HomeMy WebLinkAbout00-00483
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Becki J. King,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
Braden R. King,
: NO. 00- 1./ 2.3
CIVIL TERM
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 BEARING ON THIS MATTER IS SCHEDULED ON ~e<./. y 2000, AT
J: ,-/S ~.M., IN COURTROOM NO. / OF THE CUMBERLAND
.
COUNTY COURTHOUSE, CARLISLE, PENNSYL VANIA.
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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 ofindirect 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.ll6114. Violation may also subject you
to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18
U.S.C. ll2265, 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. II 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 fmd 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.
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Becki 1. King,
: IN THE COURT OF COMMON PLEAS OF
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Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
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: NO.OO- <ff3
CIVIL TERM
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Braden R. King,
Defendant
: PROTECTION FROM ABUSE
I:'
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name: Braden King
Defendant's Date of Birth: 1/31/64
Defendant's Social Security Number: 165-52-0549
Names of the Protected Person: Becki King
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AND NOW, this 2(; day of "::I 2.S1 u 2J 1 ,2000, upon consideration of the attached
Petition for Protection from Abuse, the court hereby enters the following Temporary
Order:
[g) 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 _ 0 ran y 0 the r
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.
[g) 3. Except for such contact with the minor child/ren as may be permitted under
Paragraph 5 ofthis Order, 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 employment. Defendant is specifically ordered to stay away from the following
locations for the duration of this Order: Any residence Plaintiff may establish and her place
of employment located at Cumberland/Perry Association For Retartded Citizens.
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[&) 4. Except for such contact with the minor children as may be permitted under
Paragraph 5 of this Order, Defendant shall not contact Plaintiff by telephone or by any
other means, including through third persons.
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~ 5. Pending t outcome ofthe fmal hearin in this matter. Plaintiffis awarded
partial stody ofthe follow minor children: Taylor 'ng (DOB3/24/91) a d Noah King
(DOH 7/1 96).
According to the
a) Plaintiff shall have ustody of the childre
begi ing on January 28, 0, from Friday at 5:0 .m. until Mo ay at
which e Plaintiffwill return e children to daycare nd school. PI 'ntiff
shall also ve partial custody 0 e children every We nesday from :00
p.m. until 8: p.m.
b) Except on Mo ays when Plaintiff sh take the childlre daycare an
school, custody excha e shall occur at the sidence of Kar
where Defendant shall drop-off and pick-up chil en.
o 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:
Defendant is prohibited from possessing, transferring or acquiring any other weapons for
the duration of this Order.
[&) 7.
The following additional relief is 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
he 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 practice that indicates risk
of harm to Plaintiff.
Defendant is enjoined from damaging or destroying any property owned jointly hy
the parties or owned solely by Plaintiff.
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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: North Middleton and
Carlisle Borough Police Departments.
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9.
THIS ORDER SUPERSEDES
o ANY PRIOR PF A ORDER and
o ANY PRIOR ORDER RELATING TO CHILD CUSTODY
~ 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 fine of up to $1,000.00 and/or up to six months in jail. 23
Pa.C.S. 96114. 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. 992261-2262. Anv
protection order granted bv a court mav be considered in anv 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 the plaintiffs residence OR
any locations where a violation of this order occurs OR where the defendant may be located. If
defendant violates Paragraphs I through 6 ofthis 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 Sheriffs office of the county which issued this Order, which office
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shall maintain possession of the weapons until further Order of this Court, unless the weaponls
are evidence of a crime, in which case, they shall remain with the law enforcement agency whose
officer made the arrest.
BY THE COURT,
Judge
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Becki J. King,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
vs.
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00- 'If3
CIVIL TERM
Braden R. King,
Defendant
: PROTECTION FROM ABUSE
PETITION FOR PROTECTION FROM ABUSE
1. The Plaintiff is Becki J. King.
2. The name of the person who seeks protection from abuse is Becki J. King
3. Plaintiffs address is 1875 Reservoir Drive Carlisle, Pennsylvania.
4. Defendant is believed to live at the following addressl41 East North Street, Carlisle,
Pennsylvania..
Defendant's Social Security Number is 165-52-0549.
Defendant's date of birth is 1/31/64.
