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Home My WebLink About10-1395CD TI, L-r c! ? y Brian K. Zellner, Esquire Supreme Court ID #59262 Hynum Law 2608 North 3'" Street Harrisburg, PA 17110 (717) 7741357 ? L' 3 r1 F ir E3 ? L? t ?. ROBERT MELLOR, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 10 -13QS Civi I Term AMY MELLOR, CIVIL ACTION - LAW Defendant 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 within twenty (20) days. You are warned that if you fail to do so, the case may proceed without you and 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, High & Hanover Streets, Carlisle, PA 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. Cumberland County Bar Association 2 Liberty Avenue, Carlisle, Pennsylvania 17103 Telephone Number (717) 249-3166 *3sa.oo Pb ATry cv.* A 7qo zrr* ass 0103 Brian K. Zellner, Esquire Supreme Court ID #59262 Hynum Law 2608 North 3'" Street Harrisburg, PA 17110 (717) 774-1357 ROBERT MELLOR, Plaintiff V. AMY MELLOR, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 16 131 CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Robert Mellor, an adult individual residing at 2504 Warren Way, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 2. Defendant is Amy Mellor, an adult individual residing at 46 Burwick Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17050. 3. Plaintiff has been bona fide resident in the Commonwealth of Pennsylvania for at least six (6) months prior to filing this complaint. 4. The Plaintiff and Defendant were married on May 13, 2005 in Las Vegas, Nevada. 5. The parties separated on January 16, 2010. 6. No previous divorce action has been filed by either party in this jurisdiction or any other jurisdiction. 7. Neither Plaintiff nor Defendant is in the military or naval service of the United States or its allies within the provisions of the Soldiers' and Sailors' Civil Relief Act of the Congress of 1940 and its amendments. 8. Plaintiff has been advised that counseling is available and that Plaintiff has the right to request that the court require the parties to participate in counseling. COUNT I - DIVORCE NO FAULT 9. The averments in paragraphs 1 through 8, inclusive, of Plaintiffs Complaint are incorporated herein by reference thereto. 10. The marriage is irretrievably broken and no possibility of reconciliation exists. WHEREFORE, Plaintiff, Robert Mellor, prays this Honorable Court to enter judgment: A. Awarding Plaintiff a decree in divorce in his favor in accordance with §3301 of the Pennsylvania Divorce Code. B. Awarding other relief as the Court deems just and reasonable. Date: -44 3 oo /f- L ?L- Bna-nK. Zellner, Esquire Supreme Court ID #59262 Hynum Law 2608 North 3rd Street Harrisburg, PA 17110 (717) 774-1357 Attomey for Plaintiff Brian K. Zellner, Esquire Supreme Court ID #59262 Hynum Law 2608 North Td Street Harrisburg, PA 17110 (717) 7741357 ROBERT MELLOR, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. AMY MELLOR, : CIVIL ACTION - LAW Defendant : IN DIVORCE VERIFICATION I, Robert Mellor, hereby certify that the facts set forth in the foregoing Complaint are true and correct to the best of my knowledge, information and belief. I understand that any false statements made herein are subject to penalties of 18 Pa.C.S.A. Section 4904 relating to unsworn falsification to authorities. Date. 2 ?( Ro AeMe for ROBERT MELLOR, IN THE COURT OF COMMON PLEAS Plaintiff :CUMBERLAND COUNTY, PEI~VSY,~,VANIA ° n c.~ v. NO. 10-1395 ~`~ ~T? ~ AMY MELLOR, :CIVIL ACTION -LAW ~-"~ Defendant IN DIVORCE ~ '-~ -~ =~ ~= .... ACCEPTANCE OF SERVICE ~ .c -~ I hereby accept service of the Divorce Complaint filed in the above-captioned matter on behalf of Defendant, AMY MELLOR, and certify that I am authorized to do so. Date: ~T ~ ~l ~ Amy el or, ndant 46 Burwick Mechanicsburg, PA 17050 Robert Mellor IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Amy Mellor NO. 10-1395 DIVORCE DECREE ~-,3: a~ ~~ ~1. AND NOW, ~tw~4-/~ ,c~'da/~ , it is ordered and decreed that Robert Mellor plaintiff, and Amy Mellor ,defendant, are divorced from the bonds of matrimony. Any existing spousal support order shall hereafter be deemed an order for alimony pendente lite if any economic claims remain pending. The court retains jurisdiction of any claims raised by the parties to this action for which a final order has not yet been entered. Those claims are as follows: (If no claims remain indicate "None.") A Marital Settlement Agreement is incorporated but not merged into this divorce decree. By the , Att J. Prothonotary (~ • [ 7• (O ~'~- CoPc~ Mop.;\ e a ~-o N-~ Huhn t~~ o~ ~.s [.~ • 1?• t d ~o-t; c~ rte;, tee "~' ~~ .,