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JOSEPH p, MURPHY,
Plaintiff
I IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
JACXYANN CLINE,
Defendant NO. 97-5990 CIVIL TERM
IN REI PROTECTION FROM ABUSE
ORDER OF COURT
AND NOW, this 3rd day of November, 1997, a
hearing was held today on the protection from abuse complaint
that was filed by Joseph P. Murphy who was represented by
Barbara Sumple-Sullivan, Esquire, against Jackyann Cline who was
represented by Charles Rector, Esquire. After the testimony was
completed, the Defendant had no objection to a PFA order being
entered against her, and, therefore, the Court does direct that
in the future the Defendant, Jackyann Cline, is prohibited from
abusing Joseph P. Murphy, the definition of ab~se as being set
forth in the Protection From Abuse Act. The Court further
directs that Ms. Cline will not enter the premises owned by the
Plaintiff which is located at 1809 st. Clair Road, New
Cumberland, Pennsylvania.
At the PFA hearing the Court was informed that Judge
Bayley had previously entered an order directing that primary
physical custody of the parties' son, Joseph P. Murphy, Jr" was
awarded to Jackyann Cline, After that order was entered, th~
parties did resume cohabitation; however, the order has not been
changed.
.
The partie. have now permanently .eparated and Ms.
Cline indicate. that 80metime during the month of November she
will be moving into a residence on Fourth street in the borough
of New Cumberland. Both the daughter of Ms. Cline and the son
of both Mr. Murphy and Ms. Cline attend school in New
Cumberland.
I would direct that until Ms, Cline obtains her
residence on Fourth Street, that temporary custody of Joseph P.
Murphy, Jr" be awarded to his father, Joseph p, Murphy, and at
such time as Ms. Cline establishes her residence at the Fourth
street property as she testified today, then custody of Joseph
p, Murphy, Jr., shall be returned to her as directed by the
order of Judge Bayley unless there would be an order by Judge
Bayley bet'ieen now and then changing the present custody
arrangement,
I have informed the Defendant that if the Plaintiff,
Joseph P. Murphy, wishes to change the order, then prior to this
taking effect he should file some type of an emergency petition
with Judge Bayley. If Judge Bayley then changes his prior
order, so be it.
By the Court,
P.J.
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Barbara Su.ple-Sullivan, Esquire
For the plaintiff
tv-;; :.... (7,...;"61
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Charl.. Rector, E.quire
For the Defendant
:1th
JOSEPH P. MURPHY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL~ANIA
No. ~). ~-<j1'tJ tliJJ ..:i?~....
PROTECTION FROM ABUSE
V.
JACKYANN CLINE,
Defendant
NOTICE TO DEFEND AND CLAIM R[GHTS
YOU HAVE BEEN SUED IN COURT. The Plaintiff is the person suing on behalf of
the abused person, Allached is a copy of the petition which indicates the relief the Plaintiff is
requesting, Also included in the petition are Plaintiff's reasons for these requests,
You must appear at the hearing on the 3.~ day of ~(;Vt.o...1~, ,1rf/7, at
lo:cC'II.M, in the assigned counroom of the Court of Common Pleas 0 this county, located at
Carlisle, Pennsylvania,
If you do not appear at the hearing at that time and place, the order requested by the
Plaintiff may be granted in your absence, and you may lose money or property rights or other
rights important to you, and/or a bench warrant may be issued directing the sheriff to brihg you
into court,
A copy of a, TEMPORARY ORDER is attached, you must obey it until the hearing. If
you do not obey, the police can arrest you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
COURT ADMINI~TRATOR
Cumberland County Courthouse
One Courthouse Square
CarIIs[e. PA 17013
(717) 240-6200 /
~ ~pl,-S,I1i.m. ...',.
Allomey for Plaintiff
549 Bridge Street
New Cumberland, Pa 17070
(7[7) 774.1445
Supreme Court 1.0, No. 32317
JOSEPH p, MURPHY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V,
No.
JACKY ANN CLINE,
Defendant
PROTECTION FROM ABUSE
TEMPORARY ORDER UNDER SECTION 10185 OF
THE PROTECTION FROM ABUSE ACT
AND NOW, this,J.1 "Ih day of f}t:Ib~ , 19 91 this Coun having found thaI,
good cause exists to enter an Order pursuant to Section 10185 of the Protection from Abuse Act;
It is hereby ORDERED and DECREED that Defendant, JackyAnn Cline, is restrained
from physically striking, harassing, threatening or contacting Plaintiff, Joseph p, Murphy, and
visiting, entering or attempting to enter the Plaintiff's present address or any subsequent
residence of the Plaintiff. Pending the conciliation conference scheduled for December 4, 1997,
Plaintiff shall retain majority physical custody of the panies' child, Joseph p, Murphy.
