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Home My WebLink About00-06867 lL..,... ~ .L....-~ , ' ~ ,L ,~ ~-.i"j;ij~i SUZETTE RENE SILVIS , Plaintiff' : In the Court qf Common Pleas of : CUMBERLAND County, v, : PENNSYL VANIA : Civil Action - Law JEFFREY WAYNE JONES, Defendant : No, 00-6867 : Protection From Abuse FINAL ORDER OF COURT Defendant's Name is: JEFFREY WAYNE JONES Defendant's Date of Birth is: August 4, 1960 Defendant's Social Security Number is: 178-56-8524 Name(s) of All protected persons, including Plaintiff and minor children: 1. SUZETTE RENE SILVIS AND NOW, this 16th Day of October, 2000 the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows: Pursuant to consent of the parties, which does not constitute Defendant's admission to the averments of abuse in the petition. The following order will be entered: Plaintiff's request for a final protection order is granted. 1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other protected person in any place where they might be found. ~ t ~, , ,- ',:JCi!nl "(' O"T I' DJf,,;j ";;', I, ') :~; J ,C I b I I"";' ~ (''l11jfV,ni,:pi L"\'(J" ('i~):U' '1\t'rV '1y "<I~,;~., ''-f II "_ '-..Iv IJ" PENNSYLVANIA !lll,~;_I,[!)I",>_,,!!! lq~ "'''"'"1 ~~ Jl,__"",,~~ - ^'-'-- - Jji~ili'J1_" - 'H'-jIIlliff!,..,..",..'ll'!-"''''''''., _ '---;Wjl.~, l~i'iill,$'i~~ift?r.r~"'~I'k;;;~F,o_" , ", ,_ ,~ ~E)'Mf.,ffl!' " "",,' JI " ~ ~ 2. Defendant is prohibited from having ANY CONTACT with the Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at Plaintiff's school, business, or place of employement. Defendant is specifically ordered to stay away from the following locations for the duration of this order. Plaintiff's current residence or any otlIer residence she may establish for herself during the term of this Order: 18 East Big Spring Avenue Newville, PA Plaintiff's current place of employment and any other location where she may be employed during tbe term of this Order: AUFirst Bank 3045 Market Street Camp Hill, PA 3. Defendant shall not contact the Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons, 4. The following additional relief is granted as authorized by ~61 08 of the Act: The Cumberland County Sheriff's Department is directed to immediately return toPlaintitf, Suzette Rene Silvis, the 12-gauge shotgun with engraved stock, "Merry Christmas, Jacob Andrew Petty - 198?", which belongs to her son, and was confiscated with Defendant's weapons on October 12, 2000. Defendant shall be allowed to possess his bow and arrows for the limited purpose of hunting during bow hunting season. Defendant shall not possess the bow and arrows within a 2-mile radins of Plaintiff. Defendant is prohibited transferring or acquiring any firearms license or weapons for a period of 6 months from the entry of this Order. The Cumberland County Sheriff's Department shall retain custody of all other weapons confIScated from Defendant on October 12, 2000, during the 6-month period. The Defendant has 30 days after the expiration ofthis Order to petition the Court for the return of confiscated weapons. Defendant is prohibited from having any contact with Plaintiff's ~~ - Lijllli "" ,., ".~ " " ~ ,U--h.-i _I , -I, .' relatives. Defendant is ordered to refrain from harassing Plaintiff's relatives. Defendant is enjoined from damaging or destroying any property owned solely by Plaintiff. The court costs and fees are waived. 5. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: NEWVILLE POLICE DEPARTMENT PENNSYLV AmA STATE POLICE CAMP HILL POLICE DEPARTMENT CARLISLE POLICE DEPARTMENT 6. TillS ORDER SUPERSEDES: 1. ANY PRIOR PF A ORDER 7. All provisions of this order shall expire on: April 16, 2002 NOTICE TO THE DEFENDANT VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WInCH IS PUNISHABLE BY A FINE OF UP TO $1,000 ANDIOR A JAIL SENTENCE OF UP TO SIX MONTHS, 23 PAC.s, S6114, VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYL VANIA CRIMES CODE, TillS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C, S2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S,C SS2261- "". -~~tl'~--. '",,"'~ ~,," ',-,,,,,- ~~-' ,'~ '''"'i!ll!i'\ .' 2262, IF THE BRADY INDICATOR PARAGRAPH APPEARS IN THE ORDER, YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT, 18 U.S,C, 9922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMVNITlON, NOTICE TO LAW ENFORCEMENT OFFICIALS The police who have jurisdiction over the plaintiffs residence OR any location where a violation of this order occurs OR where the defendant may be located, shall enforce this order, An arrest for violation of Paragraphs 1 through 3 ofthis order may be without warrant, based soley on probable cause, whether or not the violation is conunitted in the presence of the police, 23 Pa,C,S, 96113, Subsequent to arrest, the police officer shall seize all weapons used or threatened to be used during the violation of the protection order or during prior incidents of abuse, The Cumberland County Sheriff's Department shall maintain possession of the weapons until further order of this Court. When the defendant is placed under arrest for violation of this order, the defendant shall be taken to the appropriate authority or authorities before whom defendant is to be arraigned, A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police officer OR the plaintiff Plaintifl's presence and signature are not required to file the complaint. If sufficient grounds for violation of this order are alleged, the defendant shall be arraigned, bond set and both parties given notice of the date of the hearing. ~ ignature Defendant ... .l!i:l .~." , . Distribution to: Joan Carey, Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row, Carlisle, PAl 70 I3 Ronald Johnson, Attorney for Defendant ANDREWS & JOHNSON 78 West Pomfret Street, Carlisle, PA 17103 FAXed & Mailed to PSP j., j~,i.' r-toA.S ~ ii". at:r:,' lo./~.(TD r"/ "" - . "",-), ,L., i'~~'illmUlJ~- ",~ .--',':..., "- ""~~~~~~It'iWlf;;!:;{;;:sWiL~,iHij.Wl.li$j"~...;...> ")' ~- . - =~~,~, - ' ." _" ,. ,_, l.~. _ umil;-.,.,"-,,~---.i=,~lililr' ",,-, '111'"' ., "-', r ~ S~ ~, ~ Jl.. t -1= ; ~ r f t ~ ~J~~ ~ , ~ ~ -I: "'" } ~ ~ ~ " "'" -<; 3' >-.... ~ NJ< ~,~ 10/16/09 oMON 15:44 FAX 717 240 6573 I, - - ~ ~"oN~- COMB CO PROTHONOTARY 141001 *************************** *** MULTI TN REPORT *** *************************** .' TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2224 ERROR [ 01] 9p2405331 [ 03]9p2438026 [ 04]92490779 CENTRAL PROCESS LEGAL SERVICES PSP , -'. . OFFICE OF 'IllE PRarHOOOTARY aJMBERLAND a:::uNTY COURnlOOSE ONE COOR'IHOOSE SQUARE CARLISLE. PA. 17013-3387 (717) 240-6195 FAX (717) 240-6573 TO: LS (en!:.. Ptoc"eS5. PA STATE POLICE VIA TELECOPIER FAX H: 717-249-0779 FRCM: CURTIS R. LONG RE: PFA ORDERS MESSAGE : o tIO. OF PAGES (INCLUDING COVER SHEET) , This lJ'E5SCg;J is ild:.::"l1j ally fur the U3e of t:te irdivid.el c:r entity tp W1id1 is is ..d:L~, em may crnt:lin infuurBtim ttat is p:i~, cmficlential em e<al{X: Eron (ji<rlrRJre l.I'l:Et- 'W1ir;t)lp W. If tre mrli of this /I 'YJ' is rot liE interlrl recipialt. }OJ are iErEty rot:if.ia1 ttat ~ dissEmiretial, d.ist:dl.lJtjm (](' a:p,rirg cL this Q'J'lIlU1ica'-...im is strictly JXd1ibit:a:i" If)OJ ta.e r:e::eivs::l thIS -,-- ~',,", .~ '''''''''''i"....'v ht 1P1frl1:l'E errl rel1Jr11 tiE adgirelll ~ to L6 at , ~~~_~l._ 'I. _ ~l-_ . M"' --, ~ , , ~: SUZETTE RENE SILVIS, Plaintiff : IN THE COURT OF COMMON PLEAS OF vs. : CUMBERLAND COUNTY, PENNSYLVANIA : NO. OO-a 5/(] 7 CIVIL TERM JEFFREY WAYNE JONES, Defendant : PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein, If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition, In particular, you may be evicted from your residence and lose other important rights, A hearing on this matter i$ scheduled on the ~ay of October, 2000, at II; U7J ;r.:m., in Courtroom No.).., 4th Floor, Cumberland County Courthouse, 1 Courthouse Square, Carlisll~, Pennsylvania. You MUST obey the Order that is attached until it is modified or tenninated by the court after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six months in jail under 23 Pa.C.S. 96114. Violation may also subject you to prosecution and criminal pena1til~S under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C, 92265, this Order is enforceablle anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico, If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. 