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HomeMy WebLinkAbout00-08505 KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Victoria Timmerman, Plaintiffs vs. BART KARLTON TIMMERMAN, Defendant r : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW : NO. 00-8505 CIVIL TERM : PROTECTION FROM ABUSE : AND CUSTODY o FOR CONTINUANCE AND NOW, this day of November, 2001, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on Tuesday, November 20, 2001, at 3:30 p.m. by this Court's Order of August 14,2001, is hereby continued generally. This Order is entered without prejudice to either party to request a hearing. The Temporary Protection From Abuse Order shall remain in effect for a period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, whichever comes fIrst. Joan Carey, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row, Carlisle, PA 17013 Michael A. Koranda, Attorney for Defendant Tomasko & Koranda P.c. 219 State Street, Harrisburg, PA 17101 By the Court, .;jJ &r;:~Ye ~ "","^^ l ~."~~ ~)m, ':-'L' , '" ^'^:"nn,p'f ' ~, '" 11~~'1 0/ frlDV 28 In'' '"J: ,,~ C"I'[ ^ t..JNl 'jC(l'L/\;\'I,'I"~ l"-'U" U"TY Pr-. "~,.J 1\1 tJlJNSYLVANIA ' ,__: _ ~. ~,::,!Itm\, "" ". --"'- "', ".-.. , '.. ,',""",_A' " "" ""'~-~~~-'''='''''-'~''YC->;~,~-,:.,-,.,~,~,-",. '-^'<_"_ .;OC' - ',.,:"..,_ '1;0_ !,!._~n,rrry~~~lll'f$l~~~~iffl'~~~~~~'m~'1JJil, "~~ KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jarni Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Vicotria Timmerman, Plaintiffs vs, BART KARLTON TIMMERMAN, Defendant ~ -~~-.d I I : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 00-8505 CIVIL TERM : PROTECTION FROM ABUSE : AND CUSTODY MOTION FOR CONTINUANCE Plaintiff, Kathy Ann Timmerman, by and through her attorney, Joan Carey ofMidPenn Legal Services, moves the Court for an Order continuing generally the hearing in the above-captioned case on the grounds that: 1. A Motion was filed and an Order for Continuance was entered on August 14, 2001, rescheduling the hearing in the above-captioned case for November 20,2001, at 3:30 p.m. 2. The parties agree, by and through their respective counsel that the hearing be continued generally. 3. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, whichever comes first. WHEREFORE, Plaintiff requests that the Court grant this Motion and continue generally this matter, and that the Temporary Protection From Abuse Order remain in effect for a period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, '1_ , , whichever comes first. Respectfully submitted, o Carey , Attorney for P ntiff MIDPENN LEGAL SER CES 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 or 1-800-822-5288 ":~~' "--' I' 'il!fii.iil$tll_~Ii~il~~~ll!!s1iil!Mft;~1~~al!llM.~A:" '_,,-l ,~". -'''' -~- ~-" -_.-=',-_,"-," ~^~~ "-"" T";"''''Z .~- ,,; -" '-- ~ .' - ~ '~IllIi~'> ~'" " itii\M ,"-C 0 C) C) C , , <::: z vG-j c,) mr-n " Z:'.:.' L",~ Z 1--' f"..} -..' :'1 ~?2:: C:l ~=: ~.:C' -0 :1..- -'.{ P.-" ~O -.J'_~ ~'-;!(~ r:- ;-!i-::-n--i -""C ",_,.J z: o;::l =< :'J 55 '/='" -< ;~1 ~~~ . KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jarni Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Victoria Timmerman, Plaintiffs vs. BART KARLTON TIMMERMAN, Defendant ,~ ~ ,,< - > . ~ , JOY 2 1 2001 \5l : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 00-8505 CIVIL TERM : PROTECTION FROM ABUSE : AND CUSTODY ORDER FOR CONTINUANCE AND NOW, this _ day of November, 2001, upon consideration ofthe attached Motion for Continuance, the matter scheduled for hearing on Tuesday, November 20,2001, at 3:30 p.m. by this Court's Order of August 14, 2001, is hereby continued generally. This Order is entered without prejudice to either party to request a hearing, The Temporary Protection From Abuse Order shall remain in effect for a period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, whichever comes first. Joan Carey, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row, Carlisle, PA 17013 Michael A. Koranda, Attorney for Defendant Tomasko & Koranda P.C. 219 State Street, Harrisburg, P A 1710 1 By the Court, George E. Hoffer, President Judge ~iWlliiJiEM_w~:tl!f*.W'~rii,ffi~,,",~i.ID,$UWl~~wh.~'ci',n!,]hih"'+.,~ ,",*,"~f',' ,.,_:i~J;;jlii~t~'''''''+;;~''';'' ~ ,7''"', ."'7 '.~"'=,,,.,,~".' ., ,- -. ~_ '" ,,' "..," <"""""".., """,-" p <,,-~ ~ ~""",,,,-,<-;,. "'~ - ~, '~lIie ""Ili'Jlilii -:'C~"-__ ~,<- ='r-~"~'~~~ -.~ "' ~ (} a 0 C -n- ". Z *'DC] C.I -" nTr1'l .0;:: I"; Z:J.> [-.] z C~- N ~~2-~ c:. .. ~r' ,-::71 C) r;::c' .." .'", :;-. s:ja -J:.~o -:;"" z:; c5 )> C:: r:- r")l " "'-t z :::J 5:; =< - =< . ,~~. if "~ .,;..".-.;i;;<. ~'. .- ' KATHY ANN TIMMERMAN, : IN THE COURT OF COMMON PLEAS OF for herself and on behalf of her minor children: Jami Krista Hargreaves, : CUMBERLAND COUNTY, PENNSYL VANIA Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, : CNIL ACTION - LAW Daniel Josiah Christian Timmerman, and Abigail Victoria Timmerman, : NO. 00-8505 CIVIL TERM Plaintiffs vs, BART KARLTON TIMMERMAN, Defendant : PROTECTION FROM ABUSE : AND CUSTODY ORD~R FOR CONTINUANCE AND NOW, this ~ day of August, 2001, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on Tuesday, August 14,2001, at 3:30 p,m. by this Court's Order of June 26, 2001, is hereby rescheduled for hearing on Tuesday, November 20, 2001, at 3:30 p.m. in Courtroom No.3 on the 4th Floor ofthe Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. The Temporary Protection From Abuse Order shall remain in effect for a period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, whichever comes fIrst. By the Court, Joan Carey, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row, Carlisle, P A 17013 Michael A. Koranda, Attorney for Defendant Tomasko & Koranda P.C. 219 State Street, Harrisburg, PA 17101 ~~ 8;/7-tJ / t., "q_~, *_:."~ ._c 'r' .Um~-7 ,,- ~ . ~- "~ " - ~ -~' ~ '<'. "', ^., .~--"""'~.~~ ., LW"W" PI ED---Oi:F\C~ ('\1_ ".... i: !(;\\Yf/\Jf1Y ,)r ,_ I ." -" - . "/ >"'l[~' 2? 01 AUG I ;In J..... CUlvltlEtiiJ\:i[) COUNTY , PENN8YLVI>NI/\ ", )n,.., i__~_~n__~u__J._ J,"_ .."""J. ,.' _",,:__~"'_ "", "T\"" ',^ _.~_!M~~;\'"'~~1ji"!r<W'ttl!\~-~~_'~~!!'i'!~~i!lIi~, :'.'-. -~-J_J-,' .,,',<" - KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jarni Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Vicotria Timmerman, Plaintiffs vs, BART KARLTON TIMMERMAN, Defendant j , I ~ < J - c , '. .' . : IN THE COURT OF COMMON PLEAS OF , : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 00-8505 CIVIL TERM : PROTECTION FROM ABUSE : AND CUSTODY MOTION FOR CONTINUANCE Plaintiff, Kathy Ann Timmerman, by and through her attorneys, Joan Carey and David A. Lopez of MidPenn Legal Services, moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: L A Motion was filed and an Order for Continuance was entered on June 26, 2001, rescheduling the hearing in the above-captioned case for August 14,2001, at 3:30 p.m. 2. The parties agree, by and through their respective counsel. that the hearing be rescheduled. 3. Plaintiff requests that the Temporary Protection From Abuse Orderremain in effect for a period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, whichever comes first. WHEREFORE, Plaintiff requests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in effect for a period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, .~ ,~. C~ ~ ~" whichever comes fIrst. ~,-! I ,_ ~ -- _ ~ ' _, ;,l" ~ '. . ( Respectfully submitted, o ' Carey David A, Lopez Attorneys for Plaintiff MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 or 1-800-822-5288 ;~, . T ~ I '....:. '4t ';""';."'t",..'t~J1~~~.~~~~~~~1'1J.".o'''t!l'''~I~~lif''!!'i~!W19~'II!,<!'~'.1 f.'f "JJlf ~s ~ (1l01\l1J:jLtj~ti'r"'rB~'uj.ll~.tH_,i&:'~~ '.'r"lli'IfJ'- ~"li4ijJj f'; 0 0 C) C -'1'1 ::;?" "'" -ofE ,-- mrT1 G') Z:. Zr" (/]2 --.J -</ \,-=-.J !< C ~~ -, ~. c::' (:~.? z ~:~ ~O .PC cD 0 2~ ;::- :;j =< rv 51 -~ . -'~. ~., , KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Vicotria Timmerman, Plaintiffs vs. BART KARLTON TIMMERMAN, Defendant J '~ " in. c , ~", ~ : IN THE C@URT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 00-8505 CIVIL TERM : PROTECTION FROM ABUSE : AND CUSTODY FOR CONTINUANCE AND NOW, thi _ day of June, 2001, upon consideration of the attached Motio~/()r "t( Continuance, the matter scheduled for hearing on Tuesday, June 26, 2001, at 3:30 p.m. by this Court's Order of December 29, 2000, is hereby rescheduled for hearing on Tuesday, August 14, 2001, at 3:30 p.m. in Courtroom No.3 on the 4th Floor of the Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvania. The Temporary Protection From Abuse Order shall remain in effect fur a period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, whichever comes first. ,.,-..