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HomeMy WebLinkAbout95-01848 l.. a) ,E. ,;,l '11.!~/'to:',. ~;~,;~_. f;,B> ~\\ ,'-'.:;-'- "i:'~.,.,.T,' j ~ -0 '..'.....,.. .,J . _o!a) '3' . If) '7 ,',- .-...., i':;... :E:. .c.; -~ J 00 ':j- 00 - . ... .~te.' .~.>' ,OA"" .~.....-.~.".' ."..... .~........-......_...~C.. .~..'.~..... ....... .~..... .~.... ..~.....-:.....-.~.... .~..... .~.".,:<"",,,.,,,,,,,,,,,,,,,,,:.................~........~.................<'*t."C.,,,,,,,"<..,. ....... ._... ............. ..Tr............................... ...,.._...._~.r.r"..........;..........".._"._..._..ll ~ -- Iii . ^ ~ ~ $ IN THE COURT OF COMMON PLEAS $ ~ ~ ~ .'. Pl :~ .'. ~ ~ ~': ,'. ~ ,'~ ~ ~ ... ~.~ ~ ~ ,;, ~ ,'. ~ .~ :, 8 ,;, ~ ~ ~ s ,'. ~ ~ ~ ,,' ~ ,'. ~ w ',' .:i i:; ,(. ,', ~ ,;, ~ v ',' $ ~ ,; ~ .'~ ~ ~ t $ s ~ Iii ~ .,' ~ S ~ ~, ~ ,. ~ ~ ~ ~ I ~ ~~ ...-;""'" , OF CUMBERLAND STATE OF . COUNTY PENNA. IJANIEL. L.,. W..EIDENIIAMMER. II~ q,.....,q........ II N (I, .....1.m.........., ................. 1995 P.Il\1ntifL.... .'1 :1 Vlll'StlS .,,~TEI,LA L... .W.EIDENI.lAI1MER,. '! I ;1 Defendant ii ~ (~ " !.' DECREE IN DIVORCE i:i ~ :~ ~ ~ " ., :'1 ~ ,', ~ " ~ ,': ~ ~.~ ~ " ~ ~'. ~ ',' AND NOW, ' .. .. .. .. .. ,1~ .. ,?,~:, .. " 19,9,5...., it is ordered and decreed that "," ,~lI;~~,\~ ,~', ,1-!,\~~,\~ll'!~'\t;., ,~H, ,." ,.'" " , , , " plaintiff, ond ,...... , ,S~l'n\l, \." \'I1'~~I'P\JPl"\llH, , ,.. , .. , , , ..' ..,..,.. , , , " defendant, are divorced from the bonds of matrimony, 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: ~ ',' , , , , , , :r!l!" ,t!"r!'l~, ~,f, ,t~!', ,s!,p,a.r!1.t.i,o,n, ,a,n,d, 'p,r.op,e,r,t,Y, ,S,e,t,t,l,e,lI\e,n,t, ,A,&r,e,e,lI!e,~t, ,~'\t,~,\,\'1 the PllrtJl!a, dlltl!d, !ofIlY, 2,4", .199.5. .la, h.e.r.ehy, .iJ1.c.o.r.p.o.r,ll,t,e,d. ,ll,8, ,J.f. ,8,,,,t, ,(QI:t;h ,lit; ,~l\ngt;h but shall not erge in the final Divorce Decree between the parties. Dy ye court:/ -::!.; yt-;,i J=/....... ~ti.~/~i:;,?f.'i<-~~ C' t~, f~~';~ J, ~. </!.t1Ln? K. XLet'-' /.1 ,/ f.)rl' Prothonolary ,', ~ ~ ',' ~ ',' ~ ',' ~. -:. '. ." . ... - .. .:.'; ..' ., .... ... - . .... . . :..' ~"'. -. '," - . ; ;. ... ~ . , = .- , ~ -,. .. ~ ~ ',' * ~ ',' " . . . :;, ,;. . ..... ,",- . - ,~ ". '. .'" ''', . ..... .' ...... # .' . .... ............ '.. .-.........___.~ "'-.~.... _,... ~ ~"-" ..... ..~,'. - 1:4t .~~---*~*~****~.**~.**** '. .. , , t . '. SEPARATION AND PROPERTY SETl'LEMENT AGREEMENT THIS AGREEMENT, made this J'( day of fI1A 1 ' 1995, by and between Daniel L. Weldenhammer m, hereinafter referred to as "Husband", and Stella L. Weldcnhammer, hereinafter referred to as "Wife", WITNESSETH: WHEREAS, Husband and Wife were lawfullY married on July 3, 1971 in Carlisle, Pennsylvania; and WHEREAS, one child was born of this marriage; and WHEREAS, certain differences have arisen between the parties as a result <If which,they separated in November of 1988 and now live separate and apart from one another, and are desirous, therefore, of entering into an Agreement which will distribute their marital property in a manner which is considered to be an equitable division of all joint property, and will provide for the mutual responsibilities and rights growing out of the marriage relationship; and WHEREAS, there has been a complete disclosure of the earnings and property of each party, and each understands his/her rights under the Divorce Code of the Commonwealth of Pennsylvania; and WHEREAS, the parties hereto, after being properly advised by their respective counsel, Husband by his attorney, John W, Purcell, Jr, and Wife choosing not to retain counsel have come to the agreement, which follows: NOW, THEREFORE, in consideration of the above recitals and the following covenants and promises mutually made and mutually to be kept, the parties heretofore, intending to be legally bound. covenant, promise and agree as follows: . . . f . Sepamtlon and Property Settlement Agreement Page 2 1, Separation. It shall be lawful for each party at all times hereafter to live separate and apart from the other party at such place that he or she may from time to time choose or deem fit, The foregoing provision shall not be taken as an admission on the part of either party of the lawfulness of the causes leading to their living apart, 2, Interference. Each party shall be free frorn interference, authority and contact by the other, as ful1y as if he or