Scribd Logo
Upload

Welcome to Scribd!

  • Seidle Divorce Complaint

    Uploaded by

    Asbury Park Press
    36K views16 pages
    Seidle Divorce Complaint

    Copyright

    © © All Rights Reserved

    Available Formats

    PDF or read online from Scribd

    Did you find this document useful?

    Is this content inappropriate?

    Report this Document
    Seidle Divorce Complaint

    Copyright:

    © All Rights Reserved
    Download as PDF or read online from Scribd
    Flag for inappropriate content
    36K views16 pages

    Seidle Divorce Complaint

    Uploaded by

    Asbury Park Press
    Seidle Divorce Complaint

    Copyright:

    © All Rights Reserved
    Download as PDF or read online from Scribd
    Flag for inappropriate content
    of 16
    a } Law Offices of Christine N. Rossi, L.L.C. Wii Heterence #- The Pavilion Professional Center Overpayment Amount ~ 2 74 Brick Blvd., Bldg. 2, Suite 103 eae Brick, New Jersey 08723 (732) 451-9555 Attorneys for Plaintiff, TAMARA SEIDLE a a eee eee SUPERIOR COURT OF NEW JERSEY TAMARA SEIDLE, CHANCERY DIVISION/FAMILY PART - 5 IMONMOUTH COUNTY pocket no. FAl-[3- 209 5- ie CIVIL ACTION COMPLAINT FOR DIVORCE TAMARA SEIDLE, residing at 708 Heritage Court, in the Township of Neptune, County of Monmouth, State of New Jersey, by way of Complaint against the Defendant, Philip T. Seidle, says: 1. She was lawfully married to the Defendant, Philip Seidle, on August 25, 1990, in a religious ceremony in Asbury Park, New Jersey. 2 She was a bona-fide resident of the State of New Jersey, and the County of Monmouth, when this cause of action arose and, for more than one year next preceding the commencement of this action, continued to be such a bona-fide resident. 3 The Defendant, Philip Seidle, has a last known address of 24 Equestrian Drive, Tinton Falls, New Jersey. 4 There are nine (9) children born of the marriage, namely, Kirsten Seidle, | age twenty-two (22) years, do.b. January 6, 1991; Philip Samuel Seidle, age tventy (20) | years, d.o.b. April 7, 1993; John Seidle, age eighteen (18) years, d.o.b. March 22,1995; Oo Christopher Seidle, age seventeen (17) years, d.o.b. February 28, 1996; Monica Seidle, age fifteen (15) years, d.o.b. May 6, 1998; Dorothy Scidle, age thirteen (13) years, d.o.b. October 20, 1999; Maria Seidle, age ten (10) years, d.o.b. July 2, 2002; Stephen Seidle, age nine (9) years, d.o.b. May 11, 2004; and, Teresa Seidle, age five (5) years, d.o.b. January 22, 2008, all of whom are in the residential custody of the Plaintiff. EMANCIPATED. FIRST COUNT - EXTREME CRUELTY 5. The defendant has been guilty of extreme cruelty toward the plaintiff commencing essentially at the inception of the marriage, and continuing from that time through the present. Particularly specifying the acts of extreme cruelty committed by the defendant, Plaintiff says that: a) — The parties were married following a brief courtship, and, soon after they exchanged their vows, the Plaintiff began to observe what appeared to be the Defendant's obsession with pornography and playing video games. When the Plaintiff approached the Defendant expressing her concern over what appeared to be developing into addictions, the Plaintiff was abused at the Defendant’s hand, both physically, emotionally and verbally. ‘The Defendant’s conduct demonstrated his blatant disregard for the Plaintiff's health and emotional welfare, and, his refusal toaddresshis addictions wasat the heart of numerous arguments between the parties. b.) Sadly, the Plaintiff's mother passed away in 2003, and, around thesame time, the parties’ daughter, Maria, then an irfant, was in a near death medical condition. These situations, coupled with the Defendant's ongoing course of abusive conduct, caused the Plaintiff tremendous amount of stress. Plaintiff fell ill, and, was caused to have her gall bladder removed. Soon thereafter, Plaintiff learned that the Defendant had been engaging | inan extramarital affair wi who lived in Room 326 of the Neptune Motor Lodge. Once his adulterous affair was exposed, the Defendant's behavior became increasingly intense and hostile. Although the Plaintiff did not make application for a Restraining Order against the Defendant, she certainly had grounds to have done so. ©) — Tnoneinstance, while the Plaintiffwas pregnant, the Defendant held a loaded gun to her head, cocked the weapon in a threatening and intimidating fashion, with no regard to the torment he was causing the Plaintiff. 