-.,,' Joan Carey, Attorney for Plaintiff - c..J .t'~ ~~ ?t ~ ;'/..2 (, ~ I MidPenn Legal Services - I V' IT ~ - . r 8 Irvine Row, Carlisle, PA 17013 Michael A. Koranda, Attorney for Defendant - "1'1~ ~ ,,;60; Tomasko & Koranda P.C. 219 State Street, Harrisburg, PA 17101 ""'''''' ," j ~ " ('<:: ',J' r,. 0..\..': ~)' " "'\)' ('\'\ ',',_.\ J \ \,., )\",'\" , \,,;'1. 0\ \ ,~ ,"_. {'\jU\~' ,"",' '. ,:",',~.y !:~\\[':.'" CIjN;~~~\S'{'0ii\\\ - ~ llli," _ _ ~,_~ _'~)...,"~ JI!I/il.$'jI"Jlii!!lf\@~li\\~*,Uiit!~J!i'r, _ ~",l ~~ --", ~-~ .JT.~~lf~~N~J'(i'it-;;ml!'1iF,f:;f~j',,"!))'1:9"!N-~j''ffl~ij"~~~~r;\'l~!f:~;!:1~WJ~~I'@ij!!J~:\iilli/lil!~ ~ , KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Tinnnerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Vicotria Timmerman, Plaintiffs vs. BART KARLTON TIMMERMAN, Defendant "~JI" ~' ",,- ',"~~, ~ c,_,_,;",'__,0".'_-, '--'.' : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 00-8505 CIVIL TERM : PROTECTION FROM ABUSE : AND CUSTODY MOTION FOR CONTINUANCE Plaintiff, Kathy Ann Timmerman, by and through her attorneys, Joan Carey and David A. Lopez of MidPenn Legal Services, moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. AMotion was filed and an Order for Continuance was entered on December 29,2000, rescheduling the hearing in the above-captioned case for June 26,2001, at 3:30 p.m. 2. The parties agree, by and through their respective counsel that the hearing be rescheduled. 3. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect fora period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, whichever comes first. WHEREFORE, Plaintiff requests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in effect for a period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, , 1-_"' --,- - ',' -~I' _~ " - ii-. .' whichever comes first. By submitted, Joan Carey David A. Lopez Attorneys for Plaintiff MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 '.,,-~ WJ~iftti~i1]'",<il~~O:\~!~ij~il~!i(di:\i-J:\;!~jl9~_-~,"~i'i-tt,>=p:r~'''-M_~.~.-o j>-I';" '- J-'-:'" ~~ . ~! ,. ~~,~" ._,,'~'_7" ~,. ~ "" Wlii: wwih'!lIl: (') c:: "'~- ~~.. ~;~~ J>e: z: ::< . ""'''-',,0:.;- ,~ -" () " --.{ ~- ;"J C'.', "r _.C~ ~-~) i ,'C.) -'J- I"t '-J;] c; il1 ~i:J ~j " =< J_~'l<> ~, ~ :]1 :~~. I I -"-- " ~o~, ,~ .~ ~ <1-t~. -'" SHERIFF'S RETURN - REGULAR CASE NO: 2000-08505 P COMMONWEALTH~F PENNSYLVANIA: COUNTY OF CUMBERLAND TIMMERMAN KATHY ANN ET AL VS TIMMERMAN BART KARLTON STEVE WHISTLER , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon TIMMERMAN BART KARLTON the DEFENDANT , at 0011:15 HOURS, on the 12th day of December, 2000 at 101 N, 2ND ST f,e WORMLEYSBURG, PA 17043 by handing to BART KARLTON TIMMERMAN a true and attested copy of PROTECTION FROM ABUSE together with & CUSTODY, NOTICE OF HEARING & ORDER, TEMPORARY PROTECTION FROM ABUSE ORDER and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18,00 10.54 ,00 10,00 ,00 38.54 so~~ R. Thomas Kline 12/13/2000 me this If iC: day of BY~ Deputy Sheriff Sworn and Subscribed to before A.f2eu~ c20viJ A. D , 0~C. ~<etJ~.>/~ rothonotary ,~ - ^ '( . KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Tinnnennan, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Tinnnerman, and Abigail Victoria Tinnnennan, Plaintiffs v. BART KARLTON TIMMERMAN, Defendant ", , ~- '--':, . : In the Court of Common Pleas of : CUMBERLAND County, : PENNSYLVANIA : Civil Action - Law : No. 00-8505 : Protection From Abuse & : Custody No. 00-8505 CONTINUED TEMPORARY ORDER AND NOW, this 29th Day of December, 2000, pursuant to 23 Pa.C.S. ~6107(c), the terms and conditions of the Temporary Order issued on 7th Day of December, 2000, in the above-captioned case are hereby continued in full force and effect. This order is in effect until June 7, 2002. A hearing on this matter is scheduled for the June 26,2001, at 3:30PM in Courtroom NO.3 on the 4th Floor of the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. Distnbution To: .' ~ trJ/?001'1.0lly Joan Carey, Attorney for Plaintiff COf' e.s r'- / LEGAL SERVICES, INC. 8 Irvine Row, Carlisle, PA 17013 Michael A. Koranda, Attorney for Defendant TOMASKO & KORANDA PC 219 State Street, Harrisburg, PA 17101 fY) oJfcf esident Judge I;). ';u:; rOO ~ 11" ,. L_ ~1IJlIm,_!Jl!iIMNJlIII ',. j '~ (I:: T. 00 D:C :?9 ~"_"'__~~'-_ -"'" ,h.'_' ~"/> ~- ~-.-'".<-' ^ ~"'" ,-',' :>JJf/\FY ',' "'11 ; i ,J' -~..} CUMbE;:;:j\~\JU COUNT1' PENNSYLVilNI/\ 1~14!;_jLm!_~~~.~r~~U!'ftlJl8'~~il'if,'~H!~;;:';~"-$.%l'''-~fl''!>F,'.J:;!i'*,,'i<;(r.l.:~~;I'W!,gj~~~~,it~:,~~~_,tili!J~W ..L - KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Vicotria Timmerman, Plaintiffs vs. BART KARLTON TIMMERMAN, Defendant J "-;, .~.~ ,- -- t:: : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW : NO. 00-8505 CIVIL TERM : PROTECTION FROM ABUSE : AND CUSTODY MOTION FOR CONTINUANCE Plaintiff, Kathy Ann Timmerman, by and through her attorney, Joan Carey of Legal Services, lnc" moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. A Motion for Continuance was filed on December 14, 2000, and an Order for Continuance was entered on December 18, 2000, scheduling a hearing for December 20, 2000, at 3:30 p.m. 2. The parties agree, by and through their respective counsel, that the Temporary Protection From Abuse Order shall remain in effect pending a hearing in the matter, which they desire to be rescheduled to a date approximately 6 months from the hearing date of December 20, 2000, or or nntil further Order of Court, whichever comes first. WHEREFORE, Plaintiffrequests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in effect pending further ~"".,.t."".i""""'~.~~ .~ Order of Court. J " ~= , --, j--, ~::~t~ Joan Carey Maryann Murphy Attorneys for Plaintiff LEGAL SERVICES, INC. 8 Irvioe Row Carlisle, PA 17013 (717) 243-9400 ~HiliM",iJit~~~h"Niif<.;;~*g"",iii1-~i.ifis!H~~Mih~;,;{j,t;0~4fltt-t_-"',[j"",i~"h!i1!}Il'Ii-w.i!'il\i1,iJJ!.l:J t'" I!1l!-J~61!tiWm~~.4 I \ 9~ "." >~ -"~ ~ , ,.. ~" ."" 1"J!l.IW () c- :;:;;: ""O~ Fiji;;' u) ~~ rs;~;,:-' ",--r~, ~,,_r Sr-, ~o ..... c~ -::,~ <- ::! . --"-'J C:::;, c) D !,-, '-~-)' ....".., '.0 '--'-{ ~'1] , ~-~. - ~ '....- .:; .-/~i '- ~5',ii; ~ :.:0 ~~ 0;5 .::" .,';:- w ~-......., ~ . , KATHY ANN TIMMERMAN , for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, . Daniel Josiah Christian Timmerman, and Abigail Victoria Timmerman, Plaintiffs v. BART KARLTON TIMMERMAN, Defendant -.i",..d "'" ';" '1~ : In the Court of Common Pleas of : CUMBERLAND County, : PENNSYLVANIA : Civil Action - Law : No. 00-8505 : Protection From Abuse & : Custody CONTINUED TEMPORARY ORDER ll~ AND NOW, this_ th Day of December, 2000, pursuant to 23 Pa.C.S. S6107(c), the terms and conditions of the Temporary Order issued on 7th Day of December, 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 20,2000, at 3:30PM in Courtroom NO.3 on the 4th Floor of the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. Distnlmtion To: Joan Carey, Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row, Carlisle, PA 17013 Michael A Koranda, Attorney for Defendant TOMASKO & KORANDA PC 219 State Street, Harrisburg, PAl 71 0 1 , President Judge ~-fY)a1l /2 -J<g-()O R )(.s " <" ~-~ , _".'_ " _M'll_;ri~U_nJJ;!L "J Jl[j!llr ~ , ~" "-,~-~- ~" 0- "~ _" - ~, "~ - ~ .~.~. )!l~vwmtim,p~ww:~~l!l',!]j,iiU;3..~~o'!f:C"" >='"<'-i' .. ;"",,',,';oi;-:"-c,-,,"'lijfG':'4';i'~''W'flif''''''Jf~'';>,*r&!\\WfI!Il!.m:'1'';-_"~':-~,,--- '"-'H-,----ih~~],0!!~'$n~~ 0 CJ. (j C C' .:? ~ - c -::::; -om -', nl,l"'-" c:: z:i:; z-~ (,.0'-"" CO . -~-" -<:.~- !;.:Ci ~~: ?,f-G 5;;~ r~. ~ c.n )~; ::g -, ~~~- KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Vicotria Timmerman, Plaintiffs vs. BART KARLTON TIMMERMAN, Defendant .';'.- , ; ~ .-,~- ~ .' : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW : NO. 00-8505 CIVIL TERM : PROTECTION FROM ABUSE : AND CUSTODY MOTION FOR CONTINUANCE Plaintiff, Kathy Ann Timmerman, by and through her attorney, Joan Carey of Legal Services, Inc., mOves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. A Temporary Protection From Abuse Order was issued by this Court on December 7,2000, scheduling a hearing for December 13,2000, at 10:30 a.m. 2. The Cumberland Connty Sherifl's Department served Defendant with a certified copy of the Notice of Hearing, Temporary Protection From Abuse Order and Petition for Protection From Abuse on December 12, 2000, at the marital residence located at 101 North 2nd Street in Wormleysburg, Cumberland County, Pennsylvania, at approximately 11:00 a.m. 3. Defendant has retained Michael A. Koranda of Tomasko & KorandaPC, to represent him in the matter 4. The parties agree, by and through their respective counsel, that the hearing be rescheduled. ,--~~'"" . ~~ .... - . .' I ~ . ~. ~-' , "ul-- """"",-. > '. .- . 5. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of 18 months, through June 7, 2002, or until further Order of Court, whichever comes first. WHEREFORE, Plaintiff requests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in effect for a period of 18 months fr'om the date it was entered, through June 7, 2002, or until further Order of Court, whichever comes first. oan Carey, Attorney fur PI . LEGAL SERVICES, INe. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ~l:&*~~'%m~:W#:T';!;-H~':f.1l:J_~'~~~&I~~~18j"l:iib..-~"";;.-",,,,\;,_>_,,-__ ,__;_g,iif~~,Vd+~MWIii!j'll!l"~~*,W~~Ili1,&,':'..AM ~ .' r"~ '\>~~ '~~--"'- -""<- -~-,-"-, ",' ~-- =,^'~_" _ ,,,,,",,__,_ ."hT___ "" .. J1Lp-1Ii;:':'11li\1:~ o G " -,:,U] rr1 r'n 2:1) Zl;:: ~2~ ~Q -po ~?C 2= C) PC -? .F_ ::<!. o Cl C1 n'l I:' u r;i o -n .;;:. , .;~~ ~~ -'. ?:O c.:: -u ..."... -'" s~: l"" ,-~"'~ ~~, KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Vicotria Timmerman, Plaintiffs vs. BART KARLTON TIMMERMAN , Defendant __J _ "'-' -- :;-'-J, ...."'~' "'<o/~, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW : NO. 00- 'it:;'D5" CIVIL TERM : PROTECTION FROM ABUSE : AND CUSTODY NOTICE OF BEARING 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. 111 . A hearing on this matter is scheduled onthe,D day of December, 2000, at /t> c3thn., in Courtroom No. ..::L. on the 41h floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA. 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 ma, y arrest YO, u. Violation of i- '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 prose . . on and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 US.C. ~2265, this Order is enforceable anywhere in the United States, tn1>allands, 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 US.C. 92261-2262. You should take this paper to your lawyer at once. You have the right to have a lawyerrepresent you at the hearing. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help, If you cannot find a lawyer, you may have to proceed without one. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, Pennsylvania 17013 Telephone Nwnber: (717)249-3166 AMERlCANSWlTBDISABILmES ACT OF 1990 The Court of Common Pleas of'Cnml>erland ColUlly is required by law to comply with the Americans with Disabilities Act of 1990. For information about accesSIble facilities and reasonable accommodations available todisabledindividnals having business before the court, please contact our office, AIl arrangements must be made at least 72 hOlllS prior to any hearing or business before the court. Yon must attend the scheduled confetence or hearing. ~ '. fl\.EC)-()ff\CE at :?,~.", '~"\O",....y , r )~'i'-.Il !"'U\'''1\ l,uu'""l 00 DEe - 1 PH l1} \ 5 CUMI3ERU\ND COUNTY PENNSYLVANIA c' "."' ri_ij~U~; ~~.:r~iIii it. ... '_ _,n~_~~",._~- , . 1~~$1!lWI:$\~#<,~ ,_ - --~--~~~ ~_~.e ~O ~ ~"'7"-' .",-' "~-," ~ ; ~ ,,-.-, ~.'''''_.~' --~, ~_~_ . ~1~~t~l<'m'Wj,,"'~'V-(""1"-'f" t,-,,"I'''"!'''iii''''R'ffWlW'"!;;''''_'"f!''m~'!''h,!,M_~S;'' ' -'" -.,',;'.,'i. '-'-';"Y')"{"!;'",'"""r,,,"''',;wMm-mr~ i,.""",~~~,~ .. " KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Victoria Timmerman, Plaintiffs v. BART KARLTON TIMMERMAN, Defendant ,I ~ -I ~ 'I l j ,-,..:-< ""'";'~, : In the Court of Common Pleas of : : CUMBERLAND County, : PENNSYL VANIA : : Civil Action - Law . : No. 00- (;SOs' : Protection From Abuse & : Custody TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: BART KARLTON TIMMERMAN Defendant's Date of Birth is: September 3, 1960 Defendant's Social Security Number is: 493-74-8441 Name(s) of All protected persons, including Plaintiffand minor children: 1. KATHY ANN TIMMERMAN 2. JAMI KRISTA HARGREAVES 3. MELISSA SUSAN TIMMERMAN 4. ANNELYELlZABETHKATHRYNTIMMERMAN 5. DANIEL JOSIAIl CBlUSTIAN TIMMERMAN 6. ABIGAIL VICTORIA TIMMERMAN AND NOW, on 7th Day of December, 2000 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: Plaintiff's reqnest for a temporary protection order is granted. 1. Defendant shall not ahuse, harass, stalk or threaten any of the above persons in any place where they might be found. ,I 1-- 2. Defendant shal1 be evicted and excluded from the residence at: 101 North 2nd Street Wormleysburg, PA 17043 or any other permanent or temporary residence where Plaintiff or any other person protected under this Order 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 of Plaintiff or any other person protected under this Order. 3. Except for such contact with the minor childlren 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 Plaintill's school, business, or place of employment. Defendant is specifically ordered to stay away from the fonowing locations for the duration of this order. Plaintiff's current residence and any other place where she and/or the minor children may stay during the term of this Order. The schools of the minor children. 4. Except for such contact with the minor childlren as may be permitted under paragraph 5 of this Order, Defendant shal1 not contact Plaintiti: 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, Plaintiffis awarded temporary custody of the following minor child!ren: 1. MELISSA SUSAN TIMMERMAN 2. ANNELY ELIZABETH KATHRYN TIMMERMAN 3. DANIEL JOSIAH CHlUSTIAN TIMMERMAN 4. ABIGAIL VICTORIA TIMMERMAN Until the final hearing, all contact between Defendant and the childlren shall be limited to the funowing: Defendant's contact with the minor children is suspended pending further Order after tire hearing scheduled in this matter. The local law enforcement agency in the jurisdiction where the childlren are located shall ensure that the childlren are placed in the care and control of the Plaintiff in accordance with the terms of this Order. ,_ ~ 0,"-;_' ~-~~ 'iL "",.' ". 1-, 6. The fullowing additional relief is granted: Defendant is prohibited from having any contact with Plaintiff's relatives. Defendant is ordered to refrain from lIarassing Plaintifl's relatives. Defendant is enjoined from damaging or destroying any property owned jointly by tbe parties or solely by Plaintiff. 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: WEST SHORE REGIONAL POLICE DEPARTMENT 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. TmS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL JUNE 1,2002 OR UNTIL OTHERWISE MODIFlED 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 in jail. 23 Pa.C.S. ~6114. Consent of the Plaintiff to Defendant'sreturn to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C. S. ~6113. Defendant is further notified that violation of this Order may subject himlher to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. ~~2261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS l i""." 'lliM This Order shall be enforced by the police who have jurisdiction over the plaintifl's residence OR any location where a violation of this order occurs OR where the defendant may be located. Ifdefendant 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 threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sherift'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 weaponls are evidence of a crime" in which case, they shall remain with the law enforcement agency whose officer made the arrest. Judge ~ -- " Distribution to: Joan Carey, Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row, Carlisle, PAl 70 13 (717) 243-9400 FAXed & mailed to PSP ~ - i - . 'lJoJ.....if'. - ,~' -",,\\ ^=~~'''',~....... ~~ ~ ~ i J -~ ~' .Kliilll -~ - ;':, PFAD Number: WMl165596X KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, AnnelyE1izabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Victoria Timmerman, Plaintiffs : In the Court of Common Pleas of : CUMBERLAND County, : PENNSYLVANIA : Civil Action - Law v. BART KARLTON TIMMERMAN, Defendlmt : No. 00- ~5hS' CiUJ. 1..t.M- : Protection From Abuse & : Custody PETITION FOR PROTECTION FROM ABUSE 1. Plaintiffs name is: KATHY ANN TIMMERMAN 2. I, (the Plaintifl), am filing this Petition on behalfof: - myself - and as Parent of minor Plaintiff(s) 3. Name(s) of ALL person(s), including minor children, who seek protection from abuse. a. KATHY ANN TIMMERMAN b. JAMI KRISTA HARGREAVES c. MEJ.JSSA SUSAN TIMMERMAN d. ANNELYELlZABETH KATIlRYN TIMMERMAN e. DANIEL 10SIAH CHRISTIAN TIMMERMAN f. ABIGAIL VICTORIA TIMMERMAN 4. Plaintiffs Address is : 101 N~rth 2nd Street, Wormleysburg, PA 17043 ,,,,,,,,,",w~ .'0-' c : I. ~ q!;;i 5. Defendant's Name is: BART KARLTON TIMMERMAN 6. Defendant is believed to live at the following address.: c/o Augustus, "Auggie" Tokish, Carlisle, PA 17013 7. Defendant's Social Security Number is: 493-74~8441 8. Defendant's Date of Birth is: September 3" 1960 9. Defendant's Place of employment is: Roadway Express, 106 Carlisle Drive, Carlisle, FA lO. Defendant is an adult. 1 I. The relationship between the Plaintiff and the Defendant is: Spouse Parents of the same c:hildren 12. The Plaintiffand the Defendant been involved in the following court actions: a. Support 13. Plaintiff and Defendant are the parents of the following minbr child/ren: a, MELISSA SUSAN TIMMERMAN Age:U years old Child's address is: 161 North 2nd Street, Wormleysburg, PA 17043 b. ANNELY EUZABEm KATHRYN TIMMERMAN Age:9 years old Child's address is: 101 North 2nd Street, Wormleysburg, PA 17043 ,~ " .