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I, , , , .,'1 THOMAS LEE WONDERS, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 97 - 7169 CIVIL KAREN RAE WONDERS, Defendant IN DIVORCE O~DER O~OURT AND NOW, this ~ day of ~. 1998, the economic claims raised in the proceedings having been resolved in accordance with a marital settlement agreement dated August 13, 1998, the appoint~ent of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, P.J. co: Thomas J. Williams Attorney for Plaintiff Johnna J. Deily Attorney for Defendant ~~.... /7YI-c~ 1~/.:lt1?8. ,,J "P. r{! -n.c,"j"/C(:' ("r' 'I " "q:'~n'/ ',11'1 n'- , ?d { " I , 1; '/ ,,,,, '/ '/1 . . ., I I li'n'1' "I, , .' f ,1.\/:,;' ,.1.1 'T " " ""L.w' *~ '. . o o -0 -< , '."1.15\0" TA1IU'lOaNDOC'I\".."'MIA,U.. r..m.1;OJlZ1/VIQJ.'lllJI'M lrvllllt OIlO""OUIIIJSrM MARITAL SE'I:TLF;MENT AGREEMENT This Agreement, made this 1..37hdl\Y of .A-v.,jus-t , 1998, by and between THOMAS L. WONDERS, SS8 Shippensburg Road, Newville, Cumberland County, Pennsylvania (hereinafter referred to us "Husband") and KAREN R. WONDERS, 664 North Middle Roud, Newville, Cumberland County, Pennsylvania (hereinaller referred to as "Wife"). WHEREAS, the parties hereto ure Husband and Wife, huving been married on September 17, 1988 and ure the parents of Tyler Thomas Wonders, born July 22, 1991 und Morgan Paige Wonders, born June 18,1994, und are presently living with Wife. WHEREAS, difficulties have arisen between the parties as a result of which they have separated and nOW desire to divorce and, by this Agreement, to settle all tinanciul and property rights between them; and WHEREAS, this Agreement is made in settlement ofu divorce action presently pending in the Court of the CoUrt of Common Pleas, Cumberland County, Pennsylvania, No, 97.7189 and WHEREAS, Husband and Wife respectively acknowledge that before signing this Agreement they have been fully advised by their respective counsel of their rights and obligations, have read carefully and understand the tenns of this Agreement, and have freely consented to this Agreement, believing it to be fuir, just and equitable; and WHEREAS, Husband and Wife are satisfied that they understand the value and extent of all property which would be considered "marital property" under the Pennsylvania Divorce Reform Act, whether titled or owned separately or jointly as well us the value and extent of nonmarital property held or expected to be held by each other. NOW, THEREFORE, in consideration of the mutual promises and undertakings set forth herein and intending to be legally bound hereby, the parties hereto do hereby agree us follows: I. SEP ARA TlON: Husband and Wife shall be free from constraint or control by the other as fully as if he or she were unmarried. Neither shull disturb, trouble and interfere in any . way with the other or with any person for associating with the other. 2. RELEASE: Husband relinquishes his inchoate intestate right in the estate of Wife, und Wife relinquishes her inchoate intestate right in the estate of Husband, and each of the parties hereto by these presents, for himself or herself, his or her heirs, executors, administrators or assigns, does remise, release, quit claim and forever discharge the other party hereto, his or her heirs, executors, administrators or assigns, or any of them, of any and all claims, demands, damages, actions, cuuses of action or suits utlaw or in equity, ofwhutsoever kind or nature, for or because of any matter or thing done, udmitted or suffered to be done by said other party prior to and including the date hereof; further, the parties ucknowledge thut all rights under the Pennsylvania Divorce Code that are not specifically incorporated herein are hereby expressly waived. Notwithstanding the foregoing language of this paragraph, this release shall in no way exonerate or discharge either party hereto from the obligations and promises made and imposed by reason of this Agreement and shall in no way affect any causes of action in absolute divorce which either party muy have against the other. 3, MARITAL RESIDENCE: Husband and Wife jointly own the marital residence located at 664 North Middle Road, Newville, Pennsylvania (tile "Property"). Husband shall forthwith convey whatever his title, interest and rights he may have in said property and the parties' bank accounts to Wife. Concurrently therewith, Wife shall pay to Husband the amount of $21,700.00. 4, PERSONAL PROPERTY: I "\\<~ ~ A. AUTOMQBlL.ES.;, Husband shall receive sole title of the 1990 Ford F-150 and Wife shall receive sole title to the 1996 Dodge Caravan. Wife shull be solely responsible for any debts pertuining to said vehicles and shalll-,.,.. .- indemnify, defend and hold Husband harmless from any claim with respect ~ thereto, Hus\x.v--c>l -h f'Ot &\1 tOsh. +0 ~s~ r:tt-e.s, ,t...W B. OTHER PERSONAL PROPERTY: The parties shaH keep the personal property currently in their possession, with the exception that Husband shall receive the property on the list attached hereto which is presently in the possession of Wife. In the event that Wife ~n'l . has to pay a third party to remove lMie items, then Husband shall reimburse Wife for these out-of.pocket costs, It is understood that Husband may need the assistance of friends to remove property. Notice will be provided to Husband as to whom and when the property shall be removed; provided, however. the same shall be scheduled as promptly as possible. The parties agree thutthe children will not be present at the house at this time. s, PENSIONIRETIREMENT BENEFITS: Husband and Wife shall waive any right or interest In the other's pension or retirement benefits or savings, 6. AFfER"ACQUlRED PROPERTY: Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other. all items of property, be they real, personal or mixed, tangible or intangible, which is or has been ucquired by him or her ufter the date of separution, with full power in him or her to dispose of the same as fully and effectively, in all respects and for ull purposes, as though he or she were unmarried. 7. MARITAL DEBTS: During the course of the marriuge, Husband and Wife have incurred certain bills and obligations and have amassed a variety of debts. It is hereby agreed, without the necessity of ascertaining for what purpose and to whose use euch of the bills was incurred, that Wife shall be solely responsible for any and all bills, obligations or debts incurred prior to separution a.1dshall hold Husband free und harmless from any and all liability which may arise~.-".I from same. This includes, without limitation, the private mortgage to Wife's parents. W;r.. i!;o ~ T'-'I,I \l1'W~.'~V Gf-8fty ether HR8nslal 8\JligatioH.J 0,.,,<1 to Ah'.lub",.~ vfl.tr umily. 8. POST SEP ARA l'ION DEBTS: Both parties agree that, in the future, neither shall cause or permit to be charged to or against the other any purchase or purchases which either of them may hereafter make and shall not hereafter create any engagements, cebts or obligations in the name of or against each other. Except as specifically provided, herein, each agrees to hold the other free and harmless from any and all debts and other obligations which he or she may have incurred since the date of the separution and agrees to indemnifY and defend the other party from any claim regarding same, 9, CEMETERY PLOTS: Husband shall transfer any interest he has in the cemetery plots to Wife upon issuance of a final decree of divorce. Wife shull provide Husband with the papers to sign for this purpose. 