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HomeMy WebLinkAbout00-03658 o' iI_,- ROVENA M1\RIE BRIDI, Plaintiff : IN THE COURT OF COMMON PLEi\S OF vs. : CUMBERLAND COUNTY, PENNSYL V ANIi\ : NO. 2000- iitsg CIVIL TERM JOHN Mi\TTHEW PARR, Defendant : PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER / ___J YOU HAVE BEEN SUED IN COURT. If you wish to derend 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. i\hearing on this matter is scheduled on the~y ofJune, 2000, at ~:.$() p. m., in Courtroom No. ~ 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 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 US.C. ~2265, this Order is enforceable anywhere in the United States, tribal lands, US. 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 US.C. ~ 2261-2262. You should take this paper to your lawyer atoDce. 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 Of 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 acconnnodations available to disabled individuals having business before the court, please contact our office. N1 arrangements must be made at least 72 hours prior to any hearing or bUllilltSS \?WPfe tJ:!.e C9urt. YOu IIwst attend the scheduled conference or hearing. . . ~:~'"~",, " OiM""'lli',- ROVENi\ MARIE BRill!, Plaintiff : In the Court of Common Pleas : of Cumberland County, : PENNSYL VANIA v. : Civil i\ction - Law JOHN MATTHEW PARR, Defendant : No. C2 006 .... 36S8 . : PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: JOHN MATTHEW PARR Defendant's Date of Birth is: June 29, 1967 Name(s) of All protected persons, including Plaintiff and minor children: 1. ROVENA MARIE BRIDI AND NOW, on 16th Day of June, 2000 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: Plaintift"s request for a temporary protection order is granted. 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. 2. Except for such contact with the minor childJren as may be permitted under paragraph 4 of this Order, Defendant is prohibited from having ANY CONTACT with Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at Plaintifl's school, business, or place of employment. Defendant is specifically ordered to stay away from the following locations for the duration of this order. ,- Plaintiff's residence located at: 508 Enola Road, Enola, P A Plaintiff's place of employment located at: Dots Inc., 6520 Carlisle Pike, Mechanicsburg, P A 3. Except for such contact with the minor childlren as may be pennitted under paragraph 40f this Order, Defendant shall not contact Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 4. Pending the outcome of the final hearing in this matter, Plaintiff is awarded temporary custody of the following minor childlren: 1. HANNAH NICHOLE PARR Until the final hearing, all contact between Defendant and the childlren shall be limited to the following: Defendant shall continue to have periods of partial custody as set out in the parties' informal custody agreement as foDows: Defendant shall have the minor child each Thursday from 10:00 a.m. until 6:00 p.m., every other Saturday from 9:00a.m. until 6:00 p.m., and on alternating weekends from Saturday at 9:00 a.m. until Sunday at 7~OO p.m. The parties' agreement also includes a holiday schedule. Defendant may contact Plaintift' for the limited purpose of communicating custody arrangements. The loca11aw enforcement agency in the jurisdiction where the child/ren are located shall ensure that the child/ren are placed in the care and control of the Plaintiff in accordance with the terms of this Order. 