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Home My WebLink About96-05895 1{966l SZ IJa~ . '- : SWJ.L YNN3d 'ellf198:)1NVH~" OYOCI 111H ONUllOdS H.1I109 ~ MV1 J.Y Il013SNOOO ONV A3NllOUV H:>V8 'W S3WVr " '- &&~.L&L <L u) (717) 737.203~. ,< . JAMES M. BACH ATTORNEY AND COUNSELOR AT LAW 352 SOUTH SPORTING HILL ROAD MECHANICSBURG, PENNA 17055 " VB. IIN THE COURT OF COMMON PLEAS OF ICUMBERLAND COUNTY, PENNSYLVANIA I NO. 'iI., 'J \ 'II G....J 0~ I CIVIL ACTION PAULA H. STAHL, PETITIONER EUGENE T. RICHARDS, RESPONDENT I PROTECTION FROM ABUSE AND NOW, TEMPORARY PROTE~VE ~day of ~.I.,.1 ORDER this 1996, upon presentation and consideration of the within petition and upon finding that the said Petitioner, PAULA H. STAHL, is in immediate and present danger of abuse from Respondent, EUGENE T. RICHARDS, the following Temporary Protective Order is entered: 1. Respondent, is hereby prohibited from abusing, harassing, or threatening Petitioner, PAULA H. STAHL, either physically or verbally, wherever she may be, 2. Respondent is evicted and excluded from the residence known as 2101 Lambs Gap Road, Enola, Cumberland County, Pennsylvania, and any residence which petitioner may choose to establish, 3. Petitioner, PAULA H. STAHL, is granted primary physical custody of TAYLOR P. RICHARDS, born on December 26, 1991. 4. Respondent, is hereb}' prohibited from abusing, harassing, or threatening Petitioner's family and/or friends either physically or verbally, wherever they may be. minor child, TAYLOR Domestic Relations 0 P. RICHARDS, mmediately. The s directed to hold a hearing to review of the parties, Direct payments to the will be made until the Domestic Relations Order is Hshar! \.' 6. The Hampden Township Police Department will be provided a copy of this order by the attorney for the Petitioner, and is directed to 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, 7. Respondent is prohibited from stalking Petitioner as that term is defined in the Crimes Code, 18 Pa. C,S. section 2709. B. Respondent is directed to relinquish immediately any firearms or weapons he may own, possess, or control, to the Cumberland County Sheriff upon being served herewith, and be prohibited from acquiring any other firearms or weapons throughout the duration of this Order. Any police department having appropriate jurisdiction is notified that, pursuant to Section 10(c) of the Protection from Abuse Act (Act of October 1, 1976, P.L, 1090, No. 218 35 P.S, ~101B1, et ~., as amended, by Act of June 23, 1978, P.L, No. 81) in the process of enforcing this Court's Order, "(aln arrest for violation of an order issued pursuant to this act may be without warrant upon probable cause whether or not the violation is committed in the presence of the police officer." Further, ae provided in Section 10(d) of the Act, "(slubsequent to an arrest the defendant shall be taken without unnecessary delay before the court that issued the order. When that court is unavailable, the defendant shall be arraigned before a district just\~~. . in accordance with the Rules of Criminal Procedure." VB. .IN THE COURT OF COMMON PLEAS .CUMBERLAND COUNTY, PENNSYLVANIA . .NO. PAULA H. STAHL PETITIONER EUGENE T. RICHARDS , RESPONDENT ,CIVIL ACTION-LAW .PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE AND FOR SPECIAL RELIEF TO THE HONORABLE, THE JUDGES OF THE SAID COURT: The Petition of PAULA H. STAHL, by her attorney, JAMES M. BACH, ESQUIRE, pursuant to the Protection From Abuse Act, 23 Pa. C.S. Sections 6101, et seQ" as amended, respectfully represents as follows: 1. Petitioner is an adult individual presently residing at: 2101 Lambs Gap Road, Enola, Cumberland County, Pennsylvania or at an undisclosed address for their protection, hereinafter referred to as "residence." 2. Respondent is an adult individual residing at: 2101 Lambs Gap Road, Enola, Cumberland County, Pennsylvania. 3. petitioner and Respondent are not husband and wife, but lived together since early 1991, 4. The petitioner is the owner, in her own name of the residence known as 2101 Lambs Gap Road, Enola, Cumberland County, Pennsylvania, 5. The Petitioner and Respondent are the natural parents of one minor child, namely Taylor p, Richards, born December 26, 1991 and residing with the parties. 