HomeMy WebLinkAbout97-01631
Conley,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
v.
CUMBERLAND COUNTY, PENNSYLVANIA
NO.97-1l(,~1 CIVIL TERM
Jeff B. Conley, Sr.,
Defendant
PROTECT ION FROM ABUSE
AND NOW,
~ARY PROTECTION ORDER
this~t day of March, 1997,
upon presentation
and consideration of the within Petition, and upon finding that
the plaintiff, Christina L. Conley, now residing at 414 Third
Street, 2nd Floor, New Cumberland, Cumberland County,
Pennsylvania, is in immediate and present danger of abuse from
the defendant, Jeff B. Conley, Sr., the following Temporary Order
is entered.
The defendant, Jeff B. Conley, Sr., (SSN: unknown and date
of birth: 6/3/59) now residing at 414 Third Street, 2nd Floor,
New Cumberland, Cumberland County, Pennsylvania, is hereby
enjoined from physically abusing the plaintiff, Christina L.
Conley, or placing her in fear of abuse.
The defendant is enjoined from harassing and stalking the
plaintiff.
The defendant is enjoined from entering the plaintiff's
place of employment.
The defendant is enjoined from removing, damaging,
destroying or selling any property owned jointly by the parties
or owned solely by the plaintiff.
A violation of this Order may subject the defendant to: i)
arrest under 23 Pa.C.S. 66113; ii) a private criminal complaint
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Christina L. Conley,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYJ,VANIA
v.
NO.97-
CIVIL TERM
Jeff B. Conley, Sr.,
Defendant
PROTECTION FROM ABUSE
AND CUSTODY
NOTICE
You have been sued in court. If you wish to defend against the
claims set forth in the following pages, you must take action promptly
after this Petition, Order and Notice are served, by appearing
personally or by attorney at the hearing scheduled by the Court and
presenting to the Court your defenses or objections to the claims set
forth against you. You are warned that if you fail to do so the Court
may proceed without you, and a judgment may be entered against you by
the Court without further notice for any money claimed in the Petition
or for any other claim or relief requested by the plaintiff. You may
lose money or property or other rights important to you.
FEES AND COSTS
If the case goes to hearing and the judge grants a Protection
Order, a surcharge of $25.00 will be assessed against you. You may
also be required to pay attorney fees to Legal Services, Inc. for
their representation of the plaintiff.
You should take this paper to your lawyer at once. 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.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (7 17) 240-6200
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.
of bodily injury. This has included, but is not limited to, the
following specific instances of abuse:
a. On or about March 5, 1997, the defendant
forcefully pulled the plaintiff out of bcd, dragged her
by the hair across the carpet bruising her legs and
arms, and causing areas of swelling on her head. He
then grabbed her by the elbows forcing her to go into
the kitchen and blocked the doorway so that she could
not leave the room causing her to fear for her safety.
As the defendant screamed at the plaintiff calling her
vile names, he shoved her out the kitchen door into the
cold with just a shirt and her underwear on and closed
the door refusing to let her back in the house. The
police responded to the defendant's 911 call. saw the
plaintiff's injuries, and arrested the defendant for
simple assault.
b. On or about December 18. 1996, the defendant
forcefully grabbed the plaintiff's ears shaking her
head from side to side causing a laceration on her left
ear. When the police responded to the defendant's 911
call, they saw that the plaintiff was bleeding and
charged the defendant with harassment.
c. In or about the summer of 1996. the defendant
pulled the plaintiff's hair, pushed her, twisted her
arm up behind her back, and threatened to break it
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causing pain.
d. On or about AprilS, 1996, the defendant blocked a
door refusing to allow the plaintiff to leave causing
her to fear for her safety. The plaintiff escaped with
her son through a bedroom window and got into her car
with the defendant following them. When the car
stalled, the defendant approached the vehicle, grabbed
the plaintiff by her arms and hair, and dragged her out
of the car. The defendant forcefully pushed the
plaintiff's head into the hood of the car and punched
her in the head.
e. On several different occasions since 1993, the
defendant has thrown several objects at the plaintiff;
punched, kicked, and restrained her, and pulled her
hair.
5. The plaintiff believes and therefore avers that she is
in immediate and present danger of abuse from the defendant and
that she is in need of protection from such abuse.
6. The plaintiff desires that the defendant be enjoined
from harassing and stalking the plaintiff.
7. The plaintiff desires that the defendant be restrained
from entering her place of employment.
8. The plaintiff desires that the defendant be enjoined
from removing, damaging, destroying or selling any property owned
jointly by the parties or owned solely by the plaintiff.
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B. REIMBURSEMENT FOR COST OF C~SE
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9. The plaintiff asks that the defendnnt be ordered to pay
$250.00 to reimburse one of Legal Services, Inc. 's funding
sources for the cost of litigating this case.
WHEREFORE, pursuant to the provisions of the "Protection
from Abuse Act" of October 7, 1976, 23 Pa.C.S. ~ 6101 tl ~., as
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amended, the plaintiff prays this Honorable Court to grant the
A.
following relief:
Grnnt a Temporary Order pursuant to the
~
"Protection from Abuse Act:"
1. Ordering the defendant to refrain from
abusing the plaintiff and placing her in fear of
abuse.
;.
2. Ordering the defendant to refrain from
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harassing and stalking the plaintiff.
3. Prohibiting the defendant from entering the
plaintiff's place of employment.
4. Prohibiting the defendant from removing,
damaging, destroying or selling property jointly
owned by the parties or owned solely by the
plaintiff.
B. Schedule a hearing in accordance with the
provisions of the "Protection from Abuse Act," and,
after such hearing, enter an order to be in effect for
a period of one year:
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I. Ordering the defendant to refrain from
abusing the plaintiff and placing her in fear of
abuse.
2. Ordering the defendant to refrain from
harassing and stalking the plaintiff.
3. Prohibiting the defendant from entering the
plaintiff's place of employment.
4. Prohibiting the defendant from removing,
damaging, destroying or selling property jointly
owned by the parties or owned solely by the
plaintiff.
S. Ordering the defendant to pay $250.00 to
reimburse one of Legal Services, Inc. 's funding
sources for the cost of litigating this case.
The plaintiff further asks that this Petition be filed and
served without payment of fees and costs by the plaintiff,
pending a further order at the hearing, and that certified copies
of this Petition and Order be delivered to the New Cumberland and
Fairview Township Police Departments which has jurisdiction to
enforce this Order.
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The plaintiff prays for such other relief as may be just and
proper.
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Respectfully submitted,
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,~ un Carey, Attor~laintlff
LEGAL SERVICES, INC.
B Irvine Row
Carlisle, PA 17013
(717) 243-9400
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Christina L. conley,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 97 - 1631 CIVIL TERM
vs.
Jeff B. Conley, Sr.,
Defendant
PROTECTION FROM ABUSE
AND CUSTODY
MODIFICATION OF TEMPORARY PROTECTION ORDER
AND NOW, this q~ of April, 1997, upon consideration of the
within Petition the following Order is entered:
The Defendant, Jeff Conley, sr., is excluded from the
residence located at 414 Third Street, 2nd Floor, New Cumberland,
Cumberland county, Pennsylvania, and any other residence the
Plaintiff may establish for herself in the future.
