HomeMy WebLinkAbout00-00344
" '"""- - ,.,~ .<<- ---
, ,
liT
Amy M. Hartman,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 00- 344 CIVIL TERM
Peter Michael Pollack,
Defendant
: PROTECTION FROM ABUSE
ORDER FOR CONTINUANCE
AND NOW, thif.-~y of January 2000, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on January 24, 2000, by this Court's Order of
January 19,2000, is hereby rescheduled for hearing on February 16, 2000, at 8:45 a.m. in
Courtroom No.2 .
The Temporary Protection Order shall remain in effect for one year or until modified or
terminated by the court.
The Cumberland County Sheriff's Department shall attempt to make service at the plaintiff's
request and without pre-payment of fees, but service may be accomplished under any applicable
rule of Civil Procedure.
This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff
for service. The Prothonotary shall not send a copy of this Order to the defendant by mail.
A certified copy of this Order for Continuance shall be provided to t!1
/0.'
Allen and
Mechanicsburg Police Departments by the plaintiff's attorney. //.
, Judge
Joan Carey
Legal Services, Inc.
Attorney for Plaintiff
Peter Michael Pollack
Pro Se Defendant
go;
r
RLED~:XFiCE
n,c TL'C ;:')I'In"n!\!(jTI'RY
...( "i.." "-"',..1...,.1,\
"!1 "'! 2" IX,; ", 50
ULJ ...;~-l[';; ,...., I r I ...,. ". ..,
CU' """'1'" I" ",r", '1-'(
iViuCNw"Il\J LUUi~
PENNSYL\lftJl!IA
"I
,
II
II
If'i'
-
~ ,.
-
"
~1l!"I"1'[~~rr~!.'\"L ,_" _" ~.
>. V'll
'-
'.iil;j
- ""'r."",' _~-"'o;'.
- ,-p ,~,
.~" -- -"--,,- '-.'--=,-,
Amy M. Hartman,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 00- 344
CIVIL TERM
Peter Michael Pollack,
Defendant
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
The plaintiff, Amy Hartman, by the 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:
1. A Temporary Protection Order was issued by this Court on January 19,2000,
scheduling a hearing for January 24, 2000, at I :30 p.m.
2. The Cumberland County Sheriff's Department sent the Temporary Protection Order
and Petition to the Allegheny County Sheriff's Department and deputized them to serve the
defendant. The Allegheny County Sheriff's Department has not been able to effect service of the
defendant.
3. The plaintiff requests that the Temporary Protection Order remain in effect until
modified or terminated by the court after notice or hearing.
4. A certified copy of the Order for Continuance will be delivered to the Lower Allen
and Mechanicsburg Police Departments by the attorney for the plaintiff.
I
1<,
. ,', "= - ""C ~'i'.i' '~' . -, .~,<, ,~
WHEREFORE, the plaintiff requests that the Court grant this Motion and reschedule this
matter for hearing, and that the Temporary Protection Order remain in effect until further Order
of Court.
Carey, Attorney for intiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
~."
.~~
~,
,'---
:-t"r,
~ A.:
~'l
~: l.'-L
~",
~~
~,
~
LcJ
""
,.
"--~iljiS:J
"'-.
i"~!!cil!i!lT _.4..,~.....
~ .,
,
,
.-
o
t;;
<"
-0[6
rnrn
~r~~
~:;~;:-
~C>
~Q
~::::::(..J
:PC
Z
~
CJ
co
(.-
o
'n
::::;
~.;:;'129
, '1.-'-.
':':":1. ~_/
.___,.-n
'1i5~
':~~
..,..".
<"-)
:'<
f"
.;:""
:t:;;-'"
-"~
;-:>
<.11
,';--,",,'
-;j~,,< - -",
Amy M. Hartman,
: IN THE COURT OF COMMON PLEAS
Plaintiff
: OF CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 00-344
CIVIL TERM
Peter Michael Pollack,
Defendant
: PROTECTION FROM ABUSE
ORDER FOR CONTINUANCE
,-
AND NOW, this -.12 day of February, 2000, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on February 16, 2000, by this Court's Order of
January 24,2000, is hereby rescheduled for hearing on March 20, 2000 , at 11 :00 a.m. in Courtroom
No.2.
The Temporary Protection From Abuse Order shall remain in effect for a period of one year
from the date it was entered or until further Order of Court, whichever comes first.
Certified copies of this Order for Continuance will be provided to the Lower Allen Police
Department and the Mechanicsburg Police Department by the plaintiffs attorney.
By the court,.l}Jl
,.. "
/' I
)
~
J-J5-fJO
Rl(9
I
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
Charles Lopresti
Attorney for Defendant
t'
'I,
,
I
I
I
~;
.--
"---,,.
< ,
-'n F'-r' I"
i'l ";-'_" .....
'-.-. ,~ '__01,'- ..J
"i-' r'-:."'\\l:_)I)\RY
PH ~: ! 7
~~-,j :__:~:o~ir'JT\!
PL~f\Jt\SYL\'!\\l!/\
J )11_.
~ _!Jl!~~,
....
"
,-
Jf!:!lll!ll!!
~--, .
.. /'j ~--
"
Amy M. Hartman,
: IN THE COURT OF COMMON PLEAS
Plaintiff
OF CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 00- 344 CIVIL TERM
Peter Michael Pollack,
Defendant
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
The Plaintiff, Amy Hartman, 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:
I. A Temporary Protection From Abuse Order was issued by this Court on January 19,
1999, scheduling a hearing for January 4, 2000.
2. The Cumberland County Sheriffs Department deputized the Dauphin County Sheriff
who served Defendant with a certified copy of the Temporary Protection From Abuse Order and
Petition for Protection From Abuse at the Dauphin County Courthouse on February 10, 2000.
3. The parties agree, by and through their respective counsel, that the hearing be
rescheduled to afford them time to execute a consent agreement.
4. The Plaintiff requests that the Temporary Protection From Abuse Order remain in
effect for a period of one year from the date it was entered or until further Order of Court, whichever
comes first.
.
",-~ .~',I'
-I,
5. Certified copies of the Order for Continuance will be delivered to the Lower Allen
Police Department and the Mechanicsburg Police Department by the attorney for the Plaintiff.
WHEREFORE, the 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 or until further Order of Court, whichever comes first.
Respectfully submitted,
~,~ntiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
"
","0
, ""'-w...
.'.-,",,' ...~
C'} >-
("".i 1:::
:5 ~S
.~)
'-' '-
~'.-....
" ~.J
n ,"
'::J (:)
~'<'
r:;:: Z
! LU
, I:~ 1':'1_
1--- lc_ >..
(-:;1 "'j
C) U
"~
Amy M. Hartman,
: IN THE COURT OF COMMON PLEAS
Plaintiff
: OF CUMBERLAND COUNTY, PENNSYLVANIA
Ys.
