HomeMy WebLinkAbout08-3824In the Court of Common Pleas, Cumberland County, Pennsylvania
Danielle R Miller ) Term, 2
Plaintiff
V.
Case Number: e91? " 394;21/ e!utX
Jesse A Miller
Defendant
Notice to Defend and Claim Rights
TO: Jesse A Miller
You have been sued in Court. If you wish to defend against the claim 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
child(ren).
When the grounds for divorce are 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 , Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS 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:
Lawyer Referral Service (enter address below):
Phone:
AMERICANS WITH DISABILITIES ACT OF 1990
In Re the Marriage of-.
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the Court,
please contact our office. All arrangements must be made at least seventy-two (72) hours prior to
any hearing or business before the Court. You must attend the scheduled conference of hearing.
Date:
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Print Name (Plaintiff)
ignature (Plaintiff)
Mailing Address: 801B Bridge St, New Cumberland, Pennsylvania, 17070
Phone: 717-817-6266
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In the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of,
Danielle R Miller
Plaintiff
V.
Jesse A Miller
Defendant
Term, 2
Case Number d - 3 F' I-t an
Complaint for Divorce
COUNTI
REQUEST FOR DIVORCE UNDER SECTION 3301(C) OF THE DIVORCE CODE
1. Plaintiff is Danielle R Miller, who currently resides at 801B Bridge St, New Cumberland,
Pennsylvania, 17070
2. Defendant is Jesse A Miller, who currently resides at 5441 Pond Rd, Harrisburg, Pennsylvania,
17111
3. Danielle R Miller (the Plaintiff) has been a bona fide resident of the Commonwealth of
Pennsylvania for a period of more than six(6) months immediatley preceding the filing of this
Complaint.
4. The parties were married on June 18, 2005 in the city of Hershey, in the state of Pennsylvania.
Attached hereto and marked Exhibit "A" is the certificate of marriage evidencing said marriage.
5. The Plaintiff is not currently pregnant.
6. There are no minor children born or legally adopted of the marriage.
7. Military Status:
The Plaintiff is is not in the military or naval service of the United States or its allies within the
provisions of the Soldier's and Sailors' Civil Relief Act of the Congress of 1940 and its
amendments.
The Defendant is not in the military or naval service of the United States or its allies within the
provisions of the Soldier's and Sailors' Civil Relief Act of the Congress of 1940 and its
amendments.
8. There have been no prior actions for divorce or annulment between the parties.
9. There are no protective orders between the Plaintiff and Defendant.
10. The Defendant has been advised of the availability of counseling and the right to request that
the Court require the parties to participate in Counseling.
11. The marriage of the parties is irretrievable broken.
12. After 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.
WHEREFORE, if both parties file affidavits consenting to a divorce after 90 days have elapsed
from the date of the filing of this Complaint, Plaintiff respectfully requests that a decree of divorce be
entered pursuant to Section 3301(c) of the Divorce code dissolving the marriage between Plaintiff and
Defendant.
COUNT II
REQUEST FOR INCORPORATION OF MARITAL SETTLEMENT
AGREEMENT PUSUANT TO SECTION 3104(A)(1) AND (3) AND 3323(B)
OF THE DIVORCE CODE
13. Paragraphs 1 through 12 are incorporated herein and made part hereof by reference as though
fully set forth.
14. Plaintiff and Defendant have reached an agreement on issues including, but not limited to the
following;
Property and Debt, Retirement Accounts, Spousal Maintenance, Health Insurance, and Tax
Filings.
WHEREFORE, Plaintiff respectfully requests that this Court approve and incorporate a signed
Marital Settlement Agreement reached between Plaintiff and Defendant in the final divorce
decree, pursuant to Sections 3104(a)(1) and (3) and 3323(b) of the Divorce Code.
Furthermore, the Plaintiff has chosen to act as her own attorney in a pro se fashion, and
understands that she has the legal right to representation by an attorney. She fully understands her
rights and considers the terms of the parties' agreement to be fair d reasonable.
1 ?
Plaintiff
VERIFICATION
I verify that the statements made in the Complaint for Divorce are true and correct. I understand
that false statements made herein are subject to penalties of 18 Pa. C.S. Section 4904, relating to
unsworn falsification to authorities.
