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LEZLI JUNE HAKE,
Plaintiff
for herself and on behalf of the minor children:
WILLIAM MARTIN HAKE,
JACQUELYN CAITLIN HAKE, and
AMANDA JAYNE HAKE,
vs.
LAWRENCE MARTIN HAKE,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL TERM
: NO. 2000- 16''l~
: PROTECTION FROM ABUSE AND CUSTODY
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following
papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and
a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be
evicted from your residence and lose other important rights.
A hearing on this matter is scheduled on the ~ day of March, 2000, at f?: 1S" t:L. ,m., in Courtroom
No, I- 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 notic:e 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 in jail under
23 Pa.C.S. ~6114. Violation may also subject you to prosecution and criminal penalties under the pennsyllvania
Crimes Code, Under federal law, 18 US,C, ~2265, this Order is enforceable anywhere in the United States, tribal
lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally
violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18
US.C ~ 2261-2262.
You should take this paper to your lawyer at once. You have the right to have a lawyer represent you
at the hearing. The court will not, however, appoint a lawyer. for you. If you do not have a lawyer or cannot afford
one, go to or telephone the office set forth below to find out where you can get legal help. If you cannot find a
lawyer, you may have to proceed without one.
CUMBERLAND COUNTY BA~ 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, contact our office; All arrangements must be made atIeast 72
hours prior to any hearing Qr business before the court. You must attend the scheduled conference or hearilllg.
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LEZLI JUNE RAKE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of the minor : CUMBERLAND COUNTY, PENNSYLVANIA
children: WILLIAM MARTIN RAKE,
JACQUELYN CAITLIN RAKE, : CIVIL TERM
and AMANDA JAYNE RAKE,
vs. : NO, 2000- jtJ'1.L &;..e ~
LAWRENCE MARTIN RAKE,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
TEMPORARY PROTECTION
FROM ABUSE ORDER
Defendant's Name: LAWRENCE MARTIN BAKE
Defendant's Date of Birth: 07/09/1957
Defendant's Social Security Number: 206-54-3303
Names of Protected Persons: LEZLI JUNE RAKE, and the minor children:
WILLIAM MARTIN RAKE
JACQUELYN CAITLIN BAKE
'I AMANDA JAYNE RAKE
~IICt
AND NOW, this ~ ~'day of February, 2000, upon consideration of the attached
Petition for Protection from Abnse, the court hereby enters the following Temporary Order:
lID 1. Defelldant shall not abuse, harass, stalk or threaten any of the above persons in
any place where they might be fonnd.
o 2. Defendant is evicted andexcIuded from the residence at _ or any other permanent
or temporary residence where Plaintiff may live. Plaintiff is granted exclusive possession of the
residence, Defendant shall have no right or privilege to enter or be present on the premises.
lID 3. Defendant is prohibited from having ANY CONTACT with P1aintitT andJor the
minor children at any location, including, but not limited, to any contact at Plaintit1's current
residence, and any other residence she may, in the future, establish for herself, her school. her
place of employment, ortheschools andJorday care facilities otthe minor children. Defendant
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is specifically ordered to stay away from the foRoWing locations for the dnration of this Order:
Plaintiff's current residence: Undisclosed for Plaintiff and the minor childrens'
protection
Residence of Plaintiff's Barents: June and Cliff Miller, 6300 WertzvilIe Road,
Mechanicsburg,Cumberland County, Pennsylvania
Plaintiff's nlace of emolovment: HealthAmerica, Flank Drive, Dauphin County,
Pennsylvania
School of the minor children: Hampden Elementary School, 441 Skyport Road,
Mechaniesburg, Cumberland County, Pennsylvania
129 4. Defendant shall not contact Plaintiff and/or the minor children by telephone or
by any other means, including through third persons.
129 5. Pending the outcome of the imal hearing in this matter. Plaintiff is awarded
temporary custody oCthe foDowing minor children:
WILLIAM MARTIN BAKE
JACQUELYN CAITLIN RAKE
AMANDA JAYNE BAKE
Until the tinal hearing, all contact between Defendant and the children shaD be suspended.
o 6. Defendant shall immediately relinquish the following weapons to the Sherifl's Office
or a designated local law enforcement agency for the delivery to the Sheriff's Office:. Defendant
is prohibited from possessing, transferring or acquiring any other weapons for the duration of this
Order.
129 7.
The foDoWing additional relief is granted:
The Cumberland County Sheriff's Department shaD 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 shaD not send a copy of this Order
to Defendant by mail.
Law enforcement agencies, human service agencies and school districts shall not
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disclose the presence of Plaintiff and/or the children in the jurisdiction or
district or furnish any address, telephone number, or any other demographic
information about Plaintiff and/or children, except by further Order of Court.
This Order shall remain in effect until modified or terminated by the Court and
can be extended beyond its original expiration date if the Court t"mds that
Defendant has committed an act of abuse or has engaged in a pattern or
practice that iudicates risk of harm to Plaintiff and/or the minor children.
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 PlaintiWs relatives or the minor
children.
I:&> 8. A certified copy of this Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
Hampden Township Police Department
I:&> 9. THIS ORDER SUPERSEDES ANY PRIOR PFA ORDER and ANY PRIOR
ORDER RELATING TO CHILD CUSTODY.
THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT ANDSHALLREMAIN
IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE
AND HEARING.
NOTICE TO DEFENDANT
Defendant is hereby notified that violation of this Order may result in
arrest for indirect criminal contempt, which is punishable by a fine of up to
$1,000.00 and/or up to six months in jail. 23 Pa.C.s.~6114. Consent of the
Plaintiff to Defendant's return to the residence shall not invalidate this Order,
which can only be changed or modified through the filing of appropriate court
papers for that purpose. 23 Pa.C.S.~6113. Defendant is further notified that
violation of this Order may subject him/her to. state charges and penalties
under the Pennsylvania Crimes Code and to federal charges and penalties
under the Violence Against Women Act, 18 U.S.C.~~2261-2262. Any
protection order granted by a court may be considered in any subsequent
proceedings, including child custody proceedings, under title 23 (DomestiC
Relations) of the Pennsylvania Consolidated Statutes.
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NOTICE TO LAW
ENFORCEMENT OFFICIALS
This Order shall be enforced by the police who have jurisdiction over Plaintiff'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 ofIaw
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 Sherift'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.
BY THE COURT,
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Judge
Joan Carey, Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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LEZLI JUNE RAKE,
Plaintiff
for herself and on behalf of the minor
children: WlLLIAM MARTIN RAKE,
JACQUELYN CAITLIN RAKE,
and AMANDA JAYNE RAKE,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs,
: CIVIL TERM
: NO. 2000- It) '7';& {!:u:.e -r~
LAWRENCE MARTIN RAKE,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
PETITION FOR
PROTECTION FROM ABUSE
COUNT I
1. Plaintiff is Lezli June Hake.
2. Plaintiff files this Petition for herself and on behalf of her minor children, William
Martin Rake, Jacquelyn Caitlin Rake, and Amanda Jayne Rake.
3. The names of the persons who seek protection from abuse are Lezli June Hake, Wtlliam
Martin Rake, Jacquelyn Caitlin Rake, and Amanda Jayne Hake.
4, Plaintiff and the minor children are staying at an undisclosed location for their protection
and to avoid further abuse.
5. Defendant's address is Mountain View Village Apartments, 4181 Elk Court, Apt. 114,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
Defendant's Social Security Number is 433-70-8040
Defendant's date of birth is 05/04/1961
Defendant is self-employed under the name of L&M Lawn Service, and uses his
residential address as his business address.
6. Defendant is Plaintiffs husband.
7. Defendant has been involved in the following criminal court action:
To the best of Plaintiff's knowledge, Defendant has been convicted of Dm
offenses, weapons charges, and other criminaI charges,
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8. Plaintiff seeks temporary custody of the following children:
Name
William Martin Rake
Jacquelyn Caitlin Rake
Amanda Jayne Rake
Address
Undisclosed location
Undisclosed location
Undisclosed location
Birthdate
05/12/1991
06/11/1993
09/01/1995
9. Plaintiff and Defendant are the parents of the following minor childJren:
Name
Wtlliam Martin Rake
Jacquelyn Caitlin Rake
Amanda Jayne Rake
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8 years old
6 years old
4 years old
10. The following information is provided in support ofPlaintifPs 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 Plaintiff, LezIi June Rake, who is
currently residing at an undisclosed location for her protection and that of her minor
children.
c) During the past five years the children have resided with the following persons
and at the following addresses:
Persons children lived with
Plaintiff
Plaintiff and Defendant
Plaintiff and Defendant
Plaintif( Defendant, and
Defendant's son, Dan Rake
Address
Undisclosed location
When
From 02/19/2000
to the present
Mt. View Village Apts.
4181 Elk Court, Apt. 114
Mechanicsburg, P A
From 09/30/1998
to 02/19/2000
12 Louis Lane
Enola, P A
From 07/1996
to 09/30/1998
12 Louis Lane
Enola, P A
From 02/1995
to 07/1996
d) Plaintif( the mother of the children, is LezIi June Rake, currently residing at an
undisclosed location for her protection and that of her minor children.
e) She is married.
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t) Plaintiff currently resides with the following persons:
Name
William Martin Hake
Jacquelyn Caitlin Rake
Amanda Jayne Rake
Relationship
her son
her daughterr
her daughter
g) Defendant, the father of the children, is Lawrence Martin Rake, currently
residing at Mountain View Village Apartments, 4181 Elk Court, Apt. 114,
Mechanicsburg, Cumberland County, Pennsylvania.
h) He is married.
i) To the best of Plaintiff's knowledge, Defendant currently resides alone.
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 these 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
custody is temporarily granted to Plaintiff pending a hearing in this matter for reasons
including:
1) Plaintiff is a responsible parent who has provided for the emotional and
physical needs of the children since their births, and who can best take care of
the minor children.
2) Defendant has shown by his abuse of Plaintiff and/or children that he is
not an appropriate role model fOr the minor children.
3) Defendant's behavior has adversely affected the children.
11. The facts of the most recent incident of abuse are as follows:
Approximate Date:
Place:
Onot about February 19, 2000
Mountain View Village Apartments, 4181 Elk Court,
Apt. 114, Mechanicsburg, Cumberland County,
Pennsylvania, the marital residence
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On or about February 19, 2000, Plaintiff returned home and found
Defendant, who was responsible for the care of the parties' 8, 6, and 4-year- old
children, intoxicated, dancing clad only in his underwear in front of the children
and one of their playmates, with music blaring loudly. Defendant fell asleep,
and when he awakened, he yelled at Plaintiff; threw her possessions breaking
them, and other objects about such as cans of beer, the television remote control,
framed pictures, and candles, narrowly missing Plaintiff. Defendant threatened
to kill her by chopping her up into little pieces, and told her that no one would
know because he would have someone else do it for him. Defendant told their
daughters, Jacqueline, 6 years old, and Amanda, 4 years old, to clean up the
broken glass and objects. Fearing for her safety and that of her children,
Plaintiff took their son 8-year-old son, William, but was forced to leave the girls
with Defendant when he threatened to kill her if she tried to take the girls with
her. Plaintiff went to the Hampden Township Police Department, and returned
to the marital residence accompanied by an officer who assisted in tranferring
the girls to Plaintiff's care. Plaintiff immediately took the children to an
undisclosed location where she and the children have since been staying for their
protection.
12. Defendant has committed the following prior acts of abuse against Plaintiff and/or
the minor children:
a) In or about early February, Defendant over-turned the couch where
Plaintiff lay, causing her to fall tothetloor and the couch to fall on top of her.
Defendant picked up the coffee table and. slammed it down on the couch with
such force that the table broke, and Plaintiff; who was still under the couch, was
stwmed by the impact of the blow, Plaintiff sustained bruising about her ann
and leg as a result of this incident.
b) In or about mid-December 1999, after Plaintiff went to bed, Defendant
came into the room, punched her in themce, arms, and torso. Plaintiff sustained
soreness about her face, anns, and abdomen, and a portion of one of her front
teeth was chipped off as aresuIt of this incident.
c) In or about 1997, Defendant threw a can of beer at Plaintiff hitting her
in the face with it as she sat on the bed with Jacquelyn, who was 3 years old at
the time. All three children were traumatized by the sight of the laceration on
Plaintiff's face, which extended from her nose to below her lower lip, and was
bleeding profusely. Plaintiff was treated for her injuries at a Harrisburg
Hospital, where she received 20-30 stitches to close the laceration.
11) In a separate incident in or about 1997, Defendant screamed at Plaintiff,
called her names, accused her falsely, and as she telephoned 911 for help, he
~abbed the receiver from her and hung up, although the call had connected to
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the 911 dispatcher. When the 911 dispatcher called back, Defundant answered
and said that everything was all right, Police were not dispatched to the
residence, Defendant threatened Plaintiff saying, "You want my ass in jail;
you'll be dead first," Defendant threw 6-8 knives at Plaintiff, followed her
upstairs, and in front of William, then 5 years old, slapped her on the ear, threw
her to the floor, and choked her, causing her to nearly lose consciousness, as the
child screamed, "Daddy, stop." Plaintiff sought medical treatment for injuries
she sustained as a result of this incident which included, but were not limited to
bruising and soreness about her head, neck, and ear, and a punctured ear drum.
e) Io or about 1991, during her pregnancy with William, Defendant struck
Plaintiff on the head with a lamp, dragged her about by her hair, repeatedly
kicked her about her belly, and threatened her saying, "You want this baby so
bad, let's see how it turns out." Plaintiff sustained soreness and swelling about
her head, and soreness and bruising about her belly as a result of this incident.
1) Since July 6, 1991, Defendant has abused Plaintiffin ways including, but
not limited to, shoving, grabbing, punching, slapping, choking, and kicking her;
restraining her; pulling her hair, and spitting on her. Defendant has slammed
Plaintiff's head against walls, once causing her head to break: a hole in the wall
board. Defendant has grabbed Plaintiff by the throat while she was sleeping,
thrown chairs at her hitting her on the back, legs, and head, thrown household
objects about such as ashtrays, glasses, dishes, a television, often breaking the
objects in close proximity to the children, who have been hit by shattering glass,
and forced the children to clean up after his rampage, including picking up
shards ofbrokeng!ass.
Defendant has ridiculed and humiliated William in public and in front
of his playmates for bed-wetting, and has held the child's soiled underwear up
to the boy's face when he had a bowel movement in his pants, telling the boy
that if he wants to act like a dog, he'll treat him like one. Defendant shoves
William about and slaps him, and calls him vile names such as butt-fucker.
Defendant has controlled Plaintiff by documenting the mileage on her
vehicle, recording her telephone conversations, forcing her to quit and/or lose
several jobs, and taking her car keys. During one incident, the day after she
bought a new car, Defendant threw an air conditioning unit from a window onto
the hood ofPlaintitr's car to disable her vehicle.
Defendant forced Plaintiff to participate in sexual acts against her will,
threatening to harm her if she did not comply. During an incident when Plaintiff
refused Defendant's sexual demands, he grabbed the hair on the sides of her
head and repeatedly slammed her head against the floor until she complied,
Defendant's repeated threats to kill Plaintiff and his abuse of her has
caused her to be so fearful that she sleeps in her clothing, with her shoes on, and
her car keys in her pocket in case she has to run from the house.
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13. 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:
Hampden TownshiD Police Department
14. There is an immediate and present danger offurther abuse from Defendant.
15. Defendant owes a duty of support to Plaintiff and/or the minor children,
16, Plaintiffhas suffered the following out-of-pocket financial losses as a result ofthe
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 FOLWWING:
A. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff
and/or the minor children in any place where they maybe found.
B. Require Defendant to provide Plaintiff and the minor children with other
suitable housing.
C. Award Plaintiff temporary custody of the minor children and place the
following restrictions or contact between Defendant and children:
Contact between Defendant and children is suspended pending further Order
of Court after the hearing scheduled in this matter,
D. Prohibit Defendant from having any contact with Plaintiff and/or the minor
children, either in person, by telephone, or in writing, personally or through third
persons, including, but not limited to, any contact at Plaintiff's current residence, and
any residence she may, in the future, establish for herself, her schoo~ her place of
employment, or the schools and/or daycare facilities of the parties' minor children.
E. Prohibit Defendant from having any contact with Plaintiff's relatives.
F. Order Defendant to pay temporary support for Plaintiff and the minor
children, including medical support.
G. Direct Defendant to pay Plaintiff for the reasonable financial losses suffered
as a result of the abuse, to be determined at the hearing.
R Order Defendant to pay the costs of this action, including filing and service
fees,
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I. Order Defendant to pay $250,00 to reimburse one of Legal Services, Inc.'s
funding sources toward the cost of litigation in this case,
1. 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 Plaintiffs relatives and/or the minor
children.
COUNT II
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K. Grant such other relief as the court deems appropriate.
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.
