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HomeMy WebLinkAbout00-02523 < ~ , ..", -.;~l Kathleen Ann Notz, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-2523 CIVIL TERM Patricia Cugini, 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 rnust appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on this matter is scheduled on the Iftll day of December, 2002, at 9; (f2) Q.. .m., in Courtroom No. -#-- on the 4th Floor of the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania. 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. g61l4. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. g2265, 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. 9 2261-2262. You should take this paper to your lawyer at once. You have the right to have a lawyer represent you at the hearing. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. If you cannot find a lawyer, you may have to proceed without one. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, Pennsylvania 17013 Telephone Number: (717)249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information 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. - ., ,I. - ~. Kathleen Ann Notz, Plaintiff : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v. Patricia Cugini, Defendant : No. 00-2523 : CIVIL ACTION - LAW : PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Patricia Cugini Defendant's Date of Birth is: June 6, 1967 Name(s) of All protected persons, including Plaintiff and minor children: 1. Kathleen Ann Notz AND NOW, on 10th Day of December, 2002 upon consideration of the attached petition for Protection from Abuse, the court hereby enters the following Temporary Order: Plaintiffs request for a temporary protection order is granted. L Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. 2. Defendant is prohibited from having ANY CONTACT with Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at Plaintiffs school, business, or place of employment. 3. Defendant shall not contact Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. , "-I~"_~,,,'. 4. The following additional relief is granted: - Defendant is prohibited from having any contact with Plaintiffs relatives. - Defendant shall not damage or destroy any property owned by Plaintiff. 5. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Silver Spring Townhip Police Department Middlesex Township Police Department 6. The sheriff, police or other law enforcement agencies are directed to serve the Defendant with a copy of the Petition, any Order issued, and the Order for Hearing without prepayment of costs. The Petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. The Prothonotary is directed to file this Petition and Order without prepayment of costs. 7. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL JUNE 10,2004 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT Defendant is hereby notified that violation ofthis 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. g6ll4. 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. g6l13. Defendant is further notified that violation ofthis Order may subject himlher to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. gg2261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiffs residence OR any location where a violation of this order occurs OR where the defendant may be located. If defendant violates Paragraphs 1 through 3 of this Order, defendant shall 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 - '~ , .,k, threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriffs office ofthe 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. BYTHECO RT~d.. Judge Zt)O~ Date Distribution to: Legal Services Faxed & Mailed to PSP .-,. HI~o( In ProJho()o~/ De<.elVlbe.r 10, (l(~ - ......,..-"""-"._~~~.~ . ~ , ~, ~"~.,.,f~lP~Iif~~J!Il!i l!fllll!ll!ll.,,~1f!i~_'_'r)!l~ 1,_ , ,.'- - """" PFAD Number: FCl593559N Kathleen Ann Notz, Plaintiff : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYL V ANlA v. Patricia Cugini, Defendant : No. : CIVIL ACTION - LAW : PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE 1. Plaintiffs name is: Kathleen Ann Notz 2. I, (the Plaintiff), am filing this Petition on behalf of: - myself 3. Name(s) of ALL person(s), including minor children, who seek protection from abuse. a. Kathleen Ann Notz 4. Plaintiffs Address is: 222 Texaco Road, Mechanicsburg, PA 17055 5. Defendant's Name is: Patricia Cugini 6. Defendant is believed to live at the following address: 1300 Trindle Road, Carlisle, P A 17013 7. Defendant's Date of Birth is: June 6, 1967 l' h~l", 8. Defendant's Place of employment is: nnknown 9. Defendant is an adult. 10. The relationship between the Plaintiff and the Defendant is: Brother / Sister II. The Plaintiff and the Defendant been involved in the following court actions: a. Protection From Abuse 12. Other details ofthe court action are: Protection from Abuse fIled in Cumberland County May 2000 13. The defendant has been involved in a criminal court action. 14. The facts of the most recent incident of abuse are as follows: On or about November 29, 2002, Defendant sent Plaintiff instant e-mail messages threatening to come to Plaintiffs residence with a baseball bat and "take it" to Plaintiffs legs. Defendant further threatened that she will be in jail for murder and and that she would try for Plaintiffs head. 15. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor child/ren, (including any threats, injuries, or incidents of stalking) are as follows: In or around October 2002, Plaintiff sent a letter to Defendant asking that Defendant not contact her at home or at her place of business. In or around April 2000, Defendant followed Plaintiff from her work place in her car and cut Plaintiff off with her vehicle. Defendant jumped out of her car, grabbed Plaintiff by the hair and pulled her partially through the window. Plaintiff ended up on the ground and Defendant repeatedly struck her with her fists. Defendant then went to the police and fIled a false report. Defendant was eventually charged with fIling a false report and simple assault. Plaintiff required medical treatment as a result of this incident. Defendant is bi-polar and has a history of violence. As a result of Defendant's history and current state of mind, Plaintiff fears for her personal safety. ~ ;1 16. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: Silver Spring Townhip Police Department Middlesex Township Police Department 17. There is an immediate and present danger of further abuse from the Defendant. 18. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or minor child/ren in any place where Plaintiff may be found. b. Prohibit Defendant from having any contact with Plaintiff and/or minor child/ren, either in person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Plaintiffs school, business, or place of employment, except as the court may fmd necessary with respect to partial custody and/or visitation with the minor child/ren. c. Prohibit Defendant from having any contact with Plaintiffs relatives and Plaintiffs children listed in this petition, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/ren. d. Order the following additional relief, not listed above: Defendant shall not damage or destroy any property owned by Plaintiff. e. Grant such other relief as the court deems appropriate. f. Order the police or other law enforcement agency to serve the 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 the Defendant's residence, where Defendant can be served. Respectfully submitted, Date: /~//O /o~ ( ( hihp C. Briganti, Atto y for Plaintiff Joan Carey, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 , 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 Pll.C.S.g4904, relating to unsworn falsification to authorities. Dated: I'J-~/O~O~ ~Wtm Kathleen Ann Notz, Plaintiff _1IiiIii ",~ "~""Wuir ,"~;..;:_.". '""1lilf"' '"" ", ", ~ () ~~ t)6:" i~; ~,~; -~ ~"CJ z(_ .....", -' ~c :z: =< , "~' ,1' "0'_ C) r'. ',_...I "n ',,-,' .:::J '''1 i,....) ~1. '~:l=j -,-!T'1 !~C} -:;C) ;)~~ -"-<(") (srn );.1 :o:J -< a """ - -i;>. - "" ..., "" " -~ , ..~ ~-~; 12/10/02 TOE 13:06 FAX 717 240 6573 CliMB CO PROTHONOTARY 141001 *************************** *** MULTI TN REPORT *** *************************** -iJ()J - ~5-J~ TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 3545 [ 01l9p2490779 [ 03j9p2405331 [ 04]92438026 PSP CP LS ERROR OFFICE OF TIlE PROTIlONOTARY CUMBERLAND COUNTY COURTIIOUSE ONE COURTIIOUSE SQUARE CARLISLE, PA 17013" 3387 (717)240-6195 FAX (717) 240- 6573 VIA TELECOPIER TO: PA STATE POLICE - CENTRAL PROCESSING MUDPENNLEGALSERVICES FAX # FROM: CURTIS R. LONG RE: FAXING A PFA MESSAGE: 7 NO. OF PAGES (INCLUDING COVER SHEETS) This message is intended for the use of the individual or entity to which it is addressed, and it may contain Information that is privileged, confidential and exempt from dillclosme under applicable law. If the reader of this message is nor the intended recipient" you are hereby notified that any dissamination. distribution or copying of this eOIllInunication is strictly prolubited. If you have received this eommunieation in error, please notify US immediately by telephone and return the original message to us at the above address via the U. S. postal service. Thank you ' ~ Kathy Notz, for herself and on:IN THE COURT OF COMMON PLEAS behalf of her minor children, Kelly, Jessica, Tammy, and :OF CUMBERLAND COUNTY, PENNSYLVANIA Daniel Notz, Plaintiff v. :NO. 00-2523 CIVIL TERM patricia Cugini, Defendant :PROTECTION FROM ABUSE FINAL ORDER OF COURT Defendant's Name: patricia Cugini Defendant's Date of Birth: 6/7/67 Defendant's Social Security Number:Unknown Names of all Protected Persons, including Plaintiff and minor children: Kathey Noz, and her minor children, Tammy, Kelly, Jessica, and Daniel AND NOW, this ~~ttday of May, 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 The Family Law Clinic. 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 shall not abuse, stalk, harass, threaten Plaintiff or any other protected person in any place where they might be found. ~, "- ij 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. 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. Defendant is prohibited from having ANY CONTACT with Plaintiff at any location, including, but not limited to any contact at Plaintiff's 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 923 West Trindle Road, Cumberland County, Pennsylvania, and Plaintiff's place of employment located at 901 West Trindle Road, Mechanicsburg, Pennsylvania. ~ 4. Defendant shall not contact Plaintiff by telephone or by any other means, including 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 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. 5 8. The following additional relief is granted as authorized by S6l08 of this Act: a. This Order shall remain in effect until modified or ter.minated 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 har.m to Plaintiff. b. Defendant is enjoined from damaging or destroying any property owned solely by Plaintiff. c. Defendant is to refrain from harassing Plaintiff's relatives or the minor children. 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 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. o 10. The costs of this action are waived as to Plaintiff and imposed on Defendant. ~ 11. Defendant shall pay $43.24 to Plaintiff as compensation for Plaintiff's unreimbursed medical expenses due to injuries resulting from the incident which occurred on or about April 12, 2000. Defendant shall pay to Plaintiff within 60 days of the entry of this Order. 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 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 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 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. 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. TERRITORIES, AND THE COMMONWEALTH OF PUERTO RICO UNDER TaE VIOLENCE AGAINST WOMEN ACTION, 18 U.S.C. 52265. 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. 55 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 incidents 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. , " 'HDj, I I" t 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. ~ .A'Y1.' Q I BY .!IfE CO~I7' S-.2;~ .. . . iM1~ fQJJ Edg= tb P-S P q I. "I r I'. . If entered pursuant to the consent of Plaintiff and Defendant: i~~h~ Kathy tz, P ntiff p~~ patricia Cugini, Defendant oan Carey Legal Services, Inc. a Irvine Row Carlisle, PA 17013 Intern Su sing ttorney Family Law Clinic 45 North pitt Street Carlisle, PA 17013 CUij,';i: 'I ~ i) fg ~.9!,r ~r lCt: ,,- r,10V ''''.11; ., ::,' I:;; I , , . ,-,,' .. , '~.' "~.