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LISA GRACE WHITEHEAD,
Plaintiff
IN TIlE COURT OF COMMON PLEAS OF
v,
CUMBERLAND COUNTY, I'ENNSYL VANIA
NO, 98._dll".,L['"un CIVIL TERM
HENRY LEE WIIITEIIEAD,
Defendant
PROTECTION FROM ABUSE AND CUSTODY
TEMPORARY PROTECTION ORDER
AND NOW, this':'-.'i.11day of March, 199R, upon presentation and wnsideration of the
within Petition, and upon finding that the plaintill~ Lisa Grace Whitehead, now residing at an
undisclosed location for her protection and to avoid further abuse, is in immediate and present
danger of abuse from the defendant, lIenry Lee Whitehead, the following Temporary Order is
entered,
I,(/W /!llforc/!III/!1I1 a~:ellci/!s, 11111I/(/11 ,\'/!/'I'ic/! ClX/!l/d/!s Clllt! school dlslricls ,Ihallllol dlsc/o,\/!
Ih/! pr/!,\'/!/lc/! I!f Ih/! plalll/iff Cllld or Ih/! child IlIlh/! jlll'isdi('/io/l or di,ll/'iclm'.l;II'/1ish (I/~V add/'/!s,l,
I/!I/!pholl/! /IIIII/h/!/', or allY olher d/!lI/oX/'(/phh' Illforll/ClllolI ahollllhe plaillliff Cllld O/' child exc/!pt
hylll/'Ih/!/' Ord/!r (!f COllrl,
The defendant, Henry Lee Whitehead, (SSN: Unknown)(DOB: 04/19/61), now residing at
104 Bucannon Street, Chambersburg, Franklin County, Pennsylvania is hereby enjoined from
physically abusing the plaintiff, Lisa Grace Whitehead, or f1'om placing her in fear of abuse,
The defendant is ordered to stay away from the plllintifrs residence which is at an
undisclosed location for her protection, to which the plaintill' and the minor ehild moved to avoid
abuse, which is not owned or leased by the defendant, and is ordered to stay away trom any
residence the plaintitT may in the future establish tor herself
The defendant is ordered to rell'ain fl'Om having any direct or indirect contact with the
plaintiff, her relatives, or fellow workers including, but not limited to, telephone and written
communications,
The delendant is enjoined frl1m harassing and stalking the plaintiff and from harassing her
relatives, or the parl,i~s' minor child,
The defendant is enjoined Irom entering the plaintitl's place of employment and the school
and day carc facility of the parties' minor child,
The defendant is enjoined Irom damaging 01' destroying any property owned jointly by the
parties or owned by the plaintil1',
A violation of this Order may subject the defendant to: i) arrest under 23 Pa.C.S.
*6113; ii) a private criminal complaint uuder 23 Pa.C.S. *6113.1; iii) a charge of indirect
criminal contempt lindeI' 13 Pa.C.S. *6114, punishable by imprisonment lip to six months
and a fine ofSIOO.OO-$I,OOO.OO; and iv) civil contempt lindeI' 23 Pa.e.S. *6114.1.
This Order shall remain in effect until modified or terminated by the COllf; and can be
extended beyor.d its original expiration date if the Court finds that the defendant has committed an
act of abuse or has engaged in a pattern 01' practice that indicates risk of harm to the plaintiff,
Temporary cllstody of Latasha Lee Whitehead, is hereby awarded to tne plaintiff, Lisa
Grace Whitehead,
The defendant is ordered to relinqnish to the sheriIT's department any weapons
which he owns, possesses, has used or threatened to t:lse in an incident of abuse against the
plaintilT (a machete). The defendant is prohibited from acquiring or possessing any other
weapons for the duration of the Order and is required to relinqllish to the sheriIT any
firearm license the defendant may possess. The defendant's weapons and firearm license
may be returned at the expiration of the Protection Order after the defendant has
sllbmitted II written request to the Conrt for' the retnrn of the weapons and the Court has
notilied the plaintilT of the request and given the plaintiff an opportunity to respond. A
copy of this Order shall be transmitted to the chief or head of the police department of the
Pennsylvania State Pol!ce (Carlisle IIll!'racks), alld allY other appropriate police
departments alld the sheriffs or ClImberllllld alld I<'rankllll COlllltles.
