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Home My WebLink About96-04575 ) /' ,..,'" /" i I i .::F . - ~ V) ~ ~ J li1 r to -:r I , i ! cJ: , I I i ';:, ,~ LEGAL SERVICES, INC. a IRVINE ROW CARUSLE, PENNSYLVANIA 17013 (717) 243-9400 Fax (717) 243-8026 West Shore (717) 766-8476 Shlppensburg (717) 530-5866 . y,; OrJ,Cf .. . ~'!!: ,; CAROL DAWN HARRIS, Plaintill' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v SEAN EARL SMITII, Dcfenda t NO 96- ~'375 CIVIL TERM PROTECTION FROM ABUSE RARY PROTHTION ORf)f:R AND NOW, this{_. _ day of August, 1996, upon presentation and consideration of the within Petition, and upon tinding that the plaintill: Carol Dawn Harris, now residing at an undisclosed location for her own protcction and to avoid further abusc, is in immediate and prcsent danger of abusc from thc detendant, SEAN EARL SMITH, the following T7"orary Order is entered. . LAW ENFORCEMENT AGENCIES. IIlJMAN SERVICE AGENCIES AND SCHOOL DISTRICTS SHALL NOT DISCLOSE THE PRESENCE OF THE PLAINTIFF , IN THE JURISDICTION OR DISTRICT OR FlIRNISH ANY ADDRESS. TELEPHONE NUMBER, OR ANY OTHER DEMOGRAPmC INFORMATION ABOUT THE PLAINTIFF EXCEPT BY FlIRTHER ORDER OF COllRT. The defendant, Scan Earl Smith, (SSN: 187-54-6406)(DOB: 11/06/66), is an adult individual residing at II Sunset Drive, Mcchanicsburg, Cumberland County, Pennsylvania is hereby enjoined from physically abusing thc plaintil1: Carol Dawn Harris, or from placing her in fcar of abuse. The defendant is ordcred to stay away from the plaintiffs current rcsidence at an undisclosed location, which is not owncd or Icascd by thc dcfendant, and is ordered to stay away from any residence thc plainlil1' may in the futurc establish for herself. The defendant is ordcred to rcfrain from having any direct or indircct contact with thc plaintiff including, but not limitcd to, tclcphonc and writtcn communications. The defendant is cnjoincd from harassing and stalking thc plaintiff. Thc dcfendant is cnjoincd Irom cntcring thc plaintill's placc of cmploymcnt Thc dcfendant is enjoincd Irom rcmoving. damaging. destroying 01 selling any propcrty owncd by the plaintiff A violation of this Order may subject the defendant to: i) arrest under 23 Pa.C.S. ~61 13; ii) a private criminal complaint under 2J Pa,C.S. *6113.1; iii) a charge of indirect criminal contempt under 23 Pa.C.S. ~6114. punishable by imprisonment up to six months and a fine of $100.00-$1.000.00; and iv) civil contempt under 23 Pa.C.S. ~6114,1. This Order shall remain in cll'cct until modificd or terminatcd by the Court and can bc extended beyond its original expiration date ifthc Court finds that thc delendant has committed an act of abuse or has engaged in a pattcrn or practicc that indicates risk of harm to the plaintiff. The defendant is ordercd to relinquish to the sheritTs department any weapons which he owns, possesses, has used or threatcncd to use against the plaintiff and thc defendant is prohibit cd from acquiring or possessing any weapons for the duration of this Order. 0. A HEARING SHALL BE HELD ON THIS MATTER ON THE:J) DAY OF ~ AUGUST. 