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HomeMy WebLinkAbout97-01381 _-..1. ~ ~ { "t .3 ~ , JUDITH A. WAMBOLD, Plaintiff v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 97-1381 CIVIL TERM EDWARD J. WAMBOLD, Defendant IN DIVORCE ORDER OF COURT AND NOW, this ;z -r day of i)c.c.c.,..l.oY 1991-, upon a Stipulation for Entry of Court Order for Payment of Alimony in Accordance with Agreement of the Parties, it is hereby ordered and directed that upon the entry of a final decree in divorce in this matter, that Husband shall pay the sum of $462 per month, as alimony, in accordance with the terms of a Separation Agreement dated November 18, 1997, entered into between the parties, with said alimony to be paid by wage attachment and to be payable through the Domestic Relations Section of the Cumberland County Court of Common Pleas. By the Court, ./1 ;f J -~ . JUDITH A. WAMBOLD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL DIVISION NO. 97-1381 CIVIL TERM EDWARD J. WAMBOLD, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information to the court for entry of a divorce decree: 1. Ground for divorce: irretrievable breakdown under ~3301(c) 3301(d) (1) of the Divorce Code. (Strike out inapplicable section.) 2. Date and manner of service of the Complaint: March 20, 1997 - First class mail, return receipt requested - restricted delivery 3. Complete either paragraph (a) or(b). (a) Date of execution of the affidavit of consent required by ~3301(c) of the Divorce Code: by Plaintiff December 16, 1997 _; by Defendant December 8, 1997 (b) (1) Date of execution of the affidavit required by ~3301(d) of the Divorce Code: ; (2) Date of filing and service of the Plaintiff's affidavit upon the Respondent:____ 4. Related claims pending: Separation Agreement dated November 18, 1997, is incorporated in the decree 5. Complete either (a) or (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiff's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: December 16, 1997 Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: December 16, 1997 I "" t .. .:+:.' ':C-' .:.:. ,:'>'.:+:.'--:.:.- ':.;".:.:." .:ct".:c. .:.:. .:.:. .:.:. .:.:. .:.:. .:.:. .:.:. .:.:. .:.:. .:.:..)...:.:....:.:.::.:.:.~;.:.:.".:.> .:+:- ':.:":+}:'{.:-:~~ ~ - ~ ~ .' ;.' ~ ~ ... t ~.' ~ ~. w <;. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF '* PENNA. ,,~ ~ ~ ~~ .;, ., ;.; ~ ,'~ ~ ,'. ~ ~ ~ *- ',' ,', * ~ ,', ~ w ~.~ ,'~ ~ ~ !~ ,.; ~ ~.; ~ a ~.~ $ ~, ~ ;-'; .', ~ ;'~ ~ ,', ~ ~ ~.' ~ ~ ~.' ~ '.' ~ ',' ~ *- .,. ~ ~ : n Y -.; e ,c 0 A Ii : ~ All~~i: ' ~l'ld~f.~ J, l~ ~ -;r ~ !~ L. . _ ... ..._...::<<~ ~k.~ ~~"O"O,." i! ~~~~-~~~~-~-~----*---~-~--**~~. ~ ~ w. '.' ~ ,.' ,~ ~ ~ ~.' JUDITH A. WAMBOLD u.....u........ 11 i! . .................... . l 'I N ll. ,..n::-.p.!u...<:;IvJk:n;~ Plaintiff ~ ~l VCI'SlIS ~ ',' ,'~ ~ ..,.ED\o!~D r. ,~A.l1BOLIl,.., ........... :! ..' Defendant ,I .;; ., ." ~ ~.' ~ ',' DECREE IN DIVORCE ~ ',' ,.; ~ ~ I~ ~ ~ " ~ .~ ~ AND NOW, ........~.. "~:~:...... 19 ,~~..,. it is ordered and decreed that,.", .~~~~~~ ,~: ,~~~~~~~..,",.,"",.,..,',.,.",. plaintiff, and"...."....,., ~~!'I!lF~, ~,', !"!l!")>!,,l~, '.'""",."."" "",'. defendant, are divorced from the bonds of matrimony. w ... ~ w ~.' The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; ~ ,.' ~ Separation Agreement dated November 18 , 1997, to be incorporated in final .................... ................ ........................ .............., " ., ,d.er-.r,e.e.., . , , v ~.' ,'" Wambold Ssp Agt/ll.10/97/11.17.97 SEPARATION AGREEMENT THIS IS AN Agreement made this IftJ) day of ffive")onL~J.Ar- , 1997, by and between Edward J. Wambold (hereinafter referred to as Husband) and Judith A, Wambold (hereinafter referred to as wife). WHEREAS, Husband and Wife were married on August 7, 1977, in Alpha, New JerseYi and WHEREAS, various differences have arisen between Husband and Wife, whereby they have been living separate and apart since June 17, 1997i and WHEREAS, the parties have agreed to maintain separate and permanent domiciles and to live apart from each otheri and WHEREAS, the parties desire to enter into an amicable settlement to provide for all of the property rights of the parties and to dispose of the rights and obligations of