: NO. 00- ..3 'I <J CIVIL TERM
Peter Michael Pollack,
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 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.
A hearing on this matter is scheduled for the ..J.iday of January 2000, at 1'30
-#-.m., in Courtroom No. a ofthe 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 police may arrest you.
Violation ofthis Order may subject you to a charge of indirect criminal contempt which is
punishable by a fme of up to $1,000.00 and/or up to six months in jail under 23 Pa.C.S.
~61l4. 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 ofthe 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
HELD. IF YOU CANNOT FIND A LAWYER, YOU MAY HAVE TO PROCEED
WITHOUT ONE.
CUMBERLAND 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.
.
.
'l
~
CUMl3EFiLAND COUNTY
PENNSYLVANIA
. ~~;
C, '<0,'
'-< .
J-~
h:;
F!\ I=D-O:C\CE
, "', H:'-'~;;~~h"!j, :;"i. t. ....
,~F I "'c, 1-'" ., ,'. ,.~,'lI'''RY
l() . , l 1. _, ,.' :- , , j -"..~, . "" t\l
I
I
'" 00 JAN 19 AM 1\: 38
_~,IIllInJ["lI,~ -
!i7lf_~~!WIi'll,.,.--._~
Amy M. Hartman,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PENNSYL VANIA
vs.
Peter Michael. Pollack,
Defendant
: NO. 00 - .3 '1'1 CIVIL TERM
: PROTECTION FROM ABUSE
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name: Peter Michael Pollack
Defendant's Date of Birth: September 26,1966
Defendant's Social Security Number: Unknown to Plaintiff
M.H
Names of the Protected Person: Amy M. Hartman
AND NOW, this I q --tIu day of January 2000, upon consideration of the attached Petition
for Protection from Abuse, the court hereby enters the following Temporary Order:
181 1. Defendant shall not abuse, harass, stalk or threaten any of the above person in any
place where she might be found.
D 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.
181 3. Defendant is prohibited from having ANY CONTACT with Plaintiff at any
location, including, but not limited, to any contact at Plaintiff's residence or place of
employment. Defendant is specifically ordered to stay away from the following locations
for the duration ohhis Order: the plaintiff's residence located at 313 West Green Street,
Mechanicsburg, Cumberland County, Pennsylvania, and her place of employment located
at Alliance Funding, 4900 Ritter Road, Mechanicsburg, Pennsylvania.
181 4. Defendant shall not contact Plaintiff by telephone or by any other means, including
through third persons.
D 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 the Plaintiff in accordance with the terms
ohhis Order.
~ 6. Defendant shall immediately relinquish the following weapons to the Sheriffs Office
or a designated local law enforcement agency for the delivery to the Sheriffs Office: A
straight blade knife, approximable 5-6" long, with a black handle that was used in the
December 11, 1999, incident of abuse.
Defendant is prohibited from possessing, transferring or acquiring any other weapons for
the duration of this Order.
~ 7. The following additional reliefis granted:
The Cumberland County Sheriffs 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.
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 fmds that Defendant has
committed another act of abuse or has engaged in a pattern or practice that indicates
continued risk of harm to Plaintiff.
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.
~ 8. A certified copy of this Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter: The Mechanicsburg Police
Department and the Lower Allen Township Police.
o 9. THIS ORDER SUPERSEDES 0 ANY PRIOR PF A ORDER AND
PRIOR ORDER RELATING TO CHILD CUSTODY
o ANY
~ 10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT 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 fme of up to $1,000.00 and/or up to
six months in jail. 23 Pa.C.S. ~6114. Consent ofthe 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. Anv protection order l!J"anted
bv a court mav be considered in anv subsequent proceedinl!s. includinl! child custodv
proceedinl!s. under title 23 (Domestic Relations) of the Pennsvlvania Consolidated Statutes.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the police who have jurisdiction over the plaintiffs
residence OR any locations where a violation of this order occurs OR where the defendant
may be located. If defendant violates Paragraphs 1 through 7 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 of law 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 Sheriffs office ofthe county which
issued this Order, which office shall maintain possession of ap s until further
Order of this Court, unless the weaponls are evidence 11 crime,' which case, the shall
remain with the law enforcement agency whose offi er made t arrest.
Judge
cj
Amy M. Hartman,
: IN THE COURT OF COMMON PLEAS
Plaintiff
: OF CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 00- ~ '-I '-J
CIVIL TERM
Peter Michael Pollack,
Defendant
: PROTECTION FROM ABUSE
PETITION FOR PROTECTION FROM ABUSE
I. Plaintiff's name is Amy Hartman.
2. The name of the person who seeks protection from abuse is Amy Hartman.
3. Plaintiff's address is 313 West Green Street, Mechanicsburg, Pennsylvania.
4. Defendant is believed to live at 321 Cleveland Avenue, Avalon, Pennsylvania 15202.
Defendant's Social Security Number is unknown to Plaintiff.
Defendant's date of birth is September 26,1966.
Defendant's place of employment is unknown to Plaintiff.
5. Defendant is Plaintiffs former intimate partner.
6. Defendant has been involved in the following criminal court action: Defendant was
arrested on December 15, 1999, and charged with simple assault, terroristic threats, unlawful
restraint, and reckless endangerment.
7. The facts of the most recent incident of abuse are as follows:
On or about January 10, 2000, Defendant called Plaintiff at her place of
employment and threatened that she better drop the charges which
intimidated her and exacerbated her The police advised Plaintiff to file
harassment charges saying that a warrant would be issued for his arrest for
violating his bail by intimidating a witness.
8. Defendant has committed the following prior acts of abuse against Plaintiff:
a. On or about December 11, 1999, Defendant pulled out a knife, held it
to the side of Plaintiff's face, causing her to cut her palm and finger
when she raised her hands to protect herself. Defendant forcefully
pushed Plaintiff onto the bed, got on top of her, restrained her with his
legs, held the knife to her throat resulting in a cut on her ear and
causing her to fear for her life. Defendant threatened Plaintiff stating
that he had to do this, and that she was going to leave there with
emotional and physical injuries. Defendant grabbed a sock and
threatened to stuff it into Plaintiff's mouth when she began to scream.
Defendant refused to allow Plaintiff to leave the room and when she
attempted to do so, he grabbed the knife again, approached her
throwing the knife back and forth between his hands and when she
again attempted to leave, he pushed her back into the room. When
Defendant finally let go, Plaintiff fled to the front office of the hotel
for help, and Defendant drove away. When police arrived they issued
a warrant for his arrest. Charges for simple assault, terroristic threats,
reckless endangennent, and unlawful restraint were filed against
Defendant and a hearing is scheduled for February 10, 2000.
