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Home My WebLink About00-06119 ~.. "'". - -- -~; .,.- -,--~ -~.- "'-~Mi; Denise Null and Gary Null, Plaintiffs : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO: 00- UI9 CIVIL TERM John E. Janis, 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 ~ . /3 ,1ID,AT I: 30 P.M., IN COURTROOM NO. 1 OF THE CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA. You MUST obey the Order that is attached until it is modified or tenninated 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. g6ll4. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federallaw, 18 U.S.C. g2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside ofthe state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. g 2261-2262. You should take this paper to your lawyer at once. You have the right to have a lawyer represent you at the hearing. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to fmd 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 Connnon 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 acconnnodations 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. 1 I I I ,,, '" I~ 1'.'1 I !, ! " 16 !, ~I! , 11 HI ""?W_ ~ ,~ J.ll. ~m, ,< , ~" - ~-- '. ,? ",'-'"' - ~""'" S'F/) {, r::. ~ -, LU'l" h'it';,:F'i ..: F);':"/i /." <~" ',.'L) ('/' -'~' ", ,. -I ~rV""v!. , '~'_'I)jv it" VIlI"I'\I'. .i) -'fl!if."1 _ll',J _ :l.~~~,,,!,"!,>.~,,,_:_~, "<",,',,"'r_,)jWtn;rA;;l1,""1!f~~~!lm.'~~""~'if~~:~ '''~ HI --,,"~~ ~' ,-, . ".. " '- -' """"_""C-~'_~'_ -.~ " , lry,:';~ Denise Marie Null, Gary David Null Plaintiff , , : In the Court of Common Pleas : County, Pennsylvania v. : No. 50 - (./1,,/ . John Edward Janis II : CIVIL ACTION - LAW : PROTECTION FROM ABUSE Defendant TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: John Edward Janis II Defendant's Date of Birth is: June 10,1976 Defendant's Social Security Number is: 185-56-2298 Name(s) of All protected persons, including Plaintiff and minor children: 1. Denise Marie Null 2. Gary David Null AND NOW, on 6th Day of September, 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 ofthe above persons in any place where they might be found. 2. Defendant shall be evicted and excluded from the residence at: 420 Bloser Avenue Lemoyne, P A 17043 or any other pennanent or temporary residence where Plaintiff may live. Plaintiff is granted exclusive possession of the residence. Defendant shall have no right or privilege to enter or be present on the premises. ~~ . C"-, 3. Defendant is,prohibited from having ANY CONTACT with Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at Plaintiffs 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 places of employment located at The Department of Revenue, Strawberry Square, Harrisburg,Pennsylvania, and Clean Team Building Services, 651 Market Street, Lemoyne, Pennsylvania. 4. Defendant shall not contact Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 5. Defendant shall immediately relinquish any firearms license the Defendant may possess, and the following weapons to the Sheriff's Office or a designated local law enforcement agency for delivery to the Sheriff's Office. 1. Including, but not limited to, an 8-inch knife with a serrated edge, a box curter, and any other weapons Defendant may possess. Defendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration of this order. 6. The following additional relief is granted: - Prohibit Defendant from harassing Plaintiffs relatives. - Defendant shall not damage or destroy any property owned jointly by the parties or solely by Plaintiffs. 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: West Shore Regional Police Harrisburg City Police 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 IMMEDlA TEL Y TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL FEBRUARY 6, 2002 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO THEDEFENDANT ;"",,"-. ,t;..j;;,'}",'-, ~ """""~ M;~'" ,__ \' ,,- '-'--~ .', -, ~d ~~ .:,,,,.' H '." .~ .-0 l'r-'W;t;; 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. g6ll4. 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 court papers for that purpose. 23 Pa.C.S. ~6ll3. 