1996. AT r..f' fA a... IN COURTROOM NO.3... ClIMBERLAND COUNTY COURTHOUSE. CARLISLE. PENNSYLVANIA. The plaintiff may procced without pre-payment of fees pcnding a further order after the hearing. Thc Cumbcrland County SherifTs Departmcnt shall attcmpt to makc service at thc plaintiffs request and without prc-payment of fees, but scrvice may be accomplished under any applicable rule of Civil Procedure. This Ordcr shall bc dockcted in the office of thc Prothonotary and forwardcd to the Sheriff for service. The Prothonotary shall not send a copy of this Ordcr to the dcfendant by mail. The Hampden Township Policc Departmcnt and any other appropriate police departmcnts shall be provided with certified copics of this Order by thc plaintiffs attorney. This Order shall be enforced by any law cnforcemcnt agency whcre a violation occurs by arrest for indirect criminal CAROL DAWN HARRIS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. SEAN EARL SMITH, Defendant NO. 96- CIVIL TERM PROTECTION FROM ABUSE PETITION FOR PROTECTION ORDER RELIEF UNDER THE PROTECTION FROM ABUSE ACT, 23 Pa.C.S, ~6IOI et seq. A. ABUSE 1. The plaintilJ: Carol Dawn l'larris, is an adult individual temporarily staying at an undisclosed location lor her own protection and to avoid further abuse as is more fully set forth herein. This addrcss will be furnished to thc court upon request. 2. Thc defendant, Sean Earl Smith, (SSN: I 87-54-6406)(DOB: 11/06/66), is an adult individual residing at II Sunset Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055. 3. The defendant is thc son of the plaintiff 4. Sincc approximatcly 1993, thc dcfendant has attempted to cause and has intentionally, knowingly, or recklessly causcd bodily injury to the plaintiff, has sexually assaulted the plaintiff, has falsely imprisoncd thc plaintiff pursuant to 18 Pa. C.S. * 2903, has placed the plaintiff in reasonable fcar of immincnt serious bodily injury, and has knowingly engaged in a course of conduct or repeatedly committed acts toward the plaintiff including following the plaintiff without proper authorization, under circumstances which have placed the plaintiff in reasonable fear of bodily injury. This has included, but is not limited to, the following specil1c instances of abuse: a) On or about August I, 1996, the dcfendant kicked the plaintiff in her wrist and threatencd her saying, "I'll kill you, cunt." The plaintiff, fearing for her safety, tclephoncd the police for help. b) On or about July 25, 1996, thc dcfendant scrcamed and yelled at the plaintill', and when thc plaintifl' said she was going to call the police, the defendant pushed hcr causin,;; hcr to fall to thc floor The defendant then stood over the plaintill' brandishing a 1/, gallon liquor bottle in a threatening manner and threatencd to luck thc plaint ill' up and to kill hcr The plaintilHeared for her life. c) On or about July 23, 1996, thc delendant entcrcd thc plaintil1's bcdroom whilc shc was slceping, scrcamcd at hcr tclling hcr that she was not going to sleep, waved a II, gallon liquor bottle in a mcnacing fashion over hcr as she lay in bed, threatcned her saying, "I'll kill you, bitch" When the plaintiff got out ofbcd and wcnt downstairs to gct away from thc defendant, he followed her, shovcd her against thc wall, threatened her saying, "I'll kill you and no one will I1nd your body.", and spat in her face twice. d) In or about early July, 1996, thc defendant entcred the plaintiff's bedroom, threw a rifle cartridgc on her as she lay on her bed, and threatened her saying, "The next onc will be ill you." c) In or about June, 1996, the defcndant fondled thc plaintiff's breasts and attempt cd to pull hcr pRnts off against her will. I) In or about carly June, 1996, the dcfendant