HomeMy WebLinkAbout97-02227
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Oiane I.. Stahl,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
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CUMBERLAND COUNTY, PENNSYLVANIA
NO, 97-2227 CIVIL TERM
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Jack T. Stahl,
Defendant
PROTECTION FROM ABUSE
ANO CUSTODY
PROTECTION ORDER
~~ .~........:;~y of ..M:~~! ,~~~.:,T.~~~.~.-:!.~~i~n, Q.f
th.<,~:.~..~_t,t'''6'l'''t~~~~~~J'::l~'~t~t;o'rae~.~1t-
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1, T~~efendant, Jack T. Stahl, is enjoined from
physically abusing the plaintiff, Diane L. Stahl, or from placing
her in fear of abuse.
2, ~ ~efendant is ordered not to have any direct or
indirect contact with the plaintiff including, but not limited
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to, telephone and written communications, except for the limited
purpose of facilitating custody arrangements.
3. ~ ~efendant is ordered to refrain from harassing and
stalking the plaintiff and from harassing the plaint! tt' s
relatives,
4,
~ petendant is prohibited from entering the
plaintiff's place of employment.
5. ~e lefendant is prohibited from removing, damaging,
destroying or selling any property owned by the plaintiff or
jointly owned by the parties.
6. ~~efendant is excluded from the plaintiff's
residence located at 127 N, Middlesex Road, Carlisle, Cumberland
County, Pennsylvania, and any other residence the plaintiff may
establish, except for the limited purpose of transferring
custody, The defendant shall remain in his vehicle at all times
during the transfer of custody,
7, The defendant shall have access to the detached garage
which is located at 127 N. Middlesex Road, Carliale, Cumberland
County, Pennsylvania, Monday through Friday between the houra of
7:00 a.m. through 5:00 p.m.
8.
a1Jl;,s:t,V~
c1usive
the Protection Or
ssion portion of this order.
9. This Order shall remain in effect for a period of one
year or until modified or t.erminated by the Court. ~I.~ 6dL. UR
.~ Py t et'I'd1!lt-tmyond-tt's- o'l'l!f inaJ._..ex,p.l.4'.&t.J.QA..da.t.e...i.f_U> ~ ,.4: aliI' 11
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---r.lruls "hAt the dRf,g,n...Ja..t 1Trtr''(!tI'M1t\l ,eu ana ner BeL or Rouse or
h..... Ang...lled..in....a.",pa1.t.4lIA. .QJ:."PI:a.fo<t,!ce.,.t.h..,....fmtt'ea t~K' t~.. L illu."--
rj,.!!k...g,f..blUlIl-t.e-~tttll!! 'p!lfrne!11 ;.~~"
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10. A violation of this Order may subject ~'(fefendant to:
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i) arrest under 23 Pa.C,S. ~6113; ii) ~~ivate criminal
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complaint under 23 Pa.C.S. ~61,t.a~'t; iii) a charge of indirect
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criminal contempt under ~~'Pa.C.S. ~6114, punishable by
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imprisonment up ~p,'ix months and a fine of $100.00-$1,000.00;
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and iv) ciy.~r' contempt under 23 Pa.C.S. ~6114.1. Resumption of
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co-~dence on the part of the plaintiff and defendant shall not
~lifY the provisions of the court order.
11, The Middlesex Township,.rollo,,"Det'!I'!'1:'Ilr!fH't"sh'all be
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provided !Ij.J;Jv!t~Ce';'tlfied copy of this Order by the plaintiff's
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attorney and may enforce this Order by arrest for indirect
criminal contempt without warrant upon probable cause that ~~i."
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Order has been violated, whether or not the v~~~~n is
committed in the presence of a po ~, In the event that
an arrest is the defendant shall be
taken without delay before the court that issued the
order, t court is unavailable. the defendant shall be
take the appropriate district Justice. (23 Pa.C.S. g
6113),
By the Court,
Edgar B. Bayley, Judge
Joan Carey
Attorney for Plaintiff
Jack T. Stahl
Oefendant
Oiane L, Stahl,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
v,
CUMBERLAND COUNTY, PENNSY1.vANIA
NO, 97-2227 CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTOOY
Jack T. Stahl,
Oefendant
CUSTOOY ORDER
AND NOW, this
day of May, 1997, upon consideration of
the parties' Consent Agreement, the following Order is entered
with regard to custody of the parties' child, Michael Augustus
Samuel Leidigh Stahl,
I. ~~laintiff, hereinafter referred
to as the mother,
and the defendant, hereinafter referred to as the father, shall
share legal custody of the child.
2. The mother shall have primary physical custody of the
child,
3. The father shall have partial custody of the child at
times and places agreed upon by the mother and father.
4. The father shall not drink any alcoholic beverages or
take any illegal drugs prior to or during his periods of partial
custody.
5. There shall be reasonable notice given to the other
party if a scheduled period of partial custody needs to be
cancelled or modified and a make-up period shall be offered
within a reasonable time frame,
6, The mother and father shall notify the other
immediately of medical emergencies which arise while the child is
in that parent's care.
7. Neither party shall do anythin8 which may estran8e the
child from the other parent, or injure the opinion of the child
as to the other parent or which may hamper the tree and
natural development of the child's love or respect for the other
parent.
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By the Court,
Ed8ar B. Bayley, Jud8e
Joan Carey
Attorney for Plaintiff
Jack T. Stahl
Oefendant
Diane L, Stahl.
Plaintiff
IN THE COURT OF COHMON PLEAS OF
CUMBERLANO COUNTY, PENNSYLVANIA
NO, 97-2227 CIVIL TERM
v.
Jack T, Stahl,
Defendant
PROTECTION FROM ABUSE
AND CUSTOOY
This Agreement is
CONSENT AGREEMENT
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entered on this ~~ day of May, 1997,
by the plaintiff, Oiane L, Stahl, and the defendant, Jack T.
Stahl, The plaintiff is represented by Joan Carey of LEGAL
SERVICES, INC,j the defendant is unrepresented but is aware of
his right to have an attorney, The parties agree that the
following may be entered as an Order of Court,
1, The defendant, Jack T, Stahl, agree~ to refrain from
abusing the plaintiff, Oialle L, Stahl. or from placing her in
fear of abuse.
2. The defendant agrees not to have any direct or indirect
contact with the plaintiff including, but not limited to,
telephone and written communications, except for the limited
purpose of facilitating custody arrangements,
3. The defendant agrees not to harass and stalk the
plaintiff and not to harass the plaintiff's relatives.
4, The defendant agrees not to enter the plaintiff's place
of employment.
5. The defendant agrees not to remove. damage, destroy, or
sell any property owned by the plsintiff or Jointly owned by the
parties,
6, The defendant agrees to stay away from the plaintiff'm
residence located at 127 N. Middlesex Road, Carlisle,
Pennsylvania, and any other residence the plaintiff may
establish, except for the limited purpose of transferring
custody, The defendsnt shall remain in his vehicle at all times
during the transfer of custody.
