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HomeMy WebLinkAbout95-01843 '. STEPHANIE A. MYERS, plaintiff IN THE COURT OF COMMON PLEAS OF v. CUMBERLAND COUNTY, PENNSYLVANIA NO, 95-/S''/3 CIVIL TERM ROBERT M, MYERS, Defendant PROTECTION FROM ABUSE TEMPORARY PROTECTION ORDER AND NOW, this lot\" day of April, 1995, upon presentation and consideration of the within Petition, and upon finding that the plaintiff, STEPHANIE A. MYERS, now residing at 239 Bobcat Road, Carlisle, Cumberland County, pennsylvania, is in immediate and present danger of abuse from the defendant, ROBERT M. MYERS, the following Temporary Order is entered, The defendant, ROBERT M. MYERS, SSN: 181-58-0898 and DOB: 11/28/67, now residing at an unknown location, is hereby enjoined from physically abusing the plaintiff, STEPHANIE A. MYERS, or placing her in fear of abuse. The defendant is ordered to stay away from the plaintiff's residence located at 239 Bobcat Road, Carlisle, cumberland county, Pennsylvania, a residence which is leased solely by the plaintiff, of which the plaintiff has exclusive possession through a divorce action, 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, except for the limited purpose of facilitating custody arrangements. The defendant shall pick up and drop off the children at the time of custody at the Un i-Mart in plainfield and wil~ remain in his vehicle at all times. The defendant is enjoined from harassing and stalking the plaintiff and from harassing the plaintiff's relatives. The defendant is enjoined from entering the plaintiff's place of employment or the schools of the minor children, A violation of this order may subject the defendant to: i) arrest under 23 Pa. C.B. 56113; ii) a private criminal complaint under 23 Pa. C.B. 56113.1; iii) a charge of indirect criminal contempt under 23 Pa. C.B. 56114, punishablo by imprisonment up to six months and a fine of $100.00-$1,000.00; and iv) civil contempt under 23 Pa. C.B. 56114.1. Resumption of co-residence on the part of the plaintiff and defendant shall not nullify the provisions of the court order. This Order shall remain in effect 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, The defendant is ordered to relinquish to the sheriff's department the following weapons which he owns, possesses, has used or threatened to use against the plaintiff: .22 magnum semi-automatic rifle, 300 Remington rifle, 7600 BDL 30.6, semi- automatic pistol, 30/30, and a .12 gauge shotgun, and the defendant is prohibited from acquiring or possessing any other weapons for the duration of this Order, This Order shall remain in effect until modified or terminated by the court after notice or hearing. A hearing shall be held on this matter on the i1J7t day of April, 1995, at 1: .~(l -- f.m., in Courtroom No.~, Cumberland County Courthouse, carlisle, Pennsylvania. The plaintiff may proceed without pre-payment of fees pending a further order after the hearing. The Cumberland County Sheriff's Department shall attempt to make service at the plaintiff's request and without pre-payment of fees, but service may be accomplished under any applicable rule of civil Procedure. This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service. The Prothonotary shall not send a copy of this Order to the defendant by mail. The Pennsylvania State and Middlesex Township Police Departments will be provided with certified copies 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 STEPHANIE A. MYERS, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 95- CIVIL TERM ROBERT M, MYERS, Defendant PROTECTION FROM ABUSE NOT ICE 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. FEED AND COSTS If the case goes to hearing and the judge grants a protection Order, a surcharge of $25.00 will be assessed against you, You may also be required to pay