10. EXECUTION OF DOCUMENTS: The parties ugree to execute all ,,\,\r ~/ ~~ documents that are reasonably necessary to effectuate the purpose of this Agreement. In the event that either purty shall refuse or fail to execute and/or acknowledge any such docwnent, then the other party shall have, and is hereby granted, the right and power to appoint one or more times any person or persons of his or her choosing us uttorney-in-fact for the other party 10 so execute and acknowledge such documents, II. CONTRACT INTERPRETATION: For purposes of contruct interpretation and for the purpose of resolving any ambiguity herein, Husband and Wife agree that this Agreement was prepared jointly by their respective Ilttorneys. 12, ENFORCEMENT: If either party defuults in the due performance of any of the terms, conditions and covenants of this Agreement on his or her part to be perfornled, the non. defaulting party shull have the right to sue for specilic performance or damages for the breach of this Agreement, and the defllulting party shall puy the reasonable legal fees for any services rendered by pension the non-defaulting party's attorney in any action or proceeding to compel the defaulting party's due performance hereunder us well as costs for bringing the action or proceeding. 13. MISCELLANEOUS: A. This Agreement constitutes the entire agreement between the parties, being the tUial BIld complete settlement of all matters between them BIld supersedes any prior written or oral agreements between them respecting the within subject muller, There are no representations, agreements, arrangements or understandings, oral or written, between and among the parties hereto relating to the subject mailer of this Agreement which are not fully expressed herein, B. This Agreement may not be amended, modified, ultered or revoked except in writing executed by both the parties hereto. C. This Agreement may not be assigned by either party without the prior wrillen consent of the other party. D. This Agreement may be executed in multiple counterpurts, each of which shall be deemed an original for all purposes, and ull of which together shall constitute one BIld the same instrument. E. This Agreement shall be binding upon the parties hereto, tlleir heirs, executors, administrators and assigns. F, This Agreement shall be interpreted under the laws of the Commonwealth of Pennsylvania in effect us of th~ execution dute of this Agreement. '(\..-\11 >$' THOMAS LEE WONDERS, PlnintitT IN Tim COURT OF COMMON Pl.EAS OF CUMBERL.AND COUNTY, PENNSYL.V ANIA v. NO. 97. 'I) J' 'I (I,,~;( T;,.... KAREN RAE WONDERS, Dclendnnt IN DIVORCE COMPL.AINT 1. Pluintlll' is Thomas Lee Wonders, un ndult individual, with u muiling address of 558 Shippensburg Roud, Cumbcrlund County, Newville, Pennsylvuniu. 2. Defendunt is Karen Rae Wonders, an udult individual, who currently resides ut664 North Middle Roud, Cumberlund County. Ncwville, Pcnnsylvania. 3, Plaintiff and Dclendant havc been bonu tide residcnts in thc Commonwealth of Pennsylvania for atleust six months immediutely previous to the tiling of this Compluint. 4. The Pluintiff and Defendnnt were marricd on Scptembcr 17, 1988 in Newville, Cumberland County, Pennsylvanhl. 5, There huve been no prior uctions of divorcc or for unnulmcnt bctwcen the parties. 6. The marriagc is irretrievably broken. 7. Plaintiff has been udvised that counseling is avuilablc and thatPlaintill'may have the right to rcquest that the COUlt requirc tho partics to participate in counscling. 8. After ninety (90) days have clupsed from thc datc of thc tiling of this Complaint, Plaintiff intcnds to liIe an Allidavit eonscnting to u divorce. Plaintill' bclicves Dcfcndant may also lilc such un Aflidavit. 9. Pluintiff rcqucsts thc Court to cntcr a decrec of divorcc. MARTSON, DEARDORFF, WIL.LlAMS & OTTO By:1k4v) wJl~.._.-. Thomus J. Witfiams, Esquire Tcn East High Strect Curlislc, PA 17013-3093 (717) 243-3341 Attorncys for Plaintiff Date: Deccmbcr 31, 1997 , . , VERIFICATION The foregoing Divorce Complaint is based upon Information which has been gathered by my counsel in the preparation of the lawsuit. The language of the document Is thut of counsel and not my own. I have read the Divorce Complulnt and to the extent that the document is.based upon Information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the content of the document is that of counsel, I have relie4 upon counsel In making this verification. Thl~ statement and vcrlficution are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsificution to authorities, which provides that if I make knowingly false averments. I may be subject to criminal penalties. I I ! I , I \ ,I I I I g'~ d.. ~ Thomas L. Wonders 1'1 " " " " ';- r."} (: , , tr; C , .c_t.. '. , -, 1.-.; ~ .. <' Utl~'J; -" r~"" ~ r: ..1...-> (\.. - j .J.r,,: ,) rt: , . T'. '{;Jr' hIli -~~ j(U ~I- I I., L. ' ~ '.. (,I: '. , I ce ) , t!1 ~ i~ , , " 'I THOMAS [,EE WONDERS" Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA I 199 7- C:r.VIL TERM ; No, 7189 I IN DIVORCE KAREN RAE WONDERS , Defendant ~NJ;lANT' S AFFIDAVIT OF CONSENT. ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION ;~~~OUEST ENTRY OF A DIVORCE DECREE ~~ SECTION 3301(c) OF THE DIVORCE CODE 1, A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on December 31, 1997. 2. Defendant acknowledges and accepts service of the Complaint on January 10, 1998, 3. The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint, 4, I consent to the entry of a final decree of divorce without notice. 5, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if r do not claim them before a divorce 16 granted, 6. 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, 7. I have been advised of the availability of marriage counselling and understand that I may request that the court require counselling, I do not request that the court require counselling, SAlOIS, SHUFF & MASLAND AnoaNnI.tA.TIUW 16 W. III'" SU"I CoI,",I., PA I verify that the statements made in this affidavit are true and correct, I understand that false statements herein made subject to the penalties of 18 Pa, C.S, Section 4904 relating to unsworn falsific ion to authorities, DATED:~~\~11 are Defendant ~ .:J [; " ,. '~~ M .:~~ ~.'( ~]"- 0;; ~l~; :J: .....'):r( Il- l 'J .~:j .,--':.-,. '" ~-~, Fn ~';: ::,l~ n. ,N ["I'.! 0.. lIl~ . F\' ...., VI ~.~! b CO ' f_) 0- D SAlOIS. SHUFF & MASLAND Anou.YltATtlAW 16 W, HIp SI'"I CoI,U,'., PA THOMAS LEE WONDERS, Pet! t ioner IN THb. COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO, 97 7189 KAREN RAE WONDERS, Respondent IN DtVORCE ANSWER TO PETITION FOR CONTEMPT AND 'ra ENFORCE MAR [TAL SETTL"~MP.NT AGRP.EMENT AND NOW, comes the Respondent, Karen Rae Wonders, throu.gh her attorneys, Saidis, Shuff' Masland, and files the following Answer: 1. Admitted. 2. Admitted, 3. Admitted. 4. Admitted. r. Admitted. ::>. 6. Admitted, 7. Admitted. 8. Admitted. , 9. Admi tted in part and denied in part. It is admitted that a copy of an executed Deed was provided to the attorney for the Respondent, but it is specifically denied that Respondent has repeatedly told Petitloner that she has obtained the money. 10, Admitted in part and denied in part. It is admitted that Respondent received the ma.j0rlty of the money from the marital savings account, but some of the money was used for the parties' debt as well as fora trip for the children. 11. Admitted. THOMAS LEE WONDERS~ Plaintiff I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. I I 199 7- , CIVIL TERM I . No. 7189 , I IN DIVORCE KAREN RAE WONDERS , Defendant DEFENDANT'S AfflDAVIT OF CQNSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REOUEST E~'RY OF A DIVORCE DEGREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1, A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on December 31, 1997, 2. Defendant acknowledges and accepts service of the Complaint on January 10, 1998, 3, The marriage of Plaintiff and Defendant is irretrievably broken and ninety day a have elapsed from the date of the filing of the Complaint. , 4. I consent to the entry of a final decree of divorce without notice, 5, 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, 6. 