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HomeMy WebLinkAbout01-04916 OCT 2 4 2006 k F. ALLEN FRERE, CIVIL ACTION - LAW V. IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA LUCETTEI.FRERE, Defendant : NO. 2001-4916 CIVIL TERM : IN DIVORCE ORDER AND NOW this -4--l' day of aa-d&. 2006, /la ?.u G eim&a S? , Esquire, is appointed Master with respect to the following claim: equitable distribution of property. BY THE COURT: MOVING PARTY Name: F. Allen Frere Attome)Zs Name Stacy B. Wolf, Esquire Attornev's Address, olf & Wolf 10 West High Street Carlisle, PA 17013 A om -3es Telephone No 717-241-4436 Atto=3? ail stacybwolf@ eatthlink.net Name: Lucette I. Frere m Actor A. Neubaum, Esquire Attome)Zs Address Malone & Neubaum 42 South Duke Street York, PA 17401 Attome?s Telephone No.: 717-843-8001 Attome3: E- vneubaumjr@aol.com a ? io w MR ALi?1('ANVA IASNN3 d? to a pid ' a 130 960Z h&'VlO NOf4i )Jo 3HI qa 331.14O.00d1tj STACY R. WOLF, ESQUIRE ATTORNEY ID NO. 88732 WOLF & WOLF 10 WEST HIGH STREET CARLISLE; PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF F. ALLEN FRERE, CIVIL ACTION - LAW V. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA LUCETTE I. FRERE, Defendant : NO. 2001-4916 CIVIL TERM : IN DIVORCE MOTION FOR APPOINTMENT OF MASTER Plaintiff, F. Allen Frere, moves the Court to appoint a master with respect to the following claims: (X) Divorce ( ) Annulment ( ) Alimony ( ) AlimonyPendente Ute (X) Distribution of Property ( ) Support ( ) Counsel Fees ( ) Costs and Expenses and in support of the motion states: (1) Discovery is complete as to the claims for which the appointment of a_master is requested. (2) The non-moving party has appeared in the action by her attorney, Victor Neubaum, Esquire. (3) The statutory ground for divorce is 3301(d), two year separation. (4) The action is contested with respect to the following claim equitable distribution of property. (5) The action does not involve complex issues of law or fact. (6) The healing is expected to take one-half day. (7) Additional information, if any, relevant to the Motion: None. October 2006 BY. Supreme Court I.D. No. 88732 10 West High Street Carlisle, Pennsylvania 17013 (717) 241-4436 Attorney for Plaintiff Respectfully submitted, WO WOLIti STACY B. OLF, ESQUIRE . , , STACY E. WOLF, ESQUIRE ATTORNEY In NO. 88732 WOLF & WOLF 10 WEST HIGH STREET CARLISLE, PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF F. ALLEN FRERE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. LUCETTEI.FRERE, Defendant NO. 2001-4916 CIVIL TERM : IN DIVORCE CERTIFICATE OF SERVICE I, the undersigned, hereby certify that on the date indicated below, I caused a true and correct copy of the foregoing Motion for Appointment of Master to be mailed, by U. S. Mail, to the below listed parry, in the instant matter, addressed as follows: Victor A. Neubaum,.Esquire Malone & Neubaum 42 South Duke Street York, PA 17401 Dated: October Z 2006 Stacy B. Wolf, Esquire Attorney for Plaintiff (a y CSf _ _? ff1 -iD U5 m DVS' STACY R. WOLF, ESQUIRE ATTORNEY ID NO. 88732 WOLF & WOLF 10 WEST HIGH STREET CARLISLE, PA 17013 (717) 7414436 ATTORNEY FOR PLAINTIFF F. ALLEN FRERE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW V. LUCETTE I. FRERE, Defendant : NO. 2001-4916 CIVIL TERM : IN DIVORCE INVENTORY AND APPRAISEMENT OF F. ALLEN FRERE PLAINTIFF Plaintiff, F. Allen Frere, files the following Inventory and Appraisement of all properly owned or possessed by either parry at the time the parties were separated. Plaintiff verifies that the statements made in this Inventory and Appraisement are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.-S. $ 4904 relating to unswom falsification to authorities. Date: 10 --,2 3 -o 6 F. Allen Frere, Plaintiff ASSETS OF PARTIES F. ALLEN FRERE, Plaintiff, marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. If an item has been appraised, a copy of the appraisal report is attached. (X) 1. Real property ( ) 2. Motor vehicles (X) 3. Stocks, bonds, securities and deposits (X) 4. Certificates of deposits () 5. Checking accounts, cash () 6. Savings accounts, money market and savings certificates () 7. Contents of safe deposit box () 8. Trusts () 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) O 10. Annuities () 11. Gifts () 12. Inheritances () 13. Patents, copyrights, inventions, royalties () 14. Personal property outside the home () 15. Businesses (list all owners, including percentage of ownership and officer/director positions held by a party with company) O 16. Employment/termination benefits-severance pay, worker's compensation claim/award () 17. Profit sharing plans ( X) 18. Pension plans (indicate employee contribution and date plan vests) ( X) 19. Retirement plans, Individual Retirement Accounts () 20. Disability payments () 21. Litigation claims (matured and unmatured) () 22. Military/V.A. benefits () 23. Educational benefits () 24. Debts due, including loans, mortgages held () 25. Household furnishings and personalty (includes as a total category and attach itemized list if distribution of such assets is in dispute) () 26. Other LIABILITIES OF PARTIES Plaintiff, F. Allen Frere, marks on the list below those items applicable to the case at bar and itemizes the liabilities on the following pages. SECURED () 1. Mortgages () 2. Judgments () 3. Liens () 4. Other secured liabilities UNSECURED () 5. Credit card balances () 6. Purchases () 7. Loan payments () 8. Notes payable () 9. Other unsecured liabilities CONTINGENT OR DEFERRED 10. Contracts or agreements 11. Promissory notes 12. Lawsuits 13. Options 14. Taxes 15. Other contingent or deferred liabilites MARITAL PROPERTY Plaintiff lists all marital property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Description of Property Name of All Owners Values 1 marital residence H & W to be determined 2 401(1) H $49,742.40 3 IRA H $7,682.61 4 PP& G stock H $6,885.84 5 ® W unknown c' M ?