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MARY ELIZABETH CRAMER,
Plaintil1'
on behalf of her minor children:
TIFFANY MARIA CRAMER.
and JUSTIN KYLE CRAMER,
IN THE COURT OF COMMON Pl.EAS or
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 98----2"Q .\
CIVIL TERM
v.
WAYNE ELLIOTT CRAMER.
Defendant
PROTECTION FROM ABUSE AND CUSTODY
TEMPORARY PROTECTION ORDER
AND NOW, this IO<1ay of February. 1998. upon presentation and consideration of the
within Petition. and upon finding that the parties' minor children, Justin Kyle Cramer and Tiffany
Maria Cramer. now residing with the plaintiff, their mother, Mary Elizabeth Cramer, at 105
Bucher Hill Road. Apt. 2, Boiling Springs, Cumberland County, Pennsylvania, arc in immediate
and present danger of abuse from the defendant. Wayne Elliott Cramer. the following Temporary
Order is entered.
The defendant, Wayne Elliott Cramer. (SSN: 1 65-58-3290)(D08: 1/24/61) now residing
at 318 Charles Road, Mechanicsburg, Cumberland County, Pennsylvania, is hereby enjoined from
abusing the minor children or from placing them in fear of abuse,
The defendant is excluded from the plaint ill's residence located at 105 Bucher Hill Road,
Apt. 2, Boiling Springs, Cumberland County, Pennsylvania, a residence which is jointly leased by
the parties, and is ordered to stay away from any residence the plaintiff may in the future establish
for herself and the parties' minor children,
The defendant is ordered to refrain from having any unsupervised contact with the minor
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children.
The defendant is enjoined from harassing and stalking the minor children and from
harassing the plaintiff and her relatives.
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Thc dcfcndant is cnjoincd fhllll cntcring thc plaintill's placc of cmploymcnt and thc school
ofthc minor childrcn,
Thc dclcndant is cnjoincd from damllging or dcstroying lIny propcrty owncd jointly by thc
Pllrtics or own cd by thc plllintilI
A violation of this Order may subject the defendant to: i) llrrest under 23 Pa.C.S.
~6113; ii) a private criminal complaint under 23 l'a.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 ofSlOO.OO-Sl,OOO.OO; and iv) civil contempt under 23 Pa.C.S. ~6114.1.
This Order shall remain in eOcct until modi lied or terminated by the Court and can be
extended beyond its original expirlltion date 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 minor
children.
Temporary custody of Justin Kyle Cramcr and Tiffany Maria Cramer. is hereby awarded
to the plaintiff, Mary Elizabeth Cramcr.
A HEARING SHALL BE HELD ON HilS MATTER ON FEBRUARY 13, 1998,
AT / / ; JrJ If .M., IN COURTROOM NO. !J, OF THE CUMBERLAND
COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA.
The plaintiO'may proceed without pre-payment of fees pending a further order after the
hearing.
The Cumberland County SheriO's Department sh.111 attempt to make service at the
plaintiO's request and without pre-payment of fees, but service may be accomplished under any
applicable rule of Civil Procedure,
This Order shall 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 mail.
The Penllsylvnllin Slnle Police nlld the Ilampdell Township Police Department shall be
provided with certilied copies of this Order by the plnintil1's nllorney. This Order shnll be
enforced by any law enlorcemenl agellcy where a viollllion occurs by arrest for indirect criminal
contempt without warmnt upon probable cause that this Order has been violated, whether or not
the violation is commilled in the presence orthe police ol1icer. 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).
BYIh~ I
Judge
Joan Carey
LEGAL SERVICES, INC. c...f~ .:JI,c/;r
Attorney for Plaintiff
DISK: DYXXIIIA: CRAMER DOC
MARY ELIZABETH CRAMER,
Plnintil1'
on behalf of her minor children:
TIFFANY MARIA CRAMER,
nnd JUSTIN KYLE CRAMER,
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
WAYNE ELLIOTT CRAMER,
Delendant
NO, 98-
CIVIL TERM
PROTECTION FROM ABUSE AND CUSTODY
NOTICE
You have been sued in court. If you wish to defend agninst the c1nims set forth in the
following pages. you must take action promptly afier this Petition, Order and Notice arc served.
