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HomeMy WebLinkAbout02-1145HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF MICHAEL E. BAKER, Plaintiff MARNIE G. BAKER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : NO. 02 - //~/6J CIVIL TERM : : 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 in 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of mardage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, 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 2 Liberty Avenue Carlisle, Pennsylvania 17013 717-243-3166 MICHAEL E. BAKER, Plaintiff MARNIE G. BAKER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA _. : CIVIL ACTION - LAW : NO. 02 - //~/~'" CIVIL TERM : : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE NOW, comes the plaintiff, by his attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Michael E. Baker, an adult individual residing at 943 Calvary Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Marnie G. Baker, an adult individual residing at 943 Calvary Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties have been residents of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The plaintiff and the defendant were marded on May 1, 1993, in Carlisle, Cumberland County, Pennsylvania. 5. Pursuant to the Divorce Code, Section 3301(c), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken. 6. The plaintiff avers that he has been advised of the availability of counseling and that he has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff demands judgment dissolving the marriage between the two parties. I verify that the facts contained herein are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. HAROLD S. IRWIN, Attorney for Plain 35 East High Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 MICHAEL E. BAKER, Plaintiff MARNIE O. BAKER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PBNNSYLVANIA _, : CIVIL ACTION - LAW : NO. 02 - //~-~ CIVIL TERM : : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. February~, 2002 ~~ MICHAEL E BAKER, Plai~'~iff ' MICHAEL E. BAKER, Plaintiff MARNIE G. BAKER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA _. : CIVIL ACTION - LAW : NO. 02. liH5 CIVIL TERM : : IN CUSTODY PETITION FOR CUSTODY NOW comes the plaintiff, Michael E. Baker, by his attorney, Harold S. Irwin, III, Esquire, and presents the following complaint for custody, representing as follows: 1. The plaintiff is Michael E. Baker, an adult individual residing at 943 Calvary Street, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is Marnie G. Baker, an adult individual residing at 943 Calvary Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. The parties are the parents of a minor daughter, namely Stephanie Marie Baker (born October 8, 1997, age 4 years). present. The child has resided with both parties from the time of her birth until the 5. Plaintiff believes and therefore avers that the best interests and permanent welfare of the child require that the parties have joint legal custody of the child, but that plaintiff have pdmary physical custody subject to specified pedods of visitation and temporary custody with the defendant. 6. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. Plaintiff has no information of a custody proceeding conceming the child pending in a court of this Commonwealth, 7. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation dghts with respect to the child. WHEREFORE, plaintiff respectfully requests that the court enter an order providing for the legal and physical custody of the child as aforesaid. February ~, 2002 35 East High Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court I.D. No. 29920 VERIFICATION I do hereby verify that the acts set forth in this petition 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 unswom falsification to authorities. February ~._, 2002 HAROLD $. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 35 EAST HIGH STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF MICHAEL E. BAKER~ Plaintiff MARNIE G. BAKER~ Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA .' CIVIL ACTION - LAW : NO. 02 - t145 CIVIL TERM : : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 (a)(1)(i) NOW, Harold S. Irwin, III, Esquire, being duly sworn according to law, does depose and state: 1. That he is a competent adult and attorney for the plaintiff in the above captioned action in divorce. 2. That a certified copy of the complaint in divorce was served upon the defendant on or about March 8, 2002, by certified mail "restricted delivery", addressed to the defendant at PA Dutch Candies, 1250 Slate Hill Road, Camp Hill, PA 17011, by certified mail, return receipt No. 7000 1670 0001 8777 5370. 3. That a copy of the sender's receipt and signed receipt for certified mail is attached hereto. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904, relating to unsworn falsification to authorities. / ~ ~ March 11, 2002 ~ PS Form 3811, March 2001 0 r:x~m M~ Cl In~d M~ 0 C.O,O. Postmar~ Here MICHAEL E. BAKER : PLAINTIFF : V. iN THE COLrRT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 02-1145 CIVIL ACTION LAW MARNIE G. BAKER DEFENDANT : IN CUSTODY AND NOW, Wednesday, March 13, 2002 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland Count~ Courthouse, Carlisle on Wednesda}r, April 17, 2002 at 10:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to de£me and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ ]acqueline M. Ver~. . Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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 heating. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 JAN 02 20~3 ~ MICHAEL E. BAKER, Plaintiff V. MARNIE G. BAKER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-1145 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this 2nd day of January, 2003, as the parties have not contacted the Conciliator since March 28, 2002 to request a Conference, the Conciliator hereby relinquishes jurisdiction in this matter. FORTHECOURT, t/Jacq~line M. Vemey, Esquire, Custody Conciliator MARNIE G. BAKER, Plaintiff MICHAEL E. BAKER, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : : NO' C>7'" - ~ I ~c'° CIVIL TERM : IN CUSTODY .COMPLAINT FOR CUSTODY Plaintiff is Marnie G. Baker, an adult individual currently residing at 337 Franklin Street, Carlisle, Cumberland County, Pennsylvania. Defendant is Michael E. Baker, an adult individual currently residing at 943 Calvary Street, Carlisle, Cumberland County, Pennsylvania. The parties are the natural parents of one (1) child, namely, Stephanie Marie Baker, born October 8, 1997. The child was not born out of wedlock. For the past five (5) years, or since the child's birth, the child has resided with the following persons at the following addresses for the following periods of time: NAME Plaintiff Plaintiff Defendant Plaintiff Defendant ADDRESS 337 Franklin Street Carlisle, PA 943 Calvary Street * Carlisle, PA 146 South Pitt Street, Apt. 1 Carlisle, PA DATES August 6, 2003, to Present November 1, 2000 to to August 6, 2003 Birth to November 1, 2000 * During the period of time that the parties resided at 943 Calvary Street, Carlisle, with the child, Defendant vacated the residence on various occasions for brief periods of time. The natural mother of the child is Mamie G. Baker who resides as aforesaid. She is married. The natural father of the child is Michael E. Baker who resides as aforesaid. He is married. The relationship of the Plaintiff to the child is that of natural mother. The Plaintiff currently resides with the parties' daughter, as well as a friend, David Robertson and his daughter, Sarah. The relationship of the Defendant to the child is that of natural father. Defendant currently resides alone. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning custody of the child. Plaintiff has no information of any custody proceedings concerning the child pending in any Court of this Commonwealth, except for a Petition for Custody filed by Defendant herein on or about March 13, 2002, which action did not proceed to conciliation because of the fact that the parties continued to reside together, said action being docketed to 02-1145, Civil Action, in the Court of Common Please of Cumberland County, Pennsylvania. It is in the best interest and permanent welfm'e of the child to grant the relief requested because Plaintiff has been and continues to be the primary custodian for the child since birth, and, in many respects, has been the sole custodian for the child. 10. Plaintiff does not know any person not a party to these proceedings, who claims to have custody or visitation rights with respect to the child. WHEREFORE, Plaintiff requests your Honorable Court to schedule Custody Conciliation Conference followed by a hearing at which time she should be granted primary physical custody of the child. Respectfully submitted, GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 VERIFICATION I verify that the statements made in the foregoing document are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unswom falsifications to authorities. DATE: M-id{lqIE G] flAKeR, Plaintiff ~-- - MARNIE G. BAKER : PLAINTIFF : IN 'i3rIE COURT OF COMMON PLEAS OF CUMBERLAND CO'UNTY, PENNSYLVANIA 02-1145 CIVIL ACTION LAW MICHAEL E. BAKER : IN CUSTODY DEFENDANT ORDER OFCOURT AND NOW, Wednesday, August 13, 2003 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor, Cumberland County Courthouse, Carlisle on Tuesday, September 09, 2003 at .9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to def'me and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearinl~. FOR TIlE COURT, By: /s! facqueline M. Verney. Esq. Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites 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. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 SEP 1 5 ZOO3 MICHAEL E. BAKER, Plaintiff V. MARNIE G. BAKER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA _- : NO. 2002-1145 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this 1'7- ' day of 3'-.p }ag,.~ ,2003, upon consideration of the attach~ ~-ustody Conciliation Report, i[t is ordered and directed as follows: 1. The Father, Michael E. Baker, and the Mother, Mamie G. Baker, shall have shared legal custody of Stephanie Marie Baker, bom October 8, 1997. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. 2. Mother shall have primary physical custody of the Child. 3. Father shall have periods of partial physical custody as follows: A. Every Sunday at 9:00 a.m. to Tuesday morning when he shall deliver the Child to school. B. Every Wednesday, Thursday and Friday morning approximately one hour before school begins. Father shall deliver the Child to school. C. Such other times as the parties agree. 4. The party relinquishing physical custody shall transport the Child. 