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HomeMy WebLinkAbout09-0957CHANCE MINER, v. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA MELANIE LYNN MINER, Defendant NO. Oq, 957 ?l Vi l {'fT1 CIVIL ACTION - DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. If yu 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 in 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 of your children. When the ground for 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 Cumberland County, 1 Courthouse Square, 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 Lawyer Referral Service 32 South Bedford Street Carlisle, Pa 17013 (717) 249-2663 CHANCE MINER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. MELANIE LYNN MINER, CIVIL ACTION - DIVORCE Defendant : COMPLAINT IN DIVORCE 1. Plaintiff is Chance Miner who currently resides at 122 Chark Street, Lemoyne, Pennsylvania, Cumberland County. 2. Defendant is Melanie Lynn Miner, who currently resides at 5510 Silver Creek Drive, Mechanicsburg, Pennsylvania, Cumberland County. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of the Complaint. 4. The Plaintiff and Defendant were married on October 6, 2007, in Mechanicsburg, Pennsylvania. 5. There are no children born of this marriage. 6. Neither Plaintiff nor Defendant is in the military or naval service of United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and its amendments. 7. There have been no prior actions of divorce or for annulment between parties. 8. The marriage is irretrievably broken. 9. All matters of property have been resolved between the parties. 10. 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. 11. Plaintiff requests the court to enter a Decree of Divorce divorcing Plaintiff and Defendant. WHEREFORE, Plaintiff requests that this Court enter a Decree in Divorce permanently severing the matrimonial bonds between Plaintiff and Defendant and other such other Orders as are just and appropriate. Y 875 Market Street Lemoyne, PA 17043 (717) 761-1274 Date: February 1, 2009 Attorney for Plaintiff Respect ly submitted SUSAN K. P KFO ,ESQ. Attorne ID No. 93 VERIFICATION I, Chance Miner, verify that the statements made in the foregoing COMPLAINT in DIVORCE are true and correct to the best of my knowledge, information, and belief. 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: .4?- S 0 HANCE MINER CHANCE MINER, v. Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. Cr`J - 1 7 CIVIL ACTION - DIVORCE MELANIE LYNN MINER, Defendant ACKNOWLEDGEMENT OF SERVICE I, MELANIE LYNN MINER, hereby certify that on the date of my signature below I received service of a Complaint in Divorce in the above captioned matter. I hereby waive any irregularity in service. I hereby state that the above is a true and correct statement. February Ir, 2009 MELANIE LYNN MINER CHANCE MINER, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V : No MELANIE LYNN MINER, DIVORCE Defendant Certificate of Service I, Susan K. Pickford, Esquire, do hereby certify that I served a true and correct copy of the foregoing Complaint in Divorce upon the Defendant by delivering same to her on the date and at the location and in the manner indicated below. Melanie Lynn Miner 5510 Silver Creek Drive Mechanicsburg, PA 17055 (Acknowledgement of Service attached) Date: February 17, 2009 Sifsan K. Pickfoffl, E 875 Market Street Lemoyne, PA 17043 (717)761-1274 ID# 43093 ('? ?? r') rv ?,' l:?J 1..:1' ...?..j -. ? ' C° ? Y + » ? - 1 - ?? `? ?? ? w'} `a ? ???,} ?:? - ? t j - ??? ?/? r.? - c..? r { .. ' ?i " 4 ?? CHANCE MINER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. &,91 gs7 MELANIE LYNN MINER, CIVIL ACTION - DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on 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. §4904 relating to unsworn falsification to authorities. Date: 0 r CHANCE MINER FILEC-CYFICE OF THE FFOTF" ONOTARY 2009 JUN 15 PM 1: 2 7 cum b, PENNSYLVANIA CHANGE MINER, v. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA MELANIE LYNN MINER, Defendant NO. 0 9r 9S7 CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND §3301(d) 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 aad 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: I&V CHANCE MINER FILED-Cc IGE OF I P OTH( AFPX 200 JUN 15 PM 1: 2 7 .::., , , to .it-lluN? CHANCE MINER, v. NO. a P- 9,57 MELANIE LYNN MINER, CIVIL ACTION - DIVORCE Defendant AFFIDAVIT OF CONSENT 1. A conplaint in divorce under §3301(c) of the Divorce Code was filed on -?11710f 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. §4904 relating to unworn falsification to authorities. Date: moo? 0 MELANIE LYA& MINER IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA BLED-OFFICE OF THE PROTHNOTAf Y 2009 JUN 15 PH 1'. 2 3 CuMbl-.k UN PD IiiW2 INIV. CHANCE MINER, v. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA MELANIE LYNN MINER, Defendant NO. 0 y'- fs-7 CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) AND §3301(d) 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: A?-Lnq&AA MELANIE LYNW MINER FILEI~,Dt=+"k CE OF THE PPOTHONOTAf 2009 JUN 15 PIM 1: 27 CULT ?4-. ?•I'w.,i I r(..1 ?.J ??'?? f a PENN,YINANA CHANCE MINER, v. IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA NO. 09- ,95-7 MELANIE LYNN MINER, Defendant To the Prothonotary: CIVIL ACTION - DIVORCE PRAECIPE TO TRANSMIT RECORD Transmit the record, together with the following information, to the court for entry of a decree: 1. Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: February .; , 2009, Acknowledgement of Service (see attachment to Complaint) 3. Execution of the affidavit of c nsent required by §3301(c) of th Div rce Code were signed by Plaintiff , by Defendant 4. All claims raised have been resolved by Marital Settlement Agreement. 5. (a)Waiver of Notice for Plaintiff was filed with the prothonotary on / 0 . (b) Waiver of Notice for Defendant was filed with the prothonotary on usan K. Pickfo sq. Attorney for P aintiff 875 Market Street Suite 200 Lemoyne, PA 17043 717-761-5698 ID # 43093 RLED-0,1-FICE OF THE f ` TFONOTA.RY 2Q09 JUN J 5 PH 1: 2 7 F'FNNSAV' NIA IN THE COURT OF COMMON KEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CHANCE MINER V. MELANIE LYNN MINER NO. 0 9 - 977 DIVORCE DECREE AND NOW, -T&Lb` 112 vo , it is ordered and decreed that CHANCE MINER plaintiff, and MELANIE LYNN MINER bonds of matrimony. defendant, are divorced from the 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 Qu+hc rruirf ?.} ` ? ,, y a??j ?? ? ?