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Home My WebLink About09-2305RANDALL K. BAKER, PLAINTIFF : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. Oq -x.305 Civil Ter % JULIE A. BAKER, : DIVORCE ACTION DEFENDANT 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 at (717) 240-6195, Cumberland County Courthouse, One Courthouse Square, Carlisle, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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 S. Bedford Street Carlisle, PA 17103 (717) 240-6195 James G. Nealon, III, Esquire NEALON LAW FIRM, P.C. Attorney I . D. #46457 2411 North Front Street Harrisburg, PA 17110 jnealon@nealon-law.com (717) 232-9900 RANDALL K. BAKER, PLAINTIFF V. JULIE A. BAKER, DEFENDANT : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . NO. DIVORCE ACTION COMPLAINT DIVORCE UNDER SECTION 3301(c) OR SECTION 3301(d) OF THE DIVORCE CODE 1. Plaintiff, Randall K. Baker, is an adult individual who currently resides at 37 Ashton Street, Carlisle, PA 17015. 2. Defendant, Julie A. Baker, is an adult individual who currently resides at 249 Walnut Street, Carlisle, PA 17013. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of the Complaint. 4. The Plaintiff and Defendant were married on September 8, 1988, in Carlisle, PA. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a Decree of Divorce. WHEREFORE, Plaintiff, Randall K. Baker, urges this Honorable Court to enter a Decree of Divorce. Respectfully 6ybmi4d, NEALON LAW FM P. By: James G. Nealon, III, Esquire Attorney I.D. #46457 2411 North Front Street Harrisburg, PA 17110 (717) 232-9900 Date: April 8, 2009 r VERIFICATION I, Randall K. Baker, verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. 4904 relating to unsworn falsification to authorities. RANDALL K. BAKER C Dated: `f 5 11 CERTIFICATE OF SERVICE AND NOW, this 8th day of April 2009, 1 hereby certify that I have served the foregoing Exceptions To Support Master's Report and Recommendations on the following by depositing a true and correct copy of same in the United States mail, postage prepaid, addressed to: Samuel L. Andes, Esquire 525 North 12th Street Lemoyne, PA 1740, James G. Nealon, III OF TH o NOTAFty 2099 APR 13 PM 3: 22 OSS. 9o Pty A m/ fx;* SM RANDALL K. BAKER, IN THE COURT OF COMMON PLEAS PLAINTIFF ; CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 09-2305-CV JULIE A. BAKER, DIVORCE ACTION DEFENDANT ACCEPTANCE OF SERVICE I accept service of the Complaint under Section 3301(c) or Section 3301(d) of the Divorce Code and I certify that I am authorized to do so. 2'6 r &0 Date 4ai-m L. Andes, Esquire FLEI-) nT TP9 20H 51a i^ ..3 it. t')' RANDALL K. BAKER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 2009-2305 Civil Term JULIE A. BAKER, CIVIL ACTION -LAW Defendant IN DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter the appearance of Max J. Smith, Jr., Esquire as counsel for Randall K. Baker, Plaintiff in the above-captioned matter. A?"' D M h ate: arc 18, 2011 Max J. Smith, Jr., quire I.D. No. 32114 James, Smith, Dietterick & Connelly LLP P.O. Box 650 Hershey, PA 17033 (717) 533-3280 s...,.j RANDALL K. BAKER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 2009 -2305 CIVIL TERM JULIE A. BAKER, : CIVIL ACTION - LAW Defendant : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER ® Plaintiff ❑ Defendant, moves the court to appoint a master with respect to the following claims: ® Divorce ❑ Annulment ❑ Alimony ❑ Alimony Pendente Lite and in support of the motion states: ® Distribution of Property ❑ Support ❑ Counsel Fees ❑ Costs and Expenses to � 1. Discovery is complete as to the claim(s) for which the appointment of ma term Y P () PP its requested. 2. The non - moving party ® has ❑ has not appeared in the action c ; ❑ personally ® by counsel, Samuel L. Andes, Esquire. 3. The statutory ground(s) for divorce ® is ❑ are irretrievable breakdown. 4. Delete the inapplicable paragraph(s): (c) The action is contested with respect to the following claims: equitable distribution. 5. The action ❑ involves ® does not involve complex issues of law or fact. 6. The hearing is expected to take (hours) one -half (days). 7. Additional information, if any, relevant to the motio Date: April 15, 2014 Name: Max J. Smith, Jr., Es ice Attorney for ® Plaintiff ❑ Defendant AND NOW , 20 Esquire, is appointed master with respect to the following claims: BY THE COURT: J. RANDALL K. BAKER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVA1\JJ4 vs. : NO. 2009-2305 Civil Term cr, -- JULIE A. BAKER, : CIVIL ACTION - LAW r- Defendant : IN DIVORCE > 3> G NOTICE --< You are hereby notified to file a written response to the enclosed Petition within twenty (20) days from service hereof or a judgment may be entered against you. . SMITH, J Esquire Attorney for Plainti f P.O. Box 650 Hershey, PA 17033 (717) 533-3280 142 all ierfr 3 OV,r-z4, Max J. Smith, Jr., Esquire Attorney I.D., #32114 Jessica E. Lowe, Esquire Attorney I.D. #208041 Alexis M. Miloszewski, Esquire Attorney I.D. #208931 JSDC Law Offices P.O. Box 650 Hershey, PA 17033 Telephone: 717-533-3280 Fax: 717 -533 -2795 e -mail: mjs@jsdc.com RANDALL K. BAKER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2009-2305 Civil Term JULIE A. BAKER, : CIVIL ACTION - LAW Defendant : IN DIVORCE PETITION FOR EQUITABLE DISTRIBUTION OF PROPERTY AND NOW comes the Plaintiff, RANDALL K. BAKER, by his attorney MAX J. SMITH, JR., Esquire, and respectfully states as follows: 1. Plaintiff filed a divorce Complaint pursuant to the no -fault provisions of the Pennsylvania Divorce Code on April 13, 2009, entered to the within term and number. 2. There has been no responsive pleading filed to date in this matter by the Defendant. 3. During the course of the marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution by the court. 4. Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff respectfully requests that at such time as a divorce Decree may be entered, equitably divide the marital property remaining between the parties. Date: April 15 , 2014 Respectfully submitted, MAX J. SMITH, JR., uire I.D. No. 32114 JESSICA E. LOWE, Esquire I.D. No. 208041 ALEXIS M. MILOSZEWSKI, Esquire I.D. No. 208931 JSDC Law Offices P.O. Box 650 Hershey, PA 17033 (717) 533 -3280 I verify that the statements made in this Petition 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 unsworn falsification to authorities. /44,v RANDALL .BAKER RANDALL K. BAKER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 2009-2305 Civil Term JULIE A. BAKER, : CIVIL ACTION - LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this 1.54^ day of April, 2014, I, MAX J. SMITH, JR., Esquire, Attorney for Plaintiff, hereby, certify that I have this day sent a copy of Petition for Economic Relief by depositing a copy of the same in the United States mail, postage prepaid, at Hershey, Pennsyl- vania, addressed to: Samuel L. Andes, Esquire P.O. Box 168 Lemoyne, PA 17043-0168 MAX J. SMITH, JR., !.0 ire I.D. No. 32114 JESSICA E. LOWE, Esquire I.D. No. 208041 ALEXIS M. MILOSZEWSKI, Esquire I.D. No. 208931 JSDC Law Offices P.O. Box 650 Hershey, PA 17033 (717) 533-3280 RANDALL K. BAKER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2009-2305 CIVIL TERM JULIE A. BAKER, : CIVIL ACTION - LAW Defendant : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER El Plaintiff DI Defendant, moves the court to appoint a master with respect to the following claims: Divorce 0 Annulment CI Alimony El Alimony Pendente Lite 4 Distribution of Property CI Support CI Counsel Fees ID Costs and Expenses and in support of the motion states: 1. Discovery is complete as to the claim(s) for which the appointment of requested. 2. The non-moving party El has 11) has not appeared in the action El personally i4 by counsel, Samuel L. Andes, Esquire. 3. The statutory ground(s) for divorce El is 0 are irretrievable breakdown. 4. Delete the inapplicable paragraph(s): (c) The action is contested with respect to the following claims: equitable distribution. 5. The action 0 involves El does not involve complex issues of law or fact. 6. The hearing is expected to take (hours) one-half (days). 7. Additional information, if any, relevant to the motio Date: April 15, 2014 AND NOW Name: Max J. Smith, Jr., Es ife Attorney for El Plaintiff 0 Defendant /(e , 20 Pi atehlAsquire, CZ, 27. Cul r>) is appointed master with respect to the following claims: t2 .2Z4tLrA-e._ VitiVAUHH3d, UW103 aHymntan3 *8 a $00 .