HomeMy WebLinkAbout00-05390
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
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PENNA.
STATE OF
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DECREE IN
DIVORCE
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, 2 <'>0 ( , IT IS ORDERED AND
AND NOW,
DECREED THAT
JOSEPH O. RAILING, JR.
PLAI NTI FF,
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AND
SANDRA K. RAILING
, DEFENDANT,
ARE DiVORCED FROM THE BONDS OF MATRIMONY.
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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;
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THE PROPERTY SETTLEMENT AND SEPARATION AGREEMENT SIGNED BY THE
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PARTIES ON JANUARY 17, 2001 IS INCORPORATED HEREIN AS A FINAL
ORDER OF COURT.
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ATTE J.
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P THONOTARY
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SAlOIS,
SHUFF &
MASLAND
ATI'OIlNEYSIAT'LAW
26 W. High Street
Carlisle. PA
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THIS
PROPERTY SETTLEMENT AND SEPARATION AGREEMENT
AGREEMENT made this /11"14 day of jJSt.,/U~11
2011
between Joseph O. Railing, Jr., of Carlisle, Cumberland County,
Pennsylvania, hereinafter referred to as Husband,
A
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Sandra K. Railing, of Carlisle, Cumberland County, Pennsylvania,
hereinafter referred to as Wife.
WITNESSETH:
WHEREAS, in consequence of disputes and unhappy
differences, the parties have been living separate and apart
from each other; and
WHEREAS, the parties desire to confirm their separation and
make arrangements therewith, including the division of their
marital property and other rights and obligations growing out of
their marriage.
NOW THEREFORE, in consideration of the covenants and
promises hereinafter to be mutually kept and performed by each
party, as well as for other good and valuable consideration and
intending to be legally bound it is agreed as follows:
(1) It shall be lawful for each party at all times
hereafter to live separate and apart from the other party at
such place or places as he or she from time to time may choose
or deem fit.
1
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SAIDIS,
SHUFF &
MASLAND
A~AT'lAW
26 W. High Street
Carlisle. PA
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(2 )
Except as herein otherwise provided, each party hereby
releases the other from any and all claims, or demands up to the
date of execution hereof.
(3) The parties are the owners of certain real estate with
improvements thereon erected, known and numbered as 431 Walnut
Bottom Road, Carlisle, Cumberland County, Pennsylvania. The
property is currently under Agreement of Sale dated December 13,
2000, with settlement to be made on or before January 31, 2001.
Husband and Wife agree that upon the sale and settlement,
whether pursuant to the aforementioned contract or otherwise,
the proceeds from the sale of the real estate shall be divided
after the payment of all customary closing costs as follows:
A. Home Equity Loan in the approximate amount of seven
thousand, five hundred ($7,500.00) dollars which was
used to finance Husband's 1997 Mercury Sable.
B. The exact amount which is used to payoff the Home
Equity Loan shall be distributable to Wife.
C. The entire balance of the proceeds shall be divided
equally between Husband and Wife.
In the event settlement does not occur on January 31, 2001,
this paragraph shall continue to be binding and the parties
agree to actively market the real estate as recommended by their
realtor, Trisha Negley of Coldwell Banker Home Sales.
2
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SAlOIS,
SHUFF &
MASLAND
A~AT.LAW
26 W. High Slreet
Carlisle, PA
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(4) In the event that either party has contracted or
incurred any debts since June 1, 2000, the party who incurred
said debt shall be responsible for the payment thereof
regardless of the name in which the debt may have been incurred.
Husband and Wife acknowledge and agree that they have no
outstanding joint debts and obligations other than those secured
by the real estate. Debts secured by the real estate will be
paid in full at the time of settlement.
Each party agrees to pay any and all outstanding debts and
credit cards which are attributable to them and shall indemnify
the other and save the other harmless from any and all claims
and demands against them by reason of such debts or obligations.
(5) Each party relinquishes any right, title and interest
he or she may have to any and all motor vehicles currently in
the possession of the other party. Each party shall execute any
documents necessary to have said vehicles properly registered in
the other party's name with the Pennsylvania Department of
Transportation. Each party shall assume full responsibility of
any encumbrance on the motor vehicle received by said party, and
shall hold harmless and indemnify the other party from any loss
thereon.
(6) The parties hereto mutually agree that they will
effectuate a satisfactory division of the furniture, household
furnishings, appliances, tools and other household personal
3
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SAlOIS,
SHUFF &
MASLAND
ATIORNEYS.AT-LAW
26 W. High Street
Carlisle, PA
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property between them, and they mutually agree that each party
shall from and after the date of this agreement be the sole and
separate owner of all such property presently in his or her
possession or allocated to him or her whether said property was
heretofore owned jointly or individually by the parties hereto.
In particular, the attached list of property marked Exhibit "An
shall be the individual property of the Husband and the balance
of the property shall be divided approximately equally. In
addition, Wife shall make available to the Husband on or before
March 31, 2001, the plaid sofa and chair, the oak coat tree and
the darker wood, chiming wall clock all of which are in storage.
In the event Husband fails to get said items removed after Wife
provides a reasonable opportunity, this property shall become
sole and separate property of Wife. This Agreement shall have
the effect of an assignment or bill of sale from each party to
the other for such property as may be in the individual
possession of each of the parties hereto.
(7) Each party hereby relinquishes any right, title or
interest he or she may have in or to any intangible personal
property currently titled in the name of or in the possession of
the other party, including, but not limited to, stocks, bonds,
insurance, bank accounts and retirement accounts. This paragraph
specifically includes any and all retirement that either party
may have by reason of their employment, Husband at Carlisle
4
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SAID IS,
SHUFF &
MASLAND
ATfORNEYS'AT'lAW
26 W. High Street
Carlisle, PA
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Syntec and wife as a federal employee at the Navy Inventory
Control Point.
(8) Husband shall not pay to Wife nor Wife to Husband any
sum whatsoever as alimony, alimony pendente lite, or for his or
her support or maintenance.
(9) Each party is now represented by counsel of his or her
own choice, and each shall pay his or her own attorney fees
for all legal services rendered or to be rendered on his or her
behalf .
(10) Neither party shall contract or incur any debt or
liability for which the other party or his or her property or
estate may be responsible and shall indemnify and save the other
party harmless from any and all claims or demands made against
him or her by reason of debts or obligations incurred by the
other party.
(11) Each of the parties shall from time to time, at the
request of the other, execute, acknowledge and deliver to the
other party any and all further instruments that may be
reasonably required to give full force and effect to the
provision of this Agreement.
(12) The parties do hereby warrant, represent, acknowledge
and agree that each is fully and completely informed of, and is
familiar with, the wealth, real and personal property, estate
and assets, earnings and income of the other and that each has
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SAlOIS,
SHUFF &
MASLAND
ATI'Ol\NEYs.AT'lAW
26 W. lIigh Street
Carlisle, PA
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made a full and complete disclosure to the other of his and her
entire assets and liabilities and any further enumeration or
statement thereof in this Agreement is specifically waived.
(13) Husband and Wife acknowledge that each of them has
read and understand his and her rights and responsibilities
under this Agreement and that they have executed this Agreement
under no compulsion to do so but as a voluntary act.
(14) It is further specifically understood and agreed by
and between the parties hereto that each party accepts the
provisions herein made in lieu of and in full settlement and
satisfaction of any and all of said party's rights against the
other for past, present and future claims on account of support,
maintenance, alimony, alimony pendente lite, counsel fees, costs
and expenses, equitable distribution of marital property and any
other claims of each party, including all claims which have been
raised or may be raised in an action for divorce.
(15) Except as may be otherwise specifically provided in
this Agreement, Husband and Wife, for themselves, their heirs,
representatives and assigns, each hereby forever releases,
remises, discharges and quitclaims the other, and such other's
heirs, representatives, assigns and estate, from and with
respect to the following:
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SAIDIS,
SHUFF &
MASLAND
ATfORNEYSeAT.LAW
26 w. High Street
Carll.le. PA
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A. All liability, claims, causes of action, damages,
costs, contributions, expenses or demands whatsoever in law
or in equity;
B. All rights, title, interest or claims in or to any
property of the other, whether real, personal or mixed and
whether now owned or hereafter acquired;
C. All rights of curtesy and dower and all claims or
rights in the nature of curtesy and dower;
D. All widow or widower's rights;
E. All rights, title and interest or claims in or to
the other's estate, whether now owned or hereafter
acquired, including but not limited to all rights or
claims:
(1) To take against the other's will;
(2) Under the laws of intestacy;
(3) To a family exemption or similar allowances; an
(4) All other rights or authority to participate or
intervene in a deceased spouse's estate in any way,
whether arising under the laws of Pennsylvania or any
other country, territory, state or political
subdivision.
