HomeMy WebLinkAbout01-0304
JOY N. BEITLER,
: IN THE COURT OF COMMON PLEAS OF
PLAINTIFF
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
: NO. 2001- 30,/ CIVIL TERM
SCOTT EUGENE SMITH,
DEFENDANT
: PROTECTION FROM ABUSE
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the
case may proceed against you and a FINAL Order may be entered against you granting the relief
requested in the Petition. In particular, you may be evicted from your residence and lose other
important rights.
A HEARING ON TIDS MATTER IS SCHEDULED ON ~. .2 '" ,Dll,AJ:'
If :0 (j f .M., IN COURTROOM NO. I 0 THE CUMBERLAND
COUNTY COURTHOUSE, CARLISLE, PENNSYL VANIA.
You MUST obey the Order that is attached until it is modified' or terminated by the court
after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this
Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up
to $1,000.00 and/or up to six months injail under 23 Pa.C.S. ~6ll4. Violation may also subject you
to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18
U,S.C. ~2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories
and the Conunonwealth of Puerto Rico. If you travel outside of the state and intentionally violate
this Order, you may be subject to federal criminal proceedings under the Violence Against Women
Act, 18 U.S.C. ~ 2261-2262.
You should take this paper to your lawyer at once. You have the right to have a lawyer
represent you at the hearing. The court will not, however, appoint a lawyer for you. If you
do not have a lawyer or cannot afford one, go to or telephone the office set forth below to fmd
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 Conunon Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
acconunodations 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.
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Joy Noelle Beitler
Plaintiff
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
: No.
Scott Eugene Smith
Defendant
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: Scott Eugene Smith
Defendant's Date of Birth is: May 16, 1977
Name(s) of All protected persons, including Plaintiff and minor children:
I. Joy Noelle Beitler
AND NOW, on :r Zil, I ~ [2d7[ upon consideration of the attached Petition for
Protection from Abuse, the coiiifhereby 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 is prohibited from having ANY CONTACT with Plaintiff, or any
other person protected under this Order, at any location, including but not limited
to any contact at Plaintiff's school, business, or place of employment. Defendant
is specifically ordered to stay away from the following locations for the duration
of this order.
Plaintiff's residence located at 25 Park Street, Mount Holly Springs,
Pennsylvania.
Any place Plaintiff may be employed.
3. Defendant shall not contact Plaintiff, or any other person protected under this
Order, by telephone or by any other means, including through third persons.
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4. The following additional relief is granted:
The Cumberland County Sheriff's Department shall attempt to make service
at Plaintiff's request and without pre-payment offees, but service may be
accomjplished under any applicable Rule of Civil Procedure.
This Order shall be docketed in the office of the Prothonotary and forwarded
to the Sheriff for service. The Prothonotary shall not send a copy of this
Order to Defendant by m!lil.
This Order shall remaiJ;11ID, effect untp mo~ified or ter~ated by the Court
and can be extended beyond its original expiration date if the Court fmds
that Defendanthas co~tted an act of abuse or has engaged in a pattern or
practice that bJ.dicates risk of harm to Plaintiff.
Defendant is enjoined from damaging or destroying any property owned
jointly by the parties or owned solely by Plaintiff.
Defendant is to refrain from harassing Plaintiff's relatives.
5. A certified copy ofthis Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
Mt. Holly Springs Police Department
6. The sheriff, police or other law enforcement agencies are directed to serve the
Defendant with a copy ofthe 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.
7. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL JULY 16, 2002 OR UNTIL OTHERWISE
MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND
HEARlNG.
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. S6114. 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.
S6l13. Defendant is further notified that violation of this Order may subject hirn/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. SS2261-
2262.
NOTICE TO LAW ENFORCEMENT OFFICIALS
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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 3 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 weapon/s are evidence of a crime, in which
case, they shall remain with the law enforcement agency whose officer made the
arrest.
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Distribution to:
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PF AD Number: BBl182928N
Joy Noelle Beitler
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
Plaintiff
v.
