HomeMy WebLinkAbout96-04681
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CIIRISTOPIIER CURTIS ZIMMERMAN, IN TIlE COURT OF COMMON PLEAS OF
Plaintifr
I'll[ himsclf and on bchalf of
his minor childrcn Cl 'MIlERLA1\D COt ::"TY, I'ENNSYLV ANIA
AMANDA NICOLE ZIMMER~1A"
and BL:TlI ANN ZIMMERMAN,
v
NO'i()- 4b<i1
CIVIL TERM
LINDA LOU ZIMMERMAN,
Dcfcndant
PROTECTION FR0\1 ABUSE AND CUSTODY
TEMPORARY PROTECTION ORDER
AND NOW, this
"
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day of August, 19%, upon prescntation and eonsidcration
of thc within Pctition, and upon finding that the plaintin: Christopher Curtis Zimmcrman, and thc
partics' minor childrcn, Amanda Nicolc Zimmcrman and Bcth Ann Zimmcrman, currcntly rcsiding
at 122 Big Spring Tcrracc, :-':cwvillc, Cumbcrland County. Pcnnsylvania, arc in immcdiatc and
prcscnt dangcr of abusc from thc dcfcndant. Linda Lou Zimmcrman. the following Tcmporary
Ordcr is entcrcd
Thc dcfcndant, Linda Lou Zimmcrman. (SSN 18J-62-4780)(D()B: 8/09/69), is an adult
individual rcsiding at 122 Big Spring T crracc, Ncwvillc. is prohihited from physically abusing the
plaintifl: Christophcr Curtis Zimmcrman, or thc partics' minor childrcn. or from placing thcm in
fcar of ahusc
The dcfcndant is cxcludcd fhllll thc marital rcsidcncc locatcd at 122 Big Spring Tcrrace.
Ncwvillc. Cumbcrland County. Pcnnsylvania, a rcsidcncc which is owncd by Christophcr Curtis
Zimmerman, with thc lot Icased in both partics' namcs The defcndant is ordcred to stay away
from any residencc the plaintilrmay in the flJlurc establish Ill[ himsclf.
Thc defendant is ordcrcd to rclrain Irom having any dircct or indirect contact with thc
plaintifT or the partics' minor childrcn including. but not limitcd to. telephonc and written
communications,
. .~. _....~.
,-
The defendant is enjoined from harassing and stalking the plaintilT and from harassing his
relatives, or the parties' minor children.
The defendant is enjoined from removing, damaging, destroying or selling any property
owned jointly by the parties or owned by the plaintiff
A violation of this Order may subject the defendant to: i) arrest under 23 Pa.C,S.
1\6113; ii) a private criminal complaint under 23 Pa.C.S.1\6113.1; Hi) a charge of indirect
criminal contempt under 23 Pa.C.S. 1\6114. 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. 1\6114.1.
ResumDtion of co-residence on the Dart of the Dlaintiff and defendant shall not nullifv the
provisions of the court order.
This Order shall remain in effect until modified or terminated by the Court 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 or
the minor children.
Temporary custody of Amanda Nicole Zimmerman and Beth Ann Zimmerman, is hereby
awarded to the plaintiff, Christopher Curtis Zimmerman,
....0
A HEARING SHALL BE HELD ON THIS MATTER ON THE ~7.C,' DAY OF
'''' ' .,
AUGUST, 1996, AT) JUV-M., IN COURTROOM NO...;2, CUMBERLAND COUNTY
COURTHOUSE. CARLISLE. PENNSYLVANIA.
The plaintiff may proceed without pre-payment of fees pending a further order after the
hearing,
The Cumberland County Sheriffs 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 ollice 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.
CHRISTOPHER CURTIS ZIMMERMAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff
for himself and on behalf of
his minor children: CUMBERI.AND COUNTY, PENNSYI.V ANIA
AMANDA NICOLE ZIMMERMAN
and BETH ANN ZIMMERMAN,
v.
NO. 96-
CIVIL TERM
LINDA LOU ZIMMERMAN,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action promptly after this Petition, Order and Notice are served,
by appearing personally or by attorney at the hearing scheduled by the Court and presenting to the
Court your defenses or objections to the claims set forth against you. You are warned that if you
fail to do so the Court may proceed without you, and a judgment may be entered against you by
the Court without further notice for any money claimed in the Petition or for any other claim or
relief requested by the plaintiff. You may lose money or property or other rights important to
you.
FEES 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 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
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 inlormation 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.
'" -...
a) On or about August 14, 1996, the defendant threw a pot of boiling water at
the plaintift'striking him on the leg with the pot and splashing hot water on him.
The plaintifT lell the residence to avoid further abuse and telephoned the police for
help. The Pennsylvania Stale Police arrived, and subsequently, criminal charges
were filed against the defendant. Aller the police left the residence, the defendant
threatened the plaintifT saying, "I'll burn this trailer down with all three of you in
it." The plaintiff, fearing for the safety of the children, took them to his mother's
home where they remain pending the entry ofa Temporary Protection Order.
b) On or about July 21, 1996, the defendant poured ground black pepper into
the mouths of the parties' 4 and 5 year-old daughters because they told the
defendant's parents that she beats them. The children sustained burning and
discomfort inside and outside their mouths as a result of this incident. The incident
was reported to the children's caseworker, Heather Margerum, at County Children
and Youth Services (CCC & YS).
c) On or about June 25, 1996, the <:lefendant kicked the plaintiff as he slept on
the bed. As the plaintiff tried to get ofr of the bed, the defendant struck him over
the head with a glass-plated picture, breaking the glass on his head, and then tried
to punch the plaintiff. When the plaintifr moved aside to avoid being punched by
the defendant, she picked up a large porcelain pumpkin and struck him on the back
of the head, breaking the pumpkin on his head. As the plaintiff faltered and
slumped to the floor, the defendant struck him on the back of his head twice with a
coffee mug. The plaintiff, who has cerebral palsy and is prone to seizures, lost
consciousness and when he regained consciousness did not recognize family
members. The plaintiff sought medical treatment at the Carlisle Hospital for his
injuries. The plaintiff sustained a laceration to the back of his head that required
10 staples to close, soreness and swelling, and headaches as a result of this
incident. When the plaintill'relurned home, the defendant threatened the plaintitl'
saying, "You're lucky I didn't fucking kill you or shove lhcm staples up through
your head."
d) In or about summer, 1992, when the plaintifl' tried 10 tclephone the police,
the defendant grabbed the telephone from him, slammed it down, then struck the
plaintiff on the side of his head with the receiver causing him to fall to the floor.
The plaintiff sought treatment of his injuries at the Carlisle Hospital He sustained
a laceration that required several stitches to close and had headaches as a result of
this incident.
e) On or about June 27, 1991, the defendant threw a large serrated knife at
the plaintiff striking him on the shoulder. The plaintiff sustained a laceration on his
shoulder and still bears the scar.
f) On or about November 18, 1990, the day that the parties' daughter,
Amanda Nicole Zimmerman, was brought home from the hospital after her birth,
the plaintiff reported the defendant to CCC & YS for striking the newborn infant
repeatedly with a kitchen spatula because the child would not stop crying. CCC &
YS has had an ongoing case with the children to the present.
g) Since approximately November, 1990, the defendant has abused the
plaintiff in ways including, but not limited to, pushing, shoving, slapping, and
kicking him about his body. The defendant has kicked the plaintiff in his groin
several times; punched him in the mouth several times causing the plaintiff to have
lacerated lips; choked him leaving red marks on his neck; bit him on the leg, and
has thrown objects at him and used objects to strike him.. The defendant has
repeatedly threatened to kill the plaintift; and recently threatened him saying, "If I
had a gun, I'd blow your head off and your mother's so you couldn't have the kids
and raise them."
h) The defendant has also abused the parties' minor children in ways
including, but not limited 10, slapping and punching them about their heads and
bodies causing bruising and red marks; striking lhe children in their faces causing
them to sustain lacerated lips and bloodied noses;used kitchen utensils, fly swatters
and sticks to strike the children repeatedly about their bodies, often leaving the
imprint of the object on the children. The defendant has grabbed the children by
their hair, yanked them about, and once pulled a hank of hair from Amanda's head.
