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Home My WebLink About00-04805 , ,-" ~ , , .", ..:' ~ :.'-- . c.,'~'--'l Patricia Reed, : IN THE COURT OF COMMON PLEAS OF Plaintiff vs. : CUMBERLAND COUNTY, PENNSYL VANIA : NO, 00- 'ItfQ5" CIVIL TERM Nathan Reed, Defendant : PROTECTION FROM ABUSE AND CUSTODY 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 ~ 13 ,2000 AT ~:~O P .M.,INCOURTROOMNO. J-.j OF HE UMBERLAND 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. g6114. Violation may also subject 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 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 Disabllities 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. ,< ,~~ , ~..." . ~ ''''_ '>' "c"'~" . :: Patricia Lynne Reed Plaintiff . . : In the Court of Common Pleas : County, Pennsylvania v. : No. (J-(? - '-I po 5' Nathan Donald Reed Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Nathan Donald Reed Defendant's Date of Birth is: March 9, 1969 Defendant's Social Security Number is: 231-23-0413 Name(s) of All protected persons, including Plaintiff and minor children: 1. Patricia Lynne Reed AND NOW, on :J ,) , b. )lVflnpon consideration of the attached Petition for Protection from ~hereby enters the following Temporary Order: Plaintiff's request for II 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: 719 Cumberland Point Circle Mechanicsburg, Pennsylvania 3. Except for such contact with the minor child/ren as may be permitted under paragraph 5 ofthis 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. Plaintiffs place of employment located at Dollar General located at Cedar Cliff Mall, Camp HilI, Pennsylvania 17011. . ~~- " 4. Except for such cpntact with the minor child/ren as may be permitted under paragraph 5 of this Order, Defendant shall not contact Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 5. Pending the outcome of the final hearing in this matter, Plaintiff is awarded temporary custody of the following minor child/ren: I. Khelsea Lynne Reed 2. Samantha Dawn Reed Until the final hearing, all contact between Defendant and the child/ren shall be limited to the following: . The parties shall share legal custody of the children and Plaintiff shall have primary physical custody of the children. Defendant shall have partial physical custody of the children everyother weekend from Friday until Sunday, and at other dates and times agreed upon by the parties. The children shall be returned to Plaintiff Tuesday, July 11, 2000, upon their return from vacation with the paternal grandparents. 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 ofthis Order. 6. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Upper Allen Police Department Lower Allen Police Department 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 IMMEDlA TEL Y TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL DECEMBER 5, 2001 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months in jail. 23 Pa.C.S. ~6114. Consent ofthe Plaintiff to Defendant's return to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. ~6113. Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. ~~2261- 2262. " ~ -,-d ,~, "0,,,, NOTICE TO LAW ENFORCEMENT OFFICIALS . , . This Order shall be enforced by the police who have jurisdiction over the plaintiff's residence OR any location where a violation of this order occurs OR where the defendant may be located. If defendant violates Paragraphs 1 through 5 of this Order, defendant shall be arrested on the charge ofIndirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence oflaw enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriff's office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this court, unless the weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. Date Distribution to: Legal Services - Faxed & Mailed to PSP CoplU p'U2.S~ ly ~~t;V ---10 Lr. - ~c.t.- l'Y\~l'L'i..c( "--~vc.ct ...J.<.:> pr; fi '7/ I&>/OD ~ n Cl C) C 0 ~ i'~ s: . ..-.