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Home My WebLink About97-02216 4::t- o . ~ g It ~ .:f '1 ~ .~ ... o \.. cJ \l ~~ ~'l: " ~ ~\ / , if ii - . ~ :> .. - ri =) 0-, . ~ I :!l ~ ~ ... z is ... II. o :c I o ~ o u I- Z w :E l- e::: < 0- W C w U Z < e::: ::::> (J) z - 111!IJ I J! · '" ~~.i~ ,.s J j .5 ,~ oS i 11 i I ~ l.r; 1 .8 r 8 .!l I 8 oS 1 .!j i 1 j ~ .;' 1. .. 1 s .~ a. i t ~"'tS ~ a 1 g! i 1 ~ 1 ~ ~a:,.:l :s.... ~ Q e '~ a S .:! ~ " ~ I a!f ~ ~ c...l ":i c:: " Q . .:j 0: ~ '" ~ :s ~l ~ ~ .: 0- p.,:, : ~ :j '0 ; Z I o:::a c: C! 0' d e .Q .~ ... ui ~ g :3 ~ -5 ~l ti U "t:I 0- UI tl .:j Ii ~ :'il .... os ! a:: ~ .5 i ~ e 51! ~ to "'l l .~ zl I f: .~. t70 ..... . ~ -. ~ I a.," .....a 0 0' I ~ \I... u: :;:: !! I" .9 OS ~I ~.~ a 1&,1 Ill! a ~ ~ <, a;1 - S en' tnI .9 tit S' Ii '" il a 1io1:~ S ~ ..... s o . " a ~l'~ h a 6 .~ ~ ~ ~ .; 1i Q e .3 '" ~ .s ~o-.s~' , t t:o-o- .;j~ a8~t' - t1 ... "" 04 "'t;S . .~ ~ ... !t "" a :-::- S! ~ . ~ .... 1: .. ..... .5 9~:J~u~ ..s....~()"5~ "I (71. (71 .., , , -I .., ...! .,., 1.1 ~l , .. 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($) EU_ _co- SAFECO INSURANCE COMPANY OF AMERICA FINANCIAL STATEMENT - DECEMBER 31, 1996 A..... CaJh and Oank Depa.lI. ..,..""""""....",..,..',,'..,..' S .Bonds - U.S. Government ""."........."............... U.bIllU.. Unearned Premium. ......"..........,......,..................... Reserve ror Claim. and Claims E.pense......,......... Fund. Held Under Reinlurance Treaties ..'............. Relerve ror Dividend. 10 Pollcyholden ....'............ Addilional Slalulory Reserve ..""..,.....,......,..,......., Reserve ror Commissions. Tues and Other Uabilllles ..'"'..,'..'..",,...,..........,...,..,....... $ 471.503.744 1,036.499,079 3.556.704 8.158.294 ~ (57.280.251 ) 110.861.390 1.747.154.785 584.520.644 41.645.402 212,467.867 41.616.030 61.941.787 -Other BondJ ......'".."",.."""",...,'..'"...."""..'""", - Slocks ..'..".., ,...", ",',',',' '..,.. ..""" """ ,'....'.."..'.. ".. Real ESlalC ....""" "...."" ..,..', ,'.... ..,.." '" "'" .....,..,'.. A8enll' Bllanc.. or Uncollecled Premlum. ,......' Accrued Inlerelland Kenls ..,....,....'....'.."..,..,..,... Olher Admlned A..ell ,...,'....",.."",..,'....,...."..,.., 155.581.449 $1,675.299.270 , Total .........................................H.............._.... S 5.000.000 11.139.941 1 ,05 1 ,488.443 Capital Stock """,..'....""",.....'.. Paid in Surplu. ",..",................." Una..isned Surplu. ,............".... SurplUJ 10 PoUcyhold'tI .......................... 1.067.628,384 Total L1lbI1lU.. Ind SurpIUl............................ $2,742,917,654 ~ . Bonds are Italed at amortized or investment value; Slocks at Association Market Values. Securities carried al 5128.610.937 are depasiled.. required by law, I. PHILIP A, STEPHENS, seolor vice president orSAFECO Insurance Company or America. do hereby certiry Ihallhe rore80ing is Ilrue. and correcl Slelemenl orthe Asselland Uabilitlel oraaid Corporallon. as or December 3 I. 1996.10 Ihe be.l or my knowled8e and belier. IN WITNESS WHEREOF, 1 have hereunlo sel my hand and am.cd the seal oraaid Corporallon al Sealtie. Walhlnglon.lhis Isl day or March. 1997. I~~~IC~ Senior Vice Pre.ldenl 8-12Si1:W7 . RIgi_1'd badlmllll 01 SAFECO CotpoilllOn. IVo. q '7 - d;:} 'CLJ C...;,...;.D \\!Afl\ r' rrcc~rr- "'\.' ,. ,~... /"." 'roo' ',"..'\-.~y l..;' . :,.'.1, In f ",', 7i .: ;. 11 .,.. ..... I.. I." 1, ,94' c" r'~i\. i:,','." -:,,-\ .$] ;.copd S~\?Qo rn~,Co. , c.utll~S9 Rtl5141.l'i! - \, . . .~ I . . . , . ~ t " " ' . . vs. Edward L. Benton, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-2261 CIVIL TERM Tami Jo Benton, Plaintiff PROTECTION FROM ABUSE ANO NOW, this RXIKNSION ~~~ OF PROTECTIO~ROKB day of April, 1998, upon presentation and consideration of the within petition and upon finding that the defendant, Edward L. Benton, has engaged in a pattern or practice that indicates continued risk of harm to the plaintiff, Tami Jo Benton, the following Order is entered: The Temporary Protection Order shall be extended beyond the expiration date of May 1, 1997, as continued by the Orders of May 7, 1997, and August 1, 1997, such that it remains in effect for one year or until further Order of Court. A violation of this Order may sUbject the defendant to: i) arrest under 23 Pa.C.S. 66113; ii) a private criminal complaint under 23 Pa.C.S. 66113.1; iii) a charge of indirect criminal contempt under 23 Pa.C.S. 66114, 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. 66114.1. Resumption of co-residence on the part of the plaintiff and defendant shall not nullify the provisions of the court order. The defendant is ordered to relinquish to the sheriff's department any weapons which he owns, possesses, has used or threatened to use in an incident of abuse against the plaintiff. The defendant is prohibited from acquiring or possessing any other weapons for the duration of the Order and is requirad to relinquish to the sheriff any firearm license the defendant may possess. The defendant's weapons and firearm license may be returned at the expiration of the Protection Order after the defendant has submitted a written request to the court for the return of the weapons and the Court has notified the plaintiff of the request and given the plaintiff an opportunity to respond. A copy of this Order shall be transmitted to the chief or head of the Pennsylvania State Police Department and the sheriff of