HomeMy WebLinkAbout94-02310
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The court retains jurisdiction of the following claims which have ·
been railed of record In this action for which a final order has not yet -
been entered; None ·
The parties' Post Nuptial Jlgreerrent dated October 27, 1995/ is attached hereto :
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IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY
STATE OF '* PENNA.
.JENNIE L. LAVENDER,.
II
No.
2310
~.~'!.~.~"" 1994
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MICHAELA, LAVENDER,
DECREE IN
DIVORCE
AND NOW, . ~~, ~,'(.. . .... 19 ~,Clt II ordered and
decreed that..,.,.,.,..... .':H:~.I'H);;. H'.. ~1\.~~~P~,Il..,.,.",.... plaintiff,
and, , , ,. " , , ,. , . ., . . ., . , .. . ~,~~~~.~~. ~:. ,~~Y.E,~~~~. . , . , , . , , , . defendant.
are divorced from the bond. of matrimony.
II II .......... ..... II ..... ... ..... .,..... .... II. ..... .... .... .... .... ....,
,'!El .F?AA~~~,':~':! .~c;:I:t.~~~.!lP?n.!J!3. i!1~.IP,=l.r~.t~7)" ~,~ "1C!~ '~~~" .iAto
this Decree. .;'.. /
D y r h e 1'1'1"
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all property rights and all rights in, to or against each other's
property or estate, 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 maintenance and/or for spousal support, alimony pendente
lite, alimony, counsel fees and expenses, custody and equitable
distribution;
WHEREAS, Michael A. LavElnder is represented by Joanne H.
Clough, Esquire and Jennie L. Lavender is represented by stanley J.
A. Laskowski, Esquire, and each party has had the opportunity to
review this Agreement in its entirety; and
WHEREAS, ths parties intend this Agreement to be a full and
complete Postnuptial Agreement, providing for the absolute and
final ssttlement of all their respective marital and property
rights and all claims for spouse support, alimony pendente lite,
alimony, counsel feeb and expenses, and equitable distribution of
marital property.
NOW, THEREFORE, in consideration of the mutual benefits to be
derived by the parties and intending to be legally bound hereby,
the parties hereby covenant and aqree as followsl
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1, PERSONAL PROPERTY: HUSBAND warrants and represents to
WIFE, and WIFE warrants and represents to HUSBAND, that they have
effected a fair and equitable division of all marital property of
the parties, and that any and all marital property, except as
expre..ly provided herein, presently in possession of WIFE shall be
the property of WIFE, and that any and all marital property, except
as expressly provided herein, presently in possession of HUSBAND
shall be the property solely of HUSBAND.
2. ATTORNEYS FEES: Each party shall be responsible to pay
for his or her own counsel fees and other costs relating to this
Divorce action.
3. LIFE INSURANCE: HUSBAND and WIFE each agree to assume
sole responsibility for maintaining his or her own life insurance
coverage, and the cash surrender value, if any, of said policies
shall belong to the policy holder.
4. DEBTS AND INDEMNIFICATION: HUSBAND and WIFE represent
and warrant to each other that except as provided herein, neither
one has contracted or will in the future contract any debts,
charges, or liabilities whatsoever for which the other party or
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their property to their eetates shall or may be or become liable or
responsible, will at all times keep each other free, harmless and
indemnified against and from any and all debts and liabilities
heretofore or hereafter contracted or incurred by the other, except
as expressly provided in this Agreement.
5. MUTUAL RELEASE: Subject to the provisions of this
Agreement, each party has released, 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 cause of actions, claims,
rights or demands whatsoever, in law or equity, which either of the
parties ever had, now have, or can have at any time against the
other, specifically including rights or claims to spousal support,
alimony, alimony pendente lite, counsel fees and expenses, and
equitable distribution of marital property, except for any cause of
action for divorce from the bonds of matrimony and any cause of
action for breach of any provisions of this Agresmsnt.
The parties hereto expressly relinquish and waive any and all
rights that they may have now or in the future to claim
and/or obtain spouse support, alimony pendente lite, alimony,
counsel fees and expenses or equitable distribution of property.
