HomeMy WebLinkAbout01-0127 FX
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ANGELA MARIE GREEN, : IN THE COURT OF COMMON PLEAS OF
for herself and on behalf of her minor children:
NATHANIEL HENRY GEYER,
ZACHARY ALAN ROWE, : CUMBERLAND COUNTY, PENNSYLVANIA
LINDSEY RENEE ROWE, and
CODY DA V1D RIEGLE,
Plaintiffs : NO. 01-/:17 CIVIL ACTION
vs.
DOUGLAS EDWARD GEYER,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following
papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and
a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be
evicted from your residenC,e and lose other important rights.
"
A hearing on this matter is scheduled on the J8!!. day of January, 2001, at 111:30 <\' .m., in
Courtroom No. L on the 4th Floor oftlH;c;umberland County Courthouse, 1 Courthouse Square, Carlisle,
Pennsylvania.
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 and/or up to six months injail under
23 Pa.C.S. ~6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania
Crimes Code. Under federal law, 18 U.S.C. ~2265, 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 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 furth 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 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 fucilities 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 rrmst attend the scheduled conference or hearing.
..
ANGELA JVIARIE GREEN,
for herself and on behalf of her
minor children: NATHANIEL HENRY
GEYER,
ZACHARY ALAN ROWE,
LINDSEY RENEE ROWE, and
CODY DA V1D RIEGLE,
Plaintiffs
: ill the Court of Common Pleas of
: CUMBERLAND County,
: PENNSYLVANIA
: Civil Action - Law
; No. 01- /0.1
v.
DOUGLAS EDWARD GEYER,
Defendant
: Protection From Abuse
: and Custody
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: DOUGLAS EDWARD GEYER
Defendant's Date of Birth is: February 21, 1968
Defendant's Social Security Number is: 171-60-9291
Name(s) of All protected persons, including Plaintiff and minor children:
1. ANGELA MARIE GREEN
2. NATHANIEL HENRY GEYER
3. ZACHARY ALAN ROWE
4. LINDSEY RENEE ROWE
5. CODY DAVID RIEGLE
AND NOW, on 8th Day of January, 2001 upon consideration of the attached
Petition for Protection from Abuse, the court hereby enters the following Temporary
Order:
"!llinriffs ffffP.~t for a t\!\PPol'1lq PfPf!\Cti'1n order is granted.
1. Defendarit shall not abuse, harass, ,stalk or threaten any of the above pef~ons in MY
place where they might be found. '
'.
2. Except for such contact 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 Plaintiff's school, business, or place of
employment. Defendant is specifically ordered to stay away from the following
locations for the duration of this order.
Plaintiff's current residence or any other place where she andlor her minor
children may stay during the term oftbis Order:
320 Third Street
West Fairview, PA 17025
The schools ofthe minor children.
The day care facilities of the minor children.
3. Except for such contact with the minor child/ren as may be permitted under
paragraph 4 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.
4. Pending the outcome ofthe final hearing in this matter, Plaintiff is awarded
temporary custody of the following minor child/ren:
1. NATHANIEL HENRY GEYER
Until the final hearing, all contact between Defendant and the child/ren shall be
limited to the following:
Defendant's contact with the minor child is snspended pending further Order
after the hearing scheduled in this case.
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.
5. Defendant shall immediately relinquish any firearms license the Defendant may
possess, and the following weapons to the Sheriffs Office or a designated local law
enforcement agency for delivery to the Sheriff's Office.
1. any and all firearms and weapons, specifically:
2. rifles (oI).e is rewstered in Pl$tiffs q1pl).y - Pyfr11411Jlt
refused to returD. it to her),
3. handguns
4. shotguns
5. bow and arrows
6. hunting knives
Defendant is prohibited from possessing, transferring or acquiring any other
firearms license or weapons for the duration of this order.
6. The following additional relief is granted:
Defendant is prohibited from having any contact with Plaintiff's relatives
andlor Plaintiff's minor children listed in this petition.
Defendant is ordered to refrain from harassing Plaintiff's relatives and/or her
minor children.
Defendant is enjoined from damaging or destroying any property owned
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:
EAST PENNSBORO TOWNSHIP POLICE DEPARTMENT
WEST SHORE REGIONAL POLICE DEPARTMENT
S. 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 JULY 8, 2002 OR UNTIL OTHERWISE
MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND
HEARING.
