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Home My WebLink About00-05564 A , , " " , , , , , , , " " , , , , " , , , , , , , " , "'-"\ " ''-' .-'. ,",;-, --, -' - ..-'"--"<-"- , , r r , , . " . " . " , :ti;F.;F.:li ""Of. '" ". . " " . " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA, MITCHELL P. MILLER No. 00 5564 Civil Term VERSUS PETRINA A. MILLER DECREE IN DIVORCE AND Now'~OAl 7 , 7<t7l-, IT IS ORDERED AND DECREED THAT Mitchell P. Miller , PLAINTIFF, AND Petrina A. 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; ATTEST: PROTHONOTARY ;F. iF. ;F. :Ii ;F.;F.;F.;F.;F.;F. ;F.;F.;F.;F. :Ii :Ii "':Ii :Ii :Ii ;F. "'iF. if. "'''' :of. :Ii'" ~ " .,,' " " " " . " " " " , , " " " " , " " " " " " . . " , " , " " " " " " " " " " " " " " " " " . " " " " " " " " " . . " . . " . . " J. " . " " " - -.~....,,-~ '" II I I ~-~~ ,~ ~ --- d . 9 . i/I d'f'tJ/ ~ '"~~ '." ." ,".. ~", -. , ."-. .,,-..' ,., . " , u.~ ~~ ?b4~ J1~/H~ z4 ~ , . ~~ , ~~~-~~~""<"'-' ,~QI'f~~ ~-= "I m . . . .. ,~~" f- ',' ~~ --, ' -'3,-',,-" ,,-__,,__,",_" -,:, ~- - ,--. ^- , ",.")<,, "'" ~. uv- S"IS"(. y ( PROPERTY SETTLEMENT AND SEPARATION AGREEMENT THIS AGREEMENT made this 'JC--c.i---day o~{!P~r-' 1999 between Mitchell Miller, of Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as Husband, A N D Petrina Miller, of Carlisle, Cumberland County, Pennsylvania, hereinafter referred to as wife, WITNESSETH: WHEREAS, in of disputes unhappy and consequence differences, the parties have been living separate and apart from each other; and WHEREAS, the parties desire to confirm their separation and make arrangements therewith for the division of their marital property and other rights and obligations growing out of their marriage. NOW THEREFORE, in consideration of the covenants and promises hereinafter to be mutually kept and performed by each party, as well as for other good and valuable consideration and intending to be legally bound it is agreed as follows: J" '"",c'-'-' C.;::l,_' ',,-,1,:" ~, oJ- <', "';'"A~"..' ,"' ',_ "--",,.,,- , .. ( r (1) It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place or places as he or she from time to time may choose or deem fit. (2) Except as herein otherwise provided, each party hereby releases the other from any and all claims, or demands up to the date of execution hereof. (3) The parties are the owners of certain real estate with improvements thereon erected at 35 East Louther Street, Carlisle, Cumberland County, Pennsylvania. Husband agrees within thirty (30) days of the signing of this Agreement to convey the real estate with improvements thereon erected at the aforementioned address to Wife by special warranty deed. Wife shall assume full responsibility for all household expenses including, but not limited to, mortgages, home equity loans, liens of record, utility bills, insurance and real estate taxes in connection with said property. With regard to all such expenses, Wife hereby agrees to hold Husband harmless and indemnify him from any loss thereon. Husband and Wife have previously executed an Agreement for the husband's Post-Equitable Interest to be paid so that Wife may be able to use their prior dwelling as collateral, and the 2 '-~ ';, '-,-, , ;- ,-' ..~~ "'-0 ,'f'_;~_, .~' ",.-",', ~. ~"-" -"~ .." ...----,- ., ,- -,'~j" .<.id-' " ~ '~ '-,"-",' -- - I ,~" ~. : ""~'-i.