HomeMy WebLinkAbout01-2829 FX
JENNIFER AUNGST,
Plaintiff
V.
KENNETH WILSON AUNOST,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
01-2829 CIVIL
CHAROE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this 0~ day Of~OI, this Court certifies that the
attached complaints have been properly completed and verified,. and there is probable
cause for the issuance of process. In consideration of the attached Commonwealth' s
Petition, the defendant, KENNETH WILSON AUNGST, is directed to appear for trial on
the charge of Indirect Criminal Contempt before the Court on the d 1"'^ day of
~wbeP- ,2001 at 3'.00 o'c1ockL.m. in Courtroom # :;L of the Cumberland
County Courthouse, Carlisle, Pennsylvania.
The defendant has a right to be represented by an attorney. If the defendant
cannot afford an attorney, upon request one will be assigned to represent the defendant.
If the defendant wishes assignment of counsel, contact should be made prior to trial with
the Cumberland County Public Defender's Office at 717-240-6285. Further, ifthe
defendant fails to appear, an arrest warrant will be issued.
The Sheriff of Cumberland County is directed to serve this Order and Petition
upon the defendant. The assessment of costs to be determined by the Trial Judge
subsequent to trial.
Jonathan R. Birbeck,
Chief Deputy District Attorney
KENNETH WILSON AUNGST
~~~"'".
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By the Court,
f ni1JE ()DFY f:~iOM Fii:COHO
I rl TestlmG'lty wt1{j,Of\f. I tliJflJ 1$!1W iJl!l'lI1Yy haillJ
:nd tha ~al of said eooz Carllsto. PiA.
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I ~onotary
JENNIFER AUNGST,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: 01-2829 CIVIL TERM
KENNETH WILSON AUNODST,
Defendant
CHAROE: INDIRECT CRIMINAL CONTEMPT
COMMONWEALTH'S PETITION FOR A HEARING ON CHARGES
OF INDIRECT CRIMINAL CONTEMPT
Jonathan R. Birbeck, Chief Deputy District Attorney of Cumberland County,
Pennsylvania, brings the following Petition for a hearing on charges of Indirect Criminal
Contempt:
I. A Protection from Abuse Order was issued by the Court. A true and correct
copy of the Order is attached.
2. The defendant's violation of this Order is averred in the attached criminal
complaint.
3. The victim requests the filing of an Indirect Criminal Contempt Charge.
4. The District Attorney's Office approves the filing of this criminal complaint.
5. The Commonwealth is requesting a hearing on the charges of Indirect
Criminal Contempt pursuant to 23 Pa.C.S.A. ~ 6113.
6. The plaintiff and/or the defendant may seek modification of the Order based
on the filing ofthis petition as the Court deems appropriate following the trial
in addition to any other sentence. 23 Pa.C.S.A. !i 6113.
WHEREFORE, the Commonwealth requests the defendant be commanded to
appear before the Court on the charge of Indirect Criminal Contempt.
~}~
Sep 05 01 O!: 58p
Chief' of' Police
761-0753
F.2
COMMONWEALTH OF PENNSYLVANIA
COUNT Y OF: CIlMRF.RT JlNn
r~l9j5Ieri!lICiSlnct Nu:nber. 09-3-04
I DistricUUlItiei:l NaIM: HCf1. Th E: PI
.amas . acey
......., 104 s. Sporting Hill Road
Mechanicsburg, Pa. 17050
T.,.pho"., (717) 761-8230
..
POLICE
CRIMINAL COMPLAINT
COMMONWEALTH OF PENNSYLVANIA
Y5.
Docket No.:
_-.J
I
DEFENDANT:
I
NAME aM ADDRESS
!
AUNGST, Kenneth Wilson Jr.
4411 PACKARD LANE
CA'lP HILL, PA. 170lJ.
Date Filed:
L
OTN:
Defendant", RaGefEthr.icilY Ce!eoda"lt'eStur; Def~t'5D.O.B. DBfalKkrt's Social SllCurity NlI'Ilber Oelenda'll'llSID{S1ate~erofIcaIionNl.dIber) I
,
~ White o Black o Female 4-15-57 187-48-3661 I
Asian Q ).i.eAmerican li\;M'~ i
CJ Hispark 0 Unknown
OefendMl'sAK.A. (also\rllOlfnasl Defendant's I/dIide lnlOm'l8liM OefendWl\'s ()~..r6l..1clmse N\r.lbA'"
PlateNu'nber I Slate RegislralbnStic:&<<tMMf'r'Y} .~~ I
KEN I PA 17-903-042
ComplainlilnciCleroNl.mber CompItinv'ln<;idcII. Nl.mber if ether Partocipam. UCRlNI8RSCode-
I
i
District Attorney's Office 0 Approved 0 Disapproved because:
(fhe district atlcrney may require that lh& complaint, arrest warrant affidavit, or boh be llPProve<t Dy tf1e atlofMY for the Commonwealth prior ICI filing. P,ACe.P. 107.)
(Name aI Attorney 19r CllmmOl'll'l'elllf'l-.Pleah Print orType)
I, Cpl. Dennis C. Lundauist
{NaFM 0( AAiant-Please Prlnl Of l\'PGl
of
(S~NiItlnafA~ftx~eallt1)
to*1
F\~<1\1P *lq-7
(0fflc.6( B&dga NlmMr1I.G.1
Hanplen 1:'WP. Pol;,..", Il<>~t
(ldenlifY()eperlrnentorAgI!ll1tyR8pfesen1edend aliticaiSIJb<ftv'l$(oo)
~b.1"l?1 n<!1nn
tp ice~et'f::ltlI'ORINumbetl
200J-OR-441
(OdginetingAg~ Ca.. t-kmt.er(OCAI)
do hereby state: (check appropriate box)
1. &J I accuse the above named defendant 000 lives at the address set forth above
o I accuse the defendant whose name is unknown to me but who is described as
D I accuse. the defendant whose name and popular designation or nickname is unknown to me and whom I
have therefore designated as John Doe
with violating the penal laws of the Commonwealth of Pennsylvania at ~~~t:r.tLJ ..no> CRmp Hi 1 1. p~ 1 7011
llaJmden '1'cwnship
in ~JIT\hPr1Ann County on or about 4:30PM Sunday AUQUst 12, 2001
Participants were: (if there were participants, place their names here, repeating the name of the above defendant)
Kenneth Wilson A\lngst
AOPC 412A- 111241199
1-2
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Chief' of' ~ali~cE!
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{Continuation of No.2)
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Defendant's Name: ^,nV' .
nl../J.'fJST,
Docket Number;
Kenneth Wilson
1-*.
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POLICE
CRIMINAL COMPLAINT
2.
The acts committed by the accused OOfe: INDIRECT CRIMINAL CONl'l'MPT .
(Sel fol1h 8 summary of the facts sufficient to acMse the defendant of tne niltule of the offense dlarged. A ef.alion 10 the staRJ.e allegedly vbIated. WIthout marl:',
is not $uffiaent. In a summary case, you must Cite Vie speclftcsectlon and subsectioo of the etflMe Of ordinanea alleQed!y lliolated.)
