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HomeMy WebLinkAbout01-05907 Carol Susan Proudfoot, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : 01- -5'96 7 CIVIL TERM Gregory Lee Proudfoot, Defendant : PROTECTION FROM ABUSE NOTICE OJ? 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 ONTIDS MATTER IS SCHEDULED ON (J~I ~ ,2OO1,AT 3; tV ~M., IN COURTROOM NO. _ ~ OF THE CUMB RLAND COUNTY COUR OUSE, CARLISLE, PENNSYLVANIA. You MUST obey the Order that is attached until it is modified or terminated by the court after notice and hearing. If you disobey this Order, the police may arrest you. Violation oHhis Order may subject you to a charge ofindirect 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. ~6Jl14. 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 Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. ~ 2261-2262. You should take this paper to your lawyer at once. You have the right to have a lawyer represent you at the hearing. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. If you cannot find a lawyer, you may have to proceed without one. 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 conl[erence or hearing. ~~'~.I\:""">"'~"d""" .' ~r .<~,t ".~"' >'~"'1<"' ,_',',,'.' , .. , '.'- "" , ,,~ " :! Carol Susan Proudfoot, : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYL V ANlA Plaintiff v. : No. 01-5907 Gregory Lee Proudfoot, Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Gregory Lee Proudfoot Defendant's Date of Birth is: December 25,1955 Defendant's Social Security Number is: 186-38-2649 Name(s) of All protected persons, including Plaintiff and minor children: 1. Carol Susan Proudfoot AND NOW, on 11th Day of October, 2001 upon consideration of the attached Petition for Protection from Abuse, the court 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. ""-Ii; " r,,' . - '~"''''_',rc;>'" _ I ~ I ~,' > 2. Defendant shall be evicted and excluded from the residence at: 12 Cicada Drive Mechanicsburg, P A 17050 or any other permanent or temporary residence where Plaintiff or any other person protected under this Order may live. Plaintiff is granted exclusive possession of the residence. Defendant shall have no right or privilege to enter or be present on the premises 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 Plaintiffs school, business, or place of employment. Defendant is specifically ordered to stay away from the following locations for the duration of this order. -Plaintiffs place of employment located at Merck-Medco, 5073 Ritter Road, Mechanicsburg, Pennsylvania. 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. 1. Any and all weapons, including but not limited to, a boning knife Defendant used to threaten Plaintiff, rifles, shotguns, and/or handguns. Defendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration ofthis order. 6. The following additional relief is granted: -Defendant shall not harass Plaintiffs relatives. -Defendant shall not damage or destroy any property owned jointly by the parties or solely by Plaintiff. 'c-<i'l" _ :';"1'":',' '!""",~,""k,- '''!"L','''~~"'"'''' "1 ,~ ~ ~ : '-,' 't 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Silver Springs Township Police Lower Allen Township Police 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 APRIL 11, 2003 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 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 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. 