LEGAL NOTICE
IN THE COURT OF COMMON PLEAS
OF LACKAWANNA COUNTY
CIVIL DIVISON- LAW
ACTION TO QUIET TITLE
DOCKET NO: 25-CV- 10360
PATRICK WALSH, ESQUIRE
in his capacity as Successor Trustee of the
Agreement of Trust dated February 1, 1980
Plaintiff
vs.
BARBARA A. RINALDI, in her capacity as Personal Representative of the Estate of Anthony J. Rinaldi,
MADELYN RINALDI, in her capacity as
Personal Representative of the Estate of Clement J. Rinaldi,
RAYMOND C. RINALDI, II, in his capacity as Personal Representative of the Estate of Raymond C. Rinaldi,
and ALL UNKNOWN PERSONS, HEIRS, SUCCESSORS, AND/OR ASSIGNS, CLAIMING ANY LEGAL OR EQUITABLE RIGHT, TITLE, OR INTEREST IN THE PROPERTY ADVERSE TO PLAINTIFF'S TITLE AS SUCCESSOR TRUSTEE UNDER THE TRUST AGREEMENT
Defendants
NOTICE
NOTICE TO PLEAD
TO: Defendants
You are hereby notified that an Action in Quiet Title has been commenced with the Court of Common Pleas of Lackawanna County, Civil Division No. 25-CV-10360 as to the above number, averring that Plaintiff is the lawful owner in fee simple of the Property, free and clear of all adverse claims, liens, or encumbrances asserted by Defendants. Plaintiff requests that a Decree permanently barring and enjoining Defendants, and all persons claiming by, through, or under them, from asserting any right, title, estate, lien, or interest in or to the Property adverse to Plaintiff and entering a Decree quieting title to the Property in favor of Plaintiff
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 attorney and filing in writing with the court your defenses or objections 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 claimed in the complaint or for any other claim or relief requested by the plaintiff. 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.
Northeastern Pennsylvania Legal Services
33 N. Main Street, Suite 200
Pittston, PA 18640
Telephone (570) 299-4100
Patrick A. Walsh, Esquire
Law Office of Patrick A. Walsh, LLC
261 E. Grove Street
Clarks Green, PA 18411
Phone: 570-903-1684
Attorney for Plaintiff/Plaintiff
January 6 2026
LSOM0432956