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Home My WebLink About94-01123 to, \I . ~~-~~~~~~~~~-~*-~-*-*)~~:~:_._-*.:~~ ~ -- 8 ~ ~.' w ',' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ~ STATE OF . PENNA. ,', ~ ~ ',' s ~ ',' " .... ~ ',' .'. ~ .'. ~ ..JOHN W. MILLER ~ PlainWf . l\: () ,J.m,<:;:ryIL ................ 19 94 ~ .... Vt'I',.;lIS s N. SUE MILLER. ~ Defendant ~ " S w ',' DECREE IN DIVORCE AND NOW, '" $eptu".bcJ" ,12... ", " 199,6"". it is ordered and decreed that ",J~ W., ~ , . , . , , , , , . , , , , , , , , " , , , , , , " , , , '. plaintiff, and, .., , ,. .... .~: ,l?~,r:q~.. .... .. .... .. ........ ., .. .. ..... defendant. are divorcl'ld from the bonds of matrimony. ~ ':' ~ ~~ ~ ,. ~ ',' ~ ~ ~.' w .... ~ ." " ~ The court retains iurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; s ~ .... s None w .... ..... ........ ... ......... ...... ...... ............ ". s .. ........... -... .... ...... .... ........ ...... ...... .... ... M " lIy The C~ri' A \A i .. ~~ ~, r. Alle.l: i\ .,).... (':.~" 11/.q_J/ '-, J, v:3"'~~ ,..~4;)t[)~...".~0,,- >G/?~1. ~.~&. rJ;4 / '~...!honnlnry ,', ~ w '" s ~ ~I ~I :t .. __ '.:.:. ':.1:. .:.:- w '" ~ ',' ~ ',' $ .', ~ ~ s ,'. ~ S ~ ',' ~ ',' ~ .... s ~ ',' ~ l~ s s ~ s 0:. ~ $ $ s $ s * .~ , ' I~ I,. I,:, 1,- ;.:. I~ i' '~ 1',- , . ~~ :* ~ ~ ~ ~ ~..~.~..~..~..~,.~..~.~***-**~*.~.**.*.~~.~..~** :~ tJ~.~t# d/.. ~ ,,;;....~~ ~4 d~# ~,& ,f'~ :x'~~ o?1fa'~ &. d'-;4 ?ft~' fr. r-. , ,.t It: r-:: r '".'" en ::,i~ .... '_J:~ () - 1 ',..c. ?.. :"1 . ::;,c l'~}~ C .... >- ,. '" .'~;'p {, I '~ u' c... ,',: :.1._ w ; IIID 1- (I) ~p 0- 1I, \.0 ~" 0 ::J 0-' U il Cl. Cl. " ll'. '" ~ ~~~ Oti~ :I:: - j U~:S (I i ::! U) :z ~ii' !:! C09 ~ ~ ;~ l::~Ol;; OU~:Z ~I~! . ~:s ~ :- lQ ~ ": :.: U)Sl~ ~ ::1~ m - on ~ O:ll;;! ~ i ~ ~ . l2: ...l . . , ' , JOHN W. MILLER, PlaintilT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA CIVIL ACTION - LAW v, N. SUE MILLER, Defendant NO, 1123 CIVIL 1994 IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry ofa divorce decree: I. Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code, 2, Date and manner of service of the complaint: March 3, 1994, certified mail, addressee only, return receipt requested, 3, Dale of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: by PlainlilTJuly 13. 1995; by Defendant August 17, 1996, 4, Related claims pending: none. 5, Date and manner of service oflhe notice of intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under Section 3301(d)(I)(i) of the Divorce Code, ~~~ Edward L, Schorpp, Esquire Attorney for PlaintilT JOHN W, MILLER, Pluintifi" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW v, N, SUE MILLER, Defendant NO, 1123 CIVIL 1994 IN DIVORCE NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE TO: N, Sue Miller, Defendant, and her counsel, Marcus A, McKnight. 111, Esq" Irwin, McKnight and Hughes, 60 West Pomfret Street, Carlisle, Pennsylvania 17013, John W, Miller, Plaintiff, intends to file with the court the attached Praecipe to Transmit Record on or aner September 9, 1996, requesting that a final decree in divorce be entered, ~q~ Edward L, Schorpp, Esquire Attorney for Plaintiff . JOHN W, MILLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW N, SUE MILLER, Defendant NO, 1123 CIVIL 1994 IN DIVORCE CERTIFICATE OF SERVICE I, EDWARD L, SCHORPP, ESQUIRE, hereby certify that on August IS, 1996, I caused a true and correct copy ofthe Nolice oflntention to Request Entry of a Divorce Decree to be served upon the person and in the manner indicated below: FIRST CLASS MAIL, POSTAGE PREP AID, ADDRESSED AS FOLLOWS: Marcus A, McKnight, III, Esq, Irwin, McKnight & Hughes 60 West Pomfret Street Carlisle, PA 17013.3222 Attorney for Defendant BY:~~~~ Edward L, Schorpp, squire LANDIS, BLACK & SCHORPP 36 South Hanover Street Carlisle, Pennsylvania 17013 (717) 243.3727 Attorney for Plainliff Date~~~6e '? J?