Loading...
HomeMy WebLinkAbout03-5965 IN THE COURT OF COMMON PLEAS OF THE ~ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Lynn Edward Nogle, Defendant 1921 11th Avenue Altoona, PA 16601-2405 !l !l !l !l !l !l !l !l !l CIVIL ACTION - LAW Barbara Ann Nogle, Plaintiff 252 Deerfield Rd. Camp Hill, Pennsylvania 17011 210-42-2294 03 -~W- ~ a~.:l.TERM CASE NO. IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court for divorce. If you wish to defend against the claims set forth on the other side of this page, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in this paper by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of you child or children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the CUMBERLAND County Courthouse, in Carlisle, PA. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE DIVORCE OF 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. Office of the Prothonotary CUMBERLAND County Courthouse Carlisle, PA. TelephOne(711 ) -aQO ~(olq 5 IN THE COURT OF COMMON PLEAS OF THE ~ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Barbara Ann Nogle, Plaintiff 252 Deerfield Rd. Camp Hill, Pennsylvania 17011 210-42-2294 !l !l !l !l !l !l !l !l !l CIVIL ACTION - LAW TERM CASE NO. Lynn Edward Nogle, Defendant 1921 11th Avenue Altoona, PA 16601-2405 IN DIVORCE COMPLAINT UNDER SECTION 3301 (c) OR 3301 (d) OF THE DIVORCE CODE 1. Plaintiff is Barbara Ann Nogle who resides at; 252 Deerfield Rd.; Camp Hill, Pennsylvania 17011. 2. Defendant is Lynn Edward Nogle who resides at: 1921 11th Avenue, Altoona, PA 16601-2405. 3. 181 Plaintiff and/or 0 Defendant have been a bona fide resident(s) of the Commonwealth of Pennsylvania for at least six months immediately prior to commencement of this action. 4. Plaintiff married Defendant on May 31, 1991 at Fredericksburg, Fredericksburg County, Virginia. Attached hereto and marked as Exhibit "A" is the certificate of marriage evidencing said marriage. 5. Neither plaintiff nor defendant is in the military or naval service of the United States or its allies within the provisions of the Soldier's and Sailor's Civil Relief Act of Congress 1940 and its amendments. 6. There has been no prior action of divorce or for annulment between the parties. Complaint for Divorce; Page 1 7.The marriage is irretrievably broken. 8. After 90 days have elapsed from the date offiling ofthis Complaint, Plaintiff intends to file an affidavit consenting to a divorce. Plaintiff believes that Defendant may also file such an affidavit. 9. Plaintiff has been advised that marriage counseling is available and that Plaintiff may have the right to request that the Court require the parties to participate in marriage counseling. 10. There are no children born to or adopted by the parties to this marriage and none are expected. 11. There is no property or debt. WHEREFORE, if both parties file affidavits consenting to a divorce after 90 days have elapsed form the date of filing of this Complaint, Plaintiff respectfully requests that a decree of divorce be entered pursuant to Section 3301 (cl of the Divorce Code dissolving the marriage between the Plaintiff and Defendant. f::8{)J)~ ~ )2J" Barbara Ann Nogle /Ve ~- I verify that the statements made in this Complaint are true and correct. I understand that false statements herein are made subject to penalties of the 18 Pa.C.S. Section 4094 relating to unswom falsification to authorities. Date: /1- I d- - ()-3 ~ Q rvn 11 IrJJ/.... Barbara Ann ~glr.; Ir'o ;;;-- ~ ~ 0 :i':~ ,~ , .' ~ "1:~ i-;~- --,- nOli'; -:~ - Z-~ J:::. ~ 2: ~~; ..t::: 0 ~:::::.c ~ "2 ~ -'-, ....0.(".- r- :.:'1 -"',) ~ .< ~ -p, Lynn Edward Nogle, Defendant 1921 1Ith'Avenue A1toona, PA 16601-2405 IN THE COURT OF COMMON PLEAS OF THE ~ JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Barbara Ann Nogle, Plaintiff ~ CIVIL ACTION - LAW 252 Deerfield Rd. ~ Camp Hill, Pennsylvania 17011 ~ 210-42-2294 ~ ~ ~ ~ 9 ~ t"'1':?-.t;9r..s ~'r.>L"( TERM CASE NO, IN DIVORCE AFFIDAVIT OF NON-MILlTARY SERVICE Barbara Ann Nogle, being duly sworn according to Law, deposes and says that Plaintiff knows by Plaintiffs own personal knowledge and therefore avers that the defendant, Lynn Edward Nogle, is 56 years of age and that Defendant is not in the military service of the United States or its allies, or otherwise within the provision of the Soldier's and Sailor's Civil Relief Act of Congress 1940 and its amendments and that the defendant is employed by None. Date: I( -Id- -' ().~ vJ~, ~!loP.JG - Barbara Ann N091e,OPI~;;t;ff Sworn to and subscribed before me this the /'J:!:^.day of NblJemb-er .:1.00'?