HomeMy WebLinkAbout96-02275
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JULIE M. ERICKSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
DARYL S, 8RADY,
Defendant
NO. 96- .!J7'; CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
TBHPORARY PROTICTION ORDER
AND NOW, this ~~ t/ day of April, 1996, upon presentation
and consideration of the within Petition, and upon finding that
the plaintiff, JULIE M. ERICKSON, now residing at 1568 W, Penn
street, Carlisle, Cumberland County, Pennsylvania, is in
immediate and present danger of abuse from the defendant, DARYL
S. BRADY, the following Temporary Order is entered,
The defendant, DARYL S, BRADY, SSN:179-58-9439 and
DOB:1/26/74, now residing at 1028 West Pomfret Street, Carlisle,
Cumberland county, Pennsylvania, is hereby enjoined from
physically abusing the plaintiff, JULIE M. ERICKSON, or placing
her in fear of abuse.
The defendant is ordered to stay away from the plaintiff's
residence located at 1568, West Penn street, Carlisle, Cumberland
County, Pennsylvania, a residence which is leased solely by 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 relatives.
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The defendant is enjoined from entering the plaintiff's
place of employment or school.
The defendant is enjoined from removing, damaging,
destroying or selling any property owned by the plaintiff.
A violation of tbis Ordsr .ay subject tbe defendant tOI i)
arrest under 23 .a. c... 5'113; 1i) a private cri.inal complaint
under 23 .a. C... 5'113.1; iii) a cbarqe of indirect criminal
conte.pt under 23 .a. C... 5'114, punisbable by imprisonment up
to six .ontbs and a fine of tl00.00-tl,000.00; and iv) civil
cOlQte.pt under 23 .a. C... 56114.1. ResWDptioD of Clo'-reai4ence
on tbe part of the plaintiff and defendant sball not nullify the
provisions of tbe court ordor.
This Order shall remain in effect until modified or
terminated by the Court after notice or hearing and can be
extended beyond its original expiration date 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.
Temporary custody of DARIEL L. ERICKSON, is hereby awarded
to the plaintiff, JULIE M. ERICKSON.
A hearing shall be held on this matter on the ,~i1(1 day of
May, 1996, at '., 'I' . \ .m., in Courtroom NO.~, Cumberland
County Courthouse, Carlisle, Pennsylvania,
The plaintiff may proceed without pre-payment of fe.s
pending a further order after the hearing.
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The defendant is enjoined from entering the plaintiff's
place of employment or school,
The defendant is enjoined from removing, damaging,
destroying or selling any property owned by the plaintiff.
A violation of thia Order may aubjeot tbe defendant tOI i)
arreat under 23 Pa. C.8. 56113; ii) a private oriminal oomplaint
under 23 pa. C.8. 56113.1; iii) a obarqe of indireot oriminal
oonte.pt under 23 Pa. C.8. 56114, puniabable by impriaonment up
to aix montba and a fine of '100.00-'1,000.00; and iv) civil
oonteapt under 23 Pa. C.8. 56114.1. Reaumption of co-reaidence
on tbe part of tbe plaintiff and defendant aball not nullify the
proviaiona 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 its original expiration date 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.
Temporary custody of DARIEL L. ERICKSON, is hereby awarded
to the plaintiff, JULIE M. ERICKSON,
A hearing shall be held on this matter on the - i ,I day of
Hay, 1996, at ','.'1'. '\ .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.
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JULIE M. ERICKSON,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 96-
CIVIL TERM
DARYL S. BRADY,
Defendant
PROTECTION FROM ABUSE
AND CUSTODY
If 0 TIC II
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.
~.QID
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 tate 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 cut whsre you can get legal help.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
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AMIRICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland county is required
by law to comply with ehe 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,
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JULIE M. ERICKSON,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 96- .1.'1\ CIVIL TERM
DARYL S. BRADY,
Defendant
PROTECTION FROM ABUSE
AND CUS'l'ODY
PITITIOH .OR PROTICTIOH ORDIR
AIfI) CUSTODY
RILIIF UNDIR TBI PROTICTION FROM ABUSE
ACT, 23 P.S. S 6101 et eeq.
A. Hun
1, The plaintiff, JULIE M, ERICKSON, is an adult
individual residing at 156B West Penn Street, carlisle,
Cumberland County, Pennsylvania 17013.
2, The defendant, DARYL S. BRADY, SSN:179-58-9439 and
DOB:1/26/74, is an adult individual residing at 1028 W. Pomfret
Street, Carlisle, Cumberland county, Pennsylvania, 17013.
