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HomeMy WebLinkAbout91-3281 SHIRLEY M. VAUGHN, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. jqO( Q.44L Iff! ROBERT P. VAUGHN, : CIVIL ACTION - LAW Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may 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. 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 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. Court Administrator CUMBERLAND COUNTY COURTHOUSE One Courthouse Square Carlisle, PA 17013-3387 (717) 240-6200 SHIRLEY M. VAUGHN, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO . 52 S I e)~.c~l I~} 'i ! ROBERT P. VAUGHN, Defendant CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) or 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Shirley M. Vaughn, who has resided at 49 Country Club Road, Carlisle, Cumberland County, Pennsylvania, for the last 7 years. 2. Defendant is Robert P. Vaughn, who resides at Mount Airy Lodge, Mt. Pocono, Pennsylvania. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six (6) months immediately previous to the filing of this Complaint. 4. The Plaintiff and Defendant were married on January IS, 1971 in Memphis, Tennessee. 5. There have been no prior actions of divorce or for annulment between the parties. 6. Neither of the parties in this action is presently a member of the Armed Forces. 7. The Plaintiff and Defendant are both citizens of the United States. B. Plaintiff has been advised of the availability of marriage counseling and that she may have the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a divorce decree being handed down by the Court. 9. The Plaintiff avers that the grounds on which the action is based are as follows: (a) The marriage is irretrievably broken. WHEREFORE, Plaintiff requests this Honorable Court: (A) Enter a decree of divorce; (B) Grant such further relief as the Court may deem equitable and just. Respectfully submitted, METTE, EVANS & WOODSIDE ~: V L. LEHMAN, ESQUIRE Sup. Ct. I. D. #52784 1801 North Front Street P. O. Box 729 Harrisburg, PA 17108-0729 (717) 232-5000 DATED: September 20, 1991 COMMONWEALTH OF PENNSYLVANIA) ) 55.: COUNTY OF DAUPHIN ) AFFIDAVIT Shirley M. Vaughn, being duly sworn according to law, deposes and says that the facts contained in the foregoing Complaint in Divorce are true and correct to the best of her knowledge, information and belief. 1rl. J aughn Sworn to and su~~ibed befo~ me this day of ~f('J:f-:' ,1991. ~~c J ;J ); 1fItJ//t/oJ N tary Public ~SlrlI MDoA. ~,NOWyPtblc , 'Ha'riStug, Dauphin Cooniy MJCanmIssion 8<pims Fell. 27, 1995 .. H 105,151 REV 8..80 COMMONWEA.LTH OF PENNSYLVANIA OEPA.~TMENT' OF HEALTH VITAL RECORDS . . . CUMBERLAND DIVORCE [ill RECORD OF OR ANNULMENT STATE FILE NUM8ER COUNTY STATE FILE DATE (CHECK ONEl o HUSBAND , NAME ,. RESIDENCE .. NUM8ER OF THIS MARRIAGE (First) IMiddle) La" 2. DATE ot y ." 0' 10 8 1946 BIRTH 0<' 4. PLACE "tflor 0,.,,,,, unITY PA 0' BIRTH PA 7. USUAL.. OCCUPATION ROBERT P. VAUGHN StreflrorR.D. City, Boro. or Twp. unry MOUNT AIRY LODGE MOUNT POCONO MONROE 1 6. RACE WHITE [i] BLACK o OTHE~peCitVl HOTEL MANAGEMENT WIFE RESloeNCE srllttl 9. DATE 0' BIRTH 11. PLACe 0' BIRTH I,.. Ol CUPAION HOMEMAKER (Monthl 1 ro.yJ 14 fV.-,r 48 8 MAIDEN NAME (Firstl fMiddle) (/..JI$l) SHIRLEY M. "- County MUMMERT '0, Stfhr or R.D. Ciry, Bo'O, or Twp. (Sur. or FOIY;,n Country) 12. NUMBER OF THIS t.1ARa'''G~ 15. PLACE OF OF THIS MARRIAGE ~MBER OF ~HIL. OREN THIS MARRIAGE 2 20. NUMBER OF HUSBAND WIFE CH'LORENToD r[1 CUSTODY Of L:!:.J 22 :;,:\-:. ~r C'~':."iFlEE 49 COUNTRY CLUB RD 113. R~ff]E {County) CARLISLE CUMBERLAND PA PA 1 BLACK o OTHER (SOlKifyl o Ins NUMBER OF DEPENDENT CM'LllS- PLAINTIFF CREN UNOER 18 HUSSAND 1 0 SPLIT CUSTODY o OTHER tSP.city) o 16. DATEOF THIS MARRIAGE 11~.HDU6~~1 (Month) 1 (DayJ 15 (V..r} 1971 IStat~orFo"ign Ccumry) SHELBY TENNESSEE WIFE []I WIFETO OTHER ISpe<:ifyl o 0 (Month) fOJJ>lfl (V.r) 21, LEGAL GROUNDS FOR DIVOFlCE OR ANNUl.MENT ~3301(c) (Month) 23. DATE REPrFJ~r_S~NT ,"" TO VlTAL RECORDS irretriveably broken 70.yl Y8Olt'J OTHEFlISo-Cifyl o 24. SIGNATURE OF TRANSCRIBINg Cl.ERK SHIRLEY M. VAUGHN, Plaintiff v. ROBERT P. VAUGHN, Defendant ,; : IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA : NO. 3281 Civil 1991 CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF ACCEPTANCE OF SERVICE I, P. RICHARD WAGNER, Esqui~e, do hereby accept service of a true and correct copy of the Complaint in Divorce directed to my client, ROBERT P. VAUGHN, Defendant in the above-captioned matter, pursuant to Pennsylvania Rules of Civil Procedure No. 402(b). I certify that Robert P. Vaughn has authorized me to accept service on his behalf. Sworn to and subscribed befqre me this ~~~ day of ~~ftYt]A I 1991. ,-:vvrn I Q. ~ i )Q.i4-( -- Notaryipublic NOT AfllAL SEAL TAMI J. STEWART. Notary Public City of Harrisburg, Dauphin County M'I Commission E~njre5 Mav 8. 