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Slanley Shannon
15 Soulhside Drive
Newville. PA 17241
July 12. 2()()()
The Honorable Kevin Hess
Cumberland County Courthouse
Carlisle. PA
Re: Civil-Case No.: en - i.f3t/d
I am wriling with regard to Ihe subjccl-referenced Order thaI expires effeclive
July 13. 2000.
I respcclfully requestlhis Honorable Court release to me the fireann.s confiseated a.s a
result of the Order.
Sincerely yours.
*-O} 5tct~V'-
Stanley Shannon
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when such retrieval is made.
~ 3. Bxcept a. provided in Paragraph 5 of thi. Order, Defendant
i. prohibited from having ANY CONTACT with Plaintiff at any
location, including, but not limited to any contact at
Plaintiff'. place of employment located at Carli.le Ko.pital, 246
Parker Street, Carli.le, Cumberland County, penn.ylvania.
Defendant i. .pecifically ordered to .tay away from the following
location. for the duration of thi. Order. Plaintiff'. re.idence
located at 154 Faith Circle, Carli.le, Cumberland County,
Penn.ylvania. and any other re.idence Plaintiff may e.tabli.h.
~ 4. Except a. provided in Paragraph 5 of thi. Order, Defendant
.hall not contact Plaintiff by telephone or by any other mean.,
including third partie..
~ 5. CU.tody of the minor child. Ian Patrick Shannon. Date of
Birth. 09/08/95, .hall b. a. follow.. .ee attached Cu.tody Ord.r.
~ 6. D.fendant .hall i..ediately turn over to the Sh.riff'.
Offic., or to a local law enforcem.nt agency for deliv.ry to the
Sheriff'. Offic., the following weapon. u.ed or threaten.d to be
u.ed by Defendant in an act of Abu.e again.t Plaintiff.
multiple gun.
~ 7. D.f.ndant i. prohibit.d from po.....ing. tran.ferring or
acquiring any oth.r weapon. for the duration of thi. Ord.r. Any
weapon. delivered to tha .heriff und.r Paragraph 6 of thi. Order
or under Paragraph 6 of the Temporary Order .hall not b. r.turn.d
until further Ord.r of Court.
~8. The following additional relief i. granted a. authoriz.d
by 16108 of thi. Act.
a. Thi. Order .hall r...in in effect until aodified or
teraineted by the Court and can be extended beyond it. original
expiration date if the Court find. that Defendant ha. co.aitted
another act of Abu.e or he. engaged in a pattern or practice that
indicate. continued ri.k of hara to Plaintiff.
b. Defendant is required to relinquish to the sheriff any
firearm license Defendant may possess. Defendant's weapons and
firearm license may be returned at the expiration of the
Protection Order after Defendant has submitted a written request
to the Court for the return of the weapons and the Court has
notified Plaintiff of the request and given Plaintiff an
opportunity to respond. A copy of this Order shall be
transmitted to the chief or head of the police department of
Newville and the sheriff of Cumberland County.
c. Defendant is enjoined from damaging or destroying any
property owned jointly by the parties or owned solely by
Plaintiff.
d. Defendant i. to refrain froa harassing Plaintiff'.
reletives or the minor children.
f. The court costs and fees are waived.
o 9, Defendant is directed to pay temporary support for [insert
the names of the persons for whom support is to be paid]
as follows: [insert amount,
frequency and other terms and conditions of the support order]
This Order for support shall remain in effect
until a final support order is entered by this Court. However,
this Order shall lapse automatically if Plaintiff does not file a
complaint for support with the Court within fifteen days of the
date of this Order. The amount of this temporary order does not
necessarily reflect Defendant's correct support obligation, which
shall be determined in accordance with the guidelines at the
support hearing. Any adjustments in the final amount of support
shall be credited, retroactive to this date, to the appropriate
party.
o 10. The costs of this action are waived as to Plaintiff and
imposed on Defendant.
o 11. Defendant shall pay $* to Plaintiff as compensation for
Plaintiff's out-ot-pocket losses, which are as follows:
OR
COLUMBIA, TRIBAL LANDS, U.S. TBRRITORIBS, AND THB COMMONWEALTH OF
PUBRTO RICO ONDBR THB VIOLENCB AGAINST WOMBH ACTION, 18 U.S.C.
12265. IF YOU TRAVEL OUTSIDB OF THB STATB AND INTENTIONALLY
VIOLATB THIS ORDER, YOU MAY BB SUBJECT TO FEDBRAL CRIMINAL
PROCBEDINGS ONDBR THAT ACT. 18 U.S.C. II 2261-2262. IF
PARAGRAPH 12 OF THIS ORDBR BAS BBEN CHBClCED, YOU MAY BB SUBJECT
TO FEDBRAL PROSBCUTION AND PENALTIBS ONDBR THB "BRADY" PROVISIONS
or THB GUN CONTROL ACTION, 18 U.S.C. 1922(G), FOR POSSBSSION,
TRANSPORT OR RBCBIPT or rIREARMS OR AMMUNITION.
NOTICB TO LAW BHFORCBMBHT OFFICIALS
The police who have juri.diction over Plaintiff's re.idence
OR any location where a violation of this Order occurs OR where
Defendant may be located, .hall enforce this Order. An arre.t
for violation of Paragraph. 1 through 7 of this Order may be
without warrant, ba.ed .olely on probable cau.e, whether or not
the violation is comaitted in the pre.ence of the police. 23
Pa.C.S. 16113.
Sub.equent to an arrest, the police officer .hall seize all
weapon. used or threatened to be used during the violation of the
Protection Order or during prior incidents of abuse. The [insert
the appropriate name or title] .hall .aintain po..e.sion of the
weapon. until further Order of this Court. When Defendant is
placed under arre.t for violation of the Order, Defendant shall
be taken to the appropriate authority or authorities before whoa
Defendant is to be arraigned. A "Complaint for Indirect Cri.inal
Conteapt" shall then be completed and .igned by the police
officer OR Plaintiff, Plaintiff'. pre.ence and .ignature are not
required to file the coaplaint.
If sufficient ground. for violation of this Order are
alleged, Defendant .hall be arraigned, bond set and both parties
given notice of the date of the hearing.
BY THE COURT, /
~ ./IJ;je.
Kevi. A. Hess, Judge
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Mother's Day, and the father on Father's Day from 3:00 a.m. until
7:30 p.m.
5. The Christmas holiday schedule shall be pursuant to the
following schedule:
a. The father shall have the child in odd numbered
years from 9:00 a.m. on December 24th until noon on
Christmas Day and in even numbered years from noon on
December 25th until noon on December 26th.
b. The mother shall have the child in odd numbered
years from noon on December 25th until noon on December
26th and in even numbered years from 9:00 a.m. on
December 24th until noon on Christmas Day.
6. The mother and the father shall have the right to see
the child on his birthday at a time to be agreed upon by the
mother and father.
7. The mother and the father shall have custody of the
child for two blocks of seven days each during the summer. The
two blocks shall not be consecutive. The mother and the father
will give each other two weeks notice as to when his or her
period of vacation will take place. The mother and the father
shall give each other a telephone number and address where he or
she may reach the child during the periods of summer custody.
8.
vary from
in effect
The mother and the father, by mutual agreement, may
this schedule at any time, but the Order shall remain
until further order of court.
9. There ghall be reasonable notice given to the other
party if a scheduled period of temporary custody needs to be
canceled or modified and a make-up period shall be offered within
a reasonable time frame.
10. The mother and the father shall exchange the child for
each period of custody at a mutually agreed upon public place.
11. The father shall not abuse alcohol and/or narcotics
during the time the child is in his care.
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Balance Due: $-L9~~
170 State SurCharge
ADO DElETE
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III State Fine
160 Sheriff Cost 1$1.50 . any addtl)
107 District Attorney
104 Court Costs IClerk of Court)
~nl Restitution
Name "Pnrlhonoky.s " C)(i;Ce.
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PI"!ion C'HI ilYln'I Inlo,,,,,.I Ion 7~rJ. ~~olt" .5/' ?,
The defendant is ordered to refrain Irom having any dircct or indirl'Ct contact with the
plaintiff or the minor children including. but not limiled to. telephone and written
communications
The defendant is enjoined from harassing and stalking the plaintiff and from harassing her
relathoes. or the minor children
The defendant is enjoined from entering the plaintill's place of employment (except for the
limited purpose of obtaining medical treatment for himsell) or the school and day care facility of
the minor children
The defendant is enjoined from remo\ing. damaging. destroying or selling any propeny
owned by the plaintiff
A ,;olation of this Order may subject the defendant to i) arrest under 23 Pa,CS ~61 \3;
ii) a private criminal complaint under 23 Pa C S *6113 I. iii) a charge of indirect criminal
contempt under 2,1 Pa C S *6114, punishable by imprisonment up to six months and a tine of
$100 OO-SI.OOO 00, and iv) ci\;1 contempt under 23 PaeS *6114 1
This Order shall remain in elfcct until modified or ternlinated by the Court and can be
extended beyond its original expiration date if the Court finds that the defendanl has committed an
act of abuse or has engaged in a pattern or practice that indicates risk of hann to the plaintiff or
the minor children
Temporary custody of Ian Patrick layasbazan is hereby' awarded to the plaintiff. Mary
Margaret layas\Ja7.an
The defendant is ordered to relinquish to the sherilfs department any weapons which he
owns. possesses. has used or Ihreatened to use against the ptaintilf and the minor children
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cir~'\Jmslances which have placed the plaintilf and the children in reasonable lear of bodily injury This
has included. but is not limited to. the following specilic instances of abuse
al On or about July 29. 1997. early in the day, during a vacation in North
Carolina with the plaintiff and her two children, the defendant threatened to kill the
plaintiff and raised his ann with a closed list in a menacing fashion causing her to
fear that he was going to strike her
Later in the aeoing on that day. the defendant yelled obscenities at the
plaintiff and her minor children. IO-year-old Ryan. and 23-month-old lan, When
the defendant left the residence, the plaintiff fearing for her safety and that of her
children, locked herself in the bedroom Mth the parties' 23-month-old child and
her ten-year-old son. Ryan, in another room The defendant returned to the
residence, pounded on the bedroom door. and screamed. .Open the door. whore,.
