HomeMy WebLinkAbout98-02527
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CLAIRE F,MILY OSBORNE,
I'laintill'
IN TilE COURT OF COMMON "I.II.AS OF
CUMBEI{I ,AND COUNTY, I'I',NNSYI.V ANIA
v.
NO, <JH-2527 CIVil ,I'I':I{M
DWYNIi TYRONI': SIIOEM^KElt,
Defendllnl
I'IWTFCTlON FROM ^BUSE
PRo'n:CTION ORDf1~1!
AND NOW, this 111 duy of May, 1l)()H, upon eonsi<!l1rlltion of the Consent Agreement
of the parties, the tbllowing Order is l,ntered:
I, The dclendllnl, I>wyne Tyrone Shoemllker, is enjoined thlln physically abusing lhe
plaintill~ ('Iuire Fmily Osborne, or l)'(lIn placing her in tear of abuse
2, The defendant is enjoined I)'om having uny direct or indill'ct contact with the
plaintill'including, but nollimited to, t<J!<lphone, written, or electronic <:ommunieations
1. The defendant is ordered to refrain Ihlln harassing and slalking the plaintill' or any
member of her family,
4, The defendant is prohibited thnn entering the plaintifl's place of employment 01' her
c1l1sses at Dickinson College. If the plaintifl'is employed at Dickinson ('ollegll, the defendant shall
limit his contact at her place of employment to school-related business
5. The dellmdant is prohibited fhlll1 damaging or destroying uny property owned by
the plaintifT
6. The delendant is orden:d to stllY IIWllY thlln lhe plaintill's residlmce loeal<ld at 152
East lIigh Street, Carlisle, ('umberland ('ounty, I'ennsylvunia, und any residencl' the plaintiff may
in the Ihture estublish Illl' herself
7. ('ourt costs and lees arc waived.
H. This Order shall remain in et1ect tbr II period of one (I) year lInd can be extended
heyond thnt time if the ('ourt linds that the delcndant has l\ommitted an flC,t of abuse or has
CLAIRE EMILY OSBORNE,
Plaintiff'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, I>ENNSYLVANIA
v,
DWYNE TYRONE SHOEMAKER,
Defendant
NO. 98..2527 CIVIL TERM
PROTECTION FROM ABUSE
CONSENT AGREEMENT
This Agreement is entered 011 this__Li~_ day of May, 1998, by the plaintifl: Claire
Emily Osborne, and the defendant, Dwyne Tyrone Shoemaker. The plaintiff is represented by
Joan Carey of LEGAL SERVICES, INC; the defendant is represented by David Breschi of
SHUMAKER WILLIAMS Pc. The parties agree that the following may be entered as an Order
ofCoult.
I. The defendant. Dwync Tyrone Shol~maker, agrees to refrain from abusing the
plaintiff, Claire Emily Osborne, 01' from placing her in fear of abuse.
2. The dettmdant agrees not to have any direct 01' indirect contact with the plaintiff
including, but not limited to. telephone. written 01' electronic communications.
3. The defendant agrees not to harass and stalk the plaintiff or any member of her
family,
4. The defendant agrees not to go to the plaintitl's place of employment or enter her
classes at Dickinson College, If the plaintifl' is employed at Dickinson College, the deltJDdant
agrees to limit his contact at her place of employment to school-related business.
5, The delendant agrees not to damage or destroy any prop CIty oIVned by the
plaintifl'
6, The defendant agrees to stay away Irom the plainti'l's current residence located at
152 East High Street, Carlisle, Cumberland County, Pennsylvania, and any residence the plaintiff
may in the future establish for herself
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CLAIRE EMILY OSBORNE,
Pluintln'
IN TUE COURT OF COMMON PLEAS OF
v.
CUMBERLAND COUNTY, I'ENNSYLV ANIA
NO. 98- ;)5,)'}.