4.) Onanother occasion, again, while the Plaintiff was pregnant, in a fit of rage, the Defendant kicked the Plaintiff in the stomach, demonstrating gross indifference to the welfare of the parties’ unborn child, as well as to the health and safety of the Plaintiff, ©.) Inanother fit of rage, displayed against the Plaintiff on her birthday, the Defendant punched the Plaintiff in the face, causing her to sustain a black eye, this fit of rage the outcome of the Plaintiff's having confronted the Defendant about various billing entries appearing on the parties’ cable bill for pornographic materials. £) The Defendant's aggressive behaviors persisted throughout the parties’ marriage, and on more than one occasion, the Defendant recklessly pushed, shoved and/or threw the Plaintiff into walls with such force as to cause damage to the wallls, as well as injury to the Plaintiff. g) _ Given her devotion to the children, to her family, and, in fear, having developed a financial dependence upon the Defendant, the Plaintiff, despite the torture she had endured during the marriage, agreed to an attempted reconciliation, and, the parties went to counseling, h.) Plaintiff was diagnosed with breast cancer in or about October, 2010, causing her to undergo a double mastectomy, radiation and chemotherapy. Plaintiffs course of 2 OQ treatment ran through approximately June, 2011, Approximately one month later, Plaintiff learned that the Defendant had engaged in yet another extra-marital affair, which had been ongoing, atleast, during the Plaintiff's course of treatment. The Defendant's paramour was ‘identified as IMI court, Tinton Falls, New Jersey. Of course, the Defendant assured the Plaintiff his extramarital relationship had been terminated, the Defendant, willfully, recklessly and negligently continued to engage in sexual relations with both his paramour, HE 214, the Plaintiff. Atthetime, given Plaintiff's compromised medical condition, she became more susceptible to infection. And, the symptoms of the various urinary tract infections Plaintiff developed were aggravated. Defendant's callous aititude remained, as regardless, he continued to engage in relations with his paramour, while at the same time, professing his love for the Plaintiff and begging for the Plaintiff's forgiveness. i) Falling for his promises, and, devoted to the family, the Plaintiff agreed to go to counseling once again, despite the Defendant's lies, manipulations, indiscretions and abusive conduct throughout the relationship. During this round of counseling, Plaintiff learned that this extra-marital affair had been ongoing for an extended time, greater than the time frame originally confessed. At the same time, the Plaintiff discovered bank statements reflecting substantial purchases at furniture stores, which furnishings were not for the marital home or the benefit of the family, but, for the home off J) On January 7, 2012, the Defendant vacated permanently, the former marital home, and, took residence with his paramour. k.) When the Defendant left, he assured the Plaintiff that he would properly support his family. His false promises in this regard proved to be yet another of the Defendant's lies. Defendant has failed to properly support the Plaintiff who gave up her > career for the betterment of the family, and, who was and is financially dependent upon the Defendant. Further, the Defendant has failed to properly support the parties’ nine (9) children, six (6) of whom are under the age of 18. 1) Knowing that the Defendant's income through his employment with the ‘Township of Neptune Police Department is necessary to support his family, the Defendant has repeatedly threatened that he willbe retiring, leaving the Plaintiff.and, the parties’ nine (9) children to fend for themselves financially. Defendant has callously acknowledged that without his support ata meaningful level, which will be dramatically minimized, according to him, when he retires, the Plaintiff will lose the home. Defendant's statements in this regard are uttered regardless of the emotional torment he causes to the Plaintiff, as for obvious reasons, it will be difficult for the Plaintiff to identify appropriatealternate housing for herself and nine (9) children, ranging in ages from 22 years to 5 years. m.) In the meantime, althorgh the Defendant continues to maintain gainful employment, he has disregarded his financial obligations to his family, in wanton disregard for their welfare, forcing the Plaintiff to borrow from others, simply to keep food on the tableand cloth the parties’ children. And, he has funded the purchases necessary to furnish his paramour’s residence, dissipating monies desperately needed by the Plaintiff and the parties’ 9 children. 