HomeMy WebLinkAbout01-05731
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF ~ PENNA.
JENNIFER L. MILLER,
. ~.
Plaintiff
VERSUS
STEVIN B. MILLER,
Defendant
JENNIFER L. MILLER
DECREE IN
D I VO RC'E ~+.~~r~
AND NOW, ~ • 2003 IT IS ORDERED AND
DECREED THAT
AND
STEVEN B. MILLER
ARE DIVORCED FROM THE BONDS OF MATRIMONY.
DEFENDANT,
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;
All matters have been resolved pursuant to the Marital Settlement Agreement
PROTHONOTARY
No.
01-5731
PLAINTIFF,
reached by the parties dated November 19, 2001 and incorporated, but not
merged into the Decree. ~~~
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Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(7171774-1445
JENNIFER L. MILLER,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5731
STEVEN B. MILLER, CIVII, ACTION -LAW
Defendant IN DIVORCE
PRAECII'E 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 3301(c) of the Divorce Code.
2. Date and manner of service of the complaint: Acceptance of Service dated October
5, 2001.
3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code:
by Plaintiff September 8, 2003; by Defendant September 4, 2003.
4. Related claims pending: None. All matters have been resolved pursuant to~the
Marital Settlement Agreement reached by the parties dated November 19, 2001 and
incorporated, but not merged into the Decree. See paragraph 3, page 5 of the Ag~emen4~
5. Date Plaintiffs Waiver of Notice in 3301(c) Divorce was filed with ProthongtaFy:
September 18, 2003. Date Defendant's Waiver of Notice in 3301(c) Divorce was filec~ayith
Prothonotary: September 18, 2003.
Dated: September 18, 2003
(717)-774-1445
Supreme Court ID #32317
Attorney for Defendant
549 Bridge Street
New Cumberland, PA 17070-1931
Bazbaza Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(7171774-1445
JENNIFER L. MILLER,
Plaintiff
w.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5731
STEVEN B. MILLER, :CIVIL ACTION -LAW
Defendant 1N DIVORCE
CERTIFICATE OF SERVICE
I, Bazbaza Sumple-Sullivan, Esquire, do hereby certify that on this date, I served a true
and correct copy of the foregoing Praecipe to Transmit Record, in the above-captioned matter
upon the following individual by first class mail, postage prepaid, addressed as follows:
James A. Miller, Esquire
2010 Mazket Street
Camp Hill, PA 17011
DA'Z'ED: September 18, 2003
~azbaza Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070-1931
(717)774-1445
Supreme Court I.D. No. 32317
Attorney for Plaintiff
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Jennifer L. Miller,
Plaintiff
v.
Steven B. Miller,
Defendant
In the Court of Common Pleas
Cumberland County, Pennsylvania
No.: 01-5731
Civil Action -Law
In Divorce
MARITAL SETTLEMENT AGREEMENT
November 19, 2001
Miller tY_/SA
TABLE OF CONTENTS
SECTION PAGE
t: SEPARATION AND NON iNTERFERENCE :........................................................................ .....3
z. R.ECONCILIAT[ON :............................................................................................................. .....4
g. ENFORCEMENT_ ................................................................................................................ .....4
~ SPOUSAL SUPPORT~ALIMONY/ALIMONY PENDENTE LITE (APL). COSTS AND
EXPENSES :..................................................................................................................................... .....5
5:. EQUITABLE DISTRIB~ITION :............................................................................................... .....7
A. PREFACE :...........:............................................................................................................. .....7
8. DISTRIBUTIONDFASSETS :.............................................._........................................... .....8
1. WIFE'S ASSETS :............................................................................................................... .....8
?. HUSBAND'S ASSETS :...................................................................................................... .....8
3. ASSET DIVISION :............................................................................................................. .....8
A. REAL ESTATE 4012 P~ntav Drivc (including adjancent lot - 401.0 Patnav Driveh
Mechanicsburg Cumberland County Pennsylvania, 1701I . ................................................... .....8
B. REAL ESTATE :......................................................................................................... .....9
309 Fireside Drive Camp Hill Cumberland County Pennsylvania 17011 .............................. .....9
C. DISTRTBUTiON AND WAIVER OP PERSONAL ...................................................... ...10
MARITAL TANGIBLE AND INTANGIBLE, ASSETS AND 21 NON-MARITAL,
TANGIBLE AND INTANGIBLE. ASSETS :.......................................................................... ...10
D. CASH PAYMENT TO WIFE ::.................................................................................... ...12
E. C)DRO -Smith. Barncy ............................................................................................... ...12
F. INTENT:.... 12
6. AFTERAC~IRED PROPERTY ...................................................................._.......:........... ...13
Z DEBTS :..................................................................................................................................... ...13
A . Wife's Debts :....................................................................................................................... ...13
B. Husband's Debts :................................................................................................................. ...14
C. Marital Debl :...................................................................................................................... ...14
D . Indetnnifica lion :................................................................................................................. ...14
$; FULL DtSCLO~S'URE_ ........................................................................................................... ...15
cZ. RELEASES :........................................................................................................................... ...16
o: CUSTODY :............................................................................................................................ ...16
tt. BREACH :.............................................................................................................................. ...18
iz, REPR_ESENTATIO[V :........................................................................................................... ...18
~ ;. VOLUNTARY EXECUTION :...........................................................................................:.:. ...19
?4, ENTIRE AC REEMENT; ..................................................................................................... ....19
PRiORAGREEMENT :......................................................................................................... ...19
i6:. MODIFIGAT[ NAND WAIVER :...................................................................................... ....19
2 GOVERNING LAW :............................................................................................................. ...19
~8, 1NDEPGNDENTSEPARATECOVENANTS; ..................................._...................._.......... ...2C
tc~. VOID CLAUSES :................................................................................................................. ....20
gg_ DISTRI>;UTIQN DATE_ ...........................................................................................:........... ...20
zt. DATE OF EXECUTION :...................................................................................................... ...20
page 2
Miller MSA
MARITAL SETTLEMENT AGREEMENT
~„
THIS AGREEMENT, made this _~ day of C~~~2~ "C"' , 2ooi, by
and between Steven B. Miller, hereinafter called "Husband", and Jennifer L.
