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Home My WebLink About00-00024 ~'! ~ ~~ , ~\ ~.~ i ~ ~.;; I t'" ~ ;~i i Y' ~ ~."" ~.~ ~ ~ ~.~ ~.~ ;l ~.~ ~ ~ ,', ~ ;."~ ~ ~? ~,~ ~ ~I kll ~! ill ! ' ~'~'J' ~~)',,',~~),,':~~}- -,.:.}" "":'C~~~.~.., ~i '.') ~) ~."" i j,'~ ~ ; fiij ~~ :...: 00 ,~. i "'.i;' ~ r'~ i;~.. ~ ;~1 ~. ? ~ y ~ ;.~ t'~ ~ :,;~::~i<:'<.~::':;:::+::;',:::~::4''';f.::'::<(_X.~~::+:::''':'~~X~~-::(I>::i-H~~~;;~,~3>::~::.~~::<:;;';::":~)!Z.:::~~~ ~ i ~.~ ~.~ ~ ,~, ;.~ ill .,~,; r \ t ~ . :-!::03>:.:::~:::+:.,' :,:{.~~~ ::'~.::},:::~:::~~::~.::.;.X ;'~.::or;~::::+~~:;+z..;: >{~::O~:J:~)(>~~+:~'L: ;:"C<:'~:::.~~':;~::~;';~~'" ~ ~.I ~ ~.~ k': ~ ;~~ ~ IN THE COURT OF COMMON PLEAS ~I ~ t~j ~ ~ OF CUMBERLAND COUNTY STATE OF PENNA. 000"0" ." o "Mar:y: . Cather,ine..F.ahnestockT ......" ..", "", .."".., '..,." 0"'....' ,J?,l?,i,Il1:,:j.,!",:r:."...",...u, ,... II I No. ,..2,0.00._2.4.. ,...,............x161: Versus ",.........,.... c;l1,?'ci" ,11..:io",h,?~.:L" ,F.~.I)'!"e,~ t.9g,IsL.. ",....,.." h.........' ,Def,endant,..", DECREE IN DIVORCE AND NOW, ,., .to\=>.\,lc.~.~~..2........, , XlX'}{.:;2:.<:;:>?<? it is ordered and decreed that .":I':';;\'. .c::,:,~?e;:r;~~.e. X~~.~e;':l~?c:J<:.... .... .... . ... ", plaintiff, and, . . , C)1,,:d, !'1i."J:1a~l. X?-J1."':€!'?1:S'.c:l<;. , . . . . . . . . . . . . ' . . . . . . . . . " defendant, are divorced from the bonds of matrimony. The court retains jurisdiction of the following daimswhich have been raised of record in this action for which a final order has not yet been entered; The property settlement is incorporated but not merged into ,>........ .......-........ .... ............ ........ .... .... ..... ....... ,. ", decree. By Attest: ~ ~.~ X ~ ;~ ~ ~":~ ~ if~ ~~~ ~ ~ ~ 1;-' l~ ~'1 ~ ~.~ ~~ ~ :..; i!l ~i ~ ~.~ ~ '~ i:"~ ~ ~ ~~;; ~ I ,..,; ;"~ fI! M ~ ~ ~'1 ~.~ ~ :,...: " "'~<i ~ A , ~ v ;.',~ ~ ~.; ill ,', ~ ~ ~.~ '. ~ ~.~ ~ ~.~ J. I ~ ~ I v ~ ~.~ ~ .~ -~-"'--._------~-----._-_. ~. ,{.,:CX.;' ,~{";...,,{'t!-;.::..;-:~.x.~{~.: .{~;., _:.-:~.;-..{f$.-.>:~.:' ~J," '.{+),', (.~'" (.;t,: "(.;+.. Of.':": .::..:. {~',. 1/3 -61:? /('.3 .pp l .-1. '...., ~~ , c._ ~_;. . "i'-, &/ ~ #~ ~4 RS)~ /tcqJa ~~ ~ a4 ~ 1 ' . , ? , b , < .. MARrf AL SETTLEMENT AGREEMENT THIS AGREEMENT made this &'r;.vJ day of O~ ' 2000. by and between CHAD M. FAHNESTOCK, of Cumberland County, Pennsylvania, and MARY C. FAHNESTOCK, of Cumberland County, Pennsylvania; WITNESSETH: WHEREAS, Chad M. Fahnestock (hereinafter referred to as "Husband"), social security number 183-52-6441, was born ou May 19, 1971, and currently resides at 2908 Elm Street, Harrisburg, Dauphin County, Pennsylvania 17103: WHEREAS, Mary C. Fahnestock (hereinafter referred to as "Wife"), social security number 202-66-2610, was born on January 3,1971, and presently resides at 915 Apple Drive, Mechanicsburg, Cumberland County, Penusylvania 17055; WHEREAS, the parties hereto are husband and wife, having been lawfully married on September 26, 1998 in Cumberland County, Pennsylvania; WHEREAS, the parties have lived separate and apart since on or about November 4, 1999; WHEREAS, no children were born of the marriage between the parties; WHEREAS, the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including, without limitation, the settling of all matters between them relating to the ownership of real and personal property, the support and maintenance of one another and, in general, the settling of any and all claims and possible claims by one against the other or against respective estates. 1 , l i >( ,. , , NOW, THEREFORE, in consideration of these premises and of the mutual promises, covenants and undertakings hereinafter set forth, and for other good and valuable consideration, the receipt and sufficiency of which is hereby acknowledged by each of the parties hereto, Husband and Wife, each intending to be legally bounding hereby, covenant and agree as follows: l. ADVICE OF COUNSEL. Each party acknowledges that he or she has had the opportunity to receive independent legal advice fi'om counselor his or her selection (Cindy S, Conley, Esquire tor Husband and Lindsay Dare Baird. Esquire for Wife). Each paliy fully understands the facts and his or her legal rights and obligations. and each party acknowledges and accepts that this Agrecment is. in the circumstances, l'air and equitable. and that it is being entered into ti'eely and voluntarily, and that thc execution of the Agreement is not the result of any duress or undue influence. and that it is not the result of any improper or illegal agreement or agreements. In addition, each party understands the impact of the Pennsylvania Divorce Code, whereby the Court has the right and duty to determine allmaritaJ rights of the parties including divorce. alimony, alimony pel/den Ie lile. equitable distribution of all marital propeliy or property owned or possessed individually by the other, counsel fees and costs of litigation and, tillly knowing the same, each party hereto still desires to execute this Agreement. acknowledging that the temlS and conditions set forth herein are fair, just and equitable to each of the parties, and waives his or her respective right to have the Court of Common Please of Cumberland County, or any other court or competent jurisdiction, make any determination or order affecting the respective parties' rights to alimony. alimony pel/del/Ie lile. support and maintenance. equitable distribution. counsel fees and costs oflitigation, 2. DISCLOSURE OF ASSETS. Each of the parties hereto acknowledges that he or she is aware of his right to seek discovery. including but not limited to, written 2 t t t, , " < inten'ogatories, motions for production of documents, the taking of oral depositions, the filing of inventories, and all other meanS of discovery permitted under the