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HomeMy WebLinkAbout94-01004 l ..~ ,-' ~ - . - E. -i' ;;~ ;>1 ,I '~ ~ IV - --; d '7 j ,) jl Ii f' h ',\. -J' II :11 1, ii' , ;~ ~ \ ! , . , .. -:r , c::r I a-! -I i I 1 \ , I ) J ! , :\' ( ~ i -----' ! ; h, ".",,,.~, ',-.:. ,...._,.. Debra C. Lavalle, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 1004 CIVIL 1994 PROTECTION FROM ABUSE vs. ~ Dou9~S 0...: Q) '" W.-;:"Miller, De,fendant .' - -AND NOW, -. of ~e c,Q!'lsent entered: this day of March, 1994, upon consideration Agreement of the parties, the fOllowing Order is 1. The defendant, Douglas W. Miller, is enjoined from physically abusing the plaintiff, Debra C. Lavalle, or from placing her in fear of abuse. 2. The defendant, Douglas W. Miller, is hereby ordered to stay away from the premises located at 1802 Willow Road, Carlisle, Pennsylvania. The defendant is hereby notified that if he resides in the plaintiff's domicile contrary to this Order, he may be in indirect criminal contempt which is punishable by a fine not to exceed $1,000 and/or by a sentence of up to six months in jail and any other appropriate punishment. Resumption of co-residence .on the part of the plaintiff and defendant shall not nullify the provisions of the court order directing the defendant to refrain from abusing the plaintiff. 3. The defendant, Douglas W. Miller, is ordered to stay away from any residence the plaintiff may establish for herself in the future. 4. The defendant is ordered to refrain from having any contact with the plaintiff including, but not limited to, entering the plaintiff's place of employment. 5. The defendant is ordered to refrain from stalking the plaintiff and from harassing the plaintiff or her relatives. 6. The defendant is ordered to pay $21.00 to the plaintiff for out-of-pocket losses. The defendant shall pay the plaintiff no later than ten days after the entry of this order. 7. This Order shall remain in effect for a period of one year. 8. The Carlisle and North Middleton Township Police Departments will be provided with a copy of this Order by attorneys for plaintiff. This Order shall be enforced by any law enforcement agency when a violation occurs by arrest for indirect criminal contempt. The arrest may be without warrant upon probable cause that this Order has been violated, whether or not the violation is committed in the presence of the police officer. In the event that an arrest is made under this section, the defendant shall be taken without unnecessary delay before the court that issued the Order. When that court is unavailable, the defendant shall be taken before the appropriate district justice. (23 P.S. Section 6113). By the Court, /'\ (J. ; . il""'."'.~~. Debra C. Lavalle, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW vs. : : NO. 1004 CIVIL 1994 Douglas W. Miller, Defendant : : PROTECTION FROM ABUSE CONSENT AGREEMENT This Agreement is entered on this Id~ day of March, 1994, by the plaintiff, Debra C. Lavalle, and the defendant, Douglas W. Miller. The plaintiff is represented by Joan Carey of Legal Services, Inc.; the defendant is unrepresented but is aware of his right to have an attorney. The parties agree that the following may be entered as an Order of Court. 1. The defendant, Douglas W. Miller, agrees to refrain from abusing the plaintiff, Debra C. Lavalle, or from placing her in fear of abuse. 2. The defendant agrees to refrain from having any contact with the plaintiff, inclUding but not limited to, entering the plaintiff's place of employment. 3. The defendant agrees not to stalk the plaintiff or harass the plaintiff or her relatives. 4. The defendant agrees to stay away from the residence located at 1802 Willow Road, Carlisle, Pennsylvania. 5. The defendant agrees to stay away from any residence the plaintiff may establish for herself in the future. .' 6. The defendant agrees to pay $21.00 to the plaintiff for out-of-pocket losses. The defendant agrees to pay the plaintiff no later than ten days after the entry of this order. [,~. .,....'.. 'tii.:-'-" , 7. The defendant, although entering into this Agreement, does not admit the allegations made in the Petition. 8. The defendant understands that the Protective Order entered in this matter shall be in effect for a period of one year. 9. The defendant understands that this Order will be enforceable in the same manner as the Court's prior Temporary Protective Order entered in this case. WHEREFORE, the parties request that the Order entered to reflect the above terms. of Court be J)--vk~, )1~ Douglas W. Miller, Defendant o'an Carey Attorney for Pl intiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 r:' ~.... Debra C. Lavalle Plaintiff IN TilE COURT OF COMMON PI.EAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. I DO Y CIVIL 1994 v. Douglas W. Miller, Defendant PROTECTION FROM ABUSE AND NOW, this TEMPORARY PROTECTIVE ORDER 2.. L day of March, 1994, upon presentation and consideration of the within Petition, and upon finding that the plaintiff, Debra C. Lavaile, now temporariiy residing at 1802 Wiilow Road, Carlisle, Cumberland County, Pennsylvania, is in immediate and present danger of abuse from the defendant, Douglas W. Miller, the following Temporary Order Is entered. The defendant, Dougias W. Miller, now residing at 440 Fairground Avenue, Cariisle, Cumberland County, Pennsylvania, Is hereby enjoined from physically abusing the plaintiff, Debra C. Lavalle, or placing her in fear of abuse and is ordered to stay away from the residence located at 1802 Willow Road, Carlisle, Cumberland County, Pennsylvania, a residence which is owned by the plaintiff's parents and the defendant has never resided there. The defendant is hereby notified that if he resides in the plaintiff's domicile contrary to this Order, he may be in indirect criminal contempt which is punishable by a fine not to exceed $1,000.00 and/or by a sentence of up to six months in jail and any other appropriate punishment. Resumption of co-residence on the part of the plainti ff and the defendant shall not null i fy the prov isions of the court order directing the defendant to refrain from abusing the plaintiff. The defendant is ordered to refrain from having an)' contact with the plaintiff Including, hut nol. limited to, restraining the defendant from entering the plaintiff's place of employment, from stalking t.he plaintiff, or from harassing the plaintiff, or the plaintiff's relatives. The defeadant is ordered to refl'aln from destroying or damaging any property own~d by the plaintiff or any property Jointly owned by the parties. This Order shall remain in effect until a final order is entered in thh: case. A hearing shall be held on this matter on the II~ day of March, ,j " "() 1994, at ~.... lL.m. In Courtroom No.~, Cumberland County Courthouse, Carlisle, Pennsylvania. The plaintiff may proceed in I9.I:m!! pauperis pending a further order after the hearing. The Cumberland County Sheriff's office shall attempt to make service at the plaintiff's request, but service may be accomplished under any applicable rule of Civil Procedure, The Carlisle and North Middleton Township Police Departments will be provided with a copy of this Order by attorneys for plaintiff. This Order shall be enforced by any law enforcement agency when n violation occurs by arrest for indirect criminal contempt. The arrest may be without warrant upon probable cause that this Order has been violated, whether or not the violation is committed in the presence of the police officer. In the event that an arrest is made under this section, the defendant shall be taken without unnecessary delay before the court that issued the Order. When that court is unavailable, the defendant shall be arraigned before the appropriate district Justice. (23 Pa.C.S.A. Section 6113). By the Court, ~. r /1 l.(/ry3 t. () ~~; , r;J. ,w . ,. Debra C. Lavalle Plaintirf IN Tm: COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA v. CIVIL ACTION - I.AW NO. /OtJ t.f CIVIl. 1994 Douglas W. MIller. Defendant PROTECTION FROM ABUSE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action promptly after this Petition, Order and Notice are served, by appearing personally or by attorney at the hearing scheduled by the Court and presenting to the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the Court may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed In the Petition 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 OR TELEPHONE THE OFFICE SET FORTlI BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HEI.P. COURT ADMINISTRATOR, 4TH FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 240-6200 r,- ... -C{~, . . t:lIli!IIi...;,~~:~ Debra C. Lavalle Plaintiff IN TIlE COURT OF COMMON PI,EAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. /00,/ CIVIL 1994 v. Douglas W. Miller, Defendant PROTECTION FROM ABUSE PETITION FOR PROTECTIVE ORDER RELIEF UNDER TlfE PROTECTION FROM ABUSE ACT. 23 Pat C.S.A. Section 6101 et. sea. A. ABUSE 1. The plaintiff is an adult individual whose permanent address is 440 Fairground Avenue. Carlisle, Cumberland County, Pennsylvania, 17013. 2. The plaintiff is temporarily staying at her parents' residence which is located at 1802 Willow Road, Carlisle, Pennsylvania. 3. The defendant is an adult individual residing at 440 Fairground Avenue, Carlisle, Cumberland County, Pennsylvania, 17013. 4. The defendant has had an intimate relationship with the plaintiff. 5. Since approximately December 1992, the defendant has attempted to cause and has intentionally, knowingly, or recklessly caused bodily injury to the plaintiff and by physical menace has placed the plaintiff in fear of imminent serious bodlly injury. This has. included but is not limited to the following specific instances of abuse: a. On or about February 21, 1994, the defendant pinned the plainti ff down, straddled her body, and forcefully slapped her across the face causing her to have a bloody nose, n swollen lip, bruises on the side of ber face, and extreme pain in her left ear. b. On or "bout Februllry 101, 1994, the defendant threw the plaintiff's microwave on the rIoor and hroke It, he threw several glass mugs and broke theil, and burned some shirts that belonged to tho pl/llntlff's co-worker. lie also went upstairs /lnd threll the plaintiff's clot.hes, plants, and jewelry box. The Carlisle police hsd been culled several t.imes during this incident. The defendant called the Carl isle Police one time, t.old them that he had a gun, that he was going to shoot, and that he was armed and dangerous. The plaintiff took some of her belongings and left the residence. c. In or about February, 1994, the defend/lnt smashed the plaintiff's blender with a humer, and swung the hammer at the plaintiff's head missing her head and denting a wall. The defendant then threw a remote control, cracking a plexiglass door, and threatened to "bust her head In.'' Fearing for her safety, the plaintiff went upstairs to bed. The defendant came into the room, turned on the light, and told her I f she turned the light off he would smash the light bulbs allover her. d. On or about January 25, 1994, the defendant slapped the plaintiff across the face twice and pushed her down onto the floor. When the plaintiff got up, the defendant called her vile names and continued to push her causing her to fear for her safety. e. Since December 1992, on several different occasions, the defendant has kicked the plaintiff in the hip, punched her in the back, and thrown objects at her. 6. On or about February 14, 1994, the plaintiff and her child left their residence at 440 Fairground Avenue, Carlisle, Cumberland County, Pennsylvania In order to avoid further abuse. 7. The plaintiff helleves and therefore avers that she will be in Immediate and present danger of abuse from the defendant and that she Is In need of protection from such abuse. 8. The plaintiff desires t.hat the defpndant be ordered to refrain from ~,," ! r;;jo"'~ ":::-r:i-- ~j~, "c ''",..~,~,.._ having any contact with her Including, but not limited to, entering her place of elllployment, business or school, frolll stalking the plaintiff, and from harassing the plaintiff, or her relatives. 9. The plaintiff desires that the defendant be ordered to refrain from destroying or dalllaging any property owned solely by the plaintiff or jointly by the parties. B. EXCLUSIVE POSSESSION 10. The home which the plaintiff is asking the Court to order the defendant to stay away from is owned In the names of the plaintiff's parents. 11. The defendant has his own residence located at 440 Fairground Avenue, Carlisle, Pennsylvania. C. LOSSES AND ATTORNEY FEES 12. The plaintiff has suffered losses as a result of the abuse by the defendant. The losses are listed on Exhibl t A attached. 13. The plaintiff asks that the defendant be ordered to pay reasonable attorney fees pursuant to the Protection from Abuse Act. D. STATUS TO PROCEED IN FORMA PAUPERIS 14. The defendant Is unemployed. 15. The plaintiff Is employed at Carlisle Tire and Rubber and has a gross weekly salary of approximately $300.00 and has recently begun receiving support in the amouut of approximately $60.00 per week. 16. The plaintiff does not have funds available to pay the fees for filing and service. WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of October 7, 1976, 23 Pa.C.S.A. Section 6101 at seQ., as amended, the plaintl ff prays this Honorable Court to grant the following relief: A. Grant a Telllporary Order puraunnt 1.0 the "Protection from Abuse Act": f' , '1' , L I I" '1.: ')"'1 :< ,i {~:r; 3'\ .' I", I, I j'>. 1. Requiring the defendant to refrain from abusing the plaIntiff or piaclng her In fear of abuse. 2. Requiring the defendant to refrain from having any contact with the plaintiff Including, but not limited to, restraining the defendant from entering the plaintiff's place of employment, from stalking the plaintiff, and from harassing the plaintiff, or her relatives. 3. Ordering the defendant to stay away from the residence located at 1802 Willow Road, Carlisle, Pennsylvania pending a final order in this matter. 4. Ordering the defendant to stay away from any residence the plaintiff may In the future establish for herself. 5. Ordering the defendant to refrain from destroying 01' damaging any property owned by the plaintiff 01' any property owned jointly by the parties. B. Schedule a hearing In accordance with the provisions of the "Protection from Abuse Act," and, after such hearing, enter an order to be in effect for a period of one year: 1. Requiring the defendant to refrain from abusing the plaintiff or placing her in fear of abuse. 2. Requiring the defendant to refrain from having any contact with the plnlntlff inclndlng, but not limited to, restraining the defendant from entering the plaintiff's place of employment, from stalking the plaintiff, nnd from harassing the plaintiff, or her relatives. 3. Ordering the defendant to stay away from the residence located at 1802 Willow Road, Cnrl isle, Pennsylvania. "'<4*"',", ,. '. ,;..,>< ~it ~~: :rr':'~-.<, 4. Ordering the defendnnt to stny away from any residence the plaintiff may In the future establish for herself. 5. Ordering the defendant to refrain from destroying or damaging any property owned by the plaintiff or any property owned jointly by the parties. 6. Ordering the defendnnt to reimburse the plaintiff's out-of- pocket losses suffered as a result of the abuse including but not limited to the losses listed on the attached sheet marked Exhibit A. 7. Ordering the defendant to pay reasonable attorney fees. The plaintiff further asks that this Pet! tion be filed and served without payment of costs, pending a further order at the hearing, and that a copy of this Petition and Order be delivered to the Carlisle and North Middleton Township Pollee Departments I1S the Pollee Departments with jurisdiction to enforce this Order. The plaintiff prays for such other relief as may be just and proper. Respectfully submitted, JotRl' r:~ ~ ~ Philip C. Brigant:~ Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ,- Debra C. Lavalle Plaintiff IN TilE COlJRT OF COMMON PLF,AS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - I.AW v. : NO. CIVII. 1994 Douglas W. Miller, Defendant PROTECTION FROM ABUSE OUT-OF-POCKET LOSSES The plaintiff requests that the defendant pay for the costs of replacing items damaged or destroy during the incident on or about February 14, 1994. The items and estimated costs to be repiaced Include, but are not limited to, the following: I.mI APPROXIMATE COST Electric Blender $ 288.00 21. 00 25.00 Microwave China plates and glasses 3 Home Interior Pictures 60.00 Total 85.00 479.00 5 Work shirts Exhibit A ~::r;,"?'~"',:", " ,." ~'~:~ ;,~lIIOaJ.:,:'~ The above-named plaintiff, Debra C. Lavallc, vcrlflcs that the statements made In the above Petition are true and correct. The plaintiff understands that false statements hercln arc made subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorltlcs. Date: 3-1- 9( ror ,;.;-- ~";~,,,",,. ~ ?; ~ ~ "'" -..; ~ ... ll'; ...~ : Cl o '" lJ) ,: ~'Y) @:fJ I ~l;\" ~-,<,l"t!. SHERIFF'S RETURN CCMI1ONWEAL'lll OF PENNSYLVANIA. COUNTY OF ClMBERLAND In the Court of Common Pleas of Cumberland County, Pennsylvania No. 1004 Civ 11 Term 1994 Temporary Protective Order Protection From Abuse Notice & Petition Debra C. Lavalle VS Douglas W. Miller Michael Barrick , ~l[Ul6t Deputy Sheriff of Cunberland County, Pennsylvania, who being duly sworn according to law, says, that he served the within Temporary Protective Order Protection From Abuse, Notice and Petition , the defendant, at 11:05 o'clock upon Douqlas W. Miller A .M. EST / DS'K, on the 02 day of March , 19_2.:1:lt 440 Fairqround Ave.. Carlisle , Cunberland County, Pennsylvania. by handing to Douglas W. Miller a true and attested copy of the Tem orary Abuse and his Protective Order Protection Frpm Notice and Pet~t on attention to the contents thereof and and at the same time directing the "Notice to Plead" endorsed thereon. Sheriff's Costs. Docketing Service Affidavit Surcharge 14.00 2.80 So answers I r~?W~~~~ :7~~ /- Deputy Sh . 2.00 18.80 Sworn and subs=ibed to before me this g'f: day of 7h.<........L/ 19 'l'1 A.D. (17'" , Prothonotary C, fir... i~,~ <.(ii~ ' . , I CRIMINAL COMPLAINT (POLICE) DISTRICT JUSTICE MAGISTERIAL DISTRICT NO. Complaint Numberlll Other Participants A 95982 I Patrolman Alan R. Mace Badge No.III9 . ("'a,"~IIIAll1a"l) of The Carlisle Borough Police Dept. ( !lA'ntlfl' dC'f"lrtml'nI I1rllgrm:t' rrpfI'WlllcV .md political .\IIA/M.\IOII ) COMMONWEALTH OF PENNSYLVANIA DEFENDANT: VS, r ' , ' Douglas W. Miller ,440 'Fairground Ave ' Carlisle, Pa. 17013 NAME AND ADDRESS W/M32 YOA DOB-OB-ol-61 RS.A. AKA SOC-204"'4B-6370 ". do hereby state: (I) tQI I accuse the above named defendant, who lives at the address set forth above or, ~ 0 I accase an individual whose name is unknown to me but who is described as - .g " . '0 s- o ~ ~ is - (2) o his nickname or popular designation is unknown to me and, therefore, I have designated him herein as John Doe: with violating the penal laws of the Commonwealth of Pennsylvania at Carlisle Tire And Rubber 500 Block Of N. Colle eSt. mo...../WlleaISuhdl,blon/ ar 1S e rou" in r an County on or about approx Part ici pants were (if'h~" "'ell" f'UrtlrlpanU. (IloC't' ,heir namt'J/,rrr. rrptfJllnR 1M "amro! ubm'r J.oftnJant): Douglas W. ~ti1ler IA\ The acts com milled by the accased were: ~ INDIROCT CRHUNAL CON'ln1PT The defendant did violate the order issued under the Protection from abuse act in No.11 1004 Civil 1994 on the 11 th day of ~larch 1994, By the Honorable J. Wesley Oler Jr., which order directs the defendant not to harass the plantiff DEBRA C. LAVALLE either at her residence or her place of employment. In that the defendant did violate this order by driving past the p1antiff's place of employment and did harass her verb1y by making threats towards her. This action is in direct violation of the above listed order of the court. all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contmry to the Act of Assembly, or in violation of !i'1:1019.0~~~,ti'i and l$i'i~['i;:i~'.w'1::fiW8 of the Aet of iJune"23rd'i'197B!!Protel1tton?~Abuse.' IS<</Ion) ISlIb"...,fun) or the :"~-'~1~-.<r,;!~1Tlf:.ft~~ Ordinance of ,;r.1'?:;lXht~:V~Pf;;-:'~~::;;:~'~:D'_,5X_'.<.~.;-;:: ",;"':;.~':~'._-:'."',~.~~;:~~':--,,~~::;:~~~~ lPolllleal Sub'd"'bl..,,) , (3) I ask that a warrant of arrest or a summons be issacd and that the accused be required to answer the charges I have made. (4) I verify that the facts sct forth in this complaint arc true and correct to the bcst of my knowledge or information and belief, This verifieation is made subject to the penaltics of Section 4904 of the Crimes Code (18 Pa. C. s. f 4904) relating to unsworn falsification to authorities. ;f/~ofcnll/~Olnanr) Ptl. Alan R. Mace Badge No.I/19 AND NOW, on this date , 19 _, I certify the complaint has been properly completed and verified, and that there is probable cause for issuance of process. WIm~~ I ,110gb/trial Ob/llr,) May 21st 1994 '- (/s,Jlllnt "'IIIhorll)') (SEAL) AOPC 411.86 ORIGINAL'SEE REVERSE SIDE FOR WAIVER AND FOOTNOTES voll ARE!~D,1tl:~ BEl'OiiE':'::;-'~" -.",,,:1' ,. .'.M',,' UNDERSIGNED AT: " IbATE ---~-~".t' .". -4~.'~'l;.~' .... .-..............- "-" 6.__~:. ;.~\i-:-"",:,'J,.l'~'-i~:":--. ~ ."'"'''''~'' ~..,.... '01 . _mln.ry hM~ng _ tho c/wvH In tho ._ compIolnl _otdlng to .... " you 'aU to appear .t the Ume .nd place. .. .led lboYe. . wlrrant will be lIlUed lor YOU' 1,,.1l Ball wiD be Nt at the PNllmlnlry hlaring. You hIVe thl right to be repr...nted by I lawyer Ind II you cannot Irrorct I lawyer OM will be ..-'aned to ,.p,...nl you. ISEALI MAOl<H[fMl [)&STRICT IS'WINO AUHtORlTY cJh:;.:);S'. ...... " AFFIDAVIT RIDER CONTAINING PROBABLE CAUSE FOR THE ISSUANCE OF A WARRANT OF ARREST FOR Douglas Miller 440 Fairground Ave carlisle, Pa. 17013 This officer was contacted by the VictiD!Plantiff DEBRA C. LAV/lliLE on the 21st of May 94 at carlisle Tire And Uubber 500 N. College St and was advised that Douglas Miller had just violated the P.F.A. by driving past the Tire plant as she was entering to report for work at approx 22:24. f~ he was passing the plant He Miller did verba1y harass and threaten the plantiff by saying something to the effect of you better keep your eyes open or else. This action by the defendant doe3 violate the order Si3nsd by the Honorable J. Wesley 01er on the 11th of march 1994. -.. ~y" ..........~x............. 19.1.;.. . gnature~nl) Ptl. Alan R. ce Badge No.1119 Personally appeared before me on ............................... 19...... Ihe Afflanl above named. who. being duly sworn (affirmed) according to law. signed this Affidavit Rider In my presence and deposed and said that the lacts set forth therein are true and correct to the best of Afflants knowledge. Information and belief. (Issuing Authorlly) (SEAL) -"'7 ._~. ..."... .-.----.--1'\- "..~..-l . '....-.,'"; C'."'-';. f...,.....-.. . .j .~.w ..., '-...,.-.,....1r-~'....,.~,. t..-'.~.-~~"'" '1'"7" "'.:~".'~ , "''''''-.c · ,..."..._....,.~_... " AFFIDAVIT RIDER CONTAINING PROBABLE CAUSE FOR THE ISSUANCE OF A WARRANT OF ARREST FOR 1,<,.,..11\1' t:lllm:' 41,\1 Fnjc';!I:;llir.d Ave l~l\dld". l'n. lIOlJ 1111:\ "fHcer Wt:~ c;mtlicte,j DY Lll' Het tm/Plunti11 ::11!lU. C. L,WALU (J'I t!.e :l1st 01 May 9l, at curlide 'nru And I(lIuber :nx; H. (.)ll"~'.l! dt aad loIila ndvi"nl t:l<lt ilou/:lu;J !IUle~ had jll:'l vluOateo the P.~'.:,. uy <tnvln/; pIII.t tile Tire p1wlt ill' 1;lIc Vl\.:1 ent.<:::lllf, to report for \lurk at n"p,ox ;;2:'-4. .\:J Lk! W$ Pu",;ill/', tl.c plnnt :lC Hiller dtd verbaly llurmm and thrl!llton the lJlnntjff by Burinl: :Jlr.ootllinl.. to the niiuct of :ruu botlet' keel' yuur uye:. open or cIS<'. Thiu lICtiull uy tho outenouat <!(Jcu violate tho oruer Signed by th,' liOno['l!blll J. Wooley (;lcl' on tile 11ti, of oorcll 199',. E I 2h.t l~,v >)/, xecuted th s ................ day of ....,....,..,;.............. 19...... i'tJ. AjUl1 ,{. Personally appeared before me on ................,.............. 19....,. the Alllant above named. who. being duly sworn (alllrmed) according to law. signed this Allldavll Rider In my presence and deposed and said that the facts set forth therein are true and eorrectto the best of Alllants knowledge. Informallon and belief. (Issuing Authority) (SEAL) " CD rt ':).ci-(H)0754 COMPLAINT P.EP~lPT Page \k.. 05/ 1.:~ /'J~' nNNNNNNNNNNtINNNNNNNNNNNNNNNNNNtINNtINNI1NI'/NNNNNNNNNtINNI'/NNNNNNNNNtINNNNNtlNNNtINNtll'/N,':,' :,' :~:O~lPl.ri I:-JT NUM8C..:-' '34,,'X'(175'j r.'cl:cived b'i: JEFrr~EY ::.UD8:....r.H ~ate/Tlme recelve~: 03/31/94 @ 1)8:00 ~k'w I"Ecei ved: F"'''i':'lli? T~m~ di~oatched: (18:00 1'im~ ai-yived: i)G:I0 Timc cle~rcd: 08:30 DDDDD[lDDDDDD,ODDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDI!!] r r' ", COMPLAINANT -) DEBRA LAVALLE ,)ddl-ess: 180:: WILLOW RD. City: CARLI SLE F'h.~r,(?: 243.'5'~'.::'3 DDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDr; TYPE or SOMPLAINT-) Criminal Mis~hlef Natul-e elf ,:,:;.mplalnt: CRIMINAL MISCHIEF TO VEHICLE-TIRES SLAS~ED-HDOD AND S!D~ DAMAGED BY SHAF'P OBJECT How !landled: Officer ~ocatlo~ code: ZONE3 dispat.:hed L~cation di5oatclled: 180:: WILLOW F:D ~fr'CeY dl~patched: JEFFREY RUDOLPH DDr !)[lCJ:ODDL'DDDDDDDDDDDDDDDDDDD[lJ)[lDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDD [ll'DDDDDDf'D r; DD r::! T !i'iE (1NAL'r'Sj!~ Ch.lt:iUf:- t 1m!? fi'avel time .:time re':;:-:ll,,€..d :f) di':lpt:\t'::if.',r, -;': {ti,ne disoat~~,ed i.o arl"ived) <I mLr.ut.i'?S 1(1 mi nl,te~., l~J mirtL\t[~!:; :.:'( mil1i..\tr--'':l :;~e5Dc'nse t; ime t line rel:ei vee:;() en~ rived> f...:Li,_'r"1 time tinlE ~r('_'I'-?';': \-:. t:leared'> 'lltii'/;'INNNt//II/Nl>it/NNi'I/'{;-;tl.'/NNNNNNf'IN.' IIIN//NNt!NtINtlt/NrIN.'..."tltfNtIN/'ttl,'I.'INI'/Ntl',I"/t/.'INN,';"INN/'INNNtlth' 11'/.'li"1 Commonwealth', EXHIBIT -S:-l.,- <ill ..$(~, ~~,;-,t~}.1t, ". # 9-1--(100754 I NC IDENT REPORT Page No;). 05/14/'~4 Htll'f/'lNNNNNtlNNNNNHNNNHNNHNNNNNNNNNNNI'fNNNNNNI'fNNNNNNNI'fNtlNNNNNNNNNNNNNNNNNNNNNNNNNtlNl' INCIDENT STI\TUS -)- ')4"'000754 Jud!;dio:ti,o.n n"m!:ll?r: 212<)[ Brie! syn':lp"lS: CR:l"INAL MISCHIEF TO MOTCll:~ VEHICLE..TIRES SL()SHED. E"'C, Date in.:ident clccuired: 03/31/'34 tel 03/31/':).; Time incident occul"red: 12:00 to 03:00 Date reoortud; 03/3~!9;~ Time reported: 1)8:00 Inyeztioatino officr: JEFFREY RUDOLPH F:eY i ewed by: JEFFr.:EY RUDOLPI.: .- <)3/31/94 Cleared by: Date cle~red: I / Case status: Open Dbte o:lose~; / 1 DDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDI OFFENSE COUNT -> 1 ::> CC3304 -CRIMINAL MISCHIEF VEHICLE DAMAGED :..ocation code: ZONE3 Location: Lo~ation type: Re5~dence or tlonle 1002 ~ILLOW RD !~re~]~es ~rltered: Aband,::.neL~':' t": Cit'cumstance: Comoleted Unfounded? N Ale':.!l.:,l ,:on5Jt..Hlleci",;' N Drugs/N,::p.cclti,:s used? N Date unfounded: / " Cnmoutpl" eqLlioment LIsed'7' ~~ F~Y~e used? V Weaoon/force used: Knife. etc. DDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDnnDDDDDDDDDnDDDlJDO[JfJDi'f';)[1[!UDDDDf'D[10DI SUSPECT COUNT -) . . Name: DUUGLAS ~~L~:AM MIL_ER Address: 444 FAIRGROUND AVE. Citv/St/ZIP: CARL SLE, PA 1701~ DOD ~ 08/:) ~ /6 'i Se,;;: ,""1 ~~.;.':P: W!':_7 '.:":,c,nt?: At tunE .:.f in.~ident ., Age: ''\.-. ':'. ~-{eiwht. " we., 9-' l : lb,:: . t-j,i1 ~ r- : ::: ..il~~'~ : L'\U i 1-:.:. ,~_,:,miJ.. 12'" , ,.'.j. ;'jU:(jE'_'. ~nle)"'vie\oJ~d7' lJ St.,lelllE<:1. ';,,1 fc':"," " .~;L'D:JDD[)DDDDDDDD [IDE] ,~:)''''I'DDI1D2D~.lD[l[lDDDr f1,'JVDDV DDOD1)]J[\[) fir n.~n tyr..r: -':'.} [,ODD [' ,"Df1 !/[l[!/'P:);': 'i -,. 1 . ',:CTW COUNT, ,J 0:.:'o/TiC': CE:-)P(-1 ;:. :_(-\',..' ,:~dd'.e3s: 18,)-':: l.J!~ ~'J~'; ..-,~ 1 ': , " r' t " '., . -,~.F'l :);:; r~ . .,c .r-, -.- ,- r;~ L\ '; ',i: l..': ~ ' .l.:'; ,....', /i~':J ~"':r"" ~/i" , . ~ North Middleton Township 1I ':l4.-l)<)l)754 INCIDENT SUPPLEMENTAL REPORT P,,1Uf:- rJ(._ 05/14/'34 1'1/'1/'1/'1/'1N/'I/'i/'lNNNNI1NNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNNftNNNNNNNN," INCIDENT STATUS -:> '34-000754 JLty i:.idictic.r, nL,rr,tml'; ::l.:',,::; Brief synopsis: CRIMINAL MISCHIEF TO MOTOP VEHICLE"TIRES SLASHED. ETC. Date incident occurred: 03/31/34 to 08/31;~4 Time irlcident occurrEd: 12:00 to 03:00 Date reported: 03/3tc/J.