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parties' children. Tholl (Il:fendllnt shall remain in his vehicle at
all times during the t ransfel' of custody.
The defendnnt is ordered to refrain from having any direct
or Indirect contllct with the plaintiff Including, but not limited
to, telephone and written communlc'ltlons, except for the limited
purpose of facilitating custody arrangements.
The defendant is enjoined from harussing and stalking the
plaintiff and from harusslng the plaintiff's relatives.
The defendant is enjoined from entering the plaintiff's
place of employment or the schools of the minor children.
The defendant is enjoined from removing, damaging,
destroying or selling any property owned jointly by the parties
or owned solely by the plulntiff.
^ violation of this Order may subject the defendant to: I)
arrest under 23 Pa.e.s. !l6113; il) a private criminal complaint
under 23 Pa.e.s. 66113.1; III) 1.1 charge of indirect criminal
contempt under 23 Pa.e.S. 66114, punishable by imprisonment up to
six months and a fine of $100.00-$1,000.00; and Iv) civil
contempt under 23 Pa.e.s. 66114.1. Resumption of co-residence on
the part of the plaintiff and defendant shall not nullify the
provisions of the court order.
This Order shull remain in effect until modified or
terminated by the Court and can be extended beyond its original
expl rat Ion date i I' the Court finds that the de "endant has
committed another act of abuse or has engaged In /I pattern or
practice that indicates continued risk of hnrm to the plaintiff.
Temporllry custody of Cody J. Bolt (DOll 9/27/91) and Tyler R.
Bolt (DOD 11/8/93), Is hereby awarded to the plaintiff, Brenda K.
Bot t.
A hearing shllll be hcld on this matter on the __3'u'. day of
Octobcr, 1997, at ~L1i__~~..m" in Courtroom No.~, cumberland
County Courthouse, Cllrllslc, Pennsylvania.
The plaintiff mllY proceed without pre-payment of fees
pcndlng a further order aftcr the heRring.
The Cumberlllnd County Sheriff's Department shall attempt to
make service at thc plaintiff's request and without pre-payment
of fees, but scrvice may be nccompl ished under any applicable
rule of Civil Procedure.
This Order shall be docketed In the office of the
Prothonotary and forwarded to the Sheriff for service. The
Prothonotary shall not send a copy of this Order to the defendant
by mall.
The appropriate police departments will be provided with
certified copies of this Order by the plaintiff's attorney. This
Order shall be enforced by any law enforcement agency where a
violation occurs by arrcst for indirect criminal contempt without
warrant upon probable cause that this Order has been violated,
whether or not the violat ion is committed in the presence of the
police officer. In the event that an arrest is made under this
section, the defendant shall be taken without unnecessary delay
before the court that issucd the order. When thllt court Is
limited to, the folluwing Ilpllclflc Instanclls of abuset
a. On or nbout August Ill, 1997, the defllndo.nt gfllbbcd
the plaintiff by hcr Wrllltll, pulled her off the cuuch,
and pushed her onto thc floor. All the plnlntlff tried
to get 6W6Y, thc dcfendant gr6bbed hcr by the 6rm,
pulled her onto thc floor, punchcd her sevcrnl tlmcs in
the arm, and klckcd hcr in the leg cnuslng p61n,
swelling, and bruillcs. Thc defendnnt threw a cordlcss
telephone at the plnintlrf cllusing her to movc to avoid
being hit, grabbed the plaintiff around her neck with
both hands, IInd choked her causing her to fear for her
life. The defcndant gr6bbcd the plaintiff's purse,
locked himself in the bathruom. Ilnd took all her money
and her MAC canl. After the defendant Clime out of the
bathroom, he shovcd the plnintiff Into a wall, dumpcd
soda on her head, and told her to get out of the house.
b. On or about August 10, 19'17, liS the plaint iff was
Sleeping, the defcndant slapped her in the back of the
head and grabbed her hy the arm attempting to pull her
out of bed, causing hcr to fellr for her safety.
c. In or abuut August 1'197, thc defendant punchcd the
plaintiff on the 6rm with a closed fist. causing pain
and bruises.
d. In or about July 1997, after the defendant had
shoved the plaintiff causing her to fall backwards.
2
Then, In order to get to the plnlntiff, the dcfenrlnnt
picked up his minor child, who was In his way, und
threw the child onto the bcd CRUS Ins the child to hi t
the frame of the bed which resulted in bruises on his
legs.
e. On several OCCAsions sincc 6pproximately 1988, the
defendant has kicked, punched, slappcd, choked, shoved,
and restrained the plaint Iff. Thc defcndant has hit
the plaintiff In her face with a shoe, he has forced
her to have oral scx with him, Rnd he has thrown her
out the door cal ling hcr a dog. The defendant h6s
threatened the plaintiff on sever61 occ/lslons saying
that he would kil I her If he ever found her with
anoth~r man and he would kill her if she did not get
out of his face causing hcr to fear for her life.
6. On or about August 18, 1997, the plaintiff and the two
minor children left their residence at 600 North Baltimore
Avenue, Apartmcnt A, Mount Holly Springs, Cumberland County,
PennSYlvania, In order to /lvoid further abuse.