Miller, hereinafter called "Wife".
WHEREAS, Husband and Wife were lawfully married on February z,
ig86, in Dauphin County, PA;
WHEREAS, three children were born of the marriage, specifically Jason
R., DOB 2/2/88, Melissa D., DOB 2/6/go and Samantha E., DOB 5/22/95•
WHEREAS, differences have arisen between the parties and it is the
intention of Wife and Husband to live separate and apart, and the parties hereto
desire to settle fully and finally their respective financial and property rights and
obligations as between each other including, without limitation by specification:
the settling of all matters between-them relating to the ownership and equitable
distribution of real and personal property; the settling of all matters between
them relating to the past, present and future support, alimony and/or
maintenance of Wife by Husband or of Husband by Wife; and in general, the
settling of any and all claims and possible claims by one against the other or
against their respective estates.
NOW THEREFORE, in consideration of the premises and of the mutual
promises, covenants and undertakings hereinafter set forth and for other good
and valuable consideration, receipt of which is hereby acknowledged by each of
the parties hereto, Wife and Husband each, intending to be legally bound hereby
covenant and agree as follows:
1. SEPARATION AND NON INTERFERENCE:
It shall be lawful for each party at all times hereafter to live separate and
apart from each other at such place as he or she from time to time shall choose or
deem fit. The foregoing provision shall not be taken as an admission on the part
of either party of the lawfulness or unlawfulness of the causes leading to their
page 3
Miller MSA
living apart.
Each party shall be free from interference, authority and control by the
other, as fully as if he or she were single and unmarried, except as may. be
necessary to carry out the provisions of this Agreement. Neither party shall
molest or attempt to endeavor to molest the other, or in any way harass or malign
the other, nor in any other way interfere with the peaceful existence, separate and
apart from the other. Neither party shall say or do anything to negatively
influence or alienate the minor children from the other parent.
z. RECONCILIATION:
This Agreement shall not be deemed to have been waived, extinguished,
discharged, terminated, invalidated or otherwise affected by a reconciliation
between the parties hereto, cohabitation between the parties, aliving-together or
resumption of marital relations between them. They shall not be deemed to have
reconciled with the intention of vitiating or terminating this Agreement unless
they make such actions through a written instrument, executed and
acknowledged in the same manner as this Agreement.
g. ENFORCEMENT:
The parties acknowledge that Wife filed with the Cumberland County
Court of Common Pleas, Pennsylvania, to docket number o1-531, Civil Term, a
no-fault divorce action pursuant to Title 23, section 33oi(c) of the Pennsylvania
Divorce Code and amendments thereto; Husband having accepted service of the
same.
It is specifically understood and agreed by the parties that the provisions
of this agreement relating to equitable distribution of property and all other
matters contained herein including but not limited to support, alimony, alimony
pendente lice, counsel fees, costs and/or expenses are accepted by each party as a
final settlement for all purposes whatsoever, as contemplated by the
Pennsylvania Divorce Code and shall be submitted to the court at the time of
filing the praecipe to transmit the record to conclude the divorce.
page 4
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The parties agree to execute their respective Affidavit of Consent and
Waiver of Notice and proceed with entering same to the court docket for the
purpose of finalizing the divorce action on or after Apri16, 2002.
Each party shall further execute any and all documents which may require
his or her signature for the purpose of effectuating all of the terms and conditions
of this Agreement so as to give full force and effect to this Agreement.
Should a decree, judgment or order of separation or divorce be obtained
by either of the parties in this or any other state, country or jurisdiction, each of
the parties hereby consents and agrees that this Agreement and all of its
covenants shall not be affected in any way by any such separation or divorce; and
that nothing in any such decree, judgment, order or further modification or
revision thereof shall alter, amend or vary any term of this Agreement. It is
specifically agreed, however, that a copy of this Agreement or the substance of
the provisions thereof, may be incorporated by reference into any divorce,
judgment or decree. This incorporation, however, shall not be regarded as a
merger, it being the specific intent of the parties to permit this Agreement to
survive any judgment and to be forever binding and conclusive upon the parties.
4. SPOUSAL SUPPORT/ALIMONY/ALIMONY PENDENTE LITE
(APL), COSTS AND EXPENSES:
Husband and Wife hereby acknowledge that they have been advised or
have the right to obtain advice in regard to the fact that each may have the right
to assert a claim for spousal support, alimony, alimony pendent lite, costs and/or
expenses. Further, Husband and Wife acknowledge that they understand that
said rights are available in their divorce action. Husband and Wife further
acknowledge that they are aware of the income, education, income potential, and
assets and holdings of the other or have had full and ample opportunity to
become familiar with such items.
Husband and Wife hereby accept the mutual covenants and terms of this
Agreement and the benefits and properties passed to them hereunder in lieu of
any and all further rights to support or alimony for themselves, counsel fees, and
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Miller MSA
alimony pendente lite at this time and during any and all further or future
actions of divorce brought by either of the parties hereto, except as specifically
provided herein.
