HomeMy WebLinkAbout00-00667
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MATTHEW EVAN TAYLOR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL V ANlA
V.
00-667 CNIL
MINDY JEAN TAYLOR,
Defendant
: CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this I ,,- day of AUGUST, 2000, this Court certifies that the
attached complaint has been properly completed and verified, and there is probable cause
for the issuance of process. In consideration of the attached Commonwealth's Petition,
the defendant, MINDY JEAN TAYLOR, is directed to appear for trial on the charge of
Indirect Criminal Contempt before the Court on the ;LISt" day of _~\A.s-t ,2000 at
J!L 0' clock (L .m. in Courtroom # 3 of the Cumberland County CoUrthouse, Carlisle,
Pennsylvania.
The defendant has a right to be represented by an attorney. If the defendant
cannot afford an attorney, upon request one will be assigned to represent the defendant.
If the defendant wishes assignment of counsel, contact should be made prior to trial with
the CUIllberland County Public Defender's Office at 717-240-6285. Further, if the
defendant fails to appear, an arrest warrant will be issued.
The Sheriff of Cumberland County is directed to serve this Order and Petition
upon the defendant. The assessment of costs to be determined by the Trial Judge
subsequent to trial.
By the Court,
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Jonathan R. Birbeck,
Chief Deputy District Attorney ~;t;, ;D.II. f.I'f-cr0
MINDY JEAN TAYLOR
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MATTHEW EVAN TAYLOR,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: 00-667 CIVIL
MINDY JEAN TAYLOR,
Defendant
: CHARGE: INDIRECT CRIMINAL CONTEMPT
COMMONWEALTH'S PETITION FOR A HEARING ON CHARGES
OF INDIRECT CRIMINAL CONTEMPT
Jonathan R. Birbeck, Chief Deputy District Attorney of Cumberland County,
Pennsylvania, brings the following Petition for a hearing on charges of Indirect Criminal
Contempt:
I. A Protection from Abuse Order was issued by the Court. A true and correct
copy of the Order is attached.
2. The defendant's violation of this Order is averred in the attached criminal
complaint.
3. The victim requests the filing of an Indirect Criminal Contempt Charge.
4. The District Attorney's Office approves the filing of this criminal complaint.
5. The Commonwealth is requesting a hearing on the charges of Indirect
Criminal Contempt pursuant to 23 Pa.C.S.A. 9 6113.
6. The plaintiff and/or the defendant may seek modification of the Order based
on the filing ofthis petition as the Court deems appropriate following the trial
in addition to any other sentence. 23 Pa.C.S.A. 9 6113.
WHEREFORE, the Commonwealth requests the defendant be commanded to
appear before the Court on the charge of Indirect Criminal Contempt.
Respectfully submitted,
.
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COMMONWEALTH'OF PENNSYLVANIA
COUNTY OF CUIV)BERLAN~
09201
CRIMINAL COMPLAINT AND
PROBABLE CAUSE AFFIDAVIT
Mag. Dlsl. No.:
P.ddress:
1 COURTHOUSE SQ
CARLISLE PA 17013
717 240 6565
DEFENDANT:
COMMONWEALTH OF
PENNSYLVANIA
VS.
DJ Name: Hon.
PAULA P CORREAL
Telephone:
AKA:
NAME and ADDRESS
MINDY JEAN TAYLOR
132 W NORTH ST
CARLISLE
APT 2
PA 17013 0000 00
MINDY TAYLOR
JEAN TAYLOR
Docket No,:
Date Filed:
OTN:
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Registration Number
Annual Sticker Number
D.O.B.: 02 19
OLN Number
I PA25419077
I 20008~~~~r3 CAR
1979 8.8.#: 204
SID Number
Complaint Numbers If other Participants
I
1642ucRNumb"
60 9967
Complaint Number
R.8A:
WF 21
ORINO.:
PA0210200
District Attorney's Office _ Approved -Disapproved because:
(The District Attorney may require that the complaint, arrest warrant affidavit, or both be approved by the attorney for the Commonwealth prior to filing,
Pa.R.Cr,P. 107.) When the alliant Is not a police officer as defined in Rule 51 (C) and the offense(s) charged include(s) a misdemeanor or felony which
does not involve a clear and present danger to any person or the community, the complaint shall be submitted to the attomey for the Commonwealth, who
shall approve or disapprove without unreasonable delay),
(Issue Dale)
(Signature)
I, (N,meo'Aff'""') PO ADOLPHO T HEREDIA BADGE 23
m CARLISLE PD
residing at 53 WEST SOUTH ST CARLISLE PA 17013
do hereby state: (check appropriate area)
1. --K. I accuse the above named defendant, who lives at the address set forth above or,
_ I accuse an individual whose name is unknown to me but who is described as
_ I accuse the defendant whose name and popular designation or nickname is unknown to me and whom I
have therefore designated as John Doe
with violatina the penal laws of the Commonwealth of Pennsylvania at: CARLISLE
132 W'NORTH ST CARLISLE (P'a,e-polft'oa'Sub,I,','on)
in (County) CUMBERLAND on or about 07 11 2000 0343 HRS
Participants were: (if there were participants place their names here, repeating name of above defendant)
2. The acts committed by the accused were:
(Set forth a summary of the facts sufficient to advise the defendant of the nature of the offense charged. Neither the evidence nor the statute
allegedly violated need be cited. nor shall a citation of the statute aliegedly violated, by itself, be sufficient. In a summary case, set forth a
citation of the specific section and sub-section of the statute or ordinance allegedly violated).