7. The plaintiff believes and therefore avcrs that she is
In immediate and prcsent dangcr of abuse from the defendant and
that she Is in need of protection from such abuse.
R. The plaintiff dcsircs that the defendant be prohibited
from having any direct or indirect contact with the plaintiff
Including, but not limited to, telcphone and written
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communications, except for the limIted purpose of fnctlltnting
custody arrangements.
9. The plnlntlff desires that the defendnnt be enjoined
from h6rnssing and stalkIng the plaintiff, and from harassing the
plaintiff's relativcs.
10. The plnlntiff dcslres that the defendant be restrained
from entcring her place of employment or the schools of the minor
children.
II. The plaintiff desires that the defendnnt be enjoined
from removing, damaging, destroying or sclling any property owned
jointly by the parties or owned solely by the plaintiff.
-'L--..EElJ1.5.L'llL..I!Q3. S E S S I ON
12. The home which the plaintiff is asking the Court to
order the defendnnt to stay away from is not owned or rented In
the defendant's name,
13. The plaintiff cannot reveal the names of the owner of
the home because th~ names will disclose her whereabouts which
must be kept confidential for her protection. The plaintiff is
not seeking the eviction of the defendant from his residence.
14. The defendant has his own residence located at 600
North Baltimore Avenue. Apartment A, Mount Holly Springs,
Pennsylvania.
~ SUPPQR1
15. The defendant has a duty to support the plaintiff and
the minor children.
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IIrunda K. lhllt. who relildus at an undlscl()Slld location.
During the paBt fivc yearli. the children have resided with
,
thc following persons and at the following addresses:
I'l.llIDlI.
Plaint Iff
i\!llIU!llH:.IJ
undisclosed loclltion
P I a i n t If I' and
de fendan t
600 North Baltimore Ave
Mount flolly, PA
Plaint i ff
undisclosed location
Plaintiff and
de fendan t
600 North Baltimore Ave
Mount HOlly, PA
Plaintiff. Betty 102 West York Street
and Cecil Guise Blglervllle, PA
(plaintiff's p6rents),
and Brian Guise
(plalntlff's brother)
Tl1l.w
9/18/97 to
prelient
12/95 to
9/18/97
11/95 to
12/95
4/95' to
11/95
10/94 to
4/95
Plaintiff and 600 North Baltimore Ave 10/93 to
defendant Mount Holly, PA 10/94
Plaintiff North Main Street 12/92 to
Blglerville, PA 10/93
Plaintiff and 600 North Baltimore Ave 5/92 to
defendant Mount Holly, PA 12/92
Plaintiff, Bet ty 102 West York Street 9/91 to
and cecil Guise, Biglervi lie, PA 5/92
and Brian Guise
an undisclosed location.
The plaint iff, the mother of the child, current ly resides at
She Is married.
The plaintiff cannot reveal the names of people she resides
with because the names will disclose her whereabouts which must
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the minor children.
WHEREFORE, pursuant to the pl'ovls ions of the "Protect Ion
from Abuse Act" of October 7, 1976, 23 PII.C.S. 8 6101 Jll JS.~<I.., liS
amended, the plaint iff prllYB this Honorable Court to grant the
follow I n g rei i e I' :
A. Grant II Tcmporllry Order pursuant to the
"Protection from Abuse Act:"
I. Ordering the defendant to rcfraln from
abusing the plaint Iff or from placing her In fear
of abuse.
2. Ordering the defendllllt to l'efraln from having
any dlrcct or Indirect contact with the plaintiff
Including, but not limited to, telephone and
written communications, except to facilitate
custody arrllngements,
3. Onlel'ing the defendant to refrllln from
harassing and stalking the plaintiff and from
harassing the plaintiff's relatives.
4. Prohibiting the defendant from entering thc
plaintiff's place of employment or the schools of
the minor children,
5. Prohibiting the defendant from removing,
damaging, destroying or selling property jointly
owned by the parties or owned solely by the
plaintiff.
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6. Ordcrlng the defendant to stay IIWIlY from thc
plaintiff's rcsldence, and any other residence the
plaintiff mllY ll/llllbllsh, except for the limited
purpose of transferring custody of the plIrtles'
children. The defendant shall renudn In his
vehicle at 1111 t Irnes during the transfer of
custody.
7~ Granting tcmporary custody of the minor
childr",n to the plnlnt iff.
B. Schedule a hearing in accordance with the provisions of
the "Protection from Abuse Act," lind, after such hearing, enter
an order to be In effect for a period of one year:
1. Order ing the defendant to refrain from
abusing the plaintiff or from placing her in fear
of abuse.
2. Ordering the defendant to refrain from having
any direct or, indirect contact wi th the plaint Iff
Including, but not 11m! ted to, telephone and
written communications, except to facilitate
custody arrangements.
3. Ordering the dufendant to refrain from
harassing and stalking the plaintiff and from
harassing the plaintiff's relatives.
