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HomeMy WebLinkAbout98-00532 , "\" \ q! a ~ ~ ~ '( ... c:..:, 3 'It ~ CJ ,,,:ji ;i'" ,.""~',!~{ .. V ...'" , < :.t .~ ( ; { ~ ~. :---- - .:) , 'J ri ~ "') ~ (S. 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, f 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), -)/ By the Court,', I I I .' (;( 1(r,vIAi )/ IbUudge /tt-.v I' \; ( " " Patricia Ann Crawford, Plaintiff : IN THE COURT OF COMMON PLEAS OF ( f I ' I ' I I I' I ~ v, : 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, ) . I . I 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. I ,~ I I , I I 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 ~ '/ 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, 2 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. 3 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. 4 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. 5 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, 6 () f:>- 0 c- o , ~ .., . >- ...::. .. "I co- , '" '9 r;~ " , '-', ('1 < ,:.3 It.!':-:;. , { ,";.,' to: ~.} 0 .l " -. ()~. .. .. j 6:; i:'~ C-.'\ : ,:.} ~ 5!;t.: . '. ,. j':-.: .. - I'. t'.. :~) Cl c.~' U " ~ \) B 'lI ~ ~ ~ i ! i ~ i ~ . . ...... ! J J 'lI c-~ ! . c ~ ! a. ! i I \\: :> 11 11 i i '\. 1! i! b- D i I ~ ~ ~ ~ f ! j l.: Ii . i I ;I .ll ;! I ~ ~ a ;I I ;I 'i i g a ~ . . I . l. Iii I i 'g 11 I ~~ i! W l. 'Ii ::c 11 Ii: rn I I ! I 'l! 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I I j ~ ~ g~ il ~~ ~ g~ m g~ ~ ~3: gffi ~3: A~ ~ ~ ii ! ~ ii Ilillilllll~1 1~11111!!!!~i Ilfl~~! ,~ 111111111111~~!i!~IIIII!I~!I'~!i!'!!j!! ~ ~~~~i~~~i~~ ~~~~~~ ~~ ~~~~~ ~I' ' ~: : \ . l! ~.~ 3~ fil~ ! ~ ; i i~ ~ 3 Sm G~ ~ ~ ~~ ffi ~~ ~ ~ ~~ ~18 ~ i ~ ! tl ~~ ~ 51 g3 ~ l!I~d ~ 1 : ~ ~~ ill ~ ~~ ~ "'F~< e; . i ~~~ i ~ ~~ ~~i~~1 ~ i Ii D 3~~ 5 ~ ~~ ~~~~~~ i ~ !i ~ ~ ~!~! ~ ~~ ~~I~~~ ~ ~ ~ tiC,; g~~~5E ~g~~o~O~~m ., ~ ~ g ~ ~g~ ffi ! ~~ ~~~m~~ ~ ~ ~ . ~ ~ ~ 81~~~ ; ~ i~ Ig!gg~ ~ I ~ [[ ; I rg, Is ~ ~ Uti i I i~ d~jl~ ~ ~I ~ ~!~~h~~~ 1 !~ ~~~ ~ 1;llifil;~! ~ ~~ ~!~~fili Isil !~ !~~!w~I~~~[ . I f ~i~ I! '~'i!il!i.~!~ limi~1 ~~,~ !3i.lilll~~~~~f~i~! II ! lii:!~i . li;~lifiiilgi!.i!l~ii.lil~ IIIJ~il~llliiiiiliii"~!i! M 1.IIIII~ji!!II!~I~~li~~~!,~!li~I~!!g!I~'lllllllllllliilll~ll~l c ~~U~~<.;~:i ~~~c; s 8 ~ 8 8S ~ ~~~~~~~U~UUhU~~U~~~U~ : " ~ ~ i~~ 8~~ m~fl~g ~~~~~~g~~~~~~~~~~G~~~~ . , 1 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 ':t. ~"" I""''''';' c' ~,\ PATRICIA A. CRAWFORD, Plaintiff IN THE COURT OF COMMON PLEJlS OF CUMBERLAND COUNTY, PENNSYLVANIA : vs. NO. 98-671 CIVIL TERM DAVID A. CRJIWFORD, Defendant . . 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: . , 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. , 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, I,~I --M",:"", a... ~I Kevin A. Hess J. ...,. 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. j , 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 mal >- '''') t r.r; is ." " tlQ (5 .<.. ::J< )......,. ~^3;j; ffc.. ~:.:: .1.. (.1 ~ "'" ,'~ii 9<") @',c ,..... Ll. ceLli ~,., -rOo (UtI] r-= l.W u_ ftJu.. U. .:. 0 CO :::> en U Iii w ::c U) ~ ~ . w W ~U) a;:) ~lD ~< "':::E !So ~a:: s:!1I. !:!z 150 "'1= CJ w I- o a:: a. I ff I '" ! .M i ! f~) i f I ~i I i i ~~J i I tt J f' N~ S I I llf ' j it I f l!i, ! J j J i i 6 i I I j I Iii ! t J II: J I I ! : .j I t II ! a ! I'~~, i ~! I i \: , I ~ J '0 11 a- './) il j j~e J " ! a- j J j' i ; " ~; i r , ~ " ( I J i i . "1 . \ , ! .1 ~." :-. ". ,,:l1t:I,:Jr,'I-":,: hETt!I:1i 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