HomeMy WebLinkAbout00-07827
TINA MCKEE,
: IN THE COURT OF COMMON PLEAS OF
PLAINTIFF
VS.
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 2000- 78"Ji CIVIL TERM
WAYNE MCKEE, JR.,
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.
A HEARING ON THIS MATTER IS SCHEDULED ON ~\J\.lMlxr \ ~ ,DXl,AT
\ ~ ~() P.M., IN COURTROOM NO. ~ OF THE CUMBERLAND
COUNTY COURTHOUSE, CARLISLE, lPENNSYL VANIA.
You MUST obey the Order that is attached until it is modified or terminated by the court
after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this
Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up
to $1,000.00 and/or up to six months injail under 23 Pa.C.S. ~6114. Violation may also subject you
to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18
U.S.C. S2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories
and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate
this Order, you may be subject to federal criminal proceedings under the Violence Against Women
Act, 18 U.S.C. S 2261-2262.
You should take this paper to your lawyer at once. You have the right to have a l!lwyer
represent you at the hearing. The court will not, however, appoint a lawyer for you. If you
do not have a lawyer or cannot afford one, go to or telephone the office set forth below to fmd
out where you can get legal help. If you cannot find a lawyer, you may have to proceed
without one.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE, CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717)249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact
our office. All arrangements must be made at least 72 hours prior to any hearing or business before
the court. You must attend the scheduled conference or hearing.
'~,
:7,,~'$ ,"!!I'M!.
,~.'~"-'>lrJ/.A\>l",'~dJWi.j,"'~,M-l!il~~~lli~;;.Iw:i;;"!";<~''-~'''';li-'''A",,,,-',"1i,,,*,..'8l'~t,~.-n""""'"'"~b~'ili""~.,;~",,,~~~!M~j~~~:i>,r::l
~~"'-~
'.'-'-,
. _',<",,,". ,_,."""'''"~~, ~_ ~ _~"_"''''' .,.~. , _~ ,~,~,m,..,
O'
F'"I rCil_(:~.:r::I(\C
- ...J V!lIVI..
"""'Tf-'r'i'()TARY
00 NOI/-6 AM 9: 15
CUi'/,G~ilLA\ID COUNTY
PENi\!SYLV/\i\I/,';
,,0,., ., i e,,~', ___~ ._
"_~l_
~-
H"
~. ~.-.
1
,
,
Plaintiff
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYL VANIA
Tina Louise McKee
v.
: No(X!1-~.ii-
Wayne Elmer McKee Jr.
Defendant
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: Wayne Elmer McKee Jr.
Defendant's Date of Birth is: February 7, 1964
Defendant's Social Security Number is: 203-52-8369
N ame( s) of All protected persons, including Plaintiff and minor children:
1. Tina Louise ~cKee
AND NOW, JJ<< f ~nsideration 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.
2. Defendant shall be evicted and excluded from the residence at:
28 Middle Springs Road, Shippensburg, 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.
,,,'. ~,""
., ..~- -
r"
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 plac.e of
employment. Defendant is specifically ordered to stay away from the followmg
locations for the duration of this order.
Plaintiff is employed at the residence located at 28 Middle Springs Road,
Shippensburg, Pennsylvania.
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. Wayne Elmer McKee m
2. Dylan Ray McKee
3. Justin Michael McKee
Until the final hearing, all contact between Defendant and the child/ren shall be
limited to the following:
-Plaintiff shall have custody of Justin McKee and Wayne McKee III
pursuant to this Court's Order of May 30,1991.
-Plaintiff shall have primary physical custody of Dylan Ray McKee.
- Defendant shall return the children to the mother's custody immediately.
-Defendant shall have partial custody ofthe three children every other
weekend and other times agreed upon.
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 of the
Plaintiff in accordance with the terms of this Order.
6. The following additional relief is granted:
-This Order shall be docketed in the office of the Prothonotary and
forwarded to the Port Orange County, Florida 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
that Defendant has committed an act of abuse or has engaged in a pattern or
practice that indicates risk of harm to Plaintiff.
\_~,
-."".
"-.
-Defendant is 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.
7. A certified copy of this Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
The Pennsylvania State Police
8. The sheriff, police or other law enforcement agencies are directed to serve the
Defendant with a copy of the Petition, any Order issued, and the Order for
Hearing without prepayment of costs. The Petitioner will inform the designated
authority of any addresses, other than the Defendant's residence, where Defendant
can be served. The Prothonotary is directed to file this Petition and Order without
prepayment of costs.
