The URL can be used to link to this page

Home My WebLink About03-3857 HELEN T. BLOSSER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. (?.:1 - :N $", ACTION IN DIVORCE Civil Term TIMOTHY M. BLOSSER, Defendant NOTICE TO DEFEND AND CLAIM RIGHTS 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 St. Carlisle, Pa. 17013 (717) 249-3166 HELEN T. BLOSSER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. Civil Term TIMOTHY M. BLOSSER, Defendant ACTION IN DIVORCE COMPLAINT IN DIVORCE COUNT I - DIVORCE I. Plaintiff is Helen T. Blosser, a competent adult individual, who has resided at 1669 Quail Drive, Carlisle, Cumberland County, Pennsylvania, 17013, since 1997. 2. Defendant is Timothy M. Blosser, a competent adult individual, who has resided at 1669 Quail Drive, Carlisle, Cumberland County, Pennsylvania, 17013, since 1997. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on September 16, 1989 in Cumberland County, Pennsylvania. S. There have been no prior actions of divorce or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have two children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Plaintiff is not a member ofthe Armed Forces ofthe United States; Defendant is in the Army National Guard. 10. The Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken, and/or; (b) That Plaintiff has offered such indignities to the person of the Defendant, the innocent and injured spouse, as to render her condition intolerable and his life burdensome, and; WHEREFORE, Plaintiff requests the court to enter a Decree in Divorce. COUNT 11- EOUITABLE DISTRIBUTION OF PROPERTY II. Paragraph 1- 10 are herein incorporated by reference. 12. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. 13. During the course of the marriage, the parties have acquired debts during their marriage and until the present. 14. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. 15. Plaintiff is seeking an equitable division of said property. WHEREFORE, Plaintiff prays this Honorable Court, after requiring full disclosure by the Plaintiff, to equitably divide the property, both real and personal, owned by the parties hereto as marital property. COUNT III - CUSTODY 16. Paragraphs 1- 15 are herein incorporated by reference. 17. Plaintiff seeks primary custody of the following children: NAME ADDRESS DOB Owen Henry Blosser 1669 Quail Drive Carlisle, Pa. 17013 4/22/93 Madelyn Jayne Blosser 1669 Quail Drive Carlisle, Pa. 17013 3114/96 The children were born in wedlock. The children are in the custody of Mother and Father. During the past five years, the children have resided with the following persons and at the following addresses: NAME ADDRESSES DATES Helen Blosser Timothy Blosser 1669 Quail Drive Carlisle, Pa. 17013. 1997 to present. The mother of the children is: Helen Blosser, currently residing at 1669 Quail Drive, Carlisle, Pa. 17013; however, she anticipates moving soon. She is married to Timothy Blosser. The father of the children is: Timothy Blosser, currently residing at 1669 Quail Drive, Carlisle, Pa. 17013. He is married to Helen Blosser. 18. The relationship of Plaintiff to the children is that of Mother. The plaintiff currently resides with her husband, Timothy Blosser, and her children; however she is anticipating moving soon. 19. The relationship of Defendant to the children is that of Father. The defendant currently resides with his wife, Helen Blosser. 20. Plaintiff has not participated as a party or 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 ofthis Commonwealth. Plaintiff does not know of 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. 