6. Plaintiff reserves the right to amend this Complaint, as there exist numerous other acts of extreme cruelty by the Defendant, however, Plaintiff wishes to save herself from further embarrassment at this time. 7. By reason of these acts of extreme cruelty, Plaintiff's health and safety have become endangered, and it is improperand unreasonable to expect Plaintiff to continne to cohabit with the defendant. 9 d 8. More than three months have elapsed since the last act of extreme cruelty complained of as constituting Plaintif?'s cause of action herein. The acts of extreme cruelty committed by the defendant within a period of three months before the filing of the Complaint, as above set forth, are alleged not as constituting in whole or in part the cause of action set forth therein, but as relating back to qualify and characterize the acts constituting said cause of action. 9. There has been one prior proceeding between the plaintiff and the defendant respecting the marriage or its dissolution, specifically, there was an FD matter docketed FD-13-1248-12, resulting in the entry of a Consent Order regarding parenting time, ‘The aforementioned Domestic Relations Order persists. WHEREFORE, Plaintiff demands judgment: a.) Dissolving the marriage between the parties; b.)__ For sole legal and residential custody; ©.) For child and spousal support; 4.) Equitably distributing all property, both real and personal, ownéd or acquired, as well as all debt incurred, by the parties during the course of the marriage; e) Consolidating the FD action with the matrimonial action under this docket; £) For counsel fees and costs; &) _ Forleave to resume her maiden name Tamara Maria “Wilson”; h.) For such other relief as the Court may deem equitable and just. SECOND Cr TEVIS AND BA’ RED WOMAN’S SYNDROME 10.) Plaintiff repeats and realleges the allegations contained in Count One of the Complaint as if more fully and particularly set forth herein. 1) Asa result of the Defendant's actions, a fraction of which are described herein above in Count One, the Plaintiff was caused to suffer physically and emotionally. Defendant was physically and emotionally abusive to the Plaintiff throughout the parties’ marriage, and, the Plaintiff was controlled by the Defendant's, having no avenue to escape. 12.) _ Plaintiff was a victim of largely unreported, undocumented (although some incidents did involve police intervention) domestic violence throughout the parties’ marriage. The Plaintiff sacrificed her career for the betterment of the family, and, to enable the Defendant to advance in the rankings at his employment, while she was a devoted stay at home mother to the parties’ nine (9) children, 13.) _ Since the onset of the parties’ marriage, the Defendant has intentionally and/or negligently perpetrated psychological, verbal and physical abuse upuu the Plaintiff which abuse was recurring over an extended period of time. 14.) The Defendant's actions served to paralyze the Plaintiff from taking action to protect herself from the Defendant's abuse, and, given her dependence upon the Defendant, she was forced to remain under the command and control of the Defendant, unable to extricate herself from his abuse. As a proximate cause and/or direct result of the Defendant's abuse, the Plaintiff has been severely and permanently injured and has been caused repeated and recurring psychological injury over an extended period of time, The Plaintiff has, in the past, and, will require counseling and other medical services to treat her condition, proximately caused by her tortured marriage to the Defendant. Given the gravity of the situation, it would be unjust to restrict Plaintiff's claims to the two (2) year statute of limitations. > 9 WHEREFORE, the Plaintiff demands judgment as follows: a. Awarding compensatory damages to the Plaintiff; b. Awarding punitive dameges to the Plaintiff; c. Awarding counsel and expert fees to the Plaintiff; d. Granting injunctive relief; and, e. Forsuch other relief as the Court deems equitable and just. THIRD COUNT-INTENTIONAL TOR 15.) Plaintiff repeats and realleges the allegations contained in Counts One and ‘Two of the Complaint as if more fully and particularly set forth herein. 