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Jennifer Christian,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
vs.
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2000- {,OV 'I CIVIL TERM
Marshall L. Kessler,
Defendant
: PROTECTION FROM ABUSE
NOTICE OF HEARING AND ORDER
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 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 THIS MATTER IS SCHEDULED ON 7~HA' 7 ,DXl,AT
rf.?:!D P.M., IN COURTROOM NO. .::t OF HE CUMBERLAND
COUNTY COURTHOUSE, CARLISLE, PENNSYL VANIA.
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 injail under 23 Pa.C.S. S6ll4. Violation may also subject you
to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18
U.S.c. S2265, 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 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.
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Jennifer L. . Christian
: In the Court of Common Pleas
: County, Pennsylvania
.
Plaintiff
v.
: No. (H) - &00,/
Marshall Leon Kessler
Defendant
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: Marshall Leon Kessler
Defendant's Date of Birth is: October 30,1981
Name(s) of All protected persons, including Plaintiff and minor children:
1. Jennifer L. Christian
AND NOW, on 30th Day of August, 2000 upon consideration of the attached
Petition for Protection from Abuse, the court hereby enters the following Temporary
Order:
Plaintiffs request for a temporary protection order is granted.
1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in
any place where they might be found.
_I' 2. B!lsQjlt f51 3",,1. "villa"t ",1:1. 1:1." IIliIl~I ,,1.;J~'\':'il a, lllay t" -l'''llilitt"a 1ifl8i1r
'\( _ #. JllI=!;iaph'l OI tins ~, Defendant IS prohibited from haVIng ANY CONTACT
L-:? with Plaintiff, M" lj [.th~1 J5!IE~R lll'stc"lM1lI'l8Sr 1i"" Q,dlif, at any location,
including but not limited to any contact at 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.
Any residence or place of employment Plaintiff may establish.
3. Except for such contact with the minor child/ren as may be permitted under
paragraph 4 of this Order, Defendant shall not contact Plaintiff, or any other
person protected under this Order, by telephone or by any other means, including
through third persons.
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4. ending the ?utcome of e final hearing in . s matter, Plaintiff is a
orary custody oft e following minor chi Iren:
ysical custody
d pending further
er 6, 2000.
5. Defendant shall immediately relinquish any firearms license the Defendant may
possess, and the following weapons to the Sheriffs Office or a designated local
law enforcement agency for delivery to the Sheriffs Office.
1. Any firearms, including but not limited to,
approximately 7-10 rifles or shotguns.
Defendant is prohibited from possessing, transferring or acquiring any other
firearms license or weapons for the duration ofthis order.
6. The following additional relief is granted:
-The Cumberland County Sheriff's Department shall attempt to make
service at Plaintiff's request and without pre-payment offees, 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 the Defendant by mail.
-This order can be extended beyond its original expration date if the court
finds that Defendant has committedanother act of abuse or has engaged in a
pattern or practice that indicates continued risk of harm to Plaintiff.
-Defendant is required to relinquish to the sheriff any firearm license
Defendantmay possess. Defendant's weapons and firearm license may be
returned at theexpiration of the Protection Order after Defendant has
submitted a written request to the Court for the return of the weapons and
the Court has notified Plaintiff ofthe request and given Plaintiff an
opportunity to respond. A copy of this Ordershall be transmitted to the chief
or head of the police department of Carlise and Newville and the sheriff of
Cumberland County.
-Defendant is enjoined from damaging or destroying any property owned
jointly by the parties or owned solely by the Plaintiff.
-~~~ain.~1l1 harakin~vtai~
-or:~e~~an~y the~~sts ofiliis aAyt. i~~._
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7. A certified copy ofthis Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
The Carlisle Police Department and any other appropriate police
department.
8. The sheriff, police or other law enforcement agencies are directed to serve the
Defendant with a copy of the Petition, any Order issued, and the Order for
Hearing without prepayment of costs. The Petitioner will inform the designated
authority of any addresses, other than the Defendant's residence, where Defendant
can be served. The Prothonotary is directed to file this Petition and Order without
prepayment of costs.
9. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL MARCH 1, 2002 OR UNTIL OTHERWISE
MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND
HEARING.
NOTICE TO THE 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, S6ll4. 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.
S6ll3. Defendant is further notified that violation of this Order may subject himlher
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. SS226l-
2262.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the police who have jurisdiction over the plaintiff's
residence OR any location where a violation of this order occurs OR where the
defendant may be located. If defendant violates Paragraphs 1 through 5 of this
Order, defendant shall be arrested on the charge ofIndirect 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 oflaw
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 Sheriff's 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.
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PFAD Number: ZPl132107A
Jennifer L. Christian
: In the Court of Common Pleas
: County, Pennsylvania
Plaintiff
v.
:No. 00./"00'( CtM !.LA-
Marshall Leon Kessler
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
Defendant
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiff's name is:
Jennifer L. Christian
2. I, (the Plaintiff), am filing this Petition on behalf of:
- myself
3. Name(s) of ALL person(s), including minor children, who seek protection from abuse.
a. Jennifer L. Christian
4. Plaintiff's Address is: 2225 Spring Street, West Lawn, PA 19609
5. Defendant's Name is:
Marshall Leon Kessler
6. Defendant is believed to live at the following address:
33 Mount Zion Road, Carlisle, P A 17013
7. Defendant's Date of Birth is:
October 30, 1981
8. Defendant's Place of employment is:
Staples, High Street, Carlisle, Pennsylvania
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9. Defendant is an adult.
1 0, The relationship between the Plaintiff and the Defendant is:
Parents of the same children
Current or former sexual/intimate partner
11. The Plaintiff and the Defendant been involved in the following court actions:
a. Custody
b. Protection From Abuse
12. Other details of the court action are:
Kessler v. Christian Protection From Abuse and Custody 00-5969 Civil Term,
Cumberland County Court of Common Pleas 00-5023 Custody, Cumberland County
Court of Common Pleas
13. Plaintiff and Defendant are the parents of the following minor child/ren:
a. Kaylie Larie Kessler
Age:4 months
Child's address is: 33 Mount Zion Road, Carlisle, P A 17013
14. There is an existing court order regarding the custody of the Plaintiff's and Defendant's minor children.
The terms of the order are: Defendant has primary physical custody, Plaintiff has supervised
visitation.
County: Cumberland
State: Pennsylvania
15. Plaintiff is seeking an Order of child custody as part of this petition.
The following is a list of the children and where they have live for the past 5 years:
a. Kaylie Larie Kessler
For the past 5 years, this child has lived with:
Plaintiff 25 West Big Spring Avenue Birth until 8/24/00
and Defendant Apartment #3
Newville, P A 17241
Defendant 33 Mount Zion Road 8/24/00 until present
Carlisle, PA 17013
16. The facts of the most recent incident of abuse are as follows:
On or about August 24, 2000, Defendant pushed Plaintiff as she attempted to use the phone and
threatened she better not start anything. When Plaintiff attempted to use the phone a second
.
time, Defendant pushed her again. The third time Plaintiff attempted to use the phone,
Defendant grabbed Plaintiff's arm and pulled her away from the phonll as she held the baby
causing a bruise on her arm. Defendant ripped the phone from the wall, got the second phone,
and left the apartment with both phones. Fearing for their safety, Plaintiff locked herself and the
baby in the bedroom. A short time later, Defendant returned, entered the bedroom by picking
the lock, pushed Plaintiff with his shoulder, threw the cordless phone at her, and threatened he
was going to the police.
17. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor child/ren,
(including any threats, injuries, or incidents of stalking) are as follows:
In or about the Spring of 2000, Defendant went into the bedroom, loaded a gun, and left the
apartment. Defendant returned to the apartment within seconds, and threatened to kill himself
as he held a gun under his chin with his finger on the trigger and stated he wanted her to watch.
On a separate occasion, Defendant opened the car door, put his feet outside the door, and
threatened to jump out of the vehicle as Plaintiff drove the vehicle approximately 40-50 miles
per hour. Due to Defendant's instability, Plaintifffears for her safety and that of her child.
