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HomeMy WebLinkAbout02-5918Scott L. Betts, Plaintiff Julie L. Betts, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02- 6-'~/,? CIVIL TERM : CIVIL ACTION - LAW : 1N DIVORCE PETITION FOR SPECIAL RELIEF AND NOW COMES the Plaintiff and requests the Court to grant a Petition for Special Relief and alleges that: 1. Plaintiff is Scott L. Betts an adult individual currently residing at 82 Linda Drive//20, Mechanicsburg, PA 17050. 2. Defendant is Julie L. Betts, an adult individual, currently residing at 433 Laudenslager Road, Williamsport, Lycoming County, Pennsylvania 17701. 3. Concurrent with the filing of this Petition for Special Relief, the Complaint in Divorce is being filed. 4. The Plaintiff and Defendant were married on April 26, 1986 in Honolulu City, Hawaii. 5. 6. During the period of their marriage, they obtained certain personal property. On or about October 20, 2002 the Defendant moved out of the marital residence at 82 Linda Drive//20, Mechanicsburg, PA and went to live with her parents at 433 Laudenslager Road, Williamsport, PA. 7. On or about November 30, 2002 the Plaintiff went hunting. He returned on December 4, 2002. 8. While the Plaintiff was hunting with his brother-in-law, the Defendant and her parents came to the marital home at 82 Linda Drive//20, Mechanicsburg, PA and removed the majority of the personal property from said home. Among other items she removed microwave oven, coffee pot, a lazy boy recliner, a glider rocker, a TV, an entertainment center, speakers, a Lindhaus vacuum cleaner, Maytag washer, Maytag dryer, dresser, lamp, shower curtain with clips, telephone stand, telephone, towels, dishes, pots and pans, paper shredder, food items, bed linens and a 1988 Corsica automobile. 9. Defendant did not need these items since she was residing in the home of her parents. 10. It is believed by the Plaintiff and therefore alleged that Defendant removed these items out of vindictiveness to leave Plaintiff with no furnishing on which to live. 11. Defendant and her family are in the possession of certain non-marital property belonging to Plaintiff to wit five (5) antique clocks which he inherited from his mother, a Mossberg 12 gauge pump shotgun and an 16 gauge single shot shotgun. 12. When the Defendant left on October 20, 2002, she removed $12,000 from the joint bank account. 13. When the Defendant left she took with her a 1995 Escort Wagon. WHEREFORE, Plaintiff requests this Court to schedule a hearing on this matter and at the hearing order the Defendant to: 1. Return the non-marital property to the Plaintiff; 2. Return one (1) of the two (2) automobiles to the Plaintiff; 3. Give a complete inventory of the personal property in her possession; 4. Enjoin her from destroying, wasting, selling, transferring or in any other way damaging said marital property. Respectfully Submitted TURO LAW OFFICES Date Robert ~/Mulderig, E~quire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Petition for Special Relief are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. [}4904 relating to unsworn falsification to authorities. Date S~ott L.~letts Scott L. Betts, Plaintiff Julie L. Betts, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 02- ~¢//¢ CIVIL TERM : CIVIL ACTION - LAW :IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case will proceed without you and a decree in divorce or annulment may 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 the First Floor, Cumberland County Courthouse, South Hanover Street, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Pennsylvania Lawyer Referral Service Pennsylvania Bar Association P. O. box 186 Harrisburg, PA 17108 (800) 692-7375 Scott L. Betts, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 02- -. 'Y / ,~ CIVIL TERM Julie L. BeEs, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Scott L. BeEs, an adult individual, currently residing at 82 Linda Drive, #20, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. Defendant is Julie L. Betts, an adult individual, currently residing at 433 Laudenslager Road, Williamsport, Lycoming County, Pennsylvania 17701. 3. Plaintiff and Defendant are bonafide residents of the Commonwealth of Pennsylvania and have been so for at least six months immediately previous to the filing of this complaint. Hawaii. 5. Plaintiff and Defendant were married on April 26, 1986 in Honolulu City, There have been no prior actions for divorce or annulment between the 6. The Defendant is not a member of the Armed Forces of the United States i of America, or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, the Plaintiff does not desire that the Court require the parties to participate in counseling. 8. Plaintiff and Defendant are citizens of the United States of America. 9. The parties have lived separate and apart since October 20, 2002 and continue to live separate and apart as of the date of this Complaint. 10. The parties' marriage is irretrievably broken. 11. Plaintiff desires a divorce based upon the belief that Defendant will, after ninety days from the date of the filing of this Complaint, consent to this divorce. WHEREFORE, Plaintiff requests your Honorable Court to enter a decree in divorce. Respectfully Submitted TURO LAW OFFICES Date Robert/J: Mulde~, Esquire 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff VERIFICATION I verify that the statements made in the foregoing Divorce 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. ate / ~ Scott L. Betts SCOTT L. BETTS, Plaintiff V. JULIE L. BETTS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 02-5918 CIVIL TERM ORDER OF COURT AND NOW, this 19th day of December, 2002, upon consideration of Plaintiff's Petition for Special Relief, a hearing is scheduled for Wednesday, February 26, 2003, at 2:30 p.