by appearing personally 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 arc 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 plaintifi~ 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 01'$25.00
will be assessed against you. You may also be required to pay up to $250.00 to reimburse one of
Legal Services, Inc.'s funding sources for Legal 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 alTord 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 or TOLL FREE: 1-800-990-9108
FAX: (717) 249-2663
AMERICANS WITH 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 ollice. All arrangements must be made at least 72 hours prior to any hearing
or business before the court,
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MARY ELIZABETH CRAMER,
Plnintill'
on behnlfof her minor children:
TIFFANY MARIA CRAMER.
and JUSTIN KYLE CRAMER,
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
WAYNE ELLIOTT CRAMER,
Defendant
NO, 98-
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CIVIL TERM
PROTECTION FROM ABUSE AND CUSTODY
PETITION FOR PROTECTION ORDER
AND CUSTODY
RELIEF UNDER THE PROTECTION FROM ABUSE ACT
23 Pll.C.S. ~6101 et seq.
A. ABIJSE
I. The plaintill: Mary Elizabeth Cmmer, is an adult individual residing at 105 Bucher
Hill Road, Apt. 2. Boiling Springs, Cumberland County, Pennsylvania 17007. The plaintiff brings
this action on behalf of the parties' minor children, Justin Kyle Cmmer and Tiffany Mnria Cramer,
who reside with the plaintiff.
2. The defendant, Wayne Elliott Cramer, (SSN: I 65-58-3290)(DOB: 1/24/61), is an
adult individual residing with his parents, Leonard and Mary Cramer, at 3 18 Charles Road,
Mechanicsburg, Cumberland County, Pennsylvania 17055.
3, The defendant is the husband of the plaintill' and the father of the parties' two
minor children.
4. Since approximately 1995. the defendant has physically and sexually abused the
two minor children, placed the children in reasonable fear of imminent serious bodily injury, and
has knowingly engaged in a course of conduct or repeatedly committed acts toward the minor
children under circumstances which have placed them in reasonable fear of bodily injury. This has
included, but is not limited to, the following specific instances of abuse:
a) Sincc approximately 1995, and as rcccntly as thc wcck of Deccmbcr 22.
1997, thc dcfcndant has scxually abused both thc partics' 12-ycar old son, Justin
Kylc Cramcr, and 9-ycar old daughtcr, Timmy Maria Crumcr, as oncn as 3-4 timcs
a wcck, Thc dcfcndant oncn thrcatcncd to harm thc childrcn if thcy told anyonc
about his scxual abusc of thcm, Thc dcfcndant told his sistcr, Tammy Hcnch, who
was visiting thc family during thc Christmas holiday. that hc had scxually abuscd
his children, The defcndant had also sexually abuscd his sistcr, Tammy, when she
was 14 years old, Ms. Hench reported the dcfendant's sexual abuse of his children
to Cumberland County Children & Youth Services (CCC&YS) on or about
Decembcr 27, 1997. CCC&YS is currently investigating the case,
b) Since approximately 1995, the defendant has abused the children in ways
including, but not limited to, shoving, slapping, and punching them, and drawing
his fist back in a threatening manner causing them to fear he would strike them.
On one occasion. the defendant. who had a knife in his hand. pursued the children
up the stairs making a stabbing motion with the knife and threatening them saying.
"You'd beller watch oul." The children, crying and fearing for their safety. locked
themselves in a bedroom. The defendant has also been abusive to the family dog
by throwing it against the wall.
5. The plaintiff believes and therefore avers that the minor children are in immediate
and present danger of abuse from the defendant should they remain in the home without the
defendant's exclusion and that they are in need of protection from such abuse.
6. The plaintifr desires that the defendant be prohibited from having any unsupervised
contact with the minor children including,
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The plaintiff desires that the defendant bc cnjoincd from harassing and stalking the
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minor childrcn, and from harassing her and hcr relativcs,
8. The plaintill'desires that the delcndant be restrained Irom entering her place of
employment and the school of the minor children,
9. The plaintitl' desires that the defendant be enjoined from damaging or destroying
any property owned jointly by the parties or owned by the plaintill~
B. EXCLUSIVE POSSESSION
10. The apartment Irom which the plaintitl' is asking the Court to exclude the
defendant is rented in the name of Mary Elizabeth Cramer and Wayne Elliott Cramer.
