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HomeMy WebLinkAbout00-02835 - , ., . J,'" , ~., ~""" >',' , Robert Allen Hanes, Plaintiff/Petitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-2835 CIVIL TERM Patty Ann Hanes, DefendantJRespondent CIVIL ACTION - LAW IN DIVORCE RULE f\A - 01"",-,,- AND NOW, this L day of r -v - 7J , 2001, upon revIew and consideration of PlaintifflPetitioner's request for Special Relief, tl ~ ,J~ ;0 1._.~-L::r;::~l;;r~J UI'Ull c:;.. ~ r;I:........,.; 'S .,,,.,, to.... J.r,.., /IlL___ f ~o 0 ~ .. Q"fblld.au~nSgF\lRdg.Rt -=- r-- ____ .. tI,~ I"tr ~p a ..-- '0(> c,;t I!i!!/j",,,.,...... ~ .S"' ~ --,) OA "'If I , ~ r- ;, 17'?J 1- . 0. ,$:;~ ' RULE RETURNABLE M.. dn:'. JT~1Wtf.,~ ~tll_ vi o_.~, ~ - . 1IU1II../AI~ ~'hlL: 1l1I1/t ,}. (- ).3 ,J.oa I @ ,,: (Jd II.",. J I .cJ ffZ ,D \ ~ -? l?tc;~ If O'l- A: bI' U"" q:!') " , 1 I \ "--<~ c".. ~ '1:~ h, C; "J' \_'"'" CUj\j:iC5t,HLl\\'.--lU CUUNT'( PENNSYl.\fJl.NII\ I I j",,,,,~ .......]liIill ~~..~1"" .,>?-""'" ~,' mml__ - '" 1l11!"11l'l!_~ " '~'~'I'"'-~ """,' - _'-_<.- "~'-"_'OA" -___ ':"-1 Robert Allen Hanes, PlaintifflPetitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-2835 CIVIL TERM Patty Ann Hanes, DefendantJRespondent CIVIL ACTION - LAW IN DIVORCE NOTICE You have been sued in Court. If you wish to defend against the claims set forth in the following papers, you must take prompt action, You are warned that if you fail to do so, the case may proceed without you, A judgment may also be entered against you for any other claim or relief requested in these papers by the Plaintiff. YOU SHOULD TAKE TillS PAPER TO YOUR LAWYER AT ONCE. 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 Robert Allen Hanes, PlaintifffPetitioner V. NO. 00-2835 CIVIL TERM IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA (') 0 0 C...::: --1'1 1] ft' ri "-:-1 11 r"'" "'.'J - :.'1 ,~!:~ ::::;:,',.',:-,i IN.;~ , ~:);I; ~.'~,! ~~ 0 l~ ~~~ ~ -::J .j~ ~~'l --- '.-.-~?'"') N :~l~ =' ~ .--1 =< Patty Ann Hanes, Defendant/Respondent CIVIL ACTION - LAW IN DNORCE :~;t: PETITION FOR SPECIAL RELIEF PURSUANT TO 23 Pa.C.S.A. SECTION; "'- 3323(1) OF THE DNORCE CODE AND PENNSYL VANIA RULE OF CIVII:;! PROCEDURE 1920.43(a)(3) TO THE HONORABLE JUDGES OF THE SAID COURT: Petitioner, Robert Allen Hanes, by his undersigned attorney, files this Petition for Special Relief in order to preserve and protect his ability to remain gainfully employed and free from Respondent's slanderous interference and in support of the Petition respectfully represents that: 1. Petitioner, Robert Allen Hanes, is the plaintiff in this divorce action. 2. Respondent, Patty Ann Hanes, is the defendant in this divorce action. 3, The parties are husband and wife having been married on September 12, 1983, in Steelton, Pennsylvania. 4. The parties have since separated and reside in separate residences. 5. This action was commenced with the filing of a Complaint in Divorce on April 26, 2000, in which Robert Allen Hanes included claims for, inter alia, a divorce on the grounds set forth at Section 3301(c) of the Divorce Code, 6, On June 9, 2000, Respondent filed an action in support to corollary docket number 00- 2590, PACSES number 302102387/D29,768. 7. On August 16, 2000, the support conference was held and an Interim Order of Court for support was entered awarding Respondent a total amount of $730.00 per month effective July 1, 2000, with $662.00 per month as support for the parties' two (2) children and - ~. - -, - ~'- ~~ 11; $68.00 per month towards arrears, 8. Subsequent to the conference, Petitioner lost his employment with Inclinator Company of America. 9, Petitioner had been diligently seeking new employment since losing his sales position with Inclinator Company of America. 10. Petitioner was successful in obtaining gainful employment with ADT Security Systems and commenced his new sales position on or about the beginning of the New Year, 11. Respondent has attempted to undermine and compromise Petitioner's livelihood by engaging in a malicious, capricious and slanderous attack upon Petitioner's person. 12, On or about February 15, 2001, Respondent contacted Petitioner's employer by telephone and stated that: a. Petitioner is a criminal; b, Petitioner has served jail time; c. Petitioner is abusive; and further inquired: d. Whether Petitioner's employer was aware of Petitioner's background; and e. How could Petitioner's employer have hired him. 13, Throughout this entire matter, Respondent has engaged in a deliberate course of conduct aimed at undermining Petitioner in every regard. 14. Respondent has engaged in a campaign of publicly defaming and destroying Petitioner's reputation at every juncture. 15. In other instances throughout the course of this divorce action, Respondent has attempted to further destroy Petitioner's reputation by engaging in a letter writing campaign bolstering her own person and discussing the parties' domestic proceedings; has contacted Petitioner's friends directly and has investigated Petitioner's friends, 16, The parties have satisfied all marital debts, 17. Distribution of the parties' marital assets has not been resolved. , . ~ . ~ 18. Petitioner has a continuing support obligation as noted above in preceding paragraphs six (6) and seven (7). 19, Pursuant to Section 3323(t) of the Divorce Code, your Honorable Court has "full equity power and jurisdiction and may issue injunctions or other orders which are necessary to protect the interest of the parties or to effectuate the purposes of this act, and may grant such other relief or remedy as equity and justice require, . . ," 20, Pursuant to Pa, R.C.P, 1920.43(a)(3), your Honorable Court has the authority to enjoin Respondent from further any further contact with Petitioner, Petitioner's family (see attached Exhibit A), Petitioner's friends and Petitioner's business relationships and contacts; more specifically, 1920.43(a)(3) provides: (a) At any time after the filing of the complaint, on petition setting forth facts entitling the party to relief, the court may, upon such terms and conditions as it deems just, including the filing of security, (3) grant other appropriate relief, 21. The relief sought by Robert Allen Hanes: a, is necessary to protect his livelihood; b, is necessary to effectuate the purposes of the Divorce Code; c, is required by equity and justice; and, d, is necessary in order for Petitioner to continue to meet his support obligation to Respondent. 22, Patty Ann Hanes has evidenced her intent to ultimately destroy the financial condition of Petitioner as well as his reputation. 23. Robert Allen Hanes has no adequate remedy atlaw. 24, Robert Allen Hanes will suffer irreparable harm, financial and otherwise, unless Patty Ann Hanes is enjoined from and sanctioned for engaging in her deliberate, malicious and slanderous attacks upon Petitioner. 25, Pursuant to Section 3323(t) of the Divorce Code, the relief sought by this Petition can be fairly and eXpeditiously determined and disposed of in this action, " , WHEREFORE, Petitioner, Robert Allen Hanes, respectfully requests your Honorable Court enter an order directing: A. Patty Ann Hanes to be enjoined and restrained from discussing Petitioner with any party of any nature by any means of communication whatsoever; B. that Patty Ann Hanes be ordered to pay to Petitioner his reasonable counsel fees which were incurred for prosecuting this Petition; and, C, such other relief as this Court may deemappropriate. Respectfully submitted, , er, Esquire 2010 Mar Street Camp " PA 17011 (71 37-6400 ttomey for Petitioner '_I "':"'''''J '" '" ''', ~ '_' '_J: ~__~ -_~.::'~"-' r ~~":~':'r :'~ - .."",,-j . . , ' July 26, 2000 Mr, & Mrs. Charles Hanes II 4 Fox Run Hummelstown, P A 17036 Mr, & Mrs. Hanes, , Please be advised that this letter is to serve as notification to you that you are not permitted to trespass on my property at 328 Blacklatch Lane, Camp Hill, Lower Allen Township, or at my new residence at 349 Blacksmith Road, Camp Hill, There is no legitimate reason for you to come to 328 Blacklatch Lane for the next two weeks, As you already knew, Bob had all of his mail forwarded to a post office box months ago. Any tampering with the Federal mail addressed to the children or myself will be reported to the authorities, Bob has already removed more marital assets than any reasonable person could believe he would be entitled, If you enter my home, I will consider it harassment and an attempt to steal property, and will notify the police of your actions, I have endured many abuses from your son, I will not tolerate any from your or your immediate family, Sincerely, / dJubftJ {JJ. ~ Patricia A. Hanes CC: Sam Andes James Miller Lower Allen Police Dept. G:\Salcs AgenlS\PallY Hancs\]etter & memos\Hancs Family Trespass Haras Letter 7.26-00,doc EXHIBIT A ~I VERIFICATION I verify that the statements made in the attached complaint are true and corr~t. I understand that false statements herein are made subject to the p.ti!S of 18 Pa.C.S, Section 4904 relating to unsworn falsification to autnontles. ./J.i4 14 ~~I Date: r I fl-/f ili'j/YIu> Robert Allen Hanes ~ . , . , .~ , . . ,.. ""=', _ -- " Robert Allen Hanes, PlaintifflPetitioner IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 00-2835 CIVIL TERM Patty Ann Hanes, DefendantIRespondent CIVIL ACTION - LAW IN DIVORCE CERTIFICATE OF SERVICE I, James A, Miller, Esquire, hereby certify that on the date indicated below I forwarded a copy of the foregoing PETITION FOR SPECIAL RELIEF to the persons and on the date and in the manner indicated below. DATE: fv~'1 hJ)A!U! UNITED STATES FIRST CLASS MAIL, POSTAGE PREPAID Samuel L. Andes, Esquire 525 N. Twelfth Street P.O, Box 168 Lemoyne, PA 17043 Date: / James A. 'er, Esquire 2010 ket Street p Hill, PA 17011 (717) 737-6400 Attorney for Petitioner " ~ ~t 'f) , , , . L-~'- " ,-.,-,,-.' ,'_-'L ,.