HomeMy WebLinkAbout97-05447
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6. The Defendant/Father spoke with the babysiuer who I1rst indicated she did not
know where the Plaintiff/Molher was and could not help the Defendant/Father locate the
Plaintiff/Mother;
7, The Plaintiff/Mother never contacted the Defendant/Father, nor did she return
to pick the children up on Sunday, February 7, 1999;
8. The Defendant/Father contacted the undersigned counsel on Monday, February
8, 1999 and requested an emergency hearing based on the disappearance of the
Plaintiff/Mother;
9. The Defendant/Father contacted the police to report a missing person only to
discover that the Plaintiff/Mother had travel to New York and was anticipating coming back
Monday evening after 5:00PM;
10, Subsequently the Plaintiff/Mother returned and regained custody of the children
on the evening of February 8, 1999;
11. The Defendant/Father contacted the babysitler on Tuesday, February 9, 1999
only to discover that the children were not at the babysitler's on February 9, 1999;
12, On February 10, 1999 the Plaintiff/Mother dropped the children off with the
Defendant/Father and the Paternal Grandparents and advised them uhe won and he can have
the kids";
13. At which point the Plaintiff/Mother relinquished custody to the
Def.::ndant/Father;
L.~vnL bl:.H.....II..:~b. IN...:.
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the IIOthur lIhall have New VeA",' ""y fr<.>", 11 :00 a.lII. until Janl.lar)l
2 lI.t ;):00 p.lII.
6. Th" mOlh",. 111\811 have cUlltody (If the children un
ThankllsivinB and Ra~ter from 6:00 a.m. until 3:00 p.~. and Lhe
Cathor lIhall hAv~ 3:00 p.lII. until '1:00 p.m.
7. Tho mother ~h611 have cu~toay of the children on
lIIother's Day and the fI1thor shl'Jll have cUlItody llf the children on
Fl'Jther'lI Day frolll 8:00 a... until 8:00 p.m.
~. The Cather shall have cu~tody of the children on
Novembe r I 'I, ~O, and 21, 1999.
9. The faTher shall have custody of tho children on
ColumbUS Day, Martin Luther King Day, and Presldont'lI Day 'rum
8:00 p.lI. the evening before the holiday ullt II .5 :00 p.m. on the
hol iday.
10. On Memorial DIl)", the fOUrth of July, and Labor I;)ay, the
father lIhall have cuslody of the children from 8:00 p.~. the
~vening before the holiday until 5:00 p.m. on the holiday, and
the ~other ~h611 have the children the Sunday before th~ hOllrl$y
frolll 6:00 a.lII. unUI 8:00 p.m. If the children are with the
father, the mother shall b~ rcsp~nBlble for pickl". them up on
Sunday mornin8 aod the father shall he responsIble for piCking
them up fro~ the mother on Sunday evening if he is scheduled to
have the children that eveninl and the next dny.
II. Thl! fllther 1S responBibh for picking up and droPl'inR
off the chi Idren for his periods of custody except as ordend in
peuguph II.
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Pln!ntiff
I N TlI~: COlIIlT OF COMMON 1'l.F.AS OF
r.UMflF.RI.AND COUNTY, PJ\NNSYJ.VAN 1 A
VR.
Mark A. Z !nlln'llrmRrI,
Ollfenelant
NO. 97-5447
CIVil. TERM
CUSTODY
PLAINTIFF~RETRI~k~EMORA~.VM
AND-.-W..LTJiIl.ll.ll_,.LHi'J'
The plllintiff, Oubrn I... O<:ker, hereinllfter rllferred to as
the mother. is represllntcd hy JOlin ('lIrey, of Legal Services, Inc.
The defendllnt, Mark A. Zimmlll'mnn, herei nllfter refllrred to as the
fllther, is represented hy Austin F. Grognn.
Thu mother and father III'Il thll pnrents of lhu minor chlldrlln,
Kaytlynne M. Nl\stelli (DOB 6/II/CJ.1) and Ml\rkA. Zimmerman, II
(008 8/24/94).
"I STORY OF-'I'JlILC~
Since their births, the mother has been the children's
primary caretaker.
On February 19, 1998, n Protection from Abuse Dreier and
Temporary Custody Order was entered by this Court, The Temporary
Custody Order granted the mother primnry physical custody of the
children and perinds of partial <:ustndy every other weekend at
the paternal grandp/lrents residence to the fnther, The Order
also required the mother to coopernte with II cUst~dy eV/lluation
paid for by the f/lther.
On July 15, ICJ9R, the fnther's nttorney, Austin F. Grognn,
filed a Petition for Custody Concilintion Conference nnd /l
conference WI\S ,'C'heduled for August 20, 1'l'lR, beforl' Hllhl'rt X.
