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HomeMy WebLinkAbout08-1869(Shelley Ann Watson IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. Craig Charles Watson 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 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, Cumberland County Courthouse, 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. Legal Aid Bureau 500 E. Lexington Street, Baltimore, MD 21202 410-951-7737 t Shelley Ann Watson IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. Craig Charles Watson CIVIL ACTION LAW Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301 (c) OF THE DIVORCE CODE 1. Plaintiff is Shelley Ann Watson, who currently resides at 318 S. Enola Drive, Cumberland County, Enola, Pennsylvania, 17025, since 2006. 2. Defendant is Craig Charles Watson, who currently resides at the Maryland Department of Public Safety & Correctional Services work release center Threshold, located at 1702 St. Paul Street, Baltimore, Maryland, 21202. 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. The plaintiff and defendant were married June 19, 2004, in Enola, PA, Cumberland County. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. 8. Plaintiff requests the court enter a decree of divorce. 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.C.S.A. §4904, relating to unsworn falsification to authorities. Date Sh ley Ann W t n, Plaintiff, Pr N w C"3 r- ra O -?r tC% +1, ?-C ?kk? ? Shelley Ann Watson IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. DS Craig Charles Watson CIVIL ACTION LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, Shelley A. Watson, hereby certify that I have served a true and correct copy of the Plaintiff's Complaint, on Craig Charles Watson, Maryland Department of Public Safety & Correctional Services work release center Threshold, located at 1702 St. Paul Street, Baltimore, Maryland, 21202, by depositing a copy of same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid, and a copy by regular mail, to the same address, this day of n , 2008, in accordance with Rule 1930.4(c) of the . it Pennsylvania Rules of Court. DATE: LI jq jQ? S elley Ann tson, Plaintiff, Pro Se ¦ mplete items 1, 2, and 3. Also complete i em 4 if Restricted Delivery is desired. ¦ rint your name and address on the reverse $o that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to: e?D ve Sh lc? LS t 13I?(?? m ?f , mJ 21202-- A. si t? 0 Agent X 9&,? ? Addressee RrvydZVV? ved by ( aC. Date f Delivery ej? / 1-1113- D. Is delivery address different fromitem 1?4vu Yes If YES, enter delivery address below: 0 No 3. Service Type 0 Certified Mail 0 Express Mail 0 Registered 0 Return Receipt for Merchandise 0 Insured Mail 0 C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 2. Article Number 7007 268D 0001 0723 (riamfer Iron servke raa*j 2546 PS Form 3811, February 2oo4 Domestic Return Receipt C? "`? C ca ? ?? ?"1 4€,3 'i- T -? : n, _ ? ? _ . . , :? (., , ?. f t -. .a E.1.,} .. _.? V C`) ?7 ._._ -°C Shelley Ann Watson Plaintiff V. Craig Charles Watson Defendant To the Court Administrator: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0J' I9bq j,jVj I CIVIL ACTION LAW IN DIVORCE AFFIDAVIT OF MILITARY SERVICE The Plaintiff, Shelley Ann Watson, Pro se, sets forth the following: To the best of my knowledge, the defendant, Craig Charles Watson, has no United States Military Service. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Date: G $ I" kq W S elley Ann tson, Plaintiff, Pro Se =T `?',?=-? ? ,;;? ? `? ? t?T ?. F ` 1 t ? A . r ??^ ? ' V C ` p y +r • ? Shelley Ann Watson Plaintiff V. Craig Charles Watson Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 0 - C lV CIVIL ACTION LAW IN DIVORCE To the Court Administrator: AFFIDAVIT OF MINOR CHILDREN The Plaintiff, Shelley Ann Watson, Pro se, sets forth the following: There are no minor children from this marriage. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Date: 411 ?)O? luutt"?X/ S Iley Ann a on, Plaintiff, Pro Se N- n r ? C ? T1 Fr, -77 !Tt