HomeMy WebLinkAbout00-08045
--'f~~,lv~~-' ..
,,j.
"' "I",", . L
''-''~;
~ "" it!! <~ ~";--I
~
.
NOV 1 4 2~~
.
KAREN D. JOHNSEN,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CML ACTION-LAW
IN PROTECTION FROM ABUSE
TODD W. ABICHT,
Defendant
NO. m - foilS CIVIL TERM
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. Any protection order granted
by a court may be considered in subsequent proceedings under Title 23 (Domestic Relations) of the Pennsylvania
Consolidated Statutes, including child custody proceedings under Chapter 53 (relating to custody).
A hearing on the matter is scheduled for the ~/l.J., day of ?vz~N 2000, atlacpm., in
Courtroom / at the Cumberland County Courthouse, Pennsy vania.
You MUST obey the Order that is attached until it is modified or terminated by the court after notice and
hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a
charge of indirect criminal contempt which is punishable by a fme of up to $1,000.00 and/or up to six months
in jail under 23 Pa.C.S. ~ 6114. Violation may also subject you to prosecution and criminal penalties under the
Pennsylvania Crimes Code. Under federal law, 18 U.S.C. g 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. ~g 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
(717) 249-3166
"', co,-'
"
'-~ "
"
~' j ,- ,",~", ~..:.--
ft.,;
KAREND. JOHNSEN,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
TODD W. ABICHT,
Defendant
NO. ~. Jb'l~
CIVIL TERM
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name: Todd W. Abicht
Defendant's Date of Birtl1: 11/23/57
Defendant's Social Security Number: Unknown
Names of All Protected Persons, including Plaintiff: Karen D. Johnsen
AND NOW, this It.! KdaYOf N-o \1(' .--.~t.J, 2000, upon consideration of tl1e attached Petition for
Protection From Abuse, the'COUrt hereby enters the following Temporary Order:
[X] 1. Defendant shall not abuse, harass, stalk or tlrreaten Karen Johnsen in any place where she might be found.
[X] 2. Defendant is excluded frorn any permanent or temporary residence where Plaintiff may live.
[X] 3. Defendant is prohibited from having ANY CONTACT with Plaintiff at any location, including but not
limited to any contact at Plaintiff's school, business, or place of employrnent.
[X] 4. Defendant shall not contact Plaintiff by telephone or by any other rneans, including through tl1ird
persons.
[] 5. Pending the outcome of tl1e fInal hearing in this matter, Plaintiff is awarded ternporary custody of tl1e
following minor child:
[] 6. Defendant shall in1mediately relinquish tl1e following weapons to tl1e Sheriff's Office or a designated
local law enforcement agency for delivery to the Sheriff's offIce:
Defendant is prohibited frorn possessing, transferring or acquiring any otl1er weapons for tl1e duration
of this order.
[X] 7. T
laintiff shall bep mitted to return 0 Defendant's reside eat 135 North 1'( Street, ~p Hill,
P sylvania, for ill urpose of retri ing her personal bel gings, inclu' , but not' ited to,
her thing, compute and medical an fmancial files. PI' 'ff may retrie tl1ese ite s at any
time 0 ovemberl4,2 O. Thereafter, aintiffmayreturnt eresidence a date dtin1e
rz. \\~JV) d Vl t !> ~e.( not d z.""'~~7 <QJ oti,CJ......,LS,~ ~ ~f~C.'C? fe..,
rtz e.. V;? L L J Zrll J PI::> I "i 1/,:; f'p po tjll\ ~ IS foS.SC?S5/"<J'>,
y""""",",'
,;:
"
~'~).
to be agreed upon by the parties, through counsel.
[X] 8. A certified copy of this Order shall be provided to the police department where Plaintiff resides and
any other agency specified hereafter; Can1p Hill Police Department.
[] 9. THIS ORDER SUPERSEDES ANY PRIOR ORDER RELATING TO CHILD CUSTODY.
[X] 10. THIS ORDER APPLIES IMMEDIA TEL Y TO DEFENDANT AND SHALL REMAIN IN EFFECT
UNTIL 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 crin1ina1
contempt, which is punishable by a fme of up to $1,000.00 and/or up to six months in jail. 23 Pa.C.S g 6114.
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. g 6113.
Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under
the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18
U.S.C. gg 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 of this 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 of Indirect Crin1ina1 Contempt.
An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or
not the violation is committed in the presence of law enforcernent.
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 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 rnade the arrest.
cD ~
('...; 7"
5
('.J ...-.....<
(";-;z
~rr.: ---.-J o:,--r'"
r C]~
.~-, ;f{~
...iZ
:~" cr:z
.~ :......iLLJ
C ':DC!..
:~S ;; a
~i{y i.a0 - I J;L{/60
);'1-~ ~ m:J.~ -i6 i>s-P
h" 'LcL ...J.o Co j:) /I/''''!Cf'5
'>-
0::
;::f
c',
~~r:
t-.:> 0". I""' . 2-00'0
Date .
(';1
"/14/00
-U.'
, " L ,I ,,; ,
^'''''~'''-:
KAREN D. JOHNSEN,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
TODD W. ABICHT,
Defendant
NO. lJ1)" ~,+-i CIVIL TERM
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiff's narne is: Karen D. Johnsen
2. I am filing this Petition on behalf of myself.
3. N arne of person, including Plaintiff, who seeks protection from abuse:
Karen D. Johnsen
4. Plaintiff's address is: Confidential
5. Defendant is believed to live at the following address:
135 North 21 sl Street, Camp Hill, P A 17011
Defendant's Social Security Number is: Unknown
Defendant's date of birth is: 11/23/57
Defendant's place of ernployrnent is: Unemployed
6. Indicate the relationship between Plaintiff and Defendant.
[] Spouse [X] Current/former sexual/intimate partner
[] Ex-spouse [] Parent/child
[] Persons who live or have lived like spouses [] Other relationship by blood/rnarriage
[] Parents of the same child
7. Plaintiff and Defendant have not been involved in prior divorce, custody, support or protection from
abuse actions.
