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HomeMy WebLinkAbout05-3552 .~ ,_. ,., PAULA J. GEORGE, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. . : NO. 0.5' ~ 35 C; d < ew-J RANDY S. GEORGE, Defendant : CIVIL ACTION - LAW : 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 action. You are warned that, if you fail to do so, the case may proceed without you and a decree of divorce or annulment 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, One Courthouse Square, Carlisle, Pennsylvania, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE of the Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telephone (800)-990-9108 PAULA J. GEORGE, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. RANDY S. GEORGE, Defendant : CIVIL ACTION - LAW : IN DIVORCE A VISO PARA DEFENDER Y RECLt\MAR DERECHOS USTED HA SIDO DEMANDADO EN LA CORTE. Si desea defenderse de las quejas expuestas en las paginas seguientes, debe tomar accion con prontitud. se Ie avisa que si no se defiende, el caso pude proceder sin usted y decreto de divorcio 0 anuIamiento puede ser emitido en su contra POr las Corte. una decision puede tambien ser emitida en su contra por cauIquier otra queja 0 compensacion ecIamados por el demandante. Usted puede perder dinero, 0 propiedades u otros derechos importantes para usted. Cuando la base para el divorcio es indignidades 0 rompimiento irreparable del matrimonio, usted puede solicitar consejo matrimonial. Una lista de consejeros matrimoniales esta disponible en la oficina del Prothonotary, en la Cumberland County, One Courthouse Square, Carlisle, PA 17013. SI USTED NO RECLAMA PENSION ALIMENTlCIA, PROPIEDAD MARITAL, HONORARIOS DE ABOGADO U OTROS GASTOS ANTES DE QUE EL DECRETO FINAL DE DlVORCIO 0 ANULAMIENTO SEA EMTIDO, USTED PUEDE PERDER EL DERECHO A RECLAMAR CUALQUlERA DE ELLOS. USTED DEBE LEV AR ESTE PAPEL A UN ABOGADO DE INMEDlATO. SO NO TlENE 0 NO PUEDE PAGAR UN ABOGADO, VA YA 0 LLAME A LA OFlCINA INDlCADA ABAJO PARA A VERlGUAR DONDE PUEDE OBTENER ASISTENCIA LEGAL. LAWYER REFERRAL SERVICE of the Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 Telefono (800)-990-9108 PAULA J. GEORGE, Plaintiff, vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. (J.:5 - :3 ~-::;---.2. RANDY S. GEORGE, Defendant : CIVIL ACTION - LAW : IN DIVORCE COMPLAINT IN DIVORCE AND NOW, comes Plaintiff, Paula J. George, (hereinafter referred to as "Plaintiff'), by and through her counsel, Linda A. Clotfelter, who files this Complaint in Divorce and in support thereof states the following: 1. Plaintiff is Paula 1. George, (hereinafter "Plaintiff') an adult individual who resides at 835 Ridgewood Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 2. Defendant is Randy S. George, (hereinafter "Defendant"), an adult individual who resides at 835 Ridgewood Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. The parties are the parents of four (4) minor children, namely Althea A. George, born June 7, 1990, age fifteen (15) years; Chelsea M. George, born September 19, 1992, age twelve (12) years; Joshua J. George, born May 22, 1999, age six (6) years; and Benjamin 1. George, born June 28, 2002, age three (3) years, COUNT I REOUEST FOR DIVORCE 4. Paragraphs I through 3 are incorporated herein by referenced as if fully set forth. 5. Plaintiff has been a bona fide resident of the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the filing of this divorce Complaint. 6. Plaintiff and Defendant were married on October 26, 1985, in Carlisle, Cumberland County, Permsylvania. 7. The parties have been separate and apart within the meaning of the Permsylvania Domestic Relations Code since May 22, 2005. 8. There are no pending divorce proceedings upon the filing date of this Complaint. 9. Defendant is not a member of the anned forces of the United States or any of its allies. 10. Plaintiff avers that the marriage is irretrievably broken. II. Plaintiff as the irmocent and irUured spouse has suffered such indignities due to Defendant's conduct that Defendant has made Plaintiff's life intolerable and burdensome, 12. Plaintiff has been advised of the availability of counseling and that Plaintiff may have the right to request that the court require the parties to participate in counseling. Plaintiff does not desire counseling. WHEREFORE, Plaintiff respectfully requests that this Court enter a Decree of Divorce and grant such other relief as this Court deems just and proper. COUNT II EOUlT ABLE DISTRIBUTION 13, Paragraphs I through 12 of this Complaint are incorporated herein by reference, 14. During their marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under Sections 3501 et.seq. of the Divorce Code of 1980. IS. Plaintiff and Defendant have been unable to amicably agree upon the equitable distribution of the marital property. WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter a decree for divorce; equitably distribute all marital property, both real and personal owned by the parties; and grant such other relief as this Court deems just and proper. COUNT III ALIMONY 16. Paragraphs I through IS are incorporated herein by reference. 17, Plaintiff lacks sufficient property to provide for her reasonable needs. 18. Plaintiff is unable to sufficiently support herself through appropriate employment. 19. Defendant has sufficient income and assets to provide continuing and indefinite support for the Plaintiff. WHEREFORE, Plaintiff requests this Honorable Court enter a decree for divorce and compel the Defendant to pay alimony to the Plaintiff; and grant such other relief as this Court deems just and proper. COUNT IV ALIMONY PENDENTE LITE. COUNSEL FEES. COSTS AND EXPENSES 20, Paragraphs I through 19 are incorporated herein by reference. 21. By reason of the institution of the action to the above term and number, Plaintiff will be and has been put to considerable expense in the preparation of her case, in the employment of counsel, and the payment of costs. 22. Plaintiff is without sufficient funds to support herself and to meet the costs and expenses of this litigation and is unable to appropriately maintain herself during pendency of this action. 23. Plaintiff's income is not sufficient to provide her reasonable needs to pay her attorney's fees and the costs of this litigation. 24. Defendant has adequate earnings to provide support for the Plaintiff and to pay her counsel fees, costs and expenses. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter a decree for divorce; compel the Defendant to pay alimony pendente lite as well as pay the Plaintiff's counsel fees, costs and expenses; and grant such other relief as this Court deems just and proper. Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER Date: 7/ /,;.-J o~ . da A. Clotfelter, Esquire orney ID No, 72963 021 East Trindle Road, Suite I Mechanicsburg, P A 17050 (717) 796-1930 telephone (717) 796-1933 facsimile Attorney for Plaintiff PAULA J. GEORGE, Plaintiff, vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. RANDY S. GEORGE, Defendant : CIVIL ACTION. LAW : IN DIVORCE VERIFICATION I, PAULA J, GEORGE, verify that the statements in the foregoing COMPLAINT IN DIVORCE are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S, g 4904, relating to unsworn falsification to authorities. Date: 7/1;)1 OS' I I ~~-~ )j~w-- PA J. GE GE, Plaint' ~ ~ '- ~ ~ ~ w .J.. ~ . ~~ \ t ~ ~ t ~ ~ ~ ~~ ~ ~~ ~ IS ~ \ ~ 'b ~ ' '\ . . ~~ n "" ~:; g C) -:"':.. c.n " . t= :2- I rnF1 " z; ;8EJ :~,~ (1.::;. ~ ~~i-;.:.~ ::j ~ ~h; PAULA J. GEORGE, Plaintiff, vs. RANDY S. GEORGE, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-3552 Civil : CIVIL ACTION - LAW : IN DIVORCE AFFIDAVIT OF SERVICE I, Linda A. Clotfelter, Esquire, counsel for Plaintiff, Paula J. George, do hereby affirm that set forth below is the original return receipt of the Comphlint for Divorce that was sent to Defendant by Certified Mail, Restricted Delivery, Return Receipt Requested, which appears to contain the signature of Defendant, Randy S. George, indicating that Defendant received same on July 22, 2005. The undersigned understands that the statements herein are made subject to the penalties of 18 P .S. ~4904 relating to unsworn falsification t.o authorities. . Complete Items I, 2, and 3, Also complete ~em 4 ff ResIrlcIed Delivery Is desired, . Print your name and address on the reverse 10 that Vie can return the card to you, . Attach this card to the back of the mailplece, or on the front ff space penn~s. 1. Article Addressed to: Randy S. George 835 Ridgewood Drive Mecbanicsburg, PA 17055 -- ::...~ a.type .. /- RegIs -C~/(~A:~ /or Merchendloo o Insured Mall ~~;:;;:' ~ 4. A.strlctedDelIvety1,atraFsoJ (d 7001 2510 0003 4439 8447 2. Article Num!