Loading...
HomeMy WebLinkAbout01-04747IN THE COURT OF COMMON PLEAS No ...... 91...... 4747 .................. DECREE IN DI VORCE AND NOW, .........???!....Y .f..... it is ordered and decreed that .......... Dolores.A. Miller ....................... plaintiff, and . . . . . . . . . . . . . . Ronald E. 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 0 been entered; Aloft !V By a Con t ri Attes J. y ? a Prothonotary i k 4 a...: a? ?s-::.a?*. ..._??::;::es..:?..: N•, o . 2r:. ?. ?.:..?>. .:? ;c .:.e•: , .e .;cs .. w...:.. a e ,.. ..e.. , , rA v- ?- ;! - ?o ?r DOLORES A. MILLER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNA. V. NO. 01 - 4747 RONALD E. MILLER CIVIL ACTION - LAW Defendant DIVORCE PRA19CIPE 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. Grounds for divorce: irretrievable breakdown under Section (x) 3301(c) ( ) 3301(d) of the Divorce Code. 2. Date and manner of service of the Complaint: On August 16, 2001; see attached Affidavit of Service. 3. Complete Paragraph (a) or (b): (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff on 11/19/01: by Defendant on 11/26/01. (b)(1) Date of execution of Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: ; (2) date of service of Plaintiff's Affidavit upon the Defendant: See attached Affidavit of Service. 4. Related claims pending: None. 5. Date and manner of service of the Notice of Intention to File Praecipe To Transmit Record, a copy of which is attached if the decree is to be entered under section 3301(d)(i) of the Divorce Code: 6. Date and manner of service of Notice of Intention to file Praecipe To Transmit Record, a copy of which is attached, if the decree is to be entered under section 3301(c) of the Divorce Code ; OR, date of execution of Waiver of Notice of Intention 11/26/01; date of filing Waiver 11/29/01. James W. Abraham, Esq. Abraham Law Offices 513 North Second St. Harrisburg, PA 17101 (717) 232-7825 Attorney for Plaintiff DATE: 11/29/01 Dolores A. Miller DOLORES A. MILLER Plaintiff V. RONALD E. MILLER Defendant NOTICE : CIVIL ACTION - LAW : DIVORCE IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. NO.01--47k7 l.lU?` 6 ?l 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 in 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, includig 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. A list of marriage counselors is available in the office of the Court Administrator, 4th Floor, Cumberland County Courthouse, Carlisle, Pennsylvania, 17013. 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: Court Administrator 4th Floor Cumberland County Courthouse Carlisle, PA 17013 717.240.6200 DOLORES A. MILLER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNA. V. NO. Q1-?I 7(T/ ?IUII RONALD E. MILLER : CIVIL ACTION - LAW Defendant : DIVORCE COMPLAINT AND NOW, comes Plaintiff, Dolores A. Miller, by and through her attorney, James W. Abraham, Esquire, Abraham Law Offices, Harrisburg, Pennsylvania, and files the following: COUNT I DIVORCE PURSUANT TO SECTION 3301(c) OF THE DIVORCE CODE 1. Plaintiff, Dolores A. Miller, is an adult individual whose current address is 290 Hemlock Lane, Etters, Pennsylvania, 17319. 2. Defendant, Ronald E. Miller, is an adult individual whose current address is 12 Louis Lane, Enola, Cumberland County, Pennsylvania, 17025. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. Plaintiff and Defendant were married on April 7, 1978 in Enola, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties which are active. 6. The marriage is irretrievably broken. r 7. Plaintiff has been advised that counseling is available and that Defendant may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are not members of the Armed Forces of the United States. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce dissolving the marriage. COUNT II DIVORCE PURSUANT TO SECTION 3301(d) OF THE DIVORCE CODE 9. Plaintiff incorporates by reference paragraphs 1 through 8 hereto. 