Pennsylvania Divorce Code or the Pennsylvania Rules of Civil Procedure, Each of the parties further acknowledges that he or she has had the opportunity to discuss with counsel the concept of marital property under Pennsylvania law and each is aware of his or her right to have the real and/or personal property. estate and assets, earnings and income of the other assessed or evaluated by the courts of this commonwealth or any other court of competent jurisdiction. The paJiies do hereby aclmowledge that there has been lhll or fair disclosure. valuation. enumeration or statement thereof in the Agreement is specifically waived, and the parties do not wish to make or appcnd hereto any lhrther enumeration or statement. Each party warrants that he os she is not aware of any marital asset which is not identified to this Agreement. The parties hereby acknowledge and agree that the division of assets as set forth in Agreement is fair. reasonable and equitable, and is satisfactory to them. Each of the parties hereto further covenants and agrees for himself' and herself and his or her heirs, executors. administrators or assigns, that he or she will never at any time herea11:er sue the other party or his or her heirs. cxecutors. administrators or assigns in any action of contention, direct or indirect. and allege therein that there was a denial of any rights to full disclosure, or that there was any thud, duress, undue int1uence or that there was a failure to have available thll, proper and independent representation by legal counsel. 3. PERSONAL RIGHTS. Husband and Wife may, at all times hereafter. live separate and apart. Each shall be free t1'om control, restraint, interference and authority. direct or indirect by the other. Each may reside at such place or places as he or she may select 3 f 't " , c Each may, for his or her separate use or benefit, conduct. canyon or engage in any business. occupation. profession or employment which to him or her may seem advisable. Husband and Wite shall not molest. harass, disturb or malign each other or the respective families of each other, nor compel or attempt to compel the other of cohabit or dwell by any means or in any manner whatsoever with him or her. Neither party will interfere with the use, ownership, enjoyment or disposition of any property now owned by or hereatler acquired with the other. 4. MUTUAL CONSENT DIVORCE. It is the intention of the parties, and the parties agree, that by this Agreement they have resolved all ancillary economic issues relatcd to the dissolution of their marriage and thus any divorce action with respect to these parties shall be limited to a claim for divorce only. The paliies acknowledge that on or about January 3. 2000, Wife initiated a divorce action number 24-2000 in thc Cumberland County Court of Common Pleas. The parties acknowledge that thc ninety (90) day waiting period provided for under *3301(c) of the divorce code has expircd. Therefore, contemporaneously with the execution of this Agreement, each party will sign an Affidavit of Consent to divorce and Waiver of Notice of Intention to Request Entry of Divorce Decree and deliver same counsel for Wife, who shall promptly submit said Affidavits and Waivers to the Court, along with the Praecipe to Transmit Record, Vital Statistics Form and any and all other documents necessary to precipitate the prompt entry of a divorce decree. 5. EQUITABLE DISTRIBUTION. (a) Marital Residence. The parties acknowledge that they are the titled owners, as tenants by the entireties of the certain house and Jot and all improvements thereupon situated at 915 Apple Drive. Mechanicsburg, Cumberland County, Pennsylvania 4 j l' . < 17055 (hereinafter refeHed to as the "Marital Residence"), The parties agree as follows with respect to the Marital Residence: (J) Wife shall become the sole and exclusive owner of the Marital Residence and shall be permitted to take any action with respect thereto that she deems appropriate. Husband hereby waives. relinquishes and rcleases any and all past. present or tllture right, title, claim and interest he may have in and to the Marital Residence. Husband shall, at Wife's request, execute a deed transfel1'ing all of his right. title and interest in the Marital Residence to Wife. (2) Husband agrees that as the date of execution of this agreement. any and all title policies and any other policies of insurance with respect to the Marital Residence shall be endorsed to reflect Wife as sole owner thereof and tllrther agrees that Wife shall be entitled to receive any payments now or hereafter due under any such insurance policics. (3) Commencing 0]1 the execution date of this Agreement, Wife shall be solely responsible for all costs, expenses and liabilities associated with or attributable to the Marital Residence, including, but not limited to, any mortgages. any and all home equity loans or lines of credit. taxes, insurance premiums. utilities, maintenance and repairs, and Wife shall keep Husband and his successors, assigns, heirs, executors and administrators indemnified and held harmless ti'om any liability, cost or expense, including actual attomey's fees. which may be incurred with such liabilities and expenses or reSUlting from Husband's ownership interest in the Marital Residence. Moreovcr, Wife shall, within sixty (60) days ofthe date ofthe execution of the Agreement take all steps necessalY, including, but not 5 , , limited to, refinancing, to obtain a release of Husband's liability on the tirst and second mOligages associated with the Marital Residence, (4) Since Wife moved into the Marital Residence on September [,2000, there have been three (3) support payments made to Husband. Included in the support payment is a Contribution to the mortgagc of One Hundred Nine Dollars and Thirty Eight