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Home My WebLink About09-6029SCOTT T. WATSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. Oq - tv0gL9 Civil lean SUSAN K. 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. Court Administrator Cumberland County Courthouse 4th Floor, One Courthouse Square Carlisle, PA 17013 (717) 240-6200 SCOTT T. WATSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 0 y- ?j U 7 C SUSAN K. WATSON, CIVIL ACTION -LAW Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. Plaintiff is Scott T. Watson, an adult individual who resides at 1517 Carlisle Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. Defendant is Susan K. Watson, an adult individual who resides at 150 Regency Woods North, Carlisle, Cumberland County, Pennsylvania 17013. 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 on May 20, 2001, at Las Vegas, Nevada. 5. A prior action for divorce was filed in Potter County, Pennsylvania, which action has been discontinued. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and that plaintiff has the right to request that the court require that the parties participate in counseling. 8. Plaintiff requests the court to enter a decree of divorce 1 Timothy ,.J. O'Connell, Esquire TURNER AND O'CONNELL 4701 North Front Street Harrisburg, PA 17110 (717) 232-4551 Attorney for plaintiff Verification I verify that the statements made in the foregoing Complaint are true and correct. I understand false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904 relating to unworn falsification to authorities. Date: g? Scott T. Wastson SCOTT T. WATSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. SUSAN K. WATSON, CIVIL ACTION -LAW Defendant IN DIVORCE NOTICE TO THE DEFENDANT If you wish to deny any of the statements 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. Plaintiffs Affidavit Under Section 3301(d) of the Divorce Code 1. The parties to this action have continued to live separate and apart for a period of at least two years, since May 2005. 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.A. Section 4904 relating to unsworn falsification to authorities. Date: 0 ?? Scott T. Watson -; ?oY V I- _; 20", UO 9 ? P -3 pi i 1: i 'TY 4 338.50 PD A-r'N armor 17 q ?v SCOTT T. WATSON, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 09-6029 CIVIL TERM SUSAN K. WATSON, CIVIL ACTION Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Timothy J. O'Connell, Esquire, attorney for the plaintiff, Scott T. Watson, in the above captioned action for divorce, hereby certify that a conformed copy of the Complaint in Divorce and Plaintiffs Affidavit was served on the defendant, Susan K. Watson, by Certified Claim No. 7006 3450 0002 3535 1958, restricted delivery, return receipt requested, by depositing the same in the United States mail at Harrisburg, Pennsylvania, pursuant to Rule 1920.4 of the Amendments of the Pennsylvania Rules of Civil Procedure relating to the Divorce Code. As evidence by the green return receipt card attached hereto, the Complaint was received by said defendant on September 19, 2009. Timothy`J. O'Connell, Esquire Turner and O'Connell 4701 North Front Street Harrisburg, PA 17110 Sworn and subscribed to before Me this 29th day of October, 2009. otary Public ,v1V1MV1v W ZAL 1 H Ur PF.NNSn vANL4 NOTARIAL SEAL Stacey A. Fogle. Notary Public Susquehanna Townsnip, Dauphin County My Commission expim January 02, 2013 ¦ Complete items 1, 2, and 3. Also complete A. SOUR' - 0 A®ant Mom 4 if Restricted Delivery Is desired. • Print your owns and address on the reverse 0 Ader.Mw so that we can return the card to you. B. Received by (Printed Name) C. Date of D*vwy ¦ Attach this Lard to the back of the mailpiece, ermits f*t if s ce th . p pa or on e nt f rom D. Is delivery address dnrere ? 1 ? 1. Article ? to: ? r ff YES, 1 V t v c9 15l? ncq ??c s 0(44-) -? ?pp9 00 6 3 CQr i?st? Pry 1-701 Type 3 . . S Certitled Man 0 Evreas Mall Registered 0 Return Receipt for Mwdmdln 0 Insured man 0 C.O.D. F e) t i t n ? (E R d D x ra e very estr c e e 4. Yea 2. MIIdeNrmber 7006 3450 0002 3535 1958 (l4msw ha» service, A P8 Form 3811, February 2004 Domestic Rehm Receipt 102595-02-Wi FitEC).. ? C t po rn( 69y ,? 2004 NOV -4 F-12: 57 .ty GUS SCOTT T. WATSON, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 09-6029 CIVIL TERM SUSAN K. WATSON, CIVIL ACTION Defendant IN DIVORCE NOTICE OF INTENT TO REQUEST ENTRY OF 3301(d) DIVORCE DECREE TO: Susan K. Watson You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to the Section 3301(d) affidavit. Therefore, on or after October 29, 2009, the other party 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 counter-affidavit by the above date, the court can enter a final decree in divorce. A counter-affidavit which you may file with the prothonotary is attached to this notice. 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. The filing of the form counter-affidavit alone does not protect your economic claims. 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. Court Administrator Cumberland County Courthouse 40' Floor, One Courthouse Square Carlisle, PA 17013 (717) 240-6200 PLED-Or"FICE OF THE PR,THODNDTARY 2009 OV -4 PH 12: S7 Gr.lrX. ?'JIN Y SCOTT T. WATSON, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 09-6029 CIVIL TERM SUSAN K. WATSON, CIVIL ACTION Defendant IN DIVORCE COUNTER-AFFIDAVIT UNDER 43301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because [check (i), (ii) or both]: (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Date: Defendant NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. OF THIE PRO t'ONOTAPY 2009NOV -4 Phi 12:57 CUSS"?_. - u'?sNTY SCOTT T. WATSON, : IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 09-6029 CIVIL TERM SUSAN K. WATSON, : CIVIL ACTION Defendant : 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 3301d of the Divorce Code. 2. Date and manner of service of the complaint: served September 19, 2009, by certified mail--- See Affidavit of Service filed herewith 3. Date of execution of the affidavit of the required by Section 3301d of the Divorce Code: by plaintiff. August 30, 2009 Date of service of plaintiffs affidavit upon the respondent: served September 19, 2009 4. Related claims pending: none 5. Date and manner of service of the notice of intention to file praecipe to transmit record and counteraffidavit, a copy of which is attached: served October 9, 2009, by depositing same in the U.S. Mail, first class. Date: 10/29/09 Timothy onne , Esquire Turner and O'Connell 4701 North Front Street Harrisburg, PA 17110 (717) 232-4551 Attorney for plaintiff FILE- - i=lCt OF THE-' PR7-',,.NnTARY 2009 NOY -4 Pill, 12: 57 CUM! ih,??`,.;? rn, IN THE COURT OF COMMON PLEAS OF SCOTTT.WATSON CUMBERLAND COUNTY, PENNSYLVANIA V. SUSAN K. WATSON : NO 09-6029 CIVIL TERM DIVORCE DECREE 4- 1 640 AND NOW, 13 10 , it is ordered and decreed that SCOTT T. WATSON , plaintiff, and SUSAN K. WATSON , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE o , Attest: J. Proth otary ?f1 • vii ??? ,??'- ? ?? e-o*well .A