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P ATRlCK HENRI LHERlSSON,
Plaintiff
: In the Court of Common Pleas of
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: CUMBERLAND County,
: PENNSYL VANIA
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: Civil Action - Law
: No. 00-4441
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DIANE BETH LHERlSSON,
Defendant
: PROTECTION FROM ABUSE
ORDER TO VACATE
AND NOW, this: 30th Day of August, 2000, upon Plaintift's motion to withdraw or
discontinue this action,
1. This matter is dismissed without prejudice.
2. Costs of this proceeding are waived.
3. The Final Order (Filed on Jnl13, 2000) is hereby vacated.
The Order of Court entered on August 2~ 2000, in the above-captioned case
which modified the Final Order filed on July 13, 2000, is hereby vacated and
the action withdrawn.
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Distribution to:
Joan Carey, Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17103
Karl E. Rominger, Attorney for Defendant
ROMINGER LAW OFFICES
155 South Hanover Street
Carlisle, PA 17013
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P ArRICK LHERISSON,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 00-4441 CIVIL TERM
DIANE LHERISSON,
Defendant
: PROTECTION FROM ABUSE
PETITION TO VACATE ORDER
AND WITHDRAW ACTION
Plaintiff, Patrick Lherisson, by and through his attorney, Joan Carey ofLegal Services, Inc.,
requests that the Court vacate the Order of Court entered on August 2],2000, in the above-captioned
case and that the action be withdrawn on the grounds that:
1. A Final Order of Court in the above-captioned case was entered on July 6, 2000, by
consent of the parties, by and through their respective attorneys.
2. On August 22, 2000, Plaintiffpetitioned the Court to modifY the Final Order of Court
and an Order was entered on August ~, 2000, vacating the portion of the Order which evicted and
excluded Defendant from the marital residence.
3. Plaintiff is planning on returning to his home in France in the near future, and desires
that the Order entered on August 2,3, 2000, be vacated and the action withdrawn without prejudice
to him.
WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate the
Order, and that the action be withdrawn without prejudice to Plaintiff.
Respectfully submitted,
~ey,~rPlaintiff
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VERIFICATION
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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:
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2138
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Patrick Henri Lherisson
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
Plaintiff
v.
: No. 00-4441
Diane Beth Lherisson
Defendant
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
FINAL ORDER OF COURT
Defendant's Name is: Diane Beth Lherisson
Defendant's Date of Birth is: June 21,1960
Name(s) of All protected persons, including Plaintiff and minor children:
I. Patrick Henri Lherisson
Appearances by Parties and/or Counsel:
. Plaintiff appeared personally and is represented by: Joan
Carey, Legal Services, Inc.
. Defendant appeared personally and is represented by: Karl
Rominger, Rominger Law Offices
AND NOW, this 6th Day of July, 2000 the court having jurisdiction over the parties
and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows:
c
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.
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2. Defendant is completely evicted and excluded from the residence at:
352 North Middlesex Road, Carlisle, Pennsylvania.
(See paragraph 8 for limited exception as to premises.)
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. Except as provided in Paragraph 5 of this Order, 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 ofthis order.
Any place of employment Plaintiff may establish in the future.
4. Except as provided in Paragraph 5 of this Order, 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. Custody of the following minor children:
I. Jessica Andree Lherisson
2. Alexandre Pierre Lherisson
shall be as follows:
. Primary physical custody of the minor child/ren is awarded
to the Plaintiff.
. Plaintiff shall have primary physical custody of the children
and the parties shall have shared legal custody of the
children. Defendant shall have periods of partial custody at
dates and times agreed upon by the parties. Any issues
regarding the children may be addressed through phone
contact between Plaintiff and Defendant.
6. The following additional relief is granted as authorized by S6108 of the Act:
- Defendant is ordered to pay the costs of this action, including fIling fees,
service fees and surcharge of $25.00.
- Defendant is ordered to pay $250.00 to reimburse one of Legal Services Inc.'s
funding sources for the cost of litigation in this case.
- Defendant shall not harass Plaintiffs relatives.
- Defendant shall not damage or destroy any property owned jointly by
the parties or solely by Plaintiff.
- The following exception to paragraph 2 above is ordered:
-Defendant may use the portion ofthe premesis where the barn and riding
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circle are located. (The court suggests that while defendant co-"ducts any .
boarding, training, and teaching activities in these designated areas, Plaintiff
will give her ample room to do so.)