-,;a;; .. , provisions of that document are hereby incorporated as if set forth in full, (4) In the event that either party contracted or incurred any debts since the date of separation, the party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the account may have been charged, Husband and Wife acknowledge and agree that they have no other outstanding joint debts and obligations of the Husband and Wife incurred prior to the signing of this Agreement, except as follows: Each party agrees to pay the outstanding joint debts as set forth herein and further agrees to indemnify and save harmless the other from any and all claims and demands made against either of them by reason of such debts or obligations, (5) Both parties agree that Wife shall retain possession of her 1989 Chevy automobile and the 1991 Chevy 8-10 pick up. Husband shall retain title to the 1973 Chevy Camaro and 1979 Glastron fiberglass boat. Each party relinquishes any right, title and interest he or she may have to any of the aforementioned vehicles as previously described. Each party 3 -..-__'1,. ~ -- 'q' '-N.' - ',~--,. . "~ ,:,',:,,;:;;;":~:,:-:;-,~,;: ~-~;:;;-':;::-~ " - <~,-' -'--r '-M - "-,,".-0_,:"1 --'j " > shall execute any documents necessary to have said vehicles properly registered in the other party's name with the pennsylvania Department of Transportation. Each party shall assume full responsibility of any encumbrances and for any insurance on the motor vehicles received by said party, and shall hold harmless and indemnify the other party from any loss thereon. (6) The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, tools and other household personal property between them, and they mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such property presently in his or her possession whether said property was heretofore owned jointly or individually by the parties hereto. It is specifically agreed that Wife will keep all contents in the home, and the seven (7) handguns acquired during the marriage, and husband will retain and/or receive one diamond ring that belong to his mother. This agreement shall have the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties hereto. 4 ~", -""-'",-'U- '-~, ,"."' '"-__c,'., >~ _~ ~ ~, ""' '. ,.' '.' ,-',"-~ (7) Each party hereby relinquishes any right, title or interest he or she may have in or to any intangible personal property currently titled in the name of or in the possession of the other party, including, but not limited to, stocks, bonds, insurance, bank accounts and retirement accounts. Both parties specifically agree that Wife relinquishes any right, title and interest to Husband's Americhoice savings account and Husband's 401K retirement plan, (8) Wife specifically waives any right, title or interest in any alimony, support or alimony pendente lite which she may receive from Husband, (9) If each party is now represented by counsel of their own choice, each shall pay his or her own attorney for all legal services rendered or to be rendered on his or her behalf. (10) Neither party shall contract or incur any debt or liability for which the other party or his or her property or estate might be responsible and shall indemnify and save the other party harmless from any and all claims or demands made against him or her by reason of debts or obligations incurred by the other party, (11) Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the 5 - _,".... 0 '" .,"_ ,"c",~: _ ';.., ~-:':'_:"""--"' " ".' ,<,0 .- _"'~_ -. - ~' --...;.;- '~''''~ .-, C_""'";,,,_ other party any and all further instruments that may be reasonably required to give full force and effect to the provision of this Agreement. (12) The parties do hereby warrant, represent, acknowledge and agree that each is fully and completely informed of, and is familiar with, the wealth, real and personal property, estate and assets, earnings and income of the other and that each has made a full and complete disclosure to the other of his and her entire assets and liabilities and any further enumeration or statement thereof in this Agreement is specifically waived. (13) Husband and Wife acknowledge that each of them has read and understand his and her rights and responsibilities under this Agreement and that they have executed this Agreement under no compulsion to do so but as a voluntary act. (14) It is further specifically understood and agreed by and between the parties hereto that each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all of said party's rights against the other for past, present and future claims on account of support, maintenance, alimony, alimony pendente lite, counsel fees, costs and expenses, equitable distribution of marital property and any 6 - ,~ ".