_ G9 U? 1 CID J 4 `l r ._a F. ALLEN FRERE, Plaintiff V. LUCETTEI.FRERE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0. 2001- (NJ( CIVIL TERM 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 divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Prothonotary's Office at the Cumberland County Courthouse, 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. 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. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 F. ALLEN FRERE, Plaintiff V. LUCETTEI.FRERE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001- q ft CIVIL TERM CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE The Plaintiff, F. Allen Frere, through his attorney, Thomas S. Diehl, makes the following Complaint in Divorce, and, in support thereof, avers as follows: 1. The Plaintiff, F. Allen Frere, is an adult individual who currently resides at 95 Fanus Road, Gardners, Cumberland County, Pennsylvania 17324. 2. The Defendant, Lucette I. Frere, is an adult individual who currently resides at 3940 Beaver Dam Church Road, Roseboro, Sampson County, North Carolina 28382. 3. The Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six months immediately prior to the filing of this Complaint. 4. The Plaintiff and the Defendant were married on June 2, 1973 in West Tarentum, Allegheny County, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties. 6. The Defendant is not a member of the Armed Forces of the United States of America or its Allies. 7. The Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. Knowing this, Plaintiff does not desire that the Court require the parties to participate in counseling. Plaintiff and Defendant are citizens of the United States of America. 9. The parties' marriage is irretrievably broken. WHEREFORE, the Plaintiff, F. Allen Frere, respectfully requests your Honorable Court to enter a decree in divorce pursuant to 23 P.S. § 3301(c) or 3301(d) of the Divorce Code. Respectfully submitted, Date.. J 0" (0? omas S. Diehl Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX s VERIFICATION I verify that the statements made in this 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 unworn falsification to authorities. F. ALLEN FRE Plaintiff c? c =._ -? ` °? „, ? - ' ? - ?_ ? ,., ; ?.:. ?v _ ?? _ ?? s : Ji i r,;; 4 F. ALLEN FRERE, Plaintiff V. LUCETTEI.FRERE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2001-4916 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF SERVICE AND NOW, this 4th day of September 2001, comes Thomas S. Diehl, Esquire, Attorney for the Plaintiff, F. Allen Frere, and states that he had cause to be mailed a certified copy of a Complaint in Divorce to the Defendant, Lucette I. Frere, by certified, restricted delivery, return- receipt requested. A copy of said receipt is attached hereto indicating service was made on August 28, 2001. submitted, Thomas S. Diehl Attorney for the Plaintiff One West High Street, Suite 208 Post Office Box 1290 Carlisle, Pennsylvania 17013 (717) 240-0833 (717) 240-0893 - FAX Er M R M1 rn Postage s S Ir 4 M1 Cenised Fee ell Hace4n A (Esdor@f+l Re¢ulredl o C3 ! C3 - C3 1 Total Postage 6 Pees u , M1 Said To LUCETTE I. FA "SOee%ape Pic.; aad'en+rnio: 3940 BEAVER D C3 C3 . CiIY• State, Lp+ r- RO - NC. 4 ¦ complete Items 1, 2, and 3. Also complete A., item 4 If Restricted Delivery is desired. ¦ Print your name and address on the reverse so that we can return the card to you. C. ¦ Attach this card to the tack of the mailpiece, x or on the front if space permits. 1. Article Addressed to: D. LUCEM I. FRERE 3940 BEAVER DAM CHURCH ROAD ROSEBORO, NC 28382 O? f ? Agent ey address dmererlt from item 1? L.1 Ye: enter delivery address below: ? No 3. Service Type IN Certified Mail ? Express Mail ? Registered O Return Receipt for Merchandise ? Insured Mail ? C.O.D. 4. Resbietad Delivery? IExtra Fee) xp vas 2. Article Numbsr (Copy from service Iabeb00 1670 0001 8795 7639 Ps Form 3811, July 1 999 Domestic Return Receipt 10E595.WW1789 0 r_ _U ter, ..rl 1 11,,, '.._' , r3 J. C rj ?,_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA F. ALLEN FRERE, : No. 2001-4916 Plaintiff VS. LUCETTE L FRERE, : No-Fault Divorce under Defendant : §3301(c) or §3301(d) PETITION FOR RELATED CLAIMS AND NOW, comes the Defendant, Lucette I. Frere, who files this Petition raising claims under the Divorce Code of 1980, as amended, and pursuant to Pa. R.C.P.1920.15(b), and represents as follows: 1. The Petitioner is Lucette I. Frere, who resides at 3940 Beaver Dam Church Road, Roseboro, NC 28382. 2. 17324. 3. Pennsylvania 4. The Respondent is F. Allen Frere, who resides at 95 Fanus Road, Gardners, PA The Plaintiff and Defendant were married on June 2, 1973 in West Tarentum, The Petitioner and Respondent have owned property from the date of their marriage to the date of their separation, which property qualifies as marital property under the Divorce Code of 1980, as amended. The Petitioner and Respondent may also have owned property prior to the marriage of a personal and real nature, which property has increased in value during their marriage, or which property has been exchanged for other property which has increased in value, which also -1- qualifies as marital property under the Divorce Code of 1980, as amended. 5. The Petitioner and Respondent are unable to agree to an equitable division of their marital property, and the Petitioner, therefore requests the court to equitably divide the marital property of the parties. 