HomeMy WebLinkAbout98-00532
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The defendanl is enjoined from hara.'l.qing and stalking 'he plaintiff and from harassing the
plaintiffs relativcs, or the minor children.
The defendant is eqjoined from en.ering 'he plaintill's place of employmen' and the
children's schools,
The defendant is eqjoined from damaging or dcstroying any property ownedjoinlly 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.
fi6113; II) a private criminal cOlllp1alnt under 23 Pa.C,S, {i6113,lj III) a cha"8e of Indirect
criminal contempt under 23 Pa.C,S. !l6114. punishable by Imprisonment up to six months
and a One ofSl00.00-51,OOO,OO; and Iv) civil contempt under 23 Pa.C,S, !l6114, 1.
Resumption of co-residence on the part ofthe plalntilT and defendant shall not nulllly 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 ab1l8e or has engaged in a panem or practice that indicates continued risk ofhamt to
the plaintiff.
A hearing shall be held on this matter on the It f ~ day of .i,~ It 1/((11 ,V
, 1998, at I " 50 I~ ,m,. in Courtroom No,L, Cumberland County CourthoWle, Carlisle,
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Pennsylvania.
The plaintiff may proceed without prc-paym~"I1t of fccs pending further order of court.
The Cumberland County Sheri/fs Department shall attempt to make service at the
plainlilI's request and without pre-payment of fces, but service may be accomplished under any
applieable rule of Civil Procedure,
This Order shall be dockcted in the office of the Prothonotary and forwarded to thc Sheriff
for service, The Prothonotal)' shall not send a copy of thi.. Order to the defendant by mail.
The Hampden Township and Camp Hill Police Departments will be provided with certified
copies of this Order by the plainlilI'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 unnecessal)' 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),
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By the Court,', I
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Patricia Ann Crawford,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
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: CUMBERLAND COUNTY, PENNSYLVANIA
; NO, 98- S 3d. CIVIL TERM
David A. Crawford,
Defendant
: PROTECTION FROM ABUSE
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the following pages,
you must take action promptly after this Petition, Order and Notice are served, by appearing persona11y or
by attorney at the hearing 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 fail 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 relief requested by the plaintiff. You may lose
money or property or other right!! important to you, Any Protection Order granted by a Court may be
cORllidered In any subsequent domestic relations proceedings, Including custody actions,
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FEES AND COSTS
If the case goes to hearing and the judge grants a Protection Order, a surcharge of$25.00 will be
assessed against you, You may also be required to pay up to $250,00 to reimburse one of Legal SCIVices,
Inc, 's funding sources for Legal Services, Inc.' s representation of the plaintiff.
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You have the right to be represented by counsel, V ou 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: (717) 249-3166
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AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cwnberland County is required by law to comply with thc Amcrican,
with Disabilities Act of 1990. For infonnation about accessible facilitics and reasonablc accommOllallllns
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, V 011 mlllll
attend the scheduled conference or hearing.
a, On or about December 26, 1997, the defendant threatened
to kill the plaintiff causing her to fear for her safety,
b. In or about Novembcr 1997, while holding a knifc in a
threatening manner, the defendant threatened the plaintiff saying,
"One of these days I'm going to kill you," causing the plaintiff to
fear for her safety.
c, On several occasions between November 1997, and January
27, 1998, the defendant repeatedly, at times three times a day,
harassed the plaintiffby phone exacerbating her fear,
d. In or about October 1997, the defendant became angIy and
sprayed Windex twice into the plaintiff's eyescausing her pain,
e, On several different occasions since 1980, the defendant has
shoved, restrained, slapped, and threatened the plaintiff, On one
occasion when the plaintiff was pregoant, the defendant picked her
up and threatened to throw her down a set of stairs causing her to
fear for her safety and the safety of her unborn child. The
defendant has punched a hole in a wall, thrown food, and thrown
and broken a bar stool causing the plaintiff to fear for her safety,
5, The p1aintiffbelic:ves and therefore avers that she is in immediate and present
danger of abuse from the defendant should she remain in the home without the defendanl's
exclusion and that she is in need of protection from such abuse,
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6, The plaintiff desires that the defendant be prohibited from having any direct or
indirect contact with thc plaintiff including, but not limited to, telcphone and written
communications, except for the limited purposc of facilitating custody arrangements.
