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Home My WebLink About01-0650IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOELLE L. MILLER, Plaintiff JEFFREY S. MILLER, Defendant : No. Ot- 6. S't3 _- : IN DIVORCE ._ Civil Term NOTICE TO DEFEND AND CLAIM RIGHTS YOU HA VE BEENSUED 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 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, Cumberland County Courthouse, 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 Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Le han demandado a usted a la corte. Si usted quiere defenderse en contra estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas o sus objeciones a las demandas en contra suya. Se has avisado que si usted no se defienda, la corte tomara medidas y puede entrar una orden contra usted sin previo aviso o notificacion y pot cualquier quej a o alivio que es pedido en la peticion do demanda. USTED PUEDE PERI)ER D1NERO O PROPIENDADES O OTROS DERECHOS IMPORTANTES PARA USTED. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO TIENE O CONOCES UN ABOGADO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABA JO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 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 72 hours prior to any hearing or business before the Court. You must attend the scheduled Conference or Hearing. Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOELLE L. MILLER, Plaintiff JEFFREY S. MILLER, Defendant :No. 6/- &SD : IN DIVORCE Civil Term COUNT I COMPLAINT UNDER SECTION 3301(c) OF THE DIVORCE CODE AND NOW comes JOELLE L. MILLER, by and through her attorney, Maryann Murphy, Esquire of MidPenn Legal Services, who respectfully avers as follows: 1. Plaintiff is JOELLE L. MILLER whose currently resides at an undisclosed location. 2. Defendant is JEFFREY S. MILLER whose current address is 102 Limestone Drive, Camp Hill, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 27, 1997 in Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or for annulment between the parties. 6. Defendant is not a member of the Army Forces of the United States of America or any of its Allies. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being handed down by the Court. 9. Plaintiff requests this Court to enter a Decree in Divorce from the bonds of matrimony. COUNT II CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY UNDER SECTION 3502 OF THE DIVORCE CODE 10. Plaintiff hereby incorporates by reference all of the averments contained in Count I of this Complaint. 11. Plaintiff and Defendant are the owners of motor vehicles, retirement benefits and other personal property acquired during the marriage which are subject to equitable distribution by this Court. 12. Plaintiff and Defendant have been unable to agree as to an equitable division of said property as of the date of the filing of this Complaint. 13. Plaintiff requests this Court to equitably distribute the parties' marital property. W~EREFORE, Plaintiff requests this Honorable Court to enter a Decree: dissolving the marriage between the Plaintiff and Defendant; and equitably distributing all property owned by the parties hereto; and for such further relief as the Court may determine to be equitable and just. Respectfully submitted, MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaintiff AFFIDAVIT I, JOELLE L, MILLER, verify that the statements made in the foregoing Complaint in Divorce are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. OELLE L. MILLER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOELLE L. MILLER, Plaintiff JEFFREY S. MILLER, Defendant : No. : : : IN DIVORCE : Civil Term CERTIFICATE OF SERVICE I, Maryann Murphy, Esquire, do hereby certify that a true and correct copy of the within Divorce Complaint was mailed to the Defendant, JEFFREY S. MILLER, by first class U.S. mail, postage pre-paid, certified/restricted delivery, addressed as follows: Jeffrey S. Miller 102 Limestone Drive Camp Hill, PA 17011 Respectfully submitted, Maryann N~urphy, MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL ACTION - LAW JOELLE L. MILLER, : Plaintiff : :NO. JEFFREY S. MILLER, Defendam IN DIVORCE Civil Term PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow, JOELLE L. MILLER, Plaintiff, to proceed in forma pauperis. I, Maryann Murphy, Esquire, of MidPenn Legal Services, attorney for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal services to the party. The party's affidavit showing inability to pay the costs of litigation is attached hereto. MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 I.D. # 61900 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOELLE L. MILLER, Plaintiff JEFFREY S. MILLER, Defendant : No. 2001-650 Civil Term _. .. : IN DIVORCE AFFIDAVIT OF SERVICE I, Maryann Murphy, Esquire, depose and say: 1. That I am an adult individual residing in Cumberland County, Pennsylvania. 2. That on February 2, 2001, I sent by U.S. first class mail, postage pre-paid, certified/restricted delivery, number 7000 0600 0025 1595 2600, a 3301(c) Complaint in Divorce to the Defendant, JEFFREY S. MILLER, at the following address: Jeffrey S. Miller 102 Limestone Drive Camp Hill, PA 17011 3. That on February 5, 2001, the Defendant was served with the Complaint in ~ a600 0025 1595 2600, which Complete items 1, 2, atld 3. Also Complete itel~l, 4 if Restricted Defivery is desired, Print your name and address on the reverse so ~l~at we can return the card to you. AttaCh this card to the back of the maiJpiece, or o1,1 th.e front if space permits. Arti9le Address6d to: ticle Numar (Co~y ~m semice la~0 =rm 3811, July 1999 JOELLE L. MILLER, Plaintiff V. JEFFREY S. MILLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : : NO. o / - Z. £-~ Civil Term : : IN DIVORCE : AFFIDAVIT IN SUPPORT OF PETITION FOR LEAVE TO PROCEED IN FORMA PAUPERIS 1. I am JOELLE L. MILLER, the Plaintiff in the above matter and because of my financial condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action or proceeding. 2. I am unable to obtain funds from anyone, including my family and associates, to pay the costs of litigation. 3. I represent that the information below relating to my ability to pay the fees and costs is true and correct. (a) Name: JOELLE L. MILLER Address: undisclosed location - PFA in effect b) Social Security Number: 200-62-9920 If you are presently employed, state N/A Employer: N/A Address: N/A Salary or wages per month: N/A Type of work: N/A If you are presently unemployed, state Date of last employment: April of 1997 Salary or wages per month: approximately Type of work: Sales $2.500.00 gross (commission only) (c) Other income within the past twelve months Business or profession: -0- Other self-employment: -0- Interest: -0- Dividends: -0- Pension and annuities: -0- Social Security benefits: -0- Support payments: -0- Disability payments: -0- Unemployment compensation and supplemental benefits: -0- Workman's compensation: -0- Public Assistance: Other: (d) Other contributions to household support (Wife)(Husband) Name: N/A If your (husband) (wife) is employed, state Employer: N/A Approximately $200.00 per month Salary or wages per month: N/A Type of work: N/A Contributions from children: -0- (e) Property owned Cash: $3.00 Checking Account: Savings Account: -0- Certificates of Deposit: -0- Real Estate (including home): N/A Motor vehicle: Make Dodge Ram Van Cost $3,700.00 Stocks; bonds: -0- Other: -0- (f) Debts and obligations Mortgage: -0- Rent: -0- Loans: approximate balance $2,000.00 Year 1993 Amount owed -0- Monthly Expenses: currently living with friends, waiting for HUD housing, no income left at the end of the month, owe money to friends towards utilities, food and rent (g) Persons dependent upon you for support (Wife) (Husband) Name: N/A Children, if any: not living with me at this time Name: Robert Age: 13 years Name: Lacev Age: 9 years 4. I understand that I have a continuing obligation to inform the court of improvement in my financial circumstances which would permit me to pay the costs incurred herein. 5. 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: E L. MILLER