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Home My WebLink About98-04295 .,.. ",'. ~ It I ...t'": , "'. I ~. I q:; 14 !II. ~. ;..' \l: stl -C' '\l ~! , I "", t ""\ o \ ~ ,/ I ./ / ,/ " r....' i i i , , I . {! \ ~ , ~I I , .....i . ..I .: I '-11 ",I ~" j rv ~. , 0.., ~ .'~ .. .~ ," .~',~-"~!.;\..;:~i"./r':..... . ..,,' ~. '. - 'J......z.....;...;.1_'~~,.. ......... , .~.'.. ,<: '~ ~', . '1.~. .".,.,~. . '.1fc;,.. . '\.....,.,-;.- . \ ~ $. ", .!:! ':',- ;'. ,"!i.'(~ -1:,1,. .~ ~cr~ ....,!I. '~jf-;T" ~ . . .j....,., ,,: If: '~'t.,. ........ N~~ \'it.. i . . ,tv ,.,\~. ?': .,' J"%.'~. ' c~'\ ~-' "j: '.' <I". " .~\\ "'", "':~.\ ,./ ''5-7... V! j r r I ., , ~., J \~ (t) ;(:, 1,0'.' I'r., !I " . t t. , -' ,;:~-.\' ,,~ . , .'.... 41 '()'o~ t \' .,~ . h,. (~:""; I''J., ,&'fV'- ., ,... ~l' :.:.~. . -.' t t "'\"' I.'t.:.?,_ '. ' .., 'I, ,!\ ~~~'f' ..jt~ ~ ',. .'11;. .; .. ~~"'I' ~./(/1'-t.'~..~~,,1 .(' . ,'if "f ". ~ . : ')JI'"' ""..\:I.t' .'~, '.~" \. I , '. '. , ! , , \ I , , , I r,;.J~ . ,,~, I', "). , ~., , )'-~: ....f.: NQUgLQLJ:iE_l!B.lI!(LA~D Ol1J)JB YOU HAVE BEEN SUED IN COURT. If you wish to defend ngainst the claims set forth in the following paper5, you must appear at the henring scheduled herein, If you fail to do so, t.he case may proceed against you and a FINAL Order may be entered agnin5t you granting the rel ief reque5t.ed in the Petition, In particular, you may be evict.ed from your residence and lose other important right.s, A hearing on the nmtter is scheduled fat' the 3d day oftZli(j.''/./; 1998, at. :j!.{C p.m., in Courtroom No. _/_ of the Cumberland Count.y Courthouse, Carlisle, Pennsylvania, You MUST obey the Order that is attached until it is modified or terminated by the court after not.ice and hearing. If YOll disobey this Order, the police may arrest YOll, 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. g6114, Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U,S,C, g2265, this Order is enforceable anywhere in the United St.ates, tribal lands, U,S, Territories and the Commonwealth of Puert.o Rico, If you t.ravel outside of the state and int.entionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U,S,C, g 2261-2262, YOU SHOULD TAKE THIS PAPER TO YOUR 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 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, IF YOU CANNOT FIND A LAWYER, YOU MAY HAVE TO PROCEED WITHOUT ONE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717)249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of 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 at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing, for the duration of thin Ordor': tho plllintlff'!l r'llB'idenco 10cat.RO at 10:!O North Water ford Way, Mllchlln I cnlllH'V, Cumborlllnd County, Pennsy 1 van i a, a reB i cllmcn wh i eh i 1\ ownod no 1 nl y hy the plaintiff's son to which tho plllinf.lff movod t.o avoid abuse, which is not owned or loauod hy tho rlofondllnt., and 4719 B Charles Road, Mechan i csburg, Curnhnr'llInd COlin ty, POllnny 1 van i a, a res i dence which is owned sololy hy tho plllintiff, which is not owned or leased by t.he dofollcJ/lllf. II/III allY nthr". rnnidoncll t.he plaint.iff may establish. The dofondllnf. nhllll nllllllin in hin vehicle at all times during t.ho f.r'IHlufor' "I' clIIlf.Orly, 1m 4. Except. for !H/(;h /;olltllet wlt.h tho minor child/ren as may be permitted under' PllrllVrllph Ii of f.hlfl Ordor', Defondant shall not contact Plainti ff by t.olophono 01' hy /lilY ot.her means, including through t;hi rd pOnH1nll, o 5, Pending the OlltCOll1</1 of Ll1I' flnll'l hear-ing in this matter, Plaintiff is awarrJod t,llltPI>'lIt'y f,;IIHI.Ot!y of the fOllowing minor child/ren: Unt i 1 the f i na 1 Iwl'l r I 11(J, n 11 conl.ac t between Defendant and the child/ren shal'l