~ '. " ~". c. D,ANIEL JOSIAR CHRISTIAN'TlMMERMAN Age:4 years. old. . Child's address is: 101 North 2nd Street ,Wormleysburg, PA 17043' d. MIGAILVlCTORIA TIMMERMAN Age:l year ,old Child's address iS2161 North 2nd Street, Wormleysburg, PA 17643 14. PlaiIrtiffis set(kingan'Order of child custody as part of this petition. The following ~alist.ofthe children and where they have live f(jrthepaSt 5 years: 'l!.i M.ELISS:ASUSAN TIMMERMAN '. F,orthe.pasti5.years, ,this.child'haslived with: Plaintiff and child's siblings, Jami Hargreaves, Annely Timmerman, Daniel ..Timmerman, .andAbigail TiDullennan, 'i' .attl6hNorth 2nd$treet,WOMIeysburg, PA, from August 15, 2006, to the present. ,:;~ - . . ,. . ," -.,., ~. " ' - , . . . P~titT. Defendant, anlHiblings, at lOt North2ndSb'eet, Wonme~sburg, PA, '" from July 4, 2000, until August 15, 2000. Plaintitl';'and'child'S siblings; at 101 North 2ndStreet;Worlllleysburg, PA, from JateFebruary 2000, until July 3, 2600. , ,,;i PlltintitT, Defendant,'1md'riblings, at 101 North 2nd Street, .W~rmleysburg..PA, .from February11, 201J6, until late Fetiuary 2060. '. '. . Plaintiff, and siblingS, lit 161 'North 2nd Street; Wotmleysburg, P A, from N6yemhe..>>, 1999, until Fetiruarj 10,2600. . I .. Plaintiff,.'Defendant, andSiblings;:Taini;Hlitgl'elives, Annely TilliDler~an: Daniel Timmerman,'andAbigail Timmerman (DOH: 01127/99),al-l0l North 2nd Street, Worlllleysburg, PA, from January 27,1999, until November 22, 199.9. , r'-"'" ~ 1 '. ,", .t, . Plamtiff,Defendant; and siblings, Jami HargreaveS; Annel! TiillliierDllln; Iln~ Daniel Timmerman (DOD: 12/04/96);' al: 212' F~rit. Avenne; 'CarlislepA, (f9m'. 1995untiEt996. . . .,. , 'b. ANNELY ELIZABEm KATHRYN TIMMERMAN For the past 5 years, this child has lived with: Plaintiff and child's siblings, Jami Hargreaves, Melissa Timmerman, Daniel Timmerman, and Abigail Timmerman, at 101 North 2nd Street, Wormleysburg, PA, from August 15, 2000, to the present. _' ,'"_u" ~ . . ~. {'.: Plaintiff, Defendant, and siblings, at 101 North 2nd Street, Wormleysburg, PA, from July 4, 2000, untiIAugust 15.2000. Plaintiff, and child's siblings, at 101 North 2nd Street, Wormleysburg, PA, from late February 2000, until July 3, 2000. . P~tiff,c Defendant. and siblings, at 101 North 2nd Street, Wormleysburg, PA, from February 11,2000, until late February 2000. Plaintiff, and siblings; at ,101 North 2nd Street, Wormleysburg; PA, from' NovembeJ:a3~ J9-99, until:FebhIaty to:f2000~ ' I ~ Plaintiff,iDefen.dant.'41nll,siblings4dami Hargreaves,' Melissa..Timmerinan, Daniel Timmerman, and Abigail Timmerman, at 101 North 2nd Street, Wormleysburg, PA, from January 27,1999, until November 22,1999. Plaintiff, Defendant, and siblings,. Jami Hargreaves, Melissa Timmerman, and Daniel Timmerman,. at 212 Feru Avenue, Carlisle PA, from 11)95 until 1996. . c. DANIEL JOSIAH CHRISTIAN 'ImMERMAN F orthepast 5 years, this child has lived with: PlaintitTand child's siblings, Jami Hargreaves, Melissa Timmerman, Annely Timmemnan;and:AbigaiI 'fiilliDtnnan. : at 101 North 2nd Street. Wormleysburg, PA, from August 15, 2000. tlJ tbe present.. Plaintiff, Defendant, and siblings, at 101 North 2nd Street, Wormleysburg, PA, . fropl(J>gly4,;,~0,l):~,untilAuguSb15l..2000; : :"':3':,;'," 'I' _ -,'f'ft,:;"-', .'iP~n~"lmdl~ssiblingS,lan01North 2nd Street, Wormleysburg, PA, ~ ",'~!D'lateFebruar.yaOOO.until July 3, 2000.. Plaintiff, Defendant. and siblings, at 101 North 2nd Street, .... Wonnleysburg; PA, froDi'FebruaryH;2000, lintillate February 2000. . f' .Plaintiff,. and siblings; ilt 101 N6rth:2nd Street,Wonnleysbutg; P A; frdui '0' Noveml,)er.23; 1999-, until<February 10. '2000. Plaintiff, Defendant. and siblings, Jami Hargreaves, Melissa Timmerman. Annely Timmerman, and Abigail Timmerman, at 101 North 2nd Street, Wormleysburg, PA, from January 27,1999, until November 22,1999. Plaintiff, Defendant, and siblings, Jami Hargreaves, Melissa Timmerman, and - ,1'1 -. '" "","'~ . r ~ " "-:-, .',: . AnnelyTmmennan, at212:Feru AVellUe; CarlistePA, from 19-9-5 until 19-96. d. ABIGAILVICTORIATIMMERMAN For the pastS years; this clilldbas' lived with: Plaintiff and child's siblings, Jami Hargreaves, Melissa Timmerman, Annely Timmerman, and Daniel Timmerman, ~ 10l North 2nd Sti'eet.Womifeysblirg, P A, from . August15,;2000, to the present. Plaintiff, Defendant, and siblings, at 101 North 2nd Street, Wormleysburg, PA, from July 4,2000, until August 15,2000. 'Plaintiff, andchild'Ssiblin'gsi'ilt'10tNorth2ndStreet, Wonnleysburg.PA, o fromlilte February 2000;'untlIJuly3, 2000. Plaintiff, Defendant, and siblings, at 101 North 2nd Street. Wormleysburg, PA,from February 11,2000, until late February 2000. Plaintiff, and siblings, at 101 North 2nd Street, Wormleysburg, PA, from November 23, 1999, until February 10,2000. . PlaintitT,Defendant, and siblings, at 101 North 2nd Street, Wormleysburg, PA, from Abigail birth on January 27, 19-99-, until November 22, 19-99-. 15. The folloWing other minor child/renpresently live with Plaintiff: a. JAMI KRISTA HARGREAVES Age: 16 yrsold The Plaintiffs: relationship to. this child is: .motller ;, : ",;,1 16. ThefactS'oftnemost recent incident of abuse are as follows: On about Tuesday, November 07, 2000 location: 101 North 2nd Str~t, Wormleysburg, PA, Plaintiff's residence. On ofaboufNovemfte'r7, 2000, Defendltll't'de~andedfuoney from Plaintiff, yelled at her when she told him she had nomoney to givebim~ repeatedly called her vile n~mes in the presence of the parties'.Jinor tllildren, followed her tbout the lioiIse 'yelling' and screaming'at her as she tried to get away from him, and used his shoulder to shove her aside causing her to fall against the wall. At least twice in or about November 2000, Defendant gained entry to Plaintiff's residence while she was away, once by jimmying open a window, and on a separate occasion, by removing the <' "," ri" - '";" :'rI~ .' ~ _'I ---. ".... -~- trim and glass on the door and unlocking it. Alarmed and fearing for her safety and that of her minor children, Plaintiff reported the incidents to the police. 17. 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 October 2000, Defend!Ult grabbed the parties' 9-year-old daughter, Annely, by the neck with both his hands, and dragged her into the next room, traumatizing the child. Since approximately August 2000, when Defendant has become angry with the parties' 4-year- old son, Daniel, he has yeBed at the child and threatened to kill him. In or about July 2000, Defendant threatened to "puB an O.J.(Simpson)" on Plaintiff causing her to fear for her life. Defendant further threatened Plaintiff by specitying his plan to kill her and dispose of her body. On or about July 7, 2000, in the presence of Plaintiff, Defendant told the parties' family physician that he heard voices in his head, and described how he had inDicted wounds on his hands and face weeks before the appointment. The doctor prescribed medication for Defendant and'recommended that he immediately commit himself to Holy Spirit Mental Health Unit for treatment. Defendant did not take the prescribed medication nor admit himself to the mental health unit as recommended by his physician. Defendant has a history of threats to kill Plaintiff, the children and himself which exacerbates Plaintiff's fear. Since approximately 1999, Defendant has threatened to kill himself several times telling Plaintiff, "IT you leave me alone, you might not fmd me alive." Defendant's mental instability and repeated threilts to kill her, her children, others, and himself cause Plaintiff to fear for her safety and that of her children. In or about October 1999, Defendant kicked the walker with the parties' 9-month"0Id daughter, Abigail, in it with such force that the walker and child roBed across the room and into the next room. The incident traumatized the baby causing her to cry and scream. In or about early NDvember 19-9S, when Plaintiff was about S-months-pregnant with the parties' daughter, Abigail, Defendant jerked grDcery bags out DfPlaintiff's hands causing her to lose bier balance and faD forward to the ground..When Plaintiff went into the house, Defendilnt kicked the kitchen cupboard while wearing his biker boots causing a hole in the cupboard and causing Plaintiff to feRr for her safety. 18. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: WEST SHORE REGIONAL POLICE DEPARTMENT ~.,."_~ <="i. ~.. _ 1 _. ::y 19. There is an immediate and present danger of further abuse from the Defendant. 