HomeMy WebLinkAbout00-08214
Lori Ratel, for herself, and on behalf of
the minor child, Alisha Marie Ratel
: IN THE COURT OF COMMON PLEAS OF
vs.
: CUMBERLAND COUNTY, PENNSYLVANIA
; NO. 2000- <rol /L{ CIVIL TERM
Donald Gerard Ratel,
Defendant
: PROTECTION FROM ABUSE
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the
case may proceed against you and a FINAL Order may be entered against you granting the relief
requested in the Petition. In particular, you may be evicted from your residence and lose other
important rights.
AHEARING ON THIS MATTER IS SCHEDULED ON 1JA1IV/l11IA.P/I../ :1 'i ,Dl),Xf
1/:tJ7) . A- .M., IN COURTROOM NO. '/ OF THE CUMBERLAND
COUNTY COURTHOUSE, CARLISLE, PENNSYL VANIA.
You MUST obey the Order that is attached until it is modified or terminated by the court
after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this
Order may subjept you to a charge of indirect criminal contempt which is punishable by a fine of up
to $1,000.00 and/or up to six months injail under 23 Pa.C.S. ~6114. Violation may also subject you
to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18
U.S.C. ~2265, tliis 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 ~ay 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 l(t the hearing. The court will not, however, appoint a lawyer for you. If you
do not have a Il\Wyer or cannot afford one, go to or telephone the office set forth below to find
out where you ican get legal help. If you cannot find a lawyer, you may have to proceed
without one.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE, CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717)249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact
our office. All arrangements must be made at least 72 hours prior to any hearing or business before
the court. You must attend the scheduled conference or hearing.
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Lori Ann Ratel, for herself, and on behalf of the
minor child, Alisha Marie Ratel
Plaintiff
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
; No. O{)- &j,IV
Donald Gerard Ratel
Defendant
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: Donald Gerard Ratel
Defendant's Date of Birth is: July 8,1970
Defendant's Social Security Number is: 091-62-0407
Name(s) of All protected persons, including Plaintiff and minor children:
I. Lori Ann Ratel
2. Alisha Marie Ratel
AND NOW, on /1 / ~~ upon consideration of the attached Petition for
Protection from Abuse, e 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 is prohibited from having ANY CONTACT with Plaintiff, or any
other person protected under this Order, at any location, including but not limited
to any contact at Plaintiffs school, business, or place of employment. Defendant
is specifically ordered to stay away from the following locations for the duration
of this order.
Plaintiff's residence located at 931 Hamilton Street, Carlisle, Pennsylvania.
Plaintiff's place of employment located at Quality Inn, Harrisburg Pike,
Carlisle, Pennsylvania.
3. Defendant shall not contact Plaintiff, or any other person protected under this
Order, by telephone or by any other means, including through third persons.
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4. 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
that Defendant has committed an act of abuse or has engaged in a pattern or
practice that indicates risk of harm to Plaintiff.
-Defendant shall remain in his vehicle during exchange ofthe minor child for
his periods of custody.
-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.
5. A certified copy of this Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
North Middleton Police Department
Middlesex Police Department
6. 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.
7. THIS ORDER APPLIES IMMEDIA TEL Y TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL MAY 21, 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. 96114. Consent of the Plaintiff to Defendant's
return to the residence shall not invalidate this Order, which can only be changed or
modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S.
96113. Defendant is further notified that violation of this Order may subject him/her
to state charges and penalties under the Pennsylvania Crimes Code and to federal
charges and penalties under the' Violence Against Women Act, 18 U.S.C. 992261-
2262.
NOTICE TO LAW ENFORCEMENT OFFICIALS
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This Order shall be enforced by the police who have jurisdiction over the plaintiffs
residence OR any location where a violation of this order occurs OR where the
defendant may be located. If defendant violates Paragraphs I through 3 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 Sheriffs office of the county
which issued this Order, which office shall maintain possession of the weapons until
further Order of this court, unless the weapon/s are evidence of a crime, in which
case, they shall remain with the law enforcement agency whose officer made the
arrest.
