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HomeMy WebLinkAbout01-0261 FX ,j APR 0 3 2001 (j) BRENDA LEE VERNET, On behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-261 CIVIL ACTION LAW V. DONALD EDWARD VERNET, JR., Defendant PROTECTION FROM ABUSE ORDER AND NOW, this day of , 2001, upon consideration of the Cumberland County Sheriff's Office Rule to Show Cause and the District Attorney's Office Rule to Show Cause, the Petitioner's request for return of weapons is hereby denied. By the Court: Kevin A. Hess, J. Joan Carey, Esquire Legal Services Hubert X, Gilroy, Esquire Attorney for Petitioner Thomas Kline Sheriff of Cumberland County Edward L. Schorpp, Esquire Solicitor for Cumberland County Sheriff's Office !~ :;;lillJlif( ,~ c ~" "I' , , - , . BRENDALJ.W VERNET, for ~ .,ti1l:behalf of her minor child: DALLAS MICHAEL CONRAD, vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA DONALD EDWARD VERNET, JR., Defendant . alP I . . NO. 01- =:-c-- CIVIL TERM : 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 yqu and !l FINAL Order may be entered against you granting the relief requested in the Petition. In particuIai-, you may be evicted from YOUT residence and lose other important rights. A hearing on this matter is scheduled on the ~day of January, 2001, at 1 J : 30 " .m., in Courtroom No. ~ on the 4th Floor ofthe Cumberland County Courthonse, lConrtbouse Square, Carlisle, Pennsylvania. Y ouMUST 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. ~6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 US.c. ~2265, this Order is enforceable anywhere in the United States, tribal lands, US. 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 US.C. ~ 2261-2262. You sbould take this paper to your lawyer at once. You have the right to have a lawyer represent you at the hearing. Thewmt 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 lllawyer, you may have to proceed without one. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, Pennsylvania 17013 Telephol;Je Number: (717)249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. F Of infol'ifiation allout accessillle facilities and feasonallle accommodations available to disabled individuals having business before the court, please contact oUT 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. ,~~~ ~- ~~'" ~", -"I ,-- -.-- ~~~ M'f.i'~,ffi.t:)M;;~li1"y",jk;~.i9>i,"'"-'~f,;.~lii;:!.""'ili~v<i~!l!iiiillifj!g,,,,);JiM;i1;1~'M~'~",'}.""""k,,",iliHW,j1jf'&lt E.tiljj!j~ifEIIiIilliIJmIiil""l- ;UL ,c, ~< ~" ~~,,'~ I] i .Iii" ,r, ~ ;::: :un ~~i&illi 'Ul/\R'{ I: S2 C-"" ,,',' (,,' , , '1 ' "'v"-'-:' , " "'['JI ' J"", ,....1...., ",1...)li PENi\J~;YL\::,'-\j\;IA , ' ~ .-~ -~,. ~. <,-" ~. '--'-, ',' ,,~ L,-~ _t~~~~ ,..., - '" ~ - ,'~' '-," '~'l~ 1', , . BRENDA LEE VERNET, on behalf of her minor child: DALLAS MICHAEL CONRAD, Plaintiffs : In the Court of Common Pleas of : CUMBERLAND County, : PENNSYLVANIA v. : Civil Action - Law ; No. 01- ;).(P( DONALD EDWARD VERNET, JR. Defendant : Protection From Abuse TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: DONALD EDWARD VERNET, JR. Defendant's Pate of Birth is: December 7,1959 Defendant's Social Security Number is: 188-52-6972 Name(s) of All protected persons, including Plaintiff and minor children: 1. BRENDA LEE VERNET 2. DALLAS MICHAEL CONRAD AND NOW, on 12th Day of January, 2001 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. 1-..,...,.. ". "1':"" ~ ~ r ~~,' -'- 2. D~ant shall be evicted and excluded from the residence at: 3461 Spring d Carlisle, P A or any other perman or temporary residence ere Plaintiff or any other person protected und s Order may live. Plaintiff is gran exclusive possession of the resid . Defendant shall have no right or privilege ~ or be present on the mises of Plaintiff or any other person protected under this Order. 3. 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 parents' home: 602 Meadowbrook Road Carlisle, P A Plaintiff's place of employment: TYCO (formerly AMP,Inc.) Harrisburg Pike Carlisle. P A 4. Defendant shall not contact Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 5. 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 Sheriffs Office. I. any and all firearms and weapons, specifically: 2. handguns 3. semi-automatic 12-gauge shotgun 4. rifles 5. machine gun 6. compound bows and arrows 7. crossbows 8. black powder muzzle loader rifle Defendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration of tills order. "~ ",-~ IT, - 6. The following additional relief is granted: Defendant is ordered to refrain from harassing Plaintiff's relatives or her minor child. Defendant is enjoined from damaging or destroying any property jointly owned by the parties or ownedsDleIy by Plaintiff. Defendant is ordered to transfer possession ofthe parties' Rottweiler canine to Plaintiff immediately upon being served with the Order in this case. 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: MIDDLESEX TOWNSHIP POLICE DEPARTMENT PENNSYLVANIA STATE POLICE NORTH MIDDLETON TOWNSHIP POLICE DEPARTMENT 8. 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. 9. TIllS ORDER APPLIES lMMEDIATEL Y TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL JULY 12,2002 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS 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 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 :::-!-~ ~~, :or -,- --I - I , ' This Order shall be enforced by the police who have jurisdiction over the pIaintifi'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 5 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 of law 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 Sherifi's 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 officer made the arrest. BY TIlE COURT:. I 7~ API-. 1~,.J I,. Judge z.oc> I Date Distribution to: Joan Carey, Attorney for Plaintiff MidPenn Legal Services Faxed & Mailed to PSP -;~ ,^"~ i1f1!"t ~ 'o',lJ"__ I' . .. "~ ' PFADNumber: TQ1180718T BRENDA LEE VERNET, on behalf of her minor child: DALLAS MICHAEL CONRAD, Plaintiffs : In the Court of Common Pleas of : CUMBERLAND County, : PENNSYLVANIA v. : Civil Action - Law : No. 01- :nl {!.Wd --r~ DONALD EDWARD vERNET, JR. Defendant : Protection From Abuse PETITION FOR PROTECTION FROM ABUSE I. Plaintifi's name is: BRENDA LEE VERNET 2. 1, (the Plaintiff), am filing this Petition on behalf of: - myself - and as Parent of minor Plaintiff(s) 3. Name(s) of ALL person(s), including minor children, who seek protection from abuse. a. BRENDA LEE VERNET b. DALLAS MICHAEL CONRAD 4. Plaintifi's Address is : clo Janet and Robert Conrad, 602 Meadowbrook Road, Carlisle, PA 17013 5. Defendant's Name is: DONALD EDWARD VERNET, JR. '~,}L IJI-._ _~ -,,~.rt-., ,'- I; 6. Defendant is believed to live at the following address: 3461 Spring Road, Carlisle, PA 170131 7. Defendant's Social Security Number is: 188-52-6972 8. Defendant's Date of Birth is: December 7, 1959 9. Defendant's Place of employment is: Specialty Masonry, 3461 Spring Road, Carlisle, PA, self-employed masonry contractor. 10. Defendant is an adult. II. The relationship between the Plaintiff and the Defendant is: Spouse 12. The defendant has been involved in a criminal court action. 13. The defendant is not currently on probation / parole 14. The following other minor child/ren presently live with Plaintiff: a. DALLAS MICHAEL CONRAD Age: 17 years The Plaintifl's relationship to this child is: Mother 15. The facts of the most recent incident of abuse are as follows: On about Tuesday, January 02, 2001 location: 3461 Spring Road, Carlisle, PA, the marital residence. Defendant argued with Plaintiff, yelled in her face as he pressed his finger against her forehead, poked her in the arm and back with his fmger, and tb.reatened that she had better take her 17- year-old son, Dallas, with her to work that day or there would be trouble. '''=-, ", , '-." ," I 'I" . 'T ~ e, ., Later the saDle day, Defendant kicked DaDas in the foot as he lay on the bed, punched him on the back, grabbed him by the back of the shirt, pulled him off of the bed, and threw him agaiust the waD causing DaUas to faD to the floor. Fearing for her safety and that of her sou, Plaintiff telephoned 911 for help. Defendant followed Dallas as he left the house, and yelled at him not to return, threateued him by pointing his index fmger at DaDas as ifit were a gun, and pulled aside his coat and displayed a handguu stuck iu his belt. Plaintiff and Dallas drove away, reported the incident to the Middlesex Township Police Department, provided a written statement to the police, and requested that crimiual charges be med against Defeudant. 16. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor child/ren, (including any tin-eats, injuries, or incidents of stalking) are as follows: In or about August 12, 2900, Defendant yelled at Plaintiffwheu she returned home late from ber brother's wedding, demanded that she give him her car, shoved her about, grabbed her by the arms, and tried to forcibly remove the rings from her fmger. Plaintiff sustained bruising, soreness, and red marks about her arms and hands as a result of this incident. In or about early August 2000, Defendant grabbed Plaintiff by her hair and violently jerked her head backwards. In or about 1998-1999, Defendant yelled at DaDas, grabbed him by the front of his shirt, drew his fISt back in a threatening manner causing the boy to fear he was going to hit him, and shoved him to the ground. Daaas sustained a cut and bruising and soreness about his leg as a result of this incident. Plaintiff reported the incident to the police. In a separate incident in or about 1998-1999, Defendant shoved DaDas, then 14 years old, face- down onto a recliner, punched him on the back, grabbed him by his clothing and shoved him to the floor, kicked him in the back, and picked the boy up and shoved him against the wall. Dallas reported the incident to the police. In or about 1997, Defendant shoved Plaintiff to the Ooor, threatened to kill her, and ran upstairs causing ber to fear that he was going to the room where he kept his guns. Fearing for her life, Plaintiff left the residence. Plaintiff sustained cuts on her finger as II result of this incident. In or about 1995, Defendant yelled at Dallas, grabbed him by the neck, and shoved the child against the waD. Since approximately 1994, Defendant has abused Plaintiff in ways including, but not limited. to, yeDing, shoving, grabbing, restraining, pulling her hair, spitting in her face, threatening to harm and kill her. On several occasions Defendant has locked the telephone in his bedroom to prevent Plaintiff and her son from using it, and he has surreptitiously tape J1.!ConJed his conversations with them. In addition, during their 12-year relationship, Defendant has isolated Plaintiff from her child by forbidding her to bave her son live with them, except for short, sporadic periods of time. Defendant has abused Plaintift"s minor child, DaUas, in ways including, but not limited to, yelling, shoving, grabbing, punching, kicking, and threatening him with harm. Defendant has also thrown, punched, and kicked the family pets, and he has told Plaintiff that he once shot one of his dogs. Defendant has threatened Plaintiff teDing her that he bas a hit list, and if pushed to II '~^,._"--- . , I- ~ .,f' point, he will take people with him. Defendant has criminal convictions in Cumberland County, and is believed to have a felony criminal conviction in North or South Carolina. Defendant owns and possesses several rIreal'Dls and weapons, including, but not limited to handguus, shotguns, riOes, a machine gun, bows and arrows, and crossbows. 17. 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 weapons, specifically: b. handguns c. semi-automatic 12cgauge shotgun d. riOes e. machine gun f compound bows and arrows g. crossbows h. black powder muzzle loader riOe 18. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: MIDDLESEX TOWNSHIP POLICE DEPARTMENT PENNSYLVANIA STATE POLICE NORTH MIDDLETON TOWNSHIP POLICE DEPARTMENT 19. There is an immediate and present danger of further abuse from the Defendant. 20. Plaintiff is asking the court to evict and exclude the Defendant from the following residence: 3461 Spring Road Carlisle, P A Owned By: Brenda Lee Vernet and Donald Edward Vernet, Jr. 21. The Defendant owes a duty of support to Plaintiff and/or minor child/ren. 22. 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. Evict/exclude Defendant from Plaintifl's residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff. c. Require Defendant to provide Plaintiff and/or minor child/ren with other suitable ''''~e'!ll"..,_""""" ~--, " ". housing. d. 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 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. e. Prohibit Defendant from having any contact with Plaintiffs relatives and Plaintiffs 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. f. 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. g. Order Defendant to pay temporary support to Plaintiff and/or the minor child/ren, including medical support and payment of the rent or mortgage on the residence. h. Order Defendant to pay the costs of this action, including filing and service fees. 1. Order Defendant to pay Plaintift's reasonable attorney's fees. j. Order the following additional relief, not listed above: Order Defendant to refrain from harassing Plaintiff's minor child or her relatives. Enjoin Defendant from damaging or destroying any property jointly owned by the parties or owned solely by Plaintiff. Order Defendant to transfer possession of the parties' Rottweiler canine to Plaintiff immediately upon being served with the Order in this case. Order Defendant to pay $250.00 to one of MidPenn Legal Services' funding sources for the cost to litigate this case. k. Grant such other relief as the court deems appropriate. 1. Order the police or other law enforcement agency to serve the Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The petitioner will inform .the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. Respectfully sub . ed, 10 Carey, Attorney for P tiff MidPenn Legal Services, Inc. Date: / - / ;3 -cJ / i,Wi'Im',J.~~ ~~_ ~ . r . I,' VERIFICATION I verifY that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S.~4904, relating to unsworn falsification to authorities. Dated: ,;;Y..#..9 ~CJcJ / Y /~~d Brenda Lee Vernet, Plaintiff for herself and on behalf of her minor child, AJ/&/J ~/~,:7a ~ Dallas Michael Conrad, Plaintiff A, ,'. ,~,-- - - ',,"",' ;[ ,.'.r- , I' r~' ,~ c: "F:~': ! 2 t: 11 . , :To." ~c,l ~J~( 1"'\\,...." Arlo.... ~ I"lfllVOr ((("'-"7/ fq>:uot 0/\0 tllo.,,1Jd. I -I J. -0 1 ~p i " I! I ~ I ~ I I i) :m ii!' ~ " :;;\ en .F; ~[~:~:F. ('",'" ""',,' \..T '~. ',"', ,.:_'.'_:-~;,\::\'I 'T\' . , F~c>l L ~ . ~)(Qd~ p, 1~ C, /_;;.3 of ----. /. /10. {)/ Ii; daj.e/ 15~ ~ 1 to ps,o 01:57 iJAA~~ wdk ~~~ I " . .--C--CC:, CUMB CO PROTHONOTARY 141001 01/12/01 FRI 14:48 FAX 717 240 6573 II' , *************************** ... MULTI TN REPORT ... *************************** TXlRX NO INCOMPLETE TX/RX TRANSACTION OK 2392 [ 01] 9p2405331 [ 03]9p2438026 [ 04]92490779 CENTRAL PROCESS LEGAL SERVICES PSP ERROR ~ OFFICE OF 'IHE PRaTHCNOfARY CUMBERLAND axJNT'{ CXJURTHOOSE ~ ONE COllRTIiOJSE SQUARE CARLISLE. PA. 17013-3387 (717) 240-6195 FAX (717) 240-6573 fAX U: psP LS .J . c.(,rt~ (01 ,rDL--CS$fflj q-cl4o- 533/ V I ATE LEe 0 ~ I E R '1'0: F'RGI : CURTIS R. LONG RE: .p p A OrrJ~v'5 MESSAGE : l-/'\, . -4i-- 00. OF PAGI;:S (INCWDING COVER SHEET) '!his ~ is jntErrl3:i o1ly fur tte LSe of u-e irdividwl. (I[" entiW 1.0 Wrid1 is is ...dl..~. ad ITS:{ ~ .i.nfi:nmItia1 th:rt: is p:iv:i.1fgrl. exnfide"d:ial an ~ fron niq::]CISI..ICe url<:r <{l'1 i,"",1.. lcw. rr lie ~ of this" "'T is rot tie inba-d9::l r:e:::ipiart:. ~ are ~ lDl:if:iJ;d. t\"l:It <nf disse{niretic.n. d.ist:riI:.utio (I[" o::p,dr-.;J of this CI:IIIlU'\ire:ti01 is strictly p:d1ibi.tB:l. If ~ taI.e re:ei.'