Cents. ($109.38) Husband agrees that the cash that Wife pays to him contemporaneous with the Agreement signing will be reduced by Three Hundred Twenty Eight Dollars and Fourteen Cents, ($328.14) (b) Furnishings and Personalty. (I) The parties agree that they have divided by agreement between themselves all furnishings and personalty located in the Marital Residence. including all furniture. furnishings, antiques. jewelry, rugs, carpets. household appliances and equipment. (2) Except as otherwise set forth herein. Wife shall retain, as her sole and separate property, fl'ee of any and all right, title, claim or interest of Husband, all of the personalty remaining in the Marital Residence. (3) Except as othcrwise set forth herein, Husband shall retain, as his sole and separate property. I!'ee of any and all right. title. claim or interest of Wife. all oCthe personalty and furnishings currently in his possession. (4) The parties acknowledge that during the malTiage they acquired two dogs. Wife shall retain the two dogs as her sole and separate property. (c) Motor Vehicles. (I) Husband agrees that Wife shall retain possession of an receive as her sole and separate property any and all vehicles currently in her name alone. along with all 6 > ., rights and any insurance policies thereon and with all responsibility for payment of any outstanding indebtedness peliaining thereto and insurance thereon. tl'ee of any and all right, title. claim or interest of Husband. Wife shall indemnify and hold Husband and his property harmless from any liability, cost or expense, including actual attorney's fees incurred in connection with any vehicle belonging to Wife by virtue of this subparagraph. (2) Wife agrees that Husband shall retain possession of an receive as his sole and separate property the 1993 Honda Accord, cUlTently titled in the joint names of the parties, along with all rights and any insnrance policies thereon and with all responsibility for payment of any outstanding indebtedness pertaining thereto and insurance thereon, tl'ee of any and all right, title, claim or interest of Wife. Husband shall indcmnify and hold Wife and her property harmless from any liability, cost or expense, including actual attorney's fees incurred in connection with any vehicle belonging to Husband by virtue of this subparagraph, Moreover, Husband shall within thirty (30) days of the date of execution of this Agreement, take all steps necessary, including, but not limited to refinancing and/or sale of the vehicle. to remove Wife's name from any liability associated with said vehicle, (3) The parties agree that they will cooperate in effectuating the transfer of titles and insurance to accomplish the purposes of this subparagraph. (d) Life Insurance. The parties acknowledge and agree that each shall retain as his/her sole and separate propeliy, any and all life insurance policies in his/her name, free of any right, title and interest of the other party, (e) Pension and Retirement Benefits. 7 < Wife and Husband each hereby specifically and waives any and all right, title, claim or interest that he or she may have in and to any and all retirement benefits (including but not limited to pension or profit sharing bcnetits, deferred compensation plans, 40 I (k) plans, employee savings and t1uitt plans, individual retirement accounts or other similar benefits) of the other party, specifically to include a waiver of any spousal annuity benefits andlor beneficiary designations thereunder. The parties agree that they shall documents pursuant to the Retirement Equity Act or any similar act that may be required from time to time to accomplish the purposes of this subparagraph. (f) Financial Accounts. The paJ1ies agree that all financial accounts in existence as of the date of separation have been distributed to them to their mutual satisfaction, (g) Equitable Distribution Paymeuts. In order to aid Husband in paying the credit card debt which he is assuming pursuant to Paragraph 5(K) ofthi8 Agreement, Wife shall pay Husband. simultaneously with the execution of this Agreement, and equitable distribution payment in the amount of One Thousand One Hundred Seventy One Dollars and Eighty Six Cents. ($117\,86) (h) Miscellaneous Property. As ofthe execution date ofthis Agreement, any and all property not specitically addressed shall be owned by the party to whom the property is titled; and if untitled, the party in possession. This Agreement shall constitute a sut11cient bill of sale to evidence the transfer of any and all rights in such property from each to the other. (i) Property to Wife. 8 > < The parties agree that Wife shall own, possess, and enjoy, ti'ee ti'om any claim of Husband. the property awarded to her by the terms of this Agreement. Husband hereby quitclaims, assigns and conveys to Wife all such property, and waives and relinquishes any and all rights thereto, together with any insurance policies covering that property, and any escrow accounts relating to that property, This Agreement shall constitute a sutl1cient bill of sale to evidence the transfer of any and all rights in such property ti'OII1 Husband to Wife. (j) Property to Husband. The parties agree that Husband shall own, possess. and enjoy, free from any claim of Husband. the propeliy awarded to her by the terms of this Agreement. Wife hereby quitclaims, assigns and conveys to Husband all such propeliy. and waives and relinquishes any and all rights thereto, together with any insurance policies covering that property. and any escrow accounts relating to that property. This Agreement shall constitute a sufficient bill of sale 10 evidence the transfer of any and all rights in such property ti'om Wi fe to Husband, (k) Assumption of Encumbrances. The parties acknowledge that during the marriage they acquired credit card debt owed to MBNA in the approximate amounl of Seven Thousand Four Hundred Seventy Two Dollars ($7472,00) and American Express in the amount orTwo Tbousand Tbree Hundred Seventy Eight Dollars and Seventy Cents ($2378,70), The parties further acknowledge that said credit cards are solely in Husband's name. Husband agrees that he shall be solely responsible for satisfYing said credit card debt and shall indemnify wife and her property harmless t1'om any liability, costs or expense associated therewith. Moreover, the parties acknowledge that they incurred a debt to Circuit City during the marriage for the purchase of a washer and dryer which are to remain in the Marital Residence with Wife, Accordingly, wife shall be solely responsible 9 , for satisfying the Circuit City debt and shall indemnify and hold Husband harmless t)'om any liability, cost or expense associated therewith. Moreover, Wife shall within thirty (30) days of the date of execution of this Agreement take all steps necessary to obtain a release of Husband's liability on said debt. (I) Liability Not Listed. Each party represents and walTants to the other that he or she has not inculTed any debt. obligation or other liability, other than those described in this Agreement. on which the other party is or may be liable. A liability not disclosed in this Agreement will be the sole responsibility of the party who has incurred or may hereafter incur it. and such party agrees to pay it as the same shall become due, and to indemnify and hold the other party and his or her property harmless t)-om any and all such debts, obligations and liabilities. (m) Indemnification of Wife. If any claim, action or proceeding is hereafter initiated seeking to hold Wife liable for the debts or obligations assumed by Husband during this Agreement, Husband will, at his sole expense, defend wife against any such claim, action or proceeding, whether or not well-founded and indemnify her and her property against any damages or loss resulting therefrom. including. but not limited to, costs of court and actual attorney's fees incurred by Wife in connection therewith. (n) Indemnification of Husband. If any claim, action or proceeding is hcrealler initiated seeking to hold Husband liable for the debts or obligations assumed by Wife during this Agreement, Wife will, at his sole expense, defend wife against any such claim. action or proceeding, whether or not well-founded and indemnity her and her property against any damages or loss resulting 10 . <, theretl'om, including, but not limited to. costs of court and actual attorney's fees inculTed by Husband in connection therewith. (0) Warranty as to Future Obligations. Husband and Wife each represents and WaITants to the other that he or she will not at any time in the future incur or contract any debt. charge or liability for which the other, the other's legal representatives, property or estate may be responsible, From the date of execution of this Agreement, each party shall use only those credit cards and accounts lix which that party is individually liable and the parties agree to cooperate in closing any remaining accounts which provide for joint liability. Each pmty hereby agrees to indemnify. save and hold the other and his or her property harmless l1'om any liability, loss, cost or expense whatsoever. including actual attorneys fees, incuned in the event of breach hereof 6. WAIVER OF ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT. Except as provided herein. Husband and Wife hereby expressly waive. dischaI'ge and release any and all rights and claims which he or she may have now or hereaftcr by reason of the parties' marriage to alimony. alimony INlldellle lile. spousal support. and/or maintenance or other like benefits resulting from the parties' status as Husband and Wife, The parties further release and waive any rights they may have to seek modification of the terms of this paragraph in a Court of Law or equity, it being understood that the foregoing constitutes a final deteJ1nination for all time of either party's obligation to contributc to the support and maintenance of the other. The parties acknowledge that pursuant to a support order being administered through the Court of Common Please of Cumberland County, Pennsylvania, Domestic Relations Section. docketed at number 01037-S-1999 and PACSES Case No. 11 , . 761101783. Wife is obligated to pay to Husband the sum of Four Hundred Fifty Onc Dollars ($45] .00) per month as and for spousal support. The parties agree that said spOllsal slIpport obligation shall terminate as of the date of execution of this Agreemcnt. Accordingly, Husband's counsel shall, after execution of this Agreement, notify Domestic Relations Oftice to terminate said spOllsal support order. Moreover, Wife shall take all steps necessary to withdraw her request for modification of said support order. 7. COUNSEL FEES. COSTS AND EXPENSES. Each paliy shall be solely responsiblc for his or her own legal fees. costs and expenses incurred in connection with their separation and/or dissolution of their marriage, and the preparation and execution of this agreement. 8. WAIVER OF INHERITANCE RIGHTS. Unless otherwise specifically provided in this Agreement, as ofthe execution date of this Agreement. Husband and Wife each waives all rights of inheritance in the estate of the other, any right to elect to take against the will or any other trust of the other or in which the other has an interest, and each of the parties waives any additional rights which said party has or may have by reason of their man'iage, except the rights saved or created by the terms of this Agreement, This waiver shall be construed generally and shall include, but not limited to a waiver of all rights provided under the laws of Pennsylvania, or any other jurisdiction. 