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Home My WebLink About05-3128 John W. Purcell, Jr. I.D. 29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell@pkh.com THOMAS G. XHILONE, Plaintiff vs. LYNNE G. XHILONE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 6.5' - 3l CIVIL ACTION-LAW IN DIVORCE C21 0E L ?2-_yl 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 Court Administrator, Cumberland County Courthouse, Hanover Street, Carlisle, PA. 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, PA 17013 (717) 249-3166 John W. Purcell, Jr. I.D. 29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell@pkh.com THOMAS G. XHILONE, Plaintiff VS. LYNNE G. XHILONE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION-LAW IN DIVORCE COMPLAINT IN DIVORCE AND NOW COMES Plaintiff, Thomas G. Xhilone, by his attorneys, Purcell, Krug & Haller, and avers as follows: DIVORCE PURSUANT TO SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Thomas G. Xhilone, an adult individual whose current address is 1400 Bent Creek Boulevard, Apt. 105, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant is Lynne G. Xhilone, an adult individual whose current address is 2 Chantilly Court, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six {6} months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on May 2, 1981, in Cleveland, Ohio. 5. There have been no prior actions in divorce or annulment between the parties. 6. The Plaintiff avers that there is one child of the parties under the age of 18: John Xhilone, born April 17, 1991. 7, Neither of the parties in this action is presently a member of the Armed Forces. 8. The Plaintiff and Defendant are both citizens of the United States. 9. The marriage is irretrievably broken. 10. Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in 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. 2 WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree in Divorce. PURCELL, KRUG & HALLER BY. Jr., Esquire 1719 N rth Front Street arr urg, PA 17102 Dated: (717) 234-4178 VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce 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. Dated: June 15, 2005 Thomas G. one ? ? ^' ? /^ ? ? V ' ? 44? ..-? ?? ?i?? , v`7 ? =? ? ?1..) ? ? .v ,4 : J y ?- John W. Purcell, Jr. I.D. 29955 Purcell, Krug & Haller 1719 North Front Street Harrisburg, PA 17102 (717) 234-4178 jpurcell@pkh.com THOMAS G. XHILONE, Plaintiff vs. LYNNE G. XHILONE, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 05-3128 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE ACCEPTANCE OF SERVICE OF COMPLAINT IN DIVORCE AND NOW, this day of 11 ? „ 2005, I, Donald T. Kissinger, Esquire, attorney for Lynne G. Xhilone, the Defendant in the above captioned matter, hereby accepts service of the Complaint in Divorce filed in the above matter. Donald T. Kissinger, Eso ire Attorney for the Defendant Lynne G. Xhilone Z so ?? N ? Curtis R. Long Prothonotary Office of the Vrotbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 09 - 3 jakA CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY -- ??••?+?.?..?P cn„are 9 Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573