The defendant violated the Protection Fran Abuse Order 01-2829 Civil 2001 issued
on 23 July 2001 by the Honorable Judge Edgar B. Bayley. The defendant did threaten
the victim, Jennifer S. Aungst, by lunging at her, yelling at her and pounding on
the windows of her vehicle while she was inside the vehicle. The victim in fear
for her safety left the area and made alternate arraignments for housing as she
feared the defendant may cane to her primary residence.
all of which were against the peace and dignity of the Commonwealth of Pennsylvania and cortrary to the Ad of
Assembly, or in violation of
1. 6114 of the 21 Pa.C S 1
R
,-, ,-, (PA StAde) ,......,
2. ofthe
IS""""'! (Stlbsectlon) (pASIftJleJ ''''''''''
3. of the
(SIJdioo) -, (PAStaWIeo) (......,
-. of the
(s.aion) 1_' (pAStaWtl) ,......,
3. I ask that a warrant of arrest or a summons be Issued and that the <'efendant be required toanswerlhe charges I
have made. (In order for a warrant of arrest to issue, 1I1e attach Nt affidavit of probable cause must be
completed and swom to before the Issuing authority.)
4. I verify that the facts set forth in this complalnt are !rue and correct 10 the best of my knovdedge or information and
belief. This verification is made subject to the penalties of Section '\904 of the Crimes Code (18 PAC.S.!j4904)
rel~t1ng to unsworn faJSir~t1on toauthorities.01. \/J?~,
(Dale) (Signa'.. or A
AND NOW, on this date, , I certify that the complaint has been proper!
affidavit of probable cause must be completed in order for a warrant to Issu',.
(Maljtlerta, 0Is1ridj
(/s$lIfI\gAutharifyJ
SEAL
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COMMONWEAL ni OF P.ENNSYL VANIA
COUNTY OF CUMBERLAND
09201
SUMMONS
CRIMINAL COMPLAINT AND
PROBABLE CAUSE AFFIDAVIT
Mag. Disl. NCI.:
Address:
1 COURTHOUSE SQ
CARLISLE PA 17013
717 240 6564
DEFENDANT:
COMMONWEALTH OF
PENNSYLVANIA
VS.
OJ Name; Hon.
PAULA P CORREAL
Telephone:
NAME and ADDRESS
KENNETH WILSON AUNGST
4411 PACKERD LN
CAMP HILL PA 17011 0000 00
AKA:
KENNETH AUNGST
Docket No.:
Date Filed:
OTN:
.
Reg[s(ratlon Number
Annual Sticker Number
OLN Number
PA17903042
SID Number
Comp Int Number
Complaint Numbers If other Participants
R.8.A.:
ORINO.:
District Attorney's Office _ Approved -Disapproved because:
(The District Attomey mey require that the complain~ arrest warrant affidavit, or both be approved by the attomey lor the Commonwealth prior to filing.
Pa.R.Cr.P.107.) When the affiant Is not a police officer as defined in Rule 51(C) and the offense(s) charged Include(s) a misdemeanor or lelony which
does not Involve a clear and present danger to any person or the community, the complaint shail be submitted to the allomey lor the Commonwealth, who
shail approve or disapprove without unreasonable delay).
WM 44
D.0.8.: 04 15
I 2001~~'B18'!f~~ CAR
1957 8.8.#: 187
UCA Number
1642
48 3661
PA0210200
(Issue Date)
(Signature)
I (N ofA"~nl) PO DAVID H TILDEN BADGE 11
of am. CARLISLE PD
residing at 53 WEST SOUTH ST CARLISLE PA 17013
do hereby state: (check appropriate area)
1. J I accuse the above named defendant. who lives at the address set forth above or,
_ I accuse an individual whose name is unknown to me but who is described as
- I accuse the defendant whose name and popular designation or nickname is unknown to me and whom I
have therefore designated as John Doe
with vlolatina the~enallaws of the Commonwealth of Pennsylvania at: CARLISLE
561 SUMMIT DR CARLISLE (P~""Polhlcalsubdivl.~n)
in (County) CUMBERLAND on or about 08 23 2001 0458 HRS
Participants were: (il there were participants place their names here, repeating name 01 above defendant)
2. The acts committed by the accused were:
(Set lorth a summary 01 the lacts sufficient to advise the defendant 01 the nature 01 the offense charged. Neither the evidence nor the statute
allegedly violated need be cited, nor shail a citation 01 the statute ailegedly violated, by Itself, be sufficient. In a summary case, set lorth a
cltallon of the specific section and sub-section of the statute or ordinance allegedly violated).
** INDIRECT CRIMINAL CONTEMPT - ADULT
CTS
1
THE ACTOR DID VIOLATE THE PROTECTION FROM ABUSE ORDER
NUMBER 01-2829 CIVIL ACTION-LAW
THE ORDER WAS SIGNED BY THE HONORABLE JUDGE BAYLEY
THE ORDER WAS DATED 7/23/2001
Copy: District Justice
Defendant
Return of Service
Police
4197wp
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Page 2
,
*'
CRIMINAL COMPLAINT AND
PROBABLE CAUSE AFFIDAVIT
N KENNETH WILSON AUNGST
Defendant ame:
Docket Number:
THE ACTOR VIOLATED THE ORDER BY
CALLING HIS SEPARATED WIFE WHO HAS THE PFA, JENNIFER
AUNGST, ON THE PHONE WHICH WAS ANSWERED BY HER ANSWERING MACHINE
AND LEFT A MESSAGE INDICATING THAT HER EMPLOYERS MIGHT LIKE TO
RECIEVE LETTERS LETTING THEM KNOW SHE IS AN ADULTERESS, ETC.
THIS PFA PROHIBITS PHONE CALLS TO JENNIFER. THIS ACT
ALLEGEDLY OCCURED ON 8/11/01
ALL OF WHICH WERE AGAINST THE PEACE AND DIGNITY OF THE COMMONWEALTH OF
PENNSYLVANIA AND CONTRARY TO THE ACT OF ASSEMBLY,
OR IN VIOLATION OF 6114 A1 OF THE ACT OF 23
OR THE ORDINANCE OF
3. I ask that a warrant of arrest or a summons be issued and that the accused be required to answer the charges
I have made. (In order for a warrant of arrest to issue, the attached affidavit of probable cause must be
completed and sworn to before the issuing authority.)
4. I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information
and belief. I certify the complaint has been properly completed and verified, and that there is probable cause
for the issuance of process. This verification is made subject to the penalti of Section 4904 of the Crimes
Code (18 PA. C.S. 4904) relating to unsworn falsification Mtho" .
Date: <oj;!"'!f Or v/ t ' #-1 ( Cf)J ~Ji5~'
(Slgnatur. of Complainant)
AND NOW, on this date, I certify the complaint has been properly completed and
verified, and that there is probable cause for issuance of process.
(Magisterial UlstrlCtl
(ISSUIng AUlhority)
(SEAL)
'-WiJ.~-""f". <~ "~_.
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V~:- TOO
CARLISLE PD. .
PROBABLE CAUSE AFFIDAVIT
INCIDENT NUMBER: 20010800952 CAR
DATE: 08/23/2001
OTN:
PG 1
CHARGE (S) :
23 6114
Al
INDIRECT CRIMINAL CONTEMPT - ADULT
#CTS
1
COMMONWEALTH VS KENNETH
WILSON
AUNGST
INFORMATION:
JENNIFER AUNGST TESTIFIED IN A SUMMARY CASE AGAINST HER HUSBAND
ON 8/9/2001 FOR. SHE HAS A PROTECTION FROM ABUSE ORDER WHICH
PROHIBITS HIM FROM HAVING ANY CONTACT WITH HER ANYWHERE, EXCEPT
WHEN EXCHANGING CHILDREN. (PARAGRAPH 2)
PARA 3 STATES, "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."
THIS ORDER WAS ISSUED BY THE COURT OF COMMON PLEAS IN CUMBERLAND
COUNTY ON JULY 23, 2001.
IT IS TILTLED CASE NO 01-2829, CIVIL ACTION-LAW
PROTECTION FROM ABUSE.
.
IT SHALL EXPIRE DECEMBER 5,2002.
IT WAS SIGNED BY JUDGE BAYLEY.
