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HomeMy WebLinkAbout00-01509 '~ . . . . . . . ~ ~ ~ ~ ~ ~~ ~~ ~ ~ . . . IN THE COURT OF COMMON PLEAS . . . . . OF CUMBERLAND COUNTY . . . . STEVE R. FAIR PENNA. STATE OF . . No. 00-1509 CIVIL Plaintiff . . VERSUS . . CAROL L. FAIR . . Defendant. . . . . DECREE IN DIVORCE ;tq,~ (~~ ~~ ~_, 2i)C'~T IS ORDERED AND . . . . AND NOW, . . STEVE R. FAIR DECREED THAT , PLAINTIFF, . . CAROL 1;. FAIR AND , 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; . . . . . . . . MARRIAGE SETTLEMENT AGREEMENT INCORPORATED, BUT NOT MERGED . . . . . . ~ 'J. ~~~~;f.OTHONOTA" . . . .. . . . . ~ :f.~~ :f. ~~~ ~ . . '11'-,>-"'_:"' , "" . . . . . . . . . . . . . . . . . . . . . . . , , . . . . . . . . , . . . , . . . . . . . . . . . . . . . . ... _-I " ,... ~ .M """""~IIIIiIii_""'''''-''~ --~ ~ ail_III tj'-IIJ Od-. tJ - /# -0,> . ~ ~ -' - -~ ~bi- . .~.__......... "'._~-- "'~ '., . ,~"~ " - ~: ",.I. M,~~~~. .~ '71~ ~;V~~ ~ . 00 - I S09 C;U,{ THIS AGREEMENT, made this ~ day of ~ A <., t , 2002, by and <-rEtL.~ between STEPHEN R. FAIR of Lemoyne, Cumberland, P ylvama, party of the first part, hereinafter referred to as "Husband" and CAROL 1. FAIR of Coatsville, Chester County, Pennsylvania, party of the second part, hereinafter referred to as "Wife," or collectively referred to as the "Parties." MARRIAGE SETTLEMENT AGREEMENT WITNESSETH: WHEREAS, Huband and Wife were married on April 13, 1985 in Chester County, Pennsylvania; and WHEREAS, Husband and Wife have been living separate and apart from each other since August 24,1999, WHEREAS, Husband and Wife are residents of the Commonwealth of Pennsylvania and have been so for at least the past six (6) months; and WHEREAS, certain diverse, unhappy differences have arisen between the Parties hereto which have made them desirous of continuing to live separate and apart from one another; and WHEREAS, Husband and Wife desire to settle and determine certain of their marital rights and obligations, and make an equitable distribution of their marital property; and WHEREAS, there were two (2) children born of the marriage: Heather Lynn Fair (hereinafter referred to as "Heather"), born May 4, 1986; and Keith Andrew Fair (hereinafter referred to as "Keith"), born April 23, 1991, or hereinafter collectively referred to as the "Children"; and WHEREAS, it is the intention and purpose of this Agreement to set forth the respective rights and duties of the Parties while they continue to live apart form each other and to settle all [mancial and property rights between them; and WHEREAS, the Parties hereto have mutually entered into an agreement for the division of their jointly-owned assets, the provisions for the liabilities they owe, and provisions for the resolution of their mutual differences, after both have had full and ample opportunity to consult with their respective attorneys, and the Parties now wish to have that agreement reduced to writing. Page 1 of 13 :~'ft ~ I ~ ~ ..,' . ' NOW, THEREFORE, the Parties hereto in consideration of the mutually made and to-be- kept promises set forth herein and for other good and valuable consideration, intending to be legally bound and to legally bind heirs, successors, assigns, and personal representatives, do hereby covenant, promise and agree as follows: ARTICLE I: SEPARATION 1.1 It shall by lawful for Husband and Wife at all times hereafter to live separate and apart from each other and to reside from time to time at such place or places as they shall deem fit and free from any control, restrain, or interference, direct or indirect, by each other. Neither Party shall molest the other or compel or endeavor to compel the other to cohabit or dwell with him or her by any legal or other proceedings. The foregoing provision shall not be taken to be an admission on the part of either Husband or Wife as to the lawfulness of the causes leading to them living separate and apart. ARTICLE II: DIVORCE 2.1 This Agreement is not predicated on divorce. It is specifically understood and agreed by and between the Parties hereto, and each of said Parties does hereby warrant and represent to the other that the execution and delivery of this Agreement is not predicated upon nor made subject to any agreement for institution, prosecution, defense, or for the non-prosecution or non-defense of any action for divorce; provided, however, that nothing contained in this Agreement shall prevent or preclude either of the Parties hereto from commencing, instituting or prosecuting any action or action for divorce, either absolute or otherwise, upon just, legal and proper grounds; nor will it prevent either Party from defending any such action which has been, may, or shall be instituted by the other Party, or for making any just or proper defense thereto. It is warranted, covenanted, and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable and this warranty, covenant, and representation is made for the specific purpose of inducing Husband and Wife to execute this Agreement. Husband and Wife each knowingly and with full understanding, hereby waive any and all possible claims that this Agreement is, for any reason, illegal, or for any reason whatsoever of public policy, unenforceable, in whole or in part, Husband and Wife do each hereby warrant, covenant and agree that, in any possible event, he and she are, and ever shall be, estopped from asserting any illegality or unenforceability as to all, or any part, of this Agreement. Page 2 of 13 "" 1- I'? 