In all other respects the Temporary Protection Order dated
March 31, 1997, remains in effect.
This Order remains in effect for a period of one year or
until further Order of Court.
~
on the J D day of
NO.~, Cumberland
A hearing shall be held on this matter
April, 1997, at \ ,"'. \]) (tt'm., in Courtroom
county courthouse, carlisle, Pennsylvania.
The Cumberland county Sheriff's Department shall attempt to
make service at the 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
Christina L. conley,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 97 - 1631 CIVIL TERM
vs.
PROTECTION FROM ABUSE
AND CUSTODY
Jeff B. conley, sr.,
Defendant
PETITION TO AMEND PROTECTION FROM ABUSE PETITION AND
MODIFY TEMPORARY PROTECTION ORDER
The plaintiff, Christina L. Conley, by and through her
attorney, Joan Carey of Legal Services, Inc., states the
following:
1. A Temporary Protection From Abuse Order was entered by
this court against the defendant, Jeff B. Conley, Sr., on March
31, 1997, and a hearing was scheduled for April 10, 1997, at
11:00 a.m. in Courtroom No.3.
2. The defendant was served with the Temporary Protection
Order on March 31, 1997 at 414 Third street, 2nd Floor, New
cumberland, Cumberland County, Pennsylvania at approximately 4:54
p.m. by the Cumberland County Sheriff's Department.
3. The Temporary protection Order, in pertinent part,
enjoins the defendant, Jeff B. Conley, sr., from removing,
damaging, destroying or selling any property owned jointly by the
parties or owned solely by the plaintiff.
4. On or about April 3, 1997, in violation of the
Temporary Protection Order, the defendant damaged three items of
the plaintiff'S clothing, two of which appeared to have been
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damaged by a sharp object, exacerbating her fear of the
defendant, and an Indirect Criminal contempt hearing is scheduled
for the April 10, 1997, at 11:00 a.m. in Courtroom No.3.
5. Because of the defendant's history of abuse to the
plaintiff as indicated in the plaintiff's Petition for protection
Order filed on March 31, 1997, and because of the defendant's
continued rage demonstrated by the violation of the Temporary
Protection Order, the plaintiff desires that the Temporary Order
be amended to exclude the defendant from the residence located at
414 Third street, 2nd Floor, New cumberland, cumberland county,
Pennsylvania or any other residence she may establish.
WHEREFORE, the plaintiff requests that the Temporary
Protection Order be modified to exclude the defendant from the
residence located at 414 Third street, 2nd Floor, New Cumberland,
cumberland County, pennsylvania, or any other residence she may
establish and that the Petition for Protection From Abuse filed
on March 31, 1997, be amended to include the plaintiff'~ request
that the defendant be excluded from the 414 Third street
residence and any other residence in the final Protection Order.
Respectfully submitted,
1'1 (-II /'
( ,_ _ " ) I!.lUu {"
'Joan Carey II
,/Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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Christina L. Conley,
Plaintiff
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 97 - 1631 CIVIL TERM
vs.
Jeff B. Conley, Sr.,
Defendant
PROTECTION FROM ABUSE
AND CUSTODY
.
~~ROTECTJON ORDER
AND NOW, this L~ day of Apri I, 1997, upon considerat ion
of the Consent Agreement of the parties, the following Order is
entered:
I. The defendant, Jeff B. Conley, Sr., is enjoined from
physically abusing the plaintiff, Christina L. Conley, and from
placing her in fear of abuse.
2. The defendllnt is ordered to refrllin from harassing and
stalking the plaintiff.
3. The defendllnt is prohibi ted from entering the
plaintiff's place of employment.
4. The defendant is prohibited from removing, damaging,
destroying or selling Rny property owned by the plaintiff or
jointly owned by the parties.
5. The defendRnt is excluded from the plaintiff's
residence locRted Rt 414 Third Street, 2nd Floor, New Cumberland,
Cumberland County, PennsylvaniR, and Rny other residence the
plllintiff mllY estRhlish,
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6. The court costs and fees are waived.
7. The parties agree that the defendant may go to the
residence escorted by the New Cumberland Police nepartment in
order to obtain his personal items and agreed upon items of the
child. The date scheduled for this transfer of personal property
shall be two weeks from April 18, 1997.
8. The Custody Order of November 4, 1996 shall remain in
effect pending further order after conciliation conference to be
scheduled by the plaintiff. However, from April 18, 1997 until
the property transfer, the plaintiff shal I have physical custody
of the chi Id but for the following t imcs: Tuesday, Apri I 22
until Wednesday, April 23, the weekend of April 25 from Friday to
Sunday, Tuesday, April 29, 1997, and other times agreed upon by
the parties. The specific pick up and drop off times shall be
agreed upon by the parties. The parties shall keep each other
informed of their address and phone numbers.
9. This Order shall remain in effect for a period of one
year or unti I modified or terminated by the Court. The Order can
be extended beyond its original expiration date if the Court
finds that the defendant has committed another act of abuse or
has engaged in a pattern or practice that indicates continued
risk of harm to the plaintiff.
10. This Order may subject the defendant to: i) arrest
under 23 Pa.C,S. g6113; ii) a private criminal complaint undcr 23
PII.C.S. M6113.lj jii) a charge of indirect criminal contempt
under 23 Pa.e.S. M6114, punishable by imprisonment up to six
months and II fine of $100.00-$1,000.00; and iv) civil contempt
under 23 Pa.C.S. g6114.1. Resumption of co-residence on the part
of the plaintiff and defendant shull not nUllify the provisions
of the court order.
II. The New Cumberland IInd Fllirview Township Police
Departments shall be provided with certified copies of this Order
by the plaintiff's attorney und muy enforce this Order by arrest
for indirect criminal contempt without warrant upon probable
cause that this Order has been violated, whether or not the
violation is committed in the presence of II pol ice officer. In
the event that an arrest is mllde under this section, the
defendllnt shall be tllken without unnecessary delay before the
court that issued the order. When that court is unavai lable, the
defendant shall be taken before the IIppropriate district justice.
(23 Pa.C.S. g 6113).
Joan Carey -
Attorney for Plaintiff
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Gregory J. Katshir
Attorney for Defendant
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Christina L. Conley,
Plnintiff
IN TilE COURT 01' COMMON PLEAS 01'
CUMBERLAND COUNTY, PENNSYLVANIA
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CIVIl. ACTION - LAW
NO. 97 - 1631 CIVIL TERM
VB.
Jeff n. Conley, Sr.,
Defendnnt
PROTECTION FROM ABUSE
AND CUSTODY
CONSENT
AGREEMENT <X'~
on this J~ dny
of Apri I, 1997,
This Agreement is entered
by the plaintiff, Christina L. Conley, nnd the defendnnt, Jeff B.
Conley, Sr. The plnintiff is represented by Jonn Cnrey of LEGAL
SERVICES, INC.; the defendnnt is represented by Gregory J.
