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Home My WebLink About95-00598 'r" 1 , " I' , " 'I " " " I, , , " I " " J I" I I J I I I ! I , I I I, I I k> I I ,,I ;1' 7'" I I'" " I' , " ,I I , , " "I 'I " " " " I ,.\ I, " , , , ' " 'I I , , , I 'I I' " , , 1",'1 I' 'I I, I ,,' . . ., ~ ~- .J' 'v)' ~ ~ .~ I . LAW OFFICES SAIDIS, GUIDO" MASLAND P. O. BOX 560 26 V;. mGH STREET CAltLlSLE, PENNA. 17013 l'HONE (717) 2043.6222 @ f (1/ J 12 ~lj :'11'95 ,i'I:, I'"~ 'I,'; ,I', nS'5a~. 4 ..5' ct::? /d. 4.t!.Zl1i,.....~~':::,t tH /th)~? 'f!;t-.#- J I tltll , , 1,'1 I I I I I r' I I I I" I ;1 , I' i'i ,I '.', I !, ,'I I "~, .,.. SAIDIS, GUIDO. SHUFF .. MASJ.AND 1~ w, /Ilah S"..I r.,lIo1o. PA BRUCE E. BASEHORE, Ji'laintiff IN THE COURT OF COMMON Ji'LEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95- 19,y Civil Term v. REBSCCA M. BASEHORE, Defendant IN DIVORCE NOTICE 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 againElt you by the Court. A judgment may alee 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 c;hildren. When the ground for the divorce iR indignities or in'etrievable 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 Councy Court House, High and Hanover Street, Carlislo, pennsylvania. IF YOU no NOT f'ILE A CLAIM FOR ALIMONY/ DIVISION OF PROPERTY, LAWYER I 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/ 00 TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Court Administrator One Courthouse square Carlisle, PA 17013 (717) 240-6200 SAIDIS/ GUIDO/ ..I!HUrF & MASLAND ,?;L~ ./ __......r/ Bye "..? _ Edward E. Guido, Esquire Supreme Ct. 1.0. . 21206 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff BRUCE E. BASEHORE, Plaintiff IN T.HE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY/ PENNSYLVANIA v. NO. 95- Civil Term REBECCA M. BASEHORE/ Defendan t IN DIVORCE COMPLAINT UND.R 81CTION 3301(4) or TNI DIVORCK COD I 1. Plaintiff is Druce E. BaSehore / who currently resides at 98 Regency South, Carlisle, Cumberland county/ Pennsylvania, 2. Defendant is Rebecca M. Basehore, who currently resides at 325 North Baltimore Street / Mt. Holly Spr ings / Cumber land County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in 1 the Commonwealth for at least six months immediately previous to the filing of this Complaint, both having resided here all of their natural lives. 4. The Plaintlff and Defendant were married on October 20/ 1984 in Mechaniceburg/ Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintif f has been advised of the availabi lity of marriage counseling and the Plaintiff nlay h"ve the right to SAJDIS,GUII>O, request that the Court require the partles to part.icipate in 8HU"F " MASLAND counseling. Having been so advised Plaintiff does not desire the l~ w, H1.h 8'.." CIlrU,II,PA Court to order counseling. 7. The marriage is irretrievably broken. 1 SAmlS, ClllmO, SIlU.... " MASUNI) l^ W, Illih Nil." ['orllol" ~^ BRUCE E. BASEHORE, Plaintif f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-598 Civil Term v. R~BECCA M. BASEHORE/ Defllndant IN DIVORCE AFFIDAVIT OF CONSENT TO DIVqRCE (1) A Complaint in divorce under Section 3301 (Q) of the Divorce code wao fil~d on February 3, 1995. (2) Defendant acknowledges that service of the Complaint was made by certified mail on February 14/ 1995. (3) The marriage of Plaintiff and Defendant is irretr.ievably broken and ninety days have elapsed from the date of filing thG complaint. (4) I understand that I may lose rights concerning alimony, divisLon of property / lawyer's fees or expenses if I do not claim them before a divorce is granted. (5) I conannt to the entry of a final decree of divorce. (6) I underlltand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or. expenses has not been filed with the court be foro the entry of a final decree in divor.ce, the right to claim any of them will be lost. (7) I have been advised of the availability of marriage counslll lin9 and understand that I may request that the court require that my spouse and I participate in counselling. Being so IId"illP.d, I do not r:equflst. thAt t,ha CO'lrt require that my spouse and 1 p,articipate in counselling prior to a divorce decree beln9 handed down by the Court. I IJedfy t:hllt the atatements made in thle affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 10 Pa, C.S. ~ection 4904 relating to unBwo~n f81~iflcat:ion to authorities. , , I)' 'I ,,) ,," Dtlted I L!.li/I_..tJ...