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HomeMy WebLinkAbout01-1862SHELBY M. MILLER VS. MICHAEL A. MILLER Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. CIVIL ACTION -- LAW 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 L1ST OF MARRIAGE COUNSELORS IS AVAILABLE IN THE OFFICE OF THE PROTHONOTARY AT THE CUMBERLAND COUNTY COURTHOUSE, 1 COURTHOUSE SQUARE, CARLISLE, PA 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT 1S 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 REFERl~:AL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 SHELBY M. MILLER VS. MICHAEL A. MILLER Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -- LAW DIVORCE COMPLAINT UNDER §3301(c) or §3301(d) OF THE DIVORCE CODE 1. The plaintiff is SHELBY M. MILLER, who currently resides at 607 Erford Road, Camp Hill, Cumberland County, PA 17011, since December 1999. 2. The defendant is MICHAEL A. MILLER residing at an ua~known address believed to be in Cumberland County. 3. There are no children of the parties. 4. SHELBY M. MILLER, Plaintiff, and MICHAEL A. MILLER, Defendant, have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 5. The Plaintiff and Defendant were married June 30, 2000 at Mechanicsburg, Cumberland County, Pennsylvania. 6. There have been no prior actions of divorce or annulment between the parties. 7. Neither party is presently a member of the Armed Forces on active duty. 8. The parties have entered into a written agreement as to alLimony, counsel fees, costs, and CRYSTAL MYERS, Plaintiff V. ROBERT MYERS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA : : NO. 2001-1921 CIVIL TERM : : CIVIL ACTION - LAW : : IN CUSTODY ORDER OF COURT AND NOW, this 18TM day of April, 2001, the Conciliator being notified that the parties have signed a Custody Stipulation in the above matter, the Conciliator hereby relinquishes jurisdiction in this matter. FOR THE COURT, erney, Esquire, Custod~oncil'at 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA SHELBY M. MILLER, Plaintiff MICHAEL A. MILLER, Defendant VS. NO. 01-1862 Civil Term CIVIL ACTION - - DIVORCE RETURN OF SERVICE ON the 17th day of April, 2001, I, RUSSELL S. MOODY, JR., of 125 Stone Jug Road, Lewisberry, PA 17339, served the Complaint in Divorce on the Defendant, Michael A. Miller, at 2300 Linglestown Road, Harrisburg, Pennsylvania, at 2:00 o'clock P.M. by hand delivery. I verify that the statements in this Return of Service are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S.A. Section 4904, relating to nnswom falsification to authorities. l~ssell S. Moody, Jr. SHELBY M. MILLER VS. MICHAEL A. MILLER Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 01-1862 ,Civil Term CIVIL ACTION -- LAW DIVORCE AFFIDAVIT OF CONSENT_ 1. A complaint in Divorce under §3301(c) of the Diwarce Code was filed on March 29, 2001. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. SHELBY Mf MILLER.. ' Date Plaintiff SHELBY M. MILLER VS. MICHAEL A. MILLER Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, ,ENNSYLVANIA ~o. 01-1862 Civil Term CIVIL ACTION -- LAW DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c~ OF THE DIVORCE CODE 1. 1 consent to the entry of a final decree of divorce without notice. 2. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses ifI 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. 1 understand that false statements made herein are subject to the penalties of 18 Pa~ C.S. {}4904 relating to unswom falsification to authorities. Date SHELBY 1~. MILLER Plaintiff SHELBY M. MILLER VSo MICHAEL A. MILLER Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 01-1862, Civil Term CIVIL ACTION -- LAW DIVORCE 2001. AFFIDAVIT OF CONSENT_ 1. A complaint in Divorce under §3301(c) of the Diw)rce Code was filed on March 29, 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 afier service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are tree and correct. I understand that false statements made herein are subject to the penalties of' 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date MICHAEL A. MILLER Defendant SHELBY M. MILLER VS. MICHAEL A. MILLER Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 01-1862 Civil Term CIVIL ACTION -- LAW DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce withe,ut notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees, or expenses ill 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 a~er it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. MICHAEL M. MILLER Defendant SHELBY M. MILLER VS. MICHAEL A. MILLER Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 01-1862 Civil Term CIVIL ACTION -- LAW DIVORCE SOCIAL SECURITY INFORMATION SHEET PURSUANT TO 23 Pa.C.S.A. SECTION 4304.1(a)(3) ALI~r DIVORCES MUST INCLUDE THE PARTIES SOCIAL SECURITY NUMBER. PLEASE FILL IN THE APPROPRIATE INFORMATION AND RETURN TO THE PROTHONOTARY'S OFFICE. DATE: DOCKET NO. November 1,2001 01-1862 Civil Term PLAINTIFF SS NO. NAME DEFENDANT SS NO. NAME 182-60-8615 SHELBY M. MILLER 196-58-9478 MICHAEL A. MILLER SHELBY M. MILLER VS. MICHAEL A. MILLER Plaintiff Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 01-1862 Civil Term CIVIL ACTION -- LAW DIVORCE PRAECIPE TO TRANSMIT THE RECORB TO THE PROTHONOTARY Transmit the record, together with the following infomaation, to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under §3301 (c) of the Divorce Code. 2. Date and manner of service of the complaint: Persor~al service by constable on the 17th day of April, 2001. Said Return of Service was filed with the court on May 7, 2001. 3. Complete either paragraph (a) or (b) (a) Date of execution of the Affidavit of Consent required by §3301(c) of the Divorce Code: by the Plaintiff: October 4, 2001; by the Defendant: October 14, 2001. (b)(1)Date of execution of the affidavit required by §3301 (d) of the Divorce Code: (2) Date of filing and service of the Affidavit upon the respondent: 4. Related claims pending: There are no related claims pending. Date: 5. Complete either (a) or (b) (a) Date and manner of service of the notice of intention to file praecipe to transmit the record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in §3301(c) wasfiled: October 9, 2001. Date efendant s Wmver of Notme in §3301(c)wasfiled: October 23, 2001. 6. Plaintiff's Social Security Number is 182-60-8615. 7. Defendant's Social Security Number is 196-58-9478. Respectfully submitted, WILEY, LENOX, COLGAN & MARZZACCO, P.C. Attorney II) No. 77944 Attorney fe,r Plaintiff //-/ 1 South BaMmore Street Dillsburg, PA 17019 (717) 432-9666 SHELBY M. MILLER Plaintiff VERSUS MICHAEL A. MILLER Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. NO. 01-1862 Civil Term DECREE 1N DIVORCE AND NOW, DECREED THAT SHELBY M. MILLER , PLAINTIFF, AND MICHAEL A. MILLER ,DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; ATTEST: PROTHONOTARY