Loading...
HomeMy WebLinkAbout97-05333 ~ '-I " , 'I " , " I, : , iJ )1'1 .' "i' , , " " , , , " I, " " 'r '-I!' ! ,. , ,I 'I " " i'l /,1 I ~ I , I " I , , , , :-11 , " , ;, II " , , I , ., , ! I , " I , , ,I " " ,(I , , , " ,I " '., .. " I '/, , " , I I , " " , ., I , I' , " II ., I, ,,' ,I, ',' .1,11 ~ ~ ~ " '1 I ~, " I , r , , ,'I , .1 , I "1 , I , , '" , I '" , !/", I , ., ,.,1\ I. ',i" " "I " , I" I " " I" , '1'\ rill'" 1,1 I 'ii, ,r ., " "1' " , , ,'( " I " " , " I') ,'" , ' ,II ,I!, " ," " 'j.1 " ':"; ,'}:; '" II' ., II ,I , 'I , , ., 'I , , , ," " , I,' , , , , , ." \, '" I !, , :'1'1 ',I j 'oi I I , . , I ,I) , , :I (", t I ~ " " "., , , , \'1 , I II I , , ! ~ , i.t. ~ , I Ii , ,', oi', " , Ii , , , , , , " , ,.-' , , : :~i ,,' I'}:'l' 'I , , , " " ." I :[ , , , .1, ',' i't I ) " I q d~ -'J i 'j' il' , ~l II, :;;, "I ,,~, \;ll .. 1..,\ II" ..I' .(i' ,J\\__ , ,It I I \i.. Ir, ,,1ft: '..;" ,.,;.. " " , .1 ~i\ :!,lD- , '.',IA IJ: "~ '1, ," I,' , .' , , " Ii , II, ;,\ I " ',I ,', , "I?, 'I \YI~~.t tl",'.~ " :11<' , 1,1 " to arrange partial custody of the children, and then only by telephone or with a third party present. A full and final hearing shall take place on the .JJ..d day of October, 199'7, at /'(,)() o'clock _C-.M. in Courtroom No. ~ of the Adams County Courthouse, Gettysburg, Pennsylvania. The Defendant is directed to report 15 minutes before the hearing. If the Defendant fails to appear at the hearing, the case will proceed in his absence. The fact that the hearing date set out above may have passed shall not of itself affect the validity of this Order. The existence and content of this and other Orders in this case may be verified by contacting Adams County Control, Courthouse, 111 Baltimore Street, Gettysburg, Pa. 17325, tel. (717) 334-8101. The Sheriff of Adams County shall have the primary duty to forthwith serve and execute this Order and Petition, which also may be served by any competent adult. A violation of this Order may subject Defendant to arrest for criminal contempt, imprisonment for up to six months, a fine of up to $1,000.00, and civil contempt proceedings. The Defendant has the right to have an attorney to represent him in this matter. IF HE DOES NOT HAVE A LAWYER, HE SHOULD GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE HE CAN GET LEGAL HELP. Court Administrator Adams County Courthouse 111-117 Baltimore Street Gettysburg, Pa, 17325 (717) 334-6781 ext. 213 , The Defendant has the right to a hearing, at which Plaintift, .- has the burden vf proving, by a preponderance of the evidence, that Defendant has abused her, as "abuse" Ln defined in the law, 23 Pa. C,S. 56102(a), If the Plaintiff did not prove her case, no order would be entered. However, Lf there is 11 hearing at which the Plaintiff proves her case and the Court does enter an order, the Defendant must pay 11 surcharge of $25.00, in addLtion to court costs. The Defendant also has the right to agree that tho Court may enter an order against him, without a hearing, while either ad- mitting or not admitting that he has abused Plaintiff. There is no surcharge in such a case. If the Defendant wishes to agree to the entry of an order, he or his attorney should contact Plain- tiff's attorneys, Legal Services, Inc., 432 South Washington st., Gettysburg, Pa. (717) 334-7623. An order entered by agreement has the same force and effect and is subject to the same penalties for violation as an order entered after a hearing. Copies of this Order shall be provided to the Pennsylvania state Police at the Gettysburg substation, Adams County control, the Warden of the Adams county prison, the Sheriff of Adams County, each District Justice within Adams County, the Bendersville Police Department, Cumberland County Prothonotary's Office, the Carlisle Barracks of the Pennsylvania State Police, and Survivors, Inc. Any pOlice officer who has probable cause to believe that the Defendant has violated or is viOlating this Order is authorized to arrest the Defendant without a warrant. If an arrest occurs when it would be feasible to produce the Defendant before this Court, it shall be done without unnecessary I ,'. , , ~ a. ',.J .., ..:J ,... I-~I .~ C .. ." ~J.I._.I ("l ') .- d;", I .~ 1.1-, r~:: ,- ~~:, :!. -;':'1 ;)1 ':T' o " ~ . .' " ('oJ 1< n:~~ fu \. :\1) " F' v: ';~1...,. b ~ ~ (S ~ " I, " , II" ", " , . " 'I' " , , i, " ... ('u.n\\).)_~rnd (10",,1.,--\ I~v. '1'1 - ~) '.~',,->,:> C..:u:..c Tt'rp. IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA RANDI L. BOBB, Plaintiff No. 97-5-909 VB. . BRAD M. BOBB, OOB: 5/16/70 SSN: 199-56-7731 Defendant Protection from Abuse o R D E R ? fIJ.-.. AND NOW, this 11\ day of October, 1997, pursuant to his Aft idavit and Consent Agreement and without admitting Plaintiff's allegations of abuse, Defendant has waived his right to a hearing and agreed that the Court may enter this Order. Based on that Affidavit, the Defendant is ordered not to abuse, threaten with violence, harass or stalk the Plaintiff. Defendant is evicted from the marital residence at 119 Laurel Lane, Bendersville, Pa., and sole and exclusive possession is granted to Plaintiff. The eviction portion of the Order is suspended so long as Defendant faithfully obeys the remaining portions of the Order. Defendant shall not remove, damage, or destroy any of Plaintiff's personal property. Defendant shall contact a counselling center and he shall follow any recommendation for treatment. If the parties separate voluntarily or inVOluntarily, Plaintiff shall be granted temporary custody ot the minor children. :- ..,.:. I~/) 19f~ a.nll r tt,,(;t~d a,',J ,:om..