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Eleni Imes,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: NO. 00- (g'l (p 3
CIVIL TERM
Robert 1. Gramm, Jr.,
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, )Iou may be evicted from your residence and lose other
important rights.
A HEARING ON THIS MATTER IS SCHEDULED ON ~ 1'1 ,2000,
AT r: 30 II .M., IN COURTROOM NO. I OF THE 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 fme of up to $1,000.00 and/or up to six months in jail under 23 Pa.C.S. ~6114. Violation
may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes
Code. Under federal law, 18 U.S.C. ~2265, this Order is enforceable anywhere in the United
States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel
outside of the state and intentionally violate this Order, you may be subject to federal criminal
proceedings under the Violence Against Women Act, 18 U.S.C. ~ 2261-2262.
You should take this paper to your lawyer at once. You have the right to have a lawyer
represent you at the hearing. The court will not, however, appoint a lawyer for you. If you
do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find
out where you can get legal help. If you cannot find a lawyer, you may have to proceed
without one.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE, CARLISLE, PENNSYLVANIA 17013
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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Eleni Maria Imes
: In the Court of Common Pleas
: County, Pennsylvania
Plaintiff
v.
: No. f>o - t. "&3 W J.i---
Robert L. Gramm Jr.
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
Defendant
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: Robert L. Gramm Jr.
Defendant's Date of Birth is: February 4,1965
Defendant's Social Security Number is: 164-62-6808
Name(s) of All protected persons, including Plaintiff and minor children:
I. Eleni Maria Imes
AND NOW, on ~i ii, 20bO 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.
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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 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.
- Plaintiffs place of employment located at Fairview Township Police
Department, 599 Lewisberry Road, New Cumberland, Pennsylvania.
- Plaintiffs residence located at 1228 Blossom Terrace, Boiling Springs,
Pennsylvania.
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. 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 Sheriffs Office.
I. Any and all fIrearms and/or weapons, specifIcally
including, but not limited to: 9mm Baretta (Defendant
carries on him)
2. Glock
3. 357 Magnum
4. 38 Special
5. 22
6. 380
7. Defendant shall also relinquish to the Sheriff his permit
to carry a conceled weapon
Defendant is prohibited from possessing, transferring or acquiring any other
firearms license or weapons for the duration ofthis order.
5. The following additional relief is granted:
- The Cumberland County Sheriffs Department shall attempt to make
service at Plaintiffs reqilest 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
if.."l'id.'_
of this Order to Defendant by mail.
- This Order shall remain in effect until modified or terminated by the Court
andean be extended beyond its original expiration date if the Court finds that
Defendant has committed an act of abuse or has engaged in a pattern or
practice that indicates risk of harm to Plaintiff.
- Defendant is required to relinquish to the sheriff any firearm license
Defendant may possess. Defendant's weapons and firearm license may be
returned at the expiration 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 of the request and given Plaintiff an
opportunity to respond. A copy of this Order shall be transmitted to the chief
or head of the police department of New Cumberland Police Department and
the sheriff of Cumberland County.
- Defendant is enjoined from damaging or destroying any property owned
jointly by the parties or owned solely by Plaintiff.
- Defendant shall refrain from harassing Plaintiff's relatives.
6. A certified copy ofthis Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
State Police-Carlisle Barracks
Fairview Township Police
7. The sheriff, police or other law enforcement agencies are directed to serve the
Defendant with a copy ofthe 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.
8. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL APRIL 11,2002 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. g6114. 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.
g6113. Defendant is further notified that violation of this Order may subject him/her
to state charges and penalties under the Pennsylvania Crimes Code and to federal
charges and penalties under the Violence Against Women Act, 18 V.S.C. gg2261-
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 I through 4 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 of law enforcement.
Subsequent to an arrest, the law enforcement officer shall seize all weapons used or
threatened to be used during the violation of this Order OR during prior incidents of
abuse. Weapons must forthwith be delivered to the Sheriffs office of the county
which issued this Order, which office shall maintain possession of the weapons until
further Order of this court, unless the weapon/s are evidence of a crime, in which
case, they shall remain with the law enforcement agency whose officer made the
arrest.
BYTH~T:
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2. 00 -0 ______
Date
Distribution to:
Legal Services
Faxed & Mailed to PSP
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PF AD Number: ERI145964C
Eleni Maria lInes
: In the Court of Common Pleas
: County, Pennsylvania
Plaintiff
v.
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: No. ,,7 <,.
Robert L. Gramm Jr.
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
Defendant
PETITION FOR PROTECTION FROM ABUSE
I. Plaintiffs name is:
Eleni Maria Imes
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. Eleni Maria Imes
4. Plaintiffs Address is : 1228 Blossom Terrace, Boiling Springs, P A 17007
5. Defendant's Name is:
Robert L. Gramm Jr.
6. Defendant is believed to live at the following address:
419 4th Street, New Cumberland, PA 17070
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7. Defendant's Social Security Number is:
164-62-6808
8. Defendant's Date of Birth is:
February 4, 1965
9. Defendant's Place of employment is:
American Express Financial Advisors, Mechanicsburg
10. Defendant is an adult.
11. The relationship between the Plaintiff and the Defendant is:
Current Ot former sexuaIlintimate partner
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 or about October 5, 2000, Defendant drove by Plaintiffs place of employment
after being told by the police and Plaintiff not to have contact with her. (A police
officer with the Fairview Police Department followed Defendant and obtained the
license plate number to verify it was in deed the Defendant. The officier notified
the Plaintiff when she came to work the next day.)
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:
On or about September 25th-27th- Defendant repeatedly sent e-mail to Plaintiff
begging her to help him, tell him what to do, and pleading with her to have contact
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with him causing Plaintiff to fear for her safety.
On or about September 20, 2000, Trooper Evans from the State Police filed a
summary citation for harassment against Defendant since he ignored a no contact
letter sent to him by Plaintiff and ignored Tropper Evans' warning telling him to
have no conta.ct with Plaintiff. Even after being cited, Defendant called Plaintiff on
the phone two times and pleaded with her to speak to him. Plaintiff informed
Officer Baker of Fairview Township that Defendant phoned her again, and he
filed another summary citation for harassment.
On or about September 18, 2000, Plaintiff, who was at work, and retrieved her
email from home found an e-mail from Defendant stating that he misses her so
much it hurts; he needs to have some sort of contact with her, and his life is
nothing now. Defendant also asked her to allow him to write to her occassionally
because it's too hard to let go of his life and dreams, and said that he was never
good at letting go causing Plaintiff to fear for her safety.
On September 8, 2000, Plaintiff sent Defendant a no contact letter by certified
mail and on or about September 14, 2000, Trooper Evans of the State Police told
Defendant to have no contact with Plaintiff.
On or about Labor Day Week-end 2000, Plaintiff returned to her residence, went
into her room, and noticed that things had been moved. An answering machine
tape of Defendant's messages to Plaintiff was destroyed and replaced with a blank
tape. Items the Defendant purchased for Plaintiff, such as jewlery, were missing
from her room causing her to fear Defendant has been in her room while she was
away.
From approximately February 2000 to May 2000, Defendant called several times
during the day and night and made statements to Plaintiff including "it disgusts
me to know that someone else is touching you, and holding you, and I should be
the one." Defendant was warned by Chief Bistline of Fairview Township Police to
stop calling Plaintiff.
In or about June 2000, Defendant illegally accessed Plaintiffs e-mail and retrieved
her new phone number and began calling her several times a day.
On or about February 19,2000, Defendant knelt down beside the car, after
Plaintiff got out of the car and walked away, held a gun to his chest, and
threatened to kill himself if she did not get back into the car.
Since approximately July 1998, Defedant has raised his fist to Plaintiff and
threatened that he should "pop" her. Defendant has exhibited controlling and
obessesive behavior causing Plaintiff to fear for her safety. Despite warnings from
the police, citations for harassment, and a letter from Plaintiff, Defendant
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continues to contact Plaintiff. On several occassions, Plaintiff believes Defendant
has accessed her e-mail to find out what she is doing, where she is going, or who
she is talking with causing her to fear for her safety.
16. The Defendant has used, or threatened to use, the following weapon(s) against the
Plaintiff or the minor child/ren:
a. Any and all firearms and lor weapons, specifically including, but
not limited to: 9mm Baretta (Defendant carries on him)
b. Glock
c. 357 Magnum
d. 38 Special
e. 22
f. 380
g. Defendant also has a permit to carry a conceled weapon
17. The police department(s) or law enforcement agencies that should be provided with a
copy of the protection order are:
State Police-Carlisle Barracks
Fairview Township Police
18. There is an immediate and present danger of further abuse from the Defendant.
19. 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. 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.
c. 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.
d. Order Defendant to pay the costs of this action, including filing and
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service fees,
e, Order the following additional relief, not listed above:
- Order Defendant to refrain from harassing Plaintiffs relatives.
- Order Defendant not damage or destroy and property owned
solely by Plaintiff.
- Order Defendant to pay $250.00 to Legal Services, Inc. as
reimbursement for litigation in this ease.
f. 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:
Id /11/0-0
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an "carey, Attorney for aintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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VERIFICATION
I verity 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. g4904, relating
to unsworn falsification to authorities.
Dated: ~ bu 5 .2.(/)(:/(7>
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Eleni Imes, Plaintiff
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10/12/00 "THU 11:08 FAX 717 240 6573
CUMB CO PROTHONOTARY
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OFFICE OF lliE PROlliQlOTARY
CUMBERLAND a:uNI"l COURTHOOSE
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ONE CXXJRTHOOSE SQUARE
CARLISLE, PA. 17013-3387
(717) 240-6195
FAX ,:
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FAX (717) 240-6573
VIA TELECOPIER
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CURTIS R. LONG
RE: :P FA OrrJeV5
MESSAGE:
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ELENI IMES,
: IN THE COURT OF COMMON PLEAS OF
PLAINTIFF
: CUMBERLAND COUNTY, PENNSYL VANIA
V.
: NO. 00-6963
CIVIL TERM
ROBERT GRAMM, JR.,
DEFENDANT
: PROTECTION FROM ABUSE
ORDER FOR CONTINUANCE
AND NOW, this 19th day of October, 2000, upon consideration of the attached Motion for
Continuance, scheduled for hearing on October 19,2000, by this Court's Order of October 11,2000,
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,
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
Robert L. Gramm, Jr.
Pro Se Defendant
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ELENI IMES,
: IN THE COURT OF COMMON PLEAS OF
PLAINTIFF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 00-6963
CIVIL TERM
ROBERT GRAMM, JR.,
DEFENDANT
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
The Plaintiff, Eleni Imes, by and through her attorney, Joan Carey of Legal Services, Inc.,
moves the Court for an Order continuing generally the hearing in the above-captioned case on the
grounds that:
1. A Temporary Protection From Abuse Order was issued by this Court on October II,
2000, scheduling a hearing for October 19,2000, at 8:30 a.m.
2. The Cumberland County Sheriffs Department served Defendant with a certified copy
of the Temporary Protection From Abuse Order and Petition for Protection From Abuse at his
residence located at 419 4th Street, New Cumberland, Pennsylvania on October I 2 , 2000, at 6:27
p.m.
3. The parties agree that the hearing be continued generally to afford them time to
execute a Consent Agreement.
4. 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.
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WHEREFORE, the Plaintiff requests that the Court grant this Motion and continue this
matter generally, 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.
Respectfully submitted,
mti~
Maryann urphy, Attorney fi r P
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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ELENJ IMES,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: NO. 00-6963 CNIL TERM
ROBERT GRAMM, JR.,
Defendant
: CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this 75; -tL day of NOVEMBER, 2000 this Court certifies that
the attached complaint has been properly completed and verified, and there is probable
cause for this issuance of process. In consideration of the attached Commonwealth's
Petition, a WARRANT IS ISSUED FOR THE ARREST of the Defendant, ROBERT
GRAMM, JR.
If the defendant is found during normal Courthouse hours, the defendant is to be
brought immediately before the Court. If not found during Courthouse hours, the
defendant is to be taken to the on-call District Justice and bail set pursuant to the Rules of
Criminal Procedure.
Defendant has a right to be represented by an attomey. Ifthe defendant cannot
afford an attorney, upon request one will be assigned to represent the defendant. The
assessment of costs to be determined by the Trial Judge subsequent to trial.
By the Court,
I
Jonathan R. Birbeck
Chief Deputy District Attorney'
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ROBERT GRAMM, JR.
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ELENI IMES,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
V.