NOTICE TO THE DEFENDANT
"
Defendant is hereby notified that violation of this Order may result in arrest for
indirect criminal contempt, which is punishable by a fine of up to $1,000,00 and/or up
to six months in jail. 23 Pa.C.S. ~6114. Consent ofthe Plaintiff to Defendant's return
to the residence shallllot 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 himJher
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 haye jurisdiction over the plaintiff's
residence OR any location where a violation ofthis order occurs OR where the
defendant may be located. If defendant violates Paragraphs 1 through 5 of this Order,
defendant shall be arrested on the charge ofIndirect Criminal Contempt. An arrest
for violation of this Order may be made without warrant, based solely on probable
cause, whether or not the violation is committed in the presence oflaw enforcement.
Subsequent to an arrest, the law enforcement officer shall seize all weapons used or
threatened to be used during the violation of this Order OR during prior incideuts of
abuse. Weapons must forthwith be delivered to the Sheriff's office of the county
which issued this Order, which office shall maintain possession of the weapons until
further Order of this court, unless the weaponls are evidence of a crime, in which
case, they shall remain with the law enforcement agen~~" cer made the
arrest. /
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.M"-- t S Judge
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Date
Distribution to:
Joan Carey, Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row, Carlisle, P A 17013
FAXed & mailed to PSP
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PF AD Number: JWll79812R
ANGELA MARIE GREEN,
for herself and on behalf of her
minor children: NATHANIEL HENRY
GEYER,
ZACHARY ALAN ROWE,
LINDSEY RENEE ROWE, and
CODY DAVID RIEGLE,
Plaintiffs
: In the Court of Cormnon Pleas of
: CUMBERLAND County,
: PENNSYLVANIA
: Civil Action - Law
: No. 01- 1;}.1
v.
DOUGLAS EDWARD GEYER,
Defendant
: Protection From Abuse
: and Custody
PETITI<JN FOR PROTECTION FROM ABUSE
1. Plaintiff's name is:
ANGELA MARIE GREEN
2. I, (the PlaintiB:), 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 from abuse.
a. ANGELA MARIE GREEN
b. NATHANIEL HENRY GEYER
c. ZACHARY ALAN ROWE
d. LINDSEY RENEE ROWE
e. CODY DAVID RIEGLE
4. Plaintiffs Address is: 320 Third Street, West Fairview, PA 17025
5. Defendant's Name is:
.'
DOUGLAS EDWARD GEYER
6. Defendant is believed to live at the following address:
75 Bonnybrook Road, Lot 24, Carlisle, PA 17013
7. Defendant's Social Security Number is:
171-60-9291
8. Defendant's Date of Birth is:
February 21, 1968
9. Defendant's Place of employment is:
Kruger's Rental Service, 1625 Ritner Highway, Carlisle, PA 17013
10. Defendant is an adult.
11. The relationship between the Plaintiff and the Defendant is:
Parents of the same children
Persons who live or have lived like spouses
12. The defendant has been involved in a criminal court action.
13. The defendant is not currently on probation I parole
14. Plaintiff and Defendant are the parents of the following minor child/ren:
a. NATHANIEL HENRY GEYER
Age: 3 years old
Child's address is: 320 Third Street, West Fairview, PA 17025
15. Plaintiff is seeking an Order of child custody as part of this petition.
The following is a list of the children and where they have live for the past 5 years:
a. NATHANIEL HENRY GEYER
For the past 5 years, this child has lived with:
Plaintiff, step-father, Paul Green, and Plaintiff's
children by previous marriage. Zachary Alan Rowe,
and Lindsey Renee Rowe. at 320 Third Street, West
Fairview, PA, from December 31, 2000, to the present.
Defendant at 75 Bonnybrook Road, Carlisle, PA, from
mid-July 2000, to December 31, 2000.
Plaintiff, Zachary Alan Rowe, Lindsey Renee Rowe, and
Plaintiff's child by a previous marriage, Cody David
Riegle, at 40 East Louther Street, Carlisle, PA, from
November 1999, to mid-July 2000.
Plaintiff, Defendant, Zachary Alan Rowe, Lindsey Renee
Rowe, and Cody David Riegle, at 40 East Louther Street,
Carlisle, PA, from February 1999, to November 1999.
Plaintiff, Defendant, Defendant's mother, Audrey Geyer,
Zachary Alan Rowe, Lindsey Renee Rowe. and Cody David
Riegle, at 105 Heberlig Road, Newville, PA, from the
child's birth on May 2,1997, to February 1999.
