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HomeMy WebLinkAbout94-04788 " f ~ Q ';# " f 1 " \ (\) Q \ "\ \ I I ! '/ / " , I , I I ~ J gg f' '::t' I I' t ii',. , , ",' DELORES DELANCY ERIN DELANCY Plaintiffs = IN THE COURT OF COMMON PLEAS OF = = CUMBERLAND COUNTY, PENNSYLVANIA = = NO. 94-4788 CIVIL TERM I I PROTECTION FROM ABUSE I vs. KYLE DELANCY, defendant MAC DELANCY, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA , vs. NO. 94-4788 CIVIL TERM DELORES DELANCY ERIN A. DELANCY, Defendants ,j . " ANSWER TO RULE TO SHOW CAUSE - ~~ The plaintiffs in the Protection From Abu.e action, Delor.. and Erin Delancy, hereinafter referred to a. the r..pond.nt., by and through their attorney, Joan Carey of Legal servic.., Ino., files the following Answer to the Rule to Show Cau.. ent.red pursuant to the Motion for Return of Weapons fil.d by Mao Delancy, hereinafter referred to as the petitioner: 1- Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted in part. D.nied in part. It i. admitt.d that negotiations regarding the w.apon. have been in proo.... It i. denied that the respondents lack any legal or authoritative basis for refusing consent to the return of the weapons for reasons set forth in New Matter. 9. Admitted. NEW MATTER 1. When the Cumberland County Sheriff's Department seized thirteen weapons from the defendant's residence pursuant to the Protection Order of August 24, 1994, the Sheriff did not seize the weapons of Kyle Delancy, hereinafter referred to as the Defendant. 2. The respondents saw weapons in the back of the petitioner's vehicle when he left the respondent's residence with the defendant after retrieving his belongings. The respondents believe that the defendant took his weapons to the petitioner's residence immediately prior to the entry of the Temporary Protection Order. Only months later, after the respondents saw the list of weapons from the Sheriff's Department, did they know that none of the defendant's weapons had been seized. Therefore, when the sheriff seized weapons pursuant to the Protection Order, the defendant's weapons were not seized. Instead, eleven of the weapons seized were the petitioner's and two of the weapons were the respondent's husband's weapons. 3. Since the entry of the Protection From Abuse Order, the respondents have seen several incidents including the following where the defendant has acted in ways which caused the respondents to fear for their safety and to question whether the petitioner has the ability to control the defendant: a. On several occasions since the entry of the Temporary Protection order, while screaming obscenities, the defendant has ridden his dirt bike at high rates of speed in front of the respondent's residence, causing stones to fly into the respo dent's yard. b. On or about March 6, 1995, the respondents saw the defendant thro a bucket at his girlfriend. When the petitioner int rvened, the Defendant pushed him, punched the girl in the st mach and pulled her to the ground by her hair. The def ndant also shoved a wheelbarrow at the petitioner. Then, although he had not driver's license, the defendant then went into the barn, got into a car, and drove recklessly down the road and through the field, wildly and heedlessly spinning in circles. The respondents feel that the petitioner has no control over the defendant. 4. On several occasions prior to the entry of the Protection From Abuse Order, when the defendant becam~ angry at the respondents, he frequently threatened them with guns. The respondents feel that they are in danger as long as the defendant has access to guns. Because the petitioner is not able to control the defendant, the respondents fear for their safety if the petitioner's weapons are kept in his residence where the defendant resides, as the defendant could gain access to the weapons. 5. Because of the escalating violent outbursts by the defendant since the entry of the Temporary Protection order, including that of March, 1995, where he became violent with the .~~':!.::':~r~H,.;\r:;;;'[""-::;::i' ;~ _... .., ..."..~honer,ttie respondents fear for their safety if any weapons are in his possession ~r if he has access to weapons. 