7. The defendant shall have access to the detached garage
which is located at 127 N. Middlesex Road, Carlisle, Cumberland
County, Pennsylvania, Monday through Friday between the hours of
7:00 a.m. through 5:00 p,m,
8. The defendant, although entering into this Agreement,
does not admit the allegations made in the Petition,
9, The defendant understands that the Protection Order
entered in this matter will be in effect for a period of one year
and can be extended beyond it ?rigina1 expiration date if the
Court finds that the defendant has committed another act of abuse
or has engsged 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 manner 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, ~6ll3,l; iii) a charge of
indirect criminal contempt under 23 Pa.C.S. ~6l14, punishable by
imprisonment up to six months and a fine of $100.00-$l,OOO.00j
and iv) civil contempt under 23 Pa.C.S, ~6ll4.l.
11, The defendant and the plaintiff agree to the entry of
an Order providing for the following regarding cuatody of their
child, Hichae1 Augustus Samuel Leidigh Stahl,
a. The plaintiff, hereinafter referred to as the mother,
and the defendant hereinafter referred to as the father,
shall share legal custody of the child.
b, The mother shall have primary physical custody of the
child.
c. The father shall have partial custody of the child at
times and places agreed upon by the parties.
d. The fat.her shall not drink any alcoholic beverages or
take any illegal drugs prior to or during his periods of
partial custody,
e. There shall be reasonable notice given to the other
party if a scheduled period of partial custody needs to be
cancelled or modified and a make-up period shall be offered
within a reasonable time frame,
f. The mother and father shall notify the other
immediately of medical emergencies which arise while the
child is in that parent's care.
g. Neither party shall do anything which may estrange the
child from the other parent, or injure the opinion of the
child as to the other parent or which may hamper the free
and natural development of the child's love or respect for
the other parent.
WHEREFORE. the parties request that a Protection Order and a
Custody Order be entered to reflect the above terms.
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Diane L. Stahl, Plaintiff
Jack T. Stahl, Defendant
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,7oan Carey 0
Attorney for Plaintiff
LEGAL SERVICES. INC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
Diane I.. Stahl.
Plaintiff
TN TilE COURT OF COMMON PLEAS OF
v,
CUMBERLAND COUNTY, PENNSYLVANTA
NO, 97- ).J) 7CTVJI, 'rERM
Jack T. Stahl,
PROTECTTON FROM ABUSE
AND CUSTODY
Defendant
TEMPORARY PROTECTTON ORDER
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AND NOW, this day of ~P\; V
, 1997. upon
presentation and consideration of the within Petition, and upon
finding t.hat. t.he plaint.i ff, Dinne I.. Stllhl, now residing at an
IIndiscloHed locat.ion is in immedinl,e Ilnd preHent danger of abuse
from the defendnnt, Jack T. Stahl, t.he following Temporary Order
ia ent.ered. I,aw enforcement. Ilgenclea, human service agencies and
school district.s ahall not diaclose t.he presence of the plaint.lff
or the child In t.he jurisdict.ion or dlst.rict or furnish any
Ilddress, telephone number, or nny other demographic informat.ion
about the plaintiff or child except. by further Order of Court.
The defendant, Jnek T. Stahl, (SSN: 286-44-5284 and date of
hirth: 9/25/53) now residing at. 127 N, Middlesex Road, Carlisle,
ClImberlllnd Count.y, Pennsylvnnla, is hereby enjoined from
physiCAlly Ilbuslng t.he plaint.lff, DIllne L. Stahl, or placing her
in fear of Abuse.
The defendant is ofiJered to refrain from having any direct
or indirect contact with the plAintiff including, but. not. limited
to, t.elephone and written communiCAtions, except for the limited
I'U rl'ose 0 f fac I 11 t.llt ing eUs t.ody a,'rAngement.s.
Th.. defen<lant. is enjoined from hn,'assing Ilnd sl,lllking the
plnintiff nnd from l\lll'llssing t.he 1'1nintiff's reinl,ives.
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 suhJect the defendant to: i)
arrest undel' 23 Pa.C,S. 66113i II) " I'l'Ivnl.e C1'lminal eomplnint
under 23 Pa.C.S. 66113.1j Iii) a churge nf Indirect crimi""l
contempt under 23 Pu,C.S, 66114, punlshuhle by imprisonment up to
six months nnd a fine of $100.00-$I,OOO.00j nnd Iv) civil
contempt under 23 Pn.C.S. 66114.1. Resumption of co-residence on
the part of the plnint!ff nnd defendnnt shnll not nullify the
provisions of the court order.
ThlH Or'der ..hall remain In effect until modified 01'
terminated hy the COliI'!. nnd elln be extend,,,] beyond itH original
expiration dllte If the Cnllrt finds thllt the defendant has
committed another act of ubllse or has engllged in a puttern or
practice that Indiclltes contlnlled risk of hal'm to the plaintiff.
Temporary ClIstndy of Michael Augllstus Samuel Leldlgh Stahl
Is herehy IIwarded to the plaintiff, Oiane L. Stllhl,
A hearing shill I be \", I d on this mul.ler on \.lit' '7 iJ. day of
May, 1997, lit 2: ~ 5 (':(. m. I In Cour'l.I'oom No. "'~ I Cumbel'land
Coun t.y Cou rthouse, ell I'll HIe I p.,nnHY I VlIlll a,
The plaintiff mny IJl.()(",,~d wlthoul. pre-paymenl. of fe,,,,,
penellng further 01,,1<'1' of eOllrt.
The Cumhel'lllnd Cnulll.y She,'1 ff's Oeplll'lment shill I lIl.tempt to
Diane I.. Stahl,
Plaint! fr
IN THE COURT OF COMMON PI,EAS OF
v,
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 97-)';/)7cIVJI, TERM
.Jack T. Stahl,
Defendant
PROTEC'rION FROM ABUSE
AND CUSTODY
fETITION FOR PROTECTION ORDER
AND CUSTODY
RELIEF \lNDER THE PROTECTION FROM ABUSE
ACT, 23 Pa.C.S. g 6101 et Heq.
A. ABUSE
1. The plaintiff, Dlnnl' L. Stahl, is an adult individual
reHiding at 127 N, Middlesl'x Road, Carlisle, Cumberland County,
Pennsylvania 17013.
2. The plaintiff is temporarily staying at an undisclosed
location for her own protection and to avoid further abuse as is
more fully set for'th herein. This address will be furnished to
the court upon requl'st..
3, The defendant, 127 N. Middlesex Road, Carlisle, (SSN:
286-44-5284)(Oate of Birth: 9/25/53), is an adult individual
residing at 127 N. Middlesex Road, Carlisle, Cumberland County,
Pl'nnsylvanla, 17013.
4. The defendant is the plnint.iff's husbnnd,
5. Since approximately 1993, the defendant has attempted
to cause and has intentionally, knowingly, or recklessly caused
bodily inJllry to the plaintiff, has placed thl' plaintiff in
reasonable fl'ar of imminent serious bodily injury, and has
knowingly engaged In 8 CourSft of conduct or repeatedly committed
acts toward the plaintiff under circumstances which have placed
the plaintiff in reasonable fear of bodily injury, ThIs has
included, but is not limited to, the following specific instances
of ahuse:
a. On or about Apl'il 27, 1997, the defendant t.hrew a
shoe at the plaintiff and then threw a child's t.oy at
her hitting her on the chin causing a laceration.