8. Upon information and belief, Defendant has been charged with assault and rnaking terroristic threats
against the Plaintiff. The Pre1iminary Hearing for this matter is scheduled Wednesday, Novernber 15,
2000, at 9:00 a.m. in front of District Justice Manlove.
9. Plaintiff and Defendant are the parents of the following minor child: None.
10. If Plaintiff and Defendant are parents of a minor child together, is there an existing court Order
regarding their custody? N/A.
11. The following other minor child/ren presently live with Plaintiff: None
12. The facts of the most recent incident of abuse are as follows:
On Tuesday morning, November 7, 2000 Defendant punched the Plaintiff in the nose at least three tin1es,
and caused severe bleeding. The Plaintiff left fue house at that point. The Plaintiff returned to the home, but
:-' ~~,
L
-WfJ:[;i\.",W"
Defendant had locked the Plaintiff out of the home. When Defendant allowed Plaintiff back into the home he
grabbed ~e ~laintiff by the shoulders and banged her head against the wall, causing her glasses to fly off of her
face. Plaml1ff grabbed her.gl~sses, and ~e Defendant told her to "give rne the goddarnned glasses." The
Defendant gra?bed the Plaml1ff by the shirt and threw her to the floor, where he began banging her head
repeatedly agamst the floor. The Defendant stuck his knee into the Plaintiff's rib cage, and choked her. The
Defendant told her that he would kill the Plaintiff if he had to in order to get the glasses back. Plaintiff released
her gl~sses, left ~e .home, and ran tothe Police Station. When no one at the police station responded to her
knocking, the Plarnl1ff returned to the house. Defendant then told the Plaintiff that he would kill her if she went
to the police. This incident lasted about half an hour.
The next day, Plaintiff went to the emergency room at Holy Spirit Hospital in Can1p Hill. Her face was
swollen and bruised. The x-ray of her face showed a crack across the bridge of her nose. The doctors also
conducted a cat scan of her abdornen because there was a lot of blood in her urine. The cat scan showed a spot
on her liver which the doctor believed may have been caused by the abuse.
13. Defendant has committed prior acts of abuse against Plaintiff, as follows:
Defendant slapped the Plaintiff in the face in July 2000. Since that time the Defendant has hit the plaintiff
approximately 7 or 8 times, with each incident getting more severe. In mid-Septernber, 2000, Defendant becarne
angry with the Plaintiff and shoved her against a metal railing causing a cut to her face and head. On October
31, 2000, Defendant hit the Plaintiff in the face, causing swelling and bruising.
14. List the weapon(s) that Defendant has used or threatened to use against Plaintiff or the minor child/ren:
None.
15. Identify the police department or law enforcement agency in the area in which Plaintiff lives that should
be provided with a copy of the protection order: Carnp Hill Police Department
16. There is an immediate and present danger of further abuse from the Defendant.
CHECK THE FOLLOWING BOXES ONLY IF THEY APPLY TO YOUR CASE AND PROVIDE
THE REQUESTED INFORMATION
[X] Plaintiff is asking the court to exclude the Defendant from any residence where the Plaintiff might
be found. Plaintiff is currently in hiding. Her residence is, therefore, confidential.
[] rented by (list all nan1es, if known):
[] Defendant owes a duty of support to Plaintiff and/or the minor children.
[X] Plaintiff has suffered out-of-pocket frnanciallosses as a result of the abuse described above. Those
losses are: Lodging and medical expenses, in an arnount to be determined.
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:
[X] A. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff in any place where Plaintiff
may be found.
[X] B. Exclude Defendant from Plaintiff's residence and prohibit Defendant from atternpting to enter any
temporary or permanent residence of the Plaintiff.
[] C. Require Defendant to provide Plaintiff and/or minor child/ren with other suitable housing.
[] D. Award Plaintiff temporary custody of the minor child and place the following restrictions on contact
between Defendant and child:
~
'0"
.,-
" J' J ~'
"
='<""-1/jN!"'::'
[X] E. Prohibit Defendant from having any contact with Plaintiff 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 ernployment.
[] F. Prohibit Defendant from having any contact with Plaintiff's relatives and Plaintiff's children listed in
this Petition, except as the court may fmd necessary with respect to partial custody and/or visitation
with the minor child.
[] G. Order the Defendant to ternporarily turn over weapons to the Sheriff for this County and prohibit
Defendant from transferring, acquiring or possessing any such weapons for the duration of the Order.
[] H. Order Defendant to pay temporary support for Plaintiff and/or the rninor child/ren, including rnedical
support and [] payment of the rent or rnortgage on the residence.
[X] 1. Direct Defendant to pay Plaintiff for the reasonable fmanciallosses suffered as the result of the abuse,
to be determined at the hearing.
[X] J. Order Defendant to pay the costs of this action, including fIling and service fees.
[] K. Order Defendant to pay Plaintiff's reasonable attorney's fees.
[X] 1. Order the following additional relief, not listed above:
Plaintiff shall be permitted to return to Defendant's residence for the purpose of retrieving her personal
belongings, including, but not lin1ited to, clothing, her computer, medical and fmancial records.
Defendant is in jail until at least November 15, 2000, therefore, Plaintiff requests that she be permitted
to return to Defendant's residence to retrieve her belongings at any time on November 14, 2000.
Thereafter, Plaintiff requests the ability to return to the residence at a date and time to be agreed upon
by the parties, through counsel.
[X] M. Grant such relief as the court deems appropriate.
[X] N. 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 Plaintiff will inform the designated authority of
any addresses, other than Defendant's residence, where Defendant can be served.
II II.( 00
Date
ILare- -:;; ~ I-ru--.J
Kara 1. Kurtzman r
Certified Legal Intern
,,;d.M~d
ROBERT E. RAINS
Supervising Attorneys
TERI 1. HENNING
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
:,;~I ~
.
