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OF CUMBERLAND COUNTY
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DECREE IN
DIVORCE
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AND NOW,........... .Af'.~.(.. .~.7::, 19.94..., it is ordered and
decreed that . .~!t.M~. iI... .1:lf.JJ.V~!J!i..........................., plaintiff,
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are divorced from the bonds of matrimony,
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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;
Marital Settlement Agreement dated April 4 . 1994 is hereby incorporated
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into the Final Divorce Decree.
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MARITAL SETTLEMENT AGREEMENT
THIS AGREEMENT, made this ~daY of ~, 1994, by and
between BRAAM J. HATTINGH, of Cumberland County, Pennsylvania (herein after
referred to as "Husband"), and VIVIAN Y. HATTINGH, of Cumberland County,
Pennsylvania (hereinafter referred to as "Wife").
WITNESSETH:
WHEREAS, Husband and Wife were lawfully married on May 26, 1989; and
WHEREAS, no children have been born of this marriage; and
WHEREAS. differences have arisen between Husband and Wife in consequence
of which they have been separate and apart from each other; and
WHEREAS. Husband and Wife desire to settle and determine their rights
and obligations; and
WHEREAS, the parties have each made to the other a full and complete
disclosure of all of their respective assets of whatever nature and wherever
situate. which disclosures are hereby acknowledged by each party hereto; and
WHEREAS, both parties herein agree to relinquish any and all claims which
either may have against any property now owned or belonging to the other or
which may hereafter be acquired by either of them by purchase, gift, devise,
bequest, Inheritance and otherwise except as to the obligations, covenants
and agreements contained herein; and
WHEREAS. the parties hereby have each been advised of the benefit and
advisability of independent legal advice by separate legal counsel for
purposes of review and execution of this Agreement.
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NOW. THEREFORE. the parties Intending to be legally bound hereby. do
covenant and agree:
SEPARATION
It Is acknowledged hereto that the parties hereto have been living
separate and apart since December 31. 1993. and further acknowledge that It
shall be lawful for each party at all times siRce separation and hereafter
to live separate and apart from the other party at such place as he or she
may from time to time choose or deem fit. The foregoing provisions shall
not be taken as an admission on the part of either party of the lawfulness
or uRlawfulness of the causes leading to their living apart.
INTERFERENCE
Each party shall be free from interference. authority. and contact
by the other. as fully as If he or she were single and unmarried except as
may be necessary to carry out the provisions of the Agreement. Neither
party shall molest the other or attempt to endeavor to molest the other.
nor compel the other to cohabit with the other. or In any way harass or
malign the other. nor In aRY way Interfere with the peaceful existence.
separate and apart from the other.
-2-
INCOME TAX CONSEQUENCES AND RETURNS
By t:lls Agreement, the parties have Intended to effectuate and by this
Agreement have equally divided their marital property. The parties have
determined that such equal division conforms to a right and just standard
with regard to the rights of each party. The division of existing marital
property has not, except as may be otherwise expressly provided herein, been
Intended by the parties to constitute In any way a sale or exchange of assets
and the division Is being effected without the Introduction of outside funds
or other property not constituting a part of the marital estate. As part of
the equal division of the marital properties and the marital settlement
herein contained, the parties hereby agree to save and hold each other
harmless from all income taxes assessed against the other resulting from the
division of property as herein provided.
Husband and Wife do hereby specifically agree and elect to apply the
provisions of the 1984 Domestic Relations Tax Reform Act with respect to
the creation of a taxable event. Husband and Wife specifically agree that
none of the provisions of the within Agreement shall constitute a taxable
event as set forth In the 1984 Domestic Relations Tax Reform Act.
Parties hereto have filed, and will file, joint Federal, State and Local
Income tax returns through tax year 1993. Parties hereto further agree to
file separate tax returns for 1994 and all subsequent tax years.
-3-
MUTUAL RELEASE
Subject to the provisions of this Agreement, each party has released
and discharged, and by this Agreement does for himself and herself, and
his or her heirs, legal representatives, executors, administrators and
assigns, release and discharge the other of and from all causes of action,
claims, rights or demaRds, whatsoever in law or equity, which either of the
parties ever had or now has against the other, except any and all cause
or causes of action for divorce and except any and all causes of action for
breach of any provisions of this Agreement.
DEBTS
Husband and Wife herein represent and warrant to each other that as of
December 31, 1993, neither one has contracted any debt or debts, charges or
liabilities whatsoever, for which the other party or their property or
their estates shall or may become liable or become answerable, and they
covenant that they will at all times keep each other free, harmless and
indemnified against and from any and all debts and liabilities heretofore
or hereafter contracted or incurred by either of them, except as
expressly provided In this Agreement.
Husband herein further agrees to accept full responsibility for any
and all outstanding debts incurred up to, and including, December 31, 1993,
including PNB and Fulton Bank loans.
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REAL ESTATE
The parties hereto agree that Wife shall relinquish to Husband all of
her respective legal and equitable title and Interest whatsoever in real
estate currently titled in his name, located at 551 Meggan Lane, MechaRlcs-
burg, Cumberland County, Pennsylvania; Wife further agrees to execute a fee
simple Deed at the signing of the herein Agreement conveying all legal and
equitable Interest therein.
Husband Is to assume full responsibility for the existing PNC (formerly
CCNB) credit line, collateral mortgage obligation thereon, and shall
Indemnify and hold harmless Wife from any future liability pertaining thereto.
Husband to pay to Wife the cash sum of EIGHTEEN THOUSAND ($18,000.00)
DOLLARS at the complete execution of Agreement, In full and final settlement
of any and all equitable and/or legal interest Wife may claim against the
real estate.
DIVISION OF PERSONAL PROPERTY
The parties have divided between them to their mutual satlsfactioR the
personal effects, household furniture and furnishings, vehicles, and all
other articles of personal property which have heretofore been used by them
In common, and neither party will make any claim to any such Items which
are now In the possession or under the control of the other. Should It
become necessary, the parties each agree to sign any titles or documents
necessary to give effect to this paragraph upon request.
Wife shall retain the 1988 Suzuki Samurai currently titled In
Husband's name and mountain bike. Husband shall retain his 1972 Yamaha
Motorcycle, 1990 Suzuki 1100 GSXR Motorcycle, 1967 Ford Mustang, 1983
Ford Ranger, and Watercraft jet skis, and assume any and all obligations
related thereto, and garden equipment, Including chain saw and all tools.
Wife to retain household effects, Including 20" T.V., Stereo, kitchenware,
mattress, wicker furniture, phone, white writing desk, all plants and ski
equipment.
Husband to assume custody of, and responsibility for, pet dogs,
Alexis and Hannah, English Bull Terriers.
Wife to assume custody of, and responsibility for, pet cat, "Khea",
when she Is able.
Both parties to retain all benefits of their respective employment
not Inconsistent with other paragraphs herein, more specifically, all medical
and/or life Insurance benefits. Parties hereto acknowledge that neither has
any existing pension or retirement benefits, through his or her respective
employment.
SPOUSAL SUPPORT, ALIMONY PENDENTE LITE AND ALIMONY
The parties hereto mutually release each other from any and all claims
they may have against the other party for any and all obligations for
payment to the other party for spousal support, alimony pendente lite and
al imony.
-6-
COUNSEL FEES AND COSTS
Husband and Wife hereby agree that each shall pay his or her own respec-
tive counsel fees and costs, with the exception of filing costs. which have been
paid by Husband.
WAIVERS OF CLAIMS AGAINST ESTATES
Except as herein otherwise provided, each party may dispose of his or her
property In any way. and each party hereby waives and relinquishes any and all
rights he or she may now have or hereafter acquire, under the present or
future laws of any jurisdiction, to share In the proeprty or the estate of
the other as a result of the marital relationship. including without limita-
tion, dower, curtesy, statutory allowance, widow's allowance, right to take
In Intestacy, right to take against the Will of the other, and right to
act as administrator or executor of the other's estate. and each will, at
the request of the other. execute. acknowledge. and deliver any and all
Instruments which may be necessary or advisable to carry Into effect this
mutual waiver and relinquishment of all such Interests, rights and claims.
DIVORCE
Husband and Wife hereby agree that Husband shall move promptly to finalize
the pending divorce action In the Court of Common Pleas of Cumberland County.
No. 176 1994. and both parties agree to execute 3301(c) Affidavits of Consent
-7-
simultaneously hereto to effectuate obtaining the final decree in
divorce after the required Ninety (90) day waiting period.
BREACH
If either party breaches any provision of this Agreement, the other
party shall have the right, at his or her election, to sue for damages for such
breach, and the party breaching this contract should be responsible for
payment of legal fees and costs incurred by the other in enforcing their
respective rights under this Agreement or seek such other remedies or
relief as may be available to him or her.
ADDITIONAL INSTRUMENTS
Each of the parties shall, from time to time, at the request of the
other, execute, acknowledge, and deliver to the other party any and all
further instruments that may be reasonably required to give full force and
effect to the provisions of this Agreement.
ADVICE OF COUNSEL
Husband has been represented by John S. Picconi, Esquire. Wife has been
represented by JAN M. WILEY, Esquire. The provisions of this Agreement and
their legal effect have been fully explained to the parties by their respec-
tive counsel, John S. Picconi, Esquire for Husband, and Jan M. Wiley, Esquire,
for Wife. The parties acknowledge that each has received independent legal
-8-
advice from counsel of their respective selection and that they have
been fully Informed as to their legal rights and obligations, Including
all rights available to them under the Pennsylvania Divorce Code of 1980,
as amended, and other applicable laws. Each party confirms that he or she
fully understands the terms, conditions and provisions of this Agreement
and believes them to be fair, just, adequate and reasonable under the exist-
Ing circumstances. The parties further confirm that each Is entering into
this Agreement freely and voluntarily and that the execution of this
Agreement Is not the result of any duress, undue influence, collusion or
improper or illegal agreement or agreements.
VOLUNTARY EXECUTION AND ADDITIONAL GENERAL TERMS
Each party acknowledges and accepts that this Agreement, under the
circumstances, is fair and equitable, and that It is being entered Into
freely and vol~ntarily, and that execution of this Agreement Is not the
result of any duress or undue Influence and that it is not the result of
any collusion or improper or illegal agreement or agreements. Each
party hereto warrants that the Agreement provisions effected are the result
of complete and full disclosure of all respective assets to each other and
to John S. Plcconi, Esquire and Jan M. Wiley, Esquire, respectively.
Each of the parties are aware of the financial resources of the other
and each of them understands the nature and effect of this Agreement and believe
it to be fair and reasonable; and the parties have incorporated herein their
entire understanding and that no oral statements or prior written matter
intrinsic to this Agreement shall have any force and effect.
-9-
A modification or waiver of any of the provisions of this Agreement
shall be effective only If made In writing and executed with the same
formality as this Agreement. The failure of either party to insist upon
strict performance of any of the provisions of this Agreement shall not
be construed as a waiver of any subsequent default of the same or similar
nature.
The descriptive headings used herein are for convenience only. They
shall have no effect whatsoever In determining the rights or obligations
of the parties.
It Is specifically understood and agreed by and between the parties
hereto that each paragraph hereof shall be deemed to be a separate and
Independent covenant and agreement.
This Agreement shall be construed under the laws of the Commonwealth
of Pennsylvania.
If any term, condition, clause or provision of this Agreement shall
be determined or declared to be void or Invalid In law or otherwise, then
only that term, condition, clause or provision shall be stricken from this
Agreement and In all other respects this Agreement shall be valid and then
continue In full force, effect and operation.
Except as otherwise stated herein, all the provisions of this Agreement
shall be binding upon the respective heirs, next of kin, executors or
administrators of the parties.
-10-
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Commonwealth of Pennsylvania)
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County of Dauphin )
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On this, the ~ day of ~11l~ ,1994, before me, a Notary
Public for the Commonwealth of penntYlvanla, residing in the County of Dauphin,
personally appeared BRAAM J. HATTINGH, known to me to be the person whose
name is subscribed to the within Agreement and acknowledged that he executed
the same for the purposes therein contained.
IN WITNESS WHEREOF, I have hereunto set my han and off. cial seal.
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Commonwealth of Pennsylvania)
) ss:
County of Dauph in)
On this, the ~ day of Q.'~vl ,1994, before me, a Notary
Public for the Commonwealth of Penns vanIa, residing In the County of
Dauphin, personally appeared VIVIAN Y. HATTINGH. known to me to be the person
whose name is subscribed to the within Agreement and acknowledged that she
executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I
Icial seal.
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NOTARY SEAL
MARY GAIL GEYER. Notary Public
Darry Township, Dauphin County
Wrf Commission Expires June \7, 1996
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DRMM J. HATTINGH.
IN ntE COURT OF CO+ION PLEAS OF
ClMBERLAND 'COlJtolI"Y. PENNSYLVANIA
Plaintiff
CIVIL
1994
NO. 176
vs.
VIVIAN Y. HATTINGH,
IN DIVORCE
Defendant
PRAECIPE TO TRANSMIT RECORD
To the Prothonotary:
Transmit the record. together with the following information. to the court
for entry of a divorce decree:
1. Grounds for divorce: irretrievable breakdown under Section 3301 (c)
~~>>~~ of the Divorce Code. (Strike out inapplicable section)
2. Date and manner of service of the complaint: Service effected January 22,
1994 by Certified Mall; Certificate of Service dated January 13. 1994. duly filed.
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 the plaintiff
April 14. 1994
.
.
by the defendant
Aorll 14. 1994
.
B. (1) Date of execution of the plaintiff's affidavit required by
Section 3301 (d) of the Divorce Code:
(2) Date of service of the plaintiff's affidavit upon the defendant:
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)(l)(i) of the Divorce Code
JOHN S. PICCONI. Esq..
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BRAAM J. HATTINGH,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. /7 '"
Civil 1994
vs.
CIVIL ACTION - LAW
VIVIAN Y. HATTINGH,
Defendant IN DIVORCE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the
olaims set forth in the follOWing pages, you must take prompt aotion.
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 judl!lDent may also be entered against you for any other
claim or relief requested in these papers by the Plaintiff. You lI1:lY
lose money or property or other rights important to you, including
oustody 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,
Cumberland County Courthouse, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR MmuLMENT 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 FnID OUT WHERE YOU CAN GET LEGAL HELP.
Court Administrator
Cumberland County Courthouse
Carlisle, Pennsylvania 17013
(717) 240-6200
,
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17033
BRAAM J. HATTINGH,
Plaintiff
IN 1liE COURT OF C(Xo1MON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No. 17~
Civil 1994
vs.
CIVIL ACTION - LAW
VIVIAN Y. HATTINGH,
Defendant
IN DIVORCE
COMPLAINT IN DIVORCE UNDER SECTION 3301(C)
OR SECTION 3301(D) OF 1liE DIVORCE CODE OF 1980, AS AMEllDED
AND NOW, comes the above-named Plaintiff, by his attorney, JOHN S.
PICCONI, Esquire, and seeks to obtain a Decree in Divorce from the above-
named Defendant upon the grounds hereinafter more fully set forth:
1. The Plaintiff, BRAAM J. HATTINGH, is an adult individual, sui juris,
and national of the United states of America, whose present address is
551 Meggan Lane, Mechanicsburg, Cumberland County, Pennsylvania 17055.
2. The Defendant, VIVIAN Y. ~^TTI~GH, is an adult individual, sui
Juris, and national of the Republic of South Africa, whose present address
is c/o Dawn Keith, 21 South 24th Street, Camp Hill, Cumberland County,
Pennsylvania 17011.
3. Plaintiff and Defendant have been bona fide residents in the
Commonwealth of Pennsylvania for at least six (6) months immediately
preVious to the filing of this Complaint.
4. Plaintiff and Defendant were married on or about May 26, 1969
in a District Justice ceremony in Hampden Township, Mechanicsburg,
Cumberland County, Pennsylvania.
5. Neither Plaintiff nor Defendant is a member of the Armed Services
of the United States or any of its Allies.
6. Plaintiff and Defendant have both been advised of the availability
of marital counseling and that each may have the right to request that the
Court require the parties to participate in counseling.
7. The Plaintiff avers that there has been no prior action for
divorce or annulment of the marriage filed by either party in this or
any other jurisdiction.
8. Plaintiff avers that the marriage is irretrievably broken,
pursuant to Section 3301(c) or 3301(d) of the Pennsylvania Divorce Code,
Act 26 of 1980, as amended.
(a) The parties may enter into a written Marital Property
Settlement Agreement with regard to the division of property and related
matters. In the event such an Agreement is executed by the parties, the
Agreement may be incorporated by the Court into the Final Decree of Divorce.
liHEREFORE, Plaintiff prays Your Honorable Court to enter a Decree of
JOHN S.
Attorn
Atty.
389
P.O. 252
Hershey, Pennsylvania 17033
(717) 533-6780
. .
Divorce from the bonds of matrimony.
Date: December..1L, 1993
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I verify that the statements made in this COMPLAINT 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
,
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Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLANO COUNTY, PENNSYLVANIA
No. 176 C I v II 1994
CIVIL ACTION - LAW
BRAAM J. HATTINGH,
vs.
VIVIAN Y. HATTINGH,
Defendant
IN DIVORCE
CERTIFICATE OF SERVICE
AND NOW, this 13th day of January, 1994, I, JOHN S. PICCONI, Esquire,
Attorney for PlalRtlff, hereby certify that I have this day served a true and
correct copy of a COMPLAINT IN DIVORCE UNDER SECTION 3301(C) OF THE DIVORCE
CODE by deposltln9 certified copy of same In the United States mall, first
class postage, prepaid, certified mall # P 276 444 393 at Hershey,
Pennsylvania, addressed as follows:
VIVIAN Y. HATTINGH
c/o Keith
21 South 24th Street
Camp Hili, Pennsylvania 17011
Mailing and return receipt cards attach
17033
.
P 271. 444 393
~ Receipt for
Certified Mall
'. No Insurance Covcrage Provido~
-= 00 not use for Intcmotional Mall
_....,,_t tSeo Aevuf5cl
..... ,. VIVIAN Y. HATIINGH
1"".I,I'l"
PA 17011
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t ',., ,Prtnt your name end addr,.. on the rlVlf'It of thl. to"" 10 that WI Cln feel:
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BRAAM J. HA'ITINGH,
IN THE COURT OF Cct-1MON PLEAS OF
CUMBERLAND COUNTY, PElmSYLVANIA
Plaintiff
No. 176
Civil 1994
vs.
: CIVIL ACTION - LAW
VIVIAN Y. HATTINGH,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce
Code was filed on January 13 , 1994.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety days have elapsed from the date of filing the Complaint.
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.
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: olf/ 1 If/ tJlf.
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BRAAM J. HATTINGH,
IN THE COURT OF CCM10N PLEAS OF
CUMBERLAND COUNTY, P~NSYLVANIA
Plaintiff
No.
176
Civil 1994
vs.
CIVIL ACTION - LAW
VIVIAN Y. HATTINGH,
Defendant
IN DIVORCE
AFFIDAVIT OF CONSENT
1. A Complaint in Divorce under Section 3301(c) of the Divorce
Code was filed on January 13 ,1994.
2. The marriage of Plaintiff and Defendant is irretrievably
broken and ninety days have elapsed from the date of filing the Complaint.
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.
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, '-\- ~l-iJ C\ ~
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BRAAM J. HATTINGH,
plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 176 Civil 1994
vs.
VIVIAN Y. HATTINGH,
Defendant
IN DIVORCE
AJ'I'IDAVIT 01' IH'l'EH'l'IOH TO RESUKE PRIOR HAMI
commonwealth of pennsylvania
county of Dauphin
Vivian Y. Hattingh, being duly sworn according to law, deposes
.
.
: SSe
and says that she is the defendant in the above suit in which a
final decree from the bonds of matrimony was entered and she elects
to resume her prior name of Vivian Yolanda Browne, and therefore,
gives this written notice avowing said intention, in accordance
with the provisions of the Act of April 2, 1980, P. L. 63, No. 26,
section 702, (23 P. S. 702).
j)jvoJ"ce elecree fined a~ of t;./27,jJ.~' __ '
itl~\tOl '11 i{il(~ib'
to be known as
~11A-A1~0~
Viv an Yolanda Browne
SWORN and
before me
of
subscri~.?d to
this 8 day
--r994. I!.
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commission
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