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Home My WebLink About02-4929DANA LYNE MILLER, Plaintiff VS. JOSEPH DONALD MILLER, JR., Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2002- .qq29 CIVIL ACTION - LAW 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 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. 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, PA 17013 (717) 249-3166 1-800-990-9108 14_ DOlq p~LD MILLEI~, lOSE? Defendant COX.¥1_.pLAi_~NT 1~ DI~oP'CE adult individual whose mailing address Dana Lyne Miller, an pennsylvania The plaintiff is County, l. is 17 South Baltimore Street, Franklintown' Adams 17323, and whose social security number is 200-65-9056' 2. The Defendant, loseph Donald Miller, Jr., is an adult individual, whose current address is 34 West Keller Street, Mechanicsburg' cumberland County, pennsylvania 17055, and whose social security number is 2lt-56' 8548. 3. plaintiff and Defendant were married on lune 20, 1998, in MechanicsbU Cumberland County, pennsylvania' 4. Plaintiff and Defendant have resided in the Commonwealth of Pennsylvania for a period of at least six (6) months prior to this filing. 5. Defendant is not a member of the Armed Services of the United States or its allies. 6. Plaintiff is a citizen of the United States and Defendant is a citizen of the United States. 7. There has been no prior action for divorce filed in any jurisdiction. 8. Plaintiff has been advised of the availability of marriage counseling, and has waived said right. 9. There is one minor child born of the marriage; namely, Damon Tyler Miller, born November 4, 1996. 10. Plaintiff avers that the grounds on which this action is based are: (a) That the marriage is irretrievably broken. WHEREFORE, Plaintiff respectfully requests your Honorable Court to grant a Decree in Divorce. Respectfully submitted, Arthur K. Dils, Esquire 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 07056 Date: October 8, 2002 VERIFICATION I verify that the statements made in this Complaint in Divorce are true and correct. I understand that false statements herein are made subject Section 4904 relating to unsworn to the penalties of 18 Pa. C.S. falsification to authorities. DANA LYI~I~LER ' Date: October 8, 2002 DANA LYNE MILLER, Plaintiff VS. JOSEPH DONALD MILLER, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2002- ?'"/%d 7 c'q,;/, /-- CIVIL ACTION - LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Joseph Donald Miller, Jr., hereby accept service of the Complaint in Divorce under Section 3301(c) of the Divorce Code on this /O ~'£ day of October 2002. BY..,.. / < agseph Donald Miller, DANA LYNE MILLER, Plaintiff VS. JOSEPH DONALD MILLER, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2002- z/'Sd ;~ ~.v, ~' CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 9, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: /, j ~c.,i O,,. Dana Ly~,334~ller,VPlai~ti ff DANA LYNE MILLER, Plaintiff VS. JOSEPH DONALD MILLER, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2002- 9/9=2 5? c/~,~ CIVIL ACTION - LAW IN DIVORCE 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 in 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 Waiver 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 falsification to ~thorities.J x~ d ~ ,~oMy t~/Z j?,~/,/7~,( Date: /,~//,/o ~e ~-T~t Dana Lym(M~il~ir, Plaintiff - DANA LYNE MILLER, Plaintiff VS. JOSEPH DONALD MILLER, JR., Defendant 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2002- P/Po) 9 C,'o, {~ CIVIL ACTION - LAW IN DIVORCE o AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 9, 2002. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa. C.S. {}4904, relating to unsworn falsification to authorities. Date: //////8 ,_.7 J,o~h Donald Miller, J~i, D~ele~ant DANA LYNE MILLER, Plaintiff VS. JOSEPH DONALD MILLER, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2002- '-/~d_ ~ C~,~',~ CIVIL ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301( c } OF TI-IE DIVORCE CODE 1. I consent to the entry of a final Decree in 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 Waiver 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 fi ............ alsffica!~ti to ah'tkontles. Josepli t)onald Miller, Jr.~ tJ[f~n~a~ x DANA LYNE MILLER, Plaintiff VS. JOSEPH DONALD MILLER, JR., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 2002 - 4929 Civil Term CIVIL ACTION - LAW 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: Irretrievably broken under Section (X) 3301(c) or ( ) 3301 (d) of the Divorce Code. (Check applicable section) 2. Date and manner of service of the Complaint in Divorce: By Acceptance of Service on October 10, 2002. 3. [Complete either Paragraph (a) or (b).] (a) Date of execution of Affidavit of Consent required by Section 3301(c) of the Divorce Code by Plaintiff, January 11, 2003; by Defendant, January 11, 2003. (b) Date of execution of Plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: N/A; Date of service of Plaintiff's affidavit upon Defendant: N/A. Date of service of Notice of Intent to Finalize under Section 3301(d) of the Divorce Code: N/A; Date of filing of Waiver of Notice of Intent to Finalize by Plaintiff: Simultaneously herewith; by Defendant: Simultaneously herewith. BY: 5. Related Claims Pending: None ~rthur K. Dils, Esquire 1017 North Front Street Harrisburg, PA 17102 (717) 232-9724 I.D. No. 07056 Attorney for (x) Plaintiff ( ) Defendant IN THE COURT OF COMMON PLEAS OF CUMBeRlaND COUNTY STATE OF ~~~, DANA LYNE MILLER, P1 mJnl-J fF VERSUS JOSEPH DONALD MILLER, JR. Defendant NO. PENNA. 2002-4929 Civil Term DECREE IN AND NOW, DECREED THAT DIVORCe ~ ~ :( , __, IT IS ORDERED AND __, PLAINTIFF, AND JOSEPH DONALD MILLER, JR. , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; N/A PROTHONOTARY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff Vs File No. a~~d -~ ~e~ ~-~ ~' fi 1ZVy~ IN DIVORCE ~(~nh (~rirt~(~1~1~I1~t~~i. Defendant r; __ NOTICE TO RESUME PRIOR SURNAME ` ~_ , ,; :~ r~.: _:_, :.. Notice is hereby given that the Plaintiff /defendant in the above matter, , „ ~= ~ ~-~' [select one by marking "x"] prior to the entry of a Final Decree in Divorce, ~'~ ~ " _~ or -~ after the entry of a Final Decree in Divorce dated ~( , ~ (j()~, ~ ~ ` hereby elects to resume the prior surname of (~ G, h G=~} n C I~f n Gc I~t-{- ,and gives this written notice avowing his /her intention pursu t to the provisions of 54 P.S. 704. Date: ~ ~ ~~ S gnature S' n ure of name being resumed COMMONWE LTH OF PENNSYLVANIA ) COUNTY OF On the ~4`~day of , 201D ,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 acknowledged that he /she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand hereunto set my hand and official seal. Notary ublic _ ~ I i. oo P p Pc,~F w a~~ ° w"a~a~ case ~' a3(o4~18 +!~"~~