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HomeMy WebLinkAbout07-2186 Karen E Sitler, Plaintiff V. Gregory M Sitler, Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. n7 - IX ?'1.. !F/Zy? : CIVIL ACTION -LAW : IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a Decree in 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 the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County 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, PA 17013 (717) 249-3166 James Miller, Esquire Att ev for Plaintiff N Karen E Sitler, Plaintiff V. Gregory M Sitler, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA NO. n j -?1 L t c ?? CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE 1. Plaintiff is Karen E Sitler, who currently resides at 75 Iroquois Trail, York Haven, PA 17339. 2. Defendant is Gregory M Sitler who presently resides at 75 Iroquois Trail, York Haven, PA 17339. 3. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on September 21 1991, in Lycoming County Pennsylvania. 5. There have been no prior actions for divorce or annulment between the parties. 6. The Plaintiff is a citizen of the United States of America. 7. The Defendant is not a member of the Armed Services of the United States of America. 8. The Plaintiff has been advised of the availability of counseling and that the Plaintiff may have the right to request that the Court require the parties to participate in counseling. COUNT 1 REQUEST FOR A NO-FAULT DIVORCE UNDER SECTION 3301(c) OF THE DIVORCE CODE 9. The prior paragraphs of this Complaint are incorporated herein by reference as though set forth in full. 10. The marriage of the parties is irretrievably broken. w WHEREFORE, Plaintiff requests this Honorable Court to enter a decree dissolving the marriage between Plaintiff and Defendant; Respectfully Submitted, Miller Lipsitt LLC By: Jam A Miller, Fsquir A 36 6 rney for Plaintiff 6 North 21 st Mar et Street Camp Hill, PA 11 (717) 737- 0 Karen E Sitler, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. Gregory M Sitler, : CIVIL ACTION -LAW Defendant : IN DIVORCE VERIFICATION I verify that the statements made in this Divorce 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 unsworn falsification to authorities. DATE: Karen E Sitler, Plaintiff W 0 C'7 i rv c-? J ?J G'? r-? rn A KAREN E. SITLER, Plaintiff VS. GREGORY M. SITLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 07-2186 CIVIL TERM CIVIL ACTION -LAW IN DIVORCE AND NOW comes the Defendant, Gregory M. Sider, by and through his attorneys, Foreman & Foreman, P.C., and Joseph D. Caraciolo,' Esquire and files this preliminary objection avering as follows: 1. On April 18, 2007, Plaintiff filed a Complaint in Divorce under §3301(c ) of the Divorce Code with the Cumberland County Prothonotary's office. 2. Plaintiff is Karen Sitler who currently resides at 75 Iroquois Trail, York Haven, PA 17339. 3. Defendant is Gregory M. Sider, who presently resides at 75 Iroquois Trail, York Haven, PA 17339. 4. Defendant alleges, and therefore avers that 75 Iroquois Trail, York Haven, PA 17339 is located in York County, Pennsylvania. 5. Defendant avers that both he and 'Plaintiff are residents of York County, Pennsylvania, and have at no time lived in Cumberland County, Pennsylvania. 6. Rule 1920.2 of the Pennsylvania Rules of Civil Procedure requires that a Divorce Action be brought only in the county in which the plaintiff or defendant resides, unless the two parties have agreed to a different venue in writing. P Rule of Civil Procedure § 1920.2. 7. Plaintiff's Complaint does not includela written agreement regarding venue. 8. The Defendant avers that he has not agreed to pursue this action in Cumberland County. 9. The Defendant objects to the Divorce Complaint being filed in Cumberland County, Pennsylvania. 