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HomeMy WebLinkAbout99-04768 ¦ I- U? Oo o- :x IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. JANE M. MOTT No ...... 476.8......... Civil 19 99 PLAINTIFF Versu's STEVEN W. MOTT, SR. + DEFENDANT DECREE IN Dl VORCE AND NOW,.. ?. ........ ... , 19.4.1, it is ordered and decreed that . . . . . . . . . . . . . . . . . . . JANE. M. MOTT plaintiff, .. .; and .................................. . . MOTT STEVEN , SR,., 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; NONE ............................ ........... By T Co i? A ? Attest: J. r '(a Prothonotary +r+ t?..+..w:• •w• :r.• •a:• •;r.• •:v,• a:• •:?• tc• :a •:?: •;es <e: ;e• •:e:• a:• :c• •:r.• •:e:• :e: :a te> :e:...4:• •:r.• 0 i i i Ti i i i i i O i i JANE M. MOTT, Plaintiff V. STEVEN W. MOTT, SR., Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 99-4768 CIVIL TERM PRAECIPE TO TRANSMIT RECORD 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(d) of the Divorce Code. 2. Date and manner of service of the complaint: Complaint served by U.S. mail, certified, restricted delivery, return receipt requested on Steven W. Mott, Sr. at 221 East Grant Avenue, Eau Claire, Wisconsin 54701-6408 on September 13, 1999, as evidenced by the Certificate of Service filed on September 27, 1999. 3. Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: October 5, 1999. 4. Date of filing and service of the plaintiff's affidavit upon the respondent: Plaintiff's affidavit was filed on October 7, 1999. Plaintiff's affidavit was served upon the respondent on October 7, 1999 by U.S. mail, postage prepaid at 221 East Grant Avenue, Eau Claire, Wisconsin 54701-6408, as evidenced by the Certificate of Service filed on October 7, 1999. . 5. Related claims pending: None 6. Date and manner of service of the notice of intention to file Praecipe to Transmit Record, a copy of which is attached: The Notice was served on November 8, 1999, by that date placing the same in the U.S. Mail, postage prepaid, sent to the Defendant at 221 East Grant Avenue, Eau Claire, Wisconsin 54701-6408. Certified Legal Intern ROBERT E. RAINS THOMAS M. PLACE Supervising Attorney DONALD M. MARRITZ Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, Pennsylvania 17013 (717) 243-2968 Fax: (717) 243-3639 Date lj-1 -99 C (- , '?;! L N ll : Vii:': ?. :? L ._i 1 _ ?„ ? C 1 ' ; 4 i:_ ? C? ? ? . cn `=i C? u? U +` xi JANE M. MOTT, Plaintiff V. STEVEN W. MOTT, SR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 99-4768 CIVIL TERM NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: STEVEN W. MOTT, SR. You have been sued in an action for divorce. You have failed to answer the complaint or file a counteraffidavit to the plaintiff's affidavit. Therefore, on or after December 2, 1999, the plaintiff can request the court to enter a final decree in divorce. If you do not file with the prothonotary of the court an answer with your signature notarized or verified or a counteraffidavit by the above date, the court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTERAFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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, Pennsylvania 17013 (717) 249-3166 } 01 la- 4_ .. f?l ::, :L. _ 1 ? t::r.. ?. ri :n _? 1? ? 51i o ? ' (T i.j JANE M. MOTT, Plaintiff V. STEVEN W. MOTT, SR Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE NO. 99- 1176e CIVIL TERM The plaintiff, Jane M. Mott, by her attorneys, the Family Law Clinic, sets forth the following cause of action: I. Plaintiff is Jane M. Mott, who currently resides at Apartment 512, 13 South Hanover Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. Defendant is Steven W. Mott, Sr., who currently resides at 221 East Grant Avenue, Eau Claire, Eau Claire County, Wisconsin 54701-6408. 3. Plaintiff has been a bona fide resident of Cumberland County and the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The plaintiff and defendant were married on October 27, 1989 at Mechanicsburg, Cumberland County, Pennsylvania. 