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by the defendant within livc (5) days of thc cntry of thc Protcction Order in thc abovc-captioncd
mattcr. Thc total amount of losscs shall bc rcimburscd to thc plainti/l' within 30 days of thc cntry
of this Ordcr. An award undcr this chaptcr shall not constitute a bar to litigation for civil damagcs
lor injuries sustaincd from the acts of abusc giving rise to the award or a linding of contcmpt
under this chapter,
8. The defendant is ordered to pay support to thc plainti/l' and the minor children in
the amount of $75,00 per week payable to the plaintiff in the form of a check or money order,
mailed to her residence pending thc entry of an order by the Cumberland County Domcstic
Relations Office. Payments shall commence upon cntry of this Order and each Friday thereafter.
The defendant is ordered to continue to provide health coverage to the plaintift' and the minor
children, and to pay all of the unreimbursed medical expenses of the plaintifl'and/or minor children
of the parties to the provider or to the plaintifl'when she has paid for the mcdical treatment.
9. Court costs and fees arc waived.
10, This Order shall remain in eflcct for a period of one (I) year and can be extended
beyond that time if the Court linds that the defendant has committed an act of abuse or has
engaged in a pattern or practice that indicates risk of harm to the plaintifl: This Order shall be
enforceable in the same manner as the Court's prior Temporary Protection Order entered in this
case.
I I. 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.C,S, ~6113.1; iii) a charge of indirect criminal
contempt under 23 Pa,C,S, ~6114, punishable by imprisonment up to six months and a line of
$100,00-$1,000.00; and iv) civil contempt under 23 Pa,C.S, ~6114. I.
12, The East Pennsboro Township Police Department shall be provided with a
certilied copy of this Order by the plaintill's attorney and may enlorce this Order by arrest for
indirect criminal contempt without warrant upon probable cause that this Order has been violated.
whether or not the violation is com milled in the presence of the police omcer. In the event that
an arrest is made under this section. the defendant shall be taken without unnecessary delay before
the court that issued the order. When that court is unavailable, the defendant shall be taken
before the appropriate district justice. (23 Pa.C.S. 96113).
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Joan Carey
LEGAL SERVICES. INC.
Attorney for PlaintilT
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Justin Jay Eldredge. Defendant
201 2nd Street
Summerdale, P A 17093
DISK: DVXXIIIA:ELDREDGE.DOC
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CHARLENE MARIE EI.I>RE()<iE,
Plnilllill'
IN TIll,: ('01 Jln OF ('OMMON PLEAS 01'
('I//o.III1\ltI ,AND ('OIJNTY. PENNSYLVANIA
v.
NO 1)1l.20 I ('IVII. TERM
JUSTIN JA Y EI.I>REI><iE.
Dclclldnlll
I'IUl'IH'TION I'llO/o.l AB\JSE AND CUSTODY
.lISTOI)\' OIU)ER
AND NOW, thiSk.7 dny of Jnllunry, 11)I)ll. UpOIl considcrntion of thc partics' Consent
Agreement, the lallowing Ordcr is clllcrcd with rcgnlllto custody of Ihc partics' children, Kristen
Marie Eldredge and Dcrrick Jay Eldrcdgc
I. Thc plaint ill: hcrcinallcr reler-rcd to ns thc mothcr. nnd the dclcndant, hereinafter
referred to as thc Hllhcr. shall sharc Icgnl cuslody of Ihc childrcn,
2. Thc mothcr shall hnvc primary physical cuslody Ofthc children,
3, Thc Ihthcr shall havc supcrviscd visils with thc children in the presence of a
mutually agrecd upon third pany on dalcs and ntlimcs mutually ngrecd upon by Ihe parties,
4, Thc Hlthcr shallundcrgo a drug and alcohol cvaluation. lallow the recommended
treatmcnt, and continuc in trcatmcnl ulllil relcascd by his counsclor/thcrapist. Attorneys for the
plaintil1' shall have acccss 10 infbrmation conlinning Ihe dcfcndant's attendance and successful
complclion ofthc Ircalmcnl program.
