The URL can be used to link to this page

Home My WebLink About00-07077 --"~ ...~. -~,~ ,< ....-..~ - ~ ~~, ~"'k' 1 "n_~~_,,:,' SHERIFF'S RETURN - REGULAR CASE NO: 2000-07077 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GHEEN SHALON LEE VS BLOSSER KEITH ALLEN CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within NOTICE OF HEARING & ORDER was served upon BLOSSER KEITH ALLEN the DEFENDANT , at 0008:50 HOURS, on the 16th day of October ,2000 at CUMBERLAND COUNTY PRISON 1101 CLAREMONT ROAD CARLISLE, PA 17013 by handing to KEITH A. BLOSSER a true and attested copy of NOTICE OF HEARING & ORDER together with TEMP PFA & PETITION and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.10 .00 10.00 .00 31.10 So Answers: ~~~! R. Thomas Kline 10/17/2000 Sworn and Subscribed to before By: ~~~?if me this -? 3.<_.( day of (J e:t;;t., ., 2 o-<.rO A . D . ~ O. Jvu_/;~. .J<-~~ othonotary I t- COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUrrberland POLICE CRIMINAL COMPLAINT gisterial...Dtstrict...NUTber: 09 - 3 -02 istrict Justice Nan=:Hon. Helen B. SHOLENBERGER cljress: 27 W. Big Spring Ave. Newville, PA 17241 COMMONWEALTH OF PENNSYLVANIA VB_ TelerJlore: (717) 776-3187 DEFENDANT: NAME and ADDRESS r Keitb:Allen BLOSSER 428 Ctoc10tO':l<H.<<J.., Newville, Pa.17241 I ocket No.: Date Filed: OTN: L 3'1'0 C!r"..k e.; .s:h.,,,,.,., ..-....sdo-I... f1lJ. , 1'1 0 I d -.l Defendant's Race/Ethnicity lXJ W,ite 0 Asian o Hispanic D Native .ArTEr-jean eferdantls A.K.A. o Black DlJrkroI.n efen::l2ntls Sex efendantls D.D.B.: ef~tls Social Security NUTter efen::lantls SID o Farale IZJ Male 03/01/:).972 :' ,162~68-5807 eferdant's Vehicle Infonration: eferdant's Driverls License Nurber Plate NU1'b;r State_ Registratic:n Sticker(r<M/YY) State Carplaint/Ircident Nurber H2-1157154 CarpLaint/Incident NUTbers if other partici]Elts CR/N I BRS COO2 999 District Attorney's Office n Approved 0 Disapproved because: ' <Th~ district atto~ rray req.Jire~t the carplaint, arrest warrant affidavitr or ooth t.e awroved bt ~he attorney for the Ccmn::rMealth prior to fllll13 Pa.R.Cr.P. 107.) , (Nare ot Attorney tor Canrl::iMeaLth - Please prmt or lype) (S191C1ture ot Attorney tor Ccmn::nJeaL th) (pate) I, Co!. James R. WILSON (Nare of AffiantwPlease Print or Typ=) of PA State Police CIdentify Departrrent or Agen:y Represented ard PoL itical SLb:iivision) do hereby state:(check the appropriate box) PAPSP1000 (Pol i~ Agef'Coj au Nurt::er) 4553 (Officer Bad3e Nurl:er/I.D.) H2-1157154 (Originating Agency Case Nurl:er(OCA)) 1. i:2l I accuse the above named defendant, who lives at the address set forth above o I accuse an 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 428 Steelstown Rd., Newville P '" rth N ......+- "T'\<........... (Place-Pol itical SLb:livlsion) a_ , ,,0 ew~on .wt-'. in Cumberland County on or about 10/20/2000, 0320-0345 hrs. Participants were: (if there were participants, place their names here, repeating the name ofthe above defendant) Keith Allen BlDSSER 2. The acts committed by the accused were: (Set forth a SUlIlBry of the facts sufficient to ,advise the deferdant of the nature of the offense charged. A citation to the statue allegedly violated withcut rrore, is rot sufficient. In a SllTIIBry case, you rrust cite the specific section ard stbsection of the statute or ordinan:e allegedly vlo.lated.) The Defendant did violate an order issued by the . under the Protection frcm Abuse Act F.R. 1992-5l2 dated 06/04/1992, by order of Carm::m Pleas of Cumberland County. The PFA No 00 7077, Civil Tenn was issued by the Honorable Judge George E:' HOFFER, on the 13th day of October 2000. . ACJ?C 412-(4!96)CIntemet Versial) 1-3 " 0",,", j,. ~":" "', --. ,,' ~'" _ L _~"_. '.~ . ,., ' ~""'~lIIillJ_ t- AFFIDAVIT of PROBABLE CAUSE POLICE CRIMINAL COMPLAINT Defendant Name: Keith A. BLOSSER. Docket Number: The victim Shalan we GHEEN, possesses a valid Cumberland Co. PFA order. This order states that the Defendant shall not abuse, stalk or threaten the victim in any place were she is found. On 10/22/2000 between the hours of 0320-0345 the defendant went to 428 Steelstown Rd., in North Newton 'IWp., Cumberland Co., while there he threaten to do bodily haIm to the victim and threw a beer bottle at the residence. This was witnessed by another party at the residence and the victim. I, e~ Jij1Mi!""S f CJds~ ,BEINGDULYSWORNACCORDINGTO LAW, DEPOSE AND SAY THAT THE FACTS SET FORTH IN THE FOREGOING AFFIDAVIT ARE TRUE AND CORRECT TO THE BEST OF MYKNO GE'Th1FO~ BELIEF. S1Qnature 0 lant Sworn to me and subscribed before me this;;;) S j-'J day of 0 if. b.('~ ,WO" . /O-~3--tJP Date ~-.6,~ t' , District Justice My commission expires first Monday of January,~ Il tJ (, SEAL AOPC 412-(4/96)(lnternet Version) 3-3 ~ " - __, - ~~ '- <.',' ,- , I" , ">.",,,,=1, ,,,0:.';,,;,,,:,,,,"',' ',', ~~ , (Continuation of 2.) Defendant Name: Keith Allen BLOSSER 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 DR 1 (Section) (Sub-Section) (PA Statute) (counts) 2. of the (Section) (Sub-Sect ion) (PA Statute) (counts) 3. of the (Section) (Sub-Section) (PA Statute) (counts) 4. of the (Section) (Sub-Section) (PA Statute) (counts) 3. 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. 4. 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. ~ 490;Dre~ti;g~0 unsworn falsification to aut,h~~~~ C\ _ A l.) W 55 ) ~ ~ ~at~ 0' A"'ant) AND NOW, on this date 1/)-.;;1.3. ,!-!to J , I certify the complaint has been properly completed and verified. An affidaVlt of probable cause must be completea in order for a warrant to issue. o 1 ...- 3- II ~ (Mag1sterlal Dlstrtct) AOPC 412-(4/96)(Internet Version) ~6/~~:;~r~ 2-3 SEAL L. "' ~. ' ,~~ -"~"""",,;.,. Complaint No. Year Number Helen .B. Shulenberger District Justice Magisterial District 09-3-02 27 W. Big Spring Avenue Newville, PA 17241 Complaint No. of other Participants COMMONWEALTH OF PENNSYLVANIA VS. and Address) Defendant (Name ~ CU&- 6 /OJ.J <-~ I 7 ~D ~. K..I IS;.. . -"'- J J.. J~ , f'i). I '")D 1v ~ C 0 U N S E L QUE S T ION N A IRE Do you have an attorney? .~ ~. Do you understand that you are entitled to have an attorney to represent you in this proceeding if you wish one? ~ Do you further understand that if you are indigent and financially unable to employ an attorney to represent you that this court will see that one is provided for you without cost to you? _~ Once you have been advised of your right to have an attorney, do you wish to have an attorney before we proceed with this case? ~.~ I hereby certify that I have read the above questions, that they have been read to me, and that I have made the answers to them as indicated therein. >~ .(N e) I hereby certify that I have read the above questions to the defendant, , /(e,/-J., if //.~ t3IDJ.F"'-V' , and that the answers thereto were either written by him, or were written by me at his direction, and I further certify that I am satisfied that he/she fully understands the meaning of the questions and answers. , ...~e~~ce t I ()- .:2.3_ dO (Date) Month - Day - Year . ~~ ~ ." I. ..... i. J-"~". ...h '#i;>."",*",;;;"-"", COMMONWEALTH OF PENNSYL V AN IA COUNTY OF: CUMBERLAND 09-3-02 PRELIMINARY ARRAIGNMENT NOTICE COMMONWEALTH OF PENNSYLVANIA Mag, Dist. No.: DJ Name: Hon. HELEN B. SHULENBERGER Add,,,,, P.O. BOX 155 27 W. BIG SPRING AVENUE NEWVILLE, PA T",phC" (717) 776-3187 17241 VS. DEFENDANT: NAME and ADDRESS 'BLOSSER, KEITH ALLEN 340 CREEK ROAD SHERMANSDALE, PA 17090 L Docket No.: CR-0000220-00 Date Fi[ed: 10/23/00 OTN: E 936074-6 I HELEN B. SHULENBERGER P.O. BOX 155 27 W. BIG SPRING AVENUE NEWVILLE, PA 17241 .J Charge(s): r3 56110 55 VIO. OF PFA You are hereby notified lhat a preliminary arraignment will be held in the above captioned case at the following time and place: Date: 10/23/00 Place: DISTRICT COURT 09-3-02 P.O. BOX 155 Time: 1:20 PM 27 W. BIG SPRING AVENUE NEWVILLE, PA 17241 At the preliminary arraignment, you will be given a copy of the criminal complaint thal has been filed against you. In addition, you will be advised of your right to counsel, your right to a preliminary hearing, and the amount and types of bail available if your offense is a bailable offense. At the preliminary arraignment, a date and time will be fixed for your preliminary hearing and you will be given a reasonable opportunity to post bail. [f bail is not posted, you may be committed according to law. If you are disabled and require assistance, please contact the Magisterial District office at the address above. If you have any questions, please call the above office Immediately. 10/23/00 Date /~ 6 ~dJ..o<..,/ ,/ My commission expires first Monday of January, 2006 . , District Justice SEAL DATE PRINTED: 10/23/00 ALL COPIES PRINTED COMPLAINT NuMBER: DATE COMPLAINT SIGNED: 10/23/00 AOPC 630-97 ~m=~.~' .". ;'''''~M;~",,,,,,;,-, COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND NOTICE OF HEARING Mag. Dist. No.: 09-3-02 COMMONWEALTH OF DJ Name: Hon. HELEN B. SHOLENBERGER Addee,. P.O. BOX 155 27 W. BIG SPRING AVENUE NEWVILLE, PA Teleph". (717) 776-3187 17241 PENNSYLVANIA COMMON PLEAS CUMBERLAND COUNTY VS. DEFENDANT: NAME and ADDRESS 'BLOSSER, KEITH ALLEN 340 CREEK ROAD SHERMANSDALE, PA 17090 L Docket No.: CR- 0000220 - 00 Date Filed: 10/23/00 OTN: E 936074 - 6 Charqes(s): I --1 __ r3 S6110 SS VIO. OF PFA A hearing has been scheduled for the above captioned case for the following purpose: PFA VIO HEARING TO BE HEARD BEFORE THE HONORABLE JUDGE HOFFER The hearing will be held at the following date and time: Date: 10/31/00 Place: COMMON PLEAS CUMBERLAND COUNTY Time: 1:30 PM -- If you are disabled and require assistance, please contact the Magisterial District office at the address above. Please contact this office immediately if you have any questions. - 10/23/00 Date _/~ .6 "U../, L,'t d '"^-'"'" , District Justice ./ My commission expires first Monday of January, 2006 . SEAL DATE PRINTED: 10/23/00 COMPLAINT NUMBER: ALL COPIES PRINTED DATE COMPLAINT SIGNED: 10/23/00 AOPC 612-97 ..