Cumberland County. A hearing shall be held on this matter on the 'l tJ) day of 'J )lLC<j , 1998, at .'1'. (,' '\ .m., in Courtroom No. ---1--, (/ Cumberland County Courthouse, Carlisle, Pennsylvania. The plaintiff may proceed without pre-payment of fees pending a further order after the hearing. The Cumberland County Sheriff's Department shall attempt to make service at the plaintiff's request and without pre-payment of fees, but service may be accomplished under any applicable rule of Civil Procedure. This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service. The Prothonotary shall not send a copy of this Order to the defendant by mail. The Pennsylvania Stdte Police Department will be provided with a certified copy of this Order by the plaintiff's attorney. This Order shall be enforced by any law enforcement agency where a violation occurs by arrest for indirect criminal contempt without warrant upon probable cause that this Order has been r:l; "'i ~ '}Y '1 ~ .. J 'I * , '''' .... 'i- ., Tami Jo Benton, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-2261 CIVIL TERM VB. Edward L. Benton, Defendant PROTECTION FROM ABUSE NOTICE You have been sued in court. If you wish to defend against the cialms set forth in the following pages, you must take action promptly after this Petition. Order and Notice are served, by appearing personally or by attorney at the hearing scheduled by the Court and presenting to the Court your defenses or objections to the claims set forth against you. You nre warned that if you fail to do so the Court may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Petition or for any other clnim or relief requested by the plaintiff. You may lose money or property or other rights important to you. Any Protection Order granted by a Court may be considered in any subsequent domestic relations proceedings, including custody actions. FEES AND COSTS If the case goes to hearing and the judge grants a Protection Order, a surcharge of $25.00 wil I be assessed against you. You may also be required to pay up to $250.00 to reimburse one of Legal Services, Inc. 's funding sources for Legal Services Inc. 's representation of the plaintiff. You have the right to be represented by counsel. You should take this paper to your lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIAERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMAER: (717) 249-3166 or TOLL FREE: 1-800-990-9108 FAX: (717) 249-2663 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, piease contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Tllmi Jo Benton. Plaintiff I N TilE COURT OF COMMON PI.EAS OF CUMBERLAND COUNTY. PENNSYLVANIA va. Edward L. Benton. Oefendant NO. 97-2261 CIVIL TERM PROTECTION FROM ABUSE PETITION FOR P.XTENSION 0F TilE PETITION FOR PROTECTION FRQM ABUSE 23 Pa.C.S. 86108(e) The plllintiff, Tami Jo Benton. by and through her attorney, Joan Carey, of Legal Services, Inc., states the following: I. The pllllntlff filed II Petition for a Protection Order on May I. 1997, and a Temporary Protect inn Order was entered on May I, 1997. 2. The defendant fi led II Mot Ion for Cont inuance because he would not be in the nren due to his work. On May 7, i997, thia Court entered nn Order resehedul ing the heuring to August 4. 1997 . J. On August I, 1997, the plllintiff's llltorney at that time, Lee E. Oesterl ing, sent this Court It leller asking that the hearing scheduled for August I. 1997. be generally continued pending either II mutually agreed upon hearing date or an agreement rellched by the purties. 4. The plaintiff requests nn Extension of the Protection Order for reasons inclUding, but not I im! ted to, the following: II. On July 10, 1997. the defendllnt was found gui Ity of Indirect Criminal Contempt for violation of th~ T~mporary Protection from Abuse Ord~r entered on MIlY I, 1997, IInd WIIS s~nt~nced to PIlY the cost of prosecution and any fees provided for under the Protection from Abuse Act, and to undergo imprisonment in the Cumberland County Prison for 11 period of not less than 48 hours Ilnd not more than 6 months. The basis of the finding was harassment and threatening the plaintiff inclUding a threat to "stop her with a bullet." See Contempt Order and Order of Court charging the defendant attached as Exhibit A and incorporated herein by reference. b. On September 29, 1997, the defendant was found guilty of Indirect Criminal Contempt II second time for violating the Temporary Protection from Abuse Order entered on MIlY 1,1997. The defendant was sentenced to imprisonment for ten days. The basis of the finding included harllssment of the plaintiff, including following her without proper Iluthorization and coming to her place of employment. See Contempt Order and Order of Court charging the defendllnt attached as Exhibit B and incorporllt~d herein by r~ference. c. On April 14, 1998, the defendant appeared before Judge J. Wesley Oler, Jr. on a criminal charge of slalking the plaintiff, Tami Jo Renton pursuant to IS Pa. C.S. Section 2708(b). The defendant plea,l nolo contend~re and was sentenced to 30 days to 23 months with immediate parole which included a provision that he have no contact with the plaintiff. The basis for the charge Is Included in the probable cause affidavit attached as Exhibit C incorporated herein by reference. 5. The plaintiff desires that any weapons the defendant owns, possesses, and has used or threatened to use against the plaintiff be confiscated by the sheriff's Department. 