~rcd , " . t : . .Xl Defendant shall pay the costs of this action. He shall have ninety days in which to do so. This Order shall remain in full force and effect for one year, the maximum period permitted by law, beginning this date, The Defendant is notified that a violation of this Order may subject him to arrest for criminal contempt, imprisonment for up to six months, a fine of up to $1,000,00, and civil contempt proceedings. Copies of this Order shall be provided to the Pennsylvania state Police at the Gettysburg substation, Adams County Control, the Warden of the Adams County prison, the Sheriff of Adams County, each District Justice within Adams County, the Bendersville Police Cumberland the county Department, Prothonotary's Office, the Carlisle Barracks of the Pennsylvania state Police, and Survivors, Inc. Any police officer having pro- bable cause to believe that the Defendant has violated or is violating this Order is authorized to arrest the Defendant with- out a warrant. If the arrest occurs when it would be feasible to produce Defendant before this court, it shall be done without unnecessary delay. If arrest occurs otherwise, the Defendant shall be taken to a District Justice to be arraigned and have bail set. A hearing will then be scheduled in accordance with Adams County practice. If the Defendant fails to post bail, he shall be produced before this Court at thE! first available opportunity. BY THE COURT, This being a true opy taktm from ith tho original r- C~"'''t'- . ~) J. , );/ (1-~{~/( , , ijl ! " Ii! ," " I, I " , , 'I ,! " ': " , , , , i1~ 1"'" ',.. I... " ,I' - " LJ J t::~ " !-'j., t' ~ i~J ~ J; (.>~{ ..,.' 'J:"I rf ~ .. I~, t....':, ~l,. , \ "-;:-;:' , , ~) :. I , . ,-. ,Ii-' )' , ., . :~. lll" .-.. '.:\~-: ' G-.': I..' t~ j L) , " c_, I '.-!lJ- I I C;;; ~ U. r- <J C1' " , , , ' I, '" I, , , I " " 'I I ,. .. . 97- S JJ,J eWl l 'Ti ~ IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA RANDI L. BOBB, No. 97-S-909 Plaintiff vs. BRAD M. 'BOBB, Defendant Protection from Abuse ORDER AND NOW, thi&~) day Of'~, 1998, the attacheGt, verified upon presen- tation and consideration of petition for modification and extension of protection ordor, the Court enters the following Order, which shall remain in effect until modified or terminated, after notice and hearing. The protection order entered on October 2, 1997, as modif ied by the order of October 27, 1997, is further modified to provide that Defendant shall have no contact with Plaintiff whatsoever, in person, by telephone, by mail, or by any other means; that Plaintiff is awarded legal and physical custody of the parties' children; that Defendant is prohibited from entering the Capitol city Mall or its parking area, or from coming within 100 yards of the mall or its parking area; that Defendant is ordered not to have any firearms or weapons in his possession or control during the per iod of th i s ol'der. All provisions of the orders of October 2 and 27, 1997, that are not inconsistent with this order shall remain in full force and effect, A full and final hearing shall take place on the ~~ay Of \~~.hr lACU'''..-\---' 1998, at j.fl[) o'clock jl.M. in Courtrooll. No. ~ of thk Adams County Courthouse, Gettysburg, Pennsyl- vania. The Defendant is directed to report 15 minutes before the , : hearing. If the Defendant fails to appear at the h~aring, the case will proceed in his absence. The fact that the hearing date set out above may have passed shall not of itself affect the val- idity of this Order. The existence and content of this and other Orders in this case may be verified by contacting Adams County Control, Courthouse, 111 Baltimore street, Gettysburg, Pa. 17325, tel. (717) 334-8101. The Sheriff of Adams County shall have the primary duty to forthwith serve and execute this Order and Petition, which also may be served by any competent adult. A violation of. this Order may subject Defendant to arrest for criminal contempt, imprisonment for up to six months, a fine of up to $1,000.00, and civil contempt proceedings. The Defendant has the right to have an attorney to represent him in this matter. IF HE DOES NOT HAVE A LAWYER, HE SHOULD GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE HE CAN GET LEGAL HELP. Court Administrator Adams County Courthouse 111-117 Baltimore Street Gettysburg, Pa, 17325 (717) 337-9846 The Defendant has the right to a hearing, at which Plaintiff has the burden of proving, by a preponderance of the evidence, that Defendant has abused her, as "abuse" in defined in the law, 23 Pa. C.S. 56102(a). If the Plaintiff did not prove her case, no order would be entered. However, if there is a hearing at which the Plaintiff proves her case and the Court does enter an order, the Defendant must pay a surcharge of $25.00, in addition I. to court costs. The Defendant also has the right to agree that the Court may enter an order against him, without a hearing, while either ad- mitting or not admitting that he has abused Plaintiff. There is no surcharge in such a case, If the Defendant wishes to agree to the entry of an order, he or his attorney should contact Plain- tiff's attorneys, Legal Services, Inc., 432 South Washington st., Gettysburg, Pa. (717) 334-7623. An order entered by agreement has the same force and effect and is subject to the same penalties for violation as an order entered after a hearing. Copies of this Order shall be provided to the Pennsylvania state Police at the Gettysburg substation, Adams County control, the