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HomeMy WebLinkAbout05-5021 DERRICKA. WATSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL VANIA v CIVIL ACTION - LAW NO. dOO') - 50;),1 IN DIVORCE MICHELLE R. WATSON, Defendant 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 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, 1 Courthouse Square, Carlisle, P A 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 MA Y 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMA nON ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMA nON ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 WEIGLE & ASSOCIATES, Pc. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 . DERRICKA. WATSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL VANIA v CIVIL ACTION - LAW NO. 05.,50:21 Cd....t1 (;,,-.. MICHELLE R. WATSON, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE AND NOW, comes the above named Plaintiff, Derrick A. Watson, by and through his attorneys, Weigle & Associates, P.C., and Richard L. Webber, Jr., Esquire, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff, Derrick A. Watson, is an adult individual presently residing at 145 Enola Road, Newburg, Cumberland County, Pennsylvania 17240, since January 17,2004. 2. Defendant, Michelle R. Watson, is an adult individual presently residing at 90 Hershey Road, Shippensburg, Cumberland County, Pennsylvania 17257, since September 22, 2005. 3. The Plaintiff and 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 July 10, 2004 in Orrstown, Franklin County, Pennsylvania. 5. There have been no prior actions of divorce 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 September 15,2005, 9. The Plaintiff requests the court to enter a decree of divorce. WEIGLE & ASSOCIATES. Pc. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 . ~ WHEREFORE, the Plaintiff prays your Honorable Court to enter a Decree in Divorce from the bonds of matrimony and for such other and further relief to which Plaintiff shall be entitled. WEIGLE & ASSOCIATES, P.C. By: //L ,~ . d ~/ ).( ~~/~ Richard L. Webber, Jr., Esquire Attorney for Plaintiff Attorney ID #49634 126 East King Street Shippensburg, P A 17257 Telephone 717-532-7388 ~ WEIGLE & ASSOCIATES. Pc. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG. PA 17257-1397 . VERIFICATION I verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa C.S. ~ 4904, relating to unsworn falsification to authorities. Dated: 0'1/23/ D5 I ( JJ~ tL /!~ Derrick A. Watson, Plaintiff WEIGLE & ASSOCIATES, Pc. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 ~ 0 i:tL 1l ..... ~ -. -I.) :1 0 -t::.. ~ -0 9 '"" C) . ".,,-" Q ~,.: 9 r--> <:::'"J ~'_-::J C:..."'1 o -.-, --/ -,. -'i--n r , r.::::: ~-~~? ;~3 >~(....., 6lf1 =;! :.0 -< if f"'q ~'r,J f',) W ~ >c. ~.- .c- .r=- DERRICKA. WATSON, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL VANIA CIVIL ACTION - LAW NO. 05-5021 MICHELLER. WATSON, Defendant IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYL VANIA SS COUNTY OF CUMBERLAND Patricia A. Frey, being duly sworn according to law, deposes and says that on September 27,2005 a true and attested copy of Complaint in Divorce with Notice to Defend and Claim Rights was served upon the Defendant, Michelle 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: Michelle R. Watson 90 Hershey Road Shippensburg, P A 17257 The return receipt signed by the Defendant is evidence of delivery to her and is attached hereto as "Exhibit A." patt~~ A ~ Sworn to and subscribed before me this 3,d day of November, 2005. j)Jz~ A. TCNYj-Q Notary Public NOfARlAJ. SEAL PA.llIClA L TOME Notary Public SlilPPENSSURGSOROUGH.CJJMBERtANOCOUNTY My CommISsion Expires Jun 7. 2008 WEIGLE & ASSOCIATES. P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 II DERRICKA. WATSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL VANIA v CIVIL ACTION - LAW NO. 05-5021 MICHELLE R. WATSON, Defendant IN DIVORCE PROOF OF SERVICE m II'"' m II'"' II'"' o .::t II'"' m o o o U.S. Postal Service" CERTIFIED MAIL" RECEIPT (DomestIc Mall Only, No Insurance Coverage Provided) I feO ~ 3Q 1:75 5.50 Tolal Postage & Foes $ 8'. 15 ,- fostmark ~e.e ~ 3 o Ul r- o .::t , CJ ent 0 _ ~ Sbio.i"APiQi,'Eh~\t~m_B.:.._W_@_~~..m__m____....m__m__.. ;:~;~-~-Q....!J_g!2kV_..J~_9.d.m._.._nnmn..mn . ~hl t!'l\SlIol PA ''1d.57 - 10 _ _ C8Il ....., the C8I'd 10 you. . ~ lhIo C8I'd 10 11M! tMIck 01 the n'I8lIpIeoe, or.on the front W IpIIC8 permits. 1. Article Addressed to: O. 10 dIIIvooy _ _ fnlm Item 1 If YES, enter delivery address below: r<\ len e lie 12.