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Home My WebLink About09-3249 TAB OM & N ULAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 MATTHEW H. TILDEN, Plaintiff V. JESICA A. TILDEN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 4 1- 3 q Ct <? t.l T - CIVIL ACTION - LAW IN DIVORCE 1. Plaintiff is Matthew H. Tilden, who currently resides at 22 Buttonwood Lane, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Jesica A. Tilden, who currently resides at 322 Walnut Lane, Carlisle, Cumberland County, Pennsylvania. 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 March 13, 2007 at Carlisle, Cumberland County, Pennsylvania. COUNT I - DIVORCE 5. Paragraphs one (1) through four (4) of this Complaint are incorporated herein by reference as though set forth in full. 6. There have been no prior actions of divorce or for annulment between the parties. 7. Divorce is sought pursuant to the provisions of the Divorce Code, §§ 3301(a), (C) and 3301(d), in that: a. Plaintiff is the innocent and injured spouse as the Defendant has committed adultery. b. The marriage is irretrievably broken. c. Plaintiff and Defendant have lived separate and apart since April 20, 2009 and continue to do so. 8. 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. COUNT II - EQUITABLE DISTRIBUTION 10. Paragraphs one (1) through nine (9) of this Complaint are incorporated herein by reference as though set forth in full. 11. Plaintiff and Defendant have acquired property, both real and personal, during their marriage from March 13, 2007, until April 20, 2009, the date of their separation, which property is "marital property". 12. Plaintiff and Defendant may have owned, prior to marriage, property which has increased in value during the marriage and/or which has been exchanged for other property, which has increased in value during the marriage, all of which property is "marital property". 13. Plaintiff and Defendant have been unable to agree as to an equitable division of said property prior to the filing of this Complaint. WHEREFORE, the Plaintiff requests this Honorable Court to equitably divide all marital property. DATE b I2 I CA Respectfully submitted, ABom & KUTULAKIS, L.L.P. Michelle L. So er, Esquire Attorney ID No. 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for the Plaintiff I, MATTHEW H. TILDEN, 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 unsworn falsification to authorities. Date MATTHEW H. TILDEN FILED ll-=, ?' r " ?'TA4Y 2004 MAY 22 AN 8: 5 I $ No4. 50 Pt P-7" co 1599 Rl* aa5'g3y add"? ? i '"% MATTHEW H. TILDEN, Plaintiff V. JESICA A. TILDEN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 2009-3249 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE I, Michelle L. Sommer, Esquire, hereby certify that I did serve a true and correct copy of the Complaint under Sections 3301 (a), (c) and (d) 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 Jesica A. Tilden, at Carlisle, Pennsylvania, addressed as follows: Jesica Tilden 322 Walnut Lane Carlisle, PA 17015 Return card acknowledging receipt on May 23, 2009 is attached as Exhibit "A". Date: ABom&KUTVLAKi4 LLP "- Michelle L. Sommer, squire Attorney I.D. No: 93034 2 West High Street Carlisle, PA 17013 (717)249-0900 Attorney for Plaintiff op "ft M rtp W b m 1, 2, and 3. Afro c ompiete lWnA N Restricted D*#wy is deWred. ,PeMt your nine and address on the reverse sa that we r?rl mtum the card to you. ¦ Mach this card to the back of the mailoece, or on the front N space permits. 1. ArNde Addressed to: Jess I C.a T,1 dic-'ri 322. IJJ? nw-+ L.c? ne C,C?.i- l i s I PA ! ?0? 5 A- 801d#. X by( D. Is deiwry address dM If YES, enter d*4wy V,-r- lr,-l 3. Ssrvios Type 0 csrmusd Nisi 0 Express Mau 0 Raplatered 0 Pow PwoW for Merdwrdise 0 insured Mau 0 C.O.D. 4. Restricted Deuwry? lift Fee) 0 Yes 2. Article Number (NWNJNrlf.maei+ilorra" 7008 1830 0003 5942 5043 PS Form 3811, Febtary 2oD4 Darn.emm Ibkm ReoW EXHIBIT `A" Amm r FILE -+;., ?E 27 M n, s r,'nf4 ti,ry1P e. ABOM CSZ' j~LITLILAKIS Michelle L. Sommer, Esquire Attorney I.D. #: 93034 2 West High Street Cazlisle, PA 17013 (717)249-0900 MATTHEW H. TILDEN, Plaintiff v. JESICA A. TILDEN, Defendant IN THE COURT OF' COMMON PLEAS CUMBERLAND COUNTY, PA NO. 09-3249 CIVIL ACTION -LAW IN DIVORCE PRAECIPE TO WITHDRAW TO THE PROTHONOTARY: Please withdraw the Divorce Complaint in the above-referenced matter. Respectfully submitted, ABOM & KUTVLAxis, L.L.P. DATE ~V ~J J ~~.. Michelle L. Sommer, Esquire Attorney ID No. 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for the Plainti~ CERTIFICATE OF SERVICE AND NOW, this 13`'' day of October, 2009, I, Michelle L. Sommer, Esquire, of Abom & Kutulakis, L.L.P., hereby certify that I did serve a true. and correct copy of the foregoing Praecipe to Withdraw, by depositing, or causing to be deposited, same in the United States Mail, First-class mail, postage prepaid addressed to the following. Jesica Tilden 322 Walnut Lane Carlisle, PA 17015 Respectfully submitted, BOM drKUTU~ls, L.L.P. ~~ Michelle L. S er, Esquire Supreme Court ID 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plainti~ FILE[;-~:;~~=riCE 2009 OCT 13 Phi 4~ 06 r-n ; ~. ~.-,', ;~~~ rr r I~Ci'vi'Ji.~ Y ~.~~r'ti~ir~!