92261-2262, You should take this paper to your lawyer at once. You have the right to have a lawyer represent you at the hearing. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. If you cannot find a lawyer, you may have to proceed without one, CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue; Carlisle, Pennsylvania 17013 Telephone Number: (717)249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is requiredby law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing, ~~.J;j'iI!~fiMO\'j-~:~~~~~,^,%if;!!iti-W*iiW"HW.ilitidi~l,.j.v~&i~i:Bi,,.,_;~1ft"~<""!l"~~'''''~"-"''iIiiiI"~''''-.i~' ~'I>i~"~ ~" '111 .. "', ~ ~~ "~ -"'~-' - C) r::: -otF' !]j,-,~-,; 2" :;;::,:"2;/ C/)~, ;::$<: J -r-- ~...~,.' -S:C' 5!;C>' c: ;;>- ::Z! -~ r_llI!lillllll'tll",b ,,' ~, <.:) ,-.- ~.J '::) Ii c::::> ;J -I I 01 '/l-":::; i~v __",[9 -0 -, ",", ,:;..1(,; 5~~? fit (5 in :;0--/ ~. '" i'\,) " - T\) ~ . , .11 .', - ,-.--, _.n_"_ ' " ~ ~ - '11 '~ Zi) SUZETTE RENE SILVIS, Plaintiff : In the Court of Common Pleas of : CUMBERLAND County, v, : PENNSYLVANIA : Civil Action - Law JEFFREY WAYNE JONES, Defendant ~ No, OO-a Ole 7 ~ . : Protection From Abuse TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: JEFFREY WAYNE JONES Defendant's Date of Birth is: August 4, 1960 Defendant's Social Security Number is: 178-56-8524 Name(s) of All protected persons, including Plaintiff and minor children: 1. SUZETTERENEsaVIS AND NOW, on 6th Day of October, 2000 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: Plaintiff's request for a temporary protection order is granted. 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. n , ,-- , , II ,",-' , ,,'~ ", , . ~ ,o~M. '~'I!Ml!ilII!I!l:!Il~,*<-)Jc' 2. Defendant is prohibited :from having ANY CONTACT with Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at Plaintiff's school, business, or place of employment. Defendant is specifically ordered to stay away from the following locations for the duration of this order. Plaintiff's residence: 18 East Big Spring Avenue Newville, P A Plaintiff's current place of employment and any other location where she may be employed: All First Bank 3045 Market Street Camp Hill, PA 3. Defendant shall not contact Plaintiff; or any other person protected under this Order, by telephone or by any other means, including through third persons. 4. Defendant shall immediately relinquish any firearms license the Defendant may possess, and the following weapons to the Sheriffs Office or a designated local law enforcement agency for delivery to the Sheriff's Office, 1. any and all firearms and/or weapons, including but not lllrritedto:handguns 2. rifles 3, shotguns 4, bows and arrows 5, hunting/collector's knives Defendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration ofthis order. 5. The following additional relief is granted: Defendant is prohibited from having any contact with Plaintiff's relatives. Defendant is ordered to refrain from harassing Plaintiff's relatives. Defendant is enjoined from damaging or destroying any property owned solely by Plaintiff. ~ .~ ~ "-'. ., '.'~'C-'~~',"^,l.' 6. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: NEWVILLE POLICE DEPARTMENT PENNSYLVANIA STATE POLICE CAMP HILL POLICE DEPARTMENT CARLISLE POLICE DEPARTMENT 7. The sheriff, police or other law enforcement agencies are directed to serve the Defendant with a copy of the Petition, any Order issued, and the Order for Hearing without prepayment of costs, The Petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. The Prothonotary is directed to file this Petition and Order without prepayment of costs. 8. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL APRIL 6, 2002 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY TIllS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000,00 and/or up to six months injail. 23 Pa.C.S. ~6114. Consent of the Plaintiff to Defendant's return to the residence shall Dot invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S, ~6113. Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S,C, ~~2261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintift's residence OR any location where a violation of this order occurs OR where the defendant may be located. If defendant violates Paragraphs 1 through 4 of this Order, defendant shall be arrested on the charge ofIndirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence oflaw enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse, Weapons must forthwith be delivered to the Sheriffs office of the county which issued this Order, which office shall maintain possession of the weapons until ,-", ~I --~ . Il~~ ,...-I,""," 'further Order of this court, unless the weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the Mtest. Judge ~ Distribution to: Joan Carey, Attorney for Plaintiff LEGAL SERVICES, INC, 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 FAXed & Mailed to PSP , .: ~N"i'e!' ~ _I 0......:.. ~l!!Lt n~ -',' PFAD Number: NVI143743H SUZETTE RENE SILVIS, Plaintiff : In the Court of Common Pleas of : : CUMBERLAND County, v. : PENNSYLVANIA JEFFREY WAYNE JONES, Defendant : Civil Action - Law ~NO.OO- r,//,1 ~ ~ : Protection From Abuse PETITION FOR PROTECTION FROM ABUSE I. Plaintiff's name is: SUZETTE RENE SILVIS 2. I, (the Plaintiff), am filing this Petition on behalf of: - myself 3. Name(s) of ALL person(s), including minor children,who seek protection from abuse. a. SUZETTE RENE SILVIS 4. Plaintiff's Address is: 18 East Big Spring Avenne, Newville, PA 17241 5. Defendant's Name is: JEFFREY WAYNE JONES 6. Defendant is believed to live at the following address: 35 Locnst Drive, Newburg, P A 17240 ->~ ol~ ~~J'","; 7. Defendant's Social Security Number is: 178-56-8524 8. Defendant's Date of Birth is: Angust 4, 1960 9. Defendant's Place of employment is: Waddell & Reed Inc., 4999 Louise Drive, Mechanicsburg, PA 10. Defendant is an adult. II. The relationship between the Plaintiff and the Defendant is: Current or former sexual/intimate partner 12. The facts of the most recent incident of abuse are as follows: On about Thursday, October 05, 2000 On or abont October 5, 2000, Defendant telephoned Plaintiff at her place of employment, and when Plaintiff told him to leave her alone and warned him that she had contacted an attorney, he threatened her saying, "Don't you think that will make matters worse?" Fearing for her safety, Plaintiff told Defendant, "Just leave me alone." and hung np. Later the same day (approximately an hour after Defendant telephoned Plaintiff at her work) Plaintiff saw Defendant's car behind hers as she drove home. Defendant followed PlaintitTfor more than 20 miles to her home, which is on a side street, not on his route home, and waved to her as he passed her at her residence. Plaintifffears for her safety. 13. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor child/ren, (including any threats, injuries, or incidents of stalking) are as follows: From approximately September 24, 2000, through October 5, 2000, Defendant repeatedly telephoned PlaintitT's residence, often called several times a day, from ',.," ,,~ ~,~- ,,~-" -~~'"H'Ile1";' as early as 6:00 a.m. to as late as 12:30 a.m. Defendant also telephoned Plaintiff at her plaee of employment several times, and drove past her residence, cansing her to fear he is stalking her. On or about September 19, 2000, when Defendant telephoned Plaintiff at her residence, she told him to stop calling her. On or about September 14, 2000, Defendant telephoned Plaintiff at her home and threatened to hang himself from a tree because she did not want to reconcile their relationship. In or about the late August 2000, during a one-week period, Plaintiff saw Defendant drive by her house several times. In or about mid-August 2000, Defendant telephoned Plaintiff at her residence approximately 20-30 times one day. The foUowing morning, after he called PlaintitT's residence several times and she did not answer, Defendant came to her home, knocked on the doors for several minutes, and left when she did not answer the door. Defendant telephoned PlaintitT's home shortly afterward, left a message on her answering machine threatening, "I WILL see you.", and later the same day, he telephoned Plaintiff twice at her place of emloyment. On or abont July 11, 2000, when Plaintiff told Defendant that she wanted to end their relationship and did not want to have any further contact with him, he threatened her saying, "It'll never be over. I won't take "no" for an answer." Since approximately 1999 through July 2000, Defendant abused Plaintiff in ways including, but not limited to, shoving her about, yelling in her face, pinning her against walls, drawing his fist back in a threatening manner and swinging it within inches of her face before stopping abrnptly causing Plaintiff to fear that he was going to hit her. On one occasion, Defendant grabbed Plaintiff by the neck and lifted her ofT of the floor. Defendant has threatened Plaintiff saying, "No one calls the police on me; you have no right. You'D be fucking dead if you call the cops." "H I ever see you with anyone else, I'll kill you both." Defendant threatened to burn PlaintitT's house down, and threatened to "have her job" when they were employed at the same work place. In addition, Defendant attempted to control Plaintiff by demanding an accounting of her activities on a daily basis. In order to prevent Plaintiff from leaving, Defendant blocked doorways with his body; hid PlaintitT's purse and/or car keys on several occasions; parked his car behind hers so she could not drive away; rocked the car from side to side and threatened to tip it over unless Plaintiff got out; and followed her to her home when she left him. Defendant also abused his dog, a miqjature Collie Sheltie, by kicking and hitting the dog, and on one occasjoll, ~el'ting the do~ with" whiffle bat. ...4 - " -- ,'-. '--, '~ ,-. ~~i'S1,,,,,, 14. The Defendant has used, or threatened to use, the following weapon(s) against the Plaintiff or the minor child/ren: a. any and all firearms and/or weapons, including but not limited to, handguns b. rifles c. shotguns d. bows and arrows e. hunting/collector's knives 15. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: NEWVILLE POLICE DEPARTMENT PENNSYLVANIA STATE POLICE CAMP HILL POLICE DEPARTMENT CARLISLE POLICE DEPARTMENT 16. There is an immediate and present danger of further abuse from the Defendant. 17. Plaintiff has suffered out-of-pocket financial losses as a result of the abuse described above. Those losses are: lost wages as a result of incidents listed above. 18. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or minor child/ren in any place where Plaintiff may be found. b. Prohibit Defendant from having any contact with Plaintiff and/or minor child/ren, either in person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Plaintiff's school, business, or place of employment, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/ren. c. Prohibit Defendant from having any contact with Plaintiff's relatives and Plaintiff's children listed in this petition, except as the court may find necessary with respect to partial custody and/or visitation with " ~,'- ~- - '" ~~~~""., the minor child/ren. d. Order Defendant to temporarily turn over weapons to the Sheriff of this County and prohibit Defendant from transferring, acquiring, or possessing any such weapons for the duration of the Order. e. Direct Defendant to pay Plaintiff for the reasonable financial losses suffered as the result of the abuse, to be determined at the hearing. f Order Defendant to pay the costs of this action, including filing and service fees. g. Order the following additional relief, not listed above: Order Defendant to refrain from harassing PlaintitT's relatives. Enjoin Defendant from damaging or destroying any property owned solely by Plaintiff. Order Defendant to pay $250.00 to one of Legal Services, Inc.'s funding sources as reimbursement for litigation in this case. h. Grant such other relief as the court deems appropriate. 1. Order the police or other law enforcement agency to serve the Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. Respectfully submitted, Date: \t1AX.1'" .JYv"u~/'. Joan Car 0 Maryann Murphy Attorneys for Plaintiff LEGAL SERVICES, INe. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ~.:!tI -- "~-...... "' - "^ :.c. -,-' "v'~." -" 'It -'I'''tm''-l'''' VERIFICATION I verifY that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S.~4904, relatiBg to unsworn falsification to authorities. Dated: ((}~[~=?, cR 007 WI': ':"^ ' b.l-~ ~~ ~~~~~i2H,ii!~~~4S18~Aj;\l"tH~,!,jf;"OIi!t",~;m,;;'iliH(~jjj~~m"~"i Lllli. '-i~N""fu-'-.~' >=_0""' ~ ~'illJ"~~i?lt111.M.M1M' '&::i. IiI' ftJlldlliii~i!lIiiJjJi ~ ^~~ c ~ ? ~ ~~ .~ ~ ('~ 0(:.. =+- X ~~ o . o \ -cJ ~ ^,' _ ~ ".M~ \.A p c:... ~ <::> ~ s- ~ '1f) :f't :+> 8 ~ ~ i<. Jt t "17 .~ ('t, ~ ~~ ~ ~ .v: c5' ~- ~~-...~,,~-,.~..I r 6 w ~ 1;- ",.. r- :0 ~ -:d cp. ~ ~ QJ -J:::: o ~ (,N -~ 4:: o \, ~ -, --. ,~,-^ ~;;!:/i :z: 1~ ~:3~ .c:::L' p,,,,, ~~: -! -< b-' . () c c, <:::l 'b 'j y I <I Ij " C) C.., D ,-, -., , (J') (~:~ ::::! --"';fH 7:~ :a~~ ':D -< -~L- __J'~ :fJ fv ~-~ 1< . L.I CUMB CO PROTHONOTARY -', """-'jJiil!i'-d~' -~l'f; 10/06/00 FRI 14:40 FAX 717 240 6573 1ili001 *************************** *** MULTI TN REPORT *u ***********$$************** TX/IU NO INCOMPLETE TX/RX TRANSACTION OK 2210 ERROR [ 01]9p2405331 [ 03]9p2438026 [ 04]92490779 CENTRAL PROCESS LEGAL SERVICES PSP ,. OFF'ICE OF WE PROl'flGICYrARY CUMBERLAND COONTY COURTIiOOSE . ONE COURWOOSE SQUARE CARLISLE. PA. 17013-3387 (717) 240-6195 FAX H: psP LS . Cett{rol ?rOCt'SSfflj q - d..- 40 - J 33 I FAX (7171 240-6573 VIA TELECOPIER TO: f'R(]ot : CURTIS R. LONG RE: -P FA OrrJ-evs MESSAGE : .... 0 . ---.;;l- 00. OF PAGES (INCLUDING rovER SHEET) _.ll" '!l1is ~ is inten:i:rl a1l.y fi:::r tre LEe of tte irdiv:idsl cr mtity to Irhid1. is is A \1, 1, ard I1ei antain:infi:mTatia1 ttat is p:iv:i..I.eg3:I, anf:ki:ntial arl 6<BI{:t fmn eli."..!,.., rna Ink "WH,.."nlp Ia~. ff ti"e ~ of this rn:ssa;J'! is rot tie inlanD re::ipient, }'OJ are l"eJ:ety rotifi.e:i \tat inf dis:lEfnir1atim. clistrilut.im cr crpfirg af this CXJIllU\ic:al-....irn is strictly prtUbilH:l. If}Q.l taI.e re::eiw:l ttus aJ1l11.Ilir.:rt:i01 in en>;r. pl.El;u! rol:i1Y 16 imtaiiately ~ te1EP"1:re ard retIJrn tie a:ig:in3l1l:~:""I}> tr. us at b_....~ ,--~ IL.J. ,I ~' ."~~;.lrt SHERIFF'S RETURN - REGULAR CASE NO: 2000-06867 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SILVIS SUZETTE RENE VS JONES JEFFREY WAYNE CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon JONES JEFFREY WAYNE the DEFENDANT , at 0010:19 HOURS, on the 12th day of October ,2000 at 35 LOCUST DRIVE NEWBURG, PA 17240 by handing to JEFFREY W. JONES a true and attested copy of PROTECTION FROM ABUSE together with NOTICE OF HEARING & ORDER, TEMPORARY PROTECTION FROM ABUSE ORDER, PETITION and at the same time directing His attention to the contents thereof. Additional Comments WEAPONS CONFISCATED Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 13.02 .00 10.00 .00 41.02 so;;~~< R. Thomas Kline 10/12/2000 Sworn and Subscribed to before By: me this IP~ day of iO~~ ~ A.D. q't.L/ ()/1':rndL/{ ~ ~ r tho notary . ~"'~""'-",htlljl>.aJ II ~ . -'"~JIl!.; "i,*"~~o:&:lIl:.,,fjd "," , ~ DANIEL D. STEPHENS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. DO -6 '8(7 Cl\\\ \ DOUGLAS L. ZOOK and OAKWOOD HOMES, INC., Defendants Civil Action - Law AMENDED COMPLAINT Plaintiff Daniel D. Stephens, by his attorney, Albert J. Hajjar, files this Amended Complaint, stating as follows: COUNT I - CONTRACT 1. Plaintiff Daniel D. Stephens is an adult individual having a place of business at 900 Landsvale Street Extension, Marysville, PA 17053 (Perry County). 