HomeMy WebLinkAbout06-6115
,
WAYNE F. SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
170]3
MICHAEL A. KA YDO, SR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
v.
: NO. 06- ~IIS
CIVIL TERM
LISA M. KA YDO,
Defendant
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been su~d in Court. If you wish to defend against the claims set forth in the
following pages, you mmt 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 marriag~' counseling. A list of marriage counselors is available in the Office of
the Prothonotary at
CUMBERLAND COUNTY COURTHOUSE. CARLISLE. PENNSYLVANIA 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LA WYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD 1 AKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE ALA WYER 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, Pennsylvania 17013
Telephone: 717-249-3166
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Wayne . Shade, Esquire
Supreme Court No. 15712
53 West Pomfret Street
Carlisle, Pennsylvania 17013
Telephone: 717-243-0220
Attorney for Plaintiff
WAYNE F. SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
MICHAEL A. KA YDO, SR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
v.
: NO. 06- l, lIS
CIVIL TERM
LISA M. KA YDO,
Defendant
: IN DIVORCE
CAPTION
COMPLAINT
1.
Plaintiff in this Action in Divorce is MICHAEL A. KA YDO, SR., an adult
individual who resides ilt 6 Independence Drive, Mount Holly Springs, Cumberland
County, Pennsylvania 17065.
2.
Defendant is LISA M. KA YDO, an adult individual and citizen of the United
States of America whose last known address is c/o Sheetz, Inc., 420 North Baltimore
Avenue, Mount Holly S.prings, Cumberland County, Pennsylvania 17065.
3.
Defendant has bl~en a bona fide resident of Cumberland County, Pennsylvania, for
more than six months previously to the filing of this Complaint and continuing to the
commencement of this Action in Divorce.
4.
Plaintiff and Defendant were lawfully joined in marriage on January 21,1989, in
Uniontown, Pennsylvania.
WAYNEF.SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
5.
The parties have been living separate and apart since on or about March 24, 2006.
6.
Plaintiff avers as the grounds on which this action is based that the marriage of the
parties is irretrievably broken. In the alternative, Plaintiff avers as the grounds on which
this action is based that Defendant has offered such indignities to the person of the
Plaintiff, the innocent and injured spouse, as to render the condition of Plaintiff
intolerable and the life of Plaintiff burdensome.
7.
There have been no prior actions for divorce or annulment of this marriage in
Pennsylvania or in any .)ther jurisdiction.
8.
This Action in Divorce is not collusive.
9.
Both parties to this Action in Divorce are legally capable of managing their own
concerns.
10.
Defendant herein is not a member of the armed forces of the United States of
America.
-2-
WAYNEF.SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
11.
There were thret:' children born to the parties, namely, Michael A. Kaydo, Jr., born
August 26,1989, Kayla D. Kaydo, born October 21, 1991, and Dalton L. Kaydo, born
November 20, 1994.
12.
Plaintiff has been advised that counseling is available and that Plaintiff may have
the right to request that the Court require the parties to participate in counseling.
WHEREFORE, Plaintiff demands judgment dissolving the marriage between the
parties.
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Wayne . Shade, Esquire
Supreme Court No. 15712
53 West Pomfret Street
Carlisle, Pennsylvania 17013
Telephone: 717-243-0220
Attorney for Plaintiff
-3-
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WAYNE F. SHADE
Attorney at Law
53 West Pomfret Street
Carlisle, Pennsylvania
17013
I verifY that the statements made in this pleading 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: October 19. 2006
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Michael A. Kaydo, Sr.
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MICHAEL A. KA YDO, SR.,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL ACTION - LAW
v.
: NO. 06-6115 CIVIL TERM
LISA M. KA YDO,
Defendant
: IN DIVORCE
PRAECIPE
TO: Curtis R. Long, Prothonotary
Please enter my appearance and acknowledgment of receipt of a certified copy of
the Complaint in the above-captioned matter.
Date:
lO/?.O/
{ (
, 2006
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MICHAEL A. KAYDO, SR.,
No.
06-6115 CIVIL TERM
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DIVORCE
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AND NOW,
MICHAEL A. KAYDO, SR.
DECREED THAT
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LISA M. KAYDO
, DEFENDANT,
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ARE DIVORCED FROM THE BONDS OF MATRIMONY.
THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE if.
BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT
YET BEEN ENTERED;
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All other claims have been resolved in a Property Settlement and
separat~on Agreement dated July 27, 2006, a copy of which is
attached and incorporated, but not merged, herein by reference as
thollgh fully set forth.
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