Loading...
HomeMy WebLinkAbout99-06838 A! V 1 1 I ?00CsC ^t JC OCyjGOCYFyJP yrr.gf ri.?^? si uti ': a'o <: ?4 O r GG"sti rtys C ?v?i i xfh .. . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. STEVEN W. OTTO, N O 99-6838 CIVIL TERM Plaintiff I? VERSUS I? I AMY A. OTTO, If Defendant DECREE IN DIVORCE AND NOVV,_LL 1 I 7c00+ IT IS ORDERED AND DECREED THAT Steven W. Otto PLAINTIFF, AND Amy A. Otto 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; The parties' Separation and Property Settlement Agreement dated December 15, 1999, is incorporated herein, but not merged. BY THE COURT: / ATTEST: /?//Q/?q? i J• P THONOTARY YYY?'... . ' L4*,J?l%J:?:N?' :'.'J?. :"J v':KYJCT?v?'f?OOC _? I ? i i± ., ? .r c N? c4f? 'ti??K? ? ?y/? G GLC? ? I /C?u ?.,, ? ? l tLZY ?, i ?- j STEVEN W.OTTO, Plaintiff V. AMY A. OTTO, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-6838 CIVILTERM IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTI-IONOTARY: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under §3301(c) 3301(d)(1) efthe ee Cede- (Strike out inapplicable section). 2. Date and manner of service of the Complaint: Service was made on November 15, 1999 by certified mail, restricted delivery, return receipt requested to the Defendant, Amy A. Otto. 3. Complete either paragraph (a) or (b). (a) Date of execution of the Affidavit of Consent required by §3301 (c) of the Divorce Code: by Plaintiff. February 16, 2000 by Defendant: February 15, 2000 (b) (1) Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the plaintiffs affidavit upon the respondent: 4. Related claims pending: none 5. Complete either (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: (b) Date of Plaintiffs Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: February 16, 2000 Date Defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: February 15, 2000 Kristen Goddard • onsen, Esquire GRIFFIE & ASSOCIATES Attorney for Plaintiff -, STEVEN W. OTTO, : IN T HE COURTOF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA .'s. CIVIL ACTION - LAW AMY A.OTTO, NO. 9 -k!? .35- CIVIL Dclcndant IN DIVORCE NWICE TO DEFEND AND CLAIM RIGHTS You bavc been sued in Court. If you %visit 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, lbe case will proceed without you and a decree of divorce or annulment may be entered against you for any 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 Of(ice of the Prothonotary at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 Two Liberty Avenuc Carlisle, Pennsylvania 17013 (717)249-3166 STEVEN W. OTTO, : INI TI [E COURT OF COMMON PLEAS Of Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION • LAW AMY A.OTTO. : NO. `N 6e Vii" CIVIL Defendant : IN DIVORCE COMPLAINT IN DIVORCE COUNT I NO FAul:r-CONSEWE 1. Plaintiff is Steven W. Otto, an adult individual currently residing at 3670 Spring Road, Carlisle, Cumberland County, Pennsylvania. He has lived there for approximately thirteen (13) years. 2. Defendant is Amy A. Otto, an adult individual currently residing at 767 East 1-ligh Street, Apartment B, Carlisle, Cumberland County, Pennsylvania. She has lived there for approximately two (2) months. 3. Plaintiff is a bonafidc resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on April 26, 1937, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to pa ticipatc in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. S. Plaintiff and Defendant are citizens ol'the United States of America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the beliel'thal the Defendant will, ninety (90) days from the date of service of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce pursuant to Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, GRIFFIE & ASSOCIATES Kristen Goddard D risen, Esquire Attorney for Plaintiff 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (300) 347-5552 vratf_ug 1 verify that the statements made in the foregoing Complaint arc true and correct. 1 understand that false statements herein made are subject to the penalties of 18 PA.C.S. Section 4904 relating to unsworn falsificalion to authorities. DATE: 1////195 -a-cl?G?CiC ?t-, STEVEN W. OTTO, Plaintiff =,? ?- "' ' r_ ` . ?? ??,? ? r. ?; ? i, _ ?_,; ?, : . ,. L , ? ? ' ? ? G. ?. 1: ' C.' i STEVEN W. OTTO, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW AMY A.OTTO, NO. 99-6838 CIVIL Defendant IN DIVORCE AFFIDAVIT OFSERVICG AND NOW, this /7 , day of ?(u1.