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BETH LYNN BODENHEIMER,
Plaintiff
. IN THE COURT OF COMMON PLEAS OF
. CUMBERLAND COUNTY, PENNSYL VANIA
v,
. NO, 97-4183 CIVIL TERM
MICHAEL LEE STINE,
Defendant
. PROTECTION FROM ABUSE
PROTECTION ORDER
AND NOW, this ~ day of August, 1997, upon consideration of the Consent
Agreement of the parties, the following Order is entered.
I, The defendant. Michael Lee Stine. is enjoined from physically abusing the plaintiff.
Beth Lynn Bodenheimer, or from placing her in fear of abuse.
2, The defendant is enjoined from having any direct or indirect contact with the
plaintiff including. but not limited to, telephone and ",riuen communications, except for the
limited purpose of facilitating custody arrangements.
3, The defendant is ordered to refrain from harassing and stalking the plaintiff and
from harassing her relati\'eS and the minor child.
4 The defendant is prohibited from entering the p1aintift's place of employment.
S, The defendant is prohibited from rertIO\ing, damaging, destroying or seI1ing any
property owned by the p1aintilT.
6, The defendant is ordmd to stay away from the plaintift's residence located It 6
Carol Lane, Enol&, Cumberland County, Pennsytvania, except for the limited purpose of
transfening custody, and is ordered to stay away from any residence the pIaintitT may in the fUture
establish for heneIf The defendant shall mnain in his \-ehicle durilllJ transfer of custody.
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7, The defendant's weapons confiscated through the Temporary Protection Order in
this action shall be transferred from the I)my County Sheriff's Department to the Cumberland
County SheriIT's Department and shall remain in the custody of the Sheriffs Department for the
duration orthis Order, The defendant is prohibited from acquiring or possessing any weapons for
the term of the Order,
8, Court costs and fees are waived,
9, This Order shall remain in elTect for a period of one (I) year and can be extended
beyond that time if the Court finds that the defendant has committed an act of abuse or has
engaged in a pattern or practice that indicates risk of harm to the plaintiff. This Order shall be
enforceable in the same manner as the Court's prior Temporary Protection Order entered in this
case,
10, A \iolation of this Order may subject the defendant to. i) arrest under 23 Pa C S
~6113; ii) a private criminal complaint under 23 Pa C S ~ 113 I. iii) a charge of indirtCt criminal
contempt under 23 Pa,C.S ~114, punishable by imprisonment up to six months and a fine of
SIOOOO-SI,OOOOO; and iv) o\il contempt under 23 PaC S ~61141.
II. The East Pennsboro Township Police Department shall be pro\ided ~ith a
certified copy of this Order by the plaintiffs attorney and may enforce this Order by arrest for
indirtCt criminal contempt without warrant upon probable cause that this Order has been violated.
whether or not tbe violation is committed in the presence of the police officer In the event that
an arrest is made under this section. the defendant shaD be taken without unnecessary delay before
the court that issued the order When that court is unavailable. tbe defendant shaD be taken
BETH LYNN BODENHEIMER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO, 97-4183 CIVIL TERM
MICHAEL LEE STINE,
Defendant
PROTECTION FROM ABUSE
CONSENT AGREEMENT
This Agreement is entered on this ~...- day of August, 1997, by the plaintilT, Beth
Lynn Bodenheimer, and the defendant. Michael Lee Stine, The plaintiff is represented by Joan
Carey of LEGAL SERVICES, INC.; the defendant is unrepresented but is aware of his right to
have an attorney. The parties agree that the following may be entered as an Order of Court ,
I, The defendant,Michael Lee Stine, agrees to refrain from abusing the plaintiff. Beth
Lynn Bodenheimer, or from placing her in fear of abuse,
2 The defendant agrees not to have any direct or indirect contact with the plaintiff
including. but not limited to. telephone and written communications. except for the limited
purpose of facilitating custody arrangements
3, The defendant agrees not to harass and stalk the plaintiff and not to harass her
relatives and the minor child,
4, The defendant agrees not to enter the plaintift's place of employment
5, The defendant agrees not to remove., damage., destroy, or sell any property owned
by the plaintiff
6 The defendant agrees to stay away from the p1aintift's residence located It 6 CIrOI
Lane., EnoJa. Cumberland County, Pennsylvania. ~cept for the limited purpose of transferrins
custody, and the defendant agrees to stay away from any residence the plaintiff IIlIy in the fUture
establish Ax henelf The defendant will remain in his vehil;le durina transfer of custody
7, The defendant agrees that the weapons conliscated through the Temporary
Protection Order and any other weapons that he owns or possesses remain in the custody of the
Cumberland County Sherifrs Department for the duration of the Protection Order, and agrees not
to acquire or possess any weapons for the teon of the Protection Order,
8, The defendant, although entering into this Agreement, does not admit the
allegations made in the Petition,
9, The defendant understands that the Protection Order entered in this matter will be
in effect for a period of one ( I) year and can be elttended beyond that time if the Court linds that
the defendant has committed an act of abuse or has engaged in a pattern or practice that indicates
risk of hann to the plaintiff The defendant understands that this Order will be enfor;:eable in the
same manner as the Court's prior Temporary Protection Order entered in this case,
10. Violation of the Protection Order may subject the defendant to: i) arrest under 23
Pa,C,S t6IIJ, ii) a private criminal complaint under 23 Pa,C.S ~61IJ,I; iii) a charge ofindirect
criminaJ contempt under 2J PaC S ~114, punishable by imprisonment up to silt months and a
line ofSIOOOO-SI,OOO,OO; and iv) civil contempt under 23 Pa,CS ~114,I,
WHEREFORE, the parties request that a Protection Order be entered to ret1ect the above
terms,
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Bc1h Lynn '. Plaintiff
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:' Carey. Attorney ~Plaintiff
LEGAL SERVICES. INC.
