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HomeMy WebLinkAbout11-7665Steven P. Miner, Esquire ? , h 0 - F 11, - Matthew A. Sembach, Esquire . Q T Daley Zucker Meilton Miner & Gingrich, LLCM j) OCT .S PM 2: L 635 N. 12 Street, Suite 101 Lemoyne, PA 17043 CUMBERLAND (717) 724-9821 PENNSYLVANIA sminera.dzmmp-law. com IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA Lower Allen Township, Docket No. 2011- -7 Plaintiff V. CIVIL ACTION Jason M. Snyder and Isabel E. Snyder, Defendants (In equity) NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILLING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO THE TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 aW &QB. C. Pd al 21 Steven P. Miner, Esquire Matthew A. Sembach, Esquire Daley Zucker Meilton Miner & Gingrich, LLC 635 N. 12`h Street, Suite 101 Lemoyne, PA 17043 (717) 724-9821 sminer _dzmmglaw.com IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA Lower Allen Township, Docket No. 2011- Plaintiff v. CIVIL ACTION Jason M. Snyder and Isabel E. Snyder, Defendants (In equity) COMPLAINT AND NOW, comes Plaintiff, Township of Lower Allen, by and through its attorneys, Steven P. Miner, Esquire, and Daley Zucker Meilton Miner & Gingrich, LLC, and represents as follows: 1. Plaintiff, Township of Lower Allen ("Township"), is a township of the first class in the County of Cumberland, Commonwealth of Pennsylvania, having its offices at 2233 Gettysburg Road Camp Hill, PA 17011. 2. The Defendants are Jason M. Snyder ("Defendant Jason") and Isabel E. Snyder ("Defendant Isabel"). Defendant Jason resides at 1137 Columbus Avenue, Apartment 9, Lemoyne, Pa 17043. Defendant Isabel resides at 417 Allendale Way, Camp Hill Pa 17011 ("subject property"). 3. The subject property is a parcel of land in a R-1 Zoning District, improved with a single family detached dwelling. Defendant Isabel owns the property. 4. Defendant Jason owns and operates a dog walking and dog daycare business. He uses the subject property as a staging area for said business. 5. Defendant Jason typically, picks up the dogs at their owner's residence and takes the dogs to the subject property where they are walked, fed, and kept for varying periods of time, typically, at the latest until 5:30 P.M. 6. Pursuant to §220-11(E) of the Township's code, a home occupation under §220-165 is a permitted use in an R-1 Zoning district. Said ordinance was adopted pursuant to the authority granted under 53 P. S. §10201. 7. Pursuant to §220-6 a "home occupation" is "an accessory business or commercial activity, conducted entirely within a residential dwelling by one or more of the permanent residents." Said ordinance was adopted pursuant to the authority granted under 53 P. S. §10201. 8. Pursuant to §220-6 a "kennel" is defined as "a structure on any lot on which animals are kept, boarded, raised, bred, treated or trained for a fee." Said ordinance was adopted pursuant to the authority granted under 53 P. S. §10201. 9. A kennel is not a permitted use in a R-1 Zoning district. 10. On June 4, 2010, Defendant Jason submitted a zoning permit application. The application was denied by John M. Eby, Building and Zoning Coordinator for the Township ("Zoning Coordinator Eby") because Defendant Jason was not a resident of the subject property and he was operating a kennel without complying with the kennel rules. Zoning Coordinator Eby also denied the zoning permit because a home occupation requires a special exception with the Lower Allen Township Zoning Hearing Board ("Zoning Hearing Board"). Said reasons for denial were explained to Defendant Jason. Defendant Jason then applied for said exception with the Zoning Hearing Board. 11. On July 15, 2010 the Zoning Hearing Board held a public hearing on Defendant Jason's application. Following the conclusion of the evidence, the Zoning Hearing Board orally denied Defendant Jason's application. 12. On July 19, 2010 Zoning Coordinator Eby issued a Cease and Desist Order against the Defendants. Said order required the Defendants to cease operation of the dog boarding and day care business by July 31, 2010. Said order is attached and incorporated as "Exhibit A". 13. On July 21, 2010, the Zoning Hearing Board issued its written decision in which Defendant Jason's application was denied because he was not a permanent resident of the subject property and the operation of a kennel was not a permitted use. Said written decision is attached and incorporated as "Exhibit B". 14. The Plaintiff has the authority to bring this action pursuant to 53 P.S. §10617 which allows a cause of action for any use in violation of any ordinance promulgated under the Township's authority as stated in 53 P.S. §10201. COUNTI LOWER ALLEN TOWNSHIP V. JASON M. SNYDER 15. Paragraphs 1 through 14 are incorporated herein by reference as if set forth herein at length. 16. On December 20, 2007, Township Officers Edward Curtis ("Officer Curtis") and Tony Calaman ("Officer Calaman") were dispatched to the Lower Allen Dog Park located at 4075 Lisburn Road, after Joan Wyland ("Wyland") called after being bitten by a dog. Upon arriving on scene, Officer Curtis interviewed Wyland who relayed that she was attempting to get into her vehicle when she was attacked and bitten on the thumb by a Labrador Retriever. Wyland's dog was also injured during the attack. Wyland further relayed that the unknown owner had seven (7) other dogs under his control. Officer Curtis's Complaint Report is attached and incorporated as "Exhibit C". 17. Following the December 20, 2007 incident, a press release was issued relating to the incident. On December 24, 2007 the Carlisle Sentinel published an article about the incident. Said article is attached and incorporated as "Exhibit D". 18. On December 26, 2007, Township Sergeant Greg Thomas received a telephone call from Kevin McCartin who relayed that a person residing across the street at 407 Allendale Way has a son who comes to the residence and walks five (5) or six (6) dogs at a time. 19. On December 27, 2007, Officer Calaman received a phone call from Joe Kosanovic saying that he received a letter from Defendant Jason offering his services as a "dog behavioralist" and he believed the suspect mentioned in December 24, 2007 newspaper article may be Defendant Jason. 20. On January 3, 2008, Officer Curtis received a telephone call from Joseph Borza, ("Joseph") then age fourteen (14), about an incident at the subject property where Joseph was involved in a confrontation with his neighbor, Defendant Jason. Joseph told Officer Curtis that he was walking by the subject property with his dog when a boxer under Defendant Jason's control ran outside. The boxer smelled Joseph's dog and Joseph told Defendant Jason his boxer should be on a leash. Defendant Jason replied that Joseph's dog was on his property and the boxer did not need to be on a leash. Joseph walked his dog off the subject property, told Defendant Jason that he and his dog were no longer on his property. Defendant Jason, then age thirty-eight (38) pushed Joseph, then age fourteen (14). Joseph walked away and Defendant Jason's dog followed Joseph for at least three (3) more houses. A copy of Officer Curtis's Complaint Report is attached and incorporated as "Exhibit E". 21. On February 2, 2008, Township Officer Curt Heckler ("Officer Heckler") was dispatched to 425 Allendale Way for a report of a continuing problem with dogs making "unsanitary nuisances" in a yard owned by Roy Osborne ("Osborne"). Osborne told Officer Heckler that he has not seen any dogs defecating in his yard, but when he talked to neighbors, he learned it was most likely one of Defendant Jason's dogs. A copy of Officer Heckler's Complaint Report is attached and incorporated as "Exhibit F". 22. On February 8, 2008, Jay Shuler ("Shuler") went to the Township Police Station and spoke to Township Officers Justin Kirsch ("Officer Kirsch") and Heckler about an incident in which one of the dogs under Defendant Jason's control ran off the subject property into the street and attacked Shuler's dog. A copy of Officer Kirch and Heckler's Complaint Report is attached and incorporated as "Exhibit G". 23. On September 26, 2008, Township Officer Michael Scarlato ("Officer Scarlato") was dispatched to the BP Gas Station located at the 1500 block of Cedar Cliff Drive for an incident in which an unknown individual kicked one (1) of the dogs he was walking. Upon arriving on scene, Officer Scarlato was unable to locate the individual. The complainant, Nancy Ambrose relayed to Officer Scarlato that she believed the individual lived in Allendale and she often sees the individual walking dogs throughout the community. On September 27, 2008 upon talking to Officer Curtis, Officer Scarlato identified Defendant Jason as the suspect from the September 26, 2008 incident. A copy of Officer Scarlato's Complaint Report is attached and incorporated as "Exhibit H". 24. As a result of the September 26, 2008 incident, Defendant Jason was charged with and pled guilty to "Cruelty to Animals" in violation of 18 Pa.C.S.A. §5511(c)(1). A copy of the Magisterial District Judge docket sheet is attached and incorporated as "Exhibit I". 25. On November 10, 2008 Township Detective Donald Sentman ("Detective Sentman") was dispatched to 7 West Shore Drive after receiving a call from David Enrico ("Enrico") about an incident involving Defendant Jason. Detective Sentman interviewed Enrico who relayed that a week earlier Defendant Jason was walking six (6) dogs under his control in front of Enrico's home. Enrico's dog was seated near an open garage door owned by Enrico. Enrico's dog ran up to Defendant Jason's dogs. Enrico verbally scolded his dog and "put a foot into the dog's rear end to correct the dog." After the incident, Defendant Jason put a letter in Enrico's mailbox which chastised Enrico for his actions in correcting the dog. The letter also warned Enrico that if Enrico's actions continued, Defendant Jason would report him to the police. Defendant Jason also asked Enrico if the corrective actions he took against his dog that day were taught to him by the military. A copy of Detective Sentman's Complaint Report is attached and incorporated as "Exhibit F. 26. On August 23, 2009, Township Officer Richard Tamanosky ("Officer Tamanosky") was dispatched to 401 Allendale Way after receiving a call from Norman Batcheler. Upon arriving on scene, Batcheler relayed to Officer Tamanosky that he observed one of the dogs under Defendant Jason's control urinating in his flower bed. Batcheler further relayed that he yelled to Defendant Jason to get his dogs out of the flower bed, and as Defendant Jason walked away, he kicked tan bark out of the flower bed. A copy of Officer Tamanosky's Complaint Report is attached and incorporated as "Exhibit K". 27. On September 22, 2009, Township Officer Kenneth Crane ("Officer Crane") received a telephone call from Carol Dunant ("Dunant") who relayed that a German Shepard, a dog under Defendant Jason's control, nearly bit Dunant's dog because the German Shepard was not on a leash. The incident occurred at 1137 Columbus Avenue. A copy of Officer Crane's Complaint Report' is attached and incorporated as "Exhibit L". 28. On June 20, 2010, Township Officer Elias Martinez ("Officer Martinez") was dispatched to the subject property for an active dog fight. Upon arriving on scene, Officer Martinez interviewed Defendant Jason who said that he released his dogs into the back yard together and a 1 The address listed in the box for "Complaint Location" is incorrect. Said address in the box does not exist and is a clerical error. The incident occurred at Defendant Jason's home. boxer mix bit a golden retriever on the ear. Officer Martinez's Complaint Report is attached and incorporated as "Exhibit N". 29. On August 25, 2010, Township Officer Curtis received a telephone call from Jodi Teffeteller ("Jodi") who relayed to Officer Curtis that her daughter, Ruby, then age (15) was harassed by Defendant Jason who was walking his dogs on August 24, 2010. On August 28, 2010, Officer Curtis interviewed Ruby who relayed to Officer Curtis that she was walking her dog behind her residence when Defendant Jason walked by the front of her residence with a pack of dogs. The dog under Ruby's control heard Defendant Jason's dogs barking and ran to the front of the residence. Defendant Jason then began cursing at Ruby causing the dogs under his control to become even more riled up causing the leashes of the dogs to become tangled and eventually knocking Defendant Jason down to the ground. Defendant Jason then threw a bag of feces in Ruby's yard and told Ruby he should throw the feces at Ruby's face. Ruby was then age fifteen (15) and Defendant Jason was then age forty-one (41). A copy of Officer Curtis's Complaint Report is attached and incorporated as "Exhibit O". 30. As a result of the August 24, 2010 incident, Defendant Jason was charged with and pled guilty to "Disorderly Conduct" in violation of 18 Pa. C.S.A. §5503(a)(4). A copy of the Magisterial District Judge docket sheet is attached and incorporated as "Exhibit P". 31. On August 25, 2010 Township Officer Matthew Claeys ("Officer Claeys") and Township Police Chief Frank E. Williamson, Jr., ("Chief Williamson") responded to a call from the Principal of Highland Elementary School located at 1325 Carlisle Road about their custodian, Helen Gussler ("Gussler" ), being bitten by a dog. Gussler told Officer Claeys that a white male had six (6) or seven (7) dogs off their leashes in the field hockey field. Gussler approached the male to tell him that his dogs were not allowed there but as she was approaching, one of the dogs bit her on the left hip. Gussler further relayed to Officer Claeys that the male was walking only two (2) breeds of dogs-German Shepherds and Pit Bulls. On August 26, 2010 Defendant Jason was identified as the male involved in the incident. A copy of Officer Claeys's Complaint Report is attached and incorporated as "Exhibit Q". 32. As a result of the August 25, 2008 incident, Defendant Jason was charged and pled guilty to "Dogs Running at Large" in violation of §65-6 of the Township's code. A copy of said ordinance is attached and incorporated as "Exhibit R". A copy of the Magisterial District Judge docket sheet is attached and incorporated as "Exhibit S". 33. On September 15, 2010 Township Officers John DeSantis ("Officer DeSantis"), John Cypress ("Officer Cypress") and Gelnett were dispatched to the subject property for dogs barking. Upon arriving on scene, Officer Gelnett noticed a two (2) page Cease and Desist order from the Bureau of Dog Law Enforcement ordering Defendant Jason to cease his operation of a kennel. Officer Gelnett contacted State Dog Warden Natahnee Shrawder ("Warden Shrawder") who told Officer Gelnett, Defendant Jason was to have only four (4) dogs at the subject location. Warden Shrawder arrived at the subject property and Defendant Jason pulled in to the subject property with another dog in his vehicle. Defendant Jason stated that he was aware of the notice posted on his door and he was trying to limit the number of dogs on the subject property but could not completely shut his business down. A copy of Officer Gelnett's Complaint Report is attached and incorporated as "Exhibit T". 34. On May 9, 2011 Officer Gelnett was dispatched to the 300 block of Manchester Road and upon arriving on scene, Ashley Nelson, age twenty-four (24), ("Nelson") reported that she was walking her ten (10) year old Husky as Defendant Jason was walking nine (9) dogs across Manchester Road to pick up two (2) more dogs. After Defendant Jason picked up the two (2) dogs, one of the dogs slipped its collar and ran across Manchester Road toward Nelson. Defendant Jason then lost control of the remaining ten (10) dogs as they bolted across the street toward Nelson and her dog. Cathy Knipe, age sixty (60), ("Knipe") a resident of 310 Manchester Road, helped by catching one of the smaller dogs. As Knipe was returning the smaller dog, Defendant Jason had a German Shepard partially under control when the German Shepard became loose again and bit Knipe. Nelson and her dog were also knocked down numerous times and attacked by at least six (6) dogs. Township police issued Defendant Snyder a citation and filed a Complaint Report. Said Complaint Report is attached and incorporated as "Exhibit U". 35. On May 9, 2011, Nelson also told Officer Gelnett that Defendant Jason has verbally attacked her, allowed his dogs to defecate on her property, and have run loose on her property going after her dog. As a result of said incident Defendant Jason was charged with a violation of "Dogs Running at Large" in violation of §65-6 of the Township's code. Said citation is attached and incorporated as "Exhibit V". 36. On September 9, 2011 Officers Spaulding and Joshua Zeiders ("Officer Zeiders") responded to the subject property for a report of a person bitten by a dog. Officer Spaulding issued Defendant Jason a citation as a result of this incident. A copy of Officer Spaulding's Complaint Report is attached and incorporated as "Exhibit W". 37. On September 27, 2011, Chief Williamson assigned Detective Sentman the case. On September 28, 2011, Detective Sentman met with Dana Davis ("Dana"), age 21, and Dana's parents at Dana's home. Dana told Detective Sentman on September 9, 2011 she was walking along Allendale Way when a German Shepard, one of the dogs under Defendant Jason's control lunged at her and bit her on the thigh causing bodily injury. The dog began to shake his head and did not let go of Dana's leg even as Dana screamed in pain. The dog then released his bite and bit Dana again. Both of Dana's legs were bitten and the dog did not stop attacking Dana until Defendant Jason grabbed the dog. In total, Dana believed there were four (4) dogs under Defendant Jason's control. 38. After Dana was bitten, Joan Klingler ("Klingler") provided first aid to Dana and Klingler took Dana into Klingler's home located at 418 Allendale Way. Defendant Jason then barged into Klingler's home without knocking or announcing his presence. Klingler told Defendant Jason to leave numerous times. Defendant Jason refused each time and he insisted that he talk to Dana. Dana was checked by Emergency Medical Services and returned home. Dana then saw a physician at the Holy Spirit Hospital Emergency Room where she was prescribed medications. A copy of Detective Sentman's Complaint Report is attached and incorporated as "Exhibit X". 39. On September 15, 2011, Township Officer Donald Coffey ("Officer Coffey") was dispatched to the subject property for a report of a dog fight. Upon arriving on scene, Officer Coffey interviewed Elizabeth Shank ("Shank") who reported that there were seven (7) dogs and Defendant Isabel took those dogs inside. As Officer Coffey was interviewing Shank, Defendant Jason arrived at the subject location with three (3) more dogs. A copy of Officer Coffey's Complaint Report is attached and incorporated as "Exhibit Y". 40. On September 18, 2011 Officer Spaulding received a telephone call from Terrie Davis ("Davis") that Defendant Jason was walking eight (8) dogs. Officer Spaulding told Davis that Defendant Jason may walk as many dogs as he wants. A copy of Officer Spaulding's Complaint Report is attached and incorporated as "Exhibit Z". 41. On September 24, 2011, Officer Spaulding received a telephone call from Shelly Perry ("Perry") that Defendant Jason was walking seven (7) or eight (8) dogs and that he took those dogs back to the subject property. A copy of Officer Spaulding's Complaint Report is attached and incorporated as "Exhibit A2". 42. On September 26, 2011 the Lower Allen Township Board of Commissioners held its monthly meeting. At this meeting residents from the Allendale Way community complained about the numerous incidents between themselves and Defendant Jason. 43. On September 29, 2011, Officer Spaulding withdrew the citation he issued on September 9, 2011. Detective Sentman reported in his report that the citation was withdrawn to make way for the criminal prosecution. The Magisterial District Judge docket sheet is attached and incorporated as "Exhibit A3". WHEREFORE, Plaintiff, Township of Lower Allen, prays that an injunction be issued against and restraining Defendant Jason from renting the subject premises and to any tenant using the premises in violation of township zoning ordinances and prohibiting the use of subject premises as described herein. COUNT II LOWER ALLEN TOWNSHIP V. ISABEL E. SNYDER 44. Paragraphs 1 through 43 are incorporated herein by reference as if set forth in full. 45. Defendant Isabel holds legal title to the subject property. A copy of the deed to the subject property is attached and incorporated as "Exhibit A4". 46. On July 14, 2011 Defendant Isabel was interviewed by Detective Sentman because Defendant Jason was cited at least three (3) times for zoning violations and Defendant Isabel paid all of the fines which averaged $500. Township Police Department personnel were concerned that Defendant Isabel was being intimidated by her son into paying the citations. 47. During Detective Sentman's interview, Defendant Isabel said Defendant Jason was not forcing her to pay the fines and she continued to allow Defendant Jason to use her home because he had no other place to take the dogs. A copy of Detective Sentman's Complaint Report is attached and incorporated as "Exhibit A5". 48. The Zoning Ordinance of the Township, specifically states that by permitting such use without a variance or special exception, Defendant Isabel, as property owner is in violation of the Township Zoning Ordinance by continuing to allow her son to operate his business out of her home. WHEREFORE, Plaintiff, Township of Lower Allen prays that an injunction be issued against and restraining Defendant Isabel from renting the subject premises and to any tenant using the premises in violation of township zoning ordinances and prohibiting the use of subject premises as described herein. Respectfully submitted, DALEY ZUCKER WILTON MINER & GINGRICH, LLC DATE: ) V16 ? lI By: W G, St ne ev P. Miner, Esquire Supreme Court I.D. # 38901 ,,,Matthew A. Sembach, Esquire Supreme Court I.D. # 308727 635 N. 12`' Street, Suite 101 Lemoyne, Pennsylvania 17043 (717) 724-9821 Solicitor for Plaintiff, Lower Allen Township "EXHIBIT A 11 SEP-30-2011 FRI 0104 PM P. 06 d OWERALLEN rOWNS W ZP AMS DE"TTYSBUAG AOA0 -CAMP MILL, PENNSYL IIANIA 17011 July 19, 2010 Jsabael Snyder 417 Allendale Way Camp Hill, PA 17011 Re: Termination of dog boarding and day care conducted from your home by Jason Snyder Dear Mrs. Snyder: Our department became aware of the above-referenced business due to complaints from your neighborhood, and a letter dated May 10, 2010 was sent to you by Linda Hockenberry. This letter included a cease and desist directive that had a deadline of May 19, based upon the date you signed the certified mail receipt. Jason Snyder subsequently contacted me about legitimizing the business as a home occupation-. On June 4, 2010, Mr. Snyder submitted a zoning permit application that I could not approve, since home occupations with impact require a special exception approval from the Zoning Hearing Board. In addition, the Jason Snyder did not meet the residency requirement for a home occupation, and the business being conducted met the zoning ordinance defw.ition of "kennel", since dogs were being kept for compensation. Concurrently, Mr. Snyder submitted an application to the Zoning hearing boad for,the special exception approval, and variances from kennel and home occupation rules. At the conclusion of a public hearing conducted on July 15, 2010, the ZHB denied all requested relief. Consequently, I am not authorized to issue the requested zoning permit, and the dog boarding and, by care business being conducted from your home'must be terminated by July 31, 2010. It is my` understanding that PA Dog Law enforcement officers have issued a cease and desist order with a more stringent deadline, so my notice does not supersede that deadline. incerely, o . M. Eby Building & Zt oord inator cc: Jason Snyder Phon. e: (717) 9757575 www.Iowa r-allen. pa. us "EXHIBIT B " IN THE MATTER OF THE APPLICATION OF JASON SNYDER BEFORE THE LOWER ALLEN TOWNSHIP ZONING HEARING BOARD CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO. 2010-03 DECISION DENYING VARIANCES AND SPECIAL EXCEPTION The Applicant requested variances and a special exception for a staging area for dog walking and for dog daycare. A hearing was held before the Board on July 15, 2010. FINDINGS OF FACT 1. Notice of the hearing was properly advertised, the subject property was posted, and all property owners required to be notified of the hearing were notified in accordance with the Codified ordinances. 2. The Applicant is Jason Snyder. 3. The subject property is a parcel of land in an R-1 Zoning District, improved with a single-:Family detached dwelling known as 917 Allendale Way. 9. The subject property is owned by Isabel E. Snyder, who resides at the subject property. 5. The Applicant is Isabel E. Snyder's son. 6. While the Applicant spends a considerable about of time at the subject property, he resides elsewhere in an apartment. 7. The Applicant seeks relief to use the subject property as a staging area for dog walking and for dog daycare. 8. On an average day, the Applicant picks up dogs at their owner' s residence and takes them to the subject property where they are walked, fed and kept for varying period of time, typically, at the latest until 5:30 p.m. 9. Applicant has had as many as 17 dogs, but the average number is ten. 10. Approximately 30 days per year, dogs are kept at the subject property overnight. 11. The dogs have access to a couple of rooms in the dwelling, and are occasionally left out to the back yard, which is fenced. 12. Weather permitting, the Applicant takes the dogs for a walk lasting from 90 minutes to 2 hours, within and outside of the Allendale Development, 13. Many residents of the neighborhood attended the hearing. Some testified in support of the application, but the majority were opposed to it as a business use in a residential area, and because of concerns about safety, noise and other reasons. - 2 - CONCLUSIONS OF LAW 1. Under Section 220-269 of the Codified Ordinances, the Zoning Hearing Board has jurisdiction to hear and decide requests for variances and special exceptions. 2. Pursuant to Section 220-11(E), a home occupation under Section 220-165 is a permitted use in an R-1 Zoning District. 3. A home occupation is defined in Section 220-6 as an accessory business or commercial activity, conducted entirely within a residential dwelling by one or more of the permanent residents. 4. A kennel is defined in Section 220-6 as a structure on any lot on which animals are kept, boarded, raised, bred, treated or trained for a fee. 5. A kennel is not a permitted use in the R-1 Zoning District- 6. Applicant's operation cannot be a "home occupation" because he is not a permanent resident of the subject property. 7. The Applicant cannot meet the requirements of a special exception under Section 220-165(B) of the Codified Ordinances because his operation is not a home occupation. 8. Applicant's operation is encompassed within the broad definition of the term "kennel." - 3 - 9. There was no evidence of any unique physical circumstances or conditions of the subject property which could give rise to an unnecessary hardship. lo. The subject property has already been developed in conformity with the Zoning Ordinance, and a variance is not necessary to enable the reasonable use of the subject property. DECISION In view of the foregoing findings and conclusions, and in consideration of the testimony and evidence presented to the Board, it is the decision of the Board that the Applicant's request for variances and a special exception be and is hereby denied because Applicant did not meet the requirements for relief. LOWER ALLEN TOWNSHIP ZONING HEARING BOARD Date; U0016 AM?- so r - 4 - "EXHIBIT C " Complaint Report Commonwealth of Pennsylvania Lower Allen Twp Complaint Information xr Complaint Number Locked Record Follow Up Call For Service 7-12-01073 No INo IPANIVICP Description P ANIMAL COMPLAINT Status Priority Method Received DateMme Received Cleared I Radlo Dispatch 1 12/20/2007 12:06:00 Day of the Week How Handled Thursday Officer Assi n Complaint Nature Wyland reported that she was bitten while she was attempting to go to her car after being at the dog park at the Lower Allen Community Park. CoNmplaint Location X%ff% , Street Number Street Block Predlrection Street Name Street Type Postdirection 407 ILISSURN PO Box Cross-Predirection Crass-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number Cumberland Location Township Magisterial District Cityrown Political Subdivision Lower Allen To s i M chanicsb r State Zone Number Zip Code Area Grid Residence Type Unit Type PA 2 17055 2401 - Unit Number Latitude Longitude Location Type Country 40.1693 -76.921 United States of America USA Location Description 9/30/2011 1:43:15 PM Page 1 of 5 Complainant Information Salutation j 7Arst Name AN Middle Name Last Name Suffix Date of Birth Race x Address 103 SUNSET VIEW DR Apartment CUMBERLAND I TNEW State PA 1 Zip Code 17070 Phone Number 1 Area Code 717 1 Number 7743700 Ext Phone Type iWork Phone Number 2 Area Code 717 Number 7743700 Fxd i Phone Type Work Notify Complainant Call Taker ID TS Dispatcher ID cNET Complaint P. User Defined Field 1 ser Defined Field 2 User Defined Field 3 ser eid 4 ?- DIM of OC i t@ n Salutation ame TKevin Middle Name Last Name Suffix Date of Bir th Race Sex soclation Type Address 410 Allendale Y &M Apa rtment City Carn2 Hill I State PA Zip Code Phone Number 1 Area Code 717 Number 16455630 Fitt I Phone Type call Phone Number 2 Area Code 7 7 Number l Ext Phone Type User Defined Field 1 Other User Defined Field 2 User Defined Field 3 User Defined Field 4 9/30/2011 1:43:15 PM Page 2 of 5 Salutation First Name ijoe Middle Name l Last Name KosaniRvIc Suffix Date of Birth Race Sex anon Type dress 208 vi w Road Apartment Tama ty Hill I State PA Zip Code 1-011 Phone Number 1 Area Code 717 1 Number 7310397 Fact Phone Type Home Phone Number 2 Area Code 717 Number Ext Phone Type User Defined Field 1 Informant User Defined Field 2 User Defined Field 3 User Defined Field 4 Salutation Lason rst Name Middle Name I Last Name Snyder Suffix Date of Birth Race Sex rsoclation Type Address 1137 Columbia Avenue Apartment l City Camp Hill I State PA 1 Zip Code 17011 Phone Number 1 Area Code 717 1 Number 9761880 J Ext Phone Type Home Phone Number 2 Area Code 77 Number Fitt Phone Type User Defined Field 1 S c User Defined Field 2 User Defined Field 3 User Defined Field 4 Officers Involved 9/30/2011 1:43:15 PM Page 3 of 5 Officer Name Role Resource # Curtis, Edward -1817 - Lower Allen Tw Officer Dispatched 11831 I -ti-.Ili---t'l A Street Number 4075 Street Block Predirection 1 Street Name 1LISSURN Street Type D Postdirection PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County CumbeCiand Jurisdiction Number ICU Location Township Magisterial strict CityrFown Political Subdivision State PA Zone Number Zip Code Area Grid Residence Type I Unit Type Unit Number Latitude Longitude Location Type Country United States of America (USA Location Description I Dispatched 1212012007 12 :11:00 Enroute Arrived 12 :30:00 Geared 1 007 12 :38:00 user eId 1-2 7 User Defined aid 2 User Defined Field 3 User Defined Field 4 Officer Name Role Resource # Calaman, Ton - 1814 - Lower Allen Tw lReporting Officer 11827 Dispatched Enroute ,0 Arrived Cleared 1 Defined Field 1-2 uennea rrera 9/30/2011 1:43:16 PM Page 4 of 5 Attachments File Type Image I File Name lat2007 1201073amdf Description lNote from sa ov' of letter he received from Snyder File Type Image File Name la 0 1201073b. df Description /`........F --i- ?nrll la14cr ror•oivorl frnm Ignvrfpr Comments Comment Narrative by Ofc Curtis 18-31,.12/20/07 On this date, l was dispatched to call Wyland regarding an incident at the Lower Allen Dog Park. Wyland was attempting to go to her car when she was attacked by a red Labrador Retriever. She was bitten in the thumb and her dog was also injured. The owner of the dog was with approximately 7 other dogs including Pugs and a small bulldog. He was described as a white male 57", medium build, 30's. He also described himself as a dog behavioralist. I checked the area and was unable to locate the owner. A press release was prepared for information. Wyland will contact me to u date the medical conditions of her and her dog. Comment Supplemental Report by Sgt. Greg Thomas on 12/26/07 On 12/26107 Kevin McCartin called after reading the article in the newspaper relating to this incident. McCartin advised that he may know who the suspect is. McCartin stated that his neighbor accros the street at 407 Allendale Way has a son who comes to Allendale to walk dogs. The subject will walk five to six dogs at a time in Allendale. The subject also takes the dogs to the dog park. McCartin said the subject drives a gold colored Chrysler sedan, Stratus or Seabring. McCartin does not know the subject's name. 1 will pass this information to Ofc. Curtis. Comment Supplemental by T Calaman On 12/27/07 at 1558 hours 1 took a phone call at the office from Kosanovic in reference to this complaint. Kosanovic related that he lives in Allendale and received a letter from Jason Snyder. In the letter he describes himself as a "Dog Behavioralist" and offers his services. Kasonovic read the article in the newspaper about this complaint and found the information very similar. He will provide a copy of the letter and copy of the envelope that he received. I will pick it up at his residence. Information added to this report and forwarded to Ofcr Curtis. Comment Supplemental by Ofc Curtis 18-31, 1/3108 I spoke with Snyder today and he denied being involved with the dog bite at the park. I will be showing his picture to the original com laintant to see if she can identify him. 9130/2011 1:43:16 PM Page 5 of 5 "EXHIBIT D 11 Cumberlink.com: Tuesday's Sentinel police reports: baby jesus stolen from church Page 1 of 2 Home / News / News Tuesday's Sentinel police reports: baby jesus stolen from church • Story • Discussion Tuesday's Sentinel police reports: baby jesus stolen from church By staff reports, December 24, 2007 The Sentinel - cumberlink.com I Posted: Monday, December 24, 2007 12:00 am 1 (0) Comments Font Size: Default font size Larger font size retweet • Recommend Be the first of your friends to recommend this. ............................... . ..... Here are Tuesday's Sentinel police reports: Baby Jesus stolen from church A baby Jesus was stolen from the a church nativity scene early Sunday, according to Mechanicsburg Borough police. The figure, valued at $100, was taken from the manger at St. Joseph's Church in the 400 block of West Simpson Street between 12:30 and 7 a.m., police say. Police are asking anyone with information on the theft to call 691-3300. Dog bite investigated Authorities are investigating a report of a woman being bitten by a dog at Lower Allen Community Park Thursday, according to Lower Allen Township police. The woman was walking to her car with her dog between 11 a.m. and noon when she was attacked by a red Labrador Retriever, police say. The woman's hand was injured, police say. Police say the owner of the retriever was with about seven other dogs, including pugs and a small bulldog. He was described as a white male in his 30s, about 5-foot-7 with a medium build, and police say he called himself a dog behavioralist. Police are asking anyone with information about the incident to call 975-7575. Teen smoked pot while driving, police say A teen was arrested after being caught smoking marijuana while driving in Middlesex Township Monday, according to Middlesex Township police. Cumberlink.com: Tuesday's Sentinel police reports: baby jesus stolen from church Page 2 of 2 The 17-year-old male was driving well over the speed limit and traveling in the wrong lane at 4 a.m. in the 100 block of Wolf s Bridge Road, police say. He was charged with two counts of DUI and one count each of possessing marijuana and drug paraphernalia, police say. Copyright 2011 The Sentinel - cumbedink.cotn. All tights reserved. This material may not be published, broadcast, rewritten or redistributed. Posted in News on Monday, December 24, 200712: 00 am Updated: 3:20 pm. Share This Story Print Email ShareThis Other Stories Sponsored Links Penny Stock of the Day Rated #1 Penny Stock Newsletter on the net http://www.VictoryStocks.com/ Const Accounting Software #1 Rated Construction Acct Software Improve Profitability w/ Spectrum@ www.DexterChaney.com/Accounting Hot Stock Pick - OWE obscene leans & Lifestyle Brands. Invest, Trade, Stocks. www.Obscene3eans.com Ads by Yahoo! abffl? 5h your local e 9s+n 1J9 E. Htgh 5t. sa,? 'A J atii • d Pm ?'dlliST@ A -=7- purl pd?term { m 9 ' Ofpm Ms?i toy??0+11? "EXHIBIT E" Complaint Report Commonwealth of Pennsylvania Lower Allen Twp Complaint fnformabon Complaint Number Locked Record Follow Up I Call For Service -01 0141 No INo PHARNA Description P S NT T CT Status Priority Method Received Date/Time Received 1 Cleared IRadio tch 0110312008 17:46:00 Day of the Week How Handled Thursday er sianed Complaint Nature Borza reported her son, Joseph, had a confrontation with a neighbor, Jason Snyder. Snyder's dog came out of the house and started interfering with Borza's dog. When Borza told him the dog should be leashed, Snyder nnchnrl Rnr7a rinwn Rana r_nmmantc_ Complaint Location Street Number 417 Street Block Predirectlon Street Name ALLENDALE Street Type Postdirection PO Box Cross-Predirection Cross-Street Name 7 717s-Streeffype Highway Name Highway Number Highway Milepost Rural Route County Cumberland Jurisdiction Number Location Township Lower Allen T h" Magisterial District City/Town Cam Hill Political Subdivision State PA Zone Number 1 Zip Code 17011 Area Grid 1202 Residence Type Unit Type Unit Number Latitude 40,22513 Longitude -76.891 Location Type Country United at of America (Ij Location Description 9/30/2011 1:45:08 PM Page 1 of 4 Compiainant information Salutation ] First Name JOANNA Middle Name Last Name Suffix Date of Birth Race Address 421 ALLENDALE WY Apartment L I TCAMP State PA zp Code 17011 Phone Number 1 Area Code Number Ext Phone Type lHome Phone Number 2 Area Code 717 Number Ext I Phone Type Work Notify Complainant No Call Taker to CEHALL Dispatcher ID BI R 1 cNET Complaint #: 466627 User Defined Field 1 User Defined Field 2 User Defined Field 3 User mad Field 4 9/30/2011 1:45:08 PM Page 2 of 4 Complainant Associate Information, rst Name Middle Name Last Name Suffix Salutation 1 13orza Ioseph Date of Birth Race Sex sodation Type 04/12/1993 Address 421 Allendale a Apartment Ciry State Zip Code I PA 17011 C m 7ill Phone Number 1 Area Code Number Ext Phone Type l 71 1 6129984- Home Phone Number 2 rea Code Number lExt Phone Type 717 User Defined Field 1 User Defined Field 2 Victim User Defined Field 3 User Defined Field 4 Suttix Salutation Name First Middle Name I Last Name a n J snyder Date of Birth 01111/1969 Race , Sex Association Type Address 417 Allendale Way Apartment Ciry State Zip Code 1 I 17011 PA Cam Hill Phone Number 1 Area Code Number Ext l Phone Type 717 7264 Home Phone Number 2 Area Code Number Ext Phone Type 717 User Defined Field 1 User Defined Field 2 suspect User Defined Field 3 User Defined Feld 4 9/30/2011 1:45:08 PM Page 3 of 4 Officers Invol Dispatched Enroute 0110312008 1 AM"d Geared 0110312008 717:49:00 01/0301 8 18:10:00 DOW Reid 1-2 (User DeBned'F1W2 itial Report, Ofc Curtis 18-31, 1/3108 in this date, I spoke with Joseph Borza by phone. He reported he was walking by Jason Snyder's house when nydees boxer came outside. He went to Borza's dog and began to sniff it, making Borza nervous. Snyder came utside and Borza told him he should have his dog leashed. Snyder said the dog was on his property and he idn't. The dog then came on the sidewalk and Borza told him that the dog was now off the property. Snyder 3sponded by pushing him down. Borza walked away and Snyder's dog followed him down at least 3 mores ouses away. za is 14 and Snyder is 39. Borza's mother is unsure what action she wants to have action taken. I will contact on Monday to see what she would like to do. I explained Snyder would be cited for Harassment is she 9/30/2011 1:45:08 PM Page 4 of 4 rtis, Edward - 1817 - Lower Alien Twp (Officer Dispatched 11831 "EXHIBIT F" Complaint Report hit Commonwealth of Pennsylvania Lower Allen Twp Complaint InfoCmation Complaint Number Locked Record l Follow Up 1 Call For Service - 0 76 No No PANIVICE.- Description PANIMAL COMPLAINT Status Priority Method Received Date/Time Received Cleated 5 Rai Di tch 02102/2008 11:55:00 Day of the Week How Handled Saturday Phone Complaint Nature Roy Osborne reported a continuing problem with dogs making unsanitary nuisances in his yard. Aside from the remains, Osborne has not witnessed this himself. Neighbors have told him that it is most Ilkley Jason Snyder. 