-",' ".-" , ... ROBERT ALLEN HANES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW 00-2835 CIVIL TERM PATTY ANN HANES, Defendant IN DIVORCE IN RE: PETITION FOR SPECIAL RELIEF ORDER OF COURT AND NOW, this 2nd day of August, 2000, by agreement of the parties, it is hereby ordered and directed as follows: I. Neither party shall transfer or otherwise dispose of any marital personal property without the express consent of the other party or order of this Court, 2. Plaintiff shall return the Longaberger baskets and Hummel figurines to Defendant by August 15th, 2000. 3. Neither party shall transfer, encumber or otherwise dispose of any investment or retirement account or any proceeds thereof without the written consent of the other party or order of this Court. Those accounts include, but are not limited to, the following: a, Plaintiff's 401K and pension plan with Inclinator Company of America. b. The parties' IRA's held by Hanke and , =~-'> '^' c -'.. '0-__' ,~ _~, ~ Hanes. This consent order disposes of all issues raised in the petition for emergency relief filed by defendant. By the Court, Samuel L. Andes, Esquire EdW~' J. Y _'~~O l<< 'b~ James A. Miller, Esquire :mae iiIi..-l. J,,;...,~ "".__~~,.....,""", _~'~~ fE ...:r ~ <l: ""~ \5 e. 6~ w~ o~ C>c ;C P.=-'" ..a:: G~ ~ ~- C),.-- ;!:)Q r- 32 e~ I UJCL ffia1 fi::u.'t (.!l --~ ~ ro-o.. ~ ~ 1"-- 11... <:::> '3 0 <:::> ... II ':'!liiitlI - ~-i<ilj__~""""- Ilfj'~'7'. 'iiI~r'. b _ U~. .....,,,,.".;,, , ~ "~-.iJ;l , " .. ROBERT ALLEN HANES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, CIVIL ACTION - LAW PATTY ANN HANES, Defendant NO, 2000-2835 CIVIL TERM IN DIVORCE ORDER AND NOW this;' rth day of l.)/.I..j'/ , 2000, upon consideration of the attached Petition for Emergency Relief, a hearing is scheduled before the undersigned commencing at.,1; L/-.5 o'clock _?_,m, , in Court Room No. S of the Cumberland County Court House, Carlisle, Pennsylvania, on W~E-~dFlY ,the olio,,' day of A1161.t!f ,2000, BY THE COURT, J, E"ell.4.//f d E. t: 4.<" A'd ,J . 0 , l' ",J ' { s c{ . ~ 11l) }W/.1'i 1~ &. . I uz.... f., 1-)- II >J., J~ j (Y';) ) COl)lr ~.p'~{>\{'I\v~A' ~p~ m~tblc ;!~/oo - -" 'lI __ 0 ,~~ ~'.~, - CU Jut 3 3:n9 ,"'.;' ,....." 'IH~.i:'''::'C,: ,\:.> , l-'('l;u\.n" V\... 1'.1\.....' ,l..../".' ~I._j ;v I 'J 1 1 PEr~i'-1SYL'Ji\N\i\ . lfiIli!1"".,. ~ '''~~~'''~~~" .:,""",,"-III!II\!! " . ROBERT ALLEN HANES, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs, CIVIL ACTION - LAW PATTY ANN HANES, Defendant NO, 2000-2835 CIVIL TERM IN DIVORCE PETITION FOR EMERGENCY RELIEF AND NOW comes the above-named Defendant, by her attorney, Samuel L, Andes, and petitions the Court for emergency relief in this matter, based upon the following: 1, The Petitioner herein is the Defendant, Patricia Ann Hanes, The Respondent is the Plaintiff, Robert Allen Hanes, 2. The parties have been married for more than 15 years and are the parents of two minor daughters, Prior to the separation of the parties in June of 2000, both of them and the children resided in the family residence at 328 Blacklatch Lane, Camp Hill, Pennsylvania, 3. Defendant left the marital home with the two children in June of 2000 because the children could no longer tolerate the Plaintiff's conduct toward Defendant and the children, At the time of the separation, Defendant did not have a permanent place to live and had to impose upon friends and family to house herself and the children, COUNT I - POSSESSION OF HOUSEHOLD ITEMS 4, Defendant incorporates herein the averments set forth in Paragraphs 1 through 3 of this Petition. 5, Defendant has now located a permanent residence and expects to take possession of that in late July, 'I 6, After the parties' separation, when Defendant and the two children returned to the 1 marital residence to retrieve some of their belongings, Plaintiff obstructed their access to the 1 , [I . property and assaulted Defendant, striking her on the side of the head, pushing her against a wall, and causing injuries to her which required medical treatment, 7, Since Defendant and the children left the marital home, Plaintiff has removed the majority of the tangible personal property from the house, including most of the furniture and many of the other items, Plaintiff has removed the items from the marital residence and concealed them elsewhere, 8, Defendant and the children require furniture and other items of tangible property to furnish their new home so that they can live in reasonable comfort, 9, The items that Plaintiff has removed from the house are not being used by any of the parties or their children and are not doing any member of the family any good or providing any benefit to any of them, 10, This court can award possession of the various items of marital property owned by the parties on an emergency or interim basis, without making a final distribution of those assets. 11, Without a reasonable share of the household furnishings and other household tangible items, Defendant and her minor children will not be able to live in reasonable comfort and security, will not have a place to sleep, and will not have the other items they need to live and for the children to attend school successfully, 12. Awarding Defendant possession of the tangible personal property and household goods, or a reasonable portion of those items, will not prejudice the Plaintiff in any way and will prevent serious and irreparable harm to Defendant and the minor children, WHEREFORE, Defendant prays this Court to award to her a reasonable share of the tangible household goods and furnishings which were in the marital residence at the time of the parties' separation, to allow her and the children to have possession and use of those items until final , distribution of all marital claims are made, 2 Ii . COUNT II . SECURITY FOR INVESTMENT ACCOUNTS 13, The averments set forth in the preceding paragraphs are incorporated herein by reference, 14, Prior to the parties' separation they held various accounts in banks, mutual funds, and other financial institutions, The accounts, however, were under Plaintiff's control. 15, Within the past sixty days, Plaintiff appears to have dissipated, transferred, or concealed various investment accounts and other financial assets of the parties in an effort to deprive Defendant of access to or benefit from those assets. 16, Plaintiff's conduct is motivated by a desire to deprive Defendant of her share of the parties' marital property, WHEREFORE, Defendant prays this Court to order the Plaintiff to restore to joint accounts any and all funds or other assets of the parties which existed prior to Plaintiff's interference with or dissipation of such funds, ordering Plaintiff to account fully to the Court and to Defendant for any and all actions he has taken regarding the marital assets, and in particular the marital investment assets, within the past six months, and enjoining Defendant from any other dissipation, transfer, or other activity regarding the parties' marital assets without further order of Court, ~ Samuel L, Andes Attorney for Defendant Supreme Court ID 17225 525 North 12'h Street Lemoyne, PA 17043 (717) 761-5361 3 . COMMONWEALTH OF PENNSYLVANIA ) ) SS,: COUNTY OF CUMBERLAND ) PATTY ANN HANES, being duly sworn according to law, deposes and says that the facts set forth in the foregoing document are true and correct to the best of her knowledge, information, and belief, /4!p. ~ PATTY ANN HANES Sworn to and subscribed before me this I "f /t. Day of 311 L Y , 2000, . 1'f/(M1 I Notary Public II ] I LYNN 'ARIAI ~ ~~'~~I~ Expires AUg, 17,N3lJO !: 4 ~ ~~ .1 Patty Ann Hanes, Plaintiff In the Court of Common Pleas Cumberland County, Pennsylvania v, No.: 00-2835 Robert Allen Hanes, DefendantlPetitioner ORDER AND NOW, this day of , 2000, upon review and consideration of Defendant's, Robert Allen Hanes', Petition for Work Release, said Petition is granted and it is hereby; ORDERED that: 1. Robert Allen Hanes shall participate in the Cumberland County Work Release Program during his normal working hours at Inclinator Company of America, Inc" commencing Monday, July 31,2000; 2. Robert Allen Hanes' father, Charles Hanes, shall be solely responsible for Robert Allen Hanes' pick up from and return to the Cumberland County Prison, 3. Robert Allen Hanes' immediate supervisor shall cooperate with the Work Release Program to the extent any confirmation and/or information relative to Robert Allen Hanes' is required, Honorable Edgar B. Bayley r?ti ~ BY THE COURT: 1~ vV~~\~ ~1- ~ ~ 'L.f ~ '"UAro I i II II "" l~ H I'; ! I I, 11 ~.~ """",.--.~ .-, ~ T ~ M ~ ~.", .~~ ~~~""'''''''J.11I .,.,.,....,~...,.-- ~< ~, rn fl', '-'1.-t d;,~ 2r:;' ;1: "i '''i C'lCc,;,'" ,,' _,I ~ i ';' ,. '-,::' , .' , _ .'-, ' ,-::;::,1 '!~'-;~~':L) trUJi\!7\/ I eN".:; I! ';,,,, ", '" '.' 1,.'i,,,\j"'J'; -~l""'1"~ 1lif!'!