9. Defendant has used or threatened to use the following weapons against Plaintiff: A
straight bladed knife with a black handle that was used in the December 11, 2000 incident of
abuse.
, 10. The following police department or law enforcement agency in the area in which
Plaintiff lives should be provided with a copy of the Protection Order: The Mechanicsburg Police
Department and the Lower Allen Police Department.
11. There is an immediate and present danger of further abuse from the 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 in any
place where Plaintiff may be found.
B. Order Defendant to stay away from Plaintiffs residence and prohibit Defendant from
attempting to enter any temporary or permanent residence of 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
Plaintiffs residence or place of employment.
D. Prohibit Defendant from having any contact with Plaintiff's relatives.
E. Order Defendant to pay the costs of this action, including filing fees, service fees, and
surcharge of$25.00.
F. Order Defendant to pay $250.00 to reimburse one of Legal Services, Inc.'s funding
sources for the cost oflitigation in this case.
G. Order the following additional relief, not listed above:
a. Defendant is enjoined from damaging or destroying any property owned
jointly by the parties or owned solely by Plaintiff.
b. Defendant is ordered to refrain from harassing Plaintiff's relatives.
Order the police or other law enforcement agency to serve Defendant with a copy of this
Petition, any Order issued, and the Order for Hearing. Plaintiff will infolTIl the designated
authority of any addresses, other than Defendant's residence, where Defendant can be served.
Plaintiff prays for such other relief as may be just and proper.
Respectfully submitted,
,
I
{/Joan Carey
Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
g
-,-_.,
-""""'. '._,',".-,..
"',i
.
.
VERIFICATION
I verify that I am the Petitioner as designated in the present action and that the facts and
statements contained in the above Petition are true and correct to the best of my knowledge. I
understand that any false statements are made subject to the penalties of 18 Pa.C.S. g4904, relating
to unsworn falsification to authorities.
Dated:
1- / R ~O()
aw,j/J? H:uh/&fL
Amy M. H an, Plaintiff
-<'
-...-
""
~-'-~ ""
.
t., a 0
c: 0
s:: , ~n
"T:1V' :?;;
111M --
Z'" ~2: i't,.;:,.']
:z:X
r- - 'r-
C/.J'. -:--J'TJ
;:$" U) ~;~o
(;, ,"-\:)
... .'
~ "'" ..~
2'0 ::1: ~:r;:~~
-0 ,)~
>c -- Z
2:: h C) .
:-<
-I N 3t
-< (,.)
'"<
,~ ~-"
~_ i' . >-.-j "
'I
I
!
c
CD
"
Amy M. Hartman,
: IN THE COURT OF COMMON PLEAS
Plaintiff
: OF CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 00- 344 CIVIL TERM
Peter Michael Pollack,
Defendant
: PROTECTION FROM ABUSE
FINAL PROTECTION ORDER
Defendant's Name: Peter Michael Pollack
Defendant's Date of Birth: September 26,1966
Defendant's Social Security Number: Unknown to Plaintiff
Names of Protected Person: Amy M. Hartman
~eucA
AND NOW, this tIP -/It day of nary 2000, the court having
jurisdiction over the parties and the subject-matter, it is ORDERED,
ADJUDGED, and DECREED as follows:
The Plaintiff, Amy Hartman, is represented by Joan Carey of Legal Services, Inc.; the Defendant,
Peter Michael Pollack, is represented by Charles Lopresti, Attorney at Law.
The Defendant, although agreeing to the terms of this Order, does not admit the allegations
made in the Petition.
~ Plaintiffs request for a Final Protection Order is granted pursuant to the
consent of Plaintiff and Defendant
o Plaintiff's request for a Final Protection Order is denied
~ 1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any
other protected person in any place where they might be found.
". >' " _' - ".r. ~'.' "',.
-.:~
I~
'I
I:
:l
,
I
,
i
,
o
o
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,
o 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.
Defendantis prohibited from having ANY CONTACT with the Plaintiff
at any location, including, but not limited to, any contact at the
Plaintiff's school, business, or place of employment. Defendant is
specifically ordered to stay away from the following locations for the
duration ofthis Order: Plaintiff's residence located at 313 West Green
Street, Mechanicsburg, Pennsylvania and place of employment located
at Alliance Funding, 4900 Ritter Road, Mechanicsburg, Pennsylvania.
~ 4. Defendant shall not contact the Plaintiff by telephone or by any other
means, including third parties.
o 5. Custody of the minor children, [names of the children subjectto the provision
of this paragraph] shall be as follows: [state to whom primary physical custody awarded; state terms
of partial custody or visitation, if any]( or see attached Custody Order) _
o 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 weapons used or threatened
to be used by Defendant in an act of abuse against Plaintiff and/or the minor child/ren:
o 7. Defendant is prohibited from possessing, transferring or acquiring any other
weapons for the duration of this Order. Any 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.
[g) 8.
The following additional relief is granted as authorized by ~61 08 of this
Act:
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 fmds that
Defendant has committed an act of abuse or has engaged in a pattern or
~ _~__' ,,_,,', " -<_oj:... ~_ "
'f~,
,
o
o
'.
practice that indicates risk of harm to Plaintiff.
The Defendant is enjoined from damaging or destroying any property owned
jointly by the parties or owned solely by Plaintiff.
The Defendant is to refrain from harassing Plaintiff's relatives.
All costs and fees are waived.
o 9. Defendant is directed to pay temporary support for (insert the names of the
persons for whom support is to be paid) _ as follows: (insert amount, frequency and other
terms and conditions of the support order) . 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 of the date of this Order. The amount of this 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 Plaintiffs out-of-pocket losses,
which are as follows: OR
o Plaintiff is granted leave to present a petition, with appropriate notice to Defendant,
to (insert the name of the judge or court to which the petition should be presented)
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 1. 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 Order is being entered after a hearing of which Defendant received actual
notice and had an opportunity to be heard.
.
,---_-,."h~_J.--.---- ._".,
o
o
, '.
~ 3. Paragraph I of this Order has been checked to restrain Defendant from
~assing, 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 tenns 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,
129 13. THIS ORDER SUPERCEDES:
129 ANY PRIOR PFA ORDER and
o ANY PRIOR ORDER RELATING TO CHILD CUSTODY.
129 14. All provisions ofthis Order shaH 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, 96114.
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 ACTION, 18 U.S.C. 92265. 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. 99 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 ACTION, 18 U.S.C. 9922(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
-
,.,
~~' L:;",
, 0-:~
violation of Paragraphs I through 8 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. ~6113.
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, Plaintiffs presence and signature are not required to file the complaint.
If sufficient grounds for violation of this Order are alleged, Defendant shall be arraigned,
bond set and both parties given notice of the date of the hearing.)
BY THE COURT,
,
tnlJ CfftMJu,l)A
r~ PSP
~~
3 .n _00
~\Z~
!
