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DECREE IN -I- 3"23A
DI10RCE "-
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and . .~~1l.q .~P.qr:"'. ...... ...... ...... .......... ... ... '" ...... defendant,
are divorced from the bonds of matrimony. The Marital Settlement
Agreement dated June 21, 1999 is hereby incorporated but not
merged,:. 0 0 0 d" f h f II 0 I' h 0 h h
Tne court retains JUriS Ict/on 0 t e 0 oWing calms W IC ave
been raised of record in this action for which a final order has not yet
been entered;
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WHEREAS, the parties acknowledge and agree that in entering
into this Agreement, including foregoing waivers, they are each
relying on truth and completeness in all material respects as to
all information provided by the other party hereto regarding the
assets of such person.
NOW THEREFORE, in consideration of the mutual promises,
covenants and agreements hereinafter contained, each of the
parties hereto intending to be legally bound hereby promises,
covenants and agrees as follows:
1. DIVORCE, The parties agree that their marriage is
irretrievably broken and that they mutually consent to a
divorce. Husband shall file or has filed the Divorce
Complaint and be responsible for all costs for such filing.
The parties' agree and have executed or will execute all
necessary Affidavits required by the court for the entry of
a mutual consent divorce. Both Husband and Wife have
consented to immediately file with the Court said Affidavits
and file the appropriate documents to request a Decree in
Divorce from the bonds of matrimony under Section 3301(c) of
the Divorce Code.
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2. FULL FORCE 'AND EFFECT, This Agreement shall .continue in full
force and effect until such time of final Decree in Divorce
is entered.
3. INTERFERENCE, Each party shall be free from interference,
authority, and contact by the other, as fully as if he 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 other, or in
any way harass or malign the other, nor in any way interfere
with the peaceful existence, separate and apart from the
other.
4. WIFE'S DEBTS, Wife represents and warrants to Husband that
since the date the divorce was filed, to wit, April 26,
1999, 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 reason of debts or obligations incurred by
her.
5. HUSBAND'S DEBTS, Husband represents and warrants to Wife
that since the divorce was filed, to wit, April 26, 1999, he
has not and in the future he will not, contract or incur any
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debt or.liability for which Wife or her esta~e might be
responsible and shall indemnify and save harmless Wife from
any and all claims or demands made against her by reason of
debts or obligations incurred by him.
6. MUTUAL RELEASES: Subject to the provisions of this
Agreement, each party has released and discharged, and by
this Agreement does for himself or herself and his en' hel
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 causes of action
for termination of the marriage by divorce or annulment and
except any or all causes of action for breach of any
provisions of this Agreement. Husband and Wife specifically
release and waive any and all rights he or she might have to
raise claims under the Divorce Code of 1980, as amended in
1988 including, but not limited to claims for equitable
distribution of marital property, support, alimony, alimony
pendente lite, counsel fees or expenses. The fact that a
party brings an action to enforce this Agreement as
incorporated in the divorce decree, under the Divorce Code
of 1980, as amended in 1988, does not give either party the
right to raise other claims under the Divorce Code,
specifically waived and released by this paragraph and all
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rights ~nd 'obligations of the parties arising out. of the
marriage shall be determined by this Agreement.
7. RELEASE OF TESTAMENTARY CLAIMS: Except as provided for in
this Agreement, each of the parties hereto shall have the
right to dispose of his or her property by Last Will and
Testament or otherwise and each of them agree that the
estate of the other, whether real, personal or mixed, shall
be and belong to the person or persons who would become
entitled thereto as if the decedent had been the last to
die. This provision is intended to constitute a mutual
waiver by the parties of any rights to take against each
other's Last Wills under the present or future laws of any
jurisdiction whatsoever and is intended to confer third-
party beneficiary rights upon the other heirs and
beneficiaries of each.
8. AGREEMENT BINDING ON HEIRS: The parties acknowledge that
except as provided for in this Agreement, each of the
parties shall have the right to dispose of their respective'
property by Last Will and Testament, and that each party
waives the right to take under the Will of the other. This
Agreement shall be binding on the respective heirs,
executors, administrators and assigns of the parties
thereto.