>er (Transfer from service lat . 102S95-02.M.~. , PS Form 3811, February 2004 00mRt1o Ae<um_ Dated: 7/ A 1/ d) Respectfully subrrlitted, LAW OFFICE OF LINDA A. CLOTFELTER IoU Cl"~d~,G!f ttorney ID No. 72963 5021 East Trindle Road, Suite 100 Mechanicsburg, P'A 17050 (7 17) 796-1930 Attorney for Plaintiff (") ,.. c: C c: C. :,:,. L :::;:J .~, " , d-'I .- C :-,-i t.- ;;:;.- r , r-.' C/) 0: - ~~: , "'" ;~ ('-. :Jl ("~ j;.; c: .r- -'" ::~ -< co PAULA J. GEORGE, Plaintiff, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 05-3552 Civil RANDY S. GEORGE, Defendant : CIVIL ACTION - LAW : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this ;J 7""" day of ,M 1 ' 2005, the undersigned hereby certifies that a true and correct copy of the foregoing AFFIDAVIT OF SERVICE was served upon the opposing party by United States First Class Mail, postage prepaid: Randy S. George 835 Ridgewood Drive Mechanicsburg, P A 17055 Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER A. Clotfeltt:r, Esquire rney ID No. 72963 I East Trindle Road, Suite roo Mechanicsburg, P A 17050 (717) 796- I 930 tdephone (717) 796- I 933 facsimile Attorney for Plaintiff o <:;; ~~'." ~" ~','\ "" <J <- ,"" c ,- r--: a:. c:' C~ 2':- ~ -":: :>> ~ - SMIGEL, ANDERSON & SACKS, L.L.P. River Chase Office Center 4431 North Front Street, 3r<1 Floor Harrisburg, PA 17110-1778 (717) 234-2401 Richard C. Gaffney, Jr., MBA, Esquire rgnffw;:Y@$m:iUv-&PLU Attorneys for Defendant PAULA 1. GEORGE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. DOCKET NO. 05-3552 - Civil RANDY S. GEORGE Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO PLEAD To: Paula J. George c/o Linda A. Clotfelter, Esquire 5021 East Trindle Road Mechanicsburg, PAl 7050 YOU ARE HEREBY NOTIFIED TO FILE A WRITTEN RESPONSE TO THE ENCLOSED ANSWER AND COUNTERCLAIM TO COMPLAINT IN DIVORCE WITHIN TWENTY (20) DAYS FROM SERVICE HEREOF OR A JUDGMENT MAY BE ENTERED AGAINST YOU. Date: ~ ("IS'. 2~ /- ~ By: \ 2 d uj I:: Qt._ Richard C. Gaffney, Jr, , Esquire SMIGEL, ANDERSON & SACKS, L.L.P, River Chase Office Center 4431 North Front Street, 3rd Floor Harrisburg, PA 17110.1778 (717) 234-2401 Richard C. Gaffney, Jr., MBA, Esquire r,g~.fftl.~.Y@:m;;JJn-,",,-Q!n Attorneys for Defendant PAULAJ. GEORGE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. DOCKET NO. 05-3552 - Civil RANDY S. GEORGE Defendant CIVIL ACTION - LAW IN DNORCE 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 action. You are warned that, if you fail to do so, the case may proceed without you and a decree of divorce or annulment 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 Defendant. 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, One Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PAl 70 13 1-800-990-9108 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990, For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the Court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing of business before the Court. SMIGEL, ANDERSON & SACKS, L.L.P. River Chase Office Center 4431 North Front Street, 3n1 Floor Harrisburg,PA 17110.1778 (717) 234.2401 Richard C. Gaffney, Jr., !\lBA, Esquire _r:g~,,-ml~y((.&,~g~.nr.L~Dm Attorneys for Defendant PAULA J. GEORGE, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. DOCKET NO. 05-3552 - Civil RANDY S. GEORGE Defendant CIVIL ACTION - LAW IN DIVORCE ANSWER AND COUNTERCLAIM TO COMPLAINT IN DIVORCE AND NOW, comes Defendant, RANDY S. GEORGE, (hereinafter referred to as "Defendant"), by and through his counsel, Richard C. GaffiIey, Jr. and Smigel, Anderson, & Sacks, L.L.P., and answers Plaintiff's Complaint in Divorce as follows: 1. Admitted in part. Denied in part. It is admitted that Plaintiff is Paula J. George. It is denied that Plaintiff resides as set forth in the Complaint. To the contrary, Plaintiff resides at 439 Virginia Road, Mechanicsburg, P A 17050. 2. Admitted. 3. Admitted. COUNT I REOUEST FOR DIVORCE 4. Defendant hereby repeats and realleges his answers to the averments of Paragraphs I through 3, which are incorporated by reference herein. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted. 9. Admitted. 10, Admitted in part. Denied in part. Defendant admits that the marriage is irretrievably broken. Defendant denies any implication that a Divorce Decree should be entered on grounds set forth in Section 330I(c) of the Divorce Code. To the contrary and as more fully set forth below in Defendant's New Matter, a Divorce Decree should be granted to Defendant under Section 3301(a) of the Divorce Code on account of Plaintiff's adultery and indignities toward him. I I. Denied. Defendant denies that Plaintiff is the injured and innocent spouse. Defendant further denies that Plaintiff suffered indignities due to Defendant's conduct. Defendant further denies that he made Plaintiff's life intolerable and burdensome and Defendant demands that Plaintiff produce strict proof, if relevant and admissible, at the time of trial. By way of further answer, Defendant avers that he is the injured and innocent spouse and has suffered indignities due to Plaintiffs conduct that has made Defendant's life intolerable and burdensome. 12. Denied. Denied for want of knowledge whether Plaintiff was so advised or whether Plaintiff does or does not desire counseling. COUNT II EOUlTABLE DISTRIBUTION ]3, Defendant hereby repeats and realleges his answers to the averments of Paragraphs I through 12, which are incorporated by reference herein. 14. Admitted. 15. Admitted. WHEREFORE, Defendant requests this Court to equitably distribute the marital property after an inventory and appraisement has been filed by the parties. COUNT III ALIMONY 16. Defendant hereby repeats and realleges his answers to the averments of Paragraphs I through 15, which are incorporated by reference herein. 17. Denied. Defendant specifically denies that Plaintiff lacks sufficient property to provide for her reasonable needs and Defendant demands that Plaintiff produce strict proofthereof, if relevant and admissible, at the time of trial. 18. Denied. Defendant specifically denies that Plaintiff is unable to sufficiently support herself through appropriate employment and Defendant demands that Plaintiff produce strict proof thereof, if relevant and admissible, at the time of trial. 19. Denied. Defendant specifically denies that he has sufficient income and assets to provide continuing and indefinite support for the Plaintiff and Defendant demands that Plaintiff produce strict proof thereof, if relevant and admissible, at the time of trial. WHEREFORE, Defendant requests this Honorable Court deny Plaintiff's request for alimony. COUNT IV ALIMONY PENDENTE LITE. COUNSEL FEES. COSTS AND EXPENSES 20. Defendant hereby repeats and realleges his answers to the averments of Paragraphs I through 19, which are incorporated by reference herein. 2 I. Denied. Defendant specifically denies that Plaintiff has been put to considerable expense in preparation of her case, in the employment of counsel, and the payment of costs. Defendant demands that Plaintiff produce strict proof thereof, if relevant and admissible, at the time of trial. 22. Denied. Defendant specifically denies that Plaintiff is without sufficient funds to support herself and to meet the costs of expenses of this litigation. Defendant further denies that Plaintiff is unable to appropriately maintain herself during pendency of this action and Defendant demands that Plaintiff produce strict proof thereof, if relevant and admissible, at the time of trial. 23. Denied. Defendant specifically denies that Plaintitrs income is not sufficient to provide her reasonable needs to pay her attorney's fees and the costs of this litigation and Defendant demands that Plaintiff produce strict proof thereof, if relevant and admissible, at the time oftrial. 24. Denied. Defendant specifically denies that he has adequate earnings to provide support for the Plaintiff and to pay her counsel fees, costs and expenses and Defendant demands that Plaintiff produce strict proof thereof, if relevant and admissible, at the time of trial. To the contrary, Defendant is the sole support for the parties' four (4) minor children, who the Plaintiff abandoned in order to reside with her paramour. WHEREFORE, Defendant respectfully requests that this Honorable Court deny Plaintiffs request for alimony pendente lite, counsel fees, costs and expenses. COUNTERCLAIM COUNT V ABANDONMENT 25. Defendant hereby repeats and realleges his answers to the averments of Paragraphs I through 24, which are incorporated by reference herein. 