This Order is entered pursuant to the consent of Plaintiff and Defendant:
oan Carey, Attorney, r Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(
Charles Lopresti, Attorney for Defendant
Lopresti, Melograne, Stewart & Zinski
321 Regis Avenue
Pittsburg, PA 15236
""
','00 ,.,
.-., ,-.,~ ".
,-~
~ .- ,"",; -~
. .a___-,':_',_~_"..
~"-
, -~
IIIiI
~'1t)(~Cf '
00 1f41? ". i/:lOVOt<l9v
c 16 P/1 .
, VI/1S(-",r, I.. 08
IS'-'I~t'l'l
tvJl{sizt CO(M ~ .
:;q/U-,/ 'V'r
'" ~
.--'- ~ ,
lit II
IIl-J",_,_,---J,,'t",-_-,__
...-~.
, .II ,~_.
.'
~.~~ "
"~
.
1
I
I
/':
SHERIFF'S RETURN - OUT OF COUNTY
,
CASE NO: 2000-00344 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HARTMAN AMY M
VS
POLLACK PETER MICHAEL
R. Thomas Kline , Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
POLLACK PETER MICHAEL
but was unable to locate Him
in his bailiwick. He therefore
deputized the sheriff of ALLEGHENY
County, Pennsylvania, to
serve the within PROTECTION FROM ABUSE
6th , 2000 , this office was in receipt of the
On March
attached return from ALLEGHENY
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep. Allegheny Co
18.00
9.00
10.00
150.00
.00
187.00
03/06/2000
,O~
R. Thomas Kline
Sheriff of Cumberland County
Sworn and subscribed to before me
this 21M- day of~
2tnyO A.D.
C)u['-,- 0, Yvup;,,, t4
prothonotc{r
._~-, "~- ~
SHERIFF'S RETURN - OUT OF COUNTY
_m._,
!
CASE NO: 2000-00344 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HARTMAN AMY M
VS
POLLACK PETER MICHAEL
R. Thomas Kline
, Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT
, to wit:
POLLACK PETER MICHAEL
but was unable to locate Him
in his bailiwick. He therefore
deputized the sheriff of DAUPHIN
County, Pennsylvania, to
serve the within PROTECTION FROM ABUSE
6th , 2000 , this office was in receipt of the
On March
attached return from DAUPHIN
No Weapons Confiscated
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep. Dauphin Co
So
6.00
9.00
10.00
25.50
.00
50.50
03/06/2000
R. llomas Kline
Sheriff of Cumberland County
Sworn and subscribed to before me
this .l/~ day o~
J-.u-v-v A.D.
n. /I~ Q_~,~
"-1"'-<1 Prothonotary .
...
~"-.~
"
"'~-.~<
'.
@llitt of tlr~ ~4~riff
William T. Tully
Solicitor
Ralph G. McAllister
Chief Deputy
Mary Jane Snyder
Real Estate Deputy
Michael W. Rinehart
Assistant Chief Deputy
Danphin County
Harrisburg, Pennsylvania 17101
ph: (717) 255-2660 fax: (717) 255-2889
Jack Lotwick
Sheriff
. Commonwealth of Pennsylvania
HARTMAN AMY M
vs
County of Dauphin
POLLACK PETER MICHAEL
Sheriff's Return
No. 0277-T - -2000
OTHER COUNTY NO. 00-344
AND NOW: February 10, 2000 at 9:15AM served the within
ORDER FOR CONTINUANCE
upon
POLLACK PETER MICHAEL
by personally handing
to DEFT
1 true attested copy (ies)
of the original
ORDER FOR CONTINUANCE
and making known
to him/her the contents thereof at 2/10/00 AT 9:00AM (FORMAL ARRAIGNMENT)
DAUPHIN COUNTY COURTHOUSE
HBG, PA 17101-0000
Sworn and SUbscribed to
So Answers,
JR~
before me this 16TH day of FEBRUARY, 2000
(\
i \
~. (fJON4f,a)
Sheriff of Dauphin County, Pa.
PROTHONOTARY
By
...1 ......'\:2
P"4 - ~I'--
, Deputy Sheriff
Sheriff's Costs: $0.00 PD 00/00/0000
RCPT NO
GD
~i..
,.-
....-
In The Court of Common Pleas of Cumberland County, Pennsylvania
Amy M. Hartman
VS.
Peter Michael Pollack
No. 2000-344 Civil
Now 2/8/00
,
, 20 00, I, SHERIFF OF CUMBERLAND COUNTY, P A, do
hereby deputize the Sheriff of Dauphin
County to execute this Writ, this
Weapons Confiscation
deputation being made at the request and risk of the Plaintiff.
-~~ et
?:,,"-*,J_~ ~(
Sheriff of Cumb 'land County, P A
Affidavit of Service
Now,
, 20_, at
o'clock
M. served the
within
upon
at
by handing to
a
copy of the original
and made known to
the contents thereof.
So answers,
Sheriff of
County, PA
Sworn and subscribed before
me this _ day of , 20:...-
COSTS
SERVICE
MILEAGE
AFFIDAVIT
$
$
.- -
, .
"- "-- - ~ ,
" '''It>
In The Court of Common Pleas of Cumberland County, Pennsylvauia
Amy M. Hartman
VS.
Peter Michael Po1l~ck
No. 2000-344 Civil
(Continuance)
Now, 1/25/00
, 20 00, I, SHERIFF OF CUMBERLAND COUNTY, P A, do
hereby deputize the Sheriffof Allegheny
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
~
i
I
!
Sheriff of Cumberland County, P A
[;
ji
Ij
,
"
!
Affidavit of Service
:
Now,
,20_, at
o'clock
M. served the
within
i
i'
r
I,
r
i"
upon
at
by handing to
a
copy of the original
and made known to
the contents thereof.
So answers,
Sheriff of
County, PA
Sworn and subscribed before
methis~dayof ,20_
COSTS
SERVICE
MILEAGE
AFFIDAVIT
$
$
1_ _' _. ~~J
I .- -~"
I~
-1IJr-"""''''''',,",''''''\:t'
I
i
,
,
r
In The Court of Common Pleas of Cumberland County, Pennsylvania
Amy Hartman
VS.
Peter Michael Pollack
No. 2000-344 Civil
Now, 1/19/2000
, 20 -12t2, I, SHERIFF OF CUMBERLAND COUNTY, P A, do
hereby deputize the Sheriff of Allegheny
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
Weapons Confiscation: specifically 1 ~~~~(
stright blade knife. approx 5-6" lnng .,' - .
SheriffofCumb rland County, PA
Affidavit of Service
(:
r
Now,
,20_, at
o'clock
M. served the
within
by handing to
i
i:
i
I
,
i
I
ti
[,
n
I'
I:
upon
at
copy of the original
a
and made known to
the contents thereof.