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6. ESTATE RELEASE I Except as herein otherwise provided,
each party may di.pose of his or her property in any way, and each
party hereby waives and relinquishes any and all right. he or .he
may now have or hereafter acquire, under the pre.ent or future law.
of any juriSdiction, to shars in the property or the estate of the
other as a result of the marital relationship, including without
limitation,
dower, courtesy, statutory allowance,
widoW's
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allowance, right to take property under equitable distribution,
right to take in intestacy, right to take against the will of the
other, and right to act as administrator or executor of the other's
e.tate, and each will, at the request of the other, execute,
acknowledge, and deliver any and all instruments which may be
nece..ary or advi.able to carry into effect this mutual waiver end
relinquishment of all such interest, rights and claims.
7. SEPARATION I It shall be lawful for each party at all
time. hereafter to live separate and apart from the other party at
such place or places as he or she may from time to time choo.e or
determine fit.
8.
NO INTERFERENCE I
Each party shall be free from
interference, authority and control, direct and indirect, by the
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other as tully as it he or she were single and unmarried. Neither
shall molest the other, compel or endeavor to compel, the other to
cohabit or dwell with him or her, or to intertere with friendships,
society or acquaintances with either of the parties hereto may
choose or have from this day torward.
9. DOCUMENTS: Each party shall, at the request of the
other, execute, acknowledge and deliver to the other party any
documents which may be reasonably necessary to give full force and
ettect to this Aqreement.
10. INTENT TO FINALIZE DIVORCE: HUSBAND and WIFE agree to
each sign Affidavits of Consent to Divorce contemporaneously with
the execution of this Agreement. HUSBAND'S counsel shall
immediately prepare a vital statistics form and Praecipe to
Transmit Record and any other necessary documents and promptly file
the same to finalize this divorce action. A certified copy of said
Divorce Decree shall be forwarded to WIFE.
11. ABSOLUTE AND FINAL SETTLEMENT: The provisions of this
Agreement are intended to consider, determine and distribute all of
the assets ot the parties hereto as part of the terms of this
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pOBtnuptial Agreement. This Agreement is intended by the partie.
hereto to be a valid postnuptial Agreement, providing for the
abBolute and final settlement of their respective property rights
and all obligations of spouse support. This Agreement is not
intended to be a mere separation agreement. This Agreement
contains the entire understanding of the parties and there are no
representations, warranties, covenants or promises other than those
expressly set forth in this Agreement.
12. VOLUNTARY EXECUTION AND FAIRNESS OF AGREEMENT I Each
party acknowledges that this Agreement has been entered into of his
or her own violation, with full knowledge of the facts and full
information as to the legal rights, liabilities and the assets of
the other, and that each believes this Agreement to be reasonable
under the circumstances and not the result of any duress or undue
influence.
13. 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 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.
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14. SITUSI This Agreement shall be construed and governed in
accordance with the laws of the commonwealth of Pennsylvania.
15. INDEPENDENT SEPARATE COVENANTS I It is specifically
understood and agreed by and between the parties hereto that each
paragraph hereof shall be deemed to be a separate and independent
covenant and agreement.
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.
16. ENTRY AS PART OF DECREE I It is the intention of the
parties that this Agreement shall survive any action for divorce
which may be instituted or prosecuted by either party and no order,
judgment or decree of divorce (temporary, interlocutory, final or
permanent) shall affect or modify the financial terms of this
Agreement. This Agreement shall be incorporated by reference, but
not merged with any such judgment or decree of final divorce.
17. BREACH I If either party breaches any provision of this
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II 'I'D cou.'I' or OOIUIOI .LIU
CUO..LaIII) COUll'll, .....ILVUI.
10. IJ10-CIVIL-l".
CIVIL .C'I'IOIl - LaW
III DIVO.C.
"...1. L. LaftllD..,
'lat.atiff
KIClIIaIL .. LaV8ID..,
Defeaclaat
....CI.. ~ '1'.....1'1' RlCORD
To the Proth~notarYI
Pleaee tranemit the record, together with the following
info~ation, to the court for entry of a divorce decreel
1. Ground for divorce I
Irretrievable breakdown under
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section 3301(c) of the Divorce Code.
2. Date and manner of service of the Reinstated complaint I
United states certified Mail 'Z 069 897 312, Restricted Delivery,
Return Receipt Requested, on May 5, 1995, date of delivery and
receipt by Defendant being on May 6, 1995.