9. THIS ORDER SUPERSEDES
ANY PRIOR ORDER RELATING TO CHILD CUSTODY
10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL MAY 3, 2002 OR UNTIL OTHERWISE
MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND
HEARING.
NOTICE TO THE DEFENDANT
Defendant is hereby notified that violation of this Order may result in arrest for
indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or
up to six months injail. 23 Pa.C.S. g6114. Consent of the Plaintiff to Defendant's
return to the residence shall not invalidate this Order, which can only be changed or
modified through the filing of appropriate court papers for that purpose. 23 Pa.C.s.
g6113. Defendant is further notified that violation of this Order may subject himfher
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. g~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 1 through 5 of this
Order, defendant shall be arrested on the charge of Indirect Criminal Contempt. An
arrest for violation of this Order may be made without warrant, based solely on
probable cause, whether or not the violation is committed in the presence oflaw
enforcement.
Subsequent to an arrest, the law enforcement officer shall seize all weapons used or
'i~ p~ '" "c.' ~.
"
~ - .
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 of the weapons until
further Order of this court, unless the weapon/s are evidence of a crime, in which
case, they shall remain with the law enforcement agency whose officer made the
arrest.
Judge
-----.------------~-- n -1~
Distribution to:
Legal Services
Faxed & Mailed to PSP
TRUE COPY FROM RECORD
In Testimony hereof, I here unto set my hand
hand and the seal of said Court at Carlisle, Pa.
This _ day of
,2000.
Prothonotary
~~ ~,~ q", ""'F~_~ ~~ ~ ~ _ _~~ ,_
- .~
~
.
PF AD Number: RB 1156064N
Plaintiff
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
Tina Louise McKee
v.
: No. 00 --rtfJ?
Wayne Elmer McKee Jr.
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
Defendant
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiff's name is:
Tina Louise McKee
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. Tina Louise McKee
4. Plaintiff's Address is : 28 Middle Springs Road, Shippensburg, P A 17257
5. Defendant's Name is:
Wayne Elmer McKee Jr.
6. Defendant is believed to live at the following address:
637 Aurora Street, Daytona Beach, FL 32119
7. Defendant's Social Security Number is:
203-52-8369
:"~ -~, - ~ -". -. .-- .' -1. -,
8. Defendant's Date of Birth is:
February 7, 1964
9. Defendant's Place of employment is:
Chestnut Grove Construction, 90 Chestnut Grove Road, Shippensburg
10. Defendant is an adult.
11. The relationship between the Plaintiff and the Defendant is:
Spouse
12. The Plaintiff and the Defendant been involved in the following court actions:
a. Custody
I3. Other details of the court action are:
-McKee v. Mckee -Custody 91-1866 Cumberland County Court of
Common Pleas -See Order granting Plaintiff primary physical custody
of Justin and Wayne McKee. The Order is attached and incoporated
by reference.
14. The defendant has not been involved in a criminal court action.
15. Plaintiff and Defendant are the parents of the following minor child/ren:
a. Justin Michael McKee
Age: 12 years old
Child's address is: 637 Aurora Street, Daytona Beach, FL 32119
b. Wayne Elmer McKee III
Age:l0 years old
Child's address is: 637 Aurora Street, Daytona Beach, FL 32119
c. Dylan Ray McKee
Age:7 years old
Child's address is: 637 Aurora Street, Daytona Beach, FL 32119
1:',.-_ ~'l
~ ,
"..
'.
16. There is an existing court order regarding the custody of the Plaintiff's and Defendant's
minor children.
The terms of the order are: ---Plaintiff has primary physical custody of Justin and
Wayne McKee. ---Defendant has partial custody every other weekend and at other
times mutually agreed upon between the parties. ---Plaintiff seeks to confirm
primary custody of Justin and Wayne Mckee to her pursuant to this Court's
Order docketed at 91-1866. --- The Custody Order does not include the youngest
child, Dylan McKee who was not born at that time. --- Plaintiff asks that
Defendant be ordered to return the children to her custody immediately for
reasons including the following: Defendant fraudulently removed the children
from Pennsylvania and took them to Florida without Plaintiffs knowlegde on or
about October 26, 2000, and Defendant has kept the children out of school and has
placed them in danger by not giving them all of their required medications.