~ No, 01- .3 D 'f Ci.vJ 1'" ~
Scott Eugene Smith
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
Defendant
PETITION FOR PROTECTION FROM ABUSE
1, Plaintiffs name is:
Joy Noelle Beitler
2, I, (the Plaintifl), am filing this Petition on behalf of:
- myself
3. Name(s) of ALL person(s), including minor children, who seek protection from abuse.
a. Joy Noelle Beitler
4, Plaintiffs Address is: 25 Park St. , Mt. Holly Springs, PA 17065
5, Defendant's Name is:
Scott Eugene Smith
6. Defendant is believed to live at the following address:
405 N. Baltimore Ave. , Mt. Holly Springs, PA 17065
7, Defendant's Date of Birth is:
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May 16, 1977
8, Defendant's Place of employment is:
unemployed
9. Defendant is an adult.
10. The relationship between the Plaintiff and the Defendant is:
Current or former sexual/intimate partner
11. The defendant has been involved in a criminal court action.
12. The defendant is not currently on probation I parole
13, The facts of the most recent incident of abuse are as follows:
On about Sunday, January 07, 2001 at approximately 12:00AM
location: The Three Pines
When PlanittTws attempting to leave, Defendant threatened that he would kill her and then kill
himself. Later, Defendant followed PlaintitTto another restaurant, and grabbed her by the hair
on the back of her head causing her head to jerk backwards. PlaintitT sutTered pain and soreness
about her neck.
14, Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor child/ren,
(including any threats, injuries, or incidents of stalking) are as follows:
In or abont August 2000, Defendant slapped PlaintitT across the face and on her leg causiug a
black and blue mark.
In or about July 2000, Defendant grabbed PlaintitT hy the throat and squeezed it causing her to
have difficulty breathing, held her by the throat and shoved her against the waD with S1lch force
that it made a dent in the wall, anell punched her about her body. Defendant punched PlaintitT,
who was pregnant, in her stomach causing her to have a miscarriage. On one other occasion in
July, Defendant grabbed Plaintiff by both of her arms, threw her onto the bed, jumped on top of
her causing Plaintiff's wrist to twist around. PlaintitT sought medical attention at the Carlisle
Hospital.
Since approximately Summer 2000, Defendant has abused PlaintitT in ways including the
following: shoved, pushed, threw her onto the ground, pulled her hair, punched, slapped, and
kicked her. On one occasion, Defendant burned PlaintitTwith a cigarette. On nnmerous
occasions, Defendant threatened to kill PlaintitT. PlaintitT has sutTered injuries including brnises,
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a twisted wrist, and two miscarriages as a result of the abuse.
15. The police department(s) or law enforcement agencies that should be provided with a copy of the
protection order are:
Mt. Holly Springs Police Department
16, There is an immediate and present danger of further abuse from the Defendant.
17. 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
FOLWWING:
a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or
minor child/ren in any place where Plaintiff may be found.
b. Prohibit Defendant from having any contact with Plaintiff and/or minor child/ren,
either in person, by telephone, or in writing, personally or through third persons,
including but not limited to any contact at Plaintifi's school, business, or place of
employment, except as the court may find necessary with respect to partial custody
and/or visitation with the minor child/ren.
c. Order Defendant to pay the costs of this action, including filing and service fees,
d. Order the following additional relief, not listed above:
Defendant shaD not damage or destroy any property owned by Plaintiff.
Defendant shall refrain from harassing Plaintiff's relatives.
Defendant shall pay 5250.00 d~Dars to one ofMIDPENN LEGAL SERVICES
funding sources as rcimburser!tenHorlitigatibn in this case.
Defend~tshall return all of P,aintiff's clothes as per arrangements made by
MIDPENN LEGAL SERVICES.
e. Grant such other relief as the court deems appropriate.
f 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.
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Respectfully submitted,
~(J-4AA-< /
o -Carey, Attorney for Pl~ff
MID-PENN LEGAL SERVICES
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
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Date:
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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. {l4904, relating
to unsworn falsification to authorities.
Dated: \ .-l \ -0\
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J elt1er , Plaintiff
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01/17/01 WED 15:49 FAX 717 240 6573
CUMB CO PROTHONOTARY
1aJ001
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[ 01] 9p2405331
[ 03]9p2438026
[ 04]92490779
CENTRAL PROCESS
LEGAL SERVICES
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OFf1CE OF '!liE PROlliOllOI'ARY
OJMBERLAND COONTy COUR'IliOOSE
ONE lXXlRTHWSE &2UAAE
CARLISLE. PA. 17013-3387
TO:
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PA STATE POLICE
(717) 240-6195
FAX (717) 240-6573
V I ATE LEe 0 PIE R
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717-249-0779
.,
~: CURTIS R. LONG
RE: PFA ORDERS
MESSAGE :
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~.~ 110. OF PAGE;S (IN'.:f..UOING OJIIER SHEET)
TItis n "']J is irltEnEd mly fur tte LOO of &e irdivid.el (J[' enti1;y fD IIIUd1 is is t.d:l. - j, .;rd I\'8'j
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distrfu.rtjrn CIL cq;yirg of this a:mnnicatim is strictly !XdrlbitH:l. U yw h3I.e J:e::eil.e:l t!us
o:nnu1ir&kn in =;r, p1.e:a= rcti.fy .... ~y by telel;h:re an reb.u:n tie adginaJ. '"ss~ In u> at
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Joy Noelle Beitler
Plaintiff
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
: No. 01-304
Scott Eugene Smith
Defendant
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
.
CONTINUED TEMPORARY ORDER
AND NOW, this 26th Day of January, 2001, pursuant to 23 Pa.C.S. ~6107(c), the
terms and conditions of the Temporary Order issued on 16th Day ofJanuary, 2001,
in the above-captioned case are hereby continued in full force and effect until
further order ofthe court.
A hearing on this matter is scheduled for the February 7, 2001, at 4:00PM in
Courtroom 1 ofthe Cumberland County Courthouse, One Courthouse Square,
Carlisle.
BY THE COURT:
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JOYN. BEITLER,
: IN THE COURT OF COMMON PLEAS OF
PLAINTIFF
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
: NO. 2001-304 CIVIL TERM
SCOTT EUGENE SMITH,
DEFENDANT
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
The Plaintiff, Joy Beitler, by and through her attomey, Joan Carey of Legal Services, Inc.,
moves the Court for an Order continuing generally/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 16,
2001, scheduling a hearing for January 26,2001, at 4:00 p.m.
2. The Cumberland County Sheriffs Department served Defendant has been unable to
effect service on the defendant.
3. The Plaintiff requests that the Temporary Protection From Abuse Order remain in
effect for a period of eighteen months from the date it was entered or until further Order of Court,
whichever comes first.
WHEREFORE, the Plaintiff requests that the Court grant this Motion reschedule this matter
for hearing, and that the Temporary Protection From Abuse Order remain in effect for a period of
eighteen months from the date it was entered or until further Order of Court, whichever comes first.
Respectfully submitted,
oan Carey, Attome)\ or Plaintiff
MIDPENN LEGAL SERVICES
8 Irvine Row
Carlisle, PA 17013
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-00304 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
BEITLER JOY N
VS
SMITH SCOTT EUGENE
RICHARD SMITH
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE
was served upon
SMITH SCOTT EUGENE
the
DEFENDANT
, at 0014:03 HOURS, on the 29th day of January ,2001
at 46 W NORTH ST
CARLISLE, PA 17013
by handing to
SCOTT SMITH
a true and attested copy of PROTECTION FROM ABUSE
together with
NOTICE OF HEARING & ORDER, TEMPORARY PROTECTION
FROM ABUSE ORDER, PETITION, CONTINUANCE
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
3.10
.00
10.00
.00
31. 10
So Answers:
~~"'i't:~l
R. Thomas Kline
01/30/2001
Sworn and Subscribed to before By:
me this J,QJ/-
day of
.1~ ~I A.D.
Cf--r". (;tn"I!i;,~~
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Joy Noelle Beitler,
Plaintiff
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
Scott Eugene Smith,
Defendant
.
.
: No. 01-304
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
.
.
FINAL ORDER OF COURT
Defendant's Name is: Scott Eugene Smith
Defendant's Date of Birth is: May 16, 1977
Name(s) of All protected persons, including Plaintiff and minor children:
1. Joy Noelle Beitler
AND NOW, this 7th Day of February, 2001 the court having jurisdiction over
the parties and the subject-matter, it is ORDERED, ADJUDGED and
DECREED as follows:
Pursuant to consent ofthe parties, which does not constitute Defendant's
admission to the averments of abuse in the petition. The following order will be
entered:
Plaintiffs request for a fmal protection order is granted.
