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Ethia M. Stover,
Plaint i ff
and on behalf of the minor
child: Trevor A. Stover
tN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-/~59clVIL TERM
v.
PROTE~rION FROM ABUSE
AND rUSTODY
Garrett A. Forsythe,
Defendant
TEMPORARY PROTECT ION ORDER
AND NOW, this
/ I II
day of April, 1997, upon presentation
and consideration of the within Petition, and upon finding that
the plaintiff, Ethia M. Stover, and the minor child, Trevor A.
Stover, now residing at 25 Pnrk Street, loll. lIolly Springs,
Cumberland County, Pennsylvania, are in immediate and present
danger of abuse from the defendant, Garrett A. Forsythe, the
foltowing Temporary Order is entered.
The defendant, Gnrrett A. Forsythe, (SSN: 175-58-1981 and
date of birth: 2/8/751 now residing at 395 Center Mills Rond,
Aspers, Adams County, Pennsylvania, is hereby enjoined from
physically abusing the plaintiff, Ethia M. Stover, and the minor
child, Trevor A. Stover, or placing either of them in fear of
abuse.
The defendant is ordered to stny away from the plaintiff's
residence located at 25 Park Street, Mt. Holly Springs,
Cumberland County, Pennsylvania, which is not owned or teased by
the defendant, and any other residence the plaintiff may
establish, except for the limited purpose of trnnsferring custody
of the parties' child. The defendant shatl remain in his vehicte
at all times during the transfer of custody.
The defendant is ordered to refrain from having any direct
or indirect contact with the plaintiff or the minor child
including, but not limited to, telephone and written
communications, except for the limited purpose of facilitating
custody arrangements.
The defendant is enjoined from harassing and stalking the
plaintiff and from harassing the plaintiff's relatives, or the
minor child.
The defendant is enjoined from entering the plaintiff's
place of employment and the day care facility of the minor child.
The defendant is enjoined from removing, damaging,
destroying or selling any property owned solely by the plaintiff.
A violation of this Order may subject the defendant to: i)
arrest under 23 Pa.C.S. g6113; ii) a private criminal complaint
under 23 Pa.C.S. g6tI3.1; iii) a charge of indirect criminal
contempt under 23 Pa.C.S. g6I14, 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. g61I4.1. Resumption of co-residence on
the part of the plaintiff and defendant shall not nullify the
provisions of the court order.
This Order shall remain in effect until modified or
terminated by the Court and can be extended beyond its original
expiration date if the Court finds that 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.
Temporary custody of Trevor A. Stover is hereby awarded to
the plaint iff, Ethia M. Stover.
A head ng sha II be held on this matter on the /1/ rU day of
,
Apd I, 1997, at J' 1 ~ v:> .m. , in Courtroom No.2-, Cumberland
/
County Courthouse. Carlisle, Pennsylvania.
The plaintiff may proceed without pre-payment of fees
pending a further order after the hearing.
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
Prothonotary shall not send a copy of this order to the defendant
by mai I.
The Pennsylvania State, Mt. Holly Springs, and the Carlisle
Police Departments will be provided with certified copies of this
Order by the 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. 6 6113).
By the Cou r,v;
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Ethia M. Stover,
Plaint i ff
and on behalf of the minor
child: Trevor A. Stover
IN TilE COURT 01' COMMON PLEAS 01'
CUMBERLAND COUNTY, PENNSYLVANIA
NO . 97-
CIVIL TERM
v.
Garrett A. Forsythe,
Defendant
PROTECTION FROM ABUSE
AND CUSTODY
NOT I C g
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 t70lJ
TELEPHONE NUMBER: (7t7) 240-6200
AMERICANS WITII DISABILITIES ACT 01' 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. AI I 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.
Ethia M. Stover,
Plaintiff
and on behalf of the minor
child: Trevor A. Stover
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-1~6'1cIVIL TERM
v.
