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Home My WebLink About00-02113 ", ,-, "~ ~ " , , , , , , , , , , , , , , , , , , , '" '" "':l: :l: :l: iF.:l:iF. if. , :l: :l: :Ii :Ii :l:iF. if. if. , , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY CHRISTINE MILLER PENNA. STATE OF Plaintiff No. 00-2113 CIVIL TERM VERSUS DARBY D. MILLER Defendant , , , , DECREE IN DIVORCE , AND NOW, , -<1# ~,.,__ fAr J CHRISTINE MILLER , PLAINTIFF, , '2-<>01 Z? , IT IS ORDERED AND DECREED THAT , AND DARBY D. MILLER , 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; , , , NONE , , , PROTHONOTARY , , OURT:/l ~ , , , , . , , , , , , ,. , , , if. iF.:I; ;+;;F. ,. ~ "< ~" """',j '" I' jj n .'1 11 II " 1; II I' " I 11 Ij !1 !i I,! Ii I IJ II , " i-! II I' !j " I' :l: :l: :l: if. , , . , , J. , , , , , , , , , , , , , , , . . , , , , . , . . . . , , , , . , , , , , , , , , . . , , , , , . , , , , , , , , . , , , . . , , , , . , . . -'""'_.0:,""""""_" 9 ;;27.?11 1jc})C!/ ,. " '~'I' ~~ ~ M-Lo/ ~ ?f'4 tV~ 71~~Z:ii~ ,,_" _-.0' ,.. - -' ..~~~ T"'""~>-<~'~' "",,,~"'~"""'_~~~", _, \'lII!"I:I_ ~~i ,!,IIlIl'lllll!._ ~ I ,u~- -=-~ y "~M'O .' . - '~<",_Uk";,;'i;'i;;;' CHRISTINE MILLER, . IN THE COURT OF COMMON PLEAS OF . Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA .!, vs. . No. DO - ~IJJ (30l'[ ~~ . : DARBY D. MILLER, . CIVIL ACTION - LAW . , ' Defendant . 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 ~ntered 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 Jmportant to you, including custody or visitation of your children. I When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage ~ounSeling. A list of marriage counselors is available in the i Office of the Prothonotary at the Cumberland County Courthouse, i 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. I I 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 LIHERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Ii .. ~, -1-'" <- ~':'zf.#e);i;;:!~ -~.~' -' 11'--_'_ ~" , H CHRISTINE I MILLER, Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA No. I}-tJ - ..2/13 CWJ ~ . . vs. . . i I DARBY D. MILLER, Defendant . . : CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTIONS 330l(a), 330l(c) or 330l(d) OF THE DIVORCE CODE COUNT 1 - DIVORCE The Plaintiff, Christine Miller, by and through her attorneys, The Law Offices of Patrick F. Lauer, Jr., makes the following I , Complaint in Divorce: 1. The Plaintiff, Christine Miller, is an adult individual who currently resides at 4533 Gettysburg Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. The Defendant, Darby D. Miller, is an adult individual who currently resides at 223 Wood Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Parties have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The plaintiff and the Defendant were married on April 9, I ~988 in Cumberland County, Pennsylvania. I 5. There have been no prior actions I I annulment between the parties. of divorce or for 6. The marriage is irretrievably broken. i I , , " II' -'~ r c =~" ~- ,c.;;,~M'; 7. The Plaintiff has been advised that counseling is I available and that the Plaintiff may have the right to request that I ' the court require the parties to participate in counseling. a. This action is not collusive. 9. There are two minor children to the marriage, Amber R. i I Miller, , , age 12 and Morgan T. Miller, age 5. The parties intend to make independent arrangements concerning the custody and visitation of the children. WHEREFORE, the Plaintiff requests this Honorable Court to enter a Decree of Divorce in this matter. COUNT III - EOUITABLE DISTRIBUTION 10. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 11. Plaintiff requests the Court to equitably divide, distribute or assign the marital property between the parties as the Court deems just after consideration of all relevant factors. pursuant to S3502(a) of the Divorce Code. COUNT VI - ALIMONY AND ALIMONY PENDENTE LITE S 3702 I I J y 12. All preceding and succeeding paragraphs are incorporated reference. 