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. gg226l- 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 5 of this Order, defendant shall 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 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 Sheriffs office of the county which issued this Order, which office shall maintain possession ofthe 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 ~H; COURT~L .. ....~---------TUQge , J:.. y 7 ;LoC)d .- n___ -- --}2---------------, Date Distribution to: Legal Services Faxed & Mailed to PSP ,-j" .', '. ~~ ~ " ~ "" ,-;",',-c ,__ 'i~~ PFAD Number: EMl133878Y Denise Marie Null, Gary David Null Plaintiff : In the Court of Connnon Pleas : County, Pennsylvania v. : No. /hJ _ {. /19 CLuJ. T ~ John Edward Janis II Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE 1. Plaintiff's name is: Denise Marie Null 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. Denise Marie Null b. Gary David Null 4. Plaintiff's Address is : 420 Bosler Avenue, Lemoyne, P A 17043 5. Defendant's Name is: John Edward Janis II 6. Defendant is believed to live at the following address: Conrad and Evelyn LeCato , Penn Street, Harrisburg, P A 7. Defendant's Social Security Number is: 185-56-2298 8. Defendant's Date of Birth is: June 10, 1976 ..i '- ..._- . -, , ,~ko, 0 - '" ~- ,,' ,- < ,< ~"b 9. Defendant's Place of employment is: Labor Ready Temp Agency, 2050 State Street, Harrisburg, or Preferred Temp Agency. 10. Defendant is an adult. 11. The relationship between the Plaintiff and the Defendant is: Parent I Child Other relationship by blood or marriage: UnclelNephew 12. The defendant has been involved in a criminal court action. 13. The defendant is not currently on probation / parole 14. The facts of the most recent incident of abuse are as follows: On about Sunday, September 03, 2000 location: residence On or a~out September 3, 2000, Defendant grabbed Plaintiff( Denise) by her arms and, at least twiCe, attempted to push her down the stairs. When Plaintiff freed herself from Defendant, he threatened that if he would have been successful in throwing her down the stairs, he would have set her on fire and taken pleasure in hearing her scream. Defendant grabbed his head with one hand and his neck with the other and made a jerking motion as he threatened Plaintiff that he could snap her neck. Defendant made a fist, and threatened that he could break Plaintiff's jaw in three different places. Defendant further threatened if Plaintiff even thought about calling the police, he would kill her. 15. 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: Later, on or about September 3, 2000, Defendant attempted to burn Plaintiff (Denise) with his cigarette, grabbed her by the arms, and pulled her off of the couch to a standing position. Defendant threw his lit cigarette onto the couch as he held Plaintiff and stated they were both going to watch the coach burst into flames and she better not try to put it out. When Plaintiff freed herself, Defendant grabbed her with one hand and with his other hand, made a fist turning it in a windmill motion as if he were winding up to punch Plaintiff, causing her to fear he was going to hit her. When Plaintiff stated she wanted to go upstairs to take a nap, Defendant threatened it may be the last nap she ever took. Defendant let go of Plaintiff who ran upstairs into her bedroom and locked the door. Defendant threatened that if she called the police he would get a knife and stab her. When the police arrived, Defendant had already left the residence. After the police left, Defendant returned to the residence, and Plaintiff called the police a second time. The police told Defendant he would have to leave the residence for the night. Defendant returned a third time in the early morning of September 4,2000, and Plaintiff(Gary) would not let him into the residence. Defendant became angry and threatened to burn down the residence or to have someone else do it for him. In or about March! April 2000, Defendant picked up a Rubbermaid storage bin and threatened to harm Plaintiff(Denise). The next day, Defendant got into a kitchen drawer, ~1I ~'"'"'"Iil""'~~"'" .-" ~ .