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HomeMy WebLinkAbout94-05799 L. '-I ?-- Ji . j ~l I b ' g '\ \ I (, 1< . I J I J 0'- ()--. C'- lc) ,1 ~' . --.. ,.-,--. ~ -'.-'-'--~ _.."_.-, ~~_. ~ ---,,<- -, '- -._~.~~-~.-,. ~: .. ~ ( II' ! . . 8; 8i ,I 81 I 81 *1 *1 .i .! * . .. . 8 , . - , . . t , . . . 8 . 8 , . . . . II t-_~-_- , . CArl .. .,. .. ... ._.. '.. .. ... ."".,., AC' ;,C. .IC- '11.-_ .:,c. l< .*'.__''-.'. ,W - -'-'1l . ..... .._---~...'---- . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNSYLVANIA DAVID R. DRAYER. I , N ll. 94::.?79?..... ................. 19 . .1 I I Plaintiff Versus GWRIA J. DRAYER, Defendant DECREE IN DIVORCE ~ '2...' '1' AND NOW. . .. .. . .. . . . .. .. .. . . . . . . . ' . . " 19....... it is ordered and decreed that .......... DAV1!? R: . DRAYER. . . . . . .. , .. .. .. .. .. .. '" plaintiH, and. .. . .. . . .. .. . . . .. . 9.[JJ.R.IA .J.,. P~YER . . . . .... , .... ...... .,. defendant. or. divorced from the bonds of matrimony. The court retains jurisdiction of the following claims which have been raised of ~rc~d in this action for which a final order has not yet been entered; lfo.AJ"~ The part ies entered into a Settleroont Agreement dated Septerrber 30, 1997 . . . .. ............ ...................,.....,....,................... - . . . ~ . .wtach.resoLves all c1ailrs and which is incorp;>rated but not rrerged into 'hi, Ol='~ ~"~. n, ( )? .. .. .. .. .. . .. .. .. .. . ~/ All..t' cj rt . \./L" .~ . .. .... "'j' .......: 1.."'4,,('( r , tUURo:,. P~t:t.I1.~ . ~.u~"l. K ~tf, {hf .I . ~/7 Proth~nol.ry . , - ..~ --- _._~_. ._, "'-- ---- * .. ,0,;, ;0.:. ... .lOt. .<It' -lOC' ...' ..' ,., -lO:' 110__._ 8 . ~ . , . .. . . 8 , . . t . . - I . i .. . . I . . . . . j . . . 8 - 8 ; VI. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO, 94-5799 ClVIL TERM DAVID R. DRA VIR, i'I...wr GLORIA J. DRA VIR, Def.ad.at : IN DIVORCE PRAECIPE To The Prothonotary: Kindly enter into the docket the attached original Separation and Marriage Property Settlement Agreement, dated September 30, 1997, executed by the parties, Dated: ,rtf (; CJcr '17 1,,- A MARIE COYNE , 90 I Market Street Camp Hill, PA 17011-4227 (717)737-0464 Pa, S, Ct. No, 53788 Attorney For Defendant cc: Joseph Hitchings. Esquire . . , " . 4, A resolution of all marital responsibilities, rights, and all other claims and possible claims srowing Oul of the rrIlIJTiage relationship; and WHEREAS, the parties herelo, after being properly advised by their respective counsel, Wife by her anorney, Lisa Marie Coyne, Esquire, and Husband by his allomey, Joseph Hitchings, Esquire, The parties acknowledge thaI each has received indcpendenllegal advice from counsel of their selection and Ihat they have been fully infonned as 10 their legal rights and obligations, including all rights available 10 them under the Pennsylvania Divcrce Code of 1980, as amended, and other applicable law. Each party confmns thaI he or she fully understands the lerms, conditions and provisions of this Agreemetll and believes them 10 be fair, JUSI, adequale and reasonable under the existing facts and circumstances. The parties further confmn thaI each is enlering inlo this Agreemenl frtely and volunlarily and that execution of the Agreement is not Ihe result of any duress, undue influence, collusion or improper or illegal agreements, NOW, TIlEREFORE, in consideration of the above recitals and the fellowing covenants and promises mutually made and mutually to be kept the parties heretofore, intending 10 be legally boWld and to legally bind their heirs, successors, and assigns thereby, covenant, promise, and agree as follows: 1. SEPAR\TION: It shall be lawful for each party at all times hereafter to live separale and apart from each other at such place or places as he or she may from time 10 time choose or deem fit. 2. INTERFERENCE: Each party shall be free from inlerference, authority and contact by the other, as fully as if he or she were single and unmarried, except as may be necessary to carry oul the provisions of this Agreement. Neither party shall molesl the other nor allempl to endeavor 10 molesl the other, nor compellhe other 10 cohabil with the other, nor in 2 " " . 1WD PenOD AJaumlall ResDoDslblUtv 6. Nationwide Mutuallnsurance (Homeowner's) Wlf, Each party alll'tes to pay the outstanding joint debts set forth herein and further alll'ees to indemnify and save harmless the other from any and all claims and demands madt against tither of them by reason of such debts or obligations, 6, l\fUTUAL RELEASE: Subject to the provisions of this Agreement, each party waives his or her righlS to alimony and any further distribution of property inasmuch as the parties hereto alll''' that this Alll'eement provides for an equitable distribution of their marital property in accordance with the Divorce Code 1980, as amended, Subj~ctto the provisions of this Alll'eement, each party has released and discharged, and by this Alll'eement does for llimself or herself, and his or her heirs, legal representatives, executors, administrators, and assigns, release and discl1arge the other of and from all causes of action, claims, rights or demands wl1alsoever in law or tquity which either of the parties ever had or now have against the other, 7, CUSTODY AND VISITATION: The pllrties' minor child shall be in the except any or all cause or causes of action for divorce and except in any or all causes of action for divorce and except in any or all causes of action for breach of any provision of this Alll'eernenl. Each party also waives his or her right to request marital counseling pursuant to 23 Pa, C.S.A. Section 3302, permanent care and custody of the Mother, with whom Elizabeth now resides, The Father shall have righlS of visitation with said minor child on alternating weekends as shall be mutually alll'teable to the parties and the child and alternating Holidays defined as: Easter, Thanksgiving, Christtnas. The Father shall hav: visitation with said minor child on Father's Day and on the 4 child's Birthday, Father shall have periods of summer visitation