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HomeMy WebLinkAbout00-01876 ~ . . PHYLLIS E. WILKE, :IN THE COURT OF COMMON PLEAS Plaintiff :OF CUMBERLAND COUNTY, PENNSYLVANIA VB. :NO. 00 - IP7/p CIVIL TERM RAYMOND HERMAN KISS, Defendant :PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on this matter is scheduled for the 0fuJ? , 2000, at //:OU c:. .m., in the Cumberland County Courthouse, Carlisle, Pennsylvania. 'fUr day of Courtroom No.~ of You MUST obey the Order that is attached until it is modified or terminated by the court after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six months in jail under 23 Pa.C.S. S6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. S2265, this Order is enforceable anywhere in the United States, tribal lands, U.s. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. S2261-2262. 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 GANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELD. IF YOU CANNOT FIND A LAWYER, YOU MAY HAVE TO PROCEED WITHOUT ONE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (711) 249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. ..~",,,,. ".- "-. >,....,. ~. ,..,. '-f,-_ . " ~ . ,~ . :i;I PHYLLIS E. WILKE, Plaintiff. :THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, PENNSYLVANIA vs. :NO. 00- 187~ CIVIL TERM RAYMOND HERMAN KISS Defendant :PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name: RAYMOND H. KISS Defendant's Date of Birth: 01-28-52 Defendant's Social Security Number: 142-44-7284 Name of Protected Person:PHYLLIS E. WILKE AND NOW, this :;(fbA. day of March, 2000, upon consideration of the attached petition for Protection from Abuse, the court hereby enters the following Temporary Order: ~ 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. o 2. Defendant is evicted and excluded from Plaintiff's residence located at , Cumberland County, pennsylvania, (a residence which is jointly owned/leased by the parties; owned/leased by the entireties; owned/leased solely by Plaintiff/Defendant to which Plaintiff and the minor child/ren moved to avoid abuse, which is not owned or leased by the Defendant, 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, except for the limited purpose of transferring custody of the parties' child/ren. Defendant shall remain in his vehicle at all times during the transfer of custody.) ~ 3. E~cept for such contact during the transfer of custody with the minor child, Defendant is prohibited from having ANY CONTACT with Plaintiff at any location, including, but not limited to, any contact at Plaintiff's place of employment ',-, ""-:-.,.,-. -.,."",-, . c ~ H_ ~ 0>- ','C :\; located at Hampden Inn, Harrisburg Pike, Carlisle, Pennsylvania. Defendant is specifically ordered to stay away from the following locations for the duration of this Order, Plaintiff's residence located at 166 West South Street, Carlisle, Cumberland County, Pennsylvania, a residence which is leased solely by plaintiff, and from any other residence Plaintiff may establish, except for the limited purpose of transferring custody of the parties' child. Defendant shall remain in his vehicle at all times during the transfer of custody. ~ 4. Except for such contact regarding the minor child, Defendant shall not contact Plaintiff by telephone or by any other means, including through third persons. o 5. Pending the outcome of the final hearing in this matter. Plaintiff is awarded temporary custody of the following minor child/ren: Until the final hearing, all contact between Defendant and the child/ren shall be limited to the following: The local law enforcement agency in the jurisdiction where the child/ren are located shall ensure that the child/ren are placed in the care and control of Plaintiff in accordance with the terms of this Order. o 6. Defendant shall immediately relinquish the following weapons to the Sheriff'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. ~ 7. The following additional relief is granted: The Cumberland County Sheriff's Department shall attempt to make service at Plaintiff's request and without pre-payment of fees, but service may be accomplished under any applicable Rule of Civil Procedure. This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service. The Prothonotary shall not send a copy of this Order to Defendant by mail. ,. "p.r.,_ . ,. _. -"d'""". . .< 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 another act of abuse or has engaged in a pattern or practice that indicates continued risk of harm to Plaintiff. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. Defendant is to refrain from harassing Plaintiff's relatives. ~ 8. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Carlisle and Middlesex Township Police o 9. THIS ORDER SUPERSEDES 0 ANY PRIOR PFA ORDER AND 0 ANY PRIOR ORDER RELATING TO CHILD CUSTODY 10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months in jail. 23 Pa.C.S. 56114. Consent of 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. 56113. 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. 55 2261~2262. Anv nrotection order qranted by a court may be considered in any subseauent nroceedinqs. includinq child custody nroceedinqs. under title 23 (Domestic Relationsl of the Pennsylvania Consolidated Statutes. '- ~ -,-,p'.--'.'" . -~-:' ~. , "'1 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 of law enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriff'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. J ( Judge BY THE Joan Carey '-f>"""""a\~~OI'dd a/:lI.let> Attorney for Plaintiff FCL~.d", ~<! ~{>sP ~a'8'J()() I / '.' , '~', - - ,"'. ' --".,.". I ,_h ,- _ ~ ., ~ilu' --, ~~'~ ~-- ~liiIi~ii!.'i'~'Il!Mi;~",-IW.ll;l>i1!M\i!ll~ ~~ ",,, """," l:-D~:J;:F;CE CF ?~.,- :-;. ;:,~I:':cn:/\f'iY aD l!kR 28 ,q,-; Q..,o hl; .J" t....... CU~II'lGERL<-.~D COUNTY PENNSYDII\NiA 1'1liJ1iiIiI 4 :~ ;i , :~ , ~' ~! ;~ I !c.i.. 111.1.. ,Ii 'II II I,! r; I;~ Ii r,; i'i, ~I Iii ~I :o.i PHYLLIS E. WILKE, :IN THE COURT OF COMMON PLEAS Plaintiff :OF CUMBERLAND COUNTY, PENNSYLVANIA VS. :NO. 00 - /'11(., CIVIL TERM RAYMOND HERMAN KISS, Defendant :PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE 1. plaintiff's name is Phyllis E. wilke. 2. The name of the person who seeks protection from abuse is Phyllis E. wilke. 3. Plaintiff's address is 166 West South Street, Carlisle, Pennsylvania. 4. Defendant is believed to live at 5 Church Street, Piscataway, New Jersey. Defendant's Social Security Number is 142-44-7284. Defendant's date of birth is 01-28-52. Defendant's place of employment is Delphi, located on Jersey Avenue, New Brunswick, New Jersey. 5. Defendant is father of Plaintiff's child. 6. Defendant has been involved in the following criminal court action: Defendant was sent a citation in January 2000, for harassment by communication. 