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Home My WebLink About03-1666IN THE 'COURT OF COMMON PLEAS OF CUMBERLAND coUNTy, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff : : No. V. : /~L~6 Civil Term .An'x~. ~. U'-~-'I~,5 : IN DIVORCE ' 'Defendant : NOTICE TO DEFEND AND CLAIM RIGHTS YOUH~I VEBEENSUED IN COURT. If you wish to defend against the claims set fo~h in the following pages, you must take prompt action. You are warned that if you fail to do so, the ease 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 important to you, including custody or visitation of your children~ When the ground for 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, 1 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 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,.)¢4973166 Ee han demandado a usted a la Cone. Si usted quiere defenderse en contra estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra suya. Se has avisado que si usted no se defienda, ia cone tomara medidas y puede entrar una orden contra usted sin previo aviso o notificaeion y por cualquier queja o alivio que es pedido en la peticion do demanda. USTED PUEDE PERI)ER DINERO O PROPIENDADES O OTROs DERECHOS IMPORTANTES PARA USTED. . LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumber/and County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 24%3166 -AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend the scheduled Conference or Hearing. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 I Plaintiff Defendant · IN THE COURT OF COMMON PLEAS OF ' CUMBERLAND COUNTY, PENNSYLVANIA · NO. 2003- / (e f~ · CIVIL ACTION - LAW · IN DIVORCE COMPLAINT UNDER §3301(c) or (d) OF THE DIVORCE CODE Plaintiff is C,-c~te Cumberland County, Pennsylvania. who currently resides at I~'~,,:, sb,.' z3 iD~ iDIIo 2. Defendant is ~w,,~ ~. {,',,3.~,-'~ '/' who currently resides at .3 3. Plaintiff has been a bona.fide resident of the Commonwealth of Pennsylvania for at least the six months prior to the filing of this Complaint· 4. Plaintiff and Defendant were married on q-/ ~t .j 5. The marriage is irretrievably broken, and the parties separated on o There have been no prior actions of divorce or annulment between the parities. Plaintiff, to the best of his/her knowledge and belief, avers that defendant is not in the military service of the United States of America, but is in fact living at the address given in Paragraph 2 above. 8. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties participate in counseling. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce. Date Plai~ti~, Pro Se _ ~rt~ 3 ~ , verify that the statements made in this Complaint are true and correct to the best of my knowledge, information, and belief. I understand that false statements made herein are subject to the penalties for unsworn falsification to authorities as provided in 18 Pa. C.S. {}4904. ])ate Plaintiff/ Assisted by: MIDPENN LEGAL SERVICES PRO SE DIVORCE CLINIC 8 Irvine Row Carlisle, Pennsylvania 17013 (717) 243-9400 vii. Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · No. 2oo, - · CIVIL ACTION - LAW · IN DIVORCE PETITION TO PROCEED IN FORMA PAUPERIS The Petitioner, I~.c;,-,, ~,, ~ L,~-iX % ' 1'"~_ , is the Plaintiff in this action. On her behalf, I, Joan Caref', ati0me~7 }'or Mid~nn Legal Services, do hereby certify that the Petitioner is indigent according to the poverty guidelines of MidPenn Legal Services. MidPenn Legal Services is assisting the Petitioner in filing a divorce case pro se. The Petitioner's Financial Affidavit showing inability to pay the costs of litigation is attached hereto· Petitioner requests leave to proceed without payment of fees or costs. Respectfull~~ Yn'e atl°sT&d Pro Se Divorce Clinic 8 Irvine Row Carlisle, PA 17013 pi?tintiff VS. · IN THE COURT OF COlvIMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA : · NO. 0~" CIVIL TERM : : AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCF. ED IN FORMA PAUPERIS 1. I am the P~c,'t,x33r: ~2~ in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: [.2,., Address: ,~.,% \\ ~ ~ t.-~ t~, (b) Social Security Number: If you are presently employed, state Employer: ecl Address: Salary or wages per month: Type of work: If you are presently unemployed, state Date of last employment: Salary or wages per month: Type of work: (c) Other income within the past twelve months Business or profession: Other self-employment: Interest: t~ ~-~ r~ Dividends: ~'~ ~''q ~ Pension and annuities: (d) Social Security benefits: I~ ':; cO E Support payments: ~ c~.~-o ~ Disability payments: r,o ~ },J ~ Unemployment compensation and Ixo ~ [,O supplemental benefits: Workman's compensation: t~oc~q C Public Assistance: I'o '0 ~ [ Other: B) ~-~ ~xt ~ Other contributions to household support (Wife) (Husband) Name: ~ t~x~.~ ~,-, i,O,,,'"~ If your (husband) (wife) is employed, state Employer: ~o,--~ It] c.-k ~X3.e ~ ~ Salary or wages per month: ~, 5~(2~ Type of work: ~oq [ ~-.,~e.[ $ e ~. c Contributions from children: ~ ~ '~"~(-~ (e) Property owned fi) Cash: Checking Account: ,~ Savings Account: Certificates of Deposit: Real Estate (including home): Motor vehicle: Make ~t~ ~a~;-o:.~Year Cost t\1~)~% Amount owed Stocks; bonds: ~e~ ~ Other: Debts and obligations Mortgage:~ ~ ~o~ Rent: tO ~-,o~ Monthly Expenses: ~ (g) Persons dependent upon you for support (Wife) (Husband) Name: Io~6~- Children, if any: t0~ ,'~ Name: Age: 4. I understand that ! have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. 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. Gany E. Watts, II Plaintiff VS. Amy R. Watts Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 03-1666 CIVIL TERM IN DIVORCE ACCEPTANCE AND ACKNOWI~EDGMENT OF SERVICE I, Amy R. Watts, Defendant in the above captioned proceeding accept and acknowledge service of the Divorce Complaint under §3301 (c) of the Divorce Code filed in this action by the Plaintiff, Garry E. Watts, II. I also waive any defects in any form or manner of service, ,~jjLh~, C~ / ' ' ! Affiy R~/ads,'Defendant Garry E. Watts, II Plaintiff VS. Amy R. Watts Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 03-1666 CIVIL TEP~4 IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divome Code was filed on April 10, 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. 1 consent to the entry of a final decree ofdivome after service of notice of intention to request entry of divorce. 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. Section 4904 relating to unswom falsification to authorities. Date: 7'~0' ~ Signature: j) Garry~E. Watts, II, Plaintiff / Garry E. Watts, II Pla'mtiff VS. Amy R. Watts Defendant IN THE COURT OF COMMON PLEAS OF CZr/~ERLAND COUNTY PENNSYLVANIA No. 03-1666 CIVIL TERM IN DWORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301 (c) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 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. 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 filed with the Prothonotary. I verify that statements made in this affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswom falsification to authorities. Date: ~['2~1'3 Signature: ~?~4 ;~ Garry 1/. Watts, II, Plaintiff Garry E. Watts, II Plaintiff VS. Amy R. Watts IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 03-1666 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on April 10, 2003. 2. The marriage ofplaintiffand 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 ora final decree of divorce after service of notice of intention to request entry of divorce. 1 verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the~nalties of 18~Y~.S. Sect~ 4904 relating t° unsw°m falsificati°n t° auth°rit~fi/' / /~//,~ ~--~/ Date: 9/ff/[~_~ Signature: (~//[.Z, ~ '/ / A~ny R/~/atts, De-fendant Garry E. Watts, II Plaintiff VS. Amy R. Watts Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 03-1666 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(c) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 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. I understand that I will not be divorced until a divome decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that 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 unswom falsification to authorities.; Date: /~3 Signature~kmy(y~ R. ¢,~d~/ Garry E. Watts, II Plaintiff VS. Amy R. Watts Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 03-1666 CIVIL TERM IN DWORCE PRAECIPE TO TRANSMIT RECORD To The Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and Manner of service of the Complaint: Defendant signed Acceptance and Acknowledgment of Service form on April 17, 2003. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, August 29, 2003; by Defendant, September 8, 2003. (b)(1) Date of execution of the PlaintiWs Affidavit required by Section 3301(d) of the Divorce Code: N/A (2) Date of filing and service of Plaintiff's Affidavit upon Defendant: N/A 4. Related claims pending: There are no outstanding claims. 5. Complete either paragraph (a) or (b). (a) Date and manner of service of the notice of intention to file Praecipe to Transmit Record, a copy of which is attached: N/A. (b) Date PlaintifFs Waiver of Notice in Section 330 l(c) Divorce was filed with the Prothonotary: September 16, 2003. (c) Date Defendant's Waiver of Notice in Section 3301(c) Divome was filed with the Prothonotary: September 16, 2003. Plaintiff's Social Security Number: 232-23-9311 Defendant's Social Security Number: 293-74-7817 amy Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 IN THE COURT Of COMMON PLEAS GARRY E. OF CUMBERLAND COUNTY STATE OF PENNA. WATTS, II PLAINTIFF N O. 03-1666 VERSUS AMY R. WATTS DEFENDANT DECREE IN DIVORCE DECREED THAT __, IT IS ORDERED AND GARRY E. WATTS, II , PLAINTIFF, AND AMY R. WATTS ,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; ALL CLAIMS HAVE BEEN RESOLVED. ~PROTHONOTARY