5. The following additional relief is granted: The Cumberland Couaty Sberift"s Department sbaII attempt to make service at Plaintiff's request and without pre-payment of fees, but service may be accomplished under any applicable RUle of Civil Procedure. This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service. The Prothonotary shall not send a copy of this Order to Defendant by mail. - "~ -,' '~._"~,, This Order shall remain in effect until modified or 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 Plaiutiff. Defendant is enjoined from damaging or destroying any property owned solely by Plaintiff. Defendant is ordered to pay $250.00 to reimburse one of Legal Services, Ioc.'s funding sources toward the cost of litigation in this case. 6.1\ certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: EAST PENNSBORO TOWNSHIP POLICE DEPARTMENT: Plaintiff's residence SILVER SPRINGS TOWNSHIP POLICE DEPARTMENT: Plaintiff's place of employment SWATARA TOWNSHIP POLICE DEPARTMENT(Dauphin County): Defendant's residence for transfer of custody 7. 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. 8. THIS ORDER SUPERSEDES ANY PRIOR PFA ORDER ANY PRIOR ORDER RELATING TO CHILD CUSTODY 9. Tins ORDER APPLIES IMMEDLATEL Y TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL DECEMBER 16, 2001 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT ".....,'~ - !Ill,~' Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months injail. 23 Pa.C.S. ~6114. Consent of the P\aintifftQ Defendant's return to the residence shall not invalidate this Order, which can only be changed or modified through the:filing ofappropriate 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 charges and penalties under the Violence 1\gainst Women 1\ct, 18 U.S.C. ~~2261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiff's residence OR any location where a violation of this order occurs OR where the defendant may be located. If defendant violates Paragraphs I through 4 of this Order, defendant shall be arrested on the charge of Indirect Criminal Contempt. i\n arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence oflaw enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriff's office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this court, unless the weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. Judge Date Distribution to: LEGAL SERVICES, INC. Joan Carey, 1\ttomey for Plaintiff Faxed & Mailed to PSP 6/1P .ot) bit>. tJl ", -~, ,><, cc ., CO ,JU~l 'G (:": 3: ~;3 .....1 t>.':":'- _, ,I,: ,'-",(".\ It,TI'Y L;1.../iVh..:.~_l '.:--.r~ -, j 1..)~J\.;j" PEN:.~SYL:./i~\N\A . . '= _r",_ ~n ,_" ~~ ~ ~~r/v c{ f'4! ~ s/ ~~ ~~.5. .' .'., , _ i~_~~~~":,,~,')(-~,ijl!l!lJ1I!Ii!!II!llI! <<". ..,." v__~!l"""~"",&~wg;;~ii~Il'!iIjj~~ _ . , _ '_ '~'_' 1!j!I.~1i\I!! 'I ,-- !.I c," ~~ --. . ,~ ~': PF AD Number: NT1097743E ROVENA MARIE BRIDI, Plaintiff : In the Court of Common Pleas : of Cumberland County, : PENNSYL V ANlA v. : Civil 1\ction - Law JOHN Mi\TTIlEW PARR, Defendant : No. ,;2. oeD - 3658' . : PROTECTION FROM i\BUSE PETITION FOR PROTECTION FROM ABUSE 1. Plaintiff's name is: ROVENA MARIE BRIDI 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. ROVENA MARJIE BRIOI 4. Plaintiff's Address is: 508 Enola Road, West Fairview, PA 17025 5. Defendant's Name is: JOHN MAl1".l:l.EW PARR 6. Defendant is believed to live at the following address: 6871 Hnntington Street, Harrisburg, PA 17111 ,--- ',-- 7. Defendant's Date of Birth is: June 29, 1967 8. Defendant's Place of employment is: WeUness Concepts, Lemoyne, Pennsylvania 9. Defendant is an adult. 10. The relationship between the Plaintiff and the Defendant is: Parents of the same children Current or fonner sexual/intimate partner 11. The defendant has been involved in a criminal court action. 