1995 SHIRLEY M. VAUGHN, Plaintiff, :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v NO. 91- 3281 CIVIL ROBERT P. VAUGHN, Defendant, IN DIVORCE AFFIDAVIT OF SERVICE I, Hubert X. Gilroy, being duly sworn according to law do depose and state that a copy of the Complaint and Notice to Plea filed in the above referenced matter was served on Defendant Robert P. Vaughn, an Affidavit of Acceptance of Service was signed by Defendant's Attorney on Defendant's behalf on September 26, 1991. A copy of the Affidavit of Acceptance of Service is attached hereto and marked Exhibit A. ~(- DATE Hubert X. Gilroy, squire Attorney for PI . tiff Broujos & Gi oy, P.C. 4 North Hanover Street Carlisle, PA 17013 717 - 243-4574 Sworn and subscribed (;-IcJ~ Notarial S.;al i Bridget Ann Corcoran, Notary PUb1WiC Carlisle Boro, Cumberland County My Commission Expires June 10, 2006 Member, Pen!ls\,':'J;:~!) J:",;_,'.:nci;-:I:7Y1 ot Notaries I I'lET E, EVANS II: WOODSIDE, 1 ;, I /1T,T<f+NEYS AT LAW, ~ j r~~'!~S:~l' ~l_~FtN~,:~vANIA~7~1~:8!~r29 11 .. ~'rr :0029 ',j i I J1: 'i ,;1'::' i '> .ll 1'.i " ~ SHIR12 M. VAUGHN, PlaintLff [N TH:: COUET C 10 COMMON PLEAS :U'~BFRLAND COUNTY, PI:NNSYLVANIA \' w 3281 CLvil 199] ROBEI'[ VAUGHN, Defenda.nt ':I'ln. "CTICiN - LAIi EN DI'lJRCE AFJPIC'l!,YI~LOF ~CCJ,P_'l:~CE OF :;;ER'[[Cl~ I" :-'. H ICHARD HAGNER., Esqu.i.,:-e, 00 ;J,:::reby a.c.:e'2'pt service :)f a true and correct copy of the Complaint in Divorce direct:e to my client" HOBERT P. VAUGHN, Defendant in th,~ above-Criptioned matter. pu]"suant t,o ]Jennsylvilnia Rules of Civil Procedue No 402(b). [ ~erti[y that Robert P. Vaughn has authc:r.L '\'?d me 1:0 accept- s,3rvice (,1[: i1:~s behalf / " / " ~-) /" ./" /'/ ,/ ,. "",, .--'--~'" .---::::;:;,. . / ..':::::-----:: --:> / /~:~~;7' /:::=.~~ - ' . --_.~-- ../-~~ - ---,'.---_. At J:-<1'nl,P l' :I"er[)~.j. da n t ,/...../ ------/ / " / ..--- ,/' 4,____- ---- Sworn t.. and subscr ibE,d f\.r ;t\."'. befof~'_Jl:e t~..jS ilL day o f ~.ik..._'nl( 'i . .. , 1 99 1. 11 ^.JL t", .",' '\-r;-- "', .. ~ L;:.A .. ;LL!i.1ktL N.t.,.,y PublH C~ '=""l ..... v' c.; __c, C: ....., .,...; ~.;"". ","---., ~~~ ~ ~~-~ '"';:" ::u \::'~ ~>Cj I ,..-%--lQ <.:O'X,"""', );;c:: :::)::' :;t:CZ(') i;:C::,om :.t,;! --, ~... --or':,::" c..... ] NOTARIAL SEAL .i'"Ah'!i J_ STEWART Notary Public City . HamSbu'J- C.,uphin Coun~/ ~~:,mm!SSIOn t:xo'rcs May d. 1995.__ ::Ii,;,,,. :'1: c.c' -.~" I:XHIBIT I, / ' ,. ~... - ~ h 1. -II - CJ 1-> 0 (~, c.~ C';.;) -n -;;..r' ~ .-4 :''';.1 :C-q r~' . ;Al 'E. rV -OJ'' 'uO u:> iJ{) -c :.,. ',:\'\ <; f.;-=-) /"' ~,::..:; 1'1 1. 0' ,-.-" --..\ J';:'* :(6 -< -l :-< - 3301(c).not SHIRLEY M. VAUGHN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v 91-3281 CIVIL TERM ROBERT P. VAUGHN, II, Defendant IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330l(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on September 23, 1991. 2. Defendant was served the Complaint on or about September 27, 1991. 3. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree of divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 6. 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. 7. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. 1 verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. Date: '0 ,'M,v. " 1-.r () L) " .j c.. '-t-fJ , ~ - SHIRLEY M. VAUGHN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : ClJMBERLAND COUNTY, PENNSYL VANIA v 91 - 3281 CIVIL TERM ROBERT P. VAUGHN, Defendant IN DIVORCE AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. A Complaint in divorce under Section 3301(C) of the Divorce Code was filed on September 23,1991. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety days bave elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree of divorce without notice. 4. I understand that 1 may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. 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. 6. I have been advised of the availability of marriage counseling and understand that I may request that the Court require counseling. I do not request that the Court require counseling. I verify that the statements made in this affidavit are true and correct. I understand that false $tatements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. llate: I 0 - ;1. ~ - 0 'J..... 'heU hn, Plaintiff C:.1. , - .