26. Plaintiff abandoned the marriage. WHEREFORE, Defendant respectfully requests that this Honorable Court grant a divorce to him under g330I(a) of the Divorce Code. COUNT VI ADULTERY 27. Defendant hereby repeats and realleges his answers to the averments of Paragraphs 1 through 26, which are incorporated by reference herein, 28. Plaintiff has committed adultery. WHEREFORE, Defendant respectfully requests that this Honorable Court grant a divorce to him under s3301(a) of the Divorce Code. COUNT VII INDIGNITIES 29. Defendant hereby repeats and realleges his answers to the averments of Paragraphs 1 through 28, which are incorporated by reference herein. 30. Plaintiff subjected Defendant, as the injured and innocent spouse, to such indignities due to Plaintiff's conduct as to make Defendant's life intolerable and burdensome. 31. By her sworn testimony of August 5, 2005 at a hearing in a related custody matter pending at Cumberland County Docket No, 05-3620, Plaintiff is estopped from denying the averments herein. WHEREFORE, Defendant respectfully requests that this Honorable Court grant a divorce to him under s330I(a) of the Divorce Code. COUNT VIII COSTS. FEES AND EXPENSES 32. Defendant hereby repeats and realleges his answers to the averments of Paragraphs 1 through 31, which are incorporated by reference herein. 33. Defendant is without sufficient income to maintain himself and the parties' four (4) minor children and also meet the costs and expenses of this litigation. 34. Defendant has been put to considerable expense in the preparation of his case, in the employment of counsel and for the payment of costs. 35. Plaintiff has adequate earning potential to pay for the Defendant's counsel fees, costs and expenses. WHEREFORE, Defendant respectfully requests that this Honorable Court grant him a Decree in Divorce under Section 330I(a) of the Divorce Code, compel the Plaintiff to pay for Defendant's fees, costs and expenses, and grant such other and further relief as this Court deems just and proper. Respectfully Submitted, SMIGEL, ANDERSON, & SACKS, LLP Date: ~NC \ S- 2eer- . By: Richard C. Gaffhey, Jr., LD. #63313 River Chase Office Center 443 I North Front Street Harrisburg, PAl 7 I 10 Attorneys for Defendant 08/09/2005 12:41 71 75051905 NAVICP PAGE 02/02 VERIFICATION I, Randy S. George, verify th.at the statements contained in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that false statements therein are made subject to the penalties of 18 PaC.s.A ~4904, relating to unsworn falsification to authorities. Date: tJ ~O ;(a'J$' ~~ SMIGEL. ANDERSON & SACKS, L.L.P, River Chase Office Center 4431 North Front Street, 3rd Floor Harrisburg, PAl 711 0-1778 (717) 234.2401 Richard C. Gaffney, Jr., MBA. Esquire rgg.ffm:y_@~:_tl_'l~JJP'.,S,I).!.l1 Attomeys for Defendant PAULAJ. GEORGE, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff, v. DOCKET NO. 05-3552 - Civil RANDY S. GEORGE Defendant CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, Jennifer 1. Deitch, Legal Assistant to counsel for Defendant, in the above-captioned matter, do hereby certify that I served a true and correct copy of Defendant's Answer and Counterclaim to Complaint in Divorce on counsel for the Plaintiff by depositing the same in the U.S. Mail, on August 15, 2005, with postage prepaid for first class mail, addressed as follows: Linda A. Clotfelter, Esquire 502 I East Trindle Road, Suite 100 Mechanicsburg, P A 17050 SMIGEL, ANDERSON, & SACKS, LLP . m-tdv (") r:~ ~, <":~::,' (:.:~~ ,J' ~.. C: Go') -.J ~ ...... :1:., fl'F -am 'De;::> -~) .... ~~lSJI -:'::-1-1 (")(~") --7' rr' :5 ;~ "'0 '-< -r" _...~ C'"J r-...J - , . , .. v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-3552 CIVIL PAULA J, GEORGE, PLAINTIFF RANDY S. GEORGE, DEFENDANT : CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT L A Complaint in Divorce under ~330I(c) of the Divorce Code was filed on July 13, 2005. 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 intention to request entry of the decree. 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: '61 J41rJn Q~~~ Paula J. George, Plaintif't" ~ 2 ~ -0 e;, , !'111: ~f~' 0,-: ~ };(:'- .",..' ( >c z -" -< ....., = = """' r;:: C:;-J N OJ o -n ~,:n rt,- -urn ......,0 _.'~ l ~:~~.;: ,._4\ <:>0 ;~~: en 9 ?Q '-< '"Q :lI' t:'? CJ o /AVUsmm//July 28, 20061:31 PM ,. , , ... r PAULA J, GEORGE, PLAINTIFF v, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-3552 CIVIL RANDY S. GEORGE, DEFENDANT : CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER li330Hc) OF THE DIVORCE CODE I. I consent to the entry of a fmal 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 this 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: BIIl.J lo~ G; IJL.@nJ~~ PaulaJ. George, PI . tiff 0 . ... .. , o c s~ ~(Jl roC ~:,~,- 03'- ~(~:- =\...1 yC ~ ..... ,...., ~ d" :>>" c:: G"> N cs:> Q. ~~ ...,,~ :DI o "1") ~".. ~.(-, /::;:C ZO 6(<" "-I T-- ~ -0 ::r.: r:-? c::> c::> --~ . , ~ . PAULAJ, GEORGE, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v, : NO. 05-3552 CIVIL RANDY S, GEORGE, DEFENDANT : CIVIL ACTION - DIVORCE AFFIDAVIT OF CONSENT L A Complaint in Divorce under ~330I(c) of the Divorce Code was filed on July 13, 2005, 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 intention to request entry of the decree, 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: If}.. Au&} (}oOr, v RmdY~'~ ......... . g z -at'}'; fllr;" ~.'" .... ,,-.- .. -;"" <:0:; -<....:' r::::r "'" ~!i"'J J:>C: ?i I i I NO g "" "'" c::. G} N Q:) (;fi ~:!l n'r:: --orn :nQ ~3c~ ~.""-r, ~~l5 -~ -7() cyn -, ?ii ;.c; -u :z r:-? o I A VUsmrn/1 August 22, 2006 9:23 AM r . . PAULAJ. GEORGE, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, : NO. 05-3552 CIVIL RANDY S. GEORGE, DEFENDANT : CIVIL ACTION - DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER ~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 I do not claim them before a divorce is granted. 3, I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the Prothonotary, I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 94904 relating to unsworn falsification to authorities, Date: ()J Aj ;)~O(/ g -; ",. -PC" '11(':"" ~'i~~ -" -- r:.::.C ~~~. z. ~ ... ~ = "'" "" ",. c:: '" N 0:> ~ ..... ::C::n r;,::\T. ""'6 0- ~j...:(, ;)")~ ".0 6rn "'" 55 :..:: -,;) ::EO r:-? o ,. v, : IN THE COuRT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-3552 CIVIL PAULA 1. GEORGE, PLAINTIFF RANDY S, GEORGE, DEFENDANT : CIVIL ACTION - DIVORCE AND NOW, this STIPULATION (}.l- day of )~ , 2006, the parties and counsel for the parties in the above referenced action hereby stipulate and agree that the Order attached hereto may be adopted as a Court Order. Li da A. Clotfelter, Esq, 7.\ 'I /,,, 1 East Trindle Road, Ste, 100 Mechanicsburg, P A 17050 (717) 796-1930 Attorney for Plaintiff SMlG'L,i:::~I'SON & SACKS, LLF By: ~~U?!::J Ann Levin, Esquire ill #70259 443 I North Front Street, 3'" Fir. Harrisburg, PA 17110-1778 (717) 234-2401 Attorneys for Defendant ~~~-- PA ..AJ.GEOR E ~Gi;X ~ (1 c. ~ .-0 n-~ l"\'iC'_ "'""',. 7;: (l"L. r;~C" ~~\':~. -;2: -j "- ~ ~ ~ G'"> r-:> 0::> -0 --". --'.'># q, ~C!1 -o\-G _.,...,n (S"b ~>::1) 1() c._ '" o -"~ 1:> :;.<. r:-? o N .! . , 8390.1-4/MSNA VL, If 7/28/2006 1:10 PM MARITAL SETTLEMENT AGREEMENT 8390-I-4IMSNAV[;;'lf 7/2812006 1:10PM ./ . , MARITAL SETTLEMENT AGREEMENT This MARITAL SETTLEMENT AGREEMENT (this "Agreement") is made effective at Mechanicsburg, Pennsylvania this m rP' day of cAu 8 U LJ f , 2006 by and between: RANDY S. GEORGE, who resides at 835 Ridgewood Drive, Mechanicsburg, Cumberland County, Pennsylvania (hereinafter "Husband"), AND PAULA J. GEORGE, who resides at 439 Virginia Road, Mechanicsburg, Cumberland County, Pennsylvania (hereinafter "Wife"), WITNESSETH WHEREAS, Husband and Wife (collectively, the "Parties") were lawfully married to each other in Carlisle, Cumberland County, Pennsylvania on October 26, 1985; and WHEREAS, there are four (4) children of the marriage, being: Aletha A. George, Chelsea M, George, Joshua J, George and Benjamin L. George; and WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between Wife and Husband and it is the intention of the Parties to live separate and apart for the rest of their natural lives; and WHEREAS, Husband and Wife desire to settle fully and finally their respective financial and property rights and obligations including, without limitation by specification: settling of all matters between them relating to the ownership and equitable distribution ofreaI and personal property; settling of all matters between them relating to the past, present and future support, r . , alimony and/or maintenance of Wife by Husband or of Husband by Wife; and in general, the settling of any and all claims