6. The Petitioner and the Respondent acquired property during their marriage, or had acquired separate property prior also lacks sufficient property to provide for her reasonable needs, and is unable to support herself through appropriate employment. Petitioner requires support to maintain herself in accordance with the standard of living established during the marriage. Therefore, Petitioner avers that alimony, temporary alimony or support is necessary, and requests the court to award her permanent alimony, temporary alimony, or spousal support. 7. The Petitioner has also retained an attorney, but is unable to pay the reasonable and necessary attorney's fees and is unable to pay the reasonable costs and expenses to conduct this action. Therefore, Petitioner requests an award of alimony pendente lite, counsel fees and expenses be made in her favor in this case. Respectfully submitted, MALONE & NEUBAUM By: IV-r- Victor A. Neubaum, Esquire 42 South Duke Street York, PA 17401 (717) 843-8001 S.I.D. #29159 Attorney for Petitioner -2- „F IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA F. ALLEN FRERE, : No. 2001-4916 Plaintiff VS. LUCETTE L FRERE, : No-Fault Divorce under Defendant : §3301(c) or §3301(d) CERTIFICATE OF SERVICE I certify that I have this lq#L, day of October, 2001, served a copy of the Petition for Related Claims upon the person and in the manner indicated below, which service satisfies the requirements of Pa.R.C. P. 440: SERVICE BY FIRST CLASS MAIL. POSTAGE PREPAID. ADDRESSED AS FOLLOWS: Thomas S. Diehl, Esq., One West High Street, Suite 208, P.O. Box 1290, Carlisle, PA 17013, Attorney for F. Allen Frere. MALONE & NEUBAUM BY: Victor A. Neubaum, Esq. 42 South Duke Street York, PA 17401 (717) 843-8001 S.I.D. # 29159 Attorney for Petitioner -3- (? ?C v 1,10 21 ) ? i?, C7- F. ALLEN FRERE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. LUCETTEI.FRERE, Defendant CIVIL ACTION - LAW NO. 2001-4916 CIVIL TERM IN DIVORCE PRAECIPE TO THE PROTHONOTARY: WITHDRAWAL OF APPEARANCE Please withdraw my appearance on behalf of the Plaintiff in the above-captioned matter. Date: ENTRY OF APPEARANCE Please enter my appearance on behalf of the Plaintiff in the above-captioned matter. Respectfully submitted, Date: ?42 - C. Bornman, Esquire GRIFFIE & ASSOCIATES 200 North Hanover Street Carlisle, PA 17013 (717) 243-5551 (800) 347-5552 I West High Street P.O. Box 1290 Carlisle, PA 17013 rm r"o c9 t\y -?? i N STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 WOLF & WOLF 10 WEST HIGH STREET CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF F. ALLEN FRERE, Plaintiff : IN THE COURT OF COMMON YLhAS ur : CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-4916 CIVIL IN DIVORCE V. LUCETTE I. FRERE, Defendant PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about August 21, 200 land served upon the defendant on September 4, 2001 (see Affidavit of Service previously filed). 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of the 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 divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C S. Section 4904 relating to unworn falsification to authorities. 7 )2007 F. ALLEN FRERE ?.-., r? t.! ?=; ?--i ?' -r ?? -a .:. 4.7 ?? r tF ... ?_) ?? ..,,,.[ "a,. IN THE COURT OF COLON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA F. ALLEN FRERE, : No. 2001-4916 Plaintiff ; VS. s LUCETTE I. FRERE, No-Fault Divorce under Defendant §3301(c) or 93301(d) AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under §3301(c) of the Divorce Code was filed on August 21, 2001. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of Notice of Intention to Request Entry of the Decree. VERIFICATION I verify that the statements in this Affidavit are true and correct. I understand that false statements herein are made subject-to the penalties of 18 Pa. C.S.A. §4904 relating to unsworn falsifications to authorities. Date: P-69 /P _"'" 40e 0 ucet te I. Frere, Defendant C= (D C=D rr ` f'e'e -, pli IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA F. ALLEN FRERE, Plaintiff VS. LUCETTE I. FRERE, Defendant : No. 2001-4916 s : No-Fault Divorce under : §3301(c) or 53301(d) WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of 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. VERIFICATION 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.A. §4904 relating to unsworn falsification to authorities. Date 7 _ *ucAeOtte I?.Frer?e,,Def t ndant C=l mss, t •' __. y t"`?.-. F. ALLEN FRERE, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 01 - 4916 CIVIL LUCETTE I. FRERE, Defendant IN DIVORCE ORDER OF COURT AND NOW, this 0` v' day of 2007, the economic claims raised in the proceedings having been resolved in accordance with a property settlement agreement dated July 27, 20071 (agreement affirmed and signed by parties and counsel in Master's Office on November 271 2007), the appointment of the Master is vacated and counsel can file a praecipe transmitting the record to the Court requesting a final decree in divorce. BY THE COURT, ?f cc: vStacy B. Wolf Attorney for Plaintiff Edgar B. Bayley, P.J. I A. Neubaum 'ctor Attorney for Defendant t- c•'7 t= LIJ ( . r- iL' - . q Lu CV 0 CV PROPERTY SETTLEMENT AGREEMENT -M OJU,/ 2007, at Carlisle, THIS AGREEMENT made this ( day of Y Cumberland County, Pennsylvania, between LUCETTE I. FRE , he in referred to as "Wife" and F. ALLEN FRERE, herein referred to as "Husband." 1. DATE OF MARRIAGE: The parties were. married on June 2, 1973 at Tarentum, Pennsylvania. 2. CHILDREN OF THE PARTIES: The parties have two children born of this marriage, both now adults. 3. SEPARATION OF PARTIES: As a result of the irretrievable breakdown of the marriage, unhappy differences have arisen between the parties, and as a result, the parties are desirous of settling their financial and property rights. The parties have been separated since February 26, 1999, with the Wife having as her address 3940 Beaver Dam Church Road, Roseboro, NC 28382, and the Husband having as his address 95 Fanus Road, Gardners, PA 17324. 