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Home My WebLink About99-066284 3 i v CJ v? IN THE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY STATE OF ,???•:. PENNA. ROSS .1 1Ji?TT$, __ Plaintiff No, 99_6(,28 aviLJerm VERSUS ELIZABETH D. WA Defendant- DECREE IN DIVORCE AND NOW, IT IS ORDERED AND DECREED THAT ROSS M. IJATTS PLAINTIFF, AND ELIZABCT'I 9. F:ATTS DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLA I IAS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; BY THE COURTI ATTEST: J. PROTHONOTARY ' ?':n+?re:?? S?7.?? (i'?!'/? CC?f .r!/f/ f c,"yG?/. 1??7k'li.l. ROSS M. WAT'rs, Plaintiff Vs. ELIZABETH D. WATTS, Defendant IN THE COURT OF CONLMON PLEAS No. 99-6628 CIVILACTION- IN DIVORCE 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 ( x) 3301 C ( ) 3301 D of the Divorce Code. ( Check applicable code ) 2. Date and manner of service of the complaint Certified-Restricted delivery 11/17/99 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 3/3/00 ; by defendant 3/7/00 (B) (1) Date of execution of the plaintiff's affidavit required by Section 3301 (D) of the Divorce Code: (2) Date of filing and service of the plaintiffs affidavit upon the respondent 4. Related claims pending: ,rnvr. 5. (Complete either (a) or (b).) (A) Date and manner of service of the notice of intention to file praccipe to transmit record, a copy of which is attached: (B) Date plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: 3/16/00 Date defendant's Wavier of Notice in § 3301 (c) Divorce was fled with the Prothonotary: 3/16/00 Attorney or (x ) P] i tiff ( ) Defendant Nothm.- 9 cl? C- f, W•J. - -J uw 6 :' ?' "•i iu fl. o G Ci CJ Elizabeth A. Hoffman, Esquire 2201 North Second Street Harrisburg. PA 17110 ROSS M. WATTS, . IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO, gg -6 (,2 CIVIL TERM ELIZABETH D. WATTS, CIVIL ACTION - LAW Defendant 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 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 verification 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 at the Dauphin County Courthouse, Harrisburg, 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) 749-3166 ROSS M. WATTS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99 - G, G CIVIL TERM ELIZABETH D. WATTS, CIVIL ACTION - LAW Defendant IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Ross M. Watts, an adult individual whose current mailing address is 950 Sterling Court, Enola, Cumberland County, Pennsylvania 17025. 2. Defendant is Elizabeth D. Watts, an adult individual whose current mailing address is 904 Skyvievv Drive, York, York County, Pennsylvania 17402. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on November 29, 1997 in York, Pennsylvania. 5. No children were born of the marriage. 6. There has been no prior action 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. Defendant is not a member of the Armed Services. 9. Plaintiff avers that the ground on which the action is based is irretrievable breakdown of the marriage. WHEREFORE, Plaintiff requests the 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. ' .y spectfully submitted, ca?tre h A. Hoffman, EsquifEV orney for Plaintiff orney ID #71000 91 North Second Street rrisburg, PA 17110 7) 236-2956 I' e A' VERIFICATION I verify that the statements made in the attached Complaint in Divorce are true and correct to the best of my knowledge, information, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Date: It) ?/q i Ross M. Watts =RTIFICATE OF SERVICE ire, do hereby certify that a true and correct copy of the elivered by certified, restricted mail to: Elizabeth D. Watts 904 Skyview Drive York, PA 17402 Elizabeth A. Hoffman, Esquire Supreme Ct. ID #71000 Attorney for Plaintiff 2201 North Second Street Harrisburg, PA 17110 717-236-2956 ?? . -- ----------- FFT ti r O y ? O N i ?`n - m W ( i C f O Fl 9 n N 7 C < iz ?aoo? N N x '° N m ? N ti n n Y s r ROSS M. WATTS, Plaintiff vs. ELIZABETH D. WATTS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6628 CIVIL ACTION-LAW IN DIVORCE AFFWAVIT OF SERVICE I, Elizabeth A. Hoffman, Esquire, deposes and says: 1. That she is an adult individual residing in Cumberland County, Pennsylvania. 2. That on November 9, 1999 , she sent by certified- restricted mail, return receipt requesting from Harrisburg, Pennsylvania (No. 280 155 460) the Divorce Complaint in the above captioned case to: Elizabeth D. Watts 904 S:_yview Drive York, PA 17402 3. That on November 17, 1999, Elizabeth D. Watts signed the receipt (No. 280 155 460) which is attached to this ffidavit. 