> ---:- , q~Yvc~ I )0 N_P,b1E -- I RHl@116 M Morns. Notary PublIc Yo,." City, York County MV t/Offl~!~~~~~' ,EXPires April 7, 2007 (') G ~c. d18:'; ..:~- /",. rrl ',:;- ~~:- ':t~~~~ 2: -; ~. c:.::' ~. -",,:") :.;'~ -;; ", (.,) IN THE COURT OF COMMON PLEAS OF THE ~JUDICIAL DISTRICT OF PENNSYLVANIA COUNTY CUMBERLAND Barbara Ann Nogle, Plaintiff 252 Deerfield Rd. Camp Hill, Pennsylvania 17011 210-42-2294 ~ ~ ~ ~ ~ ~ ~ ~ ~ CIVIL ACTION - LAW /'jJ -s;rrf-C: C-;(:a TERM CASE NO. Lynn Edward Nogle, Defendant .1921 11th Avenue Altoona, Pa 16601-2405 IN DIVORCE COUNSELING NOTICE RULE 1920.45(a)*(1) The Divorce Code of Pennsylvania requires that you be notified of the availability of counseling where a divorce is sought under any of the fOllowing grounds: Section 3301 (a)(6) Indignities Section 3301 (c) Irretrievable breakdown Mutual Consent Section 3301 (d) Irretrievable breakdown TwolThree year separation A list of qualified professions is available for inspection in the Office of the Prothonotary CUMBERLAND County Courthouse Carlisle, PA. Telephone~) ~40- (j lqS (') ,:~ :-";>-, Q~~'~ ...<... --;..,.. (j~ . ~: ..,:~; ( ~~(.:.... ~~ ::;i f.._ ',) (,.,) NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF BARBARA ANN NOGLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW LYNN EDWARD NOGLE, Defendant : NO. 2003 - 5965 CIVIL TERM : IN DIVORCE PLAINTIFF'S MARRIAGE COUNSELING AFFIDAVIT The plaintiff, being duly sworn according to law, deposes and says: 1. I have been advised of the availability of matriage counseling and understand that I may request that the court require that my spouse and I participate in counseling. 2. I understand that the court maintains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request. 3. 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. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. 111/2-- , 2004 \ A Cn)ulJU< tZm<> ~rb~ra A. Nogle, Plaintiff {5 -.... () ("'.... !~~ ~Q c.,) :1'7 co --<: f'.." c;::, c:;:;:, ..c- 2i -t't.:: o ....'1 5! 1'1 'l ::r:' i-'~ -om &t~ ~.j i"ll . ' ~. , (n ~~ -,- -J:jo. NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE P A 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF BARBARA ANN NOGLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW LYNN EDWARD NOGLE, Defendant : NO. 2003 - 5965 CIVIL TERM : IN DIVORCE PRAECIPE TO ENTER APPEARANCE TO THE PROTHONOTARY: Please enter myappear.mce for the plaintiff, Barbara A. Nogle, in the above matter. November!!., 2004 .,.....:~ 0 I"---.~ 0 = ?; <;c~ -n ...c-- .;~:: -- j -Pl', :r n-! I a ~.'11r2 '--:;:;.. -..:: -. -ncq Ul ;;; 'r ;::::-.. ;~; (~t ::1: nl 1..0 ""':, W -< Q) NATHAN C. WOLF, ESQUIRE ATtORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATtORNEY FOR PLAINTIFF BARBARA ANN NOGLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW LYNN EDWARD NOGLE, Defendant : NO. 2003 - 5965 CIVIL TERM : IN DIVORCE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree 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 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 Courthouse, Carlisle, Pennsylvania 17013. 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF BARBARA ANN NOGLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW LYNN EDWARD NOGLE, Defendant : NO. 2003 - 5965 CIVIL TERM : IN DIVORCE AMENDED COMPLAINT IN DIVORCE PURSUANT TO SECTION 3301(D) OF THE DIVORCE CODE NOW, comes the plaintiff and files this amended complaint in divorce against the defendant, representing as follows: 1. The plaintiff is Barbara A Nogle, an adult individual residing at 252 Deerfield Road, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The defendant is Lynn Edward Nogle, an adult individual whose last known address was 192111th Avenue, Altoona, Blair, Pennsylvania 16601-2405. 3. The plaintiff has been a resident of the Commonwealth of Pennsylvania at least six months prior to the filing of this action in divorce. 4. The parties were married on May 31, 1991, in Frederickburg County, Virginia. 5. Pursuant to the Divorce Code, Section 3301(d), the plaintiff avers as the grounds upon which this action is based that the marriage between the parties is irretrievably broken and that the parties have been separated since August 1, 1993, a period in excess of two years. 6. Plaintiff filed a pro se complaint in divorce under Section 3301(c) or 3301(d) of the Divorce Code on November 13, 2003. 