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Home My WebLink About01-2830 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHAD E. WATSON : CIVIL ACTION - LAW Plaintiff, : ; vs. : NO. fl- ,3~.Y~~ ; LYNN RENEE WATSON : 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 arc 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 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 grounds 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 Cumberland County Courthouse, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFOP, E 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. CK) TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN (}ET LEGAL HELP. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHAD E. WATSON : CIVIL ACTION - LAW Plaintiff, : ; vs. : NO. o ; LYNN RENEE WATSON : Defendant. : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d] OF THE DIVORCE CODE AND NOW, comes the above named Plaimiff, Chad E. Watson, by and through his attorneys, Weigle, Perkins & Associates, and David P. Perkins, Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully se~ forth: 1. Plaintiff, Chad E. Watson, is an adult individual presently residing at 7790 McClays Mill Road, Newburg, Franklin County, Pennsylvania 17240, since August 2000. 2. Defendant, Lynn Renee Watson, is an adult individual presently residing at 321 Farmington Drive, Shippensborg, Cumberland County, Pennsylvania 17257, since December 2000. 3. The Plaintiffand Defendant are nationals and citizens of the United States of America, and both have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of the Complaint in Divorce. 4. The Plaintiff and Defendant were married on May 10, 1996, in Cumberland County, Pennsylvania. 5. There have been no prior actions ofdivoree or for annulment between the parties. 6. Plaintiff has been advised that counseling is available and the Plaintiff may have the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. 8. The parties have lived separate and apart since August 2000. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHAD E. WATSON : CIVIL ACTION - LAW Plaintiff, : : vs. : NO. 01-2830 : LYNN RENEE WATSON : Defendant. : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA : : SS COUNTY OF CUMBERLAND : Rhonda R. Wolford, being duly sworn according to law, deposes and says that on May 17, 2001, true and attested copies of Notice to Defend and Complaint in Divorce were served upon the Defendant, Lynn R. Watson. Manner of service: by mailing the same postage paid, certified mail, addressee only, and return receipt requested, at Shippensburg, Pennsylvania, addressed as follows: Lynn Renee Watson 321 Farmington Drive Shippensburg, PA ~17257 ~ Rhonda R. Wolford //" Sworn to ~ subscribed before me this Al day of May, 2001. o~y Public ' ..........,- ~¢,..'..- -.,'.: ,, ~ .:c~ ~.~ .: .~ . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHAD E. WATSON : CIVIL ACTION - LAW Plaintiff, : : vs. : NO. 01-2830 : LYNN RENEE WATSON : Defendant. : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under § 3301(c) of the Divorce Code was filed on May 10, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of 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. 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. CHAD E. WATSON, Plaintiff WEIGLE. PERKINS & ASSOCIATES -- ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG. PA 17257-1397 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHAD E. WATSON : CIVIL ACTION - LAW Plaintiff, : : vs. : NO. 01-2830 : LYNN RENEE WATSON : Defendant. : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER $ 3301fc) AND $ 330Hd] OF THE DIVORCE CODE I. I consent to the entry of a final decree ofdivoree without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifl do not claim them before a divorce is granted. 3. 1 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. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to unswom falsification to authorities. CHAD E. WATSON, Plaintiff WEIGLE, PERKINS & ASSOCIATES - ATTORNEYS AT LAW -- 126 EAST KING STREET -- SHIPPENSBURG, PA 17257-1397 CHAD E. WATSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 2001-2830 CIVIL : LYNN RENEE WATSON, : Defendant : IN DIVORCE PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of Defendant Lynn Renee Watson in the above matter. MARTSONtDEARDORFF WILLIAMS & OTTO / By '~'"~' ~-~ Thomas J. Willia~l~, Esquire Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: January,a3~, 2002 Attorneys fbr Defendant CERTIFICATE OF SERVICE I, Tricia D. Eekenroad. an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Joseph P. Ruane, Esquire WEIGLE, PERKINS & ASSOCIATES 126 East King Street Shippensburg, PA 17257 MARTSON DEARDORFF WILLIAMS & OTTO Carlisle, PA 17013 (717) 243-3341 Dated: January ~, 2002 CHAD E. WATSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 2001-2830 CIVIL LYNN RENEE WATSON, : Defendant : IN DIVORCE DEFENDANT'S ANSWER AND COUNTER-CLAIM TO PLAINTIFF'S COMPLAINT 1-9. Admitted. CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 10. Plaintiff and Defendant are the joint owners as tenants by the entireties of certain real estate which is subject to equitable distribution by this Court. 