__1II!I1",,~~Ul.'1lJ'~:trJ" - .,.,.,...., ~_.!J!I '"'" L 'I~ L, " 1,1 Patty Ann Hanes, Plaintiff In the Court of Common Pleas Cumberland County, Pennsylvania v. No.: 00-2835 Robert Allen Hanes, Defendant/Petitioner PETITION FOR WORK RELEASE NOW COMES Petitioner, Robert Allan Hanes, by and through his attorney, James A. Miller, Esquire, and respectfully requests that your Honorable Court grant his request to participate in the Cumberland County Work Release Program and for reasons therefore states: 1. On July 25, 2000, Honorable Edgar B. Bayley held that Petitioner had violated the Protection from Abuse Order entered on May 15, 2000, 2. Petitioner was sentenced to the Cumberland County Prison for 15 days and remains there presently, 3. Petitioner has been employed in excess of 12 years for Inclinator Company of America, Inc, located at 2200 Paxton Street, Harrisburg, Dauphin County, Pennsylvania, and it is believed and therefore averred that a distinct possibility exists for Petitioner to lose his job. 4. Petitioner and Plaintiff have numerous joint financial obligations for which Petitioner remains responsible, 5, Moreover, in a corollary case docketed to 2000-2590, Civil Term, DR# 29,768, PACSES # 302102387, Plaintiff is seeking spousal support and child support and a conference is scheduled for August 16, 2000, - - " ~ ~<I 6, In order to continue to meet all financial obligations, Petitioner must continue to work and remain employed with Inclinator Company of America, Inc, 7, Petitioner has transportation available through his father who will pick him up and return him to the prison each and every workday. WHEREFORE, Petitioner respectfully requests that this Honorable Court allow him to participate in the Work Release Program during Petitioner's normal working hours commencing Monday, July 31, 2000. Respectfully submitted, -t- ({~ er, Esquire Attorne r Petitioner orth Second Street, Suite 100 Harrisburg, PA 17101 (717) 236-5161 Patty Ann Hanes, Plaintiff v. Robert Allen Hanes, DefendantlPetitioner Certificate of Service ~- ., In the Court of Common Pleas Cumberland County, Pennsylvania No.: 00-2835 I, James A. Miller, hereby certify that I have forwarded to the person(s) on the date and in the manner indicated below a copy of the preceding document. Date: July 28, 2000 HAND DELIVER Cumberland County District Attorney Mary Jo Mullen, Esquire Assistant District Attorney Cumberland County Court House 1 COUlthouse Square Carlisle, PA 17013 {/~ 1IilIllii~'iIlliwDitilli~illf~~--'" .. ~ '(ull 'ItIi1i8I/ilIlI!IiiAII'~~ (') C -o~ ITIm Z"C' ~~ [:::C:: ~C. ..:::--,-:: )> ;OC '7 <- -; -< -, iliiiIIi o Cl () .'j', := ,~- r 0,) CD ~~ OJ:) .:..) (,)1 j:i -< " ," '.':" -<~,""-a', C'ri PATTY ANN HANES, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW ROBERT ALLEN HANES, Defendant 00-2835 CIVIL TERM ORDER OF COURT AND NOW, this 25th day of July, 2000, I adjudicate defendant in contempt in violation of the terms and conditions of the protection from abuse order entered on May 15, 2000. Sentence is that you undergo imprisonment in the Cumberland County Prison for 15 days. Defendant is to stand committed. By the Court, C/ Edgar B. ~yley, J. f\~ [~:;voo 1 (J.'{( Mary-Jo Mullen, Esquire Assistant District Attorney James A. Miller, Esquire For Defendant Probation CCP Sheriff prs I I:.J j 1 .1: :1' ]' % ~.. " .. ""~ I'." "'.!' ?n ,. n"> (, ~.' ,'.... CUiV'; :\~~:'::~<~uP .>{2J~jNT1f "t:i"~h:\)l L\;;.",\lll'\ ,,.,, ^~ >..~m"!1i!l'~~~I-' ,- ~~~,.~",,)I ~ _ ". r, _~,' . " "0".',,' .","i1,.-' ';.'""1,,',,,_ 2i1l!k f PATTY ANN HANES, PLAINTIFF IN THE COURT OF COMMON PLEtAS OF CUMBERLAND COUNTY, PENNSYL.VANIA v, ROBERT ALLEN HANES, DEFENDANT AND NOW, this 00-2835 CIVIL TERM ORDER OF COURT Iff-. day of July, 2000, IT IS ORDERED that defendant shall appear in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania for a hearing on the within petition to hold him in indirect criminal contempt from a protection from abuse order, on Tuesday, July 25,2000, at 11:00 a,m, This order shall be served on defendant and failure to appear will result in a bench warrant being issued for his arrest and production in court, Edgar'B, Bayley, J, Jonathan R. Birbeck, Esquire Mary-Jo Mullen, Esquire Assistant District Attorney " Herbert Goldstein, Esquire For Defendant :saa O~ HU~D-"'O:T1CE OO-'~I" ,~' IJ-'~R'i' "'---,.-. '--! 11\ I" , , -~.. , ~ "_" r ' 00 JUL I 3 P1112: ! 2 CUMi3EHL,cj\JO COUI',llY PENNSYLVANIA . '1 - (~- 00 ee. CO~\<1.S ~"'~J\ I ~.., !!'M1J!!lIIII ~'......'" .~!_i!!!I"..,.,."._"~ " - ~l!!'II'I'l~- ~" "; PATTY ANN HANES, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VAN V, : 00-2835 CIVIL ROBERT ALLEN HANES, Defendant : CHARGE: INDIRECT CRIMINAL CONTEMPT COMMONWEALTH'S PETITION FOR A HEARING ON CHARGES OF INDIRECT CRIMINAL CONTEMPT Jonathan R. Birbeck, Chief Deputy District Attorney of Cumberland County, Pennsylvania, brings the following Petition for a hearing on charges of Indirect Criminal Contempt: I, A Protection from Abuse Order was issued by the Court, A true and correct copy ofthe Order is attached, 2, The defendant's violation ofthis Order is averred in the attached criminal complaint. 3. The victim requests the filing of an Indirect Criminal Contempt Charge, 4. The District Attorney's Office approves the filing of this criminal complaint. 5, The Commonwealth is requesting a hearing on the charges of Indirect Criminal Contempt pursuant to 23 Pa,C,S,A. 9 6113, 6. The plaintiff and/or the defendant may seek modification of the Order based on the filing ofthis petition as the Court deems appropriate following the trial in addition to any other sentence, 23 Pa,C.S.A, 96113, WHEREFORE, the Commonwealth requests the defendant be commanded to appear before the Court on the charge of Indirect Criminal Contempt. Respectfully submitted, e~r-Sg Chief Deputy District Attorney ~- "" \ ,I , f '. ~ ,.... "' "~ c ,~-~-- 7177376953 => VICTIM WITNESS; #2 7177376'353 lOWER AL.l...EN TWP PD Ll:;; ..,...~ j(~ RECEIVEO: 7-1'2~ 0; 12:49; , t 'lIi 11212<1<1<1 12: 51 PAGE 1il2 COMMONWEALTH OF PF.\~'\I.V,~NJA COUNTY OF: Cumoorlao\\ Magbltttal ~)ntlit;l Nu';;" . " POLICE CRIMINAL COMPLAINT Dimet J~stice Name: HOlt COMMONWEALTH OF PENNSYLVANIA VS, AMNS!;: !TclCP.....C; (7'17) Docket No.: Date Filed: OTN: DEFENDANT ~ NA1I4EandAODUSS. ,HaRel, Robert Allq 328 Blaek Latdll,aRe Camp HiJl.PA 17011 Ph. 761-900' I L ---.J -~ ..-......- s . y --"_up" . . lm W"illr 0 .A,,,.. 0 j,lll<.~ J DJhm,ht a Hilpmil:. 0 Nui\'O! Amer;o2II. 0 I\~~~'l' .__. IE! AUIe- <l!n. n\'~A.K.A. pamtl no nt 11m ( ~''i8ooi.a'StwrityNw\-.,bes lilt. ~~~- . ~ ..;:..~..,~ PA ncl eM urn I tt f:r anlClpatll$ I> v.; . " "III all'll 000-07-186 _-__1 Distri<.\t Attorney's Office []Approved DDisapproved be<.\ause: (The di$trlct Btt~~ ntZy rcq~tr~ tt,~t ~h...' ;Ul'Kpla.rm. -lUrC$t watts(tt affldarit., Qr" bQth be EIP'J1fqvcd by the dtQrncy fQC'" die C~WQl:ttJ prinr t~ fili:~~-- P..R.Cr.P 107.) , -\. &1- or AU"""'! ff<('"",,,,,,,~dill:T!<;..!'J\11l \. \11") C~1. Mark E. Williams INamll 01 AEllliill ~ t"lwe motor -ypeJ ofLcwer Allen Townsh~ "otice =.lI1enr I'A02I0600 \lger;miY uep.!lnrnctt~ ~fI . ;~P.\:l"~~'" l liCIt! P(\llUQU ~ult(:hv{llQnJ (E'M~'U4.<llt....~ <IitU{ll'il.U:-I) '~lHAMtfM'iIM~~ - \u.wl 18-06 ,Omc;" Badge Number 11.0" 2000-07-186 --- (<R~~~:;fv.l:l!l'M.\lI.\!l\~I\.(\Sj do hereby slate: (check the appropriate box) I. IZII ""cuse the abow named defendant who lives at the address set forth above o [ accuse the detcodum who,e name is unknown to me but who is described as o I accuse the defendant who,e name and popular designation or nickname is unknown to me and whom I have tlw,IefQIedesil\l\a\d a;. J~\l!.ll OQe with violating Ibe p.,nall;lw;, .,1' the Commonwealth of Pennsylvania at 328 Black Latch Lane Lower Allen Twp, tf\w)ohlltiulSub4i'brioo) la C\lmberland County on or about 07-09-00 I n02 hrs Participants were: (if th~rc were participants, place their names here, repeating the name cf above defendant) Hanes, Robert Allen 2, The acts committed by the accused were: (Sf:( forth II :oilmma:ry Q( fm: hfl,;!" 'iutl'idc.nt to acfvise: the ddcndnr o(the n-atu(4' of the otlen$C thargtd. A ckafion to t#lt; statute allegedly vMllllcd. withuut rft('Irt. is nm ,;,unit-klll j 11 :1 ~II!'lII1'll)ry case. you rnu.'1l cite the spli!clf1c liecUQIt lInd 1iubsel:tlon nt"the $l..ute or ordin~ allegedly violnll:d.) Indirect Criminal ('(>nrel11rt: The above named individual did intentionally and/or knowingly violate an order, #00.2835. 2011ll ddl term issued under the Protection From Abuse Act by the Honorable Judge Edgar B, Bayley on the ..bn"... date and time. The defendant did violate sllid Qrder in that he did abuse, harass and threat~n Putty Ann Hane~ by blocking her exit from their jointly owned property at 328 Black Latch Lane, blew cig.ar sllI<!kc in her face, grabbed her 11)' her artlIS and thn:w he{' against a wall, Patty Ann Hane\'o complained II"" l'I<:f head n\\r\. fr<)llI $ttiking the wall, and later Np<:lrted that she had been treated at a hospital for a concus<inll. AOPf: tI2.t(;,I%)(i>'!~1 Vtt>lli,,", l-3 R1:CEIV~D:' 7~t2- 0; 12:49j e7/12/2eee 12:51 , ~L~ 7177378953 => VICTIM WITNESSj #3 7177378953 lOWER ALLEN TWP PD . '" <'". " . Ii PAGE 'e3 , (CQntinuatiull of No. Jl "'.....,'Nom<-.- ~I ~- ':'":::- ~ POLICE CRIMINAL COMPLAINT all Qf which wet'e a!!ai"~t the pea<< and dignity of the Commonwealth of Pelmsylvania and contraty to the Act of Assembly. orin vinllllrrm 01" 6113 a.... Title 23 I l~e~r/iJfll {.)lllfm:rmDl (PA Stlllflll'; "o;.IWQ, l)!'iiIe: {s"~) <~lIIlKliIIO'II) {,,,SlItute-, (~_tl ".. "r&fl_) lJ~~'I9.) IMSWllHl) ffwat<) .... \:itWI)>>) ~ !f'..t~j (~) 3. I ask that a warrant 0f 1\l'l'ClOt or a summons be issued and that the defendant be required to answer the charges I have made, (In order for a warrant of arrest to issue, the attached affidavit of probable cause tDUst be completed and SWlII'1I to beforr rh.l~~ltlll!l altth\lrlty.) 4. I verify that the facts sd limh in this complaint are true and CQJTect to the best of IllY knowledge or information and belief. This verilieali,," is made subjecllo the penalties of Section 490<1 of the Criml'S Code (18 PA. C-S- ~ 4904) relating tu unswurn falsification to authorities. -., ~""'if"\'~h'" ,,,'. yi XbAJ?- ~~:. .1\lU'J'e ant ) 1)7-12-2000 AND NOW, on this d~t~ .. n .' ,,_ ,I certifY thai the cOlll~laint bas been properly completed and verified, ^n nllidavit of probable cause must be completed in order tor a warrant to issue, SEAL 'Miq!i:."'liollti,,<,(I':-:T~ .,,-.' (ImliIlFAulwtil~, ..1(JI>r'.II!.{tjrpil(I,.,("."{'fl~"",,, 2-3 J -~,~~ -- - "- RECEIVE'O:' 7-12- OJ 12:50; I 01/12/2000 12:51 _. .. w "_ '. " - 7177378953 => VICTIM WITNESS; #4 7177378953 LOWER ALLEN TWP PD PAGE ~4 II POLICE CRIMINAL COMPLAINT Defendant's Name; H.';:, ;:.