18. The Defendant has used, or threatened to use, the following weapon( s) against the Plaintiff or the
minor child/ren:
a. Approximately 7-10 rifles or shotguns
19. The police department( s) or law enforcement agencies that should be provided with a copy of the
protection order are:
Carlisle Police Department and any other appropriate police departments.
20. There is an immediate and present danger of further abuse from the Defendant.
21. FOR THE REASONS SET FORTH ABOVE, I REQUEST 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 and/or
minor child/ren in any place where Plaintiff may be found.
b. Award Plaintiff temporary custody of the minor child/ren and place the following
restrictions on contact between Defendant and child/ren:
- Plaintiff is requesting shared legal custody and primary physical custody and
alternatively shared physical custody of the minor child pending further Order
after conciliation which is scheduled for October 6, 2000.
c. 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 Plaintiffs 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.
d. Prohibit Defendant from having any contact with Plaintiff's relatives and Plaintiff's
children listed in this petition, except as the court may find necessary with respect
to partial custody and/or visitation with the minor child/ren.
e. Order Defendant to pay the costs of this action, including filing and service fees.
f. Order the following additional relief, not listed above:
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- Defendant shall pay $250.00 to one of Legal Services, Inc.'s funding sources
as reimbursement for litigation in this case.
- Defendant shall not harass Plaintiff's relatives.
- Defendant shall not damage or destroy any property owned solely by Plaintiff
or jointly by the parties.
g. 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 petitioner
will inform the designated authority of any addresses, other than the Defendant's
residence, where Defendant can be served.
Respectfully submitted,
Date:
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'lip C. Briganti, Andrea vy, Joan Carey
and Maryarm Murphy, Attorneys for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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VERIFICATION
The above-named Plaintiff, Jennifer Christian, verifies that the
statements made in the above Petition are true and correct. Plaintiff
understands that false statements herein are made subject to the penalties of
18 Pa. C.S. 94904, relating to unsworn falsification to authorities.
Date: ,1\" ~l\ I ::IMt1>
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-06004 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHRISTIAN JENNIFER
VS
KESSLER MARSHALL L
BRIAN BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE
was served upon
KESSLER MARSHALL L
the
DEFENDANT
, at 0019:55 HOURS, on the 31st day of Auqust
, 2000
at 33 MT. ZIOON ROAD
CARLISLE, PA 17013
by handing to
MARSHALL L. KESSLER
a true and attested copy of PROTECTION FROM ABUSE
together with
NOTICE OF HEARING & ORDER, TEMPORARY
PROTECTION FROM ABUSE ORDER, PETITION
and at the same time directing His attention to the contents thereof.
Additional Comments
WEAPONS CONFISCATED
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
3.10
.00
10.00
.00
31.10
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R. Thomas Kline
09/01/2000
Sworn and Subscribed to before
By:
~~~~
Deputy Sheriff
me this 1 q"... day of
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JENNIFER L. CHRISTIAN,
Plaintiff
: In the Court of Common Pleas
: of CUMBERLAND County,
: PENNSYLVANIA
v.
: Civil Action - Law
: No. 00-6004
MARSHALL L. KESSLER,
Defendant
: PROTECTION FROM ABUSE
:In the Court of Common Pleas
MARSHALL L. KESSLER,
Plaintiff
:ofCUMBERLAND County,
v.
:PENNSYL VANIA
:No. 00-5969 ./
JENNIFER L. CHRISTIAN,
Defendant
:PROTECTION FROM ABUSE
CONTINUED TEMPORARY ORDER
AND NOW, this 8th Day of September, 2000, pursuant to 23 Pa.C.S. ~6107(c), the
terms and conditions of the Temporary Order issued on 30th Day of August, 2000,
in the above-captioned case are hereby continued in full force and effect until further
order of the court.
A hearing on this matter is scheduled for the October 16, 2000, at lO:OOAM in
Courtroom NO.2 on the 4th Floor of the Cumberland County Courthouse, One
Courthouse Square, Carlisle.
