumberland County, Pennsylvania, 17013 where he has resided since July,
2004.
2. The Defendant is Jacqueline Dainty, who currently resides at P.O. Box 1412
Manati, Puerto Rico 00764 , where she has resided since June 2004.
3. The Plaintiff has been bona fide resident in the Commonwealth of
Pennsylvania for at least six months immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on July 4, 1987 at Puerto Rico.
5. That there have been no prior actions of divorce or for annulment between
SAIDIS the parties in this or in any other jurisdiction.
SHUFF, FLOWER
& LINDSAY
AWORNEYS•AT•LAW 6. The Plaintiff avers that he is entitled to a divorce on the ground that the
26 W. High Street
Carlisle, PA 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.
SAIDIS, SNUFF, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATTORNEYS-AT-LAW
26 W. High Street
Carlisle, PA
By:
Date: 1 `7i f
Caron. IC # 446V)r
26 West High Street
Carlisle, PA 17013
(717) 243-6222
VERIFICATION
I, the undersigned, hereby verify 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 unsworn falsification to authorities.
Date: ??, r6/off
SAIDIS
SHUFF, FLOWER
& LINDSAY
A17ORNEYS•AT•LAW
26 W. High Street
Carlisle, PA
Ud ? a
0
- l
1
JAY DAINTY,
Plaintiff
JACQUELINE DAINTY IN DIVORCE
Defendant .
VS. CIVIL ACTION - DIVORCE
NO. 04-6465 CIVIL TERM
PRAECIPE TO REINSTATE DIVORCE COMPLAINT
TO THE PROTHONOTARY:
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Please reinstate the Divorce Complaint in the above captioned case.
SAIDIS, SHUFF, FWVYER & LINDSAY
Date: J I 2-01t; y By:
I D # 4469
26 Wag High Street
Carlisle, PA 17013
(717) 243-6222
SAIDIS
SNUFF, FLOWER
& LINDSAY
ATTORNEVS•AT•IAW
26 W. High Street
Carlisle, PA
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)AY DAINTY,
Plaintiff
VS.
JACQUELINE DAINTY,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - DIV?RCE
NO. 04-6465 CI IL TERM
IN DIVORCE
?I
I
TO THE PROTHONOTARY:
SAIDIS
SHUFF, FLOWER
& LINDSAY
Please reinstate the Divorce Complaint in the above
Date:
SAIDIS, SHI111,
By:
Carol J.
ID#4?
26 Wes
Carlisle,
(717) 2
case.
& LINDSAY
h Street
17013
26 W. High Street
Carlisle, PA
r.
?:
JAY DAINTY,
Plaintiff
V.
JACQUELINE DAINTY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-6465 CIVIL TERM
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 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 the Cumberland County Court House, Carlisle, Pennsylvania.
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
Telephone No. (717) 249-3166 or 1-800-990-9108
Sandra L. Meilton, Esquir6, #32551
Attorney for Plaintiff
TUCKER ARENSBERG, P.C.
P.O. Box 889
Harrisburg, PA 17108
(717) 234-4121
JAY DAINTY,
Plaintiff
V.
JACQUELINE DAINTY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-6465 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
AND NOW comes Defendant, Jacqueline Dainty, also known as Jacqueline Lamboy, by
and through her counsel, Sandra L. Meilton, Esquire, of Tucker Arensberg, P.C., and files the
within Petition Equitable Distribution, Alimony, Alimony Pendente Lite, Counsel Fees and
Expenses:
1. Plaintiff and Defendant are the owners of various items of personal property,
furniture and household furnishings acquired during their marriage which are subject to equitable
distribution by this court.
2. Plaintiff and Defendant are the owners of various motor vehicles, bank accounts,
insurance policies and retirement benefits acquired during their marriage which are subject to
equitable distribution by this court.
COUNT II:
CLAIM FOR ALIMONY UNDER THE DIVORCE CODE
Defendant has inadequate means of support for herself except as provided for by
Plaintiff.
4. Plaintiff is employed with the United States Army and has a gross monthly income
of $8,478.
Defendant is not employed since she is currently studying to become a licensed
real estate broker.
COUNT III:
CLAIM FOR ALIMONY PENDENTE LITE, COUNSEL FEES AND
EXPENSES UNDER THE DIVORCE CODE
5. Defendant does not have sufficient funds to support herself and pay counsel fees
and expenses incidental to this action.
6. Plaintiff is full well and able to pay Defendant Alimony, Alimony Pendente Lite,
counsel fees and expenses incidental to this divorce action.
WHEREFORE, Defendant requests the Court to:
A. Equitably distribute all property owned by the parties hereto;
B. Direct the Plaintiff to pay Alimony to the Defendant;
C. Direct the Plaintiff to pay Alimony Pendente Lite and Defendant's counsel fees and
the costs of this proceeding; and
D. Grant such further relief as the Court may determine equitable and just.
Respectfully submitted,
TUCKER ARENSBERG, P.C.