3. Date of execution of the Affidavits of Coneent required
by Section 3301(c) of the Divorce Codel by Plaintiff Jennie L.
Lavender on October 25, 19951 by Defendant Michael A. Lavender on
Octobsr 19, 1995.
4. Related claims pending I None.
5. Attached hereto is an original executed copy of the
parties' Property Settlement Agreement dated October 27, 1995
which is to be incorporated but not merged into the Decree in
Divorce.
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Stanley J.. , Esq.
KUNDRAT' EDOR
Attorney 1.0. '37422
1800 Linglestown Road, suite 304
Harrisburg, PA 17110
(717) 234-3911
Attorney for Plaintiff
07...1. L. ~nlD.., I 1M 'l'II. COUR'l' or COIlllO. .LIU
.1allltUf I CUIII.RUIIO COUll'l'Y, ....IYLYUIa
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v. I MO. 1310-civil-1"4
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MICDlL a. ~VIIID.R, I CIVIL aC'l'IOM - ~.
Defell4allt I 1M DIVO.CI
OIR'l'lrlca'l'l or .I.VIOI
I, stanley J. A. Laskowski, Eaquire, do hereby certify that
I have aarv.d a Praecipe to Transmit Record by placing a true and
correct co~y of aam. in the united statea mail, Firat Cla.a,
po.tage pr.paid thereon, on the -1-th Day of November 1995
addr....d to the following person(s):
Joanne Harrison Clough, Esquire
2201 N. Second street
Harrisburg, PA 17110
l<<JNDRAT , SEDOR
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Laskowski, Eaquir.
Attorney I. . No. 37422
1800 Linglestown Road
suite 304
Harrisburg, PA 17110
(717) 234-3911
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IIICIIUL a. Lann.l, I CIVIL AC'l'IOII - LaW
DereDIS.Dt I III DIVOIC.
NOTICE OF AVAILABILITY OF COUNSELING
TO THE WITHIN NAMED DEFENDANT:
You have been named as the Defendant in a divorce proceeding
filed in the Court of Common Pleas of Cumberland County,
Pennsylvania. This notice is to advise you that in accordance
with section 3202(d) of the Divorce Code, as amended, you may
request that the Court require you and your spouse to attend
marriage counseling prior to a Divorce Decree being handed down
by the Court. A list of professional marriage counselors is
available at the Domestic Relations Office, Cumberland county
Court House, 3 South Hanover Street, Carlisle, Pennsylvania.
You are advised that this list is kept as a convenience to you
and yeu are not bound to choose a counselor from the list. All
necessary arrangements and the cost of counseling services are to
be borne by you and your spouse.
If you deeire to pursue counseling, you must make your
request for counseling within twenty (20) days of the date on
which you receive this Notice. Failure to do so will constitute
a waiver of your right to request counseling.
Dated:
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Pr honotary of cu er and County
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J...I. L. LaVin.., I III '1'B. COU.'1' or COIUlO. 'UU
'laintiff I CUHI..LUID COUlft'V, .....VLVIIIIl
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V. I 110. Ci~11
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KICIlUL &. LaVin.., I CIVIL &C'l'10. - LaW
DefeDclaDt I III DIVO.C.
COM.LaIIlT
COUll'1' I. - Divorae
1. Plaintiff, Jennie L. Lavender, is an adult individual,
who currently resides at 635 Bosler Avenue, Lemoyne, Cumberland
county, Pennsylvania 17043.
2. Defendant, Michael A. Lavender, is an adult individual,
who currently resides at 1123 Valley Road, Marysville, Perry
county, Pennsylvania 17053.
3. Plaintiff and Defendant are bona fide residents of the
Commonwealth of Pennsylvania and have resided therein for a
period in excess of six months immediately previous to the filing
of this complaint.
4. Plaintiff and Defendant were married on July 27, 1991
in New CUmberland, Pennsylvania.
5. The marriage is irretrievably broken.
6. Defendant has offered such indignities to the person of
the Plaintiff, the innocent and injured spouse, as to render her
condition intolerable and life burdensome.
7. There have been no prior actions of divorce or for
annulment between the parties in this or any other jurisdiction,
B. Plaintiff has been advised that counseling is available
and that Plaintiff may have the right to request that the court
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and that Plaintiff may have the right to request that the court
require ths parties to participate in counseling.