TRUE COPY FROM RECORD
In ~lI3t!mooy whereof, I here unto set my ro.aoo
":,,j too ~I of said C'C at CwiisI6'. Pa.
TillS f ~ day Z x!:t.:~ ~
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Prothonotar)'
BY THE COURT:
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~ Edgar B. Bayley, Judge
-
Distribution To:
Joan Carey, Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
Gary L. Kelley, Attorney for Defendant
132-134 Walnut Street
Harrisburg, P A 17101
FAXed & Mailed to PSP
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JENNIFER CHRISTIAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: NO. 00-6004 CIVIL TERM
MARSHALL L. KESSLER,
Defendant
: PROTECTION FROM ABUSE
MARSHALL L. KESSLER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-5969 CIVIL TERM
JENNIFER CHRISTIAN,
Defendant
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
Plaintiff, Jennifer Christian, by and through her attorney, Joan Carey of Legal Services, Inc., moves
the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that:
1. Marshall L. Kessler filed a Petition for Protection From Abuse and custody of the parties'
child and a Temporary Protection From Abuse Order (No. 00-5969) was entered by this Court on August
29, 2000, scheduling a hearing for September 7, 2000, at 2:30 p.m. Jennifer Christian counter-filed a
Petition for Protection From Abuse and a Temporary Protection From Abuse Order (No. 00-6004) was
issued by this Court on August 30, 2000, scheduling a hearing on the same date and time.
2. The Cumberland County Sheriff's Department served Jennifer Christian with a certified copy
of the Temporary Protection From Abuse Order and Petition for Protection From Abuse
(No. 00-5969) at their offices on August 30, 2000. Marshall L. Kessler was served with a certified copy of
the Temporary Protection From Abuse Order and Petition for Protection From Abuse
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(No. 00-6004) at his residence at 301 Mt. Zion Road, Carlisle, Cumberland County, Pennsylvania, on August
31,2000, at approximately 7:30 p.m.
3. Marshall L. Kessler has retained Gary L. Kelley, Attorney at Law, to represent him in the
matter.
4. The parties agree, by and through their respective counsel, that the hearing be rescheduled
to afford them time to negotiate a settlement in this matter.
5. The parties agree, by and through their respective counsel, that their respective Temporary
Protection From Abuse Orders remain in effect until further Orders of Court.
WHEREFORE, Plaintiff, Jennifer Christian, requests that the Court grant this Motion and
reschedule this matter for hearing, and the parties, by and through their respective counsel, request that the
above-captioned Temporary Protection From Abuse Orders remain in effect until further Orders of Court.
Respectfully submitted,
11 /It
~j"~J ~'LL-<---
l16lill Carey, Attorney for aintiff
LEGAL SERVICES, C.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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JENNIFER L. CHRISTIAN,
Plaintiff
: In the Court of Common Pleas
: of CUMBERLAND County,
: PENNSYLVANIA
v.
: Civil Action - Law
; No. 00-6004 ./-
MARSHALL L. KESSLER,
Defendant
: PROTECTION FROM ABUSE
:In the Court of Common Pleas
MARSHALL L. KESSLER,
Plaintiff
:ofCUMBERLAND County,
v.
:PENNSYL VANIA
:No. 00-5969
JENNlFERL. CHRISTIAN,
Defendant
:PROTECTION FROM ABUSE
CONTINUED TEMPORARY ORDER
AND NOW, this 8th Day of September, 2000, pursuant to 23 Pa.C.S. ~6107(c), the
terms and conditions of the Temporary Order issued on 30th Day of August, 2000,
in the above-captioned case are hereby continued in full force and effect until further
order of the court.
A hearing on this matter is scheduled for the October 16, 2000, at lO:OOAM in
Courtroom NO.2 on the 4th Floor of the Cumberland County Courthouse, One
Courthouse Square, Carlisle.
BY THE COURT:
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8 Irvine Row
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Gary L. Kelley, Attorney for Defendant
132-134 Walnut Street
Harrisburg, P A 17101
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JENNIFER CHRISTIAN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
v.