-Defendant shall stay at least 50 yards from the main house, summer house,
and gazebo area.
-Defendant shall stay in the barn or at least twenty feet from the driveway and
upper parking area if Plaintiff is in those areas.
-Defendant shall park her vehicle in the pull-off area of the driveway below
the barn. Defendant can pass through the main upper parking area on her
way to the training circle for pnrposes of training horses, but she shall not
stand or loiter in that parking area.
7. THIS ORDER SUPERSEDES:
I. ANY PRIOR PF A ORDER
2. ANY PRIOR ORDER RELATING TO CHILD CUSTODY
8. All provisions of this order shall expire on: December 6, 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. g6114. VIOLATION MAY ALSO SUBJECT YOU TO
PROSECUTION AND CRIMINAL PENAL TIES UNDER THE PENNSYL VANIA
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. g2265. IF YOU TRAVEL OUTSIDE OF THE STATE
AND lNTENTIONALL Y VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO
FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C gg2261-
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.
g922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR
AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
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, shall enforce
this order. An arrest for violation of Paragraphs I through 5 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. g6113.
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 shall maintain possession of the weapons until further order of this Court.
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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. Plaintiff's 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.
----,
If entered pursuant to the consent of plaintiff and defendant:
. . . PlaintiffS -SignatUre
---m-----ITeIendant's Signature
Distribution to: . to L S
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1988
92490779
07/13 11:32
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Patrick Lherisson,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
NO. 00-4441 CIVIL TERM
Diane Lherisson,
Defendant
PROTECTION FROM ABUSE
) ~ ORDER
AND NOW, thit- day of August 2000, upon consideration of the within Petition and
agreement of the parties the following Order is entered:
1. The portion of the Protection Order, dated July 6, 2000, which evicts and excludes
the defendant, Diane Lherisson, from the residence located at 352 North Middlesex Road, Carlisle,
is suspended for the period of time that Plaintiff is out of the country.
2. Plaintiff will give Defendant notice of the date and time he plans to leave the
residence and Defendant may enter the residence two (2) hours thereafter. Plaintiff will give
Defendant at least one week notice of the day he plans to return to the residence, and Defendant shall
vacate the residence at least two (2) hours prior to his planned return date and time.
3. In all other respects the Protection Order entered November 10, 1999, remains in
effect.
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This Order is entered pursuant to an agreement of Plaintiff and Defendant:
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Diane Lherisson, Defeandant
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J an Carey, Attorney for
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
Karl Rominger, Attorney for Defendant
Law Offices of Karl Rominger
155 South Hanover Street
Carlisle, P A 17013
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Patrick Lherisson,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: NO. 00-4441 CIVIL TERM
Diane Lherisson,
Defendant
: PROTECTION FROM ABUSE
Petition for Modification of Protection From Abuse Order
The plaintiff, Patrick Lherisson, by and through his counsel Joan Carey of Legal Services,
Inc., that the following:
I. A Protection From Abuse Order was entered on July 6, 2000, after a hearing.
2. Plaintiff is going to his home ,"ountry of France for an indefinite period oftime for
personal reasons.
3. Plaintiff requests that the portion of the Protection From Abuse which evicted and
excluded Defendant from the residence located at 352 North Middlesex Road, Carlisle, be suspended
so that Defendant maybe at the residence and caring for the children during the period of time that
he is out of the country.
4. Plaintiff will give Defendant notice of the date and time he plans to leave the
residence and Defendant may enter the residence 2 hours thereafter. Plaintiff will give Defendant
at least one week notice of the day he plans to return to the residence, and Defendant shall vacate
the residence at least 2 hours prior to his planned return time.
.
,,,,",, .-
WHEREFORE, Plaintiff requests that the Protection Order of July 6, 2000, be modified to
reflect the above terms and that all other terms of the Order remain in effect.
Carey, Attorney for
Legal Services, Inc.
8 Irvine Row
Carlisle, P A 17013
VERIFICATION
Dated:
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2094
92490779
08/24 07:47
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PATRICK HENRI LHERISSON,
Plaintiff
: In the Court of Common Pleas of
: CUMBERLAND County,
: PENNSYL VANIA
v.
