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HomeMy WebLinkAbout01-0475 FX ,--- J~ "' ' - ,- "".' . -' .' -"!ltl!:~ LOIDA MERCEDES STEVENSON, for herself and on behalf of her minor children: MARK CHRISTOPHER STOKES, JR., MATTHEW ADAM STOKES, and CHRISTOPHER MICHAEL STOKES, Plaintiffs vs. MARK CHRISTOPHER STOKES, SR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW -" :NO.Ol-lfJ:::, , CIVIL TERM : 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 matter is scheduled On the Jod'~ day of . in Courtroom No.L on the 4th Floor of the Cumberland County Courthou Carlisle, Pennsylvania. , :Z001, at ,":.3 () ,nm,., , , 1 Courthouse Square, You MUST obey the Order that is attached until it is modified or terminated by the court after notice and hearing, If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000,00 and/or up to six months in jail under 23 Pa. C.S. ~6ll4. Violation may also subject you to prosecution and criminal penalties und(ll" the Pennsylvania Crimes Code, Under federal law, 18 U.S,C, ~226S, 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 underthe 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 Camlot afford one, go to or telephone the office set forth below to find out where you can get legal help. If you Camlot 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 DisabilitiesActof 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. ... ,,',,-,w,J>llIiililIIlIilill I ''''':"' ~, 4.~~-;,!', LOIDA MERCEDES STEVENSON, : In the Court of Common Pleas of for herself and on behalf of her minor children: MARK CHRISTOPHER STOKES, JR, : CUMBERLAND County, MATTHEW ADAM STOKES, and CHRISTOPHER MICHAEL STOKES, : PENNSYLVANIA Plaintiffs vs. : Civil Action - Law ; No. 01- <I?:s MARK CHRISTOPHER STOKES, SR., Defendant : Protection From Abuse TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: MARK CHRISTOPHER STOKES, SR. Defendant's Date of Birth is: October 21, 1963 Defendant's Social Security Number is: 080-56-5085 Name( s) of All protected persons, including Plaintiff and minor children: L WIDA MERCEDES STEVENSON 2. MARK CHRISTOPHER STOKES, JR. 3, MATTHEW ADAM STOKES 4. CHRISTOPHER MICHAEL STOKES AND NOW, on 23rd Day of January, 2001 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, ,;WM" .- -~~ - 2. Defendant is prohibited from having ANY CONTACT with Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at 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, which is confidential, and any other residence she and her minor children may establish for themselves during the term of this Order. Wherever Plaintiff andlor her minor children may be employed during the term of this Order. The schools ofthe minor children, which are confidential. 3. Defendant shall not contact Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 4. The following additional relief is granted: Defendant is prohibited from having any contact with Plaintiff's relatives and Plaintiff's children listed in this petition. Defendant is ordered to refrain from harassing Plaintiff's relatives and the parties' minor children. 5. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: APPROPRIATE POLICE DEPARTMENTS 6. The sheriff, police or other law enforcement agencies are directed to serve the Defendant with a copy of the Petition, any Order issued, and the Order for Hearing without prepayment of costs, The Petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. The Prothonotary is directed to file this Petition and Order without prepayment of costs. 7. TIllS ORDER APPLIES lMMEDIATEL Y TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL JULY 23, 2002 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY TIllS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT . ~ - -""" ~, < \\~l4i0 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. ~6ll4. Consent of the Plaintiff to Defendaot'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 pUlpose. 