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HomeMy WebLinkAbout00-02419 ~ !i'.~ ~.~ ~ ~ ~5 Wi ~~ .--- ~":~ ~ ~ i i J! l.,;"....,,;.:..,..,.:..,..,. . " " ~ ~'~ ~ "". ~.~ ~ i ~.~ ~.~ ~ ~'S ~ ~ ~.~ * ~ 'v' W !l'.~ ~ S: I1i ~ ~.~ i ~.~ ",,- ~ J>.~ ~~ a ~.~ ~~ ~ ~~ ~ i~~ ~ t:, ;"S ~ ~.i I i J>.~ ~":~ * ;..~ ~ ~". k~ ~ ~ .. 'I.... .... ( t , " ;:f'.:~~:: ::;~::.::;.;:. ~~~::.::(>3E~::)::C{::,.:.::~(:~~::.::!()_~:~~~~ :::~:+::'{:~~~~;~:::.::.::.( >::.:.;;" .;.::.)O.'.:::.3E(:~>>::.;:: '.~.::C{:':~:+::;';;: :;~::c;<:.:~::.::!;';;;t:::~::.)orx.::.~':~>>~fX.X,i~~>>::.<-:~~:+]-::::~:c(xc!;]::::!~D~lI ~ -.....-... ?i ~~ ~ ~ ~;.~ f' ~ ! IN THE COURT OF COMMON PLEAS ~ I ~.; ~ OF CUMBERLAND i ~.~ ~":~ I ,,','. ~'S ~ ;.,,:~ ~ ~ ~.~ ~.; . ""'- COUNTY STATE OF PENNA. ",,J1W,E'~' ..,J;\" "WM!R~G~!"... ~'S I ~ N , i . !i'.~ .. ",," m "Plaintiff.. '" "Uu N 0.. ~Q9.9::-,?41~,.. ........m...... Versus DeWAYNE,(;.",WI\I3R~GKI JR'l Defendant DECREE IN D I V 0 R C ~8:(O A.;11. AND NOW,..... ~.~~.........., li2000.., it is ordered and decreed that .... .J)\!i/F;'l;' .~, .WM!l.J;GI5. . . . .. . , . . , . . . . . .. . .. , , . , . ". plaintiff, and.......,..." .DeWAYNE.G..WABRICK"JR..........,........... defendant, are divorced from the bonds of matrimony. ~.s ~ ~,. ".~ ~'S ~ k;~ ~ ~ ~ :;'~: i ~.~ .~~~ ~.~ I H ~ H * ,'''. "'l' W ~.~ 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; None. All claims resolved by the Marital Settlement ~ ~.~ ~ \i'.~ ~ ~ ~.~ !\gj:"!3~ll:t,l. ,a.t,t,a.c:I1~C! .1}E1J;'E1t;Q . ~. ~1C!1~P~j:. tv. ~.i.C/1. .i.s. .h.e.r!3I:>Y. .i,n,c.qr!J:qr.a.t.e.C! .f.qr, ~ ~.~ l'!n;Ep):'p~nJ:. p).l):'pp,se,sJ. Put. no:t. me:t'geA/. mt.o. .this. Ae..c.r.e.e... . . . . . . . . . . . . . . . . . . . ~ ~.~ ",,' ~ ~.~ ~ ~.~ Prothonotary ~ ~.~ ~.~ ~ By ~ ~.~ J.. ~ ." Attest: u.~u ~ '.' ". _ ::C~~:: '::.:C.,:: :::0:'::( ':'.::C~:_: .::.:+~.< :':.::.::0,,: ):+::( :-,~::.::..: '::.::+;"-_ -".::+::<" .::.::'" -'.::+::'" ~~ ::-::+:;<::::::.::.::.:::::.::.::.-: >::+::'-:,>::+::":: )~>>::.'- -"'::.::": ':-:.::;',;: ::'::+::"': :':(+}:' '0 ,"", "" " ~"'". . ~ .. ,-~ ~"v'~ _ (JlcJcJ 1':J 1-t'eJ . ",-," ,'" ~- "', ~,. --'~, '.,' - '.., , -'' .,,'." '"; ""',"'-1,'~"-i_'",,-,_-'~-~-~ "- --''''''tiU"'''''''' '"'---"_"'i,'l_""~'~_', 'i"'~~I'," !I II ",,-.., .~. 'rY~-4jJ.,"-' \.':-. '.. ,~ dvf~~~ /l~ ~.~ " -'. ~ .. ....n ~_ ~< - ~ ,.~",~",.,J!'i]I, _~,...,~ ,'~,_, ~""'"l1-'f"'''~'~~ . r . MARITAL SE'.l"l'LEMENT AGREEHENT BY AND BE'lWEEN JANET B. WABRICK AND DeWAYNE GEORGE WABRICK, JR. Dawn S. Sunday, Esquire 39 West Main Street - suite #1 Mechanicsburg, PA 17055-6230 Telephone: (717) 766-9622 Counsel for: Janet B. wabrick " 14ll.i1~,', '!' . = -.' . r , MARITAL SE'l'TLEMENT AGREEMENT THIS AGREEMENT made this J /dJ day of , 2000, by and between JANET B. WABRICK, of CUmbe County, Pennsylvania, (hereinafter referred to as "WIFE"), and DeWAYNE GElCRGE WABRICK, .:JR., of Cumberland County, Pennsylvania (hereinafter referred to as "HUSBAND"), w .! T N E 2. S E ! H: WHEREAS, the parties hereto are Wife and Husband, having been married on August 14, 1982, in Allegheny County, Pennsylvania: WHEREAS, differences have arisen between Wife and Husband in consequence of which they have decided to live separate and apart from each other and agree to a mutual consent divorce: and WHEREAS, Wife and Husband desire to settle fully and finally their respective financial and property rights and obligations as between each other, including, without limitation, the settling of all matters between them relating to the ownership of real and personal property, the support and maintenance of their children and one another and, in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. ~ THEREFORE, the parties, intending to be legally bound, agree as follows: 1. ADVICE OF CXlUNSEL. Both parties agree and acknowledge that they have had ample and sufficient time to carefully and fully review the terms and provisions of this Agreement and to seek and obtain the advice "-j', , , and counsel of an attorney with respect to this Agreement. Wife has obtained legal advice from Dawn S. Sunday, Esquire. Husband acknowledges that he has been informed of his right to be advised by an attorney of his own choosing prior to entering into this Agreement and that he voluntarily has decided not to retain such counsel. Husband further acknowledges that he accepts this Agreement and that his acceptance is not based on any advice or representation made by Wife's counsel, Dawn S. Sunday, Esquire, nor has any such advice and/or representation been given to Husband by wife's attorney. Both parties agree and aCknowledge that they fully understand the facts upon which this Agreement is based, that they believe this Agreement to be fair and equitable, that this Agreement is being entered into freely and voluntarily by each of them, and that the execution of this Agreement is not the result of any duress, undue influence, collusion, or improper or illegal agreement or agreements. 2. DISCLOSURE OF ~. The parties warrant that they have given a full, complete and accurate disclosure of all assets, of any nature, whether or not the assets were held jointly or in one name alone. The remedies available to either party for breach or violation of this provision shall be those remedies available pursuant to law and equity including the right to punitive and compensatory damages. 