: 00-6963 CIVIL
ROBERT GRAMM, JR,
Defendant
CHARGE: INDIRECT CRIMINAL CONTEMPT
COMMONWEALTH'S PETITION FOR A HEARING ON CHARGES
OF INDIRECT CRIMINAL CONTEMPT
Jonathan R. Birbeck, Chief Deputy District Attorney of Cumberland County,
Pennsylvania, brings the following Petition for a hearing on charges of Indirect Criminal
Contempt:
1. A Protection from Abuse Order was issued by the Court. A true and correct
copy of the Order is attached.
2. The defendant's violation ofthis Order is averred in the attached criminal
complaint.
3. The victim requests the filing of an Indirect Criminal Contempt Charge.
4. The District Attorney's Office approves the filing of this criminal complaint.
S. The Commonwealth is requesting a hearing on the charges of Indirect
Criminal Contempt pursuant to 23 Pa.C.S.A. S 6113.
6. The plaintiff and/or the defendant may seek modification of the Order based
on the filing of this petition as the Court deems appropriate following the trial
in addition to any other sentence. 23 Pa.C.S.A. g 6113.
WHEREFORE, the Commonwealth requests the defendant be commanded to
appear before the Court on the charge of Indirect Criminal Contempt.
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COMMONWEALTH OF PENNSYLVANIA
,.,COUNTY OF: CUMBERLAND
Magisterial District Number: 09-3-05
District Justice Nama: Hon. Gayle A. ELDER
Add,.", 507 North York St.
Mechanicsburg, Pa 17055
.
POLICE
CRIMINAL COMPLAINT
COMMONWEALTH OF PENNSYLVANIA
VS.
Telephone:
717-761-4575
DEFENDANT:
Date Filed:
I NAME and ADDRESS
I Robert Lee GRAMM Jr.
419 4Th Sl.
New Cumberland, Pa 17070
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Docket No.:
OTN:
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Defendant's RaceJ thnicity
I8l White 0 Asian 0 Black
o Hispanic 0 Native American 0 Unknown
Defendant'sA.K.A.
Defendant's Sex
o Female
I8l Male
Defendant'sD.O.B.
02/04/65
Defendant's Social Security Number
164626808
Defandant'sSlD
Defendant's Vehicle Information:
Defendant's Driver's License Number
PLATE NUMBER
REGISTRATION STICKER
(MMIYY)
STATE
24398519
ComplainUlncident umber
H2-1163119
ComplainlllnCidenl Number if other Participants
UCRlN1BRS Code
260
District Attorney's Office Approved 0 Disapproved because:
(The district attorney may require that the complaint, arrest warrant affidavit, or both be approvea oy tne attorney Tor tne commonwealtn prior to TIling.
Pa.R.Cr.P.107)
(Nam@ or Attorney Tor l,.;ommonwealtn -l"'lease l"'rrnt or [ ype)
(l::ilgnalure OT Attorney tor \.,;ommonwealtn)
(Uate)
I, Tpr R. K. EVANS /
(Name of Affiant- Please Print or Typej
of, the Pennsylvania State Police
uaenlllY ueparunem or Agency Kepresemea ana l"'OIIllCaJ ;:;'UDaIVISI~n,
do hereby state: (check the appropriate box)
3517
PAPSP100
(Officer Badge Number/tO.)
~t"Ollce Agency UKI I\lumoerj
~urrgll\l:llIngAgency \..osse I\lumoer ~Ul,.;AJI
1. [8:J I accuse the above named defendant who lives at the address set forth above
D I accuse the defendant whose name is unknown to me but who is described as
D I accuse the defendant whose name and popular designation or nickname is unknown to me and whom I have
therefore designated as John Doe
with violating the penal iaws of the Commonwealth of Pennsylvania at
1228 Blossom Terrace, Monroe Twp
in Cumberla County on or about 11/22/00 at 1023 hours
Participants were: (if there were participants, place their names here, repeating the name of the above defendant)
Robert Lee GRAMM Jr.
2. The acts committed by the accused were:
(Set forth a summary of the facts sufficient to advise the defendant of the nature of the offense charged. A citation to the statute allegedly violated,
without more, is not sufficient, in a summary case, you must cite the specific section and subsection of the statute or ordinance allegedly violated.)
The Defendant Violated an order issued under the Protection From Abuse Act F.R.1992-512 dated
06/04/92, by the Court Of Common Pleas Of Cumberland County. The PFA number 00-6963 was issued
by the Honorable Judge J. Wesley OLER Jr.on 11 October 2000.
AOPC 412-(6/96)
1-3
,
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(C<1ntinuation of No.2)
Defendant's Name:
Robert Lee GRAMM Jr.
'*
POLICE
CRIMINAL COMPLAINT
Docket Number:
all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act
of Assembly, or in violation of
1. 6113 of the DRlTitle 1
(Section) \SUDseC!lOn) (PAStalute) (Counts)
2. of the
(SeCfiOi'iI ~n) ~) (GOlii'itS)
3. oflhe
{SeaiOi'iJ ~n) ~) (COUffiJ
4. of the
(SeCiiOi1) ~n) ~) (COUi'iISJ
I ask that a warrant of arrest or a summons be issued and that the defendant be required to answer the charges I have
made. (In order for a warrant of arrest to issue, the attached affidavit of probable cause must be completed and
sworn to before the issuing authority.)
3. I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or
information and belief. This verification is made subject to the penalties of Section 4904 of the Crimes Code (18
PA. C.S.A4904) relating to unsworn falsification to authoriti~, ~h ~
' ~"OAff"",)
AND NOW, on this date , , I certify that the complaint has been properly
completed and verified. An affidavit of probable cause must be completed in order for a warrant to issue.
SEAL
llVlaglslerralUISmCl)
\lssulngt-l.uUlornYI
AOPC 412-(6/96)
2-3
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Defendant's Name:
Robert Lee GRAMM Jr.
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POLICE
CRIMINAL COMPLAINT
Docket Number:
AFFIDAVIT of PROBABLE CAUSE
The victim Eleni Maria IMES, possesses a valid Cumberland County protection from abuse order,
stating in part, that the defendant shall not harass or have any contact by phone.
On 11/22/2000, the victim checked her telephone answering machine at her residence and noted that
a message was left by the defendant that date, at 1023 hours.
I, Tpr R.K.EVANS, BEING DULY SWORN ACCORDING TO LAW, DEPOSE AND SAY THAT THE FACTS
SET FORTH IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE,
INFORMATION AND BELIEF.
