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Home My WebLink About99-05318-4 t Li f 4 . •:?i •:? ^ye? :e:• N:• ;ei •:e} <e:• <? • {e:.ti..:e} •:e: !q !e? •:ei •:? • •:e? :? • •:e> :• ;? IN THE COURT OF COMMON FLEAS OF CUMBERLAND COUNTY STATE OF PENNA. DONALD BAKER, Plaintiff .1999-53.18 ................. • Vci:<Us LISA K. BAKER, Defendant i i DECREE IN 1 D I V O R C E& 3 y.Zj Pit AND NOW, W • ..• ... 2000, , , , it is ordered and decreed that Donald Baker plaintiff, and .....Lisa. K. Baker defendant, a are divorced from the bonds of matrimony. 3 The court retoins jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet i! been entered; None ............. o P J. I 7 Prothonotary ' 10, y 7A;..r. ^'.' •:?:• •w;• •w• a:• ce:• •:?• •:e:..:?..:?:...te• :?. te> to :e; •:e: ;e:• :e:• •:e• ce; s: <e:• :e• c?:• <?: cs -A, ?- i d N ? Ci 7 CZ) V r 0m o .Y' N (D n 1 m'm_7 d n 0 N 00 0 ? O O W > C N Kayer and Brown. y' A Professional Corporation t. Liberty Loft' • 4 E. Liberty Avenue • Carlisle, PA 17013 (717) 243-7922 DONALD BAKER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL. ACTION - LAW NO. 99 - 5318 CIVIL TERM LISA K. BAKER, Defendant : IN DIVORCE, PRAECIPE TO TRANSMIT RECORD TO THE 13ROTFIONOTARY: Please 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: Certified Mail, Restricted Delivery, September 8, 1999, 3. Complete either Paragraph A or B. A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: By the Plaintiff, March 10, 2000; By the Defendant March 10, 2000. B. (1) Date of execution of the Plaintiffs affidavit required by Section 3301 (d) of the Divorce Code: none. (2) Date of service of the Plaintiffs affidavit upon the Defendant: none 3. Related claims pending: None 4. Complete either (a) or (b). A. Date and manner of service of the notice of intention to rile praecipe to transmit record, a copy of which is attached: none B. Date Plaintiff's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary: 7/12/99; Date March 11, 2000, Defendant's Waiver of Notice in 3301(c) Divorce was filed with the Prothonotary March 10. 2000. . Attorney for Pluinti fT P? 7 ?J 7 ? n r Om N A r p ? PU (DD y ~ A N A d m co Q n co ? • N . W O w D c m ' Kayer and Brown A' Professional Corporation ! [ Liberty Loft • 4 E,'Liberty Avenue L Carlisle, PA 17013 (717) 249-7922 Plaintiff vs. LISA K. BAKER, Defendant CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 -63JSCIVIL TERM IN DIVORCE NOTICE, TO DEFEND AND CLAIM RIGHTS YOU HAVE BEEN SUED IN COURT. II'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 maybe 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you [nay request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. James J. Kayer, Esquire Attorney for Plaintiff Liberty Loft 4 East Liberty Avenue Carlisle, PA 17013 (717) 243-7922 DONALD BAKER, Plaintiff VS. LISA K. BAKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 -, N7CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE COMES NOW, Plaintiff Donald Baker, through his attorney, James J. Kayer, Esquire and avers as follows: COUNT I - DIVORCE 1. Plaintiff is Donald Baker, an adult individual, whose current address is 321 Chestnut Street Mt. Holly Springs, Cumberland County, Pennsylvania, 17065 2. Defendant is Lisa K. Baker, an adult individual, whose current address 105 Willowview Drive, Cumberland County, Pennsylvania, 17013. 3. Plaintiff and Defendant have been bona tide residents of the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on March 12, 1977, Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce filed in this matter. 6. Plaintiff and Defendant are not members of the United States Armed Forces. 7. The marriage is irretrievably broken, and the parties are proceeding under Section 3301(c) and Section 3301(d) of the Divorce Code. 8. 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. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Respectfully submitted, i JameO -Kay Esouire Liberty Loft 4 Liberty Avenue Carlisle, PA 17013 (717) 243-7922 Date: August X 1999 VERIFICATION OF PLEADINGS 1 have read the statements made in this document and to the extent that it is based upon information which has been given to me it is true and correct to the best of my knowledge, information and belief. I have executed this document on behalf of my client who is currently unavailable to execute a veri.