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HomeMy WebLinkAbout95-00613 r ,1 ."1 I \ ., . .... .. , >lit .. >lit C. ,*. '. .. '.. .' '. '. ..' ':t!' ,,,.;. ':t!. ,,,.;, .:t!' ,:te. ,(t!' '.. ~ 'lie> >lit. .. .. .. ... .It.} .. -'11! . ,,,-~~--,.,~,,' ~--" '''''' ,.. ,...,.., " ,'...",,,.. "" -,,, "."" ,,,.. "-.,......,,.--,..-.- . - . : IN THE COURT OF COMMON PLEAS : · OF CUMBERLAND COUNTY . 8 . : STATE OF '* PENNA, : . . . . . Mar~ a. f.sltnger, 613-95 . . ~latntHf (\;0. "",,,,,,.IL) . . V"I'"II" . . Debbie A. F.slinger, . . .' Defendant . . ~ ~ . . : 0 E CREE , N:J:. . S8 P. il ANDNow,~DleORI~ItI'o':~dond ;' _ decreed that .""" Mn.r,k,13,', f:flli,n~~r"""", """"", plalnllff, . . and.", D?~,bi~, fl', E~,ling?r """"'''' defendant, : . are divorced from the bonds of matrimony. * . . . The court retains jurisdiction of the foll<.lwlng claims which have . . been raised of record in this action for which 0 final order has not yet . . been entered; . . . . . - . - t-_ g ,~!l, ,~\!~~,h,<q~ ,pr,q'nl2,d, ,\;ll;1t tOPf)J;OVi,flionll, ,of, the, l11/I.r;~' 1et9-'l , , , , , , ':. I ,s,~~~~~,Il)EI(l~,C\grl2eI1)EI(l~ ,qi}t;.!-"d ,Ml,lrc,h, )1,,199,6, ,bctwQcn, P,1.ain,tiff. A.nc1 :. Defendant and filed in this nction are incorporated herein and l~ made apart hereof by reference thereto, but shall not merge heroin. A cop of said agreement isn,\t h d 'I-lj'l as f:xhiblt A. 18 i8 :~ z " ,." -( W ", ~ I), 'il, />.,/ If> ~ /,j Jj ~,' t. "J / (J ).\. ' l'mthollolnry '>r V" r l * ,~.:. ~.:' .:+:' ':.' .:.:. .t.:. .;.:. 'l.;' .t.:. ,ttt. ,Ct:. .~.~. .*, .*. J. :~ ;~ i~ ,II, " . . .. " , ,,' (. k ,;1- ) Nt/i. (. 11"1,1, A. ,(~t/ fi 1/4,r 11 .- o. J (I 'f(J /I' ~ I ~I, ,t...., .1 " " ',,' " " i I " ,I , " !I I' , " , , " , '1'1 , '" , I' , - . . '" J Hty( e,.l~"'\"C1tl( /~ (r ~",.,~ ~\ 1-)0. q $,- (, Ij Ac-hof' 1~\1)\VO'((1' v, lJ! IY);( ,1, t ,) \ I V,~n MA~~JAGE BETTLE~ENT ~GRJEMENT THIS AGREEMENT io made and entered into between MARK O. RSL CNGER and DROBIK A. ESLINGBlR, hereinafter referred to as Husband and Wife. The parties were married on May 28, 1988. AfI a consequence of dispUtes and unhappy differences, the par: ies have separated, . The parties desire to confirm' their sep,Lration and make arrangements in connection therewith, including the settlement of their property rights, and all other rights and obUgations arising out of the marriage relationship. It is therefore agreed: 1. CONBIDERl.TION rhe consideration for this Agreement is the mutual promises and agreements herein contained. 2. BBPARATION AND NONINTBRFBRBNCB A. It will be lawful for each party at all times hereafter to I.ive separate and apart from the other party at such place or pla':es as he or she may from time to time choose or deem fl,t. B. Each party shall be free from interference, authority and conl.rol, direct or indirect, by the other, as fully as if he or she \'lerll single and unmarried. Neither shall bother the other or compel or endeavor to compel the other to cohabit or dwell with him or her. E:XHtllt'l' "^" , .. r > ~ ; , " ~ ~i: J " .i.f, ,- I".' " f': ,'..\ "', ,- -, ! " , , ,~., . " , , , -- ,'n :l;-"~.~ , " ". (" I ' . ) 1"'" ,-.., 3. MUTUAL RBLB~SB Subject to the provisions of this Agreement, each party has relil8sed and discharged, and by this Agreement does for himBelt or hemelt, and his or her heirs, legal representatives, executors, admmistrators, and assigns, release and discharge the ot.her of and froll all causes of action, claims, rights, or demands whatsoever, in aw or equity, which either of the parties ever had or now.has aga ,nst the other, except any or all .cause or causes of action for div'lrce. 4. FULL DIBCLOSURIi The provisions of this Agreement and their legal effect are fuLy understood by each party to this Agreement, and each party acknowledges that the Agreement is fair and equitable, that it is being entered into voluntarily/and that it is not the result of any duress or undue influence. Husband and Wife each represent and warl'ant to the other that he or /lhe has made a full complErce disc:losure to the other of all assets of any nature whatsoever in whic'h such party of every type whatsoever, and of all other facts rell ting to the subject matter of this Agreement. Both parties rep) esent that the terms of this Agreement have been fully exp:ained to them by their respective counselor that both parties " haVI had the opportunity to have legal counsel review and fully expl ain the terms of this Agreement Wife acknowledges that Michael J. Pykosh, Esquire of the Law Offices ot Darrell C. 2 ".~ -,. , , Df/tllefs, is hlllr husband's attorney, and nut her attorney. Wife ackLowledf/es that her husband's attorney has nover given her advise relltive to this divorce action or in regard to this Agreement. 5. BOUITABLB DIVISION By this Agreement, the parties have intended to eftect. an equ:table division of their marital property. This division is not intl'nded by the parties to constitute in any way a sale or exchange of l.Ssets. 6. SUBSBOUBNT DIVO~CI A. AG~EEMENT NOT PREDICATED ON DIVORCB - It is specifically undl rstood and agreed by and between the parties hereto and each of the said parties doeD hereby warrant and represent to the other that the execution and delivery of this Agreement is not predicated upor nor made subject to any agreement for institution, profecution, defense, or for the non-prosecution or non-defense of any action for divorce; provided, however, that nothing contained in t his Agreement shall prevent Ot. preclude either of the parties herEto from commencing, instituting or prosecuting any action or actions for divorce, upon just, legal and proper grounds; nor to " pre\ent either party from defending any such action which has been, mayor shall be instituted by the other party, or from making any just or proper defense thereto. It is warranted, covenanted and rept9sented by Husband and Wife, each to the other, that this 3 '. ~ t"""\ ' Agrllement is lawtul and entor.ceable and this warranty, covenant and repl:esentation is made for the specific purpose of inducing Husband and Wife to execute the Agreement. Husband and Wite each knowingly and understandingly h~reby waives any and all possible claims that thill Agreement is, for any reason, illegal of for any reason wha1eoever, unenforceable in whole or in part. Husband and Wife eacll do hereby warrant, covenant and Ilgrlle that, in any possible event, he and she are and shall forever be stopped from asserting any illegality or unenforceability as to all or any part of this Agrllement. B. ENTRY AS PART OF DECREE - It is the intentiC'ln of the parI iee that the Agreement shall survive any action for divorce which may be instituted or prosecuted by either party and no ox'der, jud~rment or decree of divorce, temporary, final or permanent, shall affl'ct or modify the financial terms of this Agreement. This Agrlement shall be incorporated in but shall not mer.ge into any sue} judgment or decl'ee of final divorce, but shall be incorporated for the purpose of enforcement only. C. MUTUAL CONSENT DIVORCB The parties agree and ackr owl edge that their marriage is irretrievably broken, :that they do not desire maritlll counseling, and that they both consent to the entry of a decree in divorce pursuant to 23 Pa.C.S.A. Section 330J (c). Accordingly, both parties agne to forthwith execute such 4 f....., ,......1,. consents, affidavits, or other documents and to direct their respactive attorneys to forthwith file such con.ents, affidavits, , or (Ither documents as may be necessary to promptly proceed to obtain a divorce pUr/,luant to said 23 Pa.C.S.A. Section 3301(c). Upon request, to the extent permitted by law and the applicable Ruleil of Civil Procedure, the named defendant in such d:..vorce action shall execute any waivers t1Jf notice or other waivers necessary to expedite such divorce. 7. DIVISION OF PBRSONAL PROPBRTY Wite agrees that all of the property in the possession of Kusb !md as of August 1, 1996, shall be the sole and separate property of Husband, and Husband agrees that all of the property in the ~ossession of Wife as of August 1, 1996, shall be the sole and sepa rate property of Wite. The parties do hereby IIpecitically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to the above items which shall become the 1I0le and lIeparate property of the other. 8. DIVISION OF MOTOR VBHICLBS With respect to the motor vehicles owned by one or both of the partles, they agree 8S followsl Both parties IIhall retain the motor vehicle presently in their posssssion, more specifically husband shall retain the 1983 !l " ~~ ,-.\ CheV'rolet Chevette and the 1977 Pord Pickup Truck. Wife .hall retein the 1991 Chevrolet Corsica. The titles to the said motor vehicles shall be executed by the part ies, it appropriate, tor eHectuating transter as heroin pro\ided, on the date ot execution ot this Agreement or at any time theJeafter at the request ot either party. 9. AFTBR-ACOUIRBD PBRSONAL PROPBRTY Bach of the parties shall hereatter own and enjoy, ind~ pendently ot any claim or right Of the other, all items of perEonal property, tangible or intangible, acquired by him or her after August 1, 1995/ with full power in him or her to dispose ot the same as fully and effectively, in all respects and tor all pur.oses, as though he or she were unmarried. 10. RBAL PROPBRTY A. The parties hereto acknowledge that they are the joint owners (tenants by the entireties) ot real property known as 954 Brick Church Road, Pennsylvania (hereinafter reterred to in the foll owing subparagraphs as n the property") . B. As of midnight / August 1, 1995, Husband shall have exclusive possession of the property. 6 I, I , 1 'I . '" ) ~ ~\ C. As of August 1, 1995, and at all times thereafter Husband shall be fully, solely al'ld exclusively responsible for making timf'ly payments with respect to all costs assoclated with the prol,erty including but not limited to monthly mortgage payments, real estate taxes, utilities, sewer and all other municipal charges and all other costs related to general upkeep of the proper.ty. WifE will not in any way be held resilonsible or Hable for any of the above costs. Wife shall not have any interest in the equity of the property. D. Within forty-five (45) days of the execution of this Seplration Agreement, the parties hereto agrees to execute and file all. documents necessary to remove Wife's name from the Deed related to:he prope.t'ty. Husband shall be responsible for paying all filJng fees and costs associated therewith. E. Wife by executing this Agreement relinquishes all right, titl e and interest in the property for herself and her, heirs, executors assigns and administrators. 11. DISPOSITION OF PROPBRTY From and after the date of the signing of this Agreement, both parties shall have complete freedom of disposition as to his/her seplrate property and any property which is in their possession or control pursuant to this Agreement and may mortgage, sell, grant, 7 . ", . I"~"" ,.-'. cO'I"ey or otherwise encumber or. dispose of suoh property, whether rea: or personal, whether such property was acquired before, during or lftermarriage, and neither Husband nor Wife need join in, conllent to, or acknowledge any deed, mortgage, or other instrument of t.he other pertaining to such dJ.spollition of property. 12. PAYMENT OF SPECII?IBD OBLIGATIONS I The parties agree that the following constitute joint marital obl:.gations which shall be paid by the following personl A. WIFll - All debts incurred by Wife since the parties separation. 