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HomeMy WebLinkAbout99-04910 1 0 0 rYJ?.. V. stz 5 xyG ",..''. Al "; ii? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. eel LARRY E. GRIFFIE' Plaintiff No. 4910 1999 VERSUS LINDA KAY GRIFFIE Defendant DECREE IN DIVORCE AND NOW, m; -'t f L, 2Q ZOO?_ IT IS ORDERED AND DECREED THAT LARRY E. GRIFFIE AND LINDA KAY GRIFFIE ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAINTIFF, DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; NONE BY THE COU PROTHONOTARY -.2zew LARRY E. GRIFFIE Plaintiff V. LINDA KAY GRIFFIE Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 99 - 4910 CIVIL TERM : IN DIVORCE PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for divorce: Irretrievable breakdown under Section 3301( c ) of the Divorce Code. 2. Date and manner of service of the Complaint: Complaint served on Linda Kay Griffie by Certified Mail, with return receipt on September 2. 1999 3. Date of execution of the plaintiffs affidavit required by Section 3301(c) of the Divorce Code: March 13, 2002 Date of service of plaintiffs affidavit on defendant: March 18, 2002 Date of execution of the defendant's affidavit required by Section 3301(c) of the Divorce Code: February 20, 2002 4. Related claims pending: None sp II submitted, Peter J. Russo Date:March 18, 2002 ' ?? r- ; ; _ ?;: ?: ? ?:.. ?) ? t-?'. i r, rn -- ' __ - ?.) -? i_.? ?_:=i iJ Larry E. Griffie IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW Linda Kay Griffie NO. 99 -4 q ? 0 CIVIL TERM Defendant 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 be entered against you by the Court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Court House, 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 Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 PETER J. RUSSO, ESQUIRE PA Supreme Court ID: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 Larry E. Griffie Plaintiff V. Linda Kay Griffie Defendant Attorney for Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 -V910 CIVIL TERM IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(c) AND 3301(d) OF THE DIVORCE CODE AND NOW, COMES, the above-named Plaintiff by and through his attorney Peter J. Russo, and seeks to obtain a Decree in Divorce from the above-named Defendant, upon the grounds hereinafter more fully set forth: 1. Plaintiff is an adult individual residing at 34 Carlisle Road, Newville, PA 17241, Cumberland County, Pennsylvania and is a citizen of the United States. 2. Defendant is an adult individual residing at 1128 Mainsville Road, Shippensburg, PA 17257, Franklin County, Pennsylvania and is a citizen of the United States. 3. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for 48 years and has resided continuously therein for at least six months prior to filing of this Complaint. 4. Defendant has been a resident of the Commonwealth of Pennsylvania for 45 years and has resided continuously therein for at least six months prior to filing of this Complaint. 5. Plaintiff and Defendant were married on September 9, 1972 in Mt. Holly Springs, PA. 6. There are no children of the parties under the age of eighteen (18). COUNT I - DIVORCE 7. Plaintiff hereby incorporates by reference averments 1 through 6 of this Complaint as if each averment were set forth fully hereunder. 8. There has been no prior action for divorce by either party against the other. 9. Neither Plaintiff nor Defendant is in the Armed Forces of the United States or any of its allies. 10. Plaintiff avers that the marriage between the parties is irretrievably broken. 11. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request that the court require the parties to participate in counseling, but does not request the same. 12. Plaintiff and Defendant have property which will be subject to a property settlement agreement addressing support issues, which will be filed herein at the appropriate time. WHEREFORE, Plaintiff, Larry E. Griffie, prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: A. That a decree in divorce be entered dissolving the marriage between the two parties. Dated: / 13 1 't ctfu"'su e er J. Russo 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 PETER J. RUSSO, ESQUIRE Attorney for Plaintiff PA Supreme Court ID: 72897 61 West Louther Street Carlisle, PA 17013 (717) 249-2721 Larry E. Griffie IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW Linda Kay Griffie NO. 99 - CIVIL TERM Defendant IN DIVORCE VERIFICATION I, Larry E. Griffie, verify that the statements made in the foregoing document are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: / t? //? Q? Lapty E. Griffie - C-6 O N T <y? rn r- ?a O Q -= o J o ` ,' -? o -a o1 LARRY E. GRIFFIE Plaintiff V. LINDA KAY GRIFFIE Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : NO. 99 - 4910 CIVIL TERM : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO ENTER DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed on August 13, 1999. 2. The marriage is irretrievably broken and ninety days have elapsed from the date of the filing and service of the Complaint. 3. 1 consent to the entry of a Final Decree of Divorce without further notice. 4. 1 understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. 5. 1 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's Office. 6. 1 have been advised of the availability of marriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. I understand that the court maintains a list of marriage counselors in the Domestic Relations Office, which list is available to me on request. 7. Being so advised, I, Larry E. Griffie, do not request that the Court require my spouse and me to participate in counseling prior to a divorce decree being handed down by the Court. 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 unsworn falsification to Authorities. DATE 1 1. rriffj i- C r? C? _ i.?3 .- iR. _ ' ._ ?_, i? LARRY E. GRIFFIE, Plaintiff VS. LINDA KAY GRIFFIE, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 99-4910 CIVIL IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NARRIAOg COUNSELLING 1. A Complaint in divorce under Section 3301(c) of the Divorce Code was filed on aUGUST 12, 1999. 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. 4. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. 5. I have been advised of the availability of marriage counselling and understand that I may request that the court require that my spouse and I participate in counselling prior to a divorce decree being handed down by the court. 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 IS Pa. C.S. §4904 relating to unsworn falsification to authorities. DATE: February 20, 2002 Linda to Grt fie Sworn to and subscribed before me this 20th day of February, 2002. NOTMgL REAL BONNIE L COYLE, NOTARY PUBLIC BOgO OF CMLIELE MY , CUMBERLAND COUNTY COMMISSION V"EB OCTOBER 17 2002 ' ?; ? ? ; ?:: . ' - ;._ :, ??, E' - ?: G' :emu ? t?l ?) _ (J i_ ? l.? LARRY E. GRIFFIE, Plaintiff Vs. LINDA KAY GRIFFIE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 99-4910 CIVIL IN DIVORCE 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, lawyers 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 unsworn falsification to authorities. ?U?6R Date: Linda Kay GgLff&1& .D ? 1?? ?' !. 4_-' ' C.! ?- - ?) ? r.. I. '- ?: _' ? ;] ?. ?(i i _. V LARRY E. GRIFFIE, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. :NO. 99-4910 CIVIL TERM LINDA KAY GRIFFIE : CIVIL ACTION-LAW Defendant AFFIDAVIT OF SERVICE I, -_ Roger C Spitz , being duly sworn according to law, that I am over 18 years of age and not a party to the above-captioned action, served and made known to Linda Griffie on the 2nd day of September, 1999 at 4:30 p.m. at MGM Pharmacy, Newville, PA, 17241, a Divorce Complaint issued in the above entitled case in the manner described below: [X] Personally delivered them into the hands of the person to be served [ ] Adult family member with whom that person resides. Relationship is [ ] Agent or person in charge of person's office or usual place of business (] Other. Description of Recipient Sex: Female Skin Color: Caucasian Facial Hair: None Height (approx.): 5'6" Hair Color: Blonde Weight (approx.): 165 lbs. xz?