7. The plaintiff avers that she has been advised of the availability of counseling and that said party has the right to request that the court require the parties to participate in counseling. WHEREFORE, the plaintiff respectfully prays that this Honorable Court grant her relief in the form of the entry of a decree in divorce and for such further relief as this Honorable Court may deem equitable and just. I verify that the statements made in this complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.CS. Section 4904, relating to unsworn falsification to authorities. II t~/ ~.~ , 2004 \ t\.J~ Q.lJ O~ ~ra A. No , Plaintiil { , 2004 o C. -;".1>'" ~)'.~\ (\'i ~. ~ . ~ ; ~.- , . (f' .....1'<< ~. ~~>~ ~~>, '7 C;j, '.::'\ ::..:: r-' c::> c::> J;:'" ....-;'" ~ II - ()\ o ~\'i -' -,.\~_ -r~ -~-\'\ f:~ _() c.. ,,'\ l..' ;,~':~~:\~ L_) (' :-:~l .t<':, \" \'-~:.\ "~ ':,2. :t"" -,,<I- -... ....0 .' c...:> -1 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF BARBARA ANN NOGLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW LYNN EDWARD NOGLE, Defendant : NO. 2003 - 5965 CIVIL TERM : IN DIVORCE PLAINTIFF'S MOTION FOR SPECIAL ORDER DIRECTING SERVICE BY PUBLICATION Plaintiff, Barbara Ann Nogle, by her undersigned attorney, Nathan C Wolf, Esquire, pursuant to Pa.RCP. No. 430(a) moves this Court for a special order permitting service of the complaint in this action by publication. In support of this motion, the plaintiff avers the following: 1. The last known residence of the defendant was 192111th Avenue, Altoona, Blair, Pennsylvania 16601-2405. 2. The parties have been separated for over two years under Section 3301(d) of the Divorce Code, since August 1,1993. 3. Plaintiff filed a divorce pro se complaint in divorce under Section 3301(c) of the Divorce Code on November 13, 2003. 4. Plaintiff filed an amended divorce complaint in the Court of Common Pleas of Cumberland County, Pennsylvania, on November 15, 2004. 5. On November 18, 2004, plaintiff mailed a certified copy of the amended divorce complaint to defendant at his last known address of 192111th Avenue, Altoona, Blair, Pennsylvania 16601-2405, by regular and certified mail. 6. Both of plaintiff's attempts to serve the defendant by mail were returned to sender, not deliverable, unable to forward and unknown address. Copies of the envelopes are attached as Exhibits A and B, respectively. 7. Plaintiff retained two private investigators to locate a more current address for defendant, without success. 8. Statements from both private investigators are attached hereto as Exhibits C and D, respectively. 9. To the best of plaintiff's knowledge, information and belief, the residence address of 192111th Avenue, Altoona, Blair, Pennsylvania 16601-2405, is the last known address of defendant. 10. Plaintiff has attempted to locate defendant through contacting relatives and family. Since no relatives would communicate his location to her, she has been unable to obtain any information from any of those people. 11. Plaintiff has utilized various means to locate defendant conducted through paid internet searches. These searches were unsuccessful. 12. Plaintiff has no knowledge of defendant's current employer and, as such, plaintiff would be unable to locate defendant through his employment. 13. As established herein, plaintiff has made a good faith effort to locate and serve defendant, but has been unsuccessful in her efforts. 14. Plaintiff believes and therefore avers that defendant has left the O:>mmonwealth of Pennsylvania and has no intention of returning to his last known address at 192111th Avenue, Altoona, Blair, Pennsylvania. 15. Unless this Honorable Court allows service of the divorce complaint and all subsequent related documents by publication, plaintiff will be precluded from maintaining this action and injustice will result. 16. Plaintiff proposes to publish the Notice, attached hereto as Exhibit E, if the instant motion is granted. WHEREFORE, plaintiff requests that this Honorable Court enter a special order directing service of notice of the divorce complaint and any subsequent docwnents required by the Pennsylvania Rules of Civil Procedure on defendant, Lynn Edward Nogle, by publication, and any other relief the Court deems appropriate. Respectfully submitted, Dated: December 24-, 2004 NATHAN C. WOLF, ESQUIRE ATtORNEY ID NO. 87380 37 SOurH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATtORNEY FOR PLAINTIFF BARBARA ANN NOGLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW LYNN EDWARD NOGLE, Defendant : NO. 2003 - 5965 CIVIL TERM : IN DIVORCE AFFIDAVIT IN SUPPORT OF PLAINTIFF'S MOTION FOR SPECIAL ORDER I, Nathan C Wolf, Esquire, being dulyswom according to law, depose and say the following: 1. I am plaintiff's attorney in the above action. 