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Home My WebLink About00-06608 ,=-'~ .J~, - .~ ,~~ "' J ._1 JilI'"^.....~~Jai.'""i<,',< SHERIFF'S RETURN - REGULAR CASE NO: 2000-06608 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND BROWN DARLENE VS DILMORE DONALD J CPL. MICHAEL 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 DILMORE DONALD J the DEFENDANT , at 0019:00 HOURS, on the 28th day of September, 2000 at 66 OLD STONE HOUSE ROAD MECHANICSBURG, PA 17055 by handing to DONALD J. DILMORE 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. Sheriff's Costs: Docketing Service Aft idavit Surcharge 18.00 6.20 .00 10.00 .00 34.20 So ;;~~~~t? R. Thomas Kline 09/29/2000 Sworn and Subscribed to before By: ~u~~ me this Q~ day of (J~ d--1rVU A.D. ~ OYn,~d,':. P othonotary '''''''-'''''''''''''-~ ~ , - DARLENE BROWN, Plaintiff : In the Court of Common Pleas : of CUMBERLAND County, : PENNSYL VANIA v. : Civil Action - Law : : No. 00-6608 DONALD JOHN DILMORE, Defendant : PROTECTION FROM ABUSE FINAL ORDER OF COURT Defendant's Name is: DONALD JOHN DILMORE Defendant's Date of Birth is: August 25, 1962 Name(s) of All protected persons, including Plaintiff and minor children: 1. DARLENE BROWN AND NOW, this 19th Day of Decemher" 2000 the court havingjurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows: PlaintiB:: Darlene Brown, is represented by Joan Carey of Legal Services, Inc.; Defendant, Donald John Dilmore, is represented by Charles O. Beckley, II, of Beckley & Madden. Defendant, although agreeing to the terms of this Order, does not admit the allegations made in the Petition. Plaintiff's request for a final protection order is granted.. 1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other protected person in any place where they Inight be found. ,~ ___,,"ii>"-~"'''''', - ,-" ~ ,~_[f,~ ~ rm!!lPt~~.",,~ .~~~ .,. r:il.ED~kDFFICE OF .;" ..'Ci,\'CJTAfty 00 DEe I 9 f\l :i: 52 CUrvlULfiLAi'JD COUN1Y PENNSYLV,I.\NIA JJ!1R''!J.1J, ,.,j, ,~ 'v'r,'-''''~ ;1.J,WK~~f'iWj~:!!il~~l1"~!MI!~~~Iffi~j~~~,~m.~lil'ln "__~!Q]~ 02"~~-,,~~+~. " -" 1_, - '.~-~'-""'_~'iJ"'-i-",,,.,,l.',<l'~' 2. Defendant is prohibited from having ANY CONTACT with the Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at Plaintiff's school, business, or place of employement. Defendant is specifically ordered to stay away from the following locations for the duration ofthis order. Plaintiff's current residen~e which is confidential, and any other residence she may in the future establish for herself. Plaintiff's place of employment: K&H Ford 6320 Carlisle Pike Mechanicsburg, PA Contact of Plaintiff by Defendant's attorney for the limited purpose of communicating information regllrding pending litigation between the parties, or of conducting discovery shaU not be constrned as a violation ofthe contact provision in paragraph 3 of this Order, regarding contact through third persons. 3. Defendant shall not contact the Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 4. The following additional relief is granted as authorized by g6108 of the Act: Defendant is prohibited from having any contact with Plaintiff's relatives. Defendant is ordered to refrain from harassing Plaintiff's relatives. Defendant enjoined from damaging and/or destroying any property jointly owned by the parties or owned solely by Plaintiff. The court costs and fees are waived. ""'"'~,,-,~- u j J~ ~~ .'---. - .o._~ 5. A certified copy of t~s Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: EAST PENNSBORO TOWNSHIP POLICE DEPARTMENT HAMPDEN TOWNSHIP POLICE DEPARTMENT PENNSYLVANIA STATE POLICE 6. THIS ORDER SUPERSEDES: 1. ANY PRIOR PF A ORDER 7. All provisions of this order shall expire on: June 19, 2001 NOTICE TO THE DEFENDANT VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S. ~61l4. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. ~2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C ~~2261- 2262. IF THE :BRADY INDICATOR PARAGRAPH APPEARS IN THE ORDER, YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES, UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT, 18 U.S.C. ~922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION. NOTICE TO LAW ENFORCEMENT OFFICIALS l """''"''='''''''''''''"'''''''''''''~~'U'''''~''''~'~,:<:r"i,. _",I ..I L._... .~",\l1"',~&"""'<''''''_' The police who have jurisdiction over the plaintifl's residence OR any location where a violation of this order occurs OR where the defendant may be located, shall enforce this order. An arrest for violation of Paragraphs 1 through 3 of this order may be without warrant, based soley on probable cause, whether or not the violation is committed in the presence of the police. 23 Pa. C. S. ~6113. Subsequent to arrest, the police officer shall seize all weapons used or threatened to be used during the violation of the protection order or during prior incidents of abuse. The shall maintain possession of the weapons until further order of this Court. When the defendant is placed under arrest for violation of this order, the defendant shall be taken to the appropriate authority or authorities before whom defendant is to be arraigned. A "Complaint fur Indirect Criminal Contempt" shall then be completed and signed by the police officer OR the plaintiff. Plaintiff's presence and signature are not required to file the complaint. If sufficient grounds for violation of this order are alleged, the defendant shall be arraigned, bond set and both parties given notice of the date of the hearing. tiff arey, Attorney for P . LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 Distribution to: Joan Carey, Attorney for Plaintiff LEGAL SERVICES, INC. - ,~ ~ ~ Charles O. Beckley, II, Attorney for Defendant BECKLEY & MADDEN "', '" -.. , ti- nt. >-.. <-,~~ . .... .:.. <> , , ~ ~ ~ ~~ I...." ~~, - .~ .......k,.,-~J _. " ~'Lllil;!;o_,_iloI~"<"liIlI,,,'i',"""",., 12/19/00 TUE 16:30 FAX 717 240 6573 CUMB CO PROmONOTARY @001 *************************** *$$ MULTI TN REPORT $*$ *************************** TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2349 [ 01l9p2405331 [ 0319p2438026 [ 04192490779 CENTRAL PROCIESS LEGAL SERVICES PSP ERROR ". Off"ICE Of mE PROI'H()IlOI'ARY CUMBE;RLAND CXXJNTY o:xJRTIiCUSE . ONE COORTHOJ5e SQUARE ~LISLE. PA. 17013-3387 (717) 240-6195 FAX ,; psP LS .J . C. ett{ ({)./ Irot...-c 55(11. J q-cl4o- 533/ FAX (717) 240-6573 V I ATE L E COP I E R 10: FRa1; CURTIS R. LONG RE: -P FA OrrJ .e,,-s MESSAGE: . 2L NO. OF PAGES (IOCWDING COlIER SHEET) .J'~.~ 'lllis ~ is intarlrl ally fir tte we of tte :irdi.vidull cr entity tIJ Wrlch is is ~, .;rd rn:ry OO1tain .infi::mTat:im t:tat 5s p:ivi..leg;rl. a:nfidential a-rl aa;np; frxm <'Ii...-l...... Ifl3 url!r ~lin-bl..}a<I. [f tJ-e ~ of: this" ""'J" is rot Ii... .inle"fk1 ra::ipient, }UI am ~ rutified ttet coy ~Itit:n, distrib..rt:irn cr o:pf:in;J of this t;01TTU"\jrntiO'l III strictly px:hi.bilB:l. [f}UI h;lI.e ureiwi lIl",; <XITl1l.l'Iit:.,tia1 in eJ:IU[", pl.a:e;! rotifY ill inrreiiafEly ~ lI':l.e(:h:re a-rl return de oc:igimlll "g' to LE ill t.te .:tD.'_' aiire'l3 via tie i!.S. ID'tD.1 S2t'-iro. 'Il"ai<; ',OJ. C'l'_ I__..J_ -0 .. ~ ~~~ DARLENE BROWN, Plaintiff : In the Court of Common Pleas : of CUMBERLAND County, : PENNSYLVANIA v. : Civil Action - Law : : No. 00-6608 DONALD JOHN DILMORE, Defendant : : PROTECTION FROM ABUSE CONTINUED TEMPORARY ORDER AND NOW, this 30th Day of November, 2000, pursuant to 23 Pa.C.S. ~6107(c), the terms and conditions of the Temporary Order issued on 28th Day of September, 2000, in the above- captioned case are hereby continued in full force and effect until further order of the court. Distnl>ution To: Joan Carey, Attorney at Law LEGAL SERVICES, INC. 8 Irvine Row, Carlisle, P A 17013 [,"uV .