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HomeMy WebLinkAbout00-00135 DONNA JEAN SKEENS, Plaintiff for herself and her minor child, HEATHER ANN STRUDER, vs. JOHN JOSEPH SKEENS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000- 1.~5 Crvn.. TERM : 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 may 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. . -vv A hearing on this matter is scheduled on the f 3' day of January, 2000, at /1 . t~,) /~' .iD.., in Courtroom No. ~ of the Cumberland County Courthouse, Carlisle, Pennsylvania. . 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 poliee 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. ~6 I 14. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under fuderallaw, 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 have the right to have a lawyer represent you at the hearing. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. If you cannot find a lawyer, you may have to proceed without one. CUM:I;lERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, Pennsylvania 17013 Telephone Number: (717)249-3166 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 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. " . FILED-CI"FICE OF ,T{<~ F,~(':h::'(;~'_ln""'j.^DY - -. -.J .'"t.r\ "'0 J-" ~ U t:;~_- -- J _ _"-l'>'-. . FH 12; n2 CUM8E.FiLiJiIo COUNTY. PENNSYLVANIA - . , --,:i: ;':--.=.. '4" -4 ~ ~. "-''', ~,;.- .._~ '..~"""--"- ., ~-~-~~.,..~ 'l... ct ; ij c." '< JJ .., +.: - --'! ~~-~~ DONNA JEAN SKEENS, Plaintiff for herself and her minor child, HEATHER ANN STRVDER, vs. JOHN JOSEPH SKEENS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000- I ,~ CIVlL TERM : PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name: JOHN JOSEPH SKEENS Defendant's Date of Birth: 01/05/1966 Defendant's Social Security Number: 496-84-7146 Names of Protected Persons: DONNA JEAN SKEENS, and her minor child, ~ HEATHER ANN STRUDER AND NOW, thiS~ I day of January, 2000, upon consideration of the attached Petition for Protection from Atfu;e, the court hereby 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. o 2. Defendant is evicted and excluded from the residence at _ or any other permanent or temporary residence where Plaintiff may live. Plaintiff is granted exclusive possession of the residence. Defendant shall have no right or privilege to enter or be present on the premises. ~ 3. Defendant is prohibited from having ANY CONTACT with Plaintiff at any location, including, but not limited, to any contact at Plaintiff's current residence, and any other residence she may, in the future establish for herself, her place of employment, and/or the minor child's school. Defendant is specifically ordered to stay away from the following locations for the duration of this Order: Plaintiff's residence, place of employment, and the school of the minor child, which are at nndisclosed locations for the protection and safety of Plaintiff and her child. This information shall be made available to the Court and/or appropriate law enforcement agencies upon reqnest. l&> 4. Defendant shall not contact Plaintiff by telephone or by any other means, including through third persons. o 5. Pending the outcome of the :final hearing in this matter. Plaintiff is awarded temporary custody of the following minor child/ren: Until the :final hearing, all contact between Defendant and the child/ren shall be limited to the following: The local law enforcement agency in the jurisdiction where the child/ren are located shall ensure that the child/ren are placed in the care and control of Plaintiff in accordance with the terms of this Order. 129 6. Defendant shall immediately relinquish the following weapons to the Sheriff's Office or a designated local law enforcement agency for the delivery to the Sheriff's Office: any and all firearms and/or weapons, specifically, two handguns (Defendant keeps one handgun concealed in the glove box of his vehicle, and the other handgun, which Defendant refers to as a "throw-away" (an nnregistered handgun with unidentifiable serial nnmbers), is kept at the residence of Defendant's father, Joseph Skeens, 601 Sunnyside School Road, Blue Springs, Jackson County, Missouri, (Telephone: (816) 220-7755), and the folding knife Defendant carries concealed on his person. 129 7. 