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Home My WebLink About03-1999GWEN ANN BAITSELL, Plaintiff VS. BRUCE EDWARD BAITSELL Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · No. 03 -_ / ,:] q ? CIVIL TERM · 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 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, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 GWEN ANN BAITSELL, Plaintiff VS. BRUCE EDWARD BAITSELL, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · No. 03 - ~/9 q ~ CIVIL TERM · DIVORCE _COMPLAINT IN DIVORCE COUNT I - NO FAULT 1. Plaintiff is Gwen Ann Baitsell, an adult individual currentl residl at 88 Mooredale Road, Apartment 3 Co,4~o~ ,~---, .... Y 'ng ..... o,~, ,~umoenana Uounty, Pennsylvania. 2. Defendant is Bruce Edward Baitsell, an adult individual currently residing at c/o 3 Pines Pines Tavern, 336 North Baltimore Avenue, Mount Holly, Cumberland County, Pennsylvania. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiffand Defendant were married December 21 1999 in Carlisle, Pennsylvania. , 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither Plaintiff nor Defendant is a member of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. The parties' marriage is irretrievably broken. 9. Plaintiff desires a divorce based upon the belief that Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a divorce pursuant to 23 P. S. Section 3301 (c) of the Domestic Relations Code. Respectfully submitted, Marga~e,[ M. Simok - Attorney for the Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 717-243-9400 Copy to: Bruce Edward Baitsell c/o 3 Pines Tavern 336 North Baltimore Avenue Mt. Holly, PA 17065 VERIFICATION The above named Plaintiff, Gwen Ann Baitsell, verifies that the statements made in the above Complaint are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to unswom falsification to authorities. Date: ~-oZ~-O,3 Baitsell GWEN ANN BAITSELL, Plaintiff VS. BRUCE EDWARD BAITSELL, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · No. 03 - J q q .q CIVIL TERM · DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Gwen Ann Baitsell, Plaintiff, to proceed in forma pauperis. I, Margaret M. Simok, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay costs and that I am providing free legal service to the party. Margardl/M. Simok Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 717-243-9400 GWEN ANN BAITSELL, Plaintiff VS. BRUCE EDWARD BAITSELL, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : No. 03 - 1999 CIVIL TERM : : DIVORCE AMENDMENT COMPLAINT IN DIVORCE COUNT I - NO FAULT Plaintiff, by and through her attorney, Margaret M. Simok of MidPenn Legal Services, requests the following: to amend this Divorce Complaint as filed April 28, 2003, to correct the date of marriage for the named parties. The parties were married on December 21, 2000, not December 21, 1999, as stated in the original complaint. Respectfully submitted, MargareldV~. Simok Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 cc: Bruce Edward Baitsell 336 North Baltimore Avenue Mt. Holly Springs, PA 17065 VERIFICATION The above named Plaintiff, Gwen Ann Baitsell, verifies that the statements made in the above Complaint are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C. S. § 4904, relating to unsworn falsification to authorities. Date: ,5' - 5 -O3 Gwen Ann Baitsell Plaintiff Vs. Bruce Edward Baitsell Defendant ' IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 03-1999 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE BY MAIL I, Margaret Mary Simok, do hereby swear that I served Bruce Edward Baitsell with a Complaint in Divorce under Section 3301 (c) of the Divorce Code pursuant to Pa.R.C.P. 1920.42(a)(2) on the 29th day of April, 2003, by certified mail, return receipt, restricted delivery, to the person and address below: Bruce Edward Baitsell c/o 3 Pines Tavern 336 North Baltimore Avenue Mt. Holly, PA 17065 I, Margaret M. Simok verify that the statements made in this Affidavit of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. · Date: 6--(,,-O.(.:~ Signature: ~~0_.,,~ D'x.~ · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attachlthis card to the back of the mailpiece, or on ~lhe front if space permits. 