2. At my client's direction, which I have personally verified, an investigation was conducted into the whereabouts of the defendant. The efforts to locate the defendant included the following: (a) On November 18, 2004, I mailed a certified copy of the amended divorce complaint to defendant at his last known address in Altoona, Pennsylvania, by regular and certified mail. Copies of the envelopes are attached hereto as Exhibits A and B. (b) Retention of private investigators was made to locate a more current address for defendant, without success. Statements from both private investigators are attached hereto as Exhibits C and D. (c) Attempts to locate defendant through contacting relatives and family has not yielded any information which would aid in plaintiff's efforts to locate the defendant. (d) Various means to locate defendant were conducted through paid internet searches. These searches were without success. (e) A search for defendant's current employment status was likewise unsuccessful. 3. To the best of my knowledge, information and belief, the residence address of 1921 11th Avenue, Altoona, Blair, Pennsylvania 16601-2405, is the last known address of defendant. 4. I have been unable to locate any address for defendant other than his last known address of 192111th Avenue, Altoona, Blair, Pennsylvania 16601-24 . Sworn to and subscribed before me This ~t(dayof ~ ~ 2004. COMMONWEALTH OF PENNSYLVANIA Notarial Seal Rhonda D. Rudy, Notary Public Carlisle Boro, Cumberland County My Commission Expires Aug. 12, 2006 Member, Pennsylvania Association of Notari.. l' {, :'~ . - - - - EXHIBIT A 9~~~ ~:~~ F-~Q ~ ~~ 8 ~ ~ ~ \i~ '1'11 n >-1~ ~ ~~s:: g~~ O~t"'" E '9-] O ''0 ~~ l'rl > l en C") ;J> ... ~ " ~ ~ e:Jooo !; a . zZ>z ;" >-7 coo:::(/) ~ L. z....(/)mc ~ 0 &;:;?;~:E ~ ~ ........:....(") n m- m_ ....~~C~ C::l:s:z.... "";;=0> 0.... m.... 0 ~rn::l;o::o c:;; -Z::l >~~Orn ~>::l:5~ Om_ ~~ "' CI) ~ 0 o 0 .... : rn ::l Ii \j 1 l -a ~rv.~A~/~~ - "~t 'U loO '"'0 :c D:r lCm '( ~_ "4~}J ,~. EXHIBIT B -~~ t::;; ~;:b ~c::s ~;: <:) .... (71 (11 o .... + 1\) .j::. C) t1t ~~~ g~:'t o e~r-' ;;:~ >;6 tTJ ~=Q. C1'-t:~ C1'-f1l:.;l O 0 a cnal> N VI ;,~~~~ ~ ;;-lcn;ricn "'~~;s:;:; ~ !:: ::c :;: :!! ~ . -l<2:m~ ' omc:cm lJ\ " -n~;S:2::::i ~, .' 0",,,,0 i . ~:;;~;:~ -d. . >>cn2:::o ~:;;~~.~ -"'- ~O!Z~ ;":'7 $ ~ ~-~ c ~ r S! ~ !~ ,~ . ~ .J:;. In 91;"'t; I f:t;jVl~ a Vl 00 ~ r N@cl tTl 0 'Tl I ~....... ::J ~ ~ ~Q I ~ z~ o 9 ~ If tTln >-i~ 8 ~ Cl Cl I:-' I:-' I:-' .r Cl Cl Cl Cl lJJ ru In I:-' I:-' ~ [f"' (]:I lJJ I e~~ ~ 1!. ~~CJ co' ,,~ rj:;'" !J r ~ ~ i OJ OJ e ~ 1:, etA zg e :r>~ ~ ~ I a5' ~ --1-1 C/) i 00 O--..JVl '0. . cc.oo.D l;3t- ~. .-f;;2;" crLn QW~ 5l _ -Il. :Z:. ~ ..b. c;') m r "1 -; NOV-16-04 03:05 PM r .", Henr~ Inves~i~a~ion 8( "464442 P.S1 I4IOIA ~1 ~:~~~'\': INVESTIGATION AND Loss PRE:VE:NTION P.O, Box 525 Altoono. PA '6603 a 14.946-3$22 800-337.5705 Fox e, 4.94~4442 Offices In Altoona & York, Pennsylvania www.mehenryservleas.com Fax To: Nathan Wolf. esquire From: Brandon McHenry Fax: 814..848~2 Pages Including cover. Phone: 814-948..3322 Date: 11116104 Re: Vandersloot I Nogle CI Urgent ~ Revl.w cc: o Please Comm.nt 0 Pl.... Reply C1 Plea.1 Recycle D~ Mr. Wolf: Mrs. VanderslOOl bas retained my seIVices in effOt1J to locate Mr husband Lynn B. Nogle, AI you know. Mrs. Vandel'$loot has put forth an effort over a "ast. numlm of yearl to lacate her husband for the pu11JOJe of baving him servOlI for divorce ptOC>>ildings. Court house records, P A DMV. database re&ellfCh, and pI:lst landlords were part of the dort l1lIde to locate Mr. Nogle. We were only suctclst\JJ in determining where Mr. Nogle was only Q5 of' yean; ago. this i$ according to a landlord of his old address at 1921 11th avenue, Altoona. PA 1~601. As I 1UIdemand it, another licensed private investigator bas assisted. MR. Vand.er51oot \Vith this endeavor. I would like to make it known that I am fiuniliar with this inveltlsator and believe hiJn to be fully competent and capable: to cany out this type of work as well. Should you have lUly questions please don't hesitate to call me. Sincerely, McHenry Investigation &. LoIIPtevention ~~ Bnmdon McHelUy ...