** INDIRECT CRIMINAL CONTEMPT - CSA1990
CTS
1
THE ACTOR DID VIOLATE THE PROTECTION FROM ABUSE ORDER
NUMBER 00-667
THE ORDER WAS SIGNED BY THE HONORABLE GEOGE E.HOFFER
THE ORDER WAS DATED 9 FEBRUARY 2000
Copy: District Justice
Defendant
Retwn of Service
Pollee
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Page 2
*'
CRIMINAL COMPLAINT AND
PROBABLE CAUSE AFFIDAVIT
Defendant Name:MINDY JEAN TAYLOR
Docket Number:
THE ACTOR VIOLATED THE ORDER BY STRIKING MATTHEW EVAN TAYLOR
ABOUT THE FACE, HEAD AND NECK CAUSING A LACERATION TO THE RIGHT
SIDE OF THE NECK AND PAIN IN THE UPPER LIP.
ALL OF WHICH WERE AGAINST THE PEACE AND DIGNITY OF THE COMMONWEALTH OF
PENNSYLVANIA AND CONTRARY TO THE ACT OF ASSEMBLY,
OR IN VIOLATION OF 6113 A OF THE ACT OF 23
OR THE ORDINANCE OF
3. I ask that arrant of arrest r a~t1I,,,/IeFlS be issued and that the accused be required to answer the charges
I have made. r or a warrant of arrest to issue, the attached affidavit of probable cause must be
completed and sworn to before the issuing authority.)
4. I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information
and belief. I certify the complaint has been properly completed and verified, and that there is probable cause
for the issuance of process. This verification is made subject to the penalties of Section 4904 of the Crimes
Code (18 PA. C.S. 4904) relating to unsworn falsificatio th 'ties. '
Date:
AND NOW, on this date, I certif t complaint has been properly completed and
verified, and that there is probable cause for issuance of process.
(Magisterial UlstrlCl)
{ISSUIng AUthOrity)
(SEAL)
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CARLISLE PD
PROBABLE CAUSE AFFIDAVIT
INCIDENT NUMBER: 20000700543 CAR
DATE: 07/11/2000
OTN:
PG 1
CHARGE (S) :
23 6113
A
INDIRECT CRIMINAL CONTEMPT - CSA1990
#CTS
1
COMMONWEALTH VS MINDY
JEAN
TAYLOR
INFORMATION:
ON 07/11/00 AT 0344 HOURS I WAS DISPATCHED TO THE SQUARE OF THE
CARLISLE BOROUGH, WITHIN CUMBERLAND COUNTY, WITH THE REPORT OF
A SIMPLE ASSAULT DOMESTIC VIOLENCE, UPON ARRIVAL AND MEETING
WITH MATTHEW EVAN TAYLOR,MATTHEW STATED THAT DURING A DISCUSSION
WITH HIS WIFE, MINDY JEAN TAYLOR, HE HAD BEEN PUNCHED SEVERAL
TIMES IN THE FACE. MATTHEW STATED THAT THIS INCIDENT TOOK
PLACE IN THE BEDROOM OF THEIR HOME AT 132 W. NORTH ST.
X
MATTHEW STATED THAT MINDY TAYLOR CONTINUED TO HIT,SCRATCH AND
THROW THINGS AT HIM UNTIL HE WAS ABLE TO GRAB HIS HOUSE KEYS
AND LEAVE THE HOME.
X
AN EXAMINATION OF MATTHEW'S FACE AND NECK REVEALED THE PRESENCE
OF A LARGE ABRASSION ON THE RIGHT SIDE OF HIS NECK. CONTACT WAS
MADE WITH MINDY TAYLOR AT THEIR HOME AT WHICH TIME SHE STATED
MATTHEW HAD HIT HER. AN EXAMINATION OF MINDY'S PERSON SHOWED NO
SIGNS OF INJURY.
I ASK THAT A WARRANT OF ARREST BE ISSUED AND THAT THE ACCUSED BE REQUIRED
TO ANSWER THE CHARGE(S) I HAVE MADE IN THE ABOVE AFFIDAVIT,
I SWEAR TO, OR AFFIRM, THE
AND BELIEF, AND SIGN IT ON
BEFORE
WITHIN AFFIDAVIT UPON MY KNOWLEDGE, INFORMATION
, 20_
WHOSE I
SIGNATURE & SEAL OF DISTRICT JUSTICE
2 COPIES - DISTRICT JUSTICE
1 COPY - BUREAU OF POLICE
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I'EB 0 9 '2000 tP.