I~,
, .
'~ "-- , , -~ ' ^" 'l:.::wr:
VERIFICATION
Understanding that tl1e making of any false staternent would subject rne to tl1e penalties of 18 Pa.C.S ~ 4904,
I verify that I am the Plaintiff in tl1e present action, and that the facts and staternents contained in the above
Petition are true and correct, to tl1e best of my knowledge, information and belief.
III 1~11"'ll')
~
&,~,~./L~-"")
Karen Jo sen
,.,__~_J
~
.
. -1%
KAREN D. JOHNSEN,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
TODD W. ABICHT,
Defendant
NO.
CIVIL TERM
FINAL ORDER OF COURT
Defendant's Name: Todd W. Abicht
Defendant's Date of Birth: 11/23/57
Defendant's Social Security Number: Unknown
Names of All Protected Persons, including Plaintiff: Karen D. Johnsen
AND NOW, this day of , 2000, the court having jurisdiction over the parties and
the subject-matter, it is ORDERED, ADJUDICATED and DECREED as follows:
Note: Space is provided to allow for 1) the court's general findings of abuse; 2) inclusion of the
terms under which the order was entered (e.g., that the order was entered with the consent of the parties, or
that the defendant, though properly served, failed to appear for the hearing, or the reasons why plaintiff's
request for a final PFA order was denied); and/or 3) information that may be helpful to law enforcement
(e.g., whether a weapon was involved in the incident of abuse and/or whether the defendant is believed to be
armed and dangerous).
[] Plaintiff's request for a [mal protection order is denied. OR
[] Plaintiff's request for a [mal 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.
Defendant is completely evicted and excluded from the residence at 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.
[] 2.
--::'1
.....
j,
~ c
-1'
, -~
"'- (a:it'
[] On .' Defendant may .en~er the residence to retrieve his/her clothing and other personal
effects, provided that Defendant IS m the company of a law enforcement officer when such retrieval is
made.
[] 3. Except as provided in Paragraph 5 of this Order, Defendant is prohibited from having ANY
CONTACT with the Plaintiff at any location, including but not limited to any contact at the
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:
[] 4. Except as provided in Paragraph 5 of this Order, Defendant shall not contact the Plaintiff by
telephone or by any other means, including through third persons.
[] 5. Custody of the minor children, [names of the children subject to the provision of this paragraph] shall
be as follows: [state to whom primary physical custody awarded; state terms of partial custody or
visitation, if any.]
[] 6. Defendant shall immediately turn over to the Sheriff's Office, or to a local law enforcement agency
for delivery to the Sheriff's Office, the following weapons used or threatened to be used by Defendant
in an act of abuse against Plaintiff and/or the minor child/ren.
[] 7. Defendant is prohibited from possessing, transferring or acquiring any other weapons for the duration
of this order. Any weapons delivered to the sheriff under paragraph 6 of this Order or under
Paragraph 6 of the Temporary Order shall not be returned until further order of court.
[] 8. The following additional relief is granted as authorized by ~ 6108 of the Act:
[] 9. Defendant is directed to pay temporary support for: [insert the names of the persons for whom
support is to be paid] as. follows: [insert amount, frequency and other terms and conditions of the
support order]. This order for support shall remain in effect until a fmal support order is entered by
this Court. However, this order shall lapse automatically if the Plaintiff does not ftle a complaint for
support with the court within fifteen days of the date of this order. The amount of this temporary
order does not necessarily reflect Defendant's correct support obligation, which shall be determined in
accordance with the guidelines at the support hearing. Any adjustments in the fmal amount of support
shall be credited, retroactive to this date, to the appropriate party.
[] 10. The costs of this action are waived as to the Plaintiff and imposed on Defendant.
[] 11. [] Defendant shall pay $
as follows:
to Plaintiff as compensation for Plaintiff's out-of-pocket losses, which are
OR
[] Plaintiff is granted leave to present a petition, with appropriate notice to Defendant, to [insert the
name of the judge or court to which the petition should be presented] requesting recovery of out-of-
pocket losses. The petition shall include an exhibit itemizing all claimed out-of-pocket losses, copies
of all bills and estimates of repair, and an order scheduling a hearing. NO fee shall be required by
the Prothonotary's office for the ftling of this petition.
BRADY INDICATOR.
[] 12.
[] 1.
The Plaintiff or protected person(s) is a spouse, former spouse, a person who cohabitates or has
cohabitated with the Defendant, a parent of a common child, a child of that person, or a child of the
~ .
..J.:-
,- ' "~ L
--;
- -, wr.1 ,t_ '-~m,,:;
Defendant.
[] 2.
This order is being entered after a hearing of which the Defendant received actual notice and had an
opportunity to be heard.
Paragraph I of this Order has been checked to restrain the Defendant from harassing, stalking or
threatening Plaintiff or protected person(s). '
Defendant represents a credible threat to the physical safety of the Plaintiff or other protected
person(s) OR
[] 3.
[] 4.
The terms of this Order prohibit Defendant from using, attempting to use, or threatening to use
physical force against the Plaintiff or protected person that would reasonably be expected to cause
bodily injury.
[] 13. THIS ORDER SUPERSEDES [] ANY PRIOR PFA ORDER AND [] ANY PRIOR ORDER
RELATING TO CHILD CUSTODY.
[]
14. All provisions of this order shall expire in one year, on [insert expiration date].
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 $1,000.00
AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S. ~ 6114. VIOLATION 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. ~~ 2261-2262. 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. ~~ 2261 -2262. IF
PARAGRAPH 12 OF THIS ORDER HAS BEEN CHECKED, YOU MAYBE 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 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 7 of this order may be without warrant, based solely on probable cause, whether or not
the violation is committed in the presence of the police. 23 Pa.C.S. ~ 6113.