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00-6004 CIVIL TERM
MARSHALL L. KESSLER,
Defendant
: PROTECTION FROM ABUSE
MARSHALL L. KESSLER,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-5969 CIVIL TERM
JENNIFER CHRISTIAN,
Defendant
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
Plaintiff, Jennifer Christian, by and through her attorney, Joan Carey of Legal Services, Inc., moves
the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that:
1. Marshall L. Kessler filed a Petition for Protection From Abuse and custody of the parties'
child and a Temporary Protection From Abuse Order (No. 00-5969) was entered by this Court on August
29, 2000, scheduling a hearing for September 7, 2000, at 2:30 p.m. Jennifer Christian counter-filed a
Petition for Protection From Abuse and a Temporary Protection From Abuse Order (No. 00-6004) was
issued by this Court on August 30, 2000, scheduling a hearing on the same date and time.
2. The Cumberland County Sherifl's Department served Jennifer Christian with a certified copy
of the Temporary Protection From Abuse Order and Petition for Protection From Abuse
(No. 00-5969) at their offices on August 30, 2000. Marshall L. Kessler was served with a certified copy of
the Temporary Protection From Abuse Order and Petition for Protection From Abuse
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(No. 00-6004) at his residence at 301 Mt. Zion Road, Carlisle, Cumberland County, Pennsylvania, on August
31, 2000, at approximately 7:30 p.m.
3. Marshall L. Kessler has retained Gary L. Kelley, Attorney at Law, to represent him in the
matter.
4. The parties agree, by and through their respective counsel, that the hearing be rescheduled
to afford them time to negotiate a settlement in this matter.
5. The parties agree, by and through their respective counsel, that their respective Temporary
Protection From Abuse Orders remain in effect until further Orders of Court.
WHEREFORE, Plaintiff, Jennifer Christian, requests that the Court grant this Motion and
reschedule this matter for hearing, and the parties, by and through their respective counseL request that the
above-captioned Temporary Protection From Abuse Orders remain in effect until further Orders of Court.
Respectfully submitted,
an Carey, Attorney for aintiff
LEGAL SERVICES, C.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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JENNIFER CHRISTIAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff-Respondent : CUMBERLAND COUNTY, PENNSYL VANIA
vs. : NO. 00-6004 CIVIL TERM
MARSHALL L. KESSLER, : PROTECTION FROM ABUSE
Defendant-Petitioner
ORDER
AND NOW, this If\. day of J 'j ~~ _-,
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, 2000, the within PF A
ORDER having been vacated by Order of this Court dated October 9, 2000, the Sheriff is hereby
authorized and ORDERED to return to MARSHALL L. KESSLER the weapons seized as a
result of these proceedings.
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JENNIFER CHRISTIAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff-Respondent : CUMBERLAND COUNTY, PENNSYLVANIA
vs. : NO. 00-6004 CIVIL TERM
MARSHALL L. KESSLER, : PROTECTION FROM ABUSE
Defendant-Petitioner
DEFENDANT'S PETITION FOR ORDER OF COURT
TO RETURN WEAPONS TO MARSHALL L. KESSLER
TAKEN PURSUANT TO 23 Pa. C.S.A. 666108
TO THE HONORABLE EDGAR B. BAYLEY, JUDGE:
AND NOW, TO WIT, this J {)~day of November, 2000, comes the Defendant,
MARSHALL L. KESSLER, by his attorney, Bruce A. Grove, Jr., Esquire and respectfully
petitions this Honorable Court to order the Sheriff of Cumberland County to return to the
Petitioner the Petitioner's weapons taken by the Sheriff pursuant to the provisions of the
Protection From Abuse Act, 23 Pa. C.S.A. ~~ 6101, specifically ~~ 6108 thereof, et seq., and in
support thereof avers as follows:
I. Parties
1. Petitioner, MARSHALL L. KESSLER, is the Defendant in the above-captioned case
and he resides at 33 Mount Zion Road, Carlisle, Cumberland County, Peunsylvania 17013.
2. Respondent, JENNIFER L. CHRISTIAN, is the Plaintiff in the above-captioned case
and she resides at 2225 Spring Street, West Lawn, Berks County, Pennsylvania 19609.