The defendant then unlocked the door. poured beer on the plaintiff and the baby
as they lay in bed. and struck the plaintiff on the back of the head with a beer
bottle The defendant pulled the plaintiff out of bed by her hair and threw her
against the wall. pulling hair from her scalp While the plaintiff attempted to
comfort the parties' baby who was cl)ing. the defendant pushed and s!to,'ed the
plaintiff about and screamed obscenities at her The defendant knocked items off
of the dresser and screamed at the child. .Shut up or \11 shut you up. The
defendant followed the plaintiff, who had the baby in her anns, into the bathroom
and pushed her against the wall As the plaintiff steadied herself to keep from
dropping the baby, the defendant Idd,ed her in the leg When the plaintiff got
Ryan and the baby and attempted to nee from the residence. the defendant grabbed
the plaintiff by the shoulder threatening. "I'll blow your fucking head off and those
two fucking brats of yours" The plaintiff screamed for help. ran to a hotel with
the children. and called Q II for help The police arrived and took the plaintiff and
the children to a domestic violence shelter in North Carolina, The plaintiff
sustained bruising and soreness on her right leg and swelling and soreness on the
back of her head as a result of this incident The plaintiff telephoned her father in
Pennsylvania to come to North Carolina to get her and the children to return
home
b) On or about July 27. IQQ7, while on vacation in North Carolina. the
defendant struck the parties' 23-month-old son. Ian. on the back, The child
sustained bruising on his back in the shape of the defendant's lingers as a result of
this incident
c) On or about the morning of July 22. IQQ7. the defendant pounded on the
front door of the residence in Virginia where the plaintiff. defendant and her
children were visiting the plaintiffs niece When the plaintift's ten-year.oJd son
opened the door, the defendant grabbed the child by the neck with both hands and
shook him violently The plaintiff ran into the room when she heard the child
scream. "lte's choking me" When the plaintiff entered the room. the defendant
released the child, pushed him onto the couch. and \-erba11y abused the child.
calling him "fat,- "no good.- and "Ivy-
Later. thc cvcning of July 22. 1<)97. t he defendant returned to the
plaintil1's niece's residence. in Virginia where the defendant. the plaintiff and the
plaint ill's children were staying and screamed at the plaintiffs son, her niece and
her niece's roommate who were dO\\lnstairs The defendant then went upstairs.
screamed at the plaintiff. threatened her saying, "If you are pregnant. I will kill
you" and called her a \\Ihore As the plaintiff and her niece began packing the
defendant's belongings. he pushed the niece away, went downstairs and screamed
at the plaintiffs son Ryan The defendant returned upstairs \\Ihere the plaintiff was
holding the parties' 2J-month-old son. Ian. grabbed the plaintiff by her hair. pulled
her off of the bed. and thre\V her into a comer of the room When the child cried.
the defendant screamed at the child .Shut the lUck up" and told the plaintiff to shut
the child up When the defendant \\lent to his vehicle and thre\V the plaintiffs
belongings onto the street, Ihe plaintiffs niece locked the door The defendant
pounded on the door and \\Iindo\\ls lor approximately one hour. and after he left
the premises he telephoned the plaintilf repeatedly
d) \n or about July 19. 1<)<)7, the defendant repeatedly pushed and shoved the
plaintilfs ten-year-old son, Ryan. causing the child to be traumatized
e) On or about July 15, ICJQ7. the defendant thre\\l a lit cigarette at the
plaintiffs face. and threatened the plaintilfsaying"\ \\1111 kill you dead with my gun
if I you ever cheat on me"
o On or about July II. ICJQ7, the defendant pushed the p1aintilT, and
tluutened to kill her
!lIOn or about May II, I ()<)7, the delendanl tried 10 push the plaintiff out of
his vehicle as he backed out of the plaintilfs driveway The plaintiffs two children
were in the car screaming When the plaintiff got her children out of the vehicle.
the defendant threw the plaintilfs purse and the child's car seat onto the street,
hI In or about April 1997, the defendant grabbed Ryan by his shirt and shook
him violently causing the child's shirt to rip, The child sustained bruising and
soreness of his shoulder and was traumatized as a result of this incident
i) In or about December 19%, the the defendant came to the plaintilfs
residence, pushed her about. and pulled her hair, When the plaintiff attempted to
get to the telephone to call for help. the defendant pushed her about. pulled her by
her clothing. slapped her about her face and head, and screamed at her calling her
names The defendant grabbed the phone and hit the plaintiff in the forehead ",ith
it causing her to fall backward and hit her head on the night stand The defendant
then threatened her saying, "I'll kill you" The plaintiff sustained lacerations and
bruises on her forehead and scalp and headaches as a result of this incident The
next day the defendant telephoned the plaintiff repeatedly at her place of
employment, Carlisle 1I0spital
j) In or about January 1995, ",hile on vacation in Florida. the defendant
slapped the plaintiff about her fllte and head and pushed her The plaintiff. ",110
was appro,imately eight "'ttks pr~nanl. fearing for her safety, ran into the
bedroom and locked the door The deleooant kicked in the door, grabbed the
p1aintilf by the ~n, shook her \iolentl), and screamed at her The p1aintifftled to
a convenience store, waited until daylight and had her airline ticket changed so she
could return home immediately,
k) Since approximately 1995, the defendant has abused the plaintiff and her
two minor children in ways including. but not limited to, the following punching
her about her arnlS, slapping her about her face and head. pushing her about.
pulling her hair, shaking her and her minor child, Ryan, violently. slapping her
children, and threatening to kill her and her children In addition, the defendant
has followed her. telephoned her repeatedly at her home and at her place of
employment, and verbally abused her and her minor children
5 The plaintiff believes and therefore avers that she and Ihe minor children
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 children including. but not limited to. telephone and
written L'Omrnunications
7 The plaintiff desires that the defendant be enjoined from harassing and stalking the
plaintiff. and from harassing her relatives and the minor children
8 The plaintilf desires that the defendant be restrained from entering her place of
employment (except for the limited purpose of obtaining medical attention for himsetO and the
school and day care lacility of the minor children
Q The plaintiff desires that the defendant be enjoi~'ti Irom removing. damaging.
destro~ing or setling an\,' pmpertv owned hy the plaintilf
&.m
Plaintiff and her son,
Rene Ryan Zayasbazan
Addruses
I S4 Faith Circle
Carlisle, PA
nattl
From December 1995
to present
Plaintiff and Ryan
604C Baltimore Ave,
Mt 1I0lly Springs. PA
From September 1995
to December 1995
The plaintiff. Mary Margaret Zayasbazan, the mother of the child, currently resides at 154
Faith Circle. Carlisle. Cumberland County, Pennsylvania
She is divorced
The plaintiff currently resides with the follo\\<;ng persons'
Name
Rene Ryan Zayasbazan
Ian Patrick Zayasbazan
RelationshiD
her son
her son
The defendant, Stanley Jay Shannon. the father of the child. currently resides at 15
Southside Drive. N~;lle, Cumberland County, Pennsylvania
He is single
The defendant currently resides with the follo\\<ing persons
&.m
Arlene and Jay Shannon
Andrea Miller
Rdationshin
his parents
his daughter
15 The plaintiff has not pre\iously participated in any litigation concerning custody of
the above mentioned child in this or any other Court
16 The plaintiff has no kno\\<ledge of any custody proceedings concerning this child
pending before a court in this or any other jurisdiction
17, The plaintiff does not know of any person not a party to this action who has
physical custody of the child or claims to ha\'e custody or \;sitation rights with respect to the
child
18 The best interests and permanent welfare of the minor child w;1l be met if custody
is temporarily granted to the plaintiff pending a hearing in this matter for reasons including:
a, The plaintiff has been the caretaker of the child since
his birth and has prO\;ded for his emotional and physical
needs. and is a responsible parent who can best meet the
child's needs
b, The defendant has sho'Wn by his abuse of the plaintiff
and the children that he is nol an appropriate role model for
the child
WHEREFORE, pursuant to the prO\;sions of the "Protection from Abuse Act. of October
7. 1976,23 PaC,S, ~ 6101 ~ ~,as amended, the plaintiff prays this Honorable Court to grant
the following relief.
A Grant a Temporary Order pursuant to the 'Protection tfom Abuse Act:.
I, Ordering the defendant to refrain from abusing the plaintiff
and the minor children and from placing them in fear of abuse,
2 Ordering the detendant to refrain tfom ha\;ng any direct or
indirect contact with the plaintiff or the minor children including.
but not limited to, telephone and written communications
3, Ordering the defendant to refrain from harassing and
stalking the plaintilT and from harassing her relatives and the minor
children,
4, Prohibiting the defendant from entering the plaintiffs place
of employment (except for the limited purpose of obtaining medical
attention for himself) and the school and the day care facility of the
minor children,
5, Prohibiting the defendant from removing. damaging.
destroying or selling property owned by the plaintiff
6, Ordering the defendant to stay away from the plaintiffs
residence located at 154 Faith Circle, Carlisle. Cumberland County,
Pennsylvania, which the panies have never shared. and from any
other residence the plaintilT may in the future establish for herself
7 Granting temporary custody of the minor child. Ian Patrick
Zayasbazan. to the plaintiff.
8 Ordering the defendant to relinquish to the sherift's
department any weapons which he owns. possesses or has used or
threatened to use against the p1aintilT and the minor children:
speciflCllly guns.. and prohibiting the defendant from acquiring or
possessing any other \\,eapons for the duration of the Temporary
Protection Order
B Schedule a hearing in accordance with the provisions of the .Protection from
Abuse Act: and, aller such hearing. enter an order to be in elfect for a period of one year
Ordering the defendant to refrain from abusing the plaintiff
and the minor children and from placing them in fear of abuse,
2 Ordering the defendant to refrain from having any direct or
indirect conlact with the plaintiff or the minor children including.
but not limited to, telephone and wrillen communications
3, Ordering the defendant to refrain from harassing and
stalking the plaintiff and from harassing the plaintiffs relatives and
the minor children
4, Prohibiting the defendant from entering the plaintift's place
of employment (except for the limited purpose of obtaining medical
attention for himself) and the school and the day care facility of the
minor children
5, Prohibiting the defendant from removing. damaging.
destroying or selling property jointly O\\ned owned by the plaintiff
6. Ordering the defendant to stay away from the plaintift's
residence located at 154 Faith Circle. Carlisle. Cumberland County,
Pennsyl\'ania, which the parties ha\'C llC\-er shared. and any other
residence the p1aintitTmay in the future establish for herself
7 Ordering the defendant to relinquish to the sherift's
department any wC'apons which he owns. possesses Of has used Of
threatened to use against the plaintiff and the minor children
specifically guns. and prohibiting the defendant from acquiring or
possessing any other weapons for the duration of the protection
Order
8 Granting temporary custody of the minor child. Ian Patrick
7.ayasbazan, to the plaintiff
9, Ordering the defendant to pay $25000 to Cumberland
County. one of Legal Services, loe.'s funding sources. in lieu of
attorneys' fees. as reimbursement for the cost of litigating this case
and assessing the $2500 surcharge and court costs to the defendant
if the case goes to hearing
The plaintiff further asks that this Petition be filed and sm-ed without payment of fees and
costs by the plaintiff. pending a further order at the hearing. and that certified copies of this
Petition and Order be delivered to the North Middleton Township and Carlisle Police
Departments and any other appropriate police departments which have jurisdiction to enforce this
Order
The plaintiff prays for such other relief as may be just and proper
Respectfully submitted.
~.'" JJ"" /'
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,. h1-':>.r...........:~L, /'
{. ('an~y. Att~or PlaintilT
l.EGAL SER\'ICES. INC.