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 a,fter it is filed with the Prothonotary. 7. I have been advised of the availability of marriage counselling and understand that I may request that the court require counselling. I do not request that the court require counsel.ling, SAIDIS, SHUFF & MASLAND A~A1.u.\l 16 W, Hip SIrttt c:.,II,I.. PA I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made subject to the penalties of 18 Pa. C,S. Section 4904 relating to unsworn falSifiC);iCn to authorities. DATEDI-5l~""')\a,'i1:i ~~.......... ~ -WCTV'\A~ ...n \ en R, Wonders, Defendant " ~~ ~ ~:J :n "11 -" "oJ '" "tl~ ;' ;~~:' 1~'1 o "\1 ,,'J ij}] "rrJ "~-'r c'u ...,:t~; ""n; :"~ ~l ~ ~.; ,-" " , .. ~t;'~ =:-? "" '-.I -, are CA1'N(lFfllllll IlIi III ,~..' PliCa _ flu"" AIlPNW4 OM!) HI). 1Jql.QW A, u,a, DEPARTMENT OF HOI' '(l AND UAllAN DEV~LOPMENT ill,(:',!"i"!~",' "" ''J'YI'lllll'l.OAN ' I, _I 2_I'MIIA ) ...JLCClNV, IININS, , , 4, VA 5, CON V, INS, ,"" ".... Saldls, Guido, Shuff & Masland 4, m. NWlQbar 11 l..u... NWMl>fr WONDERS t. MUll,.,. II... C.ac Nu. SffiLEMENT STATEMENT C. NOTEI '1111, f""" I, /Im';Jllt,/1IJ Ki~' YOIl U slattt/":'" uf urllilll mllt"'c", rum. AmOllll1t puid IIIl./tld by ,Il, ulI/(mtm 111.""11I "If UWWI... ,,,''" tnmlud .Wo.C.)" WI" paid (JuuIJ~ III. dl)I/lIt Ihq aft ,huwu hI" Il1r I'lf~""al"mul PU,ptJlt, Wid ,,,, fWI ,,,dulled III ,hI ,u,a/J. 1:), NAME AND ADDRUSS OF BORROWER; Karen R. Wonders, 31098 E, NAME, ADDRESS AND TIN OF SEllER: Reflnalloo F, NAME AND ADDRESS OF If.NDER: The Fanners National !lank of Newville, PA P.O. !lox 156 Newville, PA 17241 G, PROPERTY LOCATION; 664 N, Middle Road Newville Pennsylvania 17241 o Propor1y or SfIIVIcet Aocolvod , H, SETTLEMENT AGENT; Saidis, Shuff & Mas I and TIN 1251694606 PLACE OF SETTLEMENT: 26 West Hi9h Street Carlisle, PA 17013 I. SETTlEMENT DATE: 12-11 ~9!l DIt;\;urB<lllmt 1}\tOl 12-16-98 J, SUMMAR Y Of nORRoWlli\'s 11lANSACTIUN K. SUMMARY OF Sm,I.11WS 'I'IIANSAC:I'lON J{){), ,GROSS AMOIIN'/' llllF. fROM 1IOIU/OIVf.'Ili 4{){), GROSS AMOllNT Dllh' TO ,\'f:/,LliR,' 101. COlllnu:1 aul.:' Ilrh:u 401. CUlllrucl lulclJ p.h:.: 102, P.I1O"al Pro/lCr1/ .11)2. I'cnmnal nrol~rly 103. Seulclllc:nl charlet 10 borrowcf(II11cl' J.lOO) 77,629,00 40], 11).1, 404. lOS, lOT (~J . ;!tl.4;!\/,1l1l 40S. Adjusun,,,u flJr Itfms j'tJld by sfUr, ill lIt1vjJ,jee Adjumn,nu fur IImJJ paM by ~'rlJtr I,. lIdVa1lCf 106, CIIY~llWn I."" '" 406. ('Ily/lOWI) IWlCI '0 107. COllnl)' 111)'.1:. 10 407. CmUlly 1II.IIel III - 108, A.ueunU:1II1 '0 ~C"IIl(III' III - 109. ., Hat') I\:\nk $17 011 ~~ 409. 110. Fanrers Ndt t IVInk S 6. NR44 ,110, Ill. 411. - 112. 412, 113. ,11:1, 114. ,114. liS. ,lIS. 116, 416, 120. GROSS ,IMOIINT f)l!f: nlDM /IOIIIIOIYWI 5I,05!l.88 420, WIOSS AMOIIN'/' /Jill! H) Sh'/././m 2{){)' "'MOIINTS P"'IO OYI01I/N DF.I/AU Of OORI/OWlil~ 300. Rh'/)II{,'I'/ONS IN ,IMOIINT /J/lli TO SE'I././!II: 201. Depal!1 or &:Bnuull mnnl.'Y 37 Ooo.1m1 SOL liJu:cliI 11":,>\>>Iil(n'C' ilUmlCliOlu) 202. PrinJp;;, amounl of new Illon(,) .502, Sellh:nll:ul t:hurl~1 10 1I.:III:r(ll11l /.100) 203. Ell"lln, 10an(l) laken aubjecl 10 .50). Exhtllllll: lu.m(l) III ken ~ubjecl 10 204, S04, IJuyurr 01 finl morlgllgc loan . S05. IJuynff 01 IccomJ morllsle loan 20S, 206, SO<>. 201, SOl, 208. , SOlI. 209, 50'), AdjuJtmtnlJ for "tl1U Impaid by Itlitr A,ljuslmtms fur ',rnu ullpald by stittr 210. CIIY~llWn ,.... 10 S10, CItY/lnwn laxea '0 211. Co.nlV ,,"'.. '0 SII, County IWlCI III 212. Asscumenl, '0 S12. IUsCl:lilllc:nlft 10 . 213, SIl, 214. S14. ,- 21S, SIS, 216, SI6, - 217, S11. 218, SIR, 219. 519. -. -- 1'01,11. P,II/J /IY/f1JJ! 'mT,jI. lIIall/Cf(ON AMOUN.,. 220, OOIlIIOlV/:'1I 37 ,000,00 SIO, /11m ,Yh'/.U'II 3/J(/. CASIl "'T S/irrUMENT /lROMrm BORlIOIVI;;fI /lOll CASlJ AT ,YF.I'I17Mf.iiiT /'O;FROM SEI./,F.II --- 301. OrOl&j amouRI Lluc lrom borrowc:r!!ulI 110) !II ,U5tl.1l1l1 601. (Jcoas amounlllue lu .clhullillt 410) 37.000.00 - 302. Lcu amounll paill by/rl1r borrowc:rtUllt 210) 602, I.ell redU(;liolll 111 alllounl due: lelh:rtli", 510) 30J. CASIl ( X FROMI/ TOlllO/lROWF.R 14,058.88 60,1, (,'MIl ( ml; fROMI Sh'/./.f:R AX'" YfR IOI\N'nfllcATION NlJMBBRSOllcrrMl0N: SrI.lliA y~ It. "'tuir,d IIr lirw III pI'U'IIliI Sakll., OUIdIl, Shuff ok Mul~nd wilh vour cnfmll~lI'~ycr klcnHIk~tlnn number. If you !lt11V,)! ,Milk SMjliil, (JullL.J, Shuff 0\ twbJland ....lh ftlUl' ~llfU,.t IUflll!"' ....nIWlo:.tk!i1 nlllltkr,)'OU IIUY 1M 'lIbi-~ tlJdYiI OC' ClImIIlJI"cnMltic:llmpoHII b11~1It I~dllr'. n~IU'I'), 4l1d,... and lilI klcnulkllllnfl numlNl(l) III ~n lfl lien! I!. .1tIWI cnlilhnuld b. ch..hli 'l( KcumYI UDlI., ,.n.ItU. at ,.rjl,lty.1 r.\4IrtltJ IhI! Ih. IIUIIlbe, Iba.m un tb!.Jlllcllllnllt my C<lrrc~II.",~yu hknlU\~11on numbl:r. ThtlnfonaallOtlcooulnfdInBklcUE:,O,II,~UldIln'4lI1111mpu1'1Inllulnf;;ullonlndl.kkl.rw-I~~1I11J11w Inlft'nalll.nfll.t'~)'IIU""~~'nfall.'fl(.pcnlll'YIM'OIh" IliInCllon wllI" IIopoltd onJ~ If lhII lI.m II r.qulrd III III rcponcll.nlllhcIIlSIIIIClrlll!lulh.1 ~ h.. filii bUll rt~IfI'1I. ........, .' S^l~MMjS$jONi ,. BASEl) ON l'IIICIl ~ IlMIlon 01 Comml..lolI (1111. 700) .. lulluws: . . IQ I 10 701 CommiululI 114hJ al Selllcllu:n1 PDt.! SIl'nt.IlMI!NT CIIAIIOIlS 1I1111 :"', 'It'i,',ii" I':", I , !ll-:" ",' , l'AIll FIIOM 1I01111OW/HI'S FIINllS AT SIiTI'I.IIMI!NT !'All) l'll0M SI!I.I.1!1l'S FUNllS AT SIi'I'IUlMIlNT @ '}lo. ... ~~:nl':.~AIlI.R IN ;ONNECfl~~:nl: ~o:~~ '~~t:t~~~'I\ B~nk. 0 f I ~~e~ ~.~ e ' , lAM DiIcoulll % r:;;;;;nlul F.. 10 Qodll /l.oon III Ladtr'I Inll~cllulI Fcc In .. lI.l11l1UI'l' Inlurallce Au llkallllll Fcc hl iJ/J1. ,.\uumllllon Fcc 10 .;.),j, Annlicatlon fee to The farmers National Bank ot Newville, PA Ilf/'), 810, .11 , 370.00 100,00 :ill, 41J bH, '!OI, 902, 9OJ, <JO.I. '!Ol. PlIO. /Tb'MS REI1UlRb'/J IIY UN/lb'l/ 1'0 /If: l'AIll IN AnV,iNCE Inlerc.1 (rolll 10 fly S /lJlIY ( Morlunll.C: IllIuraflCC Iln:mlulIJ rur mUllth, In IIIIZDrd Inlurum:c l'rcllIlum lor 1 )'ellr lu ,~ ~ (~D 1000. R1iSb'RVl!S IJEI'OSrrE/l WITII LENnF.l/ lOOI. Hillard Inlurlnce mUlllh, @ $ H)()2. Mortlfllle 'llIunmcc lIhlnlhl @ $ 100J, Cl,y """"'''Y I.... IIIUII'''. ~y I 100,1. COUIIIV nrol)crlv I/tJIL'I w mUlllh. @ $ 100l Annual UliStUnlt:1I11 mumh:. i!l) $ 1006. mOlllh, @ $ 1001. mOlllh. @ S 1008. monlhl fi.Y $ )/00. TrrtE CIIARG/iS 1101. St:Ulcmcnl or dOllnlC Ice 10 ll02. Abalrael or lhle I~urch Il) 1103. Tille CX4mlnallon 10 1104. Tille insurance binder II) IIOS. l)ncumcnl nrcn.uallun 10 1106, NalalV Ie. la ' 1107, ^"amev'. Ice III {includu alww I,,,,u Iwmbtrs,' 1100. Tille Inllur..ncc 10 --'htclLuleJ lJhu~ IltmS ",,,nbe,s,' 1109, tender. (OVerlie ~!.HO. Owner'. coverlle 1111. 1m, 1113. pcr I1IUlllh pi;r mURll!. per lIIulllh per 1II11111h per lIHlIIlh lK:r lIIunlh per IlIORlh per IIIURlh Saidis. Shuff 8 Masland Sajdls.~hl!1! & Masland Saldls hUl'r-& Masland 50.00 6,00 325,00 -. I I 1200, GOVl!RNMb'NT R1iCOR/lINO ANI> TRANSfF.R CI/,iRO/iS 1201. Il.ellrdlll. rm: De.d illY!. Cllv/M.IIIY ,Wl/.lumlll: 120J. SIIie '"""I.mll5 1204. 120l. I 25.50 De.d $ Deed $ : MtJrlglllc $ 27,50 ,lIele...e I : MOlrl.".e $ : Mm IJUIII:C S 53.00 IJOI. IllY!. IJOJ. 1]04, IJOl, 1106. DOl, IlOS, ~13()(J. A/JDnION,i/. SE'lT/./iMb'NT ClMl/m:S o Lien Search to Saldls~huff & Masland A rborne pa~off to Saldls, ~huff & Masland Settlement avment to Thomas l. Wonders 10.00 15.00 21,700.00 /400. '1'01111. s~:rf/.MI~:NT ('/I.iR(/f.'.\' (tI"" "" /III" 10/. Swim, J "'I<I $01, Sm,,," K) 22 629,00 I._ c.,~ rnoln" u..IlUI).I SeIl....nI SlII'meN IlkI, 'lllh, Mil of m1'nuwlIJ...,.., btllef. I' I. 111\11'11101 ~un" ""flUe'" IlllU r.uipllln4 dI.tIlWHnlCUlIlDllM on 1D11<<tlU111 Of ~ lilt In LhI1 U'1ONI;1kln. I tuUM' UIlIIr lAlll hIw. ulul"," I \iI.