6. Respondent has engaged in abusive conduct toward Petitioner as such conduct is defined in the Act. Examples include, but are not limited to, the following: On a regular basis violently cursing and swearing, destroying furniture, grabbing my upper arms and shaking me violently, threatening to burn down house and kill everyone inside, threatening to kill me, screaming, pushing and ehoving. His behavior is becoming more violent with each outburst and each and every time he threatens to burn my house down and kill everyone in it. 7. As a consequence of the above, petitioner is afraid of Respondent and believes that she is in immediate and present danger of further abuse and harassment from him, Further, petitioner is in need of, is entitled to, and desires protection from such abuse. S. Petitioner, who has been the child's primary caretaker since his birth, believes that it is in the child's best interest and welfare that she be granted primary physical custody of him at this time. 9. petitioner requires child support in the minimum amount of $100.00 per week for her son, Taylor p, Richards, 10. The petitioner avers the facts are more than sufficient to meet the requirements of exclusive possession, since she is the legal and sole owner of the property, and the parties are not married. 11. Petitioner earns in excess of $300,00 per week, 12, Respondent earns in excess of $400.00 per week, WHEREFORE, pursuant to the Protection From Abuse Act, Petitioner prays your Honorable Court ~o: 2 I. Immediately enter a temporary order, and after hearing, a final order; A. Directing Respondent to refrain from approaching, abusing, harassing, or threatening petitioner, either physically or verbally, wherever she may be; B. Evicting Respondent from 2101 Lambs Gap Road, Enola, Cumberland County, Pennsylvania, placing such residence in the exclusive possession and control of the Petitioner; C, Excluding Respondent from Petitioner's current residence and any residence which she or the minor child may occupy while this Order remains in effect; D. Prohibiting Respondent from having any contact with Petitioner, including telephone or otherwise, except through her attorney; E. Prohibiting Respondent from stalking Petitioner as that term is defined in the Crimes Code, 18 Pa. C,S, section 2709; F. Directing Respondent to refrain from harassing communication with Petitioner's relatives and or friends wherever they may be. G. Directing Respondent to relinquish immediately any firearms or weapons he may own, possess, or control, to the Cumberland County Sheriff upun being served herewith, and be prohibited from acquiring any other firearms or weapons throughout the duration of this Order. H. Grant primary physical custody of Taylor P. Richards born on December 26, 1991 to his natural mother, Paula H. Stahl, I. Direct Eugene T, Richards to pay directly to Paula H. Stahl the sum of $100,00 per week for the support of his son, Taylor P. Richards born on December 26, 1991, petitioner shall 3 ~r ~ >- .:r ~ P: L." .' 'f" ...' N ',~ UI!-! \-) -d " ()i. . .. , r, --:-. ft" (:- - 9r- ts"l -it) ..s ,j ~' C'~ '? j } , , '- c.:!," to- ",) L' "::1- 1": c:. , IL "" C) 0 <.1\ v. : : : : I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PAULA H. STAHL, Petitioner EUGENE T. RICHARDS, Respondent NO. 96-5895 CIVIL TERM ORDER OF COURT AND NOW, this '1rlJ day of November, 1996, the parties in the above action having failed to appear for the hearing scheduled for November 7, 1996, the Petition for Protection from Abuee and for Special Relief is hereby DISMISSED, and the Temporary Protective Order dated October 29, 1996, is hereby VACATED. A COPY of this order shall be provided by Petitioner's counsel to any police department which wae served with the initial Temporary Protective Order. BY THE COURT, J. Jamee M. Bach, Eeq. 352 S. Sporting Hill Road Mechaniceburg, PA 17055 Attorney for Petitioner Eugene T. Richards 2101 Lambs Gap Road Enola, PA 17025 Respondent, Pro Se c .,..,..:....vr>.....~..4A. III ff/ ft" 4 ...,I. iJ'. ( I \ , . ( , 'I -1"';\ ., , , r, : j ~l) I'. i I : i:9 ':'.1 i(f, -, , ::] , .,~ , ,< ....., - ,,' .. . . '.11 :'1 ,"- ., - :rc , ,,~~- ~ (") '':":. ~~ lJ. L '0 i.r:. 'l-t; LLl-" , ')-" c....J ". ~ -.' :";l. If~ 0-, "~2 ~t ,0 ' f.n I::' I ',z 1.~ ..-, U:" : ::.~" , '~(n ,:'':'! '1::.J- f':' ~.:.: ~5 ,.. ,0 0 a' u