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HomeMy WebLinkAbout98-07320 -a () '" ~ \) ~ \l ~ ~ l'\ It ~ :1 ~ '.t ~ t ~ :~ - .:5 ~ <::; . ~ o On _ al _.m" Delendant may enler the residence to retrieve his/her clothing and other personal ellects. provided that Dclendant is in the company ofa law enforcement oflicer when sllch retrieval is nwde. (8) 3. Dclendant is prohibited Irom having ANY CONTACT with the Plaintiffat any location, including, but not limited to, any contact at the Plaintill's residence or her place of employment. Defendant is specifically ordered to stay away frOln the following locations for the duration of this Order: Plaintiff's residence: 100 Rosemont Avenue, New Cumberland, Cnlllberland Connty, I'ennsylvllnia Plaintiff's Illace or elllplovment: PA Liqnor Control Board, Capitol and Boas Streets, lIarrisbnrg, Danphin Connty, I'ennsylvania. (8) 4, Defendant shall not contact the Plaintiffby telephone or by any other means, including third parties. o 5. Custody of the minor children, [names oCthe children subject to the provision of this paragraph] shall be as f()lIows: _ o 6. Dclendant shall immediately tUIll over to the Sherin's Ollice. or to a local law enforcement agency for delivery to the Sheritl's Ollice, the ti.lllowing 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 wcapons delivered to the sherin'under Paragraph 6 of this Order or under Paragraph 6 of the Temporary Order shall not be relurned urliil further Order of Court. (8) 8. The following additional relief is granted as authOlized by ~6108 of this Act: .... ..... . . This Order shall remain in clrect until modified or terminatl:d by the Court and can be extended beyond its original expiration date if the Court linds that Defendant has commilted an act of abuse or has engaged in a pattem or practice that indicates risk ofhaml to Plaintiff The Dclendant is enjoined from damaging or destroying any property owned by Plaintin' The Defendant is to refrain fiOln harassing I'laintitrs relatives o <) Defendant is directed to pay temporary support Jin ti,lIo\\s Order for support shall remain in enecluntil a final Sllpport order is enlered hy this Cntll1 I hlllel cr. this Order shall lapse . . . . -.' ~ ., ~ . ,\ ,. , '~' , . . .' ',', :': .' - I .....::... " .', .,., . "" . . automatically ifPlaintilr docs not liIe a cOl11plaint fill' SUPP0l1 with the Court within til1cen (15) days of the dale of this Order. The amount of this Wl11porary order docs nolnecessarily reflect Defendant's correct support obligation, which shall be determined in accordance with the guidelines at the support hearing. Any adjustments in the tinal amoLlnt of support shall be credited, retroactive to this date, to the appropriate party. o 10. The costs of this action arc waived as to Plaintifrand imposed on Defendant. ", . 'A;'",' -. I' ,- , '. . -."', -" .'-'.' ',; ,.' " . o II. Defendant shall pay $_ to Plaintifrascompensation for Plaintifl's out-of:pocketlosses, which are as follows: OR o Plaintitl'is granted leave to present a petition, with appropriate notice to Defendant, to _ 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 sball be required by tbe Prothonotary's ollice filr the filing of this petition. o ]2. BRADY INDICATOR o I. The I'laintill' or protected person/s is a spouse, tanner spouse, a person who cohabitates or has cohabited with Defcndant. a parent of a COl111llon child, a child of that person, or a child of Defendant. o 1 This Order is being entered aller a hearing of which Defendant received actual notice and had an opportunity to be heard. o 3. Paragraph I of this Order has been checked to restrain Defendant fi.otll harassing, stalking, or thrC3tening I'laintifr or protected person/s. o 4. Defcndant represents a credible threalto the physical safety ofPlaintitl'orother protected person/s OR o The terms of this Order prohibit Defendant thll11 using, attempting to use, or threatening to use physical tillTe against Plaintifr or protected person that would reasonably be expected to cause bodily injury (8) 13 TillS ORDER Sl!PERCEDES (8) ANY PRIOR PFA ORDER and o ANY PRIOR ORDER RELATIN<i TO elllI.I) ('l'STODY (8) 14 All provisions of this Onlcr sl131I espilc onl' ycar thll11 till' date this Order is entered. .'