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Home My WebLink About95-03582 ~ ~ ~ . ~ ~ (/) J1 ~ ~ J ~ 00 ~ I \{)I CT . -P ..... .:t:- .:.:. .:.:. .:.:. .:+:. .:.:. .:+:. .:<<. .:<<. .:.:. .:.:. .:.:. .:.:- -:.;. ~\. ."'.... . .. ....0.. .. . \ ..' ~\ . \ ~: , .:.;. :. .:+:. .:+:. .:+;. .:+;. .:+;. .:+:. .:+:. .:t:. .:<<. ';4 .. 18 8 8 8 . . ~( : i ~'\ '.'\ ~ .. " .., " .. " ~ .. " .. " .:+;. .:.;. .;+;. -:.;' .:.: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~. STATE OF j~~~1 PENNA, MERRIDY LOU SERSEN 1\ II. 95- 3582 " I') 95 8, \"'1',11'\ ~ THOMAS RICHARD SERSEN '.' ~ .' .. " ;;, " .. " ,;, " ,;, " ~ " w " 8 8 ~ 8 8 .. " 8 w " AND NOW, DECREE IN DIVORCE ....W~.."2)~..... 19"1.'... It Is ordered and decreed that ... M~~~t\lY. .I,.\>~. .llli!rll.~l').. . . . . . .. . . ... . . ... . ... ., plaintiff, ond . . .. . .. .. . . . .Thomas . Hehard. .Seraan. . . .. . . . .. . . . ... . . " 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; rut Jj()~ ..........' "",. ." ,..,... ..... ", 8 w " M ..' w ~ 8 8 ~ - ~ ..:: '.. .. '.. . ... .. .. .. '..... '''.' ..... ..... ..... . .' .... .... ..... ..... ..... ..... . . . . . . . " . " . . . J./. . . ; . . .. . . .. .. /. " / II v T 1II'~~1~~~' AII...ll.yo .. /' / L' 1.'''''''/ -,/ ;,>,.'I.,IL(.'/{.'" {,(.~ __~ r-~,r"~'r/ ';t,./ttl1'l ,.f',~~(t'". f);;.f . / / l'mlllUl1lJlRI'Y / ~ 8 8 8 8 8 8 8 8 8 8 8 " 8 8 8 8 8 8 8 . 8 8 8 8 8 8 8 8 ~ 8 J. 8 ~ ~ ~ M :.;. -:.: :t;. -:.: .:+;. .:+;. .:.:. .:.:. .:+:. .:.:. ':.;. .:.:. .:+;. .:.: .:t:-:t: ';t>:.: . ~!r;/ 110M, .fI.' ckl (~)' /1'111(/1'/ ,t. /,)/; II.X. f~ '1iJtI~; /fI~~J' g atf ,*/lfJ,'OH MERRIDY LOU SERSEN, Pluintlff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY PENNSYLVANIA v. NO. 95-3582 THOMAS RICHARD SERSEN, Defendunt CIVIL ACTION - LAW DIVORCE PRAECIPt: TO TRANSMIT RECORD Transmit the record, together with the following Information, to the Court for entry of a divorce decree: 1. Grounds for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Service was accepted by the Defendant on or about July 5, 1995 by Acceptance of Service dated October 31, 1997. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Merrldy Lou Sersen, Plaintiff, on September 26, 1997; by Thomas Richard Sersen, Defendant, on October 2, 1997. 4. Related claims pending: No claims were raised. 5. Date of filing of the Plaintiffs Waiver of Notice Is October 27, 1997. Date of filing of the Defendant's Waiver of Notice Is October 27, 1997. Date of execution of Plaintiffs Waiver of Notice Is September 26, 1997. Date of execution of Defendant's Waiver of Notice Is October 2, 1997. Respectfully submitted, BY: _ ~J.~116t1\a0 EMILY L. HOFFMAN, ESQUIRE Supreme Court 1.0.#66307 P.O. Box 11475 Harrisburg, PA 17108.1475 (717) 232.1112 Attorney for Defendant Date: November 14, 1997 L o . ~!, :!If' !IlL:' L~; t! ,A,', "'. r~; i . .~.,:~ i<j!....~ :;;tt'; ..... ~,:; " :::1 ~9 f;] ID ..~t..i \..;j I ~(': ", \ ':'J [" ., ? , . .H,l . ',J " )\0' ,<..t J ;~i'n " ::~ 11:1 ''0 :'l: t:>,\ ... {::;I MERRIDV LOU DERDEN, PI,IIINTt~F IN mE COURT of ,'oMMON PLEIIS O~' CUMBERI,AND COllN'rV. : PENNSVI.VAN.!/' " .A. ~~ NO. 9.1. ~3{Yv1 I. L~'V.J!I ,01 : CIVIL ACTION - LAW ACTION PaR DIVORCE V THOMAS RICHARD SERSEN. DEFENDANT NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in COUll. I f you wlsh lo defend against the claims set forth in lhe followlng pages. you must take prompt action. You 81'e warned that if YOIl fai I lo do so. the case may proceed without you and it decree of dlvorce or annulment may be entered against you by the court. II Judgement may also be entered against you for any other claim or relief requested in these papers by the Plainlllf. You mar lose money or property or other ri9hts important to you, includ ng custody or visitation of your chll dren, When the ground for the divorce is indlgnlties or irretrievable breakdown of the marrlaget you may re9uest marriage counseling. A list of marrlage counse ors is avallable in the Office of Prothonotary at the cumberland County courthouse, 1 Courthouse Square, carlisle. Pennsylvania. 17013. IF YOU DO NOT FILE PROPERTY. LAWYER'S FEES ANNULMENT IS GRANTED, YOU THEM, A OR MAY CLAIM FOR EXPENSES. LOSE THE ALIMONY. DIVISION BEFORE II DIVORCE RIGHT TO CLAIM ANY OF OR OF YOU SHOULD TAKE THI8 PAPER TO YOUR LAWYER AT ONCE, IF YOU 00 NOT HAVE A LAWYER OR cANNOT AFFORD ONE. GO TO OR TELEPHONE TilE OFFICE SET FOIlTII BELOW TO FIND OUT WHERE YOU CAN GE1' LEGAL HELP Cumberland county Lawyer Referral Service Cumberland County courthouse court Administrator 1 Courthollse Square Carllsle. Pennsylvanla. 17013 (717)-240-62~0 J. '. ~ By. (, usan sy\. l..:a e 0/ sq. 110 South~-lisle Btreet P.O, Box 670 New Bloomfleld. PA 17068 (717)-582-B766 Attorney for Plaintiff Dated: A~ MERRIDY LOU SERSEN. IN THE COURT OF COMMON PLEAS PLAINTIFF OF CUMBERLAND COUNTY. PENNSYLVANIA V NO. CIVIL CIVIL ACTION - LAW THOMAS RICHARD SERSEN, DEFENDANT ACTION FOR DIVORCE tiQ.TJ !;;L2L8 HlliT.-'tlL.99.!!1'lffi.iljQ You are one of the parties in the ahove captioned aotion in Divorce. By virtue of Section 202 of the Pennsylvania Divoroe Code, it is the duty of the Court to advise both parties of the availability of counseling and upon request to provide both parties a list of qualified professionals who provide such services. Accordingly, if you desire counseling. please advise in writing promptly by replying to: Prothonotary. Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. l70l3. Prothonotary MERRIDY LOU SERSEN. . IN THE COURT or COMMON PLEAS . PLAINTIFF . OF CUMBERLAND COUNTY. . . PENNSYLVANIA . . . V . NO. CIVIL . . . CIVIL ACTION - LAW THOMAS RICHARD SERSEN. DEFENDANT ACTION FOR DIVORCE I CUSTODY CONSOLIDATED COMPLAINT IN DIVORCE FOR DIVORCE AND CUSTODY 1. Plaintiff is MERRIDY LOU SERSEN. who currently resides at 57 Burd Drive. Camp Hill. Cumberland County. Pennsylvania. 17011. and has resided in cumberland County for over five (5) years. 2. Defendant is THOMAS RICHARD SERSEN. who currently resides at 57 Burd Drive. Camp Hill. cumberland county. Pennsylvania. 17011. and has resided in Cumberland county for over five (5) years. 3. Plaintiff and Defenaant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. The Plaintiff and Defendant are husband and wife and were lawfully married on July 16. 1977, in York County. Pennsylvania. 5. Neither plaintiff nor Defendant is in the military or naval services of the United States or its allies within the provisions of the Boldier's and Bailor's Civil Relief Act of the Congress of 1940 and its amendments. 6. There have been no prior actlons of divorce or for annulment between the parties eKcept thls Complaint flied for divorce. 7. The marriage is irretrievably broken. 8. Plalntiff and Defendant have been advised of the availability of counseling. and of the right to request that the Court require the parties to particlpate ln counseling, 9. The marriage is irretrievably broken. GQ.\JfiT ..1 REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(C) OF THE DIVORCE CODE 10. The prior paragraphs of this complaint are incorporated herein by reference thereto. 11. After ninety (90) days have elapsed from the date of filing of this complaint, Plaintiff intends to file an Affidavit consenting to a Divorce. Plaintiff believes that Defendant may also file such an Affidavit. WHEREFORE. Plaintiff respectively requests if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the date of flling of this Complaint, this Honorable Court enter a decree of divorce pursuant to Section 3301 (c) of the Divorce Code. GQ!)