~ ullllll> a !lcUIt:Mcnl Sial,menl )wJJRI~ '~.--..--. !PI1Fn ----...--------.'-- .-----~-, sftm.n ------ ~~':..rn~----. nnVI'j(j--- --- --, --.., '. ---,- llUYI!Il,---------'--..- ~~":~M~.~;~~~~17~:;2h.":.'~.J ':_' .... .,J .~"'.~..::'~' ~:,'~"~:.h~. ~",':"'''~ ~ h~~::::::::" Ih. ""'.OM: ,., W^aNiHo;"ivU"" ~-~~~::f ,,,.,IIII,...fIt Ii...... ","I," !it",,, U11lhilUf .11'1' "Ih.r ~nul., ">1111 I'Ill,hi,. ul"m ~IIMilion '11I1 in~I"1M I elIl.. In.lllIIp'll/lIl1n'rlf. .ut....~ I.ut"r_-~ IQQl..wSt-llkIfIIOIQ. -. " L , ", " I:, , , , , " , , :1 'j, :, " " , , , ., , , 'I , ", ., ' ',I. 'Ii " I ,,' . , , "I '.;-1 " " nLEI'l{)FFIC~' or- 11 ;;: n:Ofl'1I1NOrAF\Y - -.' I' 1)0 ,)lJN ~ 0 Mi IrJt :ll. CUM:J!,:I iIJ.NiJ COUNTY pgNN5YU/A"l'A ,I I; " , , I ~' .:t i";; - Ji .. t<: .:t ~;! x: u.. '-...-: (,)tJ f1' In ~.- ~ " . , ~ ' III ~ L: 1-'- 1.;' m " '.' " 1':'.III!!i"MI'AIII.Ii'lll'N/}(I("'1N "I~l).I'I-II...'w l'lnIN: IM'I0'I11111 .H AM Itr)iIN: II~iJIII'IN llJ;lfj,.\IlAM v, IN TilE ('OURT OF COMMON PLEAS OF l'UMIIElU.AND COUNTY, PENNSYLVANIA NO,IJ7-7111~ THOMAS LEE WONDERS, 1'llIllItiff KAREN RAE WONDElt~'" I>efelldllut IN CUSTODY I'LAINTlll~:.l.U.:LAIM (lOIt EQUITABLE DISTRIBUTION m:.Mi\lUTAI, 1'lUWlo:ltTY AND NOW, Cl)JlleK 1'11I11Itll'l; TholllllS Lce Wonders, by und through his uttorneys, MARTSON, DI~Alm()ltFF, WILLIAMS & uno, IIl1d mllkes his c1uim for equituble distribution liS filllows: I, I'lullltlt1'lIlUll lcfelUlulltun: the .Ioh\lowllers us tCllunts by the entireties of certain reu! estule which is Kul~lcctto c1luitllhle distrihutioll hy this Ceurt. . 2, I'luilltlll'ulUlllefl!lUlullture the oWllers ofvurious items of per so nul property, furniturc und household t\lrnishilll!K IIcl;ulr...d durill!! their Illurriuge which IIrc subject to equitable distribution by this Court. ), I'lullltll1' ulllll lclclldlluture the oWllers of various motor vehiclcs and bank uccounts uequired durin!! their IllllrriUl!e which ure subjeclto cquituble distribution by this Court. WIIERHOIW, I'lullltill', lholllus Lce Wondcrs, respcctfully requests this Honoruble Court 10 ellter hiK c1ullll filr ...qultuhle distrlhutiollofthe maritul propllrty. Respectfully submitted, MARTSON, DEARDORFF, WILLIAMS & OTTO By _'1 k,.,~L_ tV.dt............ Thomus J~ms, Esquire Tcn East High Street Curlislc, PA 17013-3093 (717) 243-3341 Dute 1'1", l.f', /9 f 9 Attorncys for Plaintiff , ! ;'L " ' "" ,I ~- r:J\ ',. , , II,'.: I, ~ I::': \ II ~'.'" '" '. I J"'" - .. (.,. J..", L. ,'.)!. 2' ,')1 t,{) Li.\1 I ," " I [;-1 ( " , , " " " " " I.., ...~, , l.l. (~"i .l CJ (,J\ ( ) " I, , ' " '. 1,,1,1 (.r: 'j-I' ,II ,r;~(',--:r-!r": , _.' \ ,_,L '.. (,-,", 1::".'( c ~~ I '," ~1 "", - ,'} .A..l';\l): ',:i cu:...\, 1',-:: ,,'{ 1'1' .1'... I i' I 'r.ILI:IWArA~lllfm!NI)(K'VI4\lJI41~ l'lllml. l'tn1c.li!1llI,lIV111,ll,nAM ."iK\l; I)li2){l...~442.U1 rM THOMAS LEE WONDERS, Pluintiff IN TilE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYl.V ANIA v, NO. 97-'11!l9- CIVIL KAREN RAE WONDERS, Defendunt IN DIVORCE PLAINTIFF'S PETITION FOR SPECIAL RELmF AND NOW, eomes Plaintiff, Thomus Lee Wonders, by and through his attorneys, MARTSON, DEARDORFF, WILLIAMS & OTfO, and petitions the Court for special relief pursuant to Pu. R.C.P, ~1920.43 und 23 Pu. C,S. ~3505, and, in support thereof, avers as follows: '1. Plaintiff and Defendant were murried on September 17, 1988, and separated on Decembcr 13, 1997. 2. Prior to the separation, Plaintiff and Defendant lived with their two children at 664 North Middle Road, Newville, Upper Miffiin Township, Cumberland County, Pennsylvania, property jointly owned by Plaintiff and Defendant. 3. Plaintlffleft the maritul residence at the request of Defendunt and went to live with a friend in u room ut his friend's house at 134 Springfield Road, Newville, North Newton Township, Cumberland County, Pennsylvania. 4. Plaintift'left behind in the marital residence numerous items of marital and personal property. 5. Afier the sepuration, Defendant had the locks changed and has not provided Plaintiff with u key. 6. In order to uvoid a confrontation, and to rcspectthe Defendant's privacy, Plaintiff hus not returned to the marital residence except to pick up and drop olTthe children, and hus de facto ceded exclusive possession of the martiul residence to Defendant. 7. Plaintiff has repeatedly requested that Defendant ullow him to recover items of personal property for which she has absolutely no use, including such things as valuable lumber and marble. 8. PluintiCl's counsel wrote to defense counsel requesting these things by letter dated January 30, 1998, u copy of which is attuched hereto und murked as Exhibit "A," and by letter duted February 17, 1997, a copy of which is uttuched hereto und markcd as Exhibit "B." 9, On Infonnatlon rcceived, I'laintill' bclieves, and thercforc avcrs, that Defendunt has intentionally dcstroyed some or all of his personul property, including burning his valuable lumber in the backyard of thc muritul residencc. 10. I'laintilrhimselfhas observcd the following outside thc house: a. A pile of ashes in the backyard which Is believed to be the remains of a truckloud of oak and u truckloud of pine which Plaintiff had kept in the garuge; b. The burnt springs of what is belicved to be the rcmuins ofl'laintlfrs rccliner; c. Broken pieces of a ceramic owl (hand made by Plaintiff and last seen on u shelf in the living room). II. Plaintiff has been unablc to observc inside the house since Defendant has taped newspapers over the windows. 12. Additionally, Defendant has withdrawn all funds from jointly titled marital accounts in an amount to be in exccss of $18,500.00, without notice to, or consent of, Plaintiff. 13, Plaintiff is concerned that Defendant may dissipate or convcrt valuable marital assets, making same unavailable for equitable distribution. WHEREFORE, Plaintiffpruys Your Honorable Court to Order thc following: 1. Defendant shall account for all funds takcn from joint accounts since the date of separation; 2. Defendant shall account for all marital property and personal property of Plaintiff that has bccn removed from the marital residenr.e or de3troycd since the datc of scpuration; 3. Defendant shall refrain from moving, or disposing of, any marital property or pcrsonul propcrty of thc Plaintiff; and . . 4. Such other and t\1rtherorelief ns the Court shall deem just and equitable under the circumstances. Respectfully submitted, MARTSON, DEARDORFF, WILLIAMS & OlTO By'1~),WP4' _ Thomas 1. w(lIiams, Esquire Ten East High Street Carlisle, PA 17013-3093 (717) 243-3341 Attorneys for Plaintiff Date: February 23, 1998 " THOMAS LEE WONDERS, Plaintlf f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V, KAREN RAE WONDERS, nef~l1d(]nt NO. 97-7189 CIVIL TERM ORJ.I.ER, OF. COURT AND NOW, this 20th cJay of March, 1998, this matter haVing been colled on a petition by plaintiff, Thomas Lee Wonders, for special relief, and upon agreement of the parties, IT I S ORDERED: 1. Defendant, Koren Rae Wonders, sholl provide 0 written accounting to defendant through his counsel not later than 14 days from this date setting forth all personal property removed from the marital residence at or about the time of the separation on December 13, 1997, 2, This accounting sholl set forth any such personal property that hos been destroyed or dissipated by defendant, 3, Any such personal property not destroyed or dissipated sholl be returned to the marital residence by defendant not later than 14 days from this date, 4, Defendant shall account in writing within 14 days of this dote for all Joint funds in saVings or checking account token by her at or near the parties' separation, All such funds sholl be held in trust by defendant for both parties and sholl not be dissipated pending further order of court, This fund sholl not include on amount UP to $1,000,00 which the parties aCknowledge will be used by defendant for 0 trip to Disney World with the parties' two children which is to commence tomorrow, ....." " ..,. , ~y the ~~rt. 