HomeMy WebLinkAbout00-05679
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BONNIE K. WATT
:: IN THE COURT OF COMMON PLEAS OF
:: CUMBERLAND COUNTY, PENNSYLVANIA
:: NO. 00- 5IP 7f CIVIL TERM
v.
JAMESW. WATT
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. 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 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 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 at the
CUMBERLAND COUNTY COURTHOUSE. CARLISLE. PENNSYLVANIA. 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'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, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
717-249-3166
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C__ 8nces H. Del Duca
10 West High St.
Carlisle, P A 17013
Dated: % - / (, - tJ7)
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BONNIE K. WATT
v.
:: IN THE COURT OF COMMON PLEAS OF
:: CUMBERLAND COUNTY, PENNSYLVANIA
:: NO. 00- 6'(,'7'/ CIVIL TERM
JAMES W. WATT
IN DIVORCE
COMPLAINT UNDER SECTION 3301 (c) AND 3301 (a) (6)
OF THE DIVORCE CODE
COUNT I - DIVORCE
1. Plaintiff is Bonnie K. Watt, who resides at 35 Slate Lane, Newville,
Cumberland County, Pennsylvania, 17241.
2. Defendant is James W. Watt, who resides at 35 Slate Lane, Newville,
Cumberland County, Pennsylvania, 17241.
3. Plaintiff and defendant have been bona fIde residents in the Commonwealth of
Pennsylvania for at least six (6) months immediately previous to the. fIling of this
complaint.
4. The plaintiff and defendant were married September 7, 1985, in Shippensburg,
PA.
5. There have been no prior actions of divorce or for annulment between the
parties.
6. Plaintiff avers that the grounds on which the action is based is that the
marriage is irretrievably broken and that defendant has offered such indignities to
plaintiff who is the innocent and injured spouse as to render her condition intolerable and
life burdensome.
EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
COUNT II
7. Paragraphs 1 through 6 are incorporated by reference herein as though set out
in full.
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8. Plaintiff and defendant are the joint owners as tenants by the entireties of real
estate located at 35 Slate Lane, Newville, Cumberland County, Pennsylvania, along with
various items of personal property, furniture and household furnishings acquired during
the marriage which are subject to equitable distribution by this Court.
ALIMONY PENDENTE LITE
COUNT III
9. Paragraphs 7 and 8 are incorporated by reference herein as though set out in
full.
1 O. Plaintiff does not have suffIcient to support herself.
WHEREFORE, Plaintiff requests the Court to enter a decree:
A. Dissolving the marriage between plaintiff and defendant;
B. Equitably distributing all property owned by the parties hereto; and
C. Directing defendant to pay alimony pendente lite.
Dated: j'-;c'-tm
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L-Ffances H. Del Duca, Esq.
Attorney for Plaintiff
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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 10 Pa.C.S.
Sec. 4904 relating to unsworn falsifIcation to authorities.
Dated: 7-1(" - 00
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BONNIE K. WATT .. IN THE COURT OF COMMON PLEAS OF
..
.. COMMON PLEAS OF CUMBERLAND COUNTY
..
v. .. NO. 00-5679
..
..
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JAMES W. WATT .. IN DIVORCE
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RE: NOTICE OF PROPOSED TERMINATION OF COURT CASE
To The Court:
The plaintiff, Bonnie K. Watt, intends to proceed with the divorce action fIled
August 16, 2000. She requests that the case not be terminated on October 28, 2003 at
9:30 a.m.
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onnie K. Watt
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Frances H. Del Duca, Esq.
Attorney for Plaintiff
10 West High St.
Carlisle, P A 17013
October 20, 2003
cc: Robert O'Brien, Esq.
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