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Home My WebLink About09-2324 KIMBERLY K. BAKER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 09- .232Y CIVIL TERM JEFFREY A. BAKER, Defendant 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. When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may 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 32 SOUTH BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 t r f KIMBERLY K. BAKER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 09- CIVIL TERM JEFFREY A. BAKER, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(C ) OR (D) OF THE DIVORCE CODE Plaintiff, Kimberly K. Baker, by her attorney, Lindsay D. Baird, Esquire, sets forth the following: 1 Plaintiff, Kimberly K. Baker, is an adult individual residing at 172 East Pomfret Street, Carlisle, Pennsylvania 17013. 2 Defendant, Jeffrey A. Baker, is an adult individual residing at 311 Airy View Road, Apt. 8, Shermans Dale, Pennsylvania 17090. 3 The parties were married on July 21, 2001, in Jamaica. 4 Defendant has lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the commencement of this action. 5 This action is not collusive. 6 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 7 In accordance with Section 3301(c ) of the Divorce Code, the marriage between the parties 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, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. -f?.LG t ? (mil GAL.= dsay D. Bair "squire Attorney for the Plaintiff 37 S. Hanover Street Carlisle, PA 17013 717 - 243-5732 I verify that to the best of my knowledge.and belief, the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS §4904 relating to unsworn falsification to authorities. Kim rly K. Bak , Plai iff 0 FILED-40I i SCE OF THEE RROTH')NIOTARY 2009 APR 14 AM 10: 4 3 CUB, '-', NTY PENNS YI VAINA. 33 Sv JCL CK -4L 1 Sg R?A A2.21043 KIMBERLY K. BAKER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : No. 09- CIVIL TERM JEFFREY A. BAKER, Defendant : IN CUSTODY COMPLAINT FOR CUSTODY 1. The plaintiff is Kimberly K. Baker, residing at 172 East Pomfret Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Jeffrey A. Baker, residing at 311 Airy View Road, Apt. 8, Shermans Dale, Pennsylvania, 17090. 3. Plaintiffs seek primary custody of the following child: Name Zachary A. Baker Present Residence 6ge 172 East Pomfret Street, Carlisle 2 The child was not born out of wedlock. The child is presently in the primary custody of Mother. During the past two years, the child has resided with the following persons and at the following addresses: Person(s) Address Dates Kimberly K. Baker 172 East Pomfret St, Carlisle, PA 1/24/09 - present Kimberly K. Baker & Jeffrey A. Baker 10 Sussex Drive, Carlisle, PA 17013 2/20/07 - 1/24/09 The mother of the child is Kimberly K. Baker She is married. The father of the child is Jeffrey A. Baker. He is married. 4. The plaintiff currently resides with the following person: Name Zachary A. Baker Relationship Subject child 5. The defendant currently resides with the following person: Name None Relationship NIA 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 7. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) Plaintiff can provide the child with a home with adequate moral, emotional and physical surroundings as required to meet the child's needs; b) Plaintiff is willing to accept primary custody of the child; c) Plaintiff continues to exercise parental duties and enjoys the love and affection of the child. 8. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. All other persons, named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim NONE Wherefore, plaintiff requests the court to grant primary custody of the child to her. I ''hdsay Dare Wfi, Esquire 37 South Han 64r Carlisle, PA 17013 Attorney for Plaintiff I verify that to the best of my knowledge and belief, the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS §4904 relating to unsworn falsification to authorities. Kim rly K. Ba iai Fly ° t= cE OF P-1,11 ROTIKOMOTAPY 2009 APR 14 AM 10: 4 5 ?NTY q 102. 00 ?4?- a-1 CK:-Ik l5$ j?7.*L .2,?3 Uo3 KIMBERLY K. BAKER IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 2009-2324 CIVIL ACTION LAW JEFFREY A. BAKER IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Tuesday, April 21, 2009 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before John J. Mangan, Jr., Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Friday, May 22, 2009 at 10:00 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT. By: /s/ John j. Man an r. Es q. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 OF FI EJ )- *y P Y"; d r- y : i Y &r /l"j' /j2lL yap os e? .14? "``` at KIMBERLY K. BAKER, Plaintiff V. JEFFREY A. BAKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 09- 2324 CIVIL TERM IN CUSTODY STIPULATION FOR CUSTODY STIPULATION made this day of 1 c , 2009, between Kimberly K. Baker, hereinafter referred to as Mother, and Jeffrey A. Baker, hereinafter referred to as Father. WHEREAS, the above-named Mother and Father had born to them the following child on the followinq date: Zachary A. Baker February 20, 2007 AND WHEREAS, the above-named Mother and Father desire to enter into a Stipulation as to the custody of the Zachary: NOW, THEREFORE, in order to effectuate the above purpose, the above-named Mother and Father hereby stipulate that: 1. Mother and Father shall share legal custody of the child. 2. Mother shall have primary physical custody of the child. 3. Father shall have periods of partial custody as the parties agree. 4. The parties agree that the other parent shall have first refusal to babysit Zachary. 5. Mother and Father shall allow the other to meet and approve any third party babysitter. 6. The parties agree not to utilize the Court for custody matters. TO THIS PURPOSE, The parties hereto intend to be legally bound by the terms of this Stipulation and desire to have the Stipulation entered as an Order of Court. Witness: ndsay D Baird, Es uire Kimb rly K. Ba e , Mo r ? A L?. b, L Jeffrey A. B fil at r PAH)---YFiCE OF TNT P O :. 2009 JUN 3Q Ali 9: 25 cutk, F KIMBERLY K. BAKER, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA ~, : No. 09- 2324 CIVIL TERM JEFFREY A. BAKER, Defendant IN CUSTODY ORDER OF COURT AND NOW, this L~ ~ day of July, 2009, upon consideration of the attached custody stipulation with respect to the child, Zachary A. Baker, born February 20, 2007, the terms of the stipulation are entered as an order of court. cc: 'ndsa D. Baird Es uire Y 4 r. Jeffrey A. Baker l :d~ ~ ~E.S ~~. t ~c~, Ala, f oq `~ BY THE COURT, OF ~ ~C~~T~-'~',,~~~~~;RY 2Da9 JUL -2 P~ 12~ Q 6