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HomeMy WebLinkAbout94-01227 ~ c - 'J; ~ 3 <0 - ~ MAR 1 1 1994 ,\y v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. /d)--'7 CIVIL 1994 PROTECTION FROM ABUSE SUSAN VON STEIN, Plaintiff ROBERT WASHINGER, Defendant TEMPORARY PROTECTIVE ORDER AND NOW, this II day of March, 1994, upon presentation and consideration of the within Petition, and upon finding that the plaintiff, Susan Von Stein, now residing at 883 Mt. Rock Road, Carlisle, Cumberland County, Pennsylvania, is in immediate and present danger of abuse from the defendant, Robert Washinger, the following Temporary Order is entered. The defendant, Robert Washinger, now residing at 883 Mt. Rock Road, Carlisle, Cumberland County, Pennsylvania, is hereby enjoined from physically abusing the plaintiff, Susan Von Stein, or placing her in fear of abuse and is excluded from the residence located at 883 Mt. Rock Road, Carlisle, Cumberland County, Pennsylvania, a residence which is owned solely by the plaintiff. The defendant is hereby notified that if he resides in the plaintiff I 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 plaintiff and defendant shall not nullify the provisions of the court order directing the defendant to refrain from abusing the plaintiff. The defendant is ordered to refrain from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications. The defendant is enjoined from harassing and stalking the plaintiff and from harassing the plaintiff's family. The defendant is enjoined from entering the plaintiff's place of employment. This Order shall remain in effect until a final order is entered in this case. A hearing shall be held on this matter on the J.1,..rday of n.4.,uJ~ , 1994, at /: 3J p.m., in Courtroom NO.-1-, Cumberland County Courthouse, Carlisle, Pennsylvania. The Cumberland County Sheriff's Department shall attempt to make service at the plaintiff's request, but service may be accomplished under any applicable rule of Civil Procedure. The appropriate police departments will be provided with a copy of this Order by the plaintiff's attorney. This Order shall be enforced by any law enforcement agency where a violation occurs by arrest for indirect criminal contempt 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. S 6113). By the Court, lfLuk.. " Judge -::r c:r> ;~:oo-- ':" ..- - = " 0- (.,. :r ..... 7 - to: -~ = ., ,1 ;';"1 ,........", ...' SUSAN VON STEIN, IN THE COURT OF COMMON PLEAS OF Plaintiff . . CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW . . ROBERT WASHINGER, NO. CIVIL 1994 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 TAItE 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 FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR, 4th FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717)240-6200 . SUSAN VON STEIN, Plaintiff IN THE COURT OF COMMON PLEAS OF . . : CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW . . ROBERT WASHINGER, Defendant NO. CIVIL 1994 PROTECTION FROM ABUSE PETITION FOR PROTECTIVE ORDER RELIEF UNDER THE PROTECTION FROM ABUSE ACT, 23 P.S. 5 6101 et seq. A. ABUSE 1. The plaintiff is an adult individual whose permanent address is 883 Mountain Rock Road, Carlisle, Cumberland County, Pennsylvania, 17013. 2. The defendant is an adult individual residing at 883 Mountain Rock Road, Carlisle, Cumberland County, Pennsylvania, 17013. 3. The defendant has had an intimate relationship with the plaintiff. 