CiVIL TERM
DWYNE TYRONI': SIIOI':MAKI':R,
I )lllcndunl
PROTECTION FROM ABUSE
IE.MPORARY PROTECTION ORDER
AND NOW, this 1;1/ day or May, 1998, upon prescntation and consideration of the
within Petition, IIml upon Iinding that thc plaintin: Claire Emily Osborne, now residing at an
undisclosed location for her safcty and to avoid Ihrther abuse, is in immediate and present danger
of a8use from the defendant, Dwyne Tyrone Shoemaker. the following Temporary Order is
entered,
.hrw el/lill'cellwm aKencies, hI/mail sel'l'h:e agencies alld school districts shall lIot
disc/o,~e the pre,I'em!e of the plailll![f ill the jl/ri,I'dic!ioll or district or .fill'lIish allY addre.I's,
telepholle IIlImher, or al!l' other dell/owaphic il/formatioll ahollt thl' plai/l/!ff except kv fl/r/her
Order (!f ('Ollr/,
The defendant, Dwyne Tyrone Shoemaker (SSN: I 82-58-5735)(DOR: 05/29/77), now
residing at Dkkinsoll College, Conway Hall, Room 208, Carlisle, Cumberland County,
Pennsylvania, is hereby enjoined from physically abusing the plaintiff, Claire Emily Osborne, or
from placing her in fear of ubuse.
The defendant is ordered to stay away from the plaintill's current residence which is at an
undisclosed location, a residence to which the plaintiff moved to avoid abuse, which is not owned
or leased by the defendant, and is ordered to stay away from any residence the plaimiff may in the
future establish for herself.
The defendant is ordered to refrain from having any direct or indirect contact with the
plaintiff including. but not limited to, telephone. written, and electronic communications,
The defendant is enjoined 11'001 harassing and stalking the plaintiff and frolTl harassing her
relatives,
The defend!lI1t is enjoined from entering the plaintitl's classes at Dickinson College or her
place of employment.
The defendant is enjoined t1'01n damaging or destroying any property owned by the
plaintiff.
A violRtion of this Order may subjert the defendant to: i) arrest under 23 Pa.C.S.
*6113; ii) a private rriminal complaint under 23 Pa.C.S. *6113.1; iii) a charge of indirect
criminal rontempt under 23 Pa.C.S. *6114, pnnishRble by imprisonmeut up to six months
and a fine of $100.00-$1,000.00; Rnd iv) civil contempt under 23 Pa.C.S. *6114.1.
This Order shall remain in effect until modified or terminated by the Court and can be
extended beyond its original expiration date if the Coul1 finds that the defendant has committed an
act of abuse or has engaged in a pallern or practke that indicates risk of harm to the plaintiff.
I ,/
. 1998.
A nEARING SHALL BE HELD ON THIS MATn:R ON MAY
AT !. 'I '; IL.M..IN COlJRTROOM NO. -.:..::..., OF THE
COUNTY COlJRTIIOUSt;, CARLISLE, Pt:NNSYLV ANIA.
ClJMB~:RLAND
The plaintiff may proceed without pre-payment of fees pending a further order after the
hearing.
The Cumberland County Sheriff's Department shall allempt 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 otlice of the Prothonotary lInd forwarded to the Sheriff'
for service. The Prothonotary shall not send a copy of this Order to the defendant by mail.
The Carlisle Police Department and Dickinson College Safety and Security shall be
provided with certified copies of this Order hy the plaintiff's allorney. This Order shall be
CLAIRE EMILY OSBORNE,
l'laintill'
IN TlII\ COURT 01' COMMON I'LEAS OF
CUMUERLAND COUNTY, PENNSYLVANIA
v,
NO, 98.
CIVIL TERM
DWYNE TYRONE SHOEMAKER,
Defendant
!>ROTECTION FROM AB\JSE
NOTICE
You have been sued in COlli'\. If you wish to delcnd against the claims set forth in the
following pages, you must take actioo promptly aner this Petition, Order and Notice are served,
by appearing personally 01' by attorney at the hearing scheduled by the ('ourt and presenting to the
Court your defenses or objections to the claims set fOl'th against you, You are 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 mnney claimed in the Petition 01' 1'01' any other claim or
relief requested by the plaintilI You may lose money or property 01' other rights important to
you, Any Protection Order granted by a Court may be considered in any subsequent
domestic I'elations proceedings, including custody actions.