kickcd in the door to the plaintilfs room, threw hcr possessions out of the room and, when she plcaded with him to stop, thc defendant kicked her in the abdomen. The plaintiff contacted Detcctivc Egolf of the Carlisle Police Department, told him of the incidcnt, and showcd him the bruisc on her abdomen she sustained as a result of this incidcnt. g) On or about June I, 1996, thc defendant, who has an active Protection Order against him (BENDER v. SMITH, No. 96-1439 Civil Term) prohibiting him from possessing or acquiring any wcapons, pointed a BB rifle at the plaintiff and thrcatencd to kill her. Thc plaintifl' rcportcd this incidcnt to Dctcctivc Egolf of thc Carlisle Police Department. h) On or about August 18, 1993, thc plaintiff awokc to the dcfendant fondling hcr under her clothing, then he pulled hcr clothing 011' of hcr, and uscd his body to block her from leaving the room. When thc plainljjl' got away from the dcfcndant and ran downstairs, the delendant followcd, chascd her around thc collec tablc, and thrcw the table aside and against thc window to catch her. The dcfendant pushed the plaintiff who was naked facc-down over the arm of the couch, pushcd his knee into her back to hold her down, handcuffed her hands behind her back, and rubbed his bare genitals against the plaintill' causing her to fear that he was going to rape her. As thc plaintiff pi cd for the defendant to remove the handcuffs he held a handgun against her head, cock cd the hammer, and pulled thc trigger. The plaintil1's mothcr, the defendant's grandmother, entered the room at this time and told the defendant to put the gun away and rclcase the plaintiff, which he did. 5. On or about August 12, 1996, the plaintifflcl1 hcr rcsidence at II Sunset Circle, Mechanicsburg, Cumberland County, Pennsylvania, in order to avoid further abuse. 6. The plaintiff believes and thereforc avcrs that she is in immediatc and prcsent danger of abuse from thc defendant and that shc is in need of protection from such abuse. 7. The plaintiff desires that the dcfendant be prohibited from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications. 8. plaintiff 9. Thc plaintiff desires that thc defendant bc enjoined from harassing and stalking the The plaintiff desires that the dcfendant be restrained from entering hcr place of cmployment. 10. Thc plaintill'dcsircs that thc dcfcndanl hc cnloincd Ii"," l\'nl"'ln~, dllma~mg. dcstroying or sclling any propcrty owncd hy hcr II. Thc plaintifr dcsircs thai any wcapons Ihc dclclldanl 'mns. pll"CSSCS. IIml has uscd or thrcatcned to usc against hcr conliscal<~d by thc Shcrill's Ilcpallmcnt and 111lI1 hc hc plOhihitcd {rom posscssing or acquiring any othcr wcapons iiII' thc duralionllfthis Ordcl II. EXCl.lISIVE POSSESSION 12. The plaintill' cannot rcvcal thc namcs of thc owncrs or thc homc whcrc shc currcntly residcs hccausc thc namcs will disclosc hcr whcrcahouts which must hc kcpt confidcntial for hcr protcction Thc plaintifris not sccking thc cviclillnllflhc dcfcndantfi'"11 his rcsidcncc Co REIMlIlIltSEI\H:NT Hm COST OF CASE 13. Thc plaintitl' asks that thc dclendanl hc ordcrcd 10 pay $2~O 00 10 Cumbcrland County, onc of Lcgal Scrviccs, Inc's litnding sourccs as rcimhurscmcnl IiII' thc cosl of litigating this case, and that thc dcfendant hc asscsscd thc $25 00 surchargc and any court cosls ifthc casc goes to hearing. WHEREFORE, pursullntto thc provisions oflhc "l'lOtcctionlhllll