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HomeMy WebLinkAbout98-03142 '1'111'/1 N, Rumbe I, P I1I1 n II 1'1' TN TilE COllRT OF COMMON PLEAS OF v, ('IJMBER/,ANI> COllNTY, I'ENNSYLVI\N [A NO. 'lH-Jf4,?CIVIL TERM Sh/lwn M. Ordjan, (l(l I' (J nrllln t i'ROTE('T I ON f!iWM AlI/ISE AND ClISTODY AND NOW, lhis 1/ ,_'ii" '!'~MPQ.MRLeR(rl'l!q t(lN., (l!{!lliR dllY of .lIllie, 1'l'lR. upon presenlllllon the plllinlirf, 'I'llI'll N. r~umbel. now residing nl 2004 Cllrllsle IInd conslcll.rnllon of thl. within Pel It ion, IInd upon finding lhllt ROlld, Camp Ilill. Cumberlllnd County, i'ennsylvllnlll, is in Immediate IInd present dllnger of Ilhuse from thlO defendllnt, Shawn M. Onljlln, the following Temporllr,V Order Is enlered. The defend/lnt, Shllwn M. Onljlln, (SSN: unknown IInel dale of birth: 1/1H/70) now J'(,sidlng lit 613 "ummel Avenue, I.emoyne, Cumherlllnd County. f'1.nn"yIVllnill, Is herehy enjoined from her In fellr of Ilhuse. physically Ilhusing the pllllntlff, Tarll N, Rumbel, or from plllclng The defundllnt Is ordered to stllY IIWIlY from the pllllntiff's residence loellted III 2004 CEll'I Isle Road, Camp Hi II, ('umherland County, Pennsylvanlll, II residence which Is not owned or lellsed by the (lefendllnl, IInd any other residence lhl' pllllntlff mllY of lhe Pllrlles' child. The defendllnt shllll relllaln In his vehicle estllbllsh, except 1'01' the II",Heel I'UI'(10S(. of trlll1sfl'l'l'lng custod.y Ilt!lll limes clul'1ng t.he trllnsfer nf ClIslody, or IndiI'ect cont.act with the pllllllllff Including, hut not IImiteel The elljfonclanl Is ordered to refrllln from hllvlng Ilny dlreet to, tolllphono alld written COlllllllllliclltions, (.xcept for the limited Tllra N, RUlllbel, PIli I n tlf I' 1 N Tim COURT OF COMMON 1'1. FAS OF CUMlllo:RLANIl COIINTY, PP,NNSYLVANIA v, NO, lJR-cl-!J CI VI L Tf-:RM Shawn M. OrdJan, Defendllnt PROTECTION FROM I\HIISE ANO C(ISToIlY NOTICE You huve been sued in COUI'(, 11' you wish to defend IIgalnst the ,ClllilllS set forth in the following pllges, you IIIUSt tllke lIet Ion prompt Iy lifter this Pelition, Order an(l Notice flrc scrvl,d, by IIppearlng personlllly 01' by attorney III the hl'llI'ing scheduled by the Court IInd presenting to the Court YOUI' defenses 01' objections to the clalllls set forth against you, You are wllrned that if you fail to do so the Court may proceed wilhout you, and II judgment lIIuy be entered against you by the Court without fUl'thl'r notice 1'01' any lIIonl'y claillled In thl' Petition 01' for any other clailll or rellel' I't,qucstl'd by the plaintiff. You may lose lIIoney 01' properly 01' othl'l' rights illlportant to you. Any Protection Order granted hy II Court may he considered in any subsequent domestic relations proceedings, including custody actions. FEli1i.,ANU,QQ1iT1I 11' the case goes lo hearing and the judge grants A Protection Order, II surcharge of $2~ .00 wi II be IIssessed aglllnst you. You mllY IIlso he required to pay up to $2~0.00 to reimburse one of 1.0gll1 Services, Inc. 's I'unding sources 1'01' Leglll Services Inc, 's representation of thl! plaintiff. You have the right to be represented by counsel, You should take this paper to your lawyer at once. If you do not IHlve a lawyer or cannot afford one, go to or telephone the office set forth below to find out where you clln get legal help. CUMflERLANO COUNTY BAR ASSOCIATION 2 I. [BERTY AV[';NllE CARLISlE, pr':NNSYLVANIA 1701.1 TEI.EPIIONE NUMBER: (717) 249-)1(i() or '1'01.1. FREE: 1-800-990-9108 FAX: (717)249-2663 ,...J"'~~R J (~AtHL\V.I '.1'lLllJ,C;_MH!.l'Ul' S ACT..9LJ..'l9Q The Court of COllllllon plells of CUlllberland County is rt,qulred by law to eOlllply with the AllIerleans with Disabilities