>>-J I;J.' ~ '1'""":\ Charles O. Beckley, II BECKLEY & MADDEN P.O. Box 11998, Harrisburg, PA 17108-1998 ~ FAXed aM mailed te PSP '1 - ~ ',Jiiio' OF Ii FIi ;:'1)" ~I'\;'P('1C "-,,"- ._", I II.,Jj_ :cc :";r;Tj,'n:\'()TAlRY " ">'" ',JJ 1'-. If\i 00 DEe -6 Arl 9: 34 CUMBERLAND COUNT{ PENNSYLVANIA i,~" . ",) . U~~8!lll"~ ITlfil!i; iW!!'~~~~_.~,. ,;,.)>__r-mr'ti!.~~~~!U~!{u!~~~~~~'~' .,,"=~-~"".~ ""I ~ LI .4~ l~biI~~- ~g"",;t: ". DARLENE BROWN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-6608 CIVIL TERM DONALD JOHN DILMORE, Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff, Darlene Brown, 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, An Order continuing the hearing was entered on November 8, 2000, rescheduling the hearing to November 29,2000, at 1:30 p.m. in Courtroom NO.3. 2. The parties agree, by and through their respective counsel, that the hearing be continued generally to facilitate settlement in the case. 3. Plaintiff requests that the Temporary Protection From Abuse Order remain in full force and effect pending further Order of Court. WHEREFORE, Plaintiffrequests that t\J.!: Court gT!lllt t\1isMotion and generally continue this matter, and that the Temporary Protection From Abuse Order remain in full force and eiThct pending further Order of Court. oan Carey, Attorney fi LEGAL SERVICES, ,c. 8 Irvine Row Carlisle, P A 17013 "', '''..__..:''..,'''_.~,(,;..:~A,-'~, _~JCiI'!1lIlBI_ : ',') "~',>,, :,'- ~ll,~1IJlCf.I1 - : '",-',,: "':._~~1lJ~~~Ju~l!!l~ ",_IIiiilIllll_, ~all-jL~fifJ ~~~iil.~1. """,.,, '",~,~, "-",'''",,.>-< . ~,' ",."". , -,~ :jjjiliilJiiiIlWBf. 0" ""'iIi- ,,',,~ (") (:;) 0 C c:> "\~i' -oS:: ~ ~ m c::. [!In'/ .<::: e'j::!] ,2;::0 r- 2<;: W '':ill . C/)....~" 0 )J 'i' ;::$' &1CJ ...'-: s:;C ." -"'~,- ""r' ?Eo ::1:: O:D ->() :;>0 ~ Om !;; :;j' W ;;g .s::- -<: .' -'i "".I Ii I, " 11 Ii Ii I' Ii " II " i '1 I i ,,,,,.,,,,",,,,,,,,,,,,,,~,,,,~L;~ _ .. -~ . j , I............ "ilirJ~il!"'h.;. DARLENE BROWN, Plaintiff : IN THE COURT OF COMMON PLEAS OF vs. : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 00- &C4 CIVIL TERM DONALD JOHN DILMORE, 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 pro~:d against you and a FINAL Order may be entered against you granting the relief requested in the Petition. ']11 particular, you may be evicted from your residence and lose other important rights. A hearing on this matter is scheduled on the ~ay of October, 2000, at 3 : 3D ~.m., in Courtroom NO)-, 4th Floor, Cumberland County Courthouse, 1 Courthouse Square, Ca s e, Pennsylvania. You MUST obey the Order that is attached until it is modified or terminated by the court after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six months in jail under 23 Pa. C. S. ~6114. Violation may also subject you to prosecution and criminal penalti($ under the Pennsylvania CriJnes Code. Under federal law, 18 US.C. ~2265, this Order is enforceable anywhere in the United States, tribal lands, US. 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 US.C. ~ 2261-2262. You should take this paper to your lawyer at once. You have the right to have a lawyer represcnt 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 offiCll. 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. ."""",,,,,,,...._,,,,,,,,, L,~ - ~l ~lfIIJail1 ,..J.