~"!I .wjlll!lll~lfflJml~nffi~"'"'l'fIilII!l1'1llffi! ............I!". nlWlf~~~~IIII1ff~._~ OS/23/00 TUE 09:44 FAX 717 240 6573 "'." CUllIB CO PROTHONOTARY (j/J- J..~/.<3 141001 TRANSMISSION OK TX/RX NO CONNECTION TEL CONNECTION ID ST. TIME USAGE T PGS. RESULT ********************* *** TX REPORT *** ********************* 1880 92490779 OS/23 09:38 05'37 8 OK '"' ~.:I ::i !j :1'1 ~ ;1 ii ;~ , J i ;! ji " ijJ " ,< 'I! Kathy Notz, for herself and on behalf of : IN THE COURT OF COMMON PLEAS OF her minor children, Kelly, Tammy, Jessica and Daniel Notz : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 2000- 2523 CIVIL TERM il " fi Patricia Cugini, Defendant : PROTECTION FROM ABUSE ORDER OF COURT .\j j , (I AND NOW, this 20th day of June, 2000, upon consideration of the attached Petition, the Final Protection Order in the above-captioned case entered on May 22, 2000, is hereby vacated and ;j II !:j ,I ~1 :1 the action withdrawn without prejudice to Plaintiff. -7.... " /. \ . , By the Court/ ' Joan Carey Attorney for Plaintiff LEGAL SERVICES, INC. ,.~ ~cuU floilil 't Wlo PS p ~. 23-00 "RK5 Donald Marritz Attorney for Defendant FAMILY LAW CLINIC !j . ~, .';',' "~:I~'(V.?V ...Jl r.~) ":/., -;', c>," "-.. :fl "', iU: t;) CVA'~I~j?'L/.t\i:') -' "~" . '''"' I CiV/\'.C;}lft/~,\'LUf\IJ\1' .... ,~v';'i/lA 'I i ." ~;JI!liJ!! T -t.. ,ml\fllj1~_.r_PlII_"~~~J]L 111-- Kathy Notz, for herself and on behalf of : IN THE COURT OF COMMON PLEAS OF her minor children, Kelly, Tammy, Jessica and Daniel Notz : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 2000- 2523 CIVIL TERM Patricia Cugini, Defendant : PROTECTION FROM ABUSE PETITION TO VACATE ORDER AND WITHDRAW ACTION Plaintiff, Kathy Notz, by and through her attorney, Joan Carey of Legal Services, Inc., requests that the Court vacate the Final Protection Order in the above-captioned case and that the action be withdrawn on the grounds that: 1. A Petition for Protection From Abuse was filed and a Temporary Protection From Abuse Order was issued by this Court on April 24, 2000, scheduling a hearing for May I, 2000, at I :30 p.m. before Judge Bayley in Courtroom No.2 of the Cumberland County Courthouse. A Final Protection Order was entered on May 22, 2000, by agreement of the parties. 2. The parties are in the process of reconciling their differences and they will be attending counseling. 3. Plaintiff requests that the Final Protection Order be vacated and the action withdrawn without prejudice to her. ",I WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate the Order, and that the action be withdrawn without prejudice to Plaintiff. Respectfully submitted, Joan Carey, Attorney r Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 "I VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above 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. g4904, relating to unsworn falsification to authorities. Dated: lt~Ji-OO ~~g Kathleen Notz, Plaintiff J' . --- '-""~lIil!lilnliilli.;;lj1t.'ilM~~Ilit~ !JilMn.iJr&l ~.o> d;'D'~ .::-- aJ5 ;g ~ <:) ~ C") 1,.",:.,> ;\,' -.',--) r:''? (J') ~~ 06/23/00 FRI 12:44 FAX 717 240 6573 J:~,: CliMB CO PROTHONOTARY 141001 TRANSMISSION OK TX/RX NO CONNECTION TEL CONNECTION In ST. TIME USAGE T PGS. RESULT ~*~****************** *** TX REPORT *** ********************* 1959 92490779 06/23 12:40 03'57 6 OK KATHY NOTZ,FOR THEMSELVES AND ON BEHALF OF THEIR MINOR CHILDREN, KELLY, JESSICA, TAMMY, AND DANIEL NOTZ VS. :IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, PENNSYLVANIA :NO. 00 -),j16 CIVIL TERM PATRICIA CUGINI, 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 ~ ' 2000, at 1'. '60 the C erland County Courthouse, Carlisle, for the {6l- day of ? .m., in Courtroom No.~ of Pennsylvania. 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. 56114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. 52265, 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. 52261-2262. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEARING. THE COURT WILL NOT, HOWEVER, APPOINT A LAWYER FOR YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL 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: (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 A1nericans with Disabilities Act of 1990. For information about accesaible 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. -~ ~. ,~,~ ~"'" '''U:0''''-"''. .. .. -~.,', -~~~. ~ 1iSi~' IbllW~1 .]v WI 7;'NV/\7/~8NN:Jd 11'1'""-''--\ 1"1'.' ..__,.,.., ,'1jJ"1 ii J" ; I,"',J -"'I~:::;Y\JrV", ,. '._, ", "'.-" '.' '! '\) '""1/ '. I! I U:~,;(, d '"..' <, ";,-1:-1 I~'ir! ...... ~. '-.I:) ."...' .~--~.-.~~ ,~, :..<; KATHY NOTZ,FOR HERSELF AND ON BEHALF OF HER MINOR CHILDREN, KELLY, JESSICA, TAMMY, AND DANIEL NOTZ VS. :IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, PENNSYLVANIA :NO. 00 - CIVIL TERM PATRICIA CUGINI, DEFENDANT :PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name: patricia Cugini Defendant's Date of Birth: 6/7/67 Defendant's Social Security Number: Unknown Name of All Protected Persons: Kathy Notz, and her minor children, Kelly, Jessica, Tammy, and Daniel. AND NOW, this dJ.'-ft/i. day of April, 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. 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. '_ 'C b~~ .........,!.' Defendant is specifically ordered to stay away from the following locations for the duration of this Order: Plaintiff's residence located at 923 West Trindle Road, Mechanicsburg, Cumberland County, Pennsylvania, which is not owned or leased by Defendant, and Plaintiff's place of employment located at 901 West Trindle Road, Mechanicsburg, Pennsylvania. Defendant is also ordered to stay away from the minor children's school located at Monroe Elementary, Eagle View M.S., and Cumberland Valley High School. Defendant is additionally ordered to stay away from oldest child's employment at The Hampden Pool, Sporting Hill Road, Mechanicsburg. ~ 4. 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. This Order shall remain in effect until modified or ter.minated 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 har.m to Plaintiff and/or the minor children. Defendant is enjoined from damaging or destroying any property owned by Plaintiff. Defendant is to refrain from harassing Plaintiff's relatives or the minor children. ~ 8. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Pennsylvania State Police, Mechanicsburg, and Silver Springs Township Police. o 9. THIS ORDER SUPERSEDES 0 ANY PRIOR PFA ORDER AND 0 ANY PRIOR ORDER RELATING TO CHILD CUSTODY ~ 10. REMAIN NOTICE THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER 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 protection order aranted bv a court may be considered in any subseauent proaeedinas. includina child custodv proceedinas. under title 23 (Domestic Relations) of the Pennsylvania Consolidated Statutes. " , -=, ""'~I",,,",,' 'd'. '"",j " 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. BY THE Judge r ~ ' KATHY NOTZ,FOR HERSELF AND ON BEHALF OF HER MINOR CHILDREN, KELLY, JESSICA, TAMMY, AND DANIEL NOTZ VS_ : IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, PENNSYLVANIA ;NO. 00 - <<5J-3 CIVIL TERM PATRICIA CUGINI, DEFENDANT :PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE I. Plaintiffs name is Kathy Notz. 2. This Petition is filed on behalf of Kathy Notz for herself and her minor children, Kelly, Jessica, Tammy and Daniel Notz,. 3. The names of ALL the persons, including Plaintiff and minor children, who seek protection from abuse are Kathy Notz and her minor children, Kelly, Jessica, Tarmny, and Daniel Notz. 4. Plaintiffs address is 923 West Trindle Road, Mechanicsburg, Pennsylvania. 5. Defendant is believed to live at 412 West Simpson Street, Mechanicsburg, Pennsylvania. Defendant's Social Security Number is unknown to Plaintiff. Defendant's date of birth is 6/7/67. Defendant's place of employment is unknown to Plaintiff. 6. Defendant is Plaintiffs sister. 7. The facts of the most recent incident of abuse are as follows: On or about April 12, 2000, Defendant blocked Plaintiff's vehicle with her own, got out of the vehicle, approached Plaintiff's vehicle, reached inside the window, grabbed Plaintiff by the hair, and pulled her head through the window. Defendant pulled Plaintiff out of the vehicle by her hair and repeatedly punched her in the head. A passerby yelled at Defendant to stop and called the police. Defendant fled the scene. As a result of the incident, Plaintiff suffered swelling and bruising on her neck and swelling under her right eye. The police stated to Plaintiff that Defendant would be arrested for assault, harassment, and filing a false police report. 8. Defendant has committed the following prior acts of abuse against Plaintiff or the minor children: a. On or about February 19, 2000, Defendant sent Plaintiff an e-mail threatening that Plaintiff's daughter might have and accident if Defendant saw her out driving causing Plaintiff to fear for her daughter's safety. b. In or about August 1999, Defendant hit Plaintiff on top of her head with a portable phone. c. Since approximately August 1999, Defendant has abused Plaintiff in the ways including the following: Defendant has made numerous threatening phone calls to Plaintiff and her family causing Plaintiff to fear for her family's safety and change her phone number. On one occasion, Defendant pulled into the driveway of Plaintiff s place of employment of which Plaintiff thought Defendant had no knowledge causing Plaintiff to fear for her safety. 9. The following police department or law enforcement agency in the area in which Plaintiff lives should be provided with a copy of the Protection Order: The Pennsylvania State Police, Mechanicsburg Police, and the Silver Springs Township Police. 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 923 West Trindle Road, which is owned by Plaintiff. 12. Plaintiff has suffered the following out-of-pocket financial losses as a result of the abuse described above: Plaintiff is asking for reimbursement of medical expenses incurred due to the incident of abuse which occurred on or about April 12, 2000. 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 and/or minor children in any place where Plaintiff may be found. B. Order Defendant to stay away from Plaintiffs residence and prohibit Defendant from attempting to enter any temporary or permanent residence of Plaintiff. C. Prohibit Defendant from having any contact with Plaintiff and/or minor children, either in person, by telephone, or in writing, personally or through third persons, including, but not limited to any contact at Plaintiffs school, business, or place of employment. D. Prohibit Defendant from having any contact with Plaintiffs relatives and Plaintiffs children I~~ ' <.'! , , Ii I' II II I: Ii 11 Ii )1 Ii I Ii i! i " I' j: ii I Ii , , ~,.. I listed in this Petition. E. Direct Defendant to pay Plaintiff for the reasonable financial losses suffered as a result of the abuse, to be determined at the hearing. F. Order Defendant to pay the costs of this action, including filing fees, service fees, and surcharge of$25.00. G. Order Defendant to pay $250.00 to reimburse one of Legal Services, Inc.'s funding sources for the cost oflitigation in this case. H. Order the following additional relief, not listed above: a. Defendant is enjoined from damaging or destroying any property owned by the by Plaintiff. b. Defendant is to refrain from harassing Plaintiff's relatives or the minor children. I. Grant such other relief as the court deems appropriate. Order the police or other law enforcement agency to serve Defendant with a copy ofthis 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, ch::@M7 Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 '- ~ i:. I I !:i I" :i 1'.1 1 !'1 !'~ H : d !; I,' i'~ i) I' 1'1 :'~ ': I: !J (; ,I " i 1'1 !J :1 :, II "'I 'l . ,I I. VERIFICATION I verity 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. g4904, relating to unsworn falsification to authorities. Dated: If-;q ~ 00 ~Pl~ '~.&.ll ft .. L-J l ~ ~ 't :.:.--Jlf- !IlI~~~~~UIi~:!lImli~;l;ii!w:t,~~UiliI~Il!~~~' '0 "~ " ~. ~ -0 II' ?~~ en ~:,~: r:~: l::;~c 5~ ~~~ ..0:_, ~? , :[:.1 C) :~'; ':;'::J ,-..J :-.0 c::" -":.. ~C. ,.' {~ , .",,,' , . - &-&",i I; Ii II I' , Kathleen Ann Notz, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-2523 CIVIL TERM Patricia Cugini, Defendant : PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, this ~ day of December, 2002, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on December 18, 2002 at 9:00 a.m. by this Court's Order of December 10, 2002, is hereby rescheduled for hearing on January 17, 2003 at 11:00 a.m. in Courtroom No.4 on the 4th Floor of the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania. The Temporary Protection From Abuse Order shall remain in effect through June 10, 2004, or until further Order of Court, whichever comes first. By the Court, Joan Carey, Attorney for Plaintiff J MidPenn Legal Services '''r;' 1.1> fVJ. r J., . S 8 Irvine Row Carlisle, PA 17013 -rid A. Hess, Judge Patricia Cugini, Pro Se Defendant Cumberland County Sheriffs Office ~, f !"