County: Cumberland County
State: Pennsylvania
17. 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. Justin Michael McKee
For the past 5 years, this child has lived with:
Plaintiff and Defendant 3703 Roxbury Road, 1995 until 1998
Shippensburg, P A
Plaintiff and Defendant 28 Middle Springs Road 1998 until 2000
Shippensburg, P A
b. Wayne Elmer McKee III
For the past 5 years, this child has lived with:
Plaintiff and Defendant 3703 Roxbury Road, 1995 until 1998
Shippensburg, P A
Plaintiff and Defendant 28 Middle Springs Road 1998 until 2000
Shippensburg, P A
c. Dylan Ray McKee
F or the past 5 years, this child has lived with:
Plaintiff and Defendant 3703 Roxbury Road, 1995 until 1998
Shippensburg, P A
Plaintiff and Defendant 28 Middle Springs Road 1998 until 2000
Shippensburg, P A
;".,,-
, ,-
- Plaintiff seeks primary physical custody of Dylan McKee.
18. The facts of the most recent incident of abuse are as follows:
On or about October 21, 2000, Defendant grabbed Plaintiff, pushed her through
the door, and punched her several funes in the head. Plaintiff went to the police
station and from there was transported to the Chambersburg Hospital. Plaintiff
suffered headaches, ear ache, and brusing as a result of the incident.
19. 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:
In or about August 2000, Defendant threw a power tool at Plaintiff who had to
move out of the way to avoid being hit causing her to fear for her safety.
In or about the beginning of Summer 2000, Defendant became angry, threw all of
Plaintiffs clothes outside, and shoved her out the door.
20. The police department(s) or law enforcement agencies that should be provided with a
copy of the protection order are:
The Pennsylvania State Police
21. There is an immediate and present danger of further abuse from the Defendant.
22. Plaintiff is asking the court to evict and exclude the Defendant from the following
residence:
28 Middle Springs Road, ShippensilJurg, P A
Rented By:Wayne and Tina McKee
23. Plaintiffhas suffered out-of-pocket financial losses as a result ofthe abuse described
above. Those losses are:
Hospital bills totaling $2,016.00 which Plaintiff incurred as a result of the incident
of abuse on October 21, 2000.
24. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT
ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER
THAT WOULD DO THE FOLLOWING:
a. Restrain Defendant from abusing, threatening, harassing, or stalking
Plaintiff and/or minor child/ren in any place where Plaintiff may be
found.
b. Evict/exclude Defendant from Plaintiffs residence and prohibit
Defendant from attempting to enter any temporary or permanent
residence ofthe Plaintiff.
c. Award Plaintiff temporary custody of the minor child/ren and place
the following restrictions on contact between Defendant and
child/ren:
.ifm ,~'^
,
-.
- Defendant shall immediately return custody of the children to
Plaintiff.
-Defendant shall have partial custody ofthe three children every
other weekend and at other times agreed upon between the
parties.
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 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.
e. Direct Defendant to pay Plaintiff for the reasonable financial losses
suffered as the result of the abuse, to be determined at the hearing.
f. Order Defendant to pay the costs of this action, including filing and
service fees.
g. Order the following additional relief, not listed above:
- Defendant shall refrain from harassing Plaintiffs relatives.
- Defendant is enjoined from daml\ging or destroying any
property owned solely by the Plaintiff or jointly by the parties.
- Defendant shall pay $250.00 to one of Legal Services, Inco's
funding sources as reimbursement for litigation in this case.
h. 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:
114/trcJ
/ /
oan Carey, Attorney Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
ii
:1-
Distribution to:
Legal SerVices, Inc.
Fax and Mail to PSP
" ~
VERIFICATION
I verify that I am the Petitioner as designated in the present action and that the facts and
statements contained in the above Petition are true and correct to the best of my knowledge. I
understand that any false statements are made subject to the penalties of 18 Pa.C.S. 94904, relating
to unsworn falsification to authorities.
Dated: II - I - ()O
- / { J( q L(ilILv?,
Tina McKee, Plaintiff
,J;,r -,~-
-
TINA L. MCKEE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
:
vs.
CIVIL ACTION - LAW
NO. I fc (" CIVIL 1991
WAYNE E. MCKEE, JR.,
Defendant
CUSTODY
:
AND NOW,
TEMPORARY C~ODY ORDER
this ___~____ day of
May,
1991,
upon
consideration of the Petition for Special Relief, primary
physical custody is granted to the Plaintiff with the Defendant
having partial custody every other weekend and other times to be
mutually agreed upon between the parties.
By the Court,
-it1Jt-I
J.
