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HomeMy WebLinkAbout01-04452IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. ~, Beniamin F. Line, Plaintiff N O. 01-4452 Civil VERSUS Janetta S. Line, Defendant DEGREE IN DIVORCE ~ Z~ 5~1 3 AND NOW, IT IS ORDERED AND DECREED THAT Beniamin F. Line ,PLAINTIFF, + AND Janetta S. Line ,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; HONOTA RY £S ~o ~~ PROPERTY AND SEPARATION AGREEMENT?7~ ~~ THIS AGREEMENT, made and entered into this S~day of~`f~~ , 2003, by and between, BENJAMIN F. LINE, hereinafter referred to as Husband, and JANETTA S. LINE, hereinafter referred to as Wife, witnesseth: WHEREAS, the parties hereto are Husband and Wife, they havingbeen married on October 22, 1982, in Franklin County, Pennsylvania; and WHEREAS, the parties hereto have ceased to cohabit together as Husband and Wife; and WHEREAS, both and each of the parties hereto are aware of their legal rights, the implications of this Agreement, and legal consequences, which may and will ensue from the execution thereof. Husband is being represented by Douglas R. Roeder, Esquire, of Reichard Law Offices, LLC. Wife is being represented by Jerry Weigle, Esquire of Weigle & Associates, P.C. WHEREAS, Husband acknowledges that he is thoroughly conversant with and accurately knows the size, degree, and extent ofthe estate and income of Wife, and Wife acknowledges that she is thoroughly conversant with and knows accurately the size, degree and extent of the estate and income of Husband; and WHEREAS, the parties hereto wish finally and for all time to settle and determine their respective property and other rights growing out of their marital relationship, wish to live separate and apart, and wish to enter into this Property and Separation Agreement. WHEREAS, this Agreement supercedes and renders all prior agreements null and void; and NOW, THEREFORE, in consideration of the promises and mutual undertakings herein contained, and intending to be Iegally bound hereby, the parties do mutually agree as follows: 1. SEPARATION: The parties may and shall continue to live apart for the rest of their lives. Each shall be free from interference, direct or indirect, by the other as fully as though unmarried. Each may, for his or her separate benefit, engage in any employment, business, or profession he or she may choose. 2. MUTUAL ESTATE WAIVER: It is the intention of the parties hereto that from and after the date and execution of this Agreement, neither shall have any spousal rights in the property or estate of the other and to that end both waive, relinquish and forbear their rights of dower or courtesy, right to inherit, rights to claim or take a husband's or wife's or family exemption or allowance, to be vested with letters of administration or testamentary, or to take against any will of the other. The parties further agree that they may and can hereafter as though unmarried without any joinder by either party, sell, convey, transfer and/or encumber any and all real estate and personal property which either of them now or hereafter owns or possesses, and further agree that the recording of this agreement shall be conclusive evidence to all of his or her right to do so. The said Husband and Wife do hereby irrevocably grant, each to the other, should the exercise of this power hereby given become necessary, the right and powers to appoint one or more time, any person or persons whom Husband and Wife shall designate to be the attorney-in-fact for the other, in their name and in their stead, to execute and acknowledge any deed or deeds, releases, quitclaims, or satisfactions, under seal or otherwise, to enable either party hereto alienate his or her real or personal property, but without any power to impose personal liability for breach of warranty or otherwise. Each of the parties hereto waive any right of election contained in Chapter 22 of the Pennsylvania Probate, Estates and Fiduciaries Code or any similar code or law of any other state or jurisdiction. 3. BANK ACCOUNTS: For the mutual promises and covenants in this Agreement, Husband and Wife hereby waive all right, title, claim or interest they may have by equitable distribution in their respective bank accounts, checking and/or savings, if any, and each party waives against the other any duty of accounting for disposition of any jointly held funds. 4, DEBTS: Except as otherwise herein expressly provided, the parties shall and do hereby mutually remise, release and forever discharge each other from any and all actions, suits, debts, claims, demands and obligations whatsoever, both in law and in equity which either of them ever had, now has, or may hereafter may have against the other upon or by reason of any matter, cause or thing up to the date of the execution of this Agreement: a) Wife will be responsible for her un-reimbursed medical bills, whether they were incurred during the marriage, after separation or at any other time. b) Wife shall be responsible for all credit card balances held in her name; c) Husband shall be responsible forall ofhis un-reimbursed medical bills, whether they were incurred during the marriage, after separation or at any other time; d} Husband shall be responsible for all credit card balances held in his name. e) In the event that either party becomes a debtor in bankruptcy or financial reorganization proceedings of any kind while any obligations remain to be performed by that party for the benefit of the other party pursuant to the provisions of this Agreement, the debtor spouse hereby waives, releases and relinquishes any right to claim any exemption (whether granted under state or federal law) or any property remaining with the debtor as a defense to any claim made pursuant to save the other, or their estate, free, harmless, and indemnified of and from all such debts and liabilities. 