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Home My WebLink About07-6905Allen Lee Baker, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Sabryna West, Defendant :NO. 07- loq6S* CIVIL TERM 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. 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, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (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. Allen Lee Baker, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Sabryna West, G gOs Defendant : NO. 07- CIVIL TERM DIVORCE COMPLAINT The plaintiff, Allen Lee Baker, by his attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa.C.S. W301(c) AND 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Allen Lee Baker, who currently resides at 84 Countryview Estates Newville, PA 17241, Cumberland County, since approximately 2005, with the exception of August and September in 2007. 2. Defendant is Sabryna West, who currently resides at 3780 Spring Road, Lot 2, Carlisle, Cumberland County, PA 17013, since approximately 2006. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. Plaintiff and Defendant were married on September 18, 2007 at Carlisle, Cumberland County, Pennsylvania. 5. Plaintiff and Defendant have lived separate and apart since October 2, 2007. 6. There have been no prior actions for divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 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. Ann Ja"64*-ZDtnou Pipkin Certified Legal Intern A Z?JJ- lfi-- , - ROB INS THOMA M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date Plaintiff Allen Lee Baker C? ? -n Allen Lee Baker, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN CUSTODY Sabryna West a? -4-g45 Defendant NO. W- CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Allen Lee Baker, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Respectfully submitted, Date" B ' Ann Dimitriou Pipkin Certified Legal Intern -)L .6 ROBE S THOMAS M. PLACE ANNE MACDONALD-FOX LUCY JOHNSTON-WALSH MEGAN RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street + n? Carlisle, PA 17013 .... ., 717-243-2968 i cn ?- >:- -ca Allen Lee Baker, Plaintiff v Sabryna West, Defendant : IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW DIVORCE : No. 07-6905 CIVIL TERM To The Prothonotary: PRAECIPE TO REINSTATE COMPLAINT Please reinstate the Divorce Complaint at the above-captioned docket. Ann Dimitriou Pipkm ?? Certified Legal Intern Anne ac ona Fox, E Supervisi Attorney Date: l 'O71-G P i"^.} :! f ^? ? ... { ! ?. . tl. 1 Allen Lee Baker, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW DIVORCE Sabryna West , Defendant NO. 07 - 6905 CIVIL TERM CERTIFICATE OF SERVICE I, Ann Dimitriou Pipkin, Certified Legal Intern, Family Law Clinic, hereby certify that I served a true and correct copy of the Divorce Complaint on Sabryna West, residing at 3780 Spring Road, Carlisle Pa 17013, by depositing a copy of the same in the United States mail, certified, restricted delivery, return receipt requested, postage prepaid. Service was complete upon receipt by Sabryna West, on the 29th day of January 2008 as evidenced by the attached green card. Ann Dimitriou Pipkin ertified Legal Intern ('t_z Anne ac onald-Fox, Esq. Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 C) t=2 Cl r jitl ftm DO" to tf?il ! ... ? AWtt so no 4 Mach "ft OW to Ow bo* eflWOUIROMW W O ` ' f.. '. 17 1. fYY4# AftemadlM M mMr iMlkit?t bMow: O No West a N. ,10,rl XD ? CI figoNMS ? Reoso for mwowx o E13 1 wAw to 0 C.o.D. I& ReW*W ffift Foo PS Form 3811, February 2w4 bNNtewe"aw ftwo t 102505-02-WI540 Allen Lee Baker, : IN THE COURT OF COMM N PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Sabryna West, Defendant : NO. 07-6905 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code w?s filed on November 15, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 the decree. I verify that the statements made in this affidavit are true and false statements herein are made subject to the penalties of 18 Pa.C.S falsification to authorities. Date 4 4 6 Wu? est, I