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HomeMy WebLinkAbout06-2243ADRIENNE J. BOYER, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. MATTHEW A. BOYER, CIVIL. ACTION -LAW DEFENDANT IN DIVORCE NOTICE YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgement 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 at: The Office of the Prothonotary, Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania 17013. IF YOU DO NOT FILE A CLAIM FOR ALIMONY. DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-3166 800-990-9108 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 ADRIENNE J. BOYER, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. MATTHEW A. BOYER, CIVIL, AC rION - LAW DEFENDANT IN DIVORCE NOTICIA LE HAN DEMANDADO A USTED EN LA COUTE. Si Listed quiere defenderse de estas demandas expuestas en las paginas siguientes, Listed tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notification. Usted debe presentar Una apariencia escrita o en persona o por abogado y archivar en la corte en forma escrita sus defensas IT sus objeciones a las demandas en contra de su persona. Sea avisado que si Listed no se detiende, la corte tomato medidas y puede entrar una orden contra Listed sin previo aviso o notification y por cualquier queja o alivio que es pedido en la petition do demanda. Usted puede perder dinero o sus propiedades o otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO IMMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO, VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION 32 S. BEDFORD STREET CARLISLE, PENNSYLVANIA 17013 (717) 249-1166 800-990-9108 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P O. BOX 1062 • HARRISBURG. PA 17108 (717) 236-9428 • FAX(717)236-2817 ADRIENNE J. BOYER, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. MATTHEW A. BOYER, CIVIL AC PION - LAW DEFENDANT IN DIVORCE COMPLAINT IN DIVORCE UNDER SECTION 3301(C) OF THE DIVORCE CODE AND NOW, comes Plaintiff, Adrienne ,I. Boyer, by and through her attorneys, Meyers, Desfor, Saltzgiver & Boyle and files the following Complaint in Divorce and in support thereof avers as follows: Plaintiff is Adrienne J. Boyer an adult individual who currently resides at 198 Martel Circle, Dillsburg, Pennsylvania. 2. Defendant is Matthew A. Boyer an adult individual who currently resides at 6 Turmeric Drive, Mechanicsburg, Pennsylvania. 3. 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 Complaint. 4. The Plaintiff and Defendant were married on July 20, 2004 at Wailea, Maui, Hawaii. 5. There have been no prior actions of divorce or annulment between the parties. 6. The marriage is irretrievably broken. 7. The Defendant is not a member of the United States Army or its allies. 8. Plaintiff has been advised that counseling is available and that Plaintiff may have the right to request the court require the parties to participate in counseling, being so MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG. PA 17108 (717) 236-9428 • FAX (717) 236-2817 advised, Plaintiff waives that right. 9. Plaintiff requests the Court to enter a Decree of Divorce pursuant to Section 3301(C) or 3301(D) of the Divorce Code. WHEREFORE, Plaintiff, Adrienne .1. Boyer, respectfully requests this Honorable Court enter a Decree in Divorce pursuant to Section 3301(C) or 3301(D) of the Divorce Code. COUNTS COUNTI EQUITABLE DISTRIBUTION 10. Paragraphs one through nine of the Complaint are incorporated by reference as if fully set forth herein. 11. During the marriage, Plaintiff and Defendant have acquired various items of marital property, both real and personal, which are subject to equitable distribution under the Divorce Code. 12. Plaintiff requests that this Honorable Court equitably distribute all marital property pursuant to the Divorce Code. WHEREFORE, Plaintiff, Adrienne J. Boyer, respectfully requests this Honorable Court equitably distribute all property, both real and personal, tangible and intangible, acquired by the parties during their marriage. MEYERS, DESFOR, SALTZGIVER & DOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 COUNT 11 ALIMONY PENDENTE LITE, SUPPORT, COUNSEL FEES, AND EXPENSES 13. Paragraphs one through twelve of the Complaint are incorporated by reference as if fully set forth herein. 14. By reason of this action, Plaintiff will be put to considerable expense in the preparation of this case, in the employment of counsel. and the payment of costs. 15. Plaintiff is without sufficient funds to support herself and to meet the costs and expenses of this litigation, and unable to appropriately maintain herself during the pendency of this action. 16. Plaintiffs income is not sufficient to provide for her reasonable needs and pay her attorneys' fees and the costs of this litigation. 