Plaintiff -
Date:
Print Name (Plaintiff, Pro Se)
Mailing Address: 801B Bridge St, New Cumberland, Pennsylvania, 17070
Phone: 717-817-6266
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in the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of.
Danielle R Miller ) Term, 2
V.
Plaintiff
Case Number: ' 3o?y
Jesse A Miller
Defendant
Affidavit of Verification
THE STATE OF: Pennsylvania
COUNTY OF: Cumberland
BEFORE ME, Danielle R Miller, the undersigned authority and the Plaintiff in the above referenced
case, on this day personally appeared who, being by me duly sworn, upon oath says:
My name is: Danielle R Miller
Social Security #: 282-82-1493
Driver's License/ State ID #: 26407905
My mailing address is:
801B Bridge St, New Cumberland, Pennsylvania, 17070
Phone: 717-817-6266
The facts contained within the foregoing Complaint for Divorce are true and correct to the best of my
knowledge, information, and belief, and that I am authorized to make this affidavit.
Date: ? X r<\o
?Printt Name (P intiff)
Signature (Plaintiff)
SWORN TO AND SUBSCRIBED BEFORE ME by the said
A, on this ?AAjt , a0 a t to
certify hich witness my hand and seal of office.
t•
&4k^
Notary Public, State of Pennsylvania
Notary Seal
My commission expires:
COMMONWCAL.TH OF PENNSYLVANIA
NOTARIAL SEAL
EEast ICIA A. BENDER, Notary Public
nnsoro 7wp., Cumberland County
ission Expi res September 19, 2011
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In the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of.
Danielle R Miller
Plaintiff
AND
Jesse A Miller
Defendant
Case Number 6 35-:;?q &--
Judge:
Affidavit of Non-Military Status
THE STATE OF: Pennsylvania
COUNTY OF: Cumberland
BEFORE ME, Danielle R Miller, the undersigned authority and the Plaintiff in the above referenced
case, on this day personally appeared who, being by me duly sworn, upon oath says:
My name is: Danielle R Miller
Social Security #: 282-82-1493
Driver's License/ State ID #: 26407905
My mailing address is:
801B Bridge St, New Cumberland, Pennsylvania, 17070
Phone: 717-817-6266
NOW COMES Danielle R Miller, who being first duly sworn deposes and says that to the best of my
knowledge, Jesse A Miller, the Defendant, is mentally competent, over the age of eighteen (18) years
old, and is not now, nor was at the date of the service of the Summons and Complaint for Divorce, a
member of any branch of the Armed Forces of the United States Military as defined by the Soldiers
and Sailors Civil Relief Act of 1940 as amended.
Date
Print Name (P mtiff)
_ Nn n
Signature (Plaintiff)
SWORN TO AND SUBSCRIBED BEFORE ME by the said
P) 013 _ F on this °Z1 , o00 4 to
certify hick witness my hand and seal of office. U
R
j6thtennsylvania
Notary Seal
My commission expires:
MMON AL.TH OF PENNSYLVANIA
NOTARIAL SEAL
CEast ATRICIA A. BENDER, Notary Public
Pennsboro Twp., Cumberland County
Commission Expires September 19, 2011
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In the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Danielle R Miller ) Term, 2
Plaintiff )
V. )
Case Number: 3g??C
Jesse A Miller )
Defendant )
COUNSELING NOTICE (Under PA. R.C.P. Rule
1920.45(a) (1)
The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where
a divorce is sought under any of the following grounds:
Section Indignities
3301(a) (6)
Section 3301 Irretrievable Breakdown
(c) Mutual Consent
Section 3301 Irretrievable Breakdown
(c) Two (2) Year Separation Where the Court Determines That There is
a Reasonable Prospect of Reconciliation
A list of qualified professionals is available for inspection in the office of the Appointments Clerk
of Family Court for Cumberland County or in the office of the Chief of the Domestic Relations
Branch of the Family Court of Philadelphia.
Date: c3-1 ?--
Print Name (Plaintiff)
Signature (Plaintiff)
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In the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Danielle R Miller
Plaintiff
V.
