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L^W OITICCS
MARLIN n. McCALEB
On August 10, 1998, at a Hearing on the PFA petition, Your
Honorable Court entered an Order awarding primary physical and
legal custody of Joshua A, Trice to Rosa and directing that
Defendant could have supervised visitation with Joshua, to be
arranged through the Carlisle YMCA, The Order also scheduled a
Custody Conciliation Conference with Hubert x. Gilroy, Esquire,
on October 2, 1998, at 10:00 o'clock, A.M..
Rosa and Joshua remained in the area and resided with
Laurette at Laurette's parents' house in New Kingstown. During
the eight-week period from August 10 through October 2,
Defendant never attempted the supervised visitation as provided
in the Order. His only contact with his son came from two
visits to the home of Laurette's parents while Joshua was there
and two visits in the parking lot at the Giant store, where
Rosa was then working, All four visits resulted from
happenstance, not prearrangement, and were quite perfunctory:
"Hello - How are you? - Gotta go,"
On October 2, 1998, Rosa returned to Philadelphia with
Joshua to attend to her mother, who had become ill.
The Conciliation Conference scheduled for October 2, 1998,
was rescheduled for October 22, 1998, at 10:30 o'clock, A.M..
That conference was attended by the Rosa and her undersigned
counsel, as well as by James K, Jones, Esquire, Counsel for
Defendant; Defendant did not attend. That Conference concluded
with the arrangement that Rosa would remain the primary
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THE SCHOOL DISTRICT OF PHILADELPHIA
EARLY PRIMARY PROGRESS REPORT
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(SEE REVERSE SIDE FOR ADDITlOtIAL INFORMATION OF IMPORTANCEI
REPORTING PERIOO, >>>>> 11 I ij 3 RCPOJIIlIlGPERlOO: >>>>> II 12'13
:1 ... ~ 'J;" SOCIAL STUDIES (Conllnued) EflGAGES III ACTIVITIES USING FIPlEMOTOR SKILLS
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. STU~ENT Nf'ME ROOM NUMBER: .
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3. Plln,. fl/.!".ENT COPY 2::0 11trOF.T F[F.:OD 4. GOLD. P,\HEtJT COpy 1ST flEPO;-H P~R!OD
______M"________.._________________.
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECrION FROM ABUSE
Laurellc M. Trice,
Plaintiff
Vincent G. Trice,
Defendant
NO. 98 - '-/ t.J..Y( CIVIL TERM
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following pages, you must appear at the hearing scheduled hcrein. If you fail to do so, the case may proceed
against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In
particular, you may be evicted from your residence and lose other important rights. , '
A hearing on the matter is scheduled for the IN!.., day of (//1 ~;Yl.).f 19 '?,f, at..:';":',!~., in
Courtroom ! at the Cumberland County Courthouse, Pennsylvani;l.
I
You MUST obey the Order that is attached until it is modi lied or terminated by the court after notice
and hearing, If you disobey this Order, the police may arrest you. Violation uf this Order may subject you
to a charge of indirect criminal contempt which is punishable by a line of up to $1,000.00 and/or up to six
months in jail under 23 Pa.C.S. S 6114. Violation may also subject you to prosecution and criminal penalties
under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. S 2265, this Order is enforceable
anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you
travel outside of the state and intentionally violate this Order, you may be subject to federal criminal
proceedings under the Violence Against Women Act, 18 U.S,C. s!i 2261-2262.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE THE RIGHT
TO HA VE 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
(717) 249-3166
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PLAINTIFF'S
EXHIBIT
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Prothonrltary
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Ex-spouse [J
Persons who Ii vc or have [X]
lived like spouses
Brother/Sister
Parent/Child
Parents of the samc ehildren
7, Have Plaintiff and Defendant been involved in any of thc following court actions? No
o Divon;~ 0 Custody 0 Support 0 Protection From Abusc_
8. Has the Defendant been involved in any criminal court action? Possibly. There may be a beneh
warrant out in Philadelphia for Defendant's arrest.
