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HomeMy WebLinkAbout02-2772JASON MELLOTT, Plaintiff DAWN RANA MELLOTT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. O.~-.~ 77~ CIVIL ACTION LAW : 1N DIVORCE/CUSTODY NOTICE 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 at the Cumberland Cotmty Court House, High and Hanover Streets, Carlisle. 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, PA 17013 Phone: (717) 249-3166 JASON MELLOTT, Plaintiff DAWN RANA MELLOTT, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. b.2-,,¥/70. CIVIL ACTION LAW : : IN DIVORCE/CUSTODY COMPLAINT UNDER SECTION 3301(e) OF THE DIVORCE CODE 1. Plaintiff is Jason Mellott, who currently resides at 5 Fairfield Street, Cumberland County, Newville, Pennsylvania, since May, 2002. 2. Defendant is Dawn Rana Mellott, who currently resides at 102 West High Street, Cumberland County, Carlisle, Pennsylvania, since May, 2002. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiff and Defendant were married on April 8, 1993, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in this or any other jurisdiction. 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 in Divorce. II. CUSTODY The plaintiff is Jason M. Mellott, residing at 5 Fairfield Street, Cumberland County, Newville, Pennsylvania 17241. The defendant is Dawn R. Mellott, residing at 102 West High Street, Cumberland County, Carlisle, Pennsylvania 17013. Plaintiff seeks custody of the following children: Name Present Residence DOB Age Jason M. Mellott, Jr. 102 West High Street 5/29/1994 8 Carlisle, PA 17013 Andrew D. Mellott 102 West High Street 8/16/2000 1 The children were not bom out of wedlock The children are presently in the custody of Dawn R. Mellott who resides at 102 West High Street, Cumberland County, Carlisle, Pennsylvania. During the past five years, the children have resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Jason and Dawn Mellott 154B West Penn Street 1997 to Oct. 2000 Carlisle, PA Jason and Dawn Mellott 7 Betty Nelson Trailer Court, Lot 138, Carlisle, PA Oct. 2000, to May 2002 Dawn Mellott 102 West High Street May 2002- to present Carlisle, PA 17013 The mother of the children is Dawn R. Mellott, currently residing at 102 West High Street, Carlisle, PA . She is married. The father of the children is Jason Mellott, currently residing at 5 Fairfield Street, Newville, PA. He is married. The relationship of plaintiff to the children is that of father. The plaintiff currently resides with the following persons. Name Relationship Deborah McMannes Girlfriend The relationship of defendant to the children is that of mother. The defendant currently resides with the following persons. Name Jason M. MelioR, Jr. Andrew D. Mellott Melvin Moppin Relationship Son Son Boyfriend Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Protection From Abuse Final Order - December 24, 1998 Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Protection From Abuse/Custody - Filed May 28, 2002, Cross Petition filed June 4, 2002. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. The best interest and permanent welfare of the child will be served by granting the relief request because: Plaintiff has undertaken and performed the primary parental responsibilities for the children. Plaintiff is best able to provide the care and nurture which the children need for healthy development. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim N/A WHEREFORE, Plaintiffrequests this Court grant him regular and extensive visitation. Respectfully submitted, Date: June 7, 2002 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff VERIFICATION I verify that the statements made in this Complaint 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. Jason Mellott, Paintiff IASON MELLOTT PLAINTIFF V. DAWN RANA MELLOTT DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 02-2772 CIVIL ACTION LAW : : IN CUSTODY AND NOW, Tuesday, June 11, 2002 , upon consideration of the attached Complaint, it is hereby directed that pa~ties and their respective counsel appear before Jaequeline M. Verney, Esq. , the conciliator, at 4thFIoor, Cumberland County Courthouse, Carlisle on Tuesday, July09,2002 at 1:30 PM for a Pre-Hearing Custody Confe~nce. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplishe~, 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/ ]acaueline M. Vernev. Esa. ~q f -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 2 Liberty Avenue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 VINVA'I, LSNN"-Jc! JASON MELLOTT, Plaintiff DAWN RANA MELLOTT, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-2772 CIVIL ACTION LAW : : . : IN DIVORCE/CUSTODY _PETITION FOR EMERGENCY RELIEF AND NOW, comes Petitioner, Jason Mellott, by and through his privately retained counsel, Karl E. Rominger, Esquire and in support of his Petition for Emergency Relief avers as follows: 1. A Custody Complaint has been filed in this matter and is attached and incorporated by reference as Exhibit "A". 2. Your Petitioner is seeking this relief because he has been made aware of the fact that Mother is in the Cumberland County Prison on theft charges. 3. Respondent is thus believed to be incarcerated at this time. 4. Your Petitioner is concerned about the safety and well being of the children and Mother's instability. 5. Conciliation in this matter is scheduled for December 19, 2002. 6. The children are now at Petitioner's grandmother. 7. Denise Dunlap of Cumberland County Children and Youth has encouraged Petitioner to seek this relief. 8. Pending conciliation in this matter, Plaintiff request this Honorable Court enter a Temporary Custody Order granting legal and primary physical custody to Father, with supervised visitation in Mother as can be agreed upon by the parties. WHEREFORE, Plaintiff request this Honorable Court enter a Temporary Custody Order as specified above pending conciliation in this matter. Respectfully submitted, ROMINGER & BAYLEY Date: November 5, 2002 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Petitioner JASON MELLOTT, Plaintiff DAWN RANA MELLOTT, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2772 CIVIL ACTION LAW 1N DIVORCE/CUSTODY VERIFICATION KARL E. ROMINGER, ESQUIRE, states that he is the attorney for, this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to the penalties of 18 Pa. C.S. Pa.C.S. §4904, relating to unsworn falsification to authorities. in Date: Karl E. Rominger, Esquire Attorney for VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of ! 8 Pa. C. S. § 4904, relating to unsworn falsification to authorities. Date: Jason Mellott '"' JASON MELLOTT, Plaintiff Vo DAWN RANA MELLOTT, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. o ~. -~ 77~ CIVIL ACTION LAW : IN DIVORCE/CUSTODY COMPLAINT UNDER SECTION 3301(e) OF THE DIVORCE CODE 1. Plaintiff is Jason Mellott, who currently resides at 5 Fairfield Street, Newville, Pennsylvania, since May, 2002. 2. Defendant is Dawn Rana Mellott, who currently resides at 102 West High Street, Cumberland County, Carlisle, Pennsylvania, since May, 2002. 3. Plaintiff and Defendant have both been bona fide residents in the Commonwealth for at least six months immediately previous to filing of this Complaint. 4. Plaintiffand Defendant were married on April 8, 1993, in Carlisle, Cumberland County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties hereto in · this or any other jurisdiction. 6. The marriage is irretrievably broken. 7. Plaintiffhas 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 in Divorce. II. CUSTODY The plaintiff is Jason M. Mellott, residing at 5 Fairfield Street, Cumberland County, Newville, Pennsylvania 17241. The defendant is Dawn R. Mellott, residing at 102 West High Street, Cumberland County, Carlisle, Pennsylvania 17013. Plaintiff seeks custody of the following children: Name Present Residence DOB Age Jason M. Mellott, Jr. 102 West High Street 5/29/1994 8 Carlisle, PA 17013 Andrew D. Mellott 102 West High Street 8/16/2000 1 The children were not bom out of wedlock The children are presently in the custody of Dawn R. Mellott who resides at 102 West High Street, Cumberland County, Carlisle, Pennsylvania. During the past five years, the children have resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Jason and Dawn Mellott 154B West Penn Street 1997 to Oct. 2000 Carlisle, PA Jason and Dawn Mellott 7 Betty Nelson Trailer Court, Lot 138, Carlisle, PA Oct. 2000, to May 2002 Dawn Mellott 102 West High Street May 2002- to present Carlisle, PA 17013 The mother of the children is Dawn R. Mellott, currently residing at 102 West High Street, Carlisle, PA . She is married. The father of the children is Jason Mellott, currently residing at 5 Fairfield Street, Newville, PA. He is married. The relationship of plaintiff to the children is that of father. The plaintiff currently resides