5. Plaintiff and defendant have lived separate and apart since April 1995. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that plaintiff or defendant may have the right to request that the court require the parties to participate in counseling. WHEREFORE, plaintiff requests the court to enter a decree of divorce dissolving the marriage. Will' .Patch IV C?ied Legal Intern THOMAS M. PLACE ROBERT E. RAINS KATHERINE C. PEARSON Supervising Attorney DONALD MARRITZ Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa. C.S. §4904, the undersigned verifies that the statements made in the foregoing Complaint are true and correct, to the best of my knowledge, information and belief. Dated: July, 1999 a, ?1 lane M. Mott ? - ...? : ; ?.. - -? ?: , :? - JANE M. MOTT, Plaintiff V. STEVEN W. MOTT, SR Defendant To the Prothonotary: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE NO. 99- -/71n/ CIVIL TERM Kindly allow Jane M. Mott, Plaintiff, to proceed in forma pauperis. I, William J. Patch, IV., of the Family Law Clinic, Certified Legal Intern for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. Date: 71,2- h, IV Intern ROBERT E. RAINS THOMAS M. PLACE Supervising Attorney DONALD MARRITZ Staff Attorney THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 iS> I:' f ;' ?1 ?,. i L? ?. CL •. i._ (Jl ?_l .. t_l ( ) JANE M. MOTT Plaintiff V. STEVEN W. MOTT,SR, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DIVORCE NO. 99- CIVIL TERM I am the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting or defending the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: Jane M. Mott Address: 3 S. High Street, Carlisle, PA 17013 Social Security No.: 205-52-1902 (b) Employment If you are presently employed, state Employer: N/A Address: N/A Salary or wages per month: N/A Type of work: N/A If you are presently unemployed, state Date of last employment: April 1997 Salary or wages per month: $4.35 per hour Type of work: Housekeeping (c) Other income within the past twelve months Business or profession: N/A Other self-employment: N/A Interest: N/A Dividends: N/A Pension and annuities: N/A Social security benefits: SSI $474.66month Business or profession: N/A Other self-employment: N/A Interest: N/A Dividends: N/A Pension and annuities: N/A Social security benefits: SSI $474.66month Support payments: N/A Disability payments: N/A Unemployment compensation and supplemental benefits: N/A Workman's compensation: N/A Public Assistance: $31 per month Other: $170.00 Food Stamps (d) Other contributions to household support N/A (e) Property owned Cash: Checking account: N/A Savings account: N/A Certificates of deposit: N/A Real estate (including home): N/A Motor vehicle: N/A Cost, Amount Owed $ Stocks; bonds: N/A Other: N/A (f) Debts and obligations Mortgage: N/A Rent: $371 a month Loans: N/A Other: Diapers - $20.00 Medical care - $20.00 Food - $150.00 a month Cable Bill - $219.90 (g) Persons dependent upon you for support Children, if any: Name: James D. Oswalt Age: 2 years Other persons: N/A Name: N/A Relationship: N/A 4. 1 understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 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. // Date ?:? __ L_ _ ? -L.?i ? ,? r ? i._ r? f.L u ?`'? _7 C ` ?. , (J JANE M. MOTT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE STEVEN W. MOTT, SR., Defendant : NO. 99-4768 CIVIL TERM CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the Divorce Complaint on Steven W. Mott, Sr. at 221 East Grant Avenue, Eau Claire, Eau Claire County, Wisconsin 54701-6408 by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid; and by first class U.S. mail, postage prepaid. Service was complete upon receipt by Steven W. Mott, Sr. on the 131„ day of Srortmig(L , 1999 as evidenced by his signature on the attached green card. P 492 349 610 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. V. /?c44- $• Streal8 Nt Pro, ?