Jesse A Miller
Defendant
Term, 2
Case Number: ,2 - 390)7 &,j
COUNSELING NOTICE (Under PA. R.C.P. Rule
1920.45(a) (1)
The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where
a divorce is sought under any of the following grounds:
Section indignities
3301(a) (6)
Section 3301 Irretrievable Breakdown
(c) Mutual Consent
Irretrievable Breakdown
Section 3301 Two (2) year Separation Where the Court Determines That There is
(c) a Reasonable Prospect of Reconciliation
A list of qualified professionals is available for inspection in the office of the Appointments Clerk
of Family Court for Cumberland County or in the office of the Chief of the Domestic Relations
Branch of the Family Court of Philadelphia.
Date: Sul, ,2 7 ?- 6 G?a
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Print Name (Defendant)
A jo-fm n . I A .
nature (Defendant)
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In the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Danielle R Miller ) Case Number: O '03k??q
Plaintiff
V.
Judge:
Jesse A Miller
Defendant
Marital Settlement Agreement
This agreement is made on AL+1" (? , 900 , between
Danielle R Miller, the Plaintiff, with a socifil security number of 282-82-1493, who lives at 801B
Bridge St, New Cumberland, Pennsylvania, 17070 (home phone: 717-817-6266) and the county of
Cumberland and Jesse A Miller, the Defendant, with a social security number of 173-60-8869, who
lives at 5441 Pond Rd, Harrisburg, Pennsylvania, 17111 (home phone: 717-303-9802) and the county
of Dauphin.
The Plaintiff and Defendant may from time to time throughout this agreement, individually and
collectively, be referred to as "Party" or "Parties".
The Plaintiff is currently employed by Pinnacle Health, which is located at, 111 S Front St,
Harrisburg, Pennsylvania, 17101 with a telephone number of 717-782-3297.
The Defendant is currently employed by Belron US, which is located at, 5500 Paxton St, Harrisburg,
Pennsylvania, 17111 with a telephone number of 717-564-5469.
1. Recitals:
The parties are making this agreement with reference to the following facts:
The parties were married on June 18, 2005 in the city of Hershey, in the state of Pennsylvania,
and separated on or about, June 31, 2007.
As a result of serious disputes, conflict of personalities, and unique goals and differences, the
parties honestly believe that the marriage is irretrievably broken and that there is no possible
chance for reconciliation. For this reason each party desires to settle fully and finally all aspects
and rights, by this agreement, of the marital affairs including, but not limited to; Property and
Debt Distribution, The Marital Home, Retirement/Pension/Profit Sharing/40Ik Accounts, Spousal
Maintenance, and Income Tax Returns.
There are no children born or legally adopted of the marriage under the age of eighteen (18).
The parties each now intend by this agreement to settle fully and finally all of their respective
rights and obligations arising out of or related to the marriage that otherwise could be adjudicated in
the above captioned case number.
There is no other pending action filed by either party regarding the dissolution of the marriage.
The date of execution of this agreement is the day on which the agreement is signed by both
parties.
Any transfer of property, funds, debts and/or documents pursuant to the agreement shall be made
on the date of the execution of this agreement, if not already done so, unless otherwise specified in this
agreement.
The parties both agree to lead separate lives, and, except for the duties and obligations imposed
and assumed under this agreement, each shall be free from interference and control of the other as
fully as if he or she were single. The parties each agree not to molest, interfere with, or harass the
other.
2. Property and Debt Distribution:
As of December 1, 2007, the parties have each possessed his and her marital and non-marital
property and have been responsible for the marital and non-marital (separate) debt that will be
described below.
The parties agree that the following marital property shall be the sole and separate property of
Jesse A Miller, the Defendant, and Danielle R Miller, the Plaintiff transfers and quitclaims any interest
that she may have in this marital property to the Defendant:
House
The parties agree that the following marital property shall be the sole and separate property of
Danielle R Miller, the Plaintiff, and Jesse A Miller, the Defendant transfers and quitclaims any
interest that he may have in this marital property to the Plaintiff
None
The parties agree that Jesse A Miller, the Defendant, shall pay and indemnify and hold Danielle R
Miller, the Plaintiff, harmless from the following marital debts:
Mortgage of 60,000.00
The parties agree that Danielle R Miller, the Plaintiff, shall pay and indemnify and hold Jesse A
Miller, the Defendant, harmless from the following marital debts:
None
The parties agree that the following non-marital (separate) property shall be the sole and separate
property of Jesse A Miller, the Defendant, and Danielle R Miller, the Plaintiff transfers and
quitclaims any interest that she may have in this non-marital (separate) property to the Defendant:
None
The parties agree that the following non-marital (separate) property shall be the sole and separate
property of Danielle R Miller, the Plaintiff, and Jesse A Miller, the Defendant transfers and quitclaims
any interest that he may have in this non-marital (separate) property to the Plaintiff
None
The parties agree that Jesse A Miller, the Defendant, shall pay and indemnify and hold Danielle R
Miller, the Plaintiff, harmless from the following non-marital (separate) debts:
None
The parties agree that Danielle R Miller, the Plaintiff, shall pay and indemnify and hold Jesse A
Miller, the Defendant, harmless from the following non-marital (separate) debts:
None
The parties both hereby represent and warrant that as of the date of this agreement, they do not
possess any property or interests in property other than the items listed in this agreement; and that
the items set forth and listed in the agreement constitute full and complete disclosure.
