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MICHAEL A. BIMLER
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 1(.
/ ! 1 ), // ( i \ C
SUSAN BIMLER
CIVIL ACTION - LAW
IN DIVORCE
Defendant.
NOTICE
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 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.
When the ground for divorce is indignities or irretrievable
breakdown of the marriage, you may request marriage counselling. A
list of marriage counselors is available at: The Office of the
Prothonotary, Cumberland county Courthouse, One Courthouse Square,
Carlisle, Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
I COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
![ ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE.
I
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COURT ADMINISTRATOR
CUMBERLAND CO COURTHOUSE
1 COURTHOUSE SQUARE
CARLISLE PA 17013 3387
(717) 240 6200
4th FLOOR
M.YI~I. DllPOII
410 NOATH SECOND S fREET . POBOX 1062 . HAAAI$BURG. PA 11108
01 n ]36-9428 . FAX (1171n15.2811
MICHAEL A. BIMLER
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 9 (, I 7) ~ (tv':.f '-C.._
VS.
SUSAN SIMLER
CIVIL ACTION - LAW
IN DIVORCE
Defendant.
COMPLAINT IN DIVORCE
1. Plaintiff is Michael A. Bimler, an adult individual, whose
permanent address is 118 North 31st street, camp Hill,
Pennsylvania 17011.
2. Defendant is Susan Bimler, an adult individual, whose
permanent address is 118 North 31st street, Camp Hill,
Pennsylvan.ia 17011.
3. Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six (6) months
immediately prior to the filing of this Complaint.
4. Plaintiff is not a member of the Un.ited Stated Armed Forces.
16.
I
17.
,18.
:1
5. Plaintiff and Defendant are husband and wife, and were married
on January 6, 1984 in Allentown, Pennsylvania.
There have been no prior actions of divorce or annulment
between the parties.
The marriage is irretrievably broken.
Plaintiff has been advised that counseling is available and
I
that Plaintiff may have the right to request the court require
the parties to participate in counseling. Being so advised,
Plaintiff waives that right.
M.YI~I. 011_
.110NOATHSECQNDSfI:jEET . PO BO)[1062 . HARRISBURG, PA 17108
Inllll&-9418 . FA>: (]l1l136-2811
9. Plaintiff requests the Court to ent.er a Decree of Divorce
pursuant to Section 3301(c) of the Divorce Code.
WHEREFORE, the Plaintiff, Michael A. Bimler, respectfully
requests this Honorable Court enter ~ Decree in Divorce pursuant to
Section 3301(c) of the Divorce Code.
~OUNT I
INDIGNITIES
10. Paragraph numbers one through nine are incorporated by
reference as if fully set forth herein.
11. The Plaintiff avers that the Defendant, in violation of her
marriage vows and the laws of this Commonwealth, has offered
such indignities to the person of the Plaintiff, the injured
and innocent spouse, as to render his condition intolerable
and his life burdensome.
WHEREFORE, Plaintiff requests this Honorable Court to enter a
Decree in Divorce, pursuant to Section 3301(a) (6) of the Divorce
Code. The Defendant has committed indiginities during the term of
the marriage.
,
I
12.
COUNT II
CUSTODY
Paragraphs one through eleven are incorporated by reference .!IS
I
i113.
!I
if fully set forth herein.
The parties are the parents of two minor children, namely,
Erica Theresa, born July 9, 1984; and Sus.!ln Carolyn, born
August 12, 1986.
M.V.~I. 011_
.110NORTH SECOND STAEtr . POBOX 1062 . HARRISBURG, PA 11108
(lln236'9428 . FAX (1111236.2811
14. The children were not born out of wedlock.
15. The children have lived with both parties from the tim. of
their birth up until the present time.
16. The children are presently in the cuetody of both parties.
17. Plaintiff has not participated as a party or as a witness, or
in another capacity, in other litigation concerning the
custody of the children in this or another court. Plaintift
has no information of a custody proceeding concerning the
children pending in a court of this Commonwealth. Plaintitf
does not know of a person not a party to the proceedings who
has physical custody of the children, or claims to have
custody or visitation rights with respect to the children.
18. Each parent whose parental rights to the children have not
been terminated, and the person who has physical custody of
the children have been named as parties to this action.