7. The facts of the most recent incident of abuse are as follows: In or around February 2000, Defendant threatened Plaintiff saying, "I want to slit your throat," causing Plaintiff to fear for her safety. In March, 2000, Defendant called Plaintiff, yelled obscenities at her, and threatened her, exacerbating her fear. '0(- , . -, ~- c_,~ .. ~. _ . -_,0_,,-' e.,-, . 4" .1, '~~-. 8. Defendant has committed the following prior acts of abuse against Plaintiff: a. On or about January 16, 2000, while Plaintiff was in New Jersey (where Defendant ,resides), Defendant called her on her cell phone and threatened to break her legs and do other types of bodily harm to her, causing Plaintiff to fear for her safety. Plaintiff reported this incident to the Piscataway Police who issued Defendant a citation for harassment by communication. b. On or about October 1999, Defendant called Plaintiff on the phone, yelled obscenities at her, and threatened to "break her face." c. In or around June, 1999, Defendant threatened to have someone break Plaintiff's legs. d. In or around May, 1999, Defendant became angry and punched Plaintiff in the head, causing soreness and swelling. Plaintiff contacted the Carlisle Police who ordered Defendant to leave the residence. e. In or around January 1999, Defendant slammed Plaintiff's door several times with such force that the door cracked. Plaintiff, fearing for her safety, grabbed her daughter and ran to her car. Defendant followed her, grabbed her cell phone, threw it onto the cement with such force that it smashed it, kicked Plaintiff's car, and pounded on the windows of her car with his fists. f. In or around May 1998, Defendant drove erratically and dangerously, punched the dashboard, and broke the rearview mirror, frightening Plaintiff who was 7-8 months pregnant, causing her to go into premature labor. Plaintiff was taken to Carlisle Hospital where her contractions were stopped. g. In or around December 1997, Defendant grabbed Plaintiff and threw her down the stairs, causing bruising. 9. 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: Carlisle and Middlesex Township. -- 'yo, ,,_ ,< .(' ~ ~ 10. There is an immediate and present danger of further abuse from the Defendant. 11. Plaintiff is asking the Court to order Defendant to stay away from the residence at 166 West South Street, Carlisle, which is rented by Plaintiff, except for the purpose of transferring custody in which Defendant will remain in his vehicle. WHEREFORE, PLAINTIFF REQUESTS THAT THE COURT ENTER A TEMPORARY ORDER, AND AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: A. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff in any place where Plaintiff may be found. B. Order Defendant to stay away from Plaintiff's residence located at 166 West South Street, Carlisle, and prohibit Defendant from attempting to enter any temporary or permanent residence of Plaintiff, except for the purpose of transferring custody in which Defendant will remain in his vehicle. C. Prohibit Defendant from having any contact with Plaintiff, either in person, by telephone, or in writing, personally or through third persons, including, but not limited to any contact at Plaintiff's school, business, or place of employment, except as the Court may find necessary with respect to partial custody with the minor child. D. Prohibit Defendant from having any contact with Plaintiff's relatives. E. Order Defendant to pay the costs of this action, including filing fees, service fees, and surcharge of $25.00. F. Order Defendant to pay $250.00 to reimburse one of Legal Services, Inc.'s funding sources for the cost of litigation in this case. G. Order the following additional relief, not listed above: a.Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. ~ ~.. ." -.~. . b. Defendant is to refrain from harassing Plaintiff's relatives. H. Grant such other relief as the court deems appropriate. order the police or other law enforcement agency to serve Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. Plaintiff will inform the designated authority of any addresses, other than Defendant's residence, where Defendant can be served. Plaintiff prays for such other relief as may be just and proper. Respectfully submitted, Dated: S/c20 h-o / / ~ . ~y / Attorney for Plaintiff LEGAL SERVICES, INC. a Irvine Row Carlisle, PA 17013 (717) 243-9400 ,,,... ~. 'n _,~. _ 0" ",_,~_,_,~, 'v. .-" ,..'~" ,,,,,= " ," I. ~- " V" c " I . VERIFICATION I verify that I am the Plaintiff as designated in the present action and that the facts and statements contained in the above petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. Dated: J /at; / (f1) I f Phyllis - -. ,---~---~ - ~. ,".L'_' II I' ii ! r I L~ rl fl 'I !I tl I.'.l.' r;j Iii l:1 Ii ,1 'I, I 1:1 Li ^_~ . .... ..ft".~,,"". . ~ ~~, - ~" ~~l'!rll!!l' "~"~ ..w_ .1 Cl c:-} <:) f_-~ \~;) '-n ~ t{: :7r: ef' :T~ ..-,..., i ~ 6~ ,-' :~,J ,.,~ <:,' ():..1 - 0 .- ~f ~J :t'-!'!'O e', ,'''', "-n (~j -~. '_J c"-') ~:.::: )> ,~ CO c; in Z "'~ c-'1 ",::,. -.-.j ~lJ -< (l:) ~; , V' "" 'I-' "" <t . ,. !"_~~'W~~ff<~!l:Voqr~llllft'~~~!Mli~___":C~_;_ ~i1'lf[.tll11l If--- , ", PHYLLIS E. WILKE, Plaintiff :IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, PENNSYLVANIA vs. :NO.2000 - 1876 CIVIL TERM RAYMOND HERMAN KISS, Defendant :PROTECTION FROM ABUSE FINAL ORDER OF COURT Defendant's Name: RAYMOND HERMAN KISS Defendant's Date of Birth: 01-28-52 Defendant's Social Security Number: 142-44-7284 Names of Protected Person: PHYLLIS E. WILKE AND NOW, this IS-~ day of S1~ , 2000, the court having jurisdiction over the parties and the subject- matter, it is ORDERED, ADJUDGED, and DECREED as follows: Plaintiff is represented by Joan Carey of LEGAL SERVICES, INC.; Defendant is represented by Jacqueline Verney, Attorney-at-Law. The parties agree that the following may be entered as an Order of Court. Defendant, although agreeing that an Order may be entered, does not admit to the allegation made in the Petition. D Plaintiff's request for a Final Protection Order is denied OR ~Plaintiff's request for a Final Protection Order is granted. ~ 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 * [NONCONFIDENTIAL ADDRESS FROM WHICH DEFENDANT IS EXCLUDED] or any other residence where Plaintiff may live. Exclusive possession of the residence is granted to Plaintiff. -~ . -- ,.""