In addition to the items listed in this agreement, if any undisclosed property or interests in
property is discovered subsequently, and a court of competent jurisdiction determines it to be
marital or community property of the parties, such discovery and determination shall not
invalidate this agreement but, the property or the interest in it shall at the election of the
discovering party (i) be divided equally or equitably in kind or (ii) be accounted for by the party
in possession who may pay to the discovering party a sum of money to offset an equal or
equitable portion.
The parties both hereby represent and warrant that except for the debts and obligations set forth
and listed above, each has not incurred any other outstanding debt or obligation on which the
other may become liable, nor has either party incurred any obligation that could henceforth be
enforced against any asset held or received pursuant to this agreement.
In the event that any outstanding debt or obligation of any kind has been incurred by either party,
other than those listed above (and is hereafter asserted against the other), the party actually
incurring the debt or obligation shall assume and be solely responsible for paying it and shall hold
the other party harmless from all claims with respect to the debts, obligations, and expenses with
respect to those debts.
In the event that the other party becomes a debtor in any bankruptcy or financial reorganization
proceeding of any kind while this agreement is in effect, that debtor party waives any and all
rights to any property held by the other party which is in fulfillment of this agreement. The debtor
party will also convey to the other party that the bankruptcy or financial reorganization
proceeding is going to take place.
The parties acknowledge and agree that the credit history established by them during their
marriage shall be deemed to have the credit history of both parties, not withstanding ordinary
practices of creditors and credit reporting agencies that may have reported such credit history in
the name of one party. Both parties agree to cooperate and execute any documents as may be
required to enable each other to provide to prospective creditors the full credit history of the
parties that was established during the marriage.
The parties each represent to the other that from the date of this agreement each party shall not
charge or incur or cause to be incurred any liability or obligations based on the credit or name of the
other. Each of the parties shall do whatever is necessary to close immediately all joint accounts.
The parties each forever waive any right to inherit from the other and the right to receive any
property on the death of the other, except as a beneficiary of any life insurance policy, by reason of a
will, codicil, or republication of will by the other party executed subsequent to the date of this
agreement.
The parties each waives all right to act as administrator of the other party's estate and all right to
request or petition for the appointment of any person to serve as such representative or to act as the
executor of the other's will, unless expressly named in a will, codicil, or republication of will by the
other party executed subsequent to the date of this agreement.
3. Marital Home:
There is a marital home of this marriage located at:
5441 Pond Rd, Harrisburg, Pennsylvania 17111,
with a legal description of: It is a townhouse located across from Central Dauphin school facing
the street.
The parties have agreed that this real estate will not be sold and the Defendant will remain as the
sole owner.
The Plaintiff recognizes that by acknowledging sole ownership to the Defendant, all rights to any
current and future equity invested or to be invested in the real estate is being forfeited.
This title shall be free of liens and encumbrances, except for the existing mortgage, which
Defendant assumes. Defendant agrees to indemnify and hold harmless the Plaintiff for any mortgage
payments, taxes, liability and expense incurred in connection with this real estate. Plaintiff waives any
and all rights or claims to any insurance policies held in connection with said real estate, or the
proceeds from any such insurance policies.
4. Retirement Accounts/Pensions/401ks/Profit Sharing Plans:
The parties each waive all claims, present and future to the other's pension benefits, retirement
funds, 401 k's, profit sharing plans and accounts of the like.