Garrett A. Forsythe,
Defendant
PROTECTION FROM ABUSE
AND CUSTODY
PETITION FOR PROTECTION ORDER
AND CUSTODY
RELIEF UNDER THE PROTECTION FROM ABUSE
ACT, 23 Pa.C.S. g 6101 et seq.
A. ABUSE
1. The plaint iff, Ethia M. Stover, is an adul t individual
residing at 25 Park Street, Mt. Holly Springs, Cumberland County,
Pennsylvania 17065.
2. The defendant, Garrett A. Forsythe, (SSN: 175-58-
1981)(Date of Birth: 2/8/75), is an adult individual residing at
395 Center Mills Road, Aspers, Adams County, Pennsylvania, 17304.
3. The defendant has had an intimate relationship with the
plaintiff.
4. Since approximately 1996, the defendant has attempted
to cause and has intentionally, knowingly, or recklessly caused
bodily injury to the plaintiff and the minor child, has placed
the plaintiff and the minor child in reasonable fear of imminent
serious bodily injury, and has knowingly engaged in a course of
conduct or repeatedly committed acts toward the plaintiff and the
minor child including following the plaintiff without proper
authorization, under circumstances which have placed the
plaintiff in reasonable fear of bodily injury. This has
included, but is not I imi ted to, the following speci fic instllnces
of abuse:
a. On or about April 3, 1997, the defcndant grabhcd
the plaintiff by thc arm and scrcamed at her calling
her vile names, slapped in her fllce causing a bruise on
her cheek, and pushed her head into the couch. During
this incident, thc defendant pushed the minor child
causing the plllintiff to fear for the child's safety.
b. On or about March 28, 1997, the defendant pushed
the plaintiff into a wall with such force that he
caused an indentation in the wall and blocked the
plaintiff from leaving the area causing her to fear for
her safety.
c. On or about March 27, 1997, the defendant smacked
the minor child in the face leaving a hand print on the
side of his face.
d. On or about the week of March 24, 1997, the
defendant kicked the plaintiff in the shin causing a
bruise and pushed her causing her to fear for her
safety.
e. On or about January 1997, the defendant punched
the plaintiff in the shoulder and threw her across the
floor causing her to fall and causing bruising on her
knee.
L On several occasions since 1996, the defendant has
pushed and shoved the minor child causing him to fall,
slapped the child, and hit the child with a vacuum
hose, wooden paddle, and plastic bat causing bruises.
Approximately once a wcek, the dcfendant would not
allow the child to eat supper causing the plaintiff to
fear for the child's well-being.
g. On several occasions since 1996, the defendant has
pushed, shoved, slapped, restrained, and kicked the
plaintiff. The defendant has punched the plaintiff
several times causing bruises. The defendant becomes
enraged and beats the family dog with his fists, a bat,
and a board. The defendant has kicked and thrown the
family cat against the wall causing the plaintiff to
fear for her safety.
5. The plaintiff belicves and therefore avers that she and
the minor child are in immediate and present danger of abuse from
the defendant and that they are in need of protection from such
abuse.
6. The plaintiff desires that the defendant be prohibited
from having any direct or indirect contact with the plaintiff or
the minor child including, but not limited to, telephone and
written communications, except for the limited purpose of
facilitating custody arrangements.
7. The plaintiff desires that the defendant be enj0ined
from harassing and stalking the plaintiff, and from harassing the
plaintiff's relatives, or the minor child.
8. The plaintiff desires that the defendant be restrained
B. EXCLUSIVE POSSESSION
from entering her place of employment and day care faci lity of
the minor child.
9. Thc plaintiff dcsircs that the defendant be enjoined
from removing, damaging, dcstroylng or sclling any property owned
jointly by the parties or owned solcly by the plaintiff.
10. The mobile home which the plaintiff is asking the Court
to order the defendant to stay away from is not owned or rented
in the dcfendant's name.
II. The dcfendant has his own residence located at 395
C. SUPPORT
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Center Mills Road, Aspers, Pennsylvania.
12. The defendant has a duty to support the minor child.
13. The plaintiff is in need of financial support from the
defendant including, but not limited to: health insurance
coverage for the minor child.
14. The defendant is employed at Tuckey's Mechanicals, and
has unnuul salary of $19,200.
15. The plaintiff currently has no income.
16. The plaintiff intends to pctltion for support within
two weeks of the issuance of a protective order.
D. REIMBURSEMENT FOR COST OF CASE
17. Thc plaintiff asks that the defendant be ordered to pay
the child.
WHEREFORE, pursuant to the provisions of the "Protcction
from Abuse Act" of Octobcr 7, 1976, 23 Pa.C.S. ft 6101 tl gg., as
amended, the plaintiff prays this Honorable Court to grant thc
following reI ief:
A. Grant a Temporary Order pursuant to the
"Protection from Abuse Act:"
I. Ordering the defendant to refrain from
abusing the plaintiff and the minor child or
placing them in fear of abuse.
2. Ordering the defendant to refrain from having
any direct or indirect contact with the plaintiff
or the minor child including, but not limited to,
telephone and written communications, except to
facilitate custody arrangements.
3. Ordering the defendant to refrain from
harassing and stalking the plaintiff and from
harassing the plaintiff's relatives and the minor
ch i I d.
4. Prohibiting the defendant from entering the
plaintiff's place of employment and the day care
facility of the minor child.
5. Prohibiting the defendant from removing,
damaging, destroying or selling property jointly
owned by the parties or owned solely by the
plaint i ff.
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6. Ordering the defendant to stay away from the
7. Granting temporary custody of the minor child
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plaintiff's residcnce located at 25 Park Street,
Mt. Holly Springs, Cumbcrland County,
Pennsylvania, and any other residence the
plaintiff may establish, except for the limited
purpose of transferring custody of the parties'
child. Thc defendant shall remain in his vehicle
at all times during the transfer of custody.
to the plaintiff.
B. Schedule a hearing in accordance with thc provisions of
the "Protection from Abuse Act," and, after such hearing, enter
an order to be in effect for a period of one year:
I. Ordering the defendant to refrain from
abusing thc plaintiff and the minor child or
placing thcm in fear of abuse.
2. Ordering the dcfcndant to refrain from having
any direct or indirect contact with the plaintiff
or the minor child including, but not limited to,
telephone and writtcn communications, except to
facilitlltc custody arrangements.
3. Ordering the defcndant to refrain from
harllssing and stalking the plaintiff and from
harassing thc plaintiff's rclatlves and the minor
ch i I d.
4. Prohibiting the dcfendant from entering the
plaintiff's place of employment and the day care
faci II ty of the minor chi Id.
5. Prohibiting the defendant from removing,
damaging, destroying or selling property jointly
owned by the parties or owned solely by the
plaint iff.
6. Ordering the defendant to stay away from the
plaintiff's residence located at 25 Park Street,
Mt. Holly Springs, Cumberland County,
Pennsylvania, and any other residence the
plaintiff may establish, except for the limited
purpose of transferring custody of the parties'
children. The defendant shall remain in his
vehicle at all times during the transfer of
custody.
7. Granting support to the minor child in an
appropriate amount according to the support
guidelines payable to the plaintiff in the form of
a check or money order, mailed to her residence,
and ordering the defendant to provide health
coverage to the minor child.
8. 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 rnd
served without payment of fees and costs by the plaintiff,
.,.
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97
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In The Court of Common Pleas of Cumberland County, Pennsylvania
"Ethla M. Stover et al
VS.
Garrett A. Forsythe
No.97-1859 Civil Term
19_
Now, Apr. 10.
Adams
199719_,1 SHERIFF OF CUMBERLAND COUNTY, PA do hereby deputize theSherllTof
County 10 execule Ihls Wrll, Ihls depulollon being mode atlbe request and risk oflhe PlolnlllT.
r~~t"~
SherllTofCumherlond Counl)', Po.
Affidavit of Service
Now, April 14 , 1997, at
within Petition For Protection Order & Custody, and Temporarv
upon Garrett A. Forsythe
at 395 Center Mills Road, Aspers, PA
by hondlog to him
attested copy oflhe original Petition & Temoorarv Order
him Ihe conlents Ihereof.
o'clock
Protection Order
M, served the
o true and
ond mode known 10
So answerst
!3.a",A/tL Z{ J1t~
SherllTof Adams County, Po.
COSTS
Sworn and subscribed before
me this day of N/ A
19_
SERVICE
MILEAGE
AFFIDAVIT
s
S No Charge
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SliER (n" I; Ilf-:'i'IJRtI - IJU r Uf CiJl/NTY
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CI)IItlTY I)t' CUtIHI.:R1.AlW
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YS.
fIJRSYTllf-: GARRETT A
R. Thomas Kline
. Sheriff, who
being duly sworn accord1ng
and inquiry for the within
to law. sa>'s. that he made a di11gent search
roaMed defendant, to wit: fiJRSYTI!f-: I;A!,RETT A
but was unabl~ to locate
Him
in his bailiwick. lie therofore
deputi:ed th~ sheriff of ADAMS CUUNTY
til serve .the within I'RI)TI':CT(IJU fRllM AI3IJSf-:
_ County. Pennsylvania.
Un Apri.1.
[f-:ith,
['J.,"
. this o1fice was in
recc>ipt ot
Pennsylvania.
the attached return from
^DAMi-> CIJIJNTY
County.
:-5hr:riff's Co~t.s:
l'i'JI=~:Ot too
f.Iut of Cc..unty
~.;urcharge
l~.00
9.00
2.00
$/':1. 00
00/00/0000
I::-..."rn <<noJ subscribed to befo:-e me
t h:z Ii T2- day of ().It...:P
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Prothonotary . 7
In The Court of Common Pleas of Cumberland County, Pennsylvania
Ethia M. Stover et al
vs.
Garrett A. Forsythe
No.97-1859 Civil Term
19_
Now, Apr. 10.
Adams
199719_, I SHERIFF OF CUMBERLAND COUNTY, PA do hereby depullze lhe Sheriff of
County 10 execule Ihls Wrll,lhls depulatlon being made allhe requesl and risk oflhe Plaintiff.
r~t!~
Sheriff of Cumberland County, Pa,
Affidavit of Service
Now, April 14, 1997 , at o'clock
within Petition For Protection Order & Custody, and Temporary Protection Order
upon Garrett A. Forsythe
at 395 Center Mills Road, Aspers, PA
by banding 10 him
attested copy of the original Peti tion & Temporarv Order
him lhe contents lhereof.
M, served tbe
a true and
and mode known to
So answerst
1UMt~ 2{ $~
Sheriff of
Adams
County, Po.
COSTS
SWorn and subscrihed before
me this day of N/ A
19_
SERVICE
MILEAGE
AFFIDA VIT
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Ethia M. Stover,
Plaintiff
and on bchalf of the minor
child: Trevor A. Stover
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-1859 CIVIL TERM
v.
Garrett A. Forsythe,
Defcndant
PROTECTION FROM ABUSE
AND CUSTODY
MOTION FOR CONTINUANCE
The plaintiff moves thc Court for an Order continuing
generally the hearing in the above-captioned casc on the grounds
that:
I. A Temporary Protection Order was issued by this Court
on April 9,1997, scheduling a hearing for April 16, 1997, at
3:00 p.m.
2. The Cumberland County Sheriff's Departmcnt sent the
Temporary Protection Order and Petition to thc Adams County
Sheriff's Department and deputized thcm to scrve the defendant.
The Adams County Sheriff's Department served the defendant with a
certified copy of the Temporary Protection Order and Petition for
Protection Order on Apri I 14, 1997, at 395 Center Mill Road,
Aspers, Adams County, Pennsylvania.