Gilroy.
At thll Cotlcll lilt Ion C'ollferencll, thl! Il/Irt les were UII/lhll! to
rl!lIch /In I\grCtllllent /llId II hel\rinll WI\S schlldulccl.
Arllold Rhll!nvold, ph.n. perforlllcd II custody eVllluotlon Itnd
rllcommended thltt the "mther ml\lntllln prlmllry physical custody of
the chi Idren IInd thl! fllthl!r hllve pl!rlods of pllrtllll custody on
I\lternlltlng weekends IInd Wedllesdl\Y l!vening frolll thl! end of work
until 7:00 p.lII.
l:.\lBR FoNT .lli.5.!l.!':.,L!!E.EQlillJ1J./L COlJRT
It Is In thll best Interest of the chi ldren to rem/lin in the
primary physlcol custody of the mother for rel\sons Including, hut
not limited to, the following:
'II. The "mther hilS hl!en the prlmllry cllretllker of the
children since their hirths.
b. Thl! mother hll.s providl!d for the emotlonlll IInd
physlclIl need,; of the l'hlldren slncl! their hirth,s.
c. According to noetor ~hlenvold's reeommendotlon.
the ml>ther hilS fl grclltl!r IIhi 1 i ty to cont 1'01 the
children's behavior thun did the fllther. This is
Important heclluse the daughter, Kl\yt lynne, hilS been
dillgnosed with Attention nefleit Hypernetivl! nisorder.
The fathl!r has not IlGte" In bl!.st Interest of the children
for reasons InclUding, hut not limited tn, the following:
a. Thl! fllther hns 'lhused the plnlnl I ff In the
presenCI' of the chi I,lren.
The defendant Is ordered to refrain from hl\vlng any direct
or Indirect contact with the plnlntlff Including, but not limited
to, telephone nnt! written communications, except for the limited
purpose of facilitating custody nrrnngements.
The defcndnnt Is enjoined from hnrnssing nnd stalking the
,. plaintiff /lnd from hlll'nsslng the plrLintiff':'l relatives.
The defendnnt is enjoined from entering the plnint iff's
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place of employment.
The defendant is enjoined from removing, damaging,
'destroying or selling any property owned jointly by the parties
or owned solely by the plaintiff.
A violation of this Order may subject the defendant to: I)
arrest under 23 Pa.C.S. !l611J; Ii) a private criminal complaint
under 23 Pa.C.S. !l6113.1j iii) a charge of indirect criminal
contempt under 23 Pa.C.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.C.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 shall remain in effect until modified or
terminated by the Court and 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 Il pattern or
practice that indicates continued risk of hllrm to the plaintiff.
Temporary custody of Mark A. Zimmerman. II (D08 R/24/94),
a. On 01' about Scptember 21, 1997, the defendant
grabbed the plaintiff and bit her hand. As the
plaint I ff at tempted to f lee Into the bathroom, the
defendant fol lowed her, pushed the bathroom door open,
and bit her again on the wrist. The defendant punched
the plaintiff several times on her back, her neck, her
arm, and the back of her neck causing several bruises.
When the plaint i ff ran out of the room, the defendant
followed her and slammed her repeatedly into the dryer.
The plaintiff tried to call for help, but the defendant
grabbed the phone find hit her on the head. The
defendant threatened the plaintiff saying that If she
did not get out of there, he would kill her, causing
her to fear for her life. The plulntiff ran to the
garage and called the police. The defendant was
charged with simple assault and harassment.
b. On or about Ju Iy 4, 1997, the defendant restrained
the plaintiff from leuving the residence, punched her
several times, and choked her resulting in bruises on
her neck and causing her to fear for her safety.
c. In or about September 1996, the defendant grabbed
the plaintiff in a parking lot outside a bar and
punched her several times causing pain. When the
defendant returned home that night, he punched the
plaintiff and choked her causing her to fear {or her
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I I fe.
d. On several occasions since the summer of 1990, the
defendant has kicked, choked, punched, bit and shoved
the plaintiff, and pulled her hair. The defendant hus
on one occl\slon slammed the plaintiff onto the bed of
his truck and punched her In the mouth breaking off her
tooth. The defendant has beaten the plaintiff with
shoes, a phone, und other !tems.
5. On or about September 21, 1997, the plaintiff and the
two minor children left their residence at 870 Crain,s Gap Road,
Carlisle, Cumberland County, Pennsylvanill, in order to avoid
further abuse.
6. The plaintiff believes and therefore avers that she Is
in Immediate and present danger of abuse from the defendant and
that she is in need of protection from such abuse.
