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HomeMy WebLinkAbout06-2708ELEANOR M. KISH, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. o - a'Y6p WILLIAM A. KISH CIVIL ACTION - LAW Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County Courthouse, 1 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 NO HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, 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 County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 1-800-990-9108 ELEANOR M. KISH, Plaintiff V. WILLIAM A. KISH Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. d L. - -170 0' (2 1-0?Cn CIVIL ACTION - LAW IN DIVORCE COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Eleanor M. Kish who currently resides at 20 Kensington Drive, Camp Hill, Pennsylvania, 17011, Cumberland County since August 17, 1996. 2. Defendant is William A. Kish who currently resides at 50 Bonny Brook Road, Carlisle, Pennsylvania, 17013, Cumberland County, and is believed to have lived there since the parties separated on January 3, 2006. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 18, 2006, Hollisterville, Pennsylvania, Wayne County. COUNT I: DIVORCE - DIVORCE 5. Plaintiff hereby incorporates by reference averments 1 through 4 of this Complaint as if each averment were set forth fully hereunder. 6. There have been no prior actions of divorce or annulment between the parties except Plaintiff filed for divorce in 1995, however, Plaintiff and Defendant soon after reconciled. 7. Neither Plaintiff nor Defendant is in the Armed Forces of the United States or any of its allies. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and the plaintiff may have the right to request that the court require the parties to participate in counseling. 10. Plaintiff and Defendant have property which will be subject to a property settlement agreement addressing support issues, which will be filed herein at the appropriate time. 11. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: That a decree in divorce be entered dissolving the marriage between the two parties. COUNT II: DIVORCE - EQUITABLE DISTRIBUTION 12. Plaintiff hereby incorporates by reference averments 1 through 11 of this Complaint as if each averment were set forth fully hereunder. 13. Plaintiff and Defendant have acquired property, both real and personal, during the course of their marriage. 14. The parties have also acquired home furnishings, motor vehicles, bank accounts, retirement accounts, investments an miscellaneous items of personal property. 15. Thus far Plaintiff and Defendant have been unable to agree as to an equitable distribution of said property, therefore Plaintiff requests the equitable distribution of said marital property. WHEREFORE, Plaintiff prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: That a decree in divorce be entered granting equitable distribution of marital property. LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys fot-PlainTiff Peter J. Russo, Esquire I D # 72897 Scott A. Stein, Esquire ID # 81738 Elizabeth J. Saylor, Esquire ID # 200139 Date: J /- 406 ELEANOR M. KISH, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. WILLIAM A. KISH CIVIL ACTION - LAW Defendant IN DIVORCE VERIFICATION I, ?'`ec3ipr , verify that the statements made in the foregoing document(s) are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. i Date: Eleanor M. Kish r . ?2• ? O ; i ELEANOR M. KISH, Plaintiff V. WILLIAM A. KISH Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE hereby certify that I am on this day serving a copy of the foregoing documents upon the person(s) and in the manner indicated below: Regular Mail and Certified Mail, Restricted Delivery, Return Receipt Requested, and addressed as follows: William A. Kish 50 Bonny Brook Rd Carlisle, PA 17013 Date: d e-) Q Mi P' Cd> ! r -ern ? . € +.S j C ) '? .w 'i C~S CO 0- ELEANOR M. KISH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 0 WILLIAM A. KISH CIVIL ACTION - LAW Defendant IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at Cumberland County Courthouse, 1 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 NO HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, 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 County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 1-800-990-9108 ELEANOR M. KISH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. WILLIAM A. KISH CIVIL ACTION - LAW Defendant IN DIVORCE AMMENDED COMPLAINT UNDER SECTION 3301(c) OR 3301(d) OF THE DIVORCE CODE 1. Plaintiff is Eleanor M. Kish who currently resides at 20 Kensington Drive, Camp Hill, Pennsylvania, 17011, Cumberland County since August 17, 1996. 2. Defendant is William A. Kish who currently resides at 50 Bonny Brook Road, Carlisle, Pennsylvania, 17013, Cumberland County, and is believed to have lived there since the parties separated on January 3, 2006. 3. Plaintiff and Defendant have been bona fide residents in the Commonwealth for at least six months immediately previous to the filing of this Complaint. 