each to the other in respect to support, maintenance, alimony, counsel fees, equitable distribution, and all other rights and obligations under the Divorce Code of 1980, as amended, and it is the intention and agreement of the parties that this Agreement be a full, complete and final settlement of all of those rights and obligations under said Divorce Codei and NOW, THEREFORE, for and in exchange of mutual considerations, and intending to be bound by the provisions hereof, the parties agree that their recitals form a part of this Agreement and waive any right to counseling under the Divorce Code of 1980, as amended, and right to counsel fees, costs, alimony, support, maintenance, and any other rights under the said Divorce Code not provided for herein and agree as follows: 1. SEPARATION. The parties agree that it shall be lawful for each party, at all times hereafter, 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 contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement and as may be necessary to exchange information that pertains to the parties' minor children. 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. '. 2. REAL ESTATE. Husband and Wife jointly owned the marital residence located at 580 Cranes Gap Road, Carlisle, Cumberland County, Pennsylvania. The marital residence was sold on July 23, 1997. The net settlement proceeds shall be distributed as follows: $18,000.00 to Husband and the remainder to Wife. 3. AUTOMOBILES. Husband shall have as his sole and exclusive property, title to and possession of the 1979 Porsche. Wife shall have has her sole and exclusive property, title to and possession of the 1987 Ford van. Each party shall indemnify and hold the other harmless from any liability on any loans encumbering said vehicles, cost of repairs, maintenance, registration, insurance and/or inspection of the vehicle which each is taking as his/her sole and exclusive property. 4. PERSONAL PROPERTY. The parties have divided or have agreed to a division of their personal property which includes bank accounts, jewelry, clothing, furniture and other personal items. After the aforesaid division of the personal property is complete, any and all property in the possession of Husband shall be his sole and separate property. Any and all property in the possession of Wife shall be her sole and separate property. Each party forever renounces whatever claims he/she may have with respect to the property which the other is taking, Each party understands that he/she has no right or claim to any property acquired by the other after the signing of this Agreement. 5. PENSION/RETIREMENT PLANS. Husband's 401(k) Plan with Sprint has previously been distributed by the parties in accordance with a Stipulation dated May 27, 1997. Wife hereby releases any and all claims or demands she may have on Husband's remaining Sprint pension benefits including, but not limited to, any additions/contributions to the aforesaid 401 (k) plan made by Husband or Husband's employer since May 27, 1997. 6. DEBTS. The parties represent and warrant to each other that neither has incurred any other debts nor made any oth~r contracts for which the other or his/her estate may be liable, from date of separation forward. Neither party shall contract nor incur any debtor liability for which the other or his/her property or estate might be responsible and agrees to indemnify the other from any claims made against the other because of debts/obligations not incurred by the other. Husband shall assume and bear sole responsibility for payment of the Corestates credit card and Cornerstone Federal Credit Union obligations. Wife shall assume and bear sole responsibility for the Montgomery Ward and Fashion Bug credit card obligations, Each party shall indemnify and hold , , harmless the other from any liability, claims, causes of action, suits, or litigation arising out of failure of each party to so pay such obligations as assumed by each herein. 