6. In the past, the defendant has destroyed property in ways including breaking things with sledgehammers; therefore, if the petitioner's woapons are returned to him, the respondents fear for their safety unless those weapons would be kept in a secure place outside the petitoner's residence where the defendant currently lives. WHEREFORE, the respondents request that the weapons ourrently held in the possession of the Cumberland County Sheriff's Department remian in their custody. Alternatively, if the weapons are returned, the respondents ask that those weapons not be kept at the petitioner's current residence while the defendant is living there. The respondents further request that the defendant turn over to the sheriff his weapons, including six shotguns - one a double barrel Fox 243 and an 1187 black Premier. The respondents also request that a new hearing date be set in the Protection From Abuse case which has been generally continued. The respondents further ask for any other relief which is just and proper. Respectfully submitted, / / oan Carey ,/ Attorney for Rasp LEGAL SERVICES, I 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 MAC DELANCY, Plaintiff v. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA No. 94 - 4788 CIVIL TERM DELORES DELANCY, ERIN A. DELANCY, Defendants AND NOW, this I!QU.ON FOR tZ THE RETURN OF PROPERTY Mo-U1-. day of F88r~a~y 1995, petitioner, Mac Delancy by and through his attorneys Costopoulos, Foster and Fields submits the following in support of relief requested herein: 1. Petitioner, Mac Delancy, is an adult individual with a legal residence of 501 Walnut Bottom Road, Shippensburg, Cumberland County, Pennsylvania. 2. Respondents, Delores C. Delancy and Erin A. Delancy, are adult individuals with a legal residence of 580 Walnut Bottom Road, Shippensburg, Cumberland County, Pennsylvania. 3. On or about August 24, 1994, the respondents herein filed a petition for a Temporary Protective Order as against Kyle C. Delancy. A true copy of which is attached hereto and marked as exhibit 1. 4. As a result of the Petition filed by respondents herein, and made reference to in the above paragraph, a Temporary Protective Order was entered by this Court on August 24, 1994 and docketed under No. 94-4788 Civil Term. A true copy of the order i8 attached hereto and marked as Exhibit 2. 5. As port ond parcel of the Order entered, ond mode reference to herein, the Court ordered thot the nomed defendont in the componion cose, Kyle C. Delancy, relinquish to the Sheriff's Deportment weapons which he allegedly threotened to use ogoinst respondents herein. 6. Based on the Temporary Protective Order of August 24, 1994, the Sheriff's Depertment of Cumberland County confiscated 13 different weapons during the enforcement of the Protective Order referenced to herein. A true copy of the inventory sheet reflecting the confiscated property is attached hereto and morked as Exhibit 3. 7. Of the thirteen seized weapons confiscated pursuant to the Order, eleven of those are the property of pett tioner, Mac Delancy (items: 1-8, 10, 11 and 13 of Exhibit 3) and at no time were they owned or possessed by Kyle Delancy, defendant in the Protection From Abuse matter. 8. Despi te repeated attempts to obtain Respondents acquiescence to the return of the property to Petitioner, the Respondents have refused to grant their consent and continue to do so without any legal or authoritative basis. 9. Respondents know, and have acknowledged the fact, that the property in question, is the personal property of Petitioner, Mac Delancy. .,---4 c'lr",:,) &\i;ltl\i~i/I~1 .;ifl",!</'i:Jlt\~,JI "::'_; ~!>; l'~-'."i' +iJ\;"i:,~'h;, -". ,,~,\, \ -,Ii; i'.}. ,; !...~ ~\';.!I~ :l~',,\ -j: i\f; 'Y;~t_./. 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' ..-'j'- c,,':-.-, .:' -.- .F ~ \t.;i~;-!'J.:1J\\,,'i,1":~;.,',:I-; II V "'le'" , . ..,",1, " ')", J ':';':11\'.!'rrl~~/\)\d-h);~ JIMnl~\'4~t1;\;ttM,Ij'~~tild~~~&~\, '!/}I.: li,'li' i, ' 1,';,\, I; ,';" ~'M;.,,',~dt,,'-iJ,I"I- I'''-''i~e~ \'t,,/,;,-'.l~~~l;~~'~j,;'~'" ,,'1 , .( , i , I' I' ) ,\ ,n , f"I;' r \ I , ~ vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4788 CIVIL TERM PROTECTION FROM ABUSE DELORES C. DELANCY, ERIN A. DELANCY, Plaintiffs KYLE C. DELANCY, MOTION FOR CONTINUANCE The plaintiff moves this Court for an Order continuing the hearing of this case until further Order of Court, on the grounds that: 1. A Temporary Protective Order was issued by this Court on the 24th day of August, 1994, scheduling a hearing for the 1st day of September, 1994, at 4:00 p.m. 2. The defendant was served with the Temporary Protective Order and his attorney, william Costopoulos, contacted Legal Services, Inc. to negotiate a Consent Agreement. The parties are unable to execute a Consent Agreement before the time of hearing. 3. The plaintiff requests that a general continuance be entered and that the Temporary Protective Order remain in effect pending further order of court. 4. A copy of the Order for continuance will be delivered to the Pennsylvania st^tft, shippensburg University, and the Mid- Cumberland Valley Regional Police Departments by attorneys for the plaintiff. WHEREFORE, the plaintiff moves this Court to grant the -- _...d_ ~ .'