Kntshir. The pnrties ngree thnt the fol lowing mny be entered ns
nn Order of Court.
1. The defendnnt. Jeff n. Conley, Sr., ngrees to refrnin
from nbusing the plnintiff. Christinn L. Conley, or from plncing
her in fenr of nbuse.
2. The defendnnt ngrees not to harnss nnd stnlk the
plaintiff.
3. The defendnnt agrees not to enter the plnintiff's plnce
of employment.
4. The defendnnt agrees not to remove, dnmnge, destroy, or
sell any property owned by the plaintiff or jointly owned by the
pnrties.
5. The defendnnt ngrees to stny nwny from the plnintiff's
residence locnted nt 414 Third Street, 2nd Floor, New Cumberlnnd,
Cumberlnnd County, Pennsylvnnin or nny other residence she mny
establish for hersclf.
6. The dcfendant, although entering into this Agreement,
does not admit the allegations made in the Petition.
7. The parties agree that the defendant may go to the
residence escorted by the New Cumberland Police Dcpartment in
order to obtain his personal items and agreed upon items of the
child. The date scheduled for this transfer of personal property
shall be two weeks from April 18, 1997.
8. The parties agree to the following regarding custody of
the child, Jeff B. Conley, Jr.: the Custody Order of November 4.
1996 shall remain in effect pending further order after
conciliation conference to be scheduled by the plaintiff.
However, from April 18, 1997 until the property transfer, the
plaintiff shall have physical custody of the child but for the
following times: Tuesday, April 22 until Wednesday, April 23,
the weekend of April 25 from Friday to Sunday, Tuesday, April
29. 1997, and other times agreed upon by the parties. The
specific pick up and drop off times shall be agreed upon by the
parties. The parties shall keep each other informed of their
address and phone numbers.
9. The defendant understands that the Protection Order
entered in this mat ter wi II be in effect for a period of one year
and can be extended beyond it original expiration date if the
Court finds that the defend,lnt has committed another act of abuse
or has engaged in a pattern or practice that indicates continued
risk of harm to the plaintiff. The defendant understands that
this Order will be enforceable in the same "mnner as the Court's
prior Temporary Protection Order entered in this case.
10. Violation of the Protection Order may subject the
defendant to: i) arrest under 23 Pa.C.S. ~6113; ii) a private
criminal complaint under 23 Pa.C.S. ~6113.1; iii) a charge of
indirect criminal contempt under 23 Pa.C.S. ~6114. punishable by
imprisonment up to six months and a fine of $100.00-$1,000.00;
and iv) civil contempt under 23 Pa.C.S. ~6114.1.
WHEREFORE, the part les request that a Protect ion Order be entered
to reflect the above terms.
nt iff
"@,'ut
oan Carey
Attorney for p aintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
900 Market Street
Lemoyne, PA 17043
(717) 763-8133
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CHRISTINA L. CONLEY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
97-1631 CIVIL TERM
JEFF B. CONLEY, SR.,
Defendant PROTECTION FROM ABUSE & CUSTODY
IN RE: CONTINUANCE
ORDER OF COURT
AND NOW, this lOth day of April, 1997, Joan Carey,
Esquire, having appeared on behalf of Christina L. Conley on the
civil side of the PFA, and John A. Ahom, Esquire, Assistant
District Attorney, having appeared on behalf of the prosecution
of the criminal contempt petition filed (which criminal contempt
allegedly arose after the signing of the temporary order on
March 31, 1997), and Ellen K. Barry, Esquire, Assistant Public
Defender, having appeared on behalf of the Defendant on the
criminal contempt, and both the original hearing on the
temporary order and the hearing on the criminal contempt having
been scheduled for this morning at 11:00 a.m., and defense
counsel having requested a continuance, the hearing is continued
until next Friday, April 18, 1997, at 10:30 a.m., in this
courtroom.
Ms. Carey, on behalf of the Plaintiff, agrees to
the continuance, as does Mr. Ahom, on behalf of the Plaintiff on
the criminal contempt end of it. Ms. Barry has asked for a
continuance so the Defendant has an opportunity to get himself
private counsel for the civil petition.
Needless to say, any temporary order and any
modification since the temporary order remain in effect until
final hearing.
By the Court,
Joan Carey, Esquire ,
Legal Services, Inc. ~utl<-I fll/l.J.uL 4/16/17
For Plaintiff ' 0 lAM-
John A. Abom, Esquire U,7l1J -/""...l. -/.t&./Mu"--
Assistant District Attorney ~-14-47
Ellen K. Barry, Esquire
First Assistant Public Defender
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OFFICE OF THE DISTRICT ATTORNEY
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ONE COURTHOUSE SQUARE
CARblSLE, P~oNNSVLVAN'A 17013
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CHRISTINA L, CONLEY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
V,
97-1631 CIVIL
JEFF B, CONLEY,
Defendant
CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this 7th day of April, 1997, this Court certifies that the attached
complaint has been properly completed and verified, and there is probable cause for the
issuance of process, In consideration of the attached Commonwealth's Petition, the
defendant. JEFF B, CONLEY, is directed to appear for trial on the charge ofIndirect
Criminal Contempt before the Court on the 10th day of April. 1997 at 11 o'c1ock a,m, in
Courtroom # 3 of the Cumberland County Courthouse, Carlisle, Pennsylvania,
The defendant has a right to be represented by an attorney, If the defendant
cannot afford an attorney. upon request one will be assigned to represent the defendant, If
the defendant wishes assignment of counsel. contact should be made prior to trial with the
Cumberland County Public Defender's Office at 7]7-240-6285, Further, if the defendant
fails to appear. an arrest warrant will be issued,
The Sheriff of Cumberland County is directed to serve this Order and Petition
upon the defendant. The assessment of costs to be determined by the Trial Judge
subsequent to trial.
By the Court,
.
Michael S, Schwoyer
Chief Deputy District Attorney
1.
JEFF B. CONLEY
(1PltS q"uv.;> +0 1). R ~ ot{;, L
I~I r.o-o~l"r.~
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C- '.. 'r" '" 'f',.', '.."''''''...,/ny
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p-t'.'.. 1\"" \
r:\I\:.;,fL.lhl'r
CHRISTINA L. CONLEY,
Plaintiff
IN THE COURT OF COMMON PLEASOF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
: 97-1631 CIVIL
JEFF B. CONLEY, SR.,
Defendant
: CHARGE: INDIRECT CRIMINAL CONTEMPT
COMMONWEALTH'S PETITION FOR A HEARING ON CHARGES
OF INDIRECT CRIMINAL CONTEMPT
Michael S. Schwoyer, Chief Deputy District Attorney "fCumberland County,
Pennsylvania, brings the following Petition for a hearing on charges of Indirect Criminal
Contempt:
I. A Protection from Abuse Order was issued by the Court. A true and correct
copy of the Order is attached.
2. The defendant's violation of this Order is averred in the attached criminal
complaint.
3. The District Attorney's Office approves the filing of this criminal complaint.
4. The Commonwealth is requesting a hearing on the charges of Indirect Criminal
Contempt pursuant to 23 Pa.C.SA 96113.