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9. ENTIRE' AGREEMENT: This Agreement represents ..the I?nt ire
agreement between the parties and supersedes any and all
prior agreements or negotiations between them. There are no
representations, promises, agreements, conditions, or
warranties between the parties other than those set forth
herein.
10. LEGAL ADVICE/VOLUNTARY EXECUTION: Husband has employed and
has had the benefit of counsel of Catherine A. Boyle,
Esquire, as his attorney. Wife is unrepresented. Each
party acknowledges that they have received or may receive
independent legal advice from counsel and that each party
fully understands the facts and their legal rights and
obligations, and each party acknowledges and accepts that
this Agreement is, under the circumstances, fair and
equitable, and that it is being entered into freely and
voluntarily, and that execution of this Agreement is not the
result of any duress or undue influence and that it is not
the result of any collusion or improper or illegal agreement
or agreements. Also, each party hereto acknowledges that he
or she is fully aware of the current Pennsylvania Divorce
Law, and his or her rights thereunder, each party hereto
still desires to execute this Agreement acknowledging that
the terms and conditions set forth herein are
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just.
and equitable to each of the parties and each party waives
their respective right to have the Court make any
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determination or order affecting the respect~ve parties'
right to a divorce, support, alimony, alimony pendente lite,
equitable distribution of all marital property, counsel fees
and costs and expenses.
11. DIVISION OF PERSONAL PROPERTY: The parties have divided
between them, to their mutual satisfaction, the personal
effects, household furniture and furnishings, and all other
articles of personal property which have heretofore been
used by them in common. Should it become necessary, the
parties each agree to sign any titles or documents necessary
to give effect to this paragraph.
12. DISPOSITION OF REAL PROPERTY: Husband does hereby set over,
transfer and assign to Wife all of his right, title and
interest in the marital residence located at 53 Bayberry
Drive, Mechanicsburg, Cumberland County, Pennsylvania. The
marital residence shall be the sole property of Wife. Said
residence is currently titled in Wife's name alone and the
parties do not anticipate the need to execute any documents.
However, if documents must be signed, Husband agrees to
execute a deed and any other necessary documents or
instruments transferring the property into Wife's name
alone.
Wife agrees that she alone shall be responsible for the
mortgage on said residence held at Columbia National
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Mortgag~ Corporation, and Wife shall indemnity and save
harmless Husband from any and all claims or demands mad~
against said mortgage. Wife also agrees that she alone
shall be responsible for all utilities, taxes, maintenance
and/or any other debts and/or obligations associated with
said residence, Wife shall indemnify and save harmless
Husband from any and all claims or demands made against said
debts and/or obligations.
The parties acknowledge that there is a home equity
loan held at PNC Bank, which is secured by the marital
residence. The parties acknowledge that said loan was taken
for Husband's business, Personal Fitness. Husband agrees
that he alone shall be responsible for the home equi.ty loan
held at PNC Bank, and Husband shall indemnify and save
harmless Wife from any and all claims or demands made
against said loan. Husband agrees that he will not draw
additional funds against said loan. In the event that
Husband does not fulfill his obligations set forth in this
paragraph, Wife sh~ll be entitled to pursue an action for
breach pursuant to the provisions of this Agreement and any
other legal remedies available to her.
13. EOUITABLE DISTRIBUTION,
a. Husband shall keep as his sole and exclusive property
the following assets:
(1) 1999 Chevrolet Silverado automob~le currently.
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titled in his name alone. Husband.. shall be
solely responsible for the debt for said
vehicle and shall indemnify and save harmless
Wife from any and all claims or demands made
against said debt.
(2) IRA in Husband's name alone.
(3) Any and all checking, savings, securities
and/or other accounts in Husband's name
alone.
(4) Joint account at Commerce Bank.
Wife shall keep as her sole and exclusive property the
following assets:
(1) 1998 Mercedes C230 automobile currently
titled in Wife's name alone. Wife shall be
solely responsible for the debt for said
vehicle and shall indemnify and save harmless
Husband from any and all claims or demands
made against said debt.