7. The plaintiff desires thllt the defendant be prohibited
from having any direct or indirect contact with the plaintiff
inclUding, but not limited to, telephone and written
communicat ions, except for the I imi ted purpose of faei II tat illl!
custody arrangements.
8. The plaintiff desires that the defendant be enjoined
from harasoing and stalking the plaintiff, and from harassing the
plaintiff's relatives.
9. The plaintiff desires that the defendant be restrained
from entering her place of employment.
:I
Plaint I ff, defendant, 870 Cralns Oap Road 10/96 to
/lnd Chassy Ocke r Carlisle, PA 9/21/97
Plaint Iff, de fendan t , 432 Pctl!rsburg Road 6/11/93 to
Rnd Chassy Oc ke r Carlisle, PA 10/96
The plaint Iff, the mothl!r of the children, current Iy resides
at 22 North High Street, Newville, Cumberland County,
Pennsy I van Ill.
She Is single.
The plaintiff currently resides with the fOllowing persons:
~
Mark A. Zimmerman II
Kaytlynne M. Nastelli
Chassy L. Ocker
Relationship
son
daughter
daughter
The defendant, the father of the children, currently resides
at 870 Crnlns Gap Road, Carlisle, Cumberland County,
Pennsylvania.
He Is single.
The defendant currently resides alone.
20. The plaintiff has not previously participated In any
litigation concerning custody of the above mentioned children in
t~is or any other Court.
21. The plaintiff has rio knowledge of any custody
proceedings concerning these children pending before a court in
this or any other jurisdiction.
22. The plaint i ff docs not know of any person not a party
to this action who has physical custody of the children or claims
to have custody or visitation rights with respect to the
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children.
23. The best Interests And permunent welfAre of the minor
children will be met I f custody is temporarily granted to thll
plaintiff pending a hearing in this mutter for reasons Including:
a. The plaintiff is R responsible parent who cnn best
tAke cure of the minor children and who hns provided
for the emot lonu I nncl phys iC/l I needs of the children
since their hlrths.
b. The defendunt hus shown by his obuse of the
plointiff thot he is not nn approprinte role model for
the minor children.
WHEREFORE, pursuunt to the I'rovisions of the "Protection
from Abuse Act" of Odober 7, 1976, 23 Pu.c.s. ft 6101 !lug., as
amended, the plnintiff prAYS this Honorable Court to grant the
following relief:
A. Grant a Temporary Order pursuant to the
"Protection from Abuse Act:"
1. Ordering the defendant to refrain' from
abusing the plaintiff or from placing her in fear
of abuse.
2. Ordering the defendant to refrain from having
any direct or Indirect contact with the plaintiff
Including, but not I iml ted to, telephone and
written communications, except to facilitate
custody arrangements.
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3. Ordering the defendant to refrain from
harassing and stalking th~ plaintiff and from
harassing the plnlntlff's relatives.
4. Prohibiting the defendnnt from entering the
plaintiff's place of employment.
S. Prohibiting the defendant from removing,
damaging, destroying or selling property jointly
owned by the parties or owned solely by the
plaintiff.
6. Ordering the defendant to stay away from the
plaintiff's residence locnted at 22 North High
Street, Newvi lie, Cemberland County, Pennsylvania,
which the parties have never shared, and any other
residence the plaintiff may establish, except for
the limited purpose of transferring custody of the
parties' children.
7. Granting temporary custody of the minor
children to the plaintiff.
B. Schedule a hearing in accordance with the provisions of
the '.Protection from Abuse Act,. and, after such hearing, enter
an order to be In effect for a period of one year:
I. Ordering the defendant to refrain from
abusing the plaintiff or from placing her in feaf
of abuse.
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2. Ordering the defendant to refrain from having
any direct ur Indirect C'lntact with the plaintiff
Including, hut not I Imi ted to, telephone and
written c<lflllllunlclltions, except to facilitate
custody IIrrangements.
3. Ordering the defendant to refrain from
harassing and stalking the plaintiff and from
harassing the pllllntiff's relatives.
4. Prohibiting the defendllnt from entering the
plaintiff's plllce of employment.
5. Prohibiting the defendant from removing,
damaging, destroying or selling property jointly
owned by the parties or owned solely by the
pia in tiff.
6. Ordering the defendant to stny away from the
plaintiff's residence located at 22 North High
Street, Newville, Cumberland County, Pennsylvania,
'whlch the parties have never shared, and any other
residence the plaintiff may establish, except for
the limited purpose of transferring custody of the
parties' children.