~I
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYL VANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
Matthew E. Taylor,
Petitioner
Mindy J. Taylor,
Respondent
NO. 00-667 CIVIL TERM
CONSENT AGREEMENT AND FINAL ORDER
This Agreement is entered on this Cjtlo\. day of February, 2000, by the petitioner,
Matthew E. Taylor, and the respondent, Mindy Taylor. Without admitting the allegations of
abuse, the respondent agrees that the Court shall enter an Order containing the following terms:
1. Respondent shall not abuse, cause reasonable fear of abuse, threaten with violence,
or harass petitioner, whether personally or through her agents.
2. Respondent is evicted and excluded from the residence at 132 West North Street,
Carlisle or any other permanent or temporary residence where petitioner may live. Petitioner
is granted exclusive possession of the residence. Respondent shall have no right or privilege
to enter or be present on the premises, except with petitioner's permission for purposes of
visiting, picking up, and returning the minor children mentioned below.
3. Respondent shall not enter petitioner's residence, currently 132 West North Street,
Carlisle, without petitioner's express permission.
4. The parties shall have shared legal custody of Stephen Harpster and Matthew E.
Taylor, Ir. The petitioner shall have physical custody of the children. The respondent shall
have temporary partial custody of the children at such times as the parties agree upon.
5. The provisions concerning custody shall be considered a temporary custody order that
can be modified pursuant to further agreement or after petition and hearing. However, such
provisions shall remain in full force and effect after the other provisions of this order expire.
6. The Carlisle Police Department shall be provided with a certified copy of this Order
by the petitioner's attorney. This Order shall be enforced by any law enforcement agency where
a violation occurs, by arrest for indirect criminal contempt without warrant upon probable cause
1
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that this Order has been violated, whether or not the violation is committed in the presence of
the police officer. In the event that an arrest is made, the respondent shall be taken without
necessary delay before the court that issued the order. When that court is unavailable the
,
respondent shall be taken before the appropriate district justice. (23 P.S. S61 13).
7. The parties intend to be legally bound by the terms of this agreement and request that
a Protection Order be entered to reflect the above terms. The respondent has been advised of
her right to have a hearing.
8. BRADY INDICATOR:
a) The petitioner and the respondent are married and have one (1) child together,
Matthew E. Taylor, Jr. The petitioner is the step-father of Stephen Harpster.
b) This order is being entered by a consent agreement.
c) This Order res,u-ains the respondent from harassing, stalking, or threatening the
petitioner.
d) Respondent represents a credible threat to the physical safety of the petitioner.
e) The terms of this Order prohibit respondent from using, attempting to use, or threat-
ening to use physical force against the petitioner that would reasonably be expected to cause
bodily injury.
9. THIS ORDER SUPERSEDES ANY PRIOR PF A ORDER.
10. All provisions of this order shall expire in one year, on February qtvt, 2001,
however the petitioner may ask the Court, after notice and hearing, to extend the term of the
Order, pursuant to 23 Pa. C.S. S 6108(e).
NOTICE TO THE RESPONDENT
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 $1,000.00 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 P A.C.S.
S 61l4. 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. SS 2261-2262. 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.
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~~ 2261 -2262. UNDER PARAGRAPH 10, YOU MAY BE SUBJECT TO FEDERAL
PROSECUTION AND PENAL TIES UNDER THE "BRADY" PROVISIONS OF THE GUN
CONTROL ACT, 18 U.S.C. ~~ 922(G),FORPOSSESSION, TRANSPORT OR RECEIPT OF
FIREARMS OR AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over the petitioner's residence OR any location where
a violation of this order occurs OR where the respondent may be located, shall enforce this
order. An arrest for violation of Paragraphs 1 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. ~ 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. When
the respondent is placed under arrest for violation of the order, the respondent shall be taken to
the appropriate authority or authorities before whom respondent is to be arraigned. A
"Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police
officer OR the petitioner. Petitioner's presence and signature are not required to file the
complaint.
If sufficient grounds for violation of this order are alleged, the respondent shall be
arraigned, bond set and both parties given notice of the date of the hearing.
jht?/.t'~f ~
Matthew E. Taylor, Petitioner
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Mi ay, Resp ~nt
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J me L. Jablons ,
Cortified L'g'] In~
Do~~t1f~ttom"
Thomas M. Place, Supervising Attorney
F AMIL Y LAW CLINIC
Counsel for Petitioner
() h... Order
AND NOW, this1- day of February, 2000, the foregoing Agreement is approved and
entered as an Order of Court.