The parties do hereby remise, release, quit claim, and relinquish forever
any and all right to support, alimony, alimony pendente lite, counsel fees and
expenses beyond those provided for herein, during the pendency of or as a result
of any such actions, as provided by the Divorce Code of Pennsylvania or any
other applicable statute, at this time and at any time in the future.
Husband's obligation to Wife for the purposes of support and
maintenance, and child support shall be limited to the foIIowing. Husband shall
pay unto Wife on or before the eighth (8) day of each month, the following
amount(s):
i. $3,000.00 commencing January, 2002 through June, 2002,
representing $i,ooo.oo in alimony (deductible by Husband
and includable by Wife for purposes of taxes) and $2,000.00
in the form of child support;
2. $3,500.00 commencing July, 2002 through June, 2006,
representing $i,4oo.0o in alimony (deductible by Husband
and includable by Wife for purposes of taxes) and $2,ioo.oo
in the form of child support;
3. $2,800,00 commencing July, zoo6 through June, zoo8,
representing $i,4oo.0o in alimony (deductible by Husband
and includable by Wife for purposes of taxes) and $1,400.00
in the form of child support; and,
~+. $850.00 commencing July, 2008 through June 2oi3.
Husband's non-modifiable alimony obligations as defined herein shall
terminate upon the death of Wife, Wife's remarriage and/or cohabitation with a
member of the opposite sex or in accordance with the schedule defined herein
but no later than June, zoo8. Either party may administer these child support
terms through the domestic relations office with appropriate jurisdiction upon
page 6
4
Miller MSA
request. For purposes of tax filings, Husband shall claim Jason and Melissa each
year and Wife shall claim Samantha. Upon Melissa no longer being able to be so
claimed by Husband, the parties shall alternate each year for claiming Samantha.
Wife shall execute the appropriate IRS document each year in order to effectuate
the intent herein and Husband's ability to claim such child(ren). Husband shall
maintain Wife's health insurance until the final decree in divorce is entered.
In order to secure the alimony and child support payments identified
herein, Husband shall maintain a term life insurance policy in a sufficient
amount to cover the the amount(s) so identified herein and Wife shall be entitled
to receive copies of such policies evidencing placement of the same upon
reasonable request but no more than one time per year. In the event Husband
unfortunately passes from the face of this earth, then unfortunately Wife must
understand that Husband's brothers' shall become the custodian over the trust
for the life insurance proceeds for the sole benefit of their children. The parties
agree that the trust shall be used for all educational expenses, health costs and
business endeavors. Further, the parties understand that Wife's allocation of the
policy covering her alimony payments shall be first segregated from the total
benefit and the balance of the benefit shall be paid into the trust for the children
in equal shares. When Sammy reaches the age 25, the entire balance of the trust
shall be disbursed to each child in equal shares.
5. EQUITABLE DISTRIBUTION:
A. PREFACE:
The parties have valued to the best of their ability their entire marital and
non-marital estates. The parties- have made use of either the information
provided between themselves and/or statement values associated with such
assets and/or have attributed fair market values and/or other agreed upon values
to such assets and for purposes of negotiation and settlement, and hereby
stipulate to such valuations. The parties desire to effectuate the division of all
assets in undertaking these terms of settlement.
page 7
B. DISTRIBUTION OF ASSETS:
z. WIFE'S ASSETS:
Miller ~t2SA
Husband does hereby grant, convey, transfer, assign, and deliver and set-
over unto Wife the assets so identified within this agreement; said assets shall be
and remain the sole and separate property of Wife hereafter, free of any claim by
or interest of Husband, regardless of whether such assets were deemed by either
of the parties to be marital property or non-marital property. And further,
Husband does hereby waive, release, relinquish, and surrender forever any and
all claim to or interest in said assets, which shall be and remain the sole and
separate property of Wife hereafter.
2. HUSBAND'S ASSETS:
Wife does hereby grant, convey, transfer, assign, and deliver and set-over
unto Husband the assets so identified within this agreement; said assets shall be
and remain the sole and separate property of Husband hereafter, free of any
claim by or interest of Wife, regardless of whether such assets were deemed by
either of the parties to be marital property or non-marital property. And further,
Wife does hereby waive, release, relinquish, and surrender forever any and all
claim to or interest in said assets, which shall be and remain the sole and
separate property of Husband hereafter.
3. ASSET DIVISION:
The parties hereby agree that the following assets shall be divided in
accordance with the terms as provided herein. Husband and Wife agree to
execute any and all documents required to effectuate the intent herein:
A. REAL ESTATE: 4oz2 Pamay Drive (including
adjancent Iot - 4ozo Pamay Drive), Mechanicsburg,
Cumberland County, Pennsylvania, z~ozz:
z. The parties are joint owners of the real property known as 4oz2 Pamay
Drive (including adjacent lot - 4ozo Pamay Drive), Mechanicsburg,
Cumberland County, Pennsylvania, z~ozz (referred to herein as the
"premise"). Wife hereby conveys unto Husband all of Wife's right, title
and interest in the premise. Wife shall execute at the time she is released
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Miller MSA
from the debt(s) associated with the premise(s) upon request a Deed
reflecting her relinquishment, waiver and abandonment forever. If in
Husband's discretion the division of the premise from the lot would be
prudent, then upon request Wife shall further execute any other
document/deed necessary to accommodate such action. Husband shall
indemnify and hold Wife harmless for all past, present and future
indebtedness on the premise including, but not limited to, any and all
mortgage obligationsl, real estate taxes, utilities and municipal
assessments, and repairs, costs and maintenace. Husband shall be
entitled to claim all interest, real estate taxes and any other permissible
expense paid for purposes of tax filings.
Husband agrees that he shall have Wife released from the mortgage
obligations identified herein within three (3) years from the date of
execution hereof.