3. PERSCNAL RIGHTS. Wife and Husband may and shall, at all times hereafter, live separate and apart. Each shall be free from all control, restraint, interference and authority, direct or indirect, by the other. Each may reside at such place or places as she or he may select. Each may, for her or his separate use or benefit, conduct, carry on or engage in any business, occupation, profession or employment which to her or him may seem advisable. Neither party will interfere with the use, - _. -", - , ownership, enjoyInent or disposition of any property now owned by or hereafter acquired by the other. 4. CHILD ::;upflCm. The parties aCknowledge that Wife has primary physical custody of the parties' Children, Evan Michael Wabrick, born June 15, 1989 and Shawn Raymond wabrick, born December 11, 1990, and further agree that Husband shall make all child support payments to Wife directly. Husband shall pay the amount of $1100.00 per IllOnth in child support for both children, with $550.00 to be paid on or before the first (1st) day of each IllOnth and $550.00 to be paid on or before the fifteenth (15th) day of each month. Husband's first $550.00 payment under this provision shall be due on July IS, 2000. Husband shall be responsible to pay 55% and Wife shall be responsible to pay 45% of the Children's medical expenses (which are not reimbursed by medical coverage) on a quarterly basis. For purposes of this provision, medical expenses shall be considered to include, but not be limited to, all health care, vision/glasses and dental care. 5. ~ DISTRIBUTIOO. A. Household and Personal Property. The parties agree that their household and personal property has been divided to their mutual satisfaction. The parties agree that they shall retain all personal property in their respective possessions and waive all rights as to personal property in the possession of the other party as of the execution date of this Agreement. Each of the parties hereby specifically waives, releases, renounces and forever abandons whatever claims he or she may have with respect to any of the foregoing personal property which shall become the sole and separate property of the other from the date of execution of this Agreement. B. Motor Vehicles. The parties agree that Wife shall retain " " - :'1 possession of and receive as her sole and separate property the Honda civic VP which she drives, along with all rights under any insurance policy thereon. Wife shall assume total responsibility for payment of any loans associated with the vehicle and all liens and encumberances thereon. Husband shall sign any documents necessary to transfer title of the vehicle to wife's sole name within 15 days of the execution date of this Agreement. The parties agree that Husband shall retain possession of and receive as his sole and separate property the 1998 Toyota camry which he drives and the 1991 Toyota Corolla Station Wagon, along with all rights under any insurance policies thereon. Husband shall assume total responsibility for payment of any loans associated with the vehicles and all liens and encumberances thereon. Wife shall sign any documents necessary to transfer title of the vehicles to Husband's sole name within 15 days of the execution date of this Agreement. C. Real Estate. (1) The parties acknowledge that during their marriage they held, as tenants by the entireties, the fee simple interest in the marital residence located at 25 Patton Road, Mechanicsburg, Cumberland County, Pennsylvania. The parties aCknowledge that the marital residence is currently listed for sale with Coldwell Banker. (2) After all encumbrances, including the mortgage from Standard Federal Bank (with a principal amount of $76,908.00 as of 3/25/00), and settlement costs are satisfied, the net proceeds shall be distributed between the parties as follows: Wife shall receive $18,000.00 and Husband shall receive all remaining net proceeds. (3) Husband shall be entitled to reside in the marital residence pending the sale. During the period in which Husband resides in the - - - ,. residence, Husband shall be responsible for all monthly payments on the mortgage and for all expenses incurred in connection with the residence including, but not limited to, repairs, taxes, insurance and utilities. D. Pension/Retirement Benefits. (1) wife shall retain as her sole and separate property, free from any claim by Husband, Wife's PSERS retirement plan ($46,249.00 value as of 6/30/99), the VAL Ie Annuity, account #3762604 ($39,272.00 value as of 12/31/99), and the Lincoln Life 403(b) tax deferred plan ($10,434.00 value as of 12/31/99). (2) Husband shall retain as his sole and separate property, free from any claim by Wife, Husband's AMP Inc. pension plan ($539.66 monthly accrued benefit, payable at age 65, as of 3/24/00), and Husband's First Union securities IRA account #U403 8697-1263 ($173,837.00 value as of 4/03/00), with the exception of $40,000.00 which shall be withdrawn from Husband's IRA and deposited into a separate qualifying account for Wife. The foregoing roll-over of funds in the amount of $40,000.00 shall be accomplished within 90 days of the execution date of this Agreement. In the event it is necessary to obtain a Qualified Domestic Relations Order (QDRO) in order to effectuate the roll-over, the cost of the QDRO shall be paid by Husband. E. Life Insurance. Each party shall maintain life insurance, with at least a minimum value of $100,000.00 for the benefit of the parties' children, until such time as the parties · youngest child reaches his eighteenth birthday. Husband shall obtain the life insurance benefits required by this provision within 90 days of the execution date of this Agreement. Wife represeents that her existing life insurance benefits satisfy this " "~ provision. F. Other Assets. (1) wife shall retain as her sole and separate property, free from any claim by Husband, the Mellon Bank Certificate of Deposit ($5,566.26 