5. Thc Hllhcr shall not usc illcgal drugs lind/or alcohol imll1cdiately prior to or during
pcriods of custody wilh 1 hc childrcn
6. The mother and Hllher shall notily the othcr of allmcdical care the children receive
while in that parent's care, Each parcnt shallllotify the other immediately of medical emergencies
which arise while the children are in that parent's care,
7, Neither party shall do anything which may estrange the children from the other
parent, or injure the opinion of the children as to the other parent or which may hamper the free
and natural development of the children's love .lr respect for the other parent.
on dates and at times mutually agreed upon by the parties,
8. This Order shall rcmain in elrect until further Order of Court.
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
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Justin Jay Eldredge, Defendant
20 I 2nd Street
Summerdale, PA 17093
DISK: DVXXIIIA, ELDREDGE. DOC
.
CHARLENE MARIE ELDREDGE,
Plaintifl.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
v,
NO. 98-201 CIVIL TERM
JUSTIN JAY ELDREDGE,
Defendant
PROTECTION FROM ABUSE AND CUSTODY
CONSENT AGREEMENT
"'-
This Agreement is entered on this dJo day of January. 1998. by the plaintiff,
Charlene Marie Eldredge. and the defendant, Justin Jay Eldredge, The plaintiff is represented by
Joan Carey of LEGAL SERVICES. INC.; the defendant is unrepresented but is aware ofhi~ right
to have an attorney. The parties agree that the following may be entered as an Order of Court.
I. The defendant. Justin Jay Eldredge. agrees to relrain from abusing the plaintiff,
Charlene Marie Eldredge, or from placing her in fear of abuse,
2, The defendant agrees not to have any direct or indirect contact with the plaintilT
including, but not limited to, telephone and written communications, except for the limited
purpose of facilitating custody arrangements.
3. The defendant agrees not to harass and stalk the plaintill' and not to harass the
plaintill's relatives and the minor children.
4. The defendant agrees not to enter the plaintitl's place of employment or the day
care Iilcility of the minor children,
5. The defendant agrees not to remove, damage, destroy. or sell any property owned
by the plaintifl' or jointly owned by the parties,
6, The defendant agrees to stay away from the plaintitl's current residence at an
undisclosed location lor her protection. and agrees to stay away Irom any residence the plaintiff
may in the luture establish lor herself.
7, The defendant agrees 10 rcimhlll'se Ihe plllintil1's out.ol:poekel losses of $<J7.85
sul1ered as a result of the incident on or about December 27. 1997, including but not limiled to
the losses listed on the attached sheet marked Exhibit A. The delendant agrees to commence
payment of losses to the plainlilr within live (5) days of the entry of Ihe Protection Order in the
above-captioned matter. The tolalamount of losses shall be reimbursed to the plaintjfi' within 30
days of the entry of the Protection Order.
8. The defendant agrees to pay interim support to the plaintil1' and the minor children
in the amount of $75,00 per week payable to the plaintiff in the lann of a check or money order
by mail pending the entry of an order by the Cumberland County Domestic Relations Omce.
Payments to commence upon entry of the Protection Order and each Friday thereafter,
9, The defendant, although entering into this Agreement, does not admil the
allegations made in the Petition.
10, The defendant understands that the Protection Order entered in this matter will be
in effect for a period of one (I) year and can be extended beyond that time if the Court Iinds that
the defendant has committed an act of abuse or has engaged in a pattern or practice that indicates
risk of harm to the plaintiff. 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,
11. Violation of the Protection Order may subject the defendant to: i) arrest under 23
Pa.C.S. 96113; ii) a private criminal complaint under 23 Pa,C.S, 96113,1; iii) a charge of indirect
criminal contempt under 23 Pa,C.S, 96114. punishable by imprisonment up to six months and a
line of $100.00-$1.000.00; and iv) civil contempt under 23 Pa,C.S. 96114. I.