5. Spousal Maintenance:
After careful consideration of the circumstances and all the other terms of this agreement, the
parties agree to waive any rights or claims that he or she may have now or in the future to receive ant
rehabilitative or permanent spousal maintenance from the other party.
The parties both agree each will be responsible for his and her own health and medical insurance
coverage.
6. Income Tax Returns:
The parties agree that they will file joint federal, state and local tax returns for the calendar year
in which this agreement is made into effect.
The parties both agree that they will cooperate in the filing of any necessary tax returns and if any
tax refunds are due on jointly filed returns they shall be divided equally.
For each calendar year after the year this agreement is made into effect, each party shall file
separate federal, state and local income tax returns, in which each shall include and report all of his or
her separate income and shall pay all income taxes due.
The parties each agree to notify the other promptly in the event the IRS or any state or local
taxing authority provides notice of an audit, deficiency, refund, or the adjustment regarding a tax
return that was jointly filed or that should have been jointly filed. The party receiving such notice from
a taxing authority shall provide a copy of the notice to the other party within 20 days of receiving it.
The parties further agree to cooperate fully with the other in any claims for refunds or in
defending against any deficiencies that may be determined with respect to joint income tax returns
filed (or to be filed). This includes, without limitation, the making, executing, and filing of amended
income tax returns; applications for refunds, protests, and other instruments; and documents as may be
required. The costs and expenses for such will be divided equally between the parties.
7. Professional Fees and Costs:
The parties have not acquired any professional service fees which they desire to be recognized,
mentioned, or distributed by this agreement.
8. Advice of Counsel:
The parties each acknowledge that they have the legal right to representation by separate
attorneys. The parties each fully understand his and her rights and the contents of this agreement.
The parties each consider the terms of this agreement to be fair and reasonable and each party
accepts sole responsibility for any decisions, and potential repercussions of those decisions, which are
presented as part of this agreement.
9. Mutual Releases:
Each party hereby releases the other from any claim of action that either may have against the
other for any reason occurring prior to this agreement, whether that claim is founded in contract, tort,
or any other basis.
10. Governing Law:
The parties agree that this document is intended to be a full and an entire settlement and
agreement between them regarding the marital rights and obligations and that this agreement, and all
contents within and attached, shall be interpreted and governed by the. laws of the State of
Pennsylvania.
11. Entire Agreement:
This agreement constitutes the entire and full agreement between the parties. If any clause is held
unenforceable or found to be in any way non-executable, or if a court alters or holds unenforceable any
clause in this agreement, this shall in no way affect or alter the other clauses in the agreement, which
shall remain in full force.
No amendment or modification to this agreement or any judgment, decree or order based on it
shall be valid unless signed and agreed to by both parties or ordered by the court after a duly noticed
hearing.
12. Further Assurances:
The parties shall execute and deliver promptly on request any additional papers, documents, and
other assurances reasonably necessary in connection with the performance of the obligations set forth
in this agreement. In the event that either party fails or refuses to comply with the provisions of this
agreement, the failing party shall reimburse the other party for all loses and expenses including, but
not limited to, attorney's fees and all costs incurred as a result of such failure.
13. Captions and Interpretations:
Paragraph captions have been used throughout this agreement for convenience and reference only
and are not intended to be used in the construction or interpretation of this agreement or any of its
provisions. No provision of this agreement is to be interpreted for or against any party by virtue of the
fact that the provision was drafted by that party or that party's counsel.
14. Submission to Court for Incorporation:
This agreement has been drafted and executed with the intention that it be submitted by either
party to any court before which a Complaint for Divorce may be pending or initially filed for approval
by the court and for incorporation into a Decree of Divorce pursuant to Sections 4104(a)(1) and (3)
and 3323(b) of the Divorce Code.
15. Verification/Disclosure:
The parties both have reviewed this agreement cooperatively and each party has fully and
honestly disclosed to the other the extent of his or her assets, income, and financial situation, and
therefore enter into this agreement reliance thereupon.
Attached to this agreement is a completed Domestic Relations Income and Expense Statement for
each party to further present to each other and the court his and her current income, expenses, property
and debts.
16. Successions:
The parties each acknowledge that this agreement, and each provision of it, is expressly made
binding upon the heirs, assigns, executors, administrators, representatives and successors in the interest
of each party.