Defendant shall have partial physical custody as can be mutually agreed.
This Order shall remain in effect until the hearing in the above-captioned matter.
The Sheriff is directed to serve a copy of this Order and the accompanying Petition on
the Defendant without prepayment of costs,
Law enforcement officers, the staff of the county office maintaining the Registry of
Protection Orders and coun personnel shall not disclose to Defendant, Defendant's counselor
JOSEPH p, MURPHY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V,
No.
JACKY ANN CLINE.
Defendant
PROTECTION FROM ABUSE
ORDER
AND NOW, this
day of
, 19_. under the authority of the
Pennsylvania Protection from Abuse Act. the Defendant is hereby Ordered and Directed as
follows:
1. Defendant shall not abuse visit, enter or attempt to enter the Plaintiff's present
address or any subsequent residence of the Plaintiff, or his place of employment. Effective from
, 1997, to
,1998.
2. Defendant shall pay Plaintiff for financial losses resulting from the abuse,
including attorney fees, and court costs,
3, Plaintiff shall retained majority physical custody of the parties' child pending a
the conciliation conference scheduled for December 4, 1997.
A photocopy of this Order shall be filed with the police department and shall be sufficient
to constitute the Court's authorization for enforcement.
VIOLA TlON OF THIS ORDER IS PUNISHABLE BY IMPRISONMENT FOR UP TO
SIX (G) MONTHS OR A FINE NOT TO EXCEED $1,000.00 OR BOTH.
TO THE POLICE
Under the Pennsylvania Protection from Abuse Act, you are authorized to arrest the
Defendant fO,r a violation of this Order without warrant upon probable cause whether or not the
violation was commilled in your presence, The Defendant is to be taken forthwith b4!fore a
district justice for preliminary arraigrunent,
BY THE COURT
J.
JOSEPH p, MURPHY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYlVANIA
V,
No.
JACKY ANN CLINE,
Defendant
PROTECTION FROM ABUSE
PETITION FOR PROTECTION FROM ABUSE
AND NOW, the Plainliff, JOSEPH p, MURPHY, by his attomey, Barbara Sumple-
Sullivan, Esquire, pursuant 10 the provisions of the Proleclion from Abuse ACl. JS P,S. Section
10181 ~ WL., respectfully represents as follows:
1. Plaintiff is Joseph p, Murphy, an adulllndlvldual who resides al 180951, Clair
Road, New Cumberland, Cumberland County. Plainliff and his son. Joseph p, Murphy, who
was born on January 13, 1991 reside althls residence,
2, Defendant is Jackyann Cline, an adull Individual currently occupying 1809 51,
Clair Road, New Cumberland, Cumberland County, Pennsylvania wllh the Plalnliff. Defendanl
has filed a child support Complaint against Plaintitr on September 29, 1997 and averred a
residence of 115 North 31st Street, Camp Hill, Pennsylvania. 17011.
3, The parties 10 Ihls action were intimale parlners who had resided logelher al1809
51. Clair Road. New Cumberland, Cumberland Counly, Pennsylvania, since May 18. 1996.
4. The premises where the Plaintiff and the Defendant reside consists of a single
family home which is owned individually by Plaintiff.
5. During the course of the parties' relationship, Defendant has attempted to cause
and has intentionally, knowingly, and recklessly caused bodily and mental Injury to the Plaintiff
by placing Plaintiff in fear of Imminent bodily injury,
6, Shortly after Defendant returned to Plaintiff's home in May 1996. it became
apparent that their relationship and living arrangements would not work, Plaintiff has sought
an amicable "decoupling" of the parties for the sake of their minor son. The tension in the
household has slowly increased due to the actions of Defendant.
7. Defendant's behavior has become increasingly belligerent. physical,
confrontational and has deteriorated to a point that serious hann may come to Plaintiff,
8. Defendant's intentional, knowingly and reckless actions which have caused bodily
and mental injury to Plaintiff are as follows:
a) On September 28, 1997, Defendant became enraged at Plaintiff cursing,
yelling and screaming at Plaintiff about a loan she co-signed for Plaintiff's
daughter. Defendant continued her verbal assault by making slanderous
and inflammatory accusations. Her intent was clearly to attempt to
provoke Plaintiff into losing his control. Instead, Plaintiff called his
brother who was able to get Defendant to leave the premises.