JENNIFER STATES THAT ON AUGUST 11, 2001, SHE RECEIVED A TELE-
PHONE CALL FROM HER HUSBAND ON HER RECORDER AND HE STATED THE
FOLLOWING:
" HELLO? CAN YOU PICK UP THE PHONE? I KNOW YOU'RE THERE BECAUSE
IT'S BEEN BUSY FOR THE LAST 5 OR 10 MINUTES. HELLO? ALL RIGHT.
WELL, IF THAT'S THE WAY YOU WANT TO DO IT, THAT I S FINE. I HOPE
YOU AND DAVE HAD A GOOD TIME LAST NIGHT. IT PROBABLY WAS A GOOD
MOVIE YOU WATCHED. I THINK THAT AFTER HAVING YOU TESTIFY
AGAINST ME, YOU AND YOUR BOYFRIEND ON WEDNESDAY, I THINK MRS.
MCCULLOUGH (VICTIMS PRESCHOOL SUPERVISOR), THE PASTOR, AND THE
PRINCIPAL AT MOORELAND WOULD PROBABLY APPRECIATE. A LETTER KNOW-
ING ABOUT WHAT I S GOING ON. THEY PROBABLY WOULD APPRECIATE
HAVING AN ADULTERESS WORKING FOR THEM. ALL RIGHT-SEE YOU LATER"
THIS STATEMENT AND A COPY OF THE PFA WERE FORWARDED TO DISTRICT
ATTOURNEY SIBERT WHO ADVISED TO FILE AN INDIRECT CRIMINAL CON-
TEMPT.
',',] " "-"""~~ "~..
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. .
Jennifer Aungst
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
Plaintiff
v.
.
: No. 01-2829
Kenneth Wilson Aungst
Defendant
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
FINAL ORDER OF COURT
Defendant's Name is: Kenneth Wilson Aungst
Defendant's Date of Birth is: April 15, 1957
Defendant's Social Security Number is: 187-48-3661
Name(s) of All protected persons, including Plaintiff and minor
children:
1. Jennifer Aungst
AND NOW, this dJ,o d. .
the parties and the subject-
DECREED as follows:
';>001
the c6urt having jurisdiction over
er, it is ORDERED, ADJUDOED and
Upon agreement of the parties for the entry of a consent order, this
order will be entered without any admission of liability by the
defendant and without a finding of abuse by this court:
Plaintiffs request for a final protection order is granted.
1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or
any other protected person in any place where they might be
found.
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2. Defendant is prohibited from having ANY CONTACT with the
Plaintiff, or any other person protected under this Order, at any
location, including but not limited to any contact at Plaintiff's
school, business, or place of employement. Defendant is
specifically ordered to stay away from the following locations for
the duration ofthis order.
Plaintiffs residence at 561 Summit Drive, Carlisle,
Pennsylvania.
Plaintiffs employment located at Grace United Methodist
Church, 41 South West Street, Carlisle. Pennsylvania.
Any non-harassing contact by Defendant with Plaintiff which
may occur during custody exchange ofthe minor children
infront of the residence located at 561 Summit Drive, Carlisle,
Peimsylvania, or during functions at the minor children's
school, shall not be deemed a violation of this Order.
Defendant shall remain in the vehicle during custody
exchanges for the duration of this Order.
3. Defendant shall not contact the Plaintiff, or any other person
protected under this Order, by telephone or by any other means,
including through third persons.
4. The following additional relief is granted as authorized by ~6l 08
ofthe Act:
-This Order shall remain in effect until modified or
terminated by the Court and can be extended beyond its
original expiration date if the Court fmds that Defendant has
committed an act of abuse or has engaged in a pattern or
practice that indicates risk of harm to Plaintiff.
- Defendant shall not damage or destroy any property owned
jointly by the parties or solely by Plaintiff.
- Defendant shall refrain from harassing Plaintiffs relatives.
- Any non-threatening, non-harassing phone calls to Plaintiff
in regards to the parties' children shall not be deemed a
violation of this Order.
- The court costs and fees are waived.
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5. A certified copy of this Order shall be provided to the police
department where PlaintitTresides and any other agency specified
hereafter:
Carlisle Police Department
6. THIS ORDER SUPERSEDES:
I. ANY PRIOR PF A ORDER
7. All provisions of this order shall expire on: December 5, 2002
NOTICE TO THE DEFENDANT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR
ARREST ON THE CHAROE 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. ~6Il4. VIOLATION MAy ALSO SUBJECT YOU TO
PROSECUTION AND CRIMINAL PENALTIES UNDER THE
PENNSYL VANIA CRIMES CODE.
THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES,
THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S.
TERRITORIES AND THE COMMONWEALTH OF PUERTO
RICO UNDER THE VIOLENCE AOAINST WOMEN ACT, 18
U.S.C. ~226S. IF YOU TRAVEL OUTSIDE OF THE STATE AND
INTENTIONALLY VIOLATE THIS ORDER, YOU MAYBE
SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER
THAT ACT. 18 U.S.C ~~226l-2262. IF THE BRADY INDICATOR
P ARAORAPH APPEARS IN THE ORDER, YOU MAY BE
SUBJECT TO FEDERAL PROSECUTION AND PENALTIES
UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL
ACT, 18 U.S.C. ~922(0), FOR POSSESSION, TRANSPORT OR
RECEIPT OF FIREARMS OR AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
,jJttM~ i tfl;HHtwilHallhiUlilHh#ig~; .HMif.d~tlHhLIuH~;cLuL
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The police who have jurisdiction over the plaintiffs residence OR
any location where a violation of this order occurs OR where the
defendant may be located, shall enforce this order. An arrest for
violation of Paragraphs I through 3 of this order may be without
warrant, based soley on probable cause, whether or not the violation
is committed in the presence of the police. 23 Pa.C.S. 96113.
Subsequent to arrest, the police officer shall seize all weapons used
or threatened to be used during the violation of the protection order
or during prior incidents of abuse. The Cumberland County Sheriff
shall maintain possession of the weapons until further order of this
Court.
When the defendant is placed under arrest for violation of this order,
the defendant shall be taken to the appropriate authority or authorities
before whom defendant is to be arraigned. A "Complaint for Indirect
Criminal Contempt" shall then be completed and signed by the police
officer OR the plaintiff. Plaintiffs 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 noti e
of the date of the hearing.
BYTHECU :
~ -~ B B,y1'i~__
. ..~~'..l)ate '
oan Carey
Attornl-lY for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, P A 17013
Edward eintra
Attorney for Defendant
Law Office of Edward Weintraub and Associates
2650 North Third Street
Harrisburg, P A 17110
Distribution to:
-Legal Services ~~. 7. J-4. 61
-Faxed and Mailed to PSP 1.J.Lj. () I ~ I(J. 4\
-Edward Weintraub, Attorney..
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CERl'IFICATIOO OF PFA CCNI'fMPT
CASE rDIBER 0/- ;zr~q
NAME K C/flJll.!..fCt. IAlit"'i>dYL .Al.L~5f
iff II P ~Cl\~V7J LiL/A.2
C-.~ [l PA /10/ J
BALANCE DUE: $ II f.r, ~ ()
VICTIM'S NAME:
J~ tLVt~-k( ;k05 f
170
171
260
207
204
502
STATE SURCHARGE
STATE FINE
SHERIFF COST <$1.50 + ADDTL)
DISTRICT ATTORNEY
COURT COSTS (CLERK OF COURTS)
RESTITU1fON
NAME-.J rothonot-a.-ry
ADD DELETE
$ $
$ 3 <6, 3' J- $
$ $
$ 15.00 $
$ 15.00 $
$ 45'.00 $
ADDRESS
CITY
STATE
ZIP
NAME
$
$
ADDRESS
CITY
STATE
ZIP
NAME
$
$
ADDRESS
CITY
STATE
ZIP
, J~
PROTHONOTARY OFFICE d 7.
