Loading...
HomeMy WebLinkAbout00-03317 . ~= - ~----M", MELANIE T. WHITE, Plaintiff : IN THE COURT OF COMMON PLEAS OF vs. : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00- ~~ 17 CIVIL TERM CHARl,ES V. WHITE Defendant : PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A HEARING ON THIS MATTER IS SCHEDULED ON ~ 7 ,2000, AT 1/: IJi) /I- .M.,INCOURTROOMNO. -3 0 HE CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PENNSYL VANIA. You MUST obey the Order that is attached until it is modified or terminated by the court afternotice 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 fme of up to $1,000.00 and/or up to six months mjail under 23 Pa.C.S. g6114. Violation may also subj ect you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. g2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. g 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 lawyell' 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 arrange;nents must be made at least 72 hours pTior to any hearing or business before the court. You must attend the scheduled conference or hearing. ...,~ <'" ~I ~l;lj~iMfill~iIkilillilllii~"-'f"-~>'" ~.~~~IlIiIi~~~dalH ~ C\I € - "" .. ~~ :Q. ..:f ~5 %: ~ u.;:.~ 0- D~ ISr"" ?;,i? 0 ?ii ",,15: C'"l if i.. ffLIJ ,.... uJ' :3.. ..oc a::t r- :& :a -u_ 0 ::> 0 0 0 .. --"~- ",,' .. , . ~ '-""~~I~' n - MELANIE T. WHITE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00- CIVIL TERM CHARLES V. WHITE Defendant : PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name: Charles V. White Defendant's Date of Birth: August 26,1972 Defendant's Social Security Number: 170-68-1916 Name of Protected per~ Mel . T. White AND NOW, thi~ day of , 2000, upon consideration of the attached Petition for Protection fro ~buse,t e urt hereby enters the following Temporary Order: [&) 1. Defendant shall not abuse, harass, stalk or threaten the above person in any place where she might be found. o 2. Defendant is evicted and excluded from the residence at _ or any other permanent or kmporary residence where Plaintiff may live. Plaintiff is granted exclusive possession of the residence. Defendant shall have no right or privilege to enter or be present on the premises. [&) 3. Except for such contact with the minor children as may be permitted under Paragraph 5 of this Order, Defendant is prohibited from having ANY CONTACT with Plaintiff at any location, including, but not limited, to any contact at Plaintiffs school, business, or place of employment. Defendant is specifically ordered to stay away from the following locations for the duration of this Order: 801 North College Street, Carlisle, Pennsylvania 17013. [&) 4. Except for such contact with the minor children as may be permitted under Paragraph 5 of this Order, Defendant shall not contact Plaintiff. , W~." I.... '_ ,k_". 129 5. Plaintiff and Defendant shall exercise the informal custody arrangement previously agreed upon by the parties. However, due to the most recent incident of abuse, the pick-up and drop-off location will be at minor children's grandparents residence located at 515 Thornwood Lane, Carlisle, Pennsylvania. Additionally, any other arrangements that need to be made for the minor children will be handled through the grandparents of minor children, Charles and Eileen White, residing at 515 Thornwood Lane, Carlisle, Pennsylvania. 129 6. Defendant shall immediately relinquish all weapons to the Sheriff's Office or a designated local law enforcement agency for the delivery to the Sheriff's Office. Defendant is prohibited from possessing, transferring or acquiring any other weapons for the durati6n of this Order. 