8 Inine Row
Carlisle, PA 11013
MARY MARGARET ZA Y ASBAZAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of her minor . CUMBERLAND COUNTY. PENNSYLVANIA
children: RENE RYAN ZA Y ASBAlAN.
and IAN PATRICKZAYASBAZAN, CIVIL ACTION - LAW
v NO 97-4368 CIVIL TERM
STANLEY JAY SHANNON,
Defendant PROTECTION FROM ABUSE
PROTECTION ORDER
AND NOW, this ~ day of September. 1997, upon consideration of the Consent
A!,,'reement of the parties. the following Order is entered
I, The defendant. Stanley Jay Shannon, is enjoined from physically abusing the
plaintiff. Mary Margaret Zayasbazan. or the minor children, Rene Ryan Zayasbazan and Ian
Patrick Zayasbazan, or from placing them in fear of abuse
2 The defendant is enjoined from ha\lng any direct or indirect contact wlth the
plaintiff or her minor child, Rene Ryan Zayasbazan, including, but not limited to. telephone and
written communications, except for the limited purpose of contacting the plaintiff to facilitate
custody' arrangements,
3, The defendant is ordered to refrain from harassing and stalking the plaintiff and
from harassing her relatives and the minor children
4, Neither party shall enter the other's place of employment, except in the event that
the defendant requires medical treatment at the plaintill's place of employment
~ The defendant is prohibited from entering the day care facility of the parties' minor
child. Ian Patrick Zayasbazan, except for the limited purpose oftranstemng custody of the child
on designaled dates
6 The defendant is prohibited trom removing. damaging, destroying 01' selling any
property owned by the plaintiff
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7 The de/cndant is ordered to stay away from the plaint ill's residence located at 154
Faith Circle. Carlisle. Cumberland County, Pennsylvania. and the defendant is ordered to stay
away from any residence the plaintiff may in the future establish for herself. except for the limited
purpose of transferring custody The defendant shall remain in his vehicle on the street at Ihe curb
during transfer of custody
8, The defendant shall not acquire or possess any weapons for the term oflhis Order.
including constructive possession Possession shall be construed as direct or indirect control
and/or constructive ownership or control of such weapons
9, Court costs and fees are waived
10 This Order shall remain in effect for a period of one (I) year and can be extended
beyond that time if the Court linds lhat the defendant has commilted an act of abuse or has
engaged in a pattern or practice that indicates risk of harm to the plaintiff or the minor children
This Order shall be enforceable in the same manner as the Court's prior Temporary Protection
Order entered in this case
II A v'iolation of this Order may subject the defendant to i) arrest under 23 Pa,CS
~61 13; ii) a private criminal complaint under 23 Pa C S ~bl n I. iii) a charge ofindirect criminal
contempt under 23 Pa C S 116114. punishable by imprisonment up to six months and a line of
5100 00-51.000 00. and iv) civil contempt under 23 Pa C S ~()114 I
12 The North Middleton Township and Carlisle Police Departments shall be provided
with certified copies of this Order '-'v the plaint ill's altorney and may enforce this Order by arrest
for indireo criminal contempt without warrant upon probable cause lhat this Order has been
violated, whether or not the violation is commilted in the presence \If the police otf1Cel' In the
event that an arrest is made under this section. the defendant 5ba1l be taken without unnecessary
delay before the court that issued the order When that ~-oo.n is unavailable. the defendant shall he
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MARY MARGARET ZA Y ASBAZAN,
Plaintiff
for herself and on behalf of her minor
children: RENE RYAN lAYASBAZAN,
and IAN PATRICK ZAYASBAZAN,
IN TilE COURT OF COMMON I'LEAS OF
CUMBERLANI> COUNTY. PENNSYLVANIA
,~. ,
CIVIL ACTION - LAW
d
.J
7~
.,
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v,
STANLEY JAY SIIANNON,
Defendant
NO, 91-4368 nVIL TERM
"
PROTECTION FROM ABUSE
CONSENT AGREEMENT
'..
'.
--
This Agreement is entered on this)6. day of September. 19<J1. by the plaintiff. Mary
Margaret Zayasbazan. and the defendant, Stanley Jay Johnson The plaintiff is represented by
Joan Carey of LEGAL SERVICES. INt', the defendant is represented by Charles Rector.
Attorney at Law The parties agree that the following may be entered as an Order ofCoun
I, The defendant. Stanley Jay Shannon, agrees to refrain from abusing the plaintilT,
Mary Margaret Zayasbazan. or lhe minor children, Renee Ryan layasbazan and Ian Patrick
Zayasbazan, or from placing them in fear of abuse
2 The defendant agrees not 10 have any direct or indirect contact \\lith the plaintiff or
her minor child. Renee Ryan layasbll7,an. including. but not limited to, telephone and written
communications. except for the for the limited purpose of contacting the plaintiff to facilitate
custody arrangements
3 The defendant agrees not to harass and stalk the plaintiff and not to harass the
plaintift's relatives and the minor children
4, Neither party will entfl' the other's place of ettlployment. except in the n'ellt that
the defendant requires medical treatment at the plaintiff s place of ettlployment
5 The defendant agrees not to enter the day' care facility of the panies' minor child.
Ian Patrick ZaYl\<ha7an, except for the limited purpose of transferring custody of the child on
designated dates
b The defendant agrees not 10 remove, damage, destroy, or sell any property owned
by the plaintiff,
7 The defendant agrees to stay away Irom the plaintiffs residence located at 154
Faith Circle. Carlisle. Cumberland County, Pennsylvania, and the defendant agrees to stay away
from any residence the plaintiff may in the future establish for herself, except for the limited
purpose of transferring custody The defendant will remain in his vehicle on the street at the curb
during transfer of custody,
8 The defendant agrees oot to acquire or possess any weapons for the term of the
Protection Order, including constructive possession Possession shall be construed as direct or
indirect control and/or constructive ownership or control of such weapons
Q The defendant. although entering into Ihis Agreement, does oot admit the
allegations made in the Petition
10 The defendant understands that the Protection Order entered in this matter will be
in effect for a period of one (I) year and can be extended beyond thaI time if the Court finds that
the defendant has committed an act of abuse or has engaged in a pattern or practice that indicates
risk of harm to the plaintiff or the minor children 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
II Violation of the Protection Order may subject the defendant to i) arrest under 23
Pa C S ~113, ii) a private criminal complaint under 23 Pa (' S ~113 I. iii) a charge of indirect
criminal contempt under 23 Pa C S ~b114, punishable by imprisonment up to six months and a
fine ofSlOO OO-SI.OOO 00. and iv) chil contempl under 23 Pa C S ~b1l4 I
12 The defendant and the plaintiff agree to the entry of an Order pro\idill8 for the
following custody schedule fur their child. Ian Patrick layasbuan
a) The panies will share legal custody of the child
b) The mother will have primary physical custody of the child,
c) The father will have panial custody of the child every third Saturday and
Sunday from 1000 a,m until 200 pm each day. and on the alternating Sunday
from 10:00 a,m until 2,00 p.m,. one weekday from 4,30 p,m until 7:30 p,m(day
to be mutually agreed upon by the panies). and on other dates and times mutually
agreed upon by the panies The father will commence the third Saturday and
Sunday schedule on October II and 12. 1997. unless other arrangements are
mutually agreed upon by the panies
d) The father and/or his mother. Arlene Shannon. will provide transponation
during transfer of custody The child will be secured in a car seat in the back seat
of the vehicle at all times when being transponed
e) The father ~;II not use alcohol and/or illegal drugs immediately prior to or
during his periods of custody with the child
t) The mother and father agree that each \\;11 notify the other of all medical
care the child receives while in that parent's care Each parent will notify the other
immediately of medical emergencies which arise while the child is in that parent's
care,
g) The panies realize that their child's well being is paramount to any
dilTerences they might have between themselves Therefore. they agree that
neither pany will 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 de\"e1opment of the child's love or respect for the other parent,
MARY MARGARET ZA Y ASBAZAN. . IN THE COURT OF COMMON PLEAS OF
Plaintiff
for hersdf and on behalf of her minor . CUMBERLAND COUNTY . PENNSYLVANIA
children: RENE RYAN ZA Y ASBAZAN.
and IAN PATRlCKZAYASBAZAN, : CIVIL ACTION - LAW
v, : NO, 97-4368 CIVIL TERM
ST ANLEY JAY SHANNON.
Defendant . PROTECTION FROM ABUSE
ORDER FOR CONTINUANCE
.
AND NOW. this .!!- of August. 1997, upon consideration of the attached Motion for
Contirwance. the matter scheduled for hearing on Monday. August 18. 1997. by this Court's
Order of August 12. 1997, is hereby continued generally
This Order is entered without prejudice to either party to request a hearing
The Temporary Protection Order shall remain in effect for a period of one year or until
funher Order ofCoun
A certified copy of this Order for Continuance \\,ill be pro\ided to the North Middleton
Township and Carlisle Police Depanments by the plaintiffs attorney,
By the Coon.
/
I
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
, mvuk.( S/Js/q'I,
c.~&. ,..! t',
Charla Rector
Attorney for Defendant
,;
MARY MARGARET ZA Y ASBAlAN,
Plaintill'
for herself and on behalf of her minor
children RENE RYAN ZA Y ASBAZAN.
and IAN PATRICK ZA Y ASBAZAN.
IN HIE COURT Of COMMON PLEAS Of
CUMBERLAND COUNTY. PENNSYLVANIA
CIVil, ACTION - L.AW
v
STANL.EY JAY SHANNON.
Defendant
NO 97-43b8 CIVIL. TERM
PROTECTION fROM ABUSE
MOTION FOR CONTINUANCE
The plaintiff. Mary Margaret Zayasbazan. by and through her altomey. Joan Carey of
Legal Services. Inc, mo\es the Court for an Order continuing generally the hearing in the abo\'e-
captioned case on the grounds that.
I. A Temporary Protection Order was issued by this Coun on August 12, 1997.
scheduling a hearing for Monday. Au~'lIst 18. 1997, al3 30 p m
2 The Cumberland County Sheriffs Depanment sen.ed the defendanl y,ith a certified
copy of the Temporary Protection Order and Petition for Protection Order on August 12, 1997.
at 4 50 pm. at his residence. 15 Southside Dri\'e. Newville. Cumberland County. Pennsylvania
3 The defendanl has retained Charles Rector, Altomey at Law, to represent him in
the malter
4 The parties agree. by and through their respective counsel. that the hearing be
continued generally pending funher Order of Coon to facilitate negotiation of a Consent
Agreement in the matter
5 The p1aintilT requests that the Temporary Protection Order remain in elTect for a
period of one year or until funher Order ofCoun
6 Certified copies of the Order for Clmtinuance will be delivered to the Nonh
Middleton Township and Carlisle Police Oepanments by the altorney lor the p1aintitT
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717-2431&22
NCRTH M 1DLLET()~ TIoP
PAGE. 113
I 98-001136
INCIDENT REPORT
page No. ]
05/03/98
DOMESTIC / PFA VIOLATION
illliiiUUlllllllllllliletietieeelllllUUUeeeelUIUllllUIUftUIIUIIIIIIIIII..titititititiieet
Date oocurred: 05/03/98 to 05/03/98 Date reported: 05/03/98
S Timo occurred: 10:45 to 11:15 Tlme reported: 11:25
T JuriSdiction: 21208
A
T
U
S
Arrost(NON-TRAFFIC): PETER CASTLE
Reviewed by:
Date reviewed:
Cleared by: Physical arrest Date cleared: 05/03/98
eaee .tatue: Closed Date closed: 05/03/98
"""""""""""""'6"6'6'66'66'6'6"66'6""6""""""""'66"""6
Otten.. code: PFA ACT...PROTECTION FROM ABUSE ACT VIOLATION
Nature ot ottenee: VIOLATED PFA ORDER
o
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! Alcohol ooneuaed? NO Drug/Narcotic? NO Premises entered:
COaputer equipment used? NO Forced entry? Abandoned?
"'6"""""6"6'66'6"66'6'66"""""""'66'6'6'"""'66"66'6""""'"
STANLEY JAY SHANNON 008: 11/22/54 Age at incident: 43
15 SOUTBSYDE DR. Sex: M Race: WHI Ethnicity: NOHR
NEWVILLE. PA 17241
circumetanc.: Coaplated
Untounded? NO Date:
alae motivation: Vnknown
Location: 154 FAITH CtRCLE
Location code: ZONE 3
Location type: Rosidence or ho..