4. INTENT TO LIVE APART: The parties intend to live apart from each other and to maintain separate households. The purpose of this Agreement is to settle fully and finally their respective financial and property rights as between each other without limitation and to set out the respective rights and duties of the parties while they continue to live apart from one another. 5. SETTLEMENT OF PROPERTY: The parties have divided their marital property in the manner which conforms to a just and right standard, and to those standards set out in §3502 of the Divorce Code of 1980, as amended, 23 Pa. C.S.A. §3502, with due regard to the rights of each parry. The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets. The division of property under this Agreement shall be in full satisfaction of all marital rights of the parties. 6. ENFORCEABILITY AND CONSIDERATION: This Agreement shall survive any action of divorce and decree of divorce and shall forever be binding and conclusive on the parties, and independent legal action may be brought to enforce the terms of this Agreement by either the Husband or Wife until it shall have been fully satisfied and performed. Furthermore, the parties agree that this Agreement shall be incorporated into but shall not merge, with a divorce decree to be entered in this case by the Court of Common Pleas of Cumberland County, Carlisle, Pennsylvania, at No. 2001-4916, for the purpose of enforcement of any of the obligations of this Agreement, pursuant to §3105 of the Divorce Code, as amended, 23 Pa. C.S.A. §3105. The consideration for this Agreement is the mutual benefits to be obtained by each of the parties hereto and the covenants and agreements of each of the parties to the other. The adequacy of the consideration for this Agreement is admitted by the parties. Each of the parties intends to be legally bound by this Agreement. &VAu4- 7. MARITAL ESTATE: The parties agree that the marital estate to be divided is comprised of the following items at the values designated: l! A. Real Estate at 95 Fanus Road, Gardners, PA 17324 $ 130,000.00 B. PPG Stock $ 7,991.36 -2- C. Lear Corp. 401-K Plan D. Cornerstone F.Cr.U. IRA E. Sovereign Bank IRA F. Other personal property TOTAL VALUE $ 56,538.89 $ 7,701.97 $ 1,745.44 (No assigned value) $ 203,997.66 The parties agree that the assigned value to each party under this agreement will be $101,988.83 of value in the marital estate to each party, along with the assignment of personal property as set forth herein. 8. REAL ESTATE: The parties own real estate at 95 Fanus Road, Gardners, PA 17324. Both parties recognize that the Husband wants to retain this property and that he does not want it sold to complete this agreement. The parties agree that the real estate is valued at $130,000.00 for the purpose of the division of marital property under this Agreement and that the real estate shall be awarded to the Husband. Husband shall within days of the date of the signing of this Agreement fulfill the other terms of this Agreement as set forth herein, and Wife shall then convey her interest in the real estate by quitclaim deed to the Husband provided that Husband fulfills his obligations under this Agreement and Wife receives compensation for her share of the house under this Agreement. w A. Husband shall within the edays of the date of signing the Agreement fulfill the other terms of this Agreement as set forth herein. The Wife, upon fulfillment of those terms by Husband, shall then convey her interest in the real estate by quit claim deed to the Husband. ?f B. If Husband does not fulfill his obligations under this Agreement within the d0 days, the real estate at 95 Fanus Road, Gardners, PA shall be listed by the parties with a realtor for -3- immediate sale. This action, if necessary, is to obtain payment for unfulfilled obligation of any balance due to the Wife as outlined in other provisions of this Agreement. Furthermore, should the sale of the property be required, the costs of sale will be divided equally between both parties. The Wife will be paid first at settlement for any balance due her from the Husband's other unpaid obligations outlined in this Agreement. The Husband will retain the remainder of the funds received at settlement for the house. Otherwise, Husband shall thereafter be solely responsible for the payment of all indebtednesses, taxes, insurance and upkeep of his property without contribution by the Wife. Husband agrees to indemnify and hold harmless the Wife in the event that the Wife is sought by any third parties to be held accountable for any payment, tax, insurance, or upkeep payment in connection with the property. After the signing of this agreement, it is the sole responsibility of the Husband to keep and maintain 95 Fanus Road, Gardners, PA. 9. PERSONAL PROPERTY: A. Husband will return to the Wife and Wife will be awarded the following items of personal property: (1) Daughter's senior picture; (2) Some small personal items including books and LPs; (3) A large wall mirror that was Wife's grandmother's and inherited by Wife from Aunt: (4) Two (2) single beds made from Maple that were Wife's as a child and a gift from her parents; (5) Childhood doll furniture: highchair and bunk bed; (6) Fiesta dinnerware Wife owned prior to marriage; -4- Flatware; gift to Wife from her aunt. # ? /.