- ~-'-. ""'-~__C~" COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND COMMITMENT Mag. Dis!. No.: 09-3-02 COMMONWEALTH OF DJName: Hon. HELEN B. SHULENBERGER Add",", P.O. BOX 155 27 W. BIG SPRING AVENUE NEWVILLE, PA T,I,ph,," (717) 776-3187 17241 PENNSYLVANIA COMMON PLEAS CUMBERLAND COUNTY VS. DEFENDANT: NAME and ADDRESS 'BLOSSER, KEITH ALLEN 340 CREEK ROAD SHERMANSDALE, PA 17090 L Docket No.: CR- 0000220 - 00 Date Filed: 10/23/00 OTN: E 936074-6 Date of Birth: 3/01/72 SSN: 162 - 68 - 5807 I -.J 123 56110 55 VIO. OF PFA To ANY AUTHORIZED PERSON of the above named County of this Commonweaith: You are hereby commanded to convey and deliver into the custody of the Keeper of the county prison the above named defendant. You, the Keeper are required to receive the defendant into your custody to be safeiy kepl by you untii discharged by due course of law for: D A PERIOD OF _ DAYS UNTIL Charae(s\: Ii] A HEARING AT Date: 10731700 Place: COMMON PLEAS CUMBERLAND COUNTY Time: 1:30 PM D A FURTHER HEARING ~ PI", II 11"'" Time: D COMMON PLEAS COURT ACTION D OTHER: CURRENT AMOUNT OF BAIL: COMMITMENT REASON: BAIL 5,000.00 STRAIGHT BAIL NOT POSTED Witness my hand and official seai thip3""~ay of 0 c.j-- j5-.::2.3-4/J Date Ok6A-~ .L - . . (5 , My commission expires first Monday of January, 2006, 00 '-' , District Justice SEAL AOPC 609-99 ,- ~. , '~j"I""," COMMONWEALTH OF PENNSYLVANIA COUNTY OF: CUMBERLAND CERTIFICATE TO FACILITATE BAIL Mag. Dist. No.: 09-3-02 COMMONWEALTH OF PENNSYLVANIA DJ Name: Hon. HELEN B. SHULENBERGER Add,.", P.O. BOX 155 27 W. BIG SPRING AVENUE NEWVILLE, PA T,r,ph009 (717) 776-3187 17241 VS. DEFENDANT: NAME ami ADDRESS 'BLOSSER, KEITH ALLEN 340 CREEK ROAD SHERMANSDALE, PA 17090 L Docket No.: CR- 0000220 - 00 Date Filed: 10/23/00 OTN: E 936074 - 6 "I HELEN B. SHULENBERGER P.O. BOX 155 27 W. BIG SPRING AVENUE NEWVILLE, PA 17241 ~ DEFENDANT NAME: 'RT.n!=:~n;~'R I 'K'RT'JIH ~T.T.'RN Chargers): 13 56110 55 VIO. OF PFA PLACE OF DETENTION: CUMBERLAND CTY PRI (Name) CUMBERLAND COUNTY PRISON (Address) 1101 CLAIRMONT ROAD CARLISLE, PA 17013 AMOUNT OF BAIL (if set): 5,000.00 STRAIGHT BAIL BAIL MUST BE POSTED BEFORE: AOPC 607-97 ~~., ,-~~", ~~ jtM,.." ,." ~....~. . ..... .~...~l~lli~""""""'" "-~\\lWi~,~,;!l;;r~t..~,- ---- __s"- =,~"'-I'l_I'''''''A<,~ '~""" "^,, =_" -,L "_,_'r_,,>_,~"""" '<'~"F"_'__'"'' ~"~C<~"""',,'h.",,~'_"'__l_,,,*"""""",,<, ., ,."._ "" =, ~, "~) _,'<0 __^ 1:.1 n-i ~ ~::;: ~~:: ( 5~;;'~ ~ "..' .,.,. ,_o~ (") E ~~ ~ , . i;[ ! ~! L.";; ;:J ~-) ..---; 1'-> f",J ''''~') (::> ~~~ ~< ,-~" ,'" - l"-mi'a_,J,,' SHALON GHEf;: N) Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 00-7077 CIVIL KEITH ALAN BLOSSER, Defendant : CHARGE: INDIRECT CRIMINAL CONTEMPT ORDER OF COURT AND NOW, thisL <.(. ~ of October, 2000, the hearing in the above- captioned case previously scheduled for Tuesday, October 31,2000 at 1 :30 p.m. in Courtroom #3 is rescheduled for Thursday, October 26,2000 at 1:30 p.m. in Courtroom #3. The defendant, KEITH ALAN BLOSSER, is ordered to appear for trial on the charge of Indirect Criminal Contempt before the Court on that date. Jonathan R. Birbeck, Chief Deputy District Attorney PI. KEITH ALAN BLOSSER ~" ~ _"<_"_""~"'''~I n. ~-,. ---"-- ~~ (-" rr"\-I' ,. !I' , ,-;. I. q " ,~ . ..;. w' CUi\'j 2,~:t;~:-;'~.I~ ;;~; ><_~.~:i\; TY \"c:i\W!\)lU!'-',I-.!J--\ I Ii I I 1'._. .~ ~ 'j:ln1l'j7 ~ _l!l''. '-'IT T~.~ ,~ _ . -~,,~, \L"" '> OM ,~'~. ~_ ,~, "'W~ 11!fJ!!l.'~'W~'r~~~~"'-"'-= ~. ,_~o < ~ ,~~~- - ", ""'>iJ"'i>M:il.;'-oo,.. SHALON GHEEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 00-7077 CNIL KEITH ALAN BLOSSER, 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 ofthe 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 of Indirect Criminal Contempt pursuant to 23 Pa.C.S.A. S 6113. 6. The plaintiff and/or the defendant may seek modification ofthe 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. Respectfully submitted, GJ:.A M {(~ ~ J/'-6 ~:i: Birbeck "--lP"--:j Chief Deputy District Attorney '~"'lil -"" , . ~- ,~, I_'j 10fl~3/00 14:25 FAX 717 776 9284 . . cOMMONWEP;LTH OF PENNSYLVANIA COUNTY OF: Cumberland gisterial District NuiIler: 09-3-02 istrict Justice Nme:Hcn. Helen B. ~ 27 W. Big Spring Ave. . Newville I PA 17241 . Telep,,,,,: (717) 776-3187 ~'"",N' ate Filed: OTN: fa-dant IS RacelEthnieity I&ll.l1ite 0 Asian 0 BLack o HisJDric 0 Nati"" _iean 0 \licn:ll,n ferrl:intls A.K.A. -'!&11 ."1~M>!tk'D'-;< n.J. (09-3-02) ()O -7077. ~002 POllCE CRIMINAL COMPLAINT COMMONWEALTH OF PENNSYLVANIA VB. NAME and ADDRESS . Allen BIDSSER -, I ., 3'1''' a.......k .e../. Ie, Pa.17241 ~...,., _.rdtJol... ;:;4- I 1'/ 0 "j d .J L efen:Ia1t's Sex e ~ =le 03/ 1/+977 efer'd3ntls Vehicle Plate Nulber c"",laint/ln::ide!1t NUJter E2-ll57154 Di~ct ~ttorney's Office. n Apprave~ 0 Disappro ed becau e: ql1r: dl.strlct atto~ nBY n:q..nre'tJclt the cmplamt, arrest warrant icSvit, brth t:e ~ by the attol'TEY for the Canll:rWealth prior to f,l ""9 Pa.R.Cr.P. llJ7.) cmplaint/ln::ide!1t Nulbers i (N.:ne ot A't'tomey tor ~ltl1 - Please ptmt or Iype) I, an-es R. WILSON (N"", of Affiant-Please Print or T)1lO) of PA Stat Police (Identify IlEparlllEnt or Ptpq RepresentEd an:! Pol itical SI.txlivis do hereby state:(check the appropriate box) 1. IXI I accuse the above named defendant, who lives at D I accuse an defendant whose name is unknown to 'f 'S So:ial security Nulber . ..lt2~68-5807 erd;rrt:ls SID efer'drrt.s Driverls License NUTter state ,gnatu e (Date) rrey or 45 (Officer aq. Nulber/I .0.) H2 - 157154 (Originatil'"El ~ Case NuiIler(OCA)) D I accuse the defendant whose name and popular d signatio or nickname is unknown to me and whom I have therefore designated as John Doe with violating the pen.al laws of the Commonwealth Pa., North Newton in CUmberland County on or ab t 10 2 0320-0345 hrs. Participants were: (if there were participants, place th ir names here, repeating the name of the above defendant) Keith Allen SER 2, The acts committed by the accused were: (set forth a SlllIIBl)' of the facts sufficient to !dvise the deferdlnt witha..rt: mre, is not sufficient. In a SlJRIEIry case, ytU nust dte the The Defendant did violate an order i F .R. 1992-51.2 dated 06/04/1992, by 0 PFA No 00 7077, Civil Tenn was is the 13th day of October 2000. lIPr. 4"-([.IQf,){Tnt~f'Tgt Vp~;rn\ 'aat 428 Steelstown Rd.~ewville . (Place-Pollt1cal ivisi<<l) the rature of 'the offerse dtarged. A citatial to the stab..e allega::lly v;olata::l ific s ien en:f Sltsectim of the statute or ordif"lEll"Ce allegedly vlolated.> by the under the Protection fran Abuse Act r of amon Pleas of Cultberlarui County _ The by the Honorable Judge George E. EDFFER, on 1_:'1 ~ L i, j~- -"~".~ili\',-: 10/23/00 14:25 FAX 717 776 9284 . {Continuation of 2.) n.J.(09-3-02) 1i!I003 Defendant Name: Keith Allen BLOSSER POLICE Docket Number: CRIMINAL COMPLAINT i t..; ~ .~' .." "" all of which were against the peace and dignity of th of Assembly, or in violation of 1. 6113 (Section) Commo ealth of Pennsylvania and contrary to the Act 01 the DR 1 (Sub-Sect on) (PA Statute) (counts) 2. (Section) of the (Sub-Sect on) (PA Statute) (counts) or the (Sub-Sect on) CPA Statute) (counts) of the (Sub-Sect on) (PA Statute) (counts) (Section) 3. (Section) 4. 3. I ask that a warrant of arrest or a summons be is I have made. an order for a warrant of arrest to . and sworn to before the issuing alIthority. 4. I verify that the facts set forth in this complaint ar and belief. This verification is made subject to the ~ 4904) relating to unsworn falsification to autho 7- ID -)...3 at the defendant be required to answer the charges ed affidavit of probable callSe must be completed AND NOW, on this date completed and verified. An cortect to the best of my knowledge or information f Section 4904 of the Crimes Code(18 PA C.S. Od.~. JJJ.. 'ff,~f,$2 , !-!td J , 1 certify the complaint has been properly ompleteiI in order for a warrant to issue. 01.,. 3- tI~ (Mag1sterlal Dfstrlct) AnPf'. L."_'''-IO~\f l................ "........: --" 6' SEAL n n . - w ...1 ~~, .- "~-_""N_'^ 10/23/00 14:25 FAX 717 776 9284 u. J. (09-3-02) @.Q04_ AFFIDAVIT 0 PRO ABLE CAUSE POLICE CRIMINAL COMPLAINT DefendantName: Keith A. BLOSSER Docket Number: The victim Shalan Lee GHEEN, possesse states tbat the Defendant shall not were she is found. On 10/22/2000 bet to 428 Steelstown Rd., in North Newt to do bodily baIrn to the vict:ini and a witnessed by another party at the res dence a val d Umiberland Co. PFA order. 'Ibis order e, s alk or threaten the victim in any place hours of 0320-0345 the defendant went CUriberland Co., while there he threaten bottle at the residence. This was the victim. . Jl'}1'\rIS K: UJds~ LA: , DEPOSE AND SAY THAT THE FACTS TRUE AND CORRECT TO THE BEST OF MY G DULY SWORN ACCORDING TO IN THE FOREGOING AFFIDAVIT ARE INFO~}mT.mli'. 