HomeMy WebLinkAbout00-07776
HELEN LOUISE RAUDABAUGH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
vs.
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00- '7-1'1{P
CIVIL TERM
WILBUR ELLSWORTH RAUDABAUGH,
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 tltiunatter is scheduled on the---1L day of November. 2000. at Z ' 1./ S q .m..
in Conrtroom No. ..a. i' Floor. Cumberland CountyCourtl1ouse, 1 Courthouse Square. Carlisle,
Pennsylvania.
You MUST obey the Order that is attached until it is modified or terminated 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. ~114. Violation may also subject you to prosecution and criminal penalties
under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. ~226S, this Order is enforceable
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. ~ 2261-2262.
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.
cUl\fSE~ COUNTY BAR ASSOCIATION
2 Liberty.-4JI!llre, Carlisle, Pennsylvania 17013
Tefephone Number; (717)249-3)66
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is requirtid by law to comply with the Americans
with Disabilities Act of 1990. For intOrmation about accessible facilities and reasonable accolIll',llodations
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 heari" or business before the court. You must attend the
scheduled conference or hearing. .
" ~ -',~ ,~- r
'-!
< -'I~"
,0" _
~L
- !~
""~""Fl'~~l"lI'l"~I~'nlIOl\!l'i<'i"";'I~~'i'1',"~",," ,_,,1
'<' ="'- '__'_0 ~'o,_
o
c
.,.-
-055
1'1["'";
z.~~
ZS,"
(fJo7
~~C;
-.:;,~,
Z"'""~
-(~
;J>'C
-;7
~
C)
C>
.",
C5
"'C:
iii
()
1')
r~
'~) >--'''';
::_~~S
'~\~;
55
'-<
-c
::r;
:~~.)
.-1
,,,",, _, .,,,:,~;'I?';~~")'d!!~'t"'~<0"'''''-t!''~!;''l'-I'~'''''''''''~It-","1';~~"-".~n"'~)~""f_""~lJlffl"~mflli!;jflt
'!i~~
HELEN LOUISE RAUDABAUGH,
Plaintiff
: In the Court of Common Pleas of
: CUMBERLAND County,
: PENNSYL VANIA
v.
: Civil Action - Law
: No. 00-
WlLBURELLSWORTH RAUDABAUGH,
Defendant
:
: Protection From Abuse
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: WILBUR ELLSWORTH RAUDABAUGH
Defendant's Date of Birth is: May 31, 1918
Defendant's Social Security Number is: 203-10-5753
Name(s) of All protected persons, including Plaintiff and minor children:
1. HELEN LOUISE RAUDABAUGH
AND NOW, on&~ Day of November, 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
plqce where they might be found.
,,~ ,
i
.
I
- I
'.!l~r~ -
2. Defendant is prohibited from having ANY CONTACT with Plaintm: or any other
person protected under this Order, at any location, including but not limited to any
contact at Plaintifl's school, business, or place of employment. Defendant is
specifically ordered to stay away from the following locations for the duration of
this order.
Plaintift's current residence which is confidential and any other residence she
may in the future establish for herself.
The foUowing residences ofPlaintift"s adult children:
James Stouffer
5213 Royal Drive
Mechanicsburg, PA 17055
Dan Stouffer
36 Scarsdale Drive
Camp Hill, PA 17011
Susau BoDing
50 South 22nd Street
Camp Hill, PA 17011
Carrie Campbell
608 Copper Circle
Lewisberry, PA 17339 (York County)
Debra Dieter
419 Lincoln Street
Duncannon, PA (perry County)
3. Defendant sbalI not contact Plaintm: or any other person protected under this
Order, by telephone or by any other means, including through third persons.
4. Defendant shall itnmediately relinquish any firearms license the Defendant may
possess, and the following weapons to the Sherifl's Office or a designated local law
enforcement agency for delivery to the Sherifl's Office.