BY: 6th ?/
Sandra L. Meilton (1/1). #32551)
111 North Front St., P.O. Box 889
Harrisburg, PA 17108-0889
Dater V• , 2005 ATTORNEYS FOR DEFENDANT
VERIFICATION
I, Jacqueline Lamboy, acknowledge that the facts stated in the within document are true
and correct to the best of my knowledge, information and belief.
I understand that any false statements herein are made subject to the penalties of 18
Pa.C.S. Section 4904 relating to unsworn falsification to authorities.
7
acqu the Lamboy a/k/a Jac eline Dainty
DATED: AjDV j S- , c S
CERTIFICATE OF SERVICE
AND NOW, this 30th day of November, 2005, I, Gloria M. Rine, Paralegal to Sandra L.
Meilton, Esquire, for the firm of Tucker Arensberg, P.C., hereby certify that I have this day served
a copy of the within document, by mailing same by first class mail, postage prepaid, addressed as
follows:
Carol J. Lindsay, Esquire
26 W. High Street
Carlisle, PA 17013
Gloria M. Rine
82725.1
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In the Court of Common Pleas of CUMBERLAND County, Pennsylvania
DOMESTIC RELATIONS SECTION
JAQUELINE LAMBOY ) Docket Number ? 6465 CIVIL
Plaintiff )
vs. ) PACSES Case Number 957107874
JAY DAINTY )
Defendant } Other State ID Number
ORDER
AND NOW, to wit on this 19TH DAY OF JUNE, 2006 IT IS HEREBY
ORDERED that the Q Complaint for Support or Q Petition to Modify or ® Other
ALIMONY PENDENTE LITE filed on DECEMBER 7, 2005 in the above captioned
matter is dismissed without prejudice due to:
PURSUANT TO THE PARTIES' STIPULATION OF DECEMBER 13, 2005 AND PETITIONER
WITHDRAWING HER REQUEST FOR APL.
Q The Complaint or Petition may be reinstated upon written application of the plaintiff
petitioner.
B C
,.1 G
Edgar B. Bayley. JUDGE
DRO: R.J. Shadday Form OE-506
Service Type M Worker ID 21005
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JAY DAINTY,
Plaintiff
V.
JACQUELINE DAINTY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 04-6465 - CIVIL TERM
IN DIVORCE
PETITION FOR SPECIAL RELIEF TO CONFIRM
SERVICE OF COMPLAINT IN DIVORCE
AND NOW, comes Jay Dainty, by and through his counsel, Saidis, Flower & Lindsay,
and petitions this Honorable Court as follows:
1. The parties hereto are husband and wife, having been joined in marriage on
July 4, 1987.
2. Plaintiff resides in Carlisle, Pennsylvania and Defendant resides at North
Coast Village, Number 654 Dell Condominio, Vega Alta, Puerto Rico.
3. On December 27, 2004, Plaintiff filed a Complaint in Divorce, a copy of which
is attached hereto as Exhibit "A".
4. On January 25, 2005, a certified copy of the Complaint was sent by first class
mail to Defendant asking her cooperation in accepting service. A copy of that letter is
attached hereto as Exhibit "B".
5. Defendant did not sign an Acceptance of Service. However, the letter and
SA 11S,
FIAWER ?
LINDSAY
ATT0WqEYS.M:?W
26 West High Street
Carlisle, PA
Complaint was not returned to the undersigned as undelivered or undeliverable.
6. The Complaint was reinstated on April 4, 2005. Suspecting that Defendant
was avoiding service, Plaintiff retained Alberto Diaz, a process server in Puerto Rico, on April
4, 2005. A copy of the letter to Mr. Diaz is attached hereto as Exhibit "C".
7. Mr. Diaz reported to the undersigned that he could not effect service because
the Defendant had instructed the security guard at the gate of her apartment complex not to
admit Mr. Diaz.
8. On June 7, 2006, Sandra L. Meilton, Esquire wrote to the undersigned
indicating that she had been retained by Defendant and on or about November 30, 2005, Ms.
?I Wilton filed a Petition for Equitable Distribution, Alimony, Alimony Pendente Lite, Counsel
Fees and Costs to the caption of the divorce case. A copy of the Petition is attached hereto
as Exhibit "D".
9. Plaintiff desires to seek the appointment of the Master and has been advised
by the Prothonotary's Office that absent proof of service, he may not proceed further.
10. Service is proven by the Petition for Economic Relief filed to the divorce action
by counsel for Defendant. McCullough v. Clark, et al., 2001 Pa. Super. 275, 784 A.2d 156
(2001); Jeannette Borough v. Roehme, 9 Pa. Superior Ct. 33.