19nature 0 lant I, J Sworn to me and subscribed before me this ;;! '3 '"' ,;18'04. /0-:;;)'3-- (JP Date ~~ .p , District Justice My commission expires first Monday of January~ {) t, SEAL a/"lDf" t..1:>_fl,/O~"T....----... ,,~--~--~ -"II >be J ., 1_..."" SHALON LEE GHEEN, Plaintiff : In the Court of Common Pleas of : CUMBERLAND County, : PENNSYLVANIA v. : Civil Action - Law KEITH ALAN BLOSSER, Defendant : No. 00- 7()77 : PROTECTION FROM ABUSE FINAL ORDER OF COURT Defendant's Name is: KEITH ALAN BLOSSER Defendant's Date of Birth is: March 1, 1972 Defendant's Social Security Number is: 162-68-5807 Name(s) of All protected persons, including Plaintiff and minor children: 1. SHALON LEE GHEEN Appearances by Parties and/or Counsel: ... . Plaintiff-appeared-personally and is represented by: Joan Carey, Legal. Services, Inc. . Defendant appeared personally and is unrepresented. AND NOW, this 18th Day of October, 2000 the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows: Upon agreement of the parties for the entry of a consent order, this order will be entered without any admission of liability by the defendant and without a finding of abuse by this court: Plaintiffs request for a fmal protection order is granted. . ~ .~"' '~~ilt\ t, j~ ., . " - .~ ,....dlif'!j*'''' l. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other protected person in any place where they might be found. 2. Defendant is completely evicted and excluded from the residence at: 428 Steels town Road Newville, P A or any other residence where Plaintiff may live. Exclusive possession of the residence is granted to Plaintiff. Defendant shall have no right or privilege to enter or be present on the premises. 3. 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 of this order. Plaintiffs current residence: 428 Steelstown Road Newville, PA Plaintiffs place of employment: SECCO 1111 Primrose Avenue Camp Hill, PA - Non-harassing phone contact by Defendant is not prohibited and will not be deemed a violation of this Order. /' 4. The following additional relief is granted as authorized by 96108 of the Act: -Defendant is ordered to refrain from harassing Plaintiffs relatives. -Defendant is enjoined from damaging and/or destroying property owned solely by Plaintiff. -The court costs and fees are waived. " - ~. ~,I ~ .. ;;'l~' u!i;j~!lI~!' 5. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: PENNSYL VANIA STATE POLICE - Plaintiffs residence LOWER ALLEN TOWNSHIP POLICE - Plaintiffs employment 6. THIS ORDER SUPERSEDES: I. ANY PRIOR PF A ORDER 7. All provisions of this order shall expire on: April 18, 2002 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. g6114. 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. g2265. 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 gg2261- 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. g922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION. NOTICE TO LAW ENFORCEMENT OFFICIALS The police who have jurisdiction over the plaintiff's residence OR any location where a violation of this order occurs OR where the defendant may be located, 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. g6113. --- ~, "I, .-","" , """"""'~-'. 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 for Irtdirect Criminal Contempt" shall then be completed and signed by the police officer OR the plaintiff. Plaintiffs 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. BY THE COURT, resident Judge If entered pursuant to the consent of Plaintiff and Defendant: an Carey Attorney for Plaintiff Legal Services, Inc. S Irvine Row Carlisle, PA 17013 ..,- ~~ --: ~~ Keith Alan Blosser, Defendant Pro Se Distribution to: -Legal Services, Inc. -Fax and Mail PSP -Keith Alan Blosser Cumberland County Prison 1101 Claremont Drive Carlisle, PA 17013 CERTIFICATION OF BAIL IOTN POLICE CASE NO, D_J, NO. AND DISCHARGE C.P TERM & NO, 00-7077 Civil COMMONWEALTH VB. (Defendant Name and AddreSs) CHARGE(S) contemptl DATE OF CHARGE(S) Keith Allen BLOSSER c/o Phyllis Reese Indirect Criminal 340 Creek Road, Shermansdale PA (PFA) o ROR (no surety) o Nominal Bail KJ Bail (total amount set. if. any) . $ 5,000.00 o Conditions of Release (aside from appearing at court when required:) NEXT COURT ACTION OATEANDTlME IILOCATION Courtroan No 3 Comply in all respect with prior order 10/26/00 @ 1:30 PM Cumb. Co. Courthouse of October 18, 2000. Defendant shall IKl Detention Center o Other appear at hearing on Thursday, October TO: 26, 2000 at 1:30 P.M. I hereby certify that sufficient bail has been entered D By the' defendant D On behalf'of the defendant by: (attach addendum, if necessary) Vivian 1. Rockey SECURITY OR SURETY (IF ANY) D Surety co~pany (Name & Address of SUrety) (License No.) Qg Professional Bondsman . Refund of cash bail will be made within 20 days after o Realty final disposition. (P'a.R.Cr.P. 4015(b)) o Other . Refund of all other types of bail will be made promptly after 20 days following final disposition. (Pa.R.Cr.P. 4015(a)) JUDGE OR ISSUING AUTHORITY George E. Hoffer, P.J. . Bring Cash Bail Receipt to Clerk of Court. DISCHARGE THE ABOVE-NAMED DEFENDANT FROM CUSTODY IF APPEARANCE OR BAil BON D DETAINED FOR NO OTHER CAUSE THAN THE ABOVE STATED. THIS BOND IS VALID FOR THE ENTIRE PR()gEEDINGS AND Given under my hand and the Official Seal of this Court, UNTIL FULL AND FINAL DISPOSITION OF THE CASE INCLUDING FINAL DISPOSITION OF ANY PETITION FOR WRIT OF CERTIORARI this 24th day of October .~OOO OR APPEAL TIMELY FILED IN THE SUPREME COURT OF THE ~'"~/.J_ A ~ A A /). UNITE,) STATES. . . (SEAL) - ( ISSUingAUrhlr y) Deputy Prothy. WE, THE UNDERSIGNED, defendant and surety, our successors, heirS1fnd assigns, are jointly and severally bound to pa to the ~_il;""""''''iIiil!~~_'!I!!lI.;4';;J,r;;'''~':-''''''''~'''''''.''"''","''"''~'I.,j..~;-~-~_1-~:~IiW!!l',;l!I~ --~~,_~!illli:>(~-I '<;J'U -~'-'d~ -~lr t'1i ~~:- L~~~~M!~"'Ma''/;j''''''i:'''"N~~~ """-"'l;- ., ii " ., ,. Commonwealth of Pennsylvania the sum of Five Thousand and no/100 doltars($ 5,000.00 y ). SEE REVERSE SIDE FOR'BAILCONDITIONS .. CERTIFICATION OF COUNTER INDEMNITY AND PREMIUM (Applicable Only When Surety Is A Corporation) , Principal, and hereby certify that the amount paid by said Principal to said Surety for bail in the above matter is $ and that no further sum or sums is to be paid therefore by the said Principal or anyone on his behalf. We further certify that said Principal has given to said Surety counter indemnity consisting of of the value of $ as follows: , Surety, and no further counter indemnity is to be given the said Surety except We further certify that there are no judgments against the said corporate surety outstanding and unpaid for a period of more than thirty days from the date of the entry of such judgment except those in which a petition to open or vacate the judgment has been filed and remains undisposed of: Dated: .19 (SEAL) (Principal) MUST BE SIGNED IN PERSON BY THE APPROVED AGENT I ACKNOWLEDGE THAT lAM LEGALLY RESPONSIBLE FOR THE FULL AMOUNT OF THE BAIL. EFENDANT..{l: Signature of Surety (May be B dsma individual or organization). Except when, efe own recognizance (ROR), this must be including nominal bail. (SEAL) The following acknowledgement is also applicable if Percentage Cash Bail is used. THIS BOND SIGNED ON October 24. 2.wJ~ ~lisle PENNSYLVANIA. (SEAL) Signed and acknowledged before me this day. of Or.tober ~ ADDRESS OF SURETY, SURETY COMPANY OR DEFENDANT Surety No or Professional Bondsman License No. & Expiration Date Deputy . In e of corporate surety bail, Power of A rney must be affixed to bond or otherwise bond is invalid. Prothy. ORIGINAL . In case of Percentage Cash Bail or Nominal Bail, Power of Attorney is not required. Aope 414.80 .._,;,___, "':f,lk!1Mil!!!iM18.f*~~[,!;~~..&Te~iil.i.i'''j'''-~0.~~8w~~I~I!iIHI~I~. _~.-,,~J _~ ItAIl CONDITIONS. The CONDITIONS of this bond are that the defendant will. (1) Appear before the issuing autllority and in the Courts of the County of , Pennsylvani~, at ail times as his presence may be required, ordered D! directed, _until fuli and fillal disposition of the case, to plead, to answer and defend as ordered ~he afcresaid charge or charges. (2) Submit himse;f to all orders and pmcesses of ths ;ssuin'd authority or Courl. (3) The DEFENDANT and SURETY must give V'JI'itten noiil;e 10 tile issuing authority, Clerk of Courts, the District Altomey AND Court Bail ,6,gency, of any change in his address within f-ony-eight Ilours Of the date 01 his changeof address, (4) Comply with any specifio requirement of release imposed by'the .Issuing autllOrity or Court, SUcll as a satisfactory participation III a deSignated program. (5) Obey such otrer conditions as the Court or Court Bc~,il/\';;J8ncy wittl leave of issuing authority or Court, may impose, If defendant performs thl3 conditions a:; set fortrl herein, tr,en this bond is ~o I:;e void, otherwise the same shall remain in full force and this bond in the full sum thereof shall be forfeited. Ilnd further, in accordance with law, we do hereby empower any attorney of any court of record within the Commonwealth of,Pennsylvania or elsewhere to appear for us at any time, and .with- or witb.oui declarations filed, and whether or not the said obligation be'in default, to-confess judgment against L;S, and in favor of the Commonwealth of Pennsylvania for use of the aforesaid County and Its assigns, as of any term or session of a court of record of the c~foresaid County for tile above sum and costs, with release of all errors, without stay of execution, and inquisition on and extension upon any levy or real estate is hereby waived. and condemnation agreed to, and the exemption (II personal property from levy and sale on any execution hereon is also hereby expressly waived, and no benefit of exemption is claimed under and by virtue of any exemption law now in force or which may be passed hereafter. f\nd for so d6ing this shall be sufficient warrant. A copy of this bond and warrant being filed in said action, it shall not be necessary to file the original as a warrant of attorney, any law or rule of the Court to the contrary, notwithstanding. . . . . . . 0 ~ ~ . . . ~ . ~ . . . . . t . . . . . JUSTIFICATiON OF SURETY OTHER THAN CASH BAiL (Questions 3, 4, 5, ;', 8 and 'jare applicable only when real estate is posted as security,) (Cash Bail justification shown on reverse.) The undersigned about to become Surety in the case ciled herein, being duly sworn (or affirmed) deposes and says' 1, I reside at ___~.____________...________"______________ my phone No, is and my occupation is aile: I work for ,,~_"_____.__~ 2. I have no undisposecJ of criminal cases against me pending in lhe Courts of '____________ County, except as follows: _____._.__"___~___~~____~___~ 3. U~: :~;:: :;:;~~~I~~(~~~~~r~~~;,retYi~-r-------------------'--~10 . . -- . In the. sa.ld County. of _. __._~___'.~'_".___' as follows, viz.. a parcel o~und, in ~ " ___ ___.._inthe____Ward,lllthe 0 Bora, D~, D cg~ which IS improved With the follOWing buildings_.___.,,_.___~___~_._.,__ (AN other joint tenants or tenants by the entirety must co.sign, this bond and siate their addresse~the batt-om of this page or on an attachment hereto) ~ 4. The said property was obtained by me by D Deed D Will from ,____. \::'....J 5 The [TDeed D VV~~ated-===::=:--------------;;.~;;-:;:r;'orded-;;;~he offi;;-e-;;;-;he ~;cor;~- of Deeds D Register of Wills of ___~_County, [J Deed 0 Will Book Vol._Page_, and the title isin n my name 0 and my spouse's name, Also a parcel of ground, in size ~_..._~____,__.__,~____._______, ~ituated at ,_____.__ in the Ward, in the [} Bora, 0 Twp, [J City of _...__________~__. . The said property was obtained by me by D Deed D Will from ~__._____..,______~__.__,___,__., The D Deed 0 Will is dated and is recorded in D Deed 0 Willl300k Vol. __ Page ____,01 ,._,___....<_,_~____..____ County, and is in D my name D and my spouse's name. 6. I am not Surely on any bond of any kind except as follows: DATE 7 There are no mortgages, or other liens or eilCUr";1brances of any kind ,)r description, upon the said premises, and there are no judgments against me except as follows: Mortgages as set forth in the Recorder of Deeds on first property _____,_.______ Mortgages as set forth in the Recorder of Deeds on second property _______ Judgments and Liens <____~____._,_._______~_"_~,_~____~_____,_~g_, Real estate taxes have been paid except: ~.______~_.,____._ 8 The assessed valuation of said premises is: ____.__..~_.__ 9. No judgment has been entered or action instituted against me upon a forfeited recognizance except AMOUNT 10. I have read carefully the foregoing affidavit and know th~t it is true and correct Sworn (affirmed) and subscribed before me this day of ~ 19___ (Clerk of Court or Issuing Aulharily) IlllltllJ~L_~ '"~ o' ~'_', .' N' " ',,~ '>."'~" "-' "-~"'.,~--,',. ',,_",'_'c' ,~ -,.',', '-<~--"~.',q ",~~ ,,' real estate situated , situated at C:3- DEFENDANT Pnn~ipal SEAL SEAL Surely (;a-surety, II any, co-joint tenanr or co-renanr by Ihe enlirety SEAL SEAL ., ,,-" , '.~," ~ "'- I" I. "1lli.!Oll,il,l-.i,-...: CERITFICATIOO OF PTh CCNJ:'I'MPT CASE M.foIBER 00-7077 NAME KEITH ALAN BLOSSER VICTIM'S NAME: 340 CREEK ROAD SHALON GHEEN BALANCE DUE: $ 103.10 CUMBERLAND CO PRISON 1101 CLAREMONT RD CARLisLE PA 17013 ADD DELETE SHERMANSDALE PA 17090 Now at 170 STATE SURCHARGE $ $ 171 STATE FINE $ $ 260 SHERIFF COST ($1. 50 + ADDTL) $ 32.60 $ 207 DISTRICT ATTORNEY $ 10.00 $ 204 COURT COSTS (CLERK OF COURTS) $ 15.00 $ 502 RESTITUTION NAME PROTHONOTARY $ 45.50 $ ADDRESS CITY STATE ZIP $ $ NAME ADDRESS 4" CITY STATE ZIP NAME $ $ ADDRESS CITY STATE ZIP PROTHONOTARY OFFICE 6r ~ A~' PERSON CERTIFYING INfORMATION ~ __~~______. DAT 11-(0- ~. ~. ~.~~~~, ~ -" ~~~ --j-11Ji...b SHALON GHEEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA V. : 00-7077 CNIL KEITH BLOSSER, Defendant : CHARGE: INDIRECT CRIMINAL CONTEMPT ORDER OF COURT AND NOW, this / i ~ay of FEBRUARY, 2002, the hearing in the above- captioned case previously scheduled by District Justice Helen Shullenberger, for February 19, 2002 in Courtroom #3, is rescheduled before the Court on the IDay of ~_, 2002 at 3: COo'clockj> .m. in Courtroom # 3 . The defendant, KEITH BLOSSER, is ordered to appear for trial on the charge of Indirect Criminal Contempt before the Court on that date. Jonathan R. Birbeck, Chief Deputy District Attorney top y O{J5 frl buJed DV D4; oP[;l.. KEITH BLOSSER ~ ."," ~ -'"~ ~ , - , ~ -, , Ti~ "IW"'''i._~l:MlIIl ""~ . ~ ~ i -"", ~- ,n("!,~" I UC 11. . P,"\ I: ::'j . " CU:v~t~ 'l~\.':',j,.,' '-:.'-.' Di=('1lf"It::Vi\!/:,(\11l', I :..,l~' ..."-,1,,,,, ., ,., , . ft-. \ \q > 1,1. '" \~i t \..~ ''(.,j -il..l' , " '''~~~ ~ ~ "\ ,j~ '~" ~ \ "'I. " , \ , \t a-a '~: /'. " :l. ~r." .;.; ioq ~ \o",_"r>'_ '! ._. '""r~"~~ '''~,,--''"'~ ',H' ~ '-'1'_ _.""'~ ,,,,~....,,,,Ji!IIi~!m~"')-f,1?'1;ie1i""'J'!#7:;,,,,~""7J;1-'--"';"!tl'1t1\l1;lWi>.<IR-T.;WL."WiI\t'ii,~~'f~~.h~~~~I'~!l'li-' - ~ -l~"- SHALON GHEEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA 00-7077 CIVIL TERM KEITH BLOSSER, 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 ofthis criminal complaint. 5. 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 in addition to any other sentence. 23 Pa.C.S.A. S 6113. WHEREFORE, the Commonwealth requests the defendant be appear before the Court on the charge of Indirect Criminal Contem , ,. ~'-_L#"~ " '-~... ,J ,- .'->.~, '~~ii~_', COMMONWEALTH OF PENNSYLVANIA . , COUNTY OF:CUMBERLAND ~iaII_ .~ POLICE CRIMINAL COMPLAINT Magisterial District Number. 09-2-01 District Justioo Name: Her.. PAULA P. CORREAL Address 1 COURTHOUSE SQUARE CARLISLE, PA17013 COMMONWEALTH OF PENNSYLVANIA VS. DEFENDANT: I NAME and ADDRESS. I Te',phone, (717)240-6564 . KEITH ALLAN BLOSSER 340 CREEK ROAD SHERMANSDALE, PA 17090 LJ717) 582-9084 ~ Docket No.: Date Filed: OTN: . Defendant's RliceJEthnicily Defendant's Sex Defendant's O.O.B. Defendant's Social Security Number Defendant's SID (Stale Identification Number) . o White Cl Black D Female o Asian 0 Native American 0_ 3/1172 162-68-5807 o Hispanic [l Uriknown Defendant's A.r-.A. (also known as) Defendant's Vehide Infonnalion Defendant's Driver's License Number . Plate Number I State I Registration SUcker (MMfYY) State I .. Complaint/Incident Number LiveScan Tracking Number Complaint/Incident Number if other Participants- UCRlNIBRS Code 02-0178 District Attorney's Office 0 Approved 0 Disapproved because: (The district attOrney may require,that the complaint, arrest warrant affidavit, or both be approved by the attorney for the Commonwealth prior to filing. Pa.R.Cr.P. 107.) (Name of Att~ for Comm~wealth-Please Print or Type) I, DETECTIVE KRISTIN D. MERTZ (Name of Aftlant-P1ease PrintorType) (Signature cf,Atlomey for Commonwealth) (Dale) 49-7 (Officer Badge Number/tO.) of CUMBERLAND COUNTY, CID (Identify Departmenl or Agency Represented and Political Subdivision) 49-7 PA021013A (Police Agency or ORf Number) (O~ginaling Agency Csse Number (OCA)) do hereby state: (check appropriate box) 1. [gJ 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 Shermansdale, PA 17090 (Place-Polilical Subdivision) in PERRY County on Dr about FEBRUARY 9, 2002, early morning hours Participants were: (if there were participants, place their names here, repeating the name of the above defendant) Keith Allan Blosser AOPC 412A - (8/00) 1-2 ,""" "" " ,1 ,- ~'" Docket Number: . '* POLICE CRIMINAL COMPLAINT Defendant's Name: Keith Allan Blosser . 2. The acls committed by the accused were: ~Se.t forth l! .summary of the facts sufficien.t to ad~se the d~ndant ?f the nature of ~he offense charged. A citation to the statute allegedly violated, without more, IS not suffic!ent. In a summary cas,s, you must C!te the specific section and subsection of the statute or ordinance allegedly violated.) ** INDIRECT CRIMINAL CONTEMPT - CSA 1990 . THE ACTOR DID VIOLATE THE PROTECTION FROM ABUSE ORDER NUMBER 00-7077 CIVIL TERM THE ORDER WAS SIGNED BY THE HONORABLE GEORGE E. HOFFER THE DEFENDANT WAS ORDERED NOT CONTACT THE VICTIM, SHALON GHEEN 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. 6114 of the Title 23 1 (Section) (Subsection) (F'AStatute) (counts) 2. of the (Section) (Subsection) (F'AStatute) (counts) 3. of the (Section) (Subsection) (pAStatute) (counts) 4. of the (Section) (Subsection) (PA Statute) (counts) 3. 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.) 4. 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 p nalties of Section 4904 of the Crimes Code (18 PA.C.S.g4904) r~ti'W 19 unsworn falsification to authorities. m () I j ,.:Jt:O:l, . (Date) AND NOW on this elate, , I certify that the complaint has been properly completed and verifieel. An affidavit of probable cause must be completed in order for a warrant to issue. . . (Magisterial District) AOPC 412B - (B/OO) (Issuing Authority) SEAL ,-, ~~ Ii )jj~, Docket Number: .. POLICE CRIMINAL COMPLAINT Defendant's Name: Keith Allan Blosser AFFIDAVIT of PROBABLE CAUSE The Victim Shalon Gheen, posses a valid Cumberland County Protectection from Abuse Order against the defendant, Keith Allan Blosser. . On February 13, 2002, this Detective met with the victim at Mid-Penn Legal Services. The victim stated that sometime between late on Friday night, February 8, 2002, to the early morning hours of Saturday, February 9, 2002 the defendant did repeatedly punch the victim about her head, sruck her in the nose using the heel of his hand and poured beer over head. As he was pouring the beer over her head she was being hit with top part of the bottle. While he was assaulting her Blosser threatened her saying, "You do some stupid shit. I don't know how else to make you understand. You need to learn how to be a good wife. One of these days I am afraid I'm gonna kill you." The victim is 5 months pregnant and lost consciousness during this incident. On February 9, 2002, throughout the day the victim had blurred vision, vomitted several times and was unable to stand up without feeling dizzy. The victim sustained bruising and soreness about her armS, and swelling and soreness about her hea~ and face from this incident. The victim pleaded with the defenant to call her an ambulance but he refused. The victim was able to seek medical treatment for her injuries at Carlisle Hospital on Sunday, February 10, 2002. I, Detective Kristin D. Mertz , 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. t,"'ot<(, If Jt1utiffl (J:i (Stgnatur Ian Sworn to me and subscribed before me this day of , District Justice My commission expires first Monday of January, SEAL AOPC412C-11/24/99 3-3 SHALON LEE GHEEN, Plaintiff : In the Court of Common Pleas of : CUMBERLAND County, . : PENNSYLVANIA v. : Civil Action - Law KEITH ALAN BLOSSER, Defendant ; No. 00- 70'77 : PROTECTION FROM ABUSE FINAL ORDER OF COURT Defendant's Name is: KEITH ALAN BLOSSER Defendant's Date of Birth is: March 1, 1972 Defendant's Social Security Number is: 162-68-5807 Name(s) of All protected persons, including Plaintiff and minor children: 1. SHALON LEE GHEEN Appearances by Parties and/or Counsel: ..,- . Plaintiff appeared personally and is represented by: Joan Carey, Legal. Services, Inc. . Defendant appeared personally and is unrepresented. AND NOW, this 18th Day of October, 2000 the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows: Upon agreement of the parties for the entry of a consent order, this order will be entered without any admission of liability by the defendant and without a finding of abuse by this court: Plaintiff's request for a fmaI protection order is granted. -......... , " ., 1. Defendant shall not abuse, slalk, harass, threaten the Plaintiff or any other prolected person in any place where they might be found. 2. Defendant is completely evicted and excluded from the residence at: 428 Steels town Road Newville, PA or any other residence where Plaintiff may live. Exclusive possession of the residence is granted to Plaintiff. Defendant shall have no right or privilege to enter or be present on the premises. . 3. 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 of this order. Plaintiff's current l'esideuce: 428 Steelstown Road Newville, PA Plaintiff's place of employment: SECCO llll Primrose Avenue Camp Hill, P A - Non-harassing phone contact by Defendant is not prohibited and will not be deemed a violation of this Order. .,- 4. The following additional relief is granted as authorized by !l6108 of the . Act: -Defendant is ordered to refrain from harassing Plaintiff's relatives. -Defendant is enjoined from damaging and/or destroying property owned solely by Plaintiff. -The court costs and fees are waived. '-', .."g, '" ~'.. 5. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: PENNSYL VANIA STATE POLICE - Plaintiffs residence LOWER ALLEN TOWNSHIP POLICE - Plaintiffs employment 6. THIS ORDER SUPERSEDES: 1. ANY PRIOR PFA ORDER 7. All provisions of this order shall expire on: April 18, 2002 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. g6114. 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. g2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY.'- VIOLATE THIS ORDER, YOU MAYBE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C gg2261- 2262. IF THE BRADY INDICAT6R 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. g922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION. NOTICE TO LAW ENFORCEMENT OFFICIALS The police who have jurisdiction over the plaintiff's residence OR any location where a violation of this order occurs OR where the defendant may be located, 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. g6113. " -, ' I-"~' -"~i~ - ~. ,I .djj!~ ., 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 ofilbuse. 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 for Irtdirect 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. BY THE COURT, resident Judge If entered pursuant to the consent of Plaintiff and Defendant: an Carey Attorney for Plaintiff Legal Services, Inc. S Irvine Row Carlisle, PA 17013 - .;=:;:. -:~- Keith Alan Blosser, Defendant Pro Be Distribution to: -Legal Services, Inc. -Fax and Mail PSP -Keith Alan Blosser Cumberland County Prison 1101 Claremont Drive Carlisle, PA 17013 -~~ ~ ., ' - .-, ~~; CERTIFICATICN OF pm CCNl'EMPI' CASE MMlER ou -7 u 71 NAME I{ ej-ft... A-u -e i'l "3 lo'S'5 'l'-f' 340 C-',t.4<. ((oCut 3h-e-r~ ih:tlL fA- nvto BALANCE DUE: $ 170 STATE SURCHARGE 171 STATE FINE 260 SHERIFF COST ($1.50 + ADDTL) 207 DISTRICT ATTORNEY 204 COURT COSTS (CLERK OF COURTS) 502 RESTITUTION NAME~!v"l~ ADDRESS CITY NAME ADDRESS CITY NAME ADDRESS CITY PROTHONOTARY OFFICE PERSON CERTIFYING INFORMATION VICTIM'S NAME: S hcuovt L~c b ~U"1 ADD DELETE $ J..C 60 $ $ $ $ 01__ ....._ $ $ 15.00 $ $ 15.00 $ $ $ STATE ZIP $ $ STATE ZIP $ $ STATE ZIP DATE M<~~G:t.: '~3Ni;-"r~"<( . "" _ _ k_ '-"-'"'~'~1" COMMONWEALTH V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA TERM & NO. 2000....7077 KEITH ALAN BLOSSER CHARGE: CASE TRANSFERRED FROM CIVIL DIVISION 000000000 OTN: AFFIANT: IN RE: RULE TO SHOW CAUSE ORDER OF COURT AND NOW, June 14, 2001, in consideration of the attached petition, the court issues a Rule to Show Cause on the defendant why he should not be adjudged in contempt of court for failing to pay the sums set forth in the petition. The Rule is returnable and the hearing shall be held on July 13, 2001 at 9:30 AM in Courtroom No.4, of the Cumberland County Courthouse, Carlisle, Pennsylvania. By the Court, ~C"> Fi~t ttJ., e5 /"TJ - ::0 rrl '- j;~':,~ .\\~ j'2('-" D"'"rl ~() c"C'l ~c::~: - ' -I"'" .:: .. Service of the petition to be made on the defendant Class Mail. /)./4 .;1>' .r::: f)~ C"!,'.e<;mg';1l'; ...j~l~ l!i,;~ ,rtM.iI>.'~~I'\liIJ_;Mjli!l>ttm1!ilIlffli~:4i;l~IlMW,~ii;g~~_","J!'~;';i1i1i\iiiwdil!li;~jl!i~-iii!- . .=-~, ..-," ~- ~Ili~~ -" ~,~~"-,~~ __7~ > ,~ ,__ () C- ;? "1J --CC ...._ 0:- t!Jr~,' I~~ ::<:: l.. p.~ -;.:--,-' 5f8 z ~ ",", .~--- --- <:;) C) -.-, , c: '--I,", '''- N c:.> --'-;IT) <'?SJ ,-. '"--' -.--Or, -;~~~ ;~- :;IT) :..~-i 5:1 -< O:~ ~ a .t::'o -1'1 ti , ~~ I' '11 :,! 'i Ii ii ~I " " t! I' .- ~. I' t: ~, '0' ~ '< , j 1irifI1f~~-_ . COMMONWEALTH V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KEITH ALAN BLOSSER TERM & NO. PROB. NO. CHARGE: 2000-57077 39478 CASE TRANSFERRED FROM CIVIL DIVISION 000000000 OTN: AFFIANT: IN RE: PETITION FOR RULE TO SHOW CAUSE WHY THE DEFENDANT SHOULD NOT BE HELD IN CONTEMPT OF COURT AND NOW, June 14, 2001, the Probation Office of Cumberland County, respectfully petitions Your Honorable Court to issue a Rule why the defendant should not be held in contempt of court. The defendant has failed to comply with the Court Order dated 10/26/2000. The defendant has failed to: 1. Report to the Probation Office in person at the time and date set by the Collections Officer. 2. Make regular payments on the fines, costs, and restitution as agreed. 3. Other: The defendant has agreed to pay $100.00 per month. Date last paid was 12/26/2000. The balance is $100.00. 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, ,,~~ Petitioner ," =" - "~ ~--j"M:lIi!lI~ V. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA 00-7077 CIVIL TERM I I SHALON GREEN KEITH ALAN BLOSSER IN RE: INDIRECT CRIMINAL CONTEMPT ORDER OF COURT AND NOW, December 20,2000, the above defendant is placed on parole, effective December 24,2000, at 9:00 a.m.; this parole to be with supervision.. By the Court, District Attorney Public Defender cep Victim Witness Probation Legal Services :ssg P.J. !.~ J;l-,;;2} -00 R.kS '",~".."c ~C-ri"' I I i F' ,rc, "", - ~ . '" ',' 'c', ""--,',-,,,- ,,-'* ',__, c",;.,.' ,k'''.c' C_..(""i" ,_;'"c_,,~,. ~~,_~'" r....'" ,__)~C. nn fjrr. r~. . '..n,; 1.'c.:_L t:! /IF; 0: ~ ? .of u.~ CUAiii~;EFr!j_"i\j;--~ t'r'" I.' r~ PENi\f8YLv/.\'KjjAGI~~! y , '~~_O__<"_~' ..~ """"'0-'-" i L eq, _Jf\'/1~'!l:f:l1~I;'U,'1I-'~P~~~1I!I_",," ~,__""~ -- , -----"-' I " ",,-,'- '" ~- '*ii' SHALON GHEEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V 00-7077 CIVIL KEITH BLOSSER, Defendant PROTECTION FROM ABUSE IN RE: INDIRECT CRIMINAL CONTEMPT ORDER OF COURT AND NOW, March 4, 2002, after hearing and consideration of the testimony presented, we do find that the evidence supports that the defendant did violate our order of October 18, 2000, and we do find the defendant to be in contempt of court for injuries he has inflicted upon the plaintiff. And further, sentence of the court is that the defendant pay any costs of prosecution associated with the filing of this contempt petition, and that he undergo imprisonment in the Cumberland County Prison for a period of not less than thirty days nor more than six months. We give the defendant credit for time served on this sentence from his incarceration on February 13, 2002. We will authorize the defendant's placement on the Work Release Program for the balance of this sentence if he can qualify for the program and arrange proper transportation. By the Court, ~:than R. Birbeck, Esquire Chief Deputy District Attorney ~~gory Cutler, Esquire For the Defendant P.J. > t~ 03 -It! -o!).. probation Office-HAI'-IIl-tllOuvcteD CCp. FI\"-' D ...., J Sheriff -r\""''O-\)S\..iV<:U", :mtf ,',,~ . ~ =<" .~~ ~ _~_, ," JljlP ,TI [ '''__""n' OF :!,,',.- O'? 1"I'r, 'I ',,- ~I .,:'l I ,; "', ~, "" ,0" ~ t';I:i iU: ?r! - ,- ~, CUMbth~..).',,; '1~"; ~-:w'l\ j:\I('',}! \ ,'J~ . C. '<I ;-Jt'..://-\ V:r\ '<<'.., ..,-' C'_._""', "j"..L" ,,"',^ ""=,,,,,,,.--,o,W '\;_-;-1__" !jJMMi~""""""",,_, 'Fe, rwr."jil1~'&<_@!t@;jR"j}!~~f~'li>ff_~~~Me~If:Wlll~I~ ,.. ',.' ~' '.;, , 'Hu SHALON GREEN v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : 00-7077 CIVIL TERM KEITH ALAN BLOSSER IN RE: PAROLE ORDER OF COURT AND NOW, March 14,2002, the above-named defendant is placed on parole, effective March 15, 2002, at 9:00 a.m.; parole to be with supervision on condition that the defendant be and remain on good behavior and comply with all directions of the probation office. By the Court, P.J. r15istrict Attorney ~blic Defender Probation.... HANb- ])euvlOl &b :'(~fJlo~ GCP - H:Al\lll- bBL! \Ie: Roe\) Victim Witness - \\AI\J\) -i)bLl vc t-e-ll ~eriff - \\Al..Jo-\:Jf;L-tVE:R.Ej) legal Services LCJP-J~{)) -fY) Q:3 D~ 03-/9 -0; l ~Xs = ~" .<' ., ,," "" u' , ''>'..' , ~ ~jU=[;--O!:FCE nc \./j D2 rU\R 19 10: n2 CUM2t>-(Lf-,:'j~J COUNT)i PENNSYLVNiif.l , ~_m , c' ',,,,~,, - ~ "--' ~<'-.. " "~-,~----,, ". "",' "~ , """"'~ "'.~ ~.~!Il~""'1._.___.."J.._,"-,~,ll!lJ&'!j1f"~!'f.ffl~~~. " -" ~" 6 " I;~~ i~ -..... .},. , < - _. I, ^ '-~' , ' .~ ~ii '. SHALON GHEEN, Plaintiff , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. 00-7077 CIVIL KEITH ALAN BLOSSER, Defendant CHARGE: INDIRECT CRIMINAL CONTEMPT IN RE: INDIRECT CRIMINAL CONTEMPT ORDER OF COURT AND NOW, October 26, 2000, after hearing and consideration of the testimony presented, we do make the Rule absolute and we do find the defendant to be in contempt of our order of October 18, 2000, by his actions of going to the victim's house on October 22, 2000. We also find that the defendant did violate the bail conditions set by the District Justice in his criminal assault case. A specific condition of bail is that the defendant have no contact with the victim, Shalon Gheen, or her family in any way whatsoever. Having found the defendant to be in contempt of the PFA order, sentence of the court is that the defendant pay any costs associated with the filing of the charge in this case and that he undergo imprisonment in the Cumberland County Prison for a period of not less than two months nor more than six months. We give him credit for two days previously served on the case. I will direct that the defendant may be placed on the , ,~. > do"~ I I I ! I' I ., , '.- I , " ii' .~ ~ .-=""'~ ~'o "J,~~ ~",,~.,.. 3_ " ' FlU:f}-CfFICE .'F c.,,,,', I~' I"T' RY ell'.' :~'-':__.';:'))I'Aj,P,r 00 NO'.l-1 JU1 9: 53 CUMBEfili\;~O COUt\'TY PENNSYLVANIA , , . ,,',"". ";J._'" -~ . ~'.-,. "'~.." <"","", . ,..<,.. "--,~. ~" '~~,"",', ""'c, ,_' ,,_~ ~~~__,"!!"""",__ _ .",.."",~~_~r_=~'_ m~il't_!'l~,~Jr:~~rillllml!~.,_ ~- ,. . ~ . 1-'- . ... ... . . -I, . -_ ' 'f,~,'.1 C' . _ _ ',,~ ~_ " 00-7077 Civil In Re: Indirect Criminal Contempt Page 2 Work Release Program on the PFA order, provided that space and transportation can be arranged. In regard to the PFA order, the Court strikes the last sentence of paragraph 3 in the order which allows phone contact; defendant is prohibited from any phone contact with victim. By the Court, Jonathan R. Birbeck, Esquire Chief Deputy District Attorney ~~ ~t tit -::; ~ 0 ~'<. q, D '0> ~'_\ f>) '"~ ArIa M. Waller, Esquire Assistant Public Defender Probation Office Sheriff CCP Legal Aid Victim-Witness :mtf '" " ~,.' Ii ,. " " " I! il I il [I [I .. fA ~ .. r " ',,'. ,'~" - _,__,C. ",,--"- ,,"", ~ - j':\LfD",Of:f\Cr. at: ,.,.-, <I'" -""'i"t" I"'d.,tl~" RY \ 1 ;~:r-. t~'",/- n\_Y'U ir~l 00 NO\! - \ !'-Iii 9: 53 CUMBf:;RLA,\jD COUI'lTY PENNSYLVANiA ,"""'~ l!l1!1f, ,~_ .C', "''j'',~;''r'" " 0.-' " _. "'_0' _~"4' , _"J""", ',' ~ _"~pm~~. _', ;@J! . "'1 /~~~~~ _ ~~,...,..!.,,,.,,,.,,Uf.".> !!ffi 11/01/~0 WED 13:22 FAX 717 240 6573 CUMB CO PROTHONOTARY 141001 . . 00 -7(J7) ~. -c.," TRANSMISSION OK TXlRX NO CONNECTION TEL CONNECTION ID ST. TIME USAGE T PGS. RESULT ********************* *** TX REPORT *** ********************* 2254 92490779 PSP 11/01 13:20 01'23 3 OK - L , '~, . . -, SHALON LEE GHEEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. KEITH ALAN BLOSSER Defendant NO. 00-7077 CIVIL TERM PROTECTION FROM ABUSE IN RE: SENTENCE (INDIRECT CRIMINAL CONTEMPT) ORDER OF COURT AND NOW, this 5th day of February, 2002, having found the defendant committed the act and is in contempt of the order, at the recommendation of the District Attorney for a very minimal sentence in the case, sentence of the Court is that the defendant pay any costs associated with the filing of this petition and that he undergo imprisonment in Cumberland County Prison for a period of not than 24 hours, nor more than 6 months. We give the defendant credit for 24 hours served in this case, we now place him on parole without supervision for the balance of the unexpired term on the condition that he abide by the protective order currently in effect in this case, which prohibits him from having any personal contact with the victim. BY THE COURT, Daniel J. Sodus, Esquire Senior Assistant District Attorney ArIa M. Waller, Esquire Assistant Public Defender pcb ~ -' .~. ~ .- . F .1" ,', \~I:)Tl\!lY Co,'? (:'cn t ".~ O."~: 01_, Ll.' ,)(.,..., L"" 1,-, ... ell- ',.,. . . ....... ""-'.I"TV l ",'I _,.!",I.,! 1, ,I'" \ l ,) i~-l I JI'.1l1.~,,"': 1'-0 ,,'<I_ \"h...-....,' P[NNSY\.~li\N1A .", _'__~"c. "~ _,' _ .- . _~_'." ~~ -""IIl.__WI, m",rr~_,llil!!~_~....\_ll\lt~_""",. -"""-'''-'~ ,~ __"""'N"~"" ! ~ ~ ~~l .-1S ~ \J' 4~ ~ .J!IIMI$~ll~,)r.,7; . II _~" -"r." ~""" ",-~lf:It!! -,,' . .... SHALON LEE GHEEN, Plaintiff aQ IN J 7fY<C. : In the Court of Common Pleas of : CUMBERLAND County, : PENNSYL VANIA v. : Civil Action - Law : No. 00-7077 KEITH ALAN BLOSSER, Defendant : PROTECTION FROM ABUSE EXTENDED FINAL ORDER ~~ AND NOW, this Day of March, 2002, pursuant to 23 Pa.C.S. 96101 et seq., upon consideration of Plaintiff's attach a Petition for Extension of Final Order of Court the Final Order entered on 18th Day of October, 2000, in the above-captioned case is hereby extended until September 4, 2003. The above-captioned Final Order of Court entered on October 18,2000, is extended and shall remain in full force and effect with the following modifications: Paragraph 3 of the Order is modified to allow contact between the parties after Plaintiff gives birth to her child, for the limited purpose of communicating custody-related information. Under Paragraph 4, referencing additional relief, Defendant is ordered to attend and successfully complete one of the 26-week batterer's programs listed below, and, in addition, follow and complete any related recommendations for ongoing treatment made by the program staff. Defendant shall be [mancially responsible for any costs related to enrolling and attending the program and any additional costs for ongoing treatment recommended by staff. Defendant shall contact a batterer's program within 7 days of the entry of this Order and schedule an intake appointment. CHOICES Tressler Counseling Services 940 Century Drive, Mechanicsburg, P A 17055 (717) 795-0330 MOSAIC Partnership Counseling Services 2001 North Front Street, Harrisburg, PA 17101 . , ), . ~, , , ,- ;- - - , ,-' , ,-",~,,,,'",:i ,. . . (717) 234-6438 NOVIS P.O. Box 4681 Gettysburg, PA 17325 1-800-736-1477 Defendant shall advise his attorney in this case which program he enrolls in, and Defendant's attorney shall provide this infonnation to MidPenn Legal Services. resident Judge Distribution To: ~ David A. Lopez, Attorney for Plaintiff t IKfJ~S -3 - 0 'I Gregory A. Cutler, Attorney for Defendant ~ .~ J.I '-01 Jonathan Birbeck, Chief Deputy District Attorney Pennsylvania State Police, Carlisle Pennsylvania State Police, Newport Mechanicsburg Police Department Cumberland County Victim Services Domestic Violence Services of CumberlandlPerry Counties FAXed & mailed to Pennsylvania State Police - MPI- f.J- (!_ p. - 30bt .6.v :: , " ~ I: I: I' ~ ~ i tl I'" ." ~--"", ~-~ ^,' "-, - ~ " -~- T ,~"< . ~ "" r:1 I ' DroJh cno!-or)' I' n I~O( In I~! !Ylc/rch II ,;)(KJ2. .. c .tl,~J!illW _,:r,',Jl!'j~'''''._WlIII!llIillI.!Jllrl.fJ_~~I!'P!i~l!I~l~f-!!' ~-"""'" ,.~rr,~wr; i7~,_=""""",.".....,~,lflij!~~ ,'J.;,...,.... ,,~ ..~~ '- -~.~-' I---~'"""""""--, 03/08/02 FRI 12:05 FAX 717 240 6573 CUMS CO PROTHONOTARY 141001 < *************************** *** MULTI TN REPORT *** *************************** . . TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 3006 [ 01l9p2490779 [ 0319p2405331 [ 04]92438026 PSP CP LS ERROR , , OfFICE OF THE PRatH(:t.IQTARY CUMBERLAND CXXJ!ITI"f lXll.1fm-lOOSE ONE COO1l'IlIOOSE SQUME CARLISLE. PA. 170131-3387 (717) 240-6195- FAX [717) 240-65?3 , V I ATE LEe 0 PIE R TO: PA STATE POLICE . eC..fR.41 fJ"',e ,ss:. 