--- ihl. IPfmelltllle IS 1l1tended 10 be re.d by thelnlllvldualor company to whom It I. .delre.eel .net may oQnttln Ir1formltlon that ,. privileged. conftdentie' and lIll:empt form ClItclClllUrtl unCler appllcllble I.w, If tile ....d.,.. of 'hie m_g. i8 nat u,. Intended recipI- ent. or the employee or Igent r.ponalbl. rw deIlverlllll !h. m...". !o ltIe Intencled reclplln!, you are hereby nalIn.d ttllt any cSl.emlnltlonl. dlwtrlblJtlon or copying of t/'tle oommlolnlcll\lon " .b'IC!ty prl;lklb~ld. If you may have rece,vllCl !hie comm\Jnlcltlon In .n-QC, PM_ nQtlfy ""lmm.lIlar,ly by tel.pt'lDl11 end r.blm the OI'l;ln.1 m....;. tl;l UlIat the abo"l Iddr.. \/11 the V.I. PCll(af S~ic.. Tt,ltnk you. di,ere13t confidential EXHIBIT C thorough discreet confidential thorough dlscree' 11/12/2BB4 15:53 7171~ >78B I AMERICAN INVL iGATN PAGE 112 OJJice: (717) 761-3532 Fax: (717) 761-3780 ; AMERICAN INVESTIGATION RESOURCi,S hgr:r: (7i7) J05-3852 E-M"il: airbilJ@pttl.,.rr W-"'illm C. McLIlJJghlJ" Jr. Priwlte Detective PA License # 98-195 Mi$c. , .. November 12,2004 Mr. Nathan Wolf: My name is William C. McLaughlin Jr. and I am the Private Detective and Owner pf American Investigation Resources. I was hired by Ms. Barbara Vandersloot to loc~te a Mr. Lynn Nogle. After exhausting every resource I know ofI still could not locat~ Mr. Nogle. I reterred Ms. Vandersloot to an associate Private Detective in hopes he ~ different re50urces he could utilize in the continued search for the whereabouts of~. Lynn Nogle. Should you need anything further from this office please do not hesi$te to call, write, or emai1 me. ~~,~. ~ W~C.Mc~ )' Private Detective ! EXHIBIT D Post Office Box 1395 Camp Hill, PA 17001 ATIORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATIORNEY FOR PLAINTIFF BARBARA ANN NOGLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW LYNN EDWARD NOGLE, Defendant : NO. 2003 - 5965 CIVIL TERM : IN DIVORCE NOTICE Plaintiff has filed a Complaint in Divorce against Lynn Edward Nogle. If you wish to defend, you must enter a written appearance pe~onally or by attorney and file your defenses or objections in writing with the Court. 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 any papers filed by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A a.AIM FOR AUMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE TI-IE DIVORCE OR ANNULMENT IS GRANIED, YOU MAY LOSE 1HRE RIGIrr TO a.AIM ANY OF lHEM YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB 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 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 EXHIBIT E r CERTIFICATE OF SERVICE I, Nathan C. WoIf, Esquire, attorney for plaintiff, hereby certify that I served a true and correct copy of Plaintiff's Motion for Special Order Directing Service by Publication upon the following party by First Class mail, postage prepaid: Date: December~, 2004 Barbara A.. Vandersloot 615 East Market Street Suite 1 YO~PA#~ Nath~ If, Esquire / ,-/ (') ~ "'..1 ;$ ~!r:~J ~c.: ......-,. .. ~~::! ~i.) ;tJ:> ~ ~ (/1 co "-.) c:::-. c:::. ..t:- o ~ f'\.) co ~ --f :-r: n,:.!:I :oF;; _DO 0/ i!-? OjJ :.?-~D c5f1'1 :;:-1 .eo'" ::;J -< -0 =.., Y:> NATHAN C. WOLF, ESQUIRE ATIORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATIORNEY FOR PLAINTIFF BARBARA ANN NOGLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW LYNN EDWARD NOGLE, Defendant : NO. 2003 - 5965 CIVIL TERM : IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO THE PR01HONOTARY: Kindly reinstate the Complaint of Divorce in the above-referenced matter pursuant. Attached is a copy of the Complaint of Divorce to reinstate. Dated: December tJ, 2004 (") ~ -u5~ nlfr; ZP..I-' ZL.._, (f? '.' ~"'''.;:-.:~ r::~. <. ..,...~C. Z.~ -C-' )>C Z ~ ,...., <<:::) <<:::) ..c- o fT1 ("") N ex> ~ ~-n rl1- Fn 15y 06 ::;:!-r-, -~-n 00 5fTI ~ 1> ~.i:J ~ -u 3 Cf! c.11 (J1 NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF BARBARA ANN NOGLE, Plaintiff v. : IN THE COURT OF COMMON PLEAS OF :CUMBE~COUNTY,PENNSYLVANIA : CIVIL ACTION .. LAW LYNN EDWARD NOGLE, Defendant : NO. 2003 - 5965 CIVIL TERM : IN DIVORCE PRAECIPE TO REINSTATE COMPLAINT TO 1HE PROmONOTARY: Kindly reinstate the Complaint of Divorce in the above-referenced matter pursuant. Attached is a copy of the Complaint of Divorce for reinstatement, which was n~instated previously on December 28, 2004. Respectfully submitted, Dated: Februaryl1l., 2005 ~I ::::::=---::?t' Na n C. " Esquire 37 outh nov,er Street S . Carlisle, PA 17013 Supreme Court I.D. No. 87380 (717) 241-4436 Attorney for Plaintiff ...-i< ....' ~~ C.--' ,.. ~ , . . '" NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF BARBARA ANN NOGLE, Plaintiff : IN THE COURT OF COMM N PLEAS OF : CUMBERLAND COUNTY, ENNSYLVANIA v. : CIVIL ACTION - LAW LYNN EDWARD NOGLE, Defendant : NO. 2003 - 5965 CIVIL TE : IN DIVORCE AFFIDAVIT OF SERVICE OF C MPLAI PURSUANT TO PA. R.C.P. RULE NO. 1920.4 NOW, Nathan C. Wolf, Esquire, being duly sworn according to law, oes depose and state: 1. That he is a competent adult and auorney for the plaintiff' the above captioned action in divorce. 