5. REAL ESTATE: The parties hereto acknowledge and agree that they are the owners of a certain improved tract of real estate known as 225 Neil Road, Shippensburg, Cumberland County, Pennsylvania. For and in consideration of the mutual covenants and agreements herein contained in the body of this instrument. Husband and Wife further stipulation and agree that Wife shall refinance or secure a release of the existing mortgage obligation for Husband and pay Husband the sum of $5000.00, for his interest in the marital property. The sum of $5,000.00 shall be paid to Husband no later than five (5) business days from the date ofclose ofrefinance ofproperty, and refinancing shall occur within ninety (90) days of this agreement. Husband shall deed his interest in said real estate over to wife at the time of refinancing or as close thereto as is practicably possible, but not before Wife turns over personal property to Husband as set forth in Paragraph 8 below. Wife shall be responsible for the preparation of the necessary deed and Wife shall bear the cost of the preparation and filing of said deed. 6. WARRANTY AS TO EXISTING OBLIGATIONS: Each party represents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the other party may be responsible or liable, except as may be provided for in this Agreement. Each party agrees to indemnify or hold the other party harmless from and against all such debts, liabilities or obligations of every kind, which may have heretofore been incurred by them, including those for necessities, except for the obligations arising out of this Agreement. 7. WARRANTY AS TO FUTURE OBLIGATIONS: Wife and Husband each covenant, warrant, represent and agree that each will now, and at all times hereafter, save harmless and keep the other indemnified from all debts, charges and liabilities incurred by the other after the execution of this Agreement, except as maybe otherwise specifically provided for by the terms of this Agreement, and that neither of them shall hereafter incur any liability whatsoever for which the estate of the other maybe liable. ~,s. 8. PERSONAL PROPERTY: Wife shall return to Husband the following items of personal property: a) Husband's tools, mostly located in the shed along with any other personal property of Husband's located in the Shed at the time of separation; b) one-half (1/2) of the children's childhood pictures; c) the "wedding ring" quilt that Mr. Line received from his Mother; and d) the blue fireplace mantel. Husband shall return to Wife one-half (1/2) of the camp pictures of the children. The parties have undertaken to agree upon an orderly disposition of personal property, and the property agreed to be distributed to each will hereafter be deemed to be his or her sole and separate property, free and clear of any right, title or claim of marital property therein by the other. Except as otherwise herein provided, each of the parties shall hereafter own, have and enj oy, independently of any claim or right of the other party, all items of real or personal properly, tangible and intangible, now or hereafter belonging to him or her and now or hereafter in his or her possession with full power to him or her to dispose of the same as fully and effectually in all respects and for all purposes as though he or she were unrnarried, and as to all such properties each party transfers all his or her right, title and interest therein to the other respectively. 9. DIVORCE: Husband has commenced an action for divorce from Wife pursuant to Pennsylvania Divorce Code (irretrievable breakdown) by filing a Complaint in the Court of Common Pleas of Cumberland County, Pennsylvania. Upon the signing of this Agreement, both parties shall execute and forward Affidavits of Consent to the Divorce and Waivers of Notice of Intention to Request Entry of a Divorce Decree Under Secfion 3301(c) of the Divorce Code. It is further agreed and understood that any decree of divorce issuing in this matter shall reflect that Husband will bear the cost of same in his individual capacity. Each of the parties hereto agrees that this Agreement represents a complete and final agreement as to their respective property rights which arose from the`marital relationship and, therefore, mutually waive any and all rights that they may have under the Pennsylvania Divorce Code, Act Number 1980-26, as amended, for equitable distribution. 10. WAIVER OF COUNSEL FEES, ALIMONY AND ALIMONY PENDENTE LITE: Husband and Wife do hereby waive, release and give up any rights they may respectively have against the other for counsel fees and expenses, alimony, alimonypendente lite, spousal support or maintenance. „,.~.~ . 