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HomeMy WebLinkAbout01-04179r IN THE COURT OF COMMON P-LEAS N o. oi-41.7.9 ....... ................. 19 DECREE IN DIVORCE AND NOW. ~ ............. ........ . ~x.2ooi eft' ~F; ssPM, it is ordered and decreed that ...............ROSIN, D., sAxER,,,.,,..,.,.,,,,,,.,, plaintiff, Ond ~••~••~•••••••••••••••••EDWARD•3..•BAKER•••••••••••••••••., 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 . .................................................. Prothonotary s.....ws., a~.. ~w..:a- :::.ee, r:•:,-s. ~ : ~;: e. ~ ...e,:. ~ . ~•; ,~ ~ , ::e; ~ ..e :ce . w .::. w :.. <..e..::::e:..: r. F:\FILES\DATAFE.E\Grnd x.cur\10345-peal/We Qeahd: IOI VI01 04:4]:33 PM Revised. 1+/02101 10:0$l l AM ROBIN D. BAKER, Plaintiff v. EDWARD J. BAKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. 01-4179 CIVIL TERM 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: See Affidavit of Service, as filed. 3. (a) Date of execution of the Plaintiffl s affidavit of consent required by Section 3301 (c) of the Divorce Code; October 19, 2001; by the Defendant; October 19, 2001. 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: October 24, 2001. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: October 25, 2001. Date: November 2, 2001 MARTSON DEARDORFF WILLIAMS & OTTO B Edward L. Schorpp, Esqui e Ten East High Street Carlisle, PA 17013 (717) 243-3341 Attorneys for Plaintiff C h N O W OO m : ~, - _. = i ~ 7f" _ `C.7 :(, t~ - ;.a _;„ .%. M1i :,~J ~;~ ~i7 (J' l ~ O '~ ~. ... peas!=e ,~~ .~~,rr~'wa*~9ac u~=s.~ra~w~!~~. ._.--' F.\FILES\DAiAFILE\Grndoc our\10345-com.l/tde Caemd: 06/18/01 10.34:0'] AM Revised: 06/19/01 12 ll9] PM ROBIN D. BAKER, Plaintiff v. EDWARD J. BAKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.oI-y1~9CIVIL TERM 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 ifyou 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 with 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, First Floor, Cumberland County Court House, Carlisle, Pennsylvania 17013. 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 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 Two Liberty Avenue Carlisle, Pennsylvania 17013 Telephone: (717) 249-3166 ROBIN D. BAKER, Plaintiff v. EDWARD J. BAKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO. CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 33011 OF THE DIVORCE CODE 1. Plaintiff is Robin D. Baker, who can-ently resides at 741 Conodoguinet Avenue, Carlisle, Cumberland County, Pennsylvania, since 1983. 2. Defendant is Edward J. Baker, who currently resides at 645 Hamilton Street (Rear), Carlisle, Cumberland County, Pennsylvania since 1999. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 27, 1993, in North Middleton Township, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiffhas been advised that counseling is available and that Plaintiffmay 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. MARTSON DEARDORFF WILLIAMS & OTTO B f Edward L. Schorpp, Esq ~ •e Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff Date: July 9, 20(31 I verify that the statements made in this complaint are true and core@cY.; I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §49b4; relating to unsworn falsification to authorities. Q ` ~ Date: ~' 3y' OI ~`J~~ ~-~n \ ,. ~°~-~-` . Robin D. Baker -3- ~. .~ ~ ~ -~ ~ \ ~ ~ & ~ ~1 ~ .~ _ ~ ~°~ _ ~, ~ ~~ ~ ~ ~ -~ ~S ~o ~~ , ~ ~ EC~ ~~ ~~~ ~u~ ~~; ~, ~a n r~, :; ~` ~- .