Warden of the Adams County Prison, the Sheriff of Adams County, each District Justice within Adams County, the Adams County District Attorney, the Bendersville Police Department, the Cumberland County Prothonotary's Office, the Carlisle Barracks of the Pennsylvania State POlice, the Lower Allen Township Police Department, and survivors, Inc. Any police officer who has pro- bable cause to believe that the Defendant has violated or is vio- lating this Order is authorized to arrest the Defendant without a warrant. If an arrest occurs when it would be feasible to pro- duce the Defendant before this Court, it shall be done without unnecessary delay, If an arrest occurs otherwise, the Defendant shall be taken to a District Justice to be arraigned and have bail set. A hearing will then be scheduled in accordance with 23 Pa. C.S. S6113(f) and Adams County practice. If the Defendant fails to post bail, he shall be produced before this Court at the IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA RANDI L. BOBB, No. 97-5-909 t. . L: Plaintiff ~. , , ." vs. r. BRAD M. BOBB, -; :1 DOB 5-16-70 -, SSN 199-56-7731 : Defendant Protection from Abu~~ PETITION FOR MODIFICATION AND EXTENSION OF PROTECTION ORDER The Plaintiff, by her attorneys, Legal Services, Inc., respectfully represents that: 1. The Plaintiff is Randi L. Bobb, an adult who lives at 119 Laurel Lane, P. O. Box 113, Bendersville, PA 17306. 2. The Defendant is Brad M. Bobb, an adult who lives at 2261 Coon Rd., Aspers, PA 17304. He was admitted to the York Hospital's psychiatric unit on Sunday, January 18, 1998, but Plaintiff believes that he will be released soon. 3. On September 25, 1997, Plaintiff filed a Petition for Protection from Abuse, alleging incidents during which Defendant threatened to kill Plaintiff, grabbed Plaintiff, backed her against the wall, restrained her, spat in her face, threw her against a door, and threw an object at her. The Court entered a temporary order on that date. 4. The parties have two children, Allison Bobb, DOB 1/24/91, and Samantha Bobb, DOB 9/22/94. The children have been in Plaintiff's primary custody since the parties separated in approximately September 1997. 5. On October 2, 1997, the Court entered a final protection order based upon an affidavit and consent agreement signed by Defendant. That order directs, inter al~ that Defendant shall not abuse, threaten with violence, harass or stalk the Plaintiff. A true copy of that order is attached as Plaintiff's Exhibit A. 6. On October' 21, 1997, the parties appeared in court. for a hearing on indirect criminal contempt charges against Defendant based on an incident that had occurred on October 19, 1997. The charges were withdrawn, and the Court entered an order, a copy of which is attached hereto as Pi. Exh. B, that amended the order of October 2, 1997, as follows: a, to provide that Defendant was evicted from the marital residence at 119 Laurel Lane, Bendersville, PA, and sole and exclusive possession thereof was granted to Plaintiff. Defendant was ordered not to trespass there, but was allowed to appear at the residence for the purpose of custody exchange or to obtain items of personal property as long as he was accompanied by one of his parents and the presence at the residence was prearranged by the parties. b, to provide that Defendant was to have no contact with Plaintiff at her place of employment and was not to trespass there except as may be necessary to address emergency issues relating to the children. 7. Defendant has violated these orders by the following acts: a. On or about December 13, 1997, Defendant repeatedly called Plaintiff at her place of employment, despite being told to stop. The calls did not concern emergency issues relating to the children, b. Plaintiff's On or about December 19, 1997, Defendant came to place of employment, approached Plaintiff, and threatened to kill her and himself. This contact with Plaintiff did not concern emergency issues relating to the children. c. On or about December 20, 1991, Defendant made a number of additional tel~phone calls to Plaintiff at her place of employment, none of which concerned emergency issues relating to the children. d. On about December 21, 1997, Defendant came to Plaintiff's home without prearrangement and without accompaniment. He tried to get in but Plaintiff would not answer the door. He left a card in the door and departed. Defendant's actions made Plaintiff fearful. e. On about December 24, 1997, Plaintiff dropped the 'parties' children off at Defendant's house for a prearranged visit. Defendant spat in Plaintiff's face, called her a slut, threatened to kill Plaintiff and a friend of hers, and pushed her up against her car. Plaintiff suffered reasonable fear of imminent serious bodily injury. f. On about December 25, 1997, Defendant pulled into Plaintiff's driveway without prearrangement, saying that the parties' children wanted to see their cats, When Plaintiff let the children, Defendant followed her into the house, told her he was going to get her fired from her job and evicted from her residence, and threatened to kill her, Plaintiff suffered reasonable fear of imminent serious bodily injury. g. On about January 5, 1998, Defendant made approximately 30 to 50 calls to Plaintiff at her place of employment, none of which concerned emergency issues relating to the children. h. On about January 6, 199B, Defendant made at least three calls to Plaintiff at her place of employment, none of which concerned emergency issues relating to the children. In the first call he threatened to kill Plaintiff. In a later call he said "Happy birthday, Missy, that's supposed to be your death threat." In another call he asked "Did you ever dance with the devil?" On the previous day, Defendant had mailed Plaintiff a card that stated "So Very Sad to See You Go" ,:md "Thanks for the Cance." Plaintiff was in reasonable fear of imminent serious bodily injury. 