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. PENDING SAID HEARING, neither party shall transfer, encumber, damage, dispose of, sell or otherwise diminish the value of any martial property except by mutual agreement in writing. Robert J. Mulderig, Esq. 28 South Pitt Street Carlisle, PA 17013 Attorney for Plaintiff Julie L. Betts 436 Laudenslager Road Williamsport, PA 17701 Defendant, Pro Se :rc BY THE COURT, /Wesley Ol('x;'Jr., ' J. Scott L. Betts, Plaintiff V. Julie L. Betts, Defendant · IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA · NO. 02-5918 CIVIL TERM · CIVIL ACTION - LAW · IN DIVORCE AFFIDAVIT OF SERVICE I HEREBY CERTIFY THAT I served a true and correct copy of Divorce Complaint and Petition for Special Relief filed in the above captioned case upon Julie L. Betts, by certified mail, return receipt requested on December 30, 2002 addressed to: Julie L. Betts 433 Laudenslager Road Williamsport, PA 17701 and did thereafter receive same as evidenced by the attached Post Office receipt card dated December 31, 2002. I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING AFFIDAVIT OF SERVICE ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF, I UNDERSTAND THAT FALSE STATEMENTS HEREIN MADE ARE SUBJECT TO THE PENALTIES OF 18 PA.C.S. SECTION 4904 RELATING TO UNSWORN FALSIFICATION TO AUTHORITIES. Date TURO LAW OFFICES Robert J..,M_~ld'eri~'; Esquire-"--.~ 28 South Pitt Street Carlisle, PA 17013 (717) 245-9688 Attorney for Plaintiff Postage cE3 Certified Fee ru Return Receipt Fee (Endorsement Required) Restricted Delivery Fee (Endorsement Required) 1:3 ,--3 1::3 r~ TotalPostage & Fees Postmark Here Sent To .......... ...... Street, Apt. No.; or o ox~o. ~'~ SENDER: ~ a~so wish to r~Uve the ~ow- [] Complete items 1 and/or 2 for additional services, ing services (for an extra fee): ~ Complete items 3, 4a, and 4b. O Print your name and address on the reverse of this form so that we can return this card to you. 1. r-I Aj:idressee's Address 0 Attach this form to the front of the mailpiece, or on the back if space does not ~ ~ ....... permit. ". Ed' Hestrlctea Uellvery { o Write 'Retum Receipt Requested' on the mailpiece below the a;licle number. [] The Return Receipt will show to whom the article was delivered and the date delivered. 3. Article Addressed to: 2510 0009 2&27 8424 5. Received By: (Print Name) 7001 4b. Service Type ~ [] Registered El'Certified _[] E,,~,~ss Maill [] Insured UJ,'Return Receipt for Merchandise [] COD 8. Addressee's Address (~ly if r~uested ~ fee is ~id) 6~ Signatu, re (Address)ee or Ag/~nt) _ I t -- I~Form3~l~ D~ember199~ ~ - 102595-99-B-0223 Dome$~c RelumReceipt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW SCOTT L. BETTS, Plaintiff vs. ' NO. 02-5918 JULIE L. BETTS, Defendant NOTICE TO: SCOTT L. BETTS cio Robert J. Mulderig, Esquire Turo Law Offices 28 South Pitt Street Carlisle, PA 17013 You are hereby notified to plead to the within Answer To Complaint and Counterclaim within twenty (20) days from service hereof or a judgment may be entered against you. WILLIAM J. MIELE, P.C. Date: William J. Miele, Esquire Attorney for Defendant WILLIAM J. MIELE, P.C. 36 West Fourth Street Williamsport, PA 17701 (570) 322-2113 I.D. #32092 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW SCOTT L. BETTS, Plaintiff vs. : NO. 02-5918 JULIE L. BETTS, :IN DIVORCE Defendant ANSWER TO COMPLAINT COMES NOW, JULIE L. BETTS, Defendant in the above referenced matter, by and through her attorney of record, William J. Miele, Esquire, filing the following Answer to Complaint and Counterclaim, to wit: 1. Admitted. 2. Admitted. 3. ^dmitted. 4. Admitted. 5. Denied. In 1986 a divorce action wis filed in Hawaii. 6. Admitted. 7. No answer required. 8. Admitted. 9. Denied. The parties separated on October 28, 2002. They have lived separate and apart since that date. 10. Denied. The Defendant contends the marriage is not irretrievably broken. 11. No answer required. COUNTERCLAIM COUNT I DIVORCE: 12. Paragraphs 1-11 are incorporated herein by reference. 13. (a) In violation of the Defendant's marriage vows and the laws of this Commonwealth, the Defendant has offered such indignities to the person of the Defendant, she being the innocent and injured spouse, as to render her condition intolerable and life burdensome, Divorce Code 3301(a)(6) (b) The marriage of the Parties is irretrievably broken. The Parties have lived separate and apart for a period of two (2) years and the marriage of the parties is irretrievably broken with no reasonable expectation of reconciliation, Divorce Code 3301 (d). WHEREFORE, the Defendant requests the Court to enter a decree in divorce. COUNT II EQUITABLE DISTRIBUTION 14. Paragraphs 1-13 are incorporated herein by reference. 15. Plaintiff and Defendant legally and beneficially acquired real and personal property from the date of their marriage until the date of their separation. 16. Plaintiff and Defendant incurred debts during their marriage. 17. There is no written property agreement in effect between the parties. WHEREFORE, the Defendant requests this Court to determine marital real and property and marital debts, and to equitably divide, distribute and/or assign he property and debts. COUNT III ALIMONY PENDENTE LITE, SPOUSAL SUPPORT, ALIMONY COUNSEL FEES AND COST~ 18. Paragraphs 1-16 are incorporated herein by reference. 19. Defendant lacks sufficient property to provide for his reasonable means and is unable to support herself through appropriate employment. 20. Defendant requests reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. 21. Defendant is employed but is unable to support herself and is unable to pay counsel fees, costs and expenses in order to properly litigate this action in the absence of a reasonable contribution by Plaintiff. WHEREFORE, Defendant requests an award of reasonable Alimony Pendente Lite plus counsel fees and costs until final hearing; and Alimony for a reasonable thereafter. COUNT VI HEALTH INSURANCF 22. Paragraphs 1-21 are incorporated herein by reference. 