If you answered Yes, is the Defendant currently on probation? No
9. Plaintiff and Defendant are parents of the following minor child/ren:
Name(s) Ages(s) who reside at (list address unless confidential)
Jose1yn T. Trice 4 18-20 E. Main Street, New Kingstown, PA
10. If Plaintiff and Defendant are parents of any minor child/ren together, is there an existing court Order
regarding their custody? No
If you are now seeking an Order of child custody as part of this petition, list the following information:
Plaintiff & Defendant
Address, unless confidential
18-20 E. Main Street, New
Kingstown, PA 17072
122 Willow Mill Park Road
Mechanicsburg, PA 17055_
132 Willow Mill Park Road
Mechanicsburg, PA 17055
When
7/28/98-Present
Child's Name
Joselyne T. Trice
Person(s) child lived with
Plain ti ff
Plaintiff & Defendant
8/95-7/28/98
694-&95
(b) List any other persons who are known to have or claim a right to custody of eaeh child listed above. None -
II. The following other minor childlren presently live with Plaintiff:
Name(s) Age(s) Plaintiffs relationship to ehild/ren
12. The facts of the most recent inCident of abuse are as follows:
Approximate Date: 7/28/98 Approximate Time: morning and night Place: Marital home
Describe in detail what happened, including any physical or sexual abuse, threats, injury, incidents of
stalking medical treatment sought, and/or calls to law enforcement:
On Wednesday, July 28, 1998, the parties's child called the Defendant, Vincent Trice, a derogatory
name. Plaintiff said that children repeat words that they have heard. Defendant held a knife to the Plaintiff
L'lurette Trice's throat and said that people would call her dead. Plaintiff went to work, where Defendant
repeatedly called. On the night of July 28, Plaintiff took her daughter and step.son to the doctor's. Defendant
told her to be back by 8 p.m. or he would kill the Plainliff, her mother, her falher, the parties' daughter, and
the Defendant's son from a previous relationship.
13. If the Defendant has committed prior acts of abuse against Plaintiff or the minor child/ren, describe
these prior incidents, including any threats, injuries, or incidents of stalking, and indicate approximately
when such acts of abuse occurred:
a) Each day for the past several weeks, Defendant has pushed and shoved the Plaintiff, and punched
her on the arm, leaving big bruises, b) About once a week for the past two months, Defendant has become
angry at the children and has shaken them or thrown them on the bed, causing them to fear bodily injury. e)
In or about March and April, 1998, Defendant held a knife to Plaintiffs throat. d) Around Christmas, 1997,
Defendant locked Plaintiff in the bedroom for several hours on several occasions. e) In or about June, 1998,
Defendant held a loaded gun to Plaintiffs head and showed her the bullets in the chambers. On several
occasions in the last few months, he has brandished a gun at her. Defendant has told Plaintiff that if she tries
to lcave him that he will kill her, her parents, and the children.
14. List the weapon(s) that Defendant has used or threatened to use against Plaintiff or the minor child/ren:
Military-style knife with a long blade and a handgun.
15. Identify the police department or law enforcement agency in the area in which PlaintiffIives that should
be provided with a copy of the protection order:
Mechanicsburg and New Kingstown
16. There is an immediate and present danger of further abuse from the Defendant.
CHECK THE FOLLOWING BOXES ONLY IF THEY APPLY TO YOUR CASE AND PROVIDE
THE REQUESTED INFORMATION
[X] Plaintiff is asking the court to evict and exclude the Defendant from the following residence:
122 Willow Mill Park Road, Mcchanicsburg, PA 17055
[x] owned by (list owners, if known): Laurette M. Trice
o Defendant owes a duty of support to Plaintiff and/or the minor children.
o Plaintiff has suffered out-of-pocket financial losses as a result of the abuse described above. Those
losses are: loss of earnings on July 30 and July 31, 1998
FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY
ORDER, and AFrER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING (CHECK ALL
FORMS OF RELIEF REQUESTED):
[x] A. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/of minor childlren
in any place where Plaintiff may be found.
[x] B. Evict/exclude Defendant from Plaintiffs residence and prohibit Defendant from attempting to enter any
temporary or permanent residence of the Plaintiff.
o C. Require Defendant to provide Plaintiff and/or minor childlren with other suitable housing.
[x] D. Award Plaintiff tcmporary custody of thc minor child/rcn and placc thc following rcstrictions on contact
bctween Dcfcndant and child/rcn: Josclync T. Tricc. Award Plaintiff temporary sole physical custody
of the minor child.
[x] E. Prohibit Dcfendant from having any contact with Plaintiff and/or minor child/ren, either in person, by
telephone, or in writing, personally or through third persons, including but not limited to any contact
at Plaintiffs school,_busincss, or place of cmployment, except as the coux,t may find necessary with
respect to partial custody :md or visitation with the minor child/ren.
[x] F. Prohibit Defendant from having any contact with Plaintirrs relatives and Plaintiffs children listed in
this Petition, except as the court may tind nccessary with respect to partial custody and/or visitationltil
the minor child/ren.
[x] G. Ordcr the Dcfcndant to temporarily turn ovcr wcapons to the Sheriff for this County and prohibit
Dcfcndant from transferring, acquiring or possessing any such weapons for the duration of the Order.
o H, Order Defcndant to pay temporary support for Plaintiff and/or the minor child/ren, including medical
support and [] payment of the rcnt or mortgage on the residence.
[x] 1. Dircct Dcfendant to pay Plaintiff for thc reasonable financial losses suffered as the result of the abuse,
to be detcrmined atthc hcaring.
[x] 1. Ordcr Dcfcndant to pay the costs of this action, including filing and service fees.