4. PrOhibiting the defendant from entering the
plaintiff's place of employment or the schools of
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the minor children.
5. Prohibiting the defendant from removing,
damaging, destroying or selling property jointly
owned by the pllrties or owned solely by the
plaintiff.
6. Ordering the dcfcndant to stay away from the
plaintiff's resldcncc, and any other residence the
plaintiff may establish, except for the limited
purpose of transferring custody of the parties'
children. The defendant shall remain In his
vehicle at all times during the transfer of
custody.
7. Granting support to the plaintiff and the
minor children in an appropriate amount according
to the support guidelines, payable to the
plaintiff in the form of a check or money order,
mailed to her, and ordering the defendant to
provide hcalth coverage to the spouse and minor
children.
8. Granting temporary custody of the minor
children to the plaintiff.
9. Ordering the defendant to pay $250.00 to
reimburse one of Legal Services, lnc.'s funding
sources for the cost of litigating this case.
The plaintiff further asks that this Petition be filed and
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plnintlff's undisclosed residence, and IIny other rcsidcnce the
[llnlntlff mllY cstllbllsh, except for the limited purpose of
transferring custody during which tlmcs the dcfendant shall
remain in his vehkle, I.I\W cnforcllml.lnt ngcncics, human service
agencies, domestic rellltions officcs, and school districts shall
not dlsclosc the prcsence of the pllllntiff or the children In the
jurisdiction or district or furnish any IIddrcBs, telephonc
numbcr, or IIny other demogrllphic Information IIbout the plaintiff
or children cxccpt by further Order of Court.
7. The defcndant is ordercd to PllY Interim support to the
plaintiff IInd the minor children in the amount of $198.00 per
week, payable to th.., pluintiff in the form of II check or money
order, by mall pending the cntry of un order by the Cumberland
County Domestic Rellltions office. The first payment is to be
made within tcn days upon entry of the Protection Order and each
week therellfter, The defendant is further ordered to provide
health coveragc to the spouse and the minor children.
8. The court costs and fees are waived,
9. This Order shull remain in effect for a period of one
year or unti I modified or terminated by the Court. The Order can
be extended beyond its original expiration date if the Court
finds that the defendant has committed another act of abuse or
has engaged in n pattern or pract Ice that Indicl\tes continued
risk of harm to the plaintiff.
10. A viollltlon of this Ordcr mllY subject the defendant to:
I) nrrest under 23 Pa.C.S. glll!.1; Ii) l\ private criminal
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6. The defendunt agrees to stay away from the plaintiff's
CUfrent resldencc IInd uny other residence the plaintiff may
establi8h, except for the Ilml ted purpose of trllnsferring
custody. The defendllnt shall remain in his vehicle nt 1111 times
during the transfer of custody.
7. The defcndunt ngrces to pay intcrim support to the
plaintiff and thc minor children the amount of $ 198.00 per week,
payable to the plaintiff in the form of a check or moncy order,
by mall pending thc entry of an ordcr by the Cumbcrland County
Domestic Rellltions Officc. The first pllyment is to be made
within ten days upon entry of thc Protection Order and each week
thereafter. The defcndant furthcr agrees to provide health
coverage to the spouse and minor child.
8. Thc defendant, although entering into this Agreement,
does not admi t the allegat ions mllde in the Pet I t ion.
9. The defendant understands that the Protection order
entered in this matter wi 11 be In effect fOf a period of one year
and can be extended beyond it original expiration date If the
Court finds that the defendant has committed another act of abuse
or has engaged in a pattern or practice thllt indicates continued
risk of harm to the plaint i fl'. The defendant understands that
this Order will be enforceable in the same manner as the court's
prior Temporary Protection Order entered In this case.
10. Violation of tbe Protection Order may subject the
defendant to: i) arrest under 23 Pa,C.S, ~6113i il) a private
criminal complaint under 23 Pa,C.S. ~61l3.1; iil) a charge of
indirect crlmln,,1 contclIlpt unclcr 2.1 Pa.e.S. 116114, punishable by
imprlaonment up to six months und II fine of $100.00-$1,000.00;
lAnd Iv) civil contempt undcr 2.1 PII.e.s. ~6114.1.
II. The clefcndunt IInd the plllintiff ngrcc to the cntry of
an Order providing for the following rcgllfdlng custody of their
chlldrcn, Cody J. Bolt (0011 'J/27/91) IInd Tyler R. Bolt (DOli
11/8/93)
II; The mother shall have prlmllry physical custody of
the children.
b. The mothcr IInd fllther shall share legal custody of
the children.
c. The father shall have partial custody of the
children on datcs IInd at times agreed upon by the
mother and fnther.
d. The mother and fllther agree that each shall not Ify
the other Immediately of medical emergencies which
arise while the chi Idren are In that parent's care.
e. The mother and father realize that their
children's well being is pllramount to any differences
they might have betweun themselves. Therefore, they
agree that neither party shall do anything which may
estrange the childrcn from the other parent, or Injure
the opinion of the children as to the other parent or
which may hampcr the free and naturlll development of
the ch i lllren' s love or respect for the other parent.
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