Loading...
HomeMy WebLinkAbout00-03067REBECCA MARTHA EDWARDS, Plaintiff vs. MARK STEPHEN EDWARDS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : tU- 2000-3067 CIVIL TERM PROTECTION FROM ABUSE ORDER OF COURT AND NOW, this,2Aay of June, 2000, upon consideration ofthe within Petition, the portion of the Final Order of Court in the above-captioned case dated May 22, 2000, which evicted and excluded Defendant, Mark Stephen Edwards, from the residence at 50 Bonnybrook Road, Lot 35, Carlisle, Cumberland County, Pennsylvania, is vacated. On May 30, 2000, after a hearing on charges of Indirect Criminal Contempt in this matter, an Order was issued modifying the Final Order of Court dated May 22, 2000, vacating paragraph 3, which prohibited Defendant from having any contact with Plaintiff at specific locations, and paragraph 4, which ordered Defendant not to have contact with Plaintiff by any means. In all other respects the Final Order of Court entered on May 22, 2000, remains in effect. Joan Carey, Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 Mark Stephen Edwards 50 Bonnybrook Road, Lot 35 Carlisle, PA 17013 ?1IlJ w t7 Ps P_ D cyl =a c C5 By the Court, REBECCA MARTHA EDWARDS, Plaintiff vs. MARK STEPHEN EDWARDS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-3067 CIVIL TERM PROTECTION FROM ABUSE PETITION FOR MODIFICATION Plaintiff, Rebecca Martha Edwards, by and through her attorney, Joan Carey, of LEGAL SERVICES, INC. represents the following: Plaintiff and Defendant, Mark Stephen Edwards, are in the process of reconciling their differences. 2. Plaintiff desires that Defendant no longer be excluded from the residence located at 50 Bonnybrook Road, Lot 35, Carlisle, Cumberland County, Pennsylvania. 3. Plaintiff desires that all other provisions of the Final Order of Court entered on May 22, 2000, remain in effect. WHEREFORE, Plaintiff requests that the Final Order of Court entered on May 22, 2000, be modified to reflect the above terms. Respectfully submitted, Jo Carey, Attorney fo aintiff LEGAL SERVICES, C. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S.§4904, relating to unsworn falsification to authorities. Dat4,,? On& 7 s 60 11 t . _ McJa-ed?' Rebecca Martha Edwards, Plaintiff Z?, ?yrr ? t O G REBECCA MARTHA EDWARDS, Plaintiff vs. MARK STEPHEN EDWARDS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA NO. 2000-3067 CIVIL TERM PROTECTION FROM ABUSE RDER OF COURT IQQ? AND NOW, this 1--1- day of June, 2000, upon consideration of the attached Petition, the Final Order of Court entered on May 22, 2000, in the above-captioned case, and the Order of Court of June 2, 2000, are hereby vacated and the action withdrawn without prejudice to Plaintiff. Joan Carey Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Cgle, PA 17013 Mark Stephen Edwards, Defendant 50 Bonnybrook Road, Lot 35 Carlisle, PA 17013 By the Court, *rPres)idnt Judge C L g ? Qy?, ?T s. ?. ;.Eft ^IVNSYLVAN[."A t REBECCA MARTHA EDWARDS, Plaintiff vs. MARK STEPHEN EDWARDS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000-3067 CIVIL TERM PROTECTION FROM ABUSE PETITION TO VACATE ORDER AND WITHDRAW ACTION Plaintiff, Rebecca Martha Edwards, by and through her attorney, Joan Carey of Legal Services, Inc., states the following: 1. A Petition for Protection From Abuse was filed and a Temporary Protection From Abuse Order was issued by this Court on May 17, 2000, scheduling a hearing for May 22, 2000, at 11:00 a.m. before Judge Hoffer in Courtroom No. 3 of the Cumberland County Courthouse. A Final Order of Court was entered after hearing on May 22, 2000. 2. On May 30, 2000, after a hearing on charges of Indirect Criminal Contempt in this matterwherein Defendant admitted that he was in contempt. Pursuant to an agreement ofthe parties, the Court entered an Order which vacated paragraph 3 of the Final Order of Court that prohibited Defendant from having any contact with Plaintiff at specific locations, and paragraph 4 which ordered Defendant not to have any contact with Plaintff by any means. 3. Plaintiff indicated to Legal Services, Inc. staff that she and Defendant were in the process of reconciling their differences and requested that the Final Order of Court be modified so that Defendant no longer be excluded from the marital residence. On June 2, 2000, an Order of Court was entered vacating the exclusion provision of the Final Order of Court. 4. Based on the parties' reconciliation, Plaintiffrequeststhat the Orders ofCourt entered on May 22, 2000, and June 2, 2000, be vacated and the action withdrawn without prejudice to her. WBEREFORE, Plaintiff requests that the Court grant the relief requested and vacate the Orders of Court entered May 22, 2000, and June 2, 2000, and that the action be withdrawn without prejudice to Plaintiff. Respectfiilly submitted, o Carey, Attorney f laintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ?o. o C L' 0%5 VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C. S. §4904, relating to unsworn falsification to authorities. Dated/ 12400 Rebecca Martha Edwards, Plaintiff F? ; .Z c_ ca ,;z` _ _'?' ?_ iJ3_ ? _ ?1.? ?_??e°, i . ` W _ f:! a ... ..... ... ........:??.:I.....? .... vow... .._..d._._._.:.. ??... ??_.. .. ...:. ...... ...<.v ..v..v'..:w ?.:=b...?..a e . 1 06/20/A0 TUE 12:46 FAX 717 240 6573 CUMB CO PROTHONOTARY Id nni azxaxxxxaxaxxxxsxaxxx aas T% REPORT sxx saassaaxsassaasaaasaa TRANSMISSION OH T%/R% NO 1937 CONNECTION TEL 92490779 CONNECTION ID ST. TIME 06/20 12:45 USAGE T 00'55 PGS. 2 RESULT OR REBECCA MARTHA EDWARDS, Plaintiff vs. MARK STEPHEN EDWARDS, Defendant : IN THE COURT OF COMMON :PLEAS OF : CUMBERLAND COUNTY, :PENNSYLVANIA CIVIL ACTION - LAW No. 00-3067 PROTECTION FROM ABUSE ORDER TO DISMISS AND NOW, this: 12th Day of June, 2000, upon Plaintiffs motion to withdraw or discontinue this action, 1. This matter is dismissed without prejudice. 2. Costs of this proceeding are placed upon: MARK STEPHEN EDWARDS (Defendant). Costs are to be paid at: Prothonotary's Office of Cumberland County. Costs are to be paid by: May 22, 2001. 3. The Final Order (Filed on June 2, 2000) is hereby dismissed. BY THE COURT: George E. Hoffer, . Ju ge Date Distribution to: LEGAL SERVICES, INC. Joan Carey, Attorney for Plaintiff Mark Stephen Edwards, Defendant 50 Bonnybrook Road, Lot 35 Carlisle, PA 17013 (etas GQ?iru- .?UT? ? (] FAXed & Mailed to PSP 07/10/00 NON 13:16 FAX 717 240 6573 CUMB CO PROTHONOTARY U-? "30& / a001 'I aaaxxaaxxasaaxzaaaaaa xxa TX REPORT ssz sxsaaxsaasxzassxzsaax TRANSMISSION OR TX/RX NO 1980 CONNECTION TEL 92490779 CONNECTION ID ST. TIME 07/10 13:15 USAGE T 01'46 PGS. 3 RESULT OH -REBECCA MARTHA EDWARDS, Plaintiff vs. MARK STEPHEN EDWARDS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000- 3 a CIVIL TERM 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. Ifyou 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. 6 A hearing on this matter is scheduled on the A mday of May, 2000, at CourtroomNo. _3 ofthe Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania. You MUST obey the Order that is attached until it is modified or terminated by the court after notice apd hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six months in jail under 23 Pa.C. S. §6114. Violation may also subject you to prosecution and criminal penalties un&r 1lie Pennsylvania Crimes Code. Under federal law, 18 U.S.C. §2265, this Order is enforceable anywhere in the United States, tribal lands, U. S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. § 2261-2262. You should take this paper to your lawyer at once. You have the right to have a lawyer represent you at the hearing. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. if you cannot find a lawyer, you may have to proceed without one. CUMBERLAND COUNTY BAR ASSOCIAT 6N 2 Liberty Avenue, Carlisle, Pennsylvania 17013 Telephone Number: (717)249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law t9 comply with the Americans with Disabilities Act of 1990. For information about accessible fa and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference 9 hearing. RED-.01-F1CE Or Ti y" nn, ?„cCINOTARY RR El,Y 17 P.' 2: t.$ ?c 11 r'ENi aS`YLV ^ m Thi REBECCA MARTHA EDWARDS, Plaintiff vs. MARK STEPHEN EDWARDS, Defendant : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION - LAW No.,'o PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: MARK STEPHEN EDWARDS Defendant's Date of Birth is: September 22, 1965 Name(s) of All protected persons, including Plaintiff and minor children: 1. REBECCA MARTHA EDWARDS AND NOW, on 17th Day of May, 2000 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: Plaintiffs request for a temporary protection order is granted. 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. 2. Defendant shall be evicted and excluded from the residence at: 50 Bonnybrook Road Lot 35 Carlisle, PA 17013 3. 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 current residence which is at an undisclosed location for her protection, or at any other location where she may reside. Plaintiffs place of employment at Lear Corporation, 50 Spring Road, Carlisle, PA 4. 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. Defendant shall immediately relinquish any firearms license the Defendant may possess, and the following weapons to the Sheriffs Office or a designated local law enforcement agency for delivery to the Sheriffs Office. 1. any and all firearms, specifically, a shotgun Defendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration of this order. 6. The following additional relief is granted: This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service. The Prothonotary shall not send a copy of this Order to Defendant by mail. Law enforcement agencies, human service agencies and school districts shall not disclose the presence of Plaintiff in the jurisdiction or district or furnish any address, telephone number, or any other demographic information about Plaintiff, except by further Order of Court. Defendant is required to relinquish to the sheriff any firearm license Defendant may possess. Defendant's weapons and firearm license may be returned at the expiration of the Protection Order after Defendant has submitted a written request to the Court for the return of the weapons and the Court has notified Plaintiff of the request and given Plaintiff an opportunity to respond. A copy of this Order shall be transmitted to the chief or head of the police department of where Defendant resides (Pennsylvania State Police, Carlisle)and the sheriff of Cumberland County. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. Defendant is to refrain from harassing Plaintiff's relatives. 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Pennsylvania State Police - the marital residence Carlisle Police Department - Plaintiffs place of employment 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. 9. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MAY 17, 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. §6114. Consent of the Plaintiff to Defendant's return to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. §6113. Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. §§2261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiffs residence OR any location where a violation of this order occurs OR where the defendant may be located. If defendant violates Paragraphs 1 through 5 of this Order, defendant shall be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence of law enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriffs office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this court, unless the weapons are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. Distribution to: Legal Services, Inc. Joan Carey, Attorney for Plaintiff Faxed & Mailed to PSP PFAD Number: QL108832,7T REBECCA MARTHA EDWARDS, Plaintiff : IN THE COURT OF COMMON : PLEAS OF vs. MARK STEPHEN EDWARDS, Defendant : CUMBERLAND COUNTY, : PENNSYLVANIA CIVIL ACTION - LAW No. Ov _ 306 7 T? PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE 1. Plaintiffs name is: REBECCA MARTHA EDWARDS 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. REBECCA MARTHA EDWARDS 4. Plaintiffs address is confidential 5. Defendant's Name is: MARK STEPHEN EDWARDS 6. Defendant is believed to live at the following address: 50 Bonnybrook Road , Lot 35, Carlisle, PA 17013 7. Defendant's Date of Birth is: September 22, 1965 8. Defendant's Place of employment is: Mike Lamaster Roofing, 2101 Longs Gap Road, Carlisle, PA 9. Defendant is an adult. 10. The relationship between the Plaintiff and the Defendant is: Spouse 11. The facts of the most recent incident of abuse are as follows: On about Saturday, May 06, 2000 location: 50 Bonnybrook Road, Lot 35, Carlisle, PA, the marital residence On or about May 6, 2000, Defendant grabbed Plaintiff by her arms and shoved her, causing a bruise on her arm. 12. 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: On or about April 24, 2000, Plaintiff awoke to Defendant yelling, and the sound of glass breaking. Plaintiff entered the room, saw that Defendant had broken the coffee carafe, and when she asked him what happened, he yelled at her threatening, "You're going to die today; I'm going to kill you or you're going to leave this house today." Fearing for her safety, Plaintiff tried to call 911 for help, but Defendant grabbed the telephone out of her hand, pulled the telephone console off the wall, and threw it down on the floor, hitting her feet with it. As Plaintiff tried to get to the door to leave, Defendant got to the door ahead of her, stood in front of it blocking it with his body, and told her that she wasn't going anywhere. On or about April 7, 2000, Defendant threatened Plaintiff saying that one day he would lure bier into the woods and do away with her. On or about April 5, 2000, Defendant punched Plaintiff on the forearm with his knuckles, causing bruising on her arm. On or about April 1, 2000, when Plaintiff' asked Defendant to hand her the cigarette lighter, he threw it at her hitting her on the forehead with it. Plaintiff sustained bruising on her forehead as a result of this incident. In or about January 2000, Defendant wanted Plaintiff to make up with him after he argued with her, and when she would not voluntarily hug him, he grabbed her arms, wrapped them around his neck and held her arms tightly. Plaintiff sustained bruising on her arm as a result of this incident. On or about December 25, 1999, Defendant used his arm to clear the table of food and drink, causing it to splatter on the floor and walls. Then he kicked the chair that Plaintiff was sitting on, causing her to fall to the floor, and when she tried to get out the door, Defendant blocked the doorway with his body, grabbed her by the arm, and shoved her into the living room and down onto the couch. Defendant raised a large glass-encased candle above his head, causing Plaintiff to fear that he was going to hit her on the head with it. Then he set the candle down, and took a shotgun off a rack on the wall, causing her to fear that he was going to shoot her. Since approximately 1999, Defendant has abused Plaintiff in ways including, but not limited to, grabbing her arms, breasts, and buttocks, punching her, shoving her about, and restraining her, punching walls and appliances; throwing household objects about such as the telephone; and intimidating and controlling Plaintiff. Defendant threatened to kill Plaintiff several times. 13. The Defendant has used, or threatened to use, the following weapon(s) against the Plaintiff or the minor chiid(ren: a. any and all firearms, specifically, a shotgun 14. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: Pennsylvania State Police - Plaintiffs residence Carlisle Police Department - Plaintiffs place of employment 15. There is an immediate and present danger of further abuse from the Defendant. 16. Plaintiff is asking the court to evict and exclude the Defendant from the following residence: 50 Bonnybrook Road Lot 35 Carlisle, PA 17013 Owned By: Defendant, Mark Stephen Edwards (Plaintiffs father bought the mobile home for her and she signed the title over to Defendant before they married in 1999). 17. Plaintiff has suffered out-of-pocket financial losses as a result of the abuse described above. Those losses are: Lost wages 18. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or minor child/ren in any place where Plaintiff may be found. b. Evict/exclude Defendant from Plaintiffs residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff. c. Require Defendant to provide Plaintiff and/or minor child/ren with other suitable housing. 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 Plaintiffs 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. Prohibit Defendant from having any contact with Plaintiffs relatives and Plaintiffs children listed in this petition, except as the court may find necessary with respect to partial custody and/or visitation with the minor children. f. Order Defendant to temporarily turn over weapons to the Sheriff of this County and prohibit Defendant from transferring, acquiring, or possessing any such weapons for the duration of the Order. g. Direct Defendant to pay Plaintiff for the reasonable financial losses suffered as the result of the abuse, to be determined at the hearing. h. Order Defendant to pay the costs of this action, including filing and service fees. i. Order the following additional relief, not listed above: Defendant is required to relinquish to the sheriff any firearm license Defendant may possess. Defendant's weapons and firearm license may be returned at the expiration of the Protection Order after Defendant has submitted a written request to the Court for the return of the weapons and the Court has notified Plaintiff of the request and given Plaintiff an opportunity to respond. Petition For`Protection From Abuse Page 5 of 5 Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. Defendant is to refrain from harassing Plaintiff's relatives. Order Defendant to pay $250.00 to reimburse one of Legal Services, Inc.'s funding sources toward the cost of litigation in this case. j. Grant such other relief as the court deems appropriate. k. 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. VERIFICATION I verify that I am the petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the Penalties of 18 Pa. C. S. §4904, relating to unswom falsification to authorities I t"o - r7]A; Al a, utter is . Signature I7lGta1? , t )b Date 0 Respectfully Submitted by: 6Y6kn Carey, Attorney Agency: LEGAL SERVICES, ` V Q - • l ww? W O d? F P.5/17/00 WED 15:32 FAX 717 240 6573 CUMB CO PROTHONOTARY oo. 30(,'1 I1001 sssssssssssssssssssss sss TX REPORT sss 888888888888888888888 TRANSMISSION OR TX/RX NO 1868 CONNECTION TEL 92490779 CONNECTION ID ST. TIME 05/17 15:28 USAGE T 03'24 PGS. 6 RESULT OR 'A05/18/00 THU 08:21 FAX 717 240 6573 CURB CO PROTHONOTARY f?J001 *?x:ts*a?xa??ss?????xx*x az T% REPORT *:a ??s??xasx??as*axa??x?ixa? TRANSMISSION OH T%/R% NO 1869 CONNECTION TEL 92490779 CONNECTION TO ST. TIME 05/18 08:19 USAGE T 02'06 PGS. 3 RESULT OR CERTIFICATION OF PFA CONTT34PP CASE NCMBER 2000-3067 Civil Term NAME Mark Edwards VICTIM'S NAME: 50 Bonnybrook Road, Lot 35 Raharra F.r9warHa Carlisle PA 17013 BALANCE DUE: $ 106.20 ADD DELETE 170 STATE SURCHARGE $ $ 171 STATE FINE $ $ 260 SHERIFF COST ($1.50 + ADDTL) $ 35.70 $ 207 DISTRICT ATTORNEY $ 10.00 $ _ 204 COURT COSTS (CLERK OF COURTS) $ 15.00 $ _ 502 RESTITUTION NAME Prothonotary $ 45.50 $ ADDRESS CITY STATE ZIP NAME ADDRESS CITY NAME CITY PROTHONOTARY OFFICE PERSON CERTIFYING INFORMATION C STATE ZIP STATE ZIP CERTIFICATION OF PEA CONTEMPT CASE Ntj4BER 00-3067 Civil Term NAME Mark Stephen Edwards A VICTIM'S NAME: Rebecca Martha Edwards BALANCE DUE: $ 106.20 (Previous balance) + $275.00 = ADD $381.20 DELETE 170 STATE SURCHARGE (DOMESTIC VIOLENCE) $ 25.00 $ 171 STATE FINE $ $ 260 SHERIFF COST ($1.50 + ADDTL) $ $ 207 DISTRICT ATTORNEY $ $ _ 204 COURT COSTS (CLERK OF COURTS) $ $ 502 RESTITUTION NAME Legal Services, Inc. $ 250.00 $ ADDRESS CITY STATE ZIP NAME $ $ ADDRESS CITY STATE ZIP NAME $ $ ADDRESS CITY STATE ZIP PROTHONOTARY OFFICE PERSON CERTIFYING INFORMATION REBECCA MARTHA EDWARDS, Plaintiff VS. MARK STEPHEN EDWARDS, Defendant : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : CIVIL ACTION - LAW No. 00-3067 PROTECTION FROM ABUSE FINAL ORDER OF COURT Defendant's Name is: MARK STEPHEN EDWARDS Defendant's Date of Birth is: September 22, 1965 Name(s) of All protected persons, including Plaintiff and minor children: 1. REBECCA MARTHA EDWARDS AND NOW, this 22nd Day of May, 2000 the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows: After hearing the testimony and upon finding that the Plaintiff and/or minor child(ren) has/have been abused within the meaning of the Protection From Abuse Act, the following Order is entered. Plaintiffs request for a final protection order is granted. 1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other protected person in any place where they might be found. 