2. All debts associ~ted with the motor vehicle in Wife's possession at the time of the parties separation, 1. B. HUSBAND - 1. All debts incurred by Husband since the parties separation. 2. All debts associated with the motor vehicle in Husband's possession at the time of the parties separation. 13. LEGAL FBBS llaah party is responsible for their own legal fees with resl,ect to this matter. '. 14. ALIMONY Both parties acknowledge and agree that the provisions of this AgrE'ement providing for equitable distribution of marital property are fair\ adequate and satisfaotory to them and are accepted by 8 , '" .. ,""'" ,.-, then in lieu of and in full and final settlement and satisfaction of Iny claims or demands that either may now or hereafter have against the other for support, maintenance, alimony pendente lite or alimony. Husband and Wire further, voluntarily and intelligently, waive and relinquish any right to seek from the other any payment for spousal support, maintenance, alimony pend ante lite or alimony. 15. P8NSION PROGRAM Bach party hereto shall maintain sole ownership over his or her individual pension plan, profit sharing or similar retirement plar acquired individually or as the result of contributions by his or h 3r employer. Wite hereby releases any interest that she has in the retirement benefits of Husband accumulated as the result of his employment and any other additional beneHts he many have accrued. Husband hereby releases any interest that he has in the reti rement beneHts of Wire accumulated as the result of her employment and any other additional benefits she may have accrued. This waiver is a full and complete discharge of each parties' marital claim. " 16. MlSC8LLANBOUS All assets including, but not limited to, savings accounts, chee king accounts / certiHcates of deposit and life insurance policies shall be the sole and separate property of the title holder of said asset. 9 I,I....J' f~\ The parties believe and agree/ that the ~ivision of property hereto made by this Agreement is a non-taxable division of property bet~een co-owners rather than a taxable sale or exchange of such pro( erty. Each party promises not to take any position with reslect to the adjusted basis of the property assigned to him or her or with respect to any other issue which is inconsistent w~th the position set forth in the preceding sentence on his or her fedEral or state income tax returns. A. 17. GENBRAL PROVISIONS WARRANTY AS TO BXISTING OBLIGATIONS Each party replesents that they have not heretofore incurred or contracted for any debt or liability or obligation for which the estate of the othEr party may be responsible or liable except as may be provided for in this Agreement. Each party agrees to indemnify or hold the othE r party harmless from and against any and all such debts, Hak iHties, or obligations of every kind which may have heretofore beel incurred by them, including those for neoessities, except for the obligations arising out of this Agreement. B. WARRANTY AS TO FUTURB OBLIGATIONS - Wife and Husband each I, covEnant/ warrant, represent, and agree that eaoh will now and at all times hereafter save harmless and keep the other after the execution date of this Agreement, exoept as may be otherwise 10 . . I. . ,""."\ specitioally provided tor by the terms of this Agreement and that neither ot them shall hereafter inour any liability whatsoever for which the estate of the other may be liable. C. SBVBRABILITY 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 al other respects this Agreement shall be valid and continue in ~ull force, effect, and operation. Likewise, the failure of any party to meet his or her obligations under anyone or more of the paragraphs herein, with the exception of the satisfaction of the conditions precedent, shall in no way void or alter the remaining obligations of the parties. D. OTHIBR DOCUMENTATION - Wite and Husband covenant and agree that they will torthwith execute any and all written instruments, assignments, releases, satisfactions, deeds, notes or such other writings as may be necessary or desirable for the proper effectuation of this Agreement, and as their respective counsel shall mutually agree should be so executed in order to carry out fully and effectively the terms of this Agreement. lB. BNTIRIB AGRBBMIiNT - This Agreement contains the entire understanding of the parties, and there are no representations, warranties, covenants, or undertakings other than those expressly set forth herein. 11 . I" lit ,j,;UI/Il, -., .,. WAIVBR OR MODIFICATION TO Blil IN WRITING - No modification or waiver of any of the terms hereof ahall be valid unless in writing and signed by both parties and no waiver of any breach hereof or default hereunder shall be deemed a waiver of any subsequent default of the same or similar nature. G. MUTUAL COOPBRAT1.0N - Bach party shall, at any time and from time to time hel':eaftor, take any and all steps and execut.e, acknowledge, and deliver to the other party any and all further instruments and/or documents that the other party may reasonably require for the purpose of giving full force and effect to the provisions of this Agreement. H. LAW GOVERNING - This Agreement shall be construed and governed in accordance with the laws of the Commonwealth of Pennsylvania. I. BINDING EFFBCT -- Bxcept as otherwise stated herein, this Agreement shall be binding and shall inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors, and assigns. J. NO WAIVBR OR DBFAULT - This Agreement shaJ.1 remain in full force and effect unless and until terminated under and pursuant to the terms of this Agreement. The failure of either party to insist upon strict performance of any of the provisions of this Agreement st)all in no way affect the right of slIch party 12 I'" ..' ""1, I'~~" herEatter to entorce the same, nor dhall the waiver of any breach of any provision hereot be construed as a waiver of any subsequent deflult of the ~ame or similar nature/ nor shall it be construed as a weiver of strict performance of any other obligations herein. K. HBADINGS NOT PART OP AGRBEMENT - Any heading preceding the text of the several paragraphs and subparagraphs hereof are insErted solely for convenience or reference and shall not COnE titute a part of this Agreement nor shall they affect its mearing, construction, or effect. L. ADDRESS OF PARTIES - Each party shall at all times keep the other informed of his or her place of residence, and shall pron,ptly notify the other of any change, giving the address of the new place of residence. M. 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" ")1 .'i\ I, '.'1 I " " , , , " , , .' , " ,1\ " :' '.i I " , II 'I ! Ij " ,I , 'I If I i'l 1'1,1 " :.1 I, I, 'i I' , , 1 'I ~ I " '\ ,\ ,(I' il'l, " , 'II . ,I , " \, I> ,.'1 I 'I 1 " 'I ',' 1\ 'I ;11 " "Ii , :.Il' di 1 I' II,i' \l! " ii'ij 'II 'I" ,~ . . 018811 A. ISLIHOP, Defendant I I I I CIVIL ACl'ION - LAW Q I ~~ I NO. 95-613 ~t;': I ACTION IN D1Voaclfeel tI\ ,r: :::; , 11[~ l: , ~.:: ("', IlT" , ,.. ~;~ WVB:":1 N~TI;~ 0:0 I:rIl~ION TO R:~UBST :1 i.!~Q~ rlo!~f o~ ~H~ g~~~R~ COPIJ IN TII8 COURT or COMMON PLIAS CUMBlIRLNlD COUNTY, PJDlNSYLVANIA MAlUt 8. ISLINGP, Plaintiff v. ..0 ~ IJ', ':":1 ) tc 'r I J~ ~, .." :~ :f w ,,~ ,. tl1 ?i - 1. I consent to the entry' of a tinal decree, of divorce without notice. 2, I understand that I may lose division of property, lawyer'S fees or them before a divorce is granted. 3. I under,stand that I will not be divorced until a divorce rights concerning alimony, , expenses if I do not claim .. decree is entered by the Court and that a copy of a decree will be sent to me i~diately after it is filed with the prothonotary. " . I verify that the 'statements made in this affidavit are true andlcorrect. I understand that false statements herein are made , \ . sul:ljec't. to t1t.peli~lties of 18 Pa. C.S.A. Section 4904 relating to .... , unsworn falsification to authoritie.. Date,.:oAy-J/, I{)ti~ ~ 71. &.tj ~ Debb . A. 8Slinger1' Defendant - c!.1A. ~ 'J, l.41 " "I "!fr':'1 'I ',:(;:~'I, ,,'I'(,:\fi, " ',(\i'Ji" ,'I "ti ".