12. The defendant is currently on probation / parole. 13. The defendant is currently on County probation / parole. Description: Dauphin County 14. Plaintiff and Defendant are the parents of the following minor childlren: a. HANNAH NICOLE PARR i\ge:2 years Child's address is: 508 Enola Road, West Fairview, PA 17025 15. Plaintiff is seeking an Order of child custody as part of this petition. The following is a list of the children and where they have live for the past 5 years: a. HANNAH NICHOLE PARR For the past 5 years, this child has lived with: PlainitT and her minor son, Austin Joel Yadlosky, at 419 West Shamokin Street, Trevorton, PA, from the child's birth, 4/26/98 to 5/98. PlaintilT, Defendant, and Austin, at 120 Tory Circle, Enola, PA, from 5/98 to 1/99. ,~" .', - ",~- " . -~""'., Plaintiff and Ausllin, at 508 Enola Road, West Fairview, P A, from 1/99 to the present. 16. The following other minor child/fen presently live with Plaintiff: a. AUSTIN JOEL YADLOSKY i\ge: 5 years The P1aintifl's relationship to this child is: mother 17. The facts of the most recent incident of abuse are as follows: On about Sunday, Jnne 04, 2000 location: 6871 Huntington Street, Harrisburg, Dauphin County, Pennsylvania On or about June 4, 2000, Defendant repeatedly kicked, punched, and spat on PJaillltifi'S borrowed vehicle breaking the side mirror off. Defendant shoved PlaintitT into the car, yelled and screamed at her, grabbed her by the arm, dragged her out of the car, and shoved her causing her to fall onto the road. PlaintitTtelephoned 911 for help. The Swatara Township Police charged Defendant with harassment and criminal mischief as a result of this incident. 18. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor child/ren, (including any threats, injuries, or incidents of stalking) are as follows: Since approximately April 2000, Defendant has stalked PlaintitT repeatedly driving by her residence; telephoned her residence and her place of employment several times a day; come to her residence and her place of employment to check up on her; and sent abusive e-mail messages to her. Defendant boasted to Plaintiff that he had someone in State government or law enforcement run license plate checks for him, and ascertained the names, addresses, and other personal information about her friends after seeing their vehicles at her residence. Defendant threatened Plaintiff numerous times that he will never let her go, and threatened to kill himself several times. In or about summer 1999, Defendant punched Plaintiff in the mouth, and slammed her head against the car window. As a result of this incident, PlaintitTsustainedinjuries including, but not limited to, swelling, bruising, and soreness about her head and mouth, and lacerations inside her mouth. Plaintiff sought medical treatment for her injuries at Harrisburg Hospital. Defendant was charged with harassmenlt as a result ofthis incident. During another incident in 011' about summer 1999, Defendant held a hammer to Plaintiff's head, and threatened her saying, "HI can't have you, no one wilL" PJaintitTfeared for her safety. Since approximately November 1998, Defendant bas abused Plaintiff in ways including, but not - <-,- . "" limited to, shoving, grabbing, and pnnching her; harassing and intimidating her; calling her vile names and verbaHy abusing her, and stalking her. 19. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: EAST PENNSBORO TOWNSHIP POLICE DEPARTMENT: Plaintiff's residence SILVER SPRINGS TOWNSHIP POLICE DEPARTMENT: Plaintiff's place of employmelllt SWATARA TOWNSHIP POLICE DEPARTMENT (Dauphin County) Defendant's residence for transfer of custody 20. There is an immediate and present danger of further abuse from the Defendant. 