11. Defendant's counsel has been asked to file an Acceptance of Service on
behalf of Defendant, but unsure of counsel's relationship to the Defendant, is reluctant to do
so.
12. Plaintiff has no objection to counsel for Defendant withdrawing from
representation if that is counsel's intention, but believes that a Complaint has been
constructively served on Defendant through counsel by counsel's entry by filing a Petition for
Economic Relief in the divorce case.
WHEREFORE, Petitioner prays this Honorable Court to enter an Order
Respectfully submitted,
SAIDIS„FLOWER &UNWAY
SAIDIS,
L * DSAY
26 West High Street
Carlisle, PA
Carol T Lindsay, Este
Supreme Court IO W. 44693
26 West High Street
Carlisle, PA 17013
717-243-6222
Dated: ?' 2-q t(k
I .a IN
JAY DAINTY, IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
Vs. CIVIL ACTION - DIVORCE
NO. D if_ 6 Y,& CIVIL TERM
N r'1
JACQUELINE DAINTY IN DIVORCE ?-
`T-
Defendant - -?
NOTICE -'
YOU HAVE BEEN SUED IN COURT. If you wish to defend against_:_the ciait s sefi ^
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 ors: annuimerrt.
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 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 ASSOCIA T ION
32 BEDFORD STREET
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
SAIDIS
SHUFF, FLOWER
& LINDSAY
1 TORNEYS•AT•LAW
26 W. High Street
Carlisle, PA
SAIDIS, SHUFF, FLOWER & LINDSAY
Attorneys for Plainti
By:
?'°'"?•?? +=?" Carol .Lindsa
MN , it 7r.
HL ,
zp._ I D 693
W said
4 PT
26 West High St
Carlisle, PA 17C
(717) 243-6222
Esquire
i
JAY DAINTY, IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
VS. CIVIL ACTION - DIVORCE
NO. CIVIL TERM
JACQUELINE DAINTY IN DIVORCE
Defendant
COMPLAINT
Jay Dainty, Plaintiff, by attorneys, SAIDIS, SHUFF, FLOWER & LINDSAY, respectfully
represents:
1. The Plaintiff is Jay Dainty, who currently resides at 1325 White Birch Lane,
Carlisle, Cumberland County, Pennsylvania, 17013 where he has resided since July,
2004.
2. The Defendant is Jacqueline Dainty, who currently resides at P.O. Box 1412
Manati, Puerto Rico 00764 , where she has resided since June 2004.
3. The Plaintiff has been bona fide resident in the Commonwealth of
Pennsylvania for at least six months immediately prior to the filing of this Complaint.
4. The Plaintiff and Defendant were married on July 4, 1987 at Puerto Rico.
5. That there have been no prior actions of divorce or for annulment between
SAIDIS
SHUFF, FLOWER
& LINDSAY
ATTORNEYS-AT-LAW
26 W. High Street
Carlisle, PA
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.
Date:
SAIDIS
SHUFF, FLOWER
& LINDSAY
AT 0RNEYS•AT•I AW
26 W. High Street
Carlisle, PA
SAIDIS, SHUFF, FLOWER & LINDSAY, P.C.
Attorneys for Plaintiff
By:
CarorJ. L,3 ds r Esqu
D # 446 26 West High Street
Carlisle, PA 17013
(717) 243-6222
VERIFICATION
f, the undersigned, hereby verify 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 unsworn falsification to authorities.
c
Jay ain/y
Date: /a?n,%
SAIDIS
`TUFF, FLOWER
& LINDSAY
A7TORNEYS•AT•E
26 W. High Street
Carlisle, PA
JOHN E. SLIKE
ROBERT C. SAIDIS
GEOFFREY S. SHUFF
JAMES D. FLOWER, JR
CAROL J. LINDSAY
BRIAN C. CAFFREY
GEORGE RDOUGLAS, III
MATTHEW J. ESHELMANt
THOMAS E. FLOWER
LINDSAY GINGRICH MACLAY
JACLYN SMITH
LAW OFFICES
SAIDIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST HIGH STREET
CARLISLE, PENNSYLVANIA 17013
TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486
EMAIL: attorney@ssfl-law.com
www.ssfl-law.com
January 25, 2005
Jacqueline Dainty
North Coast Village, Apt. 654
Vega Alta, Puerto Rico 00692
Dear Ms. Dainty:
REPLY TO CARLISLE
This letter will introduce me as the attorney for Jay Dainty. Your husband has requested that I
file a Complaint in Divorce and I have done that. I enclose a certified copy for you and an
Acceptance of Service. Would you please sign the Acceptance and return it to me in the
envelope enclosed. The purpose of the Acceptance of service is simply to let the court know
that you received notice of the filing.
