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Home My WebLink About97-04442 I I ~ I . .~ - ~ Ii ~ )- j- ~~,. 0-' I I ,// ~ ;:- 'J'. rd ~ " ~ ~ ~ l~ 0~ ;.J ;) .0 ~\ ., ;) ~ ~ ~ ir. g, i:: .0 '., " ~ co: J\ 6~ .. ;-: :r- 7- P>lS - ~).'l" '" ~~. - ~~~,~ ~ ;...: Ov....<r -', ~.... ,C 'I) . ;I. ~..I $ CW ti-;, ~n >-7 {"t ~-", -I" c.~ l~1t~j II) ~ ". :a ~'J 0.;. ~ ~ r- ~ ~ - a' ~ eJ _ 0 U .. a: J: It S om~ I~~ i Dalla :IIG; J:' I -i E- Ii >>- t .. 5 ! i ! w . "Ii '1 ! .. .. j. ~J 11 l ..... f~ j . . . -'I CUNNINGHAM, ctfIN.CDPF. p.c. ,'#.1'. '-' FELICIA ANN BAKER, . IN THE COURT OF COMMON PLEAS OF , Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA . . v, . CIVIL ACTION - LAW . . PROTECTION FROM ABUSE . JAY RANDALL BAKER, : Defendant , No, 97-4442 CIVIL TERM . ORDER OF COURT AND NOW, this 25th day of August, 1997, upon consideration of the Petition for Protection from Abuse filed in the above-captioned matter, and pursuant to an agreement reached in open court between the parties in the presence of their counsel, it is ordered and directed that the Petition for Protection from Abuse be deemed withdrawn. By the Court, / /' PAIGE MACDONALD-MATl'HES, For the Plaintiff ;,s.! Wesley ( / ESQUIRE _ C~r"" ...._~..( ')IJ/~\,. DIANE G. RADCLIFF, ESQUIRE For the Defendant "" Sheriff vcy Ii it , [! Ii it ~ ' L i: Ii il II I I i I ! i II 'I " " j! ii I: 'J II n Ii Ii " " " " " Ii H " ,. i: up residence in Grand Cayman, in the Cayman Islands. 9. On or about March 7, 1997 the Respondent was deported by the government of Grand Cayman as a result of his arrest for driving under the influence. 10. While the Respondent was out of the country, the Respondent repeatedly continued to verbally abuse Petitioner to wit: a. During the second week of February, 1997, Respondent telephone Petitioner and demanded an answer froll Petitioner as to whether she would H " i< " 'I !. H q Ii H Ii <- I' II ,~ " Jl ij 11 q h i~ II " u Ij rJ " ';t n H Ii H d 11 }I reconcile with him. When Petitioner informed him that there would be no reconciliation, Respondent became enraged and stated, "I don't want to be mad, I don't want to be angry at you, but I can't help ayself," Respondent further stated that he was diaqnosed a. being "hi-polar" and that "he needed help", Within aoaents of this admis.ion, however, a.spondent aqain bee... angry with l'etltlOMr and eventually hWlCJ up on her. 11 ~ ~~ ,; 1 I I .1 It Ii r II 1/ , I' ,I , i I I i , I , , I' ,I 'I " f' II Ii I' II it Ii " ,i I i I I i !I 'I il ~I 'I iI \; H ~j Ii !r 11 Ii l"! f!' " 11 fi , N il with anything relating to the movie. b. On July 27, 1997 the Petitioner, the parties' two minor children and Petitioner's friend attempted to go on a boating excursion, leaving from the City Island Boat dock in Harrisburg, Pennsylvania. The Respondent arrived at the dock and proceeded to verbally harass Petitioner to such an extent that the owners of the Marina had to physically remove Respondent from the dock. c. On July 28, 1997 the Respondent made ten (10) harassing phone calls to Petitioner wherein he threatened he would "take the Children," that he would "get her back" (the Petitioner and Respondent are separated and there is a divorce action pending in CUmberland County at Docket 197-2703 and that "she would be sorry." d. Between July 30, 1997 and July 31, 1997 Respondent continued to make harassing phone calls to Petitioner at her place of work necessitating co-workera to have to intercept the calls: e, Petitioner believe. and therefore avera that on or about August 5, 1997, Respondent attempted to break into her apartJlent by going through her daUlJbtert. bedl'OOll window. Petitioner reported thla to bel' 5 landlord: f. On August 11, 1997 Respondent went to Petitioner's mother's cottage located at 300 Campground Road, Dillsburg, Pennsylvania to "seek her help to get Petitioner back." When Petitioner's mother refused Respondent's request and shut her door on Respondent, Respondent kicked in the door and proceeded to verbally accost Petitioner's mother. The state Police were called and a report I I I' was filed with the Dillsburq Barracks of the Pennsylvania Police, g. On or about August 12, 1997 while Petitioner was out of town. Respondent again broke into her apartment and left flowers and a card which atated that "he was sorry" and that "he loved her." ! Ii II !1 U. The Re.pondent bas pbyaically abused Petitionu and lj I the minor children in the past. The followine) are 110M of ~ Ii I 6 " U h. On August 12, 1997 Respondent left several aeasages on Petitioner's answering machine concemine) bis unvilline)ness to have the marriage end and bis desire to ..et in person with Petitioner to "dlacuss thine)s." I II Ii " I: ,I Ii " :i " I: I I I II any contact with the Petitioner, including, but not limited to, restraining the Respondent from entering the residence or work place of the Petitioner, as well as the parties' minor children's school: and ; I II 'I L Ii I' I: if ii I (iii) Granting Petitioner Sole legal and physical custody of the parties' two (2) minor children. b, Schedule a hearing as required by the Protection from Abuse Act, and after such hearing, enter an Order effective for one (1) year, to include the relief set forth above and including the following relief: I. !; ,; ii 11 1J i: I' [; !! ii (i) Ordering Respondent to pay I ~ Ii " Ii jj :i 'i i ~ Ii II I, ji f! :: Petitioner's attorney's fees: and (ii) Ordering Respondent to pay all costs associated with the filing and service of this action. Respectfully submitted, CUNNINGHAM' CHERNICOFF, p.e, .' Date I Auaust ,I. 1997 ----'.. , By: p~1q~'&~~~ltMatth~.;\~t:i 1.0, 166266 2320 North Second Street P.O. Box 60457 Harrisburg, PI. 17106-0457 (717) 231-6570 (Attorneys for Petitioner) 11 c' ;: