HomeMy WebLinkAbout01-4179
. .
~ ~
~ ^
~ ~
~
~.~
~
~.~
~
~
~
! ~~~.~--~-~~'-'-~.'~'~~~.'~ ~
~~~."". ':.>>~... ...::.:......:+::. . '.::+::., ..~:.- .::+::.".:'::." '.::+::.,.::+::..,' ':.::.::.:,- - .::+::. ,.::+;. - -'.::+:' '.::+::..::+::..::+::. .::+::. ~::.;. .::+::. ,.::+::. ,- -'.::.::.:: :..::+;' .::~::.' ':.::.::.:.::.;. .::.::. - -'.::"::."- .::+;. - :.::+::.-
~
~.~
~
".'J
i~,
;.s
~
DDE,~Rc5: e'EN ik t.(,: )S"~. ~
AND NOW, N.~.1. ~ ><Ix9.x.2001, it is ordered and ~
~,.;;
~
~.~
~
THE COURT OF COMMON
IN
PLEAS
~.~
~
i
~.~
~
'.'
OF
CUMBERLAND
~.
COUNTY
~
~.4l
PENNA.
STATE OF
~
..
-,..
~
...
ROBIN D. BAKER,
f."'Ii
~
~
~.~
-,.~
~\
No. .Q~~~P.~....... ................. 19
.P~aintifL.
Versus
~
~.41
EDWARD J. Bl\.KERJ
~
'.'
.. Defendant
~
'.'
v
~
~.~
~
...
~
~.~
~.,
~
~,,~
~
~..
~
',,+<
~.~
~
~.~
~
~.~
~
~
~
~.~
decreed that. . . . . . . . . . . . . . . ~9~~~. P~. ~f.~F-. . . . . . . . . . . . . . . . . . . " plaintiff,
and . . . . . . . . . . . . . . . . . . . . . . . .EDWARD .J~ .BAKER . . . . . . . . . . . . . . . . . " 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 entered;
~
~.~
~
~."
~
~.~
None.
~
~l
~.~
~
~.~
~
~.~
~
~
~.~
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ,
By
Au
~
~.~
~.~
~
~
~.~
f..~
~
~.~
~
,.~
*
~~~
~
~.~
~
~.~
*
~.~
~
~+~
~
l~
~
-",,'
~
~.~
~.~
~
~
~.~
~
~.~
~
,',
~
~.~
~
'.'
~
'.'
~
~
'.'
~
$
~
'.'
*
~
'.'
~
'.'
~
'.'
. /ftp ~ 1"7~ ~lL, ! iJ .JiI.J1
/k~o fJ! .-:y.. /IT'1IW ~l.p; !v!;/-;I
.' .
FIFILESIDA T AFILEIGend'>Ccurl I 0345-pm. Iltde
Created: 10/17/0104:47:33 PM
Revised 11/0,2/0110:05IIAM
ROBIN D. BAKER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
EDWARD J. BAKER,
Defendant
NO. 01-4179 CIVIL TERM
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce
Code.
2. Date and manner of service of the complaint: See Affidavit of Service, as filed.
3. (a) Date of execution of the Plaintiff s affidavit of consent required by Section
3301 (c) of the Divorce Code; October 19,2001; by the Defendant; October 19, 2001.
4. Related claims pending: None.
5. Date Plaintiffs Waiver of Notice In 93301(c) Divorce was filed with the
Prothonotary: October 24,2001.
Date Defendant's Waiver of Notice In 93301(c) Divorce was filed with the
Prothonotary: October 25,2001.
MARTSON DEARDORFF WILLIAMS & OTTO
B~~
Edward L. Schorpp, Esqui e
Ten East High Street
Carlisle, P A 17013
(717) 243-3341
Attorneys for Plaintiff
Date: November 2,2001
--------~"-----
\~
. '
,"',-
C:1
:,)
co
-
-
~
~
N
o
V"
CO
~
)
F:\FILES\DA T AFILEIGendocwr\ 1 0345-co01 l/tde
Created 06/18/01 1034:07 AM
Revised: 06/19/0112:11:17PM
ROBIN D. BAKER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
EDWARD J. BAKER,
Defendant
NO.OI-lf/1<jcIVIL TERM
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 with your children.
When the ground for divorce is indignities or irretrievable breakdown ofthe marriage, you
may request marriage counseling. A list of marriage counselors is available in the Office of the
Prothonotary, First Floor, Cumberland County Court House, Carlisle, Pennsylvania 17013.
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
Two Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone: (717) 249-3166
ROBIN D. BAKER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
EDWARD 1. BAKER,
Defendant
NO. CIVIL TERM
IN DIVORCE
COMPLAINT UNDER
SECTION 3301(c) OF THE DIVORCE CODE
1. Plaintiff is Robin D. Baker, who currently resides at 741 Conodoguinet Avenue,
Carlisle, Cumberland County, Pennsylvania, since 1983.
2. Defendant is Edward 1. Baker, who currently resides at 645 Hamilton Street (Rear),
Carlisle, Cumberland County, Pennsylvania since 1999.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at
least six months immediately previous to the filing of this Complaint.
4. Plaintiff and Defendant were married on June 27, 1993, in North Middleton
Township, Cumberland County, Pennsylvania.