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PF AD Number: QVl164004H
Lori Ann Ratel, for herself, and on behalf of the
minor child, Alisha Marie Ratel
Plaintiff
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYL VANIA
v.
: No. (/1) - f.;1/'1 {!;,;zf-ru--
Donald Gerard Ratel
Defendant
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
.
PETITION FOR PROTECTION FROM ABUSE
I. Plaintiffs name is:
Lori Ann Ratel
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. Lori Ann Ratel
b. Alisha Marie Ratel
4. Plaintiff's Address is : 931 Hamilton St. , Carlisle, P A 17013
5. Defendant's Name is:
Donald Gerard Ratel
6. Defendant is believed to live at the following address:
140A Street, Carlisle, PA 17013
7. Defendant's Social Security Number is:
091-62-0407
8. Defendant's Date of Birth is:
July 8, 1970
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9. Defendant's Place of employment is:
Carlisle Tire and Wheel, Carlisle, Pennsylvania
10. Defendant is an adult.
11. The relationship between the Plaintiff and the Defendant is:
Spouse
Parents of the same children
12. The Plaintiff and the Defendant been involved in the following court actions:
a. Custody
13. Other details of the court action are:
Ratel v. Ratel October 12, 2000 Cumberland County Court of Common Pleas
No. 00-6884 Civil Term
14. The defendant has been involved in a criminal court action.
15. The defendant is not currently on probation I parole
16. Plaintiff and Defendant are the parents of the following minor child/ren:
a. Alisha Marie Ratel
Age:6 yrs
Child's address is: 931 Hamilton St. , Carlisle, P A 17013
17. There is an existing court order regarding the custody of the Plaintiffs and Defendant's minor
children.
The terms of the order are: joint physical custody
18. The facts of the most recent incident of abuse are as follows:
On or about November 15, 2000, Defendant went to Plaintiffs residence and entered her
home uninvited after he was asked to leave. Defendant grabbed Plaintiff by the writsts
and ~hrew her onto the bed. Defendant left in a rage and returned a short time later,
screamed at Plaintiff, grabbed her by the wrists, and threatened to hit her causing her to
fearfol' her safety. During the incident, the parties minor child was present traumatized,
crying, and stated to Defendant, "Daddy you're breaking my heart. Please don't kill my
mommy." Plaintiff's grandmother called the police. Defendant was arrested and charged
with simple assault, harassment, stalking and criminal trespass.
19. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor
chi1d/ren, (including any threats, injuries, or incidents of stalking) are as follows:
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On or about October 13, 2000, Defendant threatened Plaintiff that he would "take out"
her, their daughter, and Plaintiffs friend causing Plaintiff to fear for her safety and that
of her daughter's. Defendant further threatened that if he could not have her, no one else
would. Defendant told Plaintiff that she would have to explain to their daughter why her
father was no longer around, causing Plaintiff to believe Defendant was contemplating
suicide.
Since approximately 1997, Defendant has abused Plantiff in ways including the following:
pushed, grabbed, threw things at her, and screamed in her face. On one occasion,
Defendant and Plaintiff were arguing and Defendant picked up an axe intimadatin
Plaintiff and causing Plaintiff to fear for her safety.
20. The police department(s) or law enforcement agencies that should be provided with a copy of
the protection order are:
North Middleton Police Department
Middlesex Police Department
21. There is an immediate and present danger of further abuse from the Defendant.
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. Prohibit Defendant from having any contact with Plaintiff and/or minor
child/ren, either in person, by telephone, or in writing, personally or through
third persons, including but not limited to any contact at Plaintiffs school,
business, or place of employment, except as the court may find necessary
with respect to partial custody and/or visitation with the minor child/ren.
c. Prohibit Defendant from having any contact with Plaintiff's relatives and
Plaintiff's children listed in this petition, except as the court may find
necessary with respect to partial custody and/or visitation with the minor
child/ren.
d. Order Defendant to pay the costs of this action, including filing and service
fees.
e. Order the following additional relief, not listed above:
- Order Defendant to refrain from harassing Plaintiffs relatives.