_?Zl P;r?, Roger spitz Pennsylvania State Constable Cumberland County ID# B001517 - -? =_ ;: > ; - ' ?, ' = -; :J LARRY E. GRIFFIE Plaintiff V. LINDA KAY GRIFFIE Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION • LAW : NO. 99.4910 CIVIL TERM : IN DIVORCE CERTIFICATE OF SERVICE I, Peter J. Russo, hereby certify that I am on this day serving a copy of the foregoing documents upon the person (s) and in the manner indicated below; Hand Deliver to: Dale F. Shughart, Jr., Esquire, Attorney for Defendant Peter J. Russo Date: 31, Y/ 0 1- L. Co C, l_l ?.J LARRY E. GRIFFIE, Plaintiff VS. LINDA KAY GRIFFIE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : 99-4910 CIVIL IN DIVORCE PRAECIPE TO WITHDRAW ECONOMIC CLAIMS I, Linda Kay Griffie, hereby withdraw economic claims raised in my Counter-Affidavit filed October 2, 2001. Date: Linda Kay riff e _ `_ _ ' ? ??_, ?:, - ?'? .:: ? -- l.J ?_? CJ Larry E. Griffie IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW Linda Kay Griffie NO. 99 - 4910 CIVIL TERM Defendant IN DIVORCE NOTICE IF YOU WISH TO DENY ANY OF THE STATEMENTS SET FORTH IN THIS AFFIDAVIT, YOU MUST FILE A COUNTER-AFFIDAVIT WITHIN TWENTY DAYS (20) AFTER THIS AFFIDAVIT HAS BEEN SERVED ON YOU OR THE STATEMENTS WILL BE ADMITTED. AFFIDAVIT UNDER SECTION 33011dl OF THE DIVORCE CODE 1. The parties to this action separated in October 31, 1998 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. 1 understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: a U / LARRY E. GRIFR co N on? - ?' i o 0 1 Larry E. Grime IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW Linda Kay Griffle NO. 99 - 4910 CIVIL TERM Defendant IN DIVORCE PROOF OF SERVICE OF PLAINTIFF'S AFFIDAVIT UPON DEFENDANT AND NOW, COMES, Peter J. Russo, Attorney for Plaintiff, Larry E. Griffie, and certifies that on September 11 2001 he did serve the Defendant, Linda Kay Griffie with a time stamped copy of the Affidavit of Plaintiff Under Section 3301(d) of the Divorce Code by placing same in an envelope, return receipt requested and addressed to Linda Kay Griffie c/o Mark W. Allshouse, Esquire, 219 Pine Street, Harrisburg, PA 17101, and deposited same with the United States Postal Service for delivery. Respectfully submitted, Peter J. Russo 5010 E. Trindle Road Mechanicsburg, PA 17050 Date: 9-11-01 Larry E. Griffie Plaintiff V. Linda Kay Griffie Defendant TO: Linda Kay Griffie Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - 4910 CIVIL TERM IN DIVORCE NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to plaintiffs affidavit. Therefore, on or after October 1, 2001 the plaintiff can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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 Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Date: 9-11-01 Res ectfull itted, Peter J. Russo 5010 E. Trindle Road Mechanicsburg, PA 17050 A Larry E. Griffie IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW Linda Kay Griffle NO. 99 - 4910 Defendant IN DIVORCE CIVIL TERM CERTIFICATE OF SERVICE AND NOW, COMES, Peter J. Russo, Attorney for Plaintiff, Larry E. Griffie, and certifies that on September 11 2001 Linda Kay Griffie, c% Mark W. Allshouse, Esquire, 219 he did serve Defendant, Pie Street, tHarrisburrg, PA 17101 with the attached Notice of Intent to Enter Divorce Decree via first class mail and certified. Respectfully submitted, Peter J. Russo 5010 E. Trindle Road Mechanicsburg, PA 17050 Date: 9-11-01 _ c 4 n a I;i+:u L+1 ;.u 0- U., i.+ o U l ' Larry E. Griffie IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW Linda Kay Griffie NO. 99 - 4910 CIVIL TERM Defendant IN DIVORCE COUNTER-AFFIDAVIT UNDER SECTION 330d OF THE DIVORCE CODE 1 • Check either (a) or (b): J (a) I do not oppose the entry of a divorce decree. (b) I oppose the entry of a divorce decree because (Check either (1), (ii) or both): (i) The parties to this action have not lived separate and apart for a period of at least two years. (ii) The marriage is not irretrievably broken. 