16. The following other minor child/ren presently live with Plaintiff:
a. ZACHARY ALAN ROWE
Age: 12 years
The Plaintiff's relationship to this child is:
Mother
b. LINDSEY RENEE ROWE
Age: 10 years
The Plaintiff's relationship to this child is:
Mother
17. The facts of the most recent incident of abuse are as follows:
On about Sunday, December 31, 2000
location: 320 Third Street, West Fairview, PA, Plaintiff's residence.
In or abont mid-morning on December 31,2000, Defendant argued and yelled at Plaintiff as sbe
tried to leave, causing the parties' 3-year-old child, Nathaniel, to become frightened and lock the
car doors to prevent Defendant from getting into the car. Defendant yelled at Plaintiff and
pounded on her car windows as she drove away causing her to fear for her safety and that of her
child.
Later the same day, Defendant telephoned Plaintiff's residence approximately 4 times, and told
her not to show up at the pre-sentencing hearing schednled on Jannary 2, 2001, at the
.'
Cumberland County Courthouse so that the criminal charges which were pending against him
for assaulting her on June 17, 2000, would be dropped. When Plaintiff refused to comply with
his demands, Defendant threatened to take their child out of state and told her that she would
never see the child again; Defendant further threatened that he would kill Plaintiff if she was
awarded custody of the child; that if he went to jail, she would pay, and that "neither one of ns
will ever have Nathaniel again." Plaintiff feared for her life and that of her minor child.
Defendant's violent behavior has adversely affected the child; for example, Nathaniel, who is 3
years old, has produced toy guns, pointed them at Plaintiff and his siblings, and threatened,
"I'm going to shoot yon; I'll kill you." saying that he hears his father make these threats.
Plaintiff reported Defendant's threats and attempts to intimidate her to the Cumberland County
District Attorney's Office, and was advised by the District Attorney's Office to file a Protection
From Abuse action against Defendant as soon as possible.
On January 4, 2001, the Criminal Investigation Unit ofthe Cumberland County District
Attorney's Office filed charges against Defendant for intimidation of a witness; a warrant was
issued for his arrest, and he was arrested later the same day at his place of employment.
Defendant was arraigned before District Jnstice Bender, hail was set at $50,000, and Defendant
was placed in Cumberland Connty Prison where he remains at the time of this filing.
18. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor child/reo,
(mduding any threats, injuries, or incidents of stalking) are as follows:
In or about mid-September 2000, Defendant threatened Plaintiff saying, "You know I have my
guns; you'll pay." Defendant further threatened that he would come to Plaintiff's home. break
the door down to get to her, and that nothing and nobody could protect her from him. At this
time Defendant also threatened Plaintiff in the presence of her minor children, Zachary (12),
Lindsey (10), and Cody (6), saying, "Don't ever let nie see yonr kids around town alone." The
children were traumatized, upset and crying, and refused to go to school the following day
becanse they feared Defendant.
On or about September 1, 2000, within 24 hours after Plaintiff testified against Defendant at the
preliminary hearing on August 30, 2000, relating to criminal charges pending against him for
assanlting her in June 2000, Defendant telephoned Plaintiff at her home. threatened that if he
went to jail hecause ofthe criminal charges, she would never live to have custody oftheir child,
and withheld the child from Plaintiff for several days after the hearing.
In or about early August 2000, Defendant threatened Plaintiff saying, "If we go to conrt, I'll
keep Nathan from you and you'll never see him again", told her that he wished she was dead,
and said that his life would be a lot easier if she were dead.
On or abont Jnne 17, 2000, Defendant argued and yelled at Plaintiff, who held their 3-year-old
son in her arms, and as he got out of his truck and came after her, she ran from him. Defendant
followed Plaintiff, shoved her against a fence, and then against a brick walL As she held the child
in one arm, Defendant grabbed hfr fn~e arm, and threatellclJ tll break it as he pressed his fmgers
against the pressure points in the hollow of her elbow and ptislu~d her wrist downward in the
opposite direction. Plaintiff got away from Defendant and tele~n~d 911 for help. TheCar\i..\e
Police responded, and transported Plaintiff to Carlisle Hospital for treatment of her injuries
which included, but were not limited to, contusions, bruising and soreness about her face, head,
neck, arm, and back. Defendant was arrested, charged with simple assault, harassment, and
disorderly condnct, arraigned, and releJIsed on his own recognizance. After his release,
Defendant telephoned Plaintiff at her residence and threatened, "You'll pay for this."