5. The plaintiff and the defendant seek modification of the Order based on the
filing of this petition as the Court deems appropriate following the trial in addition to any
other sentence. 23 Pa.C.S.A. ~6113.
WHEREFORE, the Commonwealth requests the defendant be commanded to
appear before the Court on the charge of Indirect Criminal Contempt.
, 9AIMlNAL COMPlAINT
(POUCIiJ
Charles A. Clement, Jr,
DlsmlCT JU5l1CE
MAGISTERIAL DI&mICT NO. 09- 1 -01
1106 Carl1sle Road
Camp Hill, PA 17011
A39540
r.....'.
. ~ . of
~~
'-"1..... .
'.' .
I. Off1cer W1111am G, Heaver. 12-6
(NiJm,O[ti/1iafll)
of 0
( ,n")' tplmmtflltllU,,"O'ffpm,nl, t2n pOItra .III MJ/M)
COMMONWEALllt OF Pl!NNSYLVANIA
llEFEt.UmT: VS.
i I '''',:-tn.,- ''f''.I:~". HlI~",:i,t(I',I.'
NAME J ff Bel .." ",T', ,.,. I ' ,
ANO 4e14 '3rd' SOtn,~Y,.""~i' ~'_.''Y, i, " :
""'~ ,,- .' .~, ".. I:
AlXll'lESS New CUlll.be~1II :', )? ~
:"""~~.~, ..:..., '1',.':1'"
W/H/37 DOB.614l5h,~~':~i.'.".." :
55, 194~52-.4~ir". ,:i' '
R$II.
AKA
do hereby state:
(I) 61 I accuse the above named defendant, who lives at the addreu set forth above or,
~ tl I accuse an individual whose name is unknown to me but who is described as
!
,~
I
...
~
o
~
(2)
o his nickname or popular designation is unknown to me and, therefore, J have desisnated him herein as lohn
Doc: with violating the penal laws of the Commonwealth of Pennsylvania at ~ 14 3rd S~ 2nd f1 oor,
New Cumber I and (fl<<t./tJ// SuMrIs/oll)
in Cumberland CounlY on or about 3/31/97 to 4/3197
Part lei pan ts were (V,1I,,.. wrrf pa1tiClpantJ. ptact ''''ell "~mO' Arrr. trpnJ/;1fI '", "amt 01 tJlxnt JtlmJaflt);
Jeff B. Conley r&\
The acts commille~ by the accused were: >b Court Order No. 97-1631 Civil Term
The defendant was in violation of Court Order 97-1631 Civil Term signed by Judge George
E. Hoffer which was Issued on 3/31/97 in Cumberland County under the Protect1on from Abuse
Statute. In that order the defendant was enjoined from destroying or damaging any property
owned by the plaintiff, Christ1na L. Conley, among other issued addressed. Dur1ng the t1me
after the defendant was served with the order and April 3, 1997 the v1ct1m, Chr1stina L,
Conley, alleges that three clothin9 items were damaged ,in v1olat1on of sa1d order.
all of which were against the peace and dlsnity of the Commonwealth of Pennsylvania and contrary to the Act of Aaaembly,
or in violation of ~~1'n1Qt\...~.:~:~,:'~I";~.1. and ::.~::~;~~~.'f~~X of the AJ:.t of ' . .':', 4'}..(:~:~"':'i~r.:::"" "::~":-'~ '" ..
(S<<tItm) ISob.utl/Do)
h..,...., ..;.... ,'. Od' r ..... .-, "\l"r"~"",," .... . ....~.'_.....i';~._ ':"
orte.4.......... .. '" flnanceo,.. -. .... '" ....."...\ .... ..~.~.~.."'_.'."...
(/tJ/lliaJ! Sob. dl,lJlon)
(3) I ask that a warrant or arrest or a summons be Issued and that the accused be required to answer the charges
I have made.
(4) I verify that the faelS set forth in this complaint are true and correct to the best of my knowledge or Information
and belief. This verification is made subject to the penalties of Section 4904 of the Crimes Code (18 Pa. C. S.
~ 4904) relating to unsworn falsification to authorities.
April 3rd
19 97
'-
~~/J:~al_')
AND NOW, on this date , 19 _' I certify the complaint has been properly completed and
verified, and that there is prObable cause for issuance of process.
'l~' ~J&iJF;l;t'.J.~;r
(Jia"'",;/,} DiJlrlct
(lssvllIf A.tilaliry)
(SEAL)
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, .
AFFIDAVIT RIDER CONTAINING PROBABLB CAUSE FOR THE ISSUANCB OF A WARRANT OF
ARREST FOR: Jeff B. Conley of 414 3rd St., 2nd fl., New Cumberland, PA 11070, 1I/M/37, 6/4/59
On 4/3/97 at 1218 hrs. the victim, Chr1stlna L. Conley, reported that three 1tems of her
clothin9 were damaged, Two blouses had recently been unpacked by the v1ctim as part of her
warm weather wardrobe. A be1ge blouse had an approx1mate 4" tear 1n the back of the garment.
A white blouse had an approx1mate 3" slice In the back of the garment and another white blouse
had the left breast pocket almost torn off. The damage to the two wh1te blouses eppeered to
have been made with a sharp object.
On 3/31/97 Christina Conley was granted a temporary protect1on from abuse order s1gned by
Judge Hoffer. According to the Cumberland County Sher1ff's Off1ce a copy of the order was
served on the defendant at his home on 3/31/97 at approximatly 1654 hrs.. Among other things
the defendant was enjoined from damaging or destroying any property owned by Christina Conley.
The v1ctim stated that she was wearing the be1ge blouse on 3/31 which was' ,tile dey the
order was served on the defendant so the damage apparently happened after that time.
Executed this 3rd day of Apr11
, 19..2I.-
b 1.00-. ~. j}) ^'~
(s'fgnatUre of Affiant)
Personally appeared before me on ,19 the Affiant named
above. who, being duly sworn (Affirmed) according to law:-;Igned this Affidavit
Rider in my presence and deposed and said that the facts Bet forth therein are
true and correct to the best of the Affiant8 knowledge, information and belief,
(BRAt]
(Issuing Authority)
EB 39\1d
'O'd'O'N
S9L9-t>LL-LtL
9t>:t>t L66t/t>B/t>B
plaintiff's attorney, This Order shall be enforced by any law
enforcement agency where a violation occurs by arrest for
indirect criminal contempt without warrant upon probable cause
that this Order has been violated, whether or not the violation
is committed in the presence of the police officer. In the event
that an arrest is made under this section, the defendant shall be
taken without unnecessary delay before the court that issued the
order, When that court is unavailable. the defendant shall be
taken before the appropriate district justice, (23 Pa.C,S. 9
6113).
~
~
By the Court,
Judge
f
of bodily injury. This has included, but is not limited to, the
following specific instances of abuse:
a. On or about March 5, 1997. the defendant
forcefully pulled the plaintiff out of bed, dragged her
by the hair across the carpet bruising her legs and
arms, and causing areas of swelling on her head. He
then grabbed her by the elbows forcing her to go into
the kitchen and blocked the doorway so that she could
not leave the room causing her to fear for her safety.