So answers,
Sheriff of
County, PA
Sworn and subscribed before
me this _ day of ,20_
COSTS
SERVICE
MILEAGE
AFFIDAVIT
$
$
~~
I
_ . ~ l'" I 'j,;
ALILEGHENY COUNTY SHERIFF'S DEPARTMENT
436 GRANT STREET
PllTSBURGH, PA 15219-2496
PHONE (412) 350-4700
FAX (412) 350-6388
q)
DENNIS SKOSNIK
Chief Deputy
CASE#: ;;2tDo-3~Y
EXPIRES:
o SUMMONs/PRAECIPE
o SEIZURE OR POSSESSION
o NOTICE AND COMPLAINT
o REVIVAL OR SCI FA
o INTERROGATORIES
o EXECUT<,~ OR GARNISHEE
';Q: OTHER
DE
DEFT.:
DEFT.:
GAR SHEE:
ADDRSS: ~g&~j~o~S
MUNICIPALITY OR CITY WARD:
DATE: 19
ATTY'S PHONE:
ATTY:
ADDRESS:
CJJ{'.(\CC€.lli \P\N() ~1 J
INDICATE TYPE OF SERVICE: 0 PERSONAL 0 PERSON IN CHARGE 0 DEPUTIZE 0 CERT. MAIL 0 POSTED 0 OTHER 0 LEVY 0 SEIZED & STORED
NOW:
19
I, SHERIFF OF AllEGHENY COUNTY, PA do hereby deputize the Sheriff of
County to execute this Writ and make return thereof according to law
NOTE: ONLY APPLICABLE ON WRIT OF EXECUTION: N.B. WAIVER OF WATCHMAN - Any deputy sheriff levying ufon or attaching any property under
Within writ may leave same without a watchman, in custody of whomever is found in possession, after notifying person 0 levy or attachment, with out liability on
the part of such deputy herein for any loss, destruction or removal of any such property before sheriff's sale therof.
MAKE
MODEL
MOTOR NUMBER
SERIAL NUMBER
LICENSE NUMBER
SHERIFF'S OFFICE USE ONLY
I hearby CERTIFY and RETURN that on the ~day of 1f"eQ.J.J~ ,~~,qt
:>J " ~ o'clock, A.M. .M. Address Above/ Address B w, County of Allegheny, Pennsylvania
3r\--aJ
I have served in the manner Described below:
o Defendant(s) personally served.
o Adult family member with whom said Defendant(s) reside(s). Name & Relationshi
o Adult in charge of Defendant's residence who refused to give name or relationship
o Manager/other person authorized to accept deliveries of United States Mail
o Agent or person in charge of Defendant(s) ollice or usual place of business.
Sheila R. O'Brien, Notary Public
Pittsburgh, Allegheny County
M Commission Ex ires Jun 19 20
Membet Pennsylvania Association of Notaries
o Other
o Property Posted
Defendant not found because: 0 Moved
IJ Certified Mail IJ Receipt
IJ Regular Mail Why
IJ Unknown IJ No Answer
IJ Envelope Returned
IJ Vacan1 Other
IJ Neither receipt or envelope retuned: writ expired
You are hereby notified that on , 19 , levy was made in the case of
Possession/Sale has been set for , 19 at o'clock
YOU MUST CALL DEPUTY ON THE MORNING OF SALEIPOSSESSION BETWEEN 8.30 . 9:30 A.M.
ATTEMf>TS / / / / /
Additlonal Costs Due $ , This is PByE:TER ~.P.,~EF, 0, ri':-- 17 II. ,
placed on writ when returned to Prothonotary. Please check ~/~~
before satisfying case. (DEPUTY)
White Copy. Sheriff Pink Copy. Attorney DISTRICT: ....
.~- '.,
,c,...' "l.-
.Ir
Sheriff
PLAINTIFF: ~\~0, t\~\(t~M(\N
r ('~J.." " ' , ,VS,
DE \-\~:::\t,(L \\J\ \0J\~ y~l. (6l,L~_
PE
ALIl.EGHENY COUNTY SHERIFF'S,DEPARTMENT
436 GRANT STREET
PITTSBURGH, PA 15219-2496
~HONE (412) 350-4700
'FAX (412) 350-6388
~~)
, DEFT.:
DEFT,:
GAR SHEE: t::::
ADDR S: -f(CK\~ ~~<e~\ ~~()t\j
MUNICIPALITY OR CITY WARD:
DATE: 19
ATTY'S PHONE:
CASE#:
EXPIRES:
o SUMMONS/PRAE;CIPE
o SEIZURE OR POSSESSION
o NOTICE AND COMPLAINT
o REVIVAL OR SCI FA
o INTERROGATORIES
o EXECUTI~ '" LEVY OR GARNISHEE
It OTHER \- ~'p,-
DENNIS SKOSNIK
Chief Deputy
;;;;2t::oo --51.{ '-I
ATTY:
ADDRESS:
c~J'fx'\e:~\U ~"NtJ l\l)
" - . ",--;."_.:-: - .-" '" ',f
o P HSONAL 0 PERSON IN CHARGE 0 DEPUTIZE 0 CERT. MAIL 0 POSTED 0 OTHER 0 LEVY 0 SEIZED & STORED
{,
NOW:
I, SHERIFF OF ALLEGHENY COUNTY, PA do hereby deputize the Sheriff of
:'., County to execute this Writ and make return thereof according to law
NOTE: ONLY APPLICABLE ON WRIT OF ExEib,UTION: N.B. WAIVER OF WATCHMAN' Any deputy sheriff levying upon OJ attaching any properly under
within writ may leave same without a watchman, in custody ,of whomever is fou~d in posses,sion, after notifying person of levy or attachment, with out liability on
the part of such deputy herein for any loss, destruction or removal of any such property before sh~riff's sale therof.