2. Defendant is completely evicted and excluded from the residence at: 50 Bonnybrook Road Lot 35 Carlisle, PA 17013 or any other residence where Plaintiff may live. Exclusive possession of the residence is granted to Plaintiff. Defendant shall have no right or privilege to enter or be present on the premises. 3. Defendant is prohibited from having ANY CONTACT with the 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 employement. Defendant is specifically ordered to stay away from the following locations for the duration of this order. Plaintiffs current residence at 50 Bonnybrook Road, Lot 35, Carlisle, PA, or at any other location where she may reside. Plaintiffs place of employment at Lear Corporation, 50 Spring Road, Carlisle, PA 4. Defendant shall not contact the Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 5. Defendant shall immediately turn over to the Sheriffs Office, or to a local law enforcement agency for delivery to the Sheriffs Office, any firearms license the Defendant may possess, and the following weapons used or threatened to be used by Defendant in an act of abuse against Plaintiff and/or the minor children. 1. any and all firearms, specifically, a shotgun and a bow and arrow, crossbow, and bolts 6. Defendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration of this order. The Defendant has 30 days after expirations of this order to petition the Court for return of confiscated weapons. 7. The following additional relief is granted as authorized by §6108 of the Act: Law enforcement agencies, human service agencies and school districts shall not disclose the presence of Plaintiff and/or address, telephone number, or any other demographic information about Plaintiff, except by further Order of Court. This Order shall remain in effect until modified or terminated by the Court and can be extended beyond its original expiration date if the Court finds that Defendant has committed an act of abuse or has engaged in a pattern or practice that indicates risk of harm to Plaintiff. Defendant is required to relinquish to the sheriff any firearm license Defendant may possess. Defendant's weapons and firearm license may be returned at the expiration of the Protection Order after Defendant has submitted a written request to the Court for the return of the firearms and/or weapons and the Court has notified Plaintiff of the request and given Plaintiff an opportunity to respond. A copy of this Order shall be transmitted to the chief or head of the police department of where Defendant resides (Pennsylvania State Police) and the sheriff of Cumberland County. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. Defendant is to refrain from harassing Plaintiff's relatives. Pursuant to 23 Pa.C.S.A. Section 6108 (a)(10), within thirty (30) days of entry of this order,Defendant is required to submit himself to a psychological evaluation at the Stevens Center, Carlisle, PA, (717) 243- 6033, or the Holy Spirit Hospital, Camp Hill, PA, (717) 763-2228, both of which offer psychological evaluations on a sliding scale fee basis. Defendant shall enter and complete a program for anger and control issues. Defendant shall abide by the recommendations of the psychologist/counselors. Prior to the psychological evaluation, Defendant shall give notice to Legal Services, Inc., of the location, date, and identity of the evaluator. Defendant shall release Legal Services, Inc., to communicate with his psychologistlcounselors regarding the results of his psychological evaluation, his attendance at the counseling sessions, and his adherence to the recommendations of the counselors. 8. BRADY INDICATOR e The Plaintiff or protected person(s) is a spouse, former spouse, a person who cohabits or has cohabited with the Defendant, a parent of a common child, a child of that person, or a child of the Defendant. . This order is being entered after a hearing of which the Defendant received actual notice and had an opportunity to be heard. . Paragraph 1 of this Order has been checked to restrain the Defendant from harassing, stalking, or threatening Plaintiff or protected person(s). . Defendant represents a credible threat to the physical safety of the Plaintiff or other protected person(s). 9. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Pennsylvania State Police - Plaintiffs residence Carlisle Police Department - Plaintiffs place of employment 10. THIS ORDER SUPERSEDES: 1. ANY PRIOR PFA ORDER 11. All provisions of this order shall expire on: May 22, 2001 NOTICE TO THE DEFENDANT VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S. §6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. §2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C §§2261-2262. IF THE BRADY INDICATOR PARAGRAPH APPEARS IN THE ORDER, YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT, 18 U.S.C. §922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION. NOTICE TO LAW ENFORCEMENT OFFICIALS The police who have jurisdiction over the plaintiffs residence OR any location where a violation of this order occurs OR where the defendant may be located, shall enforce this order. An arrest for violation of Paragraphs 1 through 6 of this order may be without warrant, based soley on probable cause, whether or not the violation is committed in the presence of the police. 23 Pa.C.S. §6113. Subsequent to arrest, the police officer shall seize all weapons used or threatened to be used during the violation of the protection order or during prior incidents of abuse. The Cumberland County Sheriffs Department shall maintain possession of the weapons until further order of this Court. When the defendant is placed under arrest for violation of this order, the defendant shall be taken to the appropriate authority or authorities before whom defendant is to be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police officer OR the plaintiff. Plaintiffs presence and signature are not required to file the complaint. If sufficient grounds for violation of this order are alleged, the defendant shall be arraigned, bond set and both parties given notice of the date of the hearing. Pres. Judge 0406 If entered pursuant to the consent of plaintiff and defendant: Plaintiffs Signature Defendant's Signature Distribution to: Legal Services, Inc. Joan Carey, Attorney for Plaintiff Mark Stephen Edwards, Defendant Faxed & Mailed to PSP . c; ,-_ ??- ?!'' ???,. vi? fgF?Y ?lf• Au e y F '?Yi REBECCA MARTHA EDWARDS, Plaintiff vs. MARK STEPHEN EDWARDS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW : No. 00-3067 PROTECTION FROM ABUSE ORDER ASSESSING COSTS And now, this 22nd Day of May, 2000, MARK STEPHEN EDWARDS (Defendant) is hearby ORDERED to pay costs in the above action. Costs Include: Court costs Reimburse one of Legal Services, Inc.'s funding sources Domestic Violence surcharge Total: Cash or money order Office of Fines and Costs Cumberland County Courthouse I Courthouse Square, 2nd Floor Carlisle, PA 17013 $103.15 $250.00 $25.00 $378.15 DO NOT SEND CASH THROUGH THE MAIL Courthouse hours Monday through Friday are 8:00 a.m. to 4:30 p.m. It is further ORDERED that said costs shall be paid by May 22, 2001. Respondent Distribution to: LEGAL SERVICES, INC. Joan Carey, Attorney for Plaintiff Mark Stephen Edwards, Defendant Faxed & Mailed to PSP CJ , ry? Q 9'^U HIM MINOR i!iiliiiiiii 05722/00 MON 15:40 FAX 717 240 6573 CUMB CO PROTHONOTARY ftdlool ssssssssssssssassssss sss T% REPORT sss sasssssssssssssssssss TRANSMISSION OR T%/R% NO 1879 CONNECTION TEL 92490779 CONNECTION ID ST. TIME 05/22 15:35 USAGE T 04'51 PGS. 8 RESULT OR rnt6,eb lea p I ? ?O?F o coar ne?? ? br _ - aD w?(.l ale t IDOL ? v ?1 LISA, o0'u lea, 2 t C%ak ODULL ),- - wi ryl?t h but U2yYl 6 JLyo- ca n oIJ !P W f tiot-UL U/h C?2Ck ??C:F r c -e 1 Q be cn L?? tee, 'Y?v??? iti,e. Gras ? ecs?vC'L?, ? ? 1?0 (t /? ?? ?C.L ?,??? ?1Z ?eC Cor?F_Y?2 ?2 ?L;S S4,° a?L??Se (jLIL f a?/p0 ?l-,?5? ?ov,? ?..e:? hz.d? SPA-??/? c?.r????? q;vz .me C,?T ?h= Se,?n.2 a?Y1?/I-E-?t. \jOoc5 a no e,j-zc\ ?-O'ncc\ ?t1 .Su ?2t5 hes? ??? 1?:r?s> c fc??Lo ?l ?S{ ?0??5 ei 11eC Steoc) q,v2 ,nom CAt ?1 couC'Ce ?llt? TC9Ltl ?,$?' ,n -two ('?°a Cc7?? C?z"?iC7?1-C(? - ?2f"'?. ? ?v5? ?lv(Ito ?ti.:5f. C1o??? ?e?. h?C' ?Per,? ?.•?,?`\l..;v°?c` tied. c`,v?2. :?? cr??` ? co?P-•e ?'J©`\?cS , --?..v S:cE,rlerJ oue? ?''? E?S1C ?p Q\ ??C ` 2f?(J_ ?vl ?1 ?iYlo ,?.1?2 M? °t.V r, (into 5EOM4- MoOeY ! ! Th:S Pl-ric. z. t?r:?J ?ue??h?l?:v,.c,` :r :T .S ?ld?rt5 ??,20.5? ?Q?\ ?-?.-c` ?-??(' ??1t? ?,n,???,,?? ?I?-?° c??v? tine c?S'•?ns? Sow ?h??f11 ??? TU ?v?vz s??-P n? uavC ?e?`?e ??? \„2i 4.e,C' SC,xr.l? (an?hiYtia{ :i2? ??U? rr,•e'?.?C`vn; Mo?n??r gooo 1c? S ri e?'r?+jma on 7-15 PErLc-e dzvv? @vedcl[h'v? erg <<t>S t iCe l?2iJ C???J io? rVG ?y uJOVC f? \Y') 1770 ??1C?`? S 6? r' qn L ?F ?'CC':heV 'M? v(? ?;tPivlol A?i?;?e`? ©P ??T ?iz? ?o cn?et- Rema?,c3? ??? c?.?? 2 yec?rS ??? ri?lT was 13 A?c? maT ShovT,r? ?v? ?1 m2 1 Mlle c?4 c?T ?F Une h r rn e, ??m (3(in? hey 6'11e?5 Po hq5e C)Po Le m Sha?T ?mm,??1 \h_e c?c?v15 `?Inl7 ?q?ati, ?e+ne,m,?tl' i?n? ?,w?e S?? tov?t? Att 1 he ne??irs L,,vGC? hc? ?5 5?,? c??lelJ ?S Fvc1?:v,? (-'??-CS when Sl,e wqs ?2 ?????5 oL? ease +?v? m.? S?o?s an f:of- 0 w)?njk f)vc) l h??h I( how ? ??5? e?C ?- T w?aen She Zbl.!R> il>e ?b[k,2 I C-bock-eD w ?d 0'?o SI,? q-CT- /) horr; &-e- J vea 4fJei, c(,S ?o ???t v»?ho SGe 5??? ???I rn (3 Lone w,- your Ctil`C \FD? \??2s(,r5 ? 5 i? PD55? c?L..2 ' 1?.4?l '(?"?(a(w ?,? (?(?V2 F?,TI;n? .1 P?2 ?5 r I'J ref/` r> rJZj \\ DOtI Sc??? -V?\Xnv, c \IOU ACE 0?\\I ?(e l {'J?SI ©o!L ?c??i< (- T )four hr4 o Zoo l? (mow ?vCn CornPLeal? E?CC??nO (?.?tJ l c9oK f3l M-e fie' ecc T S ee ?J 1?,?? Sd ro 'r)dT Svs? ? fJ C Clef ? cro?t Sffee`?. lcw t?r? l v?ne? ?pveSei? W ?cJ? OP-2J\ ?br \ Km To ?21 10LI/ ?eS (???e?eS??f C`?om o??,erJ !?S atoc?? wl ?C ( (©v ?to?n? 1? C), r f32 STron? Verl ST?-01 ? ` h erg ?(ov w; ?l ?l w!? +5 Tae S;?c?? w i )I?,4??i (fie (Jc?,,?/?. t,.nve Roo' il?2 vend [??PeS( PdVT orF t?4`( hekrT vhYL??orfC©MF ha,m?R JcW°Rnl') C?,I? t9f an'2,??tt (Jov?l 1?,r1ow -JV1=C _oz g,Srno 50O pro w?a41 /U c?T`ntc^ ?1.?:(3??f (? ?oyize0 FCC , ' Cd?ll,?q 5?'??t Po L, «. Shy ra?r?.?.?i ?l?c?ow S?,i ??5i I,?wrerJ ?.cV??? Screen„'ny; L. .O% Z !' AI'?as*,t 5 your lny onL.tl 'I-oPC, Your t,.r '(Sv5V fre;nO r r? o PL"bC Odel 'Cwt:r.? fir. A ?t? c-bT w:M c\o cAr 7:? SF+A hest. Po( rl 019j6 tavnrJ{r;?i? ;r `o?e;S oK T CcanT word 641 n? Q5ot6 yen TooK ML- "lac ?osPr7 - r Gryt? So cp -Novtl,, Go? iPESsp (? J onj . 