[X] K. Ordcr Dcfcndant to pay Plaintiffs reasonablc attorney's fees.
o L. Ordcr the following additional rclicf, not listed above:
[x]M. Grant such relief as thc court deems appropriate.
[x] N. Order the policc or othcr law enforcemcnt agcncy to serve the Defendant with a copy of this Petition,
any Order issued, and the Ordcr for Hcaring. The Plaintiff will inform the designated authority of yu
addrcsscs, othcr thank Dcfcndant's rcsidencc, whcre Defendant can pe Sjrved.
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Donald Marritz, Supervising Attorney
Family L1W Clinic
45 North Pitt Street
Carlisle, Pa. 17013
(717) 243-2968
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[] On , Defendant may enter the residence to retrieve his/her clothing and other personal
effects, provided that Defendant is in the company of a law enforcement officer when such retrieval is
made.
y.. [x] 3. Except as provided in Paragraph 5 of this Order, Defendant is prohibited from having ANY CONTACT
with the Plaintiff at any location, including but not limited to any contact at 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.
Plaintiff's parents' house: 18-20 E. Main Street, New Kingstown, PA 17072
Plaintiff's place of employment: Health South, 4950 Wilson Lane, Mechanicsburg, PA 17055
Plaintiff's place of employment: Health South, 1706 Lancaster Lane, Mechanicsburg, PA 17055
Plaintiff's school: HACC, I HACC Drive, Harrisburg, PA 17027
Plaintiff's school: Messiah, Grantham Road, Grantham, PA
[x] 4. Except as provided in Paragraph 5 of this Order, Defendant shall not contact the Plaintiff by telephone
or by any other means, including through third persons.
[] 5. Custody of the minor children shall be as follows:
[x] 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 following weapons used or threatened to be used by Defendant in
an act of abuse against Plaintiff and/or the minor child/ren.
Military-style knife with long blade and handgun
f. [x] 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.
[] 8. The following additional relief is granted as authorized by ~ 6108 of the Act:
[] 9. Defendant is directed to pay temporary support for: [insert the names of the persons for whom support
is to be paid] as follows: [insert amount, frequency and other terms and conditions of the support order].
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 obligation, 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.
-
[x] 10. The costs of this action arc waived as to the Plaintiff .,nd imposed on Defendant.
[] II. [] Defendant shall pay $ to Plaintiff as compensation for Plaintiff's out-of-pocket losses, which arc
as follows:
[] 12. BRADY INDICATOR.
[] I. The Plaintiff or protected person(s) is a spouse, former spouse, a person who cohabitates or has
cohabitated with the Defendant, a parent of a common child, a child of that person, or a child of the
Defendant.
[] 2. This order is being entered after a hearing of which the Defendant received actual notice and had an
opportunity to be heard.
[] 3. Paragraph I of this Order has been checked to restrain the Defendant from harassing, stalking, or
threatening Plaintiff or protected person(s).
[] 4. Defendant represents a credible threat to the physical safety of the Plaintiff or other protected person(s)
OR
D The terms of this Order prohibit Defendant from using, attempting to use, or threatening to use physical
force against the Plaintiff or protected person that would reasonably be expected to cause bodily injury.
[x] 13. THIS ORDER SUPERSEDES [x] ANY PRIOR PFA ORDER AND [] ANY PRIOR ORDER
RELATING TO CHILD CUSTODY.
14. All provisions of this order shall expire in one year, on August 10, 1999.
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 $1,000.00 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, U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE
VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. ~~ 2261-2262. 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 MAYBE SUBJECT TO FEDERAL PROSECUTION AND
PENALTIES UNDER THE "BRADY" PROVISIONS OFTHE GUN CONTROL ACT, 18 U.S.C. ~~ 922(G),
FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION.
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Laurette M. Trice,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
v.
Vincent G. Trice,
Defendant
NO. 98 - '-I '-/)7 CIVIL TERM
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT, If you wish to defend against the claims set forth in the
following pages, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed
against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In
particular, you may be evicted from your residence and lose other import.ant rights.,
A hearing on the matter is scheduled for the I(t';~, day of (/ /! /;"".,c7 19 ';.s' , at,:':":',!fu., in
Courtroom I at the Cumberland County Courthouse, Pennsylvani;r.
I
You MUST obey the Order that is attached until it is modified or terminated by the court after notice
and hearing. If you disobey this Order, the police may arrest you. Violation uf 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. 9 6114. Violation may also subject you to prosecution and criminal penalties
under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. 9 2265, this Order is enforceable
anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you
travel outside of the state and intentionally violate this Order, you may be sub;ect to ferlera! climinal
proceedings under the Violence Against Women Act, 18 U.S.C. 992261-2262.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE THE RIGHT
TO HA VE 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
(717) 249-3166
PLAINTIFF'S
EXHIBIT
~!~,~L__.~
T'''''~ (,(..."". (-~')'. "'-CORD
~ ~1~~n:.';, J'..".l~" ': ,"'~il ~~~, ."'\c.
m T(:s1i,lI(my 1NhGlaof. I here until S6t my hand
a',(l t~." ."'\1' "I' "0,'" {"Jl"~ -t "al'I:"J.~ Pa
l. JIG """1" v ..... lot v' .H l a V" 1;;.t.loJj _'
This ~~ day A ~~" 19 (~
_ \ ( ;,Q { '( ,(\I\(y\', ( ,')I:Y/
Prothonotary
Laurette M. Trice,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
, "l
, I
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,
,;
Vincent G. Trice,
Defendant
NO, 98 - iN..!? CIVIL TERM
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiffs name is: Laurette M. Trice
2. I am filing this Petition on behalf of [x] Myself and/or [x] Another Person.
If you checked" myself," please answer all questions referring to yourself as "Plaintiff." If you checked
"another person, H please answer all questions referring to that person as the "Plaintiff, and provide your
address here, unless confidential:
If you checked H Another Person, H indicate your relationship with Plaintiff:
[x]parent of minor Plaintiff(s) Dapplicant for appointment as guardian ad litem of minor Plaintiff(s)
Dadult household member with minor Plaintiff(s) Dcourt appointed guardian of incompetent Plaintiff(s)
3. Name(s) of ALL person(s), including Plaintiff and minor children, who seek protection from abuse:
Laurette M. Trice, Joselyne T. Trice, and Joshua A. Trice
4. 0 Plaintiffs address is confidential or
[x] Plaintiffs address is: 18-20 E. Main Street, New Kingstown, PA 17072
5. Defendant is believed to live at the following address:
122 Willow Mill Park Road, Mechanicsburg, PA 17055
Defendant's Social Security Number (if known) is: 204-50-1725
Defendant's date of birth is: 4/4/61
Defendant's place of employment is: Morrison-Knudson, Kost Road, New Kingstown, FA 17072
o Check here if Defendant is 17 years old or younger.
6. Indicate the relationship between Plaintiff and Defendant.
[x]Spouse DCurrent or former sexual! DOther relationship by blood or
intimate partner marriage:
o
o
o
Ex-spouse 0
Persons who live or have [Xl
lived like spouses
Brother/Sister
ParentlChild
Parents of the same children
7. Have Plaintiff and Defendant been involved in any of the following court actions? No
o Divorc~ 0 Custody 0 Support 0 Proteetion From Abuse_
8. Has the Defendant been involved in any criminal court action? Possibly. There may be a bench
warrant out in Philadelphia for Defendant's arrest.
If you answered Yes, is the Defendant currently on probation? No
9. Plaintiff and Defendant are parents of the following minor child/ren:
Name(s) Ages(s) who reside at (list address unless confidential)
Joselyn T. Trice 4 18-20 E. Main Street, New Kingstown, PA
10. If Plaintiff and Defendant are parents of any minor child/ren together, is there an existing court Order
regarding their custody? No
If you are now seeking an Order of child custody as part of this petition, list the following information:
Plaintiff & Defendant
Address, unless confidential
18-20 E. Main Street, New
Kingstown, PA 17072
122 Wil10w Mil1 Park Road
Mechanicsburg, PA 17055_
132 Wil10w Mil1 Park Road
Mechanicsburg, PA 17055
When
7/28/98-Present
Child's Name
Joselyne T. Trice
Person(s) child lived with
Plaintiff
Plaintiff & Defendant
8/95-7128/98
@l..lI;95
(b) List any other persons who are known to have or claim a right to custody of each child listed above.None-
II. The following other minor child/ren presently live with Plaintiff:
Name(s) Age(s) Plaintiffs relationship to child/ren
12. The facts of the most recent inCident of abuse are as follows:
Approximate Date: 7/28/98 Approximate Time: morning and ni!':ht Place: Marital home
Describe in detail what happened, including any physical or sexual abuse, threats, injury, incidents of
stalking medical treatment sought, and/or calls to law enforcement:
On Wednesday, July 28, 1998, the parties's child called the Defendant, Vincent Trice, a derogatory
name. Plaintiff said that children repeat words that they have heard. Defendant held a knife to the Plaintiff
Laurette Trice's throat and said that people would call her dead. Plaintiff went to work, where Defendant
repeatedly called. On the night of July 28, Plaintiff took her daughter and step-son to the doctor's. Defendant
told her to be back by 8 p.m. or he would kill the Plaintiff, her mother, her father, the parties' daughter, and
the Defendant's son from a previous relationship.