11. Plaintiffand Defendant are the owners of various items of personal property, furniture and household furnishings acquired during their marriage which are subject to equitable distribution by this Court. 12. Plaintiff and Defendant are the owners of various motor vehicles and bank accounts acquired during their marriage which are subject to equitable distribution by this Court. COUNSEL FEES AND EXPENSES UNDER SECTION 3702 OF TIlE DIVORCE CODE 13. Plaintiff requests your Honorable Court to allow her reasonable counsel fees and expenses pursuant to Section 3702 of the Pennsylvania Divorce Code. WHEREFORE, Plaintiffrequests the Court to enter a Decree: A. Dissolving the marriage between Plaintiff and Defendant; B. Equitably distributing all property owned by the parties hereto; C. Ordering payment of counsel fees and expenses as the Court deems just and reasonable; and D. For such further relief as the Court may determine equitable and just. MARTSON DEARDORFF WILLIAMS & OTTO Thomas J. Willh(ms, Esquire Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: Januarys~, 2002 Attorneys for Defendant yERIFICATION Thomas J. Williams, of the firm of MARTSON DEARDORFF WILLIAMS & OTTO, attorneys for Defendant in the within action, certifies that the statements made in the foregoing Answer and Counterelaim are true and correct to the best of his knowledge, information and belief. He understands that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Thomas J. Wi~ams, Esquire CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson DeardorffWilliams & Otto, hereby certify that a copy of the foregoing Answer and Counterclaim was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Joseph P. Ruane, Esquire WEIGLE, PERKINS & ASSOCIATES 126 East King Street Shippensburg, PA 17257 MARTSON DEARDORFF WILLIAMS & OTTO Carlisle, PA 17013 (717) 243-3341 Dated: January ,2002 CHAD E. WATSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 2001-2830 CIVIL LYNN RENEE WATSON, : Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301 (e) &the Divorce Code was filed on May 10, 2001. I acknowledge receiving a true and correct copy of the Divorce Complaint, said copy being served upon me by Certified Mail, Restricted Delivery, on May 17, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce. 4. 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. WAIYER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND § 3301(d) OF THE DIVORCE CODE 1. 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, lawyers 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 and waiver 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: - Lyn~R~'ncc Watson, Defendant I'IAR ~.1 ~ CHAD E. WATSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2001-2830 CIVIL : LYNN RENEE WATSON, : Defendant : IN DIVORCE PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please withdraw all claims filed in the above matter on behalf of Defendant, except divorce. MARTSON DEARDORFF WILLIAMS & OTTO By '~'t~ ,r~ Thomas J. Willigols, Esquire Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Date: May 2, 2002 Attorneys for Defendant CERTIFICATE OF SERVICE I, Tricia D. Eckemoad, an authorized agent for Martson DeardorffWilliams & Otto, hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Joseph P. Ruane, Esquire WEIGLE, PERKINS & ASSOCIATES 126 East King Street Shippensburg, PA 17257 MARTSON DEARDORFF WILLIAMS & OTTO Carlisle, PA 17013 (717) 243-3341 Dated: May 2, 2002 CHAD E. WATSON, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : NO. 2001-2830CIVIL : LYNN RENEE WATSON, : 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 3301(c) the Divorce Code. 2. Date and manner of service of the complaint: See Affidavit of Service, as filed. 3. Date of execution of the Plaintiff's affidavit of consent required by Section 3301 of the Divorce Code; August 23, 2001; by the Defendant; March 7, 2002. 4. Related claims pending: None. 5. Date Plaintiff's Waiver of Notice in § 3301 (c) Divorce was filed with the Prothonotary: September 19, 2001. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: April 3, 2002. MARTSON DEARDORFF WILLIAMS & OTTO Thomas J. Willi~n~, Esquire Ten East High Carlisle, PA 17013-3093 (717) 243-3341 Date: May 17, 2002 Attorneys for Defendant ~ IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY 8I STATE OF PENNA, 18 ............................................................................ N o....2oo.~.-.za~o 19 · 8 ...... LYNN.. I~N~[. ~ATSON ..................................... DECREE IN DIVORCE AND NOW, ....................... "~ .......i, is oraerea and decreed that ............... .c.~. p..~....~.~.~.s.0.~ ..................... plaintiff, and T.ym~ i~St<~.E ~ATSON ..... defendant, are divorced from the bonds of matrimony. 18 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; ,:ii! ........................... ......... Prothonotary