The defendant regularly used her foot to push the children on their chests causing
them to stumble backward and sometimes fall to the floor. Once the defendant
threw a coffee mug at the children when they were in bed, and during another
incident she threw a pair of scissors at the children. The defendant has punched
the children in their chests, has threatened to break their necks, has drawn back her
fists in a menacing fashion causing them to fear that she intends to strike them, and
has choked the children resulting in red marks on their necks.
5. On or about August 14, 1996, the plaintiff took the parties' minor children to his
mother's home in order to avoid further abuse after the defendant threatened to burn the trailer
down with the plaintiff and the children in it.
6. The plaintiff believes and therefore avers that he and the minor children are in
immediate and present danger of abuse from the defendant should they remain in the home
without the defendant's exclusion and that they are in need of protection from such abuse.
7. The plaintiff desires that lhe defendant be prohibited from having any direct or
indirect cont~ct with the plaintiff or the minor children including, but not limited to, telephone and
written communications.
8. The plaintiff desires that the defendant be enjoined from harassing and stalking the
plaintiff, and from harassing his relatives, or the minor children.
12. The plaintiff desires possession of the mobile home so as to give the greatest
B. EXCLUSIVE POSSESSION
9. The plaintitl'desires that the defendant be enjoined from removing, damaging,
destroying or selling any property owned jointly by the parties or owned by the plaintiff.
10. The mobile home from which the plainlifr is asking the Court to exclude lhe
defendant is owned in the name of Christopher Curtis Zimmerman, and the lot is rented in the
names of both parties.
II . The plaintift' currently has no place to stay with his children except the marital
home, and the defendant has family and friends in the area with whom she can stay.
degree of continuity to the lives of the children.
C. REIMBIJRSEMENT FOR COST OF CASE
13. The plaintiff asks that the defendant be ordered to pay $250.00 to Cumberland
County, one of Legal Services, Inc.'s funding sources for the cost of litigating this case, that the
defendant be assessed the $25.00 surcharge and any court costs if the case goes to hearing.
D. TEMPORARV CUSTODY
14. The plaintiff seeks temporary custody of the following children:
Name
Amanda Nicole Zimmerman
Present Residence
47 Yellow Breeches Road
Mt. Holly Springs, PA
Al!e
5 years old
DOB: November 16, 1990
Beth Ann Zimmerman
47 Yellow Breeches Road
Mt. Holly Springs, PA
4 years old
DOB: May 29, 1992
The children were not born out of wedlock.
The children are temporarily residing with the plaintiff's mother at 47 Yellow Breeches
Road, Ml. Holly Springs, Cumberland County, Pennsylvania, for their own protection and to
avoid further abuse from the defendant.
During the past five years the children have resided with the following persons and at the
following addresses:
16. The plaintift' has no knowledge of any cuslody proceedings concerning these
children pending before a court in this or any other jurisdiction.
17. The plaintiff does not know of any person not a party to this action who has
physical custody of the children or claims to have custody or visitation rights with respect to the
children.
18. The best interests and permanent welfare of the minor children 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 children and who has provided for the emotional and
physical needs of the children since their births.
b. The defendant has shown by her abuse of the plaintiff that
she is not an appropriate role model for the minor children.
c. The defendant's behavior has adversely affected the
children.
WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of October
7, 1976,23 P.S. ~6101 et ~., as amended, the plaintifTprays this Honorable Court 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 and the
minor children and from placing them in fear of abuse;
2. Ordering the defendant to refrain from having any direct or indirect
contact with the plaintiff or the minor children including, but not limited to,
telephone and written communications;
3. Ordering the defendant to refrain from harassing and stalking the
plaintiff and from harassing his relatives and the minor children;
4. Prohibiting the defendant from removing, damaging, destroying or
selling property jointly owned by the parties or owned by the plaintiff;
5. Granting possession of the mobile home located at 122 Big Spring
Terrace, Newville, Cumberland Counly, Pennsylvania, to the plaintift'to the
exclusion of the defendant, and ordering the defendant to stay away from
any residence the plaintiff may establish for himself pcnding a final order in
this matter, and
6. Granting temporary custody of the minor children to the plaintiff
B. Schedule a hearing in accordance with the provisions of the "Protection from
Abuse Act," and, alter 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 and the
minor children and from them in fear of abuse.
2. Ordering the defendant to refrain from having any direct or indirect
contact with the plaintift' or the minor children including, but not limited to,
telephone and written communications.
3. Ordering the defendant to refrain from harassing and stalking the
plaintiff and from harassing his relatives and the minor children.
4. Prohibiting the defendant from removing, damaging, destroying or
selling property jointly owned by the parties or own cd by the plaintiff.
5. Granting possession of the mobile home located at 122 Big Spring
Terrace, Newville, Cumberland County, Pennsylvania, to the plaintift'to the
exclusion of the defendant, and ordering the defendant to stay away from
any residence the plaintiff may establish for himself pending a final order in
this matter.
6. Ordering the defendant to pay $2)0.00 to Cumberland County, onc
of Legal Scrvices, Inc.'s funding sources as reimbursement for the cost of
'"
The above-named plaintiff, Christopher Curtis Zimmerman, verifies that the statements
made in the above Petition are true and correct. The plaintiff understands that false statements
herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to
authorities.
Date:
8-/1 ~ ((;
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SHERIFF'S RETURN - r:CI,ULM:
CASF: NlI: 1')'J"-04561 F
CIJMMIJNWF:AI.TH I)F PI':NNSYLVAN IA:
I;UIJNTY UF CUMHI':HI,ANI>
:l,lMMI':llMAN CIIIlISTUI'IIF:R CUR'll~__
VS.
:I, IMMI':HMAN 1.1 N[IA LOll
I(F;NNF;TH F;, GIJSSERT
.' Sheriff or Deputy Stlerlf! of
CUMBERLAND County, Pennsylvanla, who belng duly Sworn accordlng
to la", says, the "i thln PROTECTION FROM ABUSF:
upon ZIMMF:RMAN LINDA LOU
defendant, at 1715:00 HOURS, on the 21st day of Auoust
1995 at I?? BIG SPRING TI.:r.RACE
was served
the
NF:WV ILLE, PA 17241
, CUMBERLAND
County, Pennsylvania, by handing to ~INDA LOU :l,IMMERMAN
a true and attested copy of the PROTECTION FROM ABUSE
and at the same time directing Her attent~on to the contents thereof.
Sheriff's Costs:
[)ocketing
:";ervice
Affidavit
Surcharge
11:3. 88
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So answers: '/..--:?"
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H. Thomas r.ll.ne. Sherl.fl
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88/88/0808
by
Sworn and subscribed to before me
this J 7 ':". day of Q,.<.o,~1-
r
19 'i r. A. [I,
l'\A{~J 0, ItLd/t't, '-"~-'1 .
~ I Protnono ary
\
LEGAL SERVICES, INC.
a IRVINE ROW
CARUSLE,oPENNSYl.VANIA 17013
(7171 243-9400
Fax (717) 243..9026
Wast Shore 1717) 766-8475
Shlppensburg 1717) 530-5866
:.