19.
The Plaintiff requests that the Court
primary physical custody of the children
confirm legal and I
with the Plaintiff,
and grant visitation rights to the Defendant.
20. The best interest and permanent welfare of the children will
be served by granting the relief requested because the
Plaintiff can provide a more stable and loving home
environment for the children.
Additionally, the Plaintiff
will ensure that the children have sufficient visitation and
contact with the Defendant.
MIV.~I' 011_
410NOA1H SECOND STREET . POBOX 1061 . HARRISBURG. PA 1110B
Pl1l13&.94l28 . FA)( 1717123B.2817
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MICHAEL A. BIMLER
Plaintiff,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. ({ &
( 7J), () t Ir- {
SUSAN BIMLER
CIVIL ACTION - LAW
IN DIVORCE
Defendant.
~QTICf;
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 I
proceed without you and a judgment may be entered against you by 'I
the Court without further notice for any money 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.
,
I
When the ground for divorce is indignities or irretrievable
breakdown of the marriage, you may request marriage counselling. A
list of marriage counselors is available at: The Office of the
Prothonotary, Cumberland County Courthouse, One Courthouse Square,
Carlisle, Pennsylvania, 17013.
IF YOU DO HOT FILE A CLAIM FOR ALUION"i, 11l.RITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE; THE FINAL DECREE OF' DIVORCE OR
ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. I
i
YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE.
4th FLOOR
M.VI~S. DllfO~
410~~OArHSFCONDsrAEET . PO BO>< 1062 . HARR!SBURG. PA 17108
(711)236-9428 . FAX 1"71236-2817
MICHAEL A. BIMLER
Plaintiff,
vs.
IN THE COURT OF COMMON PLEAS
CUMBER~'ND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION - LAW
IN DIVORCE
SUSAN BIMLER
Defendant.
COMPLAINT I~-PIVORCE
1. Plaintiff is Michael A. Bimler, an adult individual, whose
permanent address is 118 North 31st street, Camp Hill,
Pennsylvania 17011.
2 . Defendant is Susan Bimler, an adult individual, whose
permanent address is 118 North 31st street, Camp Hill'l
Pennsylvania 17011.
3. Plaintiff and Defendant have been bona fide residents of the
Commonwealth of Pennsylvania for at least six (6) months
immediately prior to the filing of this Complaint.
4. Plaintiff is not a member of the United Stated Armed Forces.
5. Plaintiff and Defendant are husband and wife, and were married
on January 6, 1984 in Allentown, Pennsylvania.
6. There have been no prior actions of divorce or annulment
between the parties.
7. The marriage is irretrievably broken.
8. Plaintiff has been advised that counseling is available and
that Plaintiff may have the right to request the court require
the parties to par.ticipate in counseling. Being so advised,
Plaintiff waives that right.
MIY.~. . D1lfOl1
"'OW)RTH')f_CONGSTRI;ET . PO ROX1061 . HARRISBURG, PA "108
l,,/)1Jt).9418 . FAX 1111123&2l!llJ
14. The children were not born out of wedlock.
15. The children have lived with both parties from the time of
their birth up until the present time.
16. The children are presently in the custody of both parties.
17. Plaintiff has not participated as a party or as a witness, or
in another capacity, in other litigation concerning the
custody of the children in this or another court. Plaintiff
has no information of a custody proceeding concerning the
children pending in a court of this Commonwealth. Plaintiff
does not know of a person not a party to the proceedings who
has phye:ical custody of the children, or claims to have
custody or visitation rights with respect to the children.
18. Each parent whose parental rights to the children have not
been terminated, and the person who has physical custody of
the children have been named as parties to this action.
19. The piaintiff requests that the Court confirm legal and
primary physical. custody oE the children with the Plaintiff,
and grant visitation rights to the Defendant.
20. The best interest and permanent welfare of the children will
be served by granting the relief requested because the
Plaintiff can provide a more stable and loving home
environment for the children.
Additionally, the Plaintiff
will ensure that the children have sufficient visitation and
contact with the Defendant.
M.YI~I. 011_
410 NOAnl SECOND STREET . po BOX 1062 . HAnAISBUAG, PA 17108
11171236-9428 , FAX (717)236-2817