she were single and unmarried 0 except as may be necessary to carry out the provisions of this Agreement. Neither party shal1 molest the other nor attempt to endeavor to molest the other, nor compel the other to cohabit with the other, nor in any way harass or malign the other, nor in any way interfere with the peaceful existence, separate and apart from the other, 3, Wife's Debts. Wife represents and warrants to Husband that since the separation she has not and in the future she will not contract or incur any debt or liability for which Husband or his estate might be responsible and shal1 indemnify and save Husband harmless from any and al1 claims or demands made against him by reason of debts or obligations incurred by her, 4, Husband's Debts. Husband represents and warrants to Wife that since the separation he has not and in the future he will not contract or incur any debt or liability for which Wife or her estate might be responsible and shall indemnify and save Wife harmless from any and all claims or demands made against her by reason of debts or obligations incurred by him, 5, Outstanding Joint Debts. The parties acknowledge and agree that they have no outstanding debts and obligations incurred prior to the signing of this Agreement, except as fol1ows: None In the event that either party contracted or incurred any debts since the date of separation, the party who incurred said debt shall be responsible for the payment thereof, regardless of the name in which the account may have been charged, and such party shall indemnify, uefend and hold the other party harmless from any claim or demand made against that party by reason of such debt. 6, Equitable Distribution of Marital Property. The parties have attempted to distribute their marital property in a manner which conforms to the criteria set forth in ~350I et. seq. of the Pennsylvania Divorce Code and taking into account the following considerations: the length of marriage; the fact that it is the first marriage for Husband and Wife; 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 to the education, training or increased earning power of the ., f , Separation and Property Settlement Agreement Page 3 othcr party; the opportUnity of cach party for future acquisitions of capitlll assets and income; the sources of income 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 appreciation of the marital property, including the contribution of each spouse as a homemaker; the value of the property set apart to each party; the standard of living of the parties established during the rnarriage; and the economic circumstances of each party at the time the division of property is to become effective, The division of existing marital property is not intended by the parties to constitute in any way a sale or exchange of assets, and the division of being effected without the introduction of outside funds or other property not constituting rnarital property, The division of property under this Agreement shall be in full satisfaction of all marital rights of the parties, A, Distribution of Personal Property. The parties hereto mutually agree that they have effected a satisfactory division of the furniture, household furnishings, appliances, and other household personal property between them, and they 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 the effect of an assignment or bill of sale from each party to the other for such property as may be in the individual possession of each of the parties 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 claim to any such items of marital property, or of the separate personal property of either party, which are 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 to be in the possession or under the control of either party if, in the case of tangible personal property. the item is physically in the possession or control of the party at the time of the signing of this Agreement and, in the case of intangible personal property, if any physical or written evidence of ownership, such as passbook, checkbook, policy or certificate of insurance 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 their own individual pensioll or other employee benefit plans or retirement benefits of lIny nature to which either party may have a vested or contingent right or interest at the ., f Separatlon and Property Settlement Agreement Page 4 time of the signing of this Agreement, and neither will make any claim against the other for any interest in such benefits, except as stated herein, From and after the date of the signing of this Agreement, both parties shal1 have complete freedom of disposition as to their separate property and any property which is in their possession or control, pursuant to this Agreement, and may mortgage, sel1, grant, convey, or otherwise encumber or dispose of such property, whether real or personal, whether such property was acquired before, during or after marriage, and neither Husband nor Wifc need join in, consent to, or acknowledge any deed, mortgage, or other instrument of the other pertaining to such disposition of property. B, Distribution of Real Estate. Husband shall transfer to Wife concurrent with the execution of this Agreement, al1 of his interest in and title to their jointly owned real estate at 16 Forge Road, Boiling Springs, Cumberland County, Pennsylvania in exchange for which Wife agrees to be solely responsible for the first mortgage obligation to First Federal as well as for the payment of all current and future taxes, insurance and utility bills relative to said real estate, Wife covenants and agrees to pay and discharge said obligations on said premises, and agrees to indemnify Husband from any loss by reason of her default in the payment thereof, and agrees to save Husband hannless from any future liability with regard thereto, including the cost of defense and actual counsel fees incurred to defend lIgainst an action brought against him by vinue of her default, The second mortgage shall be paid as set forth in paragraph 10, 7, Vehicles. Notwithstanding Paragraph 6 of this Agreement, Husband shal1 retain possession and ownership of the 1986 Chevrolet Celebrity and 1984 Plyrnouth Reliance presently in his possession, Wife hereby transfers all of her right, title and interest in said vehicle to Husband, In consideration thereof, Husband shall assume full responsibility for payment and eventual satisfaction of any and all liens presently encumbering the vehicle, and to indemnify, defend and hold Wife hannless for the same, Wife hereby agrees to sign any title or other documents necessary to transfer ownership of said vehicle at any time. upon demand, and further shall indemnify Husband for any costs, including actual counsel fees, incurred by Husband to enforce this provision, Notwithstanding Paragraph 6 of this Agreement, Wife shall retain possession and ownership of the 1988 Buick and the 1966 Mustang Convertible presently in her possession, Husband hereby transfers all of his right, title and interest in said vehicle to Wife, In consideration thereof, Wife shall f , Separation and Property Settlement Agreement Page 5 ' assume full responsibility for payment and eventual satisfaction of lIny and all liens presently encumbering the vehicle, and to indemnify, defend and hold Husband harmless for the same, Husband hereby agrees to sign any title or other documents necessary to transfer ownership of said vehicle at any time, upon demand, and further shall indemnify Wife for any costs, including actual counsel fees, incurred by Wife to enforce this provision, 8, Alimony, Both parties acknowledge and agree that the provisions of this Agreement providing for equitable distribution of marital property are fair, adequate and satisfactory to them, and are accepted by them in lieu of and in full and final settlement and satisfaction of any claims or demands that either may now or hereafter have against the other for support, maintenance or alimony, Husband and Wife further, voluntarily and intelligently. waive and relinquish any right to seek from the other any payment for support or alimony, Each party shall indemnify, defend and hold the other harmless against any future action for either support or alimony brought by or on behalf of the other, such indemnity to include the actual counsel fees of the defendant in any such future action, 9, Custody. Physical custody of the parties' rninor child Daniel L, Weidenhammer IV, shall remain in Wife, subject to Husband having temporary custody for purposes of visitation, at such dates and times as the parties may from time to time mutuaHy agree, 10, Support. Husband shaH pay to Wife for the maintenance, education and support of their minor child, the sum of $35,00 per rnonth, In addition, Husband shall continue to make all payments on the second mortgage to First Federal in the approximate amount of $200,00 per month, which shaH be considered child support and shall be paid to First Federal by Husband for so long as he would be obligated to pay child support under this Agreement or according to law, Once the parties' child has reached the age of 18, it shall be wife's responsibility to make payments on the second mortgage to First Federal as aforesaid, 1 I. 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 maritlll property of the parties is fair, adequate and satisfactory to them, Both parties shaH accept the provisions set forth in this Agreement in lieu of and in full and final settlement 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 after the commencement of any proceedings for divorce or annulment between the ~ Separation and Property Selllement Agreement Page 6 parties. Each part)' shall be responsible for his or her own counsel fees, and each agrees to Indemnify, defend and save the other harmless frorn any action commenced against the other for alimony pendente lite, counsel fees and/or expenses, 12, Divorce. A Complaint in Divorce has been filed to No, _ in the Court of Common Pleas of Cumberland County, Pennsylvania, and either part)' shall be free to proceed without further delay to secure the divorce, Both parties shall sign an Affidavit evidencing their consent to the divorce, pursuant to ~3301{c) of the Divorce Code, In the event, for whatever reason, either part)' fails or refuses to execute such affidavit upon the other party's timely request, that part)' shall indemnify, defend and hold the other harmless from any and all additional expenses, including actual counsel fees resulting from any action brought to cornpcl the refusing part)' to consent. Each party hereby agrees that a legal or equitable action may be brought to compel him or her to execute a Consent form and that, absent some breach of this Agreement by the proceeding party, there shall be no defense to such action asserted, 13. Time of Distribution. The assets and interests to be transferred under and pursuant to this Agreement shall be conveyed and transferred to the respective parties immediately upon the execution of this Agreement, All spousal support and other such obligations, including alimony, shall immediately terminate, The parties shall cooperate by executing whatever documents arc necessary to effectuate a divorce under ~3301{c) or ~3301(d) of the Pennsylvania Divorce Code, and this Agreement to cooperate shall be enforceable by an assumpsit action for specific performance, However, upon refusal to consent, all distributed property shall be returned to the party originally in possession, until the time of final Decree, 14, Release. Subject to the provisions of this Agreement, each party has released and discharged, and by this Agreement docs for hirnself or herself, and his or her heirs, legal representatives, executors, administrators and assigns, release, indemnify (including actual legal fees) and discharge the other of and from all causes of action, claims, rights, or demands, whatsoever in law or equity, including equitable distribution, spousal support, alimony, counsel fees, alimony pendente lite, and expenses which either of the parties against the other ever had, now has, or may have in the future under the Pennsylvania Divorce Code. as amended, or under any other statutory or common law, except any and all causes of action for divorce and all causes of action for breach of any f Sepamllon and Property Selllement Agreement Page 7 provisions of this Agreement, Each party also waives his or her right to request marital counseling, pursuant to ~3302 of the Divorce Code. IS, 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 hereafter acquire under the present or future laws of any jurisdiction, to share in the property or the estate of the other as a result of the marital relationship, including without limitation. dower, curtesy, statutory allowance, widow's allowance, right to take in intestacy, right to take against the Will of the other, and right to act as administrator or executor of the other's estate, and any right existing now or in the future under the Pennsylvania Divorce Code, as amended from time to time, and 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 interests, rights and claims, 