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Home My WebLink About01-1010TODD WALTERS, Plaintiff, V. HEH)I WALTERS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVAN/A NO. Ot -' CIVIL ACTION-LAW 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 in Divorce or anntflrnent may be entered against you by the Court. A judgement 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 Divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. 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 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. Dated: ,~//~/~ ?/ Court Administrator Cumberland County Courthouse 1 Courthouse Square-Fourth Floor Carlisle, PA 17013-3387 (717) 236-8515 By: Joseph J. Dixon, Esquire 126 State Street Harrisburg, PA 17101 (717)236-8515 TODD A. WALTERS, : Plaintiff, : _. V. ~ : HEIDI WALTERS, : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION ~ LAW IN DIVORCE COMPLAINT IN DIVORCE ANDNOW, this /~dayof /k'~f//,~//, 2001, comes the Plaintiff, ToddA. Walters, by and through her attorney, Joseph J. Dixon, Esquire, who respectfi_flly avers as follows: 1. Carlisle, Pennsylvania 17013. 2. Defendant, Heidi Walters, is an adult individual who resides at P.O. Box 933, Williamson, New York 14589. 3. Plaintiff has been bona fide resident of the Commonwealth of Peunsylvania for at least six (6) months immediately previous to the filing of this Complaint. Pennsylvania. 5. 6. 7. 8. Plaintiff, Todd A. Walters, is an adult individual who resides at 222 Birch Lane, The parties separated on June 9, 1999. There have been no prior actions of divorce or for annulment between the parties. There are (2) children born of this marriage. The Plaintiff and Defendant are both citizens of the United States of America. Plaintiff and Defendant were married on August 21, 1993, in Mechanicsburg, 9. Plaintiff has been advised of her right to seek marriage counseling in this divorce action, but waives the right to do so. 10. The Plaintiff and Defendant are not members of the Armed Services of the United States or any of its allies. 11. The Plaintiff avers that the ground on which this action is based is that the marriage is irretrievably broken. WHEREFORE, The Plaintiffprays this Honorable Court enter a Decree in Divorce in accordance with Section 3301 (c) of the Divorce Code. Respectfully submitted, By: Joseph J. Dixon, Esquire Attorney ID No. 28290 126 State Street Harrisburg, PA 17101 (717) 236-8515 Attorney for the Plaintiff VERIFICATION I verify COMPLAINT t~at the statements made are true and correct. in this DIVORCE I understand that statements herein are made subject to the penalty of 18 Pa. ~4904~, relating to unsworn falsification to authorities. false C.S. TODD WALTERS, Plaintiff, V. HEIDI WALTERS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1010 CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF CONSENT & WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A D1VORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE A Complaint in Divorce under section 3301(c) of the Divorce code was filed on February 20, 2001. The marriage of the Plaintiff and Defendant is irretrievably broken and Ninety (90) days have elapsed fi'om the date of the filing and service of the Complaint. I consent to the entry of the final Decree of Divorce without formal notice of the intention to request entry of the Divorce Decree. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses, if I do not claim them before a Divorce is granted. 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 tree and correct. I understand that false statements herein are subject to the penalties of 18 Pa C.S. Sec. 4904 relating to unsworn falsification to authorities. I~ATI~D DD WALTERS TODD WALTERS, Plaintiff, V. HEIDI WALTERS, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1010 CML ACTION-LAW IN DIVORCE AFFIDAVIT OF CONSENT & W&IVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A~DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE A Complaint in Divorce under section 3301(c) of the Divorce code was filed on February 20, 2001. The marriage of the Plaintiff and Defendant is irretrievably broken and Ninety (90) days have elapsed from the date of the filing and service of the Complaint. I consent to the entry of the final Decree of Divorce without formal notice of the intention to request entry of the Divorce Decree· I understand that I may lose my fights concerrfing alimony, division of property, lawyer's fees or expenses, if I do not claim them before a Divorce is granted. 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 tree and correct. I understand that false statements herein are subject to the penalties of 18 Pa C.S. Sec. 4904 relating to unsworn falsification to authorities. D TERS INTHE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA. TODD WALTERS ~ PLAINTIFF Versus HEIDI WALTERS, DEFENDANT DECREE IN DIVORCE AND NOW .............. .~. ,~......z..~ .... , ~;...~?"..~, it is ordered and decreed that TODD WALTERS plaintiff, and HEIDI WALTERS 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; TODD WALTERS, : Plaintiff, : V. : : HEIDI WALTERS, : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1010 CIVIL ACTION-LAW IN DIVORCE AFFIDAVIT OF SERVICE Personally appeared before me, a Notary Public, in and for the aforesaid Commonwealth and County, JOSEPH J. DIXON, ESQUIRE, who first being duly sworn according to law, does depose and say that he made service of the Complaint in Divorce upon the Defendant by placing a true and correct certified copy with the Notice to Defend and Claim Rights in the United States Mail at Harrisburg, Peansylvmfia. Certified Number: 7099 3400 0003 1157 5440 The same was received and acknowledged on behalf of the Defendant, HEIDI WALTERS, on this 284 day of of February 2001 as the addressee. Receipt for mailing is attached hereto. Sworn and subscribed before me th/s O.'t~- day of P,n~,r~6 , 2001. NOTARY PUBLIC My Commission Expires: ~ Oemplet:' It~n'~ 1, 2, and 3. Al~o complete item 4 if Restricted Delivery ia desired. I Pdnt.~ur name and address on the reverse so tha~we can return the card to you. · Attach this card to the back of the rnailplece, or on the front if space permits. ) . Article ~dreasecl to: i Ar~iC~r (Copy from s~l~ label) PS Form 38~, July 1999 Domestic Return Recapt C. $~gnatum ;~'~ i I Agent X TODD WALTERS, : Plaintiff, : V. : : HEIDI WALTERS : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-1010 CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the Court for the entry of the Divorce Decree: 1. Grounds for the Divorce is irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. The Defendant was served with the Divorce Complaint on February 28, 2001. 3. The Plaintiff executed an Affidavit of Consent pursuant to Section 3301 (c) of the Divorce Code on 5/27/04. The Affidavit of Consent was filed in the Prothonotary's Office of the Cumberland County Courthouse on 5/28/04. 4. The Defendant executed an Affidavit of Consent on 6/25/01. The Affidavit of Consent was filed in the Prothonotary's Office of the Cumberland County Courthouse on 7/2/01. D squire J 126 State Street Harrisburg, PA 17101 (717) 236-8515 Attorney for Plaintiff Dated: