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Home My WebLink About04-5203KEV1N ROY MILLER, Plaintiff, V. SALLY ANN MILLER, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you w/sh to defend against the claims set forth in the foregoing 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 fights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the ma~iage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Office of the Prothonotary Cumberland County Court House Carlisle, Pennsylvania 17013 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. 1~ 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. Court Administrator, Fourth Floor Cumberland County Court House Carlisle, Permsylvania 17013 Telephone: (717) 240-6200 KEVIN ROY MILLER, Plaintiff, SALLY ANN MILLER, Defendant. 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. - X'O,,a3 CIVIL ACTION - DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Kevin Roy Miller, an adult individual who resides at 302 Orrs Bridge Road, Camp Hill, Cumberland County, Pennsylvania, 17011. 2. Defendant is Sally Ann Miller, an adult individual who resides at 2016 Water Street, Lebanon, Lebanon County, Pennsylvania, 17046. 3. Both the Plaintiff and the Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on June 30, 1995 in Germany while members of the United States Armed Forces. 5. There have been no prior actions in divome or annulment between the parties. 6. The Defendant is not a member of the armed forces of the United States or any of its allies. 7. The Plaintiffavers that the marriage is irretrievably broken. 8. Plaintiffhas been advised that counseling is available and that Plaintiffmay have the right to request that the Court require the parties to participate in counseling. The Plaintiffdoes not desire counseling. 9. Plaintiff avers that there are no children of the parties under the age of 18. 10. Plaintiff requests the Court to enter a Decree of Divorce. Date: CALDWELL & KEARNS ~1~2~. ~co, Esquire I. fl~9804 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 Attorney for Plaintiff, Kevin Roy Miller 04-801/ 2 VERIFICATION I, Kevin Roy Miller, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 4904, relating to unswom falsification to authorities. KEV1N ROY MILLER, Plaintiff, SALLY ANN MILLER, Defendant. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACT1ON DIVORCE ACCEPTANCE OF SERVICE I do hereby accept service of and acknowledge, receipt of a certified copy of the Complaint Divorce in the above case. Date: Sally Atfn Miller KEV1N ROY MILLER, · Plaintiff · SALLY ANN MILLER, · Defendant · IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 04-5203 CIVIL TERM CIVIL ACTION - DIVORCE JOINT PRAECIPE TO AMEND CAPTION The parties jointly agree to amend the caption in the above referenced matter so that the Defendant's name is Sally Anne Miller. By: ~rffomey ID # 69804 3631 North Front Street Harrisburg, PA 17110 (717) 232-7661 Attorney for Plaintiff CERTIFICATE OF SERVICE served a copy of the within document on the following by depositing a tree and correct copy of the same in the U.S. Mails at Harrisburg, Pennsylvania, postage prepaid, addressed to: Sally Anne Miller 2016 Water Street Lebanon, PA 17046 CALDWELL & KEARNS KEVIN ROY MILLER, Plaintiff, IN THE COURT OF COMMON PLES CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-5203 SALLY ANNE MILLER, Defendant. CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(c) OF THE DIVORCE CODE I. A Complaint in Divorce under 3301(c) of the Divorce Code was filed on October 18,2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 'without notice. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. 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 immediatel.y after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true ,md 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. ~.; ~~~~ Kevin Roy Mille, Plamtiff Dated: 0/ /; '1 /z..O{! 5 f { SSN# 220-50-6634 04-801/83441 n ;;..::: f"'...) C.::::~' ~~,J'\ ,-;:- ~" '~ - (." -;'l _1;: (",~) -> - KEVIN ROY MILLER, Plaintiff, IN THE COURT OF COMMON PLES CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-5203 SALLY ANNE MILLER, Defendant. CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A mVORCE DECREE UNDER 1$ 3301(c) OF THE DiVORCE CODE 1. A Complaint in Divorce under 3301(c) of the Divorce Code was filed on October 18, 2004. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety 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 without notice. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! do not claim them before a divorce is granted. 5. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy ofthe decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are tme and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 94904 relating to unsworn falsification to authorities. 11'/9/0.5- / '"' /'1 .~,1 (.. ) , " < " ;" , , '/ t' .,' fL^ Sally A e iller, Defendlrrrt-.. , , SSN#iJd.-/ - S-L/ - 1(j??! Dated: 04.801/83442 ,-.' c.~:\ ;;';~, '~ ,:,.1" <c.:J -- ..-;;\ :::1:. {~~:) -- -" - KEVIN ROY MILLER, Plaintiff, IN THE COURT OF COMMON PLES CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 04-5203 SALLY ANNE MILLER, Defendant. CIVIL ACTION - LAW IN DIVORCE PRAECIPE TO TRANSMIT m:CORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Grounds for divorce: Mutual consent that marria.ge is broken under Section 3301 (c) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of Service filed Octcber 28, 2004. 3. Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by Plaintiff, January 19, 2005; by Defendant, January 19, 2005 4. Related claims pending: None. 5. Date Plaintiffs Waiver of Notice was filed with the Prothonotary: January 3 1,2005. Date Defendant's Waiver of Notice was filed with the Prothonotary: January 3 1,2005. 6. Plaintiff's Social Security number: 220-50-6634 Defendant's Social Security number: 021-54-9674 Respectfully submitted, ;)./;;/05' /--7 Br/ / ou A eyLD.#69804 aldwell & Kearns, P.C. 3631 North Front Street Harrisburg, PA 17110-1533 (717) 232-7661 Attorney for Plaintiff, Kevin Roy Miller -' ~- Date: 04-801/83445 " ~:\ .....;\ , Co - ------ ,.,:+: Of:+::+::+: + . . . . . . . . . . . . . . . . :+::+:Of:+: "':+::+:+:+:Of:+::+::+:++Of+:+:+:+:++++:+::+:+:+:+++++++~:+:++++++:+::+::+:++:+:+++:+:++++++++++~ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , , . , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , , :+:+:+:+:+:+:+:+:+:+:+:+:+::+:+++++++:+:+++:+:+++++++++++:+:+++++++++++++++++++++++~ .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY KEVIN ROY MILLER PENNA. STATE OF . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . , . . . . . . . . . . , . . . , . . . . +~:+: +:+::+: + Of:+: Of No. 04-5203 Civil VERSUS SALLY ANNE MILLER DECREE IN DIVORCE fd.v~ "', ;2..005, IT [S ORDERED AND AND NOW, Kevin Roy Mill~r , PLAINT[FF. DECREED THAT Sally Anne Miller , DEFENDANT, AND ARE DIVORCED FROM THE BONDS OF MATR[MONY. THE COURT RETA[NS JUR[SDICT[ON OF THE FOL.LOWING CLA[MS WHICH HAVE BEEN RAISED OF RECORD IN TH[S ACTION FOR WHICH A F[NAL ORDER HAS NOT YET BEEN ENTERED; IV<> /oJ ~ , 0 ..; i .- -. , - . ~ ,~ . . . ~ . " .... , . . , By THE COURT: - . . . -' .... " . .. , ". ...... \.. J... ................. _ " ~Jt:..: ~'~C\:-..... PROTHONOTARY . .. . J. ,k ~ ~(;J ...."'" ~-O!/ fl't" - ...,<;-''-. YO-II-(::"' ~p~;; !7~~-Pf) 5(}'II'c 4l:1~~' - . . ',. f;