Loading...
HomeMy WebLinkAbout99-04635 N; .a C0 v l a IN THE COURT OF COMMON PLEAS OFCUMBERLAND COUNTY STATE OF PENNA. DAWN R. MILLS, Plaintiff NO. 99-4635 CIVIL TERM VERSUS DELNORE F. MILLS, JR 1'bfp Aant DECREE IN DIVORCE AND NOW,. 14 ? 2001 , IT IS ORDERED AND DECREED THAT Dawn R. Mills PLAINTIFF, AND Delnore F. Mills, Jr. , 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; DAWN R. MILLS, Plaintiff VS. DELNM F. MILLS, M., Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION NO. 99-4635 CIVILTERM 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 §3301(c) 33fik¢dWtof the Divorce Code. (Strike out inapplicable section). 2. Date and manner of service of the complaint: hand delivery on may 1, 2000 at Domestic Relations Office by Attorney Griffie 3. Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by §3301 (c) of the Divorce Code: by plaintiff June 160 znD1 ; by defendant June 5, 2001 (b) (1) Date of execution of the affidavit required by §3301(d) of the Divorce Code: (2) Date of filing and service of the plaintiff's affidavit upon the respondent: 4. Related claims pending: 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date of plaintiff's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: Date defendant's Waiver of Notice in §3301 (c) Divorce was filed with the Prothonotary: _, ?: tc? -- DAWN R. MILLS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTICIVIL 9 9'16 3_? DELNORE F. MILLS, JR., Defendant 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 DAWN R. MILLS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION-LAW NO. CIVIL 1999 - Y43YC';,,, 1 rerµ DELNORE F. MILL, JR., Defendant IN DIVORCE COMPLAINT IN DIVORCE NO FAULT Plaintiff is Dawn R. Mills, an adult individual currently residing at 2845 Rocky Spring Road, Chambersburg, Franklin County, Pennsylvania. 2. Defendant is Delnore F. Mills, Jr., an adult individual currently residing at 32 North East Street, Carlisle, Cumberland County, Pennsylvania. 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 September 20, 1997, in Shippensburg, Cumberland County, Pennsylvania. 5. There have been no other prior actions for divorce or annulment between the parties. 6. Neither the Plaintiff nor 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 require 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 of 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 divorce pursuant to 23 P.S. Section 3301 (c) of the Domestic Relations Code. 11. Paragraphs I through 10 are incorporated herein by reference as if set forth in their full text. 12. Defendant has committed such indignities upon the person of the Plaintiff, the innocent and injured spouse, as to make his condition intolerable and life burdensome. WHEREFORE, Plaintiff requests your Honorable Count to enter a divorce pursuant to 23 P.S. Section 3301 (a) (6) of the Domestic Relations Code. Respectfully submitted, GRIFFIE & ASSOCIATES Kristen Goddard D en, Esquire Attorney for Plaintiff GRIME & ASSOCIATES 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. 1 understand that false statements herein made arc subject to the penalties of 18 Pa.C.S. Section 4904 relating to unworn falsification to authorities. DATE: M? DAWN R. MILLS, Plaintiff i- r i. O r? i i S :J Y of CO c 0 Q a , \ vJ 1 U D it j V 11?iF/lONON1021d .................... Q31H1SN1321IN IY7 p0 na7, . ..............i I e. 1. DAWN R. MILLS, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA DELNORE F. MILLS, JR. Defendant : CIVIL ACTION - LAW NO. 99-4635 CIVIL TERM IN DIVORCE A. Complaint in Divorce under §3301 (c) of the Divorce Code was filed on August 2, 1999, reinstated on April 28, 2000, and served on May 3, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service 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 VERITY THAT THE STATEMENTS MADE IN THE FOREGOING 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: DAWN R. MILLS, Plaintiff ;? ? ? :? ; - ;_? ??_? -, DAWN R. MILLS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. DELNORE F. MILLS, JR. Defendant CIVIL ACTION - LAW NO. 99-4635 CIVIL TERM IN DIVORCE 1. A. Complaint in Divorce under §3301 (c) of the Divorce Code was filed on August 2, 1999, reinstated on April 28, 2000, and served on May 3, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service 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 VERITY THAT THE STATEMENTS MADE IN THE FOREGOING 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: '? " ? - b 1 , DELNORE F. MILLS, JR., Defendant Cl. i-Au 'c o U DAWN R. MILLS, V. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA DELNORE F. MILLS, JR. Defendant : CIVIL ACTION - LAW NO. 99-4635 CIVIL TERM IN DIVORCE 1. 1 consent to the entry of a final decree in 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 divorce 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 files with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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:. ??1?11 A DAWN R. MILLS, Plaintiff I LI DAWN R. MILLS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. DELNORE F. MILLS, JR. Defendant CIVIL ACTION - LAW NO. 99-4635 CIVIL TERM IN DIVORCE WAIVE R ON NOTICE OF INT NTION TO RFC ST UN THE ENTRY OF A DIVORCE DECREE DER §3301(c) OF THE DIVORCE Copy 1. I consent to the entry of a final decree in 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 divorce 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 files with the Prothonotary. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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: !o - 5 ' O 1 DELNORE F. MILLS, JR., Defendant R~ ? ' 7? ??. N ?.,` i ? y :?.? t??r f" _?"I_ C..:. ?, : _na- ? ? y ?U O U V. DELNORE F. MILLS, JR., Defendant CIVIL ACTION - LAW NO. 99-4635 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this ci = day of I ))lj T , 2000, comes Bradley L. Griffie, Esquire, Attorney for Plaintiff, and states that he personally handed a certified and true copy of a Complaint in Divorce to the Defendant, Delnore F. Mills, Jr., on Monday, May 1, 2000, at the Domestic Relations Office, 13 North Hanover Street, Carlisle, Cumberland County, Pennsylvania. Sworn and subscribed to before me this days ooff) '2000. NOTARY PC lIC Nolariel Seel Robin J. Goshom, Notary Public Carlisle 60ro, Cumberland County My commission F_xpues Apr 17, 2003 Bfad Griffie, Esquire ey for Plaintiff GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 W- I iq l F[ KC i ?1.Li o U DAWN R. MILLS, V. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA DELNORE F. MILLS, JR., Defendant TO THE PROTHONOTARY: CIVIL ACTION - LAW NO. 99-4635 CIVILTERM IN DIVORCE PRAECIPE Please reinstate the Complaint in Divorce filed in the above captioned action. Respectfully submitted, Date: g C7 Bra le squire or.Pl6mtiff RIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 ;,,