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A violation of this Order may subject the defendant to: i) arrest nnder 23 Pa.C.S.
~6113; ii) a private criminal complaint under 23 l'a.C.S. !j6113.1; iii) a charge of indirect
criminal contempt under 23 l'lI.C.S. !j6114, 11IInishllble by imprisonment up to six months
and llline of $1 00.00-$1,000.00; and iv) civil contemptnnder 23 1'1I.C.S. !j6114.1.
This Order shall remain in eOecl until modi lied or terminaled by the Court and can be
extended beyond its original expiration date if the Court Iinds that the delendanl has committed an
act of abuse or has engaged in a paUern or practice that indicales risk of harm to the plaintilI
The defendant is ordered lo relinquish lo the sheriO's department any weapons which he
owns or possesses, including, but nol limited to, a 9mm hllndgun, has used or threatened to use
in an incident of abuse against the plaintiff. The defendant is prohibited from acquiring or
possessing any other weapons for the duration of the Order and is required to relinquish to the
sheriff any firearm license the defendanl may possess, The defendant's weapons and firearm
license may be returned at the expiration of the Protection Order after the defendant has
submitted a written request to the Court for the return of the weapons and the Court has notified
the plaintiff 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 Police
(Carlisle Barracks), and any other appropriate police departments,
A HEARING SHALL BE HELD ON THIS MATTER ON JUNE
AT I [) : 3 () /hM., IN COURTROOM NO.~, OF THE
COUNTY COURTROUSE,CARLlSLE, PENNSYLVANIA,
The plaintiff may proceed without pre-payment of fees pending a lurther order after the
rJ-9
, 1998,
CUMBERLAND
hearing,
The Cumberland County Sherill's Department shall attempt to make service at the
plaintifl's request and without pre-payment of fees, but service may be accomplished under any
applicable rule of Civil Procedure,
DANA MARIE HAAS,
Plaintill.
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO, 98-
CIVIL TERM
JASON LEE MAIIANES,
Defendant
PROTECTION FROM ABUSE
NOTICE
You have been sued in court, [I' 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 personally or by attorney at the hearing scheduled by the Court and presenting to the
Court your defenses or objections to the claims scl 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 againsl 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 of$25,OO
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 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: (7 I 7) 249-3166 or TOLL FREE: 1-800-990-9 I 08
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 office, All arrangements must be made al least 72 hours prior to any hearing
or business before the court.
DANA MARIE IIAAS,
Plaintil1'
IN TilE COURT OF COMMON PI.EAS OF
CUMBERI.AND COUNTY, PENNSYLVANIA
v.
NO, 98-____3_'l{}l___ CIVIL TERM
JASON LEE MAl lANES,
Defendant
PROTECTION FROM ABUSE
PETITION FOR PROTECTION ORDER
RELIEF UNDER THE PROTECTION FROM ABUSE ACT
23 PlI.C.S. ~6101 et seq.
A. ABUSE
I. The plaintiff, Dana Marie Haas, is an emancipated minor residing at 502 North
Bedford Street, Carlisle, Cumberland County, Pennsylvania 17013,
2, The defendant, Jason Lee Mahanes, (SSN: Unknown)(DOB: 06/05/79), is an adult
individual whose last known address is 241 Arch Street, Rear, Carlisle, Cumberland County,
Pennsylvania 17013,
3. The defendant has had an intimate relationship with the plaintiff.
4. Since approximately November 1997, the defendant has attempted to cause and
has intentionally, knowingly, or recklessly caused bodily injury to the plaintiff, has falsely
imprisoned her 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 June 8, 1998, the defendant telephoned the plaintiff at her
residence, argued with her, threatened to kill her, threalened to have 30 black girls
kick her ass, and threalened to have her boyfriend killed, The plainliff, who is 8
~
months pregnant, lea red IIII' her salety and reported the incident to the Carlisle
~'
Poliee,
b) In or about early May 1998, the dclendant telephoned the plaintil1' at her
residence and threatened to come to her residence and shoot up the house, The
plaintilT reported the threallo the Carlisle Police,
c) In or about March 1998, the delendant threatened to kick the plainlill's ass
ifshe did not allow him to see their baby aile I' it is born in July.
d) In or about December 1997, the delendant shoved the plaintiff down onto a
chair during an argument.
e) In or about November 1997, the defendant slapped the plaintiff in the lace,
The plaintiff sustained a red mark and soreness about her face as a result of this
incident.
I) Since approximalely November 1997, the defendant has abused the plaintiff
in ways including, but not limited to, shoving and slapping her, restraining her by
pinning the plaintiff against the kitchen counter, and shoving her away from the
door to keep her from leaving, telephoning her residence repeatedly and arguing
with her, threatening to kick her ass, have others harm her, and threatening to kill
her boyfriend.
5, The plaintiff believes and therefore avers that she is in immediate and present
danger of abuse from the delendant and that she is in need of protection from such abuse.
6. The plaintiff desires that the defendant be prohibited from having any direct or
indirect contact with her including, but not limited to, telephone, written, third party, or electronic
communications,
7. The plaintilT desires that the defendant be enjoined from harassing and stalking the
plaintiff, and from harassing her relatives,
8, Thc plaintifl'dcsircs tlwt thc dcfcndant bc rcstraincd Ii'om going to hcr placc of
cmploymcnt or school.