3. The defendant is tho father of the plaintiff's child,
4, Since approximately 1994, the defendant has attempted
to cause and has intentionally, knowingly, or recklessly caused
bodily injury to the plaintiff, placed the plaintiff in
reasonable fear of imminent serious bodily injury, and knowingly
engaged in a course of conduct or repeatedly committed acts
toward the plaintiff under circumstances which have placed the
plaintiff in reasonable fear of bodily injury. This has
included, but is not limited to, the following specific instanc..
of abuse:
a. On or about April 21, 1996, the defendant followed
the plaintiff into the street, grabbed her by the arm,
turned her around to face him, and grabbed her by the
throat, and choked her, causing her to pass out. When
the plaintiff awoke, the defendant picked the plaintiff
up and carried her into the building where the
plaintiff resides, while she grabbed at the railing and
screamed for help. The defendant, once inside, punched
the plaintiff in the jaw and told her that if she
didn't walk up the stairs, he would drag her up. The
defendant grabbed her and dragged her up the stairs
while she tried to stop the defendant by grabbing the
stair rails. Once inside the plaintiff's apartment,
the defendant shoved the plaintiff in the chest,
knocking her onto the sofa. The defendant covered the
plaintiff's mouth with his hand and dragged her across
the room because the police were knocking on the door.
The police broke the door down and caught the defendant
after he ran from them. The plaintiff suffered
lacerations to hor neck and face, and bruising to her
arm.
b. On or about March 7, 1996, the defendant came to
the plaintiff's residence and when she wouldn't open
the door because she feared for her safety, he hit and
kicked the plaintiff's door, breaking it. The police
were called and the defendant left.
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c, On or about February 1, 1996, the defendant
slapped the plaintiff in the face, grabbed her by the
throat, and choked her. The plaintiff suffered welts
to her face and neck.
d. Approximately once a week, the defendant abuses
the plaintiff in ways including, but not limited to,
the following: choking, punching, slapping, kicking,
and grabbing the plaintiff. The defendant also has
restrained the plaintiff from leaving, and has hidden
phones or broken phones so that she could not call for
help, On once occassion, while the plaintiff was
approximately six months pregnant, the defendant
severely choked her.
5. 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.
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 r.strained
from entering her place of employment or school,
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plaintiff, defendant,
plaintiff's mother'
sister
Addresses
32 s. spring Garden st.
Carlisle, PA
Dates
9/95 - 11/95
plaintiff
156B W. Penn street
Carlisle, PA
11/95 - present
The plaintiff, the mother of the child, is JULIE M.
ERICKSON, currently residing at 156 B W. Penn street, Carlisle,
Cumberland county, Pennsylvania.
She is single,
The plaintiff currently resides with the following persons:
~
DARIEL L, ERICKSON
Relation.biD
daughter
The defendant, the father of the child, is DARYL BRADY,
currently residing at 1028 W. Pomfret street, Carlisle,
Cumberland county, Pennsylvania,
He is single,
14. The plaintiff has not previously participated in any
litigation concerni~g custody of the above mentioned child in
this or any other Court.
15, The plaintiff has no knowledge of any custody
proceedings concerning this child pending before a court in this
or any other jurisdiction.
16, The plaintiff does not know of any person not a party
to this action who has physical custody of the child or claims to
have custody or visitation rights with respect to the child.
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18. The best interests and permanent wo1fare of the minor
child will be met if custody is temporarilY granted to the
plaintiff pending a hearing in this matter for reasons including:
a, The plaintiff is a responsible parent who can best
take care of the minor child and has provided for the
emotional and physical needs of the child since her
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birth,
b. The defendant has shown by his abuse of the
plaintiff that he is not an appropriate role model for
the minor child,
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WHEREFORE, pursuant to the provisions of the "protection
from Abuse Act" of october 7, 1976, 23 p,S. S 6101 rt WlSl., as
amended, the plaintiff prays this Honorable court to grant the
following relief:
A, Grant a Temporary order pursuant to the
"protection from Abuse Aot:"
1. ordering the de~endant to refrain from
abusing the plaintiff or from placing her in fear
of abuse;
2. ordering the defendant to refrain from h~vin9
any direct or indirect contact with the plaintiff
including, but not limited to, tel_phone an4
written communications;
3, ordering the defendant to refrain fr_'
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harassing and stalking the plaintiff .nd I..'
"
harassing the plaintiff'S relativ..'
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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 school.
5. Prohibiting the defendant from removing,
damaging, destroying or selling property owned by
the plaintiff.
6, Ordering the defendant to stay away from the
plaintiff's residence located at 156 B West Penn
street, Carlisle, Cumberland County, Pennsylvania,
7. ordering the defendant to stay away from any
residence the plaintiff may in the future
establish for herself.
8. Ordering the defendant 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,
9, Ordering the defendant to pay reasonable
attorney fees to Legal Services, Inc.
The plaintiff further asks that this Petition be filed and
served without payment of fees and costs by the plaintiff,
pending a further order at the hearing, and that a certified copy
of this Petition and Order be d~livered to the Carlisle Police
Department who has jurisdiction to enforce this Order.
-.II ,
The plaintiff prays for such other relief as may be just and
proper.
COUIIT II
CUITODY UHDBR PBKH8YLVAHIA CUITODY LAW
19. The allegations of Count I above are incorporated
herein as if fully set forth.
20. The best interest and permanent welfare of the minor
child will be served by confirming custody in the plaintiff as
set forth in Paragraph 18 of the Petition,
WHEREFORE, pursuant to 23 P.S, S 5301 ~ ~., and other
applicable rules and law, the plaintiff prays this Honorable
Court to award custody of the minor child to her.
The plaintiff prays for such other relief as may be just and
proper.
Respectfully submitted,
, I
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an carey
Attorney for Pl
LBGAL IB.VIeB.,
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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JULIB"M, -lftfe1l:S0N,
Plaintiff
IN THB COURT OF COMMON PLBAS OF
CUMBBRLAND COUNTY, PBNNSYLVANIA
NO, 96-2275 CIVIL TBRM
PROTBCTION FROM ABUSE
AND CUSTODY
v,
DARYL S, BRADY,
Defendant
Ji'JlQII.C'UO)fJ)l!DI.R
AND NOW, thla __1~_ day of May, 1996, upon consideration of
the Consent Agreement of the parties, the fOllowing Order is
entered:
1, The defendant, DARYL S, BRADY, i. enjoined from
physically abusing the plaintiff, JULIE M. ERICKSON, or from
placing her in fear of abuse,
2. The defendant is enjoined 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.
3. The defendant is ordered to refrain from hara..ing and
stalking the plaintiff and from harassing the plaintiff's
relatives,
4. The defendant is prohibited from entering the
plaintiff's place of employment or school.
5. The defendant is prohibited from removing, damaging,
destroying or selling any property owned by the plaintiff.
6, The defendant is ordered to stay away from the
plaintiff's residence located at 156B Welt Penn Street, C.~li.l.,
or from any residence which she may move to in the futu~., exoept'
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for the purpose of transferring custody during which time the
defendant will remain in his vehicle,
7, The defendant agrees not to remove, damage, destroy, or
sell any property owned by the plaintiff,
8. The defendant is ordered to reimburse the plaintiff's
out-of-pocket losses in the amount of '94.84 listed on the
attached sheet marked Exhibit A. Payment is to be made by the
defendant within thirty days from the entry of the Protection
Order, An award under this chapter shall not constitute a bar to
litigation for civil damages for injuries sustained from the acts
of abuse giving rise to the award or a finding of contempt under
this chapter.
9, The Court costs and fees are waived,
10. This Order shall remain in effect for a period of one
(1) year and can be extended beyond its original expiration date
if the Court finds, that the defendant has committed an act of
abuse or has engaged in a pattern or practice that indicate. ri.k
of harm to the plaintiff on a continued basis. Thi. Order shall
be enforceable in the same manner as the Court'. prior TemporarT
Protection Order entered in this case.
11, This Order may subject the defendant to: i) arre.t
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23 Pa, C,S. 136113.1; Hi) a charge of indirect cri.inal co.t...~ ,,);;;::'\
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under 23 Pa, C.S, 136114, punishable by imprhouent up to .j,~',,' ,::',;Y;;{j,1
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months and a fine of UOO.OO"U,OOO.OO; and tv) civJ,l cODt~"I:;r/J)~~:1
under 2 3 Pa, C, S. 136114, 1. Resumpt ion of co-reBidence _ "t"',! )i\li;~:i!1
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under 23 Pa, C,S. 136113; ii) a private criminal complaint und.r
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part of the plaintiff and defendant shall not nullify the
provisions of the court order,
12, The Carlisle 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 Pa. C.s. 6 6113).
By the Court,
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as to the other parent or which may hamper the free and natural
development of the child's love or respect for the other parent,
By the Court,
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Hel8, JUdge
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JULIE M, ERICKSON,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 96-2275 CIVIL TERM
v,
DARYL S. BRADY,
Defendant
PROTECTION FROM ABUSE
AND CUSTODY
CQ_If~t8Jfr_ .MlliI!IUI.!!Jfl'
Thil3 Agreement is entered on this ___ '_u_ day of May, 1996,
by the plaintiff, JULIE M, ERICKSON, and the defendant, DARYL S.
BRADY, 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, DARYL S, BRADY, agrees to refrain from
abusing the plaintiff, JULIE M. ERICKSON, or from placing her in
fear of abuse,
2, The defendant agrees not to have any direct or indirect
contact with the plaintiff including, but not limited to,
telephone and wr it ten communications, except for the limited
purpose of facilitating custody arrangements.
3, The defendant agrees not to harass and stalk the
plaintiff and harass the plaintiff's relatives.
4, The defendant agrees not to enter the plaintiff'. pllc.
of employment or school.
5, The defendant agrees not to remove, damage, cSe.tr~y, or
sell any property owned by the plaintiff,
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6, The defendant agrees to stay away from the plaintiff's
residence located at 156B West Penn Street, Carlisle, Cumberland
County, Pennsylvania, or any other residence she may move to in
the future, except for the limited purpose of transferring
custody during which time the defendant shall remain in his
vehicle.
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7. The defendant agrees to reimburse the plaintiff's out-
of-pocket losses in the amount of $94.84 listed on the attached
sheet marked Exhibit A, the payment to be made to the plaintiff
within thirty day of the entry of the Protection 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 will be in effect for a period of one (1)
year and can be extended beyond its original expiration date if
the Court finds that the defendant has committed an act of abuse
or has engaged in a pattern or practice that indicates risk of
harm to the plaintiff on a continued basis. The defendant
understands that this Order will be enforceable in the same
manner as the Court's prior Temporary Protection Order entered in
this case.
11. Violation of the Protection Order may subject the
defendant to: i) arrest under 23 Pa, C.S. 86113; ii) a private
criminal complaint under 23 Pa. C,S, 86113.1; iii) a charge of
indirect criminal contempt under 23 Pa, e.s. 86114, puni.hable by
imprisonment up to six months and a fine of '100.00-'1,000.00;
and iv) civil contempt under 23 Pa, C.B, 86114,1,
12, The defendant and the plaintiff agree to the entry of
an Order providing for the following custody schedule for their
child, DARIBL BRICKBON.
a. The mother will have primary physical and legal
custody of the child.
b, The father will have partial custody of the child
every other weekend from Friday at 6:00 p.m. until
Sunday at 6:00 p,m. and any other times which are
mutually agreed upon by the parties.
c, The mother and father agree that each will notify
the other of all medical emergencies which arise while
the child is in that parent's care,
d, The parties realize that their child's well being
is paramount to any differences they might have between
themselves, Therefore, they agree that neither party
will do anything which may estrange the child from the
other parent, or injure the opinion of the child as to
the other parent or which may hamper the free and
natural development of the child's love or re.pect for
the other parent,
WHBRBFORB, the parties request that a Protection Order and
C~8tody Order be entered to reflect the above terms.
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Ju e Eric~~n~t'aintiff
.n.~ll._
t':.fifiradY, Def
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Attorney for Pla tiff
LBGAL SBRVICBS, IIC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
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JUL1K M, EH[CKSON,
, P J III nIl r f
IN 'l'IIL l'llllll'l' 01, l'IIMMoN I'I.E/IS OF
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1'l!MI\I':IH,MI/I l'IIIlN'/'Y, PI:NNSHV/IN'A
n,IRYr. S, HIlAlIY,
De rundnn t
NO, 'Jh,- CIVIl. Ti':HM
9(, -..t~?S
PI{ll'l'I,r'T I I IN I [{OM ^"I1,SI'.
"Nil ,'lIST'lIlY
91!J)I':K fl)1{ COWI'I NlJMWI':
f
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ANn ,NOW, this ,,")ll'f dllY of "IllY, l'I'Il>, upon CllllSfdufLltllln of
the nltllc'hud Motion 1'0,. "llntinUllnl'l', thu mntter sctlellulcil fo\'
IIellring Oil M1IY.1, J'J()h. Ily thi-; ('OUrl',s Ordu, llr April 26, J9<}/l, [,~
herehy reschl'du J ed 1'01' hUllr j 1l11o on
-'L:.t.<2..",III, inCllUrlrolllllNo. 4,
))J(3.'LdH'-';/ '_H. , I CJ <l6 ,
Tllc TClIIl'orll'Y Prof-eel jon Order will remain In efrect fo\' u
pUl'iod or line ye/,r 01' lint II Il finlll Ordur is entllrud in this case.
" certified copy or this Order for Continuance will be
I'rovfdlld to thll C'lIrlisle Policu Departlllent by the plaintiff's
IIltornuy,
By the Court,
~ AIL
KOjA.Hess, Judge
Ilt