9. WAIVER OF BENEFICIARY DESIGNATION. Unless otherwise specifically set forth in this agreement, each party hereto specifically waives any and all heneticiary rights and any and all rights as a surviving spouse in and to any asset, benefit or like program carrying a beneficiary designation which belongs to the other pmiy under the tenTIS of this Agreement, including, but not limited to, pensions and l2 -" " ~ retirement plans or any sort or nature, deferred compensation plans. life insurance policies, annuities, stock accounts, bank accounts, final paychecks or any other post-death distribution scheme, and each party expressly states that it is his and her intention to revoke by the tel111S of this Agreement any beneficiary designations naming the other which are in effect as of the date of execution of this Agreement. lfand in the event the other party continues to be named as beneticiary and no alternate beneticiary is otherwise designated, the beneficiary shall be deemed to be the estate of the deceased party, 10. RELEASE OF CLAIMS. (a) Wife and Husband acknowledge and agree that the property dispositions provided for herein constitute and equitable distribution of their assets and liabilities pursuant to ~3502 of the Divorce Code, and Wife and Husband hereby waive any right to division of their property except as provided for in this Agreement. FUlihel1110re. except as otherwise provided for in this Agreement, each of the parties hereby specifically waives, releases, renounces, and forever abandons any claim, right, title or interest whatsoever he or she may have in propeliy transfclTed to the other party pursuant to this Agreement or identificd in this Agreement as belonging to the other party, and each party agrces never to assert any claim to said property or proceeds in the future. However, neither party is released or discharged ii'om any obligation under this Agreement or any instrument or document executed pursuant to this Agreement. Husband and Wife shall hereafter own and enjoy independently of any claim or right of the other, all items of personal property. tangible or intangible, acquired by him or her ti'om the execution date of this Agreement with full power in him or her to dispose of the same fully and effectively for all purposes. 13 "' c " (b) Each pmiy hereby absolutely and unconditionally releases and forever discharges the other and the estate of the other for all pllllJoses th)m any and all rights and obligations which either party may have or at any time hereafter has for the past. present or future maintenance, alimony pendente lite, alimony, equitable distribution, counsel fees, costs, expenses, and other right or obligation, economic or otherwise, whether arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, its supplements and amendments, as well as any other law or any other jurisdiction. except and only except all rights and obligations arising under this Agreement or for the breach of any of its provisions, Neither party shall have any obligation to the other not expressly set forth herein, (c) Except as set forth in this Agreement, each party hereby absolutely and unconditionally release and forever discharges the other and his or her heirs. executors. administrators. assigns. property and estate tt'om any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the parties whcther now existing or hereafter arising, The above release shall be etTective regardless of whether such claims arise out of any former or future acts, contracts, engagements or liabilities of the other or by way of dower, curtesy, widow's or widower's rights, family exemption or similar allowance, or under the intestate laws or the right to take against the spouse's will, or the right to treat a lifctime conveyance by the other as testamentary or all other rights of the surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of Pennsylvania. any state. commonwealth or telTitory of the United States, or any other country, (d) Except for the obligations ofthe parties contained in this Agreement and such rights as are expressly reserved herein, each party gives to the other by the 14 i: execution of this Agreement an absolute and unconditional release and discharge from all causes or action, claims, rights or demands whatsoever in law or in equity. which either party ever had or now has against the other. 11. PRESERV A nON OF RECORDS. Each party will keep and preserve for a period of four (4) years tl'om the date of their divorce decree all financial records relating to the marital estate, and each party will allow the other party access to those records in the event of tax audits, 12. MODIFICATION. No modification. rescission. or amendment to this Agreement shall be effective unless in writing signed by cach of the parties hereto. 13. SEVERABILITY. If any provision of this Agreement is held by a court of competent jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall nevertheless survive and continue in tull force and effect without being impaired or invalidated 1ll any way, 14. BREACH. If either party hereto breaches any provision hereot~ the other party shall have the right, at his or her election, to sue for damages for such breach, or seek such other remedies or relief as may be available to him or her. The non-breaching party shall be entitled to recover fi'om the breaching party all costs, expenses and legal fees actually incurred in the enforcement of the rights of the non-breaching party. 15. WAIVER OF BREACH. 15 ~ The waiver hy one party of any breach of this Agreement by the other party wiIlnot be deemed a waiver of any other breach or any provision of this Agreement. 