7, The plaintiff desires that the defendant be cnjoined from harassing and stalking the
plaintiff, and from harassing the plaintift's relatives, or the minor children,
8, The plaintiff desires that the defendant be restrained from entering her place of
employment and the children's schools.
9, The plaintiff desires that the defendant be enjoined from damaging or destroying
any property owned jointly by the parties or owned solely by the plaintiff.
B, EXCLUSIVE POSSESSION
10, The home from which the plaintiff is asking the Court to exclude thc defcndant is
owned in the names of the plaintiff and the defendant.
11. The defendant has recently voluntarily moved out of the marital residence and
moved into his parents' residence which is located at 2432 Brookwood Street, Hanisburg,
Pennsylvania.
12. The plaintiff currently has no place to stay with her children except the marital
home, and the defendant is currently living with his parents.
13, The plaintiff desires possession of the home so as to give the greatest degree of
continuity to the lives of the children and to allow them to continue their education at their schools
and to continue their school and social activities.
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C, REIMBURSEMENT FOR COST OF CASE
14, The plainliB' asks that the defendant be ordered to pay $250,00 to rcimburse one of
Legal Serviccs, Inc.'s funding sources for the cost of litigating this case,
WHEREFORE, pursuant to thc provisions of the "Protcction from Abusc Act" of October
7, 1976,23 Pa,C,S, ~ 6101 et seg., as amended, the p1ainliB'prays this Honorable Court to grant
the foUowing relief:
A. Grant a Temporary Order pursuant to the "Protection from Abuse Act:"
1. Ordering the defendant to refrain from abusing the
plainliB' or placing them in fear of abuse,
2. Ordering the defendant to refrain from having any
direct or indirect contact with the plainliB'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 p1ainliB' and from harassing the plaintifl's relatives and
the minor children.
4, Prohibiting the defendant from entering the plaintifl's
place of employment and the children's schools,
5. Prohibiting thc defendant from damaging or
destroying property jointly owned by the parties or owned solely by
the plaintiff.
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6, Granting possession of the home located at 12
Musket Lane, Mechanicsburg, Cumberland County, Pennsylvania,
to the plaintiff to the exchL~ion of the defendant pending a final
order in this matter, except for the limited purpose of transferring
custody of the parties' children, The defendant shaD remain in his
vehicle at all times during the transfer of custody,
7, Ordering the defendant to stay away from the any
other residence the plaintiff may establish except for the limited
pwpose of transfenlng custody of the parties' children. The
defendant shall remain in his vehicle at all times during the transfer
of custody,
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:
1. Ordering the defendant to refrain from abusing the
plaintiff or placing her in fear of abuse.
2. Ordering the defendant to refrain from having any
direct or indirect contact with the plaintiff ine1uding, but not limited
to, telephone and written communications, except to facilitate
custody arrangements.
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3, Ordering the defc:ndanlto refrain from harassing and
stalking the plaintiff and from hllra.'lSing the p1aintil1's relativcs and
the minor ehildren.
4, Prohibiting the defendant from entering the plaintift's
place of employment and the ehildren's sehools.
5, Prohibiting the defendant from damaging or
destroying property jointly owned by the parties or owned solely by
the plaintiff.
6, Granting possession of the home located at 1200
Musket Lane, Mechanicsburg, Cumberland County, Pennsylvania,
to the plaintiff to the exe1usion of the defendant, except for the
limited pwpose of transfening custody of the parties' children. The
defendant shall remain in his vehicle at all times during the transfer
of custody.