Act 01' 191)0, For Inforllllltion aboul accessible facilities and rellsonllble accommodAtions availllhlt, to disabled individuals hllvlng business before the court, ple/lse contact our office. All III'rangellwllts lIlust be made Ilt least 72 hours prior' to any henr i ng or bus i ness before t he courl. You must /IllcqHI the scheduled (:onl'erl'Ill'l' or hearing. II, On 01' uhout MIIY 24, 1'198, the defendnnt heclIllIe ungf'Y, hit tho pllllntlrr (1/\ tho Hldo (11' her houd, grubbed hul' hy tho thl'ollt \ find ohnk{,d hlll'. The d(,fendant pUHh(Jd tho plnlntll'I' Into n chnll' (lnuslng huf' to fill I wi th /t0f' dnughtel' III her IHIlIS, Ail the plalntlrr tried to eilCllpe further nbuso, ItHJ del'ondl\lIt rushed towal'dH her ilwlnglng hiil Ul'lnil In nn liltcmpt to hit he 1'. b. On 01' Ilhou( Decemhel' 2, 1'I'Iti, the defl'ndllnt heclllne nngry IInCl Illlf,hlld th", plnlnll 1'1' onto the ground, cflllslng bruises on her hllnrl nnd knees. Th(l pllllntlrr hlld to bo hospitalized for promlllul'lI labor pnins, 1.lItel'lhllt night, the defendllnt thn'lllened the pluintll'f hy yelling out of his CIII' window "You nl'(I delld!" Ilnd hnl'USRed hel' with severnl unwHnled telephone eallil. c. Since lulu ilummer or ol\l'ly filii 1'1'16, tbe dcl'undnnt hilS nbuHod lbe plaintiff' in ways inclUding, bul not limited to, tho following: pushing her enusing her to I'ul I, ripping u ring off of her finger, kicking her cllr clluslng 1\ donI, knocking u glasH out of her hand, nnd ripping tho I'eul' view Inlrl'ol' off of her car enuslng her to feuI' for her Hufety. 5. The plulnl i 1'1' be I icves find therefore Hvers that she Is In I~medlale and presenl danger of uhuse from the defendant Hnd that she Is in need of protection from such nbuse. 2 tllll 11I1110 I' ell II d, W/IIqWFOIH':, IIll I'N lilt II I 10 Ihl' fll'ovlslolIH of tho "Proteqtlon fl'(j'lI AhuHI' Ilel" "I' (If'I,,hol' 7, 1'17(\,2,) PIl.e',:1. 9 (\101 !it ,~eq" ai> IlllJtllldvd, Ihl' 1111111111 fI' III'/I,VH thl.'; lIollou!ldo Court tn grant the I'ollowll1!1, 1\' Ill!" i (I, (11'11111,11 'l'l!lIll1l1i'lIry Order pursullnt to thl' "Pi'oll'el Ion I'rolll AbuHO Act:" I, nrdl'l' I ng th(, defendl\lIt to refrain from l!IlIl'lllIg thl! pllllntHf 01' from placing her In fear (I I' /lbllMe, ~, Ol'dorlng the defelldant to refrain frolll having IIny rllrnut or Indirect ("Hltar,!. with the plaintiff Irlell1dlnll" hut not limited to, telephone and IVl'llton communica,t Ions, except to facilitate ollstody /I(l'lIngementa, ,), nrdbl'llIK the defendant to refrain from 1IIII'IIssIng 1\lld HUllking tht' plaintiff IInd from h /I I'll H H In g tho P III I n t iff' H l' e III t i veil , ", fll'oh I bit IlIg tho defendant from enter ing the plllllllll'I"1I plllco of employment and the d/lY cafe f'/lulllly 01' tho mlnol' child, ~, Pl'ohlblllllg tho defondllllt from damaging or dtlslroylllp. I'rol'ril'ly oWlled soltl\y hy the plltintiff. 10, Ordol'lng tlto defondnnl to st/lY nway frol1l the pllll"llrr'~1 resl<leflce located al 2004 Carlisle 6 ROfHl, CHmp 11111, Cumberlllnd County, Pennsylvania, and IIny other residence the plaintiff may establish, oxcept for the limited (Hlt'pOse of trflnsferrlng custody of the parties' child, The defendllnt shllll remllin In his vehicle at all timos during the transfer of custody, 7, Grllnting temporary custody of the minor child to the plllintiff. 8, S~hedule II hearing in IIccordance with the provisions of the "Protection frolll Abuse Act," and, after such hellrlng, enter an order to be In errect for a per iod of one yellr: I, Ordering the defendnnt to refrain 1'1'011I nb\lsing the plaintirf or from piacing her In fear of Ilbuse. 