~~. :\ lien Docklll NUlllber: AFFIDAVIT of PROBABLE CAUSE 0007-09-00 at 1302 IIr.. l.ow., AII"n Twp, Police responded to 321181ack Latcll Lane fo, an active domestic assault, Upon arrival I spoke with l'lIIty Ann Hanes, Ni<.'</k Harne<, and Nicole's younge< si$ler. PalIy and Ni"0le Hanes mid meth811hey Iwl ClllM to \lie hQ_ to allow tile Y<lUt\gest HaMS to ~pen<I \i...", with her father during her birtltday. Patty Hanes had entered tile hou!e 8J\d starte<;Hli pack items to take with ber. As she WaS doing thb, Rol".rt Han.. was unpacking the same items. An all!ume'll ensued and Robert Hanes stepped in front of l'alty Halles and IRvented her ti>rlll exiling Ille residence. He blew smoke in her face and told ber I'" ItS k>!lg '" ..... did lIQt touch her he could not gel into trouble. Ni<:oIe Hanes obsefved her la~ .,lion. and become upset. She stepped into llle house and slapped her lliIlIer aertl5S the IllI:e, Robert Hanes grablJed Nicole and th,"w her against a w;lll, causing he, head to hit said wall. Patty Hane. tried 10 step betw..., Nicole and her fathe" At this time Robert II",,~, grahbed Patty Hane. by the ann~ and throw her against the wall. Patt:' Hsnes al.o hit her head against the wall and suffered pIlin .. a res\lll. Patty Hanes reported on 07,11..00 that she had .ufl'et<od a eoncu"ion as a result of striking her head on the wall. She indicated she was _ed at H3ITisbuJg Huspi'"' ;md win provide hospilal reoords at a late~dale, J, .~p!'. Mark E. Williams , BEING DULY SWORN ACCORDING TO LAW, DEPOSE AND SAY THAT THE FACTS SET FORTH IN THE FOREGOING AFFIOAVlT ARE TRUE ANI) CORRECT TO THE BEST OF MY KNOWLEDGE, lNFORMI\TlON AND BELIEF, ~f ~().,S (fwn,~' - ~ Sworn to me and subscritlcd bcfbre me this 12th day of July 2000 [)ale . District Justice My commission expire~ tirst Monday of January, _ SEAL A.Of1('oI'i.(4tI'JGl ClatllMl!1 "':HI"U' 3 . 3 m -' . ~ ~~~~ ~ '"' .......Iit . ' ~, PATTY ANN HANES, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. ROBERT ALLEN HANES, DEFENDANT 00-2835 CIVIL TERM IN RE: PROTECTION FROM ABUSE ORDER OF COURT AND NOW, this l f't'-' day of May, 2000, following a hearing on the merits, IT IS ORDERED: (1) The temporary protection from abuse order entered May 5,2000, is vacated and replaced with this order. (2) Defendant, Robert Allen Hanes, shall not abuse, harass, stalk or threaten Patty Ann Hanes, (3) Defendant may not go to or call plaintiff or contact her, except in an emergency involving the parties' children, at any place she is employed, (4) A certified copy of this order shall be provided to the Lower Allen Police Department and the East Pennsboro Township Police Department. (5) Defendant shall not be in possession of any weapons during the term of this order and the Cumberland County Sheriff shall, during the term of this order, retain any weapons previously seized from defendant. (6) All other relief requested by plaintiff is denied, (7) This order shall remain in effect for a period 0 , ~ ~ ~ 9'\~ +-<? , ' . , ~_. , ~"~ Joan Carey, Esquire For Plaintiff Herbert Goldstein, Esquire For Defendant Sheriff :saa ~ ~ ~ .~ ~,- .-y 1 l I J ,j j '1 :1 " ~ I :j I I j j 1 1 1 , j 1 i I 1 i 1 1 j I I j I PATTY ANN HANES, :IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA VB. :NO_ 00 - ~~ CIVIL TERM ROBERT ALLEN HANES, Defendant :PROTECTION FROM ABUSE t, IJ,M ,u-O 1OY' .5'_ J ')/ 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 Petitian~ In particular, you may be evicted from your residence and lose other important rights. A hearing on this matter is scheduled for the I'Jl~ day of May, 2000, at /: /5 P.m., in Courtroom No.L of the Cumberland County Courthouse, Carlisle, Pennsylvania~ You MUST obey the Order that is attached until it is modified or terminated by the court after 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 HAY HAVE TO PROCEED WITHOUT ONE. 1\ '\ J J. b CUMBERLAND COUNTY BAR ASSOCIATION " Lief? U\ c:/ '-fV ' e 2 LIBERTY AVENUE ",' " {,,) CARLISLE, PENNSYLVANIA 17013 ,',;' '/(?,'; TEI1EPHONE NUMBER: (717) 249-3166 :)\ 1_;'; , J .p Ie /' /L., . Ie.' v Il t":e#'AME~IC~S WITH DISABILITIES ACT OF 1990 '\ f..:..J-.'-Y 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 """- I_III/lf' ",.....1"., ~- IMWI'!~ ~ ~~- -"*"~ '. tATTY ANN HANES, :IN THE COURT OF COMMON PLEAS Plaintiff :OF CUMBERLAND COUNTY, PENNSYLVANIA ,I :1 , If ",) vs, :NO_ 00 - .;JRdS CIVIL TERM ROBERT ALLEN HANES, Defendant :PROTECTION FROM ABUSE ~~ NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on this matter is scheduled for the .I)l~ day of May, 2000, at /: /5 j'.) .m., in Courtroom No.L of the Cumberland County Courthouse, Carlisle, Pennsylvania. You MUST obey the Order that is attached until it is modified or terminated by the court after 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. 86114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. 82265, 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. 82261-2262. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEl\RING. 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 Bl\R 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. , " , Temporary Protection From Abuse Order Page i '0f3 Patty Ann Hanes : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff v. J <; Ce;;:;l T.t...- : No, ()-(),.2 3 Robert Allen Hanes Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Robert Allen Hanes Defendant's Date of Birth is: February 2,1960 Defendant's Social Security Number is: 191-46-4784 Narne(s) of All protected persons, including Plaintiff and minor children: I. Patty Ann Hanes AND NOW, on 5th Day of May, 2000 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: Plaintiff's 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 shall be evicted and excluded from the residence at: 328 Black Latch Lane, Camp Hill, Pa. 3. Except for such contact with the minor child/ren as may be pennitted under paragraph 5 of this Order, 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. Defendant is specifically ordered to stay away from the following locations for the duration of this order. Plaintiff's place of employment located at KLNB - Campbell Commercial Real Estate, 207 House Avenue, St. 107, Camp HilI, Pennsylvania .../temporder.asp?TempOrderID=8798&cmdMove=View+Completed+ Temporary+Order&pfadnu 5/5/00 - ~"~ ~ ~"- ~ ~ ,:il!', Temporary Protection From Abuse Order " Page 2 '0f3 4. Except for such contact with the minor child/ren as may be permitted under paragraph 5 of this Order, Defendant shall not contact Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons, 5. Pending the outcome of the final hearing in this matter, Plaintiff is awarded temporary custody of the following minor child/ren: I, Nicole Christine Hanes 2, Amy Michelle Hanes Until the final hearing, all contact between Defendant and the child/ren shall be limited to the following: None 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 the Plaintiff in accordance with the terms of this Order, 6. The following additional relief is granted: - Defendant owes a duty of support to Plaintiff and/or minor child/ren. - Order Defendant to pay temporary support to Plaintiff and/or the minor child/ren, including medical support, and payment of the rent or mortgage on the residence. - Order Defendant to pay the costs of this action, including filing and service fees. - -Order Defendant to pay $250.00 to reimburse one of Legal Services, Inco's funding sources for the cost of litigation in this case. -No harassment of Plaintiff's relatives -No destruction or damage of Plaintiff's property or jointly owned property 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Lower Allen Police Department East Pennsboro Township Police 8. 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, .,./temporder.asp?TempOrderID=8798&cmdMove=View+Completed+ Temporary+Order&pfadnu 5/5/00 ~ " , .~ ,~ . 'I . Temporary Protection From Abuse Order Page 3 of3 9. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MAYS, 2001 OR UNTIL OTHER WISE MODIFIED OR TERMINATED BY THIS 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 $1,000.00 and/or up to six months in jail. 23 Pa,C,S, g6114, Consent of the Plaintiff to Defendant's return to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose, 23 Pa.C,S, g6113, Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under the PellIlsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U,S,C, gg2261- 2262, NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiff's residence OR any location where a violation of this order occurs OR where the defendant may be located. If defendant violates Paragraphs I through 5 of this Order, defendant shall be arrested on the charge ofIndirect Criminal Contempt. An arrest for violation ofthis Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence oflaw enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse, Weapons must forthwith be delivered to the Sheriff's office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this court, unless the weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. BY THE COURT: ~ ~--1>t~:J[(;.."d<> Judge /::., ~ ~ .. Date Distribution to: --, Legal Services f 5hlc~ Faxed & Mailed to PSP '. . '- ~ ,. .Itemporder.asp?TempOrderID=8798&cmdMove= View+Completed+ Temporary+Order&pfadnu 5/5/00 - " '"t!:$l'f~} Petition For Protection From Abuse Page l'of5 " PFAD Number: MWI084323W Patty Ann Hanes Plaintiff : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v, IJ.