-, -oC} ~ ,J ~---, n"1r~- f= 2:'+ ,.nf'~_'" ~~~ I ~::..!:~ 0', -~ ., (_ J,':" r;::c :: () -0 n"f" ~o :x: '_,'-;,---;1 C.';;'-;:; .'/'.J >2 r:"? Of!"; z 'J.:l 5;1 ~ ::0 f" -< Patricia Lynne Reed Plaintiff v. Nathan Donald Reed Defendant ,. v'"~ !!i'J. PF AD Number: CRl108377W : In the Court of Common Pleas : County, Pennsylvania : No. ()t)- 'I Po 6" CWd 7 JLW.- : CIVIL ACTION - LAW : PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE 1. Plaintiff's name is; Patricia Lynne Reed 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. Patricia Lynne Reed 4. Plaintiff's Address is : 719 Cumberland Point Circle, Mechanicsburg, Pa 17055 5. Defendant's Name is: N atkan Donald Reed 6. Defendant is believed to live at the following address: 2582 Tiffany Lane, Harrisburg, Pa 17010 7. Defendant's Social Security Number is: 231-23-0413 8. Defendant's Date of Birth is: March 9, 1969 " " . . ~ <" - .l<l~", 9. Defendant's Place of employment is: W eis Market, Linglestown Rd. 10. Defendant is an adult. II. The relationship between the Plaintiff and the Defendant is: Spouse Parents of the same children 12. The Plaintiff and the Defendant been involved in the following court actions: a. Protection From Abuse 13. Other details of the court action are: 1993 - Columbia, Missouri 14. The defendant has been involved in a criminal court action. 15. The defendant is not currently on probation / parole 16. Plaintiff and Defendant are the parents of the following minor childlren: a. Khelsea Lynne Reed Age:8 Child's address is: 719 Cumberland Point Circle, Mechanicsburg, Pa 17055 b. Samantha Dawn Reed Age:6 Child's address is: 719 Cumberland Point Circle, Mechanicsburg, Pa 17055 17. 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. Khelsea Lynne Reed For the past 5 years, this child has lived with: The child has lived with Plaintiff and Defendant for the past five years at the following locations: 6/94-7/97507 S. Main, New London, Missouri 63459 7/97-12/98 Rt. 2, Box 2371A, Center, Missouri 63436 12/98-11/99 PO Box 204, Center, Missouri 63436 11/99-present 719 Cumberland Point Circle, Mechanicsburg, Pa b. Samantha Dawn Reed For the past 5 years, this child has lived with: The child has lived with Plaintiff and Defendant for the past five years at the -WI'......... ,~ 'o""",,' following locations: 6/94-7/97507 S. Main, New London, Missouri 63459 7/97-12/98 Rt. 2, Box 2371A, Center, Missouri 63436 12/98-11/99 PO Box 204, Center, Missouri 63436 1l/99-present 719 Cumberland Point Circle, Mechanicsburg, Pa 18. The following other minor child/ren presently live with Plaintiff: a. Lauren Nicole Breedlove Age: 14 The Plaintiff's relationship to this child is: natural mother 19. The facts of the most recent incident of abuse are as follows: On or about July 1, 2000, Defendant threatened to punch Plaintiff in the face causing Plaintiff to fear for her safety. 20. 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: In or about the end of May 2000, Defendant restrained Plaintiff against the wall by pressing his arm across her throat causing red marks on her neck. Since approximately January 2000, Defendant has threatened to kill Plaintiff on at least five occasions. In or about November 1999, Defendant threatened Plaintiff if she did not shut-up, he would punch het. Defendant slapped Plaintiff across the face with an open hand. In or abOlj.t October, 1999, Defendant became angry, held a swiss army knife to Plaintiffs throat, and threatened he could killlner if he wanted too, causing Plaintiff to fear for her life. On or about August 20, 1998, Defendant held a gun to Plaintiffs forehead and threatened to shoot her. In or about Summer of 1998, Defendant punched Plaintiff about the head and body resulting in injuries including a black eye. Since approximately August 1989, Defendant has abused Plaintiff in ways including the following: punched, slapped, kicked, and grabbed Plaintiff, and threatned to kill her. Defendant has thro~ things and on one occassion, used his head to put a hole in the wall. On one occasion Defendant became enraged in the presence of Plaintiff and the children and threw a cat against the garag~ door causing it to die. Plaintiff has suffered injuries, including but not limited to, bruises, a 'cut lip, and a black eye. 21. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: Upper Allen Police Department Lower Allen Police Department 22. There is an immediate and present danger of further abuse from the Defendant. 23. Plaintiff is asking the court to evict and exclude the Defendant from the following residence: , " 719 Cumberland Point Circle Mechan4:sburg, Pennsylvania Rented By:PatricialNathan Reed 24. 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, haras$ing, or stalking Plaintiff and/or minor child/ren in any place where Plaintiffmay be found. b. Evict/exclude Defendant from Plaintiffs rellidence and prohibit Defendant from attempting to enter any temporary or pennanent rellidence of the Plaintiff. e. Award Plaintiff temporary cU$tody of the minorchild/ren and place the following re$triction$ on contact between Defendant and child/ren: The parties shall have shared legal custody of the chlldren and the Plaintiff shall have primary physical custody ofth:e*"dren. Defendant shall have partial custody of the children every other weekend from Friday until Sunday, and at other dates and times agreed, upon' by the partiell. The chlldren shall be returned to Plaintiff Tuesay, July 11,2000, upon their return from vacation with their paternal grandparents. 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 persOI1$, including but not limited to any contact at Plaintiffs school, businells, or place of employment, except all the court may find nCCellsary with 1'ellpect 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 feel!. f. Order the following additional relief, not listed above: - Defendant refrain from harassing Plaintiff's relatives. - Defendant is enjoined from damaging or destroying any property owned jointly by the parties or solely by the Plaintiff. - Order Defendant to pay $250.00 to reimburse one of Legal Services, Inc.'s funding sources for the cost of litigation in this case. g. Order the police or other law enforcement agency to serve the Defendant with a copy of thi$ Petition, any Order issued, and the Order for Hearing. The petitioner will inform the desigDated authority of any addresse$, other than the Defendant'$ residence, where Defendant can be served. ------ .-R,":"IYSOO='OObyA:i~- Agency: Legal Service$, Inc. ,~, '>-''';' .' ~',~:~ \ 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. g4904, relating to unsworn falsification to authorities. Dated: -7 - 5 - vi) MtJrj-PffaJ//ZQ0j) Patricia Reed, Plaintiff ~~~llitiMnt"i_~'~j_I~~tfWoi~..HM!II<!JJ:~"'-~!Ji;~' ~-JII.l<..Ii ~. f:II" ill.'LJ ~-----, 0 0 ~ C 0 <'"' (- -o?t] S f11fYl -r] 7.~-" , r: __AI =-~2~:q ZT' I ~::~~ 0' S~;S ~C:l -ry ~-,~~ ;~ ~';o :3: ~o ;31"\1 >c z """" ;~ ~ T h) -< \\ ~ ~ yl ~ ",I ~- 07/06/00 THU 13:57 FAX 717 240 6573 i' '_~ . . CU!lIl3 CO PROTHONOTARY 1aJ001 TRANSMISSION OK TX/RX NO CONNECTION TEL CONNECTION ID ST. TIME USAGE T PGS_ RESULT ********************* *** TX REPORT *** ********************* 1973 92490779 07/06 13:52 04'46 7 OK ,< "~, " =I~ Patricia Reed : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00- 4805 CIVIL TERM Nathan Reed, Defendant : PROTECTION FROM ABUSE AND CUSTODY ORDER FOR CONTINUANCE AND NOW, this 13 d day of July, 2000, upon consideration ofthe attached Motion for Continuance, the matter scheduled for hearing on July 13,2000, by this Court's Order of July 6, 2000, is hereby rescheduled for hearing on August 9, 2000, at 11 :00 a.m. in Courtroom No.4. The Temporary Protection From Abuse Order shall remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. By the Court, Joan Carey LEGAL SERVICES, INC. Attorney for Plaintiff ~ iJ, ~ ,S, c 'J..13' (Yt1 t- Elizabeth Hoffman LAW OFFICE OF ELIZABETH HOFFMAN ~ ~ 7-13. ov Attorney for Defendant '----t'-' .0 _-'fl~~I!',~ '~'" l"lfflmll(llJlJ)''ll!N:.""", nte: V' ;' Fll~~g:';:~f\:r;;',:~j;- t p. . "... II,-".:\"",--,.I\' ,i 00 JUt. \ 3 !