CUSTODY UNDER PENNSYLVANIA CUSTODY LAW
17. The allegations of Count I above are incorporated herein as if fully set forth,
18. The best interest and permanent welfare of the minor children will be served by
confirming custody in Plaintiff as set forth in paragraph 10 of the petitioR
WHEREFORE, pursuant to 23 Pa.C.S.~5301 et. ~., and other applicable rules and law,
Plaintift'praysthis Honorable Court to award custody of the minor children to her.
Respectful1y submitted,
Date:
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Carey, Attorney for aintift'
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 factsafltt
statements contained in the above Petition are true and correct to the best of my knowledge. 1.
understand that any false statements are made subject to the penalties of 18 Pa.C.S.~4904, relating:
to unsworn falsification to authorities.
Dated: ~.~..s-: 0 IJ
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LEZLI JUNE RAKE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of the minor : CUMBERLAND COUNTY, PENNSYLVANIA
children: WILLIAM MARTIN RAKE,
JACQUELYN CAITLIN RAKE, : CIVIL TERM
and AMANDA JAYNE RAKE,
vs, : NO. 2000-
LAWRENCE MARTIN RAKE,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
OUT-OF-POCKET LOSSES
Plaintiff requests that Defendant reimburse her out-of-pocket losses, including but not limited
to the following:
Any and all expenses/costs incurred to repair and/or replace Plaintiffs property damaged
and/or destroyed, including, but not limited to lost wages as a result of the incident which occured
on or about February 19, 2000. (The amount of damages and/or total lost wages was not available
at the time of filing this Petition).
$
EXHIBIT A
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LEZLI JUNE RAKE,
Plaintiff
for herself and on behalf of the minor children:
WILLIAM MARTIN RAKE,
JACQUELYN CAITLIN RAKE, and
AMANDA JAYNE RAKE,
vs.
LAWRENCE MARTIN RAKE,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL TERM
: NO. 00-1012
: PROTECTION FROM ABUSE AND CUSTODY
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 lIIay be
evicted from your residence and lose other important rights.
A hearing on this matter is scheduled on the gfl, day of >n~ , 200lt, at f!: Lj5 <2-.11I1., in
Courtroom No. --L of the Cumberland County Conrthouse, Carlisle, Pennsylvania.
You MUST obey the Order that is attached until it is modified or terminated by the court after notke and
hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a c:harge
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. ~6114, Violation may also subject you to prosecution and criminal penalties under the Pennsylvania
Crimes Code. Under federal law, 18 U.S.C. ~2265, this Order is enforceable anywhere in the United States, tribal
lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the stateaild intentionally
violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18
U.S.C. ~ 2261-2262,
You should take this paper to your lawyer at once. You have the right to have a lawyer represent YQU
at the hearing, The court will not, however, appoint a lawyer for you. If you do not have a lawyer or cannot afford
one, go to or telephone the office set forth below to find out where you can get legal help. If you cannot find a
lawyer, you may have to proceed without one.
----.,
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 abol,lt accessible facilities and reasonable accommodations available to
disabled individuals having business before the court, contact our office. All arrangements must be made atleast 12
hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing.
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LEZLI JUNE RAKE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of the minor : CUMBERLAND COUNTY, PENNSYLVANIA
children: WILLIAM MARTIN RAKE,
JACQUELYN CAITLIN RAKE, : CIVIL TERM
and AMANDA JAYNE RAKE,
VS. : NO. 00-1072
LAWRENCE MARTIN RAKE,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
EXTENSION OF
PROTECTION ORDER
Defendant's Name: LAWRENCE MARTIN BAKE
Defendant's Date of Birth: 07/09/1957
Defendant's Social Security Number: 206-54-3303
Names of Protected Persons:
LEZLI JUNE BAKE
WILLIAM MARTIN BAKE
JACQUELYN CAITLIN BAKE
AMANDA JAYNE BAKE
AND NOW, this ~ 11aay of February, 2001, upon presentation and consideration of the
attached Petition for Extension of Protection Order, the court hereby enters the following Order:
The Final Protection From Abuse Order entered on March 15, 2000, in the above-
captioned case (see attached Exhibit A) and the Order of Court entered on June 30, 2000,
which modified the Final Protection Order (see attached Exhibit B) shaD be extended beyond
the expiration date of March 15, 2001, such that the Orders remain in fnB force and effect for
a period of 18 months from today's date, through Augnst 26, 2002, or until otherwise modified
or terminated by the Conrt after notice and hearing.
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No.TICE 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 $1,000.00 and/or up to six months injait
23 Pa.C,S. ~6114. Consent of the Plaintiff to Defendant's return to the residence shall not invalidate
this Order, which can only be changed or modified through the filing of appropriate court papers for
that purpose. 23 Pa. C$ ~6113. Defendant is furthernotmed that violation of this Order may subject
himlher to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and
penalties under the Violence Against Women Act, 18 U.S.C.9~2261-2262. 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.
No.TICE TO. LAW ENFORCEMENT o.FFICIALS
This Order shall be enforced by the police who have jurisdiction over Plaintiffs residence or
any locations where a violation of this order occurs or where Defendant may be located. If Defendant
violates this Court's Orders of March 15, 2000, and June 30, 2000 (see attached Exhibits A and B,
respectively), Defendant may be arrested on the charge of Indirect Criminal Contempt. An arrest for
violation of this Order may be made without warrant, based solely on probable cause, whether or not
the violation is committed in the presence oflaw enforcement.
Subsequent to an arrest, the law enforcement officer shall seize all weapons used or
threatened to be used during the violation of this Order or during prior incidents of abuse. Weapons
must forthwith be delivered to the Sheriff's office of the county which issued this Order, which office
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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.
BY THE COURT,
Joan Carey
Maryann Murphy
Attorneys for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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LEZLI JUNE RAKE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of the minor : CUMBERLAND COUNTY, PENNSYL VANIA
children: WILLIAM MARTIN RAKE,
JACQUELYN CAITLIN RAKE, : CIVIL TERM
and AMANDA JAYNE RAKE,
VS. : NO, 00-1072
LAWRENCE MARTIN RAKE,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
PETITION FOR EXTENSION
OF PROTECTION ORDER
23 Pa.C.S. !6108(e)
Plaintiff, Lezli June Hake, by and through her attorneys, Maryann Murphy and Joan Carey
ofMidPenn Legal Services, states the following:
1, A Final Protection From Abuse Order in the above-captioned case was entered on
March 15, 2000, by Judge 1. Wesley 0ler, Jf. (see attached Exhibit A, incorporated herein by
reference). A Petition for Modification of Final Protection Order was filed on Plaintiff's behalf, and
an Order of Court was entered on June 30, 2000 (see attached Exhibit B, incorporated herein by
reference).
2, On or about January 30, 2001, Defendant came to the door of Plaintiff' s residence at
694 Cumberland Pointe, Mechanicsburg, Cumberland County, Pennsylvania, in violation of the Final
Protection Order of March 15, 2000, which prohibits Defendant from having any contact with
Plaintiff at her residence, and Defendant further violated the Court's Order ofJune 30, 2000, which
prohibits him from getting out of his vehicle during transfer of custody. Defendant's behavior caused
Plaintiff to fear for her safety.
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3. Plaintiff reported the incident to the Upper Allen Township Police Department.
Defendant was charged with Indirect Criminal Contempt of the Orders, arrested, and taken to
Cumberland County Prison where he remained until his release on February 16, 2001. A hearing is
scheduled in this matter for Monday, February 26, 2001, at 9:30 a.m, before Judge Oler in Courtroom
No. 1 on the 4th Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle,
Pennsylvania,
4. The Order entered on June 30, 2000, will expire on March 15, 2001, on the same date
as the Final Protection Order which was entered on March 15, 2000. Plaintiff fears that Defendant's
behavior as indicated in this Petition confirms ongoing risk ofharm to her, and she fears for her safety
when the Orders in this case expire on March 15, 2001,
WHEREFORE, Plaintiff requests that this Court extend both the Final Protection
Order entered on March 15, 2000, and the Order of Court entered on June 30, 2000, beyond the
expiration date of March 15, 2001, and keep the Orders in full force and effect for a period of 18
months from the date this Petition is filed, through August 26, 2002,
Respectfully submitted,
~4w ~
MaryannM hy ~ \
Joan Carey
Attorneys for Plaintiff
MidPenn Legal Services
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. 94904, relating
to unsworn falsification to authorities,
Dated: ,)jO<d/O/
~'ML
Lezli June Hake, Plaintiff
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LEZLI JUNE BAKE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of the minor : CUMBERLAND COUNTY, PENNSYL VANIA
children: WILLIAM MARTIN HAKE,
JACQUELYN CAITLIN RAKE, : CIVIL TERM
and AMANDA JAYNE RAKE,
vs. : NO. 2000-1072
LAWRENCE MARTIN RAKE,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
FINAL PROTECTION ORDER
Defendant's Name: LAWRENCE MARTIN BAKE
Defendant's Date of Birth: 07/09/1957
Defendant's Social Security Number: 206-54-3303
Names of Protected Persons: LEZLI JUNE BAKE, and the minor childrep:
WILLIAM MARTIN BAKE
JACQUELYN CAITLIN RAKE
AMANDA JAYNE RAKE
~ .
AND NOW, this 1$ day of March, 2000, the court having jurisdiction over the parties
and the subject-matter, it is ORDERED, ADJUDGED, and DECREED as follows:
Plaintiff, Lezli June Rake, is represented by Joan Carey of Legal Services, Inc.; Defendant,
Lawrence Martin Hake, is represented by Jane M. A!exander, Attorney at Law.
Defendant, although agreeing to the terms of this Order, does not admit the allegations made
in the Petition.
[8> Plaintiff's request for a Final Protection Order is granted pursuant to the consent of
Plaintiff and Defendant.
o Plaintiffs request for a Final Protection Order is denied.
[8> 1. Defendant shall not abuse, stalk, harass, threaten Plaintiff or any other
protected persons in any place wher~JiIlIIi'iFf~nd.
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LEZLI JUNE HAKE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of the minor : CUMBERLAND COUNTY, PENNSYLVANIA
children: WILLIAM MARTIN HAKE,
JACQUELYN CAITLIN RAKE, : CIVIL TERM
and AMANDA JAYNE HAKE,
vs. : NCl. 2000-1072
LAWRENCE MARTIN HAKE,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
ORDER OF COURT
. ~ Q
AND NOW, this ~ day of ~
)
. 2000, upon consideration of the within
Petition, paragraph 5 oftbe Final Protection Order entered on March 15,2000, is modified to
allow Defendant to transfer custody ofthe parties' minor children at Plaintiff's residence or
at any other location the parties mutually a,gree upon. Defendant shall remain in his vehicle
lilt all times during transfers of custody.
In all other respects the Final Protection Order entered on March 15, 2000, remains in full
force and effect.
By the Court,
/i iriv-<A-' (). J~
~ 1. esley Oler, Jr. Judge
Maryann Murphy, Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, pA 17013 TR"dE COPY FROM~~E~"RO
I~'rll".~~ whei'\!(if. i !lem umo oot rrr; !lI!!I'Id
Jane M. Alexander, Attorney for Defendant a e 00i.ll ell said. ,rim Car.i~t.a. Pa..
148 South Baltimore Street EXlIIB I . 1;' l.Iay . ~7)
DiIlsburg, PA 17019
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o 2. Defendant is completely evicted and excluded from the residence at or any
other residence where Plaintiff may live. Exclusive possession of the residence is granted to
Plaintiff. Defendant $hall have no right or privilege to enter or be present on the premises.
o On_ at _.m., Defendant may enter the residence to retrieve his/her clothing and
other personal effects, provided that Defendant is in the company of a law enforcement
officer when such retrieval is made.
12:9 3. Defendantis prohibited from having ANY CONTACT with Plaintiff and/or the
minor children (except as provided in paragraph 5 regarding custody) 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, and/or place of employment
or the schools and/or day care facility ofthe minor children. Defendant is specifically ordered
to stay away from the following locations for the duration of this Order:
Plaintiff's Cllrrent residence: Undisclosed location
Residence of Plaintiff's parents: June and Cliff Miller, 6300 Wertzville Road,
Mechanicsburg, Cumberland County, Pennsylvania
Plaintiff's place of emplovment: Health America (a subsidiary of Coventry
Health Care), 6345 Flank Drive, Suite 100, Harrisburg, Dauphin County,
Pennsylvania
School of the minor children: Shaull Elementary School, 1920 Good Hope
Road, Mechanicsburg, Cumberland County, Pennsylvania
12:9 4. Defendant shall not contact the. Plaintiff or the minor children (except as
provided in paragraph 5 regarding custody) by telephone or by any other means, including
third parties.
12:9 5. Custody of the minor children; William Martin Hake, Jacquelyn Caitlin Hake,
and Amanda Jayne Hake,shall be as follows pending further Order of Court after a
conciliation conference:
Plaintiff shall have primary physical and legal custody of the children.
Defendant shall have supervised visitation with the children through an
accredited supervised visitation program mutually agreed npon by the parties
through their respective counsel. Defendant shall be responsible for any and all
costs incurred for supervised visitation.
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o 6. Defendant shall immediately turn over to the Sheriffs Office, or to local law
enforcement agency for delivery to the Sheriffs Office, the firearms and/or specific weapons used
or threatened to be used by Defendant in an act of abuse against Plaintiff and/or the minor childJren:
o 7. Defendant is prohibited from possessing, transferring or acquiring any other firearms
and/or specific weapons for the duration of this Order. Any firearms and/or weapons delivered to
the sheriff under Paragraph 6 of this Order or under Paragraph 6 of the Temporary Order shall not
be returned until further Order of Court.
[g) 8.
The following additional reliefis granted as authorized by ~6108'of this Act:
Law enforcement agencies, human service agencies and school districts shall not
disclose the presence of Plaintiff and/or address, telephone nmnber, or any
other demographic information about Plaintiff and/or the minor children,
except by further Order of Court,
This Order shall remain in effect until modified or terminated by the Court and
can be extended beyond its original expiration date if the Court finds that
Defendant has committed an act of abuse or has engaged in a pattern or
. practice that indicates risk of harm to Plaintiff and/or the minor children.
Defendant is enjoined from damaging or destroying any property ownedjointIy
by the parties or owned solely by Plaintiff.
Defendant is to refrain from harassing Plaintiff's relatives or the minor
children.
o 9. Defendant is directed to pay temporary support for _ as follows: _' This Order for
support shall remain in effect until a final support order is entered by this Court. However, this
Order shall lapse automatically if Plaintiff does not file a complaint for support with the Court within
fifteen (15) days of the date of this Order. The amount ofthis temporary order does not necessarily
reflect Defendant's correct support obligation, which shall be determined in accordance with the
guidelines at the support hearing. Any adjustments in the final amount of support shall be credited,
retroactive to this date, to the appropriate party.
o
10.
The costs ofthis action are waived as to Plaintiff and imposed on Defendant.
o 11. Defendant shall pay $_ to Plaintiffas compensation for Plaintiff's out-of-pocket losses,
which are as follows: OR
-~ ~ .~
o Plaintiff is granted leave to present a petition, with appropriate notice to Defendant,
to _ requesting recovery of out-of-pocket losses. The petition shall include an exhibit
itemizing all claimed out-of-pocket losses, copies of all bills and estimates of repair, and an
Order scheduling a hearing. No fee shall be required by the Prothonotary's 'office for the
filing of this petition.
o
12.
BRADY INDICATOR
o 1. The Plaintiff or protected personls is a spouse, former spouse, a person who
cohabitates or has cohabited with Defendant, a parent ofa common child, a child of that
person, or a child of Defendant. .
o 2. This Order is being entered after a hearing of which Defendant received actual
notice and had an opportunity to be heard.
o 3. Paragraph I of this Order has been checked to restrain Defendant from
harassing, stalking, or threatening Plaintiff or protected person/so
o 4. Defendant represents a credible threat to the physical safety of Plaintiff or
other protected person/s OR
o The terms of this Order prohibit Defendant from using, attempting to use, or
threatening to use physical force against Plaintiff or protected person that would reasonably
be expected to cause bodily injury.
IZ> 13. THIS ORDER SUPERCEDES ANY PRIOR PFA ORDER llnd ANY PRIOR
ORDER RELATING TO CHILD CUSTODY.
IZ> 14.
entered.
All provisions of this Order shall expire one year from the date this Order is
NOTICE TO THEDEFENDANT
Violation of this Order may result in your arrest on the charge of Indirect
Criminal Contempt which is punishable by a fine of up to $1,000 and/or a jail
sentence of up to six months. 23 Pa.C.S. 36114. 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,
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U .s. Territories, and the Commonwealth of Puerto Rico under the Violence Against
Women Act, 18 U.S.C.~2265. If you travel outside of the state and intentionally
violate this Order, you may be subject to federal criminal proceedings under that
Act. 18 U.S.C.99 2261-2262. If paragraph 12 of this Order has been checked, you
may be subject to federal prosecution and penalties under the "Brady'! provisions
of the Gun Control Act, 18 U.S.C.S922(g), for possession, transport or receipt of
firearms or ammunition.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over Plaintiff's residence OR any location where a violation
of this Order occurs OR where Defendant may be located, shall enforce this Order. An arrest for
violation of Paragraphs I through 7 of this Order may be without warrant, based solely on probable
cause, whether or not the violation is committed in the presence of the police. 23 Pa,C.S.~6113.
