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Home My WebLink About00-07401 . . Tamara Ann Pantaloni Plaintiff v. Nicholas Edward Pantaloni Defendant " 'y : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYL VANIA . : No. 00-7401 : CIVIL ACTION - LAW : PROTECTION FROM ABUSE ANDNOW.tm:ZO:~~2:1V ACATE 1. This matter is dismissed without prejudice. 2. Costs of this proceeding are waived. 3. The Temporary Order (Filed on Oct 20, 2000) is hereby vacated. Distribution to: MIDPENN LEGAL SERVICES Faxed & Mailed to PSP Richard Wagner, Attorney for Defendant 2233 North Front Street Harrisburg, P A 1711 0 BY THE COURT; Date .~ sf' ,t)' C/O~~:~ '~lll'<I1l!i<~lliM>iIiMlMJill'- ",,, ."k".Cl;,:JJ,d. ~U!.!h~1Jt.'fn~1i~ - - - ~!:!iiL"""'-":'!c"f*_\;l~"'M-i;:*ij;bf,1<"t"~,\'i'~ ~~~ ~" mil'~'~-"''''-''''~~j:@@![ 2:," .... ~, ~ ",., ,,'_'_,^.~,__ "00, .__-~,'~." .,,_ _.,~" ~f VlNVAlASNN3d JJ.Nnoo Of<ffJI:i38itfl:) ~ I :e I<Id ZZ N'Vr 10 IW'O"'.'Hl.". "I' JO I'\OVJ.\. f'f!..J! ,Uc)d :;1-1 -i :JOi:J:iO-G::JlH "",- ." .,",-- ~~c_ _~ ~""'.'Uis. . - ~, '1':. . .-- . .;1 -",,""_ ~,0, ~nf1M~i@:,- TAMARA PANT ALONI, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 2000-7401 CIVIL TERM NICHOLAS PANTALONI, DEFENDANT : PROTECTION FROM ABUSE AND CUSTODY PETITION TO V ACA TE ORDER AND WITHDRAW ACTION Plaintiff, TamaraPantaloni, by and through her attorney, Joan Carey, of Legal Services, Inc., requests that the Court vacate the Temporary Protection Order in the above-captioned case and that the action be withdrawn on the grounds that: I. A Petition for Protection From Abuse was filed and a Temporary Protection From Abuse Order was issued by this Court on October 20, 2000. 2. Defendant was served with the Temporary Protection Order on October 23, 2000, at 20 Carlisle Road, Newville, Pennsylvania. 3. Plaintiff and Defendant are attempting a reconciliation. 4. Plaintiff requests that the Temporary Protection Order be vacated and the action withdrawn without prejudice to her. WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate the Order, and that the action be withdrawn without prejudice to Plaintiff. oan Carey Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 """. '. L ~"'<jJ .. .=~_ I..... '''~'t~.JI!"' r:-\"~ ~",_"d:_~,~~, VERIFICATION I verify that I am the Plaintiff as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. Dated: ~1J.J'ft 13, ,2rol ~~!Jrll Tamara Pantaloni, Plaintiff ~i!JIl~~milOOllt:'~Ji!Jli"" ,'H"'''',_'''-''"'''_',4i''....'''~''~'~'''M'~,,4\~'_'1"1$Pi1''''; '>1Ji.;~:;:i:Hi";" ,"lk"",'j,;j,),<t,J&i"~;rr ~ ',. ."" ""''-.",~ .~ ~".,~ _~'=."'_, '_"_d_ C'. ,_,,~ "",' ".,.;."~O~ __" 1MJli~~~~.'lll<!!OliI..~i!f[;)~$M*(j!'iAilHil; 1ll!RIlIiU -.j , I ,I d :1 , (") 0> C.. -' ~ -;-1 '- ...... !CP :P> r~::n =~ ::z: ' ,- - -O,rr:- '~Cl \D '~~"'6 ~CJ "'"' ~,;1 "'T', -j-::n ~2 :x C,O - --,. 0...11 .. " ~. -.I ~ ',". I , -, ,,~~ ,-' 01/23/01 ..- ':'- TOE 10:28 FAX 717 240 6573 *******$******************* *** MULTI TN REPORT **~ *************************** CUMB CO PRO:m:ONOTARY # . IiiJQ01 TXlRX NO INCOMPLETE TX/RX TRA.1I/SACTION OK 2412 ERROR [ 0119p2405331 [ 0319p2438026 [ 04]92490779 CENTRAL PROCESS LEGAL SERVICES PSP . OrPICE Of THE PROTHOOOTARY CUMBERLAND COONT'l COURTIiUlSE ONE: CXX1RTHCUSE SQUARE CARLISLE, PA. 17013-3387 (717) 240-6195 FAX (717) 240-6573 VIA TELECOPIER c.-P- TO: PA STATE POLICE FAX iI: 717-249-0779 . FRO-1 ~ CURTIS R. LONG RE: PFA ORDERS MESSAGE : ->>L.~~ /l:AQZS (IN:::LUDING COVER SHEET) , i. nris ~ is in~ cnly fur" tl"e we of ttB irdiv:id.e1 0:: Entity 1D W1idi is is ...uc.<! '5!, ;;n;l Il'8Y cmtain .infu:lretictl th3t is p:iv:Ueg;d. cmf:ida"ltial a"li ~ fu:m rosr1""lZe urler "WHNh1(>]av. ff tte ~ of this llESSage is rot tl~ interd3:1 ~, jOJ are h=ty rotif:iBj tret a:q di,sse'nira1;ia1, rUo=::ibJi::JJ::n cc a:w:in;I of this a:mn.nicat;m :is stxictly prlrlbitai. If )'OJ tm.e re;:ei<.e:! th1s . .,... ~ ':---...'1"'-.....1,, !