5'0 S % "{'.c %\ me 61,eS oK . k?T CkNi , wovl? \,el.P .,rte. .`;F '? hwra drown `c'?.YS woul.rJ 1?tAPPtr7 T n-Wt.r BvrZf -coLO v,ex, ,,Nt, a.0?5ee, Como d?tir n Mor?.o-r Any WtLr t/vj see.ca,;L. T UntJeCS1r?n0 T"A? r?dt,? PLRaS? Ce?\ fir m t,i.?\ ?neuzr %,T Odei' 3"C Cad So ca?2 S TM nt.?e-r cto,C%j 1-c, Set rnY w?FC ( Ai(1 A..O Mh onl,j hope. Cc1.? se. ?r,? '0 your hoL\tj P(Dwec To T'a\,?l ?eC'Ses?r? ?,nTo t\6?- cloinq C6(jc-K woSb, he-6' E? {1JS('J?r1() ih,,e. Quy CJ:O Sortie (Ze<ct? 3nrJ `IGt?n?jS Io h-tr, Lt?1rJ het AncJ Th-e 11:r?5 ?r c?.c?r?? (atC s e SL.e t.t^t r , ; n, .? t, e Pa$T, r RAPLy huaTS M-e TO -flj, n k , ?? cvPanT 5 Yec ik"RPkn;01 ?1Mc+h APCari l wns her (6r.al< wall he. covLtz-c" hAt`+v? hef RnvMo(`?. C\r0 ;F ?y Fc?°Cref? r?.a?,? SI,eN \.????r\ 1 p 4?arl! Anvtww? ?rn1l??,\?.1 c?oT CwY.?nq i1.5 So gooD An(J wouLo (Zea1{? ThnnK `?`? ?fom ?6C1`e./h DF her,,fl iF ?ov Govl,r? pj I.ewS? Te.l( Mt S/?.?y AUvE • 5 Tool( A T?o-rT Ac\o ?onl a (?(.vSK, c?ni t,. ve w. t h r?,?Sc?F Cti,, ?\l,`h? SLte s : n woorJS , rt^K 'ASS b %0 hti TkOL2,t nl he S?er? y,C1. ? av! i' r\ exl 1 Uo,,,) FO r Svc`-? tr.! ?vh `tom, Srti O 'ro V*tr woo) wro r)y ve?Y tarorlc? wino Zrn l.?v;v\? w;? ', ?' Le-FT R l,eTkr On Th-c S7kP any e (? q? 1%6ri ca .5 r?A t 2 PL.e4S4 iR \ ©J kkAo,./ U04-f-4. Sht Tr? CidoQ C6. ACA"I She Sq?p She. CCOL.Oen,- I.eT Mt cro T?+iou w?Ch tees l.:EeS 7eoc3t4B 5 Hc%o l h9 % 56- I.004.S rne. t?.er 5e Veit Ive,;r C4n ?nvanrJle_ ?t A?rJ 1 4,oue, Mk w?v e Vtfj MOLAj. So y ?? To GO-N,,! ??'o? SvSt ti©i" ??q?('60 `tom .,. -.:?...,...?+.•, ,-;. ,.? _,.; .t4Y;..?'r?mRtV €c{i,.1;-.o.wt?q,e?. bs m?, >i.!NaA'm , , W119, -_ -- i -'i}khVNA?i'?°?.k9?3H,wb`rw?+Wx? an+a:,=-:.b?uro.wF g,+zae[un?-ez?4s.=?, ?H*F ?e?LL nc) C?'C O y 0 AT ckol- S41e- scu?o L,cno? Cc-e- L L1-f'? Vvrto T?2 9,0 So CAt C \k rl rye. LA S'Oulo to kC9 V-1 q? I ID Ta W\ C? ?C9 at) o 6 -e-t-T5, 1 use ?YN.? Pq- oGm'p'- 7/, Rea,l y var ?1?, (? ev;°?e Pe , (-r\(J T nQ?QS?? 4T. t?c,c? esOLT\? an C4. a TI. CmM,4, m4 La j 4 LfI ?;-ocz -r-?,? r?dSi ?? ran ?P?-r?m-e?i??c???®c? M 1©v1?j? N G ?jk C, \ivr?L2, 2Y?1 Sor^?I (v? (?11©vv2 been T?,m??? (Dpo , (-ndw) I,s;S1vKr, ?4-)r Sorg P19t'r?. 11 flaw 31 \`now haw Ov u2 fAv\(D 1L'?flS 1 W 2? nv \ Y t 2rf1, t ? 52 ?o?t (b -p- So c, -,o ? ao(D n -1k°5 rnore' j-e 1-"T`,'-e, 11 -a/zn o's \n(??( G?e?se cb (fie S? . Coln , ?,?t? `You v"?iz-e Qooo monzy -fvy) Lod,I 10 6rtyr7 ?o? e, FT,-e- " .,Wit'w.gvi6?,9a3+m?GtbYZ.MyG?x9r?YW. ." - wauMh '?"w.me, AA85:i4N14R- sw... '91L 0 wrAS ?uST AS (b(ACJ 't ?Am So (AQ J' r L 1C ?s7__ 0 ,. (C E?\\ wc?ul(J A® F ?.y? WO-<, "t'o PJ Sc, (ld\SC An L _.(3vT "_ C-t1° -P-D, MCI Loco whgs?\- cx°c) T. C n2 Oam ME. °T wt?S ?eTT na 'Cep Tyne_ \O\,nT W -. t` wool.D STfA? Ou?wlLe r?T ???h? `r\112n wlaaT rnot\:Cl' we,S Sjoknq_ o P,c „n ca V,e_r4- c?Th2d T'h? \L?e?y'e.S r'?n? (3uUeT'? fln? Sa,Ci?k1 t,J4tA"?` wovLc? S1, e.. Ac.u S- c9F n-eXOuC wboL, u-)c9CL O was !?©tnc. T© Cda--Nk . -O\7 t`n4\u?T2 Tc:, TV,I\n\, TVxT e)uc ?,ove.. wets Sv S7'ro?= A k.sja ST flefo uj' 'h C1c9Ttn,\Vln CAnD Conoc Th',S (-.PC,-EF 7 1,90 a -qc4? ?? ?uS? C3eencanT Rn(J-)Q1 (ill _ eke S?'uf';o ho ?6 To _ C-c9b` \-.6?sWidl? a,9'C31i-?,?w(2 C?'v'l.(? ('?? `?LA'.a'1 ?C4.+.tJ t?'&e:Pj yr'ri not ?a/??"?a tI ou-c morn O"C 3 we ?\?j L v1? e.?. 9 S?t?re(J ?c?vf ?0.e? usdlbl ?tivr Sc?fC3 5on (Dae0 C-corvt ?+eeod(l Yood' 'Du?a17LC WrP+S N2LAn(J OeAtD C ? k?f -, ?kLp?< ov ?Crom Pr Ve+''L( N7(?vSc? ?l vl 1 ?c1(J Lc)O-Vc$ tiM T i4?c t?cavl ?f? l (Jfe?) 2 Inovneej fln?J l?(?v?( ?fc?dl,`? ?( \'A vJl,vL? C?61°So ?oor c'--kLID So%(7 3 T0(rte? Wh;.r ?? '?L(rJc?C3QZ9Of qnr? `aasta?heaS1 ?o+j So Sa Sc35 (C( TeO?iti? lfov?hrrT t'her Cc?cherJJ E4:r?S cu?n? To com?`5?5? for P??h ?e uh??Ll;ngs 1.c?w e'3s> OL) TG,, wl,zn S?sa\? r Lf? ekg C?ol:cd - T' ,elTe t? 14 r° ?. ?, ? Q C?? \ ?O t1 ?Q?1 trY1 +?C? ccJ ?tiat"? ?l r vtq St?w+e? wi?i . e?rcJ CaScnv? (? (3? ??®S? Z ?r?d dTrev? GJx")T- ,e tlstkve'j (Ano f3vI(tg Af\o '''N1 i11t "?Ct( em T wA-- S?j"nj A3ouTquv75 ?"10(.?l ?-.? St?T ;r3afa? ,^.tfLc. m: 9 tr?.na fie, d4: S r3nr> 0(:- , e?r`g ve-s?1 Litt`"t-v c 'y ( '? C?' a (?ec,S? 9 ?r?ez(? s?av T (ov ??q.Gl? (o Lou-e, s"E_ (?r1?J s l?nouj ycv-U Oc) trevme. --rA cc, (T?h???givC,e.t tUO5 (-Qopvnip,- Loue- YOur ttq,,Lorlfn? JU5 ?l•Y0 t\' e? w'HS l"C.J\4a^6'l? 6n?rlq'3 b??'1 TT'14SY? F'1 COY,+?` ?-t? 1. Q..? ewe C(C5 ?-?r'? c(L"WK,(" T?%n K (+r5oui-% :"Z- fi •' , ~e?S? s ??zcS?.? V??Esi?e t e°LS? ?o?t2 ?cs , a S i S ?© cJ ? tcrm2 5 v?2,4.`?'nJ ?l2 e?`?'e. T h;S t? ?Jiz,)/ 1 (??uct1 Mvc? , vorSl cS1 o rne?T wl ?\,:nA fncT S'L,5 fQP.? LXz., Q%P) ( my (3o5S _ mgfov v-5 S©/3 r<z.rJ a S,?z,s (?pc?f Ta ?Ehnl ?l©? ?? d1vT F_?Rr Surma nF An.(?h.n? WV)6T To (Do,L-rhAT To Do ?- w? [1n c.J?' do ct:?y nn w?J`Il ??'? oral.l ? n't?'?d' d? T?rn? ,,Co.?r ?r?q?i ?s cton? a?o?n, F ?v??Y r3e? G?T?ny or P:h? e z? Svr?me?TS use ver? e v" Wert?S She w:?h R den 1?(l? P c?c `r ,S S ?n Th woa?JS 4S sitiz J?h v S ?? The m ?h Con5-e(n? IT c2c'-;n? c) Q2eeei YyKar? eSrt er??? to T SAI ?rS ?e ?efr;yatC)f Anr? c ?.(?? S 5?? ?Lr<°?t! LbcrJ c(,'Vy? \0 3e (ILsoC w ?1 loo©olS R?Ja.1 f?c5rn"D '?Sv ?;?-e-S farv+'??? C.U.eP??PJorJ.l E1.i?e5 Movr,`S c??1S?n?,• S?,zI.F:S1, To Cr}1? r 1n.e({? She ?e?g vn2 J ?•?????< ?;lL? ,??nT C7s)Le me f?r}?h ?k?cffi ?,2. ?: O M ?r3 oy e ? ter,( ('t,+? (r-2 Q5?-%)4EF?&c ,L cC UC, fv?'e- l}n??.Mo?ne? ?(\ ?r?T?S me, 1-. Ir??-? .?? ?-2,32 ;? ,?lcc-??`n\ ©Pene?J f??1 ???r?? 037 (5v? lC Cie=(? a eeS ?J??CJ S woul r? ( (z`1Gea 10 C loS? ?o ??d?anl ?ov2 to For ,h-??\2,?•C?0 muea` O(?,,.?erl ( +? So,me?ow J?1,1 ? ez t'ec?L.t l SLITIco -s- C,b-z,1 • ?' hYljc::A l i©? S?rJ C'c?LT-r'_J? W rcnn ?,pv? ec?ceur?? ?? ?uue?' 1L,ew? A\\ ? .. S fi?a? w:S? Swsa\k wOO?e do ky herSeLf u?nc? 6? C?iacl?. n? (3?? ?c1 d i T \ ec 5T S wool O ©( 1ln i/1 ??u ??,Ya5 Wu-, oIZ , rn ar3,e- ?heT LvcA( 740 II ? G Z ;? i.,?.S'?''C,d W`. ?? ?m?. ??ot+-? ?r0 ?e_+10 ('e1 1??3? n °"y) ?I TkoV??? J, wzr? ?-a('•z ?l oc? O'C'e_ \(oU 0,1?- ?zV Fl w S ?Yovq? T P w?S S(Von (5,5V S' Ues ( SC 'rc?J Qq?? r ?? 1 F?l 1e?P?eSS ne'Qn (a SC?eP SL.??P vn ? huo r ?? C?oThwS F n 5h ?? foo9c (tow y, SG,o?Gr?anl pF ??r5'o?D ?? ?c.4 ??S?;n? ?,Ara4 )rsi w?c? T'o qo To S elCeu huti ac w? r? w?r14 ny rJo n ike Fin. ??c\.( h mt(S?L c V^?( cnay^^,s raj c?v2J 1 Joie (1 u'c?r\l i J\u Cv>r. lti\c i2 ,)ewNS y r ?\ SL?eP. J?hv7 hD ire. 95 wvTS iT ?2c \ l So (jaJD e-'omPAreO Tc, ' ???e1 \ ?,2?0 ?e C,'l? ?? ??Oc1 't??? ??\( 4-?-??..? icy ?b?' ?vi? ?4? ?l? ? l7p ? k I n `^,o vvV U V \ L 25? \? C7J 1! _Q tae i i YZ ? I I Oal M r?e?S FfJ o d-::> , oA CoGr?? ?? h2 w cq C?) S Aa r1'L C> 01 d v ('v-v- 0 9 21 Vl til ?? ??D?S CJ?G?• a=}? CAM ?'. 9c) n? 1ca (Do -27 Lavc-- ?? c v C1 e r v? ?t ?a c wo?L ?J M n ? ? c? i1\ ?n-2?,.,P ? (`?? \Lc.? ©ca? c2 cam- w ca ?' l? Le a es mc??e?` ?rCnv?' 2u?<ef ecc?iL, (4vi D Y,00?? w'R\? -Co 'LJ?t\ AaloL???SJ? C J? ?i 2(?v? 14 L`GVLu? JF ??dt2 i rnvc ??.f ??renl L f??v2C feL1 lh 1?9? R\cv?f tip' C ?C?nc ?Je? S e ?U 1 c2K egr JGoT r?.\?5??1 t?f??? c®c?f? Ail r s®,AO C?F? I ? how S-P-L?G.e???2a,f) cP?}V weCZ ?'h? w:4J ?plvo?2nl ?cavJ'S t Y\"?vl i o4? ^1itA? ?j7?G(Jevlj l3t? ?o?? ?Ia? c3n?e r? Ov9-tl I1c?w ?tctjtf ??rsv w2t ?• I CDC 71 T k? r4nO t mc???( `(, ?!? 1 n ?I7uJ , ?o v'1 IJ i? eLP r 1? \k?U eel ciz'r no C--UvrD 0 t Or W- ? Le v 7 IZ? ?l,?S\ ? `hc?n?I'?(? ?ta<<??? r??-?n?c.i? t?.(?rh-? .V1• `?ov ,??w , I .e?C? N'?L9o?`I? ?z•-?'`? ??'e,?' ?'?er,? Jv?' ?CCCJc/;'1) ? ? ?j?(?d,000? yvr' JOl`i,nat' ?p 1 Sid ?, e{ ? -? ? o (? ray 1? (??r? C r.? M? Ey?S ocii 'r !o -o00 ?p v 1?n2 Y d\c? e-e r ? Md?a3 no d lc3d 2 u3r?J ncl, uJcl mA\t? C n Srh 1?ov 2 1?? 1 C m2 ??c? UQZ St _.cJ i?'4-, C_tlC +M0c ?419t?.o d_? v'n?e v?S al ?'tIS G7F12 ?'7? ?iC?l r?.2(?r \ '.ebn i :Yu5? L??? r r ?Sc???? e D L_?vIC U? (? n 00 ry? SGT,USo P '\ ?-\-eCV-\ , -vv,?e_ T0-R[ ?ou? rk? 4 a t (D r-1) - I ( C'?j Orr, r S ?Se r'? 6L c (?-01, 06 Vocl c-ottllJ o0b ,e-- V? C-::7 v L \?o? c?FFe(o ?ehC? fir e ?1v? e©?Ll? ?tktA m? Cc? ©c?Nn`s ?nf? men `Po I?o`rr Yns•>ranc? S?c_.(; 6??c'? zee n loo t? ©? off(' ?„n 1(? n ? c ? 2 Cv? Cow ? ?s? Pp(D ('')A(3.c i IC ? ?? ? fJvcTo , i eCo ? lL on (G 2 cGf?ck Cod, ILaSSe ll06 SJ('e ??,?1 ?. ?aPPenO tnra3 I CA-n nq l 10'e_K l ll? Si?rrAns n? ?SIL i?.e? To ??lle_ ?hai? ??1?? oSC oP (??P©S;, l ? ? wont iAS`?. ti?u? For Mo o1 ?? CbJ RT LeaSl `I'e dY7 ` fit; ? ? se5enl A v Fof CZeSPonSr 3rCJT?e? ?`.??? Y1o v ?S?LF, J m S (C ?o?,? hv563 3 ?eSPec1 ?? aS 1 ?o?GO ?o? d?r?0 PCe?S? 0601 Ono ROO MC4n,ll 1 fu,05 C,, CorE ??l X21 c?v?o it 'S in r?c_( L ? y?,(?v-e ?(1c? `?'n??nSic?nS P?ci;' me.eT,n? ct.ul?o(?? ?CiS 6F i?ou c,t?vu w2 eqn 1 5??11 f?'?roac('?e? ?v?r> t?,l?a.n Cl,?(.f?/`.?n e1 e.6 ©L?(- ?m? 65vill Corte-??, ?mm?. ?? S? Te l1, 1nl -Q-- cl C? ctIv V-,? y C90 LO u m ,q- . I It REBECCA EDWARDS, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V : 00-3067 CIVIL TERM MARK EDWARDS, CHARGE: INDIRECT CRIMINAL Defendant CONTEMPT IN RE: INDIRECT CRIMINAL CONTEMPT ORDER OF COURT AND NOW, May 30, 2000, 11:50 a.m., the defendant having appeared in open court together with the Public Defender, Ellen K. Barry, Esquire, on a petition alleging indirect criminal contempt of our order of May 22, 2000, and the defendant having admitted the allegations contained in the police criminal complaint filed by State Trooper Gerald W. Allen, Jr., the Court does find that that petition is supported beyond a reasonable doubt and we do find the defendant to be in contempt of our order. Rebecca M. Edwards having also appeared in court represented by Legal Aid and the District Attorney, and Mrs. Edwards having indicated that she does not wish the Court to impose any jail sentence on the defendant, sentence of the court is that the defendant pay the costs of prosecution associated with this filing. Mrs. Edwards also having requested that paragraphs three and four'o the 4 Il. protection order be modified so as to allow the defendant. \? W to have contact with the plaintiff by telephone at Aa5 .a 00-3067 Civil In Re: Indirect Criminal Contempt Page 2 and at any other mutually agreeable outside location, the Court does direct that the order be so modified. Further, on the agreement of both parties, the last paragraph of the order at number seven is modified to mandate that the defendant undergo court-approved counseling for at least three months and until released by the service provider. By the Court, Jonathan R. Birbeck, Esquire Chief Deputy District Attorney Ellen K. Barry, Esquire First Assistant Public Defender Sheriff Legal Services, Inc. Victim-Witness Office 6? r ;?