~T_Jt REQUEST FOR CONFIRMATION OF CUSTODY UNDER SECTION 5303 OF THE DIVORCE CODE 12. The prior paragraphs of this complaint are incorporated herein by reference thereto. l3. Plaintiff seeks Shared Legal and Primary physical custody of the following minor children: NAME RYAN THOMAS SERSEN REBEKAH RUTH SERSEN PRESENT RESIDENCE AGE 57 Burd Drive l/l2/79 Camp Hill, PA 17011 57 Burd Drive 12/l5/Bl Camp Hill, PA 17011 57 Burd Dri ve l2/l9/85 Camp Hill, PA 17011 RANDY PAUL BERSEN The children were not born out of wedlock. The children are presently in the custody of the Plaintiff and Defendant, who reside at 57 Burd Drive, Camp Hill, Pennsylvania, 170l1. The minor children since their births have resided with the following persons and at the following addresses: NAME ADDRESS Plaintiff, Defendant. Camp Hill, PA Loah Martin, and son, Paul, (Approximately OATES 1979 to 1980 Five (5) months). Plaintiff, Defendant. Liverpool, PA 1980 Lo 1991 Loah Hartin. and son. Paul Plaintiff, Defendant, Dover. PA 1992 to 1987 and Oreg Heese. (Approximately Four (4) months). Plaintiff, Defendant. Camp Hill, PA 1997 to Present and Holly Neal, Plaintiff's Hother The Hother of the minor children is Herridy Lou Sersen, who currently resides at 57 Burd Drive, Camp Hill, PA 170l1. She is married. but has filed for divorce. The Father of the minor children is Thomas Richard Sersen, who ourrently resides at 57 Burd Drive. Camp Hill, PA, l70ll. He is married. but the Plaintiff has filed for divorce. 14. The relationship of Defendant to the minor children is that of the Natural Father, The Defendant currently resides with the following persons: NAME RELATIONSHIP Ryan Thomas Sersen Son Rebekah Ruth Sersen Daughter Randy Paul Sersen Son Plaintiff Wife 15, The relationship of the Plaintiff to the minor children is that of the Natural Mother. The Plaintiff currently resides with the followlng persons: NAME Ryan Thomas Sersen Rebekah Ruth Sersen Randy Paul Sersen Defendant RELATIONSHIP Son Daughter Son Husband 16. Plaintiff has not participated as a party or witness, or 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 of this Commonwealth. Plaintiff does not know of a person not 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. 17. The best interest and permanent welfare of the children will be served by granting the rellef requested: a. Plaintiff and Defendant have the great desire and ability to give their minor children the care and love, to nurture and assist with the development of their children. in a warm, loving environment. Plaintiff and Defendant have no desire nor inclination to keep the parties children from each other, but recognizes the important role both a Hother and Father plays in the development of a child. Plaintiff Ilnd Defendant tespectfully requt!Dt that they be awatded Shared Legal Custody of lheir children. with the Plaintiff l1111nll awalded the Pnmary Physical Custody of their minor children. and Defendant being awarded Partial Physical Gustody of theit chUdt.en acconliuy to the following schedule: b. Defendant to have lhe childlen with a liberal visitation schedule mutually agreed to by Plainttff. which 18 made in consideration with Defendant's employment schedule. c. The Holidays and the Children's Birthdays shall be shared between the parties. If one party shall desire the children for a greater period of time on a holiday that party shall request such time two (2) weeks prior to the holiday. and it shall be mutually agreed to by the parties. d. The Plaintiff shall enjoy Mother's Day and the Defendant shall enjoy Father's Day with their children ftom 9100 A.M. until 9:00 P.M.. e. The