19
MAKE
MODEL
MOTOR NUMBER
SERIAL NUMBER
LICENSE NUMBER
." SHI;RIFF'S OFFICI; US,E ONLY
I hearby CERTIFY and RETURN that on the :.::2,O("r\\ day of (CeJ">- \),,\., Cc \.J..1:. ;1"9 :,)...,: cqt
,:" \ 'S<::> o'clock, A.M,{~\AddreSs Above/ Address BMow. County of Allegheny, Penns'y~vilni~ ' /"
I have served in the manner Described below: .----h ~~,:::, '~,r <~,~." ,~'" ' ">- ",' " ",
o Defendant(s) personally served. V)1l\tbl&.~;t.,~" :'
o Adult family member with Vihom said~~fepdant(s)resid~(s~ Nam1~jHelB;tionship ,.' t ,"..,..,",..~'~1i;;:
o Adult in charge ill De\eridanl's resldei1)Jll who refused to give namll"orrelationshlp: "t~'>;,;tr
o Manager/other person authorized to accept deliveries of United States Mail 'j~" ' , : " '.
o Agent or person in charge of Defendant(s) office or usual place of business. "iiif~)@! '';5 "
o Other
o Property Posted
Defendant not found because: 0 Moved
o Certified Mail 0 Receipt
o RegUlar Mail Why
o Unknown 0 No Answer
o Envelope Returned
"'"'L' \'"", I)- q( ,.,.',"
\ l-')\-~ - ..'l-'~\'c.\,C --', ~ ., "
l.-C::S '.::>s,,- c 2J ~~ " \ p, \'t...(I...6
o Vacant ).l.Other ~<}:) Sf: C\J " 0' ''(., 1\...\ p, \'\ ;:.
o Neither receipt or envelope retuned: writ expired
You are hereby notified thet on ' , 1 g . levy was made In the case Of
Possession/Sale has been sellor '," " ' ,', , , ',,' '.. ,19, ," at o'clock
YOU MUST CALL DEPUTY ON THE MORNING OE SALEI!'OS~ESSION BETWEEN 8:30 ,9:30 A.M.
ATTEMPTS I I I I I
AddilionalCosts Due $ . This is PETER '} DE,~~' ,~)t9r!,!"), If
placed on writ when returned to Prothonotary. Please check BY' ",7"jY A0~\""-AJ,ltA
before satisfying case. ' , - " ,.. /f (DEPUTY)
White Copy. Sheriff Pink Copy . Attorney DISTRICT: ...
- .~
~_. .
4,
I
.'
JA~..2 4 laao )
Vi
Amy M. Hartman,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: NO. 00- 344 CIVIL TERM
Peter Michael Pollack,
Defendant : PROTECTION FROM ABUSE
ORDER FOR CONTmDANCE
AND NOW, this ~ay ofJanuary 2000, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on January 24, 2000, by this Court's Order of
January 19,2000, is hereby rescheduled for hearing on February 16, 2000, at 8:45 a.m. in
Courtroom No.2.
The Temporary Protection Order shall remain in effect for one year or until modified or
terminated by the court.
The Cumberland County Sheriffs Department shall attempt to make service at the plaintiffs
request and without pre-payment of fees, but service may be accomplished under any applicable
rule of Civil Procedure.
This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff
for service. The Prothonotary shall not send a copy of this Order to the defendant by mail.
A certified copy of this Order for Continuance shall be provided to the Lower Allen and
Mechanicsburg Police Departments by the plaintiffs attomey.
By the Court,
I~ f~. ~ f':>~
Edgar . Bayley, J g
Joan Carey
Legal Services, Inc.
Attomey for Plaintiff
Peter Michael Pollack
Pro Se Defendant
TRUE C!)P't{ F f~\&;,Cj{)(j1[J
T.. >-' I '''''f' """''' ~",m' ,,,,,p ,",,,,,,,,
H1 esnmOlJ1y W!l~$r1;?f'-~~1 ~Q~~ ~ M'~,,#' .;;o..",~ h~J U'!.'lH"";
and tile sea! of ~id C~;;$1", pa.
This .1 y ~ day ''-.PI AJ~ rfl'ryrV
~ - ( ~,- Ilrathon~
y
.'
.
"
i
"
Amy M. Hartman,
Plaintiff
: IN THE COURT OF COMMON PLEAS
,
!"
,
,
}.
I
: NO. 00- 344
CIVIL TERM
I
i
i
k
: OF CUMBERLAND COUNTY, PENNSYL VANIA
vs.
Peter Michael Pollack,
Defendant
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
The plaintiff, Amy Harbnan, by the through her attomey Joan Carey ofLega! Services, Inc.,
moves the Court for an Order rescheduling the hearing in the above-captioned case on the
grounds that:
I. A Temporary Protection Order was issued by this Court on January 19, 2000,
scheduling a hearing for January 24, 2000, at I :30 p.m.
l<
2. The Cumberland County Sheriffs Department sent the Temporary Protection Order
and Petition to the Allegheny County Sheriff's Deparbnent and deputized them to serve the
defendant. The Allegheny County Sheriff's Deparbnent has not been able to effect service of the
defendant.
3. The plaintiff requests that the Temporary Protection Order remain in effect until
modified or terminated by the court after notice or hearing.
4. A certified copy of the Order for Continuance will be delivered to the Lower Allen
and Mechanicsburg Police Departments by the attomey for the plaintiff.
sr
-
"
.'
.'
.
WHEREFORE, the plaintiff requests that the Court grant this Motion and reschedule this
matter for hearing, and that the Temporary Protection Order remain in effect until further Order
of Court.
,/
Respectfully submitted,
! ~\e-<
Carey, Attorney for . tiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
I
I..
1.'-
,I
i'i
\
i
r
(:,
.
,.....
: "",.'
';{. Ii:
.
(~
,Ii;
~
it
..
I
~ , . ..,
.
'" ,,'
.
.~,
-~
, '"t-- '., ~llib~l~$
~el"~ r,e ''''', '2 ,~",',\<,
.",:,-;... {, '. ,,', ,-"
.'Q11.l\;_l' ' ,,' \
fEB, 3. ~ 3;$ AM 100\
< \
'",'. -' . , f."~ Ii'.
PE~I,,'C\c1 l'f,.I,I\li/--~
. \ 'j I'" -,_' I '_.
~,..~I "
"~ 'r-_
". !Ill!lml~li
1:'
,
"
. \
,~.,- -~,..~- - - ....,~~ ~ --
"..~,!II","IIJ!I!
-
~
'1 "
. ,.
.,'. .
i' As you mow, d1ePlaintifrllllafillda.leplIlClilmBpiutyouUadertllA}'I. I ..1_ Prom, '
Abuse ArX aad has abl3iDed a T~'''l Plotstion Older, 'Ih= p!UDt!.'f l! ~..d t:l !Il1v:
a Iuostrit\g held in Older to abIain a filIal1'm~ 0tcIer afitcIiYe for OD (1) JU.
AB aD aIle1-...di....18ll1118)' .--eat to tbe eab7 oftbe Dul PrW~"''l Order to be
ID ef[ec:t r~ 0D1!,... Jr)'llll8l'll 'I'Iil!IIIg to "GlISllDt )'lIII8Iundd caD iepI Be. ,w, file. in
CarJisle at 24' 9.00, 7f6.847S from ~ Wilt Share or SINH6 fnIIl shlpa-'b_ 8IIli
IIIk to speak to tbe sIIIf penaa ............. tbe ase about a "", l 4a....... ,_
'1'he CoI1JlBlt. AgJ:eemmt sIumId be l"~ beb:e tile timo ""'-Inl...! for tile heIrlng so
,
11m CDmt wiI1 know ab=ad of time tba1 tiill cue willllDt be CllIIillIIeli. III IIlIIIIB cues, regazdless
of wlletber a u.ttI""'"nt by CcmslIIt A~ has _ ,...",,"11, tile puties nmst appear in
c:aurt at the time ...,I...nuJed for bcadng. If!be cue is IIDlJD1l11!lled, !be c:aurtappellJllllCO will be
brief. 'lbe judge will IIIlIIce sure !be paIties IIIIlIcnIaIIlI !be Ccms=t Apnent and fiDal
l'1ulGClian Older.