2, Ordering the defendllnt to refrain from having !lny direct or Indirect contllct with the plaintiff Including, hut not Ilmi ted to, telephone IInd written communiclltions, except to facilitate custody arrangements. 3. Ordering the defendant to refrllin from harassing nnd stalking the plaintiff and from harassing the plaintiff's relatives. 4, Prohibiting the clefendllnt from entering the pllllntlff's plnce of employment and the day eare fllelllty of the minor child. 7 ~ , f> 1'1' Ii I h I ( I n g I he do fen d II n t f r 011I d Illlln gin g (H dUMtloylng property owned solely hy the plaintiff. 6, Ordering (lte deflHldant (0 SillY awny from the pllllnllff's rU~lld"nee loented lit 2004 carlisle HOlld, Cnlll" 11111, Cumherlnnd County, Pennsylvunln, 11IId flny other residence llie plnlntlff IlIl.lY us(,"" IHh, except 1'('1' the Ilml tecl purpose of Lrllll~ll'erl'lng custody of the pllrtles' child, The dof(!(ldllfl( shltll rem/lln In his vehicle at 1111 times during tlie trnnsl'llr of custody. 7, Ord(1ring the defcndllnt to pllY $250.00 to reimhurse one of 1.egnl Services, Inc,'s funding SlHll'CeS for tlie cost of litiguting this CIIse, Tho plnlntlff further nsks that tills Petition he filed IInd Ml'l'vodwltlloUt pnymont of fllOS Ilnd cosls hy the plaintiff, potHling II furl her o!'fler lit the hearing, und thllt certified copies of this Orlkr he dldlverod to tlw Lower Allen Township /lnd 1If1ll1pdun T(]wflsliip Pol icu nepllT'tlllonts which hllvo jurisdiction to onfurve this Order, The (llnlntlff prnys for such other relief us may be just and I'I'0pO 1', CO\JN'!' II mh'i:tQnX....!)Nt>.F.JL!'.t~NN S Vl.!Y A!:j,l1\.-.-CJJSTOnV LAW 18, 'I'ho a Ilegnt InnH of C~ount I nhove arc incorporated IW(,(Jln liS If fully set forth, R j j , g g , , I ~. ~f ~., I' U ~i U ' . al : J Iii Ii i II II 'iJiil .1!15'!~~ .1 , '. mmulIIllHlllnmdu!ml11mn I ~~~~~~~~~~~ ~.~~~~ ~~ ~~~~~ I , i 'Ii ! ill! n " I W i 'II !' adU ' · ~ ! i il~! I II Illill I I ! ! ! J 1,,1 ! 111;lilll II I [. I I~! i II~I! r !l ~!ljl~ ! ~I I !Ilillil!! ~u J lit , I lQ ~ i~Ml Il!)o t I un~ , ~ 8 In . h~ h~~g !1~~a~g~~~fnhU~hi~ ,. , , , !' . ! I\I)~ 1r I I I' ~, j I j~ j -' 1 n- , OJ I ~ .,.. )to p: i i ~ ~ I I I I 'i i J j~ I m I .!7 j"S) J i i '2. ) j ~ - I i ,. ~ I ~ I ! i I IW ! J '* I f ;~ .& j ~ .b' II '% I i - I I .!f I! I j , I I ~ 1 I I ,~ s I ~ !~ a: I ~ -; J Do '1.1- J - OUJ ~ F 1 III '7:: I ...~ l- I : "1'5 I J J I II~ ~i f. . I I I I I . 1""'1 I i I \&1'2. ! I..".. J J F ~ i ! f TARA NICOLE (RUMBEL) GRDJAN, PlaitullT : IN TIlE COURT OF COMMON "LEAS : OF CUMBER.LAND COUNTY, "ENNSYLVANIA vs, : NO, 98..1142 CIVIL TERM SHAWN MIClIAEL GRDJAN, Defendant : PROTECTION FROM ABUSE AND CUSTODY NOTICE OF HEARlNG_AND. ORDER YOl} HA VI!: BI!:I!:N slJIm IN COURT. If you wish to defend against the claims setlol1h in the filllowing papers, you must appear at the hearing scheduled herein, If you fail to do :;0, the case may proceed against you and a FINAL Order may be entered against you granting the rcliefrequested in tlw Petition. In particular, you may be evicted from your residence and lose other important rights, f'(1 1~ , A hearing on Ihis mattfr is scheduled for Ihe ~ day of AlIGlJST, 1999, al3... L'1J...p m . , I n Courtroom No.....2-_ of Ihe Cumherland County Coul1house, Cal'lisle, Pennsylvania. You M liST' obey Ihe Order Ihalls attached unllllt is modified or lerminaled by Ihe court afler notice and hearing. If you disobey this Order, the police Illay arrest you, Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000,00 and/or up to six months in jail under 23 Pa,c.S, ~6114, Violation may also ~ubject you to prosecution and criminal penalties under the Pennsylvania Crimes Code, Under federal law, 18 U,S,c. ~2265, this Order is enforceable anywhere