CC'l~1 ~ I'h~~ ~ dL/t%O
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-00667 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
TAYLOR MATTHEW E
VS
TAYLOR MINDY
DAWN KELL
, Sheriff or Deputy Sheriff of
Cumberland County, Pensylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE
was served upon
TAYLOR MINDY
the
DEFENDANT
, at 0008:25 HOURS, on the 7th day of February
2000
at MOLLY PITCHER HOTEL
13 SOUTH HANOVER ST RM 411
CARLISLE, PA 17013
by handing to
MINDY TAYLOR
a true and attested copy of PROTECTION FROM ABUSE
together with
NOTICE OF HEARING & ORDER, TEMPORARY PROTECTION
FROM ABUSE ORDER
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So
A;:;~~t
18.00
3.10
.00
10.00
.00
31.10
R. Thomas Kline
02/07/2000
Sworn and Subscribed to before
me this .2'1 ~
By:
~~.in
Deputy Sheriff
day of
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fEB 0 9 2000 tP
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,PENNSYL VANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
Matthew E. Taylor,
Petitioner
Mindy J. Taylor,
Respondent
NO. 00-667 CIVIL TERM
CONSENT AGREEMENT AND FINAL ORDER
This Agreement is entered on this 9+"'- day of February, 2000, by the petitioner,
Matthew E. Taylor, and the respondent, Mindy Taylor. Without admitting the allegations of
abuse, the respondent agrees that the Court shall enter an Order containing the following terms:
1. Respondent shall not abuse, cause reasonable fear of abuse, threaten with violence,
or harass petitioner, whether personally or through her agents.
2. Respondent is evicted and excluded from the residence at 132 West North Street,
Carlisle or any other permanent or temporary residence where petitioner may live. Petitioner
is granted exclusive possession of the residence. Respondent shall have no right or privilege
to enter or be present on the premises, except with petitioner's permission for purposes of
visiting, picking up, and returning the minor children mentioned below.
3. Respondent shall not enter petitioner's residence, currently 132 West North Street,
Carlisle, without petitioner's express permission.
4. The parties shall have shared legal custody of Stephen Harpster and Matthew E.
Taylor, Jr. The petitioner shall have physical custody of the children. The respondent shall
have temporary partial custody of the children at such times as the parties agree upon.
5. The provisions concerning custody shall be considered a temporary custody order that
can be modified pursuant to further agreement or after petition and hearing. However, such
provisions shall remain in full force and effect after the other provisions of this order expire.
6. The Carlisle Police Department shall be provided with a certified copy ofthis Order
by the petitioner's attorney, This Order shall be enforced by any law enforcement agency where
a violation occurs, by arrest for indirect criminal contempt without warrant upon probable cause
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that this Order has been violated, whether or not the violation is committed in the presence of
the police officer. In the event that an arrest is made, the respondent shall be taken without
necessary delay before the court that issued the order. When that court is unavailable the
,
respondent shall be taken before the appropriate district justice. (23 P.S. S6l13).
7. The parties intend to be legally bound by the terms of this agreement and request that
a Protection Order be entered to reflect the above terms. The respondent has been advised of
her right to have a hearing.
8. BRADY INDICATOR:
a) The petitioner and the respondent are married and have one (1) child together,
Matthew E. Taylor, Jr. The petitioner is the step-father of Stephen Harpster.
b) This order is being entered by a consent agreement.
c) This Order restrains the respondent from harassing, stalking, or threatening the
petitioner.
d) Respondent represents a credible threat to the physical safety of the petitioner.
e) The terms of this Order prohibit respondent from using, attempting to use, or threat-
ening to use physical force against the petitioner that would reasonably be expected to cause
bodily injury.
9. THIS ORDER SUPERSEDES ANY PRiOR PF A ORDER.
IO. All provisions of this order shall expire in one year, on February qW\ , 2001,
however the petitioner may ask the Court, after notice and hearing, to extend the term of the
Order, pursuant to 23 Pa. C.S. S 6108(e).
NOTICE TO THE RESPONDENT
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 $1,000.00 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S.
S 6114. 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
TIlE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. SS 2261-2262. 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.
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992261 -2262. UNDER PARAGRAPH 10, YOU MAY BE SUBJECT TO FEDERAL
PROSECUTION AND PENAL TIES UNDER THE "BRADY" PROVISIONS OF THE GUN
CONTROL ACT, 18 U.S.c. 99 922(G),FORPOSSESSION, TRANSPORT OR RECEIPT OF
FIREARMS OR AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over the petitioner's residence OR any location where
a violation of this order occurs OR where the respondent may be located, shall enforce this
order. An arrest for violation of Paragraphs 1 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. 9 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. When
the respondent is placed under arrest for violation of the order, the respondent shall be taken to
the appropriate authority or authorities before whom respondent is to be arraigned. A
"Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police
officer OR the petitioner. Petitioner's presence and signature are not required to file the
complaint.
If sufficient grounds for violation of this order are alleged, the respondent shall be
arraigned, bond set and both parties given notice of the date of the hearing.
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Matthew E. Taylor, Petitioner
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J e L. Jablons ,
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JJ~Lt ~l_'Y
Thomas M. Place, Supervising Attorney
F AMlL Y LAW CLINIC
Counsel for Petitioner
~~ Order
AND NOW, thi~ day of February, 2000, the foregoing Agreement is approved and
entered as an Order of Court.