23. Defendant needs continued health and hospitalization coverage for lerself during the pendency of this action. 24. Defendant requests health insurance for herself be paid by the Plaintiff. WHEREFORE, Defendant requests health and hospitalization insurance for herself to continue during the pendency of this action. Defendant also requests that the health insurance for herself be paid by the Plaintiff. Respectfully submitted, William J. Miele, Esq. Attorney for Defendant WILLIAM J. MIELE, P.C. 36 West Fourth Street Williamsport, PA 17701 (570) 322-2113 I.D. #32O92 VERIFICATION I verify that the statements made in this Answer to Divorce Complaint and Counterclaim are true and correct to the best of my knowledge. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities. ~ulie L. Betts 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA C1VIL ACTION - LAW SCOTT L. BETTS, Plaintiff, VS. JULIE L. BETTS, Defendant NO. 02-5918 CIVIL TERM CERTIFICATE OF SERVICE I, William J. Miele, Esquire, hereby certify that the Answer To Complaint and hearing date when scheduled, for Defendant, Julie L. Betts, were served upon Robert J. Mulderig, Esquire, by sending a copy U.S. Mail to 28 South Pitt Street, Carlisle, PA 17013, on this, the _~'~t~/~day of~,, 2003. William J. Miele, Esquire WILLIAM J. MIELE, P.C. 36 West Fourth Street Williamsport, PA 17701 (570) 322-2113 I.D. #32092 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SCOTT L. BETTS, Plaintiff NO. 02-5918 vs. IN DIVORCE JULIE L. BETTS, Defendant AND NOW, this I t P/~ day of_Nb( ~, 2003, the parties having agreed that neither shall dissipate, transfer, encumber or otherwise waste the marital estate, IT IS HEREBY ORDERED that both parties are prohibited from dissipating, transfemng, encumbering or otherwise wasting the marital estate. The property in the possession of the respective parties shall stay in possession of that party until further Order of Court. William J. Miele, Esquire Robert J. Mulderig, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SCOTT L. BETTS, Plaintiff NO. 02-5918 vs. IN DIVORCE JULIE L. BETTS, Defendant STIPULATION COMES NOW, SCOTT L. BETTS, by and through his attorney of record, Robert J. Mulderig and JULIE L. BETTS, by and through her attorney of record, William J. Miele, hereby stipulating and agreeing that: 1. The parties are husband and wife with a divorce action pending under the above caption and number. 2. During their marriage the parties have acquired various assets, including but not limited to, a mobile home, vehicles, household and personal property, a bank account plus 401K, and other retirement accounts. 3. The parties agree that during the pending of this action neither party will dissipate, transfer, encumber or otherwise waste their marital assets. Dated this _~ ~'~'' day of//)f~.~ ,2003 William J. Miele, Esquire IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SCOTT L. BETTS, Plaintiff VS. JULIE L. BETTS, Defendant CIVIL ACTION - LAW · NO. 02-5918 ORDER AND NOW, this day of ,2003, upon consideration of the attached Petition For Alimony Pendente Lite and Counsel Fees, it is hereby directed that the parties and their respective counsel appear for a hearing at the Domestic Relations Office, 13 North Hanover Street, Carlisle, PA 17013, on the day of ,2003 at m. in room BY THE COURT, CC: William J. Miele, Esquire William J. Miele, P.C. 36 West Fourth Street Williamsport, PA 17701 Attorney for Defendant Robert J. Mulderig, Esquire 28 South Pitt Street Carlisle, PA 17013 Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, SCOTT L. BETTS, Plaintiff VS. JULIE L. BETTS, Defendant PENNSYLVANIA CIVIL ACTION - LAW NO. 02-5918 PETITION FOR ALIMONY PENDENTE LITE AND COUNSEL FEES COMES NOW, JULIE L. BETTS, the above referenced Defendant, by and through her counsel of record, William J. Miele, Esquire, petitioning the Court to wit: 1. The parties are currently husband and wife with a divorce action pending under the above caption and number. 2. The Plaintiff has been assessed by both a psychiatrist and psychologist. 3. Both of these professionals have recommended the Defendant is not able to be employed at this time. 4. The Defendant is requesting the Court to schedule a hearing to award the Defendant Alimony Pendente Lite. 5. The Defendant is also requesting the Court to order the Plaintiff to pay her reasonable counsel fees. 6. Counsel for the Defendant has not contacted the Plaintiff's counsel for his concurrence, but counsel for the Defendant does not believe he would concur with this request. WHEREFORE, the Defendant respectfully requests this Honorable Court schedule a hearing on awarding the Defendant reasonable Alimony Pendente Lite and counsel fees to be paid to her by the Plaintiff. Respectfully submitted, William J. ll~l"/~le, E,~ire c/ ~- 3V~ LwL leAstMFJo u~ ~E~;tEr~ ePt. C. Williamsport, PA 17701 (570) 322-2113 I.D. #32092 Attorney for Defendant CC: William J. Miele, Esquire Robert J. Mulderig, Esquire VERIFICATION I verify that the statements made in the foregoing Petition are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unswom falsification to authorities. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW SCOTT L. BETTS, ' Plaintiff ' vs. 