Loading...
HomeMy WebLinkAbout00-08570 ,h~~"'-",'''' DEBORAH LYNN LUCIO, Plaintiff : IN TIlE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00- f?57o CIVIL TERM JOHN LUCIO, 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. A hearing on, this mlttler is scheduled on the M.. day ofDeeember, 2000, # 10 f... inCourtro~m No. ~ 4t11 Floor, Cumberland County Courthouse, I Courthouse Square, Carlisle, Pennsylvama. . . You MUST obey the Order that is attached until it is modified or tenninated by the court after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 andlorup to six monthsin jaiJunder 23 Pa.C.8. ~61l4. Violation may also subj.ect you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 UOS.C. ~2265, this Order is enforceable anywhere in the United States, tnballands, U.S, Territories and the Commonweahh ofPuerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S. C. ~ 2261-2262. You should take this paper to your lawyer at once. You have the right to have a lawyer represent you at the hearing. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth helow to find out where you can get legal help. If you cannot find a lawyer, you may have to proceed without ODe. 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. Jl " "'-"'-~ DEBORAH LYNN LUCIO, Plaintiff : In the Court of Common Pleas of : : CUMBERLAND County, v. : PENNSYLVANIA : Civil Action - Law JOHN LUCIO, Defendant . : No. 00- ?fJ10 : : Protection From Abuse TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: JOHN LUCIO Defendant's Date of Birth is: July 10.11)70 Defendant's Social Security Number is: 160-60-1642 Name(s)of All protected persons, including Plaintiff and minor children: 1. DEBORAH LYNN LUCIO AND NOW, on 12th 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 of the above persons in any place where they might be found. _.,"",..",,>;ffi'B~i., 2. Except for such <;ontact with the minor child/ren as may be permitted under paragraph 4 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 schoo~ business, or place of employment. Defendant is speci:lically ordered to stay away from the following locations for the duration of this order. PlaintiB's CUlTent residence and any place wllere slle may stay during tile term of tIIis Order. Plaintiff's current place of employment and any otller place wllere slle may be employed during tile term of this Order: Beaudry Oral Surgery 3600 Old Gettysburg Road Camp. Hill, PA Tile school of the minor child 3. Except for such contact with the minor child/ren as may be permitted under paragraph 4 of this Order, Defendant shall not contact Plaintifl: or any other person protected under this Order, by telephone or by any other means, including through third persons. 4. Pending the outcome of the final hearing in this matter, Plaintiff is awarded temporary custody of the following minor child/ren: 1. WHITLEY BRIANA ELIZABETH LUCIO Until the final hearing, all contact between Defendant and the child/ren shall be limited to the following: Pending further Order after the hearing scheduled in tIIis case, Defendant may have periods of partial custody with the parties' minor child on dates and at times mutually agreed by the parties. Defendant shaD contact PlaintiWs attorney in this matter to facilitate custody arran~ments. Defendant shall remain in his vehicle at all times during transfer of custody. The local law emoreement a~ncy in the jurisdiction where the ehildlren are Ioeated shall ensure that the ebildIren are placed in the eare and control of the Plaintiffin accordance with the terms of this Order. ." ~ , '~ "" "~ ~ 5. The fonowing additional relief is granted: Defendant is prohibited 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. Defendant is ordered to refrain from harassing the minor child or Plaintiff's relatives. Defendant is enjoined from damaging or destroying any property joindy ownetl by the parties or owned solely by Plaintiff. 6. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: CARLISLE POLICE DEPARTMENT LOWERt.l.T.ElIi TOWNSHIP POLICE DEPARTMENT 7. 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 win 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. 8. THIS ORDER APPLIES IMMEDIATELY TO DEFENI>ANT AND SHALL REMAIN IN EFFECT UNTIL JUNE 12,2002 OR UNTIL OTIlERWISE 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 oftij) to $1,000.00 and/or up to six monthsinjail.. 23 Pa.C.S. ~6114. Consent of the Plaintiff to Defendant's return to the residence shall not invalidate this Order, whichGlUl ~ be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. ~6113. Defendant is further notified that violation of this Order may subject himlher to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. ~~2261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS I ""'--'-i!l'~;:-wi"~ ~ ~L.J " ,.< ", .~ '" . ~ -d..,.."',l:<r"""'-...."'"c This Qfder shalt be enforced by the police who have jurisdiction over the plaintiff's reside~be DR any location where a violation of this order occtlrs DR where the defen~~tmay be located. If defendant violates Paragraphs I through 4 ofthis Order, defend~t shall be arrested on the charge of Indirect Criminal Contempt. An arrest for vi~l/ltion of this ,order may be made without warrant, based solely on probable cause; y,rhether or not the violation is committed in the presence of law enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threat~ed to be used during the violation of this ,order ,oR during prior incidents of I, abuse! }V eapons must forthwith be delivered to the Sherifi's office of the county whic~j~sued this ,order, which office shall maintain possession of the weapons until furtIler larder of this court, unless the weaponls are evidence of a crime, in which case, tlJ,ey shall remain with the law enforcement agency whose officer made the I arrest: ' Judge 4ltF' Distribution to: Joan Carey, Attorn~y for Plaintiff LEGAL SERVlCE$, INC. 8 Irvine Row,. Carli~le, PA 17013 (717) 243-9400 .' - - c~ ~eitt ~ }e) ~twV -Frvrvt l. 5.. ?\ ~~. fA) O.b I\)frt:- ~. I;)./"J..[D € 3~ l~ ?IV\ FAXed & mailed to PSP L,~.@~ C.f: ' :)~\1) ~IV\ "".""i.&..l,,-'"ilih, PFADNumber: XQll72116B DEBORAH LYNN LUCIO, Plaintiff : In the Court of Common Pleas of : CUMBERLAND County, v. : PENNSYLVANIA : Civil Action - Law : JOHN LUCIO, Defendant : No. 00- <g'51O : : Protection From Abuse PETITION FOR PROTECTION FROM ABUSE 1. Plaintiffs name is: DEBORAH LYNN LUCIO 2. I, (the Plaintift), am filing this Petition on behalf of: - myself 3. Name(s) of ALL person(s), ineluding minor children, who seek protection from abuse. a. DEBORAH LYNN LUCIO 4. Plaintift's Address is : 432 Arch Street, Carlisle, FA 17013 5. Defendant's Name is: JOHN LUCIO 6. Defendant is believed to live at the following address: 558 South Hanover Street, Room 3 ,Carlisle, P A 17013 _""t<;~,,-.,,t-M,,, 7. Defendant's Social Security Number is: 160-60-1642 8. Defendant's Date of Birth is: July 10, 1970 9. Defendant's Place of employment is: Dickinson School of Law - Penn State University Forestry Dept. 10. Defendant is an adnlt. 11. The relationship between the Plaintiff and the Defendant is: Spouse Parents ofthe same children 12. The Plaintiff and the Defendant been involved in the following court actions: a. Divon:e 13. Other details of the court action are: Cumberland ColUlty - No. 00- 14. Plaintiff and Defendant are the parents of the following minor child/ren: a. WHITLEY BRIANA ELIZABETH LUCIO Age:9 years old Child's address is: 432 Arch Street, Carlisle, PA 17013 15. Plaintiff is seeking an Order of cllild custody as part of this petition. The fullowing is a list of the children and where they have live for the past 5 years: a. WHITLEY BRIANA ELIZABETH LUCIO For the past 5 years, this child has lived with: Plaintiff at 432 Arch Street, Carlisle, P A, from lCt1051t1O tit the present. ," " - Illii>d" ; -""-;""i'~OI<1/.