HomeMy WebLinkAbout00-02269
-!!! ~
.,
,
(
..
...
. .
.
.
. . .
,.,,.,,., :+: :+: :+:ff. :+:
.
:f. :+: '" "''''''''''
.
IN THE COURT OF COMMON PLEAS
.
.
.
OF CUMBERLAND COUNTY
.
STATE OF
PENNA.
.
LESLEY J. THOMAS,
.
No. 2000-2269 Civil Term
Plaintiff
VERSUS
.
.
HARRY D. THOMAS, JR.,
.
.
.
.
Defendant
.
.
DECREE IN
DIVORCE
at <lrf )\~ ~
.
.
.
.
, IT IS ORDERED AND
uo
2000
AND NOW,
.
.
.
DECREED THAT
LESLE J. THOMAS
, PLAINTIFF,
AND
HARRY D. THOMAS, JR.
, 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;
.
.
The attached Propertv Settlement Agreement. daten August 23. 2000,
.
.
.
is heeby incorporated, but not merged, into the Divorce Decree. .
.
.
.
.
.
.
.
~:+::f.:f.~~ ~ ~ "':f.~ "'~:f. ,., :f.:f.~
.
.
.
.
, J. .
.
.
.
.
.
.
.
.
.
~:+: :f.~~ :f.
~~ . ,>
-~~
, "':"
c", ,_" ,,"
I ~rr-.
. ~.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
"'""
lilt"'"
-
.'....'^
-IiIIlIii:l'
~"----
~-.
.......
'll '
;;.....~_~,~ ~"...~...... ';"'--:;'1..' '~'~. Wiiill
IIIiiIiilIiiiiIliiiliiIlIIiI
tfc;r?c;t:?
t/-;DCJ&
. '
. ~ ~.,
. ,,-,~
>""\
M~~7/;a5~L
~/H~~4/~
\
, "~~
~
, .
4
~
,
t
PROPERTY SETTLEMENT AGREEMENT
TRIS AGREEMENT,
made this d3~day of ~ooo by and
THOMAS of Cumberland C~~~' Pennsylvania
between LESLEY J.
(hereinafter referred to as WIFE), and HARRY D. THOMAS, JR. of
Cumberland County, Pennsylvania (hereinafter referred to as
HUSBAND) ,
WHEREAS, HUSBAND and WIFE were lawfully married on June 16,
1995 in Cumberland County, Pennsylvania; and
WHEREAS, the parties are the parents of one (1) minor child,
TREVOR W. THOMAS, born July 15, 1991; and
WHEREAS,
diverse,
unhappy
differences,
disputes
and
difficulties have arisen between the parties and it is the
intention of HUSBAND anq WIFE to live separate and apart for the
rest of their natural lives, and 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 by specification: the settling of all matters between
them relating to the ownership and equitable distribution of real
:"'''''\If
--,"'
"'" ""'~- ,
~
. ,
,
.
and personal property; the settling of all matters between them
relating to past, present and future support and alimony; and in
general, the settling of any and all claims by one against the
other or against their respective estates.
NOW, THEREFORE, in consideration of the premises and of the
mutual promises, covenants and undertakings hereinafter set forth
and for other good and valuable consideration, receipt of which is
hereby acknowledged by each of the parties hereto, HUSBAND and
WIFE, each intending to be legally bound, hereby covenant and agree
as follows:
1.
SeDaration:
It shall be lawful for each party at all
times hereafter to live separate and apart from the other party at
such place as he or she may from time to time choose or deem fit.
The foregoing provision shall not be taken as an admission on the
part of either party of the lawfulness or unlawfulness of the
causes leading to their living apart.
2.
Interference: Each
party
shall
be
free
from
interference, authority, and contact by the other, as fully as if
he or she were single and unmarried, except as may be necessary to
1
. " "~
"
, ' '",-"
, .
r
,
carry out the provisions of this Agreement. Neither party shall
molest the other or attempt to endeavor to molest the other, nor
compel the other to cohabit with the other, or in any way harass or
malign the other, nor in any way interfere with the peaceful
existence of the other, while living separate and apart.
3.
Subseauent Divorce:
The parties acknowledge that WIFE
has filed a Complaint in Di vorce in Cumberland County,
Pennsylvania, to docket number 00-2269 civil Term, claiming that
the marriage is irretrievably broken under the no-fault mutual
consent provision of Section 3301(c) of the Pennsylvania Divorce
Code. HUSBAND hereby expresses his agreement that the marriage is
irretrievably broken and expresses his intent to execute any and
all affidavits or other documents necessary for the parties to
obtain an absolute divorce pursuant to Section 3301 (c) of the
Divorce Code. The parties hereby waive all rights to request Court-
ordered counseling under the Divorce Code. It is specifically
understood and agreed by the parties that the provisions of this
Agreement as to equitable distribution of property of the parties
are accepted by each party as a final settlement for all purposes
2
',I,,"
, - ' . <, ,~, ~ ,
,.
, ,
,
. ,
whatsoever, as contemplated by the Pennsylvania Divorce Code.
Should a decree, judgment or order of separation or divorce be
obtained by either of the parties in this or any other state,
country or jurisdiction, each of the parties hereby consents and
agrees that this Agreement and all of its covenants shall not be
affected 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 shall
remarry. It is specifically agreed that a copy of this Agreement
or the substance of the provisions thereof, may be incorporated by
reference, but not merged, into any divorce, judgment or decree. It
is the specific intent of the parties to permit this Agreement to
survive any judgment and to be forever binding and conclusive upon
the parties.