1. any and all fireanns, including, but not limited to: rifles
and/or shotguns.
Defendant is prohibited from possessing, transferring or acquiring any other
firearms license or weapons for the duration of this order.
~-' !
<='-1
" ~
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 jointly
owned by the parties or owned solely by Plaintiff.
6. A certified copy of this Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
MECHANlCSBURG POLICE DEPARTMENT
CAMP BHL POLICE DEPARTMENT
PENNSYLVANIA STATE POLICE
FAIR VIEW TOWNSHIP POLICE DEPARTMENT (York County)
DUNCANNON POLICE DEPARTMENT (Perry County)
7. The sheriH; 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 lIlIthority 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. TIllS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL MAY ,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 in jail. 23 Pa.C.S. ~6114. Consent of the Plaintiff to Defendant's return
to the residence shall not 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 himlher
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
i~'
__'___'_O[ . I
I~ '," ,
"
,
This Order shall be enforced by the police who have jurisdiction over the plaintifl'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 of Indirect 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
further Order of this court, unless the weaponls are evidence of a crime, in which
case, they shall remain with the law enforcement agency whose 0 de the
~- .
arrest. / 1 .
/"
BY
Date
Distribution to:
Joan Carey, Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, P A 17013
FAXed & mailed to PSP
'~:mw
'"I' - T
~"
, ~~
-
0 CJ 0
c: <::1 -p
g. Z ----t
-gm 0 (:;,=,~ ,
n rn .0::: *..f
z:::r.' ,~
I ~_"Tf7'}-
-7r' '-::-10
~Q?f: 1') l'''', !
,,-=,0
~:::o -0 '-i~- :~;
j;; -.... ~~~F5
:z:Q
"pC (jfn
. C
:z: ::;:-=!
::< :..v :D
..... -<
>lm~"'i\~""",""':,'!~'"J""'~" '-"."l'f!~"-;<jOf"~mI~~~,,,*~',f'(-'~;'-K' '.'/,;"_T' ''''r'-' ,T'-"',^.< ""d')j'''_''''!i'_"'h;'~''nl,''""",'l;;-W~'1'fflY'0F-!iW~''~,''> '''~X,o;;~"''''~ifW]1';p.>r~i!iM~
PF AD Number: ARll44441D
HELEN LOUISE RAUDABAUGH,
Plaintiff
: In the Court of Conunon Pleas of
: CUMBERLAND County,
:
: PENNSYLVANIA
v.
: Civil Action - Law
; No. 00- 717(. Ct:;;d I~
WILBUR ELLSWORTH RAUDABAUGH,
Defendant
: Protection From Abuse
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiffs name is:
HELEN LOUISE RAUDABAUGH
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.
3. HELEN LOUISE RAUDABAUGH
4. Plaintiffs address is
confidential
5. Defendant's Name is:
WILBUR ELLSWORTBRAUD~GH
7f..' . _ ~,.. "..
,,~ l' "~
6. Defendant is believed to live at the following address:
205 Westview Drive ,Mechanksburg, P A 17055
7. Defendant's Social Security Number is:
203-10-5753
8. Defendant's Date of Birth is:
May 31, 1918
9. Defendant's Place of employment is:
retired.
10. Defendant is an adult.
11. The relationship between the Plaintiff and the Defendant is:
Spouse
12. The Plaintiff and the Defendant been involved in the following court actions:
a. Divorce
13. The facts of the most recent incident of abuse are as follows:
On about Monday, October 30, 2000
location: 205 Westview Drive, Mechanicsburg, PA, the marital rcsidence
On or about October 30, 2000, when Plaintin:went to the marital residence,
pursuant to an agreement between the parties facilitated by their divorce
attorneys, to retrieve her personal property, Defe.nt was not at the home but
had left notes about the "o~e slandering her adult chillren, and one BOte to
Plaintiff threatening, ".1f,\van~.. dirty fight; now ,Au're g()Qlg to get one."