S
U
S
P
B Int.rvieve4? YU Statement taken? Hair color:
C Eye color:
T citations ieaued? NO Build:
Warrantll aeuec1? NO COIIplexlon:
6"6A'6"""""""""'644""6"46"4"44"'66'6'6"""""'66"6'6"44'4"
STANLEY JAY SHANNON 0'1'N:
Height::
" weight:
lbs.
,
Date ot arrest: 05/03/98 '11:51
A Arreat typal Takon into custOdy
R Location: MIDDUSBX POLICE DBPT
R Location COde: out of jurisdiction
B
S
T
Inforaed of charge? YES
Advised of right.? YES
NCIC check? YES
Rea1dent? YES
Booking nUllber I
Other incident(s) cloared? HO
Date of disposition: I I
BoOkinq station: North Middleton PO
Condition priaoner: NOnlal
Arrest dieposition:
Arr..t(NON-TIlAl'PIC): PETER CASTLE
'4"'4'4""""4&4'1""""""'4""'4""""""'44"6"""""""""'"
MARY ZAYAS BAZAN DOB: 01/11/64 Age at incidents 34
V 1S4 FAl'lH CIRCLE sex: FRace: WHI Ethnicity: NOW
I CARLISLE, PA 17013
C (117) 241-6436
T
1
K
Interviewed? YES
statement taken? YES
Resident? Y1!:S
Hoapital:
Transported by:
Injury typo: No
Doctor:
injuries
Related ottena"l PFA ACT
Relationship to STANLEY JAY SHANNON: Boyfriend/girlfriend
"""114"""'11"'6"""""'446""11"""64""4"""""""""""'"
64/62/1998 18:26
717-2431622
tDlTH MIOru:T[J.I lY'
PAGE 64
, 98-001136
INCIDENT SUPPLEMENTAL REPORT
Page No. l
05/03/98
DOMESTIC I PFA VIOLATION
eiiiiiiiiiiiiiii66iiiiiiiiiiiiiiiiliiiiiiieiiiiiititiijijijijiii.iiiiiilllaOIIOaUiUUat
Reported bYI PETER CASTLE Date reported: 0~/03/98
Reviewed by: Date reviewed: I I
ON KAY 3. 1998 I WAS CALLED WHILE ON STATION BY KARY ZAYASBAZAN
REFERENCE 'rO A DOMESTIC I PFA VIOLATION THAT HAD JUST OCCUJUU:D AT
HER RBSIDENCE INVOLVING IIER BOYFRBIND STANLEY SHANNON. I MET
WITH KARY AT HER RESIDENCE AT 154 FAITH CIRCLE. SHE SAID THAT
SHE SPOKE WrrH STANLEY LAST HIGHT AND TOLD HIM NOT TO COME OVER
TOKHOROW AND TOLD HIM TillS DATE WHEN HE CALLED NOT TO COME OVER.
MR SHANNON CAME OVER AT AROUND 1045 HOURS TO PICK UP HIS SON.
IAN, WHO KARY ALLOWED HIM TO TAXE TO IUDS ZONE. HE WENT 'rO LEAVE
AND CAKE BACK YELLING OBSCENETIES AT HER AltO WAS TOLD TO LEAVE.
KR SHANNON DID NOT LEAVE AFTER MARY TOLD HIM SEVERAL TIMES. Hit
ENTERED THE IIOUSB AND STARTED R!JIOVING THINGS, AND ACCORDING TO
HER HE 8ECAM1!: MORB AGITATED AND sHE BECAME Fl'ARFUL AND GRABBED A
JaTCHEN JQlIPE LOCATED IN THlt BASEMBlIT OF HER HOUSE. SHE SAID SHE
USBD rr TO GET HIM TO LEAVE. AND TOLD HIM THAT THE POLICE WERB ON
THE WAY AND HE UFT THE SCENE.
I LATER WENT TO MEET AND PIa UP MR SHANNON FOR THE PFA VIOLATIOH
AT MIDDLESEX TOWNSHIP POLICE STATION WHERE HE WENT TO FILE A
COMPLlUIfT AGAINST MARY FOR CHASING HIM WITH THE KNIFE. I PLACED
HIM UNDER AlUU!ST FOR THE PFA VIOLATION AND TOOK HIM BACK 'rO THE
BTA'UON. HB WAS VERRY COOPERATIVE. HE WANTED TO MOW HOW TO
PROCEED WITH CHARGES AGAINST MARY FOR COMING AT HIN WITH THE
JQlIFE. I ADVISED HIM WE WOULD NEED A STATEMENT FROM HIM IN
WRn'ING AND WE WOULD NEED TO CONSULT WITH THE CHIIlF OF POLICE AND
PROBABLY 'l'HE DISTRICT ATTORNEYS OFFICE ABOUT THE CASE. HE WAS
WILLINO TO GIVE A STATEMENT AND IT WAS EXPLAINED TO HI" THAT HE
COULD GIVE A STATEl'IENT BUT 'l'HE EVEOlNCE IN HIS STATEMENT COULD BE
USED AGAINST HIM. I TOLD HIM HE COULD DISCUSS 'l'HIS WITH HIS
ATTORNEY AND GIVE A STATEMENT WITH HIK PRESENT. LATER THIS WIU.
IF 9 !f15HJ1:S. I WAS NOT ABLE TO GIVE HIM A DEFINATE ANSWER AT
TlfIS TIME BECAUSE HE WAS VIOLATING THE PFA WHEN THIS OCCURRED.
HE WAS TAnlf TO DISTRICT JUSTICE PLkCEY AND REMANtlID TO CCP
BECAUSE THE ORDER DOES Har ALLOW D.J. TO GIVE BAIL. HEAJUIIG IS
SCHEDULIlD FOR 0900 HOURS 011 MOliDAY KAY 4. 199.. MARY IS NOTInBD
OF THIS AND WILL REPORT TO OIS'l'JUCT A'1'TOIUfIYS OfFICE BE'l'WBEN 0130
AND 0'00.
1.....................................................1.........................
64!62/1998 18:26
717-2431622
NORTH MlDDlETO; H.f'
PAGE. 65
,
~ COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: n'*"t'land
1"";0\ Olwl.. ..., 09-2-01
lovi.. ....ti.. -..... Paula P. Carreal
1 C.Jurt:bouse Square
ClIrllsle l'a. 1701300
POLICE
CRIMINAL COMPLAINT
~. (717)240-6564
COMMONWEALm OP PENNSYLVANIA
VB.
DEFENDANT: IWlE om _...s
r Sl'ANlEt J. ~
15 SWIHSIDE mIVE
NDNILLE, PA 172-41
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'.lh8 DI!':FIXWlr did violate tJl8 C1CdIlIE' 1...- urder the ProtBctittl PraI ~ J\l:t
1n No. 97-4368 Civil ~~~ 30, 1997, ut the lIo11ca:able J(!.V])I A. HIlSS, tot\1c:h
d1.rw::bd the tlEJ>>ONl' OME '1'0 to.",,, -a OF PLADI'l'Ut" ltiERE CRl!R ..uub MJl' TO
DmlR FPBCISIS, (If w.y 3, 1998 AT 1045 'ro 1115, putt1rr:J tht1r 'PO'- K\Rr
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(Sole. 101Sl0 .J\lne 23, 1918 ~'Il(lf flU( ABlSE Aa).
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84/82/1998 18:28
717-2431622
I'mTH MIDt(.ETCl-l TWP
PAGE 86
(Colltilluat101l ol2.)
.11.........-....... J. s......
Docltet Number:
II
POUCE
CRIMINAL COMPLAINT
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~4/~2/1998 18:2~ 717-2431&22
NORTH MIDCU:TCI-I ThP
PAGE 68
STA1D1ENI'
NAME. '
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HOME ADDRESS:
PHONE NUMBER:
LOCATION OF INCItlENl':
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THE BUT 01' MY XNOWt.EDCl:R. INFORMA.TXClf AlII) UIoX1tP. 'nIXS vmunCA'l'IQl %a
IQOE SUBJECT TIlE PE:NAI.TIES OF SEC'UON 4!lD4 01' TJm CRDGS CXIDS
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~4/62/1998 18:26 717-2431622
t{FTH MIDDLETON ThP
PAGE. 16
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: CllIIBBRLUID
.,..0...,
NOTICE OF HEARING
09-3'04
0......: ttwt.
'%BOIIA8 A. l'LACBY
~: 5002 ~K_.__ ~
-'UlICSIIUm. PA
Y$.
DEFEND.\H1': _...__
rSThNlE'/~. ~NON
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Doc;Mt No,: 0--. _ A,U:>>
Dale FRed: ,. ~~
CIVI...
1'7055
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n. hMIIna wi be IltId .Ihe foIowll1l dale and tknI:
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n JOII" dlllbl,d ... NqUIre 1IIIIIlllClt..... contKt 11M U'lIlJ1trlal DIatrtct oIlloe.,... ~ In
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~
My commIAlon eIIplnIa IrII Uondey OIJaftl*Y. lEAL
~ ~\\~tt'\af\~ vrac~ "'" 3 1IA'1 "
~ 2:'1 t "."".
AQItC ""'
..,
MARY MARGARET ZAYASBAZAN,
Plaintiff
for herself and on behalf
of her minor children:
RENE RYAN ZAYAS BAZAN ,
and IAN PATRICK
ZAYAS BAZAN
V
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 97-4368 CIVIL TERM
STANLEY JAY SHANNON,
Defendant
PROTECTION FROM ABUSE
IN RE: PETITION FOR INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this 4th day of May, 1998, the defendant
having appeared in open court and having admitted that he is in
violation of that portion of the order prohibiting contact
beyond the limited purpose of facilitating custody arrangements,
he is thus adjudged,
Sentence of the court is that the defendant pay
the costs of prosecution, a fine of $100,00, and that he undergo
supervised probation for a period of six months on condition
that he undergo an evaluation and successfully complete any
prescribed program of counseling for anger management.
The defendant to be released from custody.
By the Court,
-?(~. Aoi
Kevi~ Hess, J.
/
William Gabig, Esquire
Assistant District Attorney
William Braught, Esquire
Assistant Public Defender
Probation
Victim-Witness
Sheriff
CCP
:bg
Off ice
"lAp... "
;~,J 1",2\#" J
~, '\
Mary Margaret layaa-Bazan,
Plaintiff
VI.
,IN THE COURT OF COMMON PLEAS
.
,OF CUMBERLAND COUNTY, PENNSYLVANIA
.
. NO. 97 - 4368
CIVIL TERM
Stanley Jay Shannon,
Defendant
.
.PROTECTION FROM ABUSE
NOTICE OF HEARING AND ORDER
YOU HAVE BEIN SUED IN COURT. If you wilh to defend againat the claiml let
forth in the following paperl, you muat appear at the hearing Icheduled herein. If
you fail to do ao, the cale may proceed againlt you and a FINAL Order may be entered
againlt you granting the relief requeated in the Petition. In particular, you may be
evicted from your reeidence and 10le other important rightl.
A hearing on thia matter il acheduled for the
1999, at .m., in Courtroom No.
County Courthouae, carli.le, Pennlylvania.
,
day of ft,..""
of the cumberland
You MUST obey the Order that il attached until it il modified or terminated by
the court after notice and hearing. If you dilobey thil Order, the police may arrelt
you. Violation of thil Order may lubject you to a charge of indirect criminal
contempt which il punilhable by a fine of up to $1,000.00 and/or up to lix monthl in
jail under 23 Pa.C.S. 56114. Violation may allo lubject you to prolecution and
criminal penalties under the Pennsylvania Crimel Code. Under federal law, 18 U.S.C.
