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Home My WebLink About06-7098 Dawne M. Blomstrom, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE David M. Blomstrom, Defendant :NO. 06- 1098 CIVIL TERM 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 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, Cumberland County Courthouse, Carlisle, Pennsylvania. 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION 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, Pennsylvania 17013 (717) 249-3166 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. You must attend the scheduled conference or hearing. DAWNE BLOMSTROM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE DAVID BLOMSTROM, Defendant : NO. 06 - 9 109 P CIVIL TERM DIVORCE COMPLAINT The plaintiff, Dawne M. Blomstrom, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. $43301(c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Dawne M. Blomstrom , who currently resides at 1512 A Mountain Road 2. Newburg, Cumberland County, PA 17240 since approximately September 2006. Prior to that, she resided at 26 Oak Bend Road Newburg, Cumberland County, PA 17240 since approximately June 2006. 3. Defendant is David M. Blomstrom, who currently resides in Michigan and is believed to receive mail at Post Office Box 33, Chatham, Alger County, MI 49816 since approximately June 11, 2005. 4. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 5. Plaintiff and Defendant were married on January 18, 2003 at Exmore, Northampton County, Virginia. 6. Plaintiff and Defendant have lived separate and apart since June 11, 2005. 7. There have been no prior actions for divorce or for annulment between the parties. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and that Plaintiff may have the WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Samara Gomez Certified Legal Intern ROB INS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 C? rv C7 __ C:J1 5 1 - VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date k?,-G -Ofo Plaintiff Dawne A Blomstrom o? Dawne M. Blomstrom, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE David M. Blomstrom, Defendant : NO. 06- %99 99 CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Dawne Blomstrom, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date / 13 06 Respectfully submitted, Samara Gomez Certified Legal Intern Ad ?jm. AA, hU ROE INS THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ' Y _ C.D - t f CJ -? ?rJ Dawne M. Blomstrom, Plaintiff V. David M. Blomstrom, Defendant To The Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 06 - 7098 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT Please reinstate the Divorce Complaint in the above-captioned docket. Samara Gomez Certified Legal Intern Abo?w 1_w,_4_w,4Jv4 Megan iesmeyer Supervising Attorney Date: a 1 Aq /077 7` Dawne M. Blomstrom, : IN THE-COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW IN DIVORCE David M. Blomstrom, Defendant : N0.06 - 7098 CIVIL TERM 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. Y au 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 mone or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indig you may request marriage counseling. A list of the Prothonotary, Cumberland County Courthol ties or irretrievable breakdown of the marriage, arriage counselors is available in the Office of Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR LAWYER'S FEES OR EXPENSES BEFORE A YOU MAY LOSE THE RIGHT TO CLAIM AN YOU SHOULD TAKE THIS PAPER ?IMONY, DIVISION OF PROPERTY, IVORCE OR ANNULMENT IS GRANTED, OF THEM. YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION A OUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS iT A REDUCED FEE OR NO FEE. Cumberland Co 32 South Carlisle, Pe (717) Bar Association Ford Street lvania 17013 3166 AMERICANS WITH D The Court of Common Pleas of Cum the Americans with Disabilities Act of 1990. Foi reasonable accommodations available to disabled please contact our office. All arrangements must or business before the court. You must attend the ACT OF 1990 id County is required by law to comply with information about accessible facilities and individuals having business before the court, be made at least 72 hours prior to any hearing scheduled conference or hearing. DAWNE BLOMSTROM, Plaintiff V. DAVID BLOMSTROM, Defendant CIVIL TERM :,IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 06 - 7098 MPLAINT The plaintiff, Dawne M. Blomstrom, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE 1. Plaintiff is Dawne M. Blomstrom, wh currently resides at 26 Oak Bend Road Newburg, Cumberland County, PA 1 240 since approximately February 2007. 2. Defendant is David M. Blomstrom, w o currently resides at 1608 Lakeshore Drive, Gladstone, Delta County, MI 49837. Mr. Blomstrom has resided in Michigan since approximately June 11, 2005. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on January 18, 2003 at Exmore, Northampton County, Virginia. 5. Plaintiff and Defendant have lived separate and apart since June 11, 2005. 6. There have been no prior actions for divorce or for 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 that the court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Awnd'64 A7// Samara Gomez Certified Legal Intern 6ryy/v Amm ROB T E. THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 I verify that the statements made in the fore best of my knowledge, information and be] would subject me to the penalties of 18 Pa. authorities. Date . 5-)?' 41 n-7 ng complaint are true and correct, to the I understand making any false statement §4904, relating to unsworn falsification to Plaintiff_a l.4w in Dawne M. Blomstrom. ???