'NO. 02-5918 JULIE L. BETTS, Defendant CERTIFICATE OF SERVICE I, William J. Miele, Esquire, do hereby certify a true and correct copy of the foregoing Order and Petition For Alimony Pendente Lite and Counsel Fees, has been served upon Robert J. Mulderig, Esquire, counsel for the Plaintiff, by placing same in the United States Mail, postage prepaid and addressed to: 28 South Pitt Street, Carlisle, PA 17013, on this, the 14th day of April, 2003. William J. ~/efe, ~squire SCOTT L. BETTS, : Plaintiff/Respondent : : VS. : JULIE L. BETTS, : Defendant/Petitioner : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - DIVORCE NO. 2002-5918 CIVIL TERM IN DIVORCE Pacses# 893105475 ORDER OF COURT AND NOW, this 12th day of May, 2003, upon consideration of the attached Petition for Alimony Pendente Lite and/or counsel fees, it is hereby directed that the parties and their respective counsel appear before R.J. Shadday on June 13, 2003 at 9:00 A.M. for a conference, at 13 N. Hanover St., Carlisle, PA 17013, after which the conference officer may recommend that an Order for Alimony Pendente Lite be entered. YOU are further ordered to bring to the conference: (1) a true copy of your most recent Federal Income Tax Return, including W-2's as filed (2) your pay stubs for the preceding six (6) months (3) the Income and Expense Statement attached to this order, completed as required by Rule 1910.11© (4) verification of child care expenses (5) proof of medical coverage which you may have, or may have available to you IF you fail to appear for the conference or bring the required documents, the Court may issue a warrant for your arrest. BY THE COURT, George E. Hoffer, President Judge Mail copies on 5-12-03 to: Petitioner Respondent William Miele, Esquire Robert Mulderig, Esquire Date of Order: May 12, 2003 .~P~. ~ha~day, Conferenc~~ YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE CONFERENCE AND REPRESENT YOU. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. CIVIL ACTION - LAW ;OTT L. BETTS, vs. Plaintiff : CIVIL ACTION - DIVORCE : NO. 2002-5918 CIVIL TERM · IN DIVORCE JULIE L. BETTS, Defendant - PACSES NO. 893105475 PETITION FOR CONTINUANCE NOW COMES Julie Betts by and through her attorney, William J. Miele, Esquire, and moves for continuance as follows: 1. The above captioned matter is scheduled for a conference on the 13th day of lune, 2003, 9:00 a.m., before R. J. Shadday. 2. The opposing party is Scott L. Betts represented by Robert J. Mulderig, Esquire. 3. The proceeding was scheduled by Order dated May 12, 2003. 4. The proceeding has not been previously continued. 5. A continuance is requested because the parties are in the process of negotiating a X The opposing party has been notified of this request and has no objection. The opposing party has not been notified of this request. Efforts to notify the opposing party include: The opposing party objected to the continuance for the reasons stated herein: 7. I hereby certify that if a continuance is granted, ![ will notify all witnesses who would be tppearing at my request. I specifically request a continuance of not less than ninety (90) days of not more than to the next available date. _(o0 Respectfully submitted, William J. Miele, Esq. WILLIAM J. MIELE, P~C. 36 West Fourth Street Willismsport, PA 17701 (570) 322-2113 I.D. #32092 Attorney for Defendant William J. Miele, Esq. Robert J. Mulderig, Esq. In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION JULIE L. BETTS ) Docket Number Plaintiff ) vs. ) PACSES Case Number SCOTT L. BETTS ) Defendant ) Other State ID Number 02-5918 CIVIL 893105475 ORDER AND NOW, to wit on this 2ND DAY OF SEPTEMBER, 2003 IT IS HEREBY ORDERED that the O Complaim for Support or C) Petition to Modify or O Other ALIMONY pENDENTE LITE filed on MAY 9, 2,303 in the above captioned matter is dismissed without prejudice due to: THE PARTIES' SETTLING THE MATTER AND PLAINTIFF WITEDRAWING HER REQUEST FOR AN ALIMONY pENDENTE LITE CONFERENCE. 0 The Complaint or Petition may be reinstated upon written application of the plaintiff petitioner. xc: RJ Shadday plaintiff d~fgndant William Misl~, Esquir~ Robert Mulderig, BY THE COURT: Edward E. ~ Guido JUDGE Form OE-506 Service Type M Worker ID 21005 SEPARATION AGREEMENT This Agreement made this ~ ,7.~¢~' day of 2003, between Julie L Betts (hereinafter referred to as "WIFE") and Scott L. Betts hereinafter referred to as "HUSBAND"). WlTNESSETH: The Parties hereto are Husband and Wife, having been married on April 26, 1986. Diverse and unhappy differences, disputes and difficulties have arisen between the Parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the Parties hereto are desirous of settling fully and finally their respective financial and property dghts and obligations between them, including without limitation: (1) the settling of all matters between them relating to the ownership and equitable distribution of real and personal property; (2) the settling of all matters between them relating to the past, present and future support and/or maintenance of Husband and Wife; and (3) in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW THEREFORE, with the foregoing recitals being hereinafter incorporated by reference and deemed as an essential part hereof, and intending to be legally bound hereby, and for other good and sufficient consideration, the receipt whereof is hereby acknowledged, the Parties each having had the opportunity to be advised and represented by counsel, mutually agree as follows: A. GENERAL 1. AGREEMENT NOT PREDICATED UPON DIVORCE It is specifically understood and agreed by and between the Parties hereto and each of the said Parties does hereby warrant and represent to the other that the execution and delivery of the Agreement is not predicated upon nor made subject to any agreement for the institution, prosecution, defense or for the non-prosecution or non-defense of any action for divorce; provided, however, that nothing contained in the Agreement shall prevent or preclude either Party from defending any such action which may, has been, or shall be instituted by the other Party, or from making any lust or proper defense thereto. The Parties intend to secure a no-fault divorce pursuant to the provisions of Section 3301(c) of the Pennsylvania Divorce Code of 1980, as amended. The Parties will execute and agree to promptly file the affidavits required to obtain a divorce pursuant to Section 3301 (c) of the Divorce Code upon the expiration of the mandatory 90-day waiting period. Husband shall be responsible for the prompt filing of the Praecipe to Transmit the Record. 