-It tplFrl-l.~:ne ad 1.12b.Irn tie a::i.g:iral II: -:~ to w at "'.: ~, l '0 -, -J.-- Tamara Pantaloni Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00- 7401 CIVIL TERM Nicholas Pantaloni, Defendant : PROTECTION FROM ABUSE AND CUSTODY ORDER FOR CONTINUANCE AND NOW, this 17th day of November, 2000, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on November 20, 2000, by this Court's Order of October 26'\ 2000, is hereby rescheduled for hearing on F~7 ,200', at/.*, P.m. in Courtroom No.5. The Temporary Protection From Abuse Order shall remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. Joan Carey LEGAL SERVICES, INC. Attorney for Plaintiff By the co~} ~ 7;:d~ JI-2J-()O t<Kj Richard Wagner LAW OFFICE OF RICHARD WAGNER Attorney for Defendant - ~lIii!1im<~<ili61Hi::'~.3!~liI,,~W~iM'i'~~I@;if~~lf!"'U ,ht;;",$","",~,,,;..Jl;~4~".~:~~ioi~IIl:liliIiiiW;!~~~!~Jiil1!i'!llillllili (","lyIC\ t',~" !1'\\'l\0"!'i,\ :::;,.:; \~ ;\'~I !~:~_,~,,~r\\:>~,': )"fr, \,.L\ ~\ \ oJ . \ '\ U.\; """.'.\ ,'.> ;:J '~J ,'.\r>\('I '-j ,v \Jr, :: n'.-' .iJ \ -,'- II,j\-:O ' j ~J . - ~ , , t, ~ , >~ ~'~[U ~, - "~ . '"'-'-- ~<. " 6-;.:t ,~ Tamara Pantaloni : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00- 7401 CIVIL TERM Nicholas Pantaloni, Defendant : PROTECTION FROM ABUSE AND CUSTODY MOTION FOR CONTINUANCE The Plaintiff, Tamara Pantaloni, by and through her attorney, Joan Carey of Legal Services, Inc., moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: I. A Continuance was issued by this Court on October 26, 2000, scheduling a hearing for November 20, 2000, at 10:30 a.m. 2. The parties agree, by and through their respective counsel, that the hearing be rescheduled to allow them time to execute a Consent Agreement. 3. The Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. WHEREFORE, the Plaintiff requests that the Court grant this Motion and reschedule this matter for hearing, 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, Carey, Attorney for PI . LEGAL SERVICES, INC. 8 Irvine Row Carlisle, P A 17013 ~'JlI1~'4;.l;l.1;l!iiiJ;1ffi;lii~'OO!,~~~i:_~tl1>!i;';h,-~'d1tJt4:."~~llij~lM~~~~I!I'I\N-~~~"-" . " ~,~ ,,""7" ,<. ~<" ','" .~ c ,,",,~ ,.~ ~,,, > ..". ,," o c ~ -ate 111rn z::u zc 5Q:E ~c;~ 7\..~ c=O Pc z ::< ,.< .,~, , '1:::--> Cl :z ,-::J ,,',-:': N CJ ..~ ,I " ~ !I ~ . . " .:r:~ "!"" --~~s. :r:;;;> ::.;;: C) -1', gf? -{ 5J -< co .:.,.:> .l'"" -"- .~!ll , I "" "~-" '.LJi!i:a.:.~~~~~~,! , Tamara Pantaloni : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 00- 7401 CIVIL TERM Nicholas Pantaloni, Defendant : PROTECTION FROM ABUSE AND CUSTODY ORDER FOR CONTINUANCE AND NOW, this 26th day of October, 2000, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on October 26,2000, by this Court's Order of October 20, 2000, is hereby rescheduled for hearing on fJ1IJJI. . NO y. .1..11 I 1M". , 2000, atJtJ: .m. in Courtroom No.5. 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. Joan Carey LEGAL SERVICES, INC. Attorney for Plaintiff Edward E. Guido, Judge &pM1Y/cJl to -:J.. 7-00 ~K.3 Richard Wagner LAW OFFICE OF RICHARD WAGNER Attorney for Defendant f" llfli<Ml~1liOO.:I,-,~[r-'w-~-~ - '1i~*j-""""""tM",;,i>b!l,.":&@"'iii'~i.<~'jfAtlamitl..iJ~ it ,_ .__.on, - _ ., ."'~' _ ~~~ "'",",.. ',,'.--~. .-,. VlNV^1A~ ' N.NnOO ONVl\:l3191Nno 6~ 111l<lV LZ 1JO 00 }.,l:IV::l:ONr-H"j"'''' "j"" ,-" '''v\ : \"I:--->-j' ~rit 4fJ' ,....'-'",.. ...;. '-.- 3:)1:J:lv{HU:1 ~~ __, _~. 