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HomeMy WebLinkAbout99-07172 . l rI Nli: l Ol. 17 2 1? Ji 1'F 'Y?[?,y tLwmerar+mwiwnnn,? ' J1•"? . ,?y ry:R? tc^<.? h?.A-'.'.r•KN..1'... NS.4i r.. _4.:..awi?r?,.. incr??•...rra "J? S?? ! u' '? Q•41 i. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, ) Petitioner ) V. ) JAMES M. GOODYEAR, JR., ) Respondent ) NO. 1999-7172 CIVIL CIVIL ACTION - LAW PROTECTION FROM ABUSE RULE TO SHOW CAUSE AND NOW, this day of 2000, upon consideration of Plaintiff Lisa A. Goodyear's Petition for Return of Property, a Rule is hereby entered upon Defendant James M. Goodyear, Jr. to show cause, if any he has, why the relief requested should not be granted. Rule returnable in writing within fifteen (15) days from the date of service hereof. BY THE COURT: J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, Petitioner ) V. ) NO. 1999-7172 CIVIL JAMES M. GOODYEAR, JR., ) CIVIL ACTION - LAW Respondent ) PROTECTION FROM ABUSE ORDER AND NOW, this day of , 2000, upon consideration of Plaintiff Lisa A. Goodyear's Petition for Return of Property, it is hereby ORDERED and DECREED that Plaintiff's property shall be immediately returned to her. BY THE COURT: J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, Petitioner ) V. ) NO. 1999-7172 CIVIL JAMES M. GOODYEAR, JR., ) CIVIL ACTION - LAW Respondent ) PROTECTION FROM ABUSE PETITION FOR RETURN OF PROPERTY AND NOW comes Petitioner, Lisa A. Goodyear, by and through her counsel, Hewett, Kissinger & Conley, P.C., who hereby files this Petition for Return of Property, and states as follows: A Temporary Protection From Abuse Order was entered by the Honorable J. Wesley Oler, Jr. on November 29, 1999 which stated that all guns were to be removed from Petitioner's property. 2. It was the intent of this order to keep these weapons out of Respondent's reach. 3. Two of the weapons, a Ruger model 270 ultralight hunting rifle and a Browning A-bolt hunting rifle, did not belong to Respondent and, in fact, belong to Petitioner and her brother. WHEREFORE, Petitioner, Lisa A. Goodyear, hereby requests this Honorable Court to issue an order for the return of her property. Date: 7 ?r v Respectfully submitted, Donald T. Kissinger, Esquire HOWETT, KISSINGER & CO LEY, P.C. 130 Walnut Street / P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff Lisa A. Goodyear j IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, Petitioner ) V. ) NO. 1999-7172 CIVIL JAMES M. GOODYEAR, JR., ) CIVIL ACTION - LAW Defendant ) PROTECTION FROM ABUSE CERTIFICATE OF SERVICE I, Donald T. Kissinger, Esquire, counsel for Lisa A. Goodyear, Plaintiff in the above- captioned action, hereby certify that a true and correct copy of the foregoing Petition for Return of Property was served upon Michael A. Scherer, Esquire, counsel for James M. Goodyear, Jr., by depositing same in the United States mail, first class, on August 15, 2000 addressed as follows: Michael A. Scherer, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 Dale: J Donald T. Kissinger, Esquire V HOWETT, KISSINGER & CONLEY, P.C. 130 Walnut Street / P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff Lisa A. Goodyear r, J - 7 U W 'fO II O C a ?? (fit a C* COD CL: C T ~ V d C r _ d co NO N r Y ?s Eoeir? e Y "1 ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, ) Petitioner ) V. ) NO. 1999-7172 CIVIL JAMES M. GOODYEAR, JR., ) CIVIL ACTION - LAW Respondent ) PROTECTION FROM ABUSE RULE TO SHOW CAUSE AND NOW, this day of 2000, upon consideration of Plaintiff Lisa A. Goodyear's Petition for Return of Property, a Rule is hereby entered upon Defendant James M. Goodyear, Jr. to show cause, if any he has, why the relief requested should not be granted. Rule returnable in writing within fifteen (15) days from the date of service hereof. BY THE COURT: J. H 1_; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, Petitioner ) V. ) NO. 1999-7172 CIVIL JAMES M. GOODYEAR, JR., ) CIVIL ACTION - LAW Respondent ) PROTECTION FROM ABUSE ORDER AND NOW, this day of , 2000, upon consideration of Plaintiff Lisa A. Goodyear's Petition for Return of Property, it is hereby ORDERED and DECREED that Plaintiff's property shall be immediately retumed to her. BY THE COURT: J. U.- IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, ) Petitioner ) V. ) NO. 1999-7172 CIVIL JAMES M. GOODYEAR, JR., ) CIVIL ACTION- LAW Respondent ) PROTECTION FROM ABUSE n o r? PETITION FOR RETURN OF PROPERTY AND NOW comes Petitioner, Lisa A. Goodyear, by and through her counsel;_'tioweti,, cC., I1,' Kissinger & Conley, P.C., who hereby files this Petition for Return of Property, andsta_tes as : yJ CJ :a ;ern follows: _ cb 1. A Temporary Protection From Abuse Order was entered by the Honorable J. Wesley Oler, Jr. on November 29, 1999 which stated that all guns were to be removed from Petitioner's property. 2. It was the intent of this order to keep these weapons out of Respondent's reach. 3. Two of the weapons, a Ruger model 270 ultralight hunting rifle and a Browning A-bolt hunting rifle, did not belong to Respondent and, in fact, belong to Petitioner and her brother. WHEREFORE, Petitioner, Lisa A. Goodyear, hereby requests this Honorable Court to issue an order for the return of her property. Respectfully submitted, Date: 7 ??