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Home My WebLink About09-4980I Kimberly L. Bailey, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION LAW_ -- V. No. 09- q??L) C.?. j c-e" Lloyd E. Bailey, Defendant IN DIVORCE NOTICE 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 the Cumberland County Court House, High and Hanover Streets, Carlisle. 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, PA 17013 Phone: (717) 249-3166 (800) 990-9108 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. F1 Kimberly L. Bailey, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION L W vi. No. 09- y4 ?r0 "?"- Lloyd E. Bailey, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Kimberly L. Bailey, who currently resides at 401 North Bedford Street, Carlisle, Cumberland County, Pennsylvania, since on or around October 2008. 2. Defendant is Lloyd E. Bailey, who currently resides at 1941 Maplewood Drive, Carlisle, Cumberland County, Pennsylvania, since on or around 2001. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on, March 21, 1992 in Carlisle, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 6. The marriage is irretrievably broken, and the parties separated on April 30, 2007. 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 in Divorce. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be just and appropriate. By. mberly L. ley, pro se VERIFICATION I, Kimberly L. Bailey, verify that the statements made in this Complaint 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 falsification to authorities. Date: :7 -,L2 - O o i berly L. Bail , Plaintiff Assisted by: Vincent M. Monfredo, Esquire Rominger and Associates 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 2009 ,fit °L Z2 pH 3: Pal„? ,Y ? ?+.•? 7 4Vrijel,,f? -7. F. Kimberly L. Bailey IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVANIA V. NO. 09- 111kJ CIVIL TERM Lloyd E. Bailey Defendant IN DIVORCE PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, Kimberly L. Bailey Plaintiff, to proceed in forma au eris. I, Vincent M. Monfredo, attorney for the party proceeding in forma au eris, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. Vincent M. Monfredo, Esquire Attorney for Plaintiff Rominger Law Office 155 S. Hanover Street Carlisle, PA 17013 (717) 241-6070 P1?EC)???PtCE 2009 JUL 22 PM 3' 29 pE,Ntq1Q1yLVANMA KIMBERLY L. BAILEY, IN THE COURT OF COMMON PLEAS OF Plaintiff, CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION -LAW LLOYD E. BAILEY, NO. 09-4980 Defendant. IN DIVORCE ANSWER TO COMPLAINT UNDER SECTION 3301(cl OR 33011d) OF THE DIVORCE CODE 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Defendant is without knowledge as to whether Plaintiff has been advised of the availability of counseling. Defendant does not desire counseling. 8. No answer required. WHEREFORE, Defendant Respectfully requests this Honorable Court to enter a Decree in Divorce and such other Orders as may be appropriate. NEW MATTER COUNT II -EQUITABLE DISTRIBUTION 9. Paragraphs 1 through 8 are incorporated herein by reference as if fully set forth. 10. Plaintiff and Defendant possess real marital property which is subject to equitable distribution by this Honorable Court. 11. It is believed that the parties will reach a complete agreement as to distribution of the marital property and that a Marital Settlement Agreement, signed by the parties, will be forthcoming. WHEREFORE, Defendant requests this Honorable Court to incorporate but not merge the forthcoming Marital Settlement Agreement into the Divorce Decree; and if the parties cannot reach an agreement, to equitably distribute the marital property after an inventory and appraisement has been filed by the parties. Respectfully Submitted, TURD LAW OFFICES 0~~1 a/o9 Date Lori drew nyder, Esq. P D 2 199 8 S. Pitt reet ,OaFltsi~ PA 17013 717-245-9688 Attorney for Defendant VERIFICATION I, Lloyd E. Bailey, verify that the statements contained in the Answer to the Complaint are true and correct, to the best of my knowledge and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904 relating to unsworn falsification to authorities. z~~ ~ e~ ~J Dat LI .Bailey CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Answer to Complaint in Divorce on Vincent M. Monfredp, Esquire, by depositing same in the United States Mail, first class, postage pre-paid on the Twelfth day of August, 2009, from Carlisle, Pennsylvania, addressed as follows: Vincent M. Monfredo, Esquire Rominger and Associates 155 South Hanover Street Carlisle, PA 17013 TURCI~~GOF t n A re Snyder, Esquire South reet Carlisle, PA 7013 phone: (71 ) 245-9688 717 45.2165 Attorney for Defendant ~} ~f~ _ ~~ ~i"~~ ~ ~;~ f'-.~ ; ~/ v T`, . . ~ a--G . UD ~~ Q.~ y ~`c. ~o ~~s+. ~'~ ~-~ 9' 13 7 v KIMBERLY L. BAILEY, Plaintiff, V. LLOYD E. BAILEY, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-4980 IN DIVORCE ORDER OF COURT AND NOW, this 3 1 S? day of A?Qys 2011, upon consideration of the within Petition, a Rule is issued upon Defendant, Lloyd E. Bailey, and Plaintiff, Kimberly L. Bailey, to show cause why Lorin A. Snyder, Esquire, should not be granted leave to withdraw as legal counsel for the Defendant, Lloyd E. Bailey. Rule returnable I S day after service. BY THE COURT: J . Distribution: Vincent M. Monfredo, Esquire, Attomey for Plaintiff v Lorin A. Snyder, Esquire, Attomey for Defendant Lloyd E. Bailey, Defendant r-. ?Vb 3r- -n c? co W ;rY f I KIMBERLY L. BAILEY, Plaintiff, V. LLOYD E. BAILEY, Defendant. AND NOW, this IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 09-4980 IN DIVORCE ORDER OF COURT t 'L(JAD day of Sc.Q? e?"?Oar , 2011, upon consideration of the within Motion: 1. The Rule entered on August 31, 2011, on Lorin A. Snyder, Esquire's Petition to Withdraw as Legal Counsel for Defendant is made absolute. 2. Lorin A. Snyder, Esquire, is hereby granted leave to withdraw as legal counsel and attorney of record for Defendant, Lloyd E. Bailey. BY THE COURT: Distribution: Lorin A. Snyder, Esquire, Attorney for Defendant ,?-= Vincent M. Monfredo, Esquire, AttomeyforPlaintiff 9Ia? t( ,/)r- ,?, =am C) I Lloyd E. Bailey, Defendant --?-,.y ° _? F= X- David D. Buell Prothonotary Office of the & othonbtary Cum6 errand County, Tennsyfvania �irkS. Sohonage, FSQ Solicitor 6 9 - di S0 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE —THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square 0 Suite100 0 Carlisle, PA 0 Phone 717 240-6195 0 EaX 717 240-6573