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HomeMy WebLinkAbout98-00196 . Beoknell Agl/7 .23,99/B.3,99IB,31 ,99/9,B,99 MARRIAGE SETTLEMENT AGREEMENT THIS AGREEMENT made thisA"'"'' day of .(~+,,.j;,Jnl,jJ(- , 1999, -- " by and between William D. Beckneil ("Husband"), of 210 West Allen Street, Apartment I, Mechanicsburg, Cumberland County, Pennsylvania, and Elaine Trace Becknell ("Wife"), of 287 Lake Meade Drive, East Berlin, Adams County, Pennsylvania. WHEREAS. the parties hereto are Husband and Wife, having been married on December 21, 1986, in East Berlin, Adams County, Pennsylvania; WHEREAS, diverse and unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Husband and Wife to live separate and apart for the rest of their natural lives, and the parties hereto are desirous of settling fully and finally their respective financial and property rights and obligations as between each other including, without limitation by specification: the settling of all matters between them relating to the ownership and equitable distributlDn of real and personal property; the settling of all matters between them relating to the past, present and future support, alimony and/or maintenance of Wife by Husband or of Husband by Wife; and in general, the settling of any and all claims and possible claims by one against the other or against their respective estates. NOW. THEREFORE. in consider<ltlon of the premises and mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt for which is hereby acknowledged by each of the parties hereto, Wife and Husband, each intending to be legally bound hereby, covenant and agree as follows: 1. INCORPORATION OF PREAMBLE: The recitals set forth in the Preamble of this Agreement are incorporated herain and made a part hereof as if fully set forth in the body of the Agreement, 2. AGREEMENT NOT A BAR TO DIVORCE PROCEEDlNWi: This Agreement shall not be considered to affect or bar the right of Husband and Wife to an absolute divorce on lawful grounds If suoh grounds now axist or shall hereafter exist or to such defense as may be available to either party. This Agreement is not intended to condone and shall not be deemed to be condonation on the part of either party hereto of any act or acts on the part of the other party which have occasioned the disputes or unhappy differences which have occurred or may ocour subsequent to the date hereof. 3. DIVORCE OE.CBEf;: The parties acknowledge that their marriage is Irretrievably broken and that they will secure a mutual consent no.fault divorce decree itl the action flied at 98-196 Civil Term, in the Court of Common Pleas of Cumberland County, Penflsylvania. As soon as possible under the terms of said Divorce Code, the parties shall execute and file all documents and papers, including affidavits of consent, necessary to finalize said divorce. If either party falls or refuses to finalize said divorce or execute and file the documents necessary to finalize the divorce, said failure or refusal shall be considered a material breach of this Agreement and shall entitle the other party at his or her option to terminate this Agreement. 4. effECT OF DIVORCE DECREE: Unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final Decree in divorce may be entered with respect to the parties. 6. AGREEMENT TO BE INCORPORATED IN-IDYORCE DECREE: The terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them. 6. NON-MER~: This Agreement shall not merge with the Divorce Decree, but rather, It continues to have Independent contractual significance and each party maintains their contractual remedies as well as court remedies as the result of the aforesaid Incorporation or as otherwise provided by law or statute. 7. DATE OF EXECUTION: The "date of execution" or "execution date" of this Agreement shall be defined as the date of execution by the party last executing this Agreement. 