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LAW OFFICES OF PETER J. RUSSO, P.C.
Peter J. Russo, Esquire �
Attorney I.D. No. 72897
5006 East Trindle Road, Suite 203 ,
Mechanicsburg, PA 17050
Telephone: 717-591-1755 ,
Attornevs far Petitioners
JAMES E. KAUFFMAN, . IN THE COURT OF COMMON PLEAS
Principal/Respondent . CUMBERLAND COUNTY, PENNSYLVANIA
v. . CIVIL ACTION - LAW ca '`'
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BARBARA MURRAY and . � �
� ° �
RICHARD SMITH, . NO. 21-12-846 _' = ��
� ._ . .
Petitioners . � �
PETITION FOR CONTEMPT
AND NOW COMES the Petitioner, Barbara Murray, by and through her attorneys The
Law Offices of Peter J. Russo, P.C. and avers the following in support of her Petition for
Contempt:
1. The Petitioner is Barbara Murray, an adult individual with a current residence of 107
Hollow Lane, Dillsburg, York County, Pennsylvania 17019.
2. The Respondent/Principal is James E. Kauffman (hereinafter referred to as "Mr.
Kauffman"), age 88, with a current residence of Country Meadows, 4905 East Trindle
Road, Room 95, Mechanicsburg, Cumberland County, Pennsylvania 17050.
3. On November 5, 2012 the Honorable Judge Christylee J. Peck entered an Order in
regards to an Emergency Petition for Guardianship for Incapacitated Person, filed by the
Petitioner Barbara Murray. A true and correct copy of the November 5, 2012 Order is
attached hereto as Exhibit"A."
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LAW OFFICES OF PETER J. RUSSO, P.C.
Peter J. Russo, Esquire
Attorney LD. No. 72897
5006 East Trindle Road, Suite 203
Mechanicsburg, PA 17050
Telephone: 717-591-1755
Attornevs for Petitioners
JAMES E. KAUFFMAN, . IN THE COURT OF COMMON PLEAS
Principal/Respondent . CUMBERLAND COUNTY, PENNSYLVANIA
v. . CIVIL ACTION - LAW
BARBARA MURRAY and .
RICHARD SMITH, . NO. 21-12-846
Petitioners .
PETITION FOR CONTEMPT
AND NOW COMES the Petitioner, Barbara Murray, by and through her attorneys The
Law Offices of Peter J. Russo, P.C. and avers the following in support of her Petition for
Contempt:
l. The Petitioner is Barbara Murray, an adult individual with a current residence of 107
Hollow Lane, Dillsburg, York County, Pennsylvania 17019.
2. The Respondent/Principal is James E. Kauffman (hereinafter referred to as "Mr.
Kauffman"), age 88, with a current residence of Country Meadows, 4905 East Trindle
Road, Room 95, Mechanicsburg, Cumberland County, Pennsylvania 17050.
3. On November 5, 2012 the Honorable Judge Christylee J. Peck entered an Order in
regards to an Emergency Petition for Guardianship for Incapacitated Person, filed by the
Petitioner Barbara Murray. A true and correct copy of the November 5, 2012 Order is
attached hereto as Exhibit "A."
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4. The November 5, 2012 Order issued by the Honorable Judge Christylee J. Peck directed
Petitioner to "submit copies of his bank account statements for the aforementioned Metro
Bank and Members 1 St Federal Credit Union accounts to Respondents each month."
5. On February 14, 2013 Judge Peck entered an Order amending the November 5, 2012
Order, requiring the Respondent James Kauffman to only have access to his Members 1 st
Federal Credit Union bank account in the sum of Three Thousand Five Hundred
($3,500.00) Dollars each month, for use of paying bills, medication, and other necessary
expenses. A true and correct copy of the February 14, 2013 Order is attached hereto as
Exhibit `B."
6. The Order further stated that the access to the funds was conditional upon Mr. Kauffman
providing copies of paid bills with respect to medical and prescription bills, real estate
and income taxes and professional fees to opposing counsel within thirty (30) days of the
payment of the bill.
7. However, the Order stated that Mr. Kauffman is not required to provide an accounting of
Seven Hundred Fifty ($750.00) Dollars of the Three Thousand Five Hundred ($3,500.00)
per month to Counsel.
8. Since the February 14, 2013 Order, Mr. Kauffman has only provided Undersigned
Counsel with copies of some, but not all prepaid bills, on three (3) occasions.
9. Undersigned counsel has not received the Court Ordered prepaid bills from Mr.
Kauffman or his legal representative Andrew C. Seeley since May of 2013.
10. Mr. Kauffman's failure to provide prepaid bills to Undersigned counsel places Mr.
Kauffman in contempt of the February 14, 2013 Order.
, .
11. As a result of Mr. Kauffman's actions, Mr. Kauffman is in contempt of the February 14,
2013 Order for withdrawing funds in excess of his monthly Three Thousand Five
Hundred ($3,500.00) allocation.
12. It is believed and therefore averred that Mr. Kauffman is also in contempt of this Court
due to the amount of money being withdrawn each month, well outside the limit imposed
by this Honorable Court's Order.
13. Bank statements obtained by the Petitioner exhibit that Mr. Kauffman withdrew in excess
of Five Thousand Five Hundred Eighteen ($5,518.76) Dollars between June 3, 2013 and
June 30, 2013. A true and correct copy of the transaction summary for Checking Account
ending in 0371 is attached hereto as Exhibit"C."
14. Specifically, Mr. Kauffman withdrew Three Thousand Five Hundred ($3,500.00) Dollars
as a cash withdrawal on June 3, 2013.
15. Additional draft withdrawals totaling Two Thousand Eighteen ($2,018.76) Dollars were
made in the month of June.
16. Mr. Kauffman did not deposit the excess funds withdrawn into the account at any time in
the future.
17. Petitioner is concerned that Mr. Kauffman is frivolously spending funds which have been
predetermined to pay for necessary medical and personal expenses.
18. In the last 14 months, Mr. Kauffman has monthly received $7,266.00 in Social Security
($519.00 per month); $44,747.92 from an annuity ($3,196.28 per month); $9,000.00
from the sale of his vehicle; $9,000.00 from the sale of a PNC annuity and $3,000.00
from the sale of bonds for a total in excess of$ 73,000.00.
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19. It is believed, therefore averred that as of Friday, September 6, 2013, Mr. Kauffman had
approximately $15,000.00 in his Members 1 st account.
20. Mr. Kauffman should have increased his savings substantially; instead his accounts have
been depleted.
21. Mr. Kauffman has only provided sporadic monthly bank account statements compared to
the monthly requirement established by the Court in the November 5, 2011 Order.
22. Petitioner has calculated that at the current rate of spending by Mr. Kauffman, without
any enforcement by this Court, that Mr. Kauffman will deplete his financial savings and
allocation for medical care within three (3) years, compared to twelve (12) years if he
were to follow the Court's maximum allocation of funds per month.
23. Mr. Kauffman has provided no receipts or proof of payments which would explain the
large withdrawals from Mr. Kauffman's bank account, such as to explain a personal need
which required funds in excess of the Court Ordered monthly allocation.
24. It is believed and averred that Mr. Kauffman has withdrawn large sums of money in
addition to those amounts averred in this Petition, without Petitioner's knowledge, as Mr.
Kauffman has removed Petitioner from receiving any information through the bank or
other financial institutions.
25. Without the Petitioner being able to properly monitor Mr. Kauffman's spending, Mr.
Kauffman will continue to ignore this Honorable Court's Order and exceed his monthly
allocation of funds.
26. It is believed and therefore averred that Mr. Kauffman will continue to engage in this
reckless pattern of contempt until such time as he has withdrawn his entire bank account,
1
leaving hirn without sufficient funding to allow his continued stay at Country Meadow
Nursing Home.