: Civil Action - Law
: No. 00-4441
Diane Beth Lherisson,
Defendant
: PROTECTION FROM ABUSE
MODIFIED FINAL ORDER OF COURT
Defendant's Name is: Diane Beth Lherisson
Defendant's Date of Birth is: Jnne 21, 1960
Name(s) of All protected persons, including Plaintiff and minor children:
1. Patrick Henri Lherisson
AND NOW, this 23rd Day of Angust, 2000 the court having jurisdiction
over the parties and the subject-matter, it is ORDERED, ADJUDGED and
DECREED as follows:
I. The portion of the Protection Order dated July 6, 2000 (filed July 13,
2000), which evicts and excludes Defendant, Diane Lherisson, from the
residence located at 352 North Middlesex Road, Carlisle, is suspended for
the period oftime that Plaintiff is out of the country.
2. Plaintiff will give Defendant notice of the date and time he plans to leave
the residence and Defendant may enter the residence two (2) hours
thereafter. Plaintiffwill give Defendant at least one (1) week notice of the
day he plans to return to the residence, and Defendant shall vacate the
residence at least two (2) hours prior to his planned return date and time.
3. In all other respects the Protection Order dated July 6, 2000, remains in
effect.
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1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any
other protected person in any place where they might be found.
2. Derendant is completely evicted and excluded from the residence at:
352 North Middlesex Road, Carlisle, Pennsylvania.
(See above modification, and paragraph 8 for limited exception as
to premises.)
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. Except as provided in Paragraph 5 of this Order, Defendant is prohibited
from having ANY CONTACT with the PlllintiH: 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 employement.
Defendant is specifically ordered to stay away from the following
locations for the duration of this order.
Any place of employment Plaintiff may establish in the future.
4. Except as provided in Paragraph 5 of this Order, 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. Custody of the following minor children:
1. Jessica Andree Lherisson
2. Alexandre Pierre Lherisson
shall be as follows:
. Primary physical custody of the minor child/ren is
awarded to the Plaintiff.
. Plaintiff shall have primary physical custody .of
the children and the parties shaH have shared
legal custody of the children. Defendant shall
have periods of partial custody at dates and times
agreed upon by the parties. Any issues regarding
the children may be addressed through phone
I t-__,
contact between Plaintiff and Defendant.
6. The following additional relief is granted as authorized by ~61 08 of the
Act:
Defendant is ordered to pay the costs ofthis action, including rding
fees, service fees and surcharge of $25.00.
Defendant is ordered to pay $250.00 to reimburse one of Legal
Services IDco's funding sources for the cost ofIitigation in this case.
Defendant shall not harass Plaintiff's relatives.
Defendant shall not damage or destroy any property owned jointly
by
the parties or solely by Plaintiff.
The following exception to paragraph 2 above is ordered:
Defendant may use the portion of the premesis where the barn and
riding circle are located. (The court suggests that while Defendant
conducts any boarding, training, and teaching activities in these
designated areas, Plaintiff will give her ample room to do so.)
Defendant shall stay at least 50 yards from the main house, summer
house, and gazebo area.
Defendant shall stay in the barn or at least 20 feet from the
driveway and upper parking area if Plaintiff is in those areas.
Defendant shall park her vehicle in the puB-off area of the
driveway below the barn. Defendant can pass through the main
upper parking area on her way to the training circle for purposes of
training horses, but she shall not stand or loiter in that parking
area.
7. THIS ORDER SUPERSEDES:
1. ANY PRIOR PF A ORDER
2. ANY PRIOR ORDER RELATING TO CHILD
CUSTODY
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8. All provisions of this order shall expire on: December 6, 2001
NOTICE TO THE DEFENDANT
VIOLATION OF TIllS ORDER MAY RESULT IN YOUR ARREST
ON THE CHARGE OF INDlRECT CRIMINAL CONTEMPT WHICH
IS PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL
SENTENCE OF UP TO SIXMONTHS. 23 PA.C.S. ~6114.
VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND
CRIMINAL PENALTIES UNDER TIlE PENNSYLVANIA CRIMES
CODE.
TIllS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE
DISTRICT OF COLUMBIA, TRIBAL LANDS, US. TERRITORIES
AND TIlE COMMONWEALTH OF PUERTO RICO UNDER TIlE
VIOLENCE AGAINST WOMEN ACT, 18 US.C. ~2265. IF YOU
TRAVEL OUTSIDE OF TIlE STATE AND lNTENTIONALL Y
VIOLATE TIllS ORDER, YOU MAY BE SUBJECT TO FEDERAL
CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 US.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, sha1l enforce this order. An arrest for violation of
Paragraphs 1 through 5 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 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. Plaintiff's presence and signature are not required to file the
complaint.