II. Factual Background
3. Paragraphs 1 and 2 of this Petition are incorporated herein by reference as if set forth
length.
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4. The instant Petition stems from mutual Petitions having been filed by the parties under
the Protection From Abuse Act, the Respondent's Petition and Temporary Protection From
Abuse Order having been filed and issued by the Court on August 30, 2000; a true and correct
copy of said Order is attached hereto as an Exhibit.
5. On August 31, 2000, and pursuant to the Order issued on August 30, 2000 rattached
hereto as an Exhibit]. the Cumberland County Sheriff's Department confiscated certain weapons
belonging to the Petitioner and his brother; a true and correct copy of the Cumberland County
Sheriffs Department itemized Weapons Confiscation list is attached hereto as an Exhibit.
6. On Friday, October 6, 2000, the Parties reconciled their differences during a Custody
Conciliation Conference before Hubert X. Gilroy, Esquire; as a result, Judge Bayley issued an
Order on October 9, 2000 vacating the two separate Temporary Protection From Abuse Orders
previously issued on behalf of the Parties. A true and correct copy of said Order is likewise
attached hereto as an Exhibit.
7. On October 25, 2000, undersigned counsel for the Petitioner submitted a "Joint
Petition," and proposed Order of Court, to the Respondent's attorney, Joan Carey, of Legal
Services, Inc.; a true and correct copy of undersigned counsel's October 25, 2000, letter to
Attorney Carey regarding the purpose of this "Joint Petition" is attached hereto as an Exhibit.
8, As of the date of this Petition, undersigned counsel has not received a formal response
to the "Joint Petition" request from Legal Services, Inc.
III. Petitioner Marshall L. Kessler's
Application For Return of His Weapons
9. Paragraph 1 through 9 of this Petition are incorporated herein by reference as if set
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forth at length.
10, Since August 31, 2000, Petitioner has, without justifiable cause, been wrongfully
deprived of the use and enjoyment of his guns (weaoons) because oftheir confiscation by the
Sheriff of Cumberland County.
11. Petitioner and his Father and Brother(s) are avid Pennsylvania hunters and obviously
need the confiscated guns in order to enjoy Pennsylvania's current hunting season.
WHEREFORE, Petitioner requests that this Honorable Court order of Sheriff of
Cumberland County to return to Petitioner the weapons itemized in this Petition.
Respectfully submitted,
LAW OFFICE OF BRUCE A. GROVE, JR.
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Bruce A. Grove, Jr., Esquire I
Attorney I.D. #15502
110 Lexington Road
York, PA 17402-4805
(717) 747-9351
Attorney for Petitioner
Dated: November 10, 2000
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Jennifer 1. Christian
: In the Court of Common Pleas
: County, Pennsylvania
Plaintiff
v.
: No.
Marshall Leon Kessler
Defendant
: CIVIL ACTION - LAW
; PROTECTION FROM ABUSE
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: Marshall Leon Kessler
Defendant's Date ofBitih is: October 30, 1981
/
Name(s) of All protected persons, including Plaintiff and minor children:
I. Jennifer L. Christian
AND NOW, on 30th Day of August, 2000 upon consideration of the attached
Petition for Protection from Abuse, the court hereby enters the following Temporary
Order:
Plaintifrs request for a temporary protection order is granted.
1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in
any place where they nlight be found.
2. EAL:ep[ [or SUL:h ~v!lta8t HTith thE'> n,-innl" r.hl1il/reg R3 UJUY hI,;., p~JUl.iUC;J uudOl=-
\t;l~l!il!:> .p"""gr~ph 4 "fth;a {)r,.Jp,., Defendant is prohibited from having ANY CONTACT
with Plaintiff, Qr ~ny nthE'>l" ppr~nn poot~~t~Q lmQ';"1- th1~ nrilpr, at any location,
including but not limited to any contact at 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.
Any residence or place of employment Plaintiff may establish.
3. Except for such contact with the minor child/ren as may be pennitted under
paragraph 4 of this Order, Defendant shall not contact Plaintiff, or any other
person protected under this Order, by telephone or by any other means, including
through third persons.
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4. ding the outcome of the final hearing in this matter, Plaintiff is awar d
tempo custody (;f the following minor child/ren:
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Until the final hearing, all contact en Defendant and the child/ren shall be
limited to the following:
Plaintiff shall have shar egal custody an rimary physical custody
alternatively share ysical custody ofthe min hild pending further
Order after co . lation which is scheduled for Octo . 6, 2000.
The loc aw enforcement agency in the jurisdiction where the 'ld/ren are
loc Cl shall ensure that the child/ren are placed in the care and contI
aintiffin accordance with the tenns of this Order.
5. Defendant shall immediately relinquish any firealllis license the Defendant may
possess, and the following weapons to the Sheriffs Office or a designated local
law enforcement agency for delivery to the Sheriff's Office.
1. Any firearms, including but not limited to,
approximately 7 -10 rifles or shotguns.
Defendant is prohibited from possessing, transferring or acquiring any other
firean11S license or weapons for the duration ofthis order.
6. The following additional relief is granted:
- The Cumberland County Sheriffs Department shall attempt to make
service at Plaintiffs request and without pre-payment offees, 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 the Defendant by mail.
- This order can be extended beyond its original expration date if the court
finds that Defendant has committedanother act of abuse or has engaged in a
pattern or practice that indicates continued risk of harm to Plaintiff.
-Defendant is required to relinquish to the sheriff any firearm license
Defendantmay possess. Defendant's weapons and firearm license may be
returned at theexpiration of the Protection Order after Defendant has
submitted a written request to the Court for the return of the weapons and
the Court has notified Plaintiff ofthe request and given Plaintiff an
opportunity to respond. A copy of this Ordershall be transmitted to the chief
or head of the police department of Carlise aud Newville and the sheriff of
Cumberland County.
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-Defendant is enjoined from damaging or destroying any property owned
jointly by the pal'ties or owned solely by the Plaintiff.
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-Defendant shall pay $250.00 to one of Legal Services, Inc. 's funding sources
as reimbursement fr litigation in this case.
7. A ceriified copy of this Order shall be provided to the police depmiment where
Plaintiffresides and any other agency specified hereafter:
The Carlisle Police Department and any other appropriate police
department.
8. The sheriff, police or other law enforcement agencies are directed to serve the
Defendant with a copy of the Petition, any Order issued, and the Order for
Hearing without prepayment of costs. The Petitioner will infonn the designated
authority of any addresses, other than the Defendant's residence, where Defendant
can be served. The Prothonotary is directed to file this Petition and Order without
prepayment of costs.
9. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL MARCH 1,2002 OR UNTIL OTHERWISE
MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND
HEARING.
NOTICE TO THE DEFENDANT
Defendant is hereby notified that violation of this Order may result in al1'est 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. 06114, Consent ofthe 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 couri papers for that purpose. 23 Pa.C.S.
06113. Defendant is further notified that violation of this Order may subject him/her
to state charges and penalties under the Pennsylvania Climes Code and to federal
charges and penalties under the Violence Against Women Act, 18 U.S.C. 002261-
2262
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the police who have jUlisdiction over the plaintift's
residence OR any location where a violation ofthis order occurs OR where the
defendant may be located. If defendant violates Paragraphs 1 through 5 of this
Order, defendant shall be an-ested on the charge of Indirect Criminal Contempt. An
arrest for violation of this Order may be made without walTant, based solely on
probable cause, whether or not the violation is committed in the presence oflaw
enforcement.
Subsequent to an al1'est, 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 ofthe weapons untIl
fUliher Order of this court, unless the weapon/s are evidence of a Clime, in which
case, they shall remain with the law enforcement agency whose officer made the
an'est.