-",oj "I-':;"H~ .'Ii"-' " ," (f,~ :-1\':/' , ~\ r-~ ,_,:;,;;l/;II::: "j ~'\,l~i ;.,i'i i';;ll11.J! , .;,',/ 'r,:r~ "_',il~ I"_\)A. 'ili,'lift I,i. 'jt~ .'i',;~~ , ' '. :'~" " I, :' "ill :-f1"nJ'f.t ",1" ;,l;.!l~' i ;',,{11I " "I' ,I",il ';1" : -I r :\\':.~:;J ;,I.\r/ : I jitk: """:!l)~ \. ;,;I;;/r\i!1\~ , l'jr'\\."!r.1 "'ill""/['JJ' '! 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" " " , '.,' ~. ~\914 1 d: , , , I, " I, I 'I" , " , , " I ',I " " ,,",' if, " , "11 '" " " q, , '" " ,II "ARK ESLINIER, : IN THE COURT OF CO""ON PLEAS Plelntl" : CUnDERLAND COUNTY, PENNSYLVANIA Y. . : NO. _ --- DEDDIE A. ESLINGER, : CIVIL ACTION - LAW D,"ndent : IN DIVORCE COMPLAINT IN DI"QIU PUllUArP TO 'JI:TIQIII ]]OU~) 01 ~~~,rlll OnNI: 01"011:1 CQDI OF I GIIO COUNT I DI"Olel AND NOW. comes the Plelntt f f by hIs ettorney, The Lew Offlcee of Demll C. D.thlefs, end respectfully represents es follows: 1. Plelntlff II Merk Eslinger, en lllMt Ind1vlduel woo currentllj relld8$ et 954 flrlel< ChurCh Roed, Enole, ClIl1b.rlend County, Pennsylvenle. 2. Ollf.ndent Is Debbie A. EslInger, en edult Indtvtduel curr.ntly residIng et RD II I, flox 762, Sh.rmenedele, perry County, Penneylvenle, 3. Plelntl" end D.fendent ... SUI JJrl s, end both hew been bonlfted resld.nts of the Commonw.elth Of Pennsylvenle fa- II perIod of more then Ilx (6) months Imm.dletely prec.dlng the filing Of thle Complelnt. 4. Th. perU.. were merrled on the 2ath dey of Ney, 1911a et Enole, 5tet. of p.mlylvente. 5. D.f.ndent te not In the ml' Itery or nllvlll eervtc. of the unl ted Stet.. or tI, elll" withIn the provIsIons of the SoldIers' erd Sellors' Clvt\ RelIef Act of The Congr..e of 1940 Ilnd I t6 Amendments, 6. Th.re hllve been no prIor ectl0l11 of dIvorce a- en~lment betw.n the p..tt" In thIs or eny other lurlsdlctlon. " I, ,. 'I Ii' ;1'1 1 , ,I I Ii , " , I " , I ,\ ,., I, I, 'I I' i'I, , I " '. I, ;1 ii' ,I " .. I, d) 'Ii" t:'~ "" Il'~ fl',' , "',.1 ,1"1,1 'i;:I'1 I.;;' J" J. {e"l rl,"! ..< '" , , . (.;'~ ,'1 .",. . ! 1 ,\,'1"1 1'.,'1 ;J] C-, :-.-' ), , 'I ~~ -,h )1\'1 \....) " I Q ,lj ", , , ,I 1 I , 'I v. IN THI COI1RT or COtItON PLIAB CUMlBRIJUm COUNTY, PIINNSYLVMIA CIVIL ACTION - LAN NO. 95-613 ACTION IN DIVORCII ~l B. ISLINO.~iaintiff DIBBII A. ISLINOBR, Defendant API'Ip~VIT 01' CQJfSIINT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was tiled on February 6, 1995. 2. The marriage of Plaintitf and Defendant is irretrievably broken and ninety (90) days have elapsed trom the date of filing ot the Complaint. 3. I consent to the entry of a final decree of divorce. 4. I understand that if a claim for alimony, alimony pendente lite, marital property, oounsel fees, or expenses has not been filed with the Court before the entry of a final decree in divoroe, the right to olaim any of them will be lost. I verity that the statemertts made in this Aftidavit are true and oorrect. I understand that talse statements herein are made lubjeot to the penalties ot 18 pa C.S.A. Section 4904 relating to unlworn talsification to authorities. Datet~ " By I liUkj)1 \~/\. Debbie A. .Iling , Detendant 'I " ,I I, ,\ I, 'I I " " ,I " !, " , i , , I , " I, I' , 'I 'I II , , " , , I' " , 1 .01 I, '.{'J , 0, ) ,., , L,i;.. ' , I ".j I, 'I 'J I!fr/ ,\) ,.., (i I 'i\,! /:"lli '..... , , ",r\ . , I JlI ,..:"\ " . "/ tJ; ! . .":l ~'('-" (:~:, "I) '. \T.) h.~' , '~,.~ .\./ ~ "'/ .', " I, I' i i I I:' 'I , , "ll 1 ' , , 1 " " 'I,' I' I, ,I , " " , " " i " " " ., , ," 0 ~ ~ " rn , ~... ~I I~ :'2 , 0\ _I.. ' "'tl " r" :l: j' ''- W .~ (J1 ~ - I " \ III " " " , ' , ., , , " i"