- (7) Antique Victrola, passed down though Wife's family that was gift from brother; .14 Xwood rocking horse, gift from brother; and 1 ? (10) Double Bubble gum machine, gift from brother B. Husband shall provide a cashier's check to the Wife for the entire current balance and holdings of Husband's Lear Corpo'a?ion 401-K Plan in his declared amount, which was St1 YS o° /J*J' $i 2AO'7 . '14 05 , 9.8`9, as of This amount, liquidating the account, shall be the actual amount in the account at the time of closing but not less than the declared amount unless caused by market conditions. As part of this Agreement, this cashier's check will be used by the Wife to set uip her own IRA identified as a rollov?,r from the Husband's 401-K. '14 C. Husband shaR retain the 104 shares of PPG stock, paying to Wife her share of the value of the stock, as set forth later in paragraph F. D. Husband shall retain his IRA at Cornerstone Federal Credit Union, paying to Wife ie ? y, 000 •s a..,.. /D?jN'?-c,,•'?iv`?(C?.? ?is,? • ?-? ?i `? E. Wife shall retain her IRA with Sovereign Bank in the value of the entire proceeds. 71,q2-6-13 1,C- " F. Husband shall pay to Wife the sum of $45,449-9?4 with a cashier's check representing her share of the value of the real estate at 95 Fanus Road, u»&bnr ' "P6 dock and Husband's G?e Cornerstone Federal Credit Union IRA in order to effectuate an equal division of the value of marital assets herein. Except to the extent set forth in this paragraph, the parties have otherwise divided the personal property of the marriage to their mutual satisfaction. Wife will have as her separate property all those items of personal property, including all bank accounts, currently titled in her -5- name or currently in her possession as of the date of the divorce. Husband shall have as his separate property all those items of personal property, including all bank accounts, currently titled in his name or currently in his possession as of the date of the divorce. Each party shall, to the extent that each has not already done so, and when and where necessary, execute any and all documents of title or other instruments of conveyance so as to establish the sole ownership of any and all property in the other spouse including, but not limited to, the signing of any documents necessary for the change of title of any automobile assigned to either spouse as a result of this Agreement, or any other property titled in the name of either spouse, or awarded to either as a result of this Agreement; necessary for the changing the beneficiary of any life insurance policy; and necessary for releasing or relinquishing any right, title or interest in any survivor benefit of any pension, profit sharing, Individual Retirement Account or other retirement plan in the name of the other spouse. Each party shall be fully responsible for the maintenance and payment of any insurance for any items of personal property belonging to each as a result of this Agreement. Each of the parties hereby transfers, conveys and assigns to the other all right, title and interest that each may have in such personal property currently in the possession of the other party and awarded pursuant to this paragraph. 10. RETIREMENT: As part of the consideration for this Agreement, and except as otherwise set forth in this Agreement, each party will have as his or her separate property all right, title and interest in any pension, profit sharing, retirement or individual retirement account, or stock options, or any other employee derived benefit that each has in his or her name or will have at any future time. Each party by this Agreement waives any right, title or interest in the -6- pension, profit sharing, retirement, stock options, or Individual Retirement Account of the other party now or in the future. 11. DEBTS: After the date of this agreement, each party shall be solely responsible for all debt in the name of each party. 12. GENERAL RELEASE OF ALL CLAIMS: Each party hereto releases the other from all claims, liabilities, debts, obligations, actions, and causes of actions of every kind that have been incurred relating to or arising from the marriage between the parties. However, neither party is relieved or discharged from any obligation under this Agreement or any other instrument or document executed pursuant to this Agreement. Further, Husband and Wife do hereby waive, release and give up any rights each may have respectively against the other for alimony, spousal support or maintenance, for the equitable distribution of marital property, or for payment of counsel fees and expenses, all pursuant to the Divorce Code. It shall be, from the date of the execution of this Agreement, the sole responsibility of each of the respective parties to sustain himself or herself without seeking any support from the other party. 13. WAIVER OF ESTATE CLAIM: Each party hereby waives, releases and relinquishes any and all rights that he or she may now have or may hereafter acquire as the other party's spouse under the present or future laws of any jurisdiction (a) to elect to take against any Will or Codicil of the other party now or hereafter in force; (b) to share in the other party's estate in case of intestacy; and (c) to act as Executor or Administrator of the other parry's estate. 14. FULL DISCLOSURE: Each party guarantees that he or she has made a full and complete disclosure of all of the real and personal property of whatsoever nature and wheresoever located belonging in any way to each of them, of all debts and encumbrances incurred in any manner whatsoever by each of them, of all sources and amounts of income received or receivable by each party, and of every other fact related in any way to the subject matter of this Agreement. These disclosures are a part of the consideration made by each party for entering into this Agreement. 