value as of 3/09/00), wife's DAUCO Federal Credit union Account, *2970-011 ($958.96 balance as of 12/31/99) and any other intangible personal property held by Wife on the date of execution of this Agreement or acquired thereafter. (2) Husband shall retain as his sole and separate property, free from any claim by wife, the balances remaining in the two Mellon Bank joint savings accounts after payment of the parties' joint expenses pending finalization of the divorce. In addition, Husband shall retain as his sole and separate property any other intangible personal property held by Husband on the date of execution of this Agreement or acquired thereafter. (3) wife and Husband shall retain the JANUS Funds, account *201369470, (hereinafter referred to as the "Education Account") held in joint names ($33,601.00 balance as of 12/31/99) for the benefit of their Children's education. Neither party shall withdraw funds from the Education Account without the prior approval of both parties in writing. The parties agree to deposit a minimum of $200.00 per month in the Education Account, with each party to be responsible for one-half of the deposit. The parties agree to assume equal responsibility for any tax liabilities associated with the Education Account. G. Miscellaneous Property. Any and all property not specifically addressed in this Agreement shall be hereafter owned by the party to whom the property is titled, and if untitled, the party in possession, subject to the provisions in paragraph 5(A) above. ,~ ~', 6. DISTRIBUTICl\1 OF LIABILITIES. (1) The parties agree that the distribution of debt as provided in this Agreement is fair and equitable and that neither party shall be responsible now or in the future for the debts assumed by the other party. Unless otherwise provided in this Agreement/ each party assumes the debt/ encumbrances/ taxes and liens on all the property each will hold subsequent to the date of this Agreement/ and each party agrees to indemnify and hold harmless the other party and her or his property from any claim or liability that the other party will suffer or may be required to pay because of such debts/ encumbrances or liens. (2) Each party represents and warrants to the other that she or he has not incurred any debt/ Obligation or other liability, other than those described in this Agreement/ on which the other party is or may be liable. A liability not disclosed in this Agreement shall be the sole responsibility of the party who has incurred or may hereafter incur it, and such party agrees to pay it as the same shall become due, and to indemnify and hold the other party and her or his property harmless from any and all such debts/ Obligations and liabilities. 7. INDEMNIFICATICl\1 OF WIFE. If any claim/ action or proceeding is hereafter initiated seeking to hold Wife liable for the debts or obligations assumed by Husband under this Agreement/ Husband will, at his sole expense/ defend Wife against any such claim, action or proceeding, whether or not well-founded/ and indemnify her and her property against any damages or loss resulting therefrom/ including/ but not limited to/ costs of court and actual attorney's fees incurred by Wife in connection therewith. 8. INDEMNIFICATICl\1 OF HUSBAND. If any claim, action or "~'I proceeding is hereafter initiated seeking to hold Husband liable for the debts or obligations assumed by Wife under this Agreement, Wife will, at her sole expense, defend Husband against any such claim, action or proceeding, whether or not well-founded, and indemnify him and his property against any damages or loss resulting therefrom, including, but not limited to, costs of court and actual attorney's fees incurred by Husband in connection therewith. 9. WARRANTY AS ro FUTlJRE OBLlGATlOOS. Wife and Husband each represent and warrant to the other that she or he will not at any time in the future incur any debt, charge or liability for which the other, the other's legal representatives, property or estate may be responsible. From the date of execution of this Agreement, each party shall use only those credit cards and accounts for which that party is individually liable. Each party hereby agrees to indemnify, save and hold the other and his or her property harmless from any liability, loss, cost or expense whatsoever incurred in the event of breach hereof. 10. TAXES. Wife and Husband warrant that they have paid all taxes on prior jointly filed returns including the calendar year ending December 31, 1999; that they do not owe any interest or penalties thereon; and that no tax deficiency proceeding or audit is pending or notice thereof received. Husband shall give Wife notice of any aeficiency assessment ana Wife shall give Husband notice of any deficiency assessment of which they individually or collectively become aware. The parties agree that should it ultimately be determined that any deficiency and/or penalty exists with respect to any jointly filed returns, the party responsible for the erroneous preparation and/or, non-disclosure or erroneous disclosure of information which has resulted in the deficiency and/or penalty, shall be ~ ~ . , " . solely responsible for the payment of the amount ultimately determined to be due, together with interest, as well as expenses that may be incurred to contest the assessment. 11. SUPPORT, ALJ:lo!OOY, ALJ:lo!OOY PENDENTE LITE. Both parties hereby waive any right or claim they may have against the other for alimony, alimony pendente lite and spousal support and maintenance. 