7. Granting support to the minor children in an
appropriate amount according to the support
guidelines, payable to the plaintiff in the form
<)
of Il check or money order. mailed to hur
rllsldence, Ilnd llrderlnl\ thc defendant to provide
health coverOl\e for the minor chi ldren
8. Ordering the defendant to PIlY $250.00 to
reimburse one 01' Legal Services, [nc, 's funding
sources I'llI' the cost of litiglltlng this case.
The pllllntiff further usks thllt this Petition be ri led and
served without payment of fees IInd costs by the plllintlff,
pending II further order ut the heuring, /lnd that certified copies
of this Petition und Order be delivered to the Pennsylvania
State, Newville, and North Middleton Police Departments which
have jurisdiction to enforce this Order.
The plaint Iff prays for such other re lief as mny be just and
proper.
COUNT I I
g[1!TODY UNDER PENNSYLVANIA CUSTODY LAW
24. The allegations of Count [ above arc incorporated
herein as If fUlly set forth.
25. The best interest nnd permanent welfare of the minor
children will be served hy confirming custody in the plaintiff as
set forth in paragraph 23 of the petition.
WHEREFORE, pursuant to 23 Pa.C.S. 9 5301 tl ~., and other
applicable rules and law, the plaintiff prays this Honorable
Court to award custody of the minor children to her.
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fur herlic I I' IIntl 011 hehnl I'
of h"r minor chi Illrt!ni
J<lIyllynnl! M. NlIsle III, IIn.1
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Mllrk A. ZIJIllllel'lIl/1n,
De fl'ntlllnl
I N T"~: ('(jURT Of COMMON PI.EAS OF
CUMBERL,\ND r'OlJNTY, PENNSYLVAN I A
NO. <)7-5447
CIVIl. TERM
PROTECTION FROM ABUSE
ANO CUSTODY
i'
N () TIC F.
You hllve heen liucd in COUl'l. If you wish 10 tleferlll IIgnlnst the
claims set forth In the fullowing pages, yuu IIIUlit lake 'lct ion prompt Iy
after this Pctltion, Ortlel' anti Nutice fire served, hy Ilppellrlng
l'ersllnf\lly 01' by attorney lit lht. hellrlng scheduled hy the Court IInd
present Ing to the ('ourl your defense,s or ohject ions to the c,lnims set
fol'lh against you. You lIrc' warnc'd thnt If you fill I tu do su the Court
may proceed wi thour you, Hrlll H jUllgJllcnt JIlay be entered IIgflinst you hy
thc' Court wilhout furthcr notin' for any 1II0ncy cllllmed in the Petition
or for uny other Clllllll or relief requcsted hy the plaintiff. You mny
lose money 01' property or other rights IlIIporLllnt to you. Any
Protection Order granted hy a Court may be considered in any
subsequent domesllc rellltions proceedings, including custody actions.
!,,!,! I'; 1L..ANIL.GQ,H s
I I' lhe case goes to h('lIr ing und the judge grllnts II Protect ion
Order, a surchllrge of $25,00 wi II he lI.ssessed flgllinst you, You may
also be required to pay up to .$250,00 to reimburse on.. of Legal
Services, Inc. 's funding sources for Legal Services Inc. '5
representation of the plaintiff.
You have the riKht to be represented by counsel. You should take
this paper to your Illwyer Ilt once. I f you do not have a lawyer or
cannot afford onc, go to or telephone the office set forth below to
find out where you can get legal help.
CUMBERLAND rOUNTY BAR ASSOCIATION
2 LII1F:RTY AVENUE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 24<)-3166 01' TOI.L FREE: 1-800-990-9108
FAX: (717)241)-2663
A"'JUUf1\N!!_.'!!!T!Ua.s AJULLT.lliL1\C.LQ.LJ,.2.9J!
The Court of Common Pleas of Cumherlflnd County is required by law
to comply with the Americllns with DisflhiIities Act of 19<)0. For
information flbout accessible faci liti..,s find reflsonahle accommodations
aVflilable to di.sllbled ind,vlduflls hllving busine,ss hefore the court,
please contact our offi"... ,\II arrllngemt'nt.s Illust be made at least 72
hours prior to flny heflring or husiness hefore the court. You must
attend the scheduled cOllft'f'l'Ilt't' or ht'f1rillg.
this mutter und ordering thnt the Temporury Protection Order
relllaln In effect for ,!II\! yellr ur lint II mod I fled or lllrmlnutud by
the Coun. This order wu~ entl'rell without prejudice to Qllthur
party to reque~t a hearln~. Sel' attuched Exhlhlt >> Incorporated
herein hy reference.