4. Plaintiff and Defendant were married on October 18, 1986, Hollisterville, Pennsylvania, Wayne County. COUNT I: DIVORCE -DIVORCE 5. Plaintiff hereby incorporates by reference averments 1 through 4 of this Complaint as if each averment were set forth fully hereunder. 6. There have been no prior actions of divorce or annulment between the parties except Plaintiff filed for divorce in 1995, however, Plaintiff and Defendant soon after reconciled. 7. Neither Plaintiff nor Defendant is in the Armed Forces of the United States or any of its allies. 8. The marriage is irretrievably broken. 9. Plaintiff has been advised that counseling is available and the plaintiff may have the right to request that the court require the parties to participate in counseling. 10. Plaintiff and Defendant have property which will be subject to a property settlement agreement addressing support issues, which will be filed herein at the appropriate time. 11. Plaintiff requests the court to enter a decree of divorce. WHEREFORE, Plaintiff prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: That a decree in divorce be entered dissolving the marriage between the two parties. COUNT II: DIVORCE - EQUITABLE DISTRIBUTION 12. Plaintiff hereby incorporates by reference averments 1 through 11 of this Complaint as if each averment were set forth fully hereunder. 13. Plaintiff and Defendant have acquired property, both real and personal, during the course of their marriage. 14. The parties have also acquired home furnishings, motor vehicles, bank accounts, retirement accounts, investments an miscellaneous items of personal property. 15. Thus far Plaintiff and Defendant have been unable to agree as to an equitable distribution of said property, therefore Plaintiff requests the equitable distribution of said marital property. WHEREFORE, Plaintiff prays that a decree be entered in favor of the Plaintiff and against Defendant as follows: That a decree in divorce be entered granting equitable distribution of marital property. LAW OFFICES OF PETER J. RUSSO, P.C. Attorneys for Plaintiff - Peter J. Russo, Esquire ID # 72897 Scott A. Stein, Esquire ID # 81738 Elizabeth J. Saylor, Esquire D #200139 Date: `? ?? _ 0 ELEANOR M. KISH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. WILLIAM A. KISH CIVIL ACTION - LAW Defendant IN DIVORCE VERIFICATION verify that the statements made in the foregoing document(s) are true and correct. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. Date: /?PD Eleanor M. Kish ELEANOR M. KISH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. WILLIAM A. KISH CIVIL ACTION - LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I,ne- 4J S? , hereby certify that I am on this day serving a copy of the foregoing documents upon the person(s) and in the manner indicated below: Regular Mail and addressed as follows: William A. Kish 50 Bonny Brook Rd Carlisle, PA 17013 Date: 6 ` m '6l0 C7 ? C` cy {;,Yl -n .T m rTl - 1 ELEANOR M. KISH, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA a 7os V. NO.? ?- WILLIAM A. KISH CIVIL ACTION - LAW Defendant IN DIVORCE CERTIFICATE OF SERVICE I, 7??hS>„?1??r1 , hereby certify that I am on this day serving a copy of the foregoing documents upon the person(s) and in the manner indicated below: Regular Mail and Certified Mail, Restricted Delivery, Return Receipt Requested, and addressed as follows: William A. Kish 50 Bonny Brook Rd Carlisle, PA 17013 Date: 1?( ( Dcc?t' I's ¦ Complete sterns 1, 2, and 3. Alec complete Item 4 if Restricted Delivery is deemed. ¦ Print your name and address on the reverse so that we can return the card to you. ¦ Attach this card to the back of the mailpieae, or on the front if space permits. 1. Article Addressed to: k-?OA3 A. ? Agent B. Received by (ftA Acne) JC.'D I r7 D. Is deYvery addrees dMererd from Item 1? ? Yes H YES, enter dWtmy address below: ? No 3. \Sojvlw Type WP~ I Meg M? xn Receipt for MomhWKUW IR"Wered r13C.O.D. ? noxed Mdi 4. Reslli-Wd DeNvery? (Extra Fee) Yea 2. ArddeNwnber 7001 2510 0006 5849 6761 ( www nom swwco kw PS Form 3811. February 2004 DomeMlo Reben ReOeI?iR 102595-02?A 1540 s n O (=) -u CT I! ILI •? S . ELEANOR M. KISH, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-2708 WILLIAM A. KISH CIVIL ACTION -LAW Defendant IN DIVORCE INVENTORY OF ELEANOR KISH Plaintiff files the following inventory of all property owned or possessed by either party at the time this action. Plaintiff verifies that the statements made in this inventory are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to authorities. ELEANOR 4 &ZA ?G_-- t ASSETS OF THE PARTIES Plaintiff marks on the list below those items applicable to the case at bar and itemizes the assets on the following pages. ( ) 1. Real property (X) 2. Motor vehicles ( ) 3. Stocks, bonds, securities and options ( ) 4. Certificates of deposit ( ) 5. Checking accounts, cash (X) 6. Savings accounts, money market and savings certificates ( ) 7. Contents of safe deposit boxes ( ) S. Trusts (X) 9. Life insurance policies (indicate face value, cash surrender value and current