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HomeMy WebLinkAbout01-6357IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARTIN H. MILLER, Plaintiff PATSIE M. MILLER Defendant CIVIL ACTION - LAW NO. 2001- 633'7 IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS 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 at the Office of the Prothonotary, 1 Courthouse Square, Carlisle, Pa. You are advised that this list is kept as a convenience to you and you are not bound to choose a counselor from the list. All necessary arrangements and the cost of counseling sessions are to be borne by you and your spouse. If you desire to pursue counseling, you must make your request for counseling within twenty (20) days of the date on which you receive this notice. Failure to do so will constitute a waiver of your right to request counseling. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR ANNULMENT IS ENTERED, 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 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 MARTIN H .MILLER Plaintiff V. PATSIE M. MILLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001- IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) OF THE DIVORCE CODE AND NOW, this ~ ~t. day of November, 2001 comes Plaintiff, Martin H. Miller, by and through his attorney, Richard L. Webber, Jr., Esquire, &the Law Office &Michael J. Hanft, and files thc following Complaint in Divorce, and in support thereof avers as follows: 1. The Plaintiff is Martin H. Miller, who currently resides at 220 Green Hill Road, Newville, Cumberland County, Pennsylvania 17241, since 1981. 2. The Defendant is Patsie M. Miller, who currently resides at 220 Green Hill Road, Newville, Cumberland County, Pennsylvania 17241, since 1981. 3. The Plaintiff and Defendant are sui juris, and both have been bona fide residents of the Commonwealth of Pennsylvania for a period of more than six (6) months immediately preceding the filing of this Complaint in Divorce. Pennsylvania. 5. The parties were married on November 14, 1971 in Newville, Cumberland County, There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. The Plaintiff has been advised of the availability of counseling, and that the Plaintiff may have the fight to request that the Court require the parties to participate in counseling. 8. Plaintiff requests that the Court enter a decree of divorce. WHEREFORE, Plaintiff requests Your Honorable Court to enter a Decree in Divorce, divorcing the Plaintiff from the Defendant, and any other appropriate relief. Respectfully submitted, LAW OFFICE OF MICHAEL J. HANFT Richard L. Webber, Jr., Esquirg~L, Attorney ID No. 49634 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 (717) 249-5373 VERIFICATION Marlin H. Miller hereby verifies that the facts set forth in the foregoing Complaint are true and correct to the best of his knowledge, information and belief, and understands that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unswom falsifications Martin H. Miller Date: II- LAW OFFICE C~a HAELJ. HANFT ATTORNEYS & COUNSELLORS AT LAW 19 BROOKWOOD AVENUE StnT[ 106 CARLISLE, PA 17013-9142 717.249.5373 F^x 717.249.0457 WWW. HANFTIAWF]RM,COM MARLIN H. MILLER, Plaintiff PATSIE M. MILLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001-06357 IN DIVORCE PRAECIPE TO AMEND CAPTION To the Prothonotary: Please amend the caption in the above divome action to by changing Plaintiff's name from Martin H. Miller to Marlin H. Miller. LAW OFFICE OF MICHAEL J. HANFT Date: November 9, 2001 By: Richard L. Webber, Jr., Esq!ti~e Attorney I.D. No. 49634 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013 (717) 249-5373 Attorney for Plaintiff 0 ~ ZD C~ q) 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARLIN H. MILLER, Plaintiff PATSIE M. MILLER Defendant CIVIL ACTION - LAW NO. 2001-06357 IN DIVORCE ACCEPTANCE OF SERVICE I, PATSIE M. MILLER, the Defendant in the above captioned matter, hereby accept service of the Complaim filed in the. above captioned matter. · Miller MARLIN H. MILLER, Plaintiff PATSIE M. MiLLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001-06357 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 ifI 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: Patsie M. Miller, Defend~ni MARLIN H. MILLER, Plaintiff V. PATSIE M. MILLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001-06357 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on November 7, 2001. 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. 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., Section 4904 relating to unswom falsification to authorities. Patsie M. Miller, Defendant MARLIN H. MILLER, Plaintiff PATSIE M. MILLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001-06357 IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on November 7, 2001. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety 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 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., Section 4904 relating to unswom falsification to authorities. Date: 09 ' ~ nj ~ (3 ~ Marlin H. ~liller, Plaintiff MARLIN H. MILLER, Plaintiff PATSIE M. MILLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 2001- 06357 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 ifI 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. Oate:5-0 oq Marlin H. Miller, Plaintiff 02 FEB 28 AH 8:20 CUMBERU~,ND COUNtry PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARLIN H. MILLER, Plaintiff V. PATSIE M. MILLER, Defendant CIVIL ACTION - LAW NO. 2001-06357 IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary. Transmit the record, together with the following infom,ation, to the court for entry of a divorce decree: Grounds for divorce: irretrievable breakdown under § 3301(c) of the Divorce Code. Date and manner of service of the complaint: November 12, 2001, Acceptance of Service. Date of execution of the affidavit of consent required by § 3301 (c) of the Divorce Code: by Plaintiff: February 23, 2002; by Defendant: February 23, 2002. Related claims pending: None Date Plaimiff's Waiver in § 3301(c) Divorce was filed with the prothonotary: February 28, 2002 Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the prothonotary: February 28, 2002. WEIGLE & ASSOCIATES, P.C. Richard L. Webber, Jr., Esquire Attorney for Plaintiff Attorney ID g49634 126 East King Street Shippensburg, PA 17257 Telephone (717)532-7388 WEIGLE & ASSOCIATES, AC. -- ATTOP. NE¥S AT LAW -- 126 E/XST KING STREET -- SHIPPENSBURG, PA 17257-1397 iN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of NARLIN H. NILLI~. Plaintiff VERSUS PATSIE M. MILL~ Defendant PENNA. 2001-06357 AND NOW, DECREED THAT AND DECREE IN · DIVORCE MARLIN H. PATSIE M. MILLF. R , 2002 , IT IS ORDERED AND , PLAINTIFF, , 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; ATTEST:~ Jo PROTHONOTARY