2.2 It is further specifically understood and agreed that the provisions of this Agreement relating to the equitable distribution of property of the Parties are accepted by each party as a final settlement, or for all purposes whatsoever. Should either of the Parties obtain a decree, judgment, or order of separation or divorce in any other state, county, or jurisdiction, each of the Parties to this Agreement hereby consents and agrees that this Agreement, and all its covenants, shall not be effected in any way by any such separation or divorce; and that nothing in any such decree, judgment, order, or further modification or revision thereof, shall alter, amend, or vary any term of this Agreement, whether or not either or both of the Parties should remarry, it being understood by and between the parties that this Agreement shall survive and shall not be merged into any decree, judgment, or order of divorce or separation. 2.3 It is specifically agreed that a copy of this Agreement may be incorporated by reference into any divorce judgment or decree if, or whenever sought by any of the Parties hereto. It is understood by the Parties that a Divorce Complaint has been filed in the Court of Common Pleas of Cumberland County, Pennsylvania at docket number 00-1509 Civil Term. Such incorporation, however, shall not be regarded as a merger, it being the intent of the Parties to permit the Agreement to survive any such agreements. ARTICLE III: EOUlTABLE DISTRIBUTION OF MARITAL PROPERTY 3.1 The Parties have attempted to divide their marital property in a manner which conforms to the criteria set forth in Section 3502 of the Pennsylvania Domestic Relations Code, and taking into account the following considerations: the length of the marriage; the prior marriages of the Parties (if any); the age, health, station, amount and sources of income, vocational skills, employability, estate liabilities, and need for each of the Parties; the contribution of one Party to the education, training, or increased earning power of the other Party; the opportunity of each Party for future acquisition of capital assets and income; the sources of income of both Parties, including, but not limited to medical, retirement, insurance or other benefits; the contribution of dissipation of each Party in the acquisition, preservation, depreciation, or appreciation of marital property, including the contribution of a Party as a homemaker; the value of the property set apart to each Party; the standard of living of the Parties established during their marriage. Page 3 of 13 A;I., ""1 - 3.2 The Parties shall retain sole and exclusive right, title, and possession of all personal property currently in their possession. Except as provided for herein, Husband shall make no claim whatsoever for any personal property in Wife's possession. Additionally, except as provided for herein, Wife shall make no claim whatsoever for any personal property in Husband's possession. Should it be necessary for either Party to execute any documents to convey title to any such personal property in the other Party's possession, they shall do so within thirty (30) days of the execution of this Agreement, or within thirty (30) days of a request to do so from the opposing Party. 1. Contemporaneously with the execution of this Agreement, Wife shall relinquish any and all rights she may have to any and all of the Parties joint checking and/or savings account(s), and within thirty (30) days of execution of said Agreement, Wife shall sign any documents needed to effectuate such transfer. 2. Contemporaneously with the execution of this Agreement, Wife shall relinquish any and all rights she have to any and all of the Parties joint credit card(s), and within thirty (30) days of execution of said Agreement, Wife shall sign any documents needed to effectuate such transfer. 3.3 Except as provided herein, Wife waives any right or interest she may have in Husband's employment benefits, including any retirement plan, stock option purchase plan, profit sharing plan, or related matters. Except as provided herein, Husband waives any right or interest he may have in Wife's employment benefits, including any pension benefits, retirement plan, stock option purchase plan, profit sharing plan, or related matters. 3.4 Except as provided herein, Husband and Wife agree to waive and relinquish any and all rights that he or she may now have or hereafter acquire in any real or tangible personal property subsequently acquired by the other Party. Husband and Wife specifically agree to waive and relinquish any right in such property that may arise as a result of the marriage relationship. 1. Contemporaneously with the execution of this Agreement, Wife shall transfer to Husband any and all of Wife's right, title, and interest in, and to, that certain parcel of real estate located at 342 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania, heretofore owned by the Parties as tenants by the entireties. Said transfer is subject to those liens, judgments or mortgages or record as of the date of conveyance, all of which shall thereafter become the sole and exclusive obligation of Husband. Within One Hundred Eighty (180) days of the date ofthis Page 4 of 13 -,-",i, I ~ Agreement, Husband shall payoff or refinance any and all mortgages and notes on said property to remove Wife's name from said mortgage(s) and note(s). At all times relevant hereto, Husband also agrees to indemnifY and hold Wife harmless from the collection and/or responsibility for payment of any mortgage(s), note(s), or loan(s) on said property. ARTICLE IV: RELEASE OF SUPPORT FOR HUSBAND AND WIFE 4.1 The parties herein acknowledge that by this Agreement they have respectively secured and maintained a substantial and adequate fund with which to provide themselves sufficient resources to provide for their comfort, maintenance, and support in the station of life in which they are accustomed. Except as provided herein, Husband and Wife do hereby waive, release, and give up any and all rights they may respectively have against the other for alimony pendente lite, spousal support, or maintenance. 