't / ;' ,; Thomas J, Wlll1oms, !.II, For Pla1nti ff Johnna J. Deily, Esquire For Defendant Esquire ..a.,( 3/>>)98, - C-l>(f' .~ ~ . ,.J ,f. :prs , , I ,) , I , , , "I I . '", , i , I Interrogatory No, 10 Identify any pensl~n or profit-sharing plans,in which yoU have an int~rest,' and If the PI'an(s) , is (are) available allach a copy of the sBD:1e. ANSWER; Copy attached " " " " , ' Interrogatory No.11 At any time from January I, 1998 to the present, have you either (a) had access to a safe deposit box, or (b) had any money or property that belonged to you in a safe deposit box" __If yes, then please state further with respect to each such box: (a) The name and address of each financial institution providing the box; (b) The name and address of each pel1lon who is, or was, authorized to have access 10 the box; (c) The date of each access from January I, 1993 to the present, together with the identity of the person or pcrsons having access; and (d) A complete inventory and description of everything kept in the box from January I, 1993 to the present, together with the date that each item was placed in the box and the date removed. ANSWER: (a) The Farmers National Bank of Newville opened 11/12/87. (b) Thomas Wonders, Karen Wonders and Mervin J. MOrrison. (c) Not available. (d) Cemetery lot deed, marriage certificate, baptism certificate for Karen, birth Gertificate for Morgan and Tyler, Social Security numbers, wills and Karen's birth certificate. , COins: Morgan $23.00 assorted coins. Tyler $22.00 assorted coins, 25 silver dollas, 5 Susan B. Anthony silver dollars, 20 pieces assorted coins, 50 half dollars, 1 one dollar Canadian dollar, 4 two dollar bills. Original box closed 2/13/98. Returned to Tom: birth certificate, baptism certificate birth registration notice, health and immunization record and selective sevice record. ._'''. II " , ,:>, ' 0:) ',- ,I tr.; r,; ;:.~ I'., .. . ; ~ .-;'1 \J1~~") - . J~., ~':: '>)~;i' t., ." .../ 11: " Ll.., ')~;:! @::,: _0' j' (J ~ ,C'f'" .10::'; :r 0, ::1rt:!, ~ ~'I' t..l -, I 11..\ '..lp.. , . F.. c;:J ", '~ o:l 'J 0- f.) ,/ ," " .1 ,I, Ii " i' II, " ! ,I " :1 .l' , , " " , , I . " , " , , , " ','II ., " \ ~' fy. , r.:: () lJ,p'.: <.;..< ft-".; '~~)\" (. - ~ i.', ,.,\.i.J ". I r.:' \." ~) 'il ;] , ' r" - l~1 ..... .coo. I):' , ' , .. C':: " i'),.' J:) ,,(,,' ..ct", \ .<.'\ ..... rn L) ,.if',:'1 ~ '.) '1_ ~;.;) CJ ...,:. ~-~ .-~ 0-. en II '. " )1 ,I " , 'I " ;d I. 1<. "'" l'tf;' _"I !""" 'C) 11\" ., i,i't'/ 1\"1" ,"')1,'-" l);~ \1.1(" tZ' , r. " 'l.!~ ,rj..i l:) 9 ., ..t.t. '., t,," \",., t:~ i :,.... '.)':,;,: I ~"I I'T;'~j , , ,,~ 1:11 '.. I_,t "";,I. ! ~"(n p,IO_ :.-~,] () ;01 iI' d' (~: ".' it L:i llJ '11.,:\' r.r.' , ~- , , , " ,~ " , '~~' ~~, ffi ffi 'J' ., ~ '~ l.m ~[. 13: ~ "~ ,.: ~' ~ '1:1 ~. I~' ~, ~, ' ~ ~ , ,~ , ;~ I " . .," 1,,1' f'. '" .. ,;\, " If( f) I,;' " .j iii 8~< ~il 00 ~i~ " ! , . " " f .~ , ~., -t. ",,' ~ ,~., ,. ,1 ,~., f " ,; )',t I! fO'!, ~, ' ~'w> ,; ~..~. I..il~ ~ " " l~, i,' I ~~ II , , . '.., DEe .11~ , . . " '. . , , THOMAS LEE WONDERS, P~tltioner IN TUE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, NO, 97-7189 KAREN RAE WONDERS, Respondent IN DIVORCE R1JLF. TO SHOW CAllSE AND NOW,this lsd:y ofDecember, 1998, upon consideralion of the foregoing Petition, a Rule is hereby issued upon Respondent to show cause, if any there be, why the relief prayed for should not be granted, Rule returnable lfdays al1er service, Vl..Q... ~fc?-~ \M.t ~ ZIM?~ .~~, ~~~\.& S'lMAiS2 ./ i \ \ III1ILIlIN)"TAFI1Ii\t1Lit'lI)tX"JII'I140.l'Iil' (/lol. CflllttdIllSI~1l)14J41^M Itnlu" IliOl~1 01 '4'1 AM 91401 ' THOMAS LEE WONDERS, Petitioncr IN THE COURT or COMMON PLEAS or CUMBERLAND COUNTY, PENNSYLVANIA v, NO, <)7-7189 KAREN RAE WONDERS, Respondent IN DIVORCE PF.T1TION FOR CQ.l'ITEMfI..Al'olD_ TO ENFOI~CF. MAIUTAL..sETILEMENI..AGRf,EMEN1: AND NOW, Petitioncr, Thomas Lec Wonders, by and through his llllomeys, MARTSON DEARDORFF WILLIAMS & OTTO, pu[sulInt to 23 Pa,C,S,A,*3105(1I) and *3502 (e), brings this Petition for Contcmpt and to Enforce Maritlll Sclllement Agreement (hereafter refcrred to as "MSA") and, in support thercof, avers as follows: l. Petitioner is Thomas Lec Wonders, who is the Plaintiff in this divorce action, 2, Respondent is Karen Rae Wondcrs, who is the Dcfcndllnt in this action, 3, On August 13, 1998, Petitioner lInd Respondent entercd into 1I comprchensive MSA which, ill/er alia, dctennined thc cquitablc distribution of marital property. A true lInd correct copy of the MSA is marked as Exhibit "A," allachcd hereto and mllde pllrt hcrcof, 4, Pamgraph 3 of the MSA providcs as follows with rcgard to the marital residence: "Husband slmll forthwith convey whatever his title, intcrest and rights he may have in said property and the parties' bank accounts to Wifc, ConculTently thcrewith, Wife shall pay to Husband the amount of$21, 700,00." 5, Paragraph 4(b) of thc MSA providcs as follows with rcgard to personal property: "The parties shall keep the personal propcrty currently in their possession, with the exccption that Husband shall receive the property on the list lI11achcd hcrcto which is prcscntly in the possession of Wife, In the event that Wife has to pay 1I third pllrty to rcmovc thcsc items, then Husband shall reimburse Wife for these out-of-pocket costs, It is undcrstood that Husband may nccd the assistance of friends 10 remove propcrty, Notice will bc providcd to Husband liS to whom and when the property shall be relllovcd; provided, howcvcr, the slime shall be schcdulcd as promptly as possible. The partics agice that the children willllOt be prescnt 1I1the house at this lime," 6, Paragraph 9 of thc MSA providcs as follows: "Uusband shalltransfcr any intcrcst hc has in the ccmctery plots to Wifc upon issuancc of a linal dccree of divorce, Wife shall providc Uusband with the papers to sign for this purposc," 7, Paragrnph 10 of the: MSA provides as follows with rcgard to the cxecution of documcnts: "The parties agree to cxecute all documents that are reasonably nccessary to effectuatc the purpose of this Agreement. In the event that cithcr party shall refusc or fail to exccute and/or acknowledge any sllch document, thcn thc olhcr party shall have, and is hcrcby grantcd, the right and power to appoint one or morc times any person or persons of his or hcr choosing as attorney-in-fact for the ather party to so cxecllte and acknowlcdge such documcnts," 8, Paragraph 12 of the MSA provides as follows with regard to rcmcdics on default: "If either party defaults in the duc pcrformancc of any of the tcrnlS, conditions and covcnants of this Agrecment on his or her part to bc perfornlcd, the non-dcfaulting party shall have thc right to sue for spccilic pcrfornlUnce or damages for the brcach of this Agrccmcnt, and the defaulting puny shall pay the reasonable Icgal fees for any scrviccs rcndcrcd by pcnsion thc non-defaulting party's attorncy in any action or procecding to compcl the defaulting party's due pcrfornlUnce hereunder a~ well as costs for bringing the action or procceding," 9, Pctitiollcl' has exccuted the dced to the marital residencc as required and provided a copy to Respondent's counsel at her rcqucst so that Respondcnt could obtain relinancing of the mortgagc. Respondcnt has rcpeatcdly told Pctitioncr that shc has obtained thc moncy in compliance with Paragraph 3 of the MSA, but Respondcnt was not happy about how she was rcceiving hcr support paymcnts and so shc refuscd to providc the moncy, 10, Respondent has rcceivcd all funds from the martial savings account. II, Pciitioncr