Defendant had left several riOes an'ltor shotguns about the house and within view
exacerbating Plaintiff's fear sjnce he had told her on October 28, 2000, that he had
given the weapons away. .
On or about October 29, 2000, Defendant telephoaed Plaintiff at her daughter's
residence and threatened to vandalize vehicles belonging to her and her children.
't"'~,:". _~_,. f.
-I'
-."
I '
-
-
14. Prior incidents of abuse that the Defendant has committed against plaintiff or the minor
child/roo, (including any threats, injuries, or incidents of stalking) are as follows:
On or about October 15, 2000, unbeknownst to Plaintiff, Defendant fonowed her
from church to her daughter's home in Perry County, and while she was there
visiting, Defendant drove her car fro~ the property without her. knowledge or
permission, and left his car in its place. Defendant trespassed on the property in
spite of the certified letter he had been sent by PlaintiWs daughter which notif'led
him that he was not to contact her or her family or come onto their property
under penalty of law.
In or about m.September 2000, Defendant telephoned Plaintiff's relatives and
threatened to kill himself.
On or about September 14, 2000, when Plaintiff returned to the marital residence
with her daughter and son to get her medications and personal belongings,
Defendant had the door blocked with a chair. Defendant beeame angry,. fonowed
Plaintiff about the house, and threatened, "I've had enough; rm getting my gun."
Fearing for their lives, Plaintiff and her children ran from the house. Defendant
fonawed them, and stood on the porch waving the gun about in a menacing
fashion as they got into their vehicle. Plaintiff reported the incident to the
Pennsylvania State Police.
On or about September 13, 2000, Defendanttook PlaintiWs car keys, refused to
give them Imck to her, and told lier, "You're not leaving tile kouse." Fearing for
her safety, Plaintiff left tke home in another car.
On or about August 1,2000, Defendant threatened to bum down the marital
home and get rid of Plaintiff, too.
Defendant's behavior has become increasingly more irrational, unstable, and
violent, causing Plaintift'to fear for her life and that of her family members.
Defendant has threatened to kill bimself, threatened to harm Plaintiff's family
members saying, "You just watch your back; when I go down I'm taking otllers
with me," and he has threatened Plaintiff saying, "I was in the service and I know
how to shoot; I was taught how to kin with my bare hands." During their
marriage, .Defendant attempted to intimidate and control Plaintiff by isolating her
from family and friends, refusing to anow her to go places without him, and
monitQring her daily activities.
15. The Defendant has used, or threatened to use, the following weapon(s) against the
Plaintiff or the minor child/ren:
a. including, but not limited to firearm$, specifically: riRes. andlor
shotguns.
. ~' 1 - ",-~ - I - - y ~, I.T
16. The: police department(s)or law enforcement agencies that should be provided with a
copy of the protection order are:
MECHANlCSBURG POLICE DEPARTMENT
CAMP HILL POLICE DEPARTMENT
PENNSYLVANIA STATE POLICE
FAlRVlEW TOWNSHIP POLICE DEPARTMENT (York County)
DUNCANNON POLICE DEPARTMENT (perry County)
17. There is an immediate and present danger of further abuse from the Defendant.
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 Plaintift's schoo~ 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 Plaintift's relatives
and Plaintift's children listed in this petition, except as the court may
find necessary with respect to partial custodyand/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. Order Defendant to pay the costs of this action, including :filing and
service fees.
f. Order the following additional relief: not listed above:
Prohibit Defendant from having any contact with Plaintiff's
relatives.
Order Defendant to refrain from harassing Plaintiff's relatives.
~~--"-'-
""" '-,
, ,", I I"
Enjoin Defendant from damaging or destroying any property
jointly owned by the parties or owned solely by Plaintiff.