'n" c,,_ .. lI~~IIlIoi~t " i"1 ~jjjjl!lW\['" -- ~~ I Ii I, I! < ~~- - ,- , ". ., ~ilti,; Tamara Pantaloni Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 00-7401 CIVIL TERM : PROTECTION FROM ABUSE AND CUSTODY v. Nicholas Pantaloni, Defendant MOTION FOR CONTINUANCE The Plaintiff, Tamara Pantaloni, by and through her attorney, Joan Carey of Legal Services, Inc., moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: I. A Temporary Protection From Abuse Order was issued by this Court on October 20, 2000, scheduling a hearing for October 26,2000, at 3:00 p.m. 2. The Cumberland County Sheriff's Department served Defendant with a certified copy of the Temporary Protection From Abuse Order and Petition for Protection From Abuse at his residence, 20 Carlisle Road, Newville, Pennsylvania, on October 20, 2000, at 7:48 p.m. 3. The Defendant has retained to represent him in the matter 4. The parties agree, by and through their respective counsel, that the hearing be rescheduled pending further Order in this matter. 5. 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. "-"", '^ "",' "" . -',' --+."",;~:- WHEREFORE, the Plaintiff requests that the Court grant this Motion and reschedule this matter for hearing, 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. o Carey, Attorney for PI LEGAL SERVICES, IN 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ~~~I.~-';,:~""-~~:t~M;&;>l(~tMb-,:_:i,l..W""i~t~~';;;b';;hi,,,,,~;;;l,1<MjjIiaidillllil1' , "~ " '..-"~~- .. -, ..- - - If' < ~-- i!!li:~.JlIitlID!illill , ;1 " t.! I:] ,! Ii !i (") 0 0 c 0 ., s: 0 -ow ('"") 'J ~gj -i r';;::; zs;.; N .~(.:~ t.!J ~z cr' t5 L --t'--) kO ." :1: :f-\ ~O :>: \40 )>8 r:Y Ol""ll "'l ~ N ~ ~ ~ "~~ TAMARA PANT ALONI, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF VS. : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 2000_7vo/ CIVIL TERM NICHOLAS PANT ALONI, DEFENDANT : PROTECTION FROM ABUSE AND CUSTODY NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. J. AHEARINGONTHISMATTERISSCHEDUj,EDONJhU~ {)d~;mJ,AT . "IJ " .M., IN COURTROOM NO. ~ OF T '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 andlorup 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 fmd out where you can get legal help. If you cannot fmd a lawyer, you may have to proceed without one. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE, CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717)249-31 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. ~M!!WID~~i1it,~~~.e""%"'~~"'Gffi'",R'i;,lln_i6.yMI.~"C'~r' '-, ''''-'' h", ,., .=.'~ -~, ~ " ""I:IliIilIJ'.l.i.. ! '" ~V'!IiV!0),sNNJd J\.lJ'~r :;I'} ! '.!-"\'.r:tl~.'~."'I~^ - " '-.- '., , '\-,f ':;":::-;]/11 k} 0-;'1 : i f H~,;' il>' i I'in n.," '~" '.' .;........v Ul/ .~, , -",:,1 ~..' "'~. ._ _ J ~ , ~ <. I:slIiM:illill - -{ " " , .J ~ ~~~....Iiik, Tamara Ann Pantaloni Plaintiff : In the Court of Common Pleas : County, Pennsylvania v. : No. Nicholas Edward Pantaloni Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Nicholas Edward Pantaloni Defendant's Date of Birth is: September 22, 1967 Defendant's Social Security Number is: 178-58-9261 Name(s) of All protected persons, including Plaintiff and.minor children: 1. Tamara Ann Pantaloni AND NOW, ortJa. ~ ..1I~pon consideration of the attached Petition for Protection from Abuse, 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 shall be evicted and excluded from the residence at: 304 Middle Road Newville, PA 17241 - Defendant left the residence in August 2000. 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. '" l~ ,~_l 3. Except for such contact with the minor child/ren as may be permitted under paragraph 5 of this Order, 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. - Any future place of employment Plaintiff may establish. 