17. Defendant has adequate earnings to provide support and alimony pendente lite to the Plaintiff and to pay his counsel fees, costs and expenses. WHEREFORE, Plaintiff, Adrienne J. Boyer, respectfully requests this Honorable Court compel the Defendant to pay Plaintiff alimony pendente lite, support, counsel fees, costs and expenses of this action. COUNT III ALIMONY 18. Paragraphs one through seventeen of the Complaint are incorporated by reference as if fully set forth herein. MEYERS, DESFOR, SALTZGIVER 6 BOYLE 410 NORTH SECOND STREET • FO. BOX 1062 • HARRISBURG. PA 17108 (717) 236-9428 • FAX (717) 236-2817 19, Plaintiff lacks sufficient property to provide for her reasonable needs. 20. Plaintiff is unable to sufficiently support herself through appropriate employment. 21. Defendant has sufficient income and assets to provide continuing support and to pay alimony to the Plaintiff. WHEREFORE, Plaintiff, Adrienne J. Boyer, respectfully requests this Honorable Court compel Defendant to pay alimony to Plaintiff. Respectfully submitted, Catherine A. Boyle, Esquire Attorney I.D. 76328 Meyers, Desfor, Saltzgiver & Boyle 410 North Second Street P.O. Box 1062 1larrisburg, PA 17108 (717)236-9428 Attorney for Plaintiff MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX(717)236-2817 VERIFICATION I, Adrienne J. verify that the statements made in this Complaint in Divorce are true and correct to the bes of my knowledge, information and belief. I understand that fal statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 4/20/2006 ( ) Defendant MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 ?? _, ? _v ?? ? c? C ADRIENNE J. BOYER, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. MATTHEW A. BOYER, CIVIL ACTION - LAW DEFENDANT IN DIVORCE PETITION FOR SPECIAL RELIEF TO FREEZE ASSETS AND NOW, comes the Plaintiff, Adrienne J. Boyer, by and through her attorneys, Meyers, Desfor, Saltzgiver & Boyle, and files this Petition for Special Relief to Freeze Assets and in support thereof avers as follows: Plaintiff is Adrienne J. Boyer, an adult individual currently residing at 198 Martel Circle, Dillsburg, York County, Pennsylvania (hereinafter referred to as "Wife"). 2. Defendant is Matthew A. Boyer, an adult individual currently residing at 6 Turmeric Drive, Mechanicsburg, Cumberland County, Pennsylvania (hereinafter referred to as "Husband"). The parties are husband and wife, having been lawfully married on July 20, 2004. 4. Wife files a Complaint in Divorce contemporaneously with this Petition. 5. During the marriage, both parties were employed by Giant Food Stores. Husband as Category Manager and Wife as a Human Resource Manager. 6. Although Husband is the primary wage-earner, the parties divided household expenses equally. After paying said expenses, Wife had little to no remaining income. Husband, who earns approximately $95,000.00 per year, including bonus, would have MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 money remaining after paying expenses and invest same in accounts held in his name alone. 9. Wife believes Husband's investments are held at USAA and total over $30,000.00. 10. Wife has no other knowledge or access to these accounts. 11. Additionally, both parties have a 401(k) and other retirement benefits through their employment. 12. However, Husband's 401(k) has twice the value of Wife's and represents one of the largest marital assets. 13. Wife believes that upon service of the Complaint in Divorce, Husband will dissipate the accounts, particularly the investment accounts. in order to defeat Wife's interest in same. WHEREFORE, Plaintiff, Adrienne P. Boyer, respectfully requests this Honorable Court issue an Order stating that: Any and all retirement accounts are frozen pending further Order of Court; Any and all investment accounts are frozen pending further Order of Court. Respectfully submitted, i Catherine A. Boyle, Esquire I.D.#76328 MEYERS. DESFOR, SALTZG[VER & BOYLE 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for the Plaintiff MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. Adrienne J. Boyer, No. 06-2243 Plaintiff VERSUS Matthew A. Boyer, Defendant DECREE IN DIVORCE AND NOW, b r ? -7 2006_, IT IS ORDERED AND DECREED THAT Adreinne J. Boyer PLAINTIFF, AND Matthew A. Boyer DEFENDANT, ARE DIVORCED FROM THE BONDS OF MATRIMONY. THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; The Marital Settlement Agreement dated December 11, 2006 is herebv incorporated but not merged herein. BY THE COWRT: ATT#J: J. PFIOTFfO,*OTARY ??" J '?) i , ?p ?' / f }? r VERIFICATION I, Adrienne J. Boyer verify that the statements made in this Petition For Special Relief to Freeze Assets are true and correct to the bes of my knowledge, information and belief. I understand that fal statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 4/20/2006 'lAU nN I C ( X ) Plaintiff ( ) Defendant MEYERS, OESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 ADRIENNE J. BOYER, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. MATTHEW A. BOYER, CIVIL ACTION - LAW DEFENDANT : IN DIVORCE CERTIFICATE OF SERVICE I hereby certify on this = day of April, 2006, a copy of Petition for Special Relief to Freeze Assets was sent Certified Mail Restricted Delivery and Regular U.S. Mail, postage paid to: Matthew A. Boyer 6 Turmeric Drive Mechanicsburg, PA 17050 _ ?L e atherine A. Boyle, Esquire Attorney I.D. #76328 Attorney for Plaintiff MEYERS, DESFOR, SALTZGIVER 8, BOYLE 410 NORTH SECOND STREET • RO. BOX 1062 • HARRISBURG, PA 17106 (717) 236-9428 • FAX (7171 236-2817 ? 