. Irvine Row
Carlisle. P A 170 IJ
(717) 24).940\}
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Michael Lee Stine,
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BETH LYNN BODENHEIMER,
Plaintiff
IN TIlE COURT Of COMMON PLEAS Of
. CUMBERLAND COUNTY, PENNSYLVANIA
v,
. NO, 97-...!5:LLP,~
CIVIL TERM
MICHAEL LEE STINE,
Defendant
. PROTECTION fROM ABUSE
TEMPORARY PROTECfION ORDER
AND NOW, this '/'~of August, 1997, upon presentation and consideration of the within
Petition, and upon finding that the plaintiff, Beth Lynn Bodenheimer, now residing at 6 Carol
Lane, Enola. Cumberland County, Pennsylvania. is in immediate and present danger of abuse from
the defendant. Michael Lee Stine, the following Temporary Order is entered,
The defendant, Michael Lee Stine, (SSN. 164-64-8370)(ooB. 11/24/66), now residing at
4th Street Extension, Newport, Perry County, Pennsylvania. is hereby enjoined from physically
abusing the plaintiff, Beth Lynn Bodenheimer, or from placing her in fear of abuse,
The defendant is ordered to stay away from the plaintift's residence located at 6 Carol
Lane, Enol&, Cumberland County, Pennsylvania. a residence which is ov.ned by the plaintiff. and
is ordered to stay away from any residence the plaintiff may in the future establish for herself,
except for the limited purpose of transferring custody of the parties' child The defendant shall
remain in his vehicle at all times during the transfer of custody,
The defendant is ordered to refrain from having any direct or indirect contact with the
plaintiff including, but not limited to, telephone and written communications. except for the
limited purpose of facilitating custody arrangements
The defendant is enjoined from harassing and sWking the plaintiff and from harassing her
relatives
The defendant is enjoined t"tom enterin8 the plaintift's place of employment .
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The defendant is enjoined from removing. damaging, destroying or selling any property
owned by the plaintiff
A violation of this Order may subjrct the defendant to: I) arrest under ZJ Pa.C.S.
f6113; il) a private criminal complaint undu 2J Pa.C.S. *6113.1; Iii) a charge of Indlm:t
criminal contempt under ZJ Pa.C.S. *6114, punishable by Imprisonment up to sl:l montbs
and a fine ofSI00.00-5I,ooo.00; and Iv) dvil contempt under 2J Pa.C.S. 16114.1.
This Order shall remain in effect until modified or terminated by the Court and can be
extended beyond ils original expiration date if the Court finds that the defendant has committed an
acl of abuse or has engaged in a pattern or practice that indicates risk ofhann to the plaintiff.
The defendant Is ordered to mlnqulsb to tbe sherlfl's department any weapons
whlcb he owns or possesses, and the defendant Is problbited from uquiring or possessing
any weapons for tbe duration of this Order.
A HEARING SHALL BE HELD ON THIS MA TIER ON AUGUST I / 1997,
AT ,';1; ()(J P .M., IN COURTROOM NO.S, OF THE CUMBERLAND
COlJN1Y COURTHOUSE, CARLISLE, PENNSYLVANIA.
The plaintiff may proceed without pre-payment of fees pending a further order after the
hearing.