Signed and dated on q ?0o R
+in Name (De dant)
tY)
ature (Defendan
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Print Nam (Plaintiff)
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Signature (Plaintiff)
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Witness #1 Name
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Witness #1 Signature
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Witness #2 Name
Witness #2 Signature
State of tnAs (wr-
County of OWWJ?rtWPL
SWORN TO AND SUBSCRIBED BEFORE ME by the said
On JNN?I A , 20 0 q , before me, the undersigned, a Notary Public in and for said
State, personally appeared Jesse A Miller, the Defendant, known to me (or proved on the basis of
satisfactory evidence) to be the person whose name is subscribed to within the instrument and
acknowledged that he executed the same.
W' ess my hand and official seal.
A? 4 &'?
Notary Public
Notary Seal COMMONWEALTHOFPE"" VANIA
nn ? "'.ARIAL SEi
My commission expires: PATRIC ENDER, l
East Penns jro Twp., Cum 'V
YA)? ?- s 7:2ims Ser
State of eti nS "VI
County of J
SWORN TO AND SUBSCRIBED BEFORE ME by the said
On a , 2091 , before me, the undersigned, a Notary Public in and for said
State, p rsonally ppeared Danielle R Miller, the Plaintiff, known to me (or proved on the basis of
satisfactory evidence) to be the person whose name is subscribed to within the instrument and
acknowledged that she executed the same.
tress my hand and official seal.
Q?
Notary Public
Notary Seal
My commission expires: 4114,
COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
PATRICIA A. BENDER, Notary Public
East Pennsboro Twp., Cumberland County
My Commission Expires September 19, 20i 1
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In The Court Of Common Pleas of Cumberland County,
Pennsylvania
Danielle R Miller
(Plaintiff)
Term,2
vs.
Jesse A Miller
(Defendant)
Case Number: AXX?) -CeW4
Affidavit of Service
hereby depose and say that on this date, I personally
NAME
served the above-captioned Defendant with a Complaint in Divorce and Notice to Defend
and Claim Rights with Notice of Availability of Counseling, by personally handing the
same to him/her.
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
unworn falsification to authorities.
S a7,?
Dated: Signature:
C
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In The Court Of Common Pleas of Cumberland County,
Pennsylvania
Danielle R Miller
(Plaintiff)
vs.
Term,2
Jesse A Miller Case Number: AnQf*j `tY L(
(Defendant)
Acceptance of Service
I ?- 5S L VI _ , Defendant in the above-captioned action depose and say
NAME
that on this date I hereby accept service of the Complaint in Divorce and Notice to
Defend and Claim Rights with Notice of Availability of Counseling.
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.
Dated: JU/ a Signatu
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In the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Danielle R Miller ) Case Number:=06gq
Plaintiff
V.
Judge:
Jesse A Miller
Defendant
AFFIDAVIT OF CONSENT (Plaintiff)
THE STATE OF: Pennsylvania
COUNTY OF: Cumberland
1. A Complaint for Divorce under Section 3301 (c) of the Divorce Code was filed on
<?4"1 , SOS
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing the Complaint for Divorce.
3. I consent to the entry of the final Decree of Divorce after service of intention to request entry of the
Decree of Divorce.
I verify that the statements made in this affidavit are true and correct. I understand that false statements
here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to
authorities.
Date:
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Print Name (Plaintiff)
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Signature (Plaintiff)
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In the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Danielle R Miller ) Term, 2
Plaintiff
V.
Case Number o4LrB-n?'?}
Jesse A Miller
Defendant
AFFIDAVIT OF CONSENT (Defendant)
THE STATE OF: Pennsylvania
COUNTY OF: Dauphin
1. A Complaint for Divorce under Section 3301 (c) of the Divorce Code was filed on
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2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have
elapsed from the date of filing the Complaint for Divorce.
3. I consent to the entry of the final Decree of Divorce after service of intention to request entry of the
Decree of Divorce.
I verify that the statements made in this affidavit are true and correct. I understand that false statements
here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unworn falsification to
authorities.
Date: Jo-AU (W'ti 19, , "Loog
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ignature (Defendant)
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In the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Danielle R Miller ) Term, 2
Plaintiff
V.
Case Number: ADD8 W
Jesse A Miller
Defendant
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301 (c) OF THE DIVORCE CODE. (Plaintiff)
THE STATE OF: Pennsylvania
COUNTY OF: Cumberland
1. I consent to the entry of a final Decree of Divorce without notice.
2. 1 understand that I may lose rights concerning alimony, division of property, distribution of debts,
lawyer's fees, or expenses if I do not claim them before a Decree of Divorce is granted by the Court.