11. VEHICLES: It is further stipulated and agreed by and between the parties hereto that each party shall hereafter own, possess or otherwise hold the motor vehicles which are currently in the possession of each respective party, free and clear of marital interest therein by the other. Each party shall hereafter be responsible for their own vehicle loans and maintenance with respect to said motor vehicle, and shall hold the other harmless for the same. Husband shall remove Wife's name from all vehicle loans on vehicles that are in Husband's possession within thirty (30) days of execution of this Agreement. Wife shall remove Husband's name from all vehicle loans on vehicles that are in Wife's possession within thirty (30) days of the execution of this agreement. Wife shall sign offof the title to Husband's Chevrolet Caviler and Husband shall sign off of the title of the vehicle wife is currently driving. Should it become necessary for either party to execute titles, registration, or similar documents to perfect the sole and separate interest herein addressed, that party shall, upon the request of the opposite party, immediately comply with the same. 12. LEGAL EXPENSES AND COURT COSTS: Each party shall bear his/her own legal fees and costs. 13. EQUITABLE DISTRIBUTION OF PROPERTY: It is specifically understood and agreed that this Agreement constitutes an equitable distribution of property, both real and personal, which was legally and beneficially acquired by Husband and Wife, or either of them, during the marriage as contemplated by The Act of Apri12, 1980 (P.L. No. 63, No. 26) known as The Divorce Code, 23 P.S. 101 et seq. Of the Commonwealth of Pennsylvania, as amended. 14. The parties agree that this Agreement may be enforced in any court ofcompetent jurisdicfion by petition for an affirmative injunction, money judgment for arrearage, or any other procedure compatible with the rules of court. 15. 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 be valid and continue in full force, effect and operation. Likewise, the failure of any party to meet his or her obligations under anyone or more of the paragraphs herein with the exception of the satisfaction of the conditions precedent, shall in no way avoid or alter the remaining obligations of the party. 16. APPLICA$LE LAW: The parties aclmowledge that this Agreement has been negotiated and executed in the Commonwealth of Pennsylvania, and that the laws of the Commonwealth of Pennsylvania shall be controlling in any disputes arising out of this Agreement or concerning interpretation of it. 17. SUMMARY OF EFFECT OF AGREEMENT: It is specifically understood and agreed by and between the parties hereto, and each party accepts the provisions herein made in lieu of and in full settlement and satisfaction of any and all said parties' rights against the other for any 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 raised by them in the divorce action pending between the parties. 18. TAX CONSEQUENCES: By this Agreement, the parties have intended to effectuate an equitable division of their marital properly. The parties have determined that such division conforms to a right and just standard with regard to the rights of each party. The division of existing marital property is not, except as may be otherwise expressly provided herein, intended by the parties to institute in any way a sale or exchange of assets and the division is being effected without the introduction of outside funds or other property not constituting a part of the marital estate. 19. MODIFICATION AND WAIVER: No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties, or unless such modification or waiver shall be by subsequent order of court. 20. RETIREMENT ACCOUNTS: (a) The parties recognize that Husband has a retirement plan as a result of his employment. Por the mutual promises and covenants contained in this Agreement, Wife hereby waives all right, title, claim or interest she may have by equitable distribution or otherwise in this pension plan. (b) The parties recognize that Wife has a retirement plan as a result of her employment. For the mutual promises and covenants contained in this Agreement, Husband hereby waives all right, title, claim or interest he may have by equitable distribution or otherwise in this pension plan. (c) Each party specifically waives any and all rights to pre-retirement death benefits and survivor benefits under the other's pension or retirement plan(s), and each acknowledges that the effect of this waiver is that he or she will not be entitled to any benefits whatsoever from these contracts, plans or accounts if the other dies before or after reaching retirement age and each agrees and unequivocally consents to the designation by the other of any alternate or further beneficiaries at any time. 21. LIFE INSURANCE: The whole life insurance policy on Zachary B. Line, the son of the parties born October 26, 1987, shall remain in the ownership of Husband until Zachary B. Line reaches the age of eighteen. Husband shall not dispose of, surrender, borrow against or otherwise alienate said life insurance. Should Zachary B. Line die before reaching the age of eighteen (18) years, the proceeds of said life insurance policy shall go to the estate of Zachary B. Line. Upon Zachary B. Line reaching the age of eighteen (18), said life insurance policy shall transfer to the ownership of Zachary B. Line. Upon attaining the age of eighteen (18) years, Zachary B. Line may at his option dispose of, cash, surrender, retain, etc. said life insurance policy as he sees fit. 22. HEALTH INSURANCE AND MEDICAL BILLS: Upon execution of this Agreement each party shall be solely responsible for paying the costs of his or her own medical bills and his or her own health insurance. Neither party shall have any obligation, whatsoever, to cover the other party's health insurance or medical bills. 