HomeMy WebLinkAbout99-04104?;:::
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IN THE COURT OF COMMON PLEAS
OFCUMBERLAND COUNTY
STATE OF PENNA.
EATHLEEN A. MILLER
No. 99-4104 CIVIL
Plaintiff
VERSUS
MATTHEW A. MILLER
Defendant
DECREE IN
DIVORCE
AND NOW, CA I , 2000 , IT IS ORDERED AND
DECREED THAT KATHLEEN A. MILLER PLAINTIFF,
AND MATTHEW A. 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;
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KATHLEEN A. MILLER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND CO., PENNSYLVANIA
V. No. 99-4104 CIVIL
MATTHEW A. MILLER,
Defendant CIVIL ACTION - LAW
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
(x) 3301(c) ( ) 3301(d) (1) of the Divorce Code.
2. Date and manner of service of the Complaint: On Defendant by
Affidavit of service filed July 29 1999
3. (Complete either paragraphs (a) or (b)
(a) Date of execution of the Affidavit of Consent required by
Section 3301(c) of the Divorce Code: by Plaintiff: November 5, 1999; by
Defendant: November 5, 1999.
(b) Date of execution of the Waiver of Notice on Intention to
Request Entry of Divorce Decree under §3301(c) of the Divorce Code: By
Plaintiff: November 5, 1999; by Defendant: November 5, 1999.
(c) (1) Date of execution of the Plaintiff's Affidavit required
by Section 3301(d) of the Divorce Code: N/A;
(2) date of service of the Plaintiff's Affidavit upon the
Defendant: 1A.
4. Related claims pending: None.
PURCELL, KRUG & HALLER
By
, Esquire
Date:
1719 North Front Street
Harrisburg, PA 17102
(717)234-4178
Attorney for Plaintiff
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KATHLEEN A. MILLER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. `/? NIDN \FC,c C [Q 211
MATTHEW A. MILLER, IN DIVORCE
Defendant CIVIL ACTION - LAW
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
claims set forth in the COMPLAINT IN DIVORCE 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 counseling. A
list of marriage counselors is available in the Office of the
Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
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
CUMBERLAND COUNTY COURTHOUSE
ONE COURTHOUSE SQUARE
CARLISLE, PA 17013
(717)240-6200
KATHLEEN A. MILLER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
VS. NO. S 9 V16Y (cum Tau
MATTHEW A. MILLER, IN DIVORCE
Defendant CIVIL ACTION - LAW
COMPLAINT IN DIVORCE
AND NOW COMES Plaintiff, Kathleen A. Miller, by and through her
attorneys, Purcell, Krug & Haller, and avers as follows:
COUNT I
DIVORCE PURSUANT TO SECTION 3301 (c)
OR 3301 (d) OF THE DIVORCE CODE OF 1980
1. Plaintiff is Kathleen A. Miller, an adult individual who
currently resides at 513 South Third Street, Lemoyne, Cumberland
County, Pennsylvania 17043.
2. Defendant is Matthew A. Miller, an adult individual with a
last known address at 227 Herr Street, Harrisburg, Dauphin County,
Pennsylvania 17102.
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 May 17, 1985.
5. Plaintiff avers that there are no children born of this
marriage.
6. There have been no prior actions in divorce or annulment
between the parties.
7. Neither of the parties in this action is presently a member
of the Armed Forces.
8. The Plaintiff and Defendant are both citizens of the United
States.
9. The marriage is irretrievably broken.
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10. Plaintiff has been advised of the availability of
counseling and that the Plaintiff may have the right to request that
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I the Court require the parties to participate in counseling. Being so
advised, Plaintiff does not request that the Court require the
parties to participate in counseling prior to a divorce decree being
handed down by the Court.
WHEREFORE, Plaintiff requests the Court to enter a Decree in
Divorce pursuant to Section 3301(c) or 3301(d) of the Divorce Code.
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PURCELL, KRUG & HALLER
By
,,N`--hole M.,Staiey,/ Esquire
ID #79866 L
1719 North Front Street
Harrisburg, PA 17102
(717)234-4178
Dated: July 2, 1999
2
VERIFICATION
I, KATHLEEN A. MILLER, verify that the statements made in
the foregoing Complaint are true and correct. I understand that
false statements herein are made subject to the penalties of 18
Pa.C.S. §4904, relating to unsworn falsification to authorities.
By.KA?.Q?GC?it
HLEEN A. MILLER
Dated:
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ON 11YO1 0'J I1NM \Y03131YIC-\A
KATHLEEN A. MILLER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND CO., PENNSYLVANIA
VS. NO. 99-4104 CIVIL
MATTHEW A. MILLER, CIVIL ACTION - LAW
Defendant IN DIVORCE
AFFIDAVIT OF SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
I, Nichols M. Staley, Attorney for the Plaintiff in the above
action, hereby swear and affirm that on the 12th day of July, 1999, I
sent, by certified mail, return receipt requested a Complaint in
Divorce to the Defendant, Matthew A. Miller.
The Return Receipt Card signed by the Defendant on July 13, 1999
is attached hereto as Exhibit "A".
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Sworn and subscribed to
before me this 4 10 day
of 1999.
CC?ILa.iLt,C..-
N tary Public '
{ NOTARIAL SEAL
BARBARA A. SHADEL, Notary PubNc
Harrisburg, Dauphin County
i MY Commission Expires March 17, 2003
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ER: I also wish to receive the follow.
We 4eme I andror 2lor adduionat services. Ing services (for an extra fee):
We items 3, 4a. and 4b.
sor name and address on the reverse of this torn so that we can refum this
you. 1. ? Addressee's Address
this form to the front of the madpiece. or on the bads if specie does not
2.A7Aestridetl Delivery
the headpiece below the snide number.
Reran
Receipt end will d show who
alum Receipt show w to n whom The e snide was delivered and the date
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0. Article muresseU to:
r. Matthew A. Miller
27 Herr Street
arr.isburg, PA 17102
or
a
PS Form 3811, December 1994
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O Registered XKt Certified
:' Express Mail ?Insured
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fee
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EXHIBIT "A"
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KATHLEEN A. MILLER,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND CO., PENNSYLVANIA
VS.
MATTHEW A. MILLER,
Defendant
No. 99-4104 CIVIL
IN DIVORCE.
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the divorce Code was filed on
July G, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of filing and service of the Complaint.
3. 1 consent to the entry ofa final decree of divorce after service of notice of intention
to request entry of the decree.
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§3301(c) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce without notice.
2. 1 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. 1 understand
that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904 relating to
unsworn falsification to authorities.
Date: ?r ?_ I ' \C?i(?e, ,.J 1A /K.IQPo?
Matthew A. Miller
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KATHLEEN A. MILLER, IN THE COURT OF COMMON PLEAS
Plaintiff CUMBERLAND CO., PENNSYLVANIA
VS.
No. 99-4104 CIVIL
MATTHEW A. MILLER,
Defendant IN DIVORCE.
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the divorce Code was filed on
July 6, 1999.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days
have elapsed from the date of filing and service of the Complaint.
3. 1 consent to the entry ofa final decree of divorce after service of notice of intention
to request entry of the decree.
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
§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 1 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. § 4904 relating to
unsworn falsification to authorities.
Date: ?IZ;
Ka Teen A. Miller
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