Abusc Act" ofOctobcr 7, 1976, 23 P.S. *610 I c,[ ~cq., as amcndcd, thc plaintill'l'rays Ihis Ilonorablc Court to grant thc following relief A. Grant a Tcmporary Ordcr pursuanl to Ihc "l'lOtcctionfhllll Ahusc Act''' Ordcring tllc dclcndanl 10 rl'liain fhllll ahllsing thc plaint ill' or placing hcr in Icar or ahllsc, 2. Ordcring thc dclcndant 10 rcli'ain fhllll having any dircct or indircct contact with Ihc plainlill' including, hilt 1I0t limitcd to, tclcphonc and wrillcn Clllllmunications, .J Ordering thc dl'lcndanl III refrain rrom harassing amI stalking thc plllintilJ'l\nd liomllllla"ing. 4. Prohibiting the defendant from entering the plaintitl's place of cmployment; 5. Prohibiting the delendant from rcmoving, damaging, destroying or selling property owned by the plaintifl; 6. Ordering the defendant to stay away from the plaintiffs current rcsidcnce at an undisclosed location, which the parties have never shared, and ordeIing the defendant to stay away from any residence the plaintiff may in the future establish for herself, and 7. Ordering the defendant to relinquish to the shcriffs department any weapons which he owns, possesses or has used or threatened to use against the plaintiff, and prohibiting the defendant Irom acquiring or possessing any other weapons for the duration of the Order. B. Schedule a hearing in accordance with the provisions of the "Protection from Abuse Act," and, after such hearing, enter an order to be in effect for a period of one year: I. Ordering the defendant to refrain from abusing the plaintiff or placing her in fear of abuse. 2. Ordering the defendant to refrain from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications. 3. Ordering the defendant to refrain from harassing and stalking the plaintiff. 1. prohibiting the defendant from entering the plaintitl's place of employment. 5. pro~ibiting the defendant from removing, damaging, destroying or selling property owned by the plaintiff. othcr wcapons lilllhc duration oflhe Order 6. Ordcring Ihc detcndarll 10 stay away thlll1 thc plainlitl's currcnt residence at an undisclosed location lill hcr own protcction, and ordcring thc dcfendalll to slay away thllll any residcncc Ihc plaintitl' may in the futurc cstablish l'lr hcrsclf, 7. Ordcring thc dclcndant to relinquish to thc sheritl's dcpartment any wcapons which he owns. possesses or has used or thrcatcncd to use against thc plaintitl: and prohihiting thc dclcndanl from acquiring or possessing any 8. Ordcring Ihc dclcndant 10 pay $2S0 00 10 Cumberland County, one of Lcgal Scrviccs. Inc's I(lIlding sourccs as rcimburscment for the cost of litigating this casc and asscssing thc $2S 00 surchargc and court costs to the dcfcndant ifthc ease goes 10 hcaring The plaintifl'furthcr asks lhatthis PClition hc tiled and scrvcd without payment of fees and C03ts by the plaintiff, pending a li,rther ordcr at Ihe hcaring, and that certil1cd copies of this Petition and Order be delivcrcd to thc Ilampdcn Township and any other appropriate police departments the which have jurisdiclion to cnlillcc this Ordcr The plainliffprays for such othcr rclicfas may bcjust and proper. Rcspcctfully submitted, ~:~ Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 ~~ 0 .. ,.... ':J L t:) I. r , r.u~} (1, .- <. ,. \;1 l~;. 'e L'._, (;) ~ '", - ,I (~..: .') .'] ...J .. , r;: 1.. , , cj : ~.' -' ~ ;j I- ;;,: !.:J.... :1. .', J Co ,.., --.; ,!J (-'-', u .i , ";:~!f~l j'r,''''.J....~, .?~ ,'-;:ii~~~ 1998'" '<:';hifu\,:,~;>]fi, '-B~:~:':?1& LEGAL SERVICES, INC. B IRVINE ROW CARLISLE. PENNSYLVANIA 17013 17171 243-9400 Fax (7171 243-8026 West Shora 1717) 766-8476 Shlppensburg t7171 5JO.5866 ocre9 , ~. .., " ~ CAROL OAWN HARRIS, Plaint iff IN THE COURT OF COMMON PLEAS OF CUMaERLAND COUNTY, PENNSYLVANIA v. No. 96-4575 CIVIL TERM SEAN EARL SMITH, Oefendant PROTECTION FROM ABUSE ~ ORDER OF COUR~ ANO NOW, this L'- day of ~, 1996, upon consideration of the Prae ipe filed in the above matter, the temporary protection order dated , 1996, is VACATED. ay the Court, , J. Joan Carey Attorney for Plaintiff LEGAL SERVICES, INC. a Irvine Row Carlisle, PA 17013 _ te-8-~~.,"",~"-~l'<l. Ill/III"!:....,.,. Lawrence J. Rosen Attorney for Defendant 1101 North Front St. Harrisburg PA 17102 '. l' (", , , l.' r , , No. . 96~A57.5 CIVIL TERM CAROL DAII'.N.tlA8EISL. PI a i nt iff vs. SEAN._E'\L~Ut'-'-~f engilnt PRAECIPE Filed Joan Carey _._... LEq(\L SERVICES, INC. 19 , Atty. CAROL DAWN HARRIS, Plaintitl' IN THE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 96-4575 CIVIL TERM SEAN EARL SMITH, Defcndant : PROTECTION FROM ABUSE MOTION FOR CONTIN lIANCE The plaintiff, by and through hcr attorney, Joan Carey of Legal Services, Inc., moves the Court for an Order continuing gcncrally the hearing in thc above-captioned case on the grounds that: I. A Temporary Protection Ordcr was entered by this Court on AUh'llst 15, 1996, schcduling a hcaring for August 20, 1996, at 4:00 p.rn. 2. The Cumberland County Sheriffs Department scrvcd the defendant with a certificd copy of the Temporary Protection Order and Petition for Protection Order on AUh'llst 16, 1996, at 3 :30 p.m. at II Sunset Circle, Mechanicsburg, Cumberland County, Pcnnsylvania. 3. The defendant has retaincd Lawrence 1. Rosen, Attorney at Law, to represent him. 4. The parties, by and through their rcspective counsel, agreed that the plaintiffs counsel filc a Motion for Continuance to reschedule thc hearing. and an Order lor Continuance was entcred on AUh'llst30, 1996, rescheduling the hcaring to October 1,1996, at 3:30 p.m. 5. The parties, by and through thcir rcspective counsel. agree that the hcaring be continued generally to facilitate negotiation of a Conscnt Agreemcnt in the matter. 6. The plaintiffrcquests that the Tcmporary Protcction Order remain in effect for a period of one year or until further Order of Court. , , LEGAL SERVICES. INC. B IRVINE ROW CARUSLE, PENNSYLVANIA 17013 (7171 243-9400 Fox (7171 243-8026 Wost Sha," 1717) 766-&175 Shlppensburg (717) 530-5866 ,j . CAROL DAWN HARRIS, Plaintifl' IN TIlE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA v. NO. 96-4575 CIVIL TERM SEAN EARL SMITI!, Defendant PROTECTION FROM ABUSE 'J.nMDER FOR CONTINlIANCE AND NOW, this ~ day of August, 1996, upon considcration of the attached Motion for Continuance, the matter schcduled for hearing on August 20, 1996. at 4:00 p.m. by this Court's Order of August 15, 1996. is hcreby reschcduled for hearing on SEPTEMB[R 10, 199ft, . CCrlv"e ~ I N'fr'c at 3:30 p.m., In Courtroom NO.3. I The Temporary Protection Order shall rcmain in effect for a period of one year or until further Order of Court A certil1ed copy of this Order for Continuance will bc provided to the Hampdcn Township Police Department by the plaintiff's attorncy. By the Court, Judge Joan Carcy ~~J.. LEGAL SERVICES, INC. ~? Attorney for Plaintil1' \ 0\ q\> '6 b J-~ Lawrencc J. Roscn Attorncy for Dcfendant r' , .. ... ~ ., ,l 1":-) , :--. , .