You and Jay may obtain a Decree in Divorce after 90 days from the date on your acceptance of
service if the two of you have also resolved outstanding issues such as the division of your
property. We also need to formalize your child support. I will be providing a stipulation for child
support that can be entered as a court order and I will forward that to you as soon as Jay has
had an opportunity to review it.
I suggest that you seek counsel in Pennsylvania to assist you as you go through this process.
Please have counsel give me a call. I will be happy to respond directly with counsel. In the
meantime, Jay will be preparing an offer of settlement and we will be forwarding it to you as
soon as we have it.
Very truly yours,
CJL:ap
Enclosure
cc: Jay Dainty
CAMP HILL OFFICE:
2109 MARKET STREET
CAMP HILL, PA 17011
TELEPHONE: (717)737-3405
FACSIIvIILE: (717)737-3407
tBoard Certified Creditors'
Rights Representation
Saidis, Shuff, Flower &-Lindsay
Carol J. Lindsay
JAY DAINTY,
Plaintiff
vs.
JACQUELINE DAINTY
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - DIVORCE
NO. 04-6465 CIVIL TERM
IN DIVORCE
ACCEPTANCE OF SERVICE
i, JACQUELINE DAINTY, Defendant above, accept service of the Complaint in
SAIDIS
SHUFF, FLOWER
& LINDSAY
Divorce in the above captioned matter.
Date
Jacqueline Dainty, Defendant
zU w. nign nrreer
Carlisle, PA
LAW OFFICES
SAIDIS, SHUFF, FLOWER & LINDSAY
A PROFESSIONAL CORPORATION
26 WEST HIGH STREET
JOHN E. SLIKE CARLISLE, PENNSYLVANIA 17013 CAMP HILL OFFICE:
ROBERT C. SAIDIS TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 2109 MARKET STREET
GEOFFREY S. SHUFF EMAIL: attorney@ssfl-law.com CAMP HI LL,
I / o i
JAMES D. FLOWER, JR
v.-1aw.com TELEPHONE: (717)737--,4w.
CAROL 1. LINDSAY FACSIMILE: (7177)7_17-1-4o-
BRIAN C. CAFFREY
GEORGE F. DOUGLAS, III tBoard Certified Cretim-
MATTHEW J. ESHELMANt Rights Representw!-
THOMAS E. FLOWER
JACLYN SMITH REPLY TO CARLIS(-I=
April 4, 2005
Roberto Diaz
All Puerto Rico Legal Service
Alt. De Covadonga
Calle Salvador Brua #D-1-A
Toa Baja, PR 00949
Dear Mr. Diaz:
FILE COPY
This letter will introduce me as the attorney for Jay Dainty, on whose behalf I have filed a
Complaint in Divorce in Cumberland County, Pennsylvania. Please serve the enclosed certified
copy on his wife, Jacqueline Dainty, within 30 days.
Our information is that Ms. Dainty resides at North Coast Village, Apt. 654, Vega Alta, Puerto
Rico, 00692.
I enclose a check for $150.00 to cover the cost of service, as you indicated in your
communications with my Paralegal, Sharon. I also enclose an Affidavit of Personal Service.
Please send the notarized affidavit of service to me at the Carlisle address listed above. If you
have any questions or need more information give me a call. Thank you for your assistance.
Very truly yours,
SAIDIS, SHUFF, FLOWER & LINDSAY, P.C.
Carol J. Lindsay, Esq ire
UL/sam
Enclosures
cc: )ay Dainty
SUN 0 s 2009
TucKER?ARENSBERG
June 7, 2005
Carol J. Lindsay, Esquire
26 W. High Street
Carlisle, PA 17013
RE: Lamboy
Dear Carol:
Sandra L. Wilton
smeilton@tuckerlaw.com
Please be advised that our office has been retained to represent Jacqueline Lamboy in
connection with her current domestic situation. Jacqueline and I did speak by phone
and the first issue to be cleared up is Mr. Dainty's support/alimony payments. Ms.
Lamboy advises me that he had previously been sending her $1,500.00 per month in
child support and an additional $1,500.00 per month spousal support; however, he has
now advised her that he will only be paying her $1,500.00 per month (presumably for
child support). Even though I did not have accurate figures for Mr. Dainty's income, my
calculations, based on estimated figures, show that Mr. Dainty should in fact, be paying
more than the $3,000.00 he had previously paid. In addition, as you may be aware, the
children attend private school and the private school tuition is $560.00 per month for
eleven months of the year. The tuition payment for the twelfth month is $1,500.00.
Please give me a call so that we can discuss the support and, hopefully, avoid the
necessity for Ms. Lamboy to file with Domestic Relations for support,
I look forward to hearing from you.
Sincerely,
TUCKER ARENSBERG, P.C.
Sandra L. Me Iton
SLM/smk
cc: Ms. Jacqueline Lamboy
Tucker Arensberg, P.C. 111 North Front Street P.O. Box 889 Harrisburg, PA 171,08
p. 800.257.4121 p. 717.234.4121 f. 717.232.6802
co py
JAY DAINTY,
Plaintiff
V.