1 advised Osborne that, if there is a witness to an actual violation of the Township Ordinance, an Ordinance will be served and Snyder can be cited for additional violations. I found no record in CNet that Snyder has been served 6-- #Hic -mnA mfir- wor%la*inn Complaint Location Street Number Street Block Predirection Street Name Street Type Postdirection 425 Allendale PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Cumberland urisdiction Number Location Township Magisterial District City/Town Political Subdivision Lower Allen To nshIR Cam Hill State Zone Number Zip Code Area Grid Residence Type Unit Type PA 1 17011 1202 Unit Number Latitude Longitude Location Type Country 40.22513 -76.891 Re el nce/Home United States of America USA Location Description 9/30/2011 1:46:44 PM Page 1 of 3 Complainant Information Salutation, First Name lRoy Middle Name J. Last Name Suffix Date of Birth 12/12/1969 Race ite rMale Address 425 Allendale Way Apartment l City Camn Hill State IPA 1 Zip Code 17011 Phone Number 1 Area Code 717 - 1 Number 7306288 1 Ext Phone Type lHorne Phone Number 2 Area Code Number Ext Phone Type Notify Complainant No Call Taker ID SOIKEEN Dispatcher ID I cNET Complaint A 479225 User Defined Feld 1 User Defined Field 2 User Defined Field 3 User Li lutation Fkst Name Middle Name M I Last Name Savicler Suffix Date of Binh 01/1111969 - Race hite Sex Male r7TWO dress 417 Allendale Way Apartment C I State PA 1 Zip Code 17011 Phone Number 1 Area Code T 7 17 umber Ext l Phone Type Home Phone Number2 Area Code Number l Ext Phone Type User Defined Field 1 P . violator User Defined Field 2 e Us 8 User Defined Field 4 9/30/2011 1:46:44 PM Page 2 of 3 Officers Involved Curt -1812 - Lower Allen 812 Dispatched Enroute 02/02/2008 Arrived Cleared 02/02/2008 02/02/2008 12:14:00 uennea new rz 9/30/2011 1:46:44 PM Page 3 of 3 "EXHIBIT G " Complaint Report Lower Allen Twp Commonwealth of Pennsylvania. Complaint information Complaint Number Locked Record Follow Up I Call For Service 0 0 I No PANMCP Description PANIMAL COMPLAINT Status Priority Method Received 1 DateMme Received Cleared I Personal Visit 02/0812008,13:30:00 Day of the Week How Handled Friday Officer Assigned Complaint Nature Mr. Shuler came in to the station to let us know that one of the dogs that Mr. Snyder watches came off of his property and ran down onto the street and attacked Mr. Shuler's dog. Mr. Shuler kicked the dog so he would let go of his dog. He did not want to press any charges or cause any problems, he just wanted to let us know that in ..men aewmn4hinM rnmaa hor-k that ha hart tha doa- nothina further. _ Gornplaint Location Street Number Street Block Predirection Street Name Street Type Postdirection 1993 lHummel V PO Box Goss-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Cumberland Jurisdiction Number Township Magisterial District Citylrown Political Subdivision Lower Allen T wn hi 09-1-01 C m Hill State Zone Number Zip Code Area Grid Residence Type Unit Type 1 17011 PA 1203 1 Unit Number Latitude Longitude Location Type Country nit States of America (U Location Description 9/30/2011 1:47:38 PM Page 1 of 4 Complainant Information Salutation Mr. First Name 1jay Middle Name Last Name IShuler Suffix Date of Birth 0 /1 45 Mite Sex iMale Address 407 Allendale Way Apartment l Carno City Hill I State PA Zip Code 117011 Phone Number 1 Area Code 717 1 Number 7310364 Ext Phone Type Phone Number 2 Area Code 7 17 Number Ext Phone Type Notify Complainant Call Taker ID Dispatcher ID U8,890 Complaint #: User Defined Field 1 User Defined Feld 2 User Defined Field 3 d' irra'II?33F; M-62 WTI Salutation rst Name Eason Middle Name Last Name Suffix Date of Birth 1 il 1/1969 Race Sex Type r7 Address 417 Allendale Way Apartment Law State Zip Code Phone Number 1 Area Code 717 Number l 19999999 Ext l Phone Type HoWe Phone Number 2 Area Code 717 Number l Ex, Phone Type User Defined Field 1 C User Defined Field 2 User Defined ek13 User Defined Field 4 I Officers Involve 9/30/2011 1:47:38 PM Page 2 of 4 Officer Name Role Resource # Kirsch, Justin -1859 - Lower Allen Twp Reporting Officer 11859 n•......., -A Street Number Street Block Predirection Street Name Street Type Postdirection 1993 ] Hurnmel V PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number Cumberland Location Township Magisterial District City/Town Political Subdivision Lower Alle nsh' 09-1-01 m Hill State Zone Number Zip Code Area Grid Residence Type Unit Type P 1 17011 12 3 Unit Number Latitude Longitude Location Type Country United to of America (USA) Location Description Dispatched Enroute 02/08/2008 Arrived Cleared 02/08/2008 13:30:00 02108/2008 13 :45:00 User Defined Feld 1-2 User Defined Field 2 6 User Defined Field 3 User Defined Feld 4 Officer Name Role Resource # Heckler, Curt -1812 - Lower Allen Twp lReporting Officer 11812 Dispatched Enroute 02/08/2008 13:30:00 Arrived Cleared 02/08/2008 13:30:0 1 02/0812908 13:45:00 Defined Reid 1-2 Defined Feltl 2 9/30/2011 1:47:38 PM Page 3 of 4 "EXHIBIT 11 " Complaint Report Commonwealth of Pennsylvania Lower Allen Twp Complaint Information Complaint Number Locked Record Follow Up Call For Service LA 0 8-09-01 7 No iNo 1POCRIM Description POTHER CRIMINAL OFFENSES Status Priority Method Received Daternme Received Cleared 1 Radio Dispatch 109/26/2008 08:25:00 Day of the Week How Handled Friday Offc r Assi ned Complaint Nature Dispatched to check the area of the 1500 block of Cedar Cliff Drive in reference to man kicking a dog he was walkina. Unable to locate the male. See comments. Complaint Location Street Number Street Block 0 Pradirecdon Street Name lCedar Street Type Postdirection PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Cumberland Jurisdiction Number Location Township Lower Allen To shi Magisterial District Cityrrown Hill Political Subdivision State PA Zone Number 1 Zip Code 17011 Area Grid 1203 Residence Type Unit Type Unit Number Latitude 40.2304 Longitude -76.8936 Location Type Country United States of America USA Location Description 10/5/2011 11:30:56 AM Page 1 of 4 Complainant Information Salutation First Name Middle Name Last Name suffix INancy Arnbro§a Date of Birth Raca Sex Whi e iFemale Address 423 ndl ck Road Apartment City State Zip Code l Hill I Carnp PA 1 17011 Phone Number 1 Area Code Number Ext Phone Type 717 9030756 Cell Phone Number 2 Area Code Number Ext Phone Type 717 7 614715 l Home Notify Complainant CallTakerlD DlspatcherlD cNET Complaint #: Yes CLBEEC MSFOOR 1 849185 User Defined Feld 1 User Defined Field 2 Com lain nt Witness User Defined Field 3 User Defined Field 4 Officers Involved Michael -1821 - Lower Allen Twp IReportinq Officer 11821 Dispatched Enroute 09/26/2008 08 0:00 Arrived Cleared 09/26/2008 08:34:00 09126/2008 08:53:00 user ueunea Heia l-2 Field 2 10/5/2011 11:30:56 AM Page 2 of 4 Related Incidents Incident Number LAT2008-09-01407 1 e Start ed 0Date/M2m 6/20 8 08:30:00 Location Cedar Cliff DR Cam Hill PA 17011 Status Closed Comments inal Narrative Friday 09126/08 M Scarlato 1821 0825 hrs, I was dispatched to check the area of the BP Gas station, 1500 Cedar Cliff Drive, in reference to a ile individual whom was walking dogs had kicked one of them. I responded to the area and was unable to ;ate the individual. ,fter being unsuccessful in locating the individual, 1 contacted the complainant, Nancy Ambrose, resident of 423 'andlewyck Road. Ambrose advised me that as she was traveling to work in the 1500 block of Cedar Cliff Drive t approximately 0820 hrs, she witnessed a male individual whom was walking several dogs kick one of the ogs. Ambrose was upset by what she witnessed and contacted police. Ambrose was unsure if the dog was injured or not. Ambrose is familiar with this individual and has knowledge :hat he lives in Allendale. Ambrose often sees this individual walking the dogs around the neighborhood and ocal area. informed Ambrose that I would research the statue of Cruelty to Animals to see if the action was a violation of ie law. I inquired that if the action was a violation, I would cite the male, however, if he plead not guilty to the itation and requested a hearing on the matter she would have to testify. Ambrose stated that she would testify. reviewed the statue and verified that the action was a violation. 1 will research our records to locate this idividual's information for I know that LATPD has had contact with him before. I will contact Ambrose to advise er that I will be citing the individual once I obtain his information. itation to follow. ntal Narrative Saturday 09/27/08 M Scarlato 1821 11011 hrs, I contacted Nancy Ambrose in reference to advise her that I was able to locate the individual rho kicked the dog yesterday. Upon speaking with Officer Curtis and researching my past emails, I was able to )cate and properly identity the individual as Jason M Snyder, resident 417 Allendale Way, Camp Hill, PA 17011, rith a phone number of 975-1880. 1 advised Ambrose that I identified the individual and that he would be cited. mbrose was very pleased and again reiterated that she would be willing to testify in any future court roceedings. t 1026 hrs, I attempted to contact Snyder using his home phone number listed above, however, I was nsuccessful. I left a message requesting a return phone in reference to an incident that had occurred Dsterday. Awaiting Snyder's return phone call. Based upon the witness information, 1 completed a summary non-traffic citation, Citation number P5997555-4, for Cruelty to Animals. Citation filed this date. 10/5/2011 11:30:56 AM Page 3 of 4 CAD Messages Comment 09/2612008 08:27:36 OperlD: CLBEECPQ>POSS ANIMAL ABUSE Comment 09/2612008 08:27:36 OperlD: CLBEECPQ>CFS Code changed from to 105C01 Comment 09/26/2008 08:28:41 OperlD: CLBEECHCANCIDENT HOTCALLED. Comment 09126/2008 08:28:51 OperlD: CLBEECPQ>To:1130 CARLISLE RD,LA CU;IN THE AREA Comment 09/2612008 08:28:51 OperlD: CLBEECPQ>Fr:1130 CARLISLE RD,LA CU;IN THE AREA Comment 09/26/2008 08:28:51 OperlD: CLBEECPQ>POSS ANIMAL ABUSE Comment 09/2612008 08:28:54 OperlD: CLBEECIRANCIDENT ROUTED AFTER HOTCALL Comment 09/26/2008 08:30:16 OperlD: MSFOORDP>Res: 1821 Disp Comment 09/2612008 08:32:04 OperlD: MJGUTSCO>EXP ONLY 07/09 Comment 09/2612008 08:34:09 OperlD: MSFOORAR>Res: 1821 Comment 09/2612008 08:53:52 OperlD: MSFOORCL>Finish/Clear Resource Number: 1821 Narrative entered from ProQA: CLBEEC PID:CLBEEC on 09/26108 at 08:27:36 Operator Number :CLBEEC Incident Number :0008016819 Location of Incident :1130 CARLISLE RD,LA CU;IN THE AREA Call Back Phone Number :9030756 Problem Description :POSS ANIMAL ABUSE Chief Complaint Number :105 Dispatch Level :105C01 Dispatch Level Suffix : Medical Response Text :Charlie CAD Incident Code :106C01 Responder Script :Animal. Caller Statement: POSS ANIMAL ABUSE. 1.The caller is not on scene. 2.This incident involves animal CRUELTY. 3.This incident just occurred. 4.N/A 5.The location of the animal is: IN THE AREA OF THE BP STA 6.It is not known if the animal is dangerous. --Comments: IN THE AREA OF THE BP STA- Caller Name :NANCY AMBROSE Narrative entered from ProQA: CLBEEC PID:CLBEEC on 09126/08 at 08:28:51 Updated Narrative from ProQA: Operator Number :CLBEEC Incident Number :0008016819 Location of Incident :1130 CARLISLE RD,LA CU;IN THE AREA Call Back Phone Number :9030756 Problem Description :POSS ANIMAL ABUSE Chief Complaint Number :105 Dispatch Level :105C01 Dispatch Level Suffix : Medical Response Text :Charlie CAD Incident Code :106C01 Responder Script :Animal. Caller Statement: POSS ANIMAL ABUSE. 1.The caller is not on scene. 2.This ncident involves animal CRUELTY. 3.This incident just occurred. 4.N1A 5.The location of the animal is: IN THE 4REA OF THE BP STA 6.It is not known if the animal is dangerous. 7.No one else is in immediate danger. 8.The Rnimai is not confined. 9.The animal's description is not known. 10.No one is injured. 11. t is not known if the animal is injured. 12.The suspect/person responsible is still in the area. 13.The suspect's iescription is not known. 14.The suspect did not arrive in a vehicle. --Comments: IN THE AREA OF THE BP STA --Comments: MALE WALKING A PACK OF DOGS AND WAS KICKING THE DOGS- --Comments: MALE WAS NEARING A HAT AND CALLER THINKS THAT THE- --Comments: POLICE ARE AWARE OF THIS PERSON- -- :omments: CALLER SAW HIM KICKING THE DOGS- :aller Name :NANCY AMBROSE 10/5/2011 11:30:56 AM Page 4 of 4 "EXHIBIT I " Magisterial District Judge 09-1-01 _,.. DOCKET Docket Number: MJ-09101-NT-0001301-2008 Non-Traffic Docket Commonwealth of Pennsylvania v. Jason M Snyder Judge Assigned: Page 1 of 3 CASE INFORMATION Magisterial District Judge Charles A. Issue Date: 09/26/2008 Clement Jr. OTN: File Date: uV1za/zuut5 Arresting Agency: Lower Allen Township Police Dept Arrest Date: Citation #: P5997555-4 Disposition: Guilty Plea Coun : Cumberland Disposition Date: 10/2312008 Township: Lower Allen Township Case Status: Closed STATUS INFORMATION Case Status Status Date Processing Status Closed 11/24/2008 Completed 10/27/2008 Case Balance Due 10/23/2008 Case Disposed/Penalty Imposed 10123/2008 Awaiting Sentencing 10/07/2008 Awaiting Summary Trial 09/29/2008 Awaiting Plea CALENDAR EVENTS Case Calendar Schedule Event Type Start Date Start Time Room Judge Name Summary Trial 10/23/2008 3:30 pm Courtroom: MDJ-09-1-01 Magisterial District Judge Charles A. Clement Jr. Name: Date of Birth: Address(es): Primary Camp Hill, PA 17011 Snyder, Jason M 01/11/1969 DEFENDANT iN FORMATION Sex: Race: - 1 Schedule Status Scheduled Male White Advised of His Right to Apply for Assignment of Counsel? No Public Defender Requested by the Defendant? No Application Provided for Appointment of Public Defender? No Has the Defendant Been Fingerprinted? No CASE PARTICIPANTS Participant Type Participant Name Arresting Officer Scarlato, Michael Jeffrey Defendant Snyder, Jason M CHARGES # Charge Grade Description Offense Dt. Disposition 1 18 § 5511 §§ C1 S Cruelty to Animals 09126/2008 Guilty Plea MDJS 1200 Printed: 09/30/2011 12:02 pm Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 et seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. Magisterial District Judge 09-1-01 DOCKET I Docket Number: MJ-091 01 -NT-0001 301-2008 Non-Traffic Docket Commonwealth of Pennsylvania V. Jason M Snyder DISPOSITION / SENTENCING DETAILS Page 2 of 3 Case Disposition Disposition Date Was Defendant Present. Guilty Plea 10/23/2008 Yes Offense Sea./Description Offense Disposition 1 Cruelty to Animals Guilty Plea - - - - - - - - - - - - REGISTRY ENTRY INFORMATION Filed Date Ent Filer Applies To 11/24/2008 Penalty Satisfied -Magisterial District Court 09-1-01 - Jason M Snyder, Defendant 10/27/2008 Penalty _Assessed Magisterial District Court 09-1-01 _ Jason M Snyder, Defendant 10/23/2008 Guilty Plea Magisterial District Judge Charles A. Jason M Snyder, Defendant -Clement Jr. _ _ _ _ _ _ _ _ _ _ _ _ _ 10/13/2008 Subpoena Issued via Hand Delivery - - -Magisterial District Court 09-1-01 - Restricted Participant - - - - - 10/13/2008 Subpoena Issued Magisterial District Court 09-1-01 - - - - - - - - - Restricted Participant - - - - - - - - - - - 10/07/2008 - - - - - - - - - - Summary Trial Scheduled - -Magisterial District Court 09-1-01 - Jason M Snyder, Defendant - _ _ _ 10/03/2008 Certified Summons Accepted -Magisterial District Court 09-1-01 - Jason M Snyder, Defendant - - - - 10/01/2008 _ Summons Issued -Magisterial District Court 09-1-01 - Jason M Snyder, Defendant 10/01/2008 Certified Summons Issued Magisterial District Court 09-1-01 - Jason M Snyder, Defendant - - - - 09/29/2008 Non-Traffic Citation Filed - - -Magisterial District Court 09-101 - Jason M Snyder, Defendant - - _._ .. .._.__.______ PAYMEW PLAN SUIYLMARY Payment Plan No Payment Plan Freq. Next Due Date Active Next Due Amt. Overdue Amt. 09101-2008-P0001184 Single Payment No $0.00 $0.00 Responsible Participant Snyder, Jason M Payment Plan History: Payment Dt. Transaction Type Pavor Participant Role Amount 11/24/2008 Payment Snyder, Jason M Defendant $127.50 MDJS 1200 Page 2 of 3 Printed: 09130/2011 12:02 pm Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 et seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. Magisterial District Judge 09-1-01 DQCKET 1 Docket Number: MJ-09101-NT-0001301-2008 Non-Traffic Docket Case Balance: Last Payment Amt: Commonwealth of Pennsylvania v. Jason M Snyder Page 3 of 3 CASE FINANCIAL INFORMATION $0.00 Next Payment Amt: Next Payment Due Dt: Non-Monetary Assessment Type Assessment Amt Adjustment Amt Payment Amt Payment Amt Balance Judicial Computer Project $8.00 $0.00 $0.00 ($8.00) $0.00 ATJ $2.00 $0.00 $0.00 ($2.00) $0.00 County Court Cost (Act 204 of 1976) $27.30 $0.00 $0.00 ($27.30) $0.00 State Court Costs (Act 204 of 1976) $7.35 $0.00 $0.00 ($7.35) $0.00 Commonwealth Cost - HB627 (Act 167 of $7.35 $0.00 $0.00 ($7.35) $0.00 1992) Crime Victims Compensation (Act 96 of 1984) $35.00 $0.00 $0.00 ($35.00) $0.00 Victim Witness Service (Act 111 of 1998) $25.00 $0.00 $0.00 ($25.00) $0.00 Domestic Violence Compensation (Act 44 of $10.00 $0.00 $0.00 ($10.00) $0.00 1988) Postage - Case $5.50 $0.00 $0.00 ($5.50) $0.00 Title 18 - Payable to Municipality $50.00 $0.00 $0.00 ($50.00) $0.00 MDJS 1200 Page 3 of 3 Printed: 09/30/2011 12:02 pm Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 at seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. "EXHIBIT J 11 Complaint Report Commonwealth of Pennsylvania Lower Allen Twp Complaint Information Complaint Number Locked Record Follow Up I Call For Service -11- 407 No INo PNEIGHB Description PNEIGHBOR DISPUTE Status Priority Method Received DateMme Received Cleared Phone 1 11110/2008 11:37:00 Day of the Week How Handled i Monday Officer si ned Complaint Nature Neighbor dispute, male subject Jason Snyder became upset about Enricco's dog coming over to his six dogs rlnrinn n walk See comments for additional information. Complaint Location Street Number Street Block Predirection ame F el " Street Type Postdirection Shore z s PO Bo x Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number Cumberland Location Township Magisterial District City/rown Political Subdivision Low Allen T sh' 9-1-01 Ca Hill State Zone Number Zip Code Area Grid Residence Type Unit Type PA 1 17011 1203 Unit Number Latitude Longitude Location Type Country United States of America (USA) Location Description 9/30/2011 1:50:36 PM Page 1 of 4 Complainant Information 11 Salutation First Name iDavid Middle Name IA. Last Name lEnrico Suffix Date of Birth 08102/1960 Inknown ce Sex le Address 7 West Shore Drive Apartment l City Camy Hill I State PA 1 Zip Code 17011 Phone Number 1 Area Code 1 7 7 759259 umber Ext Phone Type P hone Number 2 Area Code 717 Number Ext Phone Type Notify Complainant Call Taker ID Dispatcher ID 1 cNET Complaint #: 869012 User Defined Field 1 User Defined Field 2 User Defined Field 3 e 4 C Salutation Fret N Middle Name Last Name Suffix Date of Birth R e ale T x r sociation Type Address Apartment T Za State P 7ZJpCode 1 Phone Numbed Area Code 717 Number J 199999999 E,,1 l Phone Type Home Phone Number 2 a Code 7 7 Number Ex[ Phone Type User Defined Field 1 User Defined Feld 2 " 49 User ned Flekf 3 11 d 0 9/30/2011 1:50:36 PM Page 2 of 4 Officers Involve Donald -1808 - Lower Allen Twp lReporting Officer 11808 Street Number Street Block Predirection ] Street Name Street Type Postdirection 7 West Shore 211 PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number Cumberland Location Township Magisterial District City/rown Political Subdivision Lower Allen ownshh) 09-1-01 C Hill State Zone Number Zip Code Area Grid Residence Type Unit Type PA 1 1 Unit Number Latitude Longitude Location Type Country United States of America USA Location Description Dispatched Enroute 11/10/2008 11:37:00 Arrived Cleared 11/10/2008 11:37:00 11/1012008 11:47:00 User Defined Feld 1-2 User Defined Field 2 8 User Defined Feld 3 User Defined Field 4 9/30/2011 1:50:36 PM Page 3 of 4 Comments Report, Corporal Sentman 1808 10 November 2008 ri this date, I was asked to speak to David Erico who had called the station to report a subject put a letter in his ailbox. Enrico stated that last week he had a problem when a male subject, Jason Snyder, walked his six dogs Enrico's home. Enrico's dog Jax was with Enrico, (verbal command and control over the dog), and was ated near the open garage door. Snyder walked his six dogs by Enrico's home and Jax ran up to greet the gs. Enrico was upset by this, so he went down and verbally corrected his dog. He grabbed the dog by the Ilar, and removed him from the sidewalk and into the house He stated he did put a foot Into the dog's rear end correct the dog, but aded that he did not abuse his dog. Enrico stated he was inside his home when this took co stated that later in the week, he received a letter in his mailbox.. The letter was from Snyder and was ten in response to his actions to correct his dog. Snyder scolded Enrico for his actions, and stated that Sequent actions like he had that day would result in his filing a report with the police. Enrico also statedthat der made a comment in the fetter about Enrico's military service, and questioned if the actions he took that were taught to him in the military. is letter is signed by Snyder. Enrico suspects that Snyder removed mail from his mailbox and obtained his formation to write his name on the letter. In the letter, Snyder stated that the date of the offense was October 2008. Enrico stated that this ws in-correct and the correct date of the event was 3 November 2008.. US Postal office was contacted by Enrico reference to this incident. They are to investigate the Federal al violation reported by Enrico. was aked by Enrico to document the incident and take no further action against Snyder. 9/30/2011 1:50:36 PM Page 4 of 4 "EXHIBIT K " Complaint Report <a Commonwealth of Pennsylvania Lower Allen Twp Cornplai?t Infiorm_ atimn „ Complaint Number Locked Record l Follow Up I Call For Service No lNo PANMCP Description PANIMAL COMPLAINT Status Priority Method Received DateMme Received Cleared 5 l Radio Di atc 1 0812 20091:1:00 Day of the Week How Handled Sunday Officer A signed Complaint Nature NORMAN BATCHELER OBSERVED "JASON" (DOG WALKER) ALLOW THE DOGS TO URINATE IN HIS FLOWER BED. BATCHELER TOLD JASON TO GET THE DOGS OUT OF HIS GARDEN, AND AS JASON WALKED AWAY HE KICKFn Sc]MF nF THE TAN BARK OUT OF THE FLOWER BED. Cmoomplan iw. f? Location , Street Number Street Block Predirection Street Name Street Type Postdirection 401 1ALLENDALE PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number Cumberland Location Township Magisterial District Cityrmn Political Subdivision Lower Allen T i CAMP HILL State Zone Number Zip Code Area Grid Residence Type Unit Type PA 1 17011 1202 Unit Number Latitude Longitude Location Type Country 40,2 3 -76.88965 United States of r' "OA J Location Description dn1 ALLFNnALF WY -LA CU401ALLENDALEWYLACU 9/30/20111:51:16 PM Page 1 of 3 Complainant Information Salutation ] First Name NORMAN Middle Name Last Name 10 Suffix Date of Birth 1 43 a Mal Li Address 401 ALLENDALE Y Apartment L i TCAMP State PA 1 Zip Code 17011 Phone Number 1 Area Code 7 7 1 Number 3031939 Ext Phone Type lHorne Phone Number 2 Area Code Number Ext I Phone Type 'Vork Notify Complainant No Call Taker ID Dispatcher to 1 cNET Complaint p: 100696 User Defined Field 1 User Defined Field 2 User Defined Field 3 ser eld 4 (:fit Cik ?eeT Salutation First Name IJASON Middle Name I Last Name SNYD Suffix Date of Birth 01/11/1969 Race hit: Sex ocietlon Type Lnact Address 417 Allendale WY Apartment l Carnp Hill City I State PA Zip Code 4 1 Phone Number 1 Area Code 717 Number 9751880 Ext Phone Type e Phone Number 2 Area Code 717 T'7610574 er J Ex1 i Phone Type Cell User Defined Reid 1 SUSPECT User Defined Field 2 User Defined Reid 3 User Defined Field 4 9/30/2011 1:51:16 PM Page 2 of 3 Officers Involved Richard -1807 - Lower Allen Twp lReporting Officer 11807 von VI Street Number Street Block Prediirecton Street Name Street Type Postdirection 401 I 'ALLENDALE WY PO Box Cross-Predirection Cross-Street Name rocs-Street Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number Cumberland U Location Township Magisterial District City/Town Political Subdivision LA State Zone Number Zip Code Area Grid Residence Type Unit Type Unit Number Latitude Longitude Location Type Country USA United States of America Location Description 1 ALLEND ALE WY LA U401ALL EN DALEWYLACUO Dispatched Enroute 08/2312009 10 :54:00 Arrived Cleared 08/23/2009 1:26:0 081231200 9 11:31:00 User Defined Field 1-2 User Defined Field 2 4 User Defined Field 3 User Defined Field 4 9/30/2011 1:51:16 PM Page 3 of 3 "EXHIBIT L " Complaint Report -? Commonwealth of Pennsylvania Lower Allen Twp Q`M' t.lnforrn'A t „ Complaint Number Locked Record Follow Up all For Service LA -01 9 No INo Description COMPLAINT Status Priority Method Received Date/Time Received Cleared 5 Phone 09 0 :30:00 Day of the Week How Handled TuesdjU Offic r Assigned Complaint Nature Dunant called reference her neighbor, Snyder, allowing one of the dogs that he sits for run at large. She stated that a German Sheppard without a leash under the care of Snyder nearly bit her dog who was on a leash. Checked history and will deliver a copv of the Township Animal Ordinance to Snyder as required. ," 6ini Loca on. Street Number 37 Street Block Predirection Street Name Columbus Street Type V Postdirection PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Cumberland Jurisdiction Number Location Township Lower Allen o hi Magisterial District 09-1-01 City/Town Cam Hill Political Subdivision State PA Zone Number 1 Zip Code 17011 Area Grid 1203 Residence Type Unit Type Unit Number Latitude Longitude Location Type Country United States of America (USA) Location Description 9/30/2011 1:52:10 PM Page 1 of 3 Complainant Information Salutation First Name Carol l Middle Name Last Name I IDunant suffx Date of Birth Race Sex Address 1437 Columbus Avenue Apartment 2 l City Camp it I State PA 1 Zip Code 17011 Phone Number 1 Area Code 1 7 7 ,17374508 umber l Ext Phone Type P hone Number 2 Area Code 717 Number Ext Phone Type Notify Complainant Call Taker ID Dispatcher iD cNET Complaint M. User Defined Field 1 User Defined Field 2 ' User Defined Field 3 ser _ of 4 ago t: - Salutation rst Nam Middle Name Last Name I Suffix Cason Snyder Date of Birth 1 77 Sex Type Address 1437 Columbus Avenue Apartment City I State 1 Zip Code 9 l Cami) Hill PA 17011 Phone Number 1 Axea Code Number E,41 Phone Type 717 J 41880 l Home Phone Number 2 Area Code Number Ext Phone Type 717 l User Defined Field 1 User Defined Field 2 Sheppard Responsible Person User Defined Meld 3 User Defined Field 4 9/3012011 1:52:10 PM Page 2 of 3 Officers Involved Kenneth -1856 - Lower Allen Twp Reporting Officer 11856 Street Number 437 Street Block Predirection Street Name Columbus Street Type Postdirect on PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Cumberland Jurisdiction Number Location Township Lower Alle w i Magisterial District 9-1-01 City/Town a Hill Political Subdivision State Zone Number 1 Zip Code 17011 Area Grid 1203 Residence Type Unit Type Unit Number Latitude Longitude Location Type Country United States of America S Location Description Dispatched 09/22/2009 11:30:00 Enroute Arrived 09/2212009 11:30:00 Cleared 09122/200 9 11:37:00 User Defined Field 1-2 User Defined Field 2 User Defined Field 3 User Defined Field 4 9/30/2011 1:52:10 PM Page 3 of 3 "EXHIBIT N 11 Complaint Report Commonwealth of Pennsylvania Lower Allen Twp Complaint Information -C Complaint Number Locked Record Follow Up I Call For Service 10 - 105 No iNo PANMCP Description PANIMAL COMPLAINT Status Priority Method Received DateiTime Received Cleared 5 Radio D' tch 1 06/20/2010 20:15:00 Day of the Week How Handled Sunday Officer As i ed Complaint Nature Dispatched to this address for an active dog fight. I arrived and made contact with Jason Snyder who said that he had released his dogs into the back yard together and while playing one dog, a boxer mix, bit a golden retrievers ear. Both dogs were to ether when I arrived and displayed no a ression. No further problems. Complaint Location Street Number Street Block Predirection 1 Street Name Street Type Postdirection 417 Allen le PC Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number Cumberland Location Township Magisterial District Cityrrown Political Subdivision Lower Allen To vnshig) Camp Hill State Zone Number Zip Code Area Grid Residence Type Unit Type PA 1 17011 1202 Unit Number Latitude Longitude Location Type Country 40.225134 76,891034 Residence/Home States United of America Location Description 9130/2011 1:53:56 PM Page 1 of 3 Complainant Information Salutation l eslie rst Name Middle Name Last Name Suffix D ate of Birth Race hie Fe al Address Allendale 414 Apartment l Camp City Hill I State PA 1 Zip Code 17011 Phone Number 1 Area Code 1 7 7 1 613465 umber Ext Phone Type P hone Number 2 Area Code 7 17 Number 7613465 EM i Phone Type Work Notify Complainant Call Taker ID Y Dispatcher ID 1 cNET Complaint #: 1151737 User Defined Feld 1 User Defined Field 2 & W User Defined Field 3 ed Field 4 ! .s}fit. Salutation Name Middle Name I Last Name Suffix M SNY Date of Birth 01/11/1969 Race hite Sex Type -Male dress 417 Allendale WY Apartment City State Zip Code 1 l Camp Hill IPA 17011 Phone Number 1 Area Code Number Ext Phone Type 7 17 l 19751880 Phone Number 2 Area Code Number J EXI Phone Type i 717 1 7610574 cell User Defined Field 1 Dog Owner User Defined Field 2 User Defined Field 3 User Defined Field 4 9/30/2011 1:53:56 PM Page 2 of 3 Officers Involv'64 Elias -1819 - Lower Allen Twp Reporting Officer [1819 Dispatched ___ - _ - - - EnrWe 06120/2010 20:16:00 AMved cleared 06/20/2010 5:00 06/20/2010 20:32:00 Field 1-2 uennea neid 2 9/30/2011 1:53:56 PM Page 3 of 3 "EXHIBIT 0 " Complaint Report fir:'-•.??r.-Ll?t?"'?? c?,?:,.? Commonwealth of Pennsylvania Lower Allen Twp Co a t Information Complaint Number Locked Record Follow Up I Call For Service 11 7 No I No PHARNA Description PHARASSMNI NOT ACT Status Priority Method Received Dateffime Received Cleared 5 I Phone 1 08/25/2010 10: 0 Day of the Week How Handled Wednesday Officer slaned Complaint Nature Jodi Teffeteller reported her daughter, Ruby, was harassed by a man walking dogs yesterday. She will talk to her dauahtar to saa if a rharae will he filed. More to follow. Complaint Location Street Number Street Block Predirection Street Name ICenter Street Type DR Postdirection I PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Cumberland Jurisdiction Number Location Township Lower All wrishig) Magisterial District 9-1-01 Citylrown m Hill Political Subdivision State Zone Number PA 1 Zip Code 17011 Area Grid 1203 Residence Type Unit Type Unit Number Latitude 0.00 Longitude 0.00 Location Type Residence Home Country United a e of Ameri a A Location Description 9/30/2011 1:55:06 PM Page 1 of 4 Complainant Information Salutation F Jodi Middle Name Last Name Suffix Date of Birth 7- Acidness 6 Center Dr Apartment I City Camv Hi I State PA 1 Zip Code 17011 Phone Number 1 Area Code 7 7 1 Number 6080198 I Ext Phone Type Icell -1 Phone Number 2 Area Code 717 Number Ext Phone Type Notify Complainant Call Taker ID Dispatcher ID 1 MET Complaint M 1186050 User Defined Field 1 User Defined Field 2 User Defined Field 3 F Id4 9/30/2011 1:55:06 PM Page 2 of 4 Complainant Assoclate e. ' tion . _ . lhi6rm-e Salutation First Name Middle Name Last Name I Sutfix IRUBIE IT TEFf Date of Birth Race 7 x Association Type 06/30/1995 hie male E4 Victim Address 6 CENTER Q- Apartment city State Zip Code 1 17011 CAMP HILL A Phone Number 1 Area Code Number lExt Phone Type 717 1975-2552 I lHorne Phone Number 2 Area Code Number EA Phone Type User Defined Feld 1 User Defined Field 2 Victim User Defined Field 3 User Defined Field 4 Suffix Salutation rst Name Middle Name I Last Name EASON M SNYD Date of Birth 01/11/1969 Race I Sex I Association Type ale Suspect Address 41 Allendale Apartment City State Zip Code 1 I 17011 PA IlCarnp Hill Phone Number 1 ea Code Number E),t l Phone Type 71 J 7 1 0 Horne Phone Number 2 Area Code umber E4 Phone Type 717 J T7610574 Cell User Defined Field 1 User Defined Reid 2 c d User Defined Feld 3 User Defined Feld 4 9/30/2011 1:55:06 PM Page 3 of 4 Officers Involved Dispatched M51201,0 10:35:00 Enroute 0812512010 10:35:00 eared 08125=10 10*40:00 Dennea Meta 1-2 Detrn00 Ftwaz , -1 WWJQ".,-- Incident Number 7 1 Datefnme Started 08/2412010 08:00.00 1 Location 6 Center DR. C amp Hill, P 1 7011 rL?ed 9/30/2011 1:55:06 PM Page 4 of 4 rtis, Edward -1817 - Lower Allen Twp (Reporting Officer 11817 "EXHIBIT P" Magisterial District Judge 09-1-01 ..?f "?rYk T, .3 Docket Number: MJ-09101-NT-0000881-2010 Non-Traffic Docket Commonwealth of Pennsylvania V. Jason M Snyder Page 1 of 3 C,?s 1f .i'' Y •: M - .• ' t+' . "a';3: t.. f;' 7x+' ;s j1r I .F,OR ry. ''1;; c,Y, t ,ap rr n? a^t a.y'p .t, d'S` 1 k? Judoe Assigned: Magisterial District Judge Charles A. Issue Date: 08/24/2010 Clement Jr. OTN: File Date: 09/07/2010 Arresting Agency: Lower Allen Township Police Dept Arrest Date: Citation #: P8487261-3 Disoosition: Guilty Plea Coun : Cumberland Disposition Date: 09/27/2010 Township:: Lower Allen Township Case Statu s: Closed win{ e 59 ,...K X Case Status Status Date Processing Status Closed 03/17/2011 Completed 09/27/2010 Case Balance Due 09/27/2010 Case Disposed/Penalty Imposed 09/27/2010 Awaiting Sentencing 09/07/2010 Awaiting Plea Name: Snyder, Jason M Sex: Male Date of Birth: 01/11/1969 Race: White Address(es): Primary Camp Hill, PA 17011 Advised of His Right to Apply for Assignment of Counsel? No Public Defender Requested by the Defendant? No Application Provided for Appointment of Public Defender? No Has the Defendant Been Fingerprinted? No .:? c,.G..ASE PARTICIPANTS Participant Type Participant Name Arresting Officer Curtis, Edward Charles Defendant Snyder, Jason M 's t y yY:,r'CHA Ste' ?s .}:OWN" ,?L K # Charge Grade Description Offense Dt. Disposition 1 18 § 5503 §§ A4 S Disorder Conduct Hazardous/Physi Off 08/24/2010 Guilty Plea C P0- IL J / S 1 G G D TAILS Case Disoosition Disposition Date Was Defendant Present? Guilty Plea 09127/2010 Yes Offense Sea./Description Offense Disposition 1 Disorder Conduct Hazardous/Physi Off Guilty Plea - --- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - MDJS 1200 Printed: 10105/2011 2:26 pm Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 at seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. Magisterial District Judge 09-1-01 ? W P DOE E' Docket Number: MJ-09101-NT-0000881-2010 Non-Traffic Docket Commonwealth of Pennsylvania V. Jason M Snyder Page 2 of 3 ISVRYE EN RY I. FOB„ AT?OfI{' _ tt:'ti Filed Date Entry Filer Applies To 03/17/2011 Penalty Satisfied Magisterial District Court 09-1-01 Jason M Snyder, Defendant 09/27/2010 Penalty Assessed _Magisterial District Court 09-1-01 _ Jason M Snyder, Defendant 09/27/2010 Guilty Plea Magisterial District Judge Charles A . Jason M Snyder, Defendant -Clement Jr_ _ _ _ _ _ _ 09/09/2010 Certified Summons Accepted - - - _Magisterial District Court 09-101_ - Jason M Snyder, Defendant - - _ - 09/08/2010 Summons Issued _Magisterial District Court 09-101_ _ Jason M Snyder, Defendant _ - 09/0812010 Certified Summons Issued _Magisterial District Court 09-1-01 Jason M Snyder, Defendant _ _ _ _ 09/07/2010 Non-Traffic Citation Filed Magisterial District Court 09-1-01 Jason M Snyder, Defendant Payment Plan No. 09101-2010-P0000999 Payment Plan Freq. Monthly Next Due Date Active Next Due Amt. Overdue Amt. No $0.00 $0.00 Responsible Participant Snyder, Jason M Payment Plan History: Payment Dt. Transaction Type 11/04/2010 Payment 11/29/2010 Payment 01/26/2011 Payment 02/10/2011 Payment 03/17/2011 Payment Pavor Participant Role Amount Snyder, Jason M Defendant $40.00 Snyder, Jason M Defendant $40.00 Snyder, Jason M Defendant $80.00 Snyder, Jason M Defendant $30.00 Snyder, Jason M Defendant $102.60 MDJS 1200 Page 2 of 3 Printed: 10/0512011 2:26 pm Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 at seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. Magisterial District Judge 09-1-01 E, 0.1. {,Y' F .. -..? - . ?k..? l%A'r T. ..:. Docket Number: MJ-09101-NT-0000881-2010 Non-Traffic Docket Commonwealth of Pennsylvania I V. Jason M Snyder Page 3 of 3 `EASE FINid IAH_lIN OF MATION ' ks 1 Case Balance: $0.00 Next Payment Amt: Last Payment Amt: Next Payment Due Dt: Non-Monetary Assessment Tvoe Assessment Amt Adjustment Amt Payment Amt Payment Amt Balance Judicial Computer Project $8.00 $0.00 $0.00 ($8.00) $0.00 ATJ $3.00 $0.00 $0.00 ($3.00) $0.00 CJES $2.25 $0.00 $0.00 ($2.25) $0.00 JCPS $10.25 $0.00 $0.00 ($10.25) $0.00 County Court Cost (Act 204 of 1976) $28.20 ($28.20) $0.00 $0.00 $0.00 State Court Costs (Act 204 of 1976) $7.65 ($7.65) $0.00 $0.00 $0.00 Commonwealth Cost - HB627 (Act 167 of $7.65 ($7.65) $0.00 $0.00 $0.00 1992) County Court Cost (Act 204 of 1976) $28.20 $0.00 $0.00 ($28.20) $0.00 State Court Costs (Act 204 of 1976) $7.65 $0.00 $0.00 ($7.65) $0.00 Commonwealth Cost - HB627 (Act 167 of $7.65 $0.00 $0.00 ($7.65) $0.00 1992) Crime Victims Compensation (Act 96 of 1984) $35.00 $0.00 $0.00 ($35.00) $0.00 Victim Witness Service (Act 111 of 1998) $25.00 $0.00 $0.00 ($25.00) $0.00 Domestic Violence Compensation (Act 44 of $10.00 $0.00 $0.00 ($10.00) $0.00 1988) Postage - Case $5.60 $0.00 $0.00 ($5.60) $0.00 Title 18 - Payable to Municipality $150.00 $0.00 $0.00 ($150.00) $0.00 MDJS 1200 Page 3 of 3 Printed: 10/05/2011 2:26 pm Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 at seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. "EXHIBIT Q" Complaint Report Commonwealth of Pennsylvania Lower Allen Twp Complaint Information Complaint Number Locked Record Follow Up Call For Service 0 8-01134 No INo I PORQVI Description PORDINANCE VIOL Status Priority Method Received DatelTime Received Cleared 4 I Radlo Di atch 108125/2010 12:16:0 Day of the Week How Handled Wednesday Office A signed Complaint Nature Helen Gussler was bitten by a dog whose owner had it off a leash. Unknown who the owner is at this time. See comments for details. Complaint 12ocation Street Number Street Block Predirection i Street Name Street Type Postdirection 1325 iCarlisle PC Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County J urisdiction Number Cumberlan d Location Township Magisterial District City/Town Political Subdivision Allen Lower Townshi 9-1-0 C Hill State Zone Number Zip Code Area Grid Residence Type Unit Type P 1 7011 1 03 Unit Number Latitude Longitude Location Type Country 40.2 9648 -76.897968 P rk ' ound U United States of America Location Description 1325 CARLISLE RD LAC 132 CA LISLERDLA U 9/30/2011 1:55:51 PM Page 1 of 7 01pant Information Comp Salutation First Name Do Middle Name Last Name Enders Suffix Date of Birth I WhIte Race Sex Address 1325 Carlisle d Apartment I QamR City Hill I State PA 1 Zip Code 17011 Phone Number 1 Area Code 1 Number Ext Phone Type Phone Number 2 Area Code 717 Number 9019860 Ext I Phone Type Work Notify Complainant No Ca#Taker iD BOWE Dispatcher ID WHO R cNET Complaint #: A186020 User Defined Field 1 User Defined Field 2 E ' User Defined Field 3 st§r ed Id 4 91 771,11 Salutation First Name ]HELEN Middle Name I Last Name GUSAI M Suffix Date of Birth 03111/1955 Race on Sex Type I 7vica, Address T artment I City I CAMP HILL PA State 1 Zip Code 17011 Phone Number 1 Area Code Number J Ext Phone Type Phone Number 2 Area Code Number l Ext Phone Type User Defined Feld 1 V? User Defined Feld 2 User Defined aid 3 User Defined Field 4 9/30/2011 1:55:51 PM Page 2 of 7 Salutation First Name Middle Name l Hiabland EIOM nta[y Last Name S chool Suffix Date of Birth Race Sex Association Type Address 1325 Carlisle Rd Apartment Lamp ty Hill I State PA 1 Zip Code 17011 Phone Number 1 Area Code 717 1 Number 9999999 J E)d l Phone Type Home Phone Number 2 Area Code 1 Number Fact Phone Type User Defined Field 1 School User Defined Field 2 User Defined Feld 3 User Defined Field 4 Salutation First Name IJASON Middle Name Im Last Name Suffix Date of Birth 0 1 1969 Race hite ciation Type Cale Asso Address 417 Allendale WY Apartment HIII FCAM State P Zip Code 117011 Phone Number 1 Area Code 717 TN er 1 80 Ext Tpe THo me Pho ne Number 2 Area Code 71 Number 17610574 Ext Phone Type ICeII User Defined Field 1 u ct User Defined Field 2 User Defined Field 3 User Defined Field 4 Salutation T FIrst Name Kathleen I Middle Name Anne I Last Name Murphy uffix Date of Birth 04/ /1976 Race White Sex Fema a sciation Type Address 160 Letchworth RD Apartment I City Camp it I State PA 1 Zip Code 17011 Phone Number 1 Area Code 717 1 Number 7129205 Ext l Phone Type Home Phone Number 2 Area Code Number l Ext Phone Type User Defined Field 1 Witness User Defined Field 2 User Defined Field 3 User Defined Field 4 9/30/2011 1:55:51 PM Page 3 of 7 Salutation First Name Middle Name Last Name Suffix Date of Birth Race ' e I Sex Female sociation Type Address 311 Manchgater Rd Apartment City amp Hill I State PA Zip Code 117011 Phone Number 1 Area Code 717 1 Number I 8053682 lExt Phone Type Cell Phone Number 2 Area Code 7 Number Ext Phone Type User Defined Feld 1 Doa Owner User Defined Field 2 User Defined Field 3 User Defined Field 4 DispB[ched 08/25MO10 12:21:00 Enrage Arrived 0 Cleared 0§=?010 12:46.,00 Defined Field 1-2 9/30/2011 1:55:51 PM Page 4 of 7 Officer Name ?sslstlng le Resource # Williamson, Frank -1801 - Lower Allen Tw Officer 11801 Street Number Street Block Predirection Street Name 0 Street Type i prostdirection PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Cumberland- - Jurisdiction Number Location Township Magisterial District City/Town Political Subdivision State Zone Number Zip Code Area Grid Residence Type Unit Type Unit Number Latitude 0.00 Longitude 0.00 Location Type Country United St ates America (USA) Location Description 0000 Dispatched 08125/2010 12 :27:00 Enroute Arrived 08/25/2010 12:27:00 Cleared OBL251201 0 12 :46:00 User Defined Field 1-2 V User Defined Field 2 User Defined Field 3 User Defined Field 4 Attachments '-FW tW kc denfs," 77-1 Incident Number LAT2 1 -0 -01134 1 Date/Time Started 08/25/2010 12:16:00 1 Location 1325 Carlisle RD Cam Hill PA 17011 Status Close Comments 1. 1 9/30/2011 1:55:51 PM Page 5 of 7 inal narrative by 18-16, Ofe Claeys, on 08125/10 ispatched to meet with the Principal of Highland Elementary School in reference to their janitor, Helen Gussler, Bing bit by a dog. responded and met with Gussler. She informed me that a white male had about six or seven dogs, off of Bashes, in the field hockey field of Highland Elementary School. She approached him to inform him that he ouid not be there. When she began to approach, the dogs began to run towards her. She said that the dogs Limped on her, and one bit her on the left hip. She showed me the injury and it was a small scratch, that did not ppear to break the skin. She was wearing jeans at the time. She did not want any medical treatment for the ite. sler told me that she told the man that he could not be there, and he said that he was unaware that school in session. Gussler then asked for his name, and he would not provide it to her. He then left the area, last i on foot, with the six or seven dogs, heading west on Carlisle Rd towards Lowther Rd. Williamson checked the area, as did I, and we were unable to locate the suspect. issler said that she is familiar with the usual person who walks dogs in the area and stated that it was not n. She said that he usually has all different breeds with him. She said that this suspect had only two breeds dogs, being German Shepards and possibly Pit Bulls. All the dogs were adult dogs. he description of the suspect is a white male, with short hair, or bald, wearing a tan shirt and green shorts, with lasses. Gussler said that he appeared to be in his. 30's. will send an e-mail out to patrol to stop any individual matching this description and identify him. upplemental by Chief Williamson 18-01 n 08-25-2010, 1 heard the dispatch for the dog bite at HighlandEllementary School. The suspect, a w/m, white T girt and a ball cap, walking 7-8 dogs was last seen North on Commercial Dr. entered the Highland Park neighborhood on Letchworth Rd from 18th Street and commenced a search of the rea, including Chatham Playground, Highland Park, Cedar Cliff Mall, Carlisle Rd, and Cedar Cliff Manor, with no :er Claeys indicated the subject was walking what appeared to be only two breeds of dogs, German pards and Pit Bulls. The victim was also to be familiar with our normal dog walked in the area, who usually multiple breeds of dogs, and does not believe this to be the same person. by Ofc. Martinez on Thursday, August 26, 2010 this date Marilyn Broden, who works for the Cumberland County Dept. of Health, called to speak with the cer handling this call. I informed her that Ofc. Claeys was not available and asked if there was something I iId help her with. Broden asked if we knew who the biting dogs owner was and 1 informed her that we were astigating the bite but the owner had not been located yet. Broden asked if someone could call her if the ,ier was located so that they could also follow up with the homeowner. I Informed her that 1 would give Ofc. eys her contact information in the event that he did find the dog owner. Broden said that she understood. 