_v t 41 Donald T. Kissinger, Esquire HOWETT, KISSINGER & C i EY, P.C. 130 Walnut Street / P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff Lisa A. Goodyear IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, ) Petitioner ) V. ) JAMES M. GOODYEAR, JR., ) Defendant ) NO. 1999-7172 CIVIL CIVIL ACTION- LAW PROTECTION FROM ABUSE CERTIFICATE OF SERVICE I, Donald T. Kissinger, Esquire, counsel for Lisa A. Goodyear, Plaintiff in the above- captioned action, hereby certify that a true and correct copy of the foregoing Petition for Return of Property was served upon Michael A. Scherer, Esquire, counsel for James M. Goodyear, Jr., by depositing same in the United States mail, first class, on August 15, 2000 addressed as follows: Michael A. Scherer, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 Date: Donald T. Kissinger, Esquire V HOWETT, KISSINGER & CONLEY, P.C. 130 Walnut Street/ P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff Lisa A. Goodyear r_. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, ) Petitioner ) V. ) JAMES M. GOODYEAR, JR., ) Respondent ) NO, 1999-7172 CIVIL CIVIL ACTION - LAW PROTECTION FROM ABUSE RULE TO SHOW CAUSE AND NOW, this day of 2000, upon consideration of Plaintiff Lisa A. Goodyear's Petition for Retum of Property, a Rule is hereby entered upon Defendant James M. Goodyear, Jr. to show cause, if any he has, why the relief requested should not be granted. Rule returnable in writing within fifteen (15) days from the date of service hereof. BY THE COURT: J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, Petitioner ) V. ) NO. 1999-7172 CIVIL JAMES M. GOODYEAR, JR., ) CIVIL ACTION - LAW Respondent ) PROTECTION FROM ABUSE ORDER AND NOW, this day of 2000, upon consideration of Plaintiff Lisa A. Goodyear's Petition for Return of Property, it is hereby ORDERED and DECREED that Plaintiffs property shall be immediately returned to her. BY THE COURT: J. rN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, Petitioner ) V. ) NO. 1999-7172 CIVIL JAMES M. GOODYEAR, JR., ) CIVIL ACTION- LAW Respondent ) PROTECTION FROM ABUSE PETITION FOR RETURN OF PROPERTY AND NOW comes Petitioner, Lisa A. Goodyear, by and through her counsel, Howett, Kissinger & Conley, P.C., who hereby files this Petition for Return of Property, and states as follows: 1. A Temporary Protection From Abuse Order was entered by the Honorable J. Wesley Oler, Jr. on November 29, 1999 which stated that all guns were to be removed from Petitioner's property. 2. It was the intent of this order to keep these weapons out of Respondent's reach. 3. Two of the weapons, a Ruger model 270 ultralight hunting rifle and a Browning A-bolt hunting rifle, did not belong to Respondent and, in fact, belong to Petitioner and her brother. WHEREFORE, Petitioner, Lisa A. Goodyear, hereby requests this Honorable Court to issue an order for the return of her property. Date: 0 Respectfully submitted, Donald T. Kissinger, Esquire HOWETT, KISSINGER & C EY, P.C. 130 Walnut Street / P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff Lisa A. Goodyear IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, Petitioner ) V. ) NO. 1999-7172 CIVIL JAMES M. GOODYEAR, JR., ) CIVIL ACTION - LAW Defendant ) PROTECTION FROM ABUSE CERTIFICATE OF SERVICE I, Donald T. Kissinger, Esquire, counsel for Lisa A. Goodyear, Plaintiff in the above- captioned action, hereby certify that a true and correct copy of the foregoing Petition for Return of Property was served upon Michael A. Scherer, Esquire, counsel for James M. Goodyear, Jr., by depositing same in the United States mail, first class, on August 15, 2000 addressed as follows: Michael A. Scherer, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 ?'ls' o 0 Date: Donald T. Kissinger, Esquire V HOWETT, KISSINGER & CONLEY, P.C. 130 Walnut Street / P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff Lisa A. Goodyear IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, ) Petitioner ) V. ) JAMES M. GOODYEAR, JR., ) Respondent ) NO. 1999-7172 CIVIL CIVIL ACTION - LAW PROTECTION FROM ABUSE RULE TO SHOW CAUSE AND NOW, this day of 2000, upon consideration of Plaintiff Lisa A. Goodyear's Petition for Return of Property, a Rule is hereby entered upon Defendant James M. Goodyear, Jr. to show cause, if any he has, why the relief requested should not be granted. Rule returnable in writing within fifteen (15) days from the date of service hereof. BY THE COURT: J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, ) Petitioner ) V. ) JAMES M. GOODYEAR, JR., ) Respondent ) NO. 1999-7172 CIVIL CIVIL ACTION - LAW PROTECTION FROM ABUSE ORDER AND NOW, this day of , 2000, upon consideration of Plaintiff Lisa A. Goodyear's Petition for Return of Property, it is hereby ORDERED and DECREED that Plaintiffs property shall be immediately returned to her. BY THE COURT: J. IK r' M THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, ) Petitioner ) V. ) NO. 1999-7172 CIVIL JAMES M. GOODYEAR, JR., ) CIVIL ACTION - LAW Respondent ) PROTECTION FROM ABUSE PETITION FOR RETURN OF PROPERTY AND NOW comes Petitioner, Lisa A. Goodyear, by and through her counsel, Howett, Kissinger & Conley, P.C., who hereby files this Petition for Return of Property, and states as follows: A Temporary Protection From Abuse Order was entered by the Honorable J. Wesley Oler, Jr. on November 29, 1999 which stated that all guns were to be removed from Petitioner's property. 