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HomeMy WebLinkAbout94-05475 "- \ t, tV ~ d c!J . -7 ~ ~ E: (~ ~ ,j \.r) f'- ;;; , ~ / . ~ ~ ',' .~,~,.~.*,~,.~..~.~..~.-~.~..~.-~-~~..~-~.~.~.:~ ~ -' . - -'. '-, ~ ~ :.;. .:.;. -:.;. -:.;. <.;, -:.:- -:.;. .~.;. <.:. ',. ~ '';' (~ ~, ~. ~ *' ~: . , , ' ~ IN THE COURT OF COMMON PLEAS ~ ~ ~ :;- ~ . ~;. ,~:. .~:' ':.:- OF CUMBERLAND COUNTY ":'i ~~,o.M '~,~:f~/:r PENNA. STATE OF ~ ~ James c. Baker, ..,11)94 l'\ II " 5475 ~ Plaintiff ~I ~. \" "1'''11.'' Joo Baker, ~ Defendant .;, ~ ~; ) ~) ') ~~ , , ~I : i ~: DECREE IN DIVORCE AND NOW, ~~. ?,().." 19.""".,. it is ordered and decreed that., ,J'Il]1eS .c.. .B,'Il$er.....,."..""""",.,."",. plaintiff. and...".. . ,';99. .1;l<:1!<.er,. .. ..., .,., ". ...,.""".. defendant, are divorced from the bonds of matrimony. !Ill ~.' .", ~ ~ ~ ',' ~ ~ ~ ~ ',' 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; V(9~ ~ '.' ~ ....."..,::::::>~?1:.'::::::::::,: ~ ',' ,-', 1. '-;- ~ ,;, r.' ~ .,' ^ltl'~I: '~ , . ' . .' /' r/ ,I. J p. :"'" (,-.,I;("lr'7 . r ' . / / ,,/_~ (, ,(..i' 1':, / ,prothonotary .~ , , ill i :' )~ I.;, I.., .;, " ~ .;, " ,;, " ~ ~ ~ ~ ~ ~ '.' .;, " ,;, " ,;, I; , " ..~ ',' ~ .~ ~ '" ., ~ ~ ~ ~ I.., '~ r.. i~ . ~ ~ ;~ ,~ ~ ~ ~ ~ ~ ~ :to:. ,~~, '..:- .:.:. -:.:. -:.:-:.:. :.:- <.. -:.:, .:.;. -:.:- .;.:. -:.:- .:.:. .:.:.:.:. .;.:-:.: :0&;' .:.;. ':.:. -:.:. .;.;. .:.:. .:.:- . . SAID IS, GUIDO, ii SHUFF & MAS LAND 26 W Uiw,h SUcCI Carlislt:. PA i , , , I I I I I I I II I JAMES C. BAKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94-5475 CIVIL TERM JOO BAKER, IN DIVORCE Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together wi th the following information, to the court for entry of a divorce decree: II 1. Ground for divorce: irretrievable breakdown under S3301(c) of the Divorce Code. 2. Date and manner of service of Complaint: Certified Mail. Restricted Deliverv on September 30. 1994 I [I II I I I I I, " II ,. ii i I' , i! H , (See attached Exhibit "A"). 3. (a) Date of execution of the Plaintiff's Affidavit required by S3301(c) of the Divorce Code: by the Plaintiff i by Defendant Date of execution of the Plaintiff's (b) (1) Affidavit required by S330l(d) of the Divorce Code: N/A ; (2) date of service of the Plaintiff's Affidavit upon the Defendant: N/A . Related claims pending: None 4 . Ii II !i ", ~\ Attorney for Pl~intiff :i :1 " Date: 12/29/94 d .. '"":.r en - ..._,. H) l'. ...::-, ("--., , -J u '" C:..) " v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-1)</'75 CIVIL TERM JAMES C. BAKER, Plaintiff JOO BAKER, Defendant IN DIVORCE NOTICE You have been sued in court. If you wish to defend against I 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 I proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered I 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 I children. II I II , I I I I 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 BEP'ORE 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 YOll 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. I II II I, iI I! 'I SAlOIS, GUIDO, Ii SIIUFF & II MAS LAND !I ii II II II il II Cumberland County Court Administrator One Courthouse Square Carlisle, PA 17013 (717) 240-6200 26 W High Sln:1:1 Carlilih:.PA SAIDISX""l' '",SLAND By: .c:~~ Edward E. Guido, Esquire Supreme Ct. 1.0. * 21206 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94- 5'17'5 CIVIL TERM JAMi!:S C. BAKER, Plaint-iff JOO BAKER, Defendant IN DIVORCE COMPLAINT UNDER SECTION 33011c) OF THE DIVORCE CODE 1. Plaintiff is James C. Baker, who currently resides at the Pike Motel, Carlisle Pike, Cumberland County, Pennsylvania. 2. Defendant is Joo Baker, who currently resides at 1014 Ritner Highway, Carlisle, Cumberland County, Pennsylvania where she has resided continuously since June of 1980. 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 June 20, 1960 in Seoul, South Korea. 