The Cumberland County Sherill's Department shall attempt to make service at the
plaintift's request and without pre-payment of fees. but service may be accomplished under any
appIiabIe rule of Civil Procedure
This Order shall be docketed in the office of the Prothonotll)' and forwarded to the Sheriff
for service The Prothonotll)' shall not send a copy oftbis Order to the defendant by mail
The E.ut Pmnsboro To,,11Ship Police Department shall be provided with a celtified copy
of this Order by the plaintift's attorney This Order shall be enforced by any law mt"orcement
agency wtlere . \ioIation octUn by arrest for indirect criminal contempt "ithoot W&n'1IIt upon
BETH LYNN BODENHEIMER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v,
: NO. 97. '/ I i '1
CIVIL TERM
MICIIAEL LEE STINE,
Defendant
: PROTECTION FROM ABUSE
PETITION FOR PROTECTION ORDER
RELIEF UNDER THE PROTECTION FROM ABUSE ACT
13 P..C.S.16101 ft srq.
A. ABUSE
I, The plaintiff. Beth Lynn Bodenheimer, is an adult individual residing at 6 Carol
Lane, Enola. Cumberland County, Pennsylvania 17025.
2, The defendant, Michael Lee Stine. (SSN: 164-64-8370)(ooB 11124/66), is an
adult indi\idual residing at 4th Street Extension. Newport. Peny County. Pennsylvania 17074,
3, The defendant is the former Iwsband of the plaintiff and the father of the panies' 3
year-oid daughter, Tessa E. Stine
4. Since approximately 1995, the defendant has attempted to cause and has
intentionally, knowingly. or recklessly caused bodily injury to the plaintiff, has plactd her in
reasonable fear of imminent serious bodily injury. has knowingly engaged in a course of conduct
or repeatedly committed acts toward the plaintiff under circumstances which have p1ac:ed her in
reuonabIe fear of bodily injury This has inc:luded. but is not limited to, the following spetifIc:
instanc:es of abuse
a) On or about July 20, 1997. the defendant stood in dose proximity to the
plaiatift"s fate and yelled. "What's your lUcking problem"" Farina for her saltty,
the pIaiatitf took the panics' }.ytar-o/d cJaushter and werIt 10 her car, Tho
defendant t"olloMd the pIIintifl ~ at her, saeamintJ obscenities. and ....Ihe
plaintiff got into her car to leave, he opened the passenger side door, leaned into
the car, and threw the parties' child's cup at the plaintiff. The plaintiff pleaded
with the defendant to let go of the door so she could leave, but he refused.
threatened to "break the fucking door", and violently jerked the door back and
forth against the hinge several times, The plaintiff honked the horn until the
defendant's mother came out to the car and intervened, Although the plaintiff was
unable to close the damaged car door, she drove directly to the Pennsylvania State
Police barracks in Newport and reported the incident. A trooper had to kick the
car door to get it to shut so the plaintiff and her child could drive home safely,
Criminal mischief charges were filed against the defendant as a result of this
incident.
b) On or about June 12, 1997 (Father's Day), the defendant screamed and
yelled obseenities at the plaintiff. and threatened to kiD her if she came to pick up
their daughter early. The plaintiff contacted the Pennsylvania State Police in
Newport who telephoned the defendant and spoke to him about his behavior,
c) In or about 19%, during one incident the defendant ripped a necklace off
of the pIaintifr s neck and shoved her During another incident the defendant
screamed at the plaintiff and spat in her face
d) In or about 1995, the defendant threw a plate of food at the p1aintiffhitting
her on the anns when she l1ised them to shield her face and head The defendant
left the room. returned with a sawed-olf shotgun and Wind it in I ntel1ICinlJ
fashion cauaina the plaintiff to fear for her life The plaintiff sustained ~
about her forearms as a mutt of this in<idctIt
S The plaintiff believes and thctero.e nm that she is in inlmedYte IIllt pu:..
danger 01.. fivm the dtfendant IIld that she iI in need mprotcdion fivm lIUdI..
6, The plaintiff desires that the defendant be prohibited from having any direct or
indirect contact with the plaintiff including. but not limited to, telephone and wrillen
communications. except for the limited purpose of facilitating custody arrangements,
7. The plaintiff desires that the defendant be enjoined from harassing and stalking the
plaintiff. and from harassing her relatives,
8, The plaintiff desires that the defendant be restrained from entering her place of
employment.
