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Home My WebLink About06-5952 " HAROLD S. IRWIN, III, ESQUIRE ATTORNEY ID NO. 29920 64 SOUTH PITT STREET CARLISLE PA 17013 (717) 243-6090 ATTORNEY FOR PLAINTIFF BETH A. BAITSELL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 2006 -~o'..:z... CIVIL TERM DAVID E. BAITSELL, 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 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 marriage 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 BETH A. BAITSELL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Y. : CIVIL ACTION. LAW : NO. 2006 . 515'.2.-CIVIL TERM DAVID E. BAITSELL, Defendant : IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301 ~ OF THE DIVORCE CODE NOW, comes the plaintiff, by her attorney, Harold S. Irwin, III, Esquire, and files this complaint in divorce against the defendant, representing as follows: 1. The plaintiff is BETH A. BAITS ELL, an adult individual residing at 1916B Fry Loop Avenue, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant is DAVID E. BAITSELL, an adult individual residing at 1070 Myerstown Road, Gardners, Cumberland County, Pennsylvania 17324. 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 parties were married on March 18. 2000 in Gardners, 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 she 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 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. October /6 , 2006 --r:!uLI- a. ~ BETH A. BAITSELL, Plaintiff HAROLD S. IRWIN, III Attorney for Plaintiff 64 South Pitt Street Carlisle, Pennsylvania 17013 (717) 243-6090 Supreme Court ID No. 29920 t'-_' C..J (::;:.:> 0...... o ""1' --I ::r: III o Cj --l ~:"' ~.i-.~ . ) _..-1 ..,., -) ~~~; ..('") ;-:;::,;-n ~::\ :i; -< ~~ ~ (.,) 1"":: BETH A. BAITSELL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : NO. 2006 - !lA1 6"4:IVIL TERM DAVID E. BAITSELL, Defendant : IN DIVORCE PLAINTIFFWS 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. October 10, 2006 .~o.~ BETH A. BAITSELL, Plaintiff (") ......., c::? C (;;;:> 0-' ~' 0 ~ ~",:~ . n -j ~ ~ F ~ c-- -ry .-,.,.,. ~ -<) c ~ (~) ....c L - -L. ..P V\ 0 ~" v\ ... ~ .~ .' BETH A. BAITSELL, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Y. : CIVIL ACTION. LAW : NO. 2006 - 5952 CIVIL TERM DAVID E. BAITSELL, Defendant : IN DIVORCE AFFIDAVIT OF SERVICE OF COMPLAINT PURSUANT TO PA. R.C.P. RULE NO. 1920.4 ~ 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 October 28, 2006, by certified mail addressed to the defendant at 1070 Myerstown Road, Gardners, PA 17324, certified mail No. 7004 1350000371470864. 3. A copy of the sender's and return receipts are 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. Harold S. Irwin, III Attorney for plain 'ff October 31,2006 64 South Pitt Street Carlisle, P A 17013 717 -243-6090 Supreme Court 10 No. 29920 -. . U.S. Postal Service CERTIFIED MAIL,., RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) ::T Jl <0 Cl I"'- ::T r'l I"'- ITl Cl Cl Cl Return Reclept Fee (Endorsement Required) Cl Restricted Delivery Fee LI"l (Endorsement Required) ITl r'l Total Postage & Fees $ ::T ~ ::.~~J;"_.__~__...___.u__m__.__. ",treet, Apt. No.; ~;St~~;;~4~9-12___~~-~;M~-_mm_m Postmark Here 3.~ -- -: ",-..,.,,-...-~ SENDER CO~,1PL r" I HIS : _' ,vr. ( O^lJ1l t" Tln~) ',ECTIfP) ()(\ Of l'Jt ;--1'" . Complete items 1, 2, and 3. Also complete , Item 4 If Restdcted Delivery Is desired. . Print yout 'n~~ and address on the reverse so that we can return the card to you. . Allt8cMhj,~, card to the back of the mail piece, or on the'front if space pennlts. 1. Article Addressed to: o Agent o Addressee C. Qate of DellvEHX, (0 - 2Y -UJ D. Is cIeIlvety address different from Item 11 0 Yes If YES. enter cIeIlvery address below: ii(No x ,B. Received by ( Printed Name) 'JAVT'J To.: BAI'I's~r.JT.J 1 f'J7"J ~I\Y~'1S'-rmr\1 ~TJ SA~~q~(8 ~A 17321 3:iESe Type ad Mall 0 Express Mall eglstered Cl RetumReceipt for Merchandise Cllnsured Mail Cl C.O.D. 4. RestrIcted DeUvery? (Extra Fee) lIS 2. ArtIcle Number (Transfer from service 1Bbel) PS Fonn 3811, February 2004 7004 1350 0003 7147 0864 llor1wstlc Return Receipt 102595-02-M-1540 EXHIBIT "A" ~ ~~ ~C.1 rT'n-\ 77":{} u~;..'~ ~(-) ~C' '~7 '-< ..-L"o :P'C ~ ~ ~ cr C c-: u: -t :l - " c. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BETH A. BAITSELL Plaintiff Vs : File No. 2006 - 5952 IN DIVORCE DAVID E. BAITSELL Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plantiff / Defendant in the above matter, [select one by marking "x"] X prior to the entry of a Final Decree in Divorce or after the entry of a Final Decree in Divorce dated hereby elects to resume the prior surname of '/ e I (\ 3 ~ t , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P .S. 704 Date: 11- '6 - dO 0 lo ~~~ Signature ~~~ Signature of name being resumed COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND On the8/L day of ~, 2006, before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and axknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. Prothonotary or Notary Public Oof-CUUCl- OMMONWEALTH OF PENNSYLVANIA Notarial Seal Jane Adams, NotarY Public Carlisle Boro, cu~berland County My Commission Expires Sept. 6, 2008 ~) ~ ~ r-:> 0 = = ~.rl ('..... o~ , ::i - ~ Cf">o. lJ" , ~ ' --n ~. \.y 0 d\ ~ r~..