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HomeMy WebLinkAbout03-6538LESLIE A. MILLER, Plaintiff ANDREW J. MILLER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2003- &g3~ CIVIL TERM : 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. 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. Court Administrator Cumberland County Court House 1 Courthouse Square Carlisle, PA 17013 (717) 240-6200 RE JO S~,~me Cou~r~ ID #5~,~47J 36C North ~econd St~e~t, 8th Floor Harrisburg, PA 17101 (717) 221-1111 Attorney for Plaintiff LESLIE A. HILLER, Plaintiff Vo : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2003- ~.~,,.~,~ CIVIL TERM Ai~-DREW J. MILLER, Defendant : IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Leslie A. Miller, anadult individual, who currently resides at 155 South West Street ,Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Andrew J. Miller, anadult individual who currently resides at 26 North Market Street, Apt 2,Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been in the Commonwealth for at least six months to the filing of this Complaint. bona fide residents immediately previous 4. The Plaintiff and Defendant were married on May 25, 2000,in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Plaintiff has been advised of the availability of marriage counseling and the Plaintiff may have the right to request that the Court require the parties to participate in counseling. Having been so advised Plaintiff does not desire the Court to order counseling, as evidenced by the Affidavit as attached hereto and made a part hereof marked as "Exhibit A." 7. The marriage is irretrievably broken. WHEREFORE, Plaintiff requests Your Honorable Court to enter a decree in divorce. Re s~ec~ ~~~~ ~eme bo~t ID 3~0 North ~econd Street, 8th Floor Harrisburg, PA 17101 (717) 221-1111 LESLIE A. V. ANDREW J. MILLER, Plaintiff MILLER Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA · NO: CIVIL TERM : IN DIVORCE AFFIDAVIT I, LESLIE A. MILLER, Plaintiff, being duly sworn according to law, depose and say: (1) I have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. (2) I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. (3) Being so advised, I do not request that the court require that my spouse and I participate in counseling prior to a divorce decree being handed down by the court. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dated: LUslie A. Miller COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND :SS 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. CoSo Section 4904 relating to unsworn falsification to authorities. DATED: L Miller, Plaintiff LESLIE A. ANDREW J. MILLER, Plaintiff MILLER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 2003-6538 CIVIL TERM : IN DIVORCE AFFIDAVIT OF CONSENT (1) A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on December 19, 2003. (2) The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. (3) I consent to the entry of a final decree of divorce. (4) 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. 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 unsworn falsification to authorities. DATED: ~1~11 O~ ~lie A:-Miller , Plaintiff LESLIE A. MILLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : v. : 2003-6538 CIVIL TERM : ANDREW J. MILLER, : Defendant : IN DIVORCE AFFIDAVIT OF CONSENT TO DIVORCE (1) A Complaint in divorce under Section 3301{c) of the Divorce Code was filed on December 19, 2003. (2) Defendant acknowledges that service of the Complaint was made by certified mail on December 27, 2003. (3) The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. (4) 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. (5) I consent to the entry of a final decree of divorce. (6) I understand that if a claim for alimony, alimony pendente lite, marital property or counsel fees or expenses has not been filed with the court before the entry of a final decree in divorce, the right to claim any of them will be lost. (7) I have been advised of the availability of marriage counselling and understand that I may request that the court require that my spouse and I participate in counselling. Being so advised, I do not request that the Court require that my spouse and I participate in counselling prior to s divorce decree being handed down by the Court. 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 unsworn falsification to authorities. ~//~//~/ Andrew J. M[ll~,'~Defendant DATED: LESLIE A. MILLER , : Plaintiff : Yo ANDREW J. MILLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2003-6538 CIVIL TERM IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE (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. Section 4904 relating to unsworn falsification to authorities. Date: Andrew ~ ~4111er Defendant LESLIE A. MILLER , Plaintiff Vo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 2003-6538 CIVIL TERM ANDREW J. MILLER, Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE (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 tlhis 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 unsworn falsification to authorities. ~/~[/0% ~e~lie A. Millek, Defendant Date: iA) LESLIE A. MILLER, Plaintiff ANDREW J. MILLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : : 2003-6538 CIVIL TERM : : IN DIVORCE PP~AECIPE TO TRANSMIT RECO~D 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. (Strike out inapplicable section.) 2. Date and manner of service of the Complaint: Certified mail, return receipt requested December 27, 2003 attached hereto as Exhibit "A", postage prepaid. 3. (Complete either paragraph (a) or (b): (A) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: By the Plaintiff: March 31, 2004 By Defendant: April 11, 2004 (B) (t) Date of Execution of the Plaintiff's Affidavit required by Section 3301(d) of the Divorce Code: N/A. (2) Date of Service of the Plaintiff's Affidavit upon the Defendant: N/A 4. Related claims pending: None Joia J, ~SPec~y, E~'./'/ A~tt~'orney ~or Plaintifl~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE Of pcPrl lO'TI VERSUS J · r~)LL~/~ ~ PENNA. NO. AND NOW, DECREED THAT AND DECREE 1N DIVORCE , IT IS ORDERED AND ,PLAINTIFF, ,DEFENDANT, ARE DIVORCED FROM THE BONDS OW 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; ATT E ST~~/~// PROTHONOTARY