21. FOR THE REASONS SET FORm ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY ORDER. and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLWWING: a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or minor child/cen in any place where Plaintiff may be found. b. i\ward P1aintifftemponny custody of the minor child/ren and place the following restrictions on contact between Defendant and child/ren: Pending further Order after the hearing scheduled in this matter Defendant shaH continue to have periods of partial custody as set out in the parties' informal custody agreement as foDows: Defendant shaH have the minor child each Thursday from 19:00 a.m. until 6:00 p.m., every other Saturday from 9:00 a.m. until 6:00 p.m., and on alternating weekends from Saturday at 9:00 a.m. until Sunday at 7:00 p.m. The parties' agreement also includes a holiday schedule. Defendant may contact Plaintiff for the limited purpose of communicating custody arrangements. c. 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 P1ainti:ff'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 P1aintifl's relatives and P1aintifl'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. e, Order Defendant to pay the costs of this action, including filing and service fees. f Order the following additional relief: not listed above: TheCumberland County Sheriff's Department shall attempt to make service 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 forwarded to the Sheriff for service. The Prothonotary shaH not send a copy of this Order to Defendant by mail. This Order shaH 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 bas committed an act of abuse or has engaged in a pattern or practictthat indicates risk of harm to Plaintiff. Defendant is enjoined from damaging or destroying any property owned solely by PlaintitT. Defendant is ordered to pay 5250.00 to reimburse one of Legal Services, IRe.'s funding sources toward the cost of litigation in this case. g. Grant such other relief as the court deems appropriate. h. Order the police or other law enforcement agency to serve the Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The petitioner will inform the designated authority of any addresses, other than the Defendant's residence where Defendant can be served. , Respectfully submitted, Joan Carey Philip C. Briganti Attorneys for Plaintiff LEGAL SERVICES, INe. 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 Date: 6 j; 6/c; v VERIFICATION , __'e 1> 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: ~I/~/~ ~~- , Iii' oo~. ~~- "'"'-';'-.'11 "-- ,~ , ~ ~i#jJl":!!ll - -""",-'=';';:Hlll!Hl!1,bilH nlf ._ ,__~p _M ., '<c' ,.' :.l.,;!';,'i;;~o.M.i-V'>";," '^. - OM , '111III11'( d,f. I :! '" 0 C') ..-) ~;~;~ C) :-!'( 'T} G'? c_ - , r"'~ 9!. .. , .'f t~ ., 1-;') 0-:; (' (J " . ;::..< ~~l ~- -" ~. ~T; .. .. i:: - .. :":2:' C ") 5> C) ~-,) .. '-.n ~:; i"--, .0:.:" .'_l ~ --, ~:o -< I 0 -< \, <;> <>: t-' ... ~~ ~ "~'~~i 06/16/00 FRI 15:22 FAX 717 240 6573 CliMB CO PROmONOTARY 1i!J001 ********************* ~ .. u* TX REPORT u* ********************* TRANSMISSION OK TX/RX NO CONNECTION TEL CONNECTION ID ST. TIME USAGE T PGS. RESULT 1934 92490779 06/16 15:17 05'04 8 OK -, --.-. 'li I 1ii I I I J & I .. .1..-r.,1!l>r__ . _ s'3.48.and_4b. . Pltnt yOur name and address on the reverse of this Iom1 80 that we can return thts calli to you, . Att8ch this fonn tQ: the front of the mallp1ece. or ~ the baok If space does not . ~;R6IUm Receipt R6quested"on the mallpl~ below the artfcle number. . The Return Rece\pl: wm show to Whom the anlcle was delivered and the date delivered. 