{;- .,if3S ~ J.u---- : No, Robert Allen Hanes Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE I, Plaintiffs name is: Patty Ann Hanes 2, !, (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. Patty Ann Hanes 4, Plaintiffs Address is : 328 Black Latch Lane, Camp Hill, Pa 17011 5, Defendant's Name is: Robert Allen Hanes 6, Defendant is believed to live at the following address: 328 Black Latch Lane, Camp Hill, Pa 17011 7, Defendant's Social Security Number is: 191-46-4784 8, Defendant's Date of Birth is: February 2, 1960 .,.Ipetition,asp?PetitionID=7299&cmdMove=View+Completed+Petition&pfadnum=MWl084323 5/5/00 . . Petition For Protection From Abuse 9, Defendant's Place of employment is: Inclinator Company of America, 2200 Paxton Street, Harrisburg 10, Defendant is an adult. II, The relationship between the Plaintiff and the Defendant is: Spouse 12. The Plaintiff and the Defendant been involved in the following court actions: a. Divorce 13, Other details of the court action are: Defendant filed for divorce - Plaintiff served April 28, 2000. 14, The defendant has not been involved in a criminal court action, 15. Plaintiff and Defendant are the parents of the following minor child/ren: a, Nicole Christine Hanes Age:15 Child's address is: 328 Black Latch Lane, Camp HiD ,Pa 17011 b. Amy Michelle Hanes Age:l0 Child's address is: 328 Black Latch Lane, Camp HiD, Pa 17011 16, Plaintiff is seeking an Order of child custody as part of this petition, The following is a list of the children and where they have live for the past 5 years: a. Nicole Christine Hanes For the past 5 years, this child has lived with: 1991-1998 213 Allendale Way, Camp Hill, Pa. 17011 - Plaintiff & Defendant 1998-present 328 Black Latch Lane, Camp Hill, Pa. 17011 - Plaintiff & Defendant b, Amy Michelle Hanes For the past 5 years, this child has lived with: 1991-1998 213 Allendale Way, Camp Hill, Pa. 17011 - Plaintiff & Defendant 1998-present 328 Black Latch Lane, Camp HiD, Pa. 17011 - Plaintiff & Defendant Page2'of5 " "./petition.asp?PetitionID=7299&cmdMove=View+Completed+Petition&pfadnum=MWI 084323 5/5/00 "-. ~ -~1l1W ""'''i;" , , I'etition For Protection From Abuse Page 3 .of 5 .. 17. The facts of the most recent incident of abuse are as follows: On about Thursday, April 27, 2000 at approximately 11:30PM location: 328 Black Latch Lane, Camp Hill, Pa. 17011 While Plaintiff was asleep, Defendant entered her bedroom, grabbed her by her face and held her down on the bed for approximately fifteen minutes as he yelled.and screamed at her. Plaintiff was able to get her cell phone to call the police but Defendant grabbed it from her and threw it across the room. Plaintiff was able to get to another phone and telephone the Lower Allen Township Police. 18, 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: Since October 1999, approximately once a week, Defendant has abused Plaintiff in ways including: prevented her from leaving a room by placing his body in front of her or her exit, forced her against walls with his body, threatened to enter her bedroom and force intercourse on her, pushed her, and grabbed her by the face, squeezing her jaw, causing lacerations and bleeding inside her mouth. Defendant grabbed Plaintiff by the breasts and genital area. Defendant also stalked Plaintiff in ways including, driving by her workplace; telephoning Plaintiffs place of employment; interrogating her boss, the boss's wife, and other co-workers, following her wherever she goes and leaving notes on her car to let her know he is watching. On or about October 24,1999, Defendant grabbed Plaintiff. The children woke up and the defendant told them that if they called the police, they would put them in foster care. Defendant took the plantiffs cell phone and disabled the other phones so she could not get help. On or about October 23, 1999, Defendant grabbed the plaintiff by her wrists, threw her to the floor, straddled her, pinned her down by her wrists, grabbed her breasts and genital area, and told her that her body parts were his and he could do what he wanted. 19, The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: Lower Allen Police Department East Pennsboro Township Police 20, There is an immediate and present danger of further abuse from the Defendant. 21, Plaintiff is asking the court to evict and exclude the Defendant from the following residence: 328 Black Latch Lane, Camp Hill, Pa. Owned By: Patty and Robert Hanes 22, The Defendant owes a duty of support to Plaintiff and/or minor child/ren, 23. 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, "./petition.asp ?PetitionID=7299&cmdMove= View+Completed+Petition&pfadnum=MWI 084323 5/5/00 .."","'" -- -~ ~I ",'- ,~- :i.~ci , " " . Petition For Protection From Abuse Page 4 of 5 b, Evict/exclude Defendant from Plaintiff's residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff. c, A ward Plaintiff temporary custody of the minor child/ren and place the following restrictions on contact between Defendant and child/ren: d, 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 Plaintiff's school, business, or place of employment, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/ren. e, Order Defendant to pay temporary support to Plaintiff and/or the minor child/ren, including medical support and payment of the rent or mortgage on the residence, f, Order Defendant to pay the costs of this action, including filing and service fees, g, Order the following additional relief, not listed above: -Order Defendant to pay $250.00 to reimburse one of Legal Services, Inc. 's funding sources for the cost of litigation in this case. -No harassment of Plaintiffs relatives -No destruction or damage of Plaintiffs property or jointly owned property h. Grant such other relief as the court deems appropriate, 1. 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, ,rJ /7) // /!jf--tv,^,/ ~JtL c_-/ Respectfully Submitted bi/Joan Carey /) Agency: LEGAL SERVICES, 'rNC, . ../petition.asp?PetitionID=7299&cmdMove= View+Completed+Petition&pfadnum=MW 1084323 5/5/00 , ~ ~, '0 I -~ijVj . . , . , VERIFICATION I verify that I am the Plaintiff as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. Dated: shim f~~ Patty Ann Hanes, Plaintiff -- -,- , , '. SHERIFF'S RETURN - REGULAR . CASE NO: 2000-02835 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HANES PATTY ANN VS HANES ROBERT ALLEN CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Uj&!)", . Cumberland County, Pensylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon HANES ROBERT ALLEN DEFENDANT , at 0017:30 HOURS, on the 5th day of May at 328 BLACK LATCH LANE CAMP HILL, PA 17011 by handing to ROBERT A. HANES together with a true and attested copy of PROTECTION FROM ABUSE NOTICE OF HEARING & ORDER, TEMPORARY PROTECTION FROM ABUSE ORDER, PETITION the , 2000 and at the same time directing His attention to the contents thereof, Additional Comments DEFENDANT TURNED HIS LICENSE TO CARRY FIREARMS OVER TO CUMBERLAND COUNTY DEPUTIES AT TIME OF SERVICE OF PFA, Sheriff's Costs: Docketing Service Aft idavi t Surcharge So Answers: r~~-~~~I R, Thomas Kline 18.00 9,30 .00 10.00 .00 37.30 , f 05/09/2000 Sworn and Subscribed to before /?f0 By: me this /~ iY.- day of ~ ~. _ A.D. ~ C. "h-rJ/~~ ~ . rqthonotary , 0'''''1 \ :i:'_ , ;;., PATTY ANN HANES, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA " V, ROBERT ALLEN HANES, DEFENDANT 00-2835 CIVIL TERM AND NOW, this ORDER OF COURT /14- day of July, 2000, IT IS ORDERED that defendant shall appear in Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania for a hearing on the within petition to hold him in indirect criminal contempt from a protection from abuse order, on Tuesday, July 25, 2000, at 11 :00 a,m, This order shall be served on defendant and failure to appear will result in a bench warrant being issued forhis arrest and production in court, Edgar B. Bayley, J, Jonathan R. Birbeck, Esquire Mary-Jo Mullen, Esquire Assistant District Attorney I Herbert Goldstein, Esquire For Defendant :saa T'F~UE CQPVFROM RECORD Tn T"'"ooywller8of, there Untp!!!lt"'f II8fIcS and tM aNIa/ saId~:;Pa. ThIS,1~{JJ,i-" .....'T~ u '. PrOthonotary~ '< , , . ': PATTY ANN HANES, Plaintiff v, : IN THE COURT OF COMMON PLEASOF : CUMBERLAND COUNTY, PENNSYL VAN : 00-2835 CIVIL ROBERT ALLEN HANES, Defendant : CHARGE: INDIRECT CRIMINAL CONTEMPT COMMONWEALTH'S PETITION FOR A HEARING ON CHARGES OF INDIRECT CRIMINAL CONTEMPT Jonathan R. Birbeck, Chief Deputy District Attorney of Cumberland County, Pennsylvania, brings the following Petition for a hearing on charges of Indirect Criminal Contempt: 1, A Protection from Abuse Order was issued by the Court. A true and correct copy of the Order is attached. 2. The defendant's violation of this Order is averred in the attached criminal complaint. 3. The victim requests the filing of an Indirect Criminal Contempt Charge, 4. The District Attorney's Office approves the filing of this criminal complaint. 5. The Commonwealth is requesting a hearing on the charges of Indirect Criminal Contempt pursuant to 23 Pa,C,S.A. ~ 6113, 6. Xhe plaintiff and/or the defendant may seek modification of the Order based on the filing of this petition as the Court deems appropriate following the trial in addition to any other sentence. 23 Pa,C.S,A. ~ 6113. WHEREFORE, the Commonwealth requests the defendant be commanded to appear before the Court on the charge of Indirect Criminal Contempt. j" Respectfully submitted, ';2r!~r:re Jonat~m: R. Birbeck Chief Deputy District Attorney . .. . ""'. ," c~i RECEIVED: 7-12-' 0; 12':49; ',07/1212000 12: 51 7177378953 ~> VICTI~ WITNESS~ #2 7177378953 LOWER ALLEH TWP PD PAGE 02 COMMONWEALTH OF r'E\~"'\'I.\I,'NIA COUNTY OF; Cumberlao\! Ma~btttiall)nt,itl till';~ . POLICE CRIMINAL COMPLAINT District Justice Name: HIlD. COMMONWEALTH OF PENNSYLVANIA VS. A411....: Telephone: (717) Docket No,: Date Filed: OTN: DEFENDANT r::- . R.o&E and AIIDUtSS. IHallts, Robert Allen 328 Blac:k Latc:h I.ane Camp Hill, P A 17011 Ph. 76J.900' I L -.J $ lUl.:.Y -.'Ik' .. 1m 1"11<< O..h,,,, 0 1J11ll" 0 hID.l. HilpII\k 0 Nm~A_icu 0 \'nl.l"....." IBI Male. n\',A.K.A. -- . 50 . . ()efaldatH's~Smlfity Nu&lber . 02-(\2.-60 191-46-47&4 ~ n lor! PIII.lI1Imllc; iIlBk ~SIllI<etIMlIIiYY, ,w SlaIr: PA 18802218 VCR I NI9JlS ('(Ide am ItO nI 11m r "m ..tIl tIC. M un'l et &ntClpil'lls: 000-67-186 District Attorney's Office: [JApproved DDisapproved be<:ause: t1bc di$trlct allom<ylI!3Y I<<IU'o: Ihl .1., ;om'l........