1 .l ?l. r.. ..l 3?? ADRIENNE J. BOYER, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. Vlp oZ-1?,3 ????. MATTHEW A. BOYER, CIVIL ACTION -LAW DEFENDANT IN DIVORCE RULE TO SHOW CAUSE AND NOW, this d V day of Q+1 , 2006, a RULE is issued upon the Defendant, Matthew A. Boyer, to show cause why the within Petition for Special Relief to Freeze Assets should not be granted. Until such time a hearing may be held, any and all retirement and investment accounts are frozen. Said Rule returnable at hearing on the day of 2006 at g 3b A.m. o'clock in Courtroom No. J BY THE COURT: MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 ADRIENNE J. BOYER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION - LAW : NO. 06-2243 MATTHEW A. BOYER, Defendant IN DIVORCE PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please enter the appearance of Hubert X. Gilroy, Esquire as attorney for Defendant Matthew A. Boyer in the above case. Dated: April 25, 2006 Il be X. G* oy, Esquire Broujos & ilroy, P.C. 4 N. Hanover Street Carlisle, PA 17013 (717) 243-4574 ID #29943 Attorney for Defendant ADRIENNE J. BOYER, : IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06-2243 MATTHEW A. BOYER, CIVIL ACTION -LAW DEFENDANT IN DIVORCE PROOF OF SERVICE MEYERS, DESFOR, SALTZGIVER 6 BOYLE 410 NORTH SECOND STREET • P.O. BOX 1082 • HARRISBURG, PA 17108 (717) 238-9428 • FAX(717)236-2817 ADRIENNE J. BOYER, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06-2243 MATTHEW A. BOYER, CIVIL ACTION - LAW DEFENDANT IN DIVORCE CERTIFICATE OF SERVICE I hereby certify on this C day of AN _2006, a copy of the foregoing Proof of Service was sent via first-class mail, postage pre-paid, to: Matthew A. Boyer c/o: Hubert X. Gilroy, Esquire BROUJOS & GILROY 4 North Hanover Street Carlisle, PA 17013 /J; ?__ h ? 6 Catherine A. Boyle, Esquire Attorney for Plaintiff MEYERS, DESFOR, SALTZGIVER 6 BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 ? _ `,i ? [ _ ? ?1 _, ., - ?i ? C,?: LC: r , G' '' ? :':? =l s] t`d .[ ADRIENNE J. BOYER, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06-2243 MATTHEW A. BOYER, CIVIL ACTION -LAW DEFENDANT IN DIVORCE ORDER OF COURT AND NOW, this y? day of May, 2006, upon relation of counsel, that the parties are attempting to amicably resolve the issues in this case, the hearing previously scheduled for May 4, 2006, is continued generally. Counsel are directed to notify the court if an agreement is reached or if a hearing is desired. , atherine A. Boyle, Esq. 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 Attorney for Plaintiff X. Gilroy, Esq. 4 North Hanover Street Carlisle, PA 17013 Attorney for Defendant BY THE COURT: "\ t ?="_ M. L. Ebert, J. a° 0 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. SOX 1062 • HARRISBURG, PA 17108 (717) 236-8428 • FAX(717)236-2817 VINVAIAS1VN3d ?IN(1C,r+ r^.n'? 7 NdfYJ hz *£ Wd h- AVW 9002 AdVIONiHiOdd 3Hl dfl ADRIENNE J. BOYER, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-2243 MATTHEW A. BOYER, CIVIL ACTION -LAW DEFENDANT IN DIVORCE CERTIFICATE OF SERVICE I hereby certify on this 16"-' day of , 2006, that the foregoing Request for Production of Documents was mailed, first-class, postage pre-paid to: Matthew A. Boyer c/o Hubert X. Gilroy, Esquire BROUJOS & GILROY 4 North Hanover Street Carlisle, PA 17013 4 V(?- cc -a? z Catherine A. Boyle, Esquire Attorney for Plaintiff 7 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 r Ell?- -;n ADRIENNE J. BOYER, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06-2243 MATTHEW A. BOYER, CIVIL ACTION -LAW DEFENDANT : ALIMONY PENDENTE LITE PETITION FOR ALIMONY PENDENTE LITE, COUNSEL FEES, COSTS AND EXPENSES AND NOW, comes the Petitioner, Adrienne J. Boyer, by and through her attorneys, Meyers, Desfor, Saltzgiver & Boyle, and files the following Petition for Alimony Pendente Lite, Counsel Fees and Expenses and in support thereof avers as follows: 1. Petitioner is Adrienne J. Boyer, an adult individual who currently resides at 1471 Hillcrest Court, Apt. 706, Camp Hill, Pennsylvania (hereinafter known as "Wife"). 