Loading...
HomeMy WebLinkAbout99-02897 (2) ;p 1 4 ref.. l < v + l? 1 60 O 1 Ira% 1. ^! Laura L. Druck, :IN THE COURT OF COMMON PLEAS Plaintiff :OF CUMBERLAND COUNTY,PENNSYLVANIA Vs. Shane B. Druck :NO. 99 - a2M CIVIL TERM Defendant :PROTECTION FROM ABUSE. AND CUSTODY NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on this matter is scheduled fo the 0?14.t' day of 1999, at __1z -,[_ f the Cumberland county Courthouse, Ca rrlisle, 1 Pennsylvania. You MUST obey the order that is attached until it is modified or terminated by the court after notice and hearing. If you disobey this order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six months in jail under 23 Pa.C.S. 56114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. 52265, 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. 52261-2262. 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 HELD. 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 conference or hearing. d' N H C ELI! }- 1'1L'-U O 0 Laura L. Druck, :IN THE COURT OF COMMON PLEAS Plaintiff VS. Shane B OF CUMBERLAND COUNTY,PENNSYLVANIA :NO. 99 - asgrl CIVIL TERM Druck, Defendant :PROTECTION FROM ABUSE :CUSTODY TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name: Shane B. Druck Defendant's Date of Birth: August 10, 1968 Defendant's Social Security Number: Not known Names of Protected Persons: Laura L. Druck; Courtney Elizabeth Druck, minor child; Alexandria Kathyrn Druck, minor child AND NOW, this 131 day of _ M e 7 , 1999, upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary order: CC 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. 0 2. Defendant is evicted and excluded from Plaintiff's residence located at , Cumberland County, Pennsylvania, (a residence which is jointly owned/leased by the parties; owned/leased by the entireties; owned/leased solely by Plaintiff /Defendant to which Plaintiff and the minor child/ren moved to avoid abuse, which is not owned or leased by the Defendant, or any other permanent or temporary residence where Plaintiff 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, except for the limited purpose of transferring custody of the parties' child/ren. Defendant shall remain in his vehicle at all times during the transfer of custody.) UY 3. Except for such contact with the minor children as may be permitted under Paragraph 5 of this order, Defendant is prohibited from having ANY CONTACT with Plaintiff at any 'r location, including, but not limited to any contact at Plaintiff's school, business, or place of employment. Defendant is specifically ordered to stay away from the following locations for the duration of this Order: Plaintiff 'a residence located at 211 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania, leased solely by Plaintiff to which Plaintiff and the minor child/ren moved to avoid abuse, which is not leased by Defendant, (and any other residence Plaintiff may establish), except for the limited purpose of transferring custody of the parties' children. Defendant shall remain in his vehicle at all times during the transfer of custody. CI.14. Defendant shall not contact Plaintiff by telephone or by any other means, including through third persons. L7 5. Pending the outcome of the final hearing in this matter. Plaintiff is awarded temporary custody of the following minor children: Courtney Elizabeth Druck Alexandria Kathyrn Druck Until the final hearing, all contact between Defendant and the children shall be limited to the following: No Contact until a hearing. The local law enforcement agency in the jurisdiction where the children are located shall ensure that the children are placed in the care and control of Plaintiff in accordance with the terms of this Order. ? 6. Defendant shall immediately relinquish the following weapons to the Sheriff's Office or a designated local law enforcement agency for the delivery to the Sheriff's Office: Defendant is prohibited from possessing, transferring or acquiring any other weapons for the duration of this Order. ® 7. The following additional relief is granted: The Cumberland County Sheriff's Department shall attempt to make service at Plaintiff's request and without pro-payment of fees, but service may be accomplished under any applicable Rule of Civil Procedure. This Order shall be docketed in the office of the ? s Prothonotary and forwarded to the Sheriff for service. The Prothonotary shall not sand a copy of this Order to Defendant by mail. Law enforcement agencies, human service agencies and school districts shall not disclose the presence of Plaintiff and/or the child/ran in the jurisdiction or district or furnish any address, telephone number, or any other demographic information about Plaintiff and/or child/ran except by further Order of Court. 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 finds that Defendant has committed another act of abuse or has engaged in a pattern or practice that indicates continued risk of harm to Plaintiff. Defendant is required to relinquish to the sheriff any firearm license Defendant may possess. Defendant's weapons and firearm license may be returned at the expiration of the Protection order after Defendant has submitted a written request to the Court for the return of the weapons and the Court has notified Plaintiff of the request and given Plaintiff an opportunity to respond. A copy of this Order shall be transmitted to the chief or head of the police department of (where Defendant resides) and the sheriff of (where Defendant resides) County. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. Defendant is to refrain from harassing Plaintiff's relatives (or the minor child/ren) FOR JUVENILE DEFENDANTS: In the event that an arrest is made, the arresting officer shall file a complaint with the JUVENILE COURT. The provisions relating to detention shall be addressed to the on-duty probation officer, and the matter shall be scheduled promptly for processing, adjudication and disposition with the judge scheduled to deal with juvenile ;matters. f tY1 9 A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency 4 + specified hereafter: ? 9. THIS ORDER SUPERSEDES ? ANY PRIOR PFA ORDER AND ? ANY PRIOR ORDER RELATING TO CHILD CUSTODY 10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO 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 i in jail. 23 Pa.C.S. §6114. Consent of 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, 16 U.S.C. §§ 2261-2262. Any protection order granted by a court may be considered in any subsequent proceedings, including child custody proceedings, under title 23 (Domestic Relations) of the Pennsylvania Consolidated Statutes. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over Plaintiff's residence OR any locations where a violation of this order occurs OR where Defendant may be located. If Defendant violates Paragraphs 1 through 6 of this Order, Defendant may be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence of law enforcement. ,q: Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriff's office of the county which issued this Order, which office shall maintain possession of the weapons until further order of this Court, unless the weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. BY THE COURT, W ud Karl E. Rominger Attorney for Plaintiff Laura L. Druck, Plaintiff VS. Shane B. Druck, Defendant :IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, PENNSYLVANIA :NO. 99 - Q-69,1' CIVIL TERM :PROTECTION FROM ABUSE :AND CUSTODY RETITION FOR PROTECTION FROM ABUSE 1. Plaintiff's name is Laura L. Druck. 2. This Petition is filed on behalf of Plaintiff, Laura L. Druck and Courtney Elizabeth Druck and Alexandria Kathryn Druck who are Plaintiff's minor children. 3. The names of all the persons, who seeks protection from abuse are Laura L. Druck; Courtney Elizabeth Druck, minor child; and Alexandria Kathryn Druck, minor child. 4. Plaintiff's address is 211 Plaza Drive, Boiling Springs, Pennsylvania 17077. 