~--"'.","'~' r~, DARLENE BROWN, Plaintiff : In the Court of Connnon Pleas : of CUMBERLAND County, : PENNSYLVANIA v. : Civil Action - Law : No. 00- t. (. or DONALD JOHN DILMORE, Defendant : PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: DONALD JOHN DILMORE Defendant's Date of Birth is: August 25, 1962 Name(s) of All protected persons, including Plaintiff and minor children: 1. DARLENE BROWN AND NOW, on 28th Day of September, 2000 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: Plaintiff's 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. ,""""''''''''''''....'"'''''''''.o-.J L !.""~'!I-'l;,;," 2. 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 Plaintift's school, business, or place of employment. Defendant is specifically ordered to stay away from the following locations for the duration of this order. Plaintiff's current residence which is confidential, and any other residence she may in the future establish for herself. Plaintiff's place of employment: K&H Ford 6320 Carlisle Pike Mechanicsburg, PA 3. Defendant shall not contact Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 4. The following additional relief is granted: Defendant is prohibited from having any contact with Plaintiff's relatives. Defendant is ordered to refrain from harassing Plaintiff's relatives. Defen~t enjoined from damaging and/or destroying any property jointly owned by the parties or owned solely by Plaintiff. 5. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: SILVER SPRINGS TOWNSHIP POLICE DEPARTMENT EAST PENNSBORO TOWNSHIP POLICE DEPARTMENT HAMPDEN TOWNSHIP POLICE DEPARTMENT PENNSYLVANIA STATE POLICE 6. 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. 7. THIS ORDER SUPERSEDES ANY PRIOR PFA ORDER """"-.iiill....",,"~~' ~,-J.._ ~.~ ',' "~ ~ ""'" , " <"~L_, ffi~ip.? 8. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MARCH 28, 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 $1,000.00 and/or up to six months in jail. 23 Pa.C.S. 96114. Consent of the Plaintiff to Defendant's return to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers fOT that purpose. 23 Pa. C. S. 96113. Defendant is furtheT notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. 992261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shal1 be enforced by the police who have jurisdiction over the plaintiffs residence OR any location where a violation of this order occurs OR where the defendant may be located. If defendant violates Paragraphs 1 through 3 of this Order, defendant shall be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is connnitted in the presence of law enfoTcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sherifi's office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this court, unless the weaponls are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. Judge Date Distribution to: Joan Carey, Attorney for Plaintiff '~~'- .>> ,~, -.,1 t ",^,",,4'ill'.(l!l\1!l!iI1' J '" -,~ o~'~ ~.: 'n sr-; 'I A UJ >eC' (., V b'''_' II ..\--t'\:=FlCf ~,:;-:i, ";""';')T"Py : ; i' i' ',,;;';~ r"U \ n" , . I C; ;- n L,S. .., CUMb:::'f-i:y"iD COUi'-<'lY PENNSYLvANIA ?,..~ :il~j <>l"1f~~'0""".i$l"P"'l!jjj!p""""'i?-'NlW:'2"'f*"'~<}'Ej~INjl"ill;1~~~~!lii,~~.~,~~=-"- 1, ,~)!:':';'f"~ ~,""""""" - . ~I ~~ . j- )!fi,_~~~6 LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 FAXed & Mailed to PSP """~ ~ I. -~ . L ",' ,I ~'~ ~-- .'"'-"'"~~, PFADNumber: WP1l43036A DARLENE BROWN, Plaintiff : In the Court of Common Pleas : of CUMBERLAND County, : PENNSYL VANIA v. : Civil Action - Law . : No. 00- f,I,OY DONALD JOHN DILMORE, Defendant : PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE 1. Plaintifi's name is: DARLENE BROWN 2. I, (the Plaintifl:), am filing this Petition on behalf of: - myself 3. Name(s) of ALL person(s), including minor children, who seek protection from abuse. a. DARLENE BROWN 4. Plaintiff's address is confidential 5. Defendant's Name is: DONALD JOHN DILMOU ,,;,;,,,:,,:"','""""'"==__IOibi - ~ c' ~"'~illllilliiililll 0' ---"''1'~_!i1m:i) 6. Deti-mdant is believed to live at the following address: 66 Old Stone House Road, Carlisle, PA 17013 7. Defendant's Date of Birth is: August 25, 1962 8. Defendant's Place of employment is: unemployed 9. Defendant is an adult. 