129 7. The following additional relief is granted: The Cumberland County Sheriff's Department shall attempt to make ~ervice at Plaintiff s request and without pre-payment offees, but service may be accomplished under any applicable Rule of Civil Procedure. This Order shall be docketed in the office of the Prothonotary and forwar<;1ed 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 and/or the children in the jurisdiction or llistrict or furnish any address, telephone number, or any other demographic information about Plaintiff and/or children 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 fmds that Defendant has committed an act of abuse or has engaged in a pattern or practice that indicates risk of harm to Plaintiff and/or minor children. 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 e;xpiration 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) 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. FOR JUVENILE DEFENDANTS: In the event that an arrest is made, the arresting officer shall file a complaint with the JUVENILE COURT. The provisions relating to detention shall be addressed to the on-duty probation officer, and the matter shall be scheduled promptly for pro(essing, adjudication and disposition with the judge scheduled to deal with juvenile matters. 00- 8. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: 00- 9. THIS ORDER SUPERSEDES: ~ ANY PRIOR PF A ORDER and o ANY PRIOR ORDER RELATING TO CHILD CUSTODY THIS ORDER APPLIES IMMEDIATEL YTO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fme of up to $1,000.00 and/or up to six months injail. 23 Ya.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 himlher to state charges and penalties under the Pennsylvania Crimes Code and to federal chmges and penalties under the Violence Against Women Act, 18 U.S.C. ~~ 2261-2262. Any protection order granted by a court may be considered in any subsequent proceedings, inclUding child custody proceedings, I.lUder title 23 (Domestic Relations) of the Pennsylvania Consolidated Statutes. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiffs residence OR any locations where a violation of this order occurs OR where the defendant may be located. If defendant violates Paragraphs I through 6 of this Order, defendant may be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence oflaw enforcement. . ~"""'\i Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threitened 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, whkh office shall maintain possession of the weapons until further Order of this Court, unless the weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. BY THE COURT, . Judge Paul Bradford Orr, Attorney for Plaintiff - ...~- ~> """J~"_; MELANIE T. WHITE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00- 3.311 CIVIL TERM CHARLES V. WHITE, Defendant : PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE 1. 17013. The Plaintiff is Melanie T. White, 801 North College Street, Carlisle, Pennsylvania 2. The name of the person, who seeks protection from abuse is: Melanie T. White 3. Plaintiffs address is: 801 North College Street, Carlisle, Pennsylvania 17013. 4. Defendant is believed to live at the following address: 515 Thomwood Lane, Carlisle, Pennsylvania 17013. Defendant's Social Security Number is 170-68-1916 Defendant's date of birth is August 26,1972 Defendant's place of employment is Fry Communications, Mechanicsburg, Pennsylvania 6. Defendant is Plaintiffs estranged husband. 7. Plaintiff and Defendant have been involved in the following court action fordivorce: Case name White v. White Case No. 00-1278 Date filed 3/7/00 Court Cumberland Co.