23. BANKRUPTCY: The respective duties, covenants and obligations of each party under this Agreement shall not be discharged by battlmtptcy but, if any bankruptcy court shall discharge any party of accrued obligations to the other, this Agreement shall continue in full force and effect thereafter as to any duties, covenants and obligations accruing or to be performed thereafter. 24. RECONCILIATION: The parties shall only affect a legal reconciliation which supersedes this Agreement by their signed agreement containing a specific statement that they have reconciled and that this Ageement shall be null and void. Otherwise, this Agreement shall remain in full force and effect. Further, the parties may attempt a reconciliation, which action, if not consummated by the aforesaid agreement, shall not affect in any way the legal effect of this Property and Separation Agreement, or cause any new marital rights or obligations to accrue. 25. DUTY TO EFFECTUATE AGREEMENT: 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 assurances that the parties may reasonably require, for the purpose of giving full force and effect to the provisions of this Agreement. hi addition, the parties hereto agree that within ten (10) days of the date of submission of the other party, either party shall sign any document necessary for the completion and effectuation of the terms of this Agreement. Any costs, including attorney fees, necessitated by enforcement of this Agreement shall be borne by the party refusing to honor the terms and conditions of this Agreement. 26. NOTICES: Any and all notices given hereunder shall be in writing and shall be sent by certified mail, return receipt requested as follows: a. To Husband, at 2502 Lawyer Road, Chambersburg, Pennsylvania 17201 b. To Wife at 225 Neil Road, Shippensburg, Pennsylvania 17257. or shall be sent to such addresses as supplied by the parties to each other in writing from time to time. 27. WHOLE AGREEMENT: This Agreement constitutes the entire understanding of the parties. It supersedes any and all prior agreements between the parties. There are no representations or warranties other than those expressly set forth herein. 28. CAPTIONS: The captions of this Agreement are inserted only as a matter of convenience and for reference, and in no way define, limit or describe the scope and intent of this Agreement, nor in any way effect this agreement. 29. 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. 30. BREACH OF AGREEMENT: If either party fails in the due performance of obligations under this Agreement, at their election, the non-breaching party shall have the right to sue for damages for breach of this Agreement or to rescind same and seeks such legal remedies as may be available to them. The breaching party shall be responsible for actual legal fees and costs incurred by the non-breaching party necessary to the enforcement of this Agreement. 31. INTEGRATION: This Agreement constitutes the entire understanding of the parties and supersedes any and all prior agreements and negotiations between them. There aze no representations or warranties other than those expressly set forth herein. This Agreement shall survive integration by any court into any judgment for divorce and shall confinue to have independent legal significance as a written contract sepazat~ from such judgment for divorce and maybe enforced as an independent contract. 32. EFFECT OF DIVORCE DECREE: The parties agree that unless otherwise specifically provided herein, this Agreement will confinue in full force and effect after such time as a final decree in divorce maybe entered with respect to the parties, and shall be incorporated into said Divorce Decree. WHEREAS, the parties hereto state that he or she, in the procurement and execution of this Agreement, has not been subjected to any fraud, concealment, over-reaching, imposition, coercion, or other unfair dealing on the part of the other, or on the part of either's counsel. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals to this Property and Separation Agreement, the day and year first above written. enj n F. Line ~ anetta S. Line WITNESS: " ~~ c ~ . r.; _ ;j ~~'- .. _. -o rn~ .i t ~:: ~: >> , , _ y r_,.. -'\ .-~ -J_ 3 £5 Fo IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BENJAMIN F. LINE, CIVIL ACTION -LAW Plaintiff -vs- No. 01-4452 Civil Term JANETTA S. LINE, Defendant IN DFV ORCE a v.m. 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) Grounds for divorce: irretrievable breakdown under Section 3301(c) of the Divorce Code. 2) Date and manner of service of the comnlaint: The Complaint was filed on July 23, 2003; service was made on the Defendant by Certified Mail, Return Receipt, on August 30, 2001 at 225 Neil Road, Shippensburg, Cumberland County Pennsylvania, 17257. 3) Data of execution of the affidavit required by Section 3301(cl of the Divorce Code: The date of execution of the affidavit required by Section 3301.(c) of the Divorce Code: by Plaintiff: September 5, 2003; by Defendant: September 4, 2003. 4) Related claims pending: None. 5) Data Plaintiffs Waiver ofNotice in Section 3301 L) Divorce was filed with the Prothonotary: September 9, 2003. Date Defendant's Waiver ofNotice in Section 3301(c) Divorce was filed with the Prothonotary: September 9, 2003. Respectfully submitted: ~' dam, C~i~-" Douglas R. Roeder, Esquire Attorney for Plaintiff - ta,~<~ o c~ ~, r- ~ , V. Sii~~. '-°7 ~ ~ - --- r i_ -'. ~_, _3 ~'+ :, a ~5 Fo ~~~z ,, ~,r~ ~. ~-Kra,. ,,, „,r .~ ~ n~~,~=, ~.~ t ~~b-k~~. %~. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BENJAMIN F. LINE, PLAINTIFF CIVIL ACTION-LAW -vs- NO. Cj ! - °Se`~lS,"~ 1.1 ul ~,~£/~-~"''1 JANETTA S. LINE, DEFENDANT IN DIVORCE a v.m. NOTICE TO DEFEND AND CLAIM RIGHTS TO: Janetta S. Line, Defendant 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 otherrights 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, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. p 4 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 CAN GET LEGAL HELP. Pennsylvania Bar Association-Lawyer Referral Service Telephone 1-800-692-7375 (PA only) or717-238-6715 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact the Prothonotary's Office. All arrangements must be made at least 72 hours prior to any hearing or business before the Court. You must attend any scheduled conference or hearing. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BENJAMIN F. LINE, PLAINTIFF CIVIL ACTION-LAW -vs- NO. JANETTA S. LINE, DEFENDANT IN DIVORCE a v.m. COMPLAINT UNDER SECTION 3301(Cl or (D) OF THE DIVORCE CODE NQW comes the plaintiff and for cause of action against the Defendant says: Benjamin F. Line is the Plaintiff, who currently resides at 216 East Queen Street, Apartment 3, Chambersburg, Franklin County, Pennsylvania, since June 1, 2001. 2. Janetta S. Line is the Defendant, who currently resides at 225 Neil Road, Shippensburg, Cumberland County, Pennsylvania, since approximately 1986. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendantwere married on October22, 1982, at Newburg, Franklin County, Pennsylvania. 5. A prior divorce action was filed in Cumberland County to docket number 3024 - 1991. This action was dismissed on October 25, 1994. 6. The marriage is irretrievably broken. 7. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the Court require the parties to participate in counseling. 8. Plaintiff requests the Court to enter a decree of divorce. Respectfully submitted, /~-~ Carrie M. Bowmaster, Esquire Attorney I.D. No. 70226 Reichard Law Offices, LLC 70 West King St. Chambersburg, PA 17201 (717)267-2288 I verify that the statements made in the attached Divorce Complaint are true and correct. I understand that false statements made herein are made subject to the penalties of 18 Pa.C.S., Section 4904, relating to unsworn falsification to authorities. Date:__~~~, 2001 Benjamin. F. Line, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BENJAMIN F. LINE, PLAINTIFF CIVIL ACTION-LAW -vs- N0. 01-4452-Civil Term JANETTA S. LINE, DEFENDANT IN DIVORCE a v.m. CERTIFICATE OF SERVICE I, Kathy A. Barnhart, do hereby certify that I served a true and attested copy of the Divorce Complaint in the above-captioned action on the defendant by certified mail, on August 30, 2001, as evidenced by the attached receipt. ) For ~arrie M. Bowmaster, Esquire Attorney for Plaintiff Date: September 4, 2001 ten S{PEUR P 725 . `~ r Postage ~ 50.57 m .. 0201 n O Certified Fee 12 ~ ieturn Receipt Fea Postmark O lorsement Required) Here ~3' ~~ ~ Restricted Delivery Fes ( (Entlorsemera Required) ~ Total Postage s Feea $ 57.37 08(28!2001 .~ m0 SByt To t. a Street, APL No.; n- r.. c smre,nP+a e N 5 -..'.~. ~~ O 1~_ .., ~I l A r: I : p "'O l ' . ~iw G ~ _ _ ) ~. ~~.._' Y~~~ W _ VJ - '- " ~ } [~[J Cd ~ r w ^ Completeitems 7, 2, ehd'3Y{f$O Ctinlptete A. M~SeIVeA-Oy(v'Jaeae~YNITeEaeany/ o. ~u~nvi vnnvniy item 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse satFaat we cah return the card to you. C. Signature , ^ Attach this card to the back of the mailpiece, n ^ Agent or en the hoot if space permits. W ^ Addressee - D: Is livery address different from item 17 ^ Yes t. ArSOIe Addressetl to: If YES, enter delivery address below: ^ No O~A ~ \ ~ 3. Se~ice Type ~j L \~y/~~/ L!T Certifietl Mail ^ F~cpress Mail ~'`~P~erl-d`~(A.~„Q( ~ ^Registered ^Return Receipt for Merchandise 7/ / ~a ~ ~ ^ Insured Mail ^ C.O.D. 4. Restricted Delivery! (EZtm Fee) yes __- 2. Aff+cleNumber 701 0360 O~a1 a37-Fr- 6992- - "'~ (fiansfer from service IebeQ _ - - ' PS Form ~~.11, March 2001 Domestic Return Receipt tozss5-o1-m-1424 < 9._ n { IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BENJAMIN F. LINE, CIVIL ACTION -LAW Plaintiff -vs- No. 01-4452 Civil Term JANETTA S. LINE, Defendant IN DIVORCE a v.m. AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) was filed on July 23, 2001. 2. The marriage of the Plaintiff and the Defendant is hretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a fmal decree of divorce as I have waived notice of intention to request entry of divorce decree under 3301(c) of the Divorce Code. I verify that the statements made in this affidavit are true and correct. I understand that false statements made hereunder are subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~ ~- ~J i,,., enj m F. Line, Plaintiff .. w. 0 w -may 1 A fn1 ~, (`~ c? - ca ~ c_ _ -e ~~ `n , : ~ ~ . U: e~ rJ . _ .