- -'-,C_"_-' ".' ,-,- = 4 , , ~ Defendant shall have no right or privilege to enter or be present on the premises. D On [Insert date and time], Defendant may enter the residence to retrieve his/her clothing and other personal effects, provided that Defendant is in the company of a law enforcement officer when such retrieval is made. ~ 3. EXCEPT for contact expected during the transfer of custody of the minor child pursuant to the parties' custody arrangement (including, but not limited to, the parties exchanging information about the child's physical and emotional well-being and her feeding and nap schedule), Defendant is prohibited from having ANY CONTACT with Plaintiff at any location, including, but not limited to, any contact at Plaintiff's place of employment or residence. ~ 4. EXCEPT for contact necessary and expected regarding the minor child or phone calls with the minor child from the mother or calls from the father to the mother regarding the child's wel1-being(including, but not limited to, keeping the mother aware of current medical information, medications, the child's feeding and nap schedule and general well-being), Defendant shall not contact Plaintiff by telephone or by any other means, including through third parties. D 5. Custody of the minor children, [names of the children subject to the provision of this paragraph] shall be as follows: [state to whom primary physical custody awarded; state terms of partial custody or visitation, if any] (or see attached Custody Order) D 6. Defendant shall immediately turn over to the Sheriff's Office, or to a local law enforcement agency for delivery to the Sheriff's Office, the following weapons used or threatened to be used by Defendant in an act of abuse against Plaintiff and/or the minor child/ren: D 7. Defendant is prohibited from possessing, transferring or acquiring any other weapons for the duration of this Order. Any weapons delivered to the sheriff under Paragraph 6 of this Order "-- _'fJi' . ,.',,' . "'- . ., " ~" ,~ -'-'. i~"'''"''''''';;'""',.j '~'~"'iildIli~6<'-~ ^.,,;;j.-.- "i.lllff~\IlI~'-- 1is!itS!i-.mlJi!<~.t!~~~l:ir "- ~-' F:LSI}.Ct';:\Cr: C~ ,~-oT.t'FN [}O JU;l \ 6 [,,(Ii 8: \ 8 C' ",C)~Q' i,"," iY,'J\!lV '\.; lV".~....j ".-' ".:,... -'...... I \; I P..",.,~\"'r,..I'" Cl'-l,VjIL'lt\i\llh [I 11....- ....- ~ ."~~.... ." , , I r , , I I I I t , , i , i 1:0.. L: :.j ,,! ;" rj ~ ! ~ ~ I , ! I t ! .' ~ " , or under Paragraph 6 of the Temporary Order shall not be returned until further Order of Court. ~ 8. The following additional relief is granted as authorized by ~6108 of this Act: a. 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 another act of abuse or has engaged in a pattern or practice that indicates continued risk of harm to Plaintiff. b. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. c. Defendant is to refrain from harassing Plaintiff's relatives. d. The court costs and fees are waived. D 9. Defendant is directed to pay temporary support for [insert the names of the persons for whom support is to be paid] as follows: [insert amount, frequency and other terms and conditions of the support order] This Order for support shall remain in effect until a final support order is entered by this Court. However, this Order shall lapse automatically if Plaintiff does not file a complaint for support with the Court within fifteen 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 of this action are waived as to Plaintiff and imposed on Defendant. D 11. Defendant shall pay $* to Plaintiff as compensation for Plaintiff's out-of-pocket losses, which are as follows: OR -'~', --p.,:-, -,.,~- :_~, _c .' v' - -",.,. ,-,-r o Plaintiff is granted leave to present a petition, with appropriate notice to Defendant, to [insert the name of the judge or court to which the petition should be presented] requesting recovery of out-of-pocket losses. The petition shall include an exhibit itemizing all claimed out-of-pocket losses, copies of all bills and estimates of repair, and an Order scheduling a hearing. No fee shall be required by the Prothonotary's office for the filing of this petition. o 12. BRADY INDICATOR 1.0 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. 2.0 This Order is being entered after a hearing of which Defendant received actual notice and had an opportunity to be heard. 3.0 Paragraph 1 of this Order has been checked to restrain Defendant from harassing, stalking, or threatening Plaintiff or protected person(s) . 4.0 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 ~hat would reasonably be expected to cause bodily injury. ~ 13. THIS ORDER SUPERCEDES ~ ANY PRIOR PFA ORDER AND 0 ANY PRIOR ORDER RELATING TO CHILD CUSTODY. 14. All provisions of this Order shall expire on November 10, 2000. - ',.- -,,"-.' - '. ,y",~ . ".<-"" ."_u l1I t " " NOTICE TO 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. 56114. 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. TER~ITORIES, AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACTION, 18 U.S.C. ~2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEPERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C. 5~ 2261-2262. IF PARAGRAPH 12 OF THIS ORDER HAS BEEN CHECKED, YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACTION, 18 U.S.C. 5922(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 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. 56113. 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 incid...nts of abuse. The [insert the appropriate name or title] 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. . ~ ., " '",.-',,- ,<'~ c ~ -. " .-. 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, 14- If entered pursuant to the consent of Plaintiff and Defendant: kl.4 ~~~l:r-:; ac eline M. Verney Attorney for Defendant Law Office of Jacqueline Verney 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 Phylli E. Wilke, ,?laintiff ~a~ Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 t; J;o PS P l-//"OO RKS " - , .~ __F__ c., . ','_ ." ~ _"._> ,n',.-,_., q ~ '-'", 4- 0 >--... B 1.-, -$ 0 2- c-6 c :::f <;:, ._, '0 I,.. \~ Q,..... ( ~ \1. .jl Ii , -i: ii :11 jl II i' i' 1'! i-I d 'I , , " -,,",, . J. .. ~-..- '. '", ,_~~n'~'~~'l\'Il~~~~~ ~ ~""".,.IlI!'!li , ~,J~! " 11109/00 . THU..16: 37 FAX 717 240 6573 CUMS CO PROTHONOTARY ~ . 141001 . *******$*****~************* *** MULTI TN REPORT *** *************************** TXlRX NO INCOMPLETE TX/RX TRANSACTION OK 2274 0119p2405331 0319p2438026 04192490779 CENTRAL PROCESS LEGAL SERVICES PSP ERROR omCE OF THE PRarHCN:1rARY CUMBERLAND COONTY COUR'IHOOSE ONE COORTIiCOSE SQUl\IlE CARLISLE, PA. 17013-3387 (717) 240-6195 fAX (717) 240-6573 v I ATE L E COP I E R TO: PA STATE POLICE , -, FAX #: 717-249-0779 FROM: CURTIS R. LONG RE: PfA ORDERS MESSAGE : 1. Jf L 00. OF PAGES (INCLUDING COVER SHEET) This - ~. is iJ,teLhl ally for: t:te lEe of tie iniiviClel cr a"lti~ to I'trid"I is is n H,~ j, a"d ITB/ anUtin infurJratim ttet is JXivileg3:i, anf.idential arllNlTpt furo d;'7'l"" 1m url::r "!X'H........1" IaN. rf ttE ~ of this ~ is rot tl~ intalkl re::ipiatt. :pi Clre ~ rotifiEd tTat a"\Y disoemiretim. dis!r:il:llt:ia cr o:win;j of this cDlnu'Licat5m i8 strictly {ZChibi.tB:l. If ~ tm.e rea;:iw;! tiuB --,- ~,~ ,~........