3.1 understand that I will not be divorced until a Decree of Divorce is entered by the Court and that a
copy of the Decree of Divorce 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
here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unworn falsification to
authorities.
Date: 1 af\ n , amck
7"', N" -?Z arc
Print Name (Plaintiff) `
Signature (Plaintiff)
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In the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of.
Danielle R Miller ) Term, 2
Plaintiff
V.
Jesse A Miller
Defendant
Case Number
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301 (c) OF THE DIVORCE CODE. (Defendant)
THE STATE OF: Pennsylvania
COUNTY OF: Dauphin
1. I consent to the entry of a final Decree of Divorce without notice.
2.1 understand that I may lose rights concerning alimony, division of property, distribution of debts,
lawyer's fees, or expenses if I do not claim them before a Decree of Divorce is granted by the Court.
3. I understand that I will not be divorced until a Decree of Divorce is entered by the Court and that a
copy of the Decree of Divorce 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
here-in are made subject to the penalties of 18 Pa C.S. Section 4904 relating to unsworn falsification to
authorities.
Date: JoJ1U04-1i )q ---6e- -? 'A;
il rmt Name ( efendant
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Signature (Defendant)
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In the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Danielle R Miller ) Term, 2
Plaintiff r )
V.
Case Number: do?6=0-694
Jesse A Miller )
Defendant )
COUNSELING NOTICE (Under PA. R.C.P. Rule
1920.45(a) (1)
The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where
a divorce is sought under any of the following grounds:
Section Indignities
3301(a) (6)
Section 3301 Irretrievable Breakdown
(c) Mutual Consent
Section 3301 Irretrievable Breakdown
(c) Two (2) Year Separation Where the Court Determines That There is
a Reasonable Prospect of Reconciliation
A list of qualified professionals is available for inspection in the office of the Appointments Clerk
of Family Court for Cumberland County or in the office of the Chief of the Domestic Relations
Branch of the Family Court o.f Philadelphia.
Date: J &-AU 2?` 1
/pr*ntName(Ue ndant)
ature (Defendant)
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In the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Danielle R Miller
Plaintiff
Term, 2
Case Number: ] s
COUNSELING NOTICE (Under PA. R.C.P. Rule
1920.45(a) (1)
The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where
a divorce is sought under any of the following grounds:
Section Indignities
3301(a) (6)
Section 3301 Irretrievable Breakdown
(c) Mutual Consent
Section 3301 Irretrievable Breakdown
(c} Two (2) Year Separation'Where the Court Determines That There is
a ReasonabieProsp`ect of Reconciliation
A list of qualified professionals is available for inspection in the office of the Appointments Clerk
of Family Court for Cumberland County or in the office of the Chief of the Domestic Relations
Branch of the Family Court of Philadelphia.
Date:
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Print Name (Plaintiff) Signature (Plaintiff)
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In the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Danielle R Miller ) Term, 2
Plaintiff
V.
Case Number: `T
Jesse A Miller
Defendant
Acknowledgement (Plaintiff)
THE STATE OF: Pennsylvania
COUNTY OF: Cumberland
On this day of 2ry-?before me, a Notary Public,
the undersigned officer, personally appeared Danielle R Miller, known to me to be the person whose
name is subscribed to this written instrument, and acknowledge that (s)he executed the same for the
purposes therein contained.
AComplaint for Divorce under Section 301 (c) of the Divorce Code was filed on
Juic, 011 ,
I, the Plaintiff, agree that the marriage of the Plaintiff and the Defendant is irretrievably broken and
nintey (90) days have elapsed from the date of the filing of the Complaint for Divorce. All information
contained within the attached documentation is true and correct to the best of my knowledge,
information and belief.
It is my desire to file with the Cumberland County Court of Common Pleas the attached Marital
Settlement Agreement and to be bound fully and completely by the terms and conditions as set forth
within said Marital Settlement Agreement documentation.
Date: JcaC1 1?
Print Name (Plaintiff)
Signature (Plaintiff)
SWORN T ANDS SCRIBED BEFORE ME by the saAit 0
?:' A K on this ? P'1 to
cerKy which witness y hand and seal of office.