~ - - ~t grabbed it knife, and waved it around as Plaintiff stood approximately one foot away. Defendant threatened Plaintiff that she was just lucky that he decided not to slit it throat and make her look like a pez despenser. Defendant further threatened that he would do to her what O.J. Simpson had done to Nicole Brown Simpson. In or about March/April 2000, Defendant threatened to spray Plaintiff (Gary) with lighter fluid and set him on fire. Plaintiff attempted to calm Defendant down, and Defendant threatened Plaintiff that he was going to get a shotgun and shoot him in the gut. The ned morning when Plaintiff came into the dining room, Defendant had a container of lighter fluid and' flicked his lighter causing Plaintiff fear for his safety. In or about 1999, Defendant went out into the kitchen and reached into a drawer as if he were going to get something out of it. Defendant, with a crazed look in his eyes, dared Plaintiff(Gary) to come out into the kitchen. Defendant threatened to cut Plaintiff causin!l him to fear for his safety. For the past year, Defendant has acted irrationally. On one occasion, Defendant pulled! out a butcher knife to go after Plaintiff(Gary). On several occasions, Defendant has threatened to shoot Plaintiffs, stab them, and to burn down their residence. On at least one occasion, Defendant threatened that if he really wanted to hurt Plaintiff(Deuise) he would do it where it would cause the most damage. Defendant has also threatened to harm the family dog. 16. The Defendant has used, or threatened to use, the following weapon(s) against the Plaintiff or the minor child/ren: a. including but not limited to: an 8-inch knife with a serrated edge and a box cutter, and any other weapons Defendant may have. 20. 17. The police department(s) or law enforcelllent agencies that should be provided with a copy of the protection order are: West Shore Regional Police Harrisburg City Police 18. There is an immediate and present danger of further abuse from the Defendant. 19. Plaintiff is asking the court to evict and exclude the Defendant from the following residence: 420 Bloser Avenue Lemoyne, P A 17043 Owned By: Marian V. Null 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. Evict/exclude Defendant from Plaintiffs residence and P~odhibit DfetDhendant from attempting to enter any temporary or permanent res! ence 0 e Plaintiff. 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 Plaintiff's school, business, orplace 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 Plaintiffs 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 temporarily turn over weapons to the Sheriff of this County and prohibit Defendant from transferring, acquhing, or possessing any such weapons for the duration of the Order. f. Order Defendant to pay the costs of this action, including filing and service fees. g. Order the following additional relief, not listed above: -Defendant shall not harass Plaintiff's relatives. -Defendant shall not damage or destroy any property owned jointly by the parties Oil' solely by Plaintiffs. -Defendant shall pay $250.00 to one of Legal Services, Inc.'s funding sources as reimbursement for litigation in this case. h. Order the police or other law enforcement agency to serve the Defen~ant with a copy of this Petition, any Order issued, and the Order for Heanng. The petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. Respectfully submitted, Date: -*-\ 60 Philip C. riganti, Andrea Le , and Maryann Murphy, Attorneys LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ',llfll""~- ,",,' ,"-,.C"" ,".,.,~,-- .lW.l!lI~:'::oJ',,-;-, VERIFICATION I verifY that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unswom falsification to authorities. Dated: ~/ oritZ> ""1..1l:li1!ll"~ " ','. __~,' _. _01_,'" ., ". _", '. ,-, "'"''''.'~'''';';'';'-''' . "~), VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. Dated: ~,4 ,?; f &uG ~h~;f 'l2uzL Gary Null, intiff _.~ ~~ ~ '.'> ,---> '') .;;;, l~ r.':;: '" \:;1 i- ..:."-- ,- Q c" 8- t 0 t~ ~ <J 0 ;f -- \::: 't ..; 0.. .~ ~ j "S /:3. u: :;> f1, --c:s .r <;:' '" c cJ: .S! :$ &. ,- -+' c' ~ ., c.>:.. '4S :2 2::~ .-'(:: -c. CS a;;::. ,,,,".,,,.. t '" C> ;r ~ N ~ ~, c-'.",::;. ;' 'g -~ , '", <:l.: So e ).} "- ,.. Q< I:L. \(\, <:: ~ .~ '\.;'~" ;: ~ <l " -.J , c" ;\ <~ "I) '" () l"\ , ~ D... V) t>.:. 1 1'.'/ ""'" l'Wq ~I!L , J~ll1. ." ,"--~ ~ JJm~ ~ ~ "C w .,.' C" > '. ';W~ilmW.l;lJW2!~~~~"?;WJ:l0iil;1$:;~~1ll'II!lW!Ii1!j!!"I!:€l~iN;;!