- f._ f .. J ~ .~ __ ,. .° (:~ ~{ i ,! ~ a+n ~ S~.aoy, ~G3 r :nv? > ~E~ 1Cr:N FN YA FE" .. ~. 1 ~+xsnfa, s+yx~vx~a '- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BENJAMIN F. LINE, CIVIL ACTION -LAW Plaintiff -vs- No. 01-4452 Civil Term JANETTA S. LINE, Defendant IN DIVORCE a v.m. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(C) OF THE DIVORCE CODE I consent to the entry of a fmal divorce decree 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 made hereunder are subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~ ~' ~~ `~ Benja F. Line, Plaintiff ,~ .. < w ~ -.:, -~; ~ `' --a - w - ~ -~ ~; '~, ~- , r ~1J - _. ;r~~ ~: - -~~ t' 'j Q ~~ ~4fsHart .c..s;.::~a~t*~r'~ ,n'.~F. .. ..T1e~ta~n~z?~k3€'a°;•cw~.~ .: ?~; w,'+ s9~+a~xK« ; n,.-,i rxE! Y!'<an'~'2 b ._ _ _ _ _ _. _ _-_,E IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BENJAMIN F. LINE, CIVIL ACTION -LAW Plaintiff -vs- No. 01-4452 Civil Term JANETTA S. LINE, Defendant IN DIVORCE a v.m. AFFIDAVIT OF CONSENT A Complaint in Divorce under Section 3301(c) was filed on July 23, 2001. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. I consent to the entry of a final decree of divorce as I have waived notice of intention to request entry of divorce decree under 3301(c) of the Divorce Code. I verify that the statements made in this affidavit are true and correct. I understand that false statements made hereunder are subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Date: 'fi y, at,o03 ~tsr.-LCD • ~ , J tta S. Line, Defendant ~.~~~ s G., T] - r ; ( ,c p r~'x ~~-- !' ' 4 ~ ~ a ; ' t - i t.CS ' G' ~-. ~ ..~ ' il y~. ~ ~ ~ _' Cl __ i.,:3 -_j.i7 ~ ~ O ~ t°'' - ;~ 3 ~~ p _ .~.~~ ~t IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BENJAMIN F. LINE, CIVIL ACTION -LAW Plaintiff -vs- No. 01-4452 Civil Term 7ANETTA S. LINE, Defendant IN DIVORCE a v.m. WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER &3301(Cl OF THE DIVORCE CODE I consent to the entry of a final divorce decree 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 made hereunder are subject to the penalties of 18 PA C.S. Section 4904 relating to unsworn falsification to authorities. Date: ~ `1 ~UD3 v C~Q.~ Jan 'a S. Line, Defendant -P ~. Q ("J ~ ~. ;.i "t; 'U [~ ; rn ~ '~ ~ r n,` ~, ~ - a ~_ ~ + g„_ ~. r , ~~: ~~ '~? .-a ~-C.-.~ ... _~ L '.( S ~- ,J ,- 'r. - $~ w __ .. O a. a 3 ~s ~~ „. MTIFFYiA~.Rh+A61T1R't- WrFID91RRe`~ 1~--fHWY (!ti. _ "' f"!": ab?dSf +M a'?~'n"£ 4 i:4W4 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA BENJAMIN F. LINE, PLAINTIFF -vs- JANETTA S. LINE, DEFENDANT CIVIL ACTION-LAW N0.01-4452-CIVIL TERM IN DIVORCE a v.m. PRAECIPE TO REINSTATE DIVORCE TO THE PROTHONOTARY: Please reinstate the above-captioned civil complaint pursuant to Pa.R.C.P. Sec. 1930.4(e). A copy of the original complaint is attached hereto. Carrie M. Bowmaster, Esquire For D.L. Reichard, II, Esquire Reichard Law Offices, LLC Dated: 3 p C c'; C; Z, t=~ r1i.,: rte. ~. 1 •.J N W G2s=~ -~ ~:. Ci y_. ~... A ~ " .> _~ t r~ ~i_+ L` ~O ~F^YA~wrv E ,.-.;:,~.. .~c~,_,rrx+a;!.€fl~':~i~~~F~'~U'~~~9S. n, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENJAMIN F. LINE, Plaintiff v. JANETTA S. LINE, Defendant CIVIL ACTION -LAW No. 01-4452 Civil Term IN DIVORCE a v.m. NOTICE TO DEFEND TO: Janetta 5. Line 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 against you without you and a decree of divorce or annulment maybe 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 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 mamage counseling. A list of marriage counselors is available in the Office of the Prothonotary at: Franklin County Courthouse, 157 Lincoln Way East, Chambersburg, PA 17201. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LA'WYER'S FEES OR EXPENSES BEFORE A 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 CAN GET LEGAL HELP. Pennsylvania Bar Association Lawyer Referral Service Telephone :(717) 238-6715 or 1-800-692-7375 ~, IN TAE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENJAMIN F. LINE, CIVIL ACTION -LAW Plaintiff . v. No. 01-4452 Civil Term JANETTA S. LINE, Defendant IN DIVORCE a v.m. NOW COMES, the Plaintiff, Benjamin F. Line, and avers as follows in support of his additional count in divorce: COUNT II EQUITABLE DISTRIBUTION 9. The prior paragraphs in the Divorce Complaint filed July 23, 2001 are incorporated herein by reference thereto. 10. Plaintiff and defendant have acquired property, both real and personal, during their marriage. 11. Plaintiff and defendant have been unable to agree as to an equitable distribution of said property. 12. Plaintiff requests the Court to equitably divide, distribute and assign the marital property Uetween the parties as provided by Section 3502 of the Divorce Code. .. VERIFICATION I verify that the statements made in this affidavit are true and correct. I understand that false statements made hereunder are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. ~i Date: ~ ~hG , ~ `UO3 Benj n F. Line, Plaintiff CERTIFICATE OF SERVICE I hereby certify that on this ~ day of ~{IV1,L , 2003, I served a true and correct copy of the foregoing document via United States mail, first class, postage pre-paid on the following: 7ennetta S. Line 225 Neil Road Shippensburg, PA 17257 Jerry A. Weigle, Esquire 126 East King Street Shippensburg, PA 1725 i By: ~-~~ ~, ~TSwA/N-- Douglas R. Roeder, Esquire Reichard Law Offices, LLC 70 West King Street Chambersburg, PA 17201 (717) 267-2288 "~. p o c.