5. There have been no prior actions of divorce or for annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiffhas 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.
MARTS ON DEARDORFF WILLIAMS & OTTO
B~~
Ten East High Street
Carlisle, P A 17013-3093
(717) 243-3341
Attorneys for Plaintiff
Date: July 9, 2001
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. g4904, relating to unsworn
falsification to authorities.
Date: (p- 30'" 0 (
~'l D.-6~.
Robin D. Baker
-3-
:J;J
( 0
~\ l
~c;; --- ~
~
%.~ V') ~ ~
" ~ ~ 0
....0 ~ ,
........ ~ ~ ~~
~ ~ ,. en
~ - , . ,
'i.l -::po ~ ..l::
~ """ ~ 0
~ 1; ):.
-=\ ~
,if ;::fVEL
JUt (i:) 2081
q r ',""""'.
/1/r
.J '.
F:\FILES\DATAFILE\Gen~oc.cur\10~45-aff 1
Created: 07/23/01 ] 12154 AM
Revised: 07~23/0 1 02:20:] 2 PM
ROBIN D. BAKER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
EDWARD 1. BAKER,
Defendant
NO. 01-4179 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEAL TH OF PENNSYLVANIA )
: SS.
COUNTY OF CUMBERLAND )
I hereby certify that a copy of the Complaint in Divorce was mailed to Defendant Edward
1. Baker at 645 Hamilton Street, Rear, Carlisle, P A 17013 on July 10, 2001 by certified mai I,
restricted delivery, return receipt requested.
Attached is the Post Office return receipt signed "Edward 1. Baker." and dated July 13,2001.
~~
Edward L. Scho p, Es 1
Sworn to and subllribed
before me thisZ3 day of
~ ' 2aJI .
~jJ.~
Gotary Publi'c
NOTARIAL SEAL
TRICIA D. ECKENROAD. Notary Public
Carlisle Bore.. Cumberland County
. 4
co
Cl
rn
;:r
Cl
.-=I
rn
I'-
Postage $
Certjfied Fee
I'-
ru
Cl
Cl
Return Receipt Fee
(Endorsement Required)
Restricted Delivery Fee
(Endorsement Required)
Cl
Cl
-D
Cl
Cl
Cl
Cl
I'-
SENDER: COMPLETE THIS SEC nON
. Complete items 1, 2, and 3. Also complete
item 4 if Restricted Delivery is desired.
. Print your name and address on the reverse
so that we can return the card to you.
. Attach this card to the back of the mailpiece,
or on the front if space permits.
1. Article Addressed to:
lc\wCMA bcUl.tA
ULl5 y\n.Mililffi. ~t , ~
~ ~ 11013
- - - . . .
x
D Agent
ddressee
Yes
DNa
D. Is delivery a ss different from item 1?
If YES, enter delivery address below:
3. Service Type
rit Certified Mail
D Registered
D Insured Mail
D Express Mail
D Return Receipt for Merchandise
DC.a.D.
4. Restricted Delivery? (Extra Fee)
~Yes
2. Article Number (Copy from service label)~
70D/J ()VOD fJDZ7 73/0 -/3D9
PS Form 3811, July 1999 Domestic Return Receipt
102595-00.M-0952
a
~
--
=f
~
::::::
"
I'v
<:)
:l>.
~
f
.... .
A (' .
F. \FlLESIDA T AFlLE\Gendoc. curl I 0345-affconltdc
Created. 10/17/0104:47.33 PM
Revised. 10/17/0104.50.52 PM
ROBIN D. BAKER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LA W
EDWARD J. BAKER,
Defendant
NO. 01-4179 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under S 3301(c) of the Divorce Code was filed on July 10,
2001. I acknowledge receiving a true and correct copy of the Divorce Complaint, said copy being
served upon me by Certified Mail, Restricted Delivery, on July 13, 2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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.
4. 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 divorce is granted.
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
~3301(c) AND ~ 330Hd) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division ofproperty, lawyers
fees or expenses if I do not claim them before a divorce is granted.
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 affidavit and waiver are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904
relating to unsworn falsification to authorities.
Date: lel/ ! q / :J I t:L ,. /l f!3-J="------
.--------...,.."'.-------------.
".
o
:::::>
c-,
...-..-!
~c
~.::: C,l
--- ~::; :.,)
~':'~
___j t:"'"
-< \0
.~,
I.,__J
N
(.;'
..
..... ,.
.. (.'1 ...
ROBIN D. BAKER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
EDWARD J. BAKER,
Defendant
NO. 01-4179 CIVIL TERM
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under S 3301(c) ofthe Divorce Code was filed on July 10,
2001.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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.
4. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if! do not claim them before a divorce is granted.
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
~3301(c) AND ~ 3301 (d) OF THE DIVORCE CODE
1. 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.
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 affidavit and waiver are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. S4904
relating to unsworn falsification to authorities.
Date: /b- /q -oj
~~v---'0 ~~
Robin D. Baker, Plaintiff
o
c:
<_.:
-0--'"
ITl rOo
~5~
r:
~
;f
~
o
D
,;-:>
~-~
C-,)
J"~.J
.'0