2. Respondent is Matthew A. Boyer, an adult individual who currently resides at 1017 Chippenham Road, Mechanicsburg, Pennsylvania (hereinafter known as "Husband"). 3. The parties were married on July 20, 2004 at Wailea, Maui, Hawaii. 4. A Complaint in Divorce was filed on April 21, 2006. 5. Said Complaint in Divorce contains a count requesting Alimony Pendente Lite, Support, Counsel Fees, Costs and Expenses. 6. Since the date of separation, Wife has received no money from Husband. 7. By reason of this action, Wife will be put to considerable expense in the preparation of her case, in the employment of counsel and the payment of costs and expenses. 8. Wife is without sufficient funds to support herself and to meet the costs and expenses MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 of this litigation and is unable to appropriately maintain herself during the pendency of this action. 9. Wife's income is not sufficient to provide for her reasonable needs and to pay attorney's fees and the costs of this litigation. 10. Husband has adequate earnings to provide support and alimony pendente lite for the Wife and to pay her counsel fees, costs and expenses. WHEREFORE, the Petitioner, Adrienne J. Boyer respectfully requests this Honorable Court award her Alimony Pendente Lite. Respectfully submitted, Catherine A. Boyle, Esquire Attorney I.D. 76328 Meyers, Desfor, Saltzgiver & Boyle 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717)236-9428 Attorney for Petitioner MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 VERIFICATION I, Adrienne Boyer , verify that the statements made in this Petition for Alimony pendent T,,__, Coun el Fees, Costs and Expenses 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. Section 4904, relating to unsworn falsification to authorities. Dated: 9/29/06 ( ) Defendant MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 ADRIENNE J. BOYER, IN THE COURT OF COMMON PLEAS PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06-2243 MATTHEW A. BOYER, CIVIL ACTION -LAW DEFENDANT : ALIMONY PENDENTE LITE CERTIFICATE OF SERVICE I hereby certify that on this c2?,- day of , 2006, a copy of the attached Petition for Alimony Pendente Lite, Counsel Fees, Costs and Expenses was mailed, postage prepaid, to: Hubert X. Gilroy, Esquire BROUJOS & GILROY 4 North Hanover Street Carlisle, PA 17013 i- -?? A Catherine A. Boyle, Es re Attorney for Petitioner MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DOMESTIC RELATIONS SECTION 13 N. HANOVER ST., P.O. BOX 320, CARLISLE PA 17013 Phone: (717) 240-6225 Adreinne J. Boyer Plaintiff V. Matthew A. Bover Defendant Fax: (717) 240-6248 NO. 06-2243 CIVIL ACTION - LAW IN I DIVORCE DRS ATTACHMENT FOR APL PROCEEDINGS PETITIONER'S INFORMATION: Name: Adrienne-Jane Boyer Address: 1471 Hillcrest Court, 706 City: Camp Hill State: PA SSN: 173-54-5293 DOB: 5/1-=/74 Physica.lDescription:.Ht. Wt. Eves Emaii-Address: Employer: Ahold Financial Services LI-D Code Telephone: Hai. Race Employer's Address: 1149 Harrisburc_ Pike a rsle, Pa 17013 Phone: 960-;727 loo TitlelPosition: Human Gross Pad,: 67, loo %r Net Pay: Resource Manager (plus bonus) Petitioner's Attorney: Catherine A. Bogle, Esquire Petitioner's Attorney's Address: 41 North econa Street, Harr isflurG, A 17101 Phone:717-236-9428 Medical Insurance Carrier: Medical Insurance Carrier Address: Phone: Policy Number: Group Number: 17ti-- RESPONDENT'S INFORMATION: Name:Matthew Alan Boyer Address: 1017 C ippenham Road City: Mechanicsburg State: PA Zip Code: 17050 SSN:548-67-3737 DOB: 7/ll/72 Telephone: Physical Description: Ht. Wt. Eyes Hair Race Email Address: Employer: Giant Food Stores Employer's Address: 1149 Harrisburg Pike Carlisle, PA 17013 Phone: 240-1556 Job Title/Position: Category Gross Pay: 75,0 00/yrNet Pay: Manager (plus bonus) Respondent's Attorney: Hubert X. Gilroy, Esquire Respondent's Attorney's Address: 4 North Hanover Street Carlisle, PA 17013 Phone:717-243-457-'_ Medical Insurance Carrier: Medical Insurance Carrier-Address: Policy Number: MARRIAGE INFORMATION: Phone: Group Number. Date Married: 7 / 2 0 / 0 4 Date or Separation: Place of Marriage: Maui, Wailea, E? Address of last Marital Domicile : 6 Turmeric Drive Mechanicsburg, PA 17050 Description of Document Raising APL Claim: Petition for APL, Counsel Fees, Costs Date APL Document Filed": & Expenses "Please note: A copy of the filed document MUST be enclosed with this form." 1 PJ C? c:? l C 7 `r7 -gib co rri a I\ti G J In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION ADRIENNE J. BOYER ) Docket Number 06-2243 CIVIL Plaintiff ) VS. ) PACSES Case Number 688108667 MATTHEW A. BOYER ) Defendant ) Other State ID Number ORDER OF COURT You, MATTHEW A. BOYER plaintiff/defendant of 1017 CHIPPENHAM RD, MECHANICSBURG, PA. 17050-2196-17 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the NOVEMBER 29, 2006 at 9: 3 