21. The best interest and permanent welfare of the children will be served by granting the relief requested because: Mother has been the primary caretaker of the children since birth. is willing to provide ample visitation to father, and a stable home. 22. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, Plaintiff requests the court to grant custody of the children. Date: e;~g--03 dams, Esquire o. 79465 36 S th Pitt Street Isle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF VERIFICATION I verifY that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. g4904 relating to unsworn falsification to authorities. Date: ~ /of } 3 ~!~- ~~~~l :D: C>~ ":It. :>"1 -~. ~ ~: U\ :P- 6 0 ~8 ~ 3 (]\ }J \II OJ ( ~', :} ::-~) ." HELEN T. BLOSSER PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 03-3857 CIVIL ACTION LAW TIMOTIIY M. BLOSSER DEFENDANT IN CUSTODY ORDER OF COURT AND NOW, Wednesday, August 13, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cnmberland County Courthouse, Carlisle on Tuesday, September 09, 2003 at 8:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The conrt hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR TI-IE COURT. By: /s/ Tacqueline M. VernlO'. Esq. Custody Conciliator (, The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATIORNEY AT ONCE. IF YOU DO NOT HAVE AN ATIORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 . if~~ ~~~ ((;1-['/.? -~ ~ ~ ~u; fi;'fYj. ~/t?~ ~ ~ - ~ -J:79 fPC/jJ. VN\f!ilASNN3d 1 I \!ri\'-' ("r'."'~rl;-!::qV~n8 ,I',,,,.i',i ,. ',' ',., , L':i :2 S I ~nv SO AH\!JLJ=;,~:_b'!Ei:' ~o HELEN T. BLOSSER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 03 - 3857 Civil Term TIMOTHY M. BLOSSER, Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this August 14, 2003, I, Jane Adams, Esquire, hereby certify that on or about August 13,2003, a certified true copy ofthe NOTICE TO DEFEND, AND COMPLAINT IN DIVORCE were served, via certified mail, return receipt requested, restricted delivery, addressed to: Timothy M. Blosser 1669 Quail Drive Carlisle, Pa. 17013 DEFENDANT RespectfulJy Submitted: m-e-W~ e Adams, Esquire . No. 79465 3 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF '" . 16 > ." ~ a: ai 0 It.LI :3 o~(I)oE ... o'm:E>-~ ! g'Oc:.8-. " - O"M- en !i: <(.!a (/) t: o:t:::: :!t M~~~t5E ii'ii "T,J ~~~ '".om:g, ... C._ J:: II '" 0; - '" '" .... l:\l~a "0 E-E; l:a a ,.:"i~-$2~ ~ ... (/)t)Q)....-o~ ~ EEE1ij~E ~ ..., .$ (I) <<l C,) 0 0 liD 'j .- (I) c: Q) "'~ 12 I~~g~~~~ ;r Q.~>'~.J::- Q.l ... EE"E-S~6 13 ~ 8~;tg~6)i Ii · · · ~ ;;: $ "'" ~ ~ -..J ~ -'{ r- ~ t.n ~] ~. ~ hat r<) ~~~ I ~ !il~~ I ~ ~IH ~ jfl~ J 8 J B ~ ~~ 1;; . E () 8 () ~ '" 'cr VI t/1 o c &Qa. , c$ ~l ~o-' .~ 5 ~ ~cJ . ~ " c m ~ u " " !? 15. rIJ ~ I .- ... ~ ~ ~ 1il ~ is, E ~ " ~ .1l E ~ ~,g Crl z ~ '" .!!:117i E .:.1 @ 0 ~ ~ u.. (/J a. oj <> "."',. ;:OCJ-Ic- Coo-l:p. err C~ h;:E~m :,,:::1~> ~Cf)>O --51-1> ~mr""'::: Om:)::.'" w-l~ . (f) '" ~ a. '" " c z =1 ", '" (fJ 'iI '" ", '" "U o '" 'iI r (f) ", ?l o ", " m Ol '" CD '0 ~ ~ '< o c ~ => Ol 3 5" Ol a. a. CD '" -'" Ol => a. N 'ti + .". 3' S' or C' o x ~Vid':!' 3-otflia ::.(J)~h z "'ill' 9 QOm o '-;r~ ",,, o (I'I~ " '" a: . MAR U 9 2004 ~ HELEN T. BLOSSER, Plaintiff V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2003-3857 CIVIL TERM TIMOTHY M. BLOSSER, Defendant : CIVIL ACTION - LAW : IN CUSTODY ORDER OF COURT AND NOW, this 9th day of March, 2004, it appearing that cross custody complaints were filed by these parties and the case having proceeded under the docket number 2003-3024, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, ~ C)r'b/ acq ine M. Verney, Esquire, Cust Y Conciliator '~/"jll,J b 11 :5 !pj \ I ~WH ~Dnl l\b\llO>iGH.i.O~JJ 31-11 :10 3')1.:',.:'O-{i311:l HELEN