23 Pa.C.S. ~6ll3. Defendant is further notified that violation of this Order may subject hinlIher to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 US.c. ~~226l- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintift's residence OR any location where a violation of this order occurs OR where the defendant may be located. If defendant violates Paragraphs 1 through 3 of this Order, defendant shall be arrested on the charge oflndirect 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 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 Sherifl'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 1- Z- 3 ~o I Date Distribution to: Joan Carey, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row, Carlisle, P A 17013 (717) 243-9400 FAXed & mailed to PSP ~~-!li!*;\i[;W"iI.~M:~f%k~~fu;~,~<!ii'h!t;l:m~~lii::wB~1IIl "'''''' ~1J.1AlJ r-"~ "M.llJI ,,,,-~~ .' '....'Ii.'!! J!/jl!!r~' g 0 C) -n <- . -,"~ -- ,- "oOJ ':I>' ;,~, ~Tl ~r" :e ::n 1'> ~~ ?j~ w \<0 -0 ~O :::. :;o;g t;:? r--,\ ' ~ ?j N 2~ ::I:! (.> -<; , , ,,t(1Il- :"_,J - ~ J ~ -it~&W4U<:'-~ PFAD Number: BY1183888K LOIDAMERCEDES STEVENSON, : In the Court of Common Pleas of for herself and on behalf of her minor children: MARK CHRISTOPHER STOKES,JR., : CUMBERLAND County, MATTHEW ADAM STOKES, and CHRISTOPHER MICHAEL STOKES, : PENNSYLVANIA Plaintiffs v. : Civil Action - Law ; No. 01- '-170' MARK CHRISTOPHER STOKES, SR, Defendant : Protection From Abuse PETITION FOR PROTECTION FROM ABUSE I. Plaintiff's nanle is: LOIDA MERCEDES STEVENSON 2, I, (the Plaintift), 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. LOIDA MERCEDES STEVENSON b. MARK CHRISTOPHER STOKES, JR c. MATTHEW ADAM STOKES d. CHRISTOPHER MICHAEL STOKES 4. Plaintiff's Address is : CONFIDENTL\L 5, Defendant's Name is: MARK CHRISTOPHER STOKES, Sa. ,f:,!~' . "'" ^.I " ~ ,~ . ~ -"'1!Il,__~~IIi" 6. Defendant is believed to live at the following address: clo Marvin Stokes, 35 Arthur Place, Red Bank, NJ 07701.1707 7. Defendant's Social Security Number is: 080.56.5085 8. Defendant's Date of Birth is: October 21, 1963 9, Defendant's Place of employment is: unknown to Plaintiff. 10, Defendant is an adult. 1 L The relationship between the Plaintiff and the Defendant is: Parents ofthe same children Ex-Spouse 12, The Plaintiff and the Defendant been involved in the following court actions: a. Divorce 13. Other details of the court action are: Divorce - Pennsylvania 14, The defendant has been involved in a criminal court action. 15. The defendant is not currently on probation I parole 16. Plaintiff and Defendant are the parents of the fo\1owing minor childlren: a. MARK CHRISTOPHER STOKES, JR. Age:17 years old '--'",)'".....-,~~ ~ , - -I ,~~, Child's address is: CONFIDENTIAL " b, MATTHEW ADAM STOKES Age:16 years old Child's address is: CONFIDENTIAL c. CHRISTOPHER MICHAEL STOKES Age:ll years old Child's address is: CONFIDENTIAL 17. There is an eJcisting court order regarding the custody of the Plaintiffs !j1Jd Defendant's minor children. The terms of the order are: Judge Gloria Sosa Lintner, of the Family Court of the State of New York, New York County, entered an Order on December 19, 2000, Docket Nos. N3716-N3718/00, regarding the parties' minor children, placing them with The Administration for Children's Services of New York County, New York, for up to 12 months, with an immediate trial discharge to the mother, Plaintiff. Cumberland County Children & Youth Services is monitoring the childrens' case through an interstate agreement with ACS of New York. County: New York County State: New York 18, The facts of the most recent incident of abuse are as follows: On about Wednesday, June OS, 1996 location: New York, New York On June 5, 1996, in New York County, New York, Defendant pled guilty to the crimes of endangering the welfare of a child, sexual abuse in the first degree and sodomy in the first degree for sexually assaulting Plaintiff's daughter from the time the child was 10 years old until she was 14 years old. On July 22,1996,. Defendant was sentenced to state prison for 1-112 to 4-112 years. During the hearing, Defendant threatened Plaintift'that when he got out of prison, he would find her and the parties' children and kill them. Plaintiff fears for her safety and that of her minor children. Defendant was released from Bare Hill Correctional Facility, Malone, New York on January 18, ZOO1. On or about January 19, 2001, when one ofPlaintitT's children telephoned his paternal grandfather to speak with him, Defendant answered .tOO telephone. Defendant demanded to know Plaintiff's whereabouts, but the child did not give him any information. 19. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor childlren, (including any threats, injuries, or incidents of stalking) are as follows: In or about March 1994, when Plaintift'tried to leave with their children, Defendant grabbed her by the arm, shoved her against the waD, choked her, punched her in the stomach, blocked the door with bis body as she tried to get out, and threatened to hunt her down and kill her and -"-,,,,"'- ~" ~ - ~ "-'-- "~-~ '",,~I_,),:!- their children if she took the children. From approximately 1988 through 1994, Defendant abused Plaintiff and the parties' children in ways including, but not limited to, shoving, slapping, puncbing, and kicking them. In addition, Defendant cboked Plaintift', hit ber with objects such as a bat and a broom stick, stabbed her in the hand with a pencil, and punched her in tbe abdomen wben she was six months pregnant. Defendant isolated Plaintift' from her family and friends by refusing to allow her to leave the home, and regularly locked her in the house so that sbe was unable to get out. During one incidept when Defendant had locked Plaintift' and the parties' infant in the house, the house next door caught on fire, and when firefighters evacuated residents in neighboring houses for their safety, Plaintiff' and ber infant could not get out and the firefighters could not get the doors open from tbe outside until Defendant was contacted and returned to unlock the doors. 20, The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: APPROPRIATE POLICE DEPARTMENTS 21. There is an immediate and present danger of further abuse from the Defendant. 22. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL OlIDER THAT WOULD DO THE FOLLOWING: a. Restrain Defep.dant D::om abusing, threatening, harassing, or st~lking Plaintiff and/or minor child/ren in any place where Plaintiff may be found. b, Prohibit Defendant from having any contact with Plaintiff and/or minor child/ren, either in person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Plaintiffs schoo~ business, or place of employment, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/ren. c. Prohibit Defendant from having any contact with Plaintiffs 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/ren, d, Order Defendant to pay the costs of this action, including filing and service fees, e. Order the following additional relief, not listed above: Order Defendant to refrain from harassing Plaintiff's relatives and the parties' minor cbildren. Order Defendant to pay $250.00 to one of MidPenn Legal Services' funding sources to pay the cost of litigating this case. '='-~~ ,- . . ~ ' "0".- ~... ~- f Grant such other relief as the court deems appropriate, g, 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. __y~tt<dby~~ Joan Carey, Art. for PI . Agency: MidPeml Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 :,d,'"- ~ -" "" VERIFICATION L_ ~"- ,~--."""",,"'!rliif" 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: ~/)*I ! ~1=~ T'._=-"C_-~_~=O'=~_-~~~~O_~~~~.'~~C"'~~~~_~ . .. Fi'fCn -" OF - -.. /" ,./.-- j ,'!". ,_ \..,' -t"" li.-i::. f)~l"""'" ..:,\",t , J !'..-' i f'-ft.".NOTAAy () I JAN 23 f'M 2 II : 2? CUMBEiiLANO .. PENNSYLVA~~UNTY 0\ \,,0 /~ - Cr ./" ~/ /' I . ~ i I , , * ~ I ~ ~ :j i '& ~ ~ i . " ii ~ \f\~\D -PS-p 0-JrW W~ € 4~Ol?~~ O\So ~x.ed 10 L. S~ C-.l=: (1 'iii "(,; % ~ '-::1- j ~ j ~~ 5i ~~ \)fA ~~W- Df0M\ @ L.S, y\Q~. ~ 1'Jo-\- \>\ese~l ~ I I _J~~"' ~~ 01/23/01 TUE 16:08 FAX 717 240 6573 .- ~ 'lmOili'"",,',",,,,"_""'HC, CUlIIB CO PROmONOTARY 141001 , . i $$$$$**$*****$*$*********** *u MULTI TN REPORT u* *$$************************ TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2416 I 01] 9p2405331 I 03]9p2438026 I 04]92490779 CENTRAL PROCESS LEGAL SERVICES PSP ERROR ". OFFICE OF THE. PRal1!aIlCYl'ARY CUMBERLAND roJNT'{ COUR'IliOOSE . CX'lE CQUR11iCUSE SQUARE CARLIS~E. PA. 17013-3387 (717) 240-6195 FAX (717) 240-6573 FAX .: psP L5 .J ' C e 1l{({J I I( DC-t' 5S 01j q - cl40 - 5 3 3 J V I ATE L E COP I E R TO: FRCM: CURTIS R. LONG BE: .:p FA 0 rrJ -evS MESSAGE : ---.--- . ~ 00. OF PAGES (INCLUDING COVER sHEET) ,- ,'~j 1his ~ is interrlrl oUy fir tte lEe of tte irdividl.Bl oc mti!}' tv ..rum is is cilli. :ri, o3'rl '!ref a::ntain infi::llm;t.im tret is p:i.vi.leg:rl. cmfil:H1tial em ea;npt fron dj.....lr":lIre umr ;g;>H.......'.. 1a>I. (f 11'E ~ r.t \his" "T is rot tie inte'd3:A re::::ipjent. 'yOJ are ~ rot;iJ::ia::l ltet 00/ d,jssaniretjen. ~ ClL a:pjirg of this conn.oil:'.a!'.im is st6ctly prhibitai. If)O.l h;!I.e ra::Eive::l (jus mnl'I ni(..~icn in =. ~ rotify l.S ilme:Jj,alBly ~ lE.1.EPl:re em return tie or.igin:ll ,,~:17 to lE ill ,., ^-.~ , ~~:...I - ~" --, LOIDA MERCEDES STEVENSON, : IN THE COURT OF COMMON PLEAS OF for herself and on behalf of her minor children:: MARK CHRISTOPHER STOKES, JR., : CUMBERLAND COUNTY, PENNSYLVANIA MATTHEW ADAM STOKES, and CHRISTOPHER MICHAEL STOKES, : CIVIL ACTION - LAW Plaintiffs vs. MARK CHRISTOPHER STOKES, SR, Defendant : NO. 01-475 CIVIL TERM : PROTECTION FROM ABUSE ORD~R FOR CONTINUANCE AND NOW, this~ day of February , 2001, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on February 1, 2001, by this Court's Order of January 23,2001, is hereby rescheduled for hearing on Monday, February 26, 2001, at 1:30 p.m. in Conrtroom No.3 on the 41h 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 July 23, 2002, or until further Order of Court, whichever comes first. Joan Carey, Attorney for Plaintiff Mid-Penn Legal Services 8 Irvine Row Carlisle, P A 17013 _J,'! 0,1 ~~fff,f'~J!~Jl!j~-<(.I%i!li;I~l!iWWMbB.H~;&%,~j~_\~i'itJ"',"'\-i_Mm"i..,"~;~i~l,tioi'~d-:<:1",-;.ci;;ill!.;W:!lwll'llil[IDil,~~i1l!!~__iiiOO;j~1G~Rll_~ , "" ~~;Ii" ~ ," ,,",I ~ - --0 ^~ " (') C -/ --0 IT, rn-rr; , Z-1" ~~':. ..:<..L_ <:<C )>~ z:C,j j>g ~ -< "'~ Cl 4"\ ".....'1 ~,)Z}' 0"' :11- -~.i!1 Wlli ::-"~?r" -,:) --,.- r"; ..,"1',. .::l:? '~~~~i!, -, ',,::ff?; '0; ~ :i1 -<.. ~: o \J:) <'- -">"-.~- :i!'J~k_ LOIDA MERCEDES STEVENSON, : IN THE COURT OF COMMON PLEAS OF for herself and on behalf of her minor children:: MARK CHRISTOPHER STOKES, JR., : CUMBERLAND COUNTY, PENNSYLVANIA MATTHEW ADAM STOKES, and CHRISTOPHER MICHAEL STOKES, : CIVIL ACTION - LAW Plaintiffs vs, MARK CHRISTOPHER STOKES, SR, Defendant : NO. 01-475 CIVIL TERM : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff, Loida Mercedes Stevenson, by and through her attorney, Joan Carey ofMidPenn Legal.Services, 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 January 23,2001, scheduling a hearing for February 1, 2001, at 3:30 p.m, 2. MidPenn Legal Services staff mailed a certified copy of the Notice of Hearing, Temporary Protection From Abuse Order and Petition for Protection From Abuse to the Monmouth County Sheriff's Department in Freehold, New Jersey, and requested that they serve Defendant with the documents, On February 1, 2001, Officer ScIunidt of the Monmouth County Sheriff's Department told MidPenn Legal Services staff that their deputies attempted to serve Defendant at the address provided, but were advised by Defendant's father that he did not live there. 