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HomeMy WebLinkAbout07-6204r TIMOTHY W. MILLHOUSE, JR. Plaintiff V. CRYSTAL R. MILLHOUSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07- 6)-,6q IN DIVORCE CIVIL TERM 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 Streets, Carlisle. 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, PA 17013 Phone: (717) 249-3166 r TIMOTHY W. MILLHOUSE, JR. Plaintiff V. CRYSTAL R. MILLHOUSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. D -7 - (0c" CIVIL TERM IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Timothy W. Millhouse, Jr., who currently resides at 7 Fairfield Street, Mt. Holly Springs, Cumberland County, Pennsylvania, since December 2004. 2. Defendant is Crystal R. Millhouse, who currently resides at 7 Fairfield Street, Mt. Holly Springs, Cumberland County, Pennsylvania, since December 2004. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on May 19, 2001, at Newville, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 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 require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a Decree of Divorce. J I 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: 1o as-d IM4 -W, UXL04- i. Timot W. Millhouse, Jr., aintiff ANDREWS & JOHNSON By: Ronald E. Jo don, Esq. Attorneys f Plaintiff 78 W. Pomfret Street Carlisle, PA 17013 (717) 243-0123 ? W4 M ? A q' C, C? f CJ ' w l `'mot'.. ? ? •_'1 ? ^C 4/ TIMOTHY W. MILLHOUSE, JR. Plaintiff V. CRYSTAL R. MILLHOUSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-6204 CIVIL TERM IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND AND NOW, this 31" day of October 2007, I, Ronald E. Johnson, Esquire, attorney for Timothy W. Millhouse, Jr., Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint in Divorce, with Notice to Defend and Claim Rights, executed by the Plaintiff in the above-captioned matter, upon the Defendant at her residence at 7 Fairfield Street, Mt. Holly Springs, PA 17065, by depositing the same in the U.S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on October 27, 2007, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. ANDREWS & JOHNSON Sworn and subscribed to before me this By: Ronald E. Jo 0 Attorney for P ntiff COMMONWEALtH OF PENNSYLVANIA NOTARIAL SEAL SHELLY SEXTON, Notary Public Carlisle Boro, Cumberland County Cw nission Expires April 26, 2011 I fern 4 n I%MddW DoOvay b f W0 . 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MILLHOUSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 07-6204 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 23, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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 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: Cry al R. Millhouse, Defendant C7 C TIMOTHY W. MILLHOUSE, JR. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW CRYSTAL R. MILLHOUSE, : NO. 07-6204 CIVIL TERM Defendant : IN DIVORCE 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 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 statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities. Date: C)a r S- TIMOTHY W. MILLHOUSE, JR. Plaintiff V. CRYSTAL R. MILLHOUSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-6204 CIVIL TERM IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on October 23, 2007. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing 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 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: - o X-M4 u - mix."Q y Timothy . Millhouse, Jr., Plaintiff t`*J r4. :s. I ?+ 4 ? c^ TIMOTHY W. MILLHOUSE, JR. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW CRYSTAL R. MILLHOUSE, : NO. 07-6204 CIVIL TERM Defendant : IN DIVORCE 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 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 statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: Timoth . Millhouse, Jr., YIntiff sv Vi t TIMOTHY W. MILLHOUSE, JR. Plaintiff V. CRYSTAL R. MILLHOUSE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 07-6204 CIVIL TERM IN DIVORCE 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 3301(c) of the Divorce Code. 2 Date and manner of service of the complaint: October 27, 2007, restricted certified mail, return receipt requested. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by the Plaintiff February 18, 2008; by Defendant February 18, 2008 4. Related claims pending: None 5. Date 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: Date: zL '2008 By: ANDREWS & JOHNSON onald E. Johnso q. 78 West Pomfret treet Carlisle, PA 17013 (717) 243-0123 Supreme Court ID No. 16453 N CC:3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. TIMOTHY W. MILLHOUSE, JR „ Plaintiff VERSUS CRYSTAL R. MILLHOUSE Defendant DECREE IN DIVORCE AND NOW, d `?? IT IS ORDERED AND DECREED THAT TIMOTHY W. MILLHOUSE, JR PLAINTIFF, AND CRYSTAL R. MILLHOUSE ,DEFENDANT, No. 07-6204 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; NONE ' / ?f tc ??? ? ??? ??J ?? ?Q -? . ? ? ?