~~;,, PlaiDtift' and Defendant at 407 South Pitt Street, Car6sle, PA, from 8/93 to 10/05/00. Plaintiff and Defendant at 4205 San Juan Street, Tampa, FL, from, 7/97 to 8/98. Plaintiff and Defendant at 4213 San Juan Street, Tampa, FL, from 1995 to 7/97. 16. The facts of the most recent incident of abuse are as follows: On about Tuesday, December OS, 2000 location: 558 South Hanover Street, Room 3, Carlisle, PA, Defendant's home On or abont December 5, 2000, Defendant asked to speak with Plaintift'for a few minutes, and as she tried to leave, be blocked the doorway with his body and refused to let her out of the room. Only wben Plaintiff picked up the telephone and threatened to call the p06ce, did Defendant let her out of the room. Earlier the same day, Defendant telephoned Plaintiff at her place of employment twice, and during one of the telephone calIS lie threatened- ller $aying. "I know that your optimal way to die is in your sleep, but how does Howard want to die?" referring to the man Plaintiff is dating. 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: On or about December 3, 2000, Defendant telephoned Plaintift's residence several times. On or about December 2, 2000, Defendant,. who had picked up the parties' 9-year-old daughter, Whitley, for a weekend visit a few bours earlier, bad the child telephone PlaintitT at her residence approximately 15 times that evening, took the telephone from the child when Plaintiff aoswered,harassed Plaintift'abont the man she is datiog, and threatened lier saying, "If I can't bave you, DO one will"; "PO get back at you", and "I hate you". On or about December 1, 2000, Defendant told to Plaintift'tbat be was going to hang himself from the rafters in ber garage and that he woukl telepbooe ber before lie bURg Jrimself go. that she would be the first to find him. Defendant showed PlaintitT a piece of paper that he said was a suicide note that he has been carrying in bis pocket. On or about October 26, 2000, at Plaintiff's request Legal Services, loc. mailed Defendant a letter advising him to limit his communications with her to information relating to their cbild, and not to go to her residence uninvited (see attached Exhibit A, incorporated herein by reference). On or about October 15, 2000, Defendant agreed to go with PlaintitTto her divorce attoroey's office to accept service of the Divorce Complaint. As he left tbe attorney's office with Plaintiff, "I', , 'j C_"j.'""lh,t~<~S Defendant struck her in the face with the divorce papers. Later the same day, Defendant threatened Plaintiff saying that he was going to get back at her for having tiled for divorce. '18. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order m;e: CARLISLE POLICE DEPARTMENT LOWER ALLEN TOWNSHIP POLICE DEPARTMENT 19. There is an immediate and present danger of further abuse from the Defendant. 20. 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. Award Plaintiff temporary custody of the minor child/ren and place the following restrictions on contact between Defendant and child/ren: Pending further Order after the hearing scheduled in this case, Defendant may have periods of partial custody with the parties' minor child on dates and at times mutually agreed by the parties. Defendant shall contact Plaintit'rs attoruey in this matter to facilitate custody arrangements. Defendant shall rcmain in his vehicle at all times during transfer of custody. c. Prohibit Defendant from having any contact with Plaintiff and/or minor child/ren, either in