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HomeMy WebLinkAbout10-2304r RY 2010 APR -6 Ell I: S5 SHERRY J. MILLER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW ALLAN K. MILLER, : NO. !6 r ;22 CIVIL TERM Defendant : 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 Streets, 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. Cumberland County Bar Association 32 S. Bedford Street Carlisle, PA 17013 Phone: (717) 249-3166 4.3 S--zw -11L M eta sZ oy K' K Q;-' yo u ?d r r SHERRY J. MILLER, V. ALLAN K. MILLER, Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. IN DIVORCE CIVIL TERM COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Sherry J. Miller, who currently resides at 1367 Zimmerman Rd., Carlisle, Monroe Township, Cumberland County, Pennsylvania, 17015. 2. Defendant is Allan K. Miller, who currently resides at 1189 Boiling Springs Rd., Mechanicsburg, Monroe Twonship, Cumberland County, Pennsylvania, 17055. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on November 29, 1980, in Cumberland County, Pennsylvania. 5. Plaintiff and Defendant separated on or about March 26, 2010. 6. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 7. The marriage is irretrievably broken. 8. 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. r 9. Neither parry is now serving in the United Armed Forces, nor have ever served in the United States Armed Forces. 10. Plaintiff requests the Court to enter a Decree in Divorce. By: Paul Bradford Orr, Esquire Attorney for Plaintiff 50 E. High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court ID # 71786 VERIFICATION I verify that the statements made in the foregoing Divorce Complaint 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: Sherry J. Mil "Vtltionef Y" ~'~L.~I_ ,= T=` i-, , ~~~'",~G~~Y .. 110 J!~~ -7 ~ ` :~~ :t1 Cli~,~ - ;... SHERRY J. MILLER, ~E1,, ~.~v~,, ~,,~ P~ainti~f VS. ALLAN K. MILLER, Defendant '~ 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA NO.. ~! /G °Z 3D CIVIL ACTION -LAW IN DIVORCE ACCEPTANCE OF SERVICE I, Paul Bradford Orr, Esquire, Attorney for the Plaintiff, Sherry J. Miller, do hereby accept service of the true and correct clocked copy of DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT IN DIVORCE WITH COUNTERCLAIM and cover letter by mail at 50 E. High Street, Carlisle, PA 17013 on \ J U (, ~ (~ , 2010 at Date: ~ I ~ D P.M. aul Bradford Orr, Esquire Attorney for the Plaintiff, Sherry J. Miller ~~~ ~fEa `~~ L i,c Ti4~ F . , ., - . , .. 'rv~,c~y SHERRY J. ALLAN K. 201 Q ,;~! ~' t~l`i 8~ i ; C~'~~~:.-.~: a :.ru~f1Y ~~;~,j;~~}Y~. ~r~'d» IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA VS. NO 1o-2~+ ;, CIVIL ACTION -LAW Defendant IN DIVORCE AFFIDAVIT OF SERVICE onall f 2010 ~~~d hi AND N pers y ay o s -~ W, t appeared Jane .Alexander, Esquire who swe ccording to la , that a true and correct copy of a clocke copy of Defendant's Answe t Plaintiffs Complaint in Divorce and Counterclaim w caused to be served by certified mail with return receipt r~ues~d upon the said, c ~ =~-~ .-,`- ~_ w~ Paul B - _ _ , ~-~~ r- y `-t' ~ ''- ord Orr, Esquire On be r F of Sherry J. Miller ~ ~ , ~? 50 E. Hi Street `~ ~- G, ,''' Carlisle, A 17013 on June 28, 201 by leaving the same at the Dillsburg Post Office with postage pre-paid thereon as evide ced by the mailing receipt and return receipt hereto attached and made a part hereof. M. Alexand~f squire A rney LD. #073 1 S. Baltimore Street illsburg, PA 17019-0421 717) 432-4514 SHERRY J. ALLAN K. IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 1o-2.30!+ ;, CIVIL ACTION -LAW Defendant IN DIVORCE PROOF O F SER VICE ~ ,. o m _ .~ O Fdetage $ ~>'' j Ci ~ ~ , '9 O Certified Fee f Poetrn , G ~ Retum Receipt Fee (EndoraemeM Required) Q Were O Z O ResUbted QelNery Fee ~ ~ ~ p (Endorsement Required) ~ N Teel Poste9e & Fees $ ~b • ~$ P S •.~ ( `° °~~ QRAb~f~~ oR.(~ ) ~ - --------- ~~f~t:~:.- 50 ~ tip b+~ - - - sT . --- ~ ~.~: -------- ~ ~• Q~ - ~ 713 ^ laerrt 4 ft fawns t r ~ and s, IY.o conipi.l. Rw~b'k~and D~NrNY Y dw~d. ~ ~ G ~k X ^ Print name and addn~ss on tha rwwaa Mc~Nw .e so lhat oan ne0a'n. the Band to you. py (mod wry C• d or~r Attaoh oard m the back of tha ntail~fsce, ~~ ~ Q '~ or on trait fi apaos psm~ts. D. a dMwry acai.a aMlMw~t+wm . ~t .orb 4! Artldrr b ~ M 1rE8. ~ dMwry addnN» bdDWC O (rq '+. p~~ Rr~fvRi~oRR ~S Q ,'~ So ~ t~ ~a ST, CpRu L ~~ ~ a :a.~.,ya. "` ~~~' ~~d13 ~ 0 ,~ " o a~,M..d f~.ii ~ ~~~ orr. ~'~' lnanew 7pp6 3230 pOpO p83p 1933 P3 Fcrm 11 Irlwn~r i104 tal1~~ IIMrs 1n.*t ,a~e~aa~~ao' Sworn and me this before day of 2010. Note 1 Seal Eric D. Witme ,Notary Public CARWt TWD. York County OF CUM 1David 1n. Buell 8 Renee IG Simpson 2 �.. Prothonotary st Deputy Prothonotary J Z L J J V �irkS. Sohonage, ESQ Irene E. Morrow Solicitor 7750 2nd Deputy Prothonotary Off ce of the Prothonotary Cum6erland County, Pennsylvania /p - 22cW CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE-THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 o Carlisle, PA. 17013 • (717)240-6195 • cEa.,(717)240-6573