JACQUELINE DAINTY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 04-6465 CIVIL TERM
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 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 the Cumberland County Court House, Carlisle, Pennsylvania.
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
Telephone No. (717) 249-3166 or 1-800-990-9108
Sandra L. Meilton, Esquir , #32551
Attorney for Plaintiff
TUCKER ARENSBERG, P.C.
P.O. Box 889
Harrisburg, PA 17108
(717) 234-4121
JAY DAINTY,
Plaintiff
V.
JACQUELINE DAINTY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 04-6465 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
DEFENDANT'S PETITION FOR EQUITABLE DISTRIBUTION, ALIMONY,
ALIMONY PENDENTE LITE, COUNSEL FEES AND EXPENSES
AND NOW comes Defendant, Jacqueline Dainty, also known as Jacqueline Lamboy, by
and through her counsel, Sandra L. Meilton, Esquire, of Tucker Arensberg, P.C., and files the
within Petition Equitable Distribution, Alimony, Alimony Pendente Lite, Counsel Fees and
Expenses:
COUNT I:
CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
UNDER THE DIVORCE CODE
1. Plaintiff and Defendant are the owners of various items of personal property,
furniture and household furnishings acquired during their marriage which are subject to equitable
distribution by this court.
2. Plaintiff and Defendant are the owners of various motor vehicles, bank accounts,
insurance policies and retirement benefits acquired during their marriage which are subject to
equitable distribution by this court.
COUNT II:
CLAIM FOR ALIMONY UNDER THE DIVORCE CODE
3. Defendant has inadequate means of support for herself except as provided for by
Plaintiff.
4. Plaintiff is employed with the United States Army and has a gross monthly income
of $8,478.
Defendant is not employed since she is currently studying to become a licensed
real estate broker.
COUNT III:
CLAIM FOR ALIMONY PENDENTE LITE COUNSEL FEES AND
EXPENSES UNDER THE DIVORCE CODE
5. Defendant does not have sufficient funds to support herself and pay counsel fees
and expenses incidental to this action.
6. Plaintiff is full well and able to pay Defendant Alimony, Alimony Pendente Lite,
counsel fees and expenses incidental to this divorce action.
WHEREFORE, Defendant requests the Court to:
A. Equitably distribute all property owned by the parties hereto;
B. Direct the Plaintiff to pay Alimony to the Defendant;
C. Direct the Plaintiff to pay Alimony Pendente Lite and Defendant's counsel fees and
the costs of this proceeding; and
D. Grant such further relief as the Court may determine equitable and just.
Respectfully submitted,
TUCKER ARENSBERG, P.C.
BY:
Sandra L. Meilton (I . #32551)
111 North Front St., P.O. Box 889
Harrisburg, PA 17108-0889
Dater ?- cl , 2005 ATTORNEYS FOR DEFENDANT
VERIFICATION
I, Jacqueline Lamboy, acknowledge that the facts stated in the within document are true
and correct to the best of my knowledge, information and belief.
I understand that any false statements herein are made subject to the penalties of 18
Pa.C.S. Section 4904 relating to unsworn falsification to authorities.
Jacqu' ne Lamboy a/k/a Jac eline Dainty
DATED: kbf
S , o
CERTIFICATE OF SERVICE
AND NOW, this 30th day of November, 2005, I, Gloria M. Rine, Paralegal to Sandra L.
Meilton, Esquire, for the firm of Tucker Arensberg, P.C., hereby certify that I have this day served
a copy of the within document, by mailing same by first class mail, postage prepaid, addressed as
follows:
Carol J. Lindsay, Esquire
26 W. High Street
Carlisle, PA 17013
Gloria M. Rine
82725.1
VERIFICATION
I verify that the statements made in the foregoing document 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 falsifications to authorities.
/JD nty
Date:
SAIDIS,
FLOWER &
LINDSAY
nT UR EYSAT-uw
26 West High Street
Carlisle, PA
CERTIFICATE OF SERVICE
On the day of .? k q ?.'_, 2006, I, Carol J. Lindsay, Esquire, of the law firm of
SAIDIS, FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document
was served on the following individual, via certified mail, return receipt requested, postage
prepaid, addressed as follows:
Sandra L. Meilton, Esquire
Tucker Arensberg
P.O. Box 889
Harrisburg, PA 17108
SAIDIS, FLOWER & LINDSAY
Carol J. Lindsay, Esquire
Supreme Court ID No. 44693
26 West High Street
Carlisle, PA 17013
717-243-6222
SAIDIS,
FLOWER &
LINDSAY
ATTUR MAT-yaw
26 West High Street
Carlisle, PA
r io C)
JAY DAINTY,
PLAINTIFF
V.