-," '-"/," ,-,-"'-::_,-.-"-:~," ~"-,--- ,<~ \, ',.- ,," -' ~' _, v,~,;-~ " ", other claims of each party, including all claims which have been raised or may be raised in an action for divorce. (15) Except as may be otherwise specifically provided in this Agreement, Husband and Wife, for themselves, their heirs, representatives and assigns, each hereby forever releases, remises, discharges and quitclaims the other, and such other's heirs, representatives, assigns and estate, respect to the following: A. All liability, claims, causes of action, damages, from and with costs, contributions, expenses or demands whatsoever in law or in equity; B, All rights, title, interest or claims in or to any property of the other, whether real, personal or mixed and whether now owned or hereafter acquired; C, All rights of curtesy and dower and all claims or rights in the nature of curtesy and dower; D. All widow or widower's rights; E. All rights, title and incerest or claims in or to the other's estate, whether now owned or hereafter acquired, including but not limited to all rights or claims: (1) to take against the other's will; 7 , - "'<,:,*::--: ,~- '-'-"0.-",,'.. , '",,--.,;~, <--, ,"'-'-,""-),-, ,-';.,'" . (2) under the laws of intestacy; (3) to a family exemption or similar allowance; and (4) all other rights or authority to participate or intervene in a deceased spouse's estate in any way, whether arising under the laws of pennsylvania or any other country, territory,. state or political subdivision. F. All rights or claims to any accounting; G. All rights, claims, demands, liabilities and obligations arising out of or in connection with the marital relationship or the joint ownership of property, whether real, personal or mixed; H. All rights, claims, demands, liabilities and obligations arising under the provisions of the Pennsylvania Divorce Code, Act 26 of 19&0, as the same may be amended from time to time, and under the provisions of any similar statute enacted by any other country, state, territory or political subdivision; 1. All rights, claims, demands, liabilities and obligations each party now has, or may hereafter have, against or with respect to the other, 8 A , . -, (16) This Agreement shall be construed under the law of the Commonwealth of Pennsylvania, If any provision of this Agreement is determined to be invalid or unenforceable, all other provisions shall continue in full force and effect. (17) In the event that either of the parties shall recover a final judgment or decree of absolute divorce against the other in a court of competent jurisdiction, the provisions of this Agreement may be incorporated by reference or in substance but shall not be merged into such judgment or decree and this Agreement shall survive any such final judgment or decree of absolute divorce and shall be entirely independent thereof. (18) In the event that either party breaches any provision of this Agreement, and the other party retains counsel to assist in enforcing the terms thereof, the parties hereby agree that the breaching party will pay all attorney's fees, court costs and expenses incurred by the other party in enforcing the Agreement, (19) This Agreement constitutes the entire understanding between the parties and there are no covenants, conditions, representations, or agreements, oral or written, of any nature whatsoever, other than those herein contained. 