While the plaintiff was putting her child's shoes on to
leave the residence, the defendant screamed at the
plaintiff and threw a can of beer at her missing her
and hltt.ing the table causIng her to fear.
b. On or about April 14, 1997, the defendllnt kicked
and punched the plaintiff cllusing a laceration on her
lip. He then called her vile names IInd pushed her out
of bed onto the floor causing bruising on her knee.
c. On or about Janullry 24, 1995, the defendant
grabbed the plaintiff by her head, slammed her head
into a door, choked her wit.h a bathrobe belt, punched
her in the chest. ca,..,i ng her t.o fall backwards, got on
top of her, choked her with one hllnd, and pushed the
heel of his ot.her hand into her nose causing it to
bleed.
d. On sever'al different occasions since 1993, the
defendant has slapped, choked, punched, and pushed the
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plllln!:lff.
On UnH ()('CHH i on I fI ,"UIP 1 Un:l, ",'hflfl fh,.
plnlntl ff WII" "l'prox I IIIl1h'ly rI v.. monl h" I' ,'''!l nil II I , 1.111'
defendllnt. grabbed t1m plllint.lfC hy Ihp IIIlr.'k of ',,'r
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head, rep,,"tedly "Iummed her fllPe Into 11 ponnt"r
causing her nose to 1I1....d.
6. On or llbOl,t April 27, 1997, the pllllnUff look '...r
minor' child, Iln,l l..ft I.he "AHld"n,'" lit 127 N. Mlddl"HAx UOlld,
Carlisle, Cumbel'lllnd C:ounty, P",nIlHylvllnia, In 01',1.." to ,Ivold
fli rt.he r abuse.
7. The plnlnt.l ff b"Uev,'" IInd I.h,,,'''Co,',' IIV'-,'" I.hlll. sh" III
In immediate Ilnd p,'..."..nt dllnll"r of I/bnll" f"'Jm thl' d..f"'''.IInl., IIl1d
that Hhe i" in need of [lI'ol.pellon f,'on. "u"h 111111',....
8. The pl..int.iff d""i,'"" Ihllt 1.11'" .)r.f..ndllnl h., I'rohlhll..,,\
f,'om hnvlng I/ny dl,'eet. 01' 1IIlIlI'""l COlIlII"I. wilh I.hl' pl,lintlff
including, but. not. limited to, I..I.-plll"'" IIlId wI'III..1I
communicnt.lons, eX"l'pt for' Ih" 111011".) p"I'r")HI' oC fll"lllll/Ilnll
custody arrangpment.R.
9. Th.. pl,rinl Iff d.."I,'I,,, Ihlll II,,, d,'f"'"\IIIII I", ,'nJollI..d
from harn"sln!! und stlllking tI,.. pl,rllII iff, II11d fro," hll"'HIHlng the
plaint.lff's relntlveH,
10. TI... plnint.l ff d..si ,..." Ihlll II". dr'C"'1I1'HlI t.., reMt/'ain",1
Crom ente/'ing her plllec of ,!!"p\"ym"nl,
11. The plninUCC d"HII'''''' Ihlll tI,,, d"r"II.)llllI t.., ..nJoin",1
CI'OIll l'emovlllg, dllmllging, "..sl.l'oying 0/' "..II ing nny property owned
Joilll.ly by !:tIE' pIII,t.i"" or owr",d Hnlldy by till' plllinll rr.
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It. EXCIJJSll'E POSSESSION
12. The home from which the plaintiff is asking the Court
to exclude the defendant Ls owned in the names of the plaintiff
and the defendant.
13, The plaintiff currently has no permanent place to stay
with her child except the marital home, and the defendant has
family and friends in the area with whom he can stay,
14. The plaintiff desires possession of the home so as to
give the greatest degree of continuity to the life of the child.
C. SUPPORT
15, The defendant has a duty to support the plaintiff and
the minor child.
16, The plaintiff desires the defendant provide suitable
alternate housing for her and the minor child if she cannot
return to the home without the defendant's exclusion.
17. The defendant is self-employed at Body Man Auto Repair
at 127 N. Middlesex RORd, Carlisle, Pennsylvania.
18, The plaintiff's incomE! is insufficient to provide for
her minimal needs Rnd those of the child until such time as a
support order can be obtained by filing at the Domestic Relations
Office.
19. The plaintiff intends to petition for support within
two weeks of the Issuance of a protective order.
D. REIMBURSEMENT FOR COST OF CASE
20. The plaintiff asks that the defendant be ordered to pay
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$250,00 to r",lmburse one of Legal Ser'vlePH, Ille, 's flllldllllC
sOllrces for Lbe cost of litlgaLIIl~ Lhls e8He,
F.. TF.MPORI\RLCIJSTOm
21, The plaint! ff ..",..kA t(,IIII'O"8I'Y "IIAI,ooly of t.h.. following
ch I ld:
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PresenL.Re1l11ll:)fi!;U
Alto
Michael Augustlls unllhwlo..,.oI I<wltt.lolI
Salllue1 Leldlgh Stahl
:\ y ".., "tll
nOli 10/2A/!13
The child was 1I0t "')I'II 0111 of w..dl'll'k,
The child Is pre,,,,"t.ly III tI", "lIlil,,,ly or tl", 1'18111Uff,
Diane L. Stahl, who IH 1"'"",,"1 ly ",...1011111( Itl Itll 1I1101I..clospd
locatloll.
Since hi" birth", tI". <'Iii 101 h",. "",,101..01 wllh tilt, following
persons Hnclat tI,f' following "dol'...........:
Name
A!l!lf!UHI ell
Un !Iltl
Plaintiff and
defendant
!27 N. ~lIo101I<',,,,~ tltl.
Cnr!l.. I.., 1',\
10/2A/!!3 La
4/27/97
,1/27/97 to
1'1''''''' n t.
PI "Inti ff
UlldIH('lo",," IO('1t1 Ion
The plaintiff, t.h" lIIott,,'r of UIt. ehll,!, "\I,','ont.ly resides at
an undisclosed] ol'nt Inll,
She Is 11I1\1'1'1,,".
The 1'1..1,,11 1'1' cllI"'l'nl.ly r",dd.... with I.h,> following person:
H!\I!I!.' lllJln!. lO1lllh.l.e
Ml<'h"..1 51 "hI SOli
TIll' ,I..f"nd"nl.. tho f"t.h,.,' of tilt, child, cllrrent1)' resides
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alone at 127 N. Middlesex Road, Carlisle, Cumberland County,
Pennsylvania,
22. The plaintiff has not previously participated in any
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He is married,
litigation concerning custody of the above mentioned child in
this or any other Court,
23, The plaintiff has no knowledge of any custody
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proceedings concerning this child pending before a court in this
or any other jurisdiction.
24, The plaintiff does not know of any person not a party
to this action who has physical custody of the child or claims to
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have custody or visitation rights with respect to the child.