13. The Plaintiff is the dependent spouse and Plaintiff lacks sufficient , I , i Ilrable to : : employment. I, ! property to provide for her reasonable means and is support herself completely through appropriate -'J!"dlj_i-1>_li;i<'%!o!l_'; 14. Plaintiff requires reasonable support to adequa,tely maintain herself in accordance with the standard of living j 'l!stablished during the marriage. , WHEREFORE, the Plaintiff requests your Honorable Cour"t to , enter an aware of reasonable alimony upon final hearing and I permanently thereafter. ubIllitted, ~ Matthew J Eshelman, Esquire Law Offic s of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 ID# 72655 Tel. (717) 763-1800 Date: , , I '.-"~--~ - ,- ~.uJ ~ iIiIlIii ~ ~@I_ CHRISTINE MILLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . vs. No. . . DARBY D. MILLER, . CIVIL ACTION - LAW . Defendant : IN DIVORCE 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 18 Pa.C.S. S 4904, relating to unsworn falsification to authorities. Date: lJ/{s/CXJ t () f4 Signature: /I~>4iuu.... tXl/'1€L., Christine Mill r ,w~ , ~~ .- ~" :l,H CHRISTINE MILLER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 00-2113 CIVIL TERM DARBY D. MILLER, Defendant : CIVIL ACTION - LAW : DNORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for Divorce: Irretrievable breakdown under ~3301(c) of the Divorce Code. 2. Date and Manner of service of the Counter-claim in Divorce: Service by certified mail no. Z 104 208 836 on September 25, 2000. See attached Affidavit of Service. 3. Date of execution of the Affidavit of Consent required by ~3301( c) of the Divorce Code: by the Plaintiff: 9/10/2001; by the Defendant: 8/27/2001. 4. Related claims pending: None. 5, Date Plaintiff's Waiver of Notice in ~330 1 (c) divorce was filed with the prothonotary: filed simultaneously with this Praecipe to Transmit Record Date Defendant's Waiver of Notice in ~3301(c) divorce was filed with the prothonotary: filed simultaneously with this Praecipe to Transmit Record Respectfully Submitted: J e B. Costopoulos, Esquire Attbmey for Defendant 1400 N. Second Street Harrisburg, PA 17102 Phone: (717) 221-0900 PAS.Ct. IDNo. 68735 Dated: f /17/ ZtMJ EiiIlllflllllll :$~~!~~J&}iI<l_m,,~~"~"~ -:liillil ~L. '.;c" ......~ ~t.. ~,.~""""~-- 0 CJ (-, C .J -71 ~ </) urn f"1 ' . m['fl -0 !~;::;~ Z r"~ , z,e N ~;)r~ ~':? L~ ......- ~C! ".~<() -0 ~];::p ;;eo 2 ~;~~ ~o :Pc z U1 ::~ :<! ':0 ,..;J =< ~- ~. ~ }[ ~, CHRISTINE MILLER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. No. 00-2113 CNIL TERM DARBY D. MILLER, Defendant CNIL ACTION - LAW DNORCE AFFIDAVIT OF SERVICE TO THE PROTHONOTARY: I, Jeanne B. Costopoulos, Esquire, verifY that a Counterclaim in Divorce was served upon the Plaintiff indicated above c/o her attorney of record, Matthew J. Eshelman, Esquire, on September 25, 2000, by first class, Certified Mail No. Z 104 208 836, postage prepaid, return receipt requested, ,..,_",tOO _""'ofPaRC.P. !1930~~ By: . ------ J~ . Costopoulos, Esquire Attorney for Defendant 1400 N. Second Street Harrisburg, P A 17102 Phone: (717) 221-0900 PA S.Ct ill No. 68735 Dated: 1f7/~1 ''Q SE DER: ':5! -Complete items 1 and/or 2 for additional services. en -Complete items 3, 4a, and 4b. CD -Print your name and address on the reverse of this form so that we can return this ! ~~~u. _ = -Attach this fonn to the front of the mail piece, or on the back if s~e does not I! pennit. ' ~ CD -Write"Retum Receipt Requested" on the mailpiece below the a ,e number. ,I; -The Return Receipt will show to whom the article was delivere and the date ~ delivered. o '0 ~ C. E o " Ul Ul w a: c c 0( z . 