F.;ES AND COSTS
If the case goes to hearing and the judge grants a Protection Order, a surcharge 01'$25,00
will be assessed against you, Y Oil 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 tht' 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
ornee set forth ~elow to find ont where yon can gellegRI help. ______.___
CUMBERLAND CO\JNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 1701.1
TELEPHONE NUMBER: (717) 249-116601' 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.
please contact our office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court.
CLAIRE EMILY OSBORNE,
PlaintHr
: IN TilE COURT OF COMMON PI ,EAS OF
. CUMBERLAND COUNTY, I'ENNSYLV ANIA
v,
NO, 9H-,~ ~ ..I]
.. CIVIL TERM
DWYNE TYRONE SIIOEMAKI':R,
Delendnnl
I'ROTECTION FROM ABUSE
PETITION FOR PROTECTION ORDER
Rt;l,mFIJND.;R THE PRonrnON "'ROM ABUSE ACT
23 Pa.C.S. ~6101 et seq.
A. ADIJSI'~
I, The plaintiff, Claire Emily Osborne. is an adult individual temporarily residing at an
undisclosed location for her safety and to avoid llirther abuse,
2, The defendant, Dwyne Tyrone Shoemaker (SSN. 182-58.5735)(DOB: 05/29/77),
is an adult individual currently residing at Dickinson College. Conway Hall, Room 208, Carlisle,
Cumberland County, Pennsylvania 17013. The defendant' s permanent address is 233 BarriJ1!,>ton
Road, Upper Darby, Philadelphia County, Pennsylvania 19082,
1 The defendant has had an intimate relationship with the plaintifl',
4, Since approximately fall 1997, the defendant has attempted to cause and has
intentionally, knowingly, 01' recklessly caused bodily i"Jury tL the plaintifl~ has placed the plaintiff
in reasonable fear of il11minent serious bodily injury, and has <nowingly engaged in a course of
conduct or repeatedly committed acts tov.'ard the plaintiff under circumstances which have placed
the plaintiff' in reasonable fear of bodily injury This has included, but is not limited to, the
following specilic instances of abuse:
a) On or about April 25, 1998, the defendant grabbed the plaintiff by the arm,
pushed her back into his dorlll room as she was leaving, yelled at her, grabbed her
by the neck, shoved her against the wall, repeatedly slammed her head against the
dnder block wall, nnd thrllntened hilI' snying, "I'm gonnn kllOCk you out; ('m
gonnn kill you; I don't cnre" The defendnnt, who held the plaintiff by her neck
with one hand nnd her linn with his otlwr hand, threw her onto the bed, choked her
with both hands ellusing her to feel that she WllS losing consciousness, llnd
threatened her snying, "You're going to die on this bed tonight." The dellll1dant
pulled the shoe fhllll the plaintiO's foot and threw it at her hitting her iil jaw, As
the plnintiO'tried to Icave the room, the defendant stood in Iront of her in n boxing
stance with both his lists clenched as if to strike her, and as she moved toward the
door, he punched her in the chest, knocking her backward onto the bed, straddled
her, pinned her down on the bcd, choked her with both his hands. grabbed her by
the tl'ont of her clothing and her arm, and threw her to the tile floor causing her to
fall against the desk resulting in the desk chair fell ontop of her. As she lay on the
floor the defendant threatened her snying, "I'd like to kick you in the face." The
plaintifl' was taken to Carlisle Hospital for treatment of injuries she sustained as a
result of this incident. After lellving the hospital, she went to the Carlisle Police
Department, gave her statement. the defendant was arrested, and charged with
simple assault. The defendant made bail with a condition of his bail being that he
have no contact with tbe plaintiff. A preliminary hearing is scheduled befi>re
District Justice Correal on June 10, 1998, at 10:00 a,m. Dickinson College has
scheduled a hearing on May 5, 1998, at 2:30 p.m.
b) On or about April 13, 1998, the defendant stood so close to the plaintiff
that he was pressing his chin against her nose forcefully while yelling at her,
pushed her backward onto the bed, straddled her, grabbed her by the neck, and
held her down. The plaintiff returned to her dormitory room and telephoned
Safety and Security for help. No action was taken as a result of this incident.
