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purposc of fllci I i till ing cllstody 1I1'l'lIngcmcnts,
Thc dcfcndunl is cnjoincd from horusslng und slulking the
plllintiff ond from hurussing thc plointiff's rclutivcs,
The dcfcndont is cnjoincd from cntcring thc pluintiff's
plocc of employmcnt,
Thc dcfcndont is cnjoincd from domoging 01' dcstroying uny
property owncd jointly by thc porties 01' owned solely by the
plainliff.
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 Pu.C.S, ~6113,1; iii) a charge of indirect criminul
contempt under 23 Pu.C,S. ~6114, punishuble by imprisonment up to
six months and a fine of $100.00-$1,000.00; and iv) civil
contempt under 23 Pa.C.S. ~6114.1. Resumption of co-residence on
the part of the plaintiff und defendunt shall not nullify the
provisions of the court order.
This Order sholl remoin in effect until modified or
terminated by the Court and cun be extended beyond its original
expiration date if the Court finds that the defendant has
committed unother act of abuse or has engaged in u pattern or
practice that indicates continued risk of harm to the plaintiff,
Temporary custody of David W, Geiger (DOB 12/18/80), Ryan K.
Keeseman (DOB 11/3/83), and Alecia L. Keescman (DOll 9/1/87), is
hereby awarded to the pluintiff, Valeric A. Kcescmon,
A hearing shall be held on this matter on thc ~<6t day of
'T-et.AU,((..'Lr,
1998, at
3:l/')
;2,m,. in Courtroom No.-I_.
Cumbcrland Counly Courthou8c, Cnrl Isle, Pennsylvania,
Thc pllllnt i ff mllY pl'oeecd wi thout pre-pllyment of fees
pcnding II furthcr order nftel' thc hcnring,
The Cumberlnnd County Shcriff's Department shnl I attempt to
make scrviee nt the plaintiff's request IInd without pre-pllyment
of fees, but service mllY be accompl ished under any IIpplicable
rule of Civil Procedure,
This Order shal I 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 mai I,
The Pennsylvania State and Carlisle 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 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. ~
6113) ,
Vnlerie A, Keesemnn,
Plaintiff
IN TilE COURT 01' COMMON PLEAS 01'
v,
CUMBERLAND COUNTY, PENNSYLVANIA
NO, 98-..r~ CIVIL TERM
Bryan K, Keesemnn,
Defendant
PROTECTION I'ROM ABUSE
AND CUSTODY
NOTICE
You hnve been sued in court, If you wish to defend against the
claims set forth in the 1'01 lowing pages, you must take action promptly
after this Petition, Order und Nolice arc served, by appearing
personally or by attorney at the henring scheduled by the Court and
presenting to the Court your defenses or objections to the claims set
forth against you, You are warned that if you fai I to do so the Court
may proceed without you, and a judgment may be entered against you by
the Court without further notice for any money claimed in the Petition
or for any other claim or rei ief requested by the plaintiff, You may
lose money or property or other rights important to you, Any
Protection Order granted by a Court may be considered in any
subsequent domestic relations proceedings, including custody actions.
FEES AND COSTS
If the case goes to hearing and the judge grants a Protection
Order, a surcharge of $25,00 will be assessed ngainst you, You may
also be required to pay up to $250,00 to reimburse one of Legal
Services, Inc, 's funding sources for Legnl Services Inc,'s
representation of the plaintiff.
You have the right to be represented by counsel. 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.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (71 i) 249-3166 0 r TOLL FREE: 1-800-990-9108
FAX: (717)249-2663
AMERICANS WITII DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law
to comply with the Americans with Disabilities Act of 1990. For
information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court,
please contact our office, All arrangements must be made at least 72
hours prior to any hearing or business before the court, You must
attend the scheduled conference or hearing,
a, On or about Januury 20, IlJ'lS, the defendnnt becume
ungry, grubbed the pluintiff's throut, choked her so
thut she could not breathe, und threatened her saying
that if he could not have her, no one could, and
repeut ing that he wou Id ki II her. As the defendant
left the residence, he pointed his finger at the
plaintiff and threatened that she bettcr always watch
her back and not let her guard down, He agnin
threatened to kill her.
b, On or ubout Jnnuury 14, 1998, the defendant bit
the plaintiff's fingers, pushed her into a truck
causing her to fall Rnd bruise her leg, shoved her into
the bathroom door, slnmmed the door into her, grabbed
her by the shoulders, restrained her in the corner of
the bathroom refusing 10 allow her to leave the room,
and shoved her causing her to fnll onto the toi let and
injure her bnck, The defendant slapped the plaintiff
several times on the face cnusing bruises, grabbed her
by the shoulders, hit her ncross the back with his
forearm, hit her in the nose, and hit her on the
shoulder blades.
c, In or about the fall of 1987, the defendant became
angry, shoved the plaintiff, and threw her several feet
in the air causing her to full onto the coffee table,
d, [n or about the summer of 1982, the defendant
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became angry nnd hit the plainti ff on the side of her
face injuring her jnw which caused pain, bruising, and
swelling and resulted in her not being nble to eat
solid food or speak clearly for severnl weeks,
e, On several occasions since 1980, the defendant has
shoved, restrained, slapped, choked, and punched the
plaintiff causing bruises on her legs, hands, and face,
The defendant has threatened to ki II the plaintiff,
slammed doors, punched walls, and overturned furniture
causing her to fear for her safety,
5, On or about January 20,1998, the plaintiff and the
three minor children left their residence at 310 Shady Road,
Newburg, Cumberland County, Pennsylvania, in order to avoid
further abuse,
6. The plaintiff bel ieves and therefore avers that she is
in immediate and present dnnger of abuse from the defendnnt nnd
that she is in need of protection from such nbuse.
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 pia inti ff, and from harassing the
plaintiff's relatives,
3
9, The plllintlrr desires thllt the defendllnt he restrllined
from entering her plnce of employment,
10, The defendllnt is enjoined from damllging or destroying
any properly owned jointly by the parties 01' owned solely by the
plaintiff,
B. EXCLUSIVE POSSESSION
11, The home which the plaintiff is asking the Court to
order the defendanl to stay nway from is not owned 01' rented in
the defendant's name,
12, The defendant has his own residence located at 310
Shady Road, Newburg, Pennsylvania,
C. REIMBURSEMENT FOR COST OF CASE
13, The plaintiff asks that the defendant be ordered to pay
$250,00 to reimburse one of Legal Services, Inc, 's fnnding
sources for the cost of litigating this case.
D, TEMPORARY CUSTODY
14, The plaintiff seeks temporary custody of the following
children:
Name
David W, Geiger
Present Residence
235 Bobcat Rand
Carl isle, PA
235 Bobcat Road
Cn l' lis Ie, PA
235 Robcat Road
Cn r lis Ie, PA
A/(e
17
DOR 12/18/80
14
DOB 11/3/83
10
DOB 9/1/87
Ryan K, Keeseman
Alecia L. Keeseman
The Dnvid W. Geiger nnd Rynn K, Keeseman were born out of
wedlock and Alecin L. Keesemnn was not born out of wedlock,
The chi Idren are presently in the custody of the plaintiff,
4
Pennsylvnnia,
Vnlerie A, Keeseman, who resides 01 235 Rohcnt Rond, Carlisle,
During the past five yenrs, the children hove resided with
the fol lowing persons and at the fol lowing addresses:
Name
Plaintiff and
Sonya Oliveri
(plaintiff's mother)
Plaintiff nnd
Defendant
Plaintiff and
Defendant
Plaintiff and
Defendant
Plaintiff and
Defendant
Plaintiff and
Defendant
Addresses DateR
235 Bohcat Road 1/20/98 to
Car 1 is Ie, PA Present
310 Shady Road 3/97 to
Newburg, PA 1/20/98
Old Mi II Road 3/96 to
Newv i I Ie, PA 3/97
239 Bobcat Road 10/95 to
Carlisle, PA 3/96
Newburg, PA winter of 1993
to 10/95
239 Bobcat Road 1989 to
Ca I' lis Ie, PA winter of 1993
The plaintiff, the mother of the children, currently resides
She is married.