II, The plaintill' currently has no place to stay with her children except the marital
home, and the defendant has been residing with his parents, Leonard and Mary Cramer, since
approximately January 7, 1998.
12. The plaintifl'desires possession of the apartment 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.
C. LOSSES AND REIMBURSEMENT FOR COST OF CASE
13. The plaintilThas sulTered losses as a result of the incidents that led to the filing of
this action by the defendant. The losses arc listed on Exhibit A attached.
14,
The plaintilT asks that the defendant be ordered to pay $250.00 to Cumberland
,
County, one of Legal Services. Inc.'s funding sources as reimbursement for the cost of litigating
this case. and that the defendant be assessed the $25.00 surcharge and any court costs if the case
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goes to hearing.
D. TEMPORARY CUSTODY
] 5. The plaintilTseeks temporary custody of the following children:
Name
Justin Kyle Cramer
Aee
] 2 years old
DOB: November 30,1985
1 0 years old
DOB: March 29,1987
TilTany Maria Cramer
Address
105 Bucher Hill Road, Apt. 2
Boiling Springs, PA
105 Bucher Hill Road, Apt. 2
Boiling Springs, PA
The children were not born out of wedlock.
The children arc presently in the custody of the plaintin: Mary Elizabeth Cmmer, who
resides at 105 Bucher "Jill, Apt. 2, Cumberland County, Pennsylvania,
During the past five years the children have resided with the following persons llnd at the
following addresses:
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Plaintiff
Address
105 Bucher Hill, Apt. 2
Boiling Springs, PA
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From January 7. 1998
to the present
Plaintiff and defendant
105 Bucher /-liII, Apt. 2
Boiling Springs, PA
From 1995
to January 7, 1998
Plaintiff and defendant
99 West Portland Street
Mechanicsburg, PA
From 1993
to 1995
The plaintiff, the mother of the children, is Mary Elizabeth Cramer, currently residing at
105 Bucher /-liII Road. Apt. 2, Boiling Springs, Cumberland County, Pennsylvania,
She is married.
The plaintiff currently resides with the following persons:
Name
Justin Kyle Cramer
Tiffany Maria Cramer
Relationship
her son
her daughter
The defendant. the father of the children. is Wayne Elliott Cramer. currently residing at
318 Charles Road, Mechanicsburg, Cumberland County, Pennsylvania,
/-Ie is married.
The defendant currently resides with the following persons:
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Leonard and Mary Cramer
Relationship
his parents
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16.
The plaintiff has not previously participated in any litigation concerning custody of
the above mentioned children in this or any other Court,
17, The plaintifr hils no knowledge of IIny custody proccedings concerning these
children pending before a court inlhis or any other jurisdiction,
18. The plaintil1' docs not know of any person not II p"rty to this action who has
physical custody of the children or claims to have custody or visitation rights with respect to the
children.
19. The best interests and permanent welfare of the minor children will be met if
custody is temporarily granted to the plaintilT pending a hearing in this mattcr for reasons
including:
a, The plaintilr has provided for the emotional and physical
needs of the children since their births, and is a responsible parent
who can best take care of them,
b, The defendant has shown by his abuse of the children and
the plaint ill' that he is not an appropriate role model for the minor
children and he is a danger to them,
c. The defendant's behavior has adversely alTected the
childrcn,
WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of October
7. 1976, 23 P.S. ~61 0 I et seg" as amended, the plaintilT prays this Honorable Court to grant the
following relict:
A. Grant a Temporary Order pursuant to the "Protection from Abuse
Act:"
I. Ordering the defendant to refrain from abusing the minor children
or from placing them in fear of abuse.
