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HomeMy WebLinkAbout99-01439 .0 :):x~ ~:;)%: ..,:';,. . -:~[\ "0".1' " ~ . ~ .~ .~ f _~ .,~, <;)>. ""'}11i!i ': :~A~;~( , "';";,". ,....,':,~11: .':,}:'/; )~~ -l~! ",):\~~ "..,,:,,~ .,,'::'!.j#~~ . ,,,~.~t . -":i~l ,\"":'~~}; )~1 ::;}{;-~ ""J:' .. :)' ~ , .. .- ,~' """. ;?; ........, PATRICIA E. WILLIAMS, PlaintilT : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : CIVIL ACTION - LAW . NO, <)9 -l'iJ7CIVIL TERM . IN UIVORCE CLINT WILLIAMS, Dcfcndant NOTICE TO DEFEN/) AN/) CLAIM RIGIITS YOU HA VE 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 jf you fail to do so, the c~se 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 grounds for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counselling. 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 MA Y LOSE THE RIGHT TO CLAIM ANY OF THEM, YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VE 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 A venue Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 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 thcilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. James J. Kayer, Esquire Attorney for Plaintiff' Liberty Loft 4 East Liberty A venue Carlisle, P A 17013 (717) 243-7922 -1.-............ . ~ C1 r;: "I ,.: \.:.... ...J ~. .. ~ '.. ~ q: ~,: '0 I ?iE 8 Q r,'" .' ~ - Vi f) 10 . . . ~ , j I..' _.. ~ . -,1. ~ ~ ~ 1_; Ol ~''; ':11 .J ~ ~ t../J (J .,", 0.L c: OCT. . Ill"' - ::l.~ - 'P' . (;;' ""C '"' ~ji ~ ~.~ ...... ""0 - tI) CD ...:::I,~ . S!!..... '" a ... g Dl t\~.m !!!. ~ 1.0::1,,0 "" .......n1.r- (").... ~~.[ ~ ~. .;' .:....-<:. Q 0 ..._la''''' 0- _. <:; ..... (i; ,0 ::J "'::I ::I c: "' " '>. ,... r-: 1r; lr, j,: c~; .' ," ,I... '.11 '. (. )t \. ) ;: ~J !:. u: '-';.;: c.:J,' ')~ /,' (', "?fJ 1:.__ J,'.,. ~i: ' , 0: r.~ IICl) , : :..:: ~~-! u.. - t'': & .J <::.> Q c: 016 ~~ ~b ~Jl> ~ ~"tl ~~ . 1\)::1'" e;~ fT1 ~~C CO::l CT ""-'ctJ I\)~~ ...)> 0< ~"' "'::I c: "' )>" ~Q) -'< "' /I) ~ ., O' III ::I ::J !!!.Q. Qm -g a ~:E g ~ . '. c. PATRICIA E. WILLIAMS, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYLVANIA vs. : CIVIL ACTION. LA W : NO. 99 - 1439 CIVIL TERM n C> t~~. " ;...: "to, .". PII .'J " ,'i :.:. i <-e I (Jl, ,-:. ,~ ["';'1.; ...., " .- " :, i-: ; ~ fer. , ," ~~.'.: t.:? , ~ ',. ~ ~ .. m CI.INT WILI.IAMS, Defendant ; IN DIVORCE AFFIDAVIT OF CONSENT J. A Complaint in divorce under Section 3301(e) of the Divorce Code was filed on March 10, 1999. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3. I consent to the entry ofa final decree of divorce after service of notice of intention to request ntry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if! 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 herein are made subject to the penalties of 18 Pa. C.S. section 4904 relating to unsworn falsification to authorities. Date; I mbf 01 (J'/J W~ CLINT WILLIAMS ,. Co /', r:.: " , lr, ,"l - ; <oj Cr: . )"';' ': " j';"-; 'J ~;.. .. I, '.)~:; J,l ~j ,-, ';1 :1;; (,.'. ~: 'J'-~i ; :.~ _'.I(.L.. - /, - ::3 () 0 Q c: 016 ~~ ~r- ~-'" ~ ~"O ..:::I ~ . I\)::I.j> ~~ rn , < ~ ""Ill ..... co"CT N -. m I\)~q . ""> 0< ~" "'::I c: " >" "Ow a,< " /I) !ll ., o'lll " :;, !!!.Q. lim -ga ~:E g :;, "'- " ". c: ~16 2,~ ~r- ~Jl>~ ~"O .::lm. NSl:lo ...cnm Go:I~. ~~C "'::ICT N -'co I\)~~ "")> 0< ~m "'::I " m ~ al G 1- ~ lJ'l . frU~~~ .. ~, ("': ('3.'~ <<;:,) ~ -., "- _I;::: 1"4' ;)1 n. ".1;',; 1 , ,:..., 'f", , ," '1::~ '. r;n . . " . d . J(J.., -. , ; (.:> i;) >" "Oil) S,w- "'CD ~ ., 0' III iil :s tic. om il ., o 0 ~:E g ~ '" .: PATRICIA E, WILLIAMS. I'laintin' , IN TIlE COURT OF COMMON ('LEAS OF , CUMBERLAND COUNTY.I'ENNSYLVANIA vs, , CIVIL ACTION. LAW : NO, l)l) . 1439 CIVIL TERM CLINT WILLIAMS. Defendant . IN DIVORCE AFFIDA VIT OF SERVICE BY MAIL PURSUANT TO Pa. R.C.P. 1920,4(al(l)(ii) COMMONWEALTH OF PENNSYL VANIA : SS, COUNTY OF CUMBERLAND I, James J. Kayer, Esquire, being duly sworn according to law. deposes and says that he is the attorney for Plaintiff, PATRICIA E. WILLIAMS. and that he did serve a true and correct copy of the Notice to Defend and Complaint in Divorce that was tiled in the above maller, by U.S. Mail, postage prepaid, certified with restricted delivery, return receipt requested. unto the Defendant. CLINT WILLIAMS, on March 15. 1999, The return receipt is attached hereto. l , / . " i J//}l James J. ayer. ;WOJ:!Ito and subscribed befPreim: thi1,' 181 day of March. 