B. REAL ESTATE:
3og Fireside Drive, Camp Hi11, Cumberland County,
Pennsylvania i~oli
z. On behalf of Wife, the parties agree that Husband or Husband and Wife
shall purchase, in joint names if possible, the property known as 309
Fireside Drive, Camp Hill, Cumberland County, Pennsylvania. It is
understood that settlement is intended to take place on or before
November z9, 2001;. The purchase price is $;:2,500.00. Husband or the
parties intend to obtain a mortgage in the amount of $> 05,000.00 in order
to proceed to closing. The balance of the purchase price and all closing
costs associated with the transaction shall be paid by Husband as part of
equitable distribution. Wife shall be solely responsible for any and all
mortgage obligations including the mortgage identified herein as well as
all real estate taxes, utilities and municipal assessments, and repairs, costs
and maintenace. Wife shall indemnify and hold Husband harmless for all
National City Mortgage approximately $213,823.23 and First United Mortgage approximately
$15,109.29.
page 9
Miller N1SA
past, present and future indebtedness associated with the premise. Wife
shall be entitled to claim all interest, real estate taxes and any other
permissible expense paid for purposes of tax filings.
Wife shall refinance 309 Fireside Drive, Camp Hill, Cumberland
County, Pennsylvania on the expiration of sixty (60) months from the date
of this agreement in order to release Husband from said obligation.
Husband agrees to execute a transfer deed relinquishing his interest in the
property within sixty (60) days of execution hereof; said deed being placed
in escrow with Wife's attorney's office until the time of refinancing as
stated herein.
C. DISTRIBUTION AND WAIVER OF PERSONAL
i) MARITAL; TANGIBLE AND INTANGIBLE,
ASSETS AND 2) NON-MARITAL, TANGIBLE AND
INTANGIBLE, ASSETS:
i. Husband and Wife do hereby acknowledge that they have divided to
their mutual satisfaction all non-marital and marital assets including,
but without limitation, business interests, corporate interests,
partnership(s), joint ventures, inheritance(s), jewelry, clothing,
retirement accounts, 4oik's, pensions, brokerage accounts, stocks,
bonds, life insurance policies or other securities, Individual Retirement
Accounts, checking and savings accounts, mutual funds, and other
assets whether real, personal or mixed, tangible or intangible.
2. Husband and Wife further acknowledge and agree that the assets in
the possession of the other spouse unless otherwise so divided by way
of this agreement shall remain that spouses sole and separate property,
each party hereto specifically waiving, releasing, renouncing and
forever abandoning whatever claim, if any, he or she may have with
respect to any of the foregoing items which are the sole and separate
property of the other.
3. S.B.Miller A-Plus -Paxton Street & Cameron Street, Harrisburg, PA
page 10
Miller MSA
Wife hereby acknowledges and agrees that S.B. Miller A-Plus (2
locations) including bank accounts, cash, security deposits with
Sunoco, shall be Husband's sole and separate property with Wife
forever waiving, relinquishing and abandoning all past, present and/or
future rights, title and/or interests and claims she may have arising
from her marriage to Husband. Husband shall have Wife released
from the existing debts (Fulton loan approximately $ui,ooo.oo and
Americhoice approximately $23,000.00) on the business within six (6)
months from the date of execution hereof and shall provide evidence of
such to Wife upon her request.
Husband represents and warrants that he shall indemnify and save
harmless Wife from any and all claims or demands made against herby
reason of debts or obligations identified above including reasonable
attorneys fees incurred to enforce this indemnification.
4. Automobiles/Boat:
Husband and Wife agree that the vehicles in their respective
physical possession shall remain the possession of the party and each
shall cooperate if necessary in executing any and all documents to
retlect such ownership, including but not limited to titles, insurance
documentation and registration forms. Specifically, Wife shall retain
the Pontiac Van and Husband shall retain the Lexus SW and Pontoon
boat.
Husband and Wife do hereby waive, release, and relinquish any
and all claim to or interest in the motor vehicle in the possession of the
other. If the title to any vehicle is encumbered by any debt or
obligation, Husband and Wife agree that they shall each be solely
responsible for and shall pay and satisfy said obligation, in accordance
with its terms and provisions, and shall indemnify and save the other
harmless from any loss, cost, or cxpcnse caused to either by their
failure to make payment of such debt.
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Miller MSA
D. CASH PAYMENT TO WIFE:
In further consideration and exchange for the property distributed to the
parties herein, Husband shall pay to Wife in the form of Equitable Distribution
the total sum of Thirty Five Thousand ($35,000.00) Dollars and no cents in the
following manner:
1. $10,000.00 on or before February 28, 2002;
2. $10,000.00 upon the sale of Pamay Drive or if not sold by February
28, 2003, then such amount due on March 15, 2003,•
3. $10,000.00 due on February 28, 2005; and,
4• $5,000.00 on or before February 28, 2009.
E. QDRO -Smith, Barney
Husband shall undertake efforts to distribute by way of a Qualified
Domestic Relations Order ("QDRO") unto Wife 55% of Husband's money market
with Smith Barney (value as of October 12, 2001 - $151,911.53 and $37,144.92)•
The parties agree that Wife shall receive by way of a QDRO the sum of
$103,981.05 on or before September 30, 2002. The parties understand and agree
that a QDRO may not be required to transfer such amount and therefore further
agree to cooperate and execute any necessary documents in order to transfer
such funds to Wife with the least financial consequence. Husband shall
indemnify Wife for any costs, expenses, penalties or tax consequences incurred
on the transfer should there be any tax consequence on the transfer to wife.