1I'I.A I..:. FAX H: 717-249-0779 .- , ~: CU~TIS R. LONG RE: PFA ORDERS /! (J/ MESSAGE: : 3. 00. OF PAGES (INCWDING <XlVER SHEET) . Th:is ~ is i...tet.hl cnly fir tte \.EEl of tte irdivid:Bl a: 61tit;Y tp Wlidl is is ~]l. _ ..-on:J, cn::I /T6'f a:ntain lnfi::matjm ttet is p::iviJB;J;d. o:nfitB1t:ial. erd ea;npt fron ,H<rl""'JIB lJ1i:!r "11:'1 ;,-......1" laN. [f tl-e trei;r of lt1is - ~ is rot I:I-e inteT.le:l rrc:ipiEnt. ~ .;n:e ~ rotififd ttBt ifl/ difS'jnireilin, dis1:dl:ut::iro cc lLP.firg af this <:o'lTI1-llirntirn is sttictly p:"d1ib.i1;e:l. If}Ol teve L'ElEi~ !tus aJllIlJ\i(atkn ;it; =, pla'se rctify lS itmaiiately ty t:eleJ;h~re en! reWm !te a:igiral " "'T lP \p "l - . ... -~." 03/11/02 MON 13:02 FAX 717 240 6573 '"" - ~" ~ " ~--~"' ~~~"",",.lo-"",,,iIl<;4,I"" CUMB CO PROTHONOTARY 141001 . . *************************** *** MULTI TN REPORT *** *************************** .. ' " TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 3011 ERROR [ 0119p2490779 [ 0319p2405331 [ 04]92438026 PSP CP LS OfFICE OF THE PRarHCX'DI'I\RY CUMBERLAND COONfY COURTHCUSE ONE CXXJRTI!CUSE SQUARE CARLISLE. PA. 17013-3387 (7ln 240-6195 FAX (717) 240-6573 V I ATE L € COP I E R TO: PA STATE POLICE . (!eiVTA,,/ t1t,rc S$.. ."",.,.. - P. S. P .- y l"l\)( N: 717-249-0779 RE: PFA ORDERS f!).fioV ~~ F'RO-1 : CURTIS R. LONG MtSSAGE: .j/ 1..........- ~_ OF PAGES (IN'.::UJDING COVER SHEET) '!his ~ is in\J.":rd:d ~ fir tte lEe of I;te irrlivid.a1. cr Entity II) mien is is dlb...-.d. .nl rmy o::ntain infooratirn ttat is p:iv:iJa;Jd, o:nf'id3'ltial an ~ fmn O;9"'l""l!e m:Er ;r,p.';,..,nl~ J.a.,>. rf tie J:re"k of this lle3S<g'! is rot tiE inlElU3:l rocipimt, )OJ are ~ mtif:i.e:l ttHt <fl;{ <:Jis<;<';TlirebOl. dlstrilutirn OL awin;I cC this o::rmt.nicaticn is strictly p:dtibita:l. If}OJ t6\.e nrei\<rl ttus ......... n;_ >';rn in Pnn'". nla!l;e rot:ifY LG imra:I.iilta1.y 1::1{ t;elE~:tH-e .;rd lBtlltn l;Ie a::ig:iral ~ to LG ill . '~.: ' .J,_ - ,,(ltUI . " . . i ).. SHALON LEE GHEEN, Plaintiff : In the Court of Common Pleas of : CUMBERLAND County, : PENNSYLVANIA v. : Civil Action - Law KEITH ALAN BLOSSER, Defendant ; No. 00- 7(/77 : PROTECTION FROM ABUSE FINAL ORDER OF COURT Defendant's Name is: KEITH ALAN BLOSSER Defendant's Date of Birth is: March 1, 1972 Defendant's Social Security Number is: 162-68-5807 Name(s) of All protected persons, including Plaintiff and minor children: 1. SHALON LEE GHEEN Appearances by Parties and/or Counsel: . Plaintiff appeared personally and is represented by: Joan Carey, Legal Services, Inc. . Defendant appeared personally and is unrepresented. AND NOW, this 18th Day .of October, 2000 the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows: Upon agreement of the parties for the entry of a consent order, this order will be entered without any admission of liability by the defendant and without a finding of abuse by this court: Plaintiff's request for a fmal protection order is granted. ~ It " <"'\ <l' ~ It l"' "I 0-- ~ 'l Lo-j ~ ~ '-7 --{ '~ 1 j I Ii II Ii Ii Ii i1 " 'i I: I' ,I I I ~ Ie i~ F: II' I' !: i: I L II 1'1' I: ~-- ~ , ,,-,. - .," -" '~~." ~ .' .' -. ~,. ~"'"" . ~ <t " '1 (J- ") ~ ~ ~ , ," ,-"=" . ~ o' _." -, "J-,.;:~> I';p or.-r t..!l.) J!.,. i 9 D;'i.~ "I j : ! ~ C'II"..' I~VI:iI:F:. .'.'."1', ,".', , '''H'-N'-'t" 'I,) < ~ " J'\l'rl h:: INSYLV(~,:,~~r~~--; ~ I 1 l Y. . '""""""""""f1'r""'--'" ~ ~. ~~II!III.~~, _~~~ ~~111 ',,-0, c; .~ ---< '~ 1'1 (} ,1IIIl " . ~, - ~'~""l . '. . i/~ 1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other protected person in any place where they might be found. 2. Defendant is completely evicted and excluded from the residence at: 428 Steels town Road Newville, P A or any other residence where Plaintiff may live. Exclusive possession of the residence is granted to Plaintiff. Defendant shall have no right or privilege to enter or be present on the premises. 3. 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 of this order. Plaintiffs current residence: 428 Steelstown Road Newville, PA Plaintiffs place of employment: SECCO 1111 Primrose Avenue Camp Hill, P A - Non-harassing phone contact by Defendant is not prohibited and will not be deemed a violation of this Order. 4. The following additional relief is granted as authorized by S6108 of the Act: -Defendant is ordered to refrain from harassing Plaintiff's relatives. -Defendant is enjoined from damaging and/or destroying property owned solely by Plaintiff. -The court costs and fees are waived. , -,-", '~ - ... , . '. . 5, A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: PENNSYLVANIA STATE POLICE - Plaintiffs residence LOWER ALLEN TOWNSHIP POLICE - Plaintiffs employment 6. THIS ORDER SUPERSEDES: 1. ANY PRIOR PF A ORDER 7, All provisions of this order shall expire on: April1S, 2002 NOTICE TOTHE 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 P A.C.S. 96114. VIOLA TION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENAL TIES 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. 92265. 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 992261- 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. 9922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION. NOTICE TO LAW ENFORCEMENT OFFICIALS The police who have jurisdiction over the plaintiffs residence OR any location where a violation ofthis order occurs OR where the defendant may be located, shall enforce this order. An arrest for violation of Paragraphs I 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. 96113. ~- J"ir.~i.i-i~'&,; ~ "'0 _JJ 'I I . ' ...,i;lL-.,,,,Ib,,;-iA'- .. ~ . ,- J.. '. , ..._, 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 ofthis order, the defendant shall be taken to the appropriate authority or authorities before whom defendant is to be arraigned. A "Complaint for 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. BY THE COURT, resident Judge If entered pursuant to the consent of plaintiff and Defendant: :-:;;;.- --: 0-. Keith Alan Blosser, Defendant Pro Se Distribution to: Joan Carey Attorney for Plaintiff Legal Services, Inc. S Irvine Row Carlisle, PA 17013 -Legal Services, Inc. -Fax and Mail PSP -Keith Alan Blosser Cumberland County Prison 1101 Claremont Drive Carlisle, PA 17013 ".1 ! ': ' ~~" . 'laW_,~,'" 10/19/00 .:mu 09:27 FAX 717 240 6573 . ~ . " CUMB CO PROTHONOTARY ..... '.. ~001 '. ************************$** *** MULTI TN REPORT **~ *************************** . .- . , TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 222B [ 01]9p2405331 [ 0319p243B026 [ 04192490779 CENTRAL PROCESS LEGAL SERVICES PSP ERROR . OFITCE OF THE PROI'HCNITAR'i aJMBERLAND CXXJNT'i CXlUR1ll00sE ONE COORTHOOSE SQUAAE CARLISLE, PA. 17013-3387 (717) 240-6195 TO: C:..,+n:J PfllWS\1'\1 Lecgo.l ~J:CL~ PA STATE POLICE FAX (717) 240-6573 VIA TELECOPIER FAX H: 717-249-0779 -) FRCM: CURTIS R. LONG RE: PFA ORDERS MESSAGE: --1~ NO. OF PAGES (INCWDING COVER SHEET) This ~ is intad3:i cnly fir tte LSe of tte irrlivid.al cr. ati~ to Wlid1 is is a.Th i, 1fl1 !TB'f 001ta1n infumet:im ttBt is p:iviJa;Jrl, a:nf:id3ltial ad e<arp;: fu;m d;....l..... ~ mler "U'1 i,,*,lp J.a.1. If t1-e ree1a' of tI1is" :J' is rot tl-e int:mB:1 ra:.:ipigrt:, ~ are t'eI:eby rotifiErl tlBt i'nf dissEm:in3bm. dist:rihJt:irn or a::p{irg of ttris amnnicatim i8 strictly {Zdtibitm. If ~ teI.e re:ei\6i tfus mnnnir..Hrn in PTTV'lr. n1A'R'! rnt-ifv ill jmredjal:2lv l:w tela::h:re ad teWm tie a:icriral ~ to I.S at ~, " -,\ '. '- SHALON LEE GHEEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. KEITH ALLEN BLOSSER, Defendant : NO. OO~ 7D'1'T CIVIL TERM : 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 particulat, you may be evicted from your residence and lose other important rights. A hearing on this matter is scheduled on the ~ day of Qctober, 2000, at r' [) 6 }') .m., in Courtroom N~, 4th Floor, Cumberland County Courthouse, 1 Courthouse Square, Cakisle, 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 injail 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. . '"- - -~" ,~ ~- "'-' "'''0 ~ ,,-,-". ,."",&'," ".,,'_," ,." '_'="'-""," ",n,.!. _'-0" -','."'Z.\-I"1 ';:'" r~ \,,)1 FiLED--C~F!Cf: ';-1 "~- ::"";'~'yn<);-"JCyr,t.Hl' 00 OCT 13 PH 3: 05 CUMf3EHL/-,:\D CDUNTy PENNSYl.VN~IA . 1~ ~. _..,.,-~~, ~~~~ ", !'iJ!IlIllllliiH:I,l~!I!i.j!;!iUi'1_;!J\jffi;::I,i\1::, ....~!M1mr~~--)!<~""'-p;m,~~~""~''"'l'.JiiXJ%'Jti'fi'<'i9,lj,''f:jl:-''''''~\~i!~'" If .,~n-~~~~ '. SHALON LEE GHEEN, Plaintiff : In the Court of Common Pleas of : CUMBERLAND County, : PENNSYL VANIA v. : Civil Action - Law KEITH ALLEN BLOSSER, Defendant ; No. 00- 7077 ~ -r b- : PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: KEITH ALLEN BLOSSER Defendant's Date of Birth is: March 1, 1972 Defendant's Social Security Number is: 162-68-5807 Name(s) of All protected persons, including Plaintiff and minor children: I. SHALON LEE GHEEN AND NOW, on 13th Day of October, 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. '"" ,1-" 2. Defendant shall be evicted and excluded from the residence at: 428 Steelstown Road Newville, P A or any other permanent or temporary residence where Plaintiff may live. Plaintiff is granted exclusive possession of the residence. Defendant shall have no right or privilege to enter or be present on the premises. 