c) In or about IlIte March 19l)R, thc defendant lIccused the plllintifl' of taking
his keys, which she hlld not done, sent severnl E..mllil messagcs to her, some of
them threatening her with physielll harm, telephoned her dormitory room
repeatedly, and eventually showed up at her 1"00111. The plaintin~ who was siUing
in an adjoining 1'00m wherc she could see the defendant, observed him enter hcr
room, and close the doOl'. When she heard noises coming n.OIll her room, the
plaintifl' entered the room. sa\\' that the defendant had torn the bedding off of hilI'
bed and thrown it on the 110or, pushed all her personal items 011' of her dresser lInd
desk onto the 110or, pulled Iwr clothing out of her dresser drawers onto the 110or,
thrown the contents of her laundry basket on the 11001', lInd was in the process of
pulling her clothing out of the closet and throwing it on the floor, The plaintiff
went into the room and joined her roommatc in a!tempting to talk the defendant
into leaving. The delcndant grabbed the plaintifl's keys and her roommate leU the
room to get help, Dkkinson College Safety and Security arrived and charged the
defimdant with disorderly conduct and harassment. Fellring that he woukld be
removed from Dickinson College. the defendant and his mothcr pursuaded the
plaintiff to drop the charges so as not to interfere with the defendant's future, The
plaitltiff asked the dean to dismiss the charges because she believed that the
defendant would not act in a violent manner lIgain.
d) Since approximately fall 1977, the defendant has abused the plaintifl' in
ways including, but not limited to, shoving, punching, choking, throwing her
about, restraining her, grabbing her, threatening her with bodily harm in person and
via E-mail. and threatening to kill her.
5, On 01' about April 25, 1998. the plaintifl'lell her residence at Dickinson College,
Hall, Room, Carlisle, Cumberland County. Pennsylvania, in order to avoid further abuse.
6, The plaintifl' believes IInd therefore livers that she is in Immediate and present
dangor of abuse 1'1'0111 tho detimdant and that she is in need of protection 11'<1111 such abuse,
7. The plaintil1' desires that the defendllnt he prohibited 11'<1I11 havingllny direct 01'
indirect contact with the Illaintitl' including, but not limited to, telephone, written, IInd electronic
communications.
8. The plai:1till' desil'l~s thllt the delimdant he enjoined from harassing and stalking the
plaintiff, and thlm harassing her rcllltives.
9, The plllintill' desires thllt the defendant he restrnined from entering her c1l1sses lit
Dickinson College and her place of employment.
10, The plaintitl' desires that the ddcndant be enjoined from damaging 01' destroying
any property owned by the plaintiO',
B. EXCLlJSIV.~ POSSES~ION
II, The plaintiffs current residence, which is at IIn undisclosed location for the
plaintiff's safety, from which the plaintiff is asking the Court to order the detimdant to stay away
from is not owned 01' rented by the defendant and he has never resided there,
C. LOSSES AND REIMBlJRSEMENT FOR COST OF CASE
12. The plaintiO' has suffered losses as a result of the abuse by the defendant. The
losses arc listed on Exhibit A attached
13. The plaintiO' asks that the deliJlldant be ordered to pay $250.00 to Cumberland
County, one of Legal Services, Inc,'s funding sources as reimbursement for the cost of litigating
this case, and that the detcndant be assessed the $25.00 surcharge and any court costs if the case
goes to hearing,
WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of October
7, 1976, 23 I'.S, ~h I 0 I cl Sell, as IIll1ended, the plaintill' PI'llYS this 1I0norable Court to gl'llnt the
following rclicf:
A, GrHllt H TellllJOrary Order plll'llUHllt tll the "Protectloll from Abuse
Act:"
I. Ordering the delendant to refrnin li'Om IIbusing the plaintiff 01' from
plllcing her in fear of abuse.
2. Ordering the delendnnt to refrain Ihllll having any direct 01' indirect
contact with the plaintiO' including, but not limited to, tclephone, written,
and electronic communications,
3, Ordering the defendant 10 refrain from harassing and stalking the
plaintiff and from harassing her relatives.