\\\ Ii: 25 CUM3EiiU~'JO CUu\~TY PENNSYLW,NIA ~~..."j~~~_~i'ffi~_~$A'Oll~~~_:~~~-'''''~~\l\ilI\'IiIi!~,'~'''''"~ _ ,I ~~~ h, , " Patricia Reed Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 00,4805 CIVIL TERM : PROTECTION FROM ABUSE AND CUSTODY v. Nathan Reed, Defendant MOTION FOR CONTINUANCE The Plaintiff, Patricia Reed, 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: I. A Temporary Protection From Abuse Order was issued by this Court on July 6, 2000, scheduling a hearing for July 13, 2000, at II :00 a.m. 2. The Cumberland County Sheriffs Department served Defendant with a certified copy of the Temporary Protection From Abuse Order and Petition for Protection From Abuse at his residence, 2582 Tiffany Lane, Harrisburg, Pennsylvania, on July 7, 2000, at 9:05 p.m. 3. The parties agree, by and through their respective counsel, that the hearing be rescheduled to afford them time to negotiate a consent agreement. 4. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. , "d" ~~!. .- L WHEREFORE, Plaintiff requests that the Court grant this Motion and continue this matter reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in effect: Respectfully submitted, o _Carey, Attorney for PI . tiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 M:~_~~~...t!!,~~lt~l!I<l~i_~.atil.~W ""'''~'Jll ~ ,,~,"''"-'. ""'!iiiliWIll!!lJjlil!iI~Ilti~li!io lliLJ ~~&i;@\M!ffilil~j;j,--!4il.~ -~ S? C:::> ,- CJ :5:-. (.:::: , ~J \Y' <, m r": ,- Z :r .- ':l.l ~~~~; I~ ':.?, l Q C;::C) -n ~~~ i"c :""1-: Z(~ r:-i' )>c:: =---\ Z r.:- ~> ~ :0 co -< "' ...;. ...... , SHERIFF'S RETURN - OUT OF COUNTY , CASE NO: 2000-04805 P COMMONWEA~TH OF PENNSYLVANIA: COUNTY OF CUMBERLAND REED PATRICIA LYNNE VS REED NATHAN DONALD R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: REED NATHAN DONALD but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN County, Pennsylvania, to serve the within PROTECTION FROM ABUSE On July 13th , 2000 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep. Dauphin Co 18.00 9.00 10.00 25.50 .00 62.50 07/13/2000 ~~ R. Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this J.(J day of ::Ju.L~ ;JlOO A D. -;f.muJ ;:4;in~lfri ~1' ." ~ ~n___~ ullilllilaIiiWm.'i.. , @ffh:e of t4~ ~4~riff William T. Tully Solicitor Ralph G. McAllister Chief Deputy Michael W. Rinehart Assistant Chief Deputy Mary Jane Snyder Real Estate Deputy Dauphin County Harrisburg, Pennsylvania 1710! ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania REED PATRICIA vs County of Dauphin REED NATHAN Sheriff's Return No. 1522-T - -2000 OTHER COUNTY NO. 00-4805 AND NOW: July 7, 2000 at 9:05PM served the within PROTECTION FROM ABUSE upon REED NATHAN by personally handing to HIM 1 true attested copy(ies) of the original PROTECTION FROM ABUSE and making known to him/her the contents thereof at 2582 TIFFANY LANE HARRISBURG, PA 00000-0000 DEFENDANT WAS NOTIFIED OF EVICTION & NOTIFIED OF CUSTODY PENDING THE OUTCOME OF THE FINAL HEARING C!.. ~aNMJ PROTHONOTARY So Answers, jR~ Sworn and subscribed to before me this 10TH day of JULY, 2000 Sheriff of , Pa. By Sheriff's Costs: $0.00 PD 00/00/0000 RCPT NO ET/TS ..,~"~ '~17' ~ ~ . ~~ J, ~ In The Court of Common Pleas of Cumberland County, Pennsylvania patricia Reed VS. Nathan Reed No. 20-4805 Civil Now, 7/6/00 , 20 C () , I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. , , r~~~t:~~ Sheriff of Cumberland County, PA Affidavit of Senrice Now, ,20_, at o'clock M, served the within upon at by handing to a copy of the original and made Imown to the contents thereof. So answers, Sheriff of County, FA 20 '- COSTS SERVICE MILEAGE AFFIDA VIT $ Sworn and subscribed before me this _ day of $ 0' " "- <-+-'" ." ''''''''1 i I I I I . \, PATRICIA REED, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NATHAN REED, Defendant NO. 00-4805 CIVIL TERM TEMPORARY CUSTODY ORDER AND NOW, this 31st day of July, 2000, upon consideration of the within Petition for Special Relief, and pursuant to agreement by the parties by and through their counsel, Judge Hess's order of July 6, 2000, is modified to include the following: 1. The Plaintiff, Patricia Reed, shall have custody of the children from August 1, 2000, through August 9, 2000, and may travel with the children to the Louisiana area for her sister's graduation, family gathering, and vacation. 