3. Article Addressed to: Lower Allen Township, Lower Allen TownShip Zoning Hearing and Lower Allen 'IWp. Comnissio 1993 Hurrmel Ave. CAmp HIll, PA 17011 '_Wl$IIte_1V8111e folfoWlng services (for en extra fee): 1. CI Addressee's AcIdress~J,I,. 2. CI Rsslricted Dellvel)'1, j Coneuft postrneefer for fee.' a miea4 6i6 -J · 'e: .... j :I::.." :z: "'hi li3 Certlfled all ~ :g 0 Insured , for . 0000 i. I, I 1ft4 . , , . :.i-;_'_'_ ROVEN1\ MARIE BRIDI, Plaintiff : IN THE COURT OF COMMON PLE1\S OF : CUMBERLAND COUNTY, PENNSYLVANIA. vs. : NO. 00-3658 CIVIL TERM JOHN Mi\TTHEW PARR, Defendant : PROTECTION FROM i\BUSE OR>>. FOR CONTINUANCE AND NOW, thiVl- day of June, 2000, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on Wednesday, June 21,2000, at 2:30 p.m. by this Court's Order of June 16, 2000, is hereby rescheduled for hearing on July 25,2000, at 3:30 p.m. in Courtroom No.3 on the 4th Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. The Temporary Protection From 1\buse Order shall remainin effect for a period of 18 months from the date it was entered, through December 16, 2001, or until further Order of Court, whichever comes first. f Joan Carey, 1\ttomey for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, P1\ 17013 ~ -4Y)JJ t-J.3 -00 RK5 Bryan S. Walk, 1\ttomey for Defendant 108-112 Walnut Street Harrisburg, P 1\ 171 0 1 . ~:w ~ ~" ,,"-' ~~~I_' nr: '-' 00 JU0: 23 Ff-j 3: nD CUiv:U::.FLr' .j G::::Ui\TY' PENNS"rtVi\r\l/t 1T1II."""'1'~~" ~, ~Ilr , .!I!'[l1M~ , I'''"" .,. ,,~d!lIli5~"1~, ~~ 'f-""~"H~-" -'- ,~, p,J!.' '';,'' ROVEN1\ MARIE BRIDI, Plaintiff : IN THE COURT OF COMMON PLE1\S OF : CUMBERLAND COUNTY, PENNSYLVANIA. vs. : NO. 00-3658 CIVIL TERM JOHN Mi\TTHEW PARR, Derendant : PROTECTION FROM mUSE MOTION FOR CONTINUANCE Plaintiff; Rovena Marie Bridi, by and through her attorney, Joan Carey of Legal Services, Inc., moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. 1\ Temporary Protection From i\buse Order was issued by this Court on June 16, 2000, scheduling a hearing for Wednesday, June 21,2000, at 2:30 p.m. 2. The Cumberland County Sheriff's Department served Defendant with a certified copy of the Temporary Protection From i\buse Order and Petition for Protection From i\buse at his place of employment, Wellness Concepts, Market Street in Lemoyne, Cumberland County, Pennsylvania, on Monday, June 19, 2000, at approximately 4:00 p.m. 3. Defendant has retained Bryan S. Walk, Attorney at Law, to represent him in this matter. 4. The parties agree, by and through their respective counsel, that the hearing be rescheduled to afford them time to negotiate a settlement in this case. 5. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of 18 months from the date it was entered, through December 16, 2001, or until further Order of Court, whichever comes first. ];0' " '-"iiIib; WHEREFORE, P1aintiffrequests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From i\buse Order remain in effect for a period of 18 months from the date it was entered, through December 16, 2001, or until further Order of Court, whichever comes first. Respectfully submitted, Carey, Attorney for P LEGAL SERVICES, 8 Irvine Row Carlisle, P 1\ 17013 (717) 243-9400 !I.iI.~ c-,,__ ~ " ." 1_l:l'i'c;"""~~ ~-c; " :_ ,,- _,{,,;..~ :..l~. l!liil1i~~~iLn1 jl.i~ itfi ~ ~. c. - . '\]1.") : g..~ !.i. ~ ~r.- C=c~ ~fj' ~ "'"' C) " -'....) 