Loading...
HomeMy WebLinkAbout98-00987 fi o c3 I I , ! I I ~i \~ I I ,~ f\ : ,rlixl ":~, f' itdi,' '.,,;", ;:;',~l': '~';" ,,'?r:t)) ~t .)1 .~ ; ,,',";~~i~< ,r";, ',,:~;: '( ,:',~i :<'~i~ ,;'-)/ "'''~ -,',;i~"j !>.tfx ,\~~ ~\iJ, ,/{' ~ ':./'" .'..,', r () U . / . ,i:_"~; ~;..'t 0~~ '(~\'; , ,/i :;/-t~ :_(~;;fi ,'/':~ .-- - .~ ~q'-' - '-J ,.,.'" t-- C>.. t;.)-.. ,.,1", ';;,~. ,'1 ';:" '\~F , ;~; I 0- ~. ',>:; t;.j '.-'."~' .:+:. .:.:.. I:.:' ':.:"':+:' .:.:. .:+:. .:+:. .:.:' .:+:. .:<<..:+:. ';+:0' .:+:. t:+:' .:+:. -:.:. .:+:. .:.:. -:.:..:.~..:.:.:...:.:.::.:.:.:._.:.:..~':.:.- .:+:. .:+:.' .:.:.:~.:.:~:.;~ ~ .. -..-...-. -..--.-- ----- --- -. ---- I !e!: ~ . ~ ^ X ~ ~ ~., ~ ,', ~ ~ ,', ~ ,', ~ ~ ~.' ~', ~ ~ ',' ,', ~ ;i: ~.' ,', ~ ~ ~.' ,,~ ~ ,'~ ~ l' ,', ~ ~ '.' ~ ~.~ ~ ~.~ ~ ,', ,', ~ ~ ,', ~ w ~.~ ,', ~ ~.~ ~ ~ ~.~ ~ ... ~ ~.' ~', ~ IN THE COURT OF COMMON PLEAS ,', * ,'~ ~ ~ ',' OF CUMBERLAND COUNTY ~ '.' STATE OF ~~l':t it~!~~. ~ ..,.. "1. ,"',"V!~...,,'r ~ ~.~ ,.; ~ ~ '.' PENNA. LAWRENCE,M...COONEY . Plaintiff II 'i N (). ",9.B.",9.B7.."Ci.vtL""" It) .1 'I .', * ~ ',' VCI'.-;US ~ ~.: ~ ,~ENNIFERA.. COONEY I ! ~ ~.' ~ !~ ~ ...Defendant " DECREE IN D I V 0 R C E .....t ,o:~oA.~. AND NOW, ....',. ,t:?~..'.,...,.., 19 !.~,.. it is ordered and *- ~.# ~.; ~ ~ '.' ~ ~.' ,:. ~ decreed that.... Lawrence. M-.. .Cooney...........".........., plaintiff, and. . . . . J.enoif,er. A,.. .Cooney. ., . , . . . . . . . . . . . . , , , . . . . . . . , . " defendant, are divorced from the bonds of matrimony, ~ ~.~ ~.~ ~ ~ ~ ~ The court retains jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; ~ * ~ '.' ,'l'be. ,parties ~. September. .9, . 1.9.9B. Marria.ge. Settlement. .Agreement. .is .hereby. incorpora ted . but.. .not. ,merged. into. ' decree.' . . . . . . . . . . . ~ '.' * ,'. ~ ~ (: ~ .,' ~ ~.~ ~ ~.~ ~ ~ ~ ~ ~ ~- ,...:' '..:. ':.0:' .:.0:' ':~:. ':.' ~ * ~ s Atl~~l; dt~~i).b>>~ ~n%"N"~ 'P .~),.t' y, c1s2&, g/.. '." - /- Ttj;~olhonotnry J, s ~ ~ '.' ....-....-..._~...-------~--~~._--~~,.--_.~ ..-, ~..,.-..---~.--,_.~.-. ~ ~.~ ,,-, ~----. ~ ,-" ,.'~ -, I~ ~--~-~~~*~---***~**-*~*~. . /?/;.;/.~~ dv!- d7P,/Jn~ ~4*'4~ .I,!) <:..;:1 .f-;j ~ /~~d ?%~_ , DIANE G, RADCLIFF 3448 TRINDLE ROAO CAMP HILL, PA 17011 17171737-0100 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 distribution 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 consideration of the premises and mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of 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 herein and made a part hereof as if fully set forth in the body of the Agreement, 2. AGREEMENT NOT A BAR TO DIVORCE PROCEEDINGS: This Agreement shall not be considered to affect or bar the right of HUSBAND and WIFE to an absolute divorce on lawful grounds if such grounds now exist 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 occur subsequent to the date hereof. Page 2 of 23 DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 17171737.0100 3 . DIYORClLDE.CREE.l. The parties acknowledge that their marriage is irretrievably broken and that they will secure a mutual consent no-fault divorce decree in the above captioned divorce action. 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 and Waiver of Notice forms, necessary to finalize said divorce, If either party fails 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, 5. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE: The terms of this Agreement shall be incorporated into any Divorce Decree which may be entered with respect to them, 6, NON-MERGER.:. 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, Page 3 of 23 DIANE Q, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (7171737,0100 7, DATE_OZ-EXEQUTION: 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 . D.IS.TRIBl1'l'ION-DATa:. 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. VOLUNTARLEXECUTIOH-ANlL.EAIRNESS OF AGREEMEN'l'.l. Each party acknowledges that this Agreement has been entered into of his or her own volition, with full knowledge of the facts and full disclosure of their separate and joint estates, and that each believes this Agreement to be reasonable under the circumstances, Further, WIFE acknowledges that she has been advised of her right to be advised by an attorney of her own choosing prior to entering into this Agreement and that she has sought and received said advice from independent legal counselor has voluntarily decided not to retain such counsel, and further acknowledges that she accepts said Agreement and that said acceptance is not based on any advice or representation made by HUSBAND'S counsel, Diane G, Radcliff, Esquire, nor has any such advice and/or representation been given to WIFE by said counsel, 10, FINANCIAL DISCLOSURE: The parties confirm that each has relied on the substantial accuracy of the financial disclosure of the other, as an inducement to the execution of this Agreement and each party acknowledges that there has been a full and fair Page 4 of 23 DIANE Q, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 17171737-0100 disclosure of the parties' marital assets which has been provided to each party, 11 , IUliCLOS.'l1RILANDJlAI:\lER-QF-ERQCEIlURAL_RI.GH'l'S.l. 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 by 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 decision concerning the parties' respective rights and obligations might be different from the provisions of this Agreement, 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, 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, except in instances where said income and expense statement is hereafter required to be filed in any child Page 5 of 23 support action or in any other proceedings pursuant to an order of court, c, The right to have any discovery as may be permitted by the Rules of Civil Procedure, except discovery arising out of a breach of this Agreement, out of any child support action, 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 distribute between the parties that property court determines to be marital, equitably which the e. The right to have the court decide any other rights, remedies / privileges, or obligations covered by this Agreement, including, but not limited to, possible claims for divorce, spousal support, alimony, alimony pendente lite (temporary alimony), and counsel fees, costs and expenses, 12. PERSONAL PRQEE~ HUSBAND and WIFE do hereby acknowledge that they have previously agreed to a division of their tangible personal property including, but without limitation, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, tools, pictures, books, works of art and other personal property, Hereafter WIFE agrees that all of the property previously agreed to be distributed to HUSBAND shall be the sole and separate property of HUSBAND; and HUSBAND agrees that all of the property previously agreed to be distributed to WIFE shall be the sole and separate property of WIFE, The parties do hereby specifically waive, release, DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737,0100 Page 6 of 23 DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 1717)737'0100 renounce and forever abandon whatever claims, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other, 13 , AETER.:,ACQUIRED_ERO.EER'l'.Y_t Each of the parties shall hereafter own and enj oy, independently of any claim or right of the other, all property, tangible or intangible, real, personal or mixed, acquired by him or her, since February 23, 1998, the date of the parties' marital separation being the date of the filing of the divorce complaint in the above captioned action 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 forever 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, 14. DIVISION OF VElUCLEB-:. With respect to the vehicles owned by one or both of the parties, they agree as follows: a. 1995 Nissan Maxima, acquired by WIFE during the marriage with her pre-marital funds, shall be the sole and exclusive property of WIFE, b, 1993 Volvo 850, acquired by HUSBAND prior to the date of the marriage, shall be the sole and exclusive property of HUSBAND, The titles to said vehicles shall be executed by the parties, if appropriate, for effectuating transfer as herein provided on the date of execution of this Agreement and said executed titles shall be delivered to the proper party on the Page 7 of 23 DIANE Q, RADCLIFF 3448 TAINDLE ROAD CAMP HILL, PA 17011 (717)737'0100 distribution date, For purposes of this Paragraph 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 any vehicle is subject to a lien or encumbrance the party receiving said vehicle as his or her property shall take it subject to said lien and/or encumbrance and shall be solely responsible therefor and said party further agrees to indemnify, protect and save the other party harmless from said lien or encumbrance, Each of the parties hereto does specifically waive, release, renounce and forever abandon whatever right, title and interest they may have in the vehicles that shall become the sole and separate property of the other pursuant to the terms of this Paragraph, 15. DIVISION OF REAL-E~ The parties are the joint owners of a certain tract of real estate with improvements situate thereon known and numbered as 485 Woodcrest Drive, Mechanicsburg, Pennsylvania, Said real estate has an approximate value of $230,000,00 and is encumbered by a mortgage to Fleet Mortgage Company having an approximate balance of $160,000,00, The real estate