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Home My WebLink About02-0783Michael J. Wilson 816 Derby Avenue Camp Hill PA 17011-8367 Attorney for Plaintiff PA ID No.: 52680 (717) 774-7018 (717) 774-7019 (facsimile) email: wilsonmesq~aol, com IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA SHARON ANN BEDRIN 76 Tory Circle Enola, PA 17025 Plaintiff THOMAS BEDRIN 4916 Gander Court Harrisburg PA 17112 Defendant CIVIL ACTION-LAW IN DIVORCE 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. When the ground for 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, Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. (717) 240-6195. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A 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: Court Administrator 4th Fl., Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 Michael J. Wilson 816 Derby Avenue Camp Hill PA 17011-8367 Attorney for Plaintiff PA ID No.: 52680 (717) 774-7018 (717) 774-7019 (facsimile) email: wilsonmesq~aol.com IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA SHARON ANN BEDRIN 76 Tory Circle Enola, PA 17025 Plaintiff THOMAS BEDRIN 4916 Gander Court Harrisburg PA 17112 Defendant CIVIL ACTION--LAW IN DIVORCE NO. COMPLAINT IN DIVORCE COUNT I - DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE Plaintiff, by her attorney, Michael J. Wilson, respectfully represents: 1. The Plaintiff is Sharon Ann Bedrin, who currently resides at the above- captioned address in the County of Cumberland, Commonwealth of Pennsylvania. 2. The Defendant is Thomas Bedrin, who currently resides at the above-captioned address in the County of Dauphin, Commonwealth of Pennsylvania. 3. Plaintiff and Defendant are sui juris, and both have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on June 15, 1974 in Luzeme County, Pennsylvania. 5. The parties have two children fi.om the marriage, Philip Nicholas Bedrin, 20 years of age and an emancipated adult, and Jessiea Ann, who is 14 years of age. 6. There have been no prior action of divorce or annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiffrequests the Honorable Court to enter a decree in divorce, divorcing Plaintiff and Defendant. Respectfully submitted, Michael J. Wilson Attorney for Plaintiff -2- VERIFICATION TO COMPLAINT IN DIVORCE Plaintiff verifies that the statements made in this Complaint are tree and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. CS § 4904, relating to unsworn falsification to authorities. Sharon Ann Bedrin .~ IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA SHARON ANN BEDRIN 76 Tory Circle Enola, PA 17025 Plaintiff Vo THOMAS BEDRIN 4916 Gander Court Harrisburg PA 17112 Defendant : CIVIL ACTION--LAW : IN DIVORCE : NO. 02-783 : : NOTICE: If ou wish to den an of the statements set forth in this affidavit ou must file a counter- affidavit within 20 da s after a co of this affidavit has been served on ou or the st~t_~ment will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on July 1, 1998 and have continued to live separate and aPart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 Title 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Date: ~ ~-HARON ANN BEbRIN Michael J. Wilson Attorney at Law 816 Derby Avenue Camp Hill PA 17011-8367 Attorney for Plaintiff (717) 774-7018 (717) 774-7019 (fax) IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA SHARON ANN BEDRIN Plaintiff V. THOMAS BEDRIN Defendant : CIVIL ACTION--LAW : IN DIVORCE : : NO. 02-783 : : .CERTIFICATE OF SERVICE The undersigned counsel, hereby certifies that on the date(s) set forth below, the listed paper(s) or document(s) and this Certificate of Service was/were served upon the individual(s) and address(es) noted by placing an original or photostatic copy/copies of each original paper or document in the regular and/or certified United State mail, first class postage pre-paid, except as otherwise noted. pAPER(S) OR DOCUMENT(S) SERVED I. Notice of Intention to Request Entry of Section 3301(d) Divorce Decree; 2. Counter-Affidavit Under Section 3301(d) of the Divorce Code; 3. Affidavit Under Section 3301(d) of the Divorce Code (copy of signed affidavit of Sharon Ann Bedrin); and, 4. Certificate of Service dated May 30, 2002 (copy). Thomas Bedrin 4916 Gander Court Harrisburg Pa 17112 Date: May 30, 2002 .PERSON(S) SERVED Michael J. Wilson -2- Michael J. Wilson Attorney at Law 816 Derby Avenue Camp Hill PA 17011-8367 Attorney for Plaintiff (717) 774-7018 (717) 774-7019 (fax) SHARON ANN BEDRIN Plaintiff IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION--LAW · IN DIVORCE NO. 02 - 783 THOMAS BEDRIN Defendant CERTIFICATE OF SERVICE The undersigned counsel, hereby certifies that on the date(s) set forth below, the listed paper(s) or document(s) and this Certificate of Service was/were served upon the individual(s) and address(es) noted by placing an original or photostatic copy/copies of each original paper or document in the regular and/or certified United State mail, first class postage pre-paid, except as otherwise noted. PAPER(S) OR DOCUMENT(S) SERVED 1. Praecipe to Transmit Record (with accompanying Notice of Intent, etc.); and, 2. Counter-Affidavit dated June 1, 2002. Date: June 7, 2002 PERSON(S) SERVED Thomas Bedrin 4916 Gander Court Harrisburg Pa 17112 Defendant, pro se Michael J. Wilson IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA SHARON ANN BEDRIN 76 Tory Circle Enola, PA 17025 Plaintiff THOMAS BEDRIN 4916 Gander Court Harrisburg PA 17112 Defendant CIVIL ACTION--LAW IN DIVORCE NO. 02 - 783 follows: AFFIDAVIT OF SERVICE BY CERTIFIED MAIL MICHAEL J. WILSON, being duly sworn according to law, deposes and says as 1. That he is the attorney for the Plaintiff in the above captioned divorce action. 