9 ~. . . < . ~. . , "- ~'-, ".:- . (20) This Agreement shall bind the parties hereto, their respective heirs, executors and assigns. IN WITNESS WHEREOF, the parties hereto intending to be legally bound have hereunto set their hands and seals the day and year first written above, Witness do-uAa In_ ~ Witness PJ/H#' m~ MiEchell Miller ~~~; Petrina Mil er 10 i"",:";"'", ~', ~ " ' ..~ ,~",. ~J!"ll ........'''llf..:.. ,~'"' 0 ~~U!.u ~~jiiiililg(' o ,,' .~ _~v,^ ~"'.i4. ~,,-,-;L", ,'c ' " - '= ,_~, ,~~ ~-. ' '."" "',,,' () C <' :063 fTl,ll Z~"1 7e" ~.~~ ~,~_.. )> {~.., ~\.~t )>0 ~ L. =< .~- - ,~" ." ,~ .,",~...... ., ""'oc"'" . '- . C'-' ~> -n 1'"1 W , r'.O >: ; -~) ~ I,;" , . ~~~~ U .-,..1 '};: X -< L) c.?> ... .I"--~ SAlOIS SHUFF, FLOWER & LINDSEY ATIURNEYS.AT-LAW 26 W. High Street Carlisle. P A ~ '_- L <",-" , ~- I~ MITCHELL P. MILLER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 00~564 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE v. PETRINA A. MILLER, Defendant 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: Irretrievable breakdown under Section 3301(c) of the Divorce Code, 2. Date and manner of service of the Complaint: Certified mail, return receipt requested attached hereto as Exhibit "A", postage prepaid. 3. Complete either paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 330l(c) of the Divorce Code: By the Plaintiff: Januarv 20. 2001 By Defendant: Januarv 17. 2001 (b) (1) Date of Execution of the Plaintiff's Affidavit required by Section 330l(d) of the Divorce Code: (2) Date of service of the Plaintiff's Affidavit upon the Defendant: 4 , Related claims pending: Prooertv Settlement and Seoaration Aqreement is herebv incoroorated but not merqed. 5. Complete either (a) or (b): (a) Date and manner of service of the notice of intention to file Praecipe to Transmit the Record, a copy of which is attached: II ... --,. SAlOIS SHUFF, FLOWER & LINDSEY ATIORNEYS'AT'LAW 26 W. High Street Carlisle. PA II , . - ~' ", -',', ~", ,,,",',,. ~ (b) Date Plaintiff's Waiver of Notice in ~ 3301(c) divorce was filed with the Prothonotary: February 2, 2001 Date Defendant's Waiver of Notice in ~ 3301(c) divorce was filed with the Prothonotary: February 2, 2001 Date: ~- /-0/ , ~ - ~-w .. -...>- . ':i SENDERt 'a -COmPI&le~, i1,_',~.", Or,2~"for ~naJ services. ~, 'ii oComplO\llil!i""!!l:.4a,and!4Il. . . .Prlnt your n$ne;8ild address on the reverse oflhla toon so that we r! card to you; " , I -= thls,nn ~o the front of the mallpiece, or on the back If spa~1. OW,rits-Return,, ,RS,C$ipt Requested- on the mallpfece below the arti~, ei'jlum~;I\, -The Return iAeCefpf will show to whom the artiCle was delivered anct:the daieU delivered, ' :",. ,.,.. .-,.....,."..-,' .. ti " o I' 3. ,ArtiCle ~dreS$8d to: I ~,,\(\Q A. ~'\\\.e.r QI ~5'E..0lSt. ~v...'thQ{~. , ~~\~e., PA \lC\3 5. Aecelve~By: (Print Name) " g, ... " .. ~ ~ " g, .!! urn Receipt --"-,, -~"'- .. Certified Fee . /.~O Sp.dm~4Ir>-, .." "'<-c._',"" .. ('~~ ,) It ~;;k.Q..;' ~,k'~~~ ~jd< .':'- L _; ',=", >-"""'mi2-!- -IHJ~'"""" ~~~ ~ -, - ,. .". ,~ <-" v -~ , ~:iIiiI , , ~ _AIi"~ - I",' '-I I', fl ~ ~ ~ (' 'w _~_. .. ~l i~; f~ i" II ~~ ~ll (") 0 C c: "T ;s: ...,. -003 rrt , ~93 CD r. -?' r- I ., I '-'" '-. r: ':'1 I .,- .' , B ~t: :.,.) .-:::-,-f1 ,-' -, ~ ::::> 55 '-< - - - "~ . - , SAIDIS, SHUFF & MASLAND ATIORNEYSIATlLAW 26 W. High Street Carlisle, PA , . MITCHELL P. MILLER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL TERM 00- .s'S'I..U CIVIL ACTION - LAW l IN DIVORCE v. PETRINA A. MILLER, Defendant NOTICE 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 ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counselling. 