was owned by HUSBAND prior to the date of the marriage and was transferred into the joint names of the parties at or shortly after the marriage, With respect to the real~he parties agree as follows: J:s1: (lUl) ,aJ ~ a, Upon WIFE'S receipt of the payment of $aQ,eee,ee from HUSBAND, WIFE shall make, execute and deliver all documents in the usual form conveying, transferring and granting to HUSBAND all of WIFE'S right, title and Page 8 of 23 interest in and to the real estate situate and known as 485 Woodcrest Drive, Mechanicsburg, Pennsylvania, and upon said transfer WIFE shall specifically waive, release, renounce and forever abandon all her right, title and interest therein, b, The said conveyance shall be free of all liens and encumbrances except the lien of the existing mortgage and shall be under and subject to any covenants and restrictions of record, HUSBAND shall hereinafter be c, solely responsible for the payment of the said mortgage, and shall indemnify, protect and save WIFE harmless therefrom, it being understood and agreed that the mortgage was obtained by HUSBAND prior to the date of the parties' marriage and is carried in his sole ~~and therefore WIFE has no liability thereunder. ~ar 7~ 1/ r-S;/}<J, r-o HUSBAND shall pay WIFE the sum of "$:;'tf, aea, 00 for her interests in the real estate and other marital assets being distributed pursuant to the terms of this Agreement, Said payment shall be made fifteen (15) days prior to WIFE'S closing on her purchase of a home but in no event any later than six (6) months from the date of this Agreement, The financing for said payment shall be obtained by HUSBAND by way of his securing a home equity loan which shall be a lien against the Real Estate, WIFE shall cooperate with HUSBAND in transferring the Real Estate into HUSBAND'S sole name so as to enable him to obtain the home equity loan financing for said payment within such a time and in such a fashion so that concurrently wi th the closing of that financing, WIFE DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (7171737-0100 Page 9 of 23 ! ' ~~1} )-! ~ ; .~!4 ...., 't~ ~ '~ ~ i ~~1 ~~~~ ~ of. ~ ~~ :}~ ....c.-.3'~~ ~~o ( DIANE G, RADCLIFF 3448 TRINDlE ROAD CAMP Hill, PA 17011 (717)737,0100 16. shall transfer her interests in the real e' .j 'JJ, t/A' ' (/oJ shall make the $"~, ' HUSBAND and HUSBAND aforesaid, To facilitate the foregoing, it is understood and agreed that WIFE shall deliver the executed conveyancing deed to HUSBAND'S attorney or before the date of HUSBAND'S closing on the said financing, which deed shall be held in escrow by HUSBAND'S attorney and shall not be recor~d distribution of the sing is completed and ent aforesaid is made to WIFE. d, WIFE shall have a reasonable period of time not to exceed six months to find alternative housing before she shall be required to vacate the real estate, This time period may be extended based on mutual EAClLEARTY RETAINS OWN PENSIO Each of the parties 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, Keogh Plan, Stock Plan, Tax Deferred Savings Plan, IRA Account or Plan and/or any employee benefit plan 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 plan shall become the sole and separate property of the party in which name or through whose employment said plan is carried. With respect to the foregoing it is understood and agree that the following distributions shall apply: a. Distribution to HUSBAND: Page 10 of 23 1. HUSBAND'S pre-marital Charles schwab IRJ\ account having an estimated value of $45,000,00; 2 . HUSBAND'S marital InSource IRA/401K type plan having an estimated value of $4,000,00 b. Distribution to WIFE: 17, 1, WIFE'S pre-marital Travelers and Lincoln National Annuity having an estimated value of $60,000,00 IllYISION OF BANlLAC.QOllN'l'.S/..s.'ro.CKLLIFE INS!1RANCE.:. The parties acknowledge and agree that they have previously divided to their mutual satisfaction all of their bank accounts, certificates of deposit, bonds, shares of stock, investment plans and life insurance cash value and hereafter WIFE agrees that all said bank accounts, certificates of deposit, IRA accounts, bonds, shares of stock, ,. , . l l , , investment plans and life insurance cash value in the , .1 , possession of HUSBAND shall become the sole and separate I property of HUSBAND; and HUSBAND agrees that all the said i bank accounts, certificates of deposit, IRA accounts, bonds, shares of stock, investment plans and life insurance cash value in the possession of WIFE shall become the sole and separate property of WIFE, Each of the parties does specifically waive, release, renounce and forever abandon whatever right, title, interest or claim, he or she may have in any bank account, certificates of