TRUE COPY FROM RECORD
In Testimony hereof, I here unto set my hand
hand and the seal of said Court at Carlisle, Pa.
This _ day of
,2000.
Prothonotary
'~~'-'~~
~~
-~, ~,
,',~~, . .~,,"..'
.. ,~-, .-~,
~
~ C) 0 ~
-- ('\
. . . 0
~ a
." D..-
eft -- <A --
~ D,....
~ .
"'" a:.
~ ~ ~ V)
!1 ~ -..j v
c
<S ~ <:s
~
~ c....... >< ~
cf ~ ~ l1- \E
>- \.!) ~
is ere :z:
" N :;><(
~J..rz C)7
F~~~ a..~ CJ:..::c
("':r,,_-. C)::3
L~S~ 0') -:;")-
S~
LL~ t,,_ I
~'f-, , ;::.'" C.I::Z
LL ~.:.. UJW
j:::: CJ [Q n..
Z k"'_
LL .~
0 ::::>
0 0 <.)
I
I
I
I
I
I
I
I:
"
I
Il
"
l
1""_1
1; ~
,
l'
<l
,
"-
"
\:J
J
~~
;ll[~~Jll!!!l'llo<;: ~.,=_~.)~~'li!t'iji!'!WOOl~!!~W.~rilfl!""~lt"'o~t~ffi;;:_1I1~'!Y~"";~>l)Fdl!ilj!:ffl~Il'iI;"!"lliliPM~~1['-;!I'~"p,,,q1l't;WJworR'.~"'~~"'~;"n'''''''''';''';\\'~~~R~~V~'fflffi1"''''''f'''''''"<-r-~,~!\mll,~WW
u
11/06/00 MON 10:2S FAX 717 240 6573
CUMB CO PROTHONOTARY
14J00l
h,
***************************
*n MULTI TN REPORT ***
***************************
TX/RX NO
INCOMPLETE TX/RX
TRANSACTION OK
2263
01I9p2405331
03I9p2438026
04]92490779
CENTRAL PROCESS
LEGAL SERVICES
PSP
ERROR
.
OFFICE OF '!HE I'RGI'H<NJl'ARY
ClMlERLAND a:xJNTY CQUR'IlICUSE
..
OOE CCJUR'IlICUSE SQUARE
CARLISLE, PA. 17013-3387
(717) 240-6195
FAX (717) 240-6573
FAX ~:
psP
LS /) .
C.efl{a,{ 'rOL~5Stl1.j
tj-cJ..4-D- 0631
VIA TELECOPIER
TO:
--,
FRG1:
CURTIS R. LONG
RE: fJ FA Orc!..-elf5
MESSAGE :
. Ill- '.' ... 00. OF PAGES (IN:LUDING rovER SHEET)
This ~ is intarla:l ally fur tte \.Be of tte irdiv:idJ..B.l eX" 61tity to Wrid1 is is cilll. -I. a:rl1TEfi
a:ntaininfumatim !tat is p:ivile;Jrl. a:nf:idential arl earpt fu:m iHcr-l,..",u-e U"li& 'tP1 inonlp IaN. If
tte m:rec- of this ~ is rot tiE intarl9:l r:e::ipia:lt. ~ are tEr:lt:Jt rotifie:j lh3t ffl/ cliseaniretiJ::n.
c:li.stril:1lba eX" o::pfirg of this onmrucatirn ~ strictly prlUbitErl. If ~ l'aI.e re:eiw:! [Jus
mnnnir.r.Ja1 in emr. pleeee rctify lS immiiate1y ~ lE1fPl:re a:rl return tie adginalll "T lD LE at
'"'~d 1 ~-~,=~,
, ~, ~.
)
Plaintiff
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
Tina Louise McKee
v.
Wayne Elmer McKee Jr.
Defendant
: No. 007827
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
ORDER ASSESSING COSTS
And now, this 16th Day of November, 2000, Wayne Elmer McKee Jr.
(Defendant) is hearby ORDERED to pay costs in the above action.
Costs Include:
Domestic Violence surcharge
$25.00
Total:
$25.00
Cash or Money Order payable to
Clerk of courts
Cumberland County Courthouse
1 Courthouse Square
Carlisle, P A 17013
Office of Costs and Fines 2nd Floor
It is further ORDERED that said costs shall be paid by December 14, 2000.