~ ~ ti ~ a b ~ ~ A y ~ ~ O ^~ ~1 1 ~l F~ C'} c-, c._ - w ~~ r.,, _. ~. ~~: ~,~ => r_ r _,~ ,A~ f.:r _~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENJAMIN F. LINE, Plaintiff v. JANETTA S. LINE, Defendant CIVIL ACTION -LAW No. 01-4452 Civil Term IN DIVORCE a v.m. NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter-affidavit within twenty (20) days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(Dl OF THE DIVORCE CODE 1. The parties to this action separated on June 2, 2001 and have continued to live separate and apart for a period of at least two (2) years. 2. The marriage of the Plaintiff and the Defendant is irretrievably broken. 3. 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements made hereunder are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: Jf>n~ ~~ ,~OO3 \ _~ Benj F. Zine, Plaintiff CERTIFICATE OF SERVICE I hereby certify that on this _ day of J ~V~ , 2003, I served a true and correct copy of the foregoing document via United States mail, first class, postage pre-paid on the following: Jennetta S. Line 225 Neil Road Shippensburg, PA 17257 Jerry A. Weigle, Esquire 126 East King Street Shippensburg, PA 17257 gy. ~L~/G' A""` Vim, ~ o'-u""~ Douglas R. Roeder, Esquire Reichard Law Offices, LLC 70 West King Street Chambersburg, PA 17201 (717)267-2288 C c~ a w O 0 a C'7 ~_l L._ Cx: -~ C' /.~ mrx ` .a_ ' -~ - ~~ - ,.~ ; '~ ' : °; C 7 =: r 6,~ jm c7 -` ~y ,. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENJAMIN F. LINE, Plaintiff v. JANETTA S. LINE, Defendant CIVIL ACTION -LAW No. 01-4452 Civil Term IN DIVORCE a v.m. COUNTER-AFFIDAVIT OF CONSENT UNDER SECTION 3301(D) OF THE DIVORCE CODE TO: JANETTA S. LINE, Defendant 1. Check (a) or (b): (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because: _(i) The parties to this action have not lived separate and apart for a period of at least two (2) years. ^(ii) The marriage is not irretrievably broken. 2. Check (a) or (b): _(a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyers' fees or expenses if I do not claim them before a divorce is granted. _(b) I wish to claim economic relief, which may include alimony, division of property, lawyers' fees or expenses or other important rights. ~: I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth in the Notice of Intention to Request a Divorce Decree, the divorce decree maybe entered without further delay. I verify that the statements made in this counter-affidavit 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. Janetta S. Line NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE, AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. .~,r~~wA CERTIFICATE OF SERVICE I hereby certify that on this S~'day of _ 5V~.2r , 2003, I served a true and correct copy of the foregoing document via United States mail, first class, postage pre-paid on the following: Jennetta S. Line 225 Neil Road Shippensburg, PA 17257 Jerry A. Weigle, Esquire 126 East King Street Shippensburg, PA 17257 Douglas R. Roeder, Esquire Reichard Law Offices, LLC 70 West King Street Chambersburg, PA 17201 (717) 267-2288 ~ _ ' ;: , ~ ",' ` z -. ~,= ~~ ,> . ,u ~ T .o ~ _ ° s~ ' { > C. ~+~ ~_ji'~l i W j _) - ~ c_5 0 ~5 ~a ~'' ~ avce tea..+.~.,t a. , < :, ..,~.;. ,ae ~~~s .~ ~ r~Sr~P. i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENJAMIN F. LINE, CIVIL ACTION -LAW Plaintiff v. No. 01-4452 Civil Term JANETTA S. LINE, Defendant IN DIVORCE a v.m. AFFIDAVIT OF NON-MILITARY SERVICE PURSUANT TO PA.RC.P.1920.46 COMMONWEALTH OF PENNSYLVANIA COUNTY OF FRANKLIN :SS Plaintiff, Benjamin F. Line, being duly sworn according to law, deposes and says that he is the plaintiff in the above-captioned matter, that he personally knows the Defendant is over the age of eighteen years and that Defendant is not in the military service or in any branch of the armed forces of the United States or its allies or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 and the amendments thereto. Benjam' F. Line Swom and subscribed before me this ~`~~ day of--__ (~ 2003. Not ublic Notarial Seal Shelve J. Barton, Notary Public Wayrxtalwro eoro, Franklin County My Commission Expires Nov. 15, 2003 CERTIFICATE OF SERVICE I hereby certify that on this ~ day of S+r~'l.~ , 2003, I served a true and correct copy of the foregoing document via United States mail, first class, postage pre-paid on the following: Jennetta S. Line 225 Neil Road Shippensburg, PA 17257 Terry A. Weigle, Esquire 126 East King Street Shippensburg, PA 1725 i Douglas R. Roeder, Esquire Reichazd Law Offices, LLC 70 West King Street Chambersburg, PA 17201 (717) 267-2288 ~_ Q (n1 si W 0 a L~ i ` r1i ` _' L -_ _ G i' Y C. r ~ ~~' °~^ ~: ~ri v~ .:'C7 (, .: G7 IJ fTi J ~~ n ~~~ T ~s ~~ s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENJAMIN F. LINE, CIVIL ACTION -LAW Plaintiff v. No. 01-4452 Civil Term JANETTA S. LINE, Defendant IN DIVORCE a v.m. COUNTER-AFFIDAVIT OF CONSENT UNDER SECTION 3301(D) OF THE DIVORCE CODE TO: JANETTA S. LINE, Defendant Check (a) or (b): (a) I do not oppose-the entry of a divorce decree. (b) I oppose the entry of a divorce decree because: _(i) The parties to this action have not lived separate and apart for a period of at least two (2) years. _(ii) The marriage is not irretrievably broken. 