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Home My WebLink About01-1196 FX . . . . . . . . . . . . . . . . . . . . . . . . . . . .1 I _le,,,1 . . ... .. .. . ;f.;f. ,.,IIi:f.:f.:f. "':f. . . . :f.:F. '" ;Ii;!;"'''' :F.;t;i+. :+;:f. . . . , . , , , , . , . , , , . . . . . . . , . . . . . . . . . . . . . . . . , . . . . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Ray W. Baker, Plain.titf No. 1196 Civil Term 2001 VERSUS Sh.."..l' R. ~1<...,., TlAr..mrl..nt. DECREE IN DIVORCE AND NOW, 1" . c.~ , ZtPo/ , IT IS ORDERED AND , DECREED THAT R12Y 'Wr ~..~.,. , PLAINTIFF, . Shelley E. Baker AND , 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; Heme. . , . J. ~~P"O'HONO'A"Y . . '" :Ii :f."':f.'+' Of. :f. :f.:f.:f.:f. :f.1li;F.,IH" '" :f. . . . . Of. :f. :f.'" . . . , . . . . , . , , . . . . . . , , . , , , . . . , , , , . . . . . . . . . . . . . . , " ~~~j~li1' ="'--"~~lI;iQ\Ililt~~Itliiml_!~I~liIrIIaJ!lilli~ ~&n' ~ ~' ~~ ~~ fr :z ~:'" ~ /P ~ . <" l."".," ''''.. .-^.""," - . ~ .'~~"'" "-"-'-" ,,,' . -~,~-' ,,--,~~ . ,- HI ~ ,',;.0.., ~~" .,..-.,. / t?- C'/- '7 /r?e.p '" .,. ~" ."~ ~,~ -.-- < ,,~ ~ ~~~~ '" , ~ . ,~~ . ". ~ ~-" .i!liiI/} , RAY W. BAKER, SR., Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. DI- //Cfl::, CO~( ~ SHELLEY E. BAKER, Defendant : ACTION 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 '. . "'ili1M -J")' . , ' RAY W. BAKER, SR., Plaintiff vs. : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA ; No. OJ. WIt.. Cu;J-r~ SHELLEY E. BAKER, Defendant : ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Ray W. Baker, an individual sui juris, who has resided at 102 W. High Street, Carlisle, Pennsylvania, 17013, since June 2000. 2. Defendant is Shelley E. Baker, an individual sui juris, who resides at 909 Spruce Court, Fort Walton Beach, Florida, 32547-1021. 3. Plaintiff has been a bona fide resident of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on June 15, 1974 in Carlisle, Cumberland County, Pennsylvania. 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 no minor children. 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. &- " Wti:~. , ., .' .. I, , 10. The Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken; and/or (b) That the Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. 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 unsworn falsification to authorities. '~~r~~r Ray W. akerBaker, Plamtlff Respectfully submitted, :1( - 0 I Date: (/3-v ane Adams, Esquire J.D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF . ~- ^ -", ~ -...~.......~. "C' .~'- l~i RAY W. BAKER, SR., Plaintiff vs. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. Ol-It?f.. (Jol1~~ SHELLEY E. BAKER, Defendant : ACTION IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, RAY W. BAKER, SR., to proceed in forma pauperis. I, JANE ADAMS, ESQUIRE, attorney for the party proceeding in forma pauperis. certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. Respectfully submitted: Date: 3--( -oj J e Adams, Esquire .D. No. 79465 117 South Hanover St. Carlisle, Pa. 17013 ATTORNEY FOR PLAINTIFF ,~."'-""' ^ ~ '. ~" .l ~ .... ~(. 0_ ,~_^'h,;< RAY W. BAKER, SR., Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. SHELLEY E. BAKER, Defendant ACTION IN DIVORCE AFFIDA VII IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. 1 am the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: Ray W. Baker. Sr. Address: Safe Harbor House. 102 W. High Street. Rm 218. Carlisle. Pa. 17013 (b) Social Security Number: 184-36-7209 If you are presently employed, state Employer: None. Address: N/ A Salary or wages per month: None. Type of work: N/A If you are presently unemployed, state Date oflast employment: January 2000 Salary or wages per month: $1204 gross income per month. 