1. Article~ddressed to: 2. Article Number (Transfer from service label) D. Is delivery address different from item 1'1 3. Service Type . Certified Mail D Express Mail [] Registered [] Return Receipt for Merchandise [] ~ns~ · - - PS Form 3811, August 2001 Domestic Return Receipt 102595-02-M-1035 Gwen Ann Baitsell, Plaintiff V. Bruce Edward Baitsell, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY PENNSYLVANIA : No. 03-1999 C1vILTERM IN DIVORCE AFFIDAVIT OF SERVICE BY MAll, I, Joan Carey, do hereby swear that MidPenn Legal Serv:[ces served Bruce Edward Baitsell with an Amended Complaint under Section 3301 (c) of the Divorce Code pursuant to Pa.R.C.P. 1920.42(a)(2) on May 6, 2003, by certified mail, retura receipt, restricted delivery, to the person and address below: Bruce Edward Baitsell 336 North Baltimore Avenue Mt. Holly Springs, PA 17065 I, Joan Carey, verify that the statements made in this Affidavit of Service are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: Signature:/~'~/ ~ · Complete items 1, 2, and 3. Also complete item 4 if Restricted Delivery is desired. · Print your name and address on the reverse so that we can return the card to you. · Attach this card to the back of the mailpiece, or on the front if space permits. 2. Article Number PS Form 3811, August 2001 Domestic Return Receipt 102595-02-M-1035 ru Gwen Ann Baitsell, Plaintiff VS. Bruce Edward Baitsell, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA No. 03-1999 C~VILT~P,M IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on April 28, 2003. 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 divorce. 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. Section 4904 relating to unsworn falsification to authorities. Date:_ ! (-~ ~'~ 5 "~2) Signature: ~ ~ ~.~_~). 0 ~Q.._ ~2x '(a~'en g~nn Baitsell, Plaintiff' Gwen Ann Baitsell, Plaintiff VS. Brace Edward Baitsell, Defendant IN THE COURT OF COMMON PLEAS OF CUM~EP,~D Cotrt,rry P~SYLV~i^ NO. 03-1999 CW[L T~RM IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on April 28, 2003. 2, The marriage °f 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 divorce. 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. Section 4904 relating to unswom falsification to authorities. Date: 10'-,2..g~o'~, Signature: ~ ~..."-~,.~ _~,.. Brace Edward ' ~ Bmtsell, Defendant Gwen Ann Baitsell, Plaintiff VS. Bruce Edward Baitsell, Defendant IN THE COURT OF CoIvflvION PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 03-1999 CIWLTERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODy; 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 ifI 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 flied with the Prothonotary. I verify that statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penaities of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Gwen Ann Baitsell, Plaintiff Gwen Ann Baitsell, Plaintiff VS. Bruce Edward Baitsell, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 03-1999 C~LL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 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 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 unswom falsification to authorities. Date: ~0-a,~O'~ Signature: ~ ~. ~ ~, Bruce Edward Baitsell, Defendant Gwen Ann Baitsell, Plaintiff VS. Bruce Edward Baitsell, Defendant IN ThE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA NO. 03-1999 C~VIL T~RM : IN DWORCE _PRAECIPE TO TRANSMIT RECORD To The Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divome decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. Date and Manner of service of the Complaint: MidPenn Legal Services mailed the defendant the Complaint by certified mail, return receipt, restricted delivery. Defendant signed the return receipt on April 29, 2003. The Complaint was amended on May 5, 2003. MidPen. Legal Services mailed the defendant the Amended Complaint on May 6, 2003 by certified mail, return receipt, restricted delivery. The defendant signed the return receipt for the Amended Complaint on May 8, 2003. 2. Complete either paragraph (a) or (b). (a) Date of execution ofthe Affidavit of Consent required by Section 3301 (c) of the Divome Code: by Plaintiff, October 25 2003; by Defendant, October 23 2003. (b)(1) Date of execution of the Plaintiff's Affidavit required by Section 3301 (d) of the Divorce Code: N/A (2) Date of filing and service of Plaintiff's Affidavit upon Defendant: N/A 3. Related claims pending: _There are no outstanding claime: 4. Complete either paragraph (a) or (b). (a) Date and manner of service of the notice of intention to file Pmecipe to Transmit Record, a copy of which is attached: .N/A~. (b) Date Plaintiff's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: November 19, 2003~ (c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: _November 19, 2003. Plaintiff's Social Security Number: 204-48-6243 Defendant's Social Security Number: 1_97-50-0608 Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 INTHE COURT OF COMMON PLEAS {DF CUMBERLAND COUNTY STATE OF ~ PENNA. Gwen Ann Baitsell Plaintiff VERSUS Bruce Edward Baitsell Defendant NO. 03-1999 CIVIL DECREE IN DIVORCE AND NOW, A,b?,.~ ..~$ ' DECREED THAT Gwen Ann Baitsell AND Bruce Edward Baitsell ARE DIVORCED FROM THE BONDS OF MATRIMONY. &d3', IT IS ORDERED AND _, PLAINTIFF, _, ~;EFEN DANT, 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; ALL CLAIMS HAVE BEEN RESOLVED. By THE COURT: A PrOTHONOTArY