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HomeMy WebLinkAbout09-8029Harry M. Baturin, Esquire BATURIN & BATURIN 2604 North Second Street Harrisburg, PA 17110 (717) 234-2427 (Attorney for the Plaintiff) JESSICA N. MILLER, Plaintiff VS. JONATHAN R. MILLER, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA NO. ? g z7n// : CIVIL ACTION - LAW : 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 in the Prothonotary's Office, Cumberland County, 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 BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 Telephone: (717) 249-3166 Harry M. Baturin, Esquire BATURIN & BATURIN 2604 North Second Street Harrisburg, PA 17110 (717) 234-2427 (Attorney for the Plaintiff) JESSICA N. MILLER, Plaintiff VS. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PA NO. O 9- $O z a e ??.-- JONATHAN R. MILLER, Defendant : CIVIL ACTION - LAW : IN DIVORCE COUNTI COMPLAINT UNDER SECTION 3301(C) AND 3301(D) OF THE DIVORCE CODE AND NOW, this 18th day of November 2009, comes the Plaintiff, Jessica Miller, by and through her attorney, Harry M. Baturin, Esquire, of the Law Offices of BATURIN & BATURIN, and respectfully represents the following: 1. The Plaintiff is JESSICA N. MILLER, an adult individual, sui juris, with a Social Security Number of 210-68-3216, and who currently resides at 30 Woodmyre Lane, Enola, Cumberland County, Pennsylvania, 17025. 2. The Defendant is JONATHAN R. MILLER, an adult individual, sui juris, whose Social Security Number is 185-68-8964, and who currently resides at 33 No Exit Lane, Mill Hall, Clinton County, Pennsylvania, 17751. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 6, 2007. 5. The Plaintiff and Defendant separated in November of 2008.. 6. There has been no prior action for divorce or annulment of the marriage between the parties hereto in this or any other jurisdiction. 7. Plaintiff avers that there are no children of the parties under eighteen (18) years of age. 8. The Plaintiff and Defendant are both citizens of the United States of America. 9. Neither the Plaintiff nor the Defendant is a member on active duty of the Armed Services of the United States of America nor any of its allies. 10. The Plaintiff avers that the grounds upon which this action is based is that the marriage is irretrievably broken. 11. Plaintiff has been advised of the availability of marriage counseling and that the Court maintains a list of marriage counselors in the Office of the Prothonotary, which list is available to the Plaintiff upon request. Being so advised, Plaintiff does not request that the Court require that the parties participate in counseling prior to a divorce decree being handed down by the Court. 12. Plaintiff requests the Court to enter a Decree In Divorce. WHEREFORE, Plaintiff requests the Court to enter a Decree in Divorce dissolving the marriage between the Plaintiff and Defendant and for such further relief as the Court may determine equitable and just. Respectfully submitted, BATURIN & BATURIN By: 'gy 'm &?"^- HARRY M. BATURIN, ESQUIRE (Attorney I.D. No. 83006) 717 N. Second Street Harrisburg, PA 17102 (717) 234-2427 Attorney for Plaintiff Dated: November 18, 2009 I VERIFY THAT THE STATEMENTS MADE IN THIS COMPLAINT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, BELIEF AND INFORMATION. I UNDERSTAND THAT FALSE STATEMENTS HEREIN ARE MADE SUBJECT TO THE PENALTIES OF 18 PA. C.S. 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. OF 4U#RxCW 2#09 Noy 10 PM 2-- 4 3 ?. 74*1