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 PROPERTY, LAWYER'S FEES ANNULMENT IS GRANTED, YOU THEM. A CLAIM FOR ALIMONY, DIVISION OR EXPENSES BEFORE A DIVORCE MAY LOSE THE RIGHT TO CLAIM ANY OF OR OF 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 , I I I I Date: ~ )2,<000 o By: Jo a J. Deil Supreme Court 0 # 53147 26 West High Street Carlisle, PA 17013 (717) 243-6222 - > " -,--",: > , . MITCHELL P. MILLER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. CIVIL TERM PETRINA A. MILLER, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAXNT UNDER SECTION 3301 (c) OR 3301(d) OF THE DIVORCE CODE 1, Plaintiff is Mitchell P. Miller, who currently resides at P.O. Box 812, Prudenville, MI 48651. 2. Defendant is Petrina A. Miller, who currently resides at 35 East Louther Street, Carlisle, Cumberland County, Pennsylvania 17013. 3. Defendant has been bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4, The Plaintiff and Defendant were married on March 30, 1991, in Carlisle, Cumberland County, pennsylvania, 5. There have been no prior actions of divorce or for annulment between the parties. SAIDIS, 6. The Plaintiff has been advised of the availability of SHUFF & MASLAND marriage counseling and, the Plaintiff may have the right to ATrORNEYSeATeUW 26 W, High Street Carlisle, P A request that the Court require the parties to participate in II - , SAlOIS, SHUFF & MASLAND ATIORNEY8-AT.LAW 26 W. High Street Carlisle, PA . ~, . . counseling. Having been so advised Plaintiff does not desire the Court to order counseling. 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce. Respectfully submitted, SAIDIS, SHUFF & MASLAND Date: 1-?"(-(')"-U By: J S 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff 2 " " -. - , I SAIDIS, SHUFF & MASLAND ATl'ORNE'lS.A'r-LAW 26 W. High Street Carlisle, PA , " - -~' ,.';j:-- ,}, '_ __ 'u ,r, _ ~' ; ~;--^ ';,.'" 0 ^'. ",- "~~, ' . . MITCHELL P. MILLER, Plaintiff IN THE COURT OF COMMON PLEAS' CUMBERLAND COUNTY, PENNSYLVANIA v, NO. CIVIL TERM. , - ~ -:"\,i PETRINA A. MILLER, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT I, MITCHELL P. MILLER, 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 ','J,: marriage counselors in the Prothonotary's Office, which list 1S ,fl ., , available to me upon.request. (3) Being so advised, I do not request' that the court :1 require that my spouse and I participate in counselling prior to ii a divorce decree being handed down by the court, i, I, ii, I ~nderstand that false stat,ements herein are made subj ect \\ l , Ii to the, penal tles falsiflcatlon to of 18 Pa. C.S. Section 4904 relating to unsworn authorities, Dated: u2~z.-~o ?11~,R~ MlfcHELL MILLER, Plaintiff Ii _. ) I SAIDIS, SHUFF & MASLAND ATIORNEYSeAT.LAW 26 W. High Street Carlisle. PA II -'0""' '0".-",-" ".. ,_ ,__ - - ,,-,,~ ; ,.,"". ,0:.,,' '-'" ...\-' .~ .. _ - ~"" ~i-l - '''-'.' ".I , . . VERIFICATION I verify that the statements made in this Complaint 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: 7-22-00 ~/~ Mitchell P. Miller 1IiI'"' ,L,,-~' l=.;~' ~ ,- ,,;,.. r .~ ~'-k . -'iilJrnjl.["i-~":_ii>J '. IUlfM__t~' '-~"T '.~ ., , Jilllli 'II ,~~, t , I .'H,.' ,--,,,,-, ,.-.,.,- " " >~1iIIIl ,- () C) ~ ~ C ~ '6Q. .;p C::> C" "l:),,'" ;c,. -'[1 rnn-.f ~ ....... Zf.D c: . ~~r ~ 2",0 G'J l:. h <:i5b: ;-i-i:n a i"- ~ rs- CJ ~<~G ~ 0 6 ~CJ -n ~ D ?C) ::-.c ,-' b )>0 ~~;j <t , I c ~~) :z ~rn ~ ~ ~ =< s:- f\) ~ J .- , ilU ~ ~ ~ SAIDIS S1t1J!1&~ &~lJSAY AII.IIlN...........1AW 26 W. High street Carlisle,PA w . MITCHELL p, MILLER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 00-5564 CIVIL TERM., PETRINA A,MiLLER, Defendant CIVIL ACTION - LAW' IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1, A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 10, 2000. 2. The marx'iage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree of divorce without notice. 4. 