% ~ ~~ t e-l" " ":2" ~ ~.-< en ~..- ,,)~ ~ r'~ - .". ~... ~~ >, '. '-..9 "'~ " ..: C) ~.::.' '.J; ~,' J ..=!. ~ '" l. .~, . . '" ~ "..~ . 'J 0 ~ 0') " '0 Q ~~ C") !.QI' . ~ ~ Q<:) Q: - ....... ~~ ',::,,-; .......... ~ 'ttr: ;1 "" ::;: ~ .... .jJ Otif: .... ~ o~~ '... .jJ s~..~ i~~~ i:l i:l '... Ql E:.l~S; ~~ .... . f~ o u ~ ~ > ~~g; ~ ",Sl", -:l:::J o .. . . ~ ~ ~ ~ Q :I: ~ ~ tIl o-l ei ~ei 0 . ~ :z: ,; v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN W. MILLER, Plaintiff N. SUE MILLER, Defendant NO. /1),3 IN DIVORCE CIVIL 1994 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 with 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, First Floor, 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. 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. Court Administrator Fourth Floor Cumberland County Court House Carlisle, Pennsylvania 17013 Telephone: (717) 240-6200. v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN W. MILLER, Plaintiff N. SUE MILLER, Defendant NO. IN DIVORCE CIVIL 1994 COMPLAINT UNDBR SECTION 3301(0) OF THB DIVORCB CODB 1. Plaintiff is John W. Miller, who currently resides at 1805 Walnut Bottom Road, Newville (Dickinson), Pennsylvania 17241, filing of this Complaint. 4. Plaintiff and Defendant were married on June 14, 1969, in New Kingstown, Silver Spring TownShip, Cumberland County, Pennsylvania since November, 1970. 2. Defendant is N. Sue Miller, who currently resides at 8 Jeffrey Road, Mechanicsburg, (Hampden Township), pennsylvania 17055, since February, 1994. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the 17072. 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. 7Z.~M~~ 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. 54904, relating to unsworn falsification to authorities. Date: $~~,y 7/~~ LANDIS, BLACK & SCHORPP BY'~~<~- Edward L. Sch rpp, squire Attorney for Plaintiff 36 South Hanover street Carlisle, PA 17013 (717) 243-3727 -3- ~ en ~t: - ,....--.. :z: ;!% '. a- w,-):::I:! :) .... uxc.'Z .-:'OU...l :I' ,....0';'-' ..., t-..z.-.S \ . .;..t~ " ' i':" -:Vl ~\.- .t:.::P. c:> .;","l~- ~ . "l::X:'o.:' t-.:'(. . ... ;;:> ... o c." :r::: . ii ~ !:l ll-o ll-o i I.; i i D<: tl Olg IW .. Q S IW ~~ III ~=~~ '... ra. ~.. ~~ ~~ 0 Eo< o U ~ :2: . ~ II! :s 15 ::- ~Q :s = ~ ":. Q II) 51 ~ . I-t :J: ~ ~ -",:I Q ... .. ~ III . ~ is . to:! :z: :r " JOHN W. MILLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. N. SUE MILLER, Defendant NO. 1123 CIVIL 1994 IN DIVORCE AFFIDAVIT OF SERVICB COMMONWEALTH OF PENNSYLVANIA ) : SSe COUNTY OF CUMBERLAND ) 7# AND NOW, this .3tl-day of ~-'Y , 1994, I, Edward L. schorpp, Esquire, attorney for John W. Miller, Plaintiff in the above-captioned action, hereby swear that I have served a true copy of the Complaint in Divorce in the above-captioned matter, with Notice to Defend and Claim Rights, upon N. Sue Miller, the Defendant, at Eight Jeffrey Road, Mechanicsburg, PA 17055, by depositing same in the U. S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Defendant on March 10, 1994, indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. LANDIS, BLACK & SCHORPP BY~<~~e Attorney for Plaintiff Sworn and subscribed to before me this J()..y day of '41....