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HomeMy WebLinkAbout96-02132 ,/ i I i , , " , .--,J~ ~ r:./t 3;"7 J:> r..p~1t S ~U.H)I ,.1.... /. I , C"..,~r:/t. ...ucD CtJ C.II~TII"se ) C~u~TN~U$' S. Co,., lisle) PA 170/3 :1" 7' >>,~VJr().v Pie C,P,I4A1r 1o'1/./.4' ~ 170:48' t:. vi."''' AJJ"..,~ .."'" -rJ..,J 5t Alcw Cu""t.. I...v-! PA ~l(~ D,./V;vIS D. 1h.J./so.U , 1 eJ7~ YIP" ,II. 1I->>~l(1 :T a"" WRlnVf;, I.{,) l(€'r~Rf,ucE 7~ #AVI"u(; fiY (, _ 1'1G. s)/o-rr;u,u,l I - ;toe;. SHCJ7'(;I.I~ /.,2'2 c"" I-A,,, ~If/~) /?E-rU",ul'P ~ /Is:", 7HIS'Y wERG w eo Pt:).I..)S AIFJ.F; CoAl ,clscAr,..o .BY rll- sll~~/rr- ~ PE,DI9.RT/lE,()/ pNe "-0 ,,4 //?crl'cr/~v r,l(~.H AU.,IJ# (":',,<('/.:?t:~ S/tio",veP .B,Y y~v Ar /1Y /U(J(IJ.sr 0,1.1 .H'A)I 1,,"1. A.r d HAS BEE"v tJlI;;P. .4 Y&AI? ~/"w IMJP ..,...)1. "RPS.R 1$ FXP'RSP ;C ;'/oPF to h'AvE r#P.-<f ;:it: .,.U,R VE"P. J ->'p~,k iT ~ ~ c.i&'RJo.. (pI' r#~ c~.:.'~-r ...~$;-- /Yt?Nrll ~~p SAlE S'~/P I t \.' i y~" cev....&' /sfVS ~,V o~P.1< ~p ,RETV,I(,,() P.A..I /1)1 /AJRI7T.<1 ' ~Ec1I.P"ST AS' ~ C.4A1/vcrr A~F~,I(I? If!) P~/ FoR ~A,) t41'T"/?.AlFY 7'l:' po so <:::ON .My BEllA).."'. TII-IA/I< ,YeJQ/ V~..f.~~ ) .-.,~ , . ..' Mr2, 1~l1l1ib D. AllibOIl , 27 )lou.lolIl>r, (mmlvlllc,I'A 17028 ...........--.. (',' " , f',' .' ~"" 1(.,. , .,.......-..... ~.r... ~..- ~. "r~ ...': '1 ~ """ ,. !"'"'oo-. .:.. , " M. J'UP4E S#IE'LY CU,Al8~IfJ.AND Co C#U#I.T~4(S~ I C.u/CrNtll<lSI ~. CAItJ.IU,/ .P~ /7"13 1",111..,111"",.11.,11,1,.1,1 1",11"11".11",11,11",,,,111,1,,1 ',1 ',," '" ,.'Ii, l" " , , , evidence of abuse, as defined in the Act, by both parties, 7. Evidence was heard that for many months the Respondent has attempted to causo and has intentionally, knowingly, or recklessly caused bodily injury and serious bodily harm to the Petitioner and by physical menace has placed the Poti tioner in fear of imminent serious bodily injury. This has included but is not limited to the following specific incidents of abuse: A. On May 18, 1996, Respondent pushed Petitioner into the stairway wall causing a large gash to Petitioner's head; 8. On Decembe I' 22, 1995, Responden t ri pped the residence's three telephones f~om the wall and threw them on the floor in front of Petitioner; C. On December 21, 1995, the parties were arguing and Respondent raised his right hand into a fist and stated to Petitioner, "God, 1 just want to smash you, that you deserve to be knocked out and that would straighten you up." D. On November 14, 1995, Respondent punched Petition... in the face on two separate occasions, punched her in the back of the head, picked Petitioner up by her hair, and ripped an ea....ing from Petitioner's ear; E. On November 13, 1995, Respondent stated that Petitioner was a "slut," struck Petitioner in the back of the h.ad, and put his hand through the front door glass window; F. On numerous occasions, especially within the past -' ei ght months, Respondent has physi call y shoved Pet it i oner "out of his way;" and G. On numerous occasions, especially within the past eight months, Respondent has threatened to kill Petitioner is she "lets the tiger out of its cage." 8. Petitioner believes sne is in immediate and present danger of further abuse and harassment from Respondent and that she is in need of, and entitled to protection from such abuse, WHEREFORE, Respondent respectfully requests this Honorllble Court to Enter a final Protection from Abuse Order against Respondent, for a period of one (1) year, and further require: 1. Respondent to refrain from approaching, .busi ng, threatening, or harassing Petitioner, either physically 01' verbally, or placing her in fear of abuse, wherever he May be; 2. Respondent sha 11 not possess any hand-guns 01' othe,. firearms during the ~endency of this Order; 3. A cert i f i ed copy of th is Order sha 11 be served on the fIIew Cumberland Police Department as the police departMent with jurisdiction to enforce this Order. Should the pol ice co_ in II[ \ contact with Respondent, and should Respondent allege that he ha. not been served with this Order, the police officer sh.,ll immediately serve the Order upon him. 4. Th is Order sha 11 be enforced by any 1 aw enforcelllent agoncy In any county where d violation occurs. As provided in 23 Pa.C,S, 58113(a) of the Act, "(a)n arrest for violation of an order issued pursuant to this Act may be without warrant upon probable cause whether or not the violation is committed in the presence of the police officer." 5, Respondent is hereby notified that if he violates this Order, he IIIay be held in indirect criminal contempt which is punishsble by a fine of up to $1,000.00 and/or by a jail sentence of up to siH (8) month, The Respondent prays for such other relief as may be just and proper, Respectfully Submitted, Date: 5-?xJ '-Cj ~ 17112 , I' I ~ 3. Respondentis prohIbn-e<1 lr9M' "'ontact~~g Petitioner in any:1.. /i manner, inc~~_cUnq-entering or telephoning pe~ 0/ C ( ,...... ,..-.,- place of 'emPlOy~~nt->-__...___..__ -. 1 harassirhV L II " 4. Responden~d--'to re ra communi~tion ~petitioner's children. 5. ~~ is directed to refrain ~from ",rasSing Iy (; : i/( \ communicationJIi.itn P L1 t:loner' s relatl ve... .' 6. Respondent is directed to relinquish any hand'':'guns or I other firearms she may own or possess, and any current gun permits ""p ) she may have, to the Cumberland County Sheriff immediately upon (//-1 being served herewith. Respondent shall not possess any hand-guns or other firearms during the pendency of this Order. 