2 The Parties both acknowledge that more than ninety (90) days have passed since Wife was served with the Divorce Complaint. The Parties have represented to each other that each will promptly sign all necessary documents to finalize their divorce. If Wife fails to sign and return to Plaintiffs counsel this Separation Agreement and the necessary documents to complete the Divorce within thirty (30) days of receiving them, Husband at his option, can elect to declare this Agreement or any part thereof, null and void. If Husband elects to do this then Husband shall have the right to pursue relief under the Pennsylvania Divorce Code and his Divorce Complaint. 2. EFFECT OF DIVORCE DECREE This Agreement shall continue to be effective after the entry of a final decree in divorce between the Parties. 3. AGREEMENT TO BE INCORPORATED INTO DIVORCE DECREE This Agreement shall be incorporated into, but not merged with, any divorce decree which may be entered and the Court of Common Pleas entering the divorce decree shall retain continuing jurisdiction over the Parties and the subject matter of the Agreement for the purpose of enforcement of any of its provisions. 4. DATE OF EXECUTION The effective date of this Agreement shall be the date upon which it has been executed by the Parties. 3 5. ADVICE OF COUNSEL The terms of this Agreement and their legal effect have been fully explained to lhe Parties by their respective counsel, Robert J. Mulderig, Esquire, counsel for Husband, and William J. Miele, Esquire, counsel for Wife. The Parties acknowledge Ihat each has received independent legal advise from counsel of their selection and lhat they have been fully informed as to their legal rights available to them under the Pennsylvania Divorce Code of 1980, as amended. Each Party confirms that he or she fully understands the terms, conditions, and provisions of this Agreement and believes them to be fair and reasonable under the circumstances. The Parties further confirm that each is entering into this Agreement freely and voluntarily and Ihat the execution of this Agreement is not the result of any duress, undue influence, collusion, or improper or illegal agreement or agreements. 6. PERSONAL RIGHTS Husband and Wife may and shall, at all times hereafter, live separate and apart. Each shall be free from all control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as if she or he were unmarried. Each may reside at such place or places as he or she may select. Each may, for his or her separate use or benefit, conduct, carry on and engage in any business, occupation, profession or employment which to him or her may seem advisable. This provision shall not be taken, however, to be an admission on the part of either Husband or Wife of the lawfulness of the cause which led to, or resulted in, the 4 continuation of their living apart. Husband and Wife shall not molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt Io compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her. 7. MUTUAL RELEASES Except as otherwise provided for in this Agreement: (a) Each Party hereby releases and forever discharges the other and the estate of the other for all purposes from any and all rights and obligations which either has or at any time hereinafter may have for past, present or future support or maintenance, alimony bendente lite, alimony, equitable distribution, counsel fees, costs, expenses, and any other dght or obligation, economic or otherwise, whether arising out of the marital relationship or otherwise, including all rights and benefits under the Pennsylvania Divorce Code of 1980, its supplements and amendments, as well as under any other law of this or any other jurisdiction. (b) Each Party hereby releases and forever discharges the other and his or her heirs, executors, administrators, assigns, property and estate from any and all rights, claims, demands, or obligations adsing out of or by virtue of the marital relationship of the Parties or otherwise, 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, curtsey, widow's or widower's rights, family exception or similar allowance, or under the intestate taws, 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 5 . ithe laws of Pennsylvania, any state, Commonwealth or territory of the United States, or any other country. Except as set forth in this Agreement, the Parties each waive and release any and all right to receive insurance proceeds at the death of the other, whether as named beneficiary or otherwise, as well as any right to receive any legacy, bequest or residuary portion of the estate of the other under his or her Will (if executed prior to the execution date hereof), or to act as personal representative of the estate of the other. (c) Except for any cause of action for diw~rce which either Party may have )r claim to have, each Party gives to the other, by the execution of this Agreement, ~n 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 each other. 8. FINANCIAL DISCLOSURE Husband and Wife represent and warrant that they have disclosed to each other, in full, their respective assets (including the basis and holding period of such assets, where applicable), liabilities and income, and that this Agreement was negotiated and entered into on the basis of those disclosures. Any further enumeration or statement thereof in this Agreement is hereby specifically waived, and the Parties do not wish to make or append hereto any further exhibit or statement. 