~ , 1994. " ~ . Notar . EXHIBIT "A" JOHN W, MILLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, CIVIL ACTION - LAW N, SUE MILLER, Defendant NO, 1123 CIVIL 1994 IN DIVORCE AFFIDAVIT OF CONSENT I. 9,1994, A Complaint in Divorce under ~3301(c) of the Divorce Code was liled on March 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date ofliling the Complaint. 3, I consent to the entry ofa linal decree of divorce, 4, I understand that I may lose righls concerning alimony, division of property. la~er's fees or expenses ifI do not claim them before a divorce is granted, WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER 6330t(d OF THE DIVORCE CODE I, I consent to the enlry of a linal decree of divorce without notice, 2, I undersland that I may lose rights concerning alimony, division of property, lawyers 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 liled with the prothonotary, I verifY that the stalements made in lhis affidavit and waiver are true and correct. I understand that false statements herein are made subject to lhe penalties of 18 Pa, C,S, ~4904 relating to unsworn falsilication to authorities, Date:~ lfL) JW C(~:.~;~ ..." 'w:P ~ M >- ~ e; .. 5~ r M S.'" (~ ~ .~ 'L u.. '")::>: [, ~...~ c ;'~.Gi t;: 0 '-. N )~ eel" (.!l ~CiiQ ~ (:!:: - C!l U. oCt ::;; ~ \0 ::l en U -", :;,' ',. ,,\ '. ,', ~ '~~~ , - ~ ( :;/, ,", "' ~'~~ ,I," ,- . -~..- ,.., .;.:.: ::;~; '~~': " .~t. " '/:" '.:i ,.~,-, ~--,--, ~' . ',," .~ \ 'j, ':t. , ,...., .. !:~' t ,I . , . JOHN W. MILLER, Plain tilT : IN THE COURT OF COMMON PLEAS OF v. : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1123 CIVIL 1994 N. SUE MILLER, Defendant IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed on March 9, 1994, 2, The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the complaint. 3, I consent to the entry of a final decree in divorce, 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, I veritY that the slatemenls made in lhis affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa, C, S, Section 4904 relating to unsworn falsification to authorities, ~L113 I Y/. ..d'-LL 37Ld&tJ N. SUE MILLER ,1995 .. . ,. '. .,. !','. .:..,' ;,J..' .:~ .,..'.,: ....," ':. " , , ' . ., . . " , JOHN W. MILLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF . . : CUMBERLAND COUNTY, PENNSYLVANIA . . CIVIL ACTION - LAW v. . . . . NO. 1113 CIVIL 1994 . . N. SUE MILLER. Defendant . . IN DIVORCE . . DEFENDANT'S MARRIAGE COUNSELING AFFIDAVIT The defendant, being duly sworn according to law, deposes and says: 1, 1 have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and 1 participale in counseling, 2, 1 understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request, 3, Being so advised, I do not request that the court require that my spouse and 1 participate in counseling prior to a divorce decree being handed down, I verifY that the statements made in this affidavit are lrue and correct. I understand that false statements herein made are subject to the penalties of 18 Pa, C,S, Section 4904, relating to unsworn falsification to authorities, ~/ /3 ')1. .1c.u... J1ui&u N. SUE MILLER ,1995 ~~ ~~ ~~ ~ ~P< en e .... ~~ ~~ ~8 ""0 eQ ~~ ~i ."". en - >0- .et: =:c: ~ :; ~ ~(,~_):"I U) t;;.5:~;-:: f';:) i...-17,'I'.4 ;'''~---~ ~..:.: ~.\ ,. .Ul > t,:/::1 . ;_lll"'.J ,,;z'" '" ~;'-l N r- - <.. =::J ~ I ~ = o ::: ~ d ~ ~ ~ t; 6 t.l i ~ g tl ~ ! : ~ ~ ca e ~ ~ C:5Z~J:~ f ~ ~ ~ ! ~ ~ ~ ~ Q. 1-4 2 ~ &J oJ .,;~OUl F-4 w CD :; ~. ~ 1-4 :: I ~ ~ LI '4 .~ ~~ ,",PI ~ ~j '"'2/ :i ~ ~ ~ z - c ,~-:~~~:~t: . I."", {Jlli,."" l1~WI~. IHWI~ & ~rcI{~IGUT . , ',;",,";n~~,..