-6l tillS .........ni'"~ifTl in l"l"Trr. lll.ea;e roti.fv US imrerliately ~ t:eI.e!;h:re arl <ellJrn tie odg:irelu :"9'" lP lS i<l ~~ 11 ~~ 01/16/01 TUE 14:56 FAX 717 240 6573 CliMB CO PROTHONOTARY 141001 ********************* *** TX REPORT *** ********************* TRANSMISSION OK TXlRX NO CONNECTION TEL CONNECTION ID ST. TIME USAGE T PGS. RESULT 2396 92490779 PSP 01/16 14:55 01'30 5 OK I OfFICE OF THE PROIli<N:1TAflY aJMBERLAND o::rJNTY COUR11iCXJSe ONE COOR1llCXJSE SQUARE CARLISLE. PA. 17013-3387 (717) 240-6195 FAX (717) 240-6573 V I ATE L E COP I E R TO: PA STATE POLICE , , FAX H: 717-249-0779 f'RCM : CURTIS R. LONG RE: PFA OIlDERS MeSSAGE: .. tJ/ - dIP! t{j;JJ ~ ~ {. 00. OF PAGES (INCLUDING COVEll SHEETI 4 ~.. '1'_ . r I' BRENDA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v : NO. 01-261 CIVIL ACTION - LAW DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE PETITIONER'S EXHIBIT List of Weapons Ownership Claim 1. Browning 7mm-08 Bolt Action with scope, in case Larry Zimmerman 2. Browning 22-250 Bolt Action with scope, in case Larry Zimmerman 3. Remington Game Master 270 Pump with scope Larry Zimmerman for his nephew 4. Weatherby 300 Mag. Mark V, with scope Larry Zimmerman 5. Winchester Model 1100 Auto Loader Donald Vernet 6, Colt 45 Butline in Spanish Holster Larry Zimmerman 7. Winchester 1200, 12 gauge pump Larry Zimmerman 8. 32 Pistol Father of Donald Vernet ~ D B '_1!~.", ,;:-- .', ~-, ,~, I ~ ~M Form Approved: OMS No. 1512...0129 (3131/91) DEPARTMENT OF THE TREASURY - BUREAU OF ALCOHOL, TOBACCO, AND FIREARMS FIREARMS TRANSACTION RECORD PART I - OVER-THE-COUNTER TRANSFEROR'S TRANSACTION SERIAL NUMBER :2 r ( IOTE: Prepare in original only. All entries on this form must be in ink. See Notices and. Instructions on back. 'ECTlON A MUST BE COMPLETED PERSONALLY BY TRANSFEREE TRANSFEREE'S (Buyer's) NAME (Last, First, Middle) , ~r ;-tf4ft:7:'JlI. It' RESIDENCE' ADORESS (No" Street, City, County, State, ZIP Code) ?j'G, .!2eW"'-L -t DfiJ/t.A.(? tiLLe iccuu ~/.I ~ -;1, i 7 or:;- I. CERTIFICATION OF TRANSFEREE uyer)-An untruthful answer may subject you to criminal prosecution. with a "yes" or a. "no" inserted in the box at the right of the question: ;>( MALE o FEMALE 2. HEIGHT 6~/o I ~ S- 4. RACE o {'II V. I 7, PLACE OF BIRTH (City end State or City and Foreign Country) ,-I. ~ C? .:L)V / / .f) ') 13 Cd fC->-ct ""'. Tc,_, 6, DATE OF BIRTH MONTH DAY YEAR Each question must be answered I. Are you under indictment or information * in any court for a crime punishable by imprisonment for a term exceeding one year? .* A formal accusation of a crime made by a prosecuting attorney, as distinguished from an indictment jlJo presented by a grand jury. J. Have you been convicted in any court of a crime punishable by imprisonment for a term exceeding one year? (NOTE: A "yes" answer is necessary if the judge could have given a sentence of more than one y.ear. A "yes" answer is not required if you have been pardoned for the crime or the conviction has been expunged or set aside, or you have had your civil rights restored and, under the law where the conviction occurred. you are not prohibited from receiving or possessing any firearm). \ hereby certify that the answers to the above are true and correct prohibited from puft';hasing and/or possessing a firearm, except' as t oral or written statement or the exhibiting of any false or misreprese t felony. c. Are you fugitive from justice? d. unlawful user at, or addicted to, marihuana, or sant, stimulant, or narcotic drug, or any other substance? ?(/I> f{'c (.J-.~ tn m the Armed Forces under 4b tC-e> /' /J?' TRANSFER~E'S (Buyer's) SIGNATURE :/ ,/7 DATE I - 2-Y 4) '-- F TO ME IN THE FOLLOWING MANNER '9. TYPE OF IDENTIFICA which shows name, da signature.) <r2G OO)~ On the basis of (1) the stat Published Ordinances, it is and on the back to the pe ments in Section A; (2) the y belief that it is not unla n identified in Section A. rification of identity noted in Section B; and (3) the informatiOn in the current list of ul for me to sell, deliver, transport, or otherwise dispose of the firearm(s) described below 11. TYPE (Pistol, Revolver, Rifle. Shotgun, fItc.) 12. MODEL 13. CALIBER OR GAUGE 14. SERIAL NO. 15 MANUFACTURER (and importer, if any) 1. /"r '). r(~ . f,.F> J';<J CaL- 8 23 006 01 3 J 1 ~ 2. 16. TRADE/CORPORATE NAME AND ADDRESS OF TRANSFEROR (Seifer) (Hand stamp may be used) DIXON MUZZLELOADING SHOP RD 1. BOX 175 KEMPTON, PA 19529 17. FEDERAL FIREARMS LICENSE NO. (Hand stamp may be used) THE PERSON MAKING THE ACTUAL FIREARMS SALE MUST COMPLETE ITEMS 18 THROUGH 20 OI1'S (Seifer's) SIGNATURE 19. TRANSFEROR'S TITLE 20. TRANSACTION DATE .lJ~ / -2-7 _c;- ') - 4473 (5300.9) PART I (1-88) "~"")l;[_M'q"l '. {~~~'~ -> "..".,,,,,., BRENDA LEE VERNET, On behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-261 CIVIL ACTION LAW V. DONALD EDWARD VERNET, JR., Defendant (") c yfit r,] "'-' ;;:~--: Zr'-- ~:J ~?: PROTECTION FROM ABUSE r~L) COMMONWEALTH'S RULE TO SHOW CAUSE ~~8 -", ~> c: r;? z AND NOW, comes Michelle E. Hamilton, Senior Assist~t (D District Attorney, on behalf of the Commonwealth, responding to Larry C, Zimmerman's petition for return of weapons, and averring the following: 1. Hubert X. Gilroy, Esquire, on behalf of Larry C. Zimmerman, filed a petition for return of weapons. See attached exhibit #1. 2. On January 12, 2001, this Court issued a Temporary Protection from Abuse Order for Brenda Lee Vernet against Donald Edward Vernet, Jr, 3. This Order directed Donald Edward Vernet, Jr. to relinquish any firearms in his possession. 4, On January 12, 2001, pursuant to the Temporary Protection from Abuse Order, the Cumberland County Sheriff's Department seized all weapons found in Donald Edward Vernet, Jr.'s possession. >I!~- -'! ,v -,'" _ I. ~ Cl (") "n :=1 :-~:; ::-11 '1"--::' -'-;;-'1 Ie"] . '"'\ T .'.J(~'; -, ::. ~;;? -'-"- ~- -' ,~,'::::; (r I ~:.::'i ,~ jJ -< b> -n =a I (~) 'f0~JIq;f!I_V ,_ ";~," ,~" _0 ~ 5. Donald Edward Vernet, Jr. is a convicted felon and is prohibited by law to possess firearms. 6. Donald Edward Vernet, Jr. was subsequently charged with eight counts of Persons Not to Possess, Use, Manufacture, Control, Sell or Transfer Firearms, 18 Pa.C.S. ~6105, at Criminal Number 01-0495. 7. Hubert X. Gilroy, Esquire is representing Donald Vernet in this criminal case, Criminal Number 01-0495. 8, The weapons found in defendant's possession are evidence of and support the charges at Criminal Number 01-0495. 9. Hubert Gilroy avers that the weapons found in Donald Edward Vernet, Jr.'s possession belong to Larry C. zimmerman. 10, Even if the weapons belong to Larry C. Zimmerman, they should not be returned to his custody until the conclusion of the criminal case against Donald Edward Vernet, Jr. at Criminal Number 01-0495. WHEREFORE, the Commonwealth respectfully requests this Court to deny Larry C. Zimmerman's petition for return of weapons. ResP,ct~UllY submitt~~, 111_ 7 Ii ~ '1..1 M /i'1 --! It I 1Ii // che\i . Hamiltk5' Senior sistant District Attorney 1,1 BRENDA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : v : NO. 01 - 261 CML ACTION LAW DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE COURT ORDER ANDNOW,this_ 21st dayoff\)lAr{'~ , 200 I, upon consideration of the attached Petition, a Rule to Show Cause is hereby issued on Plaintiff Brenda Lee Vernet and on the Cumberland County Sheriff's Office to show cause why the weapons set forth in the attached Petition should not be returned to Petitioner Larry C. Zimmerman because of Mr. Zimmerman's ownership of these weapons, This Rule to Show Cause is returnable at a hearing. scheduled on. the /9 t/, day of .Ap r i L , 200 I, at 1:3 () ~.M. in Courtroom No. -.!1 of the Cumberland County Courthouse. Petitioner's attorney shall serve a copy of this Order on Plaintiff's attorney and also serve a copy on the Cumberland County Sheriff's Office. By: - , J. cc: Joan Carey, Esquire Legal Services . Thomas Kline Sheriff of Cumberland County Edward L. Schorpp, Esquire Solicitor for Cumberland County Sheriff's Office Hubert X. Gilroy, Esquire Attorney for Petitioner Office of the District Attorney Exhibit 1 ~""'J'IjIW.~ ^, , _ ~ _ r _ I ,~_ BRENDA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO.Ol- 261 CIVIL ACTION LAW DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE PETITION FOR RETURN OF WEAPONS Petitioner, Larry C. Zimmerman, by his attorneys, Broujos & Gilroy, P.C., sets forth the following: I Petitioner is Larry C. Zimmerman, an adult individual residing at 86 Dewalt Drive, Mechanicsburg, Cumberland County, 'Pennsylvania. 2 The above captioned action is a protection from abuse action and this Court has issued a Protection from Abuse Order (Order) dated January 19,2001. At Paragraph 5 of the Order,' Defendant in the above matter, Donald Edward Vernet, Jr., was required to relinquish any firearms in his possession to the Cumberland County Sheriffs Office. 3 At time of service and execution of the Order by the Cumberland County Sheriff's Office, various guns were seized from the Defendant. Included in the guns seized from the Defendant were the following weapons: A. Browning 7mm-08 Bolt Action with scope, in case. f~-$,,,l,,~ "l!_lI, ~ _of T _' .-, , I 0 ~ B. Browning 22-250 Bolt Action with scope, in case. C. Remington Game Master 270 Pump with scope. D. Weatherby 300 Mag. Mark V, with scope. E. Winchester Model 1100 Auto Loader. F. Colt 45 Butline in Spanish holster. G. Winchester 1200,12 gauge pump. 4 The weapons as set forth in Paragraph 3 above are the property of Petitioner. They were in the . possession of Defendant for Defendant's personal use. However, the weapons are owned by the Petitioner and were either purchased by the Petitioner himselffrom a gun store or obtained through trade with other gun owners. The gun listed as the Colt 45 Butline is, in fact, registered in the name of the Petitioner. 5 Petitioner desires return of his weapons and Petitioner intends to secure the weapons in question and not allow Defendant any further access to the weapons. 6 Some of the weapons in question are collector items and are very valuable guns from a monetary standpoint and a personal standpoint to the Petitioner. 7 Defendant Donald Edward Vemet, Jr. joins in this Petition as set forth in the attached verification. -""'IlJ!lli.~~ , r.', _ _ u t. ' ,- . WHEREFORE, Petitioner requests your Honorable Court to enter an Order directing return of the weapons to him. Respectfully submitted, ?1 Hubert X. G' oy, Esquire Attorney ~ . Petitioner Broujos Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 (717) 243-4574 ~';\~~, _, ~, "0. -. '-'" Evidence ~ Found 0 Recovered 0 Found or recovered from: D>t"lG'~ V@("e} .epo.rllng officer: Property Record Case No. 01 -,6 t. Prop. No. 16 t../ . ~~~ Location Date found/recovered . ~"Ib' ~"';~ ~ ,cpt',:sle 1-' d -a-oo I Custodial/receiving o'1iicer: Data of c:ustody: o ,L~ 1~'~"~GO\ O. t1W r\ , t I (I ITEMS: . -'.12) 3) f \i .) , 5) 16) 17) 18) . Property IN lOUT DATE ITEM NOs. PURPOSE 10 I . Owner's name: Owner's address I hereby certify I am the ner of above property : authoriZed agent to ~ . eive the same. Claimant's signature: .Jlat~ claimed: Address: ~. ~. r,-,;m. . , ,~ ,- . BRENDA LEE VERNET, for herself and on behalf of her minor child: DALLAS MICHAEL CONRAD, vs. : IN THE COURT OF COMMDN PLEAS OF DONALD EDWARD VERNET, JR., Defendant : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 01-~ CIVlL TERM : 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 FlNAL 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 ~is .matter is scheduled on the I'T day of January, 2001, at 1/."30 A-_.m., in Courtroom No. on the 411I Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. l You MUST obey the Order that is attached llntilit is modified qrterminated by the court after notice and hearing. If you disobey j:bi.sOrder, the p<!llice may arrest you. Violation of this Order may subject you. to a charge of indirect criminal contempt which is punishable by a fine Ofllp to $1,000:00 and/or up to six months injail under 23 Pa. C.S.96114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. 92265, this Order is enforceable anywhere in the United States, tn'ballands, U.S. Territories and the COlIlD1onwealth 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. 9 2261-2262. Yon 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. Uyou do not have a lawyer or cannot afford one, go to or telephone theoflice 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 required by law to comply with the Americans with Disabilities Act of 1990. FOI'l.lillll'i'MtlOli iibout accesslllle facilities lilid I'Woii.lil'ile 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. i'~ liIIT~"M ~" ., -~"-" ~ ~ , BRENDA LEE VERNET, on behalf of her minor child: DALLAS MICHAEL CONRAD, Plaintiffs : In the Court of Common Pleas of . . : CUMBERLAND County, : PENNSYLVANIA v. : Civil Action - Law . : No. 01- ;<(;,1 DONALD EDWARD VERNET, JR Defendant : Protection From Abuse TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is:. DONALD EDWARD VERNET, JR. Defendant's Date of Birth is: December 7,1959 Defendant's Social Security Number is: 188-52-6972 Name(s) of All protected persons, including Plaintiff and minor children: 1. BRENDA LEE VERNET 2. DALLAS MICHAEL CONRAD AND NOW, on 12th Day of January, 2001 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. .~ ". 2. Defendant ~ evicted and excluded from the residence at: 3461 Spring Road Carlisle, P A or any other permanent or tern ary res ce where Plaintiff or any other person protected under this Ord . ay live. Plaint" . 5- anted exclusive possession of the residence. Defe shall have no right or pn' e to enter or be present on the premises of tiff or any other person protected this Order. 3. Defendant is prohibited from having ANY CONTACT wi~tt: or any other person protected under this Order, at any location, including but not limited to any contact at Plaintifi's schoo~ business, or place of employment. Defendant is . specifically ordered to stay away from the fo,li.owing locations for the duration of this order. ,,- Plaintiff's parents' home: 602 Meadowbrook Road Carlisle, P A ". PIaintifrs place of employment: TYCO (formerly AMP,Ine.) Harrisburg Pike Carlisle, P A 4. Defendant shall not contact PlaintifI: or any other person protected under this Order, by telephone or by any other means, including through third persons. license the Defendant may owmg weaponS to the s Office or a designated local law enforcement agency for delivery to the Sheriffs Office. 1. any and all fireanns and weapons, specifically: 2. handguns 3. semi-automatic 12-gauge shotgun. 4. rifles 5. machine gun 6. compound bows and arrows 7. crossbows 8. black powder muzzle loader rifle I, Defendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration of this order. '~>/IiI,.,.", ..,.. ( 6. The following additional relief is granted: Defendant is ordered to refrain from harassing Plaintiff's relatives or her minor child. Defendant is enjoined from damaging or destroying any property jointly owned by the parties or owned solely by Plaintiff. Defendant is ordered to transfer possession of the parties' Rottweiler canine to Plaintiff immediately upon being servedwith the Order in this case. 7. A certified C<lpy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: MIDDLESEX TOWNSHIP POLICE DEPARTMENT PENNSYLVANIA STATE POLICE NORTH MIDDLETON TOWNSHIP POLICE DEPARTMENT \ 8. 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. 9. TIllS ORDER APPLIES IMMEDIA'IEL Y TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL JULY 12, 2002 OR UNTIL OTHERWISE MODIFIED OR lERMINATED BY TInS COURT AFTER NOnCE 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 fuie of up to $1,000.00 and/or up to six months injail. 