3, Article Addressed tOy J) \ A I &J(} 4a, Article Number '" IV 1Cv,3 I {f\ 0::1Jd1e.uJ "-.J, L'J e. fr>1V1, // 16 I'D l-f v cJ d' p ~ 0 $< (Y\ o...r 16~~:6 &t 4b, Service Type I 'II P LL i 71) I J 0 Registered sa- Certifled CJ}.J'>' fJ <I>J 'I n 0 Express Mail 0 Insured o Return Receipt for Merchandise 0 COD 7, Date of Delivery ~,..- r{/O -Jj 8, Addressee's Address (Only if requested and fee is paid) I alsO wish to receive the following services (for an extra fee): Ii 1, 0 Addressee's Address '1: 2, g Restricted Delivery ell a 'il " a: c ~ " 1; a: Ol c OJ " ~ o - " g, '" C .. .c I- Consult postmaster for fee. Domestic Return Receipt + i!.lMd ~'t1= ,~,,,,,,,,,",\~___.~.~-;, Lii6li,_~~"'iIl~hillJrJ,\i,iih,"">il:;*,'2lMjdio\j~.' ,; ~', ~ll~"""~G.o~ Iiiillld- , , _...:.0 i.1" ~" c (') 0 0 C ,1 s:: U> ~-1 "'0 OJ ,., T mrT'J " ;:.;::;ll Z::D 'r- ze- N -1:-; rYJ ~J;; ;;.;;'1" t;CC) '-~:~G? -0 ' c, )> ::t: ;:5".~ ZO ,-Co -=0 Om )>c Z oc-; :< ;{,J'1 ~ 0 -,"""'""--"-- ,1: " ,. '~ " !:l' , "i 1 " 4 ,f,- ~ i ~ 1 -j ;'jj, I (~ , 1 " 1:',' , I ;]' , ~1r ;~; j! T -',i , .,' " 'i " , :,: ;;i J { f l .~ i I -,"",v,,;, CHRISTINE MILLER, Plaintiff IN THE COURT OF COMMON PLEl~ OF CUMBERLAND COUNTY, PENNSYLVANIA No. 00-2113 Civil Term vs. DARBY D. MILLER, Defendant CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(0) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301 (c) of the Divorce Code was filed on April 7, 2000. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. 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. ~ 4904 relating to unsworn falsification to authorities. Date: II-/IJ-/)/ Signature: ~.A./'..z-j;~L ~;j h~.... Christine Miller . ~.__l.' 1,_~',\I_~;~'1I!l1~!liili_li!~~_~Ii!!M,J_'1!ti'.%L"",81~~!!;i~',_).Ii"i;;[;'jllI~1i!lIIlI/,;, ~, ~- 11II llll n,,_[~ , , L _,.: _._._1~: ,:. 3 0 0 " <"" U') -0$ J'"'1 :::-J mrr: -0 ~-\:;Q Z::D Zt;; N ;Li ~:2 C:J r:r~.' ,0 ~~; -0 -'--"-'1 ~ -.'---n C::;J-- ".-0 -:7 C) Pc (Sin Z U1 s;! ~ :JJ l::> -< " ";''''~~ I. " ,~ :f t I' ,j,:: ;j,: f '~ ~fi I' f t t L , .1: F -l 1 I t l \ i " t I l , f i' j f ~ ! I. ,.,f", ~; f , 1 t 1 'j, 1 l i ~~ { :;- f i i~; '1 f 't I' ~ ; 1 -if l~~L CHRISTINE MILLER, Plaintiff IN THE COURT OF COMMON PLEl\S OF CUMBERLAND COUNTY, PENNSYLVANIA No. 00-2113 Civil Term vs. DARBY D . MILLER, Defendant CIVIL ACTION - LAW IN DIVORCE PLAINTIFF'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301 Cel 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. 4. 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. ~ 4904 relating to unsworn falsification to authorities. Date: IJ-/O-I)/ Signature: (J!v,./A1;b/ t:(! J hA....._ Christine Miller II i!!iiiI!.t...........' bo .iJi~~j~~,~IJffi!l.tllfiWll~#;,M.~b","~I:iolJcll__'I)i~"*"~"""_j;L_'-&"'l<!I__, ij _.'fi!"iJi:am.'R%i~~~illllilliilii@;l - ~ :r ".U ~:r"'":CYU~.lUlI "oii.j 0 0 () C 'n -~ U'> """ --1 -00:; fT1 ?~~~ mrn v Z::C' Z""-- N =~8 Ct?"> .-';:" I -<L ~j:~~~ r::.,'l ~~~ .." ~O ~- -C' 0 f~m 5>c ,...) ~ U1 :;;t -< (:;J :5! ._~ " "lii" CHRISTINE MILLER, Plaintiff : IN THE COURT OF COMMON PlEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 00-2113 CIVIL TERM DARBY D. MILT .RR, Defendant : CIVIL ACTION - LAW : DNORCE DEFENDANT'S AFFIDAVIT OF CONSENT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND WAIVER OF COUNSELING 1. A Complaint in Divorce under Section 3301( c) of the Divorce Code was filed on April 7, 2000 and a Counter-claim in Divorce under Section 330l( c) of the Divorce Code was filed on September 18, 2000. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint and the filing and service of the Counter-Claim. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. 4. I verifY that the statements made in this Affidavit are true and correct I understand that Date: .9<;)'7- 0 I Signature: false statements herein are made subject to the penalties of 1 unsworn falsification to authorities. Sworn to and subscri~ to Qoremethis ..:21 day of , "914$.1: .2001. ,~~ k~J4iM;~ Notary Public NolarIalSeaI SharOn L. Reisfnger. HoI!YY Pubffc HalTlsburg, DiiuphlnCoUnly My Commleslon Expl18sJan. 19. 