-l' N. SUE MILLER, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. JOHN W. MILLER, DEFENDANT 1123 CIVIL 1994 IN DIVORCE PRAECIPE TO WITHDRAW TO: LAWRENCE E. WALKER: PWw Milidmw ~ 'p~o, ~~;JZi;j~~' Robert W, Weager, q Ire 204 State Street Harrisburg, PA 171 ~ ~ Date: August /1 , 1994 PRAECIPE TO ENTER AN APPEARANCE TO: LAWRENCE E. WALKER: Please enter my appearance on behalf of the plaintiff, N. Sue Miller, By: Date: August 11, 1994 .. -" SHERIFF'S RETURN COMMONWEALTH OF PENNSYLVANIA In The Court of Common Pleas of Cumberland County, pennsyvania COUNTY OF CUMBERLAND No. 1123 Civil Term 1994 Order, Petition for special Relief N. Sue Miller VS John W. Miller R. THOMAS KLINE, Sheriff, who being duly sworn according to law, says. that he made diligent search and inquiry for the within named defendant to wit. John W. Miller but was unable to locate him in his bailiwick. He therefore returns the nT~PT, pptition for Snecial Relief NOT FOUND, as to the within named defendant, John W. Miller. Attemots at service were made on August 10, 1994 And I'.lIgust 17. 1994. but wk could not find Mr. Miller at the address supplied Sheriff's Costs. Docketing 14.00 Service 6.16 Affidavit Surcharge to us. So answers. /.. .,/ . /- ,/ ','J "".~,~ .--;-r;, ~ /. ~ // , ~, .... #:" / I R. THOMAS KLINE, Sheriff 2.00 22.l6 Pd. by Atty. 8-l8-94 Sworn and subscribed to before me this J ..d.. , - day of ~.....,.r A.D. 19 "1'1 Cj....JI...... {.', nL<.lc<-.- , J.Jf17 ' Prothonotary N. SUE MILLER, Petitioner . . IN THE COURT OF COMMON PLEAS OF CUlolBERLlillD CQUN'rY, PENNSYLVANIA v. : CIVIL ACTION - LAW ; JOliN W. MILLER, Respondent . . . . 9'1-1123 CIVIL TERM IN RE: PETITION FOR SPECIAL REI.IEF ORDER OF COURT AND NOW, this ~ ~ t day of August, 1994, upon agreement of counsel for the above parties, the hearing previously scheduled in this matter for August 2, 1994, is RESCHEDULED to Thursday, August la, 1994, at 8:45 a.m., in Courtroom No.5, Cumberland County Courthouse, Carlisle, Pennsylvania. BY 'l.'HE COUR'l', U0L J.; Wesley Oler, I Robert W. Waeger, Esq. 204 State Street Harrisburg, PA l7l0l Attorney for Petitioner TRUE C0PY FR0M REr.CRD In Testimony whlrcof. I h; ~~ u~lo ~:I my hand and the seal of said Court at Carlisle, Pa, This ......9.Y..~.. day OLa'?,..,...." 19,f.'f.' .........,..",~l~t;~"..d...'~r"~ if Prolhoootary Edward L. Schorpp, Esq. 36 S. Hanover Street Carlisle, Pa l70l3 Attorney for Respondent :rc - , ."'- , .-. . .... JUl281994 J . ,"- .', _ ..i... \~, - - - , .' "<B.'~:-,~'~:~ ' . ,~ A ......._,,-.... .. N. SUE MILLER Petitioner IN TilE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYVLANIA CIVIL ACTION - LAW V. JOHN W. MILLER Respondent NO. 1123 CIVIL 1994 In Divorce . . o ROE R AND NOW. this Zj~ day of July. 1994, it is hereby ORDERED that: Po~11d.eR9r if;; g*'ft.~~t:'::^\jJ.u!:ilv~ putltJesHion of Un-", lIIu.l.l Lal- i lILt..';), pDSS.C~.sI...:r. of h,,",O, and Respondent is enjoinod from It(lms..'iMg it"s'" Cumbe&olaucl C9"n't:l' aRB tAe CsftlllleRWeeT't1T uf rl"u'~J11vartia any of the marital property or assets as set forth in paragraph 5 of the Petition for Special Relief filed by Pet! tioner. "pot"', f=ur+-hor Qrggr of C'Q'l........ n'l'" until SA ...~:e~~~PlQe :~ .t~: l'::t:~~MCr. J' tL..s: '1"l~~'-r.ooJl ~t.?{l ~G. ~r(J o"c Y..u.UJ70'" BY THE COURT: auf::.;I. I,,?CJLj c 1 I ! g.. 0 III ffl7, .....:-.. ~u..2i:,:o-r.->l'" --1<0, 6 "I CL eU.A'L.../{'"Y,~",,;:: -J. {Pr.-",> () O~. . ~X 6t-<..uz.LL~~oJJ, U "b ~i2<.U. f3..AtA-.....vr-u:v>l-<~ . T~UE COpy FROM RECORD In Testimony whereof, I here unto set my hand and the seal oJ said Court at Carlisle Pa 'S'h(' ,", ThiS ..,..,0....,...., day Of,..r~..,......, 19e! ,..............,6auf~ -. ''-'''''.