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HomeMy WebLinkAbout00-00081 . I .~ DAVID A. MANGAM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW BOGUMILA MANGAM, Defendant NO. 2000 - 81 CIVIL TERM ORDER OF COURT AND NOW, this 0 ~daY of January, 2000, upon consideration of the Petition for Protection From Abuse, a hearing is scheduled for January 7, 2000, at 11:15 a.m., in Courtroom No.1, Cumberland County Courthouse, Carlisle, Pennsylvania. BY TIlE COURT, :;;;~O:;:U /-j, -dJ~ -R 1J..s @ Catherine A. Boyle, Esq. 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 Attorney for Plaintiff :rc " ("~ 0 , . '--' (.- :::' ,~ gJ ::: , i ;g , .-~,n, '-' ,- . en ~~6 c' ~.-,. - : ?-~ 2; -z. r;!~ > 8 9 orn ~ --I =< => p co :.;:} -< Bogumila Mangam 3818 Panay Drive Mechanicsburg, PA 17055 Defendant vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ;;to 00 ~ P{ C~0i..L y~ PROTECTION FROM ABUSE DAVID A. MANGAM, Plaintiff BOGUMlLA MANGAM, Defendant NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case ma proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on the matter is scheduled for the _ . _', 2000 at ~m., in Courtroom No., _ o{ ClinuJer.Larl<.1, County Courthouse, Carlisle, Pennsy.Lvania. day of the You MUST obey the Order that is attached until it is modified or terminated by the court after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six months in jail under 23 Pa.C.S. ~ 6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. ~ 2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. ~ 2261-2262. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAV THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEARING. THE COURT WILL NOT, HOWEVER, APPOINT A LAWYER FOR YOU. IF YOU DO NO HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFIC SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YO CANNOT FIND A LAWYER, YOU MAY HAVE TO PROCEED WITHOUT ONE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717)249-3l66 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 hours prior to any hearing or business before the court. You must attend the scheduled conference or I hearing. I ~ MEYERS, DESFOR, SALlZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-2817 DAVID A. MANGAM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. BOGUMILA MANGAM, Defendant PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name: Bogtiini'la Mangam Defendant's Date of Birth: 9/29/57 Defendant's Social Security Number: 595-38-6310 Name of all Protected persons: David A. Mangam AND NOW, this consideration of the court hereby day of , 2000, upon the attached Petition for Protection from Abuse, enters the following Temporary Order: 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. 2. Defendant is evicted and excluded from the Plaintiff's residence located temporarily at the Hampton Inn, Mechanicsburg, Cumberland County, Pennsylvania, which is no owned or leased by the Defendant, or any other permanent or temporary residence where Plaintiff may live. Defendant shall have no right or privilege to enter or be present on the premises, except for the limited purpose of transferrin custody of the parties' children. The Defendant shall remain in her vehicle at all times during the transfer of custody. 3. The following additional relief is granted: The Cumberland County Sheriff's Department shall attempt to make service at 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 Defendant by mail. Law enforcement agencies, human service agencies and school districts shall not disclose the presence of Plaintiff in the jurisdiction or district or furnish any address, telephone number, or any other demographic information about the Plaintiff except by further Order of Court. 2 MEYERS, DESFOR, $ALTZGIVER &: BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-2817 This Order shall rem~in in effect until modified or terminated by the Court and can be e~tended beyond its original expiration date if the Court finds that Defendant has committed another act of abuse or has engaged in a pattern or practice that indicates continued risk or harm to Plaintiff. ' Defehdant is required to relinquish to the Sheriff any firearm license Defendant may possess. Defendant's weapons and firearm license may be returned at the expiration of the Protection Order after Defendant has submitted a written request to the Court for the return of the weapons and the Court has notified Plaintiff of the request and given Plaintiff an opportunity to respond. A copy of this order shall be transmitted to the chief or head Of police department of Cumberland County and the sheriff of Cumberland County. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. Defendant is to refrain frOm harassing Plaintiff's relatives. 4. A certified copy of this order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Pennsylvania State Police. 5. THIS ORDER SUPERSEDES ANY PFA ORDER AND ANY PRIOR ORDER RELATING TO CHILD CUSTODY. 6. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAI IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months in jail. 23 Pa.C.S. ~ 6114. Consent of the plaintiff to Defendant's return to the residence shall not invalidate this Order, Defendant may be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence of law enforcement. Subsequent to an arrest, the law enforcement office shall seize all weapons used or threatened to pe used during the violation of this Order OR during prior incidents of abuse. !! 