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MARSHALL L KESSLER,
Plaintiff
. IN THE COURT OF COMMON PLEAS OF
· CUMBERLAND COUNTY, PENNSYLVANIA
v
JENNIFER CHRISTIAN,
Defendant
. NO. 00-5969 CIVIL TERM
PROTECTION FROM ABUSE
JENNIFER CHRISTIAN,
Plaintiff
. IN THE COURT OF COMMON PLEAS OF
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. CUMBERLAND COUNTY, PENNSYLVAJ\T1A
. NO. 00-6004 CIVIL TERM
",IARSHALL L KESSLER,
Defendant
. PROTECTION FROM ABUSE
ORDER OF COURT
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AND NOW, this ---= day of October, 2000, upon consideration of the attached Petition,
the Temporary Protection From Abuse Orders in the above-captioned cases entered on August 29,
2000, and August 30, 2000, respectively, are hereby vacated and the actions withdrawn without
prejudice to either pm1y
By the Court,
IS! (:Ji1,~) Il M/
Edgar . Bayley, Judge
Joan Carey, Attorney for Jennifer Christian
Legal Services, lnc
8 Irvine Row
Carlisle, PAl 70 13
Bruce A. Grove, Jr., Attorney for Marshall L Kessler
110 Lexington Road
York, PA 17402
TRUE COi>Y FROM RECORD
In T e,ttmany whereof, I here "Clto set my !land
and t seal of sa' Court at carllfe: Pa.
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BRUCE A. GROVE, JR. ATTORNEY AT LAW
110 LEXINGTON ROAD. YORK, PA 17402
(717) 747-9351. Fax (717) 747-5761
October 25,2000
[HAND DELIVERED]
Joan Carey, Esquire
Legal Services, Inc.
8 Irvine Row
Carlisle, PAl 70 13
RE: Marshall L. Kessler
. 8/30/00 Temporary Protection from Abuse Order
. Weapons/Firearms ofMr. Kessler
. Joint Petition for return of Weapons to Mr. Kessler
Dear Joan:
Enclosed is a "Joint Petition," for execution by us as the attorneys for the parties,
requesting that Judge Bayley issue an Order to the Sheriff directing him to return Mr. Kessler's
weapons.
As you know, this is hunting season in Pennsylvania and Mr. Kessler needs the
immediate return of his weapons in order that he can enjoy the hunting season with his father and
friends.
I await your reply; 1 will file the executed Petition with the Court - i.e., 1 will pick it up at
your office.
Thanks for your cooperation.
Very truly yours,
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Bruce A. Grove, Jr.
BAG/plk
Enclosure
cc: Marshall L, Kessler
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CERTIFICATE OF SERVICE
I do hereby certifY that on this day I served a true and correct copy of the foregoing
Petition by first class mail, postage pre-paid, addressed to the following:
Joan Carey, Esquire
Legal Services, Inc.
8 Irvine Row
Carlisle, P A 17013
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Bruce A. Grove, Jr., Esquire
Dated: November 10, 2000
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LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, Pennsylvania 17013
(717) 243-9400
Fax (717) 243.8026
West Shore (717) 766-8475
Shippensburg (717) 530-5866
Franklin Farm Lane
Chambersburg, Pennsylvania 17201
(717)264-5354
423 S. Washington Street
Gettysburg, Pennsylvania 17325
(717)334-7623
November 20, 2000
The Honorable Edgar B. Bayley
Cumberland County Courthouse
1 Courthouse Square
Carlisle, P A 17013
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No. 00-6004 /
Protection From Abuse /
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Christian v. Kessler
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Legal Services, Inc. represented . r Chri . e above referenced Protection
From Abuse case. We sent a letter to Ms. Christian on or about November 3rd regarding Attorney
Bruce Grove's request that the Defendant- Petitioner's guns be returned to him. On or about
November 13, 2000, Attorney Grove filed a Petition requesting the return of the weapons. We
again contacted Ms. Christian who had received our letter on November 11th. Ms. Christian
faxed us her response agreeing to the release of firearms to Mr. Kessler. See attached fax
communication.
Dear Judge Bayley:
If you have any questions, please feel free to contact me.
Sincerely,
b:J
Joan Carey
Attorney for Plaintiff- Respondent
cc: Jennifer Christian
Plaintiff
Bruce Grove: .
Attorney for Defendant
SERVING ADAMS, CUMBERLAND, FRANKLIN AND FULTON COUNTIES
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