A m:ARIN(; SIIAI,I, In: m:LI) ON TillS MATn:R ON )111 ..('/: I .::i I . 1998,
AT S?, if <( .1...M., IN COlIRTRO()M NO. -L. (W 'I'm: ClIMO.:RL.AND
COlJNTY COlIRTIIOlIS.:, CARLlSU:, I"':NNSYLV ANIA.
The plaintitl' may proceed without pre-payment of fees pending n further order nfter the
hearing,
The Cumberland County Sheritl's Department shall attempt to make service at the
plaintiff's request and without pre-pnyment of fees, but service mny 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 Pennsylvania State Police shall be provided with a certified copy 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 01' not the violation is eommitted in the presence of the police
officer, In the event that an arrest is made, under this section, the defendant shall be taken
without umlecessalY delay before the court that issued the order, When that court is unavailable,
the defendant shall be taken betore the appropriate district justice, (23 Pa,C.S, *6113),
By the Court,
! i r'/ <\ / ' (,.,:) C) ,l~\ . h Judge
./
Joan Carey
LEGAL SF,RVICES,INC. 7j'/C"L ~";U<J 4 /... .r,
Attorney for PlaintilY
LISA GRACE WHITEIIEAD,
I'laintifl'
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, I'ENNSYLV ANIA
v,
NO,98" jtdf
, CIVIL TERM
HENRY LEE WIIITEIIEAD,
Defendant
I'ROTE<'T10N FROM ABUSE AND CUSTODY
PETITION FOR PROTECTION ORDER
AND CUSTODY
RELIEF lJNDER TH~: PROTECTION FROM ABlJS~: ACt'
23 Pll.C.S. fi6l01 et seq.
A. AB1JS.:
I, The plaintiff, Lisa Grace Whitehead, is an adult individual who is residing at an
undisclosed location for her own protection and to avoid further abuse aq is more fully set forth
herein, This address will be furnished to the court upon request.
2, The defendant, Henry Lee Whitehead, (SSN: Unknown)(DOB: 04/19/61), is an
adult individual residing at 104 Bucannon Street, Chambersburg, Franklin County, Pennsylvania
17201.
3. The defendant is the husband of the plaintiff and the father of the parties' 12-year-
old daughter, Latasha Lee Whitehead,
4, Since approximately 1986, the defendant has attempted to cause and has
intentionally, knowingly, or recklessly caused bodily injury to the plaintifl~ falsely imprisoned the
plaintiff pursuant to 18 Pa, c.s, * 2903, has placed the plaintiff in reasonable fear of imminent
serious bodily injury, and has knowingly engaged in a course of conduct or repeatedly committed
acts toward the plaintiff under circumstances which have placed the plaintiff in reasonable fear of
bodily injury, This has included, but is not limited to, the following specific instances of abuse:
a) On or about February 21, 1998, the defendant grabbed the plaintiff by the
arms, pulled her out of bed, dragged her into the kitchen, threw her into the comer
of 8 brick wl\1I causing her to fall to the floor, and threatened her saying, "I'll hack
you up with 8 machete and bury you all over the yard, I'll tell everyone you left
me and no 011(1 will ever lind you," The defendant picked up the wooden kitchllll
table and threw it at her causing her to have to move to avoid being struck by the
table, Fearing for her mother's life, the parties' IZ-year-old daughter, I.atasha,
telephoned the police fbr help,
b) In or about early February, 1998, the plaintiff lold thc defendant that she
could not take his abuse anymore and was going to leave, The defendant
threatened, "You'll never leave me," grabbed a butcher knife, held it to the
plaintill"s face, and threatened, "You will die today," The defendant grabbed the
plaintiff by the arm, tbrew her on her back onto the couch, straddled her, held the
butcher knife in her face, and repeatedly threatened her for appro,ximately an hour
despite her pleas for her life, The delendant then threatened, "We will all die
today," The plaintiff feared for her life and that of daughter.