3. Plaintiff requests that the hearing be rescheduled pending service of Defendant. 4. 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 23, 2002, or until further Order of Court, whichever comes first. - "-c- ~ it"w- , . 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 23,2002, or until further Order of Court, whichever comes first. / o Carey, Attorney fo laintiff MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 ~- -,,";..,,<,;~Iilf.j~4W\iiW!!i!t~:rtl'$\il~l#bB!l!;I;:~!:'iW,~"4',""',~!H!!''''2-J;:,b';'''''''.&1!]MI>.l"';H~,~...ii;jM;;j~!'i.~!liltil!@i;~~ji!\~i'!Mim~i!'n.@.i~!irt]r~ ~ ~~~'fu_~_ _,-~",,_> ,-- -.-, ~~"" ,^ -,"' "- ~ ..~, Jjr1i.liU~1 0 0 (~ C .,' , , ~ .." .- J " roc f"J"1 rnr~;~ l,:),J Z:JJ L ,- (.1)]> C' -<.",:'. , . r::: \.- 5> ~, ~'''~ ') Z ,. _. P- O w . c ',,"; Z --1 ',,-,," =2 (1'\ ::0 -< - . .l ... w I. ' .t .' " ~ .~ '1:r-tN~C". Ji.' LOIDAMERCEDES STEVENSON, : IN THE COURT OF COMMON PLEAS OF for herself and on behalf of her minor children:: MARK CHRISTOPHER STOKES, JR., : CUMBERLAND COUNTY, PENNSYLVANIA MATTIIEW ADAM STOKES, and CHRISTOPHER MICHAEL STOKES, : CIVIL ACTION - LAW Plaintiffs vs. MARK CHRISTOPHER STOKES, SR., Defendant : NO, 01-475 CIVIL TERM : PROTECTION FROM ABUSE ORD~RFORCONTThmANCE AND NOW, this~ day of March, 2001, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on February 26, 2001, by this Court's Order of February 16, 2001, is hereby rescheduled for hearing on Tnesday, April 10, 2001, at 2:30 p.m. in Courtroom No.3 on the 4th Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Peoosylvania, The Temporary Protection From Abuse Order shall remain in effect for a period of 18 months from the date it was entered, through July 23, 2002, or until further Order of Court, whichever comes first, By the Court, ~ l ",~~ \ 6'( \fO ~O ~L s o ~\~ Joan Carey, Attorney for Plaintiff Mid-Penn Legal Services 8 Irvine Row Carlisle, PA 17013 '.llIIlil- . ~'~1l!!iJji.-t!jI"~~~31!;c.1.'!'b,;nl!l~tiH,(IL~I1';III"0\t:i0,~,~i&I'4il)""d-[W\"'!lW-c;:,"~::;k,.,..W!U<i'i;4~~~~I!!!!I!illO\IIt~~iI!['~ un '! I ~ ~, , "ihii:" i I r , R , v:j>J\~/\-l)\sr\li\!:j ::! "",' 'r::'_,:.."'-~::/.rt) : n , ,. n ,,,~ (.:" '.' '..t .J ~~ ~ ~ .'l LOIDA MERCEDES STEVENSON, : IN THE COURT OF COMMON PLEAS OF for herself and on behalf of her minor children:: MARK CHRISTOPHER STOKES, JR" : CUMBERLAND COUNTY, PENNSYLVANIA MATTHEW ADAM STOKES, and CHRISTOPHER MICHAEL STOKES, : CIVIL ACTION - LAW Plaintiffs vs, MARK CHRISTOPHER STOKES, SR, Defendant : NO. 01-475 CIVIL TERM : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff, Loida Mercedes Stevenson, by and through her attorney, Joan Carey ofMidPeffil Legal Services, moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. On February 16, 2001, a Motion was filed and an Order for Continuance entered rescheduling the hearing for February 26, 2001, at 1:30 p.m, in Courtroom No.3. 2, Plaintiffhas no knowledge of Defendant' s whereabouts since his release from prison in New York State, although efforts are being made to locate him, 3. Plaintiff requests that the hearing be rescheduled pending service of Defendant. 4, 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 23,2002, 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 Orner remain in effect for a period of 18 months from the date it was entered, through July 23, 2002, or until further Order of Court, ,.- , I whichever comes first. "~oj: ur .1t.1i", Respectfully submitted, ~,~L MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ~!ll1<!~