\. NOTICE_TO THE DEFENDANT VIOLATION OF TI-IIS ORDER MA Y 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, U.S, TERRITORIES, AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACTION, 18 U,S.C. *2265. IFYOU TRAVELOUTSIDEOFTHESTATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAYBE 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 LAW ENFORCEMENT OFFICIALS The police who have jurisdiction over Plaintifl's residence OR any location where a violation of this Order occurs OR where Defendant may he located, shall enforce this Order. An arrest for violation of Paragraphs I through 7 of this Order may be without warrant, basl.'Ii solely on probable cause, whether or not the violation is wl11milled in the presence of the police. 23 Pa.C.S. ~6113 Subsequent \0 an arrest, the police of1icer shall seiz(~ all weapons used or threatened to be used during the violation of the Protection Order or during prior incidents of abuse. The Cumberland County Sherifl's Depatlment shall maintain possession of the we.apons until fimher Order of this Court When Defendant is placed under arrc~st II)r violation of the Order, Defendant shall be taken to the appropriate authnrity or authorities hetl)re Ivhmll Defendant is to be arraigned A "Complaint for Indirect Criminal Contempt" shall then he completed and signl'd by the police of1icer OR Plaintiff, Plaintifl's prescnc,e and signature arc lwt required to file the complaint '_'. . , " ..' ,'j' . .', .' ,. i <.' .' " . '" j . - ' ,,j v '-+ ~.-...- " ,-) .J- \).... ',. 3';.:. ., , ., I'J ... / ,0", " ~ ,- -~ ,,,,, \' " :\ "". ) U- 0 Cl .", ""'::' "- 6 0 .,~; <1 - ..' d ". '- (-"- I ,S -.11 ,~ , .'j ,j) ? j (, '-"':; 7: ~ --J ',~ "'.\ 'J 'rt" <) c " t' '......" ~ _-...I , t. ~ }-i; I': " ;, I:- '.J I' -2-) , ~..,'" <, ' ,', ",/ ._. ' ','1, .",' > _.~'.;"'~-"" _~' .~, , ._,'. : ' . ,~ --~ -~.",c,'. ."., , , \ .' . , ',:\ .":r '.r" " LEGAl. sERVICEs, I~. >" ':I..SIRVlNE ROW' .:..,," ,cAAUSLE, PENNSYLVANIA '70.1a ,: ...'.. (7!71243-9400: ."'.., . ' .i Flix17171 ~ ',., .r-' ..... " Wool Shoro f1171'7G6:a475 ShlpPenoburg (71.71 63().586!I I \.\ ".1 .1 , '", ;~!;::';:,~S:i:('J::" , ,.,> DEC,~311998i\\., .' !:: '~;:iii' '.,~;>" .. '1..'(:" ., ',:i~~~;:',:I; ,~ . ": v " ~,~. ,...., "1. . ~, , \ \ . " r, ," -', :.",,', --"" :~I'_"- ':; ", ., -" ,~r ",~ :'~I , ,;':.}'., ,,',':. " ~-, '.~ "~ ' ,....::t~..::r:. Diane D. Balchunas, Plaintiff IN TilE COURT 01' COMMON PLEAS . , ' ., .: '," " . ',' , . .' " ': _' ,i . -: ~- ,':::Of. >' ,- '. ',' ".. " , ' ' " ' : . - ',--. ,I -., . OF CUMBERLAND COUNTY,PENNSYLVAN1A \IS. NO. 9s-73:?O CIVIL TERM Bobbie D. Stevenson, Defendant PROTECTION FROM ABUSE t'L9TliT 0 1':..-131' AJ~JJ'l~;LhlULQR 12 E ~ YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers. you must appear at the hearing scheduled herein. If you fai I 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 thtnatter is scheduled for the ~_ dav of .VMUAIl-Ld----, 199 . at 1'()O I'm., in Courtroom NO.~_ of the Cumberlund ~ounty Co rthouse. Carlisle, Pennsylvania. You MUST olley the Order that is attached until it is modified or terminated by the court after notice and hearing. If you disolley 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 jai I under 23 Pa.C.S. 16114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, IS U.S.C. 12265, this Order is enforceable anywhere in the United States. tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you truvel 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. !l 2261-2262. YOU SnOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT TilE HEARING. TilE COURT WILL NOT. 1I0WEVER, APPOINT A LAWYER FOR YOU. IF YOU no NOT IlAVE A LAWYER OK CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FINn OUT WIIERE YOll CAN GET LEGAl. IlELP. IF YOll CANNOT FIND A LAWYER, YOU MAY HAVE TO PROCEED WITIlOUT ONE. CUMBERLANIJ COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISI.E, PENNSYLVANIA 17013 TFI,J-PIIONE NUMBER: ( 717) 24 <)- 3166 ^t>4EKICANLW11'H.I.HSi\BJ I. J_:I'JESJ~Cor-!)I' .19_',lQ The Court of ComlllOIl }Jlc;I:, of ('umber land County is required bv law to "<lInply with the AllIericall'; with llisabi lities Act of 19<)0. For infnnnal ion HhC'lut ilcce>isihlc faci I it ics dnd r~asonahle accommodations availllble to di,;ahled indi\.iduals Iw\'in).' business before the court. plcasl' contact our nffict:. All alrang.L'ml>nt~ must be rnad~ at least 72 lH'\ur~'; prior t\) ;tIl~' hC.1rin.l'. or busjnt.:''';'~, before the cnurt. You must attend thL' :-;cht'duh.'d C~)J\fl'rL'nCL' or Ilearillf. "...r- -.. _.. Diane D. Balchunas. Plaintiff I N TilE COURT OF CmlMON I'I.I,AS ",.' ...'.... ' ,.... "_'.' ..:'... ",,':~. ,.L ,.,.7:,.:':..._.,:~.~'.,." .'.,'..." ".: OF CUM;~ERLAND COUNTY. PENNS'lLVAN I A vs. NO. 'IS- '7-".2<> CIVIL TERM Bobbie D. Stevenson, Defendant PROTECTION FROM ABUSE JEMP_()RAKLP'ROTE(,o'U9JL_FI~OM .c\BUSL9R])1'1; Defendant's Name: Dobbie D. stevenson. Defendant's Date of Birth: 8/7 /68. Defendant's Social Security Number: 210-60-7435. Names of all Protected Persons, including Plaintiff and minor chi Id: Diane D. Balchunas. AND NOW, this .1.L-!f day of....l1~mj.t/l:.,--. 1998. upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the 1'01 lowing Temporary Order: ~ 1. Defendant shall not abuse, harass, stalk or threaten Rny of the above persons in any place where they might be found. o , Defendant is evicted and excluded from the plaintiff's residence located at ~ Cumberland County. Pellnsylvania~ a residence which is Jointly oWlled/lc:"isL'd by the parties; owned/leased by the ent iraties: owned/leased solely by the plaintiff/defendalll In which the plaintiff and the minor child/ren movl'd tu i1\'uid ahusl'. which is not owned or leased by tht~ di..'fell(iiinl. nr t1ny ()1 her permanent or lcmporary rl'sith'llrcwlH,'I'L' Plaintiff Illay live, PI ,1 i n 1 iff i ,'; ,l~. r t'! n Ie d l' X c 1 us i \' L' po~.. S L' S sinn n f llll~ rcsid(>ncL', Ih:_~fL'lldallt shall lid\':.! no ri!!ht or pri\'ilcgc to l'ntL'r or he presellt un the prL"l1Iise~, L'\cl:'pl for the 1 imitcd purpnsl' nf tr;tllsf!.'rrill:~ LlI~~'lHl:\' ()f tl1e partie's' child/ren. Thl' t1ef'_'lld,,"t "hall J'l'lIlaill ill hi, vl'hie!l' al all tillles dUl" 'j llF tilL' t rdJl~;f\.'r lit' cll:..,lody. ~ .1. llefl"Hlallt i:; prohihitl'd fn'l1l having ANY CONTACT with Plaintiff at all). location. ineludinl'.. hul not limitt'd, to allY contill.t at Plaintiff's school, husiness, Of place of l'mploYl1ll'nl, Defendan' is speeifieally ",'dcrcd to stay IlWIlY " from the fol lowinG locations for the duration of this Order: Ihe plaintiff's residence located at 100 Rosew-ont Avenue, New Cumherlnnd, Cumherland County, Pennsylvllnia, a residence which is not owned or leased by the defendant or any other permanent or temporary residence where Plaintiff may live. 181 4. Defendant shal I not contact Plaintiff by telephone or by any nther means, including through third persons. o 5. Pending the outcome of the final hearing in this matter, Plaintiff is awarded temporary custody of the following minor child/ren: * (DaB ). Until the finnl hearing, all contact between Defendant