4. Since approximately tJdcJlu-J , /7&7 , 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 bodily injury. This has included but is not limited to the following specific instances of abuse: a. On or about March 8, 1994, the defendant followed plaintiff to work, approached her car, and when she would not open the door for him, used his key to open the passenger side door. As he got in, plaintiff ran out her door and into her work place. All the while defendant was yelling at plaintiff, "the boys don't want anything to do with you, you're a hell of a mother, when are you gonna come and get the rest of your clothes?" b. On or about March 7, 1994, the defendant approached plaintiff in a store, grabbed her by the shoulders and shook her until she fell. Telling plaintiff that, "The fucking house is mine, come get your clothes." This was witnessed by Asper Russell of 58 Russell Road, Carlisle, Cumberland County, Pennsylvania, a friend of plaintiffs. c. On or about March 5 and 7, 1994, the defendant called plaintiff's co-workers to find out where she was. d. On or about November, 1993, the defendant threatened plaintiff that he would "burn down the house and blow up the cars" if he did not get them. e. On or about November, 1992, the defendant threw plaintiff on her bed and grabbed her around the neck. Plaintiff's two sons ran to help her and defendant threw the one son against the wall. Plaintiff ran out past defendant, and the three left the house. f. On or about May, 1991, the plaintiff had her brother and his family over. Their three children were playing in the flower bed and got dirt on the plaintiff's porch. The defendant called the family "fucking hogs", initiated a fist fight with plaintiff's brother, then kicked them all out of the house. g. The defendant has continued to yell and swear at the plaintiff and her two children daily, for the past 9 years. He has thrown out Plaintiff'sh~~~~s, as well as her children's friends, when they came to the house. I." ~~.;;;,;. 5. The plaintiff believes and therefore avers that she is in present danger of abuse from the defendant and that she is in need of protection from such abuse. 6. The plaintiff desires that the defendant be prohibited from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications. 7. The plaintiff desires that the defendant be enjoined from harassing and stalking the plaintiff, and from harassing the plaintiff's relatives. 8. The plaintiff desires that the defendant be restrained from entering her place of employment. B. BXCLUSIVB POSSBSSION 9. The house and property from which the plaintiff is asking the court to exclude the defendant is owned solely in the name of Susan I. Von stein. The defendant has resided at that same address for several years with the plaintiff but holds no possessory interest. C. LOSSBS 10. The plaintiff asks for attorney's fees for Duncan & otto, P.c., court costs and filing fees pursuant to the Protection from Abuse Act. '- WHEREFORE, pursuant to the provisions of the "protection from Abuse Act" of October 7, 1976, 23 P.S. S 6101 n ug., as amended, the plaintiff prays this Honorable Court to grant the following relief: A. Grant a Temporary Order pursuant to the "Protection from Abuse Act:" 1. Ordering the defendant to refrain from abusing the plaintiff or placing her in fear of abuse~ 2. ordering the defendant to refrain from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications~ 3. ordering the defendant to refrain from harassing the plaintiff's family~ 4. Prohibiting the defendant from entering the plaintiff's place of employment~ 5. Ordering the defendant to stay away from the residence located at 883 Mountain Rock Road, Carlisle, Cumberland County, Pennsylvania, and 6. Ordering the defendant to stay away from any residence the plaintiff may in the future establish for herself. 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. Ordering the defendant to refrain from abusing the plaintiff or placing her in fear of abuse. .......~.. 2. Ordering the defendant to refrain from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications. 3. Ordering the defendant to refrain from harassing and stalking the plaintiff and from harassing the plaintiff's family. 4. Prohibi ting the defendant from entering the plaintiff's place of employment. 5. Ordering the defendant to stay away from the residence located at 883 Mountain Rock Road, Carlisle, Cumberland County, Pennsylvania. 6. ordering the defendant to stay away from any residence the plaintiff may in the future establish for herself. 7. Ordering the defendant to pay attorney's fees to Duncan & otto, P.C. The plaintiff further asks that this Petition be filed and served, pending a further order at the hearing, and that certified copies of this Petition and Order be delivered to the appropriate police departments with jurisdiction to enforce this Order. The plaintiff prays for such other relief as may be just and proper. Respectfully submitted, -') ;;t~U:1 J~w~ &9uti& ~achel L. Me sch, Esqurre Attorney for Plaintiff Duncan & otto, P.C. 1 Irvine Row Carlisle, PA 17013 (717) 249-7780 1. '""\;,"':.'#-' The above-named plaintiff, Susan I. Von Stein, verifies that the statements made in the above Petition are true and correct. The plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S. S 4904 relating to unsworn falsification to authorities. Date: 3- \\ -q<-\ S'LDQm 1) (lf1Yl "'+1.,1 IvI Susan I. Von s€e1n, Pla1ntiff ~. \ -..\) -.::::J-. Q , .' ~. .':..::r" t:.I1..: ..tt'"." ~- . ,.....,. -- ,~~':.,.,' ," '~-' ",'.,i.t\~, '~)'~" ~,' ..,P'>.': .tI':. ~""~':-.." .<..;~< :~~~.s: ;;~t " ".' ".-' .,;-....,.\.... ':r.,.' ;':.:$~t;~~;,... -' :\. ' ,-' ., -;:;, ,." ., '.~,.'Ja": ~;"~;r~,:~ - ;;~~;~.' "::' " <'i<tt ~ ~~ ~ , .;..1.... , :' - ~ -'..f; :,....:":' .., ".,' ;', , ~ ~' ,', ~' ~""."..\ .. .~~\, ' ~ . .~ ~ " ~~, -,:f"\.' ~ ~ .~ ' ", '.'" :"'.\ -,\"" . ' .,', '" ..-..~"; .:~,,\:.<~'..{:.. '.. ,.- ,-.-'. " .;- ..;.' ,:' " '....,.- " ,~'. ,..: ..' f".' .~ :,... ":::. t',;"':. C'. .'.',:.::>::....~:;;; .c,). ...0 ',.,~..{i~.,~,.. '~i.!l :&!'~!' ',,:C;'lil.. ',I: ' ;~~~ll ;ll~i~ ',';~,' .~ " . CJ" , " .' -. " '." " '.'.:,. ";, .. i', ^ "1, '. " ". . '. I! 'I SUSAN VON STEIN, . IN THE COURT OF COMMON PLEAS OF " . , Plaintiff . CUMBERLAND COUNTY, PENNSYLVANIA i . ii . . ., CIVIL ACTION - LAW ! vs. . , . . . ROBERT WASHINGER, . NO. 1227 CIVIL 1994 . Defendant . . . PROTECTION FROM ABUSE . DEFENDANT'S ANSWER TO PETITION FOR PROTECTIVE ORDER 1. Admitted. 2. Admitted. 3. Admitted. 4. Denied. It is denied that since approximately October of 1989, 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 bodily injury. A. Admitted in part and denied in part. It is admitted that on or about March of 1994, the Defendant followed the Plaintiff to work, approached her car, and attempted to get into her vehicle with his key. It is admitted that as the Defendant got into the vehicle, the Plaintiff got out of her vehicle and ran into her place of employment. The Defendant stated to the Plaintiff, "you are some kind of mother." The Defendant denies that he said "you are a hell of mother." It is admitted that the Defendant stated to the Plaintiff, "when are you going to get the rest of your clothes?" ,... B. It is admitted that on or about March 7, 1994, the Defendant approached the Plaintiff in a store and grabbed her by the shoulders until she fell. It is denied that the Defendant stated, "The fucking house is mine, come get your clothes." It is denied the Defendant intended to cause the Plaintiff to fall. C. Admitted. D. Denied. It is denied that on or about November, 1993, the Defendant threatened Plaintiff that he would "burn down the house and blow up the cars" if he did not get them. E. Denied. It is denied that on or about November, 1992, the Defendant threw Plaintiff on her bed and grabbed her around the neck. F. Denied. It is denied that the Defendant initiated a fist fight with the Plaintiff's brother. G. Admitted. It is admitted that the Defendant and Plaintiff have continued to yell at each other and swear at each other for a period of time. The Defendant has never used physical force to i remove any of the Plaintiff's family or her children's friends from the house. 