.;j)z, ~/{ [~
(Signature of Affiant)
Sworn to me <'lnd subscribed before me thi~
day of
,-
Date
, District Justice
My commission expires first Monday of January,
SEAL
AOPC 412-(6-96)
3-3
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ELENI IMES,
: IN THE COURT OF COMMON PLEAS OF
PLAINTIFF
: CUMBERLAND COUNTY, PENNSYL VANIA
V.
: NO. 00-6963
CIVIL TERM
ROBERT GRAMM, JR.,
DEFENDANT
: PROTECTION FROM ABUSE
ORDER FOR CONTINUANCE
AND NOW, this 19th day of October, 2000, upon consideration of the attached Motion for
Continuance, scheduled for hearing on October 19,2000, by this Court's Order of October 11,2000,
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,
udge ~
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Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
Robert L. Gramm, Jr.
Pro Se Defendant
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ELENI IMES,
; IN THE COURT OF COMMON PLEAS OF
PLAINTIFF
: CUMBERLAND COUNTY, PENNSYL VANIA
V.
: NO. 00-6963
CIVIL TERM
ROBERT GRAMM, JR.,
DEFENDANT
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
The Plaintiff, Eleni rmes, by and through her attorney, Joan Carey of Legal Services, Inc.,
moves the Court for an Order continuing generally the hearing in the above-captioned case on the
grounds that:
I. A Temporary Protection From Abuse Order was issued by this Court on October I I,
2000, scheduling a hearing for October 19, 2000, at 8:30 a.m.
2. The Cumberland County Sheriffs Department served Defendant with a certified copy
of the Temporary Protection From Abuse Order and Petition for Protection From Abuse at his
~
residence located at 419 4th Street, New Cumberland, Pennsylvania on October I 2 , 2000, at 6:27
p.m.
3. The parties agree that the hearing be continued generally to afford them time to
execute a Consent Agreement.
4. 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.
.
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.
WHEREFORE, the Plaintiff requests that the Court grant this Motion and continue this
matter generally, 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.
Respectfully submi tted,
~
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Maryann urphy, Attorney fi
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle,PA 17013
(717) 243-9400
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E'eni Imes,
; IN THE COURT OF COMMON PLEAS OF
Plaintiff
vs.
; CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 00- (/1 \v3
CIVIL TERM
Robert L. Gramm, Jr.,
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, ]Iou may be evicted from your residence and lose other
important rights.
A HEARING ON THIS MATTER IS SCHEDULED ON ()1'L;;/; 6-<../ 17 ,2000,
AT r: 30 A.M., IN COURTROOM NO. / OF THE 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 in jail under 23 Pa.C.S. ~6114. Violation
may lllso subject you to prosecution and criminal penalties under the Pennsylvania Crimes
Code. Under federallllw, 18 U.S.c. ~2265, this Order is enforceable anywhere in the United
States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico.... If you travel
outside of the state and intentionally violate this Order, you may be subject to federal criminal
proceedings under the Violence Against Women Act, 18 U.S.C. ~ 2261-2262.
You should take this paper to your lawyer at once. You have the right to have a lawyer
represent you at the hearing. The court will not, however, appoint a lawyer for you. If you
do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find
out where you can get legal help. If you cannot find a lawyer, you may have to proceed
without one.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE, CARLISLE, PENNSYLVANIA 17013
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 I 990. 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.
. .'
Eleni Maria Imes
Plaintiff
: In the Court of Common Pleas
: County, Pennsylvania
v.
: No. (){;. i.<tt,.3 W J ~
Robert L. Gramm Jr.
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
Defendant
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: Robert L. Grllmm Jr.
Defendant's Date of Birth is: February 4, 1965
Defendant's Social Security Number is: 164-62-6808
Name(s) of All protected persons, including Plaintiff and minor children:
,
I. Eleni Maria Imes
AND NOW, on Qj II, 2 ODO upon consideration of the attached Petition for
Protection from Abus~, 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.
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 Plaintiffs school, business, or place of employment. Defendant
is specifically ordered to stay away from the following locations for the duration
of this order.
- Plaintiffs place of employment located at Fairview Township Police
Department, 599 Lewisberry Road, New Cumberland, Pennsylvania.
- Plaintiffs residence located at 1228 Blossom Terrace, Boiling Springs,
Pennsylvania.
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. 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.
I. Any and all firearms and/or weapons, specifically
including, but not limited to: 9mm Baretta (Defendant
carries on him)
2. Glock
3. 357 Magnum
4. 38 Special
5. 22
6. 380
7. Defendant shall also relinquish to the Sheriff his permit
to carry a canceled weapon
-
Defendant is prohibited from possessing, transferring or acquiring any other
firearms license or weapons for the duration of this order.
5. 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 ofthe Prothonotary and
forwarded to the Sheriff for service. The Prothonotary shall not send a copy
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of this Order to Defendant by mail.
- This Order shall remain in effect until modified or terminated by the Court
andcan be extended beyond its original expiration date if the Court finds that
Defendant has committed an act of abuse or has engaged in a pattern or
practice that indicates risk of harm to Plaintiff.
- Defendant is required to relinquish to the sheriff any firearm license
Defendant may possess. Defendant's weapons and firearm license may be
returned at the expiration of the Protection Order after Defendant has
submitted a written request to the Court for the return ofthe weapons and
the Court has notified Plaintiff of the request and given Plaintiff an
opportunity to respond. A copy of this Order shall be transmitted to the chief
or head of the police department of New Cumberland Police Department and
the sheriff of Cumberland County.
- Defendant is enjoined from damaging or destroying any property owned
jointly by the parties or owned solely by Plaintiff.
- Defendant shall refrain from harassing Plaintiffs relatives.
6. A certified copy ofthis Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
State Police-Carlisle Barracks
Fairview Township Police
~
7. 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.
8. THIS ORDER APPLIES IMMEDIA TEL Y TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL APRIL 11,2002 OR UNTIL OTHERWISE
MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND
HEARING.
NOTICE TO THE DEFENDANT
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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 injail. 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 for that purpose. 23 Pa.C.S.
96113. Defendant is further notified that violation of this Order may subject him/her
to state charges and penalties under the Pennsylvania Crimes Code and to federal
charges and penalties under the Violence Against Women Act, 18 U.S.C. 992261-
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 4 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 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.