52265, thil Order il enforceable anywhere in the United Statel, tribal landi, U.S.
Territoriel and the Commonwealth of Puerto Rico. If you travel outlide of the Itate
and intentionally violate thil Order, you may be lubject to federal criminal
proceedingl under the Violence Againlt Women Act, 18 U.S.C. 52261-2262.
YOU SHOULD TAItE 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 SIT FORTH BILOW TO FIND OUT WHERE YOU CAN GET LEGAL HELD. IF YIJU CANNOT FIND
A LAWYER, YOU MAY HAVE TO PROCEED WITHOUT ONE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LI8IRTY AVENUE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER. (717) 249-3166
AMERICAN' "ITa DIIABILITIE. ACT or 1990
The Court of Common Pleal of CUmberland County il required by law to comply with
the American. with Dilabilitie. Act of 1990. For information about acce.lible
facilitie. and realonable accommodation. available to dilabled indiVidual. having
bUlinea. before the court, pleale contact our office. All arrangement I mUlt be made
at lealt 72 houri prior to any hearing Or bUlineal before the court. You muet attend
the Icheduled conference or hearing.
Mary Margaret Zayas-Bazan,
Plaintiff
:IN THE COURT OF COMMON PLEAS
:OF CUMBERLAND COUNTY, PENNSYLVANIA
vs.
:
:NO. 97 - 4368
CIVIL TERM
Stanley Jay Shannon,
Defendant
:PROTECTION FROM ABUSE
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name:
Stanley Jay Shannon
Defendant's Date of Birth:
11/25/54
Defendant's Social Security Number:
210-40-4332
Name of Protected Person:
Mary Margaret Zaya.-Balan
AlII) HOW, thb -:' I day of '. , 1999, upon
con.idaration of the attached Petition for Protection froa Abu.e,
the court hereby enter. the following T..porary Order a
~ 1. Defendant ahall not abuae, haraa., atalk or threaten any
of the above peraon. in any place where they aight be found.
o 2. Defendant is evicted and excluded from Plaintiff's
residence located at , CUmberland County, Pennsylvania, (a
residence which is jointly owned/leased by the parties;
owned/leased by the entireties; owned/leased solely by
Plaintiff/Defendant to which Plaintiff and the minor child/ren
moved to avoid abuse, which is not owned or leased by the
Defendant, or any other permanent or temporary residence where
Plaintiff 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, except for the limited
purpose of transferring custody of the parties' child/ren.
Defendant shall remain in his vehicle at all times during the
transfer of custody.)
~ 3. IXcept for .uch contact with the ainor child a. ..y be
peraitted under paragraph 7 of thi. order, Derendant i.
prohibited froa having AIrY CONTACT with Plaintiff at any
location, including, but not liaited to any contact at
Plaintiff'. place of ..ployaent. Defendant ia .pecifically
ordereel to .tay avay froa the folloving location. for the
duration of thi. Ordera 'laintiff'. re.idenca locatad at 154
Faith Circla, Carliale, cuabarland County, penn.Jlvania, a
ra.idanca which i. owned .olely by 'laintiff, and any othar
ra.i4anca plaintiff aay a.tabli.b, axcapt for tba liaita4 purposa
of transfarring cust04y of tba partias' cbi14. Dafan4ant sball
raaain in bis vabicla at all tiaa. 4uring tba transfar of
cust04y.
B 4. Excapt for sucb contact witb tba ainor cbi14 as aay ba
paraitta4 un4ar paragrapb 7 of tbi. Or4ar, Daf.n4ant sball not
contact plaintiff by t.l.pbona or by any otb.r aaans, inclu4ing
tbrougb tbir4 p.r.on..
o 5. pending the outcome of the final hearing in this matter.
Plaintiff is awarded temporary custody of the following minor
child/ren:
Until the final hearing, all contact between Defendant and the
child/ren shall be limited to the following:
The local law enforcement agency in the jurisdiction where the
child/ren are located shall ensure that the child/ren are placed
in the care and control of Plaintiff in accordance with the terms
of this Order.
B 6. Dafan4ant .ball i..a4iataly ralinquisb tb. following
w.apons to tb. Sbariff's Offic. or a 4.signat.4 local law
.nforc...nt ag.ncy for tba 4alivary to tb. Sb.riff's Offica:
aultipla gun..
Oaf.n4ant i. probibita4 froa po.....ing, transf.rring or
acquiring any otb.r waapon. for tba 4uration of tbi. Or4.r.
B 7. Tba following a44itional r.li.f i. grant.41
Tba cuabarlan4 county Sbariff'. Dapartaant shall att..pt to
..ka aarvica at plaintiff'. requa.t an4 without pra-payaant of
f.a., but ..rvica ..y ba accoapli.ba4 un4ar any applicabla aula
of Civil Proca4ur..
Tbi. Or4ar .ball b. 40ck.ta4 in tba offica of tb.
protbonotary an4 forvar4.4 to tb. Sbariff for ..rvica. Tb.
protbonotary .ball not .an4 a copy of tbi. or4.r to O.f.n4ant by
..il.
Tbi. Or4.r sball raaain in .ff.ct until a04ifi.4 or
t.rainat.4 by tba Court an4 oan b. ..t.n4a4 bayon4 it. original
.xpiration 4at. if th. Court fin4. that O.fan4ant ba. coaaitt.4
anotb.r aot of abu.a or ba. .ngaga4 in a patt.rn or practic. tbat
in4icata. continua4 ri.k of bara to plaintiff.
Oafan4ant i. anjoina4 froa 4aaaging or 4a.troyin9 any
property owned .olely by Plaintitf.
Detendant i. to retrain tro. hara..inq plaintift'. relatives
or her .inor children.
The custody Order dated septeaber 30, 1997, i. currently in
ettect and Detendant's contact with Plaintitt is li.ited to
tacilitatinq custody accordinq to that Order. Defendant shall
reaain in his vehicle durinq the ti.es of transfer of the child.
~ 8. A certified copy ot this Order shall be provided to the
police departaent where Plaintift re.ides and any other aqency
specified hereatter: Horth Middleton Township and Carli.le Police
Departaent..
~ 9. THIS ORDIR SUPIRSBDIS ~ lUfY PRIOR PFA ORDIR AND 0 ANY
PRIOR ORDER RELATING TO CHILD CUSTODY
10. THIS ORDIR APPLIU IIIKIDIATILY TO DIFDDAHT AHD SHALL RIMAIII
III IFFICT UNTIL MODIFIED OR TIRMIIIATID BY THIS COURT APTIR HOTICB
MID HDIlIHG.
HOTICI TO DIFDDAHT
Detendant is hereby notitied that violation ot this Order
aay result in arrest for indirect cri.inal cont..pt, which is
punishable by a tine of up to $1,000.00 and/or up to six .onths
in jail. 23 Pa.C.S. 56114. Consent of Plaintitf to Defendant's
return to the residence shall not invalidate this Order, which
can only be chanqed or .odified throuqh the tilinq of appropriate
court papers for that purpose. 23 Pa.C.S. 56113. Defendant is
turther notified that violation of this Order .a1 subject hia/her
to state charqes and penal tie. under the penn.ylvania Criaes Code
and to tederal charqes and penal tie. under the Violence Aqainst
Wo.en Act, 18 U.S.C. 55 2261-2262. Any Drotection order aranted
bY a court aay be considered in any subseauent Droceedinas.
inclUdinG child custOdY Droceedinas. under title 23 lDo.estic
Relations) of the pennsYlvania Consolidated Statutes.
HOTICI TO LAW EHrORCEKIHT OFFICIALS
This Order shall be enforced by the police who have
jurisdiction over Plaintiff'. residence OR any locations where a
violation of this ordar occurs OR where Defendant .ay be located.
If Defendant violates Paraqraphs 1 throuqh 6 of this order,
Defendant .ay be arrested on the charqe of Indirect Cri.inal
cont..pt. An arre.t tor violation of this Order .ay be .ade
without warrant, ba.ed solely on probable cau.e, whether or not
the violation is coaaitted in the pre.ence of law enforc..ent.
Mary Margaret Zayas-Bazan,
Plaintiff
:IN THE COURT OF COMMON PLEAS
:OF CUMBERLAND COUNTY, PENNSYLVANIA
vs.
:NO. 97 - 4368
CIVIL TERM
Stanley Jay Shannon,
Defendant
:PROTECTION FROM ABUSE
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiff's name is Mary Margaret Zayas-Bazan.
2. The name of the person, who seeks protection from abuse is
Mary Margaret Zayas-Bazan.
3. Plaintiff's address is 154 Faith Circle, Carlisle,
Pennsylvania.
4. Defendant is believed to live at the following address 15
Souths ide Drive, Newville, Pennsylvania.
Defendant's Social Security Number is 210-40-4332.
Defendant's date of birth is 11/25/54.
Defendant's place of emplo~ent is Pennsylvania State Liquor
Control Board, Licensing Department, Vartan Way, Harrisburg,
Pennsylvania.
5. Defendant is Plaintiff's former intimate partner.
6. Plaintiff and Defendant have been involved in the
following court actions for divorce, custody, support, or
protection from abuse:
Case name
Date filed Court
Case no.
PFA and CUstodv
Zayasbazan
vs
Shannon
97-4368
8/12/97 CUmberland County
of Common Pleas
7. The facts of the sost recent incident of abuse are as
follows:
i
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On or about May 17, 1999, Defendant screamed at
Plaintiff and smashed ice cream in her face in front of
Plaintiff'. children. When Plaintiff got out of the
car to clean herself off, Defendant's 7 year old
daughter kicked Plaintiff and called her a vile na.e.
When Plaintiff tried to reprimand Defendant's daughter,
Defendant punched Plaintiff in the face knocking her
glasses from her face causing bruises and swelling.
Defendant struck Plaintiff's son on the ear with an
open hand. Fearing for her safety and that of her
children, who were traumatized by the incident,
Plaintiff left the car and went for help. Plaintiff
sought medical treatment for her injuries.
8. Defendant has committed the fOllowing prior acts of abuse
against Plaintiff:
a. From May 15, 1999 to the present, in spite of his
being told that she wants no further calls from him,
Defendant harassed Plaintiff by repeatedly calling
her. Defendant has called Plaintiff 50 to 100 times
at both her home and work causing her to fear for
her safety.
b. In or about November of 1997, a Protection from Abuse
Order was entered under the above captioned number.
Plaintiff's fear of abuse is exacerbated because of
Defendant's history of abuse which included the
following: threats to kill Plaintiff; raising his arm
with a closed fist in a menacing manner; pouring beer on
Plaintiff and hitting her on the back of the head with a
beer bottle; pulling Plaintiff out of bed by her hair;
throwing her against a wall, shoving her; kicking her,
throwing a lit cigarette at Plaintiff's face; pushing
Plaintiff out of a vehicle as he backed out of a
driveway; slapping her about the face and head; and
hitting her in the forehead with a phone causing bruises
and a laceration. Defendant has also abused Plaintiff's
children in ways including: slapping them causing
bruises; grabbing; shaking; choking; repeatedly shoving;
and threatening to kill them.
9. Defendant has used or threatened to use weapons against
Plaintiff.
10. The following police department or law enforcement
agency in the area in which Plaintiff lives should be provided
with a copy of the Protection Order: North Middleton Township and
Carlisle Police Departments.
11. There is an immediate and pre.ent danger of further abuse
from Defendant.
12. Plaintiff is asking the Court to order Defendant to stay
away from the residence at 154 Faith Circle, Carlisle,
Pennsylvania, which is owned by Plaintiff.