4. Pl'Ohihiting the defendant Ii-om entering the plaintiffs classes at
Dickinson College, and her place of employmcnt.
5, Prohibiting thc defendant from damaging 01' dcstroying any
property owned hy the plaintiff
6. Ordering the defendant to stay away from the plaintiffs current
residence which is at an undisclosed location for her safety, and any
residence the plaintiff' may in the future establish for herself
B. Schedul.. H hearing in Hccordance with the provisions of the
"Protection from Abuse Act," and, afler snch hearing. ellter all order to be
in effect for a period of one year:
I. Ordering the del'endant to reti'ain from abusing the plaintill' or fl'om
placing her in fcar of abusc.
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11/23/88 10:17 FAX 766 2238
COMMONWEIlLUI Of' PENNSYLVANIA
COUNty 01=: CUlWKlU..AND
G EWER
Ii!loo~
~
NOTICE OF
PRElIMINARV HEARING
COMMONWEALTH OF
rENNSYl.VANIA
UIiOM,"',1
(19-3-05
OJ "Me: ttlt4l.
QAYLllI A. RLDBR
,...." 507 N. YORK ST.
KBr~rCdbUnG, PA
II........' (117 )'166-'575
170fi5
Vfl,
1l~.FENllMH: __.....DO.....
,_. IlWAYNE TYRONE SIlOEMAKER
233 IlARRINGTON AVE.
LIPPER llAR8Y. PA 19062
. --------~---
PRKLIHINAkt ARRAIGNMENt:
-[
B!olL=.. .~~..~~~..~q ,~I'!~~cllred
L
IPOUkOINO,: ~ .~.
lDRID Fllod~ ._~ ~
Charae(a): __
DATE:.. ,~qy .~;! .;~~~.,
TlME:t. t~:,~q.v.~.......
PA DR sec. 611:l INDIRECT CRIMINAl. CONTEMPT
PPA # 98-2527 issued 5-14-96
NOTICE TO DEFENDANT
II tompllllnt has beon filed ohsrglno you with lhe ollenso(s) oollOllh auovs and on lhs atlach\ld copy 01 lho
complain\. 1\ preliminary hurlng on Ihess charges hes bsen soheduled 10':
Dale:
NOV 23 1
1:00pm
EAST WING CUMBERLAND CO
CARLISLE (117~
time:
11 you ftlll to apposr atlhEl lime IInd place abovo, B wanllnt will be-Issued lor your arrelt,
AI lhe preHmlnary hearing you may:
/: ,-50
/'lo7t,~L4/"
3, Call witnesses on your bohaU other Ihan witnesses to (oellly to your good repulatlon onty,
oller evidence on your behaU and laBtlly;
4, Make Wllllon notes of Ihe proceeding, or heve your counsel do 90, Clll1ake II slel1Ollraphlc,
l11tchunloal or oleolronlo record of the proceedbll9,
I, Be I'lIfJralanted by lJOun801;
2, Oross.e~8mlnB wltne9soo and Inspeel physloalavldenoo ollered sgolnsl you;
" yOll oannol allord III hIre an .\torn.y I onell18Y be appolnled to r.preotll1 you, PI,..o conlaOlI!1,
ollie. 01 Ihe dlllrlcllul\lce lor eddlllonel lnlormallon regarding the appointment Ql an aUDfney.
" you 11ft d1sabled and rB(tulre "!lIsteneD, plsaso oonlact Ih. Malllsletllll Olslrlot olllot al \tie
Iddr... above,
II you have any quostlons, pleas. oalllho above olllon tmmedlnlnly,
.~
I'" G/,QJ>nle __+) . (). ---f}jJ'J. ---^---
My 0Il111111IssI0l1s~plro9I1r9' MOIltJllY 01 ,January, :.\002 ,
_ ' D1slrlct Jus\1ce
SEAl.