13. If the Defendant has committed prior acts of abuse against Plaintiff or the minor child/ren, describe
these prior incidents, including any threats, injuries, or incidents of stalking, and indieate approximately
when such acts of abuse occurred:
a) Each day for the past several weeks, Defendant has pushed and shoved the Plaintiff, and punched
her on the arm, leaving big bruises. b) About once a week for the past two months, Defendant has become
angry at the childrel!, and has shaken them or thrown them on the bed, cau~Jng them to fear bodily injury. c)
In or about March and April, 1998, Defendant held a knife to Plaintiff's throat. d) Around Christmas, 1997,
Defendant locked Plaintiff in the bedroom for several hours on several occasions. e) In or about June, 1998,
Defendant held a loaded gun to Plaintiff's head and showed her the bullets in the chambers. On several
occasions in the last few months, he has brandished a gun at her. Defendant has told Plaintiff that if she tries
to leave him that he will kill her, her parents, and the children.
14. List the weapon(s) that Defendant has used or threatened to use against Plaintiff or the minor child/ren:
Military-style knife with a long blade and a handgun.
15. Identify the police department or law enforcement agency in the area in which Plaintifflives that should
be provided with a copy of the protection order:
Mechanicsburg and New Kingstown
16. There is an immediate and present danger of further abuse from the Defendant.
CHECK THE FOLLOWING BOXES ONLY IF THEY APPLY TO YOUR CASE AND PROVIDE
THE REQUESTED INFORMATION
[X] Plaintiff is asking the court to evict and exclude the Defendant from the following residence:
122 Willow Mill Park Road, Mechanicsburg, PA 17055
[x] owned by (list owners, if known): Laurette M. Trice
o Defendant owes a duty of support to Plaintiff and/or the minor children.
o Plaintiff has suffered out-of-pocket financial losses as a result of the abuse described above. Those
losses are: loss of earnings on July 30 and July 31, 1998
FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY
ORDER, and AFfER HEARING, A FINAL ORDER THA TWOULD DO THE FOLLOWING (CHECK ALL
FORMS OF RELIEF REQUESTED):
'[x] A. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/of minor child/ren
in any place where Plaintiff may be found. '
[x) B. Evict/exclude Defendant from Plaintiff's residence and prohibit Defendant from attempting to enter any
temporary or permanent residence of the Plaintiff.
o C. Require Defendant to provide Plaintiff and/or minor child/ren with other suitable housing.
j:"" !.7'.70r~.-.r""-'r'"t"''''''""::,,,: ..~; ~..' ,','r..~ .-.-.-....-..-,...'-.. ; _.-,.-:............-.....-.....-;~-........~._.....~....,.-- ~.:r..'I
Is, 307 (~).EI!)) SOSN: 44!1;r}1
I THE SCHOOL DISTRICT OF PHILADELPHIA YEAR ENDING: ? 7
II TEACHERS' REPORT CARD COMMENTS JUNE 19,
STU~ENT N{lME: ROOM NUMBER:
'~' , \Josnu C( /rICe. /03
, " ,TEAC NAME: ,--j SCHOOL: J
".'CO'" () ntl ) /7 CIS 0 tS/14/
I,," ., FIRST REPORT: JoshUQ /5 c~ v<le.:/ b(~ hCi
i ho ff[ chi lei. He is. Ct I /,lD y.{ UJ II I Ulf) To
~ pc=< ('i. Ie IpU-JI? JO:,ALAj. (;{dd:. wO'(J~~r-f!uL !~eus
I ClYld I nforw/c,d-,Dl/ Ie), DU(' ell <.l_U~~/vd'" ," ,
I ,J:dll(C( I~ etO/lllj }1/CQ 1)/01'1-:.,'
I NedvL(lcI COIlf/f1uE. i)r(~(c.i,CtnCJ},h,::... 'Je-f"fcfI:;'
! C( nJnLl /f)bers. He /1 e.c,d.f to Wof ~ 0 'I
! !\e'i:dil('~ C~ n d .speect) Wh,G-h We IUliI c dl':"OccrL
,~ ' SECOND REPORT:
l'~;:O J~hu~ Gohtih'l1eS to be-
"', CUI lA.sset ~o our c..../Clrs. He. cdwu/s
, hos SoJ'l1e.... thl/1j Interestit1j to .sax' ,
50> He tc:.stt'ul Vr;ry we.) Ion 0. / I of his:
-S:kilk. fie -s,h6L<1c! I:ecp reaclint/ CA )1({ \'
IAJorl:"-/tJfA arc1. He workS utvq fo.rtc,fj"
'V 1'.-1 >at'" t" .I nr. ::::C ~i7 ' Fe/sec!' ::r /,1.10/,(,1
THIRD REPO T: like tD ,See q 117Tle e.s:.S 'CI :~'?}
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.~. 1, WHITE. SCHOOL COPY 2, YELLOW, P,\AENT COPY 3RO f1EPORT PERIOD'
:~~_,j}} , 3, PINK, Pt.RENT COPY 2ND REPORT PEf1IOD 4, GOLD, PARENT COPY 1ST REPOHT PERIOD
-----_._----------.._--._-~------_._.