2004 8m," a n --Xffij.~~.i.,...,."~~ltl~~__rlD~~B:IJ.lMiHJ!MI~_!.illIIW4'iW!lM__-~~~ll.'tt1;\fd-" ~" . "-_~r__' , _ ,,~"'"' ",' <f"c . ,"'_, , t_"' '""" ~~~~--..,..,~ ~ ~'" .~ - W:(J_~"" '---'" (:) 0 0 C """ " -Ow U'} --I mn~~ ,..,., i~-{~i2J 2::r; " 2 -' N cn'~; Jr;'l C']O r:si'~ ':-) 1 :.:-0 ;'i! "U ,~ I, ~(:) ~~ --0 Pc ~ -,I ~'1 ?is Cl -< ,:,- , Ii! "'" ._.- ~~" . ~ , .'--'-;;:!iIP.io' CHRISTINE MTT.T .F.R, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 00-2113 CIVIL TERM DARBY D. MILLER, Defendant : CIVIL ACTION - LAW : DIVORCE DEFENDANT'S WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301W 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 in 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. 4. 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 18 PaC.s. ~904 relating to Signature: unsworn falsification to authorities. Dated: '8 -,)1-01 Sworn to and su~~ to ~fore me this ..:2. '1 day of . , \; l~i::: . 2001. '-~ "^,,, .~~jQ^-, Notary Public NotarIal Seal Sharon L. ReislI1g8f, Nol;lry Public My~=~2004 , nnsy n a SSOOia a as H~IiNIlJlI~' ~__~_:)!I~H""1'-",,, Jl\t;.M!ffil:fl~Hi.~_lliiillill~E-Ki;;~&-dci\&1l>-_:',HOlliJi-,,;-.tili~""JlIj-',j~bc;,-;;,g,!1!>~_1 ' "'~ ~~" '>=0" q.. ~~9_ . c '_ ~ I' ~" " " .. ..... (') 0 0 C " s::: en ,~ "0 OJ r>'l S2{;l'1 V r-'J:"i l:;g .:J:_1 z~' N -.'] rT' ~:': "'ld ",", ~~~ k'C) ,J :E::C ~C) :J>C xm oJ Z -~ =<! Ul ~ (;:) -< ~' "' "I l<! ~-~". '-~~, CHRISTINE MTT.T .ER , Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 00-2113 CIVll.. TERM DARBY D, MTT.T .ER., Defendant : CIVIL ACTION - LAW : 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 papets 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. 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 WSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE TmS PAPER TO YOUR LA WYERAT ONCE. IF YOU 00 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, P A 17013 (717) 249-3166 ,- , '" ." " ., ~, I I I . CHRISTINE:M1T.r F~ Plaintiff v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : No. 00-2113 CIVIL TERM DARBY D. :M1T.r F~, Defendant : CIVIL ACTION - LAW : DNORCE COUNTERCLAIM IN DIVORCE UNDER SECTION 3301(d) OF THE DIVORCE CODE The Defendant, Darby D. Miller, by and through his attorney, Jeanne B. Costopoulos, Esquire, avers the following: 1. The Plaintiff, Christine Miller, is an adult individual who currently resides at 4533 Gettysburg Road, Mechanicsburg, Cumberland County, Pennsylvania 17055 2. The Defendant, Darby D. Miller, is an adult individual who currently resides at 223 Wood Street, Camp Hill, Cumberland County, Pennsylvania 17011. 3. The Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Counterclaim. 4. The Plaintiff and the Defendant were married on April 9, 1988 in Cumberland County, Pennsylvania. COUNT I - DIVORCE 5. Paragraphs one (1) through four (4) are incorporated herein by reference as if set forth specifically below. 6. There have been no prior actions of divorce or for annulment between the parties. 7. The marriage is irretrievably broken. . ,,' "'ii"! 8. The parties have been living separate and apart since June of 1988. WHEREFORE, the Plaintiff respectfully requests this Honorable Court to grant the Defendant relief from the bonds of matrimony and order a Decree in Divorce. RESPECTFULLY SUBMITTED: Dated: 111!{fd 4r ~ Jeanie B. Costopoulos, Esquire COSTOPOULOS & WELCH 1400 North Second Street Harrisburg, Pennsylvania 17102 P A Supreme Court ID No. 68735 Telephone: (717) 221-0900 Fax: (717)221-0904 ATTORNEY FOR DEFENDANT , ........ ~- "'i=l<,~, CHRISTINE MTT.T .RR , Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 00-2113 CIVIL TERM DARBY D. MTT.T .HR, Defendant : CIVIL ACTION - LAW : DIVORCE VERIFICATION 1, Darby D. Miller, hereby verify that the statements made in the foregoing Counterclaim 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 autho . 