1. On or about January 18, 1998, Defendant went to the Capitol city Mall in Lower Allen Township, where Plaintiff's place of employment is located, and waited at the employee entrance for an unknown period of time. When Plaintiff went out the employee entrance, he approached her, grabbed her, and held a handgun to her back, Plaintiff was in reasonable fear of imminent serious bodily injury. Defendant was admitted to the York Hospital's psychiatric unit soon after this incident. 8. The Lower Allen Township Police Department is prosecuting Defendant for the acts alleged above that occurred at the Capitol City Mall. 9. Plaintiff is filing a petition fOl indirect criminal contempt in this Court relating to the acts alleged above that occurred in Adams County. WHEREFORE, Plaintiff prays that the Court: A. extend Plaintiff's protection order to run a year from the date of the hearing on this petition; B. amend Plaintiff's protection order as follows: i) by replacing the current order's restrictions on contact with a provision that prohibits Defendant from having any contact with Plaintiff whatsoever, in person, by telephone, by mail, or by any other means; 11) by awarding Plaintiff sole legal and physical custody of the parties' children; iii) by providing that Defendant is to have no contact with the children until he submits professional evaluations that establish his stability; iv) by prohibiting Defendant from entering the Capitol City Mall or its parking area, or from coming within 100 yards of the mall or its parking area; v) by ordering Defendant to turn over to the Sheriff of Adams County any and all firearms in his possession or control, prohibiting him from having any weapons in his possession or control during the period of this order, and ordering him to relinquish any and all licenses to possess a firearm. Respectfully submitted, l~\ A~~~ carol~ L. Carter Legal Services, Inc. 432 S. Washington St. Gettysburg, PA 17325 (717) 334-7623 Attorney for plaintiff , - (}~~ ~~ j co ~,\2.- \J \ -' IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENN6YLVANIA RANDI L. BOBB, plaintiff No. 97-6-909 vs. BRAD M. BOBB, DOB: 5/16/70 SSN: 199-56-7731 Defendant Protection from Abuse o ROE R AND NOW, this .A rJ.- day of October, 1997, pursuant to his Affidavit and Consent Agreement and without admitting plaintiff's allegations of abuse, Defendant has waived his right to a hearing and agreed that the Court may enter this Order. Based on that Affidavit, the Defendant is ordered not to abuse, threaten with violence, harass or stalk the Plaintiff. Defendant is evicted from the marital residence at 119 Laurel Lane, Bendersville, Pa., and sole and exclusive possession is granted to Plaintiff. The eviction portion of the Order is suspended so long as Defendant faithfully obeys the remaining portions of the Order. Defendant shall not remove, damage, or destroy any of Plaintiff's personal property. Defendant shall contact a counselling center and he shall follow any recommendation for treatment. If the parties separate voluntarily or inVOluntarily, Plaintiff shall be granted temporary custody of the minor children. -~ Defendant shall pay the costs of this action. He shall have ninety days in which to do so. This Order shall remain in full force and effect for one year, the maximum period permitted by law, beginning this date. The Defendant is notified that a violation of this Order may subject him to arrest for criminal contempt, imprisonment for up to six months, a fine of up to $1,000.00, and civil contempt proceedings. Copies of this Order shall be provided to the Pennsylvania State Police at the Gettysburg substation, Adams County Control, the Warden of the Adams County Prison, the Sheriff of Adams County, each District Justice within Adams County, the Bendersville Police Department, the Cumberland County Prothonotary's Office, the Carlisle Barracks of the Pennsylvania State Police, and Survivors, Inc. Any police officer having pro- bable cause to believe that the Defendant has violated or is violating this Order is authorized to arrest the Defendant with- out a warrant. If the arrest occurs when it would be feasible to produce Defendant before this Court, it shall be done without unnecessary delay. If arrest occurs otherwise, the Defendant shall be taken to a District Justice to be arraigned and have bail set. A hearing will then be scheduled in accordance with Adams County practice. If the Defendant fails to post bail, he shall be produced before this Court at the first available opportunity. , BY THE COURT, iJ'~ 'h , 10/ /. 'l'hi3 being a true and at~~ '" 1 COPy taken from o.,:d cor.I.::;r<ld wi;.h the oriH1nal A1.tosl:; h; {).~tI1f- { .. r 5f(( fl- . . p.J. '. I. 1 'Prothonotary .- ..~-- .""--- --- - _n 0 r/J ~ i i ~~ c - ~ ~ h~h~~ 5~Fi .- - .... (7j ~~linnnl ~ IS! ,a::: ...: 0 in ~ r- CD N UI!~nnnn a. 0 .- 0- 0- :J 0 U rO 0- 0- D r 0- ~~ a~UUUff , N r ' , , , , , . I " , . . \ ~~~UHHHH ,~ _.- s; .(.. dJ !:: f- , en , -J > U IS ~ IS U '.I (/J - ~~ 0- <..J ~ u.. ~ ~ <J u >- I (J 0 -J , en 0 en ;j0- 0 0 Iii ~ N (j 0: IIi! I!! UJ , , 0- - JJ 0- X en ~ ti I nni5d ~in el: !Q f- en r el: \S ' . , , , , . , ,. , . , ~c n~gH~i!lj~~~~ ~UJ <( ;.: tj) -,) !ten u -J ~ , i!!::J 0 $.I .