understand that relating to unsworn Q AR? Allen Lee Baker, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. Sabryna West, Defendant CIVIL ACTION - LAW IN DIVORCE NO. 07-6905 ENTRY OF A DIVORCE DECREE UNDER 43301(c) 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 c 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 and that a copy of the decree will be sent to me immediately after it is filed prothonotary. I verify that the statements made in this affidavit are true and c false statements herein are made subject to the penalties of 18 Pa.C.S. falsification to authorities. Date P C1 - C);? sqh:?:? wyak Sabryna West, Defendant , TERM f property, lawyer's d by the Court the I understand that relating to unsworn . ? 2 ? . ? ? ? . _ .?. "?, ? c» Allen Lee Baker, : IN THE COURT OF COMM N PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Sabryna West, Defendant : NO. 07-6905 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code w?s filed on November 15, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 the decree. I verify that the statements made in this affidavit are true and correc . I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §490 , relating to unsworn falsification to authorities. DateLJ-? Lee Baker, `° ?.'` xs _,;: ? ?? ? ?` ? ?'' j`rt ? .? Allen Lee Baker, Plaintiff V. Sabryna West, Defendant IN THE COURT OF COMM CUMBERLAND COUNTY, CIVIL ACTION - LAW IN DIVORCE PLEAS OF JNSYLVANIA : NO. 07-6905 CIVIC, TERM ENTRY OF A DIVORCE DECREE UNDER 43301(c) 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 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 and that a copy of the decree will be sent to me immediately after it is filed prothonotary. I verify that the statements made in this affidavit are true and c false statements herein are made subject to the penalties of 18 Pa.C.S. falsification to authorities. Date property, lawyer's ;d by the Court the I understand that relating to unworn Baker, Plaintiff ra ; -z'c ?- ? ?:;r; - ?=? ?? ? ? ? ? o ? ? Allen Lee Baker, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION- LAW V. : IN DIVORCE AND CUSTO Y Sabryna West, Defendant : No. 07-6905 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the ourt for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: Served on Defen t by U.S. mail, certified, restricted delivery, return receipt requested, postage prepaid. Serv ce was complete upon receipt by Sabryna West, on January 29, 2008. 3. Date of execution of the affidavit of consent required by §3301 (q) of the Divorce Code: by Plaintiff- April 29, 2008; by Defendant - April 29, 2008. 4. Related claims pending: none 5. Date plaintiff s Waiver of Notice was filed with the Prothonotary Date defendant's Waiver of Notice was filed with the Prothonota D to ianne Yacavo Certified Legal May 6, 2008. (: May 6, 2008. Mega 'esme er, Esq. Supervising Attorneys FAMILY LAW CI 45 N. Pitt Street Carlisle, PA 17 13 717-243-2968 Fax: 717-243-3'31 Attorneys for Pl -n C -?c ? - °, C W v -Iqq Allen Lee Baker, Plaintiff V. Sabryna West, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 07- 6905 CIVIL TERM AFFIDAVIT OF SERVICE I, Megan Riesmeyer, hereby certify that I personally served a true and correct copy of the Plaintiff s Affidavit of Consent and Waiver of Notice, Defendant's Affidavit of Consent and Waiver of Notice and Praecipe to Transmit Record, on Sabrina West, at: 3780 Spring Road, Carlisle, PA 17013, via first class, U.S. mail, postage prepaid on May 7, 2008. l Date: Meg esmeyer 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 ? ??- q ??M, c? ?? R- ?:. -'? ? `7 .?, ? .; ? .... ? { . N "tom C` --- ...C ._ .c IN THE COURT OF COMMON PLEAS Allen Lee Baker, OF CUMBERLAND COUNTY STATE OF PENNA. Plaintiff VERSUS Allen Lee Baker DECREE IN DIVORCE AND NOW, I q,( , IT IS ORDERED AND DECREED THAT AND No. 6905 07 , PLAINTIFF, Sabryna West ARE DIVORCED FROM THE BONDS OF MATRIMONY. ,DEFENDANT, 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; ATTEST: J. PROTHONOTARY 0 /7---Pw XP4?w-? J/ - "5;- lr'e? 4QV -r?'