2. lbat by special order of this Court, issued December authorized to serve notice of the complaint by publication upon the Defen 3 , 2004, plaintiff was t. 3. lbat publication of the complaint in divorce was served up n the defendant on or about February 16, 2005, in the Altoona Mirror, and February 17, 2005, in e Blair County Legal Bulletin. 4. That copies of proofs of publication are attached hereto. ~"./ t / ,2005 Sworn to and sutJ2ribed -;;.. . e this.. . '. day of __ td ,2005. - // /) . ~/L-<..;dt7t.1,'( ;]C,;-.t- N6tarv Public . . . //." Notarial Seal ~indsay D. Baird, Notary Publ1c Carlisle Bora, Cumberland County My Commission Expires Oct. 21,2006 Member. Pennsylvania Association Of Notaries I , ( . " NATHAN C. WOLF, ESQUIRE ATtORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241.4436 ATtORNEY l'OR PLAINTIFF BARBARA ANN NOGLE, Plaintiff : IN THE COURT OF COMM N PLEAS OF : CUMBERLAND COUNTY, P NNSYLVANIA v. : CML ACTION - LAW LYNN EDWARD NOGLE, Defendant : NO. 2003 - 5965 CML TER : IN DIVORCE ORDER ANDNOW,this 30th dayofjJe('ern~P,z ,2 oj, upon consideration of the Plaintiff's Motion for Special Order Directing Service By ublication upon defendant, Lynn Edward Nogle, pursuant to Pa.R.CP. 430(a), and it appea' to the ('..ourt that the plaintiff has made a good faith effort to locate and serve the defendant in the gular course, it is hereby ORDERED that witllln Motion is GRANTED, and service of the div rce complaint and all related filings upon the defendant, Lynn Edward Nogle, shall be made by pub cation. Plaintiff shall advertise notice of the action once in The Altoona Mirro and once in the Blair County Legal Bulletin in the form prescribed by Pa.R.CP. 430(b)(1). After co pletion of such publication, plaintiff shall not be required to further publish, serve or give defe dam notice of any complaint, motion, petition or other pleading regarding the witllln action. J. . .' PROOF OF PUBLICATION OF NOTICE IN ALTOO A MIRROR STATE OF PENNSYL VANIi COUNTY OF BLAIR James Powers Advertising Manager of the ALTOONA MIRR 301 Cayuga Avenue, Township of Logan, City ( That said newspaper was established 11: Day of June 1874, since which date said news] copy of the printed notice, hereto attached, is ( edition of the daily AL TOONA MIRROR publi: ::::fi.t~J The affiant further deposes and declares notice of publication and that all allegations in publication are true. }, Sworn to and subscribed before me this (...-/ - IN THE COURT OF COMMON PLEAS OF CUMIlERI.AND COUNTY, PENNSYlVANIA CIVIL ACTION - LAW NO. 2003-5965 CML TERM IN DIVORCE BARBARA ANN NOGLE, Plaintiff v. LYNN EDWARD NOGLE, Defendant NOTICE Plaintiff has filed a Complaint in Di- vorce against Lynn. Edward Nogle. If you wish to defend, you must enter a written appearance personally or by attomey and file your defenses or ob- jections in writing with the Court. You are warned that n you fail to do so, tha 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 en- tered against you for any other claim or relief requested in any papers flied by the plaintiff. You may lose money . or property or other'rights il1)P.Ol1atlt tOf WO ,sayS: That he IS the you including custody or VIsitation 0 . . . h your children. . cu ation, pubhs ed at Number When the ground for divorce is indig- d S te of Pennsylvania. nities or irretrievable breakdown of. the marriage. you may reque~ mamage counseling. A list of marnage coun. selors is available in tha office of the Prothonotary at the Cumberland County Courthouse, Cartisla, Pennsyl- vania. IF YOU 00 NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPER- TY LAWYER'S FEES OR EX- PENSES BEFORE THE DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM />JoJY 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 C/>JoJ GET LEGAL HELP. Cumber1and County Bar Association 32 South Bedford Street Carlisle, Pennsylvania 17013 717-249-3166 Nathan C. Woti, Esquire for Plaintiff 37 South Hanover Street, SUite 201 Cartisle, PA 17013 (717) 241-4436 February 16, 2005 Notary Public c' culation on the Thirteenth in the City of Altoona; that a d d published in the regular su . ect matter of the aforesaid f e, place and character of ,20 0:) My Commission expires NOTAIlIAl ~ Of Anoon,'l, CiJuIiy Mv Comn"'on Expir 'July 25, 2lDi .... Proof of Publication of Notice in Blair Co un Legal Bulletin Under Act of May 3, 1909, P L 424 as amended by Act No. 409 of Septembe 29,1951, P L 1608 State of PennSYlVania} . County of Blair S5. MRS. ROBERT E HARE, JR being duly sworn, deposes and says: that she is the Business Manager of th BLAIR COUNTY LEGAL BULLETIN, a legal Newspaper published at Duncansville, Pennsylvania. That the said Blair County I.egal Bullet n was established as a weekly legal Newspaper on October 