6. Jacqueline M. Verney, attorney of record for the defendant, was notified of the filing of this petition. Ms. Verney Informed Legal Services, Inc. that she no longer represents the defendant and that we should serve him directly with this Order and Petition for Extension of the Protection Order. WHEREFORE, the plaintiff asks that the Temporary Protection Order dated May I, 1997, as continued by the Orders of May 7, 1997, and August 1, 1997, be extended beyond the expiration date of May I, 1998, such that it remains in effect for one year or until further Order of Court. Additionally, the plaintiff requests that the Court order the defendant to relinquish to the sheriff's department any weapons which he owns, possesses or hus used or tbreatened to use against the plaintiff and that the Court prohibit the defendant from acquiring or possessing any other weapons for the duration of the order. The plaintiff further requests any other relief which is just and proper. Respectfully submitted, ~@~~ jJoiln Carey Attorney for Plaintiff Legal Services, Inc. B Irvine Row Carlisle, PA 17013 (717) 243-9400 TAMI JO BENTON, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLANO COUNTY, PENNSYLVANIA v. '. EOWARD L. BENTON, Defendant 97-2261 CIVIL TERM IN RE I SENTENCE ORDER OF COURT AND NOW, this loth day of July, 1997, the Defendant, Edward L. Benton, now appearing in court with his privately retained counsel, Jacqueline M. Verney, Esquire, for sentence, and having previously been found guilty of indirect criminal contempt as the result of a violation of a Temporary Protection from Abuse Order, the sentence of the Court is that the defendant pay the costs of prosecution and any fees provided for under the Protection from Abuse Act, and that he undergo imprisonment in the Cumberland county Prison for a period of not less than 48 hours nor more than 6 months. Conditioned upon the Defendant's good behavior while in prison, and conditioned further upon his being and remaining on good behavior and complying with all written directions of his parole officer, he shall be automatically paroled at the expiration of his minimum I I f I sentence of 48 hours, By the court, J~ A. Abom, Esquire ~~istant District Attornoy Jacqueline M. Verney, Esquire Counsel for Defendant :lkt EXHIBIT A - TAMI JO BENTON, I IN THE COURT OF COMMON PLEAS OF plaintitt I CUHBERLANO COUNTY, PENNSYLVANIA I '; V. I EOWARO L. BENTON, I Detendant . 97-2261 CIVIL TERM . IN REI INOIRECT CRIHINAL CONTEMPT OROER OF COURT ANO NOW, this loth day ot July, 1997, upon consideration ot the petition and complaint tor indirect criminal contempt tiled in the above matter and tOllowinq a trial at which the detendant was represented by Jacqueline H. Verney, Esquire, and the Commonwealth was represented by John A. Abom, Esquire, the Court tinds the defendant guilty of indirect criminal contempt. By the court, , ~.,., J , .... .."!.' 1,":1 . '. ~ E ' li~:, ...-t . J n A. Abom, EsqUire" '~-.' ,~.. sistant Dietriot Attorney cracqueline H. Verney, Esquire Counsel tor Defendant Shariff :lkt T AMI 10 BENTON, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 97-2261 CIVIL EDWARD L. BENTON, Defendant : CHARGE: INDIRECT CRIMINAL CONTEMPT ORDER OF COURT AND NOW, this 3rd day of July, 1997, this Court certifies that the attached complaint has been properly completed and verified, and there is probable cause for the issuance of process, In consideration of the attached Commonwealth's Petition, the defendant, EDW ARC L. BENTON, is directed to appear for trial on the charge of Indirect Criminal Contempt before the Court on the 10lh day ofJuly, 1997 at 8:30 o'clock a.m. in Courtroom # 5 of the Cumberland County Courthouse, Carlisle, Pennsylvania. The defendant has a right to be represented by an attorney, If the defendant cannot afford an attorney, upon request one will be assigned to represent the defendant. If the defendant wishes assignment of counsel, contact should be made prior to trial with the Cumberland County Public Defender's Office at 717-240-6285, Further, if the defendant fails to appear, an arrest warrant will be issued. The Sheriff of Cumberland County is directed to serve this Order and Petition upon the defendant. The assessment of costs to be detennined by the Trial Judge subsequent to trial, By the Court. J 10hn A. Abom Assistant District Attorney .!L...< e~ I. AJ./J, EDW ARC L. BENTON T AMI JO BENTON, Plaintiff IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA V. : 97-2261 CIVIL EDWARD L. BENTON, Defendant : CHARGE: INDIRECT CRIMINAL CONTEMPT COMMONWEALTH'S PETITION FOR A HEARING ON C}JARGES OF INDIRECT CRIMINAL CONTEMPT John A. Abom, Assistant District Attorney, Cumberland County, PCMsylvania, brings the following Petition for a hearing on charges ofIndirect Criminal Contempt: 1. A Protection from Abuse Order was issued by the Court. A true and correct copy of the Order is attached. 2. The defendant's violation of this Order is averred in the attached criminal complaint. 3. The victim requests the filing of an Indirect Criminal Contempt Charge upon infonnation received. 4. The District Attorney's Office approves the filing ofthis criminal complaint. S. The Commonwealth is requesting a hearing on the charges of Indirect Criminal Contempt pursuant to 23 Pa.C.S.A. ~ 6113. 