2. Ordering the defendant to refrain from having any unsupervised
contact with the minor children,
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), Ordering the delendant to reli'nin IrUln hnl'llssing nnd stnlking the
minor children nnd from hnl'llssing the plnintilrnnd her relntives,
4,
Prohibiting the defendant Irom entering the plnintill's plnce of
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employmentnnd the school of the minor children,
S. Prohibiting the delendant Irom damaging or destroying property
jointly owned by the parties or owned by the plaintil1:
6, Granting possession of the apartment located at 105 l3ucher Hill
Road, Apt. 2. Boiling Springs, Cumberlnnd County, Pennsylvania, to the
plaintiff to the exclusion of the defendant, and ordering the defendant to
stay away from any residence the plaintil1' may establish for herself pending
a lInal order in this malter.
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7. Granting temporary custody of the minor children, Justin Kyle
Cramer and TitT.1ny Maria Cramer, to the plaint ill:
Schedule II hearing in accordance with the provisions of the
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B.
"Protection from Abuse Act," and, after such hearing, enter an order to be in elTect for a
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period of one year:
I. Ordering the defendant to refrain from abusing the minor children
or from placing them in fear of abuse.
2. Ordering the defendant to refrain from having any unsupervised
contact with the minor children.
3. Ordering the defendant to refrain Irom harassing and stalking the
minor children and from harassing the plaintilr and her relatives,
4. Prohibiting the defendant from entering the plaintilYs place of
employment and the school of the minor children.
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5, Prohibiting thc dclendalll Irom damaging or dcstroying propcrty
jointly owncd by thc partics or owned by thc plaint ill',
6, Granting possession of the apartmcnt located at 105 Buchcr Hill
Road, Apt. 2, Boiling Springs, Cumbcrland County, Pcnnsylvania, to the
plaintifl'to the exclusion of thc defendant, and ordering the de tend ant to
stay away IrOll1 any rcsidcnce thc plaintill'may establish for herself pending
a linal order in this matter.
7. Ordering the dctendant to reimburse the plaintill's out-of-pocket
losses sullered as a result of the incidents that led to the filing of this action
including, but not limited to, the losses listed on the attached sheet marked
Exhibit A,
8, Ordering the defendant to pay $250,00 to Cumberland County, one
of Legal Services, Inc.'s funding sources as reimbursement for the cost of
litigating this case, and assessing the $25,00 surcharge and court costs to
the defendant if the case goes to hcaring,
The plaintiff further asks that this Petition be filed and served without payment of fees and
costs by the plaintiff, pending a further order at the hearing, and that a certified copy of this
Petition and Order be delivered to the Pennsylvania State Police and the Hampden Township
Police Department which have jurisdiction to enforce this Order,
The plaintiff prays for such other relief as may be just and proper,
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COUNT II
CUSTODY UNDER PENNSYLVANIA CUSTODY LAW
20, The allegations of Count I above are incorporated herein as iffully set forth,
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21. Thc bcsI intcrest lInd permllnenl wcllilrc or thc minor childrcn will be served by
confirming custody in the plllinlill'lIs set forth in PlIrngrnph 19 or the Petition.
WHEREFORE, pursuant to 23 P.S. ~ 5301 et seg.. and othcr applicable rules and law, the
plaintilT prays Ihis Honorablc Court 10 lIward custody of the minor children 10 her.
The plaintilTprays ror such olher relieras may be just and proper.
Respectfully submitted,
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{/.loan Carey, Attorney 1'0
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
DISK: DVXXIIIA: CRAMER.DOC
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MARY ELlZABETlf CRAMER,
Plainlitl'
on bchalfof hcr minor childrcn:
TIFFANY MARIA CRAMER,
and JUSTIN KYLE CRAMER,
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL V ANfA
CIVIL ACTION -LAW
v.
WAYNE ELLIOTT CRAMER,
Dclcndanl
NO, lJll-711S CIVIL TERM
PROTECTION FROM ABUSE AND CUSTODY
ORDER FOR CONTINUANCE
)lJIL
AND NOW, this ~ day of Fcbruary, 1998, upon considcration of thc attached Motion
for Continuance, the matter schcdulcd for hcaring on Fcbruary 23, 1998, by this Court's Order of
February 10, 1998, is hercby continucd gcnerally.
This Order is entered without prejudicc to cither party to request a hearing.