9, The plaintiff desires that the defendant be enjoined from removing. damaging.
destroying or selling any property owned by the plaintiff
10, The plaintiff desires that any weapons the defendant owns or possesses be
confiscated by the Sheriffs Depanment and that the defendant be prohibited from acquiring or
possessing any weapons for the duration of the Temporary Protection Order
IJ, EXCI.USIVE POSSESSION
II, The home from which the plaintiff is asking the Court to order the defendant to
stay away from is owned in the name of Beth Lynn Bodenheimer. The defendant has resided with
his mother at 4th Street Extension, Newport. Perry County. Pennsylvania, since 1995, The
defendant shall remain in his vehicle at all times during the transfer of custody
C. LOSSES ANt) RElMQURSEl\lENT FOR CO&T Of CASE
12, The plaintiff desires to be reimbursed for losses she has suffered u a result of the
abuse by the defendant The losses are listed on Exhibit A allached
J) The plaintiff desires that the Court order the defendant to pay S2SO.00 to
Cumberland County. one of LepI Senicn. loe 's funding sources. in lieu of attomeys' fees. u
reimbunement fur the cost oflitiplina this case and assess a S25,OO surtharJc and court Q)IlS to
the defendant if the case goes to hearin!J
WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of October
7, 1976,23 P.S, ~6101 !:t ~" as amended, the plaintiff prays this Honorable Coun to grant the
following relief:
A, Grant a Temporary Order pursuant to the .Protection ITom Abuse Act:.
I, Ordering the defendant to refrain from abusing the plaintiff or ITom
placing her in fear of abuse,
2, Ordering the defendant to relTain ITom having any direct or indirect
contact with the plaintiff including. but not limited to, telephone and
written communications, except for the limited purpose of facilitating
custody arrangements,
3, Ordering the defendant to retrain lTom harassing and stalking the
plaintiff and from harassing her relatives,
4, Prohibiting the defendant lTom entering the plaintift's place of
employment,
S Prohibiting the defendant lTom removing. damaging. destroying or
selling property owned by the p1aintilT
6 Ordering the defendant to stay away from the plaintift's residence
located at 6 Carol Lane. Enola. Cumberland County, PennsyMnia, and
ordains the defendant to stay away from any residence the p1aintiff'may in
the future establish for herself The defendant shall remain in his vehicle at
aD times durina the tnnsfer of custody.
7. On:lerintl the defmdant 10 rdinquish to the sherift's depanmeat any
Yo e.poos _hich he owns or pos'lCf~ and prohibitina the defer4w ftom
acquIriaj or pos.wuina any other MlIpOM for the duration of the
T~ary Pt<ltcaion Order
8, 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 from
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. except for the limited purpose of facilitating
custody arrangements,
3, Ordering the defendant to refrain from harassing and stalking the
plaintiff and from harassing her relatives
4. Prohibiting the defendant from entering the plaintift's place of
employment
5. Prohibiting the defendant from removing. damaging, destroying or
selling property owned by the plaintiff
6, Ordering the defendant to stay away from the plaintift's residence
located at 6 Carol Lane. Enola, Cumberland County. Pennsylvania, and
ordering the defendant to stay away from any residence the p1aintiff may in
the future establish for herself The defendant shaJJ remain in his vehide at
all times during the transfer of custody.
7. Ordering the defendant to relinquish to the sberift's depanment any
weapons which he owns or possesses. and prohibiting the defendant from
acquiring or possessing any other weapons for the duration of the
Protection Order
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Order for destruction of the weapons; a copy of said notice is attached hereto as
Exhibit "An,
6. The Defendant has failed to reclaim the weapons.
WHEREFORE. you petitioner respectfully requests Your Honorable Court to enter an Order
directing the destruction of the above described weapons.
Very respectfully submitted,
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Solicitor
127 West High Street
Carlisle, PA 17013
(717)243-9258
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LINDA K. MCCONNELL
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V,
: 4202 CIVIL 1997
JAY MAX MCCONNELL
Defendant
ITEM: Connecticut Valley Arms, 50 car,
Ser. # 61-13-101501
ORDER
AND NOW, this 7th day of February, 2000, upon petition of the Sheriff, the following Order
is entered:
The Sheriff of Cumberland County having sent notice to reclaim the seized weapon(s) to
the above-named defendant via regular and certified mail to the last known address, and the
defendant not having responded to the notice by asserting a claim, the Sheriff of Cumberland
County is directed to destroy the listed weapon(s) in accordance with law. The Sheriff shall make
the appropriate arrangements for the destruction of any ammunition.
By the Court,
R. Thomas Kline, Sheriff
Cumberland County Sheriff'. Department
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6. The Defendant has failed to reclaim the weapons.
WHEREFORE, you petitioner respectfully requests Your Honorable Court to enter an Order
directing the destruction of the above described weapons,
Very respectfully submitted,
#~~~~~
Edward L. Schorpp
Solicitor
127 West High Street
Carlisle, PA 17013
(717)243-9258
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11S8334 U,I. POSTAar :
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COUNTY OF CUMBERLAND
O"lce of The Sheri"
,1 Courthouse Square
Carlisle, Pennsylvania 17013
MAIL
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Jay M. McConnell
214 S. Enola Drive
Enola, PA 17025
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