HomeMy WebLinkAbout00-01901
Mandy Stahl,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: NO. 00- Nw
CIVIL TERM
Arlo Miller,
Defendant
: 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 ~ S ,
2000, AT j6, 3 D P,M., IN COURTROOM NO. 3 0 THE CUMBERLAND
COUNTY COURTHOUSE, CARLISLE, PENNSYL VANIA.
You MUST obey the Order that is attached until it is modified or terminated by the court
after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this
Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up
to $1,000.00 and/or up to six months in jail under 23 Pa.C.S. 96114. Violation may also subject you
to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law , 18
U.S.C. 92265, 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. 92261-2262.
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 YOII can get legal help. If you cannot fmd a lawyer, you may have to proceed
without one.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE, CARLISLE, PENNSYL V ANlA 17013
TELEPHONE NUMBER: (717)249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact
our office. All arrangements must be made at least 72 hours prior to any hearing or business before
the court. You must attend the scheduled conference or hearing.
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Mandy Stahl,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 00- /90/
CIVIL TERM
Arlo Miller,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name: Arlo P. Miller
Defendant's Date of Birth: 9/19/75
Defendant's Social Security Number: 168-56-9541
Names of the Pro::,c~lV\on:
AND NOW, thiS~ day of
attached Petition for Protection from
Order:
, 2000, upon consideration of the
hereby enters the following Temporary
!29 1. Defendant shall not abuse, harass, stalk or threaten any ofthe Plaintiff in any
place where she might be found.
o 2. Defendant is evicted and excluded 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.
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!29 3. Except for such contact with the minor child as may be permitted under
Paragraph 5 of this Order, Defendant is prohibited from having ANY CONTACT with
Plaintiff at any location, including, but not limited, to any contact at Plaintiffs residence or
place of employment. Defendant is specifically ordered to stay away from the following
locations for the duration of this Order: Plaintiff's residence at an undisclosed location and
her place of employment located at Loving Care Daycare, 1733 East Harrisburg Pike,
Middletown, Pennsylvania.
!29 4. Except for such contact with the minor child as may be permitted under
Paragraph 5 of this Order, Defendant shall not contact Plaintiff by telephone or by any other
means, including through third persons.
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129 5. Pending the outcome of the fmal hearing in this matter. Plaintiff is awarded
temporary custody ofthe following minor child: Makayla Miller (DOB 11/4/97).
Until the final hearing, all contact between Defendant and tII1e child shall be
limited to the following: Plaintiff shall have primary physical custody of the
minor child. Defendant shall have supervised visitation with the minor child at
the residence ofthe paternal grandmother at times agreed upon by the parties
129 6. Defendant shall immediately relinquish the following weapons to the Sheriffs
Office or a designated local law enforcement agency for the delivery to the Sheriffs Office:
Knife, collection of approximately 6-12 knives.
Defendant is prohibited from possessing, transferring or acquiring any other weapons for the
duration ofthis Order.
129 7.
The following additional reliefis granted:
The Cumberland County Sheriffs Department shall attempt to make service at
Plaintiff's request and without pre-payment of fees, but service may be
accomplished under any applicable Rule of Civil Procedure.
Law enforcement agencies, human service agencies and school districts shall not
disclose the presence of Plaintiff and/or the child in the jurisdiction or district
or furnish any address, telephone number, or any other demographic
information about Plaintiff and/or child except by further Order of Court.
Defendant's weapons and may be returned at the expiratioll of the Protection
Order after Defendant has submitted a written request to tII1e Court for the
return of the weapons and the Court has notified Plaintiff of the request and
given Plaintiff an opportunity to respond. A copy of this Order shall be
transmitted to the chief or head of the West Shore Regional police department
and the sheriff of Cumberland County.
This Order shall be docketed in the office of the Prothonotary and forwarded
to the Sheriff for service. The Prothonotary shall not send a copy of this Order
to Defendant by mail.
This Order shall remain in effect until modified or terminated by the Court and
can 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.