OAM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available to you 5. information relating to professional licenses 6. other: Service Type M Form CM-504 Worker ID 21302 BOYER V. BOYER PACSES Case Number: 688108667 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: 0 (J 0 ) - C, JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 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 at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Service Type M Worker ID 21302 r In the Court of Common Pleas of CUMBERLAND County, Pennsylvania DOMESTIC RELATIONS SECTION ADRIENNE J. BOYER ) Docket Number 06-2243 CIVIL Plaintiff ) VS. ) PACSES Case Number 688108667 MATTHEW A. BOYER ) Defendant ) Other State ID Number ORDER OF COURT You, ADRIENNE J. BOYER plaintiff/defendant of APT 706, 1471 HILLCREST CT, CAMP HILL, PA. 17011-8026-81 are ordered to appear at DOMESTIC RELATIONS HEARING RM DOMESTIC RELATIONS OFC, 13 N HANOVER ST, CARLISLE, PA. 17013-3014-13 before a hearing officer of the Domestic Relations Section, on the NOVEMBER 29, 2006 at 9:30AM for a hearing. You are further required to bring to the hearing: 1. a true copy of your most recent Federal Income Tax Return, including W-2s, as filed, 2. your pay stubs for the preceding six (6) months, 3. verification of child care expenses, and 4. proof of medical coverage which you may have, or may have available to you 5. information relating to professional licenses 6. other: Service Type M Form CM-509 Worker ID 21302 BOYER V. BOYER PACSES Case Number: 688108667 If you fail to appear for the conference/hearing or to bring the required documents, the court may issue a warrant for your arrest or enter an order in your absence. If paternity is an issue, the court may enter an order establishing paternity. The appropriate court officer may enter an order against either party based upon the evidence presented without regard to which party initiated the support action. BY THE COURT: Date of Order: r• o L 0 C, 0 4 /?4i ?' z J.//WESLEY OL JR., JUDGE YOU HAVE THE RIGHT TO A LAWYER, WHO MAY ATTEND THE HEARING AND REPRESENT YOU. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND CO BAR ASSOCIATION 32 S BEDFORD ST CARLISLE PA 17013-3302-32 (717) 249-3166 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 at: (717) 240-6225 . All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled hearing. Page 2 of 2 Form CM-509 Service Type M Worker ID 21302 1 _ (771 -t co NOV 29 2006 0" ADRIENNE J. BOYER, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : CIVIL ACTION -LAW : NO. 06-2243 MATTHEW A. BOYER, 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 April 21, 2006. 2. Defendant acknowledges receipt and accepts service of the Complaint on or about April 24, 2006. 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. 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: November a 1 , 2006 Aor e A,=::::= Matthew A. Boyer, Defend At (7 ?a a 'TF Q h3 ? C> ADRIENNE J. BOYER, PLAINTIFF V. MATTHEW A. BOYER, DEFENDANT IN THE COURT F COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2243 CIVIL ACTION LAW IN DIVORCE A Complaint in Divorce under Section 3301(c) o the Divorce Code was tiled on April 21, 2006. The marriage of the Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service oft e Complaint. I consent to the entry of a final decree of divorce Rafter 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.S. § 4904 relating to unworn falsification to authorities. Date: IZ-4`2-ooco Adrienne . Boyer MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 1 0 rrl ' : Cri t Cn '3 YT; a)C ? ?.. ? ?? -< D ADRIENNE J. BOYER, PLAINTIFF V. MATTHEW A. BOYER, DEFENDANT IN THE COURT CUMBERLAND NO. 06-2243 CIVIL ACTION IN DIVORCE WAIVER OF NOTICE OF INTENT vl ENTRY OF A DIVORCE DE REE UNDER final decree of divorc? without notice. I consent to the entry of a L 2. I understand that I may lose rights concerning al?mony, 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 d?vorce decree is entered by the Court and that a copy of the decree will be sent to me Prothonotary. I verify that the statements made in this false statements herein are made subject to the unworn falsification to authorities. Date-L2- --4 - 20 0 to OF COMMON PLEAS COUNTY, PENNSYLVANIA LAW ON TO after it is filed with the are true and correct. I understand that of 18 PC S. § 4904 relating to . Boyer MEYERS, DESFOR, SALTZGIVIER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 102 • HARRISBURG, PA 17108 (717) 236-9428 • FAX(71i)236-2817 cn MARITAL SETTLEMENT AGREEMENT `?h THIS AGREEMENT made this I I` day o , 2006 by and between Adrienne Jane Boyer (hereinafter referred to as "Wife") of 1471 Hillcrest Court, Apt. 706, Camp Hill, Cumberland County, Pennsylvania and Matthew Alan Boyer (hereinafter referred to as "Husband") of 1017 Chippenham Road, Mechanicsburg, Cumberland