As the defendant screamed at the plaintiff calling her
vile names, he shoved her out the kitchen door into the
cold with just a shirt and her underwear on and closed
the door refusing to let her back in the house. The
police responded to the defendant's 911 call, saw the
plaintiff's injuries, and arrested the defendant for
simple assaul t,
b, On or about December 18, 1996, the defendant
forcefully grabbed the plaintiff's ears shaking her
head from side to side causing a laceration on her left
ear. When the police responded to the defendant's 911
call, they saw that the plaintiff was bleeding and
charged the defendant with harassment.
c. In or about the summer of 1996. the defendant
pulled the plaintiff's hair, pushed her, twisted her
arm up behind her back. and threatened to break it
2
causing pain,
d, On or about April 5, 1996, the defendant blocked a
door refusing to allow the plaintiff to leave causing
her to fear for her safety, The plaintiff escaped with
her son through a bedroom window and got into her car
with the defendant following them, When the car
stalled, the defendant approached the vehicle, grabbed
the plaintiff by her arms and hair, and dragged her out
of the car. The defendant forcefully pushed the
plaintiff's head into the hood of the car and punched
he r in t he head.
e. On several different occasions since 1993, the
defendant has thrown several objects at the plaintiff;
punched, kicked, and restrained her, and pulled her
hair,
5, The plaintiff believes and therefore avers that she is
in immediate and present danger of abuse from the defendant and
that she is in need of protection from such abuse.
6. The plaintiff desires that the defendant be enjoined
from harassing and stalking the plaintiff,
7. The plaintiff desires that the defendant be restrained
from entering her place of employment,
8, The plaintiff desires that the defendant be enjoined
from removing, damaging, destroying or selling any property owned
jointly by the parties or owned solely by the plaintiff.
3
B, REIMBURSEMENT FOR COST OF CASE
9. The plaint I ff asks that the defendant be ordered to pay
$250.00 to reimburse one of Legal Services, Inc.'s funding
sources for the cost of litigating this case.
WHEREFORE, pursuant to the provisions of the "Protection
from Abuse Act" of October 7, 1976, 23 Pa.C,S, ti 6101 tl g,g" as
amended, the plaint i ff prays this Honorable Court to grant the
following relief:
A, Grant a Temporary Order pursuant to the
"Protection from Abuse Act:"
I. Ordering the defendant to refr~in from
abusing the plaintiff and placing her in fear of
abuse.
2, Ordering the defendant to refrain from
harassing and stalking the plaintiff,
J, Prohibiting the defendant from entering the
plaintiff's place of employment.
4. Prohibiting the defendant from removifig,
damaging, destroying or selling property jointly
owned by the parties or owned solely by the
plaint i ff,
B. Schedule a hearing in accordance with the
provisions of the "Protection from Abuse Act," and,
after such hearing, enter an order to be in effect for
a period of one year:
4
I. Ordering the defendant to refrain from
abusing the plaintiff and placing her in fear of
abuse.
2. Ordering the defendant to refrain from
harassing and stalking the plaintiff,
3, Prohibiting the defendant from entering the
plaintiff's place of employment,
4. Prohibiting the defendant from removing,
damaging, destroying or selling property jointly
owned by the parties or owned solely by the
plaintiff.
5, Ordering the defendant to pay $250.00 to
reimburse one of Legal Services, Inc, 's funding
sources for the cost of litigating this caoe.
The plaintiff further asks that this Petition be filpd and
served without payment of fees and costs by the plaintiff,
pending a further order at the hearing, and that certified copies
of this Petition and Order be delivered to the New Cumberland and
Fairview Township Police Departments which has jurisdiction to
enforce this Order,
5
The plaintiff prays for such other relief as may be just and
proper,
Respectfully submitted,
~.-J (]1'V~(,
for Plaint iff
an Carey, Altor
LEGAL SERVICES, INC.
a Irvine Row
Carlisle, I'A 17013
(717) 243-9400
6
CRIMINAL COMPLAINT
(POLICE)
COMPLAINT NUMBER
VEAR
TYPE
NUMBER
Charles A, Clement. Jr.
DISTRICT JUSTICE
MAGISTERIAL DISTRICT NO. 09-1 -01
1106 Carlisle Road
Camp Hill, PA 17011
Complaint Numbers II Other Participants
A39540
INCIOENT NUMBER UCR NO. 'IN
I Officer William G. Weaver. 12-6
. (Sall/t'o}A./liam)
of the New Cumberland Police Department
(IJwt((y d,'purtmt'lII otuK"WI' IVpfl'.It'J/f(',/ tlll/I /lo/i/it'lll wbJiri.\hm)
NAME
ANP
ADDRESS
COMMONWEALTH OF PENNSYLVANIA
DEFENDANT: VS.
r
Jeff B, Conley
414 3rd St., 2nd floor
New Cumberland, PA 17070
RSA
AKA
W/M/37 DOB 6/4/59
SS 194-52-4259
(~)~
"
.g
"
g
~
~
.
"
~
is
~
do hereby slate:
I accuse the above named defendant. who lives at the address set forth above or,
I accuse an individual whose name is unknown to me but who is described as
o his nickname or popular designation is unknown 10 me and, therefore. I have designated him herein as John
Doe; with violating the penal laws of the Commonwealth of Pennsylvania at 1114 3rd St, ,2nd floor.
N \~ Cumberland (I'!tJCl'.Il,litim/SuhdMJiol/j
(2)
in Cumberland County on or about 3/31/97 to 4/3/97
Participants were (iflh,'" "WI' p"rtidpall1.I', plaCt' tlldr II11Il/('J heTt', ft'{It'/ltlllK Iht' name o! ablll'(.Jj'fi'l1dalll):
Jeff B, Conley f'AI
The acts commilled by the accused were: \::.J Court Order No, 97-1631 Civil Term
The defendant was in violation of Court Order 97-1631 Civil Term signed by Judge George
E, Hoffer which was issued on 3/31/97 in Cumberland County under the Protection from Abuse
Statute, In that order the defendant was enjoined from destroying or damaging any property
owned by the plaintiff, Christina L, Conley, among other issued addressed. During the time
after the defendant was served with the order and April 3, 1997 the victim, Christina L.
Conley, alleges that three clothing items were damaged in violation of said order,
all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of Assembly.
or in violation of 1 n1 qn and of the Act of
(St'Ct/on) (.\'/Ib-Jt'cUo/l)
or the
Ordinance of
(llIIitlml.\'uh-Jiri.<;illl1)
(3) I ask that a warrant of arrest or a summons be issued and that the accused be required to answer the charges
I have made.
(4) I verify that the facts set forth in this complaint arc true and correct to the best of my knOWledge or information
and belief. This verification is made subject to the penalties of Section 4904 of the Crimes Code (18 Pa. C. S.
~ 4904) relating to unsworn falsific~tion to authorities.