be 1 imitorJ to tho fOllOWing: The local law en 1'0 n; mllo 11 I, ngoney in tho jurisdiction where the child/ren are located ~;hlll1 or1f\lIro that the child/ren are placed in the care and control of the Plaintiff in accordance with the terms of this Order, o 6, Defendant shall immediately relinquish the fOllowing weapons to the Sheriff's Office or a designated local law enforcement agency for the delivery to the Sheriff's Office: Defendant is prohibited from possessing, transferring or acqUiring any other weapons for the duration of this Order, 181 7, The fo 11 owi nv uclcl I ti ol1ul ro 1 i 0 1'1 s granted: The Cumber'lancJ Counl,y Shoriff's Deportment shall attempt to make service at plaintifr n requunt Ilnd without pre-payment of fees, but service limy ho uceompl inhorJ under any applicable Rule of Civil Procedure. This Or'der shill) bn doclletorJ in l;he office of the Prothonotary ilnd forwllrdncl to tho Shc3ri ff for service. The Prothonotary shill 1 nol, !lIHHJ 1,1 copy of this Order to Defendant by mai 1, Thin Onhlr' nllllll "(!fllllin in effect until modified or tennlnlltod fly I.ho Crlllrl. IInd CIHl be extended beyond its original expiration date if the Court finds that Defendant has committed another act of abuse or has engaged in a pattern or practice that indicates continued risk of harm to Plaintiff. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Pl ai nt iff. Defendant is to refrain from harassing PlaintifP s relatives. ~ 8. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Hampden Township Police Department. o 9. PR IOR THIS ORDER SUPERSEDES OANY PRIOR PFA ORDER AND__O ANY ORDER RELATING TO CHILD CUSTODY 10, THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000,00 and/or up to six months in jail. 23 Pa,C,S, g6i14, Consent of the 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, g6113, 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 penalties under the Violence Against Women Act, 18 U,S,C, gg 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 the plaintiff's residence OR any locations where a violation of this order occurs OR where the 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 on probable cause, whether or PATTY A, SPONG-EARHART, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANTA vs, 98 - '1.J'l)/ NO. CIVIL TERM SAMUEL A. EARHART, Defendant PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE ~9UNT 1: 1, Plaintiff's name is: Patty A, Spong-Earhart, 2, This Petition is filed on behalf of the Plaintiff, Patty A, Spong-Earhart, 3, The name(s) of ALL person(s), including Plaintiff who seek protection from abuse are: Patty A. Spong-Earhart, 4, Plaintiff's marital address is: 434 Prowell Drive, Camp Hill, Cumberland County, Pennsylvania 17011. The Plaintiff temporarily resides at: 1020 North Waterford Way, Mechanicsburg, Cumberland County, Pennsylvania 17055, 5, Defendant lives at the following address: 434 Prowell Drive, Camp Hill, Cumberland County, Pennsylvania 17011, Defendant's Social Security Number is 578-44-0929, Defendant's date of birth is 8/25/34, Defendant's place of employment is Earhart's Floor & Wall Tile located at 3740 Trindle Road, Camp Hill, Cumberland County, Pennsy 1 van i a 17011, 6, Defendant is Plaintiff's husband, 7, The facts of the most recent incident of abuse are as follows: On or about July 14, 1998, the defendant became enraged, hit the plaintiff on the left side of her head and ear causing a concussion, swelling and ringing in her ear, and brUising of and Soreness of her neck and jaw. 8, Defendant has committed the fOllowing prior acts of abuse against Plaintiff: a. In or about early July, 1998, the defendant unexpectant 1 Y nnd forcefu 11 y strucl\ the plaintiff's huttocks with a wooden board causing large, red marks and soreness, b. Since the late summer of 1994, the defendant has repeatedly and forcefully hit, pushed and shoved the plaintiff, harassed her, spit water and ice into her face and forced her to perform unwanted sexual acts, On one occasion in 1997 the defendant threatened to beat the living hell out of the plaintiff, 9. The following police department or law enforcement agency in the area in which Plaintiff lives should be provided with a copy of the Protection Order: Hampden Township Police Department. 