T. BLOSSER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION- LAW : NO. 03-3857 TIMOTHY M. BLOSSER, Defendant : IN DIVORCE PRAECIPE TO ENTER/WITHDRA W APPEARANCE TO THE PROTHONTARY: Please enter my appearance on behalf of the Defendant, Timothy M. Blosser in the above captioned case. Date:2it -f 7 '2 6o"{ I Respectfully submitted, ROMINGJii:R, BAYLEY & WHARE ~v (" v-- "'"""- ad E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Defendant Please withdraw my appearance on behalf of the Defendant, Timothy M. Blosser in the above captioned case. /1 /J Date: Stl>L6.u 1, :J<ro1- ~ y- -t 7J!? I - f1arcu . :~:; ~i "" C~~ l:::::;:) ..<:- (/) p, -0 t c:> 9 n .-j ;C, .11---.0 r-- :32:',} C) ( ~--iC) !~~ 5~:! ~XJ -< ;1i .r::- r,...) HELEN T. BLOSSER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 03 - 3857 Civil Term TIMOTHY M. BLOSSER, Defendant : ACTION IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the Court for entry of a divorce decree: I. Ground for divorce: irretrievable breakdown under &330 I ( c) of the Divorce Code. 2. Date and manner ofthe service of the Complaint: Delivered by certified mail, restricted delivery, return receiPt requested on: August 13,2003. 3. Date of execution ofthe affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: October 4, 2004. By Defendant: October 1, 2004. 4. Related claims pending: None. S. Date Defendant's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: October 7, 2004. Date Plaintiff's Waiver of Notice in g3301(c) Divorce was filed with the Prothonotary: October 7, 2004. o.reco/;jov Res~nittf ~ . e Adams,~ I:. .D. No. 79465 36 S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ;t':.;:+; :+: . !+Oil: ,.,'" ~ :+:~:+::+:~:+::+: ~~:+::+:~++.+++:+:+++ +++++++++++~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . :+;:t':+::+:+:+: +: '+':+:++++ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . STATE OF PENNA. Helen T. Blosser, Plaintiff VERSUS No. 03 - 3BS7 Civil Term No. Timothy M. Blosser, Defendant AND NOW, DE:CRE:ED THAT AND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . !+' Of. +. + +. :+: +. + '+' + +. Of Of. '+' ++ DECREE IN DIVORCE o;}:b.,(3 ~7:It)A.#I. ~ , IT IS ORDE:RED AND Helen T. Blosser , PLAI NTI FF, Timothy M. Blosser ,DEFE:NDANT, ARE: DIVORCED FROM THE BONDS OF MATRIMONY. THE: COURT RE:TAINS JURISDICTION OF THE: FOLLOWING CLAIMS WHICH HAVE YE:T BE:EN E:NTE:RE:D; BE:E:N RAISE:D OF RE:CORD IN THIS ACTION FOR WHICH A FINAL ORDE:R HAS NOT None; The property settlement agreement executed on October 4, 2004, and And filed October 4, 2004 is incorporated but not merged into this Decree. l~ ...._ i --, '-"'\. - -,... ~ ~ . "'-, : -, .- ., - . , " ....' ~:".. , ~ . .. "".- . . . ~;;,..", ......._~. ,,:,~"/ , ./',./.~.. -.--;.' ", ~ ......,"'..... .-",,\.. ~ fj. +. f.. \:'-~ ....~"'-~ 0.00.00.0.000000.00.00.0.0.0. y ATIE'jJ~~ PROTHONOTARY . +'+' '+''f. :f.+:+:,+,:+,+;+.:t''+'+ Of. +:+: :+:++:+:+Cf 'l':+:+: +;+:+ J. ~d r ~ ~ ~#,Ar/- 61. W ~ r f2 ~~} ~ /7(/ /,1.0/ .. . . , HELEN T. BLOSSER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA ,385'7 No. 03-~ Civil Term TIMOTHY M. BLOSSER, Defendant ACTION IN DIVORCE PRAECIPE TO WITHDRAW APPEARANCE TO THE PROTHONOTARY: Please withdraw my appearance in the above-captioned matter on behalf of the defendant. Respectfully Submitted --- . ./ c"l Date )'~.' - ~, c:... GO~) . ) /.-.......-. Karl Rominger, Esquire 155 S. Hanover Street Carlisle, PA 17013 (717)214-6070 PRAECIPE FOR ENTRY OF APPEARANCE TO THE PROTHONOTARY OF SAID COURT: Please enter the appearance of Galen R. Waltz, Esquire, on behalf of the Defendant in the above-captioned case. -:;).tn 1>,..:4 0 /J (P Date (" l"'"j c) ~:-: :::1 ['1 <"...' 0.:' N