12, The defendant and the plaintil1' agree to the entry of an Order providing for the
lallowing custody schedule for their children, Kristen Marie Eldredge and Derrick Jay Eldredge.
a) The parties will share legal CUSIOlly ol'the children,
b) The mother will have primary physical custody or the children,
c) The f.1ther will have supervised visits with the children in the presence of a
mutually agreed upon third party on dates and at times mutually agrccd upon by
thc partics.
d) Thc Huher agrccs to undergo a drug and alcohol cvaluation, follow thc
rccommended treatmcnt, and continue in trcatmcnt until rcleased by his
counselor/therapist. Attorneys for the plaint ill' will have access to information
confirming the defcndant's attendance and succcssful completion of the treatment
program,
e) The f.1ther agrees that he will not usc illegal dntgs and/or alcohol
immediately prior to or during periods of custody with the childrcn,
I) The mother and lather agree that each will notify the other of all mcdical
carc the children rcceivc while in that parcnt's carc. Each parent will notifY the
other immediately of mcdical cmcrgcncics which arise while the children are in that
parent's care,
g) The parties realize that their childrcn's well being is paramount to any
differences they might have between thcmselves, Therefore. they agree that
neither party will do anything which may estrange the children from the other
parent, or injure the opinion of the childrcn as to the other parent or which may
hamper the free and natural dcvelopment of the children's love or respect for the
other parent.
WHEREFORE, the parties request that a Protection and Custody Order be cntered to
rencct the above terms,
eoo"QOJlLL \Y\a.W fj(dJ\c~t.
Charlene Marie Eldredge. Plaintiff ,.
LEGAL SERVICES. INC.
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
DISK, DVXXIIIA: PFA.DOC
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CHARLENE MARIE ELDREDGE.
Plilintitl'
: IN THE COURT OF COMMON PLEAS OF
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CUMBERLAND COUNTY. PENNSYLVANIA
Y.
NO, 98-201 CIVIL TERM
JUSTIN JAY ELDREDGE,
Defendant
PROTECTION FROM ABUSE AND CUSTODY
OUT-OF-POCKET LOSSES
The plaintiff requests that the defendant reimburse her out-of-pocket losses including. but
not limited to. the following:
Lost wages as iI result of the incident which occured on or i1bout December 27. 1997.
TOTAL AMOUNT $97.85
EXHIBIT A
SIlEHIFF'~; HETUrm
!.:EljULAfi
CASE no: 199a-O~201 r
COMMonWEALTH OF PEnnSYLVANIA:
COUNTY OF CUM8ERLAND
ELDREDGE CHARLENE MARIE
VS.
ELDREDGE JUSTIN JAY
BRIAN BARRICK , Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania. who being duly sworn according
to law. says, the within PROTECTION FROM ABUSE was served
upon ELDREDGE JUSTIN JAY
defendant, at IG37:~~ HOURS. on the 14th day of January
the
1998 at
211H 2ND STREET
SUMMERDALE. PA 17~93
. CUMBERLAND
County, Pe>nnsylvania. by handing to JUSTIN J. EDREDGE
a true and atte>ste>d copy of the PROTECTION FROM ABUSE
toge>the>r with TEMPORARY PROTECTION ORDER
and at the> same> time directing His attention to the contents thereof.
She>riff's Costs:
Docketing
Service>
Affidavit
Surcharge
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18.00
9.92
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$2';.';2
H.
Ihomas K11ne. bhe>r1%1
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by
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Sworn and subscribed to before me
this /:;"'!.:.. day of W~
19--.9J1'_ A, D.
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CHARLENE MARIE ELDREDGE.
Plaint ill'
IN TilE COURT OF COMI\10N PLEAS OF
CUMBERI.AND COUNTY, PENNSYLVANIA
v.