Subsequent to an 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 [insert the appropriate name or
title] shall maintain possession of the weapons until further order of this court. When the defendant is placed
under arrest for violation of the 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.
,_,.' I
.'-
. .
. '. -~'-
~~ .. ~,'~""'-~.;
.
.
.
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:
Date
Judge
If entered pursuant to the consent of the plaintiff and defendant:
Karen D. Johnsen
Todd W. Abicht
"'~~"'~'li~;;&~4~J0m.i..'ii>"""'~"~~''';:h.~*,t@'it.~U<Jj,Mf~;ft\lS!illiu.iI1l.~'~ ''"'.....ati!l!!i~~_~~~~.
e. ~.
~ , w_
~ g
-"""",,,~,-'- lIIil~' ~""-~
(")
c-
....~
_ dr--.
11'/1"'_::::
?i:x;'
CIS r;:
-,...,~,-
r.::c;:::;,--
~:::::'-~'
f::c:
<:;;:::()
"'"c:::
:c
::<
'j
.
.
a
o
P5
",.-
C)
-,.,
.;CO
~;J
(.1
:..h!
=-::1
~~
."\)
<.v
......
-l
~ 1-
- ,'--<-~'~~"-
,-. "'l~~'
.1l/M/00 WE 14: 51 FAX 717 240 6573
CUMB CO PROTHONOTARY
1i!I00l
***************************
*** lllULTI TN REPORT ***
***************************
TX/RX NO
INCOMPLETE TXlRX
TRANSACTION OK
2283
01]9p2405331
04]92490779
CENTRAL PROCESS
PSP
ERROR
,
OFFICE OF THE PROIHCX\OrARY
CUMBERLAND o::uNrY <XlUR'ffiCOSE
ONe cctlRTliOOSE SQUARE
CARLtSLE, PA. 17013-3387
(717) 240-6195
FAx (717) 240-6573
VIA TELECOPIER
tertrzJ p(oce:ss\~
TO: PA STATE POLICE
FAX ~:
7l7~249-0779
"'
~: CURTIS R. LONG
RE: PPA ORDERs
MESSAGE:
-.~
~
00. OF PAGES (INCr..uoING COVER SHEET)
This ~ is i.!<lbd!U. rnly fi::;r tte \a; r1 tte :iIrlivid.el a: ffitity to Wrid1 is is ..Ih.~. ad iTBY
o::ntain :inl'i:iI1n:lt. ttBt: is p:ivi.IEg:rl. anfilhttial a:rl ~ funt r1i....,cetre I.J'd:r: "IT" iNhlp liw. ff
tI'E m:rler' of this ~ is rot tiE inta"drl =ipiEnt. }'OJ are l'"erEtv rotifie:l ttet tro/ dis!J;miret.ia1,
distr:ilubJ:ro cr awio;! of this o.::nm..nkat;m is st:J:ictly px:ttibita:l. If}'OJ h:iI.e ra::ei-..e:l IJu.5
CDIYI'U1:if,~::im in eznr, pla;rse ratify lB innaiiately q. tElqh:m a"d IeWm tie a:igiraJ. ~ ID us al
tte ihk' a::l:b:eas via tte ~!.s. p::6tal ~ire. 'Il'mk )0.1.
, d ,," ,,~___ __, , 'n_'
'.,--
'~,;:' L"_"~,,,_~,;,, "0" ,. '-,- ;,,_"
~,~~"~ .~-t'--J"~E,,1.--{--''''';- ,"',;,'"--' _,,,"'_
.-_.".-
.<
.-
KAREND. JOHNSEN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY , PENNSYLVANIA :
J,{')/
wyJ
.'1
CML ACTION-LAW
IN PROTECTION FROM ABUSE
v.
TODD W. ABICHT,
Defendant
NO. 00-8045
CIVIL TERM
FINAL ORDER OF COURT
Defendant's Name: Todd W. Abicht
Defendant's Date of Birth: 11/23/57
Defendant's Social Security Number: \ 'b"1 Y'i5 '100::'
Names of All Protected Persons, including Plaintiff: Karen D. Johnsen
AND NOW, this 22 71day of IJ" v&. ~}, 2000, the court having jurisdiction over
the parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows:
Pursuant to the consent of the parties, the following order will be entered:
1. Plaintiff's request for a fmal protection order is granted.
2. Defendant shall not abuse, stalk, harass, threaten the Plaintiff at any location where she
might be found.
3. Defendant shall continue to reside in the residence located at 135 North 21 st Street,
Camp Hill, Cumberland County Pennsylvania. Defendant shall provide to Plaintiff
developed pictures relating to her mother's funeral service and the visit with her friend,
Carmen. These pictures shall be delivered to 45 North Pitt Street, Carlisle, PA 17013
no later than December 1, 2000.
4. Defendant is prohibited from having ANY CONTACT with the Plaintiff at any
location, including, but not limited to, any contact at Plaintiff's residence,
"
.~<-- ;,L ,',,,,,,,- .-.-" ,<".,- ".;-, ,-c"_ ,.. . ,,,,,_'
~:',' . ,-,,,':,,,;:'---;',~"-;',k-,,>.;-; .~-~",:L'~_~,- -,,:; ,'-",----i -~, __\i.;;; ,\~-', ':,<'-::;-:ii:"''';-' ";,,, -~'"-".,,,;' _~
, ;-,;;;-~.j
business, or place of employment.
5. Defendant shall not contact the Plaintiff by telephone or by any other means, including
through third persons.
6. Defendant is prohibited from possessing, transferring or acquiring any weapons for the
duration of this order.
7.
The costs of this action are waived as to the Plaintiff and imposed o~Defendant.
\=('0'" Dek<.J"d.<>^+ "\'v 0/<
Plaintiff waives any right to reimbursement"for hotel and medical exp-<enses incurred
8.
from 11/7/00 to the present. Defendant waives any and all claims relating to the bank
accounts at Waypoint Bank, held jointly in plaintiff and defendant's names, closed as of
11/17/00.