9, Thc plaintiff desires that any weapons the defendant owns or possesses including,
but not limited to, a 9mm handgun, be conliscated by the Sherifl's Department and that the
defendant be prohibited from acquiring or possessing any weapons for the duration of the
Temporary Protection Order,
B. EXCLUSIVE POSSESSION
\0, The home located at 502 North Bedford Street, Carlisle, Cumberland County,
Pennsylvania, from which the plaintifl' is asking the Court to order the defendant to stay away, is
rented in the name of Ida Neal, and the defendant has never resided there,
C. REIMBURSEMENT FOR COST OF CASE
II, The plaintiff asks that the defcndant 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.
A. Grant a Temporary Order pursuant to the "Protection from Abuse
Act:"
\, Ordering the defendant to refrain from abusing the plaintiff or from
placing her in fear of abuse;
2. Ordering the defendant to refrain from having any direct or indirect
contact with the plaintiff including, but not limited to, telephone, written,
third party, or electronic communications;
3, Ordering the defendant to refrain from harassing and stalking the
plaintifl' and from harassing her relatives;
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DANA MARIE HAAS,
Plaintill'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
NO, 98-3405 CIVIL TERM
JASON LEE MAI'IANES,
Defendant
PROTECTION FROM ABUSE
~OTECTION ORDER
AND NOW, thi~ day' of June, 1998, upon consideration of the Consent Agreement
of the parties, the following Order is entered:
I, The defendant, Jason Lee Mahanes, is enjoined from physically abusing the
plaintiff, Dana Marie Haas, or from placing her in fear of abuse,
2, The defendant is enjoined from having any direct or indirect contact with the
plaintiff including, but not limited to, telephone, written, third party, or electronic
communications,
3. The defendant is ordered to refrain from harassing and stalking the plaintiff and
from harassing her relatives,
4, The defendant is prohibited from going to the plaintit1's place of employment or
school.
5, The defendant is ordered to stay away from the plaintiffs current residence located
at 502 North Bedford Street, Carlisle, Cumberland County, Pennsylvania, which the parties have
never shared, and any residence the plaintiff may in the future establish for herself.
6, Court costs and fees are waived,
7, This Order shall remain in et1'ect 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 pattern or practice that indicates risk of harm to the plaintiff. This Order shall be
DANA MARIE HAAS,
Plailltill'
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO, 98-3405 CIVIL TERM
JASON LEE MAIIANES,
Delclldant
PROTECTION FROM ABUSE
CONSENT AGREEMENT
..,tl,/
This Agreement is entered 011 this2.9 day of June, 1998, by the plaintifl: Dana Marie
Haas, and the defendant, Jason Lee Mahanes, The plaintifl' 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 lollowing may be entered as an Order of Court.
I, The defendant, Jason Lee Mahanes, agrees to refrain trom abusing the plaintitf,
Dana Marie Haas, or trom placing her in fear of abuse,
2, The defendant agrees not to have any direct or indirect contact with the plaintiff
including, but not limited to, telephone, written, third party, or electronic communications.
3, The defendant agrees not to harass and stalk the plaintiff and not to harass her
relatives,
4, The defendant agrees not to go to the plaintitfs place of employment or school.
5, The defendant agrees to stay away from the plaintiff's current residence located at
502 North Bedford Street, Carlisle, Cumberland County, Pennsylvania, which the parties have
never shared, and any residence the plaintiff may in the future establish for herself
6. The defendant agrees to relinquish to the sheriff's department any weapons which
he owns or possesses including, but not limited to a 9 mm handgun, agrees that the weapons
remain in the custody of the Cumberland County Sheriff's Department for the duration of the
Protection Order, and agrees not to acquire or possess any weapons for the term of the Protection
Order.
7, The defendant, although entering into this Agreement, does not admit the
allegations made in the Petition.
8. 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 extcndcd bcyond that time if the Court finds that
thc defendant has committed an act of abuse or has engaged in a pattern or practice that indicates
risk of harm to the plaintiff. The dcfendant understands that this Order will be enforceable in the
same manner as the Court's prior Temporary Protection Order entered in this case,
9, Violation of thc Protcction Order may subject the detendant to: i) arrest undcr 23
Pa,C,S, 96113; ii) a private criminal complaint under 23 Pa.C,S, 96113.1; iii) a charge of indirect
criminal contempt under 23 Pa,C,S, 96114, punishablc by imprisonment up to six months and a
fine of$1 00,00-$1,000,00; and iv) civil contempt under 23 Pa,C.S, 96114,1.
WHEREFORE, the partics requcst that a Protection Ordcr be entered to reflect the above
terms.
7)r"'Ul{/l -/ '111L1/l j'f'; tJ()iJ1Y
Dana Marie H".~laintiff
Q~J JlUL., /
~;C;;;:ey, Attorney for P~-
~~
son Lee Mahanes, Defendant
LEGAL SERVICES, INC.
8 Irvine Row
Carli sic, PA 17013
(717) 243-9400
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