WHEREFORE, the Petitianer, Barbara Murray, respectfully requests this Caurt to find
Principal/ Respondent in Contempt af this Court and enter the Urder propased by Petitioner
attached as Exhibit D hereto.
submit
BY:
The Law Offices Russo, P.C.
Peter J. Russo, Esquire
Attorney I.D. No. 72$97
5006 E. Trindle Raad, Suite 203
Mechanicsburg, PA 17050
Telephone: (71�} 591-1755
Attarneys for Petitianer
Date: � �3 � � 3
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IN RE: . IN THE COURT OF COMMON PLEAS OF
JAMES E. KAUFFMAN . CUMBERLAND COUNTY, PENNSYLVANIA
Petitioner and Principal .
BARBAR.A MURRAY and RICHARD : ORPHANS ' COURT DIVISION
SMITH, . n ° �
Respondents . NO. 2012-846 ORPHANS' COiJ�b � �'�
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IN RE: RETURN ASSETS �-�+ - �
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ORDER OF COURT p`--. � _.. -,..,
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AND NOW, this 5th day of November, 2012, u �-; o ��=n'
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consideration of agreement of the parties, and after having had�r
this matter been called to a hearing, it is hereby ordered as
follows:
1. Al1 funds transferred from the Petitioner' s
account at Members 1st Federal Credit Union by the Respondents to
Metro Bank shall be transferred and titled to the name of James E.
Kauffman in a separate account at Metro Bank owned by James E.
Kauffman on or before the close of business on November 9, 2012;
and
2 . Upon transfer, all funds titled in the name of
James E. Kauffman at Metro Bank shall be restricted to the use of
James E. Kauffman' s medical, nursing, short or long term care bills
incurred ar. C::ountry Meadow5 Nursing H�me �� any cth°r �°r.i�r �� ----- _
adult care facility providing services for the benefit of James E.
Kauffman, absent further order of Court; and
3 . Respondent shall make Petitioner' s vehicle,
financial records, savings bonds, safe, and all other personal
property available to him for transfer to a secure facility or any
other residence of the Petitioner within a period of 45 days after
the date of this Order of Court.
4 . All monies to be paid to Country Meadows Nursing
Home or any other seniqr or adult care facility providing services
for the benefit of James E. Kauffman shall be paid electronically
.
from Metro Bank directly to the adult care facility institution for
services rendered to or on behalf of James K. Kauffman.
5 . Petitioner may withdraw no more than $750 per
month from his Members lst Federal Credit Union accounts for his
own personal use.
6 . Funds from the Metro Bank accounts shall not be
used for any other purpose other than provided for herein.
7 . Petitioner must submit copies of his bank account
statements for the aforementioned Metro Bank and Members 1st
Federal Credit Union accounts to Respondents each month.
Petitioner must submit the copies to Respondents as provided for
herein no later than 10 days following his receipt in the mail of
the account statements or receipt on-line of his account
statements .
8 . Any interested party may petition for a
modification of this Order of Court at any time for cause shown.
By the Court,
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� — Chris'ty�,ee L. Peck, J. —
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JAMES E. KAUFFMAN, . IN THE COURT OF COMMON PLEAS OF
Respondent/Principal . CUMBERLAND COUNTY, PENNSYLVANIA
v. .
. CIVIL ACTION - LAW
BARBARA MURRAY and, .
RICHARD SMITH, . n �
Petitioners : 21-12-846 CIVIL TERM � Q �,,; � rn
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IN RE: EMERGENCY PETITION FOR GUARDIANSH� ��r� � �
FOR INCAPACITATED PERSON :� �,� � �--� � �
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ORDER OF COURT `-' y` ' `'� '
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AND VGW, 14th day of February, 2013, th�� Order !o� ;�,., �,�
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Court regarding the return of assets dated November 5, 2012, is
hereby amended as follows :
James E. Kauffman shall have access to no more than
$3, 500 per month from his Members lst Federal Credit Union account
to be used for his own personal use to include but not be limited
to the following items : paying medical bills, prescription bills, real
estate and income taxes, professional fees and any other reasonable
and necessary expenses. His access to the $3, 500 is on the
condition that Mr. Kauffman provide copies of paid bills with
respect to medical and prescription bills, real estate and income
taxes and professional fees to opposing counsel, Mr. Russo, within
30 days of the date of the payment of the bill.
Mr. Kauffman need not provide any accounting of $750
of the $3, 500 per month to Mr. Russo . All other terms and
conditions of the November 5, 2012, Order of Court shall remain in
full force and effect except as they conflict with this amending
order.
,�TR!!E CC}PY FRC?�1 RECflRQ
in�'estimvnyt�h+�rof�t hece►�" By the Court,
s,et my han��nc!ttw e�a�i
ef�ki Ceuet at GarMl�.P�t �
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_ , ° �����y-��� � .� s�� �-���
��,..• �prpts�C�t Christyl�e L. Peck, J.
G�nbe�Mnc��Y
.
Andrew C. Sheely, Esquire
�or the Respondent/Principal
Peter J. Russo, �squire
�'or the Petitioners
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�� s�Fld�nq��r�s to: Stafement of Accounts
. 5000 Loulse Drive i
PO Box 40
Mechanicsburg,PA17055 ' M��1 2�J, 2Q13 thru Jun 24, 2Q13
www.memtxrs7st.org
Maln Switchboard: (840)283-2328
E2 Call: (7�7)697-4372 or(800)283-4372 Account Number: 2037
� TdD: (717)697-5312 or(800)283-2328 e�A.5312 ' �_
TeleBreneh: (&04)237-7288
MEMBERS 1St Balances at a Glance: _
FEDERALCREDIT UNiON C�12Ckiflg: � 9,362.57 —
9b67 2 AV 0.360 19333-4667 ', cJc�IV11�1�5: : 32.77
* �..�... ��llllil�l�ili�ilrni���lhF(I�I�lillln�l���ll���li��������n��� , Ce�tificates: 0,00
JAMES E KAUFFMAN LOaC1S: O.00 _
N 49Q5 E TRINDLE RD, RM 215 Maney Management: 0.00
MECHANICSBURG PA 17050
� Swipe 5 YTD ,eward: 0.QO
� i
o ;Page: 1 of 2
Your aggregate balance as of June 1st is $10,242.1a.
An aggregate balance of $2,500 and having 3 products
wiH piace you in the Silver MLR level.
Go paperless and sign up for eStatements today! '
See the enclosed insert for more details, ,
E
CHECKING ACCOUNTS
OQ11 -CHECKING +
Date Transaction Description Additions Stibtractions Balance
May 25 BaJance Forward ; 10,208.89
May 31 Deposit Dividend 0.050% 0.44 10,209.33
Annual Percentage Y'�e/d Eamed 0.1150�from U5/01/21113 �rough QS/31/2(J13
Based on Average t7aily Ba/ance of 10,428.69 {
Jun 03 Deposit Transfer From Share 0000 519.00 � 10,728.33
Jun 03 Deposit Transfer From Share O(300 3,196.28 i 13,924.61
Jun 03 Withdrawal �,500.00- 10,424.61
Jun 03 Depasit 500.00 ` 10,924.61
Jun 03 Check 002545 Tracer 0000251435 28.50- 10,896.11
Jun 07 Check OQ2547 Tracer 0000247Q21 ;1,665,00- 9,231.11
Jun 13 Check 002548 Tracer 0000372557 13.54- 9,217.5I
--�lun- 17___. .Deposit.___.....__ ____ _. _. .;, ._. .__.. . ._._ ._._-,--._...�..�F4s:fl6------ ;: --: -�,,-. .--=g�,362:�7.�"".,
Jun 24 Ending Ba/ance 9,362.57
CHECK SUMMARY ;
Chedc # Arnount Date Check # Amount Date
�2545 28.50 Jun 03 002548 13.54 Jun 13
002547' 1,665.00 Jun Q7 ' `
' Asterisk ne�t ta number indkates skip Jn number sequenae
3 Checks C/eared for 1,TOT.114
SAVINGS AGCOUNTS �
0000-REGULAR SAVINGS !'
3
Data Transaction Descrit�tion Additiorts Su�tractions Balance
May 25 8a/ance Fonrard 32.77
Jun 03 Deposit ACH XXSOC SEC �-519.00 " 551.77
ID: 9031736026 CO: XXSOC SEC j
Jun 03 Withdrawal Transfer To Share 0011 j 519.00- 32.77
Jun 03 Deposit ACH XXCIV SERV � 3,196.28 i 3,229.05
ID: 3121736156 CO: XXCIV SERV
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LAW OFFICES OF PETER J. RUSSO, P.C.
Peter J. Russo, Esquire
Attorney I.D. No. 72897
5006 East Trindle Road, Suite 203
Mechanicsburg, PA 17050
Telephone: 717-591-175 5
Attornevs for Petitioner
JAMES E. KAUFFMAN, . IN THE COURT OF COMMON PLEAS
Principal/Respondent . CUMBERLAND COUNTY, PENNSYLVANIA
v. . CIVIL ACTION - LAW
BARBARA MURRAY and .
RICHARD SMITH, . NO. 21-12-846
Petitioners .
VERIFICATION
I, Barbara L. Murray verify that the statements made in the foregoing document(s) are true and
correct I understand that false statements made herein are subject to the penalties of 18 Pa.C.S.
§ 4904 relating to unsworn falsification to authorities.
Date: 9��Z� �,S �-�'G^-'lit/� '�{/1i1./1�,�.
B rbara L. Murray J
, ,
LAW OFFICES OF PETER J. RtiSSO, P.C.
Peter J. Russo, Esquire
Attorney LD. No. 72897
5006 East Trindle Road, Suite 203
Mechanicsburg, PA 17050
Telephone: 717-591-175 5
Attorne�s for Petitioner
JAMES E. KAUFFMAN, . IN THE COURT OF COMMON PLEAS
Principal/Respondent . CUMBERLAND COUNTY, PENNSYLVANIA
v. . CIVIL ACTION - LAW
BARBARA MURRAY and .
RICHARD SMITH, . NO. 21-12-846
Petitioners .
VERIFICATION
I, Barbara L. Murray, being familiar with the facts and circumstances in this matter and on behalf
of Richard Smith who is unable and unavailable to execute this verification with an original
signature because he resides in Silver Springs, Maryland, do hereby verify that the statements
made in the foregoing document(s) are true and correct. I understand that false statements made
herein are subject to the penalties of 18 Pa.C.S. § 4904 relating to unsworn falsification to
authorities.
Date: �( I7 �� —
Barbara L. Murray
On behalf of Richard Smith
, ,
LAW OFFICES OF PETER J. RUSSO, P.C.
Peter J. Russo, Esquire
Attorney LD. No. 72897
5006 East Trindle Road, Suite 203
Mechanicsburg, PA 17050
Telephone: 717-5 91-175 5
Attorneys for Petitioner
JAMES E. KAUFFMAN, . IN THE COURT OF COMMON PLEAS
Principal/Respondent . CUMBERLAND COUNTY, PENNSYLVANIA
v. . CIVIL ACTION - LAW
BARBARA MURRAY and .
RICHARD SMITH, . NO. 21-12-846
Petitioners .
CERTIFICATE OF SERVICE
I, Derek M. Strouphauer, Paralegal, hereby certify that I am on this day serving a copy of
the foregoing Praecipe for Entry of Appearance upon the person and in the manner indicated
below and addressed as follows:
United States Regular Mail:
Andrew C. Sheely, Esquire
127 South Market Street
P.O. Box 95
Mechanicsburg, PA 17055 �.-`�_
Date: / �
ere rouphaue , a ega