-Common Pleas 8. Plaintiff and Defendant are the parents of the following minor children: Name Al!:e KelseyB.N. White 10 Y, Laurel B.L. White 4 Y, 9. There is NOT an existing Court Order regarding custody of the parties' children. . ~ ~~" , '""'< ~ " 10. The facts of the most recent incident of abuse are as follows: Approximate Date: May 29, 2000 Approximate Time: 5:30 P.M. Place: 801 North College Street, Carlisle, Pennsylvania On the above date and time, the Defendant arrived at 801 North College Street to pick up minor children for visitation. At such time, the Defendant attempted to remove a car seat from Plaintiff s van and dislodged the door from the van. Plaintiff walked over to the van and expressed that she would remove the car seat herself. At that time, Defendant became hostile and began yelling obscenities loud enough for both minor children to hear. After defendant placed car seat in his truck, he approached'Plaintiff and stated to their older child, "Kelsey, take your sister in the house, I need to slap your mother around a little bit". At that time, Defendant grabbed Plaintiff by her t)rroat and began choking her and pushed her into the van and then on the ground. Defendant then grabbed Plaintiff by her feet and drug her into her house. Defendant took children and placed them in his truck. Plaintiff locked the door to the house and called the Carlisle Borough Police Department. 11. Defendant has committed the following prior acts of abuse against Plaintiff: a) In January of 2000 Defendant made threats to Plaintiff that he was going to put his hands around her neck and choke her. . b) In September of 1999 Defendant grabbed Plaintiff by her arm and t)rroat and drug her into the house. 12. The following police department or law enforcement agency in the area in which Plaintifflives should be provided with a copy ofthe Protection Order: Carlisle Borough Police Department. 13. There is an immediate and present danger of further abuse from Defendant. , WHEREFORE, PLAINTIFF REQUESTS THAT THE COURTjENTER , A TEMPORARY ORDER, AND AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: A, Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff in any place where Plaintiff may be found. B. Prohibit Defendant from having any contact with Plaintiff, either in person, or in writing, personally or through third persons, including, but not limited to, arty contact at Plaintiffs school, business, or place of employment, except as the Court may fmd necessary with respect to partial custody and/or visitation with the minor children. - . ~- , - "'\!~,"- C. Prohibit Defendant from having any contact with Plaintiff, except as the court may find necessary with respect to partial custody and/or visitation with the minor children. D. 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. E. Order Defendant to pay the costs of this action, including filing and service fees. F. Order the following additional relief, not listed above: The 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. The Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. The Defendant is to refrain from harassing Plaintiff's relatives. G. Grant such other relief as the court deems appropriate. H. Order the police or other law enforcement agency to serve Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The Petitioner will inform the designated authority of any addresses, other than Defendant's residence, where Defendant can be served. D,,,2M 00 FORP ORR Paul Bradford Orr, E quire 50 East High Street Carlisle, P A 17013 (717) 258-8558 ill No. 71786 . > -~ -.-~>~ . , ~ ~ ~' >, -,[" VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. 94904, relating to unsworn falsification to authorities. Dated: ')/ '?t)/CS[) ~~ . , ~, "~"--, ....I't~,,,. , , MELANIE T, WlllTE, Plaintiff : IN THE COURT OF COMMON PLEAS OF ; CUMBERLAND COUNTY, PENNSYLVANIA vs, : NO, 00- CIVIL TERM CHARLES V, WHITE Defendant : PROTECTION FROM ABUSE AFFIDAVIT OF SERVICE I, , do hereby certifY that on , 2000, I did personally serve upon Defendant, Charles V, White, the above-captioned Temporary Protection Order and Petition for Protection Order at , , Cumberland County, Pennsylvania, _0 '" "" ~ - ~ .~ ~ " --~." 