with the following persons. Name Relationship Deborah McMannes Girlfriend The relationship of defendant to the children is that of mother. The defendant currently resides with the following persons. Name Relationship Jason M. Mellott, Jr. Son Andrew D. Mellott Son Melvin Moppin Boyfriend Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Protection From Abuse Final Order - December 24, 1998 Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Protection From Abuse/Custody - Filed May 28, 2002, Cross Petition filed June 4, 2002. Plaintiff does not know ora person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. The best interest and permanent welfare of the child will be served by granting the relief request because: Plaintiff has undertaken and performed the primary parental responsibilities for the children. Plaintiffis best able to provide the care and nurture which the children need for healthy development. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named below, who are known to have or claim a right to custody or visitation of the child will be given notice of the pendency of this action and the right to intervene: Name Address Basis of Claim N/A WHEREFORE, Plaintiff requests this Court grant him regular and extensive visitation. Respectfully submitted, Date: June 7, 2002 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff JASON MELLOTT, Plaintiff DAWN RANA MELLOTT, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2772 CIVIL ACTION LAW IN DIVORCE/CUSTODY CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, attorney for Petitioner, do hereby certify that I this day served a copy of the Petition for Emergency Relief upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Jane Adams, Esquire 36 South Pitt Street Carlisle, PA 17013 Cumberland County Children & Youth Services West High Street Carlisle, PA 17013 Karl E. Rominger, Esquire Attorney for Petitioner Dated: November 5, 2002 JASON MELLOTT, Plaintiff Vo DAWN RANA MELLOTT, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND' COUNTY, PENNSYLVANIA : : NO. 02-2772 ,CIVIL ACTION LAW . '. : 1N DIVORCE/CUSTODY PETITION FOR EMERGENCY RELIEF AND NOW, comes Petitioner, Jason Mellott, by and through his privately retained counsel, Karl E. Rominger, Esquire and in support of his Petition for Emergency Relief avers as follows: 1. A Custody Complaint has been filed in this matter and is attached and incorporated by reference as Exhibit "A". 2. Your Petitioner is seeking this relief because he has been made aware of the fact that Mother is in the Cumberland County Prison on theft charges. 3. Respondent is thus believed to be incarcerated at this; time. 4. Your Petitioner is concerned about the safety and well being of the children and Mother's instability. 5. Conciliation in this matter is scheduled for December 19, 2002. 6. The children are now at Petitioner's grandmother. 7. Denise Dunlap of Cumberland County Children and Youth has encouraged Petitioner to seek this relief. 8. Pending conciliation in this matter, Plaintiff request this Honorable Court enter a Temporary Custody Order granting legal and primary physical custody to Father, with supervised visitation in Mother as can be agreed upon by the parties. WHEREFORE, Plaintiff request this Honorable Court enter a Temporary Custody Order as specified above pending conciliation in this matter. Respectfully submitted, ROMINGER & BAYLEY Date: November 5, 2002 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Petitioner JASON MELLOTT, Plaintiff Vo DAWN RANA MELLOTT, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-2772 CIVIL ACTION LAW .' : IN DIVORCE/CUSTODY VERIFICATION KARL E. ROMINGER, ESQUIRE, states that he is the attomey for, this action; that he makes this affidavit as attorney because he has sufficient knowledge or information and belief, based upon his investigation of the matters averred or denied in the foregoing document; and that this statement is made subject to 'the penalties of 18 Pa. C.S. Pa.C.S. §4904, relating to unsworn falsification to authorities. in Date: Karl E. Rominger, Esquire Attorney for VERIFICATION I verify that I am the petitioner and that the statements made in the foregoing Petition 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. Ja~on Mellott JASON MELLOTT, Plaintiff DAWN RANA MELLOTT, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. O ~-- ~ 7 7~ CIVIL ACTION LAW : (D Defendant : IN DIVORCE/CUSTODY COMPLAINT UNDER SECTION 3301(e) OF THE DIVORCE CODE 1. Pl~miff is Jason Mello~, who c~ently resides at 5 Fairfield Street, Cmberl~o~, Neville, Pe~sylv~a, since May, 2002. 2. Defender is Dam ~a Mellott, who c~emly resides at 102 West High S~eet, Cmberl~d Co~, C~lisle, Pe~sylv~ia, since May, 2002. 3. Pl~ntiff ~d Defender have both been bona fide residems in the Co~onweal~ for at least six monks immediately previous to filing of ~s Complaim. 4. Plaimiff~d Defender were m~ed on Apdl 8, 1993, in C~lisle, Cmberl~d Co~, Pe~sylv~ia. 5. ~ere have been no prior actions of divorce or for ~mulmem between ~e p~ies hereto in ~is or ~y o~er j~sdiction. 6. The m~age is i~e~ievably broken. 7. Pl~miffhas been advised ~at co~seling is av~lable, ~d ~at Plaimiffmay have ~e d~t to request that the Co~ require the p~ies to p~icipate in co~seling. 8. Plaimiff requests ~e Co~ to emer a Decree in Diw>rce. ° o II. CUSTODY The plaintiff is Jason M. Mellott, residing at 5 Fairfield Street, Cumberland County, Newville, Pennsylvania 17241. The defendant is Dawn R. Mellott, residing at 102 West High Street, Cumberland County, Carlisle, Pennsylvania 17013. Plaintiff seeks custody of the following children: Name Present Residence DOB Age Jason M. Mellott, Jr. 102 West High Street 5/29/1994 8 Carlisle, PA 17013 Andrew D. Mellott 102 West High Street 8/16/2000 1 The children were not bom out of wedlock The children are presently in the custody of Dawn R. Mellott who resides at 102 West High Street, Cumberland County, Carlisle, Pennsylvania. During the past five years, the children have resided with the following persons and at the following addresses: List All Persons List All Addresses Dates Jason and Dawn Mellott 154B West Penn Street 1997 to Oct. 2000 Carlisle, PA Jason and Dawn Mellott 7 Betty Nelson Trailer Court, Lot 138, Carlisle, PA Oct. 2000, to May 2002 Dawn Mellott 102 West High Street May 2002- to present Carlisle, PA 17013 The mother of the children is Dawn R. Mellott, currently residing at 102 West High Street, Carlisle, PA . She is married. The father of the children is Jason Mellott, currently res[ding at 5 Fairfield Street, Newville, PA. He is married. The relationship of plaintiff to the children is that of father. o o The plaintiff currently resides with the following persons. Name Deborah McMannes Relationship Girlfriend The relationship of defendant to the children is that of mother. The defendant currently resides with the following persons. Name Relationship Jason M. Mellott, Jr. Son Andrew D. Mellott Son Melvin Moppin Boyfi'iend Plaintiff has not participated as a party or witness, or in another capacity, in other litigation conceming the custody of the children in this or another court. Protection From Abuse Final Order - December 24, 1998 Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth. Protection From Abuse/Custody - Filed May 28, 2002, Cross Petition filed June 4, 2002. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child and claims to have custody or visitation rights with respect to the child. The best interest and permanent welfare of the child wil[l be served by granting the relief request because: Plaintiff has undertaken and performed the primary parental responsibilities for the children. Plaintiff is best able to provide the care and nurture which the children need for healthy development. Each parent whose parental fights to the child have not been terminated and the person who has physical custody of the child have been named below, who are known to have or claim a fight to custody or visitation of the child will be given notice of the pendency of this action and the fight to intervene: Name Address Basis of Claim N/A WHEREFORE, Plaintiff requests this Court grant him regular and extensive visitation. Respectftdly submitted, Date: June 7, 2002 Karl E. Rominger, Esquire 155 South Hanover Street Carlisle, ]PA 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Plaintiff JASON MELLOTT, Plaintiff DAWN RANA MELLOTT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2772 CIVIL ACTION LAW IN DIVORCE/CUSTODY CERTIFICATE OF SERVICE Karl E. Rominger, Esquire, attorney for Petitioner, do hereby certify that I this day served a copy of the Petition for Emergency Relief upon the following by depositing same in the United States Mail, first class postage prepaid, at Carlisle, Pennsylvania, addressed as follows: Jane Adams, Esquire 36 South Pitt