with child as long as child is willing and agreeable, During Father's visitation with child, he shall be sober and not consume alcohol. Further, Father shall not transport child in a motor vehicle unless Father is sober, There shan be no ovemight visitation with Father unless and until Father becomes married or no longer cohabits with a woman, The parties shall continue to consult with each other concerning their child's care, education, and general welfare, their child's best interest being at all times the paramount consideration of the parties. Should the parties fail to reach an agreement concerning their child's care, tducation, and general welfare, the Mother's decision and position shall be governing, 8, CHILD StJPPORT: Father shall continuously maintain child on Father's health/hospitalizationlmedical insurance offered by Father's employer. In addition to child support ordered pursuant to an order of support issued through the Cumberland County, Pennsylvania Domestic Relations Section of the Court of Common Pleas No, 931 of 1994 (DR No, 23115), or their successor or assign, and commencing November I, 1996,Fathtr shall pay to the Mother one half (112) of child's uninsured and unreimbursed medical expenses to include, but not limited to, office visits, dental and orthodontia work, counseling, eye glasses and eye exams, prescription and non-prescription medications. Mother shall submit to Father monthly statements of costs and expenses with Father's payment to Mother due seven (7) days &om presentation of the said statement. Further, upon the issuance of a final decree in divorce, Mother shan communicate to tho Office of the Domestic Relations requesting that Father receive an immediate credit for remaining mearage balance of support as established in the Order of Court, dated Febl1llUY 4, 1997, 5 9, EDUCATIONAL EXPENSES: The parties agree to provide appropria:e educational opportunities for their only child. including an undergraduate college education, post-graduate training, and txtracurricular lessons and activities, The father agrees to participate in the cost of such tducation to the extent of his then existing financial resources such participation in the education costs for the child will be after consideration of any J/Udlnt loans, scholarships, or grants which the child may recei~-e, The parents shall make a college education available to Elizabeth provided that she demonstrates readiness, ability and motivation to secure the benefits of a higher education, The cost of undergraduate college education includes but not limited to the following: tuition, room, board, books, supplies, fees, lab expenses, transportation, clothing, equipment, and telephone calls from Elizabeth to the parents, The Father agrees 10 pay the cost of such education evtn though the cost may be incurred after the child reaches majority age and shall continue until the child graduates from an undergraduate college or !ride or vocational school or reaches the age of twenty-five (25), whichever occurs first. 10, EOUlTABLE DISTRIBUTION OF MARITAL PROPERTY. The parties have attempted to distribute their marital property in a manner which conforms to the criteria act forth in 23 Pa, C,S.A, Section 3501, el, seq" and taking into account the following considerations: the length of marriage; the fact that it is the first marriage for Wife and lirst marriage for Husband; the age, health, station, amount and sources of income, vocational skills, employability, estate, liabilities and needs of each of the parties; the contribution of each party 10 the education, training for increased earnings power of the other party; the opportunity of tach party for future acquisitions of capital assets and income; the sources of income or of both parties, including but not limited to medical, retirement, insurance or other benefits; the contribution or dissipation of each party in the acquisition, preservation, depreciation or 6 appreciation of the marital property, including the contribution of each spouse as a homemaker; the value of the property set apan to each party; the standard of iiving that the panics established in the marriage; and !he tconomic circumstances of each party at the time !he division of property is to become effective, The division of e~isling marital property is not intended by !he panics to constitute in any way sale or e~change of assets, and the division is being effected wi!hout !he introduction of outside funds or other property not constituting marital property. The division of property under !his AgreemtnlShall be in fuli satisfaction of all marital rights of !he panics. A, DISTRIBUTION OF PERSONAL PROPERTY: The panics hereto mutually agree that they have affected a satisfactory division of the furniture, household furnishings, appliances and o!her household personal property between !hem and !hey mutually agree that each party shall from and after the date hereof be the sole and separate owner of all such tangible personal property presently in his or her possession, and this Agreement shall have effect of an assignment or bill of sale from each party to the other for such property as may be in !he individual possession of each of !he panics hereto. The parties hereto have divided between themselves to their mutual satisfaction, all items of tangible and intangible marital property, Neither party shall make any claims to any such items of marilal property, or of the separate personal property of each other, which is now in the possession and/or under the control of the other, Should it become necessary, the parties each agree to sign, upon request, any titles or documents necessary to give effect to this paragraph. Property shall be deemed in the possession or under the control of tither party if, in the case of tangible personal property, the item is physicaliy in the possession or control of the party at the time of the signing of this Agreement and, in the case of intangible personal 7 property, if any physical or written evidence of ownership, such as passbook, checkbook, policy or certificate of deposit or other similar writing is in the possession or control of the party. Husband and Wife shall each be deemed to be in the possession and control of his or her own individual pension or other tmployee benefits, plans or retirement benefits in any nature with the exception of Social Security Benefits to which either party may have a vested or contingent right or interest at the time of the signing of this All!eemenl. As part of the property settlement, the Wife shall pay to the Husband the sum of Twelve Thousand Dollars ($12,000.00), Payment ofTen Thousand Dollars ($10,000.00) to be paid by Wife upon issuance of Final Decree in Divorce, Balance of Two Thousand Dollars (S2,OOO,OO) to be paid by Wife in $500.00 payments once every six months after issuance of Final Decree in Divorce, From and after the date of the signing of this Agreement, both parties shall have the complete freedom of disposition as to his or her separate property and any property which is in their possession or control pursuant to this Agreement and may mortgage, sell, grant, convey, or otherwise tncumber or dispose of such property, whether real or personal, whether such property was acquired before, during or after marriage and neither Husband nor Wife need join in, consent to, or acknowledge any deed, mortgage or other instrument of the other pertaining to such disposition of property. It is further agreed that Husband shall remove within seven (7) days of the signing of this Agreement his motorcycle and three (3) boxes of personal belongings which are located in the garage at 520 South Third Street, Lemoyne, Pennsylvania, the marital residence, If Husband fails to remove the said property by the specified date, then the it shall be ÿ deemed that Husband forfeits the property to the Wife and the property shall be deemed to be the sole property of the Wife. It is specifically agreed that Husband will rtmove from garage the 8 " containers of used motor oil which he has stored therein, If Husband fails to remove the containers of used motor oil within thirtY 130\ days of the signing of this Agreement, Wife may remove the containers of used motor oil and Husband shall be responsible for any removal costs incurred by Wife, B, DISTRIBUTION OF REAL ESTATE: It is understood and agreed that the parties are the joint owners of certain real estate located at 520 South Third Street, Lemoyne, Cumberland County, Pennsylvania, Husband agrees that as part of this property settlement, Husband will to transfer to Wife immediately upon signing of this Agreement. all of his interest and title to the marital home known as 520 South Third Street, Lemoyne, Cumberland County, Pennsylvania free of all encumbrances e:'tcept that of the outstanding Harris Savings Bank Mortgage Account No, 103001223 which the Wife agrees to assume and to pay, and that the Husband will execute and deliver a deed conveying Husband's interest in said property to the Wife upon the signing of this Agreement, It is also agreed that the parties jointly own four (4) grave plots in Rolling Green Cemetery, The parties agree to evenly divide the grave plots so that Husband receives two (2) grave plots and Wife receives two (2) grave plots, C. TAX LIABILITY: The parties believe and agree that the division of property heretofore made by this Agreement is a non-la:c:able division of property between co- owners rather than a la:c:able sale or exchange of such property, Each party promises not to take any position witt. rtspect to the adjusted basis of the property assigned to him or her or with respect to any other issues which is inconsistent with the pos~tions set forth in the preceding sentences on his or her Federal or State Income Tax Return, 9 " II. MOTOR VEmCLES: With respect to the motor vehicles owned by the parties, they allfCC that each motor vehicle titled in the Husband's name shall be the exclusive property of the Husband, With respect to the motor vehicles owned by the Wife, the parties agree that tach motor vehicle titltd exclusively in the name of Wife shall be the exclusive property of the Wife, 12. HEAL Tn INSURANCE: After the date of entry of the Decree In Divorce, the pBrties shall be responsible for obtaining their own individual health insurance coverage and the payment of their own mtdical debts, 13, ALIMONY: Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property arc fair, adequate and satisfactory to them and arc accepted by them in lieu of a full and final selllement and satisfaction of any claims or demands that either may now or hereinafier have against the other for support, maintenance, or alimony, Husband and Wife further, voluntarily and intelligently, waive and relinquish any right to seck from the other any payment for support or alimony, 14, ALIMONY PENDENTE LITE, COUNSEL FEES. AND EXPENSES: Husband and Wife acknowledge and agree that the provisions of this Agreement providing for the equitable distribution of marital property of the parties arc fair, adequate and satisfactory to them. Both parties agree to accept the provisions set forth in this Agreement in lieu of and in full and rmal senlernent and satisfaction of all claims and demands that either may now or hereafter have against the other for alimony pendente lite, counsel fees or expenses or any other provision for their support and maintenance before, during, and afier the commencement of these proceedings for divorce or annulment between the parties, 'I 10 IS, INCOME TAX PRIOR RETURNS: The parties have hereunto filed ,ertaia joinl Income Tax Returns through and including Tax Year 1991. Husband represents and warrants 10 the Wife that he has heretofore duly paid all Income T i1Xes due on such returns; and he docs not owe any interest or penalties with respect thereto; and that no tax defi,iency is pending or threatened against him; and that no audit is pending with respect to any su,h relUm. If there is any deficien,y assessment. on any of the aforesaid relUms, the Husband shall give Wife immediate notice thereof, in writing, The Husband further warrants that he shall pay the amount ultimately determined to be due, togtther with interest and penalties, if any, as well as all expenses that may be in,urred if he de,ides to ,bntest the assessment. Further, regarding the 1991 Income Tax Returns, the parties agree that any refund(s) due from tht'Se return(s) shall be divided one-half to Husband and one-half to Wife, 16, LIFE INSURANCE: The Father agrees to designate the daughter, Elizabeth S. Drayer, as the irrcvoc:able, Fifty percent (50%) primary beneficiary of the whole life insuran,e policy from American General Life insuring the life of the Father which was purchased during th~ course of the parties' marriage. This policy has a fa,e amount of :550,000.00, The Father's obligation to maintain the poli,y and pay the premiums and retain the said beneficiary shall terminate at such time as Elizabeth S, Drayer's nonnal edu,ational requirements, including undergraduate ,allege and or vocational training is concluded or Elizabeth S. Drayer reaches the age of Twenty-five (25) years of age, whi,hever occurs last. So long as the parties arc bound under this paragraph, Father shall: a. Simultaneously with the execution of this Agreement. the Husband shall designate Elizabeth S, Drayer as the Fifty (50%) Percent irrevocable primary 11 ( beneficiary of the entire proceeds of the said policy with the face amount of Fifty Thousand Dollars ($50,000,00). b, The Husband shall at all times keep the aforementioned policy in full force and tffect and shall promptly pay any and all dues, prtmiums and assessments thereon. Husband, further, shall not convert, borrow against, pledge or tIIcumber said ~olicy, c. Within Thirty (30) days of the execution of this Agreement, Husband shall provide proof satisfactory to the Wife that he has taken all sttps necessary to cause the insurance company issuing the aforementioned insurance policies to forward duplicated premium receipts to the Wife and Husband shall provide Wife with the name, address, and telephone number of insurance broker for the policy, d. If Husband defaults in the payment of dues, premiums or assessments on the aforementioned policies, the Wife shall have the option, but not the obligation, to pay the same, In the event that the Wife elects to make such paymtllts, the Husband shall forthwith become liable to Wife for the aggregate of such payments made by the Wife, e, If the aforementioned life insurance policies are not in full force and tffect at the time of the Husband's death, or, if for any reason the Child does not receive the proceeds thereof that child is entitled to under this paragraph, then the Child and or the Wife shall have a creditor's claim against the Husband's estate in an amount equal 10 the insurance proceeds Child should 12 '. have received under the provisions of this paragraph, namely Twenty-Five Thousand Dollars ($2S,OOO,OO), (, Notwithstanding any other provision of this Agreement, it is understood and agrted by and between the parties that any insurance proceeds payable in the event of the Husband's death in excess of Twenty-five Thousand Dollars ($2S,OOO,OO) shall be payable to such beneficiary or beneficiaries as the Husband might select. 17. WAIVERS OF CLAIMS AGAINST ESTATES: Except as herein otherwise provided, each party may dispose of his or her 'property in any way, and each party hereby waives and relinquishes any and all rights he or she may now have or thereafter acquire, under the present or future laws of any jurisdiction, to share in the property of the estate of the other as a result of the marital relationship, including without limitation, dower, curtsey, statutory allowance, widow's allowance, right to take intestacy, right to take against the will of the other, and right to act as Administrator or Executor of the other's estate, Each will, at the request of the other, execute, acknowledge, and deliver any and all instruments which may be necessary or advisable to carry into effect this mutual waiver and relinquishment of all such interest, rights, and claims, 18, MUTUAL CONSENT DIVORCE: The parties agree and acknowledge that their marriage is irretrievably broken, that they do not desile marital counstling, and that they both consent to the entry of a Decree in Divorce pursuant to 23 Pa. C,S,A, Section 3301(c), Accordingly, both parties agree to forthwith execute such consents, affidavits, or other documents and to direct their respective attorneys to forthwith file consents, affidavits, or other document, as may be necessary to promptly proceed to obtain a divorce pursuant to said Section \3 " " 23 Pa, C,S,A, Section 330I{c). Upon request to the extent permitted by law and the applicable Rules of Civil Procedure, the namtd Defendant in such divorce action shall execute any waivers of notice or other waivers necessary to expedite such divorce, It is the intention of the parties that the Agreement shall survive any action for divorce which may be instituted or prosecuted by either party and no Order, Judgment or Decree In Divorce, temporary, fmal or permanent ~hall affect or modify the financial terms of this Agreement. This Agreement shall be incorporated but shalt not be merged with said Judgment or Decree of Final Divorce, but shall be incorporated for the purpose of enforcement only, 19, BREACH AND ENFORCEMENT: If either party 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 Agreement shall be responsible for payment of attorney fees, legal fees and costs incurred by the other in enforcing his or her rights under this Agreement. 20, ADDmONAL INSTRUMENTS: 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. 21. HEIRSfBANKRUPTCY: All financial obligations undertaken by the Husband shall be binding upon his heirs, executors, administrators, successors and assigns, and shall constitute a charge against the Husband's tstate. It is further acknowledged alld agreed that said payments are child support payments and are not intended by the parties to be debts which may be discharged in bankruptcy, 14 " .' '. 