4.2 It is specifically understood and agreed that this Agreement constitutes and equitable distribution of property, both real and personal, which was legally and beneficially acquired by Husband and Wife, or either of them, during the marriage as contemplated by the Domestic Relations Code of the Commonwealth of Pennsylvania. 4.3 Husband and Wife specifically waive, release, and give up any rights for alimony to which they may be entitled pursuant to Chapter 37 of the Pennsylvania Domestic Relations Code. ARTICLE V: DEBTS OF THE PARTIES 5.1 Each Party represents to the other that except as otherwise specifically set forth herein, there are no major outstanding obligations of the Parties; that since the separation, neither Party has contracted for any debts for which the other will be responsible; and each Party indemnifies and holds harmless, the other for all obligations separately incurred or assumed under this Agreement. Page 5 of 13 IT - In the event either Party contracted for or incurred any debts since the date of separation, the Party who incurred said debt shall be responsible for the payment thereof regardless of the name in which the account may have been charged. Husband and Wife acknowledge and agree that they have no outstanding debts or obligations of the Husband and Wife, which were incurred prior to the signing of this Agreement. 5.2 Each Party relinquishes any right, title, and interest he or she may have to any and all motor vehicles currently in the possession of the other Party. Within thirty (30) days of the date of the execution of this Agreement, each Party shall execute the necessary documents to have said vehicles properly registered in the other Party's name with the Pennsylvania Department of Transportation. It is the intention of the Parties that the 1999 Ford Ranger Pick-Up shall remain solely in Wife's name and that the I 993 Ford F-150 Truck shall be transferred solely to Husband. ARTICLE VI: CUSTODY AND SUPPORT OF CHILDREN 6.1 The Parties agree to shared legal and physical custody of the Children of the marriage. Both Husband and Wife shall be responsible for the day-to-day decisions when they have custody of the Children. Neither party has the right to make a unilateral decision of the following major issues: education; medical treatment (other than emergency treatment); and general welfare. It is agreed by and between the Parties that any decisions on these issues will be made jointly. 6.2 Each Party agrees to keep the other apprized of any and all matters relating to the Children's health, education, welfare, and activities. 6.3 Husband currently has primary physical custody of Heather and Wife currently has primary physical custody of Keith. Both Husband and Wife shall have reasonable, temporary custody and visitation rights when the Children are living with the other Party. Husband and Wife agree to allow the children to choose with which Party they wish to live at any given time. Page 6 of 13 :e"l'. -,:--r-;-' 6.4 Should Husband and Wife not reach an Agreement on visitation, Husband and Wife agree on the following custody schedule for the Children (such schedule is dependent upon with which Party the Children choose to live at any given time): 1. Weekends. On alternating weekends, Wife shall have custody of both Children beginning at 6:30 on Friday until 7:00 Sunday night. 2. Summer Vacation. Husband and Wife agree to split custody of the Children over the Children's summer vacation from school. Husband and Wife shall discuss and agree, by May 1 of each calendar year, the custody schedule for each respective summer. 3. Holidays. a) Thanksgiving - If the Parties have not reached an agreement on or before November 14, 2002 regarding visitation of the Children during the Thanksgiving holiday, the Parties will divide custody of the Children as follows: The Parties agree to alternate custody of the Children on an annual basis for Thanksgiving. Wife shall have custody of the Children beginning from after school on the Wednesday before Thanksgiving Day, 2002 through 3:00 p.m. on Thanksgiving Day, 2002 (hereinafter "Thanksgiving Morning") and on Thanksgiving Morning every even year thereafter. Husband shall have custody of the Children on Thanksgiving Morning, 2003 and on Thanksgiving morning every odd year thereafter. b) Christmas - If the Parties have not reached an agreement by December 14, 2002, the Parties will divide custody of the Children as follows: The Parties agree to alternate custody of the Children on an annual basis for Christmas. Husband shall have custody of the Children from 6:00 p.m. Christmas Eve, 2002 through 3:00 p.m. on Christmas Day, 2002 (hereinafter "Christmas Morning") and on Christmas Morning every even year thereafter. Wife shall have custody ofthe Children on Christmas Morning, 2003 and on Christmas Morning every odd year thereafter. c) Other holidays. - The Parties agree to alternate custody of the Children on an annual basis for the following other holidays each year: New Year's Day, Martin Luther King Day, Presidents' Day, Easter, Memorial Day, both Heather's and Keith's respective birthdays, July 4th, Labor Day, Columbus Day and Veterans' Day; with respect to this clause, a "Monday holiday" (holiday "observed") if any, is referred to, if it differs from the traditional date, and, in the Page 7 of 13 ~!RI;Ell'- ;I!"'