4.
Date of Bxecution:
The
"date
of execution" or
"execution date" of this Agreement shall be defined as the day upon
which it is executed by the parties if they have each executed the
agreement on the same date. Otherwise, the "date of execution" or
3
"1.
. i <~
--,,~ , ^
.1-
jj
",,,, 0
, .
,
,
"execution date" of this Agreement shall be defined as the date of
execution by the party last executing this Agreement.
5 .
Distribution Date:
The transfer of property, funds
and/or documents provided for herein, shall only take place on the
"distribution date" which shall be defined as specified herein.
6. Mutual Release: HUSBAND and WIFE each do hereby mutually
remise, release, quitclaim and forever discharge the other and the
estate of such other, for all time to come, and for all purposes
whatsoever, of and from any and all rights, title and interests, or
claims in or against the property (including income and gain from
property hereafter accruing) of the other or against the estate of
such other, of whatever nature and wheresoever situate, which he or
she now has or at any time hereafter may have against the other,
the estate of such other or any part thereof, whether arising out
of any former acts, contracts, engagements or liabilities of such
other or by way of dower or curtesy, or claims in the nature of
dower or curtesy 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
4
.' ~~
.
'-.
-
, .
,
conveyance by the other as testamentary, or all other rights of a
surviving spouse to participate in a deceased spouse I s estate,
whether arising under the laws of (a) Pennsylvania, (b) any State,
Commonwealth or territory of the United States, or (c) any country,
or any rights which either party may have or at any time hereafter
shall have for past, present or future support or maintenance,
alimony, alimony pendente lite, counsel fees, property division,
costs or expenses, whether arising as a result of the marital
relations or otherwise, except, all rights and obligation of
whatsoever nature arising or which may arise under this Agreement
or for the breach of any provisions thereof.
It is the intention of HUSBAND and WIFE to give to each other
by the execution of this Agreement a full, complete and general
release with respect to any and all property of any kind or nature,
real, personal or mixed, which the other now owns or may hereafter
acquire, except and only except all right and agreements and
obligations of whatsoever nature arising or which may arise under
this Agreement or for the breach of any provision thereof.
It is further agreed that this Agreement shall be and
5
""
r-, "~_" ,~
--~
.
I
,
I
i
I
I
,
I
I
[
i
i
i'<R;
. .
constitute a full and final resolution of any and all claims which
each of the parties may have against the other for equitable
division of property, alimony, counsel fees and expenses, alimony
pendente lite or any other claims pursuant to the Pennsylvania
Divorce Code or the divorce laws of any other jurisdiction.
7.
Advice of Counsel:
The provisions of this Agreement and
their legal effect have been fully explained to WIFE by MARYANN
MURPHY, ESQUIRE, counsel for WIFE; and to HUSBAND by DAVID PERKINS,
ESQUIRE, counsel for HUSBAND.
HUSBAND and WIFE acknowledge and accept that this Agreement
is, in the circumstances, fair and equitable and that it is being
entered into freely and voluntarily and that 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.
8.
Warranty as to Existinq Obliqations:
Each party
represents that he or she has not heretofore incurred or contracted
for any debt or liability or obligation for which the estate of the
other party may be responsible or liable except as may be provided
6
.
~- ~--
'~
for in this Agreement. Each party agrees to indemnify and hold the
other party harmless for and against any and all such debts,
liabilities or obligations of every kind which may have heretofore
been incurred by them, including those for necessities, except for
the obligation arising out of this Agreement.
9.
EXISTING DEBTS:
HUSBAND agrees that he shall be
solely and exclusively responsible for any and all debts in his
individual name. HUSBAND further agrees that he shall indemnify
WIFE and hold her harmless from any and all liability for same.
WIFE agrees that she shall be solely and exclusively
responsible for any and all debts in her individual name. WIFE
further agrees that she shall indemnify HUSBAND and hold him
harmless from any and all liability for same.
The parties acknowledge that there two (2) debts in joint
names; a personal loan with American General with an approximate
balance of $5,000.00, and a personal loan with Beneficial with an
approximate balance of $2,000. Neither party agrees to be solely
responsible for either debt, nor have the parties reached agreement
with respect to a division of the debts. Therefore, HUSBAND and
7
"'
"'C""
, .
WIFE, understanding that these creditors may attempt to collect the
entire sums from one or both of the parties, and understanding that
this Agreement does not allocate these debts between the parties,
agree to leave the issue of the American General and Beneficial
debts unresolved.
10. Warrantvas to Future Oblia-ations: HUSBAND and WIFE each
covenant, warrant, represent and agree that, with the exception of
obligations set forth in this Agreement, neither of them shall
hereafter incur any liability whatsoever for which the estate of
the other may be liable.
Each party shall indemnify and hold
harmless the other party for and against any and all debts, charges
and liabilities incurred by the other after the execution date of
this Agreement, except as may be otherwise specifically provided
for by the terms of this Agreement.
11. Personal Property: The parties agree that HUSBAND shall
become the sole and exclusive owner of all personal property
currently in his possession, and WIFE shall become the sole and
exclusive owner of all personal property currently in her
possession.
8
,~ ,
. " ~,",""~,,
"~~
""~;"~
HUSBAND and WIFE agree that the division of property is
mutually acceptable to them. Neither party shall make any claim to
any such item of marital property or of the separate personal
property of either party which will be in the possession and/or
under the control of the other at the time of the execution of this
Agreement. Should it become necessary, the parties each agree to
sign, upon request, any titles or documents necessary to give
effect to this paragraph.