-- n1""""" .......;Fv '''' _H"""]v hr I1"Jan:rB arll:ehJm tie ar::il:l:irl!ll n -"9'1 to l,S at '". PHYLLIS E. WILKE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-1876 CIVIL TERM RAYMOND H. KISS, Defendant : PROTECTION FROM ABUSE EXTENSION OF PROTECTION ORDER Defendant's Name: RAYMOND HERMAN KISS Defendant's Date of Birth: 01/28/1952 Defendant's Social Security Number: 142-44-7284 Name of Protected Person: PHYLLIS E. WILKE AND NOW. this 9!f;u.y of November, 2000. upon presentation and consideration of the attached Petition for Extension ofProtectioD Order. the court hereby enters the following Order is entered: This Court's Final Order of Court entered on June 15, 2000, shall be extended beyond the expiration date of November 10, 2000, such that it remains in full force and effect for 18 months, through May 9, 2002, or until further Order of Court. Defendant is hereby notified that violation of.s 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 himlherto 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 T' . 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. A bearing shaD be herd ~ matter on tbe 1 bY day of November. 2000, at 110 /f.m. in Courtroom ~~ 4th Floor of the Cumberland County Courthouse. Carlisle. Pemlsylvania. 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 this Order (see attached Exhibit A), Defendant may be arrested on the charge ofIndirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence oflaw enfor{;ement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order or during prior incidents of abuse, Weapons must forthwith be delivered to the Sherifl's office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this Court, unless the weaponls are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. Distribution to: Joan Carey, Attorney for Plaintiff LEGAL SERVICES, INe. Jacqueline Verney, Attorney for Defendant FAXed and tmilled to PSP PHYllJS E, WILKE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO, 00-1876 CIVIL TERM RAYMOND H. KISS, Defendant : PROTECTION FROM ABUSE PETITION FOR EXTENSION OF PROTECTION ORDER 23 Pa.C.S. ~6108(e) Plaintiff, Phyllis E. Wilke, by and through her attorney, Joan Carey ofLegal Services, Inc., states the following: I, PlaintifffiIed at Petition for ProtectionFrom Abuse and a Temporary Protection Order was entered on March 28, 2000. By agreement of the parties and their respective counsel, a Final Order of Court was entered on June 15, 2000, fora term of 6 months, through November 10, 2000. See attached Exhibit A, incorporated herein by reference. 2. Plaintiffrequests anExtension of the Final Protection Order forreasonsincluding, but not limited to the following: a. From approximately October 21 through October 23, 2000, Defendant telephoned Plaintiff's residence and left three messages on her answering machine yelling at her. Plaintiff reported the calls to the police. a. On or about October 17, 2000, during a custody conciliation conference before Dawn Sunday, Defendant became angry, pointed his finger at Plaintiff and yelled across the table at Plaintiff and her attorney, and left the conference, causing Plaintiff to fear for her safety. .- . ~ wHEREFORE, Plaintiff asks that the Final Order of Court entered on June 15, 2000, be extended beyond the expiration date of November 9, 2000, such that it remains in full force and effect for t 8 months, through May 9, 2002, or until further Order of Court. Respectfully submitted, i 7J.....1,.<J Joan Carey, Attorne)lj or Plaintiff LEGAL SERVICES, INe. 8 Irvine Row Carlisle, PA 17013 (717) 243,9400 -~ - ~,- , VERIFICATION I, Ian Terpening, Paralegal, Legal Services, Inc., verifY that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. The information is based on several conversations with Petitioner, Phyllis E. Wilke. This verification is made pursuant to Rule 1024 (c)(2) of the Pennsylvania Rules of Court (state) since Petitioner is out of Cumberland County and her verification cannot be obtained in a timely manner. I understand that any false statements are made subject to the penalties of 1 g Pa.C.S. ~4904, relating to unsworn falsification to authorities. Dated: 11/9/tJ6 I I Ian Terpening, Para! LEGAL SERVICES, 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 , " ',-. ~" JUN f 4: 200iJP PHYLLIS E. WILKE, plaintiff :IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, PENNSYLVANIA vs. :NO.2ooo - 1876 CIVIL TERM RAYMOND HERMAN KISS, Defendant :PROTECTION FROM ABUSE FINAL ORDER OF COURT Defendant 1 S Name: R..~'l!)IOND, HER~IAN KI$S Defendant's Date of Birth: 01-28-52 Defendant's Social Security Number: 142-44-7284 Names of Protected AND NOW, this Jj day of , 2000, court having jurisdiction over the parties and the subject- matter, it is ORDERED, ADJUDGED, and DECREED as follows: the PlliLintiff is represented by Joan Carey of LEGAL SERVICES, INC.; .,.." Defendant is represented by Jacqueline Verney, Attorney-at-Law. The parties agree that the following may be entered as an Order of Court. Defendant, although agreeing that an Order may be entered, does not admit to the allegation made in the Petition. o Plaintiff's request for a Final Protection Order is denied OR ~Plaintiff's request for a Final Protection Order is granted. ~ 1. Defendant shal1 not abuse, stalk, harass, threaten Plaintiff or any other protected person in any place where they might be found. o 2. Defendant is completely evicted and excluded from the residence at * [NONCONFIDENTIAL ADDRESS FROM WHICH DEFENDANT IS EXCLUDED] or any other residence where Plaintiff may live. Exclusive possession of the residence is granted to Plaintiff., , ,"'~ ','''- EXHIBIT A 7~~ "' ~ < . " _.~ ". - , ~ ~ Defendant shall have no right,or privilege to enter or be present on the premises. o On [Insert date and time], Defendant may enter the residence to retrieve his/her clothing and other personal effects, provided that Defendant is in the company of a law enforcement officer when such retrieval is made. ~ 3. EXCEPT for contact expected during the transfer of custody of the minor child pursuant to the parties' custody arrangement (including, but not limited to, the parties exchanging information about the child's physical and emotional well-being and her feeding and nap schedule), Defendant is prohibited from having ANY CONTACT with Plaintiff at any location, including, but not limited to, any contact at Plaintiff's place of employment or residence. ~ 4. EXCEPT for contact necessary and expected regarding the minor child or phone calls with the minor child from the mother or calIs from the father to the mother regarding the child's well-being(including, but not limited to, keeping the mother aware of current medical information, medications, the