BY,!,"["c: rJ ok{
(o,t 11/'L060'U'
Date
Distribution to:
Legal Services
Faxed & Mailed to PSP
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PFAD Number: ERI145964C
Eleni Maria Imes
: In the Court of Common Pleas
: County, Pennsylvania
Plaintiff
v.
/ ,.,/ -3
: No. v 7<.-
Robert L. Gramm Jr.
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
Defendant
PETITION FOR PROTECTION FROM ABUSE
I. Plaintiffs name is:
EIeni Maria Imes
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. Eleni Maria Imes
4. Plaintiff's Address is : 1228 Blossom Terrace, Boiling Springs, P A 17007
5. Defendant's Name is:
Robert L. Gramm Jr.
6. Defendant is believed to live at the following address:
419 4th Street, New Cumberland, PA 17070
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7. Defendant's Social Security Number is:
164-62-6808
8. Defendant's Date of Birth is:
February 4, 1965
9. Defendant's Place of employment is:
American Express Financial Advisors, Mechanicsburg
10. Defendant is an adult.
I I. The relationship between the Plaintiff and the Defendant is:
Current or former sexual/intimate partner
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 or about October 5, 2000, Defendant drove by Plaintiff's place of employment
after being told by the police and Plaintiff not to have contact with her. (A police
officer with the Fairview Police Department followed Defendant and obtained the
license plate number to verify it was in deed the Defendant. The officier notified
the Plaintiff when she came to work the next day.)
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:
On or about September 25th-27th- Defendant repeatedly sent e-mail to Plaintiff
begging her to help him, tell him what to do, and pleading with her to have contact
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with him causing Plaintiff to fear for her safety.
On or about September 20, 2000, Trooper Evans from the State Police filed a
summary citation for harassment against Defendant since he ignored a no contact
letter sent to him by Plaintiff and ignored Tropper Evans' warning telling him to
have no contact with Plaintiff. Even after being cited, Defendant called Plaintiff on
the phone two times and pleaded with her to speak to him. Plaintiff informed
Officer Baker of Fairview Township that Defendant phoned her again, and he
filed another summary citation for harassment.
On or about September 18, 2000, Plaintiff, who was at work, and retrieved her
email from home found an e-mail from Defendant stating that he misses her so
much it hurts; he needs to have some sort of contact with her, and his life is
nothing now. Defendant also asked her to allow him to write to her occassionalIy
because it's too hard to let go of his life and dreams, and said that he was never
good at letting go causing Plaintiff to fear for her safety.
On September 8, 2000, Plaintiff sent Defendant a no contact letter by certified
mail and on or about September 14, 2000, Trooper Evans of the State Police told
Defendant to have no contact with Plaintiff.
On or about Labor Day Week-end 2000, Plaintiff returned to her residence, went
into her room, and noticed that things had been moved. An answering machine
tape of Defendant's messages to Plaintiff was destroyed and replaced with a blank
tape. Items the Defendant purchased for Plaintiff, such as jewlery, were missing
from her room causing her to fear Defendant has been in her room while she was
away.
From approximately February 2000 to May 2000, Defendant calIed several times
during the day and night and made statements to Plaintiff including "it disgusts
me to know that someone else is touching you, and holding you, and I should be
the one." Defendant was warned by Chief Bistline of Fairview Township Police to
stop caIling Plaintiff.
In or about June 2000, Defendant illegally accessed Plaintiffs e-mail and retrieved
her new phone number and began calling her several times a day.
On or about February 19, 2000, Defendant knelt down beside the car, after
Plaintiff got out of the car and walked away, held a gun to his chest, and
threatened to kill himself if she did not get back into the car.
Since approximately July 1998, Defedant has raised his fist to Plaintiff and
threatened that he should "pop" her. Defendant has exhibited controlling and
obessesive behavior causing Plaintiff to fear for her safety. Despite warnings from
the police, citations for harassment, and a letter from Plaintiff, Defendant
.'J I
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continues to contact Plaintiff. On several occassions, Plaintiff believes Defendant
has accessed her e-mail to find ont what she is doing, where she is going, or who
she is talking with causing her to fear for her safety.
16. The Defendant has used, or threatened to use, the following weapon(s) against the
Plaintiff or the minor child/ren:
a. Any and all firearms and lor weapons, specifically including, hut
not limited to: 9mm Baretta (Defendant carries on him)
b. Glock
c. 357 Magnum
d. 38 Special
e. 22
f. 380
g. Defendant also has a permit to carry a conceled weapon
17. The police department(s) or law enforcement agencies that should be provided with a
copy of the protection order are:
State Police-Carlisle Barracks
Fairview Township Police
18. There is an immediate and present danger of further abuse from the Defendant.
19. 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. Prohibit Defendant from having any contact with Plaintiff andlor
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.
c. 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.
d. Order Defendant to pay the costs of this action, including filing and
~ "
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service fees.
e. Order the following additional relief, not listed above:
- Order Defendant to refrain from harassing Plaintiffs relatives,
- Order Defendant not damage or destroy and property owned
solely by Plaintiff,
- Order Defendant to pay $250.00 to Legal Services, Inc. as
reimbursement for litigation in this case.
f. 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:
(d /11/0-0
! I
omi'Carey, Attorney for aintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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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. 94904, relating
to unsworn falsification to authorities.
Dated: ~ k.r 5 . 20C/0
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Eleni Imes, Plaintiff
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ELENI IMES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
INDIRECT CRIMINAL CONTEMPT
ROBERT GRAMM, JR.,
Defendant
No. 00-6963 CIVIL TERM
ORDER OF COURT
AND NOW, this 30th day of November, 2000,
the Defendant, Robert Gramm, Jr., now appearing in court on
a charge of indirect criminal contempt with the Public
Defender, Jessica Becker, Esquire, and bail having been
requested to be set in this matter by the Office of the
District Attorney through Cumberland County Detective
Kristen Mertz, the Defendant is directed to appear for
trial on the charge on Thursday, December 7, 2000, at
8:30 a.m., in Courtroom No.1, Cumberland County
Courthouse, Carlisle, Pennsylvania, without further Order
of Court.
Bail is set in this matter at $1000.00.
By the Court,
J.