05/31/00 WED 14:22 FAX 717 240 6573 CUMB CO PROTHONOTARY 141001 . ********************* *** TX REPORT *** ********************* TRANSMISSION OK TX/RX NO CONNECTION TEL CONNECTION ID ST. TIME USAGE T PGS. RESULT 1897 92490779 05/31 14:16 06'19 8 OK ", SHERIFF'S RETURN - REGULAR CASE NO: 2000-03317 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WHITE MELANIE VS WHITE CHARLES V SHANNON SUNDAY , Sheriff or Deputy Sheriff of Cumberland county, Pensylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon WHITE CHARLES V the DEFENDANT , at 0020:00 HOURS, on the 30th day of May , 2000 at 515 THORNWALD LANE CARLISLE, PA 17013 by handing to CHARLES WHITE a true and attested copy of PROTECTION FROM ABUSE together with TEMPORARY PROTECTION FROM ABUSE ORDER, NOTICE OF HEARING & ORDER, PETITION and at the same time directing His attention to the contents thereof. Additional Comments WEAPONS CONFISCATED FROM DEFT. AND PLAINTIFF'S RESIDENCE. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.10 .00 10.00 .00 31.10 So An6'wers: ~~ It'<~~ R. Thomas Kline 06/02/2000 me Sworn and Subscribed to before this 7 ~ day of C}"... ~ A.D. ~"(}A~~ . thonotary . ' By L /11. ~. . Deputy Sheriff - ~ - '. '" . ~'.."' . , .. MELANIE T. WHITE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-3317 CIVIL TERM CHARLES V. WHITE, Defendant : PROTECTION FROM ABUSE AND CUSTODY FINAL PROTECTION ORDER Defendant's Name: CHARLES V. WHITE Defendant's Date lJfBirth: AUGUST 26,1972 Defendant's Social Security Number: 170-68-1916 Name/s of Protected persolV\ELANI[ ~~.W~TE AND NOW, this W day of ~ ' 2000, the court ll1aving jurisd;ctiolll over the parties and the subject-matter, it is ORDERED, ADJUDGED, and DECREED as follows: .Plaintiff, Melanie T. White, is represented by The Law Offices of Paul Bradford Orr, Paul Bradford Orr, Esquire: Defendant, Charles, is represented by Broujos & Gilroy, P.C, Hubert X. Gilroy, Esquire. Defendant, although agreeing to the terms of this Order, does not admit the allegations made in the Petition. ~ Plaintiffs request for a Final Protection Order is granted pursuant to the consent of Plaintiff and Defendant. o Plaintiffs request for a Final Protection Order is denied ~ 1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other protected person in any place where they might be found. o 2. Defendant is completely evicted and excluded from the residence at or any other residelll'~ where Plaintiff may live. Exclusive possession ofthe residence is granted to Plaintiff. Defendant shall ha ve no right or privilege to enter or be present on the premises. ., ^ I. .. o On at .m., Defendant may enter the residence to retrieve hislher clothing and other personal effects, provided that Defendant is in the company of a law enforcement officer when such retrieval is made. lli> 3. Except as provided in Paragraph 5 of this Order, Defendant is prohibited from having ANY CONTACT with Plaintiff at any location, including, but not limited to, any contact at Plaintiffs residence, her business. Defendant is specifically ordered to stay away from the following locations for the duration of this Order: 801 North College Street, Carlisle, Pennsylvania 17013. lli> 4. Except for such contact with the minor children as may be permitted under Paragraph 5 of this Order, Defendant shall not contact the Plaintiff. lli>.5. Plaintiff and Defendant shall exercise the informal custody arrangement previously agreed tlpon by the parties. However, due to the most recent incident of abuse, the pick-up and drop- offIocation will be at the minor children's grandparent's residence located at 515 Thornwood Lane, Carlish~, Pennsylvania. Additionally, any other arrangements that need to be made for the minor children will be handled through the grandparents of the minor children, Charles and Eileen White, residing at 515 Thornwood Lane, Carlisle, Pennsylvania. lli> 6. Plaintiff agrees that any and all weapons seized from the Defendant at the time of the Temporary Order shall be returned to the Defendant. o 7. Defendant is prohibited from possessing, transferring or acquiring any other weapons for the duration of this Order. Any weapons delivered to the sheriff under Paragraph 6 of this Order or under Paragraph 6 of the Temporary Order shall not be returned until further Order of Court. o 8. The following additional relief is granted as authorized by ~6108 ofthis Act: Law enforcement agencies, human service agencies and school districts shall not disclose the presence of Plaintiff and/or address, telephone munber, or any other demographic information about Plaintiff and/or the minor child/ren 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 and/or the minor children. 