8. DISTRIBUTION DATE: The transfer of property, funds and/or documents provided for herein shall only take place on the "distribution date" which shall be defined as the date of execution of this Agreement unless otherwise specified herein. .9. ADVICE OF COUNSEL: The provisions of this Agreement and its legal effect have been fully explained to Husband by his counsel, Christopher C. Houston, Esquire. Husband acknowledges that he has received independent legal advice from counsel of his selection and that he fully understand the facts and has been fully informed as to his legal rights and obligations and acknowledges and accepts that this Agreement is, in the circumstances, fair and aquitable and thet it is being entered into freely and voluntarily, after having received such advice and with such knowledge and that execution of this Agreement is not the result of any duress or undue Influence and that it is not the result of any collusion or improper or illegal agreement or agreements. Wife has elected not to proceed with the independent advice of legal counsel, although she acknowledges that she has the legal right to do so. Nonetheless, she fullV understands the facts and acknowledges and accepts that this Agreement is, In the olroumstances, fair and equitable and that it is being entered Into freely and voluntarily, and that execution of this Agreement is n;)t the result of any duress or undue Influence and that it is not the result of any collusion or improper or illegal agreement or agreements. Each party hereby acknowledges that this Agreement is fair and equitable, that it adequately provides for his or her needs and Is in his or her best interests. and that the Agreement is not the result of any fraud, duress, or undue Influence exercised by either party upon the other or by any other person or persons upon either party. t 1/ I l'l ~: r ~ I I j' j I" I 10. DISCLOSURE AND WAIVER OF PROCEDURAL RIGHTS: Each party understands that he or she has the right to obtain from the other party a complete inventory or list of all of the property that either or both parties own at this time or owned as of the date of separation, and that each party has the right to have all such property valued bV means of appraisals or otherwise. Both parties understand that they have the right to have a court hold hearings and make decisions on the matters covered by this Agreement. Both parties understand that a court dcision concerning the parties' respective rights and obligations might be different from the provisions of this Agreement. Given said understanding and acknowledgment, both parties hereby waive the following procedural rights: A. The right to obtain an inventory and appraisement of all marital and separate property as dEfined by the Pennsylvania Divorce Code. B. The right to obtain an income and expense statement of the other party as provided by the Pennsylvania Divorce Code. C. The right to have any discovery as may be permitted by the Rulas. of Civil Procedure, except discovery arising out of a breach of this Agreement or out of any other proceedings In which discovery is specifically ordered by the court.. D. The right to have the court determine which property is marital and which is non-marital, and equitably distribute between the parties that property which the court determines to be marital. E. The right to have the court decide any other rights, remedies, privileges, or obllgarions covered by this Agreement, including, but not limited to, possible claims for divorce, spousal support, alimony, alimony pendente lite (temporary alimony), and oounsel fees, costs and expenses. 11, PERSONAL PROPERTY: Husband and Wife do hereby acknowledge that they have preViously agreed to a division of their tangible personal properly Including, but without limitation, Jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, topls, pictures, books, works of ert and other personal property. The parties hereby ratify and confirm their agreement to the diviaion of their tangible personal property as a part of this Agreement. The parties do hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to the above Items which shall become tho sole and separate property of the other. 12. AFTER.ACQUIRED PRQfE.HJ'y: Each of the parties shall hereafter own and enjoy, independel1tly of any claim or right of the other, all property, tangible or intangible, feal. personal or mixed, acquired by him or her, since the 22nd day of ,Iune, 1997 , the date of the parties' marital separation. with full power in him or her to dispose of the same as fUlly and effectively, In all respects and for all purposes, as though he or she were unmarried and each party hereby waives, releases, renounces and forevar abandons any right, title, interest and claim in and to said after acquired property of the other party pursuant to the terms of this paragraph. 