$).l;Il~!I>1'l1j ,IW!l1~ '~~. '~iIIIIIIiiI"'"':"'~".' ,I,~_~;;. 09/07/00 THU 12:31 FAX 717 240 6573 CliMB CO PROTHONOTARY 141001 ********************* *** TX REPORT *** *******************~* TRANSMISSION OK TX/RX NO CONNECTION TEL CONNECTION ID ST. TIME USAGE T PGS. RESULT 2147 92438026 09/07 12:26 04'46 8 OK '" ".'0' ", <= '-'-~j;" 09/07/00 THU 10:33 FAX 717 240 6573 cmm CO PROTHONOTARY 141001 . , ********************* *** TX REPORT *** ********************* TRANSMISSION OK TXlRX NO CONNECTION TEL CONNECTION ID ST. TIME USAGE T PGS. RESULT 2145 92490779 09/07 10:29 04'31 8 OK , ; - ~~ " .:l 09/07/00 THU 11:49 FAX 717 240 6573 -~'" CUMB CO PROTHONOTARY ,~ 141001 TRANSMISSION OK TX/RX NO CONNECTION TEL CONNECTION ID ST. TIllIE USAGE T PGS. RESULT ********************* u* TX REPORT *** ********************* 2146 92438026 09/07 11: 45 04'35 8 OK ,1 _.~.... .- ',. , ~. iri!i:-)' , ~ Denise Null and Gary Null Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00- 6119 CIVIL TERM John E. Janis, Defendant : PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, this 13th day of September, 2000, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on September 13, 2000, at 1 :30 p.m. by this Court's Order of September 6, 2000, is hereby rescheduled for hearing on October 6, 2000, at 3:30 p.m. in Courtroom No.4. The Temporary Protection From Abuse Order shall remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. By the Court, ;1J Joan Carey - LEGAL SERVICES, INC.' ~ ~ t? )~?/ Attorney for Plaintiff John E.Janis -/11() -?t;tu ~ -df"~ ~ Pro Se Defendant ~, , '. ._. ,__~ c~ ;~~ _"" ... "~ ._~ F!LED--i)FFICE O~ 'r' ':: pCr,1'Wl",~IOtARY , , 1'''',. < ' ,,~lll' ,} -i\" 00 SEP 15 AM II: 29 CUMB>~RlJ..NO COUNTY PENNSYlVANIA ? -" .~~\lfI1l,OO-T'"h"~'i"'P"'fi',f-"!l";r,""~;\%'~~Hfk",j,"t"~l'":'WI1.'!Ii~~r,,,,,~~"~,@,ffiW~'@J!';j%-"':~,""T'~~~ ,;,j," 1>..l!liU ~-""'_." ""'- ~ ItiJ" --. 'i:;~- .. , Denise Null and Gary Null Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00- 6119 CIVIL TERM John E. Janis, Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE The Plaintiffs, Denise Null and Gary Null, by and through her attomey, Joan Carey ofLegal Services, Inc., moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. A Temporary Protection From Abuse Order was issued by this Court on September 6,2000, scheduling a hearing for October 6, 2000, at 3:30 p.m. 2. The Cumberland County Sheriff's Department deputized the Dauphin County Sheriffs Department to serve Defendant with a certified copy ofthe Temporary Protection From Abuse Order and Petition for Protection From Abuse. The Dauphin County Sheriff has been unable to effect service on the defendant. 3. The Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. Q-~ '.. ~~ --~ - ... - ~~.~~ ~",.~.,.",,--"' _ _-o.i _. ~ ~~' ... ,. WHEREFORE, the Plaintiff requests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Otder remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. drea Levy, ey for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 "n liIrrr/;l\!I!!~~"" t!ifJll~' J~lilf;l~~%.I!~@j!l.~r"'",,;i&,_~l'l!iH,,~~";;'ii;t;;;),-~.tf;!iH~~~~'---~iiiit " -:' ~ ".K.-~~"-~'~-'~ ~ o c: ;:"". eRr'. ~('- co ~", -<. r:~L- ~.:.,;: ~~~; ~ -=-, M."~~.J'-'-'-""""'-;ji; '~ I I! II Ii r ! " ~ c' ~ () --1'1 '" ""I "0 -'n 1:"'-:0: ),") ~ :::~~5 "".' ~ -;?~:~ (~ji-q :;-----j ,.1;- ,.J "< ~~ -'n ...,J ,,~ ,0, ~-"., . " --~ ._~ ~, .. .. .. .. .. .. ',~ ,--" .,,~~ "-,, ~~. ,p .,,~ , ~,," " ,,-~ , , '<, _n ,." .. ..._-~ -~~""'~ '. ~- .. ~~- , ,. .w..:..;.., . '"-~ll'~l':~ . . , > Denise Null and Gary Null Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 00- 6119 CIVIL TERM John E. Janis, Defendant : PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, this 6th day of October, 2000, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on October 6, 2000, at 3 :30 p.m. by this Court's Order of September13, 2000, is hereby continued generally. This Order is entered without prejudice to either party to request a hearing. The Temporary Protection From Abuse Order shall remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. By the Court, ~./Jl / A. Hess, Judge Joan Carey LEGAL SERVICES, INC. 1>e~ OAt ~ Attomey for Plaintiff oj John E.Janis - m\ I ~ ~ - ~~\ C~ m\ ~ 6vQ Pro Se Defendant ' . ~; ~ ~~W. ~~J d\d ~\ Mc<<.t ~-\\(Ctb d~~ -'~ 1 ~ ,~ "'illOO~~~'lliii!!liil'ij!,Sti[lg"'J'I',*,i~i'l~-""'=""'~' , dO"" '. ~, c 'M ," C'-.