10. Cumberland County lacks proper venue to accept Plaintiff's Divorce Complaint. WHEREFORE, the Defendant respectfully requests that this Honorable Court dismiss Plaintiff's complaint as being filed in an improper venue. Respectfully submitted $OREMA1A? & ORE N, PC. rr Date: CT J ph D. C o?squirf o ey for tze6fienlla' nt 41-2 Market Street, 6`h Floor arrisburg, PA 17101 Telephone- (717) 236-9391 Attorney ID Number: 90919 KAREN E. SITLER, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 07-2186 CIVIL TERM GREGORY M. SITLER, CIVIL' ACTION -LAW Defendant IN DIVORCE CERTIFICATE OFI SERVICE I hereby certify that I am this day serving a copy of the foregoing Preliminary Objections upon the person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by mailing the same United States Mail, postage prepaid and addressed as follows: James A. Miller, Esquire 356 North 21St Street Camp Hill, PA 17011 (Attorney for Plaintiff) Respectfully submitted PX. Date: l seph D. Caraciolo, 9squirt attorney for Defendant 1112 Market Street, 6tn Floor Harrisburg, PA 17101 Telephone- (717) 236-9391 . lttomey ID Number: 90919 r.. r" r?.'? _?.? '?"i - ,_? y r.1; ? G. !°",.? -- ?` J Karen E Sitler, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-2186 Gregory M Sitler, : CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 18 2007 and service was obtained upon the Defendant by Defendant's counsel accepting service thereof. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint and service upon Defendant of the same. 3. 1 consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. 4. 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 further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I 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.A. Section 4904, relating to unsworn falsification to authorities. 7 - o Date: S'-1 A(- Grego Sitler t'1 ?., * rT c - 4 s -tom Karen E Sitler, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-2186 Gregory M Sitler, : CIVIL ACTION -LAW Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I consent to the entry of a final decree of divorce without notice. 2. 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. 3. 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. I verify that the statements made herein in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. A. Section 4904, relating to unworn falsification of authorities. Date: Gregory M it er C) g; TF Karen E Sitler, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 07-2186 Gregory M Sitler, : CIVIL ACTION -LAW Defendant : IN DIVORCE AFFIDAVIT OF CONSENT 1. A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 18 2007 and service was obtained upon the Defendant by Defendant's counsel accepting service thereof. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint and service upon Defendant of the same. 3. 1 consent to the entry of a Final Decree in Divorce after service of notice of intention to request entry of the decree. 4. 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 further understand that the Court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. Being so advised, I do not request that the Court require that my spouse and I 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.A. Section 4904, relating to unswor fal .fication to a thorities. '9 Date: K ren Sitler r t ? - ; ,_ . Cep c Karen E Sitler, Plaintiff V. Gregory M Sitler, Defendant : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-2186 : CIVIL ACTION -LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. 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. 3. 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. I verify that the statements made herein in this affidavit are true and correct. I understand that false statements are made subject to the penalties of 18 Pa. C.S. A. Section 4904, relating to unworn falsification of authorities. Date: Kar n E Sitler C-- C? \S c o KAREN E. SITLER, Plaintiff, V. GREGORY M. SITLER, Defendant ACCEPTANCE OF SERVICE PRAECIPE TO ENTER APPEARANCE WITHDRAW PRELIMINARY OBJECTIONS AND ACCEPTANCE OF SERVICE OF DIVORCE COMPLAINT TO THE PROTHONOTARY, Kindly enter my appearance in the above captioned matter on behalf of the Defendant, Gregory M. Sider and withdraw the Preliminary Objections filed by Defendant on May 21, 2007. I, Joseph D. Caraciolo, Esquire, counsel for Gregory M. Sider, Defendant in the above captioned matter, do hereby acknowledge that on May 12, 2007, I accepted service of the divorce complaint filed by Plaintiff, Karen M. Sider, to the above term and docked behalf of the Defendant, Gregory M. Sider. Date: May 12, 2007 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-2186 CIVIL ACTION - LAW IN DIVORCE Jgjleph D. t 1 reman, Foreman & Caraciolo, P.C. 2 Market Street, 6thFloor Harrisburg, PA 17101 (717) 236-9391- Telephone (717) 236-6602 - Facsimile Attorney for Defendant ?n C? C73 : R Karen E Sitler, Plaintiff V. Gregory M Sitler, Defendant To the Prothonotary: : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 07-2186 : CIVIL ACTION -LAW : IN DIVORCE PRAECIPE TO TRANSMIT RECORD 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 service of the Complaint: A complaint in Divorce under Section 3301(c) of the Divorce Code was filed on April 18 2007 and service was obtained upon the Defendant by Defendant's counsel accepting service thereof on May 12, 2007. 3. Date of execution of the Affidavit of Consent and Waiver of Notice of Intention Request Entry of a Divorce Decree required by Section 3301(c) of the Divorce Code: by Plaintiff: September 29 2008 by Defendant: May 19 2008 Time Stamped date of Waiver of Notice of Intention Request Entry of a Divorce Decree required by Section 3301(c) of the Divorce Code: by Plaintiff: September 30 2008 by Defendant: June 17 2008 4. Related claims pending: There are no related claims pending. Respectfully Submitted, Mi i LLC By: Ja s A Miller, Esquire ttorney for Plaintiff 765 Poplar Church Road Camp Hill, PA 17011 (717) 737-6400 C ?- -? 3 1\? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Karen E Sitler Plaintiff No. 07-2185 VERSUS Gregory M Sitler Defendant DECREE IN DIVORCE AND NOW, M4& ZZ" 2,009 , IT IS ORDERED AND Karen E Sltler DECREED THAT PLAINTIFF, Gregory M Sitler AND DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The terms of the parties Marital Settlement Agreement are hereby Divorce. PROTHONOTARY ? ? ? ?:? a? ? ? ?.: COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION KAREN E. SITLER, Plaintiff FAMILY DIVISION V. No. 07-2186 GREGORY M.. SITLER, IN DIVORCE Defendant STIPULATION AND AGREEMENT FOR THE ENTRY OF "DOMESTIC RELATIONS ORDER" AND NOW, this day of , 2009, the parties, GREGORY M. SITLER, Defendant, and KAREN E. SITLER, Plaintiff, having been divorced by Decree dated October 22, 2008 of the Court of Common Pleas of Cumberland County, entered at Docket Number 07-2186 do hereby stipulate and agree as follows: 1. The Defendant, Gregory M. Sitler (hereinafter referred to as "Member") is a member of the Commonwealth of Pennsylvania State Employees' Retirement System (hereinafter referred to as "SERS"). 2. SERS, as a creature of statute, is controlled by the State Employees' Retirement Code, 71 Pa. C.S. §- 5101-5956 ("Retirement Code"). 3. Member's date of birth is June 25, 1968, and the Member's Social Security number is 180-62-8064. 4. The Plaintiff, Karen E. Sitler, (hereinafter referred to as "Alternate Payee") is the former spouse of Member. Alternate Payee's date of birth is May 20, 1968 and Alternate Payee's Social Security number is 202-60-9760. 5. Member's last known mailing address is: 432 Meadow Drive, Camp Hill, PA 17011. 6. Alternate Payee's current mailing address is: 300 Park Avenue, New Cumberland, PA 17070. It is the responsibility of Alternate Payee to keep a current mailing address on file with SERS at all times. 7. The marital property component of Member's retirement benefit equals the Coverture Fraction multiplied by Member's retirement benefit on the effective date of Member's retirement calculated using the Retirement Code in effect on March 28, 2007, the date of the parties' separation, and Member's final average salary as of the effective date of retirement. The Coverture Fraction is a fraction with a value less than or equal to one. The numerator is the amount of Member's service, as defined by SERS, for the period of time from September 21, 1991, date of marriage, to March 28, 2007, date of separation. The denominator is the total amount of member's service, as defined by SERS, on the effective date of Member's retirement. Fifty percent (50°x6) of the marital property component of Member's retirement benefit is to be allocated to Alternate Payee as the equitable distribution portion of this marital asset. 