16.) From the onset of the marriage, the Defendant has perpetrated psychological, physical and verbal abuse upon the Plaintiff. The abuse was recurring over an extended period of time. A non-exhaustive summary of merely a fraction of the Defendant's abusive behaviors is included and is detailed in Counts One and Two of this Complaint. 17.) The Defendant committed intentional torts against thé Plaintiff by psychologically, physically and verbally abusing her on an extended basis, recurring and repeating throughout the parties’ marriage. As a proximate cause and/or direct result of the Defendant’s abuse, the Plaintiff has been severely and permanently injured and has been caused repeated and recurring psychological injury over an extended period of time. The Plaintiff has, in the past, and, will require counseling and other medical services to treat her condition, proximately caused by her tortured marriage to the Defendant. Given the gravity of the situation, it would be unjust to restrict Plaintiff's | claims to the two (2) year statute of limitations. WHEREFORE, the Plaintiff demands judgment as follows: > 9 a. Awarding compensatory damages to the Plaintiff; b. Awarding punitive damages to the Plaintiff; c. Awarding counsel and expert fees to the Plaintiff; 4. Granting injunctive relief; and, e. _ Forsuch other relief as the Court deems equitable and just. FOURTH COUNT-NEGLIGENT TORT 18.) Plaintiff repeats and realleges the allegations contained in Counts One, Two and Three of the Complaint as if more fully and particularly set forth herein, 19.) From the onset of the marriage, the Defendant has perpetrated psychological, physical and verbal abuse upon the Plaintiff. ‘The abuse was recurring over an extended period of time. A non-exhaustive summary of merely a fraction of the Defendant's abusive behaviors is included and is detailed in Counts One, ‘Two and Three ofthis Complaint. Defendant’s actions were intentional and/or negligent, and, are the proximate cause of injury sustained by the Plaintiff. 20.) The Defendant committed intentional torts against the Plaintiff by psychologically, physically and verbally abusing her on an extended basis, recurring and repeating throughout the parties’ marriage. Asa proximate cause and/or direct result of the Defendant's abuse, the Plaintiff has been severely and permanently injured and has been caused repeated and recurring psychological injury over an extended period of time. The Plaintiff has, in the past, and, will require counseling and other medical services to treat her condition, proximately caused by her tortured marriage to the Defendant. 21) Included in the barrage cf abuse committed upon the Plaintiff at the Defendant's proverbial hand, were consistent verbal berating and emotional torment. > o 22.) The Defendant’s constant degradation of the Plaintiff was intended by him to cause a complete loss of self-esteem and self-respect, all in an effort to dominate and control the Plaintiff. 23.) The Defendant steadfastly and steadily undermined the Plaintiff's self- onfidence to the point where she tolerated gross verbal, physical and emotional attacks and subjected herself to constant torment in an effort to obtain the Defendant’s approval and affection. 24.) The Defendant’s domination and abuse was so powerful that the Plaintiff was paralyzed as a victim living in this abusive situation. She was unable to take action to improve her situation until she mustered the strength to file the within Complaint. 25.) The Defendant's extreme conduct toward the Plaintiff caused and continues to cause the Plaintiff extreme mental anguish and torment. 26.) The Defendant’s actions were committed intentionally and/or with reckless disregard for their effect on tae Plaintiff and/or negligently, in such a way as to cause the Plaintiff severe damages. 