In or about May 2000, in the presence of her children, Defendant gestured to Plaintiff giving her
"the finger", and threJItened the children saying, "You kids are going to die along with your
mother."
In or about snmmer 1999, as Plaintiff, who had her 4 children in the car, tried to leave
Defendant, he got onto the car, jumped up and down on the hood and roof of the car denting
both, and repeatedly punched the passenger side window of the car, breaking it, as she drove
away. Plaintiff feJIred for her safety and that of her minor children.
In or about 1996, when Plaintiff tried to leave Defendant, he followed her to the car with a
loaded shotgun, and eJIch time she tried to open the car door (approximately 4-5 times), he shot
the gun in the air, causing Plaintiff to feJIr he would kill her. Fearing for their safety, Defendant's
mother and nephew left the home and did not return until the following day.
Since approximately 1996, Defendant has abused Plaintiff in ways inclnding, but not limited to
the following: shoving, slapping, restraining, and pulling her hair. Defendant has repeJItedly
threJItened to kill Plaintiff and her childreu, and has inferred that he would kill her and then
himself. On several occasions Defendant has threatened Plaintiff saying, "Remember: I have
guns and I'm not afraid to use them. I don't care if I die, but you'll go down first." Defendant
keeps loaded guns in several locations in his home. Iu addition, Defendant abused her dog by
punching, throwing, and kicking it.
19. The Defendant has used, or threatened to use, the following weapon(s) against the Plaintiff or the minor
childlren:
a. any and all firearms and weapons, specifically the following:
b. rifles (Defendant refuses to return to Plaintiff one rifle registered in her name)
c. handguns
d. shotguns
e. bow and arrows
f hunting knives
20. The police department(s) or law enforcement agencies that should be provided with a copy of the
protection order are:
EAST PENNSBORO TOWNSHIP POLICE DEPARTMENT
WEST SHORE REGIONAL POLICE DEPAR'IMENT
21. There is an immediate and present danger of further abuse from the Defendant.
22. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER ~
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 min.or child/ren and place the following
restrictions on contact between Defendant and child!ren:
Defendant's contact with the minor child is snspended pending fnrther Order
after the hearing scheduled in tWs case.
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 Plaintifl's school, business, or place of
employment, except as the court may find necessary with respect to partial custody
and! or visitation with the minor child!ren.
d. Prohibit Defendant from having any contact with Plaintiff's relatives and Plaintiff's
children listed in this petition, except as the court may find necessary with respect to
partial custody and/or visitation with the minor child!ren.
e. Order Defendant to temporarily turn over weapons to the Sheriff of this County and
prohibit Defendant from transferring, acquiring, or possessing any such weapons for
the duration of the Order.
f Order Defendant to pay the costs of this action, including filing and service fees.
g. Order the following additional relief, not listed above:
Order Defendant to refrain from harassing Plaintiff's relatives andlor her
minor children.
Enjoin Defendant from damaging or destroying any property owned solely by
Plaintiff.
Order Defendant to pay $250.00 to one of Legal Services, Inc.'s funding
sources to pay the cost of litigating this case.
h. Grant such other relief as the court deems appropriate.
i. 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 an Carey, Art. for Plaint" ..
Agency: LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
Respectfully Submitted by:
.
.
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 lrnowledge. I
understand that any false statements are made subject to the penalties of18 Pa.C.S.s4904, relating
to unsworn falsification to authorities.
Dated:
\- 4-6\
Gr-r.n.h (r](ll/L..L2 ~.'( OM'!.
Angela Mine Green, Plainti~ .
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-00127 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GREEN ANGELA MARIE ET AL
VS
GEYER DOUGLAS EDWARD
SHAWN HlI-RRISON
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE
was served upon
GEYER DOUGLAS EDWARD
the
DEFENDANT
, at 0017:45 HOURS, on the 8th day of January ,2001
at CUMBERLAND CO. PRISON
1101 CLAREMONT RD
CARLISLE, PA 17013
by handing to
DOUGLAS GEYER
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.
Additional Comments
WEAPONS CONFISCATED
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So
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18.00
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10.00
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R. Thomas Kline
01/16/2001
Sworn and Subscribed to before
me this .l'/'= day of
CJ.. ~3. ~ ~ 'i' c2.-l.rV / A. D .