and the child/ren shall be limited to the following: **. The local law enforcement agency in the jurisdiction where the child/ren arc located shal I ensure that the chi Id/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 prohihited from possessing, transferring or acquiring any other weapons for the duration of this Order. H 7. The 1'01 lowing additional relief is granted: The Cumberland County Sheriff's Department shall attempt to nmke service at plaintiff's request and without pre-payment of fees, but service may be accomplished under any applicable Rule of Civil Procedure. This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service. The Prothonotary shall not send a copy of this Order to Defendant hy mail. This Order shall remain in effect until modified or terminated by the Court and can he extended beyond its original expiration date if the Court finds that Defendant has committed another act of ahuse or has engaged in a pattern or practice thaI indicntes continued risk of harm to Plaintiff. Ih~rcr1tfnJlt is cnjuillct.i frum dnmaging or destroying nny property owned solely hy Plaintiff. . ""':" ._: \ " I"" . . :' . '.., ",," " "-.f :", '".' '_. . .. 'J. ',' I . ,', '. ')' . Defendant is to refrain from harassing Plaintiff's rclat ives. B 8. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: New Cumberland Police DcpaT tmen t . ~ . I .' ". ~ ."'. ", . ' '.. ,:' I" ,.,' '. , ' . ,~'. ,.' o 9. THIS ORDER SUPERSEDES 0 ANY PRIOR PFA ORDER AND 0 ANY PRIOR ORDER RELATING TO CHILD CUSTODY 181 10. THIS ORDER APPLIES IMMEDIATELY TO DEFEND,\NT AND SHALL REMAIN IN EFFECT UNTIL MODIFIED OR TERMINATED BY TillS COURT AFTER NOT I CE AND IIEAR I NG . 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. ~GI14. Consent of the Plaintiff to Defendant's return to the residence shall not inval idata this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. ~G113. 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. ~!l 2261-2262. Any protection order granted by a court may be considered in any subsequent proceedings, including chi Id custody proceedings, under title 23 (Domestic Relations) of the Pennsylvania Consol idated Statutes. NOTICE TO LAW ENFORCEMENT OFF1C1ALS This Order shall be enforced by the pol ice who have jurisdiction over the plaintiff's residence OR any locations where a violation of this order occurs OR where the defendant may be locnted. 1 f defendant \'inllltes Paragraphs 1 through 6 of this Order. defendant may be arrested nn the chllrge of Indirect Criminal Cnrllc.mpt. An arrest for violation of this Ortler may be made without warrallt, based solei,' on prohable cause. whether or not till..' violation is cOlllmitted in the preSt'flee of law enforcement. get away from him. The defendant threw the plaintiff's keys and coat at her, grabbed her arm, pushed her towards the door, and then refused to allow her to leave the residence. b. In or about the beginning of spring 1998, the defendant forced the plaintiff into the car, drove the car very fast and recklessly, and put the blade of his knife to her neck causing her to fear for her life. c. On several occasions from December 1997 until August 1998, the defendant abused the plaintiff in ways including, but not I imi ted to, the fol lowing: held a gun to her head with his finger on the trigger threatening to kill her; poked her in the face and chest with his finger; pushed, shoved and grabbed her; poked her in the eye causing her pain and resulting in the loss of her contact lens; strangled her; put a pi I low over her face suffocating her: shoved her into the bathtub causing a bruise on her back; and threatened to punch her while making a fist. 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: New Cumberland Pol ice Department. 