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 Final 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 -~~ , ...t>.- .. 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 or the minor child/ren. Defendant is ordered to reimburse Cumberland County, a Legal Services funding source, $250.00 for the value of the legal services provided to Plaintiff for the cost of litigating this case. o ' I. Defendant is directed to pay temporary support for (insert the names of the persons for whom support is to be paid) as follows: (insert amount, frequency and other terms and conditions of the support order) . This Order for support shall remain in effect until a final support order is entered by this Court. However, this Order shall lapse automatically if Plaintiff does not file a complaint for support with the Court within fifteen (15) days of the date of this Order. The amount of this temporary order does not necessarily reflect Defendant's correct support obligation, which shall be determined in accordance with the guidelines at the support hearing. Any adjustments in the final amount of support shall be credited, retroactive to this date, to the appropriate party. o 10. The costs of this action are waived as to Plaintiff and imposed on Defendant. o 11. Defendant shall pay $ to Plaintiff as compensation for Plaintiff's out-of-pocket losses, which are as follows: OR o Plaintiffis granted leave to present a petition, with appropriate notice to Defendant, to (insert the name of the judge or court to which the petition should be presented) requesting recovery of out-of-pocket losses. The petition shall include an exhibit itemizing all claimed out-of-pocket losses, copies of all bills and estimates of repair, and an Order scheduling a hearing. No fee shall be required by the Prothonotary's office for the filing of this petition. o 12. BRADY INDICATOR o 1. Plaintiff or protected person/s is a spouse, former spouse, a person who cohabitates or has cohabited with Defendant, a parent of a common child, a child of that person, or a child of Defendant. o 2. This Order is being entered after a hearing of which Defendant received actual notice and had an opportunity to be heard. o 3. Paragraph I of this Order has been checked to restrain Defendant from harassing, stalking, or threatening Plaintiff or protected person/so o 4. Defendant represents a credible threat to the physical safety of Plaintiff or other protected person/s OR ~'" - "--' - '....... " , o The terms of this Order prohibit Defendant from using, attempting to use, or threatening to use physical force against Plaintiff or protected person that would reasonably be expected to cause bodily injury. [29 13. THIS ORDER SUPERCEDES ANY PRIOR PF A ORDER. and o ANY PRIOR ORDER RELATING TO CHILD CUSTODY. [29 14. All provisions of this Order shall expire one year from the date this Order is entered. NOTICE TO THE DEFENDANT VIOLA nON OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICHIS PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 P A.C.S. ~6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENAL TIES 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 tiNDER THE VIOLENCE AGAINST WOMEN ACTION, 18 U.S.C. ~2265. IF YOU TRAVEL OUTSmE 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. IFP ARi\GRAPH 12 OF THIS ORDER HAS BEEN CHECKED, YOUMA YBE SUBJECT TO FEDERAL PROSECUTION AND PENAL TIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACTION, 18 U.s.C. ~922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION. .