person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Plaintiff's school, business, or place of employment, except as the court may tind necessary with respect to partial custody and/or visitation with the minor child/ren. d. Prohibit Defendant from having any contact with Plaintifi's relatives and Plaintifi's children listed in this petition, except as the court may tind necessary with respect to partial custody and/or visitation with the minor child/ren. e. Order Defendant to pay the costs of this action, including filing and service fees. ~ " . f Order the following additional relief, not listed above: Order Defendant to refrain from harassing the minor child or Plaintiff's relatives. Enjoin Defendant from damaging or destroying any property jointly owned by the parties or owned solely by Plaintiff. Order Defendant to pay $250.00 to one of Legal Services, Inc. 's funding sonrces to pay the cost of litigating this case. g. Grant such other relief as the court deems appropriate. h. Order the police or other law enforcement agency to serve the Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The petitioner will inform the designated authority of any addresses, other than theDefendant's residence, where Defendant can be served. / Respectfully Submitted by: Agency: oan Carey Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 ~' , '~4 L~:, bl<__~'", VERIFICA TION 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 fulsification to authorities. Dated: /0- / II /00 D!J..=Z~ ,-"llfm;jur -,,"", ~'-' f~~ ." = . 'wi _""",u..-,MoO'",",,_'; ! i:' , , , LEGAL SERVICES, INC. 8 Irvine Row Carlisle, Pennsylvania 17013 (717) 243-9400 Fax (717) 243-8026 West Shore (717) 766-8475 Shippensburg (717) 530-5866 Franklin Farm Lane Cbambersburg, Pennsylvania 17201 (717)264-5354 4235.WasltingtonSlreet Gettyl;burg, Pennsylvania 17325 (717)334-7623 October 26, 2000 John Lucio 558 South Hanover Street Carlisle,PA 17013 Mr. Lucio: Ms. Lucio recently came to our office to discuss incidents which have occurred in which she says that you have harassed her and physically abused her. This letter is to inform you that future contact with Ms. Lucio is to be limited to connm~cation regarding your daughter, Whitley. You are also advised that if you go to her residence uninvited or to her place of employment while she is there working, you will be considered a defiant trespasser. The penalty for defiant trespass is up to one year imprisonment. Ms. Lucio has been advised of the criminal and civil remedies available to her in Pennsylvania. You should be aware that the criminal laws apply to acts of violence even when they occur between persons who are married. The penalty for simple assault, which can include "attempts by physical menace to put another in fear of imminent serious bodily injury" is up to two years imprisonment and a $5,000. 00 fine. For harassment (including striking, shoving, kicking, alarming or seriously annoying a person), the punishment is up to a $300.00 fine and 90 days imprisonment. Harassment by cOIIllllunication is also a crime punishable by up to one year in prison or a $2500 fine. The crime of stalking includes engaging in a course of conduct such as followitig someone without proper authority intending to cause the person fear of bodily injury or substantial emotional distress. Stalking is punishable by imprisonmeht for up to seven years. Ms. Lucio has also been advised of a civil remedy available under the Protection From Abuse Act. Under this Act, she can petition the court to issue a Protection From Abuse Order. If such an order is entered, it will be placed on file with the police, and if you violate the order, you will be taken before the judge who issued the order. The judge will then decide what punishment is appropriate. A person who violates such an order can be imprisoned for up to six months and/or assessed a fine up to $1000. . Ms. Lucio wants you to be aware that if you physically abuse her, threaten her with violence, harass and/or stalk her, contact her directly oriB~Bl"'~ for the specific purpose of discussing SERVING ADAMS, CUMBERLAND, FRANKLIN AND FULTON COUNTIES . Un!