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CHRISTOPHER CURTIS ZIMMERMAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff
for himself and on behalf of
his minor children: CUMBERLAND COUNTY, PENNSYLVANIA
AMANDA NICOLE ZIMMERMAN
and BETH ANN ZIMMERMAN,
v. NO. 96-4681 CIVIL TERM
LINDA LOU ZIMMERMAN,
Defendant PROTECT/ON FROM ABlISE AND CUSTODY
~ER FOR CONTlNlJANCE
AND NOW, this ~ day of August, 1996, upon consideration of the attached Motion
for Continuance, the matter scheduled for hearing on August 26, 1996, by this Court's Order of
August 21, 1996, is hereby rescheduled for hearing on October 9, 1996, at 9:30 a.m. in
Courtroom No.3.
The Temporary Protection Order shall remain in efrect for a period of one year or until
further Order of Court
A certified copy of this Order for Continuance will be provided to the Pennsylvania State
Police by the plaintiff's attorney.
By the Court,
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
~}-
Gail Shearer ,~ '\ ,t\ ~
FAMILY LAW CLINIC ,,\'1> )Y"-
Attorney for Defendant
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CHRISTOPHER CURTIS ZIMMERMAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff
for himself and on behalf of
his minor children: CUMBERLAND COUNTY, PENNSYLVANIA
AMANDA NICOLE ZIMMERMAN
and BETH ANN ZIMMERMAN,
v. NO. 96-4681 CIVIL TERM
LINDA LOU ZIMMERMAN,
Defendant PROTECTION FROM ABUSE AND CUSTODY
MOTION FOR CONTINlIANCE
The plaintiff moves the Court for an Order rescheduling the hearing 10 the above-
captioned case on the grounds that:
I. A Temporary Protection Order was issued by this Court on August 21, 1996,
scheduling a hearing for Monday, August 26, 1996, at 3:30 p.m.
2. The Cumberland County Sherift's Department served the defendant with a certified
copy of the Temporary Protection Order and Petition for Protection Order on August 21, 1996,
at 5: I 5 p.m. at 122 Big Spring Terrace, Newville, Cumberland County, Pennsylvania.
3. The defendant has retained Gail Shearer of THE FAMILY LAW CLINIC to
represent her in the matter.
4. By agreement of the parties and their respective counsel, the plaintiffs counsel
files this motion to reschedule the matter.
5. The plaintiff requests that the Temporary Protection Order remain in effect for a
period of one year or until further Order of Court.
6. A certified copy of the Order for Continuance will be delivered to the Pennsylvania
State Police by the attorney for the plaintifl~
WHEREFORE, the plaintiff requests that the Court grant this Motion and reschedule this
matter for hearing, and that the Temporary Protection Order remain in effect for a period of one
year or until further Order of Court.
Respectfully submitted,
IV~
. J ail-Carey, Attorney for P
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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CHRISTOPHER CURTIS ZIMMERMAN, . IN TI IE COURT OF COMMON PLEAS OF
Plaintifl'
for himself and on behalf of . CUMBERLAND COUNTY, PENNSYL VANIA
his minor children.
AMANDA NICOLE ZIMMERMAN, and . CIVIL ACTION - LAW
BETH ANN ZIMMERMAN,
v. . NO. %-4681 CIVIL TERM
LINDA LOU ZIMMERMAN,
Defendant . PROTECTION FROM ABUSE AND CUSTODY
(~PROTECTlON ORDER
AND NOW. this L day of October, 19%, upon
consideration of the Consent
Agreement of the parties, the following Order is entered.
I. The defendant, Linda Lou Zimmerman, is enjoined from physically abusing the
plaintiff, Christopher Curtis Zimmerman, or the minor children, Amanda Nicole Zimmerman and
Beth Ann Zimmerman, or from placing them 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 after the term of supervised visitation
through the Carlisle YWCA's supervised visitation program has been completed.
3. The defendant is ordered to refrain from harassing and stalking the plaintiff and
!Tom harassing the plaintiff's relatives and the minor children.
4. The defendant is prohibited from entering the school or day care facility of the
minor children.
5. The defendant is prohibited from removing, damaging, destroying, or selling any
property owned by the plaintiff or jointly owned by the parties.
6. The defendant is excluded from the plaintiff's residence located at 122 Big Spring
Terrace, Newville, Cumberland County, Pennsylvania, except for the limited purpose of
transferring custody, at which times the defendant will remain in her vehicle, and the defendant
agrees to stay away from any residence thc plaintiff may in the Iii lure establish for himself; excepl
tor the limited purpose of transferring custody, at which timcs the delendant will remain in her
vehicle.
7. Court costs and fees are waived.
8. This Ordcr shall rcmain in eflcct for a period of one ([) year and can be extended
beyond that time if the Court finds that thc defendant has committed an act of abuse or has
engaged in a pattern or practice that indicates risk of harm to the plaintiff or the minor children.
This Order shall be enforceable in lhe same manner as the Court's prior Temporary Protection
Order entered in this case.
9. This Order may subject the defendant to: i) arrest under 23 PaC.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, 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. ~6114.1.
10. The Pennsylvania State Police and the Carlisle Police Department shall be provided
with certified copies of this Order by the plaintiffs attorney and may enforce this Order by arrest
for indirect criminal contempt without warrant upon probable cause thai 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 delendant shall be taken wilhout unnecessary
delay before the court that issued the order. When that court is unavailable, the defendant shall be
taken before the appropriate dislrictjustice. (23 Pa.C.S. ~61IJ).
gc
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
Stephen A. Metz, Ccrtified Legal'ntern
FAMILV LAW CLINIC
Gail R. Shearer, Attorney f(lr Defendant
CHRISTOPHER CURTIS ZIMMERMAN, . IN THE COURT OF COMMON PLEAS OF
Plaintitl'
for himself and on behalf of . CUMBERLAND COUNTY, PENNSYL VANIA
his minor children.
AMANDA NICOLE ZIMMERMAN, and . CIVIL ACTION - LAW
BETH ANN ZIMMERMAN,
v. . NO. 96-4681 CIVIL TERM
LINDA LOU ZIMMERMAN,
Defendant . PROTECTION FROM ABUSE AND CUSTODY
~ CUSTODY ORDER
AND NOW, this I (day of October, 1996, upon consideration of the parties' Consent
Agreement, the following Order is entered with regard to custody of the parties' children, Amanda
I. The parties shall share legal custody of the children.
Nicole Zimmerman and Linda Lou Zimmerman.
2. The plaintift; hereinalter referred to as the father, shall have primary physical
custody of the children.
3. The defendant, hereinaller referred to as the mother, shall have supervised visits
with the children at the Carlisle YWCA through the agency's supervised visitation program one
hour each week for a period of two months.. The mother shall be responsible for any costs for
supervised visits. During the period of supervised visitation at the YWCA, the mother agrees to
participate in and successfully complete a parenting skills class mutually approved by the parties
and their respective counsel.
4. The mother shall remain in individual counseling with her therapist at the Helen
Stevens Mental Health Center, and shall follow her therapist's recommendations.
5. Conditioned on completing the supervised visils through lhe YWCA's program
including the counseling and parenting classes, the mother shall have supervised visits with the
children in the presence of her friend, Thura Taylor, as follows: two successive Sundays from
2:00 p.m. until 4:00 p.m.; two successive Sundays from noon to 4:00 p.m.; two successive
Sundays from noon until 6:00 p.m. Ms. Taylor shall provide transportation during periods of
supervised visits.
6. After the above periods of supervised visitation are completed, and prior to
engaging in unsupervised visits with the children, the mother's therapist at Helen Stevens Mental
Health Center shall provide written documentation confirming the mother's stability.
7. Unsupervised visitation shall commence on two successive Sundays from 10:00
a.m. until 6:00 p.m. and thereafter alternating the following periods of custody: on week one from
Saturday at 5:00 p.m. until Sunday at 5:00 p.m., and on week two from Sunday at 10:00 a.m.
until 6:00 p.rn. The mother shall provide transportation through a third party who is mutually
agreed upon by the parties.
