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MARRIAGE SETTLEMENT AGREEMENT
THIS AGREEMENT, made this \ q ~ day of
1997, by and between MIC:iAEL S. ANDERSON, of the Borou of Camp
Hill, Cumberland County, Pennsylvania, hereinafter referred to as
"Husband", and BETH A. ANDERSON, of the Borough of Camp Hill,
Cumberland County, Pennsylvania, hereinafter referred to as "Wife,"
WITNESSETH:
WHEREAS, Husband and Wife were married on June 25, 1983; and
WHEREAS, differences have arisen between Husband and Wife in
consequence of which they are living separate and apart from each
other; and
WHEREAS, Husband and Wife have made a full disclosure of their
assets to each other; and
WHEREAS, Husband and Wife desire to settle and determine their
rights and obligations with respect to each other, including the
disposition and distribution of property rights and interests,
including alimony, between them,
WHEREAS, Husband and Wife are the parents of three minor
children, to wit: Sara Elizabeth Anderson, born September 25, 1984,
Kathryn Paige Anderson, born February 16, 1989, and Margaret
Victoria Anderson, born March 25, 1992, and do also desire to
resolve and settle any dispute between themselves with regard to
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the matters of custody, visitation and support as to the minor
children.
NOW, THEREFORE, the parties intending to be legally bound
hereby, do covenant and agree:
1. SEPARATION, It shall be lawful for each party at all
times hereafter to continue to live separate and apart from the
other party at such places as he or she may from time to time
choose or deem fit. The foregoing provisions shall not be taken as
an i;ldmission on the part of either party of the lawfulness or
unlawfulness of the causes leading to their living apart, which
living apart, or physical separation, has existed since December,
1993,
2, INTERFERENCE. Each party shall be free from interference,
authority, and contact by the other, as fully as if he or she were
single and unmarried except as may be necessary to 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.
3. WIFE'S DEBTS, Wife represents and warrants to Husband
that since the separation she has not and in the future she will
not contract or incur any debt or liability for which Husband or
his estate might be responsible and shall indemnify and save
harmless Husband from any and all claims or demands made against
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him by reason of debts and obligations incurred by the Wife prior
to the date of the delivery of this Agreement, and all further
debts incurred by the Wife from and after the date of delivery
hereof, shall be the Wife's individual responsibility.
4, HUSBAND'S DEBTS, Husband represents and warrants to Wife
that since the separation he has not and in the future he will not
contract or incur any debt or liability for which Wife or her
estate might be responsible and shall indemnify and save harmless
Wife from any and all claims or demands made against her by reason
of debts or obligations incurred by him. Husband acknowledges and
agrees that all debts and obligations incurred by the Husband prior
to the date of the deli very of this Agreement, and all further
debts incurred by the Husband from and after the date of delivery
hereof, shall be the Husband's individual responsibility.
5. JOINT DEBTS. The only joint debts which the parties have
are those items of indebtedness associated with the ownership of
their marital home, which includes the existing mortgage upon the
marital home. Husband agrees that he shall pay all joint debts of
the parties and shall in1emnify and hold harmless Wife from any
further liability with regard to any such joint debts, The payment
of the mortgage is separately treated in a subsequent paragraph
entitled "REAL PROPERTY,"
6, MUTUAL RELEASE. Subject to the provisions of this
Agreement, each party has released and discharged, and by this
Agreement does for himself or herself, and his or her heirs, legal
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representatives, executors, administrators, and assigns, release
and discharge the other of and from all causes of action, claims,
rights, or demands, whatsoever in law or equity, which either of
the parties ever had or now has against the other, except any or
all cause or causes of action for divorce and except for any or all
causes of action for breach of any provision of this Agreement.
7. DISCLOSURE OF PROPERTY. Husband and Wife acknowledge and
agree that they have made a full and complete disclosure to the
other of all information pertaining to the parties' separate and
marital property owned, possessed and/or controlled by the other at
the time of the separation of the parties and, further, have made
such full and complete disclosure by the filing by each of them in
the pending action in divorce of a formal Inventory and
Appraisement.
8. DIVISION OF PERSONAL PROPERTY. The parties have reached
agreement upon the division between themselves of the furniture and
other articles of personal property contained in their marital home
and do hereby ratify and confirm the verbal agreement which they
have already reached,
9. BANK ACCOUNTS. The parties have already divided between
themselves, to their mutual satisfaction, all banking accounts
heretofore separately or jointly owned by them, do hereby ratify
the division which they have made, and do acknowledge that any
banking account presently titled in the name of Wife shall be and
remain her separate asset, and any banking account separately
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titled in the name of Husband shall be and remain his separate
asset.
10, AUTOMOBILES. The parties have three automobiles which
are: a 1987 Volvo automobile, titled in the name of Wife, a 1978
peugot automobile, titled in the name of both Husband and Wife, and
a 1997 Ford Crown Victoria, which is an automobile leased solely in
the name of Husband, The parties agree that sole title and
ownership of the aforementioned Volvo and peugot shall be solely
and exclusively in the name of Wife and that said vehicle shall
hereafter be her sole and separate property. The parties further
agree that, to the extent Wife has an interest in the 1997 Ford
Crown Victoria, she hereby releases that interest in favor of
Husband so that Husband shall be the sole lessor, sole equitable
owner, and sole obligor with regard to such leased automobile. To
the extent any further documentation needs to be signed, or title
transferred, in order to accomplish the intent and purpose of this
paragraph, both parties pledge their cooperation to each other in
the prompt completion of any such additional documentation.
11, REAL PROPERTY. The parties are the joint owners of real
estate known as 2621 Logan Street, Borough of Camp Hill, Cumberland
County, Pennsylvania, Said real estate has an approximate market
value in the $140,000 to $150,000 range, but is subj ect to a
Veterans Administration,insured mortgage loan, the balance of which
is approximately $100,000, The parties agree to the following with
regard to their real property/marital home, to wit:
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A, Upon the entry of a Decree in Divorce (Complaint
already filed by Wife), Wife shall remove herself from further
occupancy in the marital home;
B, From the date of Wife's removal from the marital
home, Husband shall be solely responsible for the payment of
any pre-existing bills or debts associated with the home, and
shall continue, thereafter, to be solely responsible for the
payment of any new bills or expenses associated with the
occupancy of the hOMe. Particularly, Husband agrees that he,
alone, shall be responsible for the continued payment of the
mortgage loan associated with the marital home and agrees that
he shall, by these presents, indemnify and hold harmless Wife
from any further liability or responsibility in conjunction
therewith,
C, Title to the marital home shall remain in the joint
names of Husband and Wife for a period of time not to exceed
two years from the date of this Agreement, within which period
of time: (1) Husband shall pay to Wife the cash sum of Nine
Thousand Eight Hundred ($9,800.00) Dollars ($5,000 of which
shall represent Wife's marital share in the home, and $4,800
of which shall represent satisfaction of Husband's deferred
obligation of support for the children of the parties), in
exchange for which payment, Wife shall deliver to Husband a
deed conveying to and relinquishing to Husband all of her
title and ownership in the marital home, QI, (2) Husband shall
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fail to pay to Wife the aforementioned sum of money, in which
case, both parties shall be obliged to cooperate with each
other in placing for sale and selling the marital home. The
provisions for payment to Wife of her marital share, set forth
herein, is designed to recognize, in part, the obligation
which Husband has agreed to undertake to pay certain items of
indebtedness of the parties as previously set forth in
paragraphs 4 and 5.
D, In the event the marital home is to be sold, as set
forth above, the parties agree that, as set forth in the
immediately preceding subparagraph 12.C., the sum of $9,800.00
shall be paid to Wife from the proceeds of sale.
E. In the event Husband makes payment to Wife and
receives a deed to the marital home, he shall receive that
deed subject to the assumption of the existing mortgage upon
the premises, and shall, by his acceptance of that deed, agree
to indemnify and hold harmless Wife from any further liability
or responsibility with regard thereto.
F. Wife agrees that she shall continue to cooperate in
the prosecution of a lawsuit against Bell Atlantic for the
recovery of damages caused to the marital home. Both parties
agree that, in the event the proceeds deri ved from the
lawsuit, or settlement thereof, after payment of Court costs
and attorney's fees, shall exceed the cost of repairing the
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damage occasioned by the actions of Bell Atlantic, such excess
proceeds shall be divided equally between Husband and Wife.
12. SPOUSAL SUPPORT. ALIMONY. ALIMONY PENDENTE LITE. COUNSEL
FEES AND EXPENSES, Both parties hereby waive and relinquish
any right which each of them may have to seek or to receive from
the other party the payment of any sums of money as spousal
support, alimony, alimony pendente lite or counsel fees and
expenses, Wife acknowledges that she has caused to be instituted
the presently-pending action in divorce in the Court of Common
Pleas of CUmberland County (at Civil Action No, 97-2519) and agrees
that she, alone, shall be responsible for all her attorneys' fees
and Court costs associated with said divorce action.
