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HomeMy WebLinkAbout06-4074MISTY D. BAKER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. oc. - 14071 Cif "77.- MARK A. BAKER, Defendant IN DIVORCE NOTICE TO DEFEND 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, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS FEES OR EXPENSES BEFORE A DECREE OF 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 32 South Bedford Street Carlisle, PA 17013 (717) 249-3166 or 800-990-9108 SAIDIS, FL WEJrY SAIDIS, FWVVER LINDSAY 26 West High Street Carlisle, PA Carol J. Lindsay, ,Fs Attorney Id. 446 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff MISTY D. BAKER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW_^ NO. 0G• 407`t Ct,_+4- 1.- MARK A. BAKER, Defendant IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) or (d) OF THE DIVORCE CODE 1. The Plaintiff is Misty D. Baker, an adult individual residing at 1148 Redwood Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Mark A. Baker, an adult individual residing at 479 Chestnut Street, New Enterprise, Pennsylvania 16664. 3. The Plaintiff and Defendant both have been bona fide residents in the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on September 17, 2005 in Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the SAIDIS, FWNVM & IaIDs" 26 West High Street Carlisle, PA parties in this or in any other jurisdiction. 6. The Plaintiff has been advised that counseling is available and that she has the right to request that the court require the parties to participate in counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with §3301 of the Pennsylvania Divorce Code. Respectfully submitted, SAIDIS, FLOWER _&,J4NDPAY Attorney Id. 469 26 West Hi eel Carlisle, PA 17013 (717) 243-6222 Dated: 7/1 `IOP Counsel for Plaintiff SAIDIS, FI-OVVM & LINDSAY 26 West High Street Carlisle, PA VERIFICATION I verify that the statements made in the foregoing document 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 falsifications to authorities. Misty D. Ba e Date: SAJM) FLOWER & L 26 West High Street Carlisle, PA `? n ?, ? ?? ?„ -. , ? ?1 ? l:J r Q ?l a ? ? N ? ?? Q ? ? '.? d -, MISTY D. BAKER, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW NO. 06-4074 CIVIL TERM MARK A. BAKER, Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Carol J. Lindsay, Esquire, being duly swom according to law, hereby deposes and says that on July 25, 2006 she served a true and correct copy of the Complaint in Divorce upon Mark A. Baker, by mailing those documents to the his address at 479 Chestnut Street, New Enterprise, PA 16664, by Certified U.S. Mail, Restricted Delivery, Return Receipt Requested, as evidenced by the attached U.S. Postal Service Form 3811, Domestic Return Receipt, the latter of which is signed by the recipient, Mark A. Baker. Respectfully submitted, Y FWVVERR & LINDSM 26 West High Street Carlisle, PA Dated; August 14, 2006 Carol J. Linds y, s Attorney Id. 693 26 West High el Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff t 4 A`R.lpwww?P WWWPWFW? ? r your nom wd fab... an u» a.vMS. a #W w = nom tM omd W you. r I I Ub aid to It*bdc of Ow ma%* o, or on to Aunt K IPMo pwmtlL ??4 Ches+n?t- S-? . ?Uec,? G-rLterp??e?i O memo Iw O PAK" fbeNpt fcr Mwdlr o CAA. IOftftw mw 7004 1350 NO 7 iw?r?YrMy lb+nt rMMtMty?? or?IM?otarMt SAID FLOWER & LIlVDsm 26 West High $tmet Carlisle, PA IL D. b M I oditw M w'*Am Wn M yn8, ?tt1? drMwY ddw trtOw. 7467 o s' Curtis R. Long Prothonotary office of the Protbonotarp Curnberianb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor ")L " ^Y CJ / 7 CVIL TERM 91 ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573