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HomeMy WebLinkAbout02-4140KELLY R. GRANT, Plaintiff VS. CHRISTOPHER A. GRANT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 2002-4//-i-0 CIVIL TERM · CIVIL ACTION-LAW IN DIVORCE 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 Prothonotary at the Cumberland County Court House, Carlisle, Pennsylvania. 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 ATTORNEY AT ONCE. IF YOU DO NOT HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. Cumberland County Bar Association Two Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 KELLY R. GRANT, Plaintiff VS. CHRISTOPHER A. GRANT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002- CIVIL TERM CIVIL ACTION-LAW IN DIVORCE COMPLAINT UNDER SECTIONS 3301(C) AND 3301(D) OF THE DIVORCE CODF 1. Plaintiff is Kelly R. Grant, an adult individual who currently resides at Three Brian Drive, Carlisle, Cumberland County, Pennsylvania. 2. Defendant is Christopher A. Grant, an adult individual who currently resides at 7950 Hoeffner Lane, Fort Pierce, Florida. 3. Plaintiff has been a bonafide resident 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 July 3, 1997, in Okeechobee, Florida. COUNT I - DIVORCE 5. Plaintiff hereby incorporates by reference paragraphs 1 through 4 above. 6. There have been no prior actions of divorce or for annulment between the parties as to their current marriage. 7. Plaintiff is not in the Armed Forces of the United States. Defendant is in the National Guard, however, he is not on active duty and is domiciled at the residence set forth in paragraph 2 above. broken. Plaintiff avers that the marriage between the parties is irretrievably 9. The Plaintiff has been advised of the availability of counseling and that she may have the right to request that the Court require the parties to participate in counseling. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree in divorce. cOUNT II - EQUITABLE DISTRIBUTION 10. Plaintiff hereby incorporates by reference paragraphs 1 through 9 above. 11. The parties have acquired both real and personal property, including automobiles, bank accounts and other items of miscellaneous property during the course of their marriage, some of which is marital property. WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter a decree which effects an equitable distribution of marital property. COUNTIII-CUSTODY 12. 13. the Plaintiff: Plaintiff hereby incorporates by reference paragraphs 1 through 11 above. The parties are the natural parents of the folliwng child who resides with Name Hanna G. Grant A.qe Sex D.O.B. 3 Female June 9, 1999 14. The child was not born out of wedlock. 15. The child is presently in the custody of Plaintiff at Three Brian Drive, Carlisle, Cumberland County, Pennsylvania. 16. During her lifetime, the child has resided with the parties at the following locations: From July 7, 2002 February, 2001 September, 2000 January, 2000 July, 1999 Birth T_~o Present July 7, 2002 February, 2001 September, 2000 December, 1999 July 1999 With whom Mother Mother & Father Mother, Father & Maternal Grandparents Mother & Father Mother & Maternal Grandparents Mother & Father Address Three Brian Drive Carlisle, PA 17013 Three Brian Drive Carlisle, PA 17013 11 Garden Drive Carlisle, PA 17013 Schweinfurt, Germany 11 Garden Drive Carlisle, PA 17013 Schweinfurt, Germany 17. The natural mother of the child is Plaintiff, Kelly R. Grant. 18. She is married to the Defendant. 19. The natural father of the child is Christopher A. Grant. 20. Plaintiff has not participated as a party or witness, or in any other capacity in other litigation, concerning the custody of the child in this or in any other Court. 21. Plaintiff has no information of a custody proceeding concerning the child pending in a Court of this Commonwealth. 22. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claim to have custody or visitation rights with respect to the child. 23. 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 your Honorable Court to grant her primary physical custody of the child and grant the Defendant partial custody of the child Respectfully submitted, O'BRIEN, BARIC & SCHERER DATE: M ch ae~A.' S/4/ch~/'el er,~E~ quire I.D. # 69174 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 mas~domestic/grant/com plaint, div VERIFICATION I verify that the statements made in the foregoing Complaint are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities, ~' Kelly R. G~ant DATED: ~)- ~-(0' 0 Z-' KELLY R. GRANT, Plaintiff VS. CHRISTOPHER A. GRANT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002-4140 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE ACCEPTANCE OF SERVICE AND NOW, this ~ ~-- day of ~,,_~[~_~r ,200 /-, I Christopher A. grant, Defendant above, hereby accept service of the Complaint filed in the above case pursuant to Pa. R.C.P. 4(e) and acknowledge receipt of a true and attested copy of said Complaint. Christopher A. Grant maslDomesticlgrantJaccept.ser KELLY R. GRANT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2002- 4140 CIVIL TERM CHRISTOPHER A. GRANT, Defendant CIVIL ACTION-LAW IN DIVORCE PLAINTIFF'S AFFIDAVIT OF CONSENT AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301(C) of the Divorce Code was filed on August 29, 2002. 2. The marriage of the Plaintiffand Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 3. I consent to the entry of a final decree in divorce without notice. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 6. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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. mas~Domestic\Grant\grant.aff KELLY R. GRANT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 2002- 4140 CIVIL TERM CHRISTOPHER A. GRANT, Defendant CIVIL ACTION-LAW IN DIVORCE DEFENDANT'S AFFIDAVIT OF CONSENT, ACCEPTANCE OF SERVICE AND WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF DIVORCE DECREE UNDER SECTION 3301(C) OF THE DIVORCE CODE 1. A complaint in divorce under Section 3301 (C) of the Divorce Code was filed on August 29, 2002. 2. Defendant acknowledges receipt and accepts service of the Complaint on September 3, 2002. 3. The marriage of the Plaintiffand Defendant is irretrievably broken and ninety days have elapsed from the date of the filing of the Complaint. 4. I consent to the entry of a final decree in divorce without notice. 5. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 6. I understand that I will not be divorced until a Divorce Decree is entered by the Court and that a copy of the Decree will be sent to me immediately after it is filed with the Prothonotary. 7. I have been advised of the availability of marriage counseling and understand that I may request that the court require counseling. I do not request that the court require counseling. 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. Christopher A Grant KELLY R. GRANT, Plaintiff VS. CHRISTOPHER A. GRANT, Defendant TO THE PROTHONOTARY: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002- 4140 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE PRAECIPE TO TRANSMIT RECORD 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 3301(c) of the Divorce Code. 2. Date and manner of service of the Complaint: The defendant signed an Acceptance of Service form on September 3, 2002. 3. (complete either paragraph (a) or (b).) A. Date of execution of the affidavit of consent required by Section 3301 (c) of the Divorce Code: by Plaintiff on December 13, 2002; and Defendant on December 17, 2002. B. (1) date of execution of the Plaintiff's Affidavit required by Section 3301 (d) of the Divorce Code: N/A. (2) date of service of the Plaintiff's Affidavit upon the Defendant: N/A. 4. Related claims pending: None. 5. Indicate date and manner of service of the notice of intention to file praecipe to transmit record, and attach a copy of said notice under section 3301 (d)(1)(i) of the Divorce Code: None. Respectfully submitted, Michael A~ Scherer, ~squire KELLY R. GRANT, Plaintiff VS. CHRISTOPHER A. GRANT, Defendant AND NOW, this~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002- 4140 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE ORDER OF COURT ~day of ?.?...~ t~7 ,200:i' , the Court adopts the following Stipulation and Agreement as an Order of Court, with respect to the following child: Hannah G. Grant, born June 9, 1999 (hereinafter referred to as "child"). 1. The parties shall have shared legal custody of the child. 2. Mother shall have primary physical custody of the child. 3. Father shall have periods of temporary physical custody at such times as the parties from time to time agree. 4. Each parent shall have two uninterrupted weeks of vacation time with the child during each summer. 5. The parties will keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to insure that the health and well being of the child is protected. Neither party may travel outside the continental United States without the written consent of the other parent.. 6. Neither parent shall do anything which may estrange the child from the other party, or injury the opinion of the child as to the other party or which may hamper the free and natural development of the child's love or affection for the other party. 7. The parties are encouraged to deviate from this schedule when the best interests of the child requires them to do so, however, in the absence of an agreement, the terms of this agreement shall be controlling. 8. The parties desire that this Stipulation and Agreement be made an Order of Court to the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody and the parties's minor child and shall retain jurisdiction should circumstances change and either party desire or require modification of said Order. 9. The parties acknowledge that they have read and understand the provisions of this Agreement. BY THE COURT, KELLY R. GRANT, Plaintiff VS. CHRISTOPHER A. GRANT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2002- 4140 CIVIL TERM CIVIL ACTION-LAW IN DIVORCE CUSTODY STIPULATION AND AGREEMENT THIS AGREEMENT AND STIPULATION entered into the day and year hereinafter set forth, by and between Kelly R. Grant (hereinafter referred to as "Mother") and Christopher A. Grant (hereinafter referred to as "Father"). WHEREAS, the parties are the natural parents of Hannah G. Grant, born June 9, 1999 (hereinafter referred to as "child"); and, WHEREAS, the parties are presently separated and living in separate residences; and, WHEREAS, the parties wish to enter into an agreement relative to the custody and partial custody of the child. NOW, THEREFORE, in consideration of the mutual covenants, promises and agreements as hereinafter set forth, the parties agree as follows: 1. The parties shall have shared legal custody of the child. 2. Mother shall have primary physical custody of the child. 3. Father shall have periods of temporary physical custody at such times as the parties from time to time agree. 4. Each parent shall have two uninterrupted weeks of vacation time with the child during each summer. 5. The parties will keep each other advised immediately relative to any emergencies concerning the child and shall further take any necessary steps to insure that the health and well being of the child is protected. Neither party may travel outside the continental United States without the written consent of the other parent. 6. Neither parent shall do anything which may estrange the child from the other party, or injury the opinion of the child as to the other party or which may hamper the free and natural development of the child's love or affection for the other party. 7. The parties are encouraged to deviate from this schedule when the best interests of the child requires them to do so, however, in the absence of an agreement, the terms of this agreement shall be controlling. 8. The parties desire that this Stipulation and Agreement be made an Order of Court to the Court of Common Pleas of Cumberland County, and further acknowledge that the Court of Common Pleas of Cumberland County does, in fact, have jurisdiction over the issue of custody and the parties's minor child and shall retain jurisdiction should circumstances change and either party desire or require modification of said Order. 9. The parties acknowledge that they have read and understand the provisions of this Agreement. IN WITNESS WHEREOF, the parties hereto intending to be legally bound by the terms hereof set their hands and seal the day and year written below. WITNESS: DATE: Christopher A. Grant DATE: ."~, f~ ~o~ masldomesticlgrantlgrant.stp KELLY R. GRANT, Plaintiff VS. CHRISTOPHER A. GRANT, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 02-4140 CIVIL TERM CIVIL ACTION - LAW IN DIVORCE MARITAL SETTLEMENT AGREEMENT THIS AGREEMENT, made this ) ?¢~ day of December, 2002, by and between Kelly R. Grant, hereinafter referred to as "Wife", and Christopher A. Grant, hereinafter referred to as "Husband." WITNESSETH: WHEREAS, the parties are Husband and Wife who were married on July 3, 1997, and have been separated since July 7, 2002; and, WHEREAS, Wife has instituted divorce proceedings in the Court of Common Pleas of Cumberland County to No. 02-4140 Civil Term by complaint filed on August 29, 2002; and, WHEREAS, the parties are the parents of Hannah G. Grant, born June 9, 1999; and, WHEREAS, diverse, unhappy differences, disputes and difficulties have arisen between the parties and the parties have decided that their marriage is irretrievably broken, and it is the intention of the parties to live separate and apart for the rest of their natural lives. The parties are therefore desirous of settling fully and finally their respective financial and property rights and obligations as between each other, including without limitation: the ownership and equitable distribution of all property owned by the parties; and the settling of all related economic claims including but not limited to spousal support, alimony and alimony pendente lite; and in general the settling of any and all claims or possible claims of one against the other or against their respective estates; and, WHEREAS, each party is fully familiar with the all of the property owned by the parties and each party acknowledges having sufficient opportunity to investigate and