6. The plaintiff and/or the defendant may seek modification of the Order based on the filing of this petition as the Court deems appropriate following the trial in addition to any other sentence. 23 Pa.C.S.A. ~6113. WHEREFORE, the Commonwealth requests the defendant be commanded to appear before the Court on the charge ofIndirect Criminal Contempt. Respectfully submitted, '-.~ {I/ b ohn A, Abom'7 ' Assistant District Attorney ~ COMMONWEAL TIl OF PENNSYL V MIlA COUNTY,OF CtlMBERLAND *' POLICE CRIMINAL COMPLAINT .........., IU_ _ COMMONWEALTH OF PENNSYLVANIA __ CUMBERLAND COUNTY COURTIIOUSE CARLISLE, PA COMMONWEALTH OF PENNSYLVANIA ... ,""""AIm "AMI'" ADDUII T_ DodtCl N.,: 0aIa Filed: OTN: EDWARD L BENTON, JR. 51 SPRING GARDEN ESTATES C.r1IsIe, PA 17013 (717) 141-5516 om...... Se. 0."......'. SodaI N...... DeI,lId..... SID F_ 409011668 U..-... Milo ~.uLA. DdeMaM'. V......... .. -- YX61410 PA C~_N- C_N-.110IMr...-- 97-$13 97.09411 OiltriCl AUOmoy', Offic. 0 App"",. 0 D/uppN-' 6_",r. cne Dltcricl Atto...y allY nqv.lrt lhIl.be complaiat. uml warrut .mdayit. or bodt b. approy.d by the .\llGns,y rot lb, Commo.wl.lda prior to nUa.. p..ItCr,'. 107.) ~ollt....., for ",,",,.__~.w.. n-e Pr*or trplJ l~ofA*'""7krC _....) (-, I, Dalal.. Ut/tUl /l. W..if'N 4,., _ol..lIIIa&.P1aM_..r)'pO OftIcotBodpN_1.D, OP CuIlllNrl..i C...IV DUtrlcl Alt.",.,'. Offlu CID U./J PA01101JA 141DQty DcpuUIIIDI or A.ncy ~ &ad Pollcical $ubdMIioa PolKt ApDCY OR! N....... OriliAaciq AJCIIICY CuI Nuatba (DCA) do heRby ,tate: (dod IIppropr/o,..,..,) \. 181 IICCUJll the above named derendant, who liv.. at the addras let ronh above or, o IICCUJll the derendant who.. name in unknown 10 me bur i. deacribed u o IICCIIICl the derendant who.. name and popular d..ignation or nickname i. unknown to me and whom I have th...r., d..ignl!ed u John Doe. with violatins Ihe penal law, orth. Commonwealth orPmn.ylvanil at Gift, F.....IJS S. Sprilf, Gan1411 S_ Cu/JJ/, in C.MlII1Ie.i C..." on or about 06-17.'76_.. 1130..i 1300 It.un, Panicipllltl wen:: (11_ won putlcipooll. pIKe _...... hon. ........... .1 above dot/.-u BDWAJID L. lENTON, J/l. 2. The KlI cononiUed by the accused were: (S.'ri.~ "'..,.....,...10........,.... 01....... DlthlolT_ dr.wpd. A ciQDCIlao............,............... illCII....... 1a.~~ ,.-- ....IM_.......oI.._OI~.."PdI,wM.....) INDIRECf CRIMINAL CONTEMPT - 2J Pa, C.S.A. Section 6113 The defendam did violate Temporary Prolection Order No. 97-2261 Civil Tenn signed by the Honorable Judge Wesley Oler, Jr. on 1 May 1997. Temporary Prote~tion Order No. 97.2261 states that the defendant is ordered to refrain from having any direct or indirect contact with the plaintiff including, but not limited 10, telephone and written communications. and to refrain from harassing and stalking the plaintiff. In that the defendant did harass intentionally harass and have direct contact with the plaintiff in a public place. 11\ or which wen: IsainJllhe pc..e and dignity oCthe Commonwealth or Penn.ylvanll and contrary 10 the ACI of Auembly. or in violalion or: t, 6/1J ,......., orlhe n,Ie1J Pa, CSA, ,UI*'*I (C"-I (s.."".... Defendant Name: HOWARD L. BENTON. JIL *' Docket Number. 1. of the -. ,_. J. ohhe ,_, (_, 4. of the _, ,_. 5. of the -. (_. POLlCE CRIMINAL COMPLAINT (fA~l (c.... ,rA k*SIl IC_ trAit.... ,C_ (r".~. IC_ J. I uk tIIII 0 _ _at ./_"..., or 1m _ ......... be iuued and thll the defendanl be required 10 answer the chilli" I hive made, (In onIer fot I _I of umt 10 iau.. thell1lChed a/lidavil of probable CIUJC musl be compleled and &Wom 10 befo~ the ilJuing IUthorilY,) 4. I verify tIIIIchI f..1I111 foM in thil complainl are trUe and co=110 the bat of my knowledge or lnformalion and bellaf. 11Iil verification is made subjecllO chi penalties ofSoction 4904 of the Crimes Code (18 PA. C.S. 4904) "'atlng 1 nswom falJifications 10 authoritlca. ~l AND NOW, on 1hI1 dale . I certify Iha complainl hu been properly completed and verified. An .mdavil of probable CIUIC mull be complCled in onIer for I warranl to laua. 1....._ Dlo_' tin.... ".&MrifJ) (SIALI 2 AFFIDAVIT OF PROBABLE CAUSE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMPLAINT NUMBER YEAR TYPE NUMBER COmplainl Numbel1 if Other Participants INCIDENT NUMBER 97-513 UCR NO. 260 OTN COMMONWEALm OF PENNSYLVANIA OEFENDANT: VS. I. Detectin Letitia Woodford (N1IIIIl of Affianl) NAME AND ADORESS EDWARD L. BENTON, JR. 52 Spring Garden Eslllel CarliJle, PA 17013 ,f Cumberland County District Attorney', Omee cm Unll (Identify deputmc1lt or Isency tepflSenled and political subdivuion) being duly swom (or affirmed) before me, accordinsto law, deposes and says thaI there u problble cause 10 believe thac PROBABLE CAUSE BEUEF IS BASEO ON TIlE FOLLOWING FACTS AND CURCUMSTANCES: Thia affianl is a Oeteetive with the Cwnberland County Districl Allomey's Offi~e, Criminal Investigation Division and bas been employed as such for the pul 6 montha. " On I May 1997, the Honorable Wesley Oler, Jr" Judse did sign a Temporary Protection Order No. 97-2261 Civil TenD, for plaintiffTami Jo Benlon and defendant, Edward L. Benton. Edward Benton was served with this Temporary Protection OnIer on I May 1997111336 houn by Deputy Sherriff. Michael Banick. Temporary Protection Order No. 97.2261 specifically .tales thaI the defendant is ordered 10 refrain from having any direcl or indirect conlaCl with the plaintiff includinS. bUI nollimiled 10, lelephone and written communications, and is 10 refrain from harassing and llaIklng the plaintiff. From