5. Defendant is believed to live at the following address: 25 N. Rockburn Street, York, Pennsylvania. Defendant's Social Security Number is unknown. Defendant's date of birth is August 10, 1968. Defendant's place of employment is Stambaugh's Auto .ales, 1636 W. Market Street, York, Pennsylvania. Defendant is 30 years old or younger. 6. Defendant is Plaintiff's husband. 7. Plaintiff and Defendant have been involved in the following court actions for divorce: Case name Case no, Die filed Court Druck v. Druck 99 SU 02003-02D 4/28/99 York County Court of Common Pleas 1 C Ib 8. Plaintiff seeks temporary custody of the following children: Name Aiddress Birth tea Courtney Elizabeth Druck 211 Plaza Drive 8/5/90 Boiling Springs, PA Alexandria Kathryn Druck 211 Plaza Drive 5/4/95 Boiling Springs, PA 9. Plaintiff and Defendant are the parents of the following minor children: Names Aces Address Courtney Elizabeth Druck 8 211 Plaza Drive Boiling Springs, PA Alexandria Kathryn Druck 4 211 Plaza Drive Boiling Springs, PA 10. There is NOT an existing Court Order regarding custody of the parties' children. The following information is provided in support of Plaintiff's request for an Order of child custody: (a) The children were not born out of wedlock. (b) The children are presently in the custody of Plaintiff, who resides at 211 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania. (c) During the past five years since their births the children have resided with the following persons and at the following addresses: Name Address Dates Laura L. Druck 6720 Old Carlisle Road, Dover, PA 5/26/92 - 915/92 Shane B. Druck Laura L. Druck 2773 Pineview Drive, York, PA 915/92 - 6/14/97 Laura L. Druck 3106 Wooster Drive, Dover, PA 1011/97 - 7/98 Shane B. Druck Laura L. Druck 40 Shippensburg Road, East Berlin, PA 7/98 - 2/99 Shane B. Druck Laura L. Druck 211 Plaza Drive, Boiling Springs, PA 2/99 - present 2 (d) Plaintiff, the mother of the children, is, currently residing at, 211 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania. (e) She is married. (f) Plaintiff currently resides with the following person/s: Name N/A Relationship (g) Defendant, the father of the children, is, currently residing at 25 N. Rockburn Street, York, York County, Pennsylvania. (h) He is married. (i) Defendant currently resides with the following persons: Name Rolationshin Kimberly Snider Girlfriend (j) Plaintiff has not previously participated in any litigation concerning custody of the above mentioned children in this or any other court. (k) Plaintiff has no knowledge of any custody proceedings concerning there children pending before a court in this or any other jurisdiction. (1) Plaintiff does not know any person not a party to this action who has physical custody of the children or claims to have custody or visitation rights with respect to the children. (m) The best interests and permanent welfare of the minor children will be met if custody is temporarily granted to Plaintiff pending a hearing in this matter for reasons including: (1) Plaintiff is a responsible parent who has provided for the emotional and physical needs of the children since their births, and who can best take care of the minor children. (2) Defendant has shown by his abuse of Plaintiff that he is not an appropriate role model for the minor children. 3 (3) Defendant's behavior has adversely affected the children. (4) Defendant has forcibly removed the children from the plaintiff on various occasions. 11. The facts of the most recent incident of abuse are as follows: On or about February 11, 1999, Defendant refused to let Plaintiff into marital home. Defendant ex_ted the marital home with above mentioned children and stated that Plaintiff could not take the minor children. When Plaintiff stated that she was taking minor children, Defendant then grabbed Plaintiff and began to hit her on the head with his fist over and over again, causing Plaintiff to fall into one of the children. Both minor children witnessed the incident and were screaming and crying. Plaintiff sustained bruises on her chin and head. 12. Defendant has committed the following prior acts of abuse against Plaintiff or the minor children: a. February, March, April and May of 1999 has made harassing and threatening phone calls to Plaintiff's residence and employment several times weekly. b. April of 1999 indicated to Plaintiff that he wish Plaintiff would die. C. April of 1999 indicated to Plaintiff that he would bash her face in if she were on the other side of the door. d. April of 1999 used foul and abusive language concerning Plaintiff in the presence of their minor children. 13. The following police departments or law enforcement agency in the area in which Plaintiff lives should be provided with a copy of the Protection Order: Pennsylvania State Police Department. 14. There is an immediate and present danger of further abuse from the Defendant. 15. Defendant owes a duty of support to Plaintiff and the minor children. 4 ( . WHEREFORE, PLAINTIFF REQUESTS ORDER, AND AFTER HEARING, A FINAL FOLLOWING: THAT THE COURT ENTER A TEMPORARY ORDER THAT WOULD DO THE A. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or minor child in any place where Plaintiff may be found. B: Order Defendant to stay away from Plaintiff's residence and prohibit Defendant from attempting to enter any temporary or permanent residence of Plaintiff. C. Prohibit Defendant from having any contact with Plaintiff and/or minor children, 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 find necessary with respect to partial custody and/or visitation with the minor children. D. Prohibit Defendant from having any contact with Plaintiff's relatives and Plaintiff's children listed in this Petition, except as the court may find necessary with respect to partial custody and/or visitation with the minor children. E. Order Defendant to pay temporary support for Plaintiff and/or the minor children, including medical support and payment of the rent or mortgage on the residence. F. Order Defendant to pay the costs of this action, including filing fees, service fees, and surcharge of $25.00. G. Order Defendant to pay $250.00 to reimburse one The Law Offices of Paul Bradford Orr's funding sources for the cost of litigation in this case. H. Order the following additional relief, not listed above: b. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. C. Defendant is to refrain from harassing Plaintiff's relatives. 5 I. Grant such other relief as the court deems appropriate. Order the police or other law enforcement agency to serve Defendant with a copy of this Petition, any order issued, and the Order for Hearing. Plaintiff will inform the designated authority of any addresses, other than Defendant's residence, where Defendant can be served. 6 COUNT II CUSTODY UNDER PENNSYLVANIA CUSTODY LAW 16. The allegations of Count I above are incorporated herein as if fully set forth. 17. The best interest and permanent welfare of the minor children will be served by confirming custody in Plaintiff as set forth in paragraph #6 of the petition. WHEREFORE, pursuant to 23 Pa.C.S.§ 5301 t. Sea., and other applicable rules and law, Plaintiff prays this Honorable Court to award temporary custody of the minor children to her. Plaintiff prays for such other relief as may be just and proper. Respectfully submitted, arl E. Rominger Attorney for Plaintiff 50 East High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court :D# 81924 Dated: . 61/:Y q q Imo! . :. .: Previous Image Refilmed to Correct Possible Error VERIFICATION I verify that I am the Plaintiff 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: 5- 13 qq n1AAA- \, 1 )? Laura L. Druck LZ UN L'? V LAURA L. DRUCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. 