7. Ordering the defendant to stay away any other
residence the plaintiff may establish, except for the limited pwpose
of transferring custody of the parties' children, The defendant shall
remain in his vchic1e at all times during the transfer of custody,
8, Ordering the defendant to pay $250,00 to reimburse
one of Legal Services, loco's funding sources for the cost of litigating
this case,
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YOU SHOULD TAKE TI11S PAPER TO VOUR LAWVER AT ONCE, IF VOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
CUMBERLAND COUNTV BAR ASSOCIATION
2 Liberty Avenue
Carlisle, PA 17013
(717) 249-3166
,
PATRICIA A. CRAWF'ORD,
Plaintiff
: IN TilE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. 98-0671 CIVIL TERM
DAVID A. CRAWFORD,
Defendant
CIVIL ACTION - LAW
CHILD CUSTODV
PETITION FOR MODIFICATION OF CUSTODY
AND NOW, comes Defendant, David A. Crawford, by and through his attorney, Kathleen
Carey Daley, Esquire, and avcrs the following:
1. Plaintiff, Patricia A. Crawford, is the natural mother of Ryan A. Crawford, born
November 10, 1984, Kyle S. Crawford, born August 19, 1988, and Eric D. Crawford, born May
9, 1991, and resides at 1200 Musket Lane, Mechanicsburg, Cumberland County, Pennsylvania,
2. Defendant, David A. Crawford, is thc natural father of Ryan A. Crawford, born
November 10, 1984, Kyle S. Crawford, born August 19, 1988, and Eric D. Crawford, born May
9,1991, and resides at 121 Beacon Drive, Harrisburg, Dauphin County, Pennsylvania.
3, On April 14, 1998, a custody conciliation conference was held before Custody
Conciliator Dawn S, Sunday, Esquire.
4, Pursuant to an agreement entered into between the parties at the custody
conference, the parties agreed that they would share legal custody of their three minor children;
Plaintiff would exercise primary physical custody over the parties' three minor children, and
Defendant would cxcrcise periods of partial physical custody ovcr the parties' three minor
children.
5, This arrangcmcnt was confirmed through a court ordcr, datcd April 20. 1998, and
cntcrcd by thc Honorablc Kevin A. Hess. A copy ofthc Ordcr is attachcd hcrcto as Exhibit "A."
6, Sinec the cntering ofthc Court Ordcr, datcd April 20, 1998, Plaintiffand
Dcfcndant havc bccn unable to cffcctively sharc lcgal custody or physical eustody of thcir thrcc
children,
7. Spccifically, Dcfendant avers thc following:
A. Plaintiff has on numerous occasions inappropriatcly involvcd thc thrcc
children in child support issucs and monctary mattcrs of thc parties;
B. Plaintiff has on numcrous occasions madc inappropriatc rcmarks and
comments rcgarding the parenting skills of Dcfendant in front of thc childrcn and has rcfuscd to
cooperatc with suggcsted modifications to schedulcs which will cnhancc the childrcn's timc with
both partics;
C. Plaintiff has on numcrous occasions used the childrcn as a messcnger
servicc to dcliver billing statcmcnts and mcssages to Dcfendant;
D. Plaintiff has on numcrous occasions rcfuscd to allow Pctitioner to visit with
the childrcn or speak to them by tclcphonc; and
E. Plaintiff and Defcndant arc unable to communicatc, discuss, or agrec upon
cven thc most minute mattcrs rcgarding their childrcn's livcs.
8. Defendant bclievcs that it would bcnefit both ofthc parties and the partics' three
children if Plaintiff and Dcfcndant wcre able to communieatc effcctivcly and work togcther in the
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PATRICIA A. CRAWFORD,
Plaintiff
IN THE COURT OF COMMON PLEJlS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
vs.