April 3rd
19 97
'-
(ait",,,,)
AND NOW. on this dat
verified, and that there is
c;::pr
L)
AOPC 411.86
ORIGINAL-SEE REVERSE SIDE FOR WAIVER AND FOOTNOTES
, ~AIL BOND
OTN OJ No:
'';c No: OJ Docket No:
~;ommonwea~h VS. (Defendant Name and Address)
J.~7-9 13, 00 IUL L'7 .
11'-1 Slt.b ST ~ 9u;~rL
IJe-tJ ~Ut11~LAtvb ff}-
Date 01 Charge(s):
NEXT COURT ACTION Date/ Time/ Location
A('~\l L{ ~ 97
iYPES OF SECURITY:
:J Cash/Equivalent 0 Gov't Bearer Bonds
J _% Cash 0 Surety Bond
OTALAMOUNT BAIL SET (IF ANY): $
o Realty w/in Commonwealth
o Realty outside Commonwealth
(see sureties page)
lid!/(
'HARGE(S):
',I
, YPE(S) OF RELEASE:
:J ROR
,] Nominal Bail
an
o Unsecured Bail 0 Nonmonetary Condition(s) (see additional pagels))
o Monetary Conditlon(s) In the amount of $
.. iE CONDITIONS OF THIS BAIL BOND ARE AS FOLLOWS:
. Tho dofendant must appoar 01 011 timos roqulrod until full and final disposition of tho ceso.
, Th. dolend.nt mu.t obey onlurthe' orde" 01 tho banauthorily,
. Tho dofondant musI glvo writtan notlco to tho ball authority, tho clark of courts, tho district ottornoy. and tho court bollogoncy or othor doslgnatod court ball
. 1leol. of any change of address within 48 hours of tho dato of tho chongo.
The defendant must neithar do, nor cauao to bo dono, ncr permit to bo done on his/hor bohalf, any Bet as proscribed by Soction 4952 of tho Crimoa Coda
olating to Intimidation 01 wltno..o. 0' victim.) or by Socllon 4953 (rolating to ,otollollon agaln.t wltno..o. or vlcllm.), 1 B Pa,C,S. ~ 4952,4953,
Tho dofendant must rofraln ftom crimlnalactlvi1y.
\GREE THAT I WILL :;r;.R AT ALL SUBSEQUENT PROCEEOINGS AS REQUIREO ANO COMPLY WITH ALL THE CONDITIONS OF THE BAIL BONO.
lBONOSIQNEOON 3 .192/
:;;-z (66
: \fldand
~~OI.me
;~N~~~v9 7
ISEAU
Court Of Itllllng Authontyl
APPEARANCE OR BAlL BOND
'. bOnd Ie valid lot tN .nllre prot.eedlngt IlIId until full and 111\&1 dl'~ of
. UIe including an.-...nun 01 dlrecl appeal to the Sllpnme Court of P'"",ylvanla
JOGE OR ISSUING AUTHORITY DATE
~9=- 1 3
PlEASE SEf ATlAC~i(O PAGES FOR AODlTIONAlINfOfW"'1ON
'..;'JC41u'1.ge
. ~AIL BOND
.)TN OJ No:
,,:;C No: OJ Docket No:
: ,ommonwealth vs. (Defendant Name and Address)
: J.~7-9 13, 00 IUL Ley _
: 1/1./ SfLb ST, ~ 9Lo~rL
i JJe-w Qu~tUl2U/IVb ,oft-
Date of Charge(s):
NEXT COURT ACTION Date! Time! Location
Ar~\l 4 ~ 97
'HARGE(S):
aK-
..
, YPE(S) OF RELEASE:
,] ROR
:] Nominal Bail
o Unsecured Ball 0 Nonmonetary Conditlon(s) (see additional pagels))
o Monetary Conditlon(s) in tho amount of $
.' iE CONDITIONS OF THIS BAIL BOND ARE AS FOLLOwS:
, Th. d.l.nd.nl mu.t .ppe.r .1.Ullm.. r.qulred untll'uU.nd Iln.1 dl'l'o.itlon ollh. c...,
. The del.ndont mu.t obey .U furth.r ord." olth. b.U.ulhorlty.
. The defendant mUll give wriUen noUce to the ball authority, tho clork of court',lho dl,trlcl anornoy, Bnd tho court ball agoncy or othor designated court ball
. :ficor. of any change 01 addroas within 48 hours of tho dale of the chango.
. The del.ndant mUlt neither do, nor caula to be dono, nor permit to be done on hlalhor bohal', Gny act 'I proacrlbbd by Gectlon 4952 of tho Crimes Code
olatlng to Intimidation olwltno.... orvlcUme) or by Section 4953 (relating to ratallation agalnat wllnouel or victims). 18 Pa,C.S.H4952,4953.
The defendant mUlt rofraln f,om crimInal activity,
:VPES OF SECURITY:
:J Cash!Equlvalent 0 Gov't Bearer Bonds
oJ _ % Cash 0 Surety Bond
OTALAMOUNT BAIL SET (IF ANY): $
o Really w!in Commonwealth
o Realty outside Commonwealth
(see surelles page)
ftdK
.,GREE THAT I WILL:;~RAT ALL SUBSEQUENT PROCEEDINGS AS REQUIREO AND COMPLY WITH ALL THE CONDITIONS OF THE BAIL BONO.
'IIONOSlONEDOO :3 .1.2/
. yYlfEZ(--f'6.b ,PENNSYLV~
;..~~~.~... C3> r!f..~L .,.Y 2
~~".. ~I -
APf'EAAANCE OR BAIl. OOND
. . ,It bOnd It Italld Joth.ntIr. p'otMdll'lO' arod WlIII full and final dltpot/llon 01
, .. UN IrldudIng AI8'*"'" 01 dlr.a appHl to the S\Ipl'tme Court 01 PeMt
JOGE OR ISSUING AUTHORrrv DATE
~~~3
Pl.EA9E BEE A'1AOifD PAGED roo o\OOfllOtW.lNFORMAtlON
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plaintiff's attorney, This Order shall be enforced by any law
enforcement agency where a violation occurs by arrest for
indirect criminal contempt without warrant upon probable cause
that this Order has been violated, whether or not the violation
is committed in the presence of the police officer. In the event
that an arrest is made under this section, the defendant shall be
taken without unnecessary delay before the court that issued the
order. When that court is unavailable, the defendant shall be
taken before the appropriate district justice. (23 Pa.C.S. g
6113) .
By the Court,
/s/ ~ f! Il(t"
I I Jud
TRUE COpy FROM RECORD
In Testimony whereof, , hero unto sel my hand
and Inti seal of said Court al Carlisle, Pa.
rhls. J~~~a! O~"h."~;;, ~9~~.
Protllclnowy
Christina L, Conley,
Plaint i rr
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO.97-
CIVIL TERM
Jeff B. Conley, Sr.,
Defendant
PROTECTION FROM ABUSE
AND CUSTODY
NOTICE
You have been sued in court. If you wish to defend against the
claims set forth in the following pages, you must take action promptly
after this Petition, Order and Notice are served, by app~aring
personally or by attorney at the hearing scheduled by the Court and
presenting to the Court your defenses or objections to the claims set
forth against you. You are warned that if you fail to do so the Court
may proceed without you, and a judgment may be entered against you by
the Court without further notice for any money claimed in the Petition
or for any other claim or relief requested by the plaintiff. You may
lose money or property or other rights important to you.