" ' I.., I ", - ,"," " ~,_
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.
BY TIIE COURT:
George E. Hoffer, President
Judge
Date
If entered pursuant to the consent of plaintiff and defendant:
Plaintifi's Signature
Defendant's Signature
Distribution to:
Joan Carey, Attorney for Plaintiff
Legal Services
Karl E. Rominger, Attorney for Defendant
Faxed & Mailed to PSP
~
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Patrick Lherisson,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: NO. 00- 'I 'IV J
CIVIL TERM
Diane Lherisson,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. rfyou 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 {],Il J..uJ.1 ~
'3 : 3 () p.M., IN COURTROOM NO. 3 OrTIJt CUMBERLAND
COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA.
You MUST obey the Order that is attached until it is modified or terminated by the court
after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this
Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up
to $1,000.00 and/or up to six months injail under 23 Pa.C.S. {l61 14. Violation may also subject you
to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18
U.S.C. {l2265, 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. {l2261-2262.
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 fmd 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.
Patrick Henri Lherisson
: In the Court of Common Pleas
: County, Pennsylvania
Plaintiff
v.
:No. D-o-L/'1'1J
Diane Beth Lherisson
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
Defendant
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: Diane Beth Lherisson
Defendant's Date of Birth is: June 21,1960
Name(s) of All protected persons, including Plaintiff and minor children:
I. Patrick Henri Lherisson
AND NOW, on 27th Day of June, 2000 upon consideration of the attached Petition
for Protection from Abuse, the court hereby enters the following Temporary Order:
j
Plaintiff's request for a temporary protection order is granted.
1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in
any place where they might be found.
2. Defendant shall be evicted and excluded from the residence at:
352 North Middlesex Road, Carlisle, Pennsylvania.
3. Except for such contact with the minor child/ren as may be permitted under
paragraph 5 of this Order, Defendant is prohibited from having ANY CONTACT
with Plaintiff, or any other person protected under this Order, at any location,
including but not limited to any contact at Plaintiff's school, business, or place of
employment. Defendant is specifically ordered to stay away from the following
locations for the duration of this order.
Any place of employment Plaintiff may establish in the future.
4. Except for such contact with the minor child/ren as may be permitted under
paragraph 5 of this Order, Defendant shall not contact Plaintiff, or any other
person protected under this Order, by telephone or by any other means, including
through third persons.
5. Pending the outco~e of the final hearing in this matter, Plaintiff is awarded
temporary custody of the following minor child/ren:
I. Jessica Andree Lherisson
2. Alexandre Pierre Lherisson
Until the final hearing, all contact between Defendant and the child/ren shall be
limited to the following:
Plaintiff shall have primary physical custody of the children and the parties
shall have shared legal custody of the children. Defendant shall have periods
of partial custody at dates and times agreed upon by the parties.
The local law enforcement agency in the jurisdiction where the child/ren are
located shall ensure that the child/ren are placed in the care and control of the
Plaintiff in accordance with the terms of this Order.
6. The following additional relief is granted:
- Defendant shall return to the Plaintiffs residence the 1986 or 1989 white,
Volvo 740 with the keys.
- Defendant shall have the horses which remain on the property removed.
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 APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL DECEMBER 27, 2001 OR UNTIL
OTHERWISE MODIFIED OR TERMINATED BY THIS COURT AFTER
NOTICE AND HEARING.
NOTICE TO THE DEFENDANT
Defendant is hereby notified that violation of this Order may result in arrest for
indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or
up to six months in jail. 23 Pa.C.S. 96114. Consent of the Plaintiff to Defendant's
return to the residence shall not invalidate this Order, which can only be changed or
modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S.
96113. Defendant is further notified that violation 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 Against Women Act, 18 U.S.C. 992261-
2262.