6 9. WAIVER OR MODIFICATION TO BE IN WRITING No modification or waiver of any of the terms of this Agreement shall be valid unless in writing and signed by both Parties and no waiver or any breach or default of this Agreement shall be deemed a waiver of any subsequent breach or default of the same or similar nature. Notwithstanding this provision, under applicable Pennsylvania law, the Parties understand that any term of this Agreement relating to child support or to custody may be subject to modification by the Court. 10. LAW OF PENNSYLVANIA APPLICABLE This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 11. AGREEMENT BINDING ON HEIRS Except as otherwise provided for herein, this Agreement shall be binding upon and shall inure to the benefit of the Parties and their respective heirs, executors, administrators, successors and assigns. 12. INTEGRATION This Agreement constitutes the entire understanding of the Parties and supersedes any and all prior agreements and negotiations between them. There are no representations or warranties other than those expressly set forth herein. 13. OTHER DOCUMENTATION Within ten (10) days after demand thereof, the Parties shall execute any and all wdtten documents which may be reasonably necessary or desirable for the proper effectuation of this Agreement. 7 14. NO WAIVER OF DEFAULT This Agreement shall remain in full force and effect unless and until d under the pursuant to the terms of this Agreement. The failure of either Party to insist upon stdct performance of any of the provisions of this Agreement shall in no way affect the right of such Party thereafter to enforce that provision. The of any breach of any provision hereof shall not be construed as a waiver of any subsequent breach of the same or similar nature, and shall not be construed as waiver of strict performance of any other obligations herein. 15. ADDRESS OF PARTIES As long as any obligations remain to be performed under this Agreement, Party shall have the affirmative obligation to keep the other informed of his or her residence address, and shall promptly notify the other, in writing, of any change of address. 16. REMEDIES AND SANCTIONS In addition to such other remedies and sanctions available under law, the Parties may utilize any remedy or sanction set forth in the Pennsylvania Divorce Code of 1980, as amended, to enforce any term of this Agreement as though it had been and Order of Court. 8 17. ATTORNEY'S FEES FOR ENFORCEMENT In the event that either Party breaches any term of this Agreement and the other Party retains counsel to assist in enforcing the terms hereof, the breaching Party shall pay all counsel fees and expenses which are incurred by the other Party in enforcing this Agreement, whether enforcement is ultimately achieved by litigation or by amicable resolution. Nothing herein contained shall be construed to restrict or impair their right to exercise this election. 18. WAIVER OF RIGHTS UNDER THE DIVORCE CODE Each Party hereto understands and hereby and forever waives any and all rights he or she may have pursuant to the Divorce Code of 1980 with respect to determination and disposition of existing property rights and interest between the Parties, Chapter 4 of the Divorce Code, and alimony, alimony pendente lite, spousal support, counsel fees and expenses, Chapter 5 of the Divorce Code, except as specifically provided herein. 19. RECONCILIATION In the event there is a reconciliation between Husband and Wife and they begin residing together as Husband and Wife, this Agreement shall remain in full force and effect unless voided by the Parties in writing. 20. HEADINGS NOT PART OF AGREEMENT Any headings preceding the text of the 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, constitution or effect. 9 21. CONTRACT INTERPRETATION For purposes of contract interpretation and resolving any ambiguity herein, the Parties agree that this Agreement was prepared jointly by their respective attorneys. 22. EFFECT OF DIVORCE DECREE The Parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final decree in divorce may be entered with respect to the Parties and shall not be altered by any decree of court hereafter except as to matters of custody or modification of support for their children. B. EQUITABLE DISTRIBUTION It is the desire of the Parties to amicably provide for the equitable distribution between them of all property acquired by either of them during their marriage, prior to their separation, in accordance with the provisions of Section 3501 of the Pennsylvania Divorce Code. The Parties hereby agree to be bound by the following division of their property as constituting a just and equitable division thereof. 10 1. DIVISION OF FURNISHINGS AND PERSONAL EFFECTS Each Party shall retain all items of personal property he or she brought into the marriage. Husband will retain as his sole property all furnishings and personal ieffects currently in his possession free and clear of all claims of Wife. Wife will iretain as her sole property all furnishings and personal effects currently in her )ossession free and clear of all claims of Husband. 2. VEHICLES The Parties hereto agree that Husband shall receive exclusive possession of he Ford Bronco and Barracuda in his possession. Husband agrees to assume full responsibility for any indebtedness on said vehicles and to indemnify and hold Wife harmless from any claims made thereon. The Parties hereto agree that Wife shall receive sole and exclusive ownership of the Chevrolet Corsica and Ford Escort currently in her possession. Wife agrees to assume full responsibility for any indebtedness on said vehicles and to indemnify and hold Husband harmless from any claims made thereon. The titles to said vehicles shall be executed by the Parties, if appropriate, for effectuating transfer as herein provided. 