25. The best interests and permanent welfare of the minor
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child will be met if custody Is temporarily granted to the
plaintiff pending a hearing in this matter for reasons including:
a, The plaintiff is a responsible parent who can best
take care of the minor child, and who has provided for
the emotional and physical needs of the child since his
birth,
b, The defendant has shown by his abuse of the
plaintiff that he is not an appropriate role model for
the minor child,
WHEREFORE I pursuant to t.he prov i ,dons 0 f the "Protec t.ion
from Abuse Act." of Oct.ober 7, 1976, 23 Pa.C.S. ~ 6101 et seQ., as
amended, t.he plaint.iff prays this Honorable Court. t.o grant. the
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following relief:
A. Grant. 1\ Tempornry Order pur'lUant to t.he
"Protection from Abuse Act:"
t, Ordering the defendl\nt. t.o refrain from
abusing t.he plaint.lff or placing her In fear of
ahuRe,
2, Ordering t.he defendant to refrain from having
any direct or Indirect contact. with the plaint.iff
including, but. not llmlt.f'r1 to, t.elephone nnd
writt.en communlcnt.ions, except t.o facillt.l\t.e
cust.ody arrangements,
3. Ordering t.he rlefendl\nt to refrain from
haraRsing and st.nlking the plalnt.iff and from
haraRRlng t.he plaint.lff's relat.ives.
4, Prohlbit.ing the defendant. from ent.erlng t.he
plaint.lff's place of employment..
5. Prohibit.ing t.he defendant from removing,
damaging, dest.roylng or sellIng property Jointly
owned by t.he parties or owned Rolely by the
plaint.! ff.
6, Or'dering thl' dl'fendant. to stay away from t.he
plaint.!ff'R present. f'''Ridence which iR undisclosed
to the defendant,
7, Granting t.empor'ary clINt.ody of t.he minor child
to t.he plaintiff.
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B. Schedule a hearing in accordance with the provisions of
the "Protection from Abuse Act," and, after such heRring, enter
an order to be in effect for a period of one year:
I. Ordering the defendant to refrain from
abusing the plaintiff or placing her in fear of
ahllse,
2. Ordering the defendant to refrain from having
any direct or Indirect contact with the plaintiff
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.
4. Prohibiting the defendant from entering the
plaintiff's place of employment.
5. Prohibiting the defendant from removing,
damaging, destroying or seillng property jointly
owned by the parties or owned solely by the
plaintiff,
6. Granting possession of the home located at
127 N. Middlesex Road, ~arli8]e, ~umber1and
County, Pennsylvania, to the plaintiff to the
exclusion of the defendant, except for the limited
purpose of transferring custody of the parties'
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child. The defendant shall remain in his vehicle
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at all times during the transfer of custody.
7. Ordering Lhe dofendant to provide suitable
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alternate housing for the plaintiff and the minor
ch lid I f she canna t re tu rn to the home wi t.hou t t.he
defendant's exclusion.
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8, Ordel'lng Lhe defendant t.o stay I\way C,'om uny
other residence t.he plalnt.iff may establish,
except for the llmlt.ed purpose of trl\nsferring
custody of t.he part.ies' chiid. The defendant
shall remain in his vehicle I\t. all t.imes during
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the transfer of cust.ody.
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9. GI'anting t.emporal'y custody of t.he minor child
to the plaint.iff.
10, Ordering the defendant. to pay $250.00 to
reimburse one of Legal Service.., Inc, 's funding
sources for t.he cost of lit.igat.lng this case.
The plaintiff further asks t.hat. this Petition he filed and
served wit.hout payment of fees and co.d.s by t.he plalnt.iff,
pending a further order at the hearing, and that a certified copy
of this Petition and Order be delivered La t.he Middlesex Township
9
police Department which has jurisdiction to enforce this Order,
The plaintiff prays for such other relief as may be jll"t and
propel',
Respectfuily submitted,
for Plaintiff
LEGAL SERVICES, INC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
10
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DIANE L. STAHL.
Plainti ff
IN TIIF COURT OF COMMON PI FAS OF
CUMBERLAND rOll/HY. PENNSYLVANIA
CIVIL ACTION - LAW
V.
JACK T. STAHL,
Defendant
NO. 97-2227 CIVIL TERM
IN RE: TEMPORARY CUSTODY
ORllELOLCOURT
AND NOW, this 7th day of May, 1997, following a
hearing, IT IS ORDERED:
1. Plaintiff, hereinafter referred to as the mother.
and the defendant, hereinafter referred to as the father, shall
share legal custody of the child.
2. The mother shall have primary physical custodY of
the child.
3. The father sholl hove partial custody of the child
at times and places agreed upon by the mother and father.
4. The father shall not drink any alcoholic beverages
or take any illegal drugs prior to or during his periods of
partial custody.
5. There shall be reasonable notice given ta the
other party if a scheduled period of partial custody needs to be
cancelled or modified and a make-up period shall be offered
within a reasonable time frame.
G. The mother a~d father shall notify the other
immediately of medical emergencies which arise while the child
is in that parent's care.
7. Neither party shall do anything which may estrange
the child from the other parent, or injure the opinion of the
child os to the other parent or which may hcmper the free and
natural development of the child's love or respect for the other
parent.
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8. Sholi!r1 eittl~,r purty ';f'f'~ tn IIIr)(lify nIl'. order. (j
custoeJy cOIIIPlo],nt SilOUld be filerJ ond rf'ferred !JY tile court
administrator to concillotlon.
By the Court;/' )
Joan E. Carey,
For Plaintiff
Jock T. Stahl
Defendant
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DrANE L STAHL.
Plotntiff
TN ThF rOURT OF COMMON PIFAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL ACTION - LAW
V.
JACK T. STAHL.
Defendant
NO. 97-7727 CIVIL TERM
IN RE: PROTECTION FROM ABlISE
ORDEROFC_OURT
AND NOW. this 7th day of May, 1997, following a
hearing, IT IS ORDERED:
1. Defendant. Jack T. Stahl. is enjoined from
physicallY abusing the plaintiff, Diane L. Stohl, or from
placing her in fear of abuse.
2. Defendant is ordered not to hove any direct or
indirect contact with the plaintiff including, but not limited
to, telephone and written communications. except for the limited
purpose of facilitating custody arrangements.
3. Defendant is ordered to refrain from harassing and
stalking the plaintiff and from harassing the plaintiff's
relatives.
4. Defendant is prohibited from entering the
plaintiff's place of employment.
5. Defendant is prohibited from removing, damaging,
destroying or selling any property owned by the plaintiff or
Jointly owned by the parties.
G. Defendant is excluded from the plaintiff's
residence located at 127 N. Middlesex Rood, Carlisle, Cumberland
County, PennsYlvania. and any other residence the plaintiff may
establish, except for the limited purpose of transferring
custody. The defendant shall remain in his vehicle at all times
during the transfer of custody.
7. Defendant sholl hove access to the detached gorage
which 1s locoteo ot j;'/ N. Mlcliilesex Roo(l. COl11s1e, ClllIIllerlwllJ
County, Peonsyl vunln. MOIHJoy through Fr i(Joy bet\~eell tile hours of
7:00 a.m. through 5:00 p,lII.
a. This order sholl rellloln in effect far a period of
one year.
9. The Cumberland County Sheriff's Deportment shall
serve the protection order and the accompanYing custodY order on
defendant,
Joan E. Carey,
For Plaintiff
Jack T. Stahl
Defendant
Bayley, J.
I
ESQUirj
P.er."wl $'!,nllU- ,SC-Jt
f- 9~t(7
By the
/
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DIANE LUCILLE STAHL,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
vs.