JACQUELINE DAINTY,
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: 04-6465 CIVIL TERM
ORDER OF COURT
AND NOW, this _ rA,^ day of October, 2006, defendant, through
counsel, having entered an appearance and filed a petition for economic relief in this
divorce action, the complaint filed by plaintiff is deemed served.
By the Co
arol J. Lindsay, Esquire
For Plaintiff
Xndra L. Meilton, Esquire 1
For Defendant
sal
Edgar B.
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C5 N
JAY DAINTY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW OCT 0 5 2006?1
JACQUELINE DAINTY, NO. 04-6465 CIVIL TERM
Defendant DIVORCE
RULE TO SHOW CAUSE
AND NOW, this day of y t_ , 2006, upon consideration of
the Petition to Withdraw as Counsel, a Rule is issued upon Defendant, Jacqueline Dainty, and
Carol J. Lindsay, Esquire, counsel for Defendant, to show cause why Sandra L. Meilton and
TUCKER ARENSBERG, P.C., should not be granted leave to withdraw as counsel for
Jacqueline Dainty in this case.
RULE RETURNABLE t 0 DAYS FROM THE DATE OF SERVICE. Service shall be
accomplished by first class mail to Defendant and Plaintiffs counsel.
BY THE COURT:
J.
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JAY DAINTY, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
NO. 04-6465
JACQUELINE DAINTY,
Defendant IN DIVORCE
PRAECIPE TO WITHDRAW APPEARANCE
TO THE PROTHONOTARY:
Please withdraw my appearance on behalf of the Plaintiff, Jay Dainty, in the above
captioned case.
SAIDIS, FLOW ER.&_LINDSAY
Carol J. Lindsa , E uire
o. 44693
Supreme Cou Wet
26 West High Carlisle, PA 17013
717-243-6222
Dated: 11) - j c - 0 C,
PRAECIPE TO ENTER APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance on behalf of the Plaintiff, Jay Dainty, in the above
captioned case.
y inty, prose
325 White Birch ne
Carlisle, PA 17013
717-245-1221
SAIDIS, Dated: p -, _0 4
FLOWER &
LINDSAY
ATWM%-f'S•19 uw
26 West High Street
Carlisle, PA
CERTIFICATE OF SERVICE
On this t1 day of 6'k r Jav" 2006, I, hereby certify that on this date a
copy of the attached document was served on the following individuals, via first class mail,
postage prepaid, addressed as follows:
Jacqueline Dainty
P.O. Box 1412
Manati, Puerto Rico 00764
AY
SAIDIS. FLOWER & L,lNDS
iris
Carol J. LindsdyFet
Supreme Court 44693
26 West High St Carl
isle, PA 17013
717-243-6222
SAIDIS,
FLOWER Si
LINDSAY
ATTDI vs•.v uw
26 West High Street
Carlisle, PA
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JAY DAINTY,
Plaintiff
V.
JACQUELINE DAINTY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 04-6465 CIVIL TERM
DIVORCE
PETITION TO MAKE RULE ABSOLUTE
AND NOW, comes the Petitioner, Sandra L. Meilton, and Tucker Arensberg, P.C.,
and petitions this Honorable Court as follows:
1. A certified copy of the Petition to Withdraw as Counsel filed by Petitioner in
the above matter, along with a copy of the Rule dated October 6, 2006 entered by the
Honorable J. Wesley Oler, Jr. were served on Defendant and Plaintiffs counsel as follows:
(a) On Defendant by letter dated October 10, 2006 mailed to
Defendant's last know address. Said mailing is evidenced by the attached Certificate of
Mailing attached hereto and marked Exhibit "A".
(b) On Plaintiffs counsel by copy of a letter dated October 10, 2006
(noted above) addressed and mailed to the Defendant.
3. Said Rule gave Defendant and Plaintiffs counsel ten (10) days to respond
after service.
4. More than ten days has elapsed since service and to Petitioner's knowledge
as of the filing of this Petition, no responses have been received by Petitioner or filed with this
Honorable Court by Defendant or Plaintiffs counsel.
WHEREFORE, Petitioner respectfully requests that this Honorable Court make the
Rule absolute and allow Petitioner to withdraw as counsel for Defendant in the above
matter.
TUCKER ARENSBERG. P.C.
By:
Sandra L. Meilton, No. 32551
P.O. Box 889
Harrisburg, PA 17108
(717) 234-4121
Petitioner
COMMONWEALTH OF PENNSYLVANIA )
ss:
COUNTY OF DAUPHIN )
Personally appeared before me, a Notary Public in and for said Commonwealth
and County, Sandra L. Meilton, who, being duly sworn according to law, deposes and says that
she is the attorney for Defendant in the within action; that she takes this Affidavit as the
Petitioner in the foregoing Petition to Make Rule Absolute as the matters are procedural or refer
to matters within the knowledge of counsel and that the facts set forth in the foregoing Petition
are true and correct to the best of her knowledge, information and belief.
andra L. Meilton
Sworn to and subscribed
before me this ?2U day
of October, 2006.