Parties shall each have the option of requesting two (2) one (1) week per i ods or two ( 2) weeks together of uninterrupted vacation time with the children, with thirty (30) days notice to the other parly and lhe mutual agreement of the other party. f. The parties agree to equally divide the Chtistmas vacation and Spr1ng break. g. And at such times as the Patties can mutually agreed upon. WHEREFORE, Plaintiff requests this Honorable Court grant Shared Legal and Primary Physical Custody of the minor children to Plaintiff, and Shared Legal Custody, with Partial Physical Custody to Defendant, as stated above. Respectfully Submitted, DATED:~~ , 1995 c-{'~~~ \~(RY\~~ Susan ay C n e 0 rd. No. 649 llO South Carlisle Street P.O. Box 670 New Bloomfield! PA 17068 Attorney for P aintiff MERRIDY LOU SERSEN. IN TilE coURT Of' COMMON PLF.AS PLAINTIFF OF CUMBERLAND COUNTY. PENNBY1NlINIlI V NO. CIVI L CIVIL ACTION - (JAW TIlOMAS RICHARD SERSEN, DEFENDANT ACTION FOR DIVORCE I CUSTODY 'lER1fJQhT191i I, MERRIDY LOU SERSEN. verify I am the Plaintiff in the foregoing aotion. that the attached Complaint for Divoroe and custody is based upon information which has been gathered by my oounsel in the preparation of this lawsuit. The language of the Complaint is that of my oounsel and not mine. I have read the Complaint and to the extent that it is based upon intormation whioh I have given to my counsel. it is true and correot to the best of my knowledge. information and belief. To the extent that the contents of the Complaint is that of counsel. I have relied upon oounsel in making this Verification. I understand that I am SUbject to the penalties of 18 Pat C.S. section 4904 relating to unsworn falsification to authorities for any false statements that I have made in the foregoing Complaint. DAT~UItI,.d.il ~\ 'j - , . . ' . THOMAS RiCHARD Sf,;RSEN, DEFENDANT IN 1'HE COUR'f OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW ACTION FOR DIVORCE / CUSTODY MERRIDY LOU BERSEN, PLAINTIFF V CERTH'JG.an: Pf.l,llmVJCl1; I, Susan Kay Candiello, Esquire, hereby certify that a true and correct copy of the foregoing COMPLAINT FOR DIVORCE / CUSTODY was served by first class mail, postage prepaid upon: Hr. Thomas Richard Sersen 57 Burd Drive Camp Hill, PA 17011 Date ~~u ,j , 1995 PA l706B ~~ P..J G' 'V '-l ~ ~ co ~ - It , . . . t__.. " " .= ~ l\ ~;. :, ~1 i:\ &.. 0:: ~. } ~ \3D~ ."0 \ \ \~ <t ~ . . . "- ~I~ ~ t MERRIDY LOU SERSEN. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL ACTION-LAW v. THOMAS RICHARD SERSEN. Defendant NO. 95-3582 IN DIVORCE AFFIDA VIT OF CONSENT I. A Complaint in Divorce under Section 3301(e) of the Divorce Code was filed on July 3. 1995. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service oflhe Complaint. 3. I consent to the entry of a I1nal decree of divorce aller service of notice of Intention to request entry of the decree. I verify that the statements made in this Affidavit arc tn1e and Correct. I understand that false statements herein arc made subject to the penalties of 18 Pa.e.S, ~4904 relating to unswom falsification to authOlities. Date: q- '.1(o'~ . , MERRIDY LOU SERSEN. Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW v, NO. 95-3582 THOMAS RICHARD SERSEN. Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEtlI ENTRY OF A DIVORCE DECREE UNnER ~3301W OF THE DIVORCE CODe 1. I consent to the entry of a final dccree of divorce without notice, 2. I understand that I may lose rights conceming alimony, division of property. lawyer's fees or expenses if! do not claim thel11 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 l11e 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 Date: q -d lc.