-00 II Ks :mtf 06/05/00 NON 08:17 FAX 717 240 6573 COMB CO PROTHONOTARY yU_ 3b4? ip.9uu1 .v %?A?X &?%:kS ffiA?R &?kM 58:$R?#8Y *$* T% REPORT gx TRANSMISSION OR T%/R% NO 1908 CONNECTION TEL 92490779 CONNECTION ID ST. TIME 06/05 08:14 USAGE T 03'24 PGS. 6 RESULT OK :C L- ;V674- fir:+_C-? '-? ? aD: b 'a,`?cp T- a?7a: ? i S c? ca 1 __Stu"3??c?_?C'QC.E.G°_a??.__:.s`,ny__y .----- _ C?c?cJ °;???e?c?o??:,??tr°c,? ?ets??^ ®i5 f?cs3ee?&?'?q?r°n`I--(?°?EiTm???_?_ whrtinLF e(3e ??CCt3 FSCof.__G1 ?Sf ---1CScaP??__4o-c?jf°T e1 iL !?-_-i13?e?,F e,._S?ca? Yss? c5-_?cs_-Intl1??_:Th.tl°s__fL...®c,..?uestii. ._-- ---,.--- -va-& _---- __Si?,.:i,_'v??y? ?- -- 5cx?.a? ?C` e: •Cs_?neC F?F _S!??. h?.c?_.:TQ c??Co.?„a?.4?.-?o-.1fe?_E,?d't_uSLi?n:? °-. _?__wos'l?,v??c?? Cc??,",-`??._E-?3°?S?c?q ; ????___f?c?fJ_.She._.5?.•_`?•?5?.??,.4??: en:.__ s ? t Z iP v, i . --- Q.t3•r?t?-C?..?C'?? C_C?3:.iS__h`?S ?'oC'?_?"0__9-czc?sE.C ?l?i:.__ °??o?[,. --- ,? `?ca _?i-?oti- §? c?T $CiSL'Pc?'q_?Cb n,'? t kt cs _C o_ ?ci?>-? ??;?C?_c ...?sE.C-c*?e„?L.._i?Su??-?'•'S'+?_c?1?t-.-?'n?T__Sbe...?.:s?'t,.t?__ -- 1?f-_G----- _..?'_s --- __ --_?eL...`as?C'_,_S?e_? --- ---_w':?s_ -_ c?C ?C ±3orJ S4c?n5SJ eu ?. nLc -W,C?t1 LaLgo(Al l-n- l-? !ner 1SicJ?_-- :_F --- -Sl,? _-- _ __^f3o_ti_?s?e?t'l?s?c,.c?__--i3t??e?'. 5?..r_f#? ???c?i??.?g.S--F??+°• h?_Si?rc??'?14 ?'!??cF_..°____?_ __®? -C oc?a __( Y? etrerlTl,?f loF( Ino'-n. _»o o1?_ CAS? ?Wti4d(_E -ty ----?_ , 7??e-0-n y _ ecse? s- ? ac) `1 ?__?1o-?n?9a? +?ZOStI,n •YnYi?F_i??j- G;?r? ?5_Gl?. i?,'[h__.Ll?'c?z?`?__?'_i29???tic.??'_._?sne`? ----- 5-- ------ -?roesvSC._t'_?ni3_.?.0?1[?s? _C.omr?QT __ th.?-?_\?.>:?-`,--(?its_3?? SC?i??.Sh,Ica-.6Se?l.__,gl??'Cc?c?•L'rrf -?_n__._?C??EczC?,Aso--L'aec..t?s??c,?._s?tf.??®??T???_??? ___Mon( --- _ ?- -- C?--?' 4,ece ?r,es?-M ng5-•-F nr -------T.L?avv! -CAs G c-as_r- c ,_colcrc?--Dairio-can-kv?-2._ ?? e5 _ - ?'cz?®,_?a?1??s_.?iJ ??'?o1-f-._die.?C?eQ??`?s?C'??e.Se,-L?:Je.,_tl??..®=Me%4-?? on_Z'Oivn.2.,_%nQ 4!1Li .F rac?r2 -- ---4.? J.r f? ?L i4r2,_3?`s? tc) °v? s? Ci oy 1 Re, fie (-?_e i??4k?T _ _-_-1-.wx:•.i?. Fo?C•Ze.?eec?°tTt?e7tJ_cs??a"_?,Jge22e.???T_la?4,__?zU_:raio ?ii5--5a`?ud3TiszYLC3¢c?e?S- ??(3?cGtk_1.,,?al,'? --_g¢Q._.._?rl?`J?lPs3j ------ -__ - r? _? eclc??nc?_sGr2C t7k?_ cti?` 6a?l t a sta. v sJouc u -r16/ --- .5oCf?a?->?S2_.`?..._Cu?R....?Le?.?c?c -?3ntJ _ ?c?„c:s?,?,C z ?$?_ ? CIc9oFg,?cjz1CJ t-.c?c,?so ?+zT LL-o?o_v?S ?ctse;¢.?f?s? ?v ?r£ ----- _--°- SoaPA xiy_? 9n?Q$?s C?oai_50???n.?l. - REBECCA M. EDWARDS, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. 00-3067 CIVIL MARK S. EDWARDS, Defendant CHARGE: INDIRECT CRIMINAL CONTEMPT /ORDER OF COURT AND NOW, this d day of May, 2000, this Court certifies that the attached complaint has been properly completed and verified, and there is probable cause for the issuance of process. In consideration of the attached Commonwealth's Petition, the defendant, MARK S. EDWARDS, is directed to appear for trial on the charge of Indirect Criminal Contempt before the Court on the 3 0 day of ?Y t 2000 at (Rb'clock __gm. in Courtroom # _?_ of the Cumberland County Courthouse, Carlisle, Pennsylvania. The defendant has a right to be represented by an attorney. If the defendant cannot afford an attorney, upon request one will be assigned to represent the defendant. If the defendant wishes assignment of counsel, contact should be made prior to trial with the Cumberland County Public Defender's Office at 717-240-6285. Further, if the defendant fails to appear, an arrest warrant will be issued. The Sheriff of Cumberland County is directed to serve this Order and Petition upon the defendant. The assessment of costs to be determined by the Trial Judge subsequent to trial. Jonathan R. Birbeck, Chief Deputy District Attorney MARK S. EDWARDS 0-C--?p l to by b. A. s/??./ CAF - - ,)TA 4Y M M,':v 2'. f'l '•. 1 ,0: 2 REBECCA M. EDWARDS, : IN THE COURT OF COMMON PLEASOF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. : 00-3067 CIVIL MARK S. EDWARDS, 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. The 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. .TH OF PENNSYLVANIA COUNTY Magisterial District Number 09-3-03 Olsmct Jbtim Name: Non. Susan K. DAY Address: 229 Mill St., P.O. Box 167 Mt. Holly Springs, Pa. 17065 Telephone: ( 717 ) 486-7672 Docket li Date Filed: OTN: Asian ? Slack ? Female Nedra American ? Unknown = Mate 1965/09/22 Plate Number I POLICE CRIMINAL COMPLAINT COMMONWEALTH OF PENNSYLVANIA vs. DEFENDANT: IDEMark Stephen 50 Bonnybrook Carlisle, Pa. 051-68-3522 NAME and ADDRESS EDWARDS Rd., Lot#35 17013 State I Registration Sticker(MMM) I State Pa. 1 24282590 H02-1129294 I District Attorney's Office nApproved (The district attorney may require `tria't'the complaint, PaR.Cr.P.107.) 260 Disapproved because: warrant stfidevit, or both be approved by the attorney for the Commonwealth prior to filing. (Name of Ana" for Commonwealth - Plebe Print or Typal (Signature of Attorney for Commonwealth) (Dal!) I, Tpr. Gerald W. ALLEN Jr. #6083 glame of Aslant - Please Print or type) (Mice, Sedge Number/1.0.) of Pennsylvania State Police PAPSP1000 (Identity Deprmment or Agency Represented and Political Subdivision) (Polity Agency ORI Number (Originating Agency Case Number (CCA do hereby state: (check the appropriate box) 1. ® 1 accuse the above named defendant who lives at the address set forth above ? I accuse the defendant whose name is unknown to me but who is described as ? 1 accuse the defendant whose name and popular designation or nickname is unknown to me and whom I have therefore designated as John Doe with violating the penal laws of the Commonwealth of Pennsylvania at 50 Bonnybrook Rd. , Lot#35, in (Place- olflloal Subdivlsmnl South Middleton Twp. in Cumberland County on or about 05/17/2000 @ approx. 22?I0hrs Participants were: (if there were participants, place their names here, repeating the name of above defendant) Mark Stephen EDWARDS Michael Duel LAMASTER 2. The acts committed by the accused were: (Set forth a summary of the facts sufficient to advise the defendant of the nature of the offense charged. A citation to the statute allegedly violated. without more, is not sufficient. In a summary case, you must cite the specific section and subsection of the statute or ordinance allegedly violated.) PA. C.S.A., Section 902, CRIMINAL SOLICITATION A person is guilty of solicitation to commit a crime if with the intent of promoting or facilitating its commission he commands, encourages or requests another person to engage in specific conduct which would constitute such crime; to wit, on above date and time the DEFENDANT did solicit Michael Duel LAMASTER to violate an active P.F.A., Order #2000-3067 dated 05/17/2000 and signed by Judge George E. HOFFER, by returning to the DEFENDANTS residence and entering same. The DEFENDANT and Mr. LAMASTER were aware of the DEFENDANTS eviction and exclusion from said residence. Defendant Name: Mark Stephen EDWARDS Docket Number: - `' POLICE CREW NAL COMPLAINT all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of Assembly, or in violation of 1. 902 (a) of the Pa. C.S.A. (Section) (Sub-Section) (PA Statute) (counts) 2. (Section) 4. 3. (Sect: i on.t (Section) of the (Sub-Section) of the (Sub-Section) of the (Sub-Section) (PA Statute) (PA Statute) (PA Statute) (counts) (counts) (counts) 3. I ask that a warrant of arrest 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 must be completed and sworn to before the issuing authority. 4. I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information and belief. This verification is made subject to the penalties of Section 4904 of the Crimes Code(18 PA. C.S. ® 4904) relating to unworn falsification to authorities. May 22nd AR 2000 Tpr. (signature o Cant AND NOW, on this date '19 , I certify the complaint has been properly completed and verified. An affidavit o probable cause must be complete( in order for a warrant to issue. agtsterta tstrtct (Issuing Authority) - AOPC 412-(4/96)(Internet Version) 2-3 art's Name: Mark Stephen EDwARDS CRIMINAL COMPLAINT Number: AFFIDAVIT of PROBABLE CAUSE This affiant is a member of the Pennsylvania State Police and I am currently assigned to Troop H, Carlisle Patrol Unit. I have been employed by the Pennsylvania State Police for nine (9) years.` On 05/19/2000 the victim, Rebecca Martha EDWARDS, notified this affiant of the possible violations of the P.F.A. Order that her husband had committed, namely returning to the residence after he had been evicted. The victim advised that these violations occurred on the evening of 05/17/2000 and possibly during the day of 05/18/2000. On 05/19/2000 this affiant spoke with the DEFENDANT about the violations and he stated that he did not return to the residence but that he had his boss ( LAMASTER ) go inside the residence to retrieve a relatives telephone number the evening of his eviction from the residence. He also stated that he did return to the trailer park, near the mailboxes, the following day ( 05/18/2000 ) but was no where near the trailer. On 05/19/2000 this affiant spoke with Michael Duel LAMASTER about who had gone back to the residence on the evening that the DEFENDANT was evicted ( 05/17/2000 ). He related that he went back to the residence and entered same to obtain a telephone number for the DEFENDANT and that the DEFENDANT did not go to the residence with him. LAMASTER acknowledged knowing about the P.F.A. and the DEFENDANTS eviction. He stated that he was not sure if what he did was wrong, he was just trying to help the DEFENDANT. Based on the aforementioned this affiant requests that a warrant be issued for the! DEFENDANT for soliciting a violation of an active P.F.A. Order due to the DEFENDANT riot having a fixed address at this time. 1, Tpr. Gerald W. ALLEN Jr. , BEING DULY SWORN ACCORDING 1'0 LAW, DEPOSE AND SAY THAT THE FACTS SET FORTH IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF. Tpr. Migname of Nl any Swam to me and subscribed before me this day of '19- . Date My commission expires first Monday of January, District Justice SEAL 3-3 REBECCA MARTHA EDWARDS, Plaintiff vs. MARK STEPHEN EDWARDS, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000- 3GC CIVIL TERM 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. d A hearing on this matter is scheduled on the ??ZOday of May, 2000, at ?? 