On October 15, 2021 a
Clerk Notice
was filed
involving a dispute between
Ippolito, Nino,
and
Vetter, Allison,
for Civil - Real Property - Partition of Real Property
in the District Court of Delaware County.
Preview
Supreme C%W&§nnsylvania
Courfigf Cmmfif‘égleas For Prothonotaly Use Only
EN ;; 5€>jeggggzfi§ a“ $2
$11; Quay“ §§t Docket No
D “V ?fé w}? County
L?
The znformatton collected on £121? form ZS used solely for court admmzstratzon purposes 17215 form does not
supplement 0) replace the filmg and servzce ofpleadmgs 0r olheVpapers as requn ed by law or i ales Ofcourz‘
Commencement of Action
S E Complaint Writ of Summons E] Petition
a Transfer from Another Jufisdictlon a Declaration of Takmg
E
C Lead Plamtiff’ S Name Lead Defendant 5 Name
T Nino lppolito Allison Vetter
Dollar Amount Requested Ewithin arbltration limJts
I Are money damages requested? Yes E No (check one) Bantam: arbination hmits
Q
N Is this a Class Actum Suit? a Yes No Is this an MDJAppeal? Yes No
A Name of Plaintiff/Appellaut s Attorney Daniel J Donohue
E1 Check here if jmu have no amuse} (a: e a Seif Represented [Pro Se} Litigant)
Nature of the Case Place an “X’ to the left of the ONE case category that most accurately describes your
PRIMARY CASE If you are making more than one type of claim, check the one that
you consider most important
TORT (do not Include Mass Tort) CONTRACT (do not Include Judgments) CIVIL APPEALS
a Intentional Buyer Plaintiff Administrative Agencies
a Malicious Prosecution E Debt Collection Cledit Ca1d Board of Assessment
E Motor Vehicle a Debt Collecuon Other fl Board of Elections
a Nuisance 5 Dept of Transportauon
S E Plemises Liability Statutory Appeal Other
E a ”12:53:,”
P d tL lab 11fly (d02? not ma lude E] Employment Dlspute
Discnmination
SI d /L b 1/ D f t
C E 0:11;? 1 e 6 mm mm Employment Dispute Other {3 Zomng Board
E Other
I [2| Other
0 MASS TORT
Asbestos
N Tobacco
a Tox1c Tort DES
a $0“ $5)” Implant REAL PROPERTY MISCELLANEOUS
0:310 aste ElEjectment a Common Law/Statutory Arbitration
B a er D Eminent Domain/Condemnation a Declaratory Judgment
a Ground Rent E Mandamus
D Landlord/Tenant Dispute a Non Domestic Relations
Mortgage Foreclosure Residential Restraining Order
PROFESSIONAL LIABLITY D Mortgage Foreclosure Commercial D Quo Warranto
Dental Partition m Replevm
E Local D Quiet Title ['3 Othel
a Medical Other
D Other Professmnal
Updated 1/1/2011
DONOHUE & DONOHUE P C
Daniel J Donohue Esquire
8513 West Chester Pike
Upper Darby PA 19082
(610) 853 2115 Fax (610) 853 2177
IN THE COURT OF COMMON PLEAS OF DELAWARE COUNTY PENNSYLVANIA
CIVIL ACTION EQUITY
NINO IPPOLITO
1902 Stanwood Street
Philadelphia PA 19152
No
vs
ALLISON VETTER
20 Walnut Road
Wallingford PA 19086
NOTICE TO DEFEND
YOU HAVE BEEN SUED IN COURT If you wish to defend against the claims set forth in the
following pages you must take action within twenty (20) days after this Complaint and Notice are
served by entering a written appearance personally or by an attorney and filing in writing With the Court
your defenses or obj ectlons to the claims set forth against you You are warned that if you fail to do so,
the case may proceed without you and a Judgment may be entered against you by the Court without
further notice for any money clalmed 1n the Complaint or for any other clalm or relief requested by the
plaintlff You may lose money or property or other rights important to you
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
LAWYER S REFERENCE SERVICE
Front and Lemon Streets
Media, Pennsylvania 19063
(610) 566 6622
IN THE COURT OF COMMON PLEAS OF DELAWARE COUNTY PENNSYLVANIA
CIVIL ACTION EQUITY
NINO IPPOLITO
1902 Stanwood Street
Philadelphia PA 19152
No
vs
ALLISON VETTER
20 Walnut Road
Wallingford PA 19086
COMPLAINT FOR PARTITION OF REAL PROPERTY