,
If you do IIDt Ip'Ile to !be eatJy of tile filial Ptoi' .1.... Om., a ~1Id I1e8IiDg will
IIbl pJacc at tile """""..1M time. Whllll a filial P&vIedioa Older is IIIlmed, it will be sent or
given 10 you, !be pJaiudff, lIIIlI tile "l'p.uptiIde police &p..bu.alb. If you fail to abide by !be
terms of !be final PlOlclllhm Olller you will be subject 10 im"""'l~ _ and a fiDe ,of
SI00.oo 10 $1,011II.00 amJIor a jailllBllb!nl!e of up 10 silt IIIDIItbs and aIber mief.
1l'R1i'R A.Nn COSTS
If the case goes to beariDg ami tllejudge gmDIS aP.o1I-(:i:on OJdrr, a su:charge,ofS2S,OO
will be aiseSSIld against you. You may also be RqUiIIllIIO pay 8llDmey fees to Legal Set'Yices,
IIIc. Cor their .~ of tile pJaiatiff.
YOU SHODLD TAKE 'lBIS PAPER'l'O YaUlt LAWXu. AT ONCE. IF YOU
DO NOT HAVE A LAWYER OR CANNOT.AnOBD ONE, GO 'l'O OR TELEPHONE
THE OFFICE SEr FORm BELOW 'l'O mm om wlWl& YOU CAN GET LEGAL
HELP.
COURT ADMINISTRATOR. 4th FLOOR
, CUMBERLAND COUNTY COURTHOUSE
CARUSLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
[
t
!
Ii
I
I'
I
I
~
'.
.1-'"
~~"~t.
..
'~~N 1 ~, ZOO~
I
I
r.
i
i
I
I
Amy M. Hartman,
: IN THE COURT OF COMMON PLEAS
Plaintiff
: OF CUMBERLAND COUNTY, PENNSYL VANIA
I
VS.
: NO. oo-31..jL.\ CIVIL TERM
Peter Michael Pollack,
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 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 evieted from your
residence and lose other important rights. ' -r"P ", ,
A hearing on this matter is scheduled for the .a:!.:day of January 2000; at
-p-.m" in Courtroom No. a of the Cumberlantl 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 police may arrest you.
Violation of this Order may subject-you to a charge of indirect criminal contempt which is
punishable by a fme of up to $1,000.00 and/or up to six mOliths 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
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
HELD. IF YOU CANNOT FIND A LAWYER, YOU MAY HAVE TO PROCEED
WITHOUT ONE.
i
~
I
i
'~
f'
,
I
i
~
i
r
i
I
CUMBERLAND 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 blllsiness before the court. You must attend the scheduled conference or
hearing.
, ,
~ ',<1,
.
"
.'
Amy M. Hartman,
Plaintiff
: IN THE COURT OF COMMON PLEAS
: OF CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: NO. 00 -
CIVIL TERM
Peter Michael. Pollack,
Defendant
: PROTECTION FROM ABUSE
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name: Peter Michael Pollack
Defendant's Date of Birth: September 26, 1966
-'.:; .
Defendant's Social Security Number: Unknown to Plaintiff
MHt
Names of the Protected Person: Amy M. Hartman
~-_.-
AND NOW, this \ ~ day of January 2000, upon consideration of the attached Petition
for Protection from Abuse, the court hereby enters the following Temporary Order:
'..,;.~
':;
181 1. Defendant shall not abuse, harass, stalk or threaten any of the above person in any
place where she might be found.
l'
,
:
I
!'
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.
181 3. Defendant is prohibited from having ANY CONTACT with Plaintiff at any
location, including, but not limited, to any contact at Plaintiffs residence or place of
employmeut. Defendant is specifically ordered to stay away from the following locations
for the duration ofthis Order: the plaintiff's residence located at 313 West Green Street,
Mechanicsburg, Cumberland County, Pennsylvania, and her place of employment located
at Alliance Funding, 4900 Ritter Road, Mechanicsburg, Pennsylvania.
181 4. Defendant shall not contact Plaintiff by telephone or by any other meaus, including
through third persons.
-,
. ,,- ~'~
~"
"
.'
I,
I:,
"
Ii
I'
Ii:
~.
, ~_.
r:
L
t
i
~-;
~,:
I:
I'
r
r
~, ;
''''
i:
.
!'
Ii
11
!'
!]
L
~- ;
t'
Ii
ri
ki
!
r
!Ii.,
,
11
"
Ii
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 c,are and control of the Plaintiff in accordance with the terms
of this Order.
1816. Defendant shall immediately relinquish the following weapons to the Sheriffs Office
or a designated local law enforcement agency for the delivery to the Sheriff's Office: A
straight blade knife, approximable 5-6" long, with a black handle that was,used in the
December 11, 1999, incident of abuse.
Defendant is prohibited from possessing, transferring or acquiring any other weapons for
the duration of this Order.
181 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 of fees, but service may be accomplished under
any applicable Rule of Civil Procedure.
This Order shall be docketed in tile 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.
j.;
',!
1:1
"
i"
I'
::
n
; ~
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 fmds that Defendant has
committed another act of abuse or has engaged ina pattern or practice that indicates
continued risk of harm to Plaintiff.
Defendant is enjoined from damaging or destroying any property owned jointly by
the p,arties or owned solely by Plaintiff.
Defendant is to refrain from harassing Plaintiff's relatives.
181 8. A certified copy of this Order shall be provided to the police department where
foe'
,
I
,
"
..
j;
i:
I,
I'
r
i',
Plaintiff resides and any other agency specified hereafter: The Mechanicsburg Police
Department and the Lower Allen Township Police.
o 9. THIS ORDER SUPERSEDES 0 ANY PRIOR PF A ORDER AND
PRIOR ORDER RELATING TO CHILD CUSTODY
o ANY
I
I
I
1'"
j<
18110. THIS ORIDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL MODlFffiD OR TERMINATED BY THIS COURT
AFTER NOTICE AND HEARING.
"
!
NOTICE TO DEFENDANT
.
't,.
