HomeMy WebLinkAbout00-07354
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DANIEL S. BAKER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Defendant
: CIVIL ACTION, LAW
: NO. 00- 73~"/ CIVIL TERM
: IN DIVORCE
v.
BETTY JANE BAKER,
NOTICE
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 Prothonotary at
the Cunlberland County Court House, High and Hanover Streets, Carlisle.
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 RlGHT 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
Phone: (717) 249-3166
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DANIEL S. BAKER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION ' LAW
Defendant
: NO. 00- 7:35Y
: IN DIVORCE
CIVIL TERM
BETTY JANE BAKER,
COMPLAINT UNDER SECTION 3301(c) or 3301(d)
OF THE DIVORCE CODE
1. Plaintiff is Daniel S. Baker, who currently resides at 415 Meadowbrook Road, Carlisle,
Cumberland County, Pennsylvania, since September 2000.
2. Defendant is Betty Jane Baker, who currently resides at 484 Old Mill Road, Carlisle,
Cumberland County, Pennsylvania, since September 1996.
3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six
months immediately previous to filing of this Complaint.
4. Plaintiff and Defendant were married on September 14, 1996, at Carlisle, Cumberland County,
Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties hereto in this
or any other jurisdiction.
6. The marriage is irretrievably broken.
7. 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.
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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. S 4904, relating to unsworn falsification
to authorities.
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Date:
I r! ~ /3 - c9ctXJ
Daniel S. Baker, Plaintiff
ANDREWS & JOHNSON
By:
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DANIEL S. BAKER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
BETTY JANE BAKER,
Defendant
: NO. 00- 7354
: IN DIVORCE
CIVIL TERM
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA )
COUNTY OF CUMBERLAND )
AND NOW, this C; P7 day of November , 2000, 1, Ronald E. Jolmson, Esquire, attorney for
Daniel S. Baker, Plaintiff in the above-captioned action, hereby swear that 1 have served a true copy of
the Complaint in Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiff in the
above-captioned matter, upon the Defendant at her residence at 484 Old Mill Road, Carlisle, PA 17013,
by depositing the same in the U.S. Mail, postage prepaid, certified, deliver to addressee only, return
receipt requested. A copy of the return receipt card signed by the Defendant on November 3, 2000,
indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof.
ANDREWS & JOHNSON
Sworn and subscribed to before me this
" day of November, 2000.
Not blic
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NOTARIAL SEAL
SHEllY SEXTON, NOTARY PUBUC .
CARLISLE BORO, cliMBER LAND COUNTY
MY COMMISSION tXPIRE9 AP~ll2B, 200~ I
Member, Pennlylv~~I. P.'~~.I"llilh {if NlJI8n@fi
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"0 [J Complete Items 1 andlor 2 tor additional services,
CD Complete lIems 3, 4a, and 4b,
~ 0 PTlrn your name and address on the reverse of this form so Ihat we can relurn this
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.r 0 Write "Return Receipt Requested' on the mallpiece below the article number.
+' Q T\\9 RetU;m Receipt will show te whom the article was deIi\leretl and the t1ate
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1Q2595-99-B-0223 Domestic Return Receipt
Exhibit A
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