4. Except for such contact with the minor child/ren as may be permitted under paragraph 5 of this Order, Defendant shall not contact Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 5. Pending the outcome of the final hearing in this matter, Plaintiff is awarded temporary custody of the following minor child/ren: 1. Nicholas Edward .PantaIoni II 2. Christina Marie Theresa Pantaloni 3. Cassidy Ann Pantaloni Until the final hearing, all contact between Defendant and the child/ren shall be limited to the following: Every other weekend from Friday until Sunday at times agreed upon by the , parties. The local law enforcement agency in the jurisdiction where the child/ren are located shall ensure that the child/ren are placed in the care and control ofthe Plaintiff in accordance with the tenus of this Order. 6. Defendant shall immediately relinquish any firearms license the Defendant may possess, and the following weapons to the Sheriff's Office or a designated local law enforcement agency for delivery to the Sheriff's Office. 1. Any and all fIrearms and lor weapons including but not limited to, handgun 2. sniper rifle 3. sawed off shotgun 4. 22 5. double barrel shortgun and all handguns, shotguns, and rifles and any liscense to carry a fIrearm Defendant may have. Defendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration of this order. ',~ .,~~, I'~ " ,-- JiM -1 !j!~._~" 7. The following additional relief is granted: -The Cumberland County Sheriffs Department shall attempt to make service at Plaintiff's request and without pre-payment of fees, but service may be accomplished under any applicable Rule of Civil Procedure. -This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service. The Prothonotary shall not send a copy of this Order to Defendant by mail. -This Order shall remain in effect until modified or terminated by the Court and can be extended beyond its original expiration date if the Court fmds thatDefendant has committed an act of abuse or has engaged in a pattern or practice that indicates risk of harm to Plaintiff and/or minor children. -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 Pennsylvania State Police 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 is to refrain from harassing Plaintiff's relatives. 8. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: State Police-Carlisle Barracks 9. 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. 10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL APRIL 18,2002 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. ,-~~. t I NOTICE TO THE DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months in jail. 23 Pa.C.S. 96114. Consent of the Plaintiff to Defendant's return to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. 96113. 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. 9~2261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiff's residence OR any location where a violation ofthis order occurs OR where the defendant may be located. If defendant violates Paragraphs 1 through 6 of this Order, defendant shall be arrested on the charge ofIndirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence oflaw enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriff's office of the county which issued this Order, which office shall maintain possession ofthe weapons until further Order of this court, unless the weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. Judge .B Distribution to: Legal Services Faxed & Mailed to PSP ,.- l" - ~,.,,~ '" ~~ -.....- . ~~ .'.'