WHEREFORE, the Plaintiff prays this Honorable Court enter a
Decree of Divorce.
COu.T II. - .aultable DivlsioD. DlstributioD aDd
a..iana.nt of K.ri~.l >>roD.r~v
9. The averments of paragraphs 1 through 8 above are
incorporated herein by reference as if set forth verbatim.
10. The parties are the owners of various items of personal
property and/or real property which qualify as marital property
as defined in Section 401 of the 1980 Divorce code, as amended.
11, said marital property is subject to equitable division,
distribution and assignment by the Court.
WHEREFORE, Plaintiff prays that this Honorable Court
equitably divide, distribute and assign all of the parties'
marital property.
Respectfully sUbmitted,
KUNDRAT , SEDOR
tEtA,,/J6..~L'
stanley JI ,I.'LaSkOWSki, Esq.
Attorney ~.O.f 37422
1800 LingleBtown Road
suite 304
Harrisburg, PA 17110
(717) 234-3911
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JlnII L. LaVlIIDI., I III T.I COU.T or ooNNOII 'LlAI
Plaintiff I CmmlRLaIID COUll'l'Y, '...IYLVAIIIA
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IIICDlL A. LaVlIIDI., I CIVIL ACTIO. - LaW
Defendant I III DIVO.CI
VlRIrICATIOII
I do hereby verify that the facte stated in the foregoing
complaint 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.A. section 4904 relating
to unsworn faleification to authorities.
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Datedl
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KICUlL A. LanllD.., . CIVIL ACI'IO. - LAW
DefelllSut . I. DIVOaC.
.L&IMI'I"'. ..'IDaVI" 0' CO...MI'
1. A Complaint in Divorce under section 3301(c) of the
Divorce Code was filed on May 2, 1994.
2. The marriage ot the Plaintiff and Detendant is
irretrievably broken, and ninety (90) days have elapsed fro. the
date of filing of the complaint.
3. I consent to the entry of a final decree of divorce.
4. I understand that I may lose rights concerning alimony,
division of property, lawyer's fees or expenses if I do not claim
them before a divorce is granted.
5. I have been advised of the availability of marriage
counseling, and understand that I may request that the Court
require that my spouse and I participate in counseling. I
further understand that the Court maintains a list of marriage
counselors in the Prothonotary's Office, which list is available
to .e upon request. Being so advised, I do not request that the
Court require that my spouse and I participate in counseling
prior to a divorce decree being handed down by the Court.
I verity that the statements made in this affidavit are true
and correct, I understand that false statements herein are made
subject to the penalties of 18 Pa. C.S. section 4904 relating to
unsworn falsification to authorities.
Dated:
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nie L. Lavender
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'I. I 10. 2310-civil-l".
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MICIlUL .. LaQIID.., I CIVIL AO'1'IOM - LaW
Defeadnt I 1M DlVoac.
CIRTlrlCATI or .laVIOI
I, the under.i9ned, hereby certify that I .erved a true and
correct c~rtified copy of Plaintiff's Reinstated Complaint in
Divorce upon Defendant Michael A. Lavender, by United states
Fir.t Class Mail, certified, return receipt requested, restricted
delivery, on May 5, 1995. The return receipt executed by
Defendant Michael A. Lavender dated May 6, 1995 is attached
hereto aarked as Exhibit "A" and incorporated herein by
reference.
Respectfully submitted,
KUNDRAT , SEDOR
~~L'
Date
5")J~ '15
. Laskowski, Esquire
Attorney .0. No. 37422
1800 Linglestown Road
suite 304
Harrisburg, PA 17110
(717) 234-3911
3...11 L. L&VlIDI.,
'lalDtUf
I. ~.I couat or COKMO. 'LI&I
CUIIIIRr.um COU1l'l'Y, .IIIIIIYLVDla
MO. 2310-clvll-1...
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.IOJIUL a. L&VlIIDI.,
Dafen4ut
CIVIL aCTIO. - LaW
1. DIVOaCI
'.~I~IO. ~ .RlVlMT DIIIIPATIOM or MARITAL ..IITI
AND NOW, come. plaintiff, Jennie Lavender, by her attorneys,
Kundrat' Sedor, and files within Petition for Injunctive and
other Relief and in support thereof respectfully avers as
follows:
1. Petitioner, Jennie L. Lavender, who resides at 635
Bosler Avenue, Lemoyne, cumberland county, pennsylvania 170.3 is
Plaintiff in above captioned divorce action.