23 Pa.C.S. S6114. Consent of the Plaintiff to Defendant's return to the residence shaI1 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. S6113. 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 SS2261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS "'M!<ll:Of~ ~" , , This Order shall be enforced by the police who have jurisdiction over the plaintifi's residence OR any location where a violation of this order occurs OR where the defendant trnry' be located. If defendant violates Paragraphs 1 through 5 of this Order, defendant shall be arrested on the charge of Indirect Criminal Contempt. AD. 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 of law 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 Sheri:fi's 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 officer made the arrest. ( , BY THE COURT: . /1(i(~ A. ~j~... ii!~J . Judge /,;J I ~I . Date Distribution to: Joan Carey, Attorney for Plaintiff :MidPenn Legal Services TRUE COPY FROM RECORD In Testimony hereof, I here unto set my hanp and the !fill of said urt at Carlisle, P A. Th" pay of 001. Faxed & Mailed to PSP , Prothonotary 'f"~~ n. ~_ r 1-' , . r Cumberland County Sheriffs Dept. Date ::JM .z ()() I 12. Name of Defendant Weapons Confiscation Court Order Oh?:M Address .3 CI(./ SPi<!rJf; ,Kb CAIW6U: Telephone 2'1.3 - S<f9 'I -- J)"AlIIL", Er-.w/lfl.l'.> VEl/JeT J /2 Number of weapons seized 10 Model/Caliber Moo / 12 t;A l1i1>lIwo,J /22 ';;S" 11<(';'1L10../7I'1M NAill( ".l.l _soo 1100 /12 ~ 71.., J . 27() i!>1.tl t..,,,, tiff" l4fs /..38 Serial No. /..1l8'!?S78 LJ 'laB ItlX.l..t1 7 II~O'lIlV'!'M7 H.l.ISOoo JJU2>I2Z V & 7o'ff...ZSlJ ~5'S~5A ,vA Condition C;OOl> GiOl,l1,) '? 001> vour.:> "001) <loo!") <::torr/) foaL <001::> ~aot> 1109(, <;.o"PoUrJb auw W €.A'" f /3 AAI'4ooIl> CIJ""'.ufA~ J.i'J& Comments - ,,;,k(t<M'/ -5.C 41J --;-------. ,j/ ...... ,,-~alH" ~1>..ifl'tJl"'frejiuty 1J ~' '~.. ~ , .. , I/'~ - "~-"'" 1/ ,J /':' ,,,' ,". ..1". f'" , .f," '>'/.A'l~ ',' ....."1117"/ , , , Signature Defendant -.~~---" , ~ I', SHERIFF'S RETURN - REGULAR CASE NO: 2001-00261 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BRENDA LEE VERNET ET AL VS VERNET DONALD EDWARD JR BARRY HORN, SGT. , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon VERNET DONALD EDWARD JR the DEFENDANT , at 0017:49 HOURS, on the 12th day of January ,2001 at 3461 SPRING RD CARLISLE, PA 17013 by handing to DONALD VERNET 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 CONFISCATION Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.10 .00 10.00 .00 31.10 So Answers: .~~~t R. Thomas Kline 01/16/2001 Sworn and Subscribed to before By: me this ';<'1 ~ day of qQ'.'" "'~'. A.D. Pl~th-o~t?:; Ii.. ~, ~ ,'~r."'llr-._"".",,~,~ ",< " "1 =. ~ , BRENDA LEE VERNET, on behalf of her minor child: DALLAS MICHAEL CONRAD, Plaintiffs : In the Court of Connnon Pleas of : CUMBERLAND County, : PENNSYLVANIA v. : Civil Action - Law : : No. 01-261 DONALD EDWARD VERNET, JR. Defendant : Protection From Abuse CONTINUED TEMPbRARY ORDER AND NOW, this 19th Day ofJanuary, 2001, pursuant to 23 Pa.C.S. ~6107(c), the terms and conditions of the Temporary Order issued on 12th Day ofJanuary, 2001, in the above-captioned case are hereby continued in full force and effect. This order is in effect until July 12, 2002. A hearing on this matter is scheduled for the March 26,2001, at 10:30AM in Courtroom No.4 on the 4th Floor of the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. BY THE COURT: i>: f" ~D \ t? O\'~ ~ Distribution To: Joan Carey, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row, Carlisle, P A 17013 Hubert X. Gilroy, Attorney for Defendant Broujos & Gilroy 4 North Hanover Street, Carlisle, P A 17013 ft~_!if''''~1 --, - , - r 1 r -l'~~, ',-' ~--m'f,~~L~,,*~~"iig;l!,li,g_:;~,jR"";;h, ..!l;~J]I,II,~~ ';~>""'inl_ _ ,~~""'.~:",'-_'h"-_ ~~ _~.", ", ~_~,~ _ _".""___",JlJ!",,,, ,_ "0 ",,~W'"_ , . ,. ~ _ ,-~ ",'-~JHk~"-<' ~., ,j'","';;f;',ti,,;~'iliitt..., ;jijlisritiub1 - bWiI~''''E.,,~ FILE[}{)PFICE C., - -/'.- ~cvv, 'ON07i:4RY 'I" E<~,", -'h..~ ': r-!. , ' , "-,, I 1 "~ , I, I 01,W122 PH /2: S4 CUMBERLAND COUNTY PENNSYLVANIA ",., ",_" , L, "~"""'-,'-7"F-"_ - ";_\,,,~,,,==,, y,"__, C',,' . ,,,-,,''cO'',;; ~-;!"~_~-",,,=..._,,,,,,r_ :_",,~_ _ ~ ,~ -('"~ -; '''-' ~ on ,_~_ '.. " .~,~ "' !Ill.,,",,,, . BRENDA LEE VERNET, : IN THE COURT OF COMMON PLEAS OF for herself and on behalf of her minor child: DALLAS MICHAEL CONRAD, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. : NO. 01-261 CIVIL TERM DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintifl; Brenda Lee Vernet, by and through her attorney, Joan Carey of MidPenn Legal Services, 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 January 12, 2001, scheduling a hearing for Friday, January 19, 2001, at 11:30 a.m. before Judge Hess in Courtroom NO.4. 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 at the marital residence at 3461 Spring Road, Carlisle, Cumberland County, Pennsylvania, on January 12, 2000. 3. Defendant has retained Hubert X. Gilroy ofBroujos & Gilroy to represent him in the matter. 4. The parties agree, by and through their respective counsel, that the hearing be rescheduled to facilitate negotiation of a settlement in this case. 5. Plaintiff requests that the Temporary Protection From Abuse Order remain in efrect for a period of 18 months from the date it was entered, through July 12, 2002, or until further Order of Court, whichever comes first. ~~""r, .7. I ,r . WHEREFORE, Plaintiff requests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in effect for a period of 18 months from the date it was entered, through July 12, 2002, or until further Order of Court, whichever comes first. Respectfully submitted, Joan Carey, Attorney; r Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 .~;,""'~ c~ I" . ~ , CUMBERLANO COUNTY P'ENNSYLVA(\tIA I I ill ~ If ~ ~ ; ;Ii' I ~ f ~ FiI t=f\-nfPCE OF T'ct:- ;'i6rJ~I.J,r.; 'OTAR'J ,f.... ,,'_ (,....,'i I f 01 JI\N \9 AlHl; I 8 . ~ ~: iJ' ~ it ~ WJ I I ~~" BRENDA LEE VERNET, : IN THE COURT OF COMMON PLEAS OF for herself and on behalf of her minor child: DALLAS MICHAEL CONRAD, : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiffs vs. : NO. 01-261 CIVIL TERM DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE ORDER TO VACATE AND NOW, this U" day of February, 2001, upon Plaintiff's Petition to Vacate Order and Withdraw Action: L This matter is dismissed without prejudice. 2. Costs of this proceeding are waived. 3. The Temporary Protection From Abuse Order entered on January 12, 2001, is hereby vacated. By the Court, /ld Distribution to: Joan Carey Maryann Murphy Attorneys for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 ~ 03 -OA -() I Hubert X. Gilroy, Attorney for Defendant Broujos & Gilroy 4 North Hanover Street Carlisle, PA 17013 F ~ed and mailed to pSP 03 - o}. -0 I CP-L3 St~II>>"llllllll -11- ld; ,;J...;.....~~"'-;jj~WJ;!~~1i1!l!WiWf~djfal!f.r*A,'U"';!~Hi1f",;"'Nl',hf~"."',Iij1l1l~~~MIiJiw_t!liIlWi!~~I8il-' ~ I~ ~,,,.=,"',. " ., _~,', , .,,",,_,, _, ,. __,,,.~~,~,, "",,_~~,," ",_ "" . ~ ," _",->--'"r._e',' .Y.= " ,",. ,1.-,l,,,iJI Df r-;,'- PI'-; .. j .c:: ~" ",," .,.... eli,\,'!"'!'! . - "'n 1......)1,'----.,,,_: i:ii;li\:Td [Y- I' ....'..,,'_'1 'I I ""'1' "''-''('L\''\'j'' ~. '1\,:) ~;',j\ 1/\ ,.'''''~ "-. ,,_I. ... ",',"'0'''''''=. _,. ~'~'''=r' < ~ ~" ., , . ~-, ... .. .~ ,BRENDA LEE VERNET, : IN THE COURT OF COMMON PLEAS OF for herself and on behalf of her minor chtld: DALLAS MICHAEL CONRAD, : CUMBERLAND COUNTY, PENNSYLV ANlA Plaintiffs vs. : NO. 01-261 CIVIL TERM DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE PETITION TO VACATE ORDER AND WITHDRAW ACTION Plaintiff, Brenda Lee Vernet, by and through her attorney, Joan Carey ofMidPenn Legal Services, requests that the Court vacate the Temporary Protection From Abuse Order in the ahove- captioned case and that the action be withdrawn on the grounds that: 1. A Petition for Protection From Abuse was filed and a Temporary Protection From Abuse Order was issued by this Court on January 12, 2001, scheduling a hearing for January 19, 2001, at 11:30 a.m. before Judge Hess. 2. The Cumberland County Sheriff's deputies served Defendant with a certified copy of the Notice of Hearing, Temporary Protection From Abuse Order and Petition for Protection From Abuse on January 12, 2001, at the marital residence located at 3461 Spring Road, Carlisle, Cumberland County, Pennsylvania. 3. The parties agreed, by and through their respective attorneys, to the continuance of the case. A Motion was filed and an Order for Continuance was entered on January 19,2001, rescheduling the hearing for March 26,2001, at 10:30 a.m. 4. The parties are in the process of reconciling their differences. 5. Plaintiff requests that the Temporary Protection From Abuse Order entered on January 12, 2001, be vacated and the action withdrawn without prejudice to her. :~:,~ H ., .1__"._,_,.",",_, WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate the Temporary Protection From Abuse Order entered on January 12, 2001, and that the action be withdrawn without prejudice to Plaintiff. Respectfully submitte Joan Carey Maryann Murphy Attorneys for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 'j~ ~~" , ,.-,.' . ", "_,~,L. -',,_,.. '_ __ 0" "-'-" ~ VERIFICATION I verifY that I am the Petitioner as designated in the present action and that the facts and statements cbntained 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 ofl8 Pa.C.S. ~4904, relating to unsworn falsification to authorities. Dated: () /J a /6 ( ~K!~~ Brenda Lee Vernet, Plaintiff i"-ct., ~ , ~ "",< ., ,~- -'1- ". '1-" I I ._:~: i!i~i~ll!'Jl,:,~~"~",-;f',a.:;(jki;;II&~~~~~~~iliiW..!1;,,, ;,-'''t'~''''''l,:;'~,~, "~~,""li~''',*,~Ri''~.w IMRllJ.JIlMIII ~~l;.!~~IIiitlJli!>!ll~~ijflOiii"-"'--U 1 = . ,~ .... ~ __~.~d~"~ ",'~.., .-.. ~, ~" ('. I ..1; '1'/ FEC ;: G r', (',';' 2: f n ~ (\1 jJ , ...../....;t~,L_~.~..-" ", :_. PEivik:Y;'Vil:::":(J/ IJr( .... ',.11,1;4 ....c. ,'"" , _'d.;.' ~. ~ I .~ _lGll' ~ ji I I I I I I I i I i 03/02101 FRIll: 30 FAX 717 240.6573 " CUMB CO PROTHONOTARY 141001 *************************** *** MULTI TN REPORT *** *************************** TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2486 [ 01] 9p2405331 [ 03]9p2438026 [ 04]92490779 CENTRAL PROCESS LEGAL SERVICES PSP ERROR OfTICE OF '!liE PROI'HON::lTAR'i CUMBERLAND CXXJNrY COORrnOOSE ONE COORTHCOSE SQUARE CARLISLE. PA. 17013-3387 (717) 240-6195 TO: FAX (717) 240-6573 LS V r I>. TEL E COP 1 E R let\troJ H~ Oc e.5 5 i fl 0/ PI>. STATE POLICE 0 I.~. FAX #: 717-249-0779 f'ROII ; CURTIS R. LONG RE: PFI>. ORDERS MESSAGE: r1ll.!"_ 00. OF PAGES (INCr..tJDING COVER SffEET) This ~ is intr;n:W ally fi:D:' tte tEe of tre irdiv:iliel ex: mtily to III1ich is is aTh Ed, om rrey crJ1tain ir1fi:mTetio1 l:tfrt: is ~vile;Jai. o::nfidffitia1 ad ~ fI:on (j;.d""JD3 ~ 'n'1 ir.:t'h]t;;' 1&1. If t1-e rerl!r of this ~ is rot Ii-e intB:IEd r:e:::ipient, ~ are tEra::y roti€ie:l t:tet a:fJ cl:issemireilln, distritutia1 cr ~ of this Cl:JTlTulicatim ~ strictly p:dlj.bita::l. If}OJ lBve re:ei\Ed lhlS a:mnnir.~tim in em:r, J;lla:e! rotify lE irme:l.iately ty telfIh:rn ad tebJm tie adginallle3SCg3 to I.S at l"i"'P.!:t'nr'~'~.::of4.Y"'\:IC' .............._'I................:.~" . I ""lf~~ f>;' ,-",- ~ " BRENDA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 01 - 261 CIVIL ACTION LAW DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE PETITION FOR RETURN OF WEAPONS Petitioner, Larry C. Zimmerman, by his attorneys, Broujos & Gilroy, P.C., sets forth the following: 1 Petitioner is Larry C. Zimmerman, an adult individual residing at 86 Dewalt Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2 The above captioned action is a protection from abuse action and this Court has issued a Protection from Abuse Order (Order) dated January 19,2001. At Paragraph 5 of the Order, Defendant in the above matter, Donald Edward Vernet, Jr., was required to relinquish any firearms in his possession to the Cumberland County Sheriff s Office. 3 At time of service and execution of the Order by the Cumberland County Sheriff s Office, various guns were seized from the Defendant. Included in the guns seized from the Defendant were the following weapons: A. Browning 7mm-08 Bolt Action with scope, in case. ih,,'?', ,. _'~_,;"'_'1_,""''''-''"'_~'__'"''''~' .-.,-l,'-,<:.f.--'' ~_.'l,.I_r.,~_'___,_ "__,-or" ". _'," . -" r B. Browning 22-250 Bolt Action with scope, in case. C. Remington Game Master 270 Pump with scope. D. Weatherby 300 Mag. Mark V, with scope. E. Winchester Model 1100 Auto Loader. F. Colt 45 Butline in Spanish holster. G. Winchester 1200, 12 gauge pump. 4 The weapons as set forth in Paragraph 3 above are the property of Petitioner. They were in the possession of Defendant for Defendant's personal use. However, the weapons are owned by the Petitioner and were either purchased by the Petitioner himself from a gun store or obtained through trade with other gun owners. The gun listed as the Colt 45 Butline is, in fact, registered in the name of the Petitioner. 5 Petitioner desires return of his weapons and Petitioner intends to secure the weapons in question and not allow Defendant any further access to the weapons. 6 Some of the weapons in question are collector items and are very valuable guns from a monetary standpoint and a personal standpoint to the Petitioner. 7 Defendant Donald Edward Vemet, Jr. joins in this Petition as set forth in the attached verification. ." ,_r" -,' -1 .~_~ _7_ 'r,. _,,-, ;' -""\'\ ,,_, "";'1_/_'" . 7',""._ - 'I R WHEREFORE, Petitioner requests your Honorable Court to enter an Order directing return of the weapons to him. Respectfully submitted, Hubert . Gilroy, Esquire Atto y for Petitioner Bro ~os & Gilroy, p.e. 4 North Hanover Street Carlisle, P A 17013 (717) 243-4574 ~?''''.~. , '-""-'F-!'~_ ~_~':/<"""_~'_, .-.-+~-1"';:-"':--"~~'~-"'''1 "',---' -- , - .e. .", -,~_. "",Ie -,. '. ,~,-, .... ~ " I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. DATE: 311ft? ~ I ~~.:-~ Larry C. 1 erman "',,'C_'.""', "';7_,,"_"___,~F._~'. "'-on"'".__" _".1 ','- , ,. ,~,. '^" " '. I verify that the statements made in the foregoing document are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities. DATE:~ ~,~r <".- "^,- -,-''::'c ":;,\""".",:"_,,,,_,,,, '!";-"''''','c,:!F.,i''T= _":,,' -'. -"rn"C'l"i ":--,~ ,.., _- ,- , ' G,_, " ,_y,,! ~, "~I-' . --~,~..,~=,- -,.." <:'~:FjCE -.. \::N~)TAr-1Y I ! I I n! Mtf? 'I :~; f11" H ?: i"lQ v I J ,,-,c. _ ,I 1... .J., CU., ";l,::Wl. '''.i'-' ,-'r,u,,1Y Wil..h...J:...r-','t....' .....f..... l'l PENNSYLVA.\JIA ~ . " ~ : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA BRENDA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs v : NO. 01 - 261 CIVIL ACTION LAW DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE COURT ORDER ANDNOW,this~/P dayof ?'ntV)~./ ,2001, upon consideration of the attached Petition, a Rule to Show Cause is hereby issued on Plaintiff Brenda Lee Vernet and on the Cumberland County Sheriffs Office to show cause why the weapons set forth in the attached Petition should not be returned to Petitioner Larry C. Zimmerman because of Mr. Zimmerman's ownership of these weapons. This Rule to Show Cause is returnable at a hearing scheduled on the /IJ-t), day of ~ ,2001, at /: 30 P.M. in Courtroom No. !L of the Cumberland County Courthouse. Petitioner's attorney shall serve a copy of this Order on Plaintiff's attorney and also serve a copy on the Cumberland County Sheriffs Office. By the Court, By: cc: Joan Carey, Esquire Legal Services Thomas Kline Sheriff of Cumberland County Edward L. Schorpp, Esquire Solicitor for Cumberland County Sheriffs Office Hubert X. Gilroy, Esquire Attorney for Petitioner Office of the District Attorney !gt~~- - . , -,"'" - '~~-" '-",,-' ,- '" .c"" v- -. , - i~ ,"1-.1' '\:. - ,'~_, "~_~'_T,_" '_' Y ,.-, . ,"<-, ,J. .;>- .0 0\ t?DJ'~ ~" +c.<:' ~--'__~ J'_ 1'-'-' .. ". Moo^O~ Lll{.,1j '. 