2. It was the intent of this order to keep these weapons out of Respondent's reach. Two of the weapons, a Ruger model 270 ultralight hunting rifle and a Browning A-bolt hunting rifle, did not belong to Respondent and, in fact, belong to Petitioner and her brother. WHEREFORE, Petitioner, Lisa A. Goodyear, hereby requests this Honorable Court to issue an order for the return of her property. Date: Respectfully submitted, Donald T. Kissinger, Esquire HOWETT, KISSINGER & C EY, P.C. 130 Walnut Street / P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff Lisa A. Goodyear IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, Petitioner ) V. ) NO. 1999-7172 CIVIL JAMES M. GOODYEAR, JR., ) CIVIL ACTION - LAW Defendant ) PROTECTION FROM ABUSE CERTIFICATE OF SERVICE I, Donald T. Kissinger, Esquire, counsel for Lisa A. Goodyear, Plaintiff in the above- captioned action, hereby certify that a true and correct copy of the foregoing Petition for Return of Property was served upon Michael A. Scherer, Esquire, counsel for James M. Goodyear, Jr., by depositing same in the United States mail, first class, on August 15, 2000 addressed as follows: Michael A. Scherer, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 Date: o C O O Donald T. Kissinger, Esquire V HOWETT, KISSINGER & CONLEY, P.C. 130 Walnut Street/ P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff Lisa A. Goodyear IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, ) Petitioner ) V. ) JAMES M. GOODYEAR, JR., ) Respondent NO. 1999-7172 CIVIL CIVIL ACTION - LAW PROTECTION FROM ABUSE RULE, TO SHOW CAUSE AND NOW, this I? t-? day of 2000, upon consideration of Petitioner Lisa A. Goodyear's Amended Petition for Return of Property, a Rule is hereby entered upon Respondent, James M. Goodyear, Jr., to show cause, if any, why the relief requested should not be granted. Said Rule is returnable in writing within fifteen (15) days from the date of service hereof. R?? -i V? _'.. ,?. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, Petitioner ) NO. 1999-7172 CIVIL V. ) CIVIL ACTION - LAW JAMES M. GOODYEAR, JR., ) PROTECTION FROM ABUSE Respondent ORDER AND NOW, this day of , 2000, upon consideration of Petitioner Lisa A. Goodyear's Amended Petition for Return of Property, it is hereby ORDERED, and DECREED that Petitioner's property shall be immediately returned. BY THE COURT: r J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, ) Petitioner ) NO. 1999-7172 CIVIL V. ) CIVIL ACTION - LAW JAMES M. GOODYEAR, JR., ) PROTECTION FROM ABUSE Respondent AMENDED PETITION FOR RETURN OF PROPERTY AND NOW, comes Petitioner, Lisa A. Goodyear, by and through her counsel, Howett, Kissinger & Conley, P.C., who hereby files this Amended Petition for Return of Property and in support thereof avers as follows: 1. On or about August 15, 2000, Petitioner filed with the court a Petition for Return of Property, which sought the return of two weapons confiscated after the court entered a Temporary Protection from Abuse Order against Respondent. The Petition is incorporated by reference as if set forth at length herein and is attached hereto as Exhibit "A." 2. Though the two weapons rightfully belong to Petitioner and her brother, and not Respondent, and the intent of the Temporary PFA Order was to keep said weapons out of Respondent's reach, mysteriously, Respondent opposes the return of said weapons to Petitioner. -f i 'r WHEREFORE, Petitioner, Lisa A. Goodyear, hereby requests this Ilonorable Court grant her Amended Petition for Return of Property and issue an order for the return of the property identified herein. Date: Respectfully sulimittetl, Donald T. Kissinger, Esqu r HOWETT, KISSINGER & ONLEY, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Petitioner, Lisa A. Goodyear M I' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, Petitioner ) NO. 1999-7172 CIVIL V. ) CIVIL ACTION - LAW JAMES M. GOODYEAR, JR., ) PROTECTION FROM ABUSE Respondent CERTIFICATE OF SERVICE 1, Donald T. Kissinger, Esquire, counsel for Lisa A. Goodyear, Petitioner in the above- captioned action, hereby certify that a true and correct copy of the foregoing Amended Petition for Return of Property was served upon Michael A. Scherer, Esquire, counsel for James M. Goodyear, Jr., Respondent, by depositing same in the United States mail, first class, on September 29, 2000, addressed as follows: Michael A. Scherer, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 Date: f z/ 13d Donald T. Kissinger, Esqu HOWETT, KISSINGER & CONLEY, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Telephone: 717-234-2616 Counsel for Petitioner, Lisa A. Goodyear IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, ) Petitioner ) V. ) JAMES M. GOODYEAR, JR., ) Respondent ) RULE TO SHOW CAUSE AND NOW, this day of NO. 1999-7172 CIVIL CIVIL ACTION - LAW PROTECTION FROM ABUSE 2000, upon consideration of Plaintiff Lisa A. Goodyear's Petition for Return of Property, a Rule is hereby entered upon Defendant Jaynes M. Goodyear, Jr, to show cause, if any he has, why the relief requested should not be granted. Rule returnable in writing within fifteen (15) days from the date of service hereof. BY THE COURT: J. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, ) Petitioner ) V. ) NO, 1999-7172 CIVIL JAMES M. GOODYEAR, JR., ) CIVIL ACTION - LAW Respondent ) PROTECTION FROM ABUSE ORDER AND NOW, this day of 2000, upon consideration of Plaintiff Lisa A. Goodyear's Petition for Return of Property, it is hereby ORDERED and DECREED that Plaintiffs property shall be immediately returned to her. BY THE COURT: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, ) Petitioner ) V. ) NO. 1999-7172 CIVIL JAMES M. GOODYEAR, JR., ) CIVIL ACTION - LAW Respondent ) PROTECTION FROM ABUSE PETITION FOR RETURN OF PROPERTY AND NOW comes Petitioner, Lisa A. Goodyear, by and through her counsel, Howett, Kissinger & Conley, P.C., who hereby files this Petition for Return of Property, and states as follows: A Temporary Protection From Abuse Order was entered by the Honorable J. Wesley Oler, Jr. on November 29, 1999 which stated that all guns were to be removed from Petitioner's property. 2. It was the intent of this order to keep these weapons out of Respondent's reach. Two of the weapons, a Ruger model 270 ultralight hunting rifle and a Browning A-bolt hunting rifle, did not belong to Respondent and, in fact, belong to Petitioner and her brother. WHEREFORE, Petitioner, Lisa A. Goodyear, hereby requests this Honorable Court to issue an order for the return of her property. Respectfully submitted, Date: ?3?2v Donald T. Kissinger, Esquire HOWETT, KISSINGER & C EY, P.C. 130 Walnut Street / P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff Lisa A. Goodyear IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, Petitioner ) V. ) NO. 1999-7172 CIVIL JAMES M. GOODYEAR, JR., ) CIVIL ACTION - LAW Defendant ) PROTECTION FROM ABUSE CERTIFICATE OF SERVICE I, Donald T. Kissinger, Esquire, counsel for Lisa A. Goodyear, Plaintiff in the above- captioned action, hereby certify that a true and correct copy of the foregoing Petition for Return of Property was served upon Michael A. Scherer, Esquire, counsel for James NI. Goodyear, Jr., by depositing same in the United States mail, first class, on August 15, 2000 addressed as follows: Michael A. Scherer, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 Date: Donald T. Kissinger, Esquire HOWETT, KISS NIGER & CONLEY, P.C. 130 Walnut Street / P.O. Box 810 Harrisburg, PA 17108 Telephone: (717) 234-2616 Counsel for Plaintiff Lisa A. Goodyear •saslwaJd aql uo luosaJd aq Jo Jalua of aSallnud Jo l15u ou anrq Ilr is luapuodsou •oouaplsaJ oglJo uolssossod anlsnloxo palurJS sl Jauolulad •aAq XrlU Janollilad aaagm aauapisaJ 6Jr.todtuol Jo utouruuod Jagto ,Cur Jo riurAl Csuuad ',punoO purpocliunO 'olsiprD 'pmd poiclXuuog 9£Z tr aauoppi ag1 tuoJJ papnlaxo pur palalAa sl luapuodsoy Z •pungj oq hui Jauoppad oiagm aarld Sun w Jauollllad AIr1s Jo'ssr.Jrq 'ualroap `osngr tou llrgs luopuodso-l •1lF1Q Jo UolssRwpr s,lttapuodsa-g ,noglptt pur salt:rd og1Jo wawnifft Sq polumS st Jopao uopoolo.td luu!I r JoJ lsonbaJ s,Jauollilad :snwpoJ sr paaaoa(I pur paSpnfpV 'paaapaO sl a '.JOltrw-loafgns otp pur salurd agl JOAO uollalpslJnf SuiArq lmoo oql 'OOOZ ` JO S of 1 still `MON QAIN JraCpooO .V rsrl :pligo Joulw pun 301101190d Swpnloui suosmad aAlloaloJd llujo sa uuN LSL6-05-0IZ :Jagwnu,gl.tnaas lulaos s,luapuodsag 8561 '£ tirn.tgad :gulgJo alp s,luapuodsog •J f'JraSpooO -W saumf :awru s,luapuodsag J Uf1OO dO Haullo 'IVN13 HSfIE[V WONA NOTIDJ 1 1O21d C' luopuodsod MV'I - NOIJ.DV'IIAID ( "W `dVEAGOOD •W SdWVf ( 6661-S-ZLIL *ON ( 'A ( ( Jauophad ( `2IVEIAGOO`J'V VSI'I VINVA'IASNNE `AINfIOD cm-nI38Wf1O .d0 SV9-Id NOWWOD 30 J.xnm 9HI NI ;::?? r. ? :? j::?? 1 f .? tr ?• S ? ,i ?? ., ., J '? ? J .? , f\ 1? 3. Respondent is prohibited from having ANY CONTACT with Petitioner at any location, including, but not limited to any contact at Petitioner's business, or place of employment. 4. Respondent shall not contact Petitioner by telephone or by any other means, including through third persons. 5. Respondent shall immediately relinquish all weapons and firearms to the Sheriffs Office and Respondent is prohibited from transferring, acquiring or possessing any such weapons for the duration of the order. A certified copy of this order shall be provided to the police department where Petitioner resides. THIS ORDER SUPERSEDES ANY PRIOR PROTECTION FROM ABUSE ORDER. ALL PROVISIONS OF THIS ORDER SHALL EXPIRE ON NOVEMBER 1, 2000. NOTICE TO THE RESPONDENT: VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE, BY A FINE OF UP TO 51,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA. C.S.§6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS ORDER IS ENFORCEABLE IN ALL FIFTY STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. §2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY LJ VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C. §§2261-2262. NOTICE TO LAW ENFORCEMENT OFFICIALS. This order shall be enforced by the police who have jurisdiction over the Respondent's residence OR any location where a violation of this order occurs OR where the Respondent may be located. Ifthe Respondent violates paragraphs 1 through 5 of this order, Respondent 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 sheriffs office of the county which issued this order, which office shall maintain possession of the weapons until further order of this Court, unless the weapons are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. When the Respondent is placed under arrest for violation of the Order, the Respondent shall be taken to the appropriate authority or authorities before whom Respondent is to be arraigned. A "complaint for indirect criminal contempt" shall then be completed and signed by the Police Officer OR the Petitioner. Petitioner's presence and signature are not required to file the complaint. If sufficient grounds for violation of this Order are alleged the Respondent shall be arraigned, bond set and both parties given notice of the date of the hearing. BY THE COURT: J. Wesleii er, J. If entered pursuant to the consent of Petitioner and Respondent: Lisa A. Goodyear Donald T. Kissinger, E u' c amen i:4. Goodyear, r. ? Z Michael A. Scherer, Esquire 5 08/17/00 'fllU 14:27 FAX 717 240 6573 CUMO CO PROTHONOTARY `1Y- 7172, im001 xxssa:ssxxxsxsxxxxzxxx sxx TX REPORT xxs ssxxxsxssxsxxsssxxsxx TRANSMISSION OK TX/RX NO 2080 CONNECTION TEL 92490779 CONNECTION ID ST. TIME 08/17 14:23 USAGE T 04'40 PGS. 7 RESULT OK LISA A. GOODYEAR, Plaintiff V. JAMES M. GOODYEAR, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 99-7172 CIVIL TERM ORDER OF COURT AND NOW, this 'Aay of December, 1999, upon consideration of the attached letter from Donald T. Kissinger, Esq., attorney for Plaintiff, the hearing previously scheduled in this matter for December 9, 1999, is continued generally. Counsel for the parties are requested to notify the court if they desire a hearing in this matter or if a consent order is entered into. The temporary protection from abuse order entered on November 29, 1999, shall remain in full force and effect. Donald T. Kissinger, Esq. 130 Walnut Street P.O. Box 810 Harrisburg, PA 17108 Attorney for Plaintiff Michael A. Scherer, Esq. 17 W. South Street Carlisle, PA 17013 Attorney for Defendant .uI • ?' t r f :rc BY THE COURT, _ ., ;. , ?. ?. ,..• .,.: ?? J ?..: r, 1._ . . ,; ?? j'L?a LAW OFFICES Of HOWETT, KISSINGER & CONLEY, P.C. 130 WALNUT STREET POST OFFICE BOX 810 I IARRISI(NR(I. PL%N'MVASIA 17108 JOHNC. HOWETT DONALD T. KISSINGER CINDY S. CONLEY DEBRA M. SHIMP, Legal Assistant December 9, 1999 VIA FAX & MAIL 717-240-6462 The Honorable J. Wesley Oler, Jr. Cumberland County Courthouse I Courthouse Square Carlisle, PA 17013-3387 Re: Goodyear v. Goodyear PFA Docket #: 1999-7172 Civil Dear Judge Oler: (717)234.2616 FAX (717) 234.5402 I write in my capacity as counsel for Lisa Goodyear, Petitioner in the above-referenced abuse action. I have had conversation with Michael A. Scherer, Esquire, counsel for James Goodyear, and it now appears that the parties will be entering into a Consent Order which would do away with the necessity for hearing. Under the circumstances, we respectfully request that you continue the hearing scheduled for 3:45 p.m. this afternoon pending our submission of a stipulation for entry of a consent order. It is my understanding that you may consider submission of such a stipulation without the necessity for appearance by the parties. Thank you for your consideration in this matter. Sincerely, Donald T. Kissinger DTK/djk cc: Michael A. Scherer (via fax & mail) Lisa A. Goodyear (via fax & mail) 6r., 0 SHERIFF'S RETURN - REGULAR CASE NO: 1999-07172 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GOODYEAR LISA A VS. GOODYEAR JAMES M JR KENNETH GOSSERT Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon GOODYEAR JAMES M JR the defendant, at 13:35 HOURS, on the 1st day of December 1999 at 804 WELLINGTON DRIVE CARLISLE, PA 17013 CUMBERLAND County, Pennsylvania, by handing to JAME M. GOODYEAR, JR. a true and attested copy of the PROTECTION FROM ABUSE together with NOTICE OF HEARING AND ORDER, TEMPORARY PROTECTION FROM ABUSE ORDER and at the same time directing His attention to the contents thereof. Additional Comments: WEAPONS CONFISCATION Sheriff's Costs: Docketing 18.00 Service 3.10 Affidavit .00 Surcharge 8.00 Omas ine, eri 12/02/1999 by Sworn and subscribed to before me this // i7-1 day of M-2o-crp A. D. Prot nOYI0Cdry%'- pu 1e i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, ) Petitioner ) V. ) NO. X1999 JAMES M. GOODYEAR, JR., ) CIVIL ACTION - LAW Respondent ) PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL order may be entered against you granting the relief requested in the petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on the matter is scheduled for the 9Lh, day of 1999 at ' 'I - m. in Courtroom # / at the Cumberland County Courthouse, I Courthouse Square, Carlisle, eLnnsylvania 17013. You MUST obey the order that is attached until it is modified or terminated by the court alter 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 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, 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 WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT FIND A LAWYER, YOU MAY HAVE TO PROCEED WITHOUT ONE. Cumberland County Lawyer Referral Service Court Administrator 4'h Floor Cumberland County Courthouse Carlisle, PA 17013 BY THE COURT: ?! J. 44?? co 71 p c.-1 U o (FC?Y( OJI I" 11_ .?.? =? Cdr 1 d IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, Petitioner ) V. ) NO. -5-1999 - 717Z Cc< t JAMES M. GOODYEAR, JR., ) CIVIL ACTION - LAW Respondent ) PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's name: James M. Goodyear, Jr. Defendant's date of birth: February 3, 1958 Defendant's social security number: 210-50-9757 Names of all protective persons including Plaintiff and minor child: Lisa A. Goodyear AND NOW, this L tt'day of kil , , A-,,-11 , 1999, upon consideration of the attached Petition for Protection from Abuse, the Court hereby enters the following temporary order: A. Respondent shall not abuse, threaten, harass, or stalk Petitioner in any place where Petitioner may be found. B. Respondent is evicted and excluded from the residence at 236 Bonnybrook Road, Carlisle, Cumberland County, Pennsylvania or any other permanent or temporary residence where Petitioner may live. Petitioner is granted exclusive possession of the residence. Respondent shall have no right or privilege to enter or be present on the premises. C. Respondent is prohibited from having ANY CONTACT with Petitioner at any location, including, but not limited to any contact at Petitioner's business, or place of employment. D. Respondent shall not contact Petitioner by telephone or by any other means, including through third persons. E. Respondent shall immediately relinquish all weapons and firearms to the Sheriff's Office and Respondent is prohibited from transferring, acquiring or possessing any such weapons for the duration of the order. F. The police or law enforcement agency shall serve the Respondent with a copy of this petition, any order issued, and order for hearing. A certified copy of this order shall be provided to the police department where Petitioner resides. THIS ORDER SUPERSEDES ANY PRIOR PROTECTION FROM ABUSE ORDER. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT: Respondent 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 and/or up to six months in jail. 23 Pa. C.S. §6114. Consent of the Petitioner to Respondent'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. Respondent is further notified that violation of this Order may subject him to state charges and penalties under the Pennsylvania crimes code and to Federal charges and penalties under the Violence Against Women Act. 18 U.S.C. §§2261- 2262. NOTICE, TO LAW ENFORCEMENT OFFICIALS. This order shall be enforced by the police who have jurisdiction over the Respondent's residence OR any location where a violation of this order occurs OR where the Respondent may be located. If the Respondent violates paragraphs A through E of this order, Respondent 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 sheriffs office of the county which issued this order, which office shall maintain possession of the weapons until further order of this Court, unless the weapons are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. BY THE COURT: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LISA A. GOODYEAR, ) Petitioner ) V. ) NO. -S-1999 - 'rI 7 Z JAMES M. GOODYEAR, JR., ) CIVIL ACTION - LAW Respondent ) PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE AND NOW comes the Petitioner, Lisa A. Goodyear, by and through her counsel, Howett, Kissinger & Conley, P.C., pursuant to the Protection from Abuse Act, 23 Pa.C.S. §§6101, el. seq., as amended, and respectfully represents as follows: 1. Petitioner's name is Lisa A. Goodyear 2. Petitioner is filing this petition on behalf of herself. 3. Names of all persons, including Petitioner and minor children, who seek protection from abuse: Lisa A. Goodyear 4. Petitioner's address is 236 Bonnybrook Road, Carlisle, Cumberland County, Pennsylvania 17013. 5. Respondent is believed to live at the following address: 236 Bonnybrook Road, Carlisle, Cumberland County, Pennsylvania, 17013. Respondent's social security number is: 210-50-9757 Respondent's date of birth is: February 3, 1958. Respondent's place of employment is: none 6. The relationship between Petitioner and Respondent is that of Wife and Husband. ?' L C) r: L 11: 1 ' '(? tom: _ . . ( _ _ '` 1 - 4. .? ? L ? '? a? ? ? ?? . LL:._. C?: .J.t._ 1J 1? L . ?? ` ?Il ,, ? J ? C_J Petitioner and Respondent have not been involved in any other court actions. 8. Respondent has been involved in a criminal court action resulting from his assault on Petitioner. The Respondent has not yet been convicted of anything. The Respondent is currently incarcerated in the Cumberland County Prison. 9. The facts of the most recent incident of abuse are as follows: Approximate date: November 29, 1999 Approximate time: 12:30 p.m. Place: 236 Bonnybrook Road, Carlisle, PA 17013 On November 29, 1999, at approximately 12:30 p.m., a co-worker telephoned Petitioner on her cellular phone. Petitioner and Respondent struggled over the phone while it was ringing and Respondent eventually gained possession of the phone and threw it in a field. Respondent (lien went and obtained a hand gun and proceeded to knock Petitioner over backward on her chair. He then placed the gun in Petitioner's side and Petitioner began screaming. He then placed the gun in Respondent's mouth. Respondent then removed the gun from his mouth and indicated that if Petitioner did not give him it real chance, that he would kill her and then himself. Respondent then attempted to put the gun in Petitioner's mouth and in the process turned her head and hit her under the let( side of hcrjaw. In order to placate Respondent, Petitioner told him that she would give him another chance. At approximately 2:00 p.m., a woman who boards her horse at the parties' properly appeared to ride her horse. Respondent allowed Petitioner to go along with the boarder on a horse back ride. While out ofear shot of Respondent, Petitioner asked the boarder whether or not she had it cell phone along and the boarder indicated that while she did have a cell phone that there was no battery and therefore the only way for Petitioner to utilize the cell phone was in the boarder's vehicle. Petitioner declined this offer as Respondent would have been able to observe her making the phone call. Petitioner and boarder returned from the horse back ride at approximately 4:00 p.m. At that point, Respondent indicated that he and Petitioner were going out to dinner. Respondent and Petitioner drove to the Holly Inn. Petitioner, while indicating to Respondent that she had to use the restroom, telephoned a friend and left the Holly Inn via a back entrance where her friend picked her up. Petitioner's friend drove her to the State Police Barrack's where Petitioner reported the day's events. Respondent was arrested on various charges and, Petitioner believes, is currently incarcerated at the Cumberland County Prison. 10. Respondent has committed a prior act of abuse against Petitioner on October 26, 1999 on that date Petitioner and Respondent where engaged in a conversation and when Petitioner attempted to get up off a couch to end a discussion with Respondent, Respondent shoved her back down. 11. Respondent has used or threaten to use against Petitioner the following weapons: a hand gun 12. The police departments/law enforcement agencies in the area in which Petitioner lives and which should be provided with a copy of the protection order are the South Middletown Township Police and Carlisle Police Department. 13. There is an immediate and present danger of further abuse from the Respondent. 14. Petitioner is asking the court to evict and exclude Respondent from the following residence: 236 Bonnybrook Road, Carlisle, PA 17013. The owners are Petitioner and Respondent. FOR THE REASONS SET FORTH ABOVE, THE. PETITIONER REQUESTS THAT THE COURT ENTER A TEMPORARY ORDER, AND AVIT'R (TEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: A. Restrain Respondent from abusing, threatening, harassing, or stalking Petitioner in any place where Petitioner may be found. B. Evict and exclude Respondent from Petitioner's residence and prohibit Respondent from attempting to enter any temporary or permanent residence of the Pctitioncr. C. Prohibit Respondent from having any contact with Petitioner either in person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Petitioner's business or place of employment. D. Order Respondent to immediately turn over weapons to the sheri ff of this county and prohibit Respondent from transferring, acquiring or possessing any such weapons for the duration of the order. E. Order Respondent to pay the costs of this action including tiling and service fees. F. Order Respondent to pay Petitioner's reasonable attorneys lees, G. Grant such other relief as the court deems appropriate. H. Order the police or law enforcement agency to serve the Respondent with a copy of this petition, any order issued, and order for hearing. The Petitioner will inform the designated authority of any addresses, other than Respondent's residence where Respondent can be served. Date: PZ9 Respectfully submitted, Donal: issingcr, Esquir I IO1N1s'I" , KISSINGER & CONLEY, P.C. 130 Walnut Street 1'.0. Box 810 I lnrrisburg, PA 17108 'Telephone: (717) 234-2616 Counsel for Petitioner Lisa A. Goodyear VERIFICATION I, Lisa A. Goodyear, hereby swear and affirm that the facts contained in the foregoing Petition for Protection from Abuse are true and correct to the best of my knowledge, information and belief and are made subject to the penalties of 18 Pa.C.S. §4904 relating to unswor falsification to authorities. ?iz99 ??Q DATE LISA A. GOODYEAR 11/29/99 LION 16:01 FAX 717 240 6573 cu mil rn l)On•rnn%,m•AT2V cn ..,.. xxxYxxxiissxxxxT:Yxxx Yxx TX REPORT xxs xTxYTSxYY'tiTYYYxiT ? , ) TTY / / / TRANSMISSION OK 7:C/RX NO 1608 CONNECTION TEL 92490779 CONNECTION ID ST. TIME 11/29 15:53 USAGE T 07'10 PCS. 11 RESULT OK .. tiL LISA A. GOODYEAR, IN THE COURT OF COMMON PLEAS OF Plaintiff/Petitioner CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 1999-7172 CIVIL TERM JAMES M. GOODYEAR, JR., CIVIL ACTION-LAW Defendant/Respondent PROTECTION FROM ABUSE ORDER OF COURT AND NOW, this l z ± day of November, 2000, upon consideration of the within Motion, and noting the concurrence of the Petitioner, Lisa A. Goodyear, the Cumberland County Sheriff is directed to return to James M. Goodyear, Jr., the firearms confiscated from him in connection with the entry of the Temporary Protection Order previously