~~'~ ~ ~ 'frWM<!!. ~~ -o'C'" "'~. UlfT OF '-j'CiR' '.~ IthV 02 nr:-C I -t.." 7 (I,'...., ") 11 ,j: r::,.... .j~ CUI'''','' \!j,'"-(c...,''-,' , P~::! ;~,..:! "i0 ("'t., tiVf\!('\';' 1 ,.'-"....,Ui\!7'1 UIL/-I.\j\!l1I ' { ')'1 , ....A1!!I!,1...,..,~o, ,~ . .-m\'f!j\\!~;lm._m"J~_JW~~~I!J'!I1. ~~~! Kathleen Ann Notz, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-2523 CIVIL TERM Patricia Cugini, Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff, Kathleen Ann Notz, by and through her attorneys, Philip Briganti and 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 Temporary Protection From Abuse Order was issued by this Court on December 10, 2002, scheduling a hearing for December 18, 2002 at 9:00 a.m. 2. The Cumberland County Sheriffs Department has not been able to serve Defendant with a certified copy of the Temporary Protection From Abuse Order and Petition for Protection From Abuse because of her hospitalization in a mental health facility. 3. The Plaintiff requests, by and through her counsel, that the hearing be rescheduled. 4. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect through June 10, 2004, or until further Order of Court, whichever comes first. "'\ -..1 ,. WHEREFORE, Plaintiff requests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in effect through June 10, 2004, or until further Order of Court, whichever comes first. Respectfully Submitted, an Carey, Attorney for MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 :r .~ ",J' <~"''''*jjj_i]U "'iliIlIdruI' '""" -- 11"'J]~~~Iii"'; , , '" .~ 1 .~~' ~, ~'" , " ""'.' ',,,<I () ~ l.l'~.., nl~;;'~ :;?-), ~f~,i c;:- d~' .;z s: ~ j;;: ~~-; ~ "";#- :3 -, :;? Ul ~,'""-J '., ;",", <'.~-' '," ~-- CJ N c,::> :--" C") ::) "n .r ':;2 - __J .-" :y '::t:',~ --.",.. .'-"'-- J::;:) >'.:; ".J"; i~-~i(:;~ ;~{ , ".~, ~ I ,~ . SHERIFF'S RETURN - NOT FOUND CASE NO: 2000-02523 P COMMONWEADTH.OF PENNSYLVANIA COUNTY OF CUMBERLAND NOTZ KATHY ET AL VS CUGINI PATRICIA R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT CUGINI PATRICIA but was unable to locate Her in his bailiwick. He therefore returns the PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER, TEMPORARY ORDER, PETITION AND CONTINUANCE ORDER , NOT FOUND , as to the within named DEFENDANT , CUGINI PATRICIA DEFENDANT IS NO LONGER AT HOLY SPIRIT REHAB. HUSBAND STATES DEFENDANT IS NOT AT THE RESIDENCE. Sheriff's Costs: Docketing Service Not Found R~turn Surcharge ~ R. Thomas Klin Sheriff of Cumberland County 18.00 6.90 5.00 10.00 .00 39.90 00/00/0000 Sworn and subscribed to before me this .1.1 ~ day of ~ :J..irV2.J A.D. ~(). ~,JPu #' P 0 honotary , I .L.: 'le , i: , L I. F ]. ], I I I I r i~, " Kathleen Ann Notz, Plaintiff : IN THE COURT OF COMMON PLEAS OF vs. : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-2523 CIVIL TERM Patricia Cugini, Defendant : PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER YOU HA VB BEEN SUED IN COURT. If you wish to defend againstthe claims set forth in the foilowing papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on this matter is scheduled on the I ~1hday of December, 2002, at OJ \00 a. .m., in ~ lli - Courtroom No. on the 4 Floor of the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania. 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. g6ll4. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. g2265, 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. 9 2261-2262. You should take this paper to your lawyer at once. You have the right to have a lawyer represent you at the hearing. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. If you cannot find a lawyer, you may have to proceed without one. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, Pennsylvania 17013 Telephone Number: (717)249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information 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. ,. , , > ~.! , r i I.. f! L I 1 1 , f'; :i: L 1 Kathleen Ann Notz, Plaintiff : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYL V ANlA t I, I' I, I' I' I, Patricia Cugini, Defendant : No. 00<!523 ~: I I i ii ii 1 I': f' r v. : CIVIL ACTION - LAW : PROTECTION FROM ABUSE r r ~i f' I, I': t t t; TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Patricia Cugini I I" fj ~! Defendant's Date of Birth is: June 6, 1967 Name(s) of All protected persons, including Plaintiff and minor children: 1. Kathleen Ann Notz AND NOW, on 10th Day of December, 2002 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: Plaintiffs request for a temporary protection order is granted. 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. 2. Defendant is prohibited from having ANY CONTACT with Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at Plaintiffs school, business, or place of employment. 3. Defendant shall not contact Plaintiff, or any other person protected tmder this Order, by telephone or by any other means, including through third persons. " , , '~ ~, il,!'1 4. The following additional relief is granted: - Defendant is prohibited from having any contact with Plaintitl"s relatives. - Defendant shall not damage or destroy any property owned by Plaintiff. 5. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Silver Spring Townhip Police Department Middlesex Township Police Department 6. The sheriff, police or other law enforcement agencies are directed to serve the Defendant with a copy of the Petition, any Order issued, and the Order for Hearing without prepayment of costs. The Petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. The Prothonotary is directed to file this Petition and Order without prepayment of costs. 7. TIllS ORDER APPLIES IMMEDIA TEL Y TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL JUNE 10, 2004 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY TIllS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months injail. 23 Pa.C.S. g61l4. 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. g6113: 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. 