Property shall be deemed to be in the possession or under the
control of either party if, in the case of tangible personal
property, the item is physically in the possession or control of
the party at the time of the execution of this Agreement; and in
the case of intangible personal property, if any physical or
written evidence of ownership, such as passbook, checkbook, policy
or certificate of insurance or other similar writing is in the
possession or control of the party at the time of the execution of
this Agreement.
HUSBAND and WIFE agree that WIFE
12. Motor Vehicles:
shall become the sole and exclusive owner of the 1988 Ford Aerostar
9
: "!'I-.
.0
,"
'-~~--'~'
currently in WIFE's individual name. The parties ayknowledge that
there is no outstanding loan on this vehicle.
13.
Marital Residence:
HUSBAND and WIFE agree that WIFE
shall have sole and exclusive possession and ownership of the
mobile home described on the title as a 1985 Forte, currently
located at 36 Town Mills, Shippensburg, Cumberland County,
Pennsylvania, as of the date of the execution of this Agreement.
HUSBAND agrees to transfer all of his rights, title and interest in
the aforesaid mobile home to WIFE's individual name at the time of
the execution of this Agreement.
HUSBAND further agrees to
execute, upon request, any and all documents necessary to
effectuate the terms of this agreement.
14. Pension/Retirement Benefits: The parties agree that
HUSBAND shall retain any and all pension/retirement benefits he may
have accrued during the course of the marriage. WIFE agrees to
waive any and all rights and interest she may have in HUSBAND's
pension/retirement benefits. WIFE further agrees to execute, upon
request, any and all documents necessary to effectuate the terms of
this Agreement.
10
,~,~,~," - -
__ _ . ~o" 0 ,
r . ~
The parties agree that WIFE shall retain any and all
pension/retirement benefits she may have accrued during the course
of the marriage. HUSBAND agrees to waive any and all rights and
interest he may have in WIFE's pension/retirement benefits. HUSBAND
further agrees to execute, upon request, any and all documents
necessary to effectuate the terms of this Agreement.
15. After Acauired Personal Property: Each of the parties
shall hereafter own and enjoy, independently of any claims or right
of the other, all items of personal property, tangible or
intangible, hereafter acquired by him or her, with full power in
him or her to dispose of the same as fully and effectively, in all
respects and for all purposes, as though he or she were unmarried.
16. Applicability of Tax Law to Property Transfers: The
parties hereby agree and express their intent that any transfers of
property pursuant to this Agreement shall be within the scope and
applicability of the Deficit Reduction Act of 1984 (herein the
"Act"), specifically, the provisions of said Act pertaining to
transfers of property between spouses or former spouses. The
parties agree to sign and cause to be filed any elections or other
11
(h,
~'''~- --<-, '" . ,
,',
-~,~
documents required by the Internal Revenue Service to render the
Act applicable to the transfers set forth in this Agreement,
without recognition of gain on such transfer and subject to the
carry-over basis provisions of said Act.
17 . Wai ver of Alimonv:
The parties herein acknowledge that,
by this Agreement, they have respectively secured and maintained an
adequate fund with which to provide for themselves sufficient
financial resources for their comfort, maintenance and support.
HUSBAND and WIFE do hereby waive, release and give up any rights
they may respectively have against the other for alimony, spousal
support or maintenance. It shall be, from the execution of this
Agreement, the sole responsibility of each of the respective
parties to sustain themselves without seeking any support from the
other party.
18. Waiver of Spousal Support, Alimonv Pendente Lite and
Counsel Fees: Each party hereby waives any rights to spousal
support and alimony pendents lite. The parties agree to be
responsible for their own attorney's fees.
19.
Child Support:
The parties acknowledge that there is
12
"i"ffi
a current Child Support Order at the Cumberland County Domestic
Relations Office, docket number 00237 S 2000, PACSES number
397102128. HUSBAND's current obligation is $369.73 per month for
the support of the minor child. HUSBAND has filed an appeal of this
Order and the hearing is scheduled for August 31, 2000.
HUSBAND agrees to withdraw his appeal, and WIFE agrees to
execute a petition to suspend support within five (5) days of the
execution of this Agreement. The parties have agreed that HUSBAND
shall pay all arrears due and owing as of the date of the execution
of this Agreement at thirty ($30.00) dollars per week.
20. Full Disclosure:
HUSBAND and WIFE each represent and
warrant to the other that he or she has made a full and complete
disclosure to the other of all assets of any nature whatsoever and
of every type whatsoever in which such party has an interest, and
of all other facts relating to the subject matter of this
Agreement.
21. Disclosure and Waiver of Procedural Riqhts: Each party
understands that he or she has the right to obtain from the other
party a complete inventory or list of all of the property that
13
'-
,
either or both parties own at this time or owned as of the date of
separation, and that each party has the right to have all such
property valued by means of appraisals or otherwise. Both parties
understand that they have the right to have the Court hold hearings
and make decisions on the matters covered by this Agreement. Both
parties understand that a Court decision concerning the parties'
respective rights and obligations might be different from the
provisions of this Agreement.
Both parties waive the following procedural rights:
a. The right to obtain an Inventory and Appraisement of
all marital and separate property as defined by the Pennsylvania
Divorce Code;
b. The right to obtain an Income and Expense Statement
of the other party as provided by the Pennsylvania Divorce Code;
c. The right to have the Court determine which property
is marital and which is non-marital and equitably distribute
between the parties that property which the Court determines to be
marital;
d. The right to have the Court decide any other rights,
14
~<-m! ,<
. .
