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HomeMy WebLinkAbout96-06853 ~,'""ii; f : ;_,:i' Ii ,,/ ).!i'-~ t,r',','1 'I. ,. j:",:Ii' I", :"i}'" ','i ,I , ~- I. I I l',11J ,. fl" " '.' '" l ~ - .: ., \J ,; .. Iilo5 , ~ i ,I 'I, .. ., '. . , " " I ,I,' ,'j,l; i'.l!,,> I ;'il .\ '.1' .":""1 ", )r,I' tl'l, ,'" Ii 'JAi, ,'I ,I"~ " "I , ii, " \-1, ,.1, <,! " I,; ., L': ','" " CERTU'ICATION OF PFA CONTEMPT ClIse Number fib -ftJ85'3 ~ 7lr", NlIme ~ i>. ~I 11L- /6/ ,04.4.- Irry ~;IL I'A 170m , Victim's Name: q()~~,~ BlIlance Due: $118. Jf5 170 Stllte Surchllrge 171 Stllte Fine ADD DELETE $ $ IS IS IS S7. '10 IS $ 10,00 IS $ 15.00 S 260 Sheriff Cost ($1.50 . any addtl) 207 District Attorney 204 C~urt Costs (Clerk of Court) 502 Restitution NlIme -P..~'A- (J#~L Address $ if 5. SO $ City Stllte Zip Name $ $ Address City - Zip Stllte Name Address City State ~ip prothonotary Office Person CertifYJ.ng Infol'mation rt~..'4.cd- a. )V'~ Date _3.-/J-'17 . u3,IO/Y7 IO:O~ fAX 717 7U1 ij~ijU COMMONWEAl. TH OF I'ENNSYl.Y ANlA COUNTY OF, cumerland POLICE CRIMINAL COMPLAINT II J CLlME~'1 1....t.1 Ol.trl...-. 09-3-02 111,1.. M.I.. _,HIn Helen a, SflllUMlERl:lI,J{ COMMONWEALTll OF l'ENNBYLV ANIA VB. 27 W, Big Spring Ave. Newville, I'A 17241 DEFENDANT: N~MI InQ ADDRESS r 'ItJCOdore Paul 0ClRlXll 151 Palm City Annville,I'A 17001 717-838-0554 L. 01.....' (717) 776-3187 ~... N., ate Filed: TN: - ] . IllOiii-TiY It..- 073-G4-0944 I, Drlwr', ~h... SlOtt PA 23305436 .0'11/... ....efa'U 1- H2-92S401 260 Diltriet Attorney's OaIce IX1 Approved n DIsapproved because: j1llt "'....1., "_ _ ...p1'l'15. tIw CIIIplllnt,"vI.. _ oflfd...h, ... _ bllIllft'o'IId lIl' lilt lnonwy lor 1111 ~LtI1 trior '0 III" .....,0'-', 107., -u&it GI' All""" nr . _un. pt... PMI"If or T~) uupnn 01' A"arN'f.rar ......_\111) (lMUJ ~ Tor _ Michael R. RIm <_ of ~Hfllll..l_ ',Int tit' l)Ile) of-f4"i~e. ~~i~~ "'_ollod..a Political ~v1ilcnl do h.reby 1t&18:(check the appropriate bO%) J. IllI 1 accu.. the abOV'lWIled defendant, who livea.t the .ddJ'lle& lit forth above [J IlICCUIt an defendant whOle 1I&IIl. Ls Wlknown to me but who Ia described 811 [J laceu.e the d.r.ndant wholllWlle and popular deslpatlon or nlckiwDe ill \IlIkllownto me and whom 1 ban thenfore dulpated u John Doe with -.lolatinr tb, ptnallawa of the Commonwealth of PBIlIIIYIVIlIlia at 10e Greason Rd. am 12 West Ma1n st., West Pennsboro 'I\Ip. 1I'1__I'llL hl..l UolIv1If1n1 In n_....laW1 COUD~ononbout 03/08/97 at 0330hrs Partldpantawen: (IftheJ'll wen partil:ipanll. place their names here, J'IIpeatiDgthe name of the abov. del.lIelantl ~..... Paul ITQTYN ~~1000 (I'll,.. ~ lJIl rubor) ~49 ( ,.. ""IUIW/I.D,' (O'I~ C81li.-*>-((Ql' I. Th. &$ colDlDitt.d hv the uCUHd were: (lilt _ I _ of IN In IUffl.'"" '0 lIIM.. lilt _ of lilt """" of lilt ~ d1orv!d. A oJtoe'", eo lIlI ....... In~IJ vlolllal lII11lou1 fin, Is nlt ..",,<1..... In I....,.,..., ~... eltl tIw .-cille Idlcn ord aDoctl'" of lIlI.ll1Me or ordt..... .n.... .,0111*1.' 'DIE IEFENCll\NT did violAte the order iNUed under the Protection Fran Alule Act F.R. 1992-512 dated 06/04/92, by the Q:IUxt of 0:mtDn Pleas of ClJmbe.rland O:lunty. n1e P,F.A. No. 96-6853 civil Tenn was issued by the Hcnorahls Kev1n A. HESS an 12/23/96. laC 41a-c4/lltlU_ IWIt.., 1,8 iJJOUI ., ..J 03110/V7 10:02 .',\X 717 Tel 8~80 D J CL~nN'l' r.tJ0Q2 - CConltDuetlon oU.) I--N- - Ooll aaml1 Docbt N\lQl.ber: POLlCE CRIMINAL COMPLAINT . aD oIwblch we.. qaIut tIut plleellld d1pIty 01 thl Com.monwtalth of PlQIQqlftllla 8lIll c:omuy Ul thl Ad ofAutm~. aria YIoIttIoIa of 1.6113 of ,h. J:R 1 1I...lon) e.......ltlon) e,. ".....e) (....U) 2. ., CIl. (IK,f.,,) (Iub-a.cllon) e'A I'.t....) e....u) ], of tIl. nK.lon) e.....I...I.,,) CPA IIltute) (oaunt.) 4. of the c..nlon) 1I...,...t.,,) (PA I..rutl) (CCUlh) 8. I uII that e wanut of arrelt or alUlDlDom bllasued and that thl cltlelldant be r~quind to r.nawer the cbaqw I have made. a.. ordtrtbra WUftIIt of_m..... the.