NO. 98-671
CIVIL TERM
DAVID A. CRJIWFORD,
Defendant
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CIVIL ACTION - LAW
CUSTODY VISITATION
OODER OF CXlURT
lIND lDI, this ..2 o:tJ.... day of ~t
consideration of the attached Custody Conciliat n Report,
directed as follows:
, 1998, upon
it is ordered and
1. The Mother, Patricia A. Crawford, and the Father, David A.
Crawford, shall have shared legal custody of Ryan A. Crawford, born November
10, 1984, Kyle S. Crawford, born August 19, 1988, and Eric D. Crawford, born
May 9, 1991. Each parent shall have an equal right, to be exerc.j.sed jointly
with the other parent, to make all major non-emergency decisions affecting
the Children's general well-being inclUding, but not limited to, all
decisions regarding their health, education and religion. Pursuant to the
tetmS of this paragraph, each parent shall be entitled to all records and
information pertaining to the Children including, but not limited to, school
and medical records and information. To the extent one parent has
possession of any such records or information, that parent shall be required
to share the same with the other parent within such reasonable time as to
make the records and information of reasonable use to the other parent.
2. The Mother shall have primary physical custody of the Children.
3. The Father shall have partial physical custody of the Children on
alternating weekends fran Friday at 6:00 p.m. until Sunday at 6:00 p.m.,
beginning April 24, 1998. In addition, the Father shall have custody of the
Children on Tuesdays and Thursdays during the school year from after school
until 8:00 p.m. and during the sUlTlller school break from 3:00 p.m. until 8:00
p.m.
4. The parties shall share or alternate having custody of the Children
on holidays as follows:
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A. Christmas: The Christmas holiday shall be divided into Segment
A, which shall begin on Christmas Eve at 12:00 noon and end on
Christmas Day at 12:00 noon, and Segment B, which shall begin
on Christmas Day at 12:00 noon and end on December 26 at 12:00
noon. The Mol:her shall have custody of the Children during
Segment A in even numbered years and during Segment B in odd
numbered years. The Father shall have custody of the Children
during Segment A in odd numbered years and during Segment B in
even numbered years.
B. ALTERNATING HOLIDAYS: The parties shall alternate having
custody of the Children on the following holidays beginning
with the Father having custody of the Children on Easter in
Thanksgiving. Under this schedule, the Father shall have
custody of the Children in even numbered years on Easter, July
4th and Thanksgiving and dut'ing odd numbered years on Memot'ial
Day and Labor Day. The Mother shall have custody of the
Children in even numbered years on Memorial Day and Labor Day
and, dut'ing odd numbered years on Easter, July 4th and
'l11anksgiving. The pedod of custody on Thanksgiving shall run
fran the Wednesday before Thanksgiving at 6:00 p.m. until the
Friday fOllowing Thanksgiving at 6:00 p.m. The pedod of
custody for all other holidays under this paragraph shall begin
at 7:00 p.m. on the evening before the holiday and shall end at
9:00 p.m. on the holiday.
C. MOl'HER I S DAY/FATHER I S DAY: The Mother shall have custody of
the Children every yeat' on Mother's Day and the Father shall
have custody of the Children every year on Father's Day from
7:00 p.m. the evening before the holiday until 9:00 p.m. on the
holiday. '
D. 'l11e holiday custody schedule shall take preceaence over the
regulat' custody schedule.
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5. During the S1.lllll1E!r school break each yeat', the Father shall be
entitled to have custody of the Children for up to two uninterrupted weeks
and the Mother shall be entitled to have custody of the Children for one
uninterrupted weeks upon providing advance notice to the other party by
April 1 of the specific week selected for s1.IIlIl1E!r vacation custody. The
party providing notice first shall be given preference in his or her
selection of vacation time.
6. Both parties shall review all homework assignments with the
Children and shall ensure that the Children complete all homework assigned
during his or her periods of custody.
7. This Order is entered pursuant to an agreement of the parties at a
CUstody Conciliation Conference. The parties may modify the provisions of
this Order by mutual agreement. In the absence of mutual agreement, the
terms of this Order shall control.
Tr.IJ!: COpy FROM R\;COF',D
In r":LiTl;':W ': h~rcoF, I hcr6 ll:i~i.~ 5:.: r.1Y hand
iJl1J :11:.' ::..;~I of said Court ()t Cariisb, Pa.