in the United States, tribal lands, U,S, Territories and the Commonwealth ofPuel1o Rico, (fyou travel outside of the state and intentionally violate this Order, you may be su~iect to federal criminal proceedings under the Violence Against Women Act, 18 U,S,c. ~2261.2262, YOU SHOULD TAKE THIS PAPER TO YOlJR LAWYER AT ONCE. YOU HAVE THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEARING THE COURT WILL NOT, HOWEVER, APPOINT A LAWYER FOR YOU IF YOU DO NOT IIA VE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELD, IF YOU CANNOT FIND A LAWYER, YOU MAY HAVE TO PROCEED WITHOUT ONE, CUMBERLAND COUNTY BAR ASSOCIATION 2 UBERTY A VENlJE CARLlSL.E, PENNSYLVANIA 17013 TELEPIIONE NUMBI!~R: (717) 249-3166 AMERICANSWJTH DISABILITIES ACT 01<' 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 Coull, please contact our office, All arrangements must be made atleasl 72 hours prior to any hearing or business belnre the court. You must attend the scheduled conference or hearing, IX> 8. A certified copy of this Order shall be provided to the police department where Plaintiff resides and/or works any other agency specified hereafter: .r!!lintiff's resw.enci!!: West Shore Regional Police Department IX> 9.' nlls ORDER SUpt:RSEm:S lID ANY PRIOR PFA ORm:R AND I&> ANY PRIOR ORDER RELATINc:; TO (:HILD CIJSTODY 10. nlls ORDt:R APPLU:S IMMEDlAn:LY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT At'TER NOTICE AND HEARING, NOTICE TO D~DANT Defendant is hereby notified that violation of this Order may resnlt in arrest for indirect criminal contempt. which is punishable by a fine of up to 51,000.00 and/or up to six months in jail. 23 Pa.C.S. ~6114. Consent of Plaintiff to Defendant's return to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. ~6113. Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penallles under the Violence Against Women Act. 18 U.S.C. U 2261-2262. Any protection order granted by a court may be considered in any subsequent proceedings, including child custody proceedings. under title 23 (Domestic Relations) of the Pennsylvania Consolidated Statutes. NOTICE TO LAW ENFORCEMENT-OFFICIALS This Order shall be enforced by the police who have jurisdiction over Plaintiff's residence OR any locations where a violation of this order occurs OR where Defendant may be located. If Defendant violates Paragraphs 1 through 6 of this Order, Defendant may be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant. based solely 011 probable cause, whether or not the violation Is committed in the presence of law enforcement. Subseqnent to an arrest, the law enforcement officer shall seize all weapons Ilst.d or threatened to be used during the violation of this Order OR during prior incidents of abust. Weapons must forthwith be delivered to the Sheriff's office of the county which issued this Order, which offict. shall maintain possession oftheweapons until furtller Order of this Court. a. Defendant is enjoined from damaging or destroying allY property owned jointly by the parties or owned solely by ')lllintilI b, DefMdant is to refi'llin thlln hllrussing 1'IIllntifrs relatives. I. Grllnt such other relief as the court deems approprilltll Order the police or other law enforcement agency to serve Defendant with a copy of this Petition, any Order issued, and the Ordllr for flearing, Plaintiff will inform the designated authority of any addresses, other than Defendant's residence, where Dllfendanl can be served, COUNT II CUSTODY ILNDER PENNSYLVANIA CUSTODY LAW ]5. The allegations of Count I above are incorporated herein liS if fully set forth, 16, The best interest and pennanent welfare of the minor child will be served by contlnnlng custody In Plaintiff as set forth in paragraph 9 of the petition, WHEREFORE, pursuant to 23 Pa,C.S,~ 5301 ef. ~" and other applicable rules and law, Plaintiff prays this Honorable Court to award custody of the minor child to her. Dated: l f';;/F/ .I ,I / Respectfully submitted, I ''',1 ~!