2. The Plaintiff shall return to Cumberland County on or before August 9, 2000. 3. The plaintiff shall have the children call the father collect at least twice during their trip. 4. The plaintiff agrees to make arrangements for the father to see the children for a short visit on Monday evening, July 31, 2000, and she further agrees to give the father a general itinerary of her plans including the contact numbers of her sister in Louisiana where they plan to stay as well as her friend's father's number in Texas ~,,- ~,-""",'-",;d-. ,;,,' , ' \" where they may visit if time permits. 5. Mother shall not drink any alcoholic beverages within five hours of operating a motor vehicle at any time during this trip. 6. In all other respects Judge Hess's order of July 6, 2000, remains in full force and effect. Edward E. Guido, J. (for Kevin A. Hess) Joan E. Carey, Esquire For the Plaintiff > . . ~ f-j-UJ Esquire ~ '"-f"""'. Elizabeth A. Hoffman, For the Defendant :lfh . . r ~~ ' .,. M~.'" c' " ,~ _0~""'"_'__ ~,,~-,~~"~.".,,-,~-~ ." =', -':ri~J-lY elL i~,f fC ,j I: n!,; CUi'i:3~:i':;j. ,~ , ()~~UNTY FJENi\JSYL~I\i\JiA ~~ .. Viii/'!!' ~. ll!"~ ~ .' '="0 '. ,,'-"- . Patricia Reed : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00- 4805 CIVIL TERM Nathan Reed, Defendant : PROTECTION FROM ABUSE AND CUSTODY TEMPORARY CUSTODY ORDER AND NOW, this day of July, 2000, upon consideration of the within Petition for Special Relief, the following this court's Order of July 6, 2000, is modified to include following: I. The plaintiff, Patricia Reed, shall have custody of the children from August I, 2000, through August 9, 2000, and travel with the children to the Louisiana area for her sister's graduation and family gathering and vacation. 2. The mother shall return to Cumberland County on or before August 9, 2000. 3. In all other respects this Court's Order of July 6, 2000, remains in full force and effect. By the Court, Kevin A. Hess Joan Carey Attorney for Plaintiff Elizabeth Hoffman Attorney for Defendant c.. . - .'~.-,';" :(~ '.,,-, .. ,~ C'"""""' i'~ P atri cia Reed : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00- 4805 CIVIL TERM Nathan Reed, Defendant : PROTECTION FROM ABUSE AND CUSTODY PETITION FOR SPECIAL RELIEF The Plaintiff, Patricia Reed, by and through her attorney, Joan Carey of Legal Services, Inc., states the following: I. Plaintiff, Patricia Reed, hereinafter referred to as the mother, resides at 719 Cumberland Point Circle, Mechanicsburg, Cumberland County, Pennsylvania. 2. Defendant, Nathan Reed, hereinafter referred to as the father, resides at 2582 Tiffany Lane, Harrisburg, Dauphin County, Pennsylvania. 3. A Petition for Protection from Abuse was filed on July 6,2000, and a Temporary Protection from Abuse Order was entered granting the mother relief including primary physical custody subject to partial custody with the father on alternate weekends, and the hearing was continued to August 9, 2000, by agreement of the parties by and through their counsel. 4. The father retained Elizabeth Hoffman, Attorney at Law, to represent him in this action, and the parties have cooperated in agreeing that the father have the children for additional periods including one day each week and other times as the parties may agree. 5. A Complaint for Custody was filed on behalf of the father by Judith A. Calkin, Attorney at Law, on July 18, 2000, and a conciliation Conference has been scheduled for September 7, 2000. 