The Temporary Protection Order shall remain in eOcct for a pcriod of one year or until
further Order of Court..; "J-.-.~ l<r",.<J ~,"M~
A certified copy of this Order for Continuance will be provided to the Pennsylvania State
Police and the Hampden Township Police Departments by the plaintiO's attorney.
By the COu~~\
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Edward E. Guido, Judge
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Joan Carey
LEGAL SERVICES, INC,
Attorney for PlaintiO'
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MARY ELIZABETH CRAMER,
I'laintill'
on behalf of her minor children:
TIFFANY MARIA CRAMER,
and JUSTIN KYLE CRAMER.
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY,PENNSYLVANIA
CIVIL ACTION - LAW
v.
WAYNE ELLIOTT CRAMER,
Defendant
NO, 98-785 CIVIL TERM
PROTECTION FROM ABUSE AND CUSTODY
MOTION FOR CONTINUANCE
The plaintiO: Mary Elizabeth Cramcr, by and through her attorney, Joan Carey of Legal
Services, Inc., moves the Court for an Order continuing generally the hearing in the above-
captioned case on the grounds that:
I. A Temporary Protection Order was issued by this Court on February 10, 1998,
scheduling a hearing for February 23, 1998, at II :00 a,m,
2. The Cumberland County Sherin' deputized the Lebanon County Sheriff's
Department whose Deputy Sheriff served the defendant with a certified copy of the Temporary
Protection Order and Petition for Protection Order on February 19, 1998, at 2:30 p.m. at the
Lebanon V A Medical Center, Lebanon, Lebanon County, Pennsylvania, where he is currently a
patient.
3. The defendant, through Alan Burgess, his social worker at the Lebanon VA
Medical Center, indicated that he wishes to enter into a Consent Agreement to settle this matter.
4. The parties agree that the hearing be continued generally to facilitate the parties'
signing of a Consent Agreement.
5. The plaintiO'requests that the Temporary Protection Order remain in effect for a
period of one ycar or until further Order of Court.
6. A certified copy of the Order for Continuance will be delivered to the Pennsylvania
State Police and the Hampden Township Police Department by the attorney for the plaintiff.
,
WHEREFORE, the plnintill'requests thaI Ihe Court grunt this Motion and eonlinue this
Inalter generally, and that Ihe Telllpornry Protection Order remain in eOccI for a period of one
year or until further Order of Courl.
RespectfiJlly sub milled,
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r)Oan Carey, Altorney
LEGAL SERVICES, INC,
8 Irvine Row
Car/isle, PA 17013
(717) 243-9400
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In The COUl't OfClJllIllIOIl Pleas ofCumbel'lalld County, Pennsyl"ania
.
~.MARY ELIZABTEH CRAMER AND ON BEHALF OF HER MINOR CHILDREN,
TIFFANY MARIA CRAMER AND JUSTIN KYLE CRAMER
"S.
WAYNE ELLIorr CRAMER
No, 98-785 CIVIL
19_
Now, LEBANON
19_,1 SHERIFF OF CUi\IBERLA:"iD COUNTY, PA do hereb~' depulize the SherllTof
Counl)' 10 exeCUle this Writ, this depulatlon being made althe request and risk of the Plain tilT.
~r'~_.... ",,t/A
,. ~~':''':''':~'1r ~~~t'
SberllT of Cumberland Coun!)', Pa.
Affidavit of Sel'vice
Nowt
wltbin
upon
al
b~' banding 10
attesled copy of Ihe original
Ihe cnnlents Ihereof.
t9
, al
o'c1ock
M. served Ihe
a true and
and made known 10
So answers.
SherilT of
Cnun!)'. Pa.
COSTS
"
:'
S\\orn and subscrib~d before
me this day of
19_
SERVICE
MILEAGE
AFFlDA VIT
S
"
s
'".