~ UrUu' ( , (;fo'lln Carey, Attome or Plaintiff OJ LEGAL SERVICt:S, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243.9400 ~, 0' "", cr:' e, I,,: ~2( I:: .. ,.. P;I\.,! 1; ,...~ .-,~" . ( ':,L ,,I ~,.,) ,,~. I,,,.' ;>' c:> .. ;~ .. . i~.. \)~~! ("f "rlf, 0.0 ()I_. "r',:!) 'l'~ 1..1.1'J- '", t!.l il'"r< fl, ~p IdCi'J I:: :'~;I Ulrl.. .'J; ~ l' Cl' ", () (n t:;.1 Law enforcemen! agencies, human service agencies and school districts shall not disclose the presence of Plaintiff and/or address, telephone numher, or any other demographic information ahollt Plaifitlff and/or chlld/ren except hy further Order of COllrt. This Order shall remain in effect until modified 01' terminated by the Court and can be extended beyond Its original nplratlon dnte If' the COllrt finds that Defendant has committed an act of abllse or has engllged In a pattern or practice that Indicates risk of harm to Plaintiff. Defendlln! Is enjoined from damllging or dcstro)'lng all)' 'Jropcrty owned .lolntly by the pnrtles or owned solely by Plaintiff. Defendant Is to refrain from harassing Plalntifrs relatives or the minor child. o 9. Defendant is directed to pay temporary support fill' _ as follows: _' This Order fill' support shnllremnin in em.,ct until n final support order is entered by this Court. Howcver, this Ordcr shall lapse automutically if!'laintiffdoes not tile a complaint for support with the Court within fifteen (15) dnys ofthc date of this Order. Thc amount of this temporary order does not nccessarily reflect Defendant's correct support obligation, which shall be dctcrmined in aceordancc with the guidelincs at the support hearing. Any adjustments in the final umount of support shall be credited, retroactive to thill date, to the appropriate party. o 10. The costs of this uetion arc wai ved as to !'Iuintiff and imposed on Defendant. o II. Defendunt shall puy $_ to!'laintiffaseompensation for !,laintHl's out-of:.pocket losses, which arc as follows: OR o !,Iuinliffis granted leave to prescnt a pctition, with approprillte notice to Defendant, to _ requesting recovery 01 out-of-pocket Imses. 1 hc pClidon shuil include an exhibit itemizing all claimed out-of-pocket losses, copies orall bills and estimates of repair, and an Order scheduling a hearing. No fee shall be required by the !'rothonotary's olftce for the filing of' this pelilion. o 12. BRADY INDICATOR o I. The Plaintiffor protected person/s is a spouse, flmner spouse, a person who eohabitates or has cohabited with Defendant, a parent of a common child, a child of that person, or a child of Defendant. o 2. This Order is being entered litleI' a hearing of which Defendant received actual notice IInd hnd an opportunity to be heard. o 3, Paragraph I of this Order has been checked to restrain Defendant from harassing, stalking, or threatening Plllintiffor protected pcrson/s. o 4. Defendnnt represenls a credible thrent to the physical safety of Plaintiff or other protected person/s OR o The terms of this Order prohibit Dclendant from using, nttel11pting to use, or threatening tousc physical force ngllinst Plaintiffor protected person thnt would rellsonllbly he expected to cause bodily injury. (8) 13. TUIS ORIlER Stll'EI{CIWES: (8) ANY PRIOR PFA ORDER and (8) ANY PRIOR ORDER RELATING TO CUlLD CUSTODY. (8). 