NOTICE TO LAW ENFORCEMENT OFFICIALS
,~
",'
This Order shall be enforced by the police who have jurisdiction over the plaintiffs
residence OR any location where a violation of this order occurs OR where the
defendant may be located. If defendant violates Paragraphs I through 5 of this
Order, defendant shall be arrested on the charge ofIndirect Criminal Contempt. An
arrest for violation 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 Sheriffs office of the county
which issued this Order, which office shall maintain possession of the weapons until
further Order of this court, unless the weapon/s are evidence of a crime, in which
case, they shall remain with the law enforcement agency whose officer made the
arrest.
e. Tuoge
Date
Distribution to:
Legal Services
Faxed & Mailed to PSP
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PFAD Number: JAl103882L
Patrick Henri Lherisson
: In the Court of Common Pleas
: County, Pennsylvania
Plaintiff
v,
: No. ffo. </'1'11 C,u:';';'oR.-v-
Diane Beth Lherisson
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
Defendant
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiffs name is:
Patrick Henri Lherisson
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. Patrick Henri Lherisson
4. Plaintiffs Address is: 352 N. Middlesex Rd., Carlisle, PA 17013
5. Defendant's Name is:
Diane Beth Lherisson
6. Defendant is believed to live at the following address:
with: Robert & Sherry Fisher, Shermans Dale, P A 17090
7. Defendant's Date of Birth is:
June 21, 1960
8. Defendant's Place of employment is:
unemployed
"^ =
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9. Defendant is an adult.
10. The relationship between the Plaintiff and the Defendant is:
Spouse
Parents of the same children
11. The defendant has been involved in a criminal court action.
12. Plaintiff and Defendant are the parents ofthe following minor child/ren:
a. Jessica Andree Lherisson
Age:16
Child's address is: 352 N. Middelsex Rd, Carlisle, PA 17013
b. Alexandre Pierre Lherisson
Age:l0
Child's address is: 352 N. Middelsex Rd, Carlisle, PA 17013
13. 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. Jessica Andree Lherisson
For the past 5 years, this child has lived with:
The child lived with Plaintiff and Defendant for the past 11 years at 352 N.
Middlesex Rd., Carlisle, P A 17013. The child currently resides at the above
address with the Plaintiff.
b. Alexandre Pierre Lherisson
For the past 5 years, this child has lived with:
The child lived with Plaintiff and Defendant for the past 10 years at 352 N.
Middlesex Rd., Carlisle, P A 17013. The child currently resides at the above
address with the Plaintiff.
14. The facts of the most recent incident of abuse are as follows:
On or about June 18, 2000, Defendant verbally abused Plaintiff and threatened to destroy his
equipment in his recording studio. Defendant became angry, approached Plaintiff and hit him
about the body with her fists, causing brusises on his arms. Plaintiff, who was sitting on a chair,
fell backwards and hit the lower spine of his back on a power strip across the floor, screamed in
pain and experienced loss of feeling and movement in his legs. After briefly leaving the room,
Defendant returned, approached Plaintiff again and attempted to hit him, but the children
prevented her from doing so by pushing her away. Plaintiff was brought to the hospital where he
was treated for injuries including broken ribs and a torn muscle in his back. The police arrested
Defendant and charged her with simple assault. A hearing is scheduled for 6/28/00.
15. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor child/ren,
(including any threats, injuries, or incidents of stalking) are as follows:
']-. ,<
On or about June 17, 2000, Defendant charged into the bathroom, hit Plaintiff with her fists,
grabbed him around the throat, and shook his head back and forth. Defendant left the room,
returned with a belt, and threatened to hit Plaintiff with it. When Plaintiff left the room,
Defendant picked up a bag of food, threw it at Plaintiff, and hit him with her fists.
On or about May 19,2000, Defendant followed Plaintiff up the stairs, lunged at him from behind
and hit him with her fists, causing him to fall forward on to the stairs.
Since approximately 1990, Defendant has abused Plaintiff in ways including, but not limited to,
the following: choking, pulling his hair, punching him with her fists, slapping and kicking him.
On seperate occasions, Defendant has kicked Plaintiff in the groin, and has threatened to bash
his head in and take the children from him. Plaintiff has suffered bruises, scrapes, pulled
muscles and broken ribs. Defendant has punched Plaintiff's friend in the face and has had
physical altercations with Plaintiffs mother. Plaintiff seeks protection so that he and his
children can live in peace and without fear. Defendant has been arrrested and charged with
simple assault.
