HomeMy WebLinkAbout00-00762
." " I ' ,~ ""
-j:'''' ,
_._ ,_ ~'_' ~,_I,":H .-
IN
ADELAIDA CASTANEDA WILLIAMS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
vs,
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO, 2000- '7U CIVIL TERM
.
GORDON STANLEY WILLIAMS,
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 proce<:d
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 on the.J..&!:. day of February, 2000, at 10 ,: Ii /J..- .m"
in Courtroom No, ~ of the Cumberland County Courthouse, Carlisle, Pennsylvania,
You MUST obey the Order that is attached until it is modified or terminated by the court after notke
and hearing, lfyou disobey this Order, the police may arrest you, Violation of this Order may subject you
to a cl1arge of indirect criminal contempt which is punishable by a fine ofup to $1,000,00 andlor up to six
months injail 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, lfyou
travel outside of the state and intentionally violate this Order, you may be subject to federal crimiIltal
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 lavvyer represent
you at the hearing, The court will not, however, appoint a lavvyer for you. If you do not have a lavvyer or
cannot afford one, go to or telephone the office set forth below to find out where you can get legal help, If
you cannot find a lawyer, you may have to proceed without one,
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 info1lll3tion about accessible faci1ities and reasonable
accommodations available to disabled individuals having business before the court, please contact our offi(:e.
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.
,.
-/'"''
- , I'
,__"n.
-.0.<."- ,1..",._
, - - - ~~
ADELAIDA CASTANEDA WILLIAMS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
vs,
: NO. 2000-
CIVIL TERM
GORDON STANLEY WILLIAMS,
Defendant
: PROTECTION FROM ABUSE
TEMPORARY PROTECTION
FROM ABUSE ORDER
Defendant's Name: GORDON STANLEY WILLIAMS
Defendant's Date of Birth: 07/01/1942
Defendant's Social Security Number: 366-40-0477
Name QfProtected Peon: ADELAIDA CASTANEDA WILUAMS
AND NOW, th(J~}.,ay of Febmary, 2000, upon consideration of the attached
Petition for Protectionl;t;;- Abuse, the court hereby enters the fonowing Temporary Order:
I&> 1. Defendant shan not abuse, harass, stalk or threaten any of the above persons in
any place where they might be found.
I&> 2. Defendant is evicted and excluded from the residence at Long Meadow
Apartments, SC Richland Lane, Apt. T12, Camp Hill, Cumberland County, Pennsylvania, or
any other pel'llianent 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,
I&> 3. Defendant is prohibited from having ANY CONTACT with Plaintiff at any
location, including, but not limited, to any contact at Plaintiff's current residence, and any
other residence she may, in the future, establish for herself, her school, business, and/or place
of employment.
I&> 4. Defendant shall not contact Plaintiff by telephone or by any other means,
including through third persons.
"'_D_"_, '. l',
,~__ _ .. ,__.J, .
,.,1__;;._"
-
.,;i<>.
o 5, Pending the outcome of the final hearing in this matter, Plaintiff is awarded
temporary custody of the following minor child/ren:
Until the final hearing, all contact between Defendant and the child/ren shall be
limited to the following:
The local law enforcement agency in the jurisdiction where the child/ren are located
shall ensure that the child/ren are placed in the care and control of Plaintiff in
accordance with the terms of this Order,
o 6. Defendant shall immediately relinquish the following weapons to the Sherifi's Office
or a designated local law enforcement agency for the delivery to the Sherift's Office:. Defendant is
prohibited from possessing, transferring or acquiring any other weapons for the duration of this
Order,
(g) 7.
The foRowing additional relief is granted:
The Cumberland County Sheriff's Department shaD attempt to make service at
Plaintifl"s request and withont pre-payment of fees, but service may be
accomplished nnder any applicable Rule of Civil Procedure.
This Order shaD be docketed in the office of the Prothonotary and forwarded
to the SheriJTfor service. The Prothonotary shaD not send a copy oftltis Order
to Defendant by mail.
This Order shaD remain in etTed until modifIed or terminated by the Court and
can be extended beyond its original expiration date if the Court finds that
Defendant has committed an act of abuse or has engaged in a pattern or
,practice that Indicates risk of harm to Plaintiff.
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 Plaintift's relatives.
(g) 8. A certified copy of this Order shaD be provided to the police department where
Plaintiff resides and any other agency specified hereafter: East Pennsboro Township Police
(g) 9.