NO, 9H-__,::LDJ_ CIVIl. TERM
JUSTIN JAY ELDREDGE,
Defendant
PROTECTION FROM ABUSE AND CUSTODY
TEMPORARY PROTECTION ORDER
u (1.\
AND NOW, this ~ day of January, 1998. upon presentation and consideration of the
within Petition. and upon finding that the plaintil1: Charlcne Marie Eldredge, temporarily residing
at an undisclosed location to avoid fhrther abuse and lor her protection, is in immediate and
present danger of abuse from the delcndant, Justin Jay Eldredge, the following Temporary Order
is entered.
/,lI\I' 1!/!{orcl!lI/l!lII a~l!lIcil!s, /1111/1(1// SI!/'I'icl! a~l!lIcil!s all</ school dislricts shall //(/t disclosl!
thl! prl!sl!lIcl! (if thl! plailll!f{ lIlI<l or thl! childrl!lI ill thl! jllrisdic!ioll or district or .fllmish lIlIY
addrl!ss, tl!ll!pholll! IIl1l1/hl!r. or (1/(1' other dl!lI/o~raphic i/!{orll/atiall lIholll thl! plllillt!f{ lIlI</ or
childrl!lIl!xcl!pt hy.fllnhl!r Order (!{COII/'/.
The defendant, Justin Jay Eldredge (SSN: 528-53-0023)(0013: 7/08170), now residing at
201 2nd Street. SummerdaJe, Cumberland County, Pennsylvania, is hereby enjoined from
physically abusing the plaintil1: Charlene Marie Eldredge, or Irom placing her in fear of abuse.
The defendant is ordered to stay away Irom the plaintil1's current residence which is at an
undisclosed location for her protection, to which the plaintil1' and the minor children moved to
avoid abuse. which is not owned or leased by the defendant. and is ordered to stay away from any
residence the plaintiff may in the lhture establish lor herself
The defendant is ordered to refrain Irom having any direct or indirect contact with the
plaintilT including, but not limited to, telephone and written communications,
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The delendant is enjoined Irom harassing and stalking the plaintill. and Irom harassing her
rclatives, or the partics' minor ehildrcn,
The defendant is enjoined Irom entering the plaint ill's placc of employment or the day care
lacility oflhe parties' minor children,
The defendant is enjoined irom removing, damaging, destroying or selling any propcrty
owned jointly by the parties or owned by the plaintil1~
A violation of this Order may snbject the defendant to: i) arrest nnder 23 Pa.C.S.
~6113; ii) II private criminal complaint nnder 23 PlI.C.S. ~6113.1; iii) 1I charge of indirect
criminlll contempt nnder 23 Pa.C.S. ~6114, pnnishable by imprisonment np to six months
and 1I fine 01'$100.00-$1,000.00; and iv) civil contempt under 23 PlI.C.S. ~6114.1.
This Order shall remain in el1ect until modi!ied or terminated by the Court and can be
extended beyond its original expiration date if the Court !inds that the defendant has committed an
act of abuse or has engaged in a pattern or practice that indicates risk of harm to the plaintifl'.
Temporary custody of Kristin Marie Eldredge and Derrick Jay Eldredge, is hereby
awarded to the plaintifl Charlene Marie Eldredge.
AT
A HEARING SHALL BE HELD ON TillS MATTER ON .IANUARY
A.' .
.ull
,;1/ , 1998.
.,
O.M., IN COURTROOM NO. .::2....-, OF
,
COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA.
THE
CUMBERLAND
The plaintiff may proceed without pre-payment of fees pending a lurther order after the
hearing,
The Cumberland County Sheril1's Department shall attempt to make service at the
plaint ill's request and without pre-payment of Ices, but service may be accomplished under any
applicable rule of Civil Procedure,
This Ordcr shall be docketed in thc ollice of the Prothonotary and forwarded to the Sherilr
for service, The Prothonotary shall not send a copy of this Order to the defendant by mail.
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CIIAIU.ENE MARIE ELDREDGE,
Plaintit1.
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
v.