16. The police department(s) or law enforcement agencies that should be provided with a copy of the
protection order are:
Middlesex Police Dept
17. There is an immediate and present danger of further abuse from the Defendant.
18. Plaintiff is asking the court to evict and exclude the Defendant from the following residence:
352 N. Middlesex Rd.
Carlisle, PA 17013
Rented By:Patrick and Diane Lherisson
19. 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. A ward Plaintiff temporary custody of the minor child/ren and place the following
restrictions on contact between Defendant and child/ren:
Plaintiff shall have primary physical custody of the children and the parties
shall have shared legal custody of the childre. Defendant shall have periods of
partial custody at dates and times agreed upon by the parties.
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 Plaintiff's 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.
~ .
f. Order Detfmdant to pay the costs ofthis action, including tiling and service tees.
g. Order the following additional relief, not listed above:
- Defendant shall not harass Plaintiffs relatives;
- Defendant shall not damage or destroy any property owned
jointly by the parties or solely by Plaintiff.
- Defendant shall pay $250.00 to reimburse one of Legal Services, Inc.'s
funding sources for the cost of litigation in this case.
h. Grant such other relief as the court deems appropriate.
1. Order the police or other law enforcement agency to serve the Defendant with a
copy of this Petition, any Order issued, and the Order for Hearing. The petitioner
will inform the designated authority of any addresses, other than the Defendant's
residence, where Defendant can be served.
Respectfully Submitted by:
Agency:
t.k~,.
Maryann MMphy
Legal Services, Inc.
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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:
( /~ rjoo
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1963
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-04441 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
LHERISSON PATRICK
VS
LHERISSON DIANE
WILLIAM DIEHL
, Sheriff or Deputy Sheriff of
Cumberland County, Pensyl vania , who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE
was served upon
LHERISSON DIANE
the
DEFENDANT
, at 0855:00 HOURS, on the 28th day of June
, 2000
at DJ DAY'S OFFICE
MT HOLLY SPRINGS, PA 17065
by handing to
DIANE LHERISSON
a true and attested copy of PROTECTION FROM ABUSE
together with
NOTICE OF HEARING AND ORDER, TEMPORARY PROTECTION
FROM ABUSE ORDER
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
3.72
.00
10.00
.00
31.72
So Answers:
._.~~J
R. Thomas Gne
00/00/0000
Sworn and Subscribed to before
By:
P~~i~
me this J.& tt::. day of
~ ,2bVzJ A.D.
~ 0. lu.df~..J,l~
r thonotary r-j
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I'f\ Carlisle Hospital and
~, Health Services.,
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF Cumberland
)
)
)
SS:
CER?fICATION OF RECORDS
Name of Patient 1J,1r~/r Ii IJ. LAtA /~J'O)
Medical Record Number (s) j) /l3~g 1 /
N~b~ of ""'~ io tho """i~l reoooI ~ f)J k, r
I
The copies of the record for which this certification is made are true and complete
reproductions of the original or microfilmed medical records which are housed in Carlisle
Hospital. The original records were made in the regular course of business at or near the
time of the matter recorded. This certification is given pursuant to 42 Pa. C.S. Chapter 61
Sub-Chapter E (relating to medical records) by the custodian of the records in lieu of his/her
personal appearance.
Y ; /f .
I~I"~
Linda Banks, RN, CPHQ
Director
Health Information & Strategic Qualily Management
~I
246 Porker Itreet. PO. Box 310 . Carlisi., PA 17013-0310 . 717-245-51!O
"
~ Carlisle Hospital
"
Meo. REC. NO.
AEO.DATE/TIME
813341
06/18/00 21:25
PREVIOUS NAME
NONE
NAME I ADDRESS { PHONE I AGE I sex I RACE I M.S.
LHERISSON, PATRICK H.
352 N MIDDLESEX RD
/
CONVENIENT CARE/EMERGENCY REGISTRATION
FC
- b
42V M W M
05/19/58
190-58-0050
PATIENT ! OTHER EMPLOYER
KEVSTONE FORD
CARLISLE, PA 17013
NAME II\OORESS I PHONE' RELATION I O.O.B./ saC.SEC.NO. ( 7 1 7 ) 2 5 8 9 6 8 5
LHERISSON, PATRICK H.
352 N MIDDLESEX RD
CARLISLE, PA
NAME / "'CDRESS I PHONE I RELATION { soc-seC-NO.
HE LTH ASSURANCE
190580050
LHERISSON, PATRICK H.