13. DIVISION OF VEHICLES: With respect to the vehicles owned by one or both of the parties, they agree as follows: A. Wife shall receive as her sole and separate property the 1987 Chevrolet C-20 Conversion Van and the 1991 Chevrolet GEO Metro, Husband shall receive as his sole and separate property the 1995 S-1 0 Chevrolet pick up. B. The title of said vehicle shall be executed by the parties, If appropriate, for effectuating transfer as herein provided on the date of execution of this Agreement and shall executed title shall be delivered to the proper party on the distribution date. For purposes of this Agreement, the term "title" shall be deemed to include "Power of Attorney" if the title to the vehicle is unavailable due to financing arrangements or otherwise. In the event that any vehicle is subject to a lien or encumbrance, the party receiving said vehicle as his/her property shall take it subject to said lien and/or ancumbrance and shall be solely responsible therefore and said party further agrees to indemnify, protect and save the other party harmless from said lien or encumbrance. The parties specifically waive, release. renounce and forever abandon whatever rights, title and interest she may have in the vehicle thet shall become the sole and separate property of the other party pursuant to the terms of this paragraph. 14. REAL ESTATE;: The parties are the joint owners of a certain tract of improved real estate known and numbered as 287 Lake Meade Drive, East Berlin, Adams County, Pennsylvania, which has heretofore been utilized as their marital residence (hereinafter referred to liS "the Real Estate"). The Real Estate Is encumbered with a mortgage owed by the parties to Adams County National Bank (hereinafter referred to as the "Mortgage"). Husband agrees to transfer his interest In the real property in the event that Wife refinances the Mortgage on the marital residence. Husband shall execute a deed of conveyance which will be held in escrow with Chester Shultz, Esq. pending settlement on said refinance, with the deed of oonveynnce to be released to Wife at settlement. Wife shall make applioatlon as soon as practicable to procaed with the refinance which shall be accomplished within ninety (90) days of the date of this Agreement. Husband shall pay to wife $529.00 to assist Wife with the payment of her closing costs on said refinance. In the event that Wife does not accomplish a refinance within the aforesaid time period. then the Real Estate shall be listed for sale and the deed of conveyance being held in escrow by Husband shall be nullified. Upon sale of the Real Estate, Wife shall receive all of the net settlement proceeds. Husband agrees to cooperate and to sign any and all documents necessary to accomplish the transfer and refinance, as aforesaid. Pending the refinance and/or sale of the premises, as provided for herein, Wife agrees to pay any and all expenses in connection with the marital residence, including but not limited to mortgage payments, taxes, utilities, and assessments. Notwithstanding the foregoing, Husband shall pay to Wlftl the sum of Four Hundred Dollars ($400.00) per month, made payable to Wife, as a contribution toward the mortgage payment with said contribution to be made for each and every month from the date of execution of this Agreement up through and including the month of December 1999. Wife shall further indemnify Husband and hold him harmless from the aforesaid obligations, except as provided herein regarding Husband's obligations for contribution on the mortgage. In the event that the real estate shall be sola, Husband shall be required to accept an offered purchase price that Is agreeable to Wife. 15. EACH PARTY RETAINS OWN PENSION PLANS: Each of the parties does specifically waive, release, renounce and forever abandon all of their right, title, interest or claim, whatever it may be, in any Pension Plan, Retirement Plan, Profit sharing Plan, 401 (k) Plan. Keough Plan, Stock Plan, Tax Deferred Savings Plan and/or any employee benefit plan and IRA Account of the other party, whether acquired through said party's employment or otherwise, and hereafter said Pension Plan, Retirement Plan,Savings Plan, Tax Deferred Savings Plan and/or any employee benefit plans hall become the sole and separate property of the party In which name or through whose employment said plan is carried. 