Office of the District Attorney
Sheriff
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Jessica Becker, Esquire
Assistant Public Defender
probation
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ELENIIMES,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
00-6963 CIVIL
ROBERT GRAMM JR.,
Defendant
CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this ,~ 1l
day of DECEMBER, 2000, this Court certifies that
the attached complaint has been properly completed and verified, and there is probable
cause for the issuance of process. In consideration ofthe attached Commonwealth's
Petition, the defendant, ROBERT GRAMM JR., is directed to appear for trial on the
charge ofIndirect Criminal Contempt before the Court on the 1-tk day of
\JeC.~2000 at 8:,Oo'c!ockQ .m. in Courtroom # -L of the Cumberland
County Courthouse, Carlisle, Pennsylvania.
The defendant has a right to be represented by an attorney. If the defendant
cannot afford an attorney, upon request one will be assigned to represent the defendant.
Ifthe defendant wishes assignment of counsel, contact should be made prior to trial with
the Cumberland County Public Defender's Office at 717-240-6285. Further, if the
defendant fails to appear, an arrest warrant will be issued.
The Sheriff of Cumberland County is directed to serve this Order and Petition
upon the defendant. The assessment of costs to be determined by the Trial Judge
subsequent to trial.
By the Court,
J.
Jonathan R. Birbeck,
Chief Deputy District Attorney
Cr/(~5 r(J"C)0cfl!r
jlve.r)
ROBERT GRAMM JR.
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ELENI IMES
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: 00-6963 CIVIL
ROBERT GRAMM, JR.
Defendant
: CHARGE: INDIRECT CRIMINAL CONTEMPT
COMMONWEALTH'S PETITION FOR A HEARING ON CHARGES
OF INDIRECT CRIMINAL CONTEMPT
Jonathan R. Birbeck, Chief Deputy District Attorney of Cumberland County,
Pennsylvania, brings the following Petition for a hearing on charges of Indirect Criminal
Contempt:
1. A Protection from Abuse Order was issued by the Court. A true and correct
copy of the Order is attached.
2. The defendant's violation of this Order is averred in the attached criminal
complaint.
3. The victim requests the filing of an Indirect Criminal Contempt Charge.
4. The District Attorney's Office approves the filing of this criminal complaint.
5. The Commonwealth is requesting a hearing on the charges ofIndirect
Criminal Contempt pursuant to 23 Pa.C.S.A. S 6113.
6. The plaintiff and/or the defendant may seek modification of the Order based
on the filing of this petition as the Court deems appropriate following the trial
in addition to any other sentence. 23 Pa.C.S.A. S 6113.
WHEREFORE, the Commonwealth requests the defendant be commanded to
appear before the Court on the charge of Indirect Criminal Contempt.
lly submitted,
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, Jonat an R. Birbeck
Chief Deputy District Attorney
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COMMqNWEAL TH OF PENNSYLVANIA '*
COUNTY OF: CUMBERLAND POLICE
Magisterial District Number: 09-3-05 CRIMINAL COMPLAINT
Dis\rict Justice Name: Hen. Gayle A. Elder
AdClress: 507 North York SI. COMMONWEALtH OF PENNSYLVANIA
Mechanicsburg, Pa 17055
VS.
Telephone: 717-761-4575 DEFENDANT:
Docket No.: r; NAME and ADDRESS I
Robert Lee Gramm Jr.
Date Filed: 4194ThSI.
New Cumberland, Pa 17070
OTN: L -.J
Doro,''''!', R",lElh,;d~ I Deleo'o,!" Sox I Del,"",,', D.O.B. I Del,"',"!" S1G:t~';80"8'0' Defendant's SID
181 White 0 Asian 0 Bisek 0 Female 02104/65
o Hispanic 0 Native American 0 Unknown 121 Male
Derendant'sA.K.A. Defendanl's Vehide Information: Defendant's Driver's Ucense Number
PLATE NUMBER I STATE I REGI8mA TlON STICKER STATE I
(MMIW) 24398519
CQmplaintllncidenl Number I Complaintllncident Numberif other Participants I UCR/NlBRS Code
H2-1163889 260
District Attomey's Office 0 Approved 0 Disapproved because:
(ihe district attorney may require that the complaint, arrest warrant affidavit, or both be approvea oy me attorney tor me t;ommonwealtn prior to tllmg,
Pa.R.Cr.P. 107)
tName or Attorney for l;ommonwealm Please I-'nnt or Iype) t~lgnature Of AtlOmeyfor l;ommonwealrnJ {Uale}
I, Tpr R.K. Evans I 3517
(Name of Affianl- Pfease Print or TYpe) (Officer Badge Numberll,D.}
of, the Pennsylvania State Police PAPSP100
V"'OIlC6 ....!:Iancy UKI NUmoer}
\unglnaung ....gtmcy I..'Else Numoer \Ul..'....n
\IOemny ueparunem or ....gancy KtlpreStlmeo anD t"OlltlC81 ;;:,UDOIVISIOnj
do hereby state: (check the appropriate box)
1. I8J I accuse the above named defendant who lives at the address set forth above
o I accuse the defendant whose name is unknown to me but who is described as
o I accuse the defendant whose name and popular designation or nickname is unknown to me and whom I have
therefore designated as John Doe
with violating the penal laws of the Commonwealth of Pennsylvania at
1228 Blossom Terrace. Monroe Two
in Cumberla County on or about 11/23/2000 at 1815 hours
Participants were: (if there were participants, place their names here, repeating the name of the above defendant)
Robert Lee Gramm Jr.
2. The acts committed by the accused were:
(Set forth a summary of the facts sufficient to advise the defendant of the nature of the offense charged. A cftaVon to the statute allegedly violated,
without more, is not sufficient, in a summary case, you must cfte the specific section and subsection of the statute or ordinance allegedly violated.)
The defendant violated an order issued under the Protection From Abuse Act F.R. 1992-512 dated
06/04/92, by the Court Of Common Pleas Of Cumberland County. The PFA number 00-6963 was issued
by the Honorable Judge J. Wesley Oler Jr. on 11 October 2000.
AOPC 412-(6196)
1-3
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(Continuation of No.2)
Defendant's Name:
Robert Lee Gramm Jr.
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POLICE
CRIMINAL COMPLAINT
Docket Number:
all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act
of Assembly, or in violation of
1. 6113 oflhe DRffitle 1
(Section) (subsection) (PAStatute) (Counts)
2. of the
(SectiOn) (Subsection) (PASlatute) (Counts)
3. of the
(Section) (Subsection) (PAStalute) (Counts)
4. of the
(Section) (Subsection) (PAStatute) (Counts)
I ask that a warrant of arrest or a summons be issued and that the defendant be required to answer the charges I have
made. (In order for a warrant of arrest to issue, the attached affidavit of probable cause must be completed and
sworn to before the issuing authority.)