...
,~, ~t7-" <
~
remedies, privileges, or obligations covered by this Agreement,
including but not limited to, possible claims for divorce, spousal
support, alimony, alimony pendente lite, counsel fees, costs and
expenses.
22. Waiver of Modification to be in WritinQ': No modification
or waiver of any of the terms hereof shall be valid unless in
writing and signed by both parties and no waiver of any breach
hereof or default hereunder shall be deemed a waiver of any
subsequent default of the same or similar nature.
23. Mutual Cooperation: Each party shall, at any time and
from time to time hereafter, take any and all steps and execute,
acknowledge and deliver to the other party any and all further
instruments and/or documents that the other party may reasonably
require for the purpose of giving full force and effect to the
provisions of this Agreement.
24. Applicable Law:
This Agreement shall be construed in
accordance with the laws of the Commonwealth of Pennsylvania which
are in effect as of the date of execution of this Agreement.
25. AQ'reement BindinQ' on Heirs: This Agreement shall be
15
,"~
, '.T'
,,".
'.-~", ,-
.
binding and shall inure to the benefits of the parties hereto and
their respective heirs, executors, administrators, successors and
assigns.
26.
Intecrration:
This Agreement constitutes the entire
understanding of the parties and supersedes any and all prior
agreements
and
negotiations
between
them.
There
are
no
representations or warranties other than those expressly set forth
herein.
27. Other Documentation: HUSBAND and WIFE covenant and agree
that they will forthwith execute any and all written instruments,
assignments, releases, satisfactions, deeds, notes or such other
writings as may be necessary or desirable for the proper
effectuation of this Agreement.
This Agreement shall remain in
28. No Waiver on Default:
full force and effect unless and until terminated under and
pursuant to the terms of this Agreement.
The failure of either
party to insist upon strict performance of any of the provisions of
this Agreement shall in no way affect the right of such party
hereafter to enforce the same, nor shall the waiver of any default
16
I.
,
,
.~
'-
.
or breach of any provisions hereof be construed as a waiver of any
subsequent default or breach of the same or similar nature, nor
shall it be construed as a waiver of strict performance of any
other obligations herein.
29. Severability:
If any term, condition, clause 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 paragraphs herein, with the exception of the
satisfaction of the conditions precedent, shall in no way avoid or
alter the remaining obligations of the parties.
30. Breach: If either party breaches any provision of this
Agreement, 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 party
breaching this contract shall be responsible for payment of
17
I'~
6:,
.
.
reasonable legal fees and costs incurred by the other in enforcing
their rights under this agreement.
31. Headinas Not Part of Aareement: Any heading preceding
the text of the several paragraphs and subparagraphs hereof are
inserted solely for convenience of reference and shall not
constitute a part of this Agreement nor shall they affect its
meaning, construction or effect.
IN WITNESS WHEREOF, the parties hereto have set their
hands and seals this day and year first above written.
g-,:l3-dOc:iJo:A C ~
Date Witness
~~LJ ~~ [.-;
HARRY. . THOMAS, JR. c:.7
yJlgJ(l) ~~~QA4 ~ ~10!J))
~ Witnes LESLEY J. HO S
18
., .~,
.~
.
~~~
, .
_N. II,
,_,~ ,', I J.II~I!",... "
o
~;
~~~~r,.
[r.{~\'!
...;_. ~-;
-;C;' r'~-
::"25:
r::::r-:J
~:(')
"':-c-'
"'-:"'---'
';""C:
-;T
:::i.
-<
(2
1_.:'>
71)
r:1
'cJ
('o,)
11II
.
o
-n
:P'
:::~
_J
-,;
::---n
(-.:::~
-.., ~-h
-0,,;8
,.:~iS
~l~
.-.;;;
::g
~
-c:
(>
...:!
~Ii!!!<,~\ii~IItJi~""~"RJt,
OV_^~,~m
,
~
<
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
LESLEY J. THOMAS,
Plaintiff
: No. 2000-2269 Civil Term
v.
HARRY D. THOMAS, JR.,
Defendant
: 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:
I. Ground for divorce: Irretrievable breakdown under Section 330](c) of the Divorce
Code.
2. Date and Marmer of service of the Complaint: Sent to Defendant on Aoril20. 2000 bv
U.S. maiL oostage ore-oaid. certified/restricted deliverv. Received bv Defendant on April 22. 2000.
3. Complete either paragraph (a) or (b).
(a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the
Divorce Code: by Plaintiff, August 18. 2000; by Defendant, August 23. 2000.
(b )(1) Date of execution of the Plaintiffs Affidavit required by Section 3301(d) of the Divorce
Code: N/ A
(2) Date of filing and service of the Plaintiff's Affidavit upon Defendant: N/ A.
4. Related claims pending: All issues have been resolved by the Prooertv Settlement
Agreement dated August 23. 2000.
--"0/,
,
-
,
5. Complete either paragraph (a) or (b).
..
(a) Date and manner of service of the notice of intention to file Praecipe to Transmit
Record, a copy of which is attached: N/A.
(b) Date Plaintiffs Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: August 25. 2000.
(c) Date Defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the
Prothonotary: August 25. 2000.
Plaintiffs Social Security Number: 187-48-2877
Defendant's Social Security Number: 168-60-4790
~E~Wre
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
!.D. # 61900
'-f';;_
"
~
~
..
-
,_ __.u~"
.
~ ,~~~~-~,',~~ ',,",~".
.
.~ ..'
~ ~ ~"~~_...
,
'.
