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Home My WebLink About05-0844IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Bradley Scott Miller, : No. OS - Plaintiff Civil Action - Law VS. Kelly Lynn Miller Defendant In Divorce NOTICE TO DEFEND AND CLAIM RIGHTS t_ I U i L `ER-J-n 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 in divorce or annulment may be 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 the custody or visitation rights 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 at the Cumberland County Courthouse, 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 32 South Bedford Street Carlisle, PA 17013 (717)-249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Bradley Scott Miller, : No. DS- Plaintiff Civil Action - Law VS. Kelly Lynn Miller Defendant In Divorce COMPLAINT UNDER SECTION 3301 OF THE DIVORCE CODE 1. Plaintiff is Bradley Scott Miller who currently resides at 86 Diller Drive, Shippensburg, Cumberland County, Pennsylvania, since November 16, 2004. 2. Defendant is Kelly Lynn Miller who currently resides at 2818 Boas Street, Harrisburg, Dauphin County, Pennsylvania, 17103, since February 1, 2005. 3. Plaintiff and Defendant have been bona fide residents in 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 April 6, 2002 at Harrisburg, Dauphin County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The marriage is irretrievably broken. 7. 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. 8. Plaintiff requests the Court to enter a decree of divorce. Wherefore Plaintiff requests that he be granted a divorce from the bonds of matrimony. Respectfully submitted. H. Anthony Adams, Esquire Attorney for Plaintiff 49 West Orange Street Shippensburg, PA 17257 (717)-532-3270 Supreme Court ID 25502 I verify that the statements made in this Complaint 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. Date: 4L4," a U Bradley Scottiller n ? 0 ? ? ?- ? C7 ? ? ? ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY - PENNSYLVANIA Bradley Scott Miller, :No. 05-844 Civil Term Plaintiff Civil Action - Law VS. In Divorce Kelly Lynn Miller Defendant TO THE PROTHONOTARY: Praecipe Pleases mark the above captioned matter discontinued and Respectfully, H. Anthony Adams -Z?2 Attorney for Plaintiff 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 n? ? t? O ?+ -n _,, -i :-J Pi iT_ __.4T1 ._ )?_, +C7 ,, n F' 's? < _} ,. Phelan Hallinan & Schmieg, LLP By: Michael E. Carleton, Esquire Identification No. 203009 One Penn Center Plaza, Suite 1400 Philadelphia, PA 19103 (215) 563-7000 Flagstar Bank, FSB Plaintiff Attorney for Plaintiff : Court Of Common Pleas : Civil Division Vs. Shirley A. Eser Defendant(s) : Cumberland County, Pennsylvania 05-884 CIVIL Term CERTIFICATE OF SERVICE I, Michael E. Carleton, Esquire, hereby certify that true and correct copies of the July 26, 2007 Rule to Show Cause with respect to Plaintiff s Exceptions to Sheriff s Sale Distribution Pursuant to Pa.R.C.P. Rule 3136(d), Plaintiff's Exceptions, and this Certificate were served by regular mail on the d? listed below on the following: Shirley A. Eser 229 Wolfs Bridge Road Carlisle, PA 17013 Tenant/Occupant 229 Wolfs Bridge Road Carlisle, PA 17013 Community Banks 201 Saint Johns Church Road Camp Hill, PA 17011 R. Thomas Kline Sheriff of Cumberland County Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 Internal Revenue Service Federated Investors Tower 1001 Liberty Avenue 13th Floor, Suite 1300 Pittsburgh, PA 15222 p IV Community Banks P.O. Box G280 Harrisburg, PA 17112 James C. Costopoulos 10 Courthouse Avenue, Suite 103 Carlisle, PA 17013 Dated: ' // d I Citifinancial, Inc. 3401 Hartzdale Drive, Ste 126 Camp Hill, PA 17011 Pennsylvania Housing Finance Agency 2101 N. Front Street Harrisburg, PA 17110 Respectfully submitted, PHELAN HA LINAN & + G, LLP ter' By: Michael E. Carleton, Esquire Attorney for Plaintiff FLAGSTAR BANK, FSB, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SHIRLEY A. ESER, ; Defendant NO. 05-884 CIVIL TERM ORDER OF COURT AND NOW, this 26th day of July, 2007, upon consideration of Plaintiff's Exceptions to Sheriff's Sale Distribution Pursuant to Pa. R.C.P. Rule 3136(d), a Rule is hereby issued upon all interested parties, including the Cumberland County Sheriff, to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. PLAINTIFF SHALL be responsible for service of this rule upon all interested persons. BY THE COURT, 5ael E. Carleton, Esq. e Penn Center Plaza to 1400 adelphia, PA 19103 ,rney for Plaintiff J. Wesley Oler, Jr., J. fund , myhand inTp- h s. Thl ,....,..17 p 7. nTf= r'-` ?, "? Ire 23 1 rr 2