7. ALIMONY. ALIMONY PENDENTE LITE. SUPPORT OF SPOUSE. Husband is currently paying to Wife spousal support pursuant to an Order of Court dated June 5, 1997, entered at 1214-S-92, DR' 20,800, allocated as $938.00 per month for children and $462,00 per month for Wife. Husband shall pay to Wife for a period of three (3) years from the date of this Agreement the sum of $462.00 per month, as spousal support and, after the entry of a final divorce decree, as alimony. Husband shall continue to pay spousal support and alimony to Wife, as aforesaid, by wage attachment payable through the Domestic Relations Section of the Court of Common Pleas. The payment of alimony to Wife shall cease upon Wife's remarriage or upon death of Wife. 8. EFFECTIVE DATE, The effective date of this Agreement shall be the date of execution by the parties if they had each executed the Agreement on the same date. Otherwise, the execution date of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 9. DIVORCE. The parties agree that should either party file a Complaint in Divorce, claiming that the marriage is irretrievably broken under the no-fault mutual consent provision of Section 3301(c) of the Pennsylvania Divorce Code, then both parties agree 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 including waiver of all rights to request Court ordered counseling. It is agreed and understood between the parties that in the event a divorce proceeding is filed by either party in any other jurisdiction, that the parties shall not contest, but instead consent to such proceedings and shall execute any and all documents necessary so as to proceed with and obtain an absolute and final divorce. 10. INCORPORATION INTO DECREE, 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 1 and that nothing in any such decree, judgment, order or further modification and revision thereof shall alter, amend or vary any term of this Agreement, whether or not either or both of the parties shall remarry, it being understood by and between the partes hereto that this Agreement shall survive and shall not be merged into any 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 its 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. 11. MUTUAL RELEASE. Husband and Wife do hereby mutually remise, release, quit claim or 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, of whatever nature and wherever situate, which he or she now has or at anytime hereafter may have against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other 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 or other rights of the 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 right which either party may now have or at anytime hereafter have for past, present or future support or maintenance, alimony, alimony pendente lite, counsel fees, costs or expenses, whether arising as a result of the marital relation or otherwise, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any 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. 12. COUNSEL PEES, Each party individually covenants and agrees that he or she will individually assume the full and sole responsibility for legal expenses for his or her attorney and court costs in connection with any divorce action which may be brought by either party and shall make no claim against the other for such costs or fees, 13. 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 or documents that may be reasonably required to give full force and effect to the provisions of this Agreement. 14. MODIFICATION OR WAIVER. A modification or waiver of any of the provisions of this 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. 15. ENTIRE AGREEMENT. This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. 16. SEPARATE PARAGRAPHS. It is specifically understood and agreed by and between the parties thereto that each paragraph hereof shall be deemed to be a separate and independent agreement. 17. BREACH. If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her and the party breaching this Agreement shall be responsible for payment of legal fees and costs incurred by the other in enforcing the rights under this Agreement, or in seeking such other remedies or relief as may be available to him or her. lB. CONTROLLING LAW. This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 19. INVALIDITY OF PROVISIONS. 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. 20. BINDING NATURE, Except as otherwise set forth herein, this Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. JUDITH A. WAMBOLD, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . v . CIVIL ACTION - LAW . . . EDWARD J. WAMBOLD, . 97-1381 CIVIL TERM . Defendant . . . IN DIVORCE . ORDER OF COURT AND NOW, this 'S"' day of "?on '/ , 1997, upon a Petition for Special Relief pursuant to Pa RCP 1920.43, it is hereby ORDERED and DIRECTED, as follows: A. A preliminary injunction is issued directing Respondent not to remove or dispose of any marital property, except for the use of marital funds for regular household expenses and obligations, pending further Order of Court~ B. A hearing is scheduled for the 1 ttj day of )17 d ~ , 1997 at ~; 30 L.M. in Courtroom No. ~ of the ~Umberland County Courthouse, CarliSle, Pennsylvania. BY THE COURT, .Ad J. 4-lf97 )Jell-ie, (ll7-'J :IotUel '~ltj(}}lJ.N'j iJ '. 5 The parties are the parents of five children, all of which reside in the marital residence. 6 The parties' only daughter, Jennifer A. Wambold, is a quadriplegic. 7 The Petitioner has limited income from working part time with the Carlisle Area School District as a cafeteria worker and at Turkey Hill Market as a sales clerk, while spending the majority of her time caring for the parties' daughter. 8 The Respondent is employed with Sprint, and the Petitioner believes and therefore avers that in Mayor June of this year that he will be separating from his family and moving to Ohio. 9 The parties' marital residence is very much in need of repair with a serious health hazard being evident as a result of a malfunctioning on-lot septic system. 10 When Respondent does separate from Petitioner, the Petitioner will continue to reside in the marital residence with the parties' children. 11 The Respondent has sold two Porsche automobiles and various pieces of ham radio equipment over the last several months, all of which is marital property. 12 The Petitioner has no knowledge of what Respondent has done with the proceeds from the sale of the various automobiles and ham radio equipment. 13 The Respondent has sole control of the parties' finances. 14 The marital residence, which is in dire need of repair, as indicated herein, is the sole remaining substantial marital asset. 15 The Petitioner desires that the Respondent provide for a full accounting of the disposition of any and all marital assets from April 1, 1996 to the present. 16 The Petitioner believes and therefore avers that a preliminary injunction should be issued preventing the Respondent from disposing of any and all marital assets pending further Order of Court and after hearing, to issue an injunction prohibiting the disposition of any marital property without first obtaining Court approval, for the following reasons: A. The Respondent is continuing to liquidate marital assets and refuses to tell Petitioner what he is doing with the proceeds from the sale of any assets~ B. The Petitioner fears that the proceeds from the sale of marital assets are or will be disposed by Respondent~ and C. Immediate harm or injury may result if Respondent disposes of marital assets and/or the proceeds from the sale of marital assets. 17 The Petitioner believes and therefore avers that it is in the parties' best interest to direct the Respondent to take immediate action to remedy the on-lot sewage septic problem in the marital residence so as to alleviate the serious health hazards. WHEREFORE, the Petitioner requests your Honorable Court to order as follows: A. To issue a preliminary or special injunction preventing Respondent from removing or disposing of any marital property, except for the use of marital funds for regular household expenses and obligations, pending further Order of Court~ B. After hearing, to issue an injunction preventing the Respondent from removing or disposing of any marital property, without first obtaining Court approval~ JUDITH A. WAMBOLD, . IN THE COURT OF COMMON PLEAS OF . Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . v : CIVIL ACTION - LAW . . EDWARD J. WAMBOLD, 97-1381 CIVIL TERM Defendant . IN DIVORCE . CERTIFICATE OF SERVICE I, Christopher C. Houston, Esquire, do hereby certify that on this date I served the aforesaid Petition by hand delivery on the following: John Wesley Weigel, III, Esquire 7 Irvine Row Carlisle, PA 17013 Date: .'Ifi~ 1-: Christop Attorney Broujos, Gilroy & Houston, P.C. 4 North Hanover Street Carlisle, PA 17013 717 - 243-4574 F. VI .. _3 '.. OJ 1". IJJf I - .'