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Home My WebLink About09-4916Carlotta Lampkin-Mitchell, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Tyrone Mitchell, : Defendant :NO. 09- CIVIL TERM 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 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, 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. Cumberland County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities 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. Carlotta Lampkin-Mitchell, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW IN DIVORCE Tyrone Mitchell, Defendant : NO. 09- `/ 57 6 CIVIL TERM DIVORCE COMPLAINT The Plaintiff, Carlotta Lampkin-Mitchell, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce: DIVORCE UNDER 23 Pa C S $$3301(c) AND 3301(d) OF THE DIVORCE CODE 2 3. 4. 5. 6. 7. 8. Plaintiff is Carlotta Lampkin-Mitchell, who currently resides at 50 West North Street, Carlisle, Cumberland County, PA 17013, since March 2007. Defendant is Tyrone Mitchell, who currently resides at 760 East 105th Street, Apartment 2A, Brooklyn, Kings County, PA 11236, since October 2007. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. Plaintiff and Defendant were married on April 8, 2005 in Alden, Erie County, New York. Plaintiff and Defendant have lived separate and apart since October 2007. There have been no prior actions for divorce or for annulment between the parties. 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 counseling. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. Amy akis Certi ed Legal Intern MEGA RIESMEYER Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 -r Fax: (717) 243-3639 VERIFICATION I verify that the statements made in the foregoing complaint are true and correct, to the best of my knowledge, information and belief. I understand making any false statement would subject me to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Date Plaintiff 14 Carlotta Lampkin-Mitchell FILED-O!`r'fCE OF THE PROTHONOTARy 2009 JUL 21 PFI 2: 3 8 4-1 Carlotta Lampkin-Mitchell, Plaintiff V. Tyrone Mitchell, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE NO. 09- WO CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS TO THE PROTHONOTARY: Kindly allow Carlotta Lampkin-Mitchell, Plaintiff, to proceed in forma pauperis. The Family Law Clinic, attorneys for the party proceeding in forma pauperis, certifies that we believe the party is unable to pay the costs and that we are providing free legal service to the party. Date ?,V Respec lly submitted, Amy Hi s Certifie Legal Intern Md 64, M&EGAN(RIESMEYER Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ALED-CFFICE ARy OF THE Pp,TL4-)N )T 1009 JUL 21 PM 2: 38 ?`.v1 r Carlotta Lampkin-Mitchell, Plaintiff V. Tyrone Mitchell, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN DIVORCE : No. 09-4916 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT To The Prothonotary: docket. reinstate the Divorce Complaint, filed on July 21, 2009, at the above-captioned Date: ??Od CertT)6d Legal Intern i Ann nald-Fox, Supervising Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 2699 OCT 1 9 PH 2_ 4 u Cw c a : , Carlotta S. Lampkin-Mitchell, Plaintiff V. Tyrone L. Mitchell, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN DIVORCE Defendant : NO. 09-4916 CIVIL TERM ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint filed on July 21, 2009. Date 10 /if/e9 yr ne Mitchell 760 East 105th Street, Apt. 2A Brooklyn, New York 11236 FILED-CF 1CE OF THE PROT HMTARY 2049 OCT 28 AM 11: 09 CUlV±v' i ,arm r 1 Ij 1/?JN1 ??E INSYL AI Ifil Carlotta S. Lampkin-Mitchell , : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA ~, v. :CIVIL ACTION -LAW ~_ -~R _~ IN DIVORCE ~ :,i-_: Tyrone L. Mitchell , --- `~' ~;'; Defendant : NO. 09-4916 CIVIL TERI~~~ ; _ "~ ' --' - ~, . - AFFIDAVIT OF CONSENT ~~~ s.,,ti 1. A Complaint in Divorce under §§ 3301(c) of the Divorce Code was filed on _July 21, 2009 and reinstated on October 19, 2009. 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. Date ~~ ~ ~ ~ ~~~/ otta S. Lampkin-Mitchell, Plaintiff Carlotta S. Lampkin-Mitchell , : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v• :CIVIL ACTION -LAW IN DIVORCE n Tyrone L. Mitchell , ~_ ~, ~ , Defendant : NO. 09-4916 CIVIL TEII :~ .~~-~, ~~ .'~i __ ~.. WAIVER OF NOTICE OF INTENTION TO REQUEST ~~, ENTRY OF A DIVORCE DECREE UNDER - ~•_ ~3301(c) OF THE DIVORCE CODE ~"i -~: 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 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. §4904 relating to unsworn falsification to authorities. U \ Date CT ~? l ..~~~~ arlotta S. Lampkin-Mitch 11, Plaintiff David D, (Buea Prothonotary Office of the Prothonotary Cum6erfancfCounty, Tennsyfvania 7C1rkS. Sofionage, ESQ Solicitor 69 - "' ? 4 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE —THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square 0 Suite100 9 Carlisle, TA ® None 717 240-6195 0 Ecus 717 240-6573