at 235 Bobcat Road, Carlisle, Cumberland County, Pennsylvania,
The plaintiff currently resides with the following persons:
Name
David W. Geiger
Ryan K, Keeseman
Alecia L, Keesemnn
Sonya Oliveri
Relationship
Son
Son
Daughter
Mother
The defendant I the father of the chi Idren, current Iy resides
He is married,
at 310 Shady Road, Newburg, Cumberland County, Pennsylvania,
5
The dcfendant currently resides alonc,
15, The plaintiff has not previously participated in any
I itigation concerning custody of the above mentioned chi ldrcn in
this or any other Court,
16, The plaintiff has no knowledge of any custody
proceedings concerning these children pending before a court in
this or any other jurisdiction,
17, The plaintiff docs not know of any person not a party
to this action who has physical custody of the chi Idren or claims
to have custody or visitation rights with respect to the
chi ldren,
18. The best interests and permanent welfare of the minor
children will be met if custody is temporarily granted to the
plaintiff pending a hearing in this matter for reasons including:
a. The plaintiff is a responsible parent who can best
take care of the minor children and has provided for
the emotional and physical needs of the children since
their birth.
b, The defendant has shown by his abuse of the
plainti ff that he is not an appropriate role model for
the minor children,
WHEREFORE, pursuant to the provisions of the "Protection
from Abuse Act" of October 7, 1976, 23 Pa.C.S. g 6101 tl~" as
amended, the plaintiff prays this Honorable Court to grant the
fol lowing reI ief:
6
A, Grant a Temporary Order pursuant to the
"Protection from Abuse Act:"
I, 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 limited to, telephone and
written communications, except to facilitate
custody arrangements,
3, Ordering 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.
5. Prohibiting the defendant from damaging or
destroying any property owned jointly by the
parties or owned solely by the plaintiff,
6, Ordering the defendant to stay away from the
plaintiff's residence located at 235 Bobcat Road,
Carlisle, Cumberland County, Pennsylvania, and any
other residence the plaintiff may establish,
except for the I imited purpose of transferring
custody of the parties' chi Idren. The defendant
shal I remain in his vehicle at al I times during
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the trnnsfer of custody,
7, Grnnting tempnrnry custody of the minor
children to the plnlntiff,
B, Schednle n henrlng in nccordnnce wilh lhe provisions of
the "Protection from Abuse Act," nnd, nfter such henring, enter
an order to be in effect for n period of one ycnr:
I, Ordering the defendnnt 10 refrnin from
nbusing the plninliff or from placing her in fenr
of nbuse,
2, Ordering lhe defendnnt to refrnin from hnving
nny direct or indirect contnct with the plnintiff
including, but not limited 10, telephone nnd
written communicntions, except to fncilitate
custody nrrnngements,
3, Ordering the defendant to refrain from
harassing and stalking lhe plaintiff and from
harassing the plaintiff's relntives,
4, Prohibiting the defendnnt from entering the
plaintiff's plnce of employment,
5. Prohibiting lhe defendant from dnmnging or
destroying any property owned jointly by the
parties or owned solely by the plaintiff,
6, Ordering the defendant to stay away from the
plaintiff's residence located at 235 nobcat Road,
Cnrl isle, Cumberland County, Pennsylvania, and any
8
other residence thc pluintiff may cstabl ish,
except for the I imitcd purpose of tl'unsfel'ring
custody of Ihe purties' children, The defendnnt
shall remain in his vehicle nt nil timcs during
the trnnsfer of custody,
7, Ordering the c1efendnnt to pny $250.00 to
reimburse one of Legnl Services, Inc, 's funding
sources for the cost of litlgnting this cnse,
The plaintiff further nsks Ihnt this Petition be fi led nnd
served without puymcnt of fees nnd costs by the plaintiff,
pending u furlher order at the hearing, and thnt a certified
copies of this Petition Rnd Order be delivered to the
Pennsylvania State and Carlisle Police Departments which have
jurisdiction to enforce this Order,
The plaintiff prays for such other relief as may be just and
propel',
COUNT II
CUSTODY UNDER PENNSYLVANIA CUSTODY LAW
19, The allegations of Count I above are Incorporated
herein as if fUlly set forth.