Defendant is hereby notified that violation of this Order may result in arrest for
indirect criminal contempt; which is punishable by a fme of up to $1,000.00 and/or up to
six months in jail. 23 Pa.C.S. ~61l4. Consent oCtRe Plaintiff to Defendant's return to the
residence shall not invalidate this Order, which can only be changed or modified through
the filing of approjpriate'court papers for that purpose. 23 Pa.C.S. ~61l3. Defendant is
further notified that violation of this Order may subject himlher to state charges and
penalties under the Pennsylvania Crimes Code and to federal charges and penalties under
the Violence Against Women Act, 18 D.S.C. ~~ 2261-2262. Anv Drotection order eranted
bv a court may be considered in any subseauent'Droceedines, includine child custody
proceedines. under title 23 (l}omestic Relations) of the Pennsvlvania Consolidated Statutes.
NOTICE TO LAW ENFORCEMENT OFFICIALS
r
,
t,
I
I
r!
f
I
,
I
,
f
I
,
This Order shall be enforced by "die police who have jurisdiction over the plaintiffs
residence OR any locations where a violation of this order occurs OR where the defendant
may be located. If defendant violates Paragraphs 1 through 7 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 of law 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 Sheriffs office of the county which
issued this Order, which office shall maintain possession of the weapons until further
Order of this Court, unless the weaponls are evidence of a crime, in which case, the shall
remain with the law enforcement agency whose officer made the arrest.
TR~E COpy FROM RECORD
In Testimooy wiieroof, I r~r;l (jm'c: ssl my Mna
and L'le ~I of said ~~-<,C::j~. Pi.
rhl~ ~- day ~" ~
~', ( Jur, 0 ~_
I .
Prothonotary
BY THE COURT,
/'$1 E~ e>, ~
Judge
-:--"~"
. ~~
.
,<
Amy M. Hartman,
: IN THE COURT OF COMMON PLEAS
Plaintiff
: OF CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 00-
CIVIL TERM
Peter Michael Pollack,
Defendant
: PROTECTION FROM ABUSE
PETITION FOR PROTECTION FROM ABUSE
I. Plaintiffs name is Amy Hartman.
2. The name of the person who seeks protection from abuse is Amy Hartman.
3. Plaintiffs address is 313 West Green Street, Mechanicsburg, Pennsylvania.
4. Defendant is believed to live at 321 Cleveland Avenue, Avalon, Pennsylvania 15202.
Defendant's Social Security Number is unknown to Plaintiff.
Defendant's date of birth is September 26,1966.
Defendant's place of employment is unknown to Plaintiff.
5. Defendant is Plaintiffs former intimate partner.
6. Defendant has been involved in the following criminal court action: Defendant was
arrested on December 15, 1999, and charged with simple assault, terroristic threats, unlawful
restraint, and reckless endangerment.
7. The facts of the most recent incident of abuse are as follows:
On or about January 10,2000, Defendant called Plaintiff at her place of
employment and threatened that she better drop the charges which
intimidated her and exacerbated her The police advised Plaintiff to file
harassment charges saying that a warrant would be issued for his arrest for
violating his bail by intimidating a witness.
8. Defendant has committed the following prior acts of abuse against Plaintiff:
a. On or about December II, 1999, Defendant pulled out a knife, held it
>-..
, "~re; ;
"
rJ
ii
I"
ji
.'
;,<
Ii
I.'~
Ii
I,'j
~:]
1,,-1
j::'1
Ii
,
:j
"
i
'1
"
"
"-'
"
(I
"
lj
II
f;'
'-1
j:1
~' i
"
, ~
U
1-1
II
t.j
,-j
~J
;1
Ii
I:
I
['
Ii
Ii
ij
Ii
H
i1
iJ
1!1
!
,j
~'.
~_ c'
.-,-.;--
.
o
"
to the side of Plaintiff's face, causing her to cut her palm and finger
when she raised her hands to protect herself. Defendant forcefully
pushed Plaintiff onto the bed, got on top of her, restrained her with his
legs, held the knife to her throat resulting in a cut on her ear and
causing her to fear for her life. Defendant threatened Plaintiff stating
that he had to do this, and that she was going to leave there with
emotional and physical injuries. Defendant grabbed a sock and
threatened to stuff it into Plaintiff's mouth when she began to scream.
Defendant refused to allow Plaintiff to leave the room and when she
attempted to do so, he grabbed the knife again, approached her
throwing the knife back and forth between his hands and when she
again attempted to leave, he pushed her back into the room. When
Defendant finally let go, Plaintiff fled to the front office of the hotel
for help, and Defendant drove away. When police arrived they issued
a warrant for his arrest. Charges for simple assault, terroristic threats,
reckless endangennent, and unlawful restraint were filed against
Defendant and a hearing is scheduled for February 10, 2000.
9. Defendant has used or threatened to use the following weapons against Plaintiff: A
straight bladed knife with a black handle that was used in the December 11, 2000 incident of
abuse.
10. The following police department or law enforcement agency in the area in which
Plaintiff lives should be provided with a copy of the Protection Order: The Mechanicsburg Police
Department and the Lower Allen Police Department.
11. There is an immediate and present danger of further abuse from the 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 in any
place where Plaintiff may be found.
B. Order Defendant to stay away from Plaintiffs residence and prohibit Defendant from
attempting to enter any temporary or pennanent residence of 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 residence or place of employment.
..
..
D. Prohibit Defendant from having any contact with Plaintiffs relatives.
E. Order Defendant to pay the costs of this action, including filing fees, service fees, and
surcharge of $25.00.
F. Order Defendant to pay $250.00 to reimburse one of Legal Services, Inc.'s funding
sources for the cost oflitigation in this case.
G. Order the following additional relief, not listed above:
a. Defendant is enjoined from damaging or destroying any property owned
jointly by the parties or owned solely by Plaintiff.
b. Defendant is ordered to refrain from harassing Plaintiff's relatives.
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. Plaintiff will inform the designated
authority of any addresses, other than Defendant's residence, where Defendant can be served.
Plaintiff prays for such other relief as may be just and proper.
Respectfully submitted,
/7)
/r'"!-t '~<-~
..'./Joan Carey
Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
,
, -,
.~",'
"
,
1;0
,
r:
Ii;
t
I,
I'
,
Ii
!
Ii-
i'
;:
if
"
"
,
I
It
If_'
!~
;r,
r
,
I:
k
I'
"
I',
T
!
'"
11ft
~
, . .'
,.
"
i
I
-.
VERIFICATION
I verif'y 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. 94904, relating
to unswom falsification to authorities.
Dated:
" / C (\(,
('-- " - ./ /
I,", .
(Lu (Ill) lire-I? }/r';L
Amy M. H~~, Plaintiff
"-t. --"
d
~_:
,;,:1
i:j
-.1.'
,
;'
"I
r:
I':
','
j:i
>,)
H
1-\
r'
i:
Ii
~
!
-:":