attorney fees to Legal Services, Inc. for their representation of the plaintiff, You should ta~e 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 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of common Pleas of Cumberland county is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95- 13~3cIVIL TERM STEPHANIE A. MYERS, Plaintiff ROBERT M. MYERS, Defendant PROTECTION FROM ABUSE PETITION FOR PROTECTION ORDER RELIEF UNDER THE PROTECTION FROK ABUSE ACT, 23 P.S. S 6101 at saq. A. ABUSE 1. The plaintiff, STEPHANIE A. MYERS, is an adult individual residing at 239 Bobcat Road, Carlisle, Cumberland county, Pennsylvania 17013. 2. The defendant, ROBERT M. MYERS, SSN:181-58-0898 and DOB: 11/28/67, is an adult individual residing at an unknown location. 3. The defendant is the husband of the plaintiff. 4. since approximately 1987, the defendant has attempted to cause and has intentionally, knowingly, or recklessly caused bodily injury to the plaintiff, has placed the plaintiff in reasonable fear of imminent serious bodily injury, and has knowingly engaged in a course of conduct or repeatedly committed acts toward the plaintiff which have placed the plaintiff in reasonable fear of bodily injury. This has included, but is not limited to, the following specific instances of abuse: a. On or about April 2, 1995, while at the plaintiff's residence to return the child from a visit, the defendant came up behind the plaintiff and pushed the plaintiff through the door, causing her to trip and hit her shoulders against the door and wall. The defendant then grabbed the plaintiff by the arms and slammed the plaintiff repeatedly against a wall, causing external and internal bruising about the plaintiff's back. When a friend of the plaintiff entered the room, the defendant left the plaintiff's residence. The plaintiff telephoned the police who charged the defendant with harassment, The plaintiff received medical treatment from her family doctor and is currently on medication for back pain. Later that evening, the defendant returned to the plaintiff's residence and banged on the door, leaving only when the landlord came down, b. In or around November 1994, the defendant grabbed the plaintiff by the throat and threw her to the floor. The plaintiff suffered soreness about her neck. c. On two occassions in or around October and November 1994, the defendant attempted to sexually assault the plaintiff by pinning her on the bed and forcing himself on her. On one occasion, the defendant stopped only when their son walked in/and on the other occassion, the plaintiff was able to fight off the defendant. d. In or around October 1994, the defendant held a shotgun to his head and threatened the plaintiff saying, "It's you or me". e. since october 1994, the defendant abused the plaintiff in ways inClUding, but not limited to the following: shoving, throwing, pulling hair, slapping, and attempted to sexually assault the plaintiff. The plaintiff left the defendant in December 1994, and the defendant purchased several weapons and brings them along when hecomes to pick up the children, causing the plaintiff to fear for her safety. 6. The plaintiff believes and therefore avers that she is in immediate and present danger of abuse from the defendant, and that she is in need of protection from such abuse. 7, 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, except for the limited purpose of facilitating custody arrangements. The defendant shall pick up and drop off the children at the time of custody at the Uni-Mart in Plainfield and will remain in his vehicle at all times. B. The plaintiff desires that the defendant be enjoined from harassing and stalking the plaintiff, and from harassing the plaintiff's relatives, 9. The plaintiff desires that the defendant be restrained from entering her place of employment or school of the minor children, 10. The plaintiff desires that any weapons the defendant owns, possesses, and has used or threatened to use against the plaintiff be confiscated by the Sheriff's Department. B. ATTORNEY FEES 11. The plaintiff asks that the defendant be ordered to pay reasonable attorney fees to Legal Services, Inc, WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of October 7, 1976, 23 P.S. S 6101 et ~., 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, except for the limited purpose of facilitating custody arrangements. The defendant shall pick up and drop off the children at the time of custody at the Un i-Mart in Plainfield and will remain in his vehicle at all times; 3. Ordering the defendant to refrain from harassing and stalking the plaintiff and from harassing the plaintiff's relatives; 4. Prohibiting the defendant from entering the plaintiff's place of employment or the schools of the minor children; 5, Ordering the defendant to stay away from the plaintiff's residence located at 239 Bobcat 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 relinquish to the sheriff's department the following weapons which he owns, possesses or has used or threatened to use against the plaintiff: .22 magnum semi-automatic rifle, 300 Remington rifle, 7600 BDL 30,6, semi- automatic pistol, 30/30, and a ,12 gauge shotgun, and prohibiting the defendant from acquiring or possessing any other weapons for the duration of the order. 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, except to facilitate custody arrangements. The defendant shall pick up and drop off the children at the time of custody at the Un i-Mart in Plainfield and will remain in his vehicle at all times. 3. ordering the defendant to refrain from harassing and stalking the plaintiff and from harassing the plaintiff's relatives. 4. prohibiting the defendant from entering the plaintiff's place of employment or schools of the minor children, 5. ordering the defendant to stay away from the plaintiff's residence located at 239 Bobcat 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 relinquish to the sheriff's department the following weapons which he owns, possesses or has used or threatened to use against the plaintiff: .22 magnum semi-automatic rifle, 300 Remington rifle, 7600 BDL 30.6, semi-automatic pistol, 30/30, and a .12 gauge shotgun, and prohibiting the defendant from acquiring or possessing any other weapons for the duration of the Order, 8. Ordering the defendant to pay reasonable attorney fees to Legal Services, Inc, The plaintiff further asks that this Petition be filed and served without pre-payment of fees by the plaintiff, and that certified copies of this Petition and Order be delivered to the . " Pennsylvania state and Middlesex Township police who have jurisdiction to enforce this Order. The plaintiff prays for such other relief as may be just and proper. Respectfully submitted, L!l../t---H.../ ?J. Gr./{- /- ( can carey, Attor _ for plaintiff 'LEGAL SERVICES, I C. B Irvine Row Carlisle, PA 17013 (717) 243-9400 The above-named plaintiff, STEPHANIE A. MYERS, verifies that the statements made in the above Petition are true and correct, plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. C.S, 54904, relating to unsworn falsification to authorities. Date: 4-7,9S STEPHANIE A. MYERS, Plaintiff v, , . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 95-1843 CIVIL TERM PROTECTION FROM ABUSE . . ROBERT M. MYERS, Defendant ORDER FOR CONTINUANCE AND NOW, this ~ day of April, 199j(, upon consideration of the attached Motion for Continuance, the hearing scheduled for April 19, 1995, at 3:30 p,m. in Courtroom No. 5, is continued until i)1Il<! - S , 1995, at ,r: /1:'- Q,... m. The Temporary Protection Order will remain in effect for a period of one year or until a final Order is entered in this case. This Order and Motion shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service along with the original Complaint. The Prothonotary shall not send a coy of this Order and Motion to Defendant by mail. , A copy of this Order for continuance will be provided to the Pennsylvania State and Middlesex Township Police Departments by the attorneys for the plaintiff, By the Court, . J, M'il 20 9 13 ,'111'95 ';,'r ~ v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO, 95-1843 CIVIL TERM STEPHANIE A. MYERS, plaintiff ROBERT M. MYERS, Defendant PROTECTION FROM ABUSE 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 Protection Order was issued by this Court on the 10th day of April, 1995, scheduling a hearing for the 19th day of April, 1995, at 3:30 p.m, 2, The Cumberland county Sheriff's Department deputized Allegheny County Sheriffs to make service on the defendant. 3. The Allegheny Sheriff's Department has not been able to effect service. 4. The plaintiff requests that a continuance be entered and that the Temporary Protection Order remain in effect for one year or until a final order is entered in this case. 5. A copy of the Order for continuance will be delivered to the Pennsylvania State and Middlesex Township Police Departments by attorneys for the plaintiff. WHEREFORE, the plaintiff moves this Court to grant the Order of Court. ~"J/ ~CJ-....<-///' ;:r an Carey , ttorney for Plain iff LEGAL SERVICES, INC. a Irvine Row Carlisle PA 17013 (717) 243-9400 i: I I'. plaintiff's Motion and to continue this matter pending further \. c_ .. "I ~ '" } j .~ ~ ..... ..:J ~ ../ .:j' ... 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ALLEGHENY COUNT!{ SHERIFF'S DEPART1NT ~OOM 111 . COURTHOUSE ~ PITTSBURGH, PA 1521~(' I!Y\ iL. . \ \..J' Phono:?, 30, 0 ::P .'/ "0LAINTIFF s-rePA ~ Pr fYL;llo/$ ~.,' "Fe. etw~ (VI rn~ 't/lIJ \ IMMo,m,' '"''' J 0 COMPLAINT ONLY ADD, DEFT, . 0 NOTICE AND COMPLAINT '"0. 0' . ~ [) $i; 0 "",^U,"'" GAR EE ' 0 INTERROGATORIES ~'- -~ lri l ,. I (,J ill pN 1M III 0 ,,'CUTON . "" plJc ' -( IV .' v t(cARNISHEE 1'-(::" MUNICIPALITY WARflTY WARD .,.." , 1/;. OTHER DATE:~ 19 PHON: ' INDICATE lYPE OF SERVICE, 0 PERSONAL 0 PERSON IN 3~ , EUGENE L.COON Sherll! . . JOHN M, McNAMARA Chle' Oepuly RGE 0 DEPUTIZE 0 CERT, MAIL 0 POSTED 0 OTHER 0 LEV'( 0 SEIZED & STORE 1D_ I, SHERIFF OF ALLEGHENY COUNTY, PA do hereby depuUze IhO Sheri II 01 County 10 o.OCUIO Ihl. Wrll and mako falurn therool accordlnD 10 law, NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.D. WAIVER OF WATCHMAN. Any depulV ah,rltI levying upon or alllChlng Iny propelty under wilhln wril may Ie....... 11m. wllhout . walchman,ln custody 01 whomlVlr I, 'ound In po.unlon, ,hlr notifying pltlon 01 IllV)' or .nachmenl. wilh oul IIblllty on Ih, part 01 auch deputy herein lor any 10.., destruction or ,emC7Jel of Iny aue" property before Iherill'. ,,10 thereof. Now, Solzo, lo~y, advortlso and sol! 011 tho personal proporly ollha derondanl on the prom laos localed al: MAKE MODEL MOTOR NUMBER SERIAL NUMBER LICENSE NUMBER SHERIFF'S OFFICE USE ONLY , hereby CERTIFY end RETURN Ihel on Ihe .}~ dey 0' -----rrv- o'clock, A....V Addr,," Above/Addr"s Below. County or Allegheny, Pennlylvanla I hllV~rved In the mlnr'lor Described bebw' .6 Delend.nt(.) porsonally IIrved. o Adult family member wllh whom ,aid Delendant(.) feslde(s), Nam. & nelationship o "dull In charge of Oelendant', retidence who refuled 10 give name or relationship. o Manager/Clerk of place 01 lodging In which Delandanl(l) reslde(s). o Agent or porson In charge or Dolandanl(s) oliCI Dr ulual place 01 bUII"n,. o Olher D Property POlled Oelend.nt not found bOCluse; 0 Moved o Certified Mall 0 Receipt o Aeguler MliI Why: l~el o UnknCMn 0 No Anrwer o Envelope "elurned o Vacant o Other o Neither Receipt Of envelope returned: writ ,_plred You are hereby notified thaI 011 Sale has been sel~~l , -Add. eo~1 duo::> I ( ......- ATTEMPTS ,19_, levy was made In the case 01 , 19_. 01 _ o'clock, ~ MAY 0 91995 Nott..!ilISuJ SlVlila R. OtYi.n, Nolo1ry f'uljc P1IIlJ"'l)Il. ~""1''''"'' Ccuoty MyComn;s.oon H'pr..Jllnel'l,19'JIl ,'U1nsytvat'ia" Oopuly crill Yellow. Sheri II Pink Copy. Allomoy ..\ ~(q Sl~k cttt-ClQ..t'-uJ t?0t29J.nl Euai~~rhiCOON . ALLl:GHENY COUNTV'SHE . ROOM 111.C THOUSE PITTSBURGH, PA 16219 \ \ ~INTIFFS (V2 ~ it Ol~ i./Ei: 360,4700 \V VS, DEFT, ADD, DEFT, ADD. G ISHEE ADORES MUNICIPALITY WARD/CITY WARD DATE:~~ PHONE. JOHN M. McNAMARA Chief Deputy """C1$" - I?,B '$ EXPIRES~fif!IPt '~! o SUMMONS/PRAECIPE o COMPLAINT ONLY , iL ~ 0 NOTICE AND COMPLAINT tJ. o REVIVAUSCI FA 'J DINTERROGATo~ra o EXECUTION. L V .fJ GARNISHEE ' I ltOTHER- ~D. MhPLi.~ INDICATE lYPE OF SERVICE: 0 PERSONAL 0 PERSON IN CHARGE 0 DEPUTIZE 0 CERT, MAIL 0 POSTED 0 OTHER 0 LEVY 0 SEIZED & STORE 19_ I, SHERIFF OF ALLEGHENY COUNlY, PA do horoby dopullzo tho Shortll of Counly 10 oxoculo this Wrll ond mako rolurn Ihorool accordln9 to low, NOTEt ONLY APPLICADLE ON WRIT OF EXECUTIONI N.D. WAIVER OF WATCHMAN. Any deputy .hen" fevy1ng upon or all aching 8n)' properly undor wilhin writ may losvI lima wllhout. walchman,ln cUltody 01 whom.....' I. found In pOllnalon, a"e, notlfylng perton elllY)' 01 IlllChment, with out IiIblUty on the par1 01 .uch deputy horeln for any 10.., destruction or romovel 01 any luch plopen)' befoll aherUr. I.'" thereor. Now, Seize, levy, advertise end sell ell the personel properly of the defendant on the premises located at: MAKE MODEL MOTOR NUMBER SHERIFF'S OFFICE USE ONLY I hereby CERTIFY and RETURN thai on tho SERIAL NUMBER LICENSE NUMBER dlY 01 o'clock, A.MJP.M. Addtes, Above/Add".. Below, County or Allegheny, Ponnlylvanla 19_at I hlVa served In Iha manner DelCribed bobw: o Defendanl'l) pOflonlll1y served. o Aduh lemily member with whom IBId Derendanl(l) rOlldl(I). Name a. nelalionstip o Aduh In chatge of Delandlnt', relldence who relused to give nama or ,elaUonshlp. o Manager/Clerk 01 place of lodging In which Def.ndantll) ,nld'(I). o Agent or person In charge 01 Defendant(l) onc. or Ulual place Dr buslno... o Other o propmy Posled DoI.ndlnl nol found becaUle: 0 Moved o Certined Mall 0 Rocelpt o R.gular Mall Why. o Unknown 0 No Answer o Et1\Ielopa nelu:ncd o Vacanl ,19_0 levy was made In Ihe case of , 19_0 al _ o'clock, You are hereby nolllled that on Sale has been set fWvl-A KcId, COSI aue $.:=LUL./' ATTEMPTS 1- Whllo Copy' Shorlll Vollow . Shorill EUGENE L. COON, Sheri" DepulY Cltrlcl Pink Copy. Allornoy \.... _t c . . C -\ l"'c:'I OUrT CT --mo""".... .. .::1......~ ...' .... ....... .1 I --- Psrmsy I Vc:r: i:: " .. I t d.' ~r · ''''''-'''~l''n . ''''-'''1 _ .....o.Jt.._...... _, ""....,....1/1 Stephanie A, Myers '15. Robert M. Myers ::-roo 95-1843 Ci}:.iJ Tenn :~- ;';ow, April 1 J. 1995 :9__ !. SEZ:..!:? O? C~G:::?..!.A...'ID COt..;.r,:,~. ?~ co h=-.by ci.::utb:: cl:.:: S==E oi Allegheny CtoJu:.ty :0 :.::='.1t: =.is 'tV::; .., .. . .. .......,. ,- =:s =?u=::.cn =:=.g -.,...- ~t =-= :-=qu=t ::a :-~ Ot :.:: :'.:L:::=. -l #' '? ""('~ ",: /.... /.. _0 ~ . ," . .," _"/. '.1,: .'olo ,__ .,,' /.....,_A l' ...-;...::::...".I'~p..... ~ -f "- 'J' ...-';;:.c-...........~ Si1e..~ Qt C::::::er'..1l:d C~U:I"1. ?:I.. " A,Sd2.vit or Sem~ ;';ow, ~9 o'.:!cc \,[. . .- !=-.~ :.:e ~.;.:" ~paa ~t by ::u:d!:q :0 3. c:::pr ci ::::: o~;':""." .. :md -!I":. bown :0 . , . == ":::::11::::3 :..~:::::t. So =we:, ~~~'i of CDw"T. ?.. Swcr: ;u1d r.:bc:-:od bdcm: ccsrs ::.e..~v"IC:: ~a:U.AGE .-\.::wA"vTI oS =:~_Qyoi 19_ _____I s 1- "--4 No. ~5-18A~____ Term. 19 ~teQhanie A. MY.er~, Plaintiff VS, B~~~rt M. Myers, Defendant PRAECIPE Filed 19 __--"9!!n CarEU' . Atty, LI;!2AJ. SER'i.LC!;'li.. INC. " " ,,- -= ::g