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Home My WebLink About03-1046ANGELA L. MULLIS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL DIVISION -LAW ROBERT C. MULLIS, NO. 2003- JQYL CIVIL TERM Defendant IN DIVORCE COMPLAINT AND NOW, comes the Plaintiff, by and through his/her attorney, Broujos & Gilroy, P.C., and sets forth the following: 1. Plaintiff is Angela L. Mullis, who currently resides at 278 Long's Gap Road, Carlisle, PA 17013, Cumberland County, Pennsylvania. 2. Defendant is Robert C. Mullis, who currently resides at 4195 Carlisle Road, Gardners, PA 17324, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. The parties were married on May 27, 1997 in Mt. Holly Springs, Cumberland County, Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties in this or any other jurisdiction. 6. 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. 7. In accordance with Section 3301(c) of the Divorce Code the marriage between the parties is irretrievably broken. WHEREFORE the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. March 7, 2003 Broujos, Esquire No. 06268 Attorney for Plaintiff BROUJOS & GILROY, P.C. 4 North Hanover Street Carlisle, Pennsylvania 17013 717-243-4574; Fax: 717-243-8227 I verify that the statements made in this pleading 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. t DATE: March 7, 2003 Angela is r. r • b? C) tr f? ANGELA L. MULLIS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL DIVISION -LAW ROBERT C. MULLIS, : NO. 2003 -1046 CIVIL TERM Defendant : IN DIVORCE AFFIDAVIT OF SERVICE I, John H. Broujos, Esquire, being duly sworn according to law, do depose and state that a copy of the Complaint and Notice to Plead filed in the above referenced matter was mailed on March 10, 2003 and was served on Defendant Robert C. Mullis by U.S. First Class, Certified Mail, on March 20, 2003 at the address below. The Return Receipt is attached, showing receipt by Beth Bream. 4195 Carlisle Road Gardners, PA 17324 April 14, 2004 troujos, Esquire No. 6268 for Plaintiff IS & GILROY. P.C. 4 North Hanover Street Carlisle. Pennsylvania 17013 (717) 243-4574 Sworn and subscribed before me this 14th day of April, 2004. _4".' 4 (?' 6x otary Public Notarial Seal Bridget Ann Corcoran, Notary Public Carbale Boro, Cumberland County my Commission Expires June ]0, 2006 Member, Pennepania Association of Notaries r v -u r ?J C.) ` CD to t vas.. ¦ Complete items 1, 2, and 3. Also ccmplste item 4 if Restricted Delivery Is desired. ¦ Print ygyr name and address on the reverse. so that can return the card to you. ¦ Attach t card to the beck of the mailpiece, or on th nt if space permits. 1. Article Addressed to: sQi4?" G ??-?.l?.Q.c:? /791 A. D. Is delivery addMes dllM wd fmm item 1? 13 Yes If YES, enter delivery address below: ? No ? Insured Mail ? C.O.D. 4. Restricted Delivery? (Extra Fee) ? Yes 3. Serjo type Iff-Cottlied Mail ? Express Mall 13 Registered ? Return Receipt for merchandise 2. Article Number (Copy from service label) 5 o t f <0 3 S8? 20-7,? 3 t-s Lv 6g)( s? PS Form 3811, July 1999 Danessc Return Receipt 102606-0PM-0a62 L. MULLIS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL DIVISION -LAW C. MULLIS, NO. 2003- 1046 CIVIL TERM Defendant IN DIVORCE PRAECIPE FOR ENTRY OF APPEARANCE THE PROTHONOTARY OF SAID COURT: Please enter the appearance of Nancy A. Prescott, Esquire, on behalf of the in the above-captioned case. Respectfully Submitted, TURO LAW OFFICES /V 01,9 N cy escott, Esquire Turo Law Offices 28 South Pitt Street Carlisle, PA 17013 (717)245-9688 ID#89627 Attorney for Defendant CERTIFICATE OF SERVICE I hereby certify that I served a true and correct copy of the Praecipe for Entry of Appearance upon John H. Broujos, Esquire, by depositing same in the United States Mail, first class, postage pre-paid on the 2_'0 day of ftI1- , 2004, from Carlisle, Pennsylvania, addressed as follows: Mr. John H. Broujos, Esq. Broujos and Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 TURO LAW OFFICES Nand A. Prs6ott, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688; FAX 717.245.2165 ID#89627 Attorney for Defendant l c- a c; cw, ANGELA L. MULLIS IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. 