20. Plaintiff is asking the court to evict and exclude the Defendant from the following residence: 101 North 2nd Street VVormleysburg,PA17043 Owned By: Kathy Ann Timmerman and Bart Karlton Timmerman 21. The Defendant owes a duty of support to Plaintiff and/or minor child/ren. 22. FOR THE REASO~SSET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY ORD:ER,.and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: a. R~ainDefendant 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 Plaintifl's residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff. c. Award Plaintiff temporary custody of the minor child/ren and place the following restrictions on contact between Defendant and child/ren: Defendant's contact with the minor children is suspended pending further Order after the hearing scheduled in this matter. d. Prqhibit Defendant from having any contact with Plaintiff and/or minor child/ren, eitlj.er in person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Plaintifl's school, business, or place of employment, except as the court may find necessary withrespectto partial Custody andior visitation with the minor child/ren. e. ProhibitDefendant from having any contact withPlaintifl's relatives and Plaintifi'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. f. Order Defendant to pay temporary support to Plaintiff and/or the minOI: child/ren, including medical support and payment of the rent or mortgage on the residence. g. Order Defendant to pay the costs of this action, including filing and service fees. h. Order the following additional relief, not listed above: Order Defendant to refrain from harassing Plaintiff's relatives. ,~- Date: I _J; ,_~ ~'"" lib ,,-'_ Enjoin Defendant from damaging or destroying any property owned jointly by the parties or solely by Plaintiff. Order Defendant to pay $250.00 to one of Legal Services, Inc.'s funding sources for the cost of litigating this case. 1. Grant such other relief as the court deems appropriate. J. 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. /,;J / 7/ (}<) / I Respectfully submitted, ~..~ LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 , .'," -'I - i_k^-' 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.~4904, relating to unsworn falsification to authorities. Dated: jf)~f/tg / ~'iil~I;!li;J"I'~;,-h~,&.I>1ivmi!!i<!li~ioo!!llll~~~"',dii\i""'V'J",g*,'I~~ili','j"fu~h~~~~V~ fi f ~. ~ :S' tt .s\-. ~ \::; 1'" ?-- .L. c... ,~ 0<0_ .~,~ ~ ,7 '...... :l::: t: B .3 In , _ _~~, "<"" ,~"e ,,_, . ~ ,~ ~, ~ ~~ rg~~[HiJlflli -li' ''''-~jil!',*r.lmlllWiili;'''~~' ~ __ . >\l!i!'li.,jj- ~ 'f,,'tIi-~.' () 0 C 0 0 <- J"J r -Om g :;j ~rn :J..) C") ?-h?J 2r--- , C/J>, ~-~58 --- -:.;;~ .-J r-"::C_" ,-, ' f'"-' ;<::d >:'~cj ~ ~o " \~5~3 ::1<; 5>0 --:'7"\.) c: s-:> <5'!} 2~ -, =< <:- 'Io. - :0 -< "-- n ~ -,' ~, ,-~" '==-"'"' ~"--'"~- .- I -,',-1 , ,~ -.~ ~~. 12/07/00 THU 16:45 FAX 717 240 6573 . , cmm CO PROTHONOTARY *************************** on MULTI TN REPORT no *************************** TXlRX NO INCOMPLETE TX/RX TRANSACTION OK 2332 01]9p2405331 03]9p2438026 04]92490779 CENTRAL PROCESS LEGAL SERVICES PSP ERROR ". OFFICE OF 'IHE PROI'HClIK7I'ARY CUMBERLAND CCXJNT'{ axJR'IHCllSE . ONE COORTHOOSE SQUARE CARLISLE. PA. 17013-3387 (71il 240-6195 FAX I: psP LS C. e n:l (0 I q - cl40 FAX (71?) 240-6573 V I ATE L E COP I E R TO: ?rOL-t' 5S~ltj 5331 ~: CURTIS R. LONG RE: :P FA OrrJ.-eifS MeSSAGE: !;II . ..:( ~' .. .. 00. OF PAGES (IN:r..uoING <XlVE1l SHEET) .--:' This ~ is int:al1;D ally fbL tte lEe of liE irrlividl.el OC altity lD ~ is is c>l.h. :1. ard lffi,' aI1b:tin infulmll:irn liBt is p;ivila;J;'d, o:nfit.Ential a"rl el<B1lX fm11 i1i.....,Oi>JrB um- 'llJl i.-..nl.. laN. rf tte ~ if: tttis" ~is rot tie inlElUs:l re::ipimt;, }OJ are ten:by rotified tl'at 8:1;1 ~tia1. di.sttiI:l.Ibm cr awing of this aronnicatim ill strictly p:d:tibitErl. [f p..t tl'M! re:Ei,vro IJUS amllnio::ia1 in ecror:, ple:Be mtify lB itmeiiately q,. telEth:re ,;rd tetum tie .xig:iral...$"1' to u; al rtP ;tn..- ~ viii tip. ~L!,;_ .......~,,' "..,.,,-j,.., ~ "",, , . KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Vicotria Timmerman, Plaintiffs VS. BART KARLTON TIMMERMAN, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA · CIVIL ACTION - LAW i NO. 00- ~,~&5'- CIVIL TERM : 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 heating scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting tlhe 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 the/? day of December, 2000, at ff~, .~d/Jn., in Courtroom No. -$ on the 4* floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA. You MUST obey the Order that is attached umil it is modified or terminated by the court after notice and heating. If you disobey this Order, the police may arrest you. Vi{~lation oft~is Drder may subject you to a charge of indirect criminal contempt which is punishable by a fin,, of up to ~!,000..00 .and/or, up to,..six months in jail under 23 Pa.C.S. §6114. Violation may also subject you to prosecfltton aaa crm~nm penames under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. §2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. § 2261-2262. You should take this paper to your lawyer at once. You have the right to have a lawyer represent you at the heating. 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, Penusylvama 17013 Telephone Numbor: (717)249-3166 AMi~IIICANS Wll'l~ DISA~IIATIES 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 courL please contact our office. All arrangements must bo made at least 72 hours prior to any hearing or business before the court. You muSt attend the scheduled conference or hearing. KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Victoria Timmerman, Plaintiffs V. BART KARLTON TIMMERMAN, Defendant In the Court of Common Pleas of CUMBERLAND County, PENNSYLVANIA Civil Action- Law No. 00- Protection From Abuse & Custody TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: BART KARLTON TIMMERMAN Defendant's Date of Birth is: September 3, 1960 Defendant's Social Security Number is: 493-74-8441 Name(s) of All protected persons, including Plaintiff and minor children: 1. KATHY ANN TIMMERMAN 2. JAMI KRISTA HARGREAVES 3. MELISSA SUSAN TIMMERMAN 4. ANNELY EIJZABETH KATHRYN TIMMERMAN 5. DANIEL JOSIAH CHRISTIAN TIMMERMAN 6. ABIGAIL VICTORIA TIMMERMAN AND NOW, on 7th Day of December, 2000 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters; the following Temporary Order: Plaintiff's request for a temporary protection order is granted. 1. Defendant shall not abuse, harass, stalk or threaten any oftbe above persons in any place where they might be found. 2. Defendant shall be evicted and excluded from the residence at: 101 North 2nd Street Wormleysburg, PA 17043 or any other permanent or temporary residence where Plaintiff or any other person protected under this Order may live. Plaintiffis granted exclusive possession of the residence. 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 for such contact with the minor child/mn 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 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 current residence and any other place whe~re she and/or the minor children may stay during the term of this Order. The schools of the minor children. 4. Except for such contact with the minor child/ten 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 heating in this matter, Plaintiffis awarded temporary custody of the following minor child/ten: 1. MELISSA SUSAN TIMMERMAN 2. ANNELY ELIZABETH KATHRYN TI3dMERMAN 3. DANIEL JOSIAH CHRISTIAN TIMMERMAN 4. ABIGAH, VICTORIA TIMMERMAN Until the final hearing, all contact between Defendant and the child/ren shall be limited to the following: Defendant's contact with the minor children is suspended pending further Order after the hearing scheduled in this matter. 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. T~ follow~g additional relief is granted: Defendant is prohibited from having any contact with Plaintiff's relatives. Defendant is ordered to refrain from harassing Plaintiff's relatives. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or solely by Plaintiff. 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified berea~er: WEST SHORE REGIONAL POLICE DEPARTMENT 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 APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL JUNE 7, 2002 OR UNTIL OTHERWISE MODWIF. D OR TERMINATED BY TillS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months in jail. 23 Pa.C.S. §6114. Consent of the Plnintiffto 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. CS. §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. §{}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, ffdefendant violates Paragraphs 1 through 5 of this Order, defendant shall be arrested on the charge of Indirect Crimir~al 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 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 ora crime, in which case, they shall remain with the law enforcement agency whose officer made the t ' ! Judg, Distribution to: Joan Carey, Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row, Carlisle, PA 17013 (717) 243-9400 FAXed & mailed to PSP KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Victoria Timmennan, Plaintiffs V. BART KARLTON TIMMERMAN, Defendant PFADNumber:WMl165596X : In the Court of Common Pleas of : : CUMBERLAND County, : : PENNSYLVANIA .. : Civil Action - Law .. : No. 00- : Protection From Abuse & : Custody PETITION FOR PROTECTION FROM ABUSE Plaintiffs name is: I, (the Plaintiff), am filing this Petition on behalf of.' - myself - and as Parent of minor Plaintiff(s) 3. Name(s) of ALL person(s), including minor children, who seek protection fi-om abuse. a. KATHY ANN TIMMERMAN b. JAMI KRISTA HARGREAVES c. MELISSA SUSAN TIMMERMAN d. ANNELY EIJZABETH KATHRYN TIMMERMAN e. DANIEL JOSIAII CHRISTIAN TIMM~RMAN f. ABIGAIL VICTORIA TIMMERMAN 4. Plaintiffs Address is: 101 North 2nd Street, Wormleysburg, PA 17043 5. Defendant's Name is: BART KARLTON TIMMERMAN Defendant is believed to live at the following address: c/o Augustus "Auggie" Tokish, Carlisle, PA 17013 7. Defendant's Social Security Number is: 493-74=8441 8. Defendant's Date of Birth is: September 3, 1960 9. Defendant's Place of employment is: Roadway Express, 100 Carlisle Drive, Carlisle, PA i0. Defendant is an adult. 11. The relationship between the Plaintiffand the Defendant is: Spouse Parents of the same children 12. The PlalntilTand the Defendant been involved in the following court actions: a. Support 13. Plaintiff and Defendant are the parents of the following minor child/ren: a. MELISSA SUSAN TIMME~ Age:fl years old hi/ds address ts: 101 North 2nd Street, Wormleysburg, PA 17043 b. ANNELY ELIZABETH KATHRYN TIMMERMAN Age:9 years old Child's address is: 101 North 2nd Street, Wormleysburg, PA 17043 c. DANIEL JO SIAH CHRISTIAN ,TIMMEI~J~AN Age:4 years, old Child's address is: 101 North 2nd Street, Wormleysburg, PA 17043 d. ABIGAIL VICTORIA TIMMERMAN Age:l year old Child's address is: 101 North 2nd Street, Wormleysburg, PA 17043 14. Plaintiff is seeking an Order of child custody as part of this petition. The following is a llst~ of the children and where they have live for the past 5 years: MELISSA SUSAN TIMME~ For the past 5 years, this child has lived with: Plaintiff and child's siblings, Jami Hargreaves, Annely Timmerman, Daniel Timmerman, and Abigail Timmerman, at i l01North 2nd Street, Wormleysbnrg, PA, from August 15, 2000, to the present. Plaintiff, Defendant, and Siblings, at 101 North 2nd Street, WOrmleYsburg, PA, from July 4, 2000, until August 15, 2000. Plaintiff, and child's siblings, at 101 North 2nd Street, WormleysbUrg, PA, from late February 2000, until July 3, 2000. Plaintiff, Defendant, and siblings, at 101 North 2nd Street, Wormleysburg, PA, from February 11, 2000, until late February 2000. Plaintiff, and siblings, at 101 North 2nd Street, Wolnnleysburg, PA, from November 23, 1999, until February 10, 2000. Plaintiff, Defendant, and siblings, Jami Hargreaves, AnnelY Timmerman, Daniel Timmerman, and Abigail Timmerman (DOEr: 01/27/99), at 101 North 2nd Street, Wormleysburg, PA, from January 27, 1999, until November 22, 1999. Plaintiff, Defendant, and siblings, Jami Hargreaves, Annely Timmerman, and Daniel Timmerman (DOB: 12/04/96), at 212. Fi~ru Avenuer, CarliSle PA, from 199~ until 1996. ANNELY ELYZABETH KATHRYN TIMMERMAN For the past 5 years, this child has lived with: Plaintiff and child's siblings, Jami Hargreaves, Melissa Timmerman, Daniel Timmerman, and Abigail Timmerman, at 101 North 2nd Street, Wormleysburg, PA, from August 15, 2000, to the present. Plaintiff, Defendant, and siblings, at 101 North 2nd Street, Wormleysburg, PA, from July 4, 2000, until August 15, 2000. Plaintiff, and child's siblings, at 101 North 2nd Street, Wormleysburg, PA, from late February 2000, until July 3, 2000. Plaintiff, Ilefendant, and siblings, at 101 North 2n~rl Street, Wormleysburg, PA, from February 11, 2000, until late February 2000. Plaintiff, and siblings, at 101 North 2nd Street, Wormleysburg, PA, from November ~3~ 1999, until February 10~ 2000. Plaintiff, Defendant,and siblings~ Jami Hargreaves, Melissa Timmerman, Daniel Timmerman, and Abigail Timmerman, at 101 North 2nd Street, Wormleysburg, PA, from January 27, 1999, until November 22, 1999. Plaintiff, Defendant, and siblings, Jami Hargreavel, Melissa Timmerman, and Daniel Timmerman, at 212 Fern Avenue, Carlisle PA, from 1995 until 1996. DANIEL JOSIAH CHRISTIAN TIMMERMAN For the past 5 years, this child has lived w~th: Plaintiff and child's siblings, Jami Hargreaves, Mel~issa Timmerman, Annely Timmerman, and Abigail Timmerman, . at 101 North 2nd Street, Wormleysburg, PA, from August 15, 2000, tothe present. Plaintiff, Defendant, and siblings, at 101 North 2nd Street, Wormleysburg, PA, from July 4, 2000~ until August 15, 2000~ .Plaintiff, and child's siblings, at I01 North 2nd Street, Wormleysburg, PA, from late February 2000, until July 3~ 2000. Plaintiff, Defendant, and siblings, at 101 North 2nd Street, Wormleysburg, PA, from February 11, 2000, until late February 2000. Plaintiff, and siblings, at 101 North 2nd Street, WolnnleysbUrg, PA, from November 23, 1999, until February 10, 2000. Plaintiff, Defendant, and siblings, Jami Hargreaves,. Melissa Timmerman, Annely Timmerman, and Abigail Timmerman, at 101 North 2nd Street, Wormleysburg, PA, from January 27, 1999, until November 22, 1999. Plaintiff, Defendant, and siblings, Jami Hargreaves, Melissa Timmerman, and Annely Timmerman, at 212 Fern Avenue, Cnrlisle PA, from 1995 until 1996. ABIGAIL VICTORIA TIMMERMAN For the past 5 years, this child has lived with: Plaintiff and child's siblings, Jami Hargreaves, Melissa Timmerman, Annely Timmerman, and Daniel Timmerman, at 101 North 2nd Street, Wormleysburg, PA, from August 15, 2000, to the present. Plaintiff, Defendant, and siblings, at 101 North 2nd Street, Wormleysburg, PA, from July 4, 2000, until August 15, 2000. Plaintiff, and child's siblings, at 101 North 2nd Street, Wormleysburg, PA, from late February 2000, until July 3, 2000. Plaintiff, Defendant, and siblings, at 101 North 2nd Street, Wormleysburg, PA, from February 11, 2000, until late February 2000. Plaintiff, and siblings, at 101 North 2nd Street, Wormleysburg, PA, from November 23, 1999, until February 10, 2000. Plaintiff, Defendant, and siblings, at 101 North 2nd Street, Wormleysburg, PA, from Abigail birth on January 27, 1999, until November 22, 1999. 15. The following other minor child/ren presently live with Ptainti~: JAMI KRISTA HARGREAVES Age: 16 yrs old The Plaintiffs relationship to this child is: mother 16. The facts of the most recent incident of abuse are as follows: On about Tuesday, November 07, 2000 location: 101 North 2nd Street, Wormleysburg, PA, Plaintiff's residence. On or about November 7, 2000, Defendant demanded money from Plaintiff, yelled at her when she told him she had no money to give him, repeatedly called her vile names in the presence of the parties' minor children, followed her about the house yeliing and screaming at her as she tried to get away from him, and used his shoulder to shove he.r aside causing her to fall against the wall. At least twice in or about November 2000, Defendant gained entry to Plaintiff's residence while she was away, once by jimmying open a window, and on a separate occasion, by removing the trim and glass on the door and unlocking it. Alarmed and fearing for her safety and that of her minor children, Plaintiff reported the incidents to the police. 17. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor child/rea, (including any threats, injuries, or incidents of stalking) are as folk~ws: In or about October 2000, Defendant grabbed the parties' 9-year-old daughter, Annely, by the neck with both his hands, and dragged her into the next room, traumatizing the child. Since approximately August 2000, when Defendant has become angry with the parties' 4-year- old son, Daniel, he has yelled at the child and threatened to kill him. In or about July 2000, Defendant threatened to "pull an O.J.