, PLAINTIFF'S
, EXHIBIT
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ILl EARL Y PRIMARY PROGRESS REPORT p
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(SEE REVERSE SIDE FOR ADDITIONAL INFORMATION OF IMPORTANCEI
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I " "SOCIAL STUDIES (Continued) EUOAOES IN ACTIVITIES USING FINE MOTOR SKILLS
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WHEREFORE, petitioner respectfully requests this Court to
grant petitioner's request for permission to intervene.
Respectfully,
FAMILY LAW CLINIC
45 North pitt street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
VERIFICATION
I verify that the statements made in this Petition for
Intervention of Mother are true and correct to the best of my
personal knowledge and belief. I understand that false statements
herein are made subject to the penalties of 18 Pa.C.S. 4904,
relating to unsworn falsification to authorities.
Date: August 10, 1998
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~osa M. Gutierrez
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Laurette M. Trice,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Rosa M. Gutierrez,
Intervenor
v.
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE, CUSTODY
Vincent G. Trice,
Defendant
NO. 98 - 4428
CIVIL TERM
COURT ORDER
111'i I
AND NOW, this 10th day of August, upon consideration of the petition to intervene and upon agreement of
the parties, being advised by their respective counsel, it is hereby ordered that:
I. Laurette M. Trice shall have primary physical and legal custody of Joselyne T. Trice.
2. Rosa M. Gutierrez shall have primary physical and legal custody of Joshua A. Trice.
3. Vincent G. Trice shall have supervised visitation with Joselyne T. Trice and Joshua A. Trice to be arranged
through the Carlisle YWCA.
4. The provisions of this Order relating to Joshua Trice shall supersede all prior orders of the Court of
Common Pleaj..of Philadelphia County docked as Case ID=009609043.
5. This Order is intended to be temporary.
6. It is hereby directed that the parties and their respective counsel appear before, \\;b;r\-)(.Gilrll-j the
-\1-<,'1"'1'1,;)'-"1 ..
conciliator, atD:\lb:r"It~Cumberland County Courthouse, on the d day of Cld-, , 1998, at 10 q,m., for a Pre-Hearing
~c><Yn
Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot
be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary order. Either
party may bring the child(ren) who is the subject of this custody action to the conference, but the child/children's
attendance is not mandatory. Failure to appear at the conference may provide grounds for entry of a temporary or
permanent order.
, J 'Wesley 01
i
AMERICANS WITH DI ABILITIES 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.
'??i2~
7-g/.4jcS
Laurette M. Trice,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
Vincent G. Trice,
Defendant
NO. 98 - t/ '/)7 CIVIL TERM
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following pages, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed
against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In
particular, you may be evicted from your residence and lose other important rights.
A hearing on the matter is scheduled for the /(}/;{, day of f? /(;'J/t.)~/' 19 '?f, atv'1:,Mfu., in
Courtroom ;I at the Cumberland County Courthouse, Pennsylvani ~~
I
You MUST obey the Order that is attached until it is modified or terminated by the court after notice
and hearing. If you disobey this Order, the police may 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 subject 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 of Puerto Rico. If you
travel outside of the state and intentionally violate this Order, you may be subject to federal criminal
proceedings under the Violence Against Women Act, 18 U.S.C. ~~ 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
(717) 249-3166
o
o
o
Ex-spouse 0
Persons who live or have [Xl
lived like spouses
Brother/Sister
Parent/Child
Parents of the same children
7. Have Plaintiff and Defendant been involved in any of the following court actions? No
o Divorce 0 Custody 0 Support 0 Protection From Abuse
8. Has the Defendant been involved in any criminal court action? Possibly. There may be a bench
warrant out in Philadelphia for Defendant's arrest.
If you answered Yes, is the Defendant currently on probation? No
9. Plaintiff and Defendant are parents of the fo\1owing minor child/ren:
Name(s) Ages(s) who reside at (list address unless confidential)
Joselyn T. Trice 4 18-20 E. Main Street, New Kingstown, PA
10. If Plaintiff and Defendant are parents of any minor child/ren together, is there an existing court Order
regarding their custody? No
If you are now seeking an Order of child custody as part of this petition, list the fo\1owing information:
Plaintiff & Defendant
Address, unless confidential
18-20 E. Main Street, New
Kingstown, PA 17072
122 Willow Mill Park Road
Mechanicsburg, PA 17055_
132 Willow Mill Park Road
Mechanicsburg, PA 17055
When
7/2B/98-Present
Child's Name
Joselyne T. Trice
Person(s) child lived with
Plaintiff
Plaintiff & Defendant
8/95-7/28/98
~
(b) List any other persons who are known to have or claim a right to custody of each child listed above. None -
11. The fo\1owing other minor child/ren presently live with Plaintiff:
Name(s) Age(s) Plaintifrs relationship to child/ren
12. The facts of the most recent inCident of abuse are as fo\1ows:
Approximate Date: 7/28/98 Approximate Time: morning and nit>:ht Place: Marital home
Describe in detail what happened, including any physical or sexual abuse, threats, injury, incidents of
stalking medical treatment sought, and/or calls to law enforcement:
On Wr.dnesday, July 28, 1998, the parties's child called the Defendant, Vincent Trice, a derogatory
name. Plaintiff said that children repeat words that they have heard. Defendant held a knife to the Plaintiff
Laurette Trice's throat and said that people would call her dead. Plaintiff went to work, where Defendant
repeatedly called. On the night of July 28, Plaintiff took her daughter and step-son to the doctor's. Defendant
told her to be back by 8 p.m. or he would kill the Plaintiff, her mother, her father, the parties' daughter, and
the Defendant's son from a previous relationship.
