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Home My WebLink About02-2208\~erver~shareddoc$\Word Processing\~omestic\witter.div complaint & notice.^prO2.doc IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA CARLA E WITTER, PAUL E WITTER, Plaintiff Defendant CIVIL ACTION - DIVORCE No. 2002 - o~ o~ 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 within twenty (20) days after this Complaint and Notice are served. 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 yo,a, 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. A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania, 17013, 717.240.6195. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISIONOF 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 71 7.249.3166 800.990.9108 \~Server~shareddocs\Word Process ng\domestic\witter.div complaint & notice.Agr02.doc IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA CARLA E WITTER, PAUL E WITTER, Plaintiff : : : Defendant .' CIVIL ACTION - DIVORCE No. 2002 - ~ COMPLAINT Plaintiff is CARLA E WITTER, who currently resides at 27 Short Lane, Shippensburg, Cumberland County, Pennsylvania, since April 19, 2002. Defendant is PAUL E WITTER, who currently resides at 7810 Olde Scotland Road, Shippensburg, Franklin County, since May 20, 2000. o Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. The Plaintiff and Defendant were married on September 19, 1981 at Fayetteville, Franklin County, Pennsylvania. \~Server~hareddocs\Word Prr/cessing~d,omestic\witter, div complaint &notice. Apr02.doc o There have been no prior actions of divorce or for annulment between the parties except NONE. 6. The marriage is irretrievably broken. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a decree of divorce. Forest N./v~ers, Esquire Atty I.D.# 18064 137 Park Place West Shippensburg, PA 17257 Phone 717. 532.9046 Fax 717.532.8879 e-mail fn myers@earthlink.net \~Serverkshareddocs\Word Pr0cessing\d?mestic\witter.div complaint & notice.Apr02.doc 0 I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. Cons. Stat. § 4904, relating to unsworn falsification to authorities. . Date: CARLA E WITTER, Plaintiff C:V, Ay Documents~ASH HD STORAGLqwitter. acpt of svc. May02.doc IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY- PENNSYLVANIA CARLA E WITTER, PAUL E WITTER, Plaintiff Defendant CIVIL ACTION - No. 2002 - 2208 DIVORCE ACCEPTANCE OF SERVICE I accept service of the Complaint under Section §3301(c) of the Divorce Code. Date: 7810 Olde Scotland Road Shippensburg PA 17257 \~SERVER\Shared Docs\Word Processing\domestic\witter. consent. Aug02.doc IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA CARLA E WITTER, vi. PAUL E WITTER, Plaintiff Defendant CIVIL ACTION - No. 2002 - 2208 DIVORCE AFFIDAVIT OF CONSENT A complaint in divorce under §3301(c) of the Divorce Code was filed on May 06, 2002. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 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. Date: August 7 ,2002 Carla E Witter, 'Plaf~tiff \~S E RVER~S hared Docs\Wo rd Processing\domestic\witter.waiver.AugO2.doc IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA CARLA E WITTER, PAUL E WITTER, Plaintiff Defendant CIVIL ACTION No. 2002 - 2208 DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODF. I consent to the entry of a final decree of divorce without notice. 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 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 statement 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. Date: August 6 ,2002 Paul E Witter, Defendant \LSE RVE RLS h a red Docs\Word Processing\domestic\witter.consent. Aug02.doc IN THE COURT OF COMMON PLEAS OF THE 9r" JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA CARLA E WITTER, Vo PAUL E WITTER, Plaintiff : : : : : Defendant : CIVIL ACTION - No. 2002 - 2208 DIVORCE AFFIDAVIT OF CONSENT A complaint in divorce under §3301(c) of the Divorce Code was filed on May 06, 2002. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 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. Date: August 6 ,2002 \~S ERVER~S h ared Docs\Wo rd Processing\domestic\witter.waiver. Au§02.doc IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA CARLA E WITTER, vi. PAUL E WITTER, Plaintiff Defendant CIVIL ACTION - No. 2002 - 2208 DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODF I consent to the entry of a final decree of divorce without notice. 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 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 statement 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. Date: .~ugust. ? ,2002 ~"~rla E ~'it~e~ Plair~tiff IN THE COURT OF COMMON PLEAS OF THE 9TM JUDICIAL DISTRICT CUMBERLAND COUNTY - PENNSYLVANIA CARLA E WITTER, Vo PAUL E WITTER, Plaintiff Defendant CIVIL ACTION - DIVORCE No. 2002 - 2208 To the Prothonotary: PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. Date and manner of service of the complaint: May 06, 2002 Acceptance of Service by Defendant o Date of execution of the affidavit of consent required by §3302(c) of the Divorce Code: by Plaintiff August 6, 2002; by the Defendant August 7, 2002. 4. Related claims pending: None Date plaintiff's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary: August 23, 2002; Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: August 23, 2002. \gerver~SHAREDDOCS\Word Processing\domestic\witter.praecipe.Aug02.doc Date: Forest N Myers, Esquire Attorney I.D. #18064 137 Park Place West Shippensburg PA 17257 Phone 717.532.9046 Fax 717.532.8879 e-mail fnmyers@earthlin k.net iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~j~. PENNA. Plaintiff VERSUS Defendant NO. 2002 - 2208 DECrEe iN DIVORCE AND NOW, :~[I.:~ , IT 15 ORDERED AND DECREED THAT CARLA E WITTER , PLAINTIFF, aND PAUL E WI'i-ru , 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; None