(2) 1989 Jeep Cherokee currently titled in
Husband's name alone. Husband shall execute
a title transfer and/or any other documents
necessary to effectuate this paragraph. The
parties acknowledge that there is no debt for
this vehicle. To the extent that there is a
debt for this vehicle, Wife shall be solely
responsible for the debt for said vehicle and
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shall indemnify and save harmless 'Wife from
any and all claims or demands against said
debt.
(3) Wife's retirement account through her
employer, Electronic Data Systems.
(4) IRA in Wife's name alone.
(5) Any and all checking, savings, securities
and/or other accounts in Wife's name alone.
14, BUSINESS INTEREST: Husband shall keep as his sole and
exclusive property his business interest and any benefits
and/or liabilities derived therefrom. Specifically, this
business interest is any interest which Husband may have in
Personal Fitness.
15, ALIMONY, Both parties acknowledge and agree that the
provisions of this Agreement providing for equitable
distribution of marital property are fair, adequate and
satisfactory to them and are accepted by them in lieu of and
in full and final settlement and satisfaction of any claims
or demand that either may now or hereafter have against the
other for spousal support, separate maintenance, alimony
pendente lite or alimony. Husband and Wife further,
voluntarily and intelligently, waive and relinquish any
right to seek from the other any payment for spousal
support, separate maintenance, alimony pendente lite or
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alimony,
16. DISCLOSURE, The parties acknowledge that there has been
full and fair disclosure to the other of his or her
respective income, assets and liabilities, whether they are
held jointly or in the name of one party alone. Any and all
other accounts, investments, property rights, contract
rights, business interest, retirement accounts and other
retirement vehicles and insurances, not specifically
mentioned herein, and of whatsoever nature of either of the
parties in their individual names shall be and shall remain
the sole and separate property of the individual in wh0s~
name it presently exists or if untitled, the sole and
separate property of the individual in possession of said
property, and neither party shall have any claims whatsoever
thereto.
17. WAIVER OF RIGHT TO COUNSEL FEES, COSTS AND EXPENSES: The
parties hereby acknowledge that they each waive their right
to request counsel fees, costs and expenses from the other.
Each party shall be responsible for payment of his or her
own counsel fees, costs and expenses.
18. INDEMNIFICATION, Each party covenants and agrees that if
any claim, action or proceeding is hereinafter initiated
seeking to hold the other party liable for any debts,
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obliga~ions~ liability, act or omission of silch ~arty, such
party will at his or her sole expense, defend the other
against any such claim or demand, whether or not well-
founded, and that he or she will indemnify and hold harmless
the other party with respect to all damages as resulting
therefrom. Damages as used herein shall include any claim,
action, demand, loss, cost, expense, penalty and other
damage including without limitation, counsel fees and other
costs and expenses reasonably incurred in investigating or
attempting to avoid same or in opposing the imposition
thereof or enforcing this indemnity, resulting to Husband or
Wife from any inaccurate representation made by or on behalf
of either Husband or Wife to the other in this Agreement,
any breach of any of the warranties made by Husband or Wife
of any of the obligations to be performed by such party
hereunder. The Husband or Wife agrees to give the other
prompt written notice of any litigation threatened or
instituted against either party which might constitute that
basis for a claim for indemnity pursuant to the terms of
this Agreement.
19. BREACH: If either party breaches any provision of this
Agreement, the other party 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 if held in breach by a court of competent
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jurisd~ctid~, the party breaching this contract shall be
responsible for payment of legal fees and costs incurred by
the other in enforcing their rights under this Agreement.
20. AGREEMENT TO CONTINUE IN EVENT OF DIVORCE: 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. In the event that the marriage of the parties hereto
is terminated by divorce, this Agreement shall nevertheless
remain in full force and effect, and shall survive such
decree and shall not in any way be affected thereby, except
as provided for herein.
21, 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 reasonably required to give full
force and effect to the provisions of this Agreement.
22. INCORPORATION, This Agreement shall be incorporated into a
Divorce Decree but not merged therein.
23. MODIFICATION AND WAIVER, A modification or waiver of any of
the provisions of this Agreement shall be effective only if
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made i~'writing and executed with the same formarity 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.
24. 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.
25. 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.