~ ;',,;05
ll-J7"OO
RK~
.__ rn ".~
l1!t~1:~~:;j;ii,[:;:;;J,,','C,,","~,-,~:i'4i'Z;i",,'10~4mm~jMilI:/iijJ\\W-'"'e;;~Wj~",,;,-,,~M1,ti'llllil~~:i:4f!7~'il<'!'i$,.,,~m~~j'N~-E',,~i,j_~"'--'~H~;lJI"!.!05~~m~-....
'O~'I'-:JCE
, "'TI;",\I"""ARV
, , -, '; \',~}: I
CO f'ell J 0' P"
j n 3: 29
In, II'" ,
-.'U lv', tj''',r'l "",,', 1""ur"TY
. ;::' 1~.J 'rl ,U vU \f
PtNNSYLVANIA
,""'Of' .'~~_
__.,J.
.,'
". ,~~
.~ .
"~,
Distribution to:
Legal Services
Faxed & Mailed to PSP
Wayne McKee
1129 Means Hollow Road
Shippensburg, P A 17257
~r'.T
'"""" 'eJ" ,
-
rr--,
Respondent
Tina Louise McKee
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
Plaintiff
v.
.
: No. 007827
Wayne Elmer McKee Ir.
Defendant
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
FINAL ORDER OF COURT
Defendant's Name is: Wayne Elmer McKee Jr.
Defendant's Date of Birth is: February 7, 1964
Defendant's Social Security Number is: 203-52-8369
Name(s) of All protected persons, including Plaintiff and minor children:
1. Tina Louise McKee
Appearances by Parties and/or Counsel:
. Plaintiff appeared personally and is represented by:
David Lopez and Joan Carey, Legal Services, Inc.
. Defendant appeared personally and is unrepresented.
AND NOW, this 15th Day of November, 2000 the court having jurisdiction
over the parties and the subject-matter, it is ORDERED, ADJUDGED and
DECREED as follows:
Plaintiffs request for a Final Protection Order is granted, after hearing upon
finding abuse within the PF A Act.
Plaintiffs request for a fmal protection order is granted.
1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other
protected person in any place where they might be found.
~"'F.'_ -~
"
2. Defendant is completely evicted and excluded from the residence at:
28 Middle Springs Road, Shippensburg, P A
or any other residence where Plaintiff or any other person protected under this
Order 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 of Plaintiff or any other person protected under this Order.
3. Except as provided in Paragraph 5 of this Order, 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
Plaintiffs school, business, or place of employement. Defendant is
specifically ordered to stay away from the following locations for the
duration of this order.
Plaintiff is employed at the residence located at 28 Middle Springs Road,
Shippensburg, Pennsylvania.
4. Except as provided in Paragraph 5 of this Order, Defendant shall not contact
the Plaintiff, or any other person protected under this Order, by telephone or
by any other means, including through third persons.
5. Custody of the following minor children:
1. Wayne Elmer McKee III
2. Dylan Ray McKee
3. Justin Michael McKee
shall be as follows:
. SEE ATTACHED ORDER
6. The following additional relief is granted as authorized by 96108 of the Act:
-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.
-Donna Richardson and Richard Stache shall facilitate the transfer of
Defendant's personal property to him at times agreed upon by the
parties.
-Defendant is ordered to pay the costs of this action, including filing fees
service fees, and surcharge of $25.00. '
]',,:,'r~,",_,
7. A certified copy of this Order shall be provided tothe police department
where Plaintiff resides and any other agency specified hereafter:
The Pennsylvania State Police
8. THIS ORDER SUPERSEDES:
1. ANY PRIOR PF A ORDER
2. ANY PRIOR ORDER RELATING TO CHILD
CUSTODY
9. All provisions of this order shall expire on: May 16, 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. ~6114. VIOLATION MAY ALSO
SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES
UNDER THE PENNSYLVANIA CRIMES CODE.
THIS ORDER IS ENFORCEABLE IN ALL FIFTY (SO) 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. ~226S. 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. ~922(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 of this order occurs OR where the defendant may be located,
shall enforce this order. An arrest for violation of Paragraphs 1 through S of this
order may be without warrant, based soley on probable cause, whether or not
the violation is cormnitted in the presence of the police. 23 Pa.C.S. 96113.
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 ofthis 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 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.
j~{
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.