..... l'!#;j,~ , \ll;~I;it(ir~,\-1\!'~;!.\1Wl . I LI..I !/\_I' ."1;',-'.. .!I,'/,., I";' Ii '~i I 'I' .,\\/ (~,~l~!:' :1\' ." ':~\"I) \: ,: I"" .,"1 ;']: (" ' j I'! j"l F " ., if t' II', I " J 'I I ' .' ;1Ji~t\:!t~i!/:(j~;I:)llf~~fl~~t~';~~H,(h",: .~'J;r,ll ',1'1';' l\~' '1,";1'/1,):-.\ ,li,:.: 1'1 ~r j l/lli''lI'CJ!",.I/I:'H.t,'l'I,t J/'lll~ 11--': il.:. ','r,"J 'l!~;ll.. 111' It" F, 'I"! ,) , ,j _I II ,""'" : '; 1'1 I..,) . Hi ,1,\ ',,: I, \. lit~LL.!' ;'i ,1 I', (I, 1!1({l:;J:.I,IIJ/11}n/.;J 1."ll~" .."",' ~,1J.l J'/,I,,':'"tC, ,l,",1 ,;\'e,: ' , I '",:= " ..r /1,',,'\1/'1, ,,", " I,' , "..._ ,__1111 1,;:~:~i~~I;li:\t;i!;::':, "',', ,,\="n,','.~,,~;;.. ',I: '\1 H;I,I.'. "-,,,"i,\~I~!\~~'i'~~i"~Nit:~:!i)'~d'f.:;!',r: '",' j ':,- 'ltilJli "17)'.,01 )' \ t~, ,,1,1;' ....' ','r.,.,j""f,,"'}'~'-)!Ff''';:'-'.:'!' . . ','" ,\ i' j'-' I' . ;':'~"'~')" '.':i-';'c,.i': '-1)',-!;:.';.'!; ,fl,-':' '. 1,1 ,'I ;' , I "i ,1:1, II' , I ," " " ", l ., t.e. " , ., \, ~ VI. I II TII COURT 0' COKKOH PLIA8 0' I I CUKlIRLAHD COUNTY, PIHN8YLVAHIA I I 10. '4-4788 CIVIL TIRM I I PROTICTIOH 'ROM ABUSI I I I I DILORI. C. DILlXCY, I.IK A. DILAHCY, 'laintiffl KYLI C. DILAHCY, Defendant f~TITION FOR RETURN OF WEAPONS The plaintiff, by and through her attorney, Joan Carey of Legal services, Inc., represents the following: 1. On August 24, 1994, a Temporary Protective Order was filed by the plaintiffs asking for the confiscation of weapons in the home. 2. On August 25, 1994, the Cumberland County Sheriff's Department confiscated all weapons located in the residence at 580 Walnut Bottom Road, Shippensburg. 3. Two of the weapons seized, a Winchester Model 70 Caliber 270 #754804 and #402936 caliber 308 bolt action, belong to Gary Delancy, plaintiff Delores Delancy's husband. 4. The plaintiffs ask that the two weapons specified above be returned to GARY DELANCY upon presentation of the attached Order to the Sheriff's Department, and that the remaining weapons which belong to the defendant, KYLE C. DELANCY, be kept in the care and control of the Cumberland County Sheriff's Department. WHEREFORE, the plaintiff requests that the two weapons, '. ..-4_1 ..4_.." .. " ~: t " , " "~ ,~. /J .(' -I" " ." .,(1 ,'j;', '" ,. ,.;, , , 'f-I ~.' 1"', <.r", 1, '''' , , 1'\ r, I , , ! 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I, ;1 ". '\, 'J!f':'(lt.\C.'~'ljlqll' ',...f"n'I~I\ )11"1 --" '" ,'.'._....'1.. I' .1,1,( 'f' :j1t" 'da.I'fl I' . "',,,'!,.' 0 ',,' ,I ' 'J', ,~. ,,' I ,. .: I' t'l I,' I ) I. 11'1 \'I~'I l~'CI:;IIJ)'j ~"r.!I\["ill",:>'1, 1"',Vl\ ~'~~!lr'_I\lj'l I: I 'I ','1"1 1'\( J~'\rl '.:t'J'I~n;IIP{~}'J1~l \"r,r;,.,t)~\h'l1J~I!'" ,I r'~" ,.., ...'.,~ j,l,~qf:;f1"~flj1'~~ . '1 .' 1'1 I 1 .'/' , il" I I I I' ~ l/;" ~ f'l~y,.\.r'1~illj'\r~I\<,'.!,I,'I'I" I,ll ., \ ",.. illl L'I' II'f/"l\l,t;J.'t\ I " I ,'F 1)\' II I 1 I, ", J, (" I " 1,1' ,{\,'/,,,I, )~~~",I' 'l'eMN.~~-' ,L" ,'ii' ,q;l)ji"j, , "I, ~ !I'l' , -...---...--- "."", f . I" ILI'ji" . ~(,'fri'~\1!',I,,;o, "', , II I', mJJ1 I', II, l:lL,""I~\,:.' ,I""I,t o Il'11"l""il:,,:1 , 1 I' I~,... ~ \ ,'JI',/I,lJr,1 '1.]"lh',il'i'if\":!tlil'I,1 1'\1 '~"""~l I " 11"'I'I'iI~j ;1/"/"1'1','",,\, _, 1)"0'1 ~f'l )j~'Jl[.'~,""'l'lj\'JI' 1,,' J! ~.&...:":""",:-,I'IM."'_."'" '" If ,;1 .,,;~ t~I(~:t(;;~~~N:;~f:i2;~~;~;~~!t<,~i;:},';;" " , ~~~~nj71'&iiil "", /;::\J::'::J;"1;~iiiW!. ~;::: \ ... ~, II', t , ' ,J " J " \: I' , .' , " , ~! . " DELORES C. DELANCY, ERIN A. DELANCY, plaintiffs I I I I IN THE COURT OF COI(MON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94 - II JRS CIVIL TERM vs. PROTECTION FROM ABUSE KYLE C. DELANCY, Defendant TEMPORARY PROTECTIVE ORDER AND NOW, this ~day of August, 1994, upon presentation and consideration of the within petition, and upon finding that the plaintiffs, DELORES C. DELANCY and ERIN A. DELANCY, now residing at 580 Walnut Bottom Road, Shippensburg, Cumberland County, Pennsylvania, are in immediate and present danger of abuse from the defendant, KYLE C. DELANCY, the following Temporary Order is entered. The defendant, KYLE C. DELANCY, currently involuntarily committed to the psychiatric Ward at Carlisle Hospital, is hereby enjoined from physically abusing the plaintiffs, DELORES C. DELANCY and ERIN A. DELANCY, or placing them in fear of abuse and is excluded from the residence located at 580 Walnut Bottom Road, Shippensburg, Cumberland county, Pennsylvania, a residence which is owned by the defendant's parents, DELORES and GARY DELANCY. 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 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 relinquish to the Sheriff's Department the following weapons which he has used or threatened to use against the plaintiffs: Approximately eight shotguns and ammunition. The defendant is ordered to refrain from having any contact with the plaintiff including, but not limited to, entering their places of employment, harassing or stalking them, and harassing their relatives. 