2. Defendant Douglas L. Zook is an adult individual having a place of business and address at 422 W. Main Street, Mount Joy, PA 17552. Douglas L. Zook sometimes trades under the name "Oakwood Custom Homes" or "Oakwood Custom Homes, Inc." 3. Defendant Oakwood Homes, Inc. is a Pennsylvania corporation having a place of business and address at 422 W. Main Street, Mount Joy, PA 17552. Oakwood Homes, Inc. sometimes trades under the name "Oakwood Custom Homes" or "Oakwood Custom Homes, Inc." 4. Plaintiff operates a general contracting and excavation business. 5. From October, 1996, to March, 1997, and from time to time, upon oral requests made by Defendant Zook or on his behalf, Plaintiff orally agreed to provide Defendants with various construction and excavation services on several projects in central Pennsylvania. 6. Plaintiff provided the services as required and billed Defendant Zook therefor. 7. The services are described, and the amounts billed therefor are set forth, on invoices, copies of which are identified, attached hereto and incorporated herein as follows: (a) Exhibit "A" is an invoice relating to the "Limekiln Road" project (in York and Cumberland Counties) and totals $15,681.08 for work done by Plaintiff on behalf of Defendants; (b) Exhibit "B" is an invoice relating to the "Shippensburg" project (in Cumberland County) and totals $6,915.48 for work done by Plaintiff on behalf of Defendants; 402\157 ',il'iliiiilffi" ......., .......~ ~, "~~-'1,If:i!liii~..",;ml~'"'''' ~ (c) Exhibit "C" is an invoice relating to the "Chambersburg" project and "Mt. Holly Springs" project (in Franklin and Cumberland Counties respectively) and totals $9,251.50 for work done by Plaintiff on behalf of Defendants; (d) Exhibit "D" is an invoice relating to the "Green Township" project (in Franklin County) and totals $1,475.00 for work done by Plaintiff on behalf of Defendants; (e) Exhibit "E" is a letter confirming a balance due of $215.00 for an invoice relating to the "Lancaster" project. 8. The total charges shown on the invoices are $33,538.06, of which Defendants have failed to make any payment. 9. Although Plaintiff has made demand for payment upon Defendants, Defendants have failed and refused to pay the balance due or any part thereof. 10. During the period when the work was requested and performed, Plaintiff dealt personally with Defendant Douglas L. Zook and with other individuals who represented to Plaintiff, and as to whom Defendant Zook represented to Plaintiff, that each such individual was an employee or agent of Defendant Zook. 11. At all such times, Defendant Zook acted as an individual and neither Defendant Zook nor any employee or agent of Defendant Zook advised Plaintiff that any such individual was acting for a corporation or any other entity. 12. During such period and from time to time, Defendant Zook and employees or agents of Defendant Zook used the name "Oakwood Homes" and "Oakwood Custom Homes" but made no representation that either of those names was the name of a corporation. 13. Subsequently to the completion of the work, Plaintiff learned that Defendant Zook, and the employees and agents previously referred to, were also acting, at all times, for Defendant Oakwood Homes, Inc. 14. All the work performed by Plaintiff was done pursuant to oral directions as to the specific work to be performed, which directions were given from time to time by Defendant Zook or an employee or agent of Defenadant Zook and these directions requested the work that is set forth and described in Exhibits "A" through "D." 15.. All the work done by Plaintiff was accepted by Defendant Zook and/or by other employees or agents of Defendant Zook, acting for Defendant Zook. 16. Although Plaintiff addressed the invoices, Exhibits "A" through "E," to Doug Zook, Donald (sic) Zook, Oakwood Homes and/or Oakwood Custom Homes, and never used a corporate indicator, no objection thereto was ever made by Defendant Zook nor by anyone acting on behalf of either Defendant. 402\157 Page 2 ',;'''''''-''''''.' , 'tM'~ ~ ~ - ,~ ~_ _..il JI .1 ~ I" ~ ~""'-'-~!Opi,'JoU!;.."d;loo;"", , WHEREFORE, Plaintiff demands judgment in its favor and against Defendants Douglas L. Zook and Oakwood Homes, Inc., individually and severally, in the amount of $33,538.06 together with interest thereon from April 1, 1997, and costs of suit. ALTERNATIVE COUNT I - QUANTUM MERUIT It1 the event it is determined that no oral agreement existed in fact or in law between Plaintiff and either Defendant as alleged in Count I, Plaintiff alleges as follows: 17. From October, 1996, to March, 1997, Plaintiff, upon oral requests made by or on behalf of Defendant Zook and Oakwood Homes, Inc., performed the work set forth in Exhibits "A" through "D." 18. In the course of performing this work, Plaintiff was requested to and did furnish various items of materials, services and labor as are detailed in Exhibits "A" through liD. II 19. The fair market value of said materials, services and labor, at the time they were furnished, was $33,538.06. 20. Defendants have refused to pay Plaintiff the fair value of the materials, services and labor furnished although the same is due. WHEREFORE, Plaintiff demands judgment in its favor and against Defendants Douglas L. Zook and Oakwood Homes, Inc., individually and severally, in the amount of $33,538.06 together with interest thereon from April 1, 1997, and costs of suit. Jiii:; Attorney for Plaintiff Attorney J.D. No. 07069 3003 N. Front Street Harrisburg, PA 17110 Tel: 717-234-9819 Fax: 717-234-9820 402\157 Page 3 Mi'1I'O~,~~""'~'-""" ~- .1 . It ., /." .. ~l ~ ~;, .'r','; f VERIFICATION I, Daniel D. Stephens, do hereby certify that I am the Plaintiff in this matter, that the statements made in the foregoing Amended Complaint are true and correct to the best of my knowledge, information and belief and that this verification is subject to the penalties of 18 Pa. C.S. ~4904, relating to unsworn falsifications to authorities. 1) ~~/:!JS:r~- Daniel D. Stephens 402\157 -,~ - - ~ ~lil"; "ic.'~~''''''~ "\' "I ",-,,1- ~, r W- Wi!. , DANIEL D. STEPHENS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL V ANlA v. No. 00-6857 DOUGLAS L. ZOOK and OAKWOOD HOMES, INC., Defendants Civil Action - Law CERTIFICATE OF SERVICE I, Albert J. Hajjar, do hereby certify that I am this day serving the foregoing Amended Complaint upon the persons and in the manner indicated below, which service satisfies the requirements of Pa. R.C.P. 440: By first class mail addressed to: C. Grainger Bowman, Esquire 114 N. Second Street Harrisburg, PA 17101 January 8, 2000 402\157 -^diJW~~' = ,- ~ '~~'.iIlo. 'no I~"~<:' "T :; ", '. \ " ~ , ,I, ,.', I' r l. ','l',.' .' ,..' Oi:J,...~\',~.f,'-'.'. 11 ~';:I:', \,~.:,. ,.,.... ., . ", .: .j . ,-'l . '" . January 1 0, 1997 Oakwood Homes 336 West King Sl. Lancaster, Pa. Re: Limekiln Rd. New Cumberland, Pa. 10/31/96 Delivery of backhoe Delivery of loader ,.... . ; " .", '...., ,._~I~ .J, ." y ,. " ., 55.00 70.00 Lot 11 Dig waler line - footer drain place slone and cover ~ Backhoe Remove rock - loader . , Lol16 . Water line trench - backhoe Lot 18 Clear rock & grade - loader Backhoe loader' labor 3.7 8.0 8.0 203.50 560.00 160.00 -1- h \. ~ 6~'~ (( (0 ,];iJ~,,,, , i .;,.:.,(' ,........,;:j. *,,--; ,-,",, "l , ) : (-~ . '. ~ " , J ., '\; ."';-;" '....