3. I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or
information and belief. This verification is made subject to the penalties of Section 4904 of the Crimes Code (18
PA. C.S.A 4904) relating to unsworn falsification to authOrit~tV/. ~ Ij! ~~/..-:t.-
Ignature ot Affiant
AND NOW. on this date . ~ I certify that the complaint has been properly
completed and verified. An affidavit of probable cause must be completed in order for a warrant to issue.
SEAL
\MagI51811aIUIliUlClJ
lI55UllIYPlUUlCnty/
AOPC 412-(6196)
2-3
".
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Defendant's Name:
Robert Lee Gramm Jr.
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POLICE
CRIMINAL COMPLAINT
Docket Number:
AFFIDAVIT of PROBABLE CAUSE
The victim Eleni Maria Imes possesses a valid Cumberland County protection from abuse order,
stating in part, that the defendant shall not harass or have any contact with the victim.
On 11/23/2000, the victim was at her computer when she received an Instant Message from the
Defendant, screen name, NIDAN244. The time was 6:18 pm.
I, _' BEING DULY SWORN ACCORDING TO LAW, DEPOSE AND SAY THAT THE FACTS SET
FORTH IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE,
INFORMATION AND BELIEF.
/f1/J.a ~ G'M0<<J--'
, (Signature of AffIant)
Sworn to me and subscribed before me thi"
rlayof
,-
Date
, District Justice
My commission expires first Monday of January,
AOPC 412-(6-96)
SEAL
3-3
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-06963 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
IMES ELENI
VS
GRAMM ROBERT L JR
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
GRAMM ROBERT L JR
the
DEFENDANT
, at 0018:27 HOURS, on the 12th day of October ,2000
at 419 4TH ST
NEW CUMBERLAND, PA 17070
by handing to
ROBERT L. GRAMM, JR
a true and attested copy of PROTECTION FROM ABUSE
together with
NOTICE OF HEARING & ORDER, TEMPORARY PROTECTION
FROM ABUSE ORDER
and at the same time directing His attention to the contents thereof.
Weapons Confiscation, License Revoked and Turned in
to Cumberland County Sheriff.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
10.54
.00
10.00
.00
38.54
So Answers:
~~~~~(
R. Thomas Kline
10/16/2000
Sworn and Subscribed to before By:
me this If ~
day of
(j)~..u-u0 A.D.
Omt Q IfuPP:" ,~
rothonotary ;
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ELENI IMES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
INDIRECT CRIMINAL CONTEMPT
ROBERT GRAMM, JR.,
Defendant
No. 00-6963 CIVIL TERM
ORDER OF COURT
AND NOW, this 7th day of December, 2000, the
Defendant, Robert Gramm, Jr., having been found guilty
following a trial of two counts of indirect criminal
contempt for violation of a Protection from Abuse order
entered in this case on October 11, 2000, the sentence of
the Court is scheduled for Tuesday, January 23, 2001, at
9:30 a.m., in Courtroom No.1, Cumberland County
Courthouse, Carlisle, Pennsylvania.
A sentencing report is requested from the
probation office, and the probation office is requested to
work with the Defendant to arrange for psychiatric or
psychological treatment for him.
By the Court,
J. es
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Jonathan R. Birbeck, Esquire
Chief Deputy District Attorney
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Sheriff
Jessica Becker, Esquire
Assistant Public Defender
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ELENI IMES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
INDIRECT CRIMINAL CONTEMPT
ROBERT GRAMM, JR.,
Defendant
No. 00-6963 CIVIL TERM
ORDER OF COURT
AND NOW, this 7th day of December, 2000,
upon consideration of the complaints filed in the
above-captioned matter, and following a trial, the Court
finds the Defendant guilty of two counts of indirect
criminal contempt for violation of the Protection from
Abuse Order of Court dated October 11, 2000.
By the Court,
J.
Jonathan R. Birbeck, Esquire
Chief Deputy District Attorney
Jessica Becker, Esquire
Assistant Public Defender
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ELENI IMES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
INDIRECT CRIMINAL CONTEMPT
ROBERT GRAMM, JR.,
Defendant
No. 00-6963 CIVIL TERM
ORDER OF COURT
AND NOW, this 7th day of December, 2000,
pursuant to an agreement of counsel, a copy of the
Protection from Abuse order entered in this case is
substituted for Commonwealth's Exhibit 3, which was the
original order.
By the Court,
JA
J.
esley
Jonathan R. Birbeck, Esquire
Chief Deputy District Attorney
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Jessica Becker, Esquire
Assistant Public Defender
Probation
Sheriff
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IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
00-6963 E:RIUIUAL TERM
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CHARGE: CIVIL ACTION
PETITTION #: 02-031
ROBERT GRAMM f JR.
IN THE CASE OF ROBERT GRAMM, JR., UNDER PROBATION FROM THE
CUMBERLAND COUNTY COURT OF COMMON PLEAS.
PETITION FOR REVOCATION OF PROBATION
To the Honorable Judges of Cumberland County Courts.
WHEREAS, Robert Gramm, Jr., on January 23, 2001 was sentenced at
the above docket number as follows:
At Count l(A), 6 months probation with a special condition
that he have no contact direct or indirect with the victim; and was
sentenced at Count l(B) to 6 months supervised probation with a
special condition that he have no contact direct or indirect with
the victim and this probation was to be consecutive to the 6 months
probation at Count l(A).
WHEREAS, Robert Gramm, Jr., signed conditions of probation
indicated that he understood them and agreed to abide by them. The
6 month probation at Count l(B) expires on January 23, 2002.
WHEREAS, Robert Gramm, Jr., has violated conditiom #1 "You must
comply with the laws of the United States, the -C~Oj~ th of
Pennsylvania and the community in which you i~.>;...... io~ed
probation condition #3 "You must remain on goo -''l=ha or"_nd
violated a special condition of probation "no coae:c' -wi trrthe
victim, Elen:L Imes" in that Sgt. Dugan of the FairV'i,w wmfl'ilp,
York County, Police Department, has filed an Indi", , t 1]:' al
Contempt charge against Robert Gramm, Jr. with th :z:~ct:JJR b 'ng
listed as Eleni Imes. A hearing was scheduled on a~~y~;~, 20 2
before a York County Judge, at which time Robert Gra~; ~'~failed
to appear and a Bench Warrant was issued.