9/30/2011 1:55:51 PM Page 6 of 7 plemental report by 18-16, Ofc Claeys, on 08/27110 108/26/10,1 was patrolling the area of Letchworth Rd and saw a white male walking several dogs that appeared be of two different breeds. stopped and spoke with him, and he was identified as Jason Snyder. He denied being involved in the incident t Highland Park. As we finished talking with him, Kathleen Murphy came over to my patrol car and said that she ritnessed the dog bite yesterday, and Snyder was the man there with the dogs. I obtained her information and hanked her. 1 then reapproached Snyder and informed him of this and he said that it was him and the dog that ,it Gussler was "Utley". tley is owned by Sharon Burke at 311 Manchester Rd. We went to the Burke residence and spoke with Sharon, ho provided me a copy of Utley's medical records, indicating that the dog was current on all vaccines. I made photocopy of this record gave a copy to Gussler. A copy is also attached to this report. irylin Broden, from the Department of Health, was called and provided with all this information as well. A copy the medical record for the dog was sent to her via fax. She said that she will send a letter to Burke indicating A the dog must be quarantined for 10 days, and she will make contact with the victim as well. will be cited for not having the dog on a leash at the time of the bite. incident report. 9/3012011 1:55:51 PM Page 7 of 7 "EXHIBIT R " Township of Lower Allen, PA § 65-6. Running at large. Page 1 of 1 Township of Lower Allen, PA Monday, October 3, 2011 [Amended 11-9-1998 by Ord. No. 98-121 No owner of any dog, cat, domesticated animal. or any nondomesticated animal shall allow such dog, cat, domesticated animal or any nondomesticated animal to run at large at any time, either upon any of the streets, alleys or public grounds in the township or upon the property of another person other than the owner of such dog, cat, domesticated animal or any non- domesticated animal, and not being firmly secured by means of a collar and chain or other device so that it cannot stray or not being accompanied by or under the reasonable contact of some person. Any police officer or law enforcement officer is hereby authorized and empowered to seize and detain any dog, cat, domesticated animal or any nondomesticated animal which is found running at large in the township or upon the property other than the owner of such dog, cat, domesticated or any nondomesticated animal and unaccompanied by the owner when such police officer or law enforcement officer is in immediate pursuit of such dog, cat, domesticated animal or any nondomesticated animal. "EXHIBIT S " Magisterial District Judge 09-1-01 Docket Number: MJ-09101-NT-0000860-2010 Non-Traffic Docket Commonwealth of Pennsylvania V. Jason Matthew Snyder Page 1 of 2 we Y. TON 1`o?nt `? ` ', a?-r1 rq ?z Judge Assigned: Magisterial District Judge Charles A. Issue Date: 08/25/2010 Clement Jr. OTN: File Date: 08/30/2010 Arrestina Agency: Lower Allen Township Police Dept Arrest Date: Citation #: P8426666-3 Disoosition: Guilty Plea Coun : Cumberland Disposition Date: 09/07/2010 Tow nshlix Lower Allen Township Case Status: Closed ..,? w ?S •+W!'e«try ?j4? _ '! a.' t C' la-:: $t u t s9,?,iy x e ^,My+4 4 ' ,°dL'r t`. " ? £ ; . 't( ' ...,. , _.. lf, • , n . . Case Status Status Date Processing Status Closed 09/27/2010 Completed 09/07/2010 Case Balance Due 09/07/2010 Case Disposed/Penalty Imposed 09/07/2010 Awaiting Sentencing 08/3012010 Awaiting Plea 1'yCMik.ll?i A Ki'1s±ct?'`, t ??£ 'I;r Name: Snyder, Jason Matthew Sex: Male Date of Birth: 01/11/1969 Race: White Address(es): Primary Camp Hill, PA 17011 Advised of His Right to Apply for Assignment of Counsel? No Public Defender Requested by the Defendant? No Application Provided for Appointment of Public Defender? No Has the Defendant Been Fingerprinted? No :Y--.t 'k @i .'ntYw}fi ?vt, .:fs( ,w !;t - nh?. G;i'? Rv-AS4<r,+r t@E5?.,1.C7'f%'i44'!F?:' •'h Participant Tvoe Participant Name Arresting Officer Claeys, Matthew B Defendant Snyder, Jason Matthew .'" } ry'?e•54.. 1 ,%.-'.:~. 3 '' r .-?f ! ' _•^r : trCHA # Charge Grade Description Offense Dt. Disposition 1 LO § 65 §§ 6 S Running A t Large 08/25/2010 Guilty ytPleay 600 571 ni7swWwwow Case Disposition Guilty Plea Offense Sea./Description 1 Running At Large Disposition Date Was Defendant Present? 09/07/2010 Yes Offense Disposition Guilty Plea MDJS 1200 Printed: 10/04/2011 9:41 am Recent entries made in the courtfiling offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 at seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. Magisterial District Judge 09-1-01 r Docket Number: MJ-09101-NT-0000860-2010 Non-Traffic Docket Commonwealth of Pennsylvania V. Jason Matthew Snyder Page 2 of 2 Ex ;; r r- i REGI`EJ?ITl'clt Filed Date Entry Filer Applies To 09/27/2010 Penalty Satisfied -Magisterial District Court 09-101 - Jason Matthew Snyder, Defendant _ 09/07/2010 Penalty Assessed Magisterial District Court 09-101 Jason Matthew Snyder, Defendant 09/07/2010 Guilty Plea - Magisterial District Judge Charles A. _ Jason Matthew Snyder, Defendant _Clement Jr. _ _ _ _ _ _ _ _ _ _ _ 09/01/2010 Certified Summons Accepted -Magisterial District Court 09-1_01 _ Jason Matthew Snyder, Defendant - - 08/31/2010 Summons Issued Magisterial District Court 09-1-01_ Jason Matthew Snyder, Defendant- _ _ - 08/31/2010 Certified Summons Issued - - Magisterial District Court 09-1-01 - - - - - - - - - - Jason Matthew Snyder, Defendant - - - - - - - - - - - - - - - - 08/3012010 - - - - - - - Non-Traffic Citation Filed - - - - -Magisterial District Court 09-101 _ Jason Matthew Snyder, Defendant ;i` y T J?;W NT P41( .aJ 5. Y r r? ..,. j? lh$p'? Payment Plan No. Payment Plan Frea. Next Due Date Active Next Due Amt. Overdue Amt. 09101-2010-P0000944 Biweekly No $0.00 $0.00 Responsible Participant Snyder, Jason Matthew Payment Plan History: Payment Dt. Transaction Type Pavor Participant Role Amount 09/27/2010 Payment Snyder, Jason Matthew Defendant $57.60 10/23/2010 Payment Snyder, Jason Matthew Defendant $65.00 .r Case Balance: $0.00 Last Payment Amt: Next Payment Amt: Next Payment Due Dt: Non-Monetary Assessment Type Assessment Amt Adjustment Amt Payment Amt Payment Amt Balance Judicial Computer Project $8.00 $0.00 $0.00 ($8.00) $0.00 ATJ $3.00 $0.00 $0.00 ($3.00) $0.00 CJES $2.25 $0.00 $0.00 ($2.25) $0.00 JCPS $10.25 $0.00 $0.00 ($10.25) $0.00 County Court Cost (Act 204 of 1976) $28.20 $0.00 $0.00 ($28.20) $0.00 State Court Costs (Act 204 of 1976) $7.65 $0.00 $0.00 ($7.65) $0.00 Commonwealth Cost - HB627 (Act 167 of $7.65 $0.00 $0.00 ($7.65) $0.00 1992) Postage - Case $5.60 $0.00 $0.00 ($5.60) $0.00 Local Ordinance $50.00 $0.00 $0.00 ($50.00) $0.00 MDJS 1200 Page 2 of 2 Printed: 10/04/2011 9:41 am Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 et seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. "EXHIBIT T" Complaint Report Commonwealth of Pennsylvania Lower Allen Twp C aint Inform?teon Complaint Number l Locked Record Follow Up Call For Service -00678 No No PAN CP Description PANIMAL COMPLAINT Status Priority Method Received DatelTime Received Cleared I Radio Dispatch 0 15/2010 11:30:00 Day of the Week How Handled Wednesday Officer A signed Complaint Nature Pat Townsend reported dogs barking 417 Allendale Way. Jason Snyder, son, and Isabel Snyder, mom, run a kennel out of the residence in violation of State and Twp laws. State Dog Warden Shrawder responded and John Ebv. TwD codes. was notified. See comments. (mplaint-Lo'?aon Street Number Street Block Predirection Street Name Street Type Postdirecdon 417 1 ALL DA WY PC Box Cross-Predirection Cross-Street Name CmssStreet Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number Cumberland Location Township Magisterial District City/Town Political Subdivision Lower Cam Hill State Zone Number Zip Code Grid Residence Type Unit Type A 1 1-7011 1202 Unit Number Latitude Longitude l Location Type Country 0. 2 966 -76.8 0 Residencefflome .Stat Urdted es of America Location Description 417 L D LE WY LAC 417ALL DALEWYLACU 9/30/2011 1:56:45 PM Page 1 of 7 Complainant Information Salutation First Name PAT Middle Name Last Name TOWN Suffix Date of Birth 7- IS ex Address 416 QLACKLATCH LN Apartment I City CAMP L I State PA Zip Code 117011 Phone Numbers Area Code 717 1 Number l 761"25 Ex, Phone Type IHome Phone Number 2 Area Code 717 Number 7614425 Ext l Phone Type Home Notify Complainant No Call Taker ID JTMccO Dispatcher 1l) 1 JMB MET Complaint A 1195914 User Defined Field 1 User Defined Field 2 User Defined Field 3 . "' ed Field 4 r Salutation Jason Middle Name IM I Last Name Snyder Suffix Date of B irth Chite Sex Type adon ddress 1137 Columbu s v rtment City State PA Zip Code 17043 Phone Number 1 a Code 717 Number l 19751880 Ext l Phone Type Home Phone Number 2 Area Code 717 Number Ext Phone Type User Defined Field 1 suspect User Defined Field 2 User Defined Field 3 User Defined Field 4 9130/2011 1:56:45 PM Page 2 of 7 Salutation First Name lJohn Middle Name l Last Name Eby Suffix Date of Birth Race Sex sociation Type Address 2233 G bur Rd Apartment Hill I Earna State PA 1 Zip Code 17011 Phone Number 1 Area Code 717 1 Number I 9757575 lExt Phone Type Phone Number 2 Area Code 717 Number l Ext Phone Type User Defined Field 1 LA CODES User Defined Field 2 User Defined Field 3 User Defined Field 4 Salutation First Name INatahnee Middle Name Last Name IShrawder Suffix Date of Birth Race I W it gex Fem le ssodation Type Address 2301 Cameron St Apartment Room 1 Zarrjlsbrq State P Zip Code 1710 Phone Number 1 Area Code 717 Number 15641680 Ext Phone Type IWork Phone Number 2 Area Code Number Ext Phone Type User Defined Field 1 ad n User Defined Field 2 User Deflned Field 3 User Defined Field 4 Salutation First Name Isabel Middle Name i Last Name Snvder r uffix Date of Birth ChIte e I Sex Fernale Association Type Address 417 Allendale Way Apartment l Carnp Hill City I State PA 1 Zip Code 17011 Phone Number 1 Area Code 7 17 1 Number 7610514 Ext Phone Type' Home Phone Number 2 Area Code 717 Number Fitt Phone Type User Defined Field 1 homeowner User Defined Field 2 User Defined Field 3 User Defined Field 4 9/30/2011 1:56:45 PM Page 3 of 7 John -1823 - Lower Allen Twp lArresting Officer 11823 t d Street Number Street Block Predirection Street Name Street Type Postdirection PO Box Cross-Predirecdon Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County ?cuMherllilnd Jurisdiction Number Location Township Magisterial District City/Town Political Subdivision State P Zone Number Zip Code Area Grid Residence Type Unit Type Unit Number Latitude .0 Longitude OM Location Type Country UnjWd States of America (USA) Location Description 417 Dispatched 09/15/2010 12 :07:00 Enroute Arrived 12 :07:00 Cleared 12 10 *59.00 User Defined eld 1-2 2 User ned' d 2 User Defined Field 3 User Defined Feld 4 Officer Name ?sslstlng le Resource # Cypress, John -1854 - Lower Allen Twp Officer 11854 ,&=on Qipi,?aai. Street Number mu Street Block Predirection Street Name Street Type Postdirection PO Box Cross-Predirection Cross-Street Name 7 7s-SVeet?ype Highway Name Highway Number Highway Milepost Rural Route County Cumbgriand Jurisdiction Number Location Township Magisterfal District City/Town Political Subdivision State PA Zone Number Zip Code I Area Grid Residence Type Unit Type Unit Number Latitude 0.00 Longitude 0 Location Type Country United %afts of America (USA) Location Description Dispatched 091151ZO10 11 :44:00 Enroute Arrived Cleared 0 12 :59:00 9 De iiad Field 1-2 5 O 2 user eat User Defined Field 3 User Damned Field 4 9/30/2011 1:56:45 PM Page 4 of 7 7cer Name Role Resource Or Gelnett, Thomas -1811 - Lower Allen Tw lReporting Officer 11811 Street Number Street Block Predirection Street Name Street Type Postdirection PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Cumberlan d Jurisdiction Number Location Township Magisterial District Citylrown Political Subdivision State Number Zip Code Area Grid Residence Type Unit Type Unit Number E Longitude n -an Location Type Country Un•te S'- '---' 'erica SA Location Description 17 LLENDALE WY LA CU417ALLENDAL WYLACUO Dispatched 09/15/2010 11:32:00 Enroue AMved 09115/201011:44:00 Cleared 091151201012:59:00 User Defined Field 1-2 User Defined Feld 2 User Defined Feld 3 User Defined Field 4 9/30/2011 1:56:45 PM Page 5 of 7 Iriginal report by Officer Gelnett on 9-15-10. was dispatched to 417 Allendale Way for dogs barking. County advised the caller stated this is a constant roblem. I responded with CSO Cypress. Upon arrival I could hear a dog barking in the rear yard. There were o cars in the driveway. I rang the doorbell and knocked on the door but no one answered. I was able to bserve three brown boxers and a black german shepard inside the residence. There was water visible in the lichen in bowls on the floor. The dog in the back yard was a tan boxer mix that had a bowl but I could not see if sere was any water in it. The mailbox was full of mail and the two front doors to the residence where Mocked. The back door, inside the fenced in area where the dog was, was open however the screen door was but so the dogs could not get outside and the dog outside could not get inside. There was also no car in the DSO Cypress left a ordinance in the mailbox for dogs barking and disturbing the neighbors. attempted numerous times to get someone to answer the door by ringing the doorbell and knocking on the loors. This just upset the dogs more and they barked constantly and ran back and forth between the two front loors. I observed a two page cease and desist order posted on the door from the Bureau of Dog Law °_nforcement on 7-13-10 stating that Jason Snyder was in violation of the kennel law and was demanded to cease ind desist operating a kennel, etc. called John Eby, Lower Allen Township Codes, and asked what his knowledge of the residence was. He nformed me that Isabel Snyder, the owner of the residence, was an elderly female and her son, Jason Snyder, soused the dogs at her residence. He actually lives on Columbus Ave. The Township has been working with ielghbors in trying to resolve the dog issues and the State Dog Law Officer has been involved. Eby statue that lason is only permitted to have four dogs on the property and those are the dogs that he and his mom own, hree boxers and a german shepard. If there are any other dogs on the property then he is in voiiation of the :ennel laws and is subject to civil and criminal prosecution. 1 was asked to document my observations and orward a copy of the complaint to Codes. I was also asked to take pictures of the dogs and conditions. :by also informed me that Isabel was an elderly woman and Jason was to be her caregiver, either staying at or oming to the residence frequently to take care of Isabel. There was some concern about whether she was come or not and If she was okay. also called the State Dog Warden from the number posted on the notice and left a message for one of them to ive me a call. Officer DeSantis was requested to come to the scene to assist if we needed to go inside the esidence or if Jason arrived. While talking to Eby a neighbor came over and advised he had seen Isabel yesterday. She had brought some ears over to his house. The neighbor, who lived to the right of Isabel's house, stated that she is hard of hearing nd she may not hear the door if she has her hearing aids out. He has not seen her today but she does have a ar that is usually in the garage. We looked in the windows of the garage again and there was no car iside. This made me feel confident that Isabel was more than likely not at home. atahnee Shrawder, State Dog Warden, called me and informed me that she is familiar with the residence and ason. She also confirmed that there area only too be Jason and Isabel's four dogs at the residence. Any more Ian those four dogs would be a violation. Shrewder stated she was about ten minutes away and would respond > document the additional dog(s) and see what violations where present. She requested we remain at the .sidence until she arrived and documented conditions. hrawder arrived and shortly afterwards Jason drove in the driveway with a black and white dog in the car. He imoved this dog from the car and was walking it on a leash on the property when I approached him. At this Dint there were three police cars and the State Dog Warden vehicle in front of the residence. Jason asked what as going on and I informed him that someone called about the dog in the back yard barking and disturbing iem in violation of the Township ordinance. He stated his mom must have left without letting this dog back in ie house. 3son was told that he was also in violation of operating a kennel, and the notice posted on the door, which he of. told he was only i d to have fb&W deAn gg the Property and he .knowl2ft he visa aware 9/30/2011 1:56:45 PM Page 6 of 7 his and Isabel's four dogs. Jason stated he was trying to stop but could not completely shut down his ass. Jason stated the tan boxer mix in the back yard was his. He also stated the two brown boxers and the german shepard were his. The one brown boxer inside was Maggie, a clients dog. The terrier mix, he brought in the car with him was also a clients. Shrawder requested the owners information. Jason I he would call her with this. of the dogs had visible license displayed on their collars. Jason stated that they all had their shots and properly licensed. Shrewder was able to verify for me that Jason's four dogs had all their license and . Shrawder will follow up with the owners of the two other dogs to verify license and shot records. ider photographed the two dogs that where not permitted on the property for her case. n stated several times that he was trying to limit the number of dogs and comply with the law. 1 told him time that he needed to comply with the law and not just try. I used the example of someone who did not a drivers license but continued to drive and tried to use the excuse that the were trying to comply with the It was still a violation. informed Jason that he was in violation of the kennel law and the township ordinance for loud and disturbing arking. Shrawder also advised him if any dog was outside for more than an hour it would need to be provided halter. Shrawder also advised Jason if any dog was off the property of the owner that it would need to be ispiavina a license. Jason stated he understood. advised Jason that he would probably be receiving several charges for the above violations. Jason was told he eeded to remove the two dogs, that where not his or his moms, from the property immediately. Jason said he rawder will coordinate with me and Eby in filing charges. I e-mailed a copy of this report to Shrawder and 9/30/2011 1:56:46 PM Page 7 of 7 "EXHIBIT U 11 Complaint Report p Commonwealth of Pennsylvania Lower Allen Twp Comp{ nformation Complaint Number Locked Record Follow Up Call For Service 88 No INo I PORDVI Description PORDINANCE VIOL Status Priority eceived 7 DateMme Received Cleared 4 Dis atch1 Rad!o 05/09/201108:52:00 Day of the Week How Handled Monday Officer signed Complaint Nature Jason Snyder, dog behaviorist, left 11 dogs he was walking break loose and attack another dog. Another resident who assisted -got bit b one of the dogs. Snyder cited. '.Complaint Location Street Number Street Block Predirectlon Street Name Street Type Postdirection 300 MANCHE STER D PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number Cumberl and Location Township Magisterial District City/Town Political Subdivision Lower Allen To nship 09-1-01 m Hill State Zone Number Zip Code Area Grid Residence Type Unit Type P 1 17011 1203 Unit Number Latitude Longitude I Location Type Country 4 . 177 -76.896601 H!ghway /Road/Alley United Sta SA tes of Ameri Location Description 31 MANCH ESTER RD ,LA CU310MANCHESTERRDLACU 9/30/2011 1:58:29 PM Page 1 of 6 Complainant Information Salutation EKy me Middle Name Last Name lKnirie Suffix Date o f Birth Race i Sex iMale Address MANCHESTER 310 D Apartment I City CAME HILL I State PA 1 Zip Code 17011 Phone Number 1 Area Code 717 1 Number 7637349 I Ext Phone Type lHome Phone Number 2 Area Code 717 Number Ext l Phone Type Home Notify Complainant No Call Taker ID Dispatcher ID wMO 1 F cNET Complaint #: 1=71 User Defined Field 1 . Defined Field 2 User Defined Feld 3 Use' Defined Field 4 Coat a t4saociate Informs o1n Salutation First Name ASON Middle Name Last Name Suffix Date of Birth 0111 Race Sex atlon Type Address 417 Allendale WY Apartment l Camp City Hill State A Zip Code 117011- Phone Number 1 Area Code 717 Number 975188 0 Ext 1 Phone Type Home Phone Number 2 a Code 7 1 Number 7610574 Ext I Phone Type COI] User Defined Field 1 suspect User Defined Field 2 User Defined Field 3 User Defined Field 4 9/30/2011 1:58:29 PM Page 2 of 6 Salutation First Name shley Middle Name I Last Name Nelson Suffix Date of Birth 02118/1987 ChIte e Sex Female ssociation Type i im Address 1291 sle RD Apartment City Cam Hill I State PA 1 Zip Code 17011 Phone Number 1 Area Code 17 Number 8567731 Fxd Phone Type Cell Phone Number 2 Area Code 1 717 -17377997 umber Ext Phone Type Home User Defined Field 1 victim User Defined Field 2 User Defined Field 3 User Defined Field 4 Salutation First Name Cat Middle Name IJane Last Name Knipe Suffix Date of Birth 07/28/1951 Race White Sex F m ssoaatlon Type i i Address 1 Manchester RD Apartment Will FCamy State IPA Zip Code 117011 Phone Number 1 Area Code 717 Number 17637349 JEKI Phone Type Home Phone Number 2 Area Code Number jExI Phone Type User Defined Feld 1 victim User Defined Feld 2 User Defined Field 3 User Defined Feld 4 Salutation I First Name S"haron Middle Name I Last Name Burke Suffix Date of Birth Race White Sex Female ssociation Type Address 11 Manchester Rd Apartment City State T PA ip Code 117011 Phone Number 1 Area Code 71 1 Number j 8053682 ExI Phone Type ell Phone Number 2 Area-Code 717 Number Ext Phone Type User Defined Field 1 owner dog User Defined Feld 2 User Defined Field 3 User Defined field 4 9/30/2011 1:58:29 PM Page 3 of 6 Salutation First Name Middle Name Last Name Suffix Date of Birth Race Sex Association Type Address unk Apartment l City unk I State PA Zip Code Phone Number 1 Area Code 717 1 Number 7958288 Fxd Phone Type Phone Number 2 Area Code 717 Number Fwd Phone Type User Defined Field 1 vet clinic User Defined Reid 2 User Defined Reid 3 User Defined Field 4 1 ruatinn r)icnatnhwri Street Number Street Block Predrection Street Name Street Type Postdirection PO Box Cross-Predirecdon Cross-Street Name Cross Street Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number Location Township M tedel District City/Town Political Subdivision State Zone Number Zip Code Area Grid Residence Type Unit Type Unit Number Latitude 00 Longitude 0.00 Location Type Country United States of America JUSA) Location Description Dis eat M9/2011 08 :54:00 (18 RIM= :58.00 Cleared 9510201109 :43:00 User Reid 1-2 1 User Defined' eld 2 User Defined Reid 3 User Dented Field 4 9/30/2011 1:58:29 PM Page 4 of 6 Officer Name ?sslstlng le Resource # Foltz, Douglas -1809 - Lower Allen Tw Officer 11809 Dispatched 05/09/2011 08:59:00 Enroute Anived 05/091201108:59:00 Cleared 051091201109:43:00 Defined Field 1-Z tuaer uennteu Fivu c Related Incidents Incident Number j T2 1 38 DatefTirne Started 05109/201108:54:00 L MAN CH TER RD Cam Hill A 17011 Status Coed Comments 9/30/2011 1:58:29 PM Page 5 of 6 report by Officer Gelnett on 5-9-11. shiey Nelson was walking her dog on the even house number side of Manchester Rd on the sidewalk. Jason nyder, Dog Behaviorist, was walking his pack of 9 dogs across the street and was in the process of picking up more dogs at 311 Manchester Rd. According to Snyder one of the dogs slipped its collar and ran across the reet toward Nelson and her dog. The rest of the dogs did likewise. Snyder lost control of all the dogs and athy Knipe, a resident at 310 Manchester Rd, helped by catching one of the smaller dogs. She returned this Dg to Snyder and got bit by one of the German Shepherds that Snyder had gained partial control rer. Nelson's dog was knocked down numerous times and attacked by at least 6 of the dogs Snyder had been alking. Nelson was also knocked down in her attempt to get the dogs away from her dog. elson and her 10 year old Husky were shaken up but did not appear injured. Nelson's dog did have wet ruffled it all over were the other dogs had attacked him. Nelson was going to take her dog home and look him over o see if he was injured then decide if she was going to take him to the vet or not. elson stated she has had problems with Snyder in the past as he walks a pack of dogs past her house and also icks a dog up at her neighbors house at times. Snyder has verbally attacked her before, his dogs have efecated on her property, and they have run loose on her property going after her dog. Nelson stays away from im and his dogs every time she sees him. ilpe was certain the dog that bit her was one of the German Shephards that belong to her neighbor. Snyder ited it was Utley and showed me the dog and the rabies tag from 2010. Snyder did not know If this was up to to but gave Cpl Foltz the phone number to the owner, Sharon Burke. Cpl Foltz called and left a message for r to contact us back. She did so in a short time and provided a phone number for her vet to verify the shot :ord. I called and later verified this with Bansfeld. Both Utley and Jetter, the other German Shephard, are up date on their rabies shots. 1 notified Nelson and Knipe of this. also had contacted the State Dog Law Office and had an officer call me while 1 was dealing with Snyder. They o not have any restriction on Snyder's dog walking but are familiar with him. * stated she was fine and was not going to the doctor. She was contacted by the dog owner and assured any doctor bills would be taken care of. i state, when 1 called her back, that she was going to take her dog to the vet later to make sure it was 1 asked her to get me a copy of the bill and I would make sure she was reimbursed. She will do that. 9/30/2011 1:58:29 PM Page 6 of 6 "EXHIBIT V " COMMOIVWFALTPI OF PENNSYLVAMI- CITATION NO. -•. NON TRAFFIC CITATION ', 18 5 813 6 9- 6 er bh*%MM 006* CON 400 s rnof: 4 a5'a3ga7 I s swo PKPA .nrlr-.iM taw aSar. V1?la SY+ a.cr lte'44le- wo-Y. n-- /fir( tic., t Y12 I aftafma 0.em rlm? (A) ? AsFen rAP4 V'VA- ,1. ommimlrp . CRj rL? ? tJr?VtlworArred cawomm"W f M' ? E3 Bb* (M 13 Hbpadc is-A s Ar w&m M 13 UIIkmm (M 13 Ferrlek 1-11-co9 ? u tq ruitaolSuMiaaro U. x r...Yr.. O oar ", " Tm 1=1 Yes Q Y O Yes 'C3 Dteordxty Conduct Q C&*w Trespass ? TMR of services ? CM*Al el ? marmu<rwtt ? Pubc DMdr wmm ? Scattering Ruohhh a Tren6 d Or MoR or Brewed Beverages ? ReW ` Purchase, Con1=1= • p?y %"'AML? ba 7 ;d 1 ¢r. Pa Cede 2! 1i T ? ? 1 w , r . o ?o 4b br k CwS 5' `} r k F s 1 baJ cr a n < L AL, ?'?-'?• V J. NAri ?,. 23.50 ``\\ Q Tc? 'K sa 24 oyx T u. e+? ?resi..ewe,a+.Id DUE m - -1 / b8 0.? 1 X03 CD ik k0 l, A OWN 141 X 1 L ED '° ? `" _,o?c .? §LFW -&amww L 42.I-d1M G?1.?Wb?(1?elpiii i,.igr - OM tfr?rlN Yrin??lYtl hi11 T11Y Y¦M11Wt a ww ? LOIdW M PWANO r agNl.0" Ywraooa ogre a11MN &1Dr?E NUMBER ORI NIM UR Ofc- T. Gelnett 18-11 PA0210600 over Allen Township Police De artment 1'r cr Rd _q - R Down Ua dB Pmpmty fleomd b symm cww ar. Y Q? ?h, ,,,?,, ?/YT?DI (^ ?.r.e?aa 3? Vkmft Ilea. 51. Dw p"I 1Do, w. - M. vmn Aee.r Code) 66. Pleb ft 6" l k, 737-2qg aL "` WORK WGT WORK ADDRESS EYES MAKE COL ST PARBAIT HAIR GUARD H Pwnww OME 7W -Q5-7V / _T-7,5- -MC) POB SIN OTN# P8581369- "%A "EXHIBIT W " Complaint Report Y' Commonwealth of Pennsylvania Lower Allen Twp . Cor? pinintfinforma on., Complaint Number Locked Record Follow Up I Call For Service LAT2011-09-00372 N INo PORDVI Description PORDINANCE L Status Priority Method Received Datelrime Received Cleared Rai 1 09/09/201112:46:00 Day of the Week How Handled Friday Officer A sianed Complaint Nature Doug Davis reported that his daughter Dana Davis was bitten by a dog that was being cared for by Jason Snvder. The doa is owned by John Burke. IC and Citations to follow n i G? U t or p a n ton . Lca Street Number Street Block Predirection Street Name Street Type Postdirection 1 IALLENDALE PC Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number Cumberland Location Township Magisterial District City/Town Political Subdivision or Allen T i Low -1-0 1 CamD Hill - State Zone Number Zip Code Ala Grid Residence Type Unit Type 1 17011 1202 Unit Number Latitude Longitude Location Type Country 40.225154 -76.890966 t nkn wn n' d States of America Location Description 417 ALLENDALE WY .LA CU417ALLENDALEWYLACU 9/30/20112:00:14 PM Page 1 of 5 Complainant Information Salutation First Name DOUG Middie Name Last Name Suffix Date of Birth Race ex Address 17 Apartment I Ca-mo City I I State PA 1 Zip Code 17011 Phone Number 1 Area Code 717 1 Number 5030228 1 Fxd Phone Type Phone Number 2 rea Code 717 Number Ext Phone Type Notify Complainant No Call Taker ID WAROWE Dispatcher ID 1 CLB cNET Complaint It. 1352084 User Defined Field 1 User Defined Field 2 User Defined Field 3 ser d (? w a- 911 on First Name Middle Name ?:Vde Name SufPoc Oate of Birth 04M 1/1969 - R 7whits sodation Type It dress 417 Allendale WY Apartment City State Zip Code 117011 Phone Number 1 Code 71 Number l 1975-1880 Ext l Phase Type Home Phone Number 2 ea Code Number l Ext Phone Type User Defined Field 1 R" 6 User Defined Field 2 3 95 User Defined Field 4 9/30/2011 2:00:14 PM Page 2 of 5 Salutation First Name Middle Name Last Name Suffix Date of Birth 01/15/1961 Race Whi a Sex IFemale sodadon Type [Progwtv Owner Address 31 MANCHESTER D Apartment City ICAMP ILL State IPA Zip Code 117011 Phone Number 1 Area Code 1 Number 1737-4307 JExt Phone Type lHome Phone Number 2 Area Code 717 Number 1805-3682 jExI Phone Type Home User Defined Field 1 Doa Owner User Defined Field 2 User Defined Field 3 User Defined Field 4 Salutation Tana t Name Middle Name I Last Name Davis Suffix Date of Birth 1 9 Race W Ite TFAM21 e sod ation Type ?Icflm dress 417 kac LN Apartment Hill FCaMD State PA zip Code 1701 Phone Number 1 Code 71 1 Number 7610557 Ext Phone Type 0 Phone Number 2 Area Code Number Fwd Phone Type User Defined Field 1 Victim User Defined Field 2 User Defined Field 3 User Defined Field 4 Officers Involved . 9/30/20112:00:14 PM Page 3 of 5 Officer Name Role Resource # Zeiders, Joshua -1894 - Lower Allen Tw lAssisting Officer 11894 Location Disnatrhari Street Number Street Block Predirection Street Name Street Type PosIdlreR`cn PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number Location Township Magisterial Dftict City/Town Political Sub vision State PA Zone Number Zip Code Area Grid Residence Type Unit Type Unit Number Latitude 0. 0 Longitude 0.00 Location Type Country United §WW§ of A=r!OA" Location Description 41 Dls MW2011 12 :49:00 QWQ2 12 :55:00 Cleared ?J 112 a 59:00 user Defined Field 7.2 2 user D ned t User Defined Field 3 User Defined Field 4 r car Name Role Resource # S auldin , Justin -1810 - Lower Allen Tw Re n Officer 1810 Dispatched Enroute 1 Artlved Cleared 09/09/2011 0 1 091OW2011 13:19:00 Defined Field 1-2 DOW Field 2 9/30/2011 2:00:14 PM Page 4 of 5 Comments 121/11 by 1844 @ 1430hrs; DANA and TERRY DAVIS came into the station and requested a copy of this mplaint. The complaint was provided to them minus the CAD and narative, which they were made aware of. na question the address for JASON SNYDER, indicating that is his mother's residence and not his. "He lives Lemoyne." Dana stated. I checked with Lt Thomas about the incorrect address and he indicated that would ve no bearing since we have multiple addresses for SNYDER. TERRY also indicated that the report needed to fixed because multiple dogs came at Dana and not just one as the report inidcated. I mentioned this to Lt 9/3012011 2:00:14 PM Page 5 of 5 "EXHIBIT X" Complaint Report Commonwealth of Pennsylvania Lower Allen Twp Camplaintjnformation, Complaint Number Locked Record Follow Up Call For Service 1 9 1327 I No INo I PTREJO Description OESPASING T Priority Method Received TDatefflime Received Cleared ?c r Initiated 091091201113:00:00 Day of the Week How Handled Fridav Officer A signed Complaint Nature Jason Snyder did enter a private residence without being invited, without knocking or announcing his presence, and remained despite at least four requests of the property owner to leave. See comments. Complaint _Location Street Number 1 Street Block Predirection Street Name IAIIendale Street Type Postdirection PO Box Cross-Predirection Cross-Street Name CrossStreet Type Highway Name Highway Number Highway Milepost Rural Route County Cumberland Jurisdiction Number Location Township Lower Allen T vnshiD Magisterial District 09-1-01 Cityfrown Cami) Hill Political Subdivision State Zone Number 1 Zip Code 17011 Area Grid 1 Residence Type Unit Type Unit Number Latitude Longitude l Location Type Rasidinne-ell-forne Country United States of America U Location Description 9/30/20112:01:10 PM Page 1 of 7 Complainant Information Salutation First Name Joan Middle Name Last Name IKI` r Suffix Date of Birth 12/15/1947 Race White ex Female Address 41 Allendale VVY Apartment l City Carng) Hill State PA 1 Zip Code 17011 Phone Number1 Area Code 717 1 Number I 7634501 F-4 l Phone Type Home Phone Number 2 Area Code Number. Ext l Phone Type HoMe Notify Complainant Call Taker ID Dispatcher ID cNET Complaint M User Defined Field 1 User Defined Field 2 User Defined Reid 3 User iced Reid 4 Cod Is??i?e, :? . n ormat on Salutation Calson rst Name Middle Name Mafthe Last Name uifoc Da te of Birth 01111/1969 Race Sex Association Type BUS Address 417 Allendale WY Apartment Mamp State Zip Code Phone Number1 Area Code 717 1 Number l 975-1880 Ext Phone Type Phone Number 2 ea Code Number I lEx, Phone Type User Defined Field 1 User Defined Field 2 User Defined Field 3 User Defined Field 4 9/30/2011 2:01:10 PM Page 2 of 7 Salutation First Name Middle Name Last Name Suffoc Date of Birth Race Sex I Association Type 11/25/1989 White Female--- WItness Address 417 I ac L Apartment City State Zip Code 1 I 17011 PA IlCamip Hill Phone Number 1 Area Code Number Ext Phone Type l 717 17610557 Home Phone Number 2 ea Code Number F.xt Phone Type User Defined Field 1 User Defined Field 2 witness User Defined Field 3 User Defined Field 4 Salutation First Name Middle Name I Last Name I Suffix Ronald F. Nev III Date of Birth Race Sex I Association Type 199 I White Male WItness Address Blacklatch LN 407 City State Zip Code Apartment 1 I 17011, PA lCamg) Hill Phone Number 1 Area Code Number EM Phone Type 717 1 J 3038871 I cell Phone Number 2 Area Code Number l Ext Phone Type User Defined Field 1 witness User Defined Field 2 User Defined Field 3 User Defined Field 4 9/30/20112:01:10 PM Page 3 of 7 rs Involved -1808 - Lower Allen TwpReporting Officer 11808 I n Atinn Ilien?fnhefl Street Number 41 Street Block Predirection ?Ilendale eet Name Street Type Postdirection PO B ox Cross-Predirection Cross-Street Name Cross Street Type Highway Name Highway Number Highway Milepost Rural Route County CuMberlan Jurisdiction Number Location Township r Magw" m t -1 Cttyrrown Political Subdlvlslon State P R Zone Number 1 Zip Code 17911 Area 1202 Residence Type Unit Type Number L atitude Longitude Location Type Residence/H ome Country United Stat s of America (USA) Location Description Dispatched 09/2712011 Enroute Arrived 0 Cleared User Defined Field 1-2 1 User Defined Field 2 User Defined Field 3 User Defined Field 4 Comments 9/30/2011 2:01:10 PM Page 4 of 7 Narrative, Detective Corporal Sentman 1808 28 September 2011 On this date, the following will be documented for this case. I was assigned a case, LAT2011-09-00372, by Chief Williamson on Tuesday 27 September 2011. 1 was told that the summary citation that was filed by Officer Spaulding was to be withdrawn to make way for a criminal prosecution of the dog handier for his actions that caused the injury to the victim. I was given a copy of the case and told to follow up accordingly. I met with the victim Dana Davis at her home with her parents. 1 spoke to her about this case. Dana advised the following. Dana was walking on the sidewalk on Allendale Way from the entrance of the development toward the middle of the development. She was walking with her friend Ronald F. Ney III (Ronnie) to his mother's home on Blacklatch Lane. The two had just been running at Cedar Cliff High School and were walking home after their work out. Dana reported that she noted the garage door on the home at 417 Allendale Way started to open. Dana then noticed that four dogs were charging out of the garage and they did not stop at the end of the driveway. The "lead dog" was a German Shepard named "Utley." Dana stated that she heard the man who came to collect the dog, known to her as Jason, yelling that name at the dog during this incident. Dana stated she saw other dogs running, (believed to be four (4) total dogs in the pack), but only remembers seeing a white Bulldog for certain with the Shepard. The other two dogs did not stand out and she did not pay any attention to them once the German Shepard got to her on the other side of the street. Dana stated she froze in her tracks and turned her back to the dog. Dana stated she remembered the dog not barking or making a sound. His eyes were focused on her until she turned around and the other dogs in the pack were growling and barking as they ran. lana stated she felt pain in her upper leg and noted that the dog was bitting and holding on to her upper 3g. The dog began to shake his head and did not let go of the bite. She felt pain with the bite and creamed. The dog released his bite and then bit her again. The dog bit both legs and continued to bite until he vas yelled at by Jason who had arrived on the opposite side of the street and grabbed the dog. Dana was frozen vith pain and fear. She stated that a resident at 418 Allendale Way, (home in front of which the bite took place), ame out and collected her and took her inside her home. Dana stated that the female's name was Joan and that he told Dana she would need to seek medical attention for the bites. Dana was handed a bottle of water by oan. Dana did ask Joan to call her father. ason then entered the home without knocking or announcing his presense. He opened the screen door but did of have to open the inside door as it was ajar after Dana entered. Jason was carrying one of the dogs, (the !nglish Bulldog), as he entered the home. Joan told Jason to leave. Joan has a dog and did not want any dogs ssociated with Jason inside her home, (or Jason at that time), and communicated that to him directly. Jason Ilegedly ignored her and stated, "it's ok." He then walked further into the home and tried to speak to, Dana. He :t go of the bulldog at this point and the dog was running about Joan's home. Joan had grabbed her dog and emanded that Jason leave with his dog. Jason continued to try to speak to Dana. Dana stated she was still Tightened and upset by the experience and did not want to speak to Jason. oan continued to demand for Jason to leave. Dana reported that Joan stated, "get the hell outl" to Jason. ason did not leave when told. Jason continued to stand in the home and Joan continued to tell him to :ave. Eventually, Jason collected the bulldog from the home and then opened the door and put the dog utside. The dog was never on a leash during this time. The dog was running freely outside the home when it ras placed outside by Jason. ason continued to try to speak to Dana. Joan continued to tell Jason to leave, (Dana recalled no less than four mes Jason was told to leave and he ignored that request), and also asked Dana for her phone number so she ould call Dana's father. Jason asked if he could have the number as well and then he handed Dana a business 9/30120112:01:10 PM Page 5 of 7 ame. This card was presented to Dana by Jason. Jason was then given Dana's name and phone number. Joai ailed Dana's father and Jason eventually left the home. remained with Joan until her father arrived. Dana stated that the police were then called and so were jency Medical Services. is stated that she was checked by Emergency Medical Services and eventually went home. Dana stated she in pain and eventually went to see a doctor for this bite. She also reported getting a few prescriptions for bite as well as being taken to the Emergency Room (Holy Spirit Hospital), for these injuries. ma presented me with photos that had been taken by her aunt of her injury. Dana stated she provided a itten statement to Officer Spaulding of these events. She indicated she would be able to print me out a copy her statement. She then asked if 1 wanted her to call her friend Ronnie to have him come over for an erview. I advised that would be great and asked if she could have him respond to her home. hile waiting for Ronnie, Dana informed me that she did not want to have the gifts that Jason had dropped off at :r home the day of the event. Dana stated her younger brother had observed Jason at the front door the night is incident took place. Jason dropped off a gift of body wash and bath related Items. He also dropped' off ?wers and some hand soap. Dana also stated that she received a $100.00 gift card/ debit card from the dog vner. Dana stated she did not want either of these gifts. observed the gifts and asked what her plans for them would be. 1 was told that the attorney for the family ranted to retain them. I advised her that If her attorney requested them, she should follow the attorney's istructions. I told her I had seen them and would document that Jason was seen dropping off the gifts of owers and the bath items. I also advised her I would document the gift card/credit card gift from the dog s arrived and I spoke with him. Ronnie presented the same account as was reported by Dana. Ronnie he did try to "clap" and scare or get the dog to release. The dog did not respond to his clapping. ie stated the dog did not let go of Dana until Jason came over and yelled at the dog. Ronnie was also int when Jason entered the home on Allendale Way without knocking or announcing. Ronnie confirmed Dana had reported and stated that he was not Invited or welcome in the home. advised he had presented a written account to Officer Spaulding and that should be available as it was up by an officer. thanked Ronnie and Dana for their time and answered any questions they had. I then cleared their home and rove to Joan's home on Allendale Way. spoke to Joan. Joan stated she heard Dana yelling and came out to see if she could help. Joan's statement ras that she did not see the attack but saw Dana after' It was over and tried to convince her that EMS needed to aspond and that she should go to the hospital. Joan also stated that she did speak to Jason when he barged ito her home and did ask that he leave. Joan stated that she was upset at the doo being In her home without a :ash, the fact that Jason had barged Into the home without knocking, and the fact that the dog was not )strained in any way despite the previous incident. Joan did not know if the dog Inside her home was the ttack dog or not and she did not want anyone else to get bitten. was willing to testify at trial if needed. Joan stated she would work on a written statement for me for this advised all parties that I would contact them once a decision was made on this case. incident report to be created from this case, (document the trespass), and various charges will be filed for case as well as that case. did instruct the victim Dana to send a letter to Jason of "not contact or trespass." 