-. '.,,' , ,:,' ',,"\ :~.. .....,. ''ll',~" ~~~~. ~ IL.~, ~~I . , ;J;_ " . .,~ .', :. . ,''':." . : -{"; " ." ", " " ',' ".~ ' , ~~Li, ,-';, '. .' 11/1/96 Lot 11 Bury trees, push off dirt that was being hauled froin Mt. Holly - backhoe Lot18 Push off fill - laoder . Lot 14 . Finish digging electric line and take dir away from back wall - backhoe' Lot 15 Grade yard and driveway - loader Dig out for stoop, pull stone out of driveway - clean up debris and take to trash pile - backhoe Lot 16 Start grading - loader Lot 18 Push off fill Backhoe loader , " 8.5 7.5 467.50 525.00 11/4/96 Clean up debris and haul- labor & truck , Lot 17 Bum up log pile and bury - fill lawn area front - lift tank and reset - take out dousing tank " Lot 18 . Grade - bad rock conditions,-Ioader -,haul dirt from lot 15 Labor 7.0 140.00 backhoe 5.6 308.00 -2- "'" 11~_'l\>;~ ,', t , , , " \ 1\ fLl.\ , l?'l=- n.,. v\IO , ~" oJ __JI~' - .~ " -:" u ",- ~ ~l- ~ - ,Ii < -_r.I"",,. < '. . '. ~~ti~YJ.;;ij!,?f' ..' ."' .',' (;". ,.. ",," :'" . " . -.. '. ~'~ . ;"" ' , , ...". ..' '-.' ~";!.. 11/4/96 con't loader truck Pipe PVC 2" x 10 primer PVC DWV 90 PVC DWV 45 PVC DWV 22 PVC DWV coup \ 7.0 2.0 20 ft 1 ea 2ea 2ea 2ea 1 ea 490.00 90.00 20.94 11/5/96, lot 11 Haul fill from lot 15 to lot 11 truck & loader " lot 16 Dig out front of house for footer for brick - loader & backhoe Lot 14 Dig well trench - regrade driveway - backhoe" Backhoe truck loader 5.8' 4.2 8.7 319.00 189.00 609.00 11/6/96 Lot 16 Put in pipe, dig behind house footer, dust and cover water line - labor Lot 18 Dig electric line, dig water line from well to house, put in schedule 40 3" pipe and fillings Lot 14 Removal of rick front driveway and regrade - loader , '" -3- , , \,\, ',' ~~tl~ -;) \ 0 ,. ;. 'ru~.,,,,,,,-, '. .: .1; .. . ."" 1IkiI1. ,_ ~. "~ "',~",~;. '. .. .. ,,' . .~. , ., 1~"':"~,: . o 11/6/96 can't . Lot 7 Cover wires, remove piles of dirt - truck, backhoe, travel Loader 3.0 backhoe 7.5 Truck ' 4.0 Schedule 40 pipe - 3" 60 ft PVC DI/IN Coup -3" 5 ea PVCDI/IN 45 degree 1 ea PVC DI/IN 22 degree 1 ea 210.00 412.50 180.00 total 62.32 11/14/96 Lot 16 Deliver backhoe 55.00 Cover electric line, dig out front stoop - place stone - backhoe & labor Lot? Cut driveway, stone, dig back of front level stone drive, set steps, grade Loader 1.6 112.00 , Backhoe 5.7 313.50 Stone 11/15/96 Transport equipment Lot 11 Put up safety fence, haul dirt, take down trees lots 19-20-21 Straw 12 bales Bobcat wlbreaker . . laborer wlchain saw Stone #3 (3A) 19.15 ton Stone #1 (4) 19.65 ton 36.00 370.00 255.62 -4- \. , ~~' ~~ " ~,\o , - -w~<. ~. _~ J ~. '. '. . . '" ,'. 'r ;;.~;;-i',;:.\" I' 11/15/96 con't backhoe , truck 11/16/96 Lot 16 Tar foundation - backfill ~"".~ ~ _: 1: _."~I",", , 1,- ',"1 , ' 11..l',1 ., '1'1. '\'" ',' 7 hrs 5 hrs 385.00 225.00 Lot 15 Gather debris and burn tree limbs, cut up trees, put in well line, put in conduit, dig and cover grade, dig electric line Lot 11 Electric line at well connector conduit Delivery loader Truck loader Backhoe Bobcat labor 3.2 6.1 ,8.2 4.1 9.0 70.00 144.00 427.00 451.00 180.00 11/18/96 Lot 12 Cover septic tank and finish Wires - backfill trench Lot 18 Cover rock grade and backfill. Put in electric conduit and telephone lines to lot 18 Haul fill from lot 14 to lot 18 Lot 14 Haul stone to lot 14 -5- .,. ""'[-~,, "',,"''::, I \. " l\~t\ f7 1<\ t~ ' s\t f) , ....- _I"-"Ii!.-"'~'"~~ l'~\'~~;1::'';'''l.>''-; ,;,;~ II"" ~ ,.. .' '."'" 11/18/96 con't Lot 7 Start to backfill lot 7 Lot 17 Dig well, an cover fire Backhoe Bobcat truck loader . labor cement schedule 40 3" rvc DWV 45 rvc DWV 22 rvc DWV Coup. 11/19/96 Lot 12 repair sewer " ..loJ ,:'.,1,..... ,-.J ,'"!:'l' . ~ , .... ."," ,J.-.-' ~\. , .' 5.2 2.6 4.3 7.4 2.5 1 pI. 60 ft 2ea 1 ea 8ea Total Lot11 backfill trenches around foundations and steps ..,1_, "" ,= , 1 '.' 286.00 104.00 193.50 518.00 50.00 71.31 Lot 18 cover fire, spread straw, cement hole around pipes for well line miscellaneous materials lot 16 cover trenches, grading lot 20-21 stone driveway, grading, place pavers, take trash out haul to bum area lot 14-15 cover trenches, grade put in.elect. lV, telephone in conduit, 2" pipe loader 4.7 backhoe 6.6 labor 10.6 bobcat 2.1 truck 3.0 , -6- .",."'. 329.00 363.00 212.00 84.00 135.00 - ,j "~~;m~,;k1:": 1 \. ...... " (?,~ \'~ . . ~\(O :' ~- -.~~~~ ~~~ _-_- ~<l~ -I -1-" . ~ :":,' . ~~lih~~;~"b'~'! ;:;;..;;'~,~'\ !.,.,~.!'.L'.~: :i '[,~. ~',\:; "t,'i,r;: :, . i,,:.' <.".'. 'i'/":':':/\:::'~' "_"~: ,>~.~:' .: ',' e;: :. ~"... , ,.-; . . 11/19/96 con't Stone #2a Stone #2a Compresion splice kit 3 wire 3/4 x 66 all weather tape 1 ea Duct seal, 1 Ib 1 ea Silver duct tape 2" x 60 yd 1 ea 20.35 ton 18.60 ton 3 ea 124.58 113.80 Total 22.20 .11/20/96 Lot 12 cover septic system - finish grade, finish wires Lot 18 . .. Backfill well trench - truck haul stone - haul fill from lot 14 to 18. start to fill and grade to cover rock put in elect. lV, telephone arid place in dust. Lot 17 load clean up fire debris, backfill trench fill around foundation truck haul fill Lot 14 backhoe - stone drive, level loader 7.4 bobcat ...- 2.6' backhoe 5.2 truck 7.5 518.00 104.00 286.00 337.50 11/21/96 ' Lot 11 grade lot loader spread straw 14-15-16 straw go for materials 1.9 2.0 9 bales 133.00 40.00 27.00 .;. LotH dig sewer line ',.'. -7- , - ~.!Il!!lil!j-A lliih ~-"'~if~'jl",i" 'l . ,i"' \. I '" e~l\ ',. 1\ \ () \. ~~~lll~lll>.iI!IlI.Il <<~~~ =-~, . -~ .II ._" " ~ " j' '~~'" .-' Ir~Y:":;i,"':, . , ,. '. "":\1",, , .' : ~'~":"i::( ". . . .' . '.' 11/21/96 can't . ,lot 18 backfill and grade, clean up materials & debris loader 6.5 hrs 455.00 backhoe 1.0 55.00 bobcat 2.0 80.00 PVC primer 1 ea. PVC DVVV 4" x 20' 40 ft. PVC DVVV coup 8 ea PVC DVVV 45 5 ea 82.01 11/22/96 Go for materials for sewer repairs to lots 17-18-11 Lot 7 Put in wires for pump - trench 300 ft aprox., cement hole where pipes went in Lbt 18 Grade, cut hole in foundation Lot 11 . Raise bottom wfstone, raise tank out of ground, grade to get some fill to rear where pipes exit house . Go for materials loader baokhoe bobcat schedule 40 pipe 4" PVC DVVV FE adpt , . PVC DVVV thrd plug 2 hrs 4.0 hrs ' ' 6.0 hrs 4.0 hrs 40 ft 4ea 8 ea 50.00 280.00 330.00 160.00 total 69.70 11/25/96 Lot 17 Tank was filled with mud, had to pump out water and remove mud, do resistance test, rewire pump, backfill tank, grade area, move topsoil pile, go for fittings :.' :_f ~ :' '. I,' -8- ,', ' '.i;" ,i', , ~ ~5'/l';!l;:WJ~'''''!', I: , I , , , , \ .. , t'\. \ ~i~ . ~\\D I , ~ ,ii<_~ ~~'-.J;..j,_d"'"""'''''=~ ,,~~ ,~I " .,JLIlI. I ",. . " "', "" , ~, . ' f' I'.. I ,'S:l'.~',\. .. .. . ;.....: , ...;~.~; ", .' ( '.' '. '.'; ~ ~:. .'.,' '. " ',' ,-. . . , I'" 11/25/96 con't . .Lot 11 Reset septic tank, repair sewer, reset with loader and slings, backfill and grade, put in pipe from house to tank - dig trench with backhoe and backfill . loader Bobcat backhoe labor 5.9 1.3 1.4 8.5 413.00 52.00 77.00 177.00 12/9/96 Lot 17 Backfill partial, di electric trench, drain water, backfill by front stoop, go for parts backhoe labor 1.6 1.5 88.00 30.00 , .' 12/19/96 Lot 7 . Repair sewer, wires burned at tank connection, grade driveway and stone backhoe labor 5.0 5.0 100.00 275.00 12/30/96 Lot 16 . Terrible mud conditions - cut off bank, grade, stone area Lot 14 Move dirt, place stone Lot 17 Stone more of drive -level and grade' -9- ,'.,." ,~~< ~(' -~~g",- ! , i. \ " . \ 'f\..lJo.. ~'no . Q\\\ ;m;'~'- ~., .' u... ~.1 . ~ .' t '" .' , . . ". I .....'...........,'.."........:.".:..:,.".......:.,...,....,.,..'...'.,....,..,'.......:.:...... ~~.m.'f.'J;i~~~..':!t.,i\~;:,.~.j:.ii.i;l,~:;~-!,-T'; l";:";",;:'_.