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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: A copy of this Order will be mailed
to the appropriate police departments.
o
9.
THIS ORDER SUPERSEDES
o ANY PRIOR PF A ORDER and
o ANY PRIOR ORDER RELATING TO CHILD CUSTODY
~ 10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL MODIFmD 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. 1/6114. 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. 1/6113. 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. 1/1/ 2261-2262. Any
protection order granted by a court may be considered in any subsequent proceedings, including
child custody proceedings, under title 23 (Domestic Relations) of the Pennsylvania Consolidated
Statutes.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the police who have jurisdiction over the plaintiffs residence
OR any locations where a violation of this order occurs OR where the defendant may be located.
If defendant violates Paragraphs I through 6 ofthis Order, defendant may be arrested on the charge
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
enforcement.
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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
weaponls are evidence of a crime, in which case, they shall remain with the law enforcement agency
whose officer made the arrest.
Judge
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Mandy Stahl,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
:NO.OO- It/Ol
CIVIL TERM
Arlo Miller,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
PETITION FOR PROTECTION FROM ABUSE
COUNT I
I. The Plaintiff is Mandy Lee Stahl.
2. The name of the person who seeks protection from abuse is Mandy Stahl.
3. Plaintiffs address is at an undisclosed location.
4. Defendant is believed to live at the following address 748 Apartment B, Market Street,
Lemoyne, Pennsylvania.
Defendant's Social Security Number is 168-56-9541.
Defendant's date of birth is 9/19/75.
Defendant's place of employment is AMP Incorporated, 3101 Fulling Mill Road,
Middletown, Pennsylvania.
5. Defendant is Plaintiffs former intimate partner.
6. Defendant has been involved in the following criminal court action: Defendant has been
arrested for possession, selling and intent to sell drugs.
Defendant is currently on probation in Dauphin County.
7.. Plaintiff seeks temporary custody of the following child:
Name
Makayla Miller
Address
531 Allison Drive
Hummelstown, Pa
Birthdate
11/4/97
8. Plaintiff and Defendant are the parents of the following minor child:
Name
Makayla Miller
Age
2 years old
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The following information is provided in support of Plaintiffs request for an Order of
child custody:
a) The child was born out of wedlock.
b) The child is presently in the custody of Plaintiff, Mandy Stahl, who resides at an
undisclosed location.
c) Since her birth the child has resided with the following persons and at the
following addresses:
Persons child lived with
Plaintiff and Defendant
Address
748 Apt. B Market Street
Lemoyne, Pa
When
Birth to 3/24/00
d) Plaintiff, the mother of the child, is currently residing at an undisclosed location.
e) She is single.
f) Plaintiff currently resides with the following persons:
Name
Makayla Miller
Relationship
Daughter
g) Defendant, the father of the child is currently residing at 748 Apartment B,
Market Street, Lemoyne, Cumberland County, Pennsylvania.
h) He is single.
i) Plaintiff has not previously participated in any litigation concerning custody of
the above mentioned child in this or any other Court.
j) Plaintiff has no knowledge of any custody proceedings concerning this child
pending before a court in this or any other jurisdiction.
k) Plaintiff does not know any person not a party to this action who has physical
custody of the child or claims to have custody or visitation rights with respect to the
child.
I) The best interests and permanent welfare of the minor child will be met if
custody is temporarily granted to Plaintiff pending a hearing in this matter for reasons
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including:
I) Plaintiff is a responsible parent who has provided for the
emotional and physical needs of the child since her birth, and
who can best take care of the minor child.
2) Defendant has shown by his abuse of Plaintiff that he is not an
appropriate role model for the minor child.
9. The facts of the most recent incident of abuse are as follows:
In or about March, 2000, Defendant threatened Plaintiff that if she
moved out of the residence someone would be standing at the door with a pistol
and she would be dead and no one would ever see her again. Defendant told the
parties' two year old daughter that mommy was going bye-byes for a little swim
and asked the child to help him push her mommy into the river.