8. The mother and father shall notity the other of all medical care the children receive
while in that parent's care. Each parent shall notity the other immediately of medical emergencies
which arise while the children are in that parent's care.
9. Neither party shall do anything which may estrange the children from the other
parent, or injure the opinion of the children as to the other parent or which may hamper the free
and natural development of the children's love or respect for the other parent.
10. This Order shall remain in effect until further Order of Court.
By the Court,
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
.., -'.'
Stephen A. Metz, Certified Legal Intern
FAMILY LAW CLINIC
Gail R. Shearer, Attomey for Defendant
:_'.1" ..,J
CHRISTOPHER CURTIS ZIMMERMAN, . IN TilE COURT OF COMMON PLEAS OF
PlaintilJ'
for himself and on behalfof . CUMBER1.AND COUNTY, PENNSYLVANIA
his minor children.
AMANDA NICOLE ZIMMERMAN, and . CIVIL ACTION -1.AW
BETH ANN ZIMMERMAN,
v. . NO. 96-4681 CIVIL TERM
LINDA LOU ZIMMERMAN,
Defendant . PROTECTION FROM ABUSE AND CUSTODY
CONSENT AGREEMENT
This Agreement is entered on this 1'1--- day of October, 1996, by the plaintiff,
Christopher Curtis Zimmerman, and the defendant. Linda Lou Zimmerman. The plaintiff is
represented by Joan Carey of LEGAL SERVICES, INC.; the defendant is represented by Stephen
A. Metz, Certified Legal Intern, and Gail Shearer, Attorney at Law, of the I' AMIL Y LAW
CLINIC. The parties agree that the following may be entered as an Order of Court.
I. The defendant, Linda Lou Zimmerman, agrees to refrain from abusing the plaintiff,
Christopher Curtis Zimmerman, and the parties' minor children, Amanda Nicole Zimmerman and
Beth Ann Zimmerman, and from placing them 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 written communications, except for the limited
purpose of facilitating custody arrangements after the term of supervised visitation through the
Carlisle YWCA's supervised visitation program has been completed.
3. The defendant agrees not to harass and stalk the plaintiff and not to harass the
plaintiffs relatives and the minor children.
4. The defendant agrees not to enter the school or day care facility of the minor
children.
5. The defendant agrees not to remove, damage, destroy, or sell any property owned
by the plaintiff or jointly owned by the parties.
6. The defendant agrees to stay away from the plaintiffs residence located at 122 Big
Spring Terrace, Newville, Cumberland County, Pennsylvania, except for the limited purpose of
transferring custody, at which times the defendant will remain in her vehicle, and the defendant
agrees to stay away from any residence the plaintift' may in the fLlture establish for himself, except
for the limited purpose of transferring custody, at which times the defendant will remain in her
vehicle.
7. The defendant, although entering into this Agreement, does not admit the
allegations made in the Petition.
8. The defendant understands that the Protection Order entered in this matter will be
in effect for a period of one (I) year and can be extended beyond that time 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 or the minor children. 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.
9. Violation of the Protection Order may subject the defendant to: i) arrest under 23
Pa.C.S. ~61 13; 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, 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. *61 14.1.
10. The defendant and the plaintift' agree to the entry of an Order providing for the
following custody schedule for their children, Amanda Nicole Zimmerman and Beth Ann
Zimmerman.
a) The parties will share legal custody of the children.
b) The father will have primary physical custody of the children.
c) The mother will have supervised visits with the children at the Carlisle
YWCA through the agency's supervised visitation program one hour each week
for a period of two months. The mother will be responsible for any costs for
supervised visits. During the period of supervised visitation at the YWCA, the
mother agrees to participate in and successfully complete a parenting skills class
mutually approved by the parties and their respective counsel.
d) The mother agrees to remain in individual counseling with her therapist at
the Helen Stevens Mental Health Center, and to follow her therapist's
recommendations.
e) Conditioned on completing the supervised visits through the YWCA's
program including the counseling and parenting classes, the mother will have
supervised visits with the children in the presence of her friend, Thura Taylor, as
follows: two successive Sundays from 2:00 p.m. until 4:00 p.m.; two successive
Sundays from noon to 4:00 p.rn.; two successive Sundays from noon until 6:00
p.m. Ms. Taylor will provide transportation during periods of supervised visits.
f) After the above periods of supervised visitation are completed, and prior to
engaging in unsupervised visits with the children, the mother agrees that her
therapist at Helen Stevens Mental Health Center will provide written
documentation confirming the mother's stability.
g) Unsupervised visitation will commence on two successive Sundays from
10:00 a.m. until 6:00 p.m. and therealter alternating the following periods of
custody: on week one from Saturday at 5:00 p.m. until Sunday at 5:00 p.m., and
on week two from Sunday at 10:00 a.rn. until 6:00 p.m. The mother will provide
transportation through a third party who is mutually agreed upon by the parties.
h) The mother and father agree that each will notifY the other of all medical
care the children receive while in that parent's care. Each parent will notifY the
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OFFICE OF THE DISTRICT ATTORNEY
OF CUMBERLAND COUNTY
ON E COURTHOUSE SQUARE
CARLI.5LE. PEfmSYLVANIA 17013
APk 11l1~:JJ:pV
CHRISTOPHER C. ZIMMERMAN, :
Plaintift'
for himself and on hehalf of
his minor children:
AMANDA NICOLE ZIMMERMAN:
and BETH ANN ZIMMERMAN
v.
LINDA LOU ZIMMERMAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: 96-4681 CIVIL
CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this 18th day of April, 1997, this Court certifies that thc attached
complaint has been propcrly completed and verified, and there is probable cause for the
issuance of process. In consideration of the attachcd Commonwealth's Petition, the
defendant, LINDA LOU ZIMMERMAN, is directed to appear for trial on the charge of
., !1"
^ Indirect Criminal Contempt before the Court on the;LS' day of : I f~JI , 1997 at
L" ,
I ~o'c1ock .l.m. in Courtroom II ~ t of the Cumberland County Courthouse, Carlisle,
Pennsylvania.
The defendant has a right to be represented by an attorney. If the defendant
cannot afford an attorney, upon requcst one will be assigned to represent the defendant. If
the defendant wishes assignment of counsel, contact should be made prior to trial with the
Cumberland County Public Defcnder's Oflicc at 717-240-6285. Further, if the defendant
fails to appear, an arrest warrant will be issucd.
The Sheriff of Cumberland County is dircctcd to servc this Ordcr and Pctition
upon the defendant. The assessment of costs to be determincd by the Trial Judge
subsequent to trial.
Michael S. Schwoyer
Chief Deputy District Attorney
LINDA LOU ZIMMERMAN
1.
CHRISTOPHER C. ZIMMERMAN,
Plaintiff
for himself and on behalf of
his minor children:
AMANDA NICOLE ZIMMERMAN
and BETH ANN ZIMMERMAN
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
: 9fi-46X I CIVIL
LINDA LOU ZIMMERMAN,
Defendant
CHARGE: INDIRECT CRIMINAL CONTEMPT
COMMONWEALTH'S PETITION FOR A HEARING ON CHARGES
OF INDIRECT CRIMINAL CONTEMPT
Michael S. Sehwoyer. Chief Deputy District Attorney of Cumberland County,
Pennsylvania, brings the following Pel it ion for a hearing on charges of Indirecl Criminal Contempt:
I. A Protcction from Abuse Order was issued by the Court. A tme and correct copy of
the Order is attached.
2. The defendant's violation of this Order is averred in the attached private complaint.
3. The victim requests the filing of an Indirect Criminal Contempt Charge upon
information received.
4. The District Attorney's Office approves the filing of this privale complaint.
5. The Commonwealth is requesting a hearing on the charges of Indirect Criminal
Contempt pursuant to 23 Pa.C.S.A. * 6113.
6. The plaintiff and the defendanl seek modification of the Ordcr based on the filing of this
petition as the Court deems appropriate following the trial in addition to any other sentence. 23
Pa.C.S.A. *6113.
WHEREFORE, the Common\\ealth requests the defendant be commanded to appear
before thc Court on the charge of Indireel Criminal Contempt.
ichae S. Schwoy
Chicf D pnty Districl Attorney
CRIMINAL COMPLAINT (PRIVATE) . COMPLAINT NUMBER YEAR TYPE NUMBER
CURT OF ClM-01 PLEAS OF Complaint Numbers il Other Participants
Cl.tIBERI.PND COOITY - " INDIRECT CRIMINAL CONTEMPT
..-t. h. .'~
, ..!,.,'
A 59317 INCIDENT NUMBER UCR NO. om
DEFENDANT
COMMONWEALTH OF PENNSYLVANIA
VS.
J.
QIRISTOfHfR rums ZI~MIRMAN Cl'J BHL\LF OF illS
MI.NtJK UIIUJ (NUII/I'llfAlfilJlII)
AMANDA NICIlIY. ZIH11~
NAME J.lNIJA 1 (XJ ZI~~n'RH,~
AND
ADDRESS
17(1: Clrrstmm Rend, S'h 1 ppcllsburg
(717) '132-:\722
of
(ldt'mi(1' OI.'ptJfIJJJI'lIIllf 1lJ:l'II(I" rt'f(('.\I'I/II'd /llId jlo/iIh'IlI.\/If'lhl'l\i/lll)
122 Big Spring Terrace, Newille, PA 17241
do hereby state:
(I) [XI I accuse the above named defendallt, who lives at the address set forth above or,
_ 0 I accuse an individual whose name is unknown to me bUl who is described as
~
..,
..
o
."
e-
1l:
o
-'<
~
<5
~
!XJB:
55 #:
R/'J/m
IS'>-62-47i{)
o his nickname or popular designation is unknown to me and, thercfo.re. 1 have ~csi~natcd. him herein a~ Jo~n
Doc: with vialatillJ( the penal law.s. Qf the Commonwealth of Pellnsylval11a at 122 Big Spnng Termee, N,,;vtlle
and 175H vtrstown J<mc1, :-:ihJ_P!XJlsh.lrg (P/a(j"Pdlili((/fSllhdil'i,\iol/)
in Cumberland / Franklin County on or about Anril 12 or 11. 1997
Participants were (iftherr In'f(' (lI1rticipanls, placr Ihdr f/tJII/C,\ hCft', rl'pt'tllill/: 11/1' /Wlllt'oj 1l1)(JI'('dt:(t'l/dll!lI):
(2)
The acts committed by the accused were: 0 DID VIQATE A PROTECfICl'l FRill, JlBU5E OlDER DATED:
O:tober 15, 1996
AT IXXJ<ET NLMBER: 'Xr-46RI
IN THAT THE DEFENDMT DID THE FCl.L<MING ACTS IN
VIQATICli Cf THE OlDER:
Q, the "eekend of April 12 and 13, 1997 the rrdnor ehLldren ilrrrlllda Nicole and Eeth Ann Zirmcnmn
were to go to their rmthcr, Lindn lJ:lll 7.irmenmn, for their first unsupervised visitation. Linda I.DU
arrived at 122 Big Spring Terrace at 5 p,m. on Satllnlny, April 12, 1997 to pick up the d1ildren, She
got out of her car ,me! \\'ent to the door of the residence. "hen Christopher ZiITJTet1TE.ll opened the door to let
the children go alt I Linda proceeded to walk inside the residalce. 'Ihis act is .in vi.olation of the protectio
order doted O:tober 15, 1996, Civil #9fr4J8I, clallse ff6 "hlch excludes lhe defendant fran the residence
except for the limited purpose of transferring clIstexly at v.hich the she is to rarr-li.n in her vehi.cle.
all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of Assembly,
or in violation of and of thc Act of
or the
(1'lllilimIS/lh.diriJior/)
(3) I ask that a warrant of arrest or a summons be isslIed and that the accused be required to answer the charges
I have made.
(Scction)
i Ordinance or
(SlIh-,\t'Cfirlll)
~
/(/
19jj_
true and correct to the best of my knowledge or information
penalties of SectiOl 4904 of thc Crimes Code (IX Pa. C. S.
f)(/
1-), ,A
. ,~'
(,I,.. 11IIIIfI'lIf{'omfll'JI'IIIJ11I)
(4)
I verify that the facts set forth in this eompl,lint arc
and bclicf. This verification is made subject to the
~ 4904) relating to unsworn falsification to authorities,
AND NOW. on this date . 19 _, I cl.:rtify thc complaint has hccn properly complctl.:d and
verified. and that there is probable cause for issuance of proccss,
(SEAL)
(,\fIl~i\I,'rl'lf !li1tril'1)
(f.\.IIIil/J: A/llh",ilr)
AorC411-BG
CHRISTOPHER CURTIS ZIMMERMAN, . IN THE COURT OF COMMON PLEAS OF
Plaintiff
for himself and on behalf of . CUMBERLAND COUNTY, PENNSYL VANIA
his minor children.
AMANDA NICOLE ZIMMERMAN, and . CIVIL ACTION - LAW
BETH ANN ZIMMERMAN,
v. . NO. 96-4681 CIVIL TERM
LINDA LOU ZIMMERMAN,
Defendant . PROTECTION FROM ABUSE AND CUSTODY
(~PROTECTION ORDER
AND NOW, this L day of October, 1996, upon
consideration of the Consent
Agreement of the parties, the following Order is entered.
The defendant, Linda Lou Zimmerman, is enjoined from physically abusing the
plaintiff, Christopher Curtis Zimmerman, or the minor children, Amanda Nicole Zimmerman and
Beth Ann Zimmerman, or from placing them 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, excepl for the
limited purpose of facilitating custody arrangements after the term of supervised visitation
through the Carlisle YWCA's supervised visitation program has been completed.
3. The defendant is ordered to refrain from harassing and stalking the plaintiff and
from harassing the plaintiff's relatives and the minor children.
4. The defendant is prohibited from entering the school or day care facility of lhe
minor children.
5. The defendant is prohibited from removing, damaging, destroying, or selling any
property owned by the plaintiff or jointly owned by the parties.
6. The defendant is excluded from the plaintifl's residence located al 122 Big Spring
Terrace, Newville, Cumberland County, Pennsylvania, cxcept for the limited purpose of
transferring custody, at which times the defendant will remain in her vehicle, and the defcndant
agrees to stay away from any residence the plaintifr may in the future establish for himself, except
for the limited purpose of transferring cuslody, at which times the defendant will remain in her
vehicle
7. Court costs and fees are waived.
8. This Order shall remain in eftect for a period of one (I) year and can be extended
beyond that time 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 or the minor children.
This Order shall be enforceable in the same manner as the Court's prior Temporary Protection
Order entered in this case.
i
I
I
1
I
I
:1
I
9 This Order may subject the defendant to: i) arrest under 23 Pa.C.S. ~6113; ii) a
private criminal complaint under 23 PaC.S. ~6113.1; iii) a charge of indirect criminal contempt
under 23 Pa.C.S. ~6114, 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. ~6 f 14. I.
10. The Pennsylvania State Police and the Carlisle Police Department shall be provided
with certified copies of this Order by the plaintitrs 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
.i
event that an arrest is made under this section, the defendant shall be taken withou. unnecessary
delay before the COl'rt that issued the order. When that court is unavailable, the defendant shall be
taken before the appropriate district justice. (23 Pa.C.S. ~61 13).
Joan Carey
LEGAL SERVICES, INC.
Attorney for PlaIntiff
Stephen A. Metz, Certified Legal Intern
FAMILY LAW CLINIC
Gail R. Shearer, Attorney for Defendant
, .
5 Conditioned on completing the supervised visits through the YWCA's program
including the counseling and parenting classes, the mothcr shall have supervised visits with the
children in the presence of her friend, Thura Taylor, as follows: two successive Sundays from
2:00 p.m. until 4:00 p.m.; two successive Sundays from noon to 4:00 p.rn.; two successive
Sundays from noon until 6:00 p.m. Ms. Taylor shall provide transpOr1ation during periods of
supervised visits.
6. After the above periods of supervised visitation are completed, and prior to
engaging in unsupervised visits with the children, the mother's therapist at Helen Stevens Mental
Health Center shall provide written documentation confirming the mother's stability.
7 Unsupervised visitation shall commence on two successive Sundays from 10:00
a.m. until 6:00 p.m. and thereafter alternating the following periods of custody: on week one from
Saturday at 5:00 p.m. until Sunday at 5:00 p.m., and on week two from Sunday at 10:00 a.m.
until 600 p.m. The mother shall provide transportation through a third party who is mutually
agreed upon by the parties.
8 The mother and father shall notifY the other of all medical care the children receive
while in that parent'; care. Each parent shall notifY the other immediately of medical emergen~jes
which arise while the children are in that parent's care.
9. Neither party shall do anything which may estrange thc children from the other
parent, or injure the opinion of the children as to the other parent or which may hamper the free
and natural development of thc children's love or respect for the other parent.
CHRISTOPHER CURTIS ZIMMERMAN, . IN THE COURT OF COMMON PLEAS OF
Plaintifl'
for himself and on bchalf of . CUMBERLAND COUNTY, PENNSYLV ANIA
his minor children
AMANDA NICOLE ZIMMERMAN, and CIVIL ACTION - LAW
BETH ANN ZIMMERMAN.
v. . NO. 96-4681 CIVIL TERM
LINDA LOU ZIMMERMAN,
Dcfendant . PROTECTION FROM ABUSE AND CUSTODY
CONSENT AGREEMENT
This Agreement is entered on this _1'1-- day of October, 1996, by thc plaintiff,
Cl1:istopher Curtis Zimmerman, and the defendant, Linda Lou Zimmerman. The plaintiff is
represented by Joan Carey of LEGAL SERVICES, INC.; the defendant is represented by Stephcn
A. Metz, Certified Legal Intern, and Gail Shearer, Attorney at Law, of the FAMILY LAW
CLINIC The parties agree that the following may be entered as an Order of Court.
I. The defendant, Linda Lou Zimmcrman, agrees to refrain from abusing thc plaintiff,
Christopher Curtis Zimmcrman, and the partie,' minor children, Amanda Niwle Zimmerman and
Beth Ann Zimmerman, and from placing them 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 written communications, except for the limited
purpose of facilitating custody arrangements altcr the term of supervised visitation through the
Carlisle YWCA's supervised visitation program has been completed
3. The defendant agrces not to harass and stalk the plaintiff and not to harass the
plaintill's relatives and the minor children
4. The defendant agrecs not to enter the school or day care facility of the minor
childrcn
5. Thc defendant agrees nol to remove, damage. dcstroy, or sell any property owned
by the plaintilr or jointly owncd by the partics
6. The delcndant agrees to stay away from the plaintiffs residence localed at 122 Big
Spring Terrace, Newville, Cumbcrland County, Pennsylvania, except for thc limitcd purposc of
transferring custody, at which times the delcndanl will remain in her vehicle, and the defendant
agrees to stay away Irom any residcnce thc plaintifl'may in the future establish for himself; except
for the limited purposc of transferring custody, at which times the defendant will remain in hcr
vehicle
7. The defendant, although entering into this Agreement, does not admit the
allegations made in thc Petition
8. The defendant undcrstands that the Protection Order entered in this matter will be
in effect for a period of ope (I) year and can be extended beyond that time if the Court finds that
lhe defendant has committtd an act of abuse or has engaged in a pattern or practice tha! indicatcs
risk of harm to the plaintifl' or the minor children. The defendant understands that this Order will
be enforceable in the same manner as the Court's prior Temporary Protectio., Order entercd in
this case.
9. Violation of the Protection Order may subject the defenda~t to: i) arrest under n
Pa.C.S. 96113; ii) a private criminal complaint under 23 Pa.C.S. 96113.1; iii) a charge ofindirec.
criminal contempt under 23 Pa.C.S 96114, punishable by imprisonment up to six months and a
fineof$100.00-$1,000.OO; and iv) civil contempt under 23 Pa.C.S. 96114.1.
10. The defendant and th~ plaintiff agree to the entry of an Order providing for thc
following custody schedule for their children, Amanda Nicole Zimmerman and Beth Ann
Zimmerman.
a) The parties will share legal custody of the children
b) The father will have primary physical custody of the children
c) Thc mother will have supervised visits with the children at the Carlisl'~
YWCA through the agency's supervised visitation program one hour each weck
for a period of two months. The mother will be responsible for any costs for
supervised visits. During the period of superviscd visitation at thc YWCA, the
mother agrees to participatc in and successfully complete a parenting skills class
mutually approved by the partics and their respective counsel.
d) The mothcr agrees to remain in individual counseling with her therapist at
the Helen Stevens Mental Health Center, and to follow her therapist's
recommendations.
e) Conditioned on completing the supervised visits ~hrough the YWCA's
program including the counseling and parenting classes, the mother will havc
supervised vi-its wi!h the children in the presence of her friend, Thura Taylor, as
follows: two ~uccessive Sundays from 2:00 p.m. until 4:00 p.m.; two su,cessive
Sundays from noon to 4:00 p.m.; two succcssive Sundays from noon ur,til 6:00
p.m. Ms. Taylor will provide transportation during periods of supervised visits.
f) After the above periods of supervised visitation are completed, and prior :0
engaging in unsuptrvised visits with the children, the mcther R!;reeS tnat her
therapist at Helen Stevens Mental Health Center will provide written
documentation confirming thc mother's stability.
g) Unsupervised visitation will commence on two successive Sundays from
10:00 a.m until 6:00 [l.m and therealter alternating the following p~riods of
custody: on week one from Saturday at 5:00 p.m. until Sunday at 5:00 p.m., and
on week two from Sunday at 10:00 a.m. until 6:00 p.m. The mother wi!! provide
transportation through a third party who is mutually agreed upon by the parties
h) The Inotller alld fathcr agree that each will notify the oth~r of all medical
care thc children rcccive whilc in that parent's care. Each parent will notify thc
SHERIFF'S OFFICE
157 LINCOLN WAY EAST. CHAMIJEHSIJIJI1G. I'LNNSYL VANIA II/III ,II /i .'It I :\flll
SHERIFF SERVICE
PROCESS RECEIPT, and AFFIDAVIT OF RETURN
PLAINTIFF/ S/
IN~; I Hue IION~i' Of! ~-;f HVI(:I or 1'!lOrl 'i', 1'111.1'... IYPlllH jJJlll1
\I!f)lllly 00 lUll dolal.lI dl\~ (,I'P'lP'
.' 1,I)lJHI rjli','l1l H
Christopher
3. DEFENDANTI $1
c. Zimmerman
')(,-Id,HI CIVIL
.\ 1'(j'l (Jf ',<,'1111 ()f\c;oMI', Alrl!
IN!lI!lECT C!lIMINAI. CIIIITEMI'T
SERVE
Linda Lou Zimmerman
{ ~J NAM[ OF INDIVHJUAL CUMf'MJY COIlI'()IlAllfHl I It
Linda Lou Zimmerman
G. ADDRESS (Street or HFD. Apdrlrll/.'1l1 No City. IlwIJ Iwp. Sldlt' dill I /11' C"d"1
_AT 1768 Orrstown Road, Shippcnsburg, I'A 17257
7. INDICATE UNUSUAL SERVICE [] COMMON Of' PA [JLPUllLr OTHErl
Now,_,. 19,1. SHERIFF OF FRM\IKLlN COUNTY, PA. do 11nr(~lJy rJ!~pllIIJ(! tllf~ Shorllf of
County 10 oxeclJle tillS Will ilnd rnilku f(lItO" ItH)I(!O! iu;cordlllq
to law. Thts deputation being made a11fle request find nst<; of the pl,wlllff
6. SPECIAL INSTRUCTIONS OR OTHER INFORMATION THAT WILL ASSIST IN EXPEOITING SERVICE
I() ',I liVl1 I 1 )Ij lit '.r 11II'll' If) III I'IIL II II!r, I', III 1 f '/11 II Allf\r.11I11 roll ',11111
.
NOTe-ONLy'-APPLlCABLE ON WRIT OF EXECUTION: N.S. WAIVER OF WATCHMAN ~ ^ny Ill'J>lll'1 ',tn'nl! II'V'{III'IIIIIiII) <II dll,II:111I1l1 .111'1 111"111'11'1 IHuh!!
within writ may leavE'! same Without <1 watct1l1liHl, In custody of wtl()llH~Vl'r I', liHHld 11111I1',',I',,',UIII ,111"[ 11,)lilYI'lrllil".,I'fl "I 10,.'1 IH ,111.ll:IIIfIf'111 Wlltl/lllt 11.1111111'1 IHI
!_~~_p~.~_9L~u"c:h deputy orlhe stlenll to any pl'lInllff ht~fI~ln for ,lily 1(1',', dn';!lucllfHl or It '!lII)'/dl 01 01111' '>il! tl pll 'p' 'ily l'l,l, 'f" '.1 1I ,till " '..lit! 1111"1 '1)1
9. SIGNATURE 01 ATTORNEY or other ORIGINATOR II) 11.11 f'II(HlI tjlJMl1f 11 11 IJ^ II
Cumberland County District Attorney
12:-'Se."NIfNOTICEOF SERVICE COpy TO NAME AND ADDRESS BELOW: (ThIS mC!n mllst be cornplehHll1 nolle(! is to he IlHUlml)
Cumberland County Sheriff, R. Thomas Kline,
____~1Le_ Courthouse_ Square, Carlisle, I'A 17013
SPACE BELOW FOR USE OF SHERIFF ONL Y - DO NOT WRITE BELOW THIS LINE
ll.I.<.aC.k.'~;;-~ICdg.e.'~~cel~~;-I'thO Will} ; Y~GNATU jlf)\IJll1rHl/hj rFCSO [)~'IHJll ()I (:II'lk .I'll! ItI~f 11 ll.I!I' 11..' "IVl.,j I', l'II",III')llltl'dllllllll.llt!
~r"_c~~plalnl ~~ Indlcate(j nbovc. I'\.JJ::+- I... ~!.~ 1.-25-97 1.-25-97
16. I heroby CERTIFY ilnc! RETURN IIwl r. c;A've per~nJ1dll'l <;erVf!d lldV+' 1..qOlI "'.nli'II'" IJI ',1'1\11' ,. .I'. ',1,,,,',11 HI 11.'11..11\.', II,h" 1"I'llIit'.j .I', "I"IWIIIII
"Remarks.. Ihe Wflt or complaint descnhc(1 nn tile mr!lVldll;jl. C()t!lp.HI', "llll"I,]111111 f'll ,It !I,I' .1'11111' ,t, ,','.11 ,iI"'i!' '.. IIII Itl" Ilnllvl,!!t.11 Illtllll,I!IY,
~o!~.~ralion, etc, ill tho address IllSI'rt/)d billow by tldnrllinq d TRUE ;lIld ATTESTED COPY 1111'1",,1
17 ~Llll1~r!!~y_cc.r~IIY_ilnd return a NOT FOUND IH~C;lIh(> t 0111I1111;1111.> 1<) Ifll_.1I" t1w Illlli'Jlilildl. . !'II'I'.III'/ I "11",1,11,,,11 ,I, ,jiJlt,d ,1I111\f1' I~,tl!, 10'111.111<', tll'ItIW)
18. Name and litle 01 rndlvidlJillscrved (If not ~;hnwn above!) 1'1
'I ,.,
Linda Lou Zimmerman
20. Address of where sp./ved (compl(~tt! only II dllh'fl;I)1 tll,ll\ :,II1)',\'1 I .tIIlIV' 'I I: ;11' '1'11 il ! ii, I J, ill",llttlll 'I 01 !j"
Cily, Bora. Twp Slate and ZIJl Code)
Same as number 6.
I lId,..!'""" :':' 1111)0'
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M.I
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23 ATTEMPTS 1 Date Miles ; Dcp. In!. OOlle Miles Ocp.lnl Dale Miles Or!p_Inl. Dale
14-25, 30 V-4
:. ,
24. Advance Costs i?':l Sr,rvlCl: Co<,,~; ;'() ~JlII.LlY (;t 'It " r.\d",llll' lOr PIJ',1.ul"
.'
18.00 4.00 8.40
30. REMARKS:
Mltl~S Dl!p. Inl
Dilte MII(!s
Dop. tnl.
,'II 1,,!.L1(,II.I<,
:''l C:tI~;1 11tH OllllUUtm
J() ,I,()
30,1,() DUE
~:;.;:',":""'''e'' ,,::",
~y COMMISSIOLrris~U";7.;", ;'If~J. ~~
38:.1 A.~CK. NDWLE.'OGE IlEtUP] 01'1.0. .~i(,.s!ffill!llt lllMlii:IGf A TUIII: I
. OF AVTHOIlIZED ISS~IN;' Wl>,l5<f~g0',:f"'Il.~1 i unly I
, "',' ,'j'T":"i.'t.:,n E,'" Ires Nov. 4. 2000
rcso 11'% -. ..' ..
,./ SOANSWEIl ~
. /J. /i ",-t:., .,~..<~-
TIIEOIlO!lE I.. KONCS)1.
1,-2H-97
~;IH IWI or rllAtJKllN C()tH~ I Y
.or ,"
SHERIFFIS OFFICE
SHERIFF SERVICE
PROCESS RECEIPT, and AFFIDAVIT OF RETURN
1. PLAINTIFFI SI--- __n
157 LINCOLN WAY EAST. CHAMBERSBURG, PENI'<SYLVANIA 17201 (71/1 :'(; 1.:JII/I
I
'1 INSTRUCTIONS Fon SEHVICE 01- tJHOCLSS !llflol',fl I'/I'll 01 prllll
legibly. 00 not detach any COplOS
I
2 COUHT NUMBI II
!-=\.trl.o;>tL>ph,:r C. ZLi,;";". ).'
3. DEFENDANTiSI--"---~'--
i.Lldd :"'(,)\.1 i:L:':Cl"]!I:I;,
. '", ,,;,J! i j':',
14 TYPE OF WfllT Oil COM!'I AIN I
,
i i '.!'i\ il
SERVE
..
