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Home My WebLink About05-5239 SAID IS SHUFF, FLOWER & LINDSAY ATIORNEYSoAToLA W 26 W. High Street Carlisle, P A CYNTHIA H. BAKER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO.OS- ~;)'J9 CIVIL TERM CIVIL ACTION - LAW v. SHAWN A. BAKER, 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 Street, Carlisle, Pennsylvania. 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 2 Liberty Avenue Carlisle, PA 17013 717 -249-3166 Respectfully submitted, By SAlOIS, SHUFF. FLOWER & ') j. vi Carol J. Li Supreme QU 0 # 78014 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff Dated: I (Iff (t;;S - SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYSoAToLAW 26 W. High Street Carlisle, P A I CYNTHIA H. BAKER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NODS - S;U 9 CIVIL TERM CIVIL ACTION - LAW v. SHAWN A. BAKER, Defendant IN DIVORCE COMPLAINT 1. Plaintiff is Cynthia H. Baker, who currently resides at 229 Middle Road, Newville, Cumberland County, Pennsylvania 17241, since 1994. 2. Defendant is Shawn A. Baker, who currently resides at 229 Middle Road, Newville, Cumberland County, Pennsylvania 17241, since 1994. 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. The Plaintiff and Defendant were married on October 2, 1992 in Mt. Holly Springs, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce and to determine marital property and to order an equitable distribution thereof. Respectfully submitted, Dated:/!t!C S By I'/~~' Carol Supr ourt ID # 78014 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff - SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYS.AT.LAW 26 W. High Street Carlisle, P A AFFIDAVIT I, Cynthia H. Baker, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. (2) I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. (3) Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. 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. Dated: IO/(p 105 I I i;;#; id II d/l/{.l K C nthia H. Baker, Plaintiff SAlOIS SHUFF, FLOWER & LINDSAY ATIORNEYSoAToLA W 26 W. High Street Carlisle, P A VERIFICATION 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. Section 4904, relating to unsworn falsification to authorities. Dated: J() /~;;cc; I ~. /;J!;t~ --#~/C( ~ Cynt ia H. Baker, Plaintiff ~~ ~ - ~ ~ ....r:::. ~ tN W -.0 -'q. -- ...(:) C> 8 ~ :r:> t ----- r-') t: t<> ;;,',,":-,":,") C .~,. ':..r" C. c: ...-t o -n I cr> ~ -.- i:-":) .' \""0 0' - SAlOIS SHUFF. FLOWER & LINDSAY ATIORNEYS.AT-LAW 26 W. High Street Carlisle, P A CYNTHIA H. BAKER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA NO. 05-5239 CIVIL TERM CIVIL ACTION - LAW v. SHAWN A. BAKER, Defendant IN DIVORCE ACCEPTANCE OF SERVICE I, Shawn A. Baker, Defendant in the above captioned matter, accept service of the DIVORCE COMPLAINT and certify that I am authorized to do so. ~II~ Shawn A. Baker Dated: October 6, 2005 h> ~ 0 CJl -q <::) C) --~ I -..1 -v =d~ 1',) .r:~ (.'n SAIDIS, FLOWER & LINDSAY ATIORNEYS.AT.lAW 26 West High Street Carlisle, PA CYNTHIA H. BAKER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA v. NO. 05.5239 CIVIL TERM CIVIL ACTION. LAW SHAWN A. BAKER, Defendant IN DIVORCE PLAINTIFF'S/DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under S 3301 (c) of the Divorce Code was filed on October 6, 2005. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed iron, 1118 datE;; of filing and ~ervice uf the Complainl. 3. I consent to the entry of a final Decree in 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 to the best of my knowledge, information 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. I Date // /3/cJl/' /",-/ - ' , ( C//)I//; <<(.;lI!6'~ b"<' Cynthia H. Baker PLAINTIFF'S/DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER& 3301 Ic) OF THE DIVORCE CODE I consent to the entry of a final Decree of Divorce without notice. 