1999, ) I . ---'" J ,n' , . urr--Q'I^...n Notary Pub c , NOT ARIAL SEAL DENISE PlNAMONTI. NOlaI)' Pubhc Carlisle Borough,. Cumberland2go~~rib ___~./IV C~.:::~I_t:?:n E1plres Nov. - . i . .CompIU", 11ltd1Of 2 fof additIonII MMceI. .CompIUbnw~"'q;lnd 4b. I -Print)'OW nIme and .dd..... on ItMI ~ 01 thII form 10 thai we can retOOl thI, cord to you. -Altech d1II form to the fronl of the mallpIece, Of' an the bide It space doN noI .=!Rann RM>>IpI R~ed.on the maHp6ece beIowthl artIcIt number. J -The Rtl:~ Receipt wUllhow 10 whom thllltlde wa. dlUYIted and the~. Selol- 13, Mde Addressed 10: Q \1. "\..\. will (, Cl "-l S ,l..( 0 t\.t 'fT', brvo l<. C ire (e \"..1 'llL ; /,t~,jVJ\Y-~ \ V\, Y .' ' ()ir'0\.{0 , , "1;, I also wish 10 receive 1110 following service. (for an .xtre fe.): 1, 0 Addr....... Addr... !J 2. 81l.s1rlcted D.llv.ry .i Consult postmaster for fe.. f 48. Mde Number 15 2Y,\d. [. ~ 4b. Service Type ___ i! D Regls1ersd Q-Cirtlfied a: co D Express Mall D InslIred ~ Ipt for Mertllandso D COD " e~ ! " o >- ress (Only If reque.tBCI J ...... 1015'S.",!J.<l17, Domestic Retum Receipt . f,I,: I I. ._. " party. This Agrecrnent is not intended to condonc and shall not be deemed to be a condonation on the part of either party hereto of any act or acts on the part of thc othcr party which have oceurrcd prior to the date hereof. The parties intend to secure a mutual consent divorce. 2, EFFECT OF DIVORCE DECREE: The partics agree that unlcss otherwise specifically provided herein, this Agreernent shall continue in full forcc and cffect after such time as a final decree in divorcc may be entered with respect to the parties. 3. AGREEMENT TO BE INCORPORATED IN DIVORCE DECREE: The parties agree that the terms of this Agreement shall be incorporated but not merged into any divorce decree which may be entered with respect to them. 4. SEP ARA nON: It shall be lawful for each party at all times hereafter to live separate and apart from the other party as such place as he or she may from time to time choose or deem fit. The foregoing provisions shall not be taken as an admission on the part of either party of the lawfulness or unlawfulness of the causes leading to their living apart. 5, INTERFERENCE: Each party shall be free from interference, authority, and contact by the other, as fully as ifhe or she were single and unmarried except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the othcr, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other. 6, WIFE'S DEBTS: WIFE represents and warrants to HUSBAND that since their separation, she has not and in the future she will not contract or incur any debt or liability for which HUSBAND or his estate might be responsible and shall indemnifY and save harmless HUSBAND from any and all claims or demands made against him by reasons of debts or obligations incurred by her. 7, IIUSBAND'S DEBTS: HUSBAND reprcsents and warrants to WIFE that since separation he has not and in the future he will not contract or incur any debt or liability for which WIFE or her estate might bc responsible und shull indcmnify und suvc hannless WIFE from uny und all cluims or dcmunds made against her by reason of debts or obligations incurred by him. 8, MUTUAL RELEASE: Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, which either of the parties ever had or now has against the other, except any or all cause or causes of action for divorce and except any or all causes of action from breach of any provisions of this Agreement. 9, REAL PROPERTY: (a) Marital Residence: The marital horne at 40 Meribrook Circle, Willingboro, New Jersey 08046 shall be the property of the HUSBAND together with any lien thereon. Husband will or has just recently obtained a second mortgage upon the home. The purpose of the second mortgage is for husband to consolidate all joint debts. Husband shall be solely responsible for any and all liability arising from the second mortgage upon the marital horne and shall indemnify and save wife harmless from any and all claims or demands made against her by reasons of said obligation. Husband shall also indemnifY and hold wife harmless from any and all liability arising from the primary mortgage upon the marital home and it shall be husband sole responsibility to satisfY that mortgage. The primary mortgage shall be refinanced in the husband sole name within twenty-four (24) months from the execution of this agreement. Should the husband not secure such a refinance in a timely fashion, the property shall be listed for sale, Both parties shall fully cooperate with the listing agent in