6. On JanulLry 6, 1'1'18, hased on the plainllff's petition
for Modlficntion, this Court entered IHI Ordor vaclltlng the
portions of the Tempornry Protection order daled OClober J, 1'l'l7,
which ordered the defendnnt to stay away frolll thl' plaintiff's
residence and any olher residence she lIIay estahl Ish, enjoined him
frolll having any ,llrect or Indirl'ct contact with the plnintlff,
and enjoined him frolll l'nler ing hl'r plncl' of employment. Pursuflnt
to thl! Order, tht! Temporary Protect Ion fwd Custody Order of
October J, 191)7, us cont inued by the Order of October 10, 19'17,
remained in effect in 1\11 other respects. See nttnchl!d Exhibit c
incorporuted herein hy referl'nce.
7. The dl'fendanl, since the entry of the Temporary
Protection from Abuse Ordl'r, hilS nbused the plnlntlff find minor
children and hilS violate,1 the tl'rms of the Protect ion Order In
ways InclUding, but not limi ted to, thl' following:
fl. On or ahout Februnry I, I l}C)8, whl Ie giving the
childrl'n n huth, the drdendnnt grnhbl'd nnd pushed thum
causing red lIIarks on thuir bodies, and screamed at the
plaintiff when r,hu tried to stop him, attempting to
justify his nbuslve behnvior hy saying thnt the
chlldrl'n were not eggs.
b. On or IIbout Jnnunry 31, 11)'18, the ddendnnt hit
thl! children Neverlll t lilies nnd then stilted to the
plaintiff, ~everal hours Int(,r, thnt the little
bn~tards "need bcnt" nnd thnt hc bcnts bls children
bccllu~e "the fucking nnilllnls need to lellrn obedience."
c. On or nbout .Jllllultry .Hl, 1'198, tIll' defcndnnt becnml!
enrllied nnd broke the coffee tnble in half cnuRlng the
p III In t Iff 1l11l1 chi I d I' e n to fell I' for t he I I' Ii a f e t y .
d. On or about JunuLIl'Y 21), 19'18, the defendant became
angry, urinated on the !llnlnt Iff, Ilncl threatened her by
saying that he would kill hut ns be pointed his finger
lit her head liS if It WUl'e n gun.
e. On or ahout January 2'1, 1998, the defendant
refused to allow the minor daughter, Kaytlynne, to use
the restroom for several minutes, hit her across the
head with an open hand, and kicked her several times
causing bruises and marks.
f. On or IIbout Jllnuary 28, 1998, the defendant hit
the minor son, Mark, across the stomach with the wire
end of a fly sWlltter cnusing welts.
8. The plaint i ff be I ieves nnd theref,He avers that she and
the minor children nre III immediate IInd present dnnger of abuse
from the defendant should they remain in the home without the
defendnnt's exclusion Illld that they nre In need of protection
from such abustl.
fl. The plulnt I CC des I res that the Court vllcntc the Order
dated Jtlnuury 6, l'IeIH, wh!c.:h U1<lllified the TcmporlHY PrntllctlQn
Order dllted' october J, 19'17, und reinHtnted the Tempornry
Protection order in itH entirety.
10. The plnintiCC dUHlrus thut the Court nm('nd the Petition
Cor Protectlnrl Order ,tod Custody duted October J. 1997, to
include thu minor children, Knytlynne M. Nnstelli IInd Mark A.
Zimmerman, II, Cor runsnns including those statud in paragraph
7a, 7b, 7c, 7e, and 7f of this pet i t ion.
11. The plaintiff dusirus thnt the Cnurt grnnt a Temporary
Protection Order excluding the deCendllnt from the residence
located nt 870 Crains Gnp Rond, Carl isle, Pennsylvllnilt, a
residence which is jnint Iy nwned by the pnrt ies, pending further
Order of Court aCter It hearing, for reasons including, but not
limited to, the following:
a. The plllintiff currently has no place to stay with
her children except the home, and the defendant has
family IInd Criends in the IIren with whom he can stay.
b.' The plaintiff desires possession of the mobile
home so liS to give the grelltest degree of continUity to
the lives of the children.
c. The plaintiff is II responsible parent who clln best
take care of the minor children IInd who hilS provided
for the emotionlll IInd physicn! needs of the chil~ren
since their births.
d. The defendant hns shown by his ahuse of the
pllllntlff tllllt he is not. nn Ilpproprlnte role model for
lhe minor chfldren.
c. The defendantis behnvfor hns ndversely affected
the children.
12. The plaintiff desfres thnt II hearing be held on the
Pet I t Ion for Protect iOIl frolT! Abuse dated Oct.oher .1, lQQ7, as
amended herein, IInd the within Petition.
1.1. Aust In Grogan, nttorney of record for the defendllnt"
hns been notified of the filing of this petition and he opposes
grant Ing the l'Olllef requested.
WHEREFORE, the plaintiff roquests that:
a. the defendant he held in contempt of the Temporary
Protection Order dated October .1, 1997, liS modified by
the Order of J'U1uary 6, lQQR,
b. t'he Order modifying the Temporllry Protect ion Order
dllted January 6, 19CJR, be vncated, and the Temporary
Protect ion Order be reinstated in its ent irety,
c. the Temporllry Protection Order be modified to
enjoin the defendnnt from nbusing the minor children or
fto~ placing them in feRr of abuse, and exclude the
defendant from the residence locnted at R70 Crains GlIp
Road, ClIrlisle, Pennsylvnnla.
d. a hearing be scheduled in IIccordnnce with the
provisions of the .Protection from Abuse Act,. and,
after suchhenrlng, eliteI' a final Protection Order
granting her the relief requested in the Petition:'!
and Kaytlynne M. Naatelli (DOB 6/11/93) ia hereby awarded to the
plaintiff, Debra L. Ocker.
A hearing ahall be he id on thia matter on the qlll day of
October, 1997, at 3',(;0 p.m., in Courtroom No.~, Cumberland
County Courthouse, Carlisle. Pennsylvania.
The plaintiff may proceed without pre-payment of fees
pending a further order after the hearing.
The Cumberland County Sheriff's Department shall attempt to
make service at the plaintiff'~ request and without pre-payment
of fees, but service may be accomplished under any applicable
rule of Civil Procedure.
This Order ahall 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 ma i I .
The Pennsylvania State, Newville, and North Middleton 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 arrest for
indirect criminal contempt without warrant upon probable cause
that this Order has been violated, whether or not the violation
is committed in the presence of the police officer.
In the event
that an arrest is made under this section, the defendant shall be
taken wi thout unnecessary de lay before the court that issued the
order. When that court is unavailable, the defendant shall be
The defendant is ordered to refrain from having any direct
or indirect contact with ~he plaintiff including, but not limited
to, telephone and written communications, except for the limited
purpose of facilitating custody arrangements.
The defendant is enjoined from harassing and stalking the
plaintiff and from harassing the plaintiff's relatives.
The defendant is enjoined from entering the plaintiff's
place of employment.
The defendant is enjoined from removing, damaging,
destroying or selling any property owned jointlY by the parties
or owned solely by the plaintiff.
A violation of this Order may subject the defendant to: i)
arrest under 23 Pa.C.S. !6113; ii) a private criminal complaint
under 23 Pa.e.s. !6113.1; iii) a charge of indirect criminal
contempt under 23 Pa.e.s. !6114, 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. !6114.1. Resumption of co-residence on
the part of the plaintiff and defendant shall not nullify the
provisions of the court order.
This Order shall remain in effect until modified or
terminated by the Court and can be extended beyond its original
expiration date if the Court finds that the defendant has
committed another act of abuse or has engaged in a pattern or
practice that indicates continued risk of harm to the plaintiff.
Temporary custody of Mark A. Zimmerman, II (DOB 8/24/94),
Debra L. Ocker,
Plaint iff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 97-
CIVIL TERM
Mark A. Zimmerman,
Defendant
PROTEr.TION FROM ABUSE
AND CUSTODY
PETITION FOR PROTECTION ORDER
AND CUSTODY
RELIEF UNDER THE PROTECTION FROM ABUSE
ACT, 23 Pa.C.S. 8 6101 et seq.
A. ABUSE
1. The plaintiff, Debra L. Ocker, is an adult Individual
residing at 22 North High Street, Newville, Cumberland County,
Pennsylvania 17241.
2. The defendant, Mark A. Zimmerman, (SSN: unknown) (Date
of Birth: 10/19/67). Is an adult Individual residing lit 870
Crains Gap Road, Carlisle, Cumberland County, Pennsylvania 17013.
3. The defendant has had an intimate relationship with the
plaintiff.
4. Since approximately summer of 1990. the defendant has
attempted to cause and has intentionally, knowinglY, or
recklessly caused bodily injury to the plaintiff, has placed the
plaintiff in reasonable fear of imminent serious bodily injury,
and has knowingly engaged in a course of conduct or repeatedly
committed act.s toward the plaintiff including following the
plaintiff, without proper authorization. under circumstances
which have placed the plaintiff in reasonable fear of bodily
injury. This has included. but is not limited to, the following
specific instances of abuse:
a. On or about September 21, 1997, the defendant
arabbed the plaintiff and bit her hand. As the
plaintiff attempted to flee into the bathroom, the
defendant followed her, pushed the bathroom door open,
and bit her again on the wrist. The defendant punched
the plaintiff several times on her back, her neck, her
arm, and the back of her neck causing several bruises.