10. There is an immediate und present danger of further abuse from the Defendant. II. Plaintiff is asking the Court to order Defendant to stay away from the residence at 100 Rosemont Avenue, New Cumberland, Cumberland County, Pennsylvania, which is not owned or rented by Defendant. WHEREFORE, PLAINTIFF REQUESTS THAT THE COURT ENTER A TEMPORARY ORDER. AND AFTER HEARING, A FINAL ORDER l~AT WOULD DO TilE FOLLOWING: ,\. Rc::;truin Defendant from abusing, threatening, harassing, or stalking Plaint i ff in any place where Plaintiff may be found. B. Order Defendant to stay away from Plaintiff's residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff. C. Prohibit Defendant from having any contact with Plaintiff, either in person, by telephone, or in writing, personally OJ' throu!,-h third persons, including. but not limited to, any contact at Plaintiff's school, business. or placL' of l'lIIp!oYllll!nt. n. Prohibit Defendant from hll\'in!,- any contact with Plaintiff'.,; l-elilti\'es. , '". ' .... . '. '. "., , ' . " . ~ . . , . , , VEltIJ'LC;:A:LIQ~ I verify that I am the petitioner as designated in the present action ond that thc facts and statemcnts contained in the above petition are true und correct to the best 01' my knowledge. I understand that any false statements arc made subject to the penalties of 18 Pa.C.S. 14904, relating to unsworn falsification to authorities. Dated: /V/j'(.j(I,\ ____.-1__.:.-<_____ !Jion__\fJ-.lJh/(),~'(( )( 0' ( ) Diane D. Balchunas, Plaintiff (L " 'I) , , ~ ...) " ) .,....- v " 'l ~ .. Id J ," .,., ,uJ' /' , " '" :'1 .~ ., q d ~. ,- , r.. , - i) :,1 , i'l ~, .; "-0 " , ,'i .~ r. ~ ~-, , ~::. SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1998-07320 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BALCHUNAS DIANE D VS. STEVENSON BOBBIE D R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: STEVENSON BOBBIE D but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN to serve the within PROTECTION FROM ABUSE County, Pennsylvania. On January 14th, 1999 this office was in receipt of DAUPHIN County, Pennsylvania, the attached return from Sheriff's Costs: Docketing Out of County Surcharge Dep. Dauphin Co So answers: /,,,.,/- ~i ",/ R. :'~'h:~Kl~&" .' 18.00 9.00 5.00 25.50 $58.50 ~her~1;t 01/14/1999 Sworn and subscribed.~o before ~e . tI-, ( ) th~s /'f ~ day of '- ) "H ".~ / I 19--1.'7 A. D. ., \ I. {,-' "; \~, . ,,' '; .-- --.-it '} r '._ . h<t14....,. ol. ...1.1'..... J Prothonotary" :" '( _ " ' ;' ::' ". ."'. ~.., . ~ . l ; '. " . " I I,." .:' .' ' ": : .:' ',. -', -. " '_ \ " ": _,'. ," '. . . '," '.' "",~~~~~;~!!;\,:" . f~~l,,,,/,~,,i ~[ i", i' ) ,',;)"," ,,' J!~~)~,if.;:~:~'f:~:';'" ",;:,'>:'; ',' ;:J " ,"',," ",.",leGAt:SER'IICES, INC~ ... .............: 8 IRVINE ROW ..... ..' cARUSLE, PENNSYLVANIA 1701:1. . ,. '!7111 %43-9400' . . Fax (717) 243-8026 '...,...-'....':'..'.'.'.,...:.-.....-:-- "'. "'...-, . w&i;t Shol8(71:71.100.a476 Shl~pen.bu'llJ717} 63Q.68e6 ,""i -,I, ',,' . ~. r .. , ., \ \ ',.,-;:',:: f.'I,-:;;' >:. .{' ., \ " .;\ ( . , '. DIANE D BALCIIUNAS. Plainti\1' . IN TilE COURT OF COMMON PLEAS OF . CUMBERLAND COUNTY.I'ENNSYLVANIA v. . NO. 98-7320 CIVIL TERM BOBBIE D. STEVENSON. Dclcndant . PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, this L1~y of January, 1999, upon consideration of the attacht,d Motion for Continuance, the mattt'r scheduled for hearing on Thursday, January 7, 1999, at 1.00 p,m. by this Court's Order of December 31, 1998, is hereby rescheduled li)r hearing onl'ehrua'1' 8, 1999, nl 2:00 p.m., in Courtroom No.5 of the Cumherland Couuty Courthouse, Carlisle, I'ennsylvanill. The Temporary Protection From Abuse Order shall remain in etlect for a period of one year from the date it was entered. December 31, 19<)8. or until Illrther Order of Court, whichever comes first. ^ certified copy of this Order ll1r Continuance will be provided to the New Cumberland Police Department by Plaintitl's attorney BY~) ~ /' or Edward E Guido. Judge J"an Call'\' LH;AL SERVICES. I:'\C Attorncv ti,r Pbintill . " I ," , . ," " . .' ." ':.' '" , ". . ' ..' '- '. . ' " ',,' I, '. ", . . ' ."