HomeMy WebLinkAbout95-03066
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: IN THE COURT OF COMMON PLEAS :
. OF CUMBERLAND COUNTY ~
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I STATE OF ~..'. PENNA. .
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. Th:::-a:Jor:. P. C,on:::J0I1/JI[ '; .
No. Q30lpltJ c.lvIL. 1~/!5
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.. Versus .
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: DECREE IN .
. DIVORCE :
~ ANDNOW/.~~.P..-~h,:-H.~.?~.."". 191<.1... It II ordered and .
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.. decreed that ..\.~~.~r~.~.,;-\.\...c,~.\.:'..(.,:......;(-........, plaintiff, ~
I :~ ~1~:';::~;~:~;d~:1 ~~~~:~~\V:~. do/endant. !
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. The court retalnl jurisdiction of the following claims which have ..
. been railed of record In thll action for which a final order has not vet !
. been entered: ..
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MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made thlsfll'day 01 de fll, A.D., 1995, by and between
Ang.l. T. Gordon, hereinafter called Wife, and Theodore P. Gordon, III, hereinafter
called Husband.
WITNESSETH:
WHEREAS, Husband and Wile were united In the bonds 01 matrimony on the 30th
day 01 April, 1986; and
WHEREAS, one child was born 01 the marriage; Christopher M. Gordon, whose
date 01 birth Is September 11, 19BB; and
WHEREAS, Husband and Wile acknowledge that said marriage Is Irretrievably
broken and the only solution lhereto lIel in divorce; and
WHEREAS, Husband and Wile desire to settle and determine their mulual property
rights: and
WHEREAS, Husband and Wile are legally competent; and
WHEREAS, Husband and Wile have Inlormed and advised each other 01 their
mutual property, estate and prospects; and
WHEREAS, Wile Is presently represented by Carl L1edebaum, Esquire.
WHEREAS, Husband II not presently reprelented by legal counlel.
NOW, THEREFORE, lor and In consideration 01 the mutual promlaes and
undertakings contained herein by each of the parties, and in consideration 01 the other
good and valuable considerations hereinafter let forth. the parties hereto, intending to b.
legally bound, covenant and agreo as follows:
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1. VOLUNTARY AGREEMENT: Ills acknowledged by the parties that this
Agreement Is entered Into voluntarily and after due deliberation by each of them.
2. SEPARATION AND NON.INTERFERENCE: It shall be lawful for Husband
and Wife at all times to live separate and apart from each other and to reside from time
to time at such place or places as thsy shall respectively deem fit, free from any control,
restraint, or Interference, Indirect or direct, from each other. Neither party shall harass
the other nor compel the other to cohabit or dwell with him or her by any legal or other
proceedings. The foregoing provisions shall not be taken to be an admission on the part
of either Husband or Wile of the lawfulness or unlawfulness of the causes leading them
to live apart.
3. DIVORCE ACTION: Husband and Wife acknowledge that Husband has
commenced an action in absolute divorce against Wife in Cumberland County, namely
Gordon v. Gordon, entered to Civil Term No. 1995-03066, using as a ground the no-faull
provision as found In Section 3301 (c). The parties hereby agree that the terms of this
MARITAL SETTLEMENT AGREEMENT shall constitute a full and final settlement of all
their respective claims In such action and that all such claims raised in such action shall
be marked "Settled" in accordance with the terms of this MARITAL SETTLEMENT
AGREEMENT, and the parties further agree to execute any affidavits of consent
necessary to effect a consensual divorce after the expiration of ninety (90) days after the
filing of the divorce complaint.
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4. MOTOR VEHICLES: Each party currently has In his or her possession
a motor vehicle, Wife having a 1988 Ford Thunderbird and Husband having a 1970 Ford
Thunderbird. Each party shall retain said vehicle lor his or her own exclusive use and
the parties agree In connection with this Agreement to execute any documents necessary
for transferring of titles in order to convey sole ownership of the respective vehicles to
Husband and Wife.
6. PERSONAL PROPERTY: It Is agree that all personal property now
In the possession of each party Is conslderod his or her respective personal property, and
each party hereby relinquishes any claim to personal property currently In the possession
of the other party.
6. DEBTS OF THE PARTIES:
(a) Husband shall pay the following debts and will not at any time hold
Wife responsible for them, and shall indemnify Wife from any liability on 8ame:
1. Beneficial loan.
2. American General loan.
(b) Wife shall pay the following debts and will not at any time hold
Husband responsible for them, and shall Indemnify Husband from any liability on same:
1. Firestone charge.
2. Seventh Avenue charge.
3. Kings charge.
4. Montgomery Wards charge.
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(c) Any other debts of the parlles, whether considered marital or
otherwise, and whether Incurred before or after the date of separation, shall be
considered the sole debt of the party In whose name the debt was Incurred.
(d) The parlles agree that they will not In the future contract or Incur any
debt or liability for which the other party, his or her property or estate might be
responsible, and each further agrees to Indemnify and save harmless the other party
against any claims that may be asserted by anyone against the other party by reason
thereof.
7. MUTUAL RELEASE: Except as provided for In this Agreement, the
parties hereby remise, release, quit-claim, and forever discharge each other and the
estate of each other, for all lime to come, and for all purposes whatsoever, from any and
every claim, Including alimony, alimony pendente-lite, equitable distribution of marital
property, counsel fees or costs under the Divorce Reform Act or spousal support, or
otherwise, that they make or hereafter make In and to or against each other's estates or
any parts thereof. whether by way or dower or curtesy, or under the Intestate laws, or the
right to take or elect against the other's will, except only such rights as accrue pursuant
to this Agreement.
8. EXECUTION OF DOCUMENTS: Husband and Wife shall at all time.,
make, deliver and execute any and all further Instruments as shall be necessary lor the
purpose of giving lull force and ellect to this Agreement.
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9.
NON.MERGER IN DIVORCE DECREE:
The parties agree that In the
event of absolute divorce between them, they shall nonetheless continue to be bound by
all the terms of this Agreoment, and neither this Agreement, nor the terms hereof, shall
be deemed to have been merged In any decree or Judgment granted In the divorce action,
but shall survive and be forever binding upon the parties.
10. NON.WAIVER:
The failure of either party to Insist In anyone or more
Instances upon the strict performance of any of the terms hereof In this MARITAL
SETTLEMENT AGREEMENT shall not be construed as a waiver or relinquishment of
such term or terms In the future.
11. BREACH: In the event thaI either party breaches any provision of this
MARITAL SETTLEMENT AGREEMENT, he or she shall be responsible for any and all
costs Incurred to enforce the MARITAL SETTLEMENT AGREEMENT, Including, but not
limited to, court costs and counsel fees of the other party. In the event of breach, the
othsr party shall have the right, at his or her election, to sue for damages for such breach
or to seek such other and additional remedies as may be available 10 him or her.
12. ENFORCEMENT: The parties agree that the terms of Ihls MARITAL
-rI'G.
SETTLEMENT AGREEMENT, Ilsrtlslllsrly IRSltle11l1'l tRe etlstod~reement, may be
entered as separate Orders of Court, and that any part or parto hereof may be enforced
In any court of competent Jurisdiction.
13. APPLICABLE LAW AND EXECUTION:
The parties hereto agree that
his Agreement shall be construed under the laws of the Commonwealth of Pennsylvania,
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and shall bind the parties hereto, and their respective heirs, executors, and assigns. This
document shall be executed as original In triplicate.
14. t:NTIRE AGREEMENT: The parties acknowledge and agree that this
MARITAL SETTLEMENT AGREEMENT contains the entire understanding 01 the parties
and supersedes any prior agreement between them. There are no other representations,
warranties, promises, covenants, or understandings between the parties other than those
expressly set forth herein.
15. INCORPORATION IN JUDGEMENT FOR DIVORCE: In the event that
either Husband or Wile at any time hereafter obtain a divorce In the action for divorce
presently pending between them, or otherwise, this MARITAL SETTLEMENT
AGREEMENT and all 01 Its provisions shall be Incorporated Into any such judgment for
divorce, either directly or by reference. The Court, on entry of judgment for divorce, shall
retain the right to enforce the provisions and the terms of this MARITAL SETTLEMENT
AGREEMENT.
16. LEGAL ADVICE: Each party acknowledges that he and she have received
or have had the opportunity to receive Independent legal advice from counsel of hll or
her selection, and that each have determined to complete this MARITAL SETTLEMENT
AGREEMENT, and that each fully understands the facts, and each has had thl
opportunity to be fully Informed as to his or her legal rights and obligations. Each party
acknowledges and accepts that this MARITAL SETTLEMENT AGREEMENT II In thl
circumstances, fair and equitable, and that It Is being entered Into freely and voluntarllv.
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The execution of the MARITAL SETTLEMENT AGREEMENT Is not a result of any
duress or undue influence, and It Is not the result 01 any collusion or Improper Illegal
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agreement or agreements. The parties acknowledge that each has been fully Informed
with the wealth, property state, and Income of the other, and each party Is hereby
satisfied that such Information Is true and correct.
17. The "WHEREAS" clauses are speclllcally Incorporated Into and made a part
of this Agreement.
IN WITNESS WHEREOF, the parties hereto have hereunto set their hands and
seals the day and year first above written.
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"Theodore P.Gordon, III
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Angela T. Gordon
WITNESS:
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THEODORE P. OORDON,III,
PI.lntl"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND CNlY., PENNSYLVANIA
NO.
VI.
ANGELA T. OORDON,
Defendanl
CIVIL ACTION. LAW
IN DIVORCE
PRAECIPE TO TRANSMIT RECORD
TO THE PROTHONOTARY:
Transmit the record, logether with the lollowlng Inlormalion to the Courllor entry
01 a divorce decree:
1. Ground lor divorce: Irretrievable breakdown under Seclion 3301(c) 01 the
Divorce Code.
2. Date and manner 01 service 01 the Complaint In Divorce: Complaint was
served on Delendant, Angela T. Gordon on .-lJ:1J~Jj~- _ _ ' 1995 by
cerlilled mall, return receipt requested, Arlicle Number dQ.,'~ 'It G II.' 1.')0 .
3. Date of execulion of the Affidavit of Consent required by Seclion 3301 (c)
of the Divorce Code:
By Plalnliff:
By Defendant:
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4. Related claims pending: None.
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Theodore P. Gordon, III. Pro Se,
Plalnliff
West Main Street
P. O. Box 202
Plalnlleld, PA 17081
(717) 249.7569
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THEODORE P. GORDON, III,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND CNTY., PENNSYLVANIA
va.
NO. CiS -iuc; 0 (~;,-,.l!"/ nfll
ANGELA T. GORDON,
Defendant
CIVIL ACTION. LAW
IN DIVORCE
ORDER OF COURT
You, ANGELA T. GORDON, are ORDERED to appear In person In the Conference
Room, Fourth Floor, Cumberland County Courthouse, One Courthouse Square, Carlisle,
PA 17013 on A\..,-~) t"''iL_Lot " , 1995 at _ leI! ?<~' {~/P.m. for a
Custody Conciliation Conference. At such Conference, an effort will be made to resolve
the Issues In dispute; or If this cannot be accomplished, to define and narrow the Issues
to be heard by the Court, and to enter Into a Temporary Order. All children age five or
older may, at the request of either attorney or party, be present at the Conference.
Failure to appear at the Conference may provide grounds for the entry of a temporary or
permanent Order.
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.
Dated:
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Court Administrator's Office
CUMBERLAND COUNTY COURTHOUSE
One Courthouse Square
Carlisle, PA 17013
Telephone (717) 240-6200
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Custody Concll/atof ". I
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VI.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND CNTV., PENNSVLVANIA
NO.
CIVIL ACTION. LAW
IN DIVORCE
THEODORE P. GORDON, III,
Plaintiff
ANGELA T. GORDON,
Defendant
NOTICE TO DEFEND AND CLAIM RIGHTS
You have been sued in Court. If you wish to delend against the claims set lorth
in the loll owing pages, you must take prompt action. You are warned that II you lall to
do so, the case may proceed without you and a decree 01 divorce or annulment may be
entered against you by the Court. A judgment may also be entered against you lor any
other claim or rellel requested in these papers by the Plalntlll. You may lose money or
property or other rights Important to you, Including custody or visitation 01 your children.
When the ground lor the divorce Is indignities or Irretrievable breakdown 01 the
marriage, you may request marriage counseling. A list of marriage counselors is
available in the Olllce 01 the Prothonotary, Cumberland County Courthouse, One
Courthouse Square, Carlisle. PA 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY.
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS
GRANTED. YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTY COURTHOUSE
Court Administrator's Office
One Courthouse Square
Carlisle, PA 17013
(717) 240-6200
THEODORE P. GORDON, III,
Plllnllff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND CNTY., PENNSYLVANIA
VI.
NO. q.j
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ANGELA T. GORDON,
Defendlnt
CIVIL ACTION. LAW
IN DIVORCE
COMPLAINT IN DIVORCE
1. Plaintiff Is Theodore P. Gordon, III, who currently resides at West Main
Street. P. O. Box 202. Plainfield. PA 17081.
2. Defendant is Angela T. Gordon, who currently resides at 20 Stephen Road
7B, Camp Hili. PA 17011.
3. Plaintiff and Defendant have been bona fide residents of the Commonwealth
of Pennsylvania for at least six (6) months immediately previous to the filing of this
Complaint.
4. The Plaintiff and Defendant were married April 30, 1986 In the State of
Oklahoma.
5. There have been no prior actions of divorce or annulment between the
parties.
6. The marriage Is Irretrievably broken.
7. Plaintiff has been advised that counseling Is available and that Plaintiff may
have the right to request that the Court require the parties to participate in counseling.
8. Neither party to this action In divorce Is a member of the armed services 01
the United States 01 America or Its alllos.
WHEREFORE, Plaintiff, Theodore P. Gordon, III, prays your Honorable Court to
enter a Decree of Divorce, divorcing the Plaintiff, Theodore P. Gordon, III from the bonds
of matrimony heretofore existing with the Defendant, Angela T. Gordon, under Section
3301 (c).
COUNT II . EQUITABLE DISTRIBUTION
9. The averments as contained In paragraphs 1 through 8 are Incorporated
herein by reference thereto.
10. The Plaintiff and Defendant have acquired personal property during their
marriage.
11. Plaintiff and Defendant have been unable to agree to an equitable
distribution of said property.
WHEREFORE, the Plslntlff, Theodore P. Gordon, III, respectfully requests your
Honorable Court to enter an order distributing all of the aforementioned property as the
Court may deem equitable and just.
COUNT III . CUSTODY
12. The averments as contained in paragraphs 1 through 11 are Incorporated
herein by reference thereto.
13. Plaintiff seeks partial custody of the following child:
Christopher Michael Gordon, who resides al20 Stephen Road 7B, Camp Hili, PA
17011 and was born on September 11, 1988 and Is currently the age of six (6) years old.
. 2 .
During the past flvo years, tho child has rosidod with tho following persons and at
the following addresses:
From Juno, 1990 through June, 1994, tho minor child resided with both the
Plaintiff, Theodore P. Gordon, III, and the Defendant, Angela T. Gordon at 321 West
Shady Lane, Enola, Pennsylvania.
From June, 1994 to present, the minor child has resided with the Defendant,
Angela T. Gordon at 20 Stephen Road, 78, Camp Hill, Pennsylvania.
The mothor of the child Is Angela T. Gordon residing at 20 Stephen Road 7B,
Camp Hili, PA 17011. She Is currently married.
The father of the child Is Theodore P. Gordon, III, currently residing at West Main
Street, P. O. Box 202, Plainfield, PA 17081. He Is currently married.
14. The relationship of Plalntllfto the child Is that of father. The Plaintiff
currently resides with the following persons:
Deborah L. Craig. Girlfriend
Corynne V. Romberger. Girlfriend's daughter
Scott C. Romberger. Girlfriend's son
15. The relationship of Defendant to the child is that of mother. The Defendant
currently resides with the following persons:
Christopher M. Gordon. Son
16. Plaintiff has not participated as a party or witness, or in another capacity,
in other lIt1gallon concerning tho custody of tho child In this or anothor court.
03.
Plalntlll has no Information of a custody proceeding concerning the child pending
In a court of this Commonwealth.
Plain till does not know of a person not a party to the proceedings who has
physical custody of the child or claims to have custody or visitation rights with respect to
the child.
17. The best Interest and permanent welfare of the child will be served by
granting the relief requested because the child enjoys the love and allectlon of the
Plaintiff.
18. Each parent whose parental rights to the child have not been terminated and
the person who has physical custody of the child have been named as parties to this
action.
WHEREFORE, Plaintiff requests the court to grant partial custody of the child.
I verify that the statements made In the foregoing Complaint In Divorce are true
and correct. I understand that false statements herein are made subject to the penalties
of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
Dated: G ;fu II ~ C( 5'
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Theodore P. Gordon, Pro Se
P. O. Box 202
Plainfield, PA 17081
(717) 249-7569
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THEODORE P. GORDON, III,
Plllntl"
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND CNTY., PENNSYLVANIA
NO. 11) ; (l ft fr, n; (I \ t!.
CIVIL ACTION. LAW
IN DIVORCE
VI.
ANGELA T. GORDON,
Defendlnt
AFFIDAVIT OF SERVICE
1. I am Theodore P. Gordon, III, an adult Individual, and Plaintiff In the above-
captioned action.
2. On June 6, 1995, I sent a true and correct copy of a Complaint In Divorce
by means of certified mall, return receipt requested, with proper postage prepaid to the
Defendant, Angela T. Gordon, at her current address of20 Stephen Road, 7B, Camp Hili,
Pennsylvania 17011.
3. Thereafter, the green return receipt card was returned to me bearing the
signature of Defendant, Angela T. Gordon, and Is attached hereto marked "Exhibit A".
4. I am familiar with the signature of the Defendant, Angela T. Gordon, and I
am of the opinion that said signature Is the signature of my wife and the Defendant
captioned above.
I verily that the statements made In this allldavlt are true and correct. I understand
that false statements herein are made subject to the penalties of18 Pa.C.S. Section 4904
relating to unsworn falsification to authorities.
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heodore P. Gordon,.III, Pro Se
Plaintiff
65 West Main St., P. O. Box 202
Plainfield, PA 17081
(717) 249-7569
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THEODORE P. GORDON, III,
PI.lnUlf
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND CNTV., PENNSVLVANIA
NO. o~. .1)(.'1.(;' (it'{II(?!
r Ii , V It.1t---
CIVIL ACTION. LAW
IN DIVORCE
v..
ANGELA T. GORDON,
Defend.nt
AFFIDAVIT OF CONSENT
1. A Complaint In Divorce under Section 3301 (c) of the Divorce Code was flied
on June 6, 1995.
2. The marriage of plaintiff and defendant is Irretrievably broken and ninety (90)
days have elapsed from the date of the filing of the Complaint.
3. I consent to the entry of a final decree In 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.
I verify that the statements made In this affidavit are true and correct. I understand
that false statement8 herein are made subject to the penalties of 18 Pa. C.S. 4904
relating to unsworn falsification to authorities.
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Theodore P. Gordon, III, Plaintiff
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VI.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND CNTY., PENNSYLVANIA
NO. (/) )(I(t(,' (' 1111' (,'_ )
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THEODORE P. GORDON, III,
Plllntlff
ANGELA T. GORDON,
Defendant
CIVIL ACTION. LAW
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint In Divorce under Section 3301 (c) of the Divorce Code was flied
on June 6. 1995.
2. The marriage of plaintiff and defendant Is Irretrievably broken and ninety (90)
days have elapsed from the date of the filing of the Complaint.
3. I consent to the entry of a final decree In divorce.
4. I understand that If a claim for alimony, alimony pendente lIIe, marital
property or counsel fees or expenses has not been flied with the Court before the entry
of a final decree In divorce, the right to claim any of them will be lost.
I verify that the statements made In this affidavit are true and correct. I understand
that false statements herein are made subjoctto the ponaltles of 18 Pa. C.S. 4904
relating to unsworn falsification to authorities.
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