flOPO 828.81
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11/23/88 10:17 FAX 766 2238
G ELUER
1aI008
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BAIL BOND
OTN Dj"No:\~~--------- Onto of Chargo(s):-----
co No: OJ Duckot Nll,: ..,'_ Nov 21 1
Commonweallh VS, (Defendant Name and Address) NI".XT COURT ACTION Oatel Imel Location
DIIAYNIi TYRONE SHoEMAKER
233 BAR.RINCTON AVE:.
UPPER DARBY, pA 19082
MONDAY, NOV. 23, 1998
l:nOl'm
CUHIlERLAND COUNTY COURT OF COMMON FLUS
CHAAGE(S): PA DR 8eo. 6113 INDIRECT CRllUNAl. CONTEMPT. PE'A # 98-2527 issued 5/14/98
AD CHAIIOESlIAY EXIST, PLEASE BElEl I N.& CHARGES PAGE,
TYPE(S) OF RELEASE:
o ROR XJUDtjJnsecured Ball 0 Nonmonotary Condilion(s) (soe additional pagels))
o No~lnal Ball D._ Monelary Condltlon(s) _In tho amount of 1& --- _____
If ..
ONS o~ THIS BAIL BOND ARE AS FOI.LOWS:
1, The defend.,,1 mu5I ""pOOl at nil t1m8o required untlllulle,," I,nal d"poollion ollho co.o,
2, The d.18ndllll mull obey 011 ",nhe' orde,e of It>e b.M aUlhll,hy
3, Thtt defendant muot gl.e Wlhten nollQtlO tho bail aUlhollly, tho clerk 01 court., ,ho di9l,lcl aUomoy, and Ihe COUll ball .goncy or Olhe' deoill".18d DOUn boll
olflcar, 01 any DhanoO of oddlo" wilhln 48 110U" of the dole 01 the chellQe.
4, ",. dafe~n1 muat noilhot do, no, cou..'P bo dono, nOI pormlllo be done 011 hl&lhor bohllll, OilY lIel .s p'osc.lbe~ by Sarllon 4952 01 tho Crlm.. Coda
(relItIng 10 Inllmldollon 01 wlln4l0.81 0' \'Iellrn.) or by Socilon 4953 ((elallng 10 ,o'ollollon aglllnot wltne..tI O. vicllma), 1 B Pe,C,S, fS 4862,4953,
8, The d.'oNlant mult rohln from crimina' aclMly,
6. NO CONTAC . VER.B.AL. WRITTEN,PlIYSICAL.
TYPES OF SECURITY:
o CaslVEqulvlllent DGov't Be9rer Bonds
D _% Cash mSurety Bond
TOTAL AMOUNT BAIL SET (IF ANY): $ ~5.000.00
o Realty w/in Commonwealth
o Rllalty outside Commonwealth
(59 a swretle9 page)
This bond Is valid lor the entire proceedings and until full and linal di$poslllon 01
the case Including all avenues 01 direot appeal to tho Supreme Court of Pennsylvania,
I AORI!I! THAT I WILL APPEl/lA AT All f1UBS!!QUI!NT PRoceeOINOS ASIIBQUIRID AND COMPLY WITH All THE OONDITlONS O~ "J'HF. IAILIONO,
lltlllCliOIalNeOON ...Nov. 71, 1.9QJL
" ._ MECHJJlICSBU!~__ ,_' P,"II8Yl'"''''
(;v;~;;.. D{./...-~
ion.lulfolDtrlndlnll
Signed and acknowledged befer9 m9 this _,
day oU /' 'Ei' I tl1.--:6
fD4. Q ~I,.
~,: L- lV
101;;:;11' .;.oUI,o,ltiUlng t'oIu11y) ,
,.,
_I.....)
JUDGE OR ISSUING AlITHORITV
DATE
My commission expires Ilrst Mondav of January.
PU!ASf. see An^OIf!D "",lE:S FQn AOOI'IONAlINfOA~ATION,
AOPC 414M-1I7
11/23/88 10:17 FAX 766 2238
~
S RETY INFORMATION PAQE . .
TN OJ No:
CO No: OJ Docket No:
ommonw..Kh VII, (OlIfnndant Name and Address)
,DWAm TYRONE SlIOEMAJ(,ER
233 barrioS ton AVe.