Husband shall not be responsible for any liabilities once Wife elects to receive the
retirement in the form of income.
F. INTENT:
This Agreement is intended to distribute all property of the parties,
whether real or personal, and whether determined to be separate or marital
property. In the event that any property maybe omitted from this Agreement, it
is understood and agreed that the person having possession and/or title to such
property following the execution of this Agreement shall be deemed the owner
thereof and each of the parties will execute any and all legal documents without
any charge therefore to evidence title to such property in the other party.
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Miller MSA
ADDITIONAL DOCUMENTS: Each of the parties shall on demand
execute and deliver to the other any deeds, documents, records or closing
statements relating to the sale of real estate under this Agreement, bills of sale,
assignment, consents to change of beneficiary on insurance policies, tax returns
and other documents and do or caused to be done any other act or thing that may
be necessary or desirable to the provisions and purposes of this Agreement.
TAXES: Husband hereby agrees to pay all income taxes assessed against
him, if any, as a result of the division of the property of the parties hereunder.
Wife hereby agrees to pay all income taxes assessed against her, if any, as a result
of the division of the property of the parties hereunder.
6. AFTER ACQUIRED PROPERTY:
Each of the parties shall hereafter own and enjoy, independently of any
claim or right of the other, all items of property, be they real, personal or mixed,
tangible or intangible, which are hereafter acquired by him or her, with full
power in him or her to dispose of the same as fully and effectively, in all respects
and for all purposes, as though he or she were unmarried.
The parties hereby agree that, as to all assets not specifically mentioned
herein which are presently titled in the sole name of one of the parties hereto or,
if untitled, are presently in the sole possession of one of the parties hereto, the
party not having title thereto or possession thereof hereby waives, releases,
relinquishes and forever abandons any and all claims therein, and acknowledges
that the party having title or possession of such items shall be the sole- and
exclusive owner thereof.
~. DEBTS:
A. Wife's Debts:
Wife represents and warrants to Husband that since the parties'
separation she has not and in the future she will not contract or incur any debt or
liability for which Husband or his estate might be responsible and shall
page 13
Miller MSA
indemnify and save harmless Husband from any and all claims or demands made
against him by reason of debts or obligations incurred by her.
B. Husband's Debts:
Husband represents and warrants to Wife that since the parties'
separation he has not and in the future he will not contract or incur any debt or
liability for which Wife or her estate might be responsible and shall indemnify
and save harmless Wife from any and all claims or demands made against herby
reason of debts or obligations incurred by him.
C. Marital Debt:
The parties acknowledge that each shall be individually responsible for
and solely liable for the debts identified hereinbelow and shall further indemnify
and hold the other harmless to every and all extent including but not limited to
-all past, present, and future fees, costs and/or expenses associated with the
collection of such debts, judgments, interest, taxes and suits, including
reasonable attorneys fees incurred to enforce this indemnification:
Mastercard # ($9,000.00) Wife
Mastercard # ($6,000.00) Husband
Mortgages identified in footnote i
Husband
Mortgage identified in 3A above, 309 Fireside Drive Wife
Business liens identified in 3C(3)
D. Indemnification:
Husband
All further debts incurred by the parties shall be their individual responsibility.
Each party represents and warrants to the other that he or she has not incurred
any debt, obligation, or other liability, other than described in this Agreement, on
which the other party is or maybe liable. Each party covenants and agrees that if
any claim, action or proceeding is hereinafter initiated seeking to hold the other
party liable for any other debts, obligations, liability, act or omission of such
party, such party will at his or her sole expense, defend the other against any
such claim or demand, whether or not well-founded, and that he or she will
indemnify and hold harmless the other party in respect of all damages as
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Miller MSA
resulting therefrom including reasonable attorneys fees incurred to enforce this
indemnification. Damages as used herein shall include any claim, action,
demand, loss, cost, expense, penalty, and other damage, including without
limitation, counsel fees and other costs and expenses reasonably incurred in
investigating or attempting to avoid same or in opposing the imposition thereof
or enforcing this indemnity, resulting to Husband or Wife from any inaccurate
representation made by or on behalf of either Husband or Wife to the other in
this Agreement, any breach of any of the warranties made by Husband or Wife in
this Agreement, or breach or default in performance by Husband or Wife of any
of the obligations to be performed by such party hereunder. The Husband or
Wife agrees to give the other prompt written notice of any litigation threatened or
instituted against either party which might constitute the basis for a claim for
indemnity pursuant to the terms of this Agreement.
8. FULL DISCLOSURE:
The parties acknowledge that each of them have had a full and ample
opportunity to consult with counsel of their choice regarding their claims arising
out of the marriage and divorce and that they have specifically reviewed their
rights to the equitable distribution of marital property, including rights of
discovery, the right to compel a filing of an Inventory and Appraisement, and the
right to have the court review the assets and claims of the parties and decide
them as part of the divorce action. Being aware of those rights, and being aware
of the marital property owned by each of the parties, the parties hereto, in
consideration of the other terms and provisions of this agreement, do hereby
waive, release and quitclaim any further right to have this court or any other
tribunal equitably distribute or divide their marital property.
The parties acknowledge that they have been fully advised and informed of
the wealth, real and/or personal property, estate and assets, earnings and income
of the other and are familiar with and cognizant of such and the value thereof, or
has knowingly waived such advice and/or information. The parties hereto have
been fully advised and informed of all rights and interests which, except for the
page IS
:~,~
Miller MSA
execution and delivery hereof, have been conferred upon or vested in each of
them by law with respect to the property or estate of the other by reason of their
marital status, or has knowingly refused or waived such advice or information.
q. RELEASES:
Except as otherwise herein provided, each party releases and discharges
completely and forever the other from any and all right, title, interest or claim or
past, present or future support, division of property including income or gain
from property hereafter accruing, right of dower and courtesy, right to act as
administrator or executor in the estate of the other, right to distributive share in
the other's estate, right of exemption in the estate of the other, or any other
property rights, benefits or privileges accruing to either party by virtue of said
marriage relationship, or otherwise, and whether the same are conferred by the
statutory law or by the common law of the Commonwealth of Pennsylvania, or
any other state, or of the common law of the United States of America.