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 14" day of LL) J;:.." .i,.... , 1994, at 1/ '00 .D.m. in II . Courtroom No. r; , Cumberland County courthouse, Carlisle, Pennsylvania. The plaintiff may proceed in forma ~uperis 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 Pennsylvania state, Shippensburg University, and the Mid-Cumberland Valley Regional 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 where a violation occurs by arrest for indirect criminal contempt DELORES C. DELANCY, ERIN A. DELANCY, plaintiffs I I I I I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94 - q 1'6'i1 CIVIL TERM VS. PROTECTION FROM ABUSE KYLE C. DELANCY, Defendant NOTICE You have been sued in court. If you wish to defend against the claims eet 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 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 vs. IN THE COURT 01" COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94 - Ij 1~8 CIVIL TERM PROTECTION FROM ABUSE DELORES C. DELANCY, ERIN A. DELANCY, Plalnt1fh KYLE C. DELANCY, Defendant ~TITION FOR PROTE~TIVE ORDER AND CUSTODY RELIEF UNDER THE PROTECTION FROM ABUSE ACT 23 P.S. SECTION 6101 A. ABUSE 1. The plaintiffs are adult individuals whose permanent address is 580 Walnut Bottom Road, Shippensburg, Cumberland county, Pennsylvania, 17251. 2. The defendant is an adult individual currently involuntarily committed to the psychiatric Ward of the Carlisle Hospital, Carlisle, Cumberland County, Pennsylvania, 11013. 3. The defendant is the son of Delores Delancy and the brother of Erin Delancy. 4. Since approximately 1989, the defendant has attempted to cause and has intentionally, knowingly, or recklessly caused bodily injury to the plaintiffs and by physical menace has placed the plaintiffs 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 August 24, 1994, the plaintiffs returned home to find that the defendant had been released from the hospital. The defendant threatened the plaintiffs saying that they would go down: they had had it, causing the plaintiffs to fear for their safety. b. On or about August 18, 1994, after an argument with the defendant, Plaintiff Delores Delancy came home to find that all of the defendant's guns were missing from the home. Plaintiff Delores Delancy feared for her life and that of plaintiff Erin Delancy since the defendant frequently threatens to kill them including as recently as August 1994 when he picked up an unloaded rifle and pointed it at Plaintiff Delores Delancy saying, "I got you now." Plaintiff Delores Delancy called crisis Intervention who called the police. c. On or about August 9, 1994, when Plaintiff Delores Delancy went for a walk, the defendant started up his motorcycle, came at her at a high rate of speed, stopped defendant stopped his bike beside her and threatened, "I'd like to run you over and break your neck." The defendant then "revved" up the engine, and edged at Plaintiff Delores Delancy as if to run her down shouting threats and obscenities at her. Tho defendant then went a few feet in front of her, turned quickly, and threw dirt and stones on her. When Plaintiff Delores Delancy returned home, the defendant ran toward her, hit her in the shoulder with his chest, and threatened to smash her and break her neck. The defendant hit the Plaintiff Delores Delancy with his cheat several more times and threatened to "clean her clock and then yours," causing her to fear for her life. d. On or about August 6, 1994, the defendant became enraged, threw an air tank across the garage, smashed his motorcycle helmet, smashed the garage door with a sledge hammer, demolished a tool box with the hammer, tore garbage bags apart, ran upstairs and trashed his room including putting his fists through walls. Fearing their safety, the plaintiffs' got into the car and drove away. The defendant threatened them as they pulled away saying that if they weren't back in five minutes, he would come down and kill Plaintiff Erin Delancy. The defendant then threw the sledgehammer at the car, just missing it. The defendant picked up the sledgehammer and ran after the car, swinging it at the vehicle. When the plaintiffs returned home, the defendant was banging his fists on the porch and hitting his head against the back of the house. e. The defendant, at least 2 to 3 times per week, telephones Plaintiff Delores Delancy and threatens to kill himself and make her watch. On one occasion the defendant threatened that if Plaintiff Delores Delancy had him committed to the hospital again, she would see him dead and that he never wanted to see her again unless she were dead causing her to fear for her life. f. In or around the summer of 1992, Plaintiff Erin Delancy was having a picnic at her home with preschool children from her work. The defendant became enraged, grabbed a baseball bat, and chased Plaintiff Erin Delancy around the yard in front of the children, yelling that he wanted to crack her head open. g. In or around 1990, the defendant grabbed Plaintiff Erin Delancy by the neck, threw her into the sink, and punched her in the arm. Later when the defendant came home, he said to his mother, "Did you see what I did to Erin?" When his mother answered him, the defendant rolled up his sleeves and said, "Which mother fucker wants it next." The defendant then ran to the bedroom where the guns are kept, but his father got to the door and would not allow the defendant entry. The defendant then dove toward the kitchen drawer, grabbed a butcher knife, and chased his father and Plaintiff Erin Delancy around the kitchen with the knife until his father kicked it out of his hand. The defendant jumped off the deck and ran away. h. The plaintiff'S are afraid of the defendant and have been staying in hotels at night to avoid the defendant and his abuse. The defendant goes into uncontrollable rages and has destroyed over $6,000.00 worth of property of the plaintiffs including smashing windshields with his bare hands. The.e acts of violence cause the plaintiffs to fear for their safety due to past incidents of physical abuse. 5. On approximately August 18, 1994, the plaintiffs left their residence at 580 Walnut Bottom Road, Shippensburg, Cumberland County, Pennsylvania in order to avoid further abuse. 6. The plaintiffs believe and therefore aver that they will be in immediate and present danger of abuse from the defendant should they remain in the home without defendant's exclusion, and that they are in need of protection from such abuse. 7. The plaintiffs desires that the defendant be restrained from entering their places of employment, having any contact with them, harassing or stalking them, and from harassing their relatives. 8. The defendant has used or threatened to use the following weapons in his abuse of the plaintiffs: eight shotguns and ammunition. B. EXCLUSIVE POSSESSION 9. The home from which the plaintiffs are asking the Court to exclude the defendant is owned in the names of DELORES and GARY DELANCY. C. ATTORNEY FEE~ 10. The plaintiff asks for attorney fees to be paid to Legal Services, Inc. pursuant to the Protection from Abuse Act. ~STATUS TO fBQCEED IN FORMA PAUPERIS 11. The defendant is unemployed. 12. Plaintiffs Delores and Erin Delancy currently have been released fr.om work due to the defendant's behavior. 13. The plaintiffs do 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 P.S. section 6101 n H.Q., 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. Requiring the defendant to refrain from abusing the plaintiffs or placing them in fear of abuse. 2. Requiring the defendant to refrain from having any contact with the plaintiffs, including, but not limited to, entering their plaintiffs' place of employment, from harassing or stalking the plaintiffs, and from harassing their relatives. 3. Granting possession of the home located at 850 Walnut Bottom Road, Shippensburg, to the plaintiffs to the exclusion of the defendant pending a final order in this matter. 4. Ordering the defendant to stay away from any residence the plaintiffa may in the future establish for herself . 5. Ordering the defendant to relinquish to the Sheriff's Department the following weapons which he has u.ed or threatened to use against the plaintiffs: Approximately eight shotguns and ammunition. 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 plaintiffs or placing them in fear of abuse. 2. Requiring the defendant to refrain from having any contact with the plaintiffs, including, but not limited to, entering their places of employment, from harassing or stalking them, and harassing their relatives. 3. Granting possession of the home located at 850 Walnut Bottom Road, Shippensburg, to the plaintiffs to the exclusion of the defendant. 4. Ordering the defendant to stay away from any residence the plaintiffs may in the future establish for themselves. 5. Ordering the defendant to relinquish to the Sheriff's Department the following weapons which he has used or threatened to use against the plaintiffs: Approximately eight shotguns and ammunition. 6. Ordering the defendant to pay attorney fees to Legal Services, Inc. pursuant to the Protection From Abuse Act. The plaintiffs further asks that this Petition be filed and .', ;('!",' (- ;i', " 'I,' :'" " ._,i, " '11'j' ','1.;' ',;;., ,I I,' I". ,,. , " '" '1.' " ,:\ ., ~ , " " "/,I r 'J," i, I, , , , i 'I" 7' ........~..t....,~ (f) luc U 3 t~ ,,, 'N "F' " , j, ~ICt r. 'IIi., '///01'11'4"1' ,UMn. "L.l11/i crill/I' ' Pr'/'I/~YI"/II'~" <1/3500 ~ c., -.....'..."......, .u'"_._.";-.--..._....;._, . ", -~.,_...,.. 'I ., ''1:---.. I; '" , ,.. 'I " . , , . I . , , ... . 1:/1 .., "~\'J" . 1:""-..,.;, , , . r " . .:.. ,. , f r'".f7 ,~r .'~ / ! , ! "" . ":-,/,:,'/ , ,fti ~ " ,,' f:' " l,.,. r f / I, f ,/ (, , , " " " DELORES DELANCY I IN THE COURT OF COMMON PLEAS OF ERIN DELANCY I Plaintiffs I CUMBERLAND COUNTY, PENNSYLVANIA I vs. I NO. 94-4788 CIVIL TERM I KYLE DELANCY, I PROTECTION FROM ABUSE defendant I MAC DELANCY, IN THE COURT OF COMMON PLEAS OF Plaintiff I I CUMBERLAND COUNTY, PENNSYLVANIA : vs. I NO. 94-4788 CIVIL TERM DELORES DELANCY ERIN A. DElANCY, Oefendants ANSWER TO RULE TO SHOW CAUSE The plaintiffs in the Protection From Abuse action, Delores and Erin Delancy, hereinafter referred to as the respondents, by and through their attorney, Joan Carey of Legal Services, Inc., files the following Answer to the Rule to Show Cause entered pursuant to the Motion for Return of Weapons filed by Mac Delancy, hereinafter referred to as the petitioner: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Admitted. 6. Admitted. 7. Admitted. 8. Admitted in part. Denied in part. It is admitted that negotiations regarding the weapons have been in process. It is denied that the respondents lack any legal or authoritative basis for refusing consent to the return of the weapons for reasons set forth in New Matter. 9. Admitted. NEW MATTER 1. When the Cumberland county Sheriff's Department seized thirteen weapons from the defendant's residence pursuant to the Protection Order of August 24, 1994, the Sheriff did not seize the weapons of Kyle Delancy, hereinafter referred to as the Defendant. 2. The respondents saw weapons in the back of the petitioner's vehicle when he left the respondent's residence with the defendant after retrieving his belongings. The respondents believe that the defendant took his weapons to the petitioner's residence immediately prior to the entry of the Temporary Protection Order. Only months later, after the respondents saw the list of weapons from the Sheriff's Department, did they know that none of the defendant's weapons had been seized. Therefore, when the sheriff seized weapons pursuant to the Protection Order, the defendant's we~pons were not seized. Instead, eleven of the weapons suized were the petitioner's and two of the weapons were the respondent's husband's weapons. 3. Since the entry of the Protection From Abuse Order, the respondents have seen several incidents including the following where the defendant has acted in ways which caused the respondents to fear for their safety and to question whether the petitioner has the ability to control the defendant: a. On .everal occasions since the entry of the Temporary Protection order, while screaming obscenities, the defendant has ridden his dirt bike at high rates of speed in front of the respondent's residence, causing stones to fly into the respondent's yard. b. On or about March 6, 1995, the respondents saw the defendant throw a bucket at his girlfriend. When the petitioner intervened, the Defendant pushed him, punched the girl in the stomach and pulled her to the ground by her hair. The defendant also shoved a wheelbarrow at the petitioner. Then, although he had not driver's license, the defendant then went into the barn, got into a car, and drove recklessly down the road and through the field, wildly and heedlessly spinning in circles. The respondents feel that the petitioner has no control over the defendant. 4. On several occasions prior to the entry of the Protection From Abuse Order, when the defendant became angry at the respondents, he frequently threatened them with guns. The respondents feel that they are in danger as long as the defendant has access to guns. Because the petitioner is not able to control the defendant, the respondents fear for their safety if the petitioner's weapons are kept in his residence where the defendant resides, as the defendant could gain access to the weapons. 5. Because of the escalating violent outbursts by the defendant since the entry of the Temporary Protection Order, including that of March, 1995, where he became violent with the petitioner, the respondents fear for their safety if any weapons are in his possession or if he has access to weapons. 6. In the past, the defendant has destroyed property in way. including breaking things with sledgehammers; therefore, if the petitioner'S weapons are returned to him, the respondents fear for their safety unless those weapons would be kept in a secure place outside the petitoner's residence where the defendant currently lives. WHEREFORE, the respondents request that the weapons currently held in the possession of the Cumberland County Sheriff's Department remian in their custody. Alternatively, if the weapons are returned, the respondents ask that those weapons not be kept at the petitioner'S current residence while the defendant is living there. The respondents further request that the defendant turn over to the sheriff his weapons, including six shotguns - one a double barrel Fox 243 and an 1187 black Premier. The respondents also request that a new hearing date be set in the Protection From Abuse case which has been generally continued. The respondents further ask for any other relief which is just and proper. Respectfully submitted, 'I 1/ '. ,~-,'i/, jJoan Carey " Attorney for Resp <ients LEGAL SERVICES, I C. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 Thll I\bOVIl-rllIJlled deferlllulltH. IlEl.tJIU.S IlEl.i\NI'Y Ilnd ERIN DEl.ANCY, verify thut the Htlltelllents III111te In the IlhllVe' ArIHwcr lire trull lInd correct. The defelldunts ullclerslund lhllt flllsll stutll,lIIcnts herein ure Illude suhJl'ct tll the pellullleH llf III PIl. C.S. section 4904, rellltlng III UII:;WllJ"n flllslficullllll tn authorities. Oil t e: r10}1J~,1__~,\ I- \Jr:\hu ,LL,".l)l~~ h..~~1~11('}.\.....___..___ nel:t'es [klanc'~, llef't\,\ldllnt &;[0 ,(;J.lJI\.5r'tH.,__..__.__.__ Erin Delancy, Def'endJnt ' D ute: J) 111<: LS-lv.'dd' ,':),,1., _ Lt 'J S-:. , ,..,1; , i' . I~ , , , I: " I \ .. i .' Ii I dPR 'I L/ 113 PH '95 " .J'flCr' 1/ IU)II'" "", ...1 "'Y ,,/, ""(- "" ',.' I')'y II. ,',' .' II,~ . I I, Gf I. ,,-I .. 1"1 . , ;"d-';I 1:1;1\1; ,:' ,', . \'i , " ' , ' '. "\t,', ':!';';' i' I '1'1' .' 't. V' I" i..~' .'., :,.-.\i 'i.' .' .,!~,;: .,', ~(:!' " ~: ,I 'I, ' ,'..' I' i '.: -l~ ,- ! ~~! ; , .-: i ~l,t::':',;.: ;t:",'.'.j"', :~~r:,,\;',;i,' " (.:' .",-...>-. ,~."..t.~...>..,.. '''~T'__''~k ,-, ~..,-", ._.a'l_ ~"~"''''''''''''''_Il~__'' 1 -~.......,....."., , e,f \l. 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';, ;1', ',~ ~.j.fjJ\ ,I 1,:;:J[j,'/;:f7"}i'~ ,~ ,- -.,'..' ,..'(' .:,' '....~ V,\'-:"_"i;\jfj\ " ~ ,,' H'\ ..~' ',>:I.__I;_'i!--/_;I: ".,__-.,.l..i'-\ 1',.'I).!,:'<II', , . :\'J,~~",~fi,l'llj~ ,';,~;~"'.-VI\' 'f,,'.I>I;, I' ,1 "'I.\:j-'_;t/;~/:'S Hdll j,'\I~.': i. I:, '~'-'i\1 ,j ,!:It,\'tk';:~ ,1.i~)I' ['If)! t' .I")::')l/'l~.;'t~t,j , 11'!!i' ,i;Vi ''-'_''i-i-.!JI-i",!.;ll:1'l ,,_.' "./' "'(11 __"\,,,,},rfl\li7l"~!/ . _:I:';:'/li,hDj-~fi.~ -: ;;::i,f:\~i~~7~;\~'t~z~ ("""ll~'-;i-'ll,tti\: , ".""1'1" i,ji_!':i/'I'f.1,'-j ':'l,;y:-'!:,}!;~;Ii-, , '1;"I'i,~IM , dl,I,,!,j' '1\!;:;!J:::li ,I ,.1;;". ':}rI:l;I:_i r',:."lt ,'" ,'..:':i','I;,.\,:,:,,:'i,\ , I, :.i,,"lei ~:' ,!,l;',V': " ,:' " , ! ., ~?\\ " IU ?~ ~\, I~~ ~ , 1,1 ,'It_ ',"\' (,t.; " , Ii" ,\ " <.1 ~. , ' ,\ I' , " . J 'I . DELORES C. DELANCY, ERIN A. DELANCY, Plaintiffs IN THE COURT OF COMMON PI,BAS CUMBERLAND COUNTY, PENNSYLVANIA v CIVIL ACTION - LAW NO. 94 - 4788 CIVIL TERM KYLE C. DELANCY, Defendant PETITIONER. MAC DELANCY'S. RESPONSE TO NEW MATTER AND NOW, this 8.kh day of ~, 1995, comes Petitioner, Mac Delancy by and through his attorney, Timothy P. Keating who respectfully submits the following in response to Plaintiff's New Matter: 1. Admitted that none of the weapons seized by the Sheritf (except for the Winchester model 70-243) belonged to Kyle Delanoy. 2. Denied. It is denied that Kyle Delancy took any weapons from the residence of Delores and Erin Delancy after the entry of the Protection from Abuse Order. 3. A. Denied. It is denied that Kyle Delancy did the acts alleged in this paragraph. B. Denied. It is denied that Kyle Delancy did the acts alleged in this paragraph. Kyle Delancy has never acted violently towards Mac Delancy or towards anyone else. 4. Neither admitted or denied. These allegations concern a time period prior to the entry of the Protection from Abuse Order and therefore are not relevant to peU Uoner I s our rent replevin type matter. Furthermore, it is noted that respondents while ~_.. ".... " , , , , {'I, i ~ 'I~ , ,,. 'I; 11 " I' II , l " ~ bELORES DELANCY, ERIN DELANCY, plaintiffs I IN THE COURT OF COMMON PLEAS OF I I CUMBERLAND COUNTY, PENNSYLVANIA : v. NO. 94-4788 CIVIL TERM KYLE DELANCY, Defendant PROTECTION FROM ABUSE AND NOW, this paOT.OTIO" ORDBR tL i.~::1' , day of , 1995, upon consideration of the Consent Agreement of the parties, the following Order is entered: 1. The defendant, KYLE DELANCY, SS:UNKNOWN and DOB: 6/11/75, is enjoined from physically abusing the plaintiffs, DELORES and ERIN DELANCY, or from placing them in fear of abuse. 