-..t_ a/l"ldari~...both be _vcdby Ihc __ r.",he 1;....""","-..111I priartc ftIl"ll, P"R.Cr,P 107.) . (Ii.....r An"""f furt'om"""''''''''''' f!""'l'I'i,"o Typo) '~HAMMN'!''''t,;~.' '~I I. Mark E. Williams I amlt I) mn'~ ease nt or 'ype: o~er Allen Township Police PeI>arlment I'A0210600 ItOendfy rlepl1nmC:ll{~~~~u=d luld PClHuod ~UadI'VI~urRJ (P"'Mt~ ellU Nu,,"'tl') dQ hereby slate: (check the appropriate bQxl 1. ~ I accuse the ahove: I'l~med defendant who lives at the addxess set forth above o [ acc:use the detenti'.lT11 who~e name is unknown to me but who is described as ' 18-06 ( 'c.. BadS" Numb.. /1.0., 2000-ID-186 (OtIf-I'~llIf- Afll'~~' ( '!Ie t't1ll1\':II:r I'K ^I) o I accuse the defendant whose name and popular designatian ar nickname is unknown ta me and wham I have t~",fore designated as hlhll Doe with violating the penall;l\v, ,'f (he Commonwealth of Pennsylvania at 328 Black Latch Lane Lower Allen Twp_ 'Pllll~robtinl BlIbIlivmon~ [a Cumberland County on Qr abQut 07-09-00 11302 brs Participants were: (if there were participants, place their names here,lepeatinl~ the named above defendant) Hanes. Robert Allen 2, The acts committed by the accusoowerc:: (!Set forth .. $(,IfI1m(lry qrth~ III~f..: ",ollidcnr to advise: tht: dcfcmdanf (Jfrhe n.tu~ oftltc ofTCfI:S'c cltarcc<t. A e;tafion to lhe statutoe aflcg4dly Vi()(8ted. withoot nN'rt. i:s not lmt'lkkm 11':1 ~1I"1""f1r)' ~ltSc. you mu.'1l cite 1he sp,cjnc set.1lon und 1i\lb5Et:t10n nfthe: 5'''l,Ite l)r l~rl$ln~04: alhl)Jc:dly vlolulI::d.) y Indirect Criminal ('''nleml't: Theabove named individual did intentionally andlor knowingly violate an order, #00.2835. 2l)OI) ci\'i1lcrm issued under the ProtectiQn From Abuse Act by the Honorable Judge Edgar B. Bayley on the "h,l\'c dale and time. The defendant did violate said order in that he did abuse, harass and thre(lten j'utty Ann Hanes by blocking her exit from their jOlnt1y owned property at 328 Black Latch Lane, blew cig.t\l' "l1I<lke in ner fa.<:<:, grabbed h<:r by her arms and thl:l:W h<< against a wall. Patty Ann Hanes complained tlw pcr Iwad hIlT!, from striking the wall. and later n:ported that she had been treated at a hOSpital for a concussion. AOft~ Ill.f6N(.)(IIlI~I~~...1 1-3 ~ 0_ ,.. , L '-0'._ ",j,]-, ru:,,,,,-,-"r:.u. .. '4- U, ,~."tl::l, J'II~IOI::lO~ ~> ViLli~ WiIN~~~; *~ 7177378953 lOWER ALLEN TWP PD PAGE 63 .'}17l12/2666 12:51 (CqnUnualk)JI ofN(,. '1 Docket NllIllbcr; POLICE CRIMINAL COMPLAINT Defendanl's Name; --- llanes, R(lhco /\ lItm --- . ~ ~---_.._.__._._- .....~...,._,..._..__.- all ofwl1ich were against the peace and dignity of the ComMonwealth ofPennsyl'l'ania and contmy to \he Act of AssemblJ. or in vinlatirm of, 611J a "'" Title 23 I j:;e.;l~.nl ~-:;1l1l11:':1I0.) (1" 5u1J1f) / (~otlIq. ..... (s<<liotI) (llltllmllll7lt (rA5latItl!:) (-, "... l'5.ctilll") I~tt/fll) (USWtlc) (t.-t~) ., ,,'" 15l!'~llm) fS>>I>Im>toU W,.1~1 i~j 3. I ask that a warrant of ilrrc~l or a summons be issued and that the defendant be required to answer the charges I have made, (In order for a WI/rrant of arrest to issue, the attached affidavit of probable cause must be completed and nrol'1l to before the J~~ulllg a\lthorily.) 4, I verify that the facts s<.i 1111'lh in this complaint are true and comct to the best of IllY \(~)wledge or information and belief, This vcrilicalj.'n is made subject to the penalties ofScction 4904 oftheCrirnes Code (18 PA. C,S- ~ 4904) relating III un~wllrn falsification to authorities: 1)7-12-2000 ~ }r;l~ {;..,~;. .) -, ~""'lf"~l\.i "" AND NOW, on this date".. ,... ,,_ .1 certifY that tbe complaint has been properly completed and verified, ^n ilflidavit of probable cause must be completed in order for a warrant to issue, IM~bf,.'lrftllll~lI,~.j ~ .. ,_.. SEAL ihrlli.,AutlVlil)1 A(II".J/!-(tffM/(I"(('rfll..tl<:t-"...,, 2-3 -~ . H ~ ~ ~~ -~ , - - , H.l:::.(.;l:::.J.Vl:::.U; ('1",- U; I'.:::;,u. ~,67/12/2666 12:51 I I I , .:" IH""'" -... ~ J...., f,,1 ....., '~I:""', It"t 7177378953 l.OoJER AI.l.EN TWP PD PAGE 64 .._.~.._...' - --...-., ....- II POLICE CRIMINAL COMPLAINT _.__.~_..,-_. Defendant's Name; Han.s, I~:~~ A ;len Docket NUJl1ber: AFFIDA VIr of PROBABLE CAUSE On 07-09-00 al1302 IIr~, Low~r I\I1.n Twp, Police responded to 328 nl~k Latch Lane for lIll active cbnestic assault. Upon arrivall.poke with Pany Ann Hanes, Nk111c H~, and NiC<lle's younger sister. Patty end Nienle H3IIe5 told me that they ha!1 come to the hQll$e to allaw the youngest Hanes II) spend time with her f.1ther during ber birtbday, Patty Hanes bad entesed the hQuse and stalte9 to )ltIck Items 10 take with har. As she was doing this, Rllhl.rt Hanes was unpacking the SlIIfIe items, An argumel\t el\sued and Rl)bert Hanes stepped in front of I'alty Hanes IlIld prevented her (..nil ,xiling die residence. He blew smoke in her face; end told her th;u: as king lIS he did not touch her he could not get into trouble. Ni<:ol< H_ obsel'ved her l;,tI1~ ,'<tions end beelll1le upset. She stepped into flIe bouse and slapped lIer fallter across the llIce, Robert Hanes 8I"'bbed Nicole and Ihr~w her ag.lnst a "'Ill. causing her head to hit said wall. Patty Hanes tried to step between Nicole and her , father, At this time Robert 'h,"~s grahbcd Patty Hanes by the anns and tlm:w her againslthe walJ. Patt;J Hanes also hit her head against the wan and suffered pain... re,,,II, patty Hanes reported on 07.11.00 thOlt she had suffered. concussion as a result of striking her head on the wall. She indicated she was lrealed at Harrisburg HospitJI and "'ill provide hospital reeonls at a lalet'date, I, ,~p!c Mark Eo Williams . BEING DULY SWORN ACCORDING TO LA W, DEPOSE AND SAY THAT THE FACTS SET FORTH IN THE FOREGOING AFFlDA VIT ARE TRUE AND ('OHIlECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. ~f jY1a"f/. ~ JA.., <$ IJIIl\lln~4( 4ffl4nrl # " Sworn to me and subscrihcd before me this 12th day of July 2000 Date , District Justice My commission eXl'ircq tir.;t Monday of January, _ SEAL AOP('oCU'-(4t94l(1nf<<Cn<lC \'j~nl.llit 3.3 ~. " " ~~ ~~'-'~;j . "", PAllY ANN HANES, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V, ROBERT ALLEN HANES, DEFENDANT : 00-2835 CIVIL TERM IN RE: PROTECT/ON FROM ABUSE AND NOW, this ORDER OF COURT l )'"1--.- day of May, 2000, following a hearing on the merits, IT 15 ORDERED: (1) The temporary protection from abuse order entered May 5,2000, is vacated and replaced with this order. (2) Defendant, Robert Allen Hanes, shall not abuse, harass, stalk or threaten Patty Ann Hanes, (3) Defendant may not go to or call plaintiff or contact her, except in an emergency involving the parties' children, at any place she is, employed. (4) A certified copy of this order shall be provided to the Lower Allen Police Department and the East Pennsboro Township Police Department. (5) Defendant shall not be in possession of any weapons during the term of this order and the Cumberland County Sheriff shall, during the term of this order, retain any weapons previously seized from defendant. (6) All other r~lief requested by plaintiff is denied, -~ (7) This order shall remain in'effect for a period of ',e year, ~ ~ 0'\~t<? . " - ~ " , , c. ~bkl_"1 Joan Carey, Esquire For Plaintiff Herbert Goldstein, Esquire For Defendant Sheriff :saa , "': - ,:.; ," ~ . .'1 tf; ", , " TRANSCRIPT OF TAPED 911 CALL FROM PATTY HANES ON 07/09/00 PATTY ANN HANES V. ROBERT ALLEN HANES CHARGES: INDj[RECT CRIMINAL CONTEMPT CIVIL# 00-2835 VOICES RECORDED TO INCLUDE, BUT NOT LIMITED TO: 911 Operator, Cumberland County Communications, Patty Hanes, and Robert Hanes Transcribed by: Christine C. Pulgar at the request of Commander Les Freehling, Cumberland County District Attorney's Office and proof read by: July 24,2000 nwealth'S Comma E')O-ll B 11 d -;\-:.S \co \X6 , ~ '- ~ <- . ---.- ,- ,. ,.,' . ',.j , " 911 OPERATOR: 911, what is your emergency? 911 OPERATOR: 911, what is your emergency? PATTY HANES: Yes, I need a police officer to 328 Blacksmith, B1ack1atch Lane please, Lower Allen, UNIDENTIFIED FEMALE: Stop it. 911 OPERATOR: What's..,? PATTY HANES: My husbands assaulting my girls and myself please hurry, 911 OPERATOR: Okay, does anybody need an ambulance? PATTY HANES: No one does, if you don't hurry we will, UNIDENTIFIED FEMALE: .,. 911 OPERATOR: Stay on the phone, Do not hang up, PATTY HANES: Okay, 911 OPERATOR: Just hold on a minute okay, PATTY HANES: Yes I am, Don't touch her. ROBERT HANES: ", PATTY HANES: You don't grab and slap somebody and hit them because they talk to you, 911 OPERATOR: Lower Allen Township 328 Blacklatch Lane active domestic, UNIDENTIFIED FEMALE: ". PATTY HANES: Yes, the assault of all three of us, 911 OPERATOR: Sounds like an assault. ROBERT HANES: You're out ofline, 911 OPERATOR: What's your name? PATTY HANES: Patly Hanes, H-A-N-E-S, I have a protection from abuse order against this person Robert Hanes, my ex-husband, ROBERT HANES: Hurry up sir get 'em here, 911 OPERATOR: Has he been drinking at all? PATTY HANES: I have no idea sure acts like it. ROBERT HANES: He's out ofline tell 'em, PATTY HANES: And all three of us are nuts right? 911 OPERATOR: Any weapons there? 