99-2897 CIVIL TERM SHANE B. DRUCK, Defendant PROTECTION FROM ABUSE AND CUSTODY IN RE: AGREEMENT REACHED ORDER OF COURT AND NOW, this 21st day of May, 1999, upon consideration of the Plaintiff's Petition for Protection from Abuse, and an agreement having been reached in open court among the parties and their counsel, Karl E. Rominger, Esquire, and Robert D. Glessner, Esquire, the agreement will be reduced to writing and submitted to the Court for entry as two orders, one dealing with protection from abuse and the other dealing with custody. Pending receipt and entry of the proposed orders, the matter is taken under advisement and the Temporary Protection from Abuse order shall remain in full force and effect. The Plaintiff shall pay the standard filing fee for filing the petition. Karl E. Rominger, Esquire Law Offices of Paul B. Orr 78 West Pomfret Street Carlisle, PA 17013 Counsel for Plaintiff Robert D. Glessner, Esquire Law Offices of Allen H. Smith 45 North Duke Street York, PA 17401-1601 Counsel for Defendant :srs ??`NA'LlSM; : By the Court, SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-02897 P COMMONWCALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DRUCK LAURA L VS. DRUCK SHANE B R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: DRUCK SHANE B but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania. to serve the within PROTECTION FROM ABUSE On. May 20th, 1999 , this office was in receipt of the attached return from YORK County, Pennsylvania Sheriff's Costs: So answers:// Docketing 18.00 Out of County 9.00 f ? Surcharge 8.00 X1. iliolllcit? , Dep. York Cc 34.50 Q 05/20/1999 Sworn and subscribed to before me this .2. ?'-r' day of 2Lell- 19A.D. 0 41 , , _.. . . ?7 COUNTY OF YORK ® `?4 rl `y OFFICE OF THE SHERIFF 5(17)77 9601E 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE INSTRUCT`ONS PROCESS RECEIPT, and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LINES 1 TO 12 DO NOT DETACH ANY.COPIES. , Laura L. Druck 4. TYPE OF WRIT OR COMPLAINT 3. DEFENDANT/S/ Not of Hrg & Order, Temp. Shane B. Druck Protection from Ahusr- SERVE S. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. Shane B. Druck, PERSONAL 6. ADDRESS (STREET RFD WITH BOX NUMBER, APT NO., CITY BOR , iWP., STATE AND ZIP 7. INDICATE SERVICE: XXPERSONAL O PERSON IN CHARGE tf DEPUTIZE rttA4FMT-F11 I4nfl GIST CLASS MAIL OPOSTED 0OTHER NOW 19 _ I, SHERIFF OF VIOR QiCOUNTY, PA, he y depuWe?10gf COUNTY to execute this d o f u to law. Thi s deputation bernnl g made et the request and risk of the plaintiff. PG 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: Cumberland POE: Stambaugh's Auto Sales Q. 1636 W. Market St C'. York, PA 17401 -.4 ci t nR. Hearing Date: 5/21/99 ©' ??rp ?.J I_'sa T rn C NOTE ONLY APPLICABLE ON WRIT OF EXECUTION; N.B. WAIVER OF WATCHMAN • Any deputy Sheriff levying upon a attaching any property under coin writ maple came wittaut a watchman, In wslody of whomever is found in possession, alter notifying person of levy or attachment, without liability on the pail dl such depulifla the 6 any plaintiff herein for any loss, destruction, or removal of any property before sheriffs cats thereof. 1:_1 _ S V3 to Cumberland County Sheriff 13.1 acknowledge receipt of the writ SIGNATURE OF AUTHORIZED CLERK 14. Data Receivetl 79aMeeang Date or oomplelet as indicated above. B. FeeseC 5/14/99 5/21/99 @ 9:30 J 16. MOW SERVED: PERSONAL RESIDENCE( ) POSTED( ) POE ( ) SHERIFFS OFF ( ) OTHER ( ) SEE REMARKS 17. hereby tartly and return a NOT FOUND becausa I em unable to bate the individual, company, corporation, etc, named above. (See remarks below.) 27. /'3mA/Y1 e'Milas Int. 34. Forelgn County Coats l 35. Advena COW 136. Ssrvko Casts 137. Notary Con. 138. Mileage/Postage/N.F. f as. hots, cwts 140, cost Due or Kerns 41.AFFIRMED4nd1ib..t pjltlil?jlll???.r?wcn 42.61yof 48 ?? M T Sproturo el Y Dale 11 43 / V,/, y?+9011T WILLIAM M. HOSE. SHERIFF 5/19/99 .1 L.? LAURA Je DRUCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW SHANE B. DRUCK, 1` cm ` 285`+ NO.29--Vr CIVIL TERM Defendant : IN CUSTODY STIPULATION REGARDING CUSTODY-VISITATION L Plaintiff Laura W. Druck, hereinafter referenced as mother, and Defendant, Shane B. Druck, hereinafter referred to as father, hereby agree to the entry of the following terms in a Court Order defining custody and partial custody rights and responsibilities in relation to the parties' minor children: Courtney Elizabeth Druck, bom August 5, 1990, and Alexandria Kathryn Druck, born May _4,,;9.95, hereinafter referenced as Children: (1) Shared legal custody of Courtney Druck and Alexandria Druck as contemplated by the Act of November 5, 1984, P.S. § 1001, et seq., is awarded to Mother and Father. (2) Physical custody of the Children, Courtney Druck and Alexandria Druck, is awarded to mother subject to partial custody by father as follows which he is directed to exercise: (a) On alternate weekends commencing May 11, 2001, from 5:00 o'clock p.m. Friday until Sunday at 7:00 o'clock p.m. (b) On the following holidays on an alternating basis beginning January 1, 2001, from 9:00 o'clock a.m. until 9:00 o'clock p.m. each day: New Year's Day, Memorial.Day, July 4th, Labor Day, Thanksgiving, and Christmas Day. (c) Each Father's Day and Mother's Day from 9:00 a.m. to 7:00 p.m. (d) For an extended two week vacation each year with father to provide at least one (1) LAURA L. DRUCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW SHANE B. DRUCK, : NO. 2 CIVIL TERM Defendant : IN CUSTODY ORDER AND NOW, this 15s 1 day of 7u n 2001, in consideration of the attached Stipulation Regarding Custody and Visitation, it is hereby ordered that: (1) Shared legal custody of Courtney Dtuck and Alexandria Dmck as contemplated by the Act of November 5, 1984, P.S. § 1001, et seq., is awarded to Mother and Father. (2) Physical custody of the Children, Courtney Druck and Alexandria Druck, is awarded to mother subject to partial custody by father as follows which he is directed to exercise: (a) On alternate weekends commencing May 11, 2001, from 5:00 o'clock p.m. Friday until Sunday at 7:00 o'clock p.m. (b) On the following holidays on an alternating basis beginning January 1, 2001, from 9:00 o'clock am. until 9:00 o'clock p.m. each day: New Year's Day, Memorial Day, July 4", Labor Day, Thanksgiving, and Christmas Day. (c) Each Father's Day and Mother's Day from 9:00 a.m. to 7:00 p.m. (d) For an extended two week vacation each year with father to provide at least one (1) month's notice of the desired time for the vacation. A1l4M/nj 5?NN3 dflo go:? (e) Such other times as the parties may mutually agree. (3) Father shall provide transportation for the children to and from each instance of visitation unless otherwise noted herein. BY THE COURT: 0 LAURA L. DRUCK, Plaintiff V. CIVIL ACTION - LAW SHANE B. DRUCK, Defendant NO. 99-2897 CIVIL TERM ORDER OF COURT AND NOW, this 24`" day of February, 2003, upon consideration of Defendant's Petition for Change of Jurisdiction, a Rule is hereby issued upon Plaintiff to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, Laura L. Shanafelter (Druck) 121 S. 4a' Street Newport, PA 17074 Plaintiff, Pro Se Barbara L. Wevodau, Esq. 26 East Main Street P.O. Box 459 New Bloomfield, PA 17068 Attorney for Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :rc ??ia:?il????C?'';I??:,1 r? i '1 ?L idd I'L c.l? ?0 1 .n n?J... ?... ?.? •. i.. ...1 LAURA L. DRUCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW V. NO. 1999-2897 CIVIL TERM SHANE B. DRUCK, IN CUSTODY Defendant ORDER AND NOW this day of 2003, it is hereby ORDERED and DIRECTED that the Defendant's Petition for Change of Jurisdiction is hereby GRANTED. BY THE COURT: J. LAURA L. DRUCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW V. NO. 1999-2897 CIVIL, TERM SHANE B. DRUCK, IN CUSTODY Defendant AND NOW comes Defendant, Shane B. Duck, by and through his counsel, Barbara L. Wevodau, Esq,, to petition this Honorable Court for a change in jurisdiction pursuant to Title 23 Sections 5341-5344 and Defendant offers the following in support thereof. Plaintiff, Laura L. Druck, now married and known as, Laura L. Shanafelter, is the natural mother of the minor children and currently resides at 121 S. a Street, Newport, Perry County, Pennsylvania.. 