WHEREFORE, PLAINTIFF R~QUESTS THAT THE COURT ENTER A TEMPORARY
ORDER, AND AFTER HEARING, A FINAL ORDER THAT WOULD DO THE
FOLLOWING:
A. Restrain Defendant from abusing, threatening, harassing, or
stalking Plaintiff in any place where Plaintiff may be found.
B. Order Defendant to stay away from Plaintiff's residence and
prohibit Defendant from attempting to enter any temporary or
permanent residence of Plaintiff.
C. Prohibit Defendant from having any contact with Plaintiff,
either in person, by telephone, or in writing, personally or
through third persons, inclUding, but not limited to any contact
at Plaintiff's place of employment, except as the Court may find
necessary with respect to partial custody and/or visitation with
the minor child.
D. Order Defendant to temporarily turn over weapons to the
Sheriff of this County and prohibit Defendant from transferring,
acquiring or possessing any such weapons for the duration of the
Order.
E. Order Defendant to pay the costs of this action, including
filing fees, service fees, and surcharge of $25.00.
F. Order Defendant to pay $250.00 to reimburse one of Legal
Services, Inc.'s funding sources for the cost of litigation in
this case.
G. Order the following additional relief, not listed above:
a. Defendant is required to relinquish to the sheriff any
firearm license the defendant ~ay possess. Defendant's weapons
and firearm license may be returned at the expiration of the
Protection Order after Defendant has submitted a written request
to the Court for the return of the weapons and the Court has
notified Plaintiff of the request and given Plaintiff an
opportunity to respond.
b. Defendant is enjoined from damaging or destroying any
property owned solely by Plaintiff,
c. Defendant is to refrain from harassing Plaintiff's
relatives or her minor children.
H. Grant such other relief as the court deems appropriate.
Order the police or other law enforcement agency to serve
Defendant with a copy of this Petition, any Order issued, and the
Order for Hearing. Plaintiff will inform the designated
~
..
MARY MARGARET ZA Y ASBAZAN,
Plaintiff
for herself and on behalf of her minor
children: RENE RYAN ZA Y ASBAZAN,
and IAN PATRICK ZA Y ASBAZAN,
: IN THE COURT OF COMMON PLEAS OF
: 2 lD
: CUMBERLAND COUNTY, PE~)1.. V ~A !?,
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: CIVIL ACTION - LAW ~, . ;':5 : ,5i
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v,
ST ANLEY JAY SHANNON,
Defendant
: NO, 97-4368 CIVIL TERM
~ONSENT AGREEMENT
'1'-
This Agreement is entered on this ~ day of September, 1997, by the plaintiff: Mary
Margaret Zayasbazan, and the defendant, Stanley Jay Johnson. The plaintiff is represented by
Joan Carey of LEGAL SERVICES, INC,; the defendant is represented by Charles Rector,
Attorney at Law, The panies agree that the following may be entered as an Order ofCoun,
I, The defendant, Stanley Jay Shannon, agrees to retrain from abusing the plaintiff:
Mary Margaret Za)'J'W7lI'l, or the minor children, Renee Ryan Zayasbazan and Ian Patrick
Zayasbm,\ or from placing them in fear of abuse,
2, The defendant agrees not to have any direct or indirect contact with the plaintiff or
ber minor child. Renee Ryan Zayasbazan, including, but not limited to. telephone and written
communications, except for the for the limited purpose of contacting the plaintiff to facilitate
custody ~gements
3. The defendant agrees not to harass and stalk the plaintiff and not to harass the
plaintift's relatives and the minor children,
4, Neither party will enter the other's place of employment. except in the event that
tbe defendant requires medical treatment at the plaintift's place of employment,
S. The defendant agrees not to enter the day care facility of the parties' minor child.
Ian Patrick ZI)'J''''''7lI'l, except for lhe limited purpose of transferring custody of the child on
designated dales,
.
6, The defendant agrees not to remove. damage. destroy. or sell any property owned
by the plaintiff.
7, The defendant agrees to stay away from the plaintift's residence located at 1S4
Faith Circle. Carlisle. Cumberland County. Pennsylvania, and the defendant agrees to stay away
from any residence the plaintiff may in the future establish for herself, except for the limited
purpose of transferring custody, The defendant will remain in his vehicle on the street at the aub
during transfer of custody,
8, The defendant agrees not to acquire or possess any weapons for the term of the
Protection Order. including constructive possession, Possession shall be construed as direct or
indirect control and/or constructive ownership or control of such weapons,
9. The defendant, although entering into this Agreement. does not admit the
allegations made in the Petition.
10, The defendant understands that the Protection Order entered in this matter will be
in effect for a period of one (I) year and can be extended beyond that time if the Coon finds that
the defendant has conunitted an act of abuse or has engaged in a pattern or practice that indicates
risk of harm to the plaintiff or the minor children, 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,
II. Violation of the Protection Order may subject the defendant to: i) IlTeSt under 2J
Pa,C,S, ~6113; ii) a private criminal complaint under 23 Pa.c.S, ~6113.l; iii) &charge of indirect
criminal contempt under 23 Pa.C,S, ~6114. punishable by imprisonment up to sht months and a
fine ors 100,OO-S 1,000.00; and iv) civil contempt under 23 PaCS ~6114,1.
12, The defendant and the plaintiff agree to the entry of an Order providins for the
following custody schedule for their child, Ian Patrick Zayasbazan,
a) The panies will share legal custody of the child,
b) The mother will have primary physical custody of the child,
c) The father will have panial custody of the child every third Saturday and
Sunday from 10:00 a,m, until 2:00 p.m. each day. and on the alternating Sunday
from 10:00 a.m. until 2:00 p,m" one weekday from 4:30 p,m. until 7:30 p,m,(day
to be mutually agreed upon by the parties), and on other dates and times mutually
agre:d uj'On by the panies, The father wUl commence the tllird Saturday and
Sunday schedule on October 11 and 12. 1997, unless other arrangements are
mutua1ly agreed upon by the parties,
d) The father and/or his mother. Arlene Shannon. will provide transportation
durins transfer of custody, The child will be secured in a car seat in the back seat
of the vehicle at all times when being transported,
e) The father will not use alcohol and/or illegal drugs immediately prior to or
during his periods of custody with the child,
t) The mother and father agree that each will notify the other of all medical
care the child receives while in that parent's care, Each parent will notify the other
inunediate1y of medical emergencies which arise while the child is in that parent's
eire:,
g) The parties realize that their child's well being is paramount to any
differences they might have between themselves, Therefore, they agree that
neither party will 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.
AUG - 2 1999,_ ')
,~~
MARY MARGARET ZAYAS-BAZAN, . IN THE CXllJRT OF ~ PLEAS OF
.
petitioner . CUMBERLAND COONTY, PENNSYLVANIA
.
.
.
va. . CIVIL ACTION - LAW
.
. NO. 97-4368
.
.
.
STANLEY JAY SHANNaI, .
.
Respondent, . IN eusrooy
.
amBR CP cnm
AND !Of, this 29th day of July, 1999, the Conciliator, being
advised by Plaintiff's counsel that all custody issues have been resolved
by ag~t of the parties, hereby relinquishes jurisdiction in this
cue. 11le Ol8tody Conciliation Conference scheduled for July 29, 1999, is
canceled.
roo TIlE CXlJRT,
~J. ,~
Dawn S. SUnday, Esqu re
CUstody Conciliator
.
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MARY MARGARET ZAYAS-BAZAN,: IN THE COURT OF COMMON PLEAS
Respondent/Plaintiff : CUMBERlAND COUNTY, PENNSYLVANIA
V,
STANLEY JAY SHANNON,
PelitionerlOefendant
: NO, 97-4368 CIVIL TERM
: CIVIL ACTION -LAW
: CUSTODY
PErmON TO MODIFY ORDER OF CUSTOQY
AND NOW, comes the Petitioner, Stanley J, Shannon, by and through his
attorney, Charles Rector, Esquire, and files a Petition to MOdify Order of Custody, and in
support thereof, aYers the fo/Iowing:
" Petitioner is Stanley J, Shannon, father, Defendant in the above-
caPtioned matter, Who CUrrently reSides at 15 Southslde Drive, Newville, Cumberland
County, Pennsylvania, 17241.
2, ResPDndent is Mary Margaret Zayas-Bazan, mother, Plaintiff in the
above-captioned matter. Who currently resides at 154 Faith Circle, Carlisle, Cumberland
County, Pennsylvania, 17013.
3, The parties hereto are the parents of the minor child Ian Patrick Shannon
(OOB 09I08tg5), Who currently resides With father at 15 Southslde Drive. NeWVille,
Pennsylvania, 17241.
4. On July 13, 1999, the Courtenlered an Order of CUStody, granting
shared /egaI custody and primary ph)'Sica/ custody to RllSpondent and P8ri0ds of
t8ll1porary ph)'Sica/ custody to Petitioner, A true and c::orrect copy of this Order is
marIled Exhibit "A. " attached hereto, and made part hereof.
I verify that the statements made herein are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904,
relating to unsworn falsification to authorities.
~j~ :T ~C~~
Stan J. Shannon
Date: /J- /'J- <!J I
Mary Margaret Zayas-Bazan,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 97- 4368
CIVIL TERM
Stanley Jay Shannon,
Defendant
PROTECTION FROM ABUSE
: AND CUSTODY
CUSTODY ORDn
AND NOW, this 13..t1...day of~1999, upon consideration of
the parties' Consent Agreement, the following Order is entered
with regard to custody of the parties' child, Ian Patrick
Shannon, Date of Birth: 09/08/95 .
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1. Plaintiff, Mary Margaret Zayas-Bazan, hereinafter ..&1 G-yrf
referred to as the mother, shall have primary physical ~ l~" ..~-
custody o~ the chil<;l. I I I /~ 11 f 30 a 0 l\~~
'<._ I1.c P...AIO s-h..lL Jht'rC ~... cloJt'(r .AO C- -, f ~\') '\\.'
2. Defendant, Stanley Jay Shannon, hereinafter referred to
as the father, shall have partial custody of the child according
to the following schedule:
a. Every third weekend from 4:30 p.m. on Friday until
7:30 p.m. on Sunday,
b. One other weekend a month from 4:30 p.m. on Friday
until 7:30 p.m. on Sunday such that the father
exercises an alternating w~ekend schedule.
c. One evening per week from 4:30 p.m. until 7:30
p.m., and
d. Other times agreed upon by the mother and father.
3. The parties shall alternate the following holidays:
Easter, Memorial Day, the Fourth of July, Labor Day, and
Thanksgiving with the father starting the rotation on the Fourth
of July in 1999.
4. The mother shall have the right to have the child on
EXHIBIT
'-11
Mother's Day, and the father on Father's Day from 9:00 a.m. until
7:30 p.m.
5. The Christmas holiday schedule shall be pursuant to the
following schedule:
a. The father shall have the child in odd numbered
years from 9:00 a.m. on December 24t1l until noon on
Christmas Day and in even numbered years from noon on
December 25th until noon on December 26th.
b. The mother shall have the child in odd numbered
years from noon on December 25t1l until noon on December
26th and in even numbered years from 9:00 a.m. on
December 24t1l until noon on Christmas Day.
6. The mother and the father shall have the right to see
the child on his birthday at a time to be agreed upon by the
mother and father.
7. The mother and the father shall have custody of the
child for two blocks of seven days each during the sUIIUller. The
two blocks shall not be consecutive. The mother and the father
will give each other two weeks notice as to when his or her
period of vacation will take place. The mother and the father
shall give each other a telephone number and address where he or
she may reach the child during the periods of summer custody.