03-1046 CIVIL ACTION LAW ROBERT C. MULLIS IN CUSTODY DEFENDANT ORDER OF COURT AND NOW, Wednesday, April 21, 2004 , upon consideration of the attached Complaint, it is hereby directed that parties and their respective counsel appear before Jacqueline M. Verney, Esq. , the conciliator, at 4th Floor Cumberland County Courthouse, Carlisle on Tuesday, May 11, 2004 at 9:30 AM for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. The court hereby directs the parties to furnish any and all existing; Protection from Abuse orders, Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing. FOR THE COURT, By: /s/ -Jacquelin M. Verney. Esa_ mhc Custody Conciliator The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilites Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. YOU SHOULD TAKE THIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY 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, Pennsylvania 17013 Telephone (717) 249-3166 or slop / h0 V 1 - MAY 1 2 2004 ANGELA L. MULLIS, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 2003-1046 CIVIL TERM ROBERT C. MULLIS, : CIVIL ACTION - LAW Defendant IN CUSTODY ORDER OF COURT I r7- AND NOW, this l n day of 1? -I J 2004 u on consideration of the attached Custody Conciliation Report, t is ordered and directed as follows: 1. The Mother, Angela L. Mullis, and the Father, Robert C. Mullis, shall have shared legal custody of Jessica Lynne Mullis, born October 28, 1993. Each parent shall have an equal right, to be exercised jointly with the other parent, to make all major non-emergency decisions affecting the Child's general well-being including, but not limited to, all decisions regarding her health, education and religion. 2. Mother shall have primary physical custody of the child. Father shall have periods of partial physical custody as follows A. Beginning May 14, 2004, alternating weekends from Friday at 4:00 p.m. to Saturday at 8:00 p.m. B. Memorial Day, 2004 weekend beginning May 28, 2004 at 6:00 p.m. to June 2, 2004 at 6:00 p.m. C. Such other times as the parties agree. 4. indicated below: A. Mother's Day/Father's Day- Mother shall have physical custody of the Child on Mother's Day; Father shall have physical custody of the Child on Father's Day, both at times as agreed by the parties. B. Memorial Day/Fourth of July/Labor Day-alternate with Father having Memorial Day in 2004. C. Thanksgiving and Easter shall be shared and alternated from 9:00 a.m. to 3:00 p.m. and 3:00 p.m. to 9:00 p.m. as agreed by the parties. D. Christmas shall be divided into two Blocks. Block A shall run from 12:00 noon Christmas Eve to 12:00 noon Christmas Day. Block B Holidays. The parties shall have physical custody of the Child as co 1 C _ u J ??- 7LU cv '=? shall run from Christmas Day at 12:00 noon to December 26 at 12:00 noon. Mother shall always have Block A and Father shall always have Block B. 5. Transportation shall be shared such that the receiving party shall transport the Child. 6. Both parties shall be entitled to reasonable, liberal telephone contact with the Child and the Child shall be entitled to speak privately with the non-custodial parent. supervision. Father shall not leave his son, Ben, alone with the Child without adult 8. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of mutual consent, the terms of this Order shall control. Another Conciliation Conference is scheduled for August 17, 2004 at 8:30 a.m. on the fourth floor of the Cumberland County Courthouse. BY THE COURT, A 0 ccc_'%O/hp? H. Broujos, Esquire, Counsel for Mother vAdcy Prescott, Esquire, Counsel for Father 1; 1 05-18'0 ANGELA L. MULLIS, Plaintiff V. ROBERT C. MULLIS, Defendant PRIOR JUDGE: None : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA 2003-1046 CIVIL TERM CIVIL ACTION - LAW IN CUSTODY CUSTODY CONCILIATION SUMMARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report: The pertinent information concerning the Child who is the subject of this litigation is as follows: NAME DATE OF BIRTH CURRENTLY IN CUSTODY OF Jessica Lynne Mullis October 28, 1993 Mother 2. A Conciliation Conference was held in this matter on May 11, 2004, with the following individuals in attendance: The Mother, Angela L. Mullis, with her counsel, John H. Broujos, Esquire and Father, Robert C. Mullis, with his counsel, Nancy Prescott, Esquire. 