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MATTHEW EVAN TAYLOR,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
00-667 CIVIL TERM
MINDY JEAN TAYLOR,
Defendant
CHARGE: INDIRECT CRIMINAL CONTEMPT
IN RE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this 21st day of August, 2000, the
Defendant, Mindy Jean Taylor, having appeared in open court
together with the Public Defender, Timothy L. Clawges, Esquire,
on a petition alleging Indirect Criminal Contempt of the
Protection from Abuse Order, and the Defendant having admitted
the allegations of the petition and having admitted that she is
in contempt of court, the Court so finds her to be in contempt.
The sentence of the Court is that the Defendant
pay any costs of prosecution associated with this petition and
that she undergo imprisonment in the Cumberland County Prison
for a period of not less than six weeks nor more than six
months. We give her credit for time served on this sentence
from July 11, 2000.
By the Court,
Ge r
Jonathan R. Birbeck, E re
Chief Deputy District Attorney
.J.
Probation
Sheriff
CCP
Victim - Witness
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Timothy L. Clawges, Esquire
Assistant Public Defender
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CERTIFICATIOO OF PFA CXJIlTEMPI'
CASE lUffiER 0 0 - 6 6 7
NAME MINDY JEAN TAYLOR
13 S. ~ANOVER ST., ROOM 411
CARlISLE PA 17013
VICTIM'S NAME:
MATTHEW EVAN TAYLOR
BALANCE DUE: $ 103.10
NAME
ADD DELETE
$ $
$ $ .
$ 32.60 $
$ 10.00 $
$ 15.00 $
$ 45.50 $
170 STATE SURCHARGE
171 STATE FINE
260 SHERIFF COST ($1.50 + ADDTL)
207 DISTRICT ATTORNEY
204 COURT COSTS (CLERK OF COURTS)
502 RESTITUTION
PROTHONTOARY
ADDRESS
CITY
STATE
ZIP
NAME
$
$
ADDRESS
CITY
STATE
ZIP
NAME
$
$
ADDRESS
CITY
STATE
ZIP
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PROTHONOTARY OFFICE , , ,
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
Matthew E. Taylor,
Petitioner
Mindy Taylor,
Respondent
~C>O C> - I./. 7
: NO, ~- CIVIL TERM
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following pages, 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 impo trights. ~ jb ;$J/f-
A hearing on the matter is scheduled for the / / 1'; day of l-9- _' at .m., in
Courtroom j at the Cumberland County Courthouse, Pennsy vania.
- ,
You MUST obey the Order that is attached until it is modified or terminated by the court after notice
and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you
to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six
months injail under 23 Pa.C.S. S 6114. Violation may also subject you to prosecution and criminal penalties
under the Pennsylvania Crimes Code. Under federal law, 18 U.S.c. S 2265, this Order is enforceable
anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you
travel outside of the state and intentionally violate this Order, you maybe subject to federal criminal
proceedings under the Violence Against Women Act, 18 U.S.C. SS 2261-2262.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE THE RIGHT
TO HA VEALA WYERREPRESENTYOU AT THE HEARING. THE COURT WILL NOT, HOWEVER,
APPOINT A LA WYERFOR you. IF YOU DO NOT HAVE A LAWYER ORCANNOT 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 MA Y HAVE TO PROCEED WITHOUT
ONE.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17m3
(717) 249-3166
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Matthew E. Taylor,
Petitioner
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANlA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
Mindy Taylor,
Respondent
: 8-DDD -l9.CQ'1
: NO.~ - CIVIL TERM
TEMPORARY PROTECTION FROM ABUSE ORDER
Respondent's Name: Mindy Taylor
Respondent's Date of Birth: 2-19-79
Respondent's Social Security Number: 204-60-9967
Names of All Protected Persons: Matthew E. Taylor
AND NOW, this ~ day of Februarv , 2000, upon consideration of the attached Petition for
Protection From Abuse, the court hereby enters the following Temporary Order:
[x] 1. Respondent shall not abuse, harass, stalk or threaten any of the above persons in any place where they
might be found.
[x] 2. Respondent is evicted and excluded from the residence at 132 West North Street, Carlisle, PA 17013
or any other permanent or temporary residence where petitioner may live. Petitioner is granted
exclusive possession of the residence. Respondent shall have no right or privilege to enter or be present
on the premises.
[x] 3. Except for such contract with the minor child/ren as my be permitted under Paragraph 5 of this Order,
respondent is prohibited from having ANY CONTACT with petitioner at any location, including but
not limited to any contact at petitioner's place of employment. Respondent is specifically ordered to
stay away from the following locations for the duration of this Order:
132 West North Street, Carlisle, P A 17013
[x] 4. Except for such contact with the minor child/ren as may be permitted under Paragraph 5 of this Order,
respondent shan not contact petitioner by telephone or by any other means, including through third
persons.
[x] 5. Pending the outcome of the final hearing in this matter, petitioner is awarded temporary custody of the
following minor child/ren: Stephen Harpster
Matthew E. Taylor, Jr.
Until the final hearing, all contact between respondent and the child/ren shall be limited to the
following: periods of visitation as agreed to by the parties.
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.
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 petitioner in accordance with the terms of this
Order.
[] 6. Respondent shall immediately relinquish the following weapons to the Sheriffs Office or a designated
local law enforcement agency for delivery to the Sheriffs office:
Respondent is prohibited from possessing, transferring or acquiring any other weapons for the duration
of this order.
