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