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KATRINA BAUGHMAN, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. NO. d~"~aa ~ CIVIL
CIVIL ACTION -LAW
BRANDON BAUGHMAN,
Defendant IN DIVORCE
NOTICE TO DEFEND
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 mamage counseling. A list of marriage counselors is available in
the Office of the Prothonotary at the Cumberland County Court House, Carlisle,
Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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, PA 17013
(717) 249-3166 or 800-990-9108
SAIDIS, FLOWER & LIN[~AY
SAIDIS,
FIAWEIt ~
LINDSAY
26 West High Street
Cazlisle, PA
Carol J. Lindsay,'
Attorney Id. ~`
26 West High reel
Carlisle, PA 17013
(717) 243-6222
Counsel for Plaintiff
KATRINA BAUGHMAN, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
v. NO. ~ ~~bz a ~ CIVIL
CIVIL ACTION -LAW
BRANDON BAUGHMAN,
Defendant IN DIVORCE
COMPLAINT IN DIVORCE UNDER
SECTION 3301(c) or (d) OF THE DIVORCE CODE
1. The Plaintiff is Katrina Baughman, an adult individual, currently residing at 222
Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania 17043.
2. The Defendant is Brandon Baughman, an adult individual, currently residing at
6870 Wentzville Road, Enola, Cumberland County, Pennsylvania 17025.
3. The Plaintiff and Defendant both have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this
Complaint.
4. The Plaintiff and Defendant were married on November 17, 2007 in
Mechanicsburg, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the
parties in this or in any other jurisdiction.
6. Neither the Plaintiff nor the Defendant are members of the United States
Armed Forces or its Allies.
7. The Plaintiff has been advised that counseling is available and that she has
SAIDIS,
FIAWER SZ
LIlVDSAY I,
26 West High Street
Carlisle, PA
the right to request that the court require the parties to participate in counseling.
8. Plaintiff and Defendant are citizens of the United States of America.
9. The parties' marriage is irretrievably broken.
10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety
(90) days from the date of service of this Complaint, consent to this divorce.
WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance
with §3301 (c) or (d) of the Pennsylvania Divorce Code.
Respectfully submitted,
SAIDIS, F1OWER & LIIyQSAY
Supreme C urt I o. 44693
26 West Hig treet
Carlisle, PA 17013
(717) 243-6222
Counsel for Plaintiff
Datedd: 1 f 5
SAIDIS,
FLOWER ~
LINDSAY
26 West High Street
Carlisle, PA
KATRINA BAUGHMAN,
Plaintiff
v.
BRANDON BAUGHMAN,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. CIVIL
CIVIL ', ACTION -LAW
IN DIVORCE
VERIFICATION
I verify that the statements made in the foregoing document 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 falsifications to authorities.
KATRINA BAUGHMAN
Date: - I ~ Z ~ a
SAIDIS,
FLOWER SZ
LIlVDSAY
26 West High Street
Cazlisle, PA
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