3. The parties agree that the hearing be generally
continued to afford them time to execute a Consent Agreement.
4. The plaintiff requests that the Temporary Protection
Ordcr remain in effect until modified or terminated by the court
after notice or hearing.
5. Certified copies of the Order for Continuance will be
delivercd to the Pennsylvania State, Mount Holly Springs, and
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cumberlund County, Pennsylvllnia, und any other residencc the
plaint iff may cstubl ish. except for the I imi ted purpose of
transferring custody during which times the defendunt shull
rcmuin in his vchiclc.
7. Thc defendllnt is ordcred to puy interim support to the
minor child thc amount of $82.00 pcr week, payable to the
plaintiff in thc form of a check or money order, by muil pcnding
the cntry of an order by the Cumbcrland County Domestic Relations
Officc. Thc first pllymcnt is to be mlldc within ten dllYs of thc
entry of thc Protection Ordcr. and payments shall be made every
Friday thereafter. The defendant further agrees to provide
health coverage to the minor child.
8. The court costs and fccs arc waived.
9. This Order shall remain in cffect for a period of onc
year or until modified or tcrminated by the Court. The Order can
be extended bcyond its originlll expirlltion date if the Court
finds thllt the dcfcndllnt has committcd another act of abuse or
has engagcd in a pattcrn or practice that indicates continued
risk of harm to the plaintiff.
10. A violation of this Ordcr may subject the defendant to:
i) lIrrest under 23 Pa.C.S. ~61IJ: ii) a private criminal
complllint under 23 Pa.C.S. g6113.1: iii) a charge of indirect
criminul contempt under 23 Pa.C.S. ~6114, punishable by
imprisonment up to six months and a fine of 5100.00-$1,000.00;
lInd iv) civil contempt under 23 Pll.C.S. g61I4.1. Resumption of
co-residcnce on the purt of the plaintiff and defcndant shall not
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nullify the provisions of the court order.
11. The Pennsylvania State. Mount Holly Springs, and
Carlisle Police Departments shall be provided with ccrtiried
copies of this Ordcr hy thc plaintiff's attorney and lIlay enforcc
this Order by arrest for indirect criminal contempt without
warrant upon probablc clluse that this Ordcr has been violated.
whether or not the violation is committed in the prescncc of a
pol icc officer. In the cvent that an arrest is madc undcr this
section, the dcfendant shal I he taken without unnecessary delay
beforc thc court that issued thc ordcr. When that court is
unavailable. the defendant shal I be taken before the appropriate
district justice. (23 PIl.C.S. ~ 6113).
Joan Carey
Attorney for Plaintiff
udge
Garrett A. Forsythc
Pro Se
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.S.p.
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Ethia M. Stover.
Pill i n t iff
and on behalf of the minor
chi Id: Trcvor A. Stover
I N TilE COUWI' OF COMMON PI.I,AS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-1859 CIVIL TERM
v.
Garrett A. For~ythe,
Defendllnt
PROTECTION FROM ABUSE
AND CUSTODY
AA.TODY ORDER
AND NOW, this _~ :11l)l of Apri I, 1997, upon consideration
of the partics' Con~ent Agreemcnt, the fol lowing Order is entered
with regard to custody of the purties' chi ld, Trevor A. Stover,
(DOB 3/9/95).
1. The pluintiff, hereinafter referred to liS the mother,
and the defendunt, hcreinafter refcrred to liS the father, ~hall
share legal cu~tody of the child.
2. The mother shull havc primury physicul of the chi Id.
3. The futher shllll have supervised visitution at his
mother's house and in hcr presence every other weekend from
Friday at 6:00 p.m. unti I Sunduy at 6:00 p.m. und lit other times
agrecd upon by thc mother and father.
4. The father shull have supervi~ed visitation from 3:00
p.m. unti I 6:00 p.m. on the following hol idays: Easter, Memorial
Day, the Fourth of July, Labor Day, ond Thanksgiving.
5. The mother shall have the child on Christmas Eve at
6:00 p.m. until Christmas Day lit 12:00 p.m. ond the father shull
have the chi Id from Chri~tmas Day ot 12:00 p.m. until Christmas
Duy ut 6:00 p.m.
6. The fllther ~hall huve the right to sce the child on his
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birthday at a time to hc agrced upon by the mother and father.
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7. The fathcr's supcrvised visitation shall be expanded to
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include periods of parl ial custody, by agreemcnt of the mother
and father, conditioncd upon his cntering and completing the
Adams County PEACE program" Your Child from Birth to Four"
which mects at the Old Meadc School, 75 Spring Avenue,
Gettysburg, Pennsylvania. The father shall provide the mothcr
and her counsel vcrification of his attcndance and completion of
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the program.
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8. Thc mother and father. by mutual agreement, may vary
from this schedulc at any time, but the Order shall remain in
effect unt i I furthcr order of courl.
10. Neither party shal I do anything which may estrange the
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9. The mothcr and father agree that each shall notify the
other immediately of medical emcrgencies which arise while the
chi Id is in that parent's care.
child from the other parent, or injurc the opinion of the child
as to the other parent or which may hampcr the free and natural
development of the child's love or respect for the other parent.
Dy the Court,
Joan Carey
Attorncy for Plaintiff
Garrett A. Forsythe
Pro Se
'-'ot"::'... ,">'"...l,,( '1-1.<"/97, .
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Ethill M. Stover.
Plllintiff
lInd on behnlf of the minor
chi Id: Trevor A. Stover
I N TilE COlJlr1' OF COM~ON PLEAS OF
ClJMIIEIU.AND COlJNT\', PENNSYLVAN J A
NO. 97-lHSC) CIVIL TEHM
v.
Garrett A. Forsythe.
Defendnnt
PIWTECT I ON FllOM AllOSE
AND CUSTODY
~Ot-llWt:!L6.GRIU::Mmn
_.....\~\
This Agrcement is cntcred on this ~
day of April, 1997.
by the plaintiff, Ethia M. Stovcr. lInd the defendant, Garrett A.
Forsythc. The plllintiff is represented by JOlin Carey of LEGAL
SERVICES, INC.; the dcfcndant is unreprcsented but is aware of
his right to hllvc an attorney. The parties lIgrcc that the
following may bc entercd as an Order of Court.
I. The defendant, Garrett A. Forsythc, agrees to refrain
from abusing the plaintiff, Ethia M. Stover, and the minor child,
Trevor A. Stover, or placing thcm in fcar of abuse.
2. Thc dcfendant agrees not to have any direct or indirect
contact with the plaintiff including, but not limited to,
telephone and writtcn co~nunications, except for the limited
purposc of facilitllting custody lIrrangemcnts.
J. The dcfendllnt agrecs not to harass and stalk the
plaintiff and not to harllss thc plaintiff's relatives.
4. Thc dcfendant lIgrees not to entcr the plaintiff's place
of cmployment or day care facility of the minor child.
5. The defendant agrces not to remove, damage, destroy, or
sell Ilny property owncd by the plaintiff.
6. Thc defendant agrees to stllY away from the plaintiff's
rcsidence located at 25 Park Strcct. Mount Holly Springs,
Cumberland County, Pcnnsylvania. and any othcr residence the
plaint i ff may establ ish, exccpt for the I imi tcd purposc of
transferring custody. The defcndant shall remain in his vehiclc
at all timcs during the transfer of custody.
7. The dcfcndant agrces to pay interim support to the
minor child in thc amount of $82.00 pcr wcek, payable to the
plaintiff in thc form of a check or money order. by mail pending
thc entry of an order by the Cumberland County Domestic Relations
Office. The first payment is to be made within ten days of the
entry of the Protection Order, and payments shall be made evcry
Friday thereafter. The defendant further agrees to providc
health coveragc to the minor child.