AND NOW comes the plaintlff Nino Ippolito by and through his attorney
Daniel J Donohue, Esqulre, and respectfillly aver the following
1 Plaintiff, Nino Ippohto, is adult1nd1viduals residing at 1902 Stanwood
Street, Philadelphia, Pennsylvania 19152
2 Defendant, Alhson Vetter, is an adult ind1Vidua1 Who resides at 20 Walnut
Road Drexel Hill PA 19086
3 The parties were previously in a relationship and were engaged to be
marrled but the relatlonship has ended
4 On December 7, 2019, the parties purchased a home at 20 Walnut Road in
Walhngford Delaware County, Pennsylvania
5 The paI‘tles own the home together as tenants in common
6 After purchasing the home, Plaintlff and 1115 famlly made substantlal
1mprovements to the property and invested labor and money in excess of $65,000 to
make the home habitable
7 The parties” relationship ended in August of 2021 and they have been
1iV1ng apart since that time
8 Defendant maintains possession of the home
9 Both parties are on the mortgage and both contribute to the costs of the
mortgage and real estate taxes
10 Plaintlff is seeking partition of the property and reimbursement of the
value of his improvements to the property
WHEREFORE Plaintiff Nino Ippolito respectfully requests this Honorable
Court to equitably partition the property
Respectfully submitted
D%fl Donohuz7é
Attorney for the Plaintiff
IN THE COURT OF COMMON PLEAS OF DELAWARE COUNTY PENNSYLVANIA
CIVIL ACTION EQUITY
NINO IPPOLITO
1902 Stanwood Street
Philadelphia PA 19152
No
vs
ALLISON VETTER
20 Walnut Road
Wallingford PA 19086
VERIFICATION
I certify that the facts set forth in the foregoing pleading are true and correct to the best of
my knowledge, 1nformat10n and belief These statements are made pursuant to the penalties of
18 PA C S Section 4904 relatmg to unsworn fa151fication to authoritles
A ,49/_ I
wonohue
Attorney for the Plaintlff
Document Filed Date
April 26, 2022
Case Filing Date
October 15, 2021
Category
Civil - Real Property - Partition of Real Property
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Preview
Supreme C%W&§nnsylvania Courfigf Cmmfif‘égleas For Prothonotaly Use Only EN ;; 5€>jeggggzfi§ a“ $2 $11; Quay“ §§t Docket No D “V ?fé w}? County L? The znformatton collected on £121? form ZS used solely for court admmzstratzon purposes 17215 form does not supplement 0) replace the filmg and servzce ofpleadmgs 0r olheVpapers as requn ed by law or i ales Ofcourz‘ Commencement of Action S E Complaint Writ of Summons E] Petition a Transfer from Another Jufisdictlon a Declaration of Takmg E C Lead Plamtiff’ S Name Lead Defendant 5 Name T Nino lppolito Allison Vetter Dollar Amount Requested Ewithin arbltration limJts I Are money damages requested? Yes E No (check one) Bantam: arbination hmits Q N Is this a Class Actum Suit? a Yes No Is this an MDJAppeal? Yes No A Name of Plaintiff/Appellaut s Attorney Daniel J Donohue E1 Check here if jmu have no amuse} (a: e a Seif Represented [Pro Se} Litigant) Nature of the Case Place an “X’ to the left of the ONE case category that most accurately describes your PRIMARY CASE If you are making more than one type of claim, check the one that you consider most important TORT (do not Include Mass Tort) CONTRACT (do not Include Judgments) CIVIL APPEALS a Intentional Buyer Plaintiff Administrative Agencies a Malicious Prosecution E Debt Collection Cledit Ca1d Board of Assessment E Motor Vehicle a Debt Collecuon Other fl Board of Elections a Nuisance 5 Dept of Transportauon S E Plemises Liability Statutory Appeal Other E a ”12:53:,” P d tL lab 11fly (d02? not ma lude E] Employment Dlspute Discnmination SI d /L b 1/ D f t C E 0:11;? 