'Ul'l'llr Darby, ~A 19082
G ELDllR
raJ007
, \
.--------[lalo Orcharge(ey-----------'----
NEXT COUflT ACTION ,patlll TIme! l.ocation
-() I, ,UqG I : CCI ,() J ,/
MONDAY. Nov. ::J ! '(I, C, ,---
"
0,* €.,fV\('1' c.o
--.,.--...---..-.----.--..--
.- ,tho IInderllgnld surety, have postod socurlty In tho amounq
TYPES OF SECURITY
D CIshlEqulvetent 0 Gov't Bearer Bonds
o __"'" Ollsh 1!tlurely Bond
[I rlaalty w/ln Commonwealth
lJ Realty Outside Commonwealth
]
,.
It
_._~----_..~_....,...~-_.__._,_.__..~--....-_._--~.".
I have read this Information, and I acknowledge that I, my personal representatives, suocessors, heirs and asslgrnJ are
jolnlly and savllrally bound with the defimdant and any other sureties to pay to the Commonwealth of Pennsylvania the sum of
$ , which Is tho full amount of the monelary condition of release In the event the ball bond Is forfeited_
. I understand that when a monetary condltlen of relllase Is Imposed, " thll dllfendant appears at all times required by the
court and satl.flea all the other conditions Slit forth In the bail bond, thon upon filII and linal disposition of the case, this bond
shatl bo void. "the defendant falls to appear as required or to comply with the conditions of the ball bond, then this bond
shall remain In lull lerce, and the lull sum of Ihe monelary condlllon 01 release may be forfeited, the defendant's release
may be revoked, and a warrant for the defendant's arrest may be issued,
WARRANT OF ATTORNEY: RECOGNIZING THAT I AM WAIVING CERTAIN IMPORTANT RIGHTS,
INCLUDING THE RIGHT OF PREJUDGMENT NOTICE AND HEARING, In accordance wKh the law, I do hereby
empower any allomay of any court 01 record whhln the Commonwealth of Pennsylvania or elllawhere to lIPpe.r for me III any
lime, and wtth or without declarations "Illd, and whether or not the defendant be In defaull, to confess Judgment against me,
and /n favor of tha Oommonwaallh of Pennsylvania for use of tho county, and lis assigns, during any tenn or session 01 a court
of record of th. county for tha full aMount 01 the monetary condition of relaa~e set forth on the first page of this ball bond,
and costs, I undol'8tand that any real estate which I have posted as security In this case may be levied upon to collect tho
amount confassad, I waive *nd release any right of Inquisition on thai real estate, voluntarily oondtlmn It, and authorke the
Prothonotary, upon a Wrft of Execution, to enter my voluntary condemnation, I also agree thai any real eslale posted by me
'In thl$ 08" may be sold on a Wrll of Execution, I hereby forever waive and release any and all errol'8 which may arise In any
proeeedlng to confess IUdgmentln this caso, waive all rlghls ef stey of execution, and waive all laws now In forca or laws
pUled In thelUlura which filxfilmpl real or personal property from executfon_
Slnee a copy of Ihle bail bond and warranl 01 atlorney Is being flied in the defendant's cass, It shall not be necessary
to file the ortglnal as a warrant 01 allorney, notwithstanding any law or rule or court to the contrary.
I have read this Instrument oer"ully and knew that Ills true and correOl,
~~.
. 1kJtat"IIIfnIdlftdbMtIIllI,(onl,lllllpl AD")
/ tJPIe'A tlt'I-A ~
&....0...,~b acJ . 11t'~Z
(AdlJrm II $lira,." Iwn, C6mf)My or DlllndIIIlJ
p~
2-)3
Swrlm (1IfIImld) Illd OIlba"lbed hefore me
thI. / I" rvr d'ra.