14. All provisions of this Order shall expire one year from the date this Order Is entered. NQTICE TOmE DEFENDANT VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A .JAil SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S. ~6114. VIOLA TION MA Y ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYL VANIA CRIMES CODE. THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES, AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACTION, 18 U.S.C. ~2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C. *~ 2261.2262. IF PARAGRAPH 12 OF T1-IIS ORDER HAS BEEN CHECKED, YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACTION, 18 U.S.C. *922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION. , \ /ltJGI 8 2000 ) '\ " \ r.ARA NICOLE (RUM BEL) GRDJAN, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 98-3142 SHAWN MICHAEL GRDJAN, Defendant CIVIL TERM PROTECTION FROM ABUSE AND CUSTODY MODIFIED FINALERQU;CTION ORDfB DEFENDANT'S NAME: DEFENDANT'S DATE OF BIRTH: DEFENDANT'S SOCIAL SECURITY NUMBER: NAMF,: OF PROTECTIVE PERSON: Shawn Michael Grdjan January 18, 1970 168.66-3656 Tara Nicole (Rumbel) Grdjan AND NOW, this 2.1 . day of _~ . ,2000, the parties having agreed to a Modification of fhe Final Protection n~rder entered by this Court on October 11, 1999, it is adjudged and decreed as follows: 1. The Plaintiff, Tara Nicole (Rum bel) Grdjan, is represented by Charles E. Petrie, Esquire; and the Defendant, Shawn Michael Grdjan, is represented by Thomas p. Gould, Esquire. The Defendant, although agreeing to the terms of this Order, does not admit the allegations made in the Petition. Plaintiff's request for a Final Protection Order is granted pursuant to the consent of Plaintiff and Defendant. Defendant shall not abuse, stalk, harass or fhreaten Plaintiff or any other protecfive person in any place where fhey might be found. 2. Except as otherwise specified below, Defendant is prohibited from having any contact with Plaintiff at any location including, but not limited fo, any contact at Plainfiff's current residence or at any of her residence she may establish for herself in fhe future, and/or at her curlent or fufure place of employment. Defendant is specifically ordered to stay away from the following locations for the duration of the Order: Plaintiff's residence, 214 Hummel Avenue, Lemoyne, PA 17043; and Plaintiff's place of employment, (the address is undisclosed for Plaintiff's profection), Information shall be provided to law enforcemenf agencies upon request. Defendant may have contact with Plaintiff as necessary to exercise his right of partial physical custody of the minor Child and for the limited purpose of parental counseling at the designated therapist's office. 3. Defendanf shall not confact Plaintiff by telephone or by any other means, inclUding third parties, except as necessary fo arrange his participation with Plaintiff in parental counseling and to arrange custodial periods with the minor Child. . 4. The custody of the minor Child shall be as indicafed in an Order of Court 'docketed at 00-3518 in Custody, Cumberland County Court of Common Pleas, 5. The following Additional Relief is granted as authorized by Section 6108 of this Act: Law Enforcement Agencies, Human Service Agencies and School Disfrict shall not disclose the presence of Plaintiff and/or address, telephone number or any other demographic information about Plaintiff and/or Child except by further Order of this Court, This Order shall remain In effect until modified or ferminated by the Court. It can be exfended beyond ifs original expiration date If the Court finds that Defendanf has committed an act of abuse or has engaged In a pattern or practice that indicates risk of harm to the Plaintiff. Defendant is enjoined from damaging or desfroying any property owned jointly by the parties or solely by Plaintiff. Defendant Is to refrain from harassing Plainflff's relatives or the minor Child. 