8. Member's retirement benefit is defined as all monies paid to or on behalf of Member by SERS, including any lump sum withdrawals or scheduled or ad hoc increases, but excluding the disability portion of any disability annuities paid to Member by SERS as a result of a disability which occurs before Member's marriage to Alternate Payee or after the date of Member's and Alternate Payee's final separation. Member's retirement benefit does not include any deferred compensation benefits paid to Member by SERS or any enhancements to the Member's retirement benefit arising from post-separation monetary contributions made by Member. The equitable distribution portion of the marital property component of Member's retirement benefit, as set forth in Paragraph Seven (7), shall be payable to Alternate Payee and shall commence as soon as administratively feasible on or about the date Member actually enters pay status and SERS approves a Domestic Relations Order incorporating this Stipulation and Agreement, whichever is later. 9. Member hereby nominates Alternate Payee as an irrevocable beneficiary to the extent of Alternate Payee's equitable distribution portion of Member's retirement benefit for any death benefits payable by SERS. This nomination shall become effective upon approval by the Secretary of the Retirement Board, or other authorized representative of the Secretary, of any Domestic Relations Order incorporating this Stipulation and Agreement. The balance of any death benefit remaining after the allocation of the equitable distribution portion payable to Alternate Payee and any other alternate payees named under other SERS-approved Domestic Relations Orders ('Balance") shall be paid to the beneficiaries named by Member on the last Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's death. If the last Nomination of Beneficiaries Form filed by Member prior to Member's death (a) predates any approved Domestic Relations Order incorporating this Stipulation and Agreement, and (b) names Alternate Payee as a beneficiary, then: (1) the terms of the Domestic Relations Order shall alone govern Alternate Payee's share of any death benefit, and (2) for purposes of paying the Balance via the last Nomination of Beneficiaries Form filed with the Retirement Board prior to Member's death, Alternate Payee shall be treated as if Alternate Payee predeceased Member. No portion of the Balance shall be payable to Alternate Payee's estate. In addition, Member shall execute and deliver to Alternate Payee an authorization, in a form acceptable to SERS, which will authorize SERS to release to Alternate Payee all relevant information concerning Member's retirement account. 10. The term and amounts of Member's retirement benefits payable to Alternate Payee after SERS approves a Domestic Relations Order incorporating this Stipulation and Agreement depends upon which option(s) Member selects at retirement. Member and Alternate Payee expressly agree that: (a) Member may select any retirement option offered by SERS under the Retirement Code at the time Member files an Application for Retirement Allowance with SERS. 11. Alternate Payee may not exercise any right, privilege or option offered by SERS. SERS shall issue individual tax forms to Member and Alternate Payee for amounts paid to each. 12. In the event of the death of Alternate Payee prior to receipt of all of payments payable from SERS under a Domestic Relations Order incorporating this Stipulation and Agreement, any death benefit or retirement benefit payable to Alternate Payee by SERS shall revert to Member. 13. In no event shall Alternate Payee have benefits or rights greater than those that are available to Member. Alternate Payee is not entitled to any benefit not otherwise provided by SERS. Alternate Payee is only entitled to the specific benefits offered by SERS as provided in this Stipulation and Agreement. All other rights, privileges and options offered by SERS not granted to Alternate Payee by this Stipulation and Agreement are preserved for Member. Member and Alternate Payee acknowledge that benefits paid pursuant to this Stipulation and Agreement are and shall remain subject to the Public Employee Pension Forfeiture Act, 43 P.S. §1311, et seq. 14. It is specifically intended and agreed by the parties hereto that any Domestic Relations Order incorporating this Stipulation and Agreement: (a) Does not require SERS to provide any type of benefit, or any option, not otherwise provided under the Retirement Code; (b) Does not require SERS to provide increased benefits (determined on the basis of actuarial value) unless increased benefits are paid to Member based upon cost of living adjustments or increases based on other than actuarial values. 