99226l- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiffs residence OR any location where a violation ofthis order occurs OR where the defendant may be located. If defendant violates Paragraphs 1 through 3, of this Order, defendant shall 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 ~ I" <;;: threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriffs office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this court, unless the weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. BY THE COURT: /S/ Ie tv I h A. li.:es..L Judge Dff f'VVl h ff \ 0 I <-CD .z. Date Distribution to: Legal Services Faxed & Mailed to PSP TRUE COPY FROM RECORD ,n TestlrnOJIy wheIOOf, I here unto set my hanG ~nd of" at CarliSle, Pa.. ...., ").. CHI)..., 11M " rv " PFAD Number: FC1593559N Kathleen Ann Notz, Plaintiff : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYL V ANlA v. Patricia Cugini, Defendant : No. : CIVIL ACTION " LAW : PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE 1. Plaintiffs name is: Kathleen Ann Notz 2. I, (the Plaintiff), am filing this Petition on behalf of: - myself 3. Name(s) of ALL person(s), including minor children, who seek protection from abuse. a. Kathleen Ann Notz 4. Plaintiffs Address is: 222 Texaco Road, Mechanicsburg, PA 17055 5. Defendant's Name is: Patricia Cugini 6. Defendant is believed to live at the following address: 1300 Trindle Road, Carlisle, P A 17013 7. Defendant's Date of Birth is: Jnne 6, 1967 - ~.,,'j 8. Defendant's Place of employment is: unknown 9. Defendant is an adult. 10. The relationship between the Plaintiff and the Defendant is: Brother I Sister II. The Plaintiff and the Defendant been involved in the following court actions: a. Protection From Abuse 12. Other details of the court action are: Protection from Abuse fIled in Cumberland Connty May 2000 13. The defendant has been involved in a criminal court action. 14. The facts of the most recent incident of abuse are as follows: On or about November 29, 2002, Defendant sent Plaintiff instant e-mail messages threatening to come to Plaintiffs residence with a baseball bat and "take it" to Plaintiffs legs. Defendant further threatened that she will be in jail for murder and and that she would try for Plaintiffs head. 15. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor child/ren, (including any threats, injuries, or incidents of stalking) are as follows: In or around October 2002, Plaintiff sent a letter to Defendant asking that Defendant not contact her at home or at her place of business. In or around April 2000, Defendant followed Plaintiff from her work place in her car and cut Plaintiff off with her vehicle. Defendant jumped out of her car, glrabbed Plaintiff by the hair and pulled her partially through the window, Plaintiff ended up on the ground and Defendant repeatedly strnck her with her fists. Defendant then went to the police and fIled a false report. Defendant was eventually charged with filing a false report and simple assault. Plaintiff required medical treatment as a result of this incident. Defendant is bi-polar and has a history of violence. As a result of Defendant's history and current state of mind, Plaintiff fears for her personal safety. I J. ~I 16. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: Silver Spring Townhip Police Department Middlesex Township Police Department 17. There is an immediate and present danger of further abuse from the Defendant. 18. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or minor childlren in any place where Plaintiff may be found. b. Prohibit Defendant from having any contact with Plaintiff and/or minor child/ren, either in person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Plaintiffs school, business, or place of employment, except as the court may fmd necessary with respect to partial custody and/or visitation with the minor child/ren. c. Prohibit Defendant from having any contact with Plaintiffs relatives and Plaintiffs children listed in this petition, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/ren. d. Order the following additional relief, not listed above: Defendant shall not damage or destroy any property owned by Plaintiff. e. Grant such other relief as the court deems appropriate. f. Order the police or other law enforcement agency to serve the 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 the Defendant's residence, where Defendant can be served. Respectfully submitted, Date: /02/ It) / () d.....- I I hiiip C. Briganti, Atto y for Plaintiff Joan Carey, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 VERlFICA TION "II .1 ,I II II 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.g4904, relating to unsworn falsification to authorities. Dated: 19~/O~Od <fJ{1UJL&N fhn '^;5. Kathleen Ann Notz, Plaintiff ,.,' ..., ~~~ \bDd1 ~ W1 ~ ( f' ;:'4'.::r ~ ' , ".'~'qrFr ..":HY DEe I J ; IC; F ~ . , " ihoi' . Kathleen Ann Notz, Plaintiff : IN THE COURT OF COMMON PLEAS OF v. : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00-2523 CIVIL TERM Patricia Cugini, Defendant : PROTECTION FROM ABUSE ORDERFORCONT~ANCE AND NOW, this 11g,,- day of December, 2002, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on December 18,2002 at 9:00 a.m. by this Court's Order of December 10, 2002, is hereby rescheduled for hearing on January 17, 2003 at II :00 a.m. in Courtroom No.4 on the 4th Floor of the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania. The Temporary Protection From Abuse Order shall remain in effect through June 10, 2004, or until further Order of Court, whichever comes first. By the Court, l/ 11{..,~ C. /~ evin A. Hess, Judge Joan Carey, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 Patricia Cugini, Pro Se Defendant Cumberland County Sheriffs Office 'TPlf?, v ~ '" ""_".".'" ! n T}~Ufnl1~Y h2r~d 1ho S8i~ of sakt Cf;it'{~ ~~.!~ \:;;;;L~ f':8'!;'~, Thili 17~ ~ay afI A0N+ 02~.:v ~_:.!.-,-Q ~ ~ PTothOnotlftl I-~I~ ",I L I I I , I I [, [ I I, ~ . Kathleen Ann Notz, Plaintiff : IN THE COURT OF COMMON PLEAS OF v. : CUMBERLAND COUNTY, PENNSYLV ANlA : NO. 00-2523 CIVIL TERM Patricia Cugini, Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff, Kathleen Ann Notz, by and through her attorneys, Philip Briganti and 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 Temporary Protection From Abuse Order was issued by this Court on December 10, 2002, scheduling a hearing for December 18, 2002 at 9:00 a.m. 2. The Cumberland County Sheriffs Department has not been able to serve Defendant with a certified copy of the Temporary Protection From Abuse Order and Petition for Protection From Abuse because of her hospitalization in a mental health facility. 