has rcpcatcdly rcquested Rcspondcnt, through hcr attorncy, to honor hcr requirements as per thc said Agreemcnt, but, as of thc liIing of this Pctition, Rcspondent has not done so, nor has she providcd Pctitioncr with ;my indication ofwhcn shc might do so. Specilieally, Pctitioncr, through counsel, has: a, Callcd Respondcnt's counscl scvcral timcs, Icaving voicc mail mcssages, most rcccntly Octobcr 30, 1998; and b, Wrolc to Respondcnt's counsel Qn Scptcmbcr 1, 1998 and Novcmber 12, 1998, copics of which arc alluchcd hcrcto and murked as Exhibit "8," 12, Contrary to thc lcnns of the MSA, Rcspondcnl has fniled, rcfuscd and continues to fail and refuse to: a, Pay Petitioner lhc $21,700,00 pursuant to Paragraph 3 ofthc MSA; b, Provioc Petitioncr with a timc and dale to rctricvc his personal property or provide Petitioner with his pcrsonal property still locatcd at thc marital rcsidcncc; and c, Filc hcr conscntlo divorcc pursuanllo Parugruph 10 ofthc MSA, \3, Contrary 10 Parugraph 3 ofthc MSA, Rcspondcnt has had lhe dceds to the ccmctcry lots transferred to her name from Pctitioner's name on Scptcmbcr 18, 1998, without exccuting the nccessary divorce paperwork as agreed upon, and without Petitioncr's knowledge or consent. 14, Respondcnt is in contcmpt of Court for fuiling to comply with the tcnns ofParagrllph 3 of the MSA which mllY bc cnforced liS an Ordcr ofthc Court undcr Section 3105(a) ofthc Divorce Code, 23 PlI, C.S,A, S 3105(a), 15, Respondent has lhe ability to comply with the relevllIlt pr9visions of the MSA, 16, Respondent should be rcsponsible for Pctitioncr's counsel fccs and costs in conncction with the instllnt Petition, 17. This Court hlls the authority pursuuntlo Scctions 3105(a) and 3502(e) of the Divorce Code of 19S0, as amended, to enter an Order dirccting Respondcnt to: a, Pay Pctilioncr lhc $21,700,00 pursuanlto Paragraph 3 of the MSA; b, Providc Petitioncr with u.time and date to retrieve his personal property or providc Petitioner with his personal propcrty still located at the marital residcnce; c, Filc her conscnt to divorcc pursuanlto Paragraph 10 of the MSA; d, Pay Pctitioner's cost, including attorncy's fees, ofhuving to cnforce the MSA; c, Transfcr title to the cemetery lots buck to Pctilioncr. IS, Pursuant to 12 of the MSA, Rcspondent is obligatcd to pay Petitio:ler's costs, including attorncy's fees, of having to cnforce the MSA, !I IxtIIblt A , ',f/LEIN>A1Aflllf\OI!NIHX'n'.9140-MSA 1/\4_ ('tft(d:o"l1/nnl:SI'IIlPM Mnl~: Q'/IU~Il)4 5'11:35 rM "\ l.. w' ~~ l\1A~.TAL SETTl,EMENT AGRf;EMENT This Agrccmcnt, madc this /,-:{llJday of .Avjusf , 1998, by and between THOMAS L. WONDERS, 558 Shippensburg Road, Newville, Cumberland County, Pennsylvania (hereinafter referred to as "Husband") and KAREN R. WONDERS, 664 North Middle Road, Ncwville, Cumberland County, Pennsylvania (hereinaftcr refcrrcd to as "Wife"), WHEREAS, the parties hereto arc Husband and Wife, having been married on September 17, 1988 and are the parents of Tyler Thomas Wonders, born July 22, 1991 and Morgan Paige Wondcrs, born June 18, 1994, and are presently living with Wife, WHEREAS, difficulties have arisen betwcen the parties as a rcsult of which they have s~'Parated and now dcsire to divorce and, by this Agreement, to settle all financial and property rights between them; and WHEREAS, this Agrcement is made in scttlemcnt of a divorce action presently pending in the Court of the Court of Common Picas, Cumberland County, Pcnnsylvania, No, 97-7189 and WHEREAS, Husband and Wife respectivcly acknowledge that before signing this Agreement they have been fully advised by their respcctive counsel of their rights and obligations, have read carefully and understand the terms of this Agreemcnt, and have frccly consented to this Agreement, believing it to be fair, just and equitable; and WHEREAS, Husband and Wife arc satisfied that they understand the value and extent of all , property which would be considered "marital property" under the Pennsylvania Divorce Refonn Aet, whethcr titled or owned separately or jointly as well as the value and extent of nonmarital property held or expected to be held by each other. NOW, THEREFORE, in consideration of the mutual promises and undertakings set forth herein and intending to be Icgally bound hereby, the parties hereto do hcreby agree as follows: I, SEP ARA TION: Husband and Wife shall be free from constraint or control by the other as fully as ifhe or she were unmarried. Neither shall disturb, trouble and interfere in any way with the other or with any person for associating with the other, 2, RELEASE: Husband relinquishes his inchoate intestate right in the estate of Wife, and Wife relinquishes her inchoate intestate right in the estate of Husband, and each of the parties hereto by these presents, for himself or herself, his or her heirs, exccutors, administrators or assigns, docs remise, releasc, quit claim and forevcr dischargc thc other party hereto, his or her heirs, EXHIBIT "A" executors, administrators or assigns, or any of them, of any and all claims, demands, damages, actions, causes of action or suits ntlaw or in equity, of whatsoever kind or nature, for or because of any mailer or thing done, admitted or sull'ered to be done by said other party prior to and including the date hereof; further,the parties acknowledge that all rights under the Pennsylvania Divorce Code that arc not specifically incorporated herein are hereby expressly waived. Notwithstanding the foregoing language of this paragraph, this relellse shall in no way exonerate or diseharge either party hereto from the obligations and promises made and imposed by reason of this Agrcement and shall in no way affect any causcs of action in absolute divorce which either party may have against the other. 3, MARITAL RESIDENCE: Husband and Wife jointly own the marital residence located at 664 North Middle Road, Newville, Pennsylvania (the "Property"), Husband shall forthwith convey whatever his title, interest and rights he may have in said property and the parties' bank accounts to Wife, Concurrently therewith, Wife shall pay to Husband the amount 01'$21,700,00, 4, PERSONAL PROPERTY: A. B, ,,\V~~ ~ t\UTOMOB~ Husband shall receive sole title of the 1990 Ford F-150 and Wife shall receive sole title to the 1996 Dodge Caravan, Wife shall be solely responsible for any debts pertaining to said vehicles and shall ~.:::""h, , indemnify, defend and hold Husband harmless from any claim with respect ,.~ thereto, Huslx.\.........,l h po-7 ~\I teSts -h, 'ha.ns~ htt-es, ,L.W OTHER PERSONAL PROPERTY: The parties shall keep the personal property currently in their possession, with the exception that Husband shall receive the property on the list attached hereto which is presently in the possession of Wife, In the event that Wife C?"'t has to pay a third party to remove lMie items, then Husband shall reimburse Wife for these out-of-pocket costs, It is undcrstood that Husband may need the assistance of friends to remove property, Notice will be provided to I Husband as to whom and when the property shall be removed; provided, however, the same shall be scheduled as promptly as possible, The parties agree that the children will not bc present at the house at this time, 5, PENSION/RETIREMENT BENEFITS: Husbllnd and Wilc shall wllive any right or interest in the oth:r's pension or flltiremcnt benefits or sllvings, 6, AFTER-ACQUIRED PROPERTY: Elich of the parties shall herellfter own and enjoy, independently of any c1l1im or right of the othcr, 1111 items of property, be they real, pel1lonal or mixed, tangible or intllngible, which is or hilS been acquired by him or her ancr the date ofseparalion, with full powcr in him or her to dispose of the sam\~ as fully and eflectively, in all respects and for all purposes, as though he or she were unmarried, 7, MARITAL DEBTS: During the course ofthc marriage, Husband and Wife have incurred certain bills and obligations and have amassed a variety of debts, It is hereby agrced, without the necessity of ascertaining for whllt purpose and to whosc use each of the bills was incurred, that Wife shall be solely rcsponsible for any and all bills, obligations or debts incurred prior to separation and shall hold Husband free and harmless from any and 1111 liability which may arise ~:-, "\. I from same, This includes, without limitation, the private mortgage to Wile's parents. -W;r.. ;8- ~ TI- .'l \u~\'.'are afsfty other HR8Ruial allligBti61U onc:.d to 1I1(.lIIb<..