President
Judge
J9.<l~
If entered pursuant to the consent of plaintiff and defendant:
Plaintitl's Signature
Defendant's Signature
Distribution to:
Legal Services
Faxed & Mailed to PSP
\ii;ayne McKee
1'129 Means Hollow Road
Shippensburg, PA 17257
t CF(lJ:m -fY1 aAtl
/}-/7-00
RJ{S
Wb, PSP,CP,LS
J1\cb~J... b, PSP
/1-/?-00
~X5
a-,;J _,~ .' "
~,~
.
-.q-
~< ^ ",p_. -~-o
,--
"'_b ~
~- ,~" ,-,~~, ~~, -:,~;)-
. "
- <_."~'_~ - "h
,- ,~
>.. r-' r-.:
~~~ ::Z
::J -....
;.U Cj"', (,~~~
:S:: -<",
il_ S, c::~ -.. '-.'""'~
"'-:. t_") :::::J
(~) C) W
F~; ''''.1 -~~':1 Z
.J:: Z
l~L: ., , c:, '_,"-J UJ
,:.Ll 0-
;;::.::. ~~
li_ C'") =--)
() C- O
-'
flll!l!~'ljllii:wJ"J!lmllj'<H'J!l~!~~~~_W!'W'~'~~~_"'_;,:'W#JM~filjft;<ffl!-;l'i#N'''''~'!,0'!1!',"~~'""I:;q;;'J~"""_,'r'T;,,,,?,W-""'i--~-'''''I'tJ'll'l''ffiqf.W!ili'l''''W~",~W4l'~''""-".~1'--'r"""!'i~~~'f!flllli4'!;lWfflJ~
TINA MCKEE,
: IN THE COURT OF COMMON PLEAS OF
PLAINTIFF
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
: NO. 2000-7827 CIVIL TERM
WAYNE MCKEE, JR.,
DEFENDANT
: PROTECTION FROM ABUSE AND CUSTODY
TINA MCKEE,
: IN THE COURT OF COMMON PLEAS OF
PLAINTIFF
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
: NO. 1866 CIVIL 1991
WAYNE MCKEE, JR.,
DEFENDANT
: CUSTODY
~STODY ORDER
AND NOW, thist(day of November, 2000, after a hearing regarding Protection from
Abuse and Custody and at the direction of this Court that the parties present an agreed upon
custody schedule in which the Plaintiff retains primary physical custody subject to the Defendant
having a specific partial physical custody schedule, the following Order is entered with regard to
custody of the parties' children: Justin Michael McKee (DOB 4/7/88), Wayne Elmer McKee III
(2/17/90), and Dylan McKee (DOB 5/10/93).
1. The plaintiff, Tina McKee, hereinafter referred to as the mother, and the defendant,
Wayne Elmer McKee, Jr., hereinafter referred to as the father, shall share legal custody of the
children.
2. The mother shall have primary physical custody of the children.
3. The father shall have partial physical custody of the children according to the following
schedule:
.~~, ". ""--^\C',-~.~,,
a. Every other weekend from Friday at 4:00 p.m. until Sunday at 7:30 p.m.
commencing November 17, 2000.
b. Every Wednesday from 4:00 p.m. until 7:30 p.m., and
c. Other times agreed upon by the mother and father.
4. The father may take the oldest child, Justin, hunting upon 24 hour notice to the
mother. Father shall supply the mother with the approximate location where the child will be
hunting, and Father shall supervise Justin at all times during the hunting trip. The father shall
not permit the two younger children to go into the woods during hunting season.
5. The father and mother shall share Thanksgiving, Christmas, and Easter each year
according to the following schedule:
a The mother shall have the children from 8:00 a.m. until 2:00 p.m.
b. The father shall have the children from 2:00 p.m. until 8:00 p.m.
6. The father is responsible for transporting the children to and from the mother's
residence for his periods of custody.
7. Neither parent shall remove the children from the Commonwealth of Pennsylvania
without the consent of the other parent. If either parent takes the children away from the home
overnight, that parent shall provide the other parent with an address and phone munber where the
children can be reached.
8. The mother and father shall notify each other of all medical care the children receive
while in that parent's care. Each parent shall notify the other immediately of medical
emergencies which arise while the children are in that parent's care.
9. Each parent shall notify the other at least within 72 hours of any change of address or
telephone number.
-'~."I ~"_, _,,",,'~_~'_ ~_
10. Neither parent shall do anything which may estrange the children from the other
parent, or injure the opinion of the children as to the other parent or which may hamper the free
and natural development of the children's love or respect for the other parent.
This Order is entered without prejudice to either party to request a conciliation
conference, but the Order shall remain in effect pending further Order of Court.