Defendant's place of employment is with the West Shore School District.
5. Defendant is Plaintiffs husband.
6. Plaintiff and Defendant have been involved in the following court actions for divorce,
custody, support, or protection from abuse:
Case name
King v King
Case No. Date fIled
01086 Support 12/20/99
Court
Cumberland Co.-Common Pleas
7. Plaintiff seeks temporary partial custody of the following children:
Name
Taylor R. King
Address
141 East North Street
Carlisle, P A
Birthdate
3/24/91
Noah J. King
141 East North Street
Carlisle, P A 17013
7/15/96
8. Plaintiff and Defendant are the parents ofthe following minor children:
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Name
Taylor R. King
Noah J. King
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8 years old
3 years old
The following information is provided in support of Plaintiffs request for an Order of
child custody:
a) The children were not born out of wedlock.
b) The children are presently in the custody of Defendant, Braden King, who
resides at 141 East North Street, Carlisle, Cumberland County, Pennsylvania.
c) During the past five years the children have resided with the following persons
and at the following addresses:
Persons children lived with
Defendant and Plaintiff
Address
141 East North Street
Carlisle, PA 17013
When
1991 to Oct.1999
Defendant
141 East North Street
Carlisle, P A 17013
Oct. 1999 to present
d) Plaintiff, the mother of the children, is, currently residing at 1875 Reservoir
Drive, Carlisle, Cumberland County, Pennsylvania.
e) She is married.
f) Plaintiff currently resides with the following persons:
Name
Ronald Shughart
Adam Shughart
Relationship
Friend
Friend's son
g) Defendant, the father of the children, is, currently residing at 141 E North Street,
Carlisle, Cumberland County, Pennsylvania.
h) He is married.
i)
Name
Rhiannon Hall
Taylor King
Defendant currently resides with the following persons.
Relationship
Step-Daughter
Son
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Noah King
Son
j) Plaintiff has not previously participated in any litigation concerning custody of
the above mentioned children in this or any other Court.
k) Plaintiffhas no knowledge of any custody proceedings concerning there children
pending before a court in this or any other jurisdiction.
I) Plaintiff does not know any person not a party to this action who has physical
custody of the children or claims to have custody or visitation rights with respect to the
children.
m) The best interests and permanent welfare of the minor children will be met if
partial custody is granted to Plaintiff pending further order of court in this matter for
reasons including:
I) It is in the children's best interest to continue their relationship
with Plaintiff who has provided for the emotional and physical
needs of the children since their births.
2) Since October 1999 when Plaintiff left the marital residence to
avoid further abuse, Defendant has unreasonably restricted her
contact with the children to periods at his residence.
3) When Plaintiff goes to Defendant's residence to see her children,
Defendant harasses her exacerbating her fear.
4) Since Plaintiff temporarily resides with a friend, she requests
partial custody until such time as she establishes adequate
housing for herself and her children.
9. The facts of the most recent incident of abuse are as follows:
On or about December 26, 1999, Defendant grabbed Plaintiff by the back of her
arms, spun her around, and screamed in her face. Defendant grabbed her by the
back of her jeans, and threw her against the kitchen cabinets causing her to fall
to the floor resulting in bruises on her arm and a bump on her head. When
Plaintiff fled to her car to avoid further abuse, Defendant followed her, raised
both of his arms, and hit her car window with his hands causing her to fear for
her safety.
10. Defendant has committed the following prior acts of abuse against Plaintiff:
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a)
In or about the Fall of 1999, Defendant grabbed Plaintiff by her arms and her
hair, screamed at her, and pushed her. Defendant grabbed Plaintiffs breast and
crotch area and refused to allow her to leave the bed.
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b)
In or about Fall of 1998, Defendant punched Plaintiff in the face while they were
in the car causing her nose to swell and bleed.
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c)
Since approximately 1988, Defendant has abused Plaintiffin ways including the
following: grabbed, pushed, and kicked Plaintiff; restrained her by holding her
against a wall, pulled her head back by her hair, and on one occasion, pulled the
car off of the road and pulled Plaintiff out of the car.
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II. The following police departments or law enforcement agencies in the area in which
Plaintiff lives should be provided with a copy of the Protection Order: North Middleton and
Carlisle Borough Police.