3. Defendant is prohibited from having ANY CONTACT with Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at 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. Plaintiff's current residence: 428 SteeIstown Road Newville, P A Plaintiff's place of employment: SECCO 1111 Primrose Avenue Camp Hill, PA 4. Defendant shall not contact Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 5. 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. Defendant is enjoined from damaging and/or destroying property owned solely by Plaintiff. 6. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: PENNSYLVANIA STATE POLICE - Plaintiff's residence LOWER ALLEN TOWNSHIP POLICE - Plaintiff's employment ,~ . . nH .'. ~!. ~, TR 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. TillS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL APRIL 13,2002 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY TillS 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. ~6114. Consent of the PIaintiffto 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. ~6113. Defendant is further notified that violation of this Order may subject himlher to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. ~~2261- 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 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. Distribution to: Joan Carey, Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 FAXed & Mailed to PSP (ib ~ Judge - .;D' -'. ,', PF AD Number: QQ 1143984C SHALON LEE GHEEN, Plaintiff : In the Court of Common Pleas of : CUMBERLAND County, : PENNSYLVANIA v. : Civil Action - Law : No. 00- 1077 KEITH ALLEN BLOSSER, Defendant : PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE 1. Plaintiff's name is: SHALON LEE GHEEN 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. SHALON LEE GHEEN 4. Plaintiff's Address is: 428 Steelstown Road, Newville, PA 17241 5. Defendant's Name is: KEITH ALLEN BLOSS'E'R. 6. Defendant is believed to live at the fono~ address: 340 Creek Road, Sherlbes Dale, P ~ 17(,\110 7. Defendant's Social Security Number is: 162-68-5807 8. Defendant's Date of Birth is: March 1, 1972 9. Defendant's Place of employment is: Motter's Silo, 408 Kerrsville Road, Carlisle, PA 10. Defendant is an adult. 11. 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 facts of the most recent incident of abuse are as follows: On about Saturday, October 07, 2000 location: 428 Steelstowu Road, Newville, PA On or about October 7, 2000, Defendant came to Plaintiff's residence and when she refused to let him in and told him that she was going to caD the police, he threatened that she had better watch her back beeause he was going to smash her head in with a basebaU bat. 14. 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 27,2000, Defendant yeUed at Plaintiff, called her vile names, hit her in the face, grabbed her by the hair, repeatedly slammed her head against the waD, grabbed her by the arms, shoved her abont, and kicked her in the legs and genitals with his steel-toed boots. Plaintiff left the residence and telephoned 911 for help~ The Pennsylvania State Police responded, arrested Defendant, and charged him with harassment, simple assault, and driving while "lB ..- ." ."-'"il'lIr.tlll_il~ operating privilege is suspended or revoked. Defendant made bail at the time of his arraignment, and a condition of his bail prohibits him from having any contact with Plaintiff. A preliminary hearing on the criminal charges is scheduled before District Justice Shulenberger on November 9, 2000, at 9:30 a.m. Plaintiff sustained soreness and swelling about her head, bruising and soreness about her arms, shoulder, and legs, and a laceration on her shin. On or about September 26, 2000, Defendant grabbed Plaintiff by the arms, shoved her about, and.kicked her on the leg with his steel-toed boots. PlaintitTsustained bruising and soreness about her arms and leg, in addition to swelling about the calf of her leg. In or about early August 2000, using the heel of his hand in an upward motion, Defendant struck Plaintiff under the nose. The force of the blow caused Plaintiff to become disoriented and nearly lose consciousness. Plaintiff sustained soreness and swelling about her face, a laceration 011, her lip, and headaches as a result of the incident. Since this incident, Plaintiff has experienced headaches, pain about her nose, eye socket, and jaw, and ringing in her ear. In or about late July 2000, Defendant grabbed! Plaintiff by the hair and repeatedly slammed her head against the hood of a vehicle. Since approximately July 2000, Defendant has abused Plaintiff in ways including, but not limited to, shoving, slapping, punching, and kicking her; grabbing her by the arms and hair and slamming her against walls and the floor; grabbing her by the neck and picking her up off ofthe floor, and holding her by her hair and repeatedly punching her about her head. Defendant has made threats including the following to PlaintitT saying, "One of these days I'm gonna fucking kill you" and "Jfyou ever call the police on me, I'll make sure you lose your son." Defendant threatened Plaintiff indirecdy and intimidated her when he told her that a man who "ripped him off" was found in a gutter, his head smashed in with a metal pipe, and that Defendant was not a suspect since he was not near the crime scene and could not be found. 15. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: PENNSYLVANIA STATE POLICE - Plaintiff's residence LOWER ALLEN TOWNSHIP POLICE - Plaintiff's employment 16. There is an immediate and present danger offurther abuse from the Defendant. 17. Plaintiff is asking the court to evict and exclude the Defendant from the following residence: J" "'J ~- -~1' .' 428 Steel$town Road Newville, PA Rented By:Shalon Gheen & Keith Blosser 18. Plaintiff has suffered out-of-pocket financial losses as a result of the abuse described above. Those losses are: any and all medical expenses incurred by Plaintiff for treatment of injuries she received as a result of the incidents which occured on or about September 27, 2000, and in or about late Augnst 2000, and for lost wages. 19. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WORD DO THE FOLLOWING: a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or minor child/ren in any place where Plaintiff may be found. b. Evict/exclude Defendant from Plaintiffs residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff. c. Prohibit Defendant from having any contact with Plaintiff and/or minor child/ren, either in person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Plaintiff's school, business, or place of employment, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/ren. d. Prohibit Defendant from having any contact with Plaintiff's relatives and Plaintiff's children listed in this petition, except as the court may find neCessary with respect to partial custody and/or visitation with the minor child/ren. e. 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. ',1l1ll~1""'" 0;.' "~ 11IM~lil~~ 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 property owned solely by Plaintiff. Ordering Defendant to pay $250.00 to a funding source of Legal Services, Inc. as reimbursement toward the cost of litigating 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 Defendant can be served. Respectfully submitted, / ~,~ LEGAL SERVICES, IN . 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 , -'-"-~"~ -. '. '. 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.~904, relating to unsworn falsification to authorities. Dated: f-ti?-t7CJ lI5~~i<~II1"~~,""M~!j%Jwa/R.~~Im!!-~a;0;'j",n!d.k;'_"'~~O@:;'H";;"llFi~1i:;;;,r'I.h;<Iil;;~".~ -'laSTlIi ~!l'l lli~JJi!lj~~.MiJlil!iililIf" ~ ~ '. " .~ 0 C:r'". , 0 c: ~=:;. --'-1 ~~ .:::J :::.3 u ....,.., n n-, ,-4 ,"i ;2 '''' ;< j~ m (Ii :> G:.I D ~ (~) r:= ~<:. ~ , / ;:--1 .,.l- , C: c: , ~ , '. ,-n .;.---- c "<~ , ~c?' ~ _"~Ow =2 (J1 ::';1 .< \ 1 \ r r ~ n '- x -=Q f\ ~ <:> 4- of. - +- l> ~ ~ ..;, 0 I , (J <:> r -. C- ~ - VI :v ft. ~S r '-0 ~ 2- .c ,-{; Y1 -:J -l-. , . ~ ~ C) '- ~ -.. .....c: <: .' i ~, ~ .,~". . n. ,~"~ _'.'-' " .,'r~-~ - ,,, ,~ - " ,J__''','_' ,"'" ,. " ,.,-, ' ,-,'" F , -"~ ~ .. " ""~ ~, "~~-> "" ,'~ ~~- "."~i:ij;,,,,~,t, 10/13/00 FRI 15:01 FAX 717 240 6573 "'~r . CliMB CO PROTHONOTARY 141001 *************************** *** MULTI TN REPORT *** *************************** TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2221 ERROR [ 0119p2405331 [ 0319p2438026 [ 04192490779 CENTRAL PROCESS LEGAL SERVICES PSP , OFFICE OF 'IllE PRO'IllCNJ'l'ARY CUMBERLAND COJNIY COUR'IHCXJSE ONE roJlmlCXJSE SQUARE CARL!SLE, PA. 17013-3387 (717) 240-6195 FAX (717) 240-6573 LS cent. PtOCef,.5. TO: PA STATE POLICE VIA TELECOP!ER FAX n: 717-249-0779 .'-1 FROM: CURTIS R. LONG RE: PFA ORDERS MESSAGE : It> 00. OF PAGES (!NCLUDING COVER SHEET) , This ~ is iJ,t.;,&.1 cnly fer lte Ul!) of lte irdivid..al or. 61tiW In Wrid'l is is cdh. :: I, cnllmj a:ntain infur:rratim ttat is p::i.vi.l.eg:rl, anfid61tial arl e<BlpI: fmn <ii<r1rR'"i! urler "ff'Hr-;hlp Lsw. If tIe re:mr- of this II ~ is rot: tie intarlrl m:::ipisnt, }oQJ are t"eI:tbt rot:ified tret mj clisEsni.n3t::ia1. dist::ril:llt'..m OJ:" awirg of this arnnnica'"jm is strictly p:d1ibitEd. If}oQJ l"BIoe recei'-'3J ttus --,- "'-'m ,~~ ....1""""" mt-ifV IE imraiiatelv b{ tE1a::h:re cnl reb.Jm tie od.girelll Tf' In 1..6 at