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Home My WebLink About99-04564r. ?tl:,c, k ??A ',A( ;'! ?I j,: (ff yft Y? 1? +; I'f .4. •:t J. ?? i:(q ANNE MARIE MILLER, Plaintiff vs. KENNETH M. MILLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CR 45LA NO. CIVIL-TCRt'? IN DIVORCE 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 will proceed without you and a decree of divorce or annulment may be entered against you for any 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 at Cumberland County Courthouse, Carlisle, Cumberland County, Pennsylvania, 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL 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 Two Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 ANNE MARIE MILLER, Plaintiff VS. KENNETH M. MILLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. CIVIL IN DIVORCE 1. Plaintiff is Anne Marie Miller, an adult individual currently residing at 199 Fairview Drive, Carlisle, Cumberland County, Pennsylvania. She has lived there for eight (8) years. 2. Defendant is Kenneth M. Miller, an adult individual whose last known address was 199 Fairview Drive, Carlisle, Cumberland County, Pennsylvania but his current resident address is unknown to the Plaintiff. 3. Plaintiff is a bonafide resident of the Commonwealth of Pennsylvania and has been so for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on January 7, 1989 in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff and the Defendant are members of the United States Armed Forces or its Allies. 7. Plaintiff has been advised of the availability of counseling and the right to request that the Court requires the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States America. 9. The parties' marriage is irretrievably broken. 10. Plaintiff desires a divorce based upon the belief that the Defendant will, ninety (90) days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce pursuant to Section 3301 (c) of the Domestic Relations Code. 11. Paragraphs 1 through 10 above are incorporated herein by reference as is set forth in their full text. 12. Plaintiff and Defendant are joint owners of certain real estate located at 199 Fairview Drive, Carlisle, Cumberland County, Pennsylvania. 13. Plaintiff and Defendant are joint owners of various items of personal property, furniture, and household furnishings acquired during their marriage which are subject to equitable distribution. 14. Plaintiff and Defendant have incurred debts and obligations during their marriage which are subject to equitable distribution. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide their marital property and equitably apportion their debts. 15. Paragraph I through 14 are incorporated herein by reference as if set forth in their full text. 16. Plaintiff is unable to provide for or afford her counsel fees, expenses, and costs during the pendency of this divorce action and through its resolution. 17. Plaintiff is without sufficient property and otherwise unable to financially support herself despite being employed. 18. Defendant is presently employed and receiving a substantial income and benefits and is able to pay for counsel fees, expenses, and costs as well as alimony and alimony pendente lite for Plaintiff. WHEREFORE, Plaintiff requests your Honorable Court to enter an Order requiring Defendant to pay Plaintiff's counsel fees, expenses, and costs as well as providing for payment of appropriate alimony and alimony pendente lite to Plaintiff. Respectfully submitted, GRIFFIE & ASSOCIATES j5Wey forY4 intiff 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein made are subject to the penalties of 18 PA.C.S. Section 4904 relating to unsworn falsification to authorities. DATE: T(A Q ti l 3. t I 9 aMn_ e-Z /t P _ ?1 / ANNE MARIE MILLER, Plaintiff c. - i -J O J O 0 Q 00 f1 5?+ ANNE MARIE MILLER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. CIVIL ACTION - LAW KENNETH M. MILLER, : NO.9q'q!5(IVIL Defendant : IN DIVORCE AND NOW, this / 7 /J day of 1999, comes Bradley L. Griffe, d Esquire, attorney for Plaintiff, Anne Marie Miller, and states that the Defendant, Kenneth M. Miller, was served with a true and attested copy of the Complaint in Divorce by certified mail, restricted delivery on August 9, 1999. Respectfully submitted, GRIFFIE & ASSOCIATES ffle, squire lai tiff 00orthoHanovcr Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 Swom and subscribed to this day of dZyje,d , 1992. Notary Pu lic Notarial Seal Robin J. Goshom, Notary Public Carlisle Boro, Cumberland County My Commission Expires Apr. 17, 2603 SENDER: edanpfafe ft. + 8rW.2 fa "ffd W w.,.. I also wish to receive the 'd°" a"' " e 3, µ and 4b• following services (for an •b nrmrawd...anm....mOf ffomlwem.ne..mmwe extra fee): •a s.d+f?iam fou»raada»menp.o.,ormeebook N oaaoo«.a t. ? pddreeeewsAddress PWA ?1 Return R PI slow to WhM taweiNtle°e wusdeYVveretl?and fl aw 2. l3al estfkYed Delivery dMMred. Consult postrnaeter for fee. 3. A cle Addreseed to: 4a Ardde Number ,?ennefh M. Miler m 13r?eker 41). SeMce Type -/ m ? Registered "Milled I r] 1 e?QC 0 KOQGI ? Express Mall ? Insured; MeehaolosbFA 17055 o ReafmRecWf« ? COD 7. Date of Delivery 5 6 IJA? 5. Received By: (Pdnt NW) S. ?resess' ess Y led Y I" Is U.1 S. Signature, ddrsssee orAaent boy 1 PS Form 3811, December 1994 _1 10259597-B-0179 Dom Reaeiot lf'i ' ><f U? ? i7G (..? N ? ? )Cl cri cn O