~ TimE yeoorted: 08:00 DDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDDIJDDDDDDDDDlJDDDD DDDDDDDDDDDDDDDDDJ:DDDr'[I.:)['! SUF'PI.EMENT AL COUNT -:, : .:. f 1 The victim reoorted that sometime 0vern,~llt her 198G Capri was damaged by pers.:,n(s) unknc.wn. The damage cc'nsisted of the drivers side tires being either slashed or the valve stems released. There was damage to the hood of the vehicle as it appears a sharp object was used to scratch the paint surf~ce. This also occurred to the drivers side door panel. The victim and the victims mother, Christina Lavalle, b~lleve this crime was com~itted by a Douglas Miller, estranged boyfrIend of Debra Lavalle. Mrs. Chrlutina I_dvalle stated that she heard a noise at approximately C300 hours, soundi~lg lif,e a car door slam Shllt. She did not notify police of tt)is OCCU1"rence. Repoy tee: by: JEFFREY RUDOLPH -- l)3/3U';)~ r;:ev i e,,'ed by: JEFFREY RUDOLr'!1 - 'X:J/31/o;1'\ NNNNNNI1NNNNNNNI1NNHNNNNNNNNNNN/'INNtl/'INNNNNNNNN/'INNN/'ltfNNNNNN/,fN,.,rINNNN/,lm'.^lt'NNN^,,.:,'!i II"::^// ::' . e..v- J'Ij .""",,----- (Y) CARLISLE POLICE DEPARTMENT 53 W, SOUTH STREET Case , 7f- Of. I'" CARLISLE, PA 17013 m.lHV. .0 ./111 l (717) 243,5252 I ,. ""'Ult J;J(J Y UCR ~ !hJ.:\ I ""'A'C;;<<-G I""~~..l TtIDAlD I~~"'.... L1t,~" d. ~.S- " .'.J' lllCA~"",JI<I_' -:b. ',.T< t...r. DATE ItIY4[H ..... J2I1lV DAY cry ....'" AND ..PJ-1!L :II) S'trT BORO OF CARLISLE I CUMBERLAND I -, q,~ 21402 TI/,IE " 'u:> 0'1 .10 "....'\ - veT'" I ~I -'OS, .. lj<H'<1WIlIS CR' ITIIUT f'n A ,,,/, IJ J "J),;- tl1b4 C Jlf~'-!JJ-' U.J Q...O C1/1iiLIHJ / J.l.IJ.. 'C:' ~- -~, O'l1L. f.) '2~tp". \ un 11 lAST""" -----riiS [Yf\cm:RISGHOOt. PtDl[ 1~.JJrl AlXlRI" - tml',,!,11l5U ~ I rs'00l5 - li'hL llt\l\_P_Cl.t1:.U . HOW AnACKEMNTEAlD VoueLl plWl ..... a~ tld--~ MO.UIA'E VI< rn l'.. 'f\..c-J~V ~f'!I<I_2!LJ,,[ --- .....0"''' - I HOt1Sl:HOI.OGlXlOS ~.1 CUIllEHCY ..oA. PAR "'Al I""''' Clot..NGfURS QfTlC((Ol.IP, 'JltNlllS COHSUlU.lltS I UVlSTOCIt IWlOC)'IVNtIl lI5C 10U1$101.(N TOTAlAlCOVUllD ~:= y)~(". C.O "1~... ~.1~'D'':''~'" ~C, ",:;D I ~[C, LOCAHO Sl6PtCI ~~IBtD ~Cf~~[K) , 0 NO n NO_llt YESn.o m NO ,...- susPEcrM'ltHtSS ~ IJ,SJlIRST'" ~ CJ\.I._LUJL_il1__!~_ JnJ......;~ ../ LA' ' 0 oIt!' S;Il..1l.O _ __Et'I.f\-J...~,"'-A--'3 OOB AGE 1''''''' I $0 ""'" .. susPNillNlSS NAU[ LAS'~tlU: AOOIl'" 50 wn ' - OOB AGEl""" 1$0 ""'" SUSPEeTM'lTH(SSN.UI[ WURST'" """''' - -- sn wo ,_. OOB AGE IlIACE I $0 ""'" . SGNlncAKf u 0 PJ\ES(NT mo NO 11 $CH1JlCAH1' ArtSICAl EVUHCt PRuon mo .oF HARRA 1M ~,) ~ O",",~ '-;:''''''''-7-17J:ft~L -"/,... 'i2d' ~ _n:.n ~~" ~"""'.L' ';) CO T -" t=1.:V OJ"" - 0'1.':" Ih:d ..s:."I~~.,.I1:' 3ii!iir . "' ~ (' I..,A \ .f"J--n ~-- 'i 11 ,...:~..:>LJb;... .rt ~e. ,,, t'>-~.-lL.t:lj\l.." c;.' """'" p,. _ k.. C':h ".... 'nt\;.' ..s:r...~c? ~-. /i~ l. v ::;!)~"'h ...v~.~~ Vt::\l 'l-I ,: =-- ~".~--o1..:t P~mr c...\T"I l;" , C" ?CL.-ic.'t ~ 9lJ'p'!/"" JS'O ') ~uo SIh' ~~< 'T\'>'.s~__U~-",..,-11+ t.; I. - t.?{,YFIW~----XJ,'1./,=.- .O:J ., t LI.'"'l'-- ,",,^ ~~~IIJ.D,C:""''''' -:-a~J~ ~ J-w 7it- I ( ,..J.t" _W.h..v~..JJ ~'1 - ---- -- -_.- ,- -~_._--,..- .-... n._ ~~--~-.---_. ---. - -~- -~-- .~~- ;'-D~ ~s. T / I. :=:I:7 ..--- H ""'_ ,Of _ () .. __I _'L8'_.e-S,; d- --.- CHaR MAW( I llAOOl' SlOH""" II ~"J'^ tZ C...... ,.t- I~ ---.J If) 'I -'" O''9,nal Copy , Police Dop, Canary Copy' Detectivo Copy Pink Copy' VICtim's CPOIlD' .:ARLlSLE POLICE DEPT. SUPPLEMENT REPORT 2. FILE CODE '.ITEM Il~< . 9y, ()(,(I~ :J. OFFENSE, 4. NAME OF VICTIM: j) - 0 "'" "lh-L ~ 7. tyPE REPORT CONTINUED OR SUPPLEMENTED: 9, NEW OFFENSE IF CHANGED: ~ITIAL~RIME .... LOUSED AS CONTINUATION SHEET OF CURRENT REPORT USED TO REPORT SUPPLEMENTAL INVESTIGATION 11, STAT\JS: 0 Unf...ndod 12. FURTHER ACTION 10 REPORT REOUIRED: 13, MULTIPLE CLEAR.UP/: CL..I O'h" In..donl ~rod 0 No. C'.rod 0 YES ~O 0 YES NOL In N.....I..I CB' NO 1..HARRATIVE: In follow-up UU". record.1l d.....'opm.nu.ubsaquWlI10 Ian raport. Lilt .nv ICCUlMf .nd/or WIPKtI_ 11m h.m. Include 'n.., 'tlPOn nUm- bwt of penoN ,n_ed. walu. and dbpotition 0' recovINecI proPlf'tV IAn.ch Prop.rtV Recordl..nd ..p"l" .ny ch.,.. ,n offenaa. o VEHICLE 0 ARREST 10, VALUE RECOVERED PROP.: L ACCUSED/SUSPECT 0"; 0..3 I'h" '1 ?r .1::- .f(J It': WIllA .f "'\l .0;;,-, "b.J..J/.- m'L-Lel\. Ik<= T'b n~ '..5 ];:..,v..., 0 "^'\, In: S 1h n:~ Ih:. Ift:I.o rtA',1 kNJ.....L. co t.v' () r:- .s 1..... Oo.vC:j L...A'/th.<.c.~ 77 'k1 {Jc.I"'t..- .( '-.'lJlh:"D. If,;.' .sD~ 8/......J ...frn-.~'"b /o'??"...., c',5 y T/t-i: '1 P,J.lIIJ'-1 Cv....",JJ ~ 1)",.J~- r,~~, L...J , '" ..v v c.~ . .... '" (;:v. 0..,....C-<:' cor" T f ~ I')"), l-L cf\... T"2> V.-.a..o""-"'O C l.-"S cO. 1'1..... '7 r-... ,..~"X.. .... t. .(...... (), .... .,.. ~ ......" - (,),ll......'" ~ IH,: ~....... .......r 'Tl-t \ ~ C'IO d "&-J bc,vc.'l....p cr I~...... "1 A NO. SlG DATE OF REPORT SUPV. INT. BADGE NO. I O~i'iCER--- - DADGE NO. c? b J'o'( ~~e- ~}II ff j(p2J '",-----_/ !lIiiiiilttl"ot I I BARRICK TIRE SALES Quality Tires at Discount Prices 455 Center Road Newville, PA 17241 - 717.776.5761 i I I t I I . .~". .L:]t 4 I JqLj ..."w. I ADORn. IOI.DIY CAIH c.oJl. QiAAQI I ON ACCT.'....AE1"D _cur OTV. DESCRIPTION PRICE AMOUNT ;.; c}J5 nv l~ (l\b) - 1f\IWl YJ:'- I d l' nO ,--- I l\ -:Y) III I~() ! I I ;::y), {() I i :=:::,nrl (,.., . (Ie) ; ~ 'OCl" I. '10 I J;;!7 I 'nl ! /~ " JI I, I v[i," 1\ ! \ rVnItJ ! '-(j ., ,v TAX (()r'l \, ~\\(n~ I/)()(J..! '" "0 TUlE .:....r ) TAX ...catVao .v I vr~ (oJ TOTAL All clalma and r.turnad Good. CJ"h '- ~ MUST be accompanied by Ihl. bill. '1'00 - NO Cash Refunds . Check Luas Arter Mounllna 'L--__._____ ~J!W.' . BARRICK TIRE SALES Quality Tins at Discount Prices 4" Cenler Road Newville, PA 17241 717-776-5761 NAW. ADORI" OTY ICUJ IY CAIH AU claim. and returned good. MUST be accompanied by Ihla blll. McarylO .., - NO Cash Rcfuacb . Check Lup After Moaadag I I i I I I I I I I I I I c. ,......""""'.n, ~..w.:?:.\~ ~ BARRICK TIRE SALES Quality Tires at Discount Prices 4SS Center Road Newville, PA 17241 717-776-5761 HA". 4DOAe.. "-...-...--..- --- _caweo .y TIllE TAl TOTAL All claim. and returned good. CI-'L MUST be accompanied by lhlo blll. .I n - NO Cub Refuads - Cbeck Lall Arler MouaUal .----- -..-- ------..-- -- ----.-.- M~"" BARRICK TIRE SALES Quality Tires at Discount Prices ,'I 455 Center Road Newville, PA 17241 717-776-5761 N..... ADON", BOlD IV CASH - ,All CUT OTV, DESCRIPTION PRle 1 '80 1 -1---- 1- -70 I All claim. and returned good. MUST be accompanied by Ihl. bill. CN.__I.CYOU (~,lt.U ,\\lA "'.. - , I f.€. . NO Cash Refunds . Cbeck LUIS After Mouullul -1,.,1- ",,, DAMAGE REPORT 05/19/94 at 08:26 FED ID 23-2234441 LAVALLE D.R. 18235-0001097 Est: J. NAILOR' SUBWAY AUTO BODY A REPUTATION BUILT ON QUALITY 1231 RITNER HIGHWAY CARLISLE, PA 17013- (717) 243-9978 WORK Parts (Subject to Invoice) o. Labor 2.5 hrs $ 27.00/hr 67. Paint 27.0 hrs $ 27.00/hr 729. Paint/Materials 375. ------------------------------------------ SUBTOTAL $ 1171. Tax on $ 1171.50 at 6.0000% ~ ---------------------------------- ------ GRAND TOTAL 1241. ---------------------------------- ------ PARTS SUBJECI' TO INVOICE ANY PERSON WHO KNOWINGLY AND WITH INTENT TO INJURE OR DEFRAUD ANY INSURER PILES AN APPLICATION OR CLAIM CONTAINING ANY FALSE, INCOMPLETE OR MISLEADING INFORMATION SHALL, UPON CONVICTION, BE SUBJECT TO IMPRISONMENT FOR UP TO SEVEN YEARS AND PAYMENT OF A FINE OF UP TO $15,000. Estllate based on HOTOR CRASH BSTlHATIHG GUIDE. Hon-asterisk/') iteas are derived frol the Guide. Database Date O{O Double asterisk(U) iteas indicate part supplied by a supplier other than the original equipaent unufacturer. BlEst. A product of CCC Inforaation services Inc. Page: 2 DAMAGE REPORT 05/19/94 at 08:26 FED ID 23-2234441 LAVALLE D.R. 18235-0001097 Est: J. NAILOR SUBWAY AUTO BODY A REPUTATION BUILT ON QUALITY WORK 1231 RITNER HIGHWAY CARLISLE, PA 17013- (717) 243-9978 Owner: DEBRA LAVALLE Address: 1802 WILLOW RD CARLISLE PA 17013 Day Phone: ( Other Ph: ( Deductible: $ ) ) 0.00 Insurance Co.: Claim No.: Phone: Adj.: 86 MERC CAPRI GS 3D RED 4-2.3L-1 vin: 1MEBP79A8GF616382 License: Prod Date: 0/ 0 Odometer: Power windows Dual mirrors Bucket seats Power steering Tinted glass Rear defogger Recline/lounge seats Power brakes Bumper guards Tilt wheel -------------------------------------------------------------------------------- NO. REPR/ REPL PART COST LBR PAINT HRS HRS MISC DESCRIPTION OF DAMAGE QTY -------------------------------------------------------------------------------- 1* 2* 3* Refin FROM MOULDINGS UP Refin CLEAR COAT Repr LEFT DOOR DENT 1 1 1 24.0 3.0 2.5 -------------------------------------------------------------------------------- subtotals 0.00 2.5 27.0 ===> Page: 1 o 0.00 94 - JDOl.{ CRIMINAL COMPLAINT (POI.ICE) N Paula P Correal DISTRICT JUSTICE MAGISTERIAL DISTRICT NO, 09-2-01 16 W High Street (2nd Floor) Carlisle, Pa 17013 Complaint Numbers If Other Partlclpanls A 64748 I, Ptl James L Peterson Badge# 4 (Sdm"tJjA(11mlt ) of North Middleton TWp. Police Dept. ( IJl'tI/Ur JqJU"",rnl IIr UXt'nrr n'pn.~u'ntl'J IUld polillnll.\IIMhMml J COMMONWEALTH OF PENNSYLVANIA DEFENDANT; VS, r, "... "...,,,, NAME Dol,lglas WillillD1 MillerIX1Bs8:-1-61 AND ,444 Fairground Ave., ' '\:'.." "'; ADDRESS Carlisle,' Pa 17013 ' RSA W/M/32 SOC# 208--48-6370 AKA do hereby state: (I) [] I accuse Ihe above named defendant, who Iivcs at thc address set forth lIbove or, o J lIccuse lIn individulll whose nllmc is unknown 10 me bUI who is described as .s " 0 his nicknllmc or papulllr dcsignlllion is unknown to me lind, Ihercforc, I hllvc dcsignllted him herein liS John l Doe- wjth violllting the penal IlIws of Ihe Commonwealth of I'ennsylvania at 1802 Willow Road in North ~ MIddleton Townshlp (l'Iac,'-11H1llruIS"bJM"'ml i in Cunberland County on or lIbout 3-5-94.3-8-94.and4-2-94 e Part ici pan ts were (I/Ihtru,trr punlclpunt". pia", Ih,l, nalllt> IItrr. ".pt'UlInR lilt /lalli' "f al....' JtftnJan'I' Douglas I~ill iam Mi ller : - (2) The acts committed by the accused were: 0 Indirect Criminal Contanpt: On 3-2-94 at about 1105 hours, Deputy Barrick of Cunberland County Sheriff's Office gave the defendant a copy of a Protection From Abuse Act Order that was sign by the Honorable J. Wesley Oler Jr. on 3-2-94. In that order it stated that the defendant shall not harass the plaintiff, or the plaintiff's relatives. The plaintiff (Debra Lavalle) was living with her parents at 1802 Willow Road and that on 3-5-94 at about 0222 and 0934 hours,and 3-8-94 at about 1525,1527, and 1531 hours, and on 4-2-94 at about 0115 and 0138 hours the defendant did call by telephone from his rother's phone. The call he made on 3-2-94 and 3-8-94 he did not talk jsut hang up. The call on 4-2-94 he told Mrs. Christine Lavalle that he was going to hunt than both and I am going to hurt than and then hung up he call back did not say anything until this officer started talking to him. all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of Assem~!~~ or in violation ofl'lil!il!10190.m.~1\~i'~ and "'Ci"'c;;"i.;P',;C,'i:t;: of the Act of;>;'~une':23';'1978,l'rnt'At'''~1in''''A''uSiL (Strtlon) (Suh. $<<'11"', J or the .: ~:~::-:.'."'.T:.'~,::y!\.t~~!f.~iJ Ordinance of f(I;m~','i-:;;F:/J7Fr::t!:51-"Cj!{r"?v,~:_'-"!,-\,';"'~-/,::;:~~~:,,:.,~;-:':',';;-->~tI,-"E~/2~,~;~.f!~~g~ . ( P,~l1Ital SlIb, JM,lIon I (3) J ask that a warrant of arrest or a summons be issued and that the accused be required to answer the charges I have made. (4) J verify that the facts set forth in this complaint lire Irue and correct to the best of my knowledge or information and belief. This verification is made subject to the penalties of Section 4904 of the Crimes Code (18 Pa. C. S. ~ 4904) relating 10 unsworn falsification 10 authorities. .19_ fi1@-"'-'-x'~: P ames L Peterson (Slgnatllrr of Complainant) -~ AND NOW, on this dllte , 19 _, I certify the complllint has been properly completed and verified, and that there is probable cause for issuance of process. ~-~ (SEAL) (Maguttflol Dutflet) (/JJulng AuthorltJ') AOPC 411.86 ORIGINAL-SEE REVERSE SIDE FOR WAIVER AND FOOTNOTES .:\ummun, 5CrYeu Of ccnUICU mall. return - recapt rcqu 1- PlACE YOU ARE COMMANDED TO APPEAR BEFORE UNDERSIGNED AT: I""" 19 on the __dilY'l( (Slgn",,,") rntlC'/ 'Of I prellmlNlry helrtng upon the chlrge, In the lbov. complelnl IccOfdlng 10 Law. " you 1111 to Ippel, .t the tlm. .nd plac., I' .lIled lbove, . wI"ant will belllUed 'or YOU' 1"1'1. Ball will be H' e' ,he prellmlnl'Y hee,lng. You have the r1gh1 to be ,.pre.ented by . Iawye, Ind II you clnnol afford I Lawye, one Will be .'~ned to 'epreHnI you. Summon. returned undelivered on the day or 19 DAft I55U(O (SEAL) t.\'/.:""',,,,,} (77"t) l,(A(il.,lllllAi OISTRICI ISSUING AUHIQfUT 'f' AFFIDAVIT RIDER CONTAINING PROBABLE CAUSE FOR THE ISSUANCE OF A WARRANT OF ARREST FOR Douglas William Miller ooB:8-1-61 On 2-24-94 a Pasty Lavalle of 1802 Willow Road in North Middleton Township request I sign a trace form so United Telephone Co. could see who was making harassing phone calls to his home. Mr. Lavalle's daughter (Debra Lavalle) who is living with him and his wife (~hristine) had just seperated with her boyfriend the de- fendant and he beleives he is making the calls. Debra Lavalle did get a Protection from Abuse Order from the Honorable J. Wesley Oler Jr. on 3-2-94 at which time the defendant received his copy. I received on 3-17-94 from United telephone Co the results of the trace and five calls carne from the defendants' mother house where the defendant lives there are close by, defendant dose not have a phone. On 4-2-94, I received a radio call from County Control to see Mrs. Lavalle. I talk to her and she stated she received a phone call from the defendant at about 0115 hours in which he stated he was going to hunt then both and going to hunt them, at about 0138 hours the phone rang and no one talk you could hear music and a female talking, Mrs Lavalle handed me the phone and I say Doug whats happen and at that time he stated not much who is this and I advised him who I was and ask him why he was calling and he stated he wanted to talk to Debra. I advised him that he was in violation of the PFA. personallr appeared before me on ............................... 19,..... the Alllant above named, who. being duly sworn (alllrmed according to law. signed this Aflldavlt Rider In my presence and deposed and said that the lacts set forth therein are true and correct to the best of Alllants knowledge, Informallon and belief. (Issuing Authorlly) [SEAL) ,. ~!,:,.,r""'~,^, DEBRA C. LaVALLE, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . . v. CIVIL ACTION - LAW . INDIRECT CRIMINAL CONTEMPT . DOUGLAS W. MILLER, Defendant . 94-1004 CIVIL TERM . IN RE: BAIL SET AND TRIAL SCHEDULED ORDER OF COURT AND NOW, this 11th day of April, 1994, upon consideration of the complaint for indirect criminal contempt, and the Defendant now appearing in court with the public Defender, William G. Braught, Esquire, of the Public Defender's office, and it having been indicated that the defense needs additional time to prepare for trial, trial in this matter is scheduled for Friday, April 15, 1994, at 1:30 p.m. in Courtroom No.2, cumberland County Courthouse, Carlisle, Pennsylvania, and bail is set in the matter at $500.00. By the Court, ,I ./i/~1 J I. Wesley Ole('; v JONATHAN BIRBECK, ESQUIRE Sr. Assistant District Attorney WILLIAM G. BRAUGHT, ESQUIRE Assistant Public Defender CCP (')0 c::.., r-' ."cc........ ~tTll""';,::' :.r.~~p V" ^ ,1l.' -)-.;-, ,..,~ .,-'; <.r::::::."" "';no:! .::::...,Zn t:C:\.)fT! :.&:-1 -'" ..'" .. ~ - - wcy w co ... -a ::II: - c.o .c.. - I ! 'I CER'UFICATION OF BAIL AND DISCHARGE OTN 1\ ~~ ,(T . :....;f tj() [).It,,) '.".' ',,'01 .\, 1" ,". """'",,~.j''' '..,.~.. .1".1 A,ll"',,; "" ,,,.v,,,,, 94-1004 Civil Tenn Douglas W. Miller 440 Fairground Ave. Carlisle. PA 17013 l ] 1l0fl(flo'illletYI U NommalBml lx Billllloldl amount sot,,' any) $50 LJ ConditIOns 01 Release (aside horn appearing at court when required:) lItAll(;',:,) Conte/1llt (Violation of Protection from Abuse Order) D"IrmCHMKill;" Cbmply in all respects with the prior Order of Court issued March 11, 1994. NEXT COURT ACTION DATI APd)TIMt lCCATlQt. Courtroom 2 4/15/94 - 1:30 P.M. Co. Courthouse TO [XI Do'onllon Cenler 0 Olho' (altach addendum,ll necessary) I hereby cOfllly thai su'hcttmt ball has been ontered [1 Bv thn defclllJanl it] On behalf ofltle dclendanl by StClllljlfn"~,t;I~II, .11 M~ll o Sumly Company X] ProfeSSioni'll Bondsmarl [] Roalty [] Olhe' jN,l'N',," Al1\1'f'~\ nr::;,,'''/)j IlJcf'''\f' No J Vivian Ibckey 707 $500.00 . Refund 01 cash ball Will be mado wlltun 20 days allor Ilnal dIsposition (Pel n err, ,IOl5(bH . Rnfund 01 all olllur lyp{!S 01 ball Will be made PlOmplly alter 20 dilYS '011011I1119 Ilnal dISPO!llliOflIPiI,R Cr ,P. 4015(a)) . Bunn CasH Bi!>j Receiplto Clllrk at CoWl JUpi,! OIlI':~jU:"',AU1"U!lllY J. Wesley Oler, Jr. APPEARANCE OR BAIL BOND DISCIIARGE TIlE ABDVHIAMED DEfENDANT fROM CUSTODY If 01 rAINED fOR lW01IIER CAUSE TIIAN HfE ABOVE STAlED GI\o'm' under my hand ':Ind the Olllcml Seal 01 thiS Court. THIS BOND IS VALID FOR THE ENTIRE PROCEEDINGS AND UNTIL FULL AND FINAL DISPOSITION OF THE CASE INCLUDING FINAL DISPOSITION OF ANY PETITION FOR WRIT OF CERTIORARI OR APPEAL TIMELY FILED IN THE SUPREME COURT OF THE UNITE,) STATES. Ihls 11th dayol April ,1994 ~ :e' n.., ~.i '.l.'-'\I""';;A"II>,',,~.~fy. SEE REVERSE SIDE FOR BAIL CONDITIONS CERTIFICATION OF COUNTER INDEMNITY AND PREMIUM (Applicable ORly When Surely Is ACorporalion) PflnClp.ll. and hereby cerllly Ihal the amount p,ltd b\ said Prtnc,pal to satd Surely lor bo:lil In Ihe abolle mailer IS S ana Ih,1l no rurltler .,urn or sums is 10 De paId therelOle by the s.lld Principal or ,\Oyone on hlS bell.llf WI! :Uf!fH~1 (l:rIIIV Ihal said Prll'';Ip.ll has gl\,en (u ~lll' Surely counler InaemlOlly COIi'\lstlng 01 ollne v<tll;eol S aslollol'iS , Surely, and no lurther counler mdemntly IS 10 be grven lhe saId Surely clcepl We lurlh'" certlly thai there are no /udgments dgarnSllhe s;JId corpafdle sUlely oulst,mdmg and unpatdlor a periOd 01 more lhan thtrly ddYs horn Ihe dale ollhe cnlfY 01 such Judgment e.c~l)lthose 10 WhiCh a pellllon to open or vacate the luogment has bCtlllllecJ aM Icmams undIsposed 01 Daled ,19 11",f/C"..1!J (SEALI MUST BE SIGNED IN PERSON BY THE APPROVED AGENT I ACKNOWLEDGE THAT I AM LEGALLY RESPONSIBLE FOR THE FULL AMOUNT OF THE BAIL. (SEALI 1'>,'I1'"J ISEALI The followmg adnowlf?dgemcnt IS also ,1ppllcatJl(> If Percel't,lgt. Cast. Uallls USt>d TIllS IJONO SIGNED ON ~ril II. ill CArl iR]P. ,g .2A- PENNSYLVAN'A Signature 01 Surety (May indivIdual Of DlganllallOn) own lecogntliJnCO mom. mcludmg oomma/ b.-III be Donas oJ Pflvilfe t_Cl'pl W'I "cnda", IS re/f.'<Jsed on filS /fll:, must b(. Signed in .1/1 b.111 sltuallons IStALI Signed dn(J arkllowt/.(fqt'tf belorl' mIl Has 11 th (lay 01 Aoril ,"J.2L "I ".i;I,':,(jl ~",IH h "'11'11. U ;I.!I'M" l;iI!lI'1 'il!A1.1 -"~-'"'t G... 'f>....;~u lOIldi:'xxx' 0""., Dpty. Prothy. · In Cd"" 01 CO/f/tll,IIt,' ~w"Iy :"I'}, 1',10\'" 01 AI/nll/"y ':llJq t)e aNIt!'(f tot)O/I(I a' nl!lt"""',I> IllllI"", 11I'0',11." ."",', ,'.", ,'t,.'".",.,.,/"..",.,. \/,; "...'111'" ORIGINAL · ,,, C,l~f' 0' 1"~'Ct'rll'H1'-' C,J~;" Rill 01 Nom",,,1 flflll, PO.....f'1 of ""()"t('~.I~ 110' n'll(JI/l'd ", '., 1'1'" IIAIl CONDITIONS - Th' CC"\nDIT10~IS of thl~ bond al(> It-.al1hl"' d!"!ltmd;l'11 ','il!! Ii! i"I~~'-,1! :""')11' ":.. I~.:.',jll"-; d'l\tll.!,ly dr;~l In p'l' Crul!~ ,;1 !t:'_~ CO\ll'I;' r.., 'ii')-(j, O'~'r>''''i ~r '''I ~~r."\,.. ::!""IH ff!m,'1Jn 1:"\ 11J!! fO~co tll".d thi~ hond In th~ full ','.J'" PlI'fl' ',!, L,t: ~l!' l~ ~!. ,:,'d ''i!-''''''l',I'',''j " ',! I~, ,!. r,! -,. i', " .: r .. _.1 . I: ,I" I;!l " ':; ; l~; r, "': ':'-; .:'.: r.' ""-1""- JI' :!"1(' " I'.. ~, .' '.'.:1, ,j',', ,',j' 'l" h.':o>{,t ;~rr<pVller .Jf1Y ,ltlornt"; 01 ,', I . " - : '. r; ~ I'. _ 1 ! :)1 (::'..-: 'I. I : +: ' i' ...,H'td! -)t'r-.ll:l!.I,n', l,j,'>(j ;w\l '\ ',Jo".~ ':,ID ((p!t' ) JiJ,l'JfT;~'(11 ;If;illl"l .1 "',,,,,,.,',';'''11'''11,11')'''''<.>1 t;".,,!r,"'.d_,j (" .J ('.ur! (11 :l'!J::rd.j! :", -,, I .. ~ !.. , {'. ~ \ r:. ,I ;". :.1' ,. ~." ','J.,,' , ., '.', r t,.l ~! . '.:lI""'''''' d ' ' ~ , c..' " ", i',' hi I'.ll, 1.",,:;1,', , " ,1'; t:' .- t'~__ :"'1' > '. ~ ."1,: '!"..cl ;:\)'11. I. 'j" ." !lit: [, C !"\; ';!l.. 10".', , :,';1; j' ~ '\:':',) c' '.'. 01 '1'1','<.1 'Jth]"'ll'!'l',,j,;fll' ...,",'1 f;,:,~",'qtl1 r~t';~s olttw t!;J!;' 01 11'" 01'\"'1" ,,! :li!:L;" .,;. (i,:IV',' .~:II' 'Il:y ~:n,'('hC H~tl;jilflqlf~fl~ (:\ It~I'-',I'..,':n';"',,!il [I !I'" " "q <l111I'd'tty ,,, (':"111 !,uCh J:> ,1 ~"J!,.,lil(Il)/y p,Hl,c;p,jfl(,n Iii d ;;"~;;')'I.lid.l P'l:,:}'d'lL l'__!l:\.';, (it "._,,,::',<! <1\.1' 1\ (j,'1,':L,U": 1"_ d: , I; :,:L ",.!'r .:1,'''' <I: " ;1" ! \.'<1!.~H:;(T: ..fen ,Y'Y ,:,. ~'" 1;::-,'.-\-\',,: . ,Jt,,:l;1Jdl0'ldG'j.:"~:IO ,\;;dll,';f;J,'lJ:i'( ","'111' h,',r: "-".-',., :-! ".;,;f"c)!' '''',,:f'.J'''', "j'l.,,\' " , , . . \',.j ", : t ",.,,'.';~ () C:,I '1 "f'(: ..'):>" ,l'" J t '-' ".-'1.rl'_' !",', Ii',;'" ;I, Llt...!.'!..-I -/,' ",)\ ir',.I-, l:c Ii,i ,,'.:\J ~:L'r,'d':L' .I'I:!")"\V ,,"~ ";1 t.'nuq., (....... I',f. .....j.'J.' "': -"."" , P ",; ',L;( :~1" '...., I'J .l; .-'1';') :\,,', ',fI.!:~.:n: \'.,.I~I<Jril A u:'t,j ;.:1 Uk. l;'J'h,] dl'd , ":,11" i'" t,(.I)~C(', ::ny 10 !i:.' llll.; ;""J f1,t' J". ,;, "I,' .f !t;;) (>,i']' 1 10 :nn I:f'!' I", ;,.:"'.'! '_i_;~\,~'~'()", ;i:. i~'p (>),-H1 ';r (" .'; P.l, "l', (,~ COurLl1la)' .1l1pO'it:. .tu':~:-, \!"i' C,l!<:I'li.f!\ il:; ';t'tl-1r!/\ h~fl"l; t,.',. I'.' )";' it, ',~':f'L ", ,:lv,j I"';,,t'l",:t".{jr . . . . . . . . . . . . . . . . . . . . . . . . . JUSTIFICATION OF SURETY OTHER THAN CASH BAIL 10lJi!<,lll1:1:} ':, '.. 7 Il ,I:: j 9 ,1'f: .IPP;lt,j!1!t {;r:iy ....~;~~I1I~'.-t! b!,lle l~ V:)f(~ ,I~ ~l":!J'I:i J lCJ'}1 H;!, j,;'-,~i"(.l1.,," ',1',-,,\" 'J:, ,!:",ti\i; 11't. \;l"k'!:,'ijl" d db']'ll 10 til'(\J!n.,' ';;,..rl.!ly :r\ lht" ':,l:,t' ell,'!J 1:ll'("!', tA.'1 <; ':,,;; '.,I.n~!' ::,' ;,!l,' ;n'.-dl (). 1/)',;' . ;lr"J..I,', lws.,h!ill _____~.._"__.___.____.._.__._._,h_..' "'n._"_'>_...____ Tny p!'OIW No I':, antl my tH:nJPI1!IOl'lI<; ~' 1 !:;W'! .~( i ulltk...f)o:.(',l 01 c!irr.inill c:-t<;l':; a~;:tjn:,,1 0'" Pt;l'dll'HJ ;., H1" CC:J'l. ' C0llnly i'relff'll a<;, Inilows ;IlUl.W.H;.-I." 3 U \1 "n-,yi" 'He) Ihe ,010 ownerls!O' } [J II am!We are) JOtnllcnaOl(S) in rJ n arni'w'Je ilre} lenanl(S) by the enfilcly WI . In ltw !:.illl1 COUIl!V 01 re.]l eslalu S>~\jiltec1 ;t:; h:!U-(l:i, 'lit d PJfCt~1 01 QfOUFld, in ~h!J:' If1I1H)_W;W1 :rji!H~ Ll 80ro L] r....'P fJ Cilynt , 'iilualed a! wh'ch 'S Illlr'O.."'d w,llllt'1'~ lollo......'ng t!ulld;IlQ'. (All oUler Il)lljr W'I,uHS 0' ronants b, me l~nt:H1ty rlll;st CJ'$I~n 'r:., ,-. 1".1 d'\! ;;1.11(.' !!'t diM t':':~":; JI rt;{' b0!:'.n cl !f:iS ~IJr;e C! 0'1 till iJttiJctlm.~nt hereto) 4 T~ll) ~a'c1 prOPt~.tv wnsohlHlncdbv mt' bv I'_"j D~~Pd C.j Will 110m 5 Trli: o' Dt'f!,l ':/0:1 I'i a:ltt~j ;\']j '~~h~~'r(j;,><j In :!o~' (;'1,(:-,:;, c! !ij>"~' P(~,=ufdfl! 01 Oee(ls r" Ae9'S!": (1! ','Jd,.; ClJW~:, r1 Dlf"d :-", W,!!Ho~.;1.V:;l__r;lgr;_ :\nd!tll.,:UI,;'<;ir, myname [j nndnWSrli'j';C:, n"fl\l~ .41$0,1 p;'\!r;l'lln! glOlmn I!! <tIle ________~,~.'~ ~~~______ ~;hh~IN1 i1! ______W<lrri Illlhl' 1-"1 [<;JIO [.' TAr) C-; [,.ly.;I ._,'__ ,n 't1t~ r' Wl'\ hrHn [)H'n ~-~l VM fl0('.. VII __ P;qe __(11,____._____ 6 [.1m nol SlfrH'I on a.....,. U(lnll ol any ~lld (,~Cl'r;! a:;; !oPO'o"" CAll ,~I."~ ir;r ".., r Tht~ ..; DeNl ' H,e ,~li" pr: p,;!l'y wa~ Cbl':I>PN2 by 'flU hy' , [)t,pd 'NIl! I;; rj,lll'd and IS rf;uwj;~(J .fJ C{:...nl.... al'il ,,., in [; 'n..,. rloHlIt.' n rtnd my SllOlJ:;!! 'c; "dn~p (l[~~M~""'1 TliP!p iH~ no fl'C~lg,lge~ O~ Olr1l'f her;'; Ul 1~'~CU!"I}!<H~(;r':. ol i!ry ;'.I~1d V' l1"!:(,fipl.'Jfl. U!Hlll !ill~ ~ilid l)I(,!lljS~" ,111(1 lhmll lll(~ no Judgn1l.'Il!' aU,llr151 me p-J(c.epl as follow~ MGllg,l'Y'S d, ';1'1 f(;i1~l HI !11I~ H.'('('l(j"f 01 0"'1',10; nn ""',1 f'ifflnf)fly ___~_~_,,__ MOIlq;hl.... <I'> ~)HlIOllh 1!1 It;!) J1(.(.O!t...~r 01 DPI~tj~, on ~f'COf](; urOf)mly _____.___ J!Jdr:;rr\~n!<: 'l~"llie~$___ RI'(l1 "c;lalf> 1:101\<; 1\;I\j' ~f'I'n p.llrt PJr::r>pl e TIll' ;lc;'~j'<;;',"(l v;j'U;j!'Q" of '~ilid f"",rn'''tw. '<:' ~______~_________"_______ 9 No Jllf.lU'f,'_:nll'il'> n.'.:'! <::<nlt.'t(;'\1 01 <iCI:Oll in<';!t!'11H.I ;1tP;r,~! HIp U[W:f'.1 fO/!;':lf',-III;cn'J"il,II1CI' plcqll 10 I ha'o'l' !pad f.iHelu!J", Wl' 1<J!pgolng alll(:;I'Jil.:md"i<.r.O"'J Hial tl r; IrlW and C~~/I;'C: S...(lln Idl!II!!;,,!]) <tna ~;lJll',c.1 ,t'.:'1 t);'lor.. 11\,. till'; t :1l. fA ..... C 'j'r'" h' SE:Al SlM .~, 0:1,1 [,1_ "I --~ V, I ~ ~-_..,. .__.._--,--------~, '\ "'."1-"," ..'''.',...... "'. ~; lll. ~ " ' ',' - -l\ 'f;.i ~ '"'' ST BE COMPLETED --~ CERTJ.liICATION OF BAIL ~'-A'ND DISCHARGE PCl'CI (,10.:,\ tl'.l llJnl OTN <" "",,,,,,,, 94-1004 Civil Texm '.".' , ',,',> ''','', i"", <1;"".""., !,.l.,tu.,,"., ,...~I.l" ,';, !JAT[.':)fCIlMVi{j'il ll:luglils \'/. Miller ~40 Fairground Ave. Carlisle. PI\ 17013 i ! Hor~ Inn SlHl!IYI [J Nominal Billl lX Baillloltll alTlount sol.ll any) $50 [-J Conditions 01 Release {aSIde horn appearing al court w!len reQuired: I Cbnterpt (V.iolat.ion of Protect.ion f:rom Abuse Order) TO NEX r COURT ACTION lOCAIIO" CourtD:x:In 2 . Q). CourtiDuse o Othe, Cooply in all respects with the pr.ior Order of Cburt issued March 11, 1994. IJAll "Ol!' "Vi 4/15/94 - 1:30 P.M. 52 Detention CfmlCl (allach addendum, II ncccssilfY) I hClcoy certify lhal ~;ulllclelll btHI tms boen entored [J Bv 1I1fl' delunclilrll :Sf] On behall olltla dofendant by: Mruully(;n~;Ulll' I oI~ MHI [1 SUfely Company JtJ ProleSSIOfltll Bonosrno1f, [] Really [} Olhm Vivian ax:key 707 (',J"'" '" A.n, .'~~ pI ~;w,".! II 'Ct"lSf' ,'~(l! $500.00 . Roluil<f of C0l5h bilit \'Ilil he mado wlltJln 20 days allcr 11!l.11(j1~;PO:;lhon (PH fle, r 401S(b)) J. Wesley Olar, Jr. . R.,hmd 01 all Olll(OlIYP'lS 01 b<lll WIll h~ rnadcprornpUy aller 20 (lilys lollowlng Iln~1 dIspoSItion. (pa,R.Cf,P. 4015(a)) . H'll1g Ca~h Batl Hf'CCIPlloClcrkof Courl JUI '\.! ~Jrll':>',I':llj:, .\Ul"U'II! Y APPEARANCE OR BAIL 80ND DISCHARGE TIlE ABOVE.NAMED OEFENDA,Nl.FROM CUSTODY IF IlElAINEIl FOR NO OIHER CAUSE IHAN TIlE ABOVE siA1EQ, THIS BOND IS VAllO FOR THE ENTIRE PROCEEDINGS AND GI'oHI UllOiH rny tl;mc ilna lfJe~Olllclal Seal ollhisCourt.. \" UNTIL FULL AND FINAL DISPOSITION OF THE CASE INCLUDING __:,.\ FINAL, DISPOSITION OF ANY PETITION FOR WRIT OF CERTIORARI It", 11 th ~ay 01 April .,.... . 19 94 OR APPEAL TIMELY FILED IN THE SUPREME COURT OF THE , ' =:e' .' '\ UNITED STATES, _.~.h ~C~"":"",,,,:,,:~&, Jrotni:[ALI WE, THE UNDERSIGNED, delend.nf .nd lorely, our IUccollorl, heirs and .solgnl, o,a Jointly and leverally bound 10 pay 10 Ihe CommonweallholPennlylvanlalhesumol Five BYrnlred -------,-----------":- dollarl(S 500.00 ..' ). SEE REVERSE SIDE FOR 8AIL CONDITIONS CERTIFICATION OF COUNTER INDEMNITY AND PREMIUM (Applicable Only When Surety Is A Corporation) ,PrmCID.H. and hmeby CCrllly th;U the .1mounl pall1 bV \a111 PllnClpallo said Surely lor MI! 10 Ihe abc'o'e malter IS S and thaI nolurlnr.r ~Ilm or M/fllS IS In le p.1ld therelore by Ih~ s,:M PrmnPdl or an)'Ofie on tll!t betldil Vir lurlhf!f r NIIIV Ih.1l Sc:l(1 Punupal has 91\'CO III ~'ud ~ulrlv (.uun!f:r moemnllV 1.0fl~lshnQ 01 olllle \<trut: 01 ~ aslallows , SUfety aM no lurlher tounler mdemmly IS 10 be gIven tho said Surely elcepl We lurthel [Crilly lhat lnete are no ludgments a9all1stlhc ~ltJ tOlpalclte sUlely outSI,1001llQ .1;10 unpalc lor a celiO<! tll mOle IIldn thlrly days !rom HIe €late ollne enlly 01 WLO Judgment e.tepllhose In whIch a pellllon to open or vacate the judgmenl nas ueen !llell dnd lelllnln~ I,r'k;po~ed 01 Dated ,19 "''''~'l\W (S~ALI MUST BE SIGNED IN PERSON BY THE APPROVED AGENT I ACKNOWLEDGE THAT I AM LEGALLY RESPONSIBLE FOR THE FULL AMOUNT OFTHE BAIL. ""'t'/t. (SEAl) / 'olALI The fOIlOWJf!(l dcllnolVltff1gemenr IS .1150flfml/Cd(Jlt~" , If Pmcl'f'I.I!)t! C;nryOJilI;' u5('d rHISfJOND'>I"'n_OOfI Jlpril 11. I ,:11 ~Arl iRl". " , ; ,:)I[jf1"d ,1I,lJ .It ~l1'l"":"ll'Jt'(j belol.'flll' ;111'. 