5. There have been no prior actions of divorce or for ~nnulment between the parties. 26 W. High Slf(~1 Carlisle. PA 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 SAID IS, GUIDO, SHUFF & I\IASLAND Court to order counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce. Date: ~71 ,:x.-/-t4 Respectfully submitted, -~ // By: c:" ~ Edward E. Guido, Esquire Supreme Ct. 1.0. # 21206 26 West High Street Carlisle, PA 17013 (717) 243-6222 Attorney for Plaintiff Ii ij il SAlOIS, GUIDO, Ii 'I SHUFF & 1,,1 MASLAND i' 26 W HI&h s""., ,I Carlulc,l-'A !I II II il 2 Ii i il i , , I I I AFFIDAVIT I, James C. Baker, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counselling and understand that I may request that the court require that my spouse and I participate in counselling. (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) Bei.lg so advised, I do not request that the court require that my spouse and I participate in counselling 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: 1/J(.,! ~ 1-/ 'I /. p.,..rr (/ .I)..st ~...._-- Ja~es C. Baker, Plaintiff I 'I II II :I SAlOIS, GUIDO, Ii SHUFF & II MASLANO II 'I II II I I ! 1 ; 26 w. High StTect Carlislc:.PA 3 j I il I I 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 l~ Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: ,[/-1; 'r /7 1..( I j ..-/' ~--- If /...J-r:r J~mes C. Baker, Plaintiff I I I, i[ Ii II II SAIDIS. GUIDO, II SHUFF & ii I\fASLAND !i 26 w. HiVh Street II C.uh\I~. PA II II II il I, li !! )j " 'i ;; , ,I 'I 4 ..-'0 ;,- J :t: '+ <t <:f. '(; -1j 1- . J'j I <l.. ~ - c.., 0 0 r tr .. 0 In - ~,.., ~- \0 0 r :r ~ ;.'l vi In 0 0 ~ , r- Oc (1 - gr; 1:l .:rl ~ I :i -L 1.1 ..J . ~ I \ \ ~ j I l , . , f' i -, SAIDIS. GUIDO. SHUFF & MASLAND 26 w. Hl~h Slm:l Carli"I",I-'A JAMES C. BAKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94-5475 CIVIL TERM JOO BAKER, Defendant IN DIVORCE AFFIDAVIT OF CONSENT i I II ~ Divorce Code was filed on September 26, 1994. II !I " II il !I 'I II II II il :1 " Ii Ii !I il 'I I: I I II :1 Ii (1) A Complaint in divorce under Section 3301(c) of the (2) The marriage of Pla~ntlff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. (3) ( 4) I consent to the entry of a final decree of divorce. 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. 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. if Dated: , t.._~ c; Ji-T-'-/v..-r- ~ames C. Baker, Plaintiff 12/2CJ/CJ4 SAlOIS, GUIDO. SHUFF & MASLAND 26 W, Hillh Sllerl Carh~lc. PA JAMES C. BAKER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94-5475 CIVIL TERM , ;1 JOO BAKER, ,I il , Defendant IN DIVORCE i I AFFIDAVIT OF CONSENT TO DIVORCE II II (1) A Complaint in divorce under Section 330l(c) of the [ DIvorce Code was filed on September 26, 1994. I I i (2) Defendant a:::knowledges that service of the Compl.3int was ~ made by certified wail on September 30, 1994. Ii II ii il i i i i II !I II il I II II III (7) I have been advised of the availability of marriage counselling and understand that I may request that the court !I . II require that my spouse and I part~cipate in counselling. Being ~ so advised, I do not request that the Court require that my " spouse and I participate in counselling prior to a divorce decree ii being handed down by the Court. il (3) The marriage of Plaintiff and Defendant is broken and ninety days have elapsed from the date Complaint. irretrievably of filing the (4) I understand division of property, them before a divorce that I may lose rights concerning alimony, lawyer's fees or expenses if I do not claim is granted. (5) I consent to the entry of a final decree of divorce. (6) I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the court before the entry of a final decree in divorce, the right to claim any of them will be lost. 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. Dated:_JZ- 2.fI-YY .~ Joo Baker, ~ Defendant