-, , , \:.' (,::' !SHIRLEY M. VAUGHN, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. : NO. 91-3281 CIVIL TERM : CIVIL ACTION - LAW !ROBERT P. VAUGHN, III : IN DIVORCE Defendant. AFFIDA VIT OF CONSENT 1. A Complaint in Divorce under Section 3301(c) of the Divorce Code was filed pn September 23, 1991. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of ffitention to request entry of the decree. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relating to unsworn falsification to authorities. DATE: 1)1 / tS" ??L ~-t r ;:>. J ~--'-1r Robert P. Vaughn, II -~.^'_._.,~~,..~~-~~ \~? ,~) .:::::J C.;-'- ....J. !'o N r...;. en \.,L:l SHIRLEY M, VAUGHN, : IN THE COURT OF COMMON PLEAS : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. : NO. 91-3281 CIVIL TERM : CIVIL ACTION - LAW ROBERT P. VAUGHN, II : IN DIVORCE Defendant. WAIVER OF NOTICE OF INTENTION TO REOUEST 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. 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 ~anted. 3. I understand that I will not be divorced until a divorce decree is entered ~y 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 fa.C.S. ~4904 relating to unsworn falsification to authorities. , " ? i.'C- ;elJW' -V d- Robert P. Vaughn, II IDATE: f/I/OS- ....j --' "L .. ".J r<. ~......~ en ....,(j ._---,.""""--_......._'.....,~......,. SHIRLEY M, VAUGHN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v No. 1991-3281 CIVIL TERM ROBERT P. VAUGHN, II, Defendant CIVIL ACTION-LAW IN DIVORCE TO: Robert P. Vaughn, II, 4715 S. Rio Grande Avenue, Orlando, FL 32839. NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter- affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on Q OflloA.!k, 1911 and have continued to live separate and apart for a period of ~o years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. DATE:-}. 'M.,; '7. 'JlJ/) 1) . - ) "Jf ~ - SHIRLEY M. VAUGHN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff/Respondent, NO. 3281 Civil 1991 v. ROBERT P. VAUGHN, CIVIL ACTION - LAW Defendant/Petitioner. IN DIVORCE PETITION FOR SPECIAL RELIEF AND NOW, comes your Petitioner, Robert P. Vaughn, by his attorneys, Mancke and Wagner, and files the following Petition for Special Relief. 1. Your Petitioner, Robert P. Vaughn, is the Defendant in the above captioned divorce action. He resides at Mount Airy Lodge, Mt. Pocono, Pennsylvania. 2. Your Respondent, Shirley M. Vaughn, is an adult individual residing in Carlisle, Cumberland County, Pennsylvania, and has instituted an action in divorce on the 23rd day of September of 1991. 3. Prior to the institution of the suit in divorce by the Respondent herein, Shirley M. Vaughn, the Petitioner and Respondent were the owners of certain marital property some of which were in the form of a money market at Commonwealth National Bank, a savings account at Farmer's Trust Bank, and a Certiflcate of Deposlt at'CCNB. 4. The aforementioned accounts were in joint names and totaled approximately $195,000.00. 5. On or about September, 1991, the Respondent herein did unilaterally remove the aforementioned accounts and placed all monies in an unknown location, presumably in another bank account or in another account in her own name. 6. The Petitioner herein has, on several occasions, requested through counsel of the parties to have the monies returned to a joint account, but Respondent herein has refused and continues to refuse to do so. 7. Petitioner believes and therefore avers that the unilateral actions by the Respondent herein can or could jeopardize the integrity of the accounts by first having them removed so that they are totally under the control of the Respondent herein and secondly because the Respondent now not only has unilateral control but also is subject to any creditor of the Respondent attaching those proceeds for any judgment that mayor may not be entered against her in the future. 8. Petitioner further believes and therefore avers that the unilateral transfer can jeopardize the integrity of the joint marital assets and the action by the Respondent constitutes potential dissipation of a marital asset. 3 VERZDCATiQN I verlfy that the statements m~do In the forego1nS docum&nt ~re true and correct. I undarstand that f~l&e stataments herein are made subject to the penalties of 18 Pa.C.S. Section 4904, relatin; to unsworn falsification to author1ties. z~~~~ Dated:. A"'iz,o.I..:!~ / <? '12- . " o(~ '''l :.' ,~,,~~'" . --a 1'" _""'"Too~:;."\:'I'l'r'~i~~-'I' ..,.~~...l. .~ a, '.~,"",,-",. .,';-.'-:":....: .. ..," '0 T ........L-, SHIRLEY M. VAUGHN. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintlff/Respondent, NO. 3281 CiVll 1991 V. ROBERT P. VAUGHN, CIVIL ACTION - LAW Defendant/Petitioner. IN DIVORCE ORDER AND NOW, thi s-1ill. day of__AJL~'~.2t___~.._, 1992, upon Petition of Robert P. Vaughn, a Rule is hereby issued upon the Respondent, Shirley M. Vaughn, to show cause why, if any, the relief requested herein, in the form of returning the proceeds from a Certificate of Deposit at CCNB Bank, a money market at Commonwealth National Bank, and a savlngs account at Farmer's Trust Bank, should not be returned to joint names. Ru 1 e retu rnab 1 e the ..)/ )<1 .~ day of _':'':'d< /J:{~'_-L,--<-,_,____, 1992, at /1' .j( o'clock _,_--t,-.m. in Courtroom No. I-.~ -. ~~..- ----- , Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT: / / ,La. ~_ __._ . J. , V 'It,;;', ^'v.' j 25, W~ . I lb. Wd ~(. I , -' ~ \~;, ~ ~- \ !'f1:; , ,,;"'j Z I ~n't; lb. ~d; _ \ c,wr "; '';'\\'1: - IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA SHIRLEY M. VAUGHN Plaintiff vs. ROBERT P. VAUGHN NO. 3281 19 91 SH[RLEY M. VAUGHN a master with ect to the ( Divorce ( ) Annulment ( ) Alimony ( ) Alimony Pendente MOTION FOR APPOINTMENT OF MASTER (Plaintiff) (E~Z' moves the court to appoint following claims: ( , Distribution of Property ( ) ?ttpport (~ ~unsel Fees (~Costs and Expenses Lite and ~n support of the motion states: (1) Discovery is complete as to the claims(s) for which the appo~ntment of a master is requested. (2) THe d fendant (h s) (has (by qis attorney, r . C (3) The the action (personally) ,Esquire). (are) (4) Delete the inapplicable paragraph(s): (a) The action is not contested. (b) An agreement has been reached with respect to the following claims: /V()/t..o(- (c) The/action is contested with respect to the following clainls: A- ( (5) The action (il""\Jlv~o:)1 (does not involve) complex issues of law or fact. (6) (7) The hearing is expected to take Additional information, if any. / relevant {tlUUI.S' to the motion: (days) . AND NOW h \ l, l is a~pointed master ORDER APPOINTING MASTER 2 C ,19,(1, r. \j'.L( rl with respect to the following claims: " ,-. Esquire Esquire, Date: November 20, 1997 ( j (-~ .\. .~ - By the Court: /j rI ., : I I \_, \J- ,,-, r, J. ( " "i , , , ..,# ,,-... ,.. !\~ _:.) SHIRLEY M. VAUGHN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V ~OBERT P. VAUGHN, Defendant NO. 91-3281 CIVIL PETITION TO RAISE ADDITIONAL CLAIM flaintiff, Shirley M. Vaughn, by her attorneys, Broujos & Gilroy, p.e, sets forth the .ollowing: 1. The plaintiff has filed the divorce action against the Defendant in the above captioned term and number. 2. The parties possess various items of personal property that is subject to equitable distribution. 3. Plaintiff requests the Defendant to reimburse her for counsel fees, expenses and costs of the litigation. tNherefore, Plaintiff requests the following claims also be litigated in the divorce action: 1. Equitable distribution of marital property. 2. Plaintiff's claim for counsel fees. 3. Plaintiff's claim for costs and expenses. Respectfully submitted. _ ~GilCOY' ,,,,,ire Attorney for Plaintiff BROUJOS & GILROY, P. c. JOHN H. BROUIOS HUBERT X. GILROY ATTORNEYS AT LAW 4 NORTH HANOVER STREET CARLISLE, PENNSYLVANIA 17013 717-243-4574 NON-ToLL FOR HARRISBURG AREA 717-766-1690 FA" 243-8227 September 14, 1998 E. Robert Elicker, II Divorce Master Cumberland County Courthouse Carlisle, PA 17013 Re: Vaughn v Vaughn Dear Bob: Enclosed in the above referenced matter is a Petition I filed with the Prothonotary Raising the Claims on Equitable Distribution, counsel fees and costs in the above referenced case. Tracey in your office had indicated to me that proceeding on the Master's Appointment had been held up pending the filing of this document. I request that you schedule further proceedings in this matter so that we can move this case along. dch Enclosure cc: P. Richard Wagner, Esquire Shirley M. Vaughn Charles Wolf, Esquire SHIRLEY M. VAUGHN, Plaintiff/Respondent: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . NO. 3281 CIVIL 1991 CIVIL ACTION - LAW V. ROBERT P. VAUGHN, Defendant/Petitioner: IN DIVORCE ORDER OF COURT AND NOW, this 2. '" l~ day of July, 1994, upon relation of Petitioner's counsel, P. Richard Wagner, Esquire, that an agreement has been reached in the above matter, the hearing scheduled for July 26, 1994 is CANCELLED and the temporary order entered July 22, 1994, shall remain in effect. BY THE COURT, ./1 /J / J. P. Richard Wagner, Esquire Counsel for Defendant/Petitioner Hubert x. Gilroy, Esquire 'Counsel for Plaintiff/Respondent :epj ------------------------------- -flf.;\"i' ~_SMSid Al~Hi:J:; O:..v!;::3Gtm~ j..'1l'10HOH ">(1; If!) 30 1:lIA'0 ~ 1tG. HV 8ft II 9Z lflr --------------- ~HIRLEY M. VAUGHN, i Plaintiff/Respondent VS. SEP '. l(',y. ,,' j;:)IJI 'I .... , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 3281 CIVIL 1991 CIVIL ACTION - LAW ~OBERT P. VAUGHN, Defendant/petitioner IN DIVORCE IN RE: PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 2nd day of September, 1992, !following a hearing on the petition for special relief submitted !by the Defendant, Robert P. Vaughn, and upon consideration of !the representations and arguments of counsel, it is ordered and i I Idirected that the Plaintiff return to joint accounts from which , Iwithdrawals may be made only with the signatures of both parties Ithe sum of $144,000.00, and it is further ordered and directed I Ithat the Defendant make no disposition of the stock which has !been referred to in this hearing. This order shall remain in effect pending further order of Court. Nothing in this order is intended to represent a finding, preliminary or otherwise, on the issue of equitable distribution. "'" CT> ::lE: 0._ ~ M (V) :>- ~1~~~1 c=~~~;~ l...;.. :r:C).'" ;.~ ,.. :~:~~ ".,'/J By the Court, ,; ,:,~ Q... W (/') ~ "-' J. P. Richard Wagner, Esquire Counsel for Defendant/Petitioner Hubert X. Gilroy, Esquire Counsel for Plaintiff/Respondent 1 :slr SHIRLEY M. VAUGHN, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 3281 CIVIL 1991 CIVIL ACTION - LAW ROBERT P. VAUGHN, Defendant/Petitioner IN DIVORCE IN RE: PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 2nd day of September, 1992, following a hearing on the petition for special relief submitted by the Defendant, Robert P. Vaughn, and upon consideration of the representations and arguments of counsel, it is ordered and directed that the Plaintiff return to joint accounts from which withdrawals may be made only with the signatures of both parties the sum of $144,000.00, and it is further ordered and directed that the Defendant make no disposition of the stock which has been referred to in this hearing. This order shall remain in effect pending further order of Court. Nothing in this order is intended to represent a finding, preliminary or otherwise, on the iss~ of ~quitable distribution. . .r"" ....... :t:: f.- :~ 0... UJ '" .':" By the court, ~~~<:::.-: :::r I.l..., c, "-"-..-~ ..". 4,~::C:C)> (Y) t';:;.:-;: ::.::~ i':~ "L; :':::': ,.~ ;':") 1-,W /.' :;:1::: c.. -" ~;0 .... u.. V'> J. P. Richard Wagner, Esquire Counsel for Defendant/Petitioner Hubert X. Gilroy, Esquire Counsel for Plaintiff/Respondent :slr SHIRLEY M. VAUGHN, Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA : V :NO. 3281 - CIVIL - 1991 . . Defendant :CIVIL ACTION - LAW :IN DIVORCE ROBERT P. VAUGHN, PRAECIPE TO THE PROTHONOTARY: Please withdraw the appearance of the firm of Mette, Evans & Woodside on behalf of Shirley M. Vaughn in the above matter. i?/r; #;{ 'DATE ( /I!tz~ '-- Maria P. i, Esquire Mette, E ans oodside 1801 North Front Street P.O. Box 729 Harrisburg PA 17108-0729 r::.:- - SHIRLEY M. VAUGHN, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA V :NO. 3281 - CIVIL - 1991 : ROBERT P. VAUGHN, Defendant :CIVIL ACTION - LAW :IN DIVORCE PRAECIPE TO THE PROTHONOTARY: Please enter the appearance of Broujos, Gilroy & Houston, P.C. in the above referenced matter on behalf of the Shirley M. Vaughn. Ctl/&( r~ DATE Hubert X. Gilroy, Es Attorney for Plaint' f Broujos, Gilroy & Houston, P.C. 4 North Hanover Street Carlisle PA 17013 717-243-4574 {_.r L" -- c(.~ 1:'''''': LAW OFFICES ro ~ "'" APE HERE" ~,.~ ro "" A WRITTEN RESPONSE TO THE: """"". VI ITHIN twENTY (20) DAYS FROM HEREOF OF! A JUDGMENT .\{ :Y8EENTEREDAaAlNST'I"OU ;"'\ ATTOAHEY ~ WE D.O HERE Y CERTIFY THAT THE WITHIN IS A TRUE ANO COR. RECT COPY F THE ORIGINAL FllB> IN THIS BY MANCKE, WAGNER, HERSHEY & TULLY EY ORDER AND NOW, this Jd ~day of upon Petition for of ROBERT P. VAUGHN, it is hereby , 1995, ERED that the divorce may proceed under the new divorce master system. BY THE COURT: hh~ E . if, J. SHIRLEY M. VAUGHN, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. : NO. 3281 CIVIL 1991 : CIVIL ACTION - LAW ROBERT P. VAUGHN, IN DIVORCE Defendant. PETITION AND NOW, comes the Petitioner, ROBERT P. VAUGHN, by and through his attorneys, MANCKE, WAGNER, HERSHEY & TULLY, and files the following Petition to proceed under the new divorce master system: 1. Your Petitioner, ROBERT P. VAUGHN, is the Defendant in the above-captioned matter. 2. The Respondent, SHIRLEY M. VAUGHN, is the Plaintiff in the above-captioned matter. 3. The divorce action was filed prior to December 1, 1991. 4. There has been no Master appointed in this matter. 5. Petitioner and Respondent have been separated for a ~eriod in excess of two years and has considerable marital ~roperty which cannot be agreed upon as far as division is Cl:oncerned. 