10. Defendant has committed the following prior acts of abuse against Plaintiff
a) On or about March 19,2000, Defendant slept with a knife clipped to his boxers.
Defendant pulled the knife from the case and threatened Plaintiff that if she
made a wrong move, he would harm her, exacerbating her fear.
b) In or about February 2000, Defendant punched Plaintiff in the arm leaving a
bruise. Defendant also pushed Plaintiff against the wall and choked her as he
stated that she was not going to leave the house.
c) Since approximately 1996, Defendant has abused Plaintiffin ways including the
following: restrained her, hit, pushed, choked her, and pushed her down the
steps. Approximately four or five times in the last month, Defendant has
threatened to harm Plaintiff and has specifically told her that he will take away
their daughter so that she will never see the child again.
II. The following police departments or law enforcement agencies in the area in which
Plaintiff lives should be provided with a copy of the Protection Order: A copy of the Order will be
mailed to the appropriate police departments.
12. There is an immediate and present danger of further abuse from Defendant.
13. Defendant owes a duty of support to the minor child.
WHEREFORE, PLAINTIFF REQUESTS THAT THE COURT ENTER A
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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. Award Plaintiff temporary custody of the minor child and place the following
restrictions or contact between Defendant and child: Plaintiff has primary physical
custody of the minor child. Defendant shall have the right to supervised visitation atthe
home ofthe paternal grandmother at times agreed upon by the parties.
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 Plaintiffs residence or place of employment, except as the Court may
find necessary with respect to partial custody and/or visitation with the minor child.
D. Prohibit Defendant from having any contact with Plaintiffs relatives.
E. Order Defendant to temporarily turn over weapons to the Sheriff of this County
and prohibit Defendant from transferring, acquiring or possessing any such weapons for
the duration of the Order.
F. Order Defendant to pay temporary support for the minor child.
G. Order Defendant to pay the costs ofthis action, including filing and service fees.
H. Order Defendant to reimburse Cumberland County, a Legal Services funding
source, $250.00 for the value of the legal services provided to Plaintiff for the cost of
litigating this case if the case goes to hearing.
. 1. Order the following additional relief, not listed above:
The Defendant is required to relinquish to the sheriff any knives Defendant may
possess. Defendant's weapons license may be returned at the expiration of the
Protection Order after Defendant has submitted a written request to the Court for
the return of the weapons and the Court has notified Plaintiff of the request and
given Plaintiff an opportunity to respond.
The Defendant is enjoined from damaging or destroying any property owned
jointly by the parties or owned solely by Plaintiff.
The Defendant is to refrain from harassing Plaintiff's relatives.
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1. Grant such other relief as the court deems appropriate.
K. 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.
COUNT II
CUSTODY UNDER PENNSYL VANIA CUSTODY LAW
14. The allegations of Count I above are incorporated herein as if fully set forth.
15. The best interest and permanent welfare of the minor child will be served by confirming
custody in Plaintiff as set forth in paragraph #7 of the petition.
WHEREFORE, pursuant to 23 Pa.C.S.g 5301 et. seq., and other applicable rules and law,
Plaintiff prays this Honorable Court to award custody of the minor child to her.
Plaintiff prays for such other relief as may be just and proper.
Date:
3/.2 'i/ko
.
Andrea Le and Phillip
Attorneys for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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VERIFICATION
I verify that I am the 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:M {};LfJL !J 71 /J.A 0 0
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-01901 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
STAHL MANDY
VS
MILLER ARLO
SHAWN HARRISON
, Sheriff or Deputy Sheriff of
Cumberland County, Pensylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE
was served upon
MILLER ARLO
the
DEFENDANT
, at 0020:43 HOURS, on the 28th day of March
, 2000
at 748 MARKET ST
APT B
LEMOYNE, PA 17043
by handing to
ARLO MILLER
a true and attested copy of PROTECTION FROM ABUSE
together with
& CUSTODY, NOTICE OF HEARING & ORDER, TEMPORARY
PROTECTION FROM ABUSE ORDER
and at the same time directing His attention to the contents thereof.