11 th " day of JlDril .. \ " rJ . ,'~:I'\\' \ (\ ""--t-d.'I\..J 'L-.- 1 ~.2L IHmSYl VANIA .':;Hlnitture 0' SlIfOly (M,lY IJtJ Bonds.f Jill/ Ayencv. IJf I)f/VdW m:1Iw(11/,J1 Of {JrY,Ifl/l.HiOfI) ("Ct'ot ~'lf I "t'nd.m"5 rc/c.Ut'd on '1/5 (j,'m ft'coqnll.lIICC ,HOR) Ntis must W slgnt-{j m iIIl bml s,tuJtiofl'; me/i/d,flg nom,nalb,fI! (5t^LI ,19.2!- ,\[,; "I ','" ',j '"L'''i,; I '.i,I,\:. I (':l,h'M,'f' r~ll r,! II '~PA!.I ,-1 ',','. "',,', I f<". I '" "I ,,,,,,.",, \1.,.",' · In (."J~,t' of corpoI,lIf' ,\urpfy tl,lll Pm"!'f of "/f,IInf'''' "I',",' tJf' a"'.f'll to f)(mdn: tllhf!fWI<;t' tJOfl(/,\ mV,jI,d iltHlf'i:'P,:,', ("w · In C,J',l' {J/ P"'Cf"Jt,Jlj(' ('.J~.lllhilOl NOfllllt:JIlJ,III, Pm..'" 01 A"O"'('y ,... "or 'f'lllll/l'll A, ." ,. DEBRA C. LaVALLE, IN THE COURT OF COMMON PLEAS OF Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . v. . CIVIL ACTION - LAW . . INDIRECT CRIMINAL CONTEMPT . DOUGLAS W. MILLER, Defendant : 94-1004 CIVIL TERM IN RE: GUILTY PLEA ORDER OF COURT AND NOW, this 15th day of April, 1994, the Defendant, Douglas W. Miller, now appearing in court with the Public Defender, William G. Braught, Esquire, and having tendered a plea of guilty to indirect criminal contempt for violation of the Protection From Abuse Order of Court dated March 11, 1994, the Defendant's plea of guilty is accepted. By the Court, THOMAS A. PLACEY, ESQUIRE -CcpI,I ~(I.(; "Ij:J~frl'l wl!'f Assistant District Attorney U WILLIAM G. BRAUGHT, ESQUIRE ~ Cb(.X,j S,1,1t '-I!JI:J)'1V /.lJOf Assistant Public Defender . U wcy .... -a '"' ..... Q:) ~,~ ~'t: :: -; \ '"~ ,- "' .. ," , ' ",~. '. e.,> ,.1 '~. .,"'...., ~~.. :~; ~~ :~. ~~ (~~ n I.:\_~~""l """, "'2- -C.. - C,CI .s:;.. N N -J -'" = !.~<..,"-r:.-"....." .. DEBRA C. LaVALLE, Plaintiff IN THE COURT OF COMMONjLEAj;OF CUMBERLAND COUNTY, PENNSYL~IA ,. = CIVIL ACTION - LAW \;~, INDIRECT CRIMINAL C6~~~PT~ "r . .-1";:; -..,J 94-1004 CIVIL TERM I::: ;J'" ;;:;] ""'1';;;- ... v. DOUGLAS W. MILLER, Defendant IN RE: c.C oC. SENTENCE ORDER OF COURT AND NOW, this 15th day of April, 1994, the Defendant, Douglas W. Miller, now appearing in court with the Public Defender, William G. Braught, Esquire, and having previously entered a plea of guilty to indirect criminal contempt for violation of the Court's Protection From Abuse Order dated March 11, 1994, the sentence of the Court is that the Defendant undergo imprisonment in the Cumberland County Prison for a period of one day, said sentence having been agreed upon by the Commonwealth and defense. It appearing that the Defendant has served the period of one day in prison, he will not be committed to prison at this time. The parties have agreed in open court to an exchange of their child's toys in possession of Mr. Miller through the Defendant's depositing said toys with Legal Services on or before April 22, 1994. The Defendant has been advised that the prohibited contact between himself and the Plaintiff and the Plaintiff's relatives includes contact, direct or indirect, and contact either by him or by other persons at his behest. .. By the Court, J Wesley 01 THOMAS A. PLACEY, ESQUIRE- CbPj '('t1i'l),)'6/1y wet Assistant District Attorney WILLIAM G. BRAUGHT, ESQUIRE-Cq:x.) sent "Isahv we'! Assistant Public Defender CCP - CC(J~ ,Yfr{ ...; /;Jb)'N ble i wcy CASH OR NOMINAL BAIL BOND CERTIFICATION OF BAIL AND DISCHARGE OTN POUC[ CASE NO OJ NO COMl,tONWlAlTll ~ f~ n.n. MJd ~I cr "R~'NO 94-1004 Civil Term I ACKNOWLEDGE THAT I AM LEGALLY RESPONSIBLE FOR THE FULL AMOUNT OF THE BAIL. Tho 'allowing acknowlodgen"",t is also applicable ') / . it Percentago C.'lSIl Bad is used. Iii) r'.., /, _ ,_ _',' THIS BOND SIGNED ON Mav 23 10.J!!.. 'itr.NATl)R[ OF O"[NO"" .L._,. Carlisle PENNSYLVANIA, //--. --- I i ,-- ..----. {SEALI Douglas W. Miller 440 Fairground Avenue Carlisle, PA 17013 IX! ROR (no suraty) 0 Nomi.., Bail o Bail (lolal amount sel, " any) $ o Condlhons 01 Relfass (aside horn appealong at court when requiled,) CHARQEISi DATE OF CHARGEtS) Contempt (Violation of Abuse Order) Protection of DAlE ANO TIMe NEXT COURT ACTION LOCATION Courtroom 115 o Other 5 27 94 - 9:30 a.m. TO: 0 Detenlion Cenler I hereby certily that sullieient bail has been entered o By the delendant DOn behall 01 the delendant by: SECURrTY OR SURETY IF ANYI o Cash In lull amount 01 bail o Percentage cash bail o Money lumished by o Delendant o 3rt! Party .A.IOGE OR l5SUNJ AUTHORITV Hon. J. Wesle Oler. Jr. (attach addendum, if nacesaary) tNilt1w & M:iwa 01 SlntyJ (LbJrnse NoJ . Relund 01 cash bail will be made within 2D days alter li..1 disposition, (PaR.Cr,P,40 15(b)) . Relund 01 all olher types 01 bail will be made pIOmpfly alter 2D days loIlowing linal disposltion.(Pa.R.Cr.PAOI5(all . Elling Cash Bail Receipt to Clerk 01 Court. APPEARANCE OR BAIL BOND lJSCIlARGE THE ABOVE,NAMED DEFENDANT FROM CUSTODY IF DETAINED FOIl NO OTHER CAUSE THAN THE ABOVE STATED, Given under my hand and fhe Ottieial Seal 01 this Court. nus BOND IS VAUD FOR THE ENTIRE PROCEEDINGS AND UNTIL FULL AND FINAL DISPOSITION OF THE CASE INCLUDING FINAL DISPOSITION OF ANV PETITION FOR WRIT OF CERTIORARI OR APPEAL TIMELY FILED IN THE SUPREME COURT OF THE UNITED STATES. this 23m dayaf Mav ,19 94, a~t:i.. d )'Y' ~.ill.A ~ (SEAL) ''''''' 01 Ciul" ...... Aur"""/)>/Deputy Prothonotary WE. THE UNDERSIGNED. defendant and surety. our successors. heirs and assigns. are jointly and severally bound to pay to the Commonwealth of Pennsylvania the sum of dollars ($ ), SEE REVERSE SIDE FOR BAIL CONDITIONS TO BE USED ONLY FOR PERCENTAGE CASH BAIL: The understgood aboullo become Surety in the case ciled herein, being duly sworn (or affirmed). deposes and says: 1, I reside ot and my occupation is my phone number is nnd I work for 2. I h.1ve no undisposed of criminal cases against me pendillQ in the Courts of tho aforesaid County, except as follows: 3. I am not Surely on any bond of any kind except as follows: lMTE AMOUNT DEFENDANT 4 I hove carelully read the foregoing affidavit and know il is true and correct. Signed and acknowledged before me this 23rd d.,y 01 May , 10..!Ii. Slgnatrxa 01 Sr.mty (May be Bondsman, Bait Agency, or private inrJlvirIuIlt or organlzalion), Excep/ when defendant is released on his own rocognlzonca fRORj, this must be signed In an bad situations, IncflKllng nornml ball. (SEALI ICbll: 01 Call a ~ AufnrooItyl Deputy Prothonotary AOORE5S0F SOUL TV. SUnLTV CO"'f'ANY OROHEHOAHT AOPC 4'J.82 ~Nn OI~~l-=tnMtNo &C~oe ORIGINAL COMMONWEALTH I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I 94-1004 CIVIL TERM : I INDIRECT CRIMINAL CONTEMPT v. DOUGLAS W. MILLER IN RE I TRIAL DATE &: ROR BAIL SET ORDER OF COURT AND NOW, this 23rd day of May, 1994, upon consideration of the Complaint for Indirect Criminal Contempt, and the Defendant, Douglas W. Miller, now appearing in court without counsel for the purposes of scheduling a trial on the charge, and the Commonwealth, in the person of William I. Gabig, Esquire, having indicated no objection to the Defendant's release on his own recognizance pending trial, trial in this matter is scheduled for Friday, May 27, 1994, at 9i30 a.m., at which time the Defendant is directed to appear with counsel without further Order of Court, and the Defendant is ordered released on his own recognizance subject to the execution~f the ~ .. -'" necessary release documents. .....' ~.'; By the Court, w CJ'I ... -a :x: !" ;... T-' :"- ~;. -<,.., - ~ ~ J~ Wesley William I. Gabig, Esquire Sr. Assistant District Attorney CCP / Islr " ~~: ,:;d f , ~ COMMONWEALTH IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 94-1004 CIVIL TERM DOUGLAS W. MILLER INDIRECT CRIMINAL CONTEMPT IN RE I BENCH WARRANT ORDER OP COURT AND NOW, this 27th day of May, 1994, the Defendant, Douglas W. Miller, having failed to appear in court as directed by Order of Court on May 23, 1994, for trial on the pending charge of indirect criminal contempt, and no reason having been given to the Court or to the Office of the District Attorney for the Defendant's nonappearance, it is hereby ordered that a bench warrant shall be issued for the Defendant's arrest. By the Court, .. ~ !It4. ~ ",,, ~ J. Thomas A. Placey, Esquire Assistant District Attorney William G. Braught, Esquire Assistant Public Defender :slr ; r1:~.':. ..'-~ , .",. ~ ~ ~ "'> ... .r ,... -.: ' ~ ...i'- :,.. (~: ' 4f -,. -"... ''''-~'- ij,.. :"~ ,. ,.' "- ....... - ::C 'f , v. " ";;1. '.. I.. ~ _,_,,--l '" . . COMMONWEALTH OF PENNSYLVANIA SS: OCA: COUNTY OF CUMBERLAND TO: R. Thomas Kline, Sheriff, or any duly authorized law enforcement officer. RE: D:lllglalO W. Miller DOB: 8/1/61 SEX: Malo SOCIAL SECURITY # 204-486-370 RACE: Cauca'\tftl1 5 I 8" WT: 165 Last Known Address: 440 Fairground Ave. ~~rliQl~ PA 17nl~ EYES:~~~HATR:-F~OTN: Failed to appear for A IlEARIN,y . 1004_CIVIL 199.3 WHEREAS, the defendant above named failed to appear before the undersigned on May 27 , 1994 as directed, on a charge of PFA CONTEMPT filed by Oxmonwealth WHEREAS, this Court on May 27, 1994 directed a Bench Warrant issue for the apprehension of the defendant. This is therefore to command you to arrest the defendant above and bring the defendant before me at Carlisle, Pennsylvania, without unnecessary delay to be dealt with according to law. WITNESS the undersigned Judge, at Carlisle, this _27th day of -- . May A.D., 19l1-. ATTEST: Isl J. Wesley Oler, Jr. J. ~ -.p -ir; /;)Bt' thcinotary (SEAL) ....".'Iir'7' ~~~;!;1", . COMMONWEALTH v. I IN THE COURT OP COMMON PLEAS OP I CUMBERLAND COUNTY, PENNSYLVANIA I I 94-1004 CIVIL TERM I I INDIRECT CRIMINAL CONTEMPT DOUGLAS W. MILLER IN RE I AMENDMENT TO COMPLAINT GRANTED ORDER OP COURT AND NOW, this 27th day of May, 1994, upon consideration of the Commonwealth's motion to amend the complaint for indirect crtminal contempt filed on or about May 21, 1994, in the above-captioned matter, and the Defendant's counsel, in the person of William G. Braught, Esquire, having indicated no objection to the amendment of the complaint to add Commonwealth's Exhibit 1 to it, the motion is granted, and Commonwealth's Exhibit 1 is added to the complaint for indirect criminal contempt. ~.j ...... By the Court, ~ Wesley Thomas A. Placey, Esquire Assistant District Attorney William G. Braught, Esquire Assistant Public Defender Islr t"""",,,,,~,,, ~ ~ ZE "" o M ~ .r~ ~,- IAJr- '.:- O~..,':f .;: c;Q;; ~:.~ ,":i:-' ~ _.- . ,~ ," " :_';,/1 ".'r. .,..;'.r . ;,';;"" ,~ ::t.. 0.::.. ,...::t 0<'> "- <'oJ .... ~ R. THOMAS KLINE Sheri II ~\'Q, ot <<u"'''~~ ~O ,~'1' '0 ~' ,~ ~. ,,!~,. t 'f&'~~Ir)...',. J '/ ,~;!I" .~ ~.'; ~?'" t,:'" ~::,("''':'~ll'~''-;~;''.. .' 'c':.:'" ~ AUDREY G. ADAMS Reel Eelele Deputy RONNY R. ANDERSON Chief Depuly HORACE A. JOHNSON Sollcllor OFFICE OF THE SHERIFF Court House Carlisle, Pennsylvania 17013 May 31, 1994 Mr. Lawrence Welker Cumberland CO. Prothonotary Cumberland Co. Court House Carlisle, Pa. 17013 SUBJECT: Civil Subpoena 1. / 94-1004 Crim Douglas Miller ( 1 ) 2.80 Total $2.80 So ans~er : , ./"':-:;~ .~ .... ,-,-' ..,,' ,-.:<~.I"';"'\.~ -?" ,.. /? ;:,;-:-.r:~:-:c '. ._. ..:, .....v..-- .." ~ . " ' R. ,'. COMMONWEALTH IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : 94-1004 CIVIL TERM v. : DOUGLAS W. MILLER : INDIRECT CRIMINAL CONTEMPT IN RE: BENCH WARRANT VACATED & TRIAL DATE SET ORDER OF COURT AND NOW, this 1st day of June, 1994, the Defendant now appearing in court with the Public Defender, Arla M. Waller, Esquire, on a bench warrant issued as a result of his failure to appear for trial on the charge of indirect criminal contempt on Friday, May 27, 1994, and it appearing that the bench warrant was not executed, the said bench warrant issued by this Court on May 27, 1994, is vacated. Trial is rescheduled in this matter for Tuesday, June 7, 1994, at 3:30 p.m., in Courtroom No.5, Cumberland County Courthouse, CarliSle, Pennsylvania, at which time 'the Defendant is directed to appear without further Order of Court. Bail is set in this matter at $250.00. By the Court, I ( Travis N. Gery, Esquire Assistant District Attorney Arla M. Waller, Esquire Assistant Public Defender Sheriff :slr t:-~ . ~, 1,:, ..... en J->o -'. ::x:: 1-- ,- ..f ~: .- .0,.) o C> ::"'1 ,.-~!:'.:- 't""~i '" ~ ......, Jr. I~ & M:ha 01 Stnty, . Relund 01 cash bail will ba made within 20 days alter linal disposltion, (Pa,RCr,P,4015(b)) . Refund of all olher Iypes 01 ball will be made promptly alter 20 days following linal disposltion. (PaRCr.P.4015(a)) . Bring Cash Bail Receipt to Clerk 01 Cou,t. OISCliAllGE THE ABOVE.NAMED DEFENDANT FRDM CUSTODY If DETAINED FOR NO OTHER CAUSE THAN THE ABOVE STAff 0, Given under my hand and the Official Seal of this Court. ILIcanIe No' CASH OR NOMINAL BAIL BOND CERTIFICATION OF BAIL AND DISCHARGE POlICE CASE NO OJ NO OTN CP IEn...I"O 94-1004 Civil Term COMMONWEAUtl vs ,DMn1lt1t""" Ind Acl.teUJ CUARQEISI DATE Of Ct4AnGWll Douglas W. Miller 440 Fairground Ave. Carlisle PA 17013 o ROR (no surety) 0 Nominal Bail IKI Bailllolal amounl set, if any) $ 250.00 !Xl Condrtions 01 Release (aside I,om appearinO al c...t when reqwred) Failure to Appear for Hearing May 27. 1994 (Conterp Charge of PFA Order) Appear at hearing Tuesday. June 7, 1994 at 3:30 P.M. Courtroom 5. CUrriJerland County Court:h:>use. Carlisle, PA 6/7/94 - 3:30 P.M. TO: &J Detention Cenler NEXT COURT ACTION LOCATION Courtroom 5 CUrb. Co. CourtlDuse o Other DATE AND lIME I hereby certify that sufficient bail has been entered IKl By lhe defendant DOn behall of the defendant by: (attach addendum. If neceasary) SECURITY OR SURETY If' ANYI lid Cash in full emoun' of ball o Percentage cash bail o Money furnished by o Defendanl D3rd Party JUOOE~ fbn. J. Wesle Oler, $250.00 APPEARANCE OR BAIL BOND THIS BOND IS VAUD FOR THE ENTIRE PROCEEDINGS AND UNTIL FULL AND FINAL DISPOSITION OF THE CASE INCLUDING FINAL DISPOSITION OF ANY PETITION FOR WRIT OF CERTIORARI OR APPEAL TIMELY FILED IN THE SUPREME COURT OF THE UNITED STATES. Ihis 1st day of June , '9 94 , J\i;~~":,,,~,~~t~~SEALI WE. THE UNDERSIGNED, defendant and surety. our succeslors. heirs and assigns. are jointly and severally bound to pay to the Commonwealth of Pennsylvania the lum of dollar. tS ). SEE REVERSE SIDE FOR BAIL CONDITIONS TO BE USED ONLY FOR PERCENTAGE CASH BAIL: The understgned about to become Surety in the Cc1se cited herein, being duly SlNQrn (or affirmed). deposes and says: 1. I reside at and my occupation Is my phone number is :md I work for 2. I have no undisposed of criminal cases against me pendif\g in the Courts 01 the aforesaid County, except as follows: 3. I am not Surety on any bond at nny kind except as follows: (lATE AMOutH OEfENDANT 4_ I have carefully read the lorogolng nfUdavit and know it is true and correct I ACKNOWLEDGE THAT I AM LEGALLY RESPONSIBLE FOR THE FULL AMOUNT OF THE BAIL. The /o/Io.ving acknowfodgement is also appIicablo ; 1'- / L,., Y/I .~ i/ PcrcenulgO Cash Bad is used. X O(J A/V'- II (.A.../ THIS BOND SIGNED ON--.-June 1. 19.....2.4. "GNAW"' 0' OHl"D'"' at___ Carlisle. PENNSYLVANIA _y'1'( ;tA ..<:',,<:au.....l."'7vA:.. (..q-.!(.)/~ Signed and acknow!edgod before "'" Ihis SignaIulO 01 Suroty I M..;t bo BondsmM, Ball AfI""CY, 01 private ItldlVldual 01 organization I. Ercopt when delenclMt IS roIoased on hiS 1st d"yof June , '9 -9A- own recognlzanco IRORI, this must bo sq,ed in 011 bail sifuafions, IfICludtng norrnnal ba.,. (SEALI ISEALI ~~. . ....... ~ Dpty. Prothy. AOOR[SS Of" SURErI'. SOREl'( CQMP4NY OR DEfENDAPH $&nIf')' No M ~ ~ Lcense No & (.,.alO1 "* AOPC <4 \3.62 ORIGINAL , , DEBORAH C. LAVALLE, Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : . . v. : DOUGLAS W. MILLER, Defendant . . . . . . 94-1004 CIVIL TERM ORDER OF COURT AND NOW, this ll~ day of July, 1994, upon consideration of Defendant's Motion for Post-Trial Relief, the motion is DENIED. BY THE COURT, w~ J Wesley Oler, Office of the District Attorney William Braught, Esq. Assistant Public Defender :rc -::r O")c .1-... _ ~t .... '::~t "..'. ,.. CO" co ......., ( . .' . -, = -, ,-~. DEBORAH C. LAVALLE, Plaintiff . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94-1004 CIVIL TERM . . . . V. . . . . . . INDIRECT CRIMINAL CONTEMPT DOUGLAS W. MILLER, Defendant ORDER OF COURT AND NOW, this day of , 1994, upon consideration of the within Motion, and on motion of William Braught, Esq., Assistant Public Defender, it is hereby ordered that a hearing shall be schedule for , 1994, at , the day of o'clock __.m. in Court Room No. , Cumberland County Court House, Carlisle, Pennsylvania. BY THE COURT, J. DEBORAH C. LAVALLE, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94-1004 CIVIL TERM INDIRECT CRIMINAL CONTEMPT DOUGLAS W. MILLER, Defendant MOTION FOR POST-TRIAL RELIEF TO THE HONORABLE JUDGES OF THE SAID COURT: AND NOW comes the Defendant, Douglas W. Miller, by and through his attorney, William Braught, Esquire, Assistant Public Defender, and respectfully represents as follows: 1. On May 21, 1994, a complaint charging Defendant with indirect criminal contempt for an incident which was alleged to have occurred on May 21, 1994, was filed. 2. On May 27, 1994, the aforementioned complaint was amended to include four alleged incidents of tire slashing of the Plaintiff's car allegedly by the Defendant. 3. On June 7, 1994, a hearing on the above alleged protection from abuse violations was held in front of the Honorable J. Wesley Oler, Jr. 4. At the hearing, the Commonwealth presented evidence in the form of testimony by the Plaintiff, Deborah Lavalle, and by Larry Readcap, the boyfriend of the Plaintiff. Neither of the two aforementioned witnesses testified as to ever seeing the Defendant slash any of the tires on any of the four alleged incidents, no f. ",-" .."..':-,\. testimony was presented that any person had seen Defendant slash any of the tires on any of the alleged incidents and the Defendant never made any admissions that he had slashed any of the tires on any of the alleged incidents. 5. At the end of all the testimony, the Honorable J. Wesley Oler, Jr., found Defendant in contempt for violating the protection from abuse order with respect to the May 21, 1994, incident and the four alleged tire-slashing incidents. 6. The Defendant was sentenced on June 7, 1994, as to each , ~ I, I ,( I, 11 count to pay the cost of prosecution, undergo imprisonment in the Cumberland County Prison for a period of forty-five days, the sentence to run concurrent for each count and that the Defendant j '~ J , three dollars and eleven cents. make restitution in the amount of one thousand six hundred fifty- 7. The evidence presented by the Commonwealth was insufficient, as a matter of law, to support a finding of guilt by the Court for the count of indirect criminal contempt arising out of the violation of the protection from abuse order relating to the four tire-slashing incidents. B. Defendant respectfully requests that this Honorable Court enter an entry of Judgment and find the Defendant not guilty of the tire-slashing incidents due to insufficient evidence. , ~ . . . WHEREFORE, Defendant respectfully requests this Honorable Court to qrant his Motion for post-trial relief. Respectfully submitted, :?lJ/JfNu,V {;.,/tParjl r ~ 1 iam Brauqht Assistant Public Defender Attorney for Defendant " ~J\)L 111994),,- .. . . 94-1004 CIVIL TERol EBORAH C. LAVALLE, Plaintiff v. LAS W. MILLER, Defendant MOl'ION FOR RlST-TRIAL RELIEF Wi11icm Braught, Esquire OFFICE OF THE PUBLIC DEFENDER OF CUMBERLAND COUNTY COURT HOUle CARLIBLIE. PENNSYLVANIA 17013 ~ 1 \' . 1 ~-~, DBBRA C. LAVALLE, Plaintiff IN THE COURT OP COMMON PLEAS OP : CUMBERLAND COUNTY, PENNSYLVANIA : v. : 94-1004 CIVIL TERM : I : INDIRECT CRIMINAL CONTEMPT DOUGLAS W. MILLER, Defendant IN RE: SENTENCING ORDER OP COURT AND NOW, this 7th day of June, 1994, the Defendant having bean found guilty by the Court of two counts of indirect criminal contempt arising out of violations of the protection from abuse order previously entered by this Court, the sentence of the Court as to each count is that the Defendant pay the costs of prosecution and undergo imprisonment in the Cumberland County Prison for a period of forty-five days. The prison sentences imposed herein shall run concurrently with each other. With respect to the damage to the vehicle of Dabra C. Lavalle, the Defendant is ordered to make restitution in the amount of $1,653.11. Work release is authorized for the Defendant. By the Court, We- /J /7( I , J. Thomas A. Placey, Esquire Assistant District Attorney William G. Braught, Esquire Assistant Public Defender .J;'. , , .. /l6. HJ Pi; I G I/nr , CCP lslr [' DBBRA C. LAVALLB, Plaintiff I IN THE COURT OF COMMON PLEAS OF I CtlMBBRLAND COUNTY, PENNSYLVANIA I I 94-1004 CIVIL TBRM I I I INDIRBCT CRIMINAL CONTEMPT v. DOUGLAS W. MILLBR, Defendant IN RE I DEPENDANT FOUND GUILTY ORDER OF COURT AND NOW, this 7th day of June, 1994, upon consideration of the charges of indirect criminal contempt for violation of a protection from abuse order entered by this Court, and following a trial, the Court finds the Defendant guilty of two counts of violation of the protection from abuse order in the form of indirect criminal contempt. By the Court, J. u/,.. Thomas A. Placey, Esquire Assistant District Attorney William G. Braught, Bsquire Assistant Public Defender CCP lslr 7' .. '-'. , ~ -. ~ .;: , ; C(t(-, /60 4.- J ) /UJb-- d . Clt/I/ , . , I l " 'I , \ I Ll-lf. Lf- =r~ Q-.. " # , Refund of Bail Court of Common Pleaa - Criminal Diviaion, for the County of Cumberland. Debra C. Lavalle No, 94-1004 Civil TeIlTl Tenn, 19_ vs. Charge: Indirect Criminal ContffiPt I:buglas W. Miller I hereby certify that the cash bail In the amount of $ ''in nn deposited with me In the above captioned case, was deposited with me by, MaIY Miller. 444 FairQround Ave. , ~1isle. PA and to the best of my knowledge Is the personal money of said M~"1' Mi"lCIr who Is entitled to the return thereof at the tennlnatlon of the case. This certificate Is made for the purpose of instructing the ~~. L_ to whom the said cash bail Is payable at the conclusion of salcl case, Witness my hand and seal this 23m day of .1l1np A. D. 19 94 [SEAL] ~;tfo~t~ -P"fL~~~- Order Of The Court And now, -;t uJJ ~ Z. ~ ,19n, It appearing from the foregoing certificate, that the cash baU deposited In the above captioned case are the proper funds of Marv Miller _ Protlnnotarv and the conditions of the ball having been met the ~ Is hereby authorized to return the same to said MRry Millpr Pmtlnnotarv ',8 , less the sale! -0IDIiiS comnusslon as provided by law. By the Court, I ; ..J. BPH CRIMINAL COMPLAINT (POLICE) IDE PAULA P. CORREL DISTRICT JUSTICE MAGISTERIAL DISTRICT NO, 16 West High street, Carlisle, PA 17013 Complaint Numba.. II Othar Participants 09-2-0 2nd Fl or A 93418 COMMONWEALTH OF PENNSYLVANIA VS. DEFENDANT: r, I, NAME AND ADDRESS . .' c. DOUGLAB'W. MILLRR' 444 Fairgrouru2 >J\ve'nu.e Carlis1e,PA ,1'7013' , W/m,/33, D081,8/1/61' . . ._~ PI-1 ~hAnp ~ rnh;r.k, 17 ( Samt (~r Alf1anr J of ( IdrlllW' cJrpar'tnl"II' "' QKtncJ' rrpn'jrlllt"l1llfl (I(,/ltical JuMMMo,,) RSA AKA do hereby state: (I) 0 tlleeuse the above named defendant. who lives at the address set forth above or, o I accuse an individual whose name is unknown to me but who is described as - ~ ~ . '. .. " ~ . ~ is ~ o his nickname or popular designation is unknown to me and, therefore, I have designated him herein as John Doe: with violating the penal laws of the Commonwealth of Pennsylvania at rAr1; R1 p rri rp And RlIhhE!r c;;nn R'n~1t Nnrth {"nl 1"9" ~"'r,:ll~", ('Arl; R:lp, tJA (f'lu('t./l)//IIru/S"bJMsJrm) in rllmh..r1And Count yon or about Q!,,!Q4, Apprnl/ 041<; hr Partici pan ts were (Uthttr Wtl't' panlriflUnll, (lluff ,I1tir nQm~ hrrr. rrptaU'IJ: '"l' "a",to! abm'f' dtftndonl): (2) The ~eqP@JtMIIWd btt~~~~sed were: @ The defendant violated the Order issued under Protection from Abuse Act in No. 1004 Civil 1994 on the 11th day of March, 1994 by the Honorable J. Wesley 01er, Jr., which order directed the defendant to refrain from having any contact with the Plaintiff, Debra C. Lavalle, including her place of employment, being Carlisle Tire and RUbber, Carlisle, in that the defendant did appear at the Plaintiff's place of employment at approximately 0415 hour on September 22, 1994, did walk up to a window where she was working and state "where did I go wrong with our relationship." After being advised by the Plaintiff that he was not to be there the defendant stated that he could be anyplace he wanted. The above acts are in violation of Par. 4 of PFA Order. (4) During the course of the above PFA violation, the defendant did cause damage to a 1993 Ford Ranger Pick-up Truck, owned by Larry Roadcap and jointly used by th CONTINUED ON PAGE 2 .. . all of wlilcli were agamst !he peace and dlgmty of the Commonwealth of Pennsylvama and contrary to the Act of Assembly, . . , f?'~~~'1'I~,~.~n ""''''''''f;''~''~'-''>'-'''''''V''r-<''~''''; h "" ..'..,.,.......,....""..,',-..o..'.,....",...._~,.,~!=,.,.~V>__....~,..,.-.'.."'..~.'..i'.'....,.. ~ or 10 violation 0 ;\,i~)';, "90~w.;."':-"~,:},! and ':<)';\;:,;")<',""";;";",,-;;..,,:":;-i,~ of t e Act of "'-,..,,.",::.Tnh.A;-I.?<:lC;'4....Q.,.A~'DVa.~-i.,,'~:~.'. lion) ( SlIb. J<<tlon) or the . .'<:":i:-.:r~~{!;~:.w::~~ Ordinance of :;"':.~~:;:';~;:~~:'/~'~~t<.'~;:;.:: ';>>,,-.', ,., ~;;."'~',.:;.~: :;(;:;~_~,;:):;:::,~;f.\~7<:'2i.:~7:.,}{1.J;;fic I MII/ral SlIb. dMJ/oo) (3) I ask that a warrant of arrest or a summons be issued and that the accused be required to answer the charges J have made. J verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information and belief. This verification is made subject to the penalties ~ 4904) relati~ unsworn falsification to authorities. 'JM cl.:2 . 19 911 ~9~4 ~rimes Code (18 Pa. C. S, ~~ Z?LI (Slgnolllrro/ Complolnont) AND NOW. on this date . 19 _' I certify the complaint has been properly completed and verified, and that there is probable cause for issuance of process. ~?gffiil~}'{&.~~ij l.lIaglJltrfal DIJ/rirl) (/."'fllng Authflrlt.l') (SEAL) AOPC 411.86 ORIGINAL-SEE REVERSE SIDE FOR W^,VEI1 AND FOOTNOTES :tummo"s lerveu 0)' cerllflcu mUll, relum recelpl requc)lcu. F YOU ARE COMMANDED TO APPEAR BEFORE UNDERSIGNED AT: IDA" 19 on the day or (SI,nmllrrJ (mlt) fOf . prehmln.ry he.rlng Uflon the Ch.fge, In the nbovll cnmplalnl .((f'lfdlng to law, If ynu I..U 10 apP".' al Ihll lime and plltc.. a.. .Ialed nbow". ,. wlt"anl will be I..uod 'ot ynur ~u'e..1 nail will tM I..' at Iho Pfehm'nl!lty h."fln" You hnve th" f1Qhl to b. ",pIII'.ntad by . lawyer end II you cAnnol nllord It law.,." on.. will ht! ."lQned III ropr...nl you Sllllltlltllh ll'IUllh'll lilhldl\t..ICt! 1111 clll' d.H III r IJ~__._._~~_ ~TE ISSUED --..wa,UWlIL 11III1,.., (SEAL) - ,<-,;<"'~~'::" !;" ""'~"Jn"'J ;';.;...:'<;:;'~>, '- ( S""",",-) lDIINI.wntC..nv RETURN OF SERVlt'!E ...".-- page 2 - Criminal Complaint Continued - DOUGLAS W. MILLER plaintiff, Debra C. Lavalle, in that he did scratch the vehicle with a key or some similar item. I believe there is sufficient Probable Cause above to show that the defendant did violate the PFA Order. I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information and belief. This verification is made subject to the penalties of Section 4904 of the Cirmes Code (18 Pa.C.S. Section 4904) relating to unsworn falsification to authorities. , ~ September 22, 1994 _~LC _ ______:_ si~at of Affiant AND NOW, on this ____ day of September, 1994, I certify the complaint has been properly completed and verified, and that there is probable cause for issuance of process. -------------------- Magisterial District ______________________________(Seal) Issuing Authority IN RE: DEFENDANT FOUND GUILTY ORDER OF COURT AND NOW, this 22nd day of September, 1994, upon consideration of the complaint for indirect criminal contempt, and following a trial, the court finds the Defendant guilty of indirect criminal contempt by reason of his violation of the Order of Court entered in this matter on March 11, 1994, said violation occurring on september 22, 1994. By the Court, J JAIME M. KEATING, ESQUIRE Assistant District Attorney TIMOTHY L. CLAWGES, ESQUIRE Assistant public Defender CCP wcy ;' , . - ~ A; 1 '.:. ~1'-l ~'J'; .";, :,lj, ';~l ~.;I '_I; ';1r: . "d!'l~ Hi ~6, Il~ 92 6 Ql d;S t ,." "7 DEBRA C. LAVALLE, . IN THE COURT OF COMMON PLEAS OF . plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA . . . v. . CIVIL ACTION - LAW . . PROTECTION FROM ABUSE . DOUGLAS W. MILLER, . . Defendant . 1004 CIVIL 1994 . IN RE: SENTENCE ORDER OF COURT AND NOW, this 22nd day of September, 1994, the Defendant, Douglas W. Miller, now appearing in court with the Public Defender, Timothy L. clawges, Esquire, and having previously been found guilty of indirect criminal contempt for violation of the Protection From Abuse Order dated March 11, 1994, as a result of an incident occurring on September 22, 1994, the sentence of the Court is that the Defendant pay the costs of prosecution, and undergo imprisonment in the Cumberland County Prison for a period of two and-a-half months. By the court, Iii J. esley Oler JAIME M. KEATING, ESQUIRE Assistant District Attorney TIMOTHY L. CLAWGES, ESQUIRE Assistant Public Defender " V1 "' ... ,..., 0'> CCP . , -' ~ !_.~ . " ...t. - : J n ~.' '.~' "'" ...,: ~i; W N .... ~ wcy . c.Q .z=- '.. DEBORAH C. LAVALLE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW . . . . v. . . . . DOUGLAS W. MILLER 94-1004 CIVIL TERM . . AND NOW, this ORDER OF COURT t'-l tLday of October, 1994, upon consideration of the Defendant's Request for Work Release, a rule is hereby ISSUED upon the District Attorney to show cause, if any it has, why the relief requested in the Request should not be granted. RULE returnable in l5' days. BY THE COURT, J. District Attorney's Office Timothy L. Clawges, Esq. Assistant Public Defender :rc , ! ~; t--.t 'i:'1 ,) '.-j t{j.t ,I i I :1 I \ I \\t' \~ 1 'j~ ~~ ,~" 't \l;~ t f~ t' '-.~ ~." "( _ _ k;,.:~. \'1 t ~, .. ." : ,,') . ~ ,..' (jl.'.""'. ,~. ,,'\ ~ "', .,,~,.~i"J \~, ~ ", C':.,,, ~ ..... ,,:;; .../. DEBORAH C. LAVALLE . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 1004 CIVIL 1994 PROTECTION FROM ABUSE V. DOUGLAS W. MILLER I I I I I ORDER OF COURT AND NOW, this day of , 1994, upon consideration of the within motion and on motion of Timothy L. Clawges, Esquire, the Court authorizes Defendant's participation in the work release program. By the Court, J. f" DEBORAH C. LAVALLE : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . V. . . : 1004 CIVIL 1994 : DOUGLAS W. MILLER . . PROTECTION FROM ABUSE REOUEST FOR WORK RELEASE AND NOW, this 10th day of October, 1994, comes the Defendant, Douglas W. Miller, by and through his attorney, Timothy L. Clawges, Esquire, Assistant Public Defender, and requests that this Honorable Court authorize work release and, in support thereof, avers as follows: 1. On September 22, 1994, Defendant was found to have violated the terms of a protection from abuse order entered at the above term and docket. 2. On September 22, 1994, Defendant was sentenced to 2 and 1/2 months in Cumberland County Prison. 3. Defendant is employed through Manpower Temporary Services. 4. Cindy Peterson, Manager of the Carlisle office of Manpower Temporary Services, has confirmed that Defendant has been employed through Manpower, is eligible for employment with Manpower and Manpower is prepared to place Defendant with a work assignment at the General Mills Plant on Ritner Highway, Carlisle, ,.- - -, l:tIJil~",l:, . Pennsylvania. Ms. Peterson also indicated that Manpower desires to utilize Defendant's services. 5. Defendant owes numerous fines and court costs of significant amounts to the Cumberland County Clerk of Courts and District Justice Paula P. Correal. 6. Authorizing Defendant's participation in work release would enable Defendant to maintain his employment relationship with Manpower. WHEREFORE, Defendant requests this Court enter an order authorizing his participation in the work release program. Respectfully submitted, rc: Tlmo Assis n Attorney " . . OCT 11 1994d" . 1004 CIVIL 1994 DEBORAH C. LAVALLE V. IXXlGLAS W. MILLER ~T FOR I<<)RK RELEASE Timothy L. Clawges, Esquire OFFICE OF THE PUBLIC DEFENDER OF CUMBERLAND COUNTY COURT HOUlE CARLISLE. P.lNNSYLYANIA 17013 DOUGLAS W. MILLER 94-1004 CIVIL TERM v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW DEBORAH C. LAVALLE ORDER OF COURT AND NOW, this ~~ day of November, 1994, upon consideration of the Defendant's Petition to Make Rule Absolute, a hearing is SCHEDULED for Monday, November 14, 1994, at 8:45 a.m., in Courtroom No.5, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, . J. J. District Attorney's Office Timothy L. Clawges, Esq. Assistant Public Defender Herbert Motter Deputy Warden-Treatment Cumberland County Prison ..... :rc a:; . >-... ~~: :s:: ,-:'..t -=c UI...-,- '-. U;c '-"~ ~o<..l..t l..~:n:'-J ~ ~~~ ::~E .,1 _''':4' ~! _'.I lil"5 ,.. cl:~~;\.. I . :...~ ...--.'. <., m '" co ,. a = I" -.. " .; ~ . . DEBORAH C. LAVALLE IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . I V. . . : 1004 CIVIL 1994 DOUGLAS W. MILLER I I PROTECTION FROM ABUSE ORDER AND NOW, this day of , 1994, upon consideration of the within petition and on motion of Timothy L. Clawges, Esquire, it is hereby ordered and directed that the rule to show cause in the above-captioned case is made absolute and work release is hereby authorized for the Defendant. BY THE COURT, . J ......i.-, < " , DEBORAH C. LAVALLE : : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. . . : 1004 CIVIL 1994 : PROTECTION FROM ABUSE DOUGLAS W. MILLER . . PETITION TO MAKE RULE ABSOLUTE TO THE HONORABLE JUDGES OF THE SAID COURT: AND NOW comes the Defendant, Douglas W. Miller, by and through his attorney, Timothy L. Clawges, Esquire, Assistant Public Defender, and respectfully represents as follows: 1. On September 22, 1994, Defendant was found in violation of a protection from abuse order entered at the above term and docket and was sentenced to two and one-half months imprisonment in the Cumberland County Prison. 2. On or about October 11, 1994, Defendant filed a petition for this Court to authorize work release. 3. On October 14, 1994, upon consideration of Defendant's request for work release, a rule was issued on the District Attorney to show cause why the relief requested should not be granted. The rule was returnable in fifteen days. 4. More than fifteen days have passed since the entry of the rule returnable on the District Attorney. 5. The District Attorneys Office has failed to show cause why the petition for work release should not be granted. , ". . WHEREFORE, Defendant respectfully requests this Court to make the rule absolute and to authorize work release for Defendant. Respectfully submitted, Timot: Assista Attorney quire Public De nder for Defen ant ~ 1004 CIVIL 1994 DEBORAH C. LAVALLE V. DOOGLAS W. MILLER PETITIOO '10 MAKE RULE ABSOLtrI'E T.iJrothy L. Clawges. Esquire OFFICE OF THE PUBLIC DEFENDER OF CUMBERLAND COUNTY COURT HOUSI CARLISLE. PENNSYLVANIA "013 DEBORAH C. LAVALLE, Plaintiff I IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : v. I CIVIL ACTION - LAW I DOUGLAS W. MILLER, Defendant . . I 94-1004 CIVIL TERM IN RE I DEFENDANT'S REQUEST DENIED ORDER OF COURT AND NOW, this 14th day of November, 1994, upon consideration of the Defendant's request for work release, and following a hearing on the petition to Make Rule Absolute, the request is DENIED. By the Court, J Office of the District Attorney Timothy L. Clawges, Esquire Assistant Public Defender Herbert Motter Deputy Warden-Treatment Cumberland County Prison CCP lslr ;'i ,} '''! I atl . ,~,;..~,~'l1t~;fM~~:~'" Noy 15 9 os ~H '9~ , j;'FICE Qf 'i ':illO~~i.\hY "U>\C''''".~~D C"'JiiTY :1;:!'tt4t:;'fI.V",,~ ~, COM110NWEALTH v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Ico'l 94-510~ CIVIL TERM CHARGE: INDIRECT CRIMINAL CONTEMPT DOUGLAS W. MILLER IN RE: PETITION FOR INDIRECT CRIMINAL CONTEMPT DEFERRED ORDER OF COURT AND NOW, this 29th day of December, 1997, the Defendant, Douglas W. Miller, now appearing in court with the Public Defender, Ellen K. Barry, Esquire, as the result of execution of a bench warrant issued by the Honorable Kevin A. Hess on December 5, 1997, pursuant to the Defendant's failure to /J/~1. 'T. in court at that time on a Petition for Indirect Criminal ~ 'e'I (I', 010 , (JP, >>_ ..'( ,. \------'!! .... f) rl u ) PI) ,SI\,C . ? r,ll fro; ;Jy/S (j ~I')' J~()ll CJ/) ""\{. {CC~ . c(c/' 'L<-e- Le. J , and the Commonwealth, in the person of William I. -q, and Defendant and his counsel having reached an 9 case whereby the Defendant will pay the sum of Friday, January 2, 1998, and adjudication petition will be deferred, it is ordered l on the petition is deferred conditioned omise to pay the sum of $80.00 on or .iness on January 2, 1998, the Defendant tsed, and the probation office is directed hin sixty days of today's date or within " the petition be dismissed. By the Court, William I. Gabig, Esquire Sr. Assistant District Attorney Ellen K. Barry, Esquire First Assistant Public Defender :slr PO, ')t..C'.l"'" ':,l(6'.' ~,\".., l..>:,~ .It_... ,( /.ldM........I Sheriff probation CCP \, " -,- '~ .. -~ ~ # ;"'>'OI/, ""I I -..... " (l,' (IUf ,::>-':-.., ____. <-; _ (" \. I--- , 10 Dr? p ) D S,/v J Pro /) ,--rl C / "c<...I')' (Jr' ,(/ 0'1 ISon ' '- /\4 oJ Lc<-t.-.. ' '\.L I - c( I' '--'<-. C , u ~ , ~~LC. 0 I ,', ~.. ..-,\ . , COMMONWEALTH v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA I~t; '( 94-51~ CIVIL TERM DOUGLAS W. MILLER CHARGE: INDIRECT CRIMINAL CONTEMPT IN RE: PETITION FOR INDIRECT CRIMINAL CONTEMPT DEFERRED ORDER OF COURT AND NOW, this 29th day of December, 1997, the Defendant, Douglas W. Miller, now appearing in court with the Public Defender, Ellen K. Barry, Esquire, as the result of execution of a bench warrant issued by the Honorable Kevin A. Hess on December 5, 1997, pursuant to the Defendant's failure to appear in court at that time on a Petition for Indirect Criminal Contempt, and the Commonwealth, in the person of William I. Gabig, Esquire, and Defendant and his counsel having reached an agreement in this case whereby the Defendant will pay the sum of $80.00 on or before Friday, January 2, 1998, and adjudication and disposition of the petition will be deferred, it is ordered and directed that action on the petition is deferred conditioned upon the Defendant's promise to pay the sum of $80.00 on or before the close of business on January 2, 1998, the Defendant is directed to be released, and the probation office is directed to relist this case within sixty days of today's date or within such time recommend that the petition be dismissed. By the Court, L. J William I. Gabig, Esquire Sr. Assistant District Attorney Ellen K. Barry, Esquire First Assistant Public Defender :slr Sheriff Probation CCP PD. I) I . c....v If..<-l '.\.>~~' ". ,j) ~'16 " v ~(,. H''', 0~_u.- _fl.'....( ("id'-<~A'" FILED-OFfICE O~ ""_J~ "~r,,,";"I,,"T,"'Y . lr..".... 1 ,'....n\JI.'V" 91 GEe 30 M-I \I: '9 CU' :~i:!" .: .' r/~.U"T'( 1"'~'''''..J....) v.... I'll Pt:~ !:~!;Y~/N~L\ f" COMMONWEALTH IN THE COURT OF COMMON PLEAS OF v CUMBERLAND COUNTY, PENNSYLVANIA 51004 CIVIL TERM 1994 DOUGLAS W. MILLER IN RE: BENCH WARRANT ORDER OF COURT AND NOW, this 5th day of December, 1997, a bench warrant is issued for the arrest of the defendant. By the Court, . Ad.. A. Hess, J. John Abom, Esquire Assistant District Attorney Probation Sheriff :bg /. ...... :if."r. i- -', .:" I, '. ~. - '. -- ;.....:J.. ., I ~ 0 r; 0 (") ., :s ''5-'. - o~ ~G EE r:.>?; "1- ~.~ C.)::''; O"l ;'<:: ~- ~5~ u.. - II' Q; Ffj fa i!: :i! ~.g" & -- 8? :J (j -- ~411"/~'9".1()33 COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NON PAYMENT CASE NO.: CHARGE. . : 1994-Sl004 INDIRECT CRIMINAL CONTEMPT AFFIANT. : OTN..... : TO: , Sheriff, or any duly authorized law enforcement officer, RE: DOUGLAS W MILLER 444 FAIRGROUND AVE CARLISLE PA 17013 DOB: SEX: HT: EYES: 8/0111961 MALE S' 8" BROWN SSN: 204-48-6370 RACE: W WT: 170 HAIR: BROWN FBII: N/A SID': WHEREAS, DOUGLAS W MILLER failed to: APPEAR AS REQUIRED FOR NON PAYMENT OF FINES AND COST PER JUDGE HESS WHEREAS, this Court on 12/05/1997 directed a Bench Warrant be issued for the apprehension of the defendant. This is therefore to command you to arrest the defendant above and bring Mr. MILLER before me at CarliSle, Pennsylvania, without unnecessary delay to be dealt with according to law. WITNESS the undersigned Clerk of Courts, at CarliSle, this the 10th day of December A.D., 1997. ATTEST: eJ1~(!ot~;,/J C1erx of Courts - Deputy I~ft/ /17 Date ORIGINAL (SEAL) ---------------------------------------------------------------------- (X) EXTRADITION - NOT APPLICABLE ( ) EXTRADITION APPROVAL - Any state, adjoining states, this state, or within 0 miles of Carlisle, DISTRICT ATTORNEY/ASS'T, { Phcito,' /, -.,}' '. ~:J d . c., . DATE { J/.~, IIJ LS l /I :J30 990.05 AMOUNT OWED, IF APPLICABLE '. ,'I ~i { Aviii'abiei". ::,;:/;{I) and, CCnlONII'EAL111 OF PENNA IN mE CXlllRI' OF aM10'l PLEAS vs Clr-mERIJ\"lD CCXNl'Y PF.."lNA 1994-51004 OOUGLAS 11'. ~nLLER I JACXlB H. BAKER JR,DEPurY SHERIFF BEING DULY SII'ORN BY LA\\' SAYS TI-lAT 0'1 12/24/97 '\lffi ABOVE :-WlF.D DF.FIDlDA."IT WAC! ARRESTED BY 111E CARLISLE POLICE DI!PARTIlINf 1\'10 TRA"lSPOlU'F.D BY OUR DEPlITIES TO TIiB mmERLAND cnJN1Y PRIsm PE.'IDING FUImlER ACfIO:-l BY TI-lE CXlOO. SHERIFF'S COSTS 10 MILES @ .31~ = $ 3.10 SO A"lSII'ERS: R TI-lCl!AS KLl"lE , SI-IERIFF ~ t":. -{'" ," . '- .. t :,.,\ .'" ,. .t~"~.,\\,,,t'" , ',';" . .......... .. .. ';" ' . .~ >- 0 ~ ~~ c .. """ - ::>~ c: 0- :i:: u~ -, "- <. r:. Q~ c .~fE 0'\ -"0- ~.~ eel;:- cr Efiifi i= ..-.: cia. ::0:: :~ ~ CQ B '" v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94-51004 CIVIL TERM COMMONWEALTH DOUGLAS W, MILLER CHARGE: INDIRECT CRIMINAL CONTEMPT IN RE: PETITION FOR CONTEMPT OF COURT ORDER OF COURT AND NOW, this 13th day of February, 1998, the defendant having paid $80.00 towards the balance due her court costs, and having agreed to make regular $20.00 monthly payments until the balance due is paid in full, action on the Petition for contempt of Court is deferred, By the Court, Office of the District Attorney Probation --I~. A;l 7 A. Hess, J. ; :~~ (-... .~ :dp . , -" ;,.,: , "'c-7 r.;:,': ">- r-- ~ l.r; ..:J ? - :--1.,,. >- cb l..1C~ t-J,:-.";. 0", ~. i~:: r-C ' ',- ~I "'~.. i;-:J o~ ;;.- , ' (() Q: "", " u.:. . ; -:;'.: li~! =-:-: .,tH,U '., .lu- F :;;: l:5 c':> ::> 0' u COMMONWEALTH IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. 1994-51004 DOUGLAS W MILLER TERM & NO. CHARGE: INDIRECT CRIMINAL CONTEMPT OTN: AFFIANT: / IN RE: RULE TO SHOW CAUSE ORDER OF COURT AND NOW, september 13, 1995, in consideration of the attached petition, the court issues a Rule to Show Cause on the defendant why he should not be adjudged in contempt of court for failing to pay the sums set forth in the petition. The Rule is returnable and the hearing shall be held on October 13, 1995 at 9:30 AM in Courtroom No.4, of the Cumberland County Courthouse, Carlisle, Pennsylvania. Service of the petition to be made on the defendant by Certified Mail, Return Receipt Requested and by regular mail. By the Court, K-::j:r..1. {- // ...., m .." '-'" -., District Attorney's Office Public Defender's Office I-' .... Probation Office U') 1:.)'" I COMMONWEALTH IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. TERM & NO. PROB. NO. CHARGE: AFFIANT: 1994-51004 20739 INDIRECT CRIMINAL CONTEMPT DOUGLAS W MILLER OTN: (Additional Cases - See Attached) IN RE: PETITION FOR RULE TO SHOW CAUSE WHY THE DEFENDANT SHOULD NOT BE HELD IN CONTEMPT OF COURT AND NOW, september 13, 1995, the Probation Office of Cumberland County, respectfully petitions Your Honorable Court to issue a Rule why the defendant should not be held in contempt of court. The defendant has failed to comply with the Court Order dated 6/07/1994. The defendant has failed to: 1. Report to the Probation Office in person at the time and date set by the Collections Officer. 2. Make regular payments on the fines, cost.s, and restitution as agreed. 3. Other: The defendant has agreed to pay $20.00 per month. Date last paid was 5/08/1995. The balance is $l,5l0.0S. Therefore your petitioner prays this Honorable Court issue a Rule why the defendant should not be held in contempt of court. Respectfully submitted, .--~'1 ?:: " "" '. . :./'. 1"- ~III"I Petitioner ) , 7" 4 / '" ..- . I .. f ~~~., <.', .,,-:,;;~,~~'~~.~.~.~'((:;, COMMONWEALTH v, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94-51004 CIVIL TERM DOUGLAS W. MILLER INDIRECT CRIMINAL CONTEMPT v IN RE: PETITION FOR CONTEMPT OF COURT DISMISSED ORDER OF COURT AND NOW, this 19th day of October, 1995, the defendant having paid $100.00 towards the balance due his court costs, and having agreed to make regular $20.00 monthly payments until the balance due is paid in full, the Petition for Contempt of Court is dismissed, By the Court, Office of the District Ad- Hess, J. Probation :dp n -= ..., .... !,;.,tj ~ 1.1 --, ,::: .... ~ (...t:l Lr' >- -;t" i:: r:; C'\.' ,'" --. '. c5 ~~ IIJ' :; '-~ ~..-;: C), - -.---.. i.,i:L '- ..". ...:..:: ."":; 9:'=' '" '~::~..i Ct. ."rr) L:.J'; - )2; -!.. -, I iith G.::.' :5 r' :-7:.:..- ., -J l.!. "" a 0 c.., ,0 . . ~ COMMONWEALTH IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. TERM & NO. 1994-51004 DOUGLAS W MILLER CHARGE: INDIRECT CRIMINAL CONTEMPT OTN: AFFIANT: / IN RE: RULE TO SHOW CAUSE ORDER OF COURT AND NOW, May 14, 1996, in consideration of the attached petition, the court issues a Rule to Show Cause on the defendant why he should not be adjudged in contempt of court for failing to pay the sums set forth in the petition. The Rule is returnable and the hearing shall be held on June 14, 1996 at 9:30 AM in Courtroom No.4, of the Cumberland County Courthouse, Carlisle, Pennsylvania. Service of the petition to be made on the defendant by Certified Mail, Return Receipt Requested and by regular mail. By the Court, .':'C') ~f- -. :','- ..-0 :,; ,.., - ~- - --: 0,) '" N District Attorney's Office Public Defender's Office Probation Office ,/IlL ~ (.1:. -.,-., ....,., _.~. -..- . ' , .... COMMONWEALTH IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v, DOUGLAS W MILLER TERM & NO. PROB. NO. CHARGE: 1994-51004 20739 INDIRECT CRIMINAL CONTEMPT OTN: AFFIANT: (Additional Cases - See Attached) IN RE: PETITION FOR RULE TO SHOW CAUSE WHY THE DEFENDANT SHOULD NOT BE HELD IN CONTEMPT OF COURT AND NOW, May 14, 1996, the Probation Office of Cumberland County, respectfully petitions Your Honorable Court to issue a Rule why the defendant should not be held in contempt of court. The defendant has failed to comply with the Court Order dated 6/07/1994. The defendant has failed to: 1. Report to the Probation Office in person at the time and date set by the Collections Officer. 2. Make regular payments on the fines, costs, and restitution as agreed. 3, Other: The defendant has agreed to pay $20.00 per month. Date last paid was 2/09/1996. The balance is $1,380.05. I verify that the facts set forth in this petition are true and correct to the best of my knowledge or information and belief. This verification is made subject to the penalties of section 4904 of the Crimes Code (18 Pa. C.S. @4904) relating to unsworn falsification to authorities. Respectfully submitted, ~~ PJ_6=='~ Petitioner ~ '. -,- i*~.: .~. ~;:,...~;t;r;"'~" ~ ','" .;... '~~.; :",;<<;I}. V. IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA 94-51004 CIVIL TERM COMMONWEALTH DOUGLAS W. MILLER CHARGE: INDIRECT CRIMINAL CONTEMPT IN RE: PETITION FOR CONTEMPT OF COURT ./ ORDER OF COURT AND NOW, this 7th day of May, 1997, the defendant having paid $140.00 towards the balance due his court costs, and having agreed to make regular $20.00 monthly payments until the balance due is paid in full, action on the Petition for Contempt of Court is deferred. By the Court, Office of the District Attorney Probation A;).. Hess, J, :dp !f C'> Co ~~~~ ~,;~;ur" ::; ;1":, :::. ~..' "l~ '.;, _ ,..... . '.-:." <, ,;:~.:-..:~:; _,c:;";Jrn ~~~ ... .... ~ r:; ~ ~ .. ~ >- ..:r 'o. ....,: N [:; ~~ 8 '-j . t' . ~---:' os. Gf."; .- -:J? tl_ ;, :;:t ....":': U.._ l;':J ~,. .~ ,.. .... N .,;." -' 1% W'.' -. il-Z dt, ,.1UJ u..', ......, lOa... i":'. ~ '2: OJ. m a u 0' I' ~";'-' V. DOUGLAS W, MILLER IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94-51004 CIVIL TERM CHARGE: INDIRECT CRIMINAL CONTEMPT J COMYoONWEALTH ORDER OF COURT AND NOW, this 17th day of July, 1997, upon relation of the Probation Department that the defendant has failed to abide by the terms and condition of our earlier deferral, it is ordered and directed that he appear for further hearing on Friday, August 15, 1997, at 9:30 a.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA, In the event that the defendant shall fail to appear, a bench warrant to issue for the defendant's arrest. By the Court, ~L. /;J;L ;:vit. A, Hess, J, Office of the District Attorney / Office of Public Defender Probation " ~ ....., <-0 :dp (\,:~ '" ;~ t.O -.. >- ..::I' is a; ~. ;3: .<. 8 :':J...... t'JQ ':,)1:; (5." :t: ()",.:> i:i:r' IJ_f" .~ C)~ CJ ~- @;, N :. :"'i'/l . .rl.- J,?; --'ll :::!: :ij(b G:j-.: ~ '''In.. ., =;; ~ t,_ m 0 (1'1 .. . k,t",oi" COMMONWEALTH IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94-51004 CIVIL TERM CHARGE: INDIRECT CRIMINAL CONTEMPT V, DOUGLAS W. MILLER IN RE: PETITION FOR CONTEMPT OF COURT ) ORDER OF COURT AND NOW, this 21th day of August, 1997, the defendant having paid $60.00 towards the balance due his court costs, and having agreed to make regular $20.00 monthly payments until the balance due is paid in full, action on the Petition for contempt of Court is deferred. By the Court, Office of the District Attorney Probation . .4,q[ Hess, J. :dp """ c: ... r---' ,-..0 ,-. , , - !::5 L ir. .:r ~ N "? <' ':3 '"" C 0 C,-<>: W--. J~;;. ~:~t. ~ r.) :;: tt:j,: ;.::: r):=;.J '::--.'- ~C- "'-, ,,'In S''! 1-- "~ , '- ~;j~ EEL' Z .\, ~ I!} ,.. ,. ..': u. CC ::J 0 0-0 U , , . 'I..... i{:~!".... . """~ V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94-51004 CIVIL TERM CHARGE: INDIRECT CRIMINAL CONTEMPT COMMONWEALTH DOUGLAS W. MILLER ./ ORDER OF COURT AND NOW, this 30th day of October, 1997, upon relation of the Probation Department that the defendant has failed to abide by the terms and condition of our earlier deferral, it is ordered and directed that he appear for further hearing on Friday, December 5, 1997, at 9:30 a.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. In the event that the defendant shall fail to appear, a bench warrant to issue for the . , , defendant's arrest. By the Court, Office of the District Attorney Office of Public Defender I 4Y, A/+ Kevin A. Hess, J. / .,<.; "..' Probation :dp '. t.:, -.: 5 By the Court, V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 9'1./ - too"! : ~4 J1ual CIVIL TERM CHARGE: INDIRECT CRIMINAL CONTEMPT COMMONWEALTH DOUGLAS W. MILLER ORDER OF COURT AND NOW, this 17th day of July 1998, upon relation of the Probation De?artment that the defendant has failed to abide by the terms and condition of our earlier deferral, it is ordered and directed that he/she appear for further hearing on Friday, August 14, 1998, at 9:30 a.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. In the event that the defendant shall fail to appear, a bench warrant to issue for the defendant's arrest. Probation Kev&~es:! If the District Attorney ;I Public Defender . ~ p.~~ ,~ &f""" Office of Office of :dp . . i l-.~.......".._ i';'''f~T.'' .~' ~)i;li:>' ~ : , .. ::;' (). " .. c..,>. -., C'.' , -/ . :j ;'<L .. ..., j. ,. eJ C.. L ......' ,. ,,-,",,",,~+"" DEBRA C. LAVALLE, Plaintiff IN THE COURT OF COMMON PLEAS OF V CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 94-1004 CIVIL TERM INDIRECT CRIMINAL CONTEMPT DOUGLAS W. MILLER, Defendant IN RE: BENCH WARRANT ORDER OF COURT AND NOW, this 14th day of August, 1998, a bench warrant is issued for the arrest of the defendant. By the Court, 'e\"'''' Jaime Keating, Esquire (I (:\',1' ,tssistant District Attorney 'f .J 'j\'" ; ,.,." probation , I" I , - " Sheriff (" , :bg F1Lr:D-'j;~F:8i: r\~ .,--' ,--, '-"",r.y \:;" l;+ - . ; I '.'~ CJ3 M!'~ t '} fl-\ 12: S5 cu: i~~" ,~, . . '., '. ,_,;,1'1' Fr)L>.:.)l'~.'.','.'.'; .. ;; r:""'~'-"' , '. . Debra C. Iavalle Plaintiff IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA . . VS. lkluglas W. Miller CIVIL ACTION - LAW : CASE NO, 94-1004 Civil Term Defendant CIVIL BENCH WARRANT TO THE SHERIFF OF CUMBERLAND COUNTY: You are hereby commanded by the Court of Common Pleas of Cumberland County, Civil Division, to take /'hug1".. W. Mill..r who stands charged in said Court for FAILURE TO APPEAR IN COURT, and forthwith bring the said person before the Court, or one of the JUdges thereof, to be dealt with according to the Law. Witness this 17th day of Auaust , A. D., 1998 Curtis R. lDna Prothonotary ADDRESS: By: "'~..~, Q, ~;'f" ) iT Deputy --444 Fairaround Ave. CArlisle. PA l70l3 DOB: RIl/li1 S. SEC. H 204-48-6370 SEX: M RACE: Whit.. HT: 5'8" WT: 170 EYES: Brown HAIR: Brown -- llibra c. Lavalle In the Court CDnmm Pleas Vs. nmberland Q:lUnty Pa. Civil Action' - Law Case No. 94-l004 Civil Term / fuuglas "'. ~liller I Tim Reitz. lliputy Sheriff being duly sworn by law says that on 8-22-98 the above naned defendant was arrested by the Carlisle Police' llipartment on our Bench Warrant and placed in the nmberland CDunty Prison. Sheriff's CDsts. $0.00 So answers R. Thomas Kline~ By ~J. . TiJoothy Reitz. ~puty Sheriff '.. '" ~ h: ~ ~;. .. -, , , I - .~.~:; () " : - , )~. Ci.: ~ " ~7". " -..:.: ,- .;. ("ll. ,.- "T'i >. a - '" l';"~ " "" 1",1' <- ~ C' ~ jij 0<: ~:,; !:l.. u .... ~) c.. ... :.:> ~ ~.::::;- tJ~ II: I)f'98~7~b . Debra C. Lavalle Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA VS. Douglas W. Miller CIVIL ACTION - LAW CASE NO. 94-l004 Civil Term- Defendant CIVIL BENCH WARRANT TO THE SHERIFF OF CUMBERLAND COUNTY: You are hereby commanded by the Court of Common Pleas of Cumberland County, Civil Division, to take !huq1"" W. Mill..r who stands charged in said Court for FAILURE TO APPEAR IN COURT, and forthwith bring the said person before the Court, or one of the Judges thereof, to be dealt ~ith according to the Law. Witness this 17th day of AUQUst , A.D.. 1998 -- Curtis R. lema Prothonotary By: _1.1>:~~L'\.. G. ?:'fLL..o J Deputy ~.DDRESS : --3M Fairqround Ave. _ CArl;sle. PA 17013 DOB: -B,{1/61 S.SEC. H 204-48-6370 SEX: M EYES: Brown RACE: Whit.. HT: 5'8" WT: 170 HAIR: Brown TRIIr: ('''IflY FROM RECORD In T 1; 1"1" ',' ,', II: n unto leI my hand OI.J ,i1~ ".J: c, s;r'r! ('lurl at Cdrli~I~, Pa. This H../,,7..-!!:.., day or"fi~"&''''', 19...1..~ ,............uALlit....[~~.:.:.,.:,t....p.~............__ -^-,i1}. Prothonotary V. DOUGLAS W. MILLER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 94-1004 CIVIL TERM INDIRECT CRIMINAL CONTEMPT DEBRA C. LAVALLE, Plaintiff IN RE: BENCH WARRANT ORDER OF COURT AND NOW, this 28th day of August 1998, upon representation of the Probation Office Collection Unit that the above mentioned defendant has paid $30.00 towards the balance due, the Bench Warrant issued on August 14, 1998, is vacated, and the Cumberland County Prison is directed to release him from custody. If the defendant fails to pay the amount of $20,00 in any given month, a Bench Warrant will be reissued, By the Court, CCP Probation Office C. 1"";'\' I ~f'1 <5 .0'( lR.o.b~'{./C:A.J. /IlL :dp :- ':0 n- ,.:-. '-. .;,.... r:"'; IU~ ~~ ~~: 1.:. , 'j) ~ .:.J I." , 11: I ;-:-: " ~ :, I, C/, ';!- ., -' () u~ '-' ) COMMONWEALTH IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94-'1004 CIVIL TERM CHARGE: INDIRECT CRIMINAL CONTEMPT v, DOUGLAS W, MILLER ORDER OF COURT AND NOW, this 15th day of January 1998, upon relation of the Probation Department that the defendant has failed to abide by the terms and condition of our earlier deferral, it is ordered and directed that he appear for further hearing on Friday, February 13, 1998, at 9:30 a.m. in Courtroom Number 4, Cumberland County Courthouse, Carlisle, PA. In the event that the defendant shall fail to appear, a bench warrant to issue for the defendant's arrest. By the Court, K~~;.1.d- Office of the District Attorney /' Office of Public Defender Probation ,. :dp ~... ~J ,.........fuf ~ 1PN(,;'i;u;,.v . ~ <..0 = " ~""-,~-""~~- '- [I; j' , I.!.oJ ( .' _.,'.f ~~- ,;; ..... C'.' .,-: I.,' "., w., c:: p L. V, " c: " .: J