-- - case of a Friday or Monday holiday on which the Children do not have school, and which immediately precedes or immediately follows a weekend on which said Party has custody, then the Friday holiday shall include the night between Friday and the weekend, and the Monday holiday shall include the night between the weekend and Monday. Once a schedule is established for any particular holiday, custody of the Children shall alternate between Husband and Wife every year according to that same schedule. d) Miscellaneous holidays. 1. The Parties hereto agree that they will cooperate and be as flexible as possible with regard to custody of the Children for any holiday or extended vacation period. In the event that any holiday discussed in this section or these Agreement falls on a weekend visitation of the Party not having primary physical custody of the Children, then the holiday schedule will take precedence over the normal custody schedule. 11. Wife shall have custody of the Children on every Mother's Day from 5:00 p.m. the day before Mother's Day until 8:30 p.m. Mother's Day. Husband shall have custody of the Children on every Father's Day from 5 :00 p.m. the day before Father's Day until 8:30 p.m. Father's Day. 111. Husband and Wife shall discuss and agree on a custody schedule for the Children at least two (2) weeks prior to any holiday not specifically mentioned in the Agreement. Once a schedule is established for any particular holiday not specifically discussed in this agreement, custody of the Children shall alternate between the Parties every year according to that same schedule. IV. The Parties may agree to modify this schedule without the necessity of a Court Order. It is specifically agreed between the Parties that visitation shall be as reasonable, liberal and frequent as possible. The periods outlined above are to take effect if the Parties can not agree as to a particular custody schedule. 6.5 It is the intent ofthe Parties that transportation of the Children between the Parties for all purposes, but especially custody purposes, shall be as flexible and accommodating as possible. For these purposes, the Parties agree to meet as close to half-way as possible to accommodate the custody schedule. It is recognized that transportation will obviously be dependent upon each Party's personal circumstances and employment. Page 8 of 13 ,",~~ '1""""- I - 6.6 Husband and Wife acknowledge their obligation to contribute to the support of their minor children. 1. Husband agrees to continue to pay to Wife, Seventy-Five ($75.00) Dollars per week in child support for Keith. Should both Children choose to live with Wife, Husband's monthly child support obligation will be calculated using the then-current net incomes of Husband and Wife to determine the new child support obligation. The new child support obligation will be determined by using the Child Support Guidelines for the Commonwealth of Pennsylvania in effect at that time. The Parties hereby agree that the provisions concerning child support may be entered as a Support Order in the Court of Common Pleas of Cumberland County, or in such other appropriate court. 2. Wife agrees that should she have a significant increase in income and the Children choose to live with Husband, the Parties shall examine the change-in-circumstances pursuant to the Child Support Guidelines for the Commonwealth of Pennsylvania in effect at that time, to determine if Husband in entitled to a monthly child support payment from Wife. 3. Should either Party have to make child support payments, the Parties agree that any and all child support payments shall be made every Friday. For the purposes of this Agreement, payments shall be deemed "made" if they are personally delivered or placed in the United States, First Class Mail, Postage Pre-paid, by Friday. 4. Child support shall continue for each child nntil said child reaches eighteen (18) years of age, or graduates from High School, whichever occurs later. 5. Husband and Wife hereby agree that up to One Thousand ($1,000.00) Dollars, annually, of investment income will be exempt for purposes of computing child support obligations. 6. The Parties hereby agree that as long as there is no cost involved, Husband shall continue to carry the Children on his health insurance coverage as long as the Children are eligible for said coverage. If and when health insurance becomes an out of pocket expense for either Party, the Parties will share equally, the costs of providing the Children with coverage similar to what they currently have as of the date of this Agreement. 7. The Parties hereby agree that as long as Heather lives with Husband and Keith lives with Wife, Husband will be responsible for any unreimbursed medical expenses incurred for the care of Heather and Wife wiII be responsible for any unreimbursed medical expenses incurred for the care of Keith pursuant to subsection (6), above. Page 9 of 13 -'illi'j 1'- . . . . 6.6 Beginning with the tax year that ends December 31, 2002, the Parties hereby agree that for Income Tax purposes, Husband shall claim Heather, and Wife shall claim Keith as dependants. ARTICLE VII: MISCELLANEOUS PROVISIONS 7.1 The Parties hereto have had the opportunity to retain independent legal counsel. The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, or the parties have voluntarily waived their right to have legal advice regarding the meaning and implication of this Agreement. The Parties acknowledge and accept that this Agreement is, under the circumstances, fair and equitable, that it is being entered into freely and voluntarily, after having received such advice, and with such knowledge that the execution of this Agreement is not the result of any duress or undue influence, and that it is not the result of any collusion or improper or illegal agreement or agreements. 