6y /3-m., in CourtroomNo. _ I ofthe Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. You MUST obey the Order that is attached until it is modified or terminated by the court after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six months in jail under 23 Pa.C. S. §6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. §2265, this Order is enforceable anywhere in the United States, tribal lands, U. S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. § 2261-2262. You should take this paper to your lawyer at once. You have the right to have a lawyer represent you at the hearing. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. If you cannot find a lawyer, you may have to proceed without one. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, Pennsylvania 17013 Telephone Number: (717)249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. REBECCA MARTHA EDWARDS, Plaintiff vs. MARK STEPHEN EDWARDS, Defendant : IN THE COURT OF COMMON :PLEAS OF : CUMBERLAND COUNTY, :PENNSYLVANIA CIVIL ACTION - LAW No. trv • 306 "/ -- -1 -,Z, . PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: MARK STEPHEN EDWARDS Defendant's Date of Birth is: September 22, 1965 Name(s) of All protected persons, including Plaintiff and minor children: 1. REBECCA MARTHA EDWARDS AND NOW, on 17th Day of May, 2000 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: Plaintiffs request for a temporary protection order is granted. 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. 2. Defendant shall be evicted and excluded from the residence at: 50 Bonnybrook Road Lot 35 Carlisle, PA 17013 I 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 current residence which is at an undisclosed location for her protection, or at any other location where she may reside. Plaintiffs place of employment at Lear Corporation, 50 Spring Road, Carlisle, PA 4. 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. Defendant shall immediately relinquish any firearms license the Defendant may possess, and the following weapons to the Sheriffs Office or a designated local law enforcement agency for delivery to the Sheriffs Office. 1. any and all firearms, specifically, a shotgun Defendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration of this order. 6. The following additional relief is granted: This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service. The Prothonotary shall not send a copy of this Order to Defendant by mail. Law enforcement agencies, human service agencies and school districts shall not disclose the presence of Plaintiff in the jurisdiction or district or furnish any address, telephone number, or any other demographic information about Plaintiff, except by further Order of Court. Defendant is required to relinquish to the sheriff any firearm license Defendant may possess. Defendant's weapons and firearm license may be returned at the expiration of the Protection Order after Defendant has submitted a written request to the Court for the return of the weapons and the Court has notified Plaintiff of the request and given Plaintiff an opportunity to respond. A copy of this Order shall be transmitted to the chief or head of the police department of where Defendant resides (Pennsylvania State Police, Carlisle)and the sheriff of Cumberland County. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. Defendant is to refrain from harassing Plaintiff's relatives. 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Pennsylvania State Police - the marital residence Carlisle Police Department - Plaintiffs place of employment 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. 9. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MAY 17, 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. §6114. Consent of the Plaintiff to Defendant's return to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C. S. §6113. Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. §§2261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiffs residence OR any location where a violation of this order occurs OR where the defendant may be located. If defendant violates Paragraphs 1 through S of this Order, defendant shall be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence of law enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriffs office of the county which issued this Order, which office shall maintain possession of the weapons until finther 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. Distribution to: Legal Services, Inc. Joan Carey, Attorney for Plaintiff Faxed & Mailed to PSP PFAD Number: QL1088327T REBECCA MARTHA EDWARDS, Plaintiff vs. : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA MARK STEPHEN EDWARDS, Defendant : CIVIL ACTION - LAW No. Ov - 366 7 PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE 1. Plaintiffs name is: REBECCA MARTHA EDWARDS 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. REBECCA MARTHA EDWARDS 4. Plaintiffs address is confidential 5. Defendant's Name is: MARK STEPHEN EDWARDS 6. Defendant is believed to live at the following address: 50 Bonnybrook Road , Lot 35, Carlisle, PA 17013 7. Defendant's Date of Birth is: September 22, 1965 8. Defendant's Place of employment is: Mike Lamaster Roofing, 2101 Longs Gap Road, Carlisle, PA 9. Defendant is an adult. 10. The relationship between the Plaintiff and the Defendant is: Spouse 11. The facts of the most recent incident of abuse are as follows: On about Saturday, May 06, 2000 location: 50 Bonnybrook Road, Lot 35, Carlisle, PA, the marital residence On or about May 6, 2000, Defendant grabbed Plaintiff by her arms and shoved her, causing a bruise on her arm. 12. 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: On or about April 24, 2000, Plaintiff awoke to Defendant yelling, and the sound of glass breaking. Plaintiff entered the room, saw that Defendant had broken the coffee carafe, and when she asked him what happened, he yelled at her threatening, "You're going to die today; I'm going to kill you or you're going to leave this house today." Fearing for her safety, Plaintiff tried to call 911 for help, but Defendant grabbed the telephone out of her hand, pulled the telephone console off the wall, and threw it down on the floor, hitting her feet with it. As Plaintiff tried to get to the door to leave, Defendant got to the door ahead of her, stood in front of it blocking it with his body, and told her that she wasn't going anywhere. On or about April 7, 2000, Defendant threatened Plaintiff saying that one day he would lure bier into the woods and do away with her. On or about April 5, 2000, Defendant punched Plaintiff on the forearm with his knuckles, causing bruising on her arm. On or about April 1, 2000, when Plaintiff asked Defendant to hand her the cigarette lighter, he threw it at her hitting her on the forehead with it. Plaintiff sustained bruising on her forehead as a result of this incident. In or about January 2000, Defendant wanted Plaintiff to make up with him after he argued with her, and when she would not voluntarily hug him, he grabbed her arms, wrapped them around his neck and held her arms tightly. Plaintiff sustained bruising on her arm as a result of this incident. On or about December 25, 1999, Defendant used his arm to clear the table of food and drink, causing it to splatter on the floor and walls. Then he kicked the chair that Plaintiff was sitting on, causing her to fall to the floor, and when she tried to get out the door, Defendant blocked the doorway with his body, grabbed her by the arm, and shoved her into the living room and down onto the couch. Defendant raised a large glass-encased candle above his head, causing Plaintiff to fear that he was going to hit her on the head with it. Then he set the candle down, and took: a shotgun off a rack on the wall, causing her to fear that he was going to shoot her. Since approximately 1999, Defendant has abused Plaintiff in ways including, but not limited to, grabbing her arms, breasts, and buttocks, punching her, shoving her about, and restraining her; punching walls and appliances; throwing household objects about such as the telephone; and intimidating and controlling Plaintiff. Defendant threatened to kill Plaintiff several times. 13. The Defendant has used, or threatened to use, the following weapon(s) against the Plaintiff or the minor children: a. any and all firearms, specifically, a shotgun 14. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: Pennsylvania State Police - Plaintiffs residence Carlisle Police Department - Plaintiffs place of employment 15. There is an immediate and present danger of further abuse from the Defendant. 16. Plaintiff is asking the court to evict and exclude the Defendant from the following residence: 50 Bonnybrook Road Lot 35 Carlisle, PA 17013 Owned By: Defendant, Mark Stephen Edwards (Plaintiffs father bought the mobile home for her and she signed the title over to Defendant before they married in 1999). 17. Plaintiff has suffered out-of-pocket financial losses as a result of the abuse described above. Those losses are: Lost wages 18. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or minor child/ren in any place where Plaintiff may be found. b. Evict/exclude Defendant from Plaintiffs residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff. c. Require Defendant to provide Plaintiff and/or minor child/ren with other suitable housing. 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 Plaintiffs 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. Prohibit Defendant from having any contact with Plaintiffs relatives and Plaintiffs children listed in this petition, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/ren. f. Order Defendant to temporarily tam over weapons to the Sheriff of this County and prohibit Defendant from transferring, acquiring, or possessing any such weapons for the duration of the Order. g. Direct Defendant to pay Plaintiff for the reasonable financial losses suffered as the result of the abuse, to be determined at the hearing. h. Order Defendant to pay the costs of this action, including filing and service fees- i. Order the following additional relief, not listed above: Defendant is required to relinquish to the sheriff any firearm license Defendant may possess. Defendant's weapons and firearm license may be returned at the expiration of the Protection Order after Defendant has submitted a written request to the Court for the return of the weapons and the Court has notified Plaintiff of the request and given Plaintiff an opportunity to respond. Petition Fof Protection From Abuse Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. Defendant is to refrain from harassing Plaintiffs relatives. Order Defendant to pay $250.00 to reimburse one of Legal Services, Inc.'s funding sources toward the cost of litigation in this case. j. Grant such other relief as the court deems appropriate, k. 