2. That on February 14, 2002, he delivered to the US Postal Service in New Cumberland PA, as Certified Mail, Return Receipt Requested (Receipt No. 7000 1530 0001 0194 2140), addressed to the Defendant herein, a true and correct copy of the Complaint in Divorce filed in the above-captioned action endorsed with a Notice to Defend and Claim Rights. 3. The Return Receipt (Postal Service Form 3811) is attached hereto as Exhibit A showing a date of delivery to the Defendant on February 19, 2002. Michael J. Wilson Swom to and subscribed before me this ~¢t-~ayof (~-(_tp.~ ,2002. LAUra. i~REWSAKER' NOTARY PUBLiC ~ Carlisl~ J~o[o, Cumberland County J M¥COmmts~ien Ex~iresApriJ 4, 200~ ~ IN THE COURT OF COMMON PLEAS FOR SHARON ANN BEDRIN 76 Tory Circle Enola, PA 17025 Plaintiff THOMAS BEDRIN 4916 Gander Court Harrisburg PA 17112 Defendant CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION--LAW IN DIVORCE NO. 02- 783 · Complete items 1, 2, and 3. A~o complete item 4 if Restricted Delivery Is desired. · Print your name and address on the reverse so that w® can return the card to you. · Attach this card to the back of the mailplece, or on the front if space permits. 2. Article Number (Copy from sent/ce/abe/) li - o ooo/ Ps Form 3811, Ju~ l~e~ YES, e~ter delivery a lYes 4. Restricted Delive~? (Extra Fee) Domestic Return Receipt 102595-00-M~09~. EXHIBIT A - AFFIDAVIT OF SERVICE BY CERTIFIED MAIL IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA SHARON ANN BEDRIN Plaintiff : CIVIL ACTION--LAW : IN DIVORCE THOMAS BEDRIN Defendant NO. 02 - 783 COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or CO): ~fi~.~ (a) 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 live separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): t~/~ ~/ (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 ifI 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 Co) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party's attorney of record or upon the other party if he/she has no attorney. IfI 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 to thereafter file any economic claims. 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. THtOMAS BEDRIN 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 FH~E TI:IlS COUNTER-AFFIDAVIT. IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA SHARON ANN BEDRIN 76 Tory Circle Enola, PA 17025 Plaintiff : CIVIL ACTION--LAW : IN DIVORCE : : THOMAS BEDRIN 4916 Gander Court Harrisburg PA 17112 Defendant NO. 02 - 783 NOTICE OF INTENTION TO REQUEST ENTRY OF SECTION 3301(d) DIVORCE DECREE You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the Section 3301(d) affidavit. Therefore, on or after June 20, 2002, the other party can request to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary is attached to this notice. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the fight to ask for economic relief. The filing of the form counter-affidavit alone does not protect your economic claims. 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: Court Administrator 4th FI., Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 IN THE COURT OF COMMON PLEAS FOR CUMBERLAND COUNTY, PENNSYLVANIA SHARON ANN BEDRIN 76 Tory Circle Enola, PA 17025 Plaintiff Vo THOMAS BEDRIN 4916 Gander Court Harrisburg PA 17112 Defendant CIVIL ACTION-LAW IN DIVORCE NO. 02 - 783 PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Plaintiff requests that you transmit the record, together with the following information, to the court for entry ora divorce decree: Ground for divorce: Irretrievable breakdown under §3301(d) of the Divorce Code. Date and manner of service of thc Complaint: Divorce Complaint served on Defendant on February 14, 2002 by certified mail, restricted delivery, with a return receipt acknowledging service thereof on February 19, 2002. (b)(1) Date(s) of execution of the Affidavit of Plaintiffrequired by § 3301(d) of the Divorce Code: May 29, 2002 (b)(2) Date of filing and service of the Plaintiff's Affidavit upon the Defendant: May 30, 2002 Related claims pending: None. Date and manner of service upon Defendant of the Notice of Intention to file praecipe (with attached Counter Affidavit form) a copy of which is attached: Dated: Served May 30, 2002 by United State Mail, postage prepaid, to address set forth on Certificate of Service dated May 30, 2002 filed with the Court. Michael J. Wilson Attorney for Plaintiff SHARON ANN BEDRIN Plaintiff VERSUS THOMAS BEDRIN Defendant IN The COURT Of COMMON PLEAS OF CUMBERLAND COUNTY STATE Of ~~ PENNA. N O. 0:t - 7S3 CIVIL DECree IN DIVORCE AND NOW, ~ ~ ~l , , it IS ORDERED AND SHARON ANN BEDRIN DECREED THAT , PLAINTIFF, THOMAS BEDRIN AND , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOt YET BEEN ENTERED; None ATTEST _~~ J. PROTHONOTARY