8. The mother and the father, by mutual agreement, may
vary from this schedule at any '.:ime, but the Order Ehall remain
in effect until further order of court.
9. There shall be reasonable notice given to the other
party if a scheduled period of temporary custody needs to be
canceled or modified and a make-up period shall be offered within
a reasonable time frame.
10. The mother and the father shall exchange the child for
each period of custody at a mutually agreed upon public place.
11. The father shall not abuse alcohol and/or narcotics
during the time the child is in his care.
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MARY MARGARET ZAYAS.BAZAN.
Plaintiff
IN TIlE COURT 01' COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
97.4368
CIVIL ACTION LAW
STANLEY JAY SHANNON.
Dcfcndant
IN CUSTODY
ORDER OF COURT
AND NOW. this S"~ day of m~ , 2002,
upon consideration ofthc attached Custody Conciliation Report. it is ordered and directed as follows:
I. The prior Order of this Court dated July 13, 199<) shall continue in effect as modified by this
Order.
2. The parties shall engage in a course of counseling/mediation with a profcssional to be
selected by agreement of the parties and counsel. Thc purpose of the counseling/mediation shall be to
recstablish communication. addrcss conflicts which have arisen in connection with the custody
schedule and develop sufficient cooperation between the parties to enable them to effectively eo-
parent their Child. The parties shall attend a minimum of 6 scssions (unless otherwise recommended
by the mediator) and shall thereafter follow the recommendations of the mediator with regard to the
duration and frequency of the sessions. All costs which arc not reimbursed by insurance coverage
shall be shared equally between the parties.
3. If the parties are unable to resolve the outstanding custody issues through
counseling/mediation. the parties shall submit themseives and their Child to a custody evaluation to be
pcrfonned by a professional selected by agreement of the parties and counsel, The purpose of the
evaluation shall be to obtain independent professional recommcndations concerning custody
arrangements which will best serve the interests Of the Child. The parties shall sign all authorizations
deemed necessary by the evaluator in order to obtain additional infonnation pertailiing to the parties or
thc Child. All costs of thc evaluation shall be shared equally by thc partics.
4. Pending further OnIer of Court or agreement ofthc partics, provision 2 ofthc July 13. 1999
Ordcr is vacated and replaced with the following provision:
A. Thc Father shall hav'c custody of thc Child cvery weck from Friday at 7:00 p,m. through
Morn.lay at 7:00 p.m. and thc Mothcr shall have custody from Monday at 7:00 p.m. through
Friday at 7:00 p.m. Notwithstanding the fOl'Cb'Oing. on the last weekend of each month during
which the Mothcr dO\.'S not \Vork, thc Mothcr shall han: custody of the Child from Friday at
7:00 p.m. through Sunday at 7:00 p.m. and the Father shall have custody from Sunday at 7:00
p.m. through Monday at 7:00 p.m.
MARY MARGARET ZA Y AS-DAZAN
l'l.AllIITll'1'
IN Till, COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
97-4368 CIVIl. ACTION 1.AW
STANLEY JAY SHANNON
DEFENDANT
IN CUSTODY
ORDER OF eOl iRT
AND NOW, Friday, May 30, 2003 . upon consldL-ration ofthc attached Complaint.
it is hereby directed that partics and their respectivc counsel appear hefore ~!:" S.Jiull<laj,_~.___, the conciliator,
at 39 WnlMaln Slreel, MecballlcsbufI, PA 17055 on Tbunday, J_ 26. 2003 at 10:30 AM
tor a Pre-lIearing Custody Confl-rence. AI such conference. an dfort will be made 10 resolvc thc issues in dispute: or
if this cannot be accomplished. 10 define and narrow the issul" to he hC'4rd by tbe court. and to enter into a tcmporary
order. All children a~c five or older may also he present at the conl....n'llcc. Failure to appear at thc conl'Crcncc may
provide grounds for entry of a temporary or permanent order.
Tbe court bereby direcls tbe parties to furnish any and aU edsting Protettion from Abase orders,
Special Retief orders, and Cnstody orden to tbe condliator 48 boun prior to sebeduled hearlllll.
fOR TIlE COURT.
By: '"
Daflltf S. Slllt~. EJq.
Custody ConCiliator
The Court of Common Picas of Cumberland County is required by law to L'tnnply with tbe
Americans with Disabilites Act of 1990. I'or information abouI acccssiblc faeihties and reasonablc
accommodations available to disabled individuals having bUSlllCSS hefore the court. plca,;e contact our office.
All amngemcnlS must be made atlcast 72 hours prior 10 any bearing or busines.s before lhe court. You must
allcnd the scheduled conference or hearing.
YOU SIIOULD TAKE nlls I'APER TO YOUR "nORNEY AT ONCE. IF YOU 00 NOT
IIA VE AN A TIORNEY OR CANNOT ,\I:FORD ONE. (j{) T() OR TFlEPllONE TIlE OffICE SET
fORm BELOW TO FIND our WIIERE YOU CAN (iET IHiAl.IIB.!'.
Cumberland ('OUl'ty liar "s"oeiali<,"
32 South B.-dli>nl Strt'd
Carlt.Ic.I'I.-nnsyhama 1701.l
TrlL-phllnr (7171241)..311\6
,
MARY MARGARET ZAYAS-BAZAN,: IN THE COURT OF COMMON PLEAS
Respondent/Plaintiff : CUMBERLAND COUNTY. PENNSYLVANIA
V.
STANLEY JAY SHANNON.
Petitioner/Defendant
: NO. 97-4368 CIVIL TERM
: CIVIL ACTION - LAW
: CUSTODY
PennON TO MODIFY ORDER OF CUSTODY
AND NOW. comes the Petitioner. Stanley J. Shannon. by and through his
attorney, Charles Rector. Esquire. and files a Petition to Modify Order of Custody. and in
support thereof. avers the fo/Iowing:
,. Petitioner is Stanley J. Shannon, father, Defendant in the above-
captioned matter, who currently resides at 15 Southside Drive, Newville. Cumberland
County, Pennsylvania, 17241.
2. Respondent is Mary Margaret Zayas-Bazan, mother, Plaintiff in the
above-captioned matter, who currently resides at 154 Faith Circle. Carlisle. Cumberland
County, Pennsylvania, 17013.
3. The parties hereto are the parents of the minor child Ian Patrick Shannon
(DOB 09108I95), who currently resides With father at 15 Southside Drive, Newville,
Pennsylvania. 17241.
4. On March 5. 2002. the Court entered an Order of Custocly which provided
inter alia for the parties to participate in counselinglmediation for a minimum of six (6)
sessions. A true and correct copy of this Order is marlled Exhibit "A: attached hereto
and macIe a part hereof.
MARY MARGARET ZA Y AS-BAZAN,
Plaintiff
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
97-4368
CIVIL ACTION LAW
STANLEY JAY SHANNON.
Defcndant
IN CUSTODY
ORllER OF COIlRT
AND NOW, this !5 th day of
upon consideration of the attached Custody Conciliation Repo
,2002,
it is ordered and directed as follows:
Order.
I. The prior Ordcr of this Court dated July 13. 1999 shall continue in e!Tect as modified by this
2. The parties shall engage in a course of counseling/mediation with a professional to be
selected by agreemcnt of the parties and counsel. The purpose of the counseling/mediation shall be to
reestablish communication. address conllicts which have arisen in connection with the custody
schcdule: and dcvelop sufficient coopcration betwecn the parties to enable them to effectively co-
parent their Child. The parties shall attcnd a minimum of 6 sessions (unless otherwise recommended
by the mediator) and shall thcreafter follow the recommendations of the mediator with rcgard to the
duration and frequency of the sessions. All costs which arc not rcimbursed by insurance coverage
shall be shared equally betwcen the parties.
3. If the parties are unable to resolve the outstanding custody issues through
counscling/mediation. the parties shall submit themselvcs and their Child to a custody evaluation to be
perfonned by a professional selected by agreement of the parties and counsel. The purpose of the
evaluation shall be to obtain independent professional recommendations concerning custody
arrangements which will best serve the interests of the Child. The parties shall sign all authorizations
deemed necessary by the evaluator in order to ohtain additional infonnation pertaining to the parties or
the Child. All costs of the evaluation shall be shared equally by the parties.
4. Pending further Order of Court or agrecment of the parties, provision 2 of the July 13, 1999
Order is vacated and replaced with the following provision:
A. The Father shall have custody of the Child every week from Friday at 7;00 p.m. through
Monday at 7:00 p.m. and the Mother shall have custody from Monday OIl 7:00 p.m. through
Friday at 7:00 p.m. Notwithstanding the foregoing, on the last weekend of each month during
which the Mother does not work. the Mother shall have custody of the Child from Friday at
7:00 p.m. through Sunday at 7;00 pm. and lhe Father shall have custody from Sunday at 7:00
p.m. through Monday at 7;00 p.m.
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C. The Father shall he entitled to haw custody of the Child upon providing reasonable
advance notice to the Mother. for.1I1 additional ten days each summer with no more
than two of the ten days to be scheduled consecutively unless otherwise agreed between
parties. II is the parties' intention tn balance the custody schedule during the summer so
that neither party monopnliles time with thc Child for an extended period without
substantial time with thc othcr parcnt.
4. The parties shall share or altemate having custody of thc Child on holidays as follows:
A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall
run from Christmas he at l):OO am through Christmas Day at 12:00 noon and Segment
B, which shall run from Christmas Day at I 2:()0 noon through December 26th at
12:00 noon. In odd numbered years, the Father shall have custody of the Child during
Segment A and the Mother shall have custody during Segment B. In even numbered
years, the Mother shall have custody of the child during Segment A and the Father shall
have custody during Segment B.
B. SHARED OR AL TERNA TED HOLIDAYS: The parties shall share or allemate
having custody of the Child on Easter. Memorial Day, July 41h. Labor Day, and
Thanksgiving each year with the specific holiday custody periods to be arranged by
agreement.
C. HALLOWEEN TRICK OR TREAT NIGHT: The Mother shall have custody of the
Child for Halloween Trick or Treat night every year.
D. MOTHER'S DAY I FATHER'S DAY: In every year. the Mother shall have custody
of the Child on Mother's Day and the Father shall have custody on Father's Day from
9:00 am until 7:30 pm.
E. CHILD'S BIRTHDAY: Each party shall be entitled to have contact with the Child
on the Child's birthday each year with the specific times to be arranged by agreement.
F. The holiday custody schedule shall supersede and take precedence over the regular
custody schedule.
5. The parties agrec that the Carlisle School District is the appropriate district for continued
enrollment of the Child and therefore. for educational purposes. the Mother's residence shall be the
primary residence of the Child.
6. The parties agrec that the Child's religious training shall take precedence over other
activities.
7. Each party shall provide the other parent with reasonable notice ifhe or she needs to cancel
or make an adjustment to a custodial period.
MARY MARGARET ZAYAS-BAZAN,:
Respondent/Plaintiff :
Vo
STANLEY JAY SHANNON,
Petitioner/Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
:
: NO. 97-4368 CIVIL TERM
:
: CIVIL ACTION - LAW
:CUSTODY
PETITION TO MODIFY ORDER OF CUSTODY
AND NOW, comes the Petitioner, Stanley J. Shannon, by and through his
attorney, Charles Rector, Esquire, and files a Petition to Modify Order of Custody, and in
support thereof, avers the following:
1. Petitioner is Stanley J. Shannon, father, Defendant in the above-
captioned matter, who currently resides at 15 Southside Drive, Newville, Cumberland
County, Pennsylvania, 17241.