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. 5, I understand that I will riot be divorced until a divorce decree'is ent'ered 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 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: i -J,O -f)/.Jf1~1!1::!!::-;iI8.intdf ~ \>::-~'d"l.i- ""i-~l>" ~ '.',' Co '-;';;,',"-.J!:1('* 0,," . ',~ "", ~ ~" - ~-- ,~,' -" ", "- ,"^- -- ~ ,-~-" " ,~.- "','..~ ,'<'~ ,',- --- -~ _ 0.. " ,,-'",~, < > ' (") c: s:: "'tJ'DJ tl1tn 2:t;, 6>5=; r>C -<, - j '" :2: C) ~o -c: :.c .::< "--~~---~""-"'^ o Cy i: 1: i! ii ii ! <::> .." . fOr: " ::;r;J I "'. C':' ::r w ''''; -n -,,'~,'o[~; -' " ..~,.- :~(~' " :' ~:;fI5-- ';:'o-:n, :,--, :5.;} ,:0 '~ ^-~- ~ o -,., Ii 11 1\1 f), L Ii iJ II i' Ii Ii l" Ii If ! i ~; I' I I: ,. -I ~_ _" ~.,"_ SAIDIS SlIl.J!'t ~WER & LIl'IvSAY AlIIJJl1\1J!J'!WT4AW 26W.Wghstre<t CatIlsle, PA ._ )I .. , MITCHELL P. MILLER, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO.00-5564 CIVIL TERM PETRINA A. MILLER, Defendant CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT. ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OP-INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on August 10, 2000. 2. Defendant ackrlol....;ledges 3..r:d 2CC'2'Ot s service- of -che Complaint on August 12, 2000.. 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint, 4. I consent to the entry of a final decree of divorce without notice. 5, 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. 6, I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree wilJ be sent to me immediately after it is filed with the Prothonotary. 7. I have been advised of the availability of marriage counselling and understand that I may request that the court require counselling, I do not request that the court require couns,pJ.l i.ng, I verify that the statements made in this affidavi.t. d:r:e Ll.l"" 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 aut~o~~es. . (\ DATED: 1/ J '7 J() J --~~ ~J J \ 0 ~____,,_ I I Petrina A, Miller ~ Defendant II II ~-~, "~;'f-"'''-'''' , . .". ,,"CO' ....... ."... .- ,... - -~--, '.... '"' ~ ~ ~ - .. ," "' "' A ~ "-' .. ",,--' '--.'," .. ......, g z -arr 92~~ :;;..:;or" V3JC: ~~. ~c) ;!;;O !o=O -pc; ~ ,. .-..::> - <- ~ I"J Cf' ~ ..... - .... ., ., if i " () ~-r-! '--:-.:\ ,'\-~$; ._':~~:(~ '~3,';) ;5~\ >~rri '::=.{ SS A. -0 ~ tf1 I""" N 'f ~ ; , , " ~~ ~ - .ib. ~; MITCHELL p, MILLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL DIVISION - LAW PETRINA A. MILLER, Defendant : NO. 2000-5564 CIVIL TERM : IN DIVORCE NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Defendant in the above matter, Petrina A. Miller. having been granted a Final Decree in Divorce on the 7th day of February 2001, hereby elects to resume the prior surname of CIUFFO and gives this wTitten notice pursuant to the provisions of 54 P.S. 9 704. Date: ~ 3/ teh/ ( t ~J:Jr '(l . ll-la... ~ Petrina A. Miller COMMONWEAL TH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On the 6th day of March . 2001. before me, a Notary Public, personally appeared the above affiant known to me (or satisfactorily proven) to be the person whose name is subscribed to the within document and acknowledge that she executed the foregoing for the purposes therein contained, IN WITNESS WHEREOF. I have hereunto set my hand and ot1icial seal. ~euy4/ 'otaryP ,P Notarial Seal Kimbarly L Diahl-Hough, Notary Public Cariisle Boro, Cumberland County My Commission Expiras May 5, 2003 ali! ,~H. ~~ '- "- ;; "- -<; '<\ ~" '- -~ 1II~ '-" 1lit..~1j,illllli;/f\i~~.MjIf-' , ~ .., '"--".",- ,""-"-"""--, l,'<"~" " "--""' ~" ., .,. ,Co " _ ~ __'>, v, '; = ~ < , ," 1 _',c_~" 'g <::> 0 ~ " ::utE ~ "" "...; mrn ',- 2::0 ::0 Fi1 ;:Q ~~ , ::;zrq ifG '" -^"-..J\- <& '"1J C?(..... ~8 ---"-f:" ::k ~J_,:d 0- ~~ ;S; -?'C) C'5m I'\) ~ 4:- -<: ~ ~ ~ g if f\ r ~, '",~ ~> ~ '..' ~J, ., -