26. EXECUTION DATE' The execution date shall be defined as the
date both parties have signed this Agreement. In the event
that the parties do not sign this Agreement at the same
time, the execution date shall be the date the last party
has signed.
27. LAW: This Agreement shall be construed pursuant to the laws
of the Commonwealth of Pennsylvania.
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COMMONWEALTH OF PENNSYLVANIA
COUNTY OF . ~ 4. AJ
On this, the / rif. day of
before me the undersigned officer, personally, MOORE
known to me (or satisfactorily proven) to be he person whose
name is subscribed to the within Marital Property Settlement
Agreement and acknowledged that he executed the same for the
purposes therein contained.
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IN WITNESS THEREOF, I have hereunto set my hand and official
seal.
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WILLIAM MOORE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. q'tf - ;2L/'b1f ~
vs.
RENA MOORE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against 'i:
the claims set forth in the following pages, you must take action
within twenty (20) days after this Complaint and Notice are ~
served, by entering a written appearance personally or by
attorney and filing in writing with the Court your defenses or
objections to the claims set forth against you.
You are warned that, if you fail to do so, the case may
pr~ceed without you and a judgment may be entered against you by
the Court without further notice for any money entered against
you by the Court without further notice for any money claimed in
the Complaint or for any other claim or relief requested by the
Plaintiff. You may lose money or property or other rights
important to you.
When the ground for divorce is indignities or irretrievable
breakdO\~n of the marriage, you may request marriage counselling.
A list of marriage counselors is available at: The Office of the
Prothonotary, Cumberland County Courthouse, One Courthouse
Square, Carlisle Pennsylvania 17101.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY,
COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF DIVORCE OR
ANNULMENT IS ENTERED, 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 HE~P.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
(717) 249-3166
MEYERS, DESFOH, SALTZGIVER . BOYLE
410 NORTH SECOND STREET . P,D BOX '062 . HARRISBURG. PA 17108
(717) 236-9428 . FAX (717)236-2817
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VERIFICATION
I, William Moore
, verify that the
scatemencs made in this COMPLAINT IN DIVORCE
are true and correct to the bes
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of my knowledge, information and belief. I understand that fals
statements herein are made subject to the penalties of 18 Pa.
C.S. Section 4904, relating to unsworn falsification to
authorities.
Dated:
4/20/99
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Plaintiff
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MEVERS. DE6FOR, SALTZGIVER . BOYLE
410 NORTH SECOND STREET I P,O, BOX '062 . HARRISeURG, PA 17108
(717) 236-9428 . FAX (7'7) 236.2817
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WILLIAM MOORE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 99-2489
RENA MOORE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
A Complaint in Divorce under Section 3301(c) of the Divorce
Code was filed on April 26, 1999.
The marriage of the Plaintiff and Defendant ~s irrecr~evably
broken and ninety (90) days have elapsed from the date of filing
and service of the Complaint.
I consent to the entry of a final decree of divorce after
service of notice of intention to request entry of the decree.
I verify that the statements made in this Affidavit are true
and correct. I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. Section 4904 relating to
unsworn falsification to authorities.
c2A-t2 . (}~~.
RENA MOORE
Date: G, -IS -C/9
MEYERS, DESFOR. SAlTZGrvER & BOYLE
410 NORn~ SECOND SlREH . PO BOX 1062 . liARRISBURG, PA 171(lR
(717) ~~36.!.f426 . FAX (717) 236,2817
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WILLIAM MOORE,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLV^NI^
NO. 99-2489
vs.
RENA MOORE,
Defendant
CIVIL ACTION - LAW
IN DIVORCE
WAIVER OF NOTICE OF INTENTION TO REQUEST
ENTRY OF A DIVORCE DECREE UNDER
~3301(Cl 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.
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. ~ 4904 relating to unswor
falsification to authorities. ~
Date (/J - / ?-qc; ~ a l/lI2.dU.....
RENA MOORE I iff)
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MEYERS, DESFOR, SALTZGIVER & BOYLE
410 NOATH SECOND STREET . P,O BOX 1002 . HARRISBURG. PA 17108
(717) 236-9428 . f"AX (717) 236.."B17