TIDS ORDER SUPERSEDES ANY PRIOR PFA ORDER.
o ANY PRIOR ORDER RELATING TO CHILD CUSTODY
\W.
-~
.'C
~j
THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAlN
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 injail.
23 Pa,C.S. ~6114. Consent of the Plaintiff to Defendant's return to the residence shall not invalidate
this Order, which can only be changed or modified through the filing of appropriate court papers for
that purpose, 23 Pa.C,S. ~61 B. Defendant is further notified that violation of this Order may subject
him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges
and penalties under the Violence Against Women Act, 18 U.S,c. ~~2261-2262, Any protection order
granted by a court may be considered in any subsequent proceedings, including child custody
proceedings, under title 23 (Domestic Relations) of the Pennsylvania Consolidated Statutes,
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the police who have jurisdiction over Plaintifl's residence
OR any locations where a violation of this order occurs OR where Defendant may be located. If
Defendant violates Paragraphs 1 through 6 of this Order, Defendant may be arrested on the charge
of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant,
based solely on probable cause, whether or not the violation is committed in the presence 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 Sherifl's office of the county which issued this Order,
which office shall maintain possession of the weapons until further Order of this Court, unless the
weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency
whose officer made the arrest,
Judge
Joan Carey, Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
"'
~'H'C
u .",
" '.. 'C
,
-. L~--:- ~'~~!:<iJThRY
C ::"".9 ?il3:L5
",.'" " 'TV
1../,-,'I__i!\Jil
I~~':I\P,\!-~\fl \!!\:\I~~
L. 'Ii 'i~l_d...._t :/ \
.", ""..'
~""',.,,--""'~.~~"""'"
..
~..,_~1l!IllIII!I
T",~~"
,
!~'"'
ADELAlDA CASTANEDA WILLIAMS, : IN TIlE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO, 2000-
CIVIL TERM
GORDON STANLEY WILLIAMS,
Defendant
: PROTECTION FROM ABUSE
PETITION FOR
PROTECTION FROM ABUSE
1. Plaintiff is Adelaida Castaneda Williams.
2, The name of the person who seeks protection from abuse is Adelaida Castaneda
Williams,
3, Plaintiff's address is Long Meadow Apartments, 5C RicWand Lane, Apt. Tl2, Camp
Hill, Cumberland County, Pennsylvania 17011,
4, Defendant's address is unknown to Plaintiff
Defendant's Social Security Number is 366-40-0477
Defendant's date of birth is 07/01/1942
Defendant is employed by General Motors as the District Field Executive working out
of his residence. Defendant sometimes uses the offices of GMAC at 1017 Mumma
Road, Lemoyne, Cumberland County, Pennsylvania,
5, Defendant is Plaintiff's husband,
6, Defendant has been involved in the following criminal court action:
East Pennsboro Township Police arrested Defendant and charged him with simple
assault, terroristic threats, and harassment, A preliminary hearing in the case was held
before District Justice Manlove on January 24, 2000, and the charges were bound over
for trial,
7. The facts of the most recent incident of abuse are as follows:
Approximate Date: On or about December 10, 1999
. ,
- ~-- "
I<'~ ".1__~ .; -_I - '. '"'
" re,
Place:
Longmeadow Apartments, 5C Ricbland Lane, Apt, TI2,
Camp Hill, Cumberland County, Pennsylvania, the
marital residence.
On or about December 10, 1999, Defendant berated and called Plaintiff
names, threw food at her, followed her into the bathroom, and threw a colander
with fruit in it at Plaintiff, hitting her on the side of the face with it. When
Plaintiff told Defendant that she was going to telephone the police, he threatened
her saying, "1 dare you to touch the phone, You'll never see daylight again,"
Defendantfollowed Plaintiff into the bedroom and repeatedly struck her about
the back with his belt, and continued to whip her with the belt as she cried and
pleaded with him to stop, and curled up to protect herself Defendant threatened
Plaintiff saying, "You're lucky that's all you got." Fearing for her safety,
Plaintiff waited until the following morning after Defendant left the home to
telephone the policefor help, The East Pennsboro Township Police responded,
and after seeing Plaintiff's injuries, transported her to the Emergency Room at
Holy Spirit Hospital where she was treated for her injuries, Upon her release
from the hospital, Plaintiff sought a safe place to stay for her protection and to
avoid further abuse from Defendant. East Pennsboro Township Police arrested
Defendant and charged him with simple assault, terroristic threats, and
harassment. A preliminary hearing in the case was held before District Justice
Manlove on January 24, 2000, and the charges were bound over for trial, On or
about February 3,2000, Plaintiff underwent oral surgery to repair injuries she
sustained to her jaw as a result of this incident,
8, Defendant has committed the following prior acts of abuse against Plaintiff:
a) On or about November 28, 1999, Defendant berated and called Plaintiff
names, and threatened her saying, "1 can see how people can stab and shoot each
other because 1 picture myself getting a butcher knife and stabbing you a
hundred times in the chest." Defendantfurtherthreatened, "How would you like
to walk around with a knife in your forehead?"