'es. Date: 7'-/3-00 Signature: J. ._- ~, . ",., /II' < CHRISTINE MTI.r .F.R, , Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 00-2113 CIVIL TERM DARBY D. MILLER, Defendant : CIVIL ACTION - LAW : DIVORCE AFFIDAVIT OF NON-MJLITARY SERVICE 1. L Darby D. Miller, am the Defendant in the above matter. 2. I personally know that the Plaintiff, Christine Miller, is over the age of eighteen (18) years and that he currently resides at 4533 Gettysburg Road, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The Plaintiff is not in the military or naval service of the United States or its allies or otherwise within the provisions of the Soldier's and Sailors Civil Relief Act of 1940 and its amendments. 4. I hereby veriry that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. Date: <j- /3- 00 Signature: Section 4904 relating to unsworn falsificatio , '" J , " ",,,- "-' , ,,~ ~~- ,- "1'-; CHRISTINE MIllER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 00-2113 CIVIL TERM DARBY D. MILLER, Defendant : CIVIL ACTION - LAW : DNORCE NOTICE TO THE PLAINTIFF IF YOU WISH TO DENY ANY OF THE STATEMENTS SEt FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTERAFFIDA VIT WITHIN TWENTY (20) DAYS AFtER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER SECTION 330l(d) OF THE DIVORCE CODE 1. The parties to this action separated in June 1998 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 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. 4. I hereby verifY that the statements made in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. ection 4904 relating to Date: 9-/:3 -00 Signature: unsworn falsification to authorities. .~~" . -"" f~I, ,; !! " " il , ii CHRISTINE MILLER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : No. 00-2113 CIVIL TERM DARBY D. MILLER, Defendant : CIVIL ACTION - LAW : DNORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): o (a) I do not oppose the entry of a divorce decree. o (b) I oppose the entry of a divorce decree because: Check (i), (ii), or both: o (i) The parties to this action have not lived separate and apart for a period of at least two years. o (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): o (a) I do not wish to make any claim for economic relief I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if} do not claim them before a divorce is granted, o (b) I wish to claim economic relief which may include alimony, division of property, lawyer's fees, or expenses or other important rights. I hereby veritY that the statements made in this Counter-affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: Signature: Christine Miller >. -- 1m CHRISTINE MILLER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYL VANIA v. : No. 00-2113 CIVll.. TERM DARBY D. MILLER, Defendant : CIVIL ACTION - LAW : DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. Check either (a) or (b): ~a) I do not oppose the entry of a divorce decree. o (b) I oppose the entry of a divorce decree because: Check (i), (ii), or both: o (i) The parties to this action have not lived separate and apart for a period of at least two years. o (ii) The marriage is not irretrievably broken. y 2. Check either (a) or (b): o (a) I do not wish to make any claim for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses if} do not claim them before a divorce is granted. ~) I wish to claim economic relief which may include alimony, division of property, lawyer's fees, or expenses or other important rights. I hereby verifY that the statements made in this Counter-affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: 1/ - J 1/ - tJlJ r~&U *(.I1~/> Christine Miller Signature: ~~.~ I;l:fi;'.' , , ;riM.' "",,-,, r- .iUfiI_ifiImlt;1~~~iiilii"~WJoalI~~.K'lnnl-.d_1lI - ...,.~.~, t -'"~'~'- 0 0 0 C c:> -on < 0 -uf,' ("") .'71 rn(,i -l Z=l~' iTl 7':: ~ " (j) G'> l' -< (~,\ ~'~:~ '-'0 ~1'! f5 Zn / , , r'p );:.""(=: -', ~ Z N --, ::D -< $" -< III