CIVIL TERM
NO, 98- .;Jc 1
JUSTIN JAY ELDREDGE,
Defendant
PROTECTION FROM ABUSE AND CUSTODY
PETITION FOR PROTECTION ORDER
AND CUSTODY
RELIEF UNDER THE PROTECTION FROM ABUSE ACT
23 Pa.C.S. ~6101 el seq.
A, ABUSE
I. The plaintil1: Charlene Marie Eldredge, is an adult individual temporarily staying at
an undisclosed location for her own protection and to avoid fUl1her abuse as is more fully set forth
herein, This address will be furnished to the court upon request.
2. The defendant, Justin Jay Eldredge, (SSN: 528-53-0023)(008: 7/08170), is an
adult individual residing at 20 I 2nd Street, Summerdale. Cumberland County, Pennsylvania
17093,
3, The defendant is the husband of the plaintiff. and the father of the parties' two
minor children, Kristen Marie Eldredge and Derrick Jay Eldredge.
4. Since approximately 1996. the defendant has attempted to cause and has
intentionally, knowingly, or recklessly caused bodily injury to the plaintiff. placed her in
reasonable fear of imminent serious bodily injury, and has knowingly engaged in a course of
conduct or repeatedly committed acts toward her under circumstances which have placed her in
reasonable fear of bodily injury. This has included. but is not limited to, the following specific
instances of abuse:
a) On or about December 27. I <)97. the delcndanl. who was holding the
parties' 4 month-old baby. Derrick. grabbed the plaintill' by the hair and
shoved her by her head through the living room and the kitchen, causing
her head to hit the wall, When the delcndant shoved her out the back door
toward her car, the plaintill' pulled away Irom him as he let go of her hair,
but when she trieClto run Irom him, he yelled, "Don'tmake me chase you
while I'm holding the baby." Fearing for the salety of the baby, the plaintiff
returned to the house,
b) On or about November 16. 1997, the delendant threatened to punch the
plaintill'in the back.
c) In or about June I <)96, the defendant punched the plaintill' about her body
repeatedly, The plaintill'sustained bruising and soreness about her body as
a result of this incident.
d) In or about June 1996, the defendant threw a knife block with knives in it
at the plaintill: causing her to have to move to avoid being struck. The
knife block was thrown with such force that one of the knives Ilew out of
the block and struck and punctured a quart of motor oil.
e) Since approximately 1996, the delendant has abused the plaintiff in ways
including, but not limited to, shoving her about, intimidating her by backing
her against walls and standing in close proximity to her while screaming at
her, poking her in the forehead and shoulders with his fingers, and
threatening to stab her with a fork, to knock her out. and to smack her.
5, On or about January 6, 1998, the plaintitT and the two minor children lell their
residence at 20 I 2nd Street, Summerdale, Cumberland County. Pennsylvania, in order to avoid
further abuse.
6 The plaintilr believes and therelbre avers that she is in immediate and present
danger of abuse Irom the delcndant and that she is in need of protect ion I rom such abuse,
7. The plaintill'desires that the defendant be prohibited Irom having any direct or
indirect contact with the plaintill' including, but not limited to, telephone and written
communications,
8, The plaintin'desires that the defendant be enjoined Irom harassing and stalking the
plaintiff, and from harassing her relatives, or the minor children,
9. The plaintill' desires that the defendant be restrained from entering her place of
employment or the day care lacility of the minor children.
10, The plaintilT desires that the defendant be enjoined Irom removing, damaging.
destroying or selling any property owned jointly by the parties or owned by the plaintiff.
n. EXCLLJSIVE POSSESSION
II. The residence from which the plaintilr is asking the Court to order the defendant to
stay away from must be kept confidential for her protection, The plaintilr is not seeking the
eviction of the defendant from his residence, The plaintilT asks that the Court order the defendant
to stay away Irom any other residence she may establish lor herself in the future.
12. Tthe plaintilT desires the defendant to provide suitable alternate housing for her
and the minor children.
