HomeMy WebLinkAbout01-4747HARRISBURG, ~SYLVANIA 17101
DOLORES A. MILLER
Plaintiff
Vo
RONALD E. MILLER
Defendant
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COI/NTY, PENNA.
: NO. Or--Z/TV7
: CIVIL ACTION - LAW
: DIVORCE
NOTICE
YOU HA~-~ 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 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, includig 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 Court Administrator, 4th Floor, Cumberland County
Courthouse, Carlisle, Pennsylvania, 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF
PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANAVOLMENT
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 CAIn-NOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP:
Court Administrator
4th Floor
Cumberland County Courthouse
Carlisle, PA 17013
717.240.6200
DOLORES A. MILLER
Plaintiff
Vo
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNA.
through
Offices,
whose current
17319.
2. Defendant, Ronald E.
whose current address is 12 Louis
Pennsylvania, 17025.
CIVIL ACTION - LAW
DIVORCE
COMPLAINT
AND NOW, comes Plaintiff, Dolores A. Miller, by
her attorney, James W. Abraham, Esquire, Abraham
Harrisburg, Pennsylvania, and files the following:
DIVORCE PURSUANT TO SECTION 3301(c)
OF THE DIVORCE CODE
and
Law
Plaintiff, Dolores A. Miller, is an adult individual
address is 290 Hemlock Lane, Etters, Pennsylvania,
Miller, is an adult individual
Lane, Enola, Cumberland County,
3. Plaintiff and Defendant have been bona fide residents
of the Con~nonwealth of Pennsylvania for at least six (6) months
immediately prior to the filing of this Complaint.
4. Plaintiff and Defendant were married on April 7, 1978
in Enola, Pennsylvania.
5. There have been no prior actions of divorce or for
annulment between the parties which are active.
6. The marriage is irretrievably broken.
RONALD E. MILLER :
Defendant :
7. Plaintiff has been advised that counseling is
available and that Defendant may have the right to request that the
Court require the parties to participate in counseling.
8. Plaintiff and Defendant are not members of the Armed
Forces of the United States.
WRK~(EFORE, Plaintiff requests Your Honorable Court to
enter a decree in divorce dissolving the marriage.
COUNT II
DIVORCE PURSUANT T~) SECTION 3301(d)
OF~4EDIVORCE CODE
9. Plaintiff incorporates by reference paragraphs 1
through 8 hereto.
10. Plaintiff and Defendant have lived separate and apart
for a period of at least two (2) years as their date of final
separation was before August 1, 1999.
WR~RRFORE, Plaintiff requests Your Honorable Court to
enter a decree in divorce dissolving the marriage.
DATE: 8/9/01
Respectfully submitted:
James W. Abraham, Esq.
Abraham Law Offices
513 North Second St.
Harrisburg, PA 17101
(717) 232-7825
Attorney for Plaintiff
VERIFICATION
I, ~0I~(~ ~. ~'l)~k~, the undersigned, hereby
verify and confirm that I have reviewed the foregoing document and
the statements therein are true and correct to the best of my
knowledge, information and belief. I further understand that any
false statements made herein are subject to the penalties of 18
Pa.C.S.A. Section 4904, relating to unsworn falsification to
authorities.
CERTIFICATE OF SERVICE
I, James W. Abraham, Esquire, the undersigned, do hereby
certify that I have served a true and correct copy of the foregoing
document, by certified mail, on the date indicated below, to the
following person(s):
Ronald E. Miller
12 Louis Lane
Enola, PA 17025
DATE: 8/9/01
James W. Abraham, Esquire