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 offees, 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 ofthis Order to Defendant by mail Law enforcement agencies, human service agencies and school districts shall not disclose the presence of Plaintiff and/or her child in the jurisdiction or district or furnish any address, telephone number, or auy other demographic information about Plaintiff and/or her child except by further Order of Court. This Order shall remain in effect until modified or terminated by the Court and can be extended beyond its original expiration date ifthe Court finds that Defendant has committed an act of abnse or has engaged in a pattern or practice that indicates risk of harm to Plaintiff and/or her minor child. Defendant is required to relinqnish to the sheriff any f"rrearm license Defendaut 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 reqnest and given Plaintiff an opportunity to respond. A copy ofthis Order shan be transmitted to the chief or head of the police department of Blue Springs, Jackson County, Missouri, where Defendant resides, and the sheriff of Cumberland County. Defendaut is enjoined from damaging or destroying auy property owned jointly by the parties or owned solely by Plaintiff. Defendant is to refrain from harassing Plaintiff's relatives or her minor child. I:&> 8. A certified copy ofthis Order shan be provided to the police department where Plaintiff resides and any other appropriate agency. I:&> 9. THIS ORDER SUPERSEDES ANY PRIOR PFA ORDER. ANY PRIOR ORDER RELATING TO CHILD CUSTODY I:&> 10. THlSORDERAPPLIESIMMEDIA TEL YTODEFENDANT AND SHALL REMAIN 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, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa. C.S.~6113. Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C.~~2261-2262. Any protection order granted by a court may be considered in any subsequent proceedings, including child custody proceedings, under title 23 (Domestic Relations) of the Pennsylvania Consolidated Statutes. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over Plaintiffs residence OR any locations where a violation of this order occurs OR where Defendant may be located. If Defendant violates Paragraphs 1 through 6 of 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 oflaw enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. 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. Joan Carey Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 DONNA JEAN SKEENS, Plaintiff for herself and her minor child, HEATHER ANN STRUDER, vs. JOHN JOSEPH SKEENS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000- 1.35 CIVIL TERM : PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE 1. Plaintiff is Donna Jean Skeens. 2. Plaintiff files this Petition for herself, and on behalf of her minor child, Heather Ann Struder. 3. The names ofthe persons who seek protection from abuse are Donna Jean Skeens and Heather Ann Struder. 4. The address of Plaintiff and her minor child is undisclosed for their protection and to avoid further abuse. 5. Defendant's address is 1417 Northwest Foxboro Road, Blue Springs, Jackson County, Missouri 64015. Telephone: (816) 228-9440. Defendant's Social Security Number is 496-84-7146. Defendant's date of birth is 01/05/66. Defendant's place of employment is Molle Toyota Body Shop, 601 West 103" Street, Kansas City, Jackson County, Missouri. Telephone: (816) 942-5200. 6. Defendant is Plaintift's estranged husband. 7. Plaintiff and Defendant are involved in the following court action: Case Name Skeens v. Skeens (Divorce) Case No. 99-FC209787 NO.7 Date Filed 12/02/99 Court Circuit Court of Jackson County, Missouri at independence 8. The facts of the most recent incident of abuse are as follows: Approximate Date: Place: On or about October 13, 1999 1417 Northwest Foxboro Road, Blue Springs, Jackson County, Missouri, the marital residence. On or about October 13, 1999, Defendant yelled at Plaintiff's 13 -year old daugher, Heather, called her vile names, and when she tried to use the telephone to call Plaintiff for help, Defendant refused to let her use the telephone. When Plaintiff returned home from work, her daughter was frightened and crying uncontrollably, traumatized by the incident. Fearing for their safety, Plaintiff took her daughter and left the marital residence on or about October 18, 1999, while Defendant was at work, and moved to an undisclosed location in Pennsylvania for their protection. Since Plaintiff left Defendant, he has repeatedly telephoned her friends, relatives, and businesses where the parties have accounts in attempts to locate her whereabouts. In or about mid-Deeember 1999, Defendant discovered where Plaintiff lives causing her to fear for her safety and that of her daughter since Defendant had threatened to find her and kill her if she ever left him. 9. Defendant has committed the following prior acts of abuse against Plaintiff and/or her minor child: a) From approximately 1994, until October 18, 1999, Defendant has abused Plaintiff and/or her minor ehild in ways including., but not limited