: CUMBERLAND COUNTY, PENNSYLVANIA
. "LJ'/
: NO. 97,rCIVIL TERM
JACK TIMOTHY STAHL,
Defendant
: PROTECTION FROM ABUSE
IIDTICE OF HEA~G 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 reliefreq...ested 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 the t!~day of January, 2001,at 11:0 tJ .01.,
in Courtroom No. -I- on the 4" Floor of the Cumberland County Courthouse, 1 Co~rthouse Square,
Carlisle, Pennsylvania.
You MUST obey the Order that is attached until it is modified or terminated by the court aller notice
and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you
to a charge ofindirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six
months in jail under 23 Pa.C.S. ~6114. Violation may also subject you to prosecution and criminal penalties
under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. 92265, this Order is enforceable
anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. /fyou
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. ~ 2261-2262.
You should tlke 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 find a lawyer, you may have to proceed without one.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue, Carlisle, Pennsylvania 17013
Telephone Number: (717)249-3166
AMERICANS WITH DISABILITIES ACf 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.
DIANE LUCILLE STAHL,
Plaintiff
: In the Court of Common Pleas of
: CUMBERLAND County,
: PENNSYLVANIA
v.
: Civil Action - Law
: No, 97-2227
JACK TIMOTHY STAHL,
Defendant
: Protection From Abuse
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: JACK TIMOTHY STAHL
Defendant's Date of Birth is: August 25,1953
Defendant's Social Security Number is: 286-44-5284
Name(s) of All protected persons, including Plaintiff and minor children:
I. DIANE LUCILLE STAHL
AND NOW, on 28th Day of December, 2000 upon consideration of the attached
Petition for Protection from Abuse, the court hereby enters the following Temporary
Order:
PlaintiWs request for a temporary protection order is granted.
1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any
place where they might be found.
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. . ,
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2. Defendant shall be evicted and excluded from the residence at:
127 North Mlddlesel Road
Carlisle, PA 17013
or any other permanent or temporary residence where Plaintiff or any other person
protected under this Order may live, Plaintiff is granted exclusive possession of
the residence. Defendant shall have no right or privilege to enter or be present on
the premises of Plaintiff or any other person protected under this Order,
3. EKcept for such contact with the minor child/ren as may be penniued under
paragraph 5 of this Order, Defendant is prohibited from having ANY CONTACT
with PlaintilT, or any other person protected under this Order, at any location,
including but not limited to any contact at Plaintiffs school, business, or place of
employment, Defendant is specifically ordered to stay away from the following
locations for the duration of this order,
Plaintiff's residence at the above-listed location or any other place where she
may stay during the term of this Order.
Plaintiff's place of employment:
Pennsylvania Department of Environmental Protection
Market Street
Harrisburg (Dauphin County), PA
School of the minor child:
Middlesex Elementary School
250 North MlddlesCJ. Iload
Carlisle, PA
4. Except for such contact with the mioor child/ren as may be pennitted 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, MICHAEL AUGUSTUS SAMUEL LEIDIGH STAHL
Until the final hearing, all contact between Defendant and the ehild/ren shall be
limited to the following:
Defendant's coutact with the minor child is suspended pending the hearing
scheduled in this maUer.
The local law enforcement agency in the jurisdiction where the child/ren are
located shall ensure that the ehild/rcn arc placed in the care and control ofthc
Plaintiff in accordance with the terms of this Order.
6. The following additional relief is granted:
Defendant Is prohibited from having any contact with Plaint 111'. relative..
Defendant Is ordered to refrain from harassing Plaintil1's relatives.
Defendant Is enjoined from damaging or destroying any property owned
jointly by tbe parties or owned solely hy Plaintiff.
7. A certified copy of this Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
MIDDLESEX TOWNSHIP POLICE DEPARTMENT
HARRISBURG POLICE DEPARTMENT
DAUPHIN COUNTY DISPATCH
8. 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 infonn 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.
9. nus ORDER SUPERSEDES
ANY PRIOR PFA ORDER
ANY PRIOR ORDER RELATING TO CHILD CUSTODY
10. TmS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL JUNE 28, 2002 OR UNTIL OTHERWISE
MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND
HEARING.
NOTICE TO TilE 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 SI,OOO.OO and/or up
to six months in jail. 23 Pa.C.S. ~6114. Consent of the PlaintitTto Defendant's return
to the residence shall not invalidate 1his 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 himlher
to state charges and penalties under the Pennsylvania Crimes Code and to federal
charges and penalties under the Violence Against Women Act. 18 U.S.C, ~~2261-
2262.
NOTICE TO LAW ENFORCEMENT OIIFICIALS
This Order shall be enforced by the police who have jurisdiction over the plaintiff's
residence OR any location where a violation of this order occurs OR where the
defendant may be located. If defendant violates Paragraphs I through 5 of this Order,
defendant shall be arrested on the charge oflndirect 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 of law enforcement.
Subsequent to an arrest, the law enforcement officer shall seize all weapons used or
threatened to be used during the violation of this Order OR during prior incidents of
abuse. Weapons must forthwith be delivered to the Sheriffs office of the county
which issued this Order, which office shall maintain possession of the weapons until
further Order of this court, unless the weapon/s are evidence of a crim.:, in which
case, they shall remain with the law enforcement agency whose officer made the
arrest.
1".
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Distribution to:
LEGAL SERVICES, INC.
FAXed & mailed to PSP
TRUE COPY FROM RECORD
In T~timony hereof, I here unto set my hand
and the se (said Court at Carlisle, PA.
This J.L da , 2000.
Prothonotary
.'
PFAD Number: VPI176566A
DIANE LUCILLE STAHL,
Plaintiff
: In the Court of Common Pleas of
: CUMBERLAND County,
: PENNSYLVANIA
v.
.
.
: Civil Action - Law
: No, 97-2227
JACK TIMOTHY STAHL,
Defendant
: Protection From Abuse
PETITION FOR PROTECTION FROM ABUSE
I. Plaintiffs name is:
DIANE LUCILLE STAHL
2. I, (the Plaintill), am filing this Petition on behalf 01:
- myself
3. Name(s) of ALL person(s), including minor children, who seek protection from abuse.
a. DIANE LUCILLE STAHL
4. Plaintiffs Address is: 127 North Middlesex Road, Carlisle, PA 17013
5. Defendant's Name is:
JACK TIMOTHY STAHL
6. Defendant is believed to live at the following address:
Edgewater Psychiatric Center, 1829 North Front Street, Harrisburg, PA 17102
7. Defendant's Social Security Number is:
286.44.S284
8. Defendant's Date of Birth is:
August 2S, 19SJ
9. Defendant's Place of employment is:
unemployed
10, Defendant is an adult.
II. The relationship between the PlaintilT and the Defendant is:
Spouse
Parents of the same children
12. The PlaintilT and the Defendant been involved in the following court actions:
a. Proteellon From Abuse
13. Other details of the court action are:
PFA - Cumberland County (Stahl v. Stahl, No. 97-2217)
14. The defendant has been Involved in a criminal court aellon.
1 S. The defendant is not currently on probation I parole
16, PlaintilTand Defendant are the parents of the following minor child/ren:
a. MICHAEL AUGUSTUS SAMUEL LEIDIGII STAHL
Age: 7 years old
Child's address is: 127 North MlddlesCl Road, Carlisle, PA 17013
17. PlaintilTis 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'
I
a. MICHAEL AUGUSTUS SAMUEL LEIDIGH STAIIL
For the past 5 years, this child has lived with:
PlaintllTat 127 North Middlesex Road, Carlisle,
PA, from December 24, 2000, to the present.