ltatements received from the pllintiff, and verified lhroush an eye wible... the defendant, Edward Benlon did harass and threaten the plaintiff in a public place in the presence of their minnr child. The incident occurred II Giant Foods loclted at 25' S. Spring Garden Slreet, Carlisle, PA 17013 on 27 June 1997 at or about 2230 houn. The plaintiff wu ltanding at the resister pun:hasing several items, when the defendanl approached the plaintiff from behlnd and began making disparaSing remarks aboul the plaintiff. in her presence, to individuals in the immediate area of the plaintiff. The defendant, Edward Benton did then follow the plaintiff oul of the GianI Foods to the puking area and further Iwassed the plaintiffby Ipproaching the plaintiff al her vehicle. While holding their minor chUd, the defendanl made additional disparaging remarka directly 10 the plaintiff and threllened 10 stop the plaintiff with a bullet. In \ishl of the information stated above, this affiant respectfully requests the defendanl be commanded to Ippear before this CoWl on the charge of Indirect Criminal Contempt. 4-q~ ADDRESS OF PRlV ^ TE CITIZEN B^OOE NO. DISTRlCTIUNIT Swom 10 and subscribed before me this day of .19 (SEAL) (SiI"IIUN or IJluinl Authonty) DISTRICT JUSTICE COURT NO, OFFICE ^DDRESS: [)ate Commluion Expire.: Phone: . ' TAlII JO BENTON, I IN TBB. COURT 01' COMMON PLD. 01' plaintiff I CllMBBRLAND COtlNTY, PENNSYLVANIA I v. I 97-2261 CIVIL TERM I EDWARD L. BENTON, I CJlARQB I INDIRECT CRIMINAL De!endant I CONTEMl'T IN REI SENTENCING ORDER OJ' COURT AND NOW, tbis 29th day o! S.ptember, 1997, the De!endant, Edward L. Benton, now app.aring in court for sentence with his privately retained counael, Jacqueline H. Verney, .squire, and having previouely been found guilty following a nonjury trial o! Indirect Criminal Contempt witb respect to the Temporary Order o! Court entered Hay 1, 1997, the santance o! the Court i. that tbe De!endant pay the cost. o! pro.ecution, and eny surcbarge. and !ee. collectible under the Protection !rOlll Abuse Aot, and that be undergo imprisonment in the cumberland County Prison for a period o! tan days. It appearing that the De!andant bas served the terlll o! imprisonmant provided for berein, be i. ordered to be released witb re.pect to this charge. It i. noted that the De!andant is pre.ently in the cumberland County pri.on awaiting trial on other charge.. By the Court, J John A. AbOlll, .squire Assistant District Attorney . ~ /0/1/91. ". CLft, ...0. 'f'. Jacqueline M. Verney, lequire Counsel for De!endant Sberi!! CCP EXHIBIT B :slr - i r TAlII JO BENTON, I Df TBB. COURT 01' COJOCON PLD. 01' plaintiff I CtJICBBRL>>lD COtlNTY, PBNNSYLVANIA I v. I 97-2261 CIVIL TERM I EDWARD L. BENTON, I CBAJlQB I INDIRBCT CRIMINAL De!andant I CONTDll'T IN RBI DEI'BNDANT rOtJHD atnLTY 01' INDIRBCT CRIMINAL CONTBKPT ORDER 01' COURT AND NOW, this 29th day o! September, 1997, upon consideration o! the complaint in the above-captioned matter charging Indirect Criminal Contempt, end following a nonjury trial held on this date, the Court finds the Defendant guilty o! Indirect Criminal Contempt for violation o! the Temporary Protection !rom Abuse Order entered on Hay 1, 1997. By the Court, J John A. Abom, .Iquire Assistant District Attorney ,- Jacqueline H. Verney, Isquire COUD~el for De!andant ~ 4'~ IO),j~1. Sheriff CCP Islr TAMI JO BENTON, Plaintiff, : IN mE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY. PENNSYLVANIA : NO, 97.2261 CIVIL TERM V. EDWARD L. BENTON, Defendant : CHARGE: INDIRECT CRIMINAL CONTEMPT ORDER OF COURT AND NOW, this I Silo day of September, 1997, this Court certifies that the attached complaint has been properly completed and verified, and there is probable cause for this issuance for process. In consideration of the attached Commonwealth's Petition, a WARRANT IS ISSUED FOR TIlE ARREST of the Defendant, EDWARD L. BENTON. If the defendant is found during nonnal Courthouse hours, the defendant is to be brought immediately before the Court, If not found during Courthouse hours, the defendant is to be taken to the on-<:all District Justice and bail set pursuant to the Rules of Criminal Procedure. Furthermore, after appearing before the District Justice the defendant is advised to appear before the Court Administrator at the open of the next business day. Defendant has a right to be represented by an attorney, If the defendant cannot afford an attorney, upon request one will be assigned to represent the defendant. The assessment of costs to be detennined by the Trial Judge subsequent to trial, By the Court, John A. Abom Assistant District Attorney Jacqueline M. Verney, Esquire For the Defendant EDWARD L, BENTON . J. TAM! 10 BENTON, Plaintiff, : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PEl'INSYL V ANlA : NO. 97-2261 CIVIL TERM v. EDWARD L. BENTON, Defendant : CHARGE: INDIRECT CRIMINAL CONTEMPT COMMONWEALTH'S PETITION FOR HEARING ON CHARGES OF INDIRECT CRIMINAL COJIJTEMPT John A. Abom, Assistant District Attorney of Cumberland COWlty, Pennsylvania, brings the following Petition for a hcarlng on charges of Indirect Criminal Contempt: 1. A Temporary Protection from Abuse Order was issued by the Court, against the defendant, on I Ma~' 1997. A true and correct copy of the Order is attached. 2. The defendant's violation of this Order is averred in the attached criminal complaint. 3. The victim requests the filing of an Indirect Criminal Contempt Charge upon information received. 