and possible claims by one Party against the other or against the other Party's respective estate, NOW, THEREFORE, in consideration of the foregoing premises and the mutual promises, covenants and undertakings hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged, and intending to be legally bound hereby, Wife and Husband, do promise, covenant and agree as follows: 1. Intention with Respect to a Divorce, The Parties acknowledge that, on July 13, 2005, Wife filed an action in divorce in the Court of Common Pleas of Cumberland County, Pennsylvania toDocket No, 05-3552. The Parties intend to secure a mutual consent, no-fault divorce pursuant to the provisions of Section 330l(c) of Pennsylvania's Divorce Code of 1980, as amended (the ''Divorce Code"), The Parties agree that they will each sign, simultaneously with the signing of this Agreement, an Affidavit of Consent to Divorce under Section 330l(c) of the Divorce Code and a Waiver of Notice of Intention to Request Entry of a Divorce Decree under Section 3301(c), and all other documents necessary to secure a divorce under that section, Husband's attorney will file a Praecipe to Transmit the Record and obtain a Decree in Divorce, The Parties understand and agree, however, that the execution and delivery of this Agreement is not predicated upon the commencement or maintenance of a divorce action. 2. Effect of Divorce Decree and Effect of No Divorce Decree. This Agreement shall continue to be effective after the entry of a final Decree in Divorce between the Parties and, except as otherwise provided for in this Agreement, this Agreement shall remain in full force and effect, even if no final Decree in Divorce is entered. Page 2 , 3. Incorporation into Divorce Decree, The Parties intend that this Agreement will be incorporated into, but not be merged with, a Divorce Decree that may be entered by any court of competent jurisdiction, The Parties intend further that the Court of Common Pleas entering the Divorce Decree shall retain continuing jurisdiction over the Parties and over the subject matter of the Agreement for the purposes of interpretation and enforcement of any of its provlSlons. 4. Date of Execution, The date of execution of this Agreement shall be the date on which the second of the Parties signs this Agreement (the "Execution Date"). 5. Effective Date of Agreement This Agreement shall become effective and binding upon both Parties on the Execution Date (the "Effective Date"), 6. Advice of Counsel; Voluntary Agreement Husband acknowledges that he fully understands each provision of this Agreement and its legal effect Wife acknowledges that she fully understands each provision of this Agreement and its legal effect. The Parties acknowledge and understand that each Party has the right to be represented by independent counsel of his or her own choice. Husband is represented by Smigel, Anderson & Sacks, LLP, Wife is represented by Linda Clotfelter, Esquire. Each Party acknowledges that he or she has received independent legal advice from counsel of his or her selection or that he or she has waived the right to receive independent legal advice from counsel of his or her own selection and that, in any case he or she has been fully informed as to his or her legal rights and obligations arising out of the Parties' marriage and impending divorce, including all rights available to him or her under the Divorce Code. Each Party confirms that he or she has read this Agreement in its entirety and fully understands the terms, conditions and provisions of this Agreement and believes them to be fair and reasonable under the circumstances. Each Party further confirms that he or she is Page 3 , entering into this Agreement freely and voluntarily and that the execution of this Agreement is not the result of any fraud, duress, undue influence, collusion, or improper or illegal agreement or agreements. 7. Personal Rights, Each Party shall be free from any direct or indirect interference by the other in his or her personal and business activities, as of the date of execution of this Agreement. Except as is otherwise set forth in this Agreement, each Party may reside wherever and with whomever he or she desires, The Parties shall not interfere with, harass, or malign each other or the respective families, friends, colleagues, employers or employees of each other. Except as is otherwise set forth in this Agreement, neither Party shall enter the residence of the other Party without the express pennission of the other Party, 8. Warranty of Disclosure. Husband and Wife represent and warrant that they have fully disclosed to each other their respective assets, liabilities and income. The Parties acknowledge that they have been given ample opportunity to identify, analyze and value the assets titled in the name of or held for the benefit of the other Party. The Parties acknowledge that no formal appraisals have been conducted, and that, but for this Agreement, they would be entitled to formal discovery including review of documents, inspections, interrogatories, depositions, formal valuations and appraisals, or otherwise. Notwithstanding the foregoing, the Parties agree that they are satisfied with the extent of the disclosure in this matter, and both Parties specifically waive any further disclosure or formal discovery, 9. Property Distribution. (a) Senarate property. All property that was acquired separately by either of the Parties prior to the marriage or after separation shall remain the separate property of Page 4 r that Party and all property that was acquired by gift or inheritance shall remain the separate property of the Party who received the property by gift or inheritance. (b) Marital propertv. Husband and Wife acknowledge that, during the term of their marriage, they acquired property that constitutes "marital property," as that term is used and defined in the Divorce Code. Husband and Wife hereby acknowledge and agree that any and all property, real or personal, tangible or intangible, contingent, disputed or unliquidated, without limitation by specification herein, owned or acquired by both or either of them during their marriage or that otherwise qualifies as marital property shall be equitably divided between them as provided in this Agreement. Each Party shall keep and retain as his or her separate property all such equitably divided marital property as provided in this Agreement. (c) Waiver of interest in seoarate propertv. Husband and Wife hereby specifically release and waive any and all right, title, interest or claim that he or she has, had, may have, might have had, or might now or hereafter have as to the whole or any part of property of the other that is separate property or that is marital property that is or will be distributed to him or her pursuant to this Agreement and, with respect to such property, each Party agrees to indemnify and hold harmless the other Party from and against any liability, cost or expense relating thereto or connected therewith from and after the Effective Date. (d) Specification oforooertv distributed. Husband and Wife hereby agree that the marital property shall be distributed to the Party and in the marmer set forth below. Husband and Wife acknowledge that the within specification does not constitute a complete list of martial property distributed between them, but the Parties acknowledge Page 5 and agree that, under all of the surrounding facts and circumstances, including but not limited to those facts and circumstances memorialized in this Agreement, and after giving due respect to the independent advice of their respective legal counsel, they have equitably divided all of the marital property and not only the property listed herein. (i) Real Property. Husband and Wife hold legal title as tenants by the entireties to a certain parcel of real property located at 835 Ridgewood Drive, Mechanicsburg, Pennsylvania 17050 with improvements thereon, (the "Real Property"), which has a fair market value of$185,900.00 and that is subject to a mortgage and other liens of record in the approximate amount of$127,285.00. I. Husband and Wife agree that the Real Property shall be distributed to Husband, to have and to hold forever, in his sole name and as his separate property. 2. Wife shall execute a Warranty Deed in the form attached hereto as Exhibit "A"contemporaneously with Wife's delivery of a signed original of this Agreement. Wife's Warranty Deed shall bargain, sell, transfer, convey and set aside to Husband all of Wife's right, title and interest in and to the Real Property, and Wife's Warranty Deed shall forever waive, relinquish, and quit claim to Husband any and all legal, equitable and other right, title and interest that Wife has, had, may have had, or might have had in the Real Property. 