Subsequent to an arrest, the police officer shall seize all weapons used or threatened to be
used during the violation of the Protection Order or during prior incidents of abuse. The
Cumberland County Sheriffs Department shall maintain possession of the weapons until further
Order of this Court. When Defendant is placed under arrest for violation of the Order, Defendant
shall be taken to the appropriate authority or authorities before whom Defendant is to be arraigned.
A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police
officer OR Plaintiff, Plaintiff's presence and signature are not required to file the COmplaint.
If sufficient grounds for violation of this Order are alleged, Defendant shall be
arraigned,bond set and both parties given notice of the date of the hearing.
BY THE COURT,
JJ~ I.. _~ tfJ IV).Jr-:
~ler, Jr., Judge .
Th~:~~~ end~ursuant to the consent of Plaintiff and J;>efendant://, 4L
L~;Jt~ ~:;;;:~tiff /
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an Carey, Attorney for P
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PAl 70 13
(717) 243-9400
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CUMB,CO PROTHONOTARY
141001
***************************
*** MULTI TN REPORT u*
***************************
TX/RX NO
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2480
[ 01]9p2405331
[ 03]9p2438026
[ 04]92490779
CENTRAL PROCESS
LEGAL SERVICES
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ERROR
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OFFICE OF THE PROma-urARY
OJMBERLANO c:o:rt-ITI COUR'l1-IOOSE
ONE a:uRTHOOSE SQUARE
CARLISLE, PA. 17013-3387
(717) 240-6195
FAX (717) 240-6573
TO ~
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Cent.. PeOceGs.
PA STATE POLICE
VIA TELECOPIER
FAX n:
717-249-0779
PR01:
CURTIS R. LONG
RE:
PFA ORDERS
MESSAGE:
I.:J....
JI/J-6IIJ.- tIK). OF PAGES (INCLUDING COVER SHEET)
This ~ is intartrl mly fur tIe 1Se of ITa irrlivid.el cr <';I1ti~ to I>hidl is is .;.jj.u....:'l:l. .nJ naj
rnlWin inftmrat:im tmt :is p:iv:i.le;J'd. oonfidEntial .nJ e<e:rP: fron rli",.,I,.,,"I-e tn'lec' 4T'1 ;...*,1.. w. ff
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dist::rituI:i<; or. CCpfi1'9 of thi<> <Xmru"1i.ceItim ~ str.i.ctly J;IrttibitJ:rl. If jO.l hM! re:ei\,9j ttllS
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LEZLI JUNE BAKE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 00-1072 CIVIL TERM
LA WERENCE MARTIN HAKE,
Defendant : CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this "27d day of FEBRUARY, 2001 this Court certifies that the
attached complaint has been properly completed and verified, and there is probable cause
for this issuance of process. In consideration ofthe attached Commonwealth's Petition, a
WARRANT IS ISSUED FOR THE ARREST of the Defendant, LA WERENCE
MARTIN HAKE.
If the defendant is found during normal Courthouse hours, the defendant is to be
brought immediately before the Court. Ifnot found during Courthouse hours, the
defendant is to be taken to the on-call District Justice and bail set pursuant to the Rules of
Criminal Procedure.
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. The
assessment of costs to be determined by the Trial Judge subsequent to trial.
JonathanR.Birbeck J.' t"Illde4bl.dfl.
Chief Deputy District Attorney CtfUJ5 7
LA WERENCE MARTIN HAKE
By the Court,
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LEZLI JUNE HAKE,
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: 00-10nCIVIL
LA WERENCE MARTIN HAKE,
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 ofIndirect Criminal
Contempt:
1. 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 ofthis 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. S 6113.
6. The plaintiff and/or the defendant may seek modification ofthe Order based
on the filing of this petition as the Court deems appropriate following the trial
in addition to any other sentence. 23 Pa.C.S.A. S 6113.
WHEREFORE, the Commonwealth requests the defendant be commanded to
appear before the Court on the charge of Indirect Criminal Contempt.
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FAX NO. 7662238 p, 02
POLICE
CRIMINAL COMPLAINT
JAN-30-01 TU[ 23:27. UPPER ALLEN POLICE
GOMMONWEALTH m' PF,NNSYLV-UlIA
, COUNTY OF: ('\l1liberland
'Gineri.l District ~UlIE,.: 09-3-05
I.trlcl Justice N_:Hon. Gayle A. Eldl:>r
.: 507 N. York Street
Mech811icsburg, PA 170!;<;
OOMJ40~TH OF PENNSYLVANIA
'\IS.
elq:n<re'
(717) 766-4575
DEFENDANT:
NAME and ADDRESS
r lJl:ll(B, Lawrence Martin
2551 Valley Road
Marysville PA 17053
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~\amt/J,...:ident NLnber
2001-01-352
tIs Sex e 9"dont1~ D.O.B.
rarB\e
gg Hole 07/09/1957
ferd>>'lt1s V ide lnfunmtfon:
plare- Nl.lIb=r I $t~te tQlSistratial Stft::kerCftV'YY)
LlveS0'l TradClr'Q Wlnber OTp\::nntl1n::ldent NIJI s if other Partlc;pents
.fErdlnl:'. sa:lal SOO\I'ity I!.IIfJCr eIerdirlt's SID
206-54-3303
f~tle Driyor1e Lletr11B ~w
Stattl
PA 19326381
/NIBRs Code
District Attorney's Office, n Approved 0 Disapprove~ because:
Cll10 dlltrfCI attorr'<'\' IIIlY ,"",'re~t the """'loin,. .r....' ..r",,' .ff,davlt. or bOtII be /lAlrWed I:!i tho .tt""'"Y for ,he CaImnleolth prim' to
mil'll. po.A.Cr.p. 11l1.)
(NR UT Att~ tor LIohllMII'IeaLtn ~ P~ease Pnnt Or 1'1l)!~
t:!lolptU"e Of AttorrEy 10r o..IIlU..~tnl
(Oate.1
1. Officer Andrew Parsons
CN.... of A1flent'PL""'" Prmt IX" TlI"')
of ~i Allen 'IbwJ:~ ~lica PA0211800
CIimt fy Dopll'\ml1nt or ~ !It,.._,'.d:rd ''''If!feaL SlbIiVlO'on) , (1'011<<1 ~ (Ill Nlnber)
do hereby state:(eheck the appropriate bOll)
1. Il!l 1 accuse the above named defendant. who lives at tne address set forth above
o I accuse Iln defendant whuse name is unknown t,o me hut who is descrlbod ~
:HG9
(Officer Ila:lge IIu1I>lr/I.D.)
(Orieir<ltlrg ~ Cooa ~(iXl,)) ,
o Ia:ccu;e the defendant whose name and popular deSignation or nicknllll\c is unknown to me and 'whom I have -
therefore designated as John Doe
with violating the penal laws of the Commonwealth of Pennsylvania at 600 BlOCk Cu/l'J:Jerlanr.l Pointe
Circle in Uppel' Allsn Township CPlaca'Polltlcal N:xl'V1S,cn)
in C\Jmberland COllnty on or about Januatj!. 30. 2001 at 1500 hours
Participl\lltl; wore: (If there Were pal"ticipants, place their names here, repeating the namo of the above defendanl)
H1\I<B. lawreru=e Martin. ,
2, The acts committed by the accused we.re:
(Set forth . sumary 01 the fads ''It'ficient to sd.>,oe the! delerdlnl of the ....wre of the offense ~. A citatl'" to the statute .LL*ly ~i"L.tod
without tll)re, is not sufficfEflt. (n It SUJm!lI")' case. yoJ Il'Uit cite the sra:1fic sectiCl'l ;m st4ectlciHJf the statt.rte or ClI"'<NI"IQI'\2 allegcd{y Violated.)
INDIRECl' CRIMINAL mNI'EMFl' (PFA)
The defendant did violate an Order issued \.ll"lder thE> Prot=tion From Abu,<;e Act, Civil
2000-1072 by the Honorable J. weBley Oler, .W'., c.\.Uti::lerland County, dated March is
2000 with an attar.~IJSd m::di.Hcation dated ,June 30, :0000 in which tbe detendant is
prohibited fro't\ having any contact wit.h his children namely, Willii;lll\ Martin lIake,
Jacquelyn c"itlin Flake, and l\rranda Jayne Hilke except. for s~r'lised visitation
thrauqh an accredited s'll.~rvised visication program, and in which the defendant is
specifically ordered to sl.ay away fron I~7.1i HaJ<g I s CI.rrr<ll1t rE'.Rideru;e in 600 block
0..Int:erland FoiBLe CirCle, except. when n'd!lSferring custody of ms children at Lezli
Hake I S 'r<esi4enue and on such occ::;;u;ions the defendant ie to remain in his vehicle
during said tr-unsfer of CLlStody,
IiS'C 412A-Cll/OO)(r'l"'<<lJc'kn)
1-3
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JAN-3D-D! rUE 23:27.
UPPER ALLEN POLICE
. FAX NO. 7662238
p, 03
POLICE
CRIMINAL COMPLAINT
Defendant Name: HAI<E, Iawrence l-Bttin
Docket Number:
all of which were against the peace and dignity of the Commonwealth of Pennsylvania alld contrary to Lbe Act
of A..embly, or ill violation of 1.6113 of t~e 23 Fa.C.S. 1
(sect;on) (s~bGoctiQn) (PA SI.tute) ~"i)
2. of the
(Se(ltion) (Subsection) CPA Statute) (cQI,mh)
3. of the
(S~ctionJ (SubgQetfon) CPA Statute) (counts)
4. 01 the
(Soet;on) (Subsel;tion) (PA St.tute) (counts)
3. r ask that a WllJ:rant of arrest or a summons be issued and that the defendant be requirod to answer the charges
r have made. (In order for a warrant of arrest to Issue, the Idtached affidavil of prohlibIo CIl1lS8 must be compl.!t;ed
and SWDl'Il to bolore the IssWng authority.)
4. I verify that the facts set forth in this complaint are true and corract to the best. of my knowledge or illformati'on
and belief. This verification is made subject to the penaltios of Sootion 4904 of the Climes Code(18 PA. C.S.
B 4904) relllling to Unsworn fwsiflcation t.o authurities. -* ~ '"
:} (l.I\V"'-t!II 30 , .;loa ( , H ,~--- J:::'~_
, 19na '8 or Ilt1"Hmt} .
AND NOW, on this date , I certify the complaint ha.~ beell propl!rly
completed and vorified. Aii aflldavit of prubable cause must be completed'in order for a warrant te Issue.
2.8
\l~~U'ne ~Ut~~t\ty)
~AL
(Maglster'a~ ijlstrlCt)
AOPC 41Z-c4/Q6B)(rOproductfonl
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JAM-30-01 rUE 23:28,
UPPER ALLEN POLICE
. FAX NO, 7662238
P,04
Defendant Name: HAKE, Lawrence Martin
-,
Dockot Number:
POLICE
CRIMINAL COMPLAINT
.
AFPIDA VIT of PROBABLE CAUSE
Cbmp./Il1C. No, 2001-01-352
On Januaxy 30, :l001 this officer received a COllplaint from lezli Haks in
reference to the Detendilnt violat: i ng a pmtection from abuse Ol.-ds~. In a written
sLCltement, Lezli lIake ...lle<Jed Lhat on January 30, ,"001 at 1500 hours the Defendant
arrived at her residence. Lezli Bake f\J1:'\:her <llleged that on the alleg.;d date th;
Defp.ndant had <.-ontact with their chi 1 dren.
on January 30, 2001 at approxima1:ely 1800 hours this officeJ;' interviewed the
Defendant at t11e Upper Allem 'I'o\oinship PoI tce Station. The Defendant admitted to being
. in the ...,."....a of Lezli Bake' D l:'Csiden.c:oe inc11ldlng standi.ng on the front stcx:>p of bEl!"
l"esidence. '!he Defendilnt further adl11iLted to I1aving contact with their' children Cll1
the alleged date.
Per a Final Protection Order ordered by the Honorable J, Wp..':lley Oler, Jr" dated
March 15, :lOOO,. with an attached m::xii.fication dated June 30 2000, the DefendarJt is
ordered to stay away from Lezli Hake's :recidence lll'lless tr-.m.sferring custooyof
children, on which such oocasionG the De!tendant ill ordered to remain in his vehic'le
during the tr'i:lI1sfer at custody. On the alleged date of violation the Defendant wa$
not trans[e=ing cuctody of the children. The order further states that the Defendant
is no\. to have arry contact with the children unless it. is supervised visitation
through ilfl accrMi.ted supe~vised vicitation p:n:gram.
):
//
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I, Officer Andrew Parsons , BErNG DULY SWORN ACCORDING TO
I.A W, DEPOSE MID SAY THAT THE I!'ACTS SET FORTH Thl THE FOllEGOING AFFlDA vrr ARE
TIUJll; AND CORBEC'l' TO TIm BEST OF MY KNOWLEDGI:!l, INFORMATION AND BELI!!:F.
l/I ~~J -
" (./ 19na ure 0
Sworn to me and subscribed bGfore me this
day of
Date
, Di$trict Justice
My commission expires first Monday of January. _'
SEAl.
AOPC 412C.('1/24/99}(reprodue';on)
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LEZLI JUNE HAKE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of the minor : CUMBERLAND COUNTY, PENNSYLVANIA
children: WILLIAM MARTIN HAKE,
JACQUELYN CAITLIN HAKE, : CIVIL TERM
and AMANDA JAYNE HAKE,
vs. : NO. 2000-1072
LAWRENCE MARTIN HAKE,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
FINAL PROTECTION ORDER
Defendant's Name: LAWRENCE MARTIN HAKE
Defendant's Date of Birth: 07/09/1957
Defendant's Social Security Number: 206-54-3303
Names of Protected Persons: LEZLI JUNE HAKE, and the minor children:
WILLIAM MARTIN HAKE
JACQUELYN CAITLIN HAKE
AMANDA JAYNE HAKE
AND NOW, this ~~ay of March , 2000, the court having jurisdiction over the parties
and the subject-matter, it is ORDERED, ADJUDGED, and DECREED as follows:
Plaintiff, Lezli June Hake, is represented by Joan Carey of Legal Services, Inc.; Defendant,
Lawrence Martin Hake, is represented by Jane M. Alexander, Attorney at Law.
Defendant, although agreeing to the terms of this Order, does not admit the allegations made
in the Petition.
lR> Plaintiffs request for a Final Protection Order is granted pursuant to the consent of
Plaintiff and Defendant.
D Plaintiffs request for a Final Protection Order is denied.
lR> 1. Defendant shall not abuse, stalk, harass, threaten Plaintiff or any other
protected persons in any place where they might be found.
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o 2. Defendant is completely evicted and excluded from the residence at or any
other residence where Plaintiff may live. Exclusive possession of the residence is granted to
Plaintiff. Defendant shall have no right or privilege to enter or be present on the premises.
o On _ at _.m" Defendant may enter the residence to retrieve his/her clothing and
other personal effects, provided that Defendant is in the company of a law enforcement
officer when such retrieval is made.
[29 3. Defendant is prohibited from having ANY CONTACT with Plaintiff andJorthe
minor children (except as provided in paragraph 5 regarding custody) 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, and/or place of employment
or the schools and/or day care facility ofthe minor children. Defendant is specifically ordered
to stay away from the following locations for the duration of this Order:
Plaintiff's cnrrent residence: Undisclosed location
Residence of Plaintiff's varents: June and Cliff Miller, 6300 Wertzville Road,
Mechanicsburg, Cumberland County, Pennsylvania
Plaintiff's vlace of emvlovment: Health America (a subsidiary of Coventry
Health Care), 6345 Flank Drive, Suite 100, Harrisburg, Dauphin County,
Pennsylvania
School of the minor children: Shaull Elementary School, 1920 Good Hope
Road, Mechanicsburg, Cumberland County, Pennsylvania
[29 4. Defendant shall not contact the Plaintiff or the minor children (except as
provided in paragraph 5 regarding custody) by telephone or by any other means, including
third parties.
[29 5. Custody of the minor children, William Martin Hake, Jacquelyn Caitlin Bake,
and Amanda Jayne Hake, shall be as follows pending further Order of Court after a
conciliation conference:
Plaintiff shall have primary physical and legal custody of the children.
Defendant shall have supervised visitation with the children through an
accredited supervised visitation program mutually agreed upon by the parties
through their respective counsel. Defendant shall be responsible for any and all
costs incurred for supervised visitation.