16. Lm1S.1QN OF BANK ACCID.!.NI.S: The parties acknowledge and agree that they have previously mutually agreed upon a distribution to their mutual satisfaction of their bank accounts and hereafter the parties agrell that all said bank accounts in the posseSSion of the other party shall become the sole and separate property of the other party. The parties shall cooperate with each other to remove their respective names from the other party's bank account. Each of the parties do specifically waive, release, renounce, and forever abandon whatever right, title, interest or claim. he or she may have in any bank account that is to become the sole and separate property of the other purslJant to the terms hereof. 17. WAIVER OF INHERITANCE: Each of the parties hereto does specifically waive, release, renounce and forever abandon any right, title, interest and claim, if any, either party may have in and to any inheritance of any kind or nature whatsoever previously or in the future received by the other party. 18. WIFE'S DEBTS: Wifa has the following credit card obligations: A. Sears Account No. 54-80679-351733 B. CitiBank VISA (American Air Advantage) Account No. 4128003249191811 C. Discover Account No. 6011002179505128 D. Members 1" VISA Account No. 4121449998441336 Husband has paid in full the obligation on the above-referenced Discover Card which was due and owing as of June 1, 1999, and has paid in full the obligation due and owing on the aforementioned Members 1" VISA account due and owing as of July 21, 1999. Wife shall cause Husband's name to be removed, as an obligor on any of the aforementioned credit card accounts or any other credit cards and all other obligations upon which Wife is an obligor. Wife shall further hold Husband harmless from any and all claims or demands made against him by reason of the debts or obligations incurred by Wife, including, but not limited to, the aforesaid credit card obligations. Wife represents and warrants to Husband that since the 22"<1 (jay of June 1997, she has not contracted or incurred any debt or liability for which Husband or his estate might be responsible and Wife further represents and warrants to Husband that she will not contract or incur any debt or liability after the execution of this Agreement, for which Husband or his estate might be responsible. Wife shall indemnify and save Husband harmless from any and all claims or demands made against him by reason of debts or obligations incurred by her. 19. HUSBAND'S DEBTS: Husband has the following credit card obligations: A. VISA Account No. 4486120000885773 B. Members 1" MAC VISA Account No. 4482510044462064 Husband will be solely responsible for the aforementioned obligations. Husband shall cause Wife's name to be removed, as an obligor on any of the aforementioned credit card accounts or any other credit cards and all other obligations, upon which Husband is an obligor. Husband shall further hold Wife harmless from any and all claims or demands made against him by reason of the debts or obligations incurred by Husband, including, but not limited to, the aforesaid credit card obligations. Husband represents and warrants to Wife that since the 22"d day of June, 1997, he has not contracted or incurred any debt or liability for which Wife or her estate might be responsible and Husband further represents and warrantt to Wife that he will not oontract or Incur any debt or liability after the execution of this Agreement, for which Wife or her estate might be responsible. Husband shall indemnify and save Wife '~. hllimless from any and all claims or demands made against him by reason of debts or obligations Incurred by him. 20. MARITAL DEBT: The parties acknowledge and agree that there are no other marital debts that have not otherwise been provided for herein. Any joint debt of the parties shall be canceled so that neither party can make any further charges thereunder and If said charges are made in violation of this Agreement, then the party incurring said charges shall immediately repay the same. Any liability not disclosed In this Agreement shall be the sole responsibility of the part'{ who has incurred or may hereafter incur it, and the party incurring or having incurred said debt shall pay it as it becomes due and payable. From the date of this Agreement, each party shall only use those credit card accounts or incur such further obligations for which that party Is individually and solely liable and the parties shall cooperate in closing any remaining accounts which provida for joint liability. 