to, shoving, grabbing, slapping, pulling their hair, dragging Plaintffby her hair, and kicking Plaintiff about her back and hips while wearing combat boots. Defendant threw objects such as a remote control, drinking glasses, a vacuum cleaner, shoes, a pot of boiling water, and lit cigarettes at her. Defendant spat in Plaintiff and her daughter's face, poured beer over Plaintiff's head, restrained her by pinning her against walls, prevented her from leaving rooms, cut telephone lines, intimidated her and her daughter several times a week by pointing his finger at them like a gun, and making the sound of a the hammer cocking, and drawing his finger across his neck to mimick a knife cutting someone's throat. Defendant threatened Plaintiff several times a month telling her that if she ever tried to leave him or betrayed him, he would kill her. Defendant threatened to shoot Plaintiff's daughter, Heather, and threatened to slit Plaintiff's brother's throat. In addition, Defendant held a loaded gun to Plaintiff's head on several occasions, held a knife to her throat several times while threatening to kill her, threatened to throw gasoline on the car and ignite it whether she was in the car or not if she tried to take it. Defendant also threatened to kill Plaintiff and dispose of her body in the Missouri River so that it would never surfuce, and repeatedly referred to his ties to organized crime and his ability to have Plaintiff; her family members, and her pastor "taken care of', and threatened to have her car and/or the house blown up. b) In or about January 1999, Defendant held a knife (the knife that he carries eonceaied on his body) against her neck and threatened her saying, "I'll kill you." Plaintiff feared for her life. c) In or about March 1991 when Plaintiff told Defendant that she was going to leave him, he held a loaded .357 handgun against the temple of her head and threatened her saying, "Now try to leave me. You're just like all the other women in my life, wanting to leave." Plaintifffeared that Defendant was going to kill her. d) In or about March 1997, in the presence of Plaintiff; her then 1 O-year -old daughter, and his parents, Defendant pulled a loaded handgun from behind him as he sat on the couch, brandished the gun in a threatening manner, threatened Plaintiff saying, "Now say what you had to say." Fearing for their safety, Plaintiff and her daughter went outside. A few moments later they heard a gunshot from inside the house. Plaintiff's daughter telephoned 911 for help. When the police arrived, they called an ambulance to transport Defendant to the hospital after finding he had shot himself in the foot. e) In or about December 1995, as Plaintiff drove her daughter, Heather (8 years old) and Defendant home, he repeatedly grabbed the steering wheel causing the car to veer treacherously about the road, and causing Plaintiff to fear for her safety and that of her child, who was crying. Once inside the house, Defendant slapped Plaintiff about the face and head several times causing her to full onto the bed. Heather, who witnessed Defendant hitting her mother, was traumatized by the scene. When Defendant left the room, Plaintiff tried to comfort her child and take her to her room. As Plaintiff stepped into the hallway, Defendant threw a heavy glass kniek-knack at her hitting her on the foot with such impact that she fell to the floor writhing in pain. Plaintiff's child wanted to call for help, but Defendant cut the telephone line and threatened them saying, "You're not calling anyone." As Heather tried to make Plaintiff comfortable on the couch, Defendant screamed at Plaintiff; picked up a heavy wooden coffee table and raised it in the air to throw it at her, but threw it away from her when the child stepped in front of her mother to protect her. Defendant grabbed the fully decorated Christmas tree and threw it over the stair railing. The following day Plaintiff sought medical attention for injuries she sustained as a result of this incident which included, but were not limited to, broken bones in her foot; bruising, swelling and soreness about her foot; soreness and swelling about her head and the side of her face; ringing in her ears, and headaches. t) In or about 1995, during an incident Defendant repeatedly shoved Plaintiff about the house, causing her to fall against fumiture and fall to the floor at least twice. Plaintiff sustained bruising, swelling and soreness about her arm from her wrist to her elbow as a result ofthis incident. g) In or about January 1995, Defendant threw a plate offood against the fireplace, went into the bedroom, pulled Plaintiff's clothing out of the closet, stabbed and cut the garments repeatedly