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rothonotary ,
By:
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ANGELA MARIE GREEN, : IN THE COURT OF COMMON PLEAS OF
for herself and on behalf of her minor children : :
NATHANIEL HENRY GEYER,
ZACHARY ALAN ROWE, : CUMBERLAND COUNTY, PENNSYLVANIA
LINDSEY RENEE ROWE, and
CODY DAVID RIEGLE,
Plaintiffs : NO. 01-127 CIVIL ACTION
vs.
DOUGLAS EDWARD GEYER,
Defendant
: PROTECTION FROM ABUSE & CUSTODY
ORDE~ FOR CONTINUANCE
7'-' '
.AN1D NOW, this ~ day of February, 2001, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on January 18, 2001, at 10:30 a.m. by this Court's
Order of January 8, 2001, is hereby rescheduled for hearing on Friday, March 23, 2001, at
1:30 p.m. in Courtroom No.4 on the 4th Floor of the Cumberland County Courthouse, 1
Courthouse Square,~arlisle, Pennsylvania.
The Temporary Protection From Abuse Order shall remain in effect for a period of18 months
from the date it was entered, through July 8, 2002, or until further Order of Court, whichever comes
4irst.
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By the Co~rt, , J
~;Jik-
Kevin . ess, Judge
Joan Carey, Attorney for Pl~i~!iff
MidPenn Legal Services ' -!
8 Irvine Row
Carlisle, PA 17013
James D. Flower, Jr., Attorney for Defendant
SAIDIS SHUFF FLOWER & LINDSAY
26 West High Street
P.O. Box 560
Carlisle, PA 17013
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ANGELA MARIE GREEN, : IN THE COURT OF COMMON PLEAS OF
for herself and on behalf of her minor children: :
NATHANlEL HENRY GEYER
ZACHARY ALAN ROWE, : CUMBERLAND COUNTY, PENNSYLVANIA
LINDSEY RENEE ROWE, and
CODY DAVID RIEGLE,
Plaintiffs : NO. 01-127 CIVll., ACTION
vs.
DOUGLAS EDWARD GEYER
Defendant
: PROTECTION FROM ABUSE & CUSTODY
MOTION FOR CONTINUANCE
Plaintiff, Angela Marie Green, by and through her attorney, Joan Carey ofMidPenn Legal
Services, moves the Court for an Order rescheduling the hearing in the above-captioued case on the
grounds that:
L A Temporary Protection From Abuse Order was issued by this Court on
January 8, 2001, scheduling a hearing for Thursday, January 18, 2001, at 10:30 a.m. before Judge
Hess in Courtroom No. 4 of the Cumberland County Courthouse, Carlisle, Pennsylvania.
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 January 8, 2001, at Cumberland County Prison, 1101 Claremont Drive, Carlisle,
Pennsylvania, where Defendant was incarcerated at the time.
3. Defendant has retained James D. Flower, Jr. ofSaidis Shuff Flower & Lindsay to
represent him in the matter.
4. The parties agree, by and through their respective counse~ that the hearing be
rescheduled to facilitate negotiation of a settlement, and that the Temporary Protection From Abuse
Order remain ill effer pending further Order after the hearing, and that it be modified to grant that
Defendant be allowed supervised visitation with the parties' minor child, Nathaniel Henry Geyer,
through the Carlisle YWCA's supervised visitation program or through another mutually agreed upon
program which offers similar staff-supervised visitation.
5. 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 July 8, 2002, or until further Order
of Court.
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 July 8, 2002, or until further Order of Court, that
pending further Order after the hearing that Defendant be granted supervised visitation with the
parties' minor child, Nathaniel Henry Geyer, through the Carlisle YWCA's supervised visitation
program or through another mutually agreed upon program which offers similar staff-supervised
visitation.
Respectfully submitted,
~tiff
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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ANGELA MARIE GREEN,
for herself and on behalf of her
minor children NATHANIEL
HENRY GEYER, ZACHARY
ALAN ROWE, LINDSEY RENEE
ROWE, and CODY DAVID
RIEGLE,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-0127 CIVIL
CIVIL ACTION - LAW
vs.
PROTECTION FROM ABUSE
DOUGLAS EDWARD GEYER,
Defendant
ORDER
AND NOW, this 2 '3'~ day of March, 2001, on request of counsel for the plaintiff,
hearing herein is continued until Wednesday, March 28,2001, at I :30 p.m. in Courtroom
Number 4, Cumberland County Courthouse, Carlisle, P A.