21. BANKRUPID: The flarties hereby agree that the provisions of this Agreement shall not be dischargeable in bankruptcy and expressly agree to reaffirm any and all obligations contained herein. In the event a party flies such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other plIrty shall have the right to terminate this Agreement in which event the division of the parties' marital assets and all other rights determined by this Agreement shall be subject to court determination the same as if this Agreement had never been entered into. 22. SOCIAL SECURITY BENEFITS: The parties agree that subjact to the rules and regulations of the Social Security Administration, each of the parties shall continue to be eligible for Social Security benefits to which he or she would ordinarily be qualified as a party to a divorce after a marriage of ten (10) years or more in duration, If the parties' marriage is determined to be of ten (10) or more years In duration. 23. INCOME TAX PRIOR RETURNS: The parties have heretofore flied separate federal and state returns. Both parties agree that in the event any deficiency in federal, state or local Income tax is proposed. or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any 1083 or liability for any such tax defiCiency or assessment therewith. 24. FINAL EQUITABLE Q.lSIBlIlllTION OF PROPERlY: The parties agree that the division of all property set forth In this Agreement is equitable and both parties relinquish the right to divide said property in any manner not consistent with the terms set forth herein. It is further the intent, understanding and agreement of the parties that this Agreement Is a full, final, complete and equitable property division. 25. WAIVER OF ALIMONY. SPOUSAL SUPPORT AND COS.IS: The parties hereto agree and do hereby waive any right and/or claim they may hove, both now and in the future, against the other for alimony, alimony pendente lite. spousal support, maintenance. counsel fees and costs. 26, PERSONAL RIGHTS: Husband and Wife may and shall, at all times hereafter, live separate and apart. They shall be free from any control, restraint, interference or authority, direct or indirect, by the other in all respects as fully as If they were unmarried. They may reside at sllch place or places as they may select. Each may, for his or her separate use or benefit, conduct, carryon and engage in any business, occupation, profession or employment which to him or her may seem advisable. 27. MUTUAL RELEAW: Husband and Wife each do hereby mutually remise, release, quitclaim and forever discharge the other and the estate of such other, for all time to come, and for all purposes whatsoever, of any from any and all rights, title and interests, or claims In or against the property (including Income and gain from property hereafter accruing) of the other or against the estate of such other, of whatever nature and wheresoever situate, which he or she now has or at any time hereafter may have againt such other, the estate of such other or allY part thereof, whether arising out of any former acts. contracts, engagements or liabilities of such other or by way of dower or curtsey, or claims in the nature of dower or curtsey or widow's or widower's rights, family exemption or similar allowance, or under the intestate laws, or the right to take against the spouse's will; or the right to treat a lifetime conveyance by the other as testatmentary, or all other rights of a surviving spouse to participate in a deceased spouse's estate. whether arising under the laws of (a) the Commonwealth of Pennsylvania, (b) State, Commonwealth or territory of the United States, or (c) any other country, or any rights which either party may have or at any time hereafter hove for past, present or future support or maintenance, alimony. alimony pendente lite, counsel fees, equitable distribution, costs or expenses, whether arising as a result of the marital relation or otherwise, except, any only except, all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provisions thereof. It is the intention of Husband and Wife to give to each other by the exec~tion of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provisions thereof. 