~, 1,,,,:,,;;';':':~;~'1; ;,:,:~';';:!::~jt~tA., ~ ~ "1 ~ . , r , , "'t';"':1-' 12/30/96 .. -'.,..,;'-:., Lot 11 Cover septic tank and wires at house, main electric cable cover pipe at rear of house. hackhoe labor 5.0 5.0 Total amount due . " -'--- 275.00 100.00 $15,681.08 - ,....... \. 'I'. u,''I;. . \'l'.. ttf\ \t:\\~ 1l!tlI~ll&liiiG .~ ~ .. ,'. ( ';' .: i; ( .' ! , I ",.!IJ '''m ,~~,-" 1",,-_, --"qa~"~1iO " , .', ) 't, >. ],_,,'-.',0 ~ll '--'iJr~,~; .4.. ," L' '. '''." ~ ',j, ;... '~ " ""_, . ;,l~ :;1;. ':";',:"\' . . . March 1 0,1997 ", Oakwood Homes P.O. Box 187 Paradise, Pa. 17562-0187. INVOICE Install septic system. on property located on the NN side of SR 533,0.8 mi NW of RT. 11 in Shippensburg, Pa. Permit NO G-37745 , Total amount due for sewer $4200.00 ADDITIONAL WORK REQUESTED 1/15/97 Work on pipe under house. Pipe, coupler and labor to repair utility pipe stub. This took two hours working on back to make this repair ,-,., , 55.00 -1- '.'1. 'I 6\\~ ,\ t?, f " / c';\.. ;;,,- ,.1 "",",""",",,"""..,,,,,,,, f-, . ... ", '~. IL........ I . I,' ~_.-,-' ~ tlt~J'!i~~,~"') .-- , . ~'" :' :" , " .i;:.'.,:\'l:',i"" ; .j ~ .;, ',,;..J '-.. ,. 1/16/97 Rock encountered in 8 holes, had to extend pipe, stone had to be put in hole to prevent settlement at corner of footer . backhoe stone pipe, sch 40, 4" 8.0hrs 440.00 30 fl 30.21 1/20/97 Take out rock all day. backhoe labor Used backhoe, drill, breakers, bits, expanders 8.4 hrs 462.00 . 8.4 hrs 168.00 1/21/97 Continue to remove rock compressor w/jackhammer labor 8.0 cut saw, stone blades backhoe 5.1 2 points 2 blades 195.00 160.00 65.00 280.50 52.47 47.17 1~~ I Very difficult, frozen ground. Dig water line, put in conduit, dig runoff at corner of house to allow water to run off. '.' Backhoe 5.2 286.00 labor 5.2 104.00 2/6/97 Electric line put in conduit & cover, materials, concrete & couplings backhoe . 4.0 220.00 .,....: I. -2- .' '. ,:,,'\ 'I ~ 'f.l\~.~. v\~ mUlli-- ,;'; ;,l:,II\:\~\I,\h::i~~'>:r,.::, ..~.., 11'''''' . r , _ ,--.J~._ ~_~. _ ,_~ ~': ... .", I .. ',. 'l'a~':'..;", ., .., '. 2/6/97 con't labor pipe, sche 40 3" couplings cement .' l,.'.i;;,\:' ;" ", 4.0 80 ft. :J.'. ~ ' TOTAL AMOUNT DUE 1-: I ~ I~ ~ c' Terms: Net 10 days 11/2% per month, Delinquency charge after 30 days. Any descrepencies or questions on billing must be submitted writing within 10 days from receipt df invoice. , " ,i. 80.00 '70.13 $6915.48 ~~"'"""'''~~~~'''-W~,;"-,,,'' " I \ 1)..-\ . {~~ ~,\;; -..I ','g,'"'"' '~~''',;j."",~, '<'0"""'_ ~o~ f '.. ffl~_f,~:ll:'t~-:~~!;,~F ~...:,! ~: ", "',,:\,' .,'" :/'! . \.,r".. ._' .: .. April 15, 1997 . Oakwood Homes . Doug Zook 166 Farmington Lane, Lancaster, Pa. .17603 '.' ,:' " I, . .1'... . \,. 0< II. "I ~ I . . ~~ ~~o~" _"'""~.~~'O~'~"~" ~.'<l'taillll:Sh-':"', , .f CORRECTED .INVOICE CHAMBERSBURG 2/24/97 Cut in swails throughout the project. materials, haul fill to next farm. Deliver machines backhoe bobcat labor straw 2/25/97 go for more straw . truck labor bobcat . pickup operate other loader straw . backhoe , 7.5 hrs 7.5 hrs 7.5hrs 12 bales 3.4 hrs 3.75 hrs 5.7 hrs 3.0 hrs 3.4 hrs 25 bales 7.6 hrs Work on the road berms, locate straw, and -1- 85.00 412.00 300.00 150.00 36.00 153.00 75.00 228.00 60.00 85.00 75.00 418.00 ~ ~.: .: , ~... ..... \t ',. Q'f- . . \\~ ,.... . ".< " ,-"~, "';d ~' ('_L-""'~" ". I . "" ~ II,. - - I ", .. ,.~I;~~,}j-'l;' ' , .,... j.' I" " , , :. 2/26/97 vi be roller backhoe bobcat truck labor 8,0 hrs 8,0 hrs 4.0 hrs 8.0 hrs 140.00 440.00 320.00 180.00 16.0.00 2/28/97 backhoe bobcat. vibratory roller truck pickup truck labor 8.0 hrs 6.5 hrs 4.0 hrs 4,5 hrs 1.5 hrs 3.0 hrs 440.00 . 260.00 70.00 202.50 30.00 .60.00 NOTE: SEWER PIP WAS PUT IN 1" UNDER GROUND. 3/5/97 & 3/6/97 Engineering consultation 3n197 cut swails, conditions were very muddy. . Vibratory roller 4.0 hrs truck 2.0 hrs bobcat 3.6 hrs backhoe 3.4 hrs laboi' 2.5 hrs 3/10/97 Grade and level, go for stone for driveway backhoe 7.0 hrs bobcat 4.5 hrs truck 1.5 hrs vibratory roller 4.0 hrs labor 2.0 hrs . 3/12/97 'Put in storm, made changes indicated by township grade and stone backhoe 8.0 hrs '. 440.00 bobcat 6.5 hrs 260.00 J" __ .' ~ ~ "O~ ~ .. -'.r~~'m-( . , '. \ . !. ,. , ,. \. ... . \'(, -\, . t\'-\ "'" ',-~''''''~ -'~'=, ..~~-~~"... . . ~~, .--, " "<' -,j . ll~~~~\:~.;:" ,~. ~ I'" _j' 't..j ;:: . 'f r,t" , . ". .' . . . ,. . ,r, , '.' -2- 3/12/97 con't tr\Jck pickup truck vibratory roller 2.6 hrs 1;0 hrs 8.0 hrs 117.00 20.00 140.00 3/28/97 backhoe truck 4.0 4.0 220.00 180.00 MOUNT HOLLY SPRINGS 3/13/97 Remove curb, put in concrete wall. grade, tree removal stone and recut waik, haul concrete from truck to holes, haul debris and stone transport equipment - bobcat & backhoe 200.00 backhoe 6.0 hrs 330.00 bobcat 7.6 hrs 304.00 truck 3.5 hrs 157.50 chain saw 55.00 . cut saw 65.00 labor 9.0 hrs 180.00 Diamond blade 20.00 3/17/97 grading bobcat labor, 1.5 hI'S 0.5 hrs 60.00 10.00 3/20/97 Stone driveway behind house Bobcat 1.5 hrs labor 0.5 hrs 60.00 10.00 3/24/97 ,grade around house and load dirt backhoe 5;0 hrs 275.00 -3- \. . :', , '"'~jl." t' f:i :, ,. i. It. \.'-f;l'" ' ( '\.- \(~ . ~\~, i1 . I ...i.I1iiiIl<iIiIlil"'"" ~~ "_~.'4". ",', 'J"'Iil'~~~"~ ,~ ,~ . .. , \a~~\lf'ft:r,"'" . f. .:' \ i _b" . .,' , ", . : ;j:..~ '- '- '; '~ -, '1", :' '.':'f,t '~ ': ~;:.. I': 3/24/97 con't bobcat truck labor 5.0 hrs 5.0 hrs 3.0 hrs 200.00 225.00 60.00 TOTAL AMOUNT DUE $9,251.50 Terms: Net 10 days 1 1/2% per monlh Deliquency Charge after 30 days. Any descrepencies or questions on billing must be submitted writing within 1 o days from receipt of invoice. NOTE: The 'price of straw changes depending on where it is purchased ',' '-" - L '111;7 'Mt;<f Ii \. i,' v.. " . \'( t 'f-~\J( ._~-o _ ~. , ' , b J_ , , I ~J - ~ ~" , " _~ I' '. , ,~, J; .... .1', ," ./ ..,f"'" . , ' ;; , t .....'. ','1. " ' '",'..,.' " , QL\NIEL D STEPHENS COMPLETE LINE OF EXCAVATION DEMOLITION '. SEWAGE & SEPTIC INSTALLATION , , . . GENERAL CONTRACTING , , ',' ,. ." ',,', . . 900 LANOSVALe STREET EXTENTION . MARVSVILLE.. PA 17053 ' " ,I,:,:';'. &rij , -'" i~V; I,' ' , , ,.," . PHONE (717) 957.4463 July 1,1997 . ';" Oakwood Custom Hoines Donald Zook, . ,,',' , 166 Farmington Lime, ., Lancaster, Pa, 17603" ' V::ZY- (, i; '3 ~ 65""."'1 . ,'.-. I. \.. " "-""'''. ,.INVOICE " 1<', March 5 & 6, 1997 Consultation fees for meeting with Green Township regarding Tatoo and Sunset Dr. in Chambersburgat site and Township building .\ 10 hrs. @ $75.00 $750.00 March 27, 1997 Take machine to waste area, load up manhole pieces and miscellaneous pieces of pipe that Rick Wolf instructed us to move approximately 1 month prior. Take , new septic tank lid to Shippensburg, grade around area to the satisfaction of owner and he indicated that things were fine Truck 5 hrs. 225.00 trailer 5 hrs 200.00 machine 5 hrs 200.00 helper 5 hrs 100.00 .'. J Before these items were removed, they were loaded on my trailer per the instructions by Rick Wolf and taken to the top of the hill were they sat for days. ',\ Then Rick Wolf told me io dispose of them. In review with my attorney, he informed me to charge for these items. There charge forthe work at Shippensburg, but the completion of the work for the septic system Total amount due $1,475.00 ... e~~J "' ,\ \ ) "jllilllf ',~...~ " "~ ",;:' . .. .. ,.,,' COMPLETE LINE OF EXCAVATION DEMOLITION SEWAGE S; SEPTIC INSTALLATION .. [)\NIEC D STEPHENS . "c.;.. I,,)\_.r . I. . 'GENERAL'CONTRACTING.. 900 LANDSVALE STREET EXTENTION MARYSVILLE. PA 17053 ." " . June 9, '1997 '" J.... '. '. Oakwood Custom Homes 166 Farmington Lane' .\ Lancaster, Pa. 17603 Attention: Accounts Payable I have requested at various times an explanation as to why you deducted $215.00 from my Invoice on the Lancaster Job. . Please fax a copy of the invoice with the items deleted and why they were deleted. I feel that I am entitled to this explanation, J Sincerely, . '~~'D~ Daniel D. Stephens .' , " ,,'. :\ -. -;...,- -I~'~".!