6. Petitioner requests this Court to permit Petitioner to proceed under the new divorce master system. -I 7. Petitioner is filing a $125.00 fee with this Petition. WHEREFORE, Petitioner requests that he be permitted to proceed with the appointment of a master under the new divorce jnaster system. Respectfully submitted, IlANCltB, .1\ ....../ , HERSHEY , TULLY .---.-...... i , Esqul.re Front street urg, PA 17110 234-7051 Attorney for Petitioner ~ATE: 1- 3 qs- SHIRLEY M. VAUGHN, IN THE COURT OF COMMON PLEAS . CUMBERLAND COUNTY, PENNSYLVANIA . Plaintiff, v. . NO. 3281 CIVIL 1991 . CIVIL ACTION - LAW ROBERT P. VAUGHN, : IN DIVORCE Defendant. . . AND NOW, ORDER thiS..!d ttfday of ~< , 1995, upon Petition for of ROBERT P. VAUGHN, it is hereby ERED that the divorce may proceed under the new divorce master system. BY THE COURT: Mcv1 t= -J1, J. SHIRLEY M. VAUGHN, Plaintiff/Respondent: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 3281 CIVIL 1991 ROBERT P. VAUGHN, Defendant/Petitioner: CIVIL ACTION - LAW IN DIVORCE PETITION FOR SPECIAL RELIEF AND NOW comes Your Petitioner, Robert P. Vaughn, by his attorneys, Mancke, Wagner, Hershey & Tully, and files the following petition for special relief: 1. Your Petitioner, Robert P. Vaughn, is an adult individual residing at 49 Country Club Road, Carlisle, Cumberland County, Pennsylvania. 2. The Respondent, Shirley M. Vaughn, resides in a property other than that set forth in paragraph one above. 3. The parties' marital home is at 49 Country Club Road, where the Petitioner currently resides. 4. On or about the weekend of July 21st, 1994, the Respondent returned to the marital home and spent the night. 5. Upon inquiry by Petitioner as to why the Respondent had returned to the marital home, Respondent advised Petitioner that she was conducting a yard sale during the weekend of July 22nd and 23rd of 1994, at which point in time she intended to sell the fUrniture, personal property and other items in the marital home, 6. Your Petitioner, through counsel, contacted counsel for the Respondent, in an effort to try to reach an amicable resolution to avoid the sale or distribution or transfer of marital assets, but no such understanding was reached. 7. Petitioner, through counsel P. Richard Wagner, advised counsel for the Respondent, Hubert Gilroy, that a petition for injunctive relief would be filed and notification was therefore given of the filing of this petition for special relief. 8. Respondent's counsel acknowledged that Petitioner should file the same to avoid the sale and the consequences thereof. 9. Petitioner believes and therefore avers that the Respondent intends to conduct a yard, garage or similar type of sale at the marital residence during the weekend of July 22nd, 1994 and intends to otherwise sell, transfer, give away or dissipate marital assets of the parties in the form of personal property, fUrniture, etc. and further intends to sell, transfer or otherwise dissipate assets belonging personally to Robert Vaughn. 10. Respondent has in the past removed marital property from the home without consent of the Petitioner, 11. Peti tioner requests the Court to enjoin the sale as having not been consented to by the Petitioner and otherwise constituting a dissipation of marital assets, and the removal of marital property from the marital home. WHEREFORE, Petitioner prays This Court to grant the relief requested. Date: .. I. ,J.c).. q~1 MANCKE, WAGNER, HERSHEY, & TULLY Attornevs for Petitioner . / / / / By: P. Rich~d W gner, Esquire 2233 North ront Street Harrisbu ,PA 17110 1717) 4-7051 Supreme Court I.D. #23103 VERIFICATION I verify that the statements made in the foregoing document 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. '1~ r. tJ~O :;:v r V Date: SHIRLEY M. VAUGHN, Plaintiff/Respondent: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 3281 CIVIL 1991 ROBERT P. VAUGHN, Defendant/Petitioner: CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, P. Richard Wagner, hereby certify that on this date Petitioner's Petition for Special Relief was served on all interested parties by depositing a true and correct copy of the same in the United States Mail, regular mail, postage prepaid at Harrisburg, Pennsylvania, addressed as follows: Hubert X. Gilroy, Esq. 4 North Hanover Street Carlisle, PA 17013 /~/. P. Date: --, . .:).j. q,..J L- SHIRLEY M. VAUGHN, Plaintiff/Respondent: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 3281 CIVIL 1991 ROBERT P. VAUGHN, Defendant/Petitioner: CIVIL ACTION - LAW IN DIVORCE ORDER AND NOW, this ~lday of ~, 1994, upon petition of Robert p, Vaughn, the Respondent, Shirley M. Vaughn, is ordered and enjoined from the sale, transfer or distribution of any assets of the parties or assets of the Petitioner herein at a yard sale on Jul y 23, 1994 or any simi lar yard sale or garage sale without further order of court. removing marital property from t rital residence, and Respondent is directe 1 e an inventory of all marital property h baSH FE!Hle.