[] 7. The following additional relief is granted:
[x] 8. A certified copy of this Order shall be provided to the police department where petitioner resides and
any other agency specified hereafter: [insert name of agency]
[] 9. THIS ORDER SUPERSEDES [ ] ANY PRIOR PFA ORDER AND [] ANY PRIOR ORDER
RELATING TO CHILD CUSTODY.
[x] 10.THIS ORDER APPLIES IMMEDIATEL YTORESPONDENT AND SHALL REMAIN IN EFFECT
UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING.
NOTICE TO THE RESPONDENT
Respondent 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 injail. 23 Ps.C.S 9 6114.
Consent of the petitioner to respondent return to the residence shall not validate this Order, which can only be
changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. 9 6113.
Respondent is further notified that violation of this Order may subj ect 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. 99 2261-2262.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the police who have jurisdiction over the petitioner's residence OR any
location where a violation of this order occurs OR where the respondent may be located. If respondent violates
Paragraphs I through 6 of this Order, respondent may be arrested on the charge ofIndirect 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 weapon/s are evidence of a crime, in which case,
they shall remain with the law enforcement agency whose officer made the arrest.
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Matthew E. Taylor,
Petitioner
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
Mindy Taylor,
Respondent
NO. 98 -
CIVIL TERM
PETITION FOR PROTECTION FROM ABUSE
I. Petitioner's name is: Matthew E. Taylor
2. I am filing this Petition on behalf of [x] Myself and/or [] Another Person.
If you checked "myself," please answer all questions referring to yourself as "Petitioner." If you
checked "another person," please answer all questions referring to that person as the "Petitioner," and
provide your address here, unless confidential: 132 West North Street, Carlisle, P A 17013
If you checked "Another Person," indicate your relationship with petitioner:
[]parent of minor petitioner( s) []applicant for appointment as guardian ad litem of minor petitioner(s)
[]adult household member with minor petitioner(s) []court appointed guardian of incompetent
petitioner( s)
3. N ame( s) of ALL person( s), including petitioner and minor children, who seek protection from abuse:
Matthew E. Taylor
4, [] Petitioner's address is confidential or
[x] Petitioner's address is: 132 West North Street, Carlisle, PA 17013
5. Respondent is believed to live at the following address: 13 South Hanover Street, Rm 411, Carlisle
Respondent's Social Security Number (if known) is: 204-60-9967
Respondent's date of birth is: 2-19-79
Respondent's place of employment is: Unknown
6. Indicate the relationship between petitioner and respondent.
[x] Spouse [] Current/former sexuaVintimate partner
[] Ex-spouse [] Parent/child
[] Persons who live or have lived like spouses [] Other relationship by blood/marriage
[] Parents of the same children
7. Have petitioner and respondent been involved in any of the following court actions?
[] Divorce [] Custody [x] Support [] Protection From Abuse
If you checked any of the above, briefly indicate when and where the case was filed and the court
number if known: The case was filed by the petitioner on or about January 20, 2000 at the Domestic
Relations office. The Case no. is 030101924
8. Has the respondent been involved in any criminal court action? Yes.
If you answered Yes, is the respondent currently on probation? No.
9. Petitioner and respondent are parents of the following minor child/ren:
Name Ages Who reside at (list address unless confidential)
Steven Harpster 2 132 West North Street, Carlisle
Matthew E. Taylor, Jr. 1 132 West North Street, Carlisle
Steven H<l!l?ster i.s the biological son of respondent and has resided with the petitioner since October
1997. PetitIoner IS the stepfather Steven Harpster. The biological father of the child is unknown.
10. If petitioner and respondent are parents of any minor child/ren together is there an existing court Order
regarding their custody? No. '
If you answered Yes, describe the terms of the Order (e.g., primary, shared, legal and/or physical
custody):
If you answered Yes, in what county and state was the order issued?
If you are now seeking an Order of child custody as part ofthis petition, list the following information:
Child's Name
Steven Harpster
Person(s) child lived with
Mother, Stepfather, brother
Mother, Father, brother
Address, unless confidential When
132 West North Street 11/99-
Pres.
132 West North Street 11/99-
Pres.
Matthew E. Taylor, Jr.
(b) List any other persons who are known to have or claim a right to custody of each child listed above.
Name Address Basis of Claim
The father of Steven Harpster is unknown.
11. The following other minor child/ren presently live with petitioner:
Name(s) Age(s) Petitioner's relationship to child/ren
12. The facts of the most recent incident of abuse are as follows:
Approximate Date: December 28, 29, 1999 Approximate Time: 11 :00 p.m.