28. WAIVER OR MODIFICATIQN.,IQ BE IN WRITIl'iQ: No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of allY subsequent default of the same or similar nature. 29. MUTU~L COOPERATION: Each party shall, at any time and from time to time hereafter, take any and all steps and execute, acknowledge and deliver to the other party, any and all further Instruments and/or document that the other party may rllasonably require , for the purpose of giving full force and effeot to the provision~ of this Agreement. 30. AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs. executors, administrators, successors and assigns. 31. INTEGRAIIQN: This Agreement oonstltutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between tham. There are no representations or warranties other than those expressly set forth herein. 32, .Q.l]feB DOCUMENTAIIQ.l\I: Wife and Husband covenant and agree that they will forthwith (and within at least twenty (20) days after demand therefor), execute any and all written instrulTlents, assignments, releases, satisfactions, deeds, notes, stock certificates, or such other wl'ltilngs as may be necessary or desirable for the property effectuation of this Agreement, and as their respective oounsel shall mutually agree should be so exeouted In order to carry out fully and effectively the terms of this Agreement. 33. NQ..WAIVER OF DEFAU.!.I: This Agreement shall remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall in no way affect the right of such party hereafter to enforoe the same, nor shall the waiver of any subsequent default of the sarne or similar nature, nor shall it be construed as a waivar of strict performance of any other obligations herein. 34. BREACH: If for any reason either Husband or Wife fails to perform his or her obligations owed to or for the benefit of the other party and/or otherwise breaches the terms of this Agreement, then the other party shall have the following rights and remedies, all of which shall be deemed to be cumulative and not in the alternative, unless said cumulative effect would have an inconsistent result or would result in a wlndfail of the other party. A. The right to specific performance of the terms of this Agreement, In which event the non-breaching party shall be reimbursed for all reasonable attorney's fees and costs incurred as the result of said breach and in bringing the action for specific performance. B. The right to damages arising out of breach of the terms of this Agreement, whioh damages shall include reimbursement of all attorney's fees and costs incurred as the result of the breach and in bringing tha damage action. C. The right to all remedies set forth In Section 3602(e) of the Pennsylvania Divorce Code, 23 Pa.C..S.A. 3602(el. and any additional rights and remedies that may hereafter be enacted by virtue of the amendment of said Section or ir co C; ~ ('., .. ~.... ~Q N )...~ \~~ [< J ;r.: ,"J: 1>_ ,,~ 1'1'.' r:~~ :!-,O <:) II r,:: 'S "... IN .....:... ily,1 ~. frz ,!.; :g~ ~ b CI' a a'\ i co ?; 0 ~Q N ~~ J:? :r- 0- ~~ (J(:-:, 6~t: Cl 3m LU"- N ltt! ~ .tii ?: ~H t> $ a 6 There have been no prior actione for divorce or annulment in this or any other jurisdiction within the knowledge of the Plaintiff. 7 In accordance with Sect.ion 3301(c) of the Divorce Code, the marriage between the partiee is irretrievably broken. B Plaintiff haSl been ad"i.sed that oounseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in couneeling. WHEREFORE, the Plaintiff request.e your Honorable Court to decree that the Plaintiff be divorced from the Defendant. COUNT II - EQUITABLE DISTRIBUTION 9 Paragraphs 1 through 4 of the Complaint are incorporated herein by reference as though set forth in full. 10 Plaintiff and Defendant have acquired property, both real and personal during their mardage from Deoemher 21, 1986 until the date of their eeparation. 