~:...._/).: ,1 ) ;(" / . )) ; /, / 1 , I.--'Lj .~:(..} '/ ' R6becca M. Base . / , .. '/' .,,'.,.~ " I. /. ;)./...... ,'<.i ,.:..___ re, Defen ant " , , iI, , , ;' I , , , I I " I', " I' \ I I I " " II I, :I~~~ W , , I, .... I ' " " '.'"' ,.' -I'H ~:~ I I ,} " ~ ~ p ~ " " , I, ,I II , I' I, " " ,f'J' ;" ff f' ,1 l'l ,I -~ I f ~n ,.I N " ::G , " .1,:\ I' " " Ci ..' " ~ '. , , 1,1 " , I L I I I I, 'fl Ii' I , the following addresses: Persona A"~ressea D.IW Rebecca M. Basehore 802 N, Market St, DOB . Oct. 1994 and Bruce E, Basebore Mechanicsburg. PA 170~~ Rebecca M. Basehore 98 Regency Suuth Oct, 1994. Dee, 1994 and Bruce E, Basehore Carlisle, PA 17013 Rebecca M, Pasehore 32S N. Baltimore SI. Dec. 1994 - present Mt, Holly Springs, PA 1706~ Bruce E, Basehore 98 Regency South De"" 1994 . present CarHsl~, PA 17013 The mother of the children Is Rebecca M, Basehore, currently residing at 325 Nortb Baltimore Street, Mt, HoHy Sprinl!s, PA 1706~, Cumberland County, Pennsylvania 17065, She Is married, The father of the r:hlldren is Bruce M. Basehore, currently residing at 98 Regency Suuth, Carlisle, Cumberland County, Pennsylvania 17013. He Is married. I 4. The relationship of the respondent to the child is that 01' father, The respondent currently resides with the followinll persons: lSID1I Relationship Brett T. Basehore (for 4 days) Kayla L. Basehore (for 4 days) sun daughter 5, The relallonship of petitioner to the child Is that of mother. The petitioner currently resides witb the following persons: lSID1I Robert DelRoso Bfhltlonshlp boyfriend Prell T. Dasehl)re (for 4 days) Kayla L. Basehore (for 4 days) son daUllhter I I I 6, Petitioner has not participated as a party or wllness, or In another capacity, In other Iltillalion concel'Olnlllhe custody of Ihe children in this or another court, Petitioner has no Infonnatlon of a custody proceedlnll concerninllthe children pendlnll in a court of this Commonwealth. .1 Pelititloner dOllS not know of a person not a party 10 Ihe proceedings who has physical cuslody of the children or claims to hBve cUf,tody or visitation rights with respect 10 the children. 7. The best Interest and pennanent welfare of the children will be served by granting the relief requesled beca~se: a) Petitioner has been prhnBry caretBker of the children since birth; b) Petitioner provides the children with a home with adequate moral. emotional and physical surroundings as required to meet the children's needs; c) Petitioner Is willing to accept custody of the children; d) Petitioner continues 10 exercise parental duties and enjoys the love and affection of the children; 0) Respondent has not Indicated to petitioner an Interest In accepting custody of the children. 8, Each parent whose parental rights to the children have not been lenninated and the person who has physical custody of the children have been named as parties to this action. WHEREFORE, petitioner requests the court to grant her joint legal and physical cusllldy or the children. nIB FAMILY LAW CLINIC 45 North Pill Street Carlisle, PA 17013 (717) 243-2968 BRUCE E, BASEHORE, PlaintIff. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION. LAW : IN DIVORCE REBECCA M. BASEHORE, Defendant. : NO, 95-598 CIVIL TERM 1995 CERTIFICATE OF SERVICE I, Taryn F. Goldsleln, Student Attorney, of Ihe Family Law Clinic, hereby certify Ihot I am servina a tNe and correct copy of Ihe Defendant's Pelitlon For Cuslody on Edward E. Q.W~o. ~Quire. Sal4ls. Guido. Shuff & Mosland. 26 Wesl High Slreet. Carlisle. PA 17013 by depositing a copy of the some In the United Sloles moll, first class. posloge prepaid. Ihisllb day of A\lIil, 199~. ;1A_l\,J .It\J;filf:.) Taryn F. Goldstein Certified Legallntem