10, There is an immediate and present danger of further abuse from the Defendant. WHEREFORE, PLAINTIFF REQUESTS THAT THE COURT ENTER A TEMPORARY ORDER, AND AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOllOWING: A. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff in any place where Plaintiff may be found, B, Exclude Defendant from the marital residence located at 434 Prowell, Drive, Camp Hill, Cumberland County, Pennsylvania 17011, for a period of two weeks beginning August 10, 1998, to afford the plaintiff the opportunity to relocate, C, Prohibit Defendant from having any contact with Plaintiff, either in person, by telephone, or in writing, personally or through third persons, including, but not limited to, any contact at Plaintiff's school, business, or place of employment, D, Prohibit Defendant from having any contact with Plaintiff's relatives, except as the court may find necessary, E, Direct Defendant to pay Plaintiff for the reasonable financial losses suffered as a result of the abuse, to be determined at the hearing. F, Order Defendant to pay the costs of this action, including filing fees, service fees, and surcharge of $25,00, G, Order Defendant to pay $250,00 to reimburse one of legal Servcies, Ind s funding sources for the cost of litigation in this case, ~, ~, ~, ?~ ~~(:i .tift,: :;':Cl j;~ (; S; ~ \;' ''<\ U.> 'f\ d- ,':') 1/' 'w') Q n :;J :':~iJJ .-,:II.1"J (:...Jf...J .) J.. :f!~~ ,-; -TI ~C). ('jI'n .~::f =.r; ~~ .:::: ,.::; '\J ':," :,.,'.' ....;: "J " '" (.lj ~ f Ii < < 1 i (/l ." I I t fi' ll, J. ~. lS: .. . l 0 , i ~ ... . 5 Ii I ~ ~ It t t 2 0 .J- ~ ~ I i .:1f~ ~ K 1~ i 11 .. ~ ~ -. ll. Q II . :g .. "tI J ~ l ::a ~ ~. i ~ 0 ~ ..... ~ i i "' S-a. ~ !! "" (') !! ~ . :\." C , ~t ! om I ZZ 0 5i i !l, : 0 ~ -n;:$ " , ~ 0. "" ~ ~ [ !! ;0;; ~ n" 0 oz i ==~ ~ !! >)l I ~ 0 . miil n -:;:::. < , 5!. ~ c:~ a 0 ..... tJ)C " ~ ~ 0 mQ I 5' 0 e. ,< c !i' ~ 0 ~ ~ .. i i j .. ..,., l/ a . n :t:~ f ~ )10 5!. ~ 0 5!. ~ ~ ~ ~ .~ l!. tJ) i . :!/ -z..o. 0 ", ::J: " 0 .. . .g I -. m - . . n ii . () , . !l o . l ~ 0 .. --Co g ~ c> ll- ~ II yo. ' i1, .. 0 .. II. ~. i . - . . I !! 1 L6 l? ~ F- 0 . , i Ii !l ~ ~ ~ = 0 ~ . 2: 2: !! . 0. e- o . ;; -..:. " " ~ . co .. 'i 0 ? "'G .. !! .- E ~ :! ~ ~ 0 if 0 !!. 0 0 !!. g , " - - . ~ =:]ii 'ii " =I . _ .. a. ~ . II a..s:::>Q. 0 c: $1 " 00" .. ...z -:l~ !! " !:. U\= = c ~ . . . Ol1\O~O o~ < ~ ~ ; ;- :. l !!. s: N a 0 :. 0. ll. m ;r ii' .. !! . .. n ;- n 8. 5!. 0 .. !! III . ~ g~~~g~~~~~~~~~~~ee~Rg~ 5~~~~ 8~@ ~~i ~ ffi ~ggg~ ii ~ l~=m ~~m~~ ~a ~ m Po~ s= S a~~~' i~~~;i~i g ~f ~ ~~~~~j h I ~ ~~~i ~ ~ ~g !: ~ Sl~ ~ ; ~ ~~~i~~ Ei ~ ~ ~~~~~ ~ ~ i ~ 0 ~ eniiic:n~ m." 12 Iii 5!"'o~~ ~ ~ Ill, , ~ ~ ~ ~~ig~~, u ~ !ll ~jill ~ g ~ ~~ , ~! ~ ~~d:I' U i i ul ~ i ! :;1 ~ ~ h ~;: ~ _ 0 Ii! l:l 0 ril z ~ -< 'z~ ~ ~ ~~"5!~~ ~~ ~ I ~~E ~ ,gi - ! *~~~a~ i~:ll ~ i it ~ ~i ~ "'~>~oii~d ~ ill ~, ~ I~; o ~ o~ ~ ~ I ill 1 "il ' iii:ll:t. 5! en '0 II 00 g ." m ~ ::11 ~ g , g~ ~2 ~ ~ ~~ i :~l ~ 0 ~iil o~ g '< 5./:'l d ' ?Z:;! ~ 0 5 g ~ III "", c !B l :,0] ::oi 'O~ to1~ ~~~~~ ~~ ~~~"~ ~~~,~~~~~~~ I ~~~~~ c::;..>_~~~~H;g;g~ c:;..>-;gn6UU~lil~:' !!~! ~8n I ~~~ I!!