9. A certified copy of this Order shall be provided to the Camp Hill Police Department.
10. This Order supercedes any prior PFA Order.
11. This Order applies immediately to Defendant and shall remain in effect for eighteen
months.
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 $1,000.00 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23
PA.C.S. ~ 6114. VIOLATION 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. ~2265. 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. ~~ 2261 -2262.
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.
. .~.' ~.~
~.~'. -.
.' ~-,. '
L:,," 1;1- s". :'-.-i~ k<:" .~,~"" c',,,,' "'-'~~-'~":ci"~,,,:;-~~,-,,;';';",~;':'i;:,;;-;i,C',~(:C"i' .," <D h -,
'-I
.
An arrest for violation of Paragraphs 1 through 6 of this order may be without warrant, based
solely on probable cause, whether or not the violation is committed in the presence of the
police. 23 Pa.C.S. ~ 6113.
Subsequent to an 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
Police Department shall maintain possession of the weapons until further order of this Court.
When the defendant is placed under arrest for violation of the 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:
.fu-ov. ) Z ] b';:>.:l
,
Date
If entered pursuant to the consent of the plaintiff and defendant:
~O""'\~AL'lO-,^ }
Karen D. Johnsen, Plaintiff
J~AI~
Todd W. Abicht, Defendant
~;-'~ l7J1)~/
Andrew 1. orrow
:~g.z=,v-
Th . Place I
Robert Rains
Teri Henning C~\U
Supervising Attorneys
~
.
R. Mark Thomas
101 South Market Street
Mechanicsburg, PA 17055
(717) 796-2100
Counsel for Defendant
f'\~ ~ M. ~'
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Counsel for Plaintiff
CG'0~
~
~:~T&JNnl\i Cjl\)et-J ~ \.e,\\,~ +\-ewW\() f2
8{)Ju)
1iI'....
~::."i~~ --li :.....,.;,' v-
.
m'
"
,i-,
~"""'-"i~W~JM '-~-if~~@i .
@~
x
~ ~
~ ~
.-. ",~ , -, ..
~<l
[":)
-cJ
.
t
:d
cP
-d
~
~
'g
-:::s:2
.,..-:)
"'1/
-I
(<:>
..,
:'-.
~ 2?
--() 3
lJ
f
:TJ
~
-d
S;;
.
"",
~" ~
" '-,'~- :-,--
.....".'h.".
-
o
c;::
~-o~
~?(.
2,J ;'-_)
~,; ~~, ':. h,~
-<----'-
r...::c.-
~~c.
"'~-- {-.
S> c:: "'_:
::s ,'~,j
-< "1_
-,
-11/22/00
WED 14:54 FAX 717 240 6573
TX/RX NO
INCOMPLETE TX/RX
TRANSACTION OK
h'RROR
****$*****$$***************
*M MULTI TN REPORT ***
***************************
CUMB CO PROTHONOTARY
1i1J00l
2304
[ 01]9p2405331
[ 04] 92490779
CENTRAL PROCESS
PSP
,
OFFICE OF THE PROIliONOTARY
CU1BERLAND a::uNTY COUR'lHOOSE
ONE CXXJRTHOOSE 9JUARE
CARLISLE, PA. 17013-3367
(717) 240-6195
FAX (717) 240-6573
VIA'l'E:LECOPIER
TO:
c.- p..
PA STATE POLICE
FAX II:
717~249-0779
PRCM:
CtlllTIS R. LONG
RE,
PFA ORDElls
MESSAGE:
~-L /10. Of PAGES
(INCLUOING COVER SHEE'l'l
This " --3" is :U It.. CW mly :fi:r l:I'e tEe of t:re irdividal at' altity 10 W'l:id1 is is aU.~. arl,rey
antain infumatiI::n tret is ~. =t\::ide'rt:ial. ad ~ fron ro=-l""'",,= ud& "fPlireh1" laN. rf
tI-e ~ of this ~ is rot tI-e inl:e'rl;d tocipie:nt. }Ol are t'el:'Et.y roti.fiI;d th3t mj di$emira~.
dlstril:J..tt:i <r a:w.ir9 of this a:mTUlicabcn i8 std.ct:ly p:ctribilBi. If y:J.I l"ac<e tID2.i\Ed tIuB
.. -,- -"'~ ;n o>n:<:c. ~ n::ti:fy l.S .irnrediately W tele!;h:re ad return tie 00giml.. "g> 1J:ll.S al
..... ~.- ~_.
-,- o'
.~. . ".
~~, '",~ -" ,,,,,.
.. c ",,,
.. --",~"~'k~'4;;;";-,,h".-,~
~ -, ~.'- -~,,-.--. -- 00"-'-' ,_-,t,"': ", "'~'-i",";;:~~,~,;,,,,,-,, - .
'-'''fil
I:
c
c
I
~'
I
I
Ij
..,-' - ~
KAREN D. JOHNSEN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION- LAW
IN PROTECTION FROM ABUSE
TODD W. ABICHT,
Defendant
NO. 00-8045
CIVIL TERM
AGREEMENT AND ORDER
1. Plaintiff and Defendant reached a consent agreement in the above captioned Protection
From Abuse action, which was made an Order of Court on November 22, 2000 ("Final Order of
ii
~~
;~
Court"). .
2. The November 22, 2000 Final Order of Court is in effect for eighteen months, until
(;1
May 22, 2002.
[1'
,
I;:
"
3. Paragraph eight of the November 22,2000 Final Order ofC~ provides that
~.-o("\ De..~er-o\.a----\' /\\/:l.if
plaintiff waives any right to reimbursemenffor hotel and medical exp&ses incurred as a result
I;,
l"
l!
ii.
io
!~
of the alleged abuse, and defendant waives any clainls relatiog to the bank accounts at
!,.