This .....~.b...~ day of....~,.I.i:.~" 19.5.?,
.......,..~~.:'.p!~~.~.........-
BY THE COURT,
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Kevin A. Hess
J.
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cc: John J. Connelly, Jr., Esquire - Counsel for Mother
Kathleen Carey Daley, Esquire - Counsel for Father
PATRICIA A. CRAWFORD,
Plain tilT
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSVLVANIA
v.
: NO. 98-671 CIVIL TERM
DAVID A. CRAWFORD,
Defendant
: CIVIL ACTION - LAW
: IN CUSTODY
PETITION FOR COURT ORDERED COUNSELING
AND NOW, comes the Defendant, David A. Crawford, by and through his attorney, Kathleen
Carey Daley, Esquire, and avers the following:
I. Petitioner is David A. Crawford, an adult individual who resides at 121 Beacon Drive,
Harrisburg, Dauphin County, Pennsylvania, and the Defendant in the above-captioned custody action.
2. Respondent is Patricia A. Crawford, an adult individual who resides at 1200 Musket
Lane, Mechanicsburg, Cumberland County, Pennsylvaoia, and the Plaintiff in the above-captioned
custody action.
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3.
The parties are the parents of three children, namely, Ryan A. Crawford, born
November 10,1984, Kyle S. Crawford, born August 19, 1988, and Eric D. Crawford, born May 9,
1991.
4. Respondent filed an action for custody on February 13, 1998. A custody conciliation
conference was held before custody conference officer Dawn S. Sunday, Esquire, on April 14, 1998,
and upon agreement of the parties, a Custody Order was entered. A true and correct copy of said
Order is attached hereto, marked as Exhibit "A", and made a part hereof.
5. Paragraph One of the Order of Court states that the parties shall share legal custody
of the three children.
6. Petitioner believes and therefore avers that he and Respondent have been unable to
effectually share legal custody of their three children during the pendency of this action.
7, Specifically, your Petitioner would aver the following:
A. Respondent has on numerous occasions inappropriately involved the three
children in child support issues and monetary matters of the parties;
B. Respondent has on numerous occasions made inappropriate remarks and
comments regarding the parenting skills of Petitioner in front of the children;
C. Respondent has on numerous occasions used the children as a messenger
service to deliver billing statements and messages to Petitioner from Respondent; and
D. Respondent has on numerous occasions refused to allow Petitioner to visit
with the children or speak to them by telephone because the visits or telephone contacts did not fit
into her schedule.
8. Petitioner believes that it would benefit both of the parties and the three children if
Petitioner and Respondent were able to communicate effectively and work together in the raising of
their three children.
9. Petitioner has requested Respondent to attend counseling sessions with him regarding
the children and Respondent has refused to cooperate with this request,
10. Petitioner believes that mandatory counseling sessions would assist the parties in their
ability to co-parent and fully exercise their shared legal custody arrangement,
11. For the reasons set forth herein, Petitioner respectfully requests this Honorable Court
enter an Order dirccting that Respondent participate in a minimum offive (5) counseling sessions with
a certified counselor. The Petitioner has confirmed with his insurance company that the following
individuals participate with his insurance plan:
A. Stanley Schneider with Guidance Associates, 412 Erford Road, Camp Hill;
B. Jane Edgar with Cornerstone Counseling, 5269 Jonestown Road, Harrisburg;
C. Robert Beach with Cornerstone Counseling, 5269 Jonestown Road,
Harrisburg; and
D. Beth Clark Byers with PA Counseling West Shore, 445 Gettysburg Pike,
Mechanicsburg.
WHEREFORE, Petitioner David A. Crawford respectfully requests this Honorable Court
enter an Order directing both he and Respondent attend a minimum of five (5) counseling sessions
with a counselor selected by the Court to increase their ability to successfully co-parent their three
children.
Respectfully submitted,
DALEY LAW OFFICES
iIU.i!~c;;,
K h1een Carey Daley, Es .
