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HomeMy WebLinkAbout02-5908MICHAEL STEW~uRT MARTIN, : Plaintiff : LAURA LEE WATTS, Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE 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 within twenty (20) days. 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 import 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, One Courthouse Square, 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 GPJkNTED, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-6200 MICHAEL STEWART MARTIN, Plaintiff LAURA LEE WATTS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE COMP~AIN~T IN DIVORCE UI~DER SECTION 3301(¢) OF THE DIVORCE COD~ currently resides at 1115 N, Harrisburg, 17102. Plaintiff is MICHAEL STEWART MARTIN, an adult individual who Dauphin County, Pennsylvania 2. Defendant is LAURA L~ WATTS, an adult individual who~ currently resides at 12 Sussex Road, Camp Will, Cumberland County, Pennsylvania 17011. 3. Both Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 21, 2001, in Cumberland County, Pennsylvania. 5. The parties separated on October 5, 2002. 6. There have been no prior actions for divorce or annulment between the parties. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 8. Neither the Plaintiff or Defendant is a member of the Armed Services of the United States or any of its Allies. 9. The Plaintiff avers that the ground on which the action is based is that the marriage is irretrievably broken. 10. Plaintiff avers that there are no children of the parties under the age of eighteen (18). WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in Divorce dissolving the marriage between the parties pursuant to Section 3301(c) of the Divorce Code of 1980, as amended. DATE: December/~ ,2002 Respectfully submitted ~r~n~is M. Socha, Esquire 2201 North Second Street Harrisburg, PA 17110 717/233-4141 DOMESTIC/M~TIN.DIV.CMP Attorney for Plaintiff I, MICHAEL S. MARTIN, verify that the statements made in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. MICHAEL S. MARTIN MICHAEL STEW~kRT MARTIN, Plaintiff LAURA LEE WATTS, Defendant IN THE COURT OF COMMON PLEAS CUMBERIJkND COUNTY, PENNSYLVA/~IA NO. CIVIL ACTION - LAW IN DIVORCE ~ERTIFICATE OF SERVIC~ I, Francis M. Socha, Esquire, hereby certify that a true and correct copy of the foregoing Complaint was sent by United States mail, postage prepaid, certified mail, return receipt requested, to the following: Laura Lee Watts 12 Sussex Road Camp Hill, PA 17011 Date: domestic.martin-div.com MICHAEL S. MARTIN, Plaintiff VS. LAURA L. WATTS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : No. 02 - 5908 CIVIL TERM CIVIL ACTION - AT LAW - IN DIVORCE PREVIOUSLY ASSIGNED: N/A ACCEPTANCE OF SERVICE I, Laura L. Watts, also known as Laura L. Martin, Defendant in the above- captioned matter, accept service of the COMPLAINT IN DIVORCE pursuant to Pennsylvania Rule of Civil Procedure, Rule 1930.4(d). k~/i~ur~ L. ~Vatts MICHAEL STEWART MARTIN, Plaintiff LAURA LEE WATTS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-5908 Civil Term : : CWIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE I, Laura A. Gargiulo, Esquire, being duly sworn according to law, deposes and says that she is the attorney for Plainfiffin the above-captioned action; that on or about December 12, 2002 a true and correct copy of the Complaint in Divorce was mailed to the Defendant, at the Defendant's last known address; that on December 14, 2002, the Defendant acknowledged receipt of the Complaint pursuant to Pennsylvania Rule of Civil Procedure 1930.4(d) as evidenced by the Acceptance of Service form attached hereto, with Defendant's signature affixed thereon; and that the facts set forth in the within Affidavit are true and correct to the best of her information and belief. argiul~ll~squ(~e Sworn to and subscribed before me this ['7 day of Notary Public ,2004. MICHAEL STEWART MARTIN, Plaintiff LAURA LEE WATTS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5908 Civil Term CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT_ 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 12, 2002 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Michael Stewart Martin, Plaintiff MICHAEL STEWART MARTIN, Plaintiff LAURA LEE WATTS, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5908 Civil Term CIVIL ACTION- LAW IN DIVORCE DIVORCE CONSENT WITH WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SS3301 OF THE DIVORCE CODE 1. A Complaint in Divorce under ss3301(c) of the Divorce Code was filed December 12, 2003 2. The marriage of Plaintiff 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 airier service of notice of intention to request entry of the decree. 4. ! consent to the entry of a final decree of divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 6. I understand that I will not be divorced until a divorce decree is entered by the Court and tht 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. ss4904 relating to unsworn falsification to authorities. Michael Stewart Martin 164-68-1946 dom~,~ ........... Social Security Number MICHAEL STEWART MARTIN, Plaintiff LAURA LEE WATTS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-5908 Civil Term : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF CONSENT_ domestic-mattin--aoc 1. A Complaint in Divorce under Section 3301(c) ,of the Divorce Code was filed on December 12, 2002 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of the filing and service of the Complaint. 3. I consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. ~Z~ur/i Lee '¢~Oa't~, ~r Defendant t MICHAEL STEWART MARTIN, Plaintiff LAURA LEE WATTS, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLANT) COUNTY, PENNSYLVANIA NO. 02-5908 Civil Term : CIVIL ACTION- LAW : IN DIVORCE DIVORCE CONSENT WITH WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SS3301 OF THE DIVORCE CODE 1. A Complaint in Divorce under ss3301(c) of the Divorce Code was filed December 12, 2003 2. The marriage of Plaintiff and Defendant is irretriew, bly 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 of intention to request entry of the decree. 4. I consent to the entry ora final decree of divorce without notice. 5. 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. 6. I understand that I will not be divorced until a divorce decree is entered by the Court and tht 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>~s4904 relating to unsworn falsification to authorities. /"/ Social Security Number MICHAEL STEWART MARTIN, Plaintiff LAURA LEE WATTS, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02-5908 Civil Term : : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORn TO THE PROTHONOTARY: Transmit the record, together with the following information, to the court for entry of a divorce decree: 2. 3. 4. 5. Ground for divorce: irretrievable breakdown under ~ 3301(c) of the Divorce Code. Date and manner of service of the Complaint: r~ecember 12, 2002, Acceptance of Service pursuant to Rule 1930.4(d). Date of execution of the affidavit of consent required by § 3301 (c) of the Divorce Code: June 15, 2004 Plaintiff June 15, 2004 Defendant Related claims pending: None Date Plaintiff' s Waiver of Notice was filed with tile prothonotary: June 181 2004 Date Defendant' s Waiver of Notice was filed with the prothonotary: June 18, 2004 Respectfully submitted, THOMAS, THOMAS AND HAFER, LLP r-fan,is M. Socha,d~squi~] Laura A. Gargiulo, Esquire 305 North Front Street PO Box 999 Harrisburg, PA 17108-0999 (717) 441-7057 IN THE COURT Of COMMON OF CUMBERLANDCOUNTY STATE OF ~~ Plaintiff VERSUS LAURA T,~ WATS, Defendant NO. PLEAS PENNA. 02-5908 CML A(~ION - LAW IN DIV(~CE DECREE IN DIVORCE AND NOW, ~_ .~h~__ 2~ DECREED THAT Michael Stewart Martin AND Laura Lee Watts ARE DIVORCED FROM THE BONDS OF MATRIMONY. , ~--c-'~J/ , IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, 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