HomeMy WebLinkAbout95-01156
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OF CUMBERLAND COUNTY
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CIj~,IS~OP!!ER S. RIT.TERL...,.. ....... :1
Plaintiff
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DECREE IN
DIVORCE
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AND NOW, ..,.... ..ilk':-.. .. -!.! ,~.....,' 19. r~" it Is ordered and
decreed that", "",.", 9fl,lW?';l'p,P'lJe~. ,!l,. RX1"l'ER"",,""" plaintiff,
and,........".......... .rr:~~~:v..r,.~ ..RTrr!'=,R....,. ,.,..".."" defendant,
are divorced from the bonds of matrimony,
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The court retains jurisdiction of the following claims which have
been raised of record In this action for which a final order has not yet
been entered;
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CHRISTOPHER S. RITTER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
No. 95-1156 CIVIL TERM
TRACY L. RITTER,
Defendant
CIVIL ACTION-LAW
IN DIVORCE
?!'.A!C:l'~ :0 nA.~SHI:' R~COR:l
To che ?:othonoca=j:
!rans~1c che recor~, cogether ~ith che :ollowi~g i~:or=acion, co che court
for ent~/ of a divorce decree:
3301(c)
1. Ground for divorce: irretrie'/ab1e breakdown under Section >lXmttllOOK
{OOQ)01! (1) or tl'le Di'/or:e Code. (Scril(e out: i."1applicab1e sec:ion.)
Z. Dace and ::anner or sc~rice 0: tl'le c:cplaint: SERVICE UPON DEFENDANT
BY U.S. CERTIFIED MAIL-R~STRICTED DELIVERY ON MARCH 11, 1995.
3. (Cocp1et:e either ;laragraph (a) or (b) .)
(a) Dace or e~ec~cion or the arfidavi: or consent: required by Section
201(c) or the Divorce Code: by the ?lainti:f
by defendanc
JUNE 15. 1995
JUNE 15, 1995
(b) (1) Date or e~ecution or che plaintiff's affidavic required by
Section 201 Cd) or che Oi'/orce Code: n/..
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(2) Dace or service or the p1a~cif:'s affidavit upon che defendant:
n/a
4. Related cla1=5 pending: NONE
S. Indicate date and canner or ser/ice or the notice or incencion to file
praecipe to trans~ic record, and attach a copy or said notice under section 201
(d)(l)(i) or the Divorce Code.
n/a
Afi1~'
A:Come'/ for (Pbill::.!!)
DAVID A. IlARIC, ESQlJIRE l(1l1l1alll:lb.~
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SETTLEMENT AGREEMENT
THIS AGREEMENT, made this I<;;~ay of JUNE, 1995, by and between
CHRISTOPHER S. RITIER, hereinafter called Husband, and TRACY L. RITIER,
hereinafter called Wife;
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on June 22, 1985, in
Cumberland County, Pennsylvania; and
WHEREAS, differences have arisen between Husband and Wife in consequence
of which they are living separate and apart from each other and have consented to a
mutual consent divorce; and
WHEREAS, Husband and Wife desire to settle and determine their rights and
obligations,
NOW, THEREFORE, the parties, intending to be legally bound hereby, agree as
follows:
1. Separation, It shall be lawful for each party at all times hereafter to
live separate and apart from the other at such place as he or she may from time to time
choose or deem fit. The foregoing provision shall not be taken as admission on the part
of either party of the lawfulness or unlawfulness of the causes leading to them living
apart.
2. Division of Property. The parties have lIivillell between them to their
mutual satisfaction the personal effects, householll furniture anll furnishings, anll other
articles of personal property which have heretofore been usell hy them in common anll
neither will make any claim to any such items which are now in possession or control of
the other except as otherwise set forth herein. Hushanll acknowlellges receipt of the
items of property illentifiellon the attachell Exhihit "A". Husbanll shall take lIelivery of
the items not currently in his possession within sixty (60) lIays of the lIate of this
Agreement. The parties agree that the fair market values of these items is $5,420.00.
Husbanll also shall receive the 1988 Furll Festiva anll 1976 Chevrolet Suhurban as his
separate property with a combinell fair market value of $750.00.
Wife shall receive the 1988 Forll Festiva as her separate property with a fair
market value of $50J.00,
Wife shall retain as her property the items illentifiellon the attached Exhibit "B".
The parties agree that the fair market value of these items is $1,000.00.
The parties acknowlellge that the properties set asille to eaeh shall be the sole
and separate property of the party taking possession of same.
Eaeh party has a retirement account and a profit sharing plan. The parties agree
that they waive any claim anll all interest in the other's retirement and profit sharing
plans and agree to sign any lIocumentation reasonahly requested to effectuate this waiver
of interest.
Each party shall maintain their own health insurance.
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Husband shall be responsible for tbe VISA balance existing as of the date of this
agreement and Wife shall be responsible for an outstanding PHEAA school loan.
3. Dehts. Except for the dehts and obligutions created hereunder,
each party ugrees to pay and hereby agrees to hold the other harmless from any and all
personal debts and obligations incurred by him or her subsequent to January I, 1993, the
date of separation. If any claim, action or proceeding is hereafter brought seeking to
hold the other party liable against any such claim, action or proceedings, whether or not
well founded, each party will at his or her sole expense defend and indemnify the other
party against any loss or liability resulting therefrom. Wife shall pay to Husband $450.00
towards the MetEd bill with payments to be made of $225.00 on or by August 16, 1995
and $225.00 on or by September IS, 1995.
4. Equitable Property. This Agreement constitutes an equitable
division of the parties' marital property. The parties have determined that the division of
this property conforms with regard to the rights of each party.
The division of existing marital property is not intended by the parties to
constitute in any way a sale or exchange of assets,
Each party hereby acknowledges that this agreement adequately provides for his
or her needs and is in his or her best interest, and that the agreement is not the result of
any fraud or undue influence exercised by either party upon the other or by any other
person or persons upon either party. Both parties hereby waive the following procedural
rights:
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A. The right to ohtain an inventory and appraisement of ull murital und
sepurate property as defined hy the Pennsylvaniu Divorce Code.
B. The right to ohtain an income and expense stutement of the other
purty as provided hy the Pennsylvaniu Divorce Code.
C. The right to have the court determine which property is maritul and
which is non-marital, and equitahly distrihutable between the parties that property which
the court determines to be marital.
D. The right to have the court decide any other rights. remedies,
privileges, or ohligations covered by this agreement, including hut not limited to possible
claims for divorce, spousal support, alimony, alimony pendente lite (temporary alimony),
and counsel fees, costs and expenses.
5. Release of All Claims. Euch party, except us otherwise provided for
in this Agreement, releases the other from all claims, liabilities, debts, obligations,
actions and causes of action of every kind that have been incurred, or may be incurred,
relating to or arising from the marriage between the parties. However, neither party is
relieved or discharged from any obligations under this Agreement or under any
instrument or document executed pursuant to this Agreement.
6. Breach. If either party breaches any provision of this Agreement, the
other party shall have the right. at his or her election, to sue for damuges for such
breacb, and seek any other remedy allowed in luw or equity. The party breaching this
contract shall be responsible for the payment of reasonable legal fees and costs incurred
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by the other In enforcing his or her rights under this Agreement, or seeking such other
remedy or relief as may he uvulluhle to him or her. Wuiver hy one party of uny breuch
of this Agreement hy the other purty shull not he deemed a wlllver of llny subsequent,
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simllur breuch or other breaches.
7. Full Disclosure. Husband and Wife each represent llnd warrant to the
other that he or she has mude a full and complete disclosure to the other of all assets of
llny nature whatsoever In which such purty has un Interest, of the source and amount of
the income of sucb purty of every type whatsoever und ull other fucts relutlng to the
subject muller of this Agreement.
ll. Divorce. This Agreement shull not be construed to affect or bar the
right of either Husband or Wife to u true und absolute divorce on legal und truthful
grounds us they now exist or may hereafter urise, Both parties understand and agree
that Wife shall pursue a divorce on the grounds that the murriage is irretrievably broken.
and that both parties will execute. deliver and file the necessary affidavits and all other
petitions or documents necessury to effectuute the divorce pursuant to Section 3301(e) of
the Divorce Code. Husbund agrees thut the marriuge is irretrievably broken.
9. Representation of Purties hy Counsel. Each party has had the
opportunity to have legal counsel to represent euch of them in the negotiation und
preparation of this Agreement and has either been so represented or has voluntarily
chosen not to he represented. Each party has carefully read this Agreement and is
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I, completely aware, not only of Its contents, but also of its legul effect.
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Ill. Additional Instruments. Each of the parties shall on demand or within
a reasonable period thereafter, execute and deliver any and all other documents and do
or cause to he done any other act or thing that may he necessary or desirable to
effectuate the provisions and purposes of this Agreement. If either party fails on
demand to comply with the provision, that party shall pay to the other all attorneys' fees,
costs and other expenses reasonably incurred as a result of such failure.
II. Modification and Waiver. Modification or waiver of any provision of
this Agreement shall be effective only if made in writing and executed with the same
formality as this Agreement, The failure of either party to insist upon strict performance
of any of the provisions of this Agreement shall not he construed as a waiver of any
subsequent default of the same or similar nature.
12. Descriptive Headings. The descriptive headings used herein are for
convenience only. They shall have no effect whatsoever in determining the rights or
obligations of the parties.
13. Governing Law. This Agreement shall he governed by and shall be
construed in accordance with the laws of the Commonwealth of Pennsylvania.
14. Order of Court. With the approval of any court of competent
jurisdiction in which any divorce proceeding may now he pending or which may hereafter
be instituted, this Agreement may he incorpontted in any decree of absolute divorce
which may be passed by said court.
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IN WITNESS WHEREOF, intending to be legally bound hereby, the parties
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hereto have hereunto set their hands and seals the day and year first above written.
WITNESS:
(seal)
VLU#! ~ , (seal)
, TR~Y L. RITIER
domCllic Idi\lll1.'e/rillcr.u~r
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EXHIBIT "A"
CHRISTOPHER S. RITIER
VALUE
1. 13" Color Television $ 50.00
2, All musical equipment $1,570.00
3. MAC/Printer $ 700.00
4. CD/Radio $ 75.00
5. COts/Tapes $1,500.00
6, Camera $ 100.00
7. Personalty $1,425.00
8. 1988 Ford Festiva $ 500.00
9. 1976 Suburban $ 250.00
TOTAL: $6,170.00
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EXHIBIT "B"
TRACY L. RIITER
TOTAL:
VALUE
$1,000.00
$ 500.00
$1,500.00
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2.
Various Household Furnishings/Materials
1988 Ford Festiva
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTy,pENNSYLVANIA
NO. 95- 1/16 CIVIL ~t""
CIVIL ACfION.LA W
IN DIVORCE
CHRISTOPHER S. RITfER,
Plaintiff
TRACY L. RITfER,
Defendant
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in court. If you wish to defend against the claims set
forth in the following pages, you must take prompt action. You are warned that if you
fail to do so, the case may proceed without you and a decree of divorce or annulment
may be entered against you by the court. A judgment may also be entered against you
for any other claim or relief requested in these papers by the Plaintiff, You may lose
money or property or other rights important to you, including custody or visitation of
your children.
When the ground for the divorce is indignities or irretrievable breakdown
of the marriage, you may request marriage counseling. A list of marriage counselors is
available in the Office of the Prothonotury at the Cumberland County Court House,
Carlisle, Pennsylvuniu.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, MARITAL
PROPERTY, COUNSEL FEES OR EXPENSES BEFORE THE FINAL DECREE OF
DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO
CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR ATfORNEY AT
ONCE. IF YOU DO NOT HAVE AN ATfORNEY OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT
WHERE YOU CAN GET LEGAL HELP.
Court Administrator
Cumberlund County Court House
Fourth Floor
Carlisle, PA nOI3
Telephone: (717) 240.6200
CHRISTOPHER S. RITIER,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLV ANIA
NO, 95- CIVIL
CIVIL ACfION-LAW
TRACY L. RITIER,
Defendant
IN DIVORCE
COMPLAINT UNDER SECfIONS 3301(Cl
AND 3301(Dl OF THE DIVORCE CODE
1. Plaintiff is CHRISTOPHER S. RITIER, an adult individual who has a
current mailing address of 157 South Pill Street, Carlisle, Cumberland County,
Pennsylvania.
2. Defendant is TRACY L. RITIER, an adult individual who has a
current mailing address of 1648 Trindle Road, Carlisle, Cumberland County,
Pennsylvania.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for at least six months immediately previous to the filing
of this Complaint,
4, The Plaintiff and Defendant were married on June 22, 1985, in
Cumberland County, Pennsylvania.
5. Tbere have been no prior actions of divorce or for annulment between
tbe parties.
6, The marriage is irretrievably broken.
7. The Plaintiff has been advised of the availubility of counseling and that
she may have the right to request that the court require the parties to participate in
Counseling.
II. Plaintiff requests the court to enter a decree of divorce.
WHEREFORE, the Plaintiff requests the court to enter a decree of
divorce in favor of the Plaintiff and against the Defendant.
