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DEBRA K. BEAR, : IN THE COURT OF COMMON PLEAS OF
Plaintift' : CUMBERLAND COUNTY, PENNSYLVANIA
.
.
VB. : CML ACTION. LAW
: 95-6784
JOHN A. BEAR,
Defendant : IN DIVORCE
ORDER OF COURT
ANONOW.'N'~"YOf ~
. 1997, upon
review of the within Petition for Contempt, it is ORDERED AND DIRECTEO that John
A. Bear, Defendant, shall appear on the J. 6 171... day of <t 6 /l u liA.J1
I
I,' ~o ~
1997 at .... o'clock -f-.m. in Courtroom Number ,-, of the
Cumberland County Courthouse to show cause why he should not be held in contempt.
BY THE COURT,
J.
.
!,.,
ALED-OFFlCE
OF TI;r; rr-rli1-l"")I\'OTAllY
97 J~~1-6 PH 4: '2
C,..qr J' .'u' "'u'iTY
\JNibl.oli;"'l'J', Lv I
PENNSYLW\N~
.'
vs.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY. PENNSYLVANIA
: CIVIL ACTION . LAW
: 95-6784
DEBRA K. BEAR.
Plaintiff
JOHN A. BEAR.
Defendant : IN DIVORCE
PETITION FOR CONTEMPT
AND NOW, comes Debra K. Bear, Petitioner. by and through her
attorneY8, Griffie & Associates seeking an Ordel' for contempt and in support
thereof avers the following:
1. Debra K. Bear, Petitioner. is an adult individual residing at 1809
Pine Road. Newville, Cumbel'land County, Pennsylvania.
2. John A. Bear is an adult individual residing at 532 Pine Road,
Carlisle, Cumbel'land County. Pennsylvania.
3, On or about December 6, 1995. John A. Bear was served with a
Complaint In Divorce docketed to number 95-6784 in Cumberland County.
4. On or about August 13, 1996 as part of said divorce proceedings.
John A. Bear signed a Property Settlement Agreement. A copy of said
Property Settlement Agreement is attached hereto and incorporated herein
as Exhibit "A",
.. ."
5. In said Property Settlement AIr.,'eemellt Respondent, John A. Bear,
agreed to indemnify and hold Wife harmless for loan account number
4001008003052715. Mr, Bear agreed to be responsible for payment of said
account.
6. Since the date of Husband signing of the Property Settlement
Agreement, Respondent has not made any payments for said account.
7. In paragraph six of the Property Settlement Agreement, Husband
agreed to pay one-half of the total costs of obtaining the divorce, including
counsel fees. Since the date of signing the Property Settlement Agreement
Husband has not paid his one-half of the total costs of obtaining the divorce,
including counsel fees.
8. One half of said costs for obtaining the divorce is $399.25.
9. Notice was sent to Husband on or about December 18, 1996 that
should he not reimburse his wife for one-half of the costs of obtaining the
divorce, including counsel fees, and begin making payments on the loan
account his wife would take the appropriate legal action. A copy of said letter
is attached hereto and incorporated herein as Exhibit "B".
10. To date John A. Bear, Respondent, has not made any payments
toward the above-referenced loan account nor has he reimbursed Debra K.
Bear for one-half of the costs for obtaining the divorce.
,...^, ,
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WHEREFORE, Petitioner prays that the Court find John A Bear in
contempt and order a wage attachment against John A. Bear in the amount
of the monthly loan payments for account number 4001008003052715 from
August 1996 until the loan is paid in full, and order payment in full to Debra
A Bear in the amount of $399.25 for one.half of the costs of obtaining the
divorce including attorney's fees.
Respectfully submitted,
GRIFFIE & ASSOCIATES
~sr6i!:r~
200 North Hanover Street
Carlisle, PA 17013
(717) 243-5551
." .-...--
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VERIFICATION
I verilY that the statements made in the foregoing document 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 falsifications to authorities.
DATE:h1.~.9~
~~ I:&-
BRA K. BEAR
DEBRA lC. BEAR, . '~N THE COURT OF COMMON PLEAS OF
.
Plaintitt . CUKBERLAND COUNTY, PENNSYLVANIA
.
.
.
vs. . CIVIL ACTION - LAW
.
.
.
JOHN A. BEAR, . 95-6784
.
Detendant . IN DIVORCE
.
1I1l1l?ftL 81f11"1tT........ &CDIJs.a:W'InII'fI
This Agre_ent _ae this J(}fi1 day ot \J~if/u, ],996,
by and bet:ween DeI:lra It. Bear ot 1809 pine Road, Newville,
Pennsylvania, hereinafter referred to as WIn, and John A. Bear,
ot 532 Pine Road, Carlisle, Pennsylvania, hereinafter referred to
as BU8BaJ1D,
In'f'nSSB'I'K:
WHEREAS, the parties bereto are husband and 'lite, havinq
!:leen ~oine4 in .arriaqe on Auqust 5, 1993, in CUllberland County,
Pennsylvania; and
WHEREAS, a Complaint in Divorce has !:leen filed in the Court
ot Co_on Pleas ot CUlIIberland County, Pennsylvania, to No. 95-
6784 Civil Term: and
WHEREAS, the parties hereto are desirous ot settling tully
and tinally their respective financial and property riqhts and
obliqatiorw as l:Iet:ween each other, inc1udinq, without limitation,
the settlinq ot all matters between them relating to the
ownership of personal property, and in qeneral, the .ettlinq ot
any and all claim. and possible claim. aqain.t the other or
aqainst their re.pective estate..
NOW THBRBFORB, in consideration of the.e considerations, and
the mutual proai.e. and undertakinq. hereinafter .et torth, and
tor other qood and valuable consideration, receipt and
EXHIBIT "A"
. '.
sufficiency of which is hdre):,y acknowledged ):,y each of the
parties hereto, Kus):,and and WHe, each intending to ):,e legally
):,ound, h.reby cov.nant and agr.e as folloWS:
1. :A4Vic. of cous.l: Th. parti.s her.to aclcnowl.dqe that
each have ):,.en notHi.d of his or her right to consult with
counsel of his or her choice, and have ):,..n provid.d a copy of
this agreement with which to consult with couns.l. Wif. is
repr.sented by Anne M. Shepard, Esquire. Each party aclcnowledges
and accepts that this aqreeaent is, in the cirCUJllSt&nc.s, fair
and equitabl., and that it is ):,eing entered into freely and
voluntarily, after having received such advice and with such
Jcnow1edg. as .ach has sought fro. counsel, and that execution of
this aqr....nt is not the r..ult of any duress or undue
innuence, and that it is not the result of any ilIproper or
illeqal agre_ent or agre_ents.
2. Divorce: The parties agree to th. entry of a Decree in
Divorce. On or about ' 1996, the parties will execute
Affidavits of consent under section 3301(C) of the Do.estic
Relations Cocle, consenting to the entry of a Decree in Divorce.
3. 1'enonal 1I1:Oper1:Y: 'rhe parties have aqreed to divide
their personal property to their .utual satisfaction. The Wife
shall o:lwn on her own ):,ehalf and independentlY of any claim of
rights of the Husband all it... of personal property of every
ldncl, nature and description and however situated which are in
her po..ession or which may hereafter belong to the wife with
full power to the wife to dispose of the same as fully and
effectivelY, as if she were not married. 'rhe Husband shall own
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.1 on hi. own behalt and independently ot any claim ot rights ot the
i
. , Wite all itUlS ot personal property ot every kind, nature and
.1
description and however situated which are in his possession or
which hereinatter belong to the Husband, with tull power to the
husband to dispo.e ot the same as tully and ettectively, as it he
were not married.
4, Mutual PropeR]' aDeS ..tate waiver: Except as otherwise
expres.ly set torth herein, in which event such express provision
shall take precedence over this paragraph, the parties hereto
intend that trOlll and atter the date ot this Aqre_ent, neither
shall have any spouse's rights in the property or estate ot the
other, and to that end both parti.s waive, relinquish, and
torbear the rights ot dower or c:urtesy, rights to inherit, riCJhts
to claill or take the au.!:land or wite's or tamily exemption or
allowance to be vested with letters ot administration or letters
testamentary, or to take against any will ot the other, and each
agrees with the other it either should die intestate, his or her
share shall descend to vest in his or her heirs at law, personal
representatives, and next ot kin, excludinq the other as thow;b
he or she had died a widow or widower. And each turther agrees
that should the other die testate, his or her property 511all
descend to and vest in those persons set torth in the other's
Last Will and Testament as though the spouse so desiqnated as
beneficiary l1ad predeceased the testator. The parties turther
agree that they aay and can hereatter, as though unmarried,
without any joinder by him or her, sell, convey, transter or
enc:umber any and all real estate and personal property which
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.ith.r ot th.m now or h.r.atter own or po..... and turther aqr.e
that the r.cordinq ot this Aqr.ement shall be conclusive evidence
to allot hi. or her riqht to do .0. The .aid Husband and Wite
do hereby irr.vocably qrant, each to the other, should the
exerci.e ot this power hereby qiven be necessary, the riqht and
the power to appoint one or more tim.s any per.on or persons whom
the hu.band or Wite .hall desiqnate to be the attorney-in-tact
tor the other, in their name and in their .tead, to execute and
aclcnowledqe any cieeci or cieecis, relea.e., quit claims, or
.atistactions, under seal or otherwise, to enal:lle either party
hereto to alienate his or her real or personal property, but
without any power to impose personal liability tor breach of
warranty or oth8%Vise. Each of the partie. hereto turther waiv_
any riqht of election contained in Chapter 22 of the Pennsylvania
Probate Estates anci Fiduciaries Code, and any riqht to seele or
have an .quitabl. distribution of married property ordered by the
Court subsequent to Section 3502 ot the Domestic Relations Code.
Each ot the parties hereto turther aqrees that neither shall
hereafter be under any leqal obliqations to support the other,
.~
pay any expenses tor maintenances, funeral, burial, or otherwise
for the other, and to that end each ot the parties hereto does
her.by waive any riqht to receive .upport, alimony, alimony
pendente lite, counsel fee., expense., or any type of financial
a.sistance what.oever trom the other, except as otherwise
expre..ly provided for herein.
5. K&rit.l Detlt: The parties have t..o loans throuqh PNC
Bank in both parties' names, Account #4001 008 003 052 715 and
Account .4002 008 000 698 436. Husband aqrees to be r.sponsibl.
for paym.nt of said accounts and will indemnify and nold the Wife
barml... for said d.bt. Each party will b. responsible for the
debt on the cr.dit card accounts in bis or b.r name. Each party
will incur no debt for which the other may be liable, and will
indelllnify and hold the other I1armless for any debt so incurred..
6. Husband and Wife agr.e to each pay on.-balf of the total.
co.t of obtaininq th. divorce, including couns.l fees.
7. KoditicatioD: No modification, rescission, or amendlllent
of this .gr....nt shall b. eff.ctiv. unl... in writing signed by
.ach ot the parties hereto.
8. applice1e Law: All acts contemplated by this aqr.tIlMnt
shall be construed and enforced under the laws ot the
COmlllonw.alth ot Pennsylvania.
9. ~._.Dt BiD4iDq OD parti.. aDd lI.in: This aqreement,
except as otherwise expressly provided berein, snall bind the
parti.s her.to, and their resp.ctive heirs, executors,
adlllinistrators, leqal representatives, assigns and successors in
any interest ot the parties.
10. Aqr._.Dt Kot to tI. x.rg.d This aqreement shall be
incorporated into the final decree of divorce of the parties
hereto for purposes of enforc8lllent only, but otherwise shall not
be merq.d into said d.cree. The parti.. shall have the right to
entorce this aqre8lllent under the Domestic Relations Code and in
...~,
addition, shall retain any r_edies in law or in equity under
this aqre_ent as an independent contract. Such remedie. in law
or equity are specifically not waived or relea.ed.
11.
DoauaeJlt. :
The parties hereto aqree that they will
execute and deliver one to the other any dOCWllents nece.sary to
qive eftect to the teras ot this Aqre_ent,
12. areacla: In the event that either party breach.. any
provision of this Aqre<<aent, he or she sball be respoMU,le for
.
any and all cosu incurre4 to enforc:e the Aqreement, inclucUncJ,
but not liaiteel to, court costs anel counsel fe.. of the other
party. In the event of breach, the otller party .l:1al.l have the
right. at his or her elec:t:ion, to sue tor ~q.. for such breach
or to seek such other and additional reaec1i.. as _y be available
to hila or her.
IN WJ:TNESS WHEREOF, the partie. hereto have .et their h......
anel seals the elay and hear first above written:
WITNESS:
~~A J1. !7;//hU
I~? JI' vI .
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//J~~ ,L~
DEBRA~. 8EAR
rof. q t).['1f/'\
JO A, BEAR
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COMMONWEALTH or PENNSYLVANIA ) .
/1 ) SS
couN'ry or c..:u.JnfJE"/2L/fNO )
On this the /lJfp c1ay ot \S..L,O~kv
, 1996, tie tore
_, the urtdersiCJllec1 otficer, personally appearec1 Del:Ira K. Bear,
known to _ (or sati.tactorily proven) to tie the person wose
name is su1:lscrUlec1 to the within Aqreement ancl acJcnovledqec1 that
she executec1 the .... tor the purposes therein containec1.
III wrrNESS W1"'D!Or, I hereunto .et -.y hancl aDd official
seal. .
. /'
,~~A /l /lZ,;y;'A';'"
t
COIIIIOlC1IZAUrB or PEKHSYLVMU
NOlana' Saal -
Leah A. Millar. Notary Publlo
Ca~Is'a Boro. Cumbe~and Coumy .
My CommiUlon e'prras Aori117. 2000
,\
)
~..U orCUrtlIJE.R Uf tII () J SS
.~ this the /jfli /Say ot /t&tL<t:
I ~. J
_. the unc1ersiCJllec1 otticer, personally appearec1
, 1996, l)etoA
John A.
Bear,
known to .. (or satistactorily proven) to tie the person vho8e
Mae is su!:lacribecl to the within Aqr_ent anci acJcnowledqec1 that
he executec1 the Salle tor the purpo... tI1erein containec1.
IN WITNESS WHl!:REOP, I hereunto set Sf hancl ancl otticial
aeal,
;/.uJ, /I
.
/?/d../r A
Notarial Seal
Laah A. Millar. Notary Public
Carllsla Bora. Cumb81lar~ CountY
My Commission Expo,., Apnl'7. 2000
.
....... L. a-..
........ A. C.tl.-.,
",.. M. s--
Rc-. J. Goeo-.
o..a~
( .' (
\:dUFFlE & ASSOcIATES
ATTORNEYS AND CCUfl'l&l 0AlI AT LAW
2lllI......~s_
c-... PA 170t3
(1t71 ZG-5II5t
I (lOa) 347.SUZ
FAX 717.~:J.~
December 17, 1996
c". ...T_a.-
s..r. SS1, t6...... MMo s_
o.. ..... PA 17Z0t
(1t71 217-1_
AIP\.., ta: c.w.u
John A. Bear
532 Pine Road
CA1'H..le, PA 17013
RE: Breach of Property Settlement Agreement
Dear Mr. Bear:
This is bring to your attention that you have not made payments QJ1
the loan that you had agreed to make payments on in the Property
Settlement Agreement. Furthermore, you had agreed to pay one-half of the
costs of the divorce. These are paragraph five and six of the Property
Settlement Agreement that you signed on August 13, 1996.
Please note that paragraph 12 indicates that in the event of a breach
you will be responsible for any and all costs incurred to enforce the
agreement including but not limited to court costs and counsel fees of the
other party. Your former wife has the legal right to take you to court to seek
enforcement of this Property Settlement Agreement. You may wish to
consider whether it is in fact worth your while to make the payments as you
had agreed rather than make them with the additions of court costs and
attomey's fees and possibly wage attachment should your wife choose to seek
to enforce this agreement as she has informed me that she intends to do.
Very truly yours,
GRUfl"U; & ASSOCL~TES
Anne M. Shepard
AMSIlam
cc: Debra Bear
EXHIBIT "B"
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ANO NOW. ...
DECREE IN
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. . . . . . . . . . . . . . . )5., 19. .9.6. . " it is ordered and
decreed that .. .~I; . .Ih.~. . '" " .. .. .. . . .. . . . . .. .... . '" . " plaintiff.
and ...... John. A.. Bear. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . " 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;
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DEBRA K. BEAR,
plaintift
IN THE COURT OF COMMON PLEAS OF
CUHBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
95-6784
IN DIVORCE
vs.
JOHN A. BEAR,
Detend.ant
n.Jl%'l'AL 8Z1."l'T.1P.V1nI'P AGU~.T
This Aqr.ement maa. this JtlflJ day ot '(,~L(/u, 1996,
by and between Debra K. Bear ot lB09 Pine Road, Newville,
Pennsylvania, hereinatter reterred. to as WIFI, and. John A. Bear,
ot 532 Pine Road., Carlisle, Pennsylvania, bereinatter reterred. to
as KlJ8BUD,
1n'l'1lJ!lSSztl'JI:
WH!:REAS, the parties bereto are busband and. wit'!, havinq
been 10ined in IIllrriaqe on Auqust 5, 1993, in ClDlberland. County,
pennsylvania: and.
WH!:REAS, a Complaint in Divorce has been tiled in the Court
ot Co_on Pleas ot cumberland County, Pennsylvania, to No. 95-
67B4 Civil Term: and
WHEREAS, the parties hereto are d.esirous ot settling tully
and. finally their respective tinancial and property riqhts and.
obligations as between each other, includ.inq, without limitation,
tbe settlinq ot all matters between them relatinq to the
ownership ot personal property, and. in qeneral, the settlinq ot
any and all claims and. possible claims against the other or
aqainst their respective estates.