child's feeding and nap schedule and general well-being), Defendant shall not contact Plaintiff by telephone or by any other means, including through third parties. o 5. Custody of the minor children, [names of the children subject to the provision of this paragraph] shall be as follows: [state to whom primary physical custody awarded; state terms of partial custody or visitation, if any] (or see attached Custody Order) o 6. Defendant shall immediately turn over to the Sheriff's Office, or to a local law enforcement agency for delivery to the Sheriff's Office, the following weapons used or threatened to be used by Defendant in an act of abuse against Plaintiff and/or the minor child/ren: o 7. Defendant is prohibitectfrom possessing, transferring or acquiring any other weapons for the duration of this Order. Any weapons delivered to the sheriff under Paragraph 6 of this Order ~ or under Paragraph 6 of the Temporary Order shall not be returned until further Order of Court. ~ 8. The following additional relief is granted as authorized by ~6108 of this Act: a. 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 another act of abuse or has engaged in a pattern or practice that indicates continued risk of harm to Plaintiff. b. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. c. Defendant is to refrain from harassing Plaintiff's relatives. d. The court costs and fees are waived. D 9. Defendant is directed to pay temporary support for [insert the names of the persons for whom support is to be paid] as follows: [insert amount, frequency and other terms and conditions of the support order] This Order for support ,shall remain in effect until a final support order is entered by this Court. However, this Order shall lapse automatically if Plaintiff does not file a complaint for support with the Court within fifteen days of_the date of this Order. The amount of this ~emporary order does not necessarily reflect Defendant's correct support obligation, which shall be determined in accordance with the gu.idelL.\es 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 of this action are waived as toPlaintiff and imposed on Defendant. D 11. Defendant shall pay $* to Plaintiff as-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 [insert the name of the judge or court to which the petition should be presented] requesting recovery of out-of-pocket losses. The petition shall include an exhibit itemizing all claimed out-of-pocket losses, copies of all bills and estimates of repair, and an Order scheduling a hearing. No fee shall be required by the Prothonotary's office for the filing of this petition. o 12. BRADY INDICATOR 1.0 PlaintifI or proEected person(s) is a spouse, former spouse, a person-who cohabitates or has cohabited with Def~ndant, a parent of a common child, a child of that person, or a child of Defendant. 2.0 This Order is being entered after a hearing of which Defendant received actual notice and had an opportunity to be heard. 3.0 Paragraph 1 of this Order has been checked to restrain Defendant from harassing, stalking, or threatening Plaintiff or protected person(s) . 4.0 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 AND 0 ANY PRIOR ORDER RELATING TO CHILD CUSTODY. 14. All provisions of this Order shal1 expire on November 10, 2000. ~ " .. ' NOTICE TO 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. ~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 ACTION, 18 U.S.C. ~22 65. IF YOU TlUl...VEL OUTSIDE OF.' rHE STATE Mm I:NTENTICN1..L:r..y VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C. ~~ 2261-2262. IF PARAGRAPH 12 OF THIS ORDER HAS BEEN CHECKED, YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACTION, 18 U.S.C. ~922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION. NOTICE TO LAW ENFORCEMENT OFFICIALS The poI ice 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 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 poI ice officer shall seize all weapons used or threatened to be used during the violation of the Protection Order or during prior incid~nte of abuse. The [insert the appropriate name or title] 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" shal1 then be completed and signed by the poI ice 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, 1.., IS/~ d :Ji.o,,) .rll Edga B. Bayley, Judge If entered pursuant to the consent of Plaintiff and Defendant: Ph~kt::!,6 )~;Ja?cvU-&1'/ ()Joan Carey tI Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ~,c// " 0 ' i )n,~ f.. , ''1k1 ' f0 . 'f'VY) Ra~ d' ~.tKi~s, D~fendant I <<,.~.,.~.~ ,,^, !/jL,._~~/ ,'a,c~eline M. Verney ,# Attorney for Defendant Law Office of Jacqueline Verney 44 South Hanover Street Carlisle, PA 17013 (717) 243-9190 T'''J'' C('l~v r,rfl~' "ECO"D if,':' \L lh ,,,,,'... .; I! \1 u\ ""'~' i"1!f\ i\ .. In Testimony v;k',"GOf, j h~~re to set my hJnd andihe seal of .521(' Court at rlisle, Pa. ~jt", ~~J:;,' '" m.u, ftjO . ~J.2.aU.L. .,.~.u...I...~IJ)./)~ L , I' '- Prothc;~~;~~ .-,,~<~~ ". ~ ~" .. '~T~~~__~~~' _ , -,. ~.~~~. ~---~ '"". ;ff i r' ~ r ~& ""~ --.l - .,,, C",'.. . ~'=rr" .",~~Il'$!!I" ,...,~ " ~'- -'i. ~_--- """r () I::) :~ c L,,) i.Y .,,- 1"'1"] ,.~-~) f1'; \,::;: ;n ;S ~n Us r"- 'T~ :>> tr, ;:? -< ~, ,".. C)- r::.;. C -"'-'J -n ,- c::: =;; !~ ~n Z CJ C) 5 c r:- ~ rTt Z ~ :::::> ~ :;:t :0:) .j,.- -< ,,'~~ """",,,,.~tffll~!~;,I'lJ1"'~f'~J",Yij'~;"'tN-Ifi!,lJ!!1jm,"~iiW"~;#~~ll&l!Ii!il!!lll__!IIli~~~1~I 06/16/00 FRI 09:14 FAX 717 240 6573 CUMB CO PROTHONOTARY 141 001 1 ,.;---.. TRANSMISSION OK TX/RX NO CONNECTION TEL CONNECTION ID ST. TIME USAGE T PGS. RESULT ***~****~************ **.*, T~ REPORT *** ********************* 1931 92490779 06/16 09:09 05'42 8 OK " ~., .. . . PHYLLIS E. WILKE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-1876 CIVIL TERM RAYMOND HERMAN KISS, Defendant : PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, this \t I-- day of April, 2000, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on April 4, 2000, at II :00 a.m. by this Court's Order of March 28, 2000, is hereby rescheduled for hearing on April 17 , 2000, at II :00 a .m. in Courtroom No, 2, The Temporary Protection From Abuse Order shan remain in effect for a period of one year from the date it was entered or until further Order of Court, whichever comes first. Joan Carey LEGAL SERVICES, INC. Attorney for Plaintiff ) By the Court;- ,/ / o ~ ;.~ ~t;t){:J \J'{ ~ ," , .' .~. < ., - "..r. . - ~~ , - ;' . .. II I ~' " EI II ~I rl ~' Iii Ii n t! i,i ~ [I f:i 1;1 ',- '. " 11 \!/NVp "lJ.lW)o'J a~i~~/~%! 