Order Defendant to pay $250.00 to one of Legal Services, Inco's
funding sources for the cost oflitigating this case.
g. Grant such other relief as the court deems appropriate.
h. Order the police or other law enforcement agency to serve the
Defendant with a copy ofthis 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, ..
~~ff
LEGAL SERVICES, INe.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
,n~!
I' -, "-'-"1 ~ ~ .,
-
.'
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, relating
to unsworn falsification to authorities.
Dated:
)0 J.3 100
, I
7'6*#Nie{t.l.l.aL~"'''f f }
Helen Louise Raudaba gh, Plaintiff
~'M~ ,_,
-'l
-? I ^
^.
-0 ~
--
^~ ?J
~,
~- r ~
g
'............
-~ , a:-
c::::: c:)\
-:t- .
~ c;\ ')- IV
,
[: ~~i:Q
,
:-tI ~
,\1 ~~
~ r-~
, ~
s-=
'-
~
V!
t)
\
t-
-
.~
"'''
.~"ij!~j~lf;;r'*t'1I~_""""''I'''''':ti
.,-~,~~r.n
-
~, ""_""""'~, ~__~"~''l-~",~, ~q~,"!~,"""-,,,---,"-, ,.-
<;'
b":l
";-<"T"""''',v",;'';:-''_~,l'''I''Ci
o
~
'C
-unJ
~J~J
6')1)>
~~
L:.
-,
-<
~
C:::'
Cl
~:::
:;:)
,~
o
",1
:::.:l
n~~
~~8
~~~
t'5f'n
sJ
:D
-<
I
p,.)
-1)
~
tv
11'H'~"~'-';""'W:<~,,~,;jI,.,;!q' "'If'!I-'iHIif'II~l~I'!Nf:i'~~ilif
11/02/00 THU 15:43 FAX 717 240 6573
CliMB CO PROTHONOTARY
141001
, .
***************************
n* MULTI TN REPORT ***
***************************
TX/RX NO
INCOMPLETE TX/RX
TRANSACTION OK
2259
ERROR
01l9p2405331
04]92490779
03]9p2438026
CENTRAL PROCESS
PSP
LEGAL SERVICES
..
OFFICE OF TIiE PRCmlCN)TARY
CUMBERLAND CXXJNT'{ CXXJR'IHOOSE
..
ONE COORTI:{OOSE SQUARE
CARLISLE, PA. 17013-3387
FAX ,:
psP
LS /) .
Cett{ {Ol +-rOL:~.5501-j
q-cL4o- 533/
(717) 240-6195
FAX (717) 240-6573
VIA TELECOPIER
TO:
FRa1:
CURTIS R. LONG
RE: :P FA Ord--ev'5
MESSAGE :
~. 00. OF PAGES (INCLUDING COVER SHEET)
1his lTE!SS3J' is :illtt::uhl ally fir tte we of tte irdivid.al cr altit;y tD Wti.ch is is ufi............J. ad nay
antain ir1fumBt:Jm t:h:rt: is p::iY:ilEg:rl. anfidential ad exEfl'!X fron tii...-l"" Ire lIlh "fPli...mlF' 1;JrJ. [f
lte J:B:<H- of ti1:is ~ is rot tIe inta"rlB:l r:a::ipialt, }OJ are te.ra:y rotifiEd ttat lflJ cii.s&:miretkn.
d:i.striI:1.rt: <r cq:Jfirg of this cimn..nicati01 is strictly rrctUbita:!. If}OJ taI.e r:a::ei...e:I ttus
a:rnnnic.r...iffi in ec:>;r, plea:E rotify \.B imrediatel.y ty te1e~tn-e ad urtum tie adgirelll YJ" tD LS at
t:te cro.-_" o.lh.=" via t:te ~1_S. p::sta1 ~ire. 'I1'mk }OJ.
