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HomeMy WebLinkAbout02-2855MICHELLE L. BAUGHMAN, Plaintiff DONALD W. BAUGHMAN, JR, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA : NO. 2002- 2-£,¢~/ CIVIL 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 of your children. When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prethonotary's Office at the Cumberland County Courthouse, 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, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 MICHELLE L. BAUGHMAN, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY PENNSYLVANIA v. : NO. 2002- g-~%'/ CIVILTERM DONALD W. BAUGHMAN, JR, Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301© OR (D) OF THE DIVORCE CODE Plaintiff, Michelle L. Baughman, by her attorney, Lindsay D. Baird, Esquire, sets forth the following: 1 Plaintiff, Michelle L. Baughman, is an adult individual residing at 192 Birch Lane, Carlisle, Cumberland County, Pennsylvania 17013. 2 Defendant, Donald W. Baughman, is an adult individual residing at 213 Birch Lane, Carlisle, Pennsylvania 17013. 3 The parties were married on June 15, 2000 in Cumberland County, Pennsylvania. 4 Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the commencement of this action. 5 This action is not collusive. 6 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 7 In accordance with Section 3301© of the Divorce Code, the marriage between the parties is irretrievably broken. 8 Plaintiff has 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. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. , /Lindsay D~.. ird, E~uire L// Attorney for the Plaintiff 37 S. Hanover Street Carlisle, PA 17013 71'7 - 243-5732 I verify that to the best of my knowledge and belief, the statements in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS §4904 relating to unsworn falsificatiTt~aut~hori~,~s. ~ Mic~elle L. Bau~h~ O