__ .., _,<." ,<,~~",_,~,"~o.._",- '".>~-< "<'"'.'.-,' 'J ~~!i\iliIiI!I!i ,.~~, "... ,.,~ ~- (') 0 C"i c: C -1'1 ;s;: 0 ::::J -VCC.1 C) ~fl' -..; '. :Xi , '-'T:,D zr"" (/) 2c: (y" , '-~; ':"<L_ "~~ c:) r::'C: :r:; S:~ ~~ ~~,ri 0 $~'~!. 20 )>C Z .w s.,-;: :< ::J:J UI -< ~~, ~ ,'" .." ,~ - ,~ ""_ IIbliliilllK -' ~ ,. . . Denise Null and Gary Null Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00- 6119 CIVIL TERM John E. Janis, Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE The Plaintiffs, Denise Null and Gary Null, by and through her attorney, Joan Carey of Legal Services, Inc., moves the Court for an Order generally continuing the hearing in the above-captioned case on the grounds that: 1. A Continuance was issued by this Court on September 13 , 2000, rescheduling the hearing for October 6,2000, at 3:30 p.m. 2. The Cumberland County Sheriff's Department deputized the Dauphin County Sheriff's Department to serve Defendant with a certified copy ofthe Temporary Protection From Abuse Order and Petition for Protection From Abuse. The Dauphin County Sheriff has been unable to effect service on the defendant. 3. The Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. ~,'" iliiIiM'iIl1I~" ' , , ~ ~-~' '-' UilMi ~~ . c WHEREFORE, the Plaintiff requests that the Court grant this Motion and generally continue this matter, and that the Temporary Protection From Abuse Order remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. Maryann urphy, Attorney for PI LEGAL SERVICES, INC. 8 Irvine Row Carlisle,PA 17013 (717) 243-9400 ,"",,;'"b~!ilIll"""~'-{;",I-@!<iJili**,,~'El;l~IlMl~;i1i",,~~~"'-~.a.."" ~- ~",_, ,-""<" '~.o ~ ' -. -", - ~,.,.. "'(") 0 G C CO " ".. 0 '"tJ(}~ .-_1 C) [!:Ifr --i - .'T:I 2:7"':': ZC , (f) - 0\ -< ",,'~ " , ~C) , ):::>" )->c' , "T-, Z.-: [~~ h~ ~C LO C Z :..n )~ ...., ~ -< Cl C< " ..~.~ ,~ "'",:,= -- " v~" -~'~5';' SHERIFF'S RETURN - OUT OF COUNTY ~ # CASE NO, 2000-06119 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NULL DENISE ET AL VS JANIS JOHN E R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: JANIS JOHN EDWARD II but w~s unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN serve the within PROTECTION FROM ABUSE County, Pennsylvania, to On December 1st, 2000 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surch~rge Dep. Dauphin Co 18.00 9.00 10.00 25.50 .00 62.50 12/01/2000 ~~ .' Thomas Kline Sheriff of Cumberland County Sworn and subscribed to before me this fL-o /'-I~ day of A~ Jirttf) A . D . Q<:,Q~~ 7' Prothonotary' "-,"_d"""""""'-., -~~ . n,'_I," ,kh W>\, ,. @flirt of t4~ ~4~:riff , William T. Tully Solicitor Ralph G. McAllister Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Pennsylvania 171 0 I ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania NULL DENISE & GARY NULL vs County of Dauphin JANIS JOHN E Sheriff's Return No. 2332-T - -2000 OTHER COUNTY NO. 20-6119 I, Jack Lotwick, She~iff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for JANIS JOHN E the DEFENDANT named in the within PFA ORDER FOR CONTINUENCE and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, November 21, 2000 DEFENDANT DOES NOT GO INTO THE ELBOW ROOM NOR HAS HE BEEN SEEN IN PORTER'S BAR. A CUSTOMER STATED THEY THOUGHT HE LEFT TOWN. NEED A BETTER ADDRESS FOR DEFENDANT. Sworn and subscribed to So Answers, ?R~ before me this 21ST day of NOVEMBER, 2000 $ffpbJ ,~~i~~) Sheriff of Dauphin County, Pa. By Deputy Sheriff Sheriff's Costs: $0. OOPD 00/00/0000 RCPT NO ,"",,=,<__'lltJ!"'"" " ~ _ .J. ,- - ,', =- - . . ""Iti..~ . In The Court of Common Pleas of Cumberland County, Pennsylvania Denise Null, et., al. , VS. 'John E. Janis No. 20-6119 Civil Now, 10117./00 , 20 Cl " , I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of ru."n!"\.;j:L County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. General Continuance' ~~"""'-€~, Sheriff ofCurnberland Coun-!:y, PA Affidavit of Service Now, ,20_, at o'clock M. served the within upon at by handing to a copy ofthe original and made lrnown to the contents thereof So answer,g, Sheriff of County, ]> A Sworn and subscribed before me this _ day of , ;0 , - COSTS SERVICE ]\iJ1LEAGE AFFIDAVIT $ $