'O"~~"T-~
"- ""'1- ,
~-~-
~""'-,~
SHERIFF'S RETURN - REGULAR
CASE NO: 2000-07776 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
RAUDABAUGH HELEN LOUISE
VS
RAUDABAUGH WILBUR ELLSWORTH
JACOB BAKER
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
was served upon
says, the within PROTECTION FROM ABUSE
RAUDABAUGH WILBUR ELLSWORTH
the
DEFENDANT
, at 0010:00 HOURS, on the 3rd day of November, 2000
at CUMBERLAND CO. SHERIFF'S DEPT. 1 COURTHOUSE SQUARE
CARLISLE, PA 17011
by handing to
WILBUR ELLSWORTH RAUDABAUGH
a true and attested copy of PROTECTION FROM ABUSE
together with
NOTICE OF HEARING & ORDER, TEMPORARY
PROTECTION FROM ABUSE ORDER
and at the same time directing His attention to the contents thereof.
Additional Comments
WEAPONS CONFISCATION
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
3.10
.00
10.00
.00
31.10
Sworn and Subscribed to before
me this 3' ~ day of
'"t~ ~- A.D. ~
__ (\ ~t7k/ ~tJ.i:j;,
P othonotary , -7- /
:-""~~l
so;:~~(
R. Thomas Kline
11/06/2000
By:
'1~'" }-( ~~.
Deputy Sheriff
,
""
HELEN LOUISE RAUDABAUGH,
Plaintiff
: In the Court of Common Pleas of
: CUMBERLAND County,
: PENNSYLVANIA
v.
: Civil Action - Law
:
: No. 00-7776
WILBURELLSWORTII RAUDABAUGH,
Defendant
.
.
: Protection From Abuse
CONTINUED TEMPORARY ORDER
AND NOW, this 8th Day of November, 2000, pursuant to 23 Pa.C.S. ~6107(c), the
terms and conditions of the Temporary Order issued on 2nd Day of November,
2000, in the above-captioned case are hereby continued in full force and effect until
further order of the court.
A hearing on this matter is scheduled for the December 5, 2000, at 8:45AM in
Courtroom No.2, of the Cumberland County Courthouse, One Courthouse Square,
Carlisle, Pennsylvania.
Distribution To:
Joan Carey, Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row, Carlisle, P A 17013
Cara A. Boyanowski, Attorney for Defendant
DALEY LAW OFFICES
1029 Scenery Drive, Harrisburg, P A 17109
-'N''''' _,. ~" '~-,,-
- -I
~~.,~
:lill~A;;ii;!i!;iil'l:lill,'l:i&M,*!;jil{,ijh'l&l~.J!;ffi;ft,~~l~;jj~:iiMh'"",~n."-,,,,,,c,',;,,,__",,,-,"""",.",: ~:~, '"_"""'loC"';":;"'i""lii>ll!.lI4_"",""-1"""'~lIfJM!!!~A!;lrw.1"'J.<w""!iPIh"'Il!ij..",,,,,,_,,;,,,,a,l<!;-;@>,Jml'Jil~i!!lt;~llIiialIIIl'BI;-
!:>-i1&,'
OF Ti
FiLETF1r'Ct/(,C
''-- _"", '-' I VL
,,:: !":OTicCii\'()T4Rv
'"Jr'i
00 NO\!-8
"'" ...,
f"" .. I"
/, \"j. '"'
CUI\;II3~eUV,jD COUNT"
PeNNSYLVANLA '
;~ ,\-,~, ,k,-),l;-;. ,u.. ~ *,","""""""""<<@-""",,,,,,,,< ,'"~_"""", ~.. 1
~_, ," '''',>'"e''', ''''_~'~
-" ~
HELEN LOUISE RAUDABAUGH,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 00-7776 CIVIL TERM
WILBUR ELLSWORTH RAUDABAUGH, :
Defendant : PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
Plaintiff, Helen Louise Raudabaugh, by and through her attorney, Joan Carey of Legal
Services, Inc., moves the Court for an Order rescheduling the hearing in the above-captioned case
on the grounds that:
1. A Temporary Protection From Abuse Order was issued by this Court on
November 2, 2000, scheduling a hearing for November &, 2000, at &:45 a.m. in Courtroom No.2.
