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HomeMy WebLinkAbout04-4113 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : NO.Q4-l/I/J- CIVIL TERM ROBYN PIFER, Plaintiff RODNEY PIFER, Defendant. : CIVIL ACTION - LAW : 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 of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the 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 Dauphin County Courthouse, Harrisburg, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF 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 S. Bedford Street Carlisle, P A 17013 (717) 249-3166 v. : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA : ()1I. : NO. 4113 - CIVIL TERM ROBYN PIFER, Plaintiff RODNEY PIFER, Defendant. : CIVIL ACTION - LAW : DIVORCE COMPLAINT AND NOW, comes the Plaintiff, Robin Pifer, by and through her attorney, Kirstin M. Sweigard, Esquire, and files this Complaint in Divorce of which the following is a statement: I. The Plaintiff is Robin Pifer, an adult individual residing at 1050 Rockledge Drive, Carlisle, Cumberland County, Pennsylvania 17013. 2. The Defendant is Rodney Pifer, an adult individual residing at 1050 Rockledge Drive, Carlisle, Cumberland County, Pennsylvania 17013. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth for at least six (6) months previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on March 31, 1990 III Carlisle, Pennsylvania. 5. No prior actions for divorce or annulment have been filed. 6. Plaintiff has been advised of the availability of counseling and the right to request that the Court require the parties to participate in counseling. 7. The Defendant is not a member of the Armed Services of the United States or any of its Allies. 8. The Plaintiff avers that the grounds on which the action is based are: a. That the marriage is irretrievably broken; Or in the alternative, b. That the parties are now living separate and apart, and have been living separate and apart since September 2004, and at the appropriate time, Plaintiff will submit an Affidavit alleging that the parties have lived separate and apart for at least two (2) years and that the marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court to enter a decree in divorce, divorcing the Plaintiff and Defendant. Respectfully Submitted, THOMAS & ASSOCIATES Date: !( /1 {p joLI t1eM~~t:2~~ Supreme Court ID# 83801 3111 N. Front Street Harrisburg, P A 17110 (717) 541-9979 Fax: (717) 541-9495 Attorney for Plaintiff VERIFICATION I verity that the statements made in the foregoing Divorce Complaint 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, 8-1'1-04 Date ...~~ Roh-Jn -,::) ~ okJ. t 'i ~ C> -... -... . ~ ~ 0 ~~-cJ Y P-- g --L... ,,0 'eJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA Robyn Pifer Plaintiff Vs FileNo. 04-4113 IN DIVORCE Rodney Pifer Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by marking "x"] -X- prior to the entry of a Final Decree in Divorce, or __ after the entry of a Final Decree in Divorce dated __ ___ ._ ____, hereby elects to resume the prior surname of Barr; ck , and gives this written notice avowing his / her intention pursuant to the provisions of 54 P ,S, 704, Date: 11/1/2004 (~ ~ ~ - "~iinature IG,~ t' ~ Signature of name being resumed COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF 'J)/tvf>~ ,...) ) On the t.j771- day of Al.9,j~>I1~q , 200t., before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he I she executed the foregoing for the purpose therein contained, In Witness Whereof, I have hereunto set my hand hereunto set my hand and official s~aL NOTAAlAL SEAL CAROL A. LYTER, Notary Public City of Harritbt.rrg.. Dtilphin County My CommiMion E1q:ne Dec. 28, 2004 (Ua~~ Prothonotary or ~ary Public (J -lcQ /0 'i ~ if. 0 ~ -- 0 ~ C) f'-.,) 0 tJ c=..) s::; ~ -11 (N F -- --1 '-.J .-rt"l... ~i~J~ C) ~ -~ , m 0 -J <:) (~) - '~~. tJ ;p _:J.IIo \, ~. rn N N 0') DIVORCE SETTLEMENT AGREEMENT THIS DIVORCE SETTLEMENT AGREEMENT, made this jOff'J - day of November, 2004, by and between Robyn Pifer, (hereinafter "Wife"), and Rodney Pifer, (hereinafter "Husband"). WITNESSETH: WHEREAS, HUSBAND and WIFE were lawfully married on March 31, 1990, in Carlisle, Pennsylvania; and WHEREAS, differences have arisen between HUSBAND and WIFE, the consequence of which they intend to live separate and apart from each other; and WHEREAS, HUSBAND and WIFE desire to settle and determine their property rights and obligations growing out of their marital relationship; NOW, THEREFORE, the parties hereto, intending to be legally bound hereby, agree as follows: I. SeDaration, The parties are currently and have been living separate and apart since July 2004, and will not cohabitate with each other. It shall be lawful for each party at all times hereafter to live separate and apart from each other at such a place or places as he or she may from time to time choose or deem fit. 2. Interference, From the date of signing this Agreement, each party shall be free from interference, authority and control of the other, as fully as ifhe or she were single or unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest or attempt to endeavor to molest the other, or compel the other to cohabitate with the other or in any way harass or malign the other, or in any other way interfere with their peaceful existence, separate and apart from the other. 