2. Re.pondent, Michael A. Lavender, whose last known
address was 330 N. 30th street, camp Hill, Pennsylvania, 17011 is
Defendant in above captioned divorce action.
3. Plaintiff filed a Complaint in Divorce on May 2, 1994
reque.ting relief, including a request for equitable
distribution.
4. During the course of the parties marriags, various
marital and non-marital personal property was acquired and u.ed
by the partie., inoluding but not limited to, various furniture,
kitchen applianoes, household goods and furnishings.
5. Defendant has taken such marital and non-marital
personal property and has ooncealed its whereabouts.
6. Defendant has refused the return of the marital and non-
marital personal property and oonoealed its whereabouts.
.
7. Plaintiff ha. not had acce.. to the property nor known
of it. whereebout. .ince the partie. separation on November 13,
1993.
8. Ba.ed upon defendant's action., Plaintiff believe. that
Defendant h.. re.oved or will remove the marital property fro.
the coaaonwealth of Pennsylvania, .ell or otherwiae diapoae the
property or aecret it in order to defeat the Plaintiff'a clai.
for equitable di.tribution of the marital property or otherwia.
prevent Plaintiff from lawfully posseasing non-marital property
to which ahe ia entitled.
9. Plaintiff further believes that Defendant will
diaaipate, alienate or encumber the marital property he took or
other .arital property.
10. Pursuant to 23 Pa.C.B.A. Bection 3323(f) an injunction
or other order .ay iaaue which is nece..ary to protect inter.ata
of the partiea and .ay grant .uch relief or re.edy aa equity and
juetice require a9ainat eithor party or a9ainat any third pereon
over who. the court ha. juriediction and who ia involved in or
concerned with the disposition of the property retained and
concealed by Defendant.
11. Plaintiff is not able to ascertain the whereabouta of
the parties marital personal property due to Defendant'.
conceal.ent of aa.e.
12. Plaintiff has not been able to oxamine, inventory or
appraise such personal property due to its concealment in order
to determine her rights to its equitable division.
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07...1. L. LanIIDI., I I. '1'8. COURT or COIOlO. .UU
.ial.tiff I CUIIB.RLMlD COURY, ....IYLVAIIIA
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v. I MO. IJ10-civil-1..4
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MICllUL a. LanllDla, I CIVIL aCTIO. - LA.
Def.....t I I. DIVORCI
CI.'l'I.IC&'l'1 O' IIRVICI
I, Stanley J. A. Laskowski, Esquire, do hereby certify that
I .erved . p.tition to prevent Dissipation of Marital Asset. by
placinq a true and correct copy of same in the United state.
a.il, Fir.t Cl..., po.t.qe prepaid ther.on, on the ~th Day of
July 1995 .ddr....d to the followinq personCs):
Michael A. Lavender
330 North 30th street
Caap Hill, PA 17011
l(U~D5fs' SEDOR.
" .~ - "
Stanley . Laskow.ki,
Attorney . No. 37422
1800 Linqlestown Road
suite 304
Harrisburq, PA 17110
(717) 234-3911
IN THE COURT OF COMMON PI.EAS OF CUMBER1.AND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
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FUe No. ' ,)/L' ( 11,", /<1' 'I
IN DIVORCE
NOTICE TO RESUME PRIOR SURNAME
Notice is hereby given that the Plaintiff/Defendant in the
above matter, having been granted a Final Decree in Divorce on the
Ifllt'\ day of /')o"\,,,J""1 ,19 '/',. . hereby elects to resume the
prior surname of, If \ .\' ," \''111'' , and gives
this written notice pursuant to the provisions of 54 P.S. S 704.
DATE: ..,- IL - 'h"
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Signature
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being resumed
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Signature of name
COMMONWEALTII OF PENNSYLVANIA:
55.
COUNTY OF CUMBERLAND
If, 11 (t;
On the u day of ('-1c1U , 19~, before me, a
Notary Public, personally appeared tlhe 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, 1 have hereunto Bct my hand and official
scal.
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