b) In or about August 1999, Defendant fidsely accused Plaintiff, threw a
container of food ather hitting her on the side of the head with it, grabbed her
by the hair, repeatedly slammed her head against the wall, dragged Plaintiff by
her hair to the bedroom, grabbed her by the front ofher clothing, and repeatedly
threw her onto the bed. Defendant grabbed plaintiffby the front of her clothing,
threw her to the floor, and when she tried to get away from him, he repeatedly
shoved her to the floor and pinned her down by putting his foot on her abdomen,
Plaintiff sustained bruising ,and soreness about her thigh, and soreness about her
head and torso as a result of this incident,
-
. '~' <"
;'-'"
'-I"
e
c) In or about June 1999, Defendant punchedPlaintifl'on the neck under her
jaw with his fist, Plaintiff sustained sorenesS about her neck and head as a
result of this incident.
d) In or about December 1998, Defendant called Plaintiff names, and
pushed a pillow forcefully against her face for a sustained period, causing her to
be unable to breathe and to choke. Only after Plaintiff pushed Defendant off of
her was she able to breathe,
9, 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:
East Pennsboro Township Police Department - Plaintiffs residence
10, There is an immediate and present danger of further abuse from Defendant,
11. Plaintiff is asking the Court to evict and exclude Defendant from the residence at Long
Meadow Apartments, SC Richland Lane, Apt. Tl2, Camp Hill, Cumberland County, Pennsylvania,
which is rented in the name of Gordon Stanley Williams, Defendant has been residing at a location
unknown to Plaintiff since December 11, 1999,
12. Plaintif'fhas suffered the following out-of-pocket financial losses as a result of the abuse
described above: see attached Exhibit A, incorporated hereto by reference.
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 she may be found.
B. Exclude Defendant from Plaintiffs current residence and prohibit Defendant
from attempting to enter any temporary or permanent residence of the Plaintiff,
C, Require Defendant to provide Plaintifl'with other suitable housing,
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
to, any contact at Plaintift'scurrent residence, and any residence she may, in the future,
establish for herself; her school, business, and/or her place of employment.
E, Prohibit Defendant from having any contact with P1aintift's relatives,
"
~ I
~ iIl'.ifu-:
F, Direct Defendant to pay Plaintiff for the reasonable financial losses suffered as
a result of the abuse, to be determined at the hearing,
G, Order Defendant to pay the costs of this action, including filing and service fees.
H, Order Defendant to pay $250,00 to reimburse one of Legal Services, Inc.'s
funding sources toward the cost of litigation in this case,
I. Order the following additional relief: not listed above:
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,
J. Grant such other relief as the court deems appropriate.
K. Order the police or other Iawenforcement 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.
Date:
c2/3/rro
/ /
Respectfully submitted,
~~
LEGAL SER.VlCES, INC,
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
,
.;j--
"-,- _,'__L
-10
''''"''iII~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 Peti,tiop are true and correct to the best of my knowledge. I
understand that any false statements are made subject to the penalties of 18 Pa.C,S,~4904, relating
to unsworn falsification to authorities,
Dated: ~ - 2 - ;2.e&t>
~t: ~ I/j~:u,)
Adelatde C. Williams, Plaintiff -
-
'-"
,.1.
1lJ!t~'
. -
ADELAIDA CASTANEDA WILUAMS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
vs,
: NO, 2000-
CIVIL TERM
GORDON STANLEY WILLIAMS,
Defendant
: PROTECTION FROM ABUSE
OUT-OF-POCKET LOSSES
Plaintiff requests that Defendant reimburse her out-of-pocket losses, including but not limited
to the following:
Any and all medical expenses not reimbursed through Plaintiff's medical insurance coverage
relating to injuries she sustained as a result of the incident which occured on or about
December 10, 1999, (The hospital has not billed Plaintiff at the time of filing this petition).