(') 0 ~
c C)
:s:: (/) --"*
-orD p, ,:~r~:;g
~r~ .'U
_I ,
ZC N ~~'.'i (J
~~ ~~:;1 C)
~O -0 .':-'-1-,
~o ::Ii:: ;] fT5
~2 r::- bm
,.-l
Z 0 :'I5
~~ (hi '-<
~~~~O'~Cl;j\fo'F;;r~~Y!1'1jIJf"mtm',la5g~~~f""V""Il'ffi'~IlI\liJ.!
....
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
LESLEY J. THOMAS,
Plaintiff
: No. 00 - 6la<09 Civil Term
v.
HARRY D. THOMAS, JR.,
Defendant
: IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HA VE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, you must take prompt action.
You are warned that if you fail to do so, the case may proceed without you and a decree of
divorce or annulment may be entered against you by the Court. A judgment may also be entered
against you for any other claim or relief requested in these papers by the Plaintiff. You may lose
money or property or other rights important to you, including custody or visitation of your children.
When the ground for divorce is indignities or irretrievable breakdown of the marriage, you
may request marriage counseling. A list of marriage counselors is available in the Office of the
Prothonotary, Cumberland County Courthouse, I Courthouse Square, 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 our WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, P A 17013
(717) 249-3166
'&",>-~
"-'> '
. ",.
,
~._,~
Le han demandado a usted a la corte. Si usted quiere defenderse en contra estas demandas
expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la
demanda y la notificacion. Usted debe presentar una apariencia escrita 0 en persona 0 por abogado
y archivar en la corte en forma escrita sus defensas 0 sus objeciones alas demandas en contra suya.
Se has avisado que si usted no se defienda, la corte tomara medidas y puede entrar una orden
contra usted sin previo aviso 0 notificacion y por cualquier que ja 0 alivio que es pedido en la
peticion do demanda. USTED PUEDE PERDER DINERO 0 PROPIENDADES 0 OTROS
DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI USTED NO
TIENE 0 CONOCES UN ABOGADO, VA Y AEN PERSONA 0 LLAME POR TELEFONO A LA
OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR
DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the Court, please contact
our office. All arrangements must be made at least 72 hours prior to any hearing or business before
the Court. You must attend the scheduled Conference or Hearing.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, P A 17013
(717) 249-3166
I
I
,
I
I
I
I
i
I
1""'1<
,
,:-"',j
~.1IIIIIIIliiIil
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
LESLEY J. THOMAS,
Plaintiff
N iJ-a r ;l'::U, <1 G;;J re....-.
: o.
v.
HARRY D. THOMAS, JR.,
Defendant
: IN DIVORCE
COUNT I
COMPLAINT UNDER SECTION 3301(c)
OF THE DIVORCE CODE
AND NOW comes LESLEY J. THOMAS, by and through her attorney,
Maryann Murphy, Esquire of Legal Services, Inc., who respectfully
avers as follows:
1. Plaintiff is LESLEY J. THOMAS whose current address is 36
Town Mills, Shippensburg, Cumberland County, pennsylvania.
2. Defendant is HARRY D. THOMAS, JR. whose current address
is 105 East Orange Street, Shippensburg, Cumberland County,
Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in
the Commonwealth for at least six months immediately previous to
the filing of this Complaint.
4. Plaintiff and Defendant were married on June 16, 1995
Cumberland County, Pennsylvania.
5. There have been no prior actions for divorce or for
~ ,3:"1
,~,"
,.'<<
~.
- ~', "-,,,. .
-
,-
annulment between the parties.
6. Defendant is not a member of the Armed Forces of the
United States of America or any of its Allies.
7. The marriage is irretrievably broken.
8. Plaintiff has been advised of the availability of
marriage counseling and that she may have the right to request the
Court to require the parties to participate in such counseling.
Being so advised, Plaintiff does not request that the Court require
the parties to participate in counseling prior to a Divorce Decree
being handed down by the Court.
9. Plaintiff requests this Court to enter a Decree in
Divorce from the bonds of matrimony.
COUNT II
CLAIM FOR EQUITABLE DISTRIBUTION OF MARITAL PROPERTY
UNDER SECTION 3502 OF THE DIVORCE CODE
10. Plaintiff hereby incorporates by reference all of the
averments contained in Count I of this Complaint.
11. Plaintiff and Defendant are the owners of real property,
retirement benefits, and other personal property acquired during
the marriage which are subject to equitable distribution by this
Court.
12. Plaintiff and Defendant have been unable to agree as to
?3f!
',~
.,
. ~--,,'
-
an equitable division of said property as of the date of the filing
of this Complaint.
13. plaintiff requests this Court to equitably distribute the
parties' marital property.
WHEREFORE, Plaintiff requests this Honorable Court to
enter a Decree:
a. dissolving the marriage between the Plaintiff and
Defendant; and
b. equitably distributing all property owned by the
parties hereto; and
c. for such further relief as the Court may determine
to be equitable and just.
Respectfully submitted,
Maryann urphy,
LEGAL SERVICES,
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
LD. # 61900
Attorney for Plaintiff
"\!~
~."~, , ,.'"'
, 0'-
,~
AFFJ:DAVJ:T
I, LESLEY J. THOMAS, verify that the statements made in the
foregoing Complaint in Divorce 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.
Lj/;;)Joo
Da'te /
~~
LESLEY J. OMAS
_,,:fijt,
_0
. .
.8I!lIII!i
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
LESLEY J. THOMAS,
Plaintiff
: No.
v.
