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HomeMy WebLinkAbout06-3330GARY BREMER, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA HEATHER BREMER, Defendant CIVIL ACTION - LAW NO. 06 - 3330 CIVIL TERM IN DIVORCE 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 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. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORAMTION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.. Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 (800) 990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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. 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. GARY BREMER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW HEATHER BREMER, : NO. 06- -9330 CIVIL TERM Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff is Gary Bremer, an adult individual, who resides at 4702 Enola Road, Newville, Cumberland County, Pennsylvania 17241. 2. Defendant is Heather Bremer, an adult individual, who resides at 4702 Enola Road, Newville, Cumberland County, Pennsylvania 17241. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on August 9, 1997, in Camp Hill, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. COUNTII EQUITABLE DISTRIBUTION 9. Paragraphs 1 through 8 are incorporated herein by reference as if set forth in their full text. 10. Plaintiff and Defendant are joint owners of various items of personal property, furniture and household furnishings acquired during their marriage, which are subject to equitable distribution. 11. Plaintiff and Defendant have incurred debts and obligations during their marriage, which are subject to equitable distribution. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree equitably dividing the parties' property and equitably apportioning the debts incurred by the parties. Respectfully submitted, ROMINGER & WHARE I Date,AMA, Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Plaintiff GARY BREMER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. HEATHER BREMER, Defendant CIVIL ACTION - LAW NO. 06 - CIVIL TERM IN DIVORCE 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. §4904, relating to unworn falsification to authorities. Date: (oZy-106 Gary B er, Plaintiff GARY BREMER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. HEATHER BREMER, Defendant CIVIL ACTION - LAW NO. 06 - CIVIL TERM IN DIVORCE CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Gary Bremer, Plaintiff, do hereby certify that I this day served a copy of the within Complaint in Divorce upon the following by depositing the same in the United States mail, certified with return receipt, restricted delivery postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Heather Bremer 4702 Enola Road Newville, Pennsylvania 17241 Respectfully submitted, ROMINGER & WHARE Dat Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court I.D. # 81924 Attorney for Plaintiff To ? ? ? ..._ ? ? b+ f? d O ? ? Q ? ? h, A- c P -?h- -,c c')` ? '? - ?. ? - r i ??.. ? ??i '" N ?: i , °rs _ ,c c"? _ =-rn G, ?? =?-? N -U? c? BREMER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06-3330 CIVIL 3ER BREMER, : CIVIL ACTION -LAW Defendant : IN DIVORCE PETITION FOR SPECIAL RELIEF FOR RETURN OF MOTOR VEHICLE , Heather Bremer, by her attorney, Kristen B. Gaddis, sets forth the following: 1 Respondent and Petitioner in the above Divorce Action have been separated since May 31, 2006, when Respondent moved out of the martial home. 2. During the marriage, the parties bought a 2004 Chevrolet Cavalier which was the primary transportation of Petitioner. Both Petitioner and Respondent are responsible for the payments on the Cavalier. On June 5, 2006, Petitioner found that Respondent had removed the vehicle without her knowledge and has since refused to return it. Respondent has in his possession at least one other vehicle which can be used for his transportation needs. Petitioner is employed at Sheetz Store #263 in Carlisle, Pennsylvania, approximately thirty (30) miles from where she is residing. Petitioner is required to rely on others for transportation to and from her place of Petitioner has had difficulty in securing transportation due to her working the overnight shift. Petitioner will continue to be irreparably harmed if she cannot find consistent transportation to her job. 0. Respondent does not need the use of the Cavalier, as he has at least one other vehicle in his possession that he can utilize. that Date: WHEREFORE, Petitioner respectfully requests your Honorable Court to order and direct husband return the jointly owned 2004 Chevrolet Cavalier to wife's possession. Respectfully Submitted, .s Gaddi Attorney for Heather Bremer, Petitioner Neuharth Law Offices PO Box 359 232 Lincoln Way East Chambersburg, PA 17201 717-264-2939 VERIFICATION I verify that the statements made in this document are true and correct to the best of my information and belief. I understand that fals.- statements herein are made subject to the of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: OCp kl Heather Bremer GARY BREMER, Plaintiff V. HEATHER BREMER, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-3330 CIVIL CIVIL ACTION -LAW IN DIVORCE PETITION RAISING CLAIMS OF ALIMONY. ALIMONY PENDENTE LITE EQUITABLE DISTRIBUTION AND LEGAL FEES AND COSTS Petitioner, Heather Bremer, by her attorney, Kristen B. Gaddis of Neuharth Law Offices, sets forth the following: 1. Petitioner/Defendant in the above-captioned action is without sufficient assets to maintain herself during the course of the divorce litigation. 2. Petitioner requests that she be awarded Alimony Pendente Lite. 3. Petitioner is without sufficient assets to maintain herself upon the entry of a Divorce Decree. 4. Petitioner requests that she be awarded Alimony upon the entry of a divorce. 5. Petitioner requests that she be awarded Counsel Fees in connection with the defense of the divorce case and that she be awarded reimbursement of costs she may expend in the defense of the divorce case. 6. Petitioner requests that the distribution of the marital estate in a manner that is just, fair and equitable. WHEREFORE, Defendant requests your Honorable Court to award the following relief: A. Alimony Pendente Lite to the Defendant. B. Alimony to the Defendant. C. Legal fees and court costs to the Defendant. D. Equitable Distribution. E. Such other relief as the Court may deem appropriate and equitable. Respectfully Submitted, t?addi Attorney for the De endant v O d 4 0. C ?t to c: =.l rti_ 1 ?pb C n n r? GARY BREMER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA Vs. CIVIL ACTION - LAW NO. 06-3330 CIVIL HEATHER BREMER, Defendant IN DIVORCE IN RE: PETITION FOR SPECIAL RELIEF ORDER AND NOW, this s ` day of July, 2006, a rule is issued on the plaintiff to show cause why the relief requested in the within petition ought not to be granted. This rule returnable ten (10) days after service. BY THE COURT, '4L Hess, J. ©1 i 1 4 GARY BREMER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06-3330 CIVIL HEATHER BREMER, : CIVIL ACTION -LAW Defendant : IN DIVORCE CERTIFICATION OF SERVICE I, Kristen B. Gaddis, Esquire hereby certify that I am on this day serving a true and correct copy of the attached Petition Raising Claims for Alimony, Alimony Pendente Lite and Equitable Distribution on the following individual(s) by First Class U.S. mail, postage prepaid addressed as follows: Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 Dated: p, Io'JA IDla Respectfully submitted, Neuharth Law Offices Kfiken B. Gadd Attorney For Defendant, Heather Bremer Supreme Ct. ID#: 202303 232 Lincoln Way East P.O. Box 359 Chambersburg, PA 17201 (717) 264-2939 -yl?= 7 l^ - J ti Curtis R. Long Prothonotary Office of the Protbonotarp Cumberfanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor 01o-333e) CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573