beneficiaries) ( ) 10. Annuities ( ) 11. Gifts ( ) 12. Inheritances ( )13. Patent, copyrights, inventions, royalties ( ) 14. Personal property outside the home ( ) 15. Business (list all owners, including percentage or ownership, and officer/director positions held by a party with company) ( ) 16. Employment termination benefits --- severance pay, worker's compensation claim/award ( ) 17. Profit sharing plans ( ) 18. Pension plans (indicate employee contribution and date plan vests) (X) 19. Retirement plan, individual Retirement Accounts ( ) 20. Disability payments ( ) 21. Litigation claims (matured and unmatured) ( ) 22. Military/V.A. benefits ( ) 23. Education benefits (X) 24. Debts due, including loans, mortgages held ( X) 25. Household furnishings and personality (include as a total category and attach itemized list if distribution of such assets is in dispute) ( ) 26. Other MARITAL PROPERTY Plaintiff lists all martial property in which either or both spouses have a legal or equitable interest individually or with any other person as of the date this action was commenced: Item Number Description of Property 2 1992 GMC Sierra 2 1996 Chevrolet Lumina 2 2002 Volkswagon Jetta 6 Arkansas Best FCU 6 AC Credit Union 6 Sovereign Bank 9 American General 9 Teamsters Name of All Owners Plaintiff and Defendant Plaintiff and Defendant Plaintiff and Defendant Plaintiff and Defendant Plaintiff and Defendant Plaintiff and Defendant Plaintiff Defendant .1 1 19 Smith Barney Citigroup 19 Teamsters 24 Arkansas Best FCU 24 Sears Credit Card 25 Gun Collection 25 Jewelry 25 NASCAR Racing Collection 25 Tools Plaintiff Defendant Plaintiff and Defendant Plaintiff and Defendant Defendant Plaintiff Plaintiff and Defendant Defendant NON-MARITAL PROPERTY Plaintiff lists all property in which a spouse has a legal or equitable interest which is claimed to be excluded from marital property: Item No. Description of Property Reason Excluded NIA PROPERTY TRANSFERRED Item Description Transfer Consid- Transferred NIA No. of Property Date eration to Property transferred by Defendant LIABILITIES Item Description Names of Names of N/A Number of Property All Creditors All Debtors LAW OFFICES OF PETER J. RUSSO, P.C. f Attorneyslor Plaintiff Peter J. Russo, Esquire ID # 72897 Scott A. Stein, Esquire ID # 81738 Elizabeth J. Saylor, Esquire ID # 200139 06 Date: / 00 ELEANOR M. KISH, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : NO. 06-2708 WILLIAM A. KISH : CIVIL ACTION -LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE 1, Janet E. Bush, hereby certify that I am on this day serving a copy of the foregoing documents upon the person(s) and in the manner indicated below: US Mail addressed as follows: William A. Kish 50 Bonny Brook Road Carlisle, PA 17013 Date: 'Z 3 J t E. Bush C7 C) ELLA?AQZ M. Y1 SN vs \lL1.- l AM A. V-\ S?A Case No. Olo _ 2-7 O 0 Statement of Intention to Proceed To the Court: E I co rm M. K 1 h intends to proceed with the above Print Name E I 1 ?O.kh Sigh Name Date: IkD N Attorney for Explanatory Comment The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit comment. 1. Rule of civil Procedure New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2 is tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting local rules. This rule was promulgated in response to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 360,710 A.2d 1104 (1998) in which the court held that "prejudice to the defendant as a result of delay in prosecution is required before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 1901." Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The general policy of the prompt disposition of matters set forth in subdivision (a) of that rule continues to be applicable. II Inactive Cases Thc purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. The process is initiated by the court. After giving notice of intent to terminate an action for inactivity, the course of the procedure is with the parties. If the parties do not wish to pursue the case, they will take no action and "the Prothonotary shall enter an order as of course terminating the matter with prejudice for failure to prosecute." If a parry wishes to pursue the matter, he or she will file a notice of intention to proceed and the action shall continue. a. Where the action has been terminated If the action is terminated when a party believes that it should not have been terminated, that party may proceed under Rule230(d) for relief from the order of termination. An example of such an occurrence might be the termination of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file the notice of intention to proceed. Thc timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of the entry of the order of termination on the docket, subdivision (dX2) provides that the court must grant the petition and reinstate the action. If the petition is filed later than the thirty-day period, subdivision (dX3) requires that the plaintiff must make a show in to the court that the petition was promptly fled and that there is a reasonable