3 MEYERS, DESFOR. SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236--9428 . FAX (717) 236-2817 Weapons must forthwith be delivered to the Sheriff's Office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this Court, unless the weaponjs are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. BY THE COURT, Judge , a, Cat erine A. Boyle, Attorney for Plainti I ~ 4 MEYERS, DES FOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236.2817 DAVID A. MANGAM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ;:2 u-vv' S / ~ -r.L--- vs. BOGUMILA MANGAM, Defendant PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE 1. Plaintiff's name is David A. Mangam. 2. This petition is filed on behalf of Plaintiff. 3. The name of the person who seeks protection from abuse is David A. Mangam. 4. Plaintiff's temporary address is Hampton Inn, Mechanicsburg, Cumberland County, Pennsylvania. 5. Defendant is believed to live at the following address: 3818 panay Drive, Mechanicsbrug, Cumberland County, pennsylvania. Defendant's date of birth is: 9/29/57. Defendant's place of employment is: Self-employed working from home. 6. Defendant is Plaintiff's spouse. 7. Plaintiff and Defendant have been involved in the following court actions for divorce, custody, support, or protection from abuse: Divorce and Custody Complaints filed contemporaneously with this Petition. 8 . Defendant has been involved in the following criminal court action: None. 9. Plaintiff and Defendant are the parents of the following minor children: Name Aqe Address Caroline Angelica 17 3818 Panay Drive Mangam Mechanicsburg, PA Victoria Olivia 11 3818 panay Drive Mangam Mechanicsburg, PA 10. There is not an existing Court Order regarding the custody of the parties' children. Plaintiff files a Custody ,Complaint contemporaneously with this Petition. I ~ 5 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P,O, BOX 1062 . HARRISBURG, PA 17108 (717) 236.9428 . FAX (717) 236.2817 11. The following other minor children presently live with Plaintiff: None. 12. The facts of the most recent incident of abuse are as follows: a. December 18. 1999- The parties were having an argument over their oldest daughter's use of a rental vehicle. The parties were involved in an automobile accident one month prior which resulted in being provided a rental vehicle to replace the vehicle damaged in the accident. The rental company restricted this vehicles use to anyone over the age of 21. Mother refused to allow the parties' daughter to use the other jointly owned vehicles and repeatedly allowed her to use the rental vehicle. The parties' oldest daughter joined in the argument and became very angry because she was no longer permitted to use the vehicle. Notably, the child's grades have been falling and her behavior becoming more and more unruly. Plaintiff removed himself from the argument and went into the guest bedroom. Whereupon, Defendant entered the room and began screaming and yelling at the Plaintiff. The parties' oldest daughter followed her and began kickin Plaintiff and screaming at Plaintiff. The argument moved into the hallway where it continued for some time. Plaintiff repeatedly ordered daughter to go to her room and she refused, again kicking Plaintiff and screaming at Plaintiff. Eventually, the daughter removed Plaintiff's glasses and when asked to return them tossed them to her mother, who also refused to return same. The two continued to throw the glasses back and forth until the glasses were ultimately recovered by Plaintiff. Plaintiff ultimately returned to the guest bedroom and called the police. 13. Defendant has committed the following prior acts of abuse against plaintiff: a. December 13. ~999- Plaintiff was reprimanding the parties' oldest daughter regarding her school work and taking the keys of the rental vehicle. Again, the daughter reacted with extremely foul language and started hitting and kicking her father. Defendant cheered the child on by stating, "You go, girl!" Eventually, Plaintiff called the police once again and the daughter was instructed that father could remove her to her room and reprimand her if necessary. b. On or about December 23, 1999- Defendant told Plaintiff that she had sold some of his things, without his knowledge or permission, including a digital camer he had recently purchased. Defendant, fearing that Plaintiff would take his lap top computer, was carryin I the lap top computer into the guest bedroom. Defendant 6 MEYERS, DES FOR, SALlZGlVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236.9428 . FAX (717) 236-2817 became enraged that Plaintiff would not return the lap top computer to her and physically attacked Plaintiff. She scratched his face and ripped his glasses from his face. she gouged at his skin until he was bleeding profusely. Photographs of the incident are attached hereto and referred to hereinafter as Exhibit "A". This incident was witnessed by the parties' youngest daughter. c. Christmas 1999 weekend- Plaintiff heard some noise in the garage late in the evening and went into same to secure the residence and the vehicles. At that time, Plaintiff noted that the hood of his vehicle was open and several parts were removed as well as the battery and starter disconnected. Plaintiff then attempted to return inside the residence and was locked out through the door in the garage where he had just entered. The front door was locked as well. When Plaintiff attempted to use his keys to re-enter the residence, someone was behind the door holding the lock shut. Plaintiff was forced to sleep in his vehicle for half of the night. d. December 25. 1999- In an attempt to celebrate the holiday, Plaintiff prepared an extensive meal for Defendant and the parties' two children. Defendant disappeared with the parties' children for the better part of the day and did not return to the residence in time to share the meal. Plaintiff went to a family members home and left the meal in the kitchen along with a note .,,__ Defendant told the children they were no permitted to eat anything prepared by plaintiff and forced them to wait until she prepared a second meal. e. Defendant has been controlling, manipulative, harassing, abusive and demanding of Plaintiff and the minor children many times in the past, with arguments that are becoming more and more violent, upsetting, an frightening. Defendant's behavior has forced Plaintif from the parties' jointly titled home and Plaintiff believes that Defendant, who is the actual aggressor, is abusing the PFA process to secure the residence and custody of the parties' two minor children. 14. The following police departments or law enforcement agency in the area in which plaintiff lives should be provided a copy of "the Protection Order: 15. There is an immediate and present danger of further abuse from Defendant. 7 MEYERS, DES FOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET ! P.o. BOX 1062 . HARRISBURG, PA 1710B (717) 236-9428 . FAX (717) 236-2817 16. Plaintiff is asking the Court to evict and exclude the Defendant from the residence at Hampton Inn, Mechanicsburg, Cumberland County, Pennsylvania, which is rented by Plaintiff. 17. Plaintiff has suffered the following out-of-pocket financial losses as a result of the abuse described above: Attorney's fees in an amount to be determined at trial. WHEREFORE, PLAINTIFF REQUESTS THAT THE COURT ENTER A TEMPORARY ORDER, AND AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff in any place where Plaintiff may be found. b. Evict/exclude Defendant from Plaintiff's residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff. c. Prohibit Defendant from having any contact with Plaintiff either in person, by telephone, or in writing, personally or through third persons, including, but not limited to, any contact at Plaintiff's school, business, or place of employment, except as the Court may find necessary with respect to partial custody and/or visitation with the minor children, d. Prohibit Defendant from having any contact with Plaintiff's relatives listed in this Petition, except as the court may find necessary with respect to partial custody and/or visitation with the minor children. e. Direct Defendant to pay Plaintiff for the reasonable financial losses suffered as a result of the abuse, to be determined at the hearing. f. Order Defendant to pay the costs of this action, including filing fees, service fees, and surcharges of $25.00. g. Order the following additional relief: i. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owne solely by Plaintiff. ii. Defendant is to refrain from harassing Plaintiff' relatives. h. Grant such other relief as the court deems appropriate. J 8 MEYERS, DES FOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-2817 Order the police or other law enforcement agency to serve the Defendant with a copy of this petition, any Order issued, and the Order for Hearing. The petitioner will inform the designated authority of any addresses, other than Defendant's residence, where Defendant can be served. Respectfully submitted, -~ therine A. Boyle, E MEYERS, DESFOR, SALT & BOYLE Attorney I.D. #76328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for Plaintiff i I ~ 9 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG. PA 17108 (717) 236-9428 . FAX (717) 236-2817 I' II I I VERIFICATION If n~'ri~ n M~n~~m , verify that the statements made in this ,PF''1'T'1'TON POR PRO'1'F'(,,'1'TON PROM ll.RTTi':F' are true and correct to the bes of my knowledge, information and belief. I understand that fals statements herein are made subject to the penalties of 18 Pa. II C.s. Section 4904, relating to unsworn falsification to II authorities. Dated: 1/4/2000 ~~fff .--- ( ) Plaintiff" / Defendant I II II II Ii I, if 'I I, I II " Ii II ii I i: il " , il I' il MEYERS., DESFOR, SALTZGIVER & BOYLE 410 NOATH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236.9428 FAX (717) 236-2817 i. I I I I i I I I I I I I I I I \ ~ EXHIBIT A .' " J f f f. '" f t i .llfl ! , J 51 ~ j i. " "I r f i i, II RI f I 'I r J I I ~ / I I , , ,i I I 1; , .,~ ~ ' i I f I ! 'r . . I F' , il , "I I 1 I ~ ~- !i , ~ c; " ~ "'CI r ~ 01, ll~ " ~J! . ! I a I ~ ~., .r" , itl , 0 . I' ~ 11 ::r~ , I ~ I r -! ~ L ~ ! ~ l!J ,,' Ii; , ~ m ," ~I I, ,~' I I .,1 ~I (") : ~E ; ::'i. ~I ~I htJ -! J :~ I , il l. o~ I,..." '. '''''''' I . I I Ii f jbt I . ZB; I~~ i II ~! i " I If .,,~ ~, ~I . " ,,~ " : $ 1 ~, I 0" J!' I , i . i ' I "I . II J ~. I' , , ~~ I i , I f l' I I I " i i :1 _..~.~ :> E I . . j~ n ~ ~ ~ I I~ ! t ~ 1%1'" i i If: ~ Cd I ~W . en'" , m ~ ' I i '", 1 I ~ i ' I )11 ] " 0 :l> .~ i '"I! i; > ] ~~ ' !, 111 II ! r en I . ~'C'I I ~ ' t i :r: ~ P'li m l ! ~ m . lrt! j -! I I #! . 'lI' f . " I I i) r If '" '" i , J J jl 1 j " I i , II I (I f "I 0 , f I t I ~ c:::: . I !pl~ j I i' .w ~ 81 ~ "'I 0 I ::: I . . J ~, ni .. ~, I .. ~ I i ", I .. g, ..I ..I j I i ::> Q; JAN 6 20UV1 vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. ~C>- II C;t( ~ PROTECTION FROM ABUSE DAVID A. MANGAM, Plaintiff BOGUMILA MANGAM, Defendant NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend againstJ1 the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case ma proceed against you and a FINAL Order may be entered against you ' granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on the matter is scheduled for the , 2000 at m., in Courtroom No. of Cumberland County Courthouse, Carlisle, Pennsylvania. day of the You MUST obey the Order that is attached until it is modified or terminated by the court after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six months in jail under 23 Pa.C.S. S 6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. S 2265, this Order is enforceabl~anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 D.S.C. S 2261-2262. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAV THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEARING. COURT WILL NOT, HOWEVER, APPOINT A LAWYER FOR YOU. IF YOU HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CANNOT FIND A LAWYER, YOU MAY HAVE TO PROCEED WITHOUT ONE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 T~~ NO~ OFFIC IF YO I I 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 hours prior to any hearing or business Ili[1 before the court. You must attend the scheduled conference or hearing. 'I )i MEYERS, DESFOR, SAlTZGIVEA & BOYLE 410 NORTH SECOND STREET .. P,Q. BOX 1062 . HARRISBURG, PA 17108 (717) 236.9428 . FAX (717)236-2817 DAVID A. MANGAM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. BOGUMILA MANGAM, Defendant PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name: Bogumila Mangam Defendant's Date of Birth: 9/29/57 Defendant's Social Security Number: 595-38-6310 Name of all Protected persons: David A. Mangam AND NOW, this consideration of the court hereby day of , 2000, upon the attached Petition for Protection from Abuse, enters the following Temporary Order: 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. 2 . Defendant is evicted and excluded from the Plaintiff's I residence located temporarily at the Hampton Inn, Mechanicsburg, Cumberland County, pennsylvania, which is notl owned or leased by the Defendant, or any other permanent or i temporary residence where Plaintiff may live. Defendant I shall have no right or privilege to enter or be present on the premises, except for the limited purpose of transferrin~ custody of the parties' children. The Defendant shall I remain in her vehicle at all times during the transfer of custody. 3 . The following additional relief is granted: The Cumberland County Sheriff's Department shall attempt to make service at 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 Defendant by mail. i i Ii i' Ii Law enforcement agencies, human service agencies and school districts shall not disclose the presence of Plaintiff in the jurisdiction or district or furnish any address, telephone number, or any other demographic information about the Plaintiff except by further Order of Court. 2 MEYERS, DESFOR, SALlZGIVER & BOYLE 410 NORTH SECOND STREET D P.O. BOX 1062 . HAARISBURG, PA 17108 (717) 236.9428 FAX (717) 236-2817 J 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 Defendant has committed another act of abuse or has engaged in a pattern or practice that indicates continued risk or harm to Plaintiff. Defendant is required to relinquish to the Sheriff any firearm license Defendant may possess. Defendant's weapons and firearm license may be returned at the expiration of the[ Protection Order after Defendant has submitted a written I request to the Court for the return of the weaponB and the Court has notified Plaintiff of the request and given plaintiff an opportunity to respond. A copy of this order i shall be transmitted to the chief or head of police department of Cumberland County and the sheriff of Cumberland County. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. Defendant is to refrain from harassing Plaintiff's relatives. 4. A certified copy of this order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Pennsylvania state Police. 5. THIS ORDER SUPERSEDES ANY PFA ORDER AND ANY PRIOR ORDER RELATING TO CHILD CUSTODY. 6. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAI IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months in jail. 23 Pa.C.S. S 6114. Consent of the plaintiff to Defendant's return to the residence shall not invalidate this Order, Defendant may be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence of law enforcement. Subsequent to an arrest, the law enforcement office shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. I II I' ( Ii 3 MEYERS, DESFOA, SALTZGIVER & BOYLE 410 NOATH SECOND STREET. P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236.9428 . FAX (717) 236-2sn Weapons must forthwith be delivered to the Sheriff's Office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this Court, unless the weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. BY THE COURT, Judge , c;l Cat erine A. Boyle, Attorney for Plainti I I ,I " II .1 " " I' Ii 4 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET. P,O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-2817 DAVID A. MANGAM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. BOGUMILA MANGAM, Defendant PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case ma proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on the matter is scheduled for the , 2000 at m., in Courtroom No. -of Cumberland County Courthouse, Carlisle, Pennsylvania. day of the You MUST obey the Order that is attached until it is modified or terminated by the court after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal 'I contempt which is punishable by a fine of up to $1,000.00 and/or I up to six months in jail under 23 Pa.C.S. S 6114. Violation may also subject you to prosecution and criminal penalties under the I' Pennsylvania Crimes Code. Under federal law, 18 U.S.C. 5 2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. S 2261-2262. YOU SHOULD T~XE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAV THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEARING. THE COURT WILL NOT, HOWEVER, APPOINT A LAWYER FOR YOU. IF YOU DO NO HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFIC SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YO CANNOT FIND A LAWYER, YOU MAY HAVE TO PROCEED WITHOUT ONE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 'I II II if 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 'I before the court, please contact our office. All arrangements 1 must be made at least 72 hours prior to any hearing or business I before the court. You must attend the scheduled conference or : hearing. i I , MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET. P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-2817 DAVID A. MANGAM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. BOGUMILA MANGAM, Defendant PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name: Bogumila Mangam Defendant's Date of Birth: 9/29/57 Defendant's Social Security Number: 595-38-6310 Name of all Protected persons: David A. Mangam AND NOW, this consideration of the court hereby day of , 2000, upon the attached Petition for Protection from Abuse, enters the following Temporary Order: 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. I Defendant is evicted and excluded from the Plaintiff's I residence located temporarily at the Hampton Inn, Mechanicsburg, Cumberland County, Pennsylvania, which is notl owned or leased by the Defendant, or any other permanent or [' temporary residence where Plaintiff may live. Defendant shall have no right or privilege to enter or be present on the premises, except for the limited purpose of tranSferrin1 custody of the parties' children. The Defendant shall remain in her vehicle at all times during the transfer of custody. , I 2. 3. The following additional relief is granted: The Cumberland County Sheriff's Department shall attempt to make service at 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 I Prothonotary shall not send a copy of this Order to Defendant by mail. I i I r I ii Law enforcement agencies, human service agencies and school districts shall not disclose the presence of Plaintiff in the jurisdiction or district or furnish any address, telephone number, or any other demographic information about the Plaintiff except by further Order of Court. 2 MEYERS, OESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P,O. BOX 1062 . HARRISBURG. PA 17108 (717) 236.9428 . FAX (717) 236.2817 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 Defendant has committed another act of abuse or has engaged in a pattern or practice that indicates continued risk or harm to Plaintiff. Defendant is required to relinquish to the Sheriff any I firearm license Defendant may possess. Defendant's weapons and firearm license may be returned at the expiration of thel Protection Order after Defendant has submitted a written request to the Court for the return of the weapons and the Court has notified Plaintiff of the request and given Plaintiff an opportunity to respond. A copy of this order shall be transmitted to the chief or head of police department of Cumberland County and the sheriff of Cumberland County. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. Defendant is to refrain from harassing Plaintiff's relatives. 4. A certified copy of this order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Pennsylvania State Police. 5. THIS ORDER SUPERSEDES ANY PFA ORDER AND ~~ PRIOR ORDER RELATING TO CHILD CUSTODY. 6. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SF-ALL REMAI IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months in jail. 23 Pa.C.S. S 6114. Consent of the plaintiff to Defendant's return to the residence shall not invalidate this Order, Defendant may be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence of law enforcement. Subsequent to an arrest, the law enforcement office shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. I Ii Ii Ii 3 MEYERS, DES FOR, SAlTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236_9428 . FAX (717) 236-2817 Weanons must forthwith be delivered to the Sheriff's Office of the-county which issued this Order, which office shall maintain possession of the weapons until further Order of this Court, unless the weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. BY THE COURT, Judge , c; I Cat erine A. Boyle, Attorney for Plainti I I I !I , II Ii 4 MEYERS, DESFOA, SALTZGIVER & BOYLE 410 NORTH SECOND STREET. P,O. BOX 1062 . HARRISBURG, PA 17108 (717) 236-9428 . FAX (717) 236-2817 DAVID A. MANGAM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. BOGUMILA MANGAM, Defendant PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case ma proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on the matter is scheduled for the , 2000 at m., in Courtroom No. of Cumberland County Courthouse, Carlisle, Pennsylvania. day of the You MUST obey the Order that is attached until it is modified or terminated by the court after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six months in jail under 23 Pa.C.S. S 6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. S 2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. S 2261-2262. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEARING. THE COURT WILL NOT, HOWEVER, APPOINT A LAWYER FOR YOU. IF YOU DO NO HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFIC SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YO CANNOT FIND A LAWYER, YOU V~Y HAVE TO PROCEED WITHOUT ONE. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 (717)249-3166 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 reasonablel accommodations available to disabled individuals having business I before the court, please contact our office. All arrangements I must be made at least 72 hours prior to any hearing or business ' 1 before the court. You must attend the scheduled conference or I Ii hearing. I' )) MEYERS, OESFOR, SALTZGIVER & BOYl...E 410 NORTH SECOND STREET. P.O. BOX 1062 . HARRISBURG. PA 17108 (717) 236.9428 . FAX (717) 236.2817 DAVID A. MANGAM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. BOGUMILA MANGAM, Defendant PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name: Bogumila Mangam Defendant's Date of Birth: 9/29/57 Defendant's Social Security Number: 595-38-6310 Name of all Protected persons: David A. Mangam AND NOW, this consideration of the court hereby day of , 2000, upon the attached Petition for Protection from Abuse, enters the following Temporary Order: 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. 2. Defendant is evicted and excluded from the Plaintiff's I residence located temporarily at the Hampton Inn, Mechanicsburg, Cumberland County, Pennsylvania, which is n09 owned or leased by the Defendant, or any other permanent or I temporary residence where Plaintiff may live. Defendant I shall have no right or privilege to enter or be present on the premises, except for the limited purpose of transferrin custody of the parties' children. The Defendant shall remain in her vehicle at all times during the transfer of custody. 3 . The following additional relief is granted: The Cumberland County Sheriff's Department shall attempt to make service at 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 Defendant by mail. i i I I' , ii Law enforcement agencies, human service agencies and school districts shall not disclose the presence of Plaintiff in the jurisdiction or district or furnish any address, telephone number, or any other demographic information about the Plaintiff except by further Order of Court. 2 MEYERS, DESFOR. SALTZGIVER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 2:36.9428 . FAX (717) 236.2817 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 Defendant has committed another act of abuse or has engaged in a pattern or practice that indicaces continued risk or harm to Plaintiff. Defendant is required to relinquish to the Sheriff any firearm license Defendant may possess. Defendant's weapons and firearm license may be returned at the expiration of the[ Protection Order after Defendant has submitted a written request to the Court for the return of the weapons and the Court has notified Plaintiff of the request and given Plaintiff an opportunity to respond. A copy of this order shall be transmitted to the chief or head of police department of Cumberland County and the sheriff of Cumberland County. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. Defendant is to refrain from harassing Plaintiff's relatives. 4. A certified copy of this order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Pennsylvania State Police. 5. THIS ORDER SUPERSEDES ANY PFA ORDER AND ANY PRIOR ORDER RELATING TO CHILD CUSTODY. 6. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAI_ IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $l,OOO.OO and/or up to six months in jail. 23 Pa.C.S. S 6114. Consent of the plaintiff to Defendant's return to the residence shall not invalidate this Order, Defendant may be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence of law enforcement. Subsequent to an arrest, the law enforcement office shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. II !i 3 MEYERS, DESFOR, SALTZG1VER & BOYLE 410 NORTH SECOND STREET . P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236~9428 . FAX (717) 236.2817 Weapons must forthwith be delivered to the Sheriff's Office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this Court, unless the weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. BY THE COURT, Judge , c;, Cat erine A. Boyle, Attorney for Plainti Ii 4 MEYERS, DESFOA, $ALTZGIVER & BOYLE 410 NORTH SECOND STREET. P.O. BOX 1062 . HARRISBURG, PA 17108 (717) 236.9428 . FAX (717) 236-2817 PROTECTION 1'ROM AB'OSlt SHERIFF'S INFORMATION Cue N4l:ll!: David A. Mangam Plaintiff Bogumila Mangam VB. Defendant No'_- crvrL 'l'E:RM HelU"ing DIIte: Judjj;e at .... In Courtroom No. 'Olglrl 3b.. hos ,UaU /le1!tA;;t (24~ ~e;. - - ' '''C' DEFENDANT'S SERVICE ADDRESS(ES) Method of Servl'ce: ___ ~rsonai only Other: HOME: 5818 panav Drive Mechanicsburg, PA 17055 1\ORK : ?hone: (717) 732-5422 Phone' Shift: Oche:-: Phone: DESCRI PTION OF DEFENDANT <l<lnder: Female Reoe : !Ie iiht: Weight: H:air: Age: 41 Eyes: Date of Birth: 9/29/57 DI.tin~~i8hing f~ture.: , TERMS OF TEMPORARY PROTECTION ORDER /' ~ ExcJuelon/Stay Away SPECIAL INSTRUCTIONS: Temporary CUstody Weapons Confis~tlon ", II i r II " J f f II " 'i Ii' J fl f II I, f AI II i J I ' , I I ! I : i I I ! :H I ~ I ~ ~" . "'I i, :1, ~ I I ~ i ~ I ~ '1,12' 'I ! I 1 ~ 1 ~ I ~ I 'Ii I i'~1 ~! I L ~ .. I , :; ~, I' ~ .. i I I ~ i , ~ i "i I I-----' ! I ~, LJ{ , i ii " ! :"1 r LJ 'I i I ~ f i ~ I. I f d t ' .. i I iLL ~ I I "i il II ;1 II U ~Il ", 'I i I ! i J I 1 ~ f~ j, ~ I ~ i I il I I W ! ~ I f I ii~ I !",j h ~~ "I I l f i ~i ~ ~,'.t ' I f: ii, I i liL, II II If/! Ii ~ I ..1..1 I ~ " "I .' , '. I ., g I ~, I I i i . , -I ~ I 1'1 I ~I ~ i fl I I I ! I jl'l I h-JL':~ j r--Ti ~ ~ 7; JI ~I HI ! ~I " II'! ~ i i l' i l' '" , ~ i ~ I I ~ I" i: I f ! ~ I I I" II i II , fl f I II i I I ..1 i ~ ! I r I ~ ~ I I I 0.' i ,if! i " ,. jj ~ I i I -c :;;: o '"' m (j '"'- -.. Oz z~ .,,~ " ;; o~ ~~ J:> ~ CD:;: Co (Jl~ m~ o ~ (Jl :J: m m '"' o C "':l o ~ ni PROTlcr I ON nOM ABOSE SHERIFF'S INFORMATION Csse Name: David A. Mangam Plaintiff vs. Bogumila Mangam ~tellCiant No. c rvrt '\"EFiM Hearinz 04te: Judie at .m. in Courtroom No. "t:;Z!Pi &i.~'i1!lee 11lsi! ~.