13. CUSTODY OF CHILDREN. Husband and Wife are the natural
parents of three minor children, to wit: Sara Elizabeth Anderson,
born September 25, 1984, Kathryn Paige Anderson, born February 16,
1989, and Margaret Victoria Anderson, born March 25, 1992, The
parties have endeavored to reach an amicable agreement with regard
to their respective rights, privileges and responsibilities to each
other and to their minor children, and pledge each to the other,
that they shall continue to cooperate with each other, and with
their children, in an effort to see that their children achieve
adulthood with a minimum of disruption in their daily lives, and
with the ongoing opportunity of the children to know that they have
the continuing love and affection afforded by each of their
parents, Husband and Wife agree that they shall share in an equal
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fashion the legal custody of their minor children. Husband and
Wife agree that primary physical custody of their minor children
shall be in the hands of Wife, but further agree that partial
physical custody of the children shall be in the hands of Husband
for such periods of time as the parties may agree upon from time to
time. In the event of the inability of Husband and Wife to reach
agreement upon times for partial custody by Husband, the following,
minimum standards shall prevail:
A. Father shall have physical custody of the children on
alternating weekends, from 6:00 p.m, Friday evening until 8:00
a.m. Monday morning. Additionally, Father shall have physical
custody of the children every weekend from 7:30 a.m, Sunday
morning until 8:00 a.m. Monday morning,
B. The holiday custodial arrangements shall be as
follows:
(1) Father shall have physical custody of all of
the children from 12:00 noon on Christmas Eve day until
12:00 noon on Christmas Day;
(2) The parties shall alternate having all of the
children in his/her physical custody on the day of the
celebration of Labor Day, Halloween Trick or Treat Night,
Thanksgiving Day, Easter Day and Independence Day;
(3) All children shall be with their Mother on her
birthday, all shall be with their Father on his birthday,
and on a birthday of one of the minor children, that
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child shall be in the custody of Father for that day,
subject, however, to the modification that on the weekend
following, Mother shall retain custody of all of the
children, and Father's alternating weekends shall be
adjusted accordingly.
(4) The children shall be in the custody of their
mother for Mother's Day, and their Father for Father's
Day.
D. Father shall be entitled to have two full weeks of
partial custody of all of his children during each period of
summer vacation from school, such weeks to be non-consecutive,
and conditioned upon giving Mother a minimum of 3D-days
advance notification of the selection of a week.
E. In the event the children are in the custody of a
parent at any given point in time, and that parent is in need
of a babysitter for one or more of the children, that parent
shall first contact the other parent for the purpose of
ascertaining his or her availability to serve as a babysitter.
F, Both Mother and Father acknowledge that it is in the
best interests and welfare of their minor children that
reasonable opportunity continues to exist for both parents to
have regular and ongoing contact with their children, and the
children with each of their parents, Such acknowledgement of
continued opportunity of reasonable contact includes a
recognition that the relocation of either parent to a
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residence at a substantial distance from the other parent will
adversely impact upon reasonable parent/child contact.
Accordingly, both Husband and Wife agree that neither of them
shall, until such time as their youngest shall have attained
the age of eighteen (18) years, relocate his or her residence
to a location greater than fifty (50) miles distant from the
present places of residence of each parent (Husband presently
resides at 2621 Logan Street, Camp Hill, Pennsylvania; Wife
presently resides at 110 South 27th Street, Camp Hill,
Pennsylvania). In the event either parent shall relocate his
or her residence to a location within the aforementioned 50,
mile radius, prior to the attainment of the youngest child to
the age of 18 years, the relocating parent shall advise the
other parent of his or her intent to relocate as soon as
practicable prior to such relocation, and the parties shall,
in good faith, enter into discussions with each other for the
purpose of making reasonable and appropriate modifications to
the partial custody rights of father as previously set forth
in this paragraph. Neither parent shall remove the residence
of the children outside the continental United States,
14. SUPPORT OF CHILDREN. HEALTH INSURANCE. AND EDUCATIONAL
EXPENSES.
A, Child Support. Husband agrees to pay and Mother
agrees to accept the sum of $1,000 each month (payable at the
rate of $462 every two weeks) for the support of the three
minor children of the parties, such payments to commence July
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1, 1997, and continue at the same amount until June 30, 1999.
Beginning July 1, 1999, Husband agrees to pay and Wife agrees
to accept the sum of $1,200 per month ($554 every two weeks)
for the support of the three minor children, until such time
as the youngest of the children shall have become fully
emancipated. It is the intention of the parties that the
payments herein provided shall be made and accepted
voluntarily between the parties; however, nothing herein
contained shall prevent Wife from filing a Complaint for the
support of the minor children in any Pennsylvania Court of
competent jurisdiction.