1 , ,-"-' -', - 1:~ " PATTY HANES: Ah, he they were confiscated from him so I don't believe so. 911 OPERATOR: Yeah, Hanes, What's your phone number there Patty? PATTY HANES: Yeah I'm on the cell phone 877-5727, 91 I OPERATOR: What's your, do you have home phone number there? PATTY HANES: Ah, it's been disconnected, 911 OPERATOR: Okay, Does anybody need an ambulance there? PATTY HANES: Not yet. 911 OPERATOR: Who was assaulted? PATTY HANES: My daughter, my younger daughter, and myself, All three of us were slapped and hit. ROBERT HANES: Oh, you weren't all slapped and hit ", UNIDENTIFIED FEMALE: You grabbed me and hit my head, '" No you", PATTY HANES: You slapped all three of us, 911 OPERATOR: You said no weapons are there, PATTY HANES: I don't think so, 911 OPERATOR: All right, UNIDENTIFIED FEMALE: Oh, my god, ROBERT HANES: Did I touch you Amy? UNIDENTIFIED FEMALE: I don't care if he touched me at all ,. .I'll always remember this, 911 OPERATOR: How old's your daughters? PATTY HANES: My daughters are ten, eleven, fifteen and I'm forty, 911 OPERATOR: Okay, PATTY HANES: Are you guys outside or? 911 OPERATOR: Yes, we are, UNIDENTIFIED FEMALE: Jerk. PATTY HANES: Stay away from him, 911 OPERATOR: Where's he at now? He has a PFA? PATTY HANES: Yes, I have a PF A against him, 911 OPERATOR: All right. Okay the police should be there shortly okay, PATTY HANES: Thank you, 2 '. . . 911 OPERATOR: All righty, "" W h'," ,- -'i 3 . ,---.- itlJ ~ ! (.' ., '. "",,- .. t.; "'. ;'l! LEGAL SERVICES, INC. 8 Irvine Row Carlisle, Pennsylvania 17013 (717) 243-9400 Fax (717) 243-8026 West Shore (717) 766-8475 Shippensburg (717) 530-5866 November 8, 1999 Franklin Farm Lane Chambersburg, Pennsylvania 17201 (717)264-5354 432 S. Wllshington Street Gettysbutg,Penn.syJ.vania17325 (717)334-7623 PLAINTIFF'S EXHIBIT t 5h;;tIOO PiL5 Robert Hanes 328 Black Larch Lane Camp Hill, PA 17011 Mr, Hanes: Ms, Hanes recently came to our office to discuss incidents of abuse in which she says that you have grabbed her inappropriately, pulled her hair, held her to the floor causing injury to her wrists, and squeezed her jaW causing cuts and sores inside her mouth from her braces. Ms, Hanes has been advised of the criminal and civil remedies available to her in Pennsylvania. You should be aware that the criminJ!llaws apply to acts of violence even when they occur persons who are married. The penalty for simple assault, which can include" attempts by physical menace to put another in fear of imminent serious bodily injury" is up to two years imprisonment and a $5,000.00 fine. For harass.ment (including striking, shoving, kicking, alarming or seriously annoying a person), the punishment is up to a $300.00 fine and 90 days imprisonment. Harassment by communication is also a crime punishable by up to one year in prison or a $2500 fine. The crime of stalking includes engaging in a course of conduct such as following someone without proper authority intending to cause the person fear of bodily injury or substantial emotional distress, Stalking is punishable by imprisonment for up to seven years, Ms. Hanes has also been advised of a civil remedy available under the Protection From Abuse Act. Under this Act, she can petition the court to issue a Protection Order, If such an order is entered, it will be placed on file with the police, and if you violate the order, you will be taken before the judge who issued the order, The judge will then decide what punishment is appropriate, A person who violates such an order can be imprisoned for up to six months and/or assessed a $100-1000 fine, Ms, Hanes does not wish to pursue her legal remedi~s against you at this time, but she does want you to be aware that if you physically abuse her or threaten her with violence she will take legal action. I hope your awareness of the consequences of violent acts will help to prevent the recurrence of such acts in the future, I would also like you to be aware that there are counselors in the area who specialize in helping people who wish to eliminate violence from their close relationships. The fees for some counselors are based on the income of the person requesting the SERVING ADAMS, CUMBERLAND, FRANKIJN AND FULTON COUNTIES . Un_ #; ..~h .. ~' , '>; service, In the Carlisle area, Stevens Mental Health Center has sliding scale fees. I strongly recommend these or other counseling services, Sincerely, LEGAL SERVICES, INC, ~y~/ Attorney at Law cc: Patricia Hanes Lower Allen Police Department -~ I,~ 07/10/00 MON 11:49 FAX 717 240 6573 CUMB CO PROTHONOTARY , ~ ~~,-~, fJ.o - .2f>35' (1_.,..-" 141001 TRANSMISSION OK TXlRX NO CONNECTION TEL CONNECTION ID ST. TIllIE USAGE T PGS. RESULT ********************* ... TX REPORT ... ********************* 1979 92490779 07/10 11:46 03'00 4 OK '''' ~". .. . _ ~...f.o _,~",_'...; . , ~ -.- ",'" .1.. PATTY ANN HANES, PLAINTIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V, ROBERT ALLEN HANES, DEFENDANT 00-2835 CIVIL TERM IN RE: PROTECTION FROM ABUSE ORDER OF COURT AND NOW, this l f'\" day of May, 2000, following a hearing on the merits, IT IS ORDERED: (1) The temporary protection from abuse order entered May 5, 2000, is vacated and replaced with this order. (2) Defendant, Robert Allen Hanes, shall not abuse, harass, stalk or threaten Patty Ann Hanes, (3) Defendant may not go to or call plaintiff or contact her, except in an emergency involving the parties' children, at any place she is employed. (4) A certified copy of this order shall be provided to the Lower Allen Police Department and the East Pennsboro Township Police Department. (5) Defendant shall not be in possession of any weapons during the term of this order and the Cumberland County Sheriff shall, during the term of this order, retain any weapons previously seized from defendant. (6) All other relief requested by plaintiff is denied, (7) This order shall remain in effect for a period. ~ ~ 9\",*-,<7 :i! "~I ;j oj ;, , :1 " . .~ --~ " ,- r ,~ ~ 'I : '" , "'-:-'"~.- ~~-]- 'T[Illill\ll!1', - r\LtO-O~f\CE Or.: ,\ ,,' ,--,,"f,'-' ''''''O,...r)V .t ,"\:: ;.;~,_.--",-',\)\\~, 11i"\f1.1 GO \"'r.\~ \ S ~~ II: \ 4 C' \~'OPO'l ;",;i, ('(")\1'\'\""" \,.Illm...-.....:. .r1O>.J,U J'.... J....\ I ?ENNSY01J0\r~\r" :-"~ ~~41"-r-~'_'c~ p_~' "I, -I ~- . ,~ ,~ ''" ~<'""~"","'''~'~M" ',; ,_~ ,." "", Joan Carey, Esquire For Plaintiff Herbert Goldstein, Esquire For Defendant Sheriff :saa . PATTY ANN HANES, : IN THE COURT OF COMMON PLEAS Plaintiff :OF CUMBERLAND COUNTY, PENNSYLVANIA vs, :NO, bo - :JPdS CIVIL TERM ROBERT ALLEN HANES, Defendant ;PROTECTION FROM ABUSE ,Lk ~ ,U--<J HEARING AND ORDER g/ 1')/ NOTICE OF YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers. you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on this matter is scheduled for the I"'-t:.h May. 2000. at I: 15 I' .m.. in Courtroom NO.r of the Courthouse, Carlisle, Pennsylvania. day of Cumberland County 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. 16114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law. 18 U.S.C. 12265. 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. 12261-2262. 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. n ') ~ 1 _ 6 CUMBERLAND COUNTY BAR ASSOCIATION I Vee / <-to ~ 2 LIBERTY AVENUE .. _ J'::> CARLISLE. PENNSYLVANIA 17013 {!J.'IIe0- . ';'~;;P.HONE NUMBER: (717) 249-3166 /J./'l Ie v It ~AMERICANS WITH DISABILITIES ACT OF 1990 -So ~tf 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 accessibl~ 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. ~- .,. " 'h"-' j PATTY ANN HANES, :IN THE COURT OF COMMON PLEAS Plaintiff : OF CUMBERLAND COUNTY, PENNSYLVANIA vs, :NO. 00 - ;)j>JS CIVIL TERM ROBERT ALLEN HANES, Defendant :PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on this matter is scheduled for the I'Jl~ May, 2000, at I: 1.5 P.m., in Courtroom NO.r. of the Courthouse, Carlisle, Pennsylvania. day of Cumberland County 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 NHERE 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 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 . - ". ~ ,..~-~ -~f Temporary Pr~tection, From Abuse Order Patty Ann Hanes Plaintiff : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v, : No, /I) -cA (u- ()-(;..;2~3)~ Robert Allen Hanes Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Robert Allen Hanes Defendant's Date of Birth is: February 2,1960 Defendant's Social Security Number is: 191-46-4784 Name(s) of All protected persons, including Plaintiff and minor children: 1. Patty Ann Hanes AND NOW, on 5th Day of May, 2000 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: Plaintiff's 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 shall be evicted and excluded from the residence at: 328 Black Latch Lane, Camp Hill, Pa. 3. Except for such contact with the minor child/ren as may be permitted under paragraph 5 of this Order, 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. Defendant is specifically ordered to stay away from the following locations for the duration of this order, Plaintiffs place of employment located at KLNB - Campbell Commercial Real Estate, 207 House Avenue, St. 107, Camp Hill, Pennsylvania .,,/temporder,asp?TempOrderID=8798&cmdMove=View+Completed+ Temporary+Order&pfadnu 5/5/00 .~ ,~ .u. '^ ~ . ,,---~~ -'-';; .,,- '.", " Temporary Pr~tection From Abuse Order Page 2 of3 4. Except for such contact with the minor child/ren as may be permitted under paragraph 5 of this Order, Defendant shall not contact Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons, 5. Pending the outcome of the final hearing in this matter, Plaintiff is awarded temporary custody of the following minor child/ren: I, Nicole Christine Hanes 2, Amy Michelle Hanes Until the final hearing, all contact between Defendant and the child/ren shall be limited to the following: None 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 the Plaintiff in accordance with the terms of this Order. 6. The following additional relief is granted: - Defendant owes a duty of support to Plaintiff and/or minor child/ren. - Order Defendant to pay temporary support to Plaintiff and/or the minor child/ren, including medical support, and payment of the rent or mortgage on the residence. - Order Defendant to pay the costs of this action, including fIling and service fees. - -Order Defendant to pay $250.00 to reimburse one of Legal Services, Inc. 's funding sources for the cost of litigation in this case. -No harassment of Plaintiff's relatives -No destruction or damage of Plaintiff's property or jointly owned property 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Lower Allen Police Department East Pennsboro Township Police 8. 