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HomeMy WebLinkAbout02-3932DANIELLE L. TILDEN, Plaintiff DANE TILDEN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION ~ LAW NO. 02- 3~3~ CML TERM IN DIVORCE 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 Huntingdon County Court House, 223 Penn Street, Huntingdon. 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 DANIELLE L. TILDEN, Plaintiff DANE TILDEN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 02- CML TERM : IN DIVORCE COMPLAINT UNDER SECTION 3301(C) OF THE DIVORCE CODE I. Plaintiffis Danielle L. Tilden, who currently resides at 414 East Old York Road, Carlisle, Cumberland County, Pennsylvania, since February, 2002. 2. Defendant is Dane Tilden, who is currently an airman in the United States Air Force, stationed at Ramstein, Germany. His mailing address is PSCI, Box 2863, APO AE 09009. 3. Plaintiffhas been a bona fide resident in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The plaintiffand defendant were married on July 21, 2001 at Mechanicsburg, Cumberland County, Pennsylvania. There have been no prior actions of divorce or for annulment between the parties. The marriage is irretrievably broken. 7. Plaintiffhas been advised that counseling is available and the plaintiff may have the right to request that the court require the parties to participate in counseling. 8. Plaintiffrequests the court to enter a decree of divorce. I verify that the statements made in this Complaint are true and correct. 1 understand that false statements herein are made subject to the penalties of 18 Pa. CS. §4904 relating to unsworn falsification to authorities. · le L. Tilden, Plaintiff LAW OFFICES OF PAUL BRADFORD ORR Attorney for Plaintiff 50 East High Street Carlisle, PA 17013 Telephone: (717) 258-8558 Supreme Court I.D. No. 73471 2 DANIELLE L. TILDEN, Plaintiff VS. DANE TILDEN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW No. 02-3932 Civil Telm : IN DIVORCE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) AND NOW, this 18t~ day of September, I Gregory L. Cutler, Esquire, attorney for Christopher J. Zastrow, Plaintiff, in the above-captioned action, hereby swear that I have served a true copy of the Divorce Co~i~olaint, executed bythe Plaintiff in the above-captioned matter, upon the Defendant on September 3, 2002 by depositing the same in the U.S. Mail, postage prepaid, certified, return receipt requested. The original return receipt card signed bythe Defendant indicating service was effected, is marked Exhibit "A", attached hereto and made a part hereof. LAW OFFICES OF PAUL BRADFORD ORR 50 East High Street Carlisle, PA 17013 (717) 258-8558 I.D. # 73471 · Complete items 1, 2, and 3. Also eomP~e ~o that we can return the c, ard to Y°U' · Attach this cmdto the back of the mallplece, la dellv~/addm~ dill.mat f~om Item 17 r'l yea If YE8. ent~' delivery addm~ below: I-1 No I [] In~d Mall 1'9 C.O.D. ' 4. ReetrlctedDellve~7 (F--,.'~aFee) ~-- 2510 0006 5891 3459 2. Nticle Number 7001 -- ~ (rratl,,~' ~ s~rv~c~/~J3~) _ =..._..._.-,-,-,-. 102~1-M-1424 "-~'~"~ 3811 , Mamh 2001 ......... EXHIBIT A DANIELLE L. TILDEN Plaintiff V. DANE TILDEN, Defendant : IN THE COURI[~ OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO 02-3932 : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on (August 16, 2003). 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: L.~- ~-- C~_I - DANIELLE L. TILDEN DANIELLE L. TILDEN, DANE TILDEN Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO 02-3932 : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVORCE CODE 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. t/DANIELLE L. TILDEN DANIELLE L. TILDEN Plaintiff V. DANE TILDEN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO 02-3932 : IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of~the Divorce Code was filed on (August 16, 2003). 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. Dane Tilden DAN1ELLE L. TILDEN, DANE TILDEN Plaintiff Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO 02-3932 : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER § 3301(c) OF THE DIVOI~,CE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning ali~nony, 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 119 Pa. C.S. §4904, relating to unsworn falsification to authorities. DANE TILDEN DANIELLE L. TILDEN, Plaintiff DANE TILDEN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA · ' CIVIL DMSION : NO.02-3932 CIVIL ACTION LAW PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: decree: Transmit the record, together with the following information, to the Court for entry of a divorce Ground for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. Date and manner of service of the complaint: August 16, 2002, by U.S. Mail, postage prepaid, certified, return receipt requested. 3. Date of execution of the affidavit of consent required by Section 3301(c) of the Code: by the Plaintiff on April 14, 2004; by Defendant on April 13, 2004. 4. Related claims pending: NONE 5. Date Plaintifffs Waiver of Notice in §3301(c) Divorce was filed with the Prothonotary: April 15, 2004. 6. Date Defendant's Waiver of Notice in §3301(c) Divome was filed ~th the Prothonotary: April 15, 2004. Date: April 15, 2004 Divorce LAW OFFICES OF PAUL BRADFORD ORR 50 East High Street Carlisle, PA 17013 (717) 258-8558 IN THE COURT Of COMMON PLEAS OF CUMBERLAND COUNTY STATE Of ~~, PENNA. Daniell~ L. TildPn VERSUS Dane S, Tilden No. 2002-3932 DECREE IN DIVORCE AND NOW, //~-,.. ~ 2.0 DECREED THAT Danielle T,. P~..lO"/ , IT IS ORDERED AND , PLAINTIFF, aND Dane S. Tilden ,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; BY THE COURT: ATTESTS:' _/~ PROTHONOTARY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW Plaintiff VS. : FILE NO. : IN DIVORCE Defendant : 20_o NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff/Defendant in the above matter, having been granted a Final Decree in Divorce on the ~2 ~ .dayof ~')1-~ [ , hereby elects to resume the prior surname of ~) ~ X"X~"t~L(Jk ~') 0k~t (x ~" , and gives this written notice pursuant to the provisions of 54 P.S. 704. . .---3 ,- DATE: 5" ~- 0 -------'- Signature COMMONWEALTH OF PENNSYLVANIA : : SS. COUNTY OF CUMBERLAND : On the '~'~'- day of ~ , 20 ~4' before me, a Notary Public, personally appeared the above affiant kn~own to ]me to be the person whose name is subscribed to the within document and acknowledged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and official seal. NOTARIAL SEAL CLAUDIA A. BREWBAKER, NOTARY PUBLIC Carlisle Bom, Cumberland County My Commission Expires April 4, 2005 Notary Public