1"'-~) _,-c.';~ c_,I) ~;fr;1 -,~ :5.] ", ".. en <\9 '"~ ~ ~ -~~ - STEPHANIE ANN HOFFMAN, TYLER MITCHELL HOFFMAN, and CL1\UDIEA MAl HOFFMAN, Plaintiffs vs. JASON ERIC HOFFMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2000-3659 CIVIL TERM : PROTECTION FROM i\BUSE AND CUSTODY R FOR CONTINUANCE of June, 2000, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on Tuesday, June 20, 2000, at 3:00 p.m. by this Court's Order of June 16, 2000, is hereby rescheduled for hearing on Tuesday, July 25, 2000, at 3:00 p.m. in Courtroom NO.3 of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. The Temporary Protection From i\buse Order shall remain in effect for a period ofl8 months from the date it was entered, through December 16, 2001, or until further Order of Court, whichever comes first. By the Court, orge E. Hoffer, Pr sident Judg~ L~~O {,' ~~?J Joan Carey, 1\ttomey for Plaintiff LEGAL SERVICES, INe. 8 Irvine Row Carlisle, P1\ 17013 " '-0- ".~,rll'.IIl!Il'J!l~ qn jl(~Ji)q !-J~i .J_': J ,:(. U CO,", Ie (~-h w: :. CUM6~F-iL,Lj\'::) CC:UNT"/ PEf\jl'~SYL\~'~l-~r!~ .1" ',~_", J! ~~=,=__"J!I_" :<"'~,~~-~~, 'l" ... '""".,~- ~~ ~~ ,r ~_@J~ ," \d - STEPHANIE ANN HOFFMAN, TYLER MITCHELL HOFFMAN, and CL1\UDIEA MM HOFFMAN, Plaintiffs vs. JASON ERIC HOFFMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLV ANlA : NO. 2000-3659 CIVIL TERM : PROTECTION FROM ABUSE AND CUSTODY MOTION FORCONTfflUANCE Plaintiff, Stephanie Ann Hoffinan, by and through her attorney, Joan Carey of Legal Services, Inc., moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. 1\ Petition for Protection From Abuse was filed and a Temporary Protection From Abuse Order was entered by this Court on June 16, 2000, scheduling a hearing for June 20, 2000, at 3:00 p.m. 2. The Cumberland County Sheriffs Department was unable to locate Defendant to serve him with a certified copy of the Temporary Protection From Abuse Order and Petition for Protection From Abuse. 3. Plaintiff requests that the hearing be rescheduled to facilitate service of Defendant. 4. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of 18 months from the date it was entered, through December 16, 2001, or until further Order of Court, whichever comes first. WHEREFORE, P1aintiffrequests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in effect for a period of -~ ~~ <,-;,;". - "",l,..~ ,~""'- ' 18 months from the date it was entered, through December 16, 2001, or until further Order of Court, whichever comes first. Respectfully submitted, ~~ LEGAL SERVICES, INC. 8 Irvine Row Carlisle, P 1\ 17013 (717) 243-9400 <-, lSJMi - ,. ~"~~ .~~-~ ~.. '-". -~12- OCil~ ~~~~ia-_d-' '~. .'- .. lL. ..... ~-ii' l1~ 0 C",) () c:: c:> "f~ 3': .-' "'D c iT! L< -:;7 ~. e-. j',,") .-;... (0 ,0 ',-," -< c::.: -:~ ... , ~~ ' . (J )> ~~.;-- . ~ ..,..;.. __.n O::''J -'J ~ (:) ::<: ~~ 1.: 1..1 .1 I I' ,;1 'I :1 iJ " "w ~ ""'llL.,- SHERIFF'S RETURN - REGULAR CASE NO: 2000-03658 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BRIDI ROVENA MARIE VS PARR JOHN MATTHEW HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County, pensylvania, who being duly sworn according to law, says, the within NOTICE & HEARING & ORDER, was served upon PARR JOHN MATTHEW the DEFENDANT , at 0014:34 HOURS, on the 19th day of June , 2000 ~t POE: WELLNESS CONCEPTS 1007 MARKET ST LEMOYNE, PA 17043 by h~nding to JOHN MATTHEW PARR ~ true and attested copy of NOTICE & HEARING & ORDER, together with PROTECTION FROM ABUSE, TEMPORARY PROTECTION FROM ABUSE ORDER, PETITION ~nd at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.92 .00 10.00 .00 37.92 So Answers: ~~ r~#'~-r~l R. Thomas Kline 06/21/2000 Sworn and. Subscribed to before By: 7vL4I V~Tf? / Deputy Sheri me this 7 ~ day of 1)0:;. ... A.D. tZ ~l#' Prothonotary. "'- ~ . " ROVEN1\ MARIE BRIDI, Plaintiff : In the Court of Common Pleas : of Cumberland County, : PENNSYL V ANLA v. : Civil 1\ction - Law JOHN MATTHEW PARR, Defendant : No. 00-3658 . : PROTECTION FROM ABUSE FINAL ORDER OF COURT Defendant's N~ is: JOHN MAl BlEW PARR Defendant's Date of Birth is: June 29, 1967 Name(s) of All protected persons, including Plaintiff and minor children: I. ROi'AMA~~ AND NOW, thi:lt Dayof~ ~. the court having jurisdiction over ~€lS and the subject- cr, it is ORDERED, ADJUDGED and DECREED as f..