3. Mutual Release, Subject to the provisions contained in this Agreement, each party has released and discharged, and by this Agreement does for himself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, forever 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 a cause or causes of action for divorce or all causes of action for breach of any provisions of this Agreement. Further each party, subject to the provisions ofthis Agreement, releases and forever discharges the other from any and all claims one may have against the other arising out of this matrimonial action, including, but not limited to alimony, alimony pendente lite, spousal support, equitable distribution, counsel fees, costs and expenses. 4. Waiver of Claims A2ainst the Estate. Except as herein otherwise provided, each party may dispose of his or her property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or hereafter acquire under the present or future law of any jurisdiction to share in the property or the estate of the other as a result of the marital relationship, including, without limitation, dowry, courtesy, statutory allowance, widow's allowance, homestead rights, right to equitable distribution, rights to take in intestacy, right to elect against the will of the other, and right to act as administrator or executor of the other's estate. Each party will, at the request of the other, execute, acknowledge and deliver any and all instruments that may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interests, rights and claims. 5. Division of Personal Property, Except as set forth herein, each of the parties hereto has divided between themselves, to their mutual satisfaction, all items of tangible and intangible marital personal property, including household furnishings, automobiles and other similar property. Neither party shall make any claim to any such items of marital property, or of the separate personal property of either party, which are now in the possession and/or under the control ofthe other. Should it become necessary, the parties each agree to sign, upon request, any titles or documents necessary to give effect to this paragraph. The property shall be deemed to be in the possession or under the control of either party if, in the case of tangible personal property, the item is physically in the possession or control of the party at the time of the signing of this Agreement, and in the case of intangible personal property, if any physical or written evidence of ownership, such as a passbook, check book, policy or certificate of insurance or other similar writing is in the possession or control of the party. The titles to the said motor vehicles shall be executed by the parties, if appropriate, for effecting the transfer as herein provided, on the date of execution of this Agreement ifthe title is in the possession of one or the other party. In the event that either or all of the documents of title to the said vehicles shall be in the hands of a bank or other holder of the lien or encumbrance upon said vehicle, the parties agree to advise such bank or holder as to the transfer of title set forth herein and they further agree to execute whatever documents may be required to transfer title or said document of title as in the hands of such bank or holder. 6. Additional Instruments, Each ofthe parties shall, on demand, execute and deliver to the other any deeds, bills of sale, assignments, consents to change of beneficiary on insurance policies, tax returns and other documents and do or cause to be done any other act or thing that may be necessary of desirable to effectuate the provisions and purposes of this Agreement. If either party fails, on demand, to comply with this provision, that party shall pay to the other, all attorney's fees, costs and other expenses reasonably incurred as a result of such failure. 7. Debts and Liabilities, HUSBAND and WIFE hereby represent and warrant to the other that he or she has not incurred any debts or liabilities or made any contracts for which the other or his or her estate may be liable, except as stated in this Agreement. If either party has incurred an individual obligation during the term of the marriage, that party shall be responsible to discharge said obligation and hereby agrees to indemnify and save the other spouse harmless on account of said obligation. HUSBAND and WIFE acknowledge that the following marital and non-marital debts shall be allotted to the parties as follows: a. Members First Credit Union: The parties hereto currently owe approximately $9,000.00 to Members First Credit Union for a personal loan taken during the marriage. The parties intend to refinance that Joan with HUSBAND assuming approximately $4,600.00 and WIFE assuming approximately $4,600.00. HUSBAND shall be solely responsible for repayment of his portion of said obligation, and WIFE shall be solely responsible for repayment of her portion of said obligation. HUSBAND shall hold WIFE harmless from his portion of said obligation and WIFE shall hold HUSBAND harmless from her portion of said obligation. If individual financing is unable to be obtained, HUSBAND and WIFE agree to split the current bi-weekly payment of $250.00 equally between them. Since payment is currently deducted from WIFE'S account, HUSBAND shall be responsible for paying to WIFE his portion of said obligation at least on a monthly basis. 