2
b) The following weekend, on or about October 4, 1997, Defendant once
again being unprovoked began yelling, cuning and slapped Plaintiff,
Again, Defendant desired to provoke P!aintiff into some physical
retribution against her by her cuninll, makinll inflammatory accusations
concerning Plaintiff and his daughter and pointing a finger inches away
from Plaintiff's face, Plainliff remained calmed throughout. Defendant's
behavior continued until 1:00 A. M, when Plaintiff finally locked himself
in his room to avoid Defendant's continual verbal tirade and threatening
physical act.s.
c) During the evening of October 24, 1997 while Plaintiff was silting at his
eomputer, Defendant came into his room extremely agitated. When
Defendant realized that Plaintiff could not be provoked by words alone,
she tore thinlls up in his office, poked and prodded Plaintiff about his
upper body and hil Plaintiff about his face, While Plaintiff was walking
away from Defendant's latest u"aulc, she leamed that Plaintiff wa$ going
to go to his physician relative 10 her physical assault, When Defendant
learned this, she Immediately called 911 and made untrue allegations to
the authorities Ihal Plalllliff was threatening her and going to kill her.
After discussion with Ihe police and the failure to remove her from the
household, Plainliff once again locked himself in his room to avoid
contact from Defendant.
9. The aforesaid aClions by the Defendant have placed the Plaintiff in immediate and
present danger of abuse, It is believed and feared lhat Ihese actions of violence will escalate
agail13t Plaintiff due to her heightening agressive behavior,
10. Plaintiff is conccmed Ihal if Defendant is not removed from his home that the
situation will conlinue 10 deleriorate ending In grave bodily injury to himself or the child in the
home.
3
11. Defendant has other living arrangements available to her. Plaintiff believes that
she is remaining at his home to further incite the situation and provoke Plaintiff so as to gain
an strategical advantage in pending litigation.
12. On September 30, 1997 Plaintiff filed a Petition to Modify Custody Order to
preserve the child's status quo once Defendant indicated her desire to relocate, A conciliation
conference is scheduled for December 4, 1997 to docket number No. 7223 - 1994 filed in the
Court of Common Pleas of Cumberland County, Pennsylvania.
13, Plaintiff believed that service of the instant Petition and Order of the Court cannot
be performed safely by anyone other than a law enforcement officer.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court enter an Order
pursuant to the Protection from Abuse Act providing relief, including but not limited to :
A. Directing Defendant to refrain from abusing the Plaintiff;
B, Prohibiting the Defendant from any ~ontact with the Plaintiff including. telephone
calls to his home, except for the purposes of contacting her son;
C. Prohibiting the Defendant from harassing the Plaintiff and his ehildren;
D, Plaintiff shall have exclusive possession of his home. Defendant is to complete
her relocation to the Camp Hill address provided to the Court in her September
28, 1997 child support claim;
4
E. The parties' ehild shall remain with Plaintiff until the conciliation conference,
Defendant shall have rights of partial physical custody; and
F. Directing Defendant to pay Plaintiff for tinanclallosses resulting from the
abuse, Including medical care, and attorney fees, and court costs,
arbara Sumple-Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
Supreme Court I.D, No. 32317
TRue COP'( FROM RECORD
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~T 281997
JOSEPH P. MURPHY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
No. ti7 -5t}tJ()
~/~~~
JACKY ANN CLINE,
Defendant
PROTECTION FROM ABUSE
NOTICE TO DEFEND AND CLAIM RIGHTS
YOU HAVE BEEN SUED IN COURT. The Plaintiff is the person suing on behalf of
the abused person, Allached is a copy of the petition which indicates the relief the Plaintiff is
requesting, Also included in the petition are Plaintiff's reasons for these requests,
You must appear at the hearing on the ~ ,~ day of -fltfV(.~ ,19!1, at
10 : C b II, M. in the assigned courtroom of the Court of Common Pleas of this county, located at
Carlisle, Pennsylvania.
If you do not appear at the hearing at that time and place, the order requested by the
Plaintiff may be granted in your absence, and you may lose money or property rights or other
rights lmportantto you, and/or a bench warrant may be issued directing the sheriff to bring you
into court,
A copy of a TEMPORARY ORDER is attached, you must obey it until the hearing. If
you do not obey, the police can arrest you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFICE SET ::OORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
COURT ADMINISTRATOR
Cumberland County Courthouse
One Courthouse Square
Carlisle, PA 17013
(717) 240.6200
/~~ara umple-Sullivan, Esquire
Allomey for Plaintiff
549 Bridge Street
New Cumberland, Pa 17070
(717) 774-1445
Supreme Court 1.0, No. 32317
JOSEPH P. MURPHY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
No, 9'1- sVttJ
V.