3. Husband's attomey shall hold Wife's Warranty Deed in escrow, but shall not record Wife's Warranty Deed or Page 6 deliver Wife's Warranty Deed to Husband until Wife is released from any and all liability for the current joint mortgage and promissory note secured by the Real Property. 4. On or before the one hundred twentieth (120'h) day following the Effective Date, Husband shall use his best efforts to formally assume, refinance or otherwise satisfy or remove Wife's name from the mortgage and promissory note that is secured by the Real Property, such that Wife is released from any and all liability for same. Husband shall be solely responsible for any and all costs associated with his assumption or refinance of the joint mortgage and promissory note secured by the Real Property pursuant to this Agreement. Upon request, Husband shall produce to Wife written proof of his application for refmance or formal assumption of the mortgage and promissory note. 5. It is acknowledged by the parties that Husband has had exclusive use and possession of the Real Property and it is agreed that Husband shall be solely responsible for all expenses related to his exclusive use and possession of the Real Property, including, but not limited to, the Mortgage, real estate taxes, insurance, utilities and the like, and Husband shall hold Wife harmless from same. It is further agreed that all household utility accounts not in Husband's name alone shall be transferred to Husband's name alone within ten (10) days of the execution of this Page 7 Agreement. Wife agrees that as of the date of execution of this Agreement, any and all title policies and any other policies of insurance with respect to the Marital Home shall be endorsed to reflect Husband as the sole owner thereof and further agrees that Husband shall be entitled to receive any payments now or hereafter due under such insurance policies. (ii) Personal Property. Except as specifically provided in this Agreement, Husband shall keep and retain as his sole and separate property all of the furniture, fixtures, household contents and personal property contained within or located on the Real Property as of the date of the Effective Date. Wife hereby conveys, transfers, and delivers to Husband all of her right, title and interest in and to the said furniture, fixtures, household contents and personal property. Wife hereby forever waives, relinquishes and quit claims to Husband any and all of her right, title and interest that she has, had, may have, may have had, might have had, or might now or hereafter have in the said furniture, fixtures, household contents and personal property. This Agreement shall be sufficient evidence of said transfer and may act as a Bill of Sale. (iii) Motor Vehicles. The Parties own certain motor vehicles that are marital property. The Parties agree to distribute the vehicles as follows: 1. Wife shall retain for her own use and disposition, the 1992 Geo Prism currently titled in Wife's name. 2. Husband shall retain for his own use and disposition the 1994 Toyota Pickup currently titled in Husband's name. Page 8 3. Husband shall retain for his own use and disposition the 1997 Grand Voyager Plymouth currently titled Husband's name. (iv) Liability to Follow Title. Except as otherwise provided in this Agreement, from and after the Effective Date, the Party having title to a motor vehicle shall be solely responsible for all liabilities, fees, costs and expenses connected with, associated with or relating to that motor vehicle, including, without limiting the generality ofthe foregoing: all loan payments, payments of principal and interest, late payment fees, finance charges and the like; all registration costs, inspection costs, repair costs, maintenance costs, operating expenses, licenses and fees; all sales taxes, transfer taxes, use taxes, and all other taxes, levies, fees or fmes; all insurance costs, insurance deductible payments and co-payments; and all other liabilities, fees, costs and expenses, whether covered or not by any policy of liability insurance. Each Party represents to the other Party that, to the best of his or herknowledge, there are no outstanding liabilities relating to any of the automobiles existing as of the date of execution of this Agreement. Except to the extent that the foregoing representation is false, the Party having title to a motor vehicle shall be solely liable for and shall indemnify, defend and hold harmless the other Party of and from any and all past, present or future liability associated with or relating to that motor vehicle, including reasonable counsel fees and increased insurance premiums due to any ofthe expenses set forth in the preceding sentence. Page 9 lfthe Party having title to a motor vehicle as of the Effective Date (the "PartY of the First Part") incurs any increase in insurance premium costs as a result of any accident or claim in which the other Party (the "Partv of the Second Part") was involved, the Party of the Second Part shall be solely liable for and shall indemnify, defend and hold harmless the Party of the First Part of and from any and all such increases in the insurance premium costs of the Party of the First Part. (v) Retirement Benefits and Savings. The Parties intend to equitably divide the marital estate, in part, by mutually releasing and waiving any interest that one Party has, may have or might have to retirement or savings benefits held by the other Party. 1. Husband's Transfer, Release and Waiver to Wife. Husband hereby irrevocably and unconditionally transfers, bargains, sells and assigns to Wife, all right, title, estate, claim and interest (collectively, "Interest"), both legal and equitable, known and unknown, foreseen and unforeseen, matured and not matured, fixed and contingent, vested and non-vested, alienable and non- alienable, that Husband has, had, may have, might have, may have had, might have had, or might now or hereafter have in and to any and any and all savings, plans, funds, accounts, investments, income, entitlements and benefits (collectively, "Benefits") accrued or accruing to Wife's account, irrespective of how any such Benefit is, was, has been, had been, will be or might be held, Page 10 registered, named or titled, and irrespective of whether any such Benefit arises on account of or pursuant to any employment relationship, group plan, collective bargaining agreement, club or organization membership, or any federal, state or local, executive, legislative, regulatory, military, administrative, judicial or quasi- judicial law, rule, regulation, treaty, constitution, statute, ordinance, order, decree, policy, practice or procedure, and irrespective of whether any such Benefit is dependent upon or related to age, health, position, income, contribution, tenure or vesting, and irrespective of how any such Benefit is established, funded or maintained, which Benefit is in the nature of a retirement benefit, pension benefit, social security insurance benefit, social security disability benefit, savings account, plan qualified under section 401(k) of the Internal Revenue Code ("Code") or under any other past, present or future section of the Code, including, but not limited to any qualified Individual Retirement Savings Account ("IRA"), Thrift Savings Plan ("TSP"), including a TSP qualified under 5 V.S.C. SS 8435(c) and 8467 and 5 C.F.R. part 1653, subpart A, Health Savings Account ("HSA"), Medical Savings Account ("MSA") and Flexible Spending Account ("FSA"), and any non-qualified savings plan or other Benefit of a similar or different nature. Husband hereby irrevocably and unconditionally releases and waives any and all Interest in Wife's Benefits and Page 11 shall, from time to time, upon reasonable demand by Wife for same, execute and deliver to Wife any and all documents needed to effectuate the intent of this provision. 