..... ~%.; PF AD Number: ND 1 148695H Tamara Ann Pantaloni : In the Court of Common Pleas : County, Pennsylvania Plaintiff v. : No. IH9 _ 7 '10 I C:.u.u(T ~ Nicholas Edward Pantaloni Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE I. Plaintiff's name is: Tamara Ann Pantaloni 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. Tamara Ann Pantaloni 4. Plaintiff's Address is: 304 Middle Road, Newville, PA 17241 5. Defendant's Name is: Nicholas Edward Pantaloni 6. Defendant is believed to live at the following address: Corner of Carlisle and Heights Road, Newville, P A 17241 7. Defendant's Social Security Number is: -,' - ~' >~', ." oI.li - ']'JiIljh 178-58-9261 8. Defendant's Date of Birth is: September 22, 1967 9. Defendant's Place of employment is: Traveling Craftsmen, 410 N. Market St., Mechanicsburg, PA 10. Defendant is an adult. 11. The relationship between the Plaintiff and the Defendant is: Spouse 12. The defendant has not been involved in a criminal court action. 13. Plaintiff and Defendant are the parents of the following minor child/ren: a. Nicholas Edward Pantaloni II Age:10 yrs Child's address is: 304 Middle Road, Newville, PA 17241 b. Christina Marie Theresa Pantaloni Age:7 yrs Child's address is: 304 Middle Road, Newville, PA 17241 c. Cassidy Ann Pantaloni Age:4yr 10mos Child's address is: 304 Middle Road, Newville, PA 17241 14. Plaintiff is seeking an Order of child custody as part of this petition. The following is a list of the children and where they have live for the past 5 years: a. Nicholas Edward Pantaloni II For the past 5 years, this child has lived with: 8/23/00 to present - 304 Middle Rd Newville - Plaintiff, Nicholas II, Christina & Cassidy 1991 to 8/23/00 - 304 Middle Rd Newville -Plaintiff, Defendant, " " ,I. ~. . -, ~ ~--," "U!"; minor children b. Christina Marie Theresa Panta10ni For the past 5 years, this child has lived with: 8/23/00 to present - 304 Middle Rd Newville -Plaintiff, Nicholas II, Christina & Cassidy 1991 to 8/23/00 - 304 Middle Rd Newville -Plaintiff, Defendant, minor children c. Cassidy Ann Pantaloni For the past 5 years, this child has lived with: 8/23/00 to present - 304 Middle Rd Newville - Plaintiff, Nicholas II, Christina & Cassidy 1991 to 8/23/00 - 304 Middle Rd Newville -Plaintiff, Defendant, minor children 15. The facts of the most recent incident of abuse are as follows: On or about each weekend in September 2000, Defendant came to the residence intoxicated, pushed Plaintiff, screamed in her face, and broke items in the residence that belonged to Plaintiff causing her to fear for her safety. 16. 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 16, 2000, Defendant screamed at Plaintiff to "f*** off" and sarcastically wished Plaintiff best wishes in her upcoming surgery stating that if she dies, he gets the kids. On or about August 23, 2000, Defendant pushed Plaintiff aronnd the residence. Defendant moved out of the residence at this time. On or about August 20,2000, Defendant punched Plaintiff in the stomach, pushed her down, straddled her, strangled her threatening that he hated her 2nd wanted her to die. On or about August 4, 2000, Defendant threw his breakfast across the room and pushed Plaintiff causing her to fear for her safety. On or about April 22, 2000, Defendant told Plaintiff he wished that she would die. Defendant threw Plaintiffto the ground, punched her, shoved her into a closet, and hit her about her body with a 2x4. Defendant took out his handgun, put it to the Plaintiffs head and told her he wished that she would die causing her to fear for her life. Plaintiff went to the Carlisle Hospital and the State Police were called. Plaintiff suffered injuries including bleeding and bruises on her arms, chest, and """_c. -- -.-:;Ji:~. legs. 17. 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 including but not limited to, handgun b. sniper rifle c. sawed off shotgun d. 22 e. double barrel shortgun and all handguns, shotguns, and rifles and any fIrearms license Defendant may possess 18. The police department( s) or law enforcement agencies that should be provided with a copy of the protection order are: State Police-Carlisle Barracks 19. There is an immediate and present danger of further abuse from the Defendant. 