8. Warranty as to Future Oblieations, HUSBAND and WIFE each covenant, warrant, represent and agree that with the exception of the obligations set forth in this Agreement, neither of them shall hereafter incur any liability whatsoever for which the estate ofthe other may be liable. Each party shall indemnifY and hold harmless the other party for and against any and all debts, charges and liabilities incurred by the other after the date of execution of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement. 9. After Acquired Personal Property, Each of the parties hereto shall hereafter own and enjoy, independent of any claims or right of the other, all items of personal property, tangible or intangible, hereafter acquired by him or her, with full power in him or her to dispose of the same as fully and effectively, in all respects and for all purposes, as though he or she were unmarried. 10. Representation bv Counsel, This Agreement has been prepared by Kirstin M. Sweigard, Esquire, Attorney for WIFE. Kirstin M. Sweigard, Esquire has not represented HUSBAND in any respect to the negotiation and preparation of this Agreement. HUSBAND acknowledges and understands that he is entitled to legal representation, however, has declined that right. HUSBAND acknowledges that he has reviewed the terms and conditions contained in this Agreement and has signed the same voluntarily with full knowledge and understanding of the provisions set forth herein. This Agreement shall be interpreted fairly and simply, and not strictly for or against either of the parties. 11. Mutual Consent Divorce, The parties agree and acknowledge that their marriage is irretrievably broken, that they do not desire marital counseling, and that they both have signed consents to the entry of a decree in divorce pursuant to Section 330 I (c) Of the Pennsylvania Divorce Code, Act 26 of 1980, as may be amended (hereinafter referred to as the Code). WIFE has filed a No-Fault Divorce action in Cumberland County at Docket No. 04-4113 at her sole cost and expense, and both parties agree at the appropriate time to execute such consents, affidavits and other documents as may be necessary to promptly proceed to obtain a divorce pursuant to said Section 330lC of the Code. All parties agree to make any necessary corrections to any documents to finalize the divorce. 12. Effect ofthe divorce Decree, The parties agree that unless otherwise specifically provided herein, this Agreement shall continue in full force and effect after such time as a final decree in divorce may be entered with respect to the parties. It is the intent of the parties hereto that this Agreement shall create contractual rights and obligations as well as becoming incorporated into the Court Order and that this Agreement may be enforced by contract remedies in addition to any other remedies which may be available pursuant to the terms of this Agreement or otherwise under the Pennsylvania divorce laws. 13. Bank Accounts, Certificates. Insurance Policies. Pension Funds and other Assets, Each party shall be and remain the sole owner of any other asset in his or her control not specifically covered by other provisions in this Agreement. Should it become necessary, each party agrees to sign any other titles or documents necessary to give effect to this section upon request of the other party. 14. Pension/401llK), Neither party has a pension or 401(K) plan subject to equitable distribution. 15. SupportlAlimonv, HUSBAND and WIFE agree to waive all rights to any claim for Supprt and/or Alimony. 16. 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. The party breaching this agreement shall be responsible for the payment of all legal fees and costs incurred by the other in enforcing his or her rights under this Agreement, or seeking such other remedy or relief as may be available to him or her. 17. Modification and Waiver, Modification or waiver of any provision of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. 18. Severabilitv, If any provision of this agreement is held to be invalid or unenforceable, all other provisions shall nevertheless continue in full force and effect. 19. Descriptive Headines, The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations ofthe parties. 20. Successors and Assiens, This Agreement, except as otherwise expressly provided herein, shall be binding upon and shall inure to the benefit of the respective legatees, devisees, heirs, executors, administrators, assigns and successors in interest of the parties. ~ 21. Governinl!: Law, This Agreement shall be governed by and shall be construed in accordance with the laws of the Commonwealth of Pennsylvania. 22. Entire Al!:reement, This Agreement contains the entire understanding of the parties and there are no representations, warranties, covenants or undertakings other than those expressly set forth herein. IN WITNESS WHEREOF, the parties hereto, intending to be legally bound hereby, have hereunto set their hands and seals the day and year first above-written. WITNESS: (lhref! By: Robyn Pifer Q~WSr-~ By:~~/)r;;r- Rodney Pifer ~ . . COMMONWEALTH OF PENNSYLVANIA : ss: COUNTY OF On this, the 3(J~ day of NDi'ei'Ak-G , 2004, before me the undersigned officer, personally appeared Robyn Pifer, known to me or satisfactorily proven to be the person whose name is subscribed to the foregoing instrument and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. NOTARI.A.l. BE.