4. The District Attorney's Office approves the filing of this criminal complaint. S. The Commonwealth is requesting a hearing on the charges of Indirect Criminal Contempt pursuant to 23 Pa. C.S.A. ~ 6114, 6. The plaintiff and/or the defendant may seek modification of the Order based on the filing of this petition as the Court deems appropriate following the trial in addition to any other sentence. 23 Pa. C.S,A. ~ 6114, WHEREFORE, the Commonwealth requests the defendant be commanded to appear before the Court on the charge of Indirect Criminal Contempt. Respectfully submitted, I ~ ... Defeadlal Nune: row ARD L BENTON, Jll *' O:lckd NIIIIlber. J. of die 1-' -, 4- of die I_I - 5. ordle _I - POLICE CRIMINAL COMPLAINT "A..... ~ 1'0- 1"- I"'..... IC_ J. J uk1hlt 181 . _, ,/_ or 0 . ,._,.. be iuued IIIlI dlII the derendant be required to lIlSWor the elw1ul hAve mad.. (In onIer ror. _lor anal 10 lIIuc, the allKhed aIIIdavit ofpobebla ""'" mull ba c:ompleaed 1IIlI1W0III1O before the iauln, autborily.) 4, I verify 1hIt the r_ lei rorth in this c:omplainllll rru.1Illi comet 10 die baa or my knowledge or infonnatiOllIllli bailer. This verlfteaalOll is nU NbjlCl 10 the pcnalti.. orScction 4904 orth. Crimea Coda (18 PA. C.S. 49(4) ..WinIIO WlIWOIII ralsiftearionllO authorill... ~I ,;::-\~~- AND NOW. on thl. dalG . J cenify the c:omplaint hu baat paopcrly c:ompleaed IIlli verlftcd. An aftIdavil of probabla eatIII mull ba c:ompleled in order ror . WIITIIlIIO iaue. (... J W DWrtd) (......_1 \llAL1 2 . . A1'FIDA vrr OP PROBABLE CAUSE COURT or COMMON PLEAS OF CUMBERLAND coUNTY COMPLAINT NUMBER YEAR TYPE NUMBER Complaint Numbers if Other ParticipantJ INCIDENT NUMBER 97-7t7 UCR NO. 260 OTN COMMONWEALTH OF PENNSYLV AN1A DEFENDANT: VS. I. Detectlvl Ltdda Woodford (Name of Affiant) NAME AND ADDRJ!SS EDWARD L. BENTON, JR.. '2 Spring Oarden Eall~a Carlisle, PA t7013 of Cumberland County Dbtrlet Attoraly'a Orne.. Crlmlnlllnnsllllllon D1v1a1on (IdeDtify departmellt or Igeoey repreaeDtcd and polilicalaubdiviaion) being duly Iwom (or affumed) before me, lCCordlng to law. deposes and lay. that there it probabt. .aUla to bellev. that: PROBABLE CAUSE BELIEP IS BASED ON mE FOLLOWING PACfS AND CURCUMSTANCES: This afflant Is a Detective with the Cumberland County District Attomey's Offlce, Crlmlnallnvestigation Division and ha. been employed a. such for the past 8 months, On 1 May 1997, the Honorable J, Wesley Oler, Jr., Judge did sign e Temporary ProtecUon Order No. 97.2281 Civil Term, for plaintiff Teml Jo Benton and defendant, Edward L, Benton. Edwerd Benton was served with the Temporary ProtecUon Ordtlf' on 1 May 1997 a11338 haul'll by Deputy Sherriff, Mlcheel Barrick, Temporary Protectlon Order No. 97.2281 speclflc8l1y states thllt the defendant Is ordered to refrain from having any direct or indirect contact with the plaintiff Including, but not limited to, telephone and writtan communlcetions. and Is to refrain from harassing the plelntlff. From statements received from the plaintiff, and further verifled through (2) two eye witness, tha defendant, Edward Benton did have Indirect contact with the plaintiff on 5 September 1997 at her place of ~ employment, Edward Benton pulled Into the front parking lot of 375 Claremont Drive, The Claremont NUl'lllng and Rehabilitative Center of Cumberland County, where the plaintiff Is employed; Edward Banton then approached a female employee of the home and requested her to deliver some flowei'll to the plelntlff Inside the home. This Incldent wee also witnessed by e County Security Offlcer. Included with the flowei'll was a card with the following message written In the defendanfs handwriting: 'Remember when these meant something good? If you ever truly loved me you will remember that there were a lot of good times. They can be gotten back. It cen be that way egaln If you ever loved and wanted love. you'd know I hope you think about It. I also hope you arent so eaten up with hate and anger that you cant see the truth. But Its up to you, I will always love you no matter what happens or what you might want to believe." A copy of this card Is attached to the effldavlt and labeled es 'Exhlblt 1', On 9 September 1997, as the plaintiff was driving with her minor child In ~ the car, the defendant did pull up beside the plaintiff at the Int~l'lIectlon of W, High Street and North Hanover Street, both partlea were trevellng east on W. High Street. The defendant did pull along the passenger side of the plaintiff's vehicle, the plaintiff looked over et the defandant and noticed the defendant holding a cemera and pointing It In the direction of the plaintiff. The plaintiff then tumed left onto N, East Street and noticed the defendent had continued to travel east on High Street. Momanta later the plaintiff again noticed the defendanfs VI/hide behind hera, The defendant then pulled along the drtvel'll side of the plaintiff'S vehicle and loudly yelled et the plaintiff, "You're a fucking ugly bitch," laughed end pulled directly In front of the plalnUff's vehicle and drove at an excessively slow speed, In en attempt to further harass the plaintiff. In light of the Information stated above, this affiant respectfully requests the defendant be commanded to appeer before this Court on the charge of Indirect Crlmlnal Contempt. c cclfJ t.; IlAlXlE NO. '-\1 DISTRlCTIUNIT ADORESS OF PRIVATE CITIZEN 'y. ~(' . \/l { .j tv4 ~~' '\ . --z-~! Jt · 1d'L ~ ;,J;:{. Mtt~ .. ....