'iiltMli\:wlll!.'liI'~ ~ - i0i~~~!lI ;;. :1"'" ,'0 Dr '" F.ii ;!!~(ri~Y~'TARY OJ 11M; 2! Pill2: 42 C1 U',IP;:i~l'i ,,',IU" CU~UN' TY Ul~,W,-, ~\, it , PENNSYlVANli\ '"..'~ ~''''-.' "',",.','" ..~".~,=,~ "", < -~ ~ ., "".. ~~~,. ~,."fl,'."'."''',',V'"~",""_,,< ~.,. -"~- --~",.,~,. ~- . .I .~,"' ,t'llIltiiIill:' ,~ ""'\ . SAIDIS SHUFF, FLOWER & UNDSAY ATI'OIlNEYS-AT.UW Z6 W. High Street Carll.le, PA ;i:~,<- ~ < ,u It MARY E. HEFFLEFINGER , Plaintiff VS. RODGER L. HEFFLEFINGER, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION. LAW : NO. 01. 268 CIVIL TERM : IN DIVORCE ORDER AND NOW, this 19th day of March , 2001, upon agreement of the parties, the hearing set for this day is generally continued. ".?' ~_""H - -- .. 1-'-';,. ," -, "f I" By the Court, t~ \ 0,0 03'~~1S (") 0 0 c " ::? 3: uffj :0- nlp' '-u "T1 Zjj ,- zC -',Ji'Tl ~:::: '.0 S~~~ r;:CJ i:o " r-- -r, _'r... ~'~ ""'"0 ~2c) ,;~'fn >c w \_-) Z W ~ =< :D -J -< 1.' , F:\FILES\DA T AFILE\Gendoc_cur\102823-ans. l!tde Created: 03/~9/0103:07:22PM Revised: 04/02!OllO:40:18AM BRENDA LEE VERNET, on behalf of her minor child, DALLAS MICHAEL CONRAD Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-261 CIVIL ACTION - LAW DONALD EDWARD VERNET, JR, Defendant PROTECTION FROM ABUSE RESPONSE OF THE CUMBERLAND COUNTY SHERIFF TO PETITION FOR RETURN OF WEAPONS AND NOW, comes R. Thomas Kline, Sheriff of Cumberland County (hereinafter "Respondent"), by and through his Solicitor, Edward L. Schorpp, Esquire, who responds to the Petition for Return of Weapons as follows: 1-3. Admitted. 4-7. Denied. After reasonable investigation, Respondent is without knowledge or information sufficient to form a belief as to the truth of these averments, and the same are therefore denied. WHEREFORE, Respondent prays Your Honorable Court to dismiss the Petition. Respectfully submitted, MARTSON DEARDORFF WILLIAMS & OTTO B~i.~~ Edward L. cho p, EsqUire Solicitor, Sheriff of Cumberland County Ten East High Street Carlisle, P A 17013-3093 (717) 243-3341 Date: April-.l:_, 2001 "J'l,..... -'-1-' ",'-; _ -~ , -1-__j_C_ . - , VERIFICATION I verify that the statements contained herein are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. 94904, relating to unsworn falsification to authorities. #?~ R. Thomas Kline, Sheriff of Cumberland County Dated: April A, 2001 , " ~."... . '",1"-~'''-'''r-- , -1" " ""'F CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certify that a copy of the foregoing Response to Petition for Return of Weapons was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: Hubert X. Gilroy, Esquire Four North Hanover Street Carlisle, P A 17013 Joan Carey, Esquire Mid Penn Legal Services 8 Irvine Row Carlisle,PA 17013 Office of the District Attorney Cumberland County Courthouse One Courthouse Square Carlisle, P A 17013 MARTSON DEARDORFF WILLIAMS & OTTO ... ~h~IJ~,-~ C-' !TI;~'D. Eckenroad ?/JO~ Ten East High Street Carlisle, P A 17013 (717) 243-3341 Dated: April 3 ,2001 ,. r" ,'~-' ,"'.',~ ^,_'<;N -., ,. '. 1_,_" ill " il Ii 1" .C. I ~ p ---""'1'11 <",~ ,- -~ ".,. ~'"'+',","",-".- '"', H"Co ","," ,_, ,+ = ,V~'.",'"_'_~'~_'_~ 0 C-=1 C'", ,~ r ......n '"-~. -:.~.... ~"?-'* '1] C.' :""-0 rn L~. ;"J Z ;:",- I Z ,-. , , u! ~ ;::':': b ~ ,(~ Q 1'.) :i> ~- /.:..., ~J1 -:: .~." _T J ll"HtL"'f'Wj'1':,"f~'!t"~'~";.~"W~ffl'!l"~~~r,(i!~!!\l",9!;~N~~!lJ:~r,_,,,,",,,) BRENDA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-261 CIVIL vs. CIVIL ACTION - LAW DONALD EDWARD VERNET JR.,: Defendant PROTECTION FROM ABUSE IN RE: PETITION FOR RETURN OF WEAPONS ORDER AND NOW, this 1':1' day of April, 2001, at the request of counsel, hearing in the above matter set for Thursday, April 19, 2001, is continued generally. BY THE COURT, Joan Carey, Esquire For the Plaintiff . A. A. Hess, J. Hubert X. Gilroy, Esquire For the Petitioner Edward L. Schorpp, Esquire Solicitor for the Cumberland County Sheriff Michelle Hamilton, Esquirl)', Assistant District Attorney :rlm ~,__" "O~, ~ ___ -du'- 1'- ~ ,<- . " . " !III CC,' _, ".,.. I " :::~'i!~'i:;//\'I,/,8.;\iN?d /\.1 it,lr'l : I {'!;- '''":1 """";I<j,...,,... .- 01" ' "". ':\i ),J o~j'P~~ ~" ,..,- u" .."" " " :1' -~ '" ~ "".., "i'~""'''',''':J:_ ,~-"' ~.'~ ,,-, ,,~'",' 'A'-'-=' ,-~""C~"''''''"'''-':ili''<:l!~ d;~:< j ": "'T~' _'~"""""l,_~_Tr~j$\~'\'"",!fIij,I""Jf'Ji'f"li:\l!'!~~~:"i.Ml~I~..~ ~iflllli~l!lffm~il'J" ,..,,~1 ~ 1lj~ ~- , . BRENDA LEE VERNET, On behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-261 CIVIL ACTION LAW V. DONALD EDWARD VERNET, JR., Defendant PROTECTION FROM ABUSE ORDER AND NOW, this day of , 2001, upon consideration of the Cumberland County Sheriff's Office Rule to Show Cause and the District Attorney's Office Rule to Show Cause, the Petitioner's request for return of weapons is hereby denied. By the Court: Kevin A. Hess, J. Joan Carey, Esquire Legal Services Hubert X. Gilroy, Esquire Attorney for Petitioner Thomas Kline Sheriff of Cumberland County Edward L. Schorpp, Esquire Solicitor for Cumberland County Sheriff's Office ;~ '>~','!-' .,.=, . -. ' -r. -1'_.1- . F," - ], or. . , BRENDA LEE VERNET, On behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 01-261 CIVIL ACTION LAW V. DONALD EDWARD VERNET, JR., Defendant PROTECTION FROM ABUSE COMMONWEALTH'S RULE TO SHOW CAUSE AND NOW, comes Michelle E. Hamilton, Senior Assistant District Attorney, on behalf of the Commonwealth, responding to Larry C. Zimmerman's petition for return of weapons, and averring the following: 1. Hubert X. Gilroy, Esquire, on behalf of Larry C. Zimmerman, filed a petition for return of weapons. See attached exhibit #1. 2. On January 12, 2001, this Court issued a Temporary Protection from Abuse Order for Brenda Lee Vernet against Donald Edward Vernet, Jr. 3. This Order directed Donald Edward Vernet, Jr. to relinquish any firearms in his possession. 4. On January 12, 2001, pursuant to the Temporary Protection from Abuse Order, the Cumberland County Sheriff's Department seized all weapons found in Donald Edward Vernet, Jr.'s possession. -,"~_~'''''~_~'' "-'C"', , ;;.-'< _" ,,~ _ ~_. I'--~-~ .. :-F 'f 1_ 1-, . 5. Donald Edward Vernet, Jr. is a convicted felon and is prohibited by law to possess firearms. 6. Donald Edward Vernet, Jr. was subsequently charged with eight counts of Persons Not to Possess, Use, Manufacture, Control, Sell or Transfer Firearms, 18 Pa.C.S. ~6105, at Criminal Number 01-0495. 7. Hubert X. Gilroy, Esquire is representing Donald Vernet in this criminal case, Criminal Number 01-0495. 8. The weapons found in defendant's possession are evidence of and support the charges at Criminal Number 01-0495. 9. Hubert Gilroy avers that the weapons found in Donald Edward Vernet, Jr.'s possession belong to Larry C. zimmerman. 10. Even if the weapons belong to Larry C. Zimmerman, they should not be returned to his custody until the conclusion of the criminal case against Donald Edward Vernet, Jr. at Criminal Number 01-0495. WHEREFORE, the Commonwealth respectfully requests this Court to deny Larry C. Zimmerman's petition for return of weapons. ResP1ct1ullY submitt~1' ;1 7 II ~ '\ .1-mJ / // ~\ 1)1.\ {',: icheti Hamilt~tl Senior sistant District Attorney '~'JII'! - .' l' ".,',-, -" "" ,"-'--"-~'II".r - ., l BRENDA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 01 - 261 CIVIL ACTION LAW DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE COURT ORDER AND NOW, this _~ day of L!)a..rch. _,2001, upon consideration of the attached Petition, a Rule to Show Cause is hereby issued on Plaintiff Brenda Lee Vernet and on the Cumberland County Sheriffs Office to show cause why the weapons set forth in the attached Petition should not be returned to Petitioner Larry C. Zimmerman because of Mr. Zimmerman's ownership of these weapons. This Rule to Show Cause is returnable at a hearing' scheduled on the / 9 ti day of Jip r i L , 200 I, at -1 ; 3 () P.M. in Courtroom No. ~ of the Cumberland County Courthouse. Petitioner's attorney shall serve a copy of this Order on Plaintiff's attorney and also serve a copy on the Cumberland County Sheriff's Office. By: . , J. cc: Joan Carey, Esquire Legal Services Thomas Kline Sheriff of Cumberland County Edward L. Schorpp, Esquire Solicitor for Cumberland County Sheriffs Office Hubert X. Gilroy, Esquire Attorney for Petitioner Office of the District Attorney Exhibit 1 1~ , ~ - - ~ ,- 1.0>.-, -,., I: -~ ~r- c. BRENDA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v : NO.Ol- 261 CIVIL ACTION LAW DONALD EDWARD VERNET,JR., Defendant : PROTECTION FROM ABUSE PETITION FOR RETURN OF WEAPONS Petitioner, Larry C. Zimmerman, by his attorneys, Broujos & Gilroy, P.C., sets forth the following: Petitioner is Larry C. Zimmerman, an adult individual residing at 86 Dewalt Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2 The above captioned action is a protection from abuse action and this Court has issued a Protection from Abuse Order (Order) dated January 19,2001. At Paragraph 5 of the Order, Defendant in the above matter, Donald Edward Vernet, Jr., was required to relinquish any firearms in his possession to the Cumberland County Sheriff's Office. 3 At time of service and execution of the Order by the Cumberland County Sheriff s Office, various guns were seized from the Defendant. Included in the guns seized from the Defendant were the following weapons: A. Browning 7mm-08 Bolt Action with scope, in case. '~;,~- '"-P"' ~, ~ , l'i - B. Browning 22-250 Bolt Action with scope, in case. C. Remington Game Master 270 Pump with scope. D. Weatherby 300 Mag. Mark V, with scope. E.. Winchester Model 1100 Auto Loader. F. Colt 45 Butline in Spanish holster. G. Winchester 1200, 12 gauge pump. 4 The weapons as set forth in Paragraph 3 above are the property of Petitioner. They were in the possession of Defendant for Defendant's personal use. However, the weapons are owned by the Petitioner and were either purchased by the Petitioner himselffrom a gun store or obtained through trade with other gun owners. The gun listed as the Colt 45 Butline is, in fact, registered in the name of the Petitioner. 5 Petitioner desires return of his weapons and Petitioner intends to secure the weapons in question and not allow Defendant any further access to the weapons. 6 Some of the weapons in question are collector items and are very valuable guns from a monetary standpoint and a personal standpoint to the Petitioner. 7 Defendant Donald Edward Vernet, Jr. joins in this Petition as set forth in the attached verification. 'H _ ,'''''''' . " '-1"'".1 WHEREFORE, Petitioner requests your Honorable Court to enter an Order directing return of the weapons to him. Respectfully submitted, t/1 Hubert X. G' oy, Esquire Attorney tI Petitioner Broujos Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 (717) 243-4574 9!;P!IIl'Ii,lv I', , . l' I I '-". Evidence ~ Found 0 . Recovered 0 Found or recovered from: Oo"G'o\ Vf?ff\tJr .eportlng otflcer: 1: ~~ I (I Property Record Case No. 01- ,6' IbtoJ Prop. No. LocatIon Date found/recovered . ~"b I ~"':I'f,. ~ \(Pt'I:~\e I-I ~-~OO I . Custodial/receiving oilicer: Date of custody: o .L~ I-'~"'~OO' O' MV"" III ( ITEMS: /8) --Pr:t'^t,~Oh. ..4) -('0) 11 ) . -~.12) 3) , (( .) 15) 1 6) 17) 18) Property IN lOUT DATE ITEM NOs. PURPOSE 10 Owner1s name: I hereby certify I am the wner of above property : authoriZed agent to ( eive the same. Owner's address Claimant's slgnatura: .Jlat~ claimed: Address: -' -' ,. ( BRENDA LEE VERNET, for herself and on behalf of her minor child: DALLAS MICHAEL CONRAD, vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA ~NO. 01-~CIVIL TERM DONALD EDWARD VERNET, JR., 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. . "1'---- A hearing ~his matter is scheduled on the 1'1 day of January, 2001, at I/,":!O h.m., in Courtroom No. on the 4th Floor oCthe Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. You MUST obey the Order that is attached until it is modified or ternrinated 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 aflne of up to $1,000;00 and/or up to six months in jail under 23 Pa.e.S. 96114. Violation may also suhject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. 92265, 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. 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 required by law to comply with the Americans . with Disabilities Act of 1990. Foi' infoi'flliltion about aceessible faellities iifid i'easofiiillle aceommodatlons 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. -,"..lt1l.....If ~ . . BRENDA LEE VERNET, on behalf of her minor child: DALLAS :MICHAEL CONRAD, Plaintiffs : In the Court of Common Pleas of : : CUMBERLAND County, : PENNSYLVANIA v. : Civil Action - Law . : No. 01- /;l61 DONALD EDWARD VERNET, JR. Defendant : Protection From Abuse TE:MPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: DONALD EDWARD VERNET, JR. Defendant's Date of Birth is: December 7, 1959 Defendant's Social Security Number is: 188-52-6972 Name(s) of All protected persons, including Plaintiff and minor children: 1. BRENDA LEE VERNET 2. DALLAS MICHAEL CONRAD AND NOW, on 12th Day of January, 2001 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. ,~I!J!lI!lIlII,""'''", -, , -'~,-, ~I- , - ,- ~_ ':, -'. evicted and excluded from the residence at: 3461 Spring Road Carlisle, P A or any other permanent or tern res ce where Plaintiff or any other person protected under this Orde . ay live. Plaint' . . anted exclusive possession of the residence. Det] t shall have no right or pn' e to enter or be present. on the premises of ntiff or any other person protected u this Order. 3. Defendant is prohibited from having ANY CONTACT wit~ff, 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 fo,ll.owing locations for the duration of this order. .,. Plaintiff's parents' home: 602 Meadowbrook Road Carlisle, P A "" Plaintiff's place of employment: TYCO (formerly AMP,Inc.) Harrisburg Pike Carlisle, P A 4. Defendant shall not contact Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. license the Defendant may , e 0 owmg weaponstOtlie . s Office or a designated local law enforcement agency for delivery to the Sheriff's Office, 1. any and all fireanns and weapons, specifically: 2. handguns 3. semi-automatic 12-gauge shotgun. 4. rifles 5. machine gun 6. compound bows and arrows 7. crossbows 8. black powder muzzle loader rifle ; \ Defendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration of this order. ~.~ " ~ "~~ .,' ., -,,~~ ( 6. The following additional relief is granted: Defendant is ordered to refrain from harassing Plaintiff's relatives or her minor child. Defendant is enjoined from damaging or destroying any property jointly owned by the parties or owned solely by Plaintiff. Defendant is ordered to transfer possession ofthe parties' Rottweiler canine to Plaintiff immediately upon being served with the Order in this case. 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: . MIDDLESEX TOWNSHIP POLICE DEPARTMENT PENNSYLVANIA STATE POLICE NORTH MIDDLETON TOWNSHIP POLICE DEPARTMENT 8. The sherifl; 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. 9. THIS ORDER APPLIES lMMEDIATEL Y TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL JULY 12, 2002 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS 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. 96114. 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. 96113. 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. S92261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS Ifl!l_ ~,~~" ~ ~~, ,. ( 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 5 of this Order, defendant shall be arrested on the charge of Indirect Criminal Contempt. Ati. 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 of law 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 Sheri:tl's 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 officer made the arrest. t BY THE COURT: /o/-f(~ A. r;,_J<,.. /;J, ~I . Date W~J . Judge Distribution to: Joan Carey, Attorney for Plaintiff MidPenn Legal Services Faxed & Mailed to PSP TRUE COpy FROM RECORD In Testimony hereof, I here unto set my hand and the Mial of said urt at Carlisle, P A.' Thi '9 day of 001. e , Prothonotary ;,;:~,. . . . 