13,
children,
C. SLJPPORT
The defendant has a duty to support the plaintill' and the parties' two minor
The children were nol born out of wedlock,
The children are prescntly in the custody of the plainlill: who is temporarily residing at an
undisclosed location to avoid thrther abuse and for her protection,
Since their births the children have resided with the following persons and at the tollowing
addresses:
~
Plaintitl'
Address
undisclosed location
Dates
January 6, 1998
to the present
Plaintifi' and defendant
20 t 2nd Street
Summerdale, P A
June 1996
to January 6, 1998
Plaintitl: defendant, plaintifi's
mother and step-nllher, Sandy and
Rick Scrignoli
201 Wayne Avenue
Summerdale, PA
March 1996
to June 1996
PlaintilT and defendant
1500 South Golden St., Lot 48
Springfield, MO
August 8, 1994
to March 1996
The plaintiff, the mother of the children, Charlene Marie Eldredge, is temporarily residing
at an undisclosed location to avoid further abuse and for her protection,
She is married,
The plaintilT currently resides with the parties' children, Kristen Marie Eldredge and
Derrick Jay Eldredge at an undisclosed location for the plaintilrs protection,
The defendant, the f.1ther of the children, Justin Jay Eldredge, currently resides at 20 I 2nd
Street, Summerdale, Cumberland County, Pennsylvania.
He is married.
The defendant currently residesalone.
21. The plaintill' has not previously participated in any litigation concerning custody of
the above mentioned children in this or any other Court,
22. The plailllill' has no knowledge or any custody proceedings concerning these
children pending belore a court in this or any other jurisdiction.
23. The plaintilr does not know or any person not a party to this action who has
physical custody or the children or claims to have custody or visitation rights with respect to the
children.
24. The best interests and permanent we\lhre or the minor children will be met if
custody is temporarily granted to the plaintilr pending a hearing in this matter for reasons
including:
a. The plaintil1' has provided for the emotional and physical
needs of the children since their births, and she is a responsible
parent who can best take care of the minor children.
b. The defendant has shown by his abuse of the plaintiff that he
is not an appropriate role model lor the minor children.
c. The defendant's behavior has adversely affected the parties'
three-year old daughter, Kristen.
WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of October
7, 1976,23 P.S. ~6101 et seg., as amended, the plaintill'prays this Honorable Court to grant the
following relief:
A. Grant a Temporary Order pursuant to the "Protection from Abuse
Act:"
I. Ordering the defendant to relrain from abusing the plaintill' or from
placing her in rear or abuse.
2. Ordering the defendant to relrain Irom having any direct or indirect
contact with the plaintilr including, but not limited to, telephone and
written communications.
3. Ordering the derendant to retrain Irom harassing and stalking the
plaintilrand Irom harassing her relatives and the minor children.
4. Prohibiting the derendant Irom entering the plaintill's place or
employment or Ihe day care Ihcility of the minor children.
S. Prohibiting the derendant trom removing, damaging, destroying or
selling propcrty jointly owncd by the partics or owned by thc plaintiff.
6. Ordering thc defcndant to slay away Irom the plaintill's currcnt
rcsidencc which is at an undiscloscd location lor her protcction, and from
any rcsidcncc thc plaintill'may in thc ruture establish for herself.
7. Granting tcmporary custody or the minor childrcn, Kristcn Marie
Eldredgc and Derrick Jay Eldrcdge, to the plaintilT.
B. Schedule II hearing in accordance with the provisions of the
"Protection from Abuse Act," and, after snch heariug, enter an order to be in elTect for a
period of one yellr:
I. Ordering thc dclcndant to rclrain from abusing thc plaintiff or from
placing her in fear of abuse.
2. Ordering the defendant to rcfrain from having any direct or indirect
contact with the plaintill' including, but not limited to, telephone and
written communications, except for thc limitcd purpose of Ihcilitating
custodyarrangcments.
3. Ordcring the defendant to rcfrain from harassing and stalking the
plaintill' and from harassing hcr relatives and the minor children.