PlaintllT and Defendant at 127 North MiddleseJ: Road,
Carlisle, PA, from February 1999, to December 24, 2000.
PlalntllT at 127 North Middlesex Road, Carlisle, PA,
from January 1998, to February 1999.
PlalntilT and Defendant at 127 North MlddleseJ: Road,
Carlisle, PA, from December 1995, to January 1998.
18. The facts of the most recent incident of abuse are as follows:
On about Sunday, December 24, 2000
location: 127 North Middlesex Road, Carlisle, PA, the marital residence
On or about December 24, 2000, Defendant threw the crock pot on the floor causing the contents
to spll/ out, backw PlalntllT up against the kitchen counter, yelled in her face and repeatedly
jabbw bls finger against her chest. Defendant then called PlalntilT vile names, swung his fist at
her face causing her to have to move to avoid being hit, kicked at her, punched the kitchen
cabinet nut to her, and threw several video cassettes at her, hitting her on the back with one.
PlalntilT telephoned 911 for help, and fearing for her safety, went outside to wait for the police.
When the Mlddlesu Township Police arrhed, Defendant came to the door with a knife In his
hand, his arm cut and bleeding, and yelled at PlaintilT Ir.ferrlng that she caused him to hann
himself. The police summoned an ambulance and Defendant was transported to 1I0ly Spirit
Hospital for treatment. Approllimately an hour after Defendant was taken to the hospital, the
Middlesell Township Police telephoned PlaintilT to warn her that Holy Spiritllospital notified
them that Defendant had walked out of the hospital, and advised PlaintllTto leave the marital
resldencl' to avoid further abuse should Defendant return. Middlesu Township Police picked
Defendant up when he returned to the marital residence, took him to the Crisis Intlrvention
Unit at Carlisle Hospital, petitioned to have Defendant Involuntarily committed, aud transported
Defendant to Edgewater Psychiatric Center In Harrisburg.
19. Prior incidents of abuse that the Defendant has commilled against Plaintiff or the minor child/ren,
(including any threats, injuries, or incidents of stalking) are as follows:
On or about December 2, 2000, Defendant yelled at PlaintilT, screamed iu her face, called her vile
names, threw household objects about breaking them, and threatened to contiuue to smash
everything until PlaintilT gave him money. When the parties' 7-year-old son, Michael,
telephoned 911 for help, Defendant grabbed the telephone from the child and told the 911
dispatcher that he felt violent and to send the police. Defendant. who had been drinking, took
Plalntil1's car and as he left the residence, was punued by Middlesell Township Police, who
ended tbe punuit wben it became unnfe. Defendant was arrested tbe following day and cbarged
with neelng and eluding the police, driving at unsafe speeds, driving under suspension and
reckless driving. A preliminary hearing on the charges is scheduled before District Justice Day
on January 3, 2001 at 9:00 a.m.
In or about September 2000, shortly after his DUI-related probation term In Cumberland
County ended, Defendant began drinking heavily, using lIIegal drugs, and has been Inconsistent
in taking the medication prescribed to him after he wns diagnosed with depression. PlnintilT
fears for her safety and that of the parties' minor child due to Defendant's Irrational and
unstable behavior, his volatile temper, and his recent act of self-mutilation.
20. The police department(s) or law enforcement agencies that should be provided with a copy of the
protection order are:
MIDDLESEX TOWNSIIIP POLICE DEPARTMENT
HARRISBURG POLICE DEPARTMENT
DAUPHIN COUNTY DlSPATCII
21. There is an immediate and present danger of further abuse from the Defendant.
22. PlaintilT is asking the court to evict and exclude the Defendant from the following residence:
127 North Middlesex Road
Carlisle, PA 17013
Owned By:
Diane Lucille Stahl and Jack Timothy Stahl
23, FOR TilE REASONS SET )i'ORTH ABOVE, I REQUEST THAT THE COURT ENTER A
TEMPORARY ORDER, and AFfER HEARING, A FINAL ORDER TIIAT WOULD DO THE
FOLLOWING:
a. Restrain Defendant from abusing, threatening, harassing, or stalking PlaintilT and/or
minor child/ren in any place where PlaintilT may be found.
b. Evict/exclude Defendant from Plaintil1's residence and prohibit Defendant from
attempting to enter any temporary or pennanent residence of the PlaintilT.
c. Award Plaintiff temporary custody of the minor child/ren and place the following
restrictions on contact between Defendant and child/ren:
Defendant's contact with the minor child is suspended pending the hearing
scheduled In this matter.
d. Prohibit Defendant from having any contact with PlaintilT and/or minor child/ren,
either in person, by telephone, or in writing, personally or through third persons,
including but not limited to any contact at Plaintiffs school, business, or place of
employment, except as the court may find necessary with respect to partial custody
and/or visitation with the minor child/ren.
e. Prohibit Defendant from having any contact with Plaintil1's relatives and Plaintift's
children listed in this petition, except as the court may find necessary with respect to
partial custody and/or visitation with the minor child/ren.
,
,
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f. Order Defendant to pay the costs of this action, including filing and service fees,
g. Order the following additional relief, not listed above:
Order Defendant to refrain from harassing Plaintiffs relatives.
!.,
Enjoin Plaintiff from damaging or destroying any property owned jointly by
the pllrtles or owned solely by Plaintiff.
Order Defendant to pay 5250.00 to one of Legal Services, Inc. 's funding
sources to pay for the cost of litigating this case.
h. Grant such other relief as the court deems appropriate.
i. Order the police or other law enforcement agency to serve the Defendant with a
copy of this Petition, any Order issued, and the Order for Hearing. The petitioner
will inform the designated authority of any addresses, other than the Defendant's
residence, where Defendant can be served.
~
\
Respectfully Submitted by:
Joan Carey
Philip C. Briganti
David A Lopez
Maryann Murphy
Attorneys for Plaintiff
LEGAL SERVICES, INC.
H Irvine Row
Carlisle, PA 17013
~
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12/29/00 FRI 08:37 FAX 71! 240 8573
cUlm co PROTIIONOTARY
~001
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...........................
... MULTI TN REPORT ...
...........................
0lJ9p2405331
0319p2438028
04192490779
CENTRAL PROCESS
LIlGAL SBRVICBS
PSP
TI/RX NO
INCOMPLBTB TI/RX
TRANSAr.T ION OK
2388
ERROR
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Of'rtCE Of mE PIlOlllCNYl'ARY
ClMlERLAND CXXJtoIJ"{ COUllTHOOSE
ONE CXXJR'IlKXJSe: SQUAtlE
CARLISLE. PA. 17013-3387
(717) 240-6195
FAX I:
psP
LS .J .