3. The Plaintiff requests, by and through her counsel, that the hearing be rescheduled. 4. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect through June 10, 2004, or until further Order of Court, whichever comes first. I_ ,I,; . . . WlIEREFORE, Plaintiff requests that the Court grant this Motion and reschedule i, [ L' (, this matter for hearing, and that the Temporary Protection From Abuse Order remain in f , [' effect through June 10, 2004, or until further Order of Court, whichever comes first. r Respectfully Submitted, r v"-../@~.e.... // an Carey, Attorney for intiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 i 1 I I I f t I i i !, II! ~ ~~.... ?<;. .' e>fTWf ,crc'" ".\Mlf\> 'i'-'."" .. - ^~."'1"f't n~t l~ LOR f\\UL PE1{ Ii Jl L"'> ,;i.; \ A . . .< , ~. /~ ,~ .., ~. ~ ,.....'- ~ ^, - SHERIFF'S RETURN - REGULAR CASE NO: 2000-02523 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NOTZ KATHY ET AL VS CUGINI PATRICIA JASON VI ORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon CUGINI PATRICIA the DEFENDANT , at 1110:00 HOURS, on the 12th day of February, 2003 at 104 S SPORTING HILL ROAD MECHANICSBURG, PA 17055 by handing to PATRICIA CUGINI a true and attested copy of PROTECTION FROM ABUSE together with ~ \ \ \ l (' and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 6.90 .00 10.00 .00 34.90 "" ,<':~" !!",~",.-: /.,0:';'" .f1:;;~_1 ",~:~j2:,><:h.: ;-:~:,~-,< , R. Thomas Kline .".' ;,y"'/-7. -,. :,?-'._", "I'~ .,,-'~ 02/12/2003 LEGAL SERVICES Sworn and Subscribed to before By: ~ ty Sheriff h. cV me t lS A7- day of J:i:!: "''''-' A.D. '.L..o (2 /h,;a..; prothonotary'~ .. "J " ~ . Kathleen Ann Notz, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLV AN:*R 1 ~ v. : NO. 00-2523 CIVIL TERM Patricia Cugini, Defendant : PROTECTION FROM ABUSE ORDER FOR HEARING AND NOW, this /,.... day of March, 2003, upon consideration of the attached Motion for Hearing, the matter continued generally by this Court's Order of January 13, 2003, is hereby rescheduled for hearing on April 2, 2003 at I :30 p.m. in Courtroom No.4 on the 4th Floor of the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania. The Temporary Protection From Abuse Order shall remain in effect through June 10, 2004, pending a hearing in this matter. By the Court, Margaret M. Simok, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 Patricia Cugini, Pro Se 1301 Trindle Road Carlisle, PA 17013 - A:..~ ~ .3-//-03 ~ I ~ . ~ o ~ ~~"~ _, OF ~:, l'13' 1~,1"r' t L"l: ~ ".~, ..~,~~., '~-,I",' "', " -', " ",.", ,. rLFt: '~;;:-FjCE "I"; Ir',',!""r,jn'l( " :,) iJ~ti PH 2: ? 1 ., C' "~i .' .... . ..~. 0i",::::!";:1 .':"'..":" .,iI../ ( i 'u' fr-Ji,\i' ..._ ' ",,"J j" 1 j-!tNNSYLVANIA 4 - 1, ~ "~ ~<_ ".,~"~,~~' l" ~~ ~1!'!ffJ'.f"!"-'!~"!\""''''''''f1Ii!/M ..~ ~'.. . ,~ I 1!MJJf!1Ml1M~r~~,~tml~m!l;/l~< '1~ ".' . . , Kathleen Ann Notz, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00-2523 CIVIL TERM Patricia Cugini, Defendant : PROTECTION FROM ABUSE MOTION FOR HEARING Plaintiff, Kathleen Ann Notz, by and through her attorney, Margaret M. Simok of MidPenn Legal Services, 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 December 10,2002, scheduling a hearing for December 18, 2002 at 9:00 a.m. That hearing was rescheduled the hearing for January 17,2003 at 11:00 a.m. On January 13,2003, subsequent Order of Court, continued the matter generally. 2. The Cumberland County Sheriffs Department served Defendant with a certified copy of the Temporary Protection From Abuse Order and Petition for Protection From Abuse and subsequent continuance orders on February 12, 2003. 3. Defendant indicated to MidPenn Legal Services staff on March 10,2003, that she desired a hearing in this matter. 4. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect through June 10, 2003, pending a hearing in the matter. ~ J " WHEREFORE, Plaintiff requests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in effect through June 10,2004 pending a hearing in the matter. Respectfully Submitted, MIDPENN LEGAL SERVICES BY: ~ /'YL~ Margar M. Slmok, Attorney for PlamtIff 8 Irvine Row Carlisle, PA 17013 :;:~~'~"'- ~ ~ ... ....,-~~~~<."';"".,bM~::U1IIJlWllillliillliiill-'-.'~--~~ ~" . (') ~ v(~f rn'-' ~:.:i &12:- ~CC. )'?:- ~~ -< -, ~,".~, .~~~, "~~ ~".~ ",:1 C) V) q Z ?.,:"" ;;0 -j', - '1--- . 1.~'l ~il~ 07,---l ;j~~ ._.f ~.' ~ "V ~ !'.) (]'\ - ~h l . - .. KATHY NOTZ,FOR HERSELF AND ON BEHALF OF HER MINOR CHILDREN, KELLY, JESSICA, TAMMY, AND DANIEL NOTZ VS. :IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, PENNSYLVANIA :NO. 00 - 2523 CIVIL TERM PATRICIA CUGINI, DEFENDANT :PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, this ttkday of May, 2000, upon consideration of the attached Motion for Continuance, the matter continued scheduled for hearing on May I, 2000, by this Court's Order of April 24, 2000, is hereby rescheduled for hearing on May 22, 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. Edgar B. Bayley, Joan Carey _ LEGAL SERVICES, INC.- (~ a.-/k'!.. 12/k..-.._ t1f Attorney for Plaintiff dI" ~ -- / - m r7 FAMILY LAW CLINIC - "11~ ~ Attorney for Defendant ( - "jj ~ ~ KATHY NOTZ,FOR HERSELF AND ON BEHALF OF HER MINOR CHILDREN, KELLY, JESSICA, TAMMY, AND DANIEL NOTZ VS. : IN THE COURT OF COMMON PLEAS :OF CUMBERLAND COUNTY, PENNSYLVANIA :NO. 00 - 2523 CIVIL TERM PATRICIA CUGINI, DEFENDANT :PROTECTION FROM ABUSE MOTION FOR CONTINUANCE The Plaintiff, Kathy Notz, 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 April 24, 2000, scheduling a hearing for May I, 2000, at I :30 p.m. 2. The Cumberland County Sheriffs Department served Defendant with a certified copy of the Temporary Protection From Abuse Order and Petition for Protection From Abuse at the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania, on April 25 , 2000, at 12:06 p.m. 3. The Defendant has retained the Family Law Clinic to represent him in the matter and they have requested that the hearing scheduled for May I, 2000, be continued. 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. Ji! ~'I I , . 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, ~y, Attome or Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 _:.~~lllr'""'"-""""'--06 _ . vI. .