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IN THE COURT OF COMMON
PLEAS
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OF CUMBERLAND COUNTY
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STATE OF
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James c. Baker,
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5475
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Plaintiff
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Joo Baker,
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Defendant
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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.
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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;
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SAID IS, GUIDO, ii
SHUFF &
MAS LAND
26 W Uiw,h SUcCI
Carlislt:. PA
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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
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(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
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Attorney for Pl~intiff
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Date:
12/29/94
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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.
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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.
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SAlOIS, GUIDO, Ii
SIIUFF & II
MAS LAND !I
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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,
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By: c:" ~
Edward E. Guido, Esquire
Supreme Ct. 1.0. # 21206
26 West High Street
Carlisle, PA 17013
(717) 243-6222
Attorney for Plaintiff
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SAlOIS, GUIDO, Ii
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SHUFF & 1,,1
MASLAND
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26 W HI&h s""., ,I
Carlulc,l-'A !I
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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-/
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p.,..rr (/ .I)..st ~...._--
Ja~es C. Baker, Plaintiff
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SAlOIS, GUIDO, Ii
SHUFF & II
MASLANO II
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26 w. High StTect
Carlislc:.PA
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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:
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J~mes C. Baker, Plaintiff
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SAIDIS. GUIDO, II
SHUFF & ii
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26 w. HiVh Street II
C.uh\I~. PA II
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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
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~ Divorce Code was filed on September 26, 1994.
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(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:
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~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,
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Defendant
IN DIVORCE
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I AFFIDAVIT OF CONSENT TO DIVORCE
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II (1) A Complaint in divorce under Section 330l(c) of the
[ DIvorce Code was filed on September 26, 1994.
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~ made by certified wail on September 30, 1994.
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III (7) I have been advised of the availability of marriage
counselling and understand that I may request that the court
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~ 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.
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(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
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Joo Baker,
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Defendant