- > ;..) ~ ~ CAROL DAWN HARRIS, Plaintifl' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 96-4575 CIVIL TERM SEAN EARL SMITI i, Defendant PROTECTION fROM ABUSE MOTION FOR CONTINlIANCE The plaintiff moves the Court for an Ordcr reschcduling the hcaring in the above- captioned case on the grounds that: I. A Temporary Protection Order was issucd by this Court on August 15, 1996, scheduling a hearing for August 20, 1996, at 4:00 p.m. 2. The Cumberland County Sheriffs Department servcd the defendant with a ccrtil1ed copy of the Temporary Protcction Order and Petition for Protection Order on August 16, 1996, at 3:30 p.m. at 11 Sunsct Circle, Mechanicsburg, Cumberland County, Pennsylvania. 3. The defendant has retaincd Lawrcnce J. Rosen, Attorncy at Law, to rcpresent him. 4. By agreement of the parties and through their respective counsel, the plaintiff's counsel files this motion to reschedule thc hearing. 5. The plaintiff requests that the Temporary Protection Ordcr remain in effect for a period of one year or until further Order of Court. 6. A certil1ed copy of the Ordcr for Continuance will bc delivered to the Hampden Township Police Department by the attorncy for thc plaintiff. WHEREFORE, the plaintiff rcquests that thc Court grant this Motion and reschedule this mattcr for hearing, ami that the Temporary Protection Ordcr remain in effect for a period of one year or until further Order of Court. Respcctfully submittcd, r) ~-, , ) , - ' I.. , -}-;;C-~-1'-/ ,v c::...--(....- Olin Carcy, Attorney for P, intiff :3I1EIlIH":,: f;!':TI.'fnl L!-::-i'.JI.Ah CASE NO: 1~~b-04575 P COMMUNW,:ALTH IJF [.'UINSYLVMIIA: COUNTY UF l:UM HI.:riLANI.' IIAIW I:, CAROL DA WN v'=;. SM lTH S,:AlI EAllL M LI;IlM;I. HARll [CI\ , :.'he'f lff Of' U",put.y ShC'f'lff of CUMDEf{LANIl County, rennsylvanl;;J, who bel.ng duly s....ol"n according to law, says. the with1n !'HUTr:CTIUN l~nUM ABU2!-~_._____~ \lfas served upon SM ['I'll Sf.:AN I::ARL defendant, at lS:30:fllQl HOURS. on the 16th d~3Y of AUQust thE' 1':J96 at 11 SUNSI::T CIRCL"; MECIIANICSBURG. PI. 17055 , CUMBERLAllP County, Pennsylvania, by handIng to SI-~bJL_J;.~~.t1JTt!_________ a true and att.ested copy of the PIlUTI::CTION FROM ABUSI:: together with TI::MPURARY PROTECTION URDER and at the same time directing His attentlon to the contents thereof. Additional Comment.s: ONE RED RYDER (DAISY), MODEL 1938 B, WAS CONFISCATED FROM THE RESIDENCE, f;heriff's Coats: Docketinq Service - Affidavit ~iurcharge So ;Jnswe~f'~'5' //7 ~., ,- ," /~"~/'. 7 ~~Y-..r~. ..r '-'..(e':'l(:.~" r:;-:--Tllomas-Kllne. ~'h:r111 S7'i:-lJB'-el0/00/::00 . /-?~. ~, -J ~~ (/0 -..-::--.. D~~_ \ 18.00 7.G6 .00 2.00 Sworn and subscribed to before me , _. 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I: :E E-<O . .. ltl " ltl , J: z::> tilet: 0 ltl <I) ltl <I) ....u P,P, Z U Ul Z C/l . CAROL DA WN HARRIS : IN TIlE COURT OF COMMON PLEAS : CUMBERLAND COUNTY. PI:NNSYLV AN!A v. SEAN SMITl! : NO: 96-4575 and 96-14.1<) AND NANCY BENDER : PROTECTION FROM ABUSE v. SEAN SMITH TO THE HONORABLE GEORGE E. HOFFElt JUDGE OF SAID COURT: PETITION FOR TilE RETUI~N OF PIWPERTY AND NOW, this ,),'1 day of January 2002, comcs Pctitioncr, Scan Smith, by and through counscl, Lawrcnce J. Roscn, Esquirc, and offers thc following avermcnts in support of the within Petition: I. Pctitioncr, Scan E. Smith, is an adult malc rcsiding in Cumbcrland County at 103 November Drivc, Apartmcntll2, Camp Ilil!. Pcnnsylvania, 17011. 2. Pursuant to a Protcction From Abusc Ordcr in 1996 in ",vor of Plaintiff, Tracy Miller. "WI' fircarms wcrc confiscatcd li'om Pctitioncr by thc Cunbcrland County ShcrilT (Scc Exhibit A). 3. Subscqucntly.two additional Protection From Ahusc Ordcrs werc issucd by Your Ilonorablc Court undcr thc abovc-captioncd docket numbcrs. 4. All of'thc above Protcctionl'rom Abusc Ordcrs havc cithcr bcen withdrawn (Scc Exhibit B) or cxpircd. 5. By Ordcr datcd Fcbruary 9, 1999, the Honorable Judge Ilaylcy cntcrcd an Order as pcr Dockct Number 95-0866 ordcring the rcturn of Pctitioncr's fircarms. (Sec Exhibit C). 6. Pctitioncr is sccking an Ordcr from Your Honorablc Court dirccting thc Sheriffof Cumbcrland County to rcturn to Pctitioncr alllircarms cllrrcntly in his posscssion bclonging to Petitioncr. WHEREFORE, Pctitioncr asks that Your Ilonorablc ('ourt Ordcr thc return to him of all fircarms currently in thc posscssion of thc Cumbcrland County ShcrifT belonging to him. Respectfully submitted: KREVSKY & ROSEN, P.c. By: I L rei cc J. Rosen, Esquire 1101 North Front Street Harrisburg, P A 17102 10# 10625 (717) 234-4583 ~~ j'-- - (;fflWO:t- ;/1' Iya '11,',., 0/,,,,, cr- 2./2J /'i:F Ct.NBERl...\ND CCU1'ny SilERIFF'S DEP/\R'I!-lE'rr l'rupel1y Record . \ 5'.-o..,.J/'IS"",-'\L I/o. '7$- 8 b(' c:,,; ~rop E"ldencefi Found 0 ReCQVtHt~d 0 CJ:i11 Found or recovered from bdOO CClf'\~ S\..e LocatIon . ~le LeT '-j08 (h hh 1) 2 ) 3 ) 4) 5 ) 6 ) 7) a) 9 ) 10) 11) 12) 13) 14) 15) 16) 17) i Bj Owner's name: : hereby certify I am the owner of above property or authorized agent to receive the same. No. It Oalc found/recovered Seon S "" :n- \2e :-\-L- CustodlllJ/rl]Cclvlng oUicer: sy ~y~ Idc.."",~ .) I \ "" '-----.-.-/ , DATE ITEM NOs. OFFICER'S SIGNA,TURE Owner's address Claimant's signature: Addross: EXHIBIT A Date at custody: d -;)3-95 \ c.Je"........,.-T St;k ,. I PURPOSE Dato clolmod: d -;)3-';S ..._...._~._--_.. .... TRACY MILLER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, SEAN E. SMITH 95-0866 CIVIL TERM ORDER OF COURT AND NOW, this 9th day of February, 1999, the protection from abuse order entered in the within case having expired by operation of law, the Sheriff is released from his obligation to retain possession of weapons, See 23 Pa.C.S. S 6108(d). For the purposes of this order, the Sheriff is authorized to relurn any weapons of defend",nt to him. Joan Carey, Esquire For Plaintiff .. , . \. "- Edgar B. Bayley, \. ". I Sean E, Smith, Pro se 103 November Drive, Apt #2 Camp Hill, PA 17011 Victim Wilness Sheriff :saa EXHIBIT C CAROL DA WN IIARRIS : IN Till.: ('01 iRT ()F ('( )~I\H)N PI.I,AS : CllMIlERI.AND cot i~ IY. P!:NNSYI.VANIA v. SEAN SMITlI : NO: <)(',4575 and 'UJ-I';:1') AND NANCY BENDER : PIWTEClION FROM AIlI is!: v. SEAN SMITH CERTIFICATE OF SERVICE ..--. AND NOW,this dli'(l.-.dayof (/)CdV.,C,;\_i,\ .2002, I. Aimcc L. Paukovits, V CJ for thc Law firm of KRI'VSK Y & ROSEN. P.C on hchalr or Dclcndanl. SEAN SI'vIlTlI herehy ccrtify that I havc this day scrved a copy orthe forcgoing Pctition in thc ahovc-captioncd maUer. by First Class U.S. Mail on thc following: CUMBERLAND COUNTY SHERIFF CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE. PA 1701) n\r~r,c .-J \-1}n~~.tj Aimce- L. I'(,ukovits II () I North Front Strcet Harrisburg. PAl 71 02 (717) 2:14-4583 I