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Home My WebLink About07-2170 Sandra L. Meilton, Esquire DALEY ZUCKER MEILTON MINER &GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 smeilton cr~dznvnglaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBORAH S. MILLER, Plaintiff v. No. D7• a 170 CIVIL ACTION -LAW LINCOLN S. MILLER Jr., Defendant (In Divorce) NOTICE 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 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 at the Cumberland County Court House, High and Hanover Street, 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. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 DALEY ZUCKER MEILTON MINER &GINGRICH, LLC Date: ~ ~ 7. ~ 7 By: Sandra L. Meilton, quire Supreme Court ID # 32551 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 Attorneys for Plaintiff r Sandra L. Meilton, Esquire DALEY ZUCKER MEILTON MINER & GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717)657-4795 smeilton(c~dzmmglaw. com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBORAH S. MILLER, .. Plaintiff No. ~ ~' '~ /~Id C'~"e Tom""' v. CIVIL ACTION -LAW LINCOLN S. MILLER Jr., Defendant (In Divorce) COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Deborah S. Miller, who currently resides in Harrisburg, Dauphin County, Pennsylvania. 2. Defendant is Lincoln S. Miller Jr., who currently resides at 913 Peachtree Drive, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on July 27~, 1991 at Boiling Springs, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court requires the parties to participate in counseling. r ` 8. The causes of action and section of Divorce Code under which Plaintiff is proceeding are: A. Section 3301(c). The marriage of the parties is irretrievably broken. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an Affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an Affidavit. B. Section 3301(d). The marriage of the parties is irretrievably broken. The Plaintiff and Defendant separated on or about January 12, 2007. WHEREFORE, Plaintiff requests this Honorable Court enter a Decree in Divorce from the bonds of matrimony. Respectfully submitted, DALEY ZUCKER MEILTON MINER & GINGRICH, LLC Date: ~ ~ T~~ By: Sandra L. Meilton, E quire Supreme Court ID #32551 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 Attorneys for Plaintiff . ... VERIFICATION I, Deborah S. Miller, verify that the statements made in this 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. ~. Date: y iG aoo," l~-c~~~'~~~-c~ Deborah S. Miller, Plaintiff !'-) n,, .~ & . ~ `~' ~ ~ .~ ~ ~ - `~- ~ ~ ;~ ~ SL, Oo ~ , , z W ?, ~ ~ - _. t~ - _` '~+r ~ --s..1 t~. • ..~ Sandra L. Meilton, Esquire DALEY ZUCKER MEILTON MINER &GINGRICH, LLC 1029 Scenery Drive Harrisburg, PA 17109 (717) 657-4795 smeilton ~dzmmglaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DEBORAH S. MILLER, Plaintiff v. LINCOLN S. MILLER Jr., Defendant : No. 07-2170 CIVIL ACTION -LAW (In Divorce) PRAECIPE TO REINSTATE COMPLAINT TO THE PROTHONOTARY: Please reinstate the above-captioned Divorce Complaint for service upon the Defendant. Respectfully submitted, DALEY ZUCKER MEILTON MINER &GINGRICH, LLC Date:...5-~-~~- O7 By: andra L. Meilton, E quire Supreme Court I.D. #32551 1029 Scenery Drive Harrisburg, Pennsylvania 17109 (717) 657-4795 Attorneys for Plaintiff cc: John J. Connelly, Jr., Esquire, Counsel for Defendant, P.O. Box 650, Hershey, PA 17033-0650 a ~„., ~~ ,, ,. ~, o ~ a ~~ .~ w o -c~ ~ `~ ~- - ~ .~ ~ -.. ~' v, _ ~--