Any and all reasonable living expenses/costs incurred by plaintiffsince the incident which
occured on or about December 10, 1999, (Listing of expenses not available at time of filing this
petition).
$.
EXHIBIT A
OIl
.r.d:t'. _
,c,.
-
.... ,
'1iI1111~~~'
iIll~"""'"
~ ~ (')
c:
~~.....- -'1
(; ~~!0\ P')
-( ~ (..:)
-
~, ~ Ul)--' u)
.-< .-~<
~ ~~~; :'-".,
-.<>>-
f >~ .
~,,:..-
(~ ~-~I '.,
.< '"
,Q, ~
r
tJ
~ ~.
("
ct-- f.
-.",., .t;
v
~B
~
8'
~,-
,:-:;
{l
_.,-. ~
':::j-.~""~
u;-- ,~ j
~'"
-.
;... F ~'"' "'", "
-,-
-+ ".-,
i"",nj~
ADELAIDA CASTANEDA WILLIAMS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUI\ffiERLAND COUNTY, PENNSYLVANIA
vs.
: NO, 2000-762 CIVIL TERM
GORDON STANLEY WILLIAMS,
Defendant
: PROTECTION FROM ABUSE
~R FOR CONTINUANCE
AND NOW, thisV day of February, 2000, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on Friday, February 18, 2000, by this Court's Order
of February 9,2000, is hereby rescheduled for hearing on March 27, 2000, at 10:30 a,m. in
Courtroom No.3 of the Cumberland County Courthouse, Carlisle, Pennsylvania.
The Temporary Protection From Abuse Order shall remain in effect for a period of one year from
iIthe iiite i~as entered, through February 9, 2001, or until further Order of Court, whichever comes
~~,~=.ittst.:~: \~ ~
~,,' ,_ ;:' c.... ,r'\ ?3
,""::'" \.-- :-::-> >--
'-;-' f_ I 0:) .",;.."'(n
~Y'l " ::, '..,',~,;,j,.rr,'~
\"~_.,. LT..; - _--
By the Court,
!'
u_
o
-c:)
~)
o
t- -
Joan Carey, Attorney for Plaintiff
LEGAL SERVICES, 1Ne.
8 Irvine Row
Carlisle, PA 17013
Thomas R. Miller, Attorney for D(endant - Copv Y'1 ~ c L ~
MILLER & MILLER ,." (
I 05 Locust Street
p,-q. Box:fOO
~urg, PA 17101'
Cpl''f.S 10~.v",-L ly ~~"iA....J
,~
- ~
I'
~
ADELAIDA CASTANEDA WILLIAMS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
vs,
: NO. 2000-762 CIVIL TERM
GORDON STANLEY WILLIAMS,
Defendant
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
Plaintiff; Adelaida Castaneda Williams, 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:
1, A Temporary Protection From Abuse Order was issued by this Court on February 9, 2000,
scheduling a hearing for February 18, 2000, at 10:00 a,m,
2, The Cumberland County Sheriffs Department served Defendant with a certified copy of the
Notice ofHearing, Temporary Protection From Abuse Order and Petition for Protection From Abuse
at the Cumberland County Sheriff s Department, Cumberland County Courthouse, )'d Floor, Carlisle,
PelUlsylvania, on February 11, 2000, at 12:55 p.m,
3, Defendant has retained Thomas R. Miller of MILLER & MILLER to represent him in the
matter,
4, The parties agree, by and through their respective counsel, that the hearing be rescheduled
to facilitate negotiation of a settlement in the matter,
5, Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a
period of one year from the date it was entered, through February 9, 200 1, or until further Order of
Court, whichever comes first.
,
'-~',
WHEREFORE, Plaintiff requests that the Court grant this Motion and reschedule this matter for
hearing, and that the Temporary Protection From Abuse Order remain in effect for a period of one
year from the date it was entered, through February 9, 2001, or until further Order of Court,
whichever comes first.
LEGAL SERVICES, 1Ne.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
._.~
:E ,"'~""""_" ..,.
~1iiJ. ~".~-!'l1J
"=~~
~~'_'"O~_,.~ .*_~~ ,~~. ,v~,,_
" ,~
Jill
.~- "".", ., ~ > '
<~_"o
-~ ~"-~
",".,"""'-
"
n C) "'j
C c' ,
::=:~ ~~t'1 .