12. WAIVER OF INHERITANCE RIGHTS. Unless otherwise specifically provided in this Agreement, effective upon the execution date, Wife and Husband waive all rights of inheritance in the estate of the other, any right to elect to take against the will or any trust of the other or in which the other has an interest, and each of the parties waives any additional rights which he or she has or may have by reason of their marriage, eJCcept the rights saved or created by the terms of this Agreement. This waiver shall be construed generally and shall include, but not be limited to, a waiver of all rights provided under the laws of pennsylvania, or any other jurisdiction, and shall include all rights under the pennsylvania Divorce Code. 13. WAIVER OF BENEFICIARY DESIGilATICU. Unless otherwise specifically set forth in this Agreement, each party hereto specifically waives any and all beneficiary rights in and to any asset, benefit or like program carrying a beneficiary designation which belongs to the other party under the terms of this Agreement, including, but not limited to, pensions and retirement plans of any sort or nature, deferred compensation plans, life insurance policies, annuities, stock accounts, bank accounts, final pay checks or any other post-death distribution scheme, and each party expressly states that it is her and his intention to revoke by the terms of this Agreement any beneficiary designations naming the other which are in ,~~ ...., ,-' J! effect as of the date of execution of this Agreement. If and in the event the other party continues to be named as beneficiary and no alternate beneficiary is otherwise designated, the beneficiary shall be deemed to be the estate of the deceased party. Notwi thstanding the foregoing, however, in the event that either party hereto specifically designates the other party as a beneficiary after the date of execution of this Agreement, then this waiver provision shall not bar the party from qualifying as such beneficary. 14. RELEASE OF CLAIMS. A. wife and Husband acknowledge and agree that the property dispositions provided for herein constitute an equitable distribution of their assets and liabilities pursuant to ~3502 of the pennsylvania Divorce Code, and wife and Husband hereby waive any right to division of their property except as provided for in this Agreement. B. Except as set forth in this Agreement, each party hereby absolutely and unconditionally releases and forever discharges the other and her or his heirs, executors, administrators, assigns, property and estate from any and all rights, claims, demands or obligations arising out of or by virtue of the marital relationship of the parties whether now existing or hereafter arising. The above release shall be effective regardless of whether such claims arise out of any former or future acts, contracts, engagements or liabilities of the other or by way of dower, curtesy, widow's or widower's rights, family exemption or similar allowance, or under the intestate laws or the 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 Pennsylvania, ~ ~~ ~: any state, commonwealth or territory of the united States, or any other country . C. Except for the obligations of the parties contained in this Agreement and such rights as are expressly reserved herein, each party gives to the other by the execution of this Agreement an absolute and unconditional release and discharge from all causes of action, claims, rights or demands whatsoever in law or in equity, which either party ever had or now has against the other. 15. WAIVER OF PROCEDURAL RIGHTS. This Agreement constitutes an equitable division of the parties' marital property. The parties have determined that the division of this property conforms with regard to the rights of each party. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division is being effectuated without the introduction of outside funds or other property not constituting the marital estate. Both parties hereby 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 nonmarital, 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, remedies, privileges, or obligations covered by this Agreement, or any possible claims not addressed in this Agreement. 16. PRFSmVATIOO OF RECORDS. Each party will keep and preserve " '"'i fot" a period of four (4) years from the date of their divorce decree all financial records relating to the marital estate, and each party will allow the other party access to those records in the event of tax audits. 17. FINALlZATlOO OF DIVORCE PROCEEDINGS. The parties acknowledge that wife filed a divorce action in the Dauphin County Court of Common pleas on April 19, 1999 to Docket No. 1588-S-1999. Wife and Husband agree that their marriage is irretrievably broken and that it shall be dissolved pursuant to ~3301(c) of the Pennsylvania Divorce Code. Unless they have already done so, the parties agree to sign Affidavits of Consent and Waivers of Notice and deliver them promptly to Wife's counsel for finalization of the divorce. 18. MODIFlCATlOO. No modification, rescission, or amendment to this Agreement shall be effective unless in writing signed by each of the parties hereto. 19. SEVERABll.ITY. If any provision of this Agreement is held by a court of competent jurisdiction to be void, invalid or unenforceable, the remaining provisions hereof shall nevertheless survive and continue in full force and effect without being impaired or invalidated in any way. 20. BREACH. If either party breaches any provision hereof, the other party shall have the right, at her or his election, to sue for damages for such breach, or seek such other remedies or relief as may be available to her or him. The non-breaching party shall be entitled to recover from the breaching party all costs, expenses and legal fees actually incurred in the enforcement of the rights of the non-breaching party. 21. WAIVER OF BREACH. The waiver by one party of any breach of this Agreement by the other party will not be deemed a waiver of any other -~-~ breach of any provi/3ion of this Agreement. 22. APPLICABLE LAW. All acts contemplated by this Agreement shall be construed and enforced under the laws of the Commonwealth of Pennsylvania in effect as of the date of execution of this Agreement. 23. DATE OF EXEClJrICN. The "date of execution" or "execution date" of this Agreement shall be defined as the date upon which the parties signed the Agreement if they do so on the same date, or if not on the same date, then the date on which the Agreement was signed by the last party to execute this Agreement. This Agreement shall become effective and binding upon both parties on the execution date. 24. EFFECT OF REXnl'CILIATICN, COHABITATICN CR DIVORCE. This Agreement shall remain in full force and effect and shall not be abrogated even if the parties effect a reconciliation, cohabit as Husband and Wife or attempt to effect a reconciliation. This Agreement also shall continue in full force and effect in the event of the parties' divorce. There shall be no modification or waiver of any of the terms hereof unless made in writing by the parties. 25. HEADIl\lGS NOr PART OF AGREEMENT. Any headings 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. 26. AGREEIiIENT BINDING CN PARTIES AND HEIRS. This Agreement shall bind the parties and their respective heirs, executors, administrators, legal representatives, assigns, and successors in any interest of the parties. 27. ENTIRE AGREEMENT. Each party acknowledges that she or he has carefully read this Agreement, that she or he has had ample opportunity to ~~. , ~ . ~" . discuss its provisions with an attorney of her or his own choice and has executed it voluntarily. This instrument expresses the entire agreement between the parties concerning the subjects it purports to cover and supersedes any and all prior agreements between the parties. This Agreement should be interpreted fairly and simply, and not strictly for or against either of the parties. 28. AGREEMENT TO BE INCCm'ORATED BUT NO!' MERGED. This Agreement shall be incorporated in a Decree of Divorce for purposes of enforcement only, but otherwise shall not be merged into the Decree. The parties shall have the right to enforce this Agreement under the Divorce Code of 1980, as amended, and in addition, shall retain any remedies in law or in equity under this Agreement as an independent contract. Such remedies in law or equity ace specifically not waived or released. IN Wl'l'NF.SS WIIEROOF, the parties hereto set their hands and seals on the dates of their acknowledgments. (fho / M) DATE/ / (/~ I/)#() DATE .tJ~ , , ~" ''', . . COMMONWEALTJz OF PENNSYL VANI!\. COUNTY OFU~~ : : 55. . . BEFORE ME, the undersigned authority, on this day personally appeared JANE::r B. WABRICK, known to me to be the person who executed the foregoing instrument, and who acknowledged to me that she executed same for the purposes and consideration therein expressed. 7'Y- "' HAND AND , 2000. day of and for the Pennsylvania ted name of Notary: Notarial Seal Chartyn Y. Guerriero, Notary Public My Commission Expires May 18, 2002 Member, Pennsylvania Associationol Notaries COMMONWEALT~F PENNSYLVANIA / CCUNTY OF L#~~J"v;I/ : : 55. . . BEFORE ME, the undersigned authority, on this day personally appeared DeWAYNJ!: GEXRGE WABRICK, JR., known to me to be the person who executed the foregoing instrument, and who acknowledged to me that he executed same for the pUJ:'poses and consideration therein expressed. ~ ~ MY HAND AND SEAL OF OFFICE this ~ >41./ day of ~ ,2000. " nd for the Pennsylvania ted name of Notary: Notarial Seal Cha~lyn Y. Guerriero, NOla Pu MyC '. ' e and County ommrsSlon Expires May 18,2002 Member, Pennsylvania ASsociation of Notarlas ~~ii1IMlilliillliril_~j~~]~m!.W~~~~WMlii' I~ ", c,_ ~'~11iW,~="'n . l'o'llIlwIiiIIiI ~" " ~ . i . D c..' (~" C 0 ,-," -n <': "'" ::;j -0 ti--! f1I (j"") ; ," -1; Z -~) Z S~ f'.) (f) CO -< ~~. ~ C) , , Z r- .,~ ;;;, c: CO tJ '7 ;;;! =< C) :0 -< ~ ~" . ' \ JANET B. WABRICK, : IN THE CXJURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : vs. . NO. 2000- 2419 CIVIL TERM . : DeWAYNE GEORGE WABRICK, JR., . . Defendant . IN CUSTODY . aIDER AND NCM, this ? 0 f1-\ , 2000, ~r day of upon consideration of the attached Custody Agreement, signed by the parties, the Court enters this Order. The terms of the Custody Agreement are approved and incorporated by the Court as its formal Order. The parties are directed to abide by the terms of the Custody Agreement as if the Order had been entered after a Hearing. J. ~ ~~~ r....... ut ",,-;:;:'\flY r',', '"'' ,., \..~) J<-:;.; .:,0 r--:: ;~: n5 CUIV!~;~; 1\ _M~:,',,, .C~:C;JNIY PCI\i;,"'(I\h'j;\ \.J _,,....,\),/'-\ ~ ,~&'hIIM . - , ~. ,~ -4l!1I~ 11_ > .lll!liIIilft:r.~_'~"f'''''0'''"_,*,1i''fi,,"~fil}'~,);;tj~IIi'Ii'J"~~~~ffW<jII~~~!.....~..,.,~! -'JO-'- ~ 'o<l.., '- ~" "",' ), ,..J- ~.. " JANET B. WABRICK, . IN THE OOURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. . NO. 2000-.,2 Ytt:t CIVIL TERM . : DeWAYNE GEORGE WABRICK, JR., : Defendant . IN DIVORCE AND CUSTODY . C) C'J C C) <? -0 EI~ ~: CUSTODY "...,.~~ .,..,-- !T.,,, .-) ..............., """"""..,.,.... Z :L ," ~ .... f"''') (Q)~~ c:o 0<.< r:::c'! This Agreement IIBde the 3()fIL day of ~ r~ "": 2000, by and between Janet B. Wabrick, of Mechanicsburg, Cumberland <l!mt~ Pennsylvania, hereinafter referred to as "Mother", and DeWayne G. raG'iick'; Jr., of Mechanicsburg, CUmberland County, Pennsylvania, herei~ftEllC refert"ed to as "Father". WIT N E SSE T H: ---------- WHEREAS; Mother and Father are the biological parents of Evan Michael Wabrick, born June 15, 1989, and Shawn Raymond Wabrick, born December 11, 1990: and WHEREAS, Mother and Father mutually desire to enter into a voluntary agreement pertaining to the custody of their Children: and I!iDf THEREIi'Clm, Mother and Father each intending to be legally bound, agree as follows: 1. Mother and Father shall have shared legal custody of Evan Michael Wabrick, born June 15, 1989, and Shawn Raymond Wabrick, born December 11, 1990. Each parent shall have an equal right, to be exercised jointly with the other parent, to IIBke all IIBjor non-emergency decisions affecting the Children's general well-being including, but not limited to, all decisions regarding their health, education, and religion. Pursuant to the terms of this paragraph each parent shall be entitled to all records and information pertaining to the Children inclUding, but not limited to, school and medical records and information. To the extent one parent has possession of any such records or information, that parent shall be required to share the same, or copies thereof, with the other parent within such reasonable time as to IIBke the records and information of reasonable use to the other parent. The parties shall share all medical and educational information concerning the Children and inform each other of school functions. 2. Mother shall have primary physical custody of the Children. 3. Father shall have partial physical custody of the Children in accordance with the following schedule: ~""...l..-~__=-i, -~.! ,- .,'-';1 -:-'~CJ - > ,1.., =-';:1:~ ;~~j~ o s;! :0 -< . ~" . ~ " "'''-'''" ; " -'\~!' ',r , r ''t'" A. DURING THE SCHOOL YEAR: (1). Unless the Father is traveling out of town, the Father shall pick up the Children after school on Mondays and take them to ceo classes and the Mother shall pick the Children up after class. In addition, the Father shall also pick up the Children after school on Wednesdays and return them to school on Thursday mornings. (2). On we~kends following weeks during which the Father travels out of town, the Father shall have custody of the Children from Friday evening through Sunday morning. On weekends following weeks during Ivhich the Father is not traveling out of town, the Father shall have custody of the Children from Sunday morning through Sunday evening. " (3) . At such time as the Father no longer travels out of town regularly for his employment, have custody of the Children weekends from Friday evening morning. the Father shall on alternating through Sunday. B. DURING THE SUMMER SCHOOL BREAK: (1) . Father shall have custody of the Children on every Monday and Wednesday evening at times to be arranged by agreement of the parties. (2). As long as Father continues to travel out of town on a regular basis for employment, Father shall have custody of the Children for 2 weekends in a row, beginning the weekend after school terminates, from Saturday at lunch time through Sunday evening and Mother shall have custody until Saturday at lunch time. On the third weekend, Father shall have custody from Friday after work through Saturday morning before lunch and the Mother shall have custody from Saturday at lunch time through Sunday evening. The schedule shall continue on a three weekend cycle. (3) . At such time as the Father no longer travels out of town regularly for his employment, the parties shall alternate having custody. of the Children on weekends from Friday through Saturday before lunch and from Saturday at lunch time through Sunday evening. c. The Father may have custody of the Children at other times as arranged by agreement of the parties. I"~ . ~ . 1-,._- ---""""~ " '-- . ' .,~- ., . " ~ "". , 4. The parties shall share or alternate having custody of the Children on holidays as follows: A. CBR:CSTMl\S: The parties shall share having custody of the Children over the Christmas holiday as arranged by agreement. B. EASTER/TllANKSGG: The parties shall alternate having custody of the Children on Easter and Thanksgiving with the specific times to be arranged by agreement. C. fov'J:tlISK'S DAY/FATaER'S DAY: Mother shall have custody of the Children every year on Mother I s Day and Father shall have custody of the Children every year on Father I s Day. D. MISCEJ:.LANEDlJS HOLIDAYS: The parties shall either share or alternate having custody of the Children on holidays not specifically addressed in this provision as arranged by agreement. 5. Each party shall be entitled to have custody of the Children for two weekS (consecutive or non-consecutive) each summer upon providing at least thirty days advance noticE!!"'-to the other party. The party providing notice first shall be entitled to preference' in his or her selection of vacation dates. . 6. Both parties shall ensure that neither the parties nor third parties smoke in the residence when the parties' son, Evan, is present. 7. The parties agree that it is important for the Children to attend church services regularly and agree to make every effort to ensure that the Children attend Mass on Sunday during their periods of custody. 8. The parties shall ensure that the Children have unrestricted telephone access to the non-custodial parent. 9. In the event either party intends to remove the Children from the Commonwealth for an overnight period or longer, that party shall notify the non-custodial party of the address and telephone number where the Children can be contacted. 