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HomeMy WebLinkAbout95-06564 ,.,. ..S~i:~ :, .~. ,....,. t~l~_~.~~~ i-:;)~;'_ ---;~ .~ ':!'l/tJj ;.~~~ .. ..~:.....~....,.~,.,...- ~"""r ,.....-. · 0' ~ I ~ ~~ ~ ~ il F U) !5 · t5C1'O :e \":. t-~ ~'" \0 B ''--~ ~ ~ C\..J '- ~<><8 ...... .. · · .... .~... -.. · · · ..' '. .. ... ..,..:.-=---~_:.... ."C-ll j - Uf ~ IN THE COURT OF COMMON PLEAS : - . . OF CUMBERLAND COUNTY . .. ~ . i STATE OF ~ PENNA. ~ '. . .. .. I t . IUMJmER.EE..MYERS .. ........ ! . .' Ii N (). ....~.s.::-.~.~.~.~. ....,............ 19 " ..............,....Plaintiff ............i Civil Term . " II .; _ Vf.lI'SlIli II " t" d ., ~~EV.f:~..W.~.~Y.ERS . ... . . ....... I . . ' :; .. ....De.fendant d . . . i ~ ~ DECREE IN ; ~ DIVORCE . . . , ;. . AND NOW, ....... .. . /!I~r:J.. /,1, ~.. .. '. 19.., ~,6,. it is ordered and ! , decreed that.... .~~t'l..~IJI!l~~,E; ,f:lY,~~f?. , .. .. .. .. .. .... .. .... ... plaintiff, ~ . and... S,'l:EVEN. ,\Ii., MYERS.. , ......, .. , , . , , , .. .. , , , , .. .. ." ..,. 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; ~ ~, ~ The Property and Separation Agreement, dated November 9, :, to to...................'.................................................., ~ ~ ) ~,9,~!, ~,~~, ~,t.~~7h,e,~, ~? ,~~~~.C;~I?~.., ,~,:" ,i,~7?~,~~~!l,t,~~, ~,e,~~~~, ,~':I~. ,~~~ll 8 . . .. ~ . ' ~,c~L .. .: · '/.J-u.lt<:~. f'.l~~ ~~ J, : 4<#,r,L'L k ~k~ LJ;Z ..~, 0/ 'r .,rothonotnry I ~ -- .-.."..."."..... . ... '1Il .~~~~--~~------~---- J/~~.t1J.('~ h!~~~ ~ /f.;1d ,~~ '71~ Iwt~ ~ ~. . . . . '-'" ;0.... ,.... -, '" J-~-. ., l.lit,;:_ (.):r ~~% -0-< t:~C'-:'~ Ql-;J'::- , "''',n &..",I~~~ lU.....t":r. =: fl,I~hj u..x;Ln.. 1-"" ::;u ::c Q.. u> <:) -:r ... C> = , ~ " . " ... . ...w...JMAa1IN, ao. . :Pf.A.......... . WI".,..", PA 172llI " ..(717)l1l.IOOI. FAX(7I7)M1.m. . MARTIN ... G~... . AlTORHEYS AT LAW . KIMI....LYS; oLY,1IQ, ~RNmhMai.sllUl' ('10. L ~Mlnol (717)26,1.1500 . PAX (71 .7111 . .. .' " . PROPERTY AND SEPARATION AGREEMENT 9.5'- ~ c,5~ Y' .c. AGREEMENT, made and entered into this day of blV, 1995, by and between STEVEN W. MYERS, of Towna p, Franklin County, Pennsylvania, hereinafter referr to as "HUSband"; and, KIM SHEREE MYERS, of the borough of Carliale, cumberland County, Pennsylvania, hereinatter referred to aa "Wife". WITNESSETH: WHEREAS, the parties hereto are Husband and Wife, having been married in Chambersburg, Franklin County, on or about May 9, 1992; and WHEREAS, children were acted in loco there are no children of this marriage and no adopted. Wife is not now pregnant. Wife has never parentis to Husband's children; and WHEREAS, the parties hereto have ceased to cohabit together as husband and wife; and WHEREAS, both and each of the parties hereto have been advised at their legal rights and the implications of this Agreement and the legal consequences which may ensue from the execution hereof; and . WHEREAS, Wife acknowledges that she is thoroughly conversant with and accurately knows the size, degree, and extent of the eatate and income of Husband, and Husband acknowledges that he is thoroughly conversant with and knows accurately the size, degree, and extent of the estate and income of Wife; and WHEREAS, diverse unhappy differences, disputes and difficulties have arisen between the parties and it is the intention of Husband and Wife to live separate and apart for the reat of their natural lives, and the parties desire to settle fully and tinally their respective financial and property rights and, in general, settling any and all claims and possible claims by one against the other or against their respective estates. Accordingly, except as otherwise expressly provided by this Agreement and in consideration of the promises and mutual undertakings herein contained, intending to be legally bound hereby the parties do mutually agree as follows: 1. .o~i.l ..aurlty DI1.h.ra Husband's social security number is 208-50-5718. Wife's social security number is 172-46-2732. 1 '. .' " I. ..rraaty of full dlaalo.ur. Husband h.reby represents and warrants to Wife that as of thi. dat., h. doe. not po..... any property or interests in property other than the item. li.t.d in thi. Agreement; and that the item. ..t forth and liatad in thia Agreement constitute full and complete di.closure by Hu.band of all property and interests in property held by or for the ben.fit of Husband. Wife her.by r.pre..nta and warrants to Husband that aa of thia dat., .he doe. not po..ess any property or interests in property other than the item. li.ted in this Agreement; and that the items .et forth and li.ted in this Agreement cor.stitute full and complete di.closur. by Wife of all property and interests in property held by or for the ben.fit of Wife. I. ..ltaBaa aD ..~.rial r.pr...D~.~iaB. Husband and Wife acknowledge that in entering into this Agreem.nt, each ha. been induced to and is directly and materially relying in good faith on the truth and completeness of the r.pre..ntations and warranties expressly made by the other party to thi. Agreem.nt. t. DAb~. an4 ObllqatioB. a. Husband hereby acknowledges that as of this date, the following outstanding debts and Obligation. are the .eparate obligations of Husband and were incurred solely by Husband for the sole benefit of Huaband and Husband agrees to assume sole liability for and to pay each outstanding separate debt and obligati~n without any contribution from Wife: 1. PFCU loan for Huaband's daughter; 2. Husband's student loan; 3. Husband's medical bills; 4. Husband's daughter'S medical bills. b. wife hereby acknowledges that as of this date, the following outstanding debts and obligations are the separate obligations of Wife and were incurred solely by Wife for the sole benefit of Wife and Wife agrees to assume sole liability for and to pay each outstanding separate debt and obligation without any contribution from Husband: 1. wife's apartment lease and associated utility bills; 2. wife's medical bills. 2 " , c. Husband hereby agrees to assume and fully pay and to indemnify and hold Wife harmless from each of the following outstanding debts, obligations, and expenses with respect to those debts: 1. American General boat loan; 2. One half i1/2) of loan from Wife's parents (this amount shall be payable to Wife who shall then be solely responsible for payment to Wife's parents); 3. 1st Card Visa. d. Wife hereby agrees to assume and fully pay and to indemnify and hold Husband harmless from each of the following outstanding debts, obligations, and expenses with respect to those debts: 1. PFCU Auto loan; 2. One half (1/2) of loan from parents; 3. Share of 1st Card VISA ($2,503.00 payable to Husband on December 1, 1995.) e. Wife shall use her best efforts to obtain from the following obligee(s) a release of Husband from liability on any continuing guaranty of the following obligation: PFCU Auto loan. f. Husband shall use his best efforts to obtain from the following obligee(s) a release of Wife from liability on any continuing guaranty of the following obligation: American General boat loan. g. In the event that any outstanding debt or Obligation of any kind has been incurred by Husband or Wife, other than the debts and obligations set forth and listed above, (and is hereafter asserted against the other) the party actually incurring the debt or obligation shall assume and be solely responsible for paying it and shall hold the other party harmless from all claims with respect to the debts, obligations, and expenses with respect to those debts. h. Husband and Wife hereby warrant that each will execute all documents necessary to effectuate the transfer of the marital home to the buyers of same on October 31, 1995. The parties further agree that all proceeds from the sale of said real estate shall be first used to payoff the balance due on the following debts: 3 . '. PFCU Visa, account number 423790000008083, with a current approximate balance of $6,367.00; Consumer's Edge, account number 425331167908649, with a current approximate balance of $6,904.00; American General furniture loan with a current approximate balance of $2,000.00. Any proceeds remaining after paying these accounts shall be split equally between Husband and Wife. 1. 2. 3. 5. Maior r~p.ir. If major repairs are required on the family residence prior to close of escrow of sale, Husband and Wife each shall be obligated to pay one-half of the costs of the repairs. Major repairs are defined as those in excess of $300. Major repairs shall be made by agreement of the parties or court order. .. %BGG.. ~.. ..~urD. a. Husband and Wife shall file joint federal and state income tax returns for the year 1995. The costs and expenses of return preparation as well as all taxes, interest, and penalties shall be borne equally by each party. Tax refunds, if any, shall be divided equally. b. Husband and Wife each agree to notify the other promptly in the event the Internal Revenue Service or any state or local taxing authority provides notice of an audit, deficiency, refund, or other adjustment regarding a tax return that was jointly filed or that should have been jointly filed. The party receiving such notice from a taxing authority shall provide a copy of the notice to the other party. Husband and Wife further agree to cooperate fully with the other in any claims for refunds or in defending against any deficiencies that may be determined with respect to joint income tax returns filed (or to be filed) for the calendar year 1995 and years prior. This includes, without limitation, the making, executing, and filing of amended income tax returns; applications for refunds, protests, and other instruments; and documents as may be required. Husband and Wife shall divide and pay all costs and expenses equally. 4 7. Pall.lall. Husband and Wife hereby waive any rights that either may have in the other's pension, profit sharing, deferred compensation or other retirement plans. 8. "'.r.allal "'ro9.r~y Husband and Wife do hereby acknowledge that they have previously divided their tangible personal property as outlined on Schedule A, which is attached hereto and incorporated herein by reference, including, but without limitation, jewelry, clothes, furniture, furnishings, rugs, carpets, household equipment and appliances, pictures, books, works of art and other personal property and hereafter Wife agrees that all of the property in the po.session of Husband shall be the sole and separate property of Husband; and Husband agrees that all of the property in the possession of Wife shall be the sole and separate property of Wife, with the exception of certain items clearly marked and agreed by the parties. The parties do hereby specifically waive, release, renounce and forever abandon whatever claims, if any, he or she may have with respect to the above items which shall become the sole and separate property of the other, with full power to him or her to dispose of the same as fully and effectually, as though he or she were unmarried. Each of the parties shall hereafter own and enjoy, independently of any claim or right of the other, all items of personal property, tangible or intangible, hereafter acquired by him or her, with full power, in him or her to dispose of the same a. fully and effectively, in all respects and for all purposes, as though he or she were unmarried. Husband and Wife further agree that Wife shall have no interest in any real estate purchased by Husband subsequent to the execution of this Agreement, and Husband shall have no interest in any real estate purchased by Wife subsequent to the execution of this Agreement. t. Motor Vehicle. Husband shall convey his right, title and interest in and to a certain Nissan 240 SX to Wife. Wife hereby assumes all liability and shall hold Husband harmless from payment on same on the automobile loan connected to this vehicle. 10, Iat Wife shall convey her right, title and interest in and to a certain .cajun" boat to Husband. Husband hereby assumes all liability and shall hold Wife harmless from payment on same on the loan connected to this boat. 5 . 11. "ri~.l ...la.DC. The real property known as 8200 Michaux Drive, Fayetteville, pennsylvania, is to be sold on OctClber 31, 1995, as previously agreed. The parties further agree that the proceeds of sale shall be used to pay the debts herein described under paragraph 4(h), and any remaining proceeds will be divided equally between the parties. 12. Cle.lng .aaouft~. Husband and Wife each represent to the other that from thia date each party shall not charge or incur or cause to be incurred any liability or obligation based on the credit or name of the other. Each of the parties shall do whatever is necessary to close immediately all joint accounts in the name of Husband and Wife or either of them under which one may make purchases on the credit of the other. 13. ..~.~. >>laftftiD9 Husband and Wife each forever waives any right to inherit from the other and the right to receive any property on the death of the other, except by reason of a will, codicil, or republication of will by the other party executed subsequent to this date. 1t. ..lv.r of ri9b~ ~o .a.ifti.~.r ..~.~. Husband and Wife each waives all right to act as administrator of the other party's estate and all right to request or petition for the appointment of any person to serve as such representative or to act as the executor of the other's will, unless expressly named in a will, codicil, or republication of will by the other party executed subsequent to this date. 15. .ff.a~iv. D.~. of agr....ft~ This Agreement shall be effective as of the date of this Agreement. All Agreements and representations of Husband and Wife shall be deemed to have been made as of this date. 1'. ~~h.r a..uranc.. Husband and Wife shall each execute and deliver promptly on request any additional papers, documents, and other assurances reasonably necessary in connection with the performance of these obligations. In the event that either party fails or refuses to comply with the provisions of this paragraph, the failing party shall reimburse the other party for all losses and expenses including, but not limited to, attorney's fees and costs incurred as a result of such failure. 6 . 17. .......t....lea tit aaurt Thia Agr..m.nt may b. aubmitt.d by .ither party to any court before which a p.tition for the dissolution of the marriage may be pending for approval by the oourt and tor incorporation into final jUdgm.nt d.cr..ing the diaaolution of the marriag.. D.apit. any auch incorporation, the providon. ahall not m.rg. into said jUdgm.nt but ahall aurviv. and may b. indep.nd.ntly enforced. 11. .uaa...laaa Thia Agr....nt aha11 inure to the b.n.fit of the parties and th.ir r.apectiv. h.ira, administratora, .xecutors, auccessors, and aa.igna. 1.. ".iG. at Can...1 Huaband acknowlMdg.a that h. h.a had the opportunity to retain counael but h.a d.cid.d not to do ao. Huaband fully und.rstanda the facta and t.r.a of thia Agr..m.nt and .ntera into it voluntarily. Hu.band alao acknowl.dg.a that Kimb.rly s. Gray, Esquire, did not r.pr.a.nt him. 10. .G~ia.a a. Any a.rvic. to the Huaband ahall be addressed to hi. at 804 siloam Road, Chamberaburg, P.nnaylvania, 17201, or anoth.r address d.signat.d by him in writing to the Wif.. b. Any a.rvic. to the Wife ahall be addr.ss.d to h.r at 30 North orang. str..t, carliale, Pennsylvania, 17013, or anoth.r addr.as designated by her in writing to the Huaband. 11. c.,~la.. ... %at.~,r.t.tiaB Paragraph captions have be.n ua.d throughout this Agreement for conv.ni.nc. and r.fer.nce only and are not intended to be used in the conatruction or int.rpr.tation of this Agreement or any of it. proviaiona. No proviaion of thia Agr.ement is to be interpreted for or againat any party by virtu. of the fact that the provision wa. draft.d by that party or that party's counsel. II. ".au~iD& i& CGUB~.rp.r~. This Agr..m.nt may be ex.cuted in two or more counterparts, .ach of which ahall be an original and all shall constitute one and the .am. inatrum.nt. 7 '. . 33. dever.ift9 LaW This Agr.ement has been drafted and shall be deemed executed in pennaylvania. The Agreement shall be governod by and enforced a. an agreement made and to be performed in accordance with the internal lawa of the state of pennsylvania. at. ..v.rahil1~y In the event that any provision of this Agreement is found by a court of compet.nt jurisdiction to be invalid or unenforc.able, auch proviaion ahall be deemed severable from the remainder of this Aqr....nt and shall not cause the invalidity or unenforceability of the rellAind.r of this Agreement~ and if a provision shall be d.emed invalid only b.caus. of excessive scope or breadth, the provision ahall be d.emed valid to the extent of the scope and breadth permitt.d by law. 21. .aiver or lIo4i~ia.t.1GIl t.o ha ill wrlt.ill9 No modification or waiver of any of the terms hereof shall be valid unless in writing and signed by both parties and no waiver of any br.ach hereof or default hereunder shall be deemed a waiver of any .ubsequ.nt d.fault of the same or similar nature. No oral modification of this paragraph shall be valid. .1. Br..all If either party breaches any provision of this Agreement, the other party shall have the right, at his or her election, to au. for damagea for such breach or seek such other rem.diea or relief aa may be available to him or her, and the party br.aching thi. contract shall be responsible for payment of legal fe.s and coat. incurred by the other in enforcing their rights under thia Agre.m.nt. 27. Whole ~re_eD.t This Agreement constitutes the entire understanding of the parties. It supersedes any and all prior oral or written agreements between them. There are no representations, covenants, warranties or agreements other than those expressly herein set forth. 8 - " . SCDDm.a A DlanUU'l'IOI or IlAaIlar, Jao.an ~r.an.J prqperty a~ Huaband ~rRonAl 9~r~y a~ Nl~. Seri.. ESE bond. Ni..an 240 SX " .Cajun. boat Huaband'. p.n.ion HU.band'. bank accounts Hou.ehold furni.hings and other it... in HUsband's po.....ion. HU.band'. .eparate (non- ..rital) property 50t of n.t proc.eds of sale of real prop.rty (.arital ho..) after payment of debts deacribed in paragraph 4(h). 50t of n.t proceed. of .ale of real property (marital home) after payment of debt. described in paragraph 4(h). Wife'. pension Wife'. bank account. Household furni.hing. and other ite.. in Wife'. possession Wifels separate (non- marital) property ~ 11 ~ II) -- ;;;: ~ I;: I~ N .r i:~~ :x: 1:5:<; ~ 0... ... (:)?J . . ~;, r- ;."In .., N [g~ '- ~p "" ""': F ::c ;~u. ;-:: ~ on => r;n U ~. . i' , , , . E.IlANltLlN MAIl11N. DQ. Z",,,1!aot Mal. -.r W.,......" PA 17261 (717)76101001 . FAX (717l76Z.'I'1 MARTIN .. GRAY;Pp. ATlURNEYs AT LAW IUIIIIDLY N, GRAY, DQ. lR Nrcth MallI 51"0' . 11111nhe"boq, PA mOl . (7I11l~H~0lI' PAX (717IlIl.1.1I7R .~ Ln en - >->- :;!i>- lut;3~ ~;r,8;j; "",,0 _, ......:r:o. 01- ~_I JC"<f>o. :I::f..J!!! ... "'- _&dLlJ~ U,.::t;",hJ >-%"- ...=> 0" .. Eo rlANKLIN M.UlnN. Z".A IlIol Mal. _ . Wayn,,,,,",,, ~ 17161 (711)761.1001 . FAX (1t7)761-$151 E N In ("I) <D - ... "'" = ~. \\ ~~ ~\) -- ~ ~ ~, ~M ~~ .. . MARTIN .. G~PP ATTORNEYS AT LAW . IUMUIlLY.. GUY, )R!'(llllU4.1. Slrttl . Chambmbura, PA 17101 ~ (717)263-1500 . FAX 17l7lZ6.1.7111 KIM SHEREE MYERS IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT, PA. Plaintiff vs. CUMBERLAND COUNTY BRANCH CIVIL ACTION - LAW STEVEN W. MYERS Defendant NO. 95-10fp'/ Civil Term 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 in divorce or annulment may be entered against you by the court. A judqment 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 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 Franklin County Courthouse, Charnbersburg, Pennsylvania 17201 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 HAY 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. Pennsylvania Bar Association Lawyer Referral Service Telephone: 1-800-692-7375 (PA ONLY) or 717-238-6715 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Franklin County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court, You must attend the scheduled conference or hearing, P.C, By Attorney for P 38 North Main Chambersburg, 717/263-8500 0\ N Jw t.; :II:: c... \0 I t' to'; 15 C:.\ In '.tl ..., . . 10 nANXLIN MAaTlN, ZH-A I!aoI Mall . W.)'I......, PA 17261 (71717Q.\(lClI . PAX (717)761.5151 MARTIN ... GRAY; plJ'o A11llRNEYS AT LIIW KIMBERLY l,llltAY.I1llQ, l. N",h M.ln S".., . 111.mIwf.hur" PA 17201 .. 17I7)l~H'110 . PAX (717)26).7.7. . I "'1_'''_--' ,............ ........... 1lIIIDlIInlI.....(lar. I ~Z!!-..._...._"..-...._--.. "'1Ii~ ! #&"_..;..."..............-.--.. 1, c .,. I"~' :, =~--_....__.._- ..0......'1 JlIIMfr J ' .=="............-..---.....- I .,i..,1 Sd-f'$\ I.u, rnYErS CIIIIUlp L 1.~~ I . cro4 ~,lc::a.m Rd. _ ; a... r ~ber~ bllr~ 1 p~ neo I L..... a COD J . I: ..,.."". I : .L f 00 ?; " c N '-;~ (3:- . ''l. .tJ :t: .!")~ E= 0- ...... i In .~ f) ::) ~ - ~~~ " ~! p;: "'" ;t: ~ ,It; >., .:> , U'" D , " .. . .. RANIILIN IoWmN, IIQ. ZJt.ABo..IIl.... . w.,......... PA 17261 (717)711-10111 . FAX (717)76%1151 ... MARTIN ... G~Pp. ATrORNEYS AT LAW . ,., .- ,\ IUMlULVI.IlBAY, DQ. 11 NIO,h Main SIR" . 0............1, PA 17201 ~ ,f .':'!~HlOO . PAX (7171211.1,7171 ~ < , plaintiff IN THE COURT OF COMMON PLEAS OF THE 9TH JUDICIAL DISTRICT, PA. i I , KIM SHEREE MYERS ;. i \:~ I' I ~< < CUMBERLAND COUNTY BRANCH VB. CIVIL ACTION - LAW STEVEN W. MYERS Defendant NO. 95-6564 Civil Term JFFYD~VYT OF CONSENT 1. A complaint in Divorce under section 3301(C) was filed on November 16, 1995, and was served upon the Defendant on November 28, 1995. 2. The marriage of plaintiff and Defendant is irretrievably broken and ninety days have elapsed from the date of service of the complaint upon the Defendant. 3. I consent to the entry of a final Decree of Divorce. 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 the costs of these proceedings will be paid for by plaintiff. 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. 4904 relating to unsworn falsification to authorities. Date: 2Jrdq~ tl A.1 U. JJ {i 1M SHEREE MYERS plaintiff .~ en ... <:) fe. I N (... ".I~ IQ .. ,.>,,) --. U...~. ~ u.. :~ r}~ . Iii In ;:'.;n - ; J.,; 1:1" UifE ": ..- t5 .~ d 'J) c; ..... . .. - .. , . II. flANIlLIN MA; DO. . DtoAr...... ~~ ...,...... PA 11361 (711l111.ICIOI . PAX (717)'762.5151 MARTIN .. G~pPo A1TOllNEY8 AT lAW . KlllIIaLY& OIAY, DQ. ~lRN~IMaI.5"'I' ClI,-LII~.PAlnol (7I7126,1.Rm . PAX (717 7171 ~ In G ~ ..::1 N -'.. ~8 13;;; e-i .- ;.J:'~ ...... r,~ u.. -. ~n r- (?~ IL '. 'f> u- N .~~~ ,.,4_ ~ 1.1. ~ C., '>:tr.5 u.;:-., ...:J: F .- ~;~ (l. - 15 '" ::> '" u ., .. . " I. ftANXLlN MAmN, DQ. '" 1!9-AEMl MIl. SIne. . '*"'....... PA 17261 (117)762.1001 . PAA (717)762-"'1 MARTIN .. G~Pp. ATl'ORNEYS AT LAW -.. , ;. . . KIMIEIlLY H, UIlAV, [llQ. ~M N""h MIlII Sl/<.. . O,.mIwnbllrt, PA 17201 .1lmll.l,R!lXl . PAX (7l1)lftf.711R ~ r.n [:':; . ~ _"1 .. .;~ N :.)~ I~ x: (J~;.. '-);'e "- [~l~ t- . , ;"i,n N :~2 I" C'l-~ F ~'1i :~lJ? l:s - <0 ;:; U\ U ,'. .t-,,} w ~- i 10 raANItLlN MAlnN, IIIQ. 239-A I!Iol MIl.SUft' . W.)'IIC.... PA \7:161 (717)762.\001 . PAX (1\7)162.'\'\ .". .; -.;.--"t ... .. fI & . MARTIN ... G~P~ ATI'ORNEYS AT LAW . .. . ~ . ItlMaEILYH.ClIlAY,DQ, ~K NIl1h Malll Slrtel . O1.mhtrIhn, PA l1201 (1I1ll6l.15oo . PAX (7I1\26.f.1111 " .