20. Plaintiff is asking the court to evict and exclude the Defendant from the following residence: 304 Middle Road Newville, PAl7241 Owned By: Nicholas & Tamara Pantaloni 21. The Defendant owes a duty of support to Plaintiff and/or minor child/ren. 22. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or minor child/ren in any place where Plaintiff may be found. b. Evict/exclude Defendant from Plaintiff's residence and prohibit Defendant from attempting to enter any temporary or permanent residence ofthe Plaintiff. c. Award Plaintiff temporary custody ofthe minor child/ren and place the following restrictions on contact between Defendant and child/ren: Every other weekend from Friday until Sunday at times agreed upon by the parties. }- "' .It . , , .~~ ~.-1-' lilii!~ d. 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 Plain tift'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. e. 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. f. Order Defendant to pay temporary support to Plaintiff and/or the minor child/ren, including medical support . g. Order Defendant to pay the costs of this action, including filing and service fees. h. Order the following additional relief, not listed above: - Order Defendant to refrain from harassing Plaintiff's relatives. - Enjoin Defendant from damaging or destroying any property owned jointly by the parties or solely by Plaintiff. - Order Defendant to pay $250.00 to one of Legal Services, Imc.'s funding sources as reimbursement for litigation in this case. 1. Order the police or other law enforcement agency to serve the Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. Respectfully submitted, Date: 10/,ftj / Hi I / C!~ Philip Briganti Attorneys for Plaintiff Legal Services, Inc. 8 Irvine Row Carlisle, P A 17013 Distribution to: -Legal Services -Fax and Mail PSP ,"~~....L , ~." _i. I ~_ _ _'J,'.~ - - - ~-,1,-,- 'lWL- VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statement$ contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. Dated: 9 wmL11 ff (J PaJj(J v1 P Ct( ~ Tamara Pantaloni, Plaintiff ~iWlllil~"1W'~d'k'\mr~~~~",j;~1iP-2<.l!_4effi~;<"h;i!;l~i';ti,ck",~JWIilAli'~"'~~-" '. , 'iti -'-","-.- ~~'JiMM>~- ~. -!t'ler- r, .:":'_') ~~ <~- ~ '----:) 1- ~. c.' ~'-i --'0,) ~=.' , ( >, ' , (~_: Z ~''V " " --1 -"', -<. (,) -<": r 11 r ~. ~ ~ ;p l0> ~ --+-.. F 1 fl.. ~ - <t- ~ ~~ p S r ~ -f ..;::.. i , ~~ +-~ c ~ l-J Jl> <- I w -- 0>\:7 ~ , ~ ~ -0 ~ ~ ~ ...., S 'S -+- t. ( C' 5-^:J w --t: . Vj q .",,_,__.~ ,,~__~.~_ >_,__~~___ ,."d. _~',,, ,,'.",.~ - .~ ~>,', - ~ 10/20/00 ~ ... F~101,4!';J5 FAX 717 , 240 6573 *************************** *** MULTI TN REPORT *** *************************** CUMB co PROTHONOTARY , @OOl , TX/RK NO INCOMPLETE TX/RK TRANSACTION OK 2236 ERROR [ 01]9p2405331 [ 03]9P2438026 [ 04]92490779 CENTRAL PROCESS LEGAL SERVICES PSP I I \ I , I , I I I I I I I I I I <13GN3S 3HL !Jill )lS\i am ::r1SISOOd S\i NCX>S SV f;619-0vZ (L 10 11\1:) 3S;13'ld 'lI'<I31;)Nfl 3W S~'<id MW !JO 'S39'<id 3HL TN 31\I3J311 J.ON CG 00" dJ '3JDN "f'I::l{ >{lI3.\1 "a:J]:.-uas"[Elm:l "S",. ap ""'" ~ .~'O:? ag W gl CII JA. " 1W1fi1::D ap UJl'"qa~ p.:e aJ'tPalal ;q ,{~ S1 i,:mOJ asa3'[!:'I '.:Una U!' Wf'....JflfiWW st4l P"'~ <WL{ f'I::l{ JI "P"l,q[lpXl Ay.pp:jS '" LOr..roru= SNl ;p a.ptto D ~ 't.DqaJ!llF.l9SW 1v2 =lEtH ~ ~ a:m ~ '~ P'P-""l"!" ap :pI s> di. n Sf41 JO ~ a.p Jl "I"E!"[ "l4"-'H<li<.Jap.rl oo'''''-'l....W uo:g :Pm>a p.:e ~ '~p:i s> =lEtH ~ U!"'llCO ku p.:e 'l 1fP" Sf Sf <P;tf< CII ,{:rnw .JO 191Pr^W1!' a.p JO asn a.p .JqJ: ,{1= ~U!' 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