15. RIGHT TO LIVE SEPARATELY AND FREE FROM INTERFERENCE: Each party shall live separately and apart from the other party at any place or places that he or she may select. Neither party shall molest, harass, annoy, injure, threaten, or interfere with the other party in any manner whatsoever. Each party may carry on and engage in any employment, profession, business or other activity as he or she may deem advisable for his or her sole use and benefit. Neither party shall interfere with the use, ownership, enjoyment or disposition of any property now owned or hereafter acquired by the other. 16. AGREEMENT VOLUNTARILY AND CLEARLY UNDERSTOOD: Each party to this Agreement acknowledges that he or she: A. Is fully and completely informed as to the facts relating to the subject matter of this Agreement and as to the right and liabilities of both parties; B. Enters into this Agreement voluntarily, after receiving the advice of independent counsel, or after having had the opportunity to receive the advice of independent counsel; C. Has given careful and mature thought to the making of this Agreement; D. Has carefully read each provision of this Agreement; and E. Fully and completely understands each provision of this Agreement, both as to the subject matter and legal effect. -8- 17. WAIVER OF MARITAL CLAIMS: The parties acknowledge that the Divorce Code grants to the court the right and duty to determine all marital rights of the parties including divorce, alimony, alimony pendente lite, spousal support, equitable distribution of all marital property or property owned or possessed individually by the other, counsel fees and costs of litigation. Each party has consulted with independent legal counsel, or has had the opportunity to consult with independent legal counsel and has foregone such opportunity, and each party hereto still desires to execute this Agreement acknowledging the terms and conditions set forth herein are fair, just and equitable to each of the parties, and each waives his or her respective right to have the Court of Common Pleas of Cumberland County or any other court of competent jurisdiction to make any determination or order affecting the respective parties' right to a divorce, alimony, alimony pendente lite, spousal support, equitable distribution of all marital property, property acquired by a party before marriage and after divorce, counsel fees and costs of litigation. Furthermore, each party waives: (1) the right to have the other party provide a complete list of all the property and debts existing at the time of separation; (2) the right to have all and any property formally valued or appraised at a cost paid by the parties; (3) the right to obtain a statement of the income and expenses of the other party; (4) the right to have a court decide the property and its value to be divided between the parties and any property or value not subject to division; and (5) the right to have the Court define the rights and obligations of the parties. This paragraph is intended to be a complete and absolute waiver of any and all rights that each may have under the Divorce Code of 1980, as amended. 18. BANKRUPTCY: The parties acknowledge and agree that they have specifically structured this Agreement so that the terms, covenants and conditions set forth herein are non- dischargeable in bankruptcy, under 11 U.S.C.(a)(5), §523(a)(15) of the Bankruptcy Code. The -9- obligations and payments set forth herein are intended to be an equitable distribution of property and not a payment in the nature of support or alimony. 19. DEFAULT: If either party fails in the due performance of any of the material obligations stated hereunder, the other party shall have the right, at his or her election, to sue for damages for breach hereof, or to seek any other legal remedy as may be available to him or her. Such remedies shall include the payment of reasonable attorney's fees, costs, or any other expense that either party incurs as a result of enforcing this or her rights against the other party who defaults under this Agreement or who fails to perform his or her obligations under this Agreement Any failure to perform any obligation by either party under this Agreement will be considered a default or breach of this Agreement subject to immediate enforcement by the non- defaulting party, in law or in equity, or under the Divorce Code, as amended. Nothing contained herein shall be construed to restrict or impair each party's right to exercise this election. 20. SUBSEQUENT DIVORCE: The parties acknowledge and agree that a divorce action has been instituted in the Court of Common Pleas of Cumberland County at No. 2001- 4916. The parties agree that upon the completion of all the obligations as set forth under this Agreement, Husband and Wife shall sign the necessary Affidavits of Consent and Waivers of Notice to complete the divorce, and Husband's counsel, as the moving party, shall refer the case to the court for the entry of a final decree in divorce. 21. AMENDMENT OR MODIFICATION: This Agreement shall not be subject to modification by the court. This Agreement shall be amended or modified only by a written instrument signed by both parties. 22. COMPLETENESS: This Agreement, together with any documents that may be executed in conjunction herewith, constitutes the entire understanding between the parties and -10- there are no covenants, conditions, representations, or agreements, either oral or written, or any nature whatsoever, other than those contained herein. 23. PARTIAL INVALIDITY: If any provision of this Agreement is held to be invalid or unenforceable, all other provisions shall nevertheless continue in full force and effect. 24. LAW GOVERNING AGREEMENT: This Agreement, including matters of custody and partial custody, shall be governed by, and shall be construed in accordance with the laws of the Commonwealth of Pennsylvania, as of the date hereof. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the date first above written. WITNESS: ucette I. Frere 3940 Beaver Dam Church Road Roseboro, NC 28382 Allen Frere 95 Fanus Road Gardners, PA 17324 COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF YORK . On this, the o? 77% day of 2007, before me the undersigned officer, a Notary Public in and for said County and Commonwealth, personally appeared Lucette I. Frere, known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that she has executed the foregoing Agreement for the purposes therein contained. IN WITNESS WHEREOF I have hereunto set my hand and official seal. COMMONWEALTH OF PENNSYLVA JL "- (SEAL) My Commission Expi NOTARIAL SEAL Notary Public PAULINE E. GIMA, Notary Pudic City Of York, York County MY Commission Expires Febrt&,Rt :2010 -¢ nary ....,?....J COMMONWEALTH OF PENNSYLVANIA' SS COUNTY OF YORK On this, the day of , 2007, before me, the undersigned officer, a Notary Pilbj?c in and for said County and Commonwealth, personally appeared F. Allen Frere, known to me, (or satisfactorily proven) to be the person whose name is subscribed to the within instrument and acknowledged that he has executed the foregoing Agreement for the purposes therein contained. IN WITNESS WHEREOF I have hereunto set my hand and official seal. My Commission Expires: Notary Public (SEAL) -12- 6 STACY B. WOLF, ESQUIRE ATTORNEY ID NO. 88732 10 WEST HIGH STREET CARLISLE PA 17013 (717) 2414436 ATTORNEY FOR PLAINTIFF F. ALLEN FRERE, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. LUCETTE I. FRERE, To the Prothonotary: : NO. 01-4916 CIVIL Defendant : IN DIVORCE PRAFCIPE TO TRANSMIT RECORD Please transmit the record, together with the following information, to the court for entry of a divorce decree: Ground for divorce: Irretrievable breakdown under Section 3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: On or about August 28, 2001, defendant was served with a copy of the divorce complaint via certified mail. (See Affidavit of Service previously filed September 4, 2001) 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: Bythe plaintiff: November 27, 2007. By the defendant: November 27, 2007. (b)(1) Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A. (b)(2) Date of filing and 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: N/A. (b) Date plaintiff's Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: November 27, 2007. Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: November 27, 2007. December 2007 A STACY B. WOO 0 Attorney for Plaintiff ?; C? --n ;, 1, ?.;,.? r,i 4..; f ? ??_!_ i `? y a ? -• .4W ,• k_ ? .. '^ ? x '??. l .. ? l . r ' ^, f„} ; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PRAOLVANIA F. ALLEN FRERE, VS. LUCETTE I. FRERE, Plaintiff : No. 2001-4916 : No-Fault Divorce under Defendant : §3301(c) or §3301(d) PETITION TO DISMISS THE DIVORCE ACTION ON ACCOUNT OF DEATH OF PLAINTIFF BACKGROI,TND 1. The Petitioner is Lucette I. Frere, who resides at 3940 Beaver Dam Church Road, Roseboro, NC 28382. Petitioner is represented by Victor A. Neubaum, Esq. 2. The Respondent is the late F. Allen Frere, who resided at 95 Fanus Road, Gardners, PA 17324. Respondent died December 4, 2007. Respondent was represented in all past proceedings by Stacy Wolf, Esq. 3. The above captioned parties in this divorce had resolved all issues concerning equitable distribution on November 27, 2007, at a hearing before the Divorce Master. 4. By order of November 28, 2007, the Court vacated the appointment of the Master. 5. On December 4, 2007, Attorney Wolf praeciped the Court for the entry of a final decree in divorce. 6. On the same date, December 4, 2007, Plaintiff, F. Allen Frere, died unexpectedly. PETITION 7. 23 Pa.C.S.A §3323(d.1) controls the current circumstances. "In the event one party dies during the course of divorce proceedings, no decree of divorce has been entered and grounds have been established as provided in subsection (g), the parties' economic rights and obligations arising under the marriage shall be determined under this part rather than under 20 Pa. C. S. (relating to decedents, estates, and fiduciaries.)" 8. Plaintiff died before the entry of the final decree in divorce, but the grounds for divorce have been established pursuant to 23 Pa.C.S.A. §3323(g), with the filing of the parties Affidavits of consent. The parties have also resolved their economic issues before the Master. 9. As a result, Petitioner argues that the divorce action has abated and the Court has no power to decree a divorce between the parties, but that the resolution of the economic issues as established by the Agreement between the parties is enforceable against the estate of the deceased Plaintiff. 10. As a further result, there is no action for the Court to take in the divorce case and the divorce action should be dismissed. MALONE & NEUBAUM B Y• Victor A. Neubaum, Esq. 42 South Duke Street York, PA 17401 (717) 843-8001 S.I.D. # 29159 Attorney for Petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA F. ALLEN FRERE, : No. 20014916 Plaintiff VS. ' LUCETTE L FRERE, : No-Fault Divorce under Defendant : §3301(c) or §3301(d) CERTIFICATE OF SERVICE I certify that I have this 6' day of December, 2007, served a copy of the PETITION TO DISMISS THE DIVORCE ACTION ON ACCOUNT OF DEATH OF PLAINTIFF upon the person and in the manner indicated below, which service satisfies the requirements of Pa.R.C.P. 440: SERVICE BY FIRST CLASS MAIL. POSTAGE PREPAID ADDRESSED AS FOLLOWS: Stacy B. Wolf, Esq., 10 West High Street, Carlisle, PA 17013, Attorney for Plaintiff MALONE & NEUBA ltr.