2. I understand that I may lose riqhts concerninq alimony. division of property, lawyer's 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 are true and correct to the best of my knowledge. information 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. Date //1'5 !{'.V/ I / (//J~.I? Gt? '/1 ~d~("G Cynthia H. Baker ~" \ 8 - C'. \~--:> .~:';.~; :---.,.. C\) ----, SAIDIS, FLOWER & LINDSAY ATIORNE)'S'ATolAW 26 West High Street Carlisle, PA CYNTHIA H. BAKER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-5239 CIVIL TERM CIVIL ACTION - LAW SHAWN A. BAKER, Defendant IN DIVORCE PLAINTlFF'S/DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under !l3301(c) of the Divorce Code was filed on October 6, 2005. 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 in 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 to the best of my knowledge, information 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 authonties. Date J (II( 0 b ~fi BJ~ PLAINTIFF'S/DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER!l3301 (c) 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 riohts concerninCi alimonv. division of property, lawyer's 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 are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. "" "'''''' " ","om~ '"''''&.4 If Shawn A. Baker Date 11 (/ ~ I c___ f' . . SAIDIS, FLOWER & LINDSAY Am)RNEY~',\T'I.AW 26 \X/esl High Street Clrlis!t:, PA CYNTHIA H. BAKER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 05-5239 CIVIL TERM CIVIL ACTION - LAW SHAWN A. BAKER, Defendant IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on October 6, 2005, via regular mail. The Acceptance of Service was filed with the Court on October 7, 2005. 3. Date Affidavit of Consent required under Section 3301 (c) of the Divorce Code was executed: By Plaintiff: January 13, 2006 and filed with Prothonotary on January 18, 2006. By Defendant: January 11, 2006 and filed with Prothonotary on January 23, 2006. 4. Related claims pending: The terms of the Property Settlement and Separation Agreement dated October 6, 2005 are incorporated, but not merged, into the Decree in Divorce. 5. executed: Date Waiver of Notice under Section 3301 (c) of the Divorce Code was By Plaintiff: January 13, 2006 and filed with Prothonotary on January 18, 2006. By Defendant: January 11, 2006 and filed with Prothonotary on January 23, 2006. SAlOIS, SHUFF, FLOWER & LINDSAY . ... SAIDIS, FLOWER & LINDSAY ArIbRNITS'Al'.lAW 26 \'<-'est High Strt;tt Car/i."/e, PA CERTIFICATE OF SERVICE I, Carol J. Lindsay, Esquire, of the law firm of SAlOIS, SHUFF, FLOWER & LINDSAY, hereby certify that on this date a copy of the attached document was served on the following individual, via first class mail, postage prepaid, addressed as follows: Shawn A. Baker 229 Middle Road Newville, PA 17241 SAlOIS, SHUFF, FLOWER & LINDSAY Carol J. Lindsay, sq Supreme Court J,E) No. 26 West High S Carlisle, PA 17013 717 -243-6222 /,,-,' , ." ~~J :11 ,..... C,' " c- .' . . . . . . . . . . . . ~ ~ ~ ~+. ~~+. ~~~+.~~+.+.+. +.+. +.+. ~+.+.~ +.+. ~ +. ~+.+.~~+~~+~++ +**++++~+ ~ IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY STATE OF . . . . . . . . . . CYNTHIA H, BAKER Plaintiff . . VERSUS SHAWN A, BAKER . . . . . . . . . . Defendant PENNA. No. 05-5239 DECREE IN DIVORCE . . . . . . . . J"Znu "''\ .~ l CYNTHIA H, BAKER AND NOW, . . + . . + + . . . . . . . + . + . DECREED THAT AND SHAWN A BAKER ,~c:6, 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 ENTERED; The tenns of the Separation and Property Settlement Agreement dated October 6, . + + . . . . . . + . . . + . . + . . + . + + + + + . . . . ;+ '*':+' :+' '+:+::-to 2005 are incorporated, but not merged, into this Decree in Divorce. cJe![ T{J~ ~7 PROTHONOTARY '+~+'++ 'f:+'~+:+'~+++;+'I'~++:+'+~~ ... + ++:-t++:+ -+,++++++'f+ .. :+<+++++ . . . + + . . . . . . + . . + . . . + . . . < . < . . . . . . . . . . . . . . . . . . . . . . . + . . . . + . . . . + . + . . . + . + . . . . . . J. . . . . . . . < . . . . . + . + + . . + ;to;:+: Of+ "cr1?;" . ~.?/ /f;7'w "'-"1/, ~?ft /"fTr";~7 ,r?7 .< . 'lrI ./f7 I' 'JC ,. r::.-:: ,