c) In or about January and February. 1998, on several occasions when the
plaintiff told the defendant that she did not want to have sexual relations with him,
he said in a threatening manner, "What do you mean you won't have sex?!" and
forced her to have sex with him despite her protests, and pleas and crying for him
to stop,
d) In or about January 1998, the defendant threatened the plaintitTsaying, "I'll
gut you like a lish," The plaintiff feared for her Iile,
e) On or about Christmas, 1997, the defendant lorcefully swung a metal bat at
the plaintiff, who ducked to avoid being hit. The defendant grabbed the the
plaintiff as she tried to run Irom the house and restrained her, The parties'
daughter, Latasha, witnessed this Incident and was traumatized by it,
t-"i .r
t) In or about 1988 or 19R9, the dl1fendllnl punched the plaintifl' in the face
with such force that the blow knocked her backward out the door, down the
outside steps, IInd into the yard where she Icllto the ground unconscious, The
plaintitrs neighbor,~ telephoned the police thr help, The Chambersburg I'olice
responded and the plllintill" was taken to the Chllmbersblll'g Hospitlll for treatment.
The plaintifl' sustained a slight concussion, and swelling and soreness aboul her
fllce as a result of this incident.
g) In or about 1987, the delcndant punched the plaintifl'in the mouth with his
fist, knocking her to the nOOl', The plaintiff sought treatment at Carlisle Hospital
for a laceration on her upper lip, The plaintill' sustained bruising, swelling and
soreness about her mouth and face and bears a visible scar on her upper lip as a
result of this incident.
h) Since approximately 1987, the defendant has abused the plaintifl" in ways
including, but not limited to, shoving, punching, slapping, choking, restraining her,
and forcing her to have sexual relations with him against her will, In addition, the
defendant has threatened to harm the plaintiff in ways including: "You won't see
daylight;" "I'll kick your ass;" "I'll cut your face up so that no one will want you,"
The defendant has held knives, a machete, and scissors to the plaintiff threatening
to kill and/or maim her, The plaintiff fears for her life,
5, On or about February 7, 1998, the plaintiff and the minor child left their residence
at 103 East Main Street, Apt. 2, Newville, Cumberland County, Pennsylvania, in order to avoid
further abuse,
6, The plaintill' believes and therefbre avers that she is in immediate and present
danger of abuse from the defendant and that she is in need of protection from such abuse.
7. The defendant is ordered 10 relhlin lhllll having any direct ()I' indirect
contact with the plaintin~ her relatives, or tellow workers including, hul not limited to, telephone
and written eOlllmunications,
8, The plaintill' desires that the defendant be enjoined !i'om harussing and stalking her,
and from harassing her relatives, and the minor child,
9, The plaint ill' desires that the defendant he I'l~strained Ih1111 entering her place of
employment, and the school and day care facility of the mintl/' child,
10, The plaintill' desires that the defendant he enjoined !i'om damaging or destroying
property owned by the plaintitl',
II, The plaintill' desires that any weapons (a machete) the defendant owns or
possesses be confiscated by the Sherill's Department and Ihat the defendant be prohibited from
acquiring or possessing any weapons for the duration of the Temporary Protection Order,
B. EXCLUSIVE POSSESSION
12, The residence from which the plaintilT is asking the Court to order the defendant to
stay away froO! is rented in the name of Lisa Grace Whitehead, and the defendant has never
resided there,
C. LOSSES AND REIMBURSEMENT FOR COST OF CASE
13. The plaintiff has suffered losses as a result of the abuse by the defendant, The
losses are listed on Exhibit A attached,
14, The plaintiff 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
goes to hearing,
He is married,
The defendant cunently resides with the following person:
~t
Rose Whitehead
RehltlonshlJ!