1, 1938, since which date said Legal Newspaper has been regularly issued we kly in said County; that a copy of the printed notice or publication attached hereto is exactly as the same was printed a~ublished in th regular weekly editions and issues of s~id Blair County Legal Bulletin on the following dates, -? - VIZ.: d"" ) CofrJ'.!.!LNotice or Publication IN THE COURT OF COMMON PLEAS OF CUMIlERLAND COUNTY, PENNSYLVANIA CIVIL ACTION. LAW NO. 2003 - 5965 CIVIL TERM IN DIVORCE BARBARA ANN NOGLE. PlaintifT v. LYNN EDWARD NOGLE. Defendant NOTICE Plaintiff has filed a Complaint in Divorce against Lynn Edward Nogle. If you wish to defend, you must enter a wrillen appearance personally Of by attorney and fi Ie your defenses or objections in writing with the Court. You arc warned that if you fail to do so, the t:asc may proceed without you and a decree in divorce or annulment may be entt:red against you by the Court. A judgment may also be entered against you for any other claim or relief requested in any papers filed by the plaintiff. Yuu may lose money or property or other rights important to you, including custody or visitation of your chi Idren. When the ground for divorce is indignities or inetrievable breakdown of the marriage, you may request marriage counseling. ^ list of marriage counsclors is available in the office of the Prothnnmary at the Cumberland County Courthouse, Cmlislc. Pennsylvania. IF YOU DO NOT FILE A CLAIM OR AUMONlY. DIVISION OF PROPERTY I.AWYER'S FEES OR EXPENSES BEFORE THE DIVORCE OR ANNULMENT IS GRANTED. YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. Sworn to and subscribed before me / 7 .//' I . Z4I- r-- "lOT ARIAl SEAL l N8I1cv H. Raker, Notary Public Altuona, Blair County ~ycommissior, eApires Octob~, 27,2007 this -lE;;;J en C/ 3 For publishing the notice or advertisem hereto on the above stated dates. ~ .. ....$ &3 Probating same /' ......................$ h. ......$- b~:tr Total. . Publisher's Receipt for dvertising Costs The BLAIR COUNTY LEGAL BUL ETIN, hereby acknowledges receipt of the aforesaid advertising and publication costs, and certifies that the same have been fully aid. THE BWR OUNTY LEGAL BULLETIN ) Q ~:; -Q'~'(: (\:\;' z_. -:Zl_~. (f) ~ r;~r: . tt: -?:; -< ....> c." "'" <-,' ~ ::;0 I 0'" o "" ..... :J:.--n fl1--;::' :;:;8 l:__) (1..) ;;~J~\ ':J -.-\ ::r-- -n ...:. .., :J'. ~ ",- NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241.4436 ATTORNEY FOR PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA BARBARA ANN NOGLE, Plaintiff v. : CIVIL ACTION - LAW LYNN EDWARD NOGLE, Defendant : NO. 2003 - 5965 CIVIL TERM : IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT 1. A complaint in divorce under Section 3301(c) of the Divorce Code was filed in this matter on or about November 15, 2004, and served upon defendant on February 16, 2005, and February 17,2005 (see affidavit of service filed Apri16, 2005). 2. The marriage of plaintiff and defendant is irretrievably broken and more than ninety days have elapsed from the date of the service of the complaint. 3. I consent to the entry of a final decree in divorce after service of notice of intention to request entry of the divorce. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein made are subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. April ! / , 2005 ~D~() ~dP~04- BARBARA ANN V ANDERSLOOT o ( r-:' <:;3 ';;7.:. ~l ?:) .~, rt' - N c "'~', :.< c- -i~1 :1. "-;) hi-p-' :;?\\~) - S- O C..,. NATHAN C. WOLF, ESQUIRE ATTORNEY ID NO. 87380 37 SOUTH HANOVER STREET, SUITE 201 CARLISLE PA 17013 (717) 241-4436 ATTORNEY FOR PLAINTIFF BARBARA ANN NOGLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW LYNN EDWARD NOGLE, Defendant : NO. 2003 - 5965 CIVIL TERM : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOlJEST ENTRY OF A DIVORCE DECREE UNDER SECTION .HOl(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 propeny, 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 umil 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.GS. Section 4904 relating to unsworn falsification to authorities. April~,2005 \(jrJA)CVlA a Y::ndMl'JCJ/: BARBARA ANN VANDERSLOOT , '"a '5' ~~. "') ~ 9~ ..-:::'~ '>..;". ,..., ~, -- -- - ATHAN C. WOLF, ESQUIRE TTORNEY ID NO. 87380 7 SOUTH HANOVER STREET, SUITE 201 ARLISLE PA 17013 717) 241-4436 TTORNEY FOR PLAINTIFF ~ARBARAANN NOGLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. lYNN EDWARD NOGLE, i Defendant I I PRAECIPE TO TRANSMIT RECORD rO TIlE PR01HONOTARY: l: Kindly transmit the record, together with the following information, to the court for entl}' of a rvorce decree: L 1. Grounds for divorce: Irretrievable breakdown under Section 3301(c) and 3301(d) of the j-'ivorce Code. I , 2. Date and manner of selVice of the complaint: With permission granted by Order of Court fted December 30, 2004, Plaintiff selVed notice upon the defendant by publication in the Altoona Mirror n or about February 16, 2005 and in the Blair County Legal Bulletin on or abou February 17, 2005. (See fidavit of selVice previously filed on April 6, 2005) . 