,
MARY ELIZABETH CRAMER,
Plaintil1'
on bchalfol'her minor children:
TIFFANY MARIA CRAMER,
and JUSTIN KYLE CRAMER,
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
WAYNE ELLIOTT CRAMER,
Defcndant
NO. 98-785 CIVIL TERM
PROTECTION FROM ABUSE AND CUSTODY
PROTECTION ORDER
AND NOW, this 3l>~day of March, 1998, upon consideration of the Consent Agreement
of the parties, the following Order is entcred:
I. The dcfendant, Wayne Elliott Cramer, is enjoined from physically abusing the
minor children, Timmy Maria Cramer and/or Justin Kyle Cramer, or from placing them in fear of
abuse.
2. The defendant is enjoincd from having any unsupervised contact with the minor
children.
3. The defendant is prohibited from harassing and stalking the minor children and is
prohibited from harassing the plaintilf and her relatives.
4. Thc defendant is prohibited from entering the plaintiffs place of employment or the
school ofthe minor children.
5. The defendant is prohibited from damaging or destroying any property owned
jointly by the parties or owned by thc plaintiff.
6. The defendant is excludcd from the plaintiffs residence where the minor children
reside located at 105 Bucher Hill Road, Apt. 2, Boiling Springs, Cumberland County,
Pennsylvania, and thc defendant is ordered to stay away from any residence that the plaintiff may
establish for herself and thc minor children in the future.
7. Court costs IInd fccs IIrc waivcd.
8. This Ordcr shall rcmain in el1ect lor II periud uf onc (I) ycar IInd can be cxtendcd
beyond that time if thc Court Iinds that the dclcndant has committed an act of abusc or has
engaged in a pattern or practice that indiclltes risk of harm to thc minor childrcn. This Order shall
be enforceable in the same mllnner as the Court's prior Temporary Protection Order entcred in
this case,
9, A violation of this Ordcr may subject the dcfendant to: i) arrest under 23 Pa.C.S.
96113; ii) a private criminal complaint under 23 Pa,C.S, 96113.1; jij) a charge of indirect criminal
contempt under 23 Pa,C.S. 96114, punishable by imprisonment up to six months and a fine of
$100,00-$1,000.00; and iv) civil contempt under 23 Pa,C.S. 96114.1.
10. The Pennsylvania State Police and the Hampden Township Police Department
shall be provided with certified copies of this Order by the plaintiO's attorney and may enforce 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 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. 96113).
BY'hoC~ \
Edward E, Guido, Judge
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
Q.~:4'''' t'l'L,.~G~ .3/ 301 ~ J' ~
.0,1).
Wayne Elliott Cramer, Defendant
Lebanon V A Medical Center
1700 South Lincoln Avenue, Bldg. 18-4
Lebanon, PA 17042
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Hospital, 503 North 21st Strect, Camp Hill, PA 17011, telcphonc: (717) 763-2249. Facilitating
therapists arc RhclI Bennic and Judy Maiella.
In addition, the father shall maintain regular contact with his attending psychiatrist and/or
certified staff. follow the staff's recommended mental health treatment, rcmain in treatment until
released, and take medication as prescribed to him by his psychiatrist.
Failure by the father to follow the terms of this custody agreement may result in limitation
or termination of his contact with the children.
Edward E. Guido, Judge
Joan Carey
LEGAL SERVICES, INC.
Attorney for PlaintiO'
Wayne Ellioll Cramer, Defendant
Lebanon V A Medical Center
1700 South Lincoln Avenue, Bldg. 18-4
Lebanon, PA 17042
MARY ELIZABETH CRAMER,
Plaintill'
on behalf of her minor children:
TIFFANY MARIA CRAMER,
and JUSTIN KYLE CRAMER,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
WAYNE ELLIOTT CRAMER,
Defendant
NO. 98-785 CIVIL TERM
PROTECTION FROM ABUSE AND CUSTODY
CONSENT AGREEMENT
This Agreement is entered on this ,8'1iay of March, 1998, by the plaintiO: Mary Elizabeth
Cramer, on behalf of her minor children, Timmy Maria Cramer and Justin Kyle Cramer, and the
defendant, Wayne Elliott Cramer. The plaintiO' is represented by Joan Carey of LEGAL
SERVICES, INC.; the defendant is unrepresented but is aware of his right to have an attorney.
The parties agree that the following may be entered as an Order of Court.