16. NOTICE. Any notice to be given under this Agreement by either party to the other shall be in writing and may be effected by registered or celiified mail, return receipt requested, Notice to Husband will be suflicient if made or addressed to the following: Chad M. Fahnestock 2908 Elm Street HalTisburg, PA 17103 and to Wife, if made or addressed to the following: Mary C'. Fahnestock 915 Apple Drive Mechanicsburg, P A 17055 Notice shall be deemed to have occulTed upon the date received by the recipient. Each party may change the address notice to him or her by giving notice of that change in accordance with the provisions of this paragraph, 17. APPLICABLE LAW. All acts contemplated by this Agreement shall be construed and enforced under the substantive laws of the Commonwealth of Pennsylvania (without regard to the conflict oflaw mles applicable in Pennsylvania) in effect as of the date of executions of the Agrecment. 18. DATE OF EXECUTION. The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which the parties signed the Agreement if they do so on the same date, 16 ~ or ifnot on the dame date then the date on which the Agreement was signed by the last paliy to execute this Agreement. 19. EFFECTIVE DATE. This Agreement shall become effective and binding upon both parties on the execution date. 20. EFFECT OF RECONCILIATION, COHABITATION OR DIVORCE. This Agreement shall remain in full rorce and effect and shall not be abrogated even if the parties effect a reconciliation, cohabit as Husband and Wife or attempt to effect a reconciliation. This Agreement shall also continue in filII force and effect in the event of the parties' divorce. There shall be no modification or waiver of any of the terms hereof unless the parties in writing execute a statement declaring this Agreement or any term of this Agreement to be null and void. 21. HEADINGS NOT PART OF AGREEMENT. Any headings preceding the text of the several paragraphs and subparagraphs hereof are inserted solely for the convenience of reference and shall not constitute a part of the Agreement nor shall they affect its meaning. construction or effect. 22. AGREEMENT BINDING ON PARTIES AND HEIRS. This Agreement shall bind the parties hereto and their respective hcirs. executors, administrators, legal representatives, assigns. and successors in any intercst of the parties, 23. ENTIRE AGREEMENT. 17 . , '" . Each party acknowledged that he or she has carefully read this Agreement: that he or she has discussed it's provisions of his or her choice, and has executed it voluntarily an in reliance upon his or her own attorney; and that this instrument expresses the entire agreement between the parties concerning the subjects it purp0l1s to cover and supersedes any and all prior agreements between the parties. This Agreement should be interpreted fairly and simply. and not strictly for or against either of the parties, 24. MUTUAL COOPERATION. Each pm1y shall. on demand. execute and deliver to the other deeds. bills of sale. assignments, consents to change of beneficiary designations, tax returns, and other documents, and shall do or cause to be done any other act or thing that may be necessary or desirable to effectuate the provisions and purposes of this Agreement. If either party unreasonably fails on demand to comply with these provisions, that party shall pay to the other party all attorney's fees, costs, and other expenses actually incurred as a result of such failure, 25. AGREEMENT NOT TO BE MERGED. This Agreement may be incorporated into a decree of divorce for pUlvoses of enforcement only, but otherwise shall not be merged into said decree, The pmiies shall have the right to enforce the Agreement under the Divorce Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity under this Agreement as an independent contract. Such remedies in law or equity are specifically no! waived or released. 18 ~ ~ . . " IN WITNESS WHEREOF. the parties hereto set their hands and seals on the dates of their acknowledgements. WITNESS (Jv "/h, :;;2. ~ - CHAD M, FAHNESTOCK I/Jt~ ('. ~/))~ MARY ,FAHNESTOCK 19 .. :t Y. ;:. COMMONWEA L TH OF PENNSYLVANIA ) ) COUNTY OF CUMBERLAND ) BEFORE ME, the undersigned authority, on this day personally appeared CHAD M. FAHNESTOCK known to me to be the person who executed the foregoing instrument, and who acknowledged to me that he executed same for the purposes and considerations therein expressed, GIVEN UNDER MY HAND AND SEAL OF OFFICE this iD'fl-- day of ()[..-h~v ,2000. " - ,,-=--. --- - ~ ,- "l:-, ,~--. J)c41f~ a J0fM)/l otalY PublIC 1 aJ or \ Commonwealth of Pennsylvania Typed or Printed name of Notary: NOTARIAL SEAL ~ruslJ:bSEklu~OTARY PUBLIC ES FER 16 2004 My commission expires: 20 . ~ , ,)" . COMMONWEALTH OF PENNSYLVANIA ) ) COUNTY OF CUMBERLAND ) "" BEFORE ME. the undersigned authority, on this day personally appeared MARY C. FAHNESTOCK known to me to be the person who e~cuted the foregoing instrumcnt, and who acknowledged to me that he executed same for the pUll'oses and considerations therein ex pressed. 'til GIVEN UNDER MY HAND AND SEAL OF OFFICE this b . day of ~ ,2000. - -~" ..;;:..' -" , .....:;-... .~~---"'~ ..." ...:::-.~,-..; _~=;--%'i.~?;'-' :;~ ;.:{ - -~ -. ...":- f,,'i{V_" -".,",.-- ._".",...... ~~"-.,--"" " t;-vt.(,,:~. ~?.->~" ~.; " '~ ,- '.. ._L /.~~::~;-'-;~~:~~~-~;'- ,;~:_~ ~ otary U Ie 111 an or Commonwealth of Pennsylvania Typed()('yrinted name of Notary: My commission expires: Notarial Seal . Niven J. Baird, Notary Public Carlisle Boro, Cumberland cQunai, My Commission Exp\res Nov. 2. 20 2 Mef'lhl'r, PennsylvaP.a ,'\ESOclation of Notaries 21 .. F!LED-(),:FJCE or iHE PFDTW'JNOTARY 000C127 PH I: sa CUMBERLAND CQUNTY PENNSYLVANIA ~ ~ . . .~ I , ! ..fJ'};):'~ '\!\II', "'rt;c~< ,'I-I' u.~, ~,.I. " , ~', I! . _ 1\ ~f~\&' ",(.('111:",(1(.., '\i() . ~.~' ".' (r, .rfl.G f, ",('r ( I (~, ,J r,C~1'i(~\'(l('C,'i"~' ','-, " .,' ,~( r;'" '~~:~>'i(,'~\" ::' (",,'r:: ~~ .(~ {::; " " ....