deposit, IRA accounts, bonds, shares of stock, investment plans and life insurance cash value that is to become the sole and separate property of the other pursuant to the terms hereof, With respect to the foregoing it is understood and agreed that the following distributions shall apply: DIANE Q, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 1717) 737-0100 Page 11 of 23 i ,~ DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737,0100 a. HUSBAND'S premarital Charles Schwab stock account having an estimated value of $5,000,00 shall be distributed to HUSBAND, b, WIFE'S pre-marital Charles Schwab stock account and any other stocks and bonds and money market accounts held in her individual name having an estimated value of between $20,000,00 and $35,000,00 shall be distributed to WIFE; c, The parties' respective individually held CoreStates checking and savings accounts shall be distributed to the party in whose name the account is held, It is estimated that as of the date of the filing of this action WIFE'S accounts had an estimated value of $2,000,00 and HUSBAND'S accounts had an estimated value of $4,000,00, 18. WAIVER OF INTEREST IN BUSINE~ The parties acknowledge that each party is the owner, in pert or in whole, either individually or as a stock holder, of a separate consulting business, It is further acknowledged that said businesses have no real tangible value subject to distribution between the parties since they do not have many fixed assets and all good will emanates from the professional good will resulting from the party's personal professional reputation and not from any general reputation as a going concern, Each of the parties, therefore, does specifically waive, release, renounce and forever abandon any right, title, interest and claim, if any, either party may have in and to the business or business interest owned by the other party, 19, WAIVER OF INHERITANCE: Each of the parties hereto does specifically waive, release, renounce and forever abandon any right, title, Page 12 of 23 DIANE G, RADCLIFF 3448 TRINDlE ROAD CAMP Hill, PA 17011 17171737,0100 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, 2 0 . l'llFE_'_S....DEB'l'S_1. WIFE represents and warrants to HUSBAND that since the parties' marital separation 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, 21. HUSBAND'S DEBTS: HUSBAND represents and warrants to WIFE that since the parties' marital separation he has not contracted or incurred any debt or liability for which WIFE or her estate might be responsible and HUSBAND further represents and warrants to WIFE that he will not contract 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 harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him, 22. MARITAL DE~ During the course of the marriage, HUSBAND and WIFE have incurred certain bills and obligations and have amassed a variety of debts, and it is hereby agreed, without Page 13 of 23 ascertaining for what purpose and to whose use each of the bills were incurred, the parties agree as follows: a. WIFE shall be solely responsible for the following bills and debts: 1. Any credi t card accounts / loans and other debts held in WIFE/S sole name. b. HUSBAND shall be solely responsible for the following bills and debts: 1. Any credi t card accounts / loans and other debts held in HUSBAND' S sole name, including but not limited to HUSBAND' S CoreStates debt having an approximate balance of $10/000,00 Each party agrees to hold the other harmless from any and all liability which may arise from the aforesaid bills which pursuant to the terms herein are not the responsibility of the other party, Any joint debt shall be canceled so that neither party can make any further charges thereunder and if said charges are made in violation of this Agreement than the party incurring said charge shall immediately repay the same, Any liability not disclosed in this agreement shall be the sole responsibility of the party 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 provide for joint liability, DIANE G, RADCLIFF 3448 TRINDlE ROAD CAMP Hill, PA 17011 1717} 737,0100 Page 14 of 23 23. BANKRU~T~Y: The parties 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 files such bankruptcy and pursuant thereto obtains a discharge of any obligations assumed hereunder, the other party shall have the right to terminate this Agreement in which event the division of the parties I 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, 24. ~lLRE'I'.URNB.:. The parties have heretofore filed joint 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 loss or liability for any such tax deficiency or assessment therewith, Such tax, interest, penalty or expense shall be paid solely and entirely by the individual who is finally determined to be the cause of the misrepresentations or failures to disclose the nature and extent of his or her separate income on the aforesaid joint returns, 25. EIN~L EOUITABLE DISTRIBUTION OF PROPERTY: The parties agree that the division of all property set forth in this Agreement is equitable and in the event an action in divorce is commenced, 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, DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737,0100 Page 15 of 23 J -3- ~ oN -4. ~ ~t~~ ~ ~ Ii~ ,{~~ f~~~ ~ ~"'~ ~' ' ~~~ ~ 'Sl\. ~ ~ ~ ::t 5 ,'-' ~ ~ , -{:. t:"- 'r ~ ~~~. "- ~ ~ --{: ~~4~ DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737,0100 understanding and agreement of the parties that this Agreement is a full, final, complete and equitable property division. WAI.V..ElLOE-ALIMONY.,J~USAL_S.UP.E.QRT-ANlLQO.5'l'S.J. The parties hereto agree and do hereby waive any right and/or claim they may have, both now and in the future, against the other for alimony, alimony pendente lite, spousal support, maintenance, counsel fees and costs, HEAL'I'ILJ:NB.lIRANCE.J. HUSBAND shall continue to provide health insurance coverage on WIFE as it exists as of the date of this Agreement until the date of the entry of a decree in divorce between the parties, Thereafter WIFE shall be entitled to continued COBRA coverage under HUSBAND'S health insurance policy as provided for by law provided that she pays the costs of said coverage in a timely fashion, EERSONAL RIGHTS. live shall, at all times hereafter, They shall be free from any control, or authority, direct or indirect, by er in all respects as fully as if they were unmarried. HUSBAND and the They may reside at such 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. HUSBAND and WIFE shall not molest, harass, disturb or malign each other or the respective families of each other nor compel or attempt to compel the other to cohabit or dwell by any means or in any manner whatsoever with him or her, Page 16 of 23 27. MU'I-UAL_REI.EASES.1. 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 against such other, the estate of such other or any part thereof, whether arising out of any former acts, contracts, engagements or liabilities of such other or by way of dower or 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 testamentary, 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 of territory of the united States, or (cl any other country, or any rights which either party may have or at any time hereafter have 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 provision thereof, It is DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717)737,0100 Page 17 of 23 the intention of HUSBAND and WIFE to give to each other by the execution of this Agreement a full, complete and general release with respect to any and all property of any kind or nature, real, personal or mixed, which the other now owns or may hereafter acquire, except and only except all rights and agreements and obligations of whatsoever nature arising or which may arise under this Agreement or for the breach of any provisions thereof, 28. WAIVER OR MODIEICA~ON TO BE IH-WR~ 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 any subsequent default of the same or similar nature, 29 , MUTUAL COOPERA~ONJ.. 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 reasonably require for the purpose of giving full force and effect to the provisions of this Agreement, 30 . AGREID<lENT BINDIlliLON 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,~ This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717)737,0100 Page 18 of 23 .\, ( ': t.,' , .' I' 1/1 1)1 1/ It! I '" l l) fi ; I i ~ I" , I I~ I i i I r negotiations between them, There are no representations or warranties other than those expressly set forth herein, 32, O.THEIU10_C_l1MENTA'l'ION.:, 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 instruments, assignments, releases, satisfactions, deeds, notes, stock certificates, or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry out fully and effectively the terms of this Agreement, 33. NO WAnlER OF DEFAUL'l'..t 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 enforce the same, nor shall the waiver of any subsequent default of the same or similar nature, nor shall it be construed as a waiver 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 DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (7171737,0100 Page 19 of 23 DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (7171737,0100 have an inconsistent result or would result in a windfall 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 I s fees and costs incurred as the resul t 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, which