- L nl' dlldnIt oIprtl1U1e ca_ __.. aapIiIUd ... __ tIII...1ha IanIIIlt aadllIIl~_ 4. I veri(y that tIut faellHt forth III thIa complaint r.nJ lnI, aDd cornet to the bllt 01 my Iulowl.clp or illformation w btUff. TbiI.,trUlW:lOIlIt IIl&d. e\lbjeet to the ~lIIIti" of Seetlon 4llO4 ofth. CrilII.. CotIe(ll PA. CA .4804) .."liD, to IUl8WOm faW1IcatlOb to a\lthonti... ~~ a-, 11/ ..:!.l T""'~, ~ f~ /..P J?- 7?A 7~'" ~r ft'."',"1J ~ AND NOW. 0' tbIa claw /\ A CA ^ A' 1_ Q. 11/ q 1, I cerl:llY the complalllt Ilu bH' property eomplf!ted and ",rifled. AD _eVIl ofpr~E;;j,r.;;;;.;; mu~e compl~ (~order tor I W1ImUlt to...., -D~ u0fl~_.... ~c .'I.(4/")(lnl'r~1 Vlr.'on) The defendant is enjoined from harassing and stalking the plaintiff and from harassing the plaintiff's relatives, or the minor children. The defendant is enjoined from entering the plaintiff's place of employment and the schools and the day care facility of the minor children, The defendant is enjoined from removing, damaging, destroying or sellin. any property owned jointly by the partie. or owned solely by the plaintiff, A violation of this Order ma~ subject the defendant to: i) arre.t 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.C.S. g6114, punishable by impri.onment up to six months and a fine of $100.00-$1,000.00. and iv) civil conteept under 23 Pa.C.S. 86114.1. Resumption of co-residence on the part of the plaintiff and defendant shall not nullif~ 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 another act of abuse or has engage~ in a pattern or practice that indicates continued risk of harm to the plaintiff. Temporary custody of Devon Nash Gordon is hereby awarded to the plaintiff, Deborah A. Gordon. December, 1996, at ....j:.j(J ..',m., in Courtroom f the ,~a.,~ day of NO.~, Cumberland A hearing shall be held on this matter on County Courthouse, Carlisle, PennMylvania, The plaintiff may proceed without pre-payment of fee a pendin. a further order after the hearin., The Cumberland County Sheriff's Department shall attempt to make service at the plaintiff's request and without pre-payment of fees, but service may be accomplished under any applicable rule of Civil Procedure, This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service. The Prothonotary shall not send a copy of this Order to the defendant by mai 1. The Pennsylvania State Police Department will be provided with a certified copy of this Order by the plaintiff's attorney. This Order shall be enforced by any law enforcement a.ency 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 I the defendant shall be taken before the appropriate district Justice. (23 Pa.C.S, g 6113). By the Court I ..If Jud.e AlED-<lFFlC! or Tf'r. ~ ~nTl.!rp!,)TmY 950rr. '9 All Illl !i3 C"II' "'/ v . l~i_J,I.4 . '.' \'~""".)I\l Pl::NN:lYL:l/~ ~IA '-, , " ).51-/~~~' dwI. ~~~ ;t,Y~ , , ,', I I, , , 1,1 , ' 1.-1 ' , , " .'i ~ 4 Deborah L. Gordon, and on behalf of her minor children: Corynne and Cody Romberger and Devon Nash Gordon, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96- CIVIL TERM vs. PROTECTION FROM ABUSE AND CUSTODY Theodore P. Gordon, III, Defendant 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 appearin, personally or by attorney at the hearing scheduled by the Court and presenting to the Court your defenses or objections to the claills 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 .et forth below to find out where you can get legal help. COURT ADMINISTRATOR, 4th FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELKPHONE NUMBER: (717) 240-6200 AMERICANS WITH DISABILITIES ACT OF 1990 ~ The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hourn prior to any hearing or business before the court. You must attend the scheduled conference or hearing. \, ,'( '~ ,~ }.' ,','/, II Deborah L. Gordon, and on behalf of her minor children: Corynne and Cody Romberger and Devon Nash Gordon, Plaint iff IN TH~ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-a)} CIVIl. TERM PROTECTION FROM ABUSE AND CUSTODY 'III I v.. " ,:' I,: Theodore P. Gordon, III, Defendant i PETITION FOR PROTEC~ION ORDER AND CUSTODY RELIEF UNDER THE PROTECTION FROM ABUSE ACT, 23 Pa.C.S. I 6101 et seq. A. ABUSE 1. The plaintiff, Deborah L. Gordon, is an adult individual residing at 12 W. Main Street, P.O. Box 202, Plainfield, Cumberland County, Pennsylvania 17081. 2. The defendant, Theodore P. Gordon, III, (SSN: 073-64- 0944)(Date of Birth: 6/8/64), is an adult individual currently at the VA Medical Center, Ward 183B, 1700 S. Lincoln Avenue, Lebanon, Lebanon County, Pennsylvania, 17004, where he voluntarily committed himself. 3. The defendant is the plaintiff's husband. 4. Since approximately January 1, 1995, the defendant has attempted to cause and has intentionally, knowingly, or recklessly caused bodily injury to the plaintiff, has physically abused the minor c~ildren, Cody and Corynne Rombe~Jer, has placed the plaintiff in reasonable fear of imminent serious bodily injury, and has knowingly engaged in a course of conduct or 1 repeatedly committed acts toward the plaintiff and the minor children under circumstances which have placed the plaintiff and the children in reasonable fear of bodily injury. This has included, but iB not limited to, the following specific instances of abuse: a. On or about Decembcr 11, 1996, the defendant, while behind the plaintiff, put her in a headlock and repeatedly punched her causing her to have a broken nose, two black eyes, and a laceration to the head which required approximately seven stitches. While the plaintiff was bleeding profusely, the defendant grabbed her, threw her into a wall preventing her from going to the hospital. Whcn the defendant w~s distracted, the plaintiff ran to her car to flee to safety, and the defendant jumped onto the hood to try to stop her escape. Finally, whcn the defendant realized she was not going to get out of the car, he got off of the hood, and the plaintiff left the residence and went to the Carlisle Hospital. The Carlisle Police charged the defendant with assault and arrested him. On or about December 14, 1996, the defendant admitted to Trooper ~Iorst of the Carlisle Police that if he could hurt the plaintiff in that way, then he feared th~t he could have also done it to the baby, Devon Nash-Gordon, causing the plaintiff to fear for 2 , , her son's safety. b. On or about November 11, 1996, the defendant became angry and forcefully knocked a can out of the plaintiff's hand causing her to fear for her safety. When the plaintiff picked up the phone to call for help, the defendant grabbed the phone out of her hand cauaing her to fear and flee to safety at a neighbor's home. c. In or about July 1996, the defendant forcefully flipped the plaintiff's son, Cody Romberger, onto a bed causing him to cry and her to fear for his safety. Later that day, the plaintiff came out of their bathroom and the defendant while cleaning his shot gun, pointed it at the plaintiff causing her to fear. When the plaintiff told him not to point the gun at her, the defendant Raid he knew what he was doing asserting that the gun wasn't loaded. Later the plaintiff heard a gun shot and when she ran upstairs, she saw a hole in the wall of her daughter's room and realized that her daughter who was crying and complaininl that her arm stung, had been hit with fragments which flew from the wall as a result of the shot. At the plaintiff's insistence, the defendant turned his guns over to his brother. d. In or about December 1995, the defendant beca.e 3 angry at the plaintiff's son, Cody Romberger, picked him up, and threw onto a couch with such force that it rocked the couch and caused the child to cry such that the plaintiff feared for her son's safety. e. In or about October 1995, the defendant called the plaintiff vile names and forcefully slapped her cauaing her to hit her head on a wall which resulted in her having swelling to her head and a headache for several days. f. In or about January 1995, the defendant forcefully shoved the plaintiff's son, Cody Romberger, from behind causing him to fall to the floor and cry, and causing the plaintiff to fear for her son's safety. 5. The plaintiff believes and therefore avers that she 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. 6. The plaintiff desires that the defendant be enjoined from harasaing and stalking the plaintiff, and from harassing the plaintiff's relatives, or the minor children. 7. The plaintiff desires that the defendant be restrained from entering her place of employment and the schools and day care facility of the minor children. 8. The plaintiff desires that the defendant be enjoined 4 from removing, dama.in., destroyin. or selling any property owned solely by the plaintiff. B. EXCLUSIVE POSSESSION 9. The home from which the plaintiff is aRkin, the Court to exclude the defendant is rented in the names of the plaintiff and the defendant, but the defendant voluntarily moved out on or about December 14, 1996. 10. The defendant is now at the VA Medical Center where he voluntarily committed himself. 11. The plaintiff currently has no place to stay with her children except the marital home, and the defendant has voluntarily left the'residence. 12. The plaintiff desires possession of the home so as to give the greatest degree of continuity to the lives of the children and to allow Cody and Corynne Romberger to continue their shared weekly custody arran3ement with their father and their education at their school and to continue their school and social activities. ~ LOSSES AND REIMBURSEMENT FOR COST OF CASE 13. The plaintiff has suffered losses as a result of the abuse by the defendant. The losses are listed on Exhibit A attached. 14. The plaintiff Asks that the defendant be ordered to pay $250.00 to reimburse one of Legal Services, Inc.'s fund in. sources for the cost of litigating this case. 5 amended, the plaintiff prays this Honorable Court to .rant the following relief: A. Grant a Temporary Order pursuant to the "Protection from Abuse Act:" 1. Orderins the defendant to refrain from abusing the plaintiff and the minor children and placing them in fear of abuse. 2. Ordering the defendant to refrain from harassing and stalking the plaintiff and from harassing the plaintiff's relatives and the minor children. 3. Prohibiting the defendant from entering the plaintiff's place of employment and the schools or the day care facility of the minor children. 4. Prohibiting the defendant from removing, damaSing, destroying or Belling property jointly owned solely by the plaintiff. 5. Granting possession of the home 10cat6d at 12 W. Main Street, Plainfield, Cumberland County, Pennsylvania, to the plaintiff to the exclusion of the defendant pendins a final order in this matter. 6. Order inS the defendant to stay away from and any other residence the plaintiff may establish. 7. Grantins temporary custody of the minor child 8 to the plaintiff. B. Schedule a hearin. in accordance with the provisions of the .Protection from Abuse Act,. and, after such hearing, enter an order to be in effect for a period of one year: 1. Ordering the defendant to refrain from abusing the plaintiff and the minor children and placing them in fear of abuse. 2. Ordering the defendant to refrain from harassing and stalking the plaintiff and fro. harassing the plaintiff's relatives and the minor children. 3. Prohibiting the defendant from entering the plaintiff's place of employment and the schools and the day care facility of the minor children. 4. Prohibiting the defendant from removing, damaging, destroying or selling property owned solely by the plaintiff. 5. Granting possession of the home located at 12 W. Main Street, Plainfield, Cumberland County, Pennsylvania, to the plaintiff to the exclusion of the defendant. 6. Ordering the defendant to stay away from any other residence the plaintiff may e8tablish. 7. Granting primary physical custody of the minor child, Devon Nash-Gordon, to the plaintiff. 9 The above-named plaintiff, Deborah L. Gordon, verifies that the statements made in the above Petition are tl'ue and correct. The plaintiff understands that false statements herein are aade subject to the penalties of 18 Pa. C. S. Section 4904 rel.tin. to unsworn fAlsification to authorities. Date: /B/Ig/qu -1)1 hi}'! a.h ':xl Y:J(!Jr.dc"n_ Deborah L. Gordon, Plaintiff , ,', , , . , " 'I j,i )I] ~ ~ .;~, ~ M '- "" j,. " .. ,., r 9 , '-) Ih .,..... ~. ):... ' b~ ,'.. 'F L': ...:i'j < I (;.~ ",' en : ',,) ij!C;'; '~ 'Lt' <..1 " 'J . :.1 L II.' ~, 'c I..&. F- ,,-, ts ,l) "j Q. U " , , , , ;( "1 J , " ! I; ,!, ; I,' I 'II,i., J,e 'I" " ".Ij I without warrant upon probable cause that this Order has been violated, whether or not the violation is committed in the presence of a police offlcer. 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. 8 6113). 12. The defendant and the plaintiff agree to following regarding custody of their child, Devon Nash Gordon: a. The mother shall have primary physical and legal custody of the child. b. The father shall see the child according to the followins schedule: i. While the father is hospitalized for the next seven weeks, the mother will make arrangements for supervised visitation with the father at least every other weekend at times agreed upon by the parties until he is released from the inpatient treatment program. ii. Upon condition that the father has completed his inpatient treatment program and is released from treatment by his counselor, the father shall have supervised visitation for two hours every Saturday with an agreed upon supervisor tor three months. iii. When the father has completed his outpatient treatment program and his counselor has verified this and assured the mother in writing that the father is not a threat to the child, the father shall have unsupervised visitation for two hours every Saturday for the next three months. iv. Thereafter, and conditioned on the completion of the schedule delineated in paragraphs 12 (b) (i) through (iii), the father shall have partial custody of the child one day every other weekend (not to include overnights). c. The mother and father, by mutual agreement, may vary from this schedule at any time, but the Order shall remain in effect until further order of court. d. The mother and father agree that each shall notify the other immediately of medical emergencies which arise while the child is in that parent's care. e. The mother and father realize that their child's well being is paramount to any differences they might have between themselves. Therefore, they agree that neither party shall 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 ;.' F1~E OF nl~ P~",)T'!(:~~()mIY 95 orr. 23 rll 31!i3 CUMt;;il"",.:) C...'JNTY PtNNSYLVM/A , , , " , , , , " ',I 'li',' // ~ !:' 0' " ;) ) vs. IN THE COURT OF COMMON Pl,EAB OF CUMBERLAND COUNTY, PENNBYlNANIA NO. 96-6853 CIVIL TERM PROTECTION FROM ABUSE AND CUSTODY Deborah L. Gordon, and on behalf of her minor children: Corynne and Cody Romberger and Devon Nash Gordon, Plaintiff Theodore P. Gordon, III, Defendant ~O~SENT AGREEMENT ~ This Agreement is entered on this ~3 day of December, 1996, by the plaintiff, Deborah I.. Gordon, and the defendant, Theodore P. Gordon, III. The plaintiff is represented by Joan Carey of l.EGAL 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, Theodore P. Gordon, Ill, agrees to refrain from abusing the plaintiff, Deborah L. Gordon, and the minor children and placing them in fear of abuse. 