~t&.:t (~4S 3-+6e~. -- ''';' DEFENDANT'S SERVICE ADDRESS(ES) Method of Service: ___ Personal only Other: HOME: 3818 Panav Drive Mechanicsburg, PA 17055 1\DRK : _ (717)732-5422 ~"on,,: Phone: Sh [ft : Othc:-: Phone: OEseRl PTION OF DEFENDANT Gende,: Female Race: He [iht: Weight: lilliS": Age: 41 Eyes: Date of Birth: 9/29/57 Distin~~i"hir.g features: TERMS OF TEMPORARY PROTECTION ORDER /" ~ Excl~sion/StllY Away SPECIAL P./STRucrroNS: Temporary CUstody weapons Confisc~tion ;! ~ ~ ~. i ~ ~ i: .t:~ ~ ~' < !, r: I 1:.-", Ii II II II ~, ,I 11 :7 i '" 1< I . I ~ I I g , !. I I ~ I i I I U I . I i I : 'Wh1U' Iii I a ,a I i II i Iii Ii i '"I !' ~ II ! ! ~I ; II I i I i ~ "J ~., ' ~ ~ i, ~ ~ 1 fl . ~\ ,.1 , i '::, ~( "" ! J il II J ~ f f I f i f I f i ~ I f il II ti J . tl AI II I I I ! ' I !! I , i I H I ! ~ i. "",.t i : ! I ~ I !i;!-I i l't r ~ a '. ' Ii" I J I ~; r! ,tf-TI ~! It, ~, ~ I : ~ I \ I 1 g I' . ... i ., i I , - U fi I ;:1 I I ~ I ! LJ if l I rl f I to I I ~ I ~ It. , "1 ! Iii! U, cl 11 f ""I ! ~ I:' l i i j,., I j~ ~ J1 ~i .- , I i i " p i~ 'I t ~; if "' ," hJ II J I ~ I I I ~ U I $ I i , II ~, i II ~ I '.' JI I >>ni i I ~ I ~ ! '\11 i ~ I I ,I~i 11~i I' ..1 i-ill i ~. J~:' ~ 'I 0 ; ~ I : cO -'j f l !r-" "~~~, ~' ~ \-0,; , I';l PJ_ t 1i ' to:! I if ~I rJ ) It l 11 ," 1 ~ ',. j ~ I r ~ 1 ,. , 1 ~ 1 : ,>' ~ IJ F , "l tj f I CD 1:1 ~ It; !f,J1 i CD i"l ,t ill !, ji; I .~l ~ "j I ' \ i , I , II i ~ ",.J 0 c:::: "":l o ::: ni " p. -c ;;0 o -I m C") -1- a~ z~ ~ ~ ,,~ 0;; " ~~ J>':: 1Il .." Cd (/l'" m ~ 0' :c> ~ (/l J: m m -I PROTECTION !raOM ABUSE SHERIFF'S INFORMATION Cll8e Name: David A. Mangam Plaint iff VB. Bogumila Mangam \lefendant No._- Headna Oate: Jud&e crvrt 'l'ERM at ,61. in Courtroom No. "tBPi ~u. U'i11!8 staff ac.~t.u;t (243.Aj.40Sj. -~,.-". DEFENDANT'S SERVICE ADDRESS(ES) Method of Sentee: _ p"'raonal onlY Other: HOME: 3818 panav Drive Mechanicsburg, PA 17055 l\URK : ?hon..: (717)732-5422 Phon..: Sh i ft : Other: Phone: DEseRl PTION OF DEFENDANT Gonder: Femal~e Race: !lei&ht: Weight: Hair: Age: 41 Eyes: Date of Birth: 9/29/57 Distinguishing features: TERMS OF TEMPORARY PROTECTION ORDER /' ~ Exclusion/Stay Away Temporary CUstody Weapons Confis~tlon SPECIAL INS'I"RUcrIONS: DAVID A. MANGAM, Plaintiff IN THE COURT OF CO.MMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW BOGUi\1ILA MANGAM, Defendant NO. 2000 - 81 CIVIL TERM ORDER OF COURT AND NOW, this b ftday of January, 2000, upon consideration of the Petition for Protection From Abuse, a hearing is scheduled for January 7, 2000, at II: 15 a.m., in Courtroom No. I, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, Catherine A. Boyle, Esq. 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 Attorney for Plaintiff Bogumila Mangam 3818 Panay Drive Mechanicsburg, PA 17055 Defendant :rc DAVID A. MANGAM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION - LAW BOGUMILA MANGAM, Defendant NO. 2000 - 81 CIVIL TERM ORDER OF COURT AND NOW, this &, ttday of January, 2000, upon consideration of the Petition for Protection From Abuse, a hearing is scheduled for January 7, 2000, at II:IS a.m., in Courtroom No. I, Cumberland County Courthouse, Carlisle, Pennsylvania. BY THE COURT, Catherine A. Boyle, Esq. 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 Attorney for Plaintiff Bogumila Mangam 3818 Panay Drive Mechanicsburg, PA 17055 Defendant :rc , "" BOGUMILA MANGAM, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 99-7746 CIVIL TERM DAVID A. MANGAM, Defendant CIVIL ACTION - LAW PROTECTION FROM ABUSE v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-81 CIVIL TERM ~ DAVID A. MANGAM, Plaintiff BOGUMILA MANGAM, Defendant CIVIL ACTION - LAW PROTECTION FROM ABUSE ORDER OF COURT AND NOW, this 7th day of January, 2000, upon consideration of the P-etition for Protection from Abuse filed at No. 99-7746 Civil Term and of the Petition for Protection from Abuse filed at No. 2000-81 Civil Term, and pursuant to an agreement reached in court among the parties and their respective counsel, Catherine A_ Boyle, Esquire, on behalf of David A. Mangam, and Matthew J. Eshelman, Esquire, on behalf of Bogumila Mangam, it is ordered and directed as follows: 1. The parties have agreed to enter reciprocal consent orders. The order shall be without admission of wrongdoing or liability in terms of the definition of abuse as set forth in the Domestic Relations Code. 2. Each party specifically stipulates that they shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found, particularly with reference to the definition of abuse a~ set forth in the Domestic Relations Code. 3. Husband, David A. Mangam, is evicted and excluded from the marital residence located at 3818 panay Drive, Mecharricsburg, CUml:lerland county, pennsylvania, 17055, which property is owned by the parties, and any other permanent or ~ ~ temporary residence where wife, Bo Mangam, may reside. Likewise, wife, BoMangam, is evicted and excluded from the husband's residence,located at 521 Barry Court, Mechanicsburg, Cumberland County, Pennsylvania, 17055. Neither party shall have the right or privilege to enter or be present on the premises previously described except for the limited purpose of transferring custody of the parties' children. Whichever party shall be dropping off the child at a period of an exchange of custody shall remain in their vehicle during the transfer of custody. 4. The parties further stipulate to negotiate through counsel a date and time for husband, David A. Mangam, to be,present at the marital residence with a law enforcement officer, such as a constable or other individual, at the cost of Mr. Mangam, to jointly go through the personal property contained in the marital residence for the purpose of specifically allowihg Mr. Mangam to pick up any personal effects which may specifically be his, any property which is jointly agreed to be nonmarital property, and any other such property as the parties may mutually agree. The parties will further agree that they will make attempts to exchange in advance lists of specific personal property to minimize any difficulties at the time of the exchange. Wife, Bo Mangam, specificall~ agrees not to permanently remove any items of personal property from the marital residence prior to the exchange takingUplace. 5. Contact between the parties shall be limited to the express purpose of discussing the welfare and/or exchange of the children. 6. Each party is prohibited from entering the place of employment, business or school of Bo Mangam, ~IJavid A. Mangam or Caroline A. Mangam, and from harassing, abusing, threatening or stalking the wife, Bo Mangam, or the minor children, Caroline A. Mangam and/or Victoria O.-Mangam. 7. The wife, Eo Mangam, is awarded temporary primary physical custody of the minor children, Caroline A. Mangam and Victoria o. Mangam, subject to periods of partial physical custody and/or visitation as follows: The parties have agreed that they shall share legal custody of both children. 8. The parties have agreed that primary physical custody of Victoria Mangam shall be with mother subject to periods of partial physical custody in father as follows: Father shall have every other weekend, beginning from Friday after school until Sunday evening at 8:30 p.m. Beginning January 12, 2000, father shall have custody 01 Victoria from after school until 8:30 p.m. and every other Wednesday thereafter. BeginnIng January 19, 2000, father shall have custody of Victoria from 6:00 p.m. until Thursday morning when the child begins school and every other Wednesday thereafter. 9. The parties have agreed to a holiday schedule as follows: (1) Easter shall be with spent with mother every year. (2) Thanksgiving shall be spent with father every year. (3) The parties have agreed to alternate the following major holidays: Memorial Day, Fourth of July, Labor Day, New Years Day, and Victoria's birthday. This alternating holiday schedule.. will occur such that mother shall have Memorial Day 2000 and alternate thereafter. The time for the holiday custody shall be from 9:00 a.m. until 8:30 p.m. (4) Christmas holidays shall be broken into two segments. Segment_A shall occur from after school, when the child is dismissed for Christmas break, until 2:00 p.m. Christmas Day. Segment B shall occur from 2 :_00 p. m. on Christmas Day until 6:00 p.m. December 27th. Father shall have Segment A in 2000 and all even numbered years thereafter. (5) Each year Mother's Day shall be spent with mother and Father's Day shall be spent with father. Periods of custody will be from9~00 a.m. until 8:30 p.m. (6) The parties acknowledge tEftt Victoria shall have other days off from school not specifically mentioned in the agreement. The parties agree to alternate these days and have custody from 9:00a.m. until 8:30 p.m. unless otherwise agreed. Mother has agreed to provide a copy of the child's school schedule to father as soon as possible. (7) Each party shall have three uninterrupted weeks through the summer vacation, which weeks shall not be exercised consecutively. Notice of when the party intends to exercise his or her summer custody schedule shall be provided to the other party no later than thirty days ahead of time. The holiday at summer schedules shall supersede the weekly custody arrangement previously dictated. (B) The alternating weekends schedule with father shall commence Friday, January 14, 2000. 10. The husband shall pay temporary support to the wife in the amount of $2,150:00 per month, payable on the 15th day of each month, and allocated as follows: $1,360.00 per month is child support, $240.00 per month spousal support, and $550.00 p~r month mortgage contribution. These amounts are ordered without prejudice to either party in a determination of ., long term support at a later date. Wife shall have filed a complaint for support at the Office of Domestic Relations within ten days. 11. This order shall remain in full force arid effect for a period of one year from today's date. 12. A copy of this order shall be forthwith filed in the county and statewide registries of protection orders. Copies shall also be provided to the Sheriff of Cumberland County, the Prothonotary of Cumberland County, counsel for_ husband, counsel for wife, - -ana-the Hampden Township Police Department. Service shall be made by counsel for wife. 13. The parties are hereby notified that violation of this order may result in arrest' for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months in Hj ail. 23 Pa. C. s. Section 6114. Consent of. either party to resume cohabitation shall not invalidate this order. Either party may be arrested on the charge of indirect criminal contempt thereby. An arrest for viQlation of this order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence of a law enforcement officer.' 14. This order shall supersede any prior order of this court with respect to. protection from abuse and/or child custody. 15. For registratio~purposes, husband's name is David A. Mangam. His date of birth is August 9, 1943. His Social Security number is 08-934-5288. Wife's name is Bogumila Mangam, also known as Bo Mangam. Her date of birth is September 29, 1957. Her Social Security number is 59-538-6310. ... ,. - . By the Court, CatherineA. Boyle, Esquir Attorney for David A. Mangam Matthew Eshelman-,- Esquire Attorney for Bogumila Mangam Sheriff :srs I , ~-"_.,, --- ~'.~-~;.--,;-, ~---,.. .- .-:---': . - FlLED-oFFJCE OF Ti-iS: C'AOl)fONOTARY 00 JAN /2 AM 10: 18 CUtviBERLAND COUN7Y PENNSYLVANIA - -~-~.~::.; ~.t':;r,;