3. MOBILE HOME The jointly owned 1990 De Rose Mobile Home shall be conveyed to Husband and become the sole and exclusive property of Husband. Wife specifically waives, sets over, transfers and assigns all of her right, title and interest in said mobile home to Husband. 11 4. MONETARY SETTLEMENT The Parties agree that Wife shall be paid $5=~150.00 for her interest in the madtal estate. Said payment shall be made to Wife from Husband the date this Agreement is signed. 5. JOINT CHECKING ACCOUNT The Parties agree that Wife shall receive $6,573.86 from the joint checking account. Said payment shall be made to Wife from Husband the date this Agreement is signed. 6. RETIREMENT BENEFITS Husband and Wife hereby specifically release and waive any and all interest, claims, or dght that he or she may have to any and all retirement benefits (including )ension or profit sharing benefits) or other similar benefits of the other Party. The Parties further acknowledge and agree that they shall execute any documents )ursuant to the Retirement Equity Act or similar Act that may be required from time to time to accomplish the purpose of this Paragraph. 7. SEPARATE ASSETS Except as otherwise set forth in this Agreement, each Party shall retain as his or her separate assets all property presently titled in his or her name or in his or her possession. The Party not having title to or possession of any particular separate asset hereby waives and releases any and all claim therein, and acknowledges that hereafter the Party having title to or possession of a separate asset is the sole and exclusive owner thereof. With respect to his or her separate assets, each Party agrees to indemnify and hold the other harmless from any liability, cost or expense with respect to such separate assets. 12 Each party acknowledges that they have various bank accounts in his and her 3wn name. 8. AFTER-ACQUIRED PROPERTY Each Party shall hereafter own and enjoy, independently of any claim or right 3f the other, all property acquired by him or her after execution of this Agreement, with full power in him or her to dispose of the same as though he or she were unmarried, 9. WARRANTY AS TO EXISTING AND FUTURE OBLIGATIONS Each Party represents and agrees that he or she has not heretofore contracted for any debt, liability or obligation including those for necessities for which lhe other or the estate of the other may be responsible or liable for, except as )rovided for in this Agreement. Husband and Wife each agree to save harmless and ~demnify the other from all such debts, liabilities, and obligations which he or she has incurred whether prior to or after the execution date hereof. The Parties further agree that all joint credit and/or charge accounts have been or shall be terminated immediately, and no charges shall be incurred by either Party against any joint account from the date of execution hereof. 10. WAIVER OF BENEFICIARY DESIGNATIONS Unless otherwise specifically set forth in this Agreement, each Party hereto specifically waives any and all beneficiary rights and any and all rights as a surviving spouse in and to any assets, 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 13 ~ccounts, final pay checks or any other post-death clistribution scheme, and each 3arty expressly states that it is his and her intention to revoke by the terms of this ~,greement any beneficiary designation naming the ,other which are in effect as of the :late of the execution of this Agreement. If, in any event, the other Party continues to 3e named as beneficiary and no alternate beneficiary is otherwise designated, the 3eneficiary shall be deemed to be the Estate of the deceased Party. Notwithstanding the foregoing, however, in the event that either Party hereto specifically designates the other Party as the beneficiary after the date of execution 3f this Agreement, then this waiver provision shall not bar that Party from qualifying as such beneficiary. 11. ACKNOWLEDGMENT OF AWARENESS OF ALL CIRCUMSTANCES CONCERNING PROPERTY RIGHTS The Parties hereto respectfully acknowledged that each has full and adequate knowledge, and has made and obtained full disclosure of the marital property, holdings, and income of the Parties hereto, individually or jointly, and of the obligations of each of them either individually or jointly, and that they are agreeing to the division of the property as set forth herein with full knowledge and understanding of the actual values that they are receiving. In the event there are other assets not mentioned, neither Party waives any interest they may have to the asset(s). C. ALIMONY/SUPPORT 1. SPOUSAL SUPPORT/ALIMONY PENDENTE LITE/ALIMONY Both Parties waive any claims for spousal support, alimony pendente lite, and/or alimony that either may have against the other. 14 D. COUNSEL FEES/EXPENSES Each Party agrees to be responsible for their own counsel fees and court E. TAX MATTER.~ 1. INTENDED TAX RESULT AND INDEMNIFICATION By this Agreement, the Parties have intended to effectuate and by this reement have divided their marital property. The Parties have determined that such equal division conforms to a right and just standard with regard to the dghts of each Party. The division of existing marital property, is not, except as may be .= expressly provided herein, intended by the Parties to constitute in any way sale or exchange of assets and the division is being effected without the of outside funds or other property not constituting a part of the marital estate. As a part of the division of the madtal properties, the Parties agree that each shall be solely responsible for the tax consequences resulting from the property distribution for the property each is receiving. Furthermore, each Party agrees that the Party receiving ownership of the property which has resulted in tax consequences, shall indemnify and hold harmless the other Party from any liability resulting from the distribution. 