-Ti 4 c:.) O A 1 ?yy. Dawne M. Blomstrom, IN THE COURT OF COMMON PLEAS OF c`} Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE David M. Blomstrom, Defendant NO. 06-7098 I CIVIL TERM CERTIFICATE OF SERVICE I, Holly 0. Vaughn, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the divorce complaint on David M. Blomstrom, residing at W 6151 Elmwood, Menominee, Michigan, 49858, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by David M. Blomstrom on the 8 h day of August, 2007 as evidenced by the attached green card. S&( Holly O.' Vaughn ' Certified) Legal Intern s'-U& - Anne c onald-Fox Supervising Attorney FAMILY LAW CLINIC 45 Northj Pitt Street Carlisle, PA 17013 (717) 24 2968 Fax: (711) 243-3639 Msr < it 11fiMI?IM'?Iiw y N alNM?d x 0 Aaw t ¦ P*A your nwo ON Oft"W'On M?l? MAW 0 so that vfo am mks" 004" to YOM a. tirorwra??{? c. DW of owk" ?r lilMiah ttdsd do thR nie, . st on the If OPMO ,;m I D6 t. t? t. AM* /IOMOMW UK o vim, 13 No al?4I?67 RESTIII y9ass' lKnowhad ua 13 IF MW ! M d ft %D or w wv OW o C3 km#W Mol C.O.D. 4. Rss6tW D~ (Extrs'AW yes 2. AdICMNwn 7005 0390 0003 2632 5683 I"o""a - ii iw bri uw Ps For, 3811. Fewwey 2M C1o M MI? n ¦ Mr? tlar*t , -M-, sao Dawne M. Blomstrom, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE David M. Blomstrom, Defendant : NO. 06-7098 CIVIL TERM NOTICE TO DEFENDANT If you wish to deny any of the allegations set forth in this affidavit, you must file a counteraffidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in approximately June 2006, and have continued to live separate and apart for a period of at least 2 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 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 unworn falsification to authorities. Date \ \-VW1 OA a15awne M. Blomstrom Plaintiff ?? ' =e? -' c 1 ?_ ' R Fi ?r l .. ' ?-..' 1,LL.r ,.' -; i'F . CgJ ; Dawne M. Blomstrom, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE David M. Blomstrom, Defendant : NO. 06-7098 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on December 13, 2006. 'A Praecipe to Reinstate Complaint and a reinstated complaint were filed on March 29, 2007. An Amended Divorce Complaint was filed on May 29, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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. Date aO O )u' Dawne M. Blomstrom, Plaintiff ? ?. f,'°t C.:^? a C'3 c:? j Ci?- ^' ?--? rt ' t"?' ?.,.- tom; ..'1 y : . ,? ?..? -, ? .. z.3 i " ?+? ? ?, ° ,.,::, r` Dawne M. Blomstrom, Plaintiff v. David M. Blomstrom, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 06-7098 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 43301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. 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. 24 4 " Date LDawne M. Blomstrom, Plaintiff r: r? ! i 4 Dawne M. Blomstrom, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE David M. Blomstrom, Defendant : NO. 06-7098 CIVIL TERM NOTICE TO DEFENDANT If you wish to deny any of the allegations set forth in this affidavit, you must file a counter-affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AMENDED PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated in approximately June 2005, and have continued to live separate and apart for a period of at least 2 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 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. Date I I' Imp awne M. Blomstr Plaintiff eTJ } ?w } (__: I ` Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court 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. You must attend the scheduled conference or hearing. Dawne M. Blomstrom, Plaintiff V. David M. Blomstrom, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 06-7098 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF § 3301(d) DIVORCE DECREE TO: DEFENDANT You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the § 3301(d) affidavit. Therefore, on or after April 17, 2008, the other party can request the court 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 of the court 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 right 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. IF YOU CANNOT AFFORD A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. r-a C? ? -rt C ?; ?-? " ?t, ? :-? ._r??. ,}r ?-., ,? .?.? Lj' Dawne M. Blomstrom, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE David M. Blomstrom, Defendant : NO. 06-7098 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown and separation for two years under § 3301(d) of the Divorce Code. 2. Date and manner of service of the complaint: Certified mail, restricted delivery, return receipt requested. Service was complete upon acceptance of service by Defendant on August 8, 2007. 3. Date of execution of the affidavit required by § 3301(d) of the Divorce Code: February 26, 2008; Date of filing and service of Plaintiff's Affidavit upon Defendant: Filed February 29, 2008 and served March 4, 2008. 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: First Class United States Mail on March 25, 2008. Date Angel Bradley Certified Legal Intern At4xt &?? Meg esmeyer Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 { ?: 1 u n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY %rA STATE OF PENNA. Dawne M. Blomstrom, Plaintiff VERSUS David M. Blomstrom, Defendant NO. 06-7098 Civil Term DECREE IN DIVORCE AND NOW, Aar- 1 IT IS ORDERED AND DECREED THAT Dawne M. Blomstrom , PLAINTIFF, AND David M. Blomstrom 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 BY THE C ATTEST: PROTHONOTARY -3O - 5-e -h Aa -5r -? Dawne M. Blomstrom, Plaintiff V. David M. Blomstrom, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE : NO. 06 - 7098 CIVIL TERM NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in divorce from the bonds of matrimony on April 24, 2008, hereby elects to retake and hereafter use her previous name of Dawne Marie Wert, and gives this written notice avowing her intention in accordance with the provisions of 54 Pa.C.S. § 704. Wishes To Be Known As: COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND r Dawne M. Blomstrom ?]?/p WeX7 awne M. Wert SS. On the 19`h day of June, 2008, before me, a Notary Public, personally appeared Dawne Marie Blomstrom, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS THEREOF, I have hereunto set my hand and Notarial Seal. NOTAR PUB oNOISSkWWO0 I +W 0g31S1111tl0 UNDA QTARY?PUBLIC CARLIS!£ BtNZD?}?ABfRIAlID COUNTY MY COMMISSION W4 DEC. 22 2010 c r ti y? c} "rJ i`- r stir CD i