HARRY D. THOMAS, JR.,
Defendant
: IN DIVORCE
CERTIFICATE OF SERVICE
I, Maryann Murphy, Esquire, do hereby certify that a true and
correct copy of the within Divorce Complaint was mailed to the
Defendant, HARRY D. THOMAS, JR., by first class U.S. mail, postage
pre-paid, certified/restricted delivery, addressed as follows:
Harry D. Thomas, Jr.
C/o Tammy Diven
105 East Orange Street
Shippensburg, PA 17257
Respectfully submitted,
Maryann Mu hy,
LEGAL SERVICES,
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
LD. # 61900
Attorney for Plaintiff
",""..
. ,.---
,.
,
,-
~
u~n~Q.
1'I."l1ll~_~
.
j ~
.'
'~.
~.
Jm'll~I"!1'~""",
, ,', "^'~ ,.
~
o
~;;:
-Oi,'/;
~'i~:'~
co '-"~ ~~
~~'t}
~2
~
~-
-l
-<
..
""
y\
c
\
-;;
--
'^'
G>
o
,-....
CJ
'"
liIii
~:?
-..,,1l'
;"":}
~::,:j
r',)
,:..i'"1
(J)
~:'~
~~5
._"
..,..",~~~"'J.
"'~~
.,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
LESLEY J. THOMAS,
Plaintiff
: NO. 00 - 'do. ~(P"l
v.
: IN DIVORCE
HARRY D. THOMAS, JR.,
Defendant
PRAECIPE TO PROCEED IN FORMA PAUPERIS
To the Prothonotary:
Kindly allow, LESLEY J. THOMAS, Plaintiff, to proceed in forma pauperis. I
Maryann Murphy, Esquire, of Legal Services, Inc., attorney for the party proceeding in forma
vauveris, certify that I believe the party is unable to pay the costs and that I am providing free
legal services to the party. The party's affidavit showing inability to pay the costs of litigation
is attached hereto.
~~Wre
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
J.D. # 61900
Attorney for Plaintiff
~'W
, . y__~ ,c" _^"',,
,-",,'
-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CML ACTION - LAW
LESLEY J. THOMAS,
Plaintiff
:NO.
v.
: IN DIVORCE
HARRY D. THOMAS, JR.,
Defendant
AFFIDAVIT IN SUPPORT OF PETITION
FOR LEAVE TO PROCEED IN FORMA PAUPERIS
1. I am LESLEY J. THOMAS, Plaintiff in the above matter and because of my financial
condition am unable to pay the fees and costs of prosecuting, defending, or appealing the action
or proceeding.
2. I am unable to obtain funds from anyone, including my family and associates, to pay
the costs of litigation.
3. I represent that the information below relating to my ability to pay the fees and costs
is true and correct.
(a) Name: LESLEY J. THOMAS
Address: 36 Town Mills. ShiDDensbuIl!. PA 17257
(b) Social Security Number: 187-48-2877
If you are presently employed, state N/A
Employer:
N/A
Address:
N/A
Salary or wages per month: N/A
Type of work: N/A
i ,"~,~, ,
~ 0"
,_",,_. ,-' ~, "'"''7 ' c'~
>~
a
If you are presently unemployed, state
Date of last employment: 2/23/00
Salary or wages per month: $1300.00
Type of work:
Industrial - labor
(c) Other income within the past twelve months
Business or profession: -0-
Other self-employment: -0-
Interest: -0-
Dividends: -0-
Pension and annuities: -0-
Social Security benefits: -0-
Support payments: -0-
Disability payments: -0-
Unemployment compensation and
supplemental benefits: -0-
Workman's compensation: -0-
Public Assistance: -0-
Other: -0-
(d) Other contributions to household support NONE
(Wife)(Husband) Name: N/A the parties are separated
If your (husband) (wife) is employed, state
Employer:
N/A
{'ol(IIii'OWIl!
" ~
c
<,,-,
-
\1
Salary or wages per month: N/A
Type of work: N/A
Contributions from children: -0-
(e) Property owned
Cash: $3.00
Checking Account: $5.00
Savings Account: -0-
Certificates of Deposit: -o-
Real Estate (including home): $3.000.00 (mobile home. ioint names)
Motor vehicle: Make Ford Aerostar
Year 1988
Amount owed
Cost $1.000.00
Stocks; bonds: -0-
Other: -0-
(t) Debts and obligations
Mortgage:
Rent:
Loans:
-0-
$170.00
$13.000.00 balance on all loans - cannot make payments at this
time
Monthly Expenses: $925.00
(g) Persons dependent upon you for support
(Wife) (Husband) Name: N/A
.~.
" ,~,
, ':'-",,,~-"
,'" ~, ~
,-
:;;
Children, if any:
Age:~
Name: Trevor
4. I understand that I have a continuing obligation to inform the court of improvement in
my fmancial circumstances which would permit me to pay the costs incurred herein.
5. 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:#
~
LESLEY J. TH MAS
"'t~
"-
" "
~
-~ ,
-
I
I
II
Ii
i'
11, "~
e
.,,1JIN!' ""
~ n ~~, .1l1lll!l"1!lIlJHlllft~
~. ~ '
r'---~
"""
_,I'",'J!jij',~W1,i' fH~li.
()
c
"'"I", f'~';
'Z;7F!.
c~~ ~,,-,.
l~j,
>,.c
:~<.
~
-'.
MNlJI~
c::>
>.J
r....:'
IIIi
,-
~n
,
"'l"""""
",,,,~"~
-
. Complei<l, 1 erMi.', .~liiz.AiS<ic6ml>l~i6
item ,4 if Restricted Delivery is desired.
~ \ Prin~ your name and address on the reverse
.'~O th~t we can r~turn the card to you.
. "Attach this card to the back of the mail piece,
or on the front if space permits.
1. Article ,6:id!essed to:
_y t. lho,IYlO-.-S) ~\,.
(aJYI((){ .~ I veAl
E(1~+ Ol--qAlae if
.' ~ A
llV\d ()..,('o' ~ '1~ 6 'I
, , id-.f
~
D, 15 -d~liv' address dIfferent from item 1?
If YES, enter delivery address below:
o Agent
o Addressee
DYes
o No
3:..~. ice Type
~~ertified Mail
o Registered
o Insured Mail
o Express Mail
o Return Receipt for Merchandise
o C.O.D.
. Restricted Delivery?
,C'l./.I'I, _.
".a!; '=""'ti"'"'!'
il
102595-99-M-1789
t
,
[
I
r
I
I
I
I
I
II
II
II
[I
II
II
i:
Ii
H
Ii
I:
"
ii
!'~ ,
",
IlIII!II'!I
"Jl!lflBlrllilll
, ,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
LESLEY J. THOMAS,
Plaintiff
: No. 2000-2269 Civil Term
v.
HARRY D. THOMAS, JR.,
Defendant
: IN DIVORCE
AFFIDAVIT OF SERVICE
I, Maryann Murphy, Esquire, depose and say:
I. That I am an adult individual residing in Cumberland County, Pennsylvania.
2. That on April 20, 2000, I sent by U.S. first class mail, postage pre-paid,
certified/restricted delivery, number 7099 3400 0004 5216 8112, a 330 I (c) Complaint in Divorce to
the Defendant, HARRY D. THOMAS, JR., at the following address:
Harry D. Thomas, Jr. .
c/o Tanuny Diven
105 East Orange Street
Shippensburg, P A 17257
3. That on April 22, 2000, the Defendant was served with the Complaint in Divorce
as evidenced by his signature on the green card, number 7099 3400 0004 5216 8112, which is
attached hereto.
.
Maryann M hy, Esquire
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
!.D. # 61900
-
, ""
I~
'O''''l\Ill!IIIIo.
....IJI:llIifilll\,~,
l]"'!l!" """",_~~Mlf.~~",
~ """'-!IlI1J
..
n 0 0
c: Cl
".. -"
""U -~ J) ----t
EPlX' fT1 -~
2m " ,~~;:;', 7T1
N . "'r
c:73~ ::'pcq
~..:;:. .JQ
::.J 1.
;,:::0 CJ --Ie)
~o ~ ;J-jj
~o in
Pc: c- com
~ .0 ~
-...I -<
,
~,.,......IIMIP~ffiJI~'MVlI"'~-W"!~Itl-'I"~~~I'!~fflfl!jl~)W@W'1f'1!ljIllffilm!~Il'!!~~
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
LESLEY J. THOMAS,
Plaintiff
: No. 2000-2269 Civil Term
v.
HARRY D. THOMAS. JR..
Defendant
: IN DIVORCE
AFFIDAVIT OF CONSENT
I. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April
12,2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
I verifY that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
00
~~lJ
LESLEY J. T MAS
. f''-
-~
'-iJ
I
I
I
l
C,.
..~...Jm .... '_" .... . ..
~i
"""""",
..<- '"-I"~ =
,,'
o
-0&:
~~~',
(f) '"~--:
r:;:(
if'
-.,,'
::::l
-<
'I'
-c.:~)
C'
E=
GJ
"", ~',,,;';';;
,. '.
I;~;;
1"')
eJ
i;?
';......,
(;:J
::g
--
~~~~~IM~~'~. ,~_
.. !!IIl!!!l!l1~
. , .
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
LESLEY J. THOMAS,
Plaintiff
: No. 2000-2269 Civil Term
v.
HARRY D. THOMAS, JR.,
Defendant
: IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
I. I consent to the entry of a final decree of divorce without notice.
2. I understand that I may lose rights concerning alimony, division of property, lawyer's
fees or expenses if I do not claim them before a divorce is granted.
3. I understand that I will not be divorced until a divorce decree is entered by the Court and
that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary.
I verifY that the statements made in this Affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
~ n )OD
Dat
~Q~ ~ ~01fYl(lD
LESLEY J. T OM S
,.,",':f1
"- "~~"
'1'''-- ~"
~
,
"-
,e ",'
.", '
, ,M!lIIQ!lI(!!!~1f.i'll\!!l!5l!ll
r . III
." '!I!l'
(')
~;
~~~~
~;=:
~~'-..
~~;
'S
~,
'.
-
",..'H' _.'''_,
"r.
,"'.'",
25
c')
.';..
.,
:C:ll!I
~~
!'o.)
(;;-
,-"
~r.
()
~"J
~.
"-)~L
/5i~i:;
:;;-1
~5J
-<
;:';)
!+'\)
Co
....~~!lj't-_~fiim(l'!!~~Qill!l'!fl_~..1f~, .
L,~.~jl'
. .
, "- )
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
LESLEY J. THOMAS,
Plaintiff
: No. 2000-2269 Civil Term
v.
HARRY D. THOMAS, JR.,
Defendant
: IN DIVORCE
AFFIDAVIT OF CONSENT
I. A Complaint in Divorce under Section 330 I (c) of the Divorce Code was filed on April
12,2000.
2. The marriage of Plaintiff and Defendant is irretrievably broken, and ninety (90) days
have elapsed from the date of filing and service of the Complaint.