JACKY ANN CLINE,
Defendant
PROTECTION FROM ABUSE
TEMPORARY ORDER UNDER SECTION 10185 OF
THE PROTECTION FROM ABUSE ACT
AND NOW, this ~,'lhday of~, 19!1lthis Court having found that
good cause exists to enter an Order pursuant to Section 10185 of the Protection from Abuse Act;
It is hereby ORDERED and DECREED that Defendant, JackyAnn Cline, is restrained
from physically striking, harassing, threatening or contacting Plaintiff, Joseph p, Murphy, and
visiting, entering or attempting to enter the Plaintiff's present address or any subsequent
residence of the Plaintiff. Pending the conciliation conference scheduled for December 4, 1997,
Plaintiff shall retain majority physical custody of the parties' child, Joseph p, Murphy,
Defendant shall have partial physical custody as can be mutually agreed,
This Order shall remain in effect until the hearing in the above-captioned matter,
The Sheriff is directed to serve a copy of this Order and the accompanying Petition on
the Defendant without prepayment of costs.
Law enforcement officers, the staff of the county office maintaining the Registry of
Protection Orders and court personnel shall not disclose 10 Defendant, Defendant's counselor
any Ihird party the confidential address of any domestic vlolenee program involved in th!s case
or any confidential address of Plaintiff.
Upon presentation of a copy of this Order, the New Cumberland Police Department shall
enforce this Order and shall arrest the Defendanl if she fails to comply wilh the Order,
A hearing is scheduled on Ihe ~ay of ~ lcJ11 al~. in
Courtroom No..:I.. '
BY THE COURT
kftJ Eo f{~
/J,
/
JOSEPH P. MURPHY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY , PENNSYLVANIA
V.
No.
JACKY ANN CLINE,
Defendant
PROTECTION FROM ABUSE
ORDER
AND NOW, this
day of
, ' 19_, under the authority of the
Pennsylvania Protection from Abuse Act, the Defendant is hereby Ordered and Directed as
follows:
1. Defendant shall not abuse visit, enter or allemptto enter the Plaintiff's present
address or any subsequent residence of the Plaintiff, or his place of employment. Effective from
, 1997, 10
, 1998,
2, Defendant shall pay Plaintiff for financial losses resulting from the abuse,
including allorney fees, and court costs,
3. Plaintiff shall retained majority physical custody of the parties' child pending a
the conciliation conference scheduled for December 4. 1997.
A photocopy of this Order shall be filed with the police department and shall be sufficient
to constitute the Court' s authorization for enforcement.
VIOLATION OF THIS ORDER IS PUNISHABLE BY IMPRISONMENT FOR UP TO
SIX (6) MONTHS OR A FINE NOT TO EXCEED $1,000,00 OR BOTH.
TO THE POLICE
Under the Pennsylvania Protection from Abuse Act, you are authorized to arrest the
Defendant for a violation of this Order without warrant upon probable cause whether or not the
violation was commilled in your presence, The Defendant is to be taken forthwith before a
district justice for preliminary arraignment.
BY THE COURT
J.
JOSEPH P. MURPHY,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V,
No,
JACKY ANN CLINE,
Defendant
PROTECTION FROM ABUSE
PETITION FOR PROTECTION FROM ABUSE
AND NOW, the Plaintiff, JOSEPH p, MURPHY, by his allomey, Barbara Sumple-
Sullivan, Esquire, pursuant to the provisions of the Protection from Abuse Act, 35 P.S. Section
10181 ~~, respeclfully represents as follows:
1. Plainliff is Joseph p, Murphy, an ndull individual who residl}s at 1809 St. Clair
Road, New Cumberland, Cumberland County. Plaintiff and his son, Joseph P. Murphy, who
was born on January 13, 1991 reside allhis residence.
2. Defendant is Jackyann Cline. an adult individual currently occupying 1809 St,
Clair Road, New Cumberland, Cumberland County, Pennsylvania wilh the Plaintiff, Defendant
has filed a child support Complaint against Plainliff on September 29, 1997 and averred a
residence of 115 North 31st Slreet, Camp Hill, Pennsylvania, 17011.
3. The parties to this action were inlimate partners who had resided together at 1809
SI. Clair Road, New Cumberland, Cumberland Counly, Penn3ylvania, since May 18, 1996.
4. The premises where the Plaintiff and the Defendant reside consists of a single
family home which is owned individually by Plaintiff.
5, During the course of the parties' relationship, Defendant has attempted to cause
and has intentionally, knowingly, and recklessly caused bodily and mental injury to the Plaintiff
by placing Plaintiff in fear of imminent bodily injury.