15. The parties intend and agree that the terms of this Stipulation and Agreement shall be approved, adopted and entered as a Domestic Relations Order. 16. The Court of Common Pleas of Cumberland County, Pennsylvania, shall retain jurisdiction to amend any Domestic Relations Order incorporating this Stipulation and Agreement, but only for the purpose of establishing it or maintaining it as a Domestic Relations Order; provided, however, that such amendment shall not require SERS to provide any type or form of benefit, or any option not otherwise provided by SERS, and further provided that such amendment or right of the Court to so amend will not invalidate the parties' existing Domestic Relations Order. 17. Upon entry of a Domestic Relations Order incorporating this Stipulation and Agreement, a certified copy of the Domestic Relations Order and this Stipulation and Agreement and any attendant documents shall be served upon SERS immediately. Such Domestic Relations Order shall take effect immediately upon SERS approval and SERS approval of any attendant documents and then shall remain in effect until such time as a further Order of Court amends or vacates the Domestic Relations Order. WHEREFORE, the parties, intending to be legally bound by the terms of this Stipulation and Agreement, do hereunto place their hands and seals. for D Wndp6odfmber, Joseph D. Caraciolo Plaintiff/Alternate Pgv-r!e-, Karen Sitler for Plainti"ternate Payee, James A. Miller AUTHORIZATION FOR RELEASE OF ACM W jjyFQjDUnON TO ALTERNATE PAYEE I, Gregory M. Sitler, authorize the Pennsylvania State Employees' Retirement System ("SERS") to release to Karen E. Sitler any and all information that hshe may request regarding my SERS benefits or retirement account. This authorization is granted under the terms of the Approved Domestic Relations Order entered by the Cumberland County Court of Common Pleas on at Docket Number 07-2186 which names Karen E. Sitler as Alternate Payee. A photocopy or faxed copy of this Authorization shall have the same force and effect as the original. Date: Mem ignature Member's Printed Name Member's Social Security Number ,A* • 1 l t .lk5 COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FAMILY DIVISION KAREN E. SITLER, V. Plaintiff FAMILY DIVISION GREGORY M. SITLER, Defendant No. 07-2186 IN DIVORCE AND NOW, this Zo" day of ovft4 e.. , 2009, based upon the Marital Settlement Agreement of the parties, we hereby find as follows: A. The parties hereto were formerly Husband and Wife and were divorced by a Final Decree in Divorce on October 22, 2008. B. The parties Marital Settlement Agreement incorporated but not merged with the Divorce Decree provided, inter alia, for division of Defendant's retirement account, and a transfer of an interest therein to a qualified account established by Plaintiff. C. Pursuant to the agreement, the parties require a Qualified Domestic Relations Order to implement properly the terms of the agreement with respect to the division of Defendant's interest in his retirement account. D. The parties have presented a stipulation and agreement for entry of a Qualified Domestic Relations Order attached and incorporated herein as Exhibit "A". NOW THEREFORE, based upon the above findings, the parties agreement, and the attached Stipulation and Agreement for the entry of a Qualified Domestic Relations, to implement the terms and provisions of the Marriage Settlement Agreement, it is hereby ORDERED, DECREED, and DIRECTED that the Stipulation and Agreement for the entry of Qualified Domestic Relations Order as attached hereto shall be entered as an Order of Court as if set forth in full herein. BY THE COURT: 0 41 J. Distribution: - Cumberland County Prothonotary One Courthouse Square, Carlisle, PA 17013 Joseph D. Caraciolo, Esquire (Attorney for Defendant) 112 Market Street, Sixth Floor, Harrisburg, PA 17101 /-James Miller (Attorney for Plaintiff) 765 Poplar Church Road, Camp Hill, PA 17011 a m.? =71") 'I If TAPY 2909OCT 21 M S. 28