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IMROLD S. IRWIN. 111
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.. /lUG 1 t) _1Je.
HAROLD S. IRWIN, III. ESQl1IRE
ATTORNEY ID NO. 199111
36 SOI'TH PITT STREET
CARLISLE PA 171113
(7171143-611911
ATTORNEY FOR PETITIONER
v.
: IN TilE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION. LAW
: NO. 9S -1J&1 CIVIL TERM
GRACE V. WOGAN,
Petitioner
FRED L. WOGAN, JR. and
JENNIFER L. WOGAi<l,
Respondent
: CUSTODY
NOW, this LZI.2t. day of August, 1995. on consideration of the attached petition, it is
hereby directed Ihat the parties and their respective counsel appear before Hubert X, Gilroy,
Esq~e. ~~bconciliator. on the 4th Floor. Cumberland County Courthouse. on the ~ day of
c. ,r, 1995. at ~".M, for a Pre-Hearing Custody Conference, At such
conference. an etlbrt 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, Failure to appear at this conference may provide grounds for entry of a
temporary or permanent order,
By the Court,
By:
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
DO NOT HA VI: A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL
HELP.
Court Administrator
Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
4ua ~3 12 41, PH '55
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GRACE V. WOGAN,
Petitioner
: IN THE COURT OF.COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION. LAW
: NO. 9S-
CIVil. TERM
FRED L. WOGAN, JR. and
JENNIFER L. WOGAN,
Respondent
: CUSTODY
NOW comes the petitioner, Grace V, Wogan. by her attorney. Harold S. Irwin, III, IUId
presents the following petition for custody, representing as follows:
1. The petitioner is Grace V, Wogan, an adult individual residing at 6S North
Bedford Street. Carlisle, Cumberland County, Pennsylvania 17013.
2, The respondent. Fred L, Wogan, Jr" is an adult individual presently incarcerated in
a federal correctional facility and is undergoing medical care for II serious heart ailment,
,
..
3, The respondent. Jennifer L. Wogan. is an adult individual residing at Cumberland
County Prison, 1101 Claremont Road. Carlisle, Cumberland County, PeMsylvania 17013.
9, Pelitioner believes and therefor avers that respondent Jennifer L. WOllan is unable
and unwillinllto provide adequate care lor and allention to the needs and welfare of the child as
demonstrated by the lallowing:
A, Respondent Jennifer L. Wogan has abandoned the child on at least three
occasions, Ihe last one of which begsn on February 17. 1995, three daysatler the child's
first birthday, and made no e!lort whatever to contact the child or petitioner until her mid.
April, 1995 arrest on the charges lor which she is now incarcerated;
B, Following her release from Cumberland County Prison, il is believed Ihat
respondent will be remanded to Dauphin County Prison on a detainer lor probation
violations in thaI County;
C. It is believed Ihat respondent has a drug abuse problem for which she may
intend to seek drug rehabilitation treatment in order to avoid incarceration in D8uphin
County on the probation detainer, during which it is believed that she intends to take the
child with her;
D, Respondent has, through her lifestyle and abandonment ofthe child,
demonstrated an uller lack of concern for the health. welfare and best interestl of the
child;
10, Petitioner believes and therefor avers that she is more ready. wlllinll and able to
provide the care, love, and support for the child and that in doinll so has the support and
cooperation of not only the father of the child, bUI also the both sets ofllrlndparents of the child,
GRACE V. WOGAN,
Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION. LAW
: NO. 95 .
CIVIL TERM
FRED L. WOGAN, JR. and
JENNIFER L. WOGAN.
Respondent
: CUSTODY
I, Fred L. Wogan, Jr" one of the respondents in the above matter, certitY that I am the
natural father of Briuany Leigh Wogan, born February 14, 1994, the child who is the subject of
this petition to which this consent is attached, I hereby knowingly and in full understanding of the
meaning of this consent, do consent to the entry of an order granting legal and physical custody of
Brittany Leigh Wogan to petitioner. Grace V. Wogan, subject to my right to have supervised
visitation of the child at the residence of the petitioner, I understand that I am retaining all my
rights as the natural father, subject to the terms of this proposed order, Due to my incarceration
in a state correctional facility, and because I am in full and voluntary agreement with the requests
made by the petitioner, I hereby waive my right to appear in person at any conciliation conference
or custody hearing, or to be notified of the date thereof
AUllust_, 1995
"'RED L. WOGAN, .fR.
Sworn to and subscribed before me
this _ day of August, 1995,
Notary Public
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HAROLD S, IRWIN. III
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II.\IUII.O S. IItWIN. III. ISI)III1U:
,\'!'HIRNi:V III NO, 2')'1211
Jr, SOUTIII'ITI' STltHT
c,\Itl.lSU: 1''\ 171113
(71 7) 24J.(,II.Jtl
ATTORNt;V Hilt I'KITI'ION~:lt
GI{ACE V. \VOGAN.
I'l'lilillllca'
: IN TilE {'I Hllrr OF COMMO:'<lI'UAS 01'
: ('IIMIU:UI..\NIl ('0111"'1'''. I.I':NNS....I.VANIA
v.
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,'L~NIFEI{ I.. WO(;,\,'\,
1(I','Plllllh'1I1
: IIlSTOIl\
ORDER OF COllRT
NOW, this'11~ dilY of .~,^,-Lr.,_, 1995, lIJlon prcscntalion and consideration of
thc attached stipulalion :lnd agrccmcnt and Up"" agrccmcnt "fthc panics, it is hcrcby ordered and
dccreed lhatthe attached agrecmcnl is made all ()rder of (', 'lIrt
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GRACE V. WOGAN.
Petitioner
: IN THE COURT Of' COMMON PLEAS OF
: CUMBERl.AND COUNTY,I'ENNSYLVANIA
v.
: CIVIL ACTION. LAW
FRED L. WOGAN. JR. IlIId
JENNIFER L. WOGAN,
Respondent
: NO. 95.4367 CIVIL TEI~M
: CUSTODY
~7'"
THIS STII'ULATION' AND AGREEMENT entered into this ..!....- day of
<;CPI(MtJ< .,~ . 1995, by and between GRACE V. WOGAN (hereinafter referred to as
"Petitioner) lind FRED L. WOGAN, JR. (hereinafter re/erred to as "Father") and JENNIFER
L. WOGAN (hereinaller referred to as "Mother"),
NOW THIS AGREEMENT WITNESSETH THAT:
WHEREAS, the Father and Mother are the natural parents of a minor child, namely,
Brittany Leigh Wogan (born February 14, 1994); and
WHEREAS. the Petitioner is the paternal great-grandmother of the child; and
WHEREAS. the child has resided with Petitioner since its birth and Petitioner has been
responsible for the care and welfare of the child since thattimc; and
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v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION . LAW
HAROLD So "WIN, W,ISQUUU:
ATrORNIY ID NO. 29910
36 SOUTH PITf STOlT
CARLISLE PA 170&3
(717) U3-609O
ATrORNIY 'OR PlmlONIR
GRACE V. WOGAN,
Petitioner
: NO. 9S - 4367 CIVIL TERM
FRED L WOGAN, JR. and
JENNIFER L WOGAN,
Relpondent
: CUSTODY
9RDER OF COURT
AND NOW,this \ ,,'<':ray of September. 1996 upon presentation and conaideration of
the attached stipulation and agreement and upon asreement of the parties, it is hereby ordered and
de<:reed that the attached agreement is made an Order of Court,
BY THE COURT,
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I. The Parents shall have joint legal custody of the child.
2, The Parents also shall have primary physical custody of the child,
3, The parties shall permit reasonable telephone contact with the child from each
other while the child is in their custody,
4, The parties will keep each other advised immediately relative to any emergencies
concerning the child while she is in their custody and shall take any necessary steps to ensure that
the health, welfare and well being of the child is protected,
5. The parties shall do nothing that may estrange the child from each other or hinder
the natural development of the child's love or affection for the other party,
6. Any modification or waiver of any of the provisions of this agreement shall be
effective only if made in writing and only ifexccuted with the same formality of this agreement.
7, The parties agree that in making this agreement there has been no fraud,
concealment, overreachin(l. coercion or other unfair dealing on the part of the other,
8, The parties desire that this agreement be made an order of Court through the
Court of Common Pleas of Cumberland County. and further acknowledge dill the Court of
Common Pleas of Cumberland County has jurisdiction over these issues and IbIII retain such
jurisdiction should circumstances change and either party desire further or require l\uther
modification of said Order,
*
(~~"\' I' V, '!.v..Plaintiff
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, IN THB COURT OF COMMON PLEAS OF
'CUMBERLAND COUNTY, PENNSYLVANIA
f,<,\ l W",.)..',d~?endant
.
.
'CIVIL ACTION - LAW
:NO.'l"'/1(,/ CIVIL
: CUSTODY /VISITATION
19
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ORDER OF COURT
dr,,,, tv fil'))
AND NOW, this )" (dace) , upon consideration of the
attached complaint, it is hereby directed that the parties and .
their respective counsel app.ear befo.re -1J L' b ( r I } ~ I ,( ')\/ t:.::c;
the conciliator, at l 1,\ <>,0/ (" "~ ".A(tl,o'I~1
on the _frl5 :M day of ~ Il , 19 1 , at 10 'J()
M., for a Prehearing Custo 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~y the court, and to enter into a temporary order. Either
party may bring the child who is the subject of this custody
action to the conference, but the child/children's attendance is
not mandatory. Failure to appear at the conference may provide
grounds for entry of a temporary or permanent order.
FOR THE COURT,
By' ---;1 ~t!,t';/ V:~~ll~(-d F~
c.r:tIay concn1at~~r C/ 1-~~
fOU SHOULD TAKE THIS PAPER 2'0 fOUR LAfI71'ER AT ONCB. IF YOU DO NOT
HAVE A LAffYER OR CANNOT AFFORD ONE, GO TO OR TBLEPHONE THE OFFICE
SET FORTH BELOW 2'0 FIND OUT WHERE YOU CAN GET LEGAL HELP.
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, FOURTH FLOOR
CARLISLE PA 17013
(717)240-6200
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IN THE COURT OF COMMON PLEAS OF CUMBEIUAND COUNTY,
PENNSYLVANIA
GRACE V. WOGAN.
Plalntllf
: CIVIL ACTION. LAW
v.
: NO. 954367
: CUSTODY
FRED L. WOGAN, JR. and
JENNIFER L. WOGAN,
Derendants
AND NOW, TO WIT, this
Ordered and Directed:
ORDER
day of
, 199 ,it Is hereby
1.
conduct a Conciliation Conference,
. esquire, is hereby assigned to
2. A Conciliation Conference will be held before the assigned Conciliator on
the day of , 1997, at o'c1ock, _M. at
3. The parties shall appear in person at the Conciliation Conference,
If you fail to appear as provided by this Order. an Order for Custody, Partial
Custody or Visitation may be entered against you or the Court may issue a warrant for
your arrest.
YOUSHOULD 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 COURT ADMINISTRATOR
CUMBERLAND COUNTY COURTHOUSE
4TH FLOOR
CARLISLE, PA 17013
TELPHONE (717) 140-6100
BY THE COURT:
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A VISO
USTED HA SIOO DEMANDADO EN LA CORTE, Si usted des<!1I defenderse de Ills
quejas expues1as en las paginas slguienles, debe loma uccion denIm de veillle (20) dills a
partir de la fecha en que recibio III demanda y elllviso. Usled debe presentur comparecencia
escrila en personu 0 par abogado y presenlar en lul Corte par escrilo sus <lefensas 0 SllS
objeciones alas demandas en su conlm.
Se Ie avisa que si no se defiendu, el caso puede proceder sin usled y la Corte puede
decidir en su contm sin mas aviso 0 nollflcacion per cualquier olm quejll <) compensacion
reclamados par el Demandanle, USTED PUEDE PERDER D1NERO, 0 PROPIEDADES
U OTROS DERECHOS IMPORTANTES PARA USTED.
LLEVE ESTA DEMAND A A UN ABOGADO INMEDlATAMENTE. SI USTEO
NO TIENE 0 NO CONOCES UN ABOGADO, V A Y A 0 LLAME A I,A OFICINA EN
LA DIRECCION ESCRITA ABAJO PARA AVERIGUAR DONDE PUEDE OBTENER
ASISTENCIA LEGAL.
Court Administrator
Cumberland County Courthouse
4th Floor
CarUsle, Pennsylvania 17013
TeleCono No. (717) 240-6200
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN1Y,
PENNSYLVANIA
GRACE V. WOGAN,
PlalnUrr
: CIVIL ACTION. LAW
v.
: NO. 95.4367
FRED L. WOGAN, JR. and
JENNIFER L. WOGAN,
Derendants
: CUSTODY
COMPLAINT FOR PARTIAL CUSTODY
AND NOW, TO WIT, this 31st day of DECEMBER, 1996, comes the
Complainanl/Second Defendanl/Mother, by and through her atlorneys, MENGES &
SNYDER, and files this complaint whereof the following is a statement:
1. The Complainanl/Second Defendant/Mother is Jennifer L. Wogan, residing at
65 North Bedford Street, Carlisle, PA 17013, Cumberland County,
2. The Plaintiff, Grae.: V. Wogan, resides at 29 North East Street, Carlisle, PA
17013, Cumberland County,
3, The First Defendant, Fred L. Wogan. resides at 29 North East Street, Carlisle,
PA 17013, Cumberland County, Pennsylvania.
4. Complainant/Second Defendanl/Mother seeks majority physical and legal
custody of Brittany Leigh Wogan, age 3, and residing at 65 North Bedford Street,
Carlisle, PA 17013.
The child was not born out of wedlock.
The child is presently in the custody of Complainanl/Second Defendant/Mother,
Jennifer L. Wogan, who resides at 65 North Bedford Street, Carllsle, PA.
During the past five years, Brillany has resided with the following persons and at
the following addresses:
I'List of pel'5ons)
(List All Addresses)
(Dates)
2-14-94 to
2-17-95
Jennifer Wogan
830 Ash Ave. St.
Carlisle, PA
Grace Wogan
Same
2-14-95 to
The mother of the child is Jennifer L. Wogan, currently residing at 65 North
Bedford Street, Carlisle, PA 17013, Cumberland County,
She is married.
The father of the child is Fred L. Wogan, Jr. currently residing at 19 North Eat
Street" Carllse, PA 17013.
He is married,
5, The relationship of Complainant/Second Defendant/Mother to Brittany is
mother, The mother currently resides with the following person(s):
(Name)
(Relationship)
Daughter
Brillany Leigh Wogan
:2
6, The relationship of First Defendant, Fred L. Wogan, Jr" to .he child is that of
father. The First Defendant, Fred L. Wogan Jr,. currently resides at 29 North Enst
Street, Carlisle, PA 17013, The First Defendant, Fred L. Wgoan, Jr.. currently resides
with the following person(s):
(Name) (Relationship)
Grace V. Wogan Grandmother
7, The relationship of Plaintiff, Grace V, Wogan, to the child is that of paternal
great-grandmother. The Plaintiff, Grace V. Wogan, currently resides with tbe following
person(s):
(Name) (Relationship)
Fred L. Wogan, Jr, Grandson
8, Complainant/Second Defendant/Mother bas participated as a party in other
litigation concerning the custody of Brittany in this court, The court term and number,
and its relationship to this action is Plaintiff, Grace V. Wogan, brought a prior custody
action which resulted in a Stipulation and Agreement being adopted by this Court as an
Order Of Court on December 7, 1995 to the number above-given. A subsequent order
was entered upon the parties agreement on September 18, 1996.
Complainant/Second Defendant/Mother has no information of a custody
proceeding concerning Brittany pending in a court of this Commonwealth,
3
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IN TilE COURT OF COMMON PLEAS 01' CUMBERLAND COUNTY,
PENNSYLVANIA
GRACE V. Woe.AN,
Plaintiff
NO. 9!l-4367 CIVIL TERM
\'.
CIVIL ACTION. LAW
FRED L. WOGAN JR.. and
JENNIFER L. WOGAN,
Defendants
CUSTODY
ORDER
AND NOW. TO WIT, this .~day of .3IllJuIi't' 1997, upon consideration of the
Stipulation and Agreemell! for Custody a\lached hereto, it is hereby
ORDERED that said Stipulation and Agreement for Custody dated the 8th day of
January, 1997 is hereby adopted as the Order of this Coun,
BY THE COURT:
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IN TIlE COURT OF COMMON P1.EAS OF CUMBER1.AND COUNTY, PENNSYLVANIA
GRACE V WOGAN,
"Iaimitl'
NO, 95-4367 CIVIL TERM
v
CIVIL ACTION - LAW
FRED 1. WOGAN JR, and
JENNIFER L WOGAN,
Defendants
CUSTODY
Sl'll'.U1.!\ nON_AND AGREEMf;NT FOR CUSTO...QY
AND NOW, TO WIT, lhis Agreement made this8. day ot~-.i:Jrl. {~?it?:nd
between Grace V Wogan, (h,:reinaner referred to as "Paternal Great-Grandmother"), Fred L.
Wogan, Jr, (hercinaller referred to as "Father"), and Jennifer L. Wogan (hereinaner reterred to as
"Mother"), and in consideration of the mutual covenants contained herein. and intending to be
legally bound hereby, the parties stipulate and agree as follows
WHEREAS, Father and Mother are the natural parents of the minor child, Brittany Leigh
Wogan, (reterred to hereinaner as "child" or "minor child") born February 14, 1994. and
WHEREAS, the parties were the subject of a Custody Order by this Court dated
September 18, 1996 pursuant to a Stipulation And Agreement for custody dated September 12,
1996; and
WHEREAS. the parties intend to set forth an Agreement to be made an Order of Court.
specirying the issues of majority and minority custody between themselves and the minor child.
with the best interests of the child in mind; and
(Agreement continued on nexl palle)
Custody Stipulation and Agreement
Page -2-
WHEREAS, the panies recognize and intend this Slipulation and Agreement For Custody
to entirely replace all existing Custody Orders including the most recent Order dated September
18, 1l)lJ6 and the related Stipulation And Agreement as tiled in the Coun of Common Pleas of
Cumberland Cuunty, Pennsylvania and numbered as above-captioned
NOW. THEREFORE, the panies agree as follows. to wit:
I, Mother and Father shall share legal custody of the minor child as above described,
2, Mother shall have majority, physical custody of the child,
l Falher shall have and exercise minority, physical custody of the child as Father and
Mother shall agree trom time to time, In addition. Father shall exercise minorily cuslody rights.
provided he is neither in jail nor in a halfway house or in a drug or alcohol rehabilitative program,
as follows:
A Every other weekend from 7:30 p,m, Friday until 5:00 p,m, Sunday;
8, The child shall spend Father's Day with Father from 8:30 a,m, until 7:00 p.m,
C. Alternating legal holidays including New Year's Day, Memorial Day. 4th of
July. Labor Day and Thanksgiving Day, Holidays shall be defined to include the period from 7:00
pm on the evening before the holiday until 700 on the evening of the holiday itself Father's
lirst alternating legal holiday shall be New Years Day;
(Agreemenl continued on nexl page)
Custody Stipulation and Agreement
page ..1.
0, On Brillany's binhday from IUO a muntil 2:30 p,m,; and
E, On Father's hinhday from 8:30 am, until 2:30 p,m,
4. Mother shall exercise custody on Mother's day
5. Father shall be responsible for transponing the child at the scheduled times indicated
above as well as during alltil11es during which his exercise of custody with the child may be
agreed upon
b The panies shall not abuse or otherwise engage in the use of illegal drugs, especially
while the child is in their physical cuslody
8. This schedule shall govern should the panies not be able to reach an agreement
9, The panies agree thatlhis Agreement is entered into aner a greal deal of contemplation
and because it is in the best interests of the minor child The panies specifically empower,
authorize and request that the Coun of Common Pleas of Cumberland County, Pennsylvania to
enter this Agreement as the Order of its Coun, as soon as practicable aner the execution of this
Agreement
10. The panies agree Ihat any amendment to this Agreement must be in writing and signed
hy both panics in order to be effective Any course of conduct, temporary depanure from Ihis
Agreement by the panies, or luture reconciliation, whether temporary or otherwise, shall not
operate to amend or nullify this Agreement.
IAgreemenl conlinued on nexl page)
Custody Stipulation llnd Agreement
page .4.
II, Mother has been represented by her legal counsel. Shawn P McLaughlin,
Mother's allorney dralled thi~ Stipulation and Agreement. Great-Grandmother has been
represenled by her legal counsel. Harold S, Irwin. III, Father has represented himself. Father has
fully read and understands the provisions contained in this Stipulation and Agreement and has not
relied in any way upon Mother ur Great-Grandmother's counsel in negotiating and entering into
this Stipulation and Agreement. Mother, Father, and Great-Grandmother fully understand and
recognize that this Agreement is in the best interests of the minor child,
12 This Agreement shall become etfective immediately, and Father's nrst alternating
wnkend period shall begin on Decembet.J.L. 1996.
IN WITNESS WHEREOF, the parties hereto set their hands and seals the day and year
tirst above wrillen
WITNESS.
,. I"~',
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-'SEAL)
c ~~NIFER:lwotA~ (~rJ.~~L)
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(}RACE V, WOGAN (PllUmaf Great-
Grandmother)
10: 111)(llo:U:iI.lIlJlt
.
COMMONWEAI.TII (n' PENNSYI,V ANIA
COl1NTY OF ('[IMBERlAND
I" (I 'l
, 'PI o. " ..
On this. the _">..... dtlY of.-J.cuL'...!..I.u..:;..". tt)%, before me the mderslgned officer.
personally tlppellred Jennililr L. Wogan, known 10 me (or satisfactoriy proven) to be the person
whose name is subscribed to the within instrument and acknowledged that she executed same for
the purposes therein contained.
IN WITNESS WHEREOF. I hereunto set my hand and ollicial seal,
NOTARIAl. SEAL
OlQA N, DAVElER, Nnlluy PubHc
lInollSl.~ latlOl6ter Coonty, PA
"., Comml$llon ~ru ()!;1. 2. 2011O
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