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HomeMy WebLinkAbout94-05802 " , I ' I' " I' i ,,' ,'~ r J I, ."wl ~ ~ ~ , , , I , , 1"1 " ",i " III " I, I , " I ,,: \';1 I" j. , ," , , ! I , , , ,il , " , , , , I'" I" ,I , ~ ",': 'j' " 'I, , , " I, " ..., ..--.-' .....-:...... -- -- -- ... - .. _1t~lt*liM(>II<~~-..:>II<l . - . : IN THE COURT OF COMMON PLEAS . : OF CUMBERLAND COUNTY : : STATE OF '*' PENNA. ! . . . ,.,SUSAN J. PAInR, II . . PI in iff ': N o. ...~~::'.~eo~,.C.iv.u............ 19 ,. "at II . . Vet'"lI" 1 . . N.J>N 5 PIDlER ,I ,. , ., il · . Defendant II . : I . DECREE IN · . . . DIVORCE : !.i AND NOW, .... ~fl&~.u~.. ~':1.... 19 .QC it is ordered and " ; d."..d tho' ... .s..,,", :'.;;:.............. ...... ...... . ... p'O;nllff.i . and .. ..~~.~~ .~'!I~......... ............................... defendant, . ' are divorced from the bonds of matrimony. . . . . . . ., . . . . . I!.--~. The court retains jurisdiction of the following claims which hove been raised of r.~py:t in this action for which a final order has not yet been entered; \\JON(, , . . ~T. IS.~. O~RED. that. ~. ~. Cl!'I'I ~~~~~~. (J.f. ~. P.i~PA .-'- . -.',':."r"'i ~l'eecrent. dated. January. 3.. 1995.,. attached - etc.,. ill' ~a.t:ed hIldift at/'\n", wI. . ., .r~,JI, Au...: ~,/.x1,."..",... (,!..iJ4-:, !a~'~""', ii, ",.t""~(Jli .r .)~;Ir .X..J,'iUoZ "', ...:,;,! ,j / T..ii';O.......I."~" / ~IIJIllUU7', 199'IILHIMH/40I" l. Snarallon, The partla hereto separated on ?r about December 6, 1994, and shall continue to live aeparate and apart and will not cohabllll' with each other. It shall bf lawful for each party at all times hereafter to live 'epJate and apart from euh other at such a pia" or places as he or she may from time to time chooIe or deem . fit. 2. Int...rermte. From the date of slllninll this Allreement, each pany shall be free from illterference, authority and control of the other, u fully as if he or she were sinllle or unmarried, except as may be Del:asary to carry out lbe provlslollS of this Allteement. Neither party shall molest or altemptto endeavor to molest lbe other, or compel lbe other to cohabitate with the other or in any way harass or malilln the other, or In any other way iDterfere with lbelr peaceful existence, separate and apan from the other. 3. Mutual Release. Subject to the provisions contained in this Allreement, each pany has released and dlschar,led, and by this A,lreement does for himself or herself, and his or her heirs, lellal representatives, executors, administrators and asslllns, forever release and discharlle the other of and from all causa of action, claims, rtabts or demands whaltoever in law or equity, which either of the parties ever had or now has allainst the other, except' c..... or causes of action for divorce or all causes of action for breach of any provisions of this Allreement. Further,_1t party, subject to the provisions of this Allreement, releases and forever discharlles the other fiom any IIId all cla1llla one may have allainst the other arisinll out of this mauimonial action, includin,l, but not limited to alIntollY, ..Intolty p.endente lite, spousal suppon, equitable distribution, counsel fees, costs and expenses. , ' 4. Waiver or Claims AllalMtthe E..late. Except as herein otherwise provided. adl,.., .., ~'lIJ" of his or her prop.eny In any way, and each party hereby waives and relinquishes any and all ri". lie ...., .- have or hereafter acquire under the present or future law of any jurisdiction to share in the ,.(lpolly or""'" . , the other as a result of the marital relationship, includin,l, without limitation, dowry, countsy. ........, ..10....,., widow's allowance, homestead rlllhlS, rillhlto equitable disuibutlon. rillhlS to take in intesllCy. '.......... the will of the other, and riJhtto a.:t as adminislrator or ellCCUlor o.