his mother
16, The pluintitl'has not previously participated in any litigation concerning custody of
the above mentioned child in this or any other Court,
17, The plllintifl' has no knowledge of any custody proceedings conccrning this child
pending betore a court in this or any othcr jurisdiction,
18, The plaintitr docs not know of any person not a party to this action who has
physical cllstody of the child or c1llims to have cllstody or visitation rights with respect to the
child,
19, The best interests and perlllanent welfarc of the minor child will be met if custody
is temporarily granted to the plaintitr pcnding a hearing in this matter for reasons including:
a) The plainli/l'is a responsiblc parent who can best take care
of the minor child and who IllIs provided tor thc emotional and
physical needs of the child since her birth,
b) The defendant has shown by his abuse of the plaintiff and
the plaintiff's children by a previous relationship that he is not an
appropriate role model tor the minor child,
c) The defendant's behavior has adversely affected the child,
WHEREFORE, pursuant to the provisions of the "Protection frolll Abuse Act" of October
7.1976,23 P,S, ~6]OI lJllilli1" as amended, thc plaintiff prays this Honorable Court to grant the
follOWing relief:
1\. Grant a Temporary Order pnrlluantto the "Protection from Abuse
Act:"
I
I
I, Ordering the defendant to relrain fl'\'Jlll ahu~ing the plaintifl' or from
placing her in fear of abuse,
2, The defendant is ordered to relrain lrolll having any direct or
indirect contact with the plaintitl: her relatives, or fellow worker~
including, but not limited to, telephone and written communications,
3. Ordering the defendant to refrain from harassing and stalking the
plaintiff and lI'om harassing her relatives and the minor child,
4, I'rohibiting the defendant !1'OIl1 entering the plainlill's place of
employment or the school or the day cart' facility of the minor child,
5, Prohibiting the defendant 110111 damaging or destroying property
jointly owned hy the pal ties or owned hy the plaintiff
6, Ordering the delendant to stay away from the plaintilfs residence at
an undisclosed location for her protection, which thll partie~ have never
shared, and from any residence the plaintitl' may in the future establish for
herself.
7, Granting temporary custody of the minor child to the plaintiff,
8, Ordering the defendant to relinquish to the sheriff's department any
weapons (a machete) which he owns or possesses, and prohibiting the
defendant from acquiring or possessing any weapons for the duration of the
Temporary Protection Order.
B. Schedule a hearing in accordance with the provisions of the
"Protection from Abuse Act," and, after such hearing, enter Mn order to be In effect for a
period of one year:
I, Ordering the defendant to refrain from abusing the plaintiff or from
placing her in fear of abuse,
2, The defcndant is ordcred to reti'ain Irom having any direct
or indirect contllct with the plaintifi; her relatives, or It.lllow workers
Including, but not limited to, telephone and writtcn communications,
3, Ordering the ddcndant to rcti'ain II'00n harassing ami stalking the
plaintill' and Irom harassing her relatives and the minm child,
4, Prohibiting the defendant frolll entering the plaintit1's place of
employment and the school and day care facility of the minor child,
5, Prohibiting the defendant ti'om damaging 01' destroying property
jointly owned by the parties or owned by the plaintill',
6, Ordering the defendant to stay away li'om the plaintit1's residence
which is at an undisclosed location, which the parties have never shared,
and ordering the defendant to stay away from any residence the plaintitl'
may in the future establish for herself.
7, Ordering the defendant to relinquish to the sheritl's department any
weapons (8 machete) which he owns or possesses, and prohibiting the
defendant from acquiring 01' possessing any weapons for the duration of the
Protet~tion Order.
8, Ordering the defendant to pay $250,00 to Cumberland County, one
of Legal Services, (nc's tlmding sources as reimbursement for the cost of
litigating this case, and assessing the $25,00 surchacge and court costs to
the defendant if the case goes to hearing,
The plaintiff thrther asks that this Petition be filed and served without payment of fees and
costs by the plaintill; pending 8 further order at the hearing, and that a certified copy of this
Petition and Order be delivered to the Pennsylvania State Police which have jurisdiction to
enforce this Order,
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LISA GRACE WHITEHEAD,
Plaintiff
IN TIlE COURT OF COMMON I'LEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v,
NO, 98-1618 CIVIL TERM
IIENRY LEE WIIlTEHEAD,
Defendant
PROTECTION FROM ABUSE AND CUSTODY
MOTION FOR CONTIN UANCE
The plaintiff, Lisa Grace Whitehead, 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:
A Temporary Protecllon Order was issued by this Court on March 25, 1998,
scheduling a hearing for March 31, 1998, at 8:45 a,m,
2, The Cumberland County Sheriff's Department served the defendant with a certified
copy of the Temporary Protection Order and Petition for Protection Order on March 26, 1998, at
10:20 a,m, at Cove Avenue. Newville, Cumberland County, Ptmnsylvania,
3, The defendant has retained Kimberly S, Gray of Gray Law Ollices, P,C, to
represent him in the matter,
4, The parties agree, by and through their respective counsel, that the hearing in this
matter be continued generally to afford the parties and counsel time to negotiate an agreement.