~_i
D 6. Defendant shall immediately turn over to the Sheriff's Office, or to local law
enforcement agency for delivery to the Sheriff's Office, the firearms and/or specific weapons used
or threatened to be used by Defendant in an act of abuse against Plaintiff and/or the minor child/ren:
D 7. Defendant is prohibited from possessing, transferring or acquiring any other firearms
and/or specific weapons for the duration of this Order. Any firearms and/or weapons delivered to
the sheriffunder Paragraph 6 of this Order or under Paragraph 6 ofthe Temporary Order shall not
be returned until further Order of Court.
!29 8.
The following additional relief is granted as authorized by ~6108 ofthis Act:
Law enforcement agencies, human service agencies and school districts shall not
disclose the presence of Plaintiff and/or address, telephone number, or any
other demographic information about Plaintiff and/or the minor children,
except by further Order of Court.
This Order shall remain in effect until modified or terminated by the Court and
can be extended beyond its original expiration date 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 and/or the minor children.
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 Plaintiffs relatives or the minor
children.
D 9. Defendant is directed to pay temporary support for _ as follows: _' This Order for
support shall remain in effect until a final support order is entered by this Court. However, this
Order shall lapse automatically if Plaintiff does not file a complaint for support with the Court within
fifteen (15) days of the date of this Order. The amount of this temporary order does not necessarily
reflect Defendant's correct support obligation, which shall be determined in accordance with the
guidelines at the support hearing. Any adjustments in the final amount of support shall be credited,
retroactive to this date, to the appropriate party.
D
10.
The costs ofthis action are waived as to Plaintiff and imposed on Defendant.
D II. Defendant shall pay L to Plaintiff as compensation for Plaintiff's out-of-pocket losses,
which are as follows: OR
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o Plaintiff is granted leave to present a petition, with appropriate notice to Defendant,
to _ requesting recovery of out-of-pocket losses. The petition shall include an exhibit
itemizing all claimed out-of-pocket losses, copies of all bills and estimates of repair, and an
Order scheduling a hearing. No fee shall be required by the Prothonotary's office for the
filing of this petition.
o
12.
BRADY INDICATOR
o 1. The P1aintiff:.lr protected personls is a spouse, former spouse, a person who
cohabitates or has cohabited with Defendant, a parent of a common child, a chIld of that
person, or [l child of Defendant.
o 2. This Order is being entered after a hearing of which Defendant received actual
notice and had an opportunity to be heard.
o 3. Paragraph 1 of this Order has been checked to restrain Defendant from
harassing, stalking, or threatening Plaintiff or protected person/so
o 4. Defendant represents a credible threat to the physical safety of Plaintiff or
other protected person/s OR
o The terms of this Order prohibit Defendant from using, attempting to use, or
threatening to use physical force against Plaintiff or protected person that would reasonably
be expected to cause bodily injury.
~ 13. THIS ORDER SUPERCEDES ANY PRIOR PFA ORDER llnd ANY PRIOR
ORDER RELA TlNG TO CHILD CUSTODY.
~ 14.
entered.
All provisions of this Order shall expire one year from the date this Order is
NOTICE TO THE DEFENDANT
Violation of this Order may result in your arrest on the charge of Indirect
Criminal Contempt which is punishable by a fine of up to $1,000 and/or a jail
sentence of up to six months. 23 Pa.C.S. 96114. Violation may also subject you
to prosecution and criminal penalties under the Pennsylvania Crimes Code. This
Order is enforceable in all fifty (50) States, the District of Columbia, Tribal Lands,
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U.S. Territories, and the Commonwealth of Puerto Rico under the Violence Against
Women Act, 18 U.S.C.~2265. 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.~~ 2261-2262. If paragraph 12 ofthis 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.~922(g), for possession, transport or receipt of
firearms or ammunition.
NOTICE TO LAW ENFORCEMENT OFFlCIALS
The police who have jurisdiction over Plaintiffs residence OR any location where a violation
of this Order occurs OR where Defendant may be located, shall enforce this Order. An arrest for
violation of Paragraphs I through 7 ofthis Order may be without warrant, based solely on probable
cause, whether or not the violation is committed in the presence of the police. 23 Pa.C.S.!}6113.
Subsequent to an arrest, the police officer shall seize all weapons used or threatened to be
used during the violation of the Protection Order or during prior incidents of abuse, The
Cumberland County Sheriffs Department shall maintain possession of the weapons until further
Order of this Court. When Defendant is placed under arrest for violation of the Order, Defendant
shall be taken to the appropriate authority or authorities before whom Defendant is to be arraigned.
A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police
officer OR Plaintiff, Plaintiffs presence and signature are not required to file the complaint.
If sufficient grounds for violation of this Order are alleged, Defendant shall be
arraigned, bond set and both parties given notice of the date of the hearing.
J~~q4-
This Order is entered pursuant to the consent of Plaintiff and Defendant:
~~ /:;/'
Lezli une ake, Plaintiff /
ICI?;: (../
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,:Wan Carey, Attorney for P ntiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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LAWRENCE M. BAKE,
Plaintiff
: IN THE OOURT OF CDMMON PLEAS OF
: Cill'BERLAND COUNTY, PENNSYLVANIA
:
vs.
: NO. Oo-1210 CIVIL TERM
.
.
LEZLI J. RAKE,
Defendant
: CIVIL ACrION - LAW
IN CUSTODY
.
.
alDER OF COORT
AND fDi, this q&.
consideration of the attached
and directed as follows:
, 2000, upon
it is ordered
day of
CUstody Concil'
I. The Father, Lawrence M. Bake, and the Mother, Lezli J. Bake,
shall have shared legal custody of William Martin Bake, born May 12, 1991,
Jacquelyn Caitlin Bake, born June 11, 1993 , and Amanda Jayne Bake, born
September I, 1998. Each parent shall have an equal right, to be exercised
jointly with the other parent, to make all llBjor non-emergency decisions
affecting the Children's general well-being including, but not limited to,
all decisions regarding their health, education and religion.
2. The Mother shall have primary physical custody of the Children.
3. The Father shall have partial physical custody of the Children
frc::m August 13, 2000 at 6:00 p.m. through August 20, 2000 at 6:00 p.m.
Thereafter, the Father shall have custody on alternating weekends from
Friday at 6:00 through Sunday at 6:00 p.m., with the exception of the
Father's first alternating weekend period of custody which shall run from
Friday, September 1 at 6:00 p.m. through Labor Day, september 4, 2000 at
6:00 p.m.
4. The Mother shall have custody of the Children for vacation from
August 3, 2000 through August 13, 2000. During this period, the Mother
shall ensure that the Children contact the Father by telephone on Sunday at
6:00 p.m.
5. The parties shall share or alternate having custody of the
Children on holidays as follows:
A. CBRISTMAS: The Christmas holiday shall be divided into
Segment A, which shall run from Christmas Eve at 12:oo noon
through Christmas Day at 12:00 noon, and Segment B, which
shall run frc::m Christmas Day at 12:00 noon through December 26
at 12:00 noon. The Mother shall have custody of the Children
during Segment A in even numbered years and during Segment B
in odd numbered years. The Father shall have custody of the
Children during Segment A in odd numbered years and during
Segment B in even numbered years. The parties shall share
having custody of the Children over the J:"emainder of the
Christmas school bJ:"eak as arranged by agJ:"eement.
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B. TBANKSGIV!NG: 111e 111anksgiving holiday shall be divided into
Segment A, which shall run fran the Wednesday before
111anksgiving at 6:00 p.m. through Thanksgiving Day at 4:00
p.m., and Segment B, which shall run fran Thanksgiving Day at
4:00 p.m. through the following Friday at 6:00 p.m. 111e
Father shall have custody of the Children during Segment A in
even numbered years and during Segment B in odd numbered
years. The Mother shall have custody of the Children during
Segment A in odd numbered years and during segment B in even
numbered years.
c. EAS:rER: 111e Easter holiday shall be divided into Segment A,
which shell run fran the Thursday before Easter at 6:00 p.m.
through the Saturday before Easter at 12:00 noon, and Segment
B, which shall run fran the Saturday before Easter at 12:00
noon through the following Monday at 6:00 p.m. if there is no
school, and through sunday at 6:00 p.m. if there is school on
Monday. 111e Mother shall have custody of the Children during
Segment A in even numbered years and during segment B in odd
numbered years. 111e Father shall have custody of the Children
during Segment A in odd numbered years and during Segment B in
even numbered years.
D. MmnUAL DAY/JOLY 4TB/Lll1lCR D1lY: In even numbered years, the
Father shall have custody of the Children on Memorial Day and
Labor Day and the Mother shall have custody en July 4th. In
odd numbered years, the Mother shall have custody on Memorial
Day and tabor Day and the Father shall have custody on July
4th. 111$ periods of custody on Memorial Day and Labor Day
shall run fran 9:00 a.m. until 6:00 p.m. and the period of
custody on July 4th shall run fran 9:00 a.m. until after the
fireworks.
E. MCmIER'S D1lY/FM.'BER'S D1lY: 111e Mother shall have custody of
the ChilCiren every year on Mother's Day fran the Saturday
before Mother's Day at 6:00 p.m. through SUnday at 6:00 p.m.
111e Father shall have custody of the Children every year on
Father's Day from the Saturday before Father's Day at 6:00
p.m. thrOUgh Sunday at 6:00 p.m.
F. In the event the Father's period of holiday custody falls
inmediataly preceding or following his regular period of
custody, the Father's period of holiday/regular custody shall
run continuously without interruption.
G. 111e holiday custody schedule shall supersede and take
precedence over the regular custody schedule.
6. Each party shall be entitled to have custody of the Children for
summer vacation each year for 2 weeks, to be scheduled either consecutively
or non-consecutively as agreed between the parties.
7. The parties shall exchange custody of the Children at the Mobil
Station on the Carlisle Pike in Hampden Township.
.
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8. Each party shall ensure that the other party has his or her
current address and telephone number. In the event either party intends to
remove the ChjJ.dren from his or her residence for an overnight period or
longer, that party shall notify the other party of the address and
telephone number where the Children can be contacted.
9. In the event either party intends to relocate his or her
residence, that party shall provide the other party with at least 60 days
advance notice so that the parties can make any necessary adjustments to
the custody arrangements required by the relocation by agreement or through
the legal process if necessary.
10. The parties shall communicate directly with each other concerning
issues involvin; the Children only.
11. The Father shall ensure that the Children do not have contact with
their paternal grandmother unless the Father is present.
12. The Mother shall ensure that the Children do not have contact with
Karen Martinez unless the Mother is present.
13. Neither party shall do or say anything which my estrange the
Children fran the other parent, injure the opinion of the Children as to
the other parent, or hamper the free and natural development of the
Children's love and respeCt for the other parent. Both parties shall
ensure that third parties having contact with the Children eomply with this
provision.
14. This Order is entered pursuant to an agreement of the parties at a
CUstody Conciliation Conference. The parties my modify the provisions of
this order by 1lDJtual consent. In the absence of 1lDJtual consent, the terms
of this Order shall control.
BY THE o::ltlRT,
cc:
Jane M. Alexander, Esquire - Counsel for Father
Maryann Murphy, Esquire - COunsel for Mother
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LAWRENCE M. HAKE, : IN THE CCURT OF OOMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
:
vs. : NO. Oo-l2l0 CIVIL TERM
.
.
LEZLI J. HAKE, : CIVIL ACTION - LAW
Defendant . IN CUSTODY
.
PRIOR JUDGE: J. Wesley aler, Jr.
CUS'l'ODY CXD::ILIATICH SUMMARY REPORT
IN ACOJIIDANCE WITH CllMBERIJ\ND CODNTY ROLE OF CIVIL PBOCEOORE
19I5.3-8, the undersigned Custody Conciliator Sl.lbmits the following report:
1. The pertinent information concerning the Children who are the
subjects of this litigation is as follows:
NAME
DATE OF BIRTH
UJl<lUllIf.L'.Ly IN UJ:j'~UJ~ OF
William Martin Bake
Jacquelyn Caitlin Bake
Amanda Jayne Bake
May 12, 1991
June 11, 1993
September I, 1998
Mother
Mother
Mother
2. A Conciliation Conference was held on August I, 2000, with the
following individuals in attendance: The Father, Lawrence M. Bake, with
his counsel, Jane M. Alexander, Esquire, and the Mother, Lezli J. Bake,
with her counsel, Maryann Murphy, Esquire.
3. The parties agreed to entry of an order in the form as attached.
Date
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Dawn S. Sunday, Esquire
Custody Conciliator
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LEZLI JUNE HAKE,
Plaintiff
V.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00-1072 CIVIL TERM
LA WERENCE MARTIN HAKE,
Defendant
CHARGE: INDIRECT CRIMINAL CONTEMPT
AND NOW, this
ORDER OF COURT
2. ~ tL day of AUGUST, 2001 this Court certifies that the
attached complaint has been properly completed and verified, and there is probable cause
for this issuance of process. In consideration of the attached Commonwealth's Petition, a
WARRANT IS ISSUED FOR THE ARREST of the Defendant, LA WERENCE
MARTIN RAKE.
If the defendant is found during normal Courthouse hours, the defendant is to be
brought immediately before the Court. If not found during Courthouse hours, the
defendant is to be taken to the on-call District Justice and bail set pursuant to the Rules of
Criminal Procedure.
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. The
assessment of costs to be determined by the Trial Judge subsequent to trial.
Jonathan R. Birbeck
Chief Deputy District Attorney
Co,Y dl veo By D. 4. 01[:<"
LA WERENCE MARTIN HAKE
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LEZLI JUNE HAKE,
Plaintiff
:IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
V.
00-1072 CIVIL TERM
LA WERENCE MARTIN HAKE,
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:
1. 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 ofthis 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. S 6113.
6. The plaintiff and/or the defendant may seek modification ofthe Order based
on the filing ofthis petition as the Court deems appropriate following the trial
in addition to any other sentence. 23 Pa.C.8.A. S 6113.
WHEREFORE, the Commonwealth requests the defendant be
appear before the Court on the charge of Indirect Criminal Cont
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COMMONWEALTH OF PENNSYLV ANL~
COUNTY OF: C~lalltl
~iS'er;a( Ol.trk, 1i.JItlor: 09-1-02
FI~~I'i~t ~Uitice NaI&:H",. Robt::.rL V.
1-: 1901 state Street
I aurp Hill, Pa 17011
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11otq:hcre:
~llove
POLICE
CRIMINAL COMPLAINT
(717) 761-0583
DEFENDANT:
r
COMlfONWEALTH OF PENNsYLVANIA
\'s.
NAME ~ ADDRESS
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!Docket No.:
Inate Filed:
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l;)eferQw1t's ~tnnh:;iry
U\.Ilit. U As!... 0 Black
[J.,__,.D Notl"" ""'rl.... 0--
;&Je, :t'S A.ICA.
I
Lawrenoo Martin BAKE
2251 Valley Rd.
Ma~ysville, FA 17053
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erdmt's C.O.B. ~fan:L;ntls Social $eQr;ty Nurt:ler eferdntl~!\om --r
07,09/1957 06-54-3303
IS vehicle InfOl1JliltiLn! endIiInt's Driverls lleE!'lSe Nl.nt:el"
plate tMter state- RBIili~tratlM SticlcQt"(IlIII/YV) Stll'Wo
.",'11'" den, liUIIlor IlIlS C<do
ClI-oB-r'i'l
District Attorney's Office n Approved 0 Disapproved because:
(11" di.,ric'.at'oirEv IIiIy r<qJ;",'u;;lt the ampla;"t, .rres, ...,."" affidavit, or both tlIl ~ l7f the llttorr'IOy 1... the ~lth p-ior t;;-"
m,rg ~...c. ... 101.l
(Nan;o ct Attorney tor wlll.....eaUI1 a P~OiISe Prlnt or 1)1:le)
1. Cpl. Robert L.Pinti
'""'" of Afflw'PI<>OSe Prln, or T>I"l
of Police
(Ider\tt fy ~ ..~ It or ~ !ed ll'd PIl m",l !Uldtvisiall
do hereby state:(check the appropriate bOll)
1. tI I accuse the above named defendant, who lives at the address set forth above
D I "ccu.e I1n defendant wbose lla1l1~ i. unknown W me but who Is described as
(Slnture Of AttOl'T'l!)' tor ~ltrl)
(uate)
1606
(cHi"", Ilac:Ige NUIller/l.O.)
PA0210300
(Po ,co /l11I!f':( all NuIIlerl (lr"ig!notirg ~ case lLnilor(a:A>>
D I a."'Use the defendant whose name and popular designation or nickname is unknown to me and whom I have
r.herAfo~e ri..sigMted as John One
I'.ith violating the penal laws of the Commonwealth o(Pennsylvania at 98 South Enola Drive, Enola,
in Easl' Pennsboro Township (Pl...,.Pol,tlcol !Uldlvisial)
[n 01!l'ih.o,..l.and CountY on orabeut 08-24-01 1800 HRS.