\,
;C~iQ adL
~-I5,lgnll"rA4D..IltC4 '
My commission expires first Monday of ,Ianuary,
~
.,/'tf
Lo
o 0 as a as any a I relale(j (ees or commissions allowed by law and reasonable costs, If any, of
administerIng Iha oaeh bait program) will be mado wllhln 20 days after fUll and final disposition,
'Rotund 01 all other types of ball will be made promptly after 20 days following full and IInal dlsposllion (Ps,R,Cr,P,4015)
. Bring Oash Ball Receipt to Clerk of Courts or Issuing AUlherlty,
AOPC 4f4A5-91
11/23/88 10:17 FAX 766 2238
p,p clul;sle re 717 249 0779
G EUlER
11/21 '981'7:05 NO.458 01/03
flJ002
"OI'MCl','MW.TH Ol'PEHHSYlVA,.."..
COUNTV OF: ~1.~M
~.
~}
Of:'
Q~~
POuell
CRIMINAL COMPLAINT
--
ILl......... ~ - ~
.-.""""':
COMIAOtM1!'AL TH O~
PI!HNSYlVANIA
VIS,
---
-
IWlr
---
PA f7_
-
1Ja:EN000T:
NAME 8Ild AOtlRE98
"
[g""';;' .........-- ..--
2'\'lbrTl"lllr:lll.Awtt- .._._ ..__
UpjlatJlGy.......__ ~ HIII82
X _ I~:: IA':.::~~ -.aa
-........- --....-
-""'N&.fniw .... I ,....~ttt ~ ....------
_____L---1 __. P~~1!lO
~ -~,,-,-,-,-- -1-"::....".,
OlBlrial ~ olIlot 0 Appro..d DltaPllfO\/lICl ;;;;;.: -
(11Ie dIIlrtotolllllnet mo, lWl'" 1II1llhl ""mptaIMIll. .__1._, IX' bnCh bo op_ by tIlO ellOtl1OYm,mo eomm._1lII prlOr"iIrl!,
.... IlOr.I", 101) .
~Ilol
- JIIIo4,
cmt1
If l\l:.4!,J..A.""
-
-
<- of J\IIalnoIy fIlr COIlW11OlWiMflll-....... Print Clf'T,"l
I, TtIr .IHIhv MAin I ~~
(SIQn8tura 01 Allml"ll ,.. I".ommo_)
(Do!al
2.
0I1IMI........... _ PolIoe ftJdJalc JWl9P1~:U:W
ClOheNJ?l." ~--*i
1. lXll_tho'~/__Ill.WhO_"1Ilo__Hlfo",,_. _" . ___."
B ,_......._",,"" n."",.. lIII_" ""'Uul_lt.....lb.,l t". . ---- ..
'_lIIId...,.Ill_ '.me ond 1lOI'-....tgn.lI.n CIf' n~""lo u",,- to.. 0I1d,
"",,",1'- _ ONIlIna..... John Doo
_1Ito1athlg tIIo ",11II ,.. 01 tho Conwo._ 01 Ponnoytvllllo III
L....... AIIrd'R..c.50~si, ----.I_ 9,WddIoIan
~ Cumb-'nd ] oOU11ll/ono,.;;;;;-j 11/2ll1l1ll ~ 2200 ""I
~~ (lI....._plIIlle/p8I't..pIIoo lhlIlr_hele.I--'"'o1he "-"'~-nl)
L..- DwII...Tr"""'SHO!lM~ ~
Tho___..."",allClllld_
(Itlllllll\'''''''''-VIIlIlA_IIIIIdonlIo_..._,,,,,,,,,_of........,,,.... _""_".,..,____100_,
....-._II..___""_,bo_ lno.......ry___._dOhc__..,_of",_"
-'-'""",,",J
.--...1
PA DR See. 8113: INDIR&eT Cl'lllllllN,Al. CONT!!MP'r . The d"ndllllt did vlalWl the Oftler IIeUlld lD'1der IhII P',~
"romAlxlRAcl. F,R 1m -612 c:t.alllld 0&'04IlIi2, by the Col.IrtofCammon Plett ofOUnme.,...ld County. The PFAfI/o.
\J8.llIZ7 CIvIl Ttnn _ '-ued by 111. HononIble Edger S. BAYl.eV. cI-.cl M;Iy 14, 11lll8.
11/21/98 18;09
TX/RX NO,6575
P.OOi
.