6 (, .', . <cl::ilfinO c,.c /,ld 1", . i~ ,_ ) l-cdifOO ) I_l~ /1 f'-" ~\Q~ . r .. ,',' "2')i1JCi~'~S7D , ,I" .'v ,-f"""''''' '.. " ,- ~f ,-". p- " , . -~"~ ." -~II;l!lMlm~-~!lIii!lti'.l~rJmiilfflilllllilli.lil\l~IIRItl~ -"Ii . -,.....,!. II'Itl~J~I~ PHYLLIS E. WILKE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-1876 CIVIL TERM RAYMOND HERMAN KISS, Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE The Plaintiff, Phyllis Wilke, by and through her attorney, Joan Carey of Legal Services, Inc., moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: I. A Temporary Protection From Abuse Order was issued by this Court on March 28, 2000, scheduling a hearing for April 4, 2000, at 11 :00 a.m. 2, The Middlesex County (New Jersey) Sheriff's Department received the Temporary Protection Order in the mail today, April 3, 2000, and have asked for additional time in order to serve the defendant and give notice of the hearing. 3. The plaintiff agrees, by and through her respective counsel, that the hearing be --- rescheduled pending further Order in this matter. 4. The Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of one year from the date it was entered or until further Order of Court, whichever comes first. WHEREFORE, the Plaintiff requests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in effect for a 1.T ,","Co,. ". '. . , , . period of one year from the date it was entered or until further Order of Court, whichever comes first. Respectfully submitted, Joan Carey, Attorney fi Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ~,- . -"- - ,,,. ~, ,-- q' ,'~ ".~" ',. , - ~ ;, , r >- 0:: <:.( I- e tu ~;-~5 ~~j: ~-:- '-...-.' ~.- 6(- Li.l: u:l.: i" 1; 'I " " :i ii ,'I II " i \-1 ,I ,'I " '-I l_i H : ~ 1 I . . . ?\ "" '- E::; ,""- ;::, ;::J~ ~~i~ ~ :';7'(0 {~~ ;j)~ ,,,: ::s o ~ LCo ..::J' I c;r CI.-.- .....: o C) '," . -~ .,...~[-~ ,-", ~~-~-1 " " ~~, ~" ~~_,"",,~!~iIliflf!\lili!~fi~~--17S'1If"'lijg_~.~ ~~.UJjlll'~ ... . . ., . PHYLLIS E. WILKE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO. 00-1876 CIVIL TERM RAYMOND HERMAN KISS, Defendant : PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, this l cr day of April, 2000, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on April 17, 2000, by this Court's Order of April 4, 2000, is hereby rescheduled for hearing on May 15, 2000, at 10:30 a.m. in Courtroom No.2. The Temporary Protection From Abuse Order shall remain in effect for a period of one year from the date it was entered or until further Order of Court, whichever comes first, / ~ rruJJ if /7-00 Rr.s Joan Carey LEGAL SERVICES, INC. Attorney for Plaintiff Jacqueline Verney Attorney for Defendant I';'" - .-~ >7,-,',' ,-~ . ,"--- -: ,.. r .. :1 !~ i~ ~ :i ;i,',I' l~ " 1\1 ill ~:!! !:'\ i'i I~i 1):1 !~l ill i,I" I) b' :'" V\f-\\fj\lASNNjd ..., -~ ~." ,. ,--' '-'1(," In'"' I, ',r,!n.)' 1 (:'\:h :>"1"'.",1.''., J 1\.-'-,;:1 I'" '_.-' n' - ,,"'~'"-''' " ',', ',,".J' ')'; ~J .(. 61 00 }.}iV1:~"i ._"""" ~T .c"..L , ,~' ,. . . ,!mlT:-U1 _,",~~~~;;Il~~~. _I~ , . , . , ""--' , PHYLLIS E. WILKE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : NO. 00-1876 CIVIL TERM RAYMOND HERMAN KISS, Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE The Plaintiff, Phyllis Wilke, by and through her attorney, Joan Carey of Legal Services, Inc., moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. A Temporary Protection From Abuse Order was issued by this Court on March 28, 2000, scheduling a hearing for April 4, 2000, at II :00 a.m. 2. On April 4, 2000, an Order for Continuance was entered, rescheduling the hearing for April 17, 2000, at II :00 a.m. because service had not yet been effected. 3. On April 14, 2000, Defendant was served by the Middlesex County Sheriff's Department in New Jersey. 4. On April 14, 2000, Defendant's attorney, Jacqueline Verney, contacted Legal Services, Inc. to request a continuance, 5. The parties agree, by and through their respective counsel, that the hearing be rescheduled pending further Order in this matter, I' - ~,>, ., ,~ ,. , -,,-~, -. '-__J .' ~ . ~'I '. ~ 5. The Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of one year from the date it was entered or until further Order of Court, whichever comes first. WHEREFORE, the Plaintiff requests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in effect for a period of one year from the date it was entered or until further Order of Court, whichever comes first. RespectfuJly submitted, , t o Joan Car , Attorney for Plainti Maryann Martin LEGAL SERVICES, INC. 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 - ,- ~ ,- - ,-- .. , - , -- I I , I I I f- il i:! i', Ii 1.1 :1 :1 !i i'l :1 'I :,:l I:,) "J 1-,' !:~ ,-,. ~"' ~. ,~~ - ~,. ." ~ o ~, ~Ili c ,..-'-. ''';':1 :-,) ",,:~- ~-~ ~ ,:.;,{ 0t r:~l y' ~i~ J>,,~ ---j l.:P -~:... W'lil~,~~~~iijjj!IllWM,~;_[:'fi _Jli~""=.~_~ ,.,.m~, '" .. PHYLLIS E. WILKE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00-1876 CIVIL TERM RAYMOND HERMAN KISS, Defendant : PROTECTION FROM ABUSE ORDER FOR CONTINUANCE ".-- AND NOW, this \ ") day of May, 2000, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on May 15, 2000, by this Court's Order of April 19, 2000, is hereby continued generally. This Order is entered without prejudice to either party to request a hearing. The Temporary Protection From Abuse Order shall remain in effect for a period of one year from the date it was entered or until further Order of Court, whichever comes first. By the. CoUrt, .' Joan Carey LEGAL SERVICES, INC. Attorney for Plaintiff -&:.;~ j "'fj-()O RK3 Jaqueline Verney Attorney for Defendant ;f~t) ~ >" .,- '""J" ,-- .' H " " 1'1 ',\ :, 'r 'I "J 1 ::1 I " ';'1 ,'; ::1 ,i ':1 I 'l 0' .. h7"'b!"lli"I\,,\r:J I ',IV'If 'Ii,) 111J_,C, J II\!nor"'; rlr".~,r;I~\["_P'''Ir!1'') /\.1. 1 \ \j \_,: '/ <<-:::iCi,i ~J 1\-1 i J lOt ~ilf ~; I ,( VJei 00 lU\.J1C"," "', "~'I' '0 I\fJV. 'i\:'k'lI ""c,-: ":1_ i ,.~. ! " ......,..'-',~ -, I,,..,.... ;30!::l.:il)'{i31/d U fi!f~~Ii!lhl'j_ ~, "' IF " . _....~ ,. ~ - ~~"l'ilIillm' ~ll-i~,~~F,;~~l~ JO ;'1 , ,. PHYLLIS E. WILKE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO, 00-1876 CIVIL TERM RAYMOND HERMAN KISS, Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE The Plaintiff, Phyllis E. Wilke, 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: L A Temporary Protection From Abuse Order was issued by this Court on April 19, 2000, scheduling a hearing for May 15, 2000, at 10:30 a.m. 2. The Defendant has retained Jaqueline Verney to represent him in the matter. 3. The parties agree, by and through their respective counsel, that the hearing be continued generally pending further Order in this matter to afford the parties time to execute a Consent Agreement. 4. The Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of one year from the date it was entered or until further Order of Court, whichever comes first. '-'~ --,-,-, , ~ _ r ,',- .