~el 8.8 sf Ll.lC: da.L'C' vf Lb~o OLd-c..r. A H UI.e..1 K.) (,- VI t~, ~ "";>1t U' S~ 111 /., c:. ~u(J .. f"7 ~ .) ~ I /11 'if eu:- BY THE COURT: k4~'~' ~ ~~.~~,eoe! Y--~<JZ/J</CLy- / J. \~a ~~\q~ ..I':l'?' I) u f ..,~i0\.(,'\\'j ~. , \~'...;, ':l . .~ \ '" " \J.\\~~ \. \..".,:,:::'\:;y.,-~, ' ,.. ~t."" ~.l\_ ...of\(" l-~ ,':J' . . 1,1. \\'\ \ S\l. \ ~,~<\ / ---- SHIRLEY M. VAUGHN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V ROBERT P. VAUGHN, Defendant NO. 91-3281 CIVIL PETITION TO RAISE ADDITIONAL CLAIM Plaintiff, Shirley M. Vaughn, by her attorneys, Broujos & Gilroy, P.C, sets forth the following: 1. The plaintiff has filed the divorce action against the Defendant in the above captioned term and number. 2. The parties possess various items of personal property that is subject to equitable distribution. 3. Plaintiff requests the Defendant to reimburse her for counsel fees, expenses and costs of the litigation. Wherefore, Plaintiff requests the following claims also be litigated in the divorce action: 1. Equitable distribution of marital property. 2. Plaintiff's claim for counsel fees. 3. Plaintiff's claim for costs and expenses. Respectfully submitted. _ ~GHroY, """;re Attorney for Plaintiff (J;) <;; t 15 ~ '" , "", ~J ..J ,1;1 '^ (? 'l'- ., ,--. [.) rt \;: 'f ... ... ~ .:r\ c <!- 0 ,0 ;-) C;; ,,1:> ->0 " :n it; d) t~~ 1''<1 \:,;2 (\ -0 ;'-: 'r" ,j/-,.- ~' ,i-n :7 ( c.;---'l " ~ <:~~;', u', ~.J '-I" ~ ~ (51 3.(-' r::..L.- -"'.~) ", .t"\ ....:J :,2\ ? ~';Cl ,.- ;._~\:D , ' _)-0 ."-' :'r'--;m 00.;;''-- t.) 9-.l ~ ,) .Y:O-C~ ~ --l :.;:-' .....:J ):.'> 0 ,-} :.:1-"1 I' ....1).. -- .r:- % ,~ , , f SHIRLEY M. VAUGHN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 3281 CIVIL 1991 ROBERT P. VAUGHN, Defendant IN DIVORCE ORDER OF COURT AND NOW, this (?!/ ~ day of r;z-t/1'LL/' 2002, counsel having advised the Master's office on August 30, 1999, that the above captioned case was settled, and no agreement having been provided the Master's office, the appointment of the Master is vacated. BY THE COURT, .J. cc: Hubert X. Gilroy Attorney for Plaintiff P. Richard Wagner Attorney for Defendant ~..~d {. ..1 /.6;L. ~. t ~I; ,~~ " II: , ' ' ~ \.-' \'.; i i PROPERTY SETTLEMENT AGREEMENT t\ THIS IS AN Agreement made this d <{ day of ~OV ,1999, by and between Robert P. Vaughn, (hereinafter referred to as Husband) and Shirley M. Vaughn, (hereinafter referred to as Wife). WHEREAS, Husband and Wife were married on January 15, 1971; and WHEREAS, various differences have arisen between Husband and Wife, whereby they have been living separate and apart; and WHEREAS, the Wife has commenced a divorce action against Husband docketed at No.91-3281 in Cumberland County, Pennsylvania; and WHEREAS, the parties desire to enter into an amicable settlement to provide for all of the property rights of the parties and to dispose of the rights and obligations of each to the other in respect to support, maintenance, alimony, counsel fees, equitable distribution, and all other rights and obligations under the Divorce Code of 1980, as amended, and it is the intention and agreement of the parties that this Agreement be a full, complete and fInal settlement of all of those rights and obligations under said Divorce Code; and NOW, THEREFORE, for and in exchange ofmutuaJ considerations, and intending to be bound by the provisions hereof, the parties agree that their recitals form a part of this Agreement and waive any right to counseling under the Divorce Code of 1980, as amended, and right to counsel fees, costs, alimony, support, maintenance, and any other rights under the said Divorce Code not provided for herein and agree as follows: 1 The parties agree that it shall be lawful for each party, at all times hereafter, to live separate and apart from the other, at such place or places as he or she may, from time to time, choose or deem fIt. Each party shall be free from interference, authority or contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry out the provisions of this Agreement. Neither party shall molest the other or attempt to endeavor to molest the other, nor compel the other to cohabit with the other, or in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart, from the other. ,~ 2 Husband shall have exclusive ownership of the marital real estate at 49 Country Club Road, Carlisle, Pennsylvania. Wife shall execute all docwnentation necessary to transfer any and all interest she has in said real estate to Husband. 