-~"", 9, .(,. , ':,:::':":<.'.((;": " ~,..;t;, / ~. ,< .'\, 11"r.,~~t..,~,r I' "~?,..'.Ai" /".: ':',..~'{,,"\,<'J.i ,\\ .. """, i' F ..~'-', , .", "" '~ ,I' I'.' " > MARY CATHERINE FAHNESTOCK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. : CIVIL DIVISION - LAW CHAD MICHAEL FAHNESTOCK, Defendant : 2000-24 CIVIL TERM : IN DIVORCE PRAECIPE 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 Section 3301(c) of the Divorce Code. 2, Date and manner of service of the Complaint: January 12, 2000, Certified, Return Receipt Requested, Restricted Delivery U.S. Mail. 3. Date of execution of the Affidavit of Consent required by Section 3301 (c) of the Divorce Code: By Plaintiff: October 26, 2000 - By Defendant: October 10, 2000, 4. Related claims pending: None 5, Date Plaintiff's Waiver of Notice in 93301(c) Divorce was filed with the Prothonotary: /o.a? of) Date Defendant's Waiver of Notice in 93301 (c) Divorce was filed with the Prothonotary: lo'~?'o6 FiLEO-Ot'FiCE OF rioT: ::rY))l1CN01AAY aOOCT27 PN /:59 CUMBERLAND COUNTY PENNSYLVANIA . . .... . , MARY CATHERINE FAHNESTOCK, Plaintiff v : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : ~ dCW -.;;H CIVIL TERM : CIVIL ACTION - LAW CHAD MICHAEL FAHNESTOCK, Defendant : 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 faii 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, inciuding custody or visitation of your children, When the grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling, A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, Carlisle, Pennsylvania. 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, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 " ., :MARY CATHERINE FAHNESTOCK, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLANDCOUNTYPENNSYLVANlA NO:~- :2 WIJ.,;) Y CIVIL TERM CHAD MICHAEL FAHNESTOCK, Defendant IN DIVORCE COMPLAINT UNDER SECTION 3301(C) OR (D) OF THE DIVORCE CODE Plaintiff, Mary Catherine Fahnestock, by her attorney, Lindsay D. Baird, Esquire, sets forth the following: 1 Plaintiff, Mary Catherine Fahnestock, is an adult individual residing at 125 Winston Drive, Mechanicsburg, Cumberland County, Peunsylvania 17055. 2 Defendant, Chad Michael Fahnestock, is an adult individual residing at 915 Apple Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3 The parties were married on September 26, 1998 in Cumberland County, Pennsylvania.. 4 Plaintiff and Defendant have lived continuously in the Commonwealth of Peunsylvania for at least six months prior to the commencement of this action. 5 This action is not collusive. 6 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the ;;; ,,;;. .~ knowledge ofthe Plaintiff, 7 In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. 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 counseling. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. .f , Idsay D. Bai{ , Esquire Attorney for the Plaintiff 37 S, Hanover Street Carlisle,PA 17013 717 - 243-5732 ~~ I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities. ~r,~ Mary Catlierine Fahnestock ~ "'" \; . , & . " I. I' i FlLlli-0FFlCE fJnF Tl.J . '0: r'!)(lT/..!,nAI/1TAny I " " ,. ,. ...J1"il/r'Mn aOJMI~3PI11:25 CU,ii.;c;lU\\/) COUN1Y FENNSYLVANrA j' J, r J , . /'7.s;!,?J /",A',~, / S;&cJ /",p!.~ I /ffO~vrd.4 ;. s I [ ~ I 1 I . , ~ # //?'&" /J:t# <f '1 b~'iT " l I , 11 :! f'- , . f c -, MARY CATHERINE FAHNESTOCK, Plaintiff IN THE COURT OF CO:M:MON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v. NO. 2000-24 CIVIL TERM CHAD MICHAEL FAHNESTOCK, Defendant IN DIVORCE AMENDED COMPLAINT UNDER SECTION 3301(C) OR (D) OF THE DIVORCE CODE Plaintiff, Mary Catherine Fahnestock, by her attorney, Lindsay D. Baird, Esquire, sets forth the following: 1 Plaintiff, Mary Catherine Fahnestock, is an adult individual residing at 125 Winston Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2 Defendant, Chad Michael Fahnestock, is an adult individual residing at 915 Apple Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3 The parties were married on September 26, 1998 in Cumberland County, Pennsylvania.. 4 Plaintiff and Defendant have lived continuously in the Commonwealth of Peunsylvania for at least six months prior to the commencement of this action, 5 This action is not collusive. 6 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the " . " knowledge of the Plaintiff. 7 In accordance with Section 3301(c) of the Divorce Code, the marriage between the parties is irretrievably broken. 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 counseling. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. COUNT II - EQUITABLE DISTRIBUTION 9 Paragraphs 1-8 of the Complaint are incorporated herein by reference as though set forth in full. 10 Plaintiff and Defendant have acquired property, both real and personal, during their marriage from September 26, 1998 until November 4,1999, 11 Plaintiff and Defendant have been unable to agree as to an equitable division of said property. WHEREFORE, Plaintiff requests your Honorable Court to equitably divide all marital property. / ~\ ;; ~/j/, /:' . ' Uit.'I"~U\ " ,,- I ndsay D. Bait'!, squire Attorney for the laintiff 37 S. Hanover Street Carlisle, PA 17013 717 - 243-5732 . .' , I verify that the statements in the foregoing pleading are true and correct. I understand that false statements herein are made subject to the penalties of 18 PaCS 4904 relating to unsworn falsification to authorities, '/Iv"'d ( f ~k Mary atherine Fahnestock . . , , ,', (, .::1 ,1 'I "', '. R~FD'Oltl2c c; CJ' h(\Ti".'~I.~J"''''Y I '; ,',_, I ~, If' III 00 FEO :2 2 AN 8: ~ 9 CUi\kJi.::11IJv',O COUN1Y PENNSYLVANIA ' /5-,00?~.4. ~fr///S ~ 1'ls-r;7 , ;.. :';1 I" , ! " ! ': . I "i 1"'1 ' . . . . . MARY CATHERINE FAHNESTOCK, Plaintiff IN THE COURT OF COMt\10N PLEAS OF CUMBERLAND COUNTY PENNSYL VANIA v. NO, 2000-24 CIVIL TERM CHAD MICHAEL FAHNESTOCK Defendant IN DIVORCE AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 330l(C) of the Divorce Code was filed on January 3, 2000. 