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Seidle Divorce Complaint
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100% found this document useful (1 vote)
36K views16 pagesSeidle Divorce Complaint
Seidle Divorce Complaint
Uploaded by
Asbury Park PressCopyright
© © All Rights Reserved
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Available Formats
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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