Participants were: (if there were participants, place their names here, repeating the name of the abOVe defendant)
Lawrence Ma~tin RAKE
~, The acts committed by the accused were:
~set iOt"".h a $l.fflIQrt of the fact;s Sl.lfficient to advise the .;);(...~~ of the rature of the offense c:harge!d. A cltatta"l to the $tatl..e alliQ8d[y Vi.)latl"rl
,,,ftl':~ ll'I:Ir"o, ;, r"C-t Nffh:lant. Tn a "3lmIlry~. yoJ. ~t: ~;~ ~ ~iffc. scctfen cn:I $tJ:6ec.tll:" u( ~Il'd' tlltl::lll.lle or ordin;n:e allegedry v'otate:l.J
Did ~iolate the PROTECTION FROM ABUSE ORDER #00-1072 Civil 2000 issued by the Hono~able
Judge Wesley Oler Jr., and extended 8 May, 2001, to wit: the defendant was orde~ed not
Lo abuse, stalk, harass or threaten Plaintiff. The Elaintiff reported on 08-24-01,
during a meeting to exchange their chi1d~en, defendant yelled at he~ that he would get
her, it was her time to suffer and remarked that others would get he~.
PROBABLE CAUSE: Plaintiff contacted this officer On 08-24-01, advising that she met
defendant in the parking lot of the East Pennsboro Township Municipal Building in order
to eltchange tl\eir children for defendant's vls1tation. Defendant reportedly beCllme very
agitated, yelling threats at her to the effect that he would get her and that othe~
people would also get her. A copy of the issued PFA on file in this officer's dept.
prohibits defendant trom harassing or threatening pleintiff.
ii
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(Continuation of 2.1
Defendant Name:
Lawrence Martin MAKE
,j,
POL1CB
CRIMINAL COMPLAJ:l'IT
Docket Number:
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all of which were against the peace and dignj1;y of the Commonwealth of Pellllsylvania and contrary tll the Act
of Assembly, or in violation of 1.6111. of the 'I'i>'~?, 1
(Section) (SUb-Soot;on) (PA Statute) (counts)
<. of thlit
CSectf~l'lI) (Sub-Sect;on) (PA Statute) (counts)
3. M the
(Section) (Sub-Section) (PA s~atu~e) (counts)
4. of th~
(S~~ jgn) (SUb-$$C~ton) (PA Statute) (counts'
3, I ask that a wartant of arrest or a summ!'us be iseu~ and that the dafandant be required to answer the charges
r have mada. Un order for a Wll1'!8Dt of arrest to issue, th" attaehl!d tdIidavit of probable 0&1180 m\18t be co"'pl.rted
and sworn to before the issuiIIg autb.orD;y.
4. I ve~ that the facts set forth in thi$ I;Omplaint are true and correct to the best of my knowl. or infonnatil>n
and belief. This vel'ification is mada subject:to the penalties of Seetion 4904 of the Crimes Code(l!! P A. C.S.
S 4904) relating to unsworn falsification to authorities. ~. ) Id dlJ-
8$-1fi! ,1!)-1Oo1 ~'#t.v.
19 ture of ATf1ant)
ANI> NOW. on this date . . 19 . I certify the complaint has been }lroperly
completed and ""rified. An affi<4\V\t ul probal1le l;ILUlIe must 6e complete(I in order for a warrant to issue.
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dse:BO 10 SG ~n~
;\01'.. (11~-(4,.')6)(ln,.Mn~[ Vert;1(ln)
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LEZLI JUNE HAKE,
Plaintiff
for herself and on behalf of the minor
children: WILLIAM MARTIN HAKE
,
JACQUELYN CAITLIN HAKE,
and AMANDA JAYNE HAKE,
vs.
LAWRENCE MARTIN RAKE,
Defendant
: In the Court of Common Pleas of
: Cumberland County, Pennsylvania
: Civil Action - Law
: No, 00-1072
: Protection From Abuse and Custody
EXTENSION OF
FINAL PROTECTION ORDER
Defendant's Name: LAWRENCE MARTIN HAKE
Defendant's DOB: 07/09/1957
Defendant's SSN: 206-54-3303
Name of Protected Persons: LEZLI JUNE HAKE
WILLIAM MARTIN HAKE
JACQUELYN CAITLIN RAKE
AMANDA JAYNE RAKE
AND NOW, this ~ itaay of May, 2001, the court having jurisdiction over the parties and the
subject-matter, it is ORDERED, ADJUDGED, and DECREED as follows:
Plaintiff, Lezli June Hake, is represented by Joan Carey ofMidPenn Legal Services; Defendant,
Lawrence Martin Hake, is represented by James M. Petrascu of Maffett & Associates.
Defendant, although agreeing to the terms of this Order, does not admit the allegations made in
the Petition. The fact that the final Protection Order was extended by agreement shall not be used
against Defendant in any proceedings regarding the determination of custody of the minor children.
129 Plaintiff's request for an Extension of Fi1lld Protection Order is granted pursuant
to the consent of Plaintiff and Defendant.
~,f:.
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(8)
1.
Defendant shall not abuse, stalk, harass, threaten Plaintiff or any other
protected person in any place where they might be found.
D 2.
Defendant is completely evicted and excluded from the residence at
or any other
residence where Plaintiff may live. Exclusive possession of the residence is granted to Plaintiff.
Defendant shall have no right or privilege to enter or be present on the premises.
D On _ at _,m., Defendant may enter the residence to retrieve his/her clothing and other
personal effects, provided that Defendant is in the company of a law enforcement officer when such
retrieval is made.
(8)
3.
Defendant is prohibited from having ANY CONTACT with Plaintiff, Lezli
June Bake, 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 or the schooI/s and/or child care facility of the minor
children. Defendant is specifically ordered to stay away from the following locations for the
duration of this Order:
. Plaintiff's residence located at 1101 Lindham Court Apartments, Apt.
101, Mechanicsburg, Pennsylvania, except for the limited nurpose of
transferrin!!: custodv ofthe narties' .children. and shall remain in his vehicle
at all times during transfer of custodv.
. Plaintiff's place of employment, wherever that may be.
. The school and/or child care facility of the parties' minor children unless
otherwise determined pursuant to a Court Order relating to custody.
. The home of Dorothy Anne Weaver at 666 Cumberland Pointe Circle,
Mechanicsburg, PA.
- .. .;. ~,
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. Ms. Weaver is Plaintiff's sister, and the temporary caretaker for the
parties' children through a Court-ordered arrangement with Cumberland
County Children & Youth Services. Defendant may come to Ms. Weaver' s
home for the limited pnrpose of transferring custody of the parties'
children, and shall remain in his vehicle at all times durin!!: transfer of
custody.
(8)
4.
Defendant shall not contact the Plaintiff, Lezli June Rake, by telephone or
by any other means, including third parties, except Dorothy Weaver regarding issues
concerning the children.
o
5.
Custody of the minor children" shall be as follows: (or see attached Custody
Order) .
o
6.
Defendant shall immediately turn over to the Sheriff's Office, or to a local law
enforcement agency for delivery to the Sheriff's Office, the following firearms and/or specific weapons
Llsed or threatened to be used by Defendant in an act of abuse against Plaintiff and/or the minor
child/ren:
o 7.
Defendant is prohibited from possessing, transferring or acquiring any other firearms
and/or specific weapons for the duration of this Order Any firearms and/or weapons delivered to
the sheriff under Paragraph 6 of this Order or under Paragraph 6 of the Temporary Order shall not
be returned until further Order of Court.
IJ9
8.
The following additional relief is granted as authorized by ~61 08 of this Act:
. Defendant is ordered to refrain from harassing Plaintiff's relatives and/or
the parties' minor children.
-"'-
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. Defendant is enjoined from damaging or destroying any property owned
solely by Plaintiff.
. This Order shall remain in effect until modified or termiuated by the
Court and cau be extended beyoud its original expiration date if the Court
fiuds that Defendaut has committed an act of abuse or has engaged in a
pattern or practice that indicates risk of harm to Plaiutiff and/or the minor
children.
09.
Defendant is directed to pay temporary support for _ as follows:
This Order for
support shall remain in effect until a final support order is entered by this Court. However, this Order
shall lapse automatically if Plaintiff does not file a complaint for support with the Court within fifteen
(15) days of the date of this Order. The amount of this temporary order does not necessarily reflect
Defendant's correct support obligation, which shall be determined in accordance with the guidelines
at the support hearing. Any adjustments in the final amount of support shall be credited, retroactive
to this date, to the appropriate party.
o 10.
The costs of this action are waived as to Plaintiff and imposed on Defendant.
o 11.
Defendant shall pay $_ to Plaintiff as compensation for Plaintiffs out-of-pocket losses,
which are as follows:
OR
o Plaintiff is granted leave to present a petition, with appropriate notice to Defendant, to
_ 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.
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o 12.
BRADY INDICATOR
o
1.
The Plaintiff or protected person/s is a spouse, former spouse, a person who
cohabitates or has cohabited with Defendant, a parent of a common child, a child of that person, or
a child of Defendant.
o
2.
This Order is being entered after a hearing of which Defendant received actual
notice and had an opportunity to be heard.
o
3.
Paragraph 1 of this Order has been checked to restrain Defendant from harassing,
stalking, or threatening Plaintiff or protected person/so
o
4.
Defendant represents a credible threat to the physical safety of Plaintiff or other
protected person/s OR
o The terms of this Order prohibit Defendant from using, attempting to use, or threatening
to use physical force against Plaintiff or protected person that would reasonably be expected to cause
bodily injury.
129
129
13.
THIS ORDER SUPERCEDES ANY PRIOR PFA ORDER.
14.
All provisions of this Order shall expire on May 7, 2002.
NOTICE TO THE DEFENDANT
Violation of this Order may result in your arrest on the charge ofIndirect Criminal Contempt
which is punishable by a fine of up to $1,000 and/or ajail sentence of up to six months. 23 Pa.C.S.
-"
~.
,
~
ij6114. 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, US. Territories, and the Commonwealth of Puerto Rico under the Violence Against Women
Act, 18 US.C.ij2265. If you travel outside of the state and intentionally violate this Order, you may
be subject to federal criminal proceedings under that Act. 18 US.C.ijij 2261-2262. Ifparagraph 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 US.C.ij922(g), for possession, transport or receipt
of firearms or ammunition.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over Plaintiffs residence OR any location where a violation of
this Order occurs OR where Defendant may be located, shall enforce this Order. An arrest for
violation of Paragraphs 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.ij6113.
Subsequent to an arrest, the police officer shall seize all weapons used or threatened to be used
during the violation of the Protection Order or during prior incidents of abuse. The Cumberland
County Sheriff s Department shall maintain possession of the weapons until further Order of this
Court. When Defendant is placed under arrest for violation of the Order, Defendant shall be taken
to the appropriate authority or authorities before whom Defendant is to be arraigned. A "Complaint
for Indirect Criminal Contempt" shall then be completed and signed by the police officer OR Plaintiff
Plaintiffs presence and signature are not required to file the complaint.
-
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,
If sufficient grounds for violation of this Order are alleged, Defendant shall be arraigned, bond
set and both parties given notice of the date of the hearing.
r{l
J esley 01
This Order is entered pursuant to the consent of Plaintiff and Defendant:
(
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Lezli June e, Plaintiff .
oan Carey, Attorney fo
MidPenn Legal Services
8 Irvine Row, Carlisle, PA 17013
.t~ -fY(~
~S
1:l-~~oU- t;o PS P
~ ~ L3-CP
J s M. Petrascu, Attorney for Defendant
affett & Associates
2201 North 2nd Street, Harrisburg, PA 17110
. ~~~:~1f~~~~J~ltij.i~!~~jbi:lt~~J+~~~l~jfi~~~:~Ui~~~~!~~~~~~tt1j~~~:I:f~i~;i
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COMMONWEALTH OF PENNSYLVANIA)
SS:
OCA:
COUNTY OF CUMBERLAND
)
TO: R. Thomas Kline, Sheriff, or any duly authorized law enforcement officer.
RE: LAWERENCE MARTIN HAKE
2551 Valley Road
Marysville, PA 17053
DOB: 7/09/1957 SEX: M RACE: WHITE
HT: 600 WT: 200 DOCKET #: 00-1072 CIVIL
EYES: BLUE HAIR: GRAY/BROWN SSN: 206/54/3303
FBI: OLN: 19326381 PA SID: 129-98-74-6
OTN:
VIOLATION OF INDIRECT CRIMINAL CONTEMPT
WHEREAS, the above-named defendant allegedly violated his protection from abuse
order on
August 24, 2001, the indirect criminal contempt was
filed by Cpl. Robert L. Pinti of East Pennsboro Township Police Department.
WHEREAS, this Court on
August 28,2001 directed a Arrest
Warrant be issued for the apprehension of the defendant.
This is therefore to command you to arrest the defendant above and bring him/her
before at Carlisle, Pennsylvania, without unnecessary delay to be dealt with according
to law.
WITNESS the undersigned Judge, at Carlisle, this
28th
day of
August, A.D., 2001.
('3/ .T. VVULl!.L\O..o4 at Q:efZ .,,1 P- .
J. Wesley Oler(JJr. J.
PROTH
(SEAL)
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LEZLI JUNE HAKE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of the minor : CUMBERLAND COUNTY, PENNSYL VANIA
children: WILLIAM MARTIN HAKE,
JACQUELYN CAITLIN HAKE, : CIVIL TERM
and AMANDA JAYNE HAKE,
vs. : NO. 2000-1072
LAWRENCE MARTIN HAKE,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
ORDER OF COURT
AND NOW, this E>day of
1~
, 2000, upon consideration of the within
Petition, paragraph 5 of the Final Protection Order entered on March 15, 2000, is modified to
allow Defendant to transfer custody ofthe parties' minor children at Plaintiff's residence or
at any other location the parties mutually agree upon. Defendant shall remain in his vehicle
at all timllS during transfers of custody.
In all other respects the Final Protection Order entered on March 15, 2000, remains in full
force and effect.
By the Court,
/I.
firr
Maryann Murphy, Attorney for Plaintiff
LEGAL SERVICES, INC. C.AJ:U~ -t. L. s.
8 Irvine Row --r---
Carlisle, PA 17013
Jane M. Alexander, Attorney for Defendant
148 South Baltimore Street ~ ~ (..30/ fJ1)
Dillsburg, PA 17019
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LEZLI JUNE RAKE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of the minor : CUMBERLAND COUNTY, PENNSYLVANIA
children: WILLIAM MARTIN RAKE,
JACQUELYN CAITLIN RAKE, : CIVIL TERM
and AMANDA JAYNE RAKE,
vs. : NO. 2000-1072
LAWRENCE MARTIN RAKE,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
PETITION FOR MODIFICATION
OF FINAL PROTECTION ORDER
Plaintiff, Lezli June Hake, by and through her attorney, Maryann Murphy of Legal Services,
Inc., represents the following:
1. Plaintiff filed a Petition for Protection From Abuse and a Temporary Protection From
Abuse Order was entered on February 25, 2000, in the above-captioned action. A Final Protection
Order was entered on March 15, 2000, by agreement of the parties.
2. Plaintiff requests that paragraph 5 ofthe Final Protection Order be modified to allow
Defendant to transfer custody ofthe parties' minor children at Plaintiffs residence or at any other
location mutually agreed upon by the parties. Defendant shall remain in his vehicle at all times
during transfers of custody.
WHEREFORE, Plaintiff requests that paragraph 5 of the Final Protection Order entered on
March 15, 2000, be modified to allow Defendant to transfer custody of the parties' minor children
at Plaintiffs residence or at any other location the parties mutually agree upon. Defendant shall
remain in his vehicle at all times during transfers of custody. In all other respects, the Final
-
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- . ...
Protection Order entered on March 15, 2000, remains in full force and effect.
Respectfully submitted,
~1~,,4n_
Maryann hy, Attorney fo I' .
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.~4904, relating
to unsworn falsification to authorities.
Dated:
Gbg/CJO
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2f~~
LezIi June Rake, Plaintiff
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LEZLI JUNE RAKE, : IN TRE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of the minor : CUMBERLAND COUNTY, PENNSYL VANIA
children: WILLIAM MARTIN RAKE,
JACQUELYN CAITLIN RAKE, : CIVIL TERM
and AMANDA JAYNE HAKE,
vs. : NO. 2000-1072
LAWRENCE MARTIN RAKE,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
FINAL PROTECTION ORDER
Defendant's Name: LAWRENCE MARTIN BAKE
Defendant's Date of Birth: 07/09/1957
Defendant's Social Security Number: 206-54-3303
Names of Protected Persons: LEZLI JUNE BAKE, and the minor children:
WILLIAM MARTIN BAKE
JACQUELYN CAITLIN BAKE
AMANDA JAYNE BAKE
AND NOW, this 15l~ay of March , 2000, the court having jurisdiction over the parties
and the subject-matter, it is ORDERED, ADJUDGED, and DECREED as follows:
Plaintiff, Lezli June Rake, is represented by Joan Carey of Legal Services, Inc.; Defendant,
Lawrence Martin Rake, is represented by Jane M. Alexander, Attorney at Law.