3. The parties agreed to an Order in the form as attached. Date V,? c acq line M. Verney, Esquire Custody Conciliator ANGELA L. MULLIS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL DIVISION -LAW ROBERT C. MULLIS, NO. 2003-1046 CIVIL TERM Defendant IN DIVORCE WITHDRAWAL OF APPEARANCE Kindly withdraw my appearance on behalf of the Plaintiff, ANGELA L. MULLIS, in the above-captioned matter. SAIDIS, FLOWER & John H. roujos, Esquire No. 6268 Atto a or Plaintiff BROUJOS & GILROY, P.C. 4 North Hanover Street Carlisle, Pennsylvania 17013 (717) 243-4574 Dated: ENTRY OF APPEARANCE Kindly enter my appearance on behalf of Plaintiff, ANGELA L. MULLIS, in the above- captioned matter. 1/" (ai I "_ SLOWIEW& LINDSAY '.6 West High Street Carlisle, PA Ma o tas, Esquire Suprem rt ID # 84919 Saidis, Flower & Lindsay 26 West High Street Carlisle, PA 17013 (717) 243-6222 Counsel for Plaintiff Dated: j / ? ??? - s? N "t LJI cr , ANGELA L. MULLIS, Plaintiff V. ROBERT C. MULLIS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL DIVISION -LAW NO. 2003-1046 CIVIL TERM IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed March 10, 2003. 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. 1 consent to the entry of a final Decree in 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 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 unsworn falsification to authorities. Date: '7 /Y ",,f / Robert C. Mullis 1. 1 consent to the entry of a final Decree of Divorce without notice. FLONVER SAWIS, LWDS" 26 West High Street Carlisle, PA 2. 1 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. 1 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 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 unsworn falsification to authorities. Date: `7 - /(/- I Robert C. Mullis - Fn Io fem.- ?^I ^^yy ?- n ? L _ ---4 ? W C-pi ANGELA L. MULLIS, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL DIVISION -LAW ROBERT C. MULLIS, : NO. 2003-1046 CIVIL TERM Defendant IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under § 3301(c) of the Divorce Code was filed March 10, 2003. 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. 1 consent to the entry of a final Decree in 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 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. Date: l8' (A 1 I cun, - Angela L. ullis I consent to the entry of a final Decree of Divorce without notice. ER & LINDSAY 26 West High Street Carlisle, PA 2. 1 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. 1 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 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 unsworn falsification to authorities. Q Date: - - L_ ___Q,EPM n_AaQ? Ange . Mullis rv c? ? ? -n ? + ,? 7''e fiT f;? '?Ji f «_ .- d?r 1... -?. a7 ? S a „ _ ? ? ? ? -.{ ?? l? ANGELA L. MULLIS, Plaintiff V. ROBERT C. MULLIS, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Kindly transmit the record, together with the following information, to the Court for entry of a Decree in Divorce: 1. Grounds for Divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Defendant accepted service of the Complaint on March 20, 2003, via certified mail. Proof of service was filed with the Court on April 19, 2004. 3. Date Affidavit of Consent required under Section 3301(c) of the Divorce Code was executed: 4. Related claims pending: None. SAMIS, FLOWER & LINDSAY RIURMY-M 26 West High Street Carlisle, PA 5. Date Waiver of Notice under Section 3301(c) of the Divorce Code was executed: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVILE DIVISION - LAW NO. 2003-1046 CIVIL TERM IN DIVORCE 21, 2008. By Defendant: On July 14, 2008 and filed with the Prothonotary on July 18, 2008. By Plaintiff: On July 18, 2008 and filed with the Prothonotary on July 21, 2008. By Defendant: On July 14, 2008 and filed with the Prothonotary on July 18, 2008. By Plaintiff: On July 18, 2008 and filed with the Prothonotary on July SAIDIS, FLOWER & LINDSAY III Mary1W ?tas, Esquire Supreme ourt ID No. 84919 26 West High Street Carlisle, PA 17013 717-243-6222 --n cxs Ct fV 7 `: r) rn IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ANGELA L. MULLIS VERSUS ROBERT C. MULLIS No. 03-1046 DECREE IN DIVORCE AND NOW, J ul -t J.u ,Zook IT IS ORDERED AND ANGELA L. MULLIS DECREED THAT AND ROBERT C. MULLIS ARE DIVORCED FROM THE BONDS OF MATRIMONY. , PLAINTIFF, ,DEFENDANT, 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; PROTHONOTARY 5a lyn-e -