11 /"1 ,1"'\ '" \J /Ill' '" I"l\ 1"'\ 1"'\ ^ ~. I~ I r. r' ('. GHAPHCOM, INC.ITI7) 334<1101 DATE RECEIVEO DATE PROCESSED SHERIFF'S DEPARTMENT ADAMS COUNTY, PENNSYLVANIA COUATHOUSE, GETTYSBURG, PA 17325 IN81'RUCTION8, s.. "INSTeUCTIONS FOR SERVICE OF PROCESS BY THE SHERIFF" on lhe '''''''18 ollne lasl (No.6) copy ollhls form, Pl.... type or ptlnlleglbly, Insuring readablllly of all copleY, Do 1101 delach any copies. AClt> I!NV,I ._------_._--~---- 1, PLAINTIFrlS1 2, COURT NUMeER WILLIAM D, BECKNElL 98-196 CIVIL TERM a. DEFENDANT/SI --------- 4. TYPE OFWAIT OR COMPLAINT; Reinstated ElAINE T. BECKNELL Com laint in CiviJ Action 5, NAME OF INDIVIDUAL. COMPANY, CORPORATION, ETC, TO-SEHVicE OR OESCAIPTlON- OF peOPERTY TO BE LEVIED, ATTACHEO OR SOW:---- SHERIFF SERVICE PROCESS RECEIPT. end AFFIDAVIT OF RETURN IIRYI . Elaine T. Becknell AT 8. AOORESS (Slr.lll or AFO, Apanmenl No.. City. BOlO, Twp., Slale and ZIP COOE) 287 u.ke tlJetJde Drive, East Berllll, PII 17316 7, INDICATE UNUSUAL SERVICE: [I PERSONAL 1'1 PERSON IN CH~Ul!?g,eUTlZEJ:I.Q.~l.MAIL 1,1 REglsTERED MAIL II POSTE.!? [,1 OTHER - Now, _ 19 ____, I, SHERIFF OF ADAMS COUNTY. PA., do hereby deputize the Sherllf of , County to execute this Writ and make return therof according to law. This deputation being made at the request and risk of the plaintllf. __'___', ..______,_,_____ .____~_.~~___~:.9L~AMS.QOUNlY 8, SPECIAL INSTRUCTIONS OR OTHEAiNFORMATIO'N THAT WILL ASSIS1-1~' EXPEDITING SERVICE, NOTE ONLY APPLICABLE ON WAIT OF ExeCUTION: N.S. WAIVER OF WATCHMAN-Any deputy sheriff levying upon or lURChing any property under wllhln writ may leave ..me without. wI'cnman, In CUIlOOy 01 whomever Is lound In possession, afler noUlylng person ot levy or allachmenl, wllhoull!ablllly on the part 01 such deputy or lhe ehitfltl 10 anv p1llntlff hlreln for Iny lon, delllruetlon or removal 01 any such properly before sheriff's 91110 thereof. 8, ltoNATURI CJt A YTORNEVor other ORIGINATOR r~qu8 Sling lelvice ~n behai~--~'0' TELEPHONE NUMBER =r11. OATg 1-l{PLAINTIFF Christopher C. Houston, Esq. nDEFENDANT (717) 241-5970 SPACE-jlSE OF SHERIFF ON!.:'L=-D.Q NOT W~R E-P..E.1..0W IJ:llS.C:-. _____-= 12, I acknowledge r4tCtlpt of lhe wrll SIGNATURE 01 Aulhorlzed AC90 Depuly or Cloi'k and Tille 13. Dale Received 14. El(pltallon / HearIng dale or complaint II Indicated .bov.. . ._-~ -.-.. 16, I h.reby CIIRTlflV and Rl!TUAN lhal 1)( have personally served, [] have served person In charll8, fJ have legal evIdence 01 service 81 showl! In "Remark." (on taverse) n ha~ potted 1h. abov, d.scrlbed property with lhe writ or complaint desotlbed on lho Individual, company, corporallon, ole., al the addre" shown above or on lhe individual, company, COfpofallon, tIC" Illhe addresI inK.rled below by handlng/ot POlling. TAUE Ind ATTESTED COPY therof, 18. [II Mrtby certify Ind ,.lurn a HOT FOUND because I am unoble 10 looSIO the Individual. company, torpor.lion, elc., named above, (See r"marks below) 17. Nam. Itt(1 m'- of IndtvldutlllltfV.d . ~~--.__._- -TIe. A Pfl'latl ollulleble 1(It Ind dllCttl;Qn Read Order the" ,elkung In the ~leMlnl'l UIIJ.' ['I BLAINB T. BBCKNELL ~"..,_ u 10. Add'.. 01 wh.r...Ned (complete only If dllletlflllh.n-Ih~wn "hove) (Slr.~"fi.lFD, Apa'rtm;.;jN;-;-Cltv, 8oro, TWp., ]~D.te of Service 21 Time Slltt Ind liP CODE) 2-21-98 2:25 PM - 22, An'MPTi-C::~ MI... lOop.lnl.- 0111 MIII11:'"P':J DI:J MII," Oop.ln~l Dll~-I-,:j~p'lnl. _ Dill Milo Oop.lnl. 23, A\lvlnct eoii'i24:' 26 126 27, Tolll COlli 2e 1l~Rl!FUND $75.~ FbI. ~ #196~3 _____ .40.LI0 Pc!, ,'3L.,60 Ck. #314 . ft;!Icddr, jJ 1/a;~N~~'R'__ By INM ~ 8hefH'f) IPIe... P,lnl or TyPl) -____-----1~_________ MICHAll.lLJ....._ COOL!!.EP.UTY SHERI Slgnalur. 01 Sheriff [{A Yt<rJND IJ. NFJ.-iMAN AFFIRMED Ind .ublo,lbId 10 blIOfI nil Ihll ___, N/A ProlhonottrylDt9utY~otitV Public --_._~--_._. Dlt. F 2-21-98 --- Oal' 2/21/98 dlY of MY COMMI"KlN EXPI~_.___ _ I ACXNOWlEDOE RECEIPT Of THE 'lI8ftIFF'1 REYUftN 8lGNATUftl Of AUTHOAllfD ISSUING AUTttOAITY AND TlTI.E, IHlRIFF Of AbAIII COUNTY ---.._-------.-..---~--_.__.._--~-_.._.. ..--..--....-------....'L----- 39, Dale Reotlved -..~..._'_._~.__.,,--,----- .-...... ~-._--_.._~.---_._-.-.._-. ~ co ~~ c ~r.;;? N ~.., ~ ~~ Jf.U -,. 0- .L'r:' C'l,"-, z ~f c .,t o. N "J C'lll CI.. ~~ L...t:. 1.4.1 ,., "" u. en a C) a-. . . , ;' L ~ eo ~~ f? 0 .. " ~~Q N . eJ :r; Wt Q.. ~'I is ,; 0 6.1"':: ~3 . " N jt., f[ l'"~ ~ ~ ~~ ~.. '" d .\ 0'\ , Ii A , .' ..... , ,., Q:) ~ ~ Cl ~Q N :::l~ ~I (:~ iE ~~~ 0 ,-, N 5 J"- ~, it 11' ~ F' ~ ~ Q\ Q\ , II '" , " ..,... f ~ co ~ 0 1-'. ," ~~~ N g~ .. ('~\ x: ~~~ ftr c... S)~., fill). 0 ~i u N rtl',.' 0.. l"1 l1J f.:' V> I.e. 0> d 0 0' .- .... i , "l .