16. Rights on Execution. Immediately upon the execution of this Agreement, the rights of each party against the other, despite their continuing marital status, shall terminate and be as if they were never married, 17, Breach. In the event of breach of any of the terms of this Agreement, the nonbreaching party shall be paid, as part of a:lY award or judgment against the breaching party. all costs, including actual counsel fees paid to his or her attorney, 18, Incorporation In Final Divorce. The terms of this Agreement shall be incorporated but shall not merge in the final divorce decree between the parties, This Agreement shan survive in its entirety resolving the spousal support, alimony, property and other interests and rights of the parties under and pursuant to the Divorce Code of the Commonwealth of Pennsylvania, This Agreement may be enforced independently of any support order, divorce decree or judgment and its terms shall take precedence over same, remaining the primary obligation of each party, This Agreement shall remain in fun force and effect regardless of any change in the marital status of the parties, It is warranted, covenanted and represented by Husband and Wife, each to the other, that this Agreement is lawful and enforceable and this warranty, covenant and representation is made for the specific purpose of inducing the parties to execute the Agreement. .. ~ Separation and Property Settlement Agreement Page 8 19, Additional Instruments, Each of the parties shall from time to tirne, at the request of thc other, execute, lIcknowledge and deliver to the other party, any and all further Instruments that may be reasonably requircd to give full force and cffect to the provisions of this Agrcement, 20, Scparabllity. In case any provision of this Agreement should be held to be contrary to, or invalid under, the law of any country, state or other jurisdiction, such illegality and invalidity shall not in any way affcct the othcr provisions hereof, all of which shall continue, neverthelcss, in full force and effect, and each paragraph herein shall be deemed to bc a separate and undisputed covenant and agreement, 21. Entire Agreement. This Agreement contains the entire understanding of the parties and there arc no representations, warranties. covenants and undertakings other than thosc expressly set forth herein. Husband and Wife acknowledge and agree that the provisions of this Agreement with rcspect to the distribution and division of marital and separate property are fair, equitable and satisfactory to thcm. based on thc length of their marriage and other relevant factors which have been taken into consideration by the parties, Both parties hcreby accept the provisions of this Agreement with respect to the division of property in lieu of and in full lInd final senlement and satisfaction of all claims and demands that they may now have or hcrcafter have against the other for equitable distribution of their propcrty by any Court of competent jurisdiction pursuant to Section 3502 of the Divorce code or any othcr laws, Husband and wife each voluntarily and intelligently waive and relinquish any right to seek a Court ordcred detcrmination and distribution of marital property, but nothing herein contained shall constitute a waiver by either party of any rights to seek the relief of any court for the purpose of enforcing the provisions of this Agreement, 22, Modification and Waiver. A modification or waiver of any of the provisions of this Agreement shall be effective only if made in writing and executed with the same formality as this Agreement. The failure of either party to insist upon strict performance of the provisions of this Agreement shall not be construcd as a waiver of any subsequent default of the same or similar nature, 23. Intent. It is the intent of the parties by this Agreemcnt to fully and finally foreclose any resort to the Courts for relicf on the basis of any statute or case law presently existing or which rnay exist at somc time in the future within the Commonwealth of Pennsylvania. including but not Iimitcd to equitablc distribution, alimony and other relief under the Pennsylvania Divorce Code, as amended, This Agreement has been drafted and acccpted on the basis that such resort would " f Separation and Property Settlement Agreement Page 9 constitute a breach under this Agreement, entitling the nonbreaching party to reimbursement for actual counsel fees, Other than as provided by the terms of this instrurnent, it is intended that the Court shall treat the parties as if they had never entered into a marillll relationship, This Agreement shall be interpreted and governed by the laws of the Commonwealth of Pennsylvania and, where such law is inconsistent, the terms of this instrument shall govern, 24, 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 acknowledges that the Agreement is fair and equilllble, that it is being entered into volunlllrily, with 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 information relating to the financial affairs of the other which has been requested by each of thern or by their respective counsel. 25, 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, 26, 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, 27, Reconciliation. Notwithstanding a reconciliation between the parties, this Agreement shall continue to rernain in full force and effect absent a writing signed by the parties stating that this Agreement is null and void, IN WITNESS WHEREOF, the partics hereto have hereunto set their hands and seals the day and year first above written, WITNESS: 'I Iii' /, I / ,. rf' L--... ~ 7 fiA'IEL L, WEIDE MER III \;~ltlu f? (lltlcg-nk/JJ;J;te.u STELLA L, WEIDENHAMMER VS, STELLA L. WEIDENHAMMER, Defendant E COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 95-1848 CIVIL ACTION.LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD THE PROTHONOTARY: Transmit the record, together with the following information, to the Court for entry of a Divorce Decree: 1. Ground for divorce: Irretrievable breakdown under Section (X) 3301(c) () 3301(d)(I) of the Divorce Code, 2, Date and manner of service of the Complaint: Certified Mall on April 12, 1995 3, (Complete either paragraphs (a) or (b), (a) Date of execution of the Affidavit of Consent rcquired by Section 3301(c) of the Divorce Code: by Plaintiff: July 13, 1995 by Defendant: July 13, 1995 (b) (I) Date of execution of the Plaintiffs Affidavit requircd by Section 330I(d) of the Divorce Code: (2) date of service of the Plaintiffs Affidavit upon the Defendant: 4. Related claims pending: None. 5, Date and manner of service of the notice of intention to file Praecipe to transmit rccord, a copy of which is attached, if the decrec is to be cntered under section 3301(d)(l) of the Divorce Code, N/A \.r'> en ,. - ., :C c- o ,. (<') <:n -. = --, In ~n , , .[> "'f '- , ','"""" 1'.-1 r.-, .~ " ~,-.. ',:", .........~, ~ ------. \>-, '" ~y, ...\ "0 '" r-;, '- ':J. ,- rlS ,~- ) = " r '" ,:J i .::-----., -j:J ' '~ '\ '.-.J " - ~~ -......, ""- ,~'" \ r- "'--, __) '--..'"' . r-. ' .) '-4' ~ ; "'- "-- \r:') l:,~ d. .. - ~ i ~ ~ ~~ H Pl~ H H ~~ . ~ . ~'" ~ j~ o . ~~ ~~ ~ ffi.... ffi~ 0 I I=l~ I=l " ~ f,1U Z H rJ H.e ~~ S~ ~p: ~~ H o I-<U j U UO: . ~ <0 ...:I . ..l ~ is ...:Ii::: d l/l 8 > a ~e~~~ H ~ I=l I-< Ul ~ ~ . :; ... ~ = ~ \t~ 5 ~ ~ ~ ~ ~ " . . = J~ ;; . ~ ~ . , . '...."h...O'.Il..' 0f0t"If("O:1A1.l.4I. .UIIU'AI"IUl lftlllIlU"" .- DANIEL L. WEIDENHAMMER III, Plaintiff IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO, 95 1848 CIVIL TERM vs, STELLA L, WEIDENHAMMER. Dcfcndant IN DIVORCE AFFII>A VIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA: ) ss: COUNTY OF DAUPHIN I, JOHN W, PURCELL, JR" Attorncy for the Plaintiff in the abovc action, hcreby swear and affirm that on thc 12th day of April, 1995. I scnt, by ccrtified mail. return receipt requested, deliver to addressee only. a ccrtificd copy of thc Complaint in Divorcc, containing Notice to Dcfcndant and Claim Rights to Stclla L, Wcidcnhammer. thc Dcfcndant in the above action, Thc rcturn rcceipt. duly signcd by thc Dcfcndant is attachcd hcrcto and madc a part hcreof as Exhibit llA". Sworn and subscribcd to bcforc mc this /.( day tlOTAAlAL SEAL J/ltlET R, WOlff, lIolalY PlIbllc ILmlsburo, PA [lJupliln Counly My Comml331oll fln1rc3 :lopt, 4. 1097 ! i E DER: "I . Complet.l"m' 1 ,ndlor 2 101 'ddlClon.I'tlvlc... I, ComJQI. It.m. 3. .nd A. . b. I . Print you, R.me and .dd"" on the "V"" of thl. torm 10 thlt w, cln I.tum Itn clld 10 you. , AIIKh ,hi' 10"" 10 Iho ',onl or lho m,lIplm, o. on ,ho b". If ,poeo 0 Add'.....'. Add'... ' dOli not Ptlmlt. I . Writt"R.tumR'ctlptR~'I.d"onthlm.Ilp1K.bllowlht"llcltnumbe', 2. p;;;) Restricted Delivery .&J l' . 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