_i;;-' ! PHONE (717) 957.4463 . \\ II E. ,. ~ i- \ . \ \' lIJl!.il!iill,~"J"'-~~~:l>~~~'~'1I1g1001ilit--li!!l,~,wtMl!i!iiiil'~-'~'-i!-~' .iIiI!"tor ~.'-ililt.d ".-' "-,- .::!; - .. . :!! i 'I' 0 0 () '~- C ''Tl '--- , -0 , . ," I+i , I ^. I I :z C (" -~ ,_. -'l ~5~ ^^ , r-'. ^^^ , <- , .l >: .^ ^. .^ -..-. z -"." =< :=0 cO .< ((3 ~. -- - ~ .~~". ~- '" ~ "I ~ ~ ~, Jiiiiiill<<M;i-dl" SUZETTE RENE SILVIS, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSY[V ANIA vs. CIVIL ACTION - LAW JEFFREY WAYNE JONES Defendant : NO. 00-6867 PROTECTION FROM ABUSE M AND NOW this tt day 0 RDER , 2001 a Rule is granted upon the Plaintiff Suzette Rene Silvis to Show Cause h the relief requested in the attached Petition should not be granted and all weapons previously confiscated from the DefendantlPetitioner, Jeffrey Wayne Jones by the Cumberland County Sheriffs Department should not be returned to him. Rule Returnable within I ~aYs of the date that Plaintiff/Respondent is served with a copy of this Petition. BY THE COURT, ~ ~O\ ,0 o ;'1 I I If , iii, i:: ~i " Ii Iii ~ ~I II ;ii :11 :'1 ii' ~ , II ~I J,i _ Wi ~~ ""Pl!!I!l~ =, , ~ , ""~- - '-' ."" '~"_". ~.,,_~,.,~_ M"~~ '" ,.~ ._.~ M_'~'", {)~fjCE OF .,... "L<:;;--X)iARY Olt'inY-i! Pc: ': 0'< I" 4 _. '-# CUMBEF;LJ~,i\i:) cOut\rrv PENNSYLVANiA j, J~ .,,~ ,H!!,L;IJl't$;ojl_'f~,,\tIWl1>~~"~~~~~\\P!~ !llWi:W"~ 11mB , J,~ -' - <, 0' {$,,$,_,_ SUZETTE RENE SILVIS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JEFFREY WAYNE JONES Defendant : NO. 00-6867 : PROTECTION FROM ABUSE PETITION FOR PARTIAL RELIEF TO THE HONORABLE, THE JUDGES OF THE SAID COURT: The Petition of Jeffrey Wayne Jones, the defendant in the above captioned action by his attorneys, Andrews & Johnson and Ronald E. Johnson, Esquire, respectfully represents that: 1. The Plaintiff in the above captioned action is Suzette Rene Silvis an adult individual who previously resided at 18 East Big Spring Avenue, Newville, Cumberland County, Pennsylvania. 2. The Defendant in the above captioned action and the Petitioner herein is Jeffrey Wayne Jones an adult individual residing at 35 Locust Drive, Newburg, Cumberland County, Pennsylvania. 3. On October 16, 2000 pursuant to an agreement entered into by the parties a Final Order of Court was entered against the Defendant by the Honorable George E. Hoffer, President Judge. (A copy of said Order is attached hereto and marked Exhibit "A") 4. Paragraph 4 of the Final Order of Court referred to above provides that the Defendant is prohibited from transferring or acquiring any firearms, license or weapons for a period of six months from the date of this Order. The Cumberland County Sheriffs . . - -~"-'U ,,;'k ,1~i1':"l'iI,' Department shall retain custody of all other weapons confiscated from Defendant on October 12,2000, during the six-month period. The defendant has 30 days after the expiration of this Order to petition the Court for the return of confiscated weapons. 5. The six-month period provided for hereinabove expired on April 16, 2001 and less than 30 days have elapsed since the termination of said six-month period. WHEREFORE, the Defendant respectfully requests your Honorable Court to enter an Order vacating that portion of the Final Order of Court dated October 16, 2000 prohibiting the Defendant from transferring or acquiring any firearms, license or weapons and further ordering the Cumberland County Sheriffs Department to return to the Defendant all weapons previously confiscated from him on October 12, 2000 or at any time thereafter pursuant to the Final Order of Court. Respectfully submitted, ANDREWS & JOHNSON 1.,_ - , ,". ~ ~"'(.iiliI!l!ML.i!!it" OCT 1 6 zoorJll SUZETTE RENE SIL VlS, Plaintiff : In the Court of Common Pleas of : : CUMBERLAND County, v. : PENNSYLVANIA : Civil Action - Law JEFFREY WAYNE JONES, Defendant : No. 00-6867 : Protection From Abuse FINAL ORDER OF COURT Defendant's Naine is: JEFFREY WAYNE JONES Defendant's Date of Birth is: August 4,1960 Defendant's Social Security Number is: 178-56-8524 . Name(s) of All protected persons, including Plaintiff and minor children: I. SUZETTE RENE SILVIS AND NOW, this 16th Day of October, 2000 the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows: Pursuant to consent of the parties, which does not constitute Defendant's admission to the averIilents of abuse in the petition. The following order will be entered: PlaintitT's request for a final protection order is granted. 1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other protected person in any place where they might be found. EXHIBIT J A -"~ , .^ 2. Defendant is prohibited from having ANY CONTACT with the Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at Plaintiff's school, business, or place of employement. Defendant is specifically ordered to stay away from the following locations for the duration of this order. PlaintitT's current residence or any other residence she may establish for herself during the term of this Order: 18 East Big Spring Avenue Newville, P A PlaintitT's current place _I)f employment aud any other location where she may be employed during the term ofthis Order: AllFirst Bank 3045 Market Street Camp HiII;P A 3. Defendant shall not contact the Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 4. The following additional relief is granted as authorized by 96108 of the Act: The Cumberland County Sheriff's Department is directed to immediately return to Plaintiff, Suzette Rene Silvis, the 12-gauge shotgun with engraved stock, "Merry Christmas, Jacob Andrew Petty - 198?", which belongs to her son, and was confiscated with Defendant's weapons on October 12, 2000. Defendant shall be allowed to possess.his bow and arrows for the limited purpose of hunting during bow hunting season. Defendant shall not possess the bow and arrows within a 2-mile radius of Plaintiff. Defendant is prohibited transferring or acquiring any firear-ms license or weapons for a period of 6 months from the entry of this Order. The Cumberland County Sheriff's Department shall retain custody of all other weapons confiscated from Defendant on October 12, 2000, during the 6-month period. The Defendant has 30 days after the expiration of this Order to petition the Court for the return of confiscated weapons. Defendant is prohibited from having any contact with Plaintiff's , ".~ "t&' 1ilGili~0.\ relatives. Defendant is ordered to refrain from harassing Plaintiff's relatives. Defendant is enjoined from damaging or destroying any property owned solely by Plaintiff. The court costs and fees are waived. 5. A certified copy of this Order shall be provided to the police department where Plaintiff resides and.any other agency specified hereafter: NEWVILLE POLICE DEPARTMENT PENNSYLVANIA STATE POLICE CAMP HILL POLICE DEPARTMENT CARLISLE POLICE DEPARTMENT 6. THIS ORDER SUPERSEDES: I. ANY PRIOR PF A ORDER 7. All provisions ofthis order shall expire on: April 16, 2002 NOTICE TO THE DEFENDANT VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S. 96114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYL VANIA CRIMES CODE. THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. 92265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C 992261- -<- 1~ullll!lll';W'b' """'~, ~ ~ .. ,II "' ~I flJlil :",~" 2262. IF THE BRADY INDICATOR PARAGRAPH APPEARS IN THE ORDER, YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT, 18 D.S.C. 9922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION. NOTICE TO LAW ENFORCEMENT OFFICIALS The police who have jurisdiction over the plaintiff's residence OR any location where a violation of this order occurs OR where the defendant may be located, shall enforce this order. An arrest for violation of Paragraphs I through 3 of this order may be without warrant, baSed soley on probable cause, whether or not the violation is committed in the presence of the police. 