4. Prohibiting thc dcfcndanl Irom cntcring thc plaintitl's place of
cmploymcnt or the day care f.1cility ofthe minor childrcn.
5. Prohibiting the derendant from removing, damaging, destroying or
selling property jointly owned by the parties or owned by the plainlif1~
6. Ordering the delcndal1l to stay away from the plaintill's current
rcsidcnce which is al an undiscloscd location ror hcr protcclion, and
ordering the delcndanlto stay away Iromany rcsidence thc plaintilr may in
thc tllturc cstablish tor hcrsclf.
7. Ordcring thc delcndant to provide suitable alternate housing lor the
plllintill'and the minor children.
8. Granting support to thc plaintill' and thc minor children in the
amount or $75.00 pcr wcek payable to the plaintiff in thc form of a check
or money ordcr, mailed to her mailing addrcss; ordcring the defendant to
continue to providc hcalth coverage to thc plaintill' and the parties' minor
children; and ordcring the defendant to pay all of the unreimbursed medical
cxpenscs or the plainlif1' and/or the parties' minor children to the providcr
or to thc plaintill' when she has paid for thc medical treatment.
9. Ordcring the dcfendant to reimburse thc plaintill's out-of-pocket
losses sullercd as a result of the incident which occured on or about
Deccmber 27, 1997, including, but not limitcd to, the losscs listed on thc
attached sheet marked Exhibit A.
i,
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.
I
10. Ordcring the defcndant to pay $250.00 to Cumberland County, one
of Legal Scrvices, Inc.'s funding sources as rcimburscmcnt for the cost of
litigating this case, and assessing thc $25.00 surchargc and court costs to
thc dcfendant ir the case goes to hcaring.
Thc plaintilrtl1rther asks that this Pctition bc filed and servcd without paymcnt offccs and
costs by thc plaintill: pending a lurthcr order at thc hearing, and that a certificd copy of this
,
f~
I
,
Pctition and Order be dclivered to thc East Pennsboro Township Police Department which has
jurisdiction to enforcc this Order.
The plaintill' prays lor such other relier as may bc just and propcr.
COUNT II
CUSTODY UNDER PENNSYLVANIA CUSTODY LAW
25. Thc allegations of Count I abovc arc incorporatcd hcrein as if fully sct forth.
26. The best intcrest and pcrmanent welfare or the minor children will be served by
confirming custody in thc plaintill' as sct forth in Paragraph 24 or the Petition.
WHEREFORE, pursuant to 23 P.S. ~ 5301 et scg., and other applicable rulcs and law, the
plaintiff prays this Honorable Court to award custody orthc minor children to her.
The plaintill' prays for such othcr rclicr as may bc just and propcr.
Respectfully submitted,
~u&, (L~
Joan Carey
Philip C. Briganti
Attorneys for Plaintill'
<
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
DISK: DVXXIIIA: ELDREDGE. DOC
Thc abovc-nllmed plaintill: Charlene Marie Eldredge, vcrifies that the statcmcnts made in
the abovc Pctition arc truc and corrcct. Thc plaintilr undcrstands that fhlsc statcmcnts hcrcin arc
madc subject to the pcnaltics of 18 Pa.C.S. ~4904 rclating to unsworn f.1lsification to authoritics.
Date:_\ - \ '6-, -qo,
~ -(V\Qrllc rQdJltO~
Charlcnc Maric Eldredgc, Plaintil1'
II
CHARLENE MARIE ELDREDGE,
Plainlif1'
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
,
,
,
v.
NO. 98-
CIVIL TERM
JUSTIN JAY ELDREDGE,
Defendant
PROTECTION FROM ABUSE AND CUSTODY
OUT-OF-POCKET LOSSES
The plaint ill' requests that the defcndant reimburse her out-of-pocket losses including, but
not limited to, the following:
Lost wages as a rcsult of the incidcnt which occurcd on or about Dccember 27, 1997.
TOTAL AMOUNT $97.85
I
EXHIBIT A
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