Street Carlisle, PA 1701:3 Cumberland County Children & Youth Services West High Street Carlisle, PA 1701:3 Karl E. Rominger, Esquire Attomey tior Petitioner Dated: November 5, 2002 JASON MELLOTT, Plaintiff DAWN RANA MELLOTT, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2772 CIVIL ACTION LAW IN DIVORCE/CUSTODY ORDER OFCOURT Distribution: //~arl E. Rominger, Esquire /ane Adams. Esquire -'~ ,,~umberland County Children & Youth Services JASON MELLOTT, Plaintiff Vo DAWN RANA MELLOTT, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02-2772 CIVIL ACTION LAW .' . : : IN DIVORCE/CUSTODY AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on June 7, 2002. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry ora 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: ,//- _5'"- ason Mellott, Plaintiff JASON MELLOTT, Plaintiff Vo DAWN RANA MELLOTT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-2772 CIVIL ACTION LAW IN DIVORCE/CUSTODY WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE I. l consent to the entry ora final decree of divorce without notice. 2. I understand that 1 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. 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: ason Mellott, Plaintiff JASON MELLOTT, Plaimiff DAWN RANA MELLOTT Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : NO. 02 - 2772 Civil Term : : IN DIVORCE/CUSTODY ACCEPTANCE OF SERVICE PURSUANT TO PA.R.C.P 4 02(B) AND PA.R.C.P. 1920.4 I, Dawn Rana Mellott, Defendant in the above-captioned matter, received a copy of the Complaint on ~a~lt 0'~, g/t0, olt0 ~, and I hereby accept service of the Complaint in the I ' above-captioned matter. Date://~./5-C~r~ Dawn Rana Mellott, Defendant DE O02 JASON MELLOTT, Plaintiff DAWN RANA MELLOTT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02 - 2772 .CIVIL 1N CUSTODY COURT ORDER AND NOW, this ~k day of December, 2002, upon consideration of the attached Custody Conciliation Report and in recognition of the fact that the two minor children involved in this case are already the subject of a dependency proceeding at Juvenile Docket Number 2000 - 0100, the Petition of the Father in this case is dismissed at this time. Father may file a petition at the Juvenile Docket Number seeking temporary custody or custody of the minor children. CC: ~ane Adams, Esquire Michael Ware, Esquire JASON MELLOTT, Plaintiff V DAWN RANA MELLOTT, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 02 - 2772 CIVIL : IN CUSTODY Prior Judge: CONCILIATION CONFERENCE SUMMARY REPORT IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: This case comes before the conciliator on petition of the Father for visitation. It was determined at the custody conciliation conference that the two children were previously found to be dependent at Docket Number 2000 - 0100 - Juvenile. On that basis, the conciliator is of the opinion that the Father must initiate a petition at the Dependency Proceeding Docket Number to ensure that Children's Services and other relevant parties are involved in a resolution of that issue. 2. The conciliator recommends the entry of an order in the form as attached. JASON MELLOTT, Plaintiff Vo DAWN RANA MELLOTT Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02 - 2772 Civil Term · IN DIVORCE/CUSTODY PRAEClPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the Court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under .~3301(c) of the Divorce Code. 2. Date and manner of the service of the Complaint: Delivered by certified mail, restricted delivery, return receipt requested, delivered on: ...) ~j~ .p___ 1 ~)~ %-~OO~.. - ~ 3. Date of execution of the affidavit of consent required by 3301(c) of the Divorce Code: By Plaintiff: J' 1 ~-"-- O ~ By Defendant: I I ' Related claims pending: None· 5. Date Defendant's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: J J · t~ ,O~ Date Plaintiff's Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: I~ · I~' o~ Date: I/' //~J~ne Ad~ ~,j[.D. No. 79465 36 S. Pitt Street Carlisle, Pa. 17013 (717) 245-8508 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Jason Mellott, Plaintiff VERSUS Dawn Rana Mellott, Defendant NO. No. 02 - 2772 Civil Term AND NOW,__ DECREED THAT DeCREe IN DIVORCE Jason Mellott , IT IS ORDERED AND __, PLAINTIFF, AND Dawn Rana Mellott , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. 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; None. ATTEST: PROTHONOTARY