Cell{ ad rroc;t'sStltj
tj-cJ..4o- 5&3/
FAX (7171 240-6573
VIA TELECOPIER
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t'1lCJ't:
CURTIS R. LONG
RE:
.p FA Ord.{!vs
MESSAGE :
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. ~ 00. OF PAGES (m:UJOI~ COVER SKEET)
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'I11is - "'g' is 1n1n'd!d O'\ly fiX' t:te t.m (;4; !te lrdivldel. cr mtity to WUt;h is is cdi I, /lI"d IT"I
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d.Ist:rilut:1a1 CX' cxwirl;} cf. this CDTTTU'Iia:Itlm U. Gtrlct1y p:dUbil:81. If)Ol tf1,e ~\.e:! Un:;
lD1llU1ir.r.Jcn 1n ctt'CC, p1am rcti.tY IS Jmm:l.iIJtely tv tBle(tI:m m1 tetum tie lX'iglIW. " V ID ... /l~
DIANE LUCILLE STAHL,
Plaintiff
: In the Court of Common Pleas of
: CUMBERLAND County,
: PENNSYLVANIA
v,
.
.
: Civil Action - Law
: No, 97-2227
JACK TIMOTHY STAHL,
Defendant
: Protection From Abuse
CONTINUED TEMPORARY ORDER
AND NOW, this 8th Day of January, 2001, pursuant to 23 Pa,C.S. ~6107(c).the tenns and
conditions ofthe Temporary Order issued on 28th Day of December, 2000, in the above-
captioned case are hereby continued in full force and effect until further order of the court.
A hearing on this matter is scheduled for the February 12,2001, at 3:30PM in Courtroom No, 1
on the 4th Floor of the Cumberland County Courthouse, One Courthouse Square, Carlisle,
Pennsylvania.
Distribution To:
Joan Carey, Attorney for Plaintiff
LEGAL SERVICES,INC,
8 Irvine Row, Carlisle, PA 17013
!tYTHEl:,QURI~ : . 'J [
, /, Ii
,,,...~\..l!~).k~...,' l.zj~
i J, Wesley Ol,er Jr., Judge /_
.
4r f'~""~ ~'''~
G-.py 9' .)(,,, +0 s kn rr
Cumberland County Sheriff's Department
DIANE LUCILLE ST A1IL,
PlaintitT
: IN TIlE COURT OF COMMON PLEAS OF
vs.
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO, 97-2227 CIVIL TERM
I
I
I
;
JACK TIMOTIIY STAIIL,
Defendant
: PROTECTION FROM ABUSE
MOTION FOR CONTI~UANCE
Plaintiff, Diane Lucille Stahl, by and through her allomey, Joan Carey of Legal Services, Jnc"
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
December 28, 2000, scheduling a hearing for Monday, January 8, 200 I, at II :00 a. m.
2, The Cumberland County Sherill's Department was unable to locate Defendant in
Cumberland County to serve him with a certified copy of the Temporary Protection from Abuse
Order and Petition for Protection From Abuse, nor was the Dauphin County Sheriffs Department
after being deputized by the Cumberland County Sherifl's Department.
3. PlaintitTindicated to Legal Services, Jnc. statTon January 5, 200 I, that she believed that
Defendant was in a rehabilitation treatment center in Allenwood, Lycoming County, Pl:I1nsylvania,
4. PlaintitTrequests that the hearing be rescheduled to facilitate service of Defendant.
5. PlaintitTrequests that the Temporary Protection From Abuse Order remain in etTect until
further Order of Court.
WHEREFORE, PlaintitTrequests that the Court grant this Motion and reschedule this mailer for
hearing, and that the Temporary Protection From Abuse Order remain in etTect until further Order
SHERIPP'S RETURN - OUT OP COUNTY
.
.
",," -
CASE NO: 1997-02227 P
COMMONWEALTH OP PENNSYLVANIA:
COUNTY OP CUMBERLAND
STAHL DIANE L
VS
STAHL JACK T
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:
STAHL JACK T
but was unable to locate Him
in his bailiwick. He therefore
deputized the sheriff of DAUPHIN
serve the within PROTECTION FROM ABUSE
County, Pennsylvania, to
On January
~th , 2001 , this office was in receipt of the
attached return from DAUPHIN
Sheriff I s Costs:
Docketing
Out of County
Surcharge
DEP. DAUPHIN CO
18.00
9.00
10.00
30,50
.00
67.50
01/08/2001
~~ '/~~
-~./~
R. Thomas Kline
Sheriff of Cumberland County
Sworn and subscribed to before me
this It:> c, day of L~L~~ '1
.2CJ A.D.
IH'..... 0 'h1.I;~ ~p,,-<t
I prothonotary
In Th.~ Court of Common Pleas of Cumberland Cuunt;', Pennsylvania
Diane Luc:ille Stahl
VS,
Jack Timothy Stahl
No, 97-2227 Civil
Now,
i
I,
i',
I I
, '
f
I
j'
,
I
~
12/29/00
,20 0 " . I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of
Dauphin
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff, .u/.4
, ~~W<~,;~,
Sheriff of Cumberland County, PA
Affidavit of Service
Now,
o'clock
M. served the
,20_, at
within '
upon
at
by handing to
a
copy of the ori ginal
and made known to
the contents thereof.
So answers,
Sheriff of
County, PA
Sworn and subscribed before
me this _ day of . 20_
COSTS
SERVICE
MILEAGE
AFFIDAVIT
$
$
@itice of tqe ~lret'iff
.
,
~
Mary Jane Snyder
Real Estal<: Depuy
William T, Tully
Sohcilor
'I
Ralph G. McAllister
Chier Deputy
Michael W, Rinehart
A"iSII1I11 Chier Depoly
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 2"-2660 ru~: (717)2"-2889
Jack Lotwick
Sheriff
, ,
\-
I
Commonwealth or Pennsylvania
STAHL DIANE LUCILLE
vs
County or Dauphin
STAHL JACK TIMOTHY
Sheriff's Return
No. 0003-T - -2001
OTHER COUNTY NO. 97-2227
I, Jack Lotwick, Sheriff of the county of Dauphin, State of
Pennsylvania, do hereby certify and return, that I made diligent
search and inquiry for STAHL JACK TIMOTHY
the DEFENDANT named in the within PFA NOTICE OF HEARING & ORDER
and that I am unable to find himlher in the county of Dauph~n, and
therefore return same NOT FOUND, January 2, 2001
RETURN TO CUMBERLAND COUNTY SHERIFF'S OFFICE PER CLAUDIA TO MARTINA ON
01/02/2001. DEFENDANT IS !lOT IN EDGE~IATER, HE NEVER WAS.
Sworn and subscribed to
JAR~
before me this 2ND day of JANUARY, 2001
0~ C!-. (~aWwJ
Sheriff of Dauphin county, Pa.
PROTHONOTARY
By
Deputy Sheriff
Sheriff's Costs: SO.OO PO 00/0010000
RCPT NO
SHERIFF'S RETURN - OUT OF COUNTY
,
.
--
CASE NO: 1997-02227 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
STAHL DIANE L
VS
STAHL JACK T
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:
STAHL JACK T
but was unable to locate Him
in his bailiwick. He therefore
deputized the sheriff of DAUPHIN
serve the within PROTECTION FROM ABUSE
County, Pennsylvania, to
On January
22nd , 2001 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs:
Docketing
Out of County
Surcharge
Dep. Dauphin Co
S~~ _ .-::::>'./"
~~
;. T~S Klin;7
Sheriff of Cumberland County
18.00
9.00
10,00
29.25
.00
66.25
01/22/2001
Sworn and subscribed to before me
this -.l....'1~ day of ()'... '..
T ,
,;)11'01 A,D.
l t/L. Q. 'Jh.di,u lfln'j
I , Prothono\:a'f'y
In The Court of Common Pleas of Cumberland County, Pennsylvania
Dt/lne Lur:i lIe SV~h 1
Jack Timothy Stahl
No. 97-2227 Civll
Now, t 110/01
, 20 0 " , I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of
Dauphin
"
County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff, .v /.f!!
~K.~~t:~'
Sheriff of Cumberland County, PA
Affidavit of Service
Now,
,20 ,at o'clock
- --
M, served the
within
upon
at
by handing to
a
copy of the ori ginal
and made known to
the contents thereof.
So answers,
Sheriff of
County, PA
Sworn and subscribed before
me this _ day of , 20_
COSTS
SERVICE
MILEAGE
AFFIDAVIT
$
$
,
. . . . 4' .
, .
, . ,
DIANE LUCILLE STAHL,
Plaintiff
: In the Court of Common Pleas of
,
.
.
: CUMBERLAND County,
: PENNSYLVANIA
v,
: Civil Action - Law
: No. 97-2227
JACK TIMOTHY STAHL,
Defendant
: Protection From Abuse
FINAL ORDER OF COURT
Defendant's Name is: JACK TIMOTlIY STAHL
Defendant's Date of Birth is: Septemborr 25,1953
Defendant's Social Security Number is: 286-44-5284
Name(s) of All protected persons, including Plaintiff and minor children:
1. DIANE LUCILLE STAHL
""'-
AND NOW, this \Jth Day of February, 2001 the court having jurisdiction over the
parties and the subject-maller, it is ORDERED, ADJUDGED and DECREED as
follows:
Plaintiff, Diane Lucille Stahl, is represented by Joan Carey of MidPenn Legal Services;
Defendant, Jack Timothy Stahl, is unrepresented, but has been advised of his right to
counsel in this mailer.
Defendant, although agreeing to the terms of this Order, does not admit the allegations
made in the Petition.
Plaintiff's request for a final protection order is granted.
I. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other protected
person in any place where they might be found.
1. Defendant is completely evicted and excluded from Ihe residence at:
117 North Mlddlan Road
Carlisle, PA 17013
j
I
.,.~.
or any olher residence where PlaintilT or any other person protected under this
Order may live. Exclusive possession of the residence is granted to PlaintilT.
Defendant shall have no right or privilege to enter or be present on the premises of
PlaintilT or any other person protected under this Order.
3. Custody of the following minor children:
i~
I. MICHAEL AUGUSTUS SAMUEL LEIDIGH STAHL
. Primary physical custody of the minor child/ren i. awarded
to the Plaintiff.
. Defendant .hall have the following partial physical
cu.todylvisitation rights: On data and at times mutually
agl'ftd upon by the parties.
shall be as follows:
(-
4. The following additional relief is granted as authorized by ~6108 of the Act:
Defendant is enjoined from damaging or destroying any property owned
jointly by the parties or owned solely by Plaintiff.
5. A certified copy of this Order shall be provided to the police department where
PlaintilTresides and any other agency specified hereafter:
MIDDLESEX TOWNSHIP POLICE DEPARTMENT
HARRISBURG POLICE DEPARTMENT
DAUPHIN COUNTY DISPATCH
6. nlls ORDER SUPERSEDES
I. ANY PRIOR PFA ORDER
2. ANY PRIOR ORDER RELATING TO CHILD CUSTODY
7. All provisions oflhis order shall expire on: August 13.2002
NOTICE TO TilE DEFENDANT
VIOLATION OF TUlS ORDER MAY RESULT IN YOUR ARREST ON THE
CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHADLE D'/
A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX
MONTHS, 23 PA.C.S, ~6114, VIOLATION MAY ALSO SUBJECT YOlJTO
PROSECUTION AND CRIMINAL PENALTIES UNDER TilE PENNSYLVANIA
CRIMES CODE.
THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT
OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE
COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST
WOMEN ACT, 18 U,S.C. ~2265. IF YOU TRAVEL OUTSIDE OF THE STATE
AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAYDE SUDJECT TO
FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT, 18 U,S.C ~~2261-
2262. IF THE DRADY INDICATOR PARAGRAPH APPEARS IN THE ORDER,
YOU MAYDE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES
UNDER THE "BRADY" PROVISIONS OF HIE GUN CONTROL ACT, 18 U,S,C,
~922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR
AMMUNITION,
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over the plaintil1's residence OR any location where a
violatilln of this order occurs OR where the defendant may be located, shall enforce
this order. An arrest for violation of Paragraphs I through 3 of this order may be
without warrant, based soley on probable cause, whether or not the violation is
committed in the presence of the police. 23 Pa.C,S, ~611J.
Subsequent to arrest, the police officer shall seize all weapons used or threatened to be
used during the violation of the protection order or during prior incidents of abuse.
The shall maintain possession of the weapons until further order of this Court,
When the defendant is placed under arrest for violation of this order, the defendant
shall be taken to the appropriate authurity or authorities before whom defendant is to
be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be completed
and signed by the police officer OR the plaintilr Plaintill's presence and signature are
not required to file the complaint.
If sufficient grounds for violation of this order are alleged, the defendant shall be
arraigned, bond set and both parties given notice of the date of the hearing,
J,
,
Ifenter~. pursuant.~~ the co~sent o~1ainti~and Defendan:. J <', ~ J 11
I.(id!', ' ,', t 1" I J(do_C-h ~
Di Ie Lucille Jl1,h1, Plaintiff Ja~k Timothy Stahl, Defendant
~~~ V ~\
oan Carey, A;~mey to <<
{\ ~ 1\,0 \
VO'( O~.~
Distribution to:
Joan Carey, Allomey for Plaintiff
MidPenn Legal Services
Slrvine Row, Carlisle, PA 17013
Jack Timothy Stahl, Defendant
clo Bethesda Mission
611 Reily Street, Harrisburg, PA 17102
FAXed and mailed to PSP J
fo.1.ed. to C. P -LS3 0;1-1'1-01
02/14/01 ~ED 16:04 FAX 717 240 6573
ClJMIJ CO PROTIIONOlARY
~001
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... MULTI TN REPORT ...
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TX/RX NO
INCOMPLh1rn TX/RX
TRANSACTION OK
245.
01 J9p2405331
0319p2U6026
04 J 92490779
CENTRAL PROCESS
UlCAL SERVICES
PSP
ERROR
.
J
omCE Of' 'IlIE PIlOTliCN:>TAIW
CtHlERLAND OXIN'i"l COUR1llO.lSE
eM: CXXJR'n1<XJ5E SQUARE
CARLISLE. PA. 1701]-3387
(7171 240-6195
FAX (7171 240-6573
VIA TELECOPIER
FAX .:
717-249-0779
CeN-\: Pr-oceSSit-Jj , IV\ r LJ/I' S'er l'1'C.~
, -
,
TO:
PA STATE POLICE
~l CURTIS R. LONG
RE: PFA ORDERS
MESSAGE :
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