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 parties' rights against the other
for any 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 other claims of each party, including all
claims raised by them in the divorce action pending between the parties.
so. CUSTODY:
A. LEGAL CUSTODY
The parties hereby agree to share legal custody of their minor children.
B. PHYSICAL CUSTODY
The parents shall share physical custody of the children. Mother shall
have primary physical custody. Father shall have partial custody as follows:
page I6
.,
Miller MSA
i. Alternating weekends with Father from Friday after school to
Sunday at ~:oo p.m.
z. Every Wednesday after school to 8:0o p.m.
3. Each parent shall enjoy two (2) non-consecutive weeks or
two (2) consecutive weeks during the summer with thirty
(30) days advance notice to the other of such periods.
4. The parents shall share the following holidays:
a. Mother shall have Easter and Christmas;
b. Father shall have the Jewish Holidays of Rosh Hashanah,
Yom Kippur and two nights of Hanukkah;
c. Thanksgiving will be split into segment A (morning
through 3 p.m.) and segment B (3 p.m until 9 p.m.) and
the parties shall discuss the segments each year;
d. Father shall have New Year's Day and Fourth of July and
Mother shall have. Memorial Day and Labor Day;
e. Father shall have custody of the children on Father's Day
from io:oo a.m. through 6:0o p.m. and Mother shall
have custody of the children on Mother's Day from io:oo
a.m. through 6:0o p.m.; and,
f. The holiday schedule shall take precedence over the
regular custody schedule.
5. With respect to President's Day, Martin Luther King Day,
Columbus Day, or Veterans Day, all of which occur on
Monday, the parent having physical custody of the children
during the immediately preceding weekend shall have
physical custody on the holiday Monday until 8:0o p.m.
page 17
.
Miller MSA
6. Each parent shall have physical custody of the children for
attendance at family funerals, near death situations and at
weddings with reasonable notice to the other parent.
C. TELEPHONE PRIVILEGES
The parties agree that there shall be reasonable telephone access between
the children and both parents. The children shall be permitted free access to
place calls to their parents at any time they desire.
u. BREACH:
If either party breaches any provision of this Agreement, the other party
shall have the right, at his or her election, to sue for damages for such breach.
The party breaching this contract shall be responsible for the payment of legal
fees and costs incurred by the other in enforcing his or her rights under this
Agreement, or seeking such other remedy or relief as maybe available to him or
her.
ia. REPRESENTATION:
Both parties have been given the opportunity to obtain the advice of
counsel regarding the provisions of this Agreement and their legal effect in
advance of the date set forth above to permit such independent review. In the
event either party elects to execute this agreement without the advice of counsel,
he/she shall nevertheless be bound hereby and he/she specifically and knowingly
waives his/her right, if any, to utilize his/her lack of legal representation as a
basis to attack the validity of this Agreement.
Each party acknowledges that he or she has had the opportunity to receive
independent legal advice from counsel from his or her selection, and that each
fully understands the facts and has been fully informed as to his or her legal
rights and legal obligations, and each party acknowledges and accepts that this
Agreement is, and the circumstances, fair and equitable, and that it is being
entered into freely and voluntarily, after having had the opportunity to receive
page I8
. ..
Miller MSA
such advice and with such knowledge, and that execution of this Agreement is
not the result of any duress or undue influence, and that it is not the result of any
improper or illegal agreement or agreements.
i3. VOLCINTARY EXECUTION:
The provisions of this Agreement are fully understood by both parties and
each party acknowledges that this Agreement is fair and equitable, that it is being
entered into voluntarily and that it is not the result of any duress or undue
influence. Further, each party acknowledges that he or she has the mental
capacity to understand the terms provided herein and has not been placed under
duress, coercion or any physical or mental stress.
i4. ENTIRE AGREEMENT:
This Agreement contains the entire understanding of the parties and there
are no representations, warranties, covenants or undertakings other than those
expressly set forth herein.
i5. PRIOR AGREEMENT:
It is understood and agreed that any and all property settlement
agreements executed between the parties, and/or may or have been executed
prior to the date and time of this Agreement, are null and void and of no effect.
t6. MODIFICATION AND WAIVER:
Any modification or waiver of any provision of this Agreement shall be
effective only if made in writing and executed with the same formality as this
Agreement. The failure of either party to insist upon strict performance of any of
the provisions of this Agreement shall not be construed as a waiver of any
subsequent default of the same or similar nature.
i~. GOVERNING LAW:
This Agreement shall be governed by and shall be construed in accordance
with the laws of the Commonwealth of Pennsylvania.
page I9
. .~
i8. INDEPENDENT SEPARATE COVENANTS:
Miller MSA
It is specifically understood and agreed by and between the parties hereto
that each paragraph hereof shall be deemed to be a separate and independent
covenant and agreement.
i9. VOID CLAUSES:
If any term, condition, clause, or provision of this Agreement shall be
determined or declared to be void or invalid in law or otherwise, then only that
term, condition, clause or provision shall be stricken from this Agreement and in
all other respects this Agreement shall be valid and continue in full force, effect
and operation.