4E1i eth Hoffman, squire Attorney for Plaintiff 106 Walnut Street Harrisburg, PA 17101 (717) 236-2956 r , Z 280 155 460 us Postal Service Receipt for Certified Mail No Insurance Ceverago Provided. roar ge S CeNeed Fce I.t Special Delivery Fee Reshidad Delivery Fee N ) on Return RDCOpI Showing to r^ _ Nrtwrn d Dale coined n Ream Recept Sharug to when Da:e.E A6.7Caeh,Adl ' TpTAI-PdsTagdd Fees $ ('( ? ? PostmaM Or Wl0,. -. F . . Ge ._ I ra a a SENDER: - I also wish to receive the a a •Comploto items l and'or2 fardddieonal services, • Complete items 3.4a. and 4b. following services (for an u • Print your name and address on the rev erso of this form so l bat we Can return this extra fee): m 0 b card to piece. or on the tuxkitspice does net • Attach tm to the front at the mail 1.0 A essee's Address u Z perrn't. .Write'Remrn Rncoipf Rnpuesfed'on thonialpioco below me article numb., 2. Ei? Restricled Dellive N W N Y • The Return ROCnpl will show to whom rho aniclo was deliver ed and tire data Consul[poslmaslerfor lee. n redwood . 0 3. Article Atldressed to: 4a. Article N umber e E 4b. Service Type ? Registered enified u !/ 444??' ? Express Mail ? insured ?Return Receipt for Merchandise ?COD / / Z Dal/f eliver r C r e ? no) 5. Ilceive ey: 8. Addr seo's Address (Only it requesfdtl L ? C- S ti i and fee is paid) A 6. Signature: (Addressee or Agent) ~ o X 2 PS Form 3811, Decernber 1994 to2s95eao0229 Domestic Return Receipt r ROSS M. WATTS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99 - 6628 CIVIL TERM ELIZABETH D. WATTS, CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under section 3301(c) of the Divorce Code was filed on _ November 1 1999 in Cumberland County Pennsylvania. 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety days have elapsed from the date of filing the complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree- 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: 31 ? l Z T /& Ross M. Watts Ss # 5. E-Sl-32y-7 >- a) , IZ. LL1U _ `, _J _ I-- CI_t [L 0 0 `_ C7 U ..e yrfj. ROSS M. WATTS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99 - 6628 CIVIL TERM ELIZABETH D. WATTS, CIVIL ACTION - LAW Defendant IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lav: ;per's fees or expenses if I do not claim them before a divorce is granted. 3. 1 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 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: 5 2'or'0 -"' [/V(, Ross M. Watts U CC) c^ E: u.r VJ N CA p Q ? G V ROSS M. WATTS, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 99 - 6628 CIVIL TERM ELIZABETH D. WATTS, CIVIL ACTION - LAW Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on _ November 1. 1999 in Cumberland County Pennsylvania. 2. The marriage of plaintiff and defendant is irretrievably broken, and ninety days have elapsed from the date of filing the complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 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: 3J / /O O EIQLA-)a;;? Elizabeth D. Watts / SS" 0//-7 V-0-?S9"3 •r a) uj J% X LL J f.n C :fw I- Cl] p_ 0 (J O CC7 U ROSS M. WATTS, Plaintiff V. ELIZABETH D. WATTS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 99 - 6628 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 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. 3. 1 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 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. 7 Date: 7 0 C /LPL/L /cz; ' Elizabeth D. Watts r G) T r. J f?? CD O ? U Ci U IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Ross M. Watts Plaintiff , No. r) q- L /,.2 ? CIVIL TERM V. : CIVIL ACTION - LAW . IN DIVORCE Elizabeth D. Watts Defendant NOTICE OF ELECTION TO RETAKE FORMER NAME Notice is hereby given that the Plaintiff in the above captioned Divorce Action, hereby elects to retake and hereafter use her previous name of Ded i er This election is made pursuant to the provisions of 54 P.S. 704. t Cr Signaui' (married name) Signature (former name) Commonwealth of Pennsylvania : CouutvofCumberland : ss: 2003 On the day of 2003; before a Notary Public. Personally appeared LbmbeM Q• ?/6 known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and Notarial Seal. Naorio7 se,i tary Public Dawo M. Guae, . Nouuy Wbtic My of York York County [My Commission Ecpiics Apr. 15, 2006 Member, Pmnsylvanla Assocta0on of Nola nos 71 r i a T 1 0