2. Respondent is Mary Margaret Zayas-Bazan, mother, Plaintiff in the
above-captioned matter, who currently resides at 154 Faith Circle, Carlisle, Cumberland
County, Pennsylvania, 17013.
3. The parties hereto are the parents of the minor child lan Patrick Shannon
(DOB 09/08/95), who currently resides with father at 15 Southside Drive, Newville,
Pennsylvania, 17241.
4. On March 5, 2002, the Court entered an Order of Custody which provided
inter alia for the parties to participate in counseling/mediation for a minimum of six (6)
sessions. A true and correct copy of this Order is marked Exhibit "A," attached hereto
and made a part hereof.
5. The parties completed their counseling/mediation with Stanley E.
Schneider, Ed.D., RCE.
6. The parties current custody arrangement is a shared arrangement with
Father having approximately 15-18 overnights per month. This arrangement has been
in effect for approximately three (3) years and provides the child with continuing contact
with both parents.
7. Despite this arrangement, Respondent has refused to formalize same
through a proposed stipulation and court order.
8. The current Order of Court (see Exhibit "A") further provides that in the
event that counseling/mediation is unsuccessful, the parties would submit themselves
and their child to a child custody evaluation.
9. Under the present circumstances of this case, no issues remain
outstanding which require a custody evaluation.
WHEREFORE, Petitioner, Stanley J. Shannon, respectfully requests that your
Honorable Court grant him a hearing on the merits of the case without the necessity of a
custody evaluation and to grant him an Order of Custody consistent with the physical
arrangement of the parties which has been ongoing for a~3) years.
1Cll'ii~leFSerRnewC~°o~ ~uree, Ste. 203
Camp Hill, PA 17011-6912
(717) 761-8101
Date: '~/~'J//~ $
I verify that the statements made herein are true and correct. I understand that
false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904,
relating to unsworn falsification to authorities.
~-~ St~an y J.~hanno~nA''t-'~'~
Date:
CERTIFICATE OF SERVICE
I, Charles Rector, Esquire, do hereby certify that on the ~),2 day of May
2003, I caused a true and correct copy of the within Petition to Modify Order of Custody
to be served upon the following counsel of record by depositing same in first class,
United States mail, postage paid, in Camp Hill, Pennsylvania:
Date: '~'/~2/~ '~
Mark C. Duffle, Esquire
Johnson, Duffle, Stewart & Weidner
301 Market Street
P. 0. Box 109
Lemoyne, PA 17043-0109 ~.~.~-.~"~ ....
By: ~-- ~----~"~ ~
Charles F~e~or,-~q uire
1104 Fer~wbod Avenue, Ste. 203
Camp Hill, PA 17011-6912
(717) 761-8101
MARY MARGARET ZAYAS-BAZAN, :
Plaintiff :
:
vs. : 97-4368
:
STANLEY JAY SHANNON, :
Defendant : IN CUSTODY
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CWIL ACTION LAW
ORDER OF COURT
upon consideration of the attached Custody Conciliation Repo~ it is ~rd~red and directed as follows:
1. The prior Order of this Court dated July 13, 1999 shall continue in effect as modified by this
Order.
2. The parties shall engage in a course of counseling/mediation with a professional to be
selected by agreement of the parties and counsel. The purpose of the counseling/mediation shall be to
reestablish communication, address conflicts which have arisen in coimection with the custody
schedule and develop sufficient cooperation between the parties to enable them to effectively co-
parent their Child. The parties shall attend a minimum of 6 sessions (unless otherwise recommended
by the mediator) and shall thereafter follow the recommendations of the mediator with regard to the
duration and frequency of the sessions. All costs which are not reimbursed by insurance coverage
shall be shared equally between the parties.
3. If the parties are unable to resolve the outstanding custody issues through
counseling/mediation, the parties shall submit themselves and their Child to a custody evaluation to be
performed by a professional selected by agreement of the parties and counsel. The purpose of the
evaluation shall be to obtain independent professional recommendations concerning custody
arrangements which will best serve the interests of the Child. The parties shall sign ali authorizations
deemed necessary by the evaluator in order to obtain additional information pertaining to the parties or
the Child. All costs of the evaluation shall be shared equally by the parties.
4. Pending further Order of Court or agreement of the parties, provision 2 of the July 13, 1999
Order is vacated and replaced with the following provision:
A. The Father shall have custody of the Child every week from Friday' at 7:00 p.m. through
Monday at 7:00 p.m. and the Mother shall have custody from Monday at 7:00 p.m. through
Friday at 7:00 p.m. Notwithstanding the foregoing, on the last weekend of each month during
which the Mother does not work, the Mother shall have custody of the Child from Friday at
7:00 p.m. through Sunday at 7:00 p.m. and the Father shall have custody from Sunday at 7:00
p.m. through Monday at 7:00 p.m.
B. The parties shall make every effort to cooperate in restoring flexibility to the custody
schedule. Any agreement by one party to afford the other party additional periods of custody
beyond that provided in this Order beginning on the date of the Custody Conciliation
Conference shall be deemed to be without prejudice to that party's position in final disposition
of the custody issues.
5. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation
Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
cc~Charles Rector, Esquire - Counsel for Father
~lark C. Duffle, Esquire - Counsel for Mother
K~vi'r/tA. Hess,--
Jo
MARY MARGARET ZAYAS-BAZAN,
Plaintiff
VS.
STANLEY JAY SHANNON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
97-4368 CIVIL ACTION LAW
IN CUSTODY
PRIOR JUDGE: Kevin A. Hess
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
Ian Patrick Shannon
DATE OF BIRTH
September 8, 1995
CURRENTLY IN CUSTODY OF
Mother
2. A Conciliation Conference was held on February 26, 2002, with the following individuals in
attendance: The Mother, Mary Margaret Zayas-Bazan, with her counsel, Mark C. Duffle, Esquire, and
the Father, Stanley J. Shannon, with his counsel, Charles Rector, Esquire.
3. The parties agreed to entry of an Order in the form as attached.
Date
Dawn S. Sunday, Esquire
Custody Conciliator
MARY MARGARET ZAYAS-BAZAN,
Plaintiff
VS.
STANLEY JAY SHANNON
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
97-4368 CIVIL ACTION LAW
CUSTODY
ORDER OF COURT
AND NOW, this Z t" day of ~ , 2003, upon
consideration of the attached Custody Conciliation Report, it ii ordered and directed as follows:
1. The prior Order of this Court dated March 5, 2002 is vacated and replaced with this Order.
2. The Mother, Mary Margaret Zayas-Bazan, and the Father, Stanley Jay Shannon, shall have
shared legal custody oflan Patrick Shannon, bom September 8, 1995. Each parent shall have an equal
right, to be exercised jointly with the other parent, to make all major non-emergency decisions
affecting the Child's general well-being including, but not limited to, all decisions regarding his health,
education and religion. Both parties shall inform each other of the Child's educational and medical
development. Both parties shall be entitled to complete information regarding the Child from any
doctor, dentist, teacher or similar authority and copies of any reports, notices or communications
regarding the Child. The parties shall notify each other promptly of any medical emergencies
concerning the Child.
3. The parties shall have physical custody of the Child as follows:
A. The Mother shall have custody every week from Monday morning before school or a
time arranged by agreement through Thursday after school or after the Father's work.
The Mother shall also have custody for one weekend each month when she is not
working.
B. The Father shall have custody of the Child every week from Thursday after school or
after work through Monday morning before school, or if there is no school, at a time to
be arranged by agreement of the parties. During weeks immediately preceding the
Mother's weekend period of custody, the Father shall have custody from Thursday after
school or after work through Friday before school,or if there is no school, at a time to be
arranged by agreement.
C. The Father shall be entitled to have custody of the Child upon providing reasonable
advance notice to the Mother, for an additional ten days each summer with no more
than two of the ten days to be scheduled consecutively unless otherwise agreed between
parties. It is the parties' intention to balance the custody schedule during the smnmer so
that neither party monopolizes time with the Child for an extended period without
substantial time with the other parent.
4. The parties shall share or alternate having custody of the Child on holidays as follows:
A. CHRISTMAS: The Christmas holiday shall be divided into Segment A, which shall
run from Christmas Eve at 9:00 am through Christmas Day at 12:00 noon and Segment
B, which shall run from Christmas Day at 12:00 noon through December 26th at
12:00 noon. In odd numbered years, the Father shall have custody of the Child during
Segment A and the Mother shall have custody during Segment B. In even numbered
years, the Mother shall have custody of the child during Segment A and the Father shall
have custody during Segment B.
B. SHARED OR ALTERNATED HOLIDAYS: The parties shall share or alternate
having custody of the Child on Easter, Memorial Day, July 4th, Labor Day, and
Thanksgiving each year with the specific holiday custody periods to be arranged by
agreement.
C. HALLOWEEN TRICK OR TREAT NIGHT: The Mother shall have custody of the
Child for Halloween Trick or Treat night every year.
D. MOTHER'S DAY / FATHER'S DAY: In every year, the Mother shall have custody
of the Child on Mother's Day and the Father shall have custody on Father's Day from
9:00 am until 7:30 pm.
E. CHILD'S BIRTHDAY: Each party shall be entitled to have contact with the Child
on the Child's birthday each year with the specific times to be arranged by agreement.
F. The holiday custody schedule shall supersede and take precedence over the regular
custody schedule.
5. The parties agree that the Carlisle School District is the appropriate district for continued
enrollment of the Child and therefore, for educational purposes, the Mother's residence shall be the
primary residence of the Child.
6. The parties agree that the Child's religious training shall take precedence over other
activities.
7. Each party shall provide the other parent with reasonable notice if he or she needs to cancel
or make an adjustment to a custodial period.
8. The Father shall not abuse alcohol or narcotics during the time the Child is in his care.
9. The parties shall insure that the Child is not exposed to illegal drug use by any individuals
during his or her periods of custody.
10. Neither party shall do or say anything which may estrange the Child from the other parent,
injure the opinion of the Child as to the other parent, or hamper the free and natural development of the
Child's love and respect for the other parent. Both parties shall ensure that third parties having contact
with the Child comply with this provision.
11. This Order is entered pursuant to an agreement of the parties at a Custody Conciliation
Conference. The parties may modify the provisions of this Order by mutual consent. In the absence of
mutual consent, the terms of this Order shall control.
BY THE COURT,
KeTHess
cc: ~k C. Duffle - Counsel for Mother
,~arles Rector, Esquire - Counsel for Father
MARY MARGARET ZAYAS-BAZAN,
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
97-4368 CIVIL ACTION LAW
STANLEY JAY SHANNON
Defendant
: IN CUSTODY
PRIOR JUDGE: Kcvin A. Hess
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL
PROCEDURE 1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Child who is the subject of this litigation is as
follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Ian Patrick Shannon
September 8, 1995
Mother / Father
2. A Conciliation Conference was held on June 26, 2003, with the following individuals in
attendance: The Mother, Mary Margaret Zayas-Bazan, with her counsel, Mark C. Duffle, Esquire, and
the Father, Stanley Jay Shannon, and his counsel, Charles Rector, Esquire.
3. The parties agreed to entry of an Order in the form as attached. Submission of this Report
and Order was delayed pending guidance from the Carlisle School District as to the necessary
language for paragraph 5 of the Order.
Date
Dawn S. Sunday, Esquire
Custody Conciliator