12. There is an immediate and present danger of further abuse from Defendant.
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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 from Plaintiffs residence and prohibit Defendant from attempting
to enter any temporary or p=anent residence of the Plaintiff.
c. Award Plaintiff temporary partial custody of the minor children according to the
following schedule:
a) Plaintiff shall have custody of the children every other weekend
beginning on January 28, 2000, from Friday at 5:00 p.m. until Monday at
which time PlaintiffwiIl return the children to daycare and school. Plaintiff
shall also have partial custody ofthe children every Wednesday from 5:00
p.m. until 8:00 p.m.
b) Except on Mondays when Plaintiff shall take the children daycare and
school, custody exchange shall occur at the residence of Karen Saporito
where Defendant shall drop-off and pick-up children.
D. 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
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to, any contact at Plaintiffs residence or employment, except as the Court may find
necessary with respect to partial custody and/or visitation with the minor children.
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E. Prohibit Defendant from having any contact with Plaintiffs relatives, except as
the court may find necessary with respect to partial custody and/or visitation with the
minor children.
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F.
Order Defendant to pay the costs of this action, including filing and service fees.
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G. Order Defendant to reimburse Cumberland County, a Legal Services funding
source, $250.00 for the value of the legal services provided to Plaintiff for the cost of
litigating this case ifthe case goes to hearing.
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H. Order the following additional relief, not listed above:
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Grant such other relief as the court deems appropriate.
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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 or the minor
children.
1. 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.
Plaintiff prays for such other relief as may be just and proper.
Respectfully submitted,
Date: I - c:2./; - H
oan Carey, Attorney for B 'ntiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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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. !i4904,
relating to unsworn falsification to authorities.
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Dated:
/-(-/-o 0
Becki Kin
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Becki J. King,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO.OO-483 CIVIL TERM
Braden R. King,
Defendant
: PROTECTION FROM ABUSE
ORDER FOR CONTINUANCE
AND NOW, this ~ day of February 2000, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on February 4, 2000, by this Court's Order of
January 26, 2000, is hereby rescheduled for hearing on ",1\ Q.A..C~ 2:J ,2000,
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at \ \ :t>DD.IIl. in Courtroom No.1.
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 Carlisle
and North Middleton Police Departments by plaintiffs attorney.
eT, Jr., Judge
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
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Braden King
PRO SE DEFENDANT
141 East North Street
Carlisle, PA 17013
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Becki J. King,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO.OO-483 CIVIL TERM
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Braden R. King,
Defendant
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
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The Plaintiff, Becki King, by and through her attorney, Joan Carey of Legal Services, Inc.,
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moves the Court for an Order rescheduling the hearing in the above-captioned case on the
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grounds that:
I. A Temporary Protection From Abuse Order was issued by this Court on January 26,2000,
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scheduling a hearing for February 4, 2000, at 3:45 p.m.
2. The Cumberland County Sheriffs Department served Defendant with a certified copy of
the Temporary Protection From Abuse Order and Petition for Protection From Abuse at his
residence,141 East North Street, Carlisle, Pennsylvania on January 26, 2000, at 7:20 p.m.
3. The parties agree 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.
5. Certified copies of the Order for Continuance will be delivered to the Carlisle and North
Middleton Police Departments by the attorney for the Plaintiff.
WHEREFORE, the Plaintiff requests that the Court grant this Motion and reschedule this
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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,
Carey, Attorne for Plaintiff
LEGAL SERVICES, INe.
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-00483 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
KING BECKI J
VS
KING BRADEN R
SHANNON M SUNDAY
Sheriff or Deputy Sheriff of
Cumberland County, pensylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE
was served upon
KING BRADEN R
the
DEFENDANT
, at 1920:00 HOURS, on the 26th day of January
2000
at 141 E NORTH ST
CARLISLE, PA 17013
by handing to
BREDEN R KING
a true and attested copy of PROTECTION FROM ABUSE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So
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18.00
3.10
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10.00
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31.10
R. Thomas Kline
00/00/0000
Sworn and Subscribed to before
By:
~fn.~.
, Deputy Sheriff
me this -i6t: day of
1~""'''1 ~ A.D.