F. All rights or claims to any accounting;
G. All rights, claims, demands, liabilities and
obligations arising out of or in connection with the
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SAID IS,
SHUFF &
MASLAND
ATm1lNEYS-AT-LAW
26 W, High Street
Carlisle. PA
II
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marital relationship or the joint ownership of property,
whether real, personal or mixed;
H. All rights, claims, demands, liabilities and
obligations arising under the provisions of the
Pennsylvania Divorce Code, Act 26 of 1980, as the same may
be amended from time to time, and under the provisions of
any similar statute enacted by any other country, state,
territory or political subdivision;
I. All rights, claims, demands, liabilities and
obligations each party now has, or may hereafter have,
against or with respect to the other.
(16) This Agreement shall be construed under the law of the
Commonwealth of Pennsylvania. If any provision of this
Agreement is determined to be invalid or unenforceable, all
other provisions shall continue in full force and effect.
(17) In the event that either of the parties shall recover
a final judgment or decree of absolute divorce against the other
in a court of competent jurisdiction, the provisions of this
Agreement may be incorporated by reference or in substance but
shall not be merged into such judgment or decree and this
Agreement shall survive any such final judgment or decree of
absolute divorce and shall be entirely independent thereof.
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(18) Upon the execution of this Agreement, the parties shall
execute and file an Affidavit of Consent and Waiver of Notice
forms, necessary to finalize the divorce file to No. 2000-5390.
(19) In the event that either party breaches any provision
of this Agreement, and the other party retains counsel to assist
in enforcing the terms thereof, the parties hereby agree that
the breaching party will pay all attorney's fees, court costs
and expenses incurred by the other party in enforcing the
Agreement.
(20) This Agreement constitutes the entire understanding
between the parties and there are no covenants, conditions,
representations, or agreements, oral or written, of any nature
whatsoever, other than those herein contained.
(21) This Agreement shall bind the parties hereto, their
respective heirs, executors and assigns.
IN WITNESS WHEREOF, the parties hereto intending to be
. ~:.~a,llY boun~+-~ hereunto set
~~~tr~tten above.
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Wi~ss
their hands and seals the day
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JOSEPH O. RAILING, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2000-5390 CIVIL TERM
SANDRA K. RAILING,
Defendant
CIVIL ACTION-LAW
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record, together with the following information, to the court for entry of a
divorce decree:
1. Ground for divorce: irretrievable breakdown under Section 3301(c) of the divorce
code.
2. Date and manner of service of the complaint: Service upon the Defendant via
certified mail-restricted delivery on August 5, 2000.
3. (Complete either paragraph (a) or (b).)
(a) Date of execution of the affidavit of consent required under Section 3301(c) of the
divorce code: by the plaintiff Februarv 5. 2001
by the defendant January 24. 2001
(b) (1)
the divorce code
Date of execution of the plaintiff's affidavit required by Section 3301(d) of
N/A
(2)
Date of service of the plaintiff's affidavit upon the defendant
N/A
4.
Related claims pending
NONE
5. Complete either (a) or (b)
(a) Date and manner of service of the notice of intention to file praecipe to
transmit record, a copy of which is attached:
(b) Date plaintiff s waiver of notice in Section 330 1 (c) divorce was filed with the
February 12.2001
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Februarv 12. 2001 ~ c.- {
Prothonotary:
the Prothonotary:
David A. Baric, Esquire
Attorney for the Plaintiff, Joseph O. Railing, Jr.
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JOSEPH O. RAILING, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2000- 5390
CIVIL TERM
SANDRA K. RAILING,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
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 the 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 Court House, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE TillS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO
NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
(717) 249-3166
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JOSEPH O. RAILING, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2000- 53 <?()
CIVIL TERM
SANDRA K. RAILING,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
COMPLAINT UNDER SECTIONS 3301(C) AND
3301(0) OF THE DIVORCE CODE
1. Plaintiff is Joseph O. Railing, Jr., an adult individual who currently resides at 431
Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania.