evaluate the property owned by the parties, and both parties now desire to settle and determine his and her property rights and claims under the Divorce Code. NOW, THEREFORE, in consideration of the mutual promises hereinafter set forth and for other good and valuable consideration, receipt of which is hereby acknowledged by each of the parties hereto, the parties, intending to be legally bound hereby, do covenant and agree as follows: 1. DIVORCE The parties agree to the entry of a Decree in Divorce pursuant to Section 3301© of the Divorce Code. Both parties shall execute and file the requisite Consents and Waivers with the Court contemporaneously with the execution of this Agreement. Wife's counsel shall withdraw Wife's claim for economic relief. Wife's attorney shall file the Praecipe to Transmit the record and obtain a Decree in Divorce without delay. Should either party do anything to delay or deny the entry of such a Decree, or fail to do anything required to obtain the Divorce Decree in breach of this Agreement, the other party may, at his or her option, declare this Agreement null and void. 2. INCORPORATION BUT NOT MERGER INTO DIVORCE DECREE This Agreement and all warranties and representations contained herein shall survive the Divorce Decree and shall continue to be enforceable in accordance with its terms. An action may be brought at law, in equity or pursuant to the provisions of the Divorce Code to enforce this Agreement by either Husband or Wife. 3. ADVICE OF COUNSEL Wife is represented by Michael A. Scherer, Esquire, who is her separate legal counsel and she has' been advised of her respective rights, privileges, duties and obligations relative to the parties' property rights and interests under the Divorce Code and regarding alimony and spousal support. Husband has voluntarily chosen to be unrepresented in this matter, however, husband understands he has the right to retain separate counsel of his choosing. 4. TANGIBLE PERSONAL PROPERTY Wife shall become the sole owner of the 2000 Honda Accord and Husband shall become the sole owner of the 1994 Honda Accord. Aside from the foregoing, the parties have divided between them to their mutual satisfaction all items of tangible personal property which had heretofore been used by them in common and neither party shall make any claim to such property in the possession of the other. Each party will execute any and all documents necessary to effectuate the transfer of ownership of any items of personal property titled in both names as set forth above. 5. OTHER PROPERTY DISTRIBUTION PROVISIONS A. REAL ESTATE: The marital residence is located at 3 Brian Drive, Carlisle, Pennsylvania. The parties purchased the marital residence in February, 2001 and believe there to be very little equity in the home, especially if the home were to be listed with a real estate broker and sold on the open market. Wife shall become the sole owner of the marital residence and Husband shall, concurrent with the execution of this agreement, sign a Quitclaim Deed transferring all his right, title and interest to the marital' residence, to Wife. B. INTANGIBLE PERSONAL PROPERTY The parties have divided between them to their mutual satisfaction all intangible personal property consisting of cash, bank accounts, annuities, securities, insurance policies, pension and retirement rights, whether vested or contingent, and all other such types of property. The parties hereby agree that all such intangible property presently in the possession of or titled in the name of Husband shall be his sole and separate property, and that in the possession or titled in the name of the Wife shall be her sole and separate property. Each party hereby expressly waives any right to claim any pension/profit sharing/retirement rights of the other, vested or contingent, each party to retain full ownership of such rights as his or her sole and separate property. 6. DEBTS AND OBLIGATIONS Husband shall continue to.pay the monthly obligation to Andrews Federal Credit Union in the amount of $414.63 per month, until such time as husband refinances the debt on the 1994 Honda Accord into his name alone. At such time as husband refinances the debt on the 1994 Honda Accord, he shall pay wife the sum of $5,000.00 to repay credit card debt incurred during the marriage which is in wife's name alone. Thereafter, wife shall be solely responsible for the debt to Andrews Federal Credit Union. 7. INDEMNIFICATION Both parties covenant, warrant, represent and agree that each will now and at all times hereafter save and keep each other indemnified against all debts, charges, or liabilities incurred by the other after the execution of this Agreement, except as may be otherwise specifically provided for by the terms of this Agreement and neither of them shall hereafter incur any liability whatsoever for which the Estate of the other may be liable. 8. EQUITABLE AGREEMENT Both parties agree that the hereinabove set forth Agreement constitutes an equitable distribution of their marital property and equitable resolution of all other economic claims pursuant to the provisions of the Divorce Code and each party irrevocably waives, releases, and remises any claim to ownership of or interest in any property designated as the property of the other by virtue of the provisions of this Agreement except as otherwise may be provided pursuant to the provisions of this Agreement. 9. MUTUAL RELEASES Husband and Wife do hereby mutually release, remise, quitclaim and forever discharge the other and the estate of the other from any and all claims either party has 5 now, ever may have or can at any time have against the other or the other party's estate or any part thereof, whether arising out of formal contracts, engagements or liabilities of the other party, arising by way of widower's right or under the Intestate Law, arising by any right to take against the Will of the other party, arising out of the Divorce Code, Act No. 26 of 1980, as amended, including, alimony, alimony pendente lite, counsel fees and expenses, arising as a right to spousal support or arising from anything of any nature whatsoever, excepting only those rights accorded to the parties under this Agreement. 10. BREACH If either party to this Agreement resorts to a lawsuit or other legal action pursuant to the provisions of the Divorce Code or otherwise to enforce the provisions of this Agreement, the successful party shall be entitled to recover his or her reasonable attorney fees, actually incurred, from the other as part of the judgment entered in such legal action, whether in law, in equity, pursuant to the provisions of the Divorce Code or otherwise as the same shall be determined by the Court. 11. ENTIRE AGREEMENT This Agreement constitutes the entire understanding of the parties. There are no covenants, conditions, representations or agreements, written or oral, of any nature whatsoever, other than those herein contained. 12. MODIFICATION This Agreement is subject to modification only by a subsequent legal writing signed by both parties. It shall be construed according to Commonwealth of Pennsylvania laws. 13. AGREEMENT BINDING ON HEIRS This Agreement shall bind and inure to the benefit of the parties hereto and their respective heirs, executors, administrators, successors and assigns. 14. COSTS AND ATTORNEYS' FEES Neither party shall reimburse the other for any court costs or filing fees associated with this case, and each party shall be responsible to pay his or her own attorneys' fees. 15. WAIVER OF ALIMONY Husband and Wife do hereby waive, release and give up any rights which either of them may have against the other to receive alimony or other post-divorce spousal maintenance or support. ,....N ESS: Kelly R( Grant Christopher A. Grant mas~Domestic~Grant\grant.agr ) {/I -< IN THE COURT OF COMMON I4'~.LY R. GRANT OF CUMBERLAND COUNTY STATE OF p~,~ PENNA. Plaintiff VERSUS CHRISTOPHER A. GRANT Defendant N o. 2002 - 4140 PLEAS Ci-v-ZL DECREE IN DIVORCE AND NOW, D]A2E~I~R , 2002 , it iS ORDERED AND DECREED THAT , PLAINTIFF, AND CHRISTOPHER A. GRANT , 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 f'OR WHICH A FINAL ORDER HAS NOT YEt BEEN ENTERED; THE PARTIES' MARITAL SETI~,~ AGRk~ENT DATED, DECEMRK~R 17r 2002r IS INCORPORATED HEREIN AS A FINAL ORDER OF COURT. BY THE COURT/~2 / ' ~PROTHONOTARY KELLY R. GRANT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 2002-4140 CIVIL TERM CHRISTOPHER A. GRANT, Defendant CIVIL ACTION-LAW IN DIVORCE NOTICE OF ELECTION TO RETAKE MAIDEN NAME Notice is hereby given that the Plaintiff in the above matter, having been granted a Final Decree in Divorce from the Bonds of Matrimony on the 31st day of December, 2002 hereby elects to retake and hereafter use her prior name of Kelly R. Jones, and gives this written notice avowing her intention in accordance with the provisions of the act of May 25, 1939, P.L. 192 (23 P.S. 98), as amended. Dated: . - K~lly R. Grant TO BE KNOWN AS Kelly R. Jd,~s - COMMONWEALTH OF PENNSYLVANIA COUNTY Of CUMBERLAND SS. On the J,/-/'/'/~day of January, 2003, before me, a notary public, personally appeared Kelly R. Grant to be known as Kelly R. Jones, known to me to be the person whose name is subscribed to the within document, and acknowledged that she executed the foregoing for the purpose therein contained. IN WITNESS WHEREOF, I have hereunto set my hand and official seal. NOTARIAL SEAL Susan J. Lamma, Notary Public Borough of Carlisle, Cumberland County My Commission Expires May 2, 2005