'Type of work: Construction cleanup. (c) Other income within the past twelve months Business or profession: None. Other self-employment: None. Interest: None. Dividends: None. Pension and annuities: None. Social Security benefits: None. Support payments: None. Disability payments: None. Unemployment compensation and supplemental benefits: None. Workman's compensation: None. Public Assistance: $220.37 per month. Other: None. (d) Other contributions to household support (Wife)(Husband) Name: None. If your (hu6b.u,d) (wife) is employed, state Employer: Unknown. Spouse currently living in Florida. Salary or wages per month: Unknown. Type of work: Unknown. Contributions from children: None. (e) Property owned Cash: $10 cash. Checking Account: None. ...1. ~ I ~ "< h ~""~''',.~- .~ -~ = " . ~L '-0 ,~~~~. ~+ . Savings Account: None. Certificates of Deposit: None. Real Estate (including home): None. Motor vehicle: Make None. Year Cost Amount owed_ Stocks; bonds: None. Other: None. (t) Debts and obligations Mortgage: None. Rent: $45 a month at Safe Harbor House. Loans: None. Monthly Expenses: $45 a month plus food equals approximately $200- $250 a month. (g) Persons dependent upon you for support (Wife) (Husband) Name: None. Children, if any: All children are above 18. ~ e /~ __ ~ a b r!~" ~ .6~ ~~, ;;7--/' '1f. ?'/~ vI/l- - ~ /'[ 4. I und!:and that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. 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: () 5 - 0 ( - [) I ~~' ~;&cbtA~ Ray W aker, Sr. ~~_~~,~;llll!lliil~il!tM\'l~iMii:;:ii.t~.,.j;;"M~"',"",,'';'''i'''''h~k'''~'- -c, .~'.M"'k:,;~;i,.~<liiI,jfijti"~"'''''''~_mIil\liii~"...;;j -..w. ~,..Ii!l-~ =.. ~Mll'm () (=--~ ~t [",":: \,- f;:iLi ;1~ ~i - ",-~ "-- ,- =.~ -. ;"-:':J -'<) ,~'? :',', (-, ~-~~:; ~( w l\i' '-" -'~ .~-, I~~W. , -~ RAY W. BAKER, SR., Plaintiff vs. : IN THE COURT OF COMMON PLEAS CUMBE~AND COUNTY, PENNSYLVANIA ~ No. 6(- IR'- C~l{ ~ : ACTION IN DIVORCE SHELLEY E. BAKER, Defendant AFFIDAVIT OF SEPARATION 1. The parties to this action separated in June 1998 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 if! do not claim them before a divorce is granted. 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. 94904 relating to unsworn falsification to authorities. Date: {:?.? ~o I - ()! ~~ .~~~ Ray . Baker, Plamtlff ~m~~'1iIf'gW<!ti"IU;jil,j!ijili!l;t!:.~~~~M&,'J1'61M-'i..,- '">",4<"_o<i,,:gt""';l:,J"bA'Hili,@;"'c~~IflI~IilIiIIiU~iel!iItEi~'~"-'ii:~~r'...~,_o,~.:~................'""'" ..- , ~~ (") c :? ~~~ :2:[- (/) - -< ~ -::~_:.. ('-, S~~ ~~~ 2: =< - c:;, \"::l :n t;::::J '>= >>- <'Q (,-~ C:\ (f . " ,,! ~ ~- . ;'f~ RAY W. BAKER, SR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA VS. No. 01 - 1196 Civil Term SHELLEY E. BAKER, Defendant 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 63301(d) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered bv certified mail. restricted deliverv. return receipt requested. delivered on: April 4. 2001. Affidavit of Service was filed Aoril9. 2001. 3. Date of execution of the affidavit required by ~3301(d) of the Divorce Code: By Plaintiff: March 1. 2001. Date of filing and service of the plaintiffs affidavit required by ~3301(d) of the Divorce Code on respondent: Filed: Served on Defendant: Affidavit of Service filed: March 1. 2001. Aoril4. 2001 (out of state defendant). April 9. 2001. 4. Related claims pending: None. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: Plaintiff's oril!:inal notice of intent and counter-affidavit was served on Defendant on April 30. 200 I. via certified mail. return receipt requested.: notice and affidavit of service attached. Respectfully Submitted: Date: S, 30 I 0) Jane dams, Esquire I. . o. 79465 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff RA Y W. BAKER, SR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 01 - I ]96 Civil Term SHELLEY E. BAKER, Defendant c; ;:;~~ Z.o' zr-- NOTICE OF INTENT TO REOUEST ENTRY OF DIVORCE DEc:REE .