'r 1'1 . Cumberland County Sheriffs Dept. Weapons Confiscation Date :JM 12. .l ()() I Court Order Oh!M - , .!' , !.JoNAH. E hw/lJl.l:> 'V6/1.';t r ...l/i'. Address .3 "It.! SPi2Jdf;> .20 CAIW~ Telephone 2l(). - S"I't 9 Name of Defendant Number of weapons seized /0 iPoiZ Serial No. t Ilfi'F $'78 41'18ifltlX2.t1 7 1/60'1 NV'!'M 7 H~ISooo )./U,?;,U.l.V g. 7Dt{r...zSlJ ~,$$~SA HAl Model/Caliber /100 112 t;A /ltMU,o,J /"'2 -25" i'Hi:>AIJ.'"'''' / 7MM t1~1( ? /3.00 /I/iIJ / 12. ~;\ 7t,,n J. 27() /!>iN! t.,,,t Sff" /.41$ /.38 Condition Make I. W"hf.i<!>.f:((.. 2. ?:JlowAl/ol " AliA&; . 3. BI2IJuJ"IIJ ~. All"!!\' 4. W{'I\ ./IHlik"l 5. !2f:/-I/# I; rt)N p. /.;:I1",/!p'04 7. (.0/:1' Nf.""'I.>tHt 8. A'iMFI!...""" I!<U.Il>tJe, . 9. UnflA I1A~. go 10. JI<JJltQN II. 12. 13. 14. 15. 'tel'/;. 410l/1:1 <? 001> (',our,;, 4wb C>OO!:i (,i1J<lP c,o"PcUr/l) ~,/ ~'" IiXi' <;000 - .. IN <.A'" f , '" AllilUlutl> 4000 J/09t.. Comments - :, li>(t""'~ - / '"4..", C. I , /,HN",N ,.flAM ('A' - W {.i) "'''' 1/1'- 1/ . 11# . ( '-"'--'. 41 '-_, S i~nilllJJ;e..S\;>Oi'.ffartrePui'y ,'^: - " . 4' ! d /1/ .J._ ,,' ~...;/' .,--..--- 1/ l' /' I;' _ / ' ;' ,J,'" /i I .;" lif-->?4t.. .J .'/1:;;//21.1/ .. - ,^,. ,A Si'gnature Defend~nt . ' "ll 1-"- BRENDA LEE VERNET, On behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-261 CIVIL ACTION LAW V. DONALD EDWARD VERNET, JR., Defendant PROTECTION FROM ABUSE ORDER AND NOW, this day of , 2001, upon consideration of the Cumberland County Sheriff's Office Rule to Show Cause and the District Attorney's Office Rule to Show Cause, the Petitioner's request for return of weapons is hereby denied. By the Court: Kevin A. Hess, J. Joan Carey, Esquire Legal Services Hubert X. Gilroy, Esquire Attorney for Petitioner Thomas Kline Sheriff of Cumberland County Edward L. Schorpp, Esquire Solicitor for Cumberland County Sheriff's Office "'$QI!!I!:m~~'l/>1 ~ ,., '" -,"'" ~ ",. =. .~, ltlim , , BRENDA LEE VERNET, On behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-261 CIVIL ACTION LAW V. DONALD EDWARD VERNET, JR., Defendant PROTECTION FROM ABUSE ORDER AND NOW, this day of , 2001, upon consideration of the Cumberland County Sheriff's Office Rule to Show Cause and the District Attorney's Office Rule to Show Cause, the Petitioner's request for return of weapons is hereby denied. By the Court: Kevin A. Hess, J. Joan Carey, Esquire Legal Services Hubert X. Gilroy, Esquire Attorney for Petitioner Thomas Kline Sheriff of Cumberland County Edward L. Schorpp, Esquire Solicitor for Cumberland County Sheriff's Office ';'>'~"~ " " . BRENDA LEE VERNET, On behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-261 CIVIL ACTION LAW V. DONALD EDWARD VERNET, JR., Defendant (") 0 (") c; -11 CB~~ ;g '~,!J L~C I '''-l-:Ti ej) ,,'?: C,...J T --< L_. ~~J AND NOW, comes Michelle E. Hamilton, Senior Assis't-arit.. ~:-: ~ E:~ -,~. \? ~ >-"'l~ N ,! District Attorney, on behalf of the Commonwealth, respo~ing.toZj ~ :::; ~ Larry C. Zimmerman's petition for return of weapons, and PROTECTION FROM ABUSE. COMMONWEALTH'S RULE TO SHOW CAUSE averring the following: % 1. Hubert X. Gilroy, Esquire, on behalf of Larry C. Zimmerman, filed a petition for return of weapons. See attached exhibit #1. 2. On January 12, 2001, this Court issued a Temporary Protection from Abuse Order for Brenda Lee Vernet against Donald Edward Vernet, Jr, 3. This Order directed Donald Edward Vernet, Jr. to relinquish any firearms in his possession. 4. On January 12, 2001, pursuant to the Temporary Protection from Abuse Order, the Cumberland County Sheriff's Department seized all weapons found in Donald Edward Vernet, Jr.'s possession. II >~ "'"'" . ,.--, ,;o~'~~~ 1'-1 5. Donald Edward Vernet, Jr. is a convicted felon and is prohibited by law to possess firearms. 6. Donald Edward Vernet, Jr. was subsequently charged with eight counts of Persons Not to Possess, use, Manufacture, Control, Sell or Transfer Firearms, 18 Pa.C.S. ~6105, at Criminal Number 01-0495. 7. Hubert X. Gilroy, Esquire is representing Donald Vernet in this criminal case, Criminal Number 01-0495, 8. The weapons found in defendant's possession are evidence of and support the charges at Criminal Number 01-0495. 9. Hubert Gilroy avers that the weapons found in Donald Edward Vernet, Jr.'s possession belong to Larry C. Zimmerman. 10. Even if the weapons belong to Larry C. Zimmerman, they should not be returned to his custody until the conclusion of the criminal case against Donald Edward Vernet, Jr. at Criminal Number 01-0495. WHEREFORE, the Commonwealth respectfully requests this Court to deny Larry C. Zimmerman's petition for return of weapons. Resp,ct1ullY submitt.e1' . ,I, uJJ; 7 II ~ ---/'\ ,~,-~.. , I /.'/1 \1 i /f \ I II I, iCheY '. Hamiltb'ii Senior sistant District Attorney ., .~ I ' . , BRENDA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 01- 261 CIVIL ACTION LAW DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE COURT ORDER AND NOW, this_ 21st: dayof~ ,2001,uponconsiderationof the attached Petition, a Rule to Show Cause is hereby issued on Plaintiff Brenda Lee Vernet and on the Cumberland County Sheriff's Office to show cause why the weapons set forth in the attached Petition should not be returned to Petitioner Larry C. Zimmerman because of Mr. Zimmerman's ownership of these weapons. This Rule to Show Cause is returnable at a hearing. scheduled on the J 91:/. day of -Apri L , 2001, at . J :3 () ...e..M. in Courtroom No. ~ of the Cumberland County Courthouse. Petitioner's attorney shall serve a copy of this Order on Plaintiff's attorney and also serve a copy on the Cumberland County Sheriff's Office. By: J. cc: Joan Carey, Esquire Legal Services . Thomas Kline Sheriff of Cumberland County Edward L. Schorpp, Esquire Solicitor for Cumberland County Sheriff's Office Hubert X. Gilroy, Esquire Attorney for Petitioner Office of the District Attorney Exhibit 1 c;'~~"",-~, . ~~ ,C 11 BRENDA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 01- 261 CIVIL ACTION LAW DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE PETITION FOR RETURN OF WEAPONS Petitioner, Larry C. Zimmerman, by his attorneys, Broujos & Gilroy, P.C., sets forth the following: I Petitioner is Larry C. Zimmerman, an adult individual residing at 86 Dewalt Drive, Mechanicsburg, Cumberland County, 'Pennsylvania. 2 The above captioned action is a protection from abuse action and this Court has issued a Protection from Abuse Order (Order) dated January 19,2001. At Paragraph 5 of the Order,' Defendant in the above matter, Donald Edward Vernet, Jr., was required to relinquish any firearms in his possession to the Cumberland County Sheriffs Office. 3 At time of service and execution of the Order by the Cumberland County Sheriff's Office, various guns were seized from the Defendant. Included in the guns seized from the Defendant were the following weapons: A. Browning 7mm-08 Bolt Action with scope, in case. ,-tn_ '" ""-"""'~ . . l" ~ ,. B. Browning 22-250 Bolt Action with scope, in case. C. Remington Game Master 270 Pump with scope. D. Weatherby 300 Mag. Mark V, with scope. E. Winchester Model 1100 Auto Loader. F. Colt 45 Butline in Spanish holster. G. Winchester 1200, 12 gauge pump. 4 The weapons as set forth in Paragraph 3 above are the property of Petitioner. They were in the possession of Defendant for Defendant's personal use. However, the weapons are owned by the . Petitioner and were either purchased by the Petitioner himself from a gun store or obtained through trade with other gun owners. The gun listed as the Colt 45 Butline is, in fact, registered in the name of the Petitioner. 5 Petitioner desires retum of his weapons and Petitioner intends to secure the weapons in question and not allow Defendant any further access to the weapons. 6 Some of the weapons in question are collector items and are very valuable guns from a monetary standpoint and a personal standpoint to the Petitioner. 7 Defendant Donald Edward Vernet, Jr. joins in this Petition as set forth in the attached verification. ---p~ ~.,."., ~". , WHEREFORE, Petitioner requests your Honorable Court to enter an Order directing return of the weapons to him. Respectfully submitted, o Hubert X. G' oy, Esquire Attorney fi Petitioner Broujos Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 (717) 243-4574 ,,'-!l!IiIlIJ~ r-I '-'" Ev\'dence g Found 0' Recovered 0 Found or recovered from: Oot'\G\cA Verne} .epo,rtlng officer: i (I Property Record Case No.ol-j.6' I b..J Prop. No. 1": ~~ Location Date found/recovered ~"'b' ~~;rc.~ ,CPrl:s\(' 1-ld-~ClOI Custodiallrecelving o'1ficer: Date of custody: o .L '-I~"~OO\ O. f1UI'"" ( ITEMS: /8 ) Pr.Me/~Oh. ,4) -r-O ) "11) . .....1~) :3) f' (( .J 15) 16) 11) 18) Property IN lOUT DATE ITEM NOs. PURPOSE 10 Owner's name: I hereby certify I am the wner of above property : a~orized agent to I erve the same \ - . I I",,, ..,- Owner's address Claimant's signature: "'pat~ claImed: Address: ~. ~. -. ~~r~~~. ,~ - BRENDA LEE VERNET, for herself and on behalf of her minor child: DALLAS MICHAEL CONRAD, vs. : IN TIiB COURT OF COMMON PLEAS OF DONALD EDWARD VERNET, JR., Defendant : CUMBERLAND COUNTY, PENNSYLV ANlA ; NO. Ol-~CIVlL TERM : 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 ~~is matter is scheduled on the 11- day of January. 2001, at / /: 5"0 I't.m., in Courtroom No. · on the4lb Floor oCthe Cumberland County Courthouse, 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 p9liee mayatrest you. Violation of this Order may subject you. to a charge of indirect eriminal contempt which is pl)nishable by a fine of up to $1,000;00 and/or up to six months injail under 23 Pa.C.S. 96114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvama Crimes Code. Under federal law, 18 U.S.C. ~2265, this Order is enforceable anywhere in the United States, tribaI 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 atonce. You have the right to have a lavvyer 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 D~ABlLlTIES ACT OF 1990 ,_ The"Court of Common Pleas of Cumber land County is required by law to comply with the Americans witll. Dlsabllltles Allt {)f 1990. Foi' liifol'iIDlt1ofi MoUt illlllesslble fallilities ami i'easolliible alleOmfi'i.odatiOfis 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. '.--- . ", ~ ~. BRENDA LEE VERNET, on behalf of her minor child: DALLAS MICHAEL CONRAD, Plaintiffs : In the Court of Common Pleas of : CUMBERLAND County, : PENNSYLVANIA v. : Civil Action - Law . : No. 01- :;l6/ DONALD EDWARD VERNET, JR. Defendant : Protection From Abuse TEl\1PORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: DONALD EDWARD VERNET, JR. Defendant's Date of Birth is: December 7, 1959 Defendant's Social Security Number is: 188-52-6972 N ame( s) of All protected persons, including Plaintiff and minor children: 1. BRENDA LEE VERNET 2. DALLAS MICHAEL CONRAD AND NOW, on 12th Day of January, 2001 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. ,,,- ,-,,--- 2. Defendant ~ evicted and excluded from the residence at: 3461 Spring Road Carlisle, P A or any other permanent or tem ary res ce where plaintilf or any other person protected under this orde. . ay live. Plain' . 5;' anted exclusive possession of the residence. Defi. t shall have no right or pn' e to, enter or be present on the premises of tiff or any other person protected . this Order. , , ~ 3. Defendant is prohibited from having ANY CONTACT with Plaintifi; or any other person protected under this Order, at any location, including but not limited to any contact at Plaintifi'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 parents' home: 602 Meadowbrook Road Carlisle, P A ". . ( Plaintiff's place of employment: TYCO (formerly AMP,Inc.) Harrisburg Pike Carlisle, P A 4. Defendant shall not contact Plaintifi; or any other person protected under this Order, by telephone or by any other means, including through third persons. license the Defendant may owmg weapons to s Office or a designated local law enforcement agency for delivery to the Sheriff's Office. 1. any and all fireanns and weapons, specifically: 2. handguns 3. semi-automatic 12-gauge shotgun, 4. rifles s. machine gun 6. compound bows and arrows 7. crossbows 8. black powder muzzle loader rifle ( , Defendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration of this order. - ~~. ,~.~ -~"~~,- ~--~, ( \ .,,- " 6. The following additional reliefis granted: Defendant is ordered to refrain from harassing Plaintiff's relatives or her minor child. Defendant is enjoined from damaging or destroying any property jointly owned by the parties or owned solely by Plaintiff. Defendant is ordered to transfer possession of the parties' Rottweiler canine to PlaintiffimmediateIyupon being servedwith the Order in this case. 7. A certified copy of this Order sh.aIl be provided to the police department where Plaintiff resides and any \)ther agency specified hereafter: MIDDLESEX TOWNSHIP POLICE DEPARTMENT PENNSYLVANIA STATE POLICE NORTH MIDDLETON TOWNSHIP POLICE DEPARTMENT 8. The sherlfl: police Gr other law enforcement agencies are directed to serve the Defendant with a copy of the PetitiOB, any Order issued, and the Order for Hearing without prepayment of costs. The l'e#tioller will infurm the designated authority of any addresses, other than the Defendlint's residence, where Defendant can be served. The Prothonotary is directed to file this Petition and Order without prepayment of costs. 9. TInS OJIDERAPPLlES IMMEDIATELY TO DEFENDANT AND SHAlL REMAlN IN EFFECT UNTIL JULY 12, 2002 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS 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. ~6Il4. 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 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.e ~~2261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS ~ ' ~ , " I - This Order shall be enforced by 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. If defendant violates Paragraphs 1 through 5 of this Order, defendant shall be arrested on the charge of Indirect Criminal Contempt. Ari 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 officer made the arrest. BY THE COURT: /2jif~ A. ~ bt-.. . - tI.~ <1'1 . Judge /.;J , ...:J.tJ6 I . Date ( / Distribution to: Joan Carey, Attorney for Plaintiff MidPenn Legal Services Faxed & Mailed to PSP TRUE COpy FROM RECORD In Testimony hereof, I here unto set my hand and the M'aI ofsaid urt at Carlisle, PA. Th' day of 001. , Prothonotary ,~-~ 1- ~, ~ ~' Cumberland County Sheriffs Dept. Date J"M .zOUt /2. Name of Defendant ;-., L)mJIIII;> i 1\,,,Af/.l> V;;J/AI"T Weapons Confiscation Court Order 0 1- 26/ - JI2 Address 3 '1M SPk:!rJt;> -, .K/) CAli.LI~ Telephone ZiI.$ - S<f9 '1 Number of weapons seized 10 Make 1. vJ/~huli.!>lflR.. 2. Jl.IK..IMIP~ Afl/ll<: 3. BaOWNIJ ~. All",... " 4. Wiiln/.lffly."1 5. iZM,lift TfJN p. i?.f:Ah/''ilON 7. CoLT flfwL..11/. 8. AlM<<("1lPI &lLt"'$> 9. UJ.rhA I'M? 8'0 10. I/lJ(ttbl'l 11. 12. 13. 14. 15. Model/Caliber Moo 11.1 C;A f1ibAu,oAl /22 '.IS,;) /'In.AlL'ON /7HM NAill( F / .!.oo i/(JI) //2 ~ 7to/J J . 271> &/NI (.,"" Sff,. /.4fS I. .38 Condition Serial No. t U8'Il$78 1..J<t8J11t.))t..z..t17 1/(, O'l#V.!oM 7 H.l/Sooo NU'&/2Z V g. 704ffdS4j ~S$~5A nM C;/X)l) Goo!:> 4001> (7001'::> 4(01) VOOD VfJfJ];> i'ooI1. <:.o"PQUdb i;(Iw W"Ai>Ii f /g, All_I> <;000 ~wo. CDh4.fAAbo.1 Ji)@ }/Oltj(b Comments . "'" <= Il' , . ,~ 'wJ -;-~----" JJ '- Si2n~(J"p Slloriff-ortrej)lily : '" -' - VJ . (,.' '--- /("-/~~//frmt; ,t. ,_I' , .. Signature Defendant 1~"",",,,~ ,_ ,~._'''' ~~~,,,,,,,,,,,,_,,,~;.m , ' .. , BRENDA LEE VERNET, On behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-261 CIVIL ACTION LAW V. DONALD EDWARD VERNET, JR., Defendant PROTECTION FROM ABUSE 000 C "T1 -u r~ ' .