3. I consent to the entry of a final decree of divorce after service of notice of intention to
request entry of the decree.
I verify that the statements made in this affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
J:A '3 . CJ-o
Date
~. 0 n;~.h
HA~ THOMAS, JR. t/
~,;;
,~,-F'
I, - "'.,[ <
-
$!
, -"
,.,"
.,_' "H
1-1
""-"'.
. "
C) C:;.'i-
C '-.-.}
:s::, }':'no
-0 (.D
rps:.:; ~.~~)
2: r' j',,} i:
:!d :-~~: c.;':
,.
r:::C::-' ~.'l J
~t~, - ' :.:; :.~~~~
"~~ C;,
~~) I , .
Pc: '.-;
Z :"'.J -=t;;
=<! ::::!
(;0 -
,~~
mllllpllllllll
~l!I!~~~lt!Ri!'lMIlll'fffl!lllW~i~~~_~!llf~~NI ~'~~"F" p:~~.
.. .
J. .., ,J
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
LESLEY J. THOMAS,
Plaintiff
: No. 2000-2269 Civil Term
v.
HARRY D. THOMAS, JR.,
Defendant
: IN DIVORCE
i
I
j
i
I
i
i
,
WAIVER OF NOTICE OF INTENTION TO REOUEST
ENTRY OF A DIVORCE DECREE UNDER
SECTION 3301(c) OF THE DIVORCE CODE
I. 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 ofthe decree will be sent to me immediately after it is filed with the Prothonotary.
I verify that the statements made in this Affidavit are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
Ii
3;).3cOO
Date
4~ 0 T)u,.v'N~c:f7
HARR . THOMAS, JR.
~,,"
,'-.,0,",: ,'C"
"," -, ~ -, '^-, ~'o' T_ ;
,"
,~,
~
",.'
..., ._ J
",
o<~,.,
"
mI.", ~
~.
() '-.'
c. c>
:;;: J,~
-0 IT: ':-S
gJ~E
~r. r,:;
~~~~ c.
r:::; C
)>r~,
~8 i"'-...)
~ ~'.j ::Ci
-< 0) -<
l?'"
"'m'.
. ,",
";'_"~,,, ,,.,,.,,_ ~JJ'i:j''I1'~PI'm"'lMJ~'fI!!~"~,,~',,!I'lfl~lfii~~_
r _'li"~~'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
LESLEY J. THOMAS
Plaintiff
v.
No. 2006-2269 Civil
HARRY D. THOMAS, JR.,
Defendant
IN DIVORCE
PRAECIPE FOR ENTRY OF APPEARANCE OF COUNSEL
To the Prothonotary:
Please enter my appearance on behalf ofthe Defendant, Hatty D. Thomas, Jr.
Dated: "^aJ G I LoQ-O
~ CJ. O~
David P. Perkins, Esquire
MARK, WEIGLE AND PERKINS - ATTORNEYS AT LAW _ 126 EAST KING STREET _ SHIPPENSBURG, PA 17257_1397
"1~" '_ """"
" 't' T," ~"' '---:,'.~, '~J 'C
,-';"",,- '-~ . ' ^.~ I'" -- ' '--,
',' ,
.
,
'"
~
1!!JlI!!Illlll~.~~l'Il'1'~
~n ,",
,,~__l
;("')
c-
~?
vm
rlli--"~
z~j
~'~~~'
~c.)
;,~().
,~C
J>(-=-
~
- "~, 0--
-
C)
C)
~
-'-"'"
-;;::
o
--:n
....
..~
.'11;2:
-,:,}rn
{~~6
',.i
?~
o ill
j;!
~
_J
:':J;,~
;'V
en
r:ki],'fJ]l'tpi:lIW"~I~!~~.'-_"~,,,~^
~~ ~~~.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
LESLEY J. THOMAS,
Plaintiff
: No. 2000-2269 Civil Term
v.
HARRY D. THOMAS, JR,
Defendant
: IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff in the above matter, having been granted a Final
Decree in Divorce on the 26& day of September, 2000, hereby elects to resume the prior surname of
Lesley J. Bums, and gives this written notice pursuant to the provisions of 54 P.S. Section 704.
Date:
/D/;s/rm
I I
~~e9~
COMMONWEALTH OF PENNSYLVANIA:
: ss:
COUNTY OF CUMBERLAND
On the / ~ day of r1l4~ , 2000, before me, a Notary Public, personally
appeared the above affiant 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 Witness Whereof, I have hereunto set my hand and official seal.
JP~_:_' JJll'-rZ
~. .
'J
NOTARIAL SEAL
PATRICIA A.SHATTO, Nqtary Public
Carlisle Boro, Cumberl~nd County
My Commission ~~Plrlhlgeeember 17, 2001
:~--.~
.
~~
If'"
,I
.'
.-
~ (") ..:.::..')-
-:b:::. j.J c ,2)
;gft ':::l
"oj
~ :z: ..
--'" '."j
-- -0 t;,~,"
() Sl. c~,. c.)
ll) -~ -""
fi' -., 2!: ~:-~:.' -,"'
~ :s )~\.._:
C
'-'\ '-'5 :::::
-." ::I .:,..)
~ , r~~,)
()
5J
VI
~
", .m~ ~"'1-"",~~~;;~r-l1~J:!I"*lI'>ll'ffi1'JN'iI'1.-,,,\'wr~!'f~~!Ii'I!~~~~~'~i9j4'-'I.'ni~ijIffll'l~~1jt1ffi~!l!!ll