-the other's estate. Each paftJ......i~"\..li of the other, execute, acknowledlle and deliver any and all inslrumenls that may be neceuary or Il2v"',...", eff. this mutual waiver and relinquishment of all su,h interests, rillhlS and claims. ,. ',',:"iit\, " '~~\:t!,i ,I "~,~w~'1; , ;',1 ,'l" ')'-"" ,:'lfiA--1 i" "."'_ H"-,, ," ,-;\II':l.' "~1'),~'1 , "i1 -'l)~ 'I' \,I~-n ~\' -:':)..::'\ " '.";\ " , OCIt7Ot-OOOOIIIIll...ry', 199"ILHIMH/40IU . 5. Division or Penonal ProDtl'tY, E~ceptas set forth herein, eIl:h of the panla hereto has divided between thems.lva, to their mutual satisfaction, all items of tanaible and Intan,ible marital personal propeny, . Indudtna household fumlshtnas and other similar prop.rty. Neither party shall make any claim to any luch items of marital propeny, or of the separate personal property of either party, which are now in the posaesslon and/or und.r the control of the other. Should it become necasary, the parties each a,ree to sl,n, upon requat, any tltla or , cIocuments necessary to ,ive effect to this paraaraph. The propllrty shall be deemed to be In the possession or under the control of either party if, in the case of tan,ible personal property, the item is physically in the posaesslon Of control of the party at the time of the sianln, of this Aareement, and in thol case of intan,ible personal propeny, if any physical or written evidence of ownership, such as a passbook, check book, policy or cenlflcate of insurance or other similar writin, is in the possession or conlrol of the party. lbe items of tan,lble personal propeny listed on thol anached Exhibit" A" shall become the sole and separate propeny of Wife. The items of tan,ible personal property listed on the attached Exhibit "B" shall become the sole and separate propeny of Husband. E~cept for the Pontiac Firebirds currenlly stored in the ,araae at the marital raid.nce, Husband shall have forty-five (4S) days from thll dale of execulion of this A,reemenlto take possession of the personal propeny listed on Exhibit "B". With respect 10 the motor vehiclu owned by one or both of the parties, they a,ree as follows: A. The 1967 Pontiac Firebird. lhe 1969 Pontiac Firebird and the 1993 Dod,e Dakota Truck shall become the sole and separale property of Husband, subject 10 any liens and encumbrances. Husband a,rees 10 pay in full any lien or encumbrance and to indemnify, defend and save harmless Wife on accounl of any said obli,ations. B. The 1986 Ch.vrolel Caprice Wa,on shall become the sole and separate property of Wife, subject to ' any liens and encumbrances. Wife a,rees 10 indemnify and save harmless Husband on account of any said obliaalion. The titles 10 the said molor vehicles shall be .ucuted by the parties, if appropriale. for effeclin, the trwf.r , as her.in provided, on the d;!.le of necution of this A,rtemllnt if the lill. is in th", poss.ssionof one or the OIber part)'. ' In the event thaI either or all of the documents of lill. 10 tht said vehiclts shall bt in the hands 01 a bank or other OOtlOI-OOOOIIJlIIlIIIY 3, J99',JLHIMH/40I9J holder of the lien or encumbrance upon said vehicle, the parties aarellto advise such bank or holder as to the trUlSfer of title set forth herein and they further aaree to IlxIICute whatever documents may be required to transfer title or said document of title as in the hands of such bank or holder. 