FEES AND COSTS
If the case goes to hearing and the judge grants a Protection
Order, a surcharge of $25.00 will be assessed against you. You may
also be required to pay attorney fees to Legal Services, Inc, for
their representation of the plaintiff,
You should take this paper to your lawyer at once. 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.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
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.
Christina L. Conley,
Plaint iff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO,97-
CIVIL TERM
Jeff B. Conley, Sr.,
Defendant
PROTECTION FROM ABUSE
AND CUSTODY
PETITION FOR PROTECTION ORDER
AND CUSTODY
RELIEF UNDER TilE PROTECTION FROM ABUSE
ACT, 23 Pa.C.S. g 6101 et seq.
A. ABUSE
1. The plaintiff, Christina L. Conley, is an adult
individual residing at 414 Third Street, 2nd Floor, New
Cumberland, Cumberland County, Pennsylvania 17070.
2. The defendant, Jeff B, Conley, Sr., (SSN: unknown)(Date
of Birth: 6/3/59), is an adult individual residing at 414 Third
Street, 2nd Floor, New Cumberland, Cumberland County,
Pennsylvania 17070.
3. The defendant is the plaintiff's husband.
4. Since approximately 1993, the defendant has attempted
to cause and has intentionally, knowingly, or recklessly caused
bodily injury to the plaintiff, has placed the plaintiff in
reasonable fear of imminent serious bodily injury, and has
knowingly engaged in a course of conduct or repeatedly committed
acts toward the plaintiff including following the plaintiff under
circumstances which have placed the plaintiff in reasonable fear
I
of bodily injury. This has included, but is not limited to, the
following specific instances of abuse:
a, On or about March 5, 1997, the defendant
forcefully pulled the plaintiff out of bed, dragged her
by the hair across the carpet bruising her legs and
arms, and causing areas of swelling on her head. He
then grabbed her by the elbows forcing her to go into
the kitchen and blocked the doorway so that she could
not leave the room causing her to fear for her safety.
As the defendant screamed at the plaintiff calling her
vile names, he shoved her out the kitchen door into the
cold with just a shirt and her underwear on and closed
the door refusing to let her back in the house. The
police responded to the defendant's 911 call, saw the
plaintiff's injuries, and arrested the defendant for
simple assault.
b, On or about December 18, 1996, the defendant
forcefully grabbed the plaintiff's ears shaking her
head from side to side causing a laceration on her left
ear. When the police responded to the defendant's 911
call, they saw that the plaintiff was bleeding and
charged the defendant with harassment,
c. In or about the summer of 1996, the defendant
pulled the plaintiff's hair, pushed her, twisted her
arm up behind her back. and threatened to break it
2
causing pain,
d, On or about April 5, 1996, the defendant blocked a
door refusing to allow the plaintiff to leave causing
her to fear for her safety. The plaintiff escaped with
her son through a bedroom window and got into her car
with the defendant following them. When the car
stalled, the defendant approached the vehicle, grabbed
the plaintiff by her arms and hair, and dragged her out
of the car. The defendant forcefully pushed the
plaintiff's head into the hood of the car and punched
her in the head.
e. On several different occasions since 1993, the
defendant has thrown several objects at the plaintiff;
punched, kicked, and restrained her, and pulled her
hair,
5, The plaintiff believes and therefore avers that she is
in immediate and present danger of abuse from the defendant and
that she is in need of protection from such abuse.
6. The plaintiff desires that the defendant be enjoined
from harassing and stalking the plaintiff,
7. The plaintiff desires that the defendant be restrained
from entering her place of employment,
8. The plaintiff desires that the defendant be enjoined
from removing, damaging, destroying or selling any property owned
jointly by the parties or owned solely by the plaintiff.
3
B. REIMBURSEMENT FOR COST OF CASE
9. The plaintiff asks that the defendant be ordered to pay
$250.00 to reimburse one of Legal Services, Inc.'s funding
sources for the cost of litigating this case,
WHEREFORE, pursuant to the provisions of the "Protection
from Abuse Act" of October 7, 1976, 23 Pa.C,S. g 6101 tl J!.!l.!l" as
amended, the plaintiff prays this Honorable Court to grant the
following relief:
A. Grant a Temporary Order pursuant to the
"Protection from Abuse Act:"
1, Ordering the defendant to refrain from
abusing the plaintiff and placing her in fear of
abuse,
2, Ordering the defendant to refrain from
harassing and stalking the plaintiff.
3, Prohibiting the defendant from entering the
piaintiff's place of employment.
4, Prohibiting the defendant from removing,
damaging, destroying or selling property jointly
owned by the parties or owned solely by the
plaintiff.
B. Schedule a hearing in accordance with the
provisions of the "Protection from Abuse Act," and,
after such hearing, enter an order to be in effect for
a period of one year:
4
J, Ordering the defendant to refrain from
abusing the plaintiff and placing her in fear of
abuse,
2. Ordering the defendant to refrain from
harassing and stalking the plaintiff.
J, Prohibiting the defendant from entering the
plaintiff's place of employment.
4. Prohibiting the defendant from removing,
damaging, destroying or selling property jointly
owned by the parties or owned solely by the
plaintiff,
5, Ordering the defendant to pay $250.00 to
reimburse one of Legal Services, lnc.'s funding
sources for the cost of litigating this case.
The plaintiff further asks that this Petition be filed and
served without payment of fees and costs by the plaintiff,
pending a further order at the hearing, and that certified copies
of this Petition and Order be delivered to the New Cumberland and
Fairview Township Police Departments which has jurisdiction to
enforce this Order.
5
The plaintiff prays for such other relief as may be just and
proper.
Respectfully submitted,
for Plaintiff
LEGAL SERVICES, INC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
6
CRIMINAL COMPlAINT
Charlos A. CleCQnt~ Jr.
DI&mICT Ju:mCE
MAGISTERIAL DISTRICT NO. 09-1-01
1106 Carlisle Road
Ca~ n111. PA 17011
Complaint Numb.rall Oth.r Participants
A39540
I, nff'trM' Ui11tA" r. tl~I\)'''''. 1?r,
(~mflijAD1/Jnl)
NAME
AND
ADDRESS
COMMONWEALTH OF PENNSYLVANIA
DEFENDANT: VS.
r
Joff B. Conloy
414 3rd St.. 2nd floor
IIev Cu:uberlond. PA 17070
.