- ~c~ ~~~: Pc'--' Z ::< . ACTION IN DIVORCE ,=, 0 "'1 - :'':"> -- -< N , , ,..;) '--/ :\ ~ (-~ ~, ;.:.:-::-, I J ~';' ~ 2- u' =<. IQ.;, Shelley E. Baker 349 Coral Drive S.W. Fort Walton Beach. FL. 32548 _ DATE: April 25, 2001. You have been sued in an action fox divorce. You have failed to answer the Complaint or file a Counter-Affidavit to the 3301(d) affidavit. Therefore, on or after May 15.2001 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 ean enter a final decree in Divorce. Unless you have already filed with the Court a written Glai.m 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 WHICH 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 2 Liberty A venue Carlisle, Pa. 170 I 3 (717) 249-3 I 66 _It.-- , _L -. ,'" I ~ . -~ ~~j" " ",' . .-~ RAY W. BAKER, SR., Plaintiff .', ;~jl~~i~t~~,..~:!~\ vs. SHELLEY E. BAKER, Defendant : ACTION IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(Jl) 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 Wlderstand that I may lose rights concerning alimony, division of property, lawyer's fees, and expenses if! 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 Wlderstand 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 delay. I verify that the statements made in this cOWlter-affidavit are true and correct. I Wlderstand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to Wlswom falsification to authorities. Date: Shelley E. Baker, Defendant NOTICE: If you do not wish to oppose the entry ofa divorce decree and you do not wish to make a claim for economic relief, you need not file the cOWlter-affidavit. RAY W. BAKER, SR., Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 01 - 1196 Civil Term SHELLEY E. BAKER, Defendant ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF THE NOTICE OF INTENT AND COUNTER-AFFIDAVIT AND NOW, this May 29,2001, I, Jane Adams, Esquire, hereby certifY that on April30, 2001, a true and correct copy of the NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE AND COUNTER~AFFIDAVIT were served, via certlIied mail, . 0 0 ~ restri,cted delivery, return receipt requested. addressed to: -;:~~ nl(-:-- Z:J" ~~;~ !<c,- ~c: :..'.::::c\ >e:: ::::; -< (-:-) ..,., ., ;..~ -<: N \.D r:-? > ~ ~'l; -'>~ F; '. ...... .---.:: {!_~ -r',_ :c'::': t -~ _:.1 ",., , :':~ n'-, --' =-j :0 -< Shelley E. Baker 349 Coral Drive Southwest Fort Walton Beach, FL 32548 '"U :::> ..,-1 DEFENDANT Respectfully Submitted: e Adams, Esquire I. . No. 79465 7 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF . -" SEN DER: COMPLETE THIS SECTION . Complete Items 1, 2, and 3. Also complate item 4 ff Restricted Delivery 'is deslrad. . Print your name and address on the reverse so that we can retum the card 10 you. . Attach this card to the back of the mallpiece, or on the front if space pannits. 1. Article Addressed to: Sh-e.-I/ey F. g~ ?II q 6rraP O/J~ S w:; pf:' ~Yl~'"'^ PL-~; L1 .1 30.5L {51, 2. Article Number (Copy from service IabeQ - ~, .- ,,-,'-' "~oj -t '. ",-,;",;,,, ,-..' ...-- dellvery address different from Item 1? If YES, enter delivery address below: o Express Mali CJ Return Receipt for Merchandise o C.O.D. 7019 3l.f ()O eo 1 g SOS: { dSS-:;;C j. PSFonn 3811 ,July 1999 Domestic Retum Receipt 102595-0Il-M.0952 '. ,-,~ . " . , . , '''''~''''''~Tih , .. . RAY W. BAKER, SR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01 - 1196 Civil Term SHELLEY E. BAKER, Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF NOTICE TO DEFEND. COMPLAINT. AND AFFIDAVIT OF SEPARATION. AND NOW, this April 9, 2001, I, Jane Adams, Esquire, hereby certify that on April 4, 2001, a true and correct copy of the NOTICE TO DEFEND, COMPLAINT, AND AFFIDAVIT OF SEPARATION were served, via certified mail, restricted delivery, return receipt requested, addressed to: Shelley E. Baker 349 Coral Drive Southwest Fort Walton Beach, FL 32548 DEFENDANT Respectfully Submitted: Jane dams, Esquire I.D o. 79465 17 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF ! , '. ~(7kk"~j_~IWI~e-V[ '~\!W-.J0Ji.ili1ih~!!fuM.,'il&<1';W_\~lIlti01~liIliIi!Ii1_i~'"----" _0_, ' ''I <". I 'I .1 " I, I I i i "M' (") C, c: <- -off :0- rl1fl'! ~) .- ! 2:c :::0 Zc:, I '"-- c::;., ::<'C \.0 ~C; " :'0 ~c:' ~() )>c: S-"~J Z .:01 .:11 J> -< '...1 :::Cl -c ~ J!; Complete_ items_1, 2, and 3. Also complete \ item 4 if Restricted Delivery is desired. i . Print your name and address on the reverse j..: so th;at we can return the card to you. -_~.. -. . Attach this card to the back of the mailpiece, " or on the front if space permits. 1, Article Addressed to: ~~,g~~ = c.l o. L<l...\.J,\)\. '€- Su"trCl'{'\ ~ <.1 '\ c..~-t>-_Q..JJnu-L S~~ ~+woJ.:h:r.".. B~ FL. o Agent o Addressee DYes o No ~i.c_e I~p_EL_ ,AI!:. ~~. --Gertifi~- Maii: 0 Express Mail ~ R "," L J 0 Return Receipt for Merchandise ..:eP-lnsured"Mail 0 C.O,D. ~Restnctea-beliv~-rY? ~ Fee) "'-==-- ~ . -' .. . Yes- 2. Art'cleNumber(~oPYfromserv'ce'abeOI oqq 3400 LC\&' 5O.s1 a..G:, d-O PS F '. R.\Um A.ee'.' I I I I II \ II i t02595.99-M-1789 Illll1ulhltlll1 11 II II t 15 III SENDER: COMPLETE THIS SECTION . Compl.::Ae 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. 1. Article Addressed to: deliv8lY address different from item 1? If YES, enter delivery address below: Shoed/evE g~ ?JI q &zJ2 07/'Jve S W ~ c ,,' /Ji ~ I) _ _ J,--, I 'd 3. S.",'ce Type D it: V~ )'l ,~oA/.... r L--O' ;-~:Certifi~;, 0 Express Mail 3 c-U <?' EJ Registered 0 Return Receipt for Merchand1se ~..:..; -I 0 ;~~- ---~ ~Insu~ed-:air 0 C.O,D, -4.-~estricted-Derivery1 (l!Xtra f_ee).. Yes 2. Article Number (Copy from service labelj 7rY193lj()Cco18sos;r d.S'.s-~ ^ c r Domestic Return Receipt PS Form 3811. July 1999 102595.00.M.0952 ,,~~ !~-...- - '" ~ ..";.,.,, " ~ .! -, "-''-'-':litii .; '(e ~-, '4" il;;" "~', . , RAY W. BAKER, SR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA vs. : No. 01 - 1196 Civil Term SHELLEY E. BAKER, Defendant : ACTION IN DIVORCE NOTICE OF INTENT TO REOUEST ENTRY OF DIVORCE DECREE TO: Shetley E. Baker 349 Coral Drive S.W. Fort Walton Beach. FL. 32548 DATE: April 25, 2001. 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 May 15. 2001 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 written 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 WHICH YOU MA YFILlE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO TillS 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 TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OmCE 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 ""~ I ~ " ~ -' ,---~ -- ;..~" '":-, \~~ kb ,c ..... . RAY W. BAKER, SR., Plaintiff : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA vs. No. 01 - 1196 Civil Term SHELLEY E. 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, and expenses ifI 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 delay. I verifY that the statements made in this counter-affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. g4904 relating to unsworn falsification to authorities. Date: Shelley E. 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. iIlIIl1il~~~!!ll~r~~rEl\t,i!;thimi!t.<~';;i!/;;,l;;~~IWlillt -- .. ~~ --~"lIlIlti;liiW'il~-'.';" ." =,;- 'iilIiliiiai ~" . 0 C; C ~ ~:': III iT: :c-", 7' [:.c_, ~ 7 ,,-- f'._.) OJ \_D r' .-' _0", ..:.::- ,<:(.. :t:2 ':? 2:: ,:::J ~d --j -< (;'\ -< ~~ .,_,_,J ",. . /" , . --. ""-~" -." ,~ 'ii;;<' ....-.' " . " , . RAY W. BAKER, SR., Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA vs. : No. 01 - 1196 Civil Term SHELLEY E. BAKER, Defendant : ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF THE NOTICE OF INTENT AND COUNTER-AFFIDAVIT AND NOW, this May 29,2001, I, Jane Adams, Esquire, hereby certifY that on April 30, 2001, a true and correct copy ofthe NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE AND COUNTER-AFFIDAVIT were served, via certified mail, restricted delivery, return receipt requested, addressed to: Shelley E. Baker 349 Coral Drive Southwest Fort Walton Beach, FL 32548 DEFENDANT Respectfully Submitted: J e Adams, Esquire I. . No. 79465 7 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF