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IN '1'111'; COUIll' OF COMMON PI.EAS
,;\J:;^N C. r-"OIltI
CUMIlEIlI.AND COUNTY. PENNSYLVANIA
VS,
:
CIVIL DIVISION
:
NO. 'l'I-()4?
CIVIL TEIlM
JOHN A. MOHN, Jr.
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record. together with the following information to
the court for entry of a divorce decree:
1. Ground for divorce: irretrievable breakdown under 53301(c)
jjlHkdldx.1d of the Divorce Code, (Strike out inapplicable section),
2, Date and manner of service of the complaint: certified mFlil,
return receipt, JeW. 8, 1997
------
]. Complete either paragraph (a) 0" (b),
(a) Date of execution of the affidavit of consent required
hy 5]301(c) of the Divorce Code: by plaintiff ,Tune 10.. 1999
by c1l'rendant ->1.unp. 10. 1999
(b)(l) Date of execution of the
of the nivorce Code:
affidavit required by 53]01(d)
; (2) Date of filing ann
se~vice of the plaintiff's affidavit upon the r~spondent:
4, Related claims pending: Nonp.
5, Complete either (a) or (b),
(a) Da.te and manner of service of the notice of intention to
file praecipe to transmit record. a copy of which is attached:
(b) Date plaintiff's
fi led wi th the prothonctaq':
Date defendant's
filed with the Prothonotary:
Waiver of Notice in 53301(c) Divcrce was
,Junp. 11, 1999
Waiver of Notice in 53301(c) Divorce was
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Attorney for (Plaintiff)~~~
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William I" Grubb
Allurucy a\ I.aw
I ~ 3105 Old G<lIyshurg Ruad ..' ..
Call1JlIIiIl, I'A 171111
SUSAN C, MOliN
: IN TilE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
l'laintiff
v,
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: NO, -'7 - 0',0.... 'wI. \ kILn
JOHN A. MOHN, JR"
Defendant
: IN LAW - DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT, If you wish to defend against the
claims set forth in the following pages. you must take prompt action, You are warned
that if you 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 relief requested in these papers by the Plaintiff. You may
loose money or property or other rights important to you. including custody or
visitation of your children,
When the grounds 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, First Floor, 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 MA Y LOSE THE RIGHT TO CLAIM ANY OF
THEM,
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Court Administrator's Office
Fourth Floor
Cumberland County Court House
I Courthouse Square
Carlisle, Pennsylvania 17013
Telephone (717) 240-6200
8, Plaintiff has been advised that counseling is available and that Plaintiff
may have the right to request that the Court require the parties to participate in
counseling,
9. Plaintiff requests the Court to elller a Decree of Divorce.
10, The Plaintiff and Defendant separated on December 27, 1996.
Respectfully submitted,
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William L. Grubb, Esquire
I.D, # 72661
3105 Old Gettysburg Road
Camp Hill, PA 17011
(717) 763,5580
Attorney for Plaintiff
Date:~
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VERIFICATION
I. SUSAN C. MOliN, verify thaI the statements made in this document are Irue
and correct. I understand thaI false statemel1ls herein are made subject 10 penalties of
18 Pa, C.S. ~ 4904, relating 10 unsworn falsification 10 authorities.
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Plaintiff
: IN TilE COURT OF COMMON PI.EAS OF
: CUMBERI.AND COUNTY, PENNSYLVANIA
SUSAN C, MOliN.
v,
: NO,
JOliN A, MOliN, JR"
Defendant
: IN I.AW - DIVORCE
WAIVER OF COUNSELING
SUSAN C, MOliN, being duly sworn according to law. deposes and says:
I. I have been advised of the availability of marriage counseling and understand
that I may request that the court require that my spouse and I participate in counseling,
2. I understand that the court maintains a list of marriage counselors in the Office
of the Prothonotary, which list is available to me upon request.
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3. Being so advised, I do not request that the court require that my spouse and I
participate in counseling prior to a divorce decree being handed down by the court,
I understand that false statements herein are made subject to the penalties of Pa.
C,S. ~4904, relating to unsworn falsification to aUIhorities.
Date:
SUSAN C. MOliN
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Plaintiff
: IN TilE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
SUSAN C. MOliN,
v,
: NO, 97.042 CIVIL TERM
JOliN A, MOliN, JR"
Dcfcndal1l
: IN LAW. DIVORCE
AFFIDAVIT OF SERVICE BY MAIL
COMMONWEALTH OF PENNSYLVANIA
SS
COUNTY OF CUMBERLAND
I, William L, Grubb, Esquire, being duly sworn
according to law, depose and say that I am the attorney for
Plaintiff t Susan C. Mohn, and that I did mail a true and
correct copy of the Complaint in Divorce filed in the above
matter, by certified mail, return receipt requested, to John
A. Mohn, Jr., on January 3, 1997, to 3B Buttonwood Lane,
Carlisle, Pennsylvania, Addressee acknowledged receipt of
the same on January B, 1997, as shown by the return receipt
card attached hereto as Exhibit "A".
Wi liam L, Grubbr Esquire
Sworn to and Subscribed
before me this 5'(1. day
of r0u~~'{ 19YI.
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Notary
Nolarlal Seal
Susan M, Grubb, Notary PubIlo
Lower Allen Twp" Cumberland County
'...tv Commission EXpiresJune21,1999
SUSAN C. MOliN
Plaintill'
: IN T!lE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v,
: NO, 97 - 042 CIVIL TERM
JOliN A, MOliN, JR.,
Dclimdanl
: IN LA W - DIVORCE
AFFIDAVIT OF CONSENT
I, A Complaint in Divorce under Section 330l(c) of the
Divorce Code was filed on January 3, 1997.
2. The marriage of the 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 in Divorce
after service of notice of intention to request entry of
decree.
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. 54904
relating to unsworn falsification to authorities,
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SlJSAN (', MOliN
: IN TilE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY. PENNSYLV ANIA
Plaintiff
v,
: NO. 97.042 CIVIL TERM
JOliN A, MOliN. JR,.
Defendant
: IN LA W . DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
DIVORCE DECREE UNDER 3301(0) OF THE DIVORCE CODE
1. I consent to the entry of a final decree of divorce
without notice.
2.
alimony,
I do not
I understand that I may lose rights concerning
division of property, lawyer's fees or expenses if
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. 54904
relating to unsworn falsification to authorities.
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Susan C, Mohn, Plaintiff
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SUSAN C. MOliN
: IN TilE CO( )RT OF COMMON PLEAS OF
: CUMBERLAND COUNTY. PENNSYLVANIA
Plaintiff
v,
: NO, 97.042 CIVIL TERM
JOliN A, MOliN, JR.,
Defendant
: IN LAW. DIVORCE
AFFIDAVIT OF CONSENT
I. A Complaint in Divorce under Section 330l(c) of the
Divorce Code was filed on January 3, 1997.
2. The marriage of the 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 in Divorce
after service of notice of inteotion to request entry of
decree.
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.
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SUSAN C. MOliN
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
Plaintitl.
v,
: NO, 97. 042 CIVIL TERM
JOliN A, MOliN, JR"
Defendant
: IN LA W . DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
DIVORCE DECREE UNDER 3301 (c) OF THE DIVORCE CODE
I. I consent to the entry of a final decree of divorce
without notice.
2.
alimony,
I do not
I understand that I may lose rights concerning
division of property, lawyer's fees or expenses if
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.
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OFFICE OF DIVORCE MASTER
CUMBERLAND COUNTY
COURT OF COMMON "tEAS
9 North Hanover Street
Carlisle, PA 17013
(717) 240,6535
E. Robert Elicker, II
Divorce Master
Tracl .10 Collier
Office Manager/Repo~er
West Shore
697,0371 Exl. 6535
January 21, 1999
William L. Grubb, Esquire
3105 Old Gettysburg Road
Camp Hill, PA 17011
John A, Mohn,
38 Buttonwood
Carlisle, PA
Jr.
Lane
17013
Re: Susan C. Hahn VB. John A. Hahn, Jr.
No. 97 - 042 Civil
In Divorce
Dear Mr, Grubb and Mr. Mohn:
By order of Court of President Judge George E. Hoffer
dated January 19, 1999, the full-time Master has been appointed
in the above referenced divorce proceedings.
A divorce complaint was filed on January 3, 1996, raising
grounds for divorce of irretrievable breakdown of the marriage.
The complaint averred that the parties separated on December 27,
1996. No economic claims were raised in the complaint,
On January 19, 1999, the Plaintiff filed a petition to
amend the complaint to add a claim for equitable distribution.
I am going to proceed on the basis that grounds for
divorce are not an issue. In accordance with P.R.C.P,
1920,33(b) I am directing Mr. Grubb, counsel for Susan C. Mohn,
and Mr, MOhn, who apparently is unrepresented, to each file a
pre-trial statement on or before Friday, February 19, 1999.
Upon receipt of the pre-trial statements, I will immediately
schedule a pre-hearing conference with Mr. Grubb, counsel for
Susan C. Mohn, and Mr. Mohn, if he remains unrepresented, to
SUSAN C. MOHN,
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 97 - 42 CIVIL
JOHN A. MOHN, JR.,
Defendant
IN DIVORCE
NOTICE OF PRE-HEARING CONFERENCE
TO: William L. Grubb
, Counsel for Plaintiff
John A. Mohn, Jr.
, Counsel for Defendant
A pre-hearing conference has been scheduled at the
Office of the Divorce Master, 9 North Hanover Street, Carlisle,
Pennsylvania, on the 11th day of June, 1999, at 9:30 a.m., at
filed by counsel, define issues, identify witnesses, explore the
which time we will review the pre-trial statements previously
possibility of settlement and, if necessary, schedule a hearing.
Very truly yours,
Date of Notice: 3/1/99
E. Robert Elicker, II
Divorce Master
William L. Grubb, Attorney for Plaintiff, filed a pre-trial
statement on February lB, 1999.
John A. Mohn, Jr., Defendant, has not filed a pre-trial
statement as of the date of this notice.
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SUSAN C, MOliN,
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERl.AND COUNTY. PENNSYl.V ANIA
Plaintiff
v,
: NO, 97-042 Civil Term
JOI IN A, MOl IN, JR,.
Defendant
: IN l.A W - DIVORCE
PLAINTIFF'S PETITION TO AMEND DIVORCE COMPLAINT
TO ADD Cl.AIM FOR EOUITABl.E DISTRIBUTION OF PROPERTY
Plaintiff. Susan c.. Mohn, by her attorney. William L. Grubb, Esquire, files this
Petition To Amend Divorce Complaint To Add Claim For Equitable Distribution of
property, and, in support theleof, avers as follows:
\, Plaintiff filed a Divorce Complaint in the above-eaptioned matter on
January 3, \997 avering that the parties' marriage is irretrievably broken
and requesting that the Court enter a Decree of Divorce under !l330\(c) or
!l330I(d) of the Pennsylvania Divorce Code, A true and correct copy of
the Divorce Complaint is attached hereto as Exhibit A.
2, The allegations in paragraph I through 8 of the Divorce Complaint are
incorporated herein and made a part hereof,
3. Plaintiff and Defendant have acquired property and have incurred debts
during their marriage.
4, Plaintiff and Defendant have been unable to agree as to the equitable
division of the property and liabilities to the date of filing this petition.
WHEREFORE. Plaintiff requests that the Court equitably divide all marital
property and liabilities,
Respectfully submitted,
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Wi Iiam L. Grubb, Esquire
1.0,117266\
3\ 05 Old Gettysburg Road
Camp lIill, PA 17011
(717) 763.5580
Attorney for Plaintiff
VERIFICATION
I, SUSAN C. MOliN. vcrify that thc statcmcnts madc in this documcnt arc truc
and corrcct. I undcrstand that falsc statcmcnts hcrein arc madc subjcct to pcnaltics of 18
Pa. C.S, ~ 4904, relating to unsworn falsification to authoritics,
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SUSAN C. MOHN
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
v.
: NO, 97. OJ-! J... e U I'l '---{( R..IrJ
JOHN A. MOHN, JR.,
Defendant : IN LAW - DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT, If you wish to defend against the
claims set forth in the following pages, you must take prompt action. You are warned
that if you 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 relief requested in these papers by the Plaintiff. You may
loose money or property or other rights important to you, including custody or
visitation of your children.
When the grounds 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, First Floor, 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 HA V'E A LAWYER OR CANNOT AFFORD ONE, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU
CAN GET LEGAL HELP.
Court Administrator's Office
Fourth Floor
Cumberland County Court House
I Courthouse Square
Carlisle, Pennsylvania 17013
Telephone (717) 240-6200
TRUE COPY FROM RECORD
. 11. Testimony whereof,l here unto set my hand
Ex H ~ C> ~ n d the IU 01 said ~ at Carlisle, Pa.
II '!$ oL..../J;l! \ I 1119'>'
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Plaintiff has been advised that counseling is available and that Plaintiff
the right to request that the Court require the parties to participate in
may have
counseling.
9.
Plaintiff requests the Court to enter a Decree of Divorce.
10.
The Plaintiff and Defendant separated on December 27, 1996.
Respectfully submitted,
1J,~j" fhQL-~.
William L. Grubb, Esquire
I.D. # 72661
3105 Old Gettysburg Road
Camp Hill, PA 17011
(717) 763-5580
Attorney for Plaintiff
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6,
Loan - 1995
From Wifc's 401(k)
for trailer down-payment
$2,500.00
7,
Loan - 1996
from Wifc's 401(k)
for cvnsolidation of husband's support
obligation, Chcvy truck, crcdit card dcbt
$4,000.00
$41,462.00
PROPOSED RESOLUTION OF ECONOMIC ISSUES
With consideration to the following:
(a) The duration of the marriage was only seven (7) years
(b) Chapter 7 bankruptcy discharged Decembcr 6, 1996
(c) It is wife's understanding and belief that husband will benefit
substantially as a beneficiary of his father's estate, who died in 1998,
The Plaintiff proposcs the following resolution of the cconomic issues:
To be distributed to wife:
VALUE
I. 1994 Oeo Tracker
2, Wife's 401(k) retirement type accounts
3, Debt- PP&L
4. Debt - Lowc's
5, Loan - 1995 401(k)
7, Loan - 1996 (401(k)
$330,00
$ I 5,686.00
( $92.00)
($1,200,00)
($2,500,00)
($4,000,00)
$8,224,00
To be distributed to husband:
I.
1995 Chevy Pick-up
$000,00
2,
Chevrolet Nova
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Husband's relirementlype accounts
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House Trailer
($3,000.00)
$1,000,00
5,
Personal property now in his possession
6,
Rental value of marital residence
Twenty-six (26) months
?
$
Respectfully submilled,
Date: l' \ 8 (((.\
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William L. Grubb, Esquire
!.D, # 72661
3105 Old Gellysburg Road
Camp Hill, PA 17011
(717) 763-5580
Allomey for Plaintiff
.
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Form
a,partment 0' the Trl"Ury u InlefNI R.v.nuI ServlC'
199) U,S. IndIvIdual Income Tax Return 1996 IRS Uso Only" Do nol W"O 0' IUplo in tIlts 'poco
IS.. pogo 15) UoolholRS 101N1. Dtho",,,o, plo... pHnt 'n ALL CAPITAL tETTERS. OMB No 15-45,0085
Your filii name'nd In/Ult l..t Mint Home .dd..... Api No City, lown Of POll oltlce, St. II, .na liP code Your aociaf lecurtty number
165-38-1020
1""""'1 loclollKUrily no,
171-56-9342
For Privacy Act and
Paperwork
Reduction Act
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SUSAN C. MOHN
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Noto: Chocking -VII' W.
nor chango your Lox Of
reducI )'OUr r.fund.
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Morriod fillllg jolne rotu'n (oYon W only 0". had Incoma)
Married '~ing UPI'ltl '.tum. Ent.r _paUle'. locial.lcurity nurmer
lboYI ond lug nama ho..,. JOHN A, MOHN , JR
Hud 01 houlOhold (w.h qUlllfylng porson) IS.. pogo 16) ~ lha qUlllfylng porson is I child
but not yout d.pend.nt, Inl.r this chiJd'. name her. ..
CUll i widow(or) w.h do ondont child ( oor. UIO diad. 19 ) (5.. 0 16)
you""n. "your pl,.nt (or someone .Is.) cln cllilm you IS I d.pend,nt on hiS or he, l.ax r.turn, -'0 not
chock box 60,
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b SpaUIO', IRA doduction (III pogo 22),
15b I
C Add tino, 1S. Ind 15b, Tho'.... )'Our lotal ocIJultmo, '
16 SublrlcH". IS. Irom ""' 14, This is your ocIjuatoclS"
· child did nollive with you). s" the instructions '01 I."
Altach Copy B 01 W-2 Ind 1D99-R horo, CM 1
Copynghl'OtmISottw.,..Onty,lt96HeCo,lrc. HI6...1
15c1
:undorl9,5oo H
.
16 I 26,186.
1'" Form lD40A P'lI' 1
Exhibit" A"
165-3B-1020
, 4
SUSJl.N C. MOliN
. .
1996 Fo,m 1040A
Page 2
11 Ent., the Irn:lunt trom hne 16
181 Check { You wlr. 6S or old., Blind }
~ Sou.. was 65 or old., Blln~
b It you Ir. minted filing ,aplr'llly and your lpoUII iI.null d.duC1lOnl,
.,. plgt 26 and chick he,..
111 Ent.r tho .lIIncWd oMductlon lor your 1,long IUIlus But SM p.go 26 _ you chock.d
any box on kne lSa or bOR IOn'WOnl CJIn d'lm you II. d.~nd.nt.
. S"'91e -- 4,000 . M.m.d 1""'9 joinlly or OU.11fying w!doW<.r) -- 6,700
. Hlld of hous.hold -.. 5,900 . Minted tiling 'IPlraltly u ),350
17 1
26 1B6,
Ent., number of
....... checked. 180
o
,. lab
o
111 1 3,350.
20 1 22,B36.
21 1 2.55L
. 22 1 20.2B6.
23 1 3,071.
20 Subtr.dlinl Ii ~om IinI 17, H IinI Ii is more thon 10.... 17, .nt.r 0,
21 Multiply 12,550 by tho tolll nurrbor 01 ...~tions cia,med on 10.... 6d
22 Subtract line 21 from line 20. If Une 21 ts mort thin hne 20. enl., O. ThiS IS your tax.bl,lncome.
" you w.nt.... IRS to Ilgu.. you. 1aJ, ... ,"g. 26,
23 Find tho II. on tho lmount on 10.... 22 (... plge 26),
241 Cr.dlt for child and dlpend.nt Clf' I.penses. AttIch Schedu'- 2.
b Cr.d! lor tho .Id.rly or tho disabled, AllIch Schodule 3
24al
24bl
C Add lin.s 241 .nd 24b Thos. Ir. your 10111 credllll.
24<:1
25 1
26 1
~ 1
. 28 1
3,533.
COMP
3 , 071.
25 SubUlct~". 24, from line 23. It ~ne 24, ts mort th.In line 23. Intt, O.
3,071.
26 Advance larned Incanw credit paynwnts hom Form(s) W-2.
~ Household .~loymen!lI.n AIlIch Schodule H,
28 Add Ii....' 25, 26, Ind 27, Thi' is your 10001IaJ,
29a TolIl Fed.rll income II. withhold Irom Forms W.2 Ind 1099. 29as
b 1996 estimated till paYfT'llnts and amount applied hom 1995 return, 29b$
C Earned Income c..em, AllIch SChadule EIC it you have I qUlllfying chold 29c 1
Nonll..ble ..r....d income, amount. 1 1 , 37 B . Ind typ.. DEFERRED
d Add Ii....' 291, 29b, Ind 29c (do not includ. nonlllxlble .Ir....d income) Thos. Ir. your 10111 ,aymenll, . 29d1
3,533.
462.
30 H lone 29d is """.than 10.... 28, sublrldli.... 28 from Ii.... 29d, This is tho amount you ov..,ald. 30 1
31. Amount of line 30 you want r"'und~ to you. If you wanl it Slnt directty to your bank IccoUnt. 1M plge 35
and foil in 31b, c, and d, 31al
db ~_-::' I 0 0
,_,_ . C Type, Chacking SlvIngs
I
32 Amount of 10.... 30 you WIn! appllecl to you. 1"7 _Imated 1aJ, 32 1
462.
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33 H 1in128 is mor.than 10.... 29d, ,ubuldIinl29d ~om i.... 28, This is tho amount you ow., For details
on how to pey, including whallo writ. on your payment. 1M page 36,
34 Estimal.d II. penalty ('M plge 36), 34 I
Under penalU" 01 perJt.ry ,I _lIrelnlll have e.amlned Ihlt fel~" and ICCOII'lpinylng KNduAn and ItIttmlf'ltl:, am 10 the
Sign bnt 01 my knowledge and beU.I, lhey are trw, tol'rK1. and KClM'ltety IItt III lmoo..rtta and IOUrCft of tncomel tecIf*durlng
here the we yMI. Oklltltlonol Pf'I'I*"'(OI_ than the I&xptYeflla bUed onalllnfonNUon of which the prepw... haM( kno.~.
~ Your s. natur, Olt' Your occupation
r ADMIN. ASSISTANT
~ Spous,'s '19na Spouse', occupation
Pr.paror's /J.\ to Chock W san- Propar.", SSN
sognalur. ~~ .~Ioyed 2.0".1..-" 62.'7
Fllm'sname JOSIAH S. OSIBODU CPA EIN
(or yours if ~
,.n.'~loy'd),4571 LARCH DRIVE # C72 ZIP cod.
Indlddrm HARRISBURG PA 17109-5175
eM 1040A 12 "Tf ..... 11M Form 1040A ,.,. Z
Copyrtqhl Fnrmt Cjnlt"",." o.,ty 1996 Nek"o Inr N96A1
331
KHp I copy of
thI$ r,turn for
our r.cords
Paid
preparer's
ule only
,
,
"
All IN C09i.\ 01 yo... W.2 .0 on lIIi. ""., ..,.01.d -V
~rf"1110n.. h. Whitt COPI'S .. for yOCl' II. 'Il'frnl; the
I". cOPV II f.r y.'" 'Icordl. nef.1 Instructions tor tht .
Ilrms. including In upllRl110n or th, line' cod.. "lid tn to.
13, .. on lilt Olll" lid. ., III. ""..
To lilt righI, II on uplllltl,.n of III. c.nt.~u of tho WIll.
H"I. on YOUfW.l PIIUf no1l thI1 thl (;fOil lmOunt thown
IfWt mclud. Idlultmtnu.
If yo." .. required to fil, . lilt rflurn. I negligenc. "nllty
or other ~tlon rY\I'f be Imposed on you if thiS InCome II
&lalbl, Wid you ',il to ripen IL
. ..'1 ,', .
... I ... . ... I' ... al
If... .n....' ."....1 '''11.11 '''11.'' 1711'.11
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.
II ,...__........
0470001064 =-.:.:-'
II~_'-"C""__'
23- 1483881
I .W\.............. ~ _.._
HARSCO CORPORATION
3$0 POPLAR CHURCH ROAD
C'MP HILL, PA
17011
owe IIlIO. .....-0001
...... ,.. .".. -....,..
2611&.$11
. ,......... ,... WIt-.
.~ . .AQU .
27$63,11'
. -.u.II _&aD; _ '"
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3533.16
1708.116
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, ~....., ""
. MLMA.....
. ,.,,..,,.IIC'..'....
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'6$-311-1020
L ............. .......,. .. _
SUSAN C KOHN
..-
"
. ....
..
. -
" ..u_*, .. c
7 3 91
Copy C Fo, EMPLOYEE'S RECORDS (S06 notice on baclt,)
Fonn W.2 Wage and Tax Statement
1 7
Depl. oIlhe T'.....ry. Internal R8'I8l1U8 SeMCe
Thes. substJIute W.2 WIQO and Tu SlatemenlS ... aooepl8bIe tor "'"ll wI1h your Fodoral, Stale and l..or:aIlnc:orno Tu Ralumt,
" yoo worItod in mulllpl. locatIOns, 0' had 18.e..IIOOOI 01 tptCIai ~tIOn, yoo may "'*"" moro than ono oIl11ose ~,
Willillm Lewis Grubb
Allornc)' III till\'
310S OILl (;CII)'shurl: l{ollLl
Cllmp 1111I, I'cnns)'hllnill 17011
Tel. (717) 76.1-5580
Fax, (717) 763-6848
E. Robert Elicker, II
Divoree Master
9 North Hanover Street
Carlisle, PA 17013
June 10. 1999
Re: Mohn v. Mohn. No. 97-042 Civil, In Divorce
Dear Mr, Elicker:
Kindly cancel the pre-hearing conference scheduled for Friday, June II, 1999, at
9:30 a.m, in the above referenced matter,
Mr, Mohn has consented to the divorce and the parties have reached an agreement
regarding the equitable distribution issues, Mr. Mollll \Vas In m) ollice this aliemoon and
has signed documents necessary to conclude this matter
I have telephoned Ms, Colyer to verhally conve) thi~ information to you, and have
asked Mr, Mohn to extend the same cour,esy to you,
Please contact my office should you have any questions.
Very truly yours.
lJi2,~hi
William L. Grubb
cc: S. Molm
J. Mol1l1
,
~
SUSAN C. HOHN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs,
NO. 97 - 42 CIVIL
JOHN A. HOHN, JR.,
Defendant
IN DIVORCE
ORDER O~ COURT
AND NOW, this -l1 day of ~
1999, the economic claims raised in the proceedings having been
resolved in accordance with a marriage settlement agreement
dated June 10, 1999, the appointment of the Haster is vacated
and counsel can file a praecipe transmitting the record to the
Court requesting a final decree in divorce.
BY THE COURT,
cc:
William L. Grubb
Attorney for Plaintiff
P.J.
John A. Hohn, Jr.
Attorney for Defendant
,
Co4>-~>>- (>'~'(" fe/t 'iff?,
<J ,,>;, f
MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT is made this
J oil
l' -
day of
]:"JIv .:
1999, by and between JOHN A. HOHN, JR., 38 Buttonwood Lane,
Carlisle,
Cumberland County,
Pennsylvania,
hereinafter
referred to as "Husband",
-AND-
SUSAN C. HOHN, now of Camp Hill, Cumberland County,
Pennsylvania, hereinafter referred to as "WifeD,
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on
December
31,
1989,
in
H"lrrisburg,
Dauphin
County,
Pennsylvania; and
WHEREAS, diverse unhappy marital difficulties have
arisen between the parties causing them to believe that
their marriage is irretrievably broken, as a result of which
they now live separate and apart from on another, the
parties being estranged due to such marital difficulties;
and
WHEREAS,
the
parties
hereto
are
desirous
of
compromising and settling fully and finally their respective
financial and property rights and obligations as between
each other, including, without limitation by specification:
ownership ot real and personal property; and in general, the
settling of any and all claims and possible claims by one
against the other or dCJainst their respective estate,
particularly those responsibilities and rights growing out
of the marriage relationship, inter alia past, present or
future spousal support or maintenance, alimony pendente
lite, alimony, counsel fees and expenses, and equitable
distribution, whether or not the parties reside together;
and
WHEREAS, the parties have made full disclosure to each
other of their assets and liabilities and have agreed on a
settlement of all property rights and differences existing
between them; and
WHEREAS, the parties intend this Agreement to be a full
and complete Marriage Settlement Agreement, providing for
the absolute and final settlement of all their respective
marital and property and all other claims.
NOW, THEREFORE, in consideration of the premises and of
the promises, covenants and undertakings hereinafter set
forth and for other good and valuable consideration, the
receipt of which is hereby acknowledged by each of the
2
parties hereto, Husband and Wife, each intending to be
legally bound hereby, covenant and agree as follows:
1. SEPARATION.
It shall be lawful for each party, at
all times hereinafter, to live separate and apart from the
other, at such place or places as he or she may, from time
to time, choose or deem fit. Each party shall be free from
interference, authority or control by the other, as full as
if he or she were single and unmarried, except as may be
necessary to 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, separate and
apart from the other. The foregoing provision shall not be
an admission on the part of either party of the lawfulness
or unlawfulness of the causes leading to their separation.
A reconciliation will not void the provisions of this
agreement.
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,
3
judgment, order or further modification or revision thereof
shall alter, amend or vary any term or this Agn~ement,
whether or not either or both of the parties shall remarry,
it being understood by and between the parties hereto that
this Agreement shall be incorporated in but shall not be
merged into and decree, judgment, or order of divorce or
separation. It is specifically agreed, however, that a copy
of this Agreement or the substance of the provisions
thereof, may be incorporated by reference into any divorce,
judgment or decree. This incorporation, however, shall not
be regarded as a merger, it being the specific intent of the
parties to permit this Agreement to survive any judgment and
to be forever binding and conclusive upon the parties.
2.
EFFECTIVE DATE.
The effective date of this
Agreement shall be the "date of execution", defined as the
date upon which it is executed by the parties if they have
each executed the Agreement on the same date. Other wise,
the "date of execution" or "execution date" of this
Agreement shall be defined as the date of execution by the
party last executing this Agreement. Transfer of property,
funds and/or documents shall occur on the effective date
unless otherwise specified herein.
4
3. AGREEMENT NOT A BAR TO DIVORCE. This Agreement
shall not be considered to affect or bar the right of either
party to a divorce on lawful grounds as may be now or
hereafter available to either party. This Agreement is not
intended to be and shall not be a condonation on the part of
either party of any act or acts of either party hereto.
Both parties hereto agree that the marriage is irretrievably
broken and agree at the time of execution hereof 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. Each party waives the right to
request Court ordered counseling.
4.
DEBTS AND OBLIGATIONS.
Each party hereto
represents and warrants that he or she has not, and in the
future will not, contract or incur any debt, obligation or
liability for which the other party or his or her estate may
be responsible or liable, except as provided for in this
Agreement. Each party hereto agrees to be solely
responsible for the prompt and timely payment of the debts
now or hereafter incurred in his or her name and
specifically
vehicle or
hereunder.
harmless
any debts secured by any automobile, motor
other property distributed to her or him
Each party hereto agrees to indemnify and hold
the other from any and all claims, debts,
5
obliCJdtions or demands made aCJdinst him or her by reason of
debts or obligations incurred by him or her or identified to
be paid by him or her in this Agreement.
5. MUTUAL RELEASES. Husband and Wife 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, from any and all rights, title and
interest, or claims in or against the estate of such other,
or whatever nature and wherever situate, which he or she not
has or at any time hereafter may have against such other,
the estate of such other or any part thereof, whether
arising out of any former acts, contracts, engagements or
liabilities or such other or by way of dower or curtesy, of
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 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; or any rights which either party may now
have or at any time hereafter have for past, present or
future support or maintenance, alimony, alimony pendente
6
lite, counsel fees, costs or expcll:,(!S, whether arising LiS a
result of the marital relation or otherwise, except and onl y
except all rights and agreements and obliga~ions of
whatsoever nature arising or which may arise under the
Agreement or for the breach of any provision 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 rights
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 by each party
that this Agreement constitutes a full and final resolution
and settlement of all claims of any kind, and especially and
claims arising under the Pennsylvania Divorce Code, which
either party may have against the other.
6.
DIVISION OF HOUSEHOLD AND PERSONAL PROPERTY.
The
parties hereto agree that they have effected
satisfactory division of the furniture,
a mutually
household
furnishings, appliances and other personal property and
motor vehicles between them and neither party will make any
claim to any personal property now in the possession or
control of the other except as herein provided. Husband
7
3
i
hereby releas('s and relinqui shes any right,
Li tie or
interest he may have had in the past or now has in the
"
property in Wife's possession. Wife agrees that Husband
shall, from and after the date hereof, be the sole and
separate owner of all personal property in Husband's
possession.
Wife hereby releases and relinquishes any
right, title or interest she may have had in the past or now
has in the property in Husband's possession. Husband agrees
that Wife shall, from and after the date hereof, be the sole
r
I
,.
and separate owner of all personal property in Wife's
possession.
7.
PENSIONS AND RETIREMENT ACCOUNTS.
The parties
hereto waive any and all interest or claims which either may
have in any individual retirement accounts, 401(k) accounts,
Keogh accounts, existing pensions or similar accounts of the
other, including any retirement type accounts of Wife
arising from her employment with Harsco Corporation, and any
retirement type accounts of Husband arising from his
employment with B'Nai B'Rith Apartments.
8. ALIHONY. Each party waives, releases and gives up
any claim, now or in the future, for any spousal support,
alimony, alimony pendente lite, or maintenance from the
other.
8
~
9. BANK ACCOUNTS.
HUSBAND and WIFE each acknowledge
that they each own or possess certain bank accounts and
similar accounts of financial instruments in their
respective names. They hereby agree that each shall become
sole owner of their respective accounts for financial
instruments and each hereby waives any interest in or claim
to any funds, instruments or accounts held by the other in
such instruments or accounts.
10. MOTOR VEHICLES. Wi th respect to motor vehicles
owned by HUSBAND and WIFE, both of the parties agree as
follows:
The 1994 Geo Tracker shall be and remain the sole and
exclusive property of Wife;
The 1995 Chevy S-10 truck shall be and remain the sole
and exclusive property of Husband;
The Chevrolet Nova automobile shall be and remain the
sole and exclusive property of Husband;
Each party shall be solely responsible for ana debt
secured by any vehicle listed as his or her property. Each
party shall be solely responsible for any insurance and any
other costs, including license, for each motor vehicle
listed above as his or her property.
<)
11. REAL PROPERTY. The house trailer currently located
at 38 Buttonwood Drive shall be and become the sole property
of Husband, and wife shall forever quit and release any
current or future claim or right of ownership or title.
Wife shall execute, and further agrees to sign, execute or
aCknowledge any additional documents, instruments, or papers
required for or necessary to the transfer of title to
husband, Upon the satisfaction and release of a certain
note, loan or mortgage that was executed by both Husband and
Wife for the purchase of said trailer. Wife agrees that she
gives up any and all right, title and interest to and in the
identified property, and agrees never to assert any claim to
said property in the future. Husband shall defend,
indemnify and hold harmless wife against any and all claim
or obligation that may result from a certain loan or
mortgage against said property that was executed by both
husband and wife. Husband shall, at husband's expense,
within sixty (60) days of the signing of this agreement,
cause the current mortgage or loan that was executed by
husband and wife to be retired or to have Wife released from
obligation by the Mortgagee. All debt currently or in the
future that encumbers said property shall be the sole
responsibility of husband.
10
Husband shall be responsible for any lot rent, water,
sewer, real estate taxes or other property taxes now or
currently due or which will become due in the future
regarding said house trailer. Husband shall defend,
indemnify and hold harmless Wife against any and all claim
or obligation from any lot rent, water, sewer, real estate
taxes or other property taxes regarding said house trailer.
12. COUNSEL FEES. Each party individually covenants
and agrees that he or she will individually assume the full
and sole responsibility for all other legal expenses for his
or her attorney, if any, and Court costs in connection with
the pending divorce action and shall make no claim against
the other for such costs or fees except as set forth in this
paragraph.
l3. ADVICE OF COUNSEL. The provisions of this
Agreement and their legal effect have been fully explained
to Wife by her counsel, WILLIAM L. GRUBB, ESQUIRE, Husband
having knowingly and intelligently waived his right to be
represented by counsel. Husband and Wife each covenants
that he or she has made a full financial disclosure to the
other of his or her respective property, holdings and
income. Husband and Wife each acknowledge that each fully
II
understunds the facts of this dCjfl'elllt'nl ,md has been fully
informed as to her or his legal rights and obligations and
each party acknowledges and accepts that this Agreement in,
in the circumstances, fair and equitable and that it is
being entered into freely and voluntarily, with such
knowledge 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. Husband, being advised that he has the right
to obtain independent advice from the attorney of his
choice, hereby waives his right to obtain counsel.
l4. ADDITIONAL INSTRUMENTS. Each of the parties shall,
from time to time, at the request of the other, execute,
acknowledge and deliver to the other party any and all
further instruments, deeds, titles or documents that may be
reasonably required to give full force and effect to the
provisions of this Agreement, including all papers necessary
to transfer title.
l5. AFTER-ACQUIRED PROPERTY. Each party shall
hereafter independently own all property, real, personal or
mixed, tangible or intangible, of any kind, acquired by him
or her, with full power to dispose of the same in all
12
respects and for all purposes, as thuu'1h he or she were
~
t
unmarried.
,
16. APPLICABILITY OF TAX LAW TO PROPERTY TRANSFER.
The parties hereby agree and expre&s their interest that any
transfer of property under this Agreement shall be within
the scope and application of the Deficit Reduction Act of
1984, hereinafter referred to as "the Act," and specifically
the provisions of the Act pertaining to property transfers
between spouses and former spouses.
The parties agree to
to the carry-over basis provisions of the Act.
'.
I
~
I
r
,
I
sign and file any elections or other documents required by
the Internal Revenue Service to apply the Act to transfers
under this Agreement without recognition of gain and subject
17. MODIFICATION AND WAIVER. A modification or waiver
of any of the provisions of the Agreement shall be effective
only if made in writing and executed with the same formality
as this Agreement.
The failure of either party to insist
upon the strict performance of any of the provisions of this
Agreement shall not be construed as a waiver of any
subsequent default of the same or similar nature.
18.
ENTIRE AGREEMENT.
This Agreement contains the
entire understanding of the parties, and there are no
13
representations, warranties, covenants or undertakings other
than those expressly set forth herein.
19. DESCRIPTIVE HEADINGS. The descriptive headings
used herein are for convenience only. They shall have no
effect whatsoever in determining the rights or obligations
of the parties.
20. INDEPENDENT SEPARATE COVENANTS. It is specifically
understood and agreed by and between the parties hereto that
each paragraph hereof shall be deemed to be a separate and
independent agreement.
21. BREACH. If either party breaches allY provision of
this Agreement, the other party shall have the right, at his
or her election, to sue for damages for such breach, to
terminate any further payments required to the other
hereunder or seek such other remedies or relief as may be
available to him or her, and the party breaching this
contract shall be responsible of payment of legal fees and
costs incurred by the other in enforcing their rights under
this Agreement, or in seeking such other remedies or relief
as may be available to him or her.
14
22.
DISCLOSURE OF FINANCES.
Each party hereto
confirms that he or she has relied on the completeness and
substantial accuracy of financial disclosures of the other
as an inducement to enter into the Agreement. The part ies
acknowledge that there has been no formal discovery
conducted in their pending divorce action and that neither
has filed and Inventory and Appraisment as required by
Section 3505(b) of the Pennsylvania Divorce Code. The
rights of either party to pursue a claim for equitable
distribution of any interest owned by the other party in an
asset prior to the date of execution hereof which interest
was not disclosed or known by the other party or his or her
counsel prior to the execution of this Agreement is
expressly reserved.
23. APPLICABLE LAW. This Agreement shall be construed
under the laws of the Commonwealth of Pennsylvania.
24.
VOID CLAUSES.
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.
15
IN WITNESS WHEREOF,
thc parties hdvc hereunto set
their hands and seals the day and year first above written.
WITNE)SS':&,0
~~ l, t,
,
j",IFE: ~
~/~~~.(~h~ ~
l~~ \J
John A. Hohn,
16
~
i
~
ACKNOWLEDGMENT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
SS
On this the
"r/"
/,j - of
)-'''''<
1999, before
me, the undersigned officer, personally appeared Susan C.
Hohn known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within Agreement and
acknowledged that she executed the same for the purposes
therein contained.
l,.\ :Q~ -I -\..Cr
Notary Public
My commission expires:
NotaTlal ~e~~fY PubliC
w.lh'"' l GfUb8u",bOlland coun\~
Allen W,p. Au9 H 200
Lower 5Slon E_plres .
My co"'""
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ACKNOWLEDGMENT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
ss
On this the ,01.... of J.J",.:; , 1999, before me,
the undersigned officer, personally appeared John A. Mohn,
Jr., known to me or satisfactorily proven) to be the
person whose name is subscribed to the within Agreement and
acknowledged that he executed the same for the purposes
therein contained.
Lt\_QL p~,,-~
Notary Public
My commission expires:
Nolana! Seal
William L. Oru:ID. Notary Public
Lowar Allen Twp.. Cumbe~and County
My Commission expire. Aug. 13.2001
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