1 e 6 mm mm Employment Dispute Other {3 Zomng Board E Other I [2| Other 0 MASS TORT Asbestos N Tobacco a Tox1c Tort DES a $0“ $5)” Implant REAL PROPERTY MISCELLANEOUS 0:310 aste ElEjectment a Common Law/Statutory Arbitration B a er D Eminent Domain/Condemnation a Declaratory Judgment a Ground Rent E Mandamus D Landlord/Tenant Dispute a Non Domestic Relations Mortgage Foreclosure Residential Restraining Order PROFESSIONAL LIABLITY D Mortgage Foreclosure Commercial D Quo Warranto Dental Partition m Replevm E Local D Quiet Title ['3 Othel a Medical Other D Other Professmnal Updated 1/1/2011 DONOHUE & DONOHUE P C Daniel J Donohue Esquire 8513 West Chester Pike Upper Darby PA 19082 (610) 853 2115 Fax (610) 853 2177 IN THE COURT OF COMMON PLEAS OF DELAWARE COUNTY PENNSYLVANIA CIVIL ACTION EQUITY NINO IPPOLITO 1902 Stanwood Street Philadelphia PA 19152 No vs ALLISON VETTER 20 Walnut Road Wallingford PA 19086 NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT If you wish to defend against the claims set forth in the following pages you must take action within twenty (20) days after this Complaint and Notice are served by entering a written appearance personally or by an attorney and filing in writing With the Court your defenses or obj ectlons to the claims set forth against you You are warned that if you fail to do so, the case may proceed without you and a Judgment may be entered against you by the Court without further notice for any money clalmed 1n the Complaint or for any other clalm or relief requested by the plaintlff You may lose money or property or other rights important to you 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 LAWYER S REFERENCE SERVICE Front and Lemon Streets Media, Pennsylvania 19063 (610) 566 6622 IN THE COURT OF COMMON PLEAS OF DELAWARE COUNTY PENNSYLVANIA CIVIL ACTION EQUITY NINO IPPOLITO 1902 Stanwood Street Philadelphia PA 19152 No vs ALLISON VETTER 20 Walnut Road Wallingford PA 19086 COMPLAINT FOR PARTITION OF REAL PROPERTY AND NOW comes the plaintlff Nino Ippolito by and through his attorney Daniel J Donohue, Esqulre, and respectfillly aver the following 1 Plaintiff, Nino Ippohto, is adult1nd1viduals residing at 1902 Stanwood Street, Philadelphia, Pennsylvania 19152 2 Defendant, Alhson Vetter, is an adult ind1Vidua1 Who resides at 20 Walnut Road Drexel Hill PA 19086 3 The parties were previously in a relationship and were engaged to be marrled but the relatlonship has ended 4 On December 7, 2019, the parties purchased a home at 20 Walnut Road in Walhngford Delaware County, Pennsylvania 5 The paI‘tles own the home together as tenants in common 6 After purchasing the home, Plaintlff and 1115 famlly made substantlal 1mprovements to the property and invested labor and money in excess of $65,000 to make the home habitable 7 The parties” relationship ended in August of 2021 and they have been 1iV1ng apart since that time 8 Defendant maintains possession of the home 9 Both parties are on the mortgage and both contribute to the costs of the mortgage and real estate taxes 10 Plaintlff is seeking partition of the property and reimbursement of the value of his improvements to the property WHEREFORE Plaintiff Nino Ippolito respectfully requests this Honorable Court to equitably partition the property Respectfully submitted D%fl Donohuz7é Attorney for the Plaintiff IN THE COURT OF COMMON PLEAS OF DELAWARE COUNTY PENNSYLVANIA CIVIL ACTION EQUITY NINO IPPOLITO 1902 Stanwood Street Philadelphia PA 19152 No vs ALLISON VETTER 20 Walnut Road Wallingford PA 19086 VERIFICATION I certify that the facts set forth in the foregoing pleading are true and correct to the best of my knowledge, 1nformat10n and belief These statements are made pursuant to the penalties of 18 PA C S Section 4904 relatmg to unsworn fa151fication to authoritles A ,49/_ I wonohue Attorney for the Plaintlff