20, The best interest and permanent welfare of the minor
children will be served by confirming custody in the plaintiff as
set forth in paragraph 18 of the petition,
WHEREFORE, pursuant to 23 Pa,C,S, !l 5301 tl seq" and other
applicable rules and law, the plaintiff prays this Honorable
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6. The defendunt is ordered to stuy UWIlY from the
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plaintiff's residence locnted lit 235 Bobcat Rond, Cllrl isle,
Cumberlllnd County, pennsylvllnia, und Ilny other residence the
plllint i ff may estnbl ish, except for the I imi ted purpose of
transferring custody during which limes Ihe defendant shal I
,
remain in his vehicle.
7. The court costs IInd fees ure waived.
8 .
,
This Order sholl remllin in effect for 0 period of one
yellr or until modified or terminated by the Court. The Order can
be extended beyond its original expiration dote if the Court
finds that the defendant has co~nitted another act of abuse or
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has engaged in a pattern or practice that indicates continued
risk of harm to the plllintiff.
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9. A viollltion of this Order may SUbject the defendant to:
i) arrest under 23 Pa.C.S. Y6113; ii) 0 private criminal
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complaint under 23 Pa.C.S. Y6113.l; iii) a charge of indirect
criminal contempt under 23 Pa.C.S. Y6114, punishable by
imprisonment up to six months IInd a fine of $100.00-$1,000.00;
and iv) civi I contempt under 23 PIl.C.S. Y6114.1. Resumption of
co-residence on the part of the plaintiff and defendllnt shall not
nullify the provisions of the court order.
10. The Pennsylvania State and Carl isle Police Departments
sholl be provided with certified copies of this Order by the
plaintiff's attorney and may enforce this Order by arrest for
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indirect criminal contempt without warrant upon probable cause
Valerie A. Keeseman,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
NO. 98-525 CIVIL TERM
CUMBERLAND COUNTY, PENNSYLVANIA
v.
Bryan K. Keeseman,
Defendnnt
PROTECTION FROM ABUSE
AND CUSTODY
CUSTODY ORDER
AND NOW, this ~ dny of February, 1998, upon
consideration of the parties' Consent Agreement, the following
Order is entered with regard to custody of the parties' children,
David W. Geiger (DOB 12/18/80), Ryan K. Keesemnn (DOB 11/3/83),
and Alecia L. Keeseman (DOB 9/1/87).
1. The plaintiff, hereinafter referred to as the
mother, shal I have primary physical and legal custody of the
children.
2. The defendant, hereinafter referred to as the
father, shall have partial custody of the children at times
agreed upon by the mother and father.
3. The mother and fnther agree that each shal I notify
the other immediately of medical emergencies which arise while
the children are in that parent's care.
4. Neither pnrty 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 nntural development of the children's love or respect
""'~\-o~ Of\O-u\..
6. The defendant agrees to stay away from the plaintiff's
residence 10caLed at 235 Bobcat Road, Carl isle, Cumberland
County, Pennsylvania, and any other residence the plaintiff may
establ ish, except for the I imi ted purpose of transferring
custody. The defendant shall remain in his vehicle nt all times
during the trnnsfer of cusLody.
7. The defendant, although entering into this Agreement,
does not admit the al legations mnde in the Petition.
8. The defendant understands Lhat the Protection Order
entered in this mntter wil I be in effect for a period of one year
and can be extended beyond it original expiration date if the
Court finds that the defendant has committed nnother act of abuse
or has engaged in a pattern or practice that indicates continued
risk of hnrm to the plnintiff. The defendant undersLands that
this Order will be enforceable in the same manner as the Court's
prior Temporary Protection Order entered in this case.
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,
9. Violation of the Protection Order nmy subject the
defendnnt Lo: i) arrest under 23 Pa.C.S. ~6113; i i) a private
criminal complaint under 23 Pa.C.S. ~6113.1; iii) a charge of
indirect criminal contempt under 23 Pn.C.S. ~6114, punishable by
imprisonment up to six months und a fine of $100.00-$1,000.00;
and iv) civil contempt under 23 Pa.C.S. ~6114.1.
10. The defendant nnd Lhe plaintiff agree to the entry of
an Order prOViding for the fol lowing regarding custody of their
children, David W. Geiger (DOB 12/18/80), Ryan K. Keeseman
i
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