INSURANCE COMMENT
REASON FOR VISIT
PAIN MID BACK FELL
COMMf:NT
EF VISIT 26700
\SS I VISIT 26710
\SS II VISIT 26720
\SS III VISIT 26730
\SS IV VISIT 26740
\SS V VISIT 26750
JaR SUTURE EDSOl
DIUM SUTURE EDS 02
JaR SUTURE ED5 03
UBATION EDS 04
;ETUP EDS 06
_VIC EXAM EDS 14
RO SET-UP EDS 16
3T, :SCOTCH SHORT ARM 26031
3T, :SCOTCH LONG ARM 26032
3T, :SCOTCH SHORT LEG 26033
3T, SCOTCH LONG LEG 26034
3T ROLL, PLASTER 26075
, MONITOR 26037
~ER PADS 79064 I
PA
GUARANTOR'S EMPLOYER
190-58-0050
17013
EMERGENCY NOTIFY
LHERISSON, DI~NE B.
(717)258-96B5
· 02
44
40341,
01
GASTRO/HEMO SLIDE 26060
KIDDE TOURNIQUET 26048
OCL PER FOOT 79670
F.S.B.S. 80081
TUBE GAUZE PER FOOT 26074
ED STAT ESTAT
PULSE OX POXED
EXTENDED CHARGE I 26760
EXTENDED CHARGE II 26770
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E.D./ATIEND1NG
FRANKE, PAUL
WILLWERTH, GERALD
1730704
PRE.CERT.NO.
I SOLATI OM
ALL ADDITIONAL CHARGES
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NAME: LHERISSON, PATRICK
MRN: 813341
DOS: 06/18/2000
CHIEF COMPLAINT:
PAIN IN THE MID BACK,
HPI: A 42-year-old gentleman was involved in an
altercation with his wife. She was hitting
him. He fell off a chair and fell backwards against fixed object on the
floor. He has significant pain in the left lower back. He is able to
ambulate. He has no numbness, tingling or weakness in the lower
extremities. He feels somewhat better now but still quite sore. He denies
any shortness of breath.
PHYSICAL EXAMINATION: GENERAL APPEARANCE: Alert and oriented
gentleman. He has obvious swelling over the
left perilumbar region in the region of L-1, T-10. There is no pain on
palpation over the thoracic or lumbar spinous processe,s. There is very
significant pain on palpation over that area, swelling, which is about S-10
cm. He also has pain on palpation of the left 11th and 12th rib area and
posterior portion. Lungs are clear. Normal lower extremity strength,
LABS/X-RAY:
DIFFERENTIAL DIAGNOSIS:
ED COURSE:
No x-rays required in my opinion.
Significant contusion and clinically has a
rib fracture based on my exam.
He needs significant amount of analgesia. I
will provide Percocet and ice and he should
be prepared to have significant discomfort
over the next week to two weeks.
FINAL DIAGNOSIS:
1. CONTUSION LOWER BACK.
2. RIB FRACTURE BASED ON CLINICAL
EXAMINATION.
PAUL FRANKE, M.D.
D 2206 EST
T 0946 EST/S10/04969
06/18/2000
06/20/2000
CARLISLE HOSPITAL
EMERGENCY DEPARTMENT RECORD
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NURSING ASS~SSMENT:
246 PARKER STREET CARLISLE, PA 17013"0310 CONVENIENT CARE/EMERGENCY REGISTRATION
ALLERGIE' h h A
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Y
MEDICINES:
TE~"?_I'~'tlIRESI ( .IB~C\ IBY \ -XJME"h}1~""ANU'
FOR NURSING ASSESSMENT
SEE NURSING DOCUMENTATION SHEET
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HISTORY
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PHYSICAL EXAM
-c-
TIME
PHYSICIAN ORDER
EO INTERPRETATiON OF:
LASS:
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DISPOSITION
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HOME ADMIT
TIME OF D1SC~GE
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NONE 0
DIAGNOSIS:
o 0 0
08S TRANS OTHER
I CONDITION ON DISCHARGE
I 0 SAME ...f?!MPROVED
ADMISSION DIAGNOSIS:
REASON FOR VISIT
ATT.PHYS.
INS
DISPOSITION FROM ~ ED
NOTIFIED TIME
CONVENIENT
o CARE CENTER
INIT. RESPONDED
PAIN MID BACK FELL
,..nil'> Ir."
FAMILYPHYS
95014
i PATIENT NUM~ER I PATIENT NAME
, 1730704 i LHERISSON, PATRICK H.
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21:25
AGE j ~XlRCIMS I HOW ARRIVED
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