(ll I tiel: ;>< hE 0 ( ) ..-r >0 <( - r) Ihl!!!!! 5!0:: ~ ~ ~YJ X u ~LL ~z > 0..- en 0- U 0- 0- 0 ~- ,.l.- s: tu~su~~ ~ -- ,.. u ti ~ ~T ~~ I~~U UJ f- 0:: ::J dh~~ U ~ 0 (ll en 0:: z -J ' \ ll. ~ 0 0: '1J ~ h~nUinU ~ '-.}) 0 -Z) :r.: , , . , , , . . ,. " en 1 fi~a~~~!3~5~~ -J '.J I cC "i -0 ij' } (' -1 I () .:! 3 ~ ! t() ~- 0 t(J (k J I~ h rf) '-l U r() 0- . ~h ~~~ Ii c.: \.n , - , -Q. ~ ~f~~!!l r~ I \.cOil I! I !' () UU" iil w S >= r '. c:~~ i!li!l~~i!l..ilI 'i r () ~ ~~ m~HfHn~ . " . .. ~ . '. ~ 0 z Z 0: (/) CD f- Z 0:: Z CD -J ~ 0 0 :E 0- 0- -' ' , , . . , ' , , , . , 0 UJ n. u.. 0 -J > <l: ~ 0- en 0- 0- It!~;m~~~~hfl~g --- ! , ~ \, .~ ,:::$ .-<) .-'l . oj QJ. Iii w :J: UJ i5 c( Q ~~ ~ co ;!c( III ::E I~ ~u.. I~ J= (.) ~ o It: D. \' " .., .., .j ~ ~ o 0.. ::l D I ~ a B 15 I:. f i J ~ ! ~ i I~ j 'i ~ ~. ~ 15 - ~ n l . ... ! ! I I I I . . 0- I I i ~ I - f' I ! i . I' a " >- I > . J 1,1 . I ~ J .. .\ a ~ . . \' ! I j '" I . l~ I " i ~ I I i . ... ~ I ~ i I ~ l~ ~ >- ~ J <, t J c i i 'J i C' c i , " " j ~ I 11- .. ~ 1; olI I . . I,. i ~ J J l. 3 5 I i . a I i I . . . I I I I I ~ I . li~ I I. 1 . . .... a I . .-\ \~ I..~ J >- - !~ .;!! ,. i i r\~ " -.. -.. I if' , .' " f~ cl i " " -, \.. ., " v ~ , ~ K' . ~ " ~ . ~ ~ " " J~'J , "l . < I . - 1, " , \ I~'; -.. " , ~ I~ < It.t ../. " ~ .. l~ , -" I II J I r~ l~ I I )1 l~ - !J " ~.~ I a I '( . I ) I J ..~ . I I , .. I J t I~ J .A I ~ " 0- -< --< I~ c I l j I . -d I I: . J )J I I .q . I \- ..' j I 11 ." I I I 1 , -.. -. ~ , ! ~t ~ ! I IJ5 ~ ~ g ; <';. ~ ~~ ~i ~Iil' \-:,'- ( I~ ~I II ~ ~ ~ ~ i i ,- ~I ~ d ~ ~ ~ I ~ I II !(lii1j! ,I,i"ftl! j! ,II liilll~llll! il!llllil!~I!! i!I~15~~ .. nnmmllmll IIIlhhumll 11m I ~~~~~~~~~.~ ~t~~~~ ~~ ~~~~~ I II ! II q ipl II il I ill I Ii III! Ii I I I ill! 'I ~I 'hll! I ! :..1 I ft i Iii l ! II 11!1!! i! I lit.. ~ ~ ~I~~~ I s ~~ ~!~~~~ ~ ~ ~ ~ ! ~ 8 ~~ .. !~ f.~g>-~ ~ ffi ~ a Ill! ! l~lll llihi1i III I nhh~~~1 ~~i ~ rial '.~ ~ >-:; i~1ll1 II! >- II: ~~ ~~~~= ~ ; J:g . ;~~~ . ~ ~~!. ! ~. ~ iii~ ~~~~ ~a ijjii!5g~~~ ~ 8 I;~ ~~~ i~~~g ~i~~aa~~~~~~~i~~~~~~~~ " 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 issues of emergency relating to the children, Plaintiff's current place of employment is Holiday Hair, Capital City Mall, Cumberland County, Pennsylvania. Any ~osts associated with the indirect criminal contempt shall be the responsibility of the Defendant. Copies of this order shall be provided to all agencies and individuals identified to have received a copy of the Order of October 2, 1997. BY THE COURT, Paul Dean, Esq. Jean Arena, Esq. Ie, b'J C) 19m, Th1s be1ng a tru., ~;tcn ;,!ojJ~r tak~n fro:n e.~l(l COL1iiD.l'(d wi ell the oriJinal Atttlst: "I' ~ . - /'.(1 ( ~~i~f ,,!,tll.)( 2 A (/ Prothonotary Alicia K. Wootr;t RPR Official Court Reporter I . '" I j, I' ~ i J 1;'1 ,{ ~ , ~ fi' .;; ~ [.,. I, ~. ( . 1'-' (. '" I j'h I r-. ~ j' " , , I" , , ',. , j' I' I I " , , I. . , , I " I j I ,[ I [ I , , , , II , , 'I I I , , I , , I I . , , I '. to arrange pi\rti<1 L cuutody of the children, and then only by telephone or with A thLrd party present. A full and rinuL hel\rinq shall take place on the31.J.- day of October, 1997, nt J.:~)(,J_ o'clock l~.M. in Courtroom No.2-of th'e Adams county courthouse, Gettysburg, Pennsylvania. The Defend~nt i6 directed to report 15 minutes before the hearing, If the Def/ilndnnt ("LLs to appear at the hearing, the case will proceed in hiu "bsence, 'rha fact that the hearing date set out above may hAve pnf.lsod shall not of itself affect the validity of th LII Ordor, 'rho ex istence and content of this and other Orders in thlu caBO may bo verified by contacting Adams county control, Courtht'lHle, III B"ltimore Street, Gettysburg, Pa. 17325, tel. (717) ]'\4-8101. 'rho Sherin of Adnms county shall have the primary duty to forthwith Borve and execute this Order and Petition, which also may be served by any competent adult. A vLoLation of this Order may subject Defendant to arrest for criminaL contampt, imprisonment for up to six months, a fine of up to $l,OCO.OO, and civil contempt proceedings. 'rhe Defendant has the right to have an attorney to represent him in thi.s matter. IF HE DOES NOT HAVE A LAWYER, HE SHOULD GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE HE CAN GET LEGAL HELP, Court Administrator Adams County Courthouse 111-117 Baltimore Street Gettysburg, Pa. 17325 (717) 334-6781 ext. 213 The Defendant has the right to a hearing, at which Plaintiff has the burden of proving, by a preponderance of the evidence, that Defendant has abused her, as "abuse" in def ined in the law, 23 Pa. C.S. S6102 (a). If the Plaintiff did not prove her case, no order would be entered, However, if there is a hearing at which the Plaintiff proves ~qr case and the Court does enter an order, the Defendant must pay a surcharge of $25.00, in addition to court costs. ThE! Defendant also has the right to agree that the Court may enter an order against him, without a hearing, while either ad- mitting or not admitting that he has abused Plaintiff. There is no surcharge in such a case. If the Defendant wishes to agree to the entry of an order, he or his attorney should contact Plain- tiff's attorneys, Legal services, Inc., 432 South Washington St., Gettysburg, Pa. (717) 314-7623. An order entered by agreement has the same force and effect and is subject to the same penalties for violation as an order entered after a hearing, Copies of this Order shall be provided to the Pennsylvania state Police at the