10. Agreement by provisions of The parties may modify the provisions of mutual consent. In the absence of mutual this Agreement shall control. this Custody consent, the IN WI'JNFSS WHERIOClF, the parties hereto have VOluntarily executed this Agreement and agree that it shall be entered by the Court as an Order. Ie /?j/{)-() Date I Date~/~o/ 6-0 f 7 I I '/ era "0 _j "7 __ /"fUQ Jl... 0) ,IJ0 / -2 > 0~ 0 c) / " " ""."~.'J. <: h J' )\ .....----;- 0t \..-J i ~ -- - --- . ---J-; ! t j (J rJ "..-- ____-u Sj))C~(j ." ..4""'......1-..-...... " -'- "~ ~ JCJ(>.:u _~ I ----~.......\ ., ,; ~ -- -> / r ill ."~ -'- '-., JANET B. WABRICK, . IN THE OJURT OF OJMMON PLEAS OF . Plaintiff . CUMBERLAND OJUNTY, PENNSYLVANIA . : vs. . NO. 2000-2419 CIVIL TERM . . . DeWAYNE GEORGE WABRICK, JR., . . Defendant : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Please transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: Irretrievable breakdown under ~330l(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Acceptance of Service signed by Defendant on April 23, 2000, a copy of which is attached. 3. Date of execution and filing of the Affidavits of Consent and waivers of Notice required by ~330l(c) of the Divorce Code: By Plaintiff: Executed July 24, 2000, filed August 22, 2000. By Defendant: Executed July 24, 2000, filed August 22, 2000. 4. Related claims pending: None. All claims settled by Marital Settlement Agreement dated June 30, 2000. DAT~~J- C)! ~n , a~~~dlJ'7 Dawn S. Sunday, Esquire Attorney for Plaintiff ID #41954 39 W. Main Street - Ste. #1 Mechanicsburg, PA 17055-6230 (717) 766-9622 li.tii;JO.. "-iUIilIIIMIiIIi~~~AA;iO,~f!r~iiiilI~'(~ "' ]ii ~ '._"~- < .,...,~, C) 0 0 C c.:) -n ~ ~ ~ "~1 -01:::[; .,,- ~~~ 2~ n1rz:: "'-., Z.c, 1'0 ~s;23 ze ~:;~~ CO -., I '":::j(~ KC) );>0 "T-l' )>c: ,. ?s~ :z ) )>0 9? c s;! ~ 0 :n -< t: ~"-- ill.-'.Jio\;._lloIiJ~, " . JANET B. WABRICK, . IN THE OJURT OF OJMMON PLEAS OF . Plaintiff . CUMBERLAND OJUNTY, PENNSYLVANIA . . . vs. . NO. 2000-.;1.4/9 CIVIL TERM . . . DeWAYNE GEORGE WABRICK, JR., . . Defendant . IN DIVORCE AND CUSTODY . NOrICE TO DEFEI!iID AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the fallowing pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary at: CllMBERLAND COUNTY COURT IKXJSE, CARLISLE, PENNSYLVANIA 17013. ~ IF YOU 00 NOr FILE A CLAIM FCR ALIMCIiY, DIVISICN OF PROPERTY, ~'S FE&S CR EXPENSES BEFCtm A DIVCRCE CR ANNI:JLMEN'l' IS GRANTED, YOU MAY LOSE THE RIGBT TO CLAIM ANY OF THEM. YOU SBOOLD TAKE THIS PAPER TO YOOR ~ AT CNCE. IF YOU 00 NOr HAVE A ~ CR CANNOl' AFI10RD QiIE GO TO CR TELEPfKl!lE THE OFFICE SET F<RrH BELCM TO FIND OUT WIIERE YOU CAN GET LEGAL HELP. CUMBERLAND OJUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE: (717) 249-3166 TOLL FREE: 1-800-990-9108 _.~ ~ ",~~;" r/ . , JANET B. WABRICK, Plaintiff . . IN THE CXlURT OF OOMMON PLEAS OF CUMBERLAND OJUNTY, PENNSYLVANIA . . . . vs. : NO. 2000- CIVIL TERM : DeWAYNE GEORGE WABRICK, JR., Defendant : . . IN DIVORCE AND CUSTODY ccm>LAINT Plaintiff, Janet B. Wabrick, by her attorney, Dawn S. Sunday, sets forth the following: 1. Plaintiff is Janet B. Wabrick, who currently resides at 25 Patton Road, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant is DeWayne G. Wabrick, Jr., who currently resides at 25 Patton Road, Mechanicsburg, Cumberland County, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six montha immediately preceding the filing of this Complaint. 4. plaintiff and Defendant were married on August 14, 1982 in Allegheny County, pennsylvania. 5. There have been no prior actions for divorce or for annulment between the parties. 6. 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. COON'l' I - DIVCRCE 7. The averments of paragraphs 1 through 6 are incorporated herein by reference. 8. The parties have been and currently are living separate and apart, and not as husband and wife, in the marital residence and Plaintiff avers, as the grounds upon which this action is based, that the marriage between the parties is irretrievably broken. 9. Plaintiff requests that the Court enter a Decree of Divorce under section 330l(c) or 330l(d) of the Pa. Divorce Code. - "~"'1~'_i ,. .,.,- . , COONT II - CHILD CIJS'.LWY 10. The averments of paragraphs 1 through 6 are incorporated herein by reference. ll. Children: Plaintiff seeks primary physical custody of the following Evan Michael Wabrick, born June 15, 1989 Shawn Raymond Wabrick, born December ll, 1990 12. The Children were not born out of wedlock. 13. The Children are presently in the custody of Plaintiff and Defendant who reside at 25 Patton Road, Mechanicsburg, Cumberland County, pennsylvania. Plaintiff and Defendant are residing separate and apart in the marital residence pending finalization of Plaintiff's arrangements to relocate with the Children to another residence and sale of the marital residence. 14. During the past 5 years the Children have resided with the fallowing persons at the following addresses: Janet B. Wabrick and DeWayne G. Wabrick, Jr. 25 Patton Road Mechanicsburg, PA 15. The biological Mother. marital residence. relationship of Plaintiff to the Children is that of Plaintiff currently resides with the Children in the 16. The biological Father. marital residence. relationship of Defendant to the Children is that of Defendant currently resides with the Children in the 17. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the Children in this or another Court. 18. Plaintiff has no information of a custody proceeding concerning the Children pending in a Court of this Commonwealth. 19. Plaintiff does not know of a person not a party to the proceedings, who has physical custody of the Children or claims to have custody or visitation rights with respect to the Children. 