10. The relationship between the Plaintiff and the Defendant is: Current or former sexual/intimate partner 11. The defendant has been involved in a criminal court action. 12. The facts of the most recent incident of abuse are as follows: On about Monday, September 25, 2000 location: Village Park Mobile Homes, Lot 7, Brandy Lane, Mechanicsburg, P A On or about September 25, 2000, while Plaintiff and her son, Hans, were staying at her friend's residence for their protection and to avoid further abuse from Defendant, Hans heard noises ontside the residence and saw Defendant crouching near Plaintiff's car, letting the air out of the tires. When Hans confronted Defendant, he hit Hans in the chest and threatened Plaintiff saying, "I'm gonna get you no matter what. Now try driving with twonat tires." Defendant got into a waiting car, and as Plaintiff tried to look at the license plate, the driver swerved the car toward her causing her to jump out ofthe way to avoid being struck. Plaintiff recognized the vehicle as one that she had seen parked near her place of emplOyment and near the mobile home park where she was staying on several occasions since she left Defendant's home, causing her to fear that he was stalking her and her children. 13. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor childlren, (including any threats, injuries, or incidents of sta1king) are as follows: On or about September 19, 2000, Defendant telephoned Plaintiff's place of 'l'e,.~_j._ ~._. " I , . IO~~,..;;;;",+, employment, and when one of Plaintiff's co-workers told him that she was not available, he told the woman to give Plaintiff the following message: "Call me or I will have no other recourse than to do things I don't want to do; it would be in your best interest to call or I will do things to you physically and legally." On or about September 15, 2000, Defendant shoved Plaintiff aside as she entered the house, yelled and screamed at her and her son, Hans, called them vile names, andrepeatfllly spit on both of them. Defendant shoved Hans about, told Plaintiff and Hans to leave, shoved Plaintiff, took the car keys,jerked all the telephone cords out of the wall jacks, and left. Fearing for their safety, Plaintiff and her son left the residence and went to stay with her friend. Since PlaintitTleft his residence, Defendant has repeatedly telephoned her at her place of employment despite her telling him not to call her. In or about March 2000, Defendant shoved Plaintiff out of the bedroom, and when she said she was leaving, Defendant took her car keys, moved her car and hid it from her. Plaintiff's son came and took her back to her apartment. Shortly after she retnrned to her residence, Defendant began telephoning her approximately every 5 minutes, causing her to disconnect tbe telephone. In or about Febrnary 2000, Defendant screamed at Plaintiff as she drove, shoved her arm while she was holding the steering wheel, causing Plaintiff to lose control of tbe car which then veered across several lanes of traffic. Fearing for her safety and traumatized by the incident, Plaintiff stopped the car and walked to a telephone, where she called her son to get her. Since approximately May 2000, Defendant has threatened Plaintiff repeatedly telling her that if she leaves him he will get even with her; that he will be a thorn in her side for the rest of her life, and that he will destroy her life. Defendant has repeatedly telephoned Plaintiff at her residence and at her place of employment, Ilnd has also telephoned Plaintiff's daughter repeatedly. Defendant has threatened Plaintiff, her daughter, and her son, with physical harm and threatened to find them wherever they may try to hide. 14. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: SILVER SPRINGS TOWNSHIP POLICE DEPARTMENT lEAST PENNSBORO TOWNSHIP POLICE DEPARTMENT HAMPDEN TOWNSHIP POLICE DEPARTMENT PENNSYL VANIA STATE POLICE 15. There is an immediate and present danger of further abuse from the Defendant. ' 16. ]FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ","..;",,,,,,~,,,",,,,,......,)~" I ~, ,.1 ~'\i;:_"~_I",;"=,e';~'''',I<','_ 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. 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 Plaintifl's schoo~ 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. c. Prohibit Defendant from having any contact with Plaintifl's relatives and Plaintifl'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. d. Order Defendant to temporarily turn over weapons to the Sheriff of this County and prohibit Defendant from transferring, acquiring, or possessing any such weapons for the duration of the Order. e. Direct Defendant to pay Plaintiff for the reasonable financial losses suffered as the result of the abuse, to be determined at the hearing. f. Order Defendant to pay the costs of this action, including filing and service fees. g. Order the following additional relief, not listed above: Order Defendant to refrain from harassing Plaintiff's relatives. Enjoin Defendant from damaging and/or destroying any property jointly owned by the parties or owned solely by Plaintiff. Order Defendant to pay $250.80 to one of Legal Services, me-'s funding sources as reimbursement for litigation in this case. h. Grant such other relief as the court deems appropriate. 1. Order the police or other law enforcement agency to serve the Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where . ~.,I ~~ Date: ~ Defendant can be served. q h f3 100 / / ~~- ....~~'w--~"'''''''; Respectfully submitted, ~AL~~ Maryann Murphy Attorneys for Plaintiff LEGAL SERVICES, INe. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 """'~~-"~I~ ~, ~"~~"""2;,1 VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S.~4904, relating to unsworn falsification to authorities. Dated: 9....26-00 , " ~1i~ii!il~~:UWM;/'1111[~,,"\l>lli!:!m~"i~>'l,!~g,,"':>!ir..1ihEl~~,~~,$i~r~' ;,=~~.'~ ~-U*ii""""''''''' ['" . 0' ~ Iajt/~ 9~/&tJ /:-5_/:J. .A' ~d> t.' I' ~I~"P(' 1.'.5 ~ ~ ~ a:--I 4-j$~ fJ~tJ~ ~~ ~ Co /0 3, uiJ '-j-" I I I I I 'n lll"' '"., r " o c: "" -o~. fT!11' :-Z'~~ -,~ /-'- <f} d:;~. ~~~ ~o ..v'~~ ~"-i ..< 0' C) (:;:::\ ---;'1 U' j"~f'" ~T) ,..., C)) -.:; :':,J,:;: _,,:1 "i..c- ::,.~J,12j" ;-, L '. -:~2{$. Ij,~~?t ~\ ':r.:..~ :.0 --<.. ~ tfl ,p _ ,,"~4 =~,,~._1 -- -"" ~_.1 1- CUMB co PROTHONOTARY " 'lllllill~i " "'"". ~ 001 "" "'-'<(;, 09/28/00 THU 15:48 FAX 717 240 6573 . ***$*********************** *** MULTI TN REPORT *** *************************** TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2195 I 01]9p2405331 [ 03]9p2438026 [ 04]92490779 CENTRAL PROCESS LEGAL SERVICES PSP ERROR ~ OFFICE OF 1HE PRarHCX\UI'ARY CUMBERLAND CCX.lNTY COUImiOOSE ONE COOR'rnOOSE SQUARE CARLISLE. PA. i7013-3387 (717) 240~6195 FAX (717) 240-6573 TO: Cef\tral ?r-oc.ess v. I LS PA STATE POLICE A TELECOPIER FAX H: 717-249-0779 ) FRCM: CURTIS R. LONG RE: PFA ORDERS MESSAGE: -1- 9 00. OF PAGES (IN:r..uoING COVER SHEET) This ~ is int:arB1 ally fur tte \Be of Ire in:lividLal. CJ[" e1tity lD W1id1 is is c:rllt. i. aU ITBJI antoin :inftmtBtia1 tret is ~. a:nf:idential crd ecmp: fmn ni.....l=1re u1Er: '{Plirffilp 1:W. If. tte mai:3:" IX this ~ is rot tiE inta'L'e:1 re::ipimt. ~ are ~ mtifiej tret i'Dj di$etnin:ltim. distril:ubm or: awirg of this C01TfUlin3+.Jm is strictly JXdribit.ed. If ~ h3I.e IECEi..e;! Ims mmuucr.Jro :in en:>.:r. pla:Be rotify u; imre:li.atcly I:y ~:re crd return tie or:igirel " --g:>lD L6 at i-ho ..::t--'.. ~'"C" ~.....