2. Defendant acknowledged receipt and accepted service of the Complaint on January 12, 2000. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without notice. 5. 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. 6. 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, 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 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. Section 4904 relating to unsworn falsification to authorities. Date: / lJ-.;J. (, . rn) 0z~ l. r~~ Mary ather1ne Fahnestock FILED-{)FFICE; or )fiE ptY'JT/-IONOTr\RY OOOCT27 PI111S8 CUMBi;RLAilJD COUN7'( PENNSYlVANIA . . . , . , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA MARY CATHERINE FAHNESTOCK, Plaintiff v. ) ) ) ) ) ) ) NO, 2000-24 CIVIL TERM CHAD MICHAEL FAHNESTOCK, Defendant CIVIL ACTION - LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT AND WAIVER OF COUNSELING 1. January 3, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety days have elapsed from the date of filing and service of the complaint. A complaint in divorce under 93301(c) ofthe Divorce Code was filed on 3. I consent to the entry ofa final decree in divorce after service of notice of intention to request entry ofthe decree, WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER S3301(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! 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 above are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.. 94904 relating to unsworn falsification to authorities. Date: {o/10/ d.0"'-= 02~ ~ ~~~ Chad Michael Fahnestock, Defendant RLED..OFFICE 01': '1'1.'," "i,j!)l',I,,!\!()"' '''RY " L 1 i.. ,~...'" 'I,"\: OOOCT2? PM 1:58 CUMSmLAND COUNTY PENNSYLVANIA " > , , , 1, ~ . - ;---. .;;:-'--i MARY CATHERINE FAHNESTOCK, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA v, : CIVIL DIVISION - LAW CHAD MICHAEL FAHNESTOCK, Defendant : NO. 2000-24 CIVIL TERM : IN DIVORCE AFFIDAVIT OF SERVICE I, Lindsay Dare Baird, Esquire, being duly sworn according to law do depose and state that a copy of the Complaint filed in the above-captioned matter along with a copy of a Notice to Plead and a Notice of Availability of Marriage Counseling was served on the Defendant, January 12, 2000 by Certified mail - Return Receipt Requested, restricted delivery, a copy of said return receipt evidencing delivery being attached hereto, Said service on January 12, 2000, I~ V~ Attorney for Plaintiff 37 South Hanover Street Carlisle, PA 17013 717 - 243-5732 Sworn and Subscribed to before me this 27'ttj day of~, 2000, n 1~.uoL( .. t&;JA.! Notary Public ~ 'i , ~, "'. - '", Notarial Seal . Niven J. Baird, Notary Public Carlisle Bore, cum~ertand County My Commission Explres Nov. 2, 2002 Member, Pennsylvania ASSOCiation ot Notanes <;; SENDeR: -c . Complete items 1 ancV.- r additional services. _ _ CD -Compleleitems3,4a,. ,. ~fRf GI aPrintyournameanda on tl1e reverse otthls form so t - e e _~~~ . ~ .>.o\ttac~ thlS{onn to the front of the mailpiece, or on the back if :SPDEIiv f: ......pennlt. C1) -Write-Return ReceiPf Requested" on the mailpiece below the arti '5 -The Return Receipt will show to whom the article was delivered and the date delivered. ,; u ?: m en ~ .!!- 11 m a: E " U' ! ~ Certified ~ o Insured ~ o COD : .2 " g, ... c " ~ c o -a 3. Article Addressed to: 2 m 'ii E o u Ul Ul W 0: C C .. z a: ft~Addressee's Address ~Jl-.Bestncted DeJjyeJ)' Consult postmaster for fee. 4a. Article Number ;i! Of3 cl Y7',J"% 4b. Service Type o Registered o Express Mail etelp or erc an I 7. Date of Delivery 1~12..-2cco 8. Addressee's Address (OnTy if requested and fee is paid) r(lr, CAc0 rn. r;.;, nesfocL C?1::j C7;>p/e. :Drtv~ M CILCl.KIC-.s0&tr'] I f?,g /Mc> 5. Received By: (Print Name) w ~ 6. Signaty(e: (AddJ.e~ee or Agent) 6 ,/ '4 /- ' /1ft> >- ,~');::i4> t: .!! PS Form 3811, December 1994 Domestic Return Receipt UNITED STATES p. SERVICE 1111 . First-Class Mail Postage & Fees Paid USPS Permit .No. G-10 . Print your name, address, and ZIP Code in this box. I I I Lindsay Dara:llaird I 37 South Hanover Street I Carlisle, PA 17013-3307 [ k:!.$ 1l!.lll..!/I/'!1!!.!I.,lJ!..!I!I!ll!ll.,!l,!,lnl!!i,.!I,I!ld .. ... H\EO.{H\CC QFIV.,[. ':fOTrlONOT~R'{ ~ '~ ~ OGOC\Z"1 PH \: 58 CUMElEHLAND COUN1Y . PENNSYLY,1>N1A .( l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : : Mary Catherine Fahnestock : P1aintiff : : Fi1e No. 2000-24 : vs. : IN DIVORCE : : Ch~n MichnAl F~hnp~r.n~k : _.. Defendant : NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the P1aintiff/Defendant in the above matter, having been granted a Fina1 Decree in Divorce on the ;,,0 lo#< day of /iJd rLm bv7 ,:J?k 0 {) , hereby e1ects to resume the prior surname of M;::)ry r.:=:tr-npri niP T.;=ing;::ln . .and _ gives this written notice pursuant to the provisions of 54 P.S. S 704. DATE: }~/2Z/() () ~c.~ Signature ~~(-~~~, Signa re of na being resumed COMMONWEALTH OF PENNSYLVANIA: : 55. COUNTY OF CUMBERLAND : On the ,!J;:).. day of-J:]nv&vn b p..,..... , :X~, before me, a Notary Pub1ic, persona11y appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknow1edged that he/she executed the foregoing for the purpose therein contained. In Witness Whereof, I have hereunto set my hand and officia1 sea1. .-" Notary ~ -N ARIALSEAL lENORilE. LANGAN, Nofury Public Silver Spring Twp. Cumberlaild Co. My Commission E1qlires AUQ. 6,2001 ,\ I' I , I ill 1 I' I I, \'1 :\ , \ I; :) i j j;' -~, I ,I . !.: . ,. 'i " ,. " Ii .1 1 1 1 , :i '~, .~, \' I' I I !) '" ,. F:LED-QI'F1CE r::: T"'; ~;)iTfi.,nl;!O'rM;N .Jl . r' r~ r" ~.; ,~ I -' -, I t\l'lI 01 APR 26 PH I: 01. CUMBtHU~'JD COUNTY PENNSYLVANIA fl, deJ F D'I)' R-tl /1073 i I 'I I ~: " " , , " I Ii .., "I " I, I -"~ ,',.. " I i