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Home My WebLink About03-4448Kathleen Ann WATKINS, Plaintiff VS. James Clyde WATKINS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- 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 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: Office of the Prothonotary Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 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) 245-8787 Kathleen Ann WATKINS, Plaintiff VS. James Clyde WATKINS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- DIVORCE COMPLAINT IN DIVORCE Plaintiff, by and through her attorney J. Michael Sheldon, Esquire, respectfully represents: 1. Plaintiff is Kathleen Ann Watkins, with a present mailing address of 1001 Rupley Road, Apt. #204, Camp Hill, Cumberland County, Commonwealth of Pennsylvania, 17011. 2. Defendant is James Clyde Watkins, with a present mailing address of 1112 Columbus Avenue, Apt. #6, Lemoyne, Cumberland County, Commonwealth of Pennsylvania, 17043.. 3. Plaintiff and Defendant are sui juris, with both parties having been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on April 15, 1985 at Mansfield, Pennsylvania.. 5. The parties have two natural children of the marriage: Christina Ann Watkins, age 11, DOB 01-27-92, $SAN 210-72-2593; and, Nathaniel Jacob Wtkins, age 5, DOB 02-03-98, SSAN 166-78-4723. 6. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its Amendments. 7. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 8. Plaintiffs Social Security Number is 175-62-3377. 9. Defendant's Social Security Number is 163-38-5380. 10. Plaintiff has been advised of the availability of counseling and that Plaintiff or Defendant may have the right to request the parties to participate in counseling. 11. The cause of action and section of the Domestic Relations Code under which Plaintiff and Defendant are proceeding is Section 3301(c). The marriage of the parties is irretrievably broken. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff and Defendant intend to file an Affidavit consenting to a divorce. WHEREFORE, upon the expiration of ninety (90) days, Plaintiff and Defendant respectfully request the Court to enter a Decree in Divorce pursuant to section 3301(c) of the Divorce Code. dissolving the marriage between Plaintiff and Defendant. DATE: September 11, 2003 Respectfully submitted, J. Michael Sheldon, Esquire Pa. I.D. # 83098 6059 Allentown Boulevard Harrisburg, PA 17112 Tel: (717) 657-3464 Fax: (717) 671-1258 Attorney for Plaintiff Kathleen Ann WATKINS, Plaintiff James Clyde WATKINS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION -- DIVORCE VERIFICATION STATEMENT I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. Ann. § 4904, relating to unsworn falsification to authorities. Date: September 11, 2003 Ann Watkins Plaintiff Kathleen Ann WATKINS, Plaintiff VS. James Clyde WATKINS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION -- DIVORCE CERTIFICATE OF SERVICE I, J. Michael Sheldon, Esquire, hereby certify that on this date I served a true and correct copy of the foregoing COMPLAINT via United States mail, first-class postage, and by United States Mail, certified number 7002 2410 0007 1402 1692, restricted delivery, to the following: Date: September 11, 2003 James Clyde Watkins 1112 Columbus Avenue, Apt. #6 Lemoyne, PA 17043 J. Michael Sheldon, Esquire Pa. ID #83098 6059 Allentown Boulevard Harrisburg, PA 17112 Tel: (717) 761-2121 Fax: (717) 761-4031 Attorney for Plaintiff Kathleen Ann WATKINS, Plaintiff VS. James Clyde WATKINS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-4448 CIVIL TERM CML ACTION -- DIVORCE · Complete items 1, 2, and 3. Aisc complete ~ ~gn~ure / //// item 4 if Restricted Delivery is desired, v I/~ , ~ ~ F3 Agent · Print your name and address on the reveme ~. /~/4/~'~ ~. (..~4~ FI Addressee SO that we can return the card to you. B~r/nt~/Na~ ~C. D~ate o~ Delivery · Attacll this card to the back cf the mailpieca, '~~~~,~ ~L~"~Vg~' Jf YES, enter deli¥~y addrea~ below: I~ No 1. Addressed to: 2. ,4~ti~le Number (Tranefe~ from sera/ce PS Form 3811, August 2001 4. Restricted Delivery? (E.Wm Fee) ~Yes 7003 1010 0000 0782 0403 Domestic Return Receipt 102595~2-M-1035 {210 Kathleen Ann WATKINS, Plaintiff VS. James Clyde WATKINS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-4448 CIVIL TERM CIVIL ACTION -- DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301f¢} OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. 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. 3. 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 the statements made in this affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification~'-8"~,x,uthorities. a~n Watkins, Pla DATE: December 18, 2003 K ~ntiff Kathleen.Ann WATKINS, Plaintiff VS. James Clyde WATKINS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-4448 CIVIL TERM CIVIL ACTION -- DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301 (c) of the Divorce Code was filed on September 10, 2003. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service af the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 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 unswom falsification to authorities. DATE: DecemDer 18, 2003 Kat~leen Ann Watkins, Plaintiff Kathleen Ann WATKINS, Plaintiff VS. James Clyde WATKINS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 03-4448 CIVIL TERM CIVIL ACTION -- DIVORCE PRAEClPE TO TRANSMIT RECORD To the Prothonotary: Transmit the attached information, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: §3301 (c) of the Pennsylvania Divorce Code. 2. Date and manner of service of the complaint: September 11,2003 by U.S. Postal Service, certified mail, article # 7003 1010 0000 0782 0403, restricted delivery. 3. Date of execution of Affidavit of Consent required by §3301 (c) of the 5. Praecipe. 6. this Praecipe. Divorce Code: by Plaintiff: by Defendant: December 18, 2003 December 18, 2003 Plaintiff makes no claims of equitable distribution. Plaintiff's signed Waiver of Notice and Affidavit of Consent accompany this Defendant's signed Waiver of Notice and Affidavit of Consent accompany Date: December 18, 2003 J. Michael Sheldon, Esquire Pa. I.D. # 83098 6059 Allentown Boulevard Harrisburg, PA 17112 Tel: (717) 657-3464 Fax: /717) 761-1258 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~~ PENNA. VERSUS DECREE IN AND NOW, DIVORCE , "~i~, IT IS ORDERED AND PLAINTIFF', 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; PROTHONOTARY