°ication. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworu falsification to authorities. Date: ( / Z 7 / I Kayerl Lsire for M! tint f/Petitioner F " = .4 S Y O ?,' ? !? I L LL I_ O O CD V E Om N ? O N j' f N D A N ? p? .? m 'S d v r o N a m - W ° O 'er < o o m ? w c m l ti,d"J ,.Kayer and :Brown A Professional Corporation Liberty Loft •'4 E. Liberty Avenue 9 Carlisle. PA 17013 (717) 243-7922 DONALD BAKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW NO. 99 - 5318 CIVIL TERM LISA K. BAKER, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVOT UNDER S 3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerring alimony, division of property, lawyer's fees or expenses if 1 do not claim them before a divorce is granted. 3. I understand that 1 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. AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 30, 1999 2. 'rhe marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 1 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 verify that the statements made in this Waiver and 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:[nAnc 17 10 .2000 1 C ONALDBAKER ,/ N ? h- ILp r Ci ac ?ti t•' [r. ? 75 r Z ti C) O U r 0m 4 - u d N r o C N• ~ A N A ' m m _ a o 1,3 ff 0 -8 m N O > 3 0 ? w c N M1 Kayer and Brown r A Professlo.n l Co a rporatlon Llberty Loft. • 4 E. Liberty Avenue • Carlisle; PA 17013 :. (717) 243-7922 . DONALD BAKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW NO. 99 - 5318 CIVIL TERM LISA K. BAKER, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVOI UNDER S 3301(c) OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 understand that 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that 1 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. AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 30, 1999 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. 1 consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 1 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 verify that the statements made in this Waiver and 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: 2000 LI A K. BAKER %Y Ili.. (V 1-?' 1.. 1 CL .. 1 U V . :L r v n m r 0 0 N N• a M N m 3 G C4 a N 0 3 A C C < O W > C m Liberty Lott • 4 E; DONALD BAKER, Plaintiff VS. LISA K. BAKER, Defendant venue • Cdrlisl"PA. 17013 t3-7922 ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - 5318 CIVIL TERM IN DIVORCE. AFFIDAVIT OF SERVICE BY MAIL PURSUANT TO Pa. R.C.P. 1920 4(a)(1)(ii) COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. I, James J. Kayer, Esquire, being duly sworn according to law, deposes and says that he is the attorney for Plaintiff, DONALD BAKER, and that he did serve a true and correct copy of the Notice to Defend and Complaint in Divorce that was filed in the above matter, by U.S. Mail, postage prepaid, certified with restricted delivery, return receipt requested, unto the Defendant, LISA K. BAKER, on September 8, 1999. The return receipt is attached hereto. Swom to and subscribed before me day of Se tei ber, 1999^. '4-L0,11 f A -0 1 1 ary Public NOTARIAL SEAL DENISE PINAMONTI. Notary Public Carlisle Borough, Cumberland County M Commission Expires Nov. 20, 2000 •s:prlteNe Itefes 1 and/or 2 for WOXW W earNp•. acornpde Ibnr 3.4a. and eb. •Prbe year name uM address. fM .wee Gaee mart es tltes we esn return 06 ddiro •Aaaw t ion to aw trove of the mrpra. or on aN bark a pace does not die -Rea. R..* Requested'. the rrreq.o• bamw ar snide rwrrov. The Return Resdpt vas ettow to whn aur artltle was delivered and the dYa delkwo. des _ .2 (?z I also wish to receive eN fooovArtp services (ices eg extrafes): 1. ? Addraaeea'a Ac&en 2.0-ReetrIcted Delivery I Corotnpo tnWterfor fee. 4a. Article Number _ 4b Service Type ? Registered M-CsrtlAed ? Express Mao ? Ir d umd 2 Return R$cW for Wollaadn ? ODD 7. Date of Delivery o Addmsue's e Fo d , j . n r yfffili arJ and fee to pw) ??dY58SD7Bg17D omest c etum ece pt.