Gettysburg substation, Adams County Control, the Warden of the Adams County prison, the Sheriff of Adams County, each District Justice within Adams County, the Bendersville Police Department, Cumberland county Prothonotary's Office, the Carlisle Barracks of the Pennsylvania State Police, and survivors, Inc. Any police officer who has probable cause to believe that the Defendant has violated or is violating this Order is authorized to arrest the Defendant without a warrant. If an arrest occurs when it would be feasible to produce the Defendant before this Court, it shall be done without unnecessary approximately six occasions that he will kill Plaintiff or that Plaintiff will be found in a ditch. He has also threatened to kill himself, Approximately three or four days ago, at the parties' residence, Defendant was upset because Plaintiff WIlS leaving him. He got a kitchen knife and came up to Plaintiff. He held the knife pointing toward his stomach and asked her "why don't you just kill me now," Plaintiff has suffered fear of imminent serious bodily injury, b) On about September 20,1997, at the parties' home in Bendersville, Defendant grabbed Plaintiff, ripping her dress. Plaintiff suffered fear of imminent serious bodily injury. c) On about September 19, 1997, at the parties' home, Defendant backed Plaintlff against the wall, restrained her, yelled at her, spat in her face, and threatened to hit her. Plaintiff was in fear of imminent serious bodily injury. d) In July, 1997, at the parties' home, Plaintiff and Defendant argued. Defendant threw Plaintiff against the door and restrained her by holding her shoulders to the door. Plaintiff suffered pain, red marks on her upper arms and shoulders, and fear of imminent serious bodily injury. e) In about June, 1997, at the parties' home, Defendant threw a hamper at Plaintiff, hitti.ng her head. Plaintiff suffered substantial pain, a red mark, and fear of imminent serious bodily injury, and fled the residence for the rest of the night. 6. Defendant works at J. C. Penney, Harrisburg East Mall, HarriSburg, PA, 7, Plaintiff works at Holiday Hair, Capital city Mall Dr., Camp Hill, PAt 8. Plaintiff and Defendant have two vehicles that are titled in both names. Plaintiff is the primary user of one of the vehicles, a 1995 Ford Taurus. 9, Plaintiff believes and avers that there is an immediate and present danger of further abuse. WHEREFORE, Plaintiff prays that th~ Court enter the attached, proposed Order and, after plenary hearing: a) order Defendant not to abuse, threaten with violence, harass or stalk the Plaintiff; b) grant temporary custody of Allison and Samantha Bobb to Plaintiff, with a suitable partial custody schedule for Defendant; C) order Defendant to pay support in an appropriate amount and to maintain health insurance coverage for Plaintiff and the two children; d) award Plaintiff exclusive possession of the home at 119 Laurel Lane, 8endersville, PA 17306, evict Defendant therefrom, order Defendant not to trespass there, and order Defendant to turn the keys to the residence over to the Sheriff of Adams County; e) order Defendant not to contact Plaintiff or trespass at her place of employmel~t; f) order Defendant not to interfere with Plaintiff's use and possession of her vehicle, a 1995 Ford Taurus; g) order Defendant not to remove, damage, or destroy , Def.endant shall pay the costs of this action. He shall have ninety days in which to do so. This Order shall remain in full force and effect for one year, the maximum period permitted by law, beginning this date. The Defendant is notified that a violation of this Order may subject him to arrest for criminal contempt, imprisonment for up to six months, a fine of up to $1,000.00, and civil contempt pr.oceedings, copies of this Order shall be provided to th.e Pennsylvania state Police at the Getty~burg substation, Adams County control, the Warden of the Adams County Prison, the Sheriff of Adams County, each District Justice within Adams county, the Bendersv i lle Po lice Department, the Cumberland county Prothonotary's Office, the Carlisle BarracKs of the Pennsylvania state Police, and survivors, Inc. Any police officer having pro- bable cause to believe that the Defendant has violated or is violating this Order is authorized to arrest the Defendant with- out a warrant. If the arrest occurs when it would be feasible to produce Defendant before this court, it shall be done without unnecessary delay. If arrest occurs otherwise, the Defendant shall be taKen to a District Justice to be arraigned and have bail set. A hearing will then be scheduled in accordance with Adams County practice. If the Defendant fails to post bail, he shall be produced before this Court at the first available opportunity, M'{~~ .... L~~J~0:1'l:h;~,~;~1~~o: tru:Y THE) COURT, a ,.I. ~'.J('" ",ti,lldj til.': original ). J C ~l~f- A~t~'iJi;: 1.1l r)1 A. __ l LC<Jf)lctlf;k 9'. Proth,):l()t.'l.ry rSr-. ' r're/2 f) J. I . C7 Vi. '0'- . ~, ';:\ ~ . - ,~ 0, \~ /:t' ',- ~. II': I:; /. . " ,,./(, ~. ,:J._ ( j; , - ) f}~ ~ .'11: I "-;,,' C)I -,_.; <', fl' ,~) J_I'_ C\i {I/I. ~". . ~. -..; .. "JI"i ,:" ~\ " t./!J.. ". CL~ '::j 0 0"\ U . " " , " 'I "I " " " " , , ". 