Defendant, although agreeing to the terms of this Order, does not admit the allegations made
in the Petition.
129 Plaintiffs request for a Final Protection Order is granted pursuant to the consent of
Plaintiff and Defendant.
o Plaintiffs request for a Final Protection Order is denied.
129 1. Defendant shall not abuse, stalk, harass, threaten Plaintiff or any other
protected persons in any place where they might be found.
,
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OF ,~LE;9-oI-NCE
. '. TI-,e: P/iOTtfO/lfOfARy
aOHAR 15 AH/f: 53
~fERLAND COU/V7y
r'ENNSY[YANIA
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o 2. Defendant is completely evicted and excluded from the residence at or any
other residence where Plaintiff may live. Exclusive possession of the residence is granted to
Plaintiff. Defendant shall have no right or privilege to enter or be present on the premises.
o On_ at _.m., Defendant may enter the residence to retrieve his/her clothing and
other personal effects, provided that Defendant is in the company of a law enforcement
officer when such retrieval is made.
129 3. Defendant is prohibited from having ANY CONTACT with Plaintiff and/or the
minor children (except as provided in paragraph 5 regarding custody) at any location,
including, but not limited to, any contact at Plaintiffs current residence, and any other
residence she may, in the future, establish for herself, her school, and/or place of employment
or the schools and/or day care facility ofthe minor children. Defendant is specifically ordered
to stay away from the following locations for the duration of this Order:
Plaintiff's current residence: Undisclosed location
Residence ofPlaintifrs Darents: June and Cliff Miller, 6300 Wertzville Road,
Mechanicsburg, Cumberland County, Pennsylvania
Plaintifrs place of emDlovment: Health America (a subsidiary of Coventry
Health Care), 6345 Flank Drive, Suite 100, Harrisburg, Dauphin County,
Pennsylvania
School of the minor children: Shaull Elementary School, 1920 Good Hope
Road, Mechanicsburg, Cumberland County, Pennsylvania
129 4. Defendant shall not contact the Plaintiff or the minor children (except as
provided in paragraph 5 regarding custody) by telephone or by any other means, including
third parties.
129 5. Custody ofthe minor children, William Martin Hake, Jacquelyn Caitlin Hake,
and Amanda Jayne Hake, shall be as follows pending further Order of Court after a
conciliation conference:
Plaintiff shall have primary physical and legal custody of the children.
Defendant shall' have supervised visitation with the children through an
accredited supervised visitation program mutually agreed upon by the parties
through their respective counsel. Defendant shall be responsible for any and all
costs incurred for supervised visitation.
"<-. ~ '~'lrnA~t
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o 6. Defendant shall immediately turn over to the Sheriffs Office, or to local law
enforcement agency for delivery to the Sheriffs Office, the firearms and/or specific weapons used
or threatened to be used by Defendant in an act of abuse against Plaintiff and/or the minor child/ren:
o 7. Defendant is prohibited from possessing, transferring or acquiring any other firearms
and/or specific weapons for the duration of this Order. Any firearms and/or weapons delivered to
the sheriff under Paragraph 6 of this Order or under Paragraph 6 of the Temporary Order shall not
be returned until further Order of Court.
129 8.
The following additional relief is granted as authorized by ~6108 ofthis Act:
Law enforcement agencies, human service agencies and school districts shall not
disclose the presence of Plaintiff and/or address, telephone number, or any
other demographic information about Plaintiff and/or the minor children,
except by further Order of Court.
This Order shall remain in effect until modified or terminated by the Court and
can be extended beyond its original expiration date 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 and/or the minor children.
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 or the minor
children.
o 9. Defendant is directed to pay temporary support for ~ as follows: _' This Order for
support shall remain in effect until a final support order is entered by this Court. However, this
Order shall lapse automatically if Plaintiff does not file a complaint for support with the Court within
fifteen (15) days of the date of this Order. The amount of this temporary order does not necessarily
reflect Defendant's correct support obligation, which shall be determined in accordance with the
guidelines at the support hearing. Any adjustments in the final amount of support shall be credited,
retroactive to this date, to the appropriate party.
o
10.
The costs of this action are waived as to Plaintiff and imposed on Defendant.
o 11. Defendant shall pay L to Plaintiff as compensation for Plaintiffs out-of-pocket losses,
which are as follows: OR
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.
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o Plaintiff is granted leave to present a petition, with appropriate notice to Defendant,
to _ requesting recovery of out-of-pocket losses. The petition shall include an exhibit
itemizing all claimed out-of-pocket losses, copies of all bills and estimates of repair, and an
Order scheduling a hearing. No fee shall be required by the Prothonotary's office for the
filing of this petition.
o 12. BRADY INDICATOR
o 1. The Plaintiff or protected person/s is a spouse, former spouse, a person who
cohabitates or has cohabited with Defendant, a parent of a common child, a child of that
person, or a child of Defendant.
o 2. This Order is being entered after a hearing of which Defendant received actual
notice and had an opportunity to be heard.
o 3. Paragraph 1 of this Order has been checked to restrain Defendant from
harassing, stalking, or threatening Plaintiff or protected person/so
o 4. Defendant represents a credible threat to the physical safety of Plaintiff or
other protected person/sO R
o The terms of this Order prohibit Defendant from using, attempting to use, or
threatening to use physical force against Plaintiff or protected person that would reasonably
be expected to cause bodily injury.
129 13. THIS ORDER SUPERCEDES ANY PRIOR PFAORDER and ANY PRIOR
ORDER RELATING TO CHILD CUSTODY.
129 14. All provisions of this Order shall expire one year from the date this Order is
entered.
NOTICE TO THE DEFENDANT
Violation of this Order may result in your arrest on the charge of Indirect
Criminal Contempt which is punishable by a fine of up to $1,000 and/or a jail
sentence of up to six months. 23 Pa.C.S. 96114. Violation may also subject you
to prosecution and criminal penalties under the Pennsylvania Crimes Code. This
Order is enforceable in all fifty (50) States, the District of Columbia, Tribal Lands,
" Jllk.i
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. -
.
U .S. Territories, and the Commonwealth of Puerto Rico under the Violence Against
Women Act, 18 U.S.C.92265. If you travel outside of the state and intentionally
violate this Order, you may be subject to federal criminal proceedings under that
Act. 18 U.S.C.99 2261-2262. If paragraph 12 of this Order has been checked, you
may be subject to federal prosecution and penalties under the "Brady" provisions
of the Gun Control Act, 18 U.S.C.9922(g), for possession, transport or receipt of
firearms or ammunition.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over Plaintiffs residence OR any location where a violation
of this Order occurs OR where Defendant may be located, shall enforce this Order. An arrest for
violation of Paragraphs 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.g6113.
Subsequent to an arrest, the police officer shall seize all weapons used or threatened to be
used during the violation of the Protection Order or during prior incidents of abuse. The
Cumberland County Sheriff's Department shall maintain possession of the weapons until further
Order ofthis Court. When Defendant is placed under arrest for violation of the Order, Defendant
shall be taken to the appropriate authority or authorities before whom Defendant is to be arraigned.
A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police
officer OR Plaintiff, Plaintiffs presence and signature are not required to file the complaint.
If sufficient grounds for violation of this Order are alleged, Defendant shall be
arraigned,bond set and both parties given notice of the date of the hearing.
w~I:Ik4
This Order is entered pursuant to the consent of Plaintiff and
L~~1;iff
an Carey, Attorney for P
LEGAL SERVICES, IN
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
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LEZLI JUNE RAKE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of the minor : CUMBERLAND COUNTY, PENNSYLVANIA
children: WILLIAM MARTIN RAKE,
JACQUELYN CAITLIN RAKE, : CIVIL TERM
and AMANDA JAYNE RAKE,
vs. : NO. 2000-1072
LAWRENCE MARTIN RAKE,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
CUSTODY ORDER
-tI.
AND NOW, this ~ day of March, 2000, the following Order is entered by consent of the
parties with regard to custody of the parties' children, William Martin Rake, born May 12, 1991,
Jacquelyn Caitlin Rake, born June 11, 1993, and Amanda Jayne Rake, born September 1, 1995,
pending further Order of Court after a conciliation conference:
1. Plaintiff, hereinafter referred to as mother, shall have primary physical and legal
custody of the children.
2. Defendant, hereinafter referred to as father, shall have supervised visitation with the
children through an accredited supervised visitation program mutually agreed upon
by the parties and their respective counsel. Defendant shall be responsible for any and
all costs incurred for supervised visitation.
By the Court,
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The above Custody Order is entered pursuant to the consent of Plaintiff and Defendant:
('
Lezli June Hake,
6an Carey, Attorney fo Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
wrence Martin Hake, Defendant
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06/30/00 FRI 15:38 FAX 717 240 6573
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TRANSMISSION OK
TX/RX NO
CONNECTION TEL
CONNECTION ID
ST. TIME
USAGE T
PGS.
RESULT
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CUMB CO PROTHONOTARY
1i!I001
*********************
*** TX REPORT ***
*********************
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1970
92490779
06/30 15:35
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SHERIFF'S RETURN - REGULAR
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CASE NO: 2000-01072 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HAKE LEZLI JUNE ET AL
VS
HAKE LAWRENCE MARTIN
CPL. TIMOTHY REITZ
, Sheriff or Deputy Sheriff of
Cumberland County, pensylvania, whob~ing duly sworn according to law,
says, the within PROTECTION FROM ABUSE
was served upon
-~. 11
BAKE LAWRENCE MARTIN
the
DEFENDANT
, at 0019:40 HOURS, on the 25th day of February, 2000
at MOUNTAIN VIEW VILLAGE APTS
4181 ELK COURT APT 114
MECHANCI SBURG , PA 17055
by handing to
LAWRENCE M. BAKE
a true and attested copy of PROTECTION FROM ABUSE
together with
& CUSTODY , NOTICE OF HEARING & ORDER,
TEMPORARY FROM ABUSE ORDER
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So
Answ.e~ ~,..,
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18.00
8.68
.00
10.00
.00
36.68
R. Thomas Kline
Sworn and Subscribed to before
me this :J. <I ~ day of
02/28/2000
By: C/~ - ~- ~~~
Deputy Sheriff
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LEZLI JUNE HAKE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
00-1072 CIVIL TERM
LAWRENCE ~TIN HAKE,
Defendant
CHARGE: INDIRECT CRIMINAL
CONTEMPT
IN RE: BAIL
ORDER OF COURT
AND NOW, this 9th day of February, 2001, the
Defendant, Lawrence Martin Hake, now appearing in court
with Public Defender Ellen K. Barry, Esquire, as a result
of the execution of an arrest warrant arising out of an
alleged violation of a Protection from Abuse order, and
counsel for the Commonwealth in the person of Jonathan R.
Birbeck, Esquire, having requested that bail be set at
$1,000.00, and Defendant's counsel having requested that
bail be set at ROR, bail is set in the amount of $1,000.00.
Pursuant to an agreement of counsel in this
case, a special condition of bail shall be that the
Defendant have no contact, direct or indirect, with the
Plaintiff or the parties' children pending the trial.
it
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By the Court,
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Jonathan R. Birbeck, Esquire
Assistant District Attorney
Ellen K. Barry, Esquire
Assistant Public Defender
Probation
Sheriff
Victim Witness
CCP
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LEZLI JUNE HAKE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
00-1072 CIVIL TERM
LAWRENCE MARTIN HAKE,
Defendant
CHARGE: INDIRECT CRIMINAL
CONTEMPT
IN RE: DEFENDANT DIRECTED TO APPEAR FOR TRIAL
ORDER OF COURT
AND NOW, this 9th day of February, 2001, the
Defendant, Lawrence Martin Hake, now appearing in court
with Public Defender Ellen K. Barry, Esquire, at 00-1072
Civil Term, on a charge of Indirect Criminal Contempt, the
Defendant is directed to appear for trial with counsel on
Thursday, February 22, 2001, at 8:30 a.m., in Courtroom
Number 1, Cumberland County Courthouse, Carlisle,
Pennsylvania.
By the Court,
:mae
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Jonathan R. Birbeck, Esquire
Assistant District Attorney
Ellen K. Barry, Esquire
Assistant Public Defender
Probation
CCP
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Sheriff
Victim Witness
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LEZLI JUNE HAKE, : IN THE COURT OP COMMON PLEAS OP
Plaintiff
for herself and on behalf of the minor : CUMBERLAND COUNTY, PENNSYL VANIA
children: WILLIAM MARTIN HAKE,
JACQUELYN CAITLIN HAKE, : CIVIL TERM
and AMANDA JAYNE HAKE,
vs. : NO. 2000-1072
LAWRENCE MARTIN HAKE,
Defendant : PROTECTION PROM ABUSE AND CUSTODY
ORDER FOR CONTINUANCE
AND NOW, this ~J.day of March, 2000, upon consideration ofthe attached Motion for
Continuance, the matter scheduled for hearing on Monday, March 6, 2000, at 8:45 a.m. by this
Court's Order ofPebruary 25,2000, is hereby continued generally.
This Order is entered without prejudice to either party to request a hearing.
The Temporary Protection Prom Abuse Order shall remain in effect pending a hearing in the
matter.
By the Court,
Joan Carey, Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, P A 17013
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Jane M. Alexander, Attorney for Defendant .
148 South Baltimore Street ,/11-~
Dillsburg, PA 17019
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LEZLI JUNE HAKE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of the minor : CUMBERLAND COUNTY, PENNSYL VANIA
children: WILLIAM MARTIN HAKE,
JACQUELYN CAITLIN HAKE, : CIVIL TERM
and AMANDA JAYNE HAKE,
vs. : NO. 2000-1072
LAWRENCE MARTIN HAKE,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
MOTION FOR CONTINUANCE
Plaintiff, Lezli June Hake, by and through her attorney, Joan Carey of Legal Services, Inc.,
moves the Court for an Order continuing generally the hearing in the above-captioned case on the
grounds that:
I. A Temporary Protection From Abuse Order was issued by this Court on
February 25, 2000, scheduling a hearing for March 6, 2000, at 8:45 a.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 at Mountain View Apartments, 4181 Elk Court, Apt. 114, Mechanicsburg, Cumberland
County, Pennsylvania, on February 25, 2000, at 7:40 p.m.
3. Defendant has retained Jane M. Alexander, Attorney at Law, to represent him in the
matter.
4. The parties agree, by and through their respective counsel, that the hearing be
continued generally to facilitate negotiation of a settlement in the matter.
5. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect
WHEREFORE, Plaintiff requests that the Court grant this Motion and continue this matter
..
generally, and that the Temporary Protection From Abuse Order remain in effect pending a hearing
in the matter.
Respectfully submitted,
J an Carey, Attorney for PI
LEGAL SERVICES, IN
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
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COMMONWEALTH OF PENNSYLVANIA
VS-
1.l'l .th.e, C Q,.w;..:t q ~C QJlWJ,q I'J. p;LeA,A.
LaWfLen..c.e MafLt..En l:fal2.e.
Cum6eAiand County, PA
2000-J072 ~
I, Steve. ()[h.1.sthfL, Ve.)9uty SIiVi..i66 tie.,.i:ng duly SWOfLn fig law says tfiat on
2/8/01 tile:. amove: named de.6endant was p.i:c.h.d U)9Eiy Pe.JtfLy County SIie.fLi66
Ve.putie.-s and tali..lln to CCPfiy]] -2a:and J J -J J .
.s lie:fLL6 6 Costs: 2o:m4.-"@,. 3J .,$6..,2.0..
So answe.fLS,
R., Tliomas Kl.i:n.e.
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D.J. NO.
CERTIFICATION OF BAIL
AND DISCHARGE
OTN
COMMONWEALTH VS. (Defendant Name and Address)
LAWRENCE MARTIN HAKE
2551 Valley Road
Marysvi11e PA
D ROR (no surety) D Nominal Bail
Q Bail (total amount set, if any) $ 1 000. 00
D Conditions of Release (aside from appearing af court when required:)
(attach addendum, if necessary)
SECURITY OR SURETY (IF ANY)
[]: Surety Company
o Professional Bondsman
D Realty
D Other
JUDGE OR ISSUING AUTHORITY
J. Wesley 01er. Jr.
APPEARANCE OR BAIL BON D
THIS BOND IS VALID FOR THE ENTIRE PROCEEDINGS AND
UNTIL FULL AND FINAL DISPOSITION OF THE CASE INCLUDING
FINAL DISPOSITION OF ANY PETITION FOR WRIT OF CERTIORARI
OR APPEAL TIMELY FILED IN THE SUPREME COURT OF THE
UNITE,) STATES.
iM1tel~,
POLICE CASE NO
cp, TERM & NO.