. ? r
Notary Public
(SEAL)
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U.S. POSTAL SERVICE CERTIFICATE OF MAILING
MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL, DOES NOT
PROVIDE FOR INSURANCE-POSTMASTER uJ 2
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Received From: Sandra L. Menton, Esquire 2
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Tucker Arensberg, PC vP <r ? p
P . Box
Harrisburg, PA 1/101,
One piece of ordinary mail addressed to:
Jacqueline Iamboy
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Iiorul cast Village, v654
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Vega Alta Puerto Rica 00692
7 a
PS Form 3817, January 2001
CERTIFICATE OF SERVICE
AND NOW, this c?S day of ?G 2006, I, Gloria M. Rine,
Paralegal to Sandra L. Meilton, Esquire, for the firm of Tucker Arensberg, P.C, hereby certify that I
have this day served a copy of the within document, by mailing same by first class mail, postage
prepaid, addressed as follows:
Ms. Jacqueline Lamboy
North Coast Village, #654
Vega Alta, Puerto Rico 00692
Carol J. Lindsay, Esquire
26 W. High Street
Carlisle, PA 17013
Gloria M. Rine
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TAY bA o (u:a IN TBE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
Vs.
Docket No.Tyr{(? 5
JACOU C LE /AAA
Defendant
?? a.av a ava N a- vas &ILA a vai a aV - i % a va XVAA- Y a a7a'k
J 4C k I N (Plainti (Defendant), moves the court to appoint a master with
respect to the following claims:
Divorce () Distribution of Property
() Annulment ( ) Support
O Alimony {) Counsel Fees
(} Alimony Pendente Lite (} Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the claims (s) for which the appointment of a master is
requested.
(2) The defendant (has) em-not) appeared in the action (pseaally) (by his t
,
5a +?t L. Me,; l 4rea , Esquire). woo ? s M AI tw, c.Q ? w ? w
(3) The Staturory ground (s) for divorce (is) {ase}
>rr?fr j (0- U 0,W,4 hro k eo
(4) Delete the inapplicable paragraph(s):
a. The action is not contested
An agreement has been reached with respect to the following claims:
The action is contested with respect to the following claims:
(5) The action (does not involve) complex issues of law or fact
(6) The hearing is expected to take
(7) Additional information if any, relevant to
r CDrh y)?4ec c:-? 41(dQ 5 vD D c { l 4- svrn?cpl S'c.du
(hours) (days).
the motion:
Date: .3 Nov Otp A4 On- „ Pro 5e.
Attorney for (Plaintiff) (Defendant)
Print Attorney Name .........
ORDER APPOINTING MASTER
AND NOW, , 20 Esquire
is appointed master with respect to the following claims:
By the Court:
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OCT so 01
JAY DAINTY,
Plaintiff
V.
JACQUELINE DAINTY,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 04-6465 CIVIL TERM
DIVORCE
ORDER
AND NOW, this day of i 4'v 2006, upo
consideration of the Petition to Make Rule Absolute, it is hereby ORDERED AND DECREEI
THAT Sandra L. Meilton, Esquire, and the law firm of Tucker Arensberg, P.C. shall be
withdrawn as counsel for Defendant, Jacqueline Dainty a/k/a Jacqueline Lamboy, in the abc
matter.
90526.1
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NOV 0820061aii
TA/ b,4 ,to :ia
Plaintiff
Vs.
Jkou C L IIVE jAl Mit
Defendant
IN THE COURT OF COMMON PLEAS (
CUMBERLAND COUNTY, PENNSYLV
Docket No. 01-
-6 A I Iu (Plainti (Defendant), moves the court to appoint a ma
JA(
respect to the following claims:
Divorce () Distribution of Property
() Annulment () Support
() Alimony () Counsel Fees
() Alimony Pendente Lite () Costs and Expenses
and in support of the motion states:
(1) Discovery is complete as to the claims (s) for which the appointment of a i
requested.
(2) The defendant (has) mot) appeared m the action (by his
Sa Q+-rx L • Me; Esquire). who ?i s M4i a? •c c?C ?
?rr?f r; e-ua,(OI " broh eve -- - -- with
(3) The Staturory ground (s) for divorce (is)
is
tuvy,
raw
(4) Delete the inapplicable pbragraph(s):
a. The action is not contested.
An agreement has been reached with respect to the following claims:
The action is contested with respect to the following I claims:
(5) The action 4a;wIv ) (does not involve) complex issues of law or fact
(6) The hearing is expected to take (hours)
(7) Additional information, if _ any, relevant to the
Date: 3 No-v- We
Print Attorney Name .........