damages shall include reimbursement of all attorney's fees and costs incurred as the result of the breach and in bringing the damage action, c. the right to all remedies set forth in Section 3502(e) of the Pennsylvania Divorce Code, 23 Pa, C.S,A, 3502(e), an any additional rights and remedies that may hereafter be enacted by virtue of the amendment of said Section or replacement thereof by any other similar laws, which remedies shall include, but not limited to: 1, the entry of judgment; 2. the authorization of the taking and seizure of goods and chattels and collection of rents and profits of real and personal and tangible and intangible property; 3. the award of interest on any unpaid installment; 4. the transfer and sale of any property required to obtain compliance with the obligations undertaken by this Agreement; Page 20 of 23 5, the posting of security to insure future payments to compliance the obligations assure with undertaken by this Agreement; 6, the issuance of attachment proceedings and the holding of the breaching party to be in contempt and the making of appropriate order therefor including, but not limited to, commitment of the breaching party to county jail for a period not to exceed six (6) months, the award of counsel fees and costs, 7, 8. the attachment of the breaching party's wages. d. Any other remedies provided for in law or in equity, 35. LAW OF PENNSYLVANIA 1I.EELICABLE..:.. This Agreement shall be construed in accordance with the laws of the Commonwealth of Pennsylvania, 36. SEVERABILITY: If any term, condition, clause or provision of this Agreement shall be determined or declared to be void or invalid in law or otherwise, then only that term, condition clause or provision shall be stricken from this Agreement and in all other respects this Agreement shall remain valid and continue in full force, effect and operation, Likewise, the failure of either party to meet his or her obligations under this Agreement under anyone or more of the paragraphs hereunder, with the exception of the satisfaction of a condition precedent, shall in no way avoid or alter the remaining obligations of the parties, DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737-0100 Page 21 of 23 t, I': : ,j .'1. " , ,. ), ) r I ~ 1 J I, f! 'I I I '{ ~ ., I i !~ "', 37 . HEADINGSJroLPART-O.F-AGREEMEN'X-.:. Any headings preceding the text of the several paragraphs and subparagraphs hereof, are inserted solely for convenience of reference and shall not constitute a part of this Agreement nor shall they affect its meaning, construction or effect, ; ! ., , BY SIGNING THIS AGREEMENT, EACH PARTY ACKNOWL~DGES HAVING READ AND UNDERSTOOD THE ENTIRE AGREEMENT, AND EACH PARTY ACKNOWLEDGES THAT THE PROVISIONS OF THIS AGREEMENT SHALL BE AS BINDING UPON THE PARTIES AS IF THEY WERE ORDERED BY THE COURT AFTER A FULL HEARING. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the day and year first above written, WITNESS: 11)/1/ ~ (SEAL) ALl . N '--r DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (7171737,0100 Page 22 of 23 COMMONWEALT~ OF PENNSYLVANIA COUNTY OF .Ulltll'l)/,v SS, On this the /6 yt.. day of .k/)(J..L ,19 '6 , before me the undersigned officer, personafly appeared, JENNIFER A, COONEY, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement / and acknowledged that JENNIFER A, COONEY executed the sam!o! for the purposes therein contained, IN WITNESS WHEREOF, I hereunto set my hand and notarial seal, NOTARIAL Sl:Al NANCY E, ROACH, Notary Public Horrhburo, Dauphin County, PA My CommlnJon Ekplrel Jon. 29, 2001 L /) /; P /. ;?' rJ-" ~' / -/; '--' c;: NOT1\: Y PUBLIC / / My Commission Expires: //:1:; j.J/ COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS, On this the g'U\.,day of &-P~b-vr.-, 19 <JS' ,before me the undersigned officer, personally appeared, LAWRENCE M, COONEY, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within Agreement, and acknowledged that LAWRENCE M, COONEY executed the same for the purposes therein contained, IN WITNESS WHEREOF, I have hereunto set my hand and notarial seal, ?1~P2L:~ DIANE G, RADCLIFF 3448 lRINDLE ROAD CAMP HILL, PA 17011 17171737,0100 ission Expires: tJoI,"Hi1! Senl 1 !nmmy J. F:J:I~.I":IJI)' PuIJIIc: M.lrJdr'.ltl.'wn Ur,f,l, D~u,.hln r.~unly J M~ Ccrr:mic;r:lon EX[Jl((.r, Stir,!. 21, 1993 M~.m:....'f'. P(j(1.15'j.vJrj,1/'U:'''~i1i!):l of t.J.:t.:.1f.c'i Page 23 of 23 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PEIlNSYLVANIA LAWRENCE M, COONEY Plaintiff v, NO, 98-987 civil Term JENNIFER A, COONEY Defendant CIVIL ACTION - LAW DIVORCE PRAECIPE OF TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: 1, Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code, 2, Date of filing and manner of service of the complaint: a, Date: February 23, 1998 b, Manner: Acceptance of Service 3. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: a, Plaintiff: September 9, 1998 b, Defendant: September 16, 1998 OR Date of execution of the Plaintiff' s affidavit required by Section 3301(d) of the Divorce Code and date of service of the Plaintiff's 3301 (d) affidavit upon the Defendant: a, Date of execution: nla b, Date of filing: nla c, Date of service: nl a 4, Related claims pending: No issues are pending, All issues have been resolved pursuant to the Marriage Settlement Agreement between the parties dated September 9, 1998 which Agreement is to be incorporated into but not merged with the Divorce Decree, 5. Date and manner of service of the Notice of Intention to file Praecipe to Transmit Record, a copy of which is attached, if the decree is to be entered under Section 3301(d) (1) (i) of the Divorce Code: a, Date of Service: nla b, Manner of Service: nla Date Waiver of Prothonotary: a, Plaintiff's b, Defendant's OR Notice in Section 3301 (c) Divorce was filed with the Waiver: Waiver: September 9, 1998 ~,~-------.". ') September :L6.,_D198 "_ -- \ DIANE G, CLIFF-,-ES ......lJtj Tr1nn1'e- oad \~ Hill, .~. 17011 Supreme-Court ID # 32112 Phone: (717) 737-0100 Fax: (717) 975-0697 Attorney for Plaintiff I ~ -' ~ C'J ~ 8 ::;t4~. ,- 9- O~., - 0-:;' 't\ ~~ :;}::. .~ ~~ ~ (:):3 ,-,?ii l~~: 0::' '.1_ C'J .}~;.; 0\.\ \ii(es -Ju' 0- ~C) 0.. rc-I_ \.LJ ,<; {.. cr. .~ q- r;c ';:.l 0 c;I'I (.) .. " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAWRENCE M, COONEY Plaintiff v. NO. q r - (IS' 'J 0..~.J-C,-, CIVIL ACTION - LAW DIVORCE JENNIFER A. COONEY Defendant NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff, You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE O~' DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU C,~ GET LEGAL HELP. Court Administrator Cumberland County Courthouse One Courthouse Square Carlisle, PA 17013 (717) 240-6200 DIANE G, RADCLIFF 344BTRINDLE ROAD CAMP HILL, PA 17011 (717) 737.0100 " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAWRENCE M. COONEY Plaintiff v. NO, (J f, '/ S' 7 e,~(.(l '0..... CIVIL ACTION - LAW DIVORCE COMPLAINT JENNIFER A. COONEY Defendant AND NOW, this ~ay of February 1998, comes the Plaintiff, LAWRENCE M. COONEY, by his attorney, DIANE G. RADCLIFF, ESQUIRE, and files this Complaint in Divorce of which the following is a statement: COUNT I: DIVORCE 1. The Plaintiff is LAWRENCE M. COONEY, an adult individual residing at 485 Woodcrest Drive, Mechanicsburg, Pennsylvania, since 1992, 2. The Defendant is JENNIFER A. COONEY, an adult individual residing at 485 Woodcrest Drive, Mechanicsburg, Pennsylvania, since 1995. 3. Plaintiff and/or Defendant have been bona fide residents of the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on June 6, 1995 at Middleburg, Virginia. 5. There have been no prior actions of divorce or annulment between the parties. - 2- 6, Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7, The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8, The Plaintiff avers that the grounds on which the action is based are: a. That the marriage is irretrievably broken; Or in the alternative, b. That the parties are now living separate and apart, and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. i /"., COUNT II: EQUITABLE DISTRIBUTION 9. Paragraphs 1 through 8 are incorporated by reference hereto as fully as though the same were set forth at length. 10. Plaintiff and Defendant have acquired property and debts, both real and personal, during their marriage from June 6, 1995 until the date of separation, all of which is "marital property". 11, Plaintiff and/or Defendant have acquired, prior to the marriage or subsequent thereto, "non-marital property" which has increased in value since the date of marriage and/or DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (7171737,0100 - 3 - " subsequent to its acquisition during the marriage, which increase in value is "marital property". 12, Plaintiff and Defendant have been unable to agree as to an equitable division of said property as of the date of the filing of this Complaint, Respectfully submitted, WHEREFORE, Plaintiff requests this Honorable Court to equitably divide all marital property and debts of the parties. , CI , PA 17011 -0100 Attorney for Plaintiff I.D. No. 32112 f , '"~ ,~ I , I' ~ : , I, 'i DIANE G, RADCLIFF 3448 TRINDlE ROAD CAMP Hill, PA 17011 (717) 737.0100 - 4- , '. , ,. , \....,. IN THE COURT OP COMMON PLEAS OP CUMBERLAND COUNTY, PENNSYLVANIA LAWRENCE M, COONEY Plaintiff v. NO, 98-987 civil Term CIVIL ACTION - LAW DIVORCE JENNIPER A, COONEY Defendant AEF-IDAV.1LOE-CONSENT A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on pebruary 23, 1998, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint, 3, I consent to the entry of a final Decree in Divorce after 1. 