~,,~ ,~'".~ ~=",__ ,~.e ,~. ,"~, ~,~ "~, ~ '->-'~"~_M<li~,~~""!tI~'-'"-" "'"'-"" uki' ~ " .... ~. . ~ . -5Il:11 - () f; "'tJ-~, nl('J) ;::r.p :2:P O)p. ~.'- r-<- :=:::.0 :!J C) ;i;:o C < ::< ~~~....... "" . a <:::> ?: ~l..,.. -<: I .c- "'t1 :::c: ,'\j '. :;;;; "~j1 '-r1:D }J@ '""C -:.... ! ...., -t _~ ';.J::ri 0...,) ?'C) am $ -<; - {N . . ';:1 iil I!! Iii ,:1 , :'i ii " :1 :1 i!1 "I il I.'!I Ii i' i:,1 III' '...' if, !tl IIJ ~:j i!,l i:'! ill I:'! II if: i:'1 I.! I .:1 il :I'i "Ii .:1 il i:,1 {i II rl 1'1 [I "I II i l 'I ., :1 II " II ~i u ,I ~ Kathleen Ann Notz, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA . v. : NO. (Xl-2523 CIVIL TERM Patricia Cugini, Defendant : PROTECTION FROM ABUSE ORDER FOR GENERAL CONTINUANCE AND NOW, this j:Jwt day of January, 2003, upon consideration of the attached Motion for General Continuance, the matter scheduled for hearing on January 17, 2003 at 9:00 a.m. by this Court's Order of December 17, 2002, 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 through June 10, 2004, or until further Order of Court, whichever comes first. By the Court, v?hilip Briganti, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 Patricia Cugini, Pro Se Defendant Cumberland County Sheriffs Department L~ fi't RXS o }-I'I-03 """,I ..,,", .~ 'w J. ~. . .. VINl]i\lASNN3d ,W\InO~} (11,,;",:r~~~~8V1!n8 L' U. '8 1,1':1 h I idFI.' ('0 . , '" '. I '~ \tf t.~ ' 1U1-l!(",;..!r",',:', " ^O\.,;.,);\J\,/J d,'y"_ _ :J8t~,:JC1-{'J].llj :;0 I" 1 I, ,I Ii , .. , I' , Kathleen Ann Notz, Plaintiff : IN THE COURT OF COMMON PLEAS OF ~ ' '1: i I , I , I I I, I 'I I, II id I! 1:.1 II :'.1 '-' Ii I" [I 1.1 il 11 H II I; u i!j i: I'j ;1 q 11 II ,I :1 ,i ~ II [j II I' II II \.1 tl " il ,I II : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 012-2523 CIVIL TERM Patricia Cugini, Defendant : PROTECTION FROM ABUSE MOTION FOR GENERAL CONTINUANCE Plaintiff, Kathleen Ann Notz, by and through her attorneys, Philip Briganti and Joan Carey of MidPenn Legal Services, moves the Court for an Order continuing generally the hearing in the above-captioned case on the grounds that: 1. A Temporary Protection From Abuse Order was issued by this Court on December 10, 2002, scheduling a hearing for December 18, 2002 at 9:00 a.m. On December 17, 2002, subsequent Order of Court rescheduled the hearing for January 17, 2003 at 11:00 a.m. 2. The Cumberland County Sheriffs Department has been unable to serve Defendant with a certified copy of the Temporary Protection From Abuse Order and Petition for Protection From Abuse and Continuance Order. 3. Plaintiff desires that the hearing be continued generally pending further Order in this matter. 4. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect through June 10, 2004, or until further Order of Court, whichever comes first. 'U' " . WHEREFORE, Plaintiff requests that the Court grant this Motion and continue this matter generally and that the Temporary Protection From Abuse Order remain in effect through June 10, 2004, or until further Order of Court, whichever comes first. Respectfully Submitted, . ip Briganti, Attorney Joan Carey, Attorney for MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 Plaintiff aintiff ;~~" ~ , - ,^-",,,',-,',' .' "'" ~"'"""f_llil!iit;>Oii<ll-'_~liO!o......j ~,~ ~.'~ , i"~>" ".,',",>., "".~ ~~ '"'"" ~ "," , o C <':" l:J{:'::"O: rn~:; 2:r,j' bSs-: ~c~; ~ {--. ~(-< >c: :z :::;;J , "," w ~ t;;, ':::> h.o "'-,",' " o W L. ~ (;) -., ::[1 !I i ~'"1"'j - ::82] ',i:~) L ,~() i~~ ~~ , f~/ . ~.I' SHERIFF'S RETURN - REGULAR CASE NO: 2000-02523 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NOTZ KATHY ET AL VS CUGINI PATRICIA JODY SMITH , Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon CUGINI PATRICIA the DEFENDANT , at 0012:06 HOURS, on the 25th day of April , 2000 at CUMBERLAND CO. SHERIFF'S DEPT 1 COURTHOUSE SQUARE CARLISLE, PA 17103 by handing to PATRICIA CUGINI a true and attested copy of PROTECTION FROM ABUSE together with NOTICE OF HEARING & ORDER, TEMPORARY PROTECTION FROM ABUSE ORDER and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 6.20 .00 10.00 .00 34.20 So Answers: r~~e R. Thomas Kline 04/25/2000 Sworn and Subscribed to before By: ~a~ ~~ De ty Sheriff me day of - " . .. Kathleen Ann Notz, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-2523 CIVIL TERM Patricia Cugini, Defendant : PROTECTION FROM ABUSE ORDER OF COURT AND NOW, this Z 11' day of April, 2003, the Temporary Protection From Abuse Order in the above-captioned case entered on December 10, 2002, is hereby vacated and the action withdrawn without prejudice to Plaintiff. A certified copy of this Order shall be provided to the Police Department by Plaintiff s attorney. By the Court, Margaret Simok, Attorney for Plaintiff MidPenn Legal Services - 1:\ 0..'-.) IYE.I:;:\ 8 Irvine Row PeR~of\ol\lY Carlisle, PA 17013 0 fl\~ ;> 4 -:).3 ~(J3 R~ 0'atricia Cugini, Pro Se Defendant 130 I Trindle Road Carlisle, PA 17013 ~'kecl to ~S~ ~~ C1p ,--",,'! "I 'I ;:1 :! " 1:1 1 ,J! ,I \1 :'i :1 " !',i 'I ~I !11 ! :;1 ij 'i! , " '" ii ,;: ,I' it! " " " ';1 11 ':1 1i Ii ~ II 11 \! )1 rr FlLE"cr<Jf8CE .... . OF TH~ p::()TC'"",m,A.RY 03 ~PR 23 PH3: 29. CUM8ERUJ'D CQUNTY PENNS'l'lVANlA , W- 04/23/03 WED 15:21 FAX 717 240 6573 *************************** u. MULTI TN REPORT ... *************************** CUMB CO PROTHONOTARY I~ - 14/001 TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 3820 ERROR [ 01J9p2490779 [ 03J9p2405331 [ 04192438026 PSP CP LS ,I." . '- / ( OFFICE OF THE PROTHONOTARY CUMBERLAND COUNTY COURTHOUSE ONE COlm.THOUSE SQIJARE CARLISLE, P A 17013 - 3387 (717)240-6195 FAX (717) 240- 6573 VIA TELECOPIER " 11 J" i Ii Ii TO: PA STATE POLICE - CENTRAL PROCESSING MIDPENN LEGAL SERVICES FAX # FROM: CURTIS R. LONG FAXING APFA RE: MESSAGE: 2 NO. OF PAGES (INCWDING COVER SHEErs) This message is intended for the use of the individu~l or entity to which it is ~ddressed, and it may conrain Information thaI is privileged, confidential and exempl from disclosure under applicable law. If the reader of this message is nOI the inlended recipient, you are hereby notified that ~ny dissaminll.tion, distribution or copying ofthi. con1Illunicll.tion is s\lictly prohibited. Uyou have received this communication in error, please notifY US immediately by telephone and return the original message to uS at the above address via the ." . "'("1.......1. "^U