\;!!!! """"",~~i'O~' <~.~ r~"~ ~ "-"~""".""-"""''''''"-"',; John Lucio October 26, 2000 Page 2 issues regarding your child, or come to her home uninvited or to her place of employment, she will take legal action against you. Ms. Lucio hopes that your knowledge of the legal consequences of violent behavior will eliminate any such behavior by you in the future. Sincerely, LEGAL SERVICES, INC. /"1 ~ ( ~ / , /. ,.../ 1'., ..; " LJ { _ / .jr-rA,,,p4'/ ....Att-"z..c-C__j/ ?Jo-an Carey if v Attorney at Law cc: Deborah Lynn Lucio Carlisle Police Department Lower Allen Township Police Department Gregory L. Cutler, Attorney at Law ~r.~Iil!I,.";'"~~~i~\1i~;ttJ.r#!Y#")il!I~~~W&;Jl~i,(fdi~","';\<:' rft nt ... ~ :>-. ..., !-' "t u. , ., ~ ) ,',^ ",~,~,'<,.~_",_ "..;;:1" ~^ '''',~~,~,<'' v", ~,,,,"',"" >",;;';1 i'l~};;,;,y",,,l;,,,,,,,,~~,b'J.]',Mili1i~~IM!~,,l'I!i'\'Ii.~"~_'~~~'''~.' p i': . ~ ,~ . ,"~ t ';'r,~.t~ '{) ~ s. u(D ITi-rn Z:XJ -;:--,..,.- U))-,. -/-;';" ~O :~ >;C) €=b Pc 2": :< t '!In't 'i I ! D C) c::') ;-i1 n Q " ._( := :TI , j"J,r~ -rolTl .,.} 1:-:1 -;::.'--." ~f " ~d I-r; ~~21~ ~~h; '-, s.::;J :rJ -< N -n ~ r:- U1 J' '''' " , ~, " ,j'~~.\iLukL.i"A< 12/12/00 TUE 15:18 FAX 717 240 6573 CUMB CO PROTHONOTARY ~001 *************************** *** MULTI TN REPORT *** *************************** TXlRX NO INCOMPLETE TX/RX TRANSACTION OK 2337 0l]9p2405331 03]9p2438026 04]92490779 CENTRAL PROCESS LEGAL SERVICES PSP ERROR OFFICE OF 'IlIE POOrHCNOTARY CUMBERLAND CCONTY CXlUR1ll00SE CXIlE CXXJRTHCUSE SQUAllE CARLISLE, PA. 17013-3387 (717) 240-6195 FAX (717) 240-6573 TO: LS Cent.. Peoce-55, PA STATE POLICE V I ATE LEe 0 PIE R FAX H: 717-249-0779 FRCM: CURTIS R. LONG RE: PFA ORDERS MESSAGE : Ii--. 00. OF PAGES (INCLUDING COVER SHEET) , This ~ is inta1:HJ. rnly fi::B:" tiE 1.E!J of tiE irdivid.eJ. cr. S\ti~ tD \<.hirh is is all.~ 1, om ITej o::ntain infuoret.kn th:lt is p:i.v:i1.eg;rl, anf:kE1t:ial ;;n:l ecmp: fron dir10Sl..Jl:e trr::e: 'fPl ;,.*,I1']a..r. [f t1-e ~ of this II "'Sr' is rot tl-e inteu:rl m::ipimt:, }W are hmtv rctifiBi t:I:-at a-.y ~ti01. d.istr:ib.rt:i. (r o:p,ring of this a::nm..nicatJOi is strictly p<<.tl.ibita:!. If 'tUI h;l\e re:;ei'-"Cl tins rrtrmnir..:-;m in F.tTIr.. n:laEse rotifv LS irrrrsiiatElv bv 1BIa:h:re a-d retJ.Jm tie ~-aJ. IT=' tt> lB at '-'~-~ ~ ~ ~ - - .I~, .......~: SHERIFF'S RETURN - REGULAR CASE NO: 2000-08570 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LUCIO DEBORAH LYNN VS LUCIO JOHN KATHY CLARKE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon LUCIO JOHN the DEFENDANT , at 0016:40 HOURS, on the 12th day of December, 2000 at 558 SOUTH HANOVER ST RM # 3 CARLISLE, PA 17013 by handing to JOHN LUCIO 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~.:. ~ ~. ... __-t:.,~_ c.lf R. Thomas Kline 12/13/2000 Sworn and SUbscribed to before me this /K~ day of 1Ju, ~., .2/>-t>-0 A . D . (llw,u~ (2, IUd&,,-, # I {Prothonotary' By: ~y~- ~J , .' \"~o-"'~'l)><cf ... DEBORAHL YNNLUCIO, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 00-8570 CIVIL TERM JOHN LUCIO, Defendant : PROTECTION FROM ABUSE ~RDER TO VACATE AND NOW, this7ltl.... day oIDecember, 2000, upon Plaintiff' s Petition to Vacate Order and Withdraw Action: l. This matter is dismissed without prejudice. 2. Costs of this proceeding are waived. 