8. The dcfendant agrees to attend, participate in, and
successfully completc an eight week course for parenting skills
entitled. Your Child Prom Birth to Four. offcred by the PEACE
program of Adams County. The defendant agrees to register in the
program immediately upon entry of the Protection Order and
verification of the defcndant's successful completion of the
program shall be provided to the plaintiff and the plaintiff's
attorney by the dcfendant and/or the PEACE program.
9. Thc dcfendant, although entering into this Agreement,
does not admit the allegations madc in thc Petition.
10. The defendant understands that the Protection Order
entered in this mattcr wi II bc in effect for a period of one year
and can be extendcd beyond it 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. The defendant understands that
this Order wi II he l!lIforceahle in the same manner liS the Court's
prior Temporary Protection order entered in this case.
II. Violation of the Protection Order may subject the
defendant to: i) arrest under 23 Pa.e.s. g6113; ii) a private
criminal complaint under 23 Pa.C.S. g61l3.1; 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. ~6l14.1.
12. Thc defendant and the plaintiff Ilgree to the cntry of
an Order providing for the following regarding custody of their
chi ld, Trevor A. Stover.
a. The mothcr and fathcr shall share legal custody of
the chi Id.
b. The mother shall have primary physical custody.
c. The father shall have supervised visitation at his
mother's house ond in hl!r presence every other weekend
from Friday at 6:00 p.m. unti I Sunday at 6:00 p.m. and
at other times agrced upon by the mother and father.
d. The father sholl have supervised visitation from
3:00 p.m. until 6:00 p.m. on the following holidays:
Eastcr, Memorial Day, the Fourth of July, Labor Day,
and Thanksgiving.
e. The mother shall hove the child on Christmas Eve
at 6:00 p.m. until Christmas Day at 12:00 p.m. and the
fathcr shall havc thc chi Id from Christmas Day at 12:00
p.m. until Christmas Day at 6:00 p.m.
f. Thc father sha 11 havc the right to see the child
on his birthday at e time to be agreed upon by thc
mother and fathcr.
g. The father's supervised visitation shall be
expanded to include periods of partial custody, by
agreemcnt of the mother and father, conditioned upon
his entering and completing the Adams County PEACE
program" Your Child from Birth to Four" which meets
at the Old Mcade School on Spring Avenue, Gettysburg,
Pennsylvania. The fathcr shall provide the mother and
her counsel verification of his attcndance and
completion of the program.
h. The mother and father, by mutual agreement, may
vary from this schedule at any time, but the Order
shall remain in effect until further order of court.
i. The parent who has the child shall provide for the
child's transportation to thc other parent for that
parent's period of custody or visitation.
j. The mother and father agree that each shall notify
the other immediately of medical emergencies which
arise whi Ie the chi Id is in that parcnt's care.
k. Thc mothcr and father realize that their child's
well being is pllramount to any differences they might
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Ethill M. Stover,
Plaintiff
and on behalf of thc minor
child: Trcvor A. Stovcr
IN TilE COURT OF COMMON PLEAS OF
..,
1997, I did personlllly scrve upon the dcfendllnt, Gllrrett A. Forsythe,
ClJ~lBERLANIl COUNTY, PENNSYI.VAN I A
NO. Q7-IHSq CIVIL TERM
v.
Garrett A. Forsythc.
Dcfendllnl
PllOTECT I ON FllOM ABUS E
ANn ClJSTOIlY
CERTIFICATE OF SERVICE
I, Jennifer L. Gutshall, do hcrcby ccrtify that on April 22,
in the above-captioned mattcr /In Order for Continuance at the
Cumbcrland County Courthousc, Cllrlisle, Cumberland County,
Pennsylvania.
L\-d-~-<1l
Date
~wvvJ<--- ~. ~~
Jennifer L. Gutshall. Paralegal
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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