-14 BY. Victor A. Neubaum, Esq. 42 South Duke Street York, PA 17401 (717) 843-8001 S.I.D. # 29159 Attorney for Defendant n tV ? C r-n C-0 -i F. ALLEN FRERE, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. LUCETTE I. FRERE, DEFENDANT 01-4916 CIVIL TERM t 4'4' ORDOF COURT AND NOW, this 42 day of December, 2007, a Rule is entered against F. Allen Frere, to be served on his counsel, as to why the complaint for divorce should not be dismissed. Rule returnable twenty (20) days from the date of service. Any answer filed shall be forwarded by the Prothonotary to chambers. By the Court, Edgar B. Bayley, J. Stacy Wolf, Esquire For Plaintiff Victor A. Neubaum, Esquire For Defendant :sal (2-crlw 4tt?t-L(- lzl&lo7 ?:?l t !? C-j ! . r?Yl? 1 i? ?g ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA. F. ALLEN FRERE, VS. LUCETTE L FRERE, : No. 20014916 Plaintiff : No-Fault Divorce under Defendant : §3301(c) or §3301(d) PETITION TO MAKE ABSOLUTE RULE TO SHOW CAUSE WHY DIVORCE ACTION MULD NOT BE DISMLSSED ON ACCOUNT OF DEATH OF PLAINTIFF BACKGROUND 1. The Petitioner is Lucette I. Frere, who resides at 3940 Beaver Dam Church Road, Roseboro, NC 28382. Petitioner is represented by Victor A. Neubaum, Esq. 2. The Respondent is the late F. Allen Frere, who resided at 95 Fanus Road, Gardners, PA 17324. Respondent died December 4, 2007. Respondent was represented in all past proceedings by Stacy Wolf, Esq. 3. The above captioned parties in this divorce had resolved all issues concerning equitable distribution on November 27, 2007, at a hearing before the Divorce Master, written agreement. 4. By order of November 28, 2007, the Court vacated the appointment of the Master, noting the resolution of the parties' issues on equitable distribution by written agreement, which was made a part of the record. 5. On December 4, 2007, Attorney Wolf praeciped the Court for the entry of a final decree in divorce. 6. On the same date, December 4, 2007, Plaintiff, F. Allen Frere, died unexpectedly. -1- 7. 23 Pa.C.S.A §3323(d. l) controls the current circumstances. "In the event one party dies during the course of divorce proceedings, no decree of divorce has been entered and grounds have been established as provided in subsection (g), the parties' economic rights and obligations arising under the marriage shall be determined under this part rather than under 20 Pa. C. S. (relating to decedents, estates, and fiduciaries.)" 8. Plaintiff died before the entry of the final decree in divorce, but the grounds for divorce have been established pursuant to 23 Pa.C.S.A. §3323(g), with the filing of the parties Affidavits of Consent. The parties have also resolved their economic issues before the Master. 9. As a result, the divorce action has abated and the Court has no power to decree a divorce between the parties, but that the resolution of the economic issues as established by the Agreement between the parties is enforceable against the estate of the deceased Plaintiff. 10. As a further result, there is no action for the Court to take in the divorce case and the divorce action should be dismissed. PETITION TO MAKE ABSOLUTE RULE TO SHOW CAUSE 11. Pursuant to a Petition to Dismiss the above captioned divorce action filed by Lucette 1. Frere, this Honorable Court issueD a Rule against F. Allen Frere, to be served on his counsel, why the above captioned divorce action should not be dismissed. A copy of the Rule is attached hereto. 12. The docket indicates that the Order of Court issuing the Rule was mailed by the Prothonotary to Stacy Wolf, Esq., Counsel of Record for F. Allen Frere, on December 11, 2007. 13. No response has been made by any person pursuant to the Rule. 14. Defendant, Lucette 1. Frere, requests this Court to make absolute the Rule to Show Cause, and to enter the proposed Order of Court. MALONE & NEUBAUM ? By: Victor A. Neubaum, Esq. 42 South Duke Street York, PA 17401 (717) 843-8001 S.I.D. # 29159 Attorney for Petitioner -2- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA F. ALLEN FRERE, VS. LUCETTE L FRERE, : No. 20014916 Plaintiff : No-Fault Divorce under Defendant : §3301(c) or §3301(d) CERTIFICATE OF SERVICE I certify that I have this day of January, 2008, served a copy of the PETITION TO MAKE ABSOLUTE RULE TO SHOW CAUSE WHY DIVORCE ACTION SHOULD NOT BE DISMISSED ON ACCOUNT OF DEATH OF PLAINTIFF upon the person and in the manner indicated below, which service satisfies the requirements of Pa.R.C.P. 440: SERVICE BY FIRST CLASS MAIL. POSTAGE PREPAID. ADDRESSED AS FOLLOWS: Stacy B. Wolf, Esq., 10 West High Street, Carlisle, PA 17013, Attorney of record for Plaintiff MALONE & NEUBAUM ?I X Y. ??' `` B Victor A. Neubaum, Esq. 42 South Duke Street York, PA 17401 (717) 843-8001 S.I.D. # 29159 Attorney for Defendant -3- ,? F. ALLEN FRERE, PLAINTIFF V. LUCETTE I. FRERE, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-4916 CIVIL TERM ,t ORDER OF COURT AND NOW, this 64--., day of December, 2007, a Rule is entered against F. Allen Frere, to be served on his counsel, as to why the complaint for divorce should not be dismissed. Rule returnable twenty (20) days from the date of service. Any answer filed shall be forwarded by the Prothonotary to chambers. By the Court, Edgar B. Bayley, J. Stacy Wolf, Esquire For Plaintiff Victor A. Neubaum, Esquire For Defendant :sal in qie .e ?1, I here unto Jai m hand ti?a S Ili of said rt at Carle, Pa. duly -111CA ?? ?:=? -, ?`? `?°-- ' °??`_ -r-s .;:.y. ? .«." j' e'1 ?:...: " Tl -?7 p -- ::?? 5 c I F. ALLEN FRERE, PLAINTIFF V. LUCETTE I. FRERE, DEFENDANT IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 01-4916 CIVIL TERM ORDER OF COURT AND NOW, this `ZLA day of January, 2008, IT IS ORDERED that the above-captioned divorce action, IS DISMISSED. By the Edgar B. Bayley, Stacy Wolf, Esquire For Plaintiff Victor A. Neubaum, Esquire For Defendant sal COP to-.T M:RLL(, ??ayla8 ` -? ?:? u ? r`' -- ._..... .. r? 'a .... _.. ?Y. t _ _?! t _, _ ",r ?-.?? ?? ?? ' -' -; tL ? ?? N C..?