~ . , -. . ", . . -~ '. ,,>' ,. " , . ' . - , , . .' ;.. '" < .' '. . ",;, . ~ ' - , . . , ","], ", DIANE D BALCHUNAS, Plaintill' . IN TilE COURT OF COMMON PLEAS OF , ' ,.,.'.,', '" " - "". ", '" ',' ..'. ',t". '., ' ' .' : CUl\lIlERLAND COUNTY, PENNSYLVANIA v. . NO. 98-7320 CIVIL TERM BOBBIE D. STEVENSON, DeCendant . PROTECTION FROM ABUSE MOTI,ON FQR COJ~_TINUA1~J:_E The Plaintill; Oiane D. Balchunas, by and through her allorney, Joan Carey 01' Legal Services, Inc., moves the Court 1'01' an Order rescheduling the hearing in the above-captioned case on the grounds that: I. A Temporary Protection From Abuse Order was issued by this Court on December 31, 1998, scheduling a hearing lor Thursday, January 7, 1991), at I :00 11.111 2. The Cumberland County Sherii1's Department deputized Dauphin County Sheriff's Deparlmentto serve DeCendant with a certified copy 01' the Temporary Protection From Abusl' Order and Petition for Protection From Abuse. Dauphin County Sheriff deputies were unsuccessful in in their attempts to serve DeCendam as 01' January 6, 1999. 3. The Plaintitfrequests that the Temporary Protection From Abuse Order remain in elfect Cur a period ot'one year ii'om the date it was entered. December 31. 1998. or until iurther Order oCCoun, whic1le\er comes lirst ,1 A CC11ified copy of the Order Cor Continuance will be delivered to the New Cumberland Police Depat1ment hv the attorney Cor PlaintitT . . WIIEREFORE, PlaintitTn:quesls that the Coun grant this Motion and reschedule this matter ij'r hearing. and thai the Temporary Pmtection From Abuse Order remain in clTect for a period 01' one yearli'om thc datc it was cntcred. Decembcr -' I, I fJfJX, llr lIntillilrthcr Ordcr ufCulIrt, whichcvcr comcs iiI's!. R~spectlill1y Sllll!l~ilted, ~/ ,'. . ,.J' .'Jfl:l(;;~I~/X~~~;~~~~;;:, lai~litT-- LEGAL SERVICES, INC. 8 Irvinc Ruw Carlisle, P ^ 17013 (717) 2.13-9400 ,', . _.' . . . .' , "..' '. ' .'. I I~' , " ,,' I' '. .' " , ..... .~ , \ ....' , , . \ " . ' " ., .. '. - ~'" .'.~:'. \" 1 " . . ....'.' :;. - , , ,'" ~ " ,. " . ~~~"';.;;'V:>:'~-;;;o.;,",,'/'j;OC"'~ . '~~~~i#rL., C/\~3E NO: 1 Q'7P. (Yr(:-~(7J F' COMMONWEALTH OF 1'[llIL,YJ I'MI1/I: COUNTY OF CUMBFRLANn IMLCIIUNAJLD I ANF;~__ './~; . ~'J'EVENSON BOBBlr::._..!2-.__..._________ R. TholTl.'3s Kline Sh~I"iif. who being d1Jly S~Grn 8(~cordjrlg to law, says, that he m3df? a di..li.gf2Jlt. searctl Bnd inqu."iry for the \.,ithin named def,?nd'lnt, t.o wi t.: _STEVENSOli_~.iJBQ.lL.!L.._..__.____.__. ..._..__.'__'_'u"__ but was unable to .loc~tc.;. ___...HJ:Jn___ in his bailiwlcl.:. He therefr:~rf? deputized the sheriff of D.6_t 1 P Ii 1-JJ____.____.__~_ c. fJ \..J r\ t y . F' ~.-. n n~:; y .1 '.J a n J. a . t.o serve t.he withi.n PRC1TiCCT)lJtL FROL6.DUSf':.__________.......______ On Febrllar.,. l1th.!.._ 19_"12"!.... this c,fiice wa2 in ]'-eceipt of the att.ached rEt.urn frc.:n __.,__.__._l:.!!~lPHni____.~_______ County, PennsylvaniB. Sheriff's CDstS: ,- _" I ;J n:::.....' l.:.:~- ,,3: ./" / ---. ~,-:~ 4- y~." 7 / /- ...K.::::_ '. .' - ~... ......./ ..-~.~ E. hr;T.1;;J~ l\l~-nl::l~---;Jli?-I~.rr Docketino Out of Cbunt.)' Surcharqp D!::P. DAOPNIN CO .1 e,. rJ(~'! (3.DCl Po, 00 :27 . ~jl1J ~~7; ~.::. ~JT::i 02 11111 ,:l':'l? Swnrn and subSCrll)ed to bpfor0 n~e lL -f" t his _lJ..:::_ oj a y <) f J-<-I.....<<_<J....vf u.____... 19_9.2.- A. [I. ","'_...' --~-=iJ..5f.t ,--C...,7JL<.0~+~dU I" rD. !j('fl (I 't ;:1~-',' r , .): .',' . " _:. ."~' , ".. r ; .' ~.:: -.... \' :,.' I _ : . , ' '. ., ~:' , , '~ " _,' , . , , . - .' .