- q 'J ME SERSEN .. MERRIDY LOU SERSEN, PlaintllT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYl.V ANI A CIVIL ACTION-LAW v. NO. 95-3582 THOMAS RICHARD SERSEN. Defendant IN DIVORCE AFFIDA VI1' OF CONSENT 1. A Complaint in Divorce undcr Section 3301 (cl of the Divorce Code was filed on July 3. 1995. 2. The marriage of Plain tilT and Defendant is irretrievably broken and ninety 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 ofintention to request entry of the decree. I verifY that the statements made in this Affidavit arc true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa,C.S. 04904 relating to unsworn falsification to authorities, Date: .., , '., , ---f'~' ....-' ;- ~",'. ,A/ <..., THOMAS R. SERSBN MERRIDY LOU SERSEN, Plaintl rr IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION.LA W v. NO, 95.3582 THOMAS RICHARD SERSEN. Defendant IN DIVORCE WAIVER OF tJQIJCE OF INTeNTION TO REQUI;8I ENTRY OF A DIVORCE DEC~EE UNDER.. 13301(Q) OF THE DIVORCE COPE 1. I consent to the entry of a Iinal 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 flied with the Prothonotary, I verify that the statements made In this Affidavit arc true and correct. I understand that false statements herein arc made subject to the penalties of 18 Pa.C.S. 04904 relating to unsworn falsllieatlonto authorities Dale: //"",.,.. c. ..../ l/h.~, 7'" THOMAS It SERSEN /. -'-y 'j .'":.! . ~,,' "., It. " ,i-, I I I I ~.. \ MERRIDY LOU SERSEN. PlulnliIT IN TIlE COURT OF COMMON PLEAS CUMllHRI.AND COUNTY PENNSYLVANIA v. NO. 95.3582 THOMAS RICHARD SIlRSBN. Defendunt CIVIL ACTION. LAW DIVORCE ACCEPTANCE OF SERVICE I accepted service of the Complainl in Custody on or aboUI July 5. J 995. ../ / /" .--_//~;i""" _,>,-t./- \ "__ Thomas R, Sersen Date: //l';'1 ~J? .''''-.,,-. p q ~ ~ ,-, --'. "I,'"'] ~ - 1'1 w ' ""~ iC' ..ry ;"1 ~ ~.~ ., ,., ~.~ N t' ~I\ .... .J ,,-,,-1 - ~ ....~ 1;.1 .- J UL () V. IN TII" COUIlT OF COMMON PL"AS OF CUMBERLAND COUNTY. I PENNSYLVANIA NO.~.J~)CIVIl, .:161,.- C IV I L AC'r! ON - (,AW cUSTODY / VISITATION MERRIDY LOU SERSEN, PLAINTIFF THOMAS RICHARD SERSEN, DEFENDANT ORDER Of COURT AND NOW. this -Y-;.l./ i). 1111/1, upon cons1deration of the attached complaint. it is hereby dll'ected that the parties and then respective counsel appeal' before -11...." ) ,');'''1('''/ (OJ, the conciliator, at 3'1 k 1"1",.. ." /)'10. ,,,'" ",L....,:J on the --Ll....f.L.- day of (lL'3'L'\ L . 1995. at U.['. o'clock ~.M., for a prehearing custody Conference. At such '- conference. an effort will be made to resolve the 1ssues 1n 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. Either party may bring the child/children who are the sub)ect(s) of th1s custody action to the conference. but the child/children's attendance is not mandatory, Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. FOR THE COURT: t,y' t~M 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 BE:LOW TO I" I NO OU1' WHERE yOU CAN GET LEGAL HELP. BY: OFFICE OF TilE COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE. FOURTH FLOOR CARLJSLE, PENNSYLVANIA, 17013 (717) - 240 - 6200 Jut Ilj II 09 AM '95 "~"~I ,.', AIo\ ill i\ 7'I'Ifrdwl'~M~~.5. ~ "1 -I'I.?> 'J14 1114 a 11: 7.I'ltJf' ~ M~~ ~ fJ. ~~ l' . I j i' . , ".. . MERRlDY LOU SERSEN, Plaintiff I IN 'I'IIE COURT OF COOMOO PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I NO. 95-3582 CIVIL TERM I I CIVIL ACTION - LAW I CUSTODY/VISITATION /1' . vs. THOMAS RICHARD SERSEN, Defendant axJRT aIDER AND tQf, this 17th day of August, 1995, the Conciliator, being advised that the parties have resolved all outstanding custody issues by agreement, hereby relinquishes jurisdiction in this case. f,:~~~;!:;;~ ..... .-..... '".. ~I!V' WHlil~ J,Hir,):J IjlH'.!JiiHIlJ J,~Yt:,Hr,\jj 'ill I 10 101 Hi :, 56. WJ Z~ f. I'l onv