(Simpson)" on Plaintiff causing her to fear for her life. Defendant further threatened Plaintiff by specifying his plan to kill her and dispose of her body. On or about July 7, 2000, in the presence of Plaintiff, Defendant told the parties' family physician that he heard voices in his head, and described how he had inflicted wounds on his hands and face weeks before the appointment. The doctor prescribed medication for Defendant and recommended that he immediately commit himself to Holy Spirit Mental Health Unit for treatment. Defendant did not take the prescribed medication nor admit himself to the mental health unit as recommended by his physician. Defendant has :~ history of threats to kill Plaintiff, the children and himself which exacerbates Plaintiff's fear. Since approximately 1999, Defendant has threatened to kill himself several times telling PlaintilT, "If you leave me alone, you might not find me alive." Defendant's mental instability and repeated threats to kill her, her children, others, and himself cause Plaintiff to fear for her safety and that of her children. In or about October 1999, Defendant kicked the walker with the parties' 9-month-old daughter, Abigail, in it with such force that the walker and child rolled across the room and into the next room. The incident traumatized the baby causing her to cry and scream. In or about early November 1998, when Plaintiffwas about 8-months=pregnant with the parties' daughter, Abigail, Defendant jerked grocery hags out of plaintiff's hands causing her to lose her balance and fall forward to the ground. When Plaintiffwent into the house, Defendant kicked the kitchen cupboard while wearing his biker boots causing a hole in the cupboard and causing Plaintiff to fear for her safety. 18. The police department(s) or law enforcement agencies that should be prodded with a copy of the protection order are: WEST SHORE REGIONAL POLICE DEPARTMENT 19. There is an immediate and present danger of further abuse from the Defendant. 20. Plaintiffis asking the court to evict and exclude the Defendant from the following residence: 101 North 2nd Street Wormleysburg, PA 17043 Owned By: Kathy Ann Timmerman and Bart Karlton Timmerman 21. The Defendant owes a duty of support to Plaintiff and/or minor child/ran. 22. FOR ~ REASONS SET FORTH ABOVE, I REQUEST TiIAT THE COURT ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO ~ FOLLOWING: a. Restrain Defendant fi-om abusing, threatening, harassing, or stalking Plaintiff and/or minor child/rea in any place where Plaintiff may be fmmd. b. Evict/exclude Defendant from Plaintiffs residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff c. Award Plaintifftemporary custody of the minor child/ten and place the following restrictions on contact between Defendant and child/rea: Defendant's contact with the minor children is suspended pending further Order after the heating scheduled in this matter. Prohibit Defendant from having any contact with Plaintiff and/or minor child/rea, either in person, by telephone, or in writing, personally' or through third persons, including but not limited to any contact at Plaintiff's sc.hool, 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. Prohibit Defendant from having any contact with Plaintiff's relatives and Plaintiffs children listed in this petition, except as the court may :find necessary with respect to partial custody and/or visitation with the minor child/rea. f.. Order Defendant to pay temporary support to Plain~Jffand/or the minor child/ren, including medical support and payment of the rent or mortgage on the residence. g. Order Defendant to pay the costs of this action, including filing and service fees. h, Order the following additional relief, not listed above: Order Defendant to refrain from harassing Plaintifl,s relatives. Enjoin Defendant from damaging or destroying any property owned jointly by the parties or solely by Plaintiff. Order Defendant to pay $250.00 to one of Legal Services, Inc.'s funding sources for the cost of litigating this case. Grant such other relief as the court deems appropriate. 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. Date: Respectfully submitted, LEGAL SERVICES, ~IC. 8 Irvine Row Carlisle, PA 17013 (717) 243 -9400 VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are tree and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S.§4904, relating to unswom falsification to authorities. Dated: ~x~/~/~//~, , Kat/hy~n Title'herman, Plaintiff 12/07/00 TItU 16:45 FAX 717 240 6573 CUMB CO PROTHONOTARY ~001 TX/RX NO INCOMPLETE TX/RX TRANSACTION OK ERROR *************************** MULTI TN REPORT 2332 0119p2405331 0319p2438026 04]92490779 CENTRAL PROCESS LEGAL SERVICES PSP CURTIS R, LONG OFFIC~ OF THE PRCYrHo~Z/YARY CL~ERLAND COUNTY CX3URTHOUSE ONE COURTHOUSE SQUARE CARLISLE, PA. 17013-3387 (717} 240-6195 FAX [717) 240-6573 VIA TELECOP I E R FA Orders NO. OF PA(~S (~NCLUDING COVER SHEET) '"" KATHY ANN TIMMERMAN, for herselfand on behaifofher minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmennm~ and Abigail Vicotria Timmerman, Plaintiffs VS. BART KARLTON T1MME~, Defendant : IN THE COURT OF COMMON PLEAS OF · CUMBERLAND, COUNTy, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 00-8505 CIVIL TERM : PROTECTION FROM ABUSE : AND CUSTODY MOTION FOR CONTINUANCE PlaintS, Kathy Ann Timmermm~ by and through her attorney, Joan Carey of Legal Services, Inc., moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. A Temporary Protection From Abuse Order was issued by this Court on December 7, 2000, scheduling a hearing for December 13, 2000, at 10:30 a.m. 2. The Cumberland County Sheriffs Department served Defendant with a certified copy of the Notice of Hearing, Temporary Protection From Abuse Order and Petition for Protection From Abuse on December 12, 2000, at the marital residence located at 101 North 2nd Street in Wormleysburg, Cumberland County, Pennsylvania, at approximately I 1:00 a.m. 3. Defendant has retained Michael A. Koranda ofTomasko & Koranda PC, to represent him in the matter 4. The parties agree, by and through their respective counsel, that the hearing be rescheduled. 5. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of 18 months, through June 7, 2002, or until further' Order of Court, whichever comes first. WHEREFORE, Plaintiffrequests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in effect for a period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, whichever comes first. Respectfully, submitted, ~goan Carey, Attorney for Pla~ilT LEGAL SERVICES, INC. 8 h-vine Row Carlisle, PA 17013 (717) 243 -9400 KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman,. Daniel Josiah Christian Timmerman, and Abigail Victoria Timmerman, Plaintiffs V. BART KARLTON TIMMERMAN, Defendant : In the Court of Common Pleas of : : CUMBERLAND County, : PENNSYLVANIA : Civil Action - Law : : No. 00-8505 : : Protection From Abuse & : Custody CONTINUED TEMPORARY ORDER Day of December, 2000, pursuant to 23 Pa C.S. §6107(c), the terms and conditions of the Temporary Order issued on 7th Day of December, 2000, in the above-captioned case are hereby continued in full force and effect until further order of the court. A bearing on this matter is scheduled for the December 20, 2000, at 3:30PM in Courtroom No. 3 on the 4th Floor of the Cumberland County Courthouse, One Cot~d~ouse Square, Carlisle, Pennsylvania. Distribution To: Joan Carey, Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row, Carlisle, PA 17013 Michael A. Koranda, Attorney for Defendant TOMASKO & KORANDA PC 219 State Street, Harrisburg, PA 17101 12-1 -00 KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Vieotfia Timmerman, Plaintiffs VS. BART KARLTON TIMMERMAN, Defendant : 1N THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION .. LAW : NO. 00-8505 CI'vq~L TERM : PROTECTION ER. OM ABUSE : AND CUSTODY MOTION FOR CONTIN1UANCE Plaintiff, Kathy Ann Timmerman, by and through her attorney, Joan Carey of Legal Services, Inc., moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. A Motion for Continuance was filed on Decemher 14, 2000, and an Order for Continuance was entered on December 18, 2000, scheduling a hearing for December 20, 2000, at 3:30 p.m 2. The parties agree, by and through their respectNe counsel, that the Temporary Protection From Abuse Order shall remain in effect pending a hearing in the matter, which they desire to be rescheduled to a date approximately 6 months from the hearing date of December 20, 2000, or or until further Order of Court, whichever comes first. WHEREFORE, Plaintiffrequests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in effect pending further Order of Court. Respectfully submitted, Joan Carey ~1 ' Maryann MUrphy Attorneys fi>r Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 KATHY ANN TIMMERMAN, for herself and on behaifofher minor children: Sami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Katluyn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Victoria Timmerman, Plaintiffs V. BART KARLTON TIMM RMAN, Defendant : In the ,Court of Common Pleas of : : CUMBERLAND County, : : PENNSYLVANIA : : Civil Action - Law : : No. 00-8505 : : Protection From Abuse & : Custody No. 00-8505 CONTINUED TEMPORARY ORDER AND NOW, this 29th Day of December, 2000, pursuant to 23 Pa.C.S. §6107(c), the terms and conditions of the Temporary Order issued on 7th Day of December, 2000, in the above-captioned case are hereby continued in full force and effect. This order is in effect until June 7, 2002. A heating on this matter is scheduled for the June 26, 2001, at 3:30PM