2. The Cumberland County Sheriff's Department served Defendant with a certified copy.
of the Notice of Hearing, Temporary Protection From Abuse Order and Petition for Protection From
Abuse on November 3, 2000, at his residence located at 205 Westview Drive, Mechanicsburg,
Cumberland County, P A.
3. Defendant has retained Cara A. Boyanowski of Daley Law Offices to represent him
in the matter.
4. The parties agree, by and through their respective counsel, that the hearing be
rescheduled to facilitate a settlement in this matter.
5. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect
until further Order of Court.
''i'~''''''__ -'-r.-
-. I
T
, "
WHEREFORE, Plaintiffrequests that the Court grant this Motion and reschedule this matter
for hearing, and that the Temporary Protection From Abuse Order remain in effect until further Order
of Court.
oan Carey, Attorney fi
LEGAL SERVICES,
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
'r,>~"'~" >, I '
'"F~ -!
"
,~
.
~, "'", ,----~-,-,,,-,,, y,,'
o
<;;;
"'U$
ffir"'-
~;ii
S;?;~:'
r:= CO}
::2;0
6C
Pc
Z
--<
-<
~,_ 1i;'fTn_ N~llIW.Uli1~~rU!""r"""",!;~-';"^<<i:il'J~~!l>Jli~~:IU[tlil!'~~~"'l"~lIDifjfdl'ii'~"""_';}"",",.h1'1'_""';''';;''
, -. n'Jllll " ""'",'hili
a
o
;z:
~::>
''*'.-;:
o
-n
---i
-~:;~~
I
0)
~~~;;~
...;'_...f
---') :
~:j9
,'-'S:d
:5-(')
C)m
~~
:b
-<
-",-;::~
:J~":
r:~'
':..,
(;0
-"'''!Y','' ,,-,-,,j"~-"'''lf<iW&l~HT,,,!I';h1!{'q'.:\'i'l!-,NW\''~'~~~'~~1\!!ll~''~'ffiiiF
:"."~;I'\ffi<!l"""'r
HELEN LONSE RAUDABAUGH,
Plaintiff
: In the Court of Common Pleas of
: CUMBERLAND County,
: PENNSYLVANIA
v.
: Civil Action - Law
:
: No. 00-7776
WILBUR ELLSWORTII RAUDABAUGH,
Defendant
:
: Protection From Abuse
FINAL ORDER OF COURT
Defendant's Name is: WILBUR ElLSWORTH RAUDABAUGH
Defendant's Date of Birth is: May 31, 1918
Defendant's Social Security Number is: 203-10-5753
Name(s) of All protected persons, including Plaintiff and minor children:
1. HEl.EN wmSE RAUDABAUGH
AND NOW, thisd th Day of December, 2000 the court having jurisdiction over the
parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as
follows:
Plaintiff, Helen Louise Raudabaugh, is represented by Joan Carey of Legal Services,
Inc.; Defendant, Wilbur Ellsworth Raudabaugh, is represented by Cara A Boyanowski
of Daley Law Offices.
Defendant, although agreeing to the terms of this Order, does not admit the allegations
made in the Petition.
Plaintiff's request for a final protection order is granted.
1. Defendant shall not abu~alk, harass, threaten the Plaintiff or any other protected
person in any place where they might be found.
,.
. ,
-
-,t~
, .
--.,
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.
Plaintift"s current resideme which is confidential and any other
residence she may in the future establish for herself.