10. Plaintiff and Defendant have lived separate and apart for a period of at least two (2) years as their date of final separation was before August 1, 1999. , Plaintiff requests Your Honorable Court to enter a decree in divorce dissolving the marriage. Respectfully submitted: James W. Abraham, Esq. Abraham Law Offices 513 North Second St. Harrisburg, PA 17101 (717) 232-7825 Attorney for Plaintiff DATE: 8/9/01 , VERIFICATION Q(J=> the undersigned, hereby verify and confirm that I have reviewed the foregoing document and the statements therein are true and correct to the best of my knowledge, information and belief. I further understand that any false statements made herein are subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. DATE: X-- e-0 4?" zz6d? OF SERVICE I, James W. Abraham, Esquire, the undersigned, do hereby certify that I have served a true and correct copy of the foregoing document, by certified mail, on the date indicated below, to the following person(s): Ronald E. Miller 12 Louis Lane Enola, PA 17025 DATE: S/9/01 James W. Abraham, Esquire fT1G- =_r ??ao=( VJr I cuyy r -C tD -mac, O:r y -. ?grt ? ¢N4-?-^ •a??,w.?a?i'$F?x'°ur?PRS#? a DOLORES A. MILLER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNA. V. NO. 01 - 4747 RONALD E. MILLER CIVIL ACTION - LAW Defendant DIVORCE AFFIDAVIT OF SERVICE I, James W. Abraham, Esquire, the undersigned, attorney for Plaintiff, Dolores A. Miller, in the above-captioned action, hereby swear and affirm that the Complaint in divorce in the above- captioned action was served upon the Defendant, Ronald E. Miller, by certified mail, return receipt requested, on August 16, 2001, as verified by the green return card from the U.S. Post Office, which is attached hereto: r ¦ Complete. items 1, 2, and 3. Also complete item 4 if Restricted Delivery,is desire(. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Addressed to. _ ?? ,L D 11 i S ?,'4 ti ? ?Hntt? , Pt 7aa9 . A. JtR ?el (,Pl v?byeey t )/ A1fG ? e of Deliver //// i C. . ignature 0 Agent X ? Addressee D. Is elivery address different from item 1? ? Yes If YES, enter delivery address below: ? No 3. Service Type P-Certified Mail ? Express Mail ? Registemd ? Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 7001 0320 .O p2. 7583 5870 PS POmI • • .. Domestic Return Receipt till t 102 ? 5 0 ' p95$ -` S"2 rb$$ F$ 188 fb#i rryi1 ntili rn if e 11, r Iu I*t DATE: 11/29/01 James W. Abraham, Esquire c7 c c. -?. v ?°- f-n r:- .< z :_,: ?_? r ? L, i.., •? ?.; DOLORES A. MILLER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNA. v. NO. 01 - 4747 RONALD E. MILLER : CIVIL ACTION - LAW Defendant : DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 10, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of service and filing 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. I verify that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. DATE: D ZA/& OLORES A. MILLER N3 DOLORES A. MILLER Plaintiff v. RONALD E. MILLER Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. NO. 01 - 4747 CIVIL ACTION - LAW 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 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. 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.A SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE :????/? 7 / f 6` i? LC'E?? / DOLORES A. MILLER c : Sv 4 A' Cla,r': are - 'yCJ [ ul IF" I r T .? truer*»r= z ? . DOLORES A. MILLER : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNA. V. NO. 01 - 4747 RONALD E. MILLER CIVIL ACTION - LAW Defendant DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 10, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of service and filing 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. I verify that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. Section 4904, relating to unsworn falsification to authorities. c DATE : NALD . MILLER r7r 1jD r, .a. 1 DOLORES A. MILLER Plaintiff V. RONALD E. MILLER Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNA. NO. 01 - 4747 CIVIL ACTION - LAW 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 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. 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.A SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. DATE : OL'/ 11k2 NALD E. MILLER ?i Q.J 1_? TJ fir' }Rf'-' r:? -?- ?C _ J l ._ _1 CT`= i? ?&['v?9ao?!ea m r+rx+- u ? .as ? a ?s,..i .,?,a *ra a !5._ •. ?, t '?fi:?e?;?'? _ _ _.