23 Pa::t.S. 96113. Subsequent to arrest, the police officer shall seize all weapons used or threatened to be used during the violation of the protection order or during prior incidents of abuse. The Cumberland County Sheriff's Department shall maintain possession of the weapons until further order of this Court. When the defendantisplaced under arrest for violation of this order, the defendant shall be taken to the appropriate authority or authorities before whom defendant is to be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police officer OR the plaintiff. Plaintiff's presence and signature are not required to file the complaint. If sufficient grounds for violation of this order are alleged, the defendant shall be arraigned, bond set and both parties given notice of the date of the hearing. TRUE COpy FROM RECORD In Te;;Umony whereof. I hera unto set my hand and tile seal of said Court at Carlisle, Pa. Thill /t.Q;!:Y ~~ ~ c"-' . AfJUZ: . Prothonotar1 . BY THE COURT: tS)~ L ~ I George . Hoffer, P. udge Date ignature Defendant . ,Il. ". ~~ '-'. ,~'k<"J,;I' Distribution to: Joan Carey, Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row, Carlisle, P A 17013 Ronald Johnson, Attorney for Defendant ANDREWS & JOHNSON 78 West Pomfret Street, Carlisle, PA 17103 FAXed & Mailed to PSP ";'1 ',,> , -,"~w~~~fi'" I, Jeffrey Wayne Jones, hereby verifY and state that the facts set forth in the foregoing document are true and correct to the best of my information, knowledge, and belief. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904, relating to unsworn falsification to authorities. DATE: 5/1/0/ , , <;f,!jilllll'Mi:iiil.@i;.r~.k-"" ...:.. II,. . --~-I lti!:i&1.fi~~~f~!.1},i;, SUZETTE RENE SILVIS, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JEFFREY WAYNE JONES Defendant : NO. 00-6867 : PROTECTION FROM ABUSE AFFIDAVIT OF SERVICE COMMONWEALTH OF PENNSYLVANIA ) COUNTY OF CUMBERLAND ) AND NOW, this /;:;- day of m~ ,2001, I, Ronald E. Johnson, Esquire, attorneyfor Jeffrey Wayne Jones, Defendant in the ove-captioned action, hereby swear that I have served a true copy of the Petition for Partial Relief, executed by the Defendant's counsel in the above-captioned matter, upon the Plaintiffs counsel, Joan Carey, Esquire, Legal Services, Inc. 8 Irvine Row, Carlisle, PA 17013, bydepositing the same in the U. S. Mail, postage prepaid, certified, deliver to addressee only, return receipt requested. A copy of the return receipt card signed by the Plaintiff s counsel on rn""w //-1';' , 2001, indicating service was effected, is marked Exhibit "A", attached hereto and made' a part hereof. ANDREWS & JOHNSON intiff Sworn and subscribed to before me this Il)"o.p,dayof ~ ,200l. otar~ NOTARIAL SEAL SHELLY SEXTON, NOTARY PUBLIC CARLISLE BORO, CUMBERLAND COUNTY MY COMMISSION EXPIRES APRIL 26, 2003 Member, PennsylV:"" A'M""'on of Notaries .. . Complete items 1, 2, and 3. Also complete item 1,.if Restricted Delivery is desired. . Print ~3'i.Jr name and address on the reverse so that we can return the card to you. . Attach, this card to the back of the mailpiece, or on{he front if spa.ce permits. 1. Article Addressed to: '"J0A.r, 6.f'~\ e$~ l.-et.JL Se.,,- \.l \c.$~~>\ :5; " c... g ~ I'"'./\V\e.. ~OuJ ~D--Y- \~\.-e \V\"\ \.""'l ~ \ S ~,. ... x o Agent o Addre~~ DYes o No D. Is delivery address different from item 1? If YES, enter delivery address below: 3. Service Type "1!1 Certified Mail o Registered o Insured Mail . o Express Mail o Return Receipt for Merchandise ..0 C.O.D. 4. Restricted Delivery? (Extra Fee) DYes 2. Article Number (CapyJrom service label) io.qCj 3t(06,~/ft' SC'f..~. 775l/ PS Form 3811 , July 1999 . Domestic RBtum Receipt -L_ 102595.0Q-M-0952 Exhibit A ~~ ..-iiJ/f;i]j;jaja'.~~"11j;;' - ~' "" J ~_ "_" -,'>>, '..aj; ,- -,',,-"""~". ~Ml_ft~".a.,fir.:~ . --- .. ... , (") C C :;: ::x -or;:) J:';'.. 1"11 rT< -.< -,.~ "'-- ..'~ UJS~ (,n -<."' !;2Ci -0 d:;Ci _l<.. 4-..,-, >c w ~ N ...:;:, .-..1 -< " ,,' ^', > "..'-..' - ,-",,,-,.,,"I,,~,,,, ~'M'~""n"W,,', .~"" '''_d_ IU',_ _ >-" "_~,, ,'.- "-""" ~-, '" ~ , r. _ ~ ,"__ H . ~ d___J\i~; .. j.~ SUZETTE RENE SILVIS, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JEFFREY WAYNE JONES Defendant : NO. 00-6867 : PROTECTION FROM ABUSE AND NOW, thil.ft, 0 ORD 2001, upon consideration of Defendant's Motion it is hereby ORDERED that the Ru e which was previously issued on Suzette Ren~ Silvis in the above captioned matter on May 11, 200 I to Show Cause as provided for therein, is made ABSOLUTE. It is further ORDERED that paragraph 4 of the final Order of Court previously entered in the above captioned matter on October 16, 2000 prohibiting the Defendant from transferring or acquiring any firearms, license or weapons is herewith V ACA TED. The Cumberland County Sheriff's Department is herewith directed to return to Jeffrey Wayne Jones all weapons previously confiscated from him. BY THE COURT, liii -~ ".;.cf:":" ""<>,,t /t' /\. y~\ ....., ,1\ \ t-.t' \'e\'.':' r:':\:'-;~):"\.,J "-' "" S" \)~ \ (J ",\ \) \ "'\\,? .' ......... Cr-i\\~" ..,' .",.~.) ,,\\11. . 1"C,\:.\',,;,,c'J\\)~-\\f' C\.)\'\~\;.~"';) \ \- , . ... " " ~~" -',--I' ^~. ' ,- " < ~ -"" ., .".-' .. ,^, _ TL ,-, ',I_',"Y'_ ,. ~ .,.t-,,.,o,,,,-\,"""'""" - ... n_. ...; ."",. ,. ~"""'''''~''' ,L~_ __=' -,. ,~""""~- =,. - !, ",..w""."'':.'l-''-'I''''''''';'';'''''''':;ml' ~ , '! " 'i~ ., ,~ ;q: J ".'., ~,.,. ::==." .II . "'~~ . '.- 'I-R,,' f . ..' SUZETTE RENE SILVIS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. CIVIL ACTION - LAW JEFFREY WAYNE JONES Defendant : NO. 00-6867 : PROTECTION FROM ABUSE DEFENDANT'S MOTION TO MAKE RULE TO SHOW CAUSE ABSOLUTE Jeffrey Wayne Jones by his undersigned counsel, respectfully moves this Court to make absolute the Rule which was issued on Suzette Rene Silvis in the above captioned action by Order of Court dated May 4, 2001 to show cause why the relief requested in the Petition of Jeffrey Wayne Jones and all weapons previously confiscated from him by the Cumberland County Sheriffs Department should not be returned to him, and in support makes the following averments: 1. Jeffrey Wayne Jones filed a Petition for Partial Relief requesting that the Court enter an Order vacating that portion of the final Order of Court dated October 16, 2000 prohibiting the Defendant from transferring or acquiring any firearms, license or weapons and further ordering the Cumberland County Sheriffs Department to return to the Defendant all weapons previously confiscated from him on October 12, 2000 or at any time thereafter said Petition being filed in the form of a Rule to Show Cause. 2. That by an Order of Court dated May 4, 2001 the Honorable George E. Hoffer, President Judge issued a Rule to Show Cause on the Plaintiff returnable within 15 days of the date that Suzette Rene Silvis is served with a copy of this Petition. , I"~ ,LI ,t....... I. """-d~J--'l>i", ~ - 3. That Suzette Rene Silvis was served with said Petition and Rule to Show Cause on May 11, 200 I by certified mail, return receipt requested said notice being sent to her attorney of record Joan Carey, Esquire all as more specifically set forth in the Affidavit of Service filed herein. 4. That as of this date Suzette Rene Silvis has failed to file an Answer or any other Petition or Pleading opposing the relief requested by Jeffrey Wayne Jones and more than 15 days have elapsed since the service of the Petition and Rule to Show Cause. WHEREFORE, Jeffrey Wayne Jones respectfully request your Honorable Court to enter an Order making the Rule absolute and granting the relief previously requested in the Petition. Respectfully submitted, cd',' ,. "'llIlllii' .~',--:, <, . -".<..'j;',' ,~" - ,- ,- .----. -- r :II~~ ~ , ,,','" '"'" ,"" C>'i"'-'+,'J>.\,~-.--,,,~,,.. 1.1 I_I ~....I , ~ ,~"" . j;~c :::':1 """ !):-' ';'" -:0 <.,;:.. " -< ~