~-1 COMMONWEALTH'S RULE TO SHOW CAUSE Ill,';g. ',;:p ~ ~=~ c:, '['? AND NOW, comes Michelle E. Hamilton, Senior Assis~1j.t ~ . ,-;~ ~ ('=1 -,'r" ~-"~ ~~S District Attorney, on behalf of the Commonwealth, respdR~tn~o9rn Z I> -; - ~o -< ..-J -< Larry C. Zimmerman's petition for return of weapons, and ~ averring the following: 1. Hubert X. Gilroy, Esquire, on behalf of Larry C. Zimmerman, filed a petition for return of weapons. See attached exhibit #1. 2. On January 12, 2001, this Court issued a Temporary Protection from Abuse Order for Brenda Lee Vernet against Donald Edward Vernet, Jr. 3. This Order directed Donald Edward Vernet, Jr. to relinquish any firearms in his possession. 4. On January 12, 2001, pursuant to the Temporary Protection from Abuse Order, the Cumberland County Sheriff's Department seized all weapons found in Donald Edward Vernet, Jr.'s possession. ~"' ","" ~ , ,- ,~~ I .~ -,-, 5. Donald Edward Vernet, Jr. is a convicted felon and is prohibited by law to possess firearms. 6. Donald Edward Vernet, Jr. was subsequently charged with eight counts of Persons Not to Possess, Use, Manufacture, Control, Sell or Transfer Firearms, 18 Pa.C.S. ~6105, at Criminal Number 01-0495. 7. Hubert X. Gilroy, Esquire is representing Donald Vernet in this criminal case, Criminal Number 01-0495. 8. The weapons found in defendant's possession are evidence of and support the charges at Criminal Number 01-0495. 9. Hubert Gilroy avers that the weapons found in Donald Edward Vernet, Jr.'s possession belong to Larry C. Zimmerman. 10. Even if the weapons belong to Larry C. Zimmerman, they should not be returned to his custody until the conclusion of the criminal case against Donald Edward Vernet, Jr. at Criminal Number 01-0495. WHEREFORE, the Commonwealth respectfully requests this Court to deny Larry C. Zimmerman's petition for return of weapons. Resp,.ct1ullY submitt71' ,I . 7 /1 ~ )\II~~b i . ! //1 "........{ II I j I!,~ (// J fche . Hamilt~ti Senior sistant District Attorney :,~__ 111!", ._" I ~ BRENDA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 01- 261 CIVIL ACTION LAW DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE COURT ORDER AND NOW, this _~ day of 1!\ o.n'b._, 2001, upon consideration of the attached Petition, a Rule to Show Cause is hereby issued on Plaintiff Brenda Lee Vernet and on the Cumberland County Sheriffs Office to show cause why the weapons set forth in the attached Petition should not be returned to Petitioner Larry C. Zimmerman because of Mr. Zimmerman's ownership of these weapons. This Rule to Show Cause is return~ble at a hearing' scheduled on the J 9ti day of -Apri L , 2001, at . J :3 () ...e..M. in Courtroom No. ~ of the Cumberland County Courthouse. . PetitiGmer's attorney shall serve a copy of this Order on Plaintiffs attorney and also serve a copy on the Cumberland County Sheriff's Office. By the CoUrt, J. By: cc: Joan Carey, Esquire Legal Services . Thomas Kline Sheriff of Cumberland County Edward L. Schorpp, Esquire Solicitor for Cumberland County Sheriff's Office Hubert X. Gilroy, Esquire Attorney for Petitioner Office of the District Attorney Exhibit 1 ,-,'1$~' ~ ~ - -, , BRENDA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 01- 261 CIVIL ACTION LAW DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE PETITION FOR RETURN OF WEAPONS Petitioner, Larry C. Zimmerman, by his attorneys, Broujos & Gilroy, P.C., sets forth the following: Petitioner is Larry C. Zimmerman, an adult individual residing at 86 Dewalt Drive, Mechanicsburg, Cumberland County, 'Pennsylvania. 2 The above captioned action is a protection from abuse action and this Court has issued a Protection from Abuse Order (Order) dated January 19,2001. At Paragraph 5 of the Order,' Defendant in the above matter, Donald Edward Vernet, Jr., was required to relinquish any firearms in his possession to the Cumberland County Sheriffs Office. 3 At time of service and execution of the Order by the Cumberland County Sheriffs Office, various guns were seized from the Defendant. Included in the guns seized from the Defendant were the following weapons: A. Browning 7mm-08 Bolt Action with scope, in case. ,~, ',-. . , ,- B. Browning 22-250 Bolt Action with scope, in case. C. Remington Game Master 270 Pump with scope. D. Weatherby 300 Mag. Mark V, with scope. E. Winchester Model 1100 Auto Loader. F. Colt 45 Butline in Spanish holster. G. Winchester 1200, 12 gauge pump. 4 The weapons as set forth in Paragraph 3 above are the property of Petitioner. They were in the possession of Defendant for Defendant's personal use. However, the weapons are owned by the . Petitioner and were either purchased by the Petitioner hirnselffrom a gun store or obtained through trade with other gun owners. The gun listed as the Colt 45 Butline is, in fact, registered in the name of the Petitioner. 5 Petitioner desires return of his weapons and Petitioner intends to secure the weapons in question and not allow Defendant any further access to the weapons. 6 Some of the weapons in question are collector items and are very valuable guns from a rnonetary standpoint and a personal standpoint to the Petitioner. 7 Defendant Donald Edward Vernet, Jr. joins in this Petition as set forth in the attached verification. ~~~ --,~ - ~ ,- 11 WHEREFORE, Petitioner requests your Honorable Court to enter an Order directing return of the weapons to him. Respectfully submitted, o Hubert X. G" oy, Esquire Attorney fi . Petitioner Broujos Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 (717) 243-4574 :i...,",~"~ " ~ ~,- - I" Property Recprd . ". Evidence g Found 0 Recovered 0 Case No. 01- j.6'. Prop. No. I b ..J I (I /8) ..4) --r1l } 11 ) . -',12) 3) f . It .} 15} 16} 17} 18) Found or recovered from: Oot'\G\cA Verne} .eportlng officer: 1": '{e....\- Location Date found/recovered ~l.Ib I ~~;~ f?eA \(..rl:)le I-I ~-~OO I Custodial/receiving o'fflcer: Date of custody: ~.Ho(t'\ 1~1'''~OO\ ( ITEMS: , .~ SS5L ~. rJ/A I ~ twn....6 't' Property IN lOUT DATE ITEM NOs. PURPOSE o Owner's name: I hereby certify J am the ner of above property : authorized agent to ~ ,efve the same. Owner's address Claimant's signature: "'pet~ claimed: Address: -- -- ~ q . BRENDA LEE VERNET, for herself and on behalf of her minor child: DALLAS "MICHAEL CONRAD, vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-~CIVIL TERM DONALD EDWARD VERNET, JR., 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 ':;his matter is scheduled on the l1. day of Janum;y, 2001, at II: 56 A: .m., in Courtroom No. on the4lh Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. ( You MUST obey the Order that is atta.cheduntil it is modified or terminated by the court after notice and hearing. If you disobeytbis 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;OOandlor up to six months injail under 23 Pa.C.S. 96114. Violation may also subject you to pro~ecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law. 18 V.S.C. 92265, 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. 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, hpwever, 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 ~ I AMERICANS WITH DISABILITJES ACT OF 1990 I The-CourtofCommon Pleas of Cumberland County is required by lawto comply with the Americans I with DlSliblllliles Act of 1990. Fop illiOt'fiiiUlOfi MOut ilccesslble faclllties ami f-eililolilible ilcc6mmodiitl.ofiS I I available to disabled individuals having business before the court, please contact our office. All arrangements I must be maoe at least 72 hours prior to any hearlng or business before the court. You must attend the : : scheduled conference or hearing. I , I \ -~!lf,~ "' ,- BRENDA LEE VERNET, on behalf of her minor child: DALLAS MICHAEL CONRAD, Plaintiffs v. DONALD EDWARD VERNET, JR Defendant : In the Court of Common Pleas of . : CUMBERLAND County, : PENNSYL VANIA : Civil Action - Law . : No. 01- ;161 : Protection Prom Abuse TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: DONALD EDWARD VERNET, JR. Defendant's Date of Birth is: December 7, 1959 Defendant's Social Security Number is: 188-52-6972 Name(s) of All protected persons, including Plaintiff and minor children: 1. BRENDA LEE VERNET 2. DALLAS MICHAEL CONRAD AND NOW, on 12th Day of January, 2001 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. , , , ~ 2. Defendant ~ evicted and excluded from the residence at: 3461 Spring Road Carlisle, PA or any other permanent or tern res ce where Plaintiff or any other person protected under this orde. . ay live. Plain' . 5;' anted exclusive possession of the residence. Defi. t shall have no right or pn. e to, enter or be present on the premises of tiff or any other person protected u . this Order. 3. Defendant is prohibited from having ANY CONTACT wi~ntifi; 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 foPowing locations for the duration of this order. ,,' Plaintiff's parents' home: 602 Meadowbrook Road Carlisle, P A .. ( Plaintiff's place of employment: TYCO (formerly AMP,Inc.) Harrisburg Pike Carlisle, :P A 4. Defendant shall not contact Plaint:ifi; or any other person protected under this Order, by telephone or by any other means, including through third persons. license the Defendant may owmgweapons to 'e' s Office or a designated local law enforcement agency for delivery to the Sherifi's Oflice. I. any and all firearms and weapons, specifically: 2. handguns 3. semi-automatic 12-gauge shotgun. 4. rifles 5. machine gun 6. compound bows and arrows 7, crossbows 8. black powder muzzle loader rifle ( , Defendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration of this order. -"'"-- c 6. The following additional relief is granted: Defendant is ordered to refrain from harassing Plaintifrs relatives or her minor child. Defendant is enjoined from damaging or destroying any property jointly owned by the parties or owned solely by Plaintiff. Defendant is ordered to transfer possession of the parties' Rottweiler canine to Plaintiff immediately upon being servedwith the Order in this case. 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: MIDDLESEX TOWNSHIP POLICE DEPARTMENT PENNSYLVANIA STATE POLICE NORTH MIDDLETON TOWNSHIP POLICE DEPARTMENT ( 8. The sherift; 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 pefendant's residence, where Defendant can be served. The Prothonotary is directed to file this Petition and Order without prepayment of costs. 9. THIS ORDER APPLlES lMMEDlATEL Y TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL JULY 12, 2002 OR UNTIL OTHERWISE MODIFIeD OR TERMINATED BY THIS 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 coutempt, which is punishable by a fine of up to $1,000.00 and/or up to six months in jail. 23 Fa.C.S. 96114. 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. 96113. 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.G ~92261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS - This Order shall be enforced by 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. If defendant violates Paragraphs 1 through 5 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 Sheriff's 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 officer made the arrest. BY TIlE COURT: /;(-f(~ If. r:;.).l~' ~tI'J Judge / e;J , ,:)6t) I . Date ( / Distribution to: Joan Carey, Attorney for Plaintiff MidPenn Legal Services TRUE COpy FROM RECORD In Testimony hereof, I here unto set my hand and the ~ of said urt at Carlisle, PA. Thi day of 001. , Prothonotary Faxed & Mailed to PSP "-"". '-' , , 'I, Cumberland County Sheriffs Dept. Weapons Confiscation Date JM 12. .zoo 1 Court Order OI-2,'M Name of Defendant Address ", ' LJotJA<" J::bwAfl.1:> V;;R.AiCr -- J/2 .3 "1M SPKI,J6 , ;2p CAiW6iL Telephone 2Jf$ - :N9 y Number of weapons seized 10 Make 1. WI'" '1J~f>lt~ 2. ~AI'')~ AIlA<; 3. PilOWNIJft All",!. 4. Wf.Alj.Jm~JoJ 5. ikrfm~TtJN p. if:,<1",t;1kJ;/ 7. Cotr Ilf_";,jt 8. AlMHt..,.., &lu,.,c. . 9. UullA I1A (>. B() 10. JIM?",", 11. 12. 13. 14. 15. Model/Caliber Moo 1/2 t;.A I1<MWo.J /22 'JSQ (1if>AILION /711M NARK X I .3.00 1/00 /12. ~ lId) J . .270 ibM\ l.,,,, Sf". /.4ts /,.38 Condition <rCO/.) "DOl> c;.OOl> <;Olli";) 40eD <'IOO!:l vo<JP J'oaI! Serial No. LW?FS78 LJ'i881t1XLt1 ., 1/6 OJU./V.3.M 7 N.l/SOoo JJ.uo/21. 1/ 1170l.((,.lSlf ~5'$'G.SA HAl CQI'1Il.~N' JE-'O <;;oae:> ~o. W "AI>. f /3 I\ltl<ll<ltlo c.o"PoUdb O<>w l/o9t. , Comments - , 41J .-;-'~'''~'''' ,J/ 'C-. Shmatllrp ~R.el#f.o~y .;;(J,QA/./ ,7ft/n/; " _~V. . ~._. Signature Defendant '}i,~~' ~" r'- I "" ~-~~ . " BRENDA LEE VERNET, On behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-261 CIVIL ACTION LAW V. DONALD EDWARD VERNET, JR., Defendant PROTECTION FROM ABUSE ORDER AND NOW, this day of , 2001, upon consideration of the Cumberland County Sheriff's Office Rule to Show Cause and the District Attorney's Office Rule to Show Cause, the Petitioner's request for return of weapons is hereby denied. By the Court: Kevin A. Hess, J. Joan Carey, Esquire Legal Services Hubert X. Gilroy, Esquire Attorney for Petitioner Thomas Kline Sheriff of Cumberland County Edward L. Schorpp, Esquire Solicitor for Cumberland County Sheriff's Office -i~1"'" lfIIRH"l'If. "11. ,-. ,_ r I,' " BRENDA LEE VERNET, On behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-261 CIVIL ACTION LAW V. DONALD EDWARD VERNET, JR., Defendant PROTECTION FROM ABUSE (') 0 (') C -n 7' ::DfII U tJ] --1~ ::;J COMMONWEALTH'S RULE TO SHOW CAUSE !:1;1l!';7.::1: <:P z t:;'-~ I :, ~.: t-g (f"),.:-" W - AND NOW, comes Michelle E. Hamilton, Senior Assis~mt ',:l.:') ::::~ (~) __.~h <: ?~ District Attorney, on behalf of the Commonwealth, resp~~ng;,.'to Q'T' z <~ :.< a-J :< Larry C. Zimmerman's petition for return of weapons, and averring the following: 1. Hubert X. Gilroy, Esquire, on behalf of Larry C. Zimmerman, filed a petition for return of weapons. See attached exhibit #1. 2. On January 12, 2001, this Court issued a Temporary Protection from Abuse Order for Brenda Lee Vernet against Donald Edward Vernet, Jr. 3. This Order directed Donald Edward Vernet, Jr. to relinquish any firearms in his possession. 4. On January 12, 2001, pursuant to the Temporary Protection from Abuse order, the Cumberland County Sheriff's Department seized all weapons found in Donald Edward Vernet, Jr.'s possession. :'~"""'l''' , '- 5. Donald Edward Vernet, Jr. is a convicted felon and is prohibited by law to possess firearms. 6. Donald Edward Vernet, Jr. was subsequently charged with eight counts of Persons Not to Possess, Use, Manufacture, Control, Sell or Transfer Firearms, 18 Pa.C.S. s6105, at Criminal Number 01-0495. 7. Hubert X. Gilroy, Esquire is representing Donald Vernet in this criminal case, Criminal Number 01-0495. 8. The weapons found in defendant's possession are evidence of and support the charges at Criminal Number 01-0495. 9. Hubert Gilroy avers that the weapons found in Donald Edward Vernet, Jr.'s possession belong to Larry C. Zimmerman. 10. Even if the weapons belong to Larry C. Zimmerman, they should not be returned to his custody until the conclusion of the criminal case against Donald Edward Vernet, Jr. at Criminal Number 01-0495. WHEREFORE, the Commonwealth respectfully requests this Court to deny Larry C. Zimmerman's petition for return of weapons. ResP,ct~ullY submitt71 , \!I_ 7 /i ~ \ I ~ . ! //1 ) II I, /.' ..-{ II I I I, iche '. Hamiltk1' Senior sistant District Attorney - .~ , . BRE!\('DA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 01 - 261 CIVIL ACTION LAW DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE COURT ORDER AND NOW, this_ 21st: dayof~.-, 2001, upon consideration of the attached Petition, a Rule to Show Cause is hereby issued on Plaintiff Brenda Lee Vernet and on the Cumberland County Sheriff's Office to show cause why the weapons set forth in the attached Petition should not be returned to Petitioner Larry C. Zimmerman because of Mr. Zimmerman's ownership of these weapons. This Rule to Show Cause is returnable at a hearing' scheduled on the /91:/. day of -Ap ri L ,2001, at J:3 () .E..M. in Courtroom No. ~ of the Cumberland County Courthouse. Petitioner's attorney shall serve a copy of this Order on Plaintiffs attorney and also serve a copy on the Cumberland County Sheriff's Office. By: J. cc: Joan Carey, Esquire Legal Services Thomas Kline Sheriff of Cumberland County Edward L. Schorpp, Esquire Solicitor for Cumberland County Sheriff's Office Hubert X. Gilroy, Esquire Attorney for Petitioner Office of the District Attorney Exhibit 1 - ~. ~..~"~_.~ IJlIilI!I!l'I , . BRENDA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO.Ol- 261 CIVIL ACTION LAW DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE PETITION FOR RETURN OF WEAPONS Petitioner, Larry C. Zimmerman, by his attorneys, Broujos & Gilroy, P.C., se.ts forth the following: 1 Petitioner is Larry C. Zimmerman, an adult individual residing at 86 Dewalt Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2 The above captioned action is a protection from abuse action and this Court has issued a Protection from Abtise Order (Order) dated January 19,2001. At Paragraph 5 of the Order,' Defendant in the above matter, Donald Edward Vernet, Jr., was required to relinquish any firearms in his possession to the Cumberland County Sheriffs Office. 3 At time of service and execution of the Order by the Cumberland County Sheriffs Office, various guns were seized from the Defendant. Included in the guns seized from the Defendant were the following weapons: A. Browning 7mm-08 Bolt Action with scope, in case. !~~" ~.-- B. Browning 22-250 Bolt Action with scope, in case. C. Remington Game Master 270 Pump with scope. D. Weatherby 300 Mag. Mark V, with scope. E. Winchester Model 1100 Auto Loader. F. Colt 45 Butline in Spanish holster. G. Winchester 1200, 12 gauge pump. 4 The weapons as set forth in Paragraph 3 above are the property of Petitioner. They were in the possession of Defendant for Defendant's personal use. However, the weapons are owned by the ' Petitioner and were either purchased by the Petitioner himselffrom a gun store or obtained through trade with other gun owners. The gun listed as the Colt 45 Butline is, in fact, registered in the name of the Petitioner. 5 Petitioner desires return of his weapons and Petitioner intends to secure the weapons in question and not allow Defendant any further access to the weapons. 6 Some of the weapons in question are collector items and are very valuable guns from a rnonetary standpoint and a personal standpoint to the Petitioner. 7 Defendant Donald Edward Vernet, Jr. joins in this Petition as set forth in the attached verification. i1f(!.,.~'.-~ -'--''f'''' '" - .., ~ r ~ " WHEREFORE, Petitioner requests your Honorable Court to enter an Order directing return of the weapons to hirn. Respectfully submitted, 0' Hubert X. G' oy, Esquire Attorney t1 Petitioner Broujos Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 (717) 243-4574 "~~~' '1'1 ' i 1 Property Record '-". Evidence g Found 0 Recovered 0 Case No. 01- j.61 Prop. No. I b l-/ i (I Found or recovered from: Oot'\G\cA Verne.\- .eportlng officer: 1": ~~ Location Date found/recovered ~&fbl ~fr:l'<.~ \(pfl:~le I-I~.~OD' Custodial/receiving o'1flcer: Date of c:ustody: o .L_ \-,~...~OO\ O. t1Uf 1'\ ( ITEMS: /B) /tM~(~- ~) ...-r"ll ) 11) . -'.12) 3) I (I .) , 5) 16) 17) 18) Property IN lOUT DATE ITEM NOs. PURPOSE o Owner's name: I hereby certify I am the ner of above property : authoriZed agent to t . eive the same. -,-~~ -~- Owner's address Claimant's signature: "'pate. claImed: Address: -. -- " . BRENDA LEE VERNET, for herself and on behalf of her minor child: DALLAS MICHAEL CONRAD, vs. : IN THE COURT OF COMMON PLEAS OF DONALD EDWARD VERNET, JR., Defendant : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-~CIVIL TERM : PROJECTION FROM ABUSE NOTICE OF HEARlNG 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 he evicted from your residence and lose other important rights. . , ~ . A hearing :~is matter is scheduled on the .iJ..- day of January, 2001, at II: 3'0 It-m., in Courtroom No. on the 4th Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. You MUST obey the Order that is attached until it is modified or tenninated by the court after notice land hearing. If you disobeytbisOrder, the pl)lice may arrest you. Violation oftbis 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 injail under 23 Pa.C.S. ij6114. Violation may also subject yOU to prosecution and criminal penalties under the PennsyIvania Crimes Code. Under federal law, IS U.s.C. ~2265, this Order is enforceable anywhere in the United States, tn'ballands, 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, IS U.S.C. ~ 2261-2262. Yon should taketbis 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 lCJCJO The-Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Dlsabllltles Act of 1990. Fol' lntOl'ititlofi aboUt accessible fllcllitles liiId f-eiiSoil.i1ble aCColllifiod!tiofis 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 hearlng or business before the court. You must attend the " scheduled conference or hearing. - BRENDA LEE VERNET, on behalf of her minor child: DALLAS MICHAEL CONRAD, Plaintiffs : In the Court of Common Pleas of . : CUMBERLAND County, : PENNSYLVANIA v. : Civil Action - Law . : No. 01- ;J.GI DONALD EDWARD VERNET, JR. Defendant : Protection Prom Abuse TEMPORARY PROTECTION FROM ABUSE OItDER Defendant's Name is: DONALD EDWARD VERNET, JR Defendant's Date of Birth is: December 7. 1959 Defendant's Social Security Number is: 188-52-6972 Name(s) of All protected persons, including Plaintiff and minor children: 1. BlmNDA LEE VERNET 2. DALLAS MICHAEL CONRAD AND NOW, on 12th Day of January, 2001 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: Plaintitrs request for a temporary protection order is grauted. 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. ~ ;~l'I""".!'lo:!Mll ~~, I. , , evicted and excluded from the residence at: 3461 Spring Road Carlisle, P A or any other permanent or tern ary res ce where Plaintiff or any other person protected under this Ord . . ay live. Plain' . 5;' anted exclusive possession of the residence. Defe. shall have no right or pn' e to enter or be present on the premises of ntiff or any other person protected u . this Order. 3. Defendant is prohibited from having ANY CONTACT wit~B; or any other person protected under this Order, at any location, including but not limited to any contact at Plaintiff's schoo~ business, or place of employment. Defendant is ' specifiqa.lIy ordered to stay away from the folilowing locations for the duration of this order. ,;' Plaintiff's parents' home: 602 Meadowbrook Road Carlisle, P A .. . ( Plaintiff's place of employment: TYCO (formerly AMP,Inc.) Harrisburg Pike Carlisle,P A 4. Defendant shall not contact Plaintiff; or any other person protected under this Order, by telephone or by any other means, including through third persons. license the Defendant may oWIng weapons tOl:b:ili"S s Office or a designated local law enforcement agency for delivery to the Sheriff's Office. I. any and all firearms and weapons, specifically: 2. handguns 3. semi-automatic 12-gauge shotgun, 4. rifles 5. machine gun 6. compound bows and arrows 7. crossbows 8. black powder muzzle loader rifle ( Defendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration of this order. :,,,-~"",,,..,,,~.,,..",,,,,,,,,,..,...,,,,.,,._..,,",..,,,-- ,~ "'O~~ ,~........ I I ~-- ( \ ,UljlilRllli~ 6. The following additional relief is granted: Defendant is ordered to refrain from harassing Plaintiff's relatives or her minor child. Defendant is enjoined from damaging or destroying any property jointly owned by the parties or owned solely by Plaintiff. Defendant is ordered to transfer possession of the parties' Rottweiler canine to Plaintiff immediately upon being served with the Order in this case. 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: MIDDLESEX TOWNSHIP POLICE DEPARTMENT PENNSYLVANIA STATE POllCE NORm MIDDLETON TOWNSHIP POLICE DEPARTMENT 8. 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 infOllD the designated authority of any addresses, other than the J:>efendant's residence, where Defendant can be served. The Prothonotary is directed to file this Petition and Order without prepayment of costs. 9. THIS ORDER APPLffiS lMMEDlATEL Y TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL JULY 12, 2002 OR UNTIL OTIlERWISE MODIFIED OR TERMlNAlED BY THIS 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. &61)4. Consent of the Plaintiff to Defendant's return to the residence sha1l 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 himJher 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.G ~S2261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS ~-~ .. ..,.."'"""" ( This Order shall be enforced by 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. If defendant violates Paragraphs I through 5 of this Order, defendant shall be arrested on the charge of Indirect Criminal Contempt. AIi 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 of law 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 Sheri:ff's office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this court, unless the weapon/s are evidence of a crime, in which case, they shall I-emain with the law enforcement agency whose officer made the arrest. ( i BY THE COURT: /o/~ A. ~j~... ti~fI"J Judge / r;l I ....:J.M I . Date Distribution to: Joan Carey, Attorney for Plaintiff lMidPenn Legal Services Faxed & Mailed to PSP TRUE COpy FROM RECORD In Testimony hereof, I here unto set my hand and the !\fllll of said urt at Carlisle, PA.' Tho day of 001. e 'N~~~_~, ^, ~U__ " ~. " . Cumberland County Sheriffs Dept. Date JM ..lOU, /l Name of Defendant .:\ ./ LJOtJ/ll() E [:""fllI.tJ VEilJJtr Weapons Confiscation -- Jll Number of weapons seized 10 Comments ~ Model/Caliber Moo / /,l c;.A I1ib/lWoAl /2.2 '.25" I'fH.Au.,lIN /711M t'/MK "i" / .500 /lOP III ~ 7(.0 j . 271> &J"" (.,..1 6",. /.41$ 1..38 C,11",PlJUfil) &:>w i.:D.-~t!tJ...,Jl~ Court Order oj - Zt.1 Address .3 W.! ~PKI.J? ~j) CAfWSU: Telephone .zif3 - S<f9 9 Condition Serial No. C;CPl> LW?l!S78 GioOllt> 4<j'lJif /,lXLt1 .., ~OU.l'> Jl60'lIlV3.I-17 (,Oilr.:> H.l'Sooo 400b JJ.u,Z,J21. V <lDOD g, 1o'f~SIJ v{Jf}J) ~~SA /WI! 11M G:l<JI::> w "'''' f I:' AAfloutll ~(> }/Oq& < JVi,!!> 1<' I. - :4J~~/,rft{wI: . 't.._v' ,'.. Signature Defendant ,1/; '~---~-,. .JI "- SiRnal"" ~lllil#f-orfl'ej5uty -r~",_. lI'oI!'!' ~ " -I' " BRENDA LEE VERNET, On behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-261 CIVIL ACTION LAW V. DONALD EDWARD VERNET, JR., Defendant PROTECTION FROM ABUSE ORDER AND NOW, this day of , 2001, upon consideration of the Cumberland County Sheriff's Office Rule to Show Cause and the District Attorney's Office Rule to Show Cause, the Petitioner's request for return of weapons is hereby denied. By the Court: Kevin A. Hess, J. Joan Carey, Esquire Legal Services Hubert X. Gilroy, Esquire Attorney for petitioner Thomas Kline Sheriff of Cumberland County Edward L. SChorpp, Esquire Solicitor for Cumberland County Sheriff's Office ;:~~'II'<m!_ ~~ ~,,- 'I ~ BRENDA LEE VERNET, On behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 01-261 CIVIL ACTION LAW V. DONALD EDWARD VERNET, JR., Defendant PROTECTION FROM ABUSE c:C'J,= (;) 0 _ _ "T1 <. ~ "T) t6 "''J =J S2 iJ) :::;~"J J, ..2.J Zr:~ I [3 AND NOW, comes Michelle E. Hamilton, Senior ASSi~~t ~ '. ~~ X:;. C) :....._: (-)__'} District Attorney, on behalf of the Commonwealth, res~inSJ tci;jhl L; u g Larry C. Zimmerman's petition for return of weapons, ana< .~ ~ COMMONWEALTH'S RULE TO SHOW CAUSE averring the following: 1. Hubert X. Gilroy, Esquire, on behalf of Larry C. Zimmerman, filed a petition for return of weapons. See attached exhibit #1. 2. On January 12, 2001, this Court issued a Temporary Protection from Abuse Order for Brenda Lee Vernet against Donald Edward Vernet, Jr. 3. This Order directed Donald Edward Vernet, Jr. to relinquish any firearms in his possession. 4. On January 12, 2001, pursuant to the Temporary Protection from Abuse Order, the Cumberland County Sheriff's Department seized all weapons found in Donald Edward Vernet, Jr.'s possession. .,~~~ '--' ---)~T'~~~ I' I ~ 5. Donald Edward Vernet, Jr. is a convicted felon and is prohibited by law to possess firearms. 6. Donald Edward Vernet, Jr. was subsequently charged with eight counts of Persons Not to Possess, Use, Manufacture, Control, Sell or Transfer Firearms, 18 Pa.C.S. ~6105, at Criminal Number 01-0495. 7. Hubert X. Gilroy, Esquire is representing Donald Vernet in this criminal case, Criminal Number 01-0495. 8. The weapons found in defendant's possession are evidence of and support the charges at Criminal Number 01-0495. " 9. Hubert Gilroy avers that the weapons found in Donald Edward Vernet, Jr.'s possession belong to Larry C. zimmerman. 10. Even if the weapons belong to Larry C. Zimmerman, they should not be returned to his custody until the conclusion of the criminal case against Donald Edward Vernet, Jr. at Criminal Number 01-0495. WHEREFORE, the Commonwealth respectfully requests this Court to deny Larry C. Zimmerman's petition for return of weapons. ResP1ct.lu. lly SUbmit.t. e1' . /' ! . 7 . / ~ j \1 . !i{J1 i ' {/ /i .-! II J rL~ I/f tche . Hamiltrc" Senior sistant District Attorney ,~1~"'=,..,.,.,.., "~~ BRENDA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 01 - 261 CIVIL ACTION LAW DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE COURT ORDER AND NOW, this_ 21st: dayof~. ,2001, upon consideration of the attached Petition, a Rule to Show Cause is hereby issued on Plaintiff Brenda Lee Vernet and . on the Cumberland County Sheriff's Office to show cause why the weapons set forth in the attached Petition should not be returned to Petitioner Larry C. Zimmerman because of Mr. Zimmerman's ownership of these weapons. This Rule to Show Cause is returnable at a hearing' scheduled on the /91:/. day of Jip ri L ,2001, at }:3 () ...e..M. in Courtroom No. ~ of the Cumberland County Courthouse. Petitioner's attorney shall serve a copy of this Order on Plaintiff's attorney and also serve a copy on the Cumberland County Sheriff's Office. By: - ,J. cc: Joan Carey, Esquire Legal Services . Thomas Kline Sheriff of Cumberland County Edward L. Schorpp, Esquire Solicitor for Cumberland County Sheriff's Office Hubert X. Gilroy, Esquire Attorney for Petitioner Office of the District Attorney Exhibit 1 F~~ij'Dl;l:!#,W1I!. ~, ~ r- "~I . BRENDA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v : NO. 01 - 261 CIVIL ACTION LAW DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE PETITION FOR RETURN OF WEAPONS Petitioner, Larry C. Zimmerman, by his attorneys, Broujos & Gilroy, P.C., sets forth the following: Petitioner is Larry C. Zimmerman, an adult individual residing at 86 Dewalt Drive, Mechanicsburg, Cumberland County, Pennsylvania. 2 The above captioned action is a protection from abuse action and this Court has issued a Protection from Abuse Order (Order) dated January 19,2001. At Paragraph 5 of the Order, Defendant in the above matter, Donald Edward Vernet, Jr., was required to relinquish any firearms in his possession to the Cumberland County Sheriffs Office. 3 At time of service and execution of the Order by the Cumberland County Sheriff s Office, various guns were seized from the Defendant. Included in the guns seized from the Defendant were the following weapons: A. Browning 7mm-08 Bolt Action with scope, in case. '1'~~-~"~~,,,~__~ =_ ~ I' ~, , .'ji';;~.,w~j~ B. Browning 22-250 Bolt Action with scope, in case. C. Remington Game Master 270 Pump with scope. D. Weatherby 300 Mag. Mark V, with scope. E. Winchester Model 1100 Auto Loader. F. Colt 45 Butline in Spanish holster. G. Winchester 1200,12 gauge pump. 4 The weapons as set forth in Paragraph 3 above are the property of Petitioner. They were in the possession of Defendant for Defendant's personal use. However, the weapons are owned by the ' Petitioner and were either purchased by the Petitioner himselffrom a gun store or obtained through trade with other gun owners. The gun listed as the Colt 45 Butline is, in fact, registered in the name of the Petitioner. 