HomeMy WebLinkAbout06-0807
II
I'
II SUSAN E. MILLER, ) IN THE COURT OF COMMON
\1 Plaintiff ) PLEAS OF CUMBERLAND
, ) COUNTY, PENNSYLVANIA
'I
, )
ii
I vs, ) CIVIL ACTION - LAW
I
I ) (!u).L
I ) NO () Cr - fU1
JARED R. MILLER, )
Defendant ) IN DIVORCE
,
,
i NOTICE TO DEFEND AND CLAIM RIGHTS
I
II' You have been sued in court. If you wish 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
I case may proceed without you and a decree in divorce or annulment may be entered against
I 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:
Office of the Prothonotary
Cumberland County Courthouse
1 Courthouse Square
Carlisle, P A 17013
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYERS 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, P A 17013
Telephone: (717) 249-3166
II
SUSAN E. MILLER,
Plaintiff
vs,
)
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
,
ii
i
II
"
i:
ii
II
I
!
'i
I
I
I
II TO THE WITHIN-NAMED DEFENDANT:
I
I
I
CIVIL ACTION - LA W
NO. ct,.. $07 Ci...ioJ T~
JARED R, MILLER,
Defendant
IN DIVORCE
NOTICE OF A V AILABILITY OF COUNSELING
You have been named as the Defendant in a Complaint in a divorce proceeding filed in
the Court of Common Pleas of Cumberland County. This notice is to advise you that in
II accordance with Section 3302 (d) of the Divorce Code, you may request that the court require
I'i,'".
you and your spouse to attend marriage counseling prior to a divorce being handed down by
I' the court. A list of professional marriage counselors is available at the Domestic Relations
Office, 13 North Hanover Street, Carlisle, Pennsylvania. You are advised that this list is kept
as a convenience to you and you are not bound to choose a counselor from this list. All
necessary arrangements and the cost of counseling sessions are to be borne by you and your
spouse.
If you desire to pursue counseling, you must make your request for counseling within
twenty days of the date on which you receive this notice. Failure to do so will constitute a
waiver of your right to request counseling.
II
r --
SUSAN E. MILLER,
Plaintiff
vs.
)
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO, Of, - SO? (!;:.;.; -1___
JARED R. MILLER,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE
AND NOW comes the above-named Plaintiff, SUSAN E. MILLER, by her attorney,
Samuel L. Andes, and makes the following Complaint in Divorce:
1. The Plaintiff is SUSAN E. MILLER, an adult individual who currently resides at 714
I'
Ii Quaker Circle, Apt. 6, Lewisberry, York County, Pennsylvania.
Ii 2. The Defendant is JARED R. MILLER, an adult individual who currently resides at
PI
45 Shelley Drive in York Haven, York County, Pennsylvania.
3. Both the Plaintiff and 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 12 May 2001 in New Cumberland,
York County, Pennsylvania.
5. There have been no prior actions of divorce or annulment between the parties.
6. The marriage is irretrievably broken.
7. Plaintiff has been advised of the availability of marriage counseling and the Plaintiff
may have the right to request that the Court require the parties to participate in counseling,
II
i
I
i
COUNT I - IRRETRIEVABLE BREAKDOWN
8. The Plaintiff requests this Court to enter a Decree in Divorce.
WHEREFORE, Plaintiff requests this Court to enter a Decree in Divorce pursuant to the
Divorce Code of Pennsylvania.
II
I
I
I
I
I
~ \W.~
Samuel L. Andes
Attorney for Plaintiff
Supreme Court ID # 17225
525 North 12th Street
Lemoyne, Pa 17043
(717) 761-5361
II
"
"
I verify that the statements made in this Complaint are true and correct. I understand that any
false statements in this Complaint are subject to the penalties of 18 Pa, C.S. 4904 (unsworn
falsification to authorities),
"
"
Ii
"
Ij
I,
II Date: 1/ /0(0
I
II
II
I
,
I
II
II
II
II
~YlE.fl1Jrf~
SUSAN E. MILLER
!I
[~---,
--...