\lt7u~#;;:.~ ~~ (:gj'j':;;~\"1) .l'~W.&~ v ".~I~~Jt;;~if ...."~~M ~~.J<<~ ' l~~UfZ~_ )\" , . , . ',' I i (- , - _/ .\ .-:.\ .\ \. ::'l';~' '. . , ",' .' ". . ... ...: ,',," .:' :, " ',f'; ::?1 .:.;:. .' ",. .... -. j()~ /~-77 @ ~: 30PI'Y{ '*' POLICE CRIMINAL COMPLAINT COMMONWEAL m 01' I'ENNSYL VANIA COUNTY 01' CUMDERI.AND .......... 0901-0 I DJ._ _ PAULAP,CORREAL _ ONE COURTHOUSE SQUARE, EAST WING CARLISLE, PA 110IJ T_ 140-6566 DockCI No.: CR-465-97 Olleflled: 9/19/97 OTN: P 068693-2 COMMONWEALTH OF PENNSYLVANIA v~ DIRl'llDAKrI "AMI'" ADDIW lOW AJID L. BENTON, JR. 51 SPRING GARDEN ESTATES CARLISLE PENNSYLVANIA 17013 717-141-5516 ""'" N.ti~ Anrican Dtfc......'. D.O... 01-/J-J8 DtIttMl...., s.c'" Senrf N..bu Ud.H..I', SID 409,01-1668 i f De"""''' ...K.A. RtPtr....Sdc.ker 8-98 C"",-,_N_ 91-1/1 OIIUi.. AUomey'. Office a App....., a Db.pp...,1I b,."u." (T'" DlIIricl AIIDmIJ mlJ nq.ln duillb. comfllainl. ,""I WI"'IlI.mcla~il. orbatll b. approved by lb. Auomey ror dtt Commonwealth prior to fill.l_ " R.C"P, 101.) ,...... of ,...., .. .. (' ............"..Tnwl (~oIA-., rorc___._w.4hll) I""" D,t<<ll.. L,l/tw R, ",..lIr.NI NamI or AfILuI. ,Icut PriM or T)1lI OF Cu",bm.d Cn.tv DI.trlct AIt.mq', OU/<<, C'I"'I..II....tlll.tI.. Dlvlal." PA01l0/JA l~o.pom."'.._~...sPoliIicalSubdi'""'" PoI..........0IUN...- do heRby .late: (c.\<<. ~"'. ""'.) I. 181 I accuse the above nuned derendanl, who liv.. ., the address"l rorth above or, a 1 acc... the defendant who.. name in unknown 10 me bUI i. d...,ribed u a I accuse Ihe der.ndanl who.e name and popular dOlignalion or nickname i. unknown 10 me and whom I havelh.reror d..ignaled u Sohn Doe, with viollling the pcnallaw. orlhe Commonwealth orPenn.ylvania at J1S CI.".....' DrI.., C.,IIsI. ..11 tho public ,...IIWGya./ C.,lbl. 6...u,lIln Cu",b,rI.nll C.ntyon oraboul S,pt.",b" S, 1991.nll Stpllmb" 9,1991. Participanll were: (lr &he"",, ptrdclpullJ. pIKe tbdr namct here. "UDJ IWI1t or lbo" dcrmdam) EDWARD L. BENTON, JIt 49-' ORk. s..... NIAlnbwfI.o. I, aria_liD, AJdCY C&M Nwnbtr (OCA) 2, The a.1I committed by Ihe accused were: (III'" .~"""'.mdeIiII.1ftiIe ...........alu.. .......,...oIT...dwpd. A ~ 10" .........,.--.......... ,.....nkkM- 1..-r~J"O'I"""Q" ......IM:............ 01...... or ___1IkpI, ~I STALKlNG .1/1 P,.. C.S. 61709(b) The derendant did enK"Ke In I coune of conduct Ind did reportedly commit Icll toward anolher penon wllh the Intent to pll.e the person In rellonable felr of bodily Injury or to Clu.e ,ub.lanUal emoUonal dbtrm to the penon. Vlellnr: TlmI Jo Benton Am: Sln.e Juue 1997 up to and IncJudinK Ihe pre.enl, Ihe derendanl b.. followed the vl.Um In and about Carlisle, followed the vl.Um from her pll.e of employment. haruaed vl.Um In publl. Ind relayed IhrealenlnK messlKes to the vl.llm IhrouKh their minor child after .cheduled vl.llaUon. all or which were againlllh. p.... and dignily or the Commonwealth or P.nn.ylvania and .onlrary 10 Ih. A.I or A...mbly, or in violation or: EXHIBIT C DeCendanl Name: EDWARD L. DENTON. JR. Docket Number. CR-465-91 *' POLICE CRIMINAL COMPLAINT (b)(l)(l) oClh. 711(.18 Pa, Crtm.. Cexl. I I'.......... tPAIt".... (e.....1 ofth. '........, trA........ 1(....&11 oClh. I_I (.A........ IC...ul oClh. I-' ('Altat.... Il...... oflh. ,-, t"'........ Ie...... 3. I uk Iha1I8I . 1M"." ,'.n..' or 0 .,...Ift'" be illued and Ihlllh. d.fr.ndanl b. required 10 answer Ih. chari" I have mad.. (In OIdet for a warranl of armllo IIIU.,lh. InlChed Imdlvll oCprobabl. cau.. mu,l be compl.led and .worn 10 beCore Ih. IlIulnllulhorily.) I verify Ihllth. faclJ... fol1h In Ihl, complalnl are 11110 and correcllo Ih. bell of my knowledg. or infoll1llllon and bellcf. Thl, v.rinclllon i, made ,ubJecllo Ih. penalll.. o(Sectlon 4904 ortho CrilllCl Cod. (18 PA. C.S. 4904) "Ialinllo unlwom fal,incaUons 10 aUlhoriU... ~IQ~~ (Sltut.n .rc;-.,......I) , I c'111 I e complalnl 4. \ Oa C'. -:...1, Gl ~ 01- J. 'CJ f lMoPUrW D1111k11 AND NOW, on this dal. of probable...... mual be compleled In order for a warranllo IlIue. (SI!ALI 2 AFFIDAVIT OF PROBABLE CAUSE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY COMPLAINT NUMBER YEAR TYPE NUMBER Complaint Numbera irOlber Participants INCIDENT NUMBER 97.717 UCR NO. 260 OTN F 068693-2 COMMONWEALTII OF PENNSYLVANIA VB. I, Deleetlv. Letllla R. WoodCord (Nama or Affiant) DEFENDANTI NAME AND ADDRESS EDWARD L. BENTON 52 Spring Garden Eatatea Carlillo, P A 170 tJ or Cumberland County Dbtrld Allorney'a Office, Criminal Inveallgatlon Division (IdentifY department or agency represented and political subdivilion) being duly Iworn (or aff1lt1lCli) berore me, ae<:ordinglo law, depoles and lays thatlbere is probablo cause to believe that: PROBABLE CAUSE BELIEF IS BASED ON TIlE FOLLOWING FACTS AND CURCUMSTANCES: maffiant is employed u a Detective wilb Ibe Cumberland County Dilmcl Allorney'a Office, Criminal Investigation Dlvlaion and hu been 10 employed rur Ibo put 8 months. According to Ibe victim, who relayed Ibe informalion to ibis Delectivo, since June oOhis year, 1997,lbe dorendant, Edward Benton hu engaged In a coune or conducl and repeatedly conunilled acts loward Ibe victim, Tami Jo Benlon, Thla activity includes tho CoUowlng events: On 27 June t997,lbe deCendant did publicly baraselbo victim in the Giant Foods Store located at 255 S, Spring Garden Street, tullalo, AJ Ibe victim wu standing in Ibe checkout line, atlbo register, Ibe