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Home My WebLink About05-5195OLGA EMMA NOBLE-DITLOW: IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. ?C1JS- JT/gj ARTHUR THOMAS DITLOW, Defendant : 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 grounds for the divorce are 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 County Courthouse. 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 LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 NOTICIA Le han demandado a usted en Is corte. Si usted quiere defenderse de estas demandas expuastas en las paginas siguientes, usted tiene viente (20) dias de plazo at partir de Is fechs de Is demands y Is notificacion. Usted debe presentar una apariencia escrita o en persona o por abogado y archivar en Is corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisdao que si usted no se defiende, Is corte tomara medidas y puede entrar una orde contra usted sin previo aviso o notificacion y por cualquier queja o alivio que es pedido en In peticion de demands. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABODAGO IMMEDIAMENTE. SI NO TIENNE ABOGAD O SI NO TIENNE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONE A LA OFICINA CUYA PUEDA CONSEGUIR ASSISTENCIA LEGAL: CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Darrell t -6ethlefs, Esquire Attorney Id. No.: 58805 2132 Market Street Camp Hill, PA 17011 (717) 975-9446 Attorney for Plaintiff OLGA EMMA NOBLE-DITLOW: IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 0,5' ?/ 4S&-,?j Ttw ARTHUR THOMAS DITLOW, Defendant : CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(C) OR SECTION 3301(D) OF THE DIVORCE DECREE CODE AND NOW, comes the Plaintiff, Olga Emma Noble Dillow, by and through her attorney, of The Law Office of Darrell C. Dethlefs, seeks to obtain a Decree in Divorce from the Bonds of matrimony with the above-named Defendant and in support of her Complaint avers the following: Plaintiff, Olga Emma Noble-Ditlow, is an adult individual, who currently resides at 2315 Kent Street, Camp Hill, Cumberland County, Pennsylvania. The Plaintiffs social security number is 213-46-7194. Defendant, Arthur Thomas Ditlow, is an adult individual, who currently resides at 2315 Kent Street, Camp Hill, Pennsylvania 17011. Both Plaintiff and Defendant have been bonified residents of the Commonwealth of Pennsylvania for at least six (6) months immediately preceding the filing of this Complaint. 4. The parties were married on July 15, 1999 in Cumberland County, Pennsylvania. 5. The Plaintiff and Defendant are citizens of the United States of America. 6. The Plaintiff and Defendant are not members of the Armed Services of the United States or any of its allies. Plaintiff has been advised of the availability of counseling and that he and the Defendant may have the right to request that the Court require the parties to participate in such counseling. COUNTI REQUEST FOR DIVORCE DUE TO IRRETRIEVABLE BREAKDOWN UNDER 3301(C) OF THE DIVORCE CODE The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 9. The marriage of the parties is irretrievably broken. 10. After ninety (90) days have elapsed from the date of the filing of this Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that the Defendant may also file such an affidavit consenting to a divorce. 11. Plaintiff has been advised of the availability of counseling and that he and the Defendant have the right to request the Court to require the parties to participate in such counseling. WHEREFORE, if both parties file affidavits to divorce after ninety (90) days have elapsed from filing of the Complaint, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(C) of the Divorce Code. COUNT II REQUEST FOR DIVORCE DUE TO IRRETRIEVABLE BREAKDOWN UNDER 3301(D) OF THE DIVORCE CODE 12. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 13. The Marriage of the parties is irretrievably broken. 14. After a period of two (2) years has elapsed form the date of separation, Plaintiff intends to file his affidavit of having lived separate and apart. 15. Plaintiff has been advised of the availability of counseling and the Plaintiff and Defendant have the right to request the Court to require parties to participate in such counseling. WHEREFORE, if two (2) years have elapsed from the date of separation and Plaintiff has filed his affidavit, Plaintiff respectfully requests the Court to enter a Decree of Divorce, pursuant to 3301(D) of the Divorce Code. COUNT III REQUEST FOR EQUITABLE DISTRIBUTION UNDER SECTION 3502 OF THE DIVORCE CODE 16. The prior paragraphs of this Complaint are incorporated herein by reference thereto. 17. Plaintiff and Defendant have acquired property, both real and personal, during their marriage. 18. Plaintiff and Defendant have been unable to agree as to an equitable distribution of sai property. WHEREFORE, Plaintiff respectfully request this Honorable Court to enter an Order istributing all of the aforementioned property, real and personal, as the Court may deem equitable anc ast, plus costs. _ )ate By: DayfeWC. Dethlefs, Esquire Attorney Id. No.: 58805 2132 Market Street Camp Hill, PA 17011 (717) 975-9446 Attorney for Plaintiff OLGA EMMA NOBLE-DITLOW: IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. ARTHUR THOMAS DITLOW, Defendant : CIVIL ACTION - LAW : IN DIVORCE VERIFICATION I hereby verify that the statements of fact made in the foregoing Complaint in Divorce, are true and correct to the best of my knowledge, information and belief. I understand that any false statements therein are subject to the criminal penalties contained in 18 Pa C. S. Section 4904, relating to unswom falsification to authorities. Date: ?`1 Olga E Noble-Ditlow d k ?4 ( 1 nor p 1 >? L_l?« N Curtis R. Long Prothonotary (Pftice of the Protbonotarp QCUltTbprlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor Ck5 -?? Qs CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER 2008 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2 BY THE COURT, CURTIS R. LONG PROTHONOTARY n„e r`ro,rrhn„cP Cn„are • Carlisle. Pennsvlvania 17013 • (717) 240-6195 • Fax (717) 240-6573