The foDowing residences of Plaintiff's adult children:
James Stouffer
5213 Royal Drive
Mechanicsburg, PA 17055
Dan Stouffer
36 Scarsdale Drive
Camp Hill, PA 17011
Susan Bolling
50 South 22nd Street
Camp Hill, PA 17011
Carrie CampbeU
608 Copper Cin:le
Lewisberry, PA 17339 (York County)
Debra Deiter
25 Lavonne Drive
Duncannon, PA (Perry County)
" Contact between the parties either through their divorce
attorneys or with their divorce attorneys present shaD not be a
violation of this Order.
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. Defendant shall immediately turn over to the Sherift's Office, or to a
local law enforcement agency for delivery to the Sheriff's Office, any
firearms license the Defendant may possess, and the following weapons
used or threatened to be used by Defendant in an act of abuse against
Plaintiff and! or the minor children.
1. any and aU rll"earms, inclnding, but not limited
to: riOes and/or shotguns.
5. Defendant is prohibited from possessing, transferring or acquiring any
other firearms license or weapons for the duration of this order. The
Defendant has 30 days after expiratioll$ of this order to petition the
Court for return of confiscated weapons.
6. The following additional relief is granted as authorized by ~6108 of the
Act:
Defendant is prohibited from having any coutact with Plaintit1's
relatives.
Defendant is ordered to refrain from harassing Plaintit1's relatives.
Defendant is enjoined from damaging or destroying any property
jointly owned by the parties or owned solely by Plaintiff.
Plaintiff agrees to give Defendant 72 hours written uotice through
the parties' respective divorce attorneys of Plaintit1's intention to
enter outo the marital property located at 205 Westview Drive,
Mechanicsburg, Cumberland County, PA, and Defendant shan
vacate the premises during the time Plaintiff plans to be there.
The court costs and fees are waived.
7. A certified copy of this Order shall be provided to the police department
where Plaintiff resides and any other agency specified hereafter:
Mechanicsburg Police Department
Camp Hill Police Department
Pennsylvania State Police
Fairview Township Police Department(York Connty)
Duncannon Police Department(Perry County)
';~"""""'l'"
~~I
"'
~-"-
8. TIllS ORDER SUPERSEDES:
1. ANY PRIOR PF A ORDER
9. All provisions ofthis order sbaIl expire on: June1!J, 2002
NOTICE TO THE DEFENDANT
VIOLATION OF TIllS ORDER MAY RESULT IN YOUR ARREST
ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WIllCR
IS PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL
SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S. ~6114.
VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND
CRIMINAL PENAL TIES 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. ~2265. IF YOU
TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY
VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL
CRIMINAL PROCEEDINGS UNDER THAT ACT. l8U.S.C ~~2261-
2262. IF THE BRADY INDICATOR P ARAGRAPR 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. ~922(G), FOR POSSESSION,
TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
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, shall enforce this order. An arrest for violation of
Paragraphs 1 through 5 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.C.S. ~6l13.
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
-1ili{>~~f~_,
~ ~.....,
~ "
~-~
..
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. Plaintifi'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.
This Order is entered pursuant to the consent of Plaintiff and Defendant:
y~~~~
Helen Louise Raudabaugh, Plaint'
~~tiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle,PA 17013
(717) 243-9400
ara A. Boyanowski, orney for Defendant
DALEY LAW OFFICES
1029 Scenery Drive
Harrisburg, PA 17109
(717) 657-4795
Distribution:
Joan Carey, Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
Cara A. Boyanowski, Attorney for Defendant
DALEY LAW OFFICES
1029 Scenery Drive
Harrisburg, P A 17109
FAXed and mailed to PSP
<-"'''-~FS-." -'-1
,.
..>>~:::
~~:\\\\\'
........ .
,........ .
........ .
..................
- . - . - . . . . . - . - . . . ~ ~
,'-iii:@i~~M'tlt~" -f-.i<l~*.~'i,,,,.;;-:t1<JltM!EW'"'!',!.'.di~,",,,,,,,,-R'~".w'~l.,\"';;';'"""""'_E';'l!h"c.hi;JF.{"i!~'1:r*~ if1lil!LJil.-~~".'~~1j~IJ1~'-';~\<WM><","'~",f@o~liIlMIlillBlti
..