~) ~ ~~ I".) BETH A. BAIT8ELL, aim BETH A. YEING8T, Plaintiff = THE COURT OF COMMON PLEA8 OF = CUMBERLAND COUNTY, PENN8YLVANIA = CIVIL ACTION. LAW Y. . . = NO. 2008 - 5852 CIVIL TERM DAVID E. BAIT8ELL, Defendant . . = IN DIVORCE AFFDAVlT OF CON.IINT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or about October 11, 2006. Personal service of the complaint was made upon defendant on or about October 12, 2006 (see acceptance of service filed herewith). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended 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. January ~, 2007 ~a.~ BETH A. YEINGST WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 33011c) 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. January 7..-.9. 2007 ,~o BETH A. YEINGST . fj~~ o ~~ ~' r-..:> = = ......J <- o -n -\ ...,.. m:JJ - s; :go ,...... I, -:.;J Sf~ ,~J5 t)fn ,,"-' 'J.."" ~ :1="" :;;: N \.0 -0 ....,. ....... .r:- -J BETH A. BAITSELL, aka BI!TH A. YEINGST, Plaintiff : THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . : CIVIL ACTION. LAW Y. . . : NO. 2008 - 5952 CIVIL TERM DAVID E. BAIT.ELL, Defendant . . : IN DIVORCE AFFDAVlT OF CONSENT 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed in this matter on or about October 11, 2006. Personal service of the complaint was made upon defendant on or about October 12, 2006 (see acceptance of service filed herewith). 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the service of the amended 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. January~, 2007 iLJ i ~j DAVID E. BAITSELL 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. January ~ 2007 ~~~~ DAVID E. BAITSELL r"o-' = = -.. L- ~ Z o -n :I! rn"'1'1 -or;:; :uy ~~:;:~ (:) ~~} ~~ :sm :::.\ J.-... :-.0 -< N \.D -0 --r.... r -.I BETH A. BAIT8ELL, aka BETH A. YEIN08T, Plaintiff : THE COURT OF COMMON PLEA8 OF : CUMBERLAND COUNTY, PENN8YLVANIA : : CIVIL ACTION. LAW Y. . . : NO. 2008 - 5152 CIVIL TERM DAVID E. BAIT8ELL, Defendant . . : IN DIVORCE ACCEPTANCE OF SERVICE I, DAVID E. BAITSELL, defendant in this divorce action, hereby certify that I received a certified copy of the complaint in divorce on or about October 27,2006, by certified mail addressed to me at 1070 Myerstown Road, Gardners, PA 17324. I verify that the statements made in this acceptance of service 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. January ~, 2007 ~)j)t-g:tJ) DAVID E. BAITSELL Defendant r--.> = = -.J <'- ;I> :.z: N \.0 o -n ~-n f11p -nnl :1')0 ~?C:l ~--,- .,"+ ~~5 ,-,m \"._J ;:;;,-1 ,''''' ::0 -< -a :Jr: .r:- CD HAROLD S. IRWIN, III, ..QUIRE ATTORNrt ID NO. 28820 M SOUTH PITT STREET CARLISLE PA 17013 (717) MMOH ATTORNrt POR PLAINTIFF BETH A. BAIT8ELL. aka BETH A. VEIN08T. Plaintiff = THE COURT OF COMMON PLEA8 OF = CUMBERLAND COUNTY. PENN8YLVANIA = CIVIL ACTION - LAW v. . . = NO. 2008 - 5952 CIVIL TERM DAVID E. BAIT8EL'" Defendant . . = 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 October 12, 2006 defendant was served with a copy of the divorce complaint by U.S. Certified Mail (see Affidavit of Service previously filed). 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301 (c) of the Divorce Code: By the plaintiff: January 29, 2007 By the defendant: January 29, 2007 (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 5. Complete either (a) or (b): (a) 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: January 29, 2007 Date defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the Prothonotary: January 29,2007 February L. 2007 HAROLD S. IRWIN, III Attorney for Plaintiff r-:> <.=:? (~'~,:;) -..J -r1 rl c:J l o:;l -0 -:0...;.0.. N . . C) ..r.:- '" '" IN THE COURT OF COMMON PLEAS Ol; OFCUMBERLANDCOUNTY '" PENNA. STATE OF BETH A. BAITSELL, aka No. 2006-5952 CIVIL TERM BETH A. YEINGST, Plaintiff VERSUS DAVID E. BAITSELL, Defendant Ol; Ol; Ol; Ol; Ol; 'to 'to 'to '" 'to 'to 'to 'to 'to Of. Of. 'to Of. Of. 'to 'to 'to '" 'to 'to 'to Of. DECREE IN DIVORCE AND NOW.~ I~ ~7, IT IS ORDERED AND DECREED THAT BETH A. BAITSELL, aka BETH A. YEINGST , PLAI NTI FF, DAVID E. BAITSELL , DEFEN DANT, AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. Of. 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 'to 'to 'to Of. Of. Of. Of. Of. Of. ATTEST' ~ J. ~~. . PROTHONOTARY Of. Of. '" Of. Of. Of. 'to 'to 'to 'to Ol; 'to Ol; Of. Of. Ol; ft; ft; '" ft; Of. Of. Of. '" Of. ft; Of. ft; Of. '" '" ft; '" ft; ft; [Ii [Ii ,,;'" .~ .~ ~ b ~ ~~;t., L<1' (fC' I:!) ~ fr -? ~ ~ - rr; d- r:I . e . . .. . ...... .~ ~ .",-