"o",j
--c..
""--'
;:-\"
Y'
r.\~
---
'r"J
~,
"
~\
(i...
, i'-
~, '-...S:
~
~
'--'"
~
r-,'
\.....,,"
""'~.
~..
(~;
-n
:~-~j
I
C)
I")
~
SUSAN E. MILLER,
Plaintiff
vs.
)
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
JARED R. MILLER,
Defendant
NO, ()G'1Ul C'~
IN DIVORCE
AGREEMENT AS TO VENUE
The undersigned, being both parties to the above-captioned action, hereby stipulate and
agree that this action may proceed before the Court of Common Pleas of Cumberland County,
Pennsylvania, and waive their rights under the Pennsylvania Rules of Civil Procedure, to
challenge or object to venue before that court.
-n
:-:?
r.:::.-~
--......".'
t
"-c!
-:;:"'!
;,"<'
r~',
I
vs.
)
)
)
)
)
)
)
)
)
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND
COUNTY, PENNSYL VANIA
SUSAN E. MILLER,
PLAINTIFF
CIVIL ACTION - LAW
~t1
NO. 2006-ze7' CIVIL TERM
JARED R. MILLER,
DEFENDANT
IN DIVORCE
ACCEPTANCE OF SERVICE
I, JARED R. MILLER, hereby accept service of the original Complaint in Divorce and
acknowledge receipt of a copy of the Complaint.
Date: 'J..(IS-(O("
i .', ; /
I " J._'" ._" ....,.,r-
, J),t //:..~.~:a;""?
JARED R. MILLER
--i",
:'-'.)
\",'1
f
II
SUSAN E. MillER, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
) PENNSYLVANIA
)
vs. ) CIVil ACTION - LAW
)
) NO. 2006@7 CIVil TERM
JARED R. MillER, )
Defendant ) IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 9
February 2006 and served on the Defendant on 15 February 2006.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of both the filing and service of the complaint.
3. I consent to the entry of a final decree in divorce after service of a Notice of
Intention to Request Entry of the Decree.
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301 ecl OF THE DIVORCE CODE
1. I consent to the entry of a final decree in divorce without notice.
2. 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.
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. 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.
~j/.:!J/Ou
Dated:
j~r7 { II1d!.ltv
SUSAN E. MillER
(") ...."
= 0
c: e., -r,
...,.~ <:h
.J ((oj ~ 3!
n, fj, [11 ::!J
z: " -<: r-
2~ , \:tm
cr.: I :'f)O
-;; U1 " '
~.. ':::;C!
;g: \.- "" C~~~,
-.
c ""'"
1'; ~;~:~ ~
:i:;5
=< 0 :i:I
N --<
II
SUSAN E. MillER, ) IN THE COURT OF COMMON
Plaintiff ) PLEAS OF CUMBERLAND COUNTY,
) PENNSYLVANIA
)
vs. ) CIVil ACTION - LAW
)
) NO. 2006807 CIVil TERM
JARED R. MillER, )
Defendant ) IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on 9
February 2006 and served on the Defendant on 15 February 2006.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90)
days have elapsed from the date of both the filing and service of the complaint.
3. I consent to the entry of a final decree in divorce after service of a Notice of
Intention to Request Entry of the Decree.
WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY
OF A DIVORCE DECREE UNDER SECTION 3301 ec) OF THE DIVORCE CODE
1. I consent to the entry of a final decree in divorce without notice.
2. 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.
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. 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.