By the Court,
Joan Carey and David Lopez
Attorneys for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle P A 170 13
Wayne McKee, Jr., Defendant
1129 Means Hollow Rd.
Shippensburg P A 17257
If.,
-
i
>-
c::
<(
1,-
~i~;2
c'
u.' ~.::_.
c:t
l-u
lL
()
~~,.., 11<:1 v~ 0 III
,,~, _o'~' .'.r_
."
'~4'-~"~~^
'".
,..-
C
'z
:;;0<
, )~-
C)?;
..~~
~,H LLl
:"._~ [1-
.':';
:3
o
u~
;:zc
a
N
:>
Sl
de.
a
C)
:;'''Wl~-mWH~''''~''''.lfIl!l'i''''"*,,,,~~!rl'~~~-l''r"~w:lIW~t1'~[iM".;WiN\<'f\I~!!I~_,";-~'''''''_~'1,,;c,,:,~,--,--"i""'_"~ ';~!'-""W"_,_"';'~W'2',:iF"(l'J.;'~.F.i~.i'W-\''''~F''''!f.P.\\'.'~'F~''-'-'.,.- ji';'--"'fl''f'''1'*'''f'!1%j!Ii'1:''M1!R~!mlW"'fA'<1.
11/17/00 FRI 10: 03 FAX 717 240 6573- . ..
CUMB CO PROTHONOTARY
141001
***************************
*** MULTI TN REPORT ***
***************************
TXlRX NO
INCOMPLETE TX/RX
TRANSACTION OK
2290
01] 9p2405331
03]9p2438026
04]92490779
CENTRAL PROCESS
LEGAL SERVICES
PSP
ERROR
----.
,
OFFICE OF THE PRarHCNOTAR'f
CUMBERLAND COON1"i COUR'lllOOSE
U'IE lXXJR1liOOSE SClUARE
CARLISLE. PA. 17013-3387
(717) 240-6195
FAX (717) 240-6573
TO:
LS
(enl. Pe.oce55.
PA. STATE POLICE
V I ATE LEe 0 PIE R
fAX #:
717-249-0779
E'R01 :
CURTIS R. LONG
RE:
PFA. ORDERS
MESSAGE:
-----It- t'Xl. OF PA.GES (IN:WDING COVER SHEET)
-------- ---
'Ihi$ ~ is in1:J:':rIBj, ally ftx' tTe I.Ee of t:I:E irdiv.id.a1 0= E!ltity 1:0 ...rn.cn is is cO:h.~, .:ro nay
CXIJt:ain ;itlfumll:icn ttet is p:ivi.lep:l. OO"If~tial ad e<BIIX fron c1i:;rl""m:': urler 'rr\';,."nl", 1;w. (f
tIe ~ of this II "'T is rot tlB il'lta"ded ra::ip.ient. ~ are ~ rotifil:rl Ihrt IDf dissEmiratia>.
"''''''''-;h <Hm nr C(D{~ tf. this COlTTU'lli:aticn is strictly );Xdribi.ta:l. If}UI taI.e J:B:ei~ tius
...._ .~...nn:::lll ~ to L6 61,.
CERTIFICATION OF PFA CXNl'EMPI'
CASE NlHlER 00-7827 CIVIL TERM
NAME WAYNE ELMER McKEE JR
VICTIM'S NAME:
637 Aurora St.
Daytona Beach FL 32119
TINA LOUISE McKEE
BALANCE DUE: $ 70.50
ADD DELETE
$ $
$ $
$ $
$ - $
$ - $
$ 45.50 $
170 STATE SURCHARGE
171 STATE FINE
260 SHERIFF COST ($1.50 + ADDTL)
207 DISTRICT ATTORNEY
204 COURT COSTS (CLERK OF COURTS)
502 RESTITUTION
NAME PROTHONOTARY
ADDRESS
CITY
STATE
ZIP
NAME
DOMESTIC VIOLENCE SURCHARGE
$ 25.00
$
ADDRESS
A'"
CITY
STATE
ZIP
NAME
$
$
ADDRESS
CITY
STATE
ZIP
PROTHONOTARY OFFICE
pERSON CERTIFYING INFORMATION
DAT
!,;~~.
/
,
I
/
A
/
~,.