• • TYit AO FILED -OFFICE OF THE HE PRO1rHONOARY 2111JUN-2 hint: 57 CUMBERLAFND COUNTY PENNSYLVANIA RANDALL K. BAKER, ) IN THE COURT OF COMMON Plaintiff ) PLEAS OF CUMBERLAND ) COUNTY, PENNSYLVANIA ) ) CIVIL ACTION - LAW ) ) NO. 2009-2305 CIVIL TERM vs. JULIE A. BAKER, Defendant ) ) IN DIVORCE DEFENDANT'S ANSWER TO PLAINTIFF'S PETITION FOR EQUITABLE DISTRIBUTION OF PROPERTY AND NOW comes the above-named Defendant, by her attorney Samuel L. Andes, and makes the following Answer to Plaintiff's Petition: 1. Admitted. 2. Admitted. By way of further answer, Defendant states that the Rules of court do not require a responsive pleading. 3. Admitted. 4. Admitted. WHEREFORE, Defendant prays this court to equitably divide and distribute the marital property and the marital obligations of the parties. Samuel L. Andes Attorney for Defendant Supreme Court ID # 17225 525 North 12th Street P.O. Box 168 Lemoyne, PA 17043 (717) 761-5361 I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: �U.,cU-tom • 4ozAe-c- LIE A. BAKER CERTIFICATE OF SERVICE I hereby certify that I served an original of the foregoing document u . on counsel for the Plaintiff herein by regular mail, postage prepaid, addressed as follows: Date: ij/g3/j L Max J. Smith, Jr., Esquire P.O. Box 650 Hershey, PA 17033 . W Amy M. arkins Secretary for Samue L. Andes RANDALL K. BAKER, Plaintiff vs. JULIE A. BAKER, Defendant LED OF-r=i Cs C ; THE PROTHONOTARY n„IliJUN-2 All [I:5 CUMBERLAND COUNTY PENNSYLVANIA ) ) ) ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2009-2305 CIVIL TERM IN DIVORCE DEFENDANT'S PETITION FOR ECONOMIC REIiIEF AND NOW comes the above-named Defendant, by her attorney, Samuel L. Andes, and makes the following Petition for Economic Relief: COUNT I - EQUITABLE DISTRIBUTION 1. During the course of the marriage, the parties have acquired numerous items of property, both real and personal, which are held in joint names and in the individual names of each of the parties hereto. WHEREFORE, Defendant prays this Honorable Court, after requiring full disclosure by the Plaintiff, to equitably divide the property, both real and personal, ownd by the parties hereto as marital property. COUNT II - ALIMONY 2. Defendant, although employed, does not have sufficient income to meet her reasonable living needs or to continue to live in the lifestyle enjoyed by the parties during the time they resided together. 3. Plaintiff enjoys a substantial income from which he can afford to pay alimony. 4. Defendant cannot meet her reasonable needs without an award of alimony following the divorce. 4 es 0 0 f d 19 93v7 �g-319647 WHEREFORE, Defendant prays this court to award her alimony following the divorce decree. COUNT III - ALIMONY PENDENTE LITE 5. Defendant is without sufficient income to support and maintain herself during the pendency of this action. 6. Plaintiff enjoys a substantial income and is well able to contribute to the support and maintenance of Defendant during the course of this action. WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay her reasonable alimony pendente lite during the pendency of this action. COUNT IV - COUNSEL FEES AND EXPENSES 7. Defendant is without sufficient funds to retain counsel to represent her in this matter. 8. Without competent counsel, Defendant cannot adequately prosecute her claims against Plaintiff and cannot adequately litigate her rights in this matter. 9. Plaintiff enjoys a substantial income and is well able to bear the expense of Defendant's attorney and the expenses of this litigation. WHEREFORE, Defendant prays this Honorable Court to order Plaintiff to pay the legal fees and expenses incurred by Defendant in the litigation of this action. el L. An e es Attorney for Defendant Supreme Court ID 17225 525 North 12th Street P.O. Box 168 Lemoyne, PA 17043 (717) 761-5361 • I verify that the statements made in this document are true and correct. I understand that any false statements in this document are subject to the penalties of 18 Pa. C.S. 4904 (unsworn falsification to authorities). Date: 4/64 LIE A. BAKER