& 01"11(( family. --(\..- ",' $ 8, POST SEP ARA TION DEBTS: Both parties agr~'C that, in the future, neither shall cause or permit to be charged to or against the othcr any purchase or purchases which either of them may hereafter make and shall not hercafter crcate any engagcl'1ents, debts or obligations in the namc of or against each other, Except as speeifieally provided hcrein, each agrees to hold the other free and harmless from any and all debts and other obligations which he or she may have incurred since the date of the separation and agr~'Cs to indcmnity and defend the othcr party from any claim regarding same, 9. CEMETERY PLOTS: Husband shall transfcr any interest he has in the cemetery plots to Wile upon issuance of II final decree of divorce, Wife shall provide Husband with the papers to sign for this purpose, 10, EXECUTION OF DOCUMENTS: The partics agree to exeeute all documents that are rcasonably neecssary to efTcctullte the purpose of this Agreement, In the event that either party shall refuse or fail to exccute and/or acknowledge any such document, then the other party shall have, and is hereby granted, the right and power to appoint one or more times any person or persons of his or her c1lC'osing as Ilttomcy-in-fact for lhe other pnrty to so exccute and acknowledge sueh documents, II, CONTRACT INTERPRETATION: For purposes of contraet interprctation and for thc purpose ofrcsolving any ambiguity hercin, Husbnnd and Wife agrec that this Agreement was preparcd jointly by their rcspcctivc attomcys. 12. ENFORCEMENT: Ifeithcr party dcfnults in the due performance of any ofthe . tenns, conditions and covenants of this Agreement on his or hel' part to be perfonned, the non- defaulting pl\J"ty shall have the right to sue for spccitic performance 01' damages for the breach of this Agreement, and the defaulting party shall pay the rcasonable legal lees for any services rendered by pension the non-defaulting party's attomey in any action or proceeding to cOlllpelthe defaulting party's duc perfonnance hercundcr as well as costs for bringing the action or proceeding, 13, MISCELLANEOUS: A, This Agreement constitutes thc entire agreement betwcen the parties, being the final and complete selllement of all mattcrs betwcen thcm and supersedes any prior written or oral agreemcnts between them respecting the within subject maller, Thcre are no representations, agreements, arrangements or undcrstandings, oral or written, between and among the partics hereto relating to the subjeet mailer of this Agreemcnt which are not fully expressed herein, B, This Agreement may not be amended, modi lied, altered or revoked except in writing exeeuted by both the parties hereto, C. This Agreement may not bc assigned by eithcr party without the prior wrillen consent of the other party, D. This Agrecment may be executed in multiple counterparts, each of which shall be deemed an original for all purposes, and all of whieh together shall constitute one and the same instrument. E, This Agreemcnt shall be binding upon the parties hereto, their heirs, executors, administrntors and assigns, F. This Agreement shall be interpretcd undcr the laws of the Commonwcalth of Pennsylvania in effect as of thc execution datc of this Agrccment. "'(\,\/,) ~~ ;' , , , " , ' 1. 2 3, 4. '5, 6, '7, 8, 9, 10, 11. i;' l)J '1Y ",:~~' ,,' I ); HUSBAND'S P~RS()NAI, PROPERTY ,STILL IN POSSESSIO/lf OF WIFE , ,! 2 ofthc 3 three-wheelers as designated by Wife One unfinished dry sink Hess truck collection Army medals Hunting video tapes Cartoon glasses collection Baseball card collection Oak and pine lumber Personal, Pllpers (baby album and baby pictures, Logging chains ' Metal cabinet and items Inside (screws, bolts etc.) " ! i , " .1 " " EXhibit. B , , M@&:6 ArroRNEY> /l( CO~NmlDlll AT UW W,WAM F, MAR1l0N )e.IlN 8. FO'WLlR III DANlfl K, DIAROOR" TItOMAS ), WillIAMS' I") V. 01'10 1II Sn'HlN L. 8LOOM C;IOaol 8. FALllR h,' M,ellAll), HANfT THOMA.s C;, COLLINS CARL C, Rlll':1t 8IN/AMI" T, WAaNIR TIN fAsT HIUH Sl'R.RT CARlISLI,VENN'l1.VANIA 17013 TmPtto", (717) 243-334\ FAClIMILl(117) 24J.1S50 INTERNIT www,mdwo,cum November 12, 1998 - '~CU.T1"WCML TNALS,.l1Aun Jolmna J.. Deily, Esquire SAlDIS, SH:UFF & MASLAND 26 West High Street .P,O, Box ~60 Carlisle, PA 17013. RE: Thomas L, Wonders v, Karen R. Wondel1l Our File No. 9140,1 Dear Johnna: It has now been three months since our clients signed an agreement requiring Mrs. Wondel1l to payMr, Wonders the sum of$2 I ,700.00 for his Interest in the house. This hasn't happened yet, nor are we given any expectation as to when it might happen. . You and I talked on the telephone a couple of months agt.i and you told me you would speak with your client. Over the past month, I h~ve left two mossages on your voice mail, without response, If your elient refuses to honor the agreement, I will have no alternative but to file a Motion . to Enforce. Please let me hear from you on this, If[ don't hear from you within ten days, I will recommend to the client that we take the only alternative available lO'us, and that is a Motion to Enforce the agreement. . Very truly yours, MARTS ON DEARDORFF WILLIAMS & OTTO Thomas J, Williams TJW/tde ';\IIILIS\OA l' Af1t.I\OlHL TlJI\9..to.m 20 I N. P 0 R M ^ T ION . A 0 Y I C F. . A 0 v 0 CAe Y 'w SAlOIS. SHUFF & MAS LAND A~AT.u.W Z6 W, Hip Slrttl Corll.lt, PA THOMAS LEE WONDERS, Petitioner IN THE COURT 01:" COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 97-7189 v. KAREN RAE WONDERS, Respondent IN DIVORCE ANSWER TO PETITION l"OR CONTEMPT AND TO EN~ORCE MARITAL SETTLEMENT AGREEMENT AND NOW, comes the Respondent, Karen Rae Wonders, through her attorneys, Saidis, Shuff & Masland, and files the following Answer: (J c If' ("') C') II '-;1 .1 1'1 " '.> Il"I~ ,'''' ,Jll c.) ,'( .> .'0 j~? ;:,1 ,'J -- , jlll .. I ,'.1 '.\' ~1I I,) -< l. Admitted. 2, Admitted, 3 , Admitted, 4, Admitted, 5, Admitted, 6, Admitted, 7, Admitted, 8, Admitted. 9. Admitted in part and denied in part, 'T' , rO-!'i -, It is admitted that a copy of an executed Deed was provided to the attorney for the Respondent, but it is specifiGally denied that Respondent has repeatedly told Petitioner that she has obtained the money. 10, Admitted in part and denied in part. It is admitted that Respondent received the majority of the money from the marital savings account, but 'some of the money was used for the parties' debt as well as for a trip for the children, 11, Admitted. SAlOIS. SHUFF & MASLAND A~ATIl(AW Z6W, HllbS,,'" CirU.I.. 