3 The Delorean automobile shall be the exclusive property of Wife and the N6 automobile shall be the exclusive property of Husband. 4 The parties own one thousand (1,000) shares of Manor Care stock and one thousand (1,000) shares of Choice Hotel stock. These stocks shall be split equally between the parties with Husband receiving five hundred (500) shares of Manor Care and five hundred (500) shares of Choice Hotel stock and wife receiving five hundred (500) shares of Manor Care and five hundred (500) shares of Choice Hotel stock. ' 5 Husband shall maintain all personal property in his possession as his exclusive property, and Wife shall maintain all personal property in his possession as his exclusive property. 6 Wife shall maintain sole ownership of the real estate located at 301 West Pine Street, Mt. Holly Springs, Pennsylvania. Husband shall execute any and all docwnents necessary to transfer any interest in said real estate. 7 \Wife shall have exclusive ownership of the monies located in the MellonJPNC Bank account which jhas an approximate value ofFlFTY FIVE THOUSAND ($55,000.00) DOLLARS at this time. 8 ~y savings bonds in the name of Wife or in the name of the parties' children that are in the possession of Husband shall be delivered to Wife and Wife shall be the exclusive and sole owner of ~aid bonds. 9 $ach party hereby represents that they have disclosed all of the marital assets to the other party in $e negotiations for the consummation of this Agreement. ~ . 20 This Agreement shall be construed under the laws of the Commonwealth of Pennsylvania. 21 If any term, condition, clause or provision of this Agreement shall be detennined or declared to be void or invalid in law or otherwise, then only that term, condition, clause or provision shall be stricken from this Agreement, and, in all other respects, this Agreernent shall be valid and continue in full force, effect and operation. 22 Except as otherwise set forth herein, this Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above written. WITNESS / / sJd~::-ll + ~~ '?~ z) -~ Robert P. Vaughn :, ())j / / ./ ,/ f__.---- ( SHIRLEY M. VAUGHN, Plaintiff : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v NO. 91-3281 CIVIL ROBERT P. VAUGHN, Defendant CIVIL ACTION - LAW PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a divorce decree: 1. Ground for Divorce: Irretrievable breakdown under Section (x )3301(c) 03301(d)(1) of the Divorce Code. (Check applicable section.) 2. Date and manner of service of the Complaint: on or about September 26, 1991, Affidavit of Acceptance of Service signed by Defendant's Attorney, P. Richard Wagner, Esquire. 3. (Complete either paragraph (a) or (b). (a) Date of execution of the affidavit of consent required by Section 3301(c) of the Divorce Code: By Plaintiff: October 28, 2002; Defendant: April I, 2005 . (b) (I) Date of execution of the Plaintiffs affidavit required by Section 3301(d) ofthe Divorce Code:_; (2) Date of service of the Plaintiffs affidavit upon the Defendant:_. 4. Related claims pending: None. 5. Complete either (a) (b). (a) Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached: (b) Date Plaintiffs Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: October 28, 2002. (c) Date Defendant's Waiver Prothonotary: April 22, 2005 of Notice in ~3302( UJiI1:1 Hubert X. Gilroy, Es Attorney for Plaint' Broujos & Gilro); C 4 North Hanov Street Carlisle, PA 013 717-243-4574 '. (-.' c::'l 'dA "'" -0 ';;<) ~ ...s;J -0 ....i~.. - o ~l ~:r, \"f-- -:~\S1 '~~lO : ,-," -~'. <~ (,~j ~?~cn -- 'il ..... (~ ()1 .l' " , , , , , , , . :f.'t::f. 'f. .., ~ ~'t::f.:f. ~ ~ ~ ~:f.~ ~~~~ ~:f.'t:~'f.~~:f.+'t:++'f.+'+'+'+'+'+'+'+'+++ +. ;+: Of. + +. '+' Of+. . . . . . + ++. ++. IN THE COURT OF COMMON PLEAS OFCUMBERLANDCOUNTY . . . . . . . . . PENNA. STATE OF Shirley M. Vaughn . . . . . . . . . . . NO. 91-3281 Plaintiff VERSUS Robert P. Vaughn . . . . . . . . . . . . . . . . . Defendant DECREE IN DIVORCE ,. , .2~, IT IS ORDERED AND . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . AND NOW, M~l t, Shirley M. Vaughn , PLAINTIFF, DECREED THAT Robert P. Vaughn , DEFENDANT, AND 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; PTOpP-Tty Sp-rr1p.mpnt A~rppmpn~ ~Rtp~ Nnvp.mhpr ?Q, lqqq is incorporated into this Order. . . . . . . A J. . . . . . . . . . . , ++ ++++++++. +++++++ ++++ +++++++++++ +++++ +++.++++? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . ~('-? frt;l;: ~~,7'j/ /P:2'!)i., 5(/ !I -;; ~' fIy?- hp~.~1 ~p pp ;;7/ 65 .' .