2. Check (a) or (b): _(a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyers' fees or expenses if I do not claim them before a divorce is granted. ~/ (b) I wish to claim economic relief, which may include alimony, division of property, lawyers' fees or expenses or other important rights. v I understand that in addition to checking (b) above, I must also file all of my economic claims with the Prothonotary in writing and serve them on the other party. If I fail to do so before the date set forth in the Notice of Intention to Request a Divorce Decree, the divorce decree maybe entered without further delay. I verify that the statements made in this counter-affidavit 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. J tta S. Line NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE, AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU SHOULD NOT FILE THIS COUNTER-AFFIDAVIT. P CERTIFICATE OF SERVICE I hereby certify that on this ~~'day of ~~/~~- , 2003, I served a true and correct copy of the foregoing document via United States mail, first class, postage pre-paid on the following: Jennetta S. Line 225 Neil Road Shippensburg, PA 17257 Jerry A. Weigle, Esquire 126 East King Street Shippensburg, PA 17257 Douglas R. Roeder, Esquire Reichard Law Offices, LLC 70 West King Street Chambersburg, PA 17201 (717) 267-2288 c ~ 2°,, o ~~ c~ ~ ~ Y J ~ 3 ~ ~~(~~+ ~] .~C; ?.? i ~ =`j ~~ ~~ :.w ~~~ c 5 CA ~rr5 Ld - ~ mr.,~~xr. -,..,~, s.*~rrr. r ems ,~e~ i.~i=~h~r ..~ ,.~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLYANIA BENJAMIN F. LINE, CIVIL ACTION -LAW Plaintiff v. NO.O1-4452 Civil Term JANETTA S. LINE, Defendant IN DIVORCE a v.m. NOTICE TO DEFEND To: Benjamin F. Line 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 judgement 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 grounds for the divorce is indignities or irretrievable breakdown of the marriage, you may request mamage counseling. A list of marriage counselors is available in the office of the Prothonotary at Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA 17013. YOIJ SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYWER 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 WEIGI.E & ASSOCIATES. P.C. -ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 1925'1-139"! 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA BENJAMIN E LINE, CIVIL ACTION -LAW Plaintiff v, NO.O1-4452 Civil Term JANETTA S. LINE, Defendant IN DIVORCE a v.m. PETITION FOR RELATED CLAIMS UNDER DIVORCE CODE NOW COMES, the Defendant, Janetta S. Line, and avers as follows in support of her additional counts in divorce: COUNT I -ALIMONY 1. Petitioner is Defendant above named, who currently resides at 225 Neil Road, Shippensburg, Southampton Township, Cumberland County, Pennsylvania 17257, since approximately 1986. 2. Respondent is the Plaintiff above named, who currently resides at 216 South Queen Street, Chambersburg, Franklin County, Pennsylvania 17201, since June 1, 2001. 3. Petitioner and Respondent were married on October 22, 1982, at Newburg, Franklin County, Pennsylvania. 4. Respondent has heretofore filed a complaint for divorce as of the above caption. 5. Petitioner lacks sufficient property to provide for her reasonable means and is unable to support herself through appropriate employment. 6. Petitioner requires reasonable support to adequately maintain herself in accordance with the standard of living established during the marriage. WHEREFORE, the Petitioner prays your Honorable Court to enter an award of alimony. COUNT II -ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND EXPENSES 7. Paragraphs 1 through 6 are incorporated herein by reference as though set forth in full. WEIGLE & ASSOCIATES. P.C. -ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 1]25]-139] 8. Petitioner has employed counsel, but is unable to pay the necessary and reasonable attorney's fees for said counsel. 9. Pefitioner is unable to sustain herself during the course of this litigation. 10. Petitioner requests the Court to enter an award of Alimony Pendente Lite and to enter an award of Alimony in her favor. 12. Petitioner requests that this petition be heard by the Cumberland County Domestic Relations Office. WIlEREFORE, the Defendant requests your Honorable Court to enter an award of alimony pendente lite, interim counsel fees, costs, and expenses, until final hearing and thereupon award such additional counsel fees, costs, and expenses as deemed appropriate. Respectfully submitted, WEIGLE & ASSOCIATES, P.C. i rry A. eigle, Esquire Attorney for Defendant Attorney ID No. 01624 126 East King Street Shippensburg, PA 17257 717-532-7388 WEIGLE & ASSOCIATES. P.C. -ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA t925T-1397 VERIFICATION I verify that the statements made in the foregoing Petition for Related Claims Under Divorce Code are true and correct. I understand that false statements herein aze made subject to the penalties of 18 Pa. C.S. 4904, relating to unsworn falsification to authorities. Dated: ~ d ~" J ETTA S. LINE WEIGLE & ASSOCIATES, P.C. -ATTORNEYS AT LAW - 126 EAST KING STREET - SHIPPENSBURG, PA 17259-1399 °v ~ ~'~ `~C~ ~ r V 6 cr, y r osr w P l11 A C : +: ~- .~ - ~_. v_+,Z~. -~ ~~,~ ,. ~~.: ~ s ~~~> > . `~ `l7 4J3 :~ }~> ~, 1.