=> H-,,-.. ff co ___1 ___~_ .........-.. _'"--""'"""-JI'-iHa;.;r,_~ ~ . ., ~ .,- -"t~~ DARLENE BROWN, Plaintiff : In the Court of Connnon Pleas : of CUMBERLAND County, : PENNSYL VANIA v. : Civil Action - Law : No. 00-6608 DONALD JOHN DILMORE, Defendant : PROTECTION FROM ABUSE CONTINUED TEMPORARY ORDER AND NOW, this 4th Day of October, 2000, pursuantto 23 Pa.C.S. ~6107( c), the terms and conditions of the Temporary Order issued on 28th Day of September, 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 18, 2000, at 3:00PM in Courtroom No.3, 4th Floor of the Cumberland County Courthouse, One Courthouse Square, Carlisle. BY THE COURT: Charles O. Beckley, II BECKLEY & MADDEN P.O. Box 11998, Harrisburg, PA 17108-1998 C~f{\~~ /O-~-OO ~X~ Distribution To: Joan Carey, Attorney at Law LEGAL SERVICES, INC. 8 Irvine Row, Carlisle, PA 17013 ~~".~,'- ~" ..,~ ~,~ __p'-~7.~!il'I~~flm.\Ii~IWIl!!RI I! c' - J' 00 eCT -0 !,11 8::-;9 ",,,' ""-, {""lJ"m' CU1Wjt:\'-I~),l\jLJ vv i~ PENNSYLVANIA ~~~j"f)lr:I-n'''''''?F;,1i''1'f;''H'''')l(qIR'f,,!~.TtI-:'~~\'''''''''~~~@'-f~~~~i!\'i!!K_"..,.-. '. ~J "_il",,,,,,,,,,,,,.'I'-~oIllii1l - .~ "" .'. .,,~~ ,~" '~jii DARLENE BROWN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-6608 CIVIL TERM DONALD JOHN DILMORE, Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff, Darlene Brown, 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. A Temporary Protection From Abuse Order was issued by this Court on September 28,2000, scheduling a hearing for October 4,2000, at 3:30 p.m. in Courtroom NO.3. 2. The Cumberland County Sheriff's Department served Defendant with a certified copy of the Temporary Protection From Abuse Order and Petition for Protection From Abuse at his residence at 66 Old Stone House Road, Carlisle, Cumberland County, Pennsylvania, on September 28,2000, at 7:00 p.m. 3. Defendant has retained Charles O. Beckley of Beckley & Madden to represent him in the matter. 4. The parties agree, by and through their respective counse~ that the hearing be rescheduled to facilitate settlement in the case pending. S. Plaintiff requests that the Temporary Protection From Abuse Order remain in full force and effect pending further Order of Court. .e~,_~ ~. ~ L_....I ..............~~~ lf1ii1i(',i!~ WHEREFORE, Plaintiff requests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in full force and effect pending further Order of Court. Carey, Attorney for LEGAL SERVICES, 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 Ii ',' ",. i'"';"-"""___,",@1"""""_"N"'i."",,,,-",,,-'.'~ ,,' II '"I .'~ "'''"'"=~'\dl~ o (- ~ Ll-" rnr~l 2" !_( Zf"',' (1))-:', ~.;:;,;. >c:::C ::r;;. ~5" c:: ::? ~ "ikl" r.- (-0 , ~'I i I C"';; <:::> a ('j -I o ~;- ~ c";; s~; :::,(; ,";::l."j' !-~'srr~ ~ 5j --< '='-? ,~ .,.~,) :"'~I '..~--, ,1- I", " . ~ "'~~ ,. . DARLENE BROWN, Plaintiff : In the Court of Common Pleas : of CUMBERLAND County, : PENNSYLVANIA v. : Civil Action - Law : No. 00-6608 DONALD JOHN DILMORE, Defendant : PROTECTION FROM ABUSE CONTINUED TEMPORARY ORDER AND NOW, this 19th Day of October, 2000, pursuant to 23 Pa.C.S. ~6107(c), the terms and conditions of the Temporary Order issued on 28th Day of September, 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 November 8, 2000, at 1 :30PM in Courtroom No.3, 4th Floor ofthe Cumberland County Courthouse, One Courthouse Square, Carlisle. P. Judge Distribution To: Joan Carey, Attorney at Law LEGAL SERVICES, INC. 8 Irvine Row, Carlisle, PA 17013 c.