6. Marllll RMJdlfl'lr.. The panles are presently lbe joint owners of real property known arA numbered as'9 Pine Rldee Circle, Enola, Cumberland County, PeMSylvania 1702'. With respect to lbis property,lbe partia ",.. as follows: Wife will continue to rqide in the marital residence wilb the children, assumina lbe mortaaae and all expense payments thereon. When the younaest child, Corey, turns eiahteen years of aae, within thiny (30) days, Wife wUl decide whether to buyout Husband's equity interest, or putlbe house up for sale. If Wife decida to buy out Husband's equity interest, bolb parties must aaree on a fair value of lbe residence, minus any obllaations owina thereon. Wife will then pay to Husband the equivalent of '0" eqully interest, minus the sum of SIO,'OO.OO, which the partla aar.. constitutes Wife's interest in Husband's railroad retirement fund. If Wife decides to put the house up for sale, both parties must aaree on the Iistina price and the house musl be listed on lbe market wilbin a reasonable period of time. Followina the sale of lbe home, Wife will pay 10 Husband SO" of the proceeds from the sale, minus any costs and expenses, and sublractina OUI further lbe sum of $10,500.00, which constitutes the value of Wife's Interest in Husband's railroad retirement fund. 7. Addillonalln.trumenl~. Each of the partills shall, on dllmand, execule and deliver to the other Iny deeds, bills of sale, assianments, consenlS to chanae of bllndiciary on insurance policies, tax returns and other documents and do 01' cause to be done any olber act or thing lbal may be necessary or desirable to eft'~ate the provisions and purposes of this Aareement. If eilber party fails, on demand, 10 comply with this provision, thai party shall pay to the olber, all anorneys fees, COSIS and olber expenses uasonably incurred as a resulJ of sudl failure. 8. Deb... and L1abllitlf.'l. Husband and Wife hllrllby rllpresllnl and warrant to the other tit. 1M Of"''''' 1101 incurred any debts or liabilities or made any conlracts for which thll othllr or his or her estale may k I~.. as stated in this "areement. The panies hereby aCknowleda" and allrll" 10 be responsible for and to lIIIIlf ",~nlll on the various debts and liabililies listed under each of their namlls on Ihe an ached Exhibit 'C'. If eldler ...,.. Incuned any other Individual obliaation durina the tllrm of thll marriaall. thac pany shall be respollSlblflO "'I~ said obliaation and hereby aarees to indemnify and save the other SPOUSIl harmless on accounl of said obi""',,"!" "'. ~IIIlAlIIlry', 199~IILHIMH/40193 9. Warranty u to Future Obll..t1ons, Husband and Wife ea~h coveniUlt, warrant, repreaent and qt.. that with the tllception of the obli,atlons set fonh In this A,reement, neither of them shall hereafter Incur any liability whatsoeVer for which the atlle of the other may be liable. Ea~h party shall indemnify and hold harmlas the other party for and aaalnst any and all debts, ~har,1IS and liabilities Incurred by the other after the date of execution of this A,r"ment, except as may be otherwise spe~iflcally provided for by the terms of this A,reemenl. 10. AftIII' Aroulred PlII'SOnel ProDel'IY. Each of the parties hereto shall hereafter own and enjoy, independent of any claims or r1,ht of the other, all items of personal propeny, lan,ible or Intan,ible, hereafter aequlred by him or ber. with full power In him or her to dispose of the same as fully and effectively, in all respe..'lS and for all purposa, as thou,h be or she were unmarried. II. Rearfllltfltlltlon by Counsel. The provisions of this Alreement and their lellal effect have been fully explained to the parties by their respective counsel, Paille Macdonald-Matthes, Esquire for Wife and Joseph L. Hltchinp, Esquire, for Husband. The parties a~knowledlle that they have re~eived indepcndentle,a1 advice from counsel of their own selection and that they fully understand the facts and have been fully informed as to their le.1I r1,hts and obli,ations and they acltnowledle and accept that this Alreement is, and the cir~umstanca are, fair and equitable, and that the Alrecment is beinl entered into freely and voluntarily. 