Supreme Court I.D, No. 30078
1029 Scenery Drive
Harrisburg, P A 17109
(717) 657-4795
Attorney for Petitioner
.
VIi:RIFICA TlON
Upon my personal knowledge, information and belief, I, David A. Crawford, do hereby verifY
that the facts averred and statements made in the foregoing Petition are true and correct.
I understand that false statements or averments therein made will subject me to the criminal
penalties of 18 Pa.C.S.A. ~4904 relating to unsworn falsification to authorities,
Date;
.3,d~;1~
By; O~.?C/ ~ ~/
David A. Crawford
PATRICIA ANN CRAWFORD,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
98-0532 CIVIL TERM
V,
DAVID A. CRAWFORD,
Defendant
PROTECTION FROM ABUSE
IN RE: TEMPORARY PROTECTIVE ORDER
ORDER OF COURT
AND NOW, this 12th day of February, 1998, after
hearing, and pending a further Order of Court, our temporary
protective order of January 30th, 1998, shall remain in full
force and effect with the exception of that provision having to
do with the defendant's involvement with the children's
schoOling.
By the Court,
Joan Carey, Esquire
8 Irvine Row
Carlisle, PA 17013
For the Plaintiff
J.
c~~
;J/I? }9K.
....J. If'.
Kathleen Daley, Esquire
1029 Scenery Drive
Harrisburg, PA 17109
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UUT l~lF CUUlITY
CASE NO: 19?8-005J: F~
cmlNONWEAL TH (IF I'E!IfISYL'/ MI1,\:
COUNTY OF CUMBERLAND
CRAWFORD PATRICIA ANN
V5.
CRAWFORD DAVID A
R, Thomas Kline
, Sheriff, who being duly sworn according
to law, says, that he made a diligent search and inquiry for the within
named defendant, to wit: CRAWFORD DAVID A
but was unable to locate
deputized the sheriff of
Him
DAUPI1IH
in his bailiw~ck, He therefore
County, Pennsylvania,
to serve the within PROTECTION FROM ABUSE
On February 10th , 1998
the attached return from
DAUPHIIJ
this office was in receipt of
County, Pennsylvania,
Sheriff's Costs:
Docketing
Out of County
Surcharge
18,00
9.00
2. ell2)
sOaanswp~s: ~"
'/ '~~ ~
r:::- T omu~ -1\1 ~ne,/ ;:J er~.1
~L'=1~
00/00/0000
Sworn and/subscribed}~ beiore
this -10- day of -1-t.li,
19_9_ff_ A, D,
~
me
:~
Office of the Sheriff
Mary Jane Snyder
Rool EGlolo Dopuly
Ralph G, McAllister
Chlol Dopuly
Michael W. Rinehart
AGGlstont Chlo' Ooputy
William T. Tully
Solicitor
Dnuphln County
Horrh.burg, Ponnsylvotlio 17101
(117) 265.2600
J. R. Lotwick
Sheriff
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF DAUPHIN
SHERIFF'S RETURN
No. 0240-T - - -98
OTHER COUNTY NO, 98-532
AND NOW, February 3, 1998 at 9:50PM served the within
TEMPORARY PROTECTION ORDER upon
CRAWFORD DAVID A. by personally handing to
CRAWFORD DAVID A. 1 true attested copy(ies) of
the original TEMPORARY PROTECTION ORDER
and making known to
him/her the contents thereof at 2432 BROOKWOOD ST,
HARRISBURG, PA 00000-0000
Sworn and subscribed to
before me this 4TH daY~f FEBRUARY, 1998
c!!-. If) ~IU-L)
PROTHONOTARY
LBIET
S~AR~
6f.e," _ U~y. Pe.
, /
BY li.v~,M.:> .~~
!lJii'UTY SHERIFF
.
Sheriff's Costs I $0.00 PD OOIOOIOC
RCPT NO
FILED-OFFICE
OF THF. Pi1OTHONOTARY
sa FEB -6 rli 3: 21
CUM8ERU,,'j[) COUf\ITY
PENNSYLVNllA