I. The defendant, Wayne Elliott Cramer, agrees to refrain from abusing the minor
children, Timmy Maria Cramer and Justin Kyle Cramer, or from placing them in fear of abuse.
2. The defendant agrees not to have any unsupervised contact with the minor
children.
3. The defendant agrecs not to harass and stalk the minor children and not to harass
the plaintiff and her relatives,
4. The defendant agrees not to enter the plaintiO's place of employment and the
school ofthe minor children,
5. The defendant agrees not to damage or destroy any property owned jointly by the
parties or owned by the plaintiff.
6. The defendant agrees to stay away from the plaintiffs residence where the minor
children reside located at 105 Bucher Hill Road, Apt. 2, Boiling Springs. Cumberland County,
Pcnnsylvania, and thc dclcndant agrccs to stay away thllll any rcsidcncc that thc plaintitr may
establish IiII' hcrselfand thc minor childrcn in thc Iillurc.
7. Thc dclcndant, although cntcring into this Agrecment, does not admit the
allcgations madc in thc Pctition.
8. The delcndant undcrstands that the Protection Order cntered in this malleI' will be
in ellcct tor a period of onc (I) year and can be extended bcyond that time if the Court t1nds that
the delendant has committed an act 01' abuse or has engagcd in a pall ern or practice that indicates
risk 01' harm to the minor children. The detendant understands that this Order will be cnforceable
in the same manner as the Court's prior Temporary Protection Order entered in this case.
9. Violation 01' the Protection Order may subject the defendant to: i) arrest undcr 23
Pa.C.S. *6113; ii) a private criminal complaint under 23 Pa.C.S. *6113.1; iii) a charge ofindirect
criminal contempt under 23 Pa.C.S. *6114, punishable by imprisonment up to six months and a
line of $1 00.00-$1,000.00; and iv) civil contempt under 23 Pa.C.S. *6114.1.
10. The defendant and the plaintiO' agree to the entry of an Order providing lor the
following custody schedule for their children, Tiffany Maria Cramer and Justin Kyle Cramer.
a) The mother will have primary physical and legal custody of the children.
b) The father will have supervised visitation with the children only in the
presence of the mother or a responsible adult approved by the mother on dates and
at times mutually agreed upon by the parties.
c) The father agrees to enter into a program specifically structured for
treatment of sexual abusers and victims of sexual abuse which is staffed by
appropriately certified personnel, follow the stairs recommendations for
treatment, and remain in treatment until released. The father agrees to enroll in
such a program within 10 days of his release from the Lebanon VA Medical
Center. The father agrees that the mother's allorneys may contact the treatment
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program tll cnnlinn his cnrollmcnl, attcndancc, and staO's rcconnncndalinn lur
trcatmcnl in Ihc progrllln. A local program approprialc lor sllch Irealmcnt in the
lather's homc lIrca is thc Incest Trclltmcnt Program localed at Holy Spirit
Hospital, 503 North 21 st Strect, Camp Hill, PA 170 II, telephone: (717) 763-
2249. Facilitating Ihcrapists are Rhett Bcnnie lInd Judy Maietta.
In addition, the lather agrees 10 maintain regular conlact with his attending
psychiatrist and/or certilied sian: follnw the staO's recommended mental health
treatment, remain in treatment llntil released, and take medication as prescribed to
him by his psychiatrist.
d) The f.1ther understands that f.1i1ure to follow the terms of this custody
agreement may result in limitation or termination of contact with the children.
WHEREFORE, the parties request that a Protection and Custody Order be entered to
reflecl the above terms.
CA..o.. f,,'
Mary EI zabeth .ramer, Plaintiff
f)
~v L.-'r..L-c..,~
(; an Carey, Attorney for:::Plaintiff
LEGAL SERVICES, INc'
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
ayne lIiott Cramer, Defendant
JlvR/I1J fJ. ~O!l) I (}.tJ, rIAl. /JJ.tJf41
(9/itness to Defend nt's signature I
,kill) IJ,f"jp)t) IJ).,1;;;/>)
Witness's relationship t6 Defendant
LEBANON VA MEDICAL CENTER
1700 South Lincoln Avenue, Bldg. 18-4
Lebanon, PA 17042
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