9/30/2011 2:01:10 PM Page 6 of 7 of the injury taken by Dana's aunt were scanned and attached to this report. 9130/2011 2:01:10 PM Page 7 of 7 "EXHIBIT Y 11 Complaint Report Commonwealth of Pennsylvania Lower Allen Twp Go niplairi4 l nformation Complaint Number Locked Record Follow Up I Call For Service LAT2011-09-00653 INo PANMCP Description ' PANIMAL COMPLAINT Status Priority Method Received DateTme Received Cleared I lRadio ch 1 09/15/201112:15;00 Day of the Week How Handled Thursday Officer sianed Complaint Nature Elizabeth Shank reported a dog fight in the rear yard of 417 Allendale Way. I checked the area and spoke with Shank. I was advised that there was seven dogs in the rear yard and Isabell Snyder took them inside. While speaking with Shank Jason Snyder showed up with three more dogs. I gave Shank my card, she will send me an e-mail. Complaint; Location Street Number 17 Street Block Pred(rection ] t Name ALLENDALE Street Type WY rIrection PC B ox Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Cumberland Jurisdiction Number Location Township Lower Allen T i Magisterial District City/rown m Hill Political Subdivision State Zone Number Zip Code 1701 Area Grid 1202 Residence Type Unit Type Unit Number Latitude 40,225154 Longitude -76,890 66 Locat on Type Country United States of America (USA) Location Description 417 ALLENDALE WY.LA CU417ALLENDALEWYLACU 9/3012011 2:02:07 PM Page 1 of 4 Complainant'7nformation Salutation First Name 1ELIZABETH Middle Name Last Name ISHANK suffix Date of Birth Race Sex Address 1 A WY Apartment City Camp Hill I PA tate Zip Code 11 Phone Number 1 Area Code 1 7 1 Number 1,9752722 Fxd Phone Type lHome Phone Number 2 Area Code 717 Number Fxd Phone Type ork Notify Complainant No Call Taker ID MOOR Dispatcher ID I MSF- cNET Complaint it. I 36J "Z User Defined Field 1 User Deffned Field 2 User Defined Field 3 User 4 9/30/2011 2:02:07 PM Page 2 of 4 Complainant Associate 'Information: Salutation I SABEL irst Name rE iddle Name Last Name ISM Y Suffix Date of Birth 02/17/1928 =hlte Sex Association Type IProperty Owner Address 417 ALLENDALE WY Apartment City ICAMP HILL State PA Zip Code 117011 Phone Number 1 Area Code 717 T761-0574 er lExt Phone Type Home Phone Number 2 Area Code Number jExI Phone Type User Defined Field 1 Owner User Defined Field 2 User Defined Field 3 User Defined Field 4 Salutation First Name ason Middle Name w Last Name n Suffix Date of Birth 01/11/1969 Race Ite h Sex @ I Association Type susRect Address 417 Allendale WY Apartment l City Camp Hill I State PA 1 Zip Code 17011 Phone Number 1 Area Code 717 1 Number J 975-1880 E*4 l Phone Type Home Phone Number 2 Area Code Number I E\t Phone Type User Defined Field 1 SUSDOCt User Defined Field 2 User Defined Field 3 User Defined Field 4 9/30/2011 2:02:07 PM Page 3 of 4 Officers Involved 9/30/2011 2:02:07 PM Page 4 of 4 ffey, Donald -1822 - Lower Allen Twp 1 11822 "EXHIBIT Z 11 Complaint Report jilt Commonwealth of Pennsylvania Lower Allen Twp pl Comain, Informatwon_ , Complaint Number Locked Record Follow Up Call For Service LAT2011-09-00793 No INo IPANMCP Description PANIMAL COMPLAINT Status Priority Method Received Date?me Received Cleared 5 ado I R ado D1912atch t 09t 09118/2011 10:57:00 Day of the Week How Handled Sunday Phone ' Complaint Nature Terrie Davis reported that Jason Snyder was walking 8 dogs and was advised by Lt. Thomas to call. I advised Davis that Snyder may walk as many dogs as he wants. I explained the codes violations and the Animal viloations to her. I still advised her to call if she sees Snyder bringing the dogs home. as-,W Comptatnt'Location, Street Number Street Block Predirection Street Name Street Type Postdirection 1195 ILOWTH R RD I PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number Cumberland Location Township Magisterial District City/rown Political Subdivision hi Cam Hill Sae Zone Number Zip Code Area Grid Residence Type Unit Type P 1 17011 1 1203 1 Unit Number Latitude Longitude 1 Location Type Country 7 -76 24 1jighwayffload/ Alley United Location Description 1195 E RD LA CU119 5LOWTHERRDLA CU 9/30/20112:03:07 PM Page 1 of 3 Complainant Infprmation Salutation First Name ITERRIE Middle Name Last Name IDAVIS Suffix Date of Birth Race Sex Address 417 Blacklatch n Apartment l Camy City I I State PA 1 Zip Code 17011 Phone Number 1 Area Code 7 1 Number j 8054394 FxI Phone Type lHome Phone Number 2 Area Code 717 Number get, Ed I Phone Type Work Notify Complainant No ILTHUM Dispatcher ID G 1 cNET Complaint #: 13633" User Defined Field 1 ser Defined Reid 2 User Defined Field 3 er ned Field 4 Gom an.. ?, Salutation Fgst Name J n Is o Middle Name Last Name Suffix Date of Birth Race Sex odatkxt Type dress 417 Allendale WY Apartment City CaMD Hill tats rPA 1 Zip Code 17011 Phone Number 1 Area Code 717 1 Number j 975-1880 ExI l Phone Type Home Phone Number 2 Area Code Number J Ext Phase Type User Defined Field 1 User Defined Field '2 User Defined Field 3 User Defined Field 4 9130/2011 2:03:07 PM Page 2 of 3 Officers Involved Justin -1810 - Lower Allen Twq IReportina Officer 11810 I n Linn Ilicnnf •hori Street Number Street Block Predirection Street Name Street Type Postdirecfion PO Box Cross-Predirecrion Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Cumberland Jurisdiction Number Location Township Magisterial District City/Town Political Subdivision State P Zone Number Zip Code Area Grid Residence Type Unit Type Unit Number Latitude 0.0 Longitude 0.00 r tion Type Country Uni to es of America (USA) Location Description 1195 H D LA 11 L H R CUO Dispatched 09/18/2011 11:00:00 Enroute Arrived 09/18/2011 11:05:00 Cleared 09/18/201 111:25:00 User Defined Feld 1-2 2 User Defined Reid 2 User Defined Field 3 User Defined Field 4 9/30/2011 2:03:07 PM Page 3 of 3 "EXHIBIT A2" Complaint Report Commonwealth of Pennsylvania Lower Allen Twp Complaiiii Information Complaint Number Locked Record Follow Up Call For Service LAT2011-09-01095 0 INo I PANMCP Description PANIMAL COMPLAINT Status Priority Method Received Datelrime Received Cleared 5 ' o Dispatch 09 09124/2011 10:08:00 Day of the Week How Handled Saturday Phone Complaint Nature Shelly Perry called and advised that Jason Snyder was walking 7-8 dogs. I called her back and advised her that his was not a violation. Perry did advise me that Snyder did bring the dogs to his house. I advised her that this may be a codes violation. I will send a co of report to codes. Complaint Location Street Number Street Block Predirection Street Name Street Type Postdirection 417 IALLENDALE VW I PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Judsdiction Number Cumberland Location Township Magisterial District Citylrown Political Subdivision Allen Lower Hill State Zone Number Zip Code Area Grid Residence Type Unit Type !PA 1 17011 1202 Unit Number Latitude Longitude Location Type Country 4 -76,89096 States United of America Location Description 41 A A LA 417ALL ND LE LA 9/30120112:03:59 PM Page 1 of 3 Complainant Information Salutation First Name ISHELLY Midge Name Last Name P Suffix Date of Birth Race Sex Address 419 ALLENDALE WY Apartment 1 City CamR-HlII I State PA 1 Zlp Code 170.11 Phone Number 1 Area Code 717 Number Ext Phone Type 11jorne Phone Number 2 Area Code 717 Number 7631998 Ext 1 Phone Type W ork Notify Complainant No Cell Taker ID SHULL Dispatcher ID 1 MSFO cNET Complaint #: 1366193 User Defined Field 1 ser Defined Field 2 User Defined Field 3 ser elf 4 Salutation First Name Middle Name 1 lm=ew Last Name Snv fir Suffix Date of Birth 01/1111269 Zito Sex 7- r"tlon: Address 417 Allendale WY Apartment I gAmg city 1 state code Phone Number 1 Area Code 717 Number J 9 "5- 880 EKt 1 Phase Type 14orne Phone Number 2 Area Code Number I EYt Phone Type User Defined Field 1 User Defined Field 2 User aid 3 User Defined Field 4 9130/2011 2:03:59 PM Page 2 of 3 Officers Involved Justin -1810 - Lower Allen Twp Reporting Officer 11810 Lnratinn Dicnntrharl Street Number Street Block Predirection Street Name Street Type Postdirection PO Box Cross-Predirecdon Cross-Street Name Cross Street Type Highway Name Highway Number Highway Milepost Rural Route County Cumberlan d Jurisdiction Number Location Township Magisterial District Citylrown Political Subdivision State Zone Number Zip Code Area Grid Residence Type Unit Type Unit Number Latitude Longitude Location Type Country United es of America S Location Description 4 7 ALLEND ALE WY,LA 417ALL NDA E 0 Dispatched 09/2412011 10:10.00 Enroute Arrived 09/2412011 10 :10:00 Cleared 09/24/2011 10:20:00 User Defined Field 1-2 User Defined Field 2 User Defined Field 3 User Defined Field 4 9/30/2011 2:03:59 PM Page 3 of 3 "EXHIBIT A3" Magisterial District Judge 09-1-01 Docket Number: MJ-091 01 -NT-0000719-201 1 Non-Traffic Docket Commonwealth of Pennsylvania V. Jason M Snyder Page 1 of 2 r JUdoe Assigned: Magisterial District Judge Charles A. Issue Date: Clement Jr. OTN: File Date: 09/23/2011 Arrestino Agency: Lower Allen Township Police Dept Arrest Date: Citation P 8581540-2 Disposition: Withdrawn Coup : Cumberland Disposition Date: 09/2912011 Summary Trial 10/18/2011 11:00 am Magisterial District Judge Cancelled Charles A. Clement Jr. Advised of His Right to Apply for Assignment of Counsel? No Public Defender Requested by the Defendant? No Application Provided for Appointment of Public Defender? No Has the Defendant Been Fingerprinted? No Participant Type Defendant Arresting Officer Participant Name Snyder, Jason M Spaulding, Justin P # Chame Grade Description Offense Dt. Disposition 1 LO § 65 §§ 6 S Running At Large 09/09/2011 Withdrawn MDJS 1200 Printed: 10/03/2011 2:41 pm Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 at seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. Magisterial District Judge 09-1-01 Docket Number: MJ-09101-NT-0000719-2011 Non-Traffic Docket Commonwealth of Pennsylvania V. Jason M Snyder Page 2 of 2 Case Disposition Withdrawn Offense Sea./Description 1 Running At Large Disposition Date Was Defendant Present? 09/29/2011 No Offense Disposition Withdrawn - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Filed D to Entrv Filer Applies To 09/29/2011 Withdrawn Magisterial District Judge Charles A. Jason M Snyder, Defendant - - - - - - - - - - - -- - - -Clement Jr_ 09/29/2011 Summary Trial Cancelled - - - - - - - - - - -Magisterial District Court 09-1_01 - - - - - - - - - - - - Jason M Snyder, Defendant 09/26/2011 Certified Summons Accepted- -Magisterial District Court 09-1-01 - - Jason M Snyder, Defendant 09/23/2011 Summons Issued - - - -- - - -Magisterial District Court 09-101 - - - - Jason M Snyder, Defendant 09/23/2011 Certified Summons Issued - - - - -Magisterial District Court 09-101 - Jason M Snyder, Defendant 09/23/2011 Summary Trial Scheduled - _ - - -Magisterial District Court 09-1-01 Jason M Snyder, Defendant 09/23/2011 - - Related Case Association Recorded - - -Magisterial District Court 09-1-01 - - - - - - - - Jason M Snyder, Defendant 09/23/2011 Non-Traffic Citation Filed - - - -Magisterial District Court 09-101 - - - - - - - - - - - MDJS 1200 Page 2 of 2 Printed: 10/03/2011 2:41 pm Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 at seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. "EXHIBIT A4" PARCEL NO. 13-24-0807-159 Tbi'vo ;Detb, ! ' day of ?' 1 6?v -?^? ix tke Y. MADE THE 17"-_ of our Lord one thousand nine hundred ninety-five (1 5) BETWEEN ROBERT F. HILBISH, widower, of Camp Hill, Pennsylvania Grantor , and ISABEL E. SNYDER, single woman, of Camp Hill, Pennsylvania WITIVESSETH, that in consideration of ONE HUNDRED THIRTY-TWO THOUSAND FIVE HUNDRED --------------------------- ($132,500.00) ------------------------ Do4arr, in hand paK the receipt whereof is hereby achumledped, the said grantor do as hereby pram and osnnay to the said grantee , ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situate in Lower Allen Township, Cumberland County, Pennsyl- vania, described according to a Plan of Lots, Section No. 3-A, Allendale, made by Damon and Foster, Civil Engineers, Sharon Hill, Pennsylvania, dated July 10, 1959, and recorded September 4, 1959, in Plan Book No. 10, Page 51. BEGINNLNG at a point on the northern line of Allendale Way at the dividing line between Lots Nos. 71 and 72 on the aforesaid Plan of Lots; thence by the north- ern line of Allendale Way, North 21 degrees 32 minutes West, a distance of 100 feet to a point at the dividing line between Lots Nos. 70 and 71 on seid.Plan; thence by said dividing line, North 68 degrees 28 minutes East, a distance of 170 feet to a point at the dividing line between Lots Nos. 63 and 71 on said Plan; thence by said last mentioned dividing line, South 21 degrees 32 minutes East, a distance of 100 feet to a point on the dividing line between Lots Nos. 71 and 72 on said Plan; and thence by said last mentioned dividing line. South 68 degrees 28 minutes West, a distance of 170 feet to a point, the Place of BE- GINNING. BEING Lot No. 71 on said Plan. HAVING THEREON ERECTED a single family residential dwelling known and numbered as 417 Allendale Way, Camp Hill, Pennsylvania. BEING THE SAME PREMISES which Helen H. Boyer, widow, by her Deed dated October 23, 1990 and recorded November 1, 1990 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book V, Volume 34, Page 1015, granted and conveyed unto Robert F. Hilbish and Dorothy J. Hilbish, his wife. The said Dorothy J. Hilbish died September 22, 1995 whereby vesting sole title unto Robert F. Hilbish, widower, Grantor herein. .f I'. ? r' n :r• . ,- N, r .i ?_ r 7 D_ i it N -- r i c7 r,: ?. 4J C? U ttf OI B36d i3:l. WF 7D3 ?L E 5E A n u f'W9 E 1& 19 . And the mod praetor hereby oovenants and agrees that he wit warrant specially the property hereby conveyed. IN WITNESS WSSRSOF, saki praetor has hereunto set his hand and seat the day and year fret above writim iiDtlti, italeQ aND 7kltYeeeO ROBERT F. HILBIS in the SttlRtatt of __-_.-._...._.._.................... .. (CM State of'"]l UU ?aa. Coa+rty of On thla, the 1-7 day of Goy-t? , 19 TJ ; before me, A notary Pablic the um Wlaipned offiw, pereondk appeared ROBERT F. HILBISH, widower, known to me (or saMefaetor* Proem) to be the Person within iwhwnent, and acknowledged that he oostai " WHEREOF, I hereon h" ?. Q not :" 7ifM whose now is subscribed to the ezecntsd some for the purposes therein _ ? Tuts Of Officer. coanty of } on this, the day of '19 , befors me, as undersigned officer , peraonaft appeared hums to as (or aa*faotn* proem) to be the pews whose name subscribed to the within innstrument, and admowtedoed that executed cams for the purposes therein contained. IN WITNESS WHEREOF, I hereunto set my hand and ogieial seal. _....___..__.._.................. Tills of Officer. E do hereby certify that the proaise residence and complete post oljlre address of the wits amed prantse is 'V/7 1911e 4,114 Waq Pkm o nucc, ,04. /7oi/ ND? . )7 1995 <7 a( A far _- HOU 131 Face 704 "EXHIBIT AS" Complaint Report Commonwealth of Pennsylvania Lower Allen Twp Complaint Information Complaint Number Locked Record Follow Up Call For Service 11-07 0 1 ] No IPDEPSV Description T N SERVICES Statu s Priority Method Received t7ate/Time Received Cleared 0 Personal Vii 071 41201114:00:00 Day of the Week How Handled Thursday Officer A signed omplaird Nature Departmental Services, requested by Codes Department employee Linda Hockenberry to speak to Isabel Snyder reference to her situation involving her son. See comments,- possible referral to be made for services. Complaint; Location Street Number & V Street Block Predirection FAllendale Name Street Type Postdirection PO Cross-Predirection Cross-Street Name Cross-Street Type H Name g?Y Highway Number Highway Milepost Rural Route County Cumberland Jurisdiction Number Location Township II o i Magisterial District 09-1-01 Cityrrown Camt) Hill Political Subdivision Se A Zone Number 1 Zip Code 17011 Area Grid 12 2 Residence Type Unit Type Unit Number Latitude 0.00 Longitude 0.00 Location Type Country Uni d Stat es o America Location Description 913012011 1:59:24 PM Page 1 of 6 Complainant Information Salutation First Name Linda Middle Name Last Name iljockanberrv Suffix Date of Birth l Race White- :TEernale Address Road 2233 GeUgbura Apartment City CAM2 Hill State PA Zip Code 17011 Phone Number 1 Area Code 717 1 Number 9757575 Ext l Phone Type Work Phone Number 2 Area Code 717 Number Ext Phone Type 1 Notify Complainant Call Taker ID Dispatcher ID 1 cNET Complaint #: 1332130 User Defined Feld 1 User DeffNed Field 2 User Defined Feld 3 User eti F 4 9/30/2011 1:59:24 PM Page 2 of 6 Complainant Associate Informations Salutation First Name IISABEL Middle Name IE Last Name Suffix Date of Birth 02/17/1928 7hIte iation Type Sex Zness Address 417 L D LE WY Apartment EMP HILL State PA Zip Code 17011 Phone Number 1 Area Code 717 Number 1761-0574 1Fx1 Phone Type lHome Phone Number 2 Area Code Number JE4 Phone Type User Defined Field 1 witness User Defined Field 2 User Defined Field 3 User Defined Field 4 Salutation T Rrst Name JASON I Middle Name m I Last Name SNYDER Suffix Date of Binh r; Sex Association Type Address 417 Allendale WY Apartment City Cam Hill State PA Zip Code 17011 Phone Number 1 Area Code 717 1 Number l 9751880 Ext l Phone Type Home Phone Number 2 Area Code 1 7 17 1,7610574 umber Fed Phone Type ICGII User Defined Field 1 s e t User Defined Field 2 son of Isabel User Defined Field 3 User Defined Field 4 9/30/2011 1:59:24 PM Page 3 of 6 Officers Involved Donald -1808 - Lower Allen Twp lReporting Officer 11808 Dispatched G 512011 4:00:00 Enroute 07/1512011 14:00:00 Cleared 07111=11 14:20:00 Comments 9/30/2011 1:59:24 PM Page 4 of 6 Narrative by Detective Corporal Sentman 180815 July 2011 On Thursday 14 July 2011,1 was asked by Linda Hockenberry of the Codes Department to speak to Isabel Snyder. Isabel Snyder lives at 417 Allendale Way. Her son, Jason Snyder walks dogs to her home and keeps them there during the day. The codes department has filed at least three (3) citations against Isabel for violations that all are created by Jason's actions. Isabel has paid all the citations. Linda Hockenbeny stated that Chief Williamson had spoken at a recent meeting and wanted an officer to speak to Isabel to determine if she is being intimidated by her son into paying these citations. was told that Isabel was waiting in the interview room. I walked in and introduced myself to Isabel. Isabel held her receipt that showed what she had paid for the most recent citation. I asked Isabel what she had wanted to speak to me about today. Isabel stated she had just come in to pay a fine and that she had not wanted to speak to me. I asked what fine she could possibly have and she showed me her paperwork. I read it and asked several aasy questions to Isabel. She was able to answer all the questions without issue. I asked her about the fine and she explained that her son continues to walk dogs to her home and she receives fines as the homeowner. asked her how many fines she has paid thus far. I was told that she has paid three fines and that they have Seen all about $500.00. asked Isabel if she is ok paying the fines. She stated she has no choice and that she has to pay them. I asked ier if she ever asked her son to pay the fines since he is the one who gets them. She stated she does not. She seemed a little un-comfortable with the questions about her son. I asked her if she ever told her son not to bring ;he dogs to her home because of the fines. She stated she cannot do that and then stated that he would have no )lace to take them. She started to get emotional and began to cry. I asked her if she was ok speaking to me about this issue. 1 then asked if Jason was forcing her to pay the fines and she stated, "No!" Isabel appeared to )ecome defensive after this question so I changed and asked a few more easy answer questions. I then came )ack to Jason and asked if he had a temper. She stated that he did. I then asked if he knew what this was doing o her, (dogs in the home getting her fined in a repeated maner), if that would change things. She stated it vouldn't change things. She then told me that Jason and his father are "working on another place to go..." in eference to the dog situation. asked Isabel if she would mind if I spoke to Jason about what he is doing to her by his actions. She stated that could. I asked if she would want me to tell him that she does not want the dogs brought over again and she eplied no. She stated that he needs to bring them because he has no place to take them. spoke to Isabel and asked if Jason was ever violent or abusive toward her. She stated, "no.!" I asked if he had fiver been abusive and she stated that he was in the past. She then explained that when he was in school he left Dr some time and ended up living with a female subject who had a daughter his age. She started to get emotional and began to cry. She then told me that she did not want to go through this right now. 1 told her I mderstood and told her she could leave if she wanted to leave. I asked if I could give her a business card and I placed my phone extension on the card. 1 asked to have Jason call me reference this issue and then told her hat if she needed anything to call for help. opened the door and thanked Isabel for speaking to me. escorted her out of the room and she departed the station. I then spoke to Linda Hockenberry and Mark Eby. I xpiained to them that I had concerns about this issue because of Isabel's reactions to me and my questions. 9/30/2011 1:59:24 PM Page 5 of 6 plemental Report, Detective Corporal Sentman 1808 15 July 2011 n this date, I completed the following work on this case. I stopped at 417 Allendale Way to speak to Jason nyder. Jason had left a message on my voice mail upon my arrival to work today. I heard that the message ras short and indicated who he was and he had no idea why I needed to speak to him but he was returning my responded and knocked on the door. There were a few dogs inside of the house that barked at me as I waited )r an answer at the door. I received no answer at the door and walked back to my car. I did leave a business and in the door for follow up purposes. then noticed a small sedan approach the home. The male subjec pulled into the driveway of the home and xited. He opened the door and let a few dogs out of the car. He then opened the garage and permitted-the dogs run through the garage to the open back door. They filed into the yard behind the home and Jason came back speak to me in teh driveway. introduced myself to Jason and explained why I was speaking to him today. I told him of my conversation with is mother yesterday, and that I had concerns that she was paying so many bills and fines that she did not meive. I asked If he wanted her to keep paying the fines. He indicated that he takes good care of his mother nd not to worry. He placed his hand on my shoulder when he made the last statement and told me again not to sorry. He then spoke of a home he is planning to purchase on off of Limeldin Road where the zoning Is perfect >r his business. He also stated that he would continue his practice of putting aside $100.00 each week to pay )r any fines he receives for his activity. He then referred to It as harassment and stated that he was going to be ut of the neighborhood as soon as he can get the home bought. thanked him for the information and asked when we could anticipate the home being purchased. He ,tated they are still talking about price and that he does not know when to expect to have the home. thanked him for the information and told him 1 would pass it along to codes. As his mother was apprehensive or me to speak to him in any way, I did not question him further about why his mother would have to use a :redit card to pay for the funds owed. returned to the station and informed Codes of what 1 had been told by Jason. I collected the phone number for 41ke Towson, Dog Warden, (774-2780) and called him on this date. I left a message for him to return my call. also called the Cumberland County office of Aging and Human Services. I spoke to Priscilla Whitman and nade a referral to their office on behalf of Isabel. will follow up as needed with this case and assist Codes and the Office of Aging as needed. Report, Detective Corporal Sentman 180819 July 2011 this date, I received a phone message from the dog warden who returned my call on Monday. I called him k but was forced to leave another message for him reference to this case. 9/30/2011 1:59:24 PM Page 6 of 6 VERIFICATION I, Thomas G. Vernau, Jr., Manager for the Township of Lower Allen and authorized representative for the Township of Lower Allen, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. Dated: ( /to l _ Thomas G. Vern au, ?? VERIFICATION I, John M. Eby, Building and Zoning Coordinator for the Township of Lower Allen and authorized representative for the Township of Lower Allen, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: ( O - D6- t 1 Jo . Eby VERIFICATION I, Frank E. Williamson, Jr., Chief of Police/Director of Public Safety for the Township of Lower Allen and authorized representative for the Township of Lower Allen, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities Dated: Steven P. Miner, Esquire H E P R 0 T H 0 NP-Matthew A. Sembach, Esquire Daley Zucker Meilton ?01' OC T -6 PM 2: 3C Miner & Gingrich, LLC 635 N. 12'' Street, Suite 101 P-UMBERLAND CU rI 1 t. Lemoyne, PA 17043 (717) 724-9821 PENNSYLVANIA sminer(a,dzmmelaw.com IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA Lower Allen Township, Docket No. 2011- Plaintiff v. CIVIL ACTION Jason M. Snyder and Isabel E. Snyder, Defendants (In equity) MOTION FOR PRELIMINARY INJUNCTION WITHOUT HEARING AND NOW, comes Plaintiff, Lower Allen Township, by and through its attorneys, Steven P. Miner, Esquire, and Daley Zucker Meilton Miner & Gingrich, LLC, and represents as follows 1. Plaintiff has contemporaneously herewith filed a Complaint in Equity alleging that the Defendants, as set forth therein, are engaged in a use not permitted by §220-11 of the Code of Lower Allen Township. 2. Plaintiffs Complaint in Equity is incorporated herein by reference in its entirety, as though fully set forth at length. A true copy of Plaintiffs Complaint is attached hereto, made apart hereof and marked "Exhibit A I". 3. Despite demand that Defendants cease their violations of the Township Zoning Ordinances, Defendants continue to operate upon their property in such a way as to constitute a danger to the neighbors. 4. Unless the improper conduct of Defendants is immediately enjoined and Plaintiff is granted relief as requested, Plaintiff will be irreparably injured in that: (a) Citizens of the Township of Lower Allen are at a continued risk of future injury because of Defendant, Jason Snyder's inability to control the dogs he is responsible for caring for; (b) Citizens of the Township of Lower Allen are at a continued risk of future injury because the dogs under Defendant Jason's control have shown a propensity for violence as indicated by the nineteen (19) incidents involving Defendant Jason and the dogs under his control including an incident where he threw dog feces at a then fifteen (15) year old girl; (c) Citizens of the Township of Lower Allen are at a continued risk for future injury because dog fighting continually breaks out between the dogs; (d) Citizens of the Township of Lower Allen are subject to a continuing nuisance from the excessive barking caused by the dogs WHEREFORE, Plaintiff requests that a Preliminary Injunction Issue: (a) Enjoining the Defendants from all use of the property abutting the residential area, and in operating their business from that property until hearing; (b) Enjoining the bringing upon the property of any new or additional dogs; (c) Granting such further and interim relief as the Court may deem appropriate. Respectfully submitted, DALEY ZUCKER MEILTON MINER & GINGRICH, LLC DATE: (d/6t1! By. Steven P. Miner, Esquire Supreme Court I.D. # 38901 'idlatthew A. Sembach, Esquire Supreme Court I.D. # 308727 635 N. 12th Street, Suite 101 Lemoyne, Pennsylvania 17043 (717) 724-9821 Solicitor for Plaintiff, Lower Allen Township VERIFICATION I, Thomas G. Vemau, Jr., Manager for the Township of Lower Allen and authorized representative for the Township of Lower Allen, verify that the statements made in this Motion for Preliminary Injunction Without Hearing are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: ? o /I- /it Thomas G. Vern VERIFICATION I, Frank E. Williamson, Jr., Chief of Police/Director of Public Safety for the Township of Lower Allen and authorized representative for the Township of Lower Allen, verify that the statements made in this Motion for Preliminary Injunction Without Hearing are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. 02- Dated: Z 0 ? - IAI?? - r . W' ' son, Jr. VERIFICATION I, John M. Eby, Building and Zoning Coordinator for the Township of Lower Allen and authorized representative for the Township of Lower Allen, verify that the statements made in this Motion for Preliminary Injunction Without Hearing are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 0(0 '11 "O?? Jo Eby 0 "EXHIBIT A]. 11 Steven P. Miner, Esquire Matthew A. Sembach, Esquire Daley Zucker Meilton Miner & Gingrich, LLC 635 N. 12`1' Street, Suite 101 Lemoyne, PA 17043 (717) 724-9821 sminergdzmmglaw.com IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA Lower Allen Township, Docket No. 2011- Plaintiff v. CIVIL ACTION Jason M. Snyder and Isabel E. Snyder, Defendants (In equity) NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. IF YOU WISH TO DEFEND AGAINST THE CLAIMS SET FORTH IN THE FOLLOWING PAGES, YOU MUST TAKE ACTION WITHIN TWENTY (20) DAYS AFTER THIS COMPLAINT AND NOTICE ARE SERVED, BY ENTERING A WRITTEN APPEARANCE PERSONALLY OR BY AN ATTORNEY AND FILLING IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. YOU ARE WARNED THAT IF YOU FAIL TO DO SO THE CASE MAY PROCEED WITHOUT YOU AND A JUDGMENT MAY BE ENTERED AGAINST YOU BY THE COURT WITHOUT FURTHER NOTICE FOR ANY MONEY CLAIMED IN THE COMPLAINT OR FOR ANY OTHER CLAIM OR RELIEF REQUESTED BY THE PLAINTIFF. YOU MAY LOSE MONEY OR PROPERTY OR OTHER RIGHTS IMPORTANT TO YOU. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO THE TELEPHONE OR THE OFFICE SET FORTH BELOW TO FIND WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 1-800-990-9108 717-249-3166 Steven P. Miner, Esquire Matthew A. Sembach, Esquire Daley Zucker Meilton Miner & Gingrich, LLC 635 N. 12th Street, Suite 101 Lemoyne, PA 17043 (717) 724-9821 sminer(a,dzmmp-law. com IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA Lower Allen Township, Docket No. 2011- Plaintiff v. CIVIL ACTION Jason M. Snyder and Isabel E. Snyder, Defendants (In equity) COMPLAINT AND NOW, comes Plaintiff, Township of Lower Allen, by and through its attorneys, Steven P. Miner, Esquire, and Daley Zucker Meilton Miner & Gingrich, LLC, and represents as follows: 1. Plaintiff, Township of Lower Allen ("Township"), is a township of the first class in the County of Cumberland, Commonwealth of Pennsylvania, having its offices at 2233 Gettysburg Road Camp Hill, PA 17011. 2. The Defendants are Jason M. Snyder ("Defendant Jason") and Isabel E. Snyder ("Defendant Isabel"). Defendant Jason resides at 1137 Columbus Avenue, Apartment 9, Lemoyne, Pa 17043. Defendant Isabel resides at 417 Allendale Way, Camp Hill Pa 17011 ("subject property"). 3. The subject property is a parcel of land in a R-1 Zoning District, improved with a single family detached dwelling. Defendant Isabel owns the property. 4. Defendant Jason owns and operates a dog walking and dog daycare business. He uses the subject property as a staging area for said business. 5. Defendant Jason typically picks up the dogs at their owner's residence and takes the dogs to the subject property where they are walked, fed, and kept for varying periods of time, typically, at the latest until 5:30 P.M. 6. Pursuant to §220-11(E) of the Township's code, a home occupation under §220-165 is a permitted use in an R-1 Zoning district. Said ordinance was adopted pursuant to the authority granted under 53 P. S. §10201. 7. Pursuant to §220-6 a "home occupation" is "an accessory business or commercial activity, conducted entirely within a residential dwelling by one or more of the permanent residents." Said ordinance was adopted pursuant to the authority granted under 53 P. S. § 10201. 8. Pursuant to §220-6 a "kennel" is defined as "a structure on any lot on which animals are kept, boarded, raised, bred, treated or trained for a fee." Said ordinance was adopted pursuant to the authority granted under 53 P. S. §10201. 9. A kennel is not a permitted use in a R-1 Zoning district. 10. On June 4, 2010, Defendant Jason submitted a zoning permit application. The application was denied by John M. Eby, Building and Zoning Coordinator for the Township ("Zoning Coordinator Eby") because Defendant Jason was not a resident of the subject property and he was operating a kennel without complying with the kennel rules. Zoning Coordinator Eby also denied the zoning permit because a home occupation requires a special exception with the Lower Allen Township Zoning Hearing Board ("Zoning Hearing Board"). Said reasons for denial were explained to Defendant Jason. Defendant Jason then applied for said exception with the Zoning Hearing Board. 11. On July 15, 2010 the Zoning Hearing Board held a public hearing on Defendant Jason's application. Following the conclusion of the evidence, the Zoning Hearing Board orally denied Defendant Jason's application. 12. On July 19, 2010 Zoning Coordinator Eby issued a Cease and Desist Order against the Defendants. Said order required the Defendants to cease operation of the dog boarding and day care business by July 31, 2010. Said order is attached and incorporated as "Exhibit A". 13. On July 21, 2010, the Zoning Hearing Board issued its written decision in which Defendant Jason's application was denied because he was not a permanent resident of the subject property and the operation of a kennel was not a permitted use. Said written decision is attached and incorporated as "Exhibit B". 14. The Plaintiff has the authority to bring this action pursuant to 53 P.S. §10617 which allows a cause of action for any use in violation of any ordinance promulgated under the Township's authority as stated in 53 P. S. §10201. COUNTI LOWER ALLEN TOWNSHIP V. JASON M. SNYDER 15. Paragraphs 1 through 14 are incorporated herein by reference as if set forth herein at length. 16. On December 20, 2007, Township Officers Edward Curtis ("Officer Curtis") and Tony Calaman ("Officer Calaman") were dispatched to the Lower Allen Dog Park located at 4075 Lisburn Road, after Joan Wyland ("Wyland") called after being bitten by a dog. Upon arriving on scene, Officer Curtis interviewed Wyland who relayed that she was attempting to get into her vehicle when she was attacked and bitten on the thumb by a Labrador Retriever. Wyland's dog was also injured during the attack. Wyland further relayed that the unknown owner had seven (7) other dogs under his control. Officer Curtis's Complaint Report is attached and incorporated as "Exhibit C". 17. Following the December 20, 2007 incident, a press release was issued relating to the incident. On December 24, 2007 the Carlisle Sentinel published an article about the incident. Said article is attached and incorporated as "Exhibit D". 18. On December 26, 2007, Township Sergeant Greg Thomas received a telephone call from Kevin McCartin who relayed that a person residing across the street at 407 Allendale Way has a son who comes to the residence and walks five (5) or six (6) dogs at a time. 19. On December 27, 2007, Officer Calaman received a phone call from Joe Kosanovic saying that he received a letter from Defendant Jason offering his services as a "dog behavioralist" and he believed the suspect mentioned in December 24, 2007 newspaper article may be Defendant Jason. 20. On January 3, 2008, Officer Curtis received a telephone call from Joseph Borza, ("Joseph") then age fourteen (14), about an incident at the subject property where Joseph was involved in a confrontation with his neighbor, Defendant Jason. Joseph told Officer Curtis that he was walking by the subject property with his dog when a boxer under Defendant Jason's control ran outside. The boxer smelled Joseph's dog and Joseph told Defendant Jason his boxer should be on a leash. Defendant Jason replied that Joseph's dog was on his property and the boxer did not need to be on a leash. Joseph walked his dog off the subject property, told Defendant Jason that he and his dog were no longer on his property. Defendant Jason, then age thirty-eight (38) pushed Joseph, then age fourteen (14). Joseph walked away and Defendant Jason's dog followed Joseph for at least three (3) more houses. A copy of Officer Curtis's Complaint Report is attached and incorporated as "Exhibit E". 21. On February 2, 2008, Township Officer Curt Heckler ("Officer Heckler") was dispatched to 425 Allendale Way for a report of a continuing problem with dogs making "unsanitary nuisances" in a yard owned by Roy Osborne ("Osborne"). Osborne told Officer Heckler that he has not seen any dogs defecating in his yard, but when he talked to neighbors, he learned it was most likely one of Defendant Jason's dogs. A copy of Officer Heckler's Complaint Report is attached and incorporated as "Exhibit F". 22. On February 8, 2008, Jay Shuler ("Shuler") went to the Township Police Station and spoke to Township Officers Justin Kirsch ("Officer Kirsch") and Heckler about an incident in which one of the dogs under Defendant Jason's control ran off the subject property into the street and attacked Shuler's dog. A copy of Officer Kirch and Heckler's Complaint Report is attached and incorporated as "Exhibit G". 23. On September 26, 2008, Township Officer Michael Scarlato ("Officer Scarlato") was dispatched to the BP Gas Station located at the 1500 block of Cedar Cliff Drive for an incident in which an unknown individual kicked one (1) of the dogs he was walking. Upon arriving on scene, Officer Scarlato was unable to locate the individual. The complainant, Nancy Ambrose relayed to Officer Scarlato that she believed the individual lived in Allendale and she often sees the individual walking dogs throughout the community. On September 27, 2008 upon talking to Officer Curtis, Officer Scarlato identified Defendant Jason as the suspect from the September 26, 2008 incident. A copy of Officer Scarlato's Complaint Report is attached and incorporated as "Exhibit H". 24. As a result of the September 26, 2008 incident, Defendant Jason was charged with and pled guilty to "Cruelty to Animals" in violation of 18 Pa.C.S.A. §5511(c)(1). A copy of the Magisterial District Judge docket sheet is attached and incorporated as "Exhibit I". 25. On November 10, 2008 Township Detective Donald Sentman ("Detective Sentman") was dispatched to 7 West Shore Drive after receiving a call from David Enrico ("Enrico") about an incident involving Defendant Jason. Detective Sentman interviewed Enrico who relayed that a week earlier Defendant Jason was walking six (6) dogs under his control in front of Enrico's home. Enrico's dog was seated near an open garage door owned by Enrico. Enrico's dog ran up to Defendant Jason's dogs. Enrico verbally scolded his dog and "put a foot into the dog's rear end to correct the dog." After the incident, Defendant Jason put a letter in Enrico's mailbox which chastised Enrico for his actions in correcting the dog. The letter also warned Enrico that if Enrico's actions continued, Defendant Jason would report him to the police. Defendant Jason also asked Enrico if the corrective actions he took against his dog that day were taught to him by the military. A copy of Detective Sentman's Complaint Report is attached and incorporated as "Exhibit F. 26. On August 23, 2009, Township Officer Richard Tamanosky ("Officer Tamanosky") was dispatched to 401 Allendale Way after receiving a call from Norman Batcheler. Upon arriving on scene, Batcheler relayed to Officer Tamanosky that he observed one of the dogs under Defendant Jason's control urinating in his flower bed. Batcheler further relayed that he yelled to Defendant Jason to get his dogs out of the flower bed, and as Defendant Jason walked away, he kicked tan bark out of the flower bed. A copy of Officer Tamanosky's Complaint Report is attached and incorporated as "Exhibit K". 27. On September 22, 2009, Township Officer Kenneth Crane ("Officer Crane") received a telephone call from Carol Dunant ("Dunant") who relayed that a German Shepard, a dog under Defendant Jason's control, nearly bit Dunant's dog because the German Shepard was not on a leash. The incident occurred at 1137 Columbus Avenue. A copy of Officer Crane's Complaint Report' is attached and incorporated as "Exhibit L". 28. On June 20, 2010, Township Officer Elias Martinez ("Officer Martinez") was dispatched to the subject property for an active dog fight. Upon arriving on scene, Officer Martinez interviewed Defendant Jason who said that he released his dogs into the back yard together and a ' The address listed in the box for "Complaint Location" is incorrect. Said address in the box does not exist and is a clerical error. The incident occurred at Defendant Jason's home. boxer mix bit a golden retriever on the ear. Officer Martinez's Complaint Report is attached and incorporated as "Exhibit N". 29. On August 25, 2010, Township Officer Curtis received a telephone call from Jodi Teffeteller ("Jodi") who relayed to Officer Curtis that her daughter, Ruby, then age (15) was harassed by Defendant Jason who was walking his dogs on August 24, 2010. On August 28, 2010, Officer Curtis interviewed Ruby who relayed to Officer Curtis that she was walking her dog behind her residence when Defendant Jason walked by the front of her residence with a pack of dogs. The dog under Ruby's control heard Defendant Jason's dogs barking and ran to the front of the residence. Defendant Jason then began cursing at Ruby causing the dogs under his control to become even more riled up causing the leashes of the dogs to become tangled and eventually knocking Defendant Jason down to the ground. Defendant Jason then threw a bag of feces in Ruby's yard and told Ruby he should throw the feces at Ruby's face. Ruby was then age fifteen (15) and Defendant Jason was then age forty-one (41). A copy of Officer Curtis's Complaint Report is attached and incorporated as "Exhibit O". 30. Asa result of the August 24, 2010 incident, Defendant Jason was charged with and pled guilty to "Disorderly Conduct" in violation of 18 Pa. C.S.A. §5503(a)(4). A copy of the Magisterial District Judge docket sheet is attached and incorporated as "Exhibit P". 31. On August 25, 2010 Township Officer Matthew Claeys ("Officer Claeys") and Township Police Chief Frank E. Williamson, Jr., ("Chief Williamson") responded to a call from the Principal of Highland Elementary School located at 1325 Carlisle Road about their custodian, Helen Gussler ("Gussler"), being bitten by a dog. Gussler told Officer Claeys that a white male had six (6) or seven (7) dogs off their leashes in the field hockey field. Gussler approached the male to tell him that his dogs were not allowed there but as she was approaching, one of the dogs bit her on the left hip. Gussler further relayed to Officer Claeys that the male was walking only two (2) breeds of dogs-German Shepherds and Pit Bulls. On August 26, 2010 Defendant Jason was identified as the male involved in the incident. A copy of Officer Claeys's Complaint Report is attached and incorporated as "Exhibit Q". 32. As a result of the August 25, 2008 incident, Defendant Jason was charged and pled guilty to "Dogs Running at Large" in violation of §65-6 of the Township's code. A copy of said ordinance is attached and incorporated as "Exhibit R". A copy of the Magisterial District Judge docket sheet is attached and incorporated as "Exhibit S". 33. On September 15, 2010 Township Officers John DeSantis ("Officer DeSantis"), John Cypress ("Officer Cypress") and Gelnett were dispatched to the subject property for dogs barking. Upon arriving on scene, Officer Gelnett noticed a two (2) page Cease and Desist order from the Bureau of Dog Law Enforcement ordering Defendant Jason to cease his operation of a kennel. Officer Gelnett contacted State Dog Warden Natahnee Shrawder ("Warden Shrawder") who told Officer Gelnett, Defendant Jason was to have only four (4) dogs at the subject location. Warden Shrawder arrived at the subject property and Defendant Jason pulled in to the subject property with another dog in his vehicle. Defendant Jason stated that he was aware of the notice posted on his door and he was trying to limit the number of dogs on the subject property but could not completely shut his business down. A copy of Officer Gelnett's Complaint Report is attached and incorporated as "Exhibit T". 34. On May 9, 2011 Officer Gelnett was dispatched to the 300 block of Manchester Road and upon arriving on scene, Ashley Nelson, age twenty-four (24), ("Nelson") reported that she was walking her ten (10) year old Husky as Defendant Jason was walking nine (9) dogs across Manchester Road to pick up two (2) more dogs. After Defendant Jason picked up the two (2) dogs, one of the dogs slipped its collar and ran across Manchester Road toward Nelson. Defendant Jason then lost control of the remaining ten (10) dogs as they bolted across the street toward Nelson and her dog. Cathy Knipe, age sixty (60), ("Knipe") a resident of 310 Manchester Road, helped by catching one of the smaller dogs. As Knipe was returning the smaller dog, Defendant Jason had a German Shepard partially under control when the German Shepard became loose again and bit Knipe. Nelson and her dog were also knocked down numerous times and attacked by at least six (6) dogs. Township police issued Defendant Snyder a citation and filed a Complaint Report. Said Complaint Report is attached and incorporated as "Exhibit U". 35. On May 9, 2011, Nelson also told Officer Gelnett that Defendant Jason has verbally attacked her, allowed his dogs to defecate on her property, and have run loose on her property going after her dog. As a result of said incident Defendant Jason was charged with a violation of "Dogs Running at Large" in violation of §65-6 of the Township's code. Said citation is attached and incorporated as "Exhibit V". 36. On September 9, 2011 Officers Spaulding and Joshua Zeiders ("Officer Zeiders") responded to the subject property for a report of a person bitten by a dog. Officer Spaulding issued Defendant Jason a citation as a result of this incident. A copy of Officer Spaulding's Complaint Report is attached and incorporated as "Exhibit W". 37. On September 27, 2011, Chief Williamson assigned Detective Sentman the case. On September 28, 2011, Detective Sentman met with Dana Davis ("Dana"), age 21, and Dana's parents at Dana's home. Dana told Detective Sentman on September 9, 2011 she was walking along Allendale Way when a German Shepard, one of the dogs under Defendant Jason's control lunged at her and bit her on the thigh causing bodily injury. The dog began to shake his head and did not let go of Dana's leg even as Dana screamed in pain. The dog then released his bite and bit Dana again. Both of Dana's legs were bitten and the dog did not stop attacking Dana until Defendant Jason grabbed the dog. In total, Dana believed there were four (4) dogs under Defendant Jason's control. 38. After Dana was bitten, Joan Klingler ("Klingler") provided first aid to Dana and Klingler took Dana into Klingler's home located at 418 Allendale Way. Defendant Jason then barged into Klingler's home without knocking or announcing his presence. Klingler told Defendant Jason to leave numerous times. Defendant Jason refused each time and he insisted that he talk to Dana. Dana was checked by Emergency Medical Services and returned home. Dana then saw a physician at the Holy Spirit Hospital Emergency Room where she was prescribed medications. A copy of Detective Sentman's Complaint Report is attached and incorporated as "Exhibit X". 39. On September 15, 2011, Township Officer Donald Coffey ("Officer Coffey") was dispatched to the subject property for a report of a dog fight. Upon arriving on scene, Officer Coffey interviewed Elizabeth Shank ("Shank") who reported that there were seven (7) dogs and Defendant Isabel took those dogs inside. As Officer Coffey was interviewing Shank, Defendant Jason arrived at the subject location with three (3) more dogs. A copy of Officer Coffey's Complaint Report is attached and incorporated as "Exhibit Y". 40. On September 18, 2011 Officer Spaulding received a telephone call from Terrie Davis ("Davis") that Defendant Jason was walking eight (8) dogs. Officer Spaulding told Davis that Defendant Jason may walk as many dogs as he wants. A copy of Officer Spaulding's Complaint Report is attached and incorporated as "Exhibit Z". 41. On September 24, 2011, Officer Spaulding received a telephone call from Shelly Perry ("Perry") that Defendant Jason was walking seven (7) or eight (8) dogs and that he took those dogs back to the subject property. A copy of Officer Spaulding's Complaint Report is attached and incorporated as "Exhibit A211 . 42. On September 26, 2011 the Lower Allen Township Board of Commissioners held its monthly meeting. At this meeting residents from the Allendale Way community complained about the numerous incidents between themselves and Defendant Jason. 43. On September 29, 2011, Officer Spaulding withdrew the citation he issued on September 9, 2011. Detective Sentman reported in his report that the citation was withdrawn to make way for the criminal prosecution. The Magisterial District Judge docket sheet is attached and incorporated as "Exhibit A3". WHEREFORE, Plaintiff, Township of Lower Allen, prays that an injunction be issued against and restraining Defendant Jason from renting the subject premises and to any tenant using the premises in violation of township zoning ordinances and prohibiting the use of subject premises as described herein. COUNT II LOWER ALLEN TOWNSHIP V. ISABEL E. SNYDER 44. Paragraphs 1 through 43 are incorporated herein by reference as if set forth in full. 45. Defendant Isabel holds legal title to the subject property. A copy of the deed to the subject property is attached and incorporated as "Exhibit A4". 46. On July 14, 2011 Defendant Isabel was interviewed by Detective Sentman because Defendant Jason was cited at least three (3) times for zoning violations and Defendant Isabel paid all of the fines which averaged $500. Township Police Department personnel were concerned that Defendant Isabel was being intimidated by her son into paying the citations. 47. During Detective Sentman's interview, Defendant Isabel said Defendant Jason was not forcing her to pay the fines and she continued to allow Defendant Jason to use her home because he had no other place to take the dogs. A copy of Detective Sentman's Complaint Report is attached and incorporated as "Exhibit A5". 48. The Zoning Ordinance of the Township, specifically states that by permitting such use without a variance or special exception, Defendant Isabel, as property owner is in violation of the Township Zoning Ordinance by continuing to allow her son to operate his business out of her home. WHEREFORE, Plaintiff, Township of Lower Allen prays that an injunction be issued against and restraining Defendant Isabel from renting the subject premises and to any tenant using the premises in violation of township zoning ordinances and prohibiting the use of subject premises as described herein. Respectfully submitted, DALEY ZUCKER MEILTON MINER & GINGRICH, LLC y: DATE: r n f G? i? B Steven P. liner, Esquire Supreme Court I.D. # 38901 -Watthew A. Sembach, Esquire Supreme Court I.D. # 308727 635 N. 12th Street, Suite 101 Lemoyne, Pennsylvania 17043 (717) 724-9821 Solicitor for Plaintiff, Lower Allen Township "EXHIBIT A 11 SEP-30-2011 FRI 01:04 PM P, 06 ..?..... ;.r............... If 41 /LOWERALLENTOWNSH/P w. 2239 GETTYS,&VRG ADAO -CAMP MILL, NNNSYL VAN/A f7m July 19, 2010 Isabael Snyder 417 A lendale Way Camp Hill, PA 17011 Re: Termination of dog boarding and day care conducted from your home by Jason Snyder Dear Mrs. Snyder: Our department became aware of the above-referenced business due to complaints from your neighborhood, and'a letter dated May 10, 2010 was sent to you by.Linda.Hockenberry. This letter included a cease and desist directive that had a deadline of May 19, based upon the date you signed the certified mail receipt. Jason Snyder subsequently contacted me about legitimizing the business as a home occupation, On Julie 4, 2010, Mr. Snyder submitted a zoning permit application that I could not approve, since home occupations with impact require a special exception approval from the Zoning Hearing Board. In. addition, the Jason Snyder did not meet the residency requirement for a home occupation, and the business being conducted met the zoning ordinance definition of "kennel", since dogs were being kept for compensation. Concurrently, Mr. Snyder submitted an application to the Zoning hearing boad for,the special exception approval, and variances from kennel and home occupation rules, At the conclusion of a public hearing conducted on July 15, 2010, the ZHB denied all requested relief. Consequently, I am not authorized to issue the requested zoning permit, and the dog boarding and day care business being conducted from your home must be terminated by rely 31, 2010. It is my understanding that PA Dog Law enforcement officers have issued a cease and desist order with a more stringent deadline, so my notice does not supersede that deadline. incerely, o . 1VI. Eby Building & Zonin Coordinator cc., Jason Snyder Phone: (717) 975.7575 w* w.lo.wer-alien. pa. us "EXHIBIT B" 'IN THE MATTER OF THE APPLICATION OF JASON SNYDER BEFORE THE LOWER ALLEN TOWNSHIP ZONING HEARING BOARD CUMBERLAND COUNTY, PENNSYLVANIA DOCKET NO.. 2010-03 DECISION DENYING VARIANCES AND SPECIAL EXCEPTION The Applicant requested variances and .a special exception for a staging area for dog walking and for dog daycare. A hearing was held before the Board on July 15, 2010. FINDINGS OF FACT 1. Notice of the hearing was properly advertised, the subject property was posted, and all property owners required to be notified of the hearing were notified in accordance with the. Codified ordinances. 2. The Applicant is Jason.Snyder. 3. The s.ubj ect property is a parcel of land in an R7-1 Zoning District, improved with a single-family detached dwelling known as 417 Allendale Way. 4. The subject property is owned by Isabel E. Snyder; who resides at the subject property. 5. The Applicant is I-sabel E. Snyder's son.. 6. While the Applicant spends a considerable about of time at the subject property, he resides elsewhere in an apartment. 7. The Applicant seeks relief to use the subject property as a staging area for dog walking and for dog daycare. 8. On an average day, the Applicant picks up dogs at their owner's residence and takes them to the subject property where they are walked, fed and kept for varying period of time, typically, at the latest until 5:30 p.m. 9. Applicant has had as many as 17 dogs, but the average number is ten. 10. Approximately 30 days per year, dogs are kept at the subject property overnight. 11. The dogs have access to a couple of rooms in the dwelling, and are occasionally left out to the back yard, which is fenced. 12. Weather permitting, the Applicant takes the dogs for a walk lasting from 90 minutes to 2 hours, within and outside of the Allendale Development. 13. Many residents of the neighborhood attended the hearing. Some testified in support of the application, but the majority were opposed to it as a business use in a residential area, and because of concerns about safety, noise and other reasons- - 2 - CONCLUSIONS OF LAW 1. Under Section 220-269 of the Codified Ordinances, the Zoning Hearing Board has jurisdiction to hear and decide requests for variances and special exceptions. 2. Pursuant to Section 220-11(E), a home occupation under Section 220-165 is a permitted use in an R--1 Zoning District. 3. A home occupation is defined in Section. 220-6 as an accessory business or commercial activity, conducted entirely within a residential dwelling by one or mbre of the permanent residents. 4. A kennel is defined in Section 220-6 as a structure on any lot on which animals are kept, boarded, raised, bred, treated or trained for a fee.. 5. A kennel is not a permitted use in the R-1 Zoning District. 6. Applicant's operation cannot be a "home occupation" because he is not a permanent resident of the subject property. 7. The Applicant cannot meet the requirements of a special exception under Section 220-165(B) of the Codified Ordinances because his operation is'not a home occupation. 0. Applicant's operation is encompassed within the broad definition of the term "kennel." - 3 - 9. There was no evidence of any unique physical circumstances or conditions of the subject property which could give rise to an unnecessary hardship. 10. The subject property has already been developed in conformity -with the Zoning ordinance, and a variance is not necessary to enable the reasonable use of the subject property. DECISION In view of the foregoing findings and conclusions; and in consideration of the testimony and evidence presented to the Board, it is the decision of the Board that the Applicant's request for variances and a special exception be and is hereby denied because Applicant did not meet the requirements for relief. LOWER ALLEN TOWNSHIP ZONING HEARING BOARD bate : ?'c/I D10 So ' r 4 - "EXHIBIT C" Complaint Report Commonwealth of Pennsylvania Lower Allen Twp Complaint Information Complaint Number Locked Record Follow Up I Call For Service T O 742-01 3 No INo PANIVICP Description iPANIMAL COMPLAINT Status Priority Method Received Date/Time Received Cleared 3 Radio Dist)atch 12120[2007 12:06:00 Day of the Week How Handled Thursday Officer Assi ned Complaint Nature Wyland reported that she was bitten while she was attempting to go to her car after being at the dog park at the 1 ^%arar Allen rt`_nmmiinifv Pnrk_ 'C mplaint Location Street Number Street Block Predirection Street Name Street Type 7Inaction 4075 ILISBU RD PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number Cumberland Location Township Magisterial District Cilyrrown Political Subdivision Lower Allen Tow h Mech i sbur State Zone Number Zip Code Area Grid Residence Typa Unit Type PA 2 17055 2401 Unit Number Latitude Longitude Location Type Country 40.1693 -76.921 United States of America US Location Description 9130/2011 1:43:15 PM Page 1 of 5 Comolainant Information Salutation first Name 1JOAN Middle Name Last Name IWYLAtiD Suffix Date of Birth Race Sex Address 103 SUNSET VIEW DR Apartment City State I PA Zip Code 17070 Phone Number 1 Area Code 717 1 Number 7743700 1 Ext Phone Type iWork Phone Number 2 Area Code 17 Number 7743700 Ext i Phone Type Work Notify Complainant No Cali Taker ID MJGUTS Dispatcher ID 1 WAKL cNET Complaint 461275 - User Defined Field 1 User Defined Field 2 User Defined Field 3 User]Odftied Field 4 ComplainantAssociate Information Salutation l Name first Middle Name Last Name Suffu< vin McCartin Date of Birth Race Sex i socation type r l White ae ml Address 410 Allendale Apartment City I State Zip Code 1 1 CamR Hill PA 17011 Phone Number 1 Area Code er Phone Type 717 76455630 Cell Phone Number 2 a Code Number l Ex, Phone Type 717 User Defined Feld 1 User Defined Field 2 Other User Defined Field 3 User Defined Feld 4 9/3012011 1:43:15 PM Page 2 of 5 Salutation First Name Middle Name Last Name 1 Suffix Joe 1(osangy1c Date of Birth Race Sex ociation Type Address 208 F neview Road State ZIP Code Apartment Hill A 17011 7MCaD Phone Number 1 Area Code Number Ext Phone Type l 71 17310397 l Home Phone Number 2 Area Code Nianbar Fxt Phone Type 717 User Defined Field 1 User Defined Field 2 Informant User Defined Field 3 User Defined Field 4 Salutation First Name Middle Name Last Name Suffix Jason Sn der Date of Birth Race Sex AssodaUOn Type Address 1137 Columbia Avenue Apartment city state Zip Code 1 I 17011 PA Cam Hill Phone Number 1 Area Code Number Fxt Phone Type 17 1 9751880 Home Phone Number 2 Area Code Number l Ext Phone Type 7 7 User Defined Field 1 User Defined Field 2 SUSDOCt --4 User Defined Field 3 User Defined Field 4 Officers Involved 9/3012011 1:43:15 PM Page 3 of 5 Officer Name Role Resource # Curtis, Edward -1817 - Lower Allen Tw Officer Dispatched 11831 Street Number J 4075 Street Block Predirection TISIURN reet Name Street Type Postdirection POBox Goss-Predirectlon Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County C r d Jurisdiction Number CU Location Township Magisterial District City/Town Political Subdivision State PA Zone Number Zip Code Area Grid Residence Type I Unit Type Unit Number Latitude Longitude Location Type Country nit St ates of A i Location Description Dispatched 1212012007 12 :11:00 Enroute Arrived 1 12 :30:0 Cleared 2-/2(1/207 12 :38:00 User ed Field 1.2 7 User Defin Field 2 User Defined Field 3 User Defined Meld 4 Officer Name Role Resource # Calaman, Ton -1814 - Lower Allen Tw lReporting. Officer 11827 Street Numher 4075 Street Block Predirection Street Name ILISBURN Street Type RD Postdirection PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County tGumberland Jurisdiction Number Location Township Lower Allen Magisteltaf District Cityrrown Mechanics r Political Subdivision state PA Zone Number 2 Zip Code 17055 Area Grid 2401 Residence Type Unit Type Unit Number Latitude 40. 93 Longitude -76,921 Location Type Country United a of America- Location Description Dispatched 12/2712007 15:58:00 Enroute Arrived 1i 15:58:00 Cleared 7 Ur Defined aid 1-2 1 User n' rid User Defined Field 3 User Defined Reid 4 9/30/2011 1:43:16 PM Page 4 of 5 Attachments File Type I maue File Name IW20071201073amdf Description Note o Ko a ovic ref letter he received from Snyder File Type I e I File Name lat20071201073b,odf Description CODV of envelope and letter received from Snvder Comments Comment Narrative by Ofc Curtis 18-31,.12/20107 On this date, I was dispatched to call Wyland regarding an incident at the Lower Allen Dog Park. Wyland was attempting to go to her car when she was attacked by a red Labrador Retriever. She was bitten in the thumb and her dog was also injured. The owner of the dog was with approximately 7 other dogs including Pugs and a small bulldog. He was described as a white male 57", medium build, 30's. He also described himself as a dog behavioralist. I checked the area and was unable to locate the owner. A press release was prepared for information. Wyland will contact me to update the medical conditions of her and her dog. Comment Supplemental Report by Sgt. Greg Thomas on 12126/07 On 12/26/07 Kevin McCartin called after reading the article in the newspaper relating to this incident. McCartin advised that he may know who the suspect is. McCartin stated that his neighbor accros the street at 407 Allendale Way has a son who comes to Allendale to walk dogs. The subject will walk five to six dogs at a time in Allendale. The subject also takes the dogs to the dog park. McCartin said the subject drives a gold colored Chrysler sedan, Stratus or Seabring. McCartin does not know the subject's name. I will pass this information to Ofc. Curtis. Comment Supplemental by T Calaman On 12127/07 at 1558 hours I took a phone call at the office from Kosanovic in reference to this complaint. Kosanovic related that he lives in Allendale and received a letter from Jason Snyder. In the letter he describes himself as a "Dog Behavioralist" and offers his services. Kasonovic read the article in the newspaper about this complaint and found the information very similar. He will provide a copy of the letter and copy of the envelope that he received. 1 will pick it up at his residence. Information added to this report and forwarded to Ofcr Curtis. Comment Supplemental by Ofc Curtis 18-31, 113/08 I spoke with Snyder today and he denied being involved with the dog bite at the park. I will be showing his icture to the original com laintant to see if she can identi him. 9/30/2011 1:43:16 PM Page 5 of 5 "EXHIBIT D" Cumberlink.com: Tuesday's Sentinel police reports: baby jesus stolen from church Page 1 of 2 Home / News / News Tuesday's Sentinel police reports: baby jesus stolen from church • Story • Discussion Tuesday's Sentinel police reports: baby jesus stolen from church By staff reports, December 24, 2007 The Sentinel - cumberlink.com Posted: Monday, December 24, 2007 12:00 am 1 (0) Comments Font Size: Default font size Larger font size retweet • • Recommend Be the first of your friends to recommend this. Here are Tuesday's Sentinel police reports: Baby Jesus stolen from church A baby Jesus was stolen from the a church nativity scene early Sunday, according to Mechanicsburg Borough police. The figure, valued at $100, was taken from the manger at St. Joseph's Church in the 400 block of West Simpson Street between 12:30 and 7 a.m., police say. Police are asking anyone with information on the theft to call 691-3300. Dog bite investigated Authorities are investigating a report of a woman being bitten by a dog at Lower Allen Community Park Thursday, according to Lower Allen Township police. The woman was walking to her car with her dog between 11 a.m. and noon when she was attacked by a red Labrador Retriever, police say. The woman's hand was injured, police say. Police say the owner of the retriever was with about seven other dogs, including pugs and a small bulldog. He was described as a white male in his 30s, about 5-foot-7 with a medium build, and police say he called himself a dog behavioralist. Police are asking anyone with information about the incident to call 975-7575. Teen smoked pot while driving, police say A teen was arrested after being caught smoking marijuana while driving in Middlesex Township Monday, according to Middlesex Township police. Cumberlink.com: Tuesday's Sentinel police reports: baby jesus stolen from church Page 2 of 2 The 17-year-old male was driving well over the speed limit and traveling in the wrong lane at 4 a.m. in the 100 block of Wolf s Bridge Road, police say. He was charged with two counts of DUI and one count each of possessing marijuana and drug paraphernalia, police say. Copyright 2011 The Sentinel - cumberlink.com. All rights reserved. This material may not be published, broadcast, rewritten or redistributed. Posted in News on Monday, December 24, 200712:00 am Updated: 3:20 pm. Share This Story Print Email ShareThis Other Stories Sponsored Links Penny Stock of the Dal Rated #1 Penny Stock Newsletter on the net http://www.VictoryStocks.com/ Coast Accounting Software #1 Rated Construction Acct Software Improve Profitability w/ Spectrum@ www.DexterChaney.com/Accounting Hot Stock Pick - OBJE Obscene Jeans & Lifestyle Brands. Invest, Trade, Stocks. www.Obsceneleans.com Ads by Yahoo! vows shop your tOtai NNW t a asr+ 9pn" i 41'911 Iftgh St sage Sate . $ l rn Catiiate t7mar r "" ice 3 IY fetoT,;ai garWtte.m mj_ I 12M ,i.+• HEADGUM' I-PI 77 "EXHIBIT E" Lower Allen Twp Complaint Report Commonwealth of Pennsylvania Complaint ,information Complaint Number Locked Record Follow up 08 1-00141 No No Description P RAS MNT NOT ACT MetirodReceh Status A =5 a i D' R Day of the Week How Handled Thigradav Officer Assi ned inn Nature za reported her son, Joseph, had a confrontation with a neighbor, Jason Snyder. Snyder's dog came out o house and started interfering with Borza's dog. When Borza told him the dog should be leashed, Snyder Page 1 of 4 913012011 1:45:08 PM Complainant Information Salutation Rrst Name IJOANNA Middle Name Last Name 1130117A Suffix Date of Birth Race ex Address 421 END LE WY Apartment L I FCAMP State PA 1 Zip Code 17011 Phone Number 1 Area Code 711 Number 99 `12 84 Ext Phone Type lHome Phone Number 2 Area Code 71 Number Ext l Phone Type Work Notify Complainant No Cali Taker ID CEHAL Dispatcher ID B 1 MET C omplalnt 4: 466627 User Defined Field 1 User Defined Field 2 User Defined Field 3 User ned Field 4 9/3012011 1:45:08 PM Page 2 of 4 Page 3 of 4 9/30/2011 1:45:08 PM Officers Involved -1817 - Lower 831 Location Disoatched Street Number 421 Street Block Predirection eet Name T'LLEND ALE Street Type Postdirection PO B ox Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County ClAmblarl ignd Jurisdiction Number C Location Township Ma st' d City/rown Political Subdivision State PA Zone Number Zip Code Area Grid Residence Type I Unit Type Unit Number Latitude Longitude Location Type Country United States of America (USA) Location Description Dispatched 0 1 7:49:00 Enroute Antved 1 7:4.0 seared 3/2008 18 0 :19 User Defined aid 1-2 7 User Dined el 2 User Defined Field 3 User Defined Field 4 Comments itial Report, Oft Curtis 18-31, 1/3/08 this date, l spoke with Joseph Borza by phone. He reported he was walking by Jason Snyder's house when rdees boxer came outside. He went to Borza's dog and began to sniff it, making Borza nervous. Snyder came side and Borza told him he should have his dog leashed. Snyder said the dog was on his property and he n't. The dog then came on the sidewalk and Sorza told him that the dog was now off the property. Snyder ponded by pushing him down. Borza walked away and Snyder's dog followed him down at least 3 mores ses away. za is 14 and Snyder is 39. Borza's mother is unsure what action she wants to have action taken. I will contact on Monday to see what she would like to do. I explained Snyder would be cited for Harassment is she 9/30/2011 1:45:08 PM Page 4 of 4 "EXHIBIT F 11 Complaint Report Lower Allen Twp Commonwealth of Pennsylvania Compiant Informati a INUIrt Nawre )y Osborne reported a continuing sl h mself. Neighbors have told h m that it is most ,Il Ilkley Jason Snyder. I mains, Osborne has not witnessed th ship Ordinance Ordinan ivised Osborne that, if there is a witness to an actual volation of the violat ons! I found no re ord in CNet that Snyder has beenceservedwill irved and Snyder can be cited for additional Page 1 of 3 9/30/2011 1:46:44 PM Complainant Information Salutation, =Roy Middle Name J. Last Name Suffix Date of Binh 1 12/ 69 Race White ex Male ddress A 425 ledl a Apartment City Cam Hill I State PA 1 Zip Code 17011 Phone Number 1 Area Code 7 17 Number 7 Ext Phone Type lHome Phone Number 2 Area Code Number Ext Phone Type Notify Complainant N Call Taker ID SBKEEN Dispatcher ID I cNET Complaint M. 479225 er Us Defined Field 1 User Defined Reld 2 h User Defined Reld 3 ser I IF ffi' Co •plOar&4 ? n Salutation First Name Jason Middle Name Last Name nvder Suffix Date of Birth ce TRa- t Sex Imale 7on Type Address 417 Allendale Way Apartment City C Hi l I State PA Zip Code 17 1 Phone Number 1 ea Code 717 Number Ext l Phone Type Home Phone Number 2 Area Code Nunbar J EKI Phone Type User Defined Field 1 Ens violator. User Defined Field 2 user treflned Reid 3 User Defined Flald 4 9/30/2011 1:46:44 PM Page 2 of 3 Officers Involved Page 3 of 3 9/30/2011 1:46:44 PM Name Officer Dispatched 1812 :kler. Curt -1812 -Lower Allen Twp "EXHIBIT G" Complaint Report Lower Allen Twp Commonwealth of Pennsylvania. Co nplalnt Information Complaint Number - Locked Record Follow Up 00 0 LA 8 o No Destxiption NI L COMPLAINT P Priority Method Receive status Pe s n Cleared Day of the Week Handled Friday Officer ned Complaint Nature Shuler came in to the station to let us know that on Mr . property and ran down onto the street and attacked Mr go of his dog. He did not want to press any charges or case something comes back that he hurt the do noth e of the dogs that Mr. Snyder watches came off of his . Shuler's dog. Mr. Shuler kicked the dog so he would let cause any problems, he just wanted to let us know that in Page 1 of 4 9/3012011 1:47:38 PM Complainant Information Salutation Mr. First Name Jay Middle Name Last Name S Suffix Date of Birth 0 /1 45 Race W i e Sex Male Address 40 Allendale a Apartment I city lCami:i, Hill I state PA 1 Zip Code 17011 Phone Number 1 Area Code 717 1 Number 73103§4 Ext Phone Type lHome Phone Number 2 a Code 717 Number E t Phone Type Notify Complainant CeliTakeflD Dispatcher ID 1 cNETComplalnt#: 481890 User Defined Field 1 User Defined Field 2 User Defined Field 3 User Defihe Ffeld 4 Complaf?niaritssociatf3 Information Salutation First Name Middle Name Last Name Suffix M Da te of Birth Rece Sex ocletion Type 01/11/1969 Address 41 Allendale W Apartment City State 1 Zip Code Cam Hill I PA 17011 Phone Number 1 Area Code Number Fxt Phone Type 17 j 9 9999 l Home Phone Number 2 Area Code Number Ext Phone Type 717 User Defined Field 1 User Defined Field 2 Co in User Defined Field 3 User Defined Field 4 I Officers Involved 9/30/2011 1:47:38 PM Page 2 of 4 -1859 - Lower Allen Twp Reporting Officer 11859 Page 3 of 4 9/3012011 1:47:38 PM rName skier. Curt -1812 - Lower Allen Twp Reporting Officer 1812 "EXHIBIT H" Complaint Report Lower Allen Twp Commonwealth of Pennsylvania Complaint Information mplaint Nature ispatched to check the area of the 1500 block of Cedar Cliff Drive in reference to man kicking a dog he was Page 1 of 4 101512011 11:30:56 AM Officers Involved 10/5/2011 11:30:56 AM Page 2 of 4 R? Vltln v.uv.+ irlato. Michael -1821 - Lower Allen w Comments )riginal Narrative Friday 09/26108 M Scarlato 1821 dar Cliff erence ?t 0826 hrs, 1 was dispatched hda s he area of the ad kicked one Pof Gas them station, 1500 the ar arandtwasf unable to a Hale le individual whom m was was walking g ocate the individual. ancy Ambrose resident ,'fter being unsuccessful locating me th individual, she was travel traveling to work in the 1500 b lock of Cedar Cliff Drive 423 :andlewyck Road. Ambrose advised it approximately 0820 hrs, she witnessed a male individual whom was walking several dogs kick one oft the logs. Ambrose was upset by what she witnessed and contacted police. Ambrose was unsure if the dog was injured or not. Ambrose is familiar with ts often sees this individual walking the dogs aro ndthelneighborhoodland e hat he lives in Allendale. Ambrose ocal area. action was a violation informed Ambrose that 1 would researh the action was a violation, I would cite the male, however, f he plead not guilty to the of he law. I inquired that if the e act ;itation and requested a hearing on the matter she would have to testify. Ambrose stated that she would testify. I know the action was a violation. I reviewed the statue and verified that has had contact with him before I will contact Ambrose to advise ndividual's information for her that 1 will be citing the individual once I obtain his information. to follow. AfflfflBfll Supplemental Narrative Saturday 09/27108 M Scarlato 1821 %t 1011 hrs, I contacted Nancy Ambrose in reference to advise her that I was able to locate the individual vho kicked the dog yesterday. Upon speaking with Officer Curtis and researching my past emails, I was able to Camp Way, Hill, and properly identity 880 individual ocate Ambrose t at I identified the indivl dualla d that he would be ci ed.l, Nith ith a a phone number of 975 ,mbrose was very pleased and again reiterated that she would be willing to testify in any future court proceedings. 4t 1026 hrs, I attempted to contact Snyder using his home phone number listed above, however, I was unsuccessful. I left a message requesting a return phone in reference to an incident that had occurred /esterday. Awaiting Snyder's return phone call. Based upon the witness information, 1 completed a summary non-traffic citation, Citation number P5997555-4, `or Cruelty to Animals. Citation filed this date. Page 3 of .4 1015/2011 11:30:56 AM comment Comment 0912612008 08:27:36 OperlD: CLBEECPQ>POSS ANIMAL ABUSE Comment 0912612008 08:27:36 OperlD: CLBEECPQ>CFS Code changed from to 105C01 Comment 0912612008 08:28:41 OperlD: CLBEECHCANCI DENT HOTCALLED. CLBEECPQ>Fr 1130 CARLISLE RD, A CU;IN THE AREA Comment 0912612008 08.28:51 OperlD: Comment 09/2612008 08 p Comment 0912612008 08:28:51 OperlD: CLBEECPQ>POSS ANIMAL ABUSE Comment 0912612008 08:28:54 OperlD: CLBEECIRANCIDENT ROUTED AFTER HOTCALL Comment 0912612008 08:30:16 OperlD: MSFOORDP>Res: 1821 Disp Comment 0912612008 08:32:04 OperlD: MJGUTSCO>EXP ONLY 07109 Comment 09/2612008 08:34:09 OperlD: MSFOORAR>Res: 1821 09/26/08 at 08 27:3gumber: 1821 Comment 0912612008 from 08:63:62 COperID: LBEEC PID:C MSFOOCL>Finish/Clear Resource Narrative entered Operator Number :CLBEEC Incident Number :0008016819 Location of Incident :1130 CARLISLE RD,LA CU;IN THE AREA Call Back Phone Number :9030756 Problem Description :POSS ANIMAL ABUSE Chief Complaint Number :105 Dispatch Level :106C01 Dispatch Level Suffix : Medical Response Text :Charlie CAD Incident Code :105C01 is not scene Responder Script :Animal. Caller TY. 3 This inc dent just occurrred. 4.N/Ah5 The location of the animal is: IN THE incident involves animal CRUEUEL AREA OF THE BP STA 6.It is not known if the animal is dangerous. --Comments: IN THE AREA OF THE BP STA- Caller Name :NANCY AMBROSE Narrative entered from ProQA: CLBEEC PID:CLBEEC on 09126108 at 08:28:51 Updated Narrative from ProQA: Operator Number :CLBEEC Incident Number :0008016819 Location of Incident :1130 CARLISLE RD,LA CU;IN THE AREA Cali Back Phone Number :9030756 Problem Description :POSS ANIMAL ABUSE Chief Complaint Number :105 Dispatch Level :105C01 Dispatch Level Suffix : Medical Response Text :Charlie CAD Incident Code :106C01 caller IN THE scene Responder Script :Animal. Caller Statement: POSS ANIML ABUSE. 3 .This incident justoccurrred. 4.NIAh5.The to ation of the animal Ths: is incident involves animal CRUELTY. 10.No one senjuredn Immediate danger. 8.T e AREA OF THE BP STA 6.It is not knowislnot known. dangerous. animal is not confined. 9.The animals description is not known if the animal is injure. did not suspect1person responsible is still d IN THE AREA OF THE BP STA in a o vehicle. -_Comments: description is not known. 14 . The suspect - --Comments: MALE WALKING NG T PACK OF HDOGS AND WAS POLICE ARE AWARE OF THIS PER ON- WEARING THAT AND CALLER THINKS Comments: CALLER SAW HIM KICKING THE DOGS- Caller Name :NANCY AMBROSE Page 4 of 4 10/512011 11:30:56 AM "EXHIBIT 1 " Magisterial District Judge 09-1-01 _ DOCKET Docket Number: MJ-09101-NT-0001301-2008 Non-Traffic Docket Commonwealth of Pennsylvania v. raw Jason M Snyder Page 1 of 3 ------- N .__ CASE INFORMATIO ..... - terial District Judge Charles A. sue Date. i 09/26/200 Judaened: s Mag Clement Jr. File Date: 09/29/2008 OTN: . Lower Allen Township Police Dept Arrest Date: Guilty Plea Arrestinyy- Disposition: Citation * P5997555 4 1 Disoosit - 1012312008 Coun -_ '- Cumberland ?_ Closed - .. f Lower Allen Township Townshi ON STATUS INFORMATI - Pmr•eSSII1Q Status Status Date ------' Care Status _ 11/2412008 Completed Closed 10127!2008 Case Balance Due e Disposed/Penalty imposed C as 1012312008 Awaiting Sentencing 10/23/2008 Awaiting Summary Trial 10107/2008 09/29!2008 Awaiting Plea - CALENDAR EVENTS --- _ _ ' Schedule Case daa oe T - .......... Sche ule Start Date Start Tie Room 01 Juda__ a Name isterial District Judge Ma Status Scheduled v Event Courtroom: MDJ-09-1- 10/23/2008 3:30 pm g Charles A. Clement Jr- Summary Trial ------ -. DEFENDANT INFORMATION _ Sex: Snyder, Jason M Male White Name: Race: 01/11/1969 Date of Address es : Primary Camp Hill, PA 17011 No Advised of His Right to Apply for Assignment of Counsel? No Public Defender Requested by the Defendant? No Application Provided for Appointment of Public DefendeR No Has the Defendant Been Fingerprinted? - CASE PARTICIPANTS .- . -. -..--- .._...- - Participant? Scarlato, Michael Jeffrey Arresting Officer Snyder, Jason M Defendant .......----_._ .....................- - ------ ----CHARGES - - QIMLe Dt isp Grade Desc-riotion 0912612008 Guilty Plea # Charae r ar„ S Cruelty to Animals Printed: 09/3012011 12:02 pm stem of ither the courts MDJS 1200 immediate heets. Recent entries made in the court filing offs he Admini trative office tof Pennsylvaon these docket nia Courts assumes any li bil ty for inaccura a the orJd delayed data! errors or eat information should not be used in place of a criminal history background check which can only be the Commonwealth of Pennsylvania nor -- --- I who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. omissions on these docket sheets. Docket sh provided by the Pennsylvania State Police. Employers nw subiect to civil liability as set forth in 18 Pa.C.S. Section 9183. Magisterial District Judge 09-1-01 DOCKET Docket Number: MJ-09101-NT-0001301-2008 Non-Traffic Docket Commonwealth of Pennsylvania V. Jason M Snyder DISPOSITION / SENTENCING. DETAILS D' t' Date Was Defendant Present? Page 2 of 3 Case Disposition Isposl ion 10/2312008 Yes Guilty Plea Offense Sep./Description Offense Disposition 1 Cruelty to Animals - Guilty Plea - - - - - REGISTRY ENTRY INFORMATION Filed Date -- Entry Filer Applies To 11/24/2008 Penalty Satisfied _ _ -Magisterial District Court 09-1-01 - Jason M Snyder, Defendant - - - - 10/27/2008 - Penalty Assessed _ -Magisterial District Court 09-1-01 - Jason M Snyder, Defendant - - 10/23/2008 Guilty Plea Magisterial District Judge Charles A. Jason M Snyder, Defendant Clement Jr. _ _ _ _ - 10/13/2008 Subpoena issued via Hand Delivery - - - -Magisterial District Court 09-1-01_ - Restricted Participant - - - - - 10113/2008 - Subpoena Issued _ -Magisterial District Court 09-1-01 _ Restricted Participant - - - - - 10/07/2008 - - - - _ Summary Trial Scheduled _ -Magisterial District Court 09-1-01 - Jason M Snyder, Defendant - - - - 10103/2008 _ - Certified Summons Accepted Magisterial District Court 09-1-01 ------ - Jason M Snyder, Defendant - - - - --- - 10/01/2008 Summons Issued Magisterial District Court 09-1-01 - Jason M Snyder, Defendant - - - - --- 10/01/2008 -------- Certified Summons Issued -Magisterial District Court 09-101 - Jason M Snyder, Defendant - - - - --- 09/29/2008 --- - --------- Non-Traffic Citation Filed ---------- - -Magisterial District Court 09-1-01 -- ---- Jason M Snyder, Defendant - PAYMENT PLAN SUMMARY - -- _... _... - Payment Plan No. Payment Plan Freq. - Next Due Date Active Next Due Amt. Overdue Amt. 09101-2008-P0001184 Single Payment No $0.00 $0.00 Responsible Participant Snyder, Jason M Payment Plan History: Payment Dt. Transaction Type Pavor Participant Role Amoun 11/24/2008 Payment Snyder, Jason M Defendant $127.50 MDJS 1200 Page 2 of 3 Printed: 09/30/2011 12:02 pm Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. ce,.w,,, of ni at Qp I may hn suhleet to civil Iiability as set forth in 18 Pa.C.S. Section 9183. i ... Magisterial District Judge 09-1-01 _ DOCKET - -- Docket Number: MJ-09101-NT-0001301-20 Non-Traffic Docket Commonwealth of Pennsylvania V. Jason M Snyder Page 3 of 3 _ ..... ` CASE FINANCIAL_INFORMATIO $0.00 Next Pavment Amt: Case_ Balance: Last payment Amt: Next Pav ment Due Dt:_ Non_ Monetary A Payment Amt B la ance Assessment Amt Adiust? mt m Pa en -'a' ($8 pp) . $0.00 Assessment Tvoe $8.00 $0.00 $ .00 00 $0 ($2'00) $0.00 Judicial Computer Project $2.00 $0.00 . $0.00 ($27.30) $0.00 ATJ County Court Cost (Act 204 of 1976) $27.30 $7 35 $0.00 $0.00 $0.00 ($7.35) ($7.35) $0.00 $0.00 State Court Costs (Act 204 of 1976) $7 35 $0.00 $0.00 Commonwealth Cost - HB627 (Act 167 of $0 00 ($35.00) $0.00 1992) Crime Victims Compensation (Act 96 of 1984) $35.00 $25.00 $0.00 $0.00 . $0 .00 ($25.00) ($10.00) $0.00 $0.00 Victim Witness Service (Act 111 of 1998) $10.00 $0.00 $0 .00 Domestic Violence Compensation (Act 44 of $5.50) ( $0.00 1988) $5.50 $0.00 $0.00 00 $0 ($50.00) $0.00 Postage - Case $50.00 $0.00 . Title 18 - Payable to Municipality Printed: 09/3012011 12:02 pm MDJS 1200 errors o Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts the ty for t delayed Commonwealth of Pennsylvania nor the Administive Oce of nia Courts assumes any sheets. Docket sheet information should not be`used in place of a criminalihistory background check, which can data only be omissions on these docket s provided by the Pennsylvania State Police. Employers who not comply with the provisions of the Criminal History Record Information Act 0 S Pe.C.S. ,.., o, ne of seal may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. "EXHIBIT J 11 Complaint Report Lower Allen Twp Commonwealth of Pennsylvania Ottl @f au 1 , -? coming over to his six dogs dispute, male subject Jason Snyder became upset about Enricco's dog -,jA.+?nnai information. Page 1 of 4 9/30/2011 1:50:36 PM 9130/2011 1:50:36 PM Page 2 of 4 Officers Involved Page 3 of 4 9130/2011 1:50:36 PM ------------ Name Reporting Officer 1808 ,4mmn rlnnald -1808 - Lower Allen Tw I Report, Corporal Sentman 180810 November 2008 n this date, I was asked to speak to David Erico who had called the station to report a subject put a letter in his ailbox. Enrico stated that last week he had a problem when a male subject, Jason Snyder, walked his six dogs Enrico's home. Enrico's dog Jax was with Enrico, (verbal command and control over the dog), and was ated near the open garage door. Snyder walked his six dogs by Enrico's home and Jax ran up to greet the cgs. Enrico was upset by this, so he went down and verbally corrected his dog. He grabbed the dog by the liar, and removed him from the sidewalk and into the house He stated he did put a foot into the dog's rear end correct the dog, but aded that he did not abuse his dog. Enrico stated he was inside his home when this took M^e nrico stated that later in the week, he received a letter in his mailbox.. The letter was from Snyder and was Britten in response to his actions to correct his dog. Snyder scolded Enrico for his actions, and stated that ubsequent actions like he had that day would result in his filing a report with the police. Enrico also stated that nyder made a comment in the letter about Enrico's military service, and questioned if the actions he took that ay were taught to him in the military. ie letter is signed by Snyder. Enrico suspects that Snyder removed mail from his mailbox and obtained his formation to write his name on the letter. In the letter, Snyder stated that the date of the offense was October 2008. Enrico stated that this ws in-correct and the correct date of the event was 3 November 2008.. US Postal office was contacted by Enrico reference to this incident. They are to investigate the Federal ,al violation reported by Enrico. was aked by Enrico to document the incident and take no further action against Snyder. 9/30/2011 1:50:36 PM Page 4 of 4 "EXHIBIT K 11 Lower Allen Twp Complaint Report Commonwealth of Pennsylvania %mpl nt Information ire. ??. .. Nawre THE DOGS TO URINATE IN HIS FLOWER MAN BATCHELER OBSERVED "JASON" (DDOGS OG WALKER) ALLOW OF HIS GARDEN, AND AS JASON WALKED AWAY HE BATCHELER TOLD JASON TO GE ^r ' u= M nWER BED. Page 1 of 3 9/30/2011 1:51:16 PM 9/30/2011 1:51:16 PM Page 2 of 3 Officers Involved "°""'° Rde 180.r 9/3o/2o11 1:51:16 PM Page 3 of 3 1-1- _.. -- 4 on7 _ i mower Allen -IWP - - "EXHIBIT L " Lower Allen Twp Complaint Report Commonwealth of Pennsylvania Complaint„ Information int Nature Innt called reference her neighbor, Snyder, allowing one of the dogs that he 'sits for run at large. She stated a German Sheppard without a leash under the care of Snyder nearly bit her dog who was on a leash. _ . __-_c ?_.cc ?........ 4-- Cnvrler'c mn1dr®d. Page 1 of 9/30/2011 1:52:10 PM 3 I Complainant Information Salutation Rrst Name lCarol Middle Name Last Name Suffix Date of Birth Race sex Address 1 Columbus Avenue Apartment Z Clry Cam Hill State PA Zip Code 17011 Phone Number 1 Area Code 17 Number 7 7374508 - Phone Type lHome Phone Number 2 Area Code 717 Number Ext Phone Type Notify Complainant Call Taker ID Dispatcher ID 1 cNET Complaint P. 1021846 User Defined Field 1 User Defined Reid 2 ' User Defined Reid 3 User ei 4 Com'plal" ` " s `?' la e. Salutation First Name Jason Middle Name Last Name ISny or Sufthl Date of Birth Race Sax Type r9oc'e"on Address 1437 Columbus Avenue Apartment J 9 CC-1ry 'II State Zip Code 170 1 Phone Number 1 Area Code 17 1 Number j 9751 Ex1 Phone Type Phone Number 2 Area Code 71 Number 1 Ext Phone Typa User Defined Feld 1 o I Person 00 User Defined Field 2 User nod User Defined Reld 4 9/30/2011 1:52:10 PM Page 2 of 3 Officers Involved Page 3 of 3 9/30/2011 1:52:10 PM rName ne. Kenneth -1856 - Lower Allen Twp Reporting Officer 185 "EXHIBIT N 11 Complaint Report Lower Allen Twp Commonwealth of Pennsylvania Compiaint {nformation, mpialnt Nature ispatched to this address for an active dog fight. I arrived and made contact with Jason Snyder bit a golden that I-A laying one dQg? ea boxer mix, a had released his dogs into the back yard together and while p n No further aroblems. Page 1 of 3 9/30/2011 1:53:56 PM I Complainant Information Salutation First Name Leslie Middle Name Last Name iDolan Suffix Date of Birth Race h' e Sex iFemale Address 414 Allendale Way Apartment City Cam Hill I State PA 1 Zip Code 17011 Phone Number 1 Area Code 7 17 Number Fxt Phone Type lHome Phone Number 2 Area Code 7 17 Number Ext Phone Type o Notify Complainant o - Call taker ID MRSNYD Dispatcher ID JEANS' 1 cNET Complaint it 1152737 User Defined Feld 1 User Defined Field 2 User Defined Field 3 User ned Feld 4 Corn ' ' t As ociate w Info atlas , Salutation First Name Middle Name Last Name suffix N im ISNYDER Date of Birth Race Sex sodetkm Type 1/1969 Address 417 Allendale WY Apartment city state Zip Code l Camp i I PA 1 17011 Phone Number 1 Area Code umber EM Phone Type ] 7 7 N 97518 80 l Home Phone Number 2 Area Code er E,,O Phone Type M 717 j 4 igi III User D efined Feld 1 User Defined Field 2 D User Defined Reid 3 User Defined Field 4 9/30/2011 1:53:56 PM Page 2 of 3 Officers Involved Page 3 of 3 9/30/2011 1:53:56 PM r N8M5 -tinez. Elias -1819 - Lower Allen Twp Reporting Officer 18 "EXHIBIT 0 " Complaint Report Coiriplaint,ln n Commonwealth of Pennsylvania Lower Allen Twp anO M Nature odi Teffeteller reported her daughter, Ruby, was harassed by a man walking dogs yesterday. She will talk to her 9/30/2011 1:55:06 PM Page 1 of 4 Complainant Information Salutation Tillro"tcd: me Middle Name Last Name T Suffix Date of Birth Race Sex Address Center Dr Apartment l city Carrip Hill I state PA 1 Zip Code 17011 Phone Number 1 Area Code 717 COMM ber J EKI Phone Type Pho ne Number 2 Area Code 717 Number Ext 1 Phone Type Notify Complainant Call Taker I D Dispatcher iD 1 cNET Complaint M 1186050 User Defined Field 1 User Defined Field 2 User Defined Field 3 User Field 4 9/30/2011 1:55:06 PM Page 2 of 4 Complainant Associate I information- _..- --- Suffix Salutation First Name MldIde Name Last Name 7?:1 R BE r e sodation Type of Birth t Zhite aimale Vict' m-- 06/3011995 ddress CENTER D zlp Code Apartment City City IZ CAMP HILL A 17011- Phone Number 1 a Code Number lExt Phone Type l 717 1975-2552 Home Phone Number 2 Area Code Number lExt Phone Type User Defined Field 1 User Defined Field 2 Victim User Defined Reid 4 User Defined Field 3 Salutation First Name Middle Name Last Name I Suffix J SON IM SNYQ Date of Birth Race Sex ation Type 1 S 01/11/1969 Address 1 Allendale WY state zip Code rtment qty PA 17011 Cam Hill Phone Number 1 Area Code Nber m Ext Type IPtione 51880 717 I9u Home Phone Number 2 a Code Number Are Ext Phone Type I 717 7610574 cell User Defined Field 1 User Defined Reid 2 d Field 3 Defined User User Defined Field 4 9/30/2011 1:55:06 PM Page 3 of 4 Officers Involved Edward -1817 - Lower Allen Officer 11817 I -+;- M -+M-1 Street Number S[eet Block Predirection Street Name lCenter Street Type Postdirection PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County CUrnberland Jurisdiction Number Location Township W i r Allen ownshiD Magisterial District -0 Citylrown 1 Imp I Political Subdh4slon a Zone Number 1 Zip Code 17011 Area ? d 1203 Residence Type Unit Type Unit Number Latitude 0.00 Longitude 0.00 ] Location Type Residence/H ome Country United Sta tes o America Location Description Dispatched 0 10:35:00 Enroute Q& W 10 :35:00 Cleared 910 10 :40:00 User Field 1-2 3 2 User Deffned Field User Defined Feld 3 User Defined Field 4 Relit.qd Incidents, incident Number Dar 'me Started Location 6 Center DR, Camp Hill. PA 1701 Status glosed 9/3012011 1:55:06 PM Page 4 of 4 . "EXHIBIT P 11 Magisterial District Judge 09-1-01 Docket Number. MJ-091 01 -NT-0000881-201 0 Non-Traffic Docket Commonwealth of Pennsylvania V. Jason M Snyder ' ,.CASE INFORMATION Judoe Assigned: Magisterial District Judge Charles A. Issue Date: Clement Jr. Page 1 of 3!! - I 08/24/2010 OTN: File Date: 09/07/2010 Arresting Aaencv: Lower Ailen Township Police Dept Arrest Date: Citation P8487261-3 Disposition: Guilty Plea Coun : Cumberland Disposition Date: 09/27/2010 Township Lower Allen Township Case Status Closed ' f r. NFOR T,ON rya ST U F" „W .H'`.=. 'r P77 . d Case Status Status Date Processing Status Closed 03/1712011 Completed 09/27/2010 Case Balance Due 09/27/2010 Case Disposed/Penalty imposed 09/27/2010 Awaiting Sentencing 09/07/2010 Awaiting Plea ORION, 11 1j::11111' ,:::, .. ,D F?ENDA Tai FORMA tON•; Name: Snyder, Jason M Sex: Male Date of Birth: 01/11/1969 Race: White Address(es): Primary Camp Hill, PA 17011 Advised of His Right to Apply for Assignment of Counsel? No Public Defender Requested by the Defendant? No Application Provided for Appointment of Public Defender? No Has the Defendant Been Fingerprinted? No TICIPANTS Participant Type Participant Name Arresting Officer Curtis, Edward Charles Defendant Snyder, Jason M -- - - . - - CHARGES- _. r• - - ! - # Change Grade Description Offense Dt. Disposition 1 18 § 5503 §§ A4 S Disorder Conduct Hazardous/Physi Off 08/24/2010 Guilty Plea DISPOS T ON / SENTE LING DETAILS Case Disposition Disposition Date Was Defendant Present? 09/27/2010 Yes Guilty Plea Offense Sea./Description Offense Disposition 1 Disorder Conduct Hazardous/Physi Off Guilty Plea - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Printed: 10/05/2011 2:26 pm MDJS 1200 Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 et seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. Magisterial District Judge 09-1-01 DOCKET Docket Number: MJ-09101-NT-0000881-2010 Non-Traffic Docket Commonwealth of Pennsylvania V. Jason M Snyder Page 2 of 3 REGISTRY ENTRY INFORMATION Filed Date Ent Filer Applies To 03/17/2011 Penalty Satisfied Magisterial District Court 09-1-01 Jason M Snyder, Defendant 09/27/2010 Penalty Assessed - - Magisterial District Court 09-101 c Jason M Snyder, Defendant - - - - 09/27/2010 - - Guilty Plea - - Magisterial District Judge Charles A. Jason M Snyder, Defendant - - - -- - Clement Jr. - - - - - - - - - - - - - - - - - - - - - - - - - 09/09/2010 - - - - - Certified Summons Accepted Magisterial District Court 09-1-01 - - - - - - - - - - - Jason M Snyder, Defendant - - - - - - - 09/08/2010 - - - - - - - - - - Summons Issued - - -Magisterial District Court 09-1_01 - Jason M Snyder, Defendant - - _ _ 09/08/2010 - - - - Certified Summons Issued -Magisterial District Court 09-101 - Jason M Snyder, Defendant - - - - 09/07/2010 Non-Traffic Citation Filed - - - -Magisterial District Court 09-1_01 - Jason M Snyder, Defendant - - - - PAYMENTPLAN SUMMARY Payment Plan No. Payment Plan Freq. Next Due Date Active Next Due Amt. Overdue Amt. 09101-2010-P0000999 Monthly No $0.00 $0.00 Resoonsible Participant Snyder, Jason M Payment Plan History: Payment Dt. Transaction Type Pavor Parficioant Role Amount 11/04/2010 Payment Snyder, Jason M Defendant $40.00 11/29/2010 Payment Snyder, Jason M Defendant $40.00 01/26/2011 Payment Snyder, Jason M Defendant $80.00 02110/2011 Payment Snyder, Jason M Defendant $30.00 03/17/2011 Payment Snyder, Jason M Defendant $102.60 MDJS 1200 Page 2 of 3 Printed: 10/05/2011 2:26 pm Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 at seq.) may be subject.to civil liability as set forth in 18 Pa.C.S. Section 9183. Magisterial District Judge 09-1-01 ;. , _ ., .. Docket Number: MJ-091 01 -NT-0000881-201 0 Non-Traffic Docket Commonwealth of Pennsylvania V. Jason M Snyder Page 3 of 3 CASE;F NANCIAI INFORMATION - - - Case Balance: $0.00 Next Payment Amt: Last Payment Amt: Next Pavment Due Dt: Non-Monetary Assessment Amt Adjustment Amt Pavment Amt Payment Amt Balance Assessment Tvoe 00 $8 $0.00 $0.00 ($8.00) $0.00 Judicial Computer Project . 00 $3 $0.00 $0.00 ($3.00) $0.00 ATJ ATJ . $2.25 $0.00 $0.00 ($2.25) $0.00 CJES 25 $10 $0.00 $0.00 ($10.25) $0.00 JCPS . 20 $28 ($28.20) .00 $0 $0.00 $0.00 County Court Cost (Act 204 of 1976) . 65 $7 ($7.65) $0.00 $0.00 $0.00 State Court Costs (Act 204 of 1976) . 65 $7 ($7.65) $0.00 $0.00 $0.00 Commonwealth Cost - HB627 (Act 167 of . 1992) $28 20 $0.00 $0.00 ($28.20) $0.00 County Court Cost (Act 204 of 1976) . 00 $0 $0.00 ($7.65) $0.00 State Court Costs (Act 204 of 1976) $7.65 . 00 $0 $0.00 ($7.65) $0.00 Commonwealth Cost- HB627 (Act 167 of $7.65 . 1992) Crime Victims Compensation (Act 96 of 1984) $35.00 $0.00 $0.00 00 $0 ($35.00) ($25.00) $0• $0.00 Victim Witness Service (Act 111 of 1998) $25.00 $0.00 00 $0 . $0.00 ($10.00) $0.00 Domestic Violence Compensation (Act 44 of $10.00 . 1988) $5 60 $0.00 $0.00 ($5.60) $0.00 Postage - Case . $150.00 $0.00 $0.00 ($150.00) $0• Title 18 - Payable to Municipality - ?-• a - MDJS 1200 Page 3 of 3 , ` - -- -- Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used In place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 at seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. "EXHIBIT Q" Lower Allen Twp Complaint Report Commonwealth of Pennsylvania Complaint IMorn ation Complaint Number Locked Record Follow Up LAT 0,08-01134 No N Description P IN E O Pdortty Method Racelved Status Cl d adio D eare - Day of the Week How Handled adnasdav O{f'cer Ass' ned Nature Gussler was bitten by a dog whose owner had it off a leash. Unknown who the owner is at this time. See Page 1 of 7 9/30/2011 1:55:51 PM Complainant Information Salutation First Name Doug I Middle Name Last Name lEnicle"' Suffix Date of Birth l Zite I Address 1326 Carlisle Rd Apartment City a HIll I State PA 1 ZJp Code 17011 Phone Number 1 ?re Code 7 7 Number l 19860 Ext Phone Type lWork Phone Number 2 Area Code 717 Number Ext phone Type Notify Complainant L Taker ID WAS-OWE Dispatcher ID 1 cNET Complaint #: 1186020 User Defined Feld 1 ter Defned Field 2 a User Defined Field 3 User De l Field 4 ComplainantFAssoclate Info,,. Salutation First Name LEN Middle Name I Last Name U "we Suffix Date of Birth 9 Race - Sex ICtirn V n Type dress C`J 2 WALNUT Apartment I City CAMP L I State PA 1 Zip Code 17011 Phone Number 1 Area Code Numbar l Ext Phone Type Phone Number 2 Area Code Number l Ext Phone Type User Defined Feld 1 Victim / Janitor User Defined Field 2 User Defined Field 3 User Defined Feld 4 9/30/2011 1:55:51 PM Page 2 of 7 Salutation First Name Middle Name Lest Name Suffix i O Race Sex l odetldt TYPa Date of Birth Address 1325 Carlisle Rd State ZlpCode Apartment City I 1 11 lCamg) Hill P Phone Number 1 Area Code Number Ext Phone Type 717 19999999 Home Phone Number 2 Area Code Number Ext Phone Type ld 2 fi d Fi User Defined ReId 1 e ne User De User Defined Reid 3 User Defined Field 4 Salutation First Name Middle Name , Last Name I Suffix I SNYDEII JASON Sex Association type Date of Birth Race 01/1111969 White Male S s Ct Address 41 Allendale VVY state Zip Code Apartment city I 1 I PA 17011 C=12-HIII Phone Number 1 Area Code Number Ext Phone Type I 7 17 9751 80 HOMG Phone Number 2 Area Code Number lExt Phone Type I 717 7 10 cell User r Defined Field 1 U User Defined Field 2 t SUS Field 3 User Defined User Defined Field 4 Salutation First Name Middle Name l Last Name Suffix IKathlean Anne Sex Associauon Type Date of Binh Race /1976 White Female Witness Address 1608 Letchwor th RD State zip coda Apartment City 1 . 17011 I CaMR Phone Number 1 Area Code Number Fact Phone Type I 17 17129205 Home Phone Number 2 Area Code Number Ext Phone Type User Defined Field 1 User Defined Field 2 Witness User Defined Field 4 User Defined Field 3 9/30/2011 1:55:51 PM Page 3 of 7 Salutation Name Middle Name Last Name Suffix Taron I Bur Date of Birth Race Sex Assodation Type Wh'te Female dress 311 Mancheste r Rd Apartment City State 1 Zip Code I Camy Hill I PA 17011. Phone Number 1 Area Code umber 1 ExI Phone Type 71 1 ,053682 8 j I cell Phone Number 2 Area Code Number Ed Phone Type 717 User Defined Field 1 User Defined Field 2 D Owner User Defined Field 3 User Defined Field 4 C"gers. Inv Matthew -1816 - Lower Allen DI Enroute 99 W2010 12:21:00 GYeared 0 8• 0 0 Defined Rod 1-2 9/30/2011 1:55:51 PM Page 4 of 7 Attachments - Comments 9/3012011 1:55:51 PM Page 5 of 7 liamson. Frank -1801 - Lower Allen Twp Assisting Officer 11801 I narrative by 18-16, Ofc Claeys, on 08/25110 tched to meet with the Principal of Highland Elementary School in reference to their janitor, Helen Gussler, bit by a dog. responded and met with Gussler. She informed me that a white male had about six or seven dogs, off of cashes, in the field hockey field of Highland Elementary School. She approached him to inform him that he ould not be there. When she began to approach, the dogs began to run towards her. She said that the dogs imped on her, and one bit her on the left hip. She showed me the Injury and it was a small scratch, that did not ppear to break the skin. She was wearing jeans at the time. She did not want any medical treatment for the ussler told me that she told the man that he could not be there, and he said that he was unaware that school 'as in session. Gussler then asked for his name, and he would not provide it to her. He then left the area, last 3en on foot, with the six or seven dogs, heading west on Carlisle Rd towards Lowther Rd. hief Williamson checked the area, as did I, and we were unable to locate the suspect. ussler said that she is familiar with the usual person who walks dogs in the area and stated that it was not m. She said that he usually has all different breeds with him. She said that this suspect had only two breeds F dogs, being German Shepards and possibly pit Bulls. All the dogs were adult dogs. is description of the suspect is a white male, with short hair, or bald, wearing a tan shirt and green shorts, with asses. Gussler said that he appeared to be in his. 30's. will send an e-mail out to patrol to stop any individual matching this description and identify him. by Chief Williamson 18-01 08-25-2010, 1 heard the dispatch for the dog bite at Highland Elementary School. The suspect, a w/m, white T- t and a ball cap, walking 7-8 dogs was last seen North on Commercial Dr. entered the Highland Park neighborhood on Letchworth Rd from 18th Street and commenced a search of the rea, including Chatham Playground, Highland Park, Cedar Cliff Mail, Carlisle Rd, and Cedar Cliff Manor, with no uccess. :er Claeys indicated the subject was walking what appeared to be only two breeds of dogs, German pards and Pit Bulls. The victim was also to be familiar with our normal dog walked in the area, who usually multiple breeds of dogs, and does not believe this to be the same person. upplemental by Ofc. Martinez on Thursday, August 26, 2010 this date Marilyn Broden, who works for the Cumberland County Dept. of Health, called to speak with the cer handling this call. I Informed her that Ofc. Claeys was not available and asked if there was something I ild help her with. Broden asked if we knew who the biting dogs owner was and I Informed her that we were astigating the bite but the owner had not been located yet. Broden asked if someone could call her if the ier was located so that they could also follow up with the homeowner. I informed her that I would give Ofc. eys her contact information in the event that he did find the dog owner. Broden said that she understood. 9/30/2011 1:55:51 PM Page 6 of 7 upplemental report by 18-16, Ofc Claeys, on 08/27/10 In 08126/10,1 was patrolling the area of Letchworth Rd and saw a white male walking several dogs that appeared 3 be of two different breeds. stopped and spoke with him, and he was identified as Jason Snyder. He denied being involved in the incident t Highland Park. As we finished talking with him, Kathleen Murphy came over to my patrol car and said that she iitnessed the dog bite yesterday, and Snyder was the man there with the dogs. I obtained her information and hanked her. I then reapproached Snyder and informed him of this and he said that it was him and the dog that it Gussler was "Utley". Itley is owned by Sharon Burke at 311 Manchester Rd. We went to the Burke residence and spoke with Sharon, rho provided me a copy of Utley's medical records, indicating that the dog was current on all vaccines. I made photocopy of this record gave a copy to Gussler. A copy is also attached to this report. larylin Broden, from the Department of Health, was called and provided with all this information as well. A copy if the medical record for the dog was sent to her via fax. She said that she will send a letter to Burke indicating hat the dog must be quarantined for 10 days, and she will make contact with the victim as well. will be cited for not having the dog on a leash at the time of the bite. incident report. Page 7 of 7 9/30/2011 1:55:51 PM "EXHIBIT R" Township of Lower Allen, PA § 65-6. Running at large. Page 1 of 1 Township of Lower Allen, PA Monday, October 3, 2011 [Amended 11-9-1998 by Ord. No. 98-121 No owner of any dog, cat, domesticated animal or any nondomesticated animal shall allow such dog, cat, domesticated animal or any nondomesticated animal to run at large at any time, either upon any of the streets, alleys or public grounds in the township or upon the property of another person other than the owner of such dog, cat, domesticated animal or any non- domesticated animal, and not being firmly secured by means of a collar and chain or other device so that it cannot stray or not being accompanied by or under the reasonable contact of some person. Any police officer or law enforcement officer is hereby authorized and empowered to seize and detain any dog, cat, domesticated animal or any nondomesticated animal which is found running at large in the township or upon the property other than the owner of such dog, cat, domesticated or any nondomesticated animal and unaccompanied by the owner when such police officer or law enforcement officer is in immediate pursuit of such dog, cat, domesticated animal or any nondomesticated animal. "EXHIBIT S" Magisterial District Judge 09-1-01 Elm Docket Number: MJ-091 01 -NT-0000860-201 0 Non-Traffic Docket Commonwealth of Pennsylvania V. Jason Matthew Snyder Page 1 of 2 $ Judge Assigned: Magisterial District Judge Charles A. Issue Date: 08/25/2010 Clement Jr. OTN: File Date: 08/30/2010 Arresting Agency: Lower Allen Township Police Dept Arrest Date: Citation P8426666-3 Disposition: Guilty Plea Coun : Cumberland Disposition Date: 09/07/2010 Township: Lower Allen Township Case Status: Closed F aA c q Case Status Status Date Processing Status Closed 09/27/2010 Completed 09/07/2010 Case Balance Due 09/07/2010 Case Disposed/Penalty Imposed 09/07/2010 Awaiting Sentencing 08/30/2010 Awaiting Plea Name: Snyder, Jason Matthew Sex: Male Date of Birth: 01/11/1969 Race: White Address(es): Primary Camp Hill, PA 17011 Advised of His Right to Apply for Assignment of Counsel? No Public Defender Requested by the Defendant? No Application Provided for Appointment of Public Defender? No Has the Defendant Been Fingerprinted? No 1 0?x . ;.. ",. WPM '? Partlci pant Twe Participant Name Arresting Officer Ciaeys, Matthew B Defendant Snyder, Jason Matthew ` R now # Charge Grade Description Offense Dt. Disposition 1 LO § 65 §§ 6 S Running At Large 08/25/2010 Guilty Plea 1 t Case Disposition Disposition Date Was Defendant Present? Guilty Plea 09/07/2010 Yes Offense Seg./Description Offense Disposition 1 Running At Large Guilty Plea - - - - - - - - - - --- - - - - - - - - - - - - - - - - - - - - - - MDJS 1200 Printed: 10/04/2011 9:41 am Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 at seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. Magisterial District Judge 09-1-01 Docket Number: MJ-09101-NT-0000860-2010 Non-Traffic Docket Commonwealth of Pennsylvania V. Jason Matthew Snyder Page 2 of 2 Filed Date Entry Filer Applies To 09/27/2010 Penalty Satisfied - -Magisterial District Court 09-1-01 Jason Matthew Snyder, Defendant 09/07/2010 Penalty Assessed - - - - - - -Magisterial District Court 09-1-01 _ _ Jason Matthew Snyder, Defendant _ _ 09/0712010 Guilty Plea Magisterial District Judge Charles A. Jason Matthew Snyder, Defendant -Clement Jr_ 09/01/2010 Certified Summons Accepted _ _ _ _ -Magisterial District Court 09-1-01 _ Jason Matthew Snyder, Defendant 08/31/2010 Summons Issued - - - - - - - - Magisterial District Court 09-1-01 _ _ Jason Matthew Snyder, Defendant _ 08/31/2010 Certified Summons Issued Magisterial District Court 09-1-01 Jason Matthew Snyder, Defendant 08/30/2010 Non-Traffic Citation Filed - - - - -Magisterial District Court 09-101 - Jason Matthew Snyder, Defendant Payment Plan No. Payment Plan Frea. Next Due Date Active Next Due Amt. Overdue Amt. 09101-2010-P0000944 Biweekly No $0.00 $0.00 Responsible Participant Snyder, Jason Matthew Payment Plan History: Payment Dt. Transaction Tv oe Pavor Participant Role Am unt 09/27/2010 Payment Snyder, Jason Matthew Defendant $57.60 10/23/2010 Payment Snyder, Jason Matthew Defendant $65.00 Wa Case Balance: $0.00 Next Payment Amt : Last Payment Amt: Next Payment Due Dt: Non-Monetary Assessment Type Assessment Amt Adjustment Amt Payment Amt Payment Amt Balance Judicial Computer Project $8.00 $0.00 $0.00 ($8.00) $0.00 ATJ $3.00 $0.00 $0.00 ($3.00) $0.00 CJES $2 25 $0.00 $0.00 ($2.25) $0.00 JCPS $10.25 $0.00 $0.00 ($10.25) $0.00 County Court Cost (Act 204 of 1976) $28.20 $0.00 $0.00 ($28.20) $0.00 State Court Costs (Act 204 of 1976) $7.65 $0.00 $0.00 ($7.65) $0.00 Commonwealth Cost - HB627 (Act 167 of $7.65 $0.00 $0.00 ($7.65) $0.00 1992) Postage - Case $5.60 $0.00 $0.00 ($5.60) $0.00 Local Ordinance $50.00 $0.00 $0.00 ($50.00) $0.00 MDJS 1200 Page 2 of 2 Printed: 10/0412011 9:41 am Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet Information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 at seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. "EXHIBIT T" Complaint Report Commonwealth of Pennsylvania Lower Allen Twp Corertt?liforma#ioln _ Complaint Number Locked Record Follow Up Call For Service -078 N No A p Description P COMPLAINT Status Priority Method Received Date/Time Received feared 5 R di Di h 09115/2010 11:30:00 Day of the Week How Handled Officer si ed Complaint Nature Pat Townsend reported dogs barking 417 Allendale Way. Jason Snyder, son, and Isabel Snyder, mom run a , kennel out of the residence in violation of State and Twp laws. State Dog Warden Shrawder responded and John Eb Tw codes was notified. See comments. ??u?G?'rripfainteLl`"ocafwn .. Street Number Street Block Predirection Street Name 1 Street Type Postdirection ALLENDA E PO Box Cross-Predirection Cross-Street Name CrossStreat Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number Cumberland Location Township Magisterial District ty/Town Political Subdivision wer Allen T i Ca 'I State Zone Number Zip Code Area Gdd Residence Type Unit Type 1 1-7011 1202 Unit Number Latitude Longitude Location Type Country L(N`A}1fln rben.inxnn 40,225154 -76,890966 Residence/Home United States of America (US 1417 ALLENDALE WY LA CU417ALLENDALEWYLACU I 9/30/2011 1:56:45 PM Page 1 of 7 Complainant Information Salutation First Name Middle Name Last Name Suff x I IAIU T PAT Date of Birth Race Address T 16 4 Code State Zip City rtment P pa ; P Phone Number 1 Area Code Number 1 EPhone Type I 7614425..-- 7 17 Home Phone Number 2 Axes Code Number Ext Phone Type l 717 761"25 Holpe Notify Complainant Call Taker lD Dispatcher ID cNET Complaint #: User Defined Field 1 User Defined Field 2 User Defined Field 3 User Field 4 First rN. Salutation 7 Middle Name Last Name Suffix Type ooetion Date of Birth Race hits r dress state Zip Code Apammnt aty I 1 t 9 A L emoyne PA 17043 p Phone Number1 Area Code 717 Number 9751880 Ext i Phone Type Homgt Phone Number 2 Area Code 717 Number j ExI Phone Type User Defined Field 1 ser Defk>ed field 2 User B EL 3 User Defined Field 4 9/30/2011 1:56:45 PM Page 2 of 7 Salutation 7 t Name IN7 hne Middle Name Last Name Suffix Shrawder Date of Binh Raceite Sex IFemale lAssociation Type Address 2301 N Cameron t Apartment Room 102 City arr's ur State PA Zip Code 1 110 Phone Number 1 Area Code 717 Number 15641680 Ext Phone Type Work Phone Number 2 Area Code 717 Number 1 Ext Phone Type User Defined Field 1 tate Do rd en User Defined Field 2 User Defined Field 3 User Defined Field 4 Salutati on T FIrst Name Isabel Middle Name Last Name Suffix Date of Birth Racei e Fe Saxm le Association Type Address 417 Allendale a Apartment City State Zip Code 1 1 Phone Number 1 Area Code 1 Number 7 61014 EM Phone Type o e Number 2 de N E77 umber E xt P hone Type fined Field 1 O U ser Defined Field 2 User Defined Field 3 User Defined Field 4 9130/2011 1:56:45 PM Page 3 of 7 Officers Involi John - 1823 - Lower Dispatched Enroute 09/1512010 12:07:00 Arrived Cleared 0911§010 12:07:00 W 10 12:59:00 UWr= Maio rc Officer Name Role Resource # Cypress, John -1854 -Lower Allen Tw ssistin Officer 1854 Street Number Street Block Predrection Street Name Street Type Postdirectlon Po Box Crass-Predirection Cross-StreetName ros"treetType T Highway Name Highway Number Highway Milepost Rural Route County CuEllberland - Jurisdiction Number Magisteft Dish" Cityfrown Polidcai Subdivision Location Township State Zone Number Zip Code Area Clod ReaidenceType Unit Type Unit Number Latitude Longitude Location Type Country 0 00 0 00 United §MW America of Location Description . . Dispatched 2010 11 :44:00 Enroute RLM 11 :44:00 09/15/2010 1 2;59:00 User Fiefd1_2 eid2 User Defined Reld 3 User De Med Field 4 9/30/2011 1:56:45 PM Page 4 of 7 Officer Name Role Resource # Gelnett, Thomas -1811 - Lower Allen Tw Re porting Officer 1811 I rv-nfinn Ili-fnk_A Street Number Street Block Predirectlon Street Name Street Type Postdirection PO Box Cross-Predirection Cross-Street Name CrossStreet Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number umbedan d Location Township Magisterial District City/Town Political Subdivision State Zone Number Zip Code Area Grid Residence Type Unit Type P Unit Number Latitude Longitude Location Type Country 0 __00 00 I United States of America A Location Description - 417 LL ND E C 0 Dispatched Psroute Arrived Cleared '911512010 1 1: •00 0 15/2 1 12:69:00 User Defined Field 1-2 User Defined Field 2 User Defined Field 3 User Defined Field 4 Comments 9/30/2011 1:56:45 PM Page 5 of 7 report by Officer Gelnett on 9-15-10. was dispatched to 417 Allendale Way for dogs barking. County advised the caller stated this is a constant roblem. I responded with CSO Cypress. Upon arrival I could hear a dog barking in the rear yard. There were o cars in the driveway. I rang the doorbell and knocked on the door but no one answered. 1 was able to bserve three brown boxers and a black german shepard inside the residence. There was water visible in the itchen in bowls on the floor. The dog in the back yard was a tan boxer mix that had a bowl but I could not see if here was any water in it. The mailbox was full of mail and the two front doors to the residence where iMocked. The back door, inside the fenced in area where the dog was, was open however the screen door was but so the dogs could not get outside and the dog outside could not get inside. There was also no car in the Cypress left a ordinance in the mailbox for dogs barking and disturbing the neighbors. attempted numerous times to get someone to answer the door by ringing the doorbell and knocking on the loors. This just upset the dogs more and they barked constantly and ran back and forth between the two front loors. I observed a two page cease and desist order posted on the door from the Bureau of Dog Law °nforcement on 7-13-10 stating that Jason Snyder was in violation of the kennel law and was demanded to cease nd desist operating a kennel, etc. called John Eby, Lower Allen Township Codes, and asked what his knowledge of the residence was. He nformed me that Isabel Snyder, the owner of the residence, was an elderly female and her son, Jason Snyder, roused the dogs at her residence. He actually lives on Columbus Ave. The Township has been working with neighbors in trying to resolve the dog issues and the State Dog Law Officer has been involved. Eby stated that ason is only permitted to have four dogs on the property and those are the dogs that he and his mom own, hree boxers and a german shepard. If there are any other dogs on the property then he is In vollation of the ennel laws and is subject to civil and criminal prosecution. I was asked to document my observations and orward a copy of the complaint to Codes. I was also asked to take pictures of the dogs and conditions. :by also informed me that Isabel was an elderly woman and Jason was to be her caregiver, either staying at or oming to the residence frequently to take care of Isabel. There was some concern about whether she was ome or not and if she was okay. also called the State Dog Warden from the number posted on the notice and left a message for one of them to give me a call. Officer DeSantis was requested to come to the scene to assist if we needed to go inside the esidence or if Jason arrived. ile talking to Eby a neighbor came over and advised he had seen Isabel yesterday. She had brought some rs over to his house. The neighbor, who lived to the right of Isabel's house, stated that she is hard of hearing she may not hear the door if she has her hearing aids out. He has not seen her today but she does have a that Is usually in the garage. We looked in the windows of the garage again and there was no car de. This made me feel confident that Isabel was more than likely not at home. atahnee Shrawder, State Dog Warden, called me and informed me that she is familiar with the residence and ason. She also confirmed that there area only too be Jason and Isabel's four dogs at the residence. Any more ian those four dogs would be a violation. Shrawder stated she was about ten minutes away and would respond > document the additional dog(s) and see what violations where present. She requested we remain at the :sidence until she arrived and documented conditions. hrawder arrived and shortly afterwards Jason drove in the driveway with a black and white dog in the car. He )moved this dog from the car and was walking It on a leash on the property when I approached him. At this oint there were three police cars and the State Dog Warden vehicle in front of the residence. Jason asked what as going on and I informed him that someone called about the dog In the back yard barking and disturbing ism in violation of the Township ordinance. He stated his mom must have left without letting this dog back in ie house. was told that he was also in violation of operating a kennel, and the notice posted on the door, which he 9/30/2011 1:56:45 PM Page 6 of 7 e his and Isabel's four dogs. Jason stated he was trying to stop but could not completely shut down his riess. Jason stated the tan boxer mix in the back yard was his. He also stated the two brown boxers and the german shepard were his. The one brown boxer inside was Maggie, a clients dog. The terrier mix, , he brought in the car with him was also a clients. Shrawder requested the owners information. Jason d he would call her with this. of the dogs had visible license displayed on their collars. Jason stated that they all had their shots and properly licensed. Shrawder was able to verify for me that Jason's four dogs had all their license and Shrawder will follow up with the owners of the two other dogs to verify license and shot records. rder photographed the two dogs that where not permitted on the property for her case. on stated several times that he was trying to limit the number of dogs and comply with the law. I told him h time that he needed to comply with the law and not just try. I used the example of someone who did not re a drivers license but continued to drive and tried to use the excuse that the were trying to comply with the . It was still a violation. informed Jason that he was in violation of the kennel law and the township ordinance for loud and disturbing arking. Shrawder also advised him if any dog was outside for more than an hour it would need to be provided halter. Shrawder also advised Jason if any dog was off the property of the owner that it would need to be isplaying a license. Jason stated he understood. advised Jason that he would probably be receiving several charges for the above violations. Jason was told he eeded to remove the two dogs, that where not his or his moms, from the property immediately. Jason said he hrawder will coordinate with me and Eby in filing charges. I e-mailed a copy of this report to Shrawder and 9/30/2011 1:56:46 PM Page 7 of 7 "EXHIBIT U" Complaint Report Commonwealth of Pennsylvania Lower Allen Twp Co,?{aintlnformatlinrc Complaint Number Locked Record Follow Up Call For Service LAT2011-05-00388 ]No I No I PORDVI Description VIOL ODINANCE Priority Method Received t Da e?me Received Cleared 7F 4 R io Disoatch Day of the Weak How Handled Monday ffic r Assigned Complaint Nature Jason Snyder, dog behaviorist, left 11 dogs he was walking break loose and attack another dog. Another resident who assisted got bit by one of the doas. Snvder citad- C86 Wnt L:o ation Street Number Street Block Predirection Street Name I Street Type Postdirection IWANQHEU 9 PO Box Cr oss-Predirection Cross-Street Name ? ssStreet Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number Cumberland Location Township Magisterial District Clty/Town Political Subdivision or Allen o -1-01 Ca Hill State Zone Number Zlp Code k; Grid Residence Type Unit Type P 1 17011 203 UMt Number Latitude Longitude 1 Location Type Country 40.231778 1-76.896601 111ahway/Roa d/Alley United Stat es of America U Location Description 1310 MANCHESTER LA CU310MANCHESTER RDLACU 9/30/2011 1:58:29 PM Page 1 of 6 Compla1nant;Information Salutation First Name Middle Name l Last Name Suffix 7 Kvle Knine Date of Birth Race r Whi e Ma-Le-- Address 310 MANCHEST911 RD city State ZIP Coda Apartment P L PA 1 11 T Phone Number 1 Area Code 1 Number Ext l Phone Type 717 7637349 Home Phone Number 2 Area Code Number F)d Phone Type l 717 Home Notify Complainant No Can Taker ID QIWIZEIG cNET Dispatcher ID 2 Complaint #: 99271 F User Defined Feld 1 . Defined Feld 2 User Defined Field 3 User " ned Feld 4 C° ° SSocate i , Informat on Salutation First Name JASON Middle Name -I Last Name SKYDE Suffix Date of Birth Race Sex Assodation Type 01111/1969 Address 417 Allendale WY State Zip Code Apartment City Camp H' PA 17011 Phone Number 1 - Area Code Number J T E,,t Phone Type 717 Phone Number 2 Area Code Number J E,,1 Phone Type 7 17 1 7619574 User Defined Field 1 User Defined Field 2 User Defined Field 3 User Defined Feld 4 9/30/2011 1:58:29 PM Page 2 of 6 Salutation First Name Middle Name Last Name Suffix C Jane Kni Date of Birth e Z Sex sociation Type 5 0 1 1 hIte Female im y 1 Add ress 31 Mancheste r D Apartment City - State Zip Code Cam Hill 1 2A 1 17011 Phone Number 1 Area Code Number 1 T- - Phone Type 717 7637349 l Home Phone Number 2 Area Code Number Fitt Phone Type User Defined Field 1 User Defined Field 2 victim User Defined Field 3 User Defined Field 4 Salutation 77 First Name Middle Name Last Name Suffix - haron IBurke Date of Birth Race T sso ciation Type White E ale Address 31 nc a ter R artment Ciry State Zip Code i I PA 17 Phone Number 1 Area Code Mber EM Phone Type 71 82 Cell Phone Number 2 Area Code N umber E xt Phone Type .717 User Defined Field 1 User Defined Field 2 r dog 2 User Defined Field 3 User Defined Field 4 9/30/2011 1:58:29 PM Page 3 of 6 Salutation -] First Name Middle Name I Last Name Ban Suffix Date of Birth Race Sex Association Type Address n State Zp Code Apartment City A Phone Number 1 Area Code Number JEd Phone Type 717 7 8 Work Phone Number 2 Area Code Number I lExt Phone Type 717 User Defined Field 1 User Defined Field 2 V User Defined Field 3 User Defined Field 4 qoalQ Street iumtief Street Block Predirection at Name Street Type Postdrection PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Juns"onNumber Locaton Township anal OTMW ty/Town PolWCalStWNsbn State Zone Number Zip Code Area Grid Residence Type Unit Type Unit Number Latitude 0 00 Longitude 0 00 Location Type Country Unftd S18121 Of -Amedca WIN Location DesodpUon MANCH 31 . TER RDIA . 9 Disp etl to 1 O Arrived 08 :58:00 Cleared O§JQ"11 0 9:43:00 User Defined Field 1-2 User Defined Field 2 User Defined Field 3 User Defined Field 4 9/30/2011 1:58:29 PM Page 4 of 6 Officer Name Role Resource # Poltz, Douglas -1809 - Lower Allen Tw Assistin Officer 1809 I nratinn Ilicnnfncarl Street Number Street Block Predirecdon Street Name Street Type Postdirection PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Cumberlan d Jurisdiction Number Logtion Township Magisterial District City/Town Political Subdivision State M Zone Number Zip Code Area Grid Residence Type Unit Type umber Number Location Description 310 MANCHE Latitude 0.00 -WER RD JA L gitude .00 31 OMANC Location Type HESTERRD LACI United Country of America SA Dispatched Enroute Arrived 98 :59:00 Cleared 0 011 9.43.00 User Defined Feld 7 2 User Defined Field 2 User Defined Feld 3 User Defined Field 4 Comments 9/3012011 1:58:29 PM Page 5 of 6 ginai report by Officer Gelnett on 5-9-11. shley Nelson was walking her dog on the even house number side of Manchester Rd on the sidewalk. Jason cyder, Dog Behaviorist, was walking his pack of 9 dogs across the street and was in the process of picking up more dogs at 311 Manchester Rd. According to Snyder one of the dogs slipped its collar and ran across the rest toward Nelson and her dog. The rest of the dogs did likewise. Snyder lost control of all the dogs and athy Knipe, a resident at 310 Manchester Rd, helped by catching one of the smaller dogs. She returned this )g to Snyder and got bit by one of the German Shephards that Snyder had gained partial control ier. Nelson's dog was knocked down numerous times and attacked by at least 6 of the dogs Snyder had been alking. Nelson was also knocked down in her attempt to get the dogs away from her dog. elson and her 10 year old Husky were shaken up but did not appear injured. Nelson's dog did have wet ruffled r all over were the other dogs had attacked him. Nelson was going to take her dog home and look him over ,o see if he was injured then decide if she was going to take him to the vet or not. Bison stated she has had problems with Snyder in the past as he walks apack of dogs past her house and also cks a dog up at her neighbors house at times. Snyder has verbally attacked her before, his dogs have 3fecated on her property, and they have run loose on her property going after her dog. Nelson stays away from m and his dogs every time she sees him. nips was certain the dog that bit her was one of the German Shephards that belong to her neighbor. Snyder ated it was Utley and showed me the dog and the rabies tag from 2010. Snyder did not know if this was up to its but gave Cpl Foltz the phone number to the owner, Sharon Burke. Cpl Foltz called and left a message for :r to contact us back. She did so in a short time and provided a phone number for her vet to verify the shot cord. I called and later verified this with Bansfield. Both Utley and Jetter, the other German Shephard, are up date on their rabies shots. I notified Nelson and Knipe of this. also had contacted the State Dog Law Office and had an officer call me while 1 was dealing with Snyder. They o not have any restriction on Snyder's dog walking but are familiar with him. ,nips stated she was fine and was not going to the doctor. She was contacted by the dog owner and assured nat any doctor bills would be taken care of. lelson state, when I called her back, that she was going to take her dog to the vet later to make sure it was kay. I asked her to get me a copy of the bill and I would make sure she was reimbursed. She witi do that. 9/30/2011 1:58:29 PM Page 6 of 6 "EXHIBIT V " COMMONWEALTH OF PENNSYLVAMt, • CITATION NO . NON-TRAFFIC CITATION y 18 5 813 6 9- 6 +. ?,.pwerroeM,viu.w 09-1-01 Pear aeaoa ?veY wedMr - J- 1 4 ?l '? 8 0 4 400 $ a _ ca m 11 In7n (717. a5'a34a7 PKPA ?. A.s? 4Sa,.. YVIA 5' 1'%4 r Ile11file- LADE Car.-? N t i'A izo i . ? ° ar ino,w? B, Hj ? d star I ? N Ovelle,ulcae a drv,WAne6, pWa D 1W Q f d"m M ? Female ?? , wean ? llnleiown f?7 GeMon&senwe ,ehiaWwer C) Yes O Yes v ar,ever w T" n ouy 11 IN-," Comd-t MAIROurl" O ? Cdna,d Ymepese ? ,hen a servlres n criminal Mlsdde } d P,d* ommm w m n Scattering RW" d Plaid Theft \ ba ` `S Purr? a Consur Phan Fbassalon or Tren of a Men Or Brewed Sevanges Ottrx vv?n NOaer o. o. ?_... _ _. "EXHIBIT W " Complaint Report Commonwealth of Pennsylvania Lower Allen Twp Comp! nt,lnfo,mation; Complaint Number Locked Record Follow Up Call For Service 1 9 37 No No I PORDVI Description RDINANCE VIOL Status Priority Method Received DaWTime Received CI are 4 Rai h 109/09/201112:46:00 Day of the Week How Handled r l er Ass i aned ompiaint Nature Doug Davis reported that his daughter Dana Davis was bitten by a dog that was being cared for by Jason [Snyder. The do is owned by John Burke. IC and Citations to follow ComptaintiL©cati6h Street Number Street Block Predirection Street Name Street Type Postdirection pi LE ; Cross-Predirectlon Cross-Street Name ross Street Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number C rl d Location Township Magisterial District City/rown Political Subdivision ow Allen T shio 0 -1-01 Hill State Zone Number Zip Code Area Grid Residence Type Unit Type 7011 12 2 Unit Number Latitude Longitude Location Type Country 40.2 5154 -76.89 966 1 0ther/Unknown United of A U e ic Location Description m r a 417 ALLENDALE WY,LA CU417ALLENDALEWYLACU 9/30/20112:00:14 PM Page 1 of 5 Complainant Information First Name Salutation Middle Name Last Name SUM/ I ? DOUG D"IS Date of Birth Race sex Address 417 Bladdatch Ln Zip Code State Apartment III I 7 PA 1 C aMI) one Number 1 Ph -- Area Code 717 1 Number 5030228 j ExI l Phone Type Home Phone Number2 ea Code Number E t Phone Type 717 ork Notify Complainant Call aker ID Dispatcher ID MET Complaint #: User Defined Field 1 User Defined Field 2 User Defined Field 3 eid 4 Qt? n Salutation I RM Name Middle Name Last Name ason Race s? Association Type Date of Birth Male dress l WY e Allenda 417 rate Zip Code rrtment Apa I City Caimp Hil l rp Phone Number 1 a Code Number Ext Phone Type 1 Phone Number2 Area Code Number lExt Phone Type User Defined Field 1 SUSDeCt' User Defined Field 2 User Defined Field 3 User Defined Field 4 9/30/2011 2:00:14 PM Page 2 of 5 Salutation First Name ISHARON Middle Name Last Name Suffix Date of Birth 011s 1 Addres 1 MANCHES ER Race hi TE x al e sociation Type Pr a O wner Apartment city AMP ILL state IPA Zip Code 117011 Phone Number 1 Area Code 7 7 Number -4307 Fed Phone Type Home Phone Number 2 a Code 7 Number 1805-3682 lExt Phone Type lHorne User Defined Field 1 D Owner User Defined Field 2 User Defined Field 3 User Defined Field 4 S l ti a uta on T Rrst Name na Middle Name Last Name D vi Suffix Date of Birth 1125/1989 7 Zhite Se x F ample ciation Type ?Ictlrn Address 417 Blacklatch N Apartment City m Hill State P Zip Code 17011 Phone Number 1 Area Code 1 Number 10 5 Ext l Phone Type Horne Phone Number 2 Area Code Number E xt Phone Type User Defined Field 1 ctim User Defined Feld 2 User Defined Feld 3 User Defined Feld 4 Officers Involved 9/30/20112:00:14 PM Page 3 of 5 Joshua -1894 - Lower Allen Twp lAssisting Officer Street Number Street Block Predirection Street Name Street Type Postdirection PO Box Cross-Predirection Cross-Street Name j Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number Location Township MagWedal DI ct Citylrown Political Subdivision State Zone Number Zip Code Area Grid Residence Type Unit Type PA I Unit Number Latitude Longitude Location Type Country 0.00 0 united Location Description Dispatched Enroute 9912011 12 :49:00 A Cleared QW 1 R User Ield1-2 ps2 user eld2 User Defined Field 3 User Defined Field 4 Role Resource k Officer Name ISpauiding, Justin -1810 - Lower Allen Tw lReporfing Officer 11810 Street Number Street Block Predirection Street Name Street Type Postdirection 417 ALLENDALE PO Box Cross-Predirection Cross-Street Name Crosststreet Type Highway Name Highway Number Highway Milepost Rural Route County QIMWan Jurisdiction Number Location Township Magisw strict Cityrrown Political Subdivison L AJ19 og-i-cli Camp Hill ower State Zone Number Zip Code Area Grid Residence Type Unit Type PA 1 17011 1 1202 Unit Number Latitude 40 225154 Longitude -76.89M6 1 Location Type 0111GE/UnknO Wn -- Country United States of AmKiCa (USA) Location Description , Dispatched Enroute 0910912011 12:49:00 Arrived Cleared S11 1 3:19:00 User Field 1-2 2 User User Defined Field 3 User Defined Field 4 9/30/2011 2:00:14 PM Page 4 of 5 Related Incidents Incident Number DateRme Started Location Status LAT2010-08-01134 108125/2010 12.16.00 1112-9i r nrliclo Pn cUM DA 117n44 it'll-,.A Incident Number Date/Time Started Location Status LAT 1 -00 8 105/091201108:54:00 MAN ER D C Hill PA 17011 lClosed Comments /21111 by 1844 @ 1430hrs; DANA and TERRY DAVIS came into the station and requested a copy of this mplaint. The complaint was provided to them minus the CAD and narative, which they were made aware of. Ina question the address for JASON SNYDER, indicating that is his mother's residence and not his. "He lives Lemoyne." Dana stated. I checked with Lt Thomas about the incorrect address and he indicated that would ve no bearing since we have multiple addresses for SNYDER. TERRY also indicated that the report needed to fixed because multiple dogs came at Dana and not just one as the report inidcated. I mentioned this to Lt 9/30/2011 2:00:14 PM Page 5 of 5 "EXHIBIT X 11 Complaint Report L ComplaintlOorMation y Commonwealth of Pennsylvania Lower Allen Twp Complaint Number 011-09-01327 Locked Record INo I Follow Up No I Call For Service PTREJO Description T P 1 T OC Status Pdodty Method Received Date?me Received lOfficer Initiated /0 1 13: 0 Day of the Week How Handled Officer Assi gned iplamt Nature son Snyder did enter a private residence without being invited, without knocking or announcing his presence, Complaint Location Street Number Street Block Predirection Street Name Street Type 3iddirecGon IAIIendaie r PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number d Location Township Magisterial District City/Town Political Subdivision er Allen T -1-01 Hill State Zone Number Zip Code Area Gdd Residence Type Unit Type 17011 1202 Unit Number Latitude Longitude Location Type Country l Residence/Home U i d States of America SA Location Description 9/30120112:01:10 PM Page 1 of 7 Complainant Information irst Name Salutation 7 Middle Name l Last Name Suffix .Joan Marie Kling or sex Date of Birth Race l Female Whbe 12/15/1947 Address 418 Allendale WY State Zp Code Apartment Hill Camo T 17011 Phone Number 1 Area Code 71 Number Ext Phone Type Phone Number 2 Area Code Number . Ext Phone Type Home Notify Complainant Cell Taker ID Dispatcher ID cNET Complaint #: User Defined Reid 1 User Defined Reid 2 User Defined Reid 3 User ` ned Field 4 Com la n! , sssoi a i pion " Salutation First Name Middle Name Last Name Sttifix e Date of Birth Race odalon Typ-T Male SUIRW 01111/1969 Address l l WY 417 Al enda e State ZJP Code Apartment I J T cam??iil PA 17011 Phone Number 1 EM Phone Type Area Code Number 1 975-1880 Home 717 Phone Number 2 Area Code Number l Ext Phone Type User Defined Feld 1 User Defined Feld 2 susRect User Defined Feld 3 User Defined Field 4 9/30/2011 2:01:10 PM Page 2 of 7 Salutation First Name Dana Middle Name Last Name Suffix Date of Birth 19 9 Race to Sexm I F ssiation Type rwoness Address 1 Blacklatch LN Apartment City iCami) Hill State PA Zip Code 117011 Phone Number 1 rea Code 717 Number 17610557 JEI Phone Type Home Phone Number 2 Area Code Number jExt Phone Type User Defined Field 1 W e User Defined Feld 2 User DefinedField 3 User Defined Field 4 Salutation Frst Name Rona Ronald I Middle Name F. I Last Name Nev Suffix III Date of Birth 03/2311990 Race ite FMale Association Type i n s Address 407 1 c tch LN Apartment 7l City Camn Hill State PA 1 Zip Code 17011 . Phone Number 1 Area Code 11 717 3038871 umber EM Phone Type Cell Phone Number2 Area Code Number Ext Phone Type User Defined Field 1 1 User Defined Reid 2 User Defined Field 3 User Defined Field 4 9/30/20112:01:10 PM Page 3 of 7 Officers Involved Donald -1808 - Lower Dispatched Enroute 09127/2011 15' Arrived cleared 09/2712011 15:00:00 Al 121:30:00 Field w i„-,...-"**-, - 9/30/2011 2:01:10 PM Page 4 of 7 Detective Corporal Sentman 1808 28 September 2011 )n this date, the following will be documented for this case was assigned a case, LAT2011-09-00372, by Chief Williamson on Tuesday 27 September 2011. 1 was told that he summary citation that was filed by Officer Spaulding was to be withdrawn to make way for a criminal irosecution of the dog handler for his actions that caused the injury to the victim. was given a copy of the case and told to follow up accordingly. met with the victim Dana Davis at her home with her parents. I spoke to her about this case. Dana advised the )flowing. Cana was walking on the sidewalk on Allendale Way from the entrance of the development toward the middle of ie development. She was walking with her friend Ronald F. Ney III (Ronnie) to his mother's home on Blackiatch ane. The two had just been running at Cedar Cliff High School and were walking home after their work out. Jana reported that she noted the garage door on the home at 417 Allendale Way started to open. Dana then oticed that four dogs were charging out of the garage and they did not stop at the end of the driveway. The lead dog" was a German Shepard named "Utley." Dana stated that she heard the man who came to collect the og, known to her as Jason, yelling that name at the dog during this incident. Dana stated she saw other dogs .inning, (believed to be four (4) total dogs in the pack), but only remembers seeing a white Bulldog for certain rith the Shepard. The other two dogs did not stand out and she did not pay any attention to them once the Berman Shepard got to her on the other side of the street. stated she froze in her tracks and turned her back to the dog. Dana stated she remembered the dog not ng or making a sound. His eyes were focused on her until she turned around and the other dogs in the were growling and barking as they ran. a stated she felt pain in her upper leg and noted that the dog was bitting and holding on to her upper The dog began to shake his head and did not let go of the bite. She felt pain with the bite and tamed. The dog released his bite and then bit her again. The dog bit both legs and continued to bite until he yelled at by Jason who had arrived on the opposite side of the street and grabbed the dog. Dana was frozen pain and fear. She stated that a resident at 418 Allendale Way, (home in front of which the bite took place), e out and collected her and took her inside her home. Dana stated that the female's name was Joan and that told Dana she would need to seek medical attention for the bites. Dana was handed a bottle of water by n. Dana did ask Joan to call her father. son then entered the home without knocking or announcing his presense. He opened the screen door but did t have to open the inside door as it was ajar after Dana entered. Jason was carrying one of the dogs, (the glish Bulldog), as he entered the home. Joan told Jason to leave. Joan has a dog and did not want any dogs ,ociated with Jason inside her home, (or Jason at that time), and communicated that to him directly. Jason agedly ignored her and stated, "it's ok." He then walked further into the home and tried to speak to Dana. He go of the bulldog at this point and the dog was running about Joan's home. Joan had grabbed her dog and handed that Jason leave with his dog. Jason continued to try to speak to Dana. Dana stated she was still Ihtened and upset by the experience and did not want to speak to Jason. continued to demand for Jason to leave. Dana reported that Joan stated, "get the hell outl" to Jason. )n did not leave when told. Jason continued to stand in the home and Joan continued to tell him to :. Eventually, Jason collected the bulldog from the home and then opened the door and put the dog ide. The dog was never on a leash during this time. The dog was running freely outside the home when it placed outside by Jason. continued to try to speak to Dana. Joan continued to tell Jason to leave, (Dana recalled no less than four Jason was told to leave and he ignored that request), and also asked Dana for her phone number so she call Dana's father. Jason asked if he could have the number as well and then he handed Dana a business 9/30/20112:01:10 PM Page 5 of 7 This card was presented to Dana by Jason. Jason was then given Dana's name and phone number. Joan Dana's father and Jason eventually left the home. remained with Joan until her father arrived. Dana stated that the police were then called and so were aencv Medical Services. lana stated that she was checked by Emergency Medical Services and eventually went home. Dana stated she vas in pain and eventually went to see a doctor for this bite. She also reported getting a few prescriptions for he bite as well as being taken to the Emergency Room (Holy Spirit Hospital), for these injuries. lana presented me with photos that had been taken by her aunt of her injury. Dana stated she provided a vritten statement to Officer Spaulding of these events. She indicated she would be able to print me out a copy f her statement. She then asked if 1 wanted her to call her friend Ronnie to have him come over for an terview. I advised that would be great and asked if she could have him respond to her home. Vhile waiting for Ronnie, Dana informed me that she did not want to have the gifts that Jason had dropped off at er home the day of the event. Dana stated her younger brother had observed Jason at the front door the night his incident took place. Jason dropped of a gift of body wash and bath related items. He also dropped off owers and some hand soap. Dana also stated that she received a $100.00 gift card/ debit card from the dog owner. Dana stated she did not want either of these gifts. observed the gifts and asked what her plans for them would be. I was told that the attorney for the family ranted to retain them. I advised her that If her attorney requested them, she should follow the attorney's istructions. 1 told her I had seen them and would document that Jason was seen dropping of the gifts of owers and the bath items. I also advised her I would document the gift card/credit card gift from the dog €e arrived and I spoke with him. Ronnie presented the same account as was reported by Dana. Ronnie i he did try to "clap" and scare or get the dog to release. The dog did not respond to his clapping. ie stated the dog did not let go of Dana until Jason came over and yelled at the dog. Ronnie was also ant when Jason entered the home on Allendale Way without knocking or announcing. Ronnie confirmed Dana had reported and stated that he was not invited or welcome in the home. Lonnie advised he had presented a written account to Officer Spaulding and that should be available as it was ilcked up by an officer. thanked Ronnie and Dana for their time and answered any questions they had. I then cleared their home and Irove to Joan's home on Allendale Way. spoke to Joan. Joan stated she heard Dana yelling and came out to see if she could help. Joan's statement ras that she did not see the attack but saw Dana after it was over and tried to convince her that EMS needed to 3spond and that she should go to the hospital. Joan also stated that she did speak to Jason when he barged ito her home and did ask that he leave. Joan stated that she was upset at the dog being in her home without a rash, the fact that Jason had barged Into the home without knocking, and the fact that the dog was not 3strained in any way despite the previous incident. Joan did not know If the dog inside her home was the ttack dog or not and she did not want anyone else to get bitten. oan was willing to testify at trial if needed. Joan stated she would work on a written statement for me for this advised all parties that I would contact them once a decision was made on this case. 3w incident report to be created from this case, (document the trespass), and various charges will be filed for is case as well as that case. did instruct the victim Dana to send a letter to Jason of "not contact or trespass." 9/30/2011 2:01:10 PM Page 6 of 7 of the injury taken by Dana's aunt were scanned and attached to this report. 9/30/2011 2:01:10 PM Page 7 of 7 "EXHIBIT Y " Complaint Report Commonwealth of Pennsylvania Lower Allen Twp ,66hiplaint,Information Complaint Number Locked Record Follow Up Call For Service -0 5 No No P N P Description ' NIMAL COMPLAINT Status Priority Method Received Date/Time Received di 0 /1 11 12:15:00 Day of the Week How Handled ursday Officer A i n d Complaint Nature Elizabeth Shank reported a dog fight in the rear yard of 417 Allendale Way. I checked the area and spoke with Shank. I was advised that there was seven dogs in the rear yard and Isabell Snyder took them inside. While speaking with Shank Jason Snyder showed up with three more dogs. I gave Shank my card, she will send me an e-mail. compiaintL`ocation Street Number 17 Street Block Predirection Street Name IALLENDAL Street Type --- 7 inaction PO Box Cross-Predirection Cross Street Name Cross Strnet Type Highway Name Highway Number Highway Milepost Rural Route County Cumberland Jurisdiction Number Location Township T Magisterial District City/rown am Hi Political Subdivision State Zone Number iPA 1 Zip Code 17011 Area Grid 1202 Residence Type Unit Type Unit Number Latitude 40,225154 Longitude -7 Location Type Country Location Description 1 N A LA 417AL NDA EWYLACU 9/30/2011 2:02:07 PM Page 1 of 4 Complainant; Information Salutation First Name Middle Name Last Name Suffix I t TH EL Date of Birth Race Sex Address 415 ALL Code State r Apartment I71011 Hill P E Phone Number 1 Area Code Number Ext 1 l Phone Type 717 1 9752722 Home Phone Number 2 Area Code Number Ext l Phone Type 717 Work Notify Complainant Ca117aker ID Dispatcher ID .1 NET Complaint #: 11361947 User Defined Field 1 User Defined Feld 2 User Defined Field 3 User 4 9/30/2011 2:02:07 PM Page 2 of 4 Complainant Associate ""?Inforrnatian Salutation Frst Name I ' Middle Name Last Name Suffix A B IS E ISNYDER Date of Birth 1 Race Sex saciation Type 02117/1928 White Own er Address 417 ALE WY Apartment Crty State Zip Code MP HI I PA 1 17011 Phone Number 1 rea Code umber T Ext Phone Type 717 761-0574 ]Home Phone Number 2 Area Code Number Fxt Phone Type User Defined Field 1 User Defined Field 2 Owner User Defined Field 3 User Defined Feld 4 Salutation First Name Middle Name Last Name Suffix Jason IlWatthe w ISnvder Date of Birth Race I -" 7 Association Type R 1 11969 White, 1 Male susRect re ss 1417 Allendale WY Apartment City State Zip Code Cam Hill I PA 1 17011 Phone Number 1 Area Code 1 Number Ext Phone Type 717 975-1880 I Home Phone Number 2 Area Code Number J EM Phone Type User Defined Field 1 User Defined Field 2 User Defined Feld 3 User Defined Field 4 9/30/20112:02:07 PM Page 3 of 4 Officers Involved 9/3012011 2:02:07 PM Page 4 of 4 fev. Donald -1822 - Lower Allen_Twp 11822 t "EXHIBIT Z 11 Complaint Report Commonwealth of Pennsylvania Lower Allen Twp Com_ ¢Iaint'Information Complaint Number Locked Record Follow Up Call For Service 07 3 No INo p p Description NT Status Priority Method Received DateMme Received Cleared 14 T Dispatch 0 09118/2011 10:57• Day of the Week How Handled Sunday Phone Complaint Nature Terrie Davis reported that Jason Snyder was walking 8 dogs and was advised by Lt. Thomas to call. I advised Davis that Snyder may walk as many dogs as he wants. I explained the codes violations and the Animal viloations to her. I still advised her to call if she sees Snvder brinaino the dens hnma_ . 'Gomplatnty.Location•-; Street Number Street Block Predirection Street Name Street Type Postdirection 1 ILOWVTHER D PC Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Cumberia Jurisdiction Number Location Township Magisterial District CltyITown Political Subdivision w Allen o Hill State Zone Number Zip Code Area Grid Residence Type Unit Type A 1 17011 1203 Unit Number Latitude Longitude 1 Location Type Country 40.23 479 -76.896124 1jighwayffload/ Alley of Americ Location Description 1195 HER RD,LA U119SLOWTHERRDLACU 9130/20112:03:07 PM Page 1 of 3 Complainant Information Salutation First Name Middle Name Last Name Suffix T R IE Date of Birth Race Sex Address 417 Btacklatch Ln ty Apartment tate Zip Code r •I Tama r Phone Number 1 Area Code Number l Ext l Phone Type 717 1 805-7394 Home Phone Number 2 Area Code 717 Number Ext l Phone Type Work Notify Complainant q Taker ID Dispatcher ID R cNET Complaint #: User Defined Field 1 .-D fined Field 2 User Defined Fleur 3 User Feld 4 Salutation rst Name Middle Name Last Name Sufiix Cason Date of Birth 01111/1969 Race :YPS L 3;; We rSUSD t Address 417 Allendale WY 417 ent ity State cwda •I 9 Phone Number1 Area Code Number Ext Phone Type l 7 7 Horne Phone Number 2 Area Coda Number J EA Phone Type User Defined Field 1 su W User Defined Plaid 2 la User Field 3 DWdid User Defined Field 4 9/30/2011 2:03:07 PM Page 2 of 3 Officers Involved Justin -1810 - Lower Allen Twp Reporting Officer 11810 i nratinn nianntrhurl Street Number Street Block Predirectlon Street Name Street Type Postdtrecbon PO Box Cross-Predirectlon Cross-Street Name fross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number Cumberland Location Township Magisterial District City/Town Political Subdivislon State Zone Number Zip Code Area Grid Residence Type Unit Type Unit Number Latitude Longitude Location Type Country .00 0. 0 United es of America U Location Description 1195 HE HDIA CU1 95 OWTHERR C 0 Dispatched Enroute 09/18/2011 11:00:00 Arrived Cleared 09/1812011 11:05:00 0911812011 11 :25:00 User Defined Field 1-2 User Defined Field 2 2 User Defined Field 3 User Defined Field 4 9/30/20112:03:07 PM Page 3 of 3 "EXHIBIT A2" Complaint Report Commonwealth of Pennsylvania Lower Allen Twp C'6molai6t Information Complaint Number Locked Record Follow Up Call For Service LAT2011-09-01095 No INo I PANMCP Description PANIMAL COMPLAINT Status Priority T hod Received Datellime Received Cleared Rado ' Dispatch 09/241201110:08:00 Day of the Week How Handled Saturday Phone Complaint Nature Shelly Perry called and advised that Jason Snyder was walking 7-8 dogs. I called her back and advised her that his was not a violation. Perry did advise me that Snyder did bring the dogs to his house. I advised her that this may be a codes violation. I will send a co of report to codes. Cdinplaint' Location,: Street Number Street Block Pre?reolon Street Name Street Type Postdirection 17 LE E PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Jurisdiction Number Curnberlan Location Township Magisterial District Cityrown Political Subdivision r II T a Hill Se Zone Number Zip Code Area Grid Residence Type Unit Type P 17011 1 2 Unit Number Latitude Longitude Location Type Country 40,225154 -76.890966 States of America Location Description 417 L WY ,LA 417AL EWYLAC 9/30/20112:03:59 PM Page 1 of 3 Complafnant)nform.ation Salutation first Name IsHELLY Middle Name I Last Name PERRY Suffix Date of Birth Race Sex Address 419 ALLENDALE WY Apartment City State Zip Code Hill PA 11 Phone Number 1 Area Code 717 1 Number l 7631998 Ext l Phone Type Home Phone Number 2 Area Code Number Fxd Phone Type Notify Complainant No 1 Taker ID SKKELL Dispatcher ID 1 MSFO cNEf Complaint #: 1366193 - User Defined Field 1 User Defined Field 2 User Defined Field 3 ser eel Field 4 .:.:ve. .ne,. . Salutation First Name ason Middle Name Last Name suffix Date of Birth 01/1111969 Rye ?x type SUSOOC Address 417 Allendale WY Apartment ity rcamR Hill State PA Coda 1 Phone Number 1 Area Code 717 1 Number I 975-1880 lExt i Phone Type ftme Phone Number 2 Area Code Number J Ext Phone Type User Defined Fleld 1 User Defined Field 2 User ned Feld 3 User Defined Field 4 9/30/20112:03:59 PM Page 2 of 3 Officers Involved Justin -1810 - Lower Allen Twp lReportina Officer I nratinn (lian=trh=H Street Number Street Block Predirection Street Name Street Type Postdirection PO Box Cross-Predirection Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Curnberian d Jurisdction Number Location Township Magisterial District Cityrrown Political Subdivision State Zone Number Zip Code Area Grid Residence Type Unit Type Unit Number Latitude Longitude Location Type Country nit d States f America SA Location Description 417 AL ALE VVY.LA 417ALL DALE LA UO Dispatched 09/2412011 10:10:00 Enroute Arrived 11 0.10.0 Cleared 09/24/2011 10:20:00 User Defined Feld 1-2 User Defined Red 2 User Defined Field 3 User Defined Field 4 9/30/2011 2:03:59 PM Page 3 of 3 "EXHIBIT A3" Magisterial District Judge 09-1-01 Docket Number: MJ-09101-NT-0000719-2011 Non-Traffic Docket Commonwealth of Pennsylvania V. Jason M Snyder Page 1 of 2 Judoe Assigned: Magisterial District Judge Charles A. Issue Date: Clement Jr. OTN: File Date: 09/23/2011 Arrestina Aaencv: Lower Allen Township Police Dept Arrest Date: Citation #: P 8581540-2 Disposition: Withdrawn Coun : Cumberland Disposition Date: 09/2912011 Township: Lower Allen Township Case Status: Closed Case Status Status Date _ IM -11 Processing Status Closed 09/29/2011 Completed 09/2312011 Awaiting Summary Trial 09/23/2011 Awaiting Plea Case Calendar Schedule Schedule Event Type Start Date Start Time Room Judoe Name Status Summary Trial 10/18/2011 11:00 am Magisterial District Judge Cancelled Charles A. Clement Jr. Advised of His Right to Apply for Assignment of Counsel? No Public Defender Requested by the Defendant? No Application Provided for Appointment of Public Defender? No Has the Defendant Been Fingerprinted? No Participant Type Participant Name Defendant Snyder, Jason M Arresting Officer Spaulding, Justin P # Charge Grade Description Offense Dt. Disposition 1 LO § 65 §§ 6 S Running At Large 09/09/2011 Withdrawn MDJS 1200 Printed: 10/03/2011 2:41 pm Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 at seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. Magisterial District Judge 09-1-01 r w Docket Number: MJ-09101-NT-0000719-2011 Non-Traffic Docket Commonwealth of Pennsylvania V. Jason M Snyder Page 2 of 2 F Case Disposition Withdrawn Offense Sea./Description 1 Running At Large Disposition Date Was Defendant Present? 09/29/2011 No Offense Disposition Withdrawn - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - Filed Date Entry A' Filer li To 09/29/2011 Withdrawn Magisterial District Judge Charles A. Jason M Snyder, Defendant Clement Jr. 09/29/2011 Summary Trial Cancelled - - - - -Magisterial District Court 09-101 - Jason M Snyder, Defendant 09/26/2011 Certified Summons Accepted - - - -Magisterial District Court 09-1_01 - - - - Jason M Snyder, Defendant 09/23/2011 Summons issued - - - - - - - -Magisterial District Court 09-101 - - Jason M Snyder, Defendant 09/23/2011 Certified Summons Issued - - - - -Magisterial District Court 09-1-01- - - - Jason M Snyder, Defendant 09/23/2011 _Summary Trial Scheduled - - - - -Magisterial District Court 09-101 - - Jason M Snyder, Defendant 09/23/2011 - - - Related Case Association Recorded - - - - - -Magisterial District Court 09-1-01 - - - - - Jason M Snyder, Defendant 09/23/2011 Non-Traffic Citation Filed - - - - - -Magisterial District Court 09-1_01 - - - - - - - - - - - - - - - - - - - - - - MDJS 1200 Page 2 of 2 Printed: 10/03/2011 2:41 pm Recent entries made in the court filing offices may not be immediately reflected on these docket sheets. Neither the courts of the Unified Judicial System of the Commonwealth of Pennsylvania nor the Administrative Office of Pennsylvania Courts assumes any liability for inaccurate or delayed data, errors or omissions on these docket sheets. Docket sheet information should not be used in place of a criminal history background check, which can only be provided by the Pennsylvania State Police. Employers who do not comply with the provisions of the Criminal History Record Information Act (18 Pa.C.S. Section 9101 at seq.) may be subject to civil liability as set forth in 18 Pa.C.S. Section 9183. "EXHIBIT A4" Dood-amt ranll m 1909-DONM End PARCEL NO. 13-24-0807-159 MADR THE day of ? in the year of our Lord one thousand nine hundred ninety-five (1995) BKrWXXN ROBERT F. HILBISH, widower, of Camp Hill, Pennsylvania Grantor and ISABEL E. SNYDER, single woman, of Camp Hill, Pennsylvania WITNESSETH, that in oonsideratron of ONE HUNDRED THIRTY-TWO THOUSAND FIVE HUNDRED --------------------------- ($132,500.00) ------------------------ DoMm. in hand paid, the raaeipt WAWWf is hereby soh WWkdped, the acrd grantor does hereby prat and aanesy to the acid grantee , ALL THAT CERTAIN lot or piece of ground with the buildings and improvements thereon erected, situate in Lower Allen Township, Cumberland County, Pennsyl- vania, described according to a Plan of Lots, Section No. 3-A, Allendale, made by Damon and Foster, Civil Engineers, Sharon Hill, Pennsylvania, dated July 10, 1959, and recorded September 4, 1959, in Plan Book No. 10, Page 51. BEGINNING at a point on the northern line of Allendale Way at the dividing line between Lots Nos. 71 and 72 on the aforesaid Plan of Lots; thence by the north- ern line of Allendale Way, North 21 degrees 32 minutes West, a distance of 100 feet to a point at the dividing line between Lots Nos. 70 and 71 on said.Plan; thence by said dividing line, North 68 degrees 28 minutes East, a distance of 170 feet to a point at the dividing line between Lots Nos. 63 and 71 on said Plan; thence by said last mentioned dividing line, South 21 degrees 32 minutes East, a distance of 100 feet to a point on the dividing line between Lots Nos. 71 and 72 on said Plan; and thence by said last mentioned dividing line, South 68 degrees 28 minutes West, a distance of 170 feet to a point, the Place of BE- GINNING. BEING Lot No. 71 on said Plan. HAVING THEREON ERECTED a single family residential dwelling known and numbered as 417 Allendale Way, Camp Hill, Pennsylvania. BEING THE SAME PREMISES which Helen H. Boyer, widow, by her Deed dated October 23, 1990 and recorded November 1, 1990 in the Office of the Recorder of Deeds in and for Cumberland County in Deed Book V, Volume 34, Page 1015, granted and conveyed unto Robert F. Hilbish and Dorothy J. Hilbish, his wife. The said Dorothy J. Hilbish died September 22, 1995 whereby vesting sole title unto Robert F. Hilbish, widower, Grantor herein. N 1 1 lr >Q , i. •' Ln ry, f1 YF++Ay iO O+ N ff??lll Y ..-? b ? r Iii 1,11- 1..1 ? N' y a m -' c.a tai rt? (.) 111 C 1 O IG ? Ln `?Q a tJI ill 7W e??F 131_ iACf ? 'sss&9 k 's?§ And the said grantor hereby oovosaNts and apses that he wal warrant specially the property hereby conveyed IN WITNESS WHEREOF, said grantor has hero sto set his hand and seal the day and year )fret above written. h1 tit ores t d .._.......... ............... o. %Clew ......_..« .....-...._......-......_..__....-_-..- _..»..._....-......-_....-.-__-_....-......__..----_ ............... AVE State 0?^ '^?"^'? COUSIN of /??? On this, the day of V /Ge"1?-c.s? , 18 fJ ; before me, A Notary Public Mesasdorstpned odloer, personally appeared ROBERT F. HILBISH, widower, knows to me (or satisfactorily proven) to be the person whoss name is subtoribed to the within inetramenk and acknowiedgsd that he executed some for the purposes therdn eolafvimsd WHEREOF, I Nereus s y hand and o s SFM Pam zYtle of Ofeer. _ Ions, .. :? ee. County of on this, the day of before me, the undersigned a&-, persona ft appeared known to me (or sat6efactot0y prom) to be the person whose name subedribed to the wi" kutrwnent, and ac nrowwosd that essouted same for the purposes therein oontai"A IN WITNESS WHEREOF, I hereunto set my hand and olliciof seal. A 1=201h -. r..._..__. .. - __..__._.... .._...._ _ _ -- Title of Officer. .r do hereby osrtify that the proem reeidenoe and complete post o8ae address of the witkis "anted prantse is y/7 1911d,non/c w07 e'll"P `,04. -701, - ND ? . 17 is 9S A for _6U.224 BOOK 131 Pur 704 "EXHIBIT AS" Complaint Report tOA Commonwealth of Pennsylvania Lower Allen Twp _. Complaint: information Complaint Number Locked Record Follow Up Call For Service 1 1 No lNo 1PDEPSV Description P N SERVICES Statu s Priority T Meth7o_dRecelved Dat;-nme Received Cleared 0 ers n 1 Visit 1 2 1 14:00:00 Day of the Week How Handled Thursday Officer A i ed Complaint Nature Departmental Services, requested by Codes Department employee Linda Hockenberry to speak to Isabel Snyder reference to her situation involving her son. See comments, possible referral to be made for services. Complaint126tation Street Number 417 Street Block Predirectlon Street Name lAllendale Street Type Vn Postdirection PO Box Cross-Predirectlon Cross-Street Name Cross-Street Type Highway Name Highway Number Highway Milepost Rural Route County Cumberland Jurisdiction Number Location Township r Allen To hi Magisterial District 09-1-01 City/Town m Hill Political Subdivision State Zone Number P Zip Code 7011 Area Grid 1202 Residence Type Unit Type Unit Number Latitude 0.00 Longitude 0.00 Location Type Country United States o is A Location Description 9/30/2011 1:59:24 PM Page 1 of 6 Complainant Information Salutation First Name Linda Middle Name Last Name rrv Suffix Date of Birth Race x e Wairnale Address 2233 GqMburg Road Apartment i City Camg) Hill I State PA 1 Zip Code 17011 Phone Number 1 Area Code Number 9757575 Ext Phone Type Phone Number 2 Area Code 717 Number Ext Phone Type 1 Notify Complainant Call Taker ID Dispatcher ID 1 cNEr Complaint #: 1332130 User Defined Feld 1 User Defined Field 2 User Defined Field 3 user 4 9/30/2011 1:59:24 PM Page 2 of 6 Complainant Associate Salutation First Name Middle Name E Last Name YD Suffix Date of Birth 02/1711928 Chite e Sex Association Type Witness Address 41 L E DALE WY Apartment city AMP HILL state IPA Zip Code 117011 Phone Number 1 Area Code 1 7 7 61-0574 umber Fact Phone Type Hom Phone Number 2 Area Code Number IlExt ----] 7977 7e User Defined Field 1 witness User Defined Field 2 User Defined Field 3 User Defined Field 4 Salutation EASON rst Name Middle Name Last Name YD Suffix Date of Birth 01/11/1969 Race - hlte Ile I Association Type suspect Address 417 Allendale WY Apartment I City Camg) Hill I State PA 1 Zip Code 17011 Phone Number 1 Area Code 717 1 umber 91751880 Fwd l Phone Type Home Phone Number 2 Area Code 71 1 umber -1,7610574 Ext Phone Type II User Defined Field 1 suspect User Defined Field 2 so of Isabel User Defined Field 3 User Defined Field 4 9/30/2011 1:59:24 PM Page 3 of 6 Officers Involved Donald -1808 - Lower Allen Twp (Reporting Officer Dispatched Enrane 07/1512011 Arrived Cleared 0711512011 0 0711512011 14:20:00 Field 1-2 luser uennea tea z comments 9/30/2011 1:59:24 PM Page 4 of 6 garrative by Detective Corporal Sentman 1808 15 July 2011 )n Thursday 14 July 2011,1 was asked by Linda Hockenberry of the Codes Department to speak to Isabel inyder. Isabel Snyder lives at 417 Allendale Way. Her son, Jason Snyder walks dogs to her home and keeps hem there during the day. The codes department has filed at least three (3) citations against Isabel for violations that all are created by Jason's actions. Isabel has paid all the citations. Linda Hockenberry stated hat Chief Williamson had spoken at a recent meeting and wanted an officer to speak to Isabel to determine if ;he is being intimidated by her son into paying these citations. was told that Isabel was waiting in the interview room. 1 walked in and introduced myself to Isabel. Isabel held ter receipt that showed what she had paid for the most recent citation. I asked Isabel what she had wanted to ,peak to me about today. Isabel stated she had just come in to pay a fine and that she had not wanted to speak o me. I asked what fine she could possibly have and she showed me her paperwork. I read it and asked several %asy questions to Isabel. She was able to answer all, the questions without issue. I asked her about the fine and ;he explained that her son continues to walk dogs to her home and she receives fines as the homeowner. asked her how many fines she has paid thus far. I was told that she has paid three fines and that they have )een all about $500.00. asked Isabel if she is ok paying the fines. She stated she has no choice and that she has to pay them. I asked ier if she ever asked her son to pay the fines since he is the one who gets them. She stated she does not. She Deemed a little un-comfortable with the questions about her son. I asked her if she ever told her son not to bring he dogs to her home because of the fines. She stated she cannot do that and then stated that he would have no )lace to take them. She started to get emotional and began to cry. I asked her if she was ok speaking to me about this issue. I then asked if Jason was forcing her to pay the fines and she stated, "Nol" Isabel appeared to ?ecome defensive after this question so I changed and asked a few more easy answer questions. I then came )ack to Jason and asked if he had a temper. She stated that he did. I then asked if he knew what this was doing o her, (dogs in the home getting her fined in a repeated maner), if that would change things. She stated it vouldn't change things. She then told me that Jason and his father are "working on another place to go..." in eference to the dog situation. asked Isabel if she would mind if I spoke to Jason about what he is doing to her by his actions. She stated that could. I asked if she would want me to tell him that she does not want the dogs brought over again and she eplied no. She stated that he needs to bring them because he has no place to take them. spoke to Isabel and asked if Jason was ever violent or abusive toward her. She stated, "no.l" I asked if he had ever been abusive and she stated that he was in the past. She then explained that when he was in school he left or some time and ended up living with a female subject who had a daughter his age. She started to get emotional and began to cry. She then told me that she did not want to go through this right now. I told her 1 mderstood and told her she could leave if she wanted to leave. I asked if I could give her a business card and I placed my phone extension on the card. I asked to have Jason call me reference this issue and then told her hat if she needed anything to call for help. opened the door and thanked Isabel for speaking to me. escorted her out of the room and she departed the station. 1 then spoke to Linda Hockenberry and Mark Eby. I xplained to them that 1 had concerns about this issue because of Isabel's reactions to me and my questions. 9/30/2011 1:59:24 PM Page 5 of 6 I Report, Detective Corporal Sentman 180815 July 2011 m this date, I completed the following work on this case. I stopped at 417 Allendale Way to speak to Jason nyder. Jason had left a message on my voice mail upon my arrival to work today. I heard that the message as short and indicated who he was and he had no idea why I needed to speak to him but he was returning my responded and knocked on the door. There were a few dogs inside of the house that barked at me as I waited :)r an answer at the door. I received no answer at the door and walked back to my car. I did leave a business and In the door for follow up purposes. then noticed a small sedan approach the home. The male subjec pulled into the driveway of the home and xited. He opened the door and let a few dogs out of the car. He then opened the garage and permitted the dogs o run through the garage to the open backdoor. They filed into the yard behind the home and Jason came back D speak to me in teh driveway. introduced myself to Jason and explained why 1 was speaking to him today. 1 told him of my conversation with is mother yesterday, and that I had concerns that she was paying so many bills and fines that she did not aceive. I asked if he wanted her to keep paying the fines. He Indicated that he takes good care of his mother nd not to worry. He placed his hand on my shoulder when he made the last statement and told` me again not to rorry. He then spoke of a home he Is planning to purchase on off of Limekiln Road where the zoning is perfect 3r his business. He also stated that he would continue his practice of putting aside $100.00` each week to pay ?r any fines he receives for his activity. He then referred to It as harassment and stud that he was going to be ut of the neighborhood as soon as he can get the home bought. thanked him for the information and asked when we could anticipate the home being purchased. He >tated they are still talking about price and that he does not know when to expect to have the home. thanked him for the information and told him I would pass it along to codes. As his mother was apprehensive or me to speak to him in any way, I did not question him further about why his mother would have to use a :redit card to pay for the funds owed. returned to the station and informed Codes of what I had been told by Jason. 