County, Pennsylvania. WITNESSETH: WHEREAS, Husband and Wife were lawfully married on July 20, 2004 in Maui, Wailea, Hawaii; and WHEREAS, no children have been conceived of this marriage; and WHEREAS, diverse differences and difficulties have arisen between the parties respecting their interests, rights and title in and to certain property, real and/or personal, owned by or in possession of the said parties to either of them; and WHEREAS, Husband and Wife desire to settle and determine their rights and obligations and to amicably adjust, compromise and forever settle all property rights and all rights in, to or against each other's property or estate of any kind or nature whatsoever, including property heretofore or subsequently acquired by either party and to settle all disputes existing between them, including any and all claims for Wife's and/or Husband's rights to equitable distribution, maintenance and/or support, alimony, alimony pendente lite, counsel fees and costs; and WHEREAS, the parties acknowledge and agree that in entering into this Agreement, including foregoing waivers, they are each relying on truth and completeness in all material respects as to all information provided by the other party hereto regarding the assets of such person. NOW THEREFORE, in consideration of the mutual promises, covenants and agreements hereinafter contained, each of the parties hereto intending to be legally bound hereby promises, covenants and agrees as follows: 1. DIVORCE: The parties agree that their marriage is irretrievably broken and that they mutually consent to a divorce and agree and have executed all necessary Affidavits of Consent and Waivers of Notice forms required by the court for the entry of a mutual consent divorce. Both Husband and Wife have directed their respective counsel to immediately file with the Court said Affidavits and Waivers and file the appropriate documents to request a Decree in Divorce from the bonds of matrimony under Section 3301(c) of the Divorce Code. 2 2. FULL FORCE AND EFFECT: This Agreement shall continue in full force and effect until such time of final Decree in Divorce is entered. 3. AGREEMENT TO CONTINUE IN EVENT OF DIVORCE: In the event that the marriage of the parties hereto is terminated by divorce, this Agreement shall nevertheless remain in full force and effect, and shall survive such decree and shall not in any way be affected thereby, except as provided for herein. 4. INTERFERENCE: Each party shall be free from interference, authority, and 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. 5. WIFE'S DEBTS: Wife represents and warrants to Husband that since the date the divorce was filed, to wit, April 21, 2006, she has not and in the future she will not, contract or incur any debt or liability for which Husband or his estate might be responsible and shall indemnify and save harmless Husband from any and all claims or demands made against him by reason of debts or obligations incurred by her. 6. HUSBAND'S DEBTS: Husband represents and warrants to Wife that since the divorce was filed, to wit, April 21, 2006, he has not and in the future he will not, contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save harmless Wife from any and all claims or demands made against her by reason of debts or obligations incurred by him. 7. DISCOVERYNINANCIAL DISCLOSURE: The parties agree and acknowledge that they have each had the opportunity to conduct discovery and investigation of the assets of both parties. Wife acknowledges that she has issued various requests for information from Husband. Husband acknowledges that he had the opportunity to conduct discovery of Wife's assets. The parties agree and acknowledge that they have made full and fair disclosure of all of their assets and income to the other party. The parties acknowledge that they have both been given the opportunity to conduct investigation into all assets, whether separate or marital, prior to entry into this agreement. Both Husband and Wife acknowledge they have had full and fair disclosure of all assets prior to execution of this agreement. Furthermore, the parties acknowledge that they have both had full disclosure as to both parties income and financial condition. MUTUAL RELEASES: Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement does for himself or herself and his or her heirs, legal representatives, executors, administrators and assigns, release and discharge the other of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, which either of the parties ever had or now has against the other, except any or 4 all causes of action for termination of the marriage by divorce or annulment and except any or all causes of action for breach of any provisions of this Agreement. Husband and Wife specifically release and waive any and all rights he or she might have to raise claims under the Pennsylvania Divorce Code and all subsequent amendments, but not limited to claims for equitable distribution of marital property, support, alimony, alimony pendente lite, counsel fees or expenses. The fact that a party brings an action to enforce the property agreement as incorporated in the divorce decree, under the Pennsylvania Divorce Code and all subsequent amendments, does not give either party the right to raise other claims under the Divorce Code, specifically waived and released by this paragraph and all rights and obligations of the parties arising out of the marriage shall be determined by this Agreement. 