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Home My WebLink About10-2953y IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JILL LANETTE BAUGHMAN Docket No. Plaintiff V. DANIEL LEE BAUGHMAN Defendant FAMILY DIVISION 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 on the first floor of the Cumberland County Courthouse, Carlisle, Cumberland County, PA. 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 LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, PA 17013 1-800-990-9108 717-249-3166 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 the Court Administrator at (717) 780-6624. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JILL LANETTE BAUGHMAN Docket No. 10 -olq 3 Oiv i I -&M Plaintiff V. FAMILY DIVISION DANIEL LEE BAUGHMAN °- c Defendant COMPLAINT IN DIVORCE' AND NOW comes Plaintiff, JILL LANETTE BAUGHMAN, by and through her' -` attorneys, TRUDY A. MARIETTA MINTZ, Esquire, and the DETHLEFS-PYKOSH LAW GROUP, LLC, and respectfully sets forth the following Complaint in Divorce: 1. Plaintiff is Jill Lanette Baughman, an adult individual residing at 1732 West Trindle Road, Carlisle, Cumberland County, Pennsylvania 17015. 2. Defendant is Daniel Lee Baughman, an adult individual residing at 262 Seaview Avenue, Daytona Beach, Florida 32118. 3. Plaintiff has resided within the Commonwealth for at least six (6) months immediately prior to the filing of this Complaint. 4. Neither Plaintiff or Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldier's and Sailor's Civil Relief Act of 1940 or any amendments thereto. 5. The Plaintiff and Defendant are husband and wife and were lawfully married on April 29, 1989. 35a. o0 PA ATTy S8a/ &** ??ayl sl9 6. The marriage is irretrievably broken. 7. The parties have lived separate and apart since January 10, 2010. 8. There has been no prior action for divorce or annulment instituted by either of the parties in this or any other jurisdiction. 9. The Plaintiff has been advised that counseling is available and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. 10. The children, Jacob Daniel, born September 1, 1989 and Mason Lee, born February 4, 1991, born of the marriage are now fully self-supporting adults. There are no issues of child custody, visitation or child support in this matter. 11. The parties have completed division of property to their satisfaction. There are no issues of property division in this matter. 12. Plaintiff does not seek support, alimony or alimony pendente elite from the Defendant. REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301 OF THE DIVORCE CODE 13. Paragraphs one through eleven of this Complaint for Divorce are incorporated by reference herein. 14. After ninety (90) days have elapsed from the date of the filing of this Complaint for Divorce, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. WHEREFORE, if both parties file affidavits consenting to a divorce after ninety (90) days have elapsed from the filing of this Complaint for Divorce, . Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to Section 3301 (c) of the Divorce Code. REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(d) OF THE DIVORCE CODE 15. Paragraphs one through thirteen of this Complain for Divorce are incorporated by reference herein. 16. At the appropriate time, Plaintiff may submit an affidavit alleging that the parties have lived separate and apart for at least two (2) years. WHEREFORE, Plaintiff respectfully requests that the Court enter a Decree of Divorce, Pursuant to Section 3301(d) of the Divorce Code, at the appropriate time. Date: Y' 3c)// o THE DETHLEFS-PYKOSH LAW GROUP, LLC WU-DY A. MARIETTA MINTZ, Esquire 2132 Market Street Camp Hill, Pennsylvania 17011 PA ID# 208523 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA JILL LANETTE BAUGHMAN Plaintiff V. DANIEL LEE BAUGHMAN Defendant Docket No. FAMILY DIVISION VERIFICATION I, Jill Lanette Baughman, hereby verify that the statements of fact made in the foregoing Complaint, are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa C. S. Section 4904, relating to unsworn falsification to authorities. Date: o4150110 Jill qele ttau an JILL LANETTE BAUGHMAN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY,PENNS!RL.VVANIX-1' V. : NO.: 10-2953 DANIEL LEE BAUGHMAN, : CIVIL ACTION - LAW Tr Defendant : IN DIVORCE `-' c- P4 PLAINTIFF'S AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on May 3", 2010. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of 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 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: C I i (. Jil anette Baughman, aintiff JILL LANETTE BAUGHMAN, Plaintiff V. DANIEL LEE BAUGHMAN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,PENNSYLVANIA NO.: 10-2953 CIVIL ACTION - LAW T: IN DIVORCE -Q'.. F7-1 w INTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST EN OF?5 DIVORCE DECREE UNDER SECTION 3301 (c) OF THE DIVORCE M$-E 1. 1 consent to the entry of a final Decree of Divorce without Notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyers' fees or expenses if I do not claim them before a divorce is granted. 3. 1 understand that I will 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 this Waiver 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. Date: Jill nette Baughman, Plai fr ;.^ rn rn JILL LANETTE BAUGHMAN, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA V. : NO.: 10-2953 DANIEL LEE BAUGHMAN, : CIVIL ACTION - LAW Defendant : IN DIVORCE ` _r m M f T, , ?=- DEFENDANT'S AFFIDAVIT OF CONSENT - ` 5;C. E Y n 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filmon < May 3rd, 2010. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of 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 understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. Date: L o 1 JILL LANETTE BAUGHMAN, Plaintiff V. DANIEL LEE BAUGHMAN, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY,PENNSYLVANIA 0 ?e `rn NO.: 10-2953 : CIVIL ACTION - LAWS' : IN DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY DIVORCE DECREE UNDER SECTION 3301(e) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without Notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyers' fees or expenses if I do not claim them before a divorce is granted. ?1^1 ''A 3. I understand that I will 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 this Waiver 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. 1 Date: j d C. aniel Baughman, Defendant AFFIDAVIT to - aq 53 Civil Term I, Daniel Lee Baughman, make this Affidavit under penalties of perjury. I hereby swear and affirm that the attested information provided below is to be the truth: I Daniel Lee Baughman received on this 14t1i day of May. 2010, the Complaint in Divorce filed on May 3, 2010, Office of Prothonotary, Cumberland County Pennsylvania. DATE: --> l? phiele Baughman COMMONWEALTH OF PENNSYL VANIA COUNTY OF CUMBERLAND On this, the day of c>L? 2010, before me, Notary Public, the undersigned officer, personally appeared, Daniel Lee Baughman, known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVANIA (SEAL) Notarial Seal No`fary Public Danielle Winn, Notary Public Camp Hill Boro, Cumberland County My Commission Expires Sept. 9, 2013 Member, Pennsylvania Association of Notaries C t :? r7 'tJ 4, („ :, Crl C. C tt? C7 ? I JILL LANETTE BAUGHMAN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. DANIEL LEE BAUGHMAN NO. 10-2953 DIVORCE DECREE AND NOW, i4?r? zB it is ordered and decreed that JILL LANETTE BAUGHMAN plaintiff, and DANIEL LEE BAUGHMAN , defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") NONE By the Court, - 1?710 . Att J. J1 114 a A (JA • v ?e+u,`o( b. /?ucll rothonotary ?? qa9<o Cu?-6W