When the plaintiff ran out of the room, the defendant
followed her and slammed her repeatedly Into the dryer.
The plaint Iff tried to call for help, but the defendant
grabbed the phone and hit her on the head. The
defendant threatened the plaintiff saying that If she
did not get out of there, he would kill her, causing
he r to f ear for he r I if e . The p I a I n tiff ran tot he
garage and called the police. The defendant was
charged with simple assault and harssr.ment.
b. On or about July 4, 1997, the defendant restrained
the plaintiff from leaving the residence, punched her
several times, and choked her resulting in bruises on
her neck and causing her to fear for her safety.
c. In or about September 1996, the defendant grabbed
the plaintiff in a parking lot outside a bar and
punched her several times causing pain. When the
defendant returned home that night, he punched the
plaintiff and choked her causing her to fear (or her
2
life.
d. On several ~ccasions since the summer of 1990, the
defendant has kicked, choked, punched, bit and shoved
the plaintiff, and pulled her hair. The defendant has
on one occasion slammed the plaintiff onto the bed of
his truck and punched her in the mouth breaking off her
tooth. The defendant has beaten the plaintiff with
shoes, a phone, and other items.
S. On or about September 21, 1997, the plaintiff and the
two minor children left their residence at 870 Crains Gap Road,
Carlisle, Cumberland County, Pennsylvania, in order to avoid
further abuse.
6. The plaintiff believes and therefore avers that she is
in immediate and present danger of abuse from the defendant and
that she is in need of protection from such abuse.
7. The plaintiff desires that the defendant be prohibited
from having any direct or indirect contact with the plaintiff
including, but not limited to, telephone and written
communications, except for the limited purpose of facilitating
custody arrangements.
8. The plaintiff desires that the defendant be enjoined
from harassing and stalking the plaintiff, and from harassing the
plaintiff's relatives.
9. The plaintiff desires that the defendant be restrained
from entering her place of employment.
J
Plaintiff, de fendan t , 870 Cralns Oap Road 10/96 to
and ChauY Ocker Carlisle, PA 9/21/97
Plaintiff, defendant, 432 Petersburg Road 6/11/93 to
and Chassy Ocker Carlisle, PA 10/96
The plaintiff, the mother of the children, current ly resides
at 22 North High Street, Newville, Cumberland County,
Pennsy I van I a.
she Is single.
The plaintiff currently resides with the following persons:
~
Mark A. Zimmerman II
Kaytlynne M. Nastelll
Chassy L. Ocke r
Relationship
son
daugh t e r
daughter
The defendant, the father of the children, currentlY' resides
at 870 Cralns Gap Road, Carlisle, Cumberland County,
Pennsylvania.
He is single.
The defendant currently resides alone.
20. The plaintiff has not previously participated In any
litigation concerning custody of the above mentioned children In
this or any other Court.
21. The plaintiff has no knowledge of any custody
proceedings concerning these children pending before a court In
this or any other jurisdiction.
22. The plaintiff does not know of any person not a party
to this action who has physical custody of the children or claims
to have custody or Visitation rights with respect to the
6
chi ldren.
23. The best intere~ts and permanent welfare of the minor
children will be met if custody is temporarily granted to the
plaintiff pending a hearing in this mutter for reasons including:
a. The plaintiff is a responsible parent who can best
take care of the minor children and who has provided
for the emotional and physical needs of the children
since their births.
b. The defendant has shown by his abuse of the
plaintiff that he is not an appropriate role model for
the minor children.
~IEREFORE, pursuant to the provisions of the "Protection
from Abllse Act" of October 7, 1976, 23 Pa.C.S. ft 6101 .ll.!.~., as
amended, the plaintiff prays this Honorable Court to grant the
following relief:
A. Grant a Temporary Order pursuant to the
"Protection from Abuse Act:"
1. Ordering the defendant to refrain from
abusing the plaintiff or from placing her .in fear
of abuse.
2. Order ing the defendant to refrain from having
any direct or indirect contact with the plaintiff
inclUding, but not limited to, telephone and
written communications, except to facilitate
custody arrangements.
7
3. Order ins the defendant 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.
S. Prohibiting the defendant from removing,
damaging, destroying or selling property jointly
owned by the parties or owned solely by the
plaintiff.
6. Ordering the defendant to stay away from the
plaintiff's residence located at 22 North High
Street, Newville, Cumberland County, Pennsylvania,
which the parties have never shared, and any other
residence the plaintiff may establish, except for
the limited purpose of transferring custody of the
parties' children.
1. Granting temporary custody of the minor
children to the plaintiff.