1,11)!lJ!lIJJlWIII~,lHll !~I.I.. c.".."..... .,
OF"
,r'.f~.t(''E
-~,_.,;>:.(.).r"Jw
"':' 'i --':" t\\.. ,'--, "\ I
(\0 lilT 15 ~.H 8: h9
} 1).__
., "'OUI"TV
CUlv~8biLtNu \...1 "I i I
PENNSYlVANL'^\
--.....ii,lb.!;lil[i ~.
~
'"
."(
'<
~
S
,
~ j
~ ~
~ ~
~ i
"
,4 {~
~ ~\~
":l
...
~
~
-
12/15/00 FR1 13:22 FAX 7~7 i40 6573
CliMB CO PROTHONOTARY
141 001
*$*******************
$$$ TX REPORT $$$
*********************
TRANSMISSION OK
TX/RX NO
CONNECTION TEL
CONNECTION ID
ST. TIME
USAGE T
PGS.
RESULT
2343
9p2405331
CENTRAL PROCESS
12/15 13: 19
03'19
10
OK
..
OffiCE: OF 'Il1E PRarHO'OI'ARY
CUMBERLAND C(XJNI'Y COORTHOOSE
Fill( .:
ONE COORTHOOSE SJUARE
CARLISLE. FA. 17013-3387
(717) 240-6195
FAX (717) 240-6573
PSP VIA TELECOPIER
L5 .J .
Cett{ (Cd rroct'5Sffl.j
q - J.4D - .533 J
..
TO:
FRQ\o1 :
CURTIS R. LONG
RE: -P r A OrrJ..-evs
MESSAGE :
~~ (10. OF PAGES (INCrAJDING rnvER SHEET)
-"<"""""-"'f~ -~T"""
"""'""I
~I--~
..
Helen Louise Raudabaugh
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
7776 Civil 2000
Wilbur Ellsworth Raudabaugh
Defendant
ITEMS: Ranger PM34 -22SLL
Remington 510 Targetmaster
S & W 1000 12 ga., serial FS17046
Remington 760 pump 30-06,
serial 113402 wI scope
ORDER
AND NOW, this ll'lDayof
~
-
the following Order is entered:
The protection from abuse order in the above-captioned case having expired on
June 15, 2002, and the defendant having requested the return of the
weapons/firearms held pursuant to the order, and the defendant otherwise being legally
entitled to possess the weapons/firearms, IT IS ORDERED that all weapons/firearms
held by the sheriff shall be returned to the defendant.
B;J~~
Edgar
cc:
R. Thomas Kline, Sheriff
Cumberland County Sheriff's Office
I
;
"~'''T ~-,
."
d~ "
tliii.li.R1i&~ii\li~'B~~':"O!'...r;!;.i,!j-H.I;f'1i;,n'ii;:!d,,,*"',,,~""""I"~I,,,,,,,'_"1i";iCi,."",__"d!",~:,;j\0,,--,.<,~,,jJi.~~~:1ra/f~aii!;lIlh;lr~"~'"'_"'liliN';'<lt""..,;~;Wi\l:lj!;f;...Iiliii\l_~llIIIiiIiiIIt~~
i"l, ,", d""l"J!UII.*",,,)Jill~,,,,,~, ~,
, -
-~ ~ ,~"-"
F\LED-Off\~~~r -
r~i= ';"1'0' I"'\(:',,..:J I,Af-{'{
," '
or-
02 Jl\N \ 1
0"\ '). 7'
I r d..."
"""\ ""I"
~ ,---,.. '\' jI"', : .< I ,'I' 1
, '" ' h' . ,'LJ .~~"
CUI j '~5~r,~NS'{LV !~N\r\
iL-'
'T~
~
II<