-." -- " , '.--,- . 'joi,-, , NOTICE TO LAW ENFORCEMENT OFFICIALS The police who have jurisdiction over Plaintiff's residence OR any location where a violation of this Order occurs OR where Defendant may be located, shall enforce this Order. An arrest for violation of Paragraphs 1 through 7 of this Order may be without warrant, based solely on probable cause, whether or not the violation is committed in the presence of the police. 23 Pa.C.S. 96113. Subsequent to an arrest, the police officer shall seize all weapons used or threatened to be used during the violation of the Protection Order or during prior incidents of abuse. The Cumberland County Sheriffs Department shall maintain possession of the weapons until further Order of this Court. When Defendant is placed under arrest for violation of the Order, Defendant shall be taken to the appropriate authority or authorities before whom Defendant is to be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police officer OR Plaintiff, Plaintiff's presence and signature are not required to file the complaint. If sufficient grounds for violation of this Order are alleged, Defendant shall be arraigned, bond set and both parties given notice ofthe date of the hearing. ~ C~ 0.00 \i~ t1-~ This Order is entered pursuant to the consent of Plaintiff and Defendant: wb flaJul ~}Ml 1:0 P!3P /p-ll-aO 1?K.3 THE LAW OFFICES OF PAUL BRADFORD ORR 50 East High Street Carlisle, PA 17013 (717) 2:\8-8558 Certifiel copies to: Pennsylvania State Police Carlislll Police Department ,~L"",,"~O>"O=~'.'i~~~~\ill1l"';;';IOl~i!!iIil'fu;i;lilll''; '~ ~? I~-: , ~. -' ~~ !L. C' ,,""') Cr;. ~:.: ,>- I=: "~f [~.~~ "'~&) -:--:;2 .',C;~ ~ t.J l' I S'Q .:;:;: =) o (L c) ('-..,' 3~ =:; C:"} c) I"". _, ~~ -'lliIIIi"- ~~ .-~- ~'~i1uIiIU - ~ ~ " ..-'- - 06/21/00 WED 09:02 FAX 717 240 6573 , "."~ ~~.... ' ".J,~" ~_ - ' CUMB CO PROTHONOTARY ~001 TRANSMISSION OK TX/RX NO CONNECTION TEL CONNECTION ID ST. TIME USAGE T PGS. RESULT ********************* *** TX REPORT *** ********************* 1940 92490779 06/21 08:57 05'21 7 OK ,,,,- . . " ~=' , '-_i~ ~~ ~"'''''"'' .. SHARON L. WITTER and her Husband, WILLIAM E. WITTER, P1.aintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 00-321.7 MICHAEL EUGENE BEERSr Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE AND NOW, this 7th day of September, 2000r I, Shawn T. Peterson, hereby certify that I have served a true and correct copy of Plaintiffsr Answers to Interrogatories (Set I) Sent by Defendant, by depositing a copy of the same in the United States Mail, postage prepaid, at Harrisburg, Pennsylvaniar addressed to: Guy H. Brooks, Esquire Goldberg, Katzman & Shipman, P,c. 320 Market Street Strawberry Square P.O. Box 1268 Harrisburg, PA 17108-4161 Respectfully submitted, SCHMIDT, RONCA & KRAMER, P.C. BY: k~ Shawn T. Peterson, Paralegal 209 State Street Harrisburg, PA 17101 (717) 232-6300 i",~ ~~~~_t~ ~~~~_. "".......~_..""""- ~.~,' ,',' ~ ,""_ ~,,_,," ,,~~~ ~_~_ .=_ = _._ ~ ~ _, 'c .. q - ,. "~ ,r- ...~~~ ~ ~ "',,' ^" 0 C:;:. ~. c= C.:..:- ' , ;."~ ", , g}g? U') 0" --iJ I - .~~_ t: (J) C':) -< r-' -- "Q 2: () ..LC )>C~ ~~ :~:5 z :;J :;! c::- ::D -< ~ SHARON L. WITTER and her Husband, WILLIAM E. WITTERr Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. No. 00-3217 MICHAEL EUGENE BEERSr Defendant CIVIL ACTION - LAW JURY TRIAL DEMANDED CERTIFICATE OF SERVICE i AND NOW, this 7th day of September, 2000, I, Shawn T. Peterson, hereby certify that I have served a true and correct copy of Plaintiffs' Responses to Requests for Production of Documents (Set I) Sent by Defendant, by depositing a copy of the same in the United States Mail, postage prepaidr at Harrisburg, Pennsylvania, addressed to: Guy H. Brooks, Esquire Goldbergr