7.2 Husband and Wife do hereby mutually remise, release, quitclaim, and forever discharge the other and the estate of the other, for all times to come and for all purposes whatsoever, of and from any legal right, title, and interest, or claims in, or against the property of the other, or against the estate of the other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter, may have, against such other, the estate of such other, or any part thereof, whether arising out of any former acts, contracts, engagements, or liabilities of such other as by way of dower or curtsey, or claims in the nature of dower or curtsey or 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 lifetime conveyance by the other as testamentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate, whether arising under the laws of (a) Pennsylvania; (b) any state, commonwealth, or territory of the United States; or (c) any other country, or any rights which either Party may have or at any time hereafter, have, for past, present, or future support or maintenance, alimony, alimony pendente lite, source fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except and only except, all rights and agreements and obligations of whatsoever nature arising, or which may arise, under this Agreement, or for the breach of any obligation thereunder. It is the intention of Husband and Wife to give to each other by execution of this Agreement, a full, complete, and general release with respect to any and all property of any kind Page 10 of 13 '-'"",", --II I' . . . . or nature, real or personal, not mixed, which the other now owns or may hereafter acquire, except, and only except, all rights, agreements, and obligations of whatsoever nature arising from, or which may arise under this Agreement, or for the breach of any thereof. 7.3 Each Party represents that since separation, they have not heretofore incurred or contracted for any debt, liability, or obligation for which the estate of the other Party may by responsible or liable, except as may be provided for in this Agreement. Each Party agrees to indemnify and hold the other Party harmless from and against any and all such debts, liabilities, or obligations of each of them, including those for necessities, except for the obligations arising out of this Agreement. Husband and Wife each warrant, covenant, represent, and agree that each will now, and all times hereafter, save harmless and keep the other indemnified from all debts, charges, and liabilities incurred by the other after the execution date of this Agreement, except as is otherwise specifically provided herein. 7.4 No waiver or modification of any of the terms of this Agreement shall be valid unless in writing and signed by both Parties hereto, and no waiver of any breach hereof, or default hereunder, shall be deemed a waiver of any subsequent default ofthe same, or similar nature. 7.5 This Agreement shall be construed in accordance with the laws of the Commonwealth of Peunsylvania which are in effect as of the date of this Agreement. 7.6 This Agreement shall be binding and shall inure to the benefit of the Parties hereto and their respective heirs, executors, administrators, successors, and assigns. 7.7 This Agreement constitutes the entire understanding ofthe Parties hereto and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. Page 11 of 13 1!I\'f; '-1' -' r ~ . . 7.8 If any term, condition, clause, section, or provision of this Agreement shall be determined or declared to be void or invalid, in law or otherwise, then only that term, condition, clause, or provision shall be stricken from this Agreement, and in all other respects, this Agreement shall be valid and continue in full force, effect, and operation. Likewise, the failure of any Party to meet his or her obligation under anyone or more of the Articles and Sections herein, shall in no way void or alter the remaining obligations of the Parties. 7.9 The Parties warrant and represent that they have made full disclosure of all assets prior to the execution of this Agreement. Each Party represents and warrants that he or she has made a full and fair disclosure to the other of all his or her personal property interests of any nature, including any mortgage, pledge, lien, charge, security interest, encumbrance, or restriction to which any property is subject. Each Party further represents that he or she has made a full and fair disclosure of all debts and obligations of any nature for which he or she is currently liable or may become liable. Each further represents and warrants that he or she has not made any gifts or transfers of marital property for inadequate consideration, without the prior consent of the other Party. Each Party further warrants, represents, and declares that each is, and has been, fully and completely informed of, is familiar with, and is cognizant of the wealth, real and/or personal property, estate and assets, earnings and income of the other Party, and that each has made a full and complete disclosure to the other of the extent of his or her entire assets and liabilities, and any further enumeration or statement thereof in this Agreement is specifically waived. Each party acknowledges that, to the extent desired, he or she has had access to all joint and separate State and Federal Tax Returns (including supporting documentation) filed by, or on behalf of, either or both Parties during marriage. 