22, TAX ADVICE: Both parties hertto hereby acknowledge and agree that they have had the opportunity to retain their own accountants, certified public accountants, tax advisor, or talt attorney with Icference to talt implications of this Agreement. Further neither party has been given any tu advice whatsoever by their respective attorneys, Further, both parties hcrtby acknowledge that they have been advised, by their respective attorneys, if any, to seek their own independent ta:< advice by retaining an accountant, certified public accountant, tax attorney, or talt advisor with reference to the talt implications involved in this Agreement. Further, the parties acknowledge and agree that their signatures to this Agreement serve as their acknowledgment that they have read this particular paragraph and have had the opportunity to seek independent talt advice. 23, VOLUNTARY EXECUTION: The provisions of this Agreement and their legal effect have been fully explained to the parties by their respective counsel, and each party acknowledgts that the Agreement is fair and equitable, that it is being entered into voluntarily, with the full knowledge of the assets of both parties, and that it is not the result of any duress or undue influence, The parties acknowledge that they have been furnished with all infonnation related to the fmancial affairs of the other which has been requested by each of them or by their respective counsel. 24, ENTIRE AGREEMENT: This Agreement contains the entire understanding of the parties. There are no representations, warranties, covenants, or undertakings other than those expressly set forth herein. Husband and Wife acknowledge and agree that the provisions of this Agreement with respect to the distribution and division of marital and separate property are fair, equitable and satisfactory to them based on the length of their marriage and other relevant factors which have been taken into consideration by the parties, Both parties hereby accept the 15 , ' 29, INDEPENDENT AND SEPARATE COVENANTS: It is specifically understood and agretd by and between the parties hereto that each paragraph hereof shall be deemed to be separate and independent covenant and agreement. 30. APPLICABLE LAW: This Agreement shall be construed under the laws of the Commonwealth of PeMsylvania. 31. VOID CLAUSES: If any tenn, condition, clause, or provision of this Agreement shall be detennined or declared to be void or invalid in law or otherwise, then only that tenn, 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, 32, AGREEMENT BINDING ON HEIRS: This Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors, and assigns, IN WfTNESS WHEREOF, the parties hereto have set their hands and seats the day and GL~~i.lYi~O-t..l -e-_ ~-Y/1A~ , R.DRAYER (SEAL) (SEAL) 17 ~~,",,,,,,,",,~h , , . COMMONWEALTH OF PENNSYLVANIA ) ) 55: COUNTY OF CUMBERLAND ) On the ;t;^'f' day of S'A~ . 19?7. before me, the subscriber, a Notary Public for the COmnlonwealth ofPcMsylvania, residing in the County of Cumberland, penonally appeared before me GLORIA J. DRA YER and in due fonn of law acknowledged the above Agreemenllo be her acl and deed. ;!:;~/f~ 4. ~~ ~ NOl4ry Public ~ NOTA _AI SIAL IIIlI!H .. COYNE Hotaty PI. Hampdt. r..p.. Cu..borlaftd bIc M~ Comm'",on r.pI,.. J\In. ~~A .J 18 . '. . . ... .. . . COMMONWEALTH OF PENNSYLVANIA ) ) 58: COUNTY OF CUMBERLAND ) On the ~~\)(\laY of ~\ ~\~ I.'^-_ . 19n before me, the subscriber, a Notary Public for the Commonwealth of PeMsylvania, residina in the County of Cumberland, personally appeared before me DAJIlD R. DRAYER and in due form of law acknowledaed the above Agreement to be his act and deed. ~"'~ ~.. . Notary Public ~ NO rAAIAl SEAL DIANNE lENIG, Notary Public lemoyne Borough Cumberland Co, My Commission Expires Dee, 21, 1997 19 ,.. ., {' ~ ll: ',' "'''~ I , I t': .~... { .... ( , ( , (,..- LI r- i C; (,J' CJ . .' . DAVID R. OHMER, 1:-1 '!liE caJR'I' Of CCMaI PLEAS Of C\..MBERtAND caJNrY, PE1'<'NSYLVA.'lIA PlaintiH NO, CIVIL 19 94-5799 vs, GLORIA J, DRAYER, Defendant PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a di'/orce decree: 1. Grounds for divorce: irretrievable breakdown under Section 3301 (c) ~ of the Divorce Code. (Strike out inapplicable section) 2. Date and l1'anner of service of the ccmplaint: Service on Defendant's counsel, Lisa Marie Coyne, Esquire. on October 18. 1994, Acceptance of Service filed 3. Ccmplete either Paragraph A, or B. October 21, 1994. A. Date of execution of the affidavit of consent required by Section 3301 (cl of the Divorce Code: by the plaintiff September 30. 1997 by the defendant October 6, 1997 B, (1) Date of execution of the plaintiff's affidavit required by Section 3301 (d) of the Divorce Code: (2) Da~e of service of the plaintiff's affidavit upon the defendant: 4. Related claims pending: 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under Section 33Ql (d)(l)(i) of the Divorce Code Waiver of Notice signed by the Defendant on October 6, 1997 and filed concurrently herewith. i LAW OfPlCU JOtDlSON.oDUF~E, STeW ART II WEIDNElt " " ~'--' ~ " ".n. ....... s.- r,. Co .... lot ~I"" ~ 11Q4)'()1~ TaIophoae ('111) 7~ . T.IocoP\.. (111) 16WOlf -_.--_._~'-_.+ DA VID R. DRAYER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 9~" j 111 (It tlt t.J gv IN DIVORCE Plainlitl' vs. GLORIA], DRAYER, Defendant NonCE TO DEFEND AND CLAIM RIGIITIi You have been sued In coun, If you wish to defend aaainst the claims set forth in the followina pqes, you must take prompt action, You are warned that if you fail to do so, the case may proceed without you and a decree 0 divorce or annulment may be entered against you by the coun, A judgment may also be entered against you for any other claim or relief requested in these paaes by the Plaintiff, You may lose money or property or other riaJIts important to you, includina custody or visitation of your children, When the around for the divorce is indignities or irretrievable breakdown of the marriage, you may request marriaae counselina. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Carlisle, Pennsylvania, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OIl EXPENSES BEFORE THE 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 Nar HAVBA LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTII BELOW TO FJNI) OUT WHERE YOU CAN GET LEGAL HELP, Coun Administrator Cumberland County Courthouse I Courthouse Square Carlisle. PA 17013.3387 Telephone: (717) 240-6200 1l99999-000JIIAu.....JI,l9941ILH/MH/JnI4 DA VID R. DRAYER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. Plaintiff VI. IN DIVORCE GLORIA J, DRAYER, Defendant COMPLAINT IN DIVORCE UNDER SECTIONS 330llcl OR 33011d) OF THE DIVORCE CODE AND NOW, comes the Plaintiff, David R. Drayer, by his altOrneys, Johnson, Duffle, Stewart" Weidner, and flies this Complaint in Divorce of which the following is a statement: I, The Plaintiff, David R, Drayer, is an adult individual residing at 320 Juniper Drive, Etters, Yorlt County, Pennsylvania, 2, The Defendant, Gloria J. Drayer, is an adult individu&l residing aI 520 Soulb Third Street, Lemo}'llll, Cumberland County, Pennsylvania, 3, The Plaintiff and Defendant have been 110na fide residents in the Commonwealth for allwt six montha previous 10 the filing of this Complaint. 4, The Plaintiff and Defendant were married on November 16, 1974, in New Cumberland, Cumberlaad County, Pennsylvania and separated on or about April 16, 1994, 5, There have been no prior actions for divorce or annulment between the parties. 6, The Plaintiff has been advised of the availability of marriage counseling and Iballbe Plaintiff may have die right 10 request thai the Court require the parties 10 participate in counseling. 09999'l 000311""1"'" 31, 19941ILH/,MH/JTII4 7, The marrlaae Is irretrievably broken. WHEREFORE, PIaInIiff requeats this Honorable Court 10 enter a dllCree of divorce 10 Plalnliff and Defendant II il they bad never been married. JOHNSON, DUFFIE, STEWART oft WEIDNER / Date:{ () - (, - <; "/ L" jJ.1J~ Joseph L. HitchIngs - ~ Attorney I,D. No, 65551 30 I Market Street P,O, Boll 109 Lemoyne, PA 1704HlI09 Te\ephone (717) 761-4540 Attorneys for Plaintiff B' I verify that the Slatementa made in this Complaint are lrue and corrCl:t 10 the beat of my bIowledJe, information and belief, I understand that false statements made herein are made subject to the penaltl. of 18 h. C,S.A 14904, relatinJIo unsworn falsification to authorities. Date: a) tP, ;<;9Y , (/lY/?d~ David R. Drayer _l:. " 099999-0003I1Aullult J I, 1994/ILH/~H/3nI4 . . DA VID R, DRAYER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, Plaintiff vs. IN DIVORCE GLORIA J. DRAYER, Defendant AmDA VIT DAVID R. DRAYER, beina duly sworn accordinato law, d~poses and says: 1. I !.ave been IIdvised of the availability of marrlaa. counsellna and understand thall may request that the court require that my spouse and I participate In counseling, 2, I understand that the court mainlains a list of marriage counselors in the Prothonotary's Office, which list is available to me upon request, ], Beina so advised, I do not r~quest that the court requir~ that my spouse and I participate in counselina prior to a divorce decree being handed down hy the court. I verify that the slatemer.ts mad~ In this Affidavit ar~ lrue and correct. I understand that false statements herein are made subject to the pen:.lties of 18 Pa,C,S, G4904, relating to unsworn falsification to authorities. Date: ()t'"cl 6. 19YY / 62~/k:4/U~ David R. Drayer / , . Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA NO. 94-5799 CIVIL TERM CIVIL ACTION - LAW DAVID R. DRAYER, V, GLORIA J, DRAYER, IN DIVORCE Defendant AFRDAVIT OF CONSENT 1. A Complaint In divorce under Section 3301(c) of the Divorce Code was filed on October 11, 1994, 2, The marriage of Plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of filing the Complaint. 3, I consent to the entry of a final decree in divorce after service of notice of Intention to request entry of the decree, 4. I have been advised of the availability of marriage counseling, understand that the Court maintal11S a list of marridge counselors and that I may request the Court require my spouse and I to part!dpate in counseling and, being so advised, I do not request that the Court require that my spouse and I participate In counseling prior to the divorce becoming final, 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, ~904 relating to unsworn falsiflcallon to authorities, Date: 0~~4 ? ~J~ K4h~C David R. DrayKr - ,- 0' - - r ~. .:1 , : " " .,' , ~, , I I I ( , I'~ I .,.] 0; , ' ,-) .-- ..... ,~ , I~" " ;;1 u, '-~ , c;; :os U, r-- L; U' <...1 DAVID R, DRAYER. Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA va, : NO, 94-5799 CIVIL TERM GLORIA ], DRAYER, Defendant : IN DIVORCE AFFIDAVIT OF CONSENT l. A Complaint In Divorce under Section 3301(c) of the Divorce Code waa filed on October 11. 1994. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety (90) days have elapsed from the date of filing and service of the Complaint. 3, I consent to the entry of a final decree of divorce after service of notice of intention to request entry \lfthe decree, 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: {} t::6bM-.-- , .L2..l.. ? / ~-"-~ ~ 52- f. L-<' A......'.....:.L... GI/RIA J. 0 R, oiYlNDANT ":"4 (71 0; ..J i- I Co I ( , , [<, . (~; ~ (') , ~i"J Co .' . ,'to ,- ,,',j l!_ C :L.l... L, II.. I- "j 0 c:r U , , va, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 94-5799 CIVIL TERM DAVID R, DRAYER. Plaintiff GLORIA 1. DRAYER. Defendant : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REOUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 330lfcJ OF THE Dn'ORCE CODE \, I consent to the entry of a final decree of divorce without notice, 2, I understand that I may lose rights conctrning alimony, division ofproperty,1awyer's fees or expenses if I do not claim them before a divorce is granted, 3, I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary, I verify thatlhe statements made in thiS affidavit are true and correct. I understand that false statements herein are made subject to the penalties of \8 Pa,C,S. Section 4904 ~lating to unsworn falsification to authorities, Date: Oauu....