B. Schedule a hearing in accordance with th" provisions of
the "Protection from Abuse Act," and, after such hearing, enter
an order to be in effect for a period of one year:
~ 1. Ordering the defendant to refrain from
abusing the plaintiff or from placing her in fear
of abuse.
8
of a check or money order, mailed to her
residence, ,and ordering the defendant to provide
health coverage for the minor children
8. Ordering the defendant to pay $250.00 to
reimburse one of Legal Services, Inc. '5 funding
sources for the cost of I it igllt ing this case.
The plaintiff further asks that this Petition be filed and
served without pllyment 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 Pennsylvania
State, Newville, and North Middleton Police Departments which
have Jurisdiction to enforce this Order.
The plaintiff prays for such other relief as may be just and
prope r.
COUNT I I
CUSTODY UNDER PENNSYLVANIA CUSTODY LAW
24. The allegations of Count I above are incorporated
herein as if fUlly set forth.
25. The best interest and permanent we 1 fare of the minor
children will be served by confirming custody. in the plaintiff as
set forth in paragraph 23 of the petition.
WHEREFORE, pursuant to 23 Pa.C.S. ft 5301 ~ ~., and other
applicable rules and law, the plaintiff prays this Honorable
Court to award custody of the minor children to her.
10
, ,
r!JlCT 1 0 1997
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 97-5447 CIVIL TERM
Debra L. Ocker,
Plaintiff
Mark A. Zi~merman.
De fendan t
PROTECTION FROM ABUSE
AND CUSTODY
QRDER FOR CONTINUANCE
AND NOW, this Jf) tJ. day of October, 1997, upon consideration
of the attached Motion for Continuance, the matter scheduled for
hearing on October 9, 1997, at 3:00 p.m. in Courtroom No.4, by
this Court's Order of October 3, 1997, is hereby cant inued
generally. This Order is entered without prejudice to either
party to request a hearing.
The Temporary Protection Order shall remain in effect for
one year or until modified or terminated by the court.
The Cumberland County Sheriff's Department shall attempt to
make service at the plaintiff's request and without pre-payment
of fees, but service may be accomplished under any applicable
rule of Civil Procedure.
Certified copies of this Order for Continuance will be
provided to the Pennsylvania State, Newville, snd North Middleton
Police Departments by the plaintiff's attorney.
By the Court,
J.sI1<'J,:'A' (.... )~
Kevin A. Hess, Judge
Joan Carey
Attorney for Plaintiff
EXH[BlT 1\
I, . T:":~I:, r:'"I?'.', r-"'("'~ !'~":ORD
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--~ f;..' PrOf he notary
Austin F. Orogan
Attorney for Defendant
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, (ConUlIuatlon on,)
Iletindant Name: MARK ZI~
Qoc:ket Number:
j
POLICE
CRIMINAL COMPLAINT
all ofwblcb wen apIll8t the peace and d1ll11lty of tbe Commonwealth of PennllYlvanla and contrary to tbe Act
of Aaeembly, or in violation of ,. 10190 of tho PI'7\. ACr 6/23/78 1
(loctlon) (l1b-Soctlon) (PA SUtuto) (C"",U)
2, of tho 0
(loctlon) (lIb'Slctlon) (PA SUCUU) (c""'U)
], of thl 0
(loctlon) (SIb-Soctlon) (PA SUCUU) (c"",U)
4, of thl 0
(Slctlon) (SIb'SICClonl (PA SUtuc.) (c""'U)
3, I uk that a warrant of arrest or a summons be issued and that the defendant be required to snswer tbe charges
I have made, (In order for a WUTIIIIt ~ arnIlt to iCIIIue, the attached amdavit at probable cause mut be completed
lUIClllWOlD to before the IBsuing authority.
4, I verity that the facts set torth in this complelnt are true and correct to the best of my knowledge or information
and beUef, Tbis verlftcatlon Is made subject to the penalUes of Section 4904 ofthe Crimes Code(18 PA C
.4904) relatinll to unsworn falsUlcatlon to authorities,
.
,
.-
,19_
..
AND NOW, on this date , 19 , I certify the complelnt has been properly
completed and verified. An afI'Idavlt of probable cause must be completeiJ in order for a warrant to iasue.
v,.gluerUl IJlltrlctJ
AOPC 412'(4/96)(I"tlroo. Vlr.lon)
8BAL
(~'Iulng AutnorltYJ
2-3
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,
p"'FIC~ OF THE DISTRICT ATTORNEY
OF CUMBERLAND,COUNTY
ONI COlJRTHOlJ8l SQlJARI
CARL'SLI, PINNSVLVANIA 170'S
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