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 I '-"" , I ) IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA ci vil 0) i. '-II.! CI..LJ. r;......:-, 97-S-909 Randi L. Bobb vs. Brad M. Bobb ORDER OF COUR~ AND NOW this 27th day of October, 1997, the parties appeared with counsel lor a hearing on an indirect criminal contempt filed October 19, 1997 alleging an incident to have occurred that same date. Based upon agreement of the parties, that indirect criminal contempt is withdrawn and dismissed. The Order of October 2, 1997 is amended to provide that the Defendant is evicted from the marital residence at 119 Laurel Lane, Bendersville, PA and sole and exclusive possession thereof is granted to the Plaintiff. The Defendant shall not trespass at said location. Appearing at the residence for the purpose of custody exchange or for the purpose of obtaining items of personal property shall not be considered a violation of this order if the Defendant is accompanied by one of his parents and the presence at the residence is prearranged between the parties. In addition, the Defendant shall have no contact with the Plaintiff at her place of employment and shall not trespass therein except as may be necessary to address 1 Alicia K, Wooters, RPR Official Court Reporter 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 --' issues of emergency relat ing to the chUdren. Plainti f f' s current place of employment is Holiday Hair, Capital City Mall, Cumberlcmd County, Pennsylvania. Any costs associated with the indirect criminal contempt shall be the responsibility of the Defendant. Copies of this order shall be provided to all agencies and individuals identified to have received a copy of the Order of October 2, 1997. BY THE COURT, John D. Kuhn, Judge Paul Dean, Esq, Jean Arena, Esq. ~~ Cf1 Thie being a true ;;..-1 9 " K" 1\ from wCi .' ttr.~: t"'d (lOiPYh t~e' ori,;l.nal and. Cd~l:_:A.l.i.., w " ~ttllJt : ~. .~~ (1 . I'll "-,,. 1 ('I 'i( - '-I ,::3 C. ,.,(:J~flI).,-, ~...~",Q., l~. 'V-I'" !N THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA RAND! L, DOBB, I No. 97-S-909 Plaintiff I I vs. I I BRAD M. DOBB, I Defendant Protection from Abuse 0 R D E R AND NOW, t.his Q 0'11'-' day of ' t, , 1998, upon presen- tation and consideration of the attach I verified petition for modification and extension of protection order, the Court enters the following Order, which shall remain in effect until modified or terminated, after notice and hearing. The protection order entered on October 2, 1997, as modified by the order of October 27, 1997, is further modified to provide that Defendant shall have no contact with Plaintiff whatsoever, in person, by telephone, by mail, or by any other means; that Plaintiff is awarded legal and physical custody of the parties' children; that Defendant is prohibited from entering the capitol City Mall or its parking area, or from coming within 100 yards of the mall or its parking area; that Defendant 1s ordered not to have any firearms or weapons in his possession or control during the period of this order. All provisions of the orders of October 2 and 27, 1997, that are not inconsistent wit.h this order shall remain in full force and effect. A full and final hearing shall take place on the It'flJday of T( hLl~, 1998, at -LtC o'clock -i-1M. in Courtroom No. '-::., of thlO Adams county Courthouse, Gettysburg, Pennsyl- vania. The Defendant is directed to report 15 minutes before the hearing. If the Defendant fails to appear at the hearing, the case will proceed in his absence. The fact that the hearing date set out above may have passed shall not of itself affect the val- idity of this Order. The existence and content of this and other Orders in this case may be verified by contacting Adams County Control, Courthouse, 111 Baltimore Street, Gettysburg, Pa. 17325, tel. (717) 334-8101, The Sheriff of Adams County shall have the primary duty to forthwith serve ar.d execute this Order and Petition, which also may be served by any competent adult. A violati.on of this Order may subject Defendant to arrest for criminal contempt, imprisonment for up to six months, a fine of up to $1,000.00, and civil contempt proceedings. The Defendant has the right to have an attorney to represent him 1n this matter. IF HE DOES NOT HAVE A LAWYER, HE SHOULD GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE HE CAN GET LEGAL HELP. Court Administrator Adams County Courthouse 111-117 Baltimore Street Gettysburg, Pa. 17325 (717) 33'/-9846 The Defendant has the right to a hearing, at which Plaintiff has the burden of proving, by a preponderance of the evidence, that Defendant has abused her, as "abuse" in defined in the law, 23 Pa. C.S. S6102(a). If the Plaintiff did not prove her case, no order would be entered. However, if there is a hearing at which the Plaintiff proves her case and the Court does enter an order, the Defendant must pay a surcharge of $25.00, in addition to court costs. The Defendant also has the right to agree that the Court may $nter an order against him, without a hearing, while either ad- mitting or not admitting that he has abused Plaintiff. There is no surcharge in such a case. If the Defendant wishes to agree to the entry of an order, he or his attorney should contact Plain- tiff's attorneys, Legal services, Inc., 432 South Washington st" Gettysburg, Pa. (717) 3)4-7623. An order entered by agreement has the same force and effect and is subject to the same penalties for violation as an order entered after a hearing. Copies of this Order shall be provided to the Pennsylvania state Police at the Gettysburg substation, Adams County Control, the Warden of the Adams County Prison, the Sheriff of Adams count.y, each District Justice within Adams County, the Adams County District Attorney, the Bendersville Police Department, the Cumberland County Prothonotary's Office, the Carlisle Barracks of the Pennsylvania State POlice, the Lower Allen Township Police Department, and Survivors, Inc. Any police officer who has pro- bable cause to believe that the Defendant has violated or is vio- lating this Order is authori~ed to arrest the Defendant without . a warrant. If an arrest occurs when it would be feasible to pro- duce the Defendant before this Court, it shall be done without unnecessary delay. If an arrest occurs otherwise, the Defendant shall be taken to a District Justice to be arraigned and have bail set. A hearing will then be scheduled in accordance with 23 Pa. C.S. S6113(f) and Adams County practice. If the Defendant fajls to post bail, he shall be produced before this Court at the ...