B. Deferred Support Obligation. In recognition of the
obligation herein undertaken by Husband to pay certain marital
indebtedness, the parties have mutually and voluntarily agreed
to a payment of support by Husband which is somewhat less than
is contemplated by the Pennsylvania Supreme Court Support
Guidelines. It is for this reason that paragraph 11,
heretofore, makes provision for the payment by Husband to Wife
of a sum of $4,800.00 either at the time of delivery of a deed
to the marital home by Wife to Husband, or, upon the sale of
the marital horne, such sum of money being agreed by the
parties to represent the satisfaction of what the parties
acknowledged would have been the obligation of child support
of Husband in strict accordance with the Pennsylvania Supreme
Court Support Guidelines.
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C. Health ImmranceA, Husband agrees that he shall
continue to maintain hospitalization and medical insurance for
the benefit of his three minor children, shall do so whether
or not his present or future employers may pay all, some or
none of the premium cost, and Husband shall, without recourse
upon Wife, pay all necessary premiums for said insurance,
shall payor contribute any co-pay requirements, and shall pay
any required deductible payments, Furthermore, in the event
the provision of health insurance for the benefit of the
children is either no longer available to Husband or, if it is
available to Wife (for the benefit of the children, and with
the agreement of Wife), Husband shall pay to Wife the cost of
her premiums in providing such J.nsurance coverage for the
children.
D, Education E~ense. The parties stipulate and agree
that attendance at and participation in a summer camp program
is deemed by them to be an educational experience for their
children. Accordingly, both parties hereto agree that each
shall pay 50% of the cost of enrollment for the attendance of
each of their children at a summer camp each summer during
their respective periods of minority. And, notwithstanding
that the status of the law of Pennsylvania does not require a
parent to pay support or make any necessary contribution to
any of their children beyond the child's attainment to
adulthood, the parties nevertheless agree that each will
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contribute or will pay 50% of the cost of tuition for each of
their children who shall enroll and pursue, uninterrupted, a
four-year baccalaureate decree program.
15, INCOME TAX EXEMPTIONS. Husband and Wife agree that for
the calendar years 1997, 1998 and 1999, Husband shall be entitled
to claim all three of the minor children as exemptions upon any
income tax return filed by him, and Wife agrees that she shall
execute and deliver to Husband IRS form No, 8332 for each of the
years identified.
16. LIFE INSURANCE. At the present time, the parties
maintain three policies of life insurance upon the life of Husband,
issued by Equitable Life Insurance Company, in the total face
amount of $300,000, and also maintain one life insurance policy
insuring the life of Wife, issued by Equitable Life Insurance
Company, in the face amount of $100,000. As a means of providing
an economic benefit to their minor children in the event of the
death of one or the other of Husband or Wife, the parties agree
that they shall continue to maintain in full force and effect all
of the foregoing policies of life insurance, and shall do so based
upon the following standards and conditions, to wit:
A. Husband shall continue to pay all of the premiums
necessary to maintain the aforementioned life insurance
policies in full force and effect and Wife shall, upon the
execution of this Agreement, submit the appropriate
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application to the insurance company to transfer ownership of
the policy upon her life to the ownership of Husband;
B, Husband shall continue to be named the beneficiary of
Wife's insurance policy; Wife shall continue to be named the
beneficiary of Husband's insurance policy; and,
C. All of the aforementioned policies shall be
maintained in full force and effect until the youngest child
of Husband and Wife attains twenty-one (21) years, at which
time, all of the policies shall be delivered into the hands of
Husband, shall become exclusively the property of Husband and
shall be subject to any disposition as to which Husband wishes
to make with regard to any or all of such policies of
insurance,
17. IMPLEMENTATION OF AGREEMENT. The parties agree that,
upon the execution of this Agreement, each of them will sign all
documents contemplated by the terms of this Agreement and necessary
to provide for the transfer of any asset intended to be transferred
to one or the other of the parties under the terms of this
Agreement and shall cause such executed documents to be delivered
to each other upon ~he entry of a final decree in divorce,
18. 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, and the party
breaching this contract should be responsible for payment of legal
fees and costs incurred by the other in enforcing their rights
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under this Agreement, or seek such other remedies or relief as may
be available to him or her.
19. 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.
20, MODIFICATION AND WAIVER. The 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 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,
21. 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.