explanation or legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of termination on the docket and for the failure to file the petition within the thirty-day period under subdivision (dX2). B. Where the action has not been terminated An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue the remedy of a common law non pros which exits independently of termination under Rule 230.2. FILED-U1:1: 1'--"t" OF THE PR,71 `NOTARY 2009 SEP 18 AM 10: 4 2 CUm.v ?IffaA, vs P? all n h f F Case No. - Z 1 !? h A I ' f S a eitienh?fwition to Proceed To the Court: Y yI (G(,o'n A, 164 intends to proceed with the above captioned matter. p Print NameZ[-fi 1 V 1. t t/(? Sign Name Date: $ Attorney for kdkndan? Explanatory Comment The Supreme Court of Pennsylvania has promulgated new Rule of Civil Procedure 230.2 governing the termination of inactive cases and amended Rule of Judicial Administration 1901. Two aspects of the recommendation merit comment. 1. Rule of civil Procedure New Rule of Civil Procedure 230.2 has been promulgated to govern the termination of inactive cases within the scope of the Pennsylvania Rules of Civil Procedure. The termination of these cases for inactivity was previously governed by Rule of Judicial Administration 1901 and local rules promulgated pursuant to it. New Rule 230.2 is tailored to the needs of civil actions. It provides a complete procedure and a uniform statewide practice, preempting local rules. This rule was promulgated in response to the decision of the Supreme Court in Shop v. Eagle, 551 Pa. 360,710 A.2d 1104 (1998) in which the court held that "prejudice to the defendant as a result of delay in prosecution is required before a case may be dismissed pursuant to local rules implementing Rule of Judicial Administration 1901." Rule of Judicial Administration 1901(b) has been amended to accommodate the new rule of civil procedure. The general policy of the prompt disposition of matters set forth in subdivision (a) of that rule continues to be applicable. 11 Inactive Cases The purpose of Rule 230.2 is to eliminate inactive cases from the judicial system. ' The process is initiated by the court. After giving notice of intent to terminate an action for inactivity, the course of the procedure is with the parties. If the parties do not wish to pursue the case, they will take no action and "the Prothonotary shall enter an order as of course terminating the matter with prejudice for failure to prosecute." If a party wishes to pursue the matter, he or she will file a notice of intention to proceed and the action shall continue. a. Where the action has been terminated If the action is terminated when a party believes that it should not have been terminated, that party may proceed under Rule230(d) for relief from the order of termination. An example of such an occurrence might be the termination of a viable action when the aggrieved party did not receive the notice of intent to terminate and thus did not timely file the notice of intention to proceed. The timing of the filing of the petition to reinstate the action is important. If the petition is filed within thirty days of the entry of the order of termination on the docket, subdivision (d)(2) provides that the court must grant the petition and reinstate the action. If the petition is filed later than the thirty-day period, subdivision (d)(3) requires that the plaintiff must make a show in to the court that the petition was promptly filed and that there is a reasonable explanation or legitimate excuse both for the failure to file the notice of intention to proceed prior to the entry of the order of termination on the docket and for the failure to file the petition within the thirty-day period under subdivision (d)(2). B. Where the action has not been terminated An action which has not been terminated but which continues upon the filing of a notice of intention to proceed may have been the subject of inordinate delay. In such an instance, the aggrieved party may pursue the remedy of a common law non pros which exits independently of termination under Rule 230.2. OF THE r^c"? 2009 OCT 12 Pal c,. 02 ? ? u O • - 4W_ \.J ELEANOR M. KISH, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 06-2708 CIVIL ACTION LAW WILLIAM A. KISH, Defendant IN DIVORCE IN RE: PETITION FOR COURT APPROVAL TO WITHDRAW AS COUNSEL FOR PLAINTIFF ORDER OF COURT AND NOW, this jay of 2012, upon consideration of the Motion to Withdraw as Counsel for Plaintiff, the Rule to Show Cause, and no responses filed thereafter, the request of Elizabeth J. Saylor, Esquire, of the Law Offices of Peter J. Russo, P.C. for Court Approval to Withdraw as Counsel for the Plaintiff in the above-captioned matter is hereby GRANTED. BY COURT, J. Law Offices of Peter J. Russo, P.C. Elizabeth J. Saylor, Esquire/Peter J. Russo, Esquire 5006 E. Trindle Road, Suite 100 Mechanicsburg, PA 17050 t/ Eleanor M. Kish 1017 Walnut Street Lemoyne, PA 17043 j/ William A. Kish 50 Bonny Brook Rd Carlisle, PA 17013 &P,PS f aJed Ilao/?a Ln C_ ? w r N) = c.a -? cam ' n C C)-; e; 'ejw