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Home My WebLink About03-0018LYDIA BAKER, Plaintiff VS. RONALD A. BAKER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. (D~ ~ /or> Civil Term . : ACTION IN DIVORCE : COMPLAINT IN DIVORCE 1. Plaintiff is Lydia BakerBaker, a competent adult individual, who has resided at 861 N. Hanover St., Carlisle, Cumberland County, Pennsylvania, since April 2002. 2. Defendant is Ronald A. Baker, a competent adult individual, who has resided at 93 East Main St., Walnut Bottom, Cumberland County, Pennsylvania, for 37 years. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months irmnediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on December 14, 1965 in Las Vegas, Nevada. 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 that plaintiff may have the right to request that the court require the parties to participate in counseling. 7. Plaintiff and Defendant have two grown children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: That the marriage is irretrievably broken. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. 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.C.S. §4904 relating to tmswom falsification to authorities. Lydia l~aker, Plaintiff Date: , / Respectfully submitted, 36 South Pitt Street Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF LYDIA BAKER, · Plaintiff · VS. · RONALD A. BAKER, · Defendant · IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 03- 18 Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this January 8, 2003, I, Jane Adams, Esquire. hereby certify that on January 4, 2003, a certified true copy of the NOTICE TO DEFEND AND COMPLAINT IN DIVORCE was served via certified mail, restricted delivery, return receipt requested, addressed to: Ronald A. Baker 93 East Main St. P.O. Box 63 Walnut Bottom, Pa. 17266 DEFENDANT Respectfully Submitted: Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF LYDIA BAKER, Plaimiff VS. RONALD A. BAKER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 03- 18 CivilTerm : : ACTION IN DIVORCE AFFIDAVIT OF SEPARATION 1. The parties to this action separated on April 18, 2002. and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose my rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. I verify that the statements made in this affidavit are tree 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. LYDIA BAKER, Plaimiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COITNTY, PENNSYLVANIA vs. No. 03 - 18 Civil Term : RONALD A. BAKER, : ACTION IN DIVORCE Defendant : AFFIDAVIT OF SERVICE AND NOW, this May 11, 2004, I, Jane Adams, Esquire, hereby certify that on May 8, 2004, a certified tree copy of the AFFIDAVIT OF SEPARATION was served, via certified mail, return receipt requested, addressed to: Ronald A. Baker 93. E. Main St. P.O.Box 63 Walnut Bottom, Pa.17266 DEFENDANT t fu][ly Submi.tted: Jan~Adams, Esquire 3,'DJ No. 79465 /3~,/South Pitt Street ~-~arlisle, Pa. 17013 (717) 245.-8508 ATTORNEY FOR PLAINTIFF DomeStic Return Receipt ° Sender: Please box ATTORNEY AT LAW 36 S. PITT STREET CARLISLE, p~, 1701~ LYDIA BAKER, Plaintiff VS. RONALD A. BAKER, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 03-18 CivilTerm : ACTION IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this June 29, 2004, I, Jane Adams, Esquire, hereby certify that on June 5, 2004, a true copy of the NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE and COUNTER-AFFIDAVIT were served, via certified mail, return receipt requested, addressed to: Ronald A. Baker 93 E. Main St. P.O. Box 63 Walnut Bottom, Pa. 17266 DEFENDANT t(,, Esquire }465 ( 3/ffSouth Pitt Street k,~.~arlisle, Pa. 17013 (717) 245-8508 · Complete items 1, 2, and 3. Atso complete item 4 if Restricted Delivery is desired. · Print your neme and address on the reverse so that we can return the card to you. · ~ this card to the back of the maitpiece, ,~the front if space permits. ~ ~ ~dress~d to: Agent Addressee D. Is delive~/ address different fr°mitem 17 r~ yes If YES, enter delive~J addreSS below: n No [] Insured Mail [;3 C.O.O____._L. -- ~ ~ ~4, ReStnctsd De ry i 2. A~c~eNumber 7003 1010 000q 7818 6633 PS Fot~n 381 ~, Augu · Sender: Please print your name, address, and ZIP+4 in this box · JANE ADAMS ATTORNEY AT LAV*I 36 $, PiTi' STREET ~ARLISLE, PA 17013 I'"llh"llh,,,-Ih,lh,,Ih,,hl,,hhhhhh,hh,h,hl LYDIA BAKER, : 1N THE COURT OF COIvlMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 03-18 Civil Term : RONALD A. BAKER, : ACTION 1N DIVORCE Defendant : NOTICE OF INTENT TO REQUEST ENTRY OF ]DIVORCE DECREE TO: Ronaid A. Baker 93 E. Main St. P.O. Box 63 Walnut Bottom Road, Pa. 17266 DATE: May 28, 2004. You have been sued in an action for divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the 3301(d) affidavit. Therefore, on or after June 18, 2004, the Plaintiff can request the Court to enter a final decree in divorce. If you do not file with the Prothonotary of the Court an answer with your signature notarized or verified or a Counter-Affidavit by the date above, the Court can enter a final decree in Divorce. Unless you have already filed with the Court a writl:en claim for economic relief, you must do so by the above date or the Court may grant the divorce and you lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICE[ YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. The filing of your counter-affidavit alone does not protect your economic claims. 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 32 South Bedford St. Carlisle, Pa. 17013 (717) 249-3166 LYDIA BAKER, VS. Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 03-18 CivilTerm RONALD A. BAKER, Defendant ACTION IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301{d) of the DIVORCE CODE.. 1. Check either (a) or (b): ___(a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because: (Check (i),(ii), or both:) __(i) The parties to this action have not lived separate and apart for a period of at least two years. __(ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, arid expenses if I do not claim them before a divorce is granted. __(b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees, or expenses or other important rights. I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth on the Notice of Intention to Request Divorce Decree, the divorce decree may be entered without further notice to me, and I shall be unable thereafter to file any economic claims. I verify that the statements made in this counter-affidavit are tree 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: Ronald A. Baker, Defendant NOTICE: If you do not wish to oppose the entry of a divorce decree and you do not wish to make a claim for economic relief, you need not file the counter-affidavit. LYDIA BAKER, Plaintiff VS. RONALD A. BAKER, Defendant : 1N THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 03- 18 CivilTenn : : ACTION 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 §3301(,~ of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail, restricted- delivery, Delivered on: January 4, 2003. 3. Date of execution of the affidavit required by §3301(d) of the Divorce Code: By Plaintiff: April 18, 2004. Date of filing and service of the plaintiffs affidavit of separation required by §3301(d) of the Divorce Code on respondent: Filed: April 26, 2004. Served on Defendant: May 8, 2004 Affidavit of Service filed: May 13, 2004. 4. Related claims pending: No claims raised. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Notice of intention was forwarded to Defendant via certified mail, and defendant si~ned and received document on June 25, 2004. ~---R-~ect fully Submitted: "-"'"~"~Afi .', q' l.D.~o. 79.465 3~. Pitt St. ~.~Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Lydia Baker, Plaintiff No. 03 - 18 Civil Term NO. VERSUS Ronaid A. Baker, Defendant DECREE IN DIVORCE AND NOW, Lydia Baker DECREED THAT Ronaid A. Baker AND , IT IS ORDERED AND , PLAI NTI FF, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE SEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. BY THTCOURT: / A~~J' ~ PROTHONOTARY