5 Petitioner desires return of his weapons and Petitioner intends to secure the weapons in question and not allow Defendant any further access to the weapons. 6 Some of the weapons in question are collector items and are very valuable guns from a rnonetary standpoint and a personal standpoint to the Petitioner. 7 Defendant Donald Edward Vernet, Jr. joins in this Petition as set forth in the attached verification. ~,"' 'I ., ."..,.,~ - WHEREFORE, Petitioner requests your Honorable Court to enter an Order directing return of the weapons to him. Respectfully submitted, o . oy, Esquire Attorney fi Petitioner Broujos Gilroy, P.C. 4 North Hanover Street Carlisle, PA 17013 (717) 243-4574 1>M~!lfflIP'I!~, I I." - Property Record '-'. Evidence g Found 0 Recovered 0 Found or recovered from: Oot'\G'cA Verne} .epo.rtlng officer: Case No.ol-j.6' Prop. No. I b..J 1": ~~ Locallon Dale found/recovered . ~&fb I ~~:rc.. fDl ,C-rl:)lC I-I ~ -,)00 I Custodia!ireceiving o'fficer: Date of custody: o .'-- 1-1~'~OO\ O. f1tJf'" " i (l ITEMS: . .",12) 3) f . l{ .) 15) 1 S) 17) 18) Property IN lOUT DATE ITEM NOs. o PURPOSE Owner's name: Owner's address I hereby certify J am the ner of aboVe property : authoriZed agent to ~ . eive the same, Claimant's signature: "pet~ claimed: Address: -' -' ~iim'",,=i~' ~~" . . I. ~ BRENDA LEE VERNET, for herself and on behalf of her minor child: DALLAS MICHAEL CONRAD, vs. : IN THE COURT OF COlMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-~ CIVIL TERM DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE NOTICE OF HEAlUNG 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~is matter is scheduled on the /9 day of January, 2001, at II: 3d A-.m., in Courtroom No. on the 4lh Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. You MUST obey);he Order that is attached until it is modified or terminated by the court after notice l and hearing. If you disobey this. Order, the Wlice may arrest you. Violation of this Order may subject you ' to a charge of indirect criminal oontempt which is punishable by a fine of up to $1,000:00 and/or up to six months injail under 23 Pa.C.S. 96114. ViolatioDmayalso subject you to prosecution and criminal penalties under the Pennsylvania CrlmesCode. Under federal law, 18 D.S.C. ~2265, this Order is enforceable anyw~ 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. S 2261-2262. . You should take this paper to your lawyer at once. You have the rightto 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 required by law to comply with the Americans WIth Disabllifies Act of 1990. FOr lnfor-matiOfi libout acusSl1;le facilities and f-eliSolUll;le accOmModittiofis 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. ~-~ .'-~"'!'"o="_ BRENDA LEE VERNET, on behalf of her minor child: DALLAS :MICHAEL CONRAD, Plaintiffs v. DONALD EDWARD VERNET, JR. Defendant : In the Court of Common Pleas of . : CUMBERLAND County, : PENNSYLVANIA : Civil Action - Law . : No. 01- .;J.GI : Protection From Abuse TEMPORARY PROTECTION FROM ABUSE OJU)ER Defendant's Name is: DONALD EDWARD VERNET, JR. Defendant's Date of Birth is: December 7, 1959 Defendant's Social Security Number is: 188-52-6972 Name(s) of All protected persons, including Plaintiff and minor children: 1. BRENDA LEE VERNET 2. DALLAS MICHAEL CONRAD AND NOW, on 12th Day of January, 2001 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: Plaintiff's request for a temporary protectiou 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. " ~ , . ,~ I 3461 Spring Road Carlisle, P A or any other permanent or tern res ce where Plaintiff or any other person protected under this Orde . ay live. Plain' '.' anted exclusive possession of the residence. Defi shall have no right or pn' e to enter or be present on ntiff or any other person protected this Order. 3. Defendant is prohibited from having ANY CONTACT with Plaintifi; or any other person protected under this Order, at any location, including but not limited to any contact at plaintiff's school, business, orpla.ce of employment. Defendant is ' specifically ordered to stay away from the following locations for the duration of this order. ,,' Plaintiff's parents' home: 602 Meadowbrook Road Carlisle, P A ,II> . ( Plaintiff's place of employment: lYCO (formerly AMP,Inc.) Harrisburg Pike Carlisle, P A 4. Defendant shall not contact plaintifl; or any other person protected under this Order, by telephone or by any other means, including through third persons. license the pefendant may () oWlDgweapons tOme s Office or a designated local law enforcement agency for delivery to the Sheriff's Office. I. any and all fire8l'DlB and weapons, specifically: 2. handguns 3. semi-automatic 12-gauge shotgun. 4. rifles 5. machine gun 6. compound bows and arrows 7. crossbows 8. black powder muzzle loader rifle (, Pefendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration of this order. ,,~_>'o/'""~,"'li' " ( l~"T 6. The following additional relief is granted: Defendant is ordered to refrain from harassing Plaintiff's relatives or her minor child. Defendant is enjoined from damaging or destroying any property jointly owned by the parties or owned solely by Plaintiff. Defendant is ordered to transfer possession of the parties' RottweiIer canine to Plaintiff immediately upon being served with the Order in this case. 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: MIDDLESEX TOWNSmP POLICE DEPARTMENT PENNSYLVANIA STATE POLICE NORm MIDDLETON TOWNSBlP POLICE DEPARTMENT 8. 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. 9. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL JULY 12, 2002 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS 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:fii1e of up to $1,000.00 and/or up to six months injail. 23 Pa.C.S. ~61l4. 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 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 ENFOR.CEMENT OFFICIALS . . - This 9rder shall be enforced by 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. If defendant violates Paragraphs 1 through 5 of this Order, defendant shal1 be arrested on the charge of Indirect Criminal Contempt. Ari 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 of law 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 sbuse. Weapons must forthwith be delivered to the Sherift's office of the county which issued this Order, which office shall maintain possession of the weapons until 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 arrest. BY THE COURT: . /0/ -f(~ A. ~JI.-. . ti~ </'-J , Judge IOJ , ..:J./.X) I . Date ( , Distribution to: Joan Carey, Attorney for Plaintiff :MidPenn Legal Services Faxed & Mailed to PSP TRUE COpy FROM RECORD In Testimonybereof, I here unto set my band and the p of said urt at Carlisle, P A.' ThO day of 001. (:.1!i~I\lIlW1~~m" ,., ~ " r I~ I . Date . Cumberland County Sheriffs Dept. Weapons Confiscation 3M /2 .2 ()tJ I Court Order 01- Lt.1 Address 3'1(,,{ "' .Kt> Name of Defendant ~\ ~ II lJoNA'", C i\wARl:> ,,;:;Jl:l>lcr -- J/l SPi<!I,;)t;> CAIWbUf Telephone .2lf3 - S'f9 <j Condition Serial No. L Il.~FS78 1.J'i8iJlfh.z.t17 JI{.OI(NV3.M7 H.lli!.ooo A!U1A21. V g, 7oAff;2.SlJ ~5$'G.5A HM Number of weapons seized 10 1. 2. 3. 4. 5. Make W/N'U~$ltf<. tk~uJ',)ft AliA'; BD./MNi.J., ARJ'l'" Wf./mlill,,'1 WiNI; rwI i.i:,lfiiltp7dN Cot, Ill- Wi.lfif/l. Model/Caliber Moo /124A I1illAU,o^, /22 '.25,;/ (H UAlL/ON / 7/'1M NAIll( .i. / ~oo I/(JI} / /2. <;A 7(.0 J . :!Jo &/"" (.",1 5ff,. /.'fs /.38 C;CPl:> "'/XII:> .q,OOl> vool> 4(01) <lOOD vo<JP i'ooI! <;o<Ji::> "001> W "AM t /3 Altlloullo NCiJ(b p. 7. 8. 9. 10. 11. 12. 13. 14. 15. AMHllI/liV &iUM(. - c,/I"Pcu,.!) i!Pw ULtJiA flM,. go 1/(>(11'''' CD_Ul.A~ Ji.'XP Comments - . 'N , '41; '-;-'-~-'" "H ,-_.fugna,,,rp SRefflforrrepUt'y 'T I-~ = '<<l.cMj' / , ;'~~~~"'" - "'~f_"'" 4~; ~. /1/" ;h /" _ _/ /, .'/"~~ ,t! ,:-~-'--;; I ." liI-'r/. j.'t:"l/nLP < <'t. _~,,-. . .-" ,,' Signature Defendant - _ - ~T =" ~,~'"' ,., .r-'.'~_"_:~r/" ,~'}"'" ~," ,'.-(""""'~''''','''- ,"". ":'.'."'r ;"'r""''''~''''';."''''-~ - ,'< ".'- , ~'""\~~'_'l:'''':'''''',;''','f''A';' ('t'.':~"~!"''';;',\f "r!<.'" "., ': ".,,!,,'~,p"";\",,-:,'~"r;'-o'l'{"1"',~Y'.'P.-,..~'-\\:t"~'":; i'"'[""'!\',,,,^<i';(';",,"~<-:"""~';'-~'Y;-''',, ';;:~!:' ::'i' MDW&t6 INFORMAtiON. ADVICE o,AoVOCAO{ , . 'A.rrbRN'EYS<& COU~SEu.oRS AT LAw , ',' ,., -, '" I " WI~L'~:'F::MARTSON JOHNB, FOWLER III 'EDWARD L 'S.cHoMp DANIELK DEARDORFF , . THOMAs J. WILLIMlS , Ivo V. 'Ono III . GEORGEB. FN-LERJR,' CARLe. RISCH . MAR~A..:'DE~:LINGER "-BOARD CERTiFIED ,CM'L t~L SPEC1A!-IST TEN EA:rr HIGH STREET, CARLISLE;. P'ENNSYtYANIA 17013 TELEPHqNE(717) 243-3341 ' FACSIMILE (717) 243-1850 INTERNET www.mdwo.com April 2, 2001 , I:ionorable KeviilA. Hess CU)TIbeilancl County Courthouse " I Courthouse Square . Carlisle,PA 17613 , RE: Brenda Lee Vernetv..DonaldEdwardVernet, Jr. No.On61 (PFA) .. . QurFile No. J0282:3 Dear Judge Hess:' . ' .' - " ' , , .,', I am Solicitor to Sheriff R.ThdmasKline. . La!ninTe~eiptofacopY ofyouf Or~er dated. March 21,2001 scheduling ahearingonaRul~toShow Cause for Aprj119, 2001 lltl:30RM... The . PetitionwasfileUby. LarryC.ZilI)li1erman WhO .s!:eksth!: r!:t\Im, of yariousweaponscqnfisc;aiedby the. Sheriff's Office uno.erthe Protection frornAbuse Order previouslyissued. '. . , ". ' . . . -. , , . .' , . . , Adliitiona\ly, I amildvisedby Sheriff Kline thathispersonnelwilll1e!:l:latleast six we~ks to conduct the proper investigation as to the true .owner of the weapons. . ' , -, - - ' ' , . . , Therefore, I wotildrequestapostp0l1ementofthehearing in order tOall0~Suffic;iehttirn~foi theil1vestigation and to. ,avoid my,schedllling conflict. Thankyouforyour kind consideration. . V erytruly yours, '., -. ' . , ' - '. . MARTSONDEARDORF'FWILLIAMS &OTTO . ~'.'..'.."'...'."..""~'..."..."'."""".."'..'.....' , , , ' ' ' , . ", '. - " . " ..' I Edward L. Schotpp . ELS/tde cc: Jo1Ul Carey, Esquire . " R: Th0rt1as.Kline, Sheriff Hubert X: Gilroy, Bsquire Office()f thebistrict Attorney' F:\FILES\DATAJ:'ILE\Genltr,cm:\,102823-kh.l ., . . . . ' - , .' , . ' , ' , ' . , . I NF 0 R MATI ON 0 'A DV I.CEoA DV 0 CAe y "" P'"'~1ii'''ffflll'J\llf_.M;.~ " ~,,"~'r.=~~,..m~"'_,' ."'Ir ~ I ~~~, ....""~~ "'~"""~r ~ ~ ~~~ c~,^'~'. ~..__ ,. '.=..' ~ =".,~,~, ~,''''''~>, ,~. --"'.~f"~ BRENDA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 01-261 CIVIL ACTION - LAW DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE COURT ORDER AND NOW, this tJ~ day of February, 2002, a hearing is scheduled in Courtroom No. 4 of the Cumberland County Courthouse on the ;:; /.cb day of '!n~ , 2002 at q : rJ/) -4-.M. at which time testimony will be taken on the petition filed by Larry C. Zimmerman for return of weapons that were seized in the above matter. BY THE COURT, By: ,J. cc: ~rt X. Gilroy, Esquire ~~::ney for Defendant Sergeant Barry Horn ../ Cumberland County Sheriffs Office !I~ LOJ.-k -OJ. .-Michelle Sibert, Esquire ;/ Office of the Cumberland County District Attorney ? ".roan E. Carey, Esquire V Attorney for Plaintiffs '. l ~ f,~ 1 ,~ , ~ _"""c'< - -.-' .- ~. . -, ~- ~ - ~ "~"''' - : 1lll....'*'lIIiiliilllf ",""ic'""'" rl~'.'"""""""~~~'-Z -~', ...;.~' 'u~'_L..''-'-~ ,--,- I ,.':'t,,;L:,:{Jr/:,HV ,,-,,'j rr-rt ,- IJ, ".,,' -I', ')>oM ~_ ;.' "-"' "." '2 0'11 1- i--i l .~: ;J "'" C' ,.,. ,. "'~'J'''''V JUll};c;:.r-;I..._,;:'-\'\';) \.../U- i\ I I PENNSYLYANIA ".- 1_ JL,J_ ~~D,_",,)ll!;~r~k'~"'~~'l'~<:<-_'~ ,," _7':,'""_ ',t-,' "~_"..."".,,-~,,,,, .,~"" ,.,__ ~_ <_ ~ ""'-'='- , I ~ "'_ _, ~ . BRENDA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 01-261 CIVIL vs. CIVIL ACTION - LAW DONALD EDWARD VERNET JR., : Defendant PROTECTION FROM ABUSE IN RE: PETITION FOR RETURN OF WEAPONS ORDER AND NOW, this ~2 ~ day of March, 2002, hearing in the above captioned rnatter set for March 21, 2002, is continued to Monday, Apri115, 2002, at 11 :00 a.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, P A. BY THE COURT, ~ Carey, Esquire For the Plaintiff . //4. Jfubert X. Gilroy, Esquire For the Petitioner Michelle Sibert, Esquire Assistant District Attorney :r1m '~~~-,~~ ",..' 0=,_-"',n''t''!f~-,_~,-".?_"_ '.' ""'_ I ?~'~IWIlI-iil !mlli'~iiltiI:~~~$l9lEllilW<iIlI~~~~1il. ~ ~ _~f .........~~~.< - -, J.]lllJlJll!"w --"'" " "",,,'C-,,,,,'f'~"c'_'_ A"',O_, - l'_ ""_~-1,"';"'_",,",' ~ AA ~_.., ~_"'" ~ ,,_ ~ ' _I '" , ,-,-. I,~ -'j' , :'''"\'1-/<1)"-,,.- _ ~ )F,! I I ,) ....,,. :"'1 / ~i j'd I i.';: C'c; .j~ Ci ;!,,/-~' " IVI~'k)::':-i'.J',;,:~ (r.1 '\n""\/ 0;':" f'. '""'\;:~\ ,,-/,,-~,.J! >: I I I _1'~I'i')1 u~J,J\jIA ~. "'" ~'l ..,,,-.'~ " '- ~ i . BRENDA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiff : IN THE COURT OF COMMON PL~~ ~F . : CUMBERLAND COUNTY, PENNS ~IA . , v : NO. 01-261 CIVIL ACTION - LAW )lrA DONALD EDWARD VERNET, JR., Defendant -i~~r..,.__, : PROTECTION FROM ABUSE PETITIONER'S EXHIBIT List of Weapons Ownership Claim 1. Browning 7mm-08 Bolt Action with scope, in case Larry Zimmerman 2. Browning 22-250 Bolt Action with scope, in case Larry Zimmerman 3. Remington Game Master 270 Pump with scope Larry Zimmerman for his nephew 4. Weatherby 300 Mag. Mark V, with scope Larry -Zimmerman 5. ,c Winchtster Model 1100 Auto Loader '" Donald V ernet ' 6. Colt 45 Butline in Spanish Holster --- Larry Zimmerman 7. Winchester 1200, 12 gauge pump ,....;rPistol "v l' Father of Donald Vernet Larry Zimmerman, 8. c- " , ~_>, r ~rl ~" =, ~, - .. BRENDA LEE VERNET, on behalf of her minor child: DALLAS MICHAEL CONRAD, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. DONALD EDWARD VERNET, JR., Defendant 01-0261 CIVIL TERM IN RE: RETURN OF WEAPONS ORDER OF COURT AND NOW, this 15th day of April, 2002, the Court enters the following order, disposition of the weapons on Petitioner's Exhibit Number 1 attached hereto, noting that Item 5 is a Remmington weapon, and further noting that Item 8 is denoted an American Bull Dog: 1. Weapons 1, 2, 3, 4, 6 and 7 shall be returned to Larry Zimmerman. 2. Weapons 5 and 8 shall be delivered to Donald Edward Vernet, Sr. This order is entered with the understanding that the captioned defendant will not possess these or any other weapons until such time as any disability in that regard shall be removed. By the Court, /Michelle H. Sibert, Esquire For the Commonwealth J. ") ~ l 1./ -I g' '0 ')... ~ ~ubert X. Gilroy, Esquire For the Defendant /sheriff-plJ...tit..l bOll.' eell.'t, 1t :-rii1J _ _",., L ".' I I '"' f!ilillli1illlillil1lliillil~ . ],LUI:.lJ", "H -~IiiM~.'''' . wiA ,,-..h.~ :,-"~ - ~~- ~. , ,,_, .",,:>,"_,'_<.~r"-""',,'J,,-_'.~ '~,". '. .,.- ,,;~ " _ -l . L ~",l.. 'c" "I ill F1LED-{)FFiCE OF :i''\T!']''OT!\RY 02 APR ! 8 P1112: 59 CUMBf::RLANO COUNTY PENNSYLV/i!\!lf\ ~ H ~__" "'_ BRENDA LEE VERNET, on behalf of her minor child DALLAS MICHAEL CONRAD, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v : NO. 01-261 CIVIL ACTION - LAW DONALD EDWARD VERNET, JR., Defendant : PROTECTION FROM ABUSE PETITIONER'S EXHIBIT List of Weapons Ownership Claim 1. Browning 7mm-08 Bolt Action with scope, in case Larry Zimmerman 2. Browning 22-250 Bolt Action with scope, in case Larry Zimmerman 3. Remington Game Master 270 Pump with scope Larry Zimmerman for his nephew 4. Weatherby 300 Mag. Mark V, with scope Larry Zimmerman 5. Winchester Model 1100 Auto Loader Donald Vernet 6. Colt 45 Butline in Spanish Holster Larry Zimmerman 7. Winchester 1200, 12 gauge pump Larry Zimmerman 8. 32 Pistol Father of Donald Vernet '.1!_~i!tJj_ " , " ~ " - - I ~~, - " i , L , ~-;',y,- '-','..,-' 'I.'.;.. , . j,:; ~ " ~ "''':'''-''','; ,: :;A;--kt~,;~;, ~ "