issued in this case, except for those to be released to Lisa A. Goodyear pursuant to this Order, }ocov,Lj tli,?f its rosscss?er? ¢? Inc TtrcZ) w U The Sheriff ifurther rtid tto return(to Lisa A. Goodyear the following two firearms: a Rueger model 77 Ultra Light .270 caliber hunting rifle and//a// Browning A-bolt huntingrilfle3 prolIv?dcd1 6?f hv-SeSSr? e;pIkC_ rcv SS Gv.? Id v?.? be oG ?c SG BY THE COURT, Michael A. Scherer, Esquire O'Brien, Baric & Scherer 17 West South Street Carlisle, Pennsylvania 17013 Donald T. Kissinger, Esquire Howett, Kissinger & Conley, PC 130 Walnut Street Harrisburg, Pennsylvania 17101 U(/Q? J. Wesley Oler r., J. ?I, clul pci ;vSyLl'i4:IA LISA A. GOODYEAR, Plaintiff/Petitioner V. JAMES M. GOODYEAR, JR., Defendant/Respondent IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 1999-7172 CIVIL TERM CIVIL ACTION-LAW PROTECTION FROM ABUSE MOTION FOR RETURN OF FIREARMS AND NOW, comes the Respondent, James M. Goodyear, Jr., by and through his attorney, Michael A. Scherer, Esquire who respectfully represents as follows: 1. On or about November 29, 1999, this Honorable Court issued a Temporary Protection From Abuse Order against James M. Goodyear, Jr. (hereinafter 'Respondent"), in connection with the above-captioned case. 2. The November 29, 1999 Temporary Protection From Abuse Order directed the Respondent to immediately relinquish all weapons and firearms to the Sheriffs office and prohibited Respondent from possessing such weapons for the duration of the Order. 3. On August 16, 2000, a Final Order of Court was entered in this matter, which Final Order also contained a provision that the Respondent not be permitted to possess firearms during the duration of the Order. 4. The Final Order of Court provides as follows: "ALL PROVISIONS OF THIS ORDER SHALL EXPIRE ON NOVEMBER 1, 2000." 5. There have been no violations of the Temporary or Final Orders in this matter. ¦I._ 6. At all times relevant hereto, the Petitioner, Lisa A. Goodyear, has been represented by Donald Kissinger, Esquire. 7. Attached hereto is a copy of a letter marked at "Exhibit A" evidencing Petitioner's concurrence in Respondent's request. WHEREFORE, the Respondent, James M. Goodyear, Jr., respectfully requests this Honorable Court enter an Order directing the Sheriff to return to him all weapons the Sheriff seized in connection with the issuance of the Temporary and Final Orders of Court in this matter, except that the Sheriff return to Lisa A. Goodyear, the Rueger model 77 Ultra Light .270 caliber hunting rifle and a Browning A-bolt hunting rifle, as those weapons, although seized by the Sheriff, belong to Lisa A. Goodyear. Respectfully submitted, O'BRIEN, BARIC & SCHERER Michael A. Scherer, Esquire I.D. # 61974 17 West South Street Carlisle, Pennsylvania 17013 (717) 249-6873 mas.d it/domesticlmisclgoodyear.mot - LAW Omcrs Of HOWETT, KISSINGER & CONLEY, P.C. 130 WALNUr STREET POSTOFFICEBOX 810 HAw?,Paoan.vAMA 1710a JOIrNC. HOW Err, JR. DONALD T. KISSINGER CINDY S. CONLEY DARREN J. HOLST DEBRA M. SHIMP 2000 October 26 Leo Aubtent , Michael A. Scherer, Esquire O'BRIEN, BARIC & SCHERER 17 West South Street Carlisle, PA 17013 Re: Goodyear v. Goodyear Dear Mike: (717) 2342616 FAX (717) 231.5402 I write in response to your inquiry as to whether Lisa would pose an objection to Jim's request for the return of his weapons confiscated under the soon to expire PFA order. While Lisa retains some trepidation concerning Jim, and the return of the behavior which prompted the filing of her PFA petition, she understands that it is highly unlikely that she will be able to seek an extension of the PFA order under the present circumstances. ,Accordingly, however reluctant her acquiescence may be, she would not pose an objection if Jim sought the return of his weapons. Notwithstanding, I am confident that you will counsel your client to exercise good judgment and advise him to continue to avoid confrontations with Lisa after the expiration of the PFA order. Similarly, as you may recall, I filed on September 29, 2000 an Amended Petition for Return of Property, which resulted in the issuance of a Rule to Show Cause dated October 12, 2000. Pursuant to said petition, Lisa is seeking the return of the two weapons inadvertently confiscated pursuant to the PFA order and which are rightfully owned by her and her brother. The October 12, 2000 Rule was retumable within 15. ays from the date of service thereof, which would mean the Rule expires on'or.about October 27, 2000.'A-. Lisiwill not pose any objection to Jim's request for return of his weapons, so too she-expects that Jinl will pose no objection to her petition. Consequently, I will be filing a Motion to Make Rule Absolute on October 28, 2000 so that Lisa's weapons may be returned, Thank you for your attention to this matter. "EXHIBIT A" ffVF CERTIFICATE OF SERVICE I hereby certify that on October \, 2000, I, Jennifer S. Lindsay, secretary to Michael A. Scherer, Esquire, did serve a copy of the Motion For Return Of Firearms, by first class U.S. mail, postage prepaid, to the party listed below, as follows: Donald T. Kissinger, Esquire Howett, Kissinger & Conley, P.C. 130 Walnut Street P.O. Box 810 Harrisburg, Pennsylvania 17108 +J6 r indsa