00-1072
CHARGE(S):
DATE OF CHARGE(S)
Indirect Criminal Contempt
of a Protection from Abuse
Order
NEXT COURT ACTION
l?2l1'tU'I'E@ 8:30 AM LOCATION Courtroan No. 1
urthous Carlisle PA
TO: ill Detention Center D Other
I hereby certify that sufficient bail has been entered
D By the defendant 0 On behalf of the defendant by:
Vivian 1. Rockey
(Name & Address of Surety) (l.icense No.)
. Refund of cash bail w\\\ be made wIthin 20 days after
final disposition. (Pa.R.Cr.P, 4015(b))
. Refund of all other types of bail will be made promptly after
20 days following final disposition. (Pa.R.Cr.P. 4015(a))
. Bring Cash Bail Receipt to Clerk of Court.
DISCHARGE THE ABOVE-NAMED DEFENDANT FROM CUSTODY IF
DETAINED FOR NO OTHER CAUSE THAN THE ABOVE STATED.
Given under my hand and the Official Seal of this Court,
,~!lOI,
(SEAL)
WE, THE UNDERSIGNED, defendant and surety, our successors, he nd assigns, are jointly and seve
Commonwealth of Pennsylvania the sum of One Thousand and nolloo dollars ($
SEE REVERSE SIDE FORBAIL CONDITIONS
CERTIFICATION OF COUNTER INDEMNITY AND PREMIUM (Applicable Only When Surety Is A Corporation)
, Principal, and
hereby certify that the amount paid by said Principal to said Surety for bail in the above matter is $
and that no further sum or sums is to be paid therefore by the said Principal or anyone on his behalf.
We further certify that said Principal has given to said Surety counter indemnity consisting of
of the value of $
asfoliows:
, Surety,
and no further counter indemnity is to be given the sai{1 Surety except
We further certify that there are no judgments against the said corporate surety outstanding and unpaid for a period of more than thirty days from the date of the entry of such
judgment except those in which CI petition to open or vacate the judgment has been filed and remains undisposed of:
Dated:
,19
MUST BE SIGNED IN PERSON
BY THE APPROVED AGENT
I ACKNOWLEDGE THAT I AM LEGALLY RESPONSIBLE FOR
THE FULL AMOUNT OFTHE BAIL.
The following acknowledgement is also applicable
if Percentage Cash Bail is used.
THIS BOND SIGNED ON
at Carlisle
FebnJarv 15. ~--L-
PENNSYLVANIA,
Signed and acknowledged l?efore me this
15th d,Y of February
,~OOI
(SEAL)
(SEAL)
X
SIGNA
(SEAL)
OF DEFENDANT
_ (SEAL)
Signature of Surety (May be Bondsman, Bail Agency, or private
individual or organization). Except when defendant is released on his
own recognizance (ROR), this must be signed in afl bail situations,
including nominal bail.
ADDRESS OF SURETY. SURETY COMPANY OR DEFENDANT
Surelv No or Professional Bondsman License No. & Expiration Dale
ORIGINAL
. In case of Percentage Cash Bail or Nominal Bail, Power
of Attorney is not required. AOPC414-80
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BAIl,CQNDtTlONS
The CONDITIONS of this bond are thaf the defendant will:
(1) Appear before the issuing authority and in the Courts of the County
of . . , Pennsylvania, at all times.as his
presence may be required, ordereq or directeej, until full and ,final disposition
of the case, to plead, to answer and defend as ordered the ,aforesaid charge'
or charges.
(2) Submit himself to all orders and processes of the issuing authority or
Court.
(3) The DEFENDANT and SURETY must give written notice to the issuing
authority, Cierk of Courts, the District Attorney AND Court Bail Agency,
of any change in his address
within forty-^eight.hours of the date of his change of address.
(4) Comply with any specific requirement at release imposed by the issuing
authority or-Coort, such as a satisfactory participation in a designated
program.
(5) Obey such other conditions as the Court Or Court Bail Agency with leave
of issuing authority or Court, may impose.
If defendant performs the conditions as set forth herein, then this bond is to
be void, otherWIse the same shall remain in full force and this bond in the full
sum thereof shall be forfeited.
And further, in accordance with law, we do hereby empower -any'.attorney Df
any court of record within the Commonwealth of Pennsylvania or elsewhere
to appear for us at any time, and with or without declarations filed, and
whether or not the said obligation be in default, to confess judgment'against
us, and in favor of the Commonweaith of Pennsyivania for use of the aforesaid
County and its assigns, as of any term or session of a court of record of the
aforesaid County for the above sum and costs, with release of all errors,
without stay of execution, and inquisition on and extension upon any levy or
real estate is hereby waived, and condemnation agreed to, and the exemption
of personal property from levy and sale on any execution hereon is also
hereby expressly waived, and no benefit of exemption is claimed under and by
virtue of any exemption law now in force or which may be passed hereafter.
And for so doing this shall be sufficient warrant. A copy of this bond and
warrant being filed in said action, it shall not be necessary to fiie the original
as a warrant of attorney, any law or rule of the Court to the contrary,
notwithstanding
. . . . . . . . . + + . . . . + . + . . . . . . . . .
JUSTIFICATION OF SURETY OTHER THAN CASH BAIL
(Questions 3,4,5,7,8 and 9 are applicable only when real estate is posted as security.) (Cash Bail justification shown on reverse.)
The undersigned about to become Surety in thE; case cited herein, being duly sworn (or affirmed) deposes and says:
1, I reside at my phone No. is
and my occupation is . and I work for
2. I have no undisposed of criminal cases age.lnsl me pending in the Courts of
County, except as foliows:
real estate situated
3,
o (I amfWe are) the sole owner(s) of }
D (I am/We are) joint tenant(s) in
o (I am/We are) tenant(s) by the entirety in
in the said County of
,as follows, viz.: a parcel of ground, in size
.1n!he_Ward,ln!he 0 Bora, 0 Twp, 0 Cityol
, situated at
which is improved with the following buildings
(AIf other joint tenants or tenants by the entirety must co-sign this bond and state their addresses at the bottom of this page or on an attachment
hereto.)
4. The said property was obtained by me by D Deed D Will from
and is recorded in the office of the D Recorder of Deeds
Will BookVoi._Page_, and the title is in D my name
, situated at _
5, The 0 Deed D Will is dafed
of _________County, D Deed D
name. Also a parcei of ground, in size "--
Ward, in the D Bora D Twp D City of
D Wllllram____,___..
D Deed n Will BookYol, ___Page_of
6. I am not Surety on any bond of any kind except as follows'
DATE
, The D Deed D
D Register of Wills
o and my spouse's
in the
. The said property was obtained by me by 0 Deed
Will is dated and is recorded in
County, and is in D my name D and my spouse's name.
AMOUNT
DEFENDANT
7 There are no mortgages, or other liells or encumbrances of any kind or description, upon the said premises, and there are no judgments
against me except as follows:
Mortgages as set forth in the Recorder of Deeds on first property
Mortgages as set forth in the Recorder of Deeds on second property
Judgments and Liens _
Real estate taxes have been paid except: .
8 The assessed valuation of said premises is:
9. No judgment has been entered or action instituted against me upon a forfeited recognizance except
10 I have read carefully the foregoing affidavit and know that it is true and correct.
Sworn (affirmed) and subscribed before me this
day of
19
(Clerk of Courl or Issuing Authority)
IlIII1
.
SEAL
Principal
SEAL
Surety
SEAL
Co-surety, if any, co-joinl len<IfJ1 or co-Ienant by the entirely
SEAL
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LEZLI JUNE RAKE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
INDIRECT CRIMINAL CONTEMPT
LAWRENCE MARTIN RAKE,
Defendant
No. 00-1072 CIVIL TERM
ORDER OF COURT
AND NOW, this 22nd day of February, 2001,
upon consideration of the complaint for indirect criminal
contempt filed in the above-captioned matter, and the
Defendant having appeared for trial without counsel, and
having indicated that he will be attempting to retain
Attorney James Petrascu, Esquire, and having agreed that
the trial in this matter can be held on Monday, February
26, 2001, at 9:30 a.m., and that if he has not retained Mr.
Petrascu as of that date, or Mr. Petrascu is unavailable at
that time, he will proceed with the representation of the
Public Defender, the trial in this case is continued until
Monday, February 26, 2001, at 9:30 a.m., in Courtroom No.
1, Cumberland County Courthouse, Carlisle, Pennsylvania, at
which time the Defendant is directed to appear for trial
without further Order of Court.
Pursuant to an agreement of the parties in
this case, a condition of bail is and shall be that the
Defendant have no contact, direct or indirect, with the
Plaintiff in this case or with the parties' children.
Pursuant to further agreement of the
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parties, a condition of bail shall be that the Defendant
have no contact, direct or indirect, with Dorothy Weaver or
her son, Chase Weaver.
By the Court,
Jonathan R. Birbeck, Esquire
Chief Deputy District Attorney
Victim
Lawrence Martin Hake
2551 Valley Road
Marysville, PA 17053
Defendant
of the Public Defender~~d.-de{j1f.efect ~/t)B/OI-U.)~
Witness -ho..nd.-d.ellve~d ;;}/~J()I -1.JlC.O U
Office
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LEZLI JUNE RAKE,
for herself and on behalf
of the minor children:
WILLIAM MARTIN RAKE,
JACQUELYN CAITLIN RAKE,
AND AMANDA JAYNE RAKE,
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO. 2000-1072 CIVIL TERM
LAWRENCE MARTIN RAKE,
PROTECTION FROM ABUSE
DEFENDANT
IN RE: GUILTY PLEA; SENTENCE
ORDER OF COURT
AND NOW, this 26th day of February, 2001, the
Defendant, Lawrence Martin Hake, now appearing in court for a
nonjury trial on a charge of indirect criminal contempt with his
privately retained counsel, James M. Petrascu, Esquire, and
having tendered a plea of guilty to indirect criminal contempt,
and the Commonwealth, represented by Jamie M. Keating, Esquire,
and the Defendant and his counsel having agreed upon the
sentence imposed in this case of 6 months probation with
supervision, with credit to be given for 7 days previously
served, the defendant's plea of guilty is accepted.
The sentence of the Court, pursuant to the agreement
of counsel and the Defendant, is that the Defendant pay the
costs of prosecution and any fees required under the Protection
from Abuse Act and that he undergo a period of probation with
supervision of 6 months conditioned upon his being and remaining
on good behavior, complying with all written directions of his
probation officer and complying in all respects with the
Protection from Abuse Order heretofore entered.
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By the Court,
Jamie M. Keating, Esquire
Chief Deputy District Attorney
James M. Petrascu, Esquire
Private Counsel for Defendant
Victim Witness
Sheriff
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LEZLI JUNE HAKE,
Plaintiff
for herself and on behalf of the minor
children: WILLIAM MARTIN HAKE,
JACQUELYN CAITLIN HAKE,
and AMANDA JAYNE HAKE,
vs.
LAWRENCE MARTIN HAKE,
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
: CIVIL TERM
: NO. 00-1072
: PROTECTION FROM ABUSE AND CUSTODY
ORDER FOR CONTINUANCE
AND NOW, this /{, (t,day of April, 2001, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on Monday, April 16, 2001, at 3:30 p.m. by this
Court's Order of March 8, 2001, is hereby rescheduled to m/!l)d~ ' 1YJf $ 2001,
at /; 30 -f!-.m. in Courtroom No.1 on the 4th Floor ofthe Cumberland County Courthouse,
I Courthouse Square, Carlisle, Pennsylvania.
The Temporary Protection From Abuse Order shall remain in effect pending a hearing in the
matter.
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Joan Carey, Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
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I\LL I Petrascu, Attorney for Defendant
Maffett & Associates
2201 North Second St.
Harrisburg, PA 17110
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LEZLI JUNE RAKE, : IN TRE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of the minor : CUMBERLAND COUNTY, PENNSYL VANIA
children: WILLIAM MARTIN RAKE,
JACQUELYN CAITLIN RAKE, : CIVIL TERM
and AMANDA JAYNE RAKE,
vs.
LAWRENCE MARTIN RAKE,
Defendant
: NO. 00-1072
"
: PROTECTION FROM ABUSE AND CUSTODY
MOTION FOR CONTINUANCE
Plaintiff, Lezli June Rake, by and through her attorney, Joan Carey of Mid Penn Legal Services,
moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds
that:
I. A Petition for Extension of Protection Order was filed and an Extension of Protection
Order was entered by this Court on March 8, 2001, scheduling a hearing for April 16, 2001,
at 3:30 p.m. in Courtroom No. I.
2. Plaintiff was admitted to the hospital during the week of April 9, 2001. As of April
16, 2000 I, she is still in the hospital, and her doctor will not release her at this time.
3. Counsel for Defendant, James M. Petrascu of Maffett & Associates, has been contacted
as to his concurrence or non concurrence but at the time of the hearing he has not responded.
4. Plaintiff requests a continuance until her doctors release her and she is able to attend a
hearing.
5. Plaintiff requests that the Extension of Protection Order remain in effect for a period of
18 months from the date it was entered, through August 26, 2002, or pending a hearing in the matter.
WHEREFORE, Plaintiff requests that the Court grant this Motion and reschedule the hearing,
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and that the Extension of Protection Order remain in effect for a period of 18 months from the date
it was entered, through August 26, 2002, or pending a hearing in the matter.
Respectfully submitted,
an Carey, Attorney for
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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LEZLI JUNE RAKE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of the minor : CUMBERLAND COUNTY, PENNSYLVANIA
children: WILLIAM MARTIN RAKE,
JACQUELYN CAITLIN RAKE, : CIVIL TERM
and AMAl'IIDA JAYNE RAKE,
vs. : NO. 00-1072
LAWRENCE MARTIN RAKE,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
ACCEPTANCE OF SERVICE
I, JamesM.l~ of Maffett & Associates, do hereby certifY that on Marchl!/., 2001, I
accept~ service of~rtified copies of the Order for Continuance entered on March 8, 2001, and the
Extension for Protection Order entered on February 26,2001, with attached Notice of Hearing
and Petition for Extension of Protection Order in the above-captioned case on behalf of Defendant,
Lawrence Martin Bake, and certifY that I am authorized to do so.
Date:
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es M. Petrascu, Attorney for Defendant
Maffett & Associates
2201 North 2nd Street
Harrisburg, PA 17110
(717) 233-4160
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LEZLI JUNE RAKE,
Plaintiff
for herself and on behalf of the minor
children: WILLIAM MARTIN RAKE,
JACQUELYN CAITLIN RAKE,
and AMANDA JAYNE RAKE,
vs.
LAWRENCE MARTIN RAKE,
Defendant
: In the Court of Common Pleas of
: Cumberland County, Pennsylvania
: Civil Action - Law
: No. 00-1072
: Protection From Abuse and Custody
EXTENSION OF
FINAL PROTECTION ORDER
Defendant's Name: LAWRENCE MARTIN RAKE
Defendant's DOB: 07/09/1957
Defendant's SSN: 206-54-3303
Name of Protected Persons: LEZLI JUNE RAKE
WILLIAM MARTIN RAKE
JACQUELYN CAITLIN RAKE
AMANDA JAYNE RAKE
AND NOW, this ~ itaay of May, 2001, the court having jurisdiction over the parties and the
subject-matter, it is ORDERED, ADruDGED, and DECREED as follows:
Plaintiff, Lezli June Hake, is represented by Joan Carey ofMidPenn Legal Services; Defendant,
Lawrence Martin Hake, is represented by James M. Petrascu of Maffett & Associates.
Defendant, although agreeing to the terms of this Order, does not admit the allegations made in
the Petition. The fact that the Final Protection Order was extended by agreement shall not be used
against Defendant in any proceedings regarding the determination of custody of the minor children.
129 Plaintiff's request for an Extension ofFiI!; Protection Order is granted pursuant
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to the consent of Plaintiff and Defendant;
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129
1.
Defendant shall not abuse, stalk, harass, threaten Plaintiff or any other
protected person in any place where they might be found.
02.
Defendant is completely evicted and excluded from the residence at
or any other
residence where Plaintiff may live. Exclusive possession of the residence is granted to Plaintiff.
Defendant shall have no right or privilege to enter or be present on the premises.
o On _ at _.m., Defendant may enter the residence to retrieve his/her clothing and other
personal effects, provided that Defendant is in the company of a law enforcement officer when such
retrieval is made.
129
3.
Defendant is prohibited from having ANY CONTACT with Plaintiff, Lezli
June Bake, at any location, including, but not limited to, any contact at Plaintiff's current
residence, and any other residence she may, in the fnture, establish for herself, her school,
business, and/or place of employment or the school/s and/or child care facility of the minor
children. Defendant is specifically ordered to stay away from the following locations for the
duration of this Order:
. Plaintiff's residence located at 1101 Lindham Court Apartments, Apt.
101, Mechanicsburg, Pennsylvania, except for the limited nurnose of
transferring custody of the narties' children. and shall remain in his vehicle
at aU times durin!! transfer of custody.
. Plaintiff's place of employment, wherever that may be.
. The school and/or child care facility ofthe parties' minor children unless
otherwise determined pursuant to a Court Order relating to custody.
. The home of Dorothy Anne Weaver at 666 Cumberland Pointe Circle,
Mechanicsburg, P A.
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. Ms. Weaver is Plaintiff's sister, and the temporary caretaker for the
parties' children through a Court-ordered arrangement with Cumberland
Conuty Children & Youth Services. Defendant may come toMs. Weaver's
home for the limited puroose of transferrin!! custody of the oarties'
children. and shall remain in his vehicle at all times durint: transfer of
custody.
129
4.
Defendant shall not contact the Plaintiff, Lezli June Rake, by telephone or
by any other means, including third parties, except Dorothy Weaver regarding issues
concerning the children.
o
5.
Custody of the minor children" shall be as follows: (or see attached Custody
Order) .
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6.
Defendant shall immediately turn over to the Sheriffs Office, or to a local law
enforcement agency for delivery to the Sheriffs Office, the following firearms and/or specific weapons
used or threatened to be used by Defendant in an act of abuse against Plaintiff and/or the minor
child/ren:
07.
Defendant is prohibited from possessing, transferring or acquiring any other firearms
and/or specific weapons for the duration of this Order. Any firearms and/or weapons delivered to
the sheriff under Paragraph 6 of this Order or under Paragraph 6 of the Temporary Order shall not
be returned until further Order of Court.
129
8.
The following additional relief is granted as authorized by ~6108 of this Act:
. Defendant is ordered to refrain from harassing Plaintiff's relatives and/or
the parties' minor children.
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. Defendant is enjoined from damaging or destroying any property owned
solely by Plaintiff.
. This Order shall remain iueffect until modified or terminated by the
Court and can be extended beyond its original expiration date if the Court
fmds that Defendant has committed an act of abuse or has engaged in a
pattern or practice that indicates risk of harm to Plaintiff and/or the minor
children.
o 9.
Defendant is directed to pay temporary support for _ as follows: _' This Order for
support shall remain in effect until a final support order is entered by this Court. However, this Order
shall lapse automatically if Plaintiff does not file a complaint for support with the Court within fifteen
(15) days of the date oftbis Order. The amount of this temporary order does not necessarily reflect
Defendant's correct support obligation, which shall be determined in accordance with the guidelines
at the support hearing. Any adjustments in the final amount of support shall be credited, retroactive
to this date, to the appropriate party.
o 10.
The costs of this action are waived as to Plaintiff and imposed on Defendant.
o 11.
Defendant shall pay $_ to Plaintiff as compensation for Plaintiffs out-of-pocket losses,
which are as follows:
OR
o Plaintiff is granted leave to present a petition, with appropriate notice to Defendant, to
_ 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.
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o 12. BRADY INDICATOR
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1.
The Plaintiff or protected person/s is a spouse, former spouse, a person who
cohabitates or has cohabited with Defendant, a parent of a common child, a child of that person, or
a child of Defendant.
o
2.
This Order is being entered after a hearing of which Defendant received actual
notice and had an opportunity to be heard.
o
3.
Paragraph 1 of this Order has been checked to restrain Defendant from harassing,
stalking, or threatening Plaintiff or protected person/so
o 4.
Defendant represents a credible threat to the physical safety of Plaintiff or other
protected person/s OR
o The terms of this Order prohibit Defendant from using, attempting to use, or threatening
to use physical force against Plaintiff or protected person that would reasonably be expected to cause
bodily injury.
129 13. THIS ORDER SUPERCEDES ANY PRIOR PFA ORDER.
Q9 14. All provisions of this Order shall expire on May 7, 2002.
NOTICE TO THE DEFENDANT
Violation of this Order may result in your arrest on the charge of Indirect Criminal Contempt
which is punishable by a fine of up to $1,000 and/or ajail sentence of up to six months. 23 Pa.C.S.
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~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 the Violence Against Women
Act, 18 U.S. C. ~2265. 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. ijij 2261-2262. Ifparagraph 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.~922(g), for possession, transport or receipt
of firearms or ammunition.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over Plaintiffs residence OR any location where a violation of
this Order occurs OR where Defendant may be located, shall enforce this Order. An arrest for
violation of Paragraphs 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. The Cumberland
County Sheriff's Department shall maintain possession of the weapons until further Order of this
Court. When Defendant is placed under arrest for violation of the Order, Defendant shall be taken
to the appropriate authority or authorities before whom Defendant is to be arraigned. A "Complaint
for Indirect Criminal Contempt" shall then be completed and signed by the police officer OR Plaintiff.
Plaintiffs presence and signature are not required to file the complaint.
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If sufficient grounds for violation of this Order are alleged, Defendant shall be arraigned, bond
set and both parties given notice of the date of the hearing.
This Order is entered pursuant to the consent of Plaintiff and Defendant:
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MidPenn Legal Services
8 Irvine Row, Carlisle, PA 17013
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J s M. Petrascu, Attorney for Defendant
affett & Associates
2201 North 2nd Street, Harrisburg, PA 17110
05/09/01 WED 14:18 FAX 717 240 6573
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CUMB CO PROTHONOTARY
141001
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[ 04]92490779
CENTRAL PROCESS
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OFFlCE OF 'ffiE PROI'HOl'OI'ARY
CUMBERlAND a:x.rNTY lXlURTfKXJSE
CJNE caJRTHCXJ5E :;QUARe
CARLISLE. PA. 17013-3387
(717) 240~6195
FAX (717) 240-6573
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PA STATE POLICE . Ctr,A"" I 1J,,,c.e.ss. ~ /VI.'" A. S.
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FAX ":
717-249-0779
rnrn :
CURTIS R. LONG
RE:
PFA ORDERS
MESSAGE :
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nus ~ is h jlb...w a\J.y fir tte \.se af t:te irdivithll ex altity 1D V\ictl is is .dh::.: : :I. <'I'd net
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CERTIFlCATICN OF PF.A <XNI'EMPl'
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BALANCE DUE: $ //9. <11'
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$ 15.00 $
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$ Y6.j6 $
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STATE SURCHARGE
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SHERIFF COST ($1.50 + ADDTL)
DISTRICT ATTORNEY
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RESTI~TION
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LEZLI J. HAKE,
Plaintiff
IN TRE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
PROTECTION FROM ABUSE
LAWRENCE M. HAKE,
Defendant
No. 00-1072 CIVIL TERM
ORDER OF COURT
AND NOW, this 30th day of August, 2001, the
Defendant, Lawrence Martin Rake, now appearing in court
with the Public Defender, Timothy L. C1awges, Esquire, on a
complaint charging indirect criminal contempt for the
purpose of having bail set and scheduling a trial on the
charge, and for the further purpose of appointing Dirk E.
Berry, Esquire, as Court-Appointed Counsel to represent the
Defendant at the trial, and the Commonwealth in the person
of Jonathan R. Birbeck, Esquire, having indicated that the
Commonwealth would be satisfied with the Defendant's
release on his own recognizance, conditioned upon the usual
terms of bail as well as a special condition that he have
no contact whatsoever with the alleged victim in this case,
Lezli June Rake, and the Defendant having acceded to this
special condition, the Defendant is directed to be released
on his own recognizance, upon his execution of the
appropriate bail documents with the special condition that
he have no contact, direct or indirect, of any kind with
Lezli June Rake pending the trial on the charge of indirect
criminal contempt.
.
FILE[}{)1'F ICE
OF T"'C: r'~")!! i()NOTARY
01 SEP II Pi12:52
CUlvl&..:RlAND COUNlY
PENI\jSYLVANIA
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The Defendant is directed to appear for
trial on the charge of indirect criminal contempt on
Thursday, September 13, 2001, at 11:00 a.m., in Courtroom
No.1, Cumberland County Courthouse, Carlisle,
Pennsylvania.
Dirk E. Berry, Esquire, is appointed to
represent the Defendant in his capacity as conflict
counsel.
By the Court,
J.
Jonathan R. Birbeck, Esquire
Chief Deputy District Attorney
Timothy L. Clawges, Esquire
Assistant Public Defender
Dirk Berry, Esquire
Court-Appointed Counsel
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LEZLI JUNE RAKE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-1072 CIVIL TERM
LAWERENCE MARTIN RAKE,
Defendant
: CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER
AND NOW this _I ~ day of
~(11~
,
, 2001 upon
consideration of within Petition, and all other matters of record, the hearing in the above
captioned matter, scheduled for September 13, 2001 has been continued to .:r I!) _fLm.
the C/-tt, day of ~ ,2001 in Court Room --L of the
Cumberland County Courthouse.
By the Court,
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Jonathan R. Birbeck, c'-,,?
Chief Deputy District Att~rney
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
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Dirk E. Berry, Esquire
7 Irvine Row
Carlisle, PA 17013
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LEZLI JUNE RAKE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-1072 CIViL TERM
LAWERENCE MARTIN RAKE,
Defendant
: CHARGE: INDIRECT CRIMINAL CONTEMPT
REQUEST FOR CONTINUANCE
AND NOW, comes Petitioner/Defendant Lawerence M. Hake by his attorney,
Dirk E. Berry, Esquire, and respectfully avers as follows:
1. Petitioner/Defendant, Lawerence M. Rake is under a Protection from Abuse
Order in the above captioned matter, issued by the Honorable J. Wesley Oler, Jr. and
extended on May 8, 2001.
2. On or about August 24,2001, Plaintiff, in the above captioned matter, alleged
to the East Pennsboro Police Department that Petitioner/Defendant had violated ~bove
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3. On or about August 28,2001, a warrant was issued for the arres~ '
Lawerence M. Hake, by the Honorable J. Wesley Oler, Jr. ~:.. .....l.'.,
4. On or about August 28,2001 this Honorable Court appointed D" . B~,
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Esquire to represent Lawerence M. Hake for the charge of indirect CriminJt;onte~pt.
5. A hearing was scheduled for 11:00 a.m. on Thursday, September 13, 2001.
6. Petitioner's appointed counsel had two previous hearings scheduled outside of
Carlisle for the morning of Thursday, September 13, 2001.
,
WHEREFORE, Petitioner respectfully requests this Honorable Court grant a
continuance to resolve the scheduling conflict with Petitioner's court-appointed counsel.
1-7-01
~?
irk E. Berry, Esquire
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LEZLI JUNE RAKE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-1072 CIVIL TERM
LAWERENCE MARTIN RAKE,
Defendant
: CHARGE: INDIRECT CRIMINAL CONTEMPT
CERTIFICA TE OF SERVICE
I, Dirk E. Berry, Esquire, do hereby certify that on this day Defendant's
Request for Continuance was served by hand delivery upon the following persons:
Jonathan R. Birbeck
Chief Deputy District Attorney
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
Date:
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Dirk E. Berry, Esquire
Attorney for Plaintiff
7 Irvine Row
Carlisle, PA 17013
(717) 240-0296
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LEZLI JUNE RAKE,
Plaintiff
for herself and on behalf
of the minor children:
WILLIAM MARTIN RAKE
JACQUELYN CAITLIN RAKE,
and AMANDA JAYNE RAKE
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2000-1072 CIVIL TERM
LAWRENCE MARTIN RAKE,
Defendant
ORDER OF COURT
AND NOW, this 9th day of October, 2001, the
Defendant, Lawrence Martin Hake, now appearing in court for
sentence with his court-appointed counsel, Dirk E. Berry, Esquire,
and having previously on this date been found guilty of indirect
criminal contempt, the sentence of the Court is that the Defendant
pay the costs of prosecution and any fees required under the
Protection from Abuse Act, and that he undergo a period of
imprisonment in the Cumberland County Prison of 48 hours,
followed by parole as hereafter stated.
Pursuant to the Defendant's request, commencement of
service of the term of imprisonment provided for herein shall be
on Friday, October 12, 2001, at 6:00 p.m., at which time
Defendant shall present himself to the Cumberland County Prison
authorities without further order of Court.
The Defendant shall be automatically paroled at the
expiration of the 48 hours at 6:00 p.m. on October 14, 2001, and
thereafter for a period of 6 months less 2 days the Defendant
shall be on unsupervised parole, upon the condition that he be and
remain on good behavior, comply with any directions of the
Probation Office and have no contact, direct or indirect, with the
Plaintiff in this case, except as permitted by the Protection from
Abuse Order.
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By the Court,
Jonathan R. Birbeck, Esquire
Chief Deputy District Attorney
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Dirk E. Berry, Esquire
For the Defendant
Probation
Sheriff
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LEZLI JUNE HAKE,
Plaintiff
for herself and on.behalf
of the minor children:
WILLIAM MARTIN HARE
JACQUELYN CAITLIN HAKE,
and AMANDA JAYNE HAKE
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 2000-1072 CIVIL TERM
LAWRENCE MARTIN HAKE,
Defendant
ORDER OF COURT
AND NOW, this 9th day of October, 2001, upon
consideration of the complaint for indirect criminal contempt
filed in the above-captioned matter and following a trial, the
court finds the Defendant guilty of indirect criminal contempt.
By the Court,
Jonathan R. Birbeck, Esquir
Chief Deputy District Attorney
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Dirk E. Berry, Esquire
For the Defendant
Probation
Sheriff
CCP
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CERTIFIcm'ICN OF PFA \XNl'EMPl'
ClISE fUIBER ()6 - i in J..
NAME La.W Ht'IC-f MMtlYI (~ctf<t:
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BALANCE DUE: $ 3 [) . be
VICTIM'S NAME:
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ADD DELETE:
170 STATE SURCHARGE
171 STATE FINE
260 SHERIFF COST ($1.50 + ADDTL)
207 DISTRICT ATTORNEY
204 COURT COSTS (CLERK OF COURTS)
502 RESTITUTION
NAME
$ $
$ $
$ $
$ 15.00 $
$ 15.00 $
$ $
ADDRESS
CITY
STATE
ZIP
NAME
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$
ADDRESS
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STATE
ZIP
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$
NAME
ADDRESS
CITY
STATE
ZIP
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LEZLI JUNE RAKE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of the minor : CUMBERLAND COUNTY, PENNSYLVANIA
children: WILLIAM MARTIN RAKE,
JACQUELYN CAITLIN RAKE, : CIVIL TERM
and AMANDA JAYNE RAKE,
vs. :NC>.00-1072
LAWRENCE MARTIN RAKE,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
ORDER FOR CONTmUANCE
AND NOW, this ~ay of March, 2001, upon consideration of the attaehed Motion for
Continuance, the matter scheduled for hearing on Thursday, March 8, 2001, at 8:45 a.m. by this
Court's Order of February 26, 2001, is hereby rescheduled to Monday, April 16, 2001,
at 3:30 p.m. in Courtroom No. 1 on the 4th Floor of the Cumberland County Courthouse,
1 Courthouse Square, Carlisle, Pennsylvania.
The Temporary Protection From Abuse Order shall remain in effect pending a hearing in the
matter.
By the Court,
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Joan Carey, Attorney for Plaintiff
MidPetm Legal Services
8 Irvine Row
Carlisle, PA 17013
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LEZLI JUNE RAKE, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of the minor : CUMBERLAND COUNTY, PENNSYLVANIA
children: WILLIAM MARTIN RAKE,
JACQUELYN CAITLIN RAKE, : CIVIL TERM
and AMANDA JAYNE RAKE,
vs. : NO. 00-1072
LAWRENCE MARTIN RAKE,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
MOTION FOR CONTINUANCE
Plaintiff; Lezli June Rake, by and through her attorney, Joan Carey ofMidPenn Legal Services,
moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds
that:
1. A Petition for Extension of Protection Order was filed and an Extension of Protection
Order was entered by this Court on February 26,2001, scheduling a hearing for March 8, 2001,
at 8:45 a.m. in Courtroom No. 1.
2. Counsel for Defendant, JamesM. Petrascu of Maffett & Associates, told MidPennLegal
Services staff that he would accept service of the Extension of Protection Order and Petition for
Extension of Protection Order on behalf of Defendant. Mr. Petrascu was not able to be served with
a certified copy of the above listed documents prior to the hearing date.
3. Plaintiff requests that the Extension of Protection Order remain in effect for a period of
18 months from the date it was entered, through August 26, 2002, or pending a hearing in the matter.
WHEREFORE, Plaintiff requests that the Court grant this Motion and reschedule the hearing,
and that the Extension of Protection Order remain in effect for a period of 18 months from the date
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it was entered, through August 26, 2002, or pending a hearing in the matter.
Respectfully submitted,
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MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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