13. If the Defendant has committed prior acts of abuse against Plaintiff or the minor child/ren, describe
these prior incidents, including any threats, injuries, or incidents of stalking, and indicate approximately
when such acts of abuse occurred:
a) Each day for the past several weeks, Defendant has pushed and shoved the Plaintiff, and punched
her on the arm, leaving big bruises. b) About once a week for the past two months, Defendant has become
angry at the children and has shaken them or thrown them on the bed, causing them to fear bodily injury. c)
In or about March and April, 1998, Defendant held a knife to Plaintiffs throat. d) Around Christmas, 1997,
Defendant locked Plaintiff in the bedroom for several hours on several occasions. e) In or about June, 1998,
Defendant held a loaded gun to Plaintiffs head and showed her the bullets in the chambers. On several
occasions in the last few months, he has brandished a gun at her. Defendant has told Plaintiff that if she tries
to leave him that he will kill her, her parents, and the children.
14. List the weapon(s) that Defendant has used or threatened to use against Plaintiff or the minor child/ren:
Military-style knife with a long blade and a handgun.
15. Identify the police department or law enforcement agency in the area in which Plaintiff lives that should
be provided with a copy of the protection order:
Mechanicsburg and New Kingstown
16. There is an immediate and present danger of further abuse from the Defendant.
CHECK THE FOLLOWING BOXES ONLY IF THEY APPLY TO YOUR CASE AND PROVIDE
THE REQUESTED INFORMATION
[X] Plaintiff is asking the court to evict and exclude the Defendant from the following residence:
122 Willow Mill Park Road, Mechanicsburg, PA 17055
[xl owned by (list owners, if known): Laurette M. Trice
o Defendant owes a duty of support to Plaintiff and/or the minor children.
o Plaintiff has suffered out-of-pocket financial losses as a result of the abuse described above. Those
losses are: loss of earnings on July 30 and July 31, 1998
FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY
ORDER, and AFrER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING (CHECK ALL
FORMS OF RELIEF REQUESTED):
[xl A. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/of minor child/ren
in any place where Plaintiff may be found.
[xl B. Evict/exclude Defendant from Plaintiffs residence and prohibit Defendant from attempting to enter any
temporary or permanent residence of the Plaintiff.
o C. Require Defendant to provide Plaintiff and/or minor child/ren with other suitable housing.
[xl D. Award Plaintiff temporary custody of the minor child/ren and place the following restrictions on contact
between Defendant and child/ren: Joselyne T. Trice. Award Plaintiff temporary sole physical custody
of the minor child.
[xl E. Prohibit Defendant from having any contact with Plaintiff and/or minor child/ren, either in person, by
telephone, or in writing, personally or through third persons, including but not limited to any contact
at Plaintifrs school, business, or place of employment, except as the court may find necessary with
respect to partial custody and or visitation with the minor child/ren.
[xl F. Prohibit Defendant from having any contact with Plaintifrs relatives and Plaintifrs children listed in
this Petition, except as the court may tind necessary with respect to partial custody and/or visitationitW
the minor child/ren.
[xl G. Order the Defendant to temporarily turn over weapons to the Sheriff for this County and prohibit
Defendant from transferring, acquiring or possessing any such weapons for the duration of the Order.
[] H. Order Defendant to pay temporary support for Plaintiff and/or the minor child/ren, including medical
support and [] payment of the rent or mortgage on the residence.
[xl I. Direct Defendant to pay Plaintiff for the reasonable financial losses suffered as the result of the abuse,
to be determined at the hearing.
[xl J. Order Defendant to pay the costs of this action, including filing and service fees.
[X] K. Order Defendant to pay Plaintirr s reasonable attorney's fees.
[] L. Order the following additional relief, not listed above:
[xl M. Grant such relief as the court deems appropriate.
[xl N. Order the police or other law enforcement agency to serve the Defendant with a copy of this Petition,
any Order issued, and the Order for Hearing. The Plaintiff will inform the designated authority of ya
addresses, other thank Defendant's residence, where Defendant can be~s rved.