20. DISTRIBUTION DATE:
The parties hereto acknowledge and agree that for purposes of distribution
of property as provided for in this agreement, the date of execution of this
agreement shall be known as the Distribution Date.
21. DATE OF EXECUTION:
The parties hereto acknowledge and agree that the date of execution
referred to herein shall be known as the last date upon which either party
executes this agreement.
IN WITNESS WHEREOF, the parties hereto, intending to be legally
bound hereby, have hereunto set their hands and seals the day and year first
above written.
WITNESS:
i~
teven B. Miller
~ennife~iller
page 20
w ~ R
Commonwealth of Pennsylvania
,' 7 ss.
COUNTY OF L!~'~"^~ ~A~
On this, the ~ day of ~" ~-u-~
MillerMSA
2001, before me, a
Notary Public, personally appeared Steven B. Miller, known to me to be the
person whose name is subscribed to the within Settlement Agreement and
acknowledged that he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
--~~
NOTARY~PU IC NorARInL sent
M YIlIZll$SlOn EX lreS' JAMES A. MILLER, Notary Public
p t3oro of Camp Hill, Cumberland County, PA
~',qy Commission Expires April 30, 2005
Commonwealth of Pennsylvania
ss.
COUNTY OF ~ ~ ~ l~
On this, the ~ ~ day of ~ V'~r'`~ .2001, before me, a
Notary Public, personaIly appeared Jennifer L. Miller, known to me to be the
person whose name is subscribed to the within Settlement Agreement and
acknowledged that she executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and of£cial seal.
NOTARY
My Commission Expires: NorARIAL sEaL ~~
JAMES A. MILLER, Notary Public a
Boro of Camp HIII, Cumberland County, PA
My Commission Expires April 30, 2005
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Bazbaza Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(7171774-1445
JENNIFER L. MILLER,
Plaintiff
v.
STEVEN B. MILLER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
No. a ~ - s7a~
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 proceed without you and a decree of divorce or annulment may be entered against you
by the Court. A judgement 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 and visitation of your children.
When the grounds for a divorce is indignities or irretrievable breakdown of the marriage,
you may request marriage counseling. A list of marriage counselors is available in the Domestic
Relations Office at the County Courthouse.
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, Pennsylvania 17013
(717) 249-3166
Bazbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717)774-1445
JENNIFER L. MILLER,
Plaintiff
v.
STEVEN B. MILLER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. ~1-5731
CIVIL ACTION -LAW
IN DNORCE
COMPLAINT IN DIVORCE
1. Plaintiff is Jennifer L. Miller, an adult individual residing at 4012 Pamay Drive,
Mechanicsburg Cumberland County, Pennsylvania 17050.
2. Defendant is Steven B. Miller, an adult individual residing at 4012 Pamay Drive,
Mechanicsburg, Cumberland County, Pennsylvania 17050.
Both Plaintiff and Defendant have been bona fide residents in the Commonwealth
of Pennsylvania for at least six (6) months prior to filing this complaint.
4. The Plaintiff and Defendant were married on February 1, 1986 in Harrisburg
Dauphin County, Pennsylvania.
5. There are three (3) minor children born of this marriage being Jason R. Miller (DOB:
2/27/88) Melissa D. Miller (DOB: 2/6/90); and Samantha E. Miller (DOB: 5/22/95).
n
6. The parties separated on September 10, 2001.
There have been no prior actions for divorce or annulment between the parties.
8. Neither Plaintiff nor Defendant is in the military or naval service of the United States
or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of
1940 and its amendments.
9. Plaintiff has been advised that counseling is available and that Plaintiff has the right
to request that the court require the parties to participate in counseling.
COUNT I -DIVORCE
NO FAULT
10. The averments in pazagraphs 1 through 9, inclusive, of Plaintiffs Complaint aze
incorporated herein by reference thereto.
11. The marriage is irretrievably broken and no possibility of reconciliation exists.
WHEREFORE, Plaintiff requests entry of a divorce decree in her favor in accordance with
§ 3301 of the Pennsylvania Divorce Code.
COUNT II
EQUITABLE DISTRIBUTION
12. The averments in paragraphs 1 through 11 of Plaintiffs Complaint are incorporated
herein by reference thereto.
13. The Plaintiff requests the Court to equitably divide, distribute or assign the marital
property between the parties in such proportion as the Court deems just after consideration of all
relevant factors.
WHEREFORE, Plaintiffrequests this Court to equitably divide said property in accordance
with Section 401(d) of the Pennsylvania Divorce Code.
COUNT III
SUPPORTS ALIMONY PFNDENTE LITE AND ALIMONY
14. The averments in paragraphs 1 through 13, inclusive, of Plaintiffs Complaint are
incorporated herein by reference thereto.
15. Plaintiff requires reasonable support to adequately sustain herself with the standard
of living established during the marriage.
WHEREFORE, Plaintiff requests an award of Support, Alimony and Alimony Pendente Lite.
COUNT IV
ATTORNEY'S FEES AND COSTS
16. The averments in paragraphs 1 through 15, inclusive, of Plaintiffs Complaint are
incorporated herein by reference thereto.
17. Plaintiff is unable to sustain herself during the course of this litigation and has
employed Barbara Sumple-Sullivan, Esquire as counsel, but is unable to pay the necessary and
reasonable attorney's fees for said counsel, and the necessary and reasonable costs and expenses.
WHEREFORE, Plaintiff requests an award of counsel's fees and expenses.