I
,
of the flew Cur1berland Police Dcpart""nt
AS,A,
AKA
1J/fl/37 DOS 6/4/59
55 194-52-4259
do hereby state:
(I) g I accuse the above named defendant, who lives at the address set forth IIhove or,
~ LI I accuse an individual whose name is unknown to me but who is described liS
~
I
~
~
o his nickname or popular designation is unknown to me IInd. therefore. I hllve designated him herein as John
Doc; with violating the penal laws of the Commonwealth of I'ellnsylvllnia at 414 1rd "t. 'nd floor
flew Cur.lberland (/'WCt.l\i/li1cu'SubJ/fI,l"n) ·
in CUMberlnnd County on or about 3/31197 to 4/3/97
Participants were (if that ij'trt'pdrtlc/ptJfltJ, plllt'f ,/'t1rnamrJ hrrr. fI'pt'a/lllg IItl!namtllfabon'JrftlldlJ/ll):
(2) -d!~ttP~o~Il1~~t~~ by the accused were: 0 Court Order tlo. 97-1631 Clvll Tera
TIle defendant WAS In violation of Oadgt DoeEer97-1GJ1 Civil Tora slgr~d by Judge GeoroQ
E. Hoffer which tlo1S Issued on 3/31/97 In Curabor1anrl County under the Protect1on frOl:l XbuSQ
Statute. In thilt ardor tho defcndilnt liAS enjoined frop dostroying or daJ:lllglng any property
Olfood by tho plaintiff, Chr1stlna L. Conley, lloon9 other Issued addressed. During thl! thllC
after thl! cl:Ifondant Has served with the order ilnd nprtl 3, 1997 the v1ct1I:l, chr1st1na L.
Conley. alleges that three clothing Iteos lrore dllf1Jgcd.ln violation of sa1d order,
all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of Assembly,
or in violation of C1"01...'M.'.... , and, of the Act of .' '
JyStrt/on) (Sub-JN't/on)
or the E~3~~:'::;'/,~::':~'.:' :...;._'
Ordinance of
( f\,lir/ruJ Sub. dMJlon)
(3) I ask that a warrant of arrest or a summons be issued and that the accused be required to answer the charges
I have made.
(4) I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information
and belief. This verification is made subject to the penalties of Section 4904 of the Crimes Code (18 I'a. C. S.
~ 4904) relating to unsworn falsification to authorities,
flprll Jrd
.19 <;)7
(SIKnalll~ III CIIf"pla/nant)
AND NOW, on this date , 19 . 1 certify the complaint has been propcrly completed and
verified. and that there is probable'caUse for issuance of process.
"
; " ,.' I"~ .. .'.
(Mugultrlal DUITlc/)-
(IHllinJ: Autlwril)')
(SEAL)
-- ~ ~
WARRANT
RET1JRN WHERE DEFENDANT IS FOUND
4-:}
""'LL! rc.d/-(
~lcrclUllllIl Ulul 11":-/1'1.... jot, !lUW;
19~.1 arresled
all
To any authorized pcr~lln: PurSUlt1l1 In thi.. wnrrunl.
you arc ommanded to arrest
D al liberty 011 bail, posted before
D in the
'iZll1efore
4~
jail.
defendant. if found in lhe Commonwe"lth of
l'ennsylvlInia and bring him/her bef,; the
undersigned at the above tl ress to answer the i~,rcgoing
Complaint. /'
(
(SIJ:lltJtlIft)
I/; l7,k./}-L.I
, (nt/t)
RET1JRN WHERE DEFENDANT IS NOT FOUND
fter careful search, I cllnnol find the named defendant.
--0
(SIKmJtllftJ
(17/lt)
COMMONWEALTH
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V,
TERM & NO,
1997-51631
/
JEFF B CONLEY SR
CHARGE:
CASE TRANSFERRED
FROM CIVIL DIVISION
OTN: AFFIANT:
IN RE: RULE TO SHOW CAUSE
ORDER OF COURT
AND NOW, June 25, 1997,
in consideration of the attached
petition, the court issues a Rule to Show Cause on the defendant why
he should not be adjudged in contempt of court for failing to pay the
sums set forth in the petition,
The Rule is returnable and the hearing shall be held on
July 11, 1997
at 9:30 AM in Courtroom No, 4,
of the
Cumberland County Courthouse, Carlisle, Pennsylvania.
Service of the petition to be made on the defendant by Certified
Mail, Return Receipt Requested and by regular mail.
<-
c;
By the Court,
j./ljjfJ'f-e, l
/'.,'
._,'
f"
c..r:)
_i
District Attorney's Office
Public Defender's Office
Probation Office
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CH-f\to"lIl'EAI:r'1 OF Ill:"lNA.
I"l TilE COIlRT OF CHIW)'Ij "LEA."
vs
O~,"\',RIA"ln C:cJ'NIY, flINIM.
I, Will iam !liehl, Icputy Sheri ff heing duly s\;om hy law says; that on ,July 25 19!17 the
above named suhj ect \;as arrested hy the New CtU1~)erl and !loro. Police I\')pl. on these warrant s.
Suhject I;as ahle to pay all nunies O\;ed and \;as released from custody hy l\;putv r,osscrl.
Sheriff Costs: 40 miles @ .3l~ per mile $12,40
So NIS\,'Crs;
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R, Thomas '(line, S~eri ff
by ___W~~jJ--.
1- ..' ",<\1 ,- '.~ ,,,,..,. . v't". :\l.""" 1I'i1 !iarn nichl, fCfluty
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***r~[luty r.ossert also c;ollected:.for Cines owed to JlJ Farner and Ilarrishurg City Police,
Copies of those receipts arc attached, Tne IOClney \;a5 disseminated by Icputy !laker and~
and f);)puty Kell on the 28th day of .July 1997, "I
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dCl;;f: d7-97-rzl'
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
CASE NO,:
1997-51631
NON PAYMENT
CHARGE. . :
CASE TRANSFERRED
FROM CIVIL DIVISION
AFFIANT. :
OTN..... :
TO: , Sheriff, or any duly authorized law enforcement officer.
RE: JEFF B CONLEY SR
414 THIRD ST 2ND FLOOR
NEW CUMBERLAND PA 17070
DOB:
SEX:
HT:
EYES:
6/04/1959 SSN: 000-00-0000
RACE:
WT:
HAIR:
FBIt:
SIDII:
WHEREAS, JEFF B CONLEY SR failed to: APPEAR AS
REQUIRED BEFORE JUDGE HESS FOR NON PAYMENT OF FINES AND COSTS
and,
WHEREAS, this Court on 7/11/1997 directed a Bench Warrant be issued
for the apprehension of the defendant.
This is therefore to command you to arrest the defendant above and
bring Mr. CONLEY before me at Carlisle, PennDylvania, without
unnecessary delay to be dealt with according to law.
WITNESS the undersigned Clerk of Courts, at Carlisle, this the 16th
day of July A.D., 1997.
~
ATTEST:
JUL 16 1997
Date
ORIGINAL
(SEAL)
----------------------------------------------------------------------
(X) EXTRADITION - NOT APPLICABLE
( ) EXTRADITION APPROVAL - Any state, adjoining states, this state, or
within 0 miles of Carlisle.
DISTRICT ATTORNEY/ASS'T.
{ Pho\i'q>IH' t, ~l\ :; ~Wil d
T" ".,'1.."
~, :'. I :. '.}, J
DATE
{ i~t "J ~'S}l H 'Wf
132.54
AMOUNT OWED, IF APPLICABLE
{ Ava~~QB~l,;J()~iZill