~ f~ (/ . .....c........~.c~,..~;..e;.. Prothonotary / "I'folal. -..". \ N. SUE MILLER Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. JOHN W. MILLER Respondent : CIVIL ACTION - LAW : . . NO. ll23 CIVIL 1994 In Divorce . . PETITION FOR SPECIAL RELIEV The Petitioner. N. Sue Miller, by and through her attorney, Robert W. Waeger, Esquire, herein avers as follows: 1. Petitioner, N. Sue Miller. is an adult female residing at 1005 Walnut Bottom Road, Newville, Cumberland County, Pennsylvania. 2. Respondent is John W. Miller, a former resident of 1805 Walnut Bottom Road, Newville, Cumberland County, Pennsylvania. John W. Miller's current address is unknown to Petitioner but it is believed that Respondent is currently residing outside the Commonwealth of Pennsylvania. 3. Respondent John W. Miller has filed a Complaint in Divorce against Petitioner on or about March 9, 1994. 4. Attorney for Petitioner has communicated with Respondent's attorney, Edward schorpp, Esquire. regarding a proposed Property Settlement Agreement but to date nothing has been accomplished. 5. It has come to Petitioner's knowledge and beUef that Respondent plans to return to pennsylvania on or about July 29, 1994, and attempt to r.emove most, if not 'Ill, marital assets including but not limih~d to: ~\r'~- --. . '~~. ~ - :' .. a) any monies in joint or non-corporate business accounts; b) any and all vehicles, automobiles, motorcycles, or construction equipment; c) furnishings and business office oquipment in the residence, as wo11 as inventoried construction materials located either at the Dickjnson Rent-N-Store or residence. 6. It is Petitioner's belief that Respondent plans to remove said marital assets on the weekend of July 29, 1994 or thereafter. Therefore, Petitioner requests this Honorable Court to issue an Order granting Petitioner exclusive possession of the marital residence at 1805 Walnut Bottom Road, and enjoining Respondent from removing any of the marital assets as outlined in paragraph 5 herein from any location situate in Cumberland County until further Order of Court or an Agreement between the parties is executed. Petitioner further requests attorney's fees, costs, and other relief the court deems appropriate. Respectfully submitted, , f / ",:. ~ . ,i ;1 ,; "/'.{ . i{:l//:_'<" to ,.-... , . " July 28, 1994 Robert W. Haeger ,-::-esquire 204 state stree~ I Harrisburg PA l~lpl Attornoy for Petitioner 2 . , .:... ~'d ,", fa' .....,........-. ...,;...,. ~ .----..-.,. VKJtIrICATION 1, N. SUE MI~LBR, ~o ptete, subjeot to the penal tie. ot 18 Pe. e.s. Section 4904 relating to unsworn falsific$tion to authorities, that I am the Potitioner herein, an~ that the inforMRtion 4et forth in the toregoing P.titio~ for Spocial ~oliet ia truo and correct to tho bost ot my knowl.~g., information, and ba1ief. Pote: _ . 4, L )1t.JfJ/A/ N. Sue M:I.11er N. SUE MILLER, Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. JOHN W. MILLER, Respondent 94-ll23 CIVIL TERM IN REI PETITION FOR'SPECIAL RELIEF ORDER OF COURT AND NOW, this (glt day of August, 1994, upon agreement of counsel, the hearing previously scheduled in the above matter for August l8, 1994, is CONTINUED GENERALLY. BY THE COURT, Marcus A. McKnight, III, Esq. ;~j{' West Pomfret Professional Building ~~--60 West Pomfret Street C ~,). Carlisle, PA l70l3-3222 .~ \\'\.1 Attorney for Petitioner )1' !l.W' ~ Edward L. Schorpp, Esq. "36 S. Hanover Street 'earlisle, PA l70l3 Attorney for Respondent :rc tll;';" .(,' I ". ~H'I.)" ., ..1, . .." I1~H.1Ij::J- ,'ftJi.'''Otl' ~ ';.~:-:i."lPJ .IOI/'t. _.'.'