~ !llllln i~ ~Iillli ~~ I ~ 111"\':1 0>~5"~oi ~znx~~~~~~~~oi >z~~~="''''~~sffi''' onl ill~~.., ~am~;,~~~~~ai ~a~~~~~a=mm~~ ~ l:l~5~ ~~ ~~~ggggg~ o~ggg;~~gp~~g ~~~ ~~ ~I~~~~@im ~~~a~!I~gg~lm 31~ g~ ~i~nI ~li~ !lli ~~~~~ j~' I~ s ~i ~~~' s Z<~~ ~~ ~, I~ a~~ ~ I"'~ ~d ~~ ~d ~ 111m m'-' 1'1ffi ". ~~ ' ~~ ~~ ~ s~ ~~ sg S ~ ~ ~ ;' ~ ~ -< -< ~ ~ ~ ~ , c c . ('-C" . . ' " lfJ)~"()"\ (I' , , .9b1->/9 ,I ~7~ '~r- ')' J1,'1- \:'\'o~) () C' :;.. ~r: i . !.!!: ,'/ ,. 'J.l (,', ...-, I I o "ll I . , ' .:;1 ,f' ," , personal effects, provided that Defendant is in the company of a law enforcement officer when such retrieval is nmde, Ia 3. Defendant is prohibited from having ANY CONTACT with the Plaintiff at any location, including, but not limited to, any contact nL the Plaintiff's school, business, or place of employment, Defendant is specifically ordered to stay away from the following locations for the duration of this Order: the plaintiff's residence located at 4719 B Charles Road, Mechanicsburg, Cumberland County, Pennsylvania, the residence of the plaintiff's son located at 1020 North Waterford Way, Mechanicsburg, Cumberland County, Pennsylvania, and any other permanent or temporary residence where Plaintiff may live. 1m 4. Defendant shall not contact the plaintiff by telephone or by any other means, including third parties. o 5, Custody of the minor children, * (DOB ) shall be as follows: [state to whom primary physical custody awarded; state terms of partial custody or visitation, if any](or see attached Custody Order). o 6. Defendant shall immediately turn over to the sheriff's Office, or to a local law enforcement agency for delivery to the Sheriff's Office, the followiog weapons used or threatened to be used by Defendant in an act of abuse against Plaintiff and/or the minor child/ren: o 7, Defendant is prohibited from possessing, transferring or acquiring any other weapons for the duration of this Order, Any weapons delivered to the sheriff under Paragraph 6 of this Order or under Paragraph 6 of the Temporary Order shall not be returned until further Order of Court, II 8. The following additional relief is granted as authorized by ~6108 of this Act: a, This Order shall remain in effect until modified or terminated by the Court and can be extended beyond its original expiration date if the Court finds that the defendant has committed another act of abuse or has engaged in a pattern or practice that indicates . continued risk of harm to the plaintiff. b, The defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by the plaintiff, c. The defendant is to refrain from harassing the plaintiff's relatives. d. The court costs and foes arc waived. o 9. Defendant is directed to pay temporary support for plaintiff and/or the minor child/ren as follows; the Bmount of $ per week, payable to the plaintiff in the form of a check or money order, by mai I pending the entry of an order by the Cumberland County Domestic Relations Office. The first payments is to commence within ten days upon entry of the Protection Order and each (week, month) thereafter, The defendant further agrees to provide health coverage to the spouse and/or minor child/ren, and will pay all of the unreimbursed medical expenses of the plaintiff and/or minor child/ren to the provider or to the plaintiff if she has paid for the medical treatment, and the defendant agrees to make or continue to make rent or mortgage payments on the residence of the plaintiff, This Order for support shall remain in effect until a final support order is entered by this Court. However, this Order shall lapse automatically if the Plaintiff does not file a complaint for support with the Court within fifteen days of the date of this Order. The amount of this temporary order does not necessarily reflect Defendant's correct support obligatioo, which shall be determined in accordance with the guidelines at the support hearing, Any adjustments in the final amount of support shall be