BY THE COURT,
Joan Carey, Esquire
For the Plaintiff
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James D. Flower, Ir., Esquire
For the Defendant
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CUivI8ErfL;;Jvu COUNTY
I-dlJiYS\'LVANiA.
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Angela Marie Green
for herself and on behalf of her minor children
Nathaniel Henrey Green.--
Zachary Alan Rowe,
Lindsay Renee Rowe, and
Cody David Reigle
PLANTIFFS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
V.
CASE # 01-127 CIVIL TERM
Douglas Edward Geyer
DEFENDANT
ITEM: 12 Gauge Mossberg # P706002
Hoyt Compound Bows wI Arrows
308 Cal. Savage # E588659
12 Gauge Kassner # 11149
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AND NOW, this E day Of~, 2003, upon petition of the Sheriff,
the following Order is entered:
The Sheriff of Cumberland County having sent notice to reclaim the seized
weapon(s) to the above-named defendant via regular mail to the last known address,
and the defendant not having responded to the notice by asserting a claim, the Sheriff
of Cumberland County is directed to destroy the listed weapon(s) in accordance with
law. The Sheriff shall make the appropriate arrangements for the destruction of any
ammunition.
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By the Court,
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R. Thomas Kline, Sheriff
Cumberland County Sheriff's Department
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Angela Marie Green
for herself and on behalf of her minor children
Nathaniel Henrey Geyer,
Zachary Alan Rowe,
Lindsey Renee Rowe, and
Cody David Riegle
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
V,
: NO. 01-127 CIVIL TERM
Douglas Edward Geyer,
Defendant
: ITEMS: 12 Gauge Mossberg # P706002
Hoyt Compound Bow w/1 0 Arrows
308 Cal. Savage #E588659
12 Gauge Kassnar # 11149
PETITION TO DESTROY UNCLAIMED WEAPONS(S)
AND NOW, comes R. Thomas Kline, the Sheriff of Cumberland County, by and through his
Solicitor, Edward L. Schorpp, Esq., and petitions Your Honorable Court to order the destruction of
the above described weapons in his possession upon the following:
1. The Cumberland County Sheriff's Office currently has possession of the above
described weapons, having seized the same from the Defendant on
January 10, 2001.
2. The weapons were seized pursuant to an Order of Your Honorable Court
dated January 8, 2001, and entered at the above docket number.
3. The Order was issued in proceedings instituted by the Plaintiff for protection from
abuse.
4. Pursuant to said Order, the period of seizure expired on July 8, 2002.
5. On May 22, 2003, the Cumberland County Sheriff's Office caused notice to be sent,
via regular mail and certified mail, to the Defendant at his last known address,
advising the defendant that the above described weapons must be reclaimed by
the defendant, in person, within 30 days, at which time the Sheriff's Office would
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petition Your Honorable Court for an Order for destruction of the weapons a
copy of said notice is attached hereto as Exhibit "A".
6. The Defendant has failed to reclaim the weapons.
WHEREFORE, your petitioner respectfully requests Your Honorable Court to enter an Order
directing the destruction of the above described weapon.
Very respectfully submitted,
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Edward Schorpp
Solicitor
10 East High Street
Carlisle, PA 17013
(717) 243-3341
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VERIFICATION
I, Barry J. Horn, verity that the statements made in the within Petition are true and
correct to the best of my knowledge, information and belief. The undersigned
understands that this statement herein is made subject to the penalties of 18 Pa. C. S.
Section 4904 relating to unsworn falsification to authorities.
Dated:b),>1!07
,
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By:
Barry J. ,ergeant
Cumberland County Sheriff's Office
01/08/01 YON 15:21 FAX 717 240 6573
CUMll CO PROTHONOTARY
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[ 01]9p2405331
[ 03]9p2438026
[ 04192490779
CE!<"TRAL PROCESS
LEGAL SERVICES
PSP
ERROR
,
OFFICE OF THE PRarHa>JOTARY
CU'1BERLIIND COUNTY COUR'rn<XlSE
ONE COURTHOOSE: SQUARE
CARLISLE, PA. 17013-3387
(717) 240-6195
FAX (717) 240-6573
TO:
LS
Cent. Pe.oce.ss:.
PA STATE POLICE
VIA TELECOPIER
FAX #:
717-249-0779
FRG1:
CURTIS R. LONG
RE:
PFA ORDERS
ME5-"AGE: :
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