Waypoint Bank, held jointly in plaintiff and defendant's names, closed as of 11/17/00.
4. Plaintiff and defendant agree that paragraph eight of the November 22, 2000 Final
Order of Court shall remain in effect beyond the expiration of the PF A Order, and intend that this
Agreement be entered as an Order of Court.
Date:~
Date:
(1!-z.2-( 6 0
0Yn'O~J~
Karen Johnsen, Plaintiff
J,/L,,:~
Todd Abicht, Defendant
',-" ',' -~,' -'
"__, -~ '-. 'r_'.-
-',"', ,~,- , <"
, k""c"I" .,'.-~, ~--,\/>.,," - -'.'~' ,<- ," :'.,,">\i,;,0,,:,',,~...,,; ,+.,,-<;..'ki~'~'~'-;"'.:,'~'"'<-" < .;-.- _,_ ."
':,
iN
(itJro~ ~ fJ1!~
Andrew 1. Morrow
Certified Legal Intern
:l~
:1'
G\~ L /~
Tho Place
Robert Rains
Teri Henning
Supervising Attorneys
R. Mark Thomas
101 South Market Street
Mechanicsburg, PA 17055
(717) 796-2100
Counsel for Defendant
;>
,!
:r
;:.
i
T'
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
(717) 243-2968
Counsel for Plaintiff
\:
1\
!?
r
ORDER OF COURT
AND NOW, this 22-,..., 1 day of November, 2000, the foregoing Agreement
~
<
r
L
(;;
;;
),'
Ii
,
l"
i.
I,
Ii
Ii
11
I
~,
is entered as an Order of Court.
BY THE COURT:
,,___,J
.,~~-
-
.
, '
~"
fIli"
.
~.. ~ ,,-~ '"~ "
SHERIFF'S RETURN - REGULAR
CASE NO: 2000-08045 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
JOHNSEN KAREN D
VS
ABICHT TODD W
CPL. MICHAEL BARRICK
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE
was served upon
ABICHT TODD W
the
DEFENDANT
, at 0016:55 HOURS, on the 14th day of November, 2000
at CUMBERLAND COUNTY PRISON
1101 CLAREMONT RD
CARLILSLE, PA 17013
by handing to
TODD W. ALBICHT
a true and attested copy of PROTECTION FROM ABUSE
together with
NOTICE OF HEARING & ORDER, TEMPORARY
PROTECTION FROM ABUSE ORDER, PETITION
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
3.10
.00
10.00
.00
31.10
'0 ;;~~~
R. Thomas Kline
me this /~
day of
11/15/2000
~
/'
. "_/",, '- ___~",c
BY.:/ Deputy .e /
Sworn and Subscribed to before
.l..
.~'
~-'~ .-r ,'1';.
JAN 2 4 2001'1\')
KAREN D. JOHNSEN,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: CIVIL ACTION-LAW
: IN PROTECTION FROM ABUSE
TODD W. ABICHT,
Defendant
: NO. 00-8045
CIVIL TERM
ORDER OF COURT
AND NOW, this 1.5 ft day of:J 2f7\ \p r2001, upon consideration of the attached
Petition to Vacate Order, it is hereby ordered that:
1. The Final Order of Court for Protection from Abuse dated November 22,2000, is
vacated, without prejudice.
3m.2S )Go/
Date )
Copy qr~ --10 Am,ry i~ec)
.I..~'al~ ~
):"a"~cl Col Y '-io PSP ~ @..y.J~ ( YRc.x:sg;f~
Copy rm. l L<uc --/-0 JJ~ .
0 C)
C
;::: r~
-oC1.:.' .~..~
\Tl cr, "':.- ~J
Z'~J N '--1
~r;. 0' ;.-~ '
"'-.-,. \,~'-(~;
,<..., -'-,'-' ''',
r::o ::po. ~
'< -.' ~~2 .,,)
:;;(; -~ f.f,\
~~ '2 ~
N ?
..,.. :Q.
=< ,'"
,. I
'M"",,~' .'1 ~ .. ~,~, "I"~
. '
KAREND. JOHNSEN,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: CML ACTION-LAW
: IN PROTECTION FROM ABUSE
TODD W. ABICHT,
Defendant
: NO. 00-8045
CIVIL TERM
PETITION TO VACATE ORDER
Petitioner, Karen Johnsen, through her attorneys, the Family Law Clinic, hereby moves to
vacate, without prejudice, the following: Final Order of Court dated November 22, 2000. In
support of her petition, Karen Johnsen states the following:
1. Petitioner, through the Family Law Clinic, filed a Petition for Protection From Abuse on
November 14, 2000 with this Court.
2. A Temporary Protection From Abuse Order was entered November 14, 2000, signed by
the Honorable Wesley Oler, Jr.
3. A hearing on the Petition for Protection From Abuse was scheduled for November 22,
2000 at 1:30 p.m. in Courtroom 1.
4. On November 22,2000 the parties reached a Consent Agreement, and a Final Order of
Court was entered. A true and correct copy of the November 22, 2000 Order is attached
as Exhibit "A".
5. Petitioner now wishes to vacate the Order entered on November 22,2000.
6. To that end, Petitioner has signed a document, verifying that she desires the Order to be
vacated. A true and correct copy of Petitioner's Instruction to Petition the Court to
Vacate the Protection from Abuse Order is attached as Exhibit "B".
, l.
.
. .
7. Counsel for Petitioner contacted Counsel for Defendant, Mark Thomas, to request his
concurrence with this Petition. Mr. Thomas concurred.
WHEREFORE, Petitioner requests that the court vacate, without prejudice, the Final
Order entered November 22, 2000.
II Vii ff1
Date
~~.~ ~
Kara I. Kurtzrifan
Certified Legal Intern
0-L~
THOMAS M. PLACE
ROBERT E. RAINS
TERI L. HENNING
Supervising Attorneys
FAMILY LAW CLINIC
45 N. Pitt. St.
Carlisle, PA 17013
717/243.2968
Attorneys for Karen Johnsen
:0.. I
.