- ~, In? / WI;! - ~ J' .J!-.. if AL,<., ~,~ '~ GLORI 1. DRA v$', DEFE ANT C;- C , :;.... ..;, jo-'; I ~ ' ii .. L.":' : , t~ L. ;- C L, " r- ::1 , - 0' U 'j .\.... ,......,. . JOt ......S- : r.o. .. to!I , t I ,.........,...,...,. l~ot ., 'LAW U1l1lCU' .. JOHNSON,..DUFFlE,mW4RT 1I WEIDNEJ.' ':.. ~ '" .':;'" ~:- '1 ""',,* 1\h$\I.mn... 'f.t,.. .... t7ll) ... . DA VID R, DRAYER. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA NO, 94-5799 CIVIL TERM Plaintiff vs, IN DIVORCE GLORIA J, DRAYER, Defendant ACCEPTANCE OF SERVICE I, Lisa Coyne, Esquire, attorney for the Defendant in thll ahove action, do certify that I received a certified copy of the Divorce Complaint above-captioned on I B 0," T ''I ' I hereby accept service of the complaint, waiving any defects in service of process. I verify that the statements made in this Acceptance of Servicll are true and correct. I understand thaI false statements herein are made suhjecllo the penalties of 18 Pa,C.S, ~904. relating to unsworn falsit1cation to authoritioll, Date: /8 ocr 9<1 . ., DAVID R. DRAYER. Plalnllff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PA vs, : NO. 94-5799 CIVIL TERM GLORIA J. DRA YEa. Defendant, : IN DIVORCE NOTICE TO DEFEND AND CUlM RIGHTS You have been sued in court, [fyou 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 di vorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the Cumberland County Courthouse, Hanover and High Streets, Carlisk, PA 17013, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNUUIENT IS GRANTED, YOU l\IA Y LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE TillS 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 Courthouse Hanover and High Streets Carlisle. PA 17013 (717) 240-6100 DAVID R. DRAYER. Plaintiff : IN THE COURT OF COMMON PLEASOF : CUMBERLAND COUNTY, PENNSYLVANIA VI, : NO. 94-5799 CIVIL TERM GLORIA J, DRAYER. Defendant. : IN DIVORCE ANSWER AND COUNTERCLAIM AND NOW COMES Defendant, Gloria], Drayer, by and through her attorney, Lisa Marie Coyne, Esquire, and avers the following in support of her answer and counterclaim: (, Admitted. By way of further answer, Plaintiff resides at said address with his paramo\;!', Patricia Behman, 2. Admitted. 3, Admitted. 4. Admitted. 5, Admitted, 6, Admitted, 7, Admitted. 8. Denied, Marriage has not irretrievably broken through no fault of the Plaintiff.. WHEREFORE, Defendant requests this Honorable Court to deny Plaintil'rs request for a no- fault divorce pursuant to Sections 3301( c) or 3301( d) of the Divorce Code, '4~;A'; ,j " COUNTERCLAIM COUNT I. FAtII,T DIVORCE 9, The Defendant's answers to Paragraphs I through 8 arc incorpol'lltcd herein. 10, Plaintiff has offered such indignities to Defendant, the innocent and injured spouse as to lender her condition intolerable and life burdensome due in large part to Plaintiff's lib use of alcohol. 11, Plaintiff committed adultery during the course of his marriage to Defendant to :nclude his involvement with prostitutes, WHEREFORE, Defendant requests your Honorable Court to enter a decree divorcing Defendant from Plaintiff pursuant to Section 3301(a) (2) andlor Section 3301 (a) (6) of the Divorce Code, COUNT )) REQUEST FOR COUNSEL FEES, COSTS AND EXPENSES UNDER SECTION 3104, SECflON 3323 AND SECfJON 3702 OF THE DIVORCE CODE, 12, Paragraphs I through II above are incorporated herein. 13, Defendant has employed Henry F, Coyne, Esquire and Lisa Marie Coyne, Esquire, to represent her in this matrimonial case, 14, Defendant is unable to pay the necessary counsel fees, costs, and expenses and Plaintiff is more than able to pay them. IS, Reserving the right to apply to the Court for temporary counsel fees, costs, and expenses prior to the final hearing, Defendant requests that, aller final hearing, the Court order Plaintiff to pay Defendant's reasonable counsel fees, costs and expenses, " WHEREFORE, Defendant respec~fully requests that, pursuant to Section 3104, 3323 and Section 3702 of the Divorce Code, the court enter an Order directing Plaintifi'to pay Defendant's reasonable counsel fees, eosts and expenses, COUNT 111 CUSTODY 16, Paragraphs I through IS of this Complaint are hereby incorporated herein by reference as though set forth in full, 17. Defendant seeks custody of Elizabeth S, Drayer, Age 14, who resides with Defendant at the above.identified address, The child was not born out of wedlock, The child is presently in the custody of the Defendant at the above-identified address, In the past five years, the parties' daughter has resided with the Defendant at the above- identified address with the parties. The Mother of the child is the Defendant. The Mother is married, The Father is the Plaintiff. The Father is married. 18, The relationship of plaintiff to the child is that of father, 19 The relationship of defendant to the child is that of mother, She currently resides at the above.ideotified address with her daughter, Elizabeth S. Drayer, 20. Defendant has not participated as a party, witness or in any othtr capacity in any other litigation concerning the custody of the same child in this or any other state. 21, Defendant does not know of a person not a party to the proceedings whQ has physical custody of the child or claims to have custody or visitation rights with respect to the child. 22, The best interest and permanent welfare of the child would be served by granting requested relief because not only does the child prefer to reside with her Mother. the MotherlDefendant has historically been the primary custodial parent and stable influence on the child, WHEREFORE, Defendant prays your Honorable Court to confirm custody of the child of this marriage with the Defendant. Respectfully submitted, Dated:-P-.' OC'T .,,, . a Marie Coyne, Esqul o I Market Street CampHiII,PA 170114227 (717)737.0464 Pa, S, Ct. No, 53788 ATTORNEY FOR DEFENDANT . ,) ;\ VIllI... A.11ON The flll:tS set forth in the foregoing are true and correct to the best of the IJftd-il""""s Imowlec!ge, infOllJll!!lon l&I1d btllief and are verified subject to the penalties for unawom falsification to authorities UJIdao 18 PL C,S.A. 54904. Dated: 1" fJ 0 rr " , -1 LlJ.a'.. rJ' AD" ~ )' fk . , . ~ CERTIFICATE OF SERVlCE I, Lisa Marie Coyne, Esquire, do hereby certify that a true and correct coy ofthc Answer and Counterclaim has been served this ~ day of t'i t.. 