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HomeMy WebLinkAbout07-28160 JENNIFER J. BASOM, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW PATRICK A. BASOM, NO k Defendant IN DIVORCE 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 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 marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER 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, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, FJ.OWER_ & W$AY SAIDIS, FLOWER & LINDSAY A YS.AMAW 26 West High Street Carlisle, PA Carol J. Linds , a Attorney Id. 693 26 West High reel Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff JENNIFER J. BASOM, Plaintiff V. PATRICK A. BASOM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07 - 2-?') b IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Jennifer J. Basom, an adult individual residing at 2424 Yale Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The Defendant is Patrick A. Basom, an adult individual residing at 330 Fourth Street, New Cumberland, Cumberland County, Pennsylvania 17070. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 8, 2001 in Valley View, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the SA 11S, LINDSAY ATIORN is v uw 26 West High Street Carlisle, PA parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that he/she has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code. Respectfully submitted, SAIDIS, FLOWER & LINDSAY Carol J: Lindsay, Attorney Id. 446 26 West High Street Carlisle, PA 17013 (717) 243-6222 Dated: v?J?O `Z Counsel for Plaintiff FLOWER ? LINDSAY AMD& AT- 26 West High Street Carlisle, PA VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. C4??? - Jennife asom Date: `T 1310-7 SAMIS, FLOWER & LIlVDSM A'1'lORNEYS-AT•uw 26 West High Street Carlisle, PA `Q v 1 ` C7 1 ?. Vv ? fTt t 1 JENNIFER J. BASOM, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-2816 PATRICK A. BASOM, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, David F. Tamanini, Esquire, attorney for Patrick A. Basom, accept service of the Complaint in Divorce in the above-captioned matter and certify that I am authorized to do so. TAMANINI LAW OFFICE SAMIS, FLOWER & LINDSAY .+T'rom?vs•evuw 26 West High Street Carlisle, PA 5-_ 1I- 07 Date David F. Tamanini, Esquire 4800 Linglestown Road, Suite 309 Harrisburg, PA 17112-6206 Attorney for Defendant ca G ° ? ? ?? ? ? ?, , rr, ?_. .,.? -,?; ;? r-? ? y? ~?~ s? ? -C .?" JENNIFER J. BASOM, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 07-2816 PATRICK A. BASOM, Defendant IN DIVORCE AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on October 14, 2006 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit 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. A (? 0? C, A-P Dated: h2! hen ife4J.wa C IS ? LINDSAY 26 West High Street Carlisle, PA FILE D-t ,1 1`KvfE OF ?HE OTL"I""{NARY 2009 MAY 18 PH Z: 40 N, Ty JENNIFER J. BASOM, Plaintiff v PATRICK A. BASOM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW NO. 07-2816 IN DIVORCE COUNTER-AFFIDAVIT UNDER 63301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) X _ I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (check (i), (ii) or both) (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-affidavit are true and correct. I SAIDIS, FLOWER & LENDSAY 26 West High Street Carlisle, PA understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Dated: trick A. Basom NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make any claim for economic relief, you should not file this counter-affidavit. JUL 3 1 2009 ^F Tf t 'd 2 C09 -'? c L -ft JENNIFER J. BASOM, Plaintiff V. PATRICK A. BASOM, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-2816 IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(d)(1) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant's counsel, David F. Tamanini, Esquire, accepted service of the Complaint on May 31, 2007. An Acceptance of Service was filed with the Court on June 6, 2007. 3. Date of the execution of the Affidavit required by Section 3301(d) of the Divorce Code: May 8, 2009; Date of filing and service of the Plaintiff's Affidavit upon the Respondent: May 15, 2009. Date of execution of Defendant's Counter-Affidavit: June 4, 2009. Date of filing: August 5, 2009. No economic claims. No objection to entry of Decree. 4. Related claims pending: None 5. Date and manner of service of the Notice of Intention to file Praecipe a copy of which is attached: August 4, 2009 by first class mail. SAIDIS, FLOWER INDSAY SAIDIS, FLOWER & LINDSAY ATICKIM-AMAW 26 West High Street Carlisle, PA Carol J. Lind§ay, quire Supreme Co o. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 Attorney for Plaintiff Dated: October 2, 2009 } ` LAW OFFICES SAIDIS, FLOWER & LINDSAY A PROFESSIONAL CORPORATION 26 WEST HIGH STREET JOHN E. SLIKE CARLISLE, PENNSYLVANIA 17013 ROBERT C. SAIDIS TELEPHONE: (717) 243-6222 - FACSIMILE: (717) 243-6486 JAMES D. FLOWER, JR EMAIL: attorney@sfl-law.com CAROL J. LINDSAY www.sfl-law.com JOHN B. LAMPI DANIEL L. SULLIVAN ALBERT H. MASLAND DEAN E. REYNOSA THOMAS E. FLOWER MARYLOU MATAS JASON E. KELSO August 4, 2009 Patrick A. Basom 103 North 21" Street Camp Hill, PA 17011-3809 Re: Basom v. Basom Dear Mr. Basom: CAMP HILL OFFICE: 2109 MARKET STREET CAMP HILL, PA 17011 TELEPHONE: (717)737-3405 FACSIMILE: (717)737-3407 REPLY TO CARLISLE We are filing the Counteraffidavit that you signed with the Court, but i am required to provide to you the enclosed Notice before the Decree in Divorce can be entered. Very truly yours, SAIDIS, F OWE NDSAY Carol J. Lind a squire CJL/bes Enclosures cc: Jennifer Basom JENNIFER J. BASOM, Plaintiff V. PATRICK A. BASOM, Defendant To: Patrick A. Basom IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-2816 IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE Jennifer J. Basom, Plaintiff, intends to file with the Court the attached Praecipe to Transmit Record on or after August 24, 2009, requesting that a final Decree in Divorce be entered. Respectfully submitted, SAIDIS, FLOWER 8,L-?N?lS?Y Carol J. Lindsay/, E uire Supreme Cou o. 44693 26 West High Street Carlisle, PA 17013 717-243-6222 SAIDIS, FLOWER & LINDSAY 26 West High Street Carlisle, PA F1L TICE OF THE Fr7HONOTARY 2009 OCT -S Pik 2- 0 S Ft_ t V' VSYVYY?N IA JENNIFER J. BASOM IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. PATRICK A. BASOM NO. 07-2816 DIVORCE DECREE AND NOW, 0C-k4bbe,?- , '100? , it is ordered and decreed that JENNIFER J. BASOM plaintiff, and PATRICK A. BASOM bo-nds of matrimony. defendant, are divorced from the Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") None. By the Court, Attest: J. rothonotary ?-??, ? ? . , , ? lwf - ?? ? ? ??'? f-' ? G ?? ??,?ar ,? . ?y ?? ?.....