7.10 In the event that either Party to this Agreement shall breach any term, covenant, or other obligation herein, the non-breaching Party shall be entitled to, in addition to all other remedies available at law or in equity, recover from the breaching Party all costs of which the non- breaching Party may incur, including, but not limited to, filing fees and attorney's fees in any action or proceeding to enforce the terms of this Agreement. Page 12 of 13 ',T( I' -~~ l . . . 7.11 This Agreement shall survive any action for divorce and Decree of Divorce, and shall forever be binding and conclusive on the Parties; and any independent action may be brought, either at law, or in equity, to enforce the terms of this Agreement by either Husband or Wife until said terms shall have been fully satisfied and performed. The consideration for this Agreement is the mutual benefits to be obtained by both of the Parties hereto, and the covenants and agreements of each of the Parties to the other. The adequacy of the consideration for all agreements herein contained is stipulated, confessed, and admitted by the Parties hereto, and the Parties intend to be legally bound hereby. 7.12 The Parties both agree to cooperate with each other in obtaining a final divorce of the marriage. It is agreed that the Parties will execute and file the consents necessary to obtain the divorce. Any Party who fails to cooperate with obtaining the Divorce shall pay all the costs and legal fees of the Party who is seeking the divorce. 7.13 Husband agrees to provide Wife with health insurance coverage until such time as a Final Decree in Divorce is entered. . IN WITNESS WHEREOF, the Parties hereto have set their hands and seals the day and year first written, above. WITNESSED BY: Or t~ a YJy1~ (! w//! :J F~ Carol L. Fair (f-15 -0 ~ F:\User Folder\Firrn Docs\GendOcs2002\1535-1.MSA.wpd Page 13 of 13 "'o;;r.:'_"'r>"'~ 1-' ~ ~ ~-- ( I I I I I, i, Ii I Ii 'I"" II II I~ I! ~. , ~,., ,. ;r: .c,"_ ""'" '.,.", ", O~ _"<~" _ "~_ ~. ,~..~ . . IMI", Il!ll!~, _H'l~p~~ . ~u; ,. () 2 c: 0 ? "n- '"1:.'0:" .:.:,. qJn-j ,- :;1 ~.::o c=> 1:::r'i;2] < ("". ~ c.f)).~ -c.,'rTl -<' '-;--.- W :.0 tj ~C) () 1 ." -'1(J ~() .~c --r-" ;'.J:: b::d :;;:0 >0 c: - ofn ~ c:- ::;:;! ",,<, N 51 -<: _.t_,,___ ~t-""~ .'-~~ , '" . ., . , r - Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STEVE R. FAIR, v. NO. 00-1509 CNIL TERM CAROL L. FAIR, IN DNORCE AND CUSTODY Defendant 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. Grounds for divorce: irretrievable breakdown under ~ 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: By certified mail on March 30,2000. 3. Date of execution of the Affidavit of Consent required by ~ 3301(c) of the Divorce Code: by Plaintiff August 9, 2002; by Defendant August 15, 2002. 4. Related claims pending: All claims raised resolved in Marriage Settlement Agreement dated August 15, 2002. 5. Date Plaintiff's Waiver of Notice in ~ 3301(c) Divorce was filed with the Prothonotary: August 13, 2002. Date Defendant's Waiver of Notice in ~ 3301(c) Divorce was fIled with the Prothonotary: August 22, 2002. Date:~"'L-l.i ( 0 'L- CLt ' '~r Austin F. Grogan, Attorney for Plain . 24 North 32nd Street Camp Hill, PA 17011 (717) 737-1956 Id # 59020 -i'l_ "-" - ~.. 1-' -~ .. " ."'. . .. . AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND ... I, Austin F. Grogan, Esquire, hereby certify that I did mail a true and correct copy of the Praecipe to Transmit the Record in the above-captioned matter to the Defendant, Carol L. Fair, on August 26, 2002, at: Lindsay Gingrich Maclay, Esq. HANFT & KNIGHT, PoCo 19 Brookwood Avenue, Suite 106 Carlisle, PA 17013-9142 which satisfied the requirements of service by mail pursuant to Pa. R.C.P. 403. I understand that false statements are made herein are made subject to the penalties of Pa.C.S. ~ 4904, relating to unsworn falsification to authorities. Date ~ w( f7 1.-- ~~J Austin F. Grogan, Esquire Attorney for Plaintiff 24 North 32nd Street Camp Hill, PA 17011 (717) 737-1956 ill #59020 .'1:f1it '1'-' - -, '. '. ., '", '.. ~ -','c ,_"_ w , ~ - ,.1"..,.,..,.-.'" , ~ ., # (") <:-.-~ C ''0 ~ s:- " ",. "'00; ~ Q}r.r; G5 ~2 .,t;;...~_, zs N '=;~Z3 9:- "7" \.0 u(L, r:: r=) ----1",..", ",- :<>- ~2t~ ~O ::K 0 >c - Om z: .. -, =< ~ ~> 0::> ::0 -< ,,!I8~"""J!!~!~~,~~~~,,!l~..~~~_ '1'~1lImI!Il~ Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA C;u~L~ NO. 00 - f5VtJ STEVE R. FAIR, v. CAROL L. FAIR, IN DNORCE AND CUSTODY Defendant ORDER OF COURT AND NOW, this :J\ day of ~1- , 2000, upon consideration of the attached complaint, it is hereby directed that the parties and their respective counsel a~pe~ before tn\N\\~:-"~, the conciliator, at 0~)J,rr1\,,&\-,,~\Q~on the \~ day of p.,.,~ \ , 2000, at ~M., for a Pre-hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to defIDe and narrow the issues to be heard by the court and to enter in to a temporary order. Either party may bring the child/children who is/are the subject of the custody action to the conference, but the child's/children's attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. For the Court, By: 0t'c~\'\1\.. JJ.J\\\J\\dn()\~" ' Custody Conciliator (~ 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. OFFICE OF THE COURT ADMINISTRATOR CUMBERLAND COUNTY COURTHOUSE, FOURTH FLOOR CARLISLE, PENNSYL VANIA 17013 TELEPHONE NUMBER: (717) 240-6200 :;u " --'I '-"'- ~1iimt,J.~ . 1-~Il1I~Mliiil!li.~~!t~g';'~~~~iillII~a,.w_~.'''' '- "'--..'~' "nillliilibllllliaill!liiJ: rlO. FlI r-O....,t'''Ir:Cif'lC Or' - .....,,-' .....1 ift.l] J' !H~~ ,f.):)I"',TLr'jrlli-''T.dOY " ",,,- II :. ! ~,.) lr-lj", OOMJ1R23 Pi'12:27 CUM8ERLA"ID COUNTY PENNSYLVANIA -3 c)3 .c() 3bO'~ 3 'dJ .C),;:t w. ~.~ ~ cj7f ~~ ~ ~ '0 ~- ~~~~~~ '" ..., ~ .