6. This Order supercedes any prior PFA Order. 7. All provisions of fhis Order shall expire October 11, 2000. NOTIC!;...TIU1:lE DEFENDANT: VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 Pa ,C. S. ~ 6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, US TERRITORIES, AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACTION 18 U.S,C. ~ 2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT 18 U.S.C. ~~ 2261-2262, YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE BRADY PROVISIONS OF THE GUN CONTROL ACTION SECTION 18 U.S.C. ~ 922(G), FOR THE POSSESSION, TRANSPORT, OR RECEIPT OF FIREARMS OR AMMUNITION IF THE ORDER SO INDICATES. NOTICE TO LAW ENFORCEMENT OFFICIAJ.S: The police who have jurisdictiorl over Plaintiff's residence OR any location where violation of this Order occurs OR where Defendant may be located, shall enforce this Order. An arrest for violation of Paragraphs 1-7 of this Order may be withouf warrant based solely on probable cause, whether or nof the violation is committed in the presence of police. 23 Pa. C. S. ~ 6113. Subsequent to an arrest the police officer shall seize all weapons used or fhreatened to be used during the violation of this Protection Order ordering the prior incidence of abuse. The Cumberland County Sheriff's Department shall maintain possession of all fhe weapons until further notice. Order of this Court: When Defendant is placed under arrest for the violation of the Order Defendant shall be taken fo the appropriate authority or aufhorities before whom Defendant is to be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by fhe police office OR Plaintiff, Plaintiff's presence and signature are not required to file ths complaint. Insufficient grounds for violation of this Order are alleged, Defendant shall be arraigned, bond set and bofh parties given notice of fhe date of hearing. , . I\Ub I H (I/I/(i \ ~ TARA NICOLE (RUMBEL) GRDJAN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 98-3142 SHAWN MICHAEL GRDJAN, Defendant CIVIL TERM PROTECTION FROM ABUSE AND CUSTODY MODIFIED.E.lNAL PROTECTION ORDER DEFENDANT'S NAME: DEFENDANT'S DATE OF BIRTH: DEFENDANT'S SOCIAL SECURITY NUMBER: Shawn Michael Grdjan January 18, 1970 166.66.3656 NAME OF PROTECTIVE PERSON: Tara Nicole (Rumbel) Grdjan AND NOW, this d Ilk day of _\\~l.J.> ~ , 2000, the parties having agreed to a Modification of the Final Protection ~er entered by this Court on October 11, 1999, it Is adjudged and decreed as follows: 1. The Plaintiff, Tara Nicole (Rumbel) Grdjan, is represented by Charles E. Petrie, Esquire; and the Defendant, Shawn Michael Grdjan, is represented by Thomas D. Gould, Esquire. The Defendant, although agreeing to the terms of fhis Order, does not admit the allegations made In the Petition. Plaintiff's request for a Final Protection Order is granted pursuant to the consent of Plaintiff and Defendant. Defendant shall not abuse, stalk, harass or threaten Plaintiff or any other protective person in any place where they might be found. 2. Except as otherwise specified below, Defendant is prohibited from having any contact with Plaintiff at any location including, but not limited to, any contact at Plaintiff's current residence or at any other residence sh~ may establish for herself in the future, and/or at her current or future place of employment. Defendant Is specifically ordered to stay away from the following locations for the duration of the Order: Plaintiff's residence, 214 Hummel Avenue, Lemoyne, PA 17043; and Plainfiff's place of employment, (the address is undisclosed for Plaintiff's protection). Information shall be provided to law enforcement agencies upon request. Defendant may have contact with Plaintiff as necessary to exercise his right of partial physical custody of the minor Child and for the limited purpose of parental counseling at the designated therapist's office. 