1 collected the phone number for Aike Towsen, Dog Warden, (774-2780) and called him on this date. I left a message for him to return my call. also called the Cumberland County office of Aging and Human Services. I spoke to Priscilla Whitman and nade a referral to their office on behalf of Isabel. will follow up as needed with this case and assist Codes and the Office of Aging as needed. Report, Detective Corporal Sentman 1808 19 July 2011 this date, I received a phone message from the dog warden who returned my call on Monday. I called him k but was forced to leave another message for him reference to this case. 9/30/2011 1:59:24 PM Page 6 of 6 VERIFICATION I, Frank E. Williamson, Jr., Chief of Police/Director of Public Safety for the Township of Lower Allen and authorized representative for the Township of Lower Allen, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. Dated: Oc')? !N VERIFICATION I, John M. Eby, Building and Zoning Coordinator for the Township of Lower Allen and authorized representative for the Township of Lower Allen, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unworn falsification to authorities. Dated: I P 'Vb-1) ?A\z L Jo .Eby VERIFICATION I, Thomas G. Vernau, Jr., Manager for the Township of Lower Allen and authorized representative for the Township of Lower Allen, verify that the statements made in this Complaint are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: (O be 111 Thomas G. Vern 2g1 / OCT 14 PH is 5 PENNs yL r T LVAP 1 A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOWER ALLEN TOWNSHIP, Plaintiff V. Docket No: 11-7665 Civil CIVIL ACTION JASON M. SNYDER AND : ISABEL E. SNYDER, (In Equity) Defendants NOTICE OF ENTRY OF APPEARANCE Kindly enter our appearance as counsel for Defendant Isabel E. Snyder in the above- captioned matter. McNEES WALLACE & NURICK LLC By Kimberly M. Colonna PA 80362 Alexis I. Snyder PA 308778 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108 (717) 237-5284 Attorneys for Defendant Isabel E. Snyder Dated: October 14, 2011 CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date a true and correct copy of the forgoing documents were served by the means indicated: In-person hand-delivery' Steven P. Miner, Esq. Daley Zucker Meitlon Miner & Gingrich 635 N. 12`h St., Suite 101 Lemoyne, PA 17043 Attorneys for Plaintiff By first class mail: Jason Snyder 1137 Columbus Ave., Apt. 9 Lemoyne, PA 17043 Defendant, pro se G berly . Colonna Dated: October 14, 2011 n t?lLE?-U?r-'1C THE PR KO' r??t 2011 OCT 14 P11 'UMBE'RLANG COT PENNSYLa/At?'d1A ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOWER ALLEN TOWNSHIP, Plaintiff Docket No: 11-7665 Civil V. CIVIL ACTION JASON M. SNYDER AND ISABEL E. SNYDER, (In Equity) . Defendants STIPULATION OF DEFENDANTS Jason M. Snyder and Isabel E. Snyder hereby stipulate to the entry of a preliminary injunction in the above-captioned matter that provides, pending further hearing, as follows: (1) that Defendant Jason Snyder is prohibited from operating any business at 417 Allendale Way, Camp Hill, Pennsylvania; (2) that Defendants Jason Snyder and Isabel Snyder will not have any dogs at 417 Allendale Way, Camp Hill, Pennsylvania, except the dogs that are owned by Jason Snyder and/or Isabel Snyder. McNEES WALLACE q& NURICK LLC By Kimberly M. Colonna PA 80362 Alexis I. Snyder PA 308778 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108 717-232-8000 Attorneys for Defendant Isabel E. Snyder Dated: October 14, 2011 k CERTIFICATE OF SERVICE The undersigned hereby certifies that on this date a true and correct copy of the forgoing documents were served by the means indicated: In-person hand-delivery: Steven P. Miner, Esq. Daley Zucker Meitlon Miner & Gingrich 635 N. 12' St., Suite 101 Lemoyne, PA 17043 Attorneys for Plaintiff By first class mail: Jason Snyder 1137 Columbus Ave., Apt. 9 Lemoyne, PA 17043 Defendant, pro se L 'Ktimberly-M. Colonna Dated: October 14, 2011 LOWER ALLEN TOWNSHIP, IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA V. a? o JASON M SNYDER AND rn c- L . ISABEL E. SNYDER, --r DEFENDANTS NO. 11-7665 CIVIL -rE C, ORDER OF COURT .«` ca AND NOW, this 14th da y of October, 2011, this being the time and place set for a hearing upon Lower Allen Township's Motion for Preliminary Injunction Without Hearing and Counsel for Defendant, Isabel Snyder having provided a stipulation signed by both Defendants to the effect that the Defendants will concur in entry of a Preliminary Injunction, IT IS HEREBY ORDERED AND DIRECTED that a Preliminary Injunction is issued as follows: (1) that Defendant, Jason Snyder, is prohibited from operating any business at 417 Allendale Way, Camp Hill, Pennsylvania; (2) that Defendants, Jason Snyder and Isabel Snyder, will not have any dogs at 417 Allendale Way, Camp Hill, Pennsylvania, except the dogs that are owned by Jason Snyder and/or Isabel Snyder. Steven P. Miner, Esquire Attorney for Plaintiff Kimberly M. Colonna, Esquire Attorney for Defendant Isabel E. Snyder Jason M. Snyder, Pro Se Defendant By the Court, bas SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff „tr at ?t?gbr,. z I^ 4/4 Jody S Smith Chief Deputy I P"T 21 AM Richard W Stewart ?vl ?r ;.tt Solicitor Lower Allen Township Case Number vs. 2011-7665 Jason M. Snyder (et al.) SHERIFF'S RETURN OF SERVICE 10/07/2011 05:05 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on October 7, 2011 at 1705 hours, she served a true copy of the within Compltin in Equity and Motion for Preliminary Injunction Without Hearing, upon the within named defendant, to wit: Isabel E. Snyder, by making known unto herself personally, at 417 Allendale Way, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. A A CO UGH, DEP TY 10/10/2011 05:29 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on October 10, 2011 at 1729 hours, he served a true copy of the within Motion for Preliminary Injunction Without Hearing, upon the within named defendant, to wit: Jason M. Snyder, by making known unto himself personally, at 1137 Columbus Avenue, Apartment 9, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true and correct copy oft a same T ? MICHAEL BAR tCK, DEPUTY 10/13/2011 07:26 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on October 13, 2011 at 1926 hours, she served a true copy of the within Complaint in Equity, upon the within named defendant, to wit: Jason M. Snyder, by making known unto himself personally, at 1137 Columbus Avenue, Apartment 9, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true and correct copy of the s e MICHELLE GUTSHALL, DEPUTY SHERIFF COST: $75.44 October 14, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF (c) COWITYSIAO She-ft, Te,ecsult. Inc. Steven P. Miner, Esquire DALEY ZUCKER MEILTON & MINER, LLC 635 N. 12th Street, Suite 101 Lemoyne, PA 17043 (717) 724-9821 sminer@dzmmlaw.com i w *} R i) 11't` J' l' t o! t ti SEP 30 AM 8: 314 CUMBERLAND COUNT' PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lower Allen Township, Docket No. 2011-7665 Plaintiff CIVIL ACTION (In equity) Jason M. Snyder and Isabel E. Snyder, Defendants Honorable Merle L. Ebert, Jr. PLAINTIFF'S PETITION FOR CONTEMPT v. AND NOW, comes Lower Allen Township, by and through its attorneys, Steven P. Miner, Esquire, and Daley Zucker Meilton & Miner, LLC, who hereby file Plaintiff's Petition for Contempt and in support thereof state as follows: 1. Plaintiff, Lower Allen Township, (hereinafter "Township") is a township of the first class in the County of Cumberland, Commonwealth of Pennsylvania, having its offices at 2233 Gettysburg Road, Camp Hill, PA 17011. 2. Defendant Jason M. Snyder (hereinafter "Defendant Jason"), is an adult individual who resides at 417 Allendale Way, Camp Hill, Pennsylvania 17011 (hereinafter "subject property"). 3. Defendant, Isabel E. Snyder (hereinafter "Defendant Isabel"), is an adult individual who resides at 417 Allendale Way, Camp Hill, Pennsylvania 17011. 4. Township filed a Complaint for violation of the Township's zoning ordinances on October 11, 2011. 5. On October 11, 2011, the Honorable Merle L. Ebert, Jr., based upon Township's Complaint and Motion for Preliminary Injunction without Hearing, entered an Order granting an injunction against Defendant Jason and Defendant Isabel enjoining the operation of the business of Defendant Jason from the subject property and from bringing additional dogs upon the subject property pending a hearing on October 14th, 2011. A copy of the October 11th, 2011 Order is attached hereto and incorporated herein by reference as Exhibit "A". 6. On October 14, 2011, the Honorable Merle L. Ebert, Jr., based upon a stipulation signed by Defendant Jason and Defendant Isabel to the effect that they would concur in the entry of a Preliminary Injunction, entered an Order of Preliminary Injunction prohibiting Defendant Jason from operating any business at the subject property and from Defendant Jason and Defendant Isabel from having any dogs at the subject property other than those dogs owned by Defendants. A copy of the October 14th, 2011 Order is attached hereto and incorporated herein by reference as Exhibit "B". 7. On August 24th, 2014, Officer Kevin Cramer (hereinafter "Ofc. Cramer") of the Lower Allen Township Police Department responded to a call from dispatch to check the area near the subject property for barking dogs. 8. Ofc. Cramer did not hear any dogs when he arrived but contacted the caller, Leslie Dolan. 9. Dolan informed Ofc. Cramer that Defendant Jason kept several dogs at the subject property, but was unsure how many. 10. Ofc. Cramer went to the subject property and upon knocking on the front door, could see and hear a minimum of six (6) dogs inside the subject property. 11. Officer Thomas Gelnett (hereinafter "Ofc. Gelnett") of the Lower Allen Police Department asked Defendant Jason whether he was allowed to have that many dogs at the subject property. Defendant Jason responded that he believed he was no longer subject to the October 14th, 2011 Preliminary Injunction. 12. Jason Snyder told Officers Cramer and Officer Gelnett that four (4) of the dogs belonged to him, but two (2) of the dogs belonged to friends. 13. Ofc. Cramer and Ofc. Gelnett documented the incident on Incident Report Form LA -14- 05417, a copy of which is attached hereto and incorporated herein by reference as Exhibit "C". 14. Officer Kevin Cramer prepared an incident report attached hereto as Exhibit "D" and labeled as LA -14-05632 on September 3, 2014. The Exhibit indicates that a Barbara Turk brought her Australian Shepard to an animal emergency center for injuries sustained from an attack by another dog. She reported the alleged injury as caused by a dog in the care of Jason Snyder at 417 Allendale Way. Ms. Turk identified Jason Snyder as her dog walker/sitter. 15. Jason Snyder owned four (4) dogs at the time of the October 14th, 2011 Order, a copy of which are attached hereto and incorporated herein by reference as Exhibit "E." 16. Jason Snyder does not currently have any dog licenses in Cumberland County. 17. Isabel Snyder does not currently have any dog licenses in Cumberland County. 18. Defendants' actions are in contempt of the October 14th, 2011 Order prohibiting Defendants from having any dogs other than those owned by Defendants at the subject property. 19. Petitioner requests that this Honorable Court hold Defendant Jason and Defendant Isabel in Contempt of the October 14th, 2011 Order for having dogs not owned by Defendants at the subject property. 20. Pursuant to Section 4133 of the Judicial Code, the Court can issue fines as punishment for contempt of court. Wherefore, Plaintiff/Petitioner respectfully requests this Honorable Court enter an Order granting its Petition for Contempt, finding Defendants/Defendants in contempt of the October 14, 2011 Order of Court, prohibiting Defendants from having any dogs on the subject property except those owned by Defendants, fines, costs and other just and equitable relief. Date: 7/30/ / 9 By: Respectfully submitted, DALEY ZUCKER MEILTON & MINER, LLC Steven P. Miner, Esquire Attorney I.D. No. 38901 Matthew B. Werner, Esquire Attorney I.D. No. 313499 635 N. 12th Street, Suite 101 Lemoyne, PA 17043 Phone: (717) 724-7821 Email: sminer@dzmmlaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Lower Allen Township, Plaintiff v. Jason M. Snyder and Isabel E. Snyder, Defendants Docket No. 2011-7665 CIVIL ACTION (In equity) Honorable Merle L. Ebert, Jr. CERTIFICATE OF SERVICE I, Steven P. Miner, Esquire, hereby certify that on the date indicated below I served a true and correct copy of the foregoing Petition for Contempt via First Class, U.S. Mail, postage prepaid, upon the following: Kimberly M. Colonna, Esquire McNees Wallace & Nurick, LLC PO Box 1166 Harrisburg, PA 17108 Attorney for Defendant Isabel E. Snyder Jason M. Snyder 417 Allendale Way Camp Hill, Pennsylvania 17011 Defendant Date: (/36/ f it By: A Steven P. Miner, Esquire Attorney I.D. No. 38901 Matthew B. Werner, Esquire Attorney I.D. No. 313499 Daley Zucker Meilton & Miner, LLC 635 N. 12th Street, Suite 101 Lemoyne, PA 17043 Phone: (717) 724-7821 Email: sminer@dzmmlaw.com EXHIBIT "A" IN THE COURT OF COMMON PLEASE OF CUMBERLAND COUNTY, PENNSYLVANIA , Lower Allen Township, Docket No. 2011- 16) (p S CIV(1 Plaintiff CZ -71 v. CIVIL ACTION r-- - -urn Jason M. Snyder and Isabel E. Snyder, Defendants (In equity) F - n --rr ORDER =? AND NOW, this day of , 2011 upon corisid re ation' of the attached Complaint and Motion for Preliminary Injuction without Hearing, and pending further hearing, IT IS HEREBY ORDERED an injunction is entered against the Defendants, Jason M. Snyder and Isabel E. Snyder: (a) enjoining the operation of the business of Defendant Jason Snyder at 417 Allendale Way, Camp Hill, PA 17011. (b) enjoining Defendants from bringing additional dogs upon the premises, pending further hearing in this matter and pending further order of the court. A rule is entered upon all Defendants to show cause why an injunction should not be issued after hearing, ordering the cessation of all activities of the business of Defendant Jason Snyder and the cessation of the use of the property described_in the Complaint, in violation of § 220-11 of the Code of Lower Allen Township. NIT IS FURTHE ORDERED a hearing shall be held on the day of ew -2011, 1.' P at A2ELP M , in Court Room of the Cumberland County Courthouse, Pennsylvania. Distribution: Steven P. Miner, Esquire, Matthew A. Sembach, Esquire, Daley Zucker Meilton Miner & Gingrich, LLC, 63/5 N. 12`h Street, Suite 101; Solicitor for Plaintiff Jason Snyder, 1137 Columbus Avenue, Apartment 9, Lemoyne, Pa 17043; Defendant Isabel E. Snyder, 417 Allendale Way, Camp Hill Pa 17011; Defendant TRUE COPY FROM RECORD In Testimony whereof, l here'unto set my hand and the al of said rt t Carlisle, Pa. This. 11 `-‘4. ay of _., 20 ./1.... Pro%bonotary BY THE COURT: EXHIBIT "B" LOWER ALLEN TOWNSHIP, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA C) ,-,., V. -_-E m123 a) = x) -I -C rrl JASON M. SNYDER AND (f)r- — xc, ISABEL E. SNYDER, DEFENDANTS : NO. 11-7665 CIVIL .--::-.- Q -ri X - r>.3 ORDER OF COURT , cp -.-.---- --‹ C-,,, AND NOW, this 14th day of October, 2011, this being the time and place set for a hearing upon Lower Allen Township's Motion for Preliminary Injunction Without Hearing and Counsel for Defendant, Isabel Snyder having provided a stipulation signed by both Defendants to the effect that the Defendants will concur in entry of a Preliminary Injunction, IT IS HEREBY ORDERED AND DIRECTED that a Preliminary Injunction is issued as follows: (1) that Defendant, Jason Snyder, is prohibited from operating any business at 417 Allendale Way, Camp Hill, Pennsylvania; (2) that Defendants, Jason Snyder and Isabel Snyder, will not have any dogs at 417 Allendale Way, Camp Hill, Pennsylvania, except the dogs that are owned by Jason Snyder and/or Isabel Snyder, Steven P. Miner, Esquire Attorney for Plaintiff By the Court, Kimberly M. Colonna, Esquire Attorney for Defendant Isabel E. Snyder Jason M. Snyder, Pro Se Defendant bas Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY tor of Citiobr,1. OFFiC:E OF iME SHERIFF 7111 OCT 27 AM $: !H CUMBERLAND CODisHf 'r PEP,'!':'.SY`_'f N!A Lower Allen Township vs. Jason M. Snyder (et al.) Case Number 2011-7665 SHERIFF'S RETURN OF SERVICE 10/07/2011 05:05 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on October 7, 2011 at 1705 hours, she served a true copy of the within Compltin in Equity and Motion for Preliminary Injunction Without Hearing, upon the within named defendant, to wit: Isabel E. Snyder, by making known unto herself personally, at 417 Allendale Way, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. 10/10/2011 05:29 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on October 10, 2011 at 1729 hours, he served a true copy of the within Motion for Preliminary Injunction Without Hearing, upon the within named defendant, to wit: Jason M. Snyder, by making known unto himself personally, at 1137 Columbus Avenue, Apartment 9, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to him personally the said true and correct copy of to same MICHAEL BAR CK, DEPUTY S- 10/13/2011 07:26 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on October 13, 2011 at 1926 hours, she served a true copy of the within Complaint in Equity, upon the within named defendant, to wit: Jason M. Snyder, by making known unto himself personally, at 1137 Columbus Avenue, Apartment 9, Lemoyne, Cumberland County, Pennsylvania 1704.3 its contents and at the same time handing to him personally the said true and correct copy of the s SHERIFF COST: $75.44 October 14, 2011 Icj CountySuile Shenit, Te,eosoft. loc. MICHELLE GUTSHALL, DEPUTY SO ANSWERS, RONNY ANDERSON, SHERIFF EXHIBIT "C" LOWER • ALLEN TOWNSHIP PD LA -14-05417 Administrative 0 Gang Related 0 Paperless Officer: KEVIN CRAMER- 1824KC 08/24/14 0 Investigation 0 Accident 0 Arrests Made Incident Report Form 0 Suspects 0 Ready for DA / Prosecutor p Log Number LA -14-05417_ Incident Number File Number Case Number UCR 26 ALL OTHERS EXCEPT SUMMARY TRAFFIC Incident Type ORDVIo ORDINANCE VIOLATION Dispatcher SourceDistrict DISP I 1202 Status ACTIVE Date Received 08/24/2014 Day Recd Sunday RcvdDisp 2250 + Arry 2250 12133 Cird 2341 Disposition CIT CLEARED BY CITATION 8e. Earliest Dale and Time INCIDENT OCCURRED AT OR BETWEEN 8 24/2014 2150 (Sunday) 8f. Latest Dale and Time 8/24/2014 2250 (Sunday) Location 417 ALLENDALE WY • CAMP HILL PA 17011 Additional Address Information / Cross Street Intersection 0 GPS Coordinates X Y Gang Arson Value Premise Code RESID RESIDENCE/HOME I Business Name Modus Operandl Coding VICTIM: ENTRY: PROPERTY EXIT: AREA: METHOD: TIME OF DAY: WEAPONS USED: Caller /Complainant Type Normal • Anonymous 0 Hangup 0 Refused • INVOLVED PERSONS _FAMILY;MEMBM. :. CODE '°<FAMILY:', -Y Name (Last, First, Middle) - Address Juvenile SNYDER, ISABEL • 417 ALLENDALE WY CAMP HILL PA 17011 Current Address © Address Changed Since Incident Date Dale of BirthAge 02/17/1928 184 Race W Sox F Ethnic I N eu Social Sanely Numbor weight ( Haight Hair Eyos Phono Number (717) 761-0574 Oliver License Number stare Later Name Edit ❑ Link Comments t SUSPECT„CODE:`'SUSP°:::: , ; Name (Last. First, Middle) - Address Juvonflo SNYDER, JASON MATTHEW 0 417 ALLENDALE WY CAMP HILL PA 17011 Current Address © Address Changed Since Incident Date Dale of Birth 01/11/1969 i Ago RaceSex 45 [ W Ethnic I M I N Social Security Number 194-44-8096 mull 180 Hob t 70 air BLD Eyes BLU . PhoneNumbor (717) 975-1880 Driver Uconse Numbor 22523927 State PA Later Name Edit 0 Link Comments FIELD STOPS RESPONDING / INVOLVED UNITS, OFFICERS, AND TIMES Vehicle Officer 1 Officer 2 Officer 3 Officer 4 Division Supervisor Unit 1 LA3 1824KC 1811 Unit 2 Unit 3 Unll 4 Aoencv Numbers Units & Times LA -14-05417 8/24/2014 Approved By: PAGE 1 IRF 1.6 ❑ Approved On: LOWER ALLEN TOWNSHIP PD LA -14-05417 KEVIN CRAMER - 1824KC 08/24/14 ■ Administrative 0 Gang Related 0 Paperless Officer: Q Investigation ❑Accident 0 Arrests Made ® Suspects ❑ Ready for DAL Prosecutor COMMENTS / NARRATIVES nua ROLL CALL SYNOPSIS Incident Report Form p Created By / On KEVIN CRAMER 08/25/2014 Updated By / On KEVIN CRAMER 08/25/2014 Approved By/On Animal ordinance violation at 417 Allendale Way. . Leslie Doland reported dogs barking for over an hour. Jason Snyder to be cited. LA -14-05417 8/24/2014 Approved By: PAGE 2 IRF 1.8 0 Approved On: R ALLEN TOWNSHIP PD LA -14-05417 KEVIN CRAMER - 1824KC 08/24/14 • Administrative 0 Gang Related 0 Paperless Officer: —In°woUgounn 0 Accident —A,ms���oda D8uopectn ] Ready for UA/Prosecutor COMMENTS / NARRATIVES n^" ORIGINAL NARRATIVE Incident R~ort Form Created By / On KEVIN CRAMER 08m5/2014 Updaled by/ On THOMAS GELNETT 08/25/2014 Approved e,/n" Charges: Ordinance 2014-01 65-2 Animals -Disturbing or Loud Noise Original Narrative by Ofc. Cramer 1824 on 08/25/2014: . On 08/24/2014, at 2250 hours, County dispatched me to check the area riear 414 Blacklatch LN for barking dogs. Upon arrival in the area of that address 1 did not hear any dogs barking. The caller, Leslie Dolan, had reported that the barking was coming from behind her home. I then drove through the area on Allendale Way that would be adjacent to her back yard. Not hearing any animals I contacted Dolan for more information. Dolan was familiar with the home where the dogs resided. She stated that the son of Isabel Snyder keeps several dogs at her home, which Dolan believed was either 417 or 419 Allendale Way. She also stated that she did not know how many dogs were on the property but she knew that it was a larger number. I found Jason Snyder listed in Cody as a resident of 417 Allendale Way along with his mother Isabel. |droxe to that address to speak with the Sriyder's. Upon knocking on the front door a minimurn of 6 dogscould be seen and heard barking inside the residence. It took several minutes for Jason Snyder to answer the door. During the time we were waiting several of the dogs could be heard barking outside the house. When Snyder answered the door I informed him that a neighbor had complained about the dogsbarking in the back yard approximately an hour before we arrived. He stated that he had just arrived at his mothers home and had not been there at the time of the incident. Ofc. Gelnett was familiar with Jason and asked him if he was to have that many dogs in the home. Snyder stated that he believed that his prior restriction had been lifted several years before. He was advised that contact would be made with LA Codes Department and the Dag Law Officer to verify. Jason brought his mother to the door to speak with us at our request. When asked what time Jason arrived at herhonnoohemtotedthatoheboUevadhohedanivedafter10:OOpm.JaoondisugreedandYe|t that she was unable to remember clearly. Ofc. Gelnett asked f he felt that 11 was appropriate to cite Isabel for the ordinance violation. Jason stated that if a citation were to be issued that it should be issued to him. He also stated that there were 6 dogs in the home at that time. Four belong to Jason and two others belong to friends. Non -traffic citation filed on Jason Snyder. Linda Hockenberry will be forwarded a copy of this complaint so that she can follow up and make contact with the dog law officer. Nothing further. LA -14-05417 0/24/2014 Approved By: PAGE o EXHIBIT "D" Lower • Allen Township Administrative ■ PD LA -14-05632 Gang Related • Paperless Officer: KEVIN CRAMER- 1824KC 09/03/2014 • • Investigation Suspects • • Accident • Arrests Made Incident Report Form Ready for DA / Prosecutor p Log Number LA -14-05632 Incident Number File Number Case Number UCR Incident Type ORDVIO ORDINANCE VIOLATION Dispatcher Source DISP District 1210 Status NONACT Date Received 09/03/2014 Day Rec'd Wednesday Rcvd 0956 Disp 0956 Arry 0956 CIrd 1015 Disposition NFPA NO FURTHER POLICE ACTION INCIDENT OCCURRED AT OR BETWEEN Earliest Date and Time Latest Date and Time Location 417 ALLENDALE WY CAMP HILL PA 17011 Cross Street Intersection • GPS Coordinates X Y Gang Arson Value Premise Code RESID RESIDENCE/HOME Business Name Modus Operandi Coding VICTIM: ENTRY: PROPERTY EXIT: AREA: METHOD: TIME OF DAY: WEAPON USED: Caller / Complainant Type Normal ■ Anonymous ■ Hangup • Refused • INVOLVED PERSONS CALLER CODE: CALLER Name (Last, First, Middle) -Address Juvenile MEYERHOFF, SABRENA LYNN • 684 OLD YORK RD ETTERS PA 17319 Current Address 0 Address has changed since the date of the incident --I Date of Birth 08/06/1971 Age 41 Race W Sex F Ethnic N Social Security Number Weight Height 506 Hair Eyes HAZ Phone Number (443) 676-8132 Driver License Number 27542873 State PA• Later Name edit Link Comments COMPLAINANT CODE: COMPL Name (Last, First, Middle) - Address Juvenile TURK, BARBARA M ■ 2432 JERICHO DR HARRISBURG PA 17110 Current Address R Address has changed since the date of the incident 1 Date of Birth 10/18/1949 Age 64 Race W Sex F Ethnic N Social Security Number Weight Height Hair Eyes Phone Number (717) 439-5689 Driver License Number 13981364 State PA• Later Name edit Link Comments SUSPECT CODE: SUSP Name (Last, First, Middle) - Address Juvenile SNYDER, JASON MATTHEW • 417 ALLENDALE WY CAMP HILL PA 17011 Current Address ,m Address has changed since the date of the inddenn Date of Birth 01/11/1969 Age 45 Race W Sex M Ethnic N Social Security Number 194-44-8096 Weight 180 Height 510 Hair BLD Eyes BLU Phone Number (717) 975-1880 Driver License Number 22523927 State PA• Later Name edit Link Comments LA -14-05632 09/03/2014 IRF 1.6 • APPROVED BY: PAGE 1 APPROVED ON: Lower Allen Township PD Paperless Officer: Arrests Made KEVIN LA -14-05632 CRAMER - 1824KC 09/03/2014 • Administrative • Investigation • Gang Related • • Accident • Incident Report Form p • Suspects • Ready for DA / Prosecutor INVOLVED BUSINESSES / ORGANIZATIONS 09/03/2014 Business 1 Organization Name ROSSMOYNE ANIMAL EMERGENCY TRAUMA CENTER Business Address 4930 BITTER RD STE 101 MECHANICSBURG, PA 17055 Phone (717) 796-2334 I Phone 2 1 Phone 3 Involvement Comments RESPONDING / INVOLVED UNITS, OFFICERS, TIMES Unit Unit Unit Unit Vehicle Officer 1 Officer 2 Officer 3 Officer 4 Division Supervisor 1 LA3 1824KC 1812 2 3 4 A.enc Numbers Units & Times COMMENTS / NARRATIVES Title ROLL CALL SYNOPSIS Created By / On KEVIN CRAMER 09/03/20141 Updated By / On kevinc 09/03/2014 Approve By / On Ordinance Violation reported as animal abuse by Sabrina Meyerhoff Barbara Turk, reported her dog was attacked by another dog Wa . of the Animal Emerg. Ctr. A client, while in Jason Snyder's care at 417 Allendale COMMENTS / NARRATIVES Title ORIGINAL NARRATIVE Created By / On KEVIN CRAMER 09/03/2014 Updated By / On kevinc 09/03/2014 Approve By / On Original Narrative by Ofc. Cramer 1824 on 09/03/2014: County dispatched a phone call with regard to animal abuse from Emergency Center at 4930 Ritter Rd. A client, Barbara Turk, brought her Australian Shepherd to the sustained from an attack by another dog. She reported it to Sabrina in the care of Jason Snyder at 417 Allendale Way. Snyder was I have attempted to contact Barbara Turk but I have been unable out how her animal came to be in the care of Snyder and for when he returned her injured dog. Meyerhoff stated that there was no medical evidence of abuse did sustain internal injuries from the attack by the other dog. She would be available to us if necessary. We will refer this incident to Linda Hockenberry as a zoning ordinance Sabrina Meyerhoff of the Animal emergency center to be treated for injuries as a case of abuse because the dog was paid by Turk as a dog walker/sitter. to reach her. I will follow up with her to find more details from her conversation with Snyder of the animal by Snyder but that the animal also stated that the animals medical records violation and the County dog law LA -14-05632 09/03/2014 IRF 1.6 PAGE 2 • APPROVED BY: APPROVED ON: Lower Allen Township PD LA -14-05632 CRAMER - 1824KC 09/03/2014 • Administrative ■ Gang Related • Paperless Officer: KEVIN • Investigation ■ Accident • Arrests Made Incident Report Form • Suspects • Ready for DA/Prosecutor officer once we have made contact with Turk. Nothin. further. COMMENTS / NARRATIVES Title NON-UCR SUPPLEMENTAL Created By / On KEVIN CRAMER 09/04/2014 Updated By / On kevinc 09/04/2014 Approve By / On Supplemental Narrative by Ofc. Cramer 1824 on 09/04/2014: I returned a phone call from Barbara Turk who better explained the incident with Jason Snyder. Turk stated that she engaged Jason Snyder as her dog walker/sitter because she was given his information from two of her co-workers, Debra Bauer and Shannon Weise. I asked Turk to have both of them contact me through County. Turk stated that on the day of the incident Snyder arrived at her home with her dog, Rose, wrapped up in bandages. He explained that she had tried to take a bone from another dog and that dog had attacked her. He also told her that he had tried to take the dog to his veterinarian but was unable to. When she and her husband suggested that they take the dog to the animal emergency center, Snyder told them not to because the dogs injuries weren't that bad. She took the animal to the animal emergency center in spite of Snyder's objection and the vets there had serious concerns that the animal would live. When Turk contacted Snyder about the dogs condition, and to ask that he return her collar, he told her that he thought the animals injuries were bad. He did offer to pay for the medical bills, for which Turk gave an estimate of cost of $2,000.00. Additionally, Turk stated that she had left her dog in Snyder's care while on vacation sometime last year and the dog had sustained to small injuries on its back. She shared her concerns with Snyder at the time but decided not to take it beyond their conversation. Nothing further. PAGE 3 LA -14-05632 09/03/2014 • APPROVED BY: IRF 1.6 APPROVED ON: EXHIBIT "E" DOG LICENSE OFT" 2011 DATE ISSUED /O/ Y-/) DOGS NVAME V I r) Yi NEUTEREt SPAYED • MALE MALE FEMALE FEMALE EC $845 $5.4 $8.45 $6.45 FREE ,?. 0 0 0 -6' NC . No. ' q 7 5-- / &S -D . PHONE a C1J-13En Ai0 COUNTY DOG'S AGE K BREED OWNER'S NAME AND ADDRESS 1 ri 02295 YLt VY) COLOR, o DO SPOTTED WHITE BLACK OTHER. L))7 ciasi.A.A,\c....Q.JLL)ct& C. (011 TREASURER 10 1-0!. C; GP.35S ▪ , ISSUED BY COUNTY TREASURERS OFFICE •.1 IN3 DATE tb ISSUED /0 y-fi cum kiERLAND co DOG'S'2 • DOG'S NAME AGE MALE $8.45 0 IS PHONE • NC No. N OWNER'S Cr) NAME AND -11 ADDRESS X • DOG LICENSE FOR 2011 BREED OWNER'S COPY COUNTY • 02296 COLOR NEUTERED SPAYED MALE FEMALE FEMALE $6.45 $8.45 $6.45 FREE 0 0 0 00 SPOTTED WHITE BLACK OTHER Lf ( 7 02.32-i48a, • cisc- • I TREASURER JOHN C GROSS ISSUED BY COUNTY TREASURERS OFFICE 0 r 0 OWNER'S COPY DOG LICENSE F,FA',ZHE 2011 DATE ISSUED DOG'S F4 NAME • MALE Lu • PHO$80N. 4E5 ft A/C OWNER'S NAME AND ADDRESS CUMBElLAND 1st 1/ AGE DOG'S NEUTERED SPAYED MALE FEMALE FEMALE 56.45 58.45 6.4- FREE 0 0 0 BREED' No. COUNTY 02297 2 e COLOR o El SPOTTED WHITE OTHER ( 2 Cc,&-V.&-LQ,Q_ LO 9Lc, fort TREASURER JOHN C.. GROSS ISSUED BY COUNTY TREASURER'S OFFICE DOG LICENSE YrAkfRrHE 2011 DATE ISSUED /c-//!) CUMBEaLiNo g DOG'S cs,A NAME 0, CD LIJ MALE 58.45 PHONE AIC OWNER'S NAME AND ADDRESS Lc - DOG'S AGE ' BREED NEUTERED SPAYED MALE . EMALE FEMALE 55.45 58.45 56.4 FREE n 0 0 No. q 2 S i cVC) OWNER'S COPY. COUNTY • 022913 COLOR 0 0 0 SPOTTED WHITE BLACK OTHER 5 c? 7''2 tCCL ckDceee2 jj TREASURER Antim fl ISSUED BY COUNTY TREASURER'S OFFICE OWNERS CORY I, Kevin Cramer, Police Officer for the Township of Lower Allen and authorized representative for the Township of Lower Allen, verify that the statements made in this Petition are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: a VAVp.e. 1 W ./Kevin Cramer VERIFICATION VERIFICATION I, John M. Eby, Building and Zoning Coordinator for the Township of Lower Allen and authorized representative for the Township of Lower Allen, verify that the statements made in this Petition are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: 9 /a3/14 . Eby VERIFICATION I, Thomas Gelnett, Police Officer for the Township of Lower Allen and authorized representative for the Township of Lower Allen, verify that the statements made in this Petition are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: {,/a 3 / ao a!/ eS Thomas Gelnett VERIFICATION 1, Linda Hockenberry, Complaints Coordinator for the Township of Lower Allen and authorized representative for the Township of Lower Allen, verify that the statements made in this Petition are true and correct to the best of my knowledge, information and belief 1 understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Dated: !1`'/'y Linda Hockenberry Lower Allen Township, Plaintiff PENNSYLVANIA CIVIL ACTION r:LED - OF F ICE IN THE COURT OF COMMON PLEAS OF OF THE PROIHONO TAR)/ CUMBERLAND COUNTY, PENNSYLVANIA Pt OCT '-'13 AM 8: 56 Docket No. 2011-7665 CUMBERLAND COUNTY v. (In equity) Jason M. Snyder and Isabel E. Snyder, Defendants Honorable Merle L. Ebert, Jr. ORDER AND NOW, this 7 day of OadA";2014, upon consideration of the foregoing Petition, it is hereby ordered that (1) A Rule is issued upon Defendants to show cause why Petitioner is not entitled to the relief requested; (2) Defendants shall file an Answer to the Petition within 9 days of this date; (3) The Petition shall be decided under Pa.R.C.P. No. 206.7; (4) An evidentiary hearing on disputed issues of material fact shall be held on a,461:004\frin Courtroom a of the eltfilieritqa County Courthouse.; and (5) TY ution: Notice of the entry of this Order shall be provided to all parties by Plaintiff. J. Steven P. Miner, Esquire, Matthew B. Werner, Esquire, Daley Zucker Meilton & Miner, LLC, 635 N. 12th Street, Suite 101; Solicitor for Plaintiff ----"<"-Cimberly M. Colonna, Esquire, McNees Wallace & Nurick, LLC, PO Box 1166, Harrisburg, PA 17108; Attorney for Defendant Isabel E. Snyder M. Snyder, 417 Allendale Way, Camp Hill, Pennsylvania 17011; Defendant Co,p Ces /0/E3A4( ..�_•_ i E svf.... Steven P.Miner,Esquire THE PROTHO°NOt +I\ Matthew B. Werner,Esquire Daley Zucker Meilton&Miner, LLC 2 I i OCT 17 AM 8 29 635 N. 12`x' Street, Suite 101 CU BE CLANG COUNT'S Lemoyne, PA 17043 PENNSYLVANIA (717)724-9821 sminer@,dzmmlaw.com IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA Lower Allen Township, • Docket No. 2011-7665 Plaintiff : • CIVIL ACTION vs. • (In equity) Jason M. Snyder and Isabel E. Snyder, : Defendants • Honorable Merle L.Ebert,Jr. EXHIBIT LIST AND NOW,the Plaintiff,Lower Allen Township,advises the Court and parties that it will be introducing the following exhibits: 1. The 2011 Injunction Order; 2. The police report of August 24, 2014. 3. The police report of September 3rd; 2014. 4. Certified record from the Township Tax Collector indicating that there were no dog licenses issued for animals owned by Jason M. Snyder or Isabel Snyder after 2012. Respectfully submitted, Daley Zucker Meilton &Miner,LLC / 4 //�^ (A 9'/i� / Date: 101 ? I By:/.'(�! Steven P. Miner,Esquire Supreme Court I.D. # 38901 Matthew B. Werner,Esquire Supreme Court I.D. #313499 635 North 126 Street, Suite 101 Lemoyne,PA 17043 (717)724-9821 Solicitor for Plaintiff,Lower Allen Township F!LED-OFFICE �� THE PROTHONOTARY 2014 OCT 16 PH 12: 13 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA LOWER ALLEN TOWNSHIP, Plaintiff V. Docket No: 11-7665 Civil CIVIL ACTION JASON M. SNYDER AND ISABEL E. SNYDER, (In Equity) Defendants ISABEL SNYDER'S ANSWER TO PETITION FOR CONTEMPT Isabel Snyder, by and through her counsel, files the following Answer to the Plaintiff's Petition for Contempt: 1. Admitted upon information and belief. 2. Denied. Although Jason Snyder sometimes stays at 417 Allendale Way, Camp Hill, PA, he resides elsewhere. By way of further answer, Jason Snyder is the son of Isabel Snyder. 3. Admitted. By way of further answer, Clayton Snyder holds a Durable General Power of Attorney for Isabel Snyder. 4. Admitted with clarification. The Township's complaint was filed on October 6, 2011. 5. Isabel Snyder admits that an Order was entered on October 11, 2014. The remaining allegations are denied, as the Order is a writing that speaks for itself. 6. Isabel Snyder admits that an Order was entered on October 11, 2014. The remaining allegations are denied, as the Order is a writing that speaks for itself. 7. Denied. After reasonable investigation, Isabel Snyder lacks sufficient information and knowledge to form a belief as to the truth of the allegations of this paragraph. Therefore, the allegations are denied. 8. Denied. After reasonable investigation, Isabel Snyder lacks sufficient information and knowledge to form a belief as to the truth of the allegations of this paragraph. Therefore, the allegations are denied. 9. Denied. After reasonable investigation, Isabel Snyder lacks sufficient information and knowledge to form a belief as to the truth of the allegations of this paragraph. Therefore, the allegations are denied. 10. Denied. After reasonable investigation, Isabel Snyder lacks sufficient information and knowledge to form a belief as to the truth of the allegations of this paragraph. Therefore, the allegations are denied. 11. Denied. After reasonable investigation, Isabel Snyder lacks sufficient information and knowledge to form a belief as to the truth of the allegations of this paragraph. Therefore,the allegations are denied. 12. Denied. After reasonable investigation, Isabel Snyder lacks sufficient information and knowledge to form a belief as to the truth of the allegations of this paragraph. Therefore, the allegations are denied. 13. Admitted that an Incident Report Form is attached to the Petition for Contempt as Exhibit C. As to the remaining allegations of this paragraph, after reasonable investigation, Isabel Snyder lacks sufficient information and knowledge to form a belief as to the truth of the allegations of this paragraph. Therefore,those allegations are denied. 14. Admitted that an Incident Report Form is attached to the Petition for Contempt as Exhibit D. The allegations regarding the content of Exhibit D are denied as that Exhibit is a writing that speaks for itself. As to the remaining allegations of this paragraph, after reasonable investigation, Isabel Snyder lacks sufficient information and knowledge to form a belief as to the truth of the allegations of this paragraph. Therefore,those allegations are denied. 15. Does Isabel know how many dogs Jason owns? 16. Denied. After reasonable investigation, Isabel Snyder lacks sufficient information and knowledge to form a belief as to the truth of the allegations of this paragraph. Therefore, the allegations are denied. 17. Admitted. 18. Denied. The averments of this paragraph constitute conclusions of law to which no response is required. To the extent that a response is deemed necessary, Isabel Snyder denies that she has acted in contempt of the Court's Order for the following reasons: (a) Isabel Snyder's conduct was not volitional. In order for a party to be held in contempt of a court order, the petitioner must prove that(1)that the contemnor had notice of the specific order or decree which he/she is alleged to have disobeyed; (2) that the act constituting the contemnor's violation was volitional; and (3) that the contemnor acted with wrongful intent. Lacahat v, Hinchcliffe, 769 A.2d 481, 489 (Pa. Super. 2004). Isabel Snyder did not bring any of the dogs to her property at 417 Allendale Way, Camp Hill, PA; the dogs were brought to her property by Jason Snyder. Isabel Snyder is 86-years old, is physically frail, and sometimes suffers from confusion and memory lapses. Ms. Snyder did not recall that there was a court order prohibiting her from having any dogs at her residence other than dogs that she and Jason own. Isabel Snyder has not willingly chosen to do any act or permit any act that constitutes a violation of the Court's Order. Therefore, Isabel Snyder cannot be held in contempt. (b) Isabel Snyder did not act with wrongful intent. Isabel Snyder incorporates paragraph 18(a) of her Answer. For the reasons set forth in that paragraph Isabel Snyder did not act with wrongful intent. 19. Denied. Isabel Snyder denies that the Township is entitled to the relief requested. 20. Denied. The averments of this paragraph constitute conclusions of law to which no response is required. WHEREFORE, Isabel Snyder requests that the Court deny the Township's Petition to hold Defendant Isabel Snyder in contempt of the Court's October 14, 2014 order. McNEES WALLACE &NURICK LLC By Kim r y M. Colonna PA 80362 100 Pine Street P.O. Box 1166 Harrisburg, PA 17108 (717) 237-5284 Attorneys for Defendant Isabel E. Snyder Dated: October 15, 2014 VERIFICATION Subject to 18 Pa. C.S. § 4904, relating to unsworn falsification to authorities, I verify that that the facts set forth in the foregoing document are true and correct to the best of my knowledge or information and belief. v�. Isaf�Oer by Clayton Snyder, POA Dated: October /_5-, 2014 CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing document was served on the date indicated below by first class mail, postage prepaid, addressed as follows: Steven P. Miner, Esq. Daley, Zucker Meilton& Miner, LLC 635 N. 12th Street, Suite 101 Lemoyne, PA 17043 Attorney for Lower Allen Township Jason M. Snyder 417 Allendale Way Camp Hill, PA 17011 Defendant Dated: 10/15/14 i be". Colonna LOWER ALLEN TOWNSHIP, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. JASON M. SNYDER AND ISABEL E. SNYDER, DEFENDANTS : NO. 11-7665 CIVIL ORDER OF COURT AND NOW, this 17th day of October, 2014, the parties, Lower Allen Township, Jason M. Snyder and Isabel E. Snyder as defendants and Clay Snyder as POA for Isabel Snyder hereby stipulate in accordance with and in clarification of the October 14, 2011, stipulation and Order of Court agree to the following: 1. Defendants will have not more than 4 dogs, owned by them at 417 Allendale Way, Camp Hill, specifically including Lilu (German Shepard), Cinder (German Shepard), Shelley (boxer), and Vinny (boxer mix); and 2. These and/or any replacement dogs shall be shall be properly licensed at all times, but at no,time will the number of dogs exceed 4; 3. Lower Allen Township shall have a reasonable right to conduct inspections of 417 Allendale Way, between the hours of 7:00 a.m. and 700 p.m. to monitor the compliance with this stipulation and Court Order. 4. In the event of a first violation, notice shall be given by Lower Allen Township, via email and/or cell phone call to Clay Snyder and via phone or written notice, or in person to Jason Snyder. The parties shall have a period of 5 days to cure the violation. 5. In the event of a second or further violation of this stipulation and Court Order, Defendants jointly and severally shall be liable for a penalty of $10,000 for each violation. 6. The assessment of the penalty will be made by municipal lien against the property located at 417 Allendale Way, Camp Hill, PA. 7. A violation of this stipulation can be established by an Affidavit of a Municipal Law Enforcement Officer stating facts sufficient to show that a violation of this stipulation occurred. 8. Jason Snyder and Isabel Snyder's POA agree to provide and maintain their current contact information to the Township for purposes of the stipulation. The Undersign / agree as above: Jason nyder 80.2 -e -eta 4 Isabel E. Snyder CI.��'yder as POA for Isabel By the Court, M. L. bert, Jr.,