2 , service of notice of intention to request entry of the decree, I verify that the statements made in this Affidavit are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa, C,S, Section 4904 relating to unsworn falsification to authorities, Dated: 7~q LAWREN DIANE Q, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (7171737,0100 '\' f " L: , i' L ,~ J ) J ' ,. , J J I , I l , >- ~ a:; N .", ,- e :.:)..,- IJJR '.:.J .:..~. Q(-) :.c ;:.):z tt"j.: ...:.~ r:) :::. 01.' c' :.:-s.. 6,., 0:' .~c.n WIJ. N ~:1 ;:-: ~~l., (,- -.... 0... tti to r~ lIJ ~.~n_ v: w- ee ::'5 .0 0' u IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAWRENCE M, COONEY plaint if f v, NO, 98-987 Civil Term JENNIFER A, COONEY Defendant CIVIL ACTION - LAW DIVORCE ~FFIDAVIT OF CONSENT 1, A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on February 23, 1998, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3, I consent to the entry of a final Decree in Divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this Affidavit are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa, C.S. Section 4904 relating to unsworn falsification to authorities, Dated: e1!k/'W I ' ,I '- c(l r~~ iT.: '" " i':=: 2: ~..~) ...<l' UJI,:'~ '. J , C)(: - ) " ::i: .; . ~ ! - r-' . .:~ .- - . .- .--' c;.i ( ,- '0 i.'? Ii' I.: , " I::. t" , " , ....:jll. rr: ~ ; -II~ ij CL_ ;1 ;:; ~1- ," 0::: 1.'- m :j 0 0' u , . ~ [i >- <::) G ~ N .- .- e :::i"", 0 ";1-- ():i~! C. -i. WU ..... C):~ '"?:= ,< .'- Ci ::; Clc, ;.,... ~. C,.L 0:> .;(i/) tub.. c" ,";..- -hI' Q.. ',"1::.-2 fL..I' uJ ~~liE (-; on I:i CO .::.) 0'> lJ ~ , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAWRENCE M, COONEY plaintiff v, NO, 98-987 Civil Term CIVIL ACTION - LAW DIVORCE JENNIFER A, COONEY Defendant WA TVERO_F N.?JTC'E OF TNTF:NTTON TO RF:OtlEST F:NTRV OF A DTj VORC'F: DEC'RF:F: tlNDER SF:CTIQN 3301 IG. OF THF: DTVORC'F: C'ODE 1, I consent to the entry of a final decree in divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted, 3, I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary, I verify that the statements made in this Affidavit are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa,C.S, Section 4904 relating to unsworn falsification to authorities, Dated: 'l/i/fA DIANE G, RADCLIFF 3448 TRINDLE ROAO CAMP HILL, PA 17011 (717)737-0100 >- t= I 0:; ,,, t== /. , c 8 ::l...,! \ lJJ.. ~ r')-. ~z.2r,,:, ..- (:,~ I ..1.-. u_~. <.: '-". '.1-,.:- q;:j q'" ( .~ 0:> :'~i;~~ C\r~: Ujtl. ('oj j'::;'-': E~l:~\ .1-. ".llI.J F 1.>' 1'..IU... U) ~":..;: lI. e:) :5 0 "" u ! 1 DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717)737'0100 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAWRENCE M, COONEY Plaintiff v. NO, 98-987 Civil Term CIVIL ACTION - LAW DIVORCE JENNIFER A, COONEY Defendant NADlER OF N01:LCE OF INTENTION TO RROURSX ENTRY OF A DTVORC~ QRCRRE IrnDRR SECTION 3301 leI OF TH~ QI~RCE CODR 1, I consent to the entry of a final decree in divorce without notice, 2, I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted, 3, I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary, I verify that the statements made in this Affidavit are true and correct, I understand that false statements herein are made subject to the penalties of 18 Pa,C,S, Section 4904 relating to unsworn falsification to authorities, Dated: 016 vr ~~~ '>- -' >- iT. C'o.! c- ,.,.: ,.. 1- .. :;5.,; 0 9 ~'_" f~~.. _2("') , .).r.:~ ..'.- - c,= H--of -...( ('"\:":1 i'il- .... '.- f-: 17.' -'fn it; ':1:'-:: ~ N --~, (C:;....: 0., ; ~II.U U~:i.. uJ ;.t:!(.\.. I- v, ::5 IJ.. m 0 0" (,) '. '.-,.....,.. ,r t........l . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LAWRENCE M, COONEY plaintiff v, NO, 98-987 civil Term CIVIL ACTION - LAW DIVORCE JENNIFER A, COONEY Defendant CERTIFICATION OF SOCI~L SECURITY NlnffiERS In accordance with the Rules of Civil procedure, I, Diane G, Radcliff, Esquire, Attorney for the plaintiff, hereby certify that the social security numbers of the parties are as follows: 1- 2. plaintiff, Lawrence M. Cooney: Defendant, Jennifer A, Cooney: 163-54-0324. Unknown, .,--- Respectfully submitted, C------....., I \ DIANE G, RADCLIFF 3448 TRINDLE ROAD CAMP HILL, PA 17011 (717) 737,0100 >- E ~ N "'"- 1-- 0 :::J.,C UJ9. ()7 Oc:; ::r: O~;: fE2~ -< CI;:J ~C) 0:' :'~[i; I- (.I; N - "'- wu.. (t: ;? cEll.: c.. "..,0 ~ LW c..:) a.. I~" Ch ~;: 1.1- r.o ;:? 0 en U , ~- (>OJ ~ ~ !?: , 1- -:J f:-:; /,JJp c'\) ..~.~;." - ~ f;?6i .-- " ~ ,'.J,-:,~L . '. ".).' '\) <;JC; f.~ ..... CHi' 0:. ;: ,,~.I ...... l Li'l..r' !.;-.j:~:~i Ei!/I. I ~ 'if. f!: 0:.) 4.J '., .',- ~ "'/ IJ. t...: ,:)i1:.' r~ 0 r.r. ...... en ::j ()