WHEREFORE, Plaintiff, Jennifer L. Miller, prays this Honorable Court to enter judgment:
A. Awarding Plaintiff a decree in divorce;
B. Awarding Plaintiff support, alimony and alimony pendente liter
C. Awarding Plaintiff counsel fees, costs and expenses;
D. Equitably distributing the marital property; and
E. Awarding other relief as the Court deems just
Dated: ~~~~~ ~~
Barbara Sumple-Sullivan, Esquire
Attorney for Plaintiff
549 Bridge Street
New Cumberland, PA 17070-1931
(717)774-1445
Supreme Court I.D. No. 32317
Bazbam Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445 -
JENNIFER L. MILLER,
Plaintiff
v.
STEVEN B. MILLER,
Defendant
1N THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION -LAW
IN DIVORCE
A`FFiDAViT REGA_R~ING COUNSELING
I have been advised of the availability of marriage counseling and understand that
I may request that the Court require that my spouse and I participate in counseling.
2. I understand that the Court maintains a list of marriage counselors in the Domestic
Relations Office, which list is available to me upon request.
3. Being so advised, I do not require that the Court require that my spouse and I
participate in counseling 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.A
Section 4904 relating to unsworn falsification to authorities.
Dated: ~ ~o~ o t ~O~ i~~
NIF L. MILLER
Bazbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(7171774-1445
JENNIFER L. MILLER,
Plaintiff
v.
STEVEN B. MILLER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.
CIVIL ACTION -LAW
IN DIVORCE
VERIFICATION
I, JENNIFER L. MILLER, hereby certify that the facts set forth in the foregoing
COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and
belief. I understand that any false statements made herein are subject to penalties of 18 Pa. C.S.A.
Section 4904 relating to unsworn falsification to authorities.
C
Dated: O ~b
NI L. LER
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Bazbaza Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(7171774-1445
JENNIFER L. MILLER,
Plaintiff
v.
STEVEN B. MILLER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
N0. 01-5731
CIVIL ACTION -LAW
IN DIVORCE
AFFILAVIT OF CONSENT
A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
October 2, 2001.
2. The marriage ofthe Plaintiffand Defendant is irretrievably broken. Ninety days have
elapsed since the filing and service of the Complaint.
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 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 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.A. §4904 relating to unsworn
falsification to authorities.
DATE; 9~~'~03
,--
NN R L. MILLER
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Barbara Sample-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(7171774-1445
JENNIFER L. MILLER,
Plaintiff
v.
STEVEN B. MILLER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
N0. 01-5731
CIVIL ACTION -LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on
October 2, 2001.
2. The marriage of the Plaintiffand Defendant is irretrievably broken. Ninety days have
elapsed since the filing and service of the Complaint.
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 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 aze made subject to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn
falsification to authorities.
DATE:
VEN $. MILLER
COMMONWEALTH OF PENNSYLVANIA )
/ / ) SS.
COUNTY OF C /~/~~/ )
Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County,
personally appeared STEVEN B. MILLER., who being duly affirmed according to law, deposes
and says that the facts and matter set forth in the within and foregoing AFFIDAVIT OF
CONSENT are true and correct to the best of his knowledge, information and belief.
Affirmed and subscribed to before me this ~ day of 2003.
f
NOT PUBLIC
ommission Expires:
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(SEAL) JAM@8 A. MILLER; Notary Publlo•
Bpro of f{eSnR HIII, Cugldarland County, PAr
My-Commission Expires April 30, 2005
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Supreme Cour[ #32317
549 Bridge Street
New Cumberland, PA 17070
(717)774-1445
JENNIFER L. MII,LER,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5731
STEVEN B. MILLER, :CIVIL ACTION -LAW
Defendant IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO RE(
ENTRY OF A DIVORCE DECREE UNDEI
&3301(cl OF THE DIVORCE CODE
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 pro~ty, ~ `-
lawyer's fees or expenses if I do not claim them before a divorce is granted. ~ ~`" .__ ,-„T,
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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 statement herein are made subject to the penalties of 18 Pa.C. S. §4904 relating to unsworn
falsification to authorities.
DATE: ~~jY/~3
NIFE .MILLER
~.
Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
JENNIFER L. MILLER,
Plaintiff
v.
STEVEN B. MILLER,
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5731
CIVIL ACTION -LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§3301(cl OF THE DIVORCE CODE
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 statement herein are made subject to the penalties of I S Pa. C. S. §4904 relating to unsworn
falsification to authorities.
DATE: 3
S EVEN .MILLER
~:
COMMONWEALTH OF PENNSYLVANIA )
~ ~~ ~ ) SS.
COUNTY OF ~ ~i"2M~`+~ )
Before me, the undersigned officer, a Notary Public in and for said Commonwealth and County,
personally appeared STEVEN B. MILLER, who being duly affirmed according to law, deposes
and says that the facts and matter set forth in the within and foregoing WAIVER OF NOTICE
OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c)
OF THE DIVORCE CODE are true and correct to the best of his knowledge, information and
belief.
Affirmed and subscribed to before me this / day of - ~~~~003.
t/ ~ ppTAR1ACSEAL
NOTAR P L1C JAMES A. MILLER, Notary Public
My Co 'Sion Expires: aoro of camp rlui, cumbadana county, PA
My Commission Expires April 30, 2005
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Barbara Sumple-Sullivan, Esquire
Supreme Court #32317
549 Bridge Street
New G~mberland, PA 17070
(7171774-1445
JENNIFER L. MILLER,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-5731
STEVEN B. MILLER, :CIVIL ACTION -LAW
Defendant IN DIVORCE
AC['FPTA_NCE OF SERVICE
I, STEVEN B. MILLER, hereby personally accept service and aclrnowledge receipt of
the above-captioned Complaint in Divorce, having received said Complaint on the` 5~ day
of (~C7a/3Fi? , 2001.
.-
TEVEN B. MTLLE
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