3. The Temporary Protection From Abuse Order entered on December 12, 2000, is hereby vacated. Distribution to: Joan Carey, Attorney for Plaintiff LEGAL SER.VICES,INe. 8 Irvine Row, Carlisle, P A 17013 John Lucio, Defendant 558 South Hanover Street, Room 3 Carlisle, PA 17013 . -oj). lrO . ro)Y'r/,1 U'f /)." vV. FAXed and mailed to PSP 1,; '~'""","J" ~ ~~_ "'~----, ""[, I '~~'~~ ' F;'(fC) ,() Pr)ilollotarY' I;) -~j,-oO ,~,'~, r ,~ Jll1r'V'~_. l,rn,:!f.I"k~,,~ i\iill;J~nJ_ "~"'-- , ,~IlI1JT ~I!'ii,~mr'{t;~:"!1>7;i'''''''Ff; "'~ w~' ;,'_"'''cC:;'' .'I:f:f;;~!f'k")~!lfIJSi1W~~'lf, ~, III! ,!t~.i!l .JJ\' ~=-'...~ ' , " , ~, i """"'~~""*'"'_-ti>~~m DEBORAH LYNN LUCIO, plaintiff : IN THE COURT OF COMMON PLEAS OF vs. : CUMBERLAND COUNTY, PENNSYL VANIA : NO. 00-8570 CIVIL TERM JOHN LUCIO, Defend8Jlt : PROTECTION FROM ABUSE PETITION TO VACATE ORDER AND WITHDRAW ACTION Plaintiff, Deborah Lynn Lucio, by and through her attorney, Joan Carey of Legal Services, Inc., requests that the Court vacate the Temporary Protection From Abuse Order in the above- captioned case and that the action be withdrawn on the grounds that: 1. A Petition for Protection From Abuse was filed and a Temporary Protection From Abuse Order was issued by this Court on December 12, 2000, scheduling a hearing fur December 20,2000, at 2:30 p.m. before Judge Hoffer. Cumberland County Sheriff's deputies served Defendant with a certified copy of the Notice ofHearing, Temporary Protection From Abuse Order and Petition for Protection From Abuse at his residence at 558 South Hanover Street, Room 3, Carlisle, Cumberland County, Pennsylvania, on December 12, 2000, at 4:40 p.m. 2. The parties are in the process of reconciling their differences. 3. Plaintiff requests that the Temporary Protection From Abuse Order entered on December 12, 2000, be vacated and the action withdrawn without prejudice to her. WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate the ",' ""~" " ',I,' " ~" L.o..i , ~"""""~jli,lim,, Order, and that the action be withdrawn without prejudice to Plaintiff. Respectfully submitted, ..-rJ o Carey, Attorney for iff LEGAL SERVICES. 8 Irvine Row Carlisle, PA 17013 ~ ~ " ~, ".. ~\",~il!i;.L', 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 oflS Pa~C~S~ 94904, relating to unsworn falsification to authorities~ Dated: De-c- .f2 0 I !).oO 0 {)~of~w~ Deborah Lynn Lucio, Plaintiff 'ici'" i:l<ii!l' 'rfllli_llI>_"i.,":c",,,,i,.nc,,,<~,,,,,,,,,'''J,''J_j''_'''''''''-'____''__".u i' ?--. L, ~ F 1:~ ~ l~, t ?"p t:~ ~ f--" ~ ~ "' .... ~ t .f ~ ~ , '". ~,'" I ~ Ji:i.~iilJii.~::n:rr';;li1~:!l'~--llil\i!JiIil ,~. -- -'iMiI!i..--:: o c <:: -au) rnll": -y--, "-." ':Zt,:,~ (D ":" % ",".. ~C ~- '"--7( ) /-0 5c: /' ~ (::> c> t:? \",1 C'") 1'0 (l' '0'" ~ ~ '~\~ ()(S ~}~~~ -;7--::-,1"\\ ~ 5"J -- - - r0 CO ~ 12/26/00 .TUB 1&:46 FAX 717 240 6573 " - '-*h,,~ CUMB CO PROTHONOTARY . . ~001 , *************************** *** MULTI TN REPORT *** *************************** TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2362 ERROR [ 01]9p2405331 [ 03]9p2438026 [ 04]92490779 CENTRAL PROCESS LEGAL SERVICES PSP . " OFFICE OF 'mE PROlliClNOTARY CUMBERLAND <XX.lNT'l o::xJImIOOSE ONE CCURTHOUSE SQUARE CARLISLE. PA. 17013-3387 (7171 240-6195 FAX (717) 240-6573 c.p LS TO: PA STATE POLICE VIA TELECOPIER FAX ~: 717-249-0779 ~ ") nKM: CURTIS R. LONG RE: PFA ORDERS MESSAGE: 1- Jt L 00. OF PAGES (lNCLUOING COVER SHEET) This lrE'fo3a1' is mtErt!;d rnly fOr tiB I.SC af tIE irdividBl or: Entity to .rom is is ;on " crrll18i a::ntain :infomat.icn ttat is p-:.ivi.legD. ~ crd ecmp:; fmn ljj.....l'J'llIl'e ud3r" 'fPliNhl.. Ia.or. ff tl--e ~ of !his ~ is rot tl--e inte"tkl ta::ipimt, ~ are lEI.<iV rotifJej ttat CI"\Y d.issEm.iretim, d.ist::tib.Jt:ial ar: <::qJ(:in;J af tNs ~jm lli str'ictly prtribita:!. If jO.l h:M! ~..m t/US .---,- -..,- ,~............. ";1....., ,..,-,rifu '''' imrs:liate.1.v b,r 1E.I,ej;h:re arl return tiE oOgiml. ,,: ""9' to lS al