20. The best interest and permanent welfare of the Children will be served by granting the relief requested because the parties have amicably made arrangements between themselves for custody of the Children upon Plaintiff's imminent move from the marital residence and Plaintiff . " - ~ "' >Jd'h Or . , wishes to have these arrangements incorporated into a Court Order for protection of the parties. 21. Each parent whose parental rights to the Children have not been terminated and the parties who have physical custody of the Children have been named as parties to this action. WHEREFORE, Plaintiff requests that the Court grant shared legal custody of the Children to the parties, with primary physical custody in Plaintiff and partial physical custody in Defendant. Respectfully Submitted, Dag~ Attorney for Plaintiff ID #41954 39 west Main Street - Ste. #1 Mechanicsburg, PA 17055-6230 (717) 766-9622 ~- ~_. .....v.. . , VERIFICATIOO I verify that the statements made in this Complaint 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. L/ 1!3 /cro DATE I ! 1$, tJ .~ ~~ ~ . .-- -.--,- . [''''"" :lllij~~.;.",,-~ :I~~'"',_- '~l~ .~.",>-",-,~~~ ...~~ ~" "~'~"'.-l-' LJJllllkllilillQ 'U#"" ~ ~ ~., ~ {:j ~ ~ ~ - 0 r-o r-) /\j B .llJ ~ ~ c c:-) '1/ :": ,~ ~ li- I!.. \) c-z -C:U1 _.;,J '. 0 [!:!C!: :~':J 1.= ~ 0 D L_,_',; . Ti a ~ ~ Zr:" J~..., ~ ,',". . 0-.1 -i;r; () () '-.",,- -< .' ~ ~~~c .0:1 ( I s: ~=~ . , ~1 .';",,-' - ,",-.- I 5;~ ~"J . _:,~ ;T1 ~ ~ '" ~j 0 "7 '''' S p:: ~ <1' -< ~ ("-'. Cf . - , -" ~-~""'-~) . . . " JANET B. WABRICK, : IN THE OJURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND OJUNTY, PENNSYLVANIA . . . vs. . NO. 2000-,;}"//9 CIVIL TERM . . . DeWAYNE GEORGE WABRICK, JR., . . Defendant : IN DIVORCE AND CUSTODY ACCEPTANCE OF SERVICE I accept service of the Divorce Complaint. I-/Ia '? 16 () Date . Ji tj/71n/( Wabrick, Jr., D , c'-" _ ,_ I ,'";.;,~_~ lIi.ilf.......".~"'- ' < ,. ~^ ..~- ~h _.~ ~. >..~ I ~, ~O~_" "alI$.lIl- u -0 ....,-I~tf ~~~ ~~ . "~~. ~- '~18i - --.. """-~ -'~ ,,~~- ~ '^' . () Cl k 0 $. ~ -0 IT":: '0._ n1r-;"": Go? Z:r:, r-,,) :Z~ ~ (......~ ~~?:; .on.- ~~ ~ )>~ 9? z =<! c> ~ " ", LJ " ---]'0 ,,'......,., -'))... ~4'-.) .J~~ =8 W~' )> Xl -< " - - ", . . .' JANET B. WABRICK, : IN THE OJURT OF OJMMON PLEAS OF Plaintiff . CUMBERLAND OJUNTY, PENNSYLVANIA . . . vs. . NO. 2000-2419 CIVIL TERM . . . DeWAYNE GEORGE WABRICK, JR., : Defendant . IN DIVORCE . AFFIDAVIT OF <nlSmiIT 1. A Complaint in Divorce under ~330l(c) of the Divorce Code was filed on April 17, 2000 and served on April 23, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of 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. 4. 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. I verify that the statements made in the 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. ix 'I ~o Date' I !i_i.~rl,,,,,,,L..<>. J_~~.""'< -~JllJil,i!jj~.& ~., ~~-"~'~ ". ...~~.~ J " "-lIiMlrr1IT~"'" ,'" , '. . 0 0 ~ 0 C) -'1 <;10: "'" nJr~ c:: :z: I.: G? tiJr:: f\.) ,,' =<2: co ).- ~c..':J ':.:J;.r "'" -'1"_) ?Eo '3= ~~~.~ :;>0 c ~ or/1 2: -, ::t 0 55 -< . - - ~-~~ ~~~ "" ""~'~ . .. " . JANET B. WABRICK, . IN THE OJURT OF OJMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. : NO. 2000-2419 CIVIL TERM : DeWAYNE GEORGE WABRICK, JR., . . Defendant : IN DIVORCE WAIVER OF NarICE OF INTENTIClIT TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~330l(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. H904 relating to unsworn falsification to authorities. 7/;}~/ 60 Pate; ~tJ~ Wabrick, Plaintiff 'I_JilW' ,-~LiL_~_..........lt: '.'0<-1'- ~,'" 'liD~I~~~' " iIlIBl.ilIIlIiMi ~'" .~. '-"-~~ " ~'"" "I :1 '.'1' , , I' II II II !' . . C) 0 ~,J C C1 " s: """ vG:: mfY, C) T; Z:n r t55~.': f'.,) ~:::; -<:"";-, 00 . . , ,<,C! :p" :':"i~) ~c --..~. >\:0 ,,-;;C) :;;;:0 0.') 001 C ;.-.:: '-4 )> =<! Cl ::0 -:: " ,-- " -.. """-" . l'. ,,- ~.. . JANET B. WABRICK, : IN THE OJURT OF OJMMON PLEAS OF Plaintiff . CUMBERLAND OJUNTY, PENNSYLVANIA . : vs. . NO. 2000-2419 CIVIL TERM . . . DeWAYNE GEORGE WABRICK, JR., : Defendant . IN DIVORCE . AFFIDAVIT OF <XIlSENT 1. A Complaint in Divorce under ~330l (c) of the Divorce Code was filed on April 17, 2000 and served on April 23, 2000. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of 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. 4. 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. I verify that the statements made in the 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. 7/8 'I/(9cJ Date dJ1J~~ ~~, l/~rA~ DeWayne rge Wabr. , Jr., Defe t "i, i' ~-'-;'"., - > \.~-'. I ,'--"..~,""". ~ ~~" -- -~ i.'- - . ;--,.- ,","r"~[-- tIIlJif _.;,___~..,D .".""__~".. ... __, .. ~~ "~~ _ <. ,_o~ .="",,~~-~... ,-., ~-_. ~- ...~"~~.......- 0." ~- " "~~ . , ~ '" .~ . , .. 0 0 () C Cl " $: 1>0 :--::-t ""Ow ,- n1r!) G? --I", Z-,-, "= ZF" J'V -::'1-'..-' V?~ ':0 .n ''-'' ::<.: ~::---- ){g ~C) """ ~C ::E: ~C) :;;::;. () PC': ~ C;;n'l z ~ =<! (:) -< ", , ~ . -~ ~~ ~ ~~..," ~. ""'""" . -,. .. ~ "\ .. JANET B. WABRICK, : IN THE OJURT OF OJMMON PLEAS OF plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . : vs. . NO. 2000-2419 CIVIL TERM . . . DeWAYNE GEORGE WABRICK, JR., . . Defendant : IN DIVORCE WAIVER OF NOl'ICE OF INTEIiI'.rI<:IiI TO REQUEST ENTRY OF A DIVORCE DECREE UNDER i3301(c) OF THE DIVORCE OJDE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. 71 {J '1/ (){) Date i." ';; 'k,-;_Lc~ ~'~ -.....,- ~j. -......'~.>ihk!l!<,<it!;~iil/i;i:iili~~I_'.. ~~_. . , d"~~~ .;, 11-' "- ~ JO'. . ~..,.. 0 C () C C. <" ~> -OED "" ,~ f''Pr-- ~, Z~~ :'-:'i:D Z:r~' ;"') ~. (J)> '; ;'1 -<::< CD -:"') ::::' , !! ~O ~ ~-j~d ~O -" '~~iQ ~O J>C 9:' OlD Z --I ~ P C) :n -< "