.; 10 M. HJ Ii~ 2 81 :InV . > ,..IM!IItDrh;., N. SUE MILLER, Petitioner v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW JOHN W. MILLER, Respondent 94-1l23 CIVIL TERM PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this \!>t day of August, 1994, upon agreement of IN RE: counsel for the above parties, the hearing previously scheduled in this matter for August 2, 1994, is RESCHEDULED to Thursday, August l8, 1994, at 8145 a.m., in Courtroom No.5, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, w~ J Wesley Oler, Robert W. Waeger, Esq. 204 State Street Harrisburg, PA l7101 Attorney for Petitioner Edward L. Schorpp, Esq. 36 S. Hanover Street Carlisle, pa l70l3 Attorney for Respondent :rc . T' :1: i .,1 ~,I :', .'h ! ~ ,1..tI} OfFICE OF THl ,ill,jIlOHCT A~Y CUHilEr.l~NO COUIHY PEHH5Yl'/AHI~ aUG Z I 51 PK '9~ JUL 29 II 03 AH '9~ ",." J.f1CE or THf t ,,11HON~TAhY CUHeER1.A~O COU~HY PENNSflVANIA v. CIVIL ACTION - LAW N. SUE MILLER Petitioner : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA . . : JOHN W. MILLER Respondent : NO. 1123 CIVIL 1994 In Divorce . . : PETITION FOR SPECIAL RELIEF The Petitioner, N. Sue Miller, by and through her attorney, Robert W. Waeger, Esquire, herein avers as follows: 1. Petitioner, N. Sue Miller, is an adult female residing at 1805 Walnut Bottom Road, Newville, Cumberland County, Pennsylvania. 2. Respondent is John W. Miller, a former resident of 1805 Walnut Bottom Road, Newville, Cumberland County, Pennsylvania. John W. Miller's current address is unknown to Petitioner but it is believed that Respondent is currently residing outside the Commonwealth of Pennsylvania. 3. Respondent John W. Miller has filed a Complaint in Divorce against Petitioner on or about March 9, 1994. 4. Attorney for Petitioner has communicated with Respondent I s attorney. Edward Schorpp, Esquire, regarding a proposed Property Settlement Agreement but to date nothing has been accomplished. 5. It has come to Petitioner's knowledge and belief that Respondent plans to return to Pennsylvania on or about July 29, 1994, and attempt to remove most, if not all, marital assets including but not limited to: (.. ...,.__,.._u a) any monies in joint or non-corporate business accounts; b) any and all vehicles, automobiles, motorcycles, or construction equipment; c) furnishings and business office equipment in the residence, as well as inventoried construction materials located either at the Dickinson Rent-N-Store or residence. 6. It is Petitioner's belief that Respondent plans to remove said marital assets on the weekend of July 29, 1994 or thereafter. Therefore, Petitioner requests this Honorable Court to issue an Order granting Petitioner exclusive possession of the marital residence at 1805 Walnut Bottom Road, and enjoining Respondent from removing any of the marital assets as outlined in paragraph 5 herein from any location situate in Cumberland County until further Order of Court or an Agreement between the parties is executed. Petitioner further requests attorney's fees, costs. and other relief the court deems appropriate. Respectfully submitted, July 28, 1994 ,( /' ; /C. Robert W. Waeger, 204 state Stree Harrisburg PA 1 1 1 Attorney for Pet tioner 2 ".--,._,~:;';':-':'::'~. YftIrXCA'l'!ON I, N. SUE Ml~LBR, 60 .tote, subjeot to the pana1tie. ot 18 Pe. e.s. Section 4904 relating to unsworn fa1sificat1on to author1Ue., that I am the Petitioner herein, an4 that the information .et forth in the foregoing .etition for Special Rali.f 18 true an4 correct to tha beet of my knowla611a, information, .n6 balief. Datal 'jJ, ~ MIl,A/ N. sue M 11ar