- Ifl ,. (~ ~j ".: , ~. " I," \1-1(1 .' (.J t ..,.'1 , f.l,"'_i , U.. ., j' ' ~,'! \', ( r~' rH "" ,. (;.: - , :1:- ,'.Ii"I.' l..: , le'- I " -.... \;.'. 41"~ ~;J U C" (,) . .' ,J " " " , " ,f):. ~ If.: .. . I>o~ ~ "l ...... \J"o ~ ~ ..:t.. .... .. <\". ~ Q", ~ ~ Ja ~ tl ~~ s , " , , " '1 'it " , " , " t:; W :J: UJ ~ ~ Q ~~ ~~ ti:& !~ ~u. I~ i= o ~ o It: 0.. , II lJ! ~ Cl a.. :::> ~ . I ~ 0 ! ~ t' ~ , i I~ f I ~ ~ I . j ~ ! J ~ . It) I ~ . A ~ I I I I . . .. J J ~ 0- f ! <l c' cr- '- l I q) I ~ V) I I I i i I J~ r.- ,. 0- J & 1 j I ~ i , . I 00 )-. 1 j I . , J~ I~ I ~ J .j I . E 1';- fJ ! I ! i I ,. M j'" .~ I I .. i ~ i i .. <1 i~ i s I a 5 .... ~ I . . . I 5 J J 5 I i . a i I I I . j , I I J ......~. J I ,. _..-' u.:.. . ~.; I I~ . oj- . . I: '.' : 1 i -:. I ,,,, l<li I ,. r:- 11.. ,> I - i " , . .' . I> .'~ I., . ct . .... .4) . i <:l- 1....1,... . I~ V) - QI ~ , I, ..~ 'J '.. . l::- i . '" --I. . <:t: ,.- Ii j -0 H 1. <X 1Z I ,;:.. . I J I 2 I -~ I 1 1;:1 ~ " J<t: 0 j ! f I I I I~ " . I~I:. j~ J I I I J . ".,9 I I i I I~ 1 I~ jdJ I i . I I ~ I I~' i 1 i! ;!In I ! ; g ~ w~ if ~~ ! ~11l I!! ~11l ~ ~ t ~i5 ~ t !, ~ ~ ill 31 l i! ~~ !~i~i II~ Ii ~ ~~~ lie li~ ~i~~~II~I~~ ~ ~~~s5~~I; ~ ~~~ lil~ ! iii ~ ~ iilii'~i ~ ~ I ~~ ~J i~~~~~~~I~I r~~~~~ ~~ ~~~~~ I /1 ~ ~ 11l~ @'" ~ j , il I 28 i i h ~i . 3 ~ . . ~ > JiI n!l!IM L ... ,.....1.... I III ~ ~ i~ ~~.!I!II I I . . 1 i ~ ~~~ I ~ ~3 ~ib~ ~ ~ i 'I'. ; ~ ,. p ~ 15 ~ ~ ~ ~ 0 ~ ~ ~ ~ ~ ; ; ..' ~ ~ i ~~~ ; ! ~~ ~~.11l. ~~ ~ ~ ~ ' il ! ~ i\1~i~ ! ~ d IgU~~ ~ I i a [ I ~ ~ i l~~ ~ I ~~ d~i ~ ~ ~ ~ h~hH! ~ I i:,11 i~I!lilll Ii! ill!ii I'i! lillliiiiiiiiiiiiiilil!l! ~ ~ I~~ ~~~ i~~~S ~;~a~d~~~~~~~i~~~~~~i~ Ctvr>..1- C Ir (f'l - 5:'> J."J IN THE COURT OF COMMON PLEAS OF ADAMS COUNTY, PENNSYLVANIA RANDI L. BOBB, Plaintiff No. 97-S-909 vs. : : I t I : : I BRAD M. BOBB, DOB 5-16-70 SSN 199-56-7731 Defendant Protection from Abuse ORDER AND NOW, this \U~ l\lay Of-.~, 1998, pursuant to his Affidav.tt and Consent Agreement and without admitting Plaintiff's allegations that he has violated the Protection Order in this case, Defendant has waived his right to a hearing on Plaintiff's Petition for Modification and Extension of Protection Order and agreed that the Court nay enter this Order. Based on that Affidavit, the Defendant is ordered not to have any contact with Plaintiff whatsoever, in person, by telephone, by mail, or by any other means. Plaintiff is awarded sole legal and physical custody of the parties' children. Defendant may exercise such partial custody rights at his parents' home as the parties agree upon from time to time. The arrangement for partial custody at the present time is that Defendant's parents pick the children up at the children's babysitter every Friday between 4:00 and 5:00 PM and return the children to Plaintiff at Claire's Grocery in Bendersv.tlle every Saturday at 6:00 PM. Defendant's parents may also have the children w.tth them at other times worked out between them and Plaintiff. Dur ing these per iods of partial custody, Defendant may go with the children to locations other than his parents' home, but shall have one of his parents or another adult with him until he provides Plaintiff with a copy of a psychological evaluation that recommends unsupervised partial custody. All arrangements for partial custody and all exchanges of the children shall be made through Defendant's parents, without Defendant being present and without contact between Plaintiff and Defendant. Defendant shall not enter the Capitol City Mall or its parking area, and shall not go within 100 yards of the mall or its parking area, Defendant shall not go to Plaintiff's residence, or enter upon the grounds of Plaintiff's residence, for any purpose. All provisions of the order of October 2, 1997, as modified by the order of October 21, 1997, that are not lnconsistent with this order shall remain in full force and effect. Defendant shall pay the costs of this action, and shall have 90 days in which to do so. The protection order entered in this case, as modified by the order of October 21, 1997, and by this Order, shall remain in full force and effect for one year, beginning this date. The Defendant is notified that a violation of this Order may subject him to arrest for criminal contempt, imprisonment for up to six months, a fine of up to $1,000.00, and civil contempt proceedings. Copies of this Order shall be provided to the Pennsylvania state Police at the Gettysburg substation, Adams County control, the Warden of the Adams County Prison, the Sheriff of Adams County, each District Justice within Adams County, the , , . "' rO--, , . , I " " '-i' ',,./. 1'i" "'''\ , , ,'tl '" , I ,I ~ o. t. " N , ~'; .. t'...." .;:J .:( - t,);;:;; r ...,. I I.....,. " . I ::2 -'~'.1. -~ 'J\~~.i f~j ~I .':-0 " e.: "'.J t,~m 1', III. OJ , r::: "'.J """ a. 15 ~ ., , , I,' \\ ..