- Order Defendant not to damage or destroy any property owned by
Plaintiff.
- Order Defendant to pay $250.00 to one of Legal Services, Inco's
funding sources as reimbursement for litigation in this case.
- Defendant shall remain in his vehicle at all times during exchange of
the minor child for his period of custody.
f. Grant such other relief as the court deems appropriate.
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g. Order the police or other law entorcement 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:
!f/;LI/H
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oan Carey, Attorney for PI
LEGAL SERVICES, IN
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
Distribution to:
Legal Services, Inc.
Fax and Mail to PSP
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VERIFICATION
I verify that I am the Petitioner as designated in the present action and that the facts and
statements contained in the above Petition are true and correct to the best of my knowledge. 1
understand that any false statements are made subject to the penalties of 18 Pa.C.S. S4904, relating
to unsworn falsification to authorities.
Dated: \ \ \ 20>\00
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L . Ratel, Plaintiff
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Lori Ann Ratel, for herself, and on behalf of the
minor child, Alisha Marie Ratel .
Plaintiff
v.
Donald Gerard Ratel
Defendant
. .
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: No. 00-8214
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
CONTINUED TEMPORARY ORDER
AND NOW, this 29th Day of November, 2000, pursuant to 23 Pa.C.S. g6107(c), the terms
and conditions ofthe Temporary Order issued on 21st Day of November, 2000, in the
above-captioned case are hereby continued in full force and effect until further order of the
court.
A hearing on this matter is scheduled for the December 21,2000, at 1 :30PM in Courtroom
4 of the Cumberland County Courthouse, One Courthouse Square, Carlisle.
Distribution To:
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-Greg Cutler, Attorney at Law1
Law Offices of Paul OIT .j
50 East High Street 'L
Carlisle,PA 17013 c.vrs fY/1A1;ri /i~,J9-())
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Lori Ann Ratel, for herself, and on behalf of: IN THE COURT OF COMMON PLEAS OF
the minor child, Alisha Marie Ratel,
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 00- 8214
CIVIL TERM
Donald Gerard Ratel,
Defendant
: PROTECT10N FROM ABUSE
MOTION FOR CONTINUANCE
The Plaintiff, Lori Ratel, by and through her attorney, Joan Carey of Legal Services, Inc.,
moves the Court for an Order continuing generally/rescheduling the hearing in the above-captioned
case on the grounds that:
1. A Temporary Protection From Abuse Order was issued by this Court on November
21,2000, scheduling a hearing for November 29,2000, at 11 :00 a.m.
2. The Cumberland County Sheriffs Department served Defendant with a certified copy
of the Temporary Protection From Abuse Order and Petition for Protection From Abuse at his place
of employment, Carlisle Tire and Wheel, located at 621 College Street, Carlisle, Pennsylvania, on
November 21,2000, at 9:05 p.m.
3. The parties agree, by and through their respective counsel, that the hearing be
rescheduled to afford them time to execute a consent agreement.
4. The Plaintiff requests that the Temporary Protection From Abuse Order remain in
effect for a period of eighteen months from the date it was entered or until further Order of Court,
whichever comes first.
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WHEREFORE, the Plaintiff requests that the Court grant this Motion 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,
an Carey, Attorney r Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-08214 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
RATEL LORI ET AL
VS
RATEL DONALD GERARD
HAROLD WEARY
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE
was served upon
RATEL DONALD GERARD
the
DEFENDANT
, at 0021:05 HOURS, on the 21st day of November, 2000
at CARLISLE TIRE & WHEEL
621 N. COLLEGE ST
CARLISLE, PA 17013
by handing to
DONALD GERARD RATEL
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
So Answers:
r~~~.t:~
R. Thomas Kline
11/22/2000
Sworn and Subscribed to before
By:
'7~1,~~ ~)~/
Deputy Sheriff.
me this f<lJ--
day of
~ !LtrtrV A.D.
o O~~
~rothonotaiy
.~_-_C""""'-"": I
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Lori Ann Ratel, for herself, and on behalf of the
minor child, Alisha Marie Rate!