,
TINA LOUISE MCKEE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
INDIRECT CRIMINAL CONTEMPT
WAYNE ELMER MCKEE, JR.,
Defendant
00-7827 CIVIL TERM
IN RE: RULE TO SHOW CAUSE
ORDER OF COURT
AND NOW, May 4, 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
Friday, June 1, 2001, at 9:30 A.M. in Courtroom No.4, Cumberland
County Courthouse, Carlisle, Pennsylvania.
Service of the Rule to be made on defendant by First
Class Mail.
By the Court,
A4
Hess, J.
:dp
;~ ".,..~~ '"-<"
'...
-
, -~'"
:%i;iliwfiiU~~;'Illi-J;&,Mrl.<;ii,~(il"i'E't,:iO~&i"llii!i!'.bfuot~;.;E""1''-'''-''':'"''''_~''"''i>i.',,,-oiJ;,!,,,.,,,,,,,:;,j2.,~~"Ui$~it@ljjjlllll!.II'lli,./i!..~,,,,r,.!'_~';,,,,_iiI<I-jJ;;~~~llMiiilllili~.~ .~ iilJ'<"~
hi
I
,
'.,;,-
,"
", ':- OJ'~b::::;~ ,~,
""Jr-.RY
("J'I 'I!' 'J _. P"
e J",I"':! w
fJH 3; no
CUMdLHLr({) COUNTY
PENNS'rlVANIA '
_' ,< l! ,.~.< " . _ - _"""""""""'q,, '''<'''_M_~_''_,~^,',,!_'' . ,.'_~'_' ~.'" ",~, ",.'
<,--",... .,,..,..-~^...,,,.",
,,--- ,".
',n)", ,"~'"'
-
-
~
TINA LOUISE MCKEE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
CIVIL ACTION - LAW
CHARGE: INDIRECT CRIMINAL
CONTEMPT
00-7827 CIVIL TERM
WAYNE ELMER MCKEE, JR.,
Defendant
PETITION TO SHOW CAUSE WHY THE DEFENDANT SHOULD NOT
BE HELD IN CONTEMPT OF COURT
AND NOW, May 4, 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 November 16, 2000.
The defendant has failed to:
[] Report to the Probation Office in person at the
time and date set by the Collections Officer.
[X] Make regular payments on the fine, costs and
restitution as agreed.
The defendant has agreed to pay $70.50 per month.
Date last paid was never.
The balance is $70.50.
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,
~k.V~
Petitioner
::"',,,.....,"" ,,'- .,
.
.
TINA LOUISE MCKEE,
Plaintiff
v
WAYNE ELMER MCKEE, JR.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
00-7827 CIVIL TERM
INDIRECT CRIMINAL CO~TEMPT
IN RE: BENCH WARRANT
ORDER OF COURT
AND NOW, this 1st day of June, 2001, a bench warrant
is issued for the arrest of the defendant.
Michael Mervine, Esquire
Assistant District Attorney
Probation ~
Sheriff ~~
:bg
- O{)-7t8) C.
~~\< ee- yl\CK €c <'
-1,1\ J\~'t:Q.-f Cft\'rn\ YlOvI
COf\ ~€M~t.
- /J 1\ f-iW-",1"
PJ- ~~ &~C,O
,.-,%~_?",~,
~~:"""'''''''~'''''
- ',,~-z ''';C'_~', ., C-I. ','
By the Court,
/1-4-
,-.
';
,
Tina Louise McKee
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
CIVIL ACTION - LAW
Wayne Elmer McKee, Jr.
Defendant
CASE NO. 00- 7827
CIVIL BENCH WARRANT
TO THE SHERIFF OF CUMBERLAND COUNTY:
You are hereby commanded by the Court of Common Pleas of
Cumberland County, Civil Division, to take Wavne Elmer McKee, Jr.
who stands charged in said Court for FAILURE
TO APPEAR IN COURT, and forthwith bring the said person before
the Court. or one of the Judges thereof, to be dealt with
according to the Law.
Wi tness this 21st
day of
June
, A. D., ~2001
Curtis R. Lona
Prothonotary
By: 41'"
.
o InJ4P.. ,
Deputy
ADDRESS:
_617 Al1rnr.=. !=;+r~,::a+
T1rtyh''\r1i=1 ~~(""n, l<'l('\r;n~ ~Jl1q
DOB: S.SEC.#
SEX: M
RACE:
W
HT:
W~.
. .
EYES:
HAIR:
,
., -, ~ - -' - ~
'-.-' -- -- ~- -,- ,,'. -, . . .-- '.
,"-..' .__._----~-~._~ -
'.~~~".,-~ ~
-
-
, .~" -"