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Home My WebLink About96-04574 -~ ;. < ~. 'to LEGAL SERVICES, INC. B IRVINE ROW CARUSLE, PENNSYLVANIA 17013 (717) 243-9400 Fax (717) 243-0026 West Shore (7171 766-8476 Shlppen,burg (717) 63G-5866 " .' rJJ{ : " " GWEN ELAINE GLASSER. Plaintitr IN TilE COURT OF COMMON PLEAS OF v CUMBERLAND COUNTY. PENNSYLVANIA NO, %- -'--I--57'f CIVIL TERM MARC ANTIIONY THOMAS-GLASSER. Defendant PROTECTION FROM ABUSE TEMPORARY PROTECTION ORDER AN9"NOW, this '~ay of August, 1996, upon presentation and consideration of the within Petition, and upon finding that the plaintiff, Gwen Elaine Glasser, now residing at 120 Linden Drive. Apt. I A, Camp Hill, Cumberland County, Pennsylvania, is in immediate and present danger of abuse from the defendant, her minor son, Marc Anthony Thomas Glasser, the following Temporary Order is entered, The defendant, Marc Anthony Thomas-Glasser, (SSN: 097-64-4746}(DOB: 11119/80), is a 15 year old minor temporarily residing at 9 William Pcnn Drive, Camp Hill, Cumberland County, Pennsylvania, is hcreby cnjoincd from physically abusing the plaintiff, Gwen Elaine Glasser, or from placing hcr in fcar of abuse. The defendant is cnjoincd from harassing and stalking the plaintiff and from harassing hcr relatives. The defendant is enjoincd from removing. damaging, dcstroying or selling any property owncd by the plaintiff A violation of this Order may subject the defendant to: i) arrest under 23 Pa.C.S. ~6113; ii) a private criminal complaint under 23 Pa.C.S. ~6113.1; iii) a charge of indirect criminal contempt under 23 Pa.C.S. ~6114, puuishable by imprisonment up to six months and a fine of $100.00-$1,000.00; and iv) civil coutempt under 23 Pa.C.S. ~6114.1. c_ Resumntion of co-residence on the nart of the plaintiff and defendant shall not nnllifv the provisions of the court order. ~6113). FOR JUVENILE DEFENDANTS: This Order shall remain in cllcct until modified or terminated by the Court and can be extended beyond its original expiration date if the Court tinds that the defendant has committed an act of abuse or has engaged in a pattern or practice that indicates risk of harm to the plaintitr A HEARING SHALL BE HELl) ON HilS MATTER ON TIn: ..;lJ/,ri DAY OF AUGUST, 1996, ATr:'/$ II.M., IN COURTROOM NO..i:, CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA. The plaintiff may proceed without pre-payment of fees pending a further oruer after the hearing. The Cumberland County Sherift's Department shall attempt to make servIce at the plaintiffs 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 otlice 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 Lower Allen Township Police Department shall be provided with a certified copy of this Order by the plaintiffs 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 Pa.C.S. In the event that an arrest is made, the arresting officer shall file a complaint with the JUVENILE COURT. The provisions relating to detention shall be addressed to the on- duty probation officer, and the matter shall be scheduled promptly for processing, adjudication and disposition with the judge scheduled to deal with juvenile matters. By the Court. l tJ 4,,, Joan Carey LEGAL SERVICES, INC. Attorney for Plaintiff GWEN ELAINE GLASSER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO, 96- 4.5"7'-1 CIVIL TERM MARC ANTHONY THOMAS-GLASSER, Defendant PROTECTION FROM ABUSE PETITION FOR PROTECTION ORDER RELIEF UNDER THE PROTECTION FROM ABUSE ACT, 23 Pa.C.S. ~6101 et seq. A. ABUSE 1. The plaintiff, Gwen Glasser, an adult individual residing at ] 20 Linden Drive, Apt. ]A, Camp Hill, Cumberland County, Pennsylvania 17011. 2. The defendant, Marc Anthony Thomas-Glasser, (SSN: 097-64-4746)(DOB: ] 1/]9/80), is a 15 year old minor temporarily residing at 9 William Penn Drive, Camp Hill, Cumberland County, Pennsylvania, ] 70 1 ]. 3. The defendant is the minor son of the plaintiff 4. Since approximately the summer, ] 995, 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 under circumstances which have placed the plaintiff reasonable fear of bodily injury. This has included, but is not limited to, the following specific instances of abuse: a) On or about August 9, 1996, the defendant threatened the plaintiff saying, "If you get me in trouble, \'11 fucking kill you." The plaintiff, fearing for her safety, contactcd Holy Spirit Mental Health Unit and the dcfendant was involuntarily committed, but released later the same day. b) On or about August 7, 1996, the defendant attempted to kick the plaintiff and when she grabbed his leg to stop him, the defendant said, "That's okay, mom. I have another leg." and kicked the plaintifl'in the abdomen causing her to fall backward over the coffee table. The plaintifl' telephoned the police, and later the same day went to the emergency room of Harrisburg Hospital for treatment of her injuries. The plaintiff sustained bruising and soreness about her leg and a contusion to her abdominal wall as a result of this incident. c) On or about July 3D, 1996, the defendant pushed the plaintiff in the presence of a State Constable, d) In or about the summer, 1995, the defendant threatened to stab the plaintiff in her sleep, pushed and shoved her about causing her to fall to the floor, and tried to pin her to the floor. The plaintifl' got away from the defendant and telephoned the police for help. The plaintiff sustained sorzness and brush burns about her knees as a result of this incident. e) Since approximately the summer, 1995. the defendant has pushed and shoved the plaintiff about at least once a month causing her to fall against walls, and sometimes to fall to the floor. In addition, the defendant threatens to harm the plaintiff on a daily basis saying, "I'm gonna kick your ass," and "I'm gonna knock you on your ass." The plaintiff fears for her safety. 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 enjoined from harassing and stalking the plaintiff, and from harassing her relatives 7. The plaintiff desires that the defendant be enjoined from removing, damaging, destroying or selling any property owned by the plaintiff, B. REIMBlJRSEMENT FOR COST OF CASE 8. The plaintitl' asks that the defendant be ordered to pay $25000 to Cumberland County, one of Legal Services, Inc.'s funding sources as reimbursement lor the cost of litigating this case. and that the defendant be assessed the $25.00 surcharge and any court costs if the case goes to hearing. WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of October 7, 1976.23 P.S. ~6101 m ~" as amended, the plaintiff prays this Honorable COUlt to grant the following relief: A, Grant a Temporary Order pursuant to the "Protection from Abuse Act:" I. Ordering the defendant to refrain from abusing the plaintiff or from placing her in fear of abuse; 2. Ordering the defendant to refrain from han.ssing and stalking the plaintiff and from harassing her relatives, and 3, Prohibiting the defendant from removing, damaging, destroying or selling property owned by the plaintiff 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: I. Ordering the defendant to refrain from abusing the plaintiff or from placing her in fear of abuse. 2. Ordering the defendant to refrain from harassing and stalking the plaintiff and from harassing her relatives. 3, Prohibiting the defendant from removing, damaging, destroying or selling property owned by the plaintiff 4. Ordering the defendant to pay $25000 to Cumberland County, one of Legal Services, Inc.'s funding sources as reimbursement for the cost of The above-named plaintiff, Gwen Elaine Glasser, verities 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. *4904 relating to unsworn falsitication to authorities. Datej1~. /~ /996 ~/~JJ~ Gwen Elaine Glasser, Plaintiff ~t , c.: j:.: ll, ~- '-.)1" . [tC': cr.. , ~; ~iL.' fE'!,. ~; h. () ,<, l.~) G', ,~() 0" .- . ."j . -' :::'~ .....,; :,;'j :,) ,<::; ':rj -0_ c.- ',J Ij (' '-J <() '"I) "~ ! V :j . J cD , GWEN ELAINE GLASSER, Plaintifl. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA v :'-JO 96-4574 CIVIL TERM MARC ANTIIONY TIIOMAS-GLASSER, Dcfendant PROTECTION FROM ABUSE MOTION FOR CONTINlIANCE Thc plaintifl' movcs thc Court for an Order continuing gcnerally the hearing in the above- captioncd casc on the grounds that: I. A Tcmporary Protcction Ordcr was issucd by this Court on August 15, 1996, scheduling a hcaring for Thursday, August 22. 1996, at 845 a.m. 2. Thc Cumbcrland County Sherill's Dcpartmcnt scrvcd the dcfcndant, thc plaintiff's 15 ycar-old minor son, with a ccrtificd copy of thc Tcmporary Protcction Order and Petition for Protcction Order on August 15, 1996. at approximately 5:00 p.m., at 9 William Penn Drive in Camp Hill. Pennsylvania. 3. On August 15. 1996. Legal Serviccs, Inc. staff contact cd Daniel J. Sodus of SODUS & VERNEY and requcstcd that hc scrve as thc minor dcfendant's guardian ad litcm in thc abovc-captioncd matt cr. Mr. Sodus agrccd to reprcsent thc defendant, and was provided with a ccrtil1cd copy of thc Tcmporary Protcction Order and Pctition for Protcction Ordcr on that datc. Thc defcndant contactcd Mr. Sodus al1cr he was scrvcd with thc Tcmporary Protcction Ordcr and Pctition for Protcction Ordcr and agrccd to Mr. Sodus acting on his behalf 4. By agrccmcnt of thc partics and thcir respective counsel. the plaintil1's counsel l1Ies this motion for general continuance to afl'ord the parties time to executc a Consent Agrcement in the matter. 5. Thc plaintitl' rcqucsts that thc Tcmporary Protcction Ordcr rcmain in cffect for a pcriod of one ycar or until further Ordcr of Court. 6. A certil1cd copy of the Ordcr for Continuancc will bc dclivered to thc Lower Allen Township Police Dcpartment by thc attorney for thc plaintiff'. WHEREFORE, thc plaintiff requcsts that the Court grant this Motion and continuc this matter gcnerally, and that thc Tcmporary Protection Order rcmain in effcct for a pcriod of one year or until further Order of Court. Rcspectfully submitted, t //-1 ('-,'L.....J ~c<.._(_ I an'Carey. Attorney for PI - LEGAL SERVICES. INC. 8 Irvinc Row Carlisle, PA 17013 (717) 243-9400 ., '''-.' ." (~) f:-', l. J L..!.J ~ c; (j , fl: " , .1 q ("..)1 '. :) i~ l~J .. C." IT: s: !", ~t ~)- ,. ~- ... 'J ) l...; C" C, GWEN ELAINE GLASSER, Plaintiff v. MARC ANTHONY THOMAS-GLASSER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 96-4574 CIVIL TERM PROTECTION FROM ABUSE AND NOW, this ORDER OF COURT \~1~ay of August, 1996, upon relation of Legal Services that Daniel J. Sodus, Esq., has expressed a willingness to serve pro bono as guardian ad litem for the minor Defendant in the above-captioned matter, Daniel J. Sodus, Esq., is appointed guardian ad litem for the Defendant. Joan Carey, Esq. Legal Services, Inc. a Irvine Row Carlisle, PA 17013 Attorney for Plaintiff Daniel J. Sodus, Esq. 7 Irvine Row Carlisle, PA 17013 Guardian ad litem for Defendant Marc Anthony Thomas-Glasser 9 William Penn Drive Camp Hill, PA 17011 Defendant :rc C'i:'':'''''' r"'-"J.:",- ,J/lo}%. . '\), /-'> BY THE COURT, ,r, ?~' . f5'~ r> !::;.~ .::) :.J ''-'' "J , ., (~: ; 1,. ,"- ~. ;) 'J . J ;1 . ; ,::~? - ,'(!1 }o '_5.::;] -.=f) ;.,''1 .-:; ~i)' -" C.-,