~- -" ,~ ". - - ." -,' ,-" ~.".~ .- - Uj Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. (H.J- /509 ~ ~ STEVE R. FAIR, v. CAROL L. FAIR, IN DNORCE AND CUSTODY Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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 judgement 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, Carlisle, Pennsylvauia. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DMSION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DNORCE 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 LmERTY AVENUE CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 ;;~~ ,-~ '",- - ~ ;--"-"-" ",~ - , ,""" I~ ' - Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. o-o~ /509 {;u.J '/LA--' STEVE R. FAIR, v. CAROL L. FAIR, IN DNORCE AND CUSTODY Defendant COMPLAINT 1. The Plaintiff is STEVE R. FAIR, Social Security number 177-42-4589, who currently resides at 342 Hunune1 Avenue, Lemoyne, Cumberland County, Pennsylvania 17043. 2. The Defendant is CAROL L. FAIR, Social Security number 166-54-9592, who currently resides at 1334 Valley Road, Coatesville, Chester County, Pennsylvania 19320. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the fIling of this Complaint. 4. Plaintiff and Defendant were married on April 13, 1985 at Chester County, Pennsylvania. COUNT I - DIVORCE 5. Paragraphs 1 through 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, Sections 3301(c) and 3301(d), in that: I~ ~, -' "'1"_' 1'- a) The marriage is irretrievably broken. b) Plaintiff and Defendant have lived separate and apart since August 24, 1999 and continue to do so. 8. The 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. 9. Defendant is not a member of the armed services. WHEREFORE, Plaintiff requests this Honorable Court to enter a Decree of Divorce. COUNT II - CUSTODY 10. Paragraphs 1 through 9 of this Complaint are incorporated herein by reference as though set forth in full. 11. The parties are the natural parents of two children, Heather Fair, born May 4, 1986, and Keith Fair, born April 23, 1991. 12. During the past five years, Heather Fair has resided with the following persons and at the following addresses: Steve Fair 342 Hummel Avenue Lemoyne, PA 17043 Oct. 1999 to present Carol Fair (Mother), Keith Fair (Brother), & Jason Fox (16 year old paramour) 1715 Norwood House Road Downingtown, PA 19367 August 24 to Oct. 1999 Steve and Carol Fair 342 Hummel Avenue Lemoyne, PA 17043 August 1996 to August 1999 Steve and Carol Fair and Keith Fair 336 Hummel Avenue Lemoyne, PA 17043 Feb. 1995 to Aug. 1996 "-il:; _~', .," .,-- " --, I, "'" 13. During the past five years, Keith Fair has resided with the following persons and at the following addresses: Carol Fair (Mother), Jason Fox (16 year old paramour), and an unknown woman Carol Fair (Mother) & Jason Fox (16 year old paramour) Steve and Carol Fair and Heather Fair (Sister) Steve and Carol Fair and Heather Fair 1334 Valley Road Coatsville, PA 19320 January 2000 to present 1715 Norwood House Road Downingtown, PA 19367 August 24, 1999 to January 2000 342 Hununel Avenue Lemoyne, PA 17043 August 24, 1996 to August 1999 336 Hununel Avenue Lemoyne, PA 17043 Feb. 1995 to Aug. 1996 14. The Plaintiff is the natural father of the children. 15. The Defendant is the natural mother of the children. 16. The children were born during wedlock. 17. The relationship of defendant to the child is that of Mother. 18. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the child in this or another court. 19. Plaintiff has no information of a custody proceeding concerning the child pending in a court of this Commonwealth. 20. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 21. The Plaintiff/Father seeks primary custody for the following reasons: ';;rij ~, --I"' I' , ~',~ a. The mother is currently in an illegal, inunoral relationship with a 16-year-old child, Jason Fox, born March 19, 1983. b. The children are currently separated from one another. c. The daughter, Heather Fair, is currently in counseling due to the mother's inunoral and illegal conduct. d. The Mother is currently in an unstable environment in that she has moved three times since August 1999 and continues to carry on in an intimate relationship with a juvenile. 22. Each parent whose parental rights to the child have not been tertuinated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, the Plaintiff, Steve Fair, respectfully requests this Court to award the father custody, with supervised visitation with the mother at the father's direction Respectfully submitted, Date ~/I?;/OO Austin F. Gro an, Attorney for Plaint 24 North 3200 Street Camp Hill, PA 17011 (717) 737-1956 ill # 59020 '-rr " -;:-"'-11-" " . ~, -, ~!' ~~,~ VERIFICATION I, STEVE R. FAIR, verify that the statements made in the foregoing 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. CoSo ~ 4904, relating to unsworn falsification to authorities. Date J!.fl1; I (f1J ~/#L STEVE R. FAIR , . '" Ii ~ . l Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STEVE R. FAIR, v. NO. 00-1509 CNIL TERM CAROL L. FAIR, IN DNORCE AND CUSTODY Defendant AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Austin F. Grogan, being dilly sworn according to law, deposes and says that he is the attorney for Plaintiff, Steve R. Fair, and that he did mail a true and correct copy of the Complaint in Divorce and Custody in the above matter, by certified mail, return receipt requested, to the Defendant, Carol L. Fair on March 27, 2000 her last known address: 1334 Valley Road, Coatesville, PA 19320, which satisfied the requirements of service by mail pursuant to Pa.R.C.PA03. The signed receipt acknowledging receipt on March 30, 2000 is attached hereto as Exhibit "A". Austin F. Grog , 24 North 32nd Str t Camp Hill, PA 17011 (717) 737-1956 Attorney for Plaintiff ill #59020 Date qnJ II) ';<000 C'~It~ ~,~~~~ -- 1--:- _.t 5. Received By: (Print Name) !i !, " III a 'ii II! c ~ " ~rtIfled! c u; " ~ .e ,,' ~ ... c .. .c .... ~. " ... 