~':." Pursuant to consent of the parties, which does not constitute Defendant's admission to the averments of abuse in the petition. The following order will be entered: Plaintiff's 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 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 Plaintifl's school, business, or place of emp1oyement. Defendant is specifically ordered to stay away from the following locations for the duration of this order. . , '<-, - "'- Plaintiff's residence located at: 508 Enola Road, Enola, P A Plaintiff's place of employment located at: Dots Inc., 6520 'Carlisle Pike, Mechanicsburg, P A Defendant may have telephone contact with Plaintiff at her residence or at her place of employment for the limited purpose of facilitating custody arrangements. 3. 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. 4. The following additional relief is granted as authorized by ~6108 of the 1\ct: This Order shaD 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 pattem or practice that indicates risk of harm to Plaintiff. Defendant is enjoined from damaging or destroying any property owned solely by Plaintiff. The court costs and fees are waived. 5. 1\ certified copy of this Order shal1 be provided to the police department where Plaintiff resides and any other agency specified hereafter: EAST PENNSBORO TOWNSHIP POLICE DEPARTMENT: Plaintiff's residence SILVER SPRINGS TOWNSHIP POLICE DEPARTMENT: Plaintiff's place of employment SW ATARA TOWNSHIP POLICE DEPARTMENT(Dauphin County): Defendant's residence for transfer of custody 6. TIllS ORDER SUPERSEDES: 1. ANYPRIORPFAORDER j --- , . .~~~. ~ -""~,,'- ~ 7. All provisions of this order shall expire on: December 21,2001 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 1\ND/OR 1\ JAIL SENTENCE OF UP TO SIX MONTHS. 23 PAC.S. ~6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION 1\ND CRIMINAL PENAL TIES UNDER THE PENNSYL VANIA. CRIMES CODE. THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) ST1\TES, THE DISTRICT OF COLUMBIA, TRIBAL L1\NDS, U.S. TERRITORIES 1\ND THE COMMONWEALm OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. ~2265. IF YOU TRAVEL OUTSIDE OF THE ST1\TE AND INTENTIONALLY VIOLATE TIllS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C ~~2261- 2262. IF THE BRADY INDIC1\TOR Pi\RAGRAPH APPEi\RS IN THE ORDER, YOUMA Y 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 plaintift's 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 3 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 Sheriff's 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. .. .~. ~_._ l ~,. . Judge ~ .~ ~;::~~t of plaintiff 'ntift's Signatur . :rrearey Distribution to: Attorney for Joan Carey, Mtorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 Bryan S. Walk, Mtorney for Defendant 108-112 Walnut Street Harrisburg, P 1\ 17101 FAXed and mailed to PSP Defendant - '~""~-~~~~~~Qlill>~iiMf.M"'''l!'., -~"':";;d"l_11iJ -" FLaol I'''' Pro-Mol\Ottlrr ofhJJ JiAi>' ;J..? &-CXXJ uu 1!.II1i'.I'~..IC<d~W!:iilllll~.wIli!l1 ~ -~ .- . .07.128/00 FRI 08:35 FAX 717 240 6573 CliMB CO PROTHONOTARY 141001 TRANSMISSION OK TX/RX NO CONNECTION TEL CONNECTION In ST. TIME USAGE T PGS. RESULT . .-< ********************* *** TX REPORT *** ********$************ 2032 92490779 07/28 08:31 04'23 8 OK