5, The plaintiff' requests that the Temporary Protection Order remain in effect for a
period of one year OJ' until further Order of Court, whichever comes first,
6, Certified copies of the Order for Continuance will be delivered to the Pennsylvania
State Police lInd the Newville Police Depllrtment by the attorney for the plllintiff~
WHEREFORE, the plaintiff' requests that the Court grant this Motion and continue this
matter generally, lInd that the Temporary Protection Ordcr remain in effect lor a period of one
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LISA GRACE WHrfElIEAIJ,
I'laintill'
IN THE COURT OF COMMON I'LEAS OF
v,
CUMBERLANIJ COUNTY. I'ENNSYL VANIA
HENRY LEE WHITEHEAD,
Defendant
NO, 98.1618 CIVIL T1iRM
PROTECTION FROM ABUSE AND CUSTODY
PROTECTION ORDER
AND NOW, this ,z..btlay of May, 1998, upon consideration of the Consent Agreement
ofttle parties, the Ibllowing Order is entered,
I, The defendant, Henry Lee Whitehead, is enjoined from physically abusing the
plaintiff, Lisa Grace Whitehead, or from placing her in fear of abuse,
2, The defendant agrees not 10 have any direct or indirect contact with the plaintiff
including, but not limited to, telephone and written communications, except where necessary
concerning the child; for example, facilitating custody arrangements, sharing information
regarding the child, and attending school or sporting events,
1 The defendant is ordered to refrain Irom harassing and stalking the plaintiff and
Irom harassing her relatives, lellow workers, and the minor child,
4, The defendant is prohibited from entering the fJlaintitrs place of employment or the
school or day care facility of the minor child,
5, The defendallt is prohibited fi'om removing Of' damaging any property owned by
the plaintiff or jointly owned by the parties
6, The defendant is ordered to stay away /i'orn the plaintiff's current residence, which
the parties have never shared, and any residence the plaintil}, may in the future establish for
herself
7, The defendant agrees to relinquish to the sherifl's department any weapons whieh
he owns or possesses, agrees that the weapons remain in the custody of the Cumberland County
~~ ,
,.. _t..,
Sheriffs Department for the duration of the I'roteclion Order, alld agrees not 10 acquire or
possess any weapons Ibr the IeI'm of the I'ruleclioll Order,
8, Coul'l costs and fees lire waivcd,
9, This Order shall remllill in enect Ihr a period of one (/) year and can be extended
beyond that time if the Court linds that the defendant has cOlllmitted an aCI of abuse or has
engaged in a paltern or practice that indicates risk of harm to the plaintilf This Order shall be
enforceable in the same manner as the Court's prior Temporary I'rotection Order enlered in this
case,
10, A violation of this Order may subject the defendant to: i) arrest untler 23 Pa,(',S,
~61J 3; ii) a private criminal complaint under 23 I'a(' S, ~6113, I; iii) a charge of indirect criminal
contempt under 23 Pa C. S, ~(i I 14, punishable by imprisonment up to six months and a fine of
$/00,00-$1,000.00; and iv) civil conlempt under 23 I'd'S, ~6114, I,
II, The Pennsylvania State Police and Newville Police Department shall be provided
with certified copies of this Order by the plaintill's attOllley and may enfbrce this Order by arrest
for indirect criminal Contempt without warrant upon probable cause that this Order has been
violated, whether or not the violation i~ committed in the presence of the police officer. In the
event that an arrest is made under this section, the defendant shaIJ be taken without unnecessary
delay before the court that issued the order, When that court is unavailable, the defendant shaIJ be
taken before the appropriate district justice, (23 PaeS ~6113),
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
.
1'., Judge
Kimber S, Gray
GRA Y LAW OFIi'ICE, P.c.