992261- 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 ofIndirect Criminal Contempt. Ao arrest for violation ofthis 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 Sheriff's office of the county which issued this Order, which office shall maintain possession of the weapons until '1%\W '-,', ' ",f~, ",-;,'__~^""';" ," '_ , ' .. ., ' I ~ - "',' ' 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. Distribution to: MidPenn Legal Services ~ Ii, ~ Faxed & Mailed to PSP t c, f!l + IYt P J- .s Cumberland County Sheriff '''''''':\i!t.;~ 0, ,j'~,Q' '~':S"',"': ,-' Judge ~ )j~ - PFAD Number: KC1346032X Carol Susan Proudfoot, : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff v. : No. 01- ,J~01 ~ T.b-- Gregory Lee Proudfoot, Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE 1. Plaintiffs name is: Carol Susan Proudfoot 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. Carol Susan Proudfoot 4. Plaintiffs Address is: 3803 Conestoga Road, Camp Hill, PA 17011 5. Defendant's Name is: Gregory Lee Proudfoot 6. Defendant is believed to live at the following address: 12 Cicada Drive, Mechanicsburg, P A 17050 'C"N""''''''' , ",:', ?;~' :-0,<"',' ~ " ^ ",[,; - -, , ' ~ 7. Defendant's Social Security Number is: 186-38-2649 8. Defendant's Date of Birth is: December 25, 1955 9. Defendant's Place of employment is: Anderson Logistics, Plainfield P A 10. Defendant is an adult. 11. The relationship between the Plaintiff and the Defendant is: Spouse 12. The defendant has not been involved in a criminal court action. 13. The facts of the most recent incident of abuse are as follows: On or about September 24, 2001, Defendant detained Plaintiff in a closet by holding his arms out and would not allow her to leave. The minor child called his grandmother, who called the police. When the police arrived, they spoke with Plaintiff. Plaintiff and the minor child fled the residence after speaking to the police. The police spoke to Defendant who remained in the residence. 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: On or about September 22, 2001, Defendant threw a laudry basket at Plaintiff causing it to break. Defendant picked up a piece of the hard plastic, pointed it at Plaintiff, and threatened that one of them was going to kill someone and that it was going to be him. Plaintiffsuffered reasonable fear of imminent serious bodily injury. On or about September 18, 2001, Defendant removed a boning knife from the kitchen drawer and stated that it was not sharp enough. Defendant sharpened the knife, used the knife to remove hair from his arm and a layer of skin off of his finger to show Plaintiff Ac,),. ',~ -,-..'r "'","' C." . how sharp the knife was. Defendant pointed the knife in Plaintiffs face and stated it was sharp enough. This caused Plaintiffto fear for her safety. Defendant then stuck the knife into the cutting board with such force it left a hole. On or about September 17, 2001, Defendant threatened Plaintiff stating that one of them was going to kill someone, causing Plaintiffto fear for her safety. Since approximately 1982, Defendant has abused Plaintiff in ways including the following: pushed, grabbed, slapped, and threw things at her causing soreness and bruises. On one occasion, Defendant pushed the minor child down the steps. Additonally, Defendant has hit the family dog. 15. The Defendant has used, or threatened to use, the following weapon(s) against the Plaintiff or the minor child/ren: a. Any and all weapons, including but not limited to, a boning knife, Defendant used to threaten Plaintiff, shotguns, rifles and/or handguns. 16. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: Silver Springs Township Police Lower Allen Township Police 17. There is an immediate and present danger of further abuse from the Defendant. 18. Plaintiff is asking the court to evict and exclude the Defendant from the following residence: 12 Cicada Drive Mechanicsburg, P A 17050 Owned By: Gregory and Carol Proudfoot 19. 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 Plaintiffs residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff. c. Prohibit Defendant from having any contact with Plaintiff and/or minor child/ren, either in person, by telephone, or in writing, personally or through ,-,-?<.- ~ M '" . ~_9 , 1'" . ~,~~ '.'" - , third persons, including but not limited to any contact at Plaintiffs 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. d. Order Defendant to temporarily turn over weapons to the Sheriff of this County and prohibit Defendant from transferring, acquiring, or possessing any such weapons for the duration of the Order. e. Order Defendant to pay the costs of this action, including filing and service fees. f. Order the following additional relief, not listed above: Defendant shall not harass Plaintiffs relatives. Defendant shall not damage or destroy any property owned jointly by the parties or solely by Plaintiff. g. Grant such other relief as the court deems appropriate. h. Order the police or other law enforcement agency to serve the Defendant with a copy ofthis Petition, any Order issued, and the Order for Hearing. The petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. Respectfully submitted, Date: J DIll /01 , / Distribution to: DaVld Lopez, Atto for P MID.PENN LEGAL SER 8 'Irvine Row Carlisle, PA 17013 (717) 243-9400 MlDPENN LEGAL SERVICES Fax and Mail to PSP Cumberland County Sheriff '"<~"'<"~--~'11 , ~'=,' """" ~ T.,.~_.,,,,,,,,-"'1 .,~. VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. Dated: /0/ j/O/ / G~ ~ ei~ Carol Proudfoot, Plainti ',"'''!Wil, -'",,' ,',,",,we,,,,, ._ ,,__, "~" I' T.=" ._,. ... ,< - H "r" "'iIi."" '''''''''=i''~'''''.''.'> .. !lIf~fT,im'",D .N" Jl1UU, ,)!!Lr.-, ~~l'r~ff"')l!il"t'!""" ^<.,4kJ~:," 4v4J,,,,,l!J.,~l!fl!l,,,,,,,,,,,,,~[J!iI~_'\l1-lM-'t,~,r'::rf#':~J!',""':'1-';;I"'-"%f'lI~1".&';J1!~l'l"i~'~Jl~~~~,*,~I~~!t~~~!~~~fl!~ 10/11/01 THO 15:08 FAX 717 240 6573 "- CUMB CO PROTHONOTARY ~001 *************************** *** MULTI TN REPORT *** *************************** TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2843 01l9p2490779 03]9p2405331 04]92438026 PSP CP LS ERROR OPF'ICE OF' TIfE PROl'HCX\I01'ARY CUMaERLAND CXXJNTY COURTIiCOSE ONE CXXJRTIlOOSE ~ARE CARLISLE, PA. 17013-3367 (717) 240-6195 FAX (717) 240-6573 V I ATE LEe 0 P ! E R TO: PA STATE POLICE. l!uu'l. """el $S.. "'.IJ. L..r. FAX ~: 717-249-0779 PRa1: CURTIS R. LONG RE: PFA ORDERS MESSAGE : -L'-I-- 00. 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Carol Susan Proudfoot, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : 01-5907 Gregory Lee Proudfoot Defendant : PROTECTION FROM ABUSE AND NOW, this OR CONTINUANCE day of October, 2001, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on October 17, 2001, by this Court's Order of October 11, 2001, is hereby rescheduled for hearing on November 28, 2001, at 2:00 p.m. in Courtroom No.3 of the Cumberland County Courthollse, 1 Courthouse Square, Carlisle, Pennsylvania. The Temporary Protection From Abuse Order shall remain in effect for a period of eighteen months from the date it was entered, through April 10, 2003, or until further Order of Court, whichever comes first. By the Court, David Lopez, Attorney for Plaintiff Elizabeth Stone, Attorney for Defendant ;2','lt!?H;-~f-. ~, T' ~ ".;, .~- ~ ~<^,...,.,.,. !I!l'l~_ =~ '!-"""""';,jn,,:c"1i1!#J;<f!i.j~~~~~llli,~~_.Jliihi!t&rr' ",-<':-""'.'>1t"-^'~">'^:' - '~~~,'u:~U!lI" "" i~ \:t~~D-{::i':~'\~~r>"'" . r<,'''''<',''',l{')'''' ,\t1qy , I .'," ',",::,' 1:'1 nl'\''') ,It :y: "1 --< "l. ~ ~ . l~ ~ Q\ OCi' is PH 3: 03 CUMBhiU,i'4D COUN1Y PENNSYLVAi~IA . -~ . . Carol Susan Proudfoot, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 01-5907 Gregory Lee Proudfoot Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff, Carol Proudfoot, by and through her attorney, David Lopez, 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 October 11, 2001, scheduling a hearing for October 17, 2001, at 3:00 p.m. 2. The Cumberland County Sheriffs Department served Defendant with a certified copy of the Temporary Protection From Abuse Order and Petition for Protection From Abuse at his residence located at 12 Cicada Drive, Mechanicsburg, Pennsylvania, on October 11, 2001. 3. The parties agree, by and through their respective counsel, that the hearing be rescheduled to afford them time to execute a consent agreement. 4. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of eighteen months from the date it was entered, October 11, 2001, or until further Order of Court. <:',''''''fl<:;;~'',,,,,1'''1!Il~ " ,. T , - . )Jj' Wherefore, Plaintiff requests that the Court grallt this Motion and continue this matter 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, through April 10, 2003, or until further Order of Court, whichever comes first. Res David Lopez, Attorney fo MIDPENN LEGAL SE 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 ;q~~~;nr;: ,,",t~ '~:'}",,"'--"~..'T'~-'" - ,. - ,,"~-, - , A' '~' ~~" ''''r~''~ .. "'~>~h~,,,., '~""'~'",,",~'~ ',>-,d,-",>"""~.,'" ~ ] nnlil r-'1i11TlillJii 0 <::} 0 c: -'1 .... 0 -~ ::.::;-,1 ""'On] n m[D ..... ri1~ 2 --, -'-' 6.152 ""-,,,,'; -J :i']-,-_j -<(",: ':--.:~'; (~) '-0 <: -0 iSA )> ~, 20 ~ --0 r:~5~ )>c: ~ ':::l o;;! :0 <>> =< ~"L ..- ,,' , ......-~i.l!l4fi!>;;~ __lIrt:!J~"""" ~J- n ,;~~m-~JJ [_~~ .., .,. ,_flTI-:J!:., ,,t;.>,~~El~"""JiJ~1'1I~~,%l~*,,,-'~rr..~!,\]y,'<t-.<': "C''''!}I1,,;tl:'-i~.J\W;:B''f\!;"l'~~,JljWj;!i.''i~illl);;'M1l:!~'''''~~~~I:,1f"~ i" SHERIFF'S RETURN - REGULAR CASE NO: 2001-05907 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PROUDFOOT CAROL SUSAN VS PROUDFOOT GREGORY LEE BRIAN BARRICK , Sheriff or Deputy Sheriff of cumberland County,Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon PROUDFOOT GREGORY LEE the DEFENDANT , at 1935:00 HOURS, on the 11th day of October ,2001 at 12 CICADA DRIVE MECHANICSBURG, PA 17055 by handing to GREGORY LEE PROUDFOOT a true and attested copy of PROTECTION FROM ABUSE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 6.50 .00 10.00 .00 34.50 r~~~~_ R. Thomas Kline 7 ~ Sworn and Subscribed to before 10/15/2001 LEGAL 'ERV~ ~ By : 'hi ~tr Deputy Sheriff me this 31.--if day of (!)r--trP ~ ~/ A.D. ~Q,~~ Prothonotary ~'!""'~"",~-, ,>,,~'~~~,. ,0 ~ ~"""'<>'~ r ~"~ ~",'" ~,-, . ,<- ~~ ~~ ~"~~~ . ".0 <'''' <,'~, ' , , Carol Susan Proudfoot, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : 01-5907 Gregory Lee Proudfoot Defendant : PROTECTION FROM ABUSE ORDE FOR CONTINUANCE AND NOW, this day of November, 2001, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on November 28th, 2001, by this Court's Order of October 18th, 2001, is hereby generally cOllltinued. The Temporary Protection From Abuse Order shall remain in effect until further Order of Court. By the Court, David Lopez, Attorney for Plaintiff P~-~cc, /l-J-q-lJ1 ~ 1l-l-f~1 Elizabeth Stone, Attorney for Defendant ?'i[:':),~" \""', ,...,~, P,'" ~ o'--k ''- ~,~ , """',' """, - ~,' ~ I - ':"':""~"'_!~C~____.,,,:,,,,~:,~ii,~_~~;,;:.~,,-!l:,;'~;';W";f,b1\&il~~\$I~1ti~iiJiiH!nj_iJi'~ "'F, '''"-.'''r~'''''''''''"''~ ';Jlw<~ ;:iU:~~'- r;;~ICF ,"-" ':'''',I'I~''';''''I'Dv' "'1)i"il,,)!Fu't 1 OF 01 WJ\] 2'3 fti 3: UI CU~/:BE~:Li~~ "~u COUl\rrv PENNSYl)/ANIiI, , , 1,~1,~.,k"hNJ",%JjLlJ,J1 '! .JJU, , ,,1 J. ~ L '. rc;L,~!L!JU".~,,~, ~ , .C "" ,_,,,, Carol Susan Proudfoot, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : 01-5907 Gregory Lee Proudfoot Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff, Carol Proudfoot, by and through her attorney, David Lopez, of MidPenn Legal Services, moves the Court for an Order generally continue the hearing in the above- captioned case on the grounds that: 1. A Continuance was issued by this Court on October 18, 2001, scheduling a hearing for November 28th, 2001, at 2:00 p.m. 2. The parties agree, by and through their respective counsel, that the hearing be generally continued. 3. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect until further Order of Court. Wherefore, Plaintiff requests that the Court grant this Motion and generally continue this matter and that the Temporary Protection From Abuse Order remain in effect until further Order of Court, whichever comes first. David Lopez, Attorney for. MIDPENN LEGAL SER 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 ''''~,:nf[ . "'~__(" ,"- <, '1"- _'I'll""'*'< . - -, q--, "- ., ~ 'b','-- . ~;li..",""'~"" '. .~ "'1 'f I!lliWl':"'r'T"#~l"li'.rllT;'CINlr" ." riT.. ,. "'~:n-r:-I'I-"rl!Jlmli':lql 0 0 c' C <I', ~ ~ -00,] "",- r'~ mrn - "'::;.:T: '- 2:1~, "" (.J"J.,:-. 'JJ -<,-., r'c ~E;' ::;::t'> c~ , >c C5rn 2: -. -' ,- -< f':) :J.J -< f--5 ~ n ~,", f1i." "L ,DR,__~",.. ~DfJ.IlUi~p'~l~~Jl!i'!,~'1:~,,,,~M, ,)1 J;ij,,,,,,,~;I~~~~Wlm;Th'-'"'i;1"W)":~d' :i1J. i;,',-.;h:;f'" Carol Susan Proudfoot, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA vs. : NO. 01-5907 CNIL TERM Gregory Lee Proudfoot, Defendant : PROTECTION FROM ABUSE PETITION TO VACATE ORDER AND WITHDRAW ACTION Plaintiff, Carol Susan Proudfoot, by and through her attorney, David A. Lopez of Mid Penn Legal Services requests that the Court vacate the Temporary Protection From Abuse Order in the above-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 October 11, 2001. 2. Plaintiff requests that the Temporary Protection From Abuse Order be vacated and the action withdrawn without prejudice to her. 3. A certified copy of this Order will be provided to the Police Departments by the attorney for Plaintiff. WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate the Order, and that the action be withdrawn without prejudice to Plaintiff. vid A. Lopez Attorneys for Plaintiff MIDPENN LEGAL SERVICES 8 Irvine Row, Carlisle, P A 17013 -"\'''l''l''"'''?'''. < ,- -" -j -, ~,' ;r"~ ~ ~ < , . VERIFICATION I verify that I am the Petitioner as desigoated 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 unswom falsification to authorities. Dated: / () /3jlo;;Z I (:m#,~L{J&1Y) 1tcx1<'P Carol Susan Proudfoot, Plain ;~~~l!1l n" ,._ ,__0" r ~ . ~ -~ ~ = '. ~"" '-, , ,,,",- -" "'~'--~~.',~",,',"" < ~~, "1 ",," r <,,,,,,,,,,,,",,~,,,,'o,,,.. . ~"'".." _ ~ ~ "<'''I'''1''~~'' 'q r=,?