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Home My WebLink About01-0549BRENDA K. BAKER, Plaintiff VS. GEORGE ILGENFRITZ, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : : So.O/-- fit~? : : ACTION 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. Where 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 at the Office of the Prothonotary, Cumberland County Courthouse. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES AND EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM 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 2 Liberty Avenue Carlisle, Pa. 17013 (717) 249-3166 BRENDA K. BAKER, Plaintiff VS. GEORGE ILGENFRITZ, Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. ACTION IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Brenda K. BakerBaker, an individual suijuris, who has resided in Cumberland County, since April 2000. 2. Defendant is George Ilgenfritz, an individual suijuris, who resides at 2745 Clearview Drive, York, York County, Pennsylvania, 17402. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least 6 months immediately previous to the filing of this Complaint. 4. The Plaintiff and the Defendant lived together in York County from December 1, 1997 through April 1, 2000; in 1999 Plaintiff signed an Affidavit for Common Law Spouse affirming that a Common Law Marriage existed between Plaintiff and Defendant. 5. There have been no prior actions of divorce or for annulment between the parties. 6. 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; however, plaintiff waives her right to request counseling. 7. Plaintiff and Defendant have no children together. 8. Plaintiff and Defendant are both citizens of the United States of America. 9. Neither Plaintiff or Defendant are a member of the Armed Forces of the United States of any of its allies. 10. The Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken; and/or (b) That the Defendant has offered such indignities to the Plaintiff, the innocent and injured spouse, as to render her condition intolerable and life burdensome. WHEREFORE, Plaintiff requests the court to enter a decree in divorce. I 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 faisifieation to authorities. Brenda K. Baker, Plaintiff Date: Respectfully submitted, 117 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF · (~omplete items 1, 2, and 3. Also complete A. ~¢4eived by (Ple.a.~ Detive~y item 4 if Restricted Oetive~ is desired. · Print your name and address on the reverse C. Signatut'~/'~ - so that we can return the card to you.L ~ ~ ~t a Attach this card to the back of the X or on the f~nt if space permits. ' , Yes UNITED STATES POSTAL SERVICE First-Clas~ Mail Postage & Fees Pa'id USPS Permit No. G-lO · Sender: Please print your name, address, and ZIP+4 in this box · BRENDA K. BAKER, Plaimiff VS. GEORGE ILGENFRITZ, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01 - 549 Civil Term ACTION IN DIVORCE AFFIDAVIT OF SERVICE OF NOTICE TO DEFEND AND COMPLAINT AND NOW, this February 7, 2001, I, Jane Adams, Esquire, hereby certify that on February 1, 2001, a true and correct copy of the NOTICE TO DEFEND and COMPLAINT were served, via certified mail, restricted delivery, return receipt requested, addressed to: George Ilgenfritz 2745 Clearview Drive York, Pa. 17402 DEFENDANT Respectfully Submitted: x% I.~. No. 79465 W17 South Hanover St. Carlisle, Pa. 17013 (717) 245-8508 ATTORNEY FOR PLAINTIFF BRENDA K. BAKER, Plaintiff VS. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 01 - 549 Civil Term GEORGE ILGENFRITZ, Defendant ACTION IN DIVORCE MOTION FOR APPOINTMENT OF MASTER ,)~'~._,~_..., (Plaintiff)(Defendant)moves this Court to appoint a master with respect to the following claims: ~-~ Divorce ( ) Distribution of Property ( )Annulment ( ) Support ( ) Alimony ( ) Counsel fees ( ) Alimony Pendente Lite ( ) Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claim(s) for which the appointment of a master is requested. (2) The Defendar{~has not)appeared in the action~erso~y his attorney, , Esquire). (3) The statutory ground(s) fordivorce(is)(are)-~(~[~Q.?)~ ~"~0~ /'o~)~/~ I (4) Delete the inapplicable paragraph(s): (a) The ootion i9 not conteotod. (b) An agreement has been reached with respect to the following claims: The action is contested wtih respect to the following claims: 3 (c) (5) The action (involve '~oes ~) complex issues of law or fact. (6) The headng is expected to take (7) Additional information, if any, relevant to the motion: ~.~c,"-E._-, ~siFEl~iqn~ii rf f~( Defe n d ant ) Date:~_.~ / j~(~), ' ORDER APPOINTING MASTER AND NOW, this ))'/~.z_~c/ /-3,2001, Robert Elicker, Esquire, is appointed Master with repsect to the following claims: ~ BRENDA K. BAKER V. GEORGE ILGENFRITZ : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 01 - 549 CIVIL ACTION LAW IN DIVORCE ORDER AND NOTICE SETTING HEARING TO: Brenda K. Baker Jane Adams George Ilgenfritz · Plaintiff Counsel for Plaintiff , Defendant · Counsel for Defendant ~ou are directed to appear for a hearing to take testimony on the outstanding issues in the above captioned divorce proceedings at the Office of the Divorce Master, 9 North Hanover Street, Carlisle, Pennsylvania on the ]4~ day of ~ne 2001 at 9:00 a.m., at which place and time you will be given the opportunity to present witnesses and exhibits in support of your case. !iccahrt' r, President Judge Date of Order and Notice: 3/22/01 By: Divorce Master 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 2 LIBERTY AVENUE CARLISLE, PA 17013 TELEPHONE (717) 249-3166 TESTIMONY WILL BE LIMITED TO THE ISSUE OF GROUNDS FOR DIVORCE OF INDIGNITIES TO THE PERSON BRENDA K. BAKER, Plaintiff vs. GEORGE ILGENFRITZ, Defendant IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 01 - 549 Civil Term : ACTION IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in divo~ ce dnder section 3301(c) of the Divorce Code was filed on January 26. 