Additional Comments
3 KNIVES CONFISCATED.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
10.54
.00
10.00
.00
38.54
r~#ty't-t:~.t
R. Thomas Kline
03/29/2000
,
Sworn and Subscribed to before By:
me this If> Ie
day of
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q.,...- (l 1k,1PLoJ #
P othonotary .
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Mandy Stahl
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 00-1901
CIVIL TERM
Arlo Miller,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
FOR CONTINUANCE
AND NOW, this
day of April, 2000, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on April 5, 2000, by this Court's Order of March 28,
2000, is hereby rescheduled for hearing on April 24'h , 2000, at 10:30 p.m. in Courtroom No.3.
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.
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
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Arlo Miller
Pro Se Defendant
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Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00-1901 CIVIL TERM
: PROTECTION FROM ABUSE AND CUSTODY
Mandy Stahl
v.
Arlo Miller,
Defendant
MOTION FOR CONTINUANCE
The Plaintiff Mandy Stahl, 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 5, 2000, at 10:30 a,m.
2. The Cumberland County Sheriff's Department served Defendant with a certified copy
of the Temporary Protection From Abuse Order and Petition for Protection From Abuse at his
residence located at 748 Market Street, Apartment B, Lemoyne, Pennsylvania March 28,2000, at
8:25 p.m.
3.
The parties agree that the hearing be rescheduled pending further Order in this matter
to afford them time to execute a Consent Agreement.
4. The Plaintiff requests that the Temporary Protection From Abuse Order remain in
effect for a period of one year from the date it was entered or until further Order of Court, whichever
comes first.
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
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effect for a period of one year from the date it was entered or until further Order of Court, whichever
comes first.
Respectfully submitted,
o Carey, Attorney for B ntiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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Mandy Stahl
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-1901
CIVIL TERM
Arlo Miller,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
OR CONTINUANCE
day of April, 2000, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on April 24, 2000, by this Court's Order of March
April 5, 2000, is hereby rescheduled for hearing on May 24th, 2000, at 10:00 p.m. in Courtroom No.
3.
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.
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
Judge
Arlo Miller
Pro Se Defendant
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Mandy Stahl
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 00-1901
CIVIL TERM
Arlo Miller,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
MOTION FOR CONTINUANCE
The Plaintiff Mandy Stahl, 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 Continuance was issued by this Court on April 5, 2000, scheduling a hearing for
April 24, 2000, at 10:30 a.m.
2. The parties agree that the hearing be rescheduled to afford them time to execute a
Consent Agreement.
3. 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.
Respectfully submitted,
Carey, Attorney for aintiff
LEGAL SERVICES, I C.
8 Irvine Row
Carlisle, PA 17013
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Mandy Stahl
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 00-1901
CIVIL TERM
Arlo Miller,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
ORDER FOR CONTINUANCE
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AND NOW, this f). 'f day of May, 2000, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on May 24, 2000, by this Court's Order of March 28,
2000, is hereby rescheduled for hearing on June 20, 2000, at 4:00 p.m. in Courtroom No.3.
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
Arlo Miller
Pro Se Defendant
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: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 00- 1901
CIVIL TERM
Arlo Miller
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
MOTION FOR CONTINUANCE
The Plaintiff, Mandy Stahl, 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 continuance was issued by this Court on April 26th, 2000, scheduling a hearing
for May 24, 2000, at 4:00 p.m.
2. The parties agree that the hearing be rescheduled to afford them time to execute a
Consent Agreement.
3. 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 fora
period of one year from the date it was entered or until further Order of Court, whichever comes first.
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA l70l3
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: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-1901
CIVIL TERM
Arlo Miller,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
ORDE~FOR CONTINUANCE
AND NOW, thi()t1 d.:\f June, 2000, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on June 20, 2000, by this Court's Order of March
May 24, 2000, is hereby rescheduled for hearing on July 7,2000, at 10:00 p.m. in Courtroom No.
3. 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.
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
Judge
Arlo Miller
Pro Se Defendant
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: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-1901
CIVIL TERM
Arlo Miller,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
MOTION FOR CONTINUANCE
The Plaintiff Mandy Stahl, 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 Continuance was issued by this Court on May 24, 2000, scheduling a hearing for
June 20,2000, at 10:30 a.m.
2. The parties agree that the hearing be rescheduled to afford them time to execute a
Consent Agreement.
3. 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.
Respectfully submitted,
~~
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, P A 17013
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: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 00-1901 CIVIL TERM
Arlo Miller,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
ORDE\FOR CONTINUANCE
AND NOW, this ~ day of July, 2000, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing, July 7, 2000, by this Court's Order of June 20, 2000,
is hereby rescheduled for hearing on July 24,2000, at 3:30 p.m. in Courtroom NO.3.
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. ~ t, l. S,
Attorney for Plaintiff
Arlo Miller
PROSEDEFENDANT ~ ~ 70//3,07)
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: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-1901 CIVIL TERM
Arlo Miller,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
MOTION FOR CONTINUANCE
The Plaintiff, Mandy Stahl, 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 Continuance was issued by this Court on June 20, 2000, scheduling a hearing for
July 7, 2000, at 10:00 a.m.
2. The parties agree that the hearing be rescheduled to afford them time to execute a
consent agreement.
3. 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.
an Carey, Attorney for aintiff
EGAL SERVICES, I C.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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Mandy Stahl
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-1901
CIVIL TERM
Arlo Miller,
Defendant
: PROTECTION FROM ABUSE
FINAL ORDER OF COURT
Defendant's Name: Arlo Miller
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Defendant's Date of Birth: 9/19/75
Defendant's Social Security Number: 168-56-9541
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AND NOW, this day of ::;; ~ cou~t having j!risdiCtiOn 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
unrepresented but is aware of his right to have an attorney. 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 Plaintiffs request for a Final Protection Order is denied OR
181 Plaintiff's reqnest for a Final Protection Order is granted.
1811. 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 *[NONCONFIDENTIAL
ADDRESS FROM WHICH DEFENDANT IS EXCLUDED] 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.
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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.
03. Except as provided in Paragraph 5 (and Paragraph #8 if any unusual circumstances) of this
Order, Defendant is prohibited from having ANY CONTACT with Plaintiff at any location,
including, but not limited to any contact at Plaintiff's school, business, or place of employment.
Defendant is specifically ordered to stay away from the following locations for the duration of this
Order: Plaintiff's residence located at *, Cumberland County, Pennsylvania, and any other residence
Plaintiff may establish.
o 4. Except as provided in Paragraph 5 of this Order, Defendant shall not contact Plaintiff by
telephone or by any other means, including third parties.
~ 5. Custody of the minor child, Makayla Miller, shall be as follows: 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 prohibited from possessing, transferring or acquiring any other weapons for the
duration of this Order. Any weapons delivered to the sheriff under Paragraph 6 of this Order or
under Paragraph 6 of the Temporary Order shall not be returned until further Order of Court.
~ 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 fmds 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.
o 9. Defendant is directed to pay temporary support for [insert the names of the persons for whom
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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 II. Defendant shall pay $* to Plaintiffas compensation for Plaintiffs out-of-pocket losses, which
are as follows:
OR
D Plaintiff is granted leave to present a petition, with appropriate notice to Defendant, to
[insert the name ofthe 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.
D 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 I 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
D 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.
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ORDER RELATING TO CHILD CUSTODY.
JgJ 14. All provisions ofthis Order shall expire in one year.
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. ~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 OF THIS ORDER HAS BEEN CHECKED, YOU MAY
BE SUBJECT TO FEDERAL PROSECUTION AND PENAL TIES 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 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
[insert the appropriate name or title) shall maintain possession ofthe 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
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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.