credited, retroactive to this date, to the appropriate party, o 10. The costs of this action are waived as to the Plaintiff and imposed on Defendant, o 11. Defendant shall pay $ * to Plaintiff as compensation for Plaintiff's out-of-pocket losses, which are as follows; OR o 11, Plaintiff is graoted leave to present a petition, with appropriate notice to Defendant, to [insert the name of the judge or court to which the petition should be presented] * requesting recovery of out-of-pocket losses. The petition shall include an exhibit itemizing all claimed out-of-pocket losses, copies of all bills and estimates of repair, and an Order scheduling a hearing. No fee shall be required by the Prothonotary's office for the filing of this petition, o 12, BRADY INDICATOR ..~,. '~,"'-' . ",. .,.----.. -"~"'...~"-- . I, 0 The Plaintiff or protected personls) is a spouse, former SPOllse, a person who cohllbi tates or has cohabi ted wi th the Defendllnt, a Pllrent of a common chi ld, a chi ld of thllt person, or a chi Id of the Defendant, 2, 0 This Order is being entered after a hearing of which the Defendaot received actual notice and had an opportunity to be heard, J, 0 Paragraph I of this Order has been checked to restrain the Defendant from harassing, stalking, or threatening Plaintiff or protected personls), 4, 0 Defendant represents a credible threat to the physical safety of the Plaintiff or other protected person(s) OR 4, 0 The terms of this Order prohibit Defendant from using, attempting to use, or threateniog to use physical force against the Plaintiff or protected person that would reasonably be expected to cause bOdily injury, a 13, THIS ORDER SUPERSEDES a ANY PRIOR PFA ORDER AND o ANY PRIOR ORDER RELATING TO CHILD CUSTODY, a 14. All provisions of this Order shall expire in one year. NOTICE 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 YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS ORDER IS ENFORCEABLE IN ALL FIFTY ISO) 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 THIS 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. " '~' NOTICE TO LA\\' ENFORCEMENT OFFICIALS The police who have jurisdiction over the Plaintiff's residence OR any locat ion where a viol at ion of this Order occurs OR where the Defendant may be located, shall enforce this Order. An arrest for violation of Paragraphs I through 7 of this Order may be without warrant, based solely on probable cause, whether or not the violation is committed in the presence of the police, 23 Pa,C,S. g6113, Subsequent to an arrest, the pol ice officer shall seize all weapons used or threatened to be used during the violation of the Protection Order or during prior incidents of abuse, The Cumberland County Sheriff's Department shal I maintain possession of the weapons until further Order of this Court. When the Defendaot is placed under arrest for violation of the Order, the Defendant shall be taken to the appropriate authority or authorities before whom Defendant is to be arraigned, A "Complaint for Indirect Crimioal Contempt" shall then be completed and signed by the police officer OR the Plaintiff, Plaintiff's presence and signature are not required to file the complaint, If sufficient grounds for violation of this Order are alleged, the Defendant shall be arraigned, bond set aod both parties given notice of the date of the hearing, BY Tt:LJ:.UR J 'Wesley 01 This Order is entered pursuant to the consent of Plaintiff and Defendant: ~{f;J~1J'l1-Cj~/ ~a ~j!- Patty Spong Earh rt Samuel A, Earhart Plaintiff Defendant ~ /?J u C;;v . oan Carey ~ Attorney for Plaintiff LEGAL SERVICE, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 har 1 es Re Attorney .0 Defendant THE LAW OFFICES OF CHARLES RECTOR 1104 Fernwood Avenue Ste, 203 Camp Hill, PA 17011 (717) 761-8101 I~ (j~