{ 5 NAMEOFINDIVIDUALCOMPANY CORf'()HAr~ON tel(, ro~;lnvICEOnU~SO\II"ION(Jf f'ftfJl'IHIV 10m tIVIIIJ,^,rAUlIlll)jI',lllIJ
Lindd L.1Y. Zilll..J"t...,I'\
6 ADDRESS (Street or RFO. Apilrtment No Clly Boro, Twp.. Stale and ZIP Coth!)
AT ~,_!..X_!)_i.J_~r2.'~:~Y~!,_;l_F\1 d, D,":, "II, .',\ 1 1/
7. INDICATE UNUSUAL SERVICE: IJ COMMON OF PA.II DEPUTIZE' : OTHER
Now._-===~.:.: -.. '19' ,I. SHERIFF OF FRANKLIN COUNTY, PA. eJo l",rollY (l"pIIII/" Ih" SluJllII 01
County to execute this Writ and lTIilko rnltJlrl tl1f!fool accordlll(l
to law. This deputation being made at the request and risk 01 the plainli".
B. SPEelALINSTRlicTIONSClR ClTHER INFORMATION THAT Will. ASSIST IN EXPEDITING SERVICE:
"""","''''',
'''''.''
NOTE ONLY APPLICABLE ON WRIT OF EXECUT1(jN:"N.B".' WAIVER OF WATCHMAN - AllY dnpllly ',liprl!! 1t'....YIIIII UPUtll1l ,11I,Ktlltlq ,illY pllJpl!fty wI/1m
within writ may lealle same without a walch man, in custody of whomeller islollnd In POSSC!.SIOrl, .Ifll'r rllltllYI,\il ~Jt'I','Hl 11111!vy !l/ ,11';u tlrrl!lrl', wllllI~llt 1I,IIJllllY IHI
the part 01 such deputy or the sherifllo any plaintil'- herein for.any .t.o?s,. deslrucho_n or removal 01 aflY ~,11Ch prll!ll'r1y t II!II Ull ',11111111 ~, ',,1111 llillrllo!
9. SIGNATURE of ATTORNEV or other ORIGINATClR---H. -. .. 1110 TUfYHONI tlIJMBl1l ill IIAII
Cumberld;tu COU,lt:v District Att()!T.,.:j :
"' .. .-- --.-- ... -. '
12. SEND NOTICE OF SERVICE COPY TO NAME AND-ADORESS BEL(jW; (This area must bo comploled II notice I" 10 ho mullod)
Ct1mb~rlanddCoutltj 51u.:cif [. R. ;:'~10',:1;1~;: ~" . .a:,
One Courthouse S(JU~lrt.:. C:\rli~;l~J:G._J:2.:_~JJ..-.____,_._
SPACE BELOW FOR USE OF SHERIFF ONLY - DO NOT WRITE BELOW THIS LINE
13. I acknowledge receipt of the writ} J )IGNAT~:.I."Au~ori-zedFC.SO. [)eptily'orClerk ilntl Tlllo : 1.1 I ),llp 1.II!UIIVlIIl \1/) l.plr'IIiIJtlIHllilm~\1 rl~llo
or complaint as indicated above. /5..{J.~. --.--------.&V;::::i.-t.-r :, ..... 'j" I:, -- :'.J -) /
16. I hereby CERTIFY and ~ETURN that I ' ve personally served. [] halle leg~1 eVldenco or snrvlco d', ',IIOWII In "flpmark',. ~ : Ildllfl nwcIllml as !;tlown In
"Remarks., the writ or complaint descri ed on the IndiVIdual. company, corpOlilllon, (!Ie, ill Ihl! dddrf!~,:, ',liflWIl dIIOVl! Of WI HIll IlHhwh'dl. company,
corporation, etc., at the address inserted below ~J han.9~]_.'-!_!.~_':J~and ~TTESTEO COPY 1t1(!H'ol
17.0 I hereby certify and return a NOT FOUND because I am unable to locate IIw IndlVl(lual, Corllp.UIY. O)/lIm ltlflfl l'tt. rl,Ullod dlJnvn, U",O rotllarks be_lOW)
18. Name and title of indillidual served or nOlshown above) .... ----. \tJ ^ I"""'" "I '.",1"1",, "'1" .""101,',, ,,,I,,,,, It",,,
"..",."" ",\10,. 01.01"',,1."'1', """"\1'1,,,.,,,,,
Linda Lou ZiIi'.;>l.~r;T1;)d ,I,,,j.,
20. Address of where served (compleie only-i'f diffcrenl-ii{im stlOwn .:lhovcI (Streal or IIH). AfldllllllUl1 No
City, 80ro, Twp. State and Zip Code)
Dille I
I
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Mdl'dllf'(
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l'll..l.lql'
i.' I 11,IIH 1,1 ~;"I""IU'
,
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I Milos lOop.
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nTlIllfJ
nM
PM
E51
mS1
~;Iil,~ --:l.G nlm.t>e r 6.
1 : 1 IIt~;
23. ATTEMPTS :~:.s L~I~s e~'~.'~.'~'..~.t...I.-'.'D.-'ai-C 'j Miles loep.,nti
24. Advance Cosls --- L5. ~':~'~~ :0515. \ 20 Nol.IIY C;",,'
30. REMARKS:
Milos
Dop. In!.! Dltlo
In'. I
l'o!alCosls
Onlo I Milos I D.p. itii:'-
[20. COST DUE OR REFUNP-
30.1,0 DUE
.-.._.--_...-_.~-
31. AFFIRMED and subscribed to bofore 11\0 tillS
34. day of _------11.PRL1_'----,_
1 ~}
I
11."'"1'''''''''
jl>.,1' '.1.",.'1
1"""'1",'1"",.".,,,.,,'1
SO ANSWEn.
., .'
:();.
J30,110
I~ - :W-~.)7
360,,10
37._.._____ .___ -.
p",tt,,,nnl,,,~ 1"'I""vN"',,,~ I
MY COMMISSION EXPIRES
38. I ACKNOWLEOGE-FfECElPfCiFTHE SHERIFF'S RETURN SIGNATURE
OF AUTHORIZEO ISSUING AUT.~.QBITY ANO TITL[
SIIERIFF OF FRANKLIN COUNTY
I ~!I.D..;~nf.:~~~~~_,
FCSO.llI!16
CHRISTOPHER C. ZIMMERMAN,: IN THE COURT OF COMMON PI.EAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
for himself and on behalf
his minor children:
AMANDA NICOLE ZIMMERMAN:
and BETH ANN ZIMMERMAN
V. : 96-4681 CIVIL
LINDA LOU ZIMMERMAN,
Defendant
CHARGE: INDIRECT CRIMINAL CONTEMPT
IN RE: CONSENT TO MODIFICATION OF CUSTODY ORDER DATED
OCTOBER 15, 1996
1
I
1
.1 2.
,
I
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,
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3.
I. The Defendant, Linda Lou Zimmerman, shall have superviscd visits with the children
at the Carlisle YWCA through the agency's supervised visitation program one hour
each week, said visits shall be scheduled at the convenience of the parties and the
YWCA of Carlisle. Said visits shall continue until further Order of Court or
agreement of the parties. The Defendant may seek modification of this Order after
two (2) months. The Defendant shall be responsible for any costs for supervised visits.
The Plaintiff shall be responsible for transporting the children to the YWCA of Carlisle
for the purpose of these supervised visits.
The Defendant shall begin and remain in individual counseling with a therapist at thc
Helen Stevens Mental Health Center, and to follow the therapist's recommendations.
The individual counseling shall include at a minimum, dircct observations of the
Defendant with the children for thc purpose of assessing the Defcndant's ability to
employ any skills or techniques she has bcen taught.
The Defendant shall maintain follow-up appointments, as may be necessary, with hcr
family physician for monitoring of her anti-depressant medication.
4. The Defendant agrees to modify the Custody Order entered on October 15, 1996, in
accordance with the paragraphs above.
/61 I
--VA~ g~ /9'/
Attorney for Defendant '/
_oj) ('0 I _)/ /7 c) ,~.
CliLlJ(hi .' r/!/ /, / I L~l" ("It)
j{filloa Lou Zimmer an, Defendant
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