with the Irnife he carries, rendering the clothing unwearable, and tlrreatened Plaintiff saying, "This is what you get." Then Defendant threw Plaintiff's clothing into the fireplace, doused it with lighter fluid, and set it afire. When Plaintiff said that she was leaving, Defendant told her that he would only allow her to leave if her brother came to get her, knowing that she would not call him. Plaintiff told Defendant that she would not endanger her brother because of Defendant' s repeated tlrreats to harm and/or kill him. Defendant threatened her saying, "That's right. If your brother is stupid enough to come here. . ." and drew his finger across his neck mimicking a knife slitting his throat, causing Plaintiff to fear he would kill her brother. As Plaintiff picked up the telephone book to call for a taxi, Defendant grabbed the telephone book, and tlrrew it at Plaintiff hitting her on the face with it. Plaintiff sought medical attention and was treated for a scratched cornea on her eye which she sustained as a result of this incident. 10. Defendant has used or threatened to use the following firearms and/or specific weapons against Plaintiff and/or the minor child: any and all firearms and/or weapons, specifically: two handguns (Defendant keeps one handgun concealed in the glove box of his vehicle, and the other handgun, which Defendant refers to as a "throw-away" (an unregistered handgun with unidentifiable serial numbers), is kept at the residence of Defendant' s father, Joseph Skeens, 601 Sunnyside School Road, Blue Springs, Jackson County, Missouri, (Telephone: (816) 220-7755), and the folding Irnife Defendant carries concealed on his person. 11. The appropriate police departments or law enforcement agencies in the area in which Plaintiff lives will be provided with a copy of the Protection Order. 12. There is an immediate and present danger of further abuse from Defendant. 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 and/or her minor child in any place where they may be found. B. Prohibit Defendant from having any contact with Plaintiff and/or her minor child, either in person, by telephone, or in writing, personally or tlrrough third persons, Date: including, but not limited to, any contact at Plaintifl:'s current residence, and any residence she may, in the future, establish for herself, her school, business, and/or her place of employment, and/or the school of her minor child. C. Prohibit Defendant from having any contact with Plaintifl:'s relatives. D. Order Defendant to temporarily turn over firearms and/or weapons to the Sheriff of this County and prohibit Defendant from transferring, acquiring or possessing any such firearms and/or weapons for the duration of the Order. E. Order Defendant to pay the costs of this action, including filing and service fees. F. Order Defendant to pay $250.00 to reimburse one of Legal Services, Inc.'s funding sources toward the cost of litigation in this case. G. Order the following additional relief, not listed above: 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. 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 and/or Plaintiff's minor child. H. Grant such other relief as the court deems appropriate. L Order the police or other law enforcement agency to serve 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. /-& -0-0 Respectfully submitted., () /7i / ~vG:!v~/ oan Carey, Attorney t3r Plaintiff LEGAL SERVICES, INC. 8 Irvine Row, Carlisle, P A 17013 (717)243-9400 . VERIFICATION I veriJY that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S.~4904, relating to unsworn falsification to authorities. Dated: I zjz9l19 d/ ~ r?/: '#%/iM ( , .) ~Ut;?:;.-- Donna Jean Sk s, PlamtIff DONNA JEAN SKEENS, Plaintiff for herself and her minor child, HEATHER ANN STRUDER., vs. JOHN JOSEPH SKEENS, Defendant : ffi THE COURT OF COMl\1bN PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA : NO. 2000-135 CIVIL TERM : PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, thi~ day of January, 2000, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on January 13, 2000, by this Court's Order of January 7,2000, is hereby rescheduled for hearing on February 18, 2000, at 9:30 a.IlL in Courtroom NO.3. The Temporary Proteetion From Abuse Order shall remain in effect for a period of one year from - the date it was entered, through January 7,2000, oruntiI further Order of Court, whichever comes first. A certified copy of this Order for Continuance shall be provided to the appropriate poliee departments by Plaintifl's attorney. Joan Carey LEGAL SERViCES, INe. Attorney for Plaintiff _ _ _ C~~'f ,'cs ~c.0!:L{ (y ~~ _ ;P7/0::) Q = - (:) c- o ~n ~.,.. -06 '- ~~ -' ". 52fT.'! Z ( .'1::0 z:J' - r- r;:- N ~~~ P=1 ~--:::- -.J d~ r:: c; ;::;j ,I ;,;: -e !Q" :x - n:~ .. .~ - 5(") pO r::? om c: Z -I - ~ => s (J1 -< DONNA JEAN SKEENS, Plaintiff for herself and her minor child, HEATHER ANN STRUDER, vs. JOHN JOSEPH SKEENS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-135 CIVIL TERM : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff; Donna Jean Skeens, by and through her attorney, Joan Carey of Legal Services, Inc., moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: L A Temporal)' Protection From Abuse Order was issued by this Court on Janual)' 7, 2000, scheduling a hearing for Janual)' 13, 2000, at 11 :00 a.m. 2. The Cumberland County Sheriff's Department mailed a certified copy of the Temporal)' Protection From Abuse Order and Petition for Protection From Abuse to Defendant at his residence at I417NWFoxboro Road, Blue Springs, MO 64015. 3. Legal Services, Inc. staff contacted the Cumberland County Sheriff's Department on Janual)' 12, 2000, and was told that the Return Receipt from the certified mailing of the Temporal)' Protection From Abuse Order and Petition for Protection From Abuse had not been returned to their office. 4. Plaintiff requests that the hearing be rescheduled pending service of the Defendant, and that the Temporary Protection From Abuse Order remain in effect for a period of one year from the date it was entered, through January 7, 2001, or until further Order of Court, whichever comes first. 5. Certified copies of the Order for Continuance will be delivered to the appropriate police departments by the attorney for Plaintiff. WHEREFORE, Plaintiffrequests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary ProtectionFrom Abuse Order remain in effect for a period of one year from thedateitwas entered, through January 7,200 I, or until further Order of Court, whichever comes first. ~R~SPectfully submitted, ! I /; 6;X../ U "" ./.fo'im Carey, Attorney:fi Plaintiff /' LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ~ "'J ~ u:: =,. f--' :::J<( --~--~ - ~ ~q 82 L --~ ~ -- - _C~J :c o~ H-:r: '""" :g~-~: ~i -~ \.D ~c,.. N 8J D:.\;-- -".. ~- :n _ . .. F :2 -,- ,,- o. a <:) 0 . SHERIFF'S RETURN - U.S. CERTIFIED MAIL * CASE NO, 2000-00135 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SKEENS DONNA JEAN ETC VS. SKEENS JOHN JOSEPH R. Thomas Kline Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law served the within named DEFENDANT ,SKEENS JOHN JOSEPH by United States Certified Mail postage prepaid, on the 7th day of January ,2000 at 0008:00 HOURS, at 1417 NW FOXBORO ROAD BLUE SPRINGS, MO 64015 1 a true and attested copy of the attached PROTECTION FROM ABUSE Together with NOTICE OF HEARING & ORDER, TEMPORARY PROTECTION FROM ABUSE ORDER The returned receipt card was signed by JOHN J. SKEENS 01/11/2000 on Additional Comments: Sheriff's Costs: Docketing Service Certified Mail Surcharge 18.00 .00 5.46 10.00 .00 33.46 S~~_~~ ~~ -- .~~ /'R. Thomas Kl ine Sheriff of Cumberland County Paid by on 01/19/2000 . Sworn and subscribed to before me this :i~ day of 3"~ 02c"7Ji::; A.D. Cku- f:i fMd;...~ ~. othonotary I .-~-,.,-"~,~~-- C? () lJ() -/.~ '/v,'L ~ SENDER: '~ ~ ~ ~ > ~ ~ ;; " o '0 ~ '$ Q. E o o 1 also wish to receive the follow- ing services (for an extra fee): ,; o '> :;; '" 0. 0; o ~ 0: c ~ '$ 0: '" c 7Ji c ~ .E c o ,.. '" " " t= 1. 0 Addressee's Address 2. 0 Restricted Delivery article number. ered and the date :7&3 72.2 4b. ServIce Type @ Registered o Express Mail o Return R.eceipt for Merchandise $ertifled o Insured DeOD 1<0 7. Date of Delivery ,JJ /-/I-Cn::> T 8. Addressee's Address (Only if requested and fee is paid) 102595-99-8-0223 Domestic Return Receipt -- ----- - -- -~- -- -- DONNA JEAN SKEENS, Plaintiff for herself and her minor child, HEATHER ANN STRUDER, vs. JOHN JOSEPH SKEENS, Defendant - :IN THE COURT OF COMMON PLEAS OF -. - : CUMBERLAND COUNTY, PENNSYLVANIA ___ : NO. 2000c135 CML TERM : PROTECTION FROM ABUSE AND NOW, this d y of February, 2000, upon consideration of the attaehed Motion for Continuance, the matter scheduled for hearing on February 18, 2000, by this Court's Order of January 27, 2000, is hereby rescheduledfor hearing on March 27,2000, at 10:00 am. in Courtroom No.3. The Temporary Protection From Abuse Order shall remain in effect for a period of one year from the date it was entered, through January 7, 2000, oruntil further Order of Court, whichever comes fIrst. ~ -7 C ~ _c Z l': !~,~ ~ 8s:; -~.'(: o~ ,--'.-~ G.-_ _::::>: "AF_- CD ~~ Uj~:~ "'"" - o:.:z Joan~anfY1 Aj~ LEq~L ~R~!CES, INC. _ AttOrney fOr Plarntiff tJudge - - -- -, - - -. -Coprcs - ~a.J~{ly GtOC0 e-/-, LS-- John Joseph Skeens Defendant f- -- ----------- "- - - - -- ---~---~ ~ . DONNA JEAN SKEENS, Plaintiff for herself and her minor child, HEATHER ANN STRUDER, vs. JOHN JOSEPH SKEENS, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-135 CIVIL TERM : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff, Donna Jean Skeens, by and through her attorney, Joan Carey of Legal Services, Inc., moves the Court for an Orderrescheduling the hearing in the above-captioned ease on the grounds that: I. A Temporary Protection From Abuse Order was issued by this Court scheduling a hearing for Februaryl8, 2000. 2. Serviee was not been effeeted upon Defendant. 3. Plaintiff requests that the hearing be reseheduled pending serviee of the Defendant, and that the Temporary Proteetion From Abuse Order remain in effeet for a period of one year from the date it was entered, through January 7, 2001, or until further Order of Court, whichever comes first. WHEREFORE, Plaintiff requests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in effect for a period of one year from the date it was entered, through January 7,2001, or until further Order of Court, whichever comes first. Respeetfully submitted, r& I7i '-tt.--"~J ~~, v. oan Carey, Attorney for intiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 "- N ->- C.r: tr: C ;:<; -"'- -', M ::ls:; I! _ C)- .{ j" ....-~Z --""-( '-'<( '-, ii: ,-....-:> y'f':- 's'5::' r~,....~ '0 ':5~ = cc 0 '.Uv - '-'.1 .'}..)Q 1--. ~ "S ~- C> 3 '--' Cl () . --.r-r. o .._-~ '-'='-~c :. ~.. " :!.. .~ -~ ."-" ~ ~. ~.:. IN THE CIRCUIT COURT, OF JACKSON COUNTY, MISSOURI CASE DESCRIPTION: DONNA JEAN SKEENS V JOHN JOSEPH SKEENS COURT CASE NUMBER: 2000-135 FOREIGN CASE NUMBER: CIVIL PROCESS AFFIDAVIT . of lawful age, being first duly sworn, on my oath state that I am a Deputy Court Administrator employed as a process server for the Circuit Court of JACKSON County, Missouri: that the Court Administrator is vested with the authority I, --ri reS" !k,ASIm to exe.cute process in JACKSON County pursuant to Article VI of the JACKSON County, Missouri Constitutional Home Rule Charter; and that I executed this ORDER FOR CONTINUANCE, NOTICE OF HEARING & ORDER, TEMPORARY PROTECTION FROM ABUSE ORDER, NOTICE OF LAW ENFORCEMENT OFFICIALS, PETITION FOR PROTECTION , PERSONAL SERVICE: By delivering a copy of same personally to defendant o MEMBER OF F AMIL Y: By leaving a copy thereof at the dwelling place or usual place of abode of the within-named defendant, by leaving with . who stated he/she was a member of the detendant's family over the age of 15 years. D CORPORA TIONMPERSON IN CHARGE: By leaving a copy of same at the business office of the within-named corporation, . with . who said he/she was the person having charge thereof. o CORPORATION-OFFICER OR AGENT: By delivering a copy of same to the within-named corporation, . by serving o NON-EST: . who said he/she was By making a diligent search for and failing to fmd the within-narned .defendant, , for the reason that I Place of Service: Date of Service: I i Time of Service: I 60 I '10, If) 3 r.(. 3-~..-oO / e:;., .s :2- ~C/1'"I1o DAM ?M COURT ADMINISTRATOR'S OFFICE DEPARTMENT OF CIVIL PROCESS Bv' Subscribed and sworn to before me on '"j.. yo c7-dc70 ',~'"""~~:",o:."'-,-V_"""":'_-~0~~~. _---""' ~ " !'lOT ARY SeAL ~ <0." My Commission ~x~iresS~:irlrg l:ltz;:bj~:-:.:;. ".:ot:J-j rtlb:i" r<. I S Clay County, State of Missouri i e. ;',,;; C':Jil1mi sf n Fm' g::;l1 ~~~-"':~"'._"~"'.-~""'''''''r'~.'.''''~'''''''~~~...s '-- j7 ~r~tJ13L(~~~ ~ CIRCT 3030-5/89 6: N ?::: r.n Z ~ N ::::><( b Oz BZ -,;- u~ --0 ;;,- ;::)~ fi:;:L 96 ..,. -= ..~W ~g= 52 :-;--: o::z 0::: LWLU tI.:~~ ."" IX) a.. .. j:!:: :i:: 2: u.. C> :::> 0 0 Q , , " " '. DONNA JEAN SKEENS, : IN THE COURT OF COMMON PLEAS OF Plaintiff for herself and on behalf of her minor child, : CUMBERLANIT COUNTY, PENNSYL V ANlA HEATHER ANN STRUDER, vs. : NO. 2000-135 CIVll.. TERM JOHN JOSEPH SKEENS, Defendant : PROTECTION FROM ABUSE FINAL PROTECTION ORDER Detendant's Name: JOHN JOSEPH SKEENS Defendant's Date of Birth: 01/05/1966 Defendant's Social Security Number: 496-84-7146 Names of Protected Persons: DOEA JEAN SKEENS, for herself, and on behalf of her minor child, HEATHER ANN ~PrUl\R AND NOW, this H day of March, 2000, after hearing on the matter and finding that Defendant has abused Plaintiff as defined in 23 Pa. C.S.A. ~6102 it is ORDERED, ADJUDGED, and DECREED as follows: Plaintif'I: Donna Jean Skeens, is represented by Joan Carey ofLegaI Services, Inc.; Defendant, is unrepresented, but has been advised of his right to counsel in this matter. I:&> Plaintiff's request for a Final Protection Order is granted. o Plaintiff's request for a Final Protection Order is denied. [g) 1. Defendant shall not abuse, stalk, harass, threaten Plaintiff or any other protected person in any place where they might be found. o 2. Defendant is completely evicted and excluded from the residence at or any other residence where Plaintiff may live. Exclusive possession of the residence is granted to Plaintiff Defendant shall have no right or privilege to enter or be present on the premises. ~ - Fili:D-,Q~"'Fn= I't- /'r'''- r~ v_ ~ ,r::- ,~"m_'O\(OTARY 00 ?1~R 27 PH 3: 59 , - CUlv!SgFiL4ND COUNli' ' Pt;N/VSYLVANiA ----.~~~~ -~ ;;: '. ;,--~ .-:--:..:. ~ - -'" - '. " " "--0-_,1 -.>::- 4' !f; .....~-.( ~ ~~ , II!: ~11 } . ~ ..- , r .- _ - ~ "i -" :~ 1 . L~ " ' -," ". '. '. D On_ at _.m., Defendant may enter the residence to retrieve his/her clothing and other personal effects, provided that Defendant is in the company of a law enforcement officer when such retrieval is made. [&> 3. Defendant is prohibited from having ANY CONTACT with the Plaintiff and/or her minor child at any location, including, but not limited to, any contact at the Plaintiff's current residence, and any other residence she may, in the future, establish for herself, her school, business, or her place of employment and/or the school of her minor child. [&> 4. Defendant shall not contact the Plaintiff and/or her minor child by telephone or by any other means, including third parties. D 5. Custody of the minor children, shall be as follows: or (see attached Custody Order) D 6. Defendant shall immediately turn over to the Sheriff's Office, or to a local law enforcement agency for delivery to the Sheriff's Office, the following firearms and/or specific weapons used or threatened to be used by Defendant in an act of abuse against Plaintiff and/or the minor child/ren: D 7. Defendant is prohibited from possessing, transferring or acquiring any other firearms and/or specific weapons for the duration of this Order. Any firearms and/or weapons delivered to the sheriff under Paragraph 6 of this Order or under Paragraph 6 of the Temporary Order shall not be returned until further Order of Court. [&> 8. The following additional relief is granted as authorized by ~61 08 of this Act: Law enforcement agencies, human service agencies and school districts shall not disclose the presence of Plaintiff and/or address, telephone number, or any other demographic information about Plaintiff and/or her minor child, except by fnrther Order of Court. 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 an act of abuse or has engaged in a pattern or practice that indicates risk of harm to Plaintiff and/or her minor child. Defendant is prohibited from possessing any .......earms and/or weapons in the State of Pennsylvania. Defendant is enjoined from damaging or destroying any property ownedjointIy by the parties or owned solely by Plaintiff. .' '. '. '. Defendant is to refrain from harassing Plaintiff's relatives. o 9. Defendant is directed to pay temporary support for _ as follows: _' This Order for support shall remain in effect until a final support order is entered by this Court. However, this Order shall lapse automatically if Plaintiff does not file a complaint for support with the Court within fifteen (15) days ofthe date ofthis Order. The amount ofthis temporary order does not necessarily reflect Defendant's correct support obligation, which shall be determined in accordance with the guidelines at the support hearing. Any adjustments in the final amount of support shall be credited, retroactive to this date, to the appropriate party. o 10. The costs of this action are waived as to Plaintiff and imposed on Defendant. o 11. Defendant shall pay $_ to Plaintiff as compensation for Plaintiff's out -of-pocket losses, which are as follows: OR o Plaintiff is granted leave to present a petition, with appropriate notice to Defendant, to requesting recovery of out-of-pocket losses. The petition shall include an exhibit itemizing all claimed out-of-pocket losses, copies of all bills and estimates of repair, and an Order scheduling a hearing. No fee shall be required by the Prothonotary's office for the filing of this petition. o 12. BRADY INDICATOR o I. The Plaintiff or protected person/s is a spouse, former spouse, a person who cohabitates or has cohabited with Defendant, a parent of a common child, a child of that person, or a child of Defendant. o 2. This Orderis being entered after a hearing of which Defendant received actual notice and had an opportunity to be heard. o 3. Paragraph I of this Order has been checked to restrain Defendant from harassing, stalking, or threatening Plaintiff or protected person/so o 4. Defendant represents a credible threat to the physical safety of Plaintiff or other protected person/s OR o The terms of this Order prohibit Defendant from using, attempting to use, or threatening to use physical force against Plaintiff or protected person that would reasonably be expected to cause bodily injury. " !29 13. THIS ORDER SUPERCEDES ANY PRIOR PFA ORDER. D ANY PRIOR ORDER RELATING TO CHILD CUSTODY. !29 14. All provisions of this Order shall expire one year from the date this Order is entered. NOTICE TO THE DEFENDANT Violation of this Order may result in your arrest on the charge of Indirect Criminal Contempt which is punishable by a fine of up to $1,000 and/or a jail sentence of up to six months. 