2• Defendant, Shane B. Druck, is the natural father of the minor children and currently resides at 1270 Greenwood Road, York, York County, Pennsylvania. 3. The attached Custody Stipulation was made an Order of Court dated June 18, 2001 whereby PlaintftMother was awarded primary physical custody of the minor children.(See Attached Exhibit "X). 4. The minor children are Courtney Druck, born August 5, 1990 and Alexandria Druck, boar May 4, 1995 . 5. The minor children are currently residing in Newport, Perry County for over six (6) months. 6. Defendant avers that it is in the best interest of the minor children for the Court of Common Pleas of the 41 'Judicial District, Perry County to assume jurisdiction of the custody case because Peery County has been the home county of the children for more than six months and the children have a significant connection with Perry County as their home county. WHEREFORE, Father/Defendant respectfully requests that this Honorable Court grant a transfer of Jurisdiction to the Court of Common Pleas for the 41" Judicial District, Perry County. Respectfully Submitted, deb Attorney for Defendant Barbara L. Wevodau, Esq. Supreme ID # 85673 26 East Main Street P.O. Box 459 New Bloomfield, PA 17068 (717) 582-8883 LAURA L. DRUCK, Plaintiff V. SHANE B, DRUCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. 1999-2897 CIVIL TERM IN CUSTODY I verify that the statements in the attached PETITION FOR CHANGE OF JURISDICTION are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsification to authorities, DATE: Z - // - 0 3 6 ShaneShane ckck LAURA L. DRUCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW SHANE B. DRUCK, `?`1?- a89? ?.v t NO. 28--9:7- CIVIL TERM Defendant : IN CUSTODY ORDER AND NOW, this 4 day of Su J, 2001, in consideration of the attached Stipulation Regarding Custody and Visitation, it is hereby ordered that: (1) Shared legal custody of Courtney Druck and Alexandria Druck as contemplated by the Act of November 5, 1984, P.S. §1001, et seq., is awarded to Mother and Father. (2) Physical custody of the Children, Courtney Druck and Alexandria Druck, is awarded to mother subject to partial custody by father as follows which he is directed to exercise: (a) On alternate weekends commencing May 11, 2001, from 5:00 o'clock p.m. Friday until Sunday at 7:00 o'clock p.m. (b) On the following holidays on an alternating basis beginning January 1, 2001, from 9:00 o'clock a.m. until 9:00 o'clock p.m. each day: New Year's Day, Memorial Day, July 4i°, Labor Day, Thanksgiving, and Christmas Day. (c) Each Father's Day and Mother's Day from 9:00 a.m. to 7:00 p.m. (d) For an extended two week vacation each year with father to provide at least one (1) month's notice of the desired time for the vacation. f (e) Such other times as the parties may mutually agree. (3) Father shall provide transportation for the children to and from each instance of visitation unless otherwise noted herein. BY THE COURT: q vv t ?•Iq L. LAURA V. DRUCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW e SHANE B. DRUCK, (IDA - 28q`+ NO.29 =?97- CIVIL TERM Defendant : IN CUSTODY STIPULATION REGARDING CUSTODY-VISITATION L Plaintiff, Laura B: Druck, hereinafter referenced as mother, and Defendant, Shane B. Druck, hereinafter referred to as father, hereby agree to the entry of the following terms in a Court Order defining custody and partial custody rights and responsibilities in relation to the parties' minor children: Courtney Elizabeth Druck, born August 5, 1990, and Alexandria Kathryn Druck, bom May 1995, hereinafter referenced as Children: (1) Shared legal custody of Courtney Druck and Alexandria Druck as contemplated by the Act of November 5, 1984, P.S. § 1001, et seq., is awarded to Mother and Father. (2) Physical custody of the Children, Courtney Druck and Alexandria Dmek, is awarded to mother subject to partial custody by father as follows which he is directed to exercise: (a) On alternate weekends commencing May 11, 2001, from 5:00 o'clock p.m. Friday until Sunday at 7:00 o'clock p.m. (b) On the following holidays on an alternating basis beginning January 1, 2001, from 9:00 o'clock a.m. until 9:00 o'clock p.m. each day: New Year's Day, Memorial Day, July 4th, labor Day, Thanksgiving, and Christmas Day. (c) Each Father's Day and Mother's Day from 9:00 a.m. to 7:00 p.m. (d) For an extended two week vacation each year with father to provide at least one (1) t. , month's notice of the desired time for the vacation. (e) Such other times as the parties may mutually agree. (3) Father shall provide transportation for the children to and from each instance of visitation unless otherwise noted herein. ? ? lZtUs? ??,??r Karl E. Rominger, Esq. Laura B: Druck, Plaintiff' i ` Attorney for Plaintiff U i Robert D. Glessner, Esq. Shane B. Druck, Defendant i'. Attorney for Defendant LAURA L.DRUCK, Plaintiff V. SHANE B. DRUCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. 1999-2897 CIVIL TERM IN CUSTODY CERTIFICATE OF SERVICE 1, Barbara L. Wevodau, Esquire, hereby certify that, on this date, a true and correct copy of the foregoing Petition for Change of Venue was served upon Laura L. Druck, Plaintiff in the above-captioned by mailing a copy of said Petition from the New Bloomfield Post Office via first class mail postage prepaid to the following address: Laura L. Shanafelter (Druck) 121 S. 4i6 Street Newport, PA 17074 Date: A- . n Attorney for Plaintiff Barbara L. Wevodau, Esq. Supreme Court ID# 85673 P.O, Box 264 New Bloomfield, PA 17068 (7I7)582-8883 r AMERICANS WITH DISABILITIES ACT OF 1990 The Perry County Branch of the Court of Common Pleas for the 41" Judicial District 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 my 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. P? U) L. r-j v ?? ?1 C.i V LAURA L. DRUCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW SHANE B. DRUCK, Defendant NO. 99-2897 CIVIL TERM ORDER OF COURT AND NOW, this 25a' day of April, 2003, upon consideration of the attached letter from Barbara L. Wevodau, Esq., attorney for Defendant, this matter is hereby transferred to the Court of Common Pleas of Perry County. Any court costs associated with the transfer shall be borne by Defendant. ,E'aura L. Shanafelter (Druck) 121 S. 4'" Street Newport, PA 17074 Plaintiff, Pro Se ,41arbara L. Wevodau, Esq. 26 East Main Street P.O. Box 459 New Bloomfield, PA 17068 Attorney for Defendant BY THE COURT, , W (A C/ " //- - t Wesley r., J. ar?Aw oq-A-63 :rc VINVAIASNN3d Gu :z 14J 6Z 6dv CO J-D JJi:_??•:1-1i -7-:77-7- Barbara Wevodau, Esquire Attorney At Law 26 E. Main Street, PO Box 459 New Bloomfield, PA 17068 Phone. (717)582-4335 Fax. (717)582-7697 April 24, 2003 Honorable J. Wesley Oler, Jr. Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013 Re: Druck v, Druck No. 99 - 2897 Dear Judge Oler, On February 24, 2003, this Honorable Court issued a rule to show cause why relief requested should not be granted to Defendant. No response has been received to date. W. Druck respectfully requests that the above-captioned case be transferred to the Court of Common Pleas in Perry County, Thank you for your consideration of this request. Sincerely'', c A arara Wevodau, Esq. B W/mm cc: Mr, Druck Curtis R. Long Pmthonowry Rcncc K. Simpson Dmuly Prothnnutnry John E. Slike Solicitor (Office of toe Protoonotarp Ctimberlanb Countp LOum Court of Common Pleas S Cumberland County, Pennsylvania Dane. 6 ' Q(vc'k- Docket No. Qq _ OQ10 I Please acknowledge receipt of this case by signing and dating this document. Please send this back to: PROTHONOTARY OFFICE CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 17013 ° Attn: Becky Record received: °' Date: - ?q U 3 O - CD (signature & title) a }}}}}}{{ ¢¢rr. +11+,? ` C* Courthouse Square • Carlisle Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573 "Ti Ya.i4 A h t ?. •, iL _ ?_ ? _ - a:.. ? I t ` ?,. I i -a'r •- t !:. :~ Y 4 Laura L. Druck, VS. Shane B. Druck :IN THE COURT OF COMMON PLEAS Plaintiff :OF CUMBERLAND COUNTY,PENNSYLVANIA :NO. 99 - awn CIVIL TERM Defendant :PROTECTION FRO14 ABUSE AND CUSTODY NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on this matter is scheduled for the a14,t- day of y? , 1999, at q,-30 4_m., in Courtroom No. of the Cumberland County Courthouse, Carlisle, Pennsylvania. You MUST obey the Order that is attached until it is modified or terminated by the court after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six months in jail under 23 Pa.C.S. §6114. 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, 13 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 HELD. 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 conference or hearing. ec ; , fy Lt- 0 m U Laura L. Druck, :IN THE COURT OF COMMON PLEAS Plaintiff :OF CUMBERLAND COUNTY,PENNSYLVANIA VS. Shane B. Druck, Defendant :NO. 99 - p'?Qrl CIVIL TERM :PROTECTION FROM ABUSE :CUSTODY TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name: Shane B. Druck Defendant's Date of Birth: August 10, 1968 Defendant's Social Security Number: Not known Names of Protected Persons: Laura L. Druck; Courtney Elizabeth Druck, minor child; Alexandria Kathyrn Druck, minor child AND NOW, this ( 31`' day of me , 1999, upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: X 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 evicted and excluded from Plaintiff's residence located at , Cumberland County, Pennsylvania, (a residence which is jointly owned/leased by the parties; owned/leased by the entireties; owned/leased solely by Plaintiff/Defendant to which Plaintiff and the minor child/ren moved to avoid abuse, which is not owned or leased by the Defendant, or any other permanent or temporary residence where Plaintiff 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, except for the limited purpose of transferring custody of the parties' child/ren. Defendant shall remain in his vehicle at all times during the transfer of custody.) 1:0 3. Except for such contact with the minor children as may be permitted under Paragraph 5 of this Order, Defendant is prohibited from having ANY CONTACT with Plaintiff at any location, including, but not limited to any contact at Plaintiff's school, business, or place of employment. Defendant is specifically ordered to stay away from the following locations for the duration of this Order: Plaintiff's residence located at 211 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania, leased solely by Plaintiff to which Plaintiff and the minor child/ren moved to avoid abuse, which is not leased by Defendant, (and any other residence Plaintiff may establish), except for the limited purpose of transferring custody of the parties' children. Defendant shall remain in his vehicle at all times during the transfer of custody. rl 4. Defendant shall not contact Plaintiff: by telephone or by any other means, including through third persons. 1:. 5. Pending the outcome of the final hearing in this matter. Plaintiff is awarded temporary custody of the following minor children: Courtney Elizabeth Druck Alexandria Kathyrn Druck Until the final hearing, all contact between Defendant and the children shall be limited to the following: No Contact until a hearing. The local law enforcement agency in the jurisdiction where the children are located shall ensure that the children are placed in the care and control of Plaintiff in accordance with the terms of this Order. ? 6. Defendant shall immediately relinquish the following weapons to the Sheriff's Office or a designated local law enforcement agency for the delivery to the Sheriff's Office: Defendant is prohibited from possessing, transferring or acquiring any other weapons for the duration of this Order. ® 7. The following additional relief is granted: The Cumberland County Sheriff's Department shall attempt to make service at Plaintiff's request and without pre-payment of fees, but service may be accomplished under any applicable Rule of Civil Procedure. This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service. The Prothonotary shall not send a copy of this Order to Defendant by mail. Law enforcement agencies, human service agencies and school districts shall not disclose the presence of Plaintiff and/or the child/ren in the jurisdiction or district or furnish any address, telephone number, or any other demographic information about Plaintiff and/or child/ren except by further Order of Court. 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 finds that Defendant has committed another act of abuse or has engaged in a pattern or practice that indicates continued risk of harm to Plaintiff. Defendant is required to relinquish to the sheriff any firearm license Defendant may possess. Defendant's weapons and firearm license may be returned at the expiration of the Protection Order after Defendant has submitted a written request to the Court for the return of the weapons and the Court has notified Plaintiff of the request and given Plaintiff an opportunity to respond. A copy of this Order shall be transmitted to the chief or head of the police department of (where Defendant resides) and the sheriff of (where Defendant resides) County. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. Defendant is to refrain from harassing Plaintiff's relatives (or the minor child/ren) FOR JUVENILE DEFENDANTS: In the event that an arrest is made, the arresting officer shall file a complaint with the JUVENILE COURT. The provisions relating to detention shall be addressed to the on-duty probation officer, and the matter shall be scheduled promptly for processing, adjudication and disposition with the judge scheduled to deal with juvenile matters. 4 A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: ? 9. THIS ORDER SUPERSEDES ? ANY PRIOR PFA ORDER AND ? ANY PRIOR ORDER RELATING TO CHILD CUSTODY 10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and./or up to six months in jail. 23 Pa.C.S. §6114. Consent of Plaintiff to Defendant's return to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. §6113. Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. §§ 2261-2262. Any protection order granted by a court may be considered in any subsequent proceedings, including child custody proceedings, under title 23 (Domestic Relations) of the Pennsylvania Consolidated. Statutes. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over Plaintiff's residence OR any locations where a violation of this order occurs OR where Defendant may be located. If Defendant violates Paragraphs 1 through 6 of this Order, Defendant may be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence of law enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriff's office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this Court, unless the weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. BY THE COURT, G? J ud Karl E. Rominger Attorney for Plaintiff Laura L. Druck, :IN THE COURT OF COMMON PLEAS Plaintiff :OF CUMBERLAND COUNTY PENNSYLVANIA VS. NO. 99 - agC? tj CIVIL TERM Shane B. Druck, Defendant :PROTECTION FROM ABUSE :AND CUSTODY PETITION FOR PROTECTION FROM ABUSE 1. Plaintiff's name is Laura L. Druck. 2. This Petition is filed on behalf of Plaintiff, Laura L. Druck and Courtney Elizabeth Druck and Alexandria Kathryn Druck who are Plaintiff's minor children. 3. The names of all the persons, who seeks protection from abuse are Laura L. Druck; Courtney Elizabeth Druck, minor child; and Alexandria Kathryn Druck, minor child. 4. Plaintiff's address is 211 Plaza Drive, Boiling Springs, Pennsylvania 17077. 5. Defendant is believed to live at the following address: 25 N. Rockburn Street, York, Pennsylvania. Defendant's Social Security Number is unknown. Defendant's date of birth is August 10, 1968. Defendant's place of employment is Stambaugh's Auto Sales, 1636 W. Market Street, York, Pennsylvania. Defendant is 30 years old or younger. 6. Defendant is Plaintiff's husband. 7. Plaintiff and Defendant have been involved in the following court actions for divorce: Case name Case no. Date filed Court Druck v. Druck 99 SU 02003-02D 4/28/99 York County Court of Common Pleas 1 8. Plaintiff seeks temporary custody of the following children: Name Address Birthdates Courtney Elizabeth Druck 211 Plaza Drive 8/5/90 Boiling Springs, PA Alexandria Kathryn Druck 211 Plaza Drive 5/4/95 Boiling Springs, PA 9. Plaintiff and Defendant are the parents of the following minor children: Names Ages Address Courtney Elizabeth Druck 8 211 Plaza Drive Boiling Springs, PA Alexandria Kathryn Druck 4 211 Plaza Drive Boiling Springs, PA 10. There is NOT an existing Court Order regarding custody of the parties' children. The following information is provided in support of Plaintiff's request for an Order of child custody: (a) The children were not born out of wedlock. (b) The children are presently in the custody of Plaintiff, who resides at 211 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania. (c) During the past five years since their births the children have resided with the following persons and at the following addresses: Name Address Dates Laura L. Druck 6720 Old Carlisle Road, Dover., PA 5/26/92 - 9/5/92 Shane B. Druck Laura L. Druck 2773 Pineview Drive, York, PA 9/5/92 - 6/14/97 Laura L. Druck 3106 Wooster Drive, Dover, PA 10/1/97 - 7/98 Shane B. Druck Laura L. Druck 40 Shippensburg Road, East Berlin, PA 7/98 - 2/99 Shane B. Druck Laura L. Druck 211 Plaza Drive, Boiling Springs, PA 2/99 - present 2 (d) Plaintiff, the mother of the children, is, currently residing at, 211 Plaza Drive, Boiling Springs, Cumberland County, Pennsylvania. (e) She is married. (f) Plaintiff currently resides with the following person/s: Name N/A Relationship (g) Defendant, the father of the children, is, currently residing at 25 N. Rockburn Street, York, York County, Pennsylvania. (h) He is married. (i) Defendant currently resides with the following persons: Name Kimberly Snider Relationship Girlfriend (j) Plaintiff has not previously participated in any litigation concerning custody of the above mentioned children in this or any other Court. (k) Plaintiff has no knowledge of any custody proceedings concerning there children pending before a court in this or any other jurisdiction. (1) Plaintiff does not know any person not a party to this action who has physical custody of the children or claims to have custody or visitation rights with respect to the children. (m) The best interests and permanent welfare of the minor children will be met if custody is temporarily granted to Plaintiff pending a hearing in this matter for reasons including: (1) Plaintiff is a responsible parent who has provided for the emotional and physical needs of the children since their births, and who can best take care of the minor children. (2) Defendant has shown by his abuse of Plaintiff that he is not an appropriate role model for the minor children. 3 (3) Defendant's behavior has adversely affected the children. (4) Defendant has forcibly removed the children from the plaintiff on various occasions. 11. The facts of the most recent incident of abuse are as follows: On or about February 11, 1999, Defendant refused to let Plaintiff into marital home. Defendant ex:_ted the marital home with above mentioned children and stated that Plaintiff could not take the minor children. When Plaintiff stated that she was taking minor children, Defendant then grabbed Plaintiff and began to hit her on the head with his fist over and over again, causing Plaintiff to fall into one of the children., Both minor children witnessed the incident and were screaming and crying. Plaintiff sustained bruises on her chin and head. 12. Defendant has committed the following prior acts of abuse against Plaintiff or the minor children: a. February, March, April and May of 1999 has made harassing and threatening phone calls to Plaintiff's residence and employment several times weekly. b. April of 1999 indicated to Plaintiff that he wish Plaintiff would die. c. April of 1999 indicated to Plaintiff that he would bash her face in if she were on the other side of the door. d. April of 1999 used foul and abusive language concerning Plaintiff in the presence of their minor children. 13. The following police departments or law enforcement agency in the area in which Plaintiff lives should be provided with a copy of the Protection Order: Pennsylvania State Police Department. 14. There is an immediate and present danger of further abuse from the Defendant. 15. Defendant owes a duty of support to Plaintiff and the minor children. 4 WHEREFORE, PLAINTIFF REQUESTS 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 in any place where Plaintiff may be found. B. Order Defendant to stay away from Plaintiff's residence and prohibit Defendant from attempting to enter any temporary or permanent residence of Plaintiff. C. Prohibit Defendant from having any contract with Plaintiff and/or minor children, 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 find necessary with respect to partial custody and/or visitation with the minor children. D. Prohibit Defendant from having any contract with Plaintiff's relatives and Plaintiff's children listed in this Petition, except as the court may find necessary with respect to partial custody and/or visitation with the minor children. E. Order Defendant to pay temporary support for Plaintiff and/or the minor children, including medical support and payment of the rent or mortgage on the residence. F. Order Defendant to pay the costs of this action, including filing fees, service fees, and surcharge of $25.00. G. Order Defendant to pay $250.00 to reimburse one The Law Offices of Paul Bradford Orr's funding sources for the cost of litigation in this case. H. Order the following additional relief, not listed above: b. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. C. Defendant is to refrain from harassing Plaintiff's relatives. 5 I. Grant such other relief as the court deems appropriate. Order the police or other law enforcement agency to serve Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. Plaintiff will inform the designated authority of any addresses, other than Defendant's residence, where Defendant can be served. 6 COUNT II CUSTODY UNDER PENNSYLVANIA CUSTODY LAW 16. The allegations of Count I above are incorporated herein as if fully set forth. 17. The best interest and permanent welfare of the minor children will be served by confirming custody in Plaintiff as set forth in paragraph #8 of the petition. WHEREFORE, pursuant to 23 Pa.C.S.§ 5301 et. Sec., and other applicable rules and law, Plaintiff prays this Honorable Court to award temporary custody of the minor children to her. Plaintiff prays for such other relief as may be just and proper. Respectfully submitted, s t G arl E. Rominger Attorney for Plaintiff 50 East High Street Carlisle, PA :_7013 (717) 258-8558 Supreme Court =:D# 81924 Dated: 2/3/g J 1-7 VERIFICATION I verify that I am the Plaintiff 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. D a t e d: 5 3- OVI ` C1 i s (` tom-- Laura L. Druck ?- _ ' ? -n - .., - s? ?. ? , ? ? i, n ?.. i ?? `=1. ?1 ? _ •. ? - y ? -G C J < LAURA L. DRUCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. 99-2897 CIVIL, TERM SHANE B. DRUCK, Defendant PROTECTION FROM ABUSE AND CUSTODY IN RE: AGREEMENT REACHED ORDER OF COURT AND NOW, this 21st day of May, 1999, upon consideration of the Plaintiff's Petition for Protection from Abuse, and an agreement having been reached in open court among the parties and their counsel, Karl E. Rominger, Esquire, and Robert D. Glessner, Esquire, the agreement: will be reduced to writing and submitted to the Court for entry as two orders, one dealing with protection from abuse and the other dealing with custody. Pending receipt and entry of the proposed orders, the matter is taken under advisement and the Temporary Protection from Abuse Order shall remain in full force and effect. The Plaintiff shall pay the standard filing fee for filing the petition. Karl E. Rominger, Esquire Law Offices of Paul B. Orr 78 West Pomfret Street Carlisle, PA 17013 Counsel for Plaintiff A6 9 Robert D. Glessner, Esquire Law Offices of Allen H. Smith 45 North Duke Street York, PA 17401-1601 Counsel for Defendant ?i'isv?l llS?l U . )3 Clti114'lL . . n -7 :srs By the Court, SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-02897 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DRUCK LAURA L VS. DRUCK SHANE B R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: DRUCK SHANE B but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of YORK County, Pennsylvania. to serve the within PROTECTION FROM ABUSE On May 20th, 1999 this office was in receipt of the attached return from YORK County, Pennsylvania. Sheriff's Costs: So answers: Docketing 18.00 Out of County 9.00 Surcharge 8.00 omas eri Dep. York Co 34.50 05/20/1999 Sworn and subscribed to before me this .2,o day of 19192_ A.D. ro ono y 07 COUNTY OF YORK OFFICE OF THE SHERIFF S(17)I7719 01L 28 EAST MARKET ST., YORK, PA 17401 SHERIFF SERVICE INSTRUCTIONS PROCESS RECEIPT, and AFFIDAVIT OF RETURN PLEASE TYPE ONLY LINES 1 TO 12 DO NOT DETACH ANY COPIES. 1. PLAINTIFF/S/ 2. COURT NUMBER 99-2897 C i V i Laura L. Druck 4. TYPE OF WRIT OR COMPLAINT 3. ULI-t_NUANI/S/ Not of Hrg & Order, Temp. Shane B. Druck Pro ion from Abuse SERVE 5. NAME OF INDIVIDUAL, COMPANY, CORPORATION, ETC. TO SERVE OR DESCRIPTION OF PROPERTY TO BE LEVIED, ATTACHED, OR SOLD. Shane B. Druck, PERSONAL W 6. ADDRESS (STREET OR RFD WITH BOX NUMBER, APT NO., CITY, BORO, TWP., STATE AND ZIP CODE AT 25 N. Rockburn St, York, PA 17401 7. INDICATE SERVICE: XXPERSONAL ? PERSON IN CHARGE M DEPUTIZE C t iAWRI-1(LNIj d ? 1ST CLASS MAIL ? POSTED ? OTHER NOW 5/13/9-9 19 I, SHERIFF OF 11100INCOUNTY, PA, d her y deputize t of Yep'-k COUNTY to execute this a re u her e rtdird,?ig to law. This deputation being made at the request and risk of the plaintiff. SHERIFF OF OUNTY 8. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEDITING SERVICE: Cumberland POE: Stambaugh's Auto Sales W- __° w 1636 W. Market St York, PA 17401 r Hearing Date: 5/21/99 NOTE ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying upon or attaching any property under Sin writ ma? same without a watchman, in custody of whomever is found in possession, after notifying person of levy or attachment, without liability on the paft of such depu%or the s any plaintiff herein for any loss, destruction, or removal of any property before sheriff's sale thereof. 9. TYPE NAME AND ADDRESS of ATTORNEY/ORIGINATOR and SIGNATURE 10. TELEPH NE N 1BER DATE QED Paul Bradford Orr, Esq. T1 50 East High Street, Carlisle, PA 17013 17-258-8556 5/13/99 12. SEND NOTICE OF SERVICE COPY TO NAME AND ADDRESS BELOW: (This area must be completed if notice is to be mailed). Cumberland County Sheriff SPACE BELOW FOR USE OF THE SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE 13. 1 acknowledge receipt of the writ SIGNATURE OF AUTHORIZED CLERK 14. Date Received 1 5/Hearing Date or complaint as indicated above. B. Feeser 5/14/99 5/21/99 @ 9:30 AM 16.HOW SERVED: PERSONAL RESIDENCE ( ) POSTED( ) POE ( ) SHERIFF'S OFF ( ) OTHER ( ) SEE REMARKS 17. 1 hereby certify and return a NOT FOUND because I am unable to locate the individual, company, corporation, etc, named above. (See remarks below.) NAME AND J????''E OF INDIVID "L SEED /LIST ADDRESS HERE ?IF?N`OO?T SHOWN ABOVE Relationship to Defend nt 19. Date of Service 20. Time of Service X 9??L,tr .'??/ L _?',s?7'7/ °i!?` i ?De??i????? / Via/ 21. ATTE Date Time Miles Int. Date Time Miles MCI Date I Timel Miles l Int. I Date l Time I Miles l Int. I Date I Time Miles i Int. I Date ! Time 'Miles Int. 22. REMARKS: Service Costs 25. N/F 26. Mileage 27. Postage 28. Sub Total 29. Pound 30. Notary Fee 31 32. Total Co tSl 33. Cost Due or 34. Foreign County Costs 135. Advance Costs 136. Service Costs 37. Notary Cert. 138. Mileage/Postage/N.F 139. Total Costs 140. Cost Due or Refund 41. AFFIRMED 42. day of 1 _ _ MaWity of York, 43. 44. Signature of 47. Date _ De p. Sheriff " 45. Signature of Y 48. Date County Sheriff WILLIAM M. HOSE, SHERIFF 5/19/99 46. Signature of Foreign 49. Date ?" r- r? ,? - ,.t ?4 ? ? +? w ? ; ?-?? ,, , l1 LAURA B'. DRUCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW SHANE B. DRUCK, : NO.29-79 - CIVIL: TERM Defendant : IN CUSTODY STIPULATION REGARDING CUSTODY-VISITATION L Plaintiff, Laura W. Druck, hereinafter referenced as mother, and Defendant, Shane B. Druck, hereinafter referred to as father, hereby agree to the entry of the following terms in a Court Order defining custody and partial custody rights and responsibilities in relation to the parties' minor children: Courtney Elizabeth Druck, born August 5, 1990, and Alexandria Kathryn Druck, bom May 4, 1995, hereinafter referenced as Children: (1) Shared legal custody of Courtney Druck and Alexandria Druck as contemplated by the Act of November 5, 1984, P.S. § 1001, et seq., is awarded to Mother and Father. (2) Physical custody of the Children, Courtney Druck and Alexandria Druck, is awarded to mother subject to partial custody by father as follows which he is directed to exercise: (a) On alternate weekends commencing May 11, 2001, fi-om 5:00 o'clock p.m. Friday until Sunday at 7:00 o'clock p.m. (b) On the following holidays on an alternating basis beginning January 1, 2001, from 9:00 o'clock a.m. until 9:00 o'clock p.m. each day: New Year's Day, Memorial Day, July 4th, Labor Day, Thanksgiving, and Christmas Day. (c) Each Father's Day and Mother's Day from 9:00 a.m. to 7:00 p.m. (d) For an extended two week vacation each year with father to provide at least one (1) LAURA L. DRUCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW SHANE B. DRUCK, : NO. 2$--9-7? CIVIL TERM Defendant : IN CUSTODY ORDER AND NOW, this I cZ7 K day of 7u :r), c , 2001, in consideration of the attached Stipulation Regarding Custody and Visitation, it is hereby ordered that: (1) Shared legal custody of Courtney Druck and Alexandria Druck as contemplated by the Act of November 5, 1984, P. S. § 1001, et seq., is awarded to Mother and Father. (2) Physical custody of the Children, Courtney Druck and Alexandria Druck, is awarded to mother subject to partial custody by father as follows which he is directed to exercise: (a) On alternate weekends commencing May 11, 2001, from 5:00 o'clock p.m. Friday until Sunday at 7:00 o'clock p.m. (b) On the following holidays on an alternating basis beginning January 1, 2001, from 9:00 o'clock a.m. until 9:00 o'clock p.m. each day: New Year's Day, Memorial Day, July 4', Labor Day, Thanksgiving, and Christmas Day. (c) Each Father's Day and Mother's Day from 9:00 a.m. to 7:00 p.m. (d) For an extended two week vacation each year with father to provide at least one (1) month's notice of the desired time for the vacation. e b1NV iJA3,NN3d Ail- (e) Such other times as the parties may mutually agree. (3) Father shall provide transportation for the children to and from each instance of visitation unless otherwise noted herein. BY THE COURT: C? qol LAURA L. DRUCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW SHANE B. DRUCK, Defendant NO. 99-2897 CIVIL TERM ORDER OF COURT AND NOW, this 24th day of February, 2003, upon consideration of Defendant's Petition for Change of Jurisdiction, a Rule is hereby issued upon Plaintiff to show cause why the relief requested should not be granted. RULE RETURNABLE within 20 days of service. BY THE COURT, Laura L. Shanafelter (Druck) 121 S. 4' Street Newport, PA 17074 Plaintiff, Pro Se Barbara L. Wevodau, Esq. 26 East Main Street P.O. Box 459 New Bloomfield, PA 17068 Attorney for Defendant 03 :rc eta LAURA L. DRUCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW V. NO. 1999-2897 CIVIL, TERM SHANE B. DRUCK, IN CUSTODY Defendant ORDER AND NOW this day of 2003, it is hereby ORDERED and DIRECTED that the Defendant's Petition for Change of Jurisdiction is hereby GRANTED, BY THE COURT: J. LAURA L. DRUCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW V. NO. 1999-2897 CIVIL TERM SHANE B. DRUCK, IN CUSTODY Defendant PETITION FOR SHOE OFD ICTION AND NOW comes Defendant, Shane B. Druck, by and through his counsel, Barbara L. Wevodau, Esq., to petition this Honorable Court for a change in jurisdiction pursuant to Title 23 Sections 5341-5344 and Defendant offers the following in support thereof Plaintiff, Laura L. Druck, now married and known as, Laura L. Shanafelter, is the natural mother of the minor children and currently resides at 1211 S. 0 Street, Newport, Perry County, Pennsylvania.. 