9. RELEASE OF TESTAMENTARY CLAIMS: Except as provided for in this Agreement, each of the parties hereto shall have the right to dispose of his or her property by Last Will and Testament or otherwise and each of them agree that the estate of the other, whether real, personal or mixed, shall be and belong to the person or persons who would become entitled thereto as if the decedent had been the last to die. This provision is intended to constitute a mutual waiver by the parties of any rights to take against each other's Last Wills under the present or future laws of any jurisdiction whatsoever and is intended to confer third-party beneficiary rights upon the other heirs and beneficiaries of each. 5 10. AGREEMENT BINDING ON HEIRS: The parties acknowledge that except as provided for in this Agreement, each of the parties shall have the right to dispose of their respective property by Last Will and Testament, and that each party waives the right to take under the Will of the other. This Agreement shall be binding on the respective heirs, executors, administrators and assigns of the parties thereto. 11. ENTIRE AGREEMENT: This Agreement represents the entire agreement between the parties. There are no representations, promises, agreements, conditions, or warranties between the parties other than those set forth herein. 12. LEGAL ADVICENOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel. The Wife has employed and has had the benefit of counsel of Catherine A. Boyle, Esquire, as her attorney. The Husband has employed and has had the benefit of counsel of Hubert X. Gilroy, Esquire, as his attorney. Each party acknowledges that they have received independent legal advice from counsel and that each party fully understands the facts and have been fully informed of their legal rights and obligations, and each party acknowledges and accepts that this Agreement is, under the circumstances, fair and equitable, and that it is being entered into freely and voluntarily after having received such advice and with such knowledge, and that execution of this Agreement is not the result of any duress or undue influence and that it is not the result of any collusion or improper or illegal agreement or agreements. Also, each party hereto acknowledges that 6 he or she has been fully advised by his or her respective attorney of the current Pennsylvania Divorce Law, and his or her rights thereunder, each party hereto still desires to execute this Agreement acknowledging that the terms and conditions set forth herein are fair, just, and equitable to each of the parties and waives their respective right to have the Court make any determination or order affecting the respective parties' right to a divorce, alimony, alimony pendente lite, equitable distribution of all marital property, counsel fees and costs and expenses. 13. EQUITABLE DISTRIBUTION: a. The parties acknowledge that the former marital residence was sold and the proceeds placed in a Mid Penn Escrow account #14000939. The parties agree that said account shall be closed with $50,000.00 being distributed to Wife and the balance being distributed to Husband. b. The parties acknowledge that there are savings bonds titled in joint names. Any and all said bonds shall become the sole and exclusive property of Husband. Any tax consequence resulting from redeeming said bonds shall be the sole and exclusive responsibility of Husband. C. Any and all other property not specifically mentioned herein shall become the sole and exclusive property of the individual to whom said asset is titled. 14. WAIVER OF RIGHT TO ALIMONY, ALIMONY PENDENTE LITE, SPOUSAL SUPPORT, COUNSEL FEES, COSTS AND EXPENSES: The parties hereby acknowledge that they each waive their right to request alimony, alimony pendente lite, spousal support, counsel fees, costs and expenses from the other unless otherwise provided for in this Agreement. 15. BREACH: If either parry breaches any provision of this Agreement, the other party shall have the right, at his or her election, to sue for damages for such breach or seek such other remedies or relief as may be available to him or her, and the party breaching this contract shall be responsible for payment of legal fees and costs incurred by the other in enforcing their rights under this Agreement. 