3. Defendant shall not contact Plaintiff by telephone or by any other means, including third parties, except as necessary to arrange his participation with Plaintiff in parenfal counseling and to arrange custodial periods with the minor Child. , . 4. The custody of the minor Child shall be as indicated in an Order of Court docketed at 00-3518 in Custody, Cumberland County Court of Common Pleas. 5. The following Additional Relief is granted as authorized by Section 6108 of this Act: Law Enforcement Agencies, Human Service Agencies and School District shall not disclose Ihe presence of Plaintiff and/or address, telephone number or any other demographic information about Plaintiff and/or Child except by further Order of this Court. This Order shall remain in effect until modified or terminated by fhe Court. It can be extended beyond its original expiration date If the Court finds that Defendant has committed an act of abuse or has engaged in a pattern or practice that indicates risk of harm fo the Plaintiff. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or solely by Plaintiff. Defendant is to refrain from haraSSing Plaintiff's relatives or the minor Child. 6. This Order supercedes any prior PFA Order. 7. All provisions of this Order shall expire OctOber 11, 2000. tiO.TICE TO THE DEFENDANT: ViOlATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 Pa .C. S. ~ 6114. VIOLATION MAY ALSO SUBJECT YOLl TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, US TERRITORIES, AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACTION 18 U.S.C. ~ 2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT 18 U.S.C. ~~ 2261-2262. YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE BRADY PROVISIONS OF THE GUN CONTROL ACTION SECTION 18 U.S.C. ~ 922(G), FOR THE POSSESSION, TRANSPORT, OR RECEIPT OF FIREARMS OR AMMUNITION IF THE ORDER SO INDICATES. NOTICE TO LAW ENF~OFFICIAL.S.: The police who have jurisdiction over Plaintiff's residence OR any location where violation of this Order occurs OR where Defendant may be located, shall enforce this Order. An arrest for violation of Paragraphs 1-7 of this Order may be withouf warrant based solely on probable cause, whether or nof the violation is committed in fhe presence of pollee. 23 Pa. C. S. ~ 6113. Subsequent to an arrest the police officer shall seize all weapons used or threatened to be used during the violation of this Protection Order ordering the prior Incidence of abuse. The Cumberland County Sheriff's Department shall maintain possession of all the weapons until further notice. Order of this Court: When Defendant is placed under arrest for fhe violation of the Order Defendant shall be taken to the appropriate authority or aufhoritles before whom Defendant is to be arraigned. A "Complainf for Indirect Criminal Contempt" shall then be completed and signed by the police office OR Plaintiff, Plaintiff's presence and slgnafure are not required to file the complaint. Insufficient grounds for violation of this Order are alleged, Defendan! shall be arraigned, bond set and both parties given notice of fhe date of hearing. .. " r t', 1\; I' t [, ,~ \ ,; I ~. . '4, , , ' JtfF ,,0( .tt,~ , It(:,....... ""t"~,, 'J 'ft , ;...' " " .." ~fl.''' J . .~ , . \ r t,I,\' j: ,~,,' 'r;A~ .1~; + ',- ~:' j ,;~..tf! ,'t" ~ '/1/-;';~' ','" v..',1 <, ,.,j ~.~ \: " ~, ' 1 {V< , ~ 'fi. ~ '. II <s;: " ""',/f. ~. ,. ~ , ,J { ,-.( '-'of " .' I ; , .