~ ~d~d~° G `" P: \PIL£5\OATAFILE\Gend C.CUt\10i 95-aff.l Gested' 0]/?3101 IL2154 AM Revised 0]!23101 02:20J2 PM ROBIN D. BAKER, Plaintiff v. EDWARD J. BAKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.O1-4179 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) SS. COUNTY OF CUMBERLAND ) I hereby certify that a copy of the Complaint in Divorce was mailed to Defendant Edward Baker at 645 Hamilton Street, Rear, Carlisle, PA 17013 on July 10, 2001 by certified mail, restricted delivery, return receipt requested. Attached is the Post Office return receipt signed "Edward J. Baker." and dated July 13, 2001. ~~ T~ ~/ Edward L. Scho p, Es i Sworn to and subs ribed before me this2j"~day of YY ~~/ ~J. Oe2'l~nrr otary Public NOTARIAL SEAL TRICIA D. ECKENROAD, Notary Public Carlisle Boro„Cumberland County. icS;oPl ~sr 0 m ~- ~ Postage $ a fTl CertiSetl Fee ~ ~. lC N Return Receipt Fee I fll (Endorsement Aequired) G Restricted Delivery Fee p (Endorsement Required) 3_oZC ~ Total Postage & Fees ,$ y ~ WteipantS Name le`arly- ptreat, Apt Na; rP0 ox O Sy~~p C~ O Ci.-SYete. IPS-- .-___-- J~efr M1 ~ I ^ 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. 1. Article Addressed to: ~G~,UJGd~ ~~~ Ut.~ ~~G,mi.~lm ~~• , Cam. ¢+~ ~'l o.~ JUL ' F~~p mark 2001e A. Receive Eby (P/eas~ ~`Cleady) I B. ~ ~~ C. Signature D. Is delivery acfdiass dlHeren[ Irom item 1? U Yes IF YES, enter delivery address below: ^ No I' 3. Service Type Certified Mail ^ Express Mail ^ Registered ^ Return Receipt for Merchandise ^ Insured Mail ^ C:O.D. 4. Restricted Delivery? (Extra Fee) ~ y~ 2. Artice Number (COPY from servke IabeQ rJ-~on ~ot7 7310 y~ PS Form 3811, July 1999 Domesgo Return Receipt 702595-00-M-0952 .~=?x* .. ... ... _ 7 A ~ ` C3 ~~ '. ~)h; , V \ .~ -; ~~ Ar P ~` `•) 1 „" ~l .. ... .. ptpq~Z{ ., . ... ~. `tNsni~s'¢hiN ,.. . , 'Y~~4ip3uP(NW'. _ , . A. a F.\FILES\DATAFIl.E\Gendoacudl0345-afCcoMde Crtaled: 10/1]/0109:4]:33 PM RevisA 10/1]/0104:50:52 PM 1 ~ ROBIN D. BAKER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -.LAW EDWARD J. BAKER, N0.01-4179 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on July 10, 2001. I acknowledge receiving a true and correct copy of the Divorce Complaint, said copy being served upon me by Certified Mail, Restricted Delivery, on July 13, 2001. 2. The marriage ofPlaintiff 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. 4. I understand that I may lose rights concerning alimony, division ofproperly, lawyer's fees or expenses if I do not claim them before a divorce is granted. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(cl AND ~3301(d) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division ofproperty, lawyers fees or expenses if I do not claim them before a divorce is granted. 3. 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 statements made in this affidavit and waiver are true and correct. I understand that false statements herein aze made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: ~~~ l ~J ~~ ~ ----_'__ 1 Edward J. ,Defendant wn . ,. r ~- -. , z~~-F ~ _ ~' ti - - fl) ~'~ FC.~' LJ.; - ~ ~ ` ~ 41=i .~, _ ~ ~~ ~',~ __~ fl /'/~A~ ly 1 Y _ . -,~qap _ ~ . _ R'AI ~. M?m+Y~~.!~ i --- nur~a(u x~~3~k[i~ .. , '~~ V w ~+ ~ ,~ .„ w ROBIN D. BAKER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION -LAW EDWARD J. BAKER, N0.01-4179 CIVIL TERM Defendant IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed on July 10, 2001. 2. The marriage of 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. 4. 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. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(c) AND § 3301 (d) OF THE DIVORCE CODE 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 ofproperty, lawyers fees or expenses if I do not claim them before a divorce is granted. 3. 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 statements made in this affidavit and waiver 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: /C7- l~-OI ~~~~~-~'~-w-~ Robin D. Baker, Plaintiff ~ ry M ~ n i~ ~~ C ~--~ Tt ~~ ~ ~~.' ii ~ ~ _ ~ _ ._ ~l\ ~. ~. ` = 4~ _ '^4 ~f~ 0