Place: 132 West North Street, Carlisle
Describe in detail what happened, including any physical or sexual abuse, threats, injury, incidents of
stalking medical treatment sought, and/or calls to law enforcement:
Late in the evening of December 28, 1999, the petitioner and the respondent came home from a night
out. The respondent had been drinking and an argument ensued. The respondent began pushing and
hitting the petitioner. She also began throwing objects at him. The petitioner went to the Carlisle
Police Department for help and was escorted back to the house. By this time, -the respondent had
passed out and the officer left. A little later the respondent woke up and came down stairs. The
respondent began yelling again, knocked over the television set, threatened the petitioner with a knife,
and finally bit the petitioner on the left cheek. The bite broke the skin and caused petitioner substantial
pain. The petitioner was in reasonable fear of serious bodily injury.
13. If the respondent has committed prior acts of abuse against petitioner or the minor child/ren, describe
these prior incidents, including any threats, injuries, or incidents of stalking, and indicate approximately
when such acts of abuse occurred:
a) On or about Thanksgiving, 1998, the respondent and petitioner got into an argument at their
apartment. During the course of the argument, the respondent began hitting the petitioner. The
. .
respondent repeatedly hit the petitioner in the face causing his cheek swell which did not allow him
to open his eye. During the argument, the petitioner's lip was cut open. B~th of these injuries led to
causing the petitioner substantial pain.
b) Sometime during April, 1998, the respondent and petitioner were test driving a car when an
~gument ensued about when they would be able to purchase the car. The respondent threatened to
Jump out .of t~e car and then punched the petitioner in the side of the face, catching his ear with a ring,
and causmg It to bleed. As a result of this course of conduct, the respondent caused petitioner
substantial pain.
14. List the weapon(s) that respondent has used or threatened to use against petitioner or the minor
child/ren: None.
IS. IdentifY the police department or law enforcement agency in the area in which petitioner lives that
should be provided with a copy of the protection order: Carlisle Police Department
16. There is an immediate and present danger of further abuse from the respondent.
CHECK THE FOLLOWING BOXES ONLY IF THEY APPLY TO YOUR CASE AND PROVIDE
THE REQUESTED INFORMATION
[x] Petitioner is asking the court to evict and exclude the respondent from the following residence:
132 West North Street, Carlisle
[] owned by (list owners, ifknown):
[x] rented by (list all names, if1mown): Matthew and Mindy Taylor
[] Respondent owes a duty of support to petitioner and/or the minor children.
[] Petitioner has suffered out-of-pocket financial losses as a result ofthe abuse described above. Those
losses are:
FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY
ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING (CHECK
ALL FORMS OF RELIEF REQUESTED):
[x] A. Restrain respondent from abusing, threatening, harassing, or stalking petitioner in any place where
petitioner may be found.
[ x] B. Evict/exclude respondent from petitioner's residence and prohibit respondent from attempting to enter
any temporary or permanent residence of the petitioner.
[] C. Require respondent to provide petitioner and/or minor child/ren with other suitable housing.
[x] D. A ward petitioner temporary custody of the minor child/ren and place the following restrictions on
contact between respondent and child/ren: Visitation at times agreed upon by the parties.
[]F.
Prohibit respondent from having any contact with petitioner either in person, by telephone, or in
writing, personally or through third persons, including but not limited to any contact at petitioner's
place of employment, except as may be necessary for respondent to exercise partial custody at times
to be decided by the parties.
Prohibit respondent from having any contact with petitioner's relatives and petitioner's children listed
in this Petition, except as the court may find necessary with respect to partial custody and/or visitation
[x]E.
with the minor child/ren.
[] G. Order the respondent to temporarily turn over weapons to the Sheriff for this County and prohibit
respondent from transferring, acquiring or possessing any such weapons for the duration of the Order.
[] H. Order respondent to pay temporary support for petitioner and/or the minor child/ren, including medical
support and [] payment of the rent or mortgage on the residence.
[] 1. Direct respondent to pay petitioner for the reasonable financial losses suffered as the result of the abuse,
to be determined at the hearing.
[x] J. Order respondent to pay the costs of this action, including filing and service fees.
[] K. Order respondent to pay petitioner's reasonable attorney's fees.
[] L. Order the following additional relief, not listed above:
[x] M. Grant such relief as the court deems appropriate.
[x] N. Order the police or other law enforcement agency to serve the respondent 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 respondent's residence, where respondent can be served.
e L. Jao on i
rtified Legal ntern
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ROBERT E. RAINS
Supervising Attorneys
DONALD MARRITZ
Staff Attorney
F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
717/243-2968
VERIFICATION
Understanding that the making of any false statement would subject me to the penalties of 18 Pa.C.S
S 4904, I verifY that I am the Petitioner in the present action, and th.at the fa~ts and state.ments contained in the
above Petition are true and correct, to the best of my knowledge, mformatlOn and belIef.
2/"100
Date
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Matthew E. Taylor
Matthew E. Taylor,
Petitioner
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
Mindy Taylor,
Respondent
NO. 98 -
CIVIL TERM
FINAL ORDER OF COURT
Respondent's Name: Mindy Taylor
Respondent's Date of Birth: 2-19-79
Respondent's Social Security Number: 204-60-9967
Names of All Protected Persons, including petitioner and minor children:
Matthew E. Taylor
AND NOW, this. day of , 19_, the court having jurisdiction over the parties and
the subject-matter, it is ORDERED, ADruDICA TED and DECREED as follows:
Note: Space is provided to allow for 1) the court's general findings of abuse; 2) inclusion of the terms
under which the order was entered (e.g., that the order was entered with the consent of the parties, or that the
respondent, though properly served, failed to appear for the hearing, or the reasons why petitioner's request
for a fmal PF A order was denied); and/or 3) information that may be helpful to law enforcement (e.g., whether
a weapon was involved in the incident of abuse and/or whether the respondent is believed to be armed and
dangerous).