- 'k? D A-1 PTA - Pro 5,--
Attorney for (Plaintiff)
AND NOW, AU7rA69144 Y , 20_Te? C. X
is appointed master with respect to the following claims:
By
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JAY DAINTY,
vs.
IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
JACQUELINE DAINTY,
Defendant
NO: 2004-6465 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
PRAECIPE
To the Prothonotary:
Please enter my appearance on behalf of the Plaintiff, Jay Dainty, in the above captioned
divorce action.
Respectfully submitted,
ANDREWSA JOHNSON
Tayl . Andrews, Esquire
78 st Pomfret Street
Carlisle, PA 17013
(717) 243-0123
JAY DAINTY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO: 2004-6465 CIVIL TERM
CIVIL ACTION - LAW
JACQUELINE DAINTY,
Defendant : IN DIVORCE
CERTIFICATE OF SERVICE
I hereby certify that on this date, , 2007, I mailed a copy of Affidavit
Under Section 3301(d) of the Divorce Code and Counter Affidavit Under Section 3301(d) of the
Divorce Code on the following person at the following address by U.S. Mail, postage prepaid,
delivered to addressee only:
Jacqueline Dainty
North Coast Village #654
Vega Alta, PR 00692
I verify that the statements made in the foregoing Certificate 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
unsworn falsification to authorities.
ANDREWS & JOHNSON
By:
roo P.Andrews, Esq.
eys for Plaintiff
78 W. Pomfret Street
Carlisle, PA 17013
(717) 243-0123
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JAY DAINTY, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO: 2004-6465 CIVIL TERM
CIVIL ACTION - LAW
JACQUELINE DAINTY,
Defendant : IN DIVORCE
NOTICE
If you wish to deny any of the statements set forth in this Affidavit, you must file a counter-affidavit
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 June 13, 2004, 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.
I verify that the statements made in this Affidavit 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: I 190 01-
I
JAY DAINTY,
VS.
: IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
JACQUELINE DAINTY,
Defendant
NO: 2004-6465 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
COUNTER-AFFIDAVIT UNDER
SECTION 3301(d) OF THE DIVORCE CODE
1. Check either (a) or (b):
(a) I do not oppose the entry of a divorce decree.
(b) I oppose the entry of a divorce decree because
Check (i), (ii) or both):
(i) The parties to this action have not lived separate and apart for a
period of at least two years.
(ii) The marriage is not irretrievably broken.
2. Check either (a) or (b):
(a) I do not wish to make any claims for economic relief. 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.
(b) I wish to claim economic relief which may include
alimony, division of property, lawyer's fees or expenses or other important rights.
I verify that the statements made in this counter-affidavit 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:
Jacqueline Dainty, Defendant
NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not
wish to make any claim for economic relief, you need not file this counter-
affidavit.
.
JAY DAINTY,
vs.
IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
JACQUELINE DAINTY,
Defendant
NO: 2004-6465 CIVIL TERM
CIVIL ACTION - LAW
IN DIVORCE
CERTIFICATE OF SERVICE
I hereby certify that on this date, , 2007, I mailed a copy of Praecipe
on the following person at the following address by U.S. Mail, postage prepaid, delivered to
addressee only:
Jacqueline Dainty
North Coast Village #654
Vega Alta, PR 00692
I verify that the statements made in the foregoing Certificate 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
unsworn falsification to authorities.
ANDREWS & JOHNSON
By:
T 14191 P. Andrews, Esq.
Aft'orneys for Plaintiff
78 W. Pomfret Street
Carlisle, PA 17013
(717) 243-0123
?,„
C:D
FAHLES\12715\12715.1.PRA1
Created: 9/20/04 0:06PM
Revised: 8/20/07 3:54PM
Jennifer L. Spears, Esquire
MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER
MARTSON LAW OFFICES
I.D. 87445
10 East High Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Defendant
JAY DAINTY
Plaintiff
v.
JACQUELINE LAMBOY f/k/a
JACQUELINE DAINTY,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 04-6465 CIVIL ACTION -LAW
IN DIVORCE
PRAECIPE
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Enter the appearance of MARTSON LAW OFFICES on behalf of Defendant in the above
matter.
MARTSQN/LPLW OFFICES
By
Je Spears, Esquire
Ten E V igh Street
Carlisle, PA 17013
(717) 243-3341
Attorneys for Defendant
Dated: August 20, 2007
CERTIFICATE OF SERVICE
I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams Otto Gilroy &
Faller, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same
in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows:
Taylor P. Andrews, Esquire
ANDREWS & JOHNSON
78 West Pomfret Street
Carlisle, PA 17013
MARTSON LAW OFFICES
By
"Ii6ia D. Eckenr ad
Ten East High Street
Carlisle, PA 17013
(717) 243-3341
Dated: August 20, 2007
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