2. The defendant agrees not to harass and stalk the plaintiff and not to harass the plaintiff's relatives and the minor children. 3. The defendant agrees not to enter the plaintiff's place of employment and the schools or day care facility of the minor children. 4. The defendant agrees not to remove, damage, destroy, or sell any property owned by the plaintiff. 5. The defendant agrees to stay away from the plaintiff's residence located at 12 W. Main Street, Plainfield, Cumberland County, Pennsylvania, and any other residence the plaintiff may establish. 6. The defendant agrees to pay the plaintiff's out-of~ pocket losses suffered as a result of the abuse immediately upon receipt of any bills including but not limited to the losses listed on the attached sheet marked Exhibit A. The defendant understands that thia award does not constitute a bar to litigation for civil damages for other injuries sustained from the acts of abuse giving rise to this award. 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 year and can be extended beyond it 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. The defendant understands that thie Ord~r 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. g6113; ii) a private criminal complaint under 23 Pa.C.S. g6113.1i iii) a charge of indirect criminal contempt under 23 Pa.C.S. ~6114, punlshable by imprisonment up to six months and a fine of $100.00-$1,000.00; and iv) civil contempt under 23 Pa.C.S. 86114.1. 10. The defendant and the plaintiff agree to following i ';1 regarding custody of their child, Devon Nash Gordon: a. The mother shall have primary physical and legal custody of the child. b. The father shall see the child according to the following schedule: i. Whlle the father is hospitalized for the next seven weeks, the mother will make arrangements for supervised visitation with the father at least every other weekend at times agreed upon by the parties until he is released from the inpatient treatment program. ii. Upon condition that the father has completed his inpatient treatment program and is released from treatment by his counselor, the father shall have supervised visitation for two hours every Saturday with an agreed upon supervisor for three months. iii. When the father has completed his outpatient treatment program and his counselor has verified this and assured the mother in writing that the father is not a threat to the child, the father shall have unsupervised visitation for two hours every Saturday for the next three months. Iv. Thereafter, and conditioned on the completion of the schedule delineated in paragraphs 10 (b) (i) through (iii), the father shall have partial Deborah L. Gordon, and on behalf of her minor children: Corynne and Cody Romberger and Devon Nash Gordon, Plaintiff IN THE COURT OF COMMON PI,EAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 96-6853 CIVIL TERM vs. PROTECTION FROM ABUSE AND CUSTODY Theodore P. Gordon, III, Defendant QU1-0F-POCKET LOSSES The plaintiff requests that the defendant reimburse her out- of-pocket losses, including but not limited to the following: Any and all unreimbursed medical expenses relating to injuries she sustained as a result of the incident on or about December 11, 1996. (The plaintiff has not received any medical bills as of the filing of this petition.) Ixh1bit A , '. ::HIERLn':j r\ETLJI~N ',~IIJ r lJf,' ':UIJIIrY CAH~ NO: 1~9G 0GB5J P CUMMONW~;^l.rll IJF f'I':NN'~Yl.VANLA: CUI.lNTY UF CUM 1)1.:nLANf) GtllWUN DFlllmAH L...ll-A.!.... V," .::>, IjUnDUN TIl~;UDIIH~: P [II 11. ThnRlOS Kline . Sherlff, >tho belng duly s>torn accordlng and lnquiry for the ~lthln to law. says. that he Rlade a dillgent ,,,,,arch na,"~d defendant. to >t ~ t. : GORDON TII~:ODURE f' ILL but was unable to locate Hlm in hlS balliwlck. He then'fore deputized the sheriff of ~~BANON to aerve the >tlthin PRUr~GTIUN FROM ABUS~ County, I"'~nnsylvania. On [lecE'mber 21th. 1391;. the attached return from , thlS uff!ce >taF ln receipt of LEBANON Count y, Pennsylvanla. Sherlff's CostSI Docketing Out. of County Surcharge Lebanon County 11'.\,00 9..00 2.1/)(,11 27.45 ::;0 anaw"Is: /"',' /./ /) V.../,...~/ ." R. rlhl:lmas I\llne, -..-;;'-;'. ::'her i tt '~'~'.h 45 00/00/1/)IJ00 ~w"rn anrJ aubscr.~be~ to bofor~ nle this 31 A#' oj a y 0 f J...i.t.u.__ t . . 1':1 ?~ A.D, ~~ ~ ~ .eA-J ~ - Pr ho b i-lr]' I ,l . PROTF.C'l'tON FROM ARUSE ORDF,R ! No. 96-6853 DEBORAH L. GORDON, ET At LtlOanon, i'A, December 23, 1996' (RETURN TO CUMBERLAND CO. SHERIFF) VB. THEODORE P. GORDON, III DOCKET PAGE 10551 STATE OF PENNSYLVANIA } COUNTY OF LEBANON } 55: Ferdinand J. Sammer, Deputy Sheriff, being duly sworn according to law, deposes and says that he served the within PROTECTION FROM ABUSE ORDER upon THEODORE P. GORDON, III, the within named DEFENDANT, by handing a true and attested copy thereof, to him, personally, on December 20, 1996, at 4:35 o'clock P.M., at Lebanon VA Medical center, 1700 South r.incoln Avenue, Lebanon (s. Lobanon 'l'Wp.), I.ebanon County, Pennsylvania, and by making known to him the contents of the same. Sworn to and subscribed before me , SO ANS~ER~, ", ,', l . / 2.,,;.....:.~.o!?ht. '.j '-'-cf'd-J/P/IW DEPUTY $'H ER,IfF Iv'J' .V..S , '0/.," ~ ' ,I '/, . , '.... '/ -....... .. ,. . (,(0'':-/' ,f..~ v 'Jl;ze. ~ SHE~FF \/ ~ s l.his December, A.D., 1996 Notary Public fARIAL SEAL 'j r AI-.t~j~'~, !l:tciry Cl'J~!:C l.ttll.r,~r. I ~t. ,,! (', '.' c/, t 1 ~lt\. '_ ~~ '.('t,1'~"'~\l ~ I~.'rt~ oll&.,t ij ,~a SHERIFF'::> co,,~c T~ ABOVE PROCEEDINGS Advanced costs pald on Check No. Costs incurred: IN FORMA PAUPERIS-NO COSTS DUE Refund: Check No. ~" 27.45 l\I\1ount Amount All Sheriff's Costs shall be due and payable when services arc performed, and it shall be lawful for him to demand and receive from the party instituting the proceedings, or any party liable for the costs thereof, all unpaid sheriff's fees on the same before he shall be obligated by law to make return thereof. __Sec. 2, Act of June 20, 1911, P.L. 1.072 Deborah L. Gordon VS. Theodore P. Gordon ~o. 96-6853 ..Civil . ~ ----r ..-- ~ow. December 19 :9--2A !., S:...r:'"~~ 0:: C~[3::::'='!"A..'rn COt.-:1":Y, ?4... CQ :=-J:y c!..c:u"':'" tb: :=-= cl Lebanon C.::u::r :0 C::-':::: = '.V::~ =::s e~u::..~ , , . :;..-t -...... u ~ ~:d :.:d :::.k of := ?!:1!:::. i"'~I1'...t:~~ SC&:"..! ct S-=ar...1CQ C:U::T, ?~ '" ~~a."":t cr- ... -- ~t;..~ '::e. ,:~ :iow, ~9 o":!cc ,,[. .-.-: .-...... . . ,. :.::: ~...... ":::eEl ;: by==C!::.i:.o a. c:::rr r:i == :::~_...r - ,- ~ci -~,;. i::.owa = :!::.: ::::e::s ':.~::::i. Sa :l:SW=-'.. !l:c:!5 at C~\lArr. !':. Swc:: :::Ie! s:.:==:m == == =s c.."! d t~_ CCS1'3 SD'-i'CZ ~C!l.!..'.CZ .-\.::m.......17 s ------. 5 ,_ ~-.l D..ORAB L. GORDON, and on b.ha1f of minor ohi1dren CORYNNI and CODY RONBIROI. and DIVaN NASH GOaDON, Plaintiff V. TRIODO.I P. GORDON, III, D.fendsnt . .... -.... I IN THI COURT or COMMON PLIAS or I CUMBIRLAND COUNTY, PIINNSYLVANIA I I PROTICTION rRON ABUSI I I CIVIL ACTION - LAW I I I I 96-6853 CIVIL TIRM IN RII PROTICTIV. OaDIR VACATID OaDlR or COURT AND NOW, this 10th day of Maroh, 1997, on raqu..t of the p.tition.r h.rein. the within prot.otive ord.r i. d....d vaoat.d. Nioha.1 Sohwoy.r, ..quir. As.i.tant Di.triot Attorney My1e. Kauffman, I.quire ror the Defendant Shedff ..1 By the Court. . .3/,;;1,/ '1'1 C-o.>>""", (..,,,,ul..;'" 1" -"I )" . f I' I i , f" , or- :i t:"r).O~:r"lf~i: , " ~, , '. 'T' "',' Ii,"" (r/W:: I.. i'ii 1:1..6 L;l);.:. :, I' . "1' ~ /. ..:' _,' \ '. ' .. 'L:1'1l,..,) .L./j I. j.f \ ',i I , " , , " D..OIAR L. (JORDON, and on behalf of minor cbildren CORYKNI and CODY ROMBIROIR and DIVON NABB (JORDON, Plaintiff V. TBlODOR. P. (JORDON, III, Defendant I IN TBI COURT 01' COIOlON PLIAS 01' I CUMIIIRLAHD COUNTY, PIIHH8YLVAHIA I I PROTICTION PROM ABU81 I I CIVIL ACTION - LAW I I I I 96-6853 CIVIL TIRN IN .11 COHTIDCPT CRDIR 01' COURT AND NOW. tbi. 10th day of Marob, 1997, the defendant baving admitted that he i. in oontempt of tbe witbin protective order, he is thu. adjudged. Sentenoe of tbe Court i. that be pay tbe co.t. and undergo .upervised probation for a period of 6 month.. Micbael Schwoyer, I.quire A..i.tant Di.trict Attorney _ J I" ('~~L.t ,:>/,a. "l ' -~ -- ~ ,of'. Nyle. Kauffman, I.quire I'or tbe Defendant Sheriff _1 By the Court, /L ,. , , f!(: <JJ , , III' ,~~ 'OS c,>; " [' '-' L_. ::::j 9: 1-,1 ::~ t,:i ~ .; [-/: I , 'j~ I, '. .' ,- , u 1,7', l'j , I " r~ECE,IPr FOR PAYME,NT ~~OOI~bUDDM~~~t~~nIIWBIIIU":~UU" i;,r Cunlb.n':~lAl'Id County P'r'o~ho!1oto\l')" 1II Office Carlisla, Pa 1701J f~l\fCfl~~t p'atu 1(;1/08/9'7 ~:g:tp~ M~lIl 81~9~~~ , 'f' : "I " " CAllIO Numbll'r 199'7'-9'~9'~9 ;11' 130RDlJN TI,mODlme: P III (Vel) f~oceivad of 96-6853 CIVIL l'ERI1 COe;T€1 (IF P"<OS PAID (IY I)EFl' Total Check... + :35.00 l'ot.ll Call1h.... + .00 Ch""ge....... ........ .-.....".MM..'~~~~.......".."........p_~I.. Check No. 13234 Receipt 'l;()t;"l. "" ;;l~:;.lil(a _ .__ _. _. '... ,M' .....M ..,... 'M' _..." _.." ........._._.... .....M.... IHst'd.bution Of Pc\Ylllent "."......,-_.....,.._'-'-_..._--.;.-~---- Tl','l'Is.wt:l.on Desc'('l ption PaYlllfJnt AmoLlnt 11ISC. MONIES ~~~). 00 CUI11~E:flI..I~Nl) ClJ 13EI<lERIlI. FUND a~;j. ~)(il -,,' f~ECE,lPl F()I~ PIWI'IENT n~II~U~~lwmlllCllnnnUU~nnl~JI~I~I~tlm Cunlborl.md CCllll'lty P'rclthcm';lt;iA','y'l& Offir:e C~rllmlfl, P~ 17ID13 R€lcoipt D.,tIJ llil/0B/'~7 r~l)cI)ipt Tinm 1~~54105 Receipt No. 513e4 GORDON \)EBIJRnH L <VB> 130RDOI'l nit:mDllI~t::: P n r C.1ne Nlllllb€)'r j, 99&'.'0(,8~j" Roce i wid (l f PD BY lHE()DOR~: P (301~D()N I I I Tot~l Ch€ldf,... .. Tot.,l Cal&h.... .. Changa. . . . . . .. "M 10.~\0 .0~ ......,,,..,,.,,...,,...,.j!,,,,,,,.. HI. 50 Chedt, No. 1"~234 Receipt tatal. . ..,.,___,_,.".,__,__,_____"__NM'.'_'_'_". Di st'r i bution Of P~ynlfent ...,.,.,....,.,......,.,...,..,.,..,..,........-..-...,...--,.... Pc1YIll€Hlt AlIltlunt T'ranlil~ctic)l'l [)'~';c'd, Ilt icm m::lTLEl1EIH JCP FEE: STATE TAX ~5..1i.)0 ~j. 00 . e,ila ClJI1BERUll'lD CO (3ENEI~m. FUND BUrmAU OF m'::CEIPTS AND CONTROL BUREllU OF RE,CEIPTU AND CONTROL lIa. !,\0 " . , COMMONWEALTH IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. TERM " NO. PROB. NO. CHARGEl 1996-56853 37659 CASE TRANSFERRED FROM CIVIL DIVISION THEODORE P GORDON III OTNI AFFIANTl IN REI PETITION FOR VIOLATION OF PROBATION AND NOW, July 28, 1997, the Probation Office of Cumberland County, respectfully petitions Your Honorable Court to revoke the defendant's probation. The defendant has failed to comply with the Court Order dated 3/10/1997. The defendant has failed to: 1. Report to the Probation Office in person at the time and date set by the Collections Officer. 2. Make regular payments on the fines, costs, and restitution as agreed. 3. Other: ;' The defendant has agreed to pay $50.00 per month. Date last paid was 0/00/0000. The balance is $128.45. Therefore your petitioner prays this Honorable Court to issue a order revoking the defendant's probation. Respectfully submitted, j~ /z;?i,. ,peUtionW . " " iY: ..:l' ~ " .~ ~ ~r .. r.:,) "1~ - - ':5".1 '..... " ~. ;.e '..'.t ''''~.1 J(" 'n ,~[,? I oK - l.tq, -, ;:1& r!;; =) "'lO LI, ~ a, (.) '" ) " ~#J""'_ ~+,J._, -~ ' 1- " '0, , ' ,/ '.. ;.:r , tr: .:% ?:; '" ~" "_ I ~9 .. :""J...(. - r;,'f - .,~ ;'.J ~ t" , , ft' ;~)! - -I" ,,"i::.:i' ,,- %'; :,,;:"- i 'n . ([l ,. ,- ',\ ..l~ uJ'" :l'~ hre W.:I-~ :;J :1,! ... -) ~ 1:'.5 0.') 0' ~ .::r -- .:1 (:.. .'1 , J_ ...;. .. ':l..rl' "5(,' - .~ \ '.' I .~:; c.. .', - 1; , t(' ,..-\ '''-~ , ,~j ~~. '.f) <:}~ L \;.1: .~ '.' (. - ,J .:.~ tCl.' -_... .+1'0 " - r' ::-J ' 1.1 0:: --, ..; u- 0:: B 0 0' " "