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, ".ltemporder.asp?TempOrderID=8798&cmdMove=View+Completed+ Temporary+Order&pfadnu 5/5/00 f ~lIIIl ., Temporary Protection From Abuse Order . , Page 3 of3 . , 9. THIS ORDER APPLIES IMMEDIA TEL Y TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MAYS, 2001 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS 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 in jail. 23 Pa,C,S, 96114, 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. 96113, 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, 992261- 2262, NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiff's residence OR any location where a violation of this order occurs OR where the defendant may be located, If defendant violates Paragraphs 1 through 5 of this Order, defendant shall 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. 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 COURT: d- ___-:!~,-d-~--, ....,. ..,... . ...._ ~ /!':--' L:. "",'<<.0 Judge _____~~- .... C ~....____ Date Distribution to: J LegalS~ces ~ Faxed & Mailed to PSP .5/.5) ., .Itemporder,asp?TempOrderID=8798&cmdMove=View+Completed+ Temporary+Order&pfadnu 5/5/00 Wi ~." "'" ~. "".~ . FiLED-OFFICE ,.,~ ,! "~ '~l"'\,r<"'" .--,l"I/~-r!\IRY ,,\.)t" :r';r::. ;'";':\..,ifr;(j,i1..)lf\i 0, 0 Il~V -'~ P~i '1: 0" ridl ...;. 0... ',_ CUM6EfiLANC COUN1Y PENNSYLVf,NiA tH!IB!Ml ,,., <'"'~....,... '''---''<c"',Y<'- "rf' .1liI!1l!>U 1?l~~""""Jl'll~~~! ._",-, "'" .,~""'Il!_ ~l!Il1!!! ".~. - I~~ , ,- ',-- lLil"", 'ji) Petition For Protection From Abuse Page 1 of5 PF AD Number: MWl084323W Patty Ann Hanes : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYL VANIA Plaintiff v, fJ-(J _ .iI' 3:S ~ -r v-.-- : No, Robert Allen Hanes Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE I. Plaintiff's name is: Patty Ann Hanes 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. Patty Ann Hanes 4, Plaintiff's Address is : 328 Black Latch Lane, Camp Hill, Pa 17011 5, Defendant's Name is: Robert Allen Hanes 6. Defendant is believed to live at the following address: 328 Black Latch Lane, Camp Hill, Pa 17011 7, Defendant's Social Security Number is: 191-46-4784 8. Defendant's Date of Birth is: February 2, 1960 "./petition,asp?PetitionID=7299&cmdMove=View+Completed+Petition&pfadnum=MWl 084323 5/5/00 ~ . '~.",",- ~, , . ~- .- - ~ jj.,*~, Petition For Protection From Abuse Page 2 of 5 .' 9. Defendant's Place of employment is: Inclinator Company of America, 2200 Paxton Street, Harrisburg 10, Defendant is an adult. II, The relationship between the Plaintiff and the Defendant is: Spouse 12. The Plaintiff and the Defendant been involved in the following court actions: a. Divorce 13, Other details of the court action are: Defendant fIled for divorce - Plaintiff served April 28, 2000. 14. The defendant has not been involved in a criminal court action, 15, Plaintiff and Defendant are the parents of the following minor child/ren: a. Nicole Christine Hanes Age:15 Child's address is: 328 Black Latch Lane, Camp Hill , Pa 17011 b, Amy Michelle Hanes Age:10 Child's address is: 328 Black Latch Lane, Camp Hill, Pa 17011 16, Plaintiff is seeking an Order of child custody as part of this petition. The following is a list of the children and where they have live for the past 5 years: a. Nicole .Christine Hanes For the past 5 years, this child has lived with: 1991-1998 213 AIlendale Way, Camp Hill, Pa. 17011 - Plaintiff & Defendant 1998-present 328 Black Latch Lane, Camp Hill, Pa.17011 - Plaintiff & Defendant b, Amy Michelle Hanes For the past 5 years, this child has lived with: 1991-1998 213 Allendale Way, Camp Hill, Pa. 17011 - Plaintiff & Defendant 1998-present 328 Black Latch Lane, Camp Hill, Pa. 17011 - Plaintiff & Defendant .,./petition,asp?PetitionID=7299&cmdMove= View+Completed+Petition&pfadnum=MWI 084323 5/5/00 '[' . "' .,"--;,-. lfi:iIIi:t, Petition For Protection From Abuse Page 3 of5 17. The facts of the most recent incident of abuse are as follows: On about Thursday, April 27, 2000 at approximately 11 :30PM location: 328 Black Latch Lane, Camp Hill, Pa. 17011 While Plaintiff was asleep, Defendant entered her bedroom, grabbed her by her face and held her down on the bed for approximately fifteen minntes as he yelled and screamed at her. Plaintiff was able to get her cell phone to call the police but Defendant grabbed it from her and threw it across the room. Plaintiff was able to get to another phone and telephone the Lower Allen Township Police. 18. 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: Since October 1999, approximately once a week, Defendant has abused Plaintiff in ways including: prevented her from leaving a room by placing his body in front of her or her exit, forced her against walls with his body, threatened to enter her bedroom and force intercourse on her, pushed her, and grabbed her by the face, squeezing her jaw, causing lacerations and bleeding inside her mouth. Defendant grabbed Plaintiff by the breasts and genital area. Defendant also stalked Plaintiff in ways including, driving by her workplace; telephoning Plaintiffs place of employment; interrogating her boss, the boss's wife, and other co-workers, following her wherever she goes and leaving notes on her car to let her know he is watching. On or about October 24, 1999, Defendant grabbed Plaintiff. The children woke up and the defendant told them that if they called the police, they would put them in foster care. Defendant took the plantiffs cell phone and disabled the other phones so she could not get help. On or about October 23, 1999, Defendant grabbed the plaintiff by her wrists, threw her to the floor, straddled her, pinned her down by her wrists, grabbed her breasts and genital area, and told her that her body parts were his and he could do what he wanted. 19. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: Lower Allen Police Department East Pennsboro Township Police 20. There is an immediate and present danger of further abuse from the Defendant. 21. Plaintiff is asking the court to evict and exclude the Defendant from the following residence: 328 Black Latch Lane, Camp Hill, Pa. Owned By: Patty and Robert Hanes 22. The Defendant owes a duty of support to Plaintiff and/or minor child/ren. 23. 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. ...Ipetition.asp?PetitionID=7299&cmdMove=View+Completed+Petition&pfadnum=MWI084323 5/5/00 ">; ~. . .--, ...! Petition For Prptectio!l Prom Abuse . Page 1 of5 . b. Evict/exclude Defendant from Plaintiff's residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff. c. A ward Plaintiff temporary custody of the minor child/ren and place the following restrictions on contact between Defendant and child/ren: d. 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 Plaintiff's school, business, or place of employment, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/ren. e. Order Defendant to pay temporary support to Plaintiff and/or the minor child/ren, including medical support and payment of the rent or mortgage on the residence. f. Order Defendant to pay the costs of this action, including filing and service fees. g. Order the following additional relief, not listed above: -Order Defendant to pay $250.00 to reimburse one of Legal Services, Inc.'s funding s.ources for the cost of litigation in this case. -No harassment of Plaintiff's relatives -No destruction or damage of Plaintiff's property or jointly owned property h. Grant such other relief as the court deems appropriate. 1. Order the police or other law enforcement agency to serve the Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. Respecffully Submitted b~ Agency: LEGAL SERVICES, / .. .Ipetition.asp?PetitionID=7299&cmdMove=View+Completed+Petition&pfadnum=MWl 084323 5/5/00 ~ ..- ,., , ~-. ..;,; -, . . VERIFICATION I verify that I am the Plaintiff as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. Dated: shIm f~~ Patty Ann Hanes, Plaintiff .. _~r~r'l ~~i~~~$~ . - -, ...........~j,D.ilf:iI. ~"'"""........ - ., ~~--~ -.:~rWit'ffilIiWMi ,: - I "~ () f; "1:;0" fn1P .<!,.;.j ls .S~ ~;~ r,,,',_, -e ;z: -.. -< ~- , . -- r , I f l I 1 I, I I I o Q ~ l:Yto ~ I UJ o 'T) ,:J:!........... "">- '..'.... '. ., ;}T-. ,~~.,~- C), - - . '~I;,.'..... ., ---".. - ---<"4 ._' C) , ". j;! -':1 =:.: -u ~ S~.) ,-,. - ~~" -,-.- SHERIFF'S RETURN - REGULAR CASE NO: 2000-02835 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND HANES PATTY ANN VS HANES ROBERT ALLEN CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County, Pensyl vania , who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon HANES ROBERT ALLEN the DEFENDANT , at 0017:30 HOURS, on the 5th day of May , 2000 at 328 BLACK LATCH LANE CAMP HILL, PA 17011 by handing to ROBERT A. HANES a true and attested copy of PROTECTION FROM ABUSE together with NOTICE OF HEARING & ORDER, TEMPORARY PROTECTION FROM ABUSE ORDER, PETITION and at the same time directing His attention to the contents thereof. Additional Comments DEFENDANT TURNED HIS LICENSE TO CARRY FIREARMS OVER TO CUMBERLAND COUNTY DEPUTIES AT TIME OF SERVICE OF PFA. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.30 .00 10.00 .00 37.30 So Answers: r-~A"l~" R. Thomas Kline 05/09/2000 sworq' and Subscribed to before By: me this /~ ~ day of ~ :;~, A.D. G ur1 ~ ~ rqthonotary , '~><1.~- , i , , ; , I I I I j I , - . I I I , I I I . - .,~- . L ! I I , j i ,--_.-_~ ,. I I i.. Jj I ___J ! :'M_' _ ____ I I -11\ 1 i -' -.- ., i .1- I , , I " I I , , (, i I I f i , I , , I I . , - I ! , ! I I j I I i -,--- t I 0'+ I i i H_' ~_ I ! I , t I l I 1 I i I I I n_"-t I i I i j ! I i ,.--- ~" , , i ! j I I ., ' j i j I ! , t i 1 1 i. ~, -_.J i i .1 I I ! I I I ! j I i , ! I , I 1 I ! 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