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Home My WebLink About09-8640n I? MATTHEW H. TILDEN, Plaintiff V. JESICA A. TILDEN, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. Oq - S&O aivi l -Ferm CIVIL ACTION - LAW 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. 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 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, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYERS'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 32 SOUTH BEDFORD CARLISLE, PA 17013 (717) 249-3166 OR (800)990-9108 OM CSC T; A U 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 C?UIc{I NO. 4 y- 3 646 CIVIL ACTION - LAW IN DIVORCE COMPLAINT 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. w 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(c) and 3301(d), in that: a. The marriage is irretrievably broken. b. 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 November 16, 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 12115 ILA Respectfully submitted, ABOM & KUTUL4u,? 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 VERIFICATION 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 2L& ?? MATTHEW H. TILDEN 14 CERTIFICATE )F SERVIC AND NOW, this 15th day of December, 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 Divorce Complaint, upon the Defendant by depositing, or causing to be deposited, same in the United States Mail, Certified, First-class mail, postage prepaid addressed to the following: Jesica A. Tilden 322 Walnut Lane Carlisle, PA 17015 Respectfully submitted, ABOM & KuTur?ws, LLP. Michelle L. So r, Esquire Supreme Court ID No. 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaintiff FILED "l?JE r;F T; ice' E:::'??OTARY 2009 DEC 15 PIN 3: 38 I NT 3Fi 1. So PQ ATty Clcv aa33 er* a3so 8A laddn C? MATTHEW H. TILDEN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PA V. NO. 2009- 8640 JESICA A. TILDEN, CIVIL ACTION - LAW Defendant IN DIVORCE I, Michelle L. Sommer, Esquire, hereby certify that I did serve a true and correct copy of the Complaint under Sections 3301(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 December 23, 2009 is attached as Exhibit "A". Date: (2-1-2-q 101 ABOM & KUTULA"S, LLP *' kmfiulvo Michelle L. So e r, Esquire Attorney I.D. No: 93034 2 West High Street Carlisle, PA 17013 (717)249-0900 Attorney for Plaintiff v • Nois t 2, „and 3. Also complete ??'E very 19 desirod. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the maiiplece, or on the front if space permits. 1. Article Addressed to: _ k 13 X Agent ?, , n i An 0 An rl e BB., Oec#ed by (A*Od Nana) C. Date of D*my t ? &-1 1 lC: 0 D. Is dd Kvy address dffWent Uom Item 1? ? Yes If YES, order delivery address below: ? No 3. Service Type V-Qwthw Mail ? Express Mail rb Registered ? Retum Receipt for Merchandas ? Irmured KW ? C.O.D. 4. Reetrfcted Delivery? (Extra Fee) ? yes 2' Article Number 7008 1,830, 0003 5942 5333 (fh?terfiwn sra?v?a Wdi PS Foen 1, FWxWV2M Dansaro bhetrn fieoelpt 102506-02-M-1540 EXHIBIT `A" 2 0 G 9 DcC 29 P 1 2: w 1 }, ? COAL, _ ABOM ~' 1CT.ITLILAKIS 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 f=1LE~-OFF1C1* ~~ T~°~' "~ ~~ 7";~'~ I~Q T~ E2 Y 20;~ ~'CT ~ 5 Phi 3~ ~~2 ~11~`i~~ ~? e^~~D C(~l1q~Y IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 2009- 8640 CIVIL ACTION -LAW IN DIVORCE 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. Date: l~"/~ ~ j~ Jesica .Tilden, Def ndant OM ~' LILAKIS Michelle L. Sommer, Esquire Attorneyl.D. #: 93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 MATTHEW H. TILDEN, Plaintiff v. JESICA A. TILDEN, Defendant D~ TP ~ ~ T~~ TAY ZOf fl ~~~ ! S ~~¢i 3~ 4 ! ~'~P~~,'S YLrV;~~~lld IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 2009- 8640 CIVIL ACTION -LAW IN DIVORCE 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. Date: / y~l ~ ~%~.. Matthew H. Tilden, Plaintiff ABOM CS2' j~LITLILAKIS 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 FiL~O'OF~1C~ za~o acT ~ s P~~ ~: ~ ~ CU~-~1ZLA~~r~J COU~'iTY P~P~SYt~/AIE~, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 2009- 8640 CIVIL ACTION -LAW IN DIVORCE 1. A Complaint in divorce under §§ 3301(c) and 3301(d) of the Divorce Code was filed on December 15, 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. -\ l0-1~- JC7 Date: sica .Tilden OM ~' LILAKIS 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 ~'ILED-OFFICE Dr T~tE Pg~JTf'Q~iOTAf~Y 254 ACT 15 i'~j 3~ ~ 1 '.9F°`®~g~L~y~islDr CQI~A+'~TY f ~E°~E~~ i LY~~~i~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 2009- 8640 CIVIL ACTION -LAW IN DIVORCE 1. A Complaint in divorce under § § 3301(c) and 3301(d) of the Divorce Code was filed on December 15, 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: O 0 Matthew H. Ti den OM ~' KuTU~Is .~ Michelle L. Sommer, Inquire Attorney LD. No.: 93(134 2 West High Street Carlisle, Pennsylvania 17013 (717) 249-09110 MATTHEW H. TILDEN, Plaintiff v. JESICA A. TILDEN, Defendant ..F~~ED,QFFICF DF 7F,~ P~1~~10~~Q7AP,Y 201-~ ~~7 I S Ft§t 3~ ~~3 CU~`~El. ~~ ~o~D C0~11~7Y PE~!SYLV.y~lA IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PA NO. 2009- 8640 CIVIL ACTION -LAW IN DIVORCE To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1) Ground(s) for Divorce: a) Irretrievable Breakdown under ~3301(c) of the Divorce Code. 2) Date and manner of service of the Complaint: a) December 23, 2009, by Certified Mail/Restricted Delivery. 3) Date of execution of the Affidavit of Consent required by ~3301(c) of the Divorce Code: a) by Plaintiff October 14, 2010; by Defendant: October 15, , 2010 4) Related claims pending: None 5) Date Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: a) by Plaintiff October 15, 2010; by Defendant: October 15, 2010 Respectfully submitted, - DAB to~~5~10 Bohr ~ Kvrvz.Axrs, L.L.P ~- Michelle L. So r, Esquire Supreme Court ID #93034 2 West High Street Carlisle, PA 17013 (717) 249-0900 Attorney for Plaint MATTHEW H. TILDEN V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA JESICA A. TILDEN ' No. 2009-8640 DIVORCE DECREE AND NOW, G~'+ ~ ~~' +, zee ip , it is ordered and decreed that MATTHEW H. TILDEN plaintiff, and JESICA A. TILDEN ,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.") NONE By the Court, J. ~~ v ~~ rr ~ ~~