--r- Porn OfBp, SINe, 8 ZIP Coda ?c -. vr= "° $ SS Special Delivery Fm --- Restac ed Delivery Fee Return Receim Showinn m Certlfied Fee u son B. Perry Certified Legal Intern W FAMILY LAW CLINIC 45 North Pitt Street Carlisle, Pennsylvania 17013 (717) 243-2968 c• o SENDER: `w I] Campele Items 1 enN ComplBle llama ar 21or atldnionel . b. eerv¢es ? Pant your name 3, 4 anda, adtl and ms aa an Ins reverse of lbis lorm W haI wa can !alum this m caN to you. ? Anadl Ihie /orm to the b pennil. Irani of 'he mailgaca, or on the back if space tleee ?Wme•gefum Raelpf gequesfed'on lho medpiece below the eNde number. ? O The RBIUm RecaiPt will show to whom the snide was dNivared o tloliveratl, and the dale 1-`4 -2 () I - 6 vas' S?'ue? W. Mel y. Z gen c 6. Signature (Addressee or A i N PS Form 3811, December 1994 I also wish to receive follow. aerVlCeg ((018(1 extra fee): 1- O Addressee'sgddreea 2• 0 Restricted Delivery 3 5?Y e?/D ? Express Mall O Insured ? Return Receipt for MerchentllUe ?DDD to2595.ea.g.o223 JANE M. MOTT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE STEVEN W. MOTT, SR., Defendant : NO. 99-4768 CIVIL TERM CERTIFICATE OF SERVICE I hereby certify that I have served a true and correct copy of the Divorce Complaint on Steven W. Mott, Sr. at 221 East Grant Avenue, Eau Claire, Eau Claire County, Wisconsin 54701-6408 by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid; and by first class U.S. mail, postage prepaid. Service was complete upon receipt by Steven W. Mott, Sr. on the 3TN day of SLorcmisck , 1999 as evidenced by his signature on the attached green card. u soJ d n LB.Perry Certified Legal Intern P 492 349 610 US Postal Service Receipt for Certified Mail No Insurance Coverage Provided. Do not use for International Mail /See reversal aem 0 S- %-- J V. /'Tofa S: . Slraetd NUmW ? ?2 yS?l>i.??fTl.! Post Olfim, $1100, 8 LP Code 1$ . S Certified Fee Special Delivery Fee ??- Restricted Delivery Fee Return Retain 5nowg to Wham & Dale Delivered Reom Rxepl Nlomly b hTan. Dab. A Ad Twee' els TOTAL es $ Pas a ale Q N 0 m m M 0 LL FAMILY LAW CLINIC 45 North Pitt Street Carlisle, Pennsylvania 17013 (717) 243-2968 Fax: (717) 243-3639 ,r, N --) <r VJ N .; • F .: ? `IfL U on U JANE M. MOTT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE STEVEN W. MOTT, SR., Defendant : NO. 99-4768 CIVIL TERM CERTIFICATE OF SERVICE 1, hereby certify that I have served a true and correct copy of the Praecipe to Transmit Record and Vital Statistics form on Steven W. Mott, Sr. at 221 East Grant Avenue, Eau Claire, Eau Claire County, Wisconsin 54701-6408 by this date placing the same in the U.S. mail, first class, postage prepaid, addressed as above. Date 2 0>' 9 .-- 6 Judson B. Perry Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, Pennsylvania 17013 (717) 243-2968 Fax: (717) 243-3639 ? ?? ' >, , _; ?,:: ?: ? r. ? il??_. CD _ tq __ i, ? J _, I?. ?? ?`-' J cn ?' ? ?, JANE M. MOTT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE STEVEN W. MOTT, SR., Defendant : NO. 99-4768 CIVIL TERM NOTICE TO DEFENDANT If you wish to deny any of the allegations set forth in this affidavit, you must file a counteraffidavit within twenty days after this affidavit has been served on you or the statements will be admitted. PLAINTIFF'S AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action are separated and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 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. Date rlb .? ' / / \ CvjZ..t? ne M. Mott RECEIVED OCT 0 6 1999 r_r, v? r C) ?' 1 U cn W U JANE M. MOTT, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE STEVEN W. MOTT, SR., Defendant : NO. 99-4768 CIVIL TERM CERTIFICATE OF SERVICE 1, Judson B. Perry, Certified Legal Intern of the Family Law Clinic, hereby certify that I have served a true and correct copy of the Plaintiff's Affidavit on Steven W. Mott, Sr. at 221 East Grant Avenue; Eau Claire, Eau Claire County, Wisconsin 54701-6408 by this date placing the same in the U.S. mail, first class, postage prepaid, addressed as above. Date Oer. 7r 1991 Judson B. Perry Certified Legal Intern FAMILY LAW CLINIC 45 North Pitt Street Carlisle, Pennsylvania 17013 (717) 243-2968 Fax: (717) 243-3639 LLI ` 't L. L ll U tr ;?