3. Complete either paragraph (a) or (b): (a) Date of execution of consent required by Section 3301(c) of the Divorce Code: By the plaintiff: April 11, 2005 By the defendant: Notice was not required pursuant to Order of Court dated December 30, 2004. Date of execution of the affidavit required by Section 3301(d) of the Divorce Code: N/A Date of filing and service of the plaintiff's affidavit upon the defendant: N/ A. : CIVIL ACTION - LAW : NO. 2003 - 5965 CIVIL TERM : IN DIVORCE (b) (1) (b) (2) 4. Rehtted claims pending: None 5. Complete either (a) or (b): (a) Date and manner of selVice of the notice of intention to file praecipe to transmit record, a copy of which is attached: N/ A. Notice was not required pursuant to Order of Court dated December 30, 2004. (b) Date plaintiff's Waiver of Notice in Section 3301(c) divorce was filed with the Prothonotary: April 11, 2005 Date defendant's Waiver of Notice in Section 3301(c) Divorce was filed with the Prothonotary: Nj A. Notice was not required pursuany6 Order of Court dated December 30, 2004. -vY I 1 ' ,.- _I pril ./-- >Z005 I () ~; ri~~ :~~;;. Z'~' ~~;' kL:'" )::"r"' .Z;,..", 5<= ~ -~ r-> = = c.n o -n ~:n ..,,~ ~).J r") ~.:..\ ) ~~~~ ;f~'fll ...,J --.j ., ~". ::iJ .< ::>- -0 :::0 N cr> -0 ::r: ~, N .. :+:+. +:+::of +.:+::+: +.:+::+::+: +.:Ii:+: +.:+':+::+::+':+' +:+::+::+':+: +. '+' +. +. +.:+' +. +.:+:;+::+. '+ +. +. +.:+. +. +.:+:+:+: '+ '+:+ '+ '+ +;+: ~+.;+: '+:+: +. + '+:+ ~ +.:+ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + :+' '+:+: +:+' +. '+:+::+: '+ :+'.'+:+: '+ '+:+: + Of +. + 'to + + '+ +. + + + +:+:+:+ :+ + + + +:T:+' +':+' +''':f :f 'to:f +. -to +. +. + +. '+ '+ +. ~+ +. + + +. +. 'to ++ + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + + +:+':+.:+: :+: IN THE COURT OF COMMON OFCUMBERLANDCOUNTY Barbara Ann Nogle PENNA. STATE OF No. 2003 VERSUS Lynn Edward Nogle DECREE IN DIVORCE AND NOW, /1"l'1'7 Barbara Ann Nogle ~~ /' ,-!1Jf15 _' IT IS ORDERED AND DECREED THAT Lynn Edward Nogle AND ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLEAS 59~5 .--5ffl5- , PLAINTIFF, , DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE YET BEEN ENTERED; BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDE:R HAS NOT none ByTHEC '/;d + ++ PROTHONOTARY + + + + + + + + + + + + + + + + + + + + + + + + + + + J BARBARA ANN NOGLE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW LYNN EDWARD NOGLE, Defendant : NO. 2003 - 5965 CIVIL TERM : IN DIVORCE NOTICE OF INTENTION TO RETAKE AND USE PRIOR NAME TO THE PROTHONOTARY: Kindly file the anach Notice of Intention to Retake and Use Prior Name: I, BARBARA ANN NOGLE, hereby give notice, avowing my intention to resume and hereafter use my prior surname, to wit: BARBARA ANN V ANDERSLOOT, in accordance with the provisions of the Act of December 16, 1982, P.L. 1309, No. 295, Section 704 (a) (54 Pa.C.S. Section 704 (a)) and in support there I aver as follows: 1. I, Barbara Ann Nogle, am an adult resident of Camp Hill Borough, Ounberland Counry, Pennsylvania. 2. My divorce, docketed to the above term and number was granted on May 4, 2005. I verify that the statements made in this document are true and correct to the best of my knowledge, information and belief. I understand that false statements herein made are subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. IN WITNESS WHEREOF, I have hereunto set rny hand and seal this 10 day of May, 2005. \~~ Qflv}'---'I\ ~Z- (SEAL) BARBARA ANN Nci6 TO BE KNOWN AS: ~hu~8:dLLJd-(SEAL) BARBARA ANN ANDERSLOOT (;OMMONWEALTH OF PENNSYLVANIA : ss: (j;OUNTY OF CUMBERLAND PERSONALLY APPEARED BEFORE ME, a notary public for Cumberland Counry, pennsylvania, this ~ day of /'l/J'1 , 2005, BARBARA A. NOGLE, known to me (or satisfactorily proven) to be the person whose name is subscribed to the within agreement, and acknowledge that she executed the same for the pwposes therein contained. IN WITNESS WHEREOF, I have hereunto set and official seal ONWEAL TH OF PENNSYLVANIA Notarial Seal NaIhan C. Woij. No1a'Y PublIc Carlisle Boro, ()'mtJe~and County My Commission ExpIres Apr. 19,2008 Member, PennsylvanIa Association Of Notaries ~ - (;' ~ ~ ';;....\ '"" 0> :-.J -n ~ c:' If - ~ ~ \ ---\:- - C:. s ~