'iji " !! ~ " Ii c .: 3. Article Addressed \0: t (I {u{)J.j~cu/u ! /83,-/ J~I-Qw;L ~ (!t2~ PA- C ~ )e; 52.0 SENDER: .Complete 111 and/or 2 fat additional services. .Complete ; 3.48, ancl4b. .. Print your e and address on the reverse of this form so that we can return this card to you. . .Attach this form to the front of the mailpiece, or on the back If space does not permit. .Write"Return Rsceipt Requestsc/" on the mail piece below the article number. .1he Retum Receipt will show to whom the article was dellvered and the dale delivered. II: ~ " g, .!! j', e,stic RetiJrn'Receipl ~ EXHIBIT" A" 'i~ ~~~~ . , , Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STEVE R. FAIR, v. NO. 00-1509 CML TERM CAROL L. FAIR, IN DNORCE AND CUSTODY Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on March 15, 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. 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 Off/09 /0.2...- , I ~d2 STEVE R. AIR _ ,,~" '_''co;' '0'""," "~-, ~':-f"" - , " " ~,- ~RlIM ,_.,,"C,~ _, -~--^~~. .. (") 0 C r'--.) <" """ -Om ~-~~ mn, c: :r z~ yJ I fo-LJ z...... --j::;:-:' (fl.-' c;; -<:/ , ~C_) ""? I. -,.,; ,.. ~8 '<>~ (j 5>r- N c5~"n '7 ~.-\ ::3 '-'" '> :'b "' -< "",.,._!~~!~~WJl!ll!l_I__ nI!Tf\l\llI9ll~~ '-r-"~ .' . Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STEVE R. FAIR, v. NO. 00-1509 CNIL TERM CAROL L. FAIR, IN DNORCE AND CUSTODY Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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 innnediately 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: 02' /Oq /0;7 , . -' ~ -,- '_ -, ;___~p-: 'o,j" -~ ,lll_~~~," ~ 1 " '. ~_"fR ~~ o c s: 'L."tCG f:p!JJ 2=F:C! (?j 2~" r;C: ~l""" ~t~ Pc:: ~ o r,-, ;to. c:: GJ o '-,'j +.+~t .'{~ =D r- ',:::!II .-';-iCl , ',l -~;....J ;~~ );! :0 -<: GJ V ::t: r:::> :v ,I!l,,,,, " __,1l1llllll'~l'IJ"!i.~~_~~~~,...,..,.~, "1 "B~ . ~ . . . '" Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STEVE R. FAIR, v. NO. 00-1509 CIVIL TERM CAROL L. FAIR, IN DNORCE AND CUSTODY Defendant AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was fJIed on March 15, 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. 3. I consent to the entry of a fmal 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 '5-6~ ~~. ~ F~ CAROL L. FAIR COMMONWEALTH OF PENNSYLVANIA ss COUNTY OF CH~STER I;~ On August 15, 2002, before me a Notary Public, personally appeared Carol L. Fair, known to me to be the person whose name is subscribed to the within document and acknowledged that she executed the foregoing for the purpose therein contained. IN W1TNESS WHEREOF, I have hereunto set my hand and official seal. "",~~'^'9 ~ Notarial Seal Jermffer J. Tumer, Notary PUbl'lC Pad<esburg Bolo, Chestllr County My Commission ExpIres Oct. 22, 2005 Member. Pennsylvania Association Of Notaries ~j.~",~,~ ""'..- r; - - ~ ." - ., . . ,,1.1 " _,~.~>_IllI~~~~~~ -~= ~1 ITl[n_ c' 'c ." ~ - ., . .. ~ 0 a N -n ~ -l '"U1J:l :.c.." 2rT1 !7) "11"" :0 N ~~ ~S;, N 0", 6 ~,::;1 i K'" -u f):!J ~o :;.t 15Pn 0 !.:? s; ':0.., ~ '::;> ~ m '-< J._ITTI W_lY"-iW~,18'fQh11~~lIlll"'!~.ffiRWiil~~!lffi;~Ii-1-lm'Jlj -. 0 __ ~.~~~ . " .. ~ Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA STEVE R. FAIR, v. NO. 00-1509 CNIL TERM CAROL L. FAIR, IN DIVORCE AND CUSTODY Defendant WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 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! 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 innnediately 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: '3 -\ 5" -b~ (~ I. FiAk CAROL L. FAIR ij:,-~ _ - "0- _, ",_.__,_ 'i , >- ,.~ ~ I',' ~_R.~~,,,. I~ _~".....,_.~ JJJlU '" NJI!.L~ .. . ~ (') 0 0 ~ 1'0.) "1'1 :z, ..-< -OW ~ ~-t' 9293 rD :D r N -"Om ~~ "''I N Z~ "-,:1'-' CJ -0 ': =H ><::: ~(") :I: ~B 0 0 om ~ :::> ~ (1:) _,~!JmP!llq~~_M.'h....."~ ,...,._=~~,ft!iltlrIll\N', ,'lI!!lfJ!!~ i , . 1 " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA STEVE R. FAIR, Plaintiff CIVIL ACTION - LAW v. : NO. 00-1509 Civil Term CAROL L. FAIR, Defendant PRAECIPE TO: PROTHONOTARY Please enter my appearance on behalf of the Defendant, Carol L. Fair. Respectfully submitted, Date: April 17, 2000 EtJi!! Attorney ill #57976 19 Brookwood Avenue, Suite 106 Carlisle,P A 17013 (717) 249-5373 Attorney for Defendant F:\User Folder\Firm Docs\Gendocs2000\1535_1 elltry,app.wpd v~ ~" "-, 'f' , '. -1IQII!IlI ~ !Il"l!II'IJ'IIf!""'!I"'!__ml!!ll'll'l " ~, .,...~- "",:=- 1'!',,",~"~~, ~ o r-; ~ft~ Z"T! zt .sQ:-;~:: !:=r--, i> -~ ~2' z :~ .~"' (:J o ,- , " --'1'j -:;:=1 > "D ::0 -.J :::::"j >;~}~~: . ~;: ~:: ::,:~C) ':-~5rn ::;:~ ~o -.:,: . , .;';' .'~ ~ '" -~""""'~, - .(-~~ J:.,. MAY 30 2~ \ STEVE R. FAIR, Plaintiff : IN THE CDURT OF CDMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : vs. : NO. 00-1509 CIVIL TERM . . . . CIVIL ACTION - LAW CAROL L. FAIR, Defendant : : IN CUSTODY ORDER OF COORT AND !Oi, this 26th day of May, 2000, the Conciliator, having received no contact from counsel for either party to reschedule the Custody Conciliation Conference originally set for April 27, 2000, hereby relinquishes jurisdiction. FOR THE COURT, (~~ Dawn S. Sunday, Esquire Custody Conciliator " -'-. ~, ""r'-. - __~iW*""~.'-~' ""' '~~I -..... .... ~~li$i"jlijll;!i~~~M!iml~)~1m~!IlIiIf!- - '- - ~-'-J'~-r"- FILED-OfFlGE OF TliE pqOTHONOTARY 00 MA Y3 I PM I: I 3 CUMBERlJlND COUNTY PENNSYLVANIA I~" """""..- ~_i!~Il:"-.--" -"'" oo~ - ni'_ .- <' ., JT _',-,T.f,~