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Home My WebLink About97-02306 VI > '1 ~ v'" .... o i / .5 ,/ t"'- ~i , . ~ 1, Jake's toy box including all toys 2, Jessi's doll house and all barbies 3, collectible Disney cups-set of 12 4, life jacketsllife preservers 5, blank checks 6, bank statements 7. birth certificates 8, savings bonds 9. photo albums and photos 10. bras and underwear 11. two big rubbermaid containers 12. crock pot 13. two childrens computers 14. box of Jessi's school papers 15. bag of winter coats 16, Jessi's dress shoes - 4 pairs 17, Jake's Disney and cartoon pillow 18, children's four wheeler 19. sprinkler 20. children's play tent 21. crib sheets 22, curling irons 23. set of Disney books 24. set of Dr. Suess books 25, Tonya's shoes 26, at leastlwo dresses 27. wagon and accessories 28, ball pit "EXHIBIT 2" Tanya L. Moore, Plaintiff and on behalf of the minor child: Jacob S. Belt IN THE COURT OF COMMON PLEAS OF v. CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-2306 CIVIL TERM PROTECTION FROM ABUSE AND CUSTODY Jeremy S. Belt, Defendant . . AND NOW, this ~ PROTECTION ORDER day of May, 1997, upon consideration of the Consent Agreement of the parties, the following Order is entered: 1. The defendant, Jeremy S. Belt, is enjoined from physically abusing the plaintiff, Tanya L. Moore, and the minor child, Jacob S. Belt, or from placing them in fear of abuse. 2. The defendant is enjoined from having any direct or indirect contact with the plaintiff and the minor child including, but not limited to, telephone and written communications, except for the supervised visits at the Carlisle YWCA according to the schedule agreed upon by the parties. 3. The defendant is ordered to refrain from harassing and stalking the plaintiff and from harassing the plaintiff's relatives and the minor child. 4. The defendant is prohibited from entering the plaintiff's place of employment and the school or the day care facility of the minor children. 5. The defendant is prohibited from removing, damaging, destroying or selling any property owned by the plaintiff. 6. The defendant is ordered to stay away from the plaintiff's residence located at 88 Fry town Road, Newville, Cumberland County, Pennsylvania, and any other residence the plaintiff may establish. ~., 0 7. The ~~~~~i1' shal~i~~~~'~ ~~~~:~~;~~~i~~'-;-b1i/<-b:~ful ~~t-(-v.J /uu ather, and a Constable access to~l& residence at 1282 Boiling springs Road, Boiling springs, on Saturday May 10, 1997, at 3:00 p.m. for the purpose of retrieving her property including items listed in Exhibit A which is attached hereto and incorporated by reference. 8. The court costs and fees are waived. 9. This order shall remain in effect for a period of one year or until 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. A violation of this Order may subject the defendant to: i) arrest under 23 Pa.C.S. 56113; ii) a private criminal complaint under 23 Pa.C.S. 56113.1; iii) a charge of indirect criminal contempt under 23 Pa.C.S. 56114, 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. 56114.1. Resumption of co-residence on the part of the plaintiff and defendant shall not nullify the provisions of the court order. 11. The Pennsylvania state, Newville, and Silver spring Township police Departments shall be provided with certified copies of this Order by the plaintiff's attorney and may 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 a police officer. In the event that an Tonya L. Moore, Plaintiff and on behalf of the minor child: Jacob S. Belt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 97-2306 CIVIL TERM v. Jeremy S. Belt, Defendant PROTECTION FROM ABUSE AND CUSTODY CONSENT AGREEMENT fN This Agreement is entered on this 7 day of May, 1997, by the plaintiff, Tonya L. Moore, and the defendant, Jeremy S. Belt. The plaintiff is represented by Joan Carey of LEGAL SERVICES, INC.; 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, Jeremy S. Belt, agrees to refrain from abusing the plaintiff, Tonya L. Moore, and the minor child, Jacob S. Belt, or from placing them in fear of abuse. 2. The defendant agrees not to have any direct or indirect contact with the plaintiff and the minor child including, but not limited to, telephone and written communications, except for the supervised visits at the Carlisle YWCA according to the schedule agreed upon by the parties. 3. The defendant agrees not to harass and stalk the plaintiff and not to harass the plaintiff's relatives and the minor child. 4. The defendant agrees not to enter the plaintiff's place of employment and the schools or day care facility of the minor children. 