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. VERIFICATION I verify that I am the petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the Penalties of 18 Pa. C. S. §4904, relating to unworn falsification to authorities Signature M (U (!c bC Date Page '5 of 5 Respectfully Submitted by: (Akn Carey, Attorney Agency: LEGAL SERVICES, SHERIFF'S RETURN - REGULAR + -CASE NO: 2000-03067 P COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND EDWARDS REBECCA MARTHA VS EDWARDS MARK STEPHEN WILLIAM DIEHL , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within TEMPORARY PROTECTION FROM was served upon EDWARDS MARK STEPHEN the DEFENDANT , at 0019:15 HOURS, on the 17th day of May , 2000 at 50 BONNYBROOK RD., LOT 35 CARLISLE, PA 17013 by handing to MARK STEPHEN EDWARDS a true and attested copy of TEMPORARY PROTECTION FROM together with ABUSE ORDER, NOTICE OF HEARING & ORDER PETIION and at the same time directing His attention to the contents thereof. Additional'Comments WEAPONS CONFISCATED Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 3.10 o ?. .00 10.00 R. Thomas Kline .00 31.10 05/18/2000 Sworn and Subscribed to before me this 7 1%_? day of o24ruc7 A. D. P othonotary 4_ I By: uW . 1 ]?A Dep eriff tj- Name of Defendant Number of weapons seized 49 Make 1. 2. 3. 4. 5. 6. 7. 8. 9. 10 11 12 13 14 15 Model/Caliber Serial No. Comments f d,rb?I ?rsr Signature Sheriff or Deputy Signature Defendant Condition SHERIFF'S RETURN - REGULAR CASE NO: 2000-03067 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND EDWARDS REBECCA MARTHA VS EDWARDS MARK STEPHEN HAROLD WEARY Amended , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within WEAPONS CONFISCATION was served upon EDWARDS MARK STEPHEN the DEFENDANT , at 0015:00 HOURS, on the 26th day of May , 2000 at 50 BONNYBROOK RD., LOT 35 CARLISLE, PA 17013 by handing to a true and attested copy of WEAPONS CONFISCATION together with and at the same time directing Her attention to the contents thereof. Additional Comments Amended SHERIFFS' DEPUTIES CONFISCATED: (1) COMPOUND BOW & (3) ARROWS AT PLAINTIFF'S ADDRESS. Sheriff's Costs: Docketing .00 Service 3.10 Affidavit .00 Surcharge .00 .00 3.10 Sworn and Subscribed to before me this 2,u-A day of A.D. Prothonotary So Answers: R. T ma' ine 05/30/2000 By: Deputy Sheriff FEB 13 200110 Rebecca Edwards IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. Mark Edwards 2000-3067 CIVIL ER OF URT AND NOW, this IV day of , 2001, the within PFA order having Been withdrawn on 06/19/00, the Sheriff is authorized to return to Mark Edwards the weapons retained as a result of these proceedings. By the Court, ft\ J. ;0391V 1` 0 - -xy F? ?C . eea? .. ... ,.. nx5z.?mur?eauxwnge. rwr?.;:?;mcems .. 6(b??o. rn , 6 dw(,e-M v c??c r?lle?.e,? S, CAS _ L41 (°??? -? cir (4244?. boI't V Clr ?G?n nbl6s nbw, TtbLcea- k?&64S , 1,z1A6dbeS 4(f CwEr• a ? aI(Ojs . UL ? (? Udc)gl tab r&k C? ?brv, ?rbt C0,g1vu, P 4 rl n? 3 01-7 z4 a z7? Z. ? IC S . 5. and c'ldO LJ)b rz&l a? '10?6 f10htY-P(n-DK 0 carlikk,-, "PiA. (171,7- S Lico ord ,?r I raaafl , c,)l 16() . j ind(-624 i n raled co t4. 4, Q,,it ? ?01 h1ou/- "AA . cc.n ,-e "s. j2-wAr) DC C(ie". Cff 6- C (-L f 910 Cf--u, Qr6 nL c4 f- r4vli? LOl 2 ?2G?rJan Te?Pec?-O 5?6-)Afgj y r ? RECEIPT FOR PAYMENT Cumberland County - Cu=rl= of Courts 1 Courthouse Square-, Carlisle. Pa f7013 EDWARDS MARK 50 BONNYBROOK RD LOT 35 CARLISLE, PA 1701,7', Trans D; sc Case Number 2000-53067 Remarks PD BY DEFENDANT MA 11- I, Total Paid $******211.20 PVMT/CHECK Probation No. 40504 Bal. Due RESTITUTION RESTITUTION CYOIfi'(T COSTS DISTRICT ATTY SHERIFFS COS( PEA SURCHARGE Receipt Date 02/@E/200:,- Receipt Time 12 % 43; 2;,-,, Receipt No. 111571--7t No. 134 O Be?. Bal. Prior PVm't;s This Pm 4 5. 5 10. -4.:ar. 544 25M 00 j24.50 ,iii. 50 MOO 13. 047" MOO OO i & 011;11 35.70 35. lit 211. n W{W: 25.00 00 k?i!L"I 2!i'it . V'Y!Gh .00 : *h Paid in Full N:* NOTE: .f:}r:ltf"{:: 'r` Due r.:..i 1, a1n7 ., this 5wE}c].f:E c case MY. Additional Costs/Fines/Restitutions may' be t:!.Ap on .}'irrlpT" cases. J I 'o. L? i= / j05 -{ tD ?i77 < I verify that the statements made in this Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904 relating to unswom falsification to authorities. Plaintiff Sworn and Subscribed To Before Me This aG ez Dag of% 2001, A. NOTARIAL SEAL PATP,ICIA A. SHATTO, Notary Public Carlisle Bore, Cumberland County My Commission Explras December 17, 2001 k o. Z.oob- -tv(,p -7 11)6&.2 , I , ol t, ?,1-riir; C; 1L? U tnu h?J rA i-o(,z3 ZZ, oo. trCi b (?6 ?1 oc?s .? IJY? til bU ohs . 1 aca-t4GC C5h o?csa £ C l c ', Cc .2/rsl4i ; ?. PFAD Number: BQ2804868C Rebecca Martha Edwards, : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, : PENNSYLVANIA vro - 3oG7 :No. CIVIL ACTION - LAW PROTECTION FROM ABUSE Plaintiff V. Mark Steven Edwards, Defendant PETITION FOR PROTECTION FROM ABUSE 1. Plaintiffs name is: Rebecca Martha Edwards 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. Rebecca Martha Edwards 4. Plaintiffs Address is : 50 Bonny Brook Rd., Carlisle, Pa 17013 5. Defendant's Name is: Mark Steven Edwards 6. Defendant is believed to live at the following address: Cumberland County Prison 7. Defendant's Date of Birth is: September 22, 1965 8. Defendant's place of employment is: Wire Mould 9. Defendant is an adult. 10. The relationship between Plaintiff and Defendant is: 1 X I spouse or former spouse of Defendant I 1 parent of a child with Defendant [XI current or former sexual or intimate partner with Defendant [ ] child of Plaintiff I I child of Defendant family member related by blood (consanguinity) to Defendant family member related by marriage or affinity to Defendant sibling (person who shares parenthood) of Defendant current or former cohabitant (person who lives with) Defendant 11. Plaintiff and Defendant have been involved in the following court actions: a. Protection From Abuse 12. Other details of the court action are: or- 13. Cumberland County, Docket No. 2000-3067 t , Defendant has been involved in a criminal court action. 14. The facts of the most recent incident of abuse are as follows: On about Thursday, June 28, 2007 location: 50 Bonny Brook Rd. #35, Carlisle, Pa. 17013 Defendant acted in a menacing manner when he slapped Plaintiff across the face, punched her in the eye several times and threatened to kill her. The Pennsylvania State Police Department was contacted and arrived to the residence. Defendant was arrested and placed in Cumberland County Prison. Plaintiff feared for her safety. 15. Prior incidents of abuse that Defendant has committed against Plaintiff or the minor child/ren, (including any threats, injuries, or incidents of stalking) are as follows: In or around June 2007, Defendant physically assaulted Plaintiff when he grabbed Plaintiff by her hair and threw her to the floor as he verbally abused Plaintiff. During the course of the parties' twelve year relationship, the Defendant has engaged in a course of conduct that puts Plaintiff in fear of bodily injury and to fear for her life. The Defendant's actions include, but are not limited to; punching, pushing, grabbing, blocking Plaintiffs exits, being mentally, emotionally and verbally abusive and threatening homicide. 16. (a) Has Defendant used or threatened to use any firearms or other weapons against Plaintiff or the minor child/ren? NO (b) Other than the firearms, other weapons or ammunition Defendant used or threatened to use against Petitioner or the minor child/ren, does Defendant, to the best of your knowledge or belief, own or possess any additional firearm, other weapon, ammunition or any firearm license? NO (c) If the answer to (b) above is "Yes", list any additional firearm, other weapon or ammunition owned by or in the possession of Defendant on Attachment A to Petition, which is incorporated by reference into this petition. (d) Plaintiff DOES NOT request that the court order Defendant to relinquish firearms, other weapons or ammunition listed on Attachment A to Petition. 17. The sheriff, police department or law enforcement agency that should be provided with a copy of the protection order are: Pennsylvania State Police 18. There is an immediate and present danger of further abuse from Defendant. 19. Plaintiff is asking the court to evict and exclude Defendant from the following residence: 50 Bonny Brook Rd. #35 Carlisle, Pa. 17013 Rented By:Mark & Rebecca Edwards 20. 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 the minor child/ren in any place where Plaintiff and/or the child/ren may be found. b. Evictlexclude Defendant from Plaintiffs residence and prohibit Defendant from attempting to enter any temporary or permanent residence of Plaintiff. c. Prohibit Defendant from having any contact with Plaintiff and/or the 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. d. Prohibit Defendant from having any contact with Plaintiffs relatives and Plaintiff's children listed in this petition, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/ren. The following persons are Plaintiffs relatives or family and household members that Plaintiff believes require protection from stalking and harassment by Defendant. e. Order the following additional relief, not listed above: Defendant shall not damage or destroy any property owned by the parties or solely by the Plaintiff. Defendant shall not stalk the Plaintiff. Non-harassing, non-threatening contact via third party, regarding Defendant's personal belongings and/or financial obligations, shall not be deemed a violation of this order. f. Order the police, sheriff or other law enforcement agency to serve Defendant with a copy of this petition, any order issued, and the order for hearing. Plaintiff will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. Respectfully submitted, MIDPENN LEGAL SERVICES Date: 7 7 By: Grace E. D'Alo, Attorney for Plainti Jessica Holst, Attorney for Plaintiff Geoffrey M. Biringer, Attorney for Plaintiff 401 East Louther Street, Suite 103 Carlisle, PA 17013 (717) 243-9400 VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S.