(,1999• comes Kristen Goddard Donsen, Esquire, attorney for Plaintiff, Steven W. Otto, and states that the Defendant, Amy A. Otto, was served with a true and attested copy of the complaint in Divorce by certified mail, restricted delivery on November 15, 1999. Respectfully submitted, GRIFFIE & ASSOCIATES Kristen Goddard )Dronsen, Esquire Attorney for Plaintiff 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Sworn and subscribed to this / :`'di day of ?lNotary Pu, lic Notarial Seal Robin.l. Goshorn, Norory Public Carlisle f3oro, Cumbedand county FApr t7. 2003 My Commission expi,es Z-0f,9 872 948 Receipt for Certified Mail No Inew:mc,; Cov.nuga prc nJen Do not utic far In mina pnncrl Mail 1 (S., HI-Vursul ti.L LI... r? m o' ,- $ o I O :osQn,pt ciJ?rtc .} m t .i o ^? LL a m SENDER: I also wish to receive the v .compete Items l wdlorz[or additional serdcea. following services (for an m Complete item 3.4a, and 41b. extra fee): a Print your name and address on the revene olthia farm w that we can velum INS 8 odressee's Address re Card tothiui Z eAtlach s oan to the hoot of In, malpieea, or on lire back it apace done not 1.0 A 2. Ga`RosrIcted DelivrY 4% pomv. article -S Consult pos postmast master r for for ftea. slum : m The Return Roca pt Wil Show to whom the w d e eatdel vexed and the data o te 6 s. delivered. c 4a. Article Number i 3. ANCIe Addressed to: -? E ; 1-t , 04-1o n m 4b. Service Type Q?CeMfled E rn Y n 11 i. ? Registered u n "1 E• 11-1i?h r ? Express Mall Q Insured a. QY?!S P/ (7Return ReeeiptlorMe ndse 11 COD J- 17613 ' 7, Data of situ 'o ° G+ rs 4 r 5. Received By: (Print Neme) 8. Addre ae' Address (Only!/requested and lee is paid) 1 ?/) g 6. Sign Atldr 0 Rs orm 11, a mbar lsga tazsn.v.aot s Domestic Return Receipt i.? 7 f.- '?.:' ___ ,> _ i?_r. .- n _- ?? STEVEN W. OTTO, IN TI IL' COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW AMY A. OTI.0, NO. 99-6838 CIVIL TERM Defendant IN DIVORCE AFFIDAvrr OF CONSENT A. Complaint in Divorce under §3301 (c) of the Divorce Code was filed on November 12, 1999, and served upon the Defendant on November 15, 1999. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of 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 VERITY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 13 Pa.C.S. §4904 RELATING TO UNS WORN FALSIFICATION TO AUTHORITIES. DATE: l ?/ L /0() « J'V STEVEN W. OTTO, Plaintiff STEVEN W.OTTO, Plaintiff V. AMY A. OTTO, Defendant IN 'nii. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVILACTION - LAW NO. 99-6838 CIVILTERM IN DIVORCE WAIVER ON NOTIC E OF INTENTIO N T O REQUEST THE ENTRY OF A DIVORCE DEC REE UNDER §3301(c ) OF THE DIVO RCE CODE I consent to the entry of a final decree in divorce without notice. 2. I understand that 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses if 1 do not claim them before a divorce is granted. 3. 1 understand that I will not be divorce 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 files with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. I UNDERSTAND THAT FALSE STATEMENTS HEREIN i ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO Ili UNSWORN FALSIFICATION TO AUTHORITIES. DATE: ;211i /D 0 -?CGG?L?t aL/ 0-?A? STEVEN W. OTTO, Plaintiff .., STEVEN 1V. OTTO, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY. PENNSYLVANIA v. CIVIL ACTION - LAW AMY A. OTTO, NO. 99 - 6838 CIVIL TER-NI Defendant : IN DIVORCE AFFIDAVIT OF CONSGN'r A. Complaint in Divorce under §3301 (c) of the Di%,orce Code was filed on November 12, 1999, and served upon the Defendant on November 15, 1999- 2. The marriage of Plaintiff and Dcicndant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. l consent to the entry of a final Decree of Divorce after service of notice of intention to request entry of the decree. I VERITY THAT THE STATEMENTS MADE IN THE FOREGOING 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: ?' ' 15 - CL C?? - AA A. GtTO,?Defendant STEVEN W. OTTO, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY,1'ENNSYLVANIA V. :CIVIL ACTION - LAW AMY A. OTTO, : NO. 99 - 6838 CIVIL TERM Defendant : IN DIVORCE WAIVER ON NOTICE OF INTENTION TO REQUEST THE ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1 consent to the entry of a final decree in 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 1 will not be divorce 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 files with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT. 1 UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 Pa.C.S. §4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE: 2--\5-0u AA9 A.OTT-O,Dcfendant _. - :? `;? -?.?