executing any and all documents relating to the sale of the home, preparing the home for sale including undertaking any repairs or renovations recommended by the listing agent and facilitating and fully cooperating in the sale of the home. The proceeds from the prospective sale of the home shall be equally divided between the parties aller the full satisfaction of the primary and secondary mortgages and all other transaction costs, At the time that the hushand receives a commitmentlellcr from any lender confil'lllingthc refinance of the primary mortgage, the wife shall be obligated to sign any deed or any other documents provided by the husband to convey any and all interest that she has in the marital home and convey such interest to the husband. (b) Time Share: HUSBAND has or will transfer any and all interest he may have in a time share in North Myrtle Beach, North Carolina to WIFE. The estimated value of this time share is $4,150.00. HUSBAND waives any right or interest he may have in the property, WIFE agrees to indemnifY and hold HUSBAND harmless from any and all liability arising out of her ownership thereof. 10. DIVISION OF PERSONAL PROPERTY: (a) The parties have heretofore divided their personal property to their mutual satisfaction. Henceforth, each of the parties shall own, have and enjoy, independently of any claim of right of the other party, all items of personal property of every kind, nature and description and wheresoever situated, which are now owned or held by or which may hereafter belong to the HUSBAND or WIFE respectfully, with full power to the HUSBAND or the WIFE to dispose of same as fully and effectually, in all respeets and for all purposes as if he or she were unmarried. All items of personal property shall be divided between the parties as provided herein: (b) Personal Effects: All iterns of personal effects such as, but not limited to: jewelry, luggage, sports equipment, hobby collections and books, but not including furniture or any property, personal or otherwise specifically disposed of pursuant to this agreement, shall become the absolute and sole property of that party who has had the principal use thereof or to whom the property was given or for whom it was purchased, and each party hcreby surrenders any interest he or she may have in any such tangible personal property of the other. (c) Intangible Personal Property (other than Life Insurance): All stocks, bonds, cash, and sums on deposit in checking and saving accounts (owned by either or both parties) have been or will be divided to the mutual satisfaction of the parties, (d) Military Pension: The HUSBAND recognizcs that his military pension is a property asset divisible as part of this property settlement agreement. Since thc parties have been married and lived as HUSBAND and WIFE for sixteen years of the HUSBAND's military service prior to this agreement, the HUSBAND agrees that forty percent (40010) of his disposable military pension shall be the sole and exclusive property of the WIFE. The WIFE waives any right in HUSBAND's Survivor Benefit Program, which is deemed property of the HUSBAND.. All amounts hereunder are to be paid by allotment from HUSBAND's Military Retirement Pay. (e) Debts: The HUSBAND shall be responsible for all existing joint debts and liabilities incurred by the parties prior to their separation except as otherwise provided herein. The HUSBAND shall also be responsible for all existing debts and liabilities incurred in his own name prior to the separation. The WIFE shall be responsible for all existing debts and liabilities incurred in her own name prior to the separation. (f) The parties further agree that neither will incur any future debts for which the other may be held liable, and if either party incurs a debt for which the other will be liable, that party incurring such debt will hold the other harmless from any and all liability thereon. (g) The vehicle currently in wifeDs possession shall be titled solely to the wife. Any and all liability attached to that vehicle shall be assumed by the husband and shall be paid at the time that he obtains the second mortgage on the family property. Wife shall be responsible for maintaining the vehicle and shall be responsible for insuring the vehicle, Any vehicle thai is in husbandOs possession al thc time of executing this agreement shall b;: and remain solely Ihe propcrty of the husband. 