23 Pa.C.S. s6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. This Order is enforceable in all fifty (50) States, the District of Columbia, Tribal Lands, u.s. Territories, and the Commonwealth of Puerto Rico under the Violence Against Women Act, 18 U.S.C.s2265. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under that Act. 18 U.S.C.ss 2261-2262. If paragraph 12 of this Order has been checked, you may be subject to federal prosecution and penalties under the "Brady" provisions of the Gun Control Act, 18 U.s.C.s922(g), for possession, transport or receipt of firearms or ammunition. NOTICE TO LAW ENFORCEMENT OFFICIALS The police who have jurisdiction over Plaintiff's residence OR any location where a violation of this Order occurs OR where Defendant may be located, shall enforce this Order. An arrest for violation of Paragraphs I through 7 of this Order may be without warrant, based solely on probable cause, whether or not the violation is committed in the presence of the police. 23 Pa.C.S.s61 13. Subsequent to an arrest, the police officer shall seize all weapons used or threatened to be used during the violation of the Protection Order or during prior incidents of abuse. The Cumberland County Sheriff's Department shall maintain possession of the weapons until further Order of this Court. When Defendant is placed under arrest for violation of the Order, Defendant shall be taken to the appropriate authority or authorities before whom Defendant is to be arraigned. A "Complaint ." for Indirect Criminal Contempt" shall then be completed and signed by the police officer OR Plaintiff, Plaintiff's presence and signature are not required to file the complaint. Ifsufficient grounds for violation of this Order are alleged, Defendant shall be arraigned, bond set and both parties given notice of the date ofthe hearing. Joan Carey, Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 John Joseph Skeens, Defendant 1417 Northwest Foxboro Road Blue Springs, MO 64015 (816) 228-9440 ~.:. Vi Q;, i 'j ..... '" ~ TJ\ 5: 0- <'J ~ IN THE CIRCUIT CqU.RT OF JACKSON COUNTY, MISSOURI CASE DESCRIPTION: DONNA JEAN SKEENS V JOHN JOSEPH SKEENS COURT CASE NUMBER: 2000-135 FOREIGN CASE NUMBER: (!~iJuf~ Cb CIVIL PROCESS AFFIDAVIT ~ ~~ ., I, 7-!AMA , of lawful age, being first duly sworn, on my oath state that I am a Deputy Court . Administrator employed as a process server for the Circuit Court of JACKSON County, Missouri: that the Court Administrator is vested with the authority to execute process in JACKSON County pursuant to Article VI of the JACKSON County, Missouri Constitutional Home Rule Charter; and that I executed this FINAL PROTECTION ORDER, NOTICE TO DEFEl'-.'DANT, NOTICE TO LAW ENFORCEMENT OFFICIALS inIACKSONCountv Missouri. ~~ ~ ~ PERSONAL SERVIC~: By delivering a copy of same personally to defendan? D MElvlBER OF F AMIL Y; By leaving a copy thereof at tht:: dwelling place or usual place of abode of the within-named defendant, by leaving with , who stated he/she was a member of the defendant's family over the age of 15 years. D CORPORATION-PERSON IN CHARGE: By leaving a copy of same at the business office of the within-named corporation, ,with , who said he/she was the person having charge thereof. D CORPORATION-OFFICER OR AGENT: By delivering a copy of same to the withirHlamed corporation, , by serving . who said he/she was D NON-EST: By making a_diligent search for and failing, to fmd the within-named defendant, , for the reason that I P lace of Service: 0/J/ -t-J. /tJ3 .J: C. /Z1c ) Date of Service: .Lf-~-~ COURT ADMINISTRATOR'S OFFfCE Time of S::rvict:: B~i<_1.._.___ D. ~MZ"rM DEPARTMENT OF CIVIL PROCESS I' CIRCUIT COURT OF JACKSON County, MO ~~a ~7i~<~-;C,-_ Deputy Subscribed and sworn to before me on -v. 7-0i) ~~&p{J~ BETIY L PEL10N My Commission Expires: Notary Public - Notary Sea! JACKSON cOUNlY NOTARYP BUC MY cOMMISSION EXP. DEC. 30,2002 CIRCT 3030-5/89 >- C") r-: 0; <'4 :a: ~ N 8i w2 EE~? ::c 1.L._.".l..... 0... o~ C.:X~ :~ ' , ...::l' ............- '--'~- -'2 L.!..I>..:" CCZ C~ c= tH~ 0.... 1=: "'" ...". " 0 .:'5 is = (.) < . ",," ."";':: '-.;. , '''>..'' -'-~..""""" -'!"" ~\ J..~':.