~a.~~~~
. Prothonotary'
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Becki J. King,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO.00-483 CIVIL TERM
Braden R. King,
Defendant
: PROTECTION FROM ABUSE
ORDER FOR CONTINUANCE
AND NOW, this ~ day of March, 2000, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on March 3, 2000, by this Court's Order of
February 3, 2000, is hereby rescheduled for hearing on 'YY)~ ?J ()
at t' : r:tsr.m. in Courtroom No.1.
The Temporary Protection From Abuse Qrder shall remain in effect for a pecigg gf 6fl~
~e"2i~l:Jt:tb\' ft~.~;~~~dJ ~-intb fi~1d:r ~er'of Conn, whlchev"l e13FR€~ Yc.st.
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
Oler, Jr., Judge
Braden King
PRO SE DEFENDANT
141 East North Street
Carlisle,PA 17013
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Becki 1. King,
Plaintiff
: IN THE COURT OP COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: NO.00-483 CIVIL TERM
Braden R. King,
Defendant
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
The Plaintiff, Becki King, 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 Prom Abuse Order was issued by this Court on January 26,2000,
scheduling a hearing for February 4,2000, at 3:45 p.m.
2. The Cumberland County Sheriffs Department served Defendant with a certified copy of
the Temporary Protection From Abuse Order and Petition for Protection Prom Abuse at his
residence,141 East North Street, Carlisle, Pennsylvania on January 26, 2000, at 7:20 p.m.
3. The parties agree 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.
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WHEREFORE, the Plaintiffrequests 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,
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,loan Carey, Attome or Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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Becki 1. King,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO.00-483 CIVIL TERM
Braden R. King,
Defendant
: PROTECTION FROM ABUSE
ORDER FOR CONTINUANCE
AND NOW, this 3zl ~ay of March, 2000, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on March 30, 2000, by this Court's Order of
March 3, 2000, is hereby rescheduled for hearing on April 17, 2000, at4 00 p.m. in Courtroom
No.1.
The Temporary Protection From Abuse Order shall remain in effect pending a hearing
in the matter.
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
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Braden King
PRO SE DEFENDANT
141 East North Street
Carlisle, P A 17013
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Becki J. King,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO.00-483 CIVIL TERM
Braden R. King,
Defendant
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
The Plaintiff, Becki King, 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 26,2000,
scheduling a hearing for February 4, 2000, at 3:45 p.m.
2. A Continuance was entered March 3, 2000, scheduling a hearing for March 30, 2000, at
11 :00 a.m.
3. The parties agree 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.
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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,
an Carey, Attorney for P ntiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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Becki King,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 00-483 CIVIL TERM
Braden King,
Defendant
: PROTECTION FROM ABUSE
ORDER OF COURT
AND NOW, this tit flday of April 2000, upon consideration of the attached Petition, the
Temporary Protection Order in the above-captioned case entered on January 26, 2000, is hereby
vacated and the action withdrawn without prejudice to Plaintiff.
Joan Carey- ~ ~ ~. /)-0 0
Attorney for Plaintiff
LEGAL SERVICES, INC.
BradenKing - ~ ~ -',/./).t7t:1
PRO SE DEFENDANT
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Becki King,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
v.
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00-483 CIVIL TERM
Braden King,
Defendant
: PROTECTION FROM ABUSE
PETITION TO VACATE ORDER
AND WITHDRAW ACTION
Plaintiff, Becki King, by and through her attorney, Joan Carey, of Legal Services, Inc.,
requests that the Court vacate the Final Protection Order in the above-captioned case and that the
action be withdrawn on the grounds that:
1. A Petition for Protection From Abuse was filed and a Temporary Protection From
Abuse Order was issued by this Court on January 26, 2000.
2. The plaintiff requests that the above-referenced Protection From Abuse action be
withdrawn without prejudice.
3. Plaintiff and Defendant have agreed to the entry of a Temporary Custody Order which
will be filed under a separate number.
4. Plaintiff further requests that the Temporary Protection Order of January 26, 2000,
be vacated.
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WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate
the Order, and that the action be withdrawn without prejudice to Plaintiff.
Respectfully submitted,
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Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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VERIFICATION
I verify that I am the Plaintiff 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 unsworn falsification to authorities.
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Dated:
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