§4904, relating to unworn falsification to authorities. Dated: July 9, 2007 U L Rebecca A Edwards, Plaintiff - C I aS7 ; C`. a (0 50 1165-9 3 Rebecca Martha Edwards, Plaintiff v Mark Steven Edwards, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 2000 - 3067 CIVIL TERM - LAW PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claim 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, be prohibited from possessing any firearm, other weapon, ammunition or any firearm license, and lose other important rights, including custody of your children. Any protection order granted by a court may be considered in subsequent proceedings under Title 23 (Domestic Relations) of the Pennsylvania Consolidated Statutes, including child custody proceedings under Chapter 53 (relating to custody). A heart o e matter is scheduled for the / O day of , 2007, at ?J - m., with Judge G " • cLb in Co oom o. on the 4 Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. You MUST obey the order that is attached until it is modified or terminated by the court after notice and hearing. If you disobey this order, the police or sheriff 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.A. §6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18. U.S.C. §2265, this order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this order, you may be subject to federal criminal proceedings under the Violence Against Women Act. 18 U.S.C. §2261-2262. If this order directs you to relinquish any firearm, other weapon, ammunition or any firearm license to the sheriff, you may do so upon service of this order. As an alternative, you may relinquish any firearm, other weapon, or ammunition listed herein to a third party provided you and the third party first comply with all requirements to obtain a safekeeping permit. You must relinquish any firearm, other weapon, ammunition or any firearm license listed herein no later than 24 hours after service of the order. Failure to timely relinquish any firearm, other weapon, ammunition or any firearm license shall result in a violation of this order and may result in criminal conviction under the Uniform Firearms Act, ,18 Pa. C.S.A.§6105. NOTICE: Even if this order does not direct you to relinquish firearms, you may be subject to federal firearms prohibitions and federal criminal penalties under 18 U.S.C. §922(g)(8). YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEARING. THE COURT WILL NOT, HOWEVER, APPOINT A LAWYER FOR YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT FIND A LAWYER, YOU MAY HAVE TO PROCEED WITHOUT ONE. County Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA 17013 717-249-3166 Distribution to: Legal Services Faxed & Mailed to PSP This verifies that the above document is on file with the Cumberland County Office of the Prothonotary. dh TRANSMISSION VERIFICATION REPORT T1FIL J^ JJ?UCJ1 1J. 4J NAME PROTHONOTARY C LONG FAX 7172406573 TEL SER.# BROH3J606381 DATE,TIME 07/09 15:46 FAX NO./NAME 92458792 DURATION 00:01:36 PAGE(S) 09 RESULT OK MODE STANDARD ECM OFFICE OF THE PROTHONOTARY CUMBERLAND COUNTY COURTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA 1.7013-3387 (717)240-61,95 WM0 k? To: Central Processing, Legal Services Fax# From: Cumberland County Prothonotary RE: Message: 9 No of pages (including cover sheet) This message is intended for the use of tbe, individuni nr isnfifv to wh;,-h W. ;? TRANSMISSION VERIFICATION REPORT TIME 07/09/2007 15:50 NAME PROTHONOTARY C LONG FAX 7172406573 TEL I Lit-a I tI 1 P'+ft t? r i b s 1:i : ?P'? FAX N0./NAME 92438026 DURATION 00:01:10 PAGE(S) 09 RESULT OK MODE STANDARD ECM OFFICE OF THE PROTHONOTARY d-irr?irn-VnT AXT-n PnTTNTv rill TUT1401TSF, ONE COURTHOUSE SQUARE CARLISLE, PAS 17013-3387 (717) 240-6195 '14 .'. Tn. 4-pntral FrnePCCtina_ X ,oval ServlceS 1 l1•* - - T /1 From: Cumberland County Prothonotary RE: 9 No of pages (including cover sheet) . __-_-- __ i-4-- -1-j *-- 4L. .,... .,4' +1,., .nAivirln4l nr jantit[i to Which it ie Campbell, Laura From: ra-jnetoperations@state.pa.us Sent: Monday, July 09, 2007 5:17 PM To: Campbell, Laura Subject: PFAD Document Confirmation No.003067 against EDWARDS, MARK PFAD Document Confirmation No.003067 against EDWARDS, MARK filed by EDWARDS, REBECCA RECORD ACCEPTED BY CLEAN: 2007-07-09 17:16:28Z Rebecca Martha Edwards, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V NO. 2000 - 3067 CIVIL TERM Mark Steven Edwards, Defendant PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff, Rebecca Martha Edwards, by and through her attorneys, MidPenn Legal Services, moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. A Temporary Protection From Abuse Order was issued by this Court on July 9, 2007, scheduling a hearing for July 18, 2007, at 3:30 p.m. 2. The Cumberland County Sheriff's Department served Defendant with a certified copy of the Notice of Hearing, Temporary Protection From Abuse Order and Petition for Protection From Abuse on July 10, 2007. 3. Counsel for both Plaintiff and Defendant are in the process of negotiating a Consent Agreement 4. Attorney for Plaintiff requests a continuance of this hearing to allow for the completion of Consent Order. Counsel for Defendant does not oppose this continuance. WHEREFORE, Plaintiff requests that the Court grant this Motion and generally continue this matter, and that the Temporary Protection From Abuse Order remain in effect through July 9, 2010, or until further Order of Court, whichever comes first. Respectfully Submitted, MIDPENN LEGAL SERVICES BY: a race JAIY, Attorney for Plaintiff Jessica st, Attorney for Plaintiff 401 E. Louther Street, Suite 103 Carlisle, PA 17013 JUL 19 W Rebecca Martha Edwards, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V : NO. 2000 - 3067 CIVIL TERM Mark Steven Edwards, Defendant PROTECTION FROM ABUSE ORDER AND NOW, this 18th day of July 2007, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on July 18, 2007, by this Court's Order of July 9, 2007, is hereby continued generally. Either party may petition the Court to have this matter scheduled for hearing. The Temporary Protection From Abuse Order shall remain in effect through July 9, 2010, or until further Order of Court, whichever comes first. By the Court, Edward E. Guido, Judge Grace E. D'Alo, Attorney for Plaintiff Geoffrey Biringer, Attorney for Plaintiff Jessica Holst, Attorney for Plaintiff XdPenn Legal Services 401 E. Louther Street, Suite 103 Carlisle, PA 17013 Xrl E. Rominger, Attorney for Defendant 155 South Hanover Street Carlisle, PA 17013 J Co SHERIFF'S RETURN - REGULAR CASE NO: 2000-03067 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND EDWARDS REBECCA MARTHA VS EDWARDS MARK STEPHEN MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon wnwapnq MARK gTRPTHFN the DEFENDANT , at 1533:00 HOURS, on the 10th day of July 2007 at CUMBERLAND COUNTY PRISON 1101 CLAREMONT ROAD CARLISLE, PA 17013 by handing to a true and attested copy of PROTECTION FROM ABUSE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge ?, 1/9369 So Answers: 18.00 4.80 00 10.00 R. Thomas Kline .00 ? 32.80 00/00/0000 Sworn and Subscibed to before me this of By l day Depu y She iff A.D. Rebecca Martha Edwards, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V NO. 2000 - 3067 CIVIL TERM Mark Steven Edwards, Defendant PROTECTION FROM ABUSE PETITION TO VACATE ORDER AND WITHDRAW ACTION Plaintiff, Rebecca Martha Edwards, by and through their attorneys, MidPenn Legal Services requests that the Court vacate the Temporary Order of Court in the above-captioned case and that the action be withdrawn on the grounds that: 1. A Temporary Order of Court was entered on July 9, 2007. 2. Plaintiff requests that the Temporary Order of Court be vacated and the action withdrawn without prejudice to her. 3. A certified copy of this Order will be provided to the Police Department by attorney for Plaintiff. WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate the Order, and that the action be withdrawn without prejudice to Plaintiff. Respi(*f *y Abmitted, Grace HJD"Alo, Attorney for Plaintiff Jessica C. Holst, Attorney for Plaintiff Geoffrey Biringer, Attorney for Plaintiff MIDPENN LEGAL SERVICES 401 E. Louther, Suite 103, Carlisle, PA 17013 VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Dated: ter :ace Rebecca Martha Edwards, Plaintiff if, 114, ?, MidPenn Legal Services 401 E. Louther Street, Suite 103, Carlisle, PA 17013 717-243-9400 FAX 717-243-8026 Toll-Free 800-822-5288 www.midpenn.org I, Rebecca Martha Edwards, hereby direct MidPenn Legal Services to file a Petition to Vacate Order and Withdraw Action on my behalf (Edwards v Edwards, No. 2000-3067). I understand that upon entry of an Order in this matter that the Court will vacate the Temporary Order of Court entered on July 9, 2007, and that my Protection From Abuse action will be withdrawn. In addition, I request that no further litigation be filed on my behalf in this case, and I no longer desire that MidPenn Legal Services represent me in this matter at this time. I understand that my Protection From Abuse case will be closed. I have been advised by MidPenn Legal Services staff that I can contact their offices in the future if I need legal assistance in this or any other matter handled by their program, and that if I meet the program's requirements, they may be able to assist me. Date: FJA LAb&t Rebecca Martha Edwards, Plaintiff II1 LSC C> N C7 'Y.1 t t a"' ? --n = 1 co ? fJ -?j Campbell, Laura Jo -3 (-)6' -7 From: ra-jnetoperations@state.pa.us Sent: Thursday, August 09, 2007 11:38 AM To: Campbell, Laura Subject: PFAD Document Confirmation No.003067 against EDWARDS, MARK PFAD Document Confirmation No.003067 against EDWARDS, MARK filed by EDWARDS, REBECCA RECORD ACCEPTED BY CLEAN: 2007-08-09 11:37:53Z 1 ii-7 5-d (o Rebecca Martha Edwards, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V : NO. 2000 - 3067 CIVIL TERM Mark Steven Edwards, Defendant PROTECTION FROM ABUSE ORDER OF COURT AND NOW, this 8th day of August, 2007, upon consideration of the attached Petition, the Temporary Order of Court in the above-captioned case entered on July 9, 2007, is hereby vacated and the action withdrawn without prejudice to Plaintiff. A certified copy of this Order shall be provided to the Police Department by Plaintiff's attorney. Edward E. Guido, Judge Grace E. D'Alo, Attorney for Plaintiff Jessica Holst, Attorney for Plaintiff Geoffrey Biringer, Attorney for Plaintiff MidPenn Legal Services vo, 401 E. Louther Street, Suite 103 Carlisle, PA 17013 Karl E. Rominger, Attorney for Defendant 1r? 155 South Hanover Street r4 _ a Carlisle PA 17013 x?A4-o CF -4 I-5 e t e J. +- P S P ??L iili ?'.1 i ?'?1 i? L? •01 WV b` SAID LCOZ AweU aU i J d 3RL 40