11. AFTER ACOUIRED PERSONAL PROPERTY: Each of the parties shall hereafter own and enjoy, independently of any claims or right of the other, all itcms of pcrsonal propcrty, tWlgihle or inlangible, hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respect and for all purposes, as though he or she were unmarried, 12. CUSTODY: Primary physical custody of the ehildrcn shall be with the wife, The parties shall share legal custody of the children, The husband shall have rcgular access to the children and specific periods of visitation will be during thosc times that the parties can agree, HUSBAND's pcriods of physical custody shall not exceed 7 days in duration unless the parties agree otherwise. He shall provide the WIFE with 30 days notice of his intention to exercise such a period of physical custody. Notwithstanding the above provision, December 25th each year shall be spent with the mother unless otherwise agreed by the parties. The parties agree that they will undertake all best efforts to confirm that HUSBAND's visitation will be scheduled so as not to interfere with extra curricular activities and school attendance. The HUSBAND shall not remove the children from the country without WIFE's prior consent. 13. ALLOWANCES TO WIFE AND CHILDREN: (a) The parties have entered into a support stipulation dated January 24, 2000 resolvong all issues of child support. (b) Without waiving rights under 13(a), the parties agree to absolutely waive any further right to spousal support, alimony or alimony pendente lite, (c) HUSBAND hereby agrees that WIFE and the aforesaid children shall continue to be entitled to use and enjoy all medical and dental services, commissary and post exchange privilege, and other services allowed to them as a result of HUSBAND's employment as a member of the United States Armed " Services. During the time that HUSBAND and WIFE arc married, although living separate and apart, WIFE shall continue to enjoy these benefits but upon divorce of the parties, these benefits shall terminate as to WIFE, except as she is eligible under the Fonner Spouse Protection (PI. 97.252) but remain for the use and benefit of said children, provided they qualify for these benefits as detemlined by applicable United States Armed Forces entitlement regulations, The WIFE agrees to ensure that, whenever pmetieable, the children, use whatever rnedieal, hospital, and dental services that are available to them through Armed Forces facilities, (d) With respect to the children, an emancipation event shall occur or be deemed to occur upon the earliest happening of any of the following: (I) Reaching the age eighteen (IS); (2) Marriage by child; (3) Death of child; (4) In the event that the child, upon reaching the age of eighteen, is unmarried and is handicapped to such an extent that he is physically or mentally incapable, as opposed to unwilling, to support himself or to be engaged in full. time employment, then emancipation shall be deferred, and the HUSBAND's obligation for child support as set forth in Paragraph 12(a) and (b) shall continue in full effect until the child's handicap or disability is removed or the child marries or dies. 14. COLLEGIATE SUPPORT: It is the intention of the parties to assist their children should they elect to pursue a post-secondary education immediately upon completion of their high school education. To that end, the parties agree that in the event that the children avail themselves of all fonns of financial aid including scholarships, grants, loans or other forms of financial aid, that they shall provide each child with sufficient support so as to satisfy any collegiate costs including tuition, room and board. Parents shall be responsible to pay for such extraordinary expcnscs in a manner that is proportionate to thcir incomes at that time. 15. COUNSEL FEES: Each party shall pay his or her counsel fees and expenses, 16. INSURANCE POLICIES: In lieu of maintaining WIFE as a beneficiary under his Military Survivor Benefit Plan, HUSBAND shall maintain a term life insurance policy with a company of his choosing, in the amount of$IOO,OOO.OO, naming Patricia Williams as the beneficiary under the policy for the beneift of the children. HUSBAND shall maintain said policy until the youngest child reaches age eighteen (/S), WIFE shall receive a copy of the policy and all renewals, and of any and all notices of premium due and of default. In the event of default of payment by HUSBAND of any amount due on account of any policy of insurance required to be maintained by virtue of this paragraph, such payment may be paid by WIFE, who shall be reimbursed by HUSBAND for the full amount of such payments, plus any interest, penalties and costs, and reasonable legal fees incurred by WIFE in securing repayment. 