WHEREAS, Robert Gramm, Jr., has violated probation condition #7
"You are required to pay all costs, fines, and restitution as
directed by the Court" in that according to the Clerk of Court
Records under #2000-56963 no payments have been received.
THEREFORE your petitioner prays this Honorable Court to determine
whether there has been a probation violation and if so, whether the
probation heretofore granted should be revoked.
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ROBERT GRAMM, JR. - PETITION
Page 2
I verify that the facts set forth in this petition are true and
correct to the best of my knowledge or information and belief.
This verification is made subject to the penalties of section 4904
of the Crimes Code (18 PA C.S. @4904) relating to unsworn
falsification to authorities.
Respectfully Submitted,
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ELENI IMES,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
ROBERT GRAMM, JR.,
Defendant
00-6963 CIVIL TERM
IN RE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this 23rd day of January, 2001, the
Defendant, Robert Gramm, Jr., now appearing in court for sentence
with the Public Defender, Ellen K. Barry, Esquire, and having
previously been found guilty following a bench trial of two counts
of indirect criminal contempt for violation of a protection from
abuse order dated October 11, 2000, and the Court being in receipt
of a pre-sentence investigation report, upon which it relies, the
sentence of the Court is as follows:
At Count l(A), the Defendant is sentenced to pay the
costs of prosecution and a fine of $250.00, and to undergo a
period of probation with supervision of 6 months, conditioned upon
his being and remaining on good behavior, complying with all
written directions of his probation officer, having no contact,
direct or indirect with the victim in this case, Eleni Imes, and
continuing to undergo psychological treatment until successfully
discharged by the care provider.
At Count l(B), the Defendant is sentenced to pay the
costs of prosecution and a fine of $250.00, and to undergo a
period of probation with supervision of 6 months, conditioned upon
his being and remaining on good behavior, complying with all
written directions of his probation officer, having no contact
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direct or indirect with the victim in this case, Eleni Imes, and
continuing his psychological treatment until successfully
discharged. The sentences imposed herein shall run consecutive to
each other.
By the Court,
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Jonathan R. Birbeck, Esquire
For the Commonwealth
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Ellen K. Barry, Esquire
For the Defendant
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CERTIFICllTIOO OF PTh CCNl'EMPl'
CASE IU-IBER 60 - Co 7 f.t, 3 j
NAME R()herL L b rCLvV\l'Y'I, J /,_
4{9 4-tCt 5'* YUL
N-uv c.l.LMheV (({I'\L PA /1070
BALANCE DUE: $ G, {6-' 54-
VICTIM'S NAME:
8 - AA - "7
e~VI par/it L MC5
ADD
DELETE
170
171
260
207
204
502
STATE SURCHARGE
STATE FINE
SHERIFF COST ($1.50 + ADDTL)
DISTRICT ATTORNEY
COURT COSTS (CLERK OF COURTS)
RESTITUTf\lN
NAME j---l r-o-l: iumoLa.~~
$ J,j-, CD
$
$
$
$
15.00
15.00
$
$
$
$
$
40,oLf.-
$
46:(jD
$
ADDRESS
CITY
STATE
ZIP
NAME (J CXLrt hfl,f:S
(A-~ R,)
$ 6-tnll
$
ADDRESS
CITY
STATE
ZIP
NAME
$
$
ADDRESS
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STATE
ZIP
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CERTIFICATlCN OF PFA CCNl'EMPT
,
CASE tUmER 00-6963
NAME Robert L. Gramm, Jr.
VICTIM'S NAME:
419 4th Street
F.1Ani Maria Imes
New Cumberland, PA 17070
BALANCE DUE:
$ l?S sa
ADD DELETE
$ $
$ $
$ 40.04 $
$ 25.00 $
$ 15.00 $
$ 45.50 $
170 STATE SURCHARGE
171 STATE FINE
260 SHERIFF COST ($1.50 + ADDTL)
207 DISTRICT ATTORNEY
204 COURT COSTS (CLERK OF COURTS)
502 RESTITUTION
NAME Prothonotary
ADDRESS
CITY
STATE
ZIP
NAME
$
$
ADDRESS
CITY
STATE
ZIP
NAME
$
$
ADDRESS
CITY
STATE
ZIP
PROTHONOTARY OFFICE
PERSON CERTIFYING INFORMATION
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AMENDED
CERTIFICATIC1'l OF PFA aNl'EMPT
Cl\SE ~
00=6963
NAME
Robp.rt L. GRAMM, JR.
419 4th St.
VICTIM'S NAME:
Eleni Maria IMES
New Cumberland PA 17070
BALANCE DUE: $ 390.54
ADD DELETE
$ 25.00 $
$ $
$ 40.04 $
$ 15.00 $
$ 15.00 $
$ 45.50 $
170 STATE SURCHARGE
171 STATE FINE
260 SHERIFF COST ($1.50 + ADDTL)
207 DISTRICT ATTORNEY
204 COURT COSTS (CLERK OF COURTS)
502 RESTITUTION
NAME Prothonotary
ADDRESS
CITY
STATE
ZIP
NAME
Court Fine
$
250.00
$
ADDRESS
CITY
STATE
ZIP
NAME
$
$
ADDRESS
CITY
STATE
ZIP
.,omONOTARY omeE ~ J 4 . ~
PERSON CERTIFYING INFORMATION . ~ 1!---vJ---, / ~~
DA 11-18-01
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ELENI IMES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LAW
ROBERT GRAMM, JR.,
Defendant
NO. 00-6963 CIVIL TERM
ORDER OF COURT
AND NOW, this 13th day of September, 2004, upon consideration of the attached
memorandum from Defendant's parole officer, Charles R. McKenrick, Esq., the Petition
for Revocation of Probation filed January 22,2002, is dismissed.
BY THE COURT,
Office of the District Attorney
Office of the Public Defender /J:1J.. A
Probation Office ~~
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MEMO
TO:
Judge J. Wesley Oler, Jr.
Charles R. McKenrick C ~
FROM:
DATE:
September 3, 2004
RE:
Robert L. Gramm, Jr.
In an effort to clear this Petition for Revocation of Probation, I spoke with Sgt. Dugan,
Fairview TWP P.D., York County. No action has been taken on his case for over 2 years and
probably won't.
I have no interest in pursuing this, and ask your Honor to enter an order dismissing the
petition.
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