5. The defendant agrees not to remove, damage, destroy, or sell any property owned by the plaintiff. 6. The defendant agrees to stay away from the plaintiff's residence located at 88 Fry town Road, Newville, Cumberland County, Pennsylvania, which the parties have never shared, and any other residence the plaint;iff may establish. )~ " /5.l!r-lo!l[,-c^ 7. The ~~~~t. shal~~~Ji~t~~h~1~~t'i~"f,il~~~:;:;~~r,~ her-- Y JsfS f,.l~ father, and a Constable access to.~ residence at 1282 Boiling springs Road, Boiling springs, on Saturday May 10, 1997, at 3:00 p.m. for the purpose of retrieving her property including items listed in Exhibit A which is attached hereto and incorporated by reference. 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 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 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. 56113; ii) a private criminal complaint under 23 Pa.C.S. 56113.1; iii) a charge of indirect criminal contempt under 23 Pa.C.S. 56114, 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. 56114.1. 11. The defendant and the plaintiff agree to the entry of an ,>. 1"-, ," " t ~~ ) ~,,) i' \1. " lL j. l ~: ,-' t. 11:: G~,! I .' U ..:'1' .'1 {~ t~; "1.... I <:~ " ~ ~;' ",; P.. (''',1 (~ j.'-J .....'~ ~ (-'- ..~\ f". U' :~J U @ UI < "- I 1>.1 .. I 0 I ..:I . 0 I I Q "'>< .. I:: I Z I ::;:Z E-< Qjo," .... I 0 I 1>:< ZZ I::E I:: I H I 1>.11>.1 00< 0 .01 I E-: I ::t::OH ... OlE-< E-<'" I <1>.1 I E-<U1 ::;:CJZ .....<::..:1 ..:II:: I CJQ I ..:10 "" ~ o < .~,J.JW 1>.10 I HI>: I HlIl ~ C CJQ> .... 1Il 1Ila. I "-0 I >< r_ ..., t Z..:I 01.... rn I H I >< :J:: < "-<>< ..0.. 0 . . . 01 I c:lZ I H::;:c:l li tr ~ O..:lUl 1>.1'-. UI U11>: I 00 CJoo ~ ~ > I " I>:Z 1>:........ "- I ::;:H I 101>:E-< l.J ., E-.1Z 0....~1Il ><.... I E-:1Il1>.1 ::;:1:: I ~ 6: 9 '" o...ItlO I>:CJ I M 0 r:: 0::;:'" :i:oIoJ..c:u I>.1Itl I 01>.1 I NZCJ ~ ;:; r- oo 1::01< 1>:'" I "-E-.11:: I 0 I r-H z: ,..,01 I ZI>: ..., $ - ..:I1tl I ",E-< .... I ii: .. ~ 1>.1"- ~ I:: . 0'" I CJ :'::0 <"'0'0 01 I H .1>.1 a:l I b ~ E-< >< ~ c:l I E-: H E-< ItlU I 1>.1 I '" I '" I . AUG ;) )~97 i-'1/ ,;, ~~ Q'- , ~~ -.. ~ 1 ~ t:" . Tonya L. Moore, Plaintiff and on behalf of the minor child: Jacob S. Belt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 97-2306 CIVIL TERM Jeremy S. Belt, Defendant PROTECTION FROM ABUSE AND CUSTODY PROTECTION ORDER AND NOW, this ~ day of May, 1997, upon consideration of the Consent Agreement of the parties, the following Order is entered: 1. The defendant, Jeremy S. Belt, is enjoined from physically abusing the plaintiff, Tonya L. Moore, and the minor child, Jacob S. Belt, or from placing them in fear of abuse. 2. The defendant is enjoined from having any direct or indirect contact with the plaintiff and the minor child including, but not limited to, telephone and written communications, except for the supervised visits at the Carlisle YWCA according to the schedule agreed upon by the parties. 3. The defendant is ordered to refrain from harassing and stalking the plaintiff and from harassing the plaintiff's relatives and the minor child. 4. The defendant is prohibited from entering the plaintiff's place of employment and the school or the day care facility of the minor children. 5. The defendant is prohibited from removing, damaging, destroying or selling any property owned by the plaintiff. 6. The defendant is ordered to stay away from the plaintiff's residence located at 88 Fry town Road, Newville, Cumberland County, EXHIBIT "1" .... .1 Pennsylvania, and any other residence the plaintiff may establish. . cSlZ"' ~./J-{'_fl.'~ll.tfA( , / ';:'14'-1.,.14"'" :1"ll,J".. J( I',U nLJ ~I,..tj U~ 1-1" ?/-.~"J._(:J.....~:/"I,,' ...../ . 7. The ~el"end~nt1 shal~ grant the plaintiff, her brother, her ather, and a Constable access to~iv~residence at 1282 Boiling springs Road, Boiling springs, on Saturday May 10, 1997, at 3:00 p.m. for the purpose of retrieving her property including items listed in Exhibit A which is attached hereto and incorporated by reference. 8. The court costs and fees are waived. 9. This Order shall remain in effect for a period of one year or until 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. A violation of tbis order may subject the defendant to: i) arrest under 23 Pa.C.S. S6ll3; ii) a private criminal complaint under 23 Pa.C.S. S6113.1; iii) a charge of indirect criminal contempt under 23 Pa.C.S. S6114, 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. S6114.1. Resumption of co-residence on the part of the plaintiff and defendant shall not nullify the provisions of the court order. 