PERSON CERTIFYING INFORMATION {~. ~ l~ ~
DAT IO~(-()(~-V U
'''."'-'''''''':- , -.,
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JENNIFER AUNGST,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
: NO. 2001- (J/ -.2S'29cIVIL TERM
KENNETH AUNGST,
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. .c;r\l~
A HEARING ON THIS MATTER IS SCHEDULED ON ~ l g ,DlI,AT
~ "l.::>' ,:L. .M., IN COURTROOM NO.:f\ OF THE . MBERLAND
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 contelIlpt which is punishable by a fme of up
to $1,000.00 and/or up to six months in jail under 23 Pa.C.S. g6114. Violation may also subject you
to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18
U.S.C. g2265, 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 tmder the Violence Against Women
Act, 18 U.S.C. 9 2261-2262.
You should take this paper to your lawyer at once. You have the right to have a lawyer
represent you at the hearing. The court will not, however, appoint a lawyer for you. If you
do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find
out where you can get legal help. If you cannot fmd 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. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact
our office. All arrangements must be made at least 72 hours prior to any hearing or business before
the court. You must attend the scheduled conference or hearing.
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Jennifer Aungst
Plaintiff
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYL VANIA
v.
: No. Of. ;;.?;;U; &;r<J T..u---
Kenneth Wilson Aungst
Defendant
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: Kenneth Wilson Aungst
Defendant's Date of Birth is: April 15, 1957
Defendant's Social Security Number is: 187-48-3661
Name(s) of All protected persons, including Plaintiff and minor children:
1. Jennifer Aungst
AND NOW, on"~ 10 cloolupon consideration of the attached Petition for
Protection from Abus ,the bourt hereby enters the following Temporary Order:
Plaintiffs 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.
Plaintiffs residence at 561 Summit Drive, Carlisle, Pennsylvania.
Plaintiff's employment located at Grace United Methodist Church, 41 South
West Street, Carlisle, Pennsylvania.
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3. Defendant shall not contact Plaintiff, or any other person protected under this
Order, by telephone or by any other means, including through third persons.
4. The following additional relief is granted:
- This Order shall remain in effect until modified or terminated by the Court
and can be extended beyond its original expiration date if the Court fmds
that Defendant has committed an act of abuse or has engaged in a pattern or
practice that indicates risk of harm to Plaintiff.
- Defendant shall not damage or destroy any property oWllled jointly by the
parties or solely by Plaintiff.
- Defendant shall refrain from harassing Plaintiff's relatives.
- Any non-threatening, non-harassing phone calls to Plaintiff in regards to
the parties children shall not be deemed a violation of this Order.
- Defendant shall remain in his vehicle during periods of custody exchange.
5. A certified copy ofthis Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
Carlisle Police Department
6. 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.
7. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL NOVEMBER 4, 2002 OR UNTIL OTHERWISE
MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND
HEARINO.
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 rnonths in jail. 23 Pa.C.S. ~6Il4. 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. S~2261-
2262.
NOTICE TO LAW ENFORCEMENT OFFICIALS
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This Order shan 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 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 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 weapon/s are evidence of a crirne, in which
case, they shall remain with the law enforcement agency whose officer made the
arrest.
BYT
Ju ge
_1....10'
__~_~c___~~_ Date
Distribution to:
Legal Services
Faxed & Mailed to PSP
Cumberland County Sheriff
-""""""""~
PFAD Number: XNl243l46E
Jennifer Aungst
Plaintiff
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
:No.&I- ~'Y.29 CWJ -r~
Kenneth Wilson Aungst
Defendant
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
PETITION FOR PROTECTION FROM ABUSE
I. Plaintiff's name is:
Jennifer Aungst
2. I, (the Plaintiff), am filing this Petition on behalf of:
- myself
3. Name(s) of ALL person(s), including minor children, who seek protection from abuse.
a. Jennifer Aungst
4. Plaintiff's Address is : 561 Summit Drive, Carlisle, P A 17013
5. Defendant's Name is:
Kenneth Wilson Aungst
6. Defendant is believed to live at the following address:
4411 Packard Lane, Camp Hill, P A 17011
7. Defendant's Social Security Number is:
187-48-3661
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8. Defendant's Date of Birth is:
April 15, 1957
9. Defendant's Place of employment is:
Comcast, 1500 Market Street, Harrisburg, Pennsylvania
10. Defendant is an adult.
11. The relationship between the Plaintiff and the Defendant is:
Spouse
12. The defendant has been involved in a criminal court action.
13. The facts of the most recent incident of abuse are as follows:
On or about April 23, 2001, Defendant stood outside Plaintiffs window and
watched Plaintiff who was inside the house. Defendant entered the residence,
pointed at Plaintiff and a male friend, and threatened, "Y our're dead!" Defendant
ran toward Plaintiff and her male friend and threatened, "I'm going to f***** kill
you!" Plaintiff ran to the kitchen and grabbed the phone to call the police. When
Plaintiff returned to the living room, Defendant again went after Plaintiff causing
her to fear for her safety. Defendant Oed the residence. The police cited Defendant
for harassment.
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 about mid-January 2001, Defendant called Plaintiff who reiterated that she
did not want him to call her anymore, and she hung up the phone. Later,
Defendant came to the residence, rang the doorbell, and walked around the
outside of the house banging on the doors and windows. Fearing for her safety,
Plaintiff threatened to call the police and Defendant left. During a separate
incident in January 2001, Defendant called Plaintiff and threatened that if he ever
saw her with another man, that he would kill them both.
From in or about the month of October 2000 until January 2001, despite
Plaintiff's frequent requests that Defendant stop calling her, Defendant called
Plaintiff on the phone several times a week harassing her. When Plaintiff hung up
the phone, Defendant called her back and let it ring until she answered.
15. The police department(s) or law enforcement agencies that should be provided with a
copy of the protection order are:
Carlisle Police Department
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16. There is an immediate and present danger of further abuse from the Detendant.
17. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT
ENTER A TltMPORARY ORDER, and AFTER HEARING, A FINAL ORDER
THAT WOULD DO THE FOLLOWING:
a. Restrain Defendant from abusing, threatening, harassing, or stalking
Plaintiff and/or minor child/ren in any place where Plaintiff may be
found.
b. Prohibit Defendant from having any contact with Plaintiff and/or
minor childlren, either in person, by telephone, or in writing,
personally or through third persons, including but not limited to any
contact at Plaintiff's school, business, or place of employment,
except as the court may fmd 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 shall not damage or destroy any property owned
jointly by the parties or solely by Plaintiff.
Defendant shall refrain from harassing Plaintiffs relatives.
Defendant sb,all pay $250.00 to one MidPenn's funding sources
as reimbursement for litigation in this case.
Any non-threatening, non-harassing phone calls to Plaintiff in
regards to the parties childreu shall not be deemed a violation of
this Order.
Defendant shall remain in his vehicle during periods of custody
exchange.
e. Orant such other relief as the court deems appropriate.
f. Order the police or other law enforcement agency to serve the
Defendant with a copy of this Petition, any Order issued, and the
Order for Hearing. The petitioner will inform the designated
authority of any addresses, other than the Defendant's residence,
where Defendant can be served.
Respectfully Subrnitted by:
I oan arey, Attorney
Agency: MidPenn Legal Service
8 Irvine Row
Carlisle, PA 17013
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VERIFICATION
I verify that I am the Petitioner as designated in the present action and that the facts and
statements contained in the above Petition are true and correct to the best of my knowledge. I
understand that any false statements are made subject to the penalties of 18 Pa.C.S. ~4904, relating
to unsworn falsification to authorities.
Dated: tn11 ;IDOl
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05/10/01 THU 13:45 FAX 717 240 6573 .
, CUMB CO PROTHONOTARY
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***************************
*** MULTI TN REPORT ***
***************************
TX/RX NO
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2606
[ 01l9p2405331
[ 03]9p2438026
[ 04192490779
CENTRAL PROCESS
LEGAL SERVI CES
PSP
ERROR
.
,
OFFICE Of '!lIE PROl'HCN::rl'AAY
a.JMBERLAND CXXJNIY COURniOOSE
ONE COORTHaJSE 9:)UARE
CARLISLE. PA. 17013-3387
(717) 240-6195
FAX (717) 240-6573
V I ATE LEe 0 PIE R
TO:
PA STATE POLICE - Ce.,l. I'IlDc,e$t:.. M. (J. J..S.
FAX ":
717-249-0779
FRQ.l :
CURTIS R. LONG
RE:
PFA ORDERS
MESSAGE :
~ N::l. OF PAGES (INCLUDING COVER SHEET)
This - ,,' is il,teubJ cnly fur tiE lBe d'. the irdiv:id.eJ. IX" EIlt:i.W In Wlich is is nI1. i, <I'd IIH'f
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SHERIFF'S RETURN - REGULAR
,
CASE NO: 2001-02829 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
AUNGST JENNIFER
VS
AUNGST KENNETH
JASON VIORAL
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE
was served upon
AUNGST KENNETH
the
DEFENDANT
, at 0019:55 HOURS, on the lOth day of May
, 2001
at 4411 PACKWARD LANE
CAMP HILL, PA 17011
by handing to
KENNETH AUNGST
a true and attested copy of PROTECTION FROM ABUSE
together with
NOTICE OF HEARING AND ORDER, TEMP PFA
PETITION
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
9.30
.00
10.00
.00
37.30
So Answers: .... ~
~~~.
R. Thomas Kline
05/11/2001
~ J..-trol A.D.
Ck Q.1rt</~,. , ~
thonotary I
Sworn and Subscribed to before
me this .:13,ul.- day of
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JENNIFER AUNOST,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL V ANlA
01-2829 CIVIL
V.
KENNETH WILSON AUNGST,
Defendant
CHARGE: INDIRECT CRIMINAL CONTEMPT
AND NOW, this \0 day of
attached complaints have been properly completed and verified, and there is probable
cause for the issuance of process. In consideration ofthe attached Commonwealth's
Petition, the defendant, KENNETH WILSON AUNGST, is directed to appear for trial on
the charge of Indirect Criminal Contempt before the Court on the d. ~ day of
Ser\-eAMkiC- ,2001 at3: CO o'clock~.m. in Courtroom # .a:: of the Cumberland
County Courthouse, Carlisle, Pennsylvania.
The defendant has a right to be represented by an attorney. If the defendant
cannot afford an attorney, upon request one will be assigned to represent the defendant.
If the defendant wishes assignment of counsel, contact should be made prior to trial with
the Cumberland County Public Defender's Office at 717-240-6285. Further, if the
defendant fails to appear, an arrest warrant will be issued.
The Sheriff of Cumberland County is directed to serve this Order and Petition
upon the defendant. The assessment of costs to be determined by the Trial Judge
subsequent to trial. e'
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B~~ Court .
J.
Jonathan R. Birbeck,
Chief Deputy District Attorney ~ ~ i 1J.v". /..21}. \
KENNETH WILSON AUNGST
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JENNIFER AUNGST,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: 01-2829 CNIL TERM
KENNETH WILSON AUNOUST,
Defendant
CHARGE: INDIRECT CRIMINAL CONTEMPT
COMMONWEALTH'S PETITION FOR A HEARING ON CHARGES
OF INDIRECT CRIMINAL CONTEMPT
Jonathan R. Birbeck, Chief Deputy District Attorney of Cumberland County,
Pennsylvania, brings the following Petition for a hearing on charges ofIndirect Criminal
Contempt:
I. A Protection from Abuse Order was issued by the Court. A true and correct
copy of the Order is attached.
2. The defendant's violation ofthis Order is averred in the attached criminal
complaint.
3. The victim requests the filing of an Indirect Criminal Contempt Charge.
4. The District Attorney's Office approves the filing ofthis criminal complaint.
5. The Commonwealth is requesting a hearing on the charges of Indirect
Criminal Contempt pursuant to 23 Pa.C.S.A. 9 6113.
6. The plaintiff and/or the defendant may seek modification ofthe Order based
on the filing ofthis petition as the Court deems appropriate following the trial
in addition to any other sentence. 23 Pa.C.S.A. 96113.
WHEREFORE, the Commonwealth requests the defendant be commanded to
appear before the Court on the charge of Indirect Criminal Contempt.
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,on'"
Sep:> 05 01 01:58p:>
Chief' of' Police
761-0753.
".2
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: C1JMRr:RUNf1
1~lJ9isteri!:tlOislnctN>mber. 09-3-04
I DilOhietJuet.eet-laroe:Ho:w1. Thomas E. Placey
.................
. .
. . .
POLlCE
CRIMINAL COMPLAINT
A~~, 104 S. Sporting Hill Road
Mechanicsburg, Fa. 17050
T"'P",n'" (717) 761-8230
DEFENDANT:
COMMONWEALTH OF PENNSY\.VAN1A
VS.
Date Filed:
~
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NAME an<! ADDRESS
AUNGST, Kenneth Wilson J"
4411 PACKARD LANE
CAMP. HILL, FA. 17011
!
Docket No.:
L
OTN:
Defenl'l.Ylf) RllceJElhniclly Derendll'lf& Se~ DefriMt's O,Q.B. Oilfendr.fs Social Security Nlftlber DefendwJt'lI SID {$tate ldMliflcation Nl.JT1ber} I
~VVhite C1BIal;k [J Fern. 4-15-57 187-48-3661 I
Asilli o NativeAmeric;an t;tMale ,
o HiSf)ilnicD lJnknown _--1
Oefendlllll1l'sAK.A. (eltGk.nIMn a$l o,fendal1r:o'lehic!<:l1n(orm8tM DefendanhDrivet'sL:censeNlIl'ID<< I
PlateNU'nber I Sl<t, Registlatian Stidl.oM tMMIYY) Slate I
!<EN I PA 17-903-042 i
Complainlllncldent Nunoer l;ompl&lnttlrK>idvnl Nunber if other Pa.;tei~ UCRINIBRS~ 1
i
,
I
District Attorney's OffIce 0 Approved 0 Disapproved because:
(The dlSVict attorney may r.equife Ihallhe complaint, arrest warrant affidaw, or both ~ appn;lVe(l by lf1e atton:\eY for the Commonwealth prior to filing. Pa.FtCr.P_ 107.)
(Namer/. Attomi!Y for Commoi'lHi!llllt\.Please Pm\ (J( Type)
(0.)
(Sig~ure aI Attorney for Canrnonweallh)
I, CO!. Dennis C. Lundauist
(Named Affiant.Pleae Pool Of Type)
~i1\1" ilg-?
IOffi=ersv,dgeN"","rll.O.)
of
Hampien '!:WI;>. Pol; C'.P D"'~
(kI6n1ifY Oapertmentar Agancy RIlpf4,enled and oliUes! SubdMStotI)
pn.n?l n.d.nn
{police A.Q<<'tri or OR] NUMbw)
2001-0R-443
(Originaiing~ Case Nt.mI:el'(OCA))
do hereby state: (check appropriate box)
1. I<J I accuse the above named defendant who lives at the address set forth above
o I accuse the defendant whose name is unknown to me but who is described as
o I acc"se the defendant Whose name and popular designation or nickname is unknown to me and whom I
have therefore designated as John Doe
with violating !he penal laws of the Commonwealth of Pennsylvania at 44!1, PA"k,",'" T,,,,.. r,,1l1p 'f; 11 p" 17nll
{PI olltic:.llSubdi'li3ion} .
F.amuden l'CMnship
in Cllmh..rl;mn County on oraboul 4:30PM Sunday AUClUSt 12, 2001
Perticipants were: (If there were participants, place their names here, repeating the name of the ebove defendant)
Kenneth Wilson Aungst
AOPC 412A.111241tEl
1-'
Sep OS 01 01:581"
Chief of Po'! ice'
761-0753,
1".3
\Continuallon rJ No.2)
~'
Defendant's Name: AUNG .
ST.
Docket Number:
Kenneth Wilson
1*,.-.
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POLICE
CRIMINAL COMPLAINT
2.
The acts committed by the accused were: OOIREGr CRIMINAL CONTEMl'T .'
(Set forth a summaryQfthe facta suffICIent 10 ad'oisethe defendant Of the nature ot tne offen8e cl1arged. A Ci'.alion to the statute allegedlv VIOlated. Wlthout mons,
is not sufficient. In '8 summary case, you must cite ltIe specIfic section and subsection of the statute or ordinac'lee allegedly ..rotated.)
'ltJe defendant violated the Protection From Abuse Order 01-2829 Civil 2001 issued
on 23 July 2001 by the Honorable Judge Edgar B. Bayley. 'ltJe defendant did threaten
the victim. Jennifer S. Aungst, by lunging at her, yelling at her and pounding on
the windows of her vehicle while she was inside the vehicle. 'ltJe victim in fear
for her safety left the area and made alte:rnate arraignments for housing as she
feared the defendant may come to her primary residence.
all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of
Assembly, or in violation of
6]]4 " ofthe 23 Pa.C: S 1
(t;eclion) {SubaeotionJ (PASIatJl8) (<om)
2. of the
(S~lon) (SUbs&diQn) (PA$IBOAe) (<oml
3 of the
(58Ctioo) (SlJllGlIdion~ (PAStatutel ('-"I
,. of the
{Section) (Subaec:ljgn) tPAStatute) ''''''''''
3. I ask that a warrant of arrest or a summons be Issued and that the defendant be required to answer the charges I
have made. (In oilier for a warrant of arrest to issue. Ihe attac/1ed affidavit of probable cause must be
completed and swom to before the issuing authority.)
4. I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information and
belief. This verification is made subject to the penalties of Section 4904 of the Crimes COde (16 PA.C.S.~904)
relating to unsworn falsification to authorities. \ .
10ate)
AND NOW, on this date, , I certify that the complaint has been proper! ompleted and verified. An
affidavit of probable cause muSt be completed in order for a warrant to issue.
(Magisterial DIstrict;!
(lssuinp Authority)
SEAL
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COMMONWEAL""H OF PENNSYLVANIA
COUNTY OF CUMBERLAND
09201
SUMMONS
CRIMINAL COMPLAINT AND
PROBABLE CAUSE AFFIDAVIT
COMMONWEALTH OF
PENNSYLVANIA
VS.
Mag. Disl. No.:
OJ Name: Hon.
PAULA P CORREAL
Address:
1 COURTHOUSE SQ
CARLISLE PA 17013
717 240 6564
DEFENDANT:
Telephone:
NAME and ADDRESS
KENNETH WILSON AUNGST
4411 PACKERD LN
CAMP HILL PA 17011 0000 00
AKA:
KENNETH AUNGST
Docket No.:
Date Filed:
OTN:
~-
~
Registra1ion Number
Annual Sticker Number
R.8.A.:
WM 44
D.0.6.: 04 15
OLN Number
IPA17903042
I 20015~~~~~~ CAR
1957 8.8.#: 187
SID Number
Complainl Number
Complaint Numbers if other Participants
I
1642 UCR N,mbe'
48 3661
ORINO.:
PA0210200
District Attorney's Office _ Approved -Disapproved because:
(The District Attorney may require that the complaint, arrest warrant affidavit, or both be approved by the attorney for the Commonwealth prior to filing.
Pa.R.Cr.P. 107.) When the affiant is not a police officer as defined in Rule 51(C) and the offense(s) charged include(s) a misdemeanor or felony which
does not involve a clear and present danger to any person or the community, the complaint shall be submitted to the attorney for the Commonwealth, who
shall approve or disapprove without unreasonable delay).
(Issue Date)
(Signature)
I, (NameolAtflant) PO DAVID H TILDEN BADGE 11
m CARLISLE PD
residing at 53 WEST SOUTH ST CARLISLE PA 17013
do hereby state: (check appropriate area)
1. -K. I accuse the above named defendant, who lives at the address set forth above or,
_ I accuse an individual whose name is unknown to me but who is described as
_ I accuse the defendant whose name and popular designation or nickname is unknown to me and whom I
have therefore designated as John Doe
with violatingJhe penal laws of the Commonwealth of Pennsylvania at: CARLISLE
561 SUMMIT DR CARLISLE (Place-PollllcaISubdivision)
in (County) CUMBERLAND on or about 08 23 2001 0458 HRS
participants were: (if there were participants place their names here, repeating name of above defendant)
2. The acts committed by the accused were:
(Set forth a summary of the facts sufficient to advise the defendant of the nature of the offense charged. Neither the evidence nor the statute
allegedly violated need be cited, nor shall a citation of the statute allegediy violated, by itself, be sufficient. In a summary case, set forth a
citation of the specific section and sub-section of the statute or ordinance allegedly violated).
** INDIRECT CRIMINAL CONTEMPT - ADULT
CTS
1
THE ACTOR DID VIOLATE THE PROTECTION FROM ABUSE ORDER
NUMBER 01-2829 CIVIL ACTION-LAW
THE ORDER WAS SIGNED BY THE HONORABLE JUDGE BAYLEY
THE ORDER WAS DATED 7/23/2001
Copy: District Justice
Defendant
Return of Service
Police
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Page 2
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CRIMINAL COMPLAINT AND
PROBABLE CAUSE AFFIDAVIT
KENNETH WILSON AUNGST
Defendant Name:
Docket Number:
THE ACTOR VIOLATED THE ORDER BY
CALLING HIS SEPARATED WIFE WHO HAS THE PFA, JENNIFER
AUNGST, ON THE PHONE WHICH WAS ANSWERED BY HER ANSWERING MACHINE
AND LEFT A MESSAGE INDICATING THAT HER EMPLOYERS MIGHT LIKE TO
RECIEVE LETTERS LETTING THEM KNOW SHE IS AN ADULTERESS, ETC.
THIS PFA PROHIBITS PHONE CALLS TO JENNIFER. THIS ACT
ALLEGEDLY OCCURED ON 8/11/01
ALL OF WHICH WERE AGAINST THE PEACE AND DIGNITY OF THE COMMONWEALTH OF
PENNSYLVANIA AND CONTRARY TO THE ACT OF ASSEMBLY,
OR IN VIOLATION OF 6114 A1 OF THE ACT OF 23
OR THE ORDINANCE OF
3. I ask that a warrant of arrest or a summons be issued and that the accused be required to answer the charges
I have made. (In order for a warrant of arrest to issue, the attached affidavit of probable cause must be
completed and sworn to before the issuing authority.)
4. I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information
and belief. I certify the complaint has been properly completed and verified, and that there is probable cause
for the issuance of process. This verification is made subject to the penaltie of Section 4904 of the Crimes
Code (18 PA. C.S. 4904) relating to unsworn falsification t)'tho .. '_
Date: <g/;t...'ff Or ,1 (Signature of Complainant) #--1 ( CP]) CBrJ;56.
AND NOW, on this date, I certify the complaint has been properly completed and
verified, and that there is probable cause for issuance of process.
(MaglslenaILJlstnct)
(Issuing Autnority)
(SEAL)
I C'~~__N~ _ .
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y~-,-.....,-,- -~, ,'.' - -
CARLISLE PD
PROBABLE CAUSE AFFIDAVIT
INCIDENT NUMBER: 20010800952 CAR
DATE: 08/23/2001
OTN:
PG 1
CHAAGE (S) :
23 6114
Al
INDIRECT CRIMINAL CONTEMPT - ADULT
#CTS
1
COMMONWEALTH VS KENNETH
WILSON
AUNGST
INFORMATION:
JENNIFER AUNGST TESTIFIED IN A SUMMARY CASE AGAINST HER HUSBAND
ON 8/9/2001 FOR. SHE HAS A PROTECTION FROM ABUSE ORDER WHICH
PROHIBITS HIM FROM HAVING ANY CONTACT WITH HER ANYWHERE, EXCEPT
WHEN EXCHANGING CHILDREN. (PARAGRAPH 2)
PARA 3 STATES, "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."
THIS ORDER WAS ISSUED BY THE COURT OF COMMON PLEAS IN CUMBERLAND
COUNTY ON JULY 23, 2001.
IT IS TILTLED CASE NO 01-2829, CIVIL ACTION-LAW
PROTECTION FROM ABUSE.
.
IT SHALL EXPIRE DECEMBER 5,2002.
IT WAS SIGNED BY JUDGE BAYLEY.
JENNIFER STATES THAT ON AUGUST 11, 2001, SHE RECEIVED A TELE-
PHONE CALL FROM HER HUSBAND ON HER RECORDER AND HE STATED THE
FOLLOWING:
" HELLO? CAN YOU PICK UP THE PHONE? I KNOW YOU'RE THERE BECAUSE
IT'S BEEN BUSY FOR THE LAST 5 OR 10 MINUTES. HELLO? ALL RIGHT.
WELL, IF THAT'S THE WAY YOU WANT TO DO IT, THAT'S FINE. I HOPE
YOU AND DAVE HAD A GOOD TIME LAST NIGHT. IT PROBABLY WAS A GOOD
MOVIE YOU WATCHED. I THINK THAT AFTER HAVING YOU TESTIFY
AGAINST ME, YOU AND YOUR BOYFRIEND ON WEDNESDAY, I THINK MRS.
MCCULLOUGH (VICTIMS PRESCHOOL SUPERVISOR), THE PASTOR, AND THE
PRINCIPAL AT MOORELAND WOULD PROBABLY APPRECIATE A LETTER KNOW-
ING ABOUT WHAT'S GOING ON. THEY PROBABLY WOULD APPRECIATE
HAVING AN ADULTERESS WORKING FOR THEM. ALL RIGHT-SEE YOU LATER"
THIS STATEMENT AND A COPY OF THE PFA WERE FORWARDED TO DISTRICT
ATTOURNEY SIBERT WHO ADVISED TO FILE AN INDIRECT CRIMINAL CON-
TEMPT.
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Jennifer Aungst
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
. : PENNSYLVANIA
Plaintiff
v.
: No. 01-2829
Kenneth Wilson Aungst
Defendant
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
FINAL ORDER OF COURT
Defendant's Name is: Kenneth Wilson Aungst
Defendant's Date of Birth is: April 15, 1957
Defendant's Social Security Number is: 187-48-3661
Name(s) of All protected persons, including Plaintiff and minor
children:
1. Jennifer Aungst
AND NOW, this J3rd d.
the parties and the subject-
DECREED as follows:
';>001
o the c6urt having jurisdiction over
er, it is ORDERED, ADJUDOED and
Upon agreement of the parties for the entry of a consent order, this
order will be entered without any admission ofliability by the
defendant and without a finding of abuse by this court:
Plaintiffs request for a fInal protection order is granted.
1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or
any other protected person in any place where they might be
found.
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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 at 561 Summit Drive, Carlisle,
Pennsylvania.
Plaintiffs. employment located at Grace United Methodist
Church, 41 South West Street, Carlisle, Pennsylvania.
Any non-harassing contact by Defendant with Plaintiff which
may occur during custody exchange of the minor children
infront of the residence located at 561 Summit Drive, Carlisle,
Pennsylvania, or during functions at the minor children's
school, shall not be deemed a violation ofthis Order.
Defendant shall remain in the vehicle during custody
exchanges for the duration of this Order.
3. Defendant shall not contact the Plaintiff, or any other person
protected under this Order, by telephone or by any other means,
including through third persons.
4. The following additional relief is granted as authorized by ~6l 08
of the Act:
- This Order shall remain in effect until modified or
terminated by the Court and can be extended beyond its
original expiration date if the Court fmds that Defendant has
committed an act of abuse or has engaged in a pattern or
practice that indicates risk of harm to Plaintiff.
- Defendant shall not damage or destroy any property owned
jointly by the parties or solely by Plaintiff.
- Defendant shall refrain from harassing Plaintiffs relatives.
- Any non-threatening, non-harassing phone calls to Plaintiff
in regards to the parties' children shall not be deemed a
violation ofthis Order.
- The court costs and fees are waived.
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5. A certified copy of this Order shall be provided to the police
department where Plaintiff resides and any other agency specified
hereafter:
Carlisle Police Department
6. THIS ORDER SUPERSEDES:
1. ANY PRIOR PFA ORDER
7. All provisions of this order shall expire on: December 5, 2002
NOTICE TO THE DEFENDANT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR
ARREST ON THE CHAROE 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 P A.C.S. ~6Il4. VIOLATION MAY ALSO SUBJECT YOU TO
PROSECUTION AND CRIMINAL PENALTIES UNDER THE
PENNSYL VANIA CRIMES CODE.
THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES,
THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S.
TERRITORIES AND THE COMMONWEALTH OF PUERTO
RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18
U.S.C. ~2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND
INTENTIONALL Y VIOLATE THIS ORDER, YOU MAYBE
SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER
THAT ACT. 18 U.S:C ~~2261-2262. IF THE BRADY INDICATOR
PARAGRAPH APPEARS IN THE ORDER, YOU MAYBE
SUBJECT TO FEDERAL PROSECUTION AND PENALTIES
UNDER THE "BRADY" PROVISIONS OF THE OUN CONTROL
ACT, 18 U.S.c. ~922(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 I through 3 of this order may be without
warrant, based soley on probable cause, whether or not the violation
is committed in the presence of the police. 23 Pa.C.S. 96113.
Subsequent to arrest, the police officer shall seize all weapons used
or threatened to be used during the violation of the protection order
or during prior incidents of abuse. The Cumberland County Sheriff
shall maintain possession of the weapons until further order of this
Court.
When the defendant is placed under arrest for violation of this order,
the defendant shall be taken to the appropriate authority or authorities
before whom defendant is to be arraigned. A "Complaint for Indirect
Criminal Contempt" shall then be completed and signed by the police
officer OR the plaintiff. 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 no . e
of the date of the hearing.
oan Carey
Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
Edward eintra
Attorney for Defendant
Law Office of Edward Weintraub and Associates
2650 North Third Street
Harrisburg, P A 17110
Distribution to:
-Legal Services ~~ 7.,;),.4.61
-Faxed and ~ailed to PSP ~-J.Lj. 0 i ~ lOt 41
-Edward Wellltraub, Attomey. ..
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Plaintiff
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
Jennifer Aungst
v.
.
.
: No. 01-2829
Kenneth Wilson Aungst
Defendant
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
FINAL ORDER OF COURT
Defendant's Name is: Kenneth Wilson Aungst
Defendant's Date of Birth is: April 15, 1957
Defendant's Social Security Number is: 187-48-3661
Name(s) of All protected persons, including Plaintiff and rninor
children:
I. Jennifer Aungst
AND NOW, this dJrd cI-
the parties and the subject-
DECREED as follows:
-'001
the c6urt having jurisdiction over
er, it is ORDERED, ADJUDOED and
Upon agreement of the parties for the entry ofa consent order, this
order will be entered without any admission of liability by the
defendant and without a finding of abuse by this court:
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.
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2. Defendant is prohibited frorn having ANY CONTACT with the
Plaintiff, or any other person protected under this Order, at any
location, including but not limited to any contact at Plaintiff's
school, business, or place of ernployernent. Defendant is
specifically ordered to stay away from the following locations for
the duration of this order.
Plaintiffs residence at 561 Summit Drive, Carlisle,
Pennsylvania.
Plaintiffs e~ployment located at Grace United Methodist
Church, 41 South West Street, Carlisle, Pennsylvania.
Any non-harassing contact by Defendant with Plaintiff which
may occur during custody exchange of the minor children
infrontof the residence located at 561 Summit Drive, Carlisle,
Pennsylvania, or during functions at the minor children's
schooL, shall not be deemed a violation of this Order.
Defendant shall remain in the vehicle during custody
exchanges for the duration of this Order.
3. Defendant shall not contact the Plaintiff, or any other person
protected under this Order, by telephone or by any other means,
including through third persons.
4. The following additional relief is granted as authorized by ~6J08
of the Act:
- This Order shall remain in effect until modified or
terminated by the Court and can be extended beyond its
original expiration date if the Court fmds that Defendant has
committed an act of abuse or has engaged in a pattern or
practice that indicates risk of harm to Plaintiff.
- Defendant shall not damage or destroy any property owned
jointly by the parties or solely by Plaintiff.
- Defendant shall refrain from harassing Plaintiffs relatives.
- Any non-threatening, non-harassing phone calls to Plaintiff
in regards to the parties' children shall not be deemed a
violation ofthis Order.
- The court costs and fees are waived.
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5. A certified copy of this Order shall be provided to the police
department where Plaintiff resides and any other agency specified
hereafter:
Carlisle Police Department
6. THIS ORDER SUPERSEDES:
1. ANYPRIORPFAORDER
7. All provisions of this order shall expire on: December 5, 2002
NOTICE TO THE DEFENDANT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR
ARREST ON THE CHAROE 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 P A.C.S. 96114. VIOLATION MAY ALSO SUBJECT YOU TO
PROSECUTION AND CRIMINAL PENAL TIES 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 AOAINST WOMEN ACT, 18
U.S.C. 92265. IF YOU IRA VEL OUTSIDE OF THE STATE AND
INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE
SUBJECT TO FEDERAL CRIMINAL PROCEEDINOS UNDER
THAT ACT. 18 U.S.C 992261-2262. IF THE BRADY INDICATOR
PARAGRAPH APPEARS IN THE ORDER, YOU MAY BE
SUBJECT TO FEDERAL PROSECUTION AND PENALTIES
UNDER THE "BRADY" PROVISIONS OF THE OUN CONTROL
ACT, 18 U.S.C. 9922(0), 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. ~6l13.
Subsequent to arrest, the police officer shall seize all weapons used
or threatened to be used during the violation of the protection order
or during prior incidents of abuse. The Cumberland County Sheriff
shall maintain possession of the weapons until further order of this
Court.
When the defendant is placed under arrest for violation of this order,
the defendant shall be taken to the appropriate authority or authorities
before whom defendant is to be arraigned. A "Complaint for Indirect
Criminal Contempt" shall then be completed and signed by the police
officer OR the plaintiff. 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 n
of the date of the hearing.
oan Carey
Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
Edward eintra
Attorney for Defendant
Law Office of Edward Weintraub and Associates
2650 North Third Street
Harrisburg, P A 17110
Distribution to: --,
-Legal Services --~. 7.J-4.6f
-Faxed and MaiYed to PSP l-.~Lj. () 1 ~ IfJ 41
-Edward Weintraub, Attorney
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07/24/01 TUE 10:41 FAX 717 240 6573
~ CUMB_CO PROTHONOTARY
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OfflCE Of mB PROI'HCNJrAR'!
CUMBERLAND o:xJNrY COUR1liClJSe:
C>>lE COORTIlOOSE SQUARE
CARLiSLE. PA. l7013-3367
(717) 240-6195
fAX (717) 240-6573
V I ATE LEe 0 PIE R
TO:
PA STATE POLICE ~ CellI. p"'CC$r... /11. Po J..S.
FAX #:
717-249-0779
,
FRQ-1:
CURTIS R. LONG
RE:
PFA ORDERS
MESSAGE :
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JENNIFER AUNOST,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS OF
VS.
: CUMBERLAND COUNTY, PENNSYLVANIA
; NO. 2001- ..l J.21 CIVIL TERM
KENNETH AUNGST,
DEFENDANT
: PROTECTION FROM ABUSE
ORDER FOR CONTINUANCE
AND NOW, this/!l!!ctay of May 2001, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing, May 18,2001, by this Court's Order of May 10,200 I,
is hereby rescheduled for hearing on ~Ju" \U~'4. 28t ~m. in
courtroomNo.b.[lt1.. ~~ ().<<)~ e~
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Edward Weintraub
Attorney for Defendant
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Joan Carey
Attorney for Plaintiff
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JENNIFER AUNOST,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
VS.
: NO. 2001- .:182.q CIVILTERM
KENNETH AUNOST,
DEFENDANT
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
The Plaintiff, Jennifer AunlJ"t, by and through her attorney, Joan Carey of Mid Penn Legal Services,
moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds
that:
,,1
1.
A Temporary Protection From Abuse Order was issued by this Court on May 10,
2001, scheduling a hearing for May 18,2001, at 8:45 a.m.
2. The Cumberland County Sheriff's Department served Defendant with a certified copy
of the Temporary Protection From Abuse Order and Petition for Protection From Abuse at his
residence located at4411 Packard Lane, Camp Hill, Pennsylvania, on, May 10,2001, at 7:55 p.m.
3. Defendant has retained Edward Weintraub, Esquire, to represent him in the above-
captioned matter, and Attorney Weintraub has requested a Continuance.
4. The parties agree, by and through their counsel, that the hearing be rescheduled and
that the Temporary Protection From Abuse Order remain in effect until further Order of Court.
5. The Plaintiff requests that the Temporary Protection From Abuse Order remain in
effect for a period of eighteen months frorn the date it was entered or until further Order of Court,
whichever comes first.
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WHEREFORE, the 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 eighteen months from the date it was entered or until further Order of Court, whichever
comes first.
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JENNIFER AUNGST,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
KENNETH WILSON AUNGST,
Defendant.
NO. 01-2829 CIVIL TERM
ORDER OF COURT
AND NOW, this 27th day of September, 2001, I
adjudicate defendant in contempt of the terms and conditions of
the PFA order. Sentence is that you pay the costs of
prosecution and undergo a period of probation for a period of
six months conditioned upon your compliance with all terms and
conditions of the PFA order of July 23, 2001.
By the Court,
Jonathan R. Birbeck, Esquire
Chief Deputy District Attorney
J.
probation
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William G. Braught, Esquire
Assistant Public Defender
Sheriff
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