- . (.Ji ;, "~ [f 3: ; '~"l Cj':. ~:: .~ ~] 6;.' :.-, .- -.., UJC. I ~..: a:~! ,1.: ..:-" :j r- C.. .'~ .. "'7- l', h .J CJ Cf1 '..J wambold.dlvl3.14.97 JUDITH A. WAMBOLD, : IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . v CIVIL DIVISION - LAW . . EDWARD J. WAMBOLD, 97- /3K/ CIVIL TERM Defendant . . IN DIVORCE COMPLAINT Plaintiff, Judith A. Wambold, by her attorneys, Broujos, Gilroy & Houston, P.C., sets forth the following: 1 Plaintiff, Judith A. Wambold, is an adult individual residing at 580 Cranes Gap Road, Carlisle, Cumberland County, Pennsylvania. 2 Defendant, Edward J. Wambold, is an adult individual residing at 580 Cranes Gap Road, Carlisle, Cumberland County, Pennsylvania. 3 The parties were married on August 7, 1977, in Alpha, New Jersey. 4 Plaintiff and Defendant have lived continuously in the Commonwealth of Pennsylvania for at least six months prior to the commencement of this action. 5 This action is not collusive. 6 There have been no prior actions for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 7 In accordance with Section 3301 (c) of the Divorce Code, the marriage between the parties is irretrievably broken. 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. WHEREFORE, the Plaintiff requests your Honorable Court to decree that the Plaintiff be divorced from the Defendant. COUNT II - EQUITABLE DISTRIBUTION 9 Paragraphs 1 through 4 of the Complaint are incorporated herein by reference as though set forth in full. 10 Plaintiff and Defendant have acquired property, both real and personal during their marriage from the date of the marriage until the present. 11 Plaintiff and Defendant have been unable to agree as to an equitable division of said property. - 0 ~ ~ ~ - .... "-.J \;)'- ~ . it. ::l- . ~ t ~ ~ ~ ~ '.. <'I ~:3t r.;; r': - ,,~ .- 1I1~.. ".j J _ ~~ e. ~ l;..'" .' ,. <:) 0 Ie:. '<;) e' L. ; ~~ () ~ c. I.t) ~ (~:- en ~ -..... ...... ie' c: . :.;j ~ ~ - f C . ':..to- IL r- 0 U O'~ (J .. 0 .- C:I '>- n: -. f,: ;::: .- .- ,..... ,.'.--: HI~, --: '..).-. c)-, :.r: ~~) .~: --.( . L ~. ~. . Or:'~ ::>-. "., t... I 1-' ~ ;1) @r'_ , 'L :::,;: [f" . '-' ;,".J :"-, 0, r 0 , ;l.. l:':' t. r- ':3 b C' u . "' . . " I JUDITH A. WAMBOLD, . IN THE COURT OF COMMON PLEAS OF . Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . . v . CIVIL ACTION - LAW . EDWARD J. WAMBOLD, . 97-1381 CIVIL TERM . Defendant . . . IN DIVORCE . WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER ~ 3301(0) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities. Date: 1& - 1(, -f7 ~ 0. .ft)th.!~ JUDI A. WAMBOLD Plaintiff ..... '-'I Co (~ ..:l ~ ..... ~~ ., ~-~ . c;.'''; ltJ' , ~- , ().r,: . ..... " F':~ ~.., ". bf~ ,c. I" J ';- Co"'- ,.!) :l';~l [:~ ~'~ ' - '"'.:/: L'. ': I~~ t:'. P ~; "'- 1'_ r- ::; C' 0' U ,. 1'" '- i~: -"' I:; i:~ ~ ::'t; " '. :'-.. U.I~ , l , . i . , ~, " (.. ;~~ ~~~: :, D , , . "! l ,.j . c: , L' i ;,~.t l l. 0 W r , r- :';5 d 01 U .... 1"" :...~ t:.: - I::: ".., I - t t~ ( , ~" ) -' (;1 ~- ..- {~~ L',,: 1..... ! ", 0," 1.= r'.: .:> .. WI' ;:....}" t.~ .~. ~r:~1 co. , t..., ~)~ r"' c::; 1.:... r-- ":'j (J 0,-' (.) . ,. . . I' ~ JUDITH A. WAMBOLD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v NO. 97-1381 CIVIL TERM EDWARD J. WAMBOLD, Defendant IN DIVORCE AFFIDAVIT OF SERVICE I, Christopher C. Houston, Esquire, being duly sworn according to law do depose and state that a copy of the Complaint filed in the above-captioned matter along with a copy of a Notice to Plead and a Notice of Availability of Marriage Counseling was served on the Defendant, Edward J. Wambold, by Certified Mail - Return Receipt Requested, restricted delivery, a copy of said return receipt evidencing delivery being attached hereto. Said service on March 20, 1997. ~ c. Bon.ton, Attorney for Plaintiff 52 West Pomfret Street Carlisle, PA 17013 717 - 241-5970 Esquire Sworn and subscribed to before me this /~f~ day of ~~ , 1997. ~ I. ,d....A.A J V,..JS-- ~ry pubUr- --- --,..,........, '- c_..... f 1 -c..,. M "", . ..............,,- '.. U" ..~) , .. pl . -, '17 ..... .' () ; {l , (, ~ i,.; L, , , I ; {., " r': .1 ~ '_J .. " . . . r, .