22. INDEPENDENT SEPARATE COVENANT. 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
covenant and agreement.
23, APPLICABLE LAW. This Agreement shall be construed under
the laws of the Commonwealth of Pennsylvania.
24. VOID CLAUSE. 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,
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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.
25. ENTRY AS PART OF THE DECREE, Wife has initiated an
action in divorce under Section 3301(c) or 3301(d) of the
Pennsylvania Domestic Relations Code, filed in Cumberland County to
Civil Action No. 97-2519. It is the intention of the parties that
the within Agreement shall survive the aforementioned action for
di vorce, and that no order, judgment or decree, temporary or
interlocutory, final or permanent, shall affect or modify the
financial terms of this Agreement, Both parties agree to execute
Affidavits of Consent for the purpose of entry of a Divorce Decree
under Section 3301(c) of the Pennsylvania Domestic Relations Code,
This Agreement shall be made part of any such judgment or decree of
final divorce, but shall not be merged therein.
26. VOLlmTARY EXECUTION. Husband and Wife acknowledges that
Carl G. Wass, Esquire, has served as legal counsel to Wife, solely,
in connection with the pending divorce action and in the
preparation of this Marriage Settlement Agreement, the negotiation
of which Agreement has been privately conducted by the parties and
to which they have privately agreed. Both parties do acknowledge,
however, that Carl G. Wass, Esquire, did explain to both of them,
separately, the rights and obligations which each of them may have
under the Domestic Relations Code of Pennsylvania, particularly,
with regard to the equitable distribution of property, the right of
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either party to receive alimony or to receive alimony pendente lite
or to receive the payment of their respective counsel fees and
Court costs, Both parties do acknowledge that Carl G. Wass,
Esquire, has served as legal counsel to Wife and that, prior to the
execution of this Agreement, a copy thereof was provided to Husband
and he was given the opportunity to, and encouraged to, discuss and
review the terms thereof with any attorney of his choosing. Both
parties do acknowledge and declare that each does understand the
full legal effect of this Agreement, especially with regard to the
fairness and equitable nature of the distribution of marital
property between them and the waiver of spousal support and/or
alimony payments provided in this Agreement. Both parties
acknowledge that their execution of this Agreement has been done
voluntarily and knowingly and that their execution is not the
result of any duress or undue influence,
IN WITNESS WHEREOF, the parties have hereunto set their hands
and seals the day and year first above written.
WITNESS:
1J/[~~~
M chael S, Anderson
(tt\'A Q, Cl\\.~ur'\)\ /
Beth A, Anderson
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AFFIDAVIT
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF .l)f) uPlf II-!
SS:
On this, the
Ie; i!:
day of 4 ""-J'l.-L-F V
the undersigned officer,
, 1997,
before me, a Notary Public,
personally
appeared MICHAEL S, ANDERSON, known to me (or satisfactorily
proven) to be the person whose name is subscribed to the within
instrument, and acknowledged that he executed the same for the
purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and official seal.
Ie" -.;:: 0
J <:"/ L., C"'Vc..,..d
I Notary Public
NOTARIAL SEAL
TILLY C. KDlUS, Nolary Public
Harrl;"U1U, Dauphin County
My Commission Expires Nov, 28, 2000
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:;~lY~~:E\Ri!?W;>'SHARRWJBUR~"PeNNSYLVANfA'-liiIO,'8g:t;;~~~~:~~tt:~~fig~~~~,;~~o~l::.lYt~,t~I~1t7~
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BETH A. ANDERSON,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
No. 97,2519
MICHAEL S. ANDERSON,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
ACCEPTANCE OF SERVICE
I do hereby accept service of and acknowledge receipt of a
certified copy of the Complaint Under Section 3301(c) or 3301(d) Of
The Domestic Relations Code, the Notice Of Availability Of
Counseling, and the Notice To Defend And Claim Rights in the above
case.
Date:'7;Ld) tl /il1
JltLY.;3;li'-----.J
: Michael S. Anderson
87503-1
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
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BEFORE ME, the undersigned authority, on this day personally appeared
Michael S. Anderson, known to me to be the person who executed the foregoing
instrument, and who acknowledged to me that he executed same for the purposes and
considerations therein expressed.
GIVEN UNDER MY HAND AND SEAL OF OFFICE this S-tb. day of
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,1998.
Notary Public in and for
Commonwealth of Pennsylvania
Typed or printed name of Notary:
NOTARIAL SEAL
TERRI L. METIL NOI.ry Public
M r:ommlsslon Ex ires Jul 28. 2001
My commission expires:
5