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Notary Public, State of Pennsylvania
Notary Seal
MMONWEALTH OF PENNSYLVANIA
My commission expires: NOTARIAL SEAL
PATRICIA .ENDER, Notary Public
East Pennsboro Twp., Cumberland County
My Commission Expires September 19, 2011
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In the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Danielle R Miller ) Term, 2
Plaintiff )
V. )
Case Number: ATA 'Ong:304
Jesse A Miller
Defendant
Acknowledgement (Defendant)
THE STATE OF: Pennsylvania
COUNTY OF: Dauphin
On this r? day of ?0./kJ1yl1- , 2 OG q , before me, a Notary Public,
the undersigned officer, personally appeared Jesse A Miller, known to me to be the person whose
name is subscribed to this written instrument, and acknowledge that (s)he executed the same for the
purposes therein contained.
A Complaint for Divorce under Section 301 (c) of the Divorce Code was filed on
:5-o (1 e 7.7 , 2 00
I , the Defendant, agree that the marriage of the Plaintiff and the Defendant is irretrievably broken and
nintey (90) days have elapsed from the date of the filing of the Complaint for Divorce. All information
contained within the attached documentation is true and correct to the best of my knowledge,
information and belief.
It is my desire to file with the Cumberland County Court of Common Pleas the attached Marital
Settlement Agreement and to be bound fully and completely by the terms and conditions as set forth
within said Marital Settlement Agreement documentation.
Date: :5anU r-IC-")-60q_.
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Print Name (Defendant)
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Sig ature (Defendant)
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SWO)?T AND UBSCRIBED.BEFORE;MF by. the said
c bu+.:nci [U[i on this Iq UA°A to
cefYy which witness my hand and seal of office. U
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Notary Public, State of Pennsylvania
Notary Seal cote ON *w or PENNSYLVANIA
NOTARIAL. SEAT.
My commission expires: PATRICIA A. BENDER, Notary Public
East enns oro wp., Cumberland County
My Commission Expires September 19, 2011
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In the Court of Common Pleas, Cumberland County, Pennsylvania
In Re the Marriage of:
Danielle R Miller Term, 2
Plaintiff
V.
Case Number:
Jesse A Miller
Defendant
Praecipe to Transmit Record
Kindly Transmit the Record, together with the following information, the Court for entry of a Decree
of Divorce:
1. Ground for Divorce: irretrievable breakdown under Section 3301 (c) of the Divorce Code.
2. Date and Manner of Service of the Complaint for Divorce:
7Jm.-_A2, 2_CX)6 , by personal or O certified mail.
3. Date of execution of the Affidavit /Consent Waiver required by Section 3301 (c) of the Divorce
Code:
By Plaintiff: 2009
.
By Defendant: j rn kq -'2 Cock
4. Complete the appropriate paragraphs:
(a) Related claims pending...
None
(b) Claims withdrawn...
None
(c) Claims settled by agreement of the parties...
None
(d) State whether any written agreement is to be incorporated into the Divorce Decree. If yes,
attach a true and correct copy of the fully executed agreement to the proposed Decree that is
submitted herewith:
The parties have both signed a Marital Settlement Agreement resolving all of their issues
and wish to heave it incorporated into the Final Decree.
5. I certify that the Notice of Intent to File Praecipe to Transmit as required by Rule 1920.42(c) or (d)
was mailed on ?, _ 115 , 2 Oo , and a copy thereof is attached. I further certify that all other
documents required by Rule 1920.42(e) are enclosed herewith.
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Date: Arlr\ ignature (Plaintiff)
Mailing Address: 801B Bridge St, New Cumberland, Pennsylvania, 17070
Phone: 717-817-6266
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Danielle R Miller
V.
Jesse A Miller NO. r3 -- dac?
DIVORCE DECREE
AND NOW, Ssr»? . Z. it is ordered and decreed that
Danielle R Miller
plaintiff, and
Jesse A Miller , defendant, are divorced from the
bonds of matrimony.
Any existing spousal support order shall hereafter be deemed an order for
alimony pendente lite if any economic claims remain pending.
The court retains jurisdiction of any claims raised by the parties to this action
for which a final order has not yet been entered. Those claims are as follows: (if no
claims remain indicate "None.")
None
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By the Court,
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