2. Wife '5 Transfer, Release and Waiver to Husband. Wife hereby irrevocably and unconditionally transfers, bargains, sells and assigns to Husband, all right, title, estate, claim and interest (collectively, "Interest"), both legal and equitable, known and unknown, foreseen and unforeseen, matured and not matured, fixed and contingent, vested and non-vested, alienable and non- alienable, that Wife has, had, may have, might have, may have had, might have had, or might now or hereafter have in and to any and any and all savings, plans, funds, accounts, investments, income, entitlements and benefits (collectively, "Benefits") accrued or accruing to Husband's account, irrespective of how any such Benefit is, was, has been, bad been, will be or might be held, registered, named or titled, and irrespective of whether any such Benefit arises on account of or pursuant to any employment relationship, group plan, collective bargaining agreement, club or organization membership, or any federal, state or local, executive, legislative, regulatory, military, administrative, judicial or quasi- judicial law, rule, regulation, treaty, constitution, statute, ordinance, order, decree, policy, practice or procedure, and irrespective of whether any such Benefit is dependent upon or Page 12 related to age, health, position, income, contribution, tenure or vesting, and irrespective of how any such Benefit is established, funded or maintained, which Benefit is in the nature of a retirement benefit, pension benefit, social security insurance benefit, social security disability benefit, savings account, plan qualified under section 401(k) of the Internal Revenue Code ("Code") or under any other past, present or future section of the Code, including, but not limited to any qualified Individual Retirement Savings Account ("IRA"), Thrift Savings Plan ("TSP"), including a TSP qualified under 5 D.S.C. SS 8435(c) and 8467 and 5 C.F.R. part 1653, subpart A, Health Savings Account ("HSA"), Medical Savings Account ("MSA") and Flexible Spending Account ("FSA"), and any non-qualified savings plan or other Benefit of a similar or different nature. Wife does hereby irrevocably and unconditionally release and waive any and all Interest in Husband's Benefits and Wife shall, from time to time, upon reasonable demand by Husband for same, execute and deliver to Husband any and all documents needed to effectuate the intent of this provision. 3. Domestic Relations Order. The sum of Fifty-seven Thousand One Hundred Twenty-one Dollars ($57,121.00) shall be paid to Wife from Husband's Thrift Savings Plan. In order to accomplish this transfer, the parties shall sign the Stipulation Page 13 attached hereto as Exhibit B which requests that the Court enter the attached Retirements Benefit Court Order as an Order of Court, also included as part of Exhibit B. Tbe Stipulation and proposed Order will be forwarded to the Court for signature simultaneously with the Praecipe to Transmit tbe Record. Once the Order is signed, it will be forwarded to the Thrift Savings Plan Processing Dnit for implementation as soon as administratively possible. 4. Alienation; Cooperation; Tender. To the fullest extent permitted by law, either Party may alienate any Interest in a Benefit accruing to his or her account, including, without limiting the generality of the foregoing, by way of loan, withdrawal, liquidation, hypothecation, assignment or transfer, free and clear of interference or objection from the other Party. (vi) Bank Accounts. Husband and Wife jointly own or owned cbecking and/or savings account at Citizens Bank and at Members 1st Bank, which, as of May 22, 2005 had the following balances: Combined Financial Account Account Balance as of Institution Ownership Number Account Type Status Mav 22, 2005 Citizens Bank Joint 620422-281-7 Checking OPEN $3,450.50 Members 1 st Joint 73081 Checking/Savings CLOSED $3,062.59 Members 1st Joint 73278 Checking/Savings CLOSED $2,375.55 Members 1 st Joint 163547 Savings OPEN $1,867.40 Page 14 " The Members 1st FCU accounts Numbered 73081 and 73278 sball be distributed to Husband. The Citizens Bank account No. 620422-281-7 shall be distributed to Husband. Wife acknowledges already receiving the Members 151 FeD No. 163547. (vii) After-Acquired Property. Each Party shall hereafter own and enjoy, independently of any claim or right of the other, all property acquired by him or her after execution of this Agreement, with full power in him or her to dispose ofthe same as though he or she were unmarried. 10. Alimony/Support. (a) Release and Waiver of claims. Husband and Wife represent and acknowledge that each of them has sufficient property to provide for his or her reasonable needs and that they are able to support themselves through appropriate employment. Therefore, notwithstanding anything to the contrary contained in Pennsylvania law including, without limitation, the Divorce Code, Wife and Husband expressly release, remise and discharge the other Party from any and all obligations and duties owed by one Party to the other, and Wife and Husband expressly relinquish, extinguisb and waive any and all right( s) or claim( s) which she or he has, had, may have, might have had, or might now or hereafter have to alimony, alimony pendente lite, spousal support, maintenance, dower or curtesy and/or any other benefit or benefits of a like or similar nature that result from or arise out of any asserted need or from or as a result of the Parties' status as Husband and Wife or as former Husband and former Wife. (b) Effective Date of Release and Waiver. Husband and Wife agree that the release and waivers provided-for in the foregoing paragraph shall be effective on the date of execution of this Agreement. Page 15 /1' (c) Health Insurance and Medical Expenses. Husband maintains health and dental insurance through his employer, for Husband, Wife and the parties' children. Husband shall continue to maintain health and dental insurance for Wife at Husband's expense, if any, until the parties' Divorce Decree is entered. Thereafter Wife shall be solely responsible for Cibtaining health insurance coverage for herself at her own expense. Wife Shil'L be solely responsible for any co-pays and unreimbursed medical expenses that she incur~., whether incurred before or after the date of the Divorce Decree. 11. Debt. During t!)e term of the marriage and prior to the date of this Agreement, the Parties incurred certain debt in the form of a mortgage loan on the Real Property; the Parties incurred certain ether debt in joint names; Wife incurred certain debt in her sole name; Husband incurred certain debt in his sole name; and the Parties jointly incurred liability for payment of income taxes and other taxes. (a) Mortgage and Real Propertv Expenses. The parties agree that Husband shall be solely responsible for the pay-off of the mortgage, including the principal amount and any i lterest, finatlCe charges, penalties, fees and costs associated therewith, if there be any, ~l1ld Husband shall also be solely responsible for any and all other expenses associated with the Real Property including, but not limited to, the real estate taxes, insurance, utilities, and all costs associated with the refinance or sale of the Real Property. (b) Joint Debt. The Parties acknowledge that, during the marriage, Husband and Wife incurred debt in their joint names. Effective as of the date of separation of the parties, May 22, 2005, each party shall only use those credit accounts or incur such further obligations for which that party is individually and solely liable and the parties Page 16 shall cooperate in closing any remaining accounts which provide for joint liability, with the exception of the joint mortgage and promissory note secured by the Real Property which shall be satisfied as stated in paragraph 9( d)(i) and its subparts. Neither party shall make any further cbarges on any joint debt for which the other party may be responsible, and if said charges are made in violation of this Agreement, then the party incurring said charge sball immediately repay the same. Any liability not disclosed in this Agreement shall be the sole responsibility of the party who has incurred or may hereafter incur it, and the party incurring or having incurred said debt shall pay it as it becomes due and payable. (c) Wife's Debt. The Parties acknowledge that, during the marriage, Wife incurred certain debt in her sole name. The Parties hereby agree that Wife shall hereafter assume responsibility for payment of the entire principal amount and any interest, finance charges, penalties, fees and costs associated therewith on the debt that Wife incurred in her individual name. (d) Husband's Debt. The Parties acknowledge that, during the marriage, Husband incurred certain debt in bis sole name. The Parties agree that Husband shall hereafter assume responsibility for payment of the entire principal amount and any interest, finance charges, penalties, fees and costs associated therewith on the debt that Husband incurred in his individual name. (e) Tax Liabilitv. The parties have heretofore filed joint federal and state tax returns. Both parties agree that in the event any deficiency in federal, state or local income tax is proposed, or any assessment of any such tax is made against either of them, each will indemnify and hold harmless the other from and against any loss or liability for Page 17 breach, including, but not limited to, counsel fees and costs relating to such breach, whether or not litigation is instituted. 