2. TAX ADVICE Both Parties hereto hereby acknowledge and agree that they have had the opportunity to retain their own accountants, certified public accountants, tax advisor, or tax attorney with reference to the tax implications of this Agreement. Further, neither Party has been given any tax advise whatsoever by their respective attorneys. Further, both Parties hereby acknowledge that they have been advised, 15 by their respective attorneys, to seek their own independent tax advice by retaining an accountant, certified public accountant, tax attorney, or tax advisor with reference to the tax implications involved in this Agreement. Further, the Parties acknowledge and agree that their signatures to this Agreement serve as their acknowledgment that they have read this particular paragraph and have had the opportunity to seek independent tax advice. Each Party has carefully read and fully considered this Agreement and all of the statements, terms, conditions, and provisions thereof prior to signing below, IN WITNESS WHEREOF, the Parties have executed this Agreement the day and year first wdtten above. WITNESS: Robert O. tRR~ulderig, F_~o SCOTT L. BETTS Willi ire ~JI..IE L. BETTS - 16 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. SCOTT L. BETTS, Plaintiff VS. JULIE L. BETTS, Defendant : NO. 02-59t8 : CIVIL ACTION - LAW : IN DIVORCE, A.V.M. AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on December 12, 2002. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety (90) days have elapsed from the date of 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 the decree (unless waived), as follows (check either (a) or (b)): ./" (a) I consent to entry of a decree at this time, subject to the following protective provisions, to be contained in the decree: Separation Agreement to be incorporated into final divorce decree. v/ none __ (b) I do not consent to entry of a decree until all outstanding economic issues are resolved. I verify that the statements made in this Affidavit are tree and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Scott L. Betts~ Plaintiff 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. SCOTT L. BETTS, Plaintiff VS. JULIE L. BETTS, Defendant : NO. 02-5918 : CIVIL ACTION - LAW : IN DIVORCE, A.V.M. AFFIDAVIT OF CONSENT 1. A Complaint in Divome under Section 3301(c) of the Divome Code was filed on December 12, 2002. 2. The marriage of Plaintiffand Defendant is irretrievably broken and ninety (90) days have elapsed from the date of service of the Complaint. 3. I consent to the entry of a final Decree in Divome after service of notice of intention to request entry of the decree (unless waived), as follows (check either (a) or (b)): ~ (a) I consent to entry of a decree at this time, subject to the following protective provisions, to be contained in the decree: Separation Agreement to be incorporated into final divorce decree~ none __ (b) I do not consent to entry of a decree until all outstanding economic issues are resolved. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. ~lie L. Betts, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. SCOTT L. BETTS, Plaintiff VS. JULIE L. BETTS, Defendant : NO. 02-5918 : CIVIL ACTION - LAW : IN DIVORCE, A.V.M. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: fi' /3 O~ ~~~ Scott L. Betts, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNA. SCOTT L. BETTS, Plaintiff VS. JULIE L. BETTS, Defendant : NO. 02-5918 : CIVIL ACTION - LAW : IN DIVORCE, A.V.M WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses ifI 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 Prothonota~. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unswom falsification to authorities. Date: J~u4ie L. Betts, Defendant Scott L. Betts, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 02-5918 CIVIL TERM Julie L. BeEs, Defendant : CIVIL ACTION - LAW :IN DIVORCE PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information to the court for entry of a Divorce Decree: 1. Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. 30, 2002. 3. Divorce Code. By Plaintiff: August 13, 2003 4. Related claims pending: None. 5. Date the Waiver of Notice in §3301(c) divorce was filed with the Prothonotary: By Plaintiff: September 3, 2003 By Defendant: September 3, 2003 Date and manner of service of the complaint: Certified mail on December Date of execution of the Affidavit of Consent required by §3301 (c) of the By Defendant: August 27, 2003 Attorney for Plaintiff 1N The COURT Of COMMON OF CUMBERLAND COUNTY STA. YE Of PENNA. Scott L. Betts VERSUS ~ulie Lynn Betts NO. 02-5918 PLEAS DECREE IN DIVORCE AND NOW, ~__~_~ ,2003 DECREED THAT Scott L. Betts AND Julie Lynn Betts ARE DIVORCED fROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The Separation Agreement is incorporated but not merged herein ~ IT IS ORDERED AND , PLAINTIFF, , DEFENDANT, BY THE COURT: ~ ~ /~ -- ~/PROTHONOTARY THE COURT OF COMMON PLEAS OF CUMBERL/uND COUNTY, PENNSYLVANIA L. BETTS, : Plaintiff : NO. 02-5918 vs. i CIVIL ACTION - LAW LYNN BETTS, : IN DIVORCE, A.V.M. Defendant AFFIDAVIT FOR RESUMPTION OF FORMER NAMe... pENNSYLVANIA ,YCOMING JULIE LYNN BETTS, being duly sworn according to law, deposes and says that she ; the Defendant in the above suit in which a final decree from the bonds of matrimony was 2003; that Defendant elects to retake and hereafter use her former JULIE LYNN SAUTER, and therefoxe, gives this written notice avowing said intention in accordance with the provisions of the Act of May 25, 1939. P.L. 192, as ~ and subscribed ,~ me this ~) +~day of t yPubflc ' - My Commission Expires: Julie Lynn Bells to be known as Julie Lynn Sauter