in Courtroom No. 3 on the 4th Floor of the Cumberland County Courthouse, One Courthouse Square, Carlisle, Pennsylvania. BY THE COURT: Judge Distribution To: J°an CareY, Attorney for Plaintiff COJ LEGAL SERVICES, INC. 8 Irvine Row, Carlisle, PA 17013 Michael A. Koranda, Attorney for Defendant TOMASKO & KORANDA 219 State Street, Harrisburg, PA 17101 SHERIFF'S RETURN - CASE NO: 2000-08505 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND TIMMERMA_N KATHY AIYN ET AL VS TIMMERNLAN BART KARLTON REGULAR STEVE WHISTLER Sheriff or Beputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon TIMMERMJ~N BART KARLTON the DEFENDANT , at 0011:15 HOURS, at 101 N. 2ND ST WORMLEYSBURG, PA 17043 on the 12t~ day of December 2000 by handing to BART KARLTON TIMMERM3~N a true and attested copy of PROTECTION FROM ABUSE & CUSTODY, NOTICE OF HEARING & ORDER, TEMPOraRY PROTECTION FROM ABUSE ORDER and at the same together with time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.54 Affidavit .00 Surcharge 10.00 .00 38.54 Sworn and Subscribed to before me this /~ day of A.D. rothonotary R. Thomas Kline 12/13/2000 Deputy Sheriff KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Vicotria Timmerman, Plaintiffs VS. BART KARLTON TIMMERMAN, Defendant : IN THE COURT OF COMMON PLEAS OF · CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 00-8505 CI~qL TERM : PROTECTION FROM ABUSE : AND CUSTODY MOTION FOR CONTINiUANCE Plaintiff, Kathy Ann Timmerman, by and through her attorneys, Joan Carey and David A. Lopez of MidPenn Legal Services, moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. A Motion was filed and an Order for Continuance was entered on December 29, 2000, rescheduling the hearing in the above-captioned case for June 26, 12001, at 3:30 p.m. 2. The parties agree, by and through their respective counsel that the hearing be rescheduled 3. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, whichever comes first. WHEREFORE, Plaintiffrequests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in effect for a period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, whichever comes first. Respec lly submitted, Joan Carey ' (] ~.~ David A. Lopez .~'~ Attorneys for Plaintiff MIl)PENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Tinunerman, Daniel Josiah Christian Timmerman, and Abigail Vicotria Timmerman, Plaintiffs VS. BART KARLTON T1MME~, Defendant ! IN THE COURT OF COMMON PLEAS OF · CUMBERLAND, COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 00-8505 CIVIL TERM PROTECTION FROM ABUSE AND CUSTODY AND NOW, IANCE _ day of June, 2001, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on Tuesday, June 26, 2001, at 3:30 p.m. by this Court's Order of December 29, 2000, is hereby rescheduled for hearing on Tuesday, August 14, 2001, at 3:30 p.m. in Courtroom No. 3 on the 4~ Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. The Temporary Protection From Abuse Order shall remain in effect for a period of 18 months from the date it was entered, through June 7, 2002, or until further Order &Court, whichever comes first. t Judge Joan Carey, Attorney for Plaintiff. ~. , .~ - 8 Ir'vine Row, Carlisle, PA 17013 MiChael A. Koranda, Attorney for Defendant Tomasko & Koranda p.C. 219 State Street, Harrisburg, PA 17101 KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Vicotria Timmerman, Plaintiffs VS. BART KARLTON TIMMERMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAN]) COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 00-8505 CIVIL TERM PROTECTION FROM ABUSE AND CUSTODY MOTION FOR CONTINUANCE Plaintiff, Kathy Ann Timmerman, by and through her attorneys, Joan Carey and David A. Lopez of MidPenn Legal Services, moves the Court for an Order rescheduling the heating in the above-captioned case on the grounds that: 1. A Motion was filed and an Order for Continuance was entered on June 26, 2001, rescheduling the hearing in the above-captioned case for Augus~t 14, 2001, at 3:30 p.m. 2. The parties agree, by and through their respective counsel, that the heating be rescheduled. 3. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, whichever comes first. WHEREFORE, Plaintiff requests that the Court grant this Motion and reschedule this matter for heating, and that the Temporary Protection From Abuse Order remain in effect for a period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, whichever comes first. Respectfi~lly submitted, David A. Lopez Attorneys for Plaintiff MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 or 1-800-822-5288 KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Victoria Timmerman, Plaintiffs VS. BART KARLTON TIMMERMAN, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW NO. 00-8505 C]!VIL TERM : PROTECTION FROM ABUSE : AND CUSTODY _ORDER FOR CONTINUANCE AND NOW, this t 7 ~day of August, 2001, upon consideration ofthe attached Motion for Continuance, the matter scheduled for hearing on Tuesday, at 3:30 p.m. by this August 14, 2001, Court's Order of June 26, 2001, is hereby rescheduled for hearing on Tuesday, November 20, 2001, at 3:30 p.m. in Courtroom No. 3 on the 4th Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. The Temporary Protection From Abuse Order shall remain in effect for a period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, whichever comes first. Joan Carey, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row, Carlisle, PA 17013 Michael A. Komnda, Attorney for Defendant Tomasko & Koranda P.C. 219 State Street, Harrisburg, PA 17101 By the Court, °e.H~3 President Judge KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Vicotria Timmerman, Plaintiffs VS. BART KARLTON TIMMERMAN, Defendant : 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 00-8505 CIVIL TERM PROTECTION FROM ABUSE AND CUSTODY MOTION FOR CONTINUANCE Plaintiff, Kathy Ann Timmerman, by and through her attorney, Joan Carey of MidPenn Legal Services, moves the Court for an Order continuing generally the heating in the above-captioned case on the grounds that: 1. A Motion was filed and an Order for Continuance was entered on August 14, 2001, rescheduling the hearing in the above-captioned case for November 20, 2001, at 3:30 p.m. 2. The parties agree, by and through their respective counsel that the hearing be continued generally. 3. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, whichever comes first. WHEREFORE, Plaintiffrequests that the Court grant this Motion and continue generally this matter, and that the Temporary Protection From Abuse Order remain in effect for a period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, whichever comes first. Respectfully submitted, (,~Joa~ Carey, Attorney for PJ~ntiff MIDPENrN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243 -9400 or 1-800-822.5288 KATHY ANN TIMMERMAN, for herself and on behalf of her m/nor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Victoria Timmerman, Plaintiffs VS. BART KARLTON TIMMERMAN, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW NO. 00-8505 CIVIL TERM PROTECTION FROM ABUSE AND CUSTODY .ORDER FOR CONTINUANCE AND NOW, this. day &November, 2001, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on Tuesday, November 20, 2001, at 3:30 p.m. by this Court's Order of August 14, 2001, is hereby continued generally. This Order is entered without prejudice to either party to request a hearing. The Temporary Protection From Abuse Order shall remain in effect for a period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, whichever comes first. By the Court, Joan Carey, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row, Carlisle, PA 17013 Michael A. Koranda, Attorney for Defendant Tomasko & Koranda P.C. 219 State Street, Harrisburg, PA 17101 George E. Holler, President Judge KATHY ANN TIMMERMAN, for herself and on behalf of her minor children: Jami Krista Hargreaves, Melissa Susan Timmerman, Annely Elizabeth Kathryn Timmerman, Daniel Josiah Christian Timmerman, and Abigail Victoria Timmerman, Plaintiffs VS. BART KARLTON TIMMERMAN, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : : CIVIL ACTION - LAW : : NO. 00~8505 CIVIL TERM : PROTECTION FROM ABUSE : AND CUSTODY FOR CONTINUANCE AND NOW, this day of November, 2001, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on Tuesday, November 20,2001, at 3:30 p.m. by this Court's Order &August 14, 2001, is hereby continued generally. This Order is entered without prejudice to either party to request a hearing. The Temporary Protection From Abuse Order shall reraain in effect for a period of 18 months from the date it was entered, through June 7, 2002, or until further Order of Court, whichever comes first. Joan Carey, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row, Carlisle, PA 17013 Michael A. Koranda, Attorney for Defendant Tomasko & Koranda P.C. 219 State Street, Harrisburg, PA 17101 By the Court,