LftJ.4IOb
Date :
I~ ~/ /
J ED R. MillER
Q
~~
-.,
""OGJ
~~~
(J! "
r~(
'~,'
~f(~';
~p. ~;
"':"',
-"j
,,<
r->
=
=
"'"
3
"'"
-<
t
(f\
""<J
::r;:
~
o
N
o
-n
~, "1J
rlf:':'
-nIT-
-nO
;~~ ~~)\
J__ +'T:
;.~r5
,1~.~ rn
o
___I
'CO
er:J
:..;;
SUSAN E. MillER,
Plaintiff
vs.
)
)
)
)
)
)
)
)
) IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
IN THE COURT OF COMMON
PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVil ACTION - LAW
~~l
NO. 2006~ CIVil TERM
JARED R. MillER,
Defendant
TO THE PROTHONOTARY:
Transmit the record, together with the following information, to the Court for entry of a
divorce decree:
1. Grounds for Divorce: Irretrievable breakdown under Section 3301 (c).
2. Date and manner of service of the Complaint: Acceotance of Service filed by Plaintiff's
counsel indicatiml service on or about 15 Februarv 2006.
3. Complete either Paragraph (a) or (b):
(a) Date of execution of the Affidavit of Consent required by Section 3301 (c)
of the Divorce Code: By Plaintiff: 3 May 2006 By Defendant: 24 Aoril 2006
(b) (1) Date of execution of the Affidavit required by Section 3301 (d) of the
Divorce Code: (2) Date of filing and service of the Plaintiff's Affidavit
upon the Respondent:
4. Related claims pending: None.
5. Complete either (a) or (b):
(a) Date and manner of service of the Notice of Intention to File Praecipe to
Transmit Record, a copy of which is attached:
(b) Date Plaintiff's Waiver of Notice in Section 3301 (c) Divorce was filed with
the Prothonotary: Dated 3 May 2006 and filed contemooraneously herewith. Date
Defendant's Waiver of Notice in Section 3301 (c) Divorce was filed with the
Prothonotary: Dated 24 Aoril 2006 and filed contemooraneously herewith.
Date: 3 May 2006
By (~~~~~
Attorney for Plaintiff
0 .....,
= 0
c: = -"
";:--., 0_
;;-~F~ :J::: :?
~..." -"
Z -< nip
>:~ I ~p8
(f)
~ (Jl (~; (
r' :":^'j()
<' :-1"
~i:... -u r';~ "
,., ::Ji: C)
~,
j.';' (~: N l~~rn
.-,.... -,
":J (::J ~
.n
'.'. ..,. .<
'"
'"
'"
'"
'"
'"
'"
'"
'"
'"
'"
'"
'"
'"
'"
'>
'>
'>
'>
'>
'>
'>
'>
'"
'>
'>
'"
'>
'>
'"
'>
'>
'>
'>
'>
'>
'>
'>
'>
'>
'>
'>
'>
'>
'>
'>
"''''''' '"
if.'"
if.
'"
if.
'"
"''''if.'''
'"
'" if.
IN THE COURT OF COMMON PLEAS
OFCUMBERLANDCOUNTY
STATE OF
PEN NA.
SUSAN E. MILLER,
2006~7
No.
Plaintiff
VERSUS
JARED R. MILLER,
Defendant
DECREE IN
DIVORCE
AND NOW,
t'\ ~ 'i
2006
, IT IS ORDERED AND
\0
SUSAN E. MILLER
DECREED THAT
, PLAINTIFF,
AND
JARED R. 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;
NONE
By THE COURT:
ATTES~ l ~ ~ J.
~~~.
C
PROTHONOTARY
'" '" '" '" '"
'" '"
"'''' '" '"
'"
'>
'" '" "''''
'>
'"
if.
'>
if.
'>
if.
'>
if.
if.
if.
if.
'"
if.
if.
'"
if.
if.
if.
if.
if.
if.
if.
if.
if.
if.
if.
~-b ~ ~~}L; t1Jo. r?/ ~y
~ ~ ~ ~P9 ~(/7. ()/:~
."
. ..
,
'i ~ ""
... ' .
, " '" t ..... >, J \.',~.",:.,
, ~