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Home My WebLink About03-5251DANIELLE K. MITTEN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERI2xND COUNTY, PA NO. OB- 5'dff-t CIVIL TERM RUSSELL P. MITTEN, III, Defendant : CIVIL ACTION - LAW : IN DIVORCE 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 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, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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 ! J~.GAL HELP. CUMBERLAND COUNTY BMR ~tSXOCIATION 32 SO UTH BEDFORD CA~T,I:fT.E, PA 17013 7) 4v-3 66 oR ( 00) 90-9 DANIELLE K. MITTEN, Plaintiff RUSSELL P. MITTEN, III, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. O~'ar'43'! CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT Plaintiff is Danielle K. Mitten, who currently resides at 854 Mountain Road, Newville, Cumberland County, Pennsylvama 17241. 2. Defendant is Russell P. Mitten, who currently resides at 854 Mountain Road, Newville, Cumberland County, Pennsylvania 17241. 3. The Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on October 30, 1999 at Newville, Cumberland County, Pennsylvania. COUNT I - DIVORCE 5. Paragraphs 1 through 4 of this Complaint are incorporated herein by reference as though set forth in full. the parties. 7. 3301(c), in that: There have been no prior actions of divorce or for annulment between Divorce is sought pursuant to the provisions of the Divorce Code, a. The marriage is irretrievably broken. 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 such counseling. 9. The Plaintiff in this action is not a member of the Armed forces. WHEREFORE~ the Plaintiff requests the Court to enter a decree of Divorce. DATE Respectfully submitted, A_BOM & KUTUL,IKI$~ LL P. Jasor. P. Kumlakis 36 So~uth Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff ID No. 80411 VERIFICATION I, DANIELLE K. MITTEN, verify that the statements made in this Divorce 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. Date ql 5~1C/~ ~~.k~ I/._~_~/~5~-- DANIELLE K. MITTEN DANIELLE K. MITTEN, Plaintiff RUSSEI.I, P. MITTEN, III, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 03-5251CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Jason P. Kutulakis, hereby certify that I did setaTe a tree and correct copy of the Complaint under Section 3301(c) of the Divorce Code, upon the Defendant, by depositing, or causing to be deposited, same in the U.S. mail, certified, restricted delivery, postage prepaid, on October 3, 2003, at Carlisle, Pennsylvania, addressed as follows: Russell P. Mitten, III 854 Mountain Raod Newville, PA 17241 Remm card acknowledging receipt on October 4, 2003 is attached as Exhibit ABOM & KUTUIAKIS, LLP Jason ~. Kutulakis, Esquire 36 South Hanover Street Carlisle, PA 17013 (717)249-0900 Attorney for Plaintiff I.D. No: 80411 EXHIBIT "A ~'' DANIELLE K. MITTEN, Plaintiff Vo RUSSELL P. MITTEN, III, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 03-525~ CIVIL TERM CML ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301 (c) of the Divorce Code was fried on October 3, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are tree and correct. 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: ~-~anieile ~. Mitten[ DANIELLE K. MITTEN, Plaintiff V. RUSSELL P. MITTEN, III, Defendant : IN THE COURT OF COMMON PLEAS CUMBERL2~qD COUNTY, PA : NO. 03-525~ CIVIL TERM CML ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER [3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 3. I understand that I will not be divorced u~atil 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 AffidavSt are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. 24904 relating to unswom falsification to authorities. Date: 1' /Oq )q,, '~anielle K.t Miqxen DANIELLE K. MITTEN, Plaintiff Vo RUSSELL P. MITTEN, !II, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 03-525~t CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under ~3301 (c) of the Divorce Code was filed on October 3, 2003. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) 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 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. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. DANIELLE K. MITTEN, Plaintiff V. : RUSSELL P. MITTEN, III, : Defendant : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 03-525~ CIVIL TERM CML ACTION - LAW IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER [3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not daim 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. 24904 relating to unswom falsification to authorities. Date: Russell P. Mitten, III DANIELLE K. MITTEN, Plaintiff RUSSELL P. MITTEN, III, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA : NO. 03-5251 CIVILTERM : : CIVIL ACTION - LAW : IN DIVORCE PRAECIPE TO DISCONTINUE TO THE PROTHONOTARY: Kindly discontinue the above referenced Civil Action in Divorce. Date: April 5, 2004 Respectfully submitted, ABOM & K'UTULAKI& L.L.P. Kara W. Haggerty, Esquire Attorney I.D. No. 86914 36 S. Hanover Street Carlisle, PA 17013 (717) 249-0900 Attorney for Defendant