6. The mother requests this court's intervention to grant her leave to take the children with her to the Louisiana Area from August 1,2000, through August 9, 2000, for reasons including the following: a. The mother has plans which were made a year, and agreed to at that time by the father, to go with her family to her sister's graduation from University of Mississippi on August 4,2000, which would necessitate her having the children over the father's court-ordered weekend. b. The mother had planned to drive with her children to Louisiana, ..c.. c, ,,_, ~-' ,~, . , ~ .,:) leaving Cumberland County on August I, 2000, and after an overnight motel stay, arriving in the Louisiana area in time for the graduation and returning home in time for the Protection from Abuse hearing scheduled for August 9, 2000, c. Several family members, including the children's maternal grandparents and aunts, have also planned to gather for the family celebration! vacation. d. The mother and children have asked the father to accommodate her, and the mother has agreed to make up the weekend and midweek time the father would miss. e. Legal Services, Inc. has attempted to negotiate this matter with the father's attorney, Elizabeth Hoffman, and the father continues to deny the mother her request. f. The mother has been flexible in accommodating the father's requests for additional time including agreeing to a vacation to Missouri with the paternal grandparents. g, Without this Court's intervention the mother will be harmed by the father's unreasonably denying her request in that she and the children will miss the graduation and family gathering and vacation time. 7. Father's counsel, Elizabeth Hoffinan, has been notified of the filing of this petition and has been faxed a copy. WHEREFORE, Plaintiff asks that the court grant her request and modify its order granting her primary custody, to specifically include that she have the children from August 1, 2000, through August 9,2000, to take the children with her to her sister's graduation in Mississippi and family vacation in the area, and that she return them to Cumberland County by August 9,2000. Plaintiff further requests any other relief which is just and proper. Respectfully submitted, ~ Attorney at Law LEGAL SERVICES, INC. 8 Irvine Row Carlisle, P A (717) 243-9400 ;;0" =- ilIlJ ~ ' . , '" I" 'c, "'.Y.' , . VERIFICATION The above-named Plaintiff, Patricia Reed, verifies that the statements made in the above Petition are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa. c.s. 94904, relating to unsworn falsification to authorities. 9aJ;0JJL ~Q; , Patricia Reed, Plaintiff Date:7~dr -OJ ~lU."";~>illdlid'~l;;".llI~~;;l~ffi~K.tJ~~<IW!MI!'i'>-'""I,r{;/!",<~~i!iIiI~1il!mli!~IO"""""""""''''-i;;M ~~ ~^ ,1., ~ . '_~"m ~~- ~- .,- ~ ~ ,.~~ '. ~ ...~-"'.~ ~" , 1IlMtlil~lWi'rilIi~ [L" <.::. -<,Or (j-~ ~, S:("'j .~ f:ki -< t:~) ,"\') (~ ~.~' -~, C) c_ .:.,.} . "I - .~:::; (-I i -J~) . ! ~ - ;-! -:." {-~ ;~~jrG :,l.) '<:; . ',.,--,,-- ""' PATRICIA REED, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 00-4805 CIVIL TERM CIVIL ACTION - LAW NATHAN REED, Defendant PROTECTION FROM ABUSE IN RE: PROTECTION FROM ABUSE ORDER OF COURT AND NOW, this 9th day of August, 2000, this matter having been called for hearing, on agreement of the parties, that portion of the petition seeking a protective order is deemed dismissed without prejudice. The temporary order of custody dated July 6th, 2000, shall remain in full force and effect pending further order, with the understanding that paragraph five thereof is amended to reflect partial custody from Wednesday to Thursday as the parties shall agree. By the Court, Joan Carey, Esquire For the Plaintiff d :mae ;) ~OO - .,y> ~ lcR' 1l'\ q\< ~l\' , ~ 0 ~<? \pD \J> l\)\ ~ Elizabeth Hoffman, Esquire For the Defendant Wf' I. '." 0., ". Cc, n','" '""., ., .. I ~~",=._,-' .~ . ,,~ ~-,"-^.. -- ~:I! _r:f\_!),,'::!7."i(~;: C"," ":",;.~;~ )\';I~'rJ\rlY '~"--, ,'~ ,''\ -i\l...J Ihr 00 AUG I S All 8: lit CUIVIBEfLND COUNtY PENNSYLVANIA ,,0 ,~ ,''''''''l~""",- ,,"-"',~,,~ ~~ 4 ~<__" '."ff_" ","'_'c , ,,~