~ iJ .. WHEREFORE, the Plaintiffrequests that the Court grant this Motion and continue this matter generally, and that the Temporary Protection From Abuse Order remain in effect for a period of one year from the date it was entered or until further Order of Court, whichever comes first. Respectfully submitted, 'Carey, Attorney for P ntiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 .~ - - ~- --, - <"~-~-" -~ - ""." " --, , -~ ~." :l I '" i.~ I~ '." ',:1 -~ i'l v. '11II -',.'" J ..~ "~~~~ "~4$llrp H '" ",' .. Q s::;; .' -DOS rnrri :Z::;-:.,-; ~jj S~+: -</" !~;CJ ~~~~ ).~S ==i -<. ~i ell c.:> o -" ---\ -,+:0 'T1r -oen -,,', dC, OT '..~~ (:,.I7"n '-\ '];> ~ ::1: ..,. ':< N 5: '=' t" ~'Q.~~~~'i1'B~ c ." ,'i<',ml]!I!!i~ll1iI;i~;r</<iI'1I%<mm~!-f!l~fllI~~~~,. ~ ,.., ~, ""'''!''-~'I~~'BJ " . ., PHYLLIS E. WILKE, Plaintiff : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-1876 CIVIL TERM ~. RAYMOND H. KISS, Defendant : PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, this \, f\ day of November, 2000, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on November 16, 2000, by this Court's Order of November 9, 2000, is hereby rescheduled for hearing on Tuesday, December 5, 2000, at 8:45 a.m. in Courtroom No.2 on the 4th Floor of the Cumberland County Courthouse, Carlisle, Pennsylv:ania. The Extension for Protection Order entered on November 9, 2000, shall remain in effect until further Order of Court. /""" \ B(!C6mt, Joan Carey, Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 CoPy pe :i/)(1t1l1y ~ I v~,..., ) Jacqueline M. Verney, Attorney for Defendant 44 South Hanover Street Carlisle, PA 17013 . eopy pesaM{!y Jive" Cumberland County Sheriff's Department " e_, - - '(" f"IIIJ!Ilf'l ~..,~->~,,... '"j " ,. " 'tINW\-,IASNN3d IUNnO') '-',\ 'en - c ."\,,, '''.''-'''''00 . ,.........:'.:Jfy.... L'I .1'" /', .t. $r(fj ! I - l,ON 00 J.b'lfJ()\ _~.~1D~~";l/JOj'I1~~n ,.!Vl!.~ [. .~_~~;j1~"r~,~'Il"'IF."''''fF''''li''\'\''''~'''"'",,'N'>iiJr''''n'lf~~~!\fllr;~1i~-ll>"H;)",>ff"'"Il!!''1'1fflJ:!'!'!ii!1Iillllli1l!!mI!l!llili~IlIffl'w.!!R1 ... 0, PHYLLIS E. WILKE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL V ANlA vs, : NO, 00-1876 CIVIL TERM RAYMOND H. KISS, Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff, Phyllis E. Wilke, by and through her attorney, Joan Carey of Legal Services, Inc., moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: I. APetition for Extension ofProtection Order was filed and an Extension of Protection Order was issued by this Court on November 9, 2000, scheduIing a hearing for November 16,2000, at 2:30 p.m, in Courtroom NO.2. 2. A certified copy of the Extension of Protection Order and Petition for Extension of Protection Order was mailed to the Sheriff's Office of Middlesex County, New Jersey, for service of Defendant at his residence or place of employment. On November 15, 2000, Legal Services, Inc. staff telephoned the Middlesex County Sheriff's Office in New Jersey and was told that their office had not yet received the certified copy of the Extension of Protection Order and Petition for Extension of Protection Order. 3. Plaintiff requests that the hearing be rescheduled to faciIitate service of Defendant. 4. Plaintiff requests that the Extension ofprotection Order issued on November 9,2000, remain in effect until further Order of Court. .1li"-=.., ~.....' ,= , .. ., WHEREFORE, Plaintiffrequests that the Court grant this Motion and reschedule this matter for hearing, and that the Extension of Protection Order remain in effect until further Order of Court. Respectfully submitted, ~@v,,<~ Jo . Carey, Attorney for P . " LEGAL SERVICES. INC. 8 Irvine Row Carlisle, PA 170B (717) 243-9400 ~~_.- ~ -~ , "" ,. . - ~.~ I -.. . PHYLLIS E. WILKE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-1876 CIVIL TERM RAYMOND H. KISS, Defendant : PROTECTION FROM ABUSE ORDERFORCONTUWANCE AND NOW, thi~ day of December, 2000, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on December 5, 2000, by this Court's Order of November 17, 2000, is hereby rescheduled for hearing on Monday, February 5, 2001, at 10:30 a.m. in .Courtroom No.2 on the 4th Floor of the Cumberland County Courthouse, Carlisle, Pennsylvania. The Extension for Protection Order entered on November 9, 2000, shall remain in effect until further Order of Court Joan Carey, Attorney for Plaintiff / LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 Jacqueline M. . Verney, Attorney for Defendant 44 South Hanover Street Carlisle,PA 17013 :--""",,~ ." ~ ~ . I I I I I , I I , II I , I I. Ii I I Ii II !j I'. ", " \iiN'v'i\lASNN3d AlNnOCI ON\fl\j38\"ln:) LS :8 I~~ 8- J::lG 00 AB'\f 0' ",,, "," "'1' '0 ] '\1', ',I"'" ',"" l ~ . 1 .>...,' Ic'V..J~' ~"li _.... -A "'\I.Pil-I'JTih :1...1.....".... ..:;1 ,.. , mr~l'~~~~'lill!_",-"e_"'_ ,~!_lif'ff~M~~'iilj'%1!'''.,~)1'JRill'"'';:o~;"'i'';lmR~~~'\l!'l1~,~~,.,.,,~_,_'*_~i"~O!lll!l:il~!~! I -l. PHYLLIS E. WILKE, Plaintiff : IN TIIE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-1876 CIVIL TERM RAYMOND H. KISS, Defendant : PROTECTION FROM ABUSE MOTIONFORCONTfflUANCE Plaintiff, Phyllis E, Wilke, by and through her attorney, Joan Carey of Legal Services, Inc., moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. An Motion was filed and an Order for Continuance issued by this Court on November 17, 2000, scheduling a hearing for December 5, 2000, at 8:45 a.m, in Courtroom No.2 of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania, 2. Certified copies ofthe Order for Continuance entered on November 17, 2000, and the Extension of Protection Order and attached Petition for Extension of Protection Order were mailed to the Sheriff's Office of Middlesex County, New Jersey, for service of Defendant. On November 30,2000, Legal Services, Inc. staff telephoned the Middlesex County Sheriff's Office in New Jersey and was told that their office had not received paperwork for service. 3. Jacqueline M, Vemey, counsel for Defendant during the initial proceeding in the above-captioned action, was mailed certified copies of this most current litigation and has been in communication with Defendant. On November 30, 2000, Legal Services, Inc. staff advised Ms. Verney ofthestatus of service, and she agreed that the matter be continued to facilitate service of Defendant since she did not have authorization from him to accept service on his behalf 4, Plaintiff requests that the hearing be rescheduled to facilitate service of Defendant. .c.\,,," , ~. ~ ~. I ,. 5. Plaintiffrequests that the Extension ofProtection Order issued onNovember 9, 2000, remain in effect until further Order of Court. WHEREFORE, Plaintiffrequests that the Court grant this Motion and reschedule this matter for hearing, and that the Exte1lllion of Protection Order remain in effect until further Order of Court. ~.;; ~~" N'an Carey, h/ey fI r Plaint" tEGAL SERVICES, INC. 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 _%ru@l1: , ~, , ~, ~ ~-- ~. 