11. The Pennsylvania State, Newville, and Silver Spring Township Police Departments shall be provided with certified copies of this Order by the plaintiff's attorney and may 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 a police officer. In the event that an 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 or the schools and the day care facility of the minor chi Idren. The defendant is enjoined from removing, damaging, destroying or selling any property owned solely by the plaintiff. ^ 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. g6ll3.1; iii) a charge of indirect criminal contempt under 23 Pa.C.S. g6114, 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. g6114.1. Resumption of co-residence on the part of the plaintiff and defendant shall not nullify the provisions of the court order. This Order shall remnin in effect until modified or terminated by the Court nnd can be extended beyond its original expiration date if the Court finds thut 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. Tonya L. Moore, Plnintirf nnd on behalf of the minor child: Jacob S. lIelt IN TilE COURT 01' COMMON PLEAS OF CUMIIERLANO COUNTY, PENNSYLVANIA NO. 97_.J3Dl CIVIL TERM v. J e I' emy S. lie It, Defendant PROTECTION FROM AnUSI' AND CUSTODY NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pnges, you must take nction promptly after this Petition. Order and Notice arc served, by appearing personnlly or hy attorney at the hearing scheduled hy the Court and presenting to the Court your defenses or ohjections to the claims set forth against you. You arc warned that if you fai I to do so the Court may proceed without you, and a judgment may he entered against you by the Court without further notice for any money claimed in the Petition or for any other claim or relief requested hy the plaintiff. You may lose money or property or other rights importnnt to you. FEES AND COSTS If the case goes to hearing and the judge grants a Protection Order, a surcharge of $25.00 will he assessed against you. You may also he required to pay attorney fees to Legnl 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 CUMIlERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMI1ER: (717) 240-6200 AMERICANS WITH DISAI1IL1TII,S ACT OF 1990 The Court of Common Pleas of Cumherland County is required hy Inw to comply with the Americans with Disnbilities Act of 1990. For information ahout accessihle facil ities and reasonahle accommodntions availahle to disahled individuals hnving husiness before the court, please contact our office, All arrnngements must be made at least 72 hours prior to any heoring or husiness hefore the court. You must attend the scheduled conference or henring. is not I imited to, the following specific instnnces of nbuse: n. On or about April 19, 1997. the defendnnt pushed the minor son off of the kitchen table causing him to fnll to the floor nnd hit his hend. Children and Youth Services of Cumberland County (CYS) is currently investigating this matter. Jul ie Stone of CYS took the chi Id to the Carl isle IIospital for trentment and relellsed the chi ld into the plaintiff's cnre. The defendnnt became hostile towards two CYS workers and threatened to "knock" the look off of the face of a CYS worker. When the plaintiff returned to her residence to get medication for the child, the defendant who was enraged screamed nt the plnintifr, ripped off a switch in the plaintiff's cnr, and pulled out the stereo cnusing her to fear for her safety and that of her child. b. In or about the beginning of March 1997, the defendant threw his rood and drink onto the p1nintiff nnd rorced her to clean it up, grabbed his minor son nnd hit him forcefully on his buttocks, grabbed the plaintiff by the hair, nnd pounded her head against the floor for several minutes. The defendant threatened to snap the plaintiff's neck and continued to bounce her head on the floor. The defendant allowed the plaint i fr to change her clothing, but followed her to the bedroom, grabbed her around the neck, and shoved her agninst the bathroolll door. As A result of this incident, the plaintiff feared for her safety nnd that of her child. c. Since October 1994, the defendant has grabbed the plaintiff around the neck and chocked her, pushed and shoved her, and punched her in the head. The defendant has grabbed the plaintiff by the hair causing her to lose clumps of hair, pulled her up the stairs by the hair, and locked her in the hasement. The defendant has thrown items at the plaintiff, grabbed her by the arms, and thrown her on the floor. The defendant has threatened to snap the plaintiff's neck, put her in the car, and drive it over a cliff causing the plaintiff to fear for her safety. 