5. The parties shall share holidays as agreed. 6. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for November 24, 2003 at 8:30 a.m. BY THE COUP,.T, // J. cc:2~old S. Irwin, III, Esquire, Counsel for Father /~radley L. Griffie, Esquire, Counsel for Mother MICHAEL E. BAKER, Plaintiff V. MARNIE G. BAKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2002-1145 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY pRIOR JUDGE: None CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: 1. The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME Stephanie Marie Baker DATE OF BIRTH October 8, 1997 CUI~.ENTLY IN CUSTODY OF Mother 2. A Conciliation Conference was held in this matter on September 15, 2003, with the following individuals in attendance: The Father, Michael E. Baker, with his counsel, Harold S. Irwin, III, Esquire and the Mother, Marnie G. Baker with her counsel, Bradley L. Griffie, Esquire. 3. It is noted that Father resides with his parents. 4. The parties agreed to the entry of an Order in the form as attached. Date 4. Vemey, Esquire Custody Conciliator NOV 2u 1003 MICHAEL E. BAKER, Plaintiff V. MARNIE G. BAKER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 2002-1145 CIVIL TERM : CIVIL ACTION - LAW : : IN CUSTODY ..ORDER OF COURT AND NOW, this 20th day of November, 2003, the Conciliator being advised that the parties have reached an agreement whereby the interim Order shall remain a permanent Order, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, ~ol/acqu~line M. Vemey, [:squire, Custody~onciliator MICHAEL E. BAKER, Plaintiff MARNIE G. BAKER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02- l 145 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under 43301 (c) of the Divorce Code was filed on March 7, 2002, and served on March 11, 2002. 2. The marriage of 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 THE FOREGOING AFFIDAVIT 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: MARNIE G. BAKER, Defendant MICHAEL E. BAKER, Plaintiff MARNIE G. BAKER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02-1145 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST THE ENTRY OF A DIVORCE DECREE UNDER 1~3301(c) OF THE DIVORCE CODE I. I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose fights concerning alimony, division of property, lawyer's fees or expenses ifI 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 THE FOREGOiNG AFFIDAVIT 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: MARNIE G. BAKER, Defendant MICHAEL E. BAKER, Plaintiff MARNIE G. BAKER~ Defendant : IN THE COURT OF COMMON PLEA8 OF : CUMBERLAND COUNTY, PENNEYLVANIA ; : CIVIL ACTION - LAW : NO. 02 - t145 CIVIL TERM : : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT 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. 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 unswom falsification to authorities. March ~', 2004 MICH.~,EL E. B-AKER~ '- MICHAEL E. BAKER, Pl~llntlff V, MARNIE O. BAKER, Defendant : IN THE COURT OF COMMON PLEA8 OF : CUMBERLAND COUNTY, PENNSYLVANIA .. : CIVIL ACTION - LAW : NO. 02 - 1145 CIVIL TERM : : IN DIVORGE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 (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 rights concerning 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. 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. March /~, 2004 MICHAEL E. BAKER NATHAN C. WOLF~ ESQUIRE ATTORNEY ID NO. 8"~JB0 64 8OUTH PITT STREET CARLISLE PA 17013 (717) ~13-eo~o AI'rORNEY FOR PLAINTIFF MICHAEL E. BAKER, Plaintiff MARNIE G. BAKER, Defendant : IN THE COURT OF COMMON PLEAS OF · - CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO, 02 - tt45 ClVlLTERM : IN DIVORGE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about March 7, 2002 and served upon defendant on March 11, 2002 (see Affidavit of Service filed March 11, 2002). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the 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 divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. March/c/, 2004 ? MI(~HAEE E. BAKE~, ~' - ' HAROLD 8. IRWIN, ill, E~CIUiRE AI'rORNEY ID NO. 29920 84 SOUTH Pil'r STREET CARLISLE PA 17013 ATTORNEY FOR PLAINTIFF MICHAEL E, BAKER, Plaintiff Vm MARNIE G. BAKER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; CIVIL ACTION - LAW : NO. 02 - tt4S 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: On or about march 7, 2002, defendant was served with a copy of the divorce complaint via certified mail, addressed to the defendant. (See Affidavit of Service previously filed.) Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: March 19, 2004. By the defendant: February 9, 2004. (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and service of the plaintiff's affidavit upon the defendant: N/A. 4. Related claims pending: None (a) Complete either (a) or (b): Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/A. (b) Date plaintiff's Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: March 19, 2004. Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Februa~ 9, 2004. March 19, 2004 IN THE COURT Of COMMON PLEAS STATE OF MICHAEL E. BAKER, OF CUMBERLAND COUNTY ~~~ PENNA. Plaintiff VERSUS MARNIE G. BAKER, Defendant NO. 02 - 1145 - Civil Term DECREE IN DIVORCE AND NOW, 2004, IT IS ORDERED AND DECREEd THAT Michael E. Baker , PLAINTIFF, AND Marnie G. 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. BY THE/COUrt: PROTHONOTARY