~1 Jill L l<.lJLAW~ECl NOfAi--:,y ~'lIC BORO OF CARuSLE CUMBERLJ>"'D COUNTY. PA IIV COMMISSION EXPlREb AUGUST 4. 2007 COMMONWEALTH OF PENNSYLVANIA : ss: COUNTY OF On this, the ....J:f''C/ day of jlJe lfei1Li::Jel ,2004, before me the undersigned officer, personally appeared Rodney Pifer, known to me or satisfactorily proven to be the person whose name is subscribed to the foregoing instrument and acknowledge that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and official seal. ,,-;'::':1 AR!!\l ~FAl $:"'l.. i. ,<uLA"I~!t:.CZ NOTARY PUBLIC IOftO Of.: CftPi.J"LE, ClJMB;':;J:{L,\ND COUNTY. PA MY' C;~"'~J.,k,;..o::;.l(\N E.XPt>~ ;;~ {.,. 1r.,lI$T 4. 2007 ROBYN PIFER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-4113 CIVIL TERM RODNEY PIFER, Defendant. : CIVIL ACTION ~ LAW : DIVORCE ACCEPTANCE OF SERVICE I, Rodney Pifer, defendant in the above-captioned matter, do hereby accept service of the Divorce Complaint on this 27th day of August ,2004. /f~~/~ Rodney Pifer ROBYN PIFER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-4113 CIVIL TERM RODNEY PIFER, Defendant. : CIVIL ACTION - LAW : DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 330l(C) of the Divorce Code was filed on August 19, 2004. 2. The marriage between Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a Final Decree of Divorce. 4. I understand that I may lose the 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 the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 P A.C.S. 94904 relating to unsworn falsification to authorities. Date: NOli lmW 22, 2DD4' Roh" pCit f It ROBYN PIFER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-4113 CIVIL TERM RODNEY PIFER, Defendant. : CIVIL ACTION - LAW : DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. 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 in 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 the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA.C.S. 94904 relating to unsworn falsification to authorities. Date: Novlmb-tr ').1}., IJ.oO// RO& f Ii ROBYN PIFER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-4113 CIVIL TERM RODNEY PIFER, Defendant. : CIVIL ACTION - LAW : DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301(C) of the Divorce Code was filed on August 19, 2004. 2. The marriage between Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing the Complaint. 3. I consent to the entry of a Final Decree of Divorce. 4. I understand that I may lose the rights concerning Alimony, Division of Property, Lawyer's fees or Expenses ifI do not claim them before a Divorce is granted. I verifY that the statements made in the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 P A.C.S. 94904 relating to unsworn falsification to authorities. Date: 1/30#4 I RZ~f'~r ROBYN PIFER, Plaintiff '"' : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-4113 CIVIL TERM RODNEY PIFER, Defendant. : CIVIL ACTION - LAW : DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE I. 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! 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 the Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 P A.C.S. 94904 relating to unsworn falsification to authorities. Date: 1113010 y: f!~~fb/ Rodney Pifer , ROBYN PIFER, Plaintiff : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 04-4113 CIVIL TERM RODNEY PIFER, Defendant. : CIVIL ACTION - LAW : 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 93301(c). 2. Date and Manner of service of the complaint: Service was made by certified mail and accepted on August 27,2004. 3. Date of execution of the affidavit of consent required by 9330I(c) of the Divorce Code: by plaintiff: November 22, 2004 by defendant: November 30, 2004 4. Related claims pending: None 5. Date plainitfrs Waiver of Notice in g3301(c) Divorce was filed with the Prothonotary: December 15,2004. . Date defendant's Waiver of Notice in 9330I(c) Divorce was filed with the Prothonotary: December] 5, 2004. Respectfully Submitted, Date: 12/n/CL/ '/ L.- '10...- j,.-', k Kirstin M. Sweigard, Es uire Supreme Court ID# 83801 P.O. Box 1168 Camp Hill, P A 17001 (717) 932-4646 Fax: (717) 932-3577 Attorney for Plaintiff +~ Of. ~ + , , , , . ,.. . , " Of. ~ + ;I' . , ~~:li;l' Of.~++:f.+0f.~~++ + Of: ~ Of. ++ , , + , , . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , + , , , , , . , , , STATE OF Robyn Pifer , , , , , , , + , VERSUS Rodney Pifer , , . , . , + . , + , + + , , , , + , + + , , PEN NA. No. 04 41 D Civil T-:= DECREE IN DIVORCE AND NOW, fl,,,., ~ DECREED THAT Robyn Pifer , , + , , + , , + , , , , , AND Rodney Pifer ~7' ,.2<70# , IT IS ORDERED AND , PLAINTIFF, , 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 , , , , , , , + , , , , + , + , + + + , , + , + , + + + , , , , Of,+, + + 't::f.:+' YET BEEN ENTERED; The Divorce Settlement Agreement dated November 30, 2004, is incorporated BY THE OU;; d TtJuA~ but not merged into this Decree. , + ~++:+'Of.0f.+ + +:+ ~ PROTHONOTARY , , 'fo:++Of.~++ +:f. 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