27.) Asa direct result of the Defendant's abuse, the Plaintiff as been severely and permanently injured and has been caused repeated and recurring psychological injury. The Plaintiff has, in the past, and, will, in the future, required medical attention to treat the injuries caused by the Defendant. WHEREFORE, the Plaintiff demands judgment as follows: a. Awarding compensatory damages to the Plaintiff; b. Awarding punitive damages to the Plaintiff; c Awarding counsel and expert fees to the Plaintiff; d. Granting injunctive relief; and, oD 3 ©. For such other relief as the Court deems equitable and just. (FTH COUNT- [ONAL and/or NEI GENT INFLIe (ON O} EMOTIONAL DISTRESS 28.) Plaintiff repeats and realleges the allegations contained in Counts One, ‘Two, Three and Four of the Complaint as if more fully and particularly set forth herein. 29.) From the onset of the marriage, the Defendant has intentionally perpetrated psychological, physical and verbal abuse upon the Plaintiff which was intended to inflict emotional distress. The abuse was recurring over an extended period of time. A non-exhaustive summary of merely a fraction of the Defendant’s abusive behaviors is included and is detailed in Counts One, Two, Three and Four of this Complaint. Defendant's actions were intentional and/or negligent, and, are the proximate cause of injury sustained by the Plaintiff. 30.) The Defendant committed intentional torts against the Plaintiff by psychologically, physically and verbally abusing her on an extended basis, recurring and repeating throughout the parties’ marriage. As a proximate cause and/or direct result of the Defendant's abuse, the Plaintiffhas been severely and permanently injured and has been caused repeated and recurring psychological injury over an extended period of time. The Plaintiff has, in the past, and, will require counseling and other medical services to treat her condition, proximately caused by her tortured marriage to the Defendant. 31.) Included in the berage of abuse committed upon the Plaintiff at the Defendant's proverbial hand, were consistent verbal berating and emotional torment. 32.) The Defendant's constant degradation of the Plaintiff was intended by him to cause a complete loss of self-esteem and self-respect, all in an effort to dominate and 2 D control the Plaintiff. 33.) The Defendant steadfastly and steadily undermined the Plaintiff's self confidence to the point where she tolerated gross verbal, physical and emotional attacks. and subjected herself to constant torment in an effort to obtain the Defendant's approval and affection. 34.) The Defendant’s domination and abuse was so powerful that the Plaintiff was paralyzed as a victim living in th's abusive situation. She was unable to take action to improve her situation until she mustered the strength to file the within Complaint. 35.) The Defendant's extreme conduct toward the Plaintiff caused and continues to cause the Plaintiff extreme mental anguish and torment. 36.) The Defendant's actions were committed intentionally and/or with reckless disregard for their effect on the Plaintiff and/or negligently, in such a way as to cause the Plaintiff severe damages. 37.) Asa direct result of the Defendant’s abuse, the Plaintiff as been severely and permanently injured and has been caused repeated and recurring psychological injury. The Plaintiff has, in the past, and, will, in the future, required medical attention to treat the injuries caused by the Defendant. The Defendant's intentional conduct has caused the Plaintiff severe and irreversible emotional and psychological distress. WHEREFORE, the Plaintiff demands judgment as follows: a. Awarding compensatory damages to the Plaintiff; b. Awarding punitive damages to the Plaintiff; ©. Awarding counsel and expert fees to the Plaintiff; a. Granting injunctive relief; and, e. _ Forsuch other relief as the Court deems equitable and just. 2 > DESIGNATION OF TRIAL COUNSEL Pursuant to R. 4: 25-4, Christine N. Rossi, Esq,, is hereby designated as Trial Counsel of this matter. of Christine N. Rossi, LLL.C. for Plains, Tamara Seidle ‘STINE N. ROSSI, ESQ. Dated: vfiali2 eae > o CERTIFICATION OF VERIFICATION AND Ni TAMARA SEIDLE, of full

    You might also like