Katzman & Shipman, P.C. 320 Market Street Strawberry Square P.O. Box 1268 Harrisburg, PA 17108-4161 Respectfully submitted, SCHMIDT, RONCA & KRAMER, P.C. BY: awn T. Peterson, Paralegal 209 State Street Harrisburg, PA 17101 (717) 232-6300 ~"~' t ill:<..;."j , , . MELANIE T. WHITE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW CHARLES V. WHITE, Defendant : NO. 00-3317 CIVIL TERM : Protection From Abuse and Custody ~RDER TO VACATE AND NOW, this ~ day of February, 2001, upon Plaintiffs Petition to Vacate Order and Withdraw Action: 1. This matter is dismissed without prejudice. ii. _ ____ __~_~ !'"VWvuJ,!!~' .vu. _ 3. The Temporary Protection From Abuse OrderIFinal Protection Order entered on June 20, 2000, is hereby vacated. BY THE COURT, Distribution to: Paul Bradford Orr, Attorney for Plaintiff Hubert X. Gilroy, Attorney for Defendant Rl 'r .......~ ~~~''''-, --^-~ ~-- 0;: - ,i,:,--':-',:]IARY i" Fcp I ~, 1 i : /,8 ,.) J ~... >.,,' l 1_ CUf\l18EHiJ\i\:L COUNTY PENNSYLVANIA , .~lo_]iJlJI! ~I!I~- ~_ Jllii ~~L B/!IIi:"!l'I~~ ' - -, "' '. . "~~'-'''T'~ '-- .-....~"U__ ,d!,!/!. ~. . , MELANIE T. WHITE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW CHARLES V. WHITE, Defendant : NO. 00-3317 CIVIL TERM : Protection From Abuse and Custody PETITION TO V ACA TE ORDER AND WITHDRAW ACTION I:' Plaintiff, Melanie T. White, by and through her attorneys, The Law Offices of Paul Bradford Orr, requests that the Court vacate the Temporary Protection From Abuse/Final Protection Order in the above-captioned case and that the action be withdrawn on the grounds that: I. A Petition for Protection From Abuse was filed and a Temporary Protection From Abuse Order was issued by this Court on May 30, 2000, scheduling a hearing for June 7, 2000. A Final Protection Order was entered by agreement of the parties on June 20, 2000. 2. The parties are in the process of reconciling their differences. 3. Plaintiff request that the Temporary Protection From Abuse OrderIFinal Protection Order be vacated and the action withdrawn without prejudice to her. WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate the Order, and that the action be withdrawn without prejudice to the Plaintiff. D,m II ~llol Paul Bradford Orr, Esquire 50 East High Street Carlisle, P A 17013 (717) 258-8558 Supreme Court ill No. 71786 ~~ ~ ~~. --il'-t. ~ " -~ , " MELANIE T. WHITE, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW CHARLES V. WHITE, Defendant : NO. 00-3317 CIVIL TERM : Protection From Abuse and Custody VERIFICATION I verify that the statements made in the foregoing Petition are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. S 4904, relating to unsworn falsification to authorities. DATE: 1151/ 01 "'!'''''''''''7 - ....... . ~ '51 l~ 02/12/01 MON 14:05 FAX 717 240 6573 CillIB CO PROTHONOTARY 141001 . - , *****************$********* u* MULTI TN REPORT *u ***********$$$$***$*$$$$$$$ TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2452 [ 01l9p2405331 [ 04]92490779 CENTRAL PROCESS PSP ERROR . OFFICE OF 'lliE PROTIfCN'JTARY CUMBERLAND COONT"l rourmiCuSE ONE a:xJRWOOSE SQUARE CARLISLE, PA. 17013-3387 (717) 240-6~95 FAX (717) 240-6573 VIA TELECOPIER cP LS TO: PA STATE POLICE FAX #: 717-249-0779 M) FRCM: CURTIS R. LONG RE: PFA ORDERS MESSAGE: ,;( f Jf .~ 00. OF PAGEs (INCLUDING COVER SHEET) 1:his ~ is int:BlEl cnly fur' tre !.Be of Ire irrli,v:idu;lJ. cr ent:il;v lD \<hid'! is is cilll...JSa::l, crd rrey mrt;rin infi:ltrIBti<:n ttat is ~. o:nf:kEnt:.ial a'd ~ fron di.....l.....~ U1i:!l: WH",*,lp J.a,t. {f liE rerl3r of this ~ is rot liE int:En:b:l m:ipiri, }OJ are ~ roti.filrl tmt av c:l.is3Emi.ratirn, disttil:ubm at" r;q;;yJrg of this o:mnnicatlm :is strictly p:drlbitB::!. If}Q.l!me J:W'i!i...w ttus a:nmni(.r...im in er::t'Ol:'. pl.a;;i;e ratify \E :ilmaliatBly ~ teleI;h:re a-d teb.lm t1-e o:ig:ire1." :"'3" In IS ,,( tl-e 6"n.'o' a11r:ess via tiE [l.S. p:l'ltal ~io;:. 'Ita1k ~.