2. Defendant, Shane B. Druck, is the natural father of the minor children and currently resides at 1270 Greenwood Road, York, York County, Pennsylvania. 3. The attached Custody Stipulation was made an Order of Court dated June 18, 2001 whereby PlaintifWother was awarded primary physical custody of the minor children. (See Attached Exhibit IN). 4. The minor children are Courtney Druck, born August 5, 1990 and Alexandria Druck, born May 4, 1995 . 5. The minor children are currently residing in Newport, Perry County for over six (6) months. 6. Defendant avers that it is in the best interest of the minor children for the Court of Common Pleas of the 41g Judicial District, Perry County to assume jurisdiction of the custody case because Perry County has been the home county of the children for more than six months and the children have a significant connection with Perry County as their home county. WHEREFORE, Father/Defendant respectfully requests that this Honorable Court grant a transfer of Jurisdiction to the Court of Common Pleas for the 41' Judicial District, Perry County. Respectfully Submitted, Feb i?;?3 /Attorney for Defendant Barbara L. Wevodau, Esq. Supreme ID # 85673 26 East Main Street P.O. Box 459 New Bloomfield, PA 17068 (717) 582-8883 LAURA L. DRUCK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW V. NO. 1999-2897 CIVIL TERM SHANE B. DRUCK, IN CUSTODY Defendant 1 verify that the statements in the attached PETITION FOR CHANGE OF JURISDICTION are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 4904 relating to unworn falsification to authorities. 'Ile DATE: Z - / / - 0 3 --?? Z. / - Shane Druck LAURA L. DRUCK, V. Plaintiff SHANE B. DRUCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW - Jgl NO. 2 CIVIL TERM IN CUSTODY ORDER AND NOW, this __ 1 ( day of ?? C 2001, in consideration of the attached Stipulation Regarding Custody and Visitation, it is hereby ordered that: (1) Shared legal custody of Courtney Druck and Alexandria Druck as contemplated by the Act of November 5, 1984, P.S. § 1001, et seq., is awarded to Mother and Father. (2) Physical custody of the Children, Courtney Druck and Alexandria Druck, is awarded to mother subject to partial custody by father as follows which he is directed to exercise: (a) On alternate weekends commencing May 11, 2001, from 5:00 o'clock p.m. Friday until Sunday at 7:00 o'clock p.m. (b) On the following holidays on an alternating basis beginning January 1, 2001, from 9:00 o'clock a.m. until 9:00 o'clock p.m. each day: New Year's Day, Memorial Day, July 4`h, Labor Day, Thanksgiving, and Christmas Day. (c) Each Father's Day and Mother's Day from 9:00 a.m. to 7:00 p.m. (d) For an extended two week vacation each year with father to provide at least one (1) month's notice of the desired time for the vacation. i (e) Such other times as the parties may mutually agree. (3) Father shall provide transportation for the children to and from each instance of visitation t> unless otherwise noted herein. BY THE COURT: zvcl 4L)4 ?q .ol pL ? LAURA B: DRUCK, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : CIVIL ACTION - LAW SHANE B. DRUCK, : NO. 2F-797- CIVIL, TERM Defendant : IN CUSTODY STIPULATION REGARDING CUSTODY-'VISITATION L Plaintiff, Laura R. Druck, hereinafter referenced as mother, and Defendant, Shane B. Druck, hereinafter referred to as father, hereby agree to the entry of the following terms in a Court Order defining custody and partial custody rights and responsibilities in relation to the parties' minor children: Courtney Elizabeth Druck, born August 5, 1990, and Alexandria Kathryn Druck, born May 4, 1995, hereinafter referenced as Children: (1) Shared legal custody of Courtney Druck and Alexandria Druck as contemplated by the Act of November 5, 1984, P.S. §1001, et seq., is awarded to Mother and Father. (2) Physical custody of the Children, Courtney Druck and Alexandria Druck, is awarded to mother subject to partial custody by father as follows which he is directed to exercise: (a) On alternate weekends commencing May 11, 2001, from 5:00 o'clock p.m. Friday until Sunday at 7:00 o'clock p.m. (b) On the following holidays on an alternating basis beginning January 1, 2001, from 9:00 o'clock a.m. until 9:00 o'clock p.m. each day: New Year's Day, Memorial Day, July 4th, Labor Day, Thanksgiving, and Christmas Day. (c) Each Father's Day and Mother's Day from 9:00 a.m. to 7:00 p.m. (d) For an extended two week vacation each year with father to provide at least one (1) month's notice of the desired time for the vacation. (e) Such other times as the parties may mutually agree. (3) Father shall provide transportation for the children to and from each instance of visitation unless otherwise noted herein. Jam. Karl E. Rominger, Esq. Attorney for Plaintiff Robert DCGIIIessner, Esq. Attorney for Defendant 1- k?Lki Laura B: Druck, Plaintiff L r Shane B. Druck, Defendant LAURA L. DRUCK, Plaintiff V. SHANE B. DRUCK, ; Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW NO. 1999-2897 CIVIL TERM IN CUSTODY CERTIFICATE OF SERVICE 1, Barbara L. Wevodau, Esquire, hereby certify that, on this date, a true and correct copy of the foregoing Petition for Change of Venue was served upon Laura L. Druck, Plaintiff in the above-captioned by mailing a copy of said Petition from the New Bloomfield Post Office via first class mail postage prepaid to the following address: Laura L. Shanafelter (Druck) 121 S. 4* Street Newport, PA 17074 r Date: j- ?-a3 Attorney for tl) Plaintiff Barbara L. Wevodau, Esq. Supreme Court IDS 85673 P.O. Box 264 New Bloomfield, PA 17068 (717) 582-8883 AMERICANS WITH DISABILITIES ACT OF 1990 The Perry County Branch of the Court of Common Pleas for the 41" Judicial District 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 my 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. C'7 ?- -. LL _ ?--^ r?; ; ;_.? ??,, r-' ?- .. ; ,; ?'- ? ? ,. ??. _a ,_ -- -. _?: LAURA L. DRUCK, Plaintiff V. SHANE B. DRUCK, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-2897 CIVIL TERM ORDER OF COURT AND NOW, this 25`x' day of April, 2003, upon consideration of the attached letter from Barbara L. Wevodau, Esq., attorney for Defendant, this matter is hereby transferred to the Court of Common Pleas of Perry County. Any court costs associated with the transfer shall be borne by Defendant. BY THE COURT, a L. Shanafelter (Druck) 121 S. 4th Street Newport, PA 17074 Plaintiff, Pro Se Vilarbara L. Wevodau, Esq. 26 East Main Street P.O. Box 459 New Bloomfield, PA 17068 Attorney for Defendant Wesley r., J. RK? o q 29 -ct3 :rc VIN'VAI,'Ng, N *qd s c u :z 14 d 6 ? d'V IC0 Barbara Wevodau, Esquire Attorney At Law 26 E. Main Street, PO Box 459 New Bloomfield, PA 17068 Phone. (717)582-4335 Fax: (717):582-7697 April 24, 2003 Honorable J. Wesley Oler, Jr. Cumberland County Courthouse 1 Courthouse Square Carlisle, PA 17013 Re: Druck v. Druck No. 99 - 2897 Dear Judge Oler, On February 24, 2003, this Honorable Court issued a rule to show cause why relief requested should not be granted to Defendant. No response has been received to date. Mr. Druck respectfully requests that the above-captioned case be transferred to the Court of Common Pleas in Perry County. Thank you for your consideration of this request. Sincerely, ?- Barbara Wevodau, Esq. B Wlmm P, cc: Mr. Druck