0_ "~_,f-~~~~~'l!l~..,.,,~, ~~,~ .~"" I'. -, ,- ",.. \ 'A' v., ''- .",,' 0 (,.-:l 0 c: c::> ~Tt ~, c:l :."2 _ -ceo p, fTlrr, c-:l 1'",._13 Z'::c "1'"' 2;[... I -"1.::)\'1 U) ,-~ co ..~:;o .;.,; r'" r':--- 1 r-=o ~~~ ~ :!:>. ZO ::<:: -0 7("") 5>c: 9? '-m ~ ~ w ~ 0 "' """""'~"'~~'1V""~.ii'\1<11~i"-'r""!""'lj",q'i~!I'V'.!i'<i1'ifm"W;!~~~1Ii~~IJ!""""""",,,,"!l!Iil!I!!!H!Ill " .. ~ PHYLLIS E. WILKE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO, 00-1876 CIVIL TERM RAYMOND H. KISS, Defendant : PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, this A day of February, 200 I, upon consideration ofthe attached Motion for Continuance, the matter scheduled for hearing on February 5,2001, at 10:30 a,m, by this Court's Order of December 9,2000, is hereby rescheduled for hearing on Monday, April 23, 2001, at 10:30 a.m. in Courtroom No. 2 on the 4'" Floor of the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania. The Extension for Protection Order entered on November 9,2000, shall remain in effect until further Order of Court. Edgar B. Bayley, Iu I Joan Carey, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 Jacqueline M. Verney, Attorney for Defendant 44 South Hanover Street Carlisle, P A 17013 ,\!~:'4,~ " ~ - .. I I I I I I ,~ ,''I''<'__M~~'~"'''2'~ I "' n c::' C :<:'" ...,., -0 jj:' '-'11 m r;-: ;.:~,:J 2: :7:: &~;~- c -""'< 5~; C'~ t'~-, e' (::~ j:; c: ~~,.) :,~ ::=,) ~ ,,- 10 ,.'..J -< ,c ~~ ioi _. L ~,,*""IW[!,~w,r,rn.w,~.J,'t''''?;''lt.'{roi>llM;"\f'!f!'~~~'lf_I~-'l:1r)f;Wf~1iiI~fIfl\f~WIiI~,!Oflml!~~~J1!i!lll!l!M' , PHYLLIS E. WILKE, Plaintiff : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO, 00-1876 CIVIL TERM RAYMOND H. KISS, Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE PlaintiH; Phyllis E. Wilke, by and through her attorney, Joan Carey of MidPenn Legal Services, moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. A Motion was filed and an Order for Continuance issued by this Court on December 8, 2000, scheduling a hearing for February 5, 2001, at 10:30 a.m. in Courtroom NO.2 ofthe Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania, 2. The parties, by and through their respective counsel, agreed that the hearing be rescheduled pending further Order. 3, Plaintiff requests that the Extension ofprotection Order issued on November 9, 2000, remain in effect until further Order {)f Court, WHEREFORE, Plaintiffrequests that the Court grant this Motion and reschedule this matter for hearing, and that the Extension of Protection Order remain in effect until further Order of Court. o Carey, Attorney for . ntiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ~~ r' .q " '.,-~. ~~, N"' _ ~,_" , ,. ~ "" ~ "_ d. j ~,~,," , I; ~",' - .. .~ - ,_,." ,",'W ri'",",',",o,,- C) c:) .--- * -1"(-':'"' 9~ ~j-'.: i:S::;-. ~~~; ~:::.C ):l>C_-: :z :::! "1-'MiLl' '-'," ':.') ,.-----, ~, t~,: ~.:J -< (}.... ,~=' ._"'f!\!I~~~C'II'WJ~!fJLH i I\1j:U9Jll:-:~f1-_i>WIi\'~~~!'II?_'j;;-?I~'l$~",*~~'1<JWi!lfib:,~~l'!'tl!1"'1!lj~!mml~!m':"!I;1h<Jf!:1l!f.lmlll!ll~!!J.I!1'IlI,~!Pl ,. - PHYLLIS E. WILKE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-1876 CIVIL TERM RAYMOND H. KISS, Defendant : PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, this !'l.-aay of July, 2001, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on July 5, 2001, at 1 :30 p.m. is hereby rescheduled for hearing on Wednesday, October 3, 2001, at 1:30 p.m. in Courtroom No.2 on the 4th Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. The Extension for Protection Order entered on November 9,2000, shall remain in effect until further Order of Court. \ Joan Carey, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 ~ ~ 7-/2.0/ q.. Lisa Greason, Attorney for Defendant 155 South Hanover Street Carlisle, PA 17013 '---'...,- '.'T ,.- -~ ~T PHYLLIS E. WILKE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-1876 CIVIL TERM RAYMOND H. KISS, Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff, Phyllis E. Wilke, by and through her attorney, Joan Carey of MidPenn Legal Services, moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. A hearing was scheduled for July 5, 2001, at 1:30 p.m. in Courtroom No.2 ofthe Cwnberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. 2. The parties, by and through their respective counsel, agreed that the hearing be rescheduled. 3. Plaintiff requests that the Extension of Protection Order issued on November 9, 2000, remain in effect until further Order of Court. WHEREFORE, Plaintiff requests that the Court grant this Motion and reschedule this matter for hearing, and that the Extension of Protection Order remain in effect until further Order 0 'ourt. Carey, Attorney for MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 ,',~ ,,-~ '.-,,"" '" '~' 0', . -" -" ..,'" <. w ... PHYLLIS E. WILKE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-1876 CIVIL TERM RAYMOND H. KISS, Defendant : PROTECTION FROM ABUSE ORDER FOR CONTINUANCE fiX Oc.o/db ~r AND NOW, this L day of Slllltemhet, 2001, npon consideration of the attached Motion for Continuance, the matter scheduled for hearing on October 3, 20(11, at 1 :30 p.m. is hereby generally continued. The Extension for Protection Order entered on November 9, 2000, shall remain in effect until further Order of Court. By the_Gouri; / \ Joan Carey, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 Lisa Greason, Attorney for Defendant 1h<1,1 ed 155 South Hanover Street Carlisle, P A 17013 I f~rsO(\Q{ ty 3!Vfn /0' 5-01 I , ;0 - - ~ .~ .... PHYLLIS E. WILKE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-1876 CIVIL TERM RAYMOND H. KISS, Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff, Phyllis E. Wilke, 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: 1. A hearing was scheduled for October 3, 2001, at 1:30 p.m. in Courtroom No.2 of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. 2. The parties, by and through their respective counsel, agreed that the hearing be continued generally to afford them time to execute a consent agreement. 3. Plaintiffrequests that the Extension of Protection Order issued on November 9, 2000, remain in effect until further Order of Court. WHEREFORE, Plaintiff requests that the Court grant this Motion and continue this matter generally, and that the Extension of Protection Order remain in effect until further Order of Court. Respectfully submitted, ~ttorney for PI I MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 -.,-- cC c' ~, ,L." - . ,-,' ,-_^~-,'~' '-'c:' ,~',. It., ~T _M' ~ ,~ ,. ,." _C".t."""""""'r,,,,:t1'J'~'lIl<!L "_~" ,"'.l!I!!I!I!~I~n_1J ~ o c ~6'ff ,6:~S'~:' ......-../.. r.::l~:-; -;:,- Z(.:) $- ( j "(= ..~ .~ "" - ,_.~- " '_'. .,' l'_ ~-'_' CJ - a '" -J I W ,,'- .~ .; ,-, , , w '-~~ j', ~V~ :::0 -< tll'JIIlRJO., ._o,.m~