12. Custody. Husband and Wife shall have shared lelal custody of the pany's minor children, Satl Lila Palmer, and Corey I\lan Palmer. Husband and Wife shall each have the rilht to make major parentin. declsloll atfectinll the children's health, education and welfare. Each party a8rees to consult with the other with r.pect to IIloM major parentinll decisions. Primary physical custody of the minor children shall be with Wife, and Husblld ........ pel'lods of visitation, &.1 allreed upon by the parti"'.. I" L IJ .il Durlnll such time as the children reside with the oth",r par..nt. that parent shall be responsible lot ... _{ .11:1., o!iii\ of the children's care, includinll medical needs and shall have the dUly to immediately advise the other ,... _,~) i unusual ~~u"ences or any illness. Each of the panies h",reby a<;knowledle that it is imponanl tItaI 1M cl!'IJ.~ · :. ,j eontinuelO have a relationship with both the Husband and Wife. and u<;h hereby allr"s to assen his Of..... '*'...: ,I' " . , I 1',1< to Insure that thOSoll relalior\ships continue and is not in any way advenely aff",c"d. The pania ..r.. tIlM ..... "I,iII" provisions penaininllto custody, may upon th. applkation of either patty. be entered ;u a ~oun order. 0091OWOOO1IJanll&ry', 19951ILHIMH/40IU 13. Child Support. Husband h.reby acknowledies and airees to pay to Wife the sum of $200.00 per week u child support until the parties' daulhter, Sara, turns eiihteen years of aie, at which time the child support payments wll1 be reduced to $100.00 per WINk payablll until the parties' lon, Cor.y, turns elihteen years of .... 14. Mutual CORStIIt DIYor~. Thll parties airee and acltnowledie that their manial' is irretri.vably broken, that they do not desire marital counselini, and that th.y both cons.ntto thll .ntry of a deer.. In divorc. pursuant to S.ctlon 3301(c) of the Pennsylvania Divorce Codll, Act 26 of 1980, as may b. amended (h.r.lnafter referred to u the Cod.). Th. parties acltnowledi' that Wife has instituted a divorc. acalon ..ainst Husband In the Cumberland COUDty Court of Common Ploeas, docketed to number 94-'802 Civil Term. Both partla qree to .1lecUt. such consents, affidavits and other documents as may be necessary to promptly proceed to obtain a divorce pursuant to said Section 3301(c) of the Code. The parties alree that Wife's counsel Ihalltalce the necessary steps to flnallz. the divorce u soon as may be practical. U. EffHt or the Divorce D4!cree. The parties alree that unless otherwise specit1cally provided h.r.ln, this Aireement shall continue in full force and effect after such time as a t1nal decree in divorce may bll entered with respect to the partia. It is the intent of the parties hereto that this Alreement shalt create contraccual ri,hts and oblllations entirely independent of any Court Order and that this Alreemellt may be enforced by contracc r.medla In addition to any other remedies which may be available pursuant to the ternu of this Alreement or otherwis., IInc1ef the Pennsylvania divorce laws. 16. Bonk Attounts. Crrtincotes. I/Isuroncr Policle. Prnsion Funlh ond other Aullt.l. Ellcept. ,', otherwise set forth herein reiardini Husband's railroad retirement plan, each party shall recaln any lIdi'ridull, 'I L' ,','I, retir.ment account In his or her name. Each party shall retain as his or her own property, any pension. 1CllC1l,..... ',,'iil i' .,t.'j or other plan throuih his or her place of employment, or otherwise, whether vested or non vated. !ad,.., ....,:;.::;:11 , ' .. ',: 'W~" b. and remain the sole owner of any othu asset in his or her control not specifically covered by othtr prov1lllllM,.: "il!i!~i , ..n~_i' this Alreement. Should il become necrssary, each party allrees to silln any other titles or docum.nts ......,., .. I. .ffect to this section upon request of the other party. , . ~ .. ~. '.. ,'-'.~. 4/... ,'" _'" ;0, ..' .....",-"'~ .- . ~..... , - ...-: .. . "l . oi ... oltIf~ .. BXHIB1'1' .C. 1;- OeM. ne - H.... 1rI..ftll6 monltllv 900 00, 11213I10 17207.70 wk) 2eOO 00 I - 1?OO 00 11213I10 ShMtI T.iQ eo. 00 11213I101 , ~oIHtltonlDlminlck utllIll.. 200.00 1st -" orthodontist &10.00 1st week. to 12JG1o Herriebura Hael..1 autslMldlna bjll !SO. 00 2nd WMk Q a.vrMnls NIIlIonwlde L. Ine. Co. 1.ln,urw1C4llAl 310. QlI 2nd ~. 1010.Qll . NlItionst.nk I vi.. 7S.00 3rd Mek ~ line. Co. ~surlnce toJL"IS'e2.!SO 3rd _k Irent 360.00 IoltlwMk a.nk of PA !c:arOlvment :le7.00 IoltlWMk Sare I ch"ttIA !SO 00 loth -'< , 2533. loll <<:tuallxaen_ le33.1oll SUlWf J. PALlER 1~J DeM. ~t NolIM ... a 11M ;; Food 12!l1l:ler_k SOO.OO 1323.113 b snAndl"" 120.00 11213I10 IlOO 207. ShMtI .... eo.OO 11213I10 zm.1I3 week IQcN' A110WW1Cll1 monltlivl 100.00 11213I10 PHFA mto. n200 1st_k J8n ~v. Iniano 100.00 1 st WMk . e-v. I clothe. 2S.00 1st MIk PPIL Ilteclrlc 127.00 2nd Mek aIIlslance ~nental Cab/,vlsion fc:abl. tv 32.00 2nd Mek EPT_. i_/refI.IM :N.OO 2nd WMk. SItm8t lank lvi_ e:z.00 3rd WMk 3e ~Nat'f Inl. Co. QI' insurance "f1.~:KJ.00 3rd WMk e PAWC WIIIM 30.00 3rd week ilrloCONews w.nI ~ 2S.00 3rd wMk ~~ 3rd WMk loIPA IDhon. 1oS. IoltlWMk MIdIc:aI non-ineur_ 100.00 IoltlWMk MIle. ullWtc.1 100.00 - 21 Q7. 001 SUSAN J. PALMER, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-5802 Civil Term CIVIL ACTION - LAW IN DIVORCE ALAN S. PALMER, Defendant PRAECIPE TO TRANSMIT UNDER SECTION 3301{c' TO THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: irretl'ievable breakdown under S.ction {Xl 3301lcl ( 1 3301ldl of the Divorce Code. 2, Date and manner of service of the Complaint: Defendant_ received the ComDlaint in Divorce on October 13, 1994. See Pl'oof of Service filed to the above term and number. 3, (Complete either Paragraph (a) or (b)), (a) Date of execution of the Affidavit of Consent required by section 3301(c) of the Divorce Code: By Plaintiff: Januarv 11, 1995; Defendant: Januarv 11. 1995. (b)(1) Date of execution of the Plaintiff'. Affidavit required by Sect.ion 3301 (d) of the Divorce Code: HLA: (2) Date of service of the Plaintiff's Affidavit upon the Defendant: HLA, 4, Related claims pending: No claims DendinQ. Respectfully submitted, Date: ~!ru..l.JO.A.0 \ L, I' C\'\ ") FARR , CUNNINGHAM, P,C. ~".'lrA.'tV.,,~~~,o.J - .1 . Paige aCdonald-Matthes.~' ".: 1.0, !/66266 2320 NOl'th Second Street P,O. Box 1855 Harrisburg, PA 17105-1855 (717) 238-6570 (Attorneys for Plaintiff) v, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 1/r -55 ().)-. (It c}.", c..J).l4- SUSAN J, PALMER, plaintiff ALAN 5, PALMER, Defendant CIVIL ACTION - LAW IN DIVORCE HQIlCE TO DEFEND AND CLAIM RIQHTS YOU HAVE BEEN SUED IN COURT, If you wish to defend against the claims set fOl'th in the following paqes, you must take prompt action, You al'e warned that if you fail to do so, the case may proceed without you and a Decree of Divol'ce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim 01' relief requested in these papf'l's by the plaintiff. You may lose money or property or other rights impol'tant 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 Dauphin county Courthouse, Harrisburg, Pennsylvania, IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECRE! OF DIVORCE OR ANNULMENT IS ENTERED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR " LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY COURT ADMINISTRATOR Cumberland county Courthouse, 4th Flool' 1 Courthouse square cal'lisle, FA 17013-3387 Telephone: (717) 240-6200 FARR & CUNNINGHAM, P.C, Date: {\NtAl'i I1 b lCl~l\ , Bs,'at~\l~~~~~~l~~~~&~s~rs~ ' 1.0. 1/66266 2320 North Second stl'eet P. 0, !lox 1855 Harl'isburg, PA 17105-1855 SUSAN J, PALMER, Plaintiff IN 'l'HE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. CIVIL ACTION - LAW IN DIVORCE v, ALAN S, PALMER, Defendant QQKPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Susan J, Palmer, by and through her attorneys, Farr & Cunningham, P.C., and seeks to obtain a Decree in Divorce from the Defendant and in support thereof avers as follows: 1. The Plainti ff, Susan J. Palmer, resides at 59 Pin. Ridge Circle, Enola, Cumberland County, Pennsylvania, TIl. Plaintiff is a citizen of the United States of Amel'ica. 2, The Defendant, Alan S, Palmer, resides at 59 JUdge Circle, Enola, Cumberland County, Pennsylvania. Defendant is a citizen of the United States of America, ], The Plaintiff has been a bona fide l'esident in Commonwealth of Pennsylvania for at least the last six (6) months immediately previous to the filing of this Complaint. 4, The Defendant has been a bona fide l'esident in the , ' . VERIFICATION I, Susan J, Palmer, verify that the statements made in the foregoing Complaint in Divorce are true and corl'ect to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penal ties of 18 Pa. C, S. !i 4904, relating to unsworn ,) falsification to authorities. ,I,' ~tE~ Susan J, P Imer ,'I., '.,' " Date: 10111 /1.'f .. . AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSVLVANIA COUNTY BS; OF DAUPHIN The Plaintiff, being duly sworn according to law, deposes and says that she is the Plaintiff in the above captioned matter and that she personally knowll that the Defendant is over the age of eighteen (18) years. ", The Plaintiff further avers that the Defendant i. 'lot in the Military Service or in any branch of the Armed 'orc.. r'" , ',',i)i: of the United states of America or its Allies or otbenrl~i ,I,;; , . ',',"ii,"',:-t)i/, within the provisions of the Soldiers I and Sailor.' Civil'!':."," ; ,'-I,'>",J1:l," , , ':::'L\/il\~,b<,i(" Relief Act of Congress of 1940 and its Amendment.. "':;:I;!.~)J',\i li\,1-iii ,,',I';..r/ \1l,:1 _ 'iff'lt ',-,::18".' Susan SWORN and Subscribed to Before me this II~ day of O~ , 1994. ~1~ NOTARY PUBLIC NOla,lal Seal MIcNII S. MlUer. NoWy I'ulIIIc ~., 1olo, O.upNn COIInlY My Commt"lon (.pI,.. July e, 1998 ..... d_ ':,' 5 . '. SUSAN J. PAUll:R, Plaintiff I IN THI COURT or COJlKON PLIAS CUM81RLAND COUNTY, PENNSYLVANIA NO. 94-5802 Civil Tera CIVIL ACTION - LAW IN DIVORCE . . . . v. ALAN S. PALMER, Defendant . . I U'PIDAVI'l' OP COIfSIIII'l' 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 (90) day. have elapsed fro. the date of filing the Complaint. 3. I con.ent to the entry of a Final Deere. ot Divorce. 4. I understand that J. may lo.e rights concerni.. alimony, division of property, lawyer's fees or expen... if I do not claim them before a clivorce i. granted. " '.', I ".'1\: , "I ',llt1 ,. ;,'1'1;';\' , ,':,...'.':.11I' I verify that the statements maele in this AtfJ.d.~1t: .:",,:,1, true and correct. I understancl that false state.enta ' are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unsworn falsification to authorities. ' Date: i/lt/QC S san ;J, '" ~.-.. ,u....., - .... ., 'lC' 1_'.. '" ., :..' .. . ., "'" ... ,. ... , ,~ ". " ." 1\, , " ',' ".'1' '" " "