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BY THE COURT,
P esident Judge
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If entered pursuant to the consent of Plaintiff and D
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oan Carey
Attorney for Plaintiff
Legal Serivces, Inc.
8 Irvine Row
Carlisle, Pa 17013
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: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-1901
CIVIL TERM
Arlo Miller,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
. ~ CDS
AND NOW, thiS~ day of . 0 0, upon consideration of the parties' Consent
Agreement, the following Order is entered with regard to custody of the parties' child: Makayla
Miller (DOB 11/4/97).
I. Plaintiff, Mandy Stahl, hereinafter refen'ed to as the mother, and Defendant, Arlo
Miller, hereinafter referred to as the father, shall share legal custody of the child.
2. The mother shall have primary physical custody of the child.
3. The father shall have partial custody of the child on dates and at times agreed upon by
the 1l10ther and father.
4. The father shall supervise the child at all times if he takes her to the paternal
grandfather's residence.
5. . Either party may request a conciliation cohference to modify this Custody Order, but
this Order shall remain in effect pending further Order.of Court.
By the Court,
t Judge
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1 a Carey, Attorney for PI
Legal Services, Inc.
8 Irvine Row
Carlisle,l>a 170B
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CUMB CO PROTHONOTARY
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CONNECTION ID
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RESULT
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*********************
2026
92490779
07/26 12:56
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MANDY STAHL,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
1901 CIVIL 2000
ARLO MILLER
Defendant
ITEM: (5) Knives
~~
AND NOW, this ~ Day of ~, upon petition of the Sheriff, the
following Order is entered:
The Sheriff of Cumberland County having sent notice to reclaim the seized
weapon(s)/firearm(s) to the above-named defendant via regular mail to the last known
address, and the defendant not having responded to the notice by asserting a claim,
the Sheriff of Cumberland County is directed to destroy the listed weapon(s)/firearm(s)
in accordance with law.
By the Court,
, P.J.
R. Thomas Kline, Sheriff
Cumberland County Sheriff's Office
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MANDY STAHL
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
1901 CIVIL 2000
ARLO MILLER
Defendant
ITEM: (5) Knives
PETITION TO DESTROY UNCLAIMED WEAPON(S)
AND NOW, comes R. Thomas Kline, the Sheriff of Cumberland County, by and through his
Solicitor, Edward L. Schorpp, Esq., and petitions Your Honorable Court to order the destruction of
the above described weapons in his possession upon the following:
1. The Cumberland County Sheriffs Office currently has possession of the above
described weapons, having seized the same from the Defendant on March 28, 2000.
2. The weapons were seized pursuant to an Order of Your Honorable Court dated
March 28, 2000 and entered at the above docket number.
3. The Order was issued in proceedings instituted by the Plaintiff for protection from
abuse.
4. Pursuant to said Order, the period of seizure expired on July 26, 2001.
5. On January 31, 2002, the Sheriff's Office caused notice to be sent, via
regular mail and certified mail, to the Defendant at his last known address, advising
him that the above described weapons must be reclaimed by him, in person, within
30 days after the expiration of the order, at which time the Sheriff Office would
petition Your Honorable Court for an Order for destruction of the weapons; a copy of
said notice is attached hereto as Exhibit "Au.
6. The Defendant has failed to reclaim the weapons.
.
WHEREFORE, you petitioner respectfully requests Your Honorable Court to enter an Order
directing the destruction of the above described weapons.
Very respectfully submitted,
~~
Edward L. Sch rpp
Solicitor
10 East High Street
Carlisle, PA 17013
(717)243-3341
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VERIFICATION
I, Barry J. Horn, verify that the statements made in the within Petition are true and
correct to the best of my knowledge, information and belief. The undersigned
understands that this statement herein is made subject to the penalties of 18 Pa. C. S.
Section 4904 relating to unsworn falsification to authorities.
Dated:~
By:
Barry J. Ho Sergeant
Cumberland County Sheriffs Office