2001, 2. The marriage of PlairLt ff and E)efendant is irretrievably broken and ninety days have elapsed from the date of the filing and service ot 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 correct. I also understand that false statements herein are made subject to the penal[les of 18 Pa.C.S. 4904, relating to unsworn falsification to authorities. Data: Brenda K. Baker, Plaintiff WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~3301(C) OF TIlE OIVORCE CODE 1. I consent to entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a d~vorce is granted 3. I understand that I wdl not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary, I verify that the statements made in th~s affidavit are true and correct. I understand that false statements herein are made subject to the penal,ties of 18 Pa,C.S. {}4904 relating to unswom falsification to authorities. Brenda K. Baker, Plaintiff BRENDA K. BAKER, Plaintiff vs (3[~ ORGE ILGENFRITZ, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 01 - 549 Civil Term : ACTION IN DIVORCE AFFIDAVIT OF CONSENT ~ ::o~ ~}1~ ~t in divorce under section 3301(c) of the Divome Code was filed on January 26, 2001. ¥t e ~,ar age of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the Jal:e of the fihng and service of the Complaint. ! ',:on-~er~ tc the entry of a final decree of divorce after service of notice of intention to request entry of the verify that :ne statements made in this affidavit are true and correct. I also understand that false statements hgrem ~e made subject to the penalties of 18 Pa.C.S. 4904, relating to unswom falsification to authorities WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~350t(ci OF THE DIVORCE CODE ~ 3or, sert to entry of a final decree of divorce without notice. dndersland that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not clamn them before a divorce is granted. ~ ander'.~tand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the de~.'ree *,ill be set1', to me immediately after it is filed with the Prothonotary. verify ~ha~ the statements made in this affidavit are true and correct. I understand that false statements nere,n are made st ~ject to the penalties of 18 Pa.C.S. §4904 relating to unswornfalsification.,~o authorities. Date 1,,/! 'G~or~gefritz, Defe~n~(~ / PATRICK B. SCHILD, : Plaintiff : VS. : DIMITP~A C. SCHILD, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98 566 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this /~ day of 2001, the parties and counsel having entered into an agreement and stipulation resolving the economic issues on May 14, 2001, the date set for a four-party conference, the agreement and stipulation having been transcribed, and subsequently signed by the parties and counsel, the appointment of the Master is vacated, and counsel can conclude the proceedings by the filing of a praecipe to transmit the record with the affidavits of consent of the parties so that a final decree in divorce can be entered. CC: Johnna J. Deily Attorney for Plaintiff Paul J. Esposito Attorney for Defendant BY THE COURT, BRENDA K. BAKER VS. GEORGE ILGENFRITZ Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 0! - 549 CIVIL 19 IN DIVORCE STATUS SHEET DATE: ACTIVITIES: r47t.¢~' ./¢~,.',,- ~.~,.,.X~.,t,~d/Zl~;,,-)~'/e ~~'~ ~' BRENDA K. BAKER, : Plaintiff : Vs. : GEORGE ILGENFRITZ, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01 549 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this / ~ day of 2001, counsel for the Plaintiff having advised that both parties have signed affidavits of consent so that the divorce can be concluded under Section 3301(c) of the Domestic Relations Code, and no economic raised in the action, the appointment of vacated. claims having been the Master is CC: Jane Adams Attorney for Plaintiff George Ilgenfritz Attorney for Defendant BY THE COURT, BRENDA K. BAKER, : Plaintiff : Vs. : GEORGE ILGENFRITZ, : Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01 549 CIVIL IN DIVORCE ORDER OF COURT AND NOW, this / ~ day of 2001, counsel for the Plaintiff having advised t~t both parties have signed affidavits of consent so that the divorce can be concluded under Section 3301(c) of the Domestic Relations Code, and no economic claims having been raised in the action, the appointment of the Master is vacated. cc: Jane Adams Attorney for Plaintiff George Ilgenfritz Attorney for Defendant BY THE COURT, BRENDA K. BAKER:, Plaintiff VS. GEORGE ILGENFRITZ Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA No. 01-549 Civil Term : ACTION IN DIVORCE PRA~ECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY Transmit the record, together with the following information to the Court for entry of a divorce decree 1. Grodnd for divorce irretrievable breakdown under §3301(c) of the Divorce Cede. 2, Date and, n~a, nner of the service of the Complaint: Delivered by certified mail, restricted deliveL~_.return r_e_ceipt requested, delivered on: February 1. 2001. 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: F3y Plaintiff: 5/10/2001 h3!l Defendant: 5/6/2001 4. Related claims pending: None. 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: May 11 2001. Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: May 11. 2001. Date: ~ne Adams, Esquire - ('~/fl' 1D~ Ns°o~t7h94H6a5nover St. Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF Brenda K. ~aker, Plaintiff PENNA. NO. 549 Civil Ten~ 200~ VERSUS Geerge Ilgenfritz, Defendant DECREE IN DIVORCE AND NOW, DECREED THAT AND Brenda X. Baker George Ilgemfritz , J'~d~/__, It IS ORDERED AND , PLAINTIFF, , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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 ENTEREE); Ne~e. BY THE C.OURT: . /