6. Shortly after Defendant returned to Plaintiff's home in May 1996, it became
apparent that their relationship and living arrangements would not work, Plaintiff has sought
an amicable "decoupling" of the parties for the sake of their minor son. The tension in the
household has slowly increased due to the actions of Defendant.
7, Defendant's behavior has become increasingly belligerent, physical,
confrontational and has deteriorated to a point that serious harm may come to Plaintiff.
8. Defendant's intentional, knowingly and reckless actions which have caused bodily
and mental injury to Plaintiff are as follows:
a) On September 28, 1997, Defendant became enraged at Plaintiff cursing,
yelling and screaming at Plaintiff about a loan she co-signed for Plaintiff's
daughter. Defendant continued her verbal assault by making slanderous
and inflammatory accusations. Her intene was clearly to attempt to
provoke Plaintiff into losing his control. Instead, Plaintiff called his
brother who was able to get Defendant to leave the premises.
2
b) The following weekend, on or about October 4, 1997, Defendant once
again being unprovoked began yelling, cursing and slapped Plaintiff.
Again, Defendant desired 10 provoke Plaintiff into some physical
retribution against hcr by her cursing, making inflammatory accusalions
concerning Plaintiff and his daughtcr and pointing a finger inches away
from Plaintiff's face. Plaintiff remained calmed throughout. Defendant's
behavior continued until 1:00 A,M. when Plaintiff finally lockcd himself
in his room to avoid Defendant's continual verbal tirade and threatening
physical acts.
c) During the evening of October 24, 1997 while Plaintiff was siuing at his
eomputer, Defendant came into his room extremely agitated, When
Defendant realized that Plaintiff could not be provoked by words alone,
she tore things up in his officc, poked and prodded Plaintiff about his
upper body and hit Plaintiff about his facc. While Plaintiff was walking
away from Defendant's latest assault, she leamed that Plaintiff wa$ going
to go to his physician relative to her physical assault. When Defendant
learned this, she immediately called 911 and made untrue allegations to
the authorities that Plaintiff was threatening her and going to kill her.
After discussion with the police and the failure to remove her from the
household, Plaintiff once again locked himself in his room to avoid
contact from Defendant.
9. The aforesaid actions by the Defcndant have placed the Plaintiff in immediate and
present danger of abuse, It is believed and feared that these actions of violence will escalate
against Plaintiff due to her heightening agressive behavior.
10, Plaintiff is concerned that if Defendant is not removed froOl his home that the
situation will continue to deteriorate ending in grave bodily injury to himself or the child in the
home,
3
II. Defendanl has other living arrangemenls available 10 her. Plainliff believes thai
she is remaining al his home 10 further incite Ihe silualion and provoke Plainliff so as 10 gain
an strategical advanlage in pending Iiligalion.
12, On September 30, 1997 Plaintiff filed a Pelilion 10 Modify Custody Order 10
preserve the child's status quo once Defendant indicaled her desire to relocale. A concilialion
conference is scheduled for December 4, 1997 10 docket number No, 7223 - 1994 filed in the
Court of Common Pleas of Cumberland County, Pennsylvania.
13, Plaintiff believed thai service of the instant Pelition and Order of Ihe Court cannol
be perfonned safely by anyone olher Ihan a law enforcement officer.
WHEREFORE, Plaintiff respeclfully requests Ihalthis Honorable Court enler an Order
pursuant to Ihe Protection from Abuse Act providing relief, including bul nOllimiled 10 :
A, Directing Defendanl to refrain from abusing the Plaintiff;
B. Prohibiting the Defendanl from any contacl with the Plainliff including. lelephone
calls to his home, except for the purposes of contacting her son;
C. Prohibiting the Defendant from harassing the Plaintiff and his children;
0, Plaintiff shall have exclusive possession of his home, Defendanl is to complele
her relocation to the Camp Hill address provided to the Court in her Seplember
28, 1997 child support claim;
4
E. The parties' child shall remain with Plaintiff until the conciliation conference.
Defendant shall have rights of partial physical custody; and
F. Directing Defendant to pay Plaintiff for Cinanciallosses renulting from the
abuse. including medical care, and allomey fees, and court costs,
'Barbara Sumple.Sullivan, Esquire
549 Bridge Street
New Cumberland, PA 17070
(717) 774-1445
Supreme Court I.D, No. 32317
,{I
5
VERIFICATION
I. Joseph P. Murphy. hereby certify that the facts sel forth in the foregoing PETITION
are true and correct to the best of my knowledge, information and belief. I understand that any
false slate men Is made herein are subject to penalties of 18 Pa. C.S,A, 64904 relating to unsworn
falsification to authorities,
DATED:
IO/.tr/';?
~ p~'\tCJ
( Joseph P. rph