5. Denied. It is denied that the Plaintiff has a reasonable basis to believe that she is in need of protection from abuse from the Defendant. 6. The Defendant submits that there is no basis to preclude the Defendant from having any contact with the Plaintiff. 'I II ,I i Ii 7. The Defendant desires that he not be enjoined from :1 communicating with Plaintiff. It is denied that he has harassed or i stalked the Plaintiff or harassed the Plaintiff's relatives. 8. The Defendant has no desire to enter the Plaintiff's place of employment. 9. Exclusive Possession It is denied that the Defendant holds no possessory interest to ; the property which is titled exclusively in the name of the , , Plaintiff. By further answer, the Defendant provided the Plaintiff ,eleven-thousand dollars ($11,000.00) to purchase the property as a result of Plaintiff's "buy-out" of her equitable rights of her 'first marriage. By further answer, the Defendant has made the entire mortgage payment for said property for the last eleven (11) : years. ,10. I Losses The Plaintiff is not entitled to attorney fees, court costs ,and filing fees pursuant to the Protection from Abuse Act. WHEREFORE, the Defendant requests this Honorable Court to dismiss the Plaintiff's Petition for Protection from Abuse. NEW MATTER 'II. Plaintiff and Defendant began residing together in 1982 or 1983. 12. The Defendant has attempted to contact the Plaintiff at her place of employment on several occasions during severe weather conditions and Defendant wanted to know if the Plaintiff arrived at her place of employment in a safe manner. 13. The Defendant has never utilized physical force against the Plaintiff nor has he threatened to do so. 14. The Plaintiff and Defendant have lived together as husband and wife for the past eleven years. 15. During the period of time in which the Plaintiff and Defendant i resided together, Defendant provided eleven-thousand dollars ($11,000.00) to the Plaintiff in 1982 or 1983 to purchase her interest in the house which is currently titled in her own name. 16. The Defendant submits that he has a possessory interest in the property pursuant to the laws of equity as well as common law marriage. 17. The Defendant has provided the Plaintiff five-thousand dollars ($5,000.00) for her to complete her schooling at the Empire Beauty School. 18. The Defendant purchased the Plaintiff a 1991/1992 Plymouth Sunbird for fourteen-thousand dollars ($14,000.00) and permitted the Plaintiff to title the vehicle in her name. 19. In December of 1993, the Defendant became estranged from the Plaintiff. Plaintiff began staying out late at night and not coming home to care for her children. 20. The Defendant became concerned for Plalintiff's children as well as the Plaintiff and wanted to have a reconciliation of their relationship. ", " , 21. The Defendant has had very little personal contact with the i Plaintiff in that he works from 10:30 p.m until 7:00 a.m. The , Plaintiff currently works from 9:00 a.m until 4:00 p.m. 22. The Defendant and Plaintiff went out to socialize on February 19, 1994, Februarj 26, 1994, and March 5, 1994, at the Midway Bar in Carlisle, Pennsylvania, and both have consumed alcohol together on numerous occasions. 23. 24. i The Defendant contacted the Plaintiff on March B, 1994, as a I I I WHEREFORE, the Defendant respectfully requests your Honorable I The Defendant is not a threat to the Plaintiff. result of seeing Plaintiff with another man on March 7, 1994. i I 'I , Court to dismiss Plaintiff's Petition for Protective Order. ,I ;1 i :i :i , Respectfully Submitted: ~~ Patrick F. Lauer, Jr., Esquire 210B Market Street Camp Hill, PA 17011 (717) 763-1BOO Supreme Ct. ID' 46430 " it ': ;1 'I I Date: I i i ; :3 //? /tlf / I i I 'i 11. I j 2. ,I 3. 'I :1 '. ATTORNEY VERIFICATION The undersigned, Patrick F. Lauer, Jr., Esquire, hereby verifies and states that: He is the attorney for Robert Washinger. He is authorized to make this verification on his behalf~ The facts set forth in the foregoing Answer are known to him and not necessarily to his client~ :1 \ 4. I :1 The facts set forth in the foregoing Answer are true and " correct to the best of his knowledge, information and belief~ and :1 5. I d , i I ,I " " He is aware that false statements herein are made subject to the penalties 4904, relating unsworn to of 18 C.s. Pa. falsification to authorities. Respectfully Submitted: ;i ;1 " ii :1 :i 'i ,I 11 \: Date: ~/~k~ ',I ' , " q 'i , I ,j I i , i Ur /( FL~ ~atrick F. Lauer, Jr., Esquire 2108 Market Street Camp Hill, PA 17011 (717) 763-1800 t..... ,."..,.."....c'"'_ . '.' CERTIFICATE OF SERVICE I hereby certify that I am this day serving a copy of the foregoing Answer upon the person and in the manner indicated below, which service satisfies the requirements of the Pennsylvania Rules of Civil Procedure, by depositing a copy of the same in the United States Camp Hill, Pennsylvania, through first class mail, prepaid and addressed as follows:: Rachel L. Mensch, Esquire Duncan & Otto, P.C. 1 Irvine Row Carlisle, PA 17013 c52:-tZct Patrick F. Lauer,' Jr., Esquire 2108 Market Street Camp Hill, PA 17011 (717) 763-1800 , Date: f11Q? . ~ ... ei ~ <i t.l os u ~ ::> ;j ..J ~ ... 5 < u; ~ :c - < - ..J c: <i C1. . ... ::l ,., eo: >> ~ al '" .. :E ... = u :c - ~ .. ~ ... U Q ~ " a. - < e ... - - - ~ < 1'" ... '- (,J < Q. PATRICK ~', LA\' ER. ,," ,\lInrne~ tit 1..1\\ : II,), \lal~...1 ""Ic.'\'1 ..\/1e'1,. Ihllhhlll~ ('amp 11111. II \ I ill I I 1i'1;\ "'(,\.Pillll ., "',- SIIERH'F'S RETURN CGMJNWEAL'IH OF PENNSYLVANIA: COUNl'Y OF CLt>lBERLJIND In The Court of Common Pleas of Cumberland County, Pennsylvania No. 1227 Civil Term 1994 Temporary Protective Order Protection From Abuse Notice and Petition for Protective order Susan Von Stein VS Robert Washinger Harrv Kinq , ~k~~x~ Deputy Sheriff of Cunberland County, Pennsylvania. who being duly sworn according to law. says, Temporary Protective Order Protection from Abuse that he served the within Not ice and Petition for Protective Order upon Robert Washinqer , the defendant. at 6:40 o'clock P .M, EST 1 R~ on the March , 19-9Jat day of 14 35 W. Main St., Plainfield Pennsylvania, by handing to Robert Washinqer , Cumberland County, Temporary Protective Order Protection From a true and attested copy of theAbuse, Notice and Petition for Protective Order and at the same time directing his attention to the contents thereof and the "Notice to Plead" endorsed thereon. Sheriff's Costs: Docketing Service Affidavit Surcharge So /~e.fsp ~ 7 ~..,...,....~ 1-~ c.t! 14.00 2.80 2.00 18.80 Pd. by Atty. 3-15-94 R. Thomas Kline, Sheriff ~ 1/- ~rPI ___..'7 Dep ty Sookf Sworn and subscribed to before me this /" <l- I - day of 'Ill "-,' ,/...../ 19 Cd A.D, < /-'1 (~ C'. ) I'U-i(, ~- . A1fl~ ' Prothonotary SUSAN VON STEIN, plaintiff : IN THE COURT OF COMMON PLEAS OF . . : CUMBERLAND COUNTY, PENNSYLVANIA : v. CIVIL ACTION - LAW : ROBERT WASHINGER, Defendant : NO. 1227 CIVIL 1994 . . : PROTECTION FROM ABUSE AND NOW, this +.S PROTECTIVE ORDER day of March, 1994, upon consideration of the Consent Agreement of the parties, the following Order is entered: 1. The defendant, Robert Washinger, and the plaintiff, Susan Von stein, are enjoined from physically abusing each other or from placing each other in fear of abuse. 2. The defendant and the plaintiff are enjoined from having any direct or indirect contact with the each other including, but not limited to, telephone and written communications. 3. The defendant and the plaintiff are ordered to refrain from harassing and stalking the other and from harassing the other's family. 4. The defendant and the plaintiff are prohibited from entering the other's place of employment. 5. The defendant is excluded from the premises located at 883 Mt. Rock Road, Carlisle. Cumberland County, Pennsylvania. 6. The defendant and the plaintiff are ordered to stay away from any residence the other may in the future establish for him or herself. 7. The defendant is ordered to collect his belongings from the plaintiff's residence while accompanied by a constable, in the presence of the plaintiff, within 10 days of this order. 8. This Order shall remain in effect for a period of one year. 9. The Carlisle Borough Police Department shall be provided with a certified copy of this Order by the plaintiff's attorney and may enforce this Order by arrest for indirect criminal contempt 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. S 6113). offer, Judge o~ c-: =-: fa ...... ~ I' . .' "",' I', (/1" r:; -,' ..'Q:r '.: ~otJ.:"j ;-.';)Z~J ...: '-:~ '-.,"' ;,r-i . ~ ,.. ~?< c.o c w :l;.- = . c..a .c... SUSAN VON STEIN, plaintiff ,". : IN THE COURT OF COMMON PLEAS OF . . CUMBERLAND COUNTY. PENNSYLVANIA . . . . v. : CIVIL ACTION - LAW ROBERT WASHINGER, Defendant NO. 1227 CIVIL 1994 : PROTECTION FROM ABUSE CONSBNT AGREEMBNT This Agreement is entered on this 'd-S day of March, 1994, by the plaintiff, Susan Von stein, and the defendant, Robert Washinger. The plaintiff is represented by Rachel L. Mensch, Esquire of Duncan & otto, P.C.; the defendant is represented by patrick F. Lauer, Jr., Esquire of Law Offices of Patrick F. Lauer, Jr. The parties agree that the following may be entered as an Order of Court. 1. The defendant, Robert Washinger, and the plaintiff, Susan Von stein, agree to refrain from abusing each other. or placing each other in fear of abuse. 2. The defendant and the plaintiff agree not to have any direct or indirect contact with each other including, but not limited to, telephone and written communications. 3. The defendant and the plaintiff agree not to enter the place of employment of the other. 4. The defendant and the plaintiff agree not to harass and stalk each other or harass the other's family. 5. The defendant agrees to stay away from p",4nHff's ~vJ r'UliaaRQa ] "'....r.,.. ae 883 Mt. Rock Road. Carlisle. Cumberland county, Pennsylvania. 6. The defendant and plaintiff agree to stay away from any (. ;"-'''';~- residence the other may in the future establish for him or herself. 7. The defendant and the plaintiff although entering into this Agreement, do not admit the allegations made in the Petition. 8. The defendant and the plaintiff understand that the Protective Order entered in this matter shall be in effect for a period of one year. 9. The defendant and the plaintiff understand that this Order shall be enforceable in the same manner as the Court's prior Temporary Protective Order entered in this case. 10. The defendant and the plaintiff agree to pay their own attorneys fees. 11. The defendant and the plaintiff agree to split the cost of having a constable present when defendant comes to return plaintiff's property and to collect some of his own. WHEREFORE, the parties request that an Order of Court be entered to reflect the above terms. :'::'.Lu:\CLIY\ UOY\~I Susan Von Stein, PIa nt ff " atr ck F. Lauer, Jr.. re Attorney for Defendant Law Offices of Patrick F. Lauer, Jr. 2108 Market Street Camp Hill. PA 17011 (717) 763-4247 Duncan & otto, P.C. 1 Irvine Row Carlisle, PA 17013 (717) 249-7780 ,,~:',~-:,-;,.- v-,.:t.:..-;;.i./..j ,;'; ;:<tl{~' ":'~,,),,-*,.. ~:,'"" , :::;<ir~~~iZ~~I\:~gl:~:!P~~l;.~~:':', " ' "'. :l,;,_ -,J,I.!'''' ..r'o.~~;;,}.~,:tl.")iI;yt.li(J '-,/.' , :'.., ';',::<\~~'~i~:;;;fi~Ei~ff~~;kl?' ' ,!f'I':~'~ ",,'1 ~ '., ~. _ . .. """r' ~ ~j.~I':~,:t,:'t .,;t<~.\:;~~ \, \:" . -- ' if' ,,'. ,1, 'L'J''";I...~-'::':;\>;i\,~''I:", '.,' ;" -" . ^"T r,";~':..' '.,: ~""\)/~; t" \,,;~ ";::\,-u. I. ~ ",~{,.. ';Vt,,'" . '\4'~~<l:.'V-'V:"": . 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