'A 12, D~nied, It is specifically denied that the Respondent has failed, refused and continues to fail and refuse to comply with the Marital Settlement Agreement: a, SpecificaLly, the refinance of the real estate occurred on December 11, 1998, and a check in the amount of $21,700,00 was paid directly to the attorney for the Petitioner on or about December 16, 1998; b, The parties had discussed the retrieval of the items of personalty, and the Petitioner was to make arrangements to pick up this property, along with the junk that remained on the property; c, An Affidavit of Consent to the divorce was filed on September 22, 1998, 13. Denied, Copies of the deeds to the cemetery lot were provided to the attorney, but it was contingent upon Respondent executing the necessary paperwork, 14, Denied, Respondent has complied with all of the Property Settlement Agreement, as previously stated in the response to paragraph 12, 15, Admitted, Specifically, Respondent has complied with the relevant provisions of the Marital Settlement Agreement, 16, Denied, All of the items have been complied with, and it is Petitioner who should pay for Respondent's counsel fees, as all of the iteMs were carried out, Further, Respondent's attorney called Petitioner's attorney on several occasions to advise as to the status of the refinance, including when the commitment letter was received, when settlement was schedul,ed, and when the funds would be available, 17, Denied. The allegation in paragraph 17 is a conclusion of law to which no response is required. To the extent a response is required, allot the items a through c were complied with, and it iS,Respondent's attorney's fees that should be paid by the Petitioner for filing this unnecessary lawsuit, 18, Denied. Respondent is not o~ligated to pay anything to Petitioner, as aU the items were complied with and Petitioner's attorney knew of the time frame for the refinance, WHEREFORE, the Respondent respectfully requests Your Honorable Court to dismiss the Contempt petition as filed by the Petitioner, and Order Petitioner to reimburse her for any attorney's fees she had to incur to defend this lawsuit, Respectfully submitted, SAlOIS, By: SAIDIS, SHUFF & MAS LAND A~AT.U~ J6 W, HI'" SUitt tull.... PA THOMAS LEE WONDERS" I?laintiff v. IN THE COURT OF COMMON I?LEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 199 7- CIVIL TERM ; No. 7189 : IN DIVORCE KAREN RAE WONDERS , Defendant DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REOUE.i! ENTRY OF A qIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on December 31, 1997. 2. Defendant acknowledges and accepts service of the Complaint on January 10, 1998. 3. The marriage of I?laintiff and Defendant i~ irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the ent~/ of a final decree of divorce without notice, S. 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. 6. 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 I?rothonotary. 7, I have been advised of the availability of marriage counselling and understand that I may request that the court require counselling, I do not request that the court require counselling, SAlOIS, SHUFF & MASLAND A~ATtt.AW 16 W. Hip ,""' c.arlltlt,'A I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made subject to the penalties of 18 I?a. C,S. Section 4904 relating to unsworn falsific~iQn to authorities. DATED: "?.~:'1\C\91 ~\'"'" ..:;<, \NCl'Y'\Ah[,) \ Karen R. Wonders. Defendant n ~, ;:;~:.l '" "'1 '-.:J '-l '" are ~j: ~ ?, '.;1 :l~] .' rrJ ".j'.? ::(J ,'j~~ >:' ) ~-m ...J -I !i ..... ::1 ~.. ('Lf ~~: ~.~ I: : c".: .. '-j -. c:- CA1'HO~~OOIlI 1'4)Uf'UI Pu.l I'l)fm AlNlllWtll OMIJ No. uuum A, U,S, DEPARTMENT OF 1101' 'Q AND URBAN DEVELOPMENT IR'I'\" . "II-,ll" 1'YI'1l Pi'1.O^N . , ) .lLmHv lIHIHS, I_I 1 - (IMIIA ,/' 4 _.VA I. CtlH V. IHS ./ Sold Is, GuIdo, Shuff & Masland 6. IliI" Nv., 11 ..u... Nvwb., WONDERS .~ .--- . ~hull'I" Iii. C". NIl. SETTI EMENT STATEMENT , .- - C, NOIf: '1111. (o(/II I. P,,"iuIr,III' ~11I' )1m' U jlU',IImll UI'Mllul wllrlll"'" ,'UUl ~1"UI"1II1 puM III ulIll by JJII UII/"1I1t111 ugrlll II'. UWWIL 11"11' ItlUllw/"{I',O.(',)'" IWO" PUJ~ UU~ IIIfI ,'mlllt; ,hcv Uti ~Jluw/l/"" fUf j/l.E!.EulilJtwlllmpu.t. tlllt/ 1JI1 till' IlIcllllkd III ,h. IUwh D, HAME mD ADDRESS OF BORROWER: a ren ll. Iolande rs. J 1U911 E, HAME, ADORESU ANa fiN OF SELLER: flef Jnlllnl F, NAME ANO ADDRESS OF LENDER The Fanners National nank of Newville, PA 1'.0, !lox 156 Newv II Ie, PA 17241 G. PROPERTY LOCA110N: 664 N, Middle !load Newv 111 e Pennsylvania 17241 o Propolty Of 6eMcol Recolvud Saidis, Shuff & M.1S I and TIN 1251694606 II SETTLEMENT AGENT: PlACE OF SETlLEMENT: 26 West 1119h Street Carlisle, PA 17013 I. SETTLEMENT DATE: 12-11-96 1l.b1l1rlKIIl,nt nllo: 12-16.')0 , ), SlJMMAI\ Y or 1I0l1110WI!II'5 'I'IlANSAC'I'lllN K. SlIMM^1l YOI' SHI.I.nIl'S 'lHANSAC7noN 100. mlOss .iA/OIINT I)/If: NIOM 110/11I011'1'1/' 4lH\ O/IO.VV ,iMoIIN'f /lllf: TO Slil,I,IL'/I: 101. ClllllrUl,'llUl~. Il,!l:i: . .lUl. C.ulllnU:lllllca IJlk~ 102. P~nontll PrullC:r1V .102, l'c",,"a1Ilropcny -- tOl Sculcm(ul dlllrlCJ 10 burruwc:r(lill': 11(0) 22 1629 ~ 00 ,101, 101, ~O.I. 10S I'AYOFF lOTAl(S) . , 21!J"2"g,-llll ,HIS. ,',ljUflllltIlU (llf iltUn pdM hy st/fa 1/1 IIf/l'dllft _--!..llIjllulllr"'~ f!!., j",fU I'tJIiI by utltr ill mli'Ulln: 106. Cily/lOwn Illlet In .106, C'hy/hlWU laxel 10> 107. Counly laxe. 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",' I'^II)' NlllM ' nUllllOWIIIl'S FUNDS AT SIl'I'I'l.llMIlNT 1'^IIl FilUM SI!I.I,I!II'S HJNDS AT SIl'm,IIMllNT ill:l.\ m':)/S"(Il'A8aUfvCQNNb'C'fltJNlVml/.o.1NI,H))"1,1.~t':'h',,, ':;':',I,!,:IP,lI.l!:\ '''" .. '-ONlJl.lIlonf" ~ The Fanners National Dank of Newville ,lMO DbMunl 'If, .- APMbal Fcc In ... CndU lI,ponln .. lmdtr'. IntllCClloll F.:c: In ,. .L'.ll1~a.t hlluralU:c ^1)I)lIctHlnu Fl:u In , im1. .oUtUmlJllnn Fe., In j.;,j, Application Fee to The Farmers NatlonarOank of Newville, PA 1lO'), 810, :Ill ~,~. .11 bll. " 370,00 100,00 _ POO I'/D:MS n/1Q/J/RIi/) IIY I.hW/l/::n TO 11/. 1',11/1 IN AIIV,1NCf: 901, lnh:ll:" (HIm In Cl~ $ lililY ( 902. Marlgllllc IUluranc&: .-n:llllulIl rur IIIUlllh, hi 901. lIal4ul Insunmtc Iln:lIIhulI I"or 1 )'l:lIr lU !IOl, !IOl, . ~~r!l. ((Ouyerll 1100 1'fIU' CllIIROh'S 1101. Sclllemenl or dOlin,ll rtc 10 1101, Abtlra" or 1111. "arch 10 IIOJ. Tille l'.X8l11lf1l1tion 10 11l)4, Tille In'"rllne&: binder In IIOS. llucllllU~nl urcllMuliun 10 1106. NolaN rea: 10 1101. Allumey', (ee 10 {illCtlldtl ubiJVf iwnr 1I11l1lbcrJ: 1108. 11111: Inauranc.: 10 (blduJ.:. uoow ',ellU """,befl,' 1109. lender', COYeral~ t 110. Owner'. ('O\'crllllC 1111, 1112, 1111 l1IU1uh,@ , IIIUIIIIII (!jl $ munlllA (ly $ IIUlfllh~ <l( $ lIlululli' ti:~ $ nU)lJlhl @ $ mUlllhl @ $ month>> (ill $ - ,.' " , , ,.1.., . . , ' , lief IIIlullh lH:r lIIonlh lH:r month l)Cr lIIUlIlh Ik:r 1IIIIIlIII - lM:r IIIUI1II. pcr nUlIIlh 1N:llllonlh - 10000/lESEHVES N:POSmm WI/'/lI,/1NllF./t 100L 1I..1IIrt) Insurance 1002. MOllgllc InulrI.IIIec 1001 (,'hy l,rol><"Y IWI" IOO~. CoUnlY IIWllCrly IllXCI )UOt AnIlUIIIIIUCil.''inICIlII 1lJ()6, 1001, 1008, Saldls-:sTiii11 & Masl.lJlll Salllls, S/u!L1TMasland Saldls -shuff & Masland 50,00' 6.00 325JiO s s -~ 1200 OOVEIlNMf.'NT /tECOI/OINO ANIl '/1lANSl'f:n CIWIOES 1201. n.'or~lnl I..., IJ"~ 1202, Chy/cuunlY 1,"",lamp" 1203. Sill. IllJl/Ilnmp. 1'10.1. 12Ul, $ 25,50 Oc.~ s j)..~ s : MUflSllge $ 27.50 ,1Ic1"". $ : MOUIIUIC $ : MnrlKllHC $ 53,00 1301, 1302, 130l, IlO4, 1301, 1306, 1301, 13011. , 1300 A/JDrt'IONAI, S~'lTL/1M6'N'/'Cl/.in(J~'S . . . ORO lien Search to Saidl.iLJhurr&1ia!iJan~L Ai rborne PayOTftOSdTdls , ShuTr&Masl an(r--- Settlement Payment to Thomas L. ~onders . 10.00 15,00 21, 1400 T07'III, SF.'ITUMf.'N7' ('/IA//C1/1S ('Ill" "" Ii"" 10:1, S<<';II" I Wld 501, S",lo" K) 22 629,00 IIlwe 'II',^", ,.......u .. IlUI).I Scu"""" S4'l,IIMIM Inlf, 10 lb, k.1 Dt rrr'J knowltd.' and ttdI,l. II b . InI' II'\d 1kl(W1l. .ltI,,..,lt uI t:j rmlpe. ,OIl ...t.ufMlMnlt ..w. QI' flI)' .QWlIIIC DC' ~ _ In lhlI u"""",,* I ,~, lItniIJ tII.. I hew NUIw," . 00fl1 of IIUI).I S4IlI.cocm SlIt.mell" ~~>k~~ ::-----...----------.. ::: -. ----- let iN .... of ., ''''IN.-,~.J.!UD' ~. UllIIl4 ..Nib Il!WIlI I'l'PIfN It . IJlM IUJ 1CCUf1C. '"DlMII utlh. fllnd. *bkll ...,. mtht.J IN'" hi'll ."11 Of ..lit.. ....lit.... ., Ih. 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