~-{Y\~ 10-15-00 1?K~ Charles O. Beckley, II BECKLEY & MADDEN P.O. Box 11998, Harrisburg, PA 17108-1998 ".... ~~., """",,,,,,..JlI__liMf!!,, ~~I~~ .'~ .. ".,,' '. " "'''M' , ''''of ,'1,1 (', I'~( '-' i -.. " , .. ,) ; ", '.. " , ) '.. CUh/i::~;..:;- it) ;..,',~',J>.:i'Y "'~'I'I'''' I-'Ci \j\\")'( L\//\:\I!/\ ".."~.._"'~' '"-. ~, .. . .~ .,~~_.. ~~,,,,:~~W~~~~~~~.~~~~~t., I '''..'' ,llIItJI ""-"~~",,,".."~_J.. ..:! ~n"= '~ " ~. ~~ ~ ~Ii"r&m ~ . DARLENE BROWN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-6608 CIVIL TERM DONALD JOHN DILMORE , Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff, Darlene Brown, 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. An Order continuing the hearing was entered on October 4, 2000, rescheduling the hearing to October 18, 2000, at 3:00 p.m. 2. The parties agree, by and through their respective counsel, that the hearing be rescheduled to facilitate settlement in the case. 3. Plaintiffrequests that the Temporary Protection From Abuse Order remain in full force and effect pending further Order of Court. WHEREFORE, Plaintiffrequests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in full force and effect pending further Order of Court. Carey, Attorney for laintiff LEGAL SERVICES, C. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ,i~"""'" 1Ir4~~,'~cl,~~' r DARLENE BROWN, Plaintiff : In the Court of Common Pleas : : of CUMBERLAND County, : PENNSYLVANIA v. : : Civil Action - Law : No. 00-6608 DONALD JOHN DILMORE, Defendant : : PROTECTION FROM ABUSE CONTINUED TEMPORARY ORDER AND NOW, this 8th Day of November, 2000, pursuant to 23 Pa.C.S. ~6107(c), the terms and conditions of the Temporary Order issued on 28th Day of September, 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 November 29, 2000, at 1 :30PM in Courtroom No.3, 4th Floor of the Cumberland County Courthouse, One Courthouse Square, Carlisle. r E. Hoffer, P. Judge ~~ -fY1aJJ , 1-9-00 Rgg Distribution To: Joan Carey, Attorney at Law LEGAL SERVICES, INC. 8 Irvine Row, Carlisle, PA 17013 Charles O. Beckley, II BECKLEY & MADDEN P.O. Box 11998, Harrisburg, PA 17108-1998 .". ~JiiT . L.~ !lWJf -, .'. ~..>, '~'" . " '~"I"" c ~."~. ~" ,~, ~ ~. .,;>....'~. 0 C) 0 c c::> "T1 s: :ie. -ow c::> lJ~L1::: ~r.:: .T'! .d..~ .J..J r"- ZC" I 1r;1 ~2~~: 'D :,~,)O r;;::C; :~ ~~~~ 2:>C1 _...~~ ~~ (~3 ",' , j;C) <.0 ESrn c z :;;! =< '"' :D -< -, ~-\!"ljJMUI,!~~'WjJ.;J,lI!W~~f3'<1f,0;r.W'f*,'''f<'''1''~';>'"~'\~'>;';'':!JI\~)'-;~i?<J;:jijiJ'1j-jllll;MJill~')~i~lilj~ijl.~iiI~!l,~-~ e:: \!~' . ~<"...L~ 0 . .. ~~"; DARLENE BROWN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 00-6608 CIVIL TERM DONALD JOHN DILMORE, Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff, Darlene Brown, 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. An Order continuing the hearing was entered on October 19, 2000, rescheduling the hearing to November 8,2000, at 1:30 p.m. in Courtroom No.3. 2. The parties agree, by and through their respective counsel, that the hearing be rescheduled to facilitate settlement in the case. 3. Plaintiff requests that the Temporary Protection From Abuse Order remain in full force and effect pending further Order of Court. WHEREFORE, Plaintiff requests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in full force and effect pending further Order of Court. arey, Attorney for LEGAL SERVICES, 8 Irvine Row Carlisle, P A 17013 0". " '1~diSJ~iilI~~~i~}-"l€m~t'fr~&Hir!!ti!/t%WWf:\.:fJ!i#>lk~~i:Hfu'';'-h-ilih''J;,:(L0''''';:'i,..,,-"Bl,,~.;;,g~ ~ '.'. ""'lll' . '~~;1!m;1 'j) c,. ",,., -'~,_~"_~,"._ ~ ,." .~,~~,~ '__d ,.k ,v,,_, , ~, "" " UlIL III '~li'ilIIJjf J', ,~ 0 0 0 <;;: 0 -n <:JEi:; ;;;1: 111fT' C., ~:):; ,,<:: :g L..r-- I r'~.' (f)"- :~~~ ~E::: CO :So y ;'=~H Z'; ~ :,?C") ,-:::(~ J>C= ~ c5nl z -,., =< :..:> J.~ ();) :1J -<