Plaintiff commenced an action for a divorce on January 3, 1978 by service of a summons and notice, alleging the grounds to be adultery and seeking alimony, custody of minor children, support for the children, and counsel fees. No complaint was ever served. Negotiations between attorneys for an amicable disposition without service of a formal notice of appearance or demand for a verified complaint were unsuccessful. On December 17, 1980, plaintiff served upon defendant's attorneys...
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