Altorney for Defendant
LISA GRACE WHITEHEAD,
Plaintiff
: IN TilE COURT OF COMMON PLEAS OF
v,
: CUMBERlAND COUNTY, PENNSYLVANIA
HENRY LEE WI "TEHEAD,
Defer.dant
: NO, 98./6/11 CIVIl. TERM
: PROTECT/ON FROM ABUSE AND CUSTODY
CUSTODY ORDER
AND NOW, this 2.!.s.t day of May, /998, UpOI1 consideration of the parties' Consent
""''''''M', th, tOlI,wi" ""'~ i. ""red w"" re,,,,, " """d, of ,,. ""b' '"Id. lA'''',
Lee Whitehead,
I, The plaintiff, hereinaftl1r referred to as the mother, shall have primary physical and
legal custody of the child,
2, The defendant, hereinafter referred to as the lather, shall have partial custody of
th, ,hild "" .,,,"',,,.. w"""'" fr'm "rid" " 6 00 p. m. .m iI Su'd., " ".00 P "', Md .. "'''''
times mutually agreed upon by the parties,
3. The father shall be responsible for transportation of the child during his periods of
ro""" T "''''"''f ""'d, "", to" P"" " I'ioo'. Pi,,, & S." S..", IE,,, M.. Sf"~"~
N,,,,,,.. C'''''''''''d C"m" p,,,.,,~,. (717-176-764/)), "".. .._~ ..'''''' '" ,,.
parties,
4, This Order shall remain in et}ect until fimher Order of Court,
5, The mother and lather shall notity each olher of all medical care the child receives
whil, i, 'h" ".",', "re. .."" ",rem .",11 "li~ th, .."" im"""i"., of m.....' __
which arise while the child is in that parent's care,
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...."'....~..~ - -
LISA GRACE WHITEHEAD,
Plaintiff
; IN THE COURT OF COMMON PLEAS OF
; CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO, 98-1618 CIVIL TERM
HENRY LEE WHITEHEAD,
De!endant
PROTECTION FROM ABUSE AND CUSTODY
CONSENT AGREEMENT
This Agreement h; entered on this Itl day of April, 1998, by the plaintiff, Lisa Grace
Whiti1head, and the defendant, lIenry Lee Whitehead, Thl1 plaintill'is represented by Joan Carey
of LEGAL SERVICES, INc.; the defendant is represented by Kimberly S, Gray of GRAY LAW
OFFICES, P,C, The parties agree that the following may be entered as an Order of Court,
I. The defendant, Henry Lee Whitehead, agrees to refrain from abusing the plaintiff,
Lisa Grace Whitehead, or from placing her in fear of abuse,
2, The defendant agrees not to have any direct or indirect contact with the plainti!l"
including, but not limited to, telephone and written comllJunications, except where necessary
concerning the child; for example, facilitating custody arrangements, sharing information
regarding the child, and allending school or sporting events,
3. The defendant agrees not to harass and stalk the plainti!l" and not to harass her
relatives, fellow workers. and the minor child,
4, The defendant agrees not to enter the plaintill's place of em!}loyment or the school
or day care facility of the minor child,
5, The defendant agrees not to damage or de~troy any propel1y owned by the plaintiff
or jointly owned by the parties,
6, The defendant agrees to stay away !Tom the plaintill's current residence. which the
parties have never shared, and any residence the plaintill'may in the fUllll'e establish for herself
, .
7, The defendant agrees 10 relinquish to the sheriff's depal1ment any weapons which
he owns or possesses, agrees that the weapons remain in the custody of the Cumberland County
Sheritl's Department for the duration of the Protection Order, and agrees not to acquire or
possess any weapons lor the term of the Protection Order,
8, The defendant, although entering into this Agreement, does not admit the
allegations made in the Petition,
9, The defendant understands that the Protection Order entered in this matter will be
in effect for a period of one (I) year and can be extended beyond that time if the Court finds that
the defendant has committed an act of abuse or has engaged in a pattei'll or practice that indicates
risk of harm to the plaintiff The defendant understands that this Order will be enforceable in the
same manner as the Court's prior Temporary Protection Order entered in this case,
10, Violation of the Protection Order may subject the defendant to: i) arrest 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 l'a,C.S, *6114, punishable by imprisonment up to six months and a
fine of$IOO,OO-$I,OOO,OO; and iv) civil contempt under 23 l'a,C,S, *6114,1.
II, The defendant and the plaintill' agree to the entry of an Order providing lor the
following custody schedule for their child, Latasha Lee Whitehead,
a) The mother will have primary physical and legal custody of the child,
b) The father will have partial custody of the child on alternating weekends
from Friday at 6:00 p,m, until Sunday at 6:00 p,m" and at other times mutually
agreed upon by the parties,