derendant did approach Ibe victim Crom behind and began making disparaging remarla aboutlbo viclim, in her presenco, to individuals in tho immedlato area oC the victim. Alao on 27 Juno 1997, the deCendantapproached Ibo viclim in tho parking area oCth. Giant Foods Store located al255 S, Spring Garden Sln:et, Carlisle. At Ibis time, Ibe deCendanlapproached lb. victim and made Ibo Collowlng atalemenl: "11lings arc not going 10 go Ibo way you Ibink Ibey will, a bullet willalop you." On 2J July 1997,lbe derendant was leen by the victim driving pul heron Claremonl Road alapproximalely 1400 hours,just u Ibo victim wu leaving work. Th. deCendant ia well aware Ibe victim leavlS work al approximalely 1400 hoUD. On I August t 997, lb. deCendant wu seen by Ibe victim driving pUI her on Claremont Road alapproximalely 1415 hOUri, just u the victim wu leaving work, On 7 August 1997, lb. victim wu in route 10 pick up her child Crom her child care provider. The viclim picla up her child each day atapproximalely Ibe aametimo and generally takes Ibe aamo route each time. This route Is known 10 the deCendant. On lhis day, Ibe deCendant crossed patha twice wilb Ihe victim U Ihe made her way to Ibe child care provider, On 19 Augusl 1997, the deCendanl drove on Claremont Road, putlbe victim'a place oC employment, at approximately 0555 hours, just u Ibe viclim wu arriving Cor work. The derendant blcw hil horn atlbe victim, Tho derendanl is well aware thaI the viclim begins work at 0600 houra. On 17 August 1997 aner COUlt ordered visitation wilb Ibe deCendant, Ibe minor child alaled thaI she had to lelllbe victim a lecrel. The child llaled 10 the victim, "Monuny, daddy kill you". The minor child Is three yean oC a8e. On 20 Auguatl997, Ibe derendant drove on Claremonl Road alapproximately 1407 hours and waived to Ibe viclim. The viclim pulled oul onto Claremont Road, some distance behind the deCendant. The derendanlthen pulled to the righl side oC the road In Ibe 500 block oCE. North Street, aUowingthe victim to pus. 11le deCendant then pulled behind Ibo victim and Collowed her to tile interaectlon oC E. North Street and N. Easl Street. "age I COMMONWEALTII OF PENNSYLVANIA VS. I, DetecUve LeUlIa R. WoodCord (Heme oC Affiant) DEFENDANT: NAME AND ADDRESS EDWARD L. BENTON 52 Spring Garden !!alates Carlisle, P A 17013 QC Cumberland County Dutrld Atlorney'a Office, CrlmlnallnvesllsaUon Division (IdentifY deputment or agency represented and politicat lubdivision) being duly Iwom (or a!fumed) before me, according to law, deposes and says that there is probable cause to believe that: PROBADLE CAUSE BELIEF IS BASED ON THE FOLLOWING FACI'S AND CURCUMSTANCES: (Conllnued Crom PIse 1) On 2t August 1997, a!approximately 1407 hours, the victim was lraveling west on Claremont Road and noticed ule deCendant pulling out oCthe parking tot oC Carlisle Conlliner, located at 750 Claremont Road, directly behind ber vehicle, The deCendant Collowed the victim to the intenection oCE. North Street and N. East Slrett. Aner the victim picked up ber cbild, at Ipproximaloly 1420 boufl, the victim noticed the deCendant palked in the parking lot of the Creamart Store,located at 603 Franklin StreeL On 5 September 1997, the defendant pulled into the Cront parking lot at 375 Claremont Drive, The Nursing and Rehlbililative Center of Cumberland County, where the victim is employed. The deCendant approacbed Sbannon Walter, a female employee oCthe home, and requested her to take a box oCOowefl with a card to the victim inside the home. These actions were wimeased by a County Security Officer, Darlene Rickabaugh. Both Ms. Waller and Ms. Rickabaugh relayed this inConnation to this Detective. On 9 September 1997, between 1930 and 2000 hours, the victim Ilong with her minor child were traveling cast on Wgb Slrecl in the leO lane, when they encountered the defendant also lraveling east on JJigh Street in the right lane, The deCendant pulled up beside the victim'l vehicle, the victim looked over toward the defendant and the defendant was pointing a camera at the victim, The victim then turned leO ontn N. East Slreet, but noticed the deCendant remaining cast on High Slreet, Moments later, the victim Igain noticed the defendontlraveling behind her on N, East Street. The deCendant then pulled hia vehicle along the len aide oC the vlctim'land hollered out the window, "Vou"e a Cucking ugly bitch" and laughed, The defendant then pulled his vehicle directly in Cront oCthe victim'l vehicle and slowed to an unreasonable speed, not allowing the victim to pass. In light oCthe information stated above, this affiant respectCully requests the Court issue a warrant oC arrest Cor the deCendant, Edward L, Benton, on the chlrge oC s!alklng. e:. DAOOE NO. "'l'1 DISTRICT/UNIT 19 f1 ,- DISTRICT JUSTICE COURT NO. OFFICE ADDRF.5S: Dati Convnlulon ~pircl: Phone:: Page 2 The above-named plaintiff, Taml Jo Benton, verifies that the statements made In the above Petition are true and correct. The plaintiff understands that false statements herein are made SUbject to the penalties of 18 Pa.C.S. 04904 relating to unsworn falsification to authorities. 'hy I . 1(S -;0., · u.' 9rO 0',' dc'Yv1..J Taml Jo BenYon, Plaintiff Date ';, . '- co (:: a; ...:3 ~ N ~,'j .-i' ll.lr~l C~:;.: (.),> ct:. ,- \...<1 :~ t I~ r'. e'- :~ ;J :;~~ " ,..4 <XI :'.,J) 1...L.,1. (" .lX _.1" (J.; :"Z u: " ii ~I ~j,j F- n ,n:&... .c:< ~~.: ~ ro a '" 0- V"l c... ~ ~\ .,...,.