20. Integration. This Agreement constitutes the entire understanding of the Parties and supersedes any and all prior agreements and negotiations between them. There are no other oral or written agreements, promises, representations, terms, covenants, conditions, or warranties of any nature whatsoever, express or implied, other than those expressly set forth in this Agreement. 21. Severability. If any provision of this Agreement sball be finally determined by any court of competent jurisdiction to be invalid, then only that provision shall be stricken from this Agreement and in all other respects this Agreement shall be valid and shall continue in full force and effect. The failure of a Party to meet her or his obligations under any provision of this Agreement, with the exception of the satisfaction of the conditions precedent, sball in no way void or alter the remaining obligations of the Parties. 22. Agreement Binding on Heirs. The terms, provisions and conditions of this Agreement shall be binding upon any and shall inure to the benefit of the heirs, executors, administrators, successors or assigns of the respective Parties hereto, except as otherwise herein provided. 23. Death Prior to Divorce. This Agreement shall remain in full force and effect even if one of the Parties dies prior to the date of entry of a final Decree in Divorce. 24. Applicable Law. This Agreement shall be governed by and construed in accordance with the laws of the Commonwealth of Pennsylvania. Page 21 25. Headings Not Part of Agreement. Any headings preceding the text of any of the paragraphs or subparagraphs of this Agreement are inserted solely for convenience of reference, shall not constitute a part of this Agreement and shall not affect its interpretation. 26. Contract Interpretation. For purposes of contract interpretation and for the purpose of resolving any ambiguity in this Agreement, Husband and Wife agree that this Agreement was prepared by the joint efforts of the respective Parties. 27. Address of Parties. As long as any obligations remain to be performed under this Agreement, each Party shall have the affirmative obligation to keep the other Party informed of his or her residence and mailing address, and each Party shall promptly notify the other in writing of any change of residence or mailing address. 28. Connterparts. This Agreement may be executed in counterparts, each of which shall be an original and which together shall constitute one and the same instrument. IN WITNESS WHEREOF, the Parties have executed this Agreement the day and By: ~<. {j CMf W TNESS - ~cr- Page 22 '; . COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF .C1JMBERLAND On this, the~ day of ~ ' 2006, before me, a Notary Public in and for the aforesaid Commonwealth arid C ty, personally appeared RANDY S. GEORGE, known to me to be the person whose name is subscribed to tbe within Agreement and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. :n~ 9{)fld~ ~y Public COMMONWEALTH OF PENNSYLVANIA NcmiaI Seal Sara J. AndI8I. Notary Public ~rg. DauphinCounly ExpIres Jan. 8, 2008 Member, Pennsylvania ASSOCIation Of Notaries Page 23 COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND On this, the Nt'day of ~ I.<.Vt ,2006, before me, a Notary Public in and for tbe aforesaid Commonwealth and County, personally appeared PAULA J. GEORGE, known to me to be the person whose name is subscribed to the within Agreement and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. Page 24 Exhibit A WARRANTY DEED Page 25 " .. " 7/28/20063:18:47 PrtJAVUsmm Prepared By: Smigel, Anderson & Sacks, LLP 4431 North Front Street Harrisburg, P A 17110 Return To: Smigel, Anderson & Sacks, LLP 4431 North Front Street Harrisburg, PA 17110 ParcelId# : Property Address: 835 Ridgewood Drive, Mechanicsburg, P A 17050 TillS DEED MADE THE and six (2006) DAY OF in the year of our Lord two thousand BETWEEN RANDY S. GEORGE and PAULA J. GEORGE, of Cumberland County, Pennsylvania, hereinafter "Grantors" AND RANDY S. GEORGE, an adult individual, hereinafter "Grantee" ~ WITNESSETH, that in consideration of ONE DOLLAR ($1.00) and other good and valuation consideration, the receipt whereof is hereby acknowledged, the said Grantors do hereby grant and convey to the said Grantee, his heirs and assigns, in sole tenancy, ALL THAT CERTAIN lot or piece of ground with the improvements thereon erected situate in the Township of Hampden, County of Cumberland and Commonwealth of Pennsylvania, bounded and described in accordance with a Subdivision Plan of Laurel Hills, Section 16, made by Buchart-Horn, Consulting Engineers and Planners, Job No. 203020, and recorded in the Office of the Recorder of Deeds in and for Cumberland County, Pennsylvania, in Plan Book 13, Page 27, as follows, to wit: BEGINNING at a concrete monument set on the West side of Ridgewood Drive fifty (50) feet wide, a comer of Lot No. 231; thence extending from said beginning concrete monument and measured along tbe West side of Ridgewood Drive, Soutb eighteen (18) degrees twenty (20) minutes forty-five (45) seconds East, one hundred and no one-hundredths (100.00) feet to a stake, a corner of Lot No. 233; thence extending along said lot, South seventy-one (71) degrees thirty-nine (39) minutes fifteen (15) seconds West, one hundred and no one-hundredths (100.00) feet to a stake set in a line of Deimler Manor; thence extending along same, North eighteen (18) degrees twenty (20) minutes forty-five (45) seconds West, one hundred and no l . #'. 7/28/20063:18:47 PM/A VUsmrn one-hundredths (100.00) feet to a stake, a comer of Lot No. 231 aforesaid; thence extending along same, North seventy-one (71) degrees thirty-nine (39) minutes fifteen (15) seconds East, one hundred and no one-hundredths (100.00) feet to a concrete monument and the place of BEGINNING. BEING Lot No. 232 (as shown on said plan), house number 835 Ridgewood Drive. BEING the same premises which Edward J. Zimmer and Maureen Zimmer, husband and wife, by their deed dated February 20,2002 and recorded on February 21, 2002 in the Office for tbe Recorder of Deeds in and for Cumberland County, Pennsylvania, in Deed Book 250 at Page 2248, granted and conveyed unto Randy S. George and Paula J. George, husband and wife, Grantors herein. UNDER AND SUBJECT, NEVERmELESS, to all restrictions, reservations, conditions, covenants, easements and rights of way of prior record. The purpose of this Deed is to relinquish all right, title and interest in the property which Paula J. George may have pursuant to divorce proceedings between the parties hereto indexed to No. 05-3552 Civil filed in the Office of the Prothonotary of Cumberland County, Pennsylvania, which proceedings are still pending. THIS IS A CONVEYANCE BETWEEN HUSBAND AND WIFE TO HUSBAND AND IS THEREFORE EXEMPT FROM THE PAYMENT OF PENNSYV ANIA REALTY TRANSFER TAX. AND the said Grantors hereby covenant and agree that they will warrant specially the property hereby conveyed. IN WITNESS WHEREOF, said Grantors have hereunto set tbeir hands and seals the day and year first above written. SEALED AND DELIVERED IN THE PRESENCE OF: { seal} Randy S. George {seal} Paula J. George .1 .. IJ.., ... 7/28/20063:18:47 PM/A VUsmm COMMONWEALTH OF PENNSYLVANIA: ss. COUNTY OF On this, the day of , 2006, before me a Notary Public, in and for the Commonwealth of Pennsylvania, the undersigned officer personally appeared Randy S. George, known to me {or satisfactorily proven} to be the person whose name is subscribed to the within instrument and acknowledged that he executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. Notary Public My Commission Expires: . ...I. 7/28/20063:]8:47 Pl\.I/AVUsmm COMMONWEALTH OF PENNSYLVANIA: ss. COUNTY OF CUMBERLAND On this, the day of ,2006, before me a Notary Public, in and for the Commonwealth of Pennsylvania, the undersigned officer personally appeared Paula J. George, known to me {or satisfactorily proven} to be the person whose name is subscribed to the within instrument and acknowledged that she executed the same for the purposes therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. Notary Public My Commission Expires: I hereby certify that the precise residence and complete post office address of the within named Grantee is 835 Ridgewood Drive, Mechanicsburg, P A 17050. Attorney for Grantee Please Return To: Ann V. Levin, Esquire Smigel, Anderson & Sacks, LLP 4431 North Front St., 3rd FIr. Harrisburg, P A 17110-1709 '. ~ """. .. Exhibit B RETIREMENT BENEFITS COURT ORDER Page 26 .:'. ~, . PAULA J. GEORGE, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 05-3552 CIVIL RANDY S. GEORGE, DEFENDANT : CML ACTION - DIVORCE RETIREMENT BENEFITS COURT ORDER AND NOW this day of , 2006, based upon the findings set forth below, it is hereby Ordered and Decreed: 1. This Order applies to the Thrift Savings Plan for federal employees. 