COUNT I1.DlVISION OF PROPERTY
9. The parties have acquired home furnishings, motor vehicles, bank
accounts, retirement and profit sharing plans and miscellaneous items of personal
property.
WHEREFORE, Plaintiff requests that the court enter a decree equitubly
distributing suid property.
Respectfully submiued,
O'BRIEN, BARIC & SCHERER
Date: S; I I '1'~
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David A. Baric, Esquire
1.0.# 441153
17 West South Street
Carlisle, PA 17013
(717) 241).61173
Auorney for Pluintiff
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VERIFICATION
I verify that the statements made in the foregoing Complaint are true and correct,
I understand that false statements herein are subject 10 the penalties of III Pa.C.S. ~4904,
relating to unsworn falsifications to aUlhorites.
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CHRISTOPHER S. RITIER,
Pluintiff
IN THE COURT OF COMMON PLEAS OF
CUMI3ERLAND COUNTY, PENNSYLVANIA
NO. 95-1156 CIVIL TERM
CIVIL ACfION-LA W
IN DIVORCE
v.
TRACY L. RITIER,
Defendunt
AFFIDAVIT OF CONSENT
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A Compluint in Divorce under Section 3301 (c) of the Divorce Code wus filed
on Murch 3, 1995.
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2. The murriuge of Pluintiff und Defemlunt is irretrievubly broken and ninety
days huve elapsed from the date of filing the Compluint.
3, I consent to the entry of a final decree of divorce.
4. I understand thut if a c1uim for alimony, alimony pendente lite, marital
property or counsel fees or expenses has not been filed with the court before tbe entry of
a final decree in divorce, tbe right to claim any of them will be lost.
5. I bave been advised of the avuilubility of marriuge counseling and understund
tbut I may request that the court require thut my spouse and I participate in counseling prior
to a divorce decree being handed down by tbe court.
6, I am not a member of the armed forces, nor in active military service, of the
United States of America or the Commonwealth of Pennsylvania.
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" Section 4904,
relating to unsworn falsification to authorities,
Date: (p /It;;/ 'I S-
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~RISTOPHER S. RITIER
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CHRISTOPHER S. RITfER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 1)5-1156 CIVIL TERM
v.
TRACY L. RITfER,
Defendant
CIVIL ACfION-LA W
IN DIVORCE
AFFIDA VIT OF CONSENT
I, A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed
on March 3, 11)95.
2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety
days bave elapsed from the date of filing 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 or counsel fees or expenses has not been filed with the court before the entry of
a final decree in divorce, the right to claim any of them will be lost.
5. I have been advised of the availability of marriage counseling and understand
that I may request that the court require that my spouse and I participate in counseling prior
to a divorce decree being handed down by the court.
6. I am not a member of the armed forces, nor in aetive military service, of the
United States of America or the Commonwealth of Pennsylvania.
I verify that the statements made in this affidavit are true and correct. I understand
that false statements herein ure mude subject 10 the penalties of 18 Pu. C.S., Section 4904,
relating to unsworn fulsificution to authorities.
Dute:
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 95.1156 CIVIL TERM
CHRISTOPHER S. RI'ITER,
Plaintiff
TRACY L. RITIER,
Defendant
CIVIL ACnON.LA W
IN DIVORCE
CERTIFICATE OF SERVICE
I, David A Baric, Esquire, attorney for the Plaintiff in the above.captioned divorce
action, do hereby certify that I have served a certified copy of the Complaint in Divorce to
the Defendant, as per the attached U.S, Postal Service Certified Mail, return receipt card.
O'BRIEN, BARIC & SCHERER
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DAVID A. BARIC, ESQUIRE
DATE:
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CHRISTOPHER S. RITIER,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
95-1156 CIVIL TERM
TRACY L. RITIER,
Defemlant
CIVIL ACI'ION-LAW
IN CUSTODY
ORDER OF COURT
AND NOW, this J I.' day of
1v......
, 1995, the attached Stipulation
and Agreement is hereby made an Order of Court and an prior Orders in this matter are
hereby vacated.
BY THE COURT,
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CHRISTOPHER S. RlTIER,
Pluintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
95-1156 CIVIL TERM
v.
CIVIL ACfION-LA W
TRACY L. RITIER,
Defendant
IN CUSTODY
STIPULATION AND AGREEMENT
1}v
THIS STIPULATION AND AGREEMENT entered into this ~ day of JUNE,
1995 by and between CHRISTOPHER S. RITIER (hereinafter referred to as "Father") and
TRACY L. RITIER (hereinafter referred to as "Mother").
WHEREAS, the Father and Mother are the natural parents of one child, Alex Ritter,
born February 7, 1988;
WHEREAS, the Father and Mother separated in January, 1993, and the Father has
instituted divorce proceedings at the above term and number; and
WHEREAS, the parties wish to enter into an Agreement relative to the custody and
partial custody of the child; and
NOW, THEREFORE, in consideration of the mutual covenants, promises and
agreements as hereinafter set forth and intending to be legally bound, the parties hereto
agree as follows:
1. The parties shall have joint legal custody of the child.
2. Mother shall have primary physical custody of the child subject to the Father's
periods of temporary physical custody.
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3. Father's periods of temporary physicul custody shall include:
A. Father shall huve custody every other week beginning at 7:30 U.m.
Monday and concluding at 7:30 a.m. the following Monday;
B. Easter Sunday from 11:00 n.m. to noon;
C. Christmas Eve dny;
D, All other holidays and hlrthduys falling within Father's alternating
weeks of custody;
E, Such other times as the pnrties muy mutually agree.
4. The purties shall keep each other advised h11l11ediately relative to any
emergencies concerning the child and shall further take any and all necessary steps to ensure
that the health. welfare. and well-helng of the child Is protected.
5. The purtles shull du nuthlng that may estrllnge the child from the other or
inhibit naturul develupment of the child's luve und uffectlon for the other party.
6. Both parties shull have reusonahle telephune cuntact with the child during
periods when the other purent Is exercising physical cusllldy.
Neither party shall remuve the child from the Commonwealth of Pennsylvania
except for a vucatiun perlml of not more thun une week in a culendur year.
7. Any mudlflcutlun ur waiver of nny of the provisions of this Agreement shall
he effective only if made In writing und only If executed In the sume formality of this
Agreement. The purtles shull recognize the child us u dependant for tUJ( purposes on an
alternating husls hy yeur with muther to c1ulm the child us a dependunt for the 1995 tUJ(
yeur.
8. The parties agree that in making this Agreement there has been no fraud,
concealment, overreaching, coercion or other unfair dealing on the part of the other.
9. The parties desire that this Agreement he made an Order of Court through
the Court of Common Pleas of Cumberland County, and further acknowledge that the Court
parties' minor child and shall retain such jurisdiction should circumstances change and either
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of Common Pleas of Cumberland County has jurisdiction over the issue of custody of the
party desire further or require further modification of said ORDER.
WITNESS:
Wi(j~/!::-
tlnmcM lr/l'Uloltl\l)'/rillcr.10111
COMMONWEALTII OF I'ENNSYLVANIA
COUNTY OF CUMIlIIRL/\ND
PEl~SONALI.Y Al'l'EAlmD IIEFOIm ME, this IS'" 1:0 day of JUNE, 1995, a
: ss:
Notury Puhllc, In und fnr thc Cllnlmonweulth of Pennsylvunlu and County of Cumberland,
Chrlslllpher S, I~lller. known to me (or sutlsfuclllry proven) to he the person whose name
Is suhscrlhed 10 the within Sllpulullon und Agreement, und ucknowledges that he executed
the sume for the purposes therein contulned,
IN WITNESS WIIEIWOF, I huve hereto set my hllnd und officlul seal.
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COMMONWEALTII OF PENNSYLVANIA
NottIIlaJSoaI
NWJJ F. u')J01', Nol.1/y NlIc
CQIISIe [lo(o, Cumolltlllld County
MY t:(OOBt'CO E>PII!l1 O:t. 7, 1996
III 'I ~ns' anIti,\,,-'\C(jtlllOllCll ;:m03
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COUNTY OF CUMBERLAND
PERSONALLY API'EAIWD BEFORE ME, Ihis / r t." day of JUNE. 1995. a
Nntury Puhllc, In und for the Conllnonwculth of Pennsylvania and County of Cumberland,
'I'rucy L. Rlller, known to me (nr sUllsfuclOry proven) to he the person whose name is
sllhscrlhed tn Ihe within Sllpulution und Agreement. and acknowledges that he executed the
sume for the pllrpnses Ihereln contulned.
IN WITNESS WIIEIUlOF, I have hereto set my hand and officiul seal.
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NoIn1l.~ Solll
Argoin F, UIVJor, Not",y NlIc
CO~$k) 11<rio, CI~' IJtlIlurid County
My Cunnll$t;l(:III';.W~1 O:t. 7, 10'J0
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