Plaintiff
v.
Donald Gerard Ratel
Defendant
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: No. 00-8214
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
ORDER TO VACATE
AND NOW, this: 5th Day of December, 2000, upon Plaintiff's motion to withdraw
or discontinue this action,
1. This matter is dismissed without prejudice.
2. Costs ofthis proceeding are waived.
3. The Temporary Order (Filed on Nov 21, 2000) is hereby vacated.
Distribution to:
-Legal Services
-Faxed & Mailed to PSP- 1ll.'?'O 0
- Greg Cutler, Esquire
50 East High Street
Carlisle, PA 17013
-Fa.xed. to CoP q.l~' Ji.7-00
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BY THE COURT: /
/1/01-
vin A. Hess, Ju ge
,!Z- - r - (J'C
fI Date
Lop.U.D~
/ fl- '1-00
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1i<~!i!ill4iItli~~~\0t,W;;I:;;'~~j.1i!?!@,~'"WH'"""'M",buJ::,{,;&..!1,;(@&'h',""-'~'"g,'i'_ ,',~ '.1.."_ ".-,ii' d*.M\'1;!\i,"'jW;Pi~f@_~Il!!ijl~NI~!llg$;I<R~~>'illil!tiIr" ~~ J:b..Smti.l~
FiLFD-Di:FICE
OF it :r~' 7::FOT;.1('i!\10T.ARY
00 DEe .-'] Ml 8: 13
CUMBEHLJ\i'JD COUNTY
PENNSYLVANIA
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Lori Ratel, for herself, and on behalf of the : IN THE COURT OF COMMON PLEAS OF
minor child, Alisha Marie Ratel
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 00- 8214
CIVIL TERM
Donald Gerard Ratel
Defendant
: PROTECTION FROM ABUSE
PETITION TO VACATE ORDER AND WITHDRAW ACTION
Plaintiff requests the Court vacate the Temporary Protection From Abuse Order in the
above-captioned case on the grounds that:
I. A Temporary Protection Order was issued by this Court on November 21, 2000,
scheduling a hearing for November 29, 2000, at II :00 a.m.
2. A Continuance was filed on November 29, 2000, rescheduling the hearing for
December 21,2000 at 1:30p.m.
3. Plaintiff no longer wishes to pursue the Protection From Abuse Order.
4. At this time Plaintiff requests that the Temporary Order entered on November 21,
2000, be vacated without prejudice.
WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate the
Order without prejudice.
Respectfully submitted,
Joan Carey, Attorney for P
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, P A 17013
'.~ll~:L ~I
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"
.
Verification
The above-named plaintiff, Lori Ratel, verifies that the statements made in the above
Petition are true and correct. The plaintiff understands that false statements herein are made
subject to the penalties of 18 Pa.C.S. ~ 4904 relating to unsworn falsification to authorities.
Date:n ,\c::\d)
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.. CUMB CO PROTHONOTARY
141001
12/07/00 THU 09:10 FAX 717 240 6573
***************************
U$ MULTI TN REPORT U$
***************************
TX/RX NO
INCOMPLETE TX/RX
TRANSACTION OK
2329
[ 01j9p2405331
[ 03j9p2438026
[ 04]92490779
CENTRAL PROCESS
LEGAL SERVICES
PSP
ERROR
. "
.
omCE OF THE PROI'HOlIKJI'ARY
ClHlERLAND a:xJNTY COUR1HOOSE
ONE o:xJRTHOOSE 9;!UARE
CARL1SLE. PA. 17013-3387
(717) 240-6195
FAX (717) 240-6573
VIA TELECOPIER
cf
LS
TO: PA STATE POLICE
,
-,
FAX H:
717-249-0779
FRCl'!: CURTIS R. LONG
RE: PFA ORDERS
MESSAGE:
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