- Wccbon CfD Ke(~hey Ro ad S\-"{l~el\~blol(5 Pt1 1'1 ';l.S? 3. Service Type Xi Certified Mall D Express Mall P- Registered ):I Return Receipt for Merchandise D Insured Mall 'D C.O.D. 4. Restricted DelIvely? (Ednl Fee) Yes 7004 0750 0003 9409 9393 2. Artlcle Number ~1tom_1IIbeI} PS Form 3811, February 2004 ~ -." ReceIpt 102515-02-M.1540 ~ \\. b.1 "f\" WEIGLE & ASSOCIATES, P.C. - ATTORNEVS AT LAW - 126 EAST KING STREET - $HIPPENSBURG, PA 17257-1397 C) r-> C) C:-:l c- ~-'" "1'1 <->~ 0 ---1 -,- (,.~') ril -r; --' r I , 'c'j ()'1 (-- ." ~ ") :~] ~:.! ..... /.. (-j 5 r...:::) fil ~ ::;;2 -- U1 '0 -< DERRICKA. WATSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL VANIA v CIVIL ACTION - LAW NO. 05-5021 MICHELLE R. WATSON, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under S 3301(c) of the Divorce Code was filed on September 23, 2005. 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 ofthe 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. S 4904 relating to unsworn falsification to authorities. Dated: ell O'j / cr ^ I I )j {. /) /:] k:/: .- /"t",VU,r./{ .: _ /~'?-rJiuf)-;>'-. Derrick A. Watson, Plaintiff WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER & 330l(c) I. 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. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. Dated: 01/ c3/ (,0 ( I )t~I)u{j~' D d~-I~s- Derrick A. Watson, Plaintiff WEIGLE & ASSOCIATES. PC. - ATTORNEYS AT LAW - 126 EAST KING STREET ,,- SHIPPENSBURG, PA 17257-1397 C) " '" r~ ~f~ c;. -n ::::-1 ~? t-Ji DERRICKA. WATSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYL VANIA v CIVIL ACTION - LAW NO. 05"5021 MICHELLE R. WATSON, Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under ~ 3301(c) of the Divorce Code was filed on September 23, 2005. 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 unsworn falsification to authorities. Dated _ F-:fCb ~ ~~~,e. hL'*'_J MIchelle R. Watson, Defendant WAIVER OF NOTICE OF INTENTION TO RE9UEST ENTRY OF A . DIVORCE DECREE UNDER 6 3301(c) 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, 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. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904 relating to unsworn falsification to authorities. Dated: ~"-{~-D lP 7J'L~~ #h J(. H "'Pi.... ./ Michelle R. Watson, Defendant WEIGLE & ASSOCIATES. RC. - ATTORNEYS AT LAW - 126 EAST KING STREET - SH1PPENSBURG, PA 17257-1397 (? c :;;,v -ofr.' rnr'-- ~f:~_ r:-::.- "'--. ~b .J> c: "7 ':3 ~, ....., = = "" > c:: G"> N c..:> -0 :;ll: C1? ~ ~~ -om :P\'C Oc.> "--4-r. :L--n (~)0 2m o -~ 5:; '< U1 + DERRICK A. WATSON, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY 'pENNSYL VANIA v CIVIL ACTION - LAW NO. 05-5021 MICHELLE R. 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. Grounds for divorce: irretrievable breakdown under ~ 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: September 27, 2005, by mailing postage paid, certified mail, addressee only, and return receipt requested at Shippensburg, Pennsylvania. 3. Date of execution of the affidavit of consent required by ~ 3301(c) of the Divorce Code: January 3,2006 by Plaintiff Derrick A. Watson; August 15, 2006 by Defendant, Michelle R. Watson. 4. Related claims pending: None 5. Date Plaintiff's Waiver in ~ 3301(c) Divorce was filed with the prothonotary: January 4, 2006 Date Defendant's Waiver of Notice in ~ 3301(c) Divorce was filed with the prothonotary: August 23, 2006 WEIGLE & ASSOCIATES, P.C. r0 /{t/L/_ / Richard L. Webber, Jr., Esquire Attorney for Plaintiff Attorney ID #49634 126 East King Street Shippensburg, P A 17257 Telephone (717)532-7388 WEIGLE & ASSOCIATES, P.c. - ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17257-1397 (') c: ~. i'r. r-.:J c:::> c::.:;:l C1"" if) ~~ - S::.- ~ :1,:!3 fir:::: -om -n '-/ ~~)~ ~(; ~,>~ ~{1 ()' ."'-\ 2p ':.< -0 r;-? N r,..) it' 04' 04' it' it' 04' it' ;f. it' ;f. Of. [f; lti iIi lti iIi iIi ltiili iIi iIi O4'iIi ;t. iIi iIiiliiliili iIi IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF PENNA. DERRICK A. WATSON. No. 05-5021 Plaintiff VERSUS MICHELLE R. WATSON. Defendant DECREE IN DIVORCE AND NOW, ~j~ 3-(,- 2006 , IT IS ORDERED AND DECREED THAT DERRICK A. WATSON AND MICHELLE R. WATSON ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, , DEFENDANT, 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; NONE '" '" iIi "'04' iIi iIi iIi iIi iIi lti URT, d- iIi lti lti lti iliililti PROTHONOTARY lti '" ltiltiililti iliiliili iIi iIi 04' lti iIi it' it' it' iIi iIi iIi iIi it' iIi lti iIi it' iIi iIi 'I' '" 'I' iIi iIi iIi J. it' ",,.;'+' ~ p? ~ ~ 1rJ-LC/1 ~('1 y$ ~ JW.j'V ')J,u::-b . ", ,~ ,.lo'~" . 4.. ^.' .. ..