7. "--~rothonotary, Sheriff, and local law enforcemen~ f agencies are dir~~~ to -~ccept;fiTe~rve all copies of thi~'t (; --- .1/-) Petition and Order without prepayment of costs. --_ 8. A certified copy of this Order shall be served on the New Cumberland Borough Police Department if said department is within the appropriate juriSdiction for Petitioner's residence. Should the police come into contact with Respondent, and should Respondent allege that she has not been served with this order, the police officer shall immediately serve the Order upon her. 9. This Order shall be enforced by any law enforcement agency in any county where a violation occurs. As provided in 23 Pa.C.S. S6113(a) of the Act, "[a]n arrest for violation of an order issued pursuant to this Act may be without warrant upon probable cause whether or not the violation is committed in the presence of the police officer." 10. Respondent is hereby notitied that it she violates this Order, she may be held in indirect criminal contempt which is punishable by a tine ot up to $1,000.00 and/or by a jail sentence ot up to six (6) months. 11. Tbis Order sbal1 r...in in full foroe and effeot until furtber Order of the Court. 12. A beariDg on tbis ..tter 18 sobeduled for tbe ~,,-tIJ day of mAY ,1"k, at ..1: ad L.a., in Court Roo. 110. ~ , CWlberland county Courtbouse, Hanover an4 ligb 8treets, Carlisle, Pennsylvania, COURT. -'......... . , J. DISTRIBUTION Petitioner Sheritt tor Respondent New Cumberland Borough Police Department Cumberland County Emergency Management -10 DUIlI. D. aLLIIOII, . III Tal COURT 0' CONNOII PLaal PetitioDer . CUJlBULAIID C01QlTY, PI...YLVUIA . v. . 110. . KICBILL. L. ALLIIOII, . CIVIL ACTIOII - LAW Re.poDcleDt I PROT.CTIOII 'ROM ABUI. PETITION FOR PROTECTION FROM ABUSE TO Tal aOIlORABLI JUDOII 0' lAID COURT. This Petition of DENNIS D. ALLISON, by and through his attorney, Nora F. Blair, Esquire, pursuant to the Protection from Abuse Act, 23 Pa. C.S. 556101, ~ ~., AA amended, respectfully represents as follows: 1. Petitioner is an adult individual who cur.rent1y resides at 504 Third street, Cumberland County, New Cumberland, PA 17070. 2. Respondent is an adult who currently resides at 504 Third Street, Cumberland County, New Cumberland, PA 17070. 3. The relationship between Petitioner and Respondent is that of Husband and Wife. 4. Petitioner's and Respondent's names are on the lease for the residence in paragraph number 1 above. 5. Petitioner and Respondent are the parents of three minor children: Joseph Allison, born June 17, 1987; Lucas Al1i.on, born June 19, 1990; Jacob Allison, born August 5, 1992. 6. Petitioner is employed at Sears with an gross weekly earnings of approximately $440.00 and net weekly earnings of approximately $300.00. 7. Respondent is unemployed. 8. Respondent has engaged in abusive conduct toward Petitioner as such conduct is defined in the Act. E~amples of said conduct include, but are not limited to, the following: a. On or about May 18, 1996, Respondent poked Petitioner in the face with the portable phone, spit in Petitioner's face, slapped Petitioner across his back with his work vest with the metal name tag attached to it causing pain and a red mark on Petitioner's back and threw a large phone at Petitioner hitting him in the groin area. b. On numerous occasions, especially during the last eight months, Respondent has hit Petitioner with her flat hand, usually slapping him in the back. c. On numerous occasions, especially during the last eight months, Respondent has punched Petitioner with her fist, especially in the arm. d. On numerous occasions, especially during the last eight months, Respondent has pushed and shoved Petitioner. e. On numerous occasions, especially during the last eight months, Respondent has thrown various household items, including picture frames and phones, at Petitioner. f. On numerous occasions, especially during the last eight months, Respondent has grabbed the telephone and other items from Petitioner and in the process, hit Petitioner with the item. g. The police have been called to the parties' residence on numerous occasions because of the violent acts of Respondent. h. There have been numerous other incidents where Respondent has treated Petitioner abusively to one degree or another. 9. Petitioner believes that he is in immediate and present danger of further abuse and harassment from Respondent, and that he is in need of, and entitled to, protection from such abuse. 10. A Custody Count was in the Divorce Complaint filed on April 25, 1996 in Cumberland County at Number 96-2132 Civil Term. A Custody Conciliation Conference is scheduled for May 30, 1996. 11. Petitioner believes that it is in the best interest and welfare of the minor children that Petitioner be granted primary physical and legal Custody until further Order of Court. OB.B.O.., pursuant to the Protection from Abuse Act, Petitioner prays your Honorable Court to: I. Immediately enter a temporary order, pursuant to Section 5(b) of the Act, 23 Pa.C.S. S6107(b); A. Directing Respondent to refrain from approaching, abusing, harassing, or threatening Petitioner, Physically or verbally, wherever he may be; B. Evicting Respondent from Petitioner's current residence located at 504 Third Street, New Cumberland, Pennsylvania and restoring such residence to the exclusive possession and control of Petitioner; e. Excluding Respondent from any residence which Petitioner may occupy during the pendency of this Order; D. prohibiting Respondent from having any contact with Petitioner, including entering or telephoning Petitioner's home or place of employment; E. Directing Respondent to refrain from all harassing communication with Petitioner's children; F. Directing Respondent to refrain from all harassing communication with Petitioner's relatives; G. Granting Petitioner temporary primary physical and legal custody of the three minor children Joseph Allison, born June 11, 1987; Lucas Allison, born June 19, 1990; and Jacob Allison, born August 5, 1992; H. prohibiting Respondent from stalking Petitioner as that term is defined in the crime Code, 18 Pa.e.s. section 2709; and I. Directing Respondent to relinquish any hand-guns or other firearms she may own or possess, and any current gun permits she may have, to the Cumberland county Sheriff immediately upon being served herewith and prohibiting Respondent from possessing any handguns or other firearms during the pendency of this Order. II. After hearing, and pursuant to section 1 of the Act, 23 Pa.C.S. 56108, enter a final protection order continuing the relief set forth above, for a period of one (1) year, and further requiring that Respondent: A. Pursuant to section 5(d) of the Act, 23 Pa.C.S. 56017(d), pay all taxable costs of this action; B. Pay Petitioner's attorneys fees in the amount of $500.00; C. Reimburse Petitioner for out-of-pocket losses suffered as a result of Respondent's abusive conduct in the amount of $ ; D. Reimburse Petitioner for earnings from employment lost as a result of Respondent's abusive conduct in the amount of $ E. Pay Petitioner $50.00 per week for the support and carli! of the three minot. children: Joseph Allison, born June 17,1987; Lucas Allison, born June 19, 1990; and Jacob Allison, born August 5, 1992; until a final Order of Support is entered by Domestic Relations; F. Peacefully retrieve any personal possessions with the aid of a local law enforcement officer, said officer to be compensated, if payment is required, by Respondent; G. Relinquish any hand-'guns or other firearms she may own or possess, and any current gun permits she may have, to the Sheriff of Cumberland county if she has not already done so and prohibiting Respondent from possessing any hand-guns or other firearms during the pendency of this order; and H. Enroll in private or publicly funded professional psychological counseling concerning anger control and Respondent's history of abusive conduct, including any substance abuse which may be involved. oat.d, 1~ ", I 'i'ir.- Respectfully submitted, --......... -) 17112-0216 "I I.,. DIINNIS D. ALLISON I IN THE COURT or COMMON PLEAS OP I CUMBERLAND COUNTY, PENNSYLVANIA V. I I MICHELLE L. ALLISON I 96-2132 CIVIL TERM I I MICHELLE L. ALLISON I IN THE COURT OF COMMON PLEAS or I CUMBERLAND COUNTY, PINNSYLVANIA I V. I DENNIS D. ALLISON 96-2132 CIVIL TERM IN REI PITITION rOR CONTEMPT ORDER or COURT AND NOW, this 26th day of June, 1996, a hearing waa aet by me today on a petition of Mr. Alliaon to hold Mra. Alliaon in contempt for an alleged violation of a protection from abua. order. The parties have resolved that iasue, and by agreement the petition for contempt ia withdrawn. The mother has removed herself from the premiaes at 504 Third Street. She agree a not to return except to r.move her peraonal belongings, and by further agreement Mr. AlliaoD ahall be present at such time aa the personal belonginga are removed. The protection from abuae orders against botb partiea will remain in full force and effeot until further order of the Court. By the Court, f " I / 'I ~ Ilarold E. Shed , P.J. Nora r. Blair, Eaquire For Dennia Alliaon -. ("~.!.i'~.~ , 'I. J .l. ,,/'1 ~ . ~ l,. ~ ..I . ,." .... 'C"' ..\ 1 ' Cara A. Boyanowaki, Esquire For Michell. Alliaon lma1 "'-\ ~.':., >- ex) r:: ..-: .. Illt" cj ; 2; rJ- G7,~ I"'.. '. ~;: " ". '\~J ?: " ro, O? 11,' ~: lrJ .., <C' ' ~) '1--;" / . J "<.4, /. 'n -:'j c;, (:.... .:) " . DIIIIII8 D. ALLI801l, I III TBI COURT O. COMMOII PLlA8 petitioner I CUllBIRLAIID COUIITY, PI...8YLVAIIIA I v. I 110. g, - 2132 CIVIL TIRN I IIICRILLI L. ALLI801l, I Re.pondent I CIVIL ACTION - DIVORCI STIPULATION FOR EXCLUSIVE POSSESSION The parties hereto having reached agreement with respect to exclusive possession hereby agree as follows: 1. Petitioner is DENNIS D. ALLISON, who resides at 504 Third Street, Cumberland County, New Cumberland, PA 17070. 2. Respondent is MICHELLE L. ALJ"ISON, who resides at 302 Hickory Hill Terrace, Dauphin County, Harrisburg, PA 17109. 3. Respondent has agreed to and has moved out of the residence at 504 Third Street, Cumberland County, New Cumberland, PA 17070. 4. Petitioner and Respondent agree that Petitioner shall have exclusive possession of the residence at 504 Third street, Cumberland county, New cumberland, PA 17070. Nora F. Blair, Esquire Dennis D. Allison Cara A. Boyanowski, Esquire Michelle L. Allison Wednesday at 9:00 a.m. until Thursday at 9:00 a.m. Father shall have the children from Thursday at 9:00 a.m, until Saturday at 9:00 a.m. The parties then shall alternate the Saturday so that each one of them has a Saturday every other week. This alternating SalUrday schadula will begin with Mother having the children on Saturday, 6 July 1996. 3. Transportation will be such that the party who is beginning their period of custody shall be responsible to pick up the children at the other party's residence. Since there are protective orders currently in force against both parties, it is understood that the party picking up the children shall not get out of his or her vehicle. The children should be ready at the time of the pick up and will walk from the residence to the parent's vehicle to begin their periods of partial custody with the children. 4. There shall be no telephone contact with the other party unless there is an emergency related strictly to the children. 5. The parties agree thaI they shall submit themselves and their minor children to Deborah Salem of Innor Works who shall porform a custody evaluation in this case. Deborah Salem is to provide both counsel with a written report as to her recommendation. In the event that the parties cannot resolve lhe ultimate custody schedule after 5. The Plaintiff's position on custody Is as follows: See attached Order, 6, The Dafandant's position on custody is as follows: Sea attached Order. 7. Need for separate counsel to represent children: None requested. 8. Need for independent psychological evaluation or counseling: See attached Order. Data: 11 July 1996 Vi · I ,I ,,' Michael L. Bangs Custody Conciliator 7 I I f I " , ','.,i \ " , 2 , .' DENNIS D. ALLISON, peU Honer IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 96-2132 MICHELLE L. ALLISON Respondent CIVIL ACTION - LAW PROTECTION FROM ABUSE RESPONDENT' S ANSWER TO PETITIONER"S PETITION FOR PROTECTION FROM ABUSE WITH NEW MATTER AND NOW, comes the Respondent, Michelle L. Allison, by and through her attorney. Cara A. Boyanowski, Esquire, and respectfully avers the following: 1 . Admi tted . 2. Mmitted. 3. Denied. It is specifically denied that the relationship of the parties is that of Husband and Wife. 4. Admi tted . 5. Admitted. 6. Admi tted. 7. Admitted. 6. Denied. It is specifically denied that Respondent has engaged in abusive conduct toward Petitioner, in which Respondent attempted to cause or caused bodily injury, rape, spousal sexual assault, placed Petitioner in fear of imminent serious bodily injury by physical menace, or inflicted Petitioner to false imprisonment, dS defined in the Act. a. Admitt~ld in pHrt and dnnl"d In pnrt. It ill allmltted that Respondent spit ill I'OUllorllll'll !'1\l!1I flnd Illllppod him with his work vest. It is dllnlod that HIlHIl<)Illh!l\l' POkllll I'nUtionol' in the face with a portable phono and t.hrl!W .1 lill'ln phono lit. Petitioner, By way of furt.her oxplanatlon, Hllllpon<lnllt. iHlrnlt.1I that shp. was holding the port.able phOllll dnd IWaIVI!d" It In tn>nl of Petitioner, however, the appliance IH1Vlll' t.mlCh..d I'lll I l lurH!r and by way of further expl.anallon, Rll~lponchmt. .ldmllH lhnl thn large phone may have hit pellUonel' In Ulll '1loln nllla, hOWI'VIlI, Hl!lIpondent denies she threw the phOll1l at l'lltlt.[onql, inlllna<l, hl! Willi grabbing for the phone and it fell. b. Admllt"d In part .lIld dllnlnd In Pdrt. It Is admitted that altercatiollH hav'l o<!<!uIIl1d III which Hlnpplnq has taken place, however, whon t.ho lIiilpplnq occutllld, t.t Wd/i aH II joint action, not solely Rellpondont.. c. AdmiUlll) In pdlt. <lJI<1 dllnlnd in part. [t is admitted that al tercat.lons h<lvl' O,;CIIl r...1 I II wh l<!h punch ing has taken place, however, wtwn Uw "unchln', ol'<!urlll(l, it. W8H ilS a Joint action, not solely Respondllnt.. d. AdmlUlld III Ihltt. .1Ild dfHlllld In part.. It is admitted that altercations h.Wl! occurp'd In, which shoving and pushing have taken p iace, hOWOVll r, whlln UIll IIhov I rIC) iHld pushing occurred, it was as a joint ac:Uon, not. Molnly Hllllpondonl.. (!. AdmlU."J I,n "illl dnd dl!nied in part. It is admitted that Respondent has lhrown various household items, however, it is speci f ically denied that Respondent has thrown these items at Petitioner. Respondent avers that these items were thrown at the floor. f. AdmJ. tted in part and denied in part. It is admi tted that Respondent has grabbed items from Petitioner, it is specifically denied that she hit him with these items. g. Admitted in part and denied in part. It is admitted that the police have been summoned to the parties' residence on numerous occasions, however, it is denied that they were summoned due to the violent acts of Respondent. By way of further explanation, Respondent has called the police herself and had her son call the police from a neighbor's house because of Petitioner's violent behavior and actions. h. Denied. It is specifically denied that Respondent has treated Petitioner abusively to one degree or another. 9. Respondent is without sufficient information or knowledge as to answer the allegation set forth in Paragraph 9. By way of further answer, Respondent does not believe that Petitioner should " "-' believe he is in immediate and present danger, in that, Plaintiff owned many guns and rifles, is an ex-police officer, and is a member of the Pennsylvania National Guard. Whereas, Respondent is approximatel y 5' 4" tall and weighs 135 pounds. 10. Admitted. 11. Denied, It Is denied lhat the best interest and welfare of the minor children would bu upheld by granting primary physical custody to Petitioner. Ry WilY of further explanation, Respondent has been tho primary Ciltl"llveJ[" of the children since birth, has been the acllve (lilHHlt eoncllrnlnq HchooL and health decisions, and has provided Uw chI ldron wllh.,food, clothing and personal items. WHEREFORE, IlmlporHhOllt rospCH:tfui Ly requests this Honorable Court to dlsmlHs tho I'ollllnn for Prolection from Abuse filed by peti t ioner. tl.ILMAIIU 12. A 'remponlry Prntllct.lon from Abuse Order is in effect against Respondent.. 13. A hear Inq hilS blH'Il Ilchedu Led for the Temporary Protection from Abuse Order for May 24/ 1996, at 2:00 p.m.. in Courtroom No. 1/ of the Cumbcdilnd County Court.house, Carlisle, Pennsylvania. 14. Petlt.lonur has ongaged in abusive conduct toward Responden t / In wh I eh Po tIt lone r has a t tempted to cause or caused bodily Injury, rap!)/ speH1Hal sexual assault. placed Petitione:r:' in fear of Immlnenl Ilf!rlollll bodily injury by physical menace, or Inflicted PetItioner to false imprisonment, as defined in the Act, by !ler{ormlnq tlw followlnq acts: a. On May 18, 1996, Petitioner pushed Respondent into the stairway wall causing a large gash to Respondent's head. b, [n November, 1995/ Petitioner punched Respondent in the face on two separate occasions, punched her in the back of the head, and then broke the front door glass window with his fist. c. On numerous occasions, especially within the past eight months, Petitioner has pushed Respondent down unto a bench, breaking the bench, and causing Respondent's head to hit a wooden bookcase. d. On numerous occasions, especially within the past eight months. Petitioner has shoved Respondent "out of his way." e. On numerous occasions, especially within the past eight month, Petitioners has threatened to kill Respondent if she "lets the tiger out of its cage." 13. Respondent believes she is in immediate and present danger of further abuse and harassment from Petitioner, and that she is in need of, and entitled to protection from such abuse. 14. Respondent feels that it is in the best interest and welfare of the minor children that Respondent be granted primary physical and legal custody. WHEREFORE. Respondent respectfully requests this Honorable Court to Enter a final Protection from Abuse Order against Petitioner, for a period of one (1) ye~r/ and further require: 1. Petitioner to refra.in from abusing the Respondent or placing her in fear of abuse; 2. Granting possess ion of the home located at 504 Third street, New CumberLand.Cumberiand County, Pennsylvania to . ~ VERIFICATION j.\\cheJ\e.. l=\\\l~JOn verify that the 1/ statements made in the foregoing Document are true and correct to the best of my knowledge, information and belief. I understand that the statements therein are made subject to the penalties of 18 Pa.C.S, ~ 4904 relating to unsworn falsification to authorities 5'~3'C\l.c Date ill /( hOt' til! / ( <-(}/I.! Ai~ , , I '.i,,' , . CBRTIFICATE OF SBRVICB I certify that I served a true and correct copy of Respondent's Answer upon Dennis Allison and Nora Blair, Esquire, by deposition same in the United states Mail, first class, postage prepaid, from Harrisburg, Pennsylvania, on the 23rd day of May, 1996, as addressed as follows: Dennis Allison 504 Third street New Cumberland, PA 17070 Nora Blair, Esquire 5440 Jonestown Road P.O. Box 621 6 Harrisburg. PA 17112 Date: 5/iC3/q" ,') ., .,',..1" ",..,_., , " " ~ r DIDIIII8 D. ALLI80N, I III TBI COURT OJ' COIOlON PLllA8 plaintiff I CUKBIRLAIlD COUNTY, PI1lH8YLVAIlIA I v.. I NO. 91 - 2132 CIVIL TIRJI I IIICBILLI L. ALLISON, I D.fendant I CIVIL ACTION - DIVORCI , CU8TODY AFFIDAVIT OF SERVICE I, Nora F. Blair, Esquire, hereby certify that a true and correct copy of the Complaint For Divorce Unc.er Section 3301(a) of the DJ.vorce Code with Custody Count was sent to the Defendant by certified mail, restricted delivery, return receipt requested, on May 1, 1996, addressed as follows: , ~ , MICHELLE L. ALLISON 504 Third Street New Cumberland, PA 17070 The envelope was marked "refused" and was returned to sender. The envelope is attached hereto marked Exhibit "A" and is incorporated harein by reference. The Complaint For Divorce Under Section 3301(a) of the Divorce Code with Custody Count was sent by regular mail on May 6, 1996 and was not returned to sender within fifteen (15) days. / / .".-.., , DATED: 17 /1 ' 1'/ (1- ;. '2/ /~; '::'I~ '.d \I ( J I Bla r Supreme Court 10 #45513 5440 Jonestown Road P.O. Box 6216 Harrisburg, PA 17112-.0216 (717) 541-1428 ~~~' , .I" Ii! , " , , " .L'j-t> en. 14, I. ),\11 Ii " 'I!, "1 1,1;' I' '"I ,,+~ Q'~i~,/~ '. " "'I' .,', :1 " "" , /,11' " lijlli 1,,\ ,',i",1 "1 I , , III , Ii ,1; \1\' j" "I,' I. "'''~ ~ ~.,.", ,//.. . r "'~-......-"'""...~.(. - Co(! ;rrf/7f' : " -J. , .. ~ ( " ,. i \ , ~ ,', \ I. .' ..' , ~I l I , , j-, ;.- (\~/ , .,,(" i:;'V 1.;1 "if 'I' , ' , I, I ;.1 ,;' ,(I' , ' :" , , I,' " , I.t , ..' .i r ~, t -{ t ~ .9 "R. ~ ~, ,Lt.' 0 0 i I " iJ 1I!' ," In 0 ll) ( " ~ , I" I.t'l .1.. & \C) I'" l 0- -.. N) , fe,. <~ ;" - - ~ L.: , .. ... 11 " ..J o,J. I I' , , I " , , ! CORRECTION Previous Image Refilmed to Correct Possible Error t -I; t l 8 "'&. 1;l~ i' f.) (, , 0 I) () i u'" ., \t) 0 ll) c',. ~ t:< & III \() l"- t . c- .... (1) , f; i:\ - L J .. ~ ~ '11 '" I' . , ' 8. Plaintiff and Defendant are both citizens of the United states. 9. Plaintiff has been advised of the availability of marriage counseling and of the right to request the Court to require the parties to participate in such counseling. Being so advised, Plaintiff does not request that the Court require the parties to participate in counseling prior to a Divorce Decree being issued by the Court. 10. Plaintiff avers that the grounds for divorce are that Defendant has committed adultery and Defendant has offered such indignities to Plaintiff, the innocent and injured spouse, as to render Plaintiff's condition intolerable and life burdensome. WHBRSlOR!, Plaintiff requests that Your Honorable Court enter a Decree of Divorce. COUNT II CUSTODY OF MINOR CHILDREN 11. The averments of Paragraphs 1 through 10 are incorporated herein by reference as though set forth in full. 12. The parties are the parents of 3 minor child~en, Joseph Allison, born June 17, 1987, Lucas Allison, born on June 19, 1990, and Jacob Allison, born August 5, 1992. 13. Plaintiff se'lks primary physical and legal custody of the following minor children: tfAHE PRESENT ADDRESS 504 Third Street New Cumberland, PA 17070 504 Third Street New Cumberland, PA 17070 504 Third Street New Cumberland, PA 17070 Joseph Allison Lucas Allison Jacob Allison DATE OF BIRTH June 17, 1987 June 19, 1990 August 5, 1992 Lucas Allison and Jacob Allison were born in wedlock. Joseph Allison is the national son of Michelle Allison and was adopted by Dennis Allison. The children are presently in the custody of mother and father who reside at 504 Third Street, New Cumberland, PA 17070. 14. During the last five years, the children have resided with the f.ollowing persons and at the following addresses: NAMES Michelle Allison Dennis Allison ADDRESS~S 504 Third Street New Cumberland, PA 17101 DATES June of 1994 to Present Nathaniel Bruno Edith Bruno Michelle Allison Dennis Allison 302 Hickory Hill Terr.ace August of 1993 HarriSburg, PA 17109 to June of 1994 Michelle Allison Dennis All ison 312 East Kansas Medicine Lodge, Kansas 67104 Michelle Allison DElnnis All ison 504 Roosevelt Avenue Middletown, PA 17057 Fort Indian Town Gap RD2 Box ?? Lebanon, PA 17003 Michelle Allison Dennis Allison June of 1993 to August of 1993 June of 1992 to June of 1993 August of 1991 to June of 1992 The father of the children is DENNIS D. ALLISON, residing at 504 Third Street, Cumberland county, New Cumberland, PA 17070. He is married. The mother of the children is MICHELLE I/O ALLISON residing at 504 Third street, Cumberland county, New Cumberland, PA 17070. She is married. 15. The relationship of PlaintiCf to the children is that of Father. The Plaintiff currently resides with the following persons: HAW: Michelle Allison Joseph Allison Lucas Allison Jacob Allison RELATIONS~ Wife (Separated) Son Son Son 16. The relationship of Defendant to the children is that of Mother. The Defendant currently resides with the following persons: HAW: Dennis Allison Joseph Allison Lucas Allison Jacob Allison RELATIONSHIP Husband (Separated) Son Son Son 17. Plaintiff has not participated as a party or witness, or in another capacity, in other litigation concerning the custody of the children in this or another court. Plaintiff has no information of a custody proceeding concerning the children pending in a court of this Commonwealth or in another state or Commonwealth. Plaintiff does not know of a person not a party to the proneedinge who has physical custody of the children or claims to , I v. ...;, . X,N. .:J;u.E., CQllRT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-2132 CIVIL TERM DENNIS D. ALLISON, Plaintiff MICHELLE L. ALLISON, Defendant CIVIL ACTION DIVORCE & CUSTODY ANSWER TO PLAINTIFF'S COMPLAINT IN DIVO~ UNDER SECTION 3301(a) OF THE DIVORCE CODE AND NOW comes Defendant, Michelle L. Allison, by and through her attorney, Cara A. Boyanowski, Esquire, and avers the following: COUNT I DIVORCE UNDER SECTION 3301(a) OF THE DIVORCE CODE 1. Admitted. 2. Admit ted . 3. Admitted. 4. Admitted. 5. Denied. It is been living separate and .. .~.... .. '''...... I'" ",. '. ~ specifically denied that the parties have apart since on or about November 7, 1995. By way of further explanation, Defendant maintains that the parties have resided together in the same household and have shared the marital bed since the alleged November 7, 1995, separation date. 6. Admltted. 7. Admitted. 8. Adm it ted . .. ...... .. ~ 100 .. ... I'" "" ,. . 9. Defendant is without knowledge or information sufficient . 10 .j~"'''~'' DINNIS D. ALLISON, IN THZ COURT OP COMMON PL!AS or I Petitioner I CUMBERLAND COUNTY, PENNSYLVANIA I V. I NO. 96.3132 I MICHELLI L. ALLISON, I CIVIL ACTION - LAW Respondent I PROTICTION PROM ABUSS IN RII PROTECTIVE ORDER ORDER or COURT AND NOW, this 24th day of May, 1996, after hearing, the Court finds that the re.pondent, Miohelle L. Allison, ha. abu.ed Dennis D. Alli.on within the meaning of the Proteotion from Abuse Act, and I 80 find. The Court further directs that in the future .he .hall refrain from abu8ing the petitioner. I would also find that Mr. Allison has abused the r..pondent. However, .ince there'8 been no petition filed, under the law I'm not permitted at thi8 time to enter such an order, but upon appropriate petition being filed I'd be willing to enter an order finding that he has abu.ed Michelle, and also that he'. directed to refrain from abusing her in the future. By the Court, "/.li ~Mi~,~, \J; - Nora r. Blair, Esquire ror the Petitioner "t". , ~ l CC.r1.kL ,)liU.tJ/ rc /1>>f Cara A. Boyanowski, Zsquire 7,~,~ ror the Re.pondent mal 1,1 " I ) . v.. I IX TBB COURT O. COKNOH PLBAI I CUKlBRLMlD COUllTY, PDl1I8YLVUIA I I 110. '6 - 2132 I I I CIVIL ACTIOII - LAW I PROTSCTIOH rROM ABU8! 0...18 D. ALLI80N, ,.titioDer HICBBLLB L. ALLI80N, R..pODd.Dt .-Ji /1 UD NOW, this ...Li- ORDER day of ~ " _,..... '-J' .............. - , 1996, upon presentation of evidence at hearing, it is hereby ordered that: 1. Respondent is to refrain from approaching, abusing, threatening, or harassing Petitioner, either physically or verbally, or placing him in fear of abuse, wherever he may be; 2. Respondent shall not possess any hand-guns or other firearms during the pendency of this Order; 3. A certH ied copy of this Order shall be served on the New Cumberland Police Department as the police department with jurisdiction to enforce this Order. Should the police come in contact with Respondent, and should Respondent allege that she has not been served with this order, the police officer shall immediately serve the Order upon her. 4. This Order shall be enforced by any law enforcement agency in any county where a violation occurs. As provided in 23 Pa.C.S. 5 6113(a) of the Act, " [a]n arrest for violation of an order issued pursuant to this Act may be without warrant upon , , probable caus. whether or not the violatiun is committed in the pres.nce of the police officer." 5. Respondent is hereby notified that if she violates this Order, she may be held in indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or by a jail sentence of up to six (6) months. BY THE COURT: ~ ~. ct \'~~, "\ __ a Old~. Sheely, Judge ,/1, .1 ~J "" r-. ~ . , ~ I ' ~ '1 ~ r' II ., ~ I ,I . 01..1. D. ALLI.ON, Plaintiff va. I IN THI COURT OF COKMON PL-.. I CUHBIRLAID COUNTY, P....YLVAaIA I I RO. II - 2132 CIVIL TIRM I I I CIVIL ACTION - DIVORC. HI CHILLI L. ALLI.ON, Dafendant ORDER MID NOW, this 1/'1. /1 day of , (i d 11 ,~.. - For / pecial , 1996, upon consideration of the Petition Relief, filed by Dennis D. Allison, parties shall appear day of ~/ Courtroom N4),j1 it is hereby Ordered and Decreed that the for a hearing on said Pstition on the " _) I1...L , 1996, at k CD o'clock /i-.m. in of the Cumberland County Courthouse. J. ,,"'~'\1\~NN?d 'I ' ,', ';" ,',''1'' "H~' . ' .J \ ,,,, [IG, /: \ ')1" I [' II," ; f;J "I' I , ',"\ ""'. ' ,', ,_ _J f\U j~.'" , .6-. " J ~'JUjO'UJ 1\ 7. Having the two parties reside in the same house is becoming very stressful fo~ the parties and their minor children. 8. The most recent incident occurred on Saturday, May 18, 1996, when Respondent became upset because Petitioner refused to discontinue the divorce action. Respondent proceeded to: a. Poke Petitioner in the face with the portable phone. b. Spit in Petitioner's face. c. Slap Petitioner across the back with his work vest, which had his metal name badge on it. The name badge left a red mark on Petitioner's back and the name badge was broken. d. Slammed the portable phone on the kitchen counter until it was smashed. e. Ripped the phones in the house out of the wall. f. Threw the large phone at Petitioner hitting him in the groin. 9. On numerous occasions in the past, especially during the last eight months, Respondent has slapped Petitioner with her open hand, usually on the back; punched Petitioner, usually on the arm; thrown various household items at Petitioner, including picture frames and telephones; and attempted to take things from Petitioner, such as telephones and resulting in hitting Petitioner with the item. 10. When Respondent becomes upset with Petitioner, she makes inappropriate statements to the parties' children or in front of I, .. the parties' children. Such statements include: a. Telling the children that their father is leaving them. b. Telling the children that thoir father is kicking them out. c. Telling the children that their father is rude to their mother. d. Calling Petitioner names uuch as "asshole". 11. In an effort to entice Petitioner into her bed, Respondent frequently walks around the house wearing no clothes or wearing just a thong. This is done frequently when the minor boys are present and are awake. 12. Petitionar and Respondent rent the house at 504 Third street, Cumberland County, New Cumberland, Pennsylvania. 13. Petitioner has difficulty paying all of the bills for the rental property on his salary alone. 14. Petitioner has requested that Respondent seek employment to assist with the bills. 15. Respondent has refused to seek any type of employment. 16. Respondent's mother and her grandmother live in Susquehanna Township. DIDI. D. ALLIIOII, I III TBS COURT or CONHOII PLIlI peU tioner I CUllBULA1lJ) COl1JlTY, ....IYLVAlfIA I v. I 110. 16 - 2132 CIVIL TZU I IIIC.ILLS L. ALLI.OII, I CIVIL ACTION - LAW .e.ponclent I PROTSCTIOII .ROM ABU.S ORDER AIfD IIOW, this )., ~ay of b/ttN l,.. , 1996, after review of the Petition For Contempt Of Protection From Abuse Order, a hearing is scheduled on said Petition for the .ot~ ~ day of _UtJ'\JL , 1996, in Courtroom Number ~, Cumberland County Courthouse, Carlisle, Pennsylvania. cE I :J() '-m. fJCG~ t~ if\- . 1........ J. , .J..t:J . , qv J.. NO,I V~I t,6l,Ct.~ f\ l \ a. Friday, June 7, 1996, Respondent harassed Petitioner at the Winner's circle Saloon located in the Holiday Inn, Grantville, PA. Petitioner, ~lho is on summer drill with the National Guard at Indiantown Gap, was having dinner at the restaurant when Respondent and her mother arrived at or about 10:30 in the evening. Petitioner believes and therefore avers that Respondent was there to see Petitioner because Respondent's mother had seen Petitioner there earlier in the week. According to witnesses, Respondent began to drink heavily, Later that night, Respondent approached Petitioner while he was sitting and talking with his friends. She asked him to dance and he refused. Shortly thereafter, Respondent returned to where Petitioner was sitting and proceeded to "bad mouth" him in front of his companions. Petitioner calmly asked Respondent to return to her table. Respondent returned to her table and danced for a while. Respondent again approached Petitioner and told him that he was losing the best thing that ever happened to him. Petitioner asked Respondent to leave him alone. RB8POHDBHT 8PIT IN PBTITION.R'8 I'AC.. Petitioner went into the lobby of the hotel to find a security guard. Two troopers happened to be in the lobby at the time, and Petitioner told them what had occurred. He informed them that both Petitioner and Respondent had Protection from Abuse Orders. The officers spoke with Petitioner and Respondent separately, and Respondent admitted to one of the officers that she had spat in Petitioner's face. The officers also asked Petitioner's friends to describe what had happened. These witnesses are willing to testify to the accuracy of the events described herein. As the troopers could not verify the existence of the orders, they asked Petitioner if he wanted to file charges against Respondent. He responded in the affirmative. The officers issued a summons to Respondent either for harassment or disorderly conduct. b. Wednesday, June 5, 1996, Petitioner attempted to speak with the parties' children while he was away at guard duty. Respondent listened in on the telephone conversation, and when Petitioner asked her to stop, she took the phone away from the children and hung up on Petitioner. c. Wednesday, May 29, 1996, Respondent and her mother sat in the parties' house and were talking about Petitioner. They spoke in a loud enough voice that Petitioner could hear them and heard the numerous names that Respondent was calling Petitioner. d. Friday, May 24, 1996, and other subsequent to that time, Respondent made it difficult for Petitioner to sleep on the couch by trying to talk with Petitioner or speaking loudly in the same room where Petitioner was trying to sleep. Despite Petitioner's requests to stop such conduct, Respondent continued obviously with the intent to harass and annoy Petitioner. 6. Petitioner believes that he is in immediate and present danger of further abuse and harassment from Respondent, and that he in need of, and entitled to protection from such abuse. 7. Petitioner believes and therefore avers that if the parties remain in the same residence, the harassing, annoying and abusive conduct by Respondent will continue. VERIFICATION I verify that the statement made in the foregoing document are true and correct to the best of my knowledge, information and belief. I understand that the statements therein are made sUbject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. O~ D..-IS D. ALLISOII, I III Tal COURT or COIOlOII PLUS PStitiODSl' I CUIUIIRLUD COtnlTY, PI..SYLVUIA I v. I 110. t. - 2132 CIVIL TBRII I IIICISLLI L. ALLISOII, I CIVIL ACTIOII - LAW RS.pOD4sDt I PROTBCTIOH FaOM ABU.B CERTIFICATE OF SERVICE I hereby certify that I have this date served a copy of the Petition For Contempt Of Protection From Abuse Order on the person in the manner stated below which service satisfies the requirement of Pa.R.C.P. No. 440. SERVICE BY FIRST CLASS MAIL TO: Cara A. Boyanowski, Esquire 5201 Jonsstown Road Harrisburg, PA 17112 Date: June 19, 1996 Respectfully submitted, j} .... "~ d _,J IL(C:1 " j '" ..... ~ ,... ... .... Jana C. rler DENNIS D. ALLISON, Plaintiff/Respondent IN THE COURT OF COMMON PLEAS CUMBER~AND COUNTY, P~NNSYLVANIA NO. 96-2132 CIVIL TERM v. MICHELLE L. ALLISON, Defendant/Petitioner CIVIL ACTION ~ DIVORCE PETITION FOR SPECIAL RELIEF AND NOW, comes Petitioner Michelle L. Allison by and through her attorney, Cara A. Boyanowski, Esquire, and files this Petition for Special Relief and avers as follows: 1. Petitioner is Michelle L. Allison an adult individual presently residing at 302 Hickory Hill Terrace, Harrisburg, Dauphin County, Pennsylvania. 2. Respondent is Dennis D. Allison an adult individual presently residing at 504 Third street, New Cumberland, Cumberland County, Pennsylvania. 3. A Complaint in Divorce under 3301 (a) was filed on or about April 25, 1996. 4. On or about May 22, 1996, Respondent filed a Protection From Abuse Petition against Petitioner. 5. After hearing on May 24, 1996, concurrent Protection From Abuse Orders were filed upon both parties. 6. On June 26, 1996, Petitioner voluntarily removed herself from the marital residence at 504 Third street, and she and the children moved in with Petitioner's grandmother, Edith Bruno, 7. At the limc PPlltiorwr from the marital properly, ~tJe reUlOVI'c! het'lw] f and the chi ldrcn left. behind numerous items of personal propl'l.ty and lll'JonrJinl):;, 8. On Junc 26, 1996, Uw partics agrccd that Petitioner would be ~llowed to enter the premises at a later date to remove her personal propert.y and ~('lonl)ings, as long as Respondent and a constable were present durinCJ lhe exchange. 9. In the Order of Court, filed June 26, 1996, the Honorable Harold E. Sheely, placed the following language: "The mother has removed herself from the premIses at 504 Third street. She agrees not to return except to remove her personal belongings, and by further agreement Mr. Allison shall be present at such time as the personal belongings are removed." A copy of said Order is attached hereto and incorporated herein as Exhibit "A." 10. On or about July 2, 1996, Petitioner forwarded a list of personal property requested and again requested a date for removal of same. A copy of the letter, dated July 2, 1996, is attached hereto and incorporated herein as Exhibit "B." 11. Peti tioner and Peti tioner' s counsel have continuously requested a date and time from Respondent and Respondent's counsel to schedule the removal of Ms. All ison I s personal property and belongings from the marital residence since July 2, 1996. Copies of letters, dated July 18, 1996, and August 6, 1996, are attached hereto and incorporated herein as Exhibit "C." 12. Respondent and Respondent's counsel have continuously failed to relinquish possession of Petitioner's personal property and belongings or schedule a date for relinquishment of said property. In fact, Respondenl has lecenUy slaLed ltJilt he will not allow Petitioner to remove her personal property and belongings without a signed court order. 13, Petitioner is in the process of moving from her grandmother's residence and establishing a residence of her own. 14. Petitioner is in need of her personal belongings and property to establish this residence. 15. Petitioner has been and will continue to be damaged by Respondent's wrongful detention of Petitioner's personal property and belongings. WHEREFORE, Petitioner respectfully requests that this Honorable Court enter judgment in her favor and against respondent for: 1. the possession and delivery of all Petitioner's personal belongings and property; 2. pay all legal fees incurred in this action to effectuate the exchange of peU tioner' s personal property and belongings; and 3. any and all other relief which this Court deems appropriate. Respectfully Submitted, MacINTYRE & MacINTYRE ,. / , (/ 1,'1.' j'" C/)~ ' I'" '/. '.(- ( '[ II ' I{I/ If I/,-t~ ;)/:) -ara A. Boyanows i, Esquire 5201 Jonestown oad P.O. Box 6656 Harrisburg, PA 17112 (717) 652-9485 , , CERTIFICATE OF SERVICE I, Cara A. Boyanowski, Esquire, do hereby certify that I caussd a true and correct copy of the foregoing to be served upon the following individuals by placing the same in the United states Mail, First Class Postage Prepaid, at Harrisburg, Dauphin County, Pennsylvania, on _J!.-;;;.'3' '1[;, and addressed as follows: Nora F. Blair, Esquire 5440 Old Jonestown Road Harrisburg, PA 17112 I/] V i, l- ara A. Boyanow 'i' Attorney for Petitioner ,"'), j''}t:[.c,.::f' c.' " U) ~ in /'.,": 8 1i ~ ). II. ..~ r, lI') .: !J . " ., I 'ffi 1" -- ,~ I ":':) ft =, .1 II, ..~ d <..J V> . '.1' J;' , 1~ Ii! i tI' j;; , j~ ' . i ~ E GI ~.&! &&:=re5ca II~I i IN . 'tl... .001 ~~ ~ lil'" ~i~if >t.. ~ . .~Iij 0< ~ III '001 III 001 ~ tU~~ "" 0: - ::J C3' UJ "" 1aI a: - :J l3' UI 1aI . 0: - <Q c( - ..J ~ III J ~ ~ . ~ f;j ~ &.; )( <C Sa; ~ i ~ E ~ ~ ~ ~ . It: - <Q c( ~ .J lil aJ~~g ~ .. ,,~ ~ ell a: ~ i ~ jf!t o ;q z :!, 0. MICHELLE L. ALLISON I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA V. I I DENNIS D. ALLISON I NO. 96-2132 CIVIL TERM . . I CIVIL ACTION - LAW ORDER OF COU.!i'r AND NOW, this 28th day of JULY, 1997, the sheriff of Cumberland County is directed to return to Dennis D. Allison all firearms taken from him as a result of a final protection from abuse order dated May 30, 1996. This order has not been extended. Mr. Allison shall contact the sheriff's office for the procedure to be followed in the return of the firearms. B he Court, \\.c\\'f H rold E. Shes COI Cara A. Boyanowski, Esquire Dennis Allison C/~f"( I .T1-lll..,.('i..{ 1 ')'i, '17 lsld Shoeriff's Office of Cumberland County ./" .~'"... -I;""'" I , 1/ \ i, ...... ,.... r~'~ b; .."..' "'I~ f., N , ., I LJ ~ -: , ()..' 11: ~i' C_ , ~r. 1'::\ " ("....' " ,J.,I -. r~I' :':l "I 'j J"'j : 'JI:l. f-: -, r~~ II, ,.... " (.! CT" U