[] Petitioner's request for a final protection order is denied. OR
[] Petitioner's request for a final protection order is granted.
[]l.
Respondent shall not abuse, stalk, harass, threaten the petitioner or any other protected person in any
place where they might be found.
[]
Respondent is completely evicted and excluded from the residence at [NONCONFIDENTIAL
ADDRESS FROM WHICH RESPONDENT IS EXCLUDED] or any other residence where petitioner
may live. Exclusive possession of the residence is granted to petitioner. Respondent shall have no right
or privilege to enter or be present on the premises.
On , respondent may enter the residence to retrieve his/her clothing and other personal
effects, provided that respondent is in the company of a law enforcement officer when such retrieval
is made.
[] 2,
[]3.
[] 4.
[] 5.
[] 6.
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[] 8.
[] 9.
[] 10.
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[] 12.
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Except as provided in Paragraph 5 of this Order, respondent is prohibited from having ANY
CO.~TA~T with the .petitioner at any location, including but I,1ot limited to any contact at the
petItIOner s school, busmess, or place of employment. Respondent IS specifically ordered to stay away
from the following locations for the duration of this Order.
Except as provided in Paragraph 5 of this Order, respondent shall not contact the petitioner by
telephone or by any other means, including through third persons.
Custody of the minor children, [names of the children subject to 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.]
Respondent shall immediately turn over to the Sheriffs Office, or to a local law enforcement agency
for delivery to the Sheriffs Office, the following weapons used or threatened to be used by respondent
in an act of abuse against petitioner and/or the minor child/ren.
Respondent 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.
The following additional relief is granted as authorized by S 610S of the Act:
Respondent 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 ofthe 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 the petitioner does not file a complaint for support with
the court within fifteen days of the date of this order. The amount of this temporary order does not
necessarily reflect respondent's correct support obligation, which shall be determined in accordance
with the guidelines at the support hearing. Any adjustments in the fmal amount of support shall be
credited, retroactive to this date, to the appropriate party.
The costs of this action are waived as to the petitioner and imposed on respondent.
[] Respondent shall pay $ to petitioner as compensation for petitioner's out-of-pocket losses, which
are as follows:
OR
[] Petitioner is granted leave to present a petition, with appropriate notice to respondent, 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.
BRADY INDICATOR.
The petitioner or protected person(s) in a spouse, former spouse, a person who cohabitates or has
cohabitated with the respondent, a parent of a common child, a child of that person, or a child of the
respondent.
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[] 2. This order is being entered after a hearing of which the respondent received actual notice and had an
opportunity to be heard.
[] 3, Paragra.ph 1 o~ ~his Order has been checked to restrain the respondent from harassing, stalking, or
threatenIng petItIOner or protected person(s).
[] 4. Respondent represents a credible threat to the physical safety of the petitioner or other protected
person(s) OR
[] The terms of this Order prohibit respondent from using, attempting to use, or threatening to use physical
~o:ce against the petitioner or protected person that would reasonably be expected to cause bodily
mJury.
[] 13. THIS ORDER SUPERSEDES [] ANY PRlOR PFA ORDER AND [] ANY PRlORORDER
RELATING TO CHILD CUSTODY.
14. All provisions of this order shall expire in one year, on [insert expiration date].
NOTICE TO THE RESPONDENT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF
INDIRECT CRlMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF UP TO $1,000.00
AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 P A.C.S. S 6114. VIOLATION MAY ALSO
SUBJECT YOU TO PROSECUTION AND CRlMINAL PENAL TIES UNDER THE PENNSYLVANIA
CRlMES CODE. THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRlCT OF
COLUMBIA, TRIBAL LANDS, U.S, TERRlTORlES AND THE COMMONWEALTH OF PUERTO RlCO
UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. SS 2261-2262. IF YOU TRAVEL
OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER YOU MAYBE 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. SS 922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR
AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over the petitioner's residence OR any location where a violation of
this order occurs OR where the respondent 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. 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 [insert the appropriate name or
title] shall maintain possession of the weapons until further order of this court. When the respondent is placed
under arrest for violation of the order, the respondent shall be taken to the appropriate authority or authorities
before whom respondent is to be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be
completed and signed by the police officer OR the petitioner. Petitioner's presence and signature are not
required to file the complaint.
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If sufficient grounds for violation of this order are alleged, the respondent shall be arraigned, bond set
and both parties given notice of the date of the hearing.
BY THE COURT:
Judge
Date
If entered pursuant to the consent of the petitioner and respondent:
(Petitioner's signature)
(Respondent's signature)
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