16. ADDITIONAL INSTRUMENTS: a. Each of the parties shall from time to time, at the request of the other, execute, acknowledge, and deliver to the other party any and all further instruments that may be reasonably required to give full force and effect to the provisions of this Agreement. b. This Agreement shall be incorporated into a Divorce Decree but not merged therein. 17. MODIFICATION AND WAIVER: A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance 18 19 20 21. of any of the provisions of this Agreement shall not be construed as a waiver of any subsequent default of the same or similar nature. DESCRIPTIVE HEADINGS: The descriptive headings used herein are for convenience only. They shall have no effect whatsoever in determining the rights or obligations of the parties. VOID CLAUSES: If any term, condition, clause or provision of this Agreement shall be determined 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 Agreement shall be valid and continue in full force, effect, and operation. EXECUTION DATE: The execution date shall be defined as the date both parties have signed this Agreement. In the event that the parties do not sign this Agreement at the same time, the execution date shall be the date the last party has signed. APPLICABLE LAW: This Agreement shall be construed pursuant to the laws of the Commonwealth of Pennsylvania. 9 IN WITNESS WHEREOF, the parties have hereunto set their hands and seals the day and year first above-written. Catherine A. Boyle, Esquire Adrienne J. Boyer Matthew A. Boyer 10 r'? _ r., ?-? O _. ?=? -n -?:, ? ?? -- : t: -= r .._ ?... ?__ .?.Jl./ _ -._ ? .....,E !? ?' . .. wl ?.A? _ ?i ADRIENNE J. BOYER, PLAINTIFF V. MATTHEW A. BOYER, DEFENDANT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2243 CIVIL ACTION -LAW IN 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 Section 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: Served by Certified Mail Restricted Delivery on April 28, 2006. Proof of Service was filed with the Prothonotary on MU 3, 2006. 3. (a) Date of execution of the Affidavit of Consent required by Section 3301(c) of the Divorce Code: by the Plaintiff December 4, 2006; by the Defendant November 29. 2006. 4. Related claims pending: No other claims ending. 5. Date and manner of service of the notice of intention to file praecipe to transmit record, a copy of which is attached, if the decree is to be entered under section 3301(d)(1)(I) of the Divorce Code. (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: ?J MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 (b) Date Plaintiffs Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary; December 5 2006. Date Defendant's Waiver of Notice in § 3301(c) Divorce was filed with the Prothonotary November 29 2006. Catherine A. Boyle, Esqui Attorney for Plaintiff MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX (717) 236-2817 ADRIENNE J. BOYER, IN THE COURT OF COMMON PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA NO. 06-2243 MATTHEW A. BOYER, DEFENDANT 'CIVIL ACTION -LAW : IN DIVORCE CERTIFICATE OF SERVICE I hereby certify on this day of, 2006 Praecipe to Transmit Record was sent first-class mail, Postage copy of the forgoing paid to: Matthew A. Boyer C/o Hubert X. Gilroy, Esquire BROUJOS & GILROY 4 North Hanover Street Carlisle, PA 17013 Respectfully submitted, r Catherine A. Boyle, Esquire Attorney for Plaintiff II MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 - HARRISBURG, PA 17108 (717) 236-9428 - FAX (717) 236-2817 c r. l.v W 0 -rt =r ril --C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA. Plaintiff Vs File No. IN DIVORCE ? Defendant NOTICE TO RESUME PRIOR SURNAME Notice is hereby given that the Plaintiff / defendant in the above matter, [select one by mai dng "x'] prior to the entry of a Final Decree in Divorce, or X_ after the entry of a Final Decree in Divorce dated D2c- Z-7 , 200ig hereby elects to resume the prior surname of (et* I , and gives this written notice avowing his / her intention p pro of 54 P.S. 704. Date: I)-U, 01 Si C-'y J-jlp'?p - Signature of Aama being resumed COMMONWEALTH OF PENNSYLVANIA COUNTY OFI-', 1/,v,4,,,. d ) On the day of Wgty , 200 before me, the Prothonotary or the notary public, personally appeared the above affiant known to me to be the person whose name is subscribed to the within document and acknowledged that he / she executed the foregoing for the purpose therein contained. In Witness Whereof, I have her unto set my hand hereunto set my hand and official seal. NOTARIAL SEAT. PROTHONOTARY, NOTARY PUBLIC CARLISLE CUMBERLAND COUIGY COURTHOUSE MY COMMISSION E)IRES JANUARY 4, 2010 Notary Public - ? o r v Q4