2. Defendant is Sandra K. Railing, an adult individual who currently resides at 431
Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the Commonwealth of
Pennsylvania for at least six months immediately previous to the filing of this Complaint.
4. The Plaintiff and Defendant were married on September 18, 1997, in Cumberland
County, Pennsylvania.
COUNT I - DIVORCE
5. Plaintiff hereby incorporates by reference paragraphs 1 through 4 above.
6. There have been no prior actions of divorce or for annulment between the parties
as to their current marriage.
7. Neither Plaintiff nor Defendant is in the Armed Forces of the United States.
8. Plaintiff avers that the marriage between the parties is irretrievably broken.
9. The Plaintiff has been advised of the availability of counseling and that he may
have the right to request that the court require the parties to participate in counseling.
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WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree in
divorce.
COUNT II -EOUITABLE DISTRIBUTION
10. Plaintiff hereby incorporates by reference paragraphs 1 through 9 above.
11. The parties have acquired personal property, including automobiles, bank accounts
and other items of miscellaneous property during the course of their marriage, some of which is
marital property.
WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree
which effects an equitable distribution of marital property.
Respectfully submitted,
O'BRIEN, BARIC & SCHERER
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DATE: If /z.. / d?J
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David A. Baric, Esquire
17 West South Street
Carlisle, Pennsylvania 17013
(717) 249-6873
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VERIFICATION
I verify that the statements made in the foregoing Complaint are true and correct. I
understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~ 4904,
relating to unsworn falsification to authorities.
DATED: DB- 01- ~ocx)
11
JOSEPH O. RAILING, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2000-5390 CIVIL TERM
SANDRA K. RAILING,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
PLAINTIFF'S AFFIDAVIT OF CONSENT
AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE DECREE UNDER SECTION 330HC) OF THE DIVORCE CODE
1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on
August 2,2000.
2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety
days have elapsed from the date of the filing of the Complaint.
3. I consent to the entry of a [mal decree in divorce without notice.
4. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses in do not claim them before a divorce is granted.
5. I understand that I will not be divorced until a Divorce Decree is entered by the
Court and that a copy ofthe Decree will be sent to me immediately after it is filed with the
Prothonotary .
6. I have been advised of the availability of marriage counseling and understand that
I may request that the court require counseling. I do not request that the court require counseling.
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.
Date: O~/08/01
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JOSEPH O. RAILING, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2000-5390 CIVIL TERM
SANDRA K. RAILING,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF
SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY
OF DIVORCE 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
August 2, 2000.
2.
5, 2000.
Defendant acknowledges receipt and accepts service of the Complaint on August
3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety
days have elapsed from the date ofthe filing ofthe Complaint.
4. I consent to the entry of a final decree in divorce without notice.
5. I understand that I may lose rights concerning alimony, division of property,
lawyer's fees or expenses in 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
Prothonotary .
7. I have been advised of the availability of marriage cOlmseling and understand that
I may request that the court require counseling. I do not request that the court require counseling.
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.
Date: ~\ rl. L\ \-iLl
~ndn~ "0
Sandra K. R 'ling
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JOSEPH O. RAILING, JR.,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 2000-5390 CIVIL TERM
v.
SANDRA K. RAILING,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
CERTIFICATE OF SERVICE
I, David A. Baric, Esquire, attorney for the Plaintiff in the above-captioned divorce
action, do hereby certify that I served a certified copy of the Complaint in Divorce to the
Defendant, as per the attached U.S. Postal Service Certified Mail, return receipt card.
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~RIEN, BARIC & SC~R
By~tJ t: lA,
David A. Baric, Esquire
DATE:
1,/q/1f1
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1. Article Addressed to:
D. Is delivery,address different m item 1 .
If YES, enter delivery address below:
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&ndra K. Roi/inq . .
t.?J1 Walnut 50itWl RoOJJ
Car/islE) PA )1013
3. Service Type
o Certified Mail 0 Express Mail
o Registered 0 Return Receipt for Merchandise
o Insured Mail 0 C.O.D.
4. Restricted Delivery? (Extra Fee) Yes
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