17. DIVORCE: The parties hereto agree to enter into a mutual consent divorce. WIFE agrees to pursue the divorce and to be the Plaintiff therein. HUSBAND agrees to sign the necessary documents, including an Affidavit of Consent and further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. IS. WAIVER OF CLAIMS: Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she shaIJ now have or hereafter acquire, under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation, dower, courtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and each will, at the request of the other, cxecute, acknowledge and deli vcr any and all instrument' which may be necessary or advisable to cany into effect this mutual waiver and relinquishment of all such interests, rights and claims. 19. BREACH: If eithcr pany breaches any provision of this Agreement, the other pany shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of legal fces and costs incurred by the other in enforcing their rights under this Agreement. 20. VOID CLAUSES: 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. 2 J. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. ,22. INDEPENDENT SEPARATE COVENANTS: It is specifically understood and agreed by and between the parties hereto that each paragraph hereof shall be deemed to be a separate and independent covenant and agreement. 23. ADDITIONAL INSTRUMENTS: Each of the parties shall from time to time, at the request of the other, execute, acknowledge and deliver to the other party any and all further instruments that may be reasonable required to give full force and effect to the provisions of this Agreement. 24, APPLICABLE LA W: This Agreement shall be construed under the laws of the Comrnonwealth of Pennsylvania and rnore specifically under the Divorce Code of 1980. 25. 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. . , 26, ENTIRE AGREEMENT: This Agn:c:ment contains lhe entire understanding of the parties and there are no representations, warranties, covenants or undenakings other than those expressly set fonh herein. 27, MODIFICATION AND WAIVER: A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature, 28. WAIVER OF RIGHTS: The parties hereto havc been informed of their rights or have been advised to seek counsel to inform them of their rights under and pursuant to lhe Divorce Code, Act of April 2, 1980, Number 1980-26, particularly the provisions for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses. Both parties agree that this Agreement shall conclusively provide for the distribution of property under the said law and hereby waive, release and relinquish any further rights they may respectively have against the other for alimony, alimony pendente lite, equitable distribution of marital property, counsel fees or expenses. From the date hereof, each party may acquire either personal or real propcrty in their own name. Any property so acquired shall be owned solely by the individual and shall not be subject to any claim whatsoever by the other party. 29. EXECUTION OF DOCUMENTS: Both parties hereby agree to execute any documents required to implement this Agreement. 30, FINANCIAL DISCLOSURE: The parties confirm that they have relied on the substantial accuracy of the financial disclosure of the other as an inducement to the execution of this Agreement. IN WITNESS WHEREOF, the parties hereto have set their hands and seals the date and year first above written, " . ~ . . , I I I , i f'" II~fu r c) , L. __ .v 7:J"j)-!....,J Witness n ,/, tli,a'1A ~16J.;R'~ PATRICIA E, WILLIAMS ~ ~? J;~ Wit s (<Lq' W~ CLINT WILLIAMS Kayer and Brown Attorneys At Law A Professional Corporation Liberty loll 4 E. liberty Avenue Cerlisle, Pennsylvania 17013 .:'I'!JJ\'~ ~ -''- .. .. .. {i~......,.., . ~ 1______ 156 J - PD8735083 2BOeOO.340APR 0201 7 3 ' 0 MAILED fROIA C.ARll~l[ PI> 1 7 01 3 Mr. Clint Williams 40 Meribrook Circle Willingboro, NJ 08046 -_. -<- ,~l:"',7:-;<;r-i"~vt""'''''",'r,:I'\''r' "',", Kayer and Brown Attorneys At Law A Professional Corporation liberty Loll 4 E. Liberty Avenue Carlisle, Pennsylvania 17013 ..~~"'P~. -' " ... ... .. fi(~~ . ~ "'.-...-.- 174 O~O 3-40 PDB735083 23501 . APR 02 01 730 9 MAILED '"""OARIlOCEPt, 1 7 0 1 3 . iJL. I B!UeA(k,;;';;;:ld ':J!s!llC.) :mU;lAV AUaqn lSllg: 17 NA\O~g CINV ~g:^ v)I WI \, \ V\-Ms,