^ ,~ '" I
, .
, (,I
I
~ ' j (.
VERIFICATION
Understanding that the making of any false statement would subject me to the penalties
of 18 Pa.C.S ~ 4904, I verify that I am the Plaintiff in the present action, and that the facts and
statements contained in the above Petition are true and correct, to the best of my koowledge,
information and belief.
da,qOI
~
~o.~
Karen Johnsen
~~~~~~,~"","~~--"~~c-,-y,;,,*Fi;,;.:rc,~~A'-:!J'l;;\Mrn,~lii~llIiilll~~li.li{tl'n'
-
~M1 41~"'~
,~
R,
"
g 0 r,
.:.:n
t- .,
..". c~,~
4JC.::l '>:>'"
rnfTl ;;e
Z:::o N
t;"
Z ~ ~ ~::?6
(f.l: ot'"___
25 ..., :~'~~~,
"'- -". ~C)
?;L) ~. .,r,;-ffl
=0 N S
J>-C .. ~
~ N
.r:'
i\'
1- ,
. -"-~:~:'_'H'~: -~ ,.,'..,.',.~. '
.!L'.
""f"~ 'iu-' "('''-.- ,
, ,-,~' ,
, ::~-'
(
KAREN D. JOHNSEN,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA:
v.
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
TODD W. ABICHT,
Defendant
NO. 00-8045
CIVIL TERM
FINAL ORDER OF COURT
Defendant's Name: Todd W. Abicht
Defendant's Date of Birth: 11/23/57
Defendant's Social Security Number: \ 'b I Y '6 ~ 00 3
Names of All Protected Persons, including Plaintiff: Karen D. Johnsen
AND NOW, this 22 .,cLday of ~ 2000, the court having jurisdiction over
the parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows:
Pursuant to the consent of the parties, the following order will be entered:
1. Plaintiff's request for a final protection order is granted.
2. Defendant shall not abuse, stalk, harass, threaten the Plaintiff at any location where she
~
might be found.
3. Defendant shall continue to reside in the residence located at 135 North 21st Street,
Camp Hill, Cumberland County Pennsylvania. Defendant shall provide to Plaintiff
developed pictures relating to her mother's funeral service and the visit with her friend,
Carmen. These pictures shall be delivered to 45 North Pitt Street, Carlisle, PA 17013
no later than December 1, 2000.
4. Defendant is prohibited from having ANY CONTACT with the Plaintiff at any
location, including, but not limited to, any contact at Plaintiff's residence,
/3dll.b/t f(
,': ~,I--,: ,':-"1'.__, ..: >In --"'&
lTL' "''''''f'x'~'''-''''-r "-~(i''''
("
,
business, or place of employment.
5.' Defendant shall not contact the Plaintiff by telephone or by any other means, inclUding
through third persons.
6. Defendant is prohibited from possessing, transferring or acquiring any weapons for the
duration of this order.
7.
The costs of this action are waived as to the Plaintiff and imposed o~Defendant.
~('o..... 'Dek<^cl."",,+ 'i\.. .t<
Plaintiff waives any right to reimbursemenf'for hotel and medical expbnses incurred
8.
from 11/7/00 to the present. Defendant waives any and all claims relating to the bank
accounts at Waypoint Bank, held jointly in plaintiff and defendant's names, closed as of
11117/00.
9. A certified copy of this Order shall be provided to the Camp Hill Police Department.
10.' This Order supercedes any prior PFA Order.
11. This Order applies immediately to Defendant and shall remain in effect for eighteen
months.
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 $1,000.00 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 (50) STATES, THE DISTRICT OF COLUMBIA,
TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO
RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. ~2265. IF YOU
TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER
YOU MAYBE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT
ACT. 18 U.S.c. ~~ 2261 -2262.
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.
,
, ,
.'~~
.-', .<.'
- ,~ 11
r'"
!
An arrest for violation of Paragraphs 1 through 6 of this order may be without warrant, based
solely on probable cause, whether or not the violation is committed in the presence of the
police. 23 Pa.C.S. ~ 6113.
Subsequent to an 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
Police Department shall maintain possession of the weapons until further order of this Court.
When the defendant is placed under arrest for violation of the 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:
$\.Jo v ') 2 ] D;> J
Date .
If entered pursuant to the consent of the plaintiff and defendant:
~......k-LL\"'" }
Karen D. Johnsen, Plaintiff
J~&~
Todd W. Abicht, Defendant
~L"'> ~ h11 J</YV11t/
Andrew J. orrow
Certified Legal Intern 1 _
0~ L i\ /
Th Place / v
Robert Rains
Teri Henning
Supervising Attorneys
~
R. Mark Thomas
101 South Market Street
Mechanicsburg, PA 17055
(717) 796-2100
Counsel for Defendant
THE F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Counsel for Plaintiff
TRUE COPY'FAOM RECORD
In TestImony*h8I'8Ofi I bereWIfJ,*myhana
and tile . said CartIsII.
~ i,
.'
.
, -.'
, ~
,.
''''~
I fJ~.1C
" '"
Instruction to Petition the Court to Vacate the Protection from Abuse Order
I have informed the Family Law Clinic that I would like the Protection From Abuse
Order dated November 22,2000 to be vacated.
I understand that this means that Todd Abicht will no longer be prohibited from
contacting me at my residence, my place of employment, or any other location. In addition, I
understand that Todd Abicht can contact me by phone or any other means.
I also understand that this means that the November 22, 2000 Protection From Abuse
Order, prohibiting Todd Abicht from abusing me, will no longer be in effect.
~Ol
Date
~~.~~Q4^~~
Karen Johnsen
/6wJ- J . ~~~=--=::::,
Kara I. Kurtzman---'
Certified Legal Intern
Family Law Clinic
45 North Pitt Street
Carlisle, PA 17013
& K.Jc; bd' 13
.."
.
i_. _-J
'"
l\'~
KAREN D. JOHNSEN,
Plaintiff
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: CIVIL ACTION-LAW
: IN PROTECTION FROM ABUSE
TODD W. ABICHT,
Defendant
: NO. 00-8045
CIVIL TERM
CERTIFICATE OF SERVICE
I, Kara I. Kurtzman, hereby certify that I am serving a true and correct copy of the
Petition to Vacate Order on the following person at tlte following address, by first class mail,
postage prepaid:
Mr. Mark Thomas, Esquire
101 South Market Street
Mechanicsburg, P A 17055
Date -U24\ t)\
~J.~~
Kara I. Kurtzman
Certified Legal Intern
F AMIL Y LAW CLINIC
45 N. Pitt St.
Carlisle, PA 17013
717-243-2968
"- -
~. "I. O' .' '. ,
'~-o ; __ , "_
'-", ~c '" ~;, ,,;,,".;- ,; _.:; "" " ,';, ,': "'" . ~
......
.
DONALD E. KRAMER and
SARAH A. KRAMER,
Plaintiffs
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-8063 CIVIL TERM
DAVID W. HANSEN TRUCKING
and WARD HOMER ELKINS,
Defendants
AGREEMENT ~URSUANT TO RULE 237.2 TO
EXTEND iI1IME TO PLEAD
FOLLOWING TEN-DAY NOTICE
It is agreed that Defendant, David W. Hansen Trucking and Ward Homer Elkins, is
granted an extension of time through Friday, February 23, 2001, in which to file
1.
a complaint.
-1L2.
3.
an answer
an answer or preliminAry objections
After the above date, a judgment of non pros or by defuuh, as may be appropriate, may be
entered upon praecipe without further notice.
Date: J!2-t!Oj
~f
Dale F. Shughart, Jr., Esquire
35 East High Street, Suite 203
Carlisle, PA 17013
(717) 241-4311
Counsel for plaintiff
Date: 1/ 2- S- / f) (
~
100 Pine Street, Suite 260
Harrisburg, P A 17101
(717) 720-0700
Counsel fur Defendants
IOIE ~ ~ MAt
~OOi.iW-I~
!f!l~!tlMI";;'-';:;!I~Ji~m~~"i'ilt~1l;\l1I;Il~llfrj~Oll!"'""t;:':~.-l!l!~~
::, "; .1~
"
'(
i- J
c -,' t '~
,- t
-i ;': ,~.
") ,'.~-,
.,
...
:'"
I,'
~1i~~~_
;',
;';".'
~F
, ~ -,
..-'
I,"
...
>,-
':f.'$
,"
,.;.' ;,
t:
f"
,
'r:'
. ~ >Yj,
, .< \ ~
,'..'
..,
'ii:
-'l"'
,=,
"Ii[j
itllII!il ,~~
-j' ~
..
~";
"
'i. .
'.,'
:,;'1'
".'
,,: 1- ~
.- I ~;
~ih
'..)
.>':
'i
,.,
JAR 2S !IOI
. ~~<
.
...
;;
m
~,.",.!<-....
",-, ~:k__,
" .".,;-~,.,."- 'i,"-:.]__>;",.."
."-'1:-1-
... .
JOHN GERARD DEVLIN & ASSOCIATES, P. C.
JOHN GERARD DEVLIN, ESQUIRE
L D. NO. 32858
HOWARD D. KAUFFMAN, ESQUIRE
I. D. NO. 38963
SUITE 260, 100 PINE STREET
HARRISBURG, PA 17101
(717) 120-0700
ATTORNEY FOR:
Defendant, David W. Hansen
Trucking and Ward Homer Elkins
DONALD E. KRAMER and
SARAH A. KRAMER,
Plaintiffs
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00-8063 CIVIL TERM
DAVID W. HANSEN TRUCKING
and WARD HOMER ELKINS,
Defendants
CERTIFICATE OF SERVICE
:'1
Ii
i
i
I]
I
,
!,I
!,i
1'1
l,!
1':1
i!
fl
Ij
"
I
j
I
,
,'I
!,i
,1
AND NOW, this 25th day ofJanuary, 2001, I, Howard D. Kauffinan, Esquire, counsel
for Defendant affirm that I served the foregoing Agreement Pursuant to Rule 237.2 To Extend
Time to Plead Following Ten-Day Notice by depositing same in the United States Mail, postage
prepaid in Harrisburg, Pennsylvania addressed to:
Dale F. Shughart, Jr., Esquire
35 East High Street
Suite 203
Carlisle, PA 17013
~ Kal~n, Esquire
~~M$l#lf1'~blliil'lJ'i'~""U~J~~~"'~8>*,"""U:;.\gilx.'-:l!i';!ltH,,'t..",~t,~~-Wji(~"';"'"~ c-;;";'.g
~'~
""!
<-,;
;c
,; :t ~
/. ~
j:
_l~ i~'
~','" ,,'^,
'-'" ,.,
,-.
-
'",".,
, ~ ,,'
'H\"
,,' >
"],.'., ;:-:'
',"
,
.'!
. ~'
"
,"
"".{",'f';'
"
t " ~". '" ~ (
, ~ ~. : \:
(")
C
~'-'
m"'Ofu
m
Z:tl
Z.("'
(f).!":
-<L
~q_.
:t>O
20
);>C
z
~
~~
.\.1
<,,"
.,'";'
:., .....
.r
~:
;- ~ '" i_,:
N
"CJ'1' "
+
~.
'" ''"
,.
....
.,'j;
,,". ;
.',:
'! '( 't ~ ';'
(' '.
t
o
o
--1,
<-
,."
;Z
'",.
0"0
':;:;1.:7
"t~~
';.7(~
Oln
.ii?
~
:;;>, .
::x "
R