1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other
protected person in any place where they might be found.
2. Defendant is prohibited from having ANY CONTACT with the Plaintiff, or
any other person protected under this Order, at any location, including but not
limited to any contact at Plaintiffs school, business, or place of employement.
Defendant is specifically ordered to stay away from the following locations
for the duration of this order.
Plaintiffs residence located at 80 E. Main Street, Newville, Pennsylvania,
or any other residence Plaintiff may establish in the future.
Any place Plaintiff may be employed.
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3. Defendant shall not contact the Plaintiff, or any other person protected under
this Order, by telephone or by any other means, including through third
persons.
4. The following additional relief is granted as authorized by ~61 08 of the Act:
Defendant is enjoined from damaging or destroying any property owned
jointly by the parties or owned solely by Plaintiff.
Defendant is to refrain from harassing Plaintiff's relatives.
Defendant shall return any and all personal property including clothing
and legal documents belonging to Plaintiff by bringing the property to
MidPenn Legal Services within two weeks ofthe entry ofthis order.
5. A certified copy of this Order shall be provided to the police department
where Plaintiff resides and any other agency specified hereafter:
Newville Police and Pennsylvania State Police Departments
6. THIS ORDER SUPERSEDES:
1. ANY PRIOR PFA ORDER
7. All provisions of this order shall expire on: August 7, 2002
NOTICE TO THE DEFENDANT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE
CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS
PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE
OF UP TO SIX MONTHS. 23 PA.C.S. 96114. VIOLATION MAY ALSO
SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES
UNDER THE PENNSYLVANIA CRIMES CODE.
THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE
DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND
THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE
AGAINST WOMEN ACT, 18 U.S.C. ~2265. IF YOU TRAVEL OUTSIDE OF
THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY
BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT
ACT. 18 U.S.C SS2261-2262.IF THE BRADY INDICATOR PARAGRAPH
APPEARS IN THE ORDER, YOU MAYBE SUBJECT TO FEDERAL
PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS
OF THE GUN CONTROL ACT, 18 U.S.C. S922(G), FOR POSSESSION,
TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
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The police who have jurisdiction over the plaintiff's residence OR any location
where a violation of this order occurs OR where the defendant may be located,
shall enforce this order. An arrest for violation of Paragraphs 1 through 3 of this
order may be without warrant, based soley on probable cause, whether or not
the violation is committed in the presence of the police. 23 Pa.C.S. g6113.
Subsequent to arrest, the police officer shall seize all weapons used or
threatened to be used during the violation of the protection order or during prior
incidents of abuse. The shall maintain possession of the weapons until further
order ofthis Court.
When the defendant is placed under arrest for violation of this order, the
defendant shall be taken to the appropriate authority or authorities before whom
defendant is to be arraigned. A "Complaint for Indirect Criminal Contempt"
shall then be completed and signed by the police officer OR the plaintiff.
Plaintiff's presence and signature are not required to file the complaint.
If sufficient grounds for violation of this order are alleged, the defendant shall
be arraigned, bond set and both parties given notice ofthe date of the hearing.
. ,
,t t~ the ~nsent OfPlain~ff~2;t~;~
amtJ s SIgnature e en ant's Ignature
Distribution to:
MidPenn Legal Services - ~ ~
Faxed & Mailed to PSP ~ " . .
Scott Smith - ~~
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02/08/01 THU 11:11 FAX 717 240 6573
CUMB CO PROTHONOTARY
I4i 001
***************************
*** IlIULTI TN REPORT *"*
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TX/RX NO
INCOMPLETE TX/RX
TRANSACTION OK
2445
[ 01] 9p2405331
[ 03]9p2438026
[ 04] 92490779
CENTRAL PROCESS
LEGAL SERVICES
PSP
ERROR
.
OFFICE OF 'I1iE PROI'HQ\ICJI'ARY
CUMBERLAND COONTY OOUR'IHCXJSE
ONE CWRTHCXJSE 9,JUARE
~LISLE, PA. 17013-3387
(717) 240-6195
FAX (717) 240-6573
TO;
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PA STATE POLICE
VIA TELECOPIER
f'AX ":
717-249-0779
f'RCM :
CURTlS fl. LONG
RE:
l'FA ORDERS
MESSAGE :
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