--0 r;'" '1
\T1 {i', <:0
2": ::L
---;'-1""'"-
L-c
en -"~ C,::. : ,
--< .,~ ..
r..:.:C,
-:-:.> "--~-.
~~1 ~,
-~
~<- ~
-I
-< (.0
~.'"
.,.'
.= ~~
..
_.,,,,,,,,,,"'--""1,,,,, .. ~ ~
"'1 t .&:~.-,
SHERIFF'S RETURN - REGULAR
CASE NO: 2000-00762 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WILLIAMS ADELAIDA CASTANEDA
VS
WILLIAMS GORDON STANLEY
CHIEF DEP. RON ANDERSON
, Sheriff or Deputy Sheriff of
Cumberland County, Pensyl vania , who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE
was served upon
WILLIAMS GORDON STANLEY
the
DEFENDANT
, at 0012:55 HOURS, on the 11th day of February, 2000
at CUMBERLAND CO. SHERIFF'S DEPT 1 COURTHOUSE SQUARE
CARLISLE, PA 17013 by handing to
GORDON S. WILLIAMS
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
Aft idavi t
Surcharge
So Answers:
18.00
3.10
.00
10.00
.00
31.10
r~r4~~e_.
R. Thomas Kline'
02/14/2000
Sworn and Subscribed to before
I:c:.-
me this ~ - day of
Y,-duu~ OlnnJ A.D.
- ~J
n~, () Iz".<tk, #.
'- /' ~rothonotary ,
By:
~
,-'.' ".
- "-,~' ,-. ,I "'~-; -
~ ;;i'~J
ADELAIDA CASTANEDA WILLIAMS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
vs,
: NO. 2000-762 CIVIL TERM
GORDON STANLEY WILLIAMS,
Defendant
: PROTECTION FROM ABUSE
ORDE~FORCONTThmANCE
AND NOW, tbis U day of March, 2000, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on Monday, March 27, 2000, at 10:30 a,m, by tbis
Court's Order of February 18, 2000, is hereby rescheduled for Monday, April 24, 2000, at
9:30 a.m. in Courtroom No.3 ofthe Cumberland County Courthouse, Carlisle, Pennsylvania.
The Temporary Protection From Abuse Order shall remain in effect for a period of one year
from the date it was entered, through February 9, 2001, or until further Order of Court, wbichever
comes first.
By the Court,
-,
Joan Carey, Attorney for Plaintiff
LEGAL SERVICES, INe.
8 Irvine Row \
Carlisle, PA 17013
Thomas R. Miller, Attorney for Defendan!
MILLER & MILLER
105 Locust Street
P,O, Box 709
Harrisburg, P A 17101
~ ~ .j.,J.1-IJ<J
6' .
-,"[
CF n";~?LR!':.q>~i:!CP
, 'c,-':C);\!"iTMO
O"c"""''lVlY
uNS",?:.,
"'b J L'.{'
~. f;-4~. ~
" ..). ,.. Q
O!IL'~., ,'~
LJilij"'C,f-U' .
~ 'IV'"
PfivNSY/!" COUN7y
LVIi!ViA '
, -
"
~~,~~, ~p -~"
,,~"--~
.II$W"~~~,,,.~_. ~~,~"...,..=,~ ij '",_" .........,..~J!\lIlilIlUlll!Jllll\
-
c__ l ~"' L'. ,-,~:"
- ",',.
~,
ADELAIDA CASTANEDA WILLIAMS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
vs,
: NO, 2000-762 CIVIL TERM
GORDON STANLEY WILLIAMS,
Defendant
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
Plaintifi; Adelaida Castaneda Williams, 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 Motion for Continuance was filed and an Order for Continuance entered on
February 18, 2000, rescheduling the hearing for March 27,2000, at 10:30 a.m,
2, The parties agree, by and through their respective counsel, that the hearing be
rescheduled to facilitate negotiation of a settlement in the matter,
3, Plaintiff requests that the Temporary Protection From Abuse Order remain in effect
for a period of one year from the date it was entered, through February 9, 2001, or until further Order
of Court, whichever comes first.
WHEREFORE, Plaintiffrequests that the Court grant this Motion and reschedule the hearing
in this matter, and that the Temporary Protection From Abuse Order remain in effect for a period of
one year from the date it was entered, through February 9, 2001, or until further Order of Court,
whichever comes first,
Respectfully sub
(]
!
oan Carey, Attorney fi
LEGAL SERVICES,