'T D . e l!. , 1996, by fint class mail, postage prepaid upon those listed below: Joseph L. Hitchings Johnson, Duffie, Stewart & Weidner p, 0, BOll 109 Lemoyne, PA 17043-0109 Dated: rf't oc.... "to arie oyne, Esquire 3 1 Market Street Camp Hill, PA 170114227 (717) 737.0464 Pa, S. Cl. No, 53788 t ,...... ," '" , " '"R -Y ", ; ~ l't) II' ,. - (, 8 l (. 3 " C I . r .. 0 (b ,. Tl L' , i, r<) ---.; j ~ ,j ,-, .r;, '-- . , ,,':~n . LAW OPFICES JOHNSON, DUPFUl, STBW ART fJ WEIDNt!R ~ .. '.';1 :j:Or"'...~c . t.. Q. 80.. 109 '1;&.."",.. ,P......ylnnla 11043-0109 " '.. . ..... .- . H...... '''', . . ';,_.,'.':A';Y'" T.lopho... ('/17) 16M540 " ,';.' Telocoplu (117) 1&WOU DA VID R. DRAYER. IN THE COURT OF COMMON ILEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 94-S799 CIVIL TERM Plaintiff vs, IN DIVORCE GLORIA J, DRAYER, Defendant PLAINTIFF'S ANSWER TO DEFENDANT'S COUNTERCLAIM AND NOW, this )J-l day of October, \996, comes the Plaintiff, David R. Drayer, and answers the Counterclaim of the Defendant as follows: COUNT 1 FAULT DIVORCE 9, Paragraphs \ through 8 of Plaintiffs Divorce Complaint are incorporated herein by reference as if the same were more fully set forth at length herein, \0, Denied, At no time has the Plaintiff offered any indignities to Defendant. \\, Admitted In part, Denied in part, It Is admitted that Plaintiff had an affair durlna the parties' marriage. however, this was ten years prior to the parties' separation and the Defendant forgave the Plaintiff and afterward the parties engaged in normal marital relations. By way of further answer, Plaintiff has never committed adultery with a prostitute, WIlEREFORE, Plaintiff requests your Honorable Court to enter a decree divorcing Plaintiff from Defendant pursuant to Section 3301(c) or 3301(d) of the Divorce Code. 001013-0000310<100,,18, 1'/96IlLHIMHIl7121 COUNT 1/ REQUEST FOR COUNSEL FEES, COSTS AND EXPENSES UNDER SECTION 3014, SECTION 3323 AND SECTION 3702 OF THE DIVORCE CODE 12, Paragraphs I through 8 of Plaintiffs Divorce Complaint and paragraphs 9 through II of the above Answer are incorporated herein by reference as if the same were more fully set fonh at length herein. 13, Admitted. 14. Denied, By way of further answer, Plaintiff is not currently able to pay his own attorney's fees, much less those of the Defendant, and has a substantial balance owing to his counsel. By way of still further answer, Defendant has a better paying job than Plaintiff, and as such is able to pay her own counsel fees, costs and expenses. IS, Denied. See answer to paragraph 14 above, WHEREFORE, Plaintiff respectfully requests that Defendant's request for counsel fees, costs and expenses be denied, COUNT 11/ CUSTODY 16, Paragraphs I through 8 of Plaintiffs Divorce Complaint and paragraphs 9 through IS of the above Answer are incorporated herein by reference as If the same were more fully set forth at length herein. 17. Admitted. 18, Admitted. 19, Admitted, 20. Adm:tted, ,') /l ~ C'I ,- ..,. >-. i~ '$ C' '''/'' ,".. ~~ . - )::~ ,- r:; :-.J ~, ~.~, 1n r:l ~... . ! ~ '. fE' ~- '- , , . ! ~J f- (... 'u.. (,;. ... l..,=' , l.' en j . . . LAW mACES JOHNSON, DUFFIE. STEWART (I WEIDNER ., . ~~ No"'" s.-. P. 0. Boa 109 r......""'. p_,I..nl& 170.3-0109 TaIapN>Nl (71'/) "'M~ Tit_pi.. (11'/) .,'wou DAVID R. DRAYER, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA NO. 94-S799 CIVIL TERM IN DIVORCE Plaintiff vs. GLORIA 1. DRAYER. Defendant PETITION FOR BOUITABLE DISTRIBUTION UNDBR THE DIVORCE CODE AND NOW, comes the Plaintiff. David R. Drayer. by and through his undersigned anomeys.lohnson. Duffie. Stewart &. Weidner, and respectfully represents that: COUNT I . EQUITABLE DISTRIBUTION 1. Petitioner. David R. Drayer, Is the Plaintiff in the above referenced divorce ....tlon who filed a Complaint In Divorce under Section 3301(c) or 3301 (d) of the Divorce Code on October II. 1994. Respondent, Olorla 1. Drayer. is the Defendant in the above captioned action and has not flied a counterclaim or complaint for related matters under the Divorce Code. 2. Petitioner and Respondent were married on November 16. 1974 In New Cumberland. Pennsylvania and separated on or about April 16. 1994. 3. Petitioner and Respondent have legally and beneficially acquired properly durlna their marrlaae from November 16. 1974 until April 16. 1994 the date of their separation, which property is .marital property.. 4. Petitioner and Respondent may have owned. prior to marriage. property. both real and personal. which property has increased in value during the marriage and/or which has been exchanged for other property. which baa increased in value during the marriage. all of which is .marital property.. S. Petitioner and Respondent have been unable lQ agree as lQ an equitable division of laid property to die date of filing of '.his Petition. OO'oaHOOo:J/Mudlll, 1_ILHIMHm2JS 6. Petitioner requeatl lb. Court lQ equitably dlvid. all marital properly ownlna or beIooalJlllo lb. Petitioner and Respondent. 10HNSON. DUFFIE. STEW ART &. WEIDNER Date: ~ _ /'- <:/1. By: seph L. Hitchings ~lIomey I,D. No. 6SSS1 30 I Market Street P.O. Box 109 Lemoyne, PA 17043-0109 Telephone (717) 7614S40 AlIorney. for David Drayer I! OO'OI3.00003lMateb tl, 19961ILHIMHISl2JS VERlFICA1'ION I. Dav!d R. Drayer, verify lbat lb. ltatementl made In lb. foreiolJll Petition are true and correct to lb. beat of my knowledi', information and bell.f, I undentlnd lbat false ltaten-II herein are made lubject to the penaltiel of 18 PI,C.S. 14904 relatlni to unsworn falsification 10 authorities, Dat.: .#1~ 1/. /f1'1/ , 6?~/! d~~ David R. Drayer \.'. .. ! :j ( . \~ -----' '-.J '<":> :>- .......... ". -'" r .' U') ......:: . ~.:' c.i :l,,~ ~...~ ~ EFC !."I "\) . r ..... "...... IV) . ! --i ~ ~ ~ ,. (....J .. 'l'-T' '.! - Cl , ~ - {'" " > .','-1 '""',<:: ~ ~~ - .. ,. \ l ....-, .' , (.., . ) - c::J (. , Ci r-,','