2. The defendant is enjoined from having any direct or indirect contact with the plaintiffs including, but not limited to, telephone and written communications. 3. The defendant is ordered to refrain from harassing and stalking the plaintiffs and from harassing the plaintiffs' relatives. 4. The defendant is prohibited from entering the plaintiffs' place of employment. 5. The defendant is excluded from the plaintiffs' residence located at 580 Walnut Bottom Road, Shippensburg, Cumberland county, Pennsylvania. 6. The defendant is ordered to stay away from any residence the plaintiffs may in the future establish for themselves. 7. The Cumberland County Sheriff's Department will return to Mac Delancy the weapons which were confiscated in the case, and Mac Delancy will keep the weapons out of the possession or control of the defendant, KYLE DELANCY. 8. The defendant, KYLE DELANCY, will not own, possess, or purchase, any weapons for the duration of this Order. 9. The court costs and fees are waived. 10. This Order shall remain in effect until August 24, 1995, but may be extended beyond that time if the Court finds that the defendant has committed another act of abuse or has engaged in a pattern or practice that indicates continued risk of harm to the plaintiff. 11. This Order may subject the defendant to: i) arrest under 23 Pa. C.S. 56113; ii) a private criminal complaint under 23 Pa. C.S. 56113.1; iii) a charge of indirect criminal contempt under 23 Pa. C.S. 56114, punishable by imprisonment up to six months and a fine of $100.00-$1,000.00; and iv) civil contempt under 23 Pa. C.S. 56114.1. Resumption of co-residence on the part of the plaintiff and defendant shall not nullify the provisions of the court order. 12. The Pennsylvania state and Mid-Cumberland Valley Regional Police Departments will be provided with certified copies 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 DELORES DELANCY, ERIN DELANCY, IN THE COURT OF COMMON PLEAS OF Plaintiff. CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4788 CIVIL TERM PROTECTION FROM ABUSE v. KYLE DELANCY, Defendant ~OH8IHT AORIIMIHT This Agreement is entered on this ,~~,~~ day of June, 1995, by the plaintiffs, DELORES and ERIN DELANCY, and the defendant, KYLE DELANCY. The plaintiffs are represented by Joan Carey of LEGAL SERVICES, INC.; the defendant is represented by Timothy Keating of COSTOPOULOS, FOSTER & FIELDS. The parties agree that the following may be entered as an Order of Court. 1. The defendant, KYLE DELANCY, agrees to refrain from abusing the plaintiffs, DELORES and ERIN DELANCY, or placing them in fear of abuse. 2. The defendant agrees not to have any direct or indirect contact with the plaintiffs, but not limited to, telephone and written communications. 3. The defendant agrees not to harass and stalk the plaintiffs' and harass the plaintiffs relatives. 4. The defendant agrees not to enter the plaintiffs' places of employment. 5. The defendant agrees to stay away from the plaintiffs' residence located at 580 I~alnut Bottom Road, Shippensburg, Cumberland County, Pennsylvania. 6. The defendant agrees to stay away from any residence the plaintiffs may in the future establish for themselve.. 7. The Cumberland County Sheriff's Department will return to Mac Delancy the weapons which were confiscated in the case, and Mac Delancy agrees to keep the weapons out of the posses. ion or control of the defendant, KYLE DELANCY. 8. The defendant, KYLE DELANCY, agrees not own, possess, or purchase, any weapons for the duration of this Order. 9. The defendant, although entering into this Agreement, does not admit the allegations made in the Petition. 10. The defendant understands that the Protection Order entered in this matter shall be in effect until August 24, 1995, or until modified or terminated by the Court after notice or hearing and, can be extended beyond that time, if the Court finds that the defendant has committed another act of abuse or has engaged in a pattern or practice that indicates continued risk of harm to the plaintiff. 11. The defendant understands that thi.s Order shall be enforceable in the same manner as the Court's prior Temporary Protection Order entered in this case. WHEREFORE, the parties request that a Protection Order be - I." " JIll 6 9 49 All '95 ';'{i~!( ",'j)~;\b ,I "~# ,1'r)!;/rtJ,,' ,'Ji)t'" '" i;#lt~lI / ',!~III . , '''IL'M,\ ,'.' f r;r!~, ,I( ~f,'{ '"11' r ,1.,Il, (if, 'Itp!\;.!~~it'! , :/~"jl{:ij,~ ' "l" ':fti~,'l'I-'(" ',\,.".,0'\1 '~~/~\t ':', ~:f:~!ldl~,~l,~q, ; '1'/l/ll!i"'/f~".'I~. .4':'!\'l' , I., >. " 'lJ'r,"'J~! 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