Don d Marri. , Supervising Attorney
Family Law Clinic
45 North Pitt Street
Carlisle, Pa. 17013
(717) 243-2968
specifically ordcred to stay away from the following locations for the duration of this Order:
Plaintifrs parents' house: 18-20 E. Main Street, New Kingstown, PA 17072
Plaintifrs place of employment: Health South, 4950 Wilson Lane, Mechanicsburg, PA 17055
Plaintifrs place of employment.: Health South, 1706 Lancaster Lane, Mechanicsburg, PA 17055
Plaintifrs school: HACC, 1 HACC Drive, Harrisburg, PA 17027
Plaintifrs school: Messiah, Grantham Road, Grantham, PA
[xl 4. Except for such contact with the minor child/ren as may be permitted under Paragraph 5 of this Order,
Defendant shall not contact Plaintiff by telephone or by any other means, including through third
persons.
[xl 5. Pending the outcome of the final hearing in this matter, Plaintiff is awarded temporary custody of the
following minor child/ren: Joselyne T. Trice
Until the final hearing, all contact between Defendant and the child/ren shall be limited to the
following: None
The local law enforcement agency in the jurisdiction where the child/ren are located shall ensure that the
child/ren are placed in the care and control of the Plaintiff in accordance with the terms of this Order.
[xl 6. Defendant shall immediately relinquish the following weapons to the Sherifrs Office or a designated
local law enforcement agency for delivery to the Sherifrs office:
Military-style knife with long blade and handgun
Defendant is prohibited from possessing, transferring or acquiring any other weapons for the duration
of this order.
o 7. The following additional relief is granted:
[xl 8. A certified copy of this Order shall be provided to the police department where Plaintiff resides and:Jll
other agency specified hereafter:
o 9. THIS ORDER SUPERSEDES [ l ANY PRIOR PPA ORDER AND [ l ANY PRIOR ORDER
RELATING TO CHILD CUSTODY,
[xl 10. THIS ORDER APPLIES IMMEDIATELY TO DEPENDANT AND SHALL REMAIN IN EPFECT
UNTIL MODlPIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING.
NOTICE TO TilE 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 Ps.C.S ~ 6114.
Consent of the Plaintiff to Defendant return to the residence shall not validate 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 penalties under the Violence Against Women
Act, 18 U.S.C. ~~ 2261-2262.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the police who have jurisdiction over the plaintiffs residence OR any
location 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 not the violation is committed in the presence of law enforcement.
Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be
used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be
delivered to the Sheriffs office of the county which issued this Order, which office shall maintain possession
of the weapons until further Order of this court, unless the weapon/s are evidence of a crime, in which case,
they shall remain with the law enforcement agency whose officer made the arrest.
BY THE COURT:
!Jh
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Dated: July 31, 1998
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ROSA M. GUTIERREZ,
Intervenor
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 98-4428 CIVIL TERM
v.
CIVIL ACTION--LAW
VINCENT G. TRICE,
Defendant
CUSTODY
PETITION FOR LEAVE TO WITHDRAW AS COUNSEL
1. Petitioner is James K. Jones, Esquire, hereinafter
"Counsel."
2. Respondent is Vincent G. Trice, Defendant in the above
matter:
3. On or about August 10, 1998, Counsel entered his appear-
ance on behalf of Defendant in response to a Protection From
Abuse petition filed by his wife Laurette M. Trice.
4. Prior to entering his appearance, Counsel forwarded a
letter dated August 4, 1999, establishing the fees to be paid by
Defendant for services rendered by Counsel, a copy of which is
attached hereto as Exhibit "A."
5. Including proper credits, Respondent has a balance of
$175.25 which has accumulated since the time Counsel entered his
appearance. Respondent has promised to pay the outstanding
balance but has made no payments since August 10, 1998, as set
forth in the monthly statements from August, 1998 through the
present as attached hereto as Exhibit "B."
6. These lack of payments is a serious breach of the agree-
ment between Counsel and Respondent and justifies granting Coun-
LAW OFFICE' OF
JAMES K. JONES, ESQUIRE
7 IRVINE ROW
CARLISLE, PA 17013-3019
(717)240-0296
Statement as of March 1, 1999
vincent G. Trice
122 Willow Mill Park Rd,
Mechanicsburg, Pennsylvania 17055
RE: Domestic issues
DATE
DESCRIPTION OF SERVICES RENDERED HOURS
,
AMOUNT
----------
Prior Balance:
213.25
----------
----------
BALANCE DUE AND OWING $
213.25
Statement reflects transactions through 02/28/99
Balance is past due. please pay promptly.
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Laurette M. Trice,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
Rosa M. Gutierrez,
Intervenor, Petitioner
v.
CIVIL ACTION--LAW IN
PROTECTION FROM ABUSE
Vincent G. Trice,
Defendant, Respondent
No. 98-4428
Civil Term
COURT ORDER
AND NOW, this
\ ~tt. of August, 1998, upon consideration of
the Petition To Confirm Custody Order, said Petition is granted.