NOW THEREFORE, in consideration ot these consid.erations, and.
the mutual promises and. undertakinqll hereinatter set forth, and.
tor other qood. and valuable consideration, receipt and.
sufficiency of which is hereby acknowledged by each of the
parties hereto, Husband and Wire, each intending to be legally
bound, hereby covenant and agree as follows:
1. Advice of Coua.e1: The parties hereto acknowledge that
each have been notiried of his or her right to consult with
counsel of his or her choice, and have been provided a copy of
this agre_ent with which to consult with counsel. Wife is
represented by Anne M. Shepard, Esquire. Each party acknowledges
and accepts that this agre_ent is, in the cirCWIIStances, fair
and equitable, and that it is being entered into freely and
voluntarily, after having received such advice and with such
knovledqe as each has souqht from counsel, and that executicn of
this aqreemant i. not the re.ult of any durass or undue
influence, and that it is not the result of any .i:IIIproper or
i11eqa1 agre_ent or agre_ents.
2. Divorce: The parties agree to the entry of a Decree in
Divorce. On or about , 1996, the parties will execute
Affidavits of Consent under Section JJ01(C) of the Domestic
Relations Code, consentinq to the entry of a Decree in Divorce.
J. Personal Property: The parties have agreed to divide
their personal property to their mutual satisfaction. The wife
shall own on her own behalf and independently of any cla.i:lll of
riqhts of the Husband all it8lllS of personal property of every
kind, nature and description and however situated which are in
her possession or which lIUly hereafter belonq to the Wife with
full power to the Wife to dispose of the same as fully and
effectively, as if she were not married. The Husband shall own
on his own behalt and independently ot any claim ot rights ot the
Wite all itelllS ot personal property ot every kind, nature and
description and however situated which are in his possession or
which hereinatter belong to the Husband, with tull power to the
husband to dispose ot the same as tully and ettectively, as it he
were not married.
4. Mutual property an4 .seaee waiver: Except as otherwise
expressly set torth herein, in which event such express provision
shall take precedence over this paragraph, the partie. hereto
intend that trom and atter the date ot this Agreement, neither
shall have any spouse's rights in the property or estate ot the
other, and to that end both parties waive, relinquish, and
forbear the rights ot dower or curtesy, rights to inherit, rights
to cla1lll or take the Husband or Wite'. or tamily 8X8lIIption or
allowance to be vested with letters ot administration or letters
testamentary, or to take against any will ot the other, and each
agrees with the other it either should die intestate, his or her
share shall descend to vest in his or her heirs at law, personal
representatives, and next ot kin, excluding the other as thouqb
he or she had died a widow or widower. And each turther agrees
that should the other die testate, his or her property shall
descend to and vest in those persons set forth in the other's
Last will and Testament as though the spouse so desiqnated as
beneticiary had predecea.ed the testator. The partie. turther
agree that they _y and can hereatter, as though U%lIII&rried,
without any joinder by h1lll or her, sell, convey, transfer or
enCUlllber any and all real estate and personal property which
.ith.r ot them now or hereatter own or po..... and turther aqree
that the recordinq ot this Aqreement shall be conclusiv. .vid.nce
to allot his or her riqht to do .0. The .aid Husband and Wite
do hereby irrevocably qrant, each to the other, should the
exercise ot this power hereby qiven be necessary, the riqht and
the power to appoint one or more times any person or persons whom
the husband or Wite shall desiqnate to be the attorney-in-tact
tor the other, in their name and in their stead, to execute and
acknowledqe any d..d or deeds, relea.es, quitclaims, or
satistactions, under seal or otherwise, to ena))le either party
hereto to alienate his or her real or personal property, but
without any power to apose personal lia))ility tor breach ot
warranty or otherwise. Each ot the partie. hereto turther waives
any riqht ot election contained in Chapter 22 ot the Pennsylvania
Probate Estates and Fiduciaries Code, and any riqht to seek or
have an equita))le distribution ot married property ordered by the
Court subsequent to Section 3502 ot the Domestic Relations Code.
Each ot the parties hereto further aqrees that neither .hall
hereatter be under any leqal obliqation. to support the other,
'..
pay any expenses tor maintenances, tuneral, burial, or otherwise
tor the other, and to that end each ot the parties hereto does
hereby waive any riqht to receive support, alimony, alimony
pendante lite, counsel fee., expenses. or any type of tinancial
assistance "ha-csoever trom the other, except as otherwise
expres.ly provided tor herein.
5. Kari tal Dellt: The parties have two loans through PNC
Bank in both parti..' names, Account '4001 008 003 052 715 and
Account '4002 008 000 698 436. Husband aqr..s to b. r.sponsibl.
tor paym.nt ot said accounts and will indemnity and hold the wit.
harml..s tor said debt. Each party will be responsible tor the
dellt on the credit card accounts in his or her name. Each party
will incur no debt tor which the other may be liable, and will
indemnity and hold the other harmless tor any debt so incurred.
6. Husband and Wite aqr.. to each pay one-halt ot the total
cost ot Obtaining the divorce, including couns.l fees.
7. Xodification: No moditication, rescission, or amendment
ot this aqr....nt shall be .tt.ctive unle.. in writing .iqned by
.ach ot the parties hereto.
8. :t.pplicaJ:ll. Law: All acts cont.-plated by this aqreeaent
shall b. construed and entorced under the laws ot the
CODIIDonw.alth of Pennsylvania.
9. :agr....nt Binding on Parti.. and )I.in: This aqre8lllent,
except as otherwise expressly provided herein, shall bind the
part i.. her.to, and th.ir resp.ctiv. h.irs, executors,
administrators, legal representatives, assigns and successors in
any interest ot the parties.
10. Agre_ent )fot to be X.rqed This agreement shall be
incorporated into the tinal decree ot divorce of the parties
hereto tor purposes ot entorc8lllent only, but otherwise shall not
be merqed into said decree. The parties shall have the riqht to
entorce this aqre8lllent under the Domestic Relations Code and in
adcUtion, shall retain any remedies in law or in equity under
this aqreement as an independent contract. Such remedies in law
or equity are specitically not waived or released.
11. Doc:uaeDts:
The parties hereto aqre. that they will
execute and deliver one to the other any documents necessary to
qive .tfect to the terms ot this Aqreement.
12. Br.ach: In the .vent that either party breach_ any
provision ot this Aqr_ent, he or she sbal.l be responsi})le tor
any and all costs incurred to entorce the Aqreement, includi.Dg,
but not limited to, court co.ts and counsel tee. of the other
party. In the event ot breach, the other party shall have the
riCJht, at tUs or her election, to sue tor daJlaq_ for such breach
or to aeek .uch other and additional r_edies a. ..y ~ availa!)le
to hb or her.
IN WITNESS WHEREOF, the parties hereto have set their han4s
and seals the day and hear tirst above written:
WI'l'NESS:
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COMMONWEALTH OF PENNSYLVANIA )
COt1N'l'Y OF fA.ijn{jF~L/lNO l SS
On this the /~+jJ day of \f'#~
, 1996, before
.e, the under.iqned officer, per.onally appeared Debra It. Bear,
known to .e (or .atisfactorily proven) to be the per.on who.e
n... i. .ub.cribed to the within A9z:'eeaent and acknowledqed that
she executed the .... for the purpos.s th.r.in contained.
IN wrrNESS WHEREOF, I bereunto .et my band and official
seal.
~.., A ~ /J2. L~~/'f .;
COIDIOKWEAL'.rB 01" PElINSYLVAHIA
c:ommc opCunU!Ee I.A It! tJ
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Nota"al S"I -
IIlh A. Millar. Notary Publle
Carl,S11 Baro. Cumba"and County
My Comm.ssion eXpires Aori117. 2000 .
, "
55
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on this the j..) I II day of rf',/J/ ~(SC
./
the undersiqned officer, personally appeared John A.
Bear ,
, 1996. befon
known to .e (or satisfactorily proven) to be the per.on WOlle
naJM is subscribed to the within Aqr...ent and acknowledqed that
be uecuted the .... for the purpo._ therein contained.
IN wrrNES5 WHEREOF, I hereunto .et ray band and official
s.al.
J,,'J_ ,I 1/ .
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Notonal S..I
Loah A. Mille.. Nala,\, Public
Carbsle Bore. CLJmtHIuDr"r County
My Commission E~pire5 April' '7 2000
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CEBRA K. BEAR,
Plaintiff
nr 'rB!: CCCRr or C:CIlHOK l't.ZU OJ'
: CUIl'berland CCtnrrY, P!:HHstr.V>>In
.
.
.
.
.
vs.
JOHN A. BEAR,
Defendant
N'''. 95-6784
\;,I, V..w 1.995
.
.
.
.
.
.
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.
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~oz:II&1:.1C111r t:o t:he c:aa:t ~or ent:y o~ _ 1!J.vc:ce ~:
1.. G:01m4 ~or 41vcn:ce: L.....~lna!11. =.-~'lnm ......._~
Sa-:tioa 33Q1(C) ~ o~ the Di'il-._ Coda.
wppUcabI. MCt:1on.,
2. Date am! 1IIanner o~ service o~ the COlIIplain~: bv certified
~i'. rp-~~ri~P-d dAliverv on December 6. 1995
(~Q aut:
.
3. eCClllplet. either paraqraph (a) ar (b).)
e-, Data a~ ex~an a~ the a.l~iclavi~ o~ CClasent
requ1recl bY' Sectioll 3301ec} a~ the Divarce CQcle: bY' the
PI.ain1:i~~: September 10, 1996 : by Cef.1:I"'''~ August 28, 1996 .
(b) (l) Dat:e of execut:ion of the Pla.intif~'s affidavit:
J:eqa.in4 by Sec1:1an 3301(4) af th. Civaz:ee c:cde: N/A
.
(2) Data a~ seJ:Vice of the Plaintiff's a!fictavit:
apan the C~endan~:
N/A
.
4. Rela.t:ed clai.:us pencUnq: Mr.""
5. Inc1icate elate and manner of service a~ the notice of
intention t:cI ~Ue praecipe to t.ransm.i.t: recctM, am! attach a copy
of sai4 nat:ice under Section 3301.ec!) el) () af the Divo:c:a Code.
N/A
. ,Anne M. Shepard,
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DEBRA K. BEAR, I IN THE COURT OF COMMON PLEAS OF
Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
v. I CIVIL ACTION - LAW
.
.
JOHN A. BEAR, I 95-~'lr~IVIL TERM
Defendant . IN DIV RCE
.
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 will
proceed without you and a decree in divorce or annulment may 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.
Court Administrator
Fourth Floor
CUmberland County Courthouse
Carlisle, Pennsylvania 17013
(717) 240-6200
indignities
or
When the ground for the divorce is
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 Courthouse,
Carlisle, Pennsylvania 17013.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF MARITAL
PROPERTY, LAWYER'S FEES, OR EXPENSES BEFORE A DIVORCE 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.
,
DEBRA K. BEAR, I IN THE COURT OF COMMON PLEAS OF
Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA
I
vs. . CIVIL ACTION - LAW
.
I NO.
JOHN A. BEAR, .
.
Defendant . IN DIVORCE
.
COIIPLaIII'1' IB DIVORCB
1. Plaintiff is Debra K. Bear, an adult individual
currently residing at 1809 Pine Road, Newville, CUmberland
County, Pennsylvania.
2. Defendant is John A. Bear, an adult individual currently
residing at 532 Pine Road, Carlisle, CUmberland County,
pennsylvania.
3. Plaintiff and Defendant are bona fide residents of the
Commonwealth of Pennsylvania and have been so for at least six
months immediately previous to the filing of this complaint.
4. Plaintiff and Defendant were married on August 5, 1993
in Carlisle, Pennsylvania.
5. There have been no prior actions for divorce or
annulment between the parties.
6. The Defendant is not a member of the United states Armed
Forces or its Allies.
7. Plaintiff has been advised of the availability of
counseling and the right to request that the Court requires the
parties to participate in counseling. Knowing this, Plaintiff
does not desire that the Court require the parties to participate
in coun..1inq.
1
.,
r
8. Plaintiff and Defendant are citizens of the United
states of America.
9. The parties' marriage is irretrievably broken.
10. Plaintiff desires a divorce based upon the fact that
Defendant has offered such indignities to the person of the
plaintiff, the innocent and injured spouse, as to render her
condition intolerable and life burdensome and this action is not
collusive.
WHEREFORE, plaintiff requests your Honorable Court to enter
a decree in divorce pursuant to Section 3301(a) (6) and 3301(C) of
the Divorce Code of 1980, as amended.
Respectfully submitted,
GRIFFIE , ASSOCIATES
2
nRt.!CA'J.I!OM
.
I verify that the statements made in the foregoing Complaint
are true and correct. I understand that false statements herein
made are subject to the penalties of 18 PA.C.S. Section 4904
relating to unsworn falsification to authorities.
DATE: 1/-;:;'8-f.r
P26~.. /:-' {jr;A.-
Debra K. Bear
DEBRA K. BEAR,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
plaintiff
vs.
JOHN A. BEAR,
95-6784
IN DIVORCE
Defendant
AFPIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on November 30, 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 of Divorce
after service of notice of intention to request entry of the
; .
decrees.
,
I VERIFY THAT THE ST~TEMENTS MADE IN THE FOREGOING 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:
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UFIDAVIT OF CONS.II'!'
1. A Complaint in Divorce under Section 3301(c) of the
Divorce Code was filed on November 29, 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 of Divorce
after service of notice of intention to request entry of the
I VERIFY THAT THE STATEMENTS MADE IN THE FOREGOING 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.
~t....1:~
Plaintiff
DATE: 9-10- C}d7
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DEBRA K. BEAR,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
vs.
JOHN A. BEAR,
Defendant
95-6784
IN DIVORCE
WAIVER OF NOTICE OF INTBNTION TO REOUEST
ENTRY OF A DIVORCE DECREE
UNDER SECTION 3301lCl OP THE DIVORCE CODE
1. I consent to the entry of a final decree in divorce
without notice.
2. 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.
3. 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.
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.
OATE: rf~C
JOH EAR,
Oef dant
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DEBRA K. BEAR,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
95-6784
vs.
JOHN A. BEAR,
Defendant
IN DIVORCE
WAIVER OP NOTICB OP INTBII'1'ION TO RBOUBST
BII'1'RY OP A DIVORCB DI!ICRBB
UNDI!IR SI!ICTION 3301'Cl OP TH1! DIVORCI!I CODI!I
1. I consent to the entry of a final decree in divorce
without notice.
2. 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.
3. 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.
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.
DATE: 9../0 -9~
~A-~
K. BEAR,
Plaintiff
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DEBRA K. BEAR, I IN THE COURT OF COMMON PLEAS or
plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA
.
I
VB. . CIVIL ACTION - LAW
.
.
.
JOHN A. BEAR, . 95-6784 CIVIL TERM
.
Defendant . IN DIVORCE
.
AFPIDAVIT O. SIRVICI
AND NOW, this 18th day of December 1995, comes Anne H.
Shepard, Esquire, Attorney for Plaintiff, Debra K. Bear, and
states
that she personally mailed a copy of a Complaint in
Divorce to
Pine Road,
the Defendant at 532
carlisle,
Pennsylvania, by certified mail, restricted delivery, return
receipt requested.
A copy of said receipt is attached hereto
indicating service was made on December 6, 1995.
Shep rd, squ
GRIFFIE , ASSOCI TES
200 North Hanover street
Carlisle, Pennsylvania 71013
(717) 243-5551
Sworn and subscribed
to this /J7~ day
of December, 1995.
~ju~ a,4'-' i ftTAt
NOTARY ~B IC
Nola~al Seal
Robin J. Goshom, Notary Public
Carllsla BolO, Cumberland County
My Commission ExplraaAp~ll1, 1999
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DEBRA K, BEAR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION. LAW
95-6784 CIVIL TERM
V.
JOHN A. BEAR,
Defendant
~
~
AND NOW, February 20, 1997, the parties having appeared for hearing,
Debra K. Bear, represented by private counsel, Anne M. Shepard, Esquire, and
John A. Bear appearing pro se, upon agreement of the parties It Is ordered and
directed that:
A. John A. Bear shall pay $384.25 to Debra K. Bear for the costs and legal
expenses of their divorce. Said payment shall be made to Griffie & AS80clates
Law Firm and In the following manner:
$150.00 paid on February 21, 1997
$234.25 paid on March 7, 1997.
B. That he shall pay $233.94 cents per month to PNC Bank until the
payments are brought current. Thereafter, he shall pay $116.97 per month until
the loan Is paid in full.
C. That he shall pay to Debra Bear $240.00, the cost of preparing and filing
said petition for contempt. Said payment shall be made In full to Griffie &
Associates Law Firm no later than May 21,1997.
Anne M. Shepard. Esquire
For the Plaintiff
By the Court,
J.
John A. Bear, pro se
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PENNSYLW..NlA
DEBRA K. BEAR.
Plaintiff
IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
vs.
JOHN A. BEAR,
Defendant
CIVIL ACTION. LAW
NO, 6784. CIVIL i9%'
IN DIVORCE Iqqs
NOTICE OF ELECTION TO RETAKE FORMER NAME
Notice is hereby given that the Plaintiff in the above maller, having been granted a
Final Decree in divorce from the bonds of matrimony on the 25111 day of September, 1996,
hereby elects to retake and hereafter use her previous name of Debra K. Caufman,
a-k~-
Debra K. Bear
aJ~- ~ e.~~w-
Debra K. Caufman
COMMONWEALTH OF PENNSYLVANIA:
SS,
COUNTY OF CUMBERLAND
On the J PM day of , 1997, before me, a Notary Public,
personally appeared Debra K. Bear, known 0 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 hercunto sct my hand and Notarial Seal.
~ Ii h J! '17/ Lt~A~___,.
Notary Public'
NOlarial So.1
Leah A. Millar, Notary PubliC
C.~iale Boro, CumbOfland County
My Commission E.plrea Apm 17.2000
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