5, On or about Apri I 23, 1997, the plaintiff and the minor chi 10.1 left their residence at 1282 Boi I ing Springs Road, noi ling Springs, Cumberland County, Pennsylvania, in order to avoid further abuse. 6. The plaintiff believes 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, 7. The plaintiff desires that the defendant he prohibited from having any direct or indirect contact with the plaintiff or the minor child including, but not limited to, telephone and writlen communications, except for the limited purpose of facilitating custody arrangements. 8. The plaintiff desires that the defendant be enjoined from harassing and stalking the plaintiff, and from harassing the plaintiff's relatives, or the minor child. 9. The plaintiff desires that the defendant be restrained from this action who has physical custody of the child or claims to have custody or visitatioa rights with respect to the chi Id. 18. The hest interests and permanent welfare of the minor 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 cun best take cure of the minor child 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 chi I d. c. The defendant's behavior has adversely affected the chi Id. WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of October it 1976,23 Pa.C.S. g 6101 tl seQ., 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 the minor child or placing them in fear of ahuse. 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 lInd written c,'mmunications, except to facilitate custody orrangements. 3. Ordering the defendllnt to refroin from horussing ond stlllking the plaintiff and from hllrassing the plaintiff's relatives and the minor child. 4. Prohihiting the defendant from entering the plaintiffts place of employment and the school or the day care facility of the minor children. 5. Prohibiting the defendant from removing, damaging, destroying or sel I ing property owned solely by the plaintifr. 6. Ordering the defendant to stay uway from the pluintiff's residence located at 88 Fry town Road, Newville, Cumberland CountYt Pennsylvania, which the parties have never shored, and any other residence the plaintiff may establish, except for the limited purpose of transferring custody of the parties' child. The defendant shall remain in his vehicle at all times during the trllnsfer of custody. 7. Granting temporary custody of the minor child, Jacoh S. Belt, to the plaintiff, Tonya L. Moore. B. Schedule a hearing in accordance with the provisions of the "Protection from Abuse Act," nnd, after such hearing, enter an order to be in effect for n period of one year: I. Order ing the defendant to refrain from lIhus ing the plllinti ff Ilnd the minor chi Id or plllcing them in fear of abuse. 2. Ordering the defendllnt to refrain from having any direct or indirect contllct with the plllintiff or the minor child includingt hut not limited to, telephone and written communications, except to facilitate custody arrllngements. 3. Ordering the defendant to refrain from harassing and stalking the plaintiff and from harassing the plaintiff's relatives and the minor child. 4. Prohibiting the defendant from entering the plaintiffts place of employment and the school or the day care facility of the minor children. 5. Prohibiting the defendant from removing, damogingt destroying or selling property owned solely by the plaint i ff. 6. Ordering the defendant to stay oWllY from the plaintiff's residence located at 88 Fry town Road, Newville, Cumberland County, Pennsylvania, which the parties have never sharcdt and any other residence the plaintiff may estahlish, except for the limited purpose of transferring custody of the parties' child. The defendant shall remain in his vehicle at all times during the transfer of custody. i. Ordering the defendant to pay $250.00 to reimbursc one of Leglll Services, Inc.'s funding sources for the cost of litigating this cuse. The plaintiff further asks that this Petition be filed and served VJ '-< r- -1 '::- ,;, '~ 'J " . ...,. .;) ~ ~ ~ .....}..t>... '~ -.J~ j~ ~ IA LI ,- ItJ ii. . ' ~ .. I' .. ,', I"' . I l I , r> i I' : L, .. " iii "'," j, ~ ;:'1' ~ l' . , l,.,q C1 .j'""", ',','",. ~ : ; :.. :; ~, ';i; ; r ~,,:i fL, I :~ i. i\ r~ i] \'/\1"1,[,; 'i:.l ii Ut' ;j-" C:UHi' ;'1 iiiY,\ _ _._._,-----"----~.- ._~-"_. ",' " i' Tl..U.__[~__M;.:JiJ~: ____~._.__.. >,,,. n ;1: I l-r'Ullt:: . .. . t ~ .' ',> n j; " : '. : , r , " .. ~... 'I t' .~__.....:_~_~~~~.__~:.:::.t__~~~___ t t~,.:.'; ,;;, i' J~<:h ;-:i1 Y j J r, ~ __':l.~ .......;.~_ ]i,.i7Y;' '-J' .,~ ,.. :4,' iI.', I"" \;, >1, ;', . n '. ;', ". n::'" :,-:,; " '\',' .' W1 _to ':,. .. .. 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