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HomeMy WebLinkAbout02-1267MICHELLE L. WATSON, Plaintiff VS. TIMOTHY M. WATSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : 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 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 Court Administrator, Cumberland County Courthouse, Hanover Street, Carlisle, PA. 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 MICHELLE L. WATSON, Plaintiff VS. TIMOTHY M. WATSON, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN DIVORCE COMPLAINT 1. The Plaintiff Michelle L. Watson, is an adult individual whose residence is 1194 Highland Drive, Mechamcsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant Timothy M. Watson, is an adult individual whose residence is c/o Bonnie Scrignoli, 1517 Carlisle Road, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Plaintiff has been a bonafide resident in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were mamed on October 1, 1994, in Lewisberry, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The Plaintiff avers that there are two children of the parties under the age of 18: Austin T. Watson, bom March 19, 1995 and Christian R. Watson, bom October 3, 2000. 7. Neither of the parties in this action is presently a member of the Armed Forces. 8. The Plaintiff and Defendant are citizens of the United States. 9. The Social Security Number of the Plaintiff is 173-66-7813 and the Social Security Number of the Defendant is 206-54-0474. 9. The Plaintiff has been advised of the availability of mamage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. 10. The Plaintiff avers the grounds on which the action is based is that the marriage is irretrievably broken. WHEREFORE, the Plaintiff requests the Court to enter a Decree of Divorce. Respectfully submitted, PURCELL, KRUG & HALLER BY ~quire (I.~. #29955 k.~719 North Front Street Harrisburg, PA 17102 (717) 234-4178 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 unswom falsification to authorities. Dated: March 12, 2002 MICHELLE L. WATSON, Plaintiff VS. TIMOTHY M. WATSON, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002 - 01267 : CIVIL ACTION-LAW : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS: COUNTY OF DAUPHIN I, Carol Masich, secretary to, John W. Purcell, Jr., Attorney for the Plaintiff in the above action, hereby swear and affirm that on the 15~ day of March, 2002, I sent, by certified mail, return receipt requested, deliver to addressee only, a certified copy of the Complaint in Divorce, containing Notice to Defend and Claim Rights to Timothy M. Watson, the Defendant in the above action. The return receipt, is attached hereto and made a part hereof as Exhibit "A". Sworn and subscribed to before me thi~_day ,-]q~t~r y~ Public- - ~. Carol Masich Secretary to John W. Purcell, Jr. Exhibit "A"