2. Check either (a) or (b): (a) I do not wish to make any claims for economic relief. I understand that I may lose rights concerning alimony, division of property, lawyers fees or expenses if I do not claim them before a divorce is granted. (b) I wish to claim for economic relief which may include alimony, division of ???lll property, lawyers fees or expenses or other important rights. I verify that the statements made in this affidavit are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: Linda Kay Griffie NOTICE: IF YOU DO NOT WISH TO OPPOSE THE ENTRY OF A DIVORCE DECREE AND YOU DO NOT WISH TO MAKE ANY CLAIM FOR ECONOMIC RELIEF, YOU NEED NOT FILE THIS COUNTER-AFFIDAVIT. C.. ZIL LARRY E. GRIFFIE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW : 99-4910 CIVIL LINDA KAY GRIFFIE, Defendant IN DIVORCE NOTICE OF ELECTION TO RESUME PRIOR NAME PURSUANT TO 54 PA. C.S. 704 Notice is hereby given that Linda Kay Griffis, being the Defendant in the above captioned action, hereby elects to resume and hereafter use her prior name of Linda Kay Tanger. ---- 4 Linda ay r ffi.e TO BE KNOWN AS: r2 Lima Ray ranger COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND On this, the,?`A-W!day of 2002, before me, the undersigned officer, personally appeared Linda Kay Griffis, to be known as Linda Kay Tanger, hereafter, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within instrument, and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have set my hand and official seal. NOTARIAL SEAL J VYLIVLZ I C i ` el BONNIE COYLA, CNOTARY PUBLIC _-_-' -- [13YORO CARLISLE, BERLAND COUNT" COMMISSION OM(MRESRES OCTOBER I7 x002 T a M ? n 1 V Larry E. Griffie IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW Linda Kay Griffie NO. 99 - 4910 CIVIL TERM Defendant IN DIVORCE PROOF OF SERVICE OF PLAINTIFF'S AFFIDAVIT UPON DEFENDANT AND NOW, COMES, Peter J. Russo, Attorney for Plaintiff, Larry E. Griffle, and certifies that on _ September 19 2001 he did serve the Defendant, Linda Kay Griffie with a time stamped copy of the Affidavit of Plaintiff Under Section 3301(d) of the Divorce Code by placing same in an envelope, return receipt requested and addressed to Linda Kay Griffie, 1128 Mainsville Road, Shippensburg, Pennsylvania 17257, and deposited same with the United States Postal Service for delivery. Respectfully submitted, Peter J. Russo 5010 E. Trindle Road Mechanicsburg, PA 17050 Date: 9-19-01 ? rn C Ln h 7G O r"O N Cl- L U L_ CJ (::J i.J Larry E. Griffie IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW Linda Kay Griftie NO. 99 - 4910 CIVIL TERM Defendant IN DIVORCE CERTIFICATE OF SERVICE AND NOW, COMES, Peter J. Russo, Attorney for Plaintiff, Larry E. Griffie, and certifies that on September 19. 2001 he did serve the Defendant, Linda Kay Griffie, 1128 Mainsville Road, Shippensburg, Pennsylvania 17257, with the attached Notice of Intent to Enter Divorce Decree vie first class mail and certified. Respectfully submitted, Peter J. Russo 5010 E. Trindle Road Mechanicsburg, PA 17050 Date: 9-19-01 a Larry E. Griffis Plaintiff V. Linda Kay Griffie Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99 - 4910 CIVIL TERM IN DIVORCE NOTICE OF INTENT TO REQUEST ENTRY OF DIVORCE DECREE TO: Linda Kay Griffie Defendant You have been sued in an action for divorce. You have failed to answer the complaint or file a counter-affidavit to plaintiffs affidavit. Therefore, on or after October 9, 2001 the plaintiff can request the court to enter a final decree in divorce. If you do not file with the Prothonotary of the court an answer with your signature notarized or verified or a counter-affidavit by the above date, the court can enter a final decree in divorce. Unless you have already filed with the court a written claim for economic relief, you must do so by the above date or the court may grant the divorce and you will lose forever the right to ask for economic relief. A COUNTER-AFFIDAVIT WHICH YOU MAY FILE WITH THE PROTHONOTARY OF THE COURT IS ATTACHED TO THIS NOTICE. 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 Lawyers Referral Service Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 Date: 9-19-01 Res ectfull itted, Peter J. Russo 5010 E. Trindle Road Mechanicsburg, PA 17050 °) Lr. F . C) u7 C/; C'3 _i , _