2. The Thrift Savings Plan Participant is Randy S. George. His current address is 835 Ridgewood Drive, Mechanicsburg, P A, 17055. His social security number is 183-52-4517 and his date ofbirtb is September 1, 1963. 3. Payee is Paula J. George, whose current address is 439 Virginia Road, Mechancisburg, P A, 17050. Her social security number is 195-62-8583 and her date of birth is February 22, 1967. 4. This Order assigns to the Payee an amount equal to $57,121.00 from the Participant's Thrift Savings Plan, Account # 183524517. 5. Payee shall be responsible for any tax consequences incurred as a result of the transfer required by this Order. 7. The parties are directed to timely submit all documents, including releases, which are required to finalize this Order. 8. This Order is entered pursuant to the authority granted in the applicable domestic relation laws of Pennsylvania. -. . Order. 9. This Court reserves jurisdiction to issue further orders as needed to execute this BY THE COURT: 1. 0Le,.1 . ".'~ v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-3552 CIVIL PAULAJ. GEORGE, PLAINTIFF RANDY S. GEORGE, DEFENDANT : CIVIL ACTION - DIVORCE STIPULATION AND NOW, this day of , 2006, the parties and counsel for the parties in tbe above referenced action hereby stipulate and agree that the Order attached hereto maybe adopted as a Court Order. SMIGEL, ANDERSON & SACKS, LLP By: - Linda A. Clotfelter, Esq. ill # 5021 East Trindle Road, Ste. 100 Mechanicsburg, PA 17050 (717) 796-1930 Attorney for Piaintiff Ann Levin, Esquire ID #70259 4431 North Front Street, 3'd Fir. Harrisburg, PA 17110-1778 (717) 234-2401 Attorneys for Defendant PAULAJ. GEe'RGE RANDY S. GEORGE o ~~: c,,'; \ \ ... .' . ... ~t" .-' f::~ C.7' , '..=J c: ~ ""- ::P~ c... G) 1',) OJ :q -".... ~ ~ --4 ::t"'1) n1f-:- -r:JC.:' ,;'U ~3!SJ~ -",'.m g ::t': ", '-< CJ - . v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-3552 CIVIL PAULAJ. GEORGE, PLAINTIFF RANDY S. GEORGE, DEFENDANT : CIVIL ACTION - 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 ~3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: The Complaint was served via certified mail on the Defendant on July 22,2005. A correct copy of the Affidavit of Service is attached hereto. 3. (a) Date of execution of the Affidavit of Consent required by g3301(c) of the Divorce Code: by Plaintiff on August 14, 2006; and by Defendant on August 22, 2006. (b) (1) Date of execution of the affidavit required by S3301(d) of the Divorce Code: NtA. (2) Date of filing and service of the Affidavit upon the respondent: Nt A. 4. Related claims pending: None. 5. Complete either (a) or (b). (a) Date and manner of service of the Notice of Intention to File Praecipe to Transmit Record, a copy of which is attached: N/A. (b) Date Plaintiff's Waiver of Notice in S3301(c) Divorce was filed with the Prothonotary: A copy is attached hereto and is being filed simultaneously with this Praecipe. (c) Date Defendant's Waiver of Notice in ~3301(c) Divorce was filed with the Prothonotary: A copy is attached hereto and is being filed simultaneously with this Praecipe. y -.L<{-OJ, DERSON & SACKS, LLP u6 Ann . Levin, Esquire LD.#: 70259 4431 North Front Street Harrisburg, P A 17110 (717) 234-2401 Attorney for Defendant Date: By: 08/08/2005 13:54 71 76051906 NAVICP PAGE 62/El3 '''--'''- ) PA~J.GEORGE. PImntiff, : IN THE COURT OF COMMON PLEAS OF ,. : CuMBERLAND COUNTY, PENNSYLVANIA VI. . . : NO. 05-3S52 Civil RANDY s. GEORGE, Defendant . : CIVIL ACTION - LAW : IN DIVORCE ~FDtA VlT OF SERVI~ 1, Linda A. Clotfelter, Esquire, COUDSCl for Plaintiff, Paula J. George, do hereby affhm that set forth below is the original xetum receipt of the Complaint for Divorce that was sent to Defendant by Certified Mail, Restricted Delivery, Return R.eceipt Requested. which appears to contain the signature of DefeMant, Randy S. Geotgc, indicating that Defendant received same on July 22, 2005. The UDdeJ:signed understands that the statements hmin are made subject to thepei1altiC$ of 18 P.S. 04904 rellori"sto ~m f'a.lsification.to:~borities. . CompIU ~ ,. t,..." s.. Alae> aampleta . 118m 4 II RIIllIc:lIcI o.llvl/Y I. dMIred. . Prlnl~n__Cd_onlhol_.... 00 lhIII... con ...,m tho oon:t to)'llU. . AttoolIlIU1I oltll to l!1e bOOk uf tho mollpl_. or on 1M '""" IIIp1M ponnlla. 1, MloraA<l._IO' .,......,~.. Randy S. George 835 Ridpwood Drive Meeblnicsburg, PA 17055 ..ta . ~~. i.h)~1 :... :...... a. ~. I --..- "' .Not E' Mall .' ....n AoooIpI far Molahondoo a_MIll C.OD. .. .....,..,d D111vory'l jI!lON FMI 2.A",..N""''' -- 7DlI]' 2510 0003 Ii'!"'! AIi"7 (1IIInoI'Ir-"'- . '" a, PS ~orm 3811, FobruIIY 2~ _II<>......._pI , '--.Il.\IOII'j R.espeetfu11y submitted, LAW OFFICE OP LINDA A. CLOTFELTER Dated: 7/ A 1/0'1 A. Clotfelter. squue ltOmey ID No. 72963 5021 East Tnlldlc Road, Suite 100 Mcchanicsbur8. PA 17050 (717) 796.1930 A.ttorney for Plaintift' PAGE 03/e13 0B/elB/2005 13:54 7176851986 NAVICP PAULA J. GEORGE, PlalDtiff, : IN THE COUllT or COMMON PLEAS OF : CUMBERLAl'm COUNTY, PENNSYLVANIA : vs. : NO. 05-3551 CivO RANDY S. GEOR.GE, Deleadaat . . : CIVIL ACTION - LAW :' IN DIVORCE gs,TlfICATEJ)F ~~ J...17 hereby certifies that a true and correct copy of the foregoing APFIDA vrr OF SERVICE was AND NOW, tbis 117"" day of - . 2005, the undersigned served upon the opposins party by Unill:d States First Class Mail, postage prepaid: Randy S. George 835 Ridgewood Drive Medlanicsburg, PA 17055 Respectfully submitted, LAW FIRM OF LINDA A. CLOTFELTER a A. Clotfelter, Esquire Att ID No. 72963 East Trindle Road. Suite 100 McE;banicsburg, PA 1.7050 (117) 796-1930 tdepboDe (117) 796-1933 tloc.oiruile A~rney for Plaintiff (") c: tBF' ><;-:0:-:';'" ~<. I~ (..01 ':c -.." ~~ 5~: ~~,~ ~ ....., = ,::::::> C1' :> c: Gel N OJ -0 ~ o -n -i ::C..,., nlp -om -'7' _J ,-) ::-;c) ~~~; (~)l n --l ?D -< I)i' o "-' . v. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 05-3552 CIVIL PAULA J. GEORGE, PLAINTIFF RANDY S. GEORGE, DEFENDANT : CIVIL ACTION - DIVORCE RETIREMENT BENEFITS COURT ORDER AND NOW this 3\.st day of 14 <> 0 '" SoL 2006, based upon the findings set fortb below, it is hereby Ordered and Decreed: 1. This Order applies to the Thrift Savings Plan for federal employees. 2. The Thrift Savings Plan Participant is Randy S. George. His current address is 835 Ridgewood Drive, Mechanicsburg, P A, 17055. His social security number is 183-52-4517 and his date ofbirtb is September 1, 1963. 3. Payee is Paula J. George, whose current address is 439 Virginia Road, Mechancisburg, P A, 17050. Her social security number is 195-62-8583 and her date ofbirtb is February 22, 1967. 4. This Order assigns to the Payee an amount equal to $57,121.00 from the Participant's Thrift Savings Plan, Account # 183524517. 5. Payee shall be responsible for any tax consequences incurred as a result of the transfer required by this Order. 7. The parties are directed to timely submit all documents, including releases, which are required to finalize this Order. 8. This Order is entered pursuant to the authority granted in the applicable domestic relation laws of Pennsylvania. -' ," ~ , 9. This Court reserves jurisdiction to issue further orders as needed to execute this Order. BY THE COURT: - J. . y. 'JQ/t../b ~ ~J \7\ \0''''.;'' .'\0),:.~~\<i' -13d 1'1\'<'<'; '''''<Y:,f'O ~\j :2 \~(\ L- dJS q~J7. )..ti1101:C1,i,jJcl ?r\i. :10 ,y)',J;:IQ-(:\Jil:1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. PlWIA J. Qnr.F. No. 05 - 3552 CIVIL TJRI VERSUS RAWY S. GI!IHiE DECREE IN DIVORCE AND NOW, ~~.;>s1 "Sl , 7oo~ IT IS ORDERED AND DECREED THAT Paula J. George. , PL.AINTIFF, AND Rarrly S. George , DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOL.L.OWING CL.AIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL. ORDER HAS NOT YET BEEN ENTERED;None. It is further ORDERED arrl DEX::REED that the Marital Settlerrent Acu:eerrent executed by arrl between the parties, dated August 22, 2006, is incorporated py reference into this ~ for the plI!pOses of enforcement, but shall NO!' be ~ tn h""", hoAn with thif' flP<-n><> J. ATT ~ fr' t /fr":" ~)t., 19. d ~ pP ~ ~k,,;;f"7 ',(J' LIJ '. . 0,.. . . . ~, \, > . ,. t .}' )