~O',"Ifi ,"~ ,'~_ "~ ~~,~ ,,' .[" l J1, ~ ~_",j~"u:j!!f!!\!f ~,"_,.;Iri'W.~~Jjii(#1i"g''''"'':;--'''''l'''j''' Ii ....TUli'r"~'~'h'".l11n [linn] JllJilllij(II"'ffl'fl'&I'w o ~~ ."[i:':"-' Q::r ~:~::' , d~~__ Cf) "; - :':,-?: -?~ , ::-~~:~~ =< r-- r-:..) (' :'C<'" l() c::: T . , , Carol Susan Proudfoot, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 01-5907 CIVIL TERM Gregory Lee Proudfoot, Defendant : PROTECTION FROM ABUSE ORDER OF COURT AND NOW, thil day of November, 2002, upon consideration ofthe attached Petition, the Temporary Protection From Abuse Order in the above-captioned case entered on October 11, 2001, is hereby vacated and the action withdrawn without prejudice to Plaintiff. A certified copy of this Order shall be provided to the Police Department by Plaintiffs attorney. By the Court, David Lopez Attorney for Plaintiff MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, P A 17013 , M~'~ 11- 1.5-0h Elizabeth Stone Attomey for Defendant STONE LAF AVER & SHEKLETSKI 414 Bridge Street New Cumberland, PA 17070 9-. J"u~~ , P s. P. (2. f? <f /h ,:JJ.s - II-IS' IJ<- I iij';l;l'l<,c~_.\.' "Y,'_ ," .,., " . . - I' ~ ~ : 1,';" 'f",:,~,,"~'l'!;~fili~'.dr';. "'-'- ' ~"-'cL","",:,~ " "'''~ ~~" """".~,~, ~ ,"-' u;:: ;~; '; "" ...,!;;..; ''.it I..... " CUi\"':[~.,i" ~'"/ , :_/~~,Ji'-~TY DI:~,H\1CJ\,'1 \/,~)\\~A I ~"" ''" 0.> liIIl~~~!,ltmllt~LWI!IJllI~nmI;!JMllJlfJ!lJ",~U~LJ I .0.. .~,~._., .,w~""'"'''' ,... "'" .~~ ~ "<"lut!''-Yo ~-i'i..f~~""'~- ~ w, J Jj < 11/15/02 FRI 11:47 FAX 717 240 6573 CUMS CO PROTHONOTARY 19J001 *************************** *** MULTI TN REPORT *** *************************** TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 3506 [ 01] 9p2490779 [ 03]9p2405331 [ 04]92438026 PSP CP LS ERROR OfFICE OF THE PROTHONOTARY cUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE. PA 17013 - 3387 (717) 24 0 - 6195 FAX (717) 240 - 6573 VIA TELECOPlER TO: PA STATE POLlCE - CENTRAL PROCESSING MIDPENN LEGAL SERVICES FAX # FROM: CURTIS R. LONG RE: FAXING A PFA MESSAGE: 4 NO. OF PAGES (INCLUDING COVER SHEETS) This message is intended for the use of the individual or entity to which it is addressed, and it may contain Information that is privileged, confidential and exempt from disclosure Ultder applicable law. If the reader of this nll:ssage is not the intended recipient, you are hereby notified mat any dissamination.. distribution or copying of this communication is strictly prohibited.lfyou have received this communication in error, please notify US immedial~Y br telephone and return the original message to uS at me above address via the -;"'''"''''cl,O'"''0~1!!'_f-i''i'-''"",".". " I'"~ ,1I!!IIIIi\!IIII.."".~,," ~~ ., .- -.- , ~, . ~ ~ I "' 'W';"~ 'l1' ~,' <",,<",,-, , ''', ~^ ~-~I"" " '. "-' """, ""-'-' -~-"">,. r ~~w.,"";"""< ,_. _ ,~~ ",,,",'p',_ "'~,:tI!''4i~~!1I1:\I<m<riii'0"'';'~~'W0'iWl''~~lIIl",.,.._J, ~~~jj;W~,'h,"";-i\"', ,', I 1\lll'jiir>'"l"t'iI''ti!'llH liar"!' IT''<;llIiii'r'l1'\'I''\!li'ii! f% M ';"''O'J''lP;'%~f~'~,'<<!f'l\.'Wji'lQl1:'~,~mll1!lli~lilll~@lf~!~~~'i''~.!1~ir!'"' ~ FEB 2 0 2003 " CAROL SUSAN PROUDFOOT, Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA v. : NO. 01-5907 CIVIL TERM GREGORY LEE PROUDFOOT, Movant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE ORDER AND NOW, this ~ d':' of February, 2003, IT IS HEREBY ORDERED AND DECREED that since this Court Vacated the Protection From Abuse, the Cumberland County Sheriff s Department is to release to the Movant, Gregory Lee Proudfoot, any and all firearms or other lawful objects that are currently being stored by the Sheriffs department pursuant to the now vacated Temporary Protection From Abuse. A certified copy ofthis Order shall be provided to the Cumberland County Sheriffs Department. By the Court . j:,:<y~,_ .,.,--', ,,~ -y"''''.. _ 'C"',''''',_., ",__,'..,:,','''' - ;'~lfl\ilil~.;;i~~:;""'i""'-" ,'" ,'- iWli.t1llib~~~i~.fu':' '" ," l1I",J;:k~$",iHililBjil<,'Bt'~&f:M;l,~~d"ii_""' ~... ii'" < 0 -1 ",," --'~," ,,"-~ Q~ Ci~: :':';,ttK~c . o~, "'o'.'TI~iR\1 .,' ,-./1\' i]'j 1'1 c, FI- i ,',', :"1 8' r,? " ,~ '-, \ ..... ':'\1 . '~1.. CUiVE:1EjjL/,i'i~j COUNTY PENNSYLVANIA . ~ "~If,'!(,\';[!W2!ilII!J ,', '( ,~I!liJi I1IliI m I M ,~ __ ,_d"""~~" ,,,',, ",_"..,l',,]l!!JJ..ITt~""""'''''''''' '",,~.'_~,,~ " < ~ -,,"-" ~ I:l ... ~~ L-1-3 ~:1 '1: ~ t 8cJ -\3 t J~~ , II F:\DOCS\PD\mot..proudfoot.retumgWls.wpd , ~ CAROL SUSAN PROUDFOOT, Respondent : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA FEU 0 2003 (.. v. : NO. 01-5907 CIVIL TERM GREGORY LEE PROUDFOOT, Movant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE MOTION FOR RETURN OF FIREARMS And now comes the Movant, by and through his attorneys, Stone LaFaver & Shekletski, and files this Motion For Return of Firearms averring as follows: 1. A Temporary Protection from Abuse Order was issued by this Court on October 11, 2001. 2. On or about November 14, 2002, Respondent through her counsel filed a petition requesting that the Temporary Protection From Abuse Order be Vacated and the action withdrawn without prejudice to her. 3. On November 15,2002, this Court issued an Order and Vacated the Temporary Protection From Abuse Order sigoed on October 11, 2001, and ordered that the action be withdrawn. 4. Since this Court vacated the Order, Movant now files this Motion asking that the Court order the Sheriff s department to release the firearms to Movant and pennit him to retrieve those firearms that he voluntarily handed over to the Cumberland County Sheriffs Department at the time of the issuance of the Temporary Protection from Abuse. WHEREFORE, Movant respectfully requests that this Court order that the Sheriffs department release Movant's firearms to him based upon the vacated order. / STONE LaF AVER &SHEKLETSKI - -----) ./ / .' j ! -1- . ""~J Carol Susan Proudfoot, Plaintiff vs. : CUMBERLAND COUNTY, P : NO. 01-5907 CIVIL TERM Gregory Lee Proudfoot, Defendant : PROTECTION FROM ABUSE ORDER OF COURT AND NOW, this /<;' 'f:' day of November, 2002, upon consideration of the ttached Petition, the Temporary Protection From Abuse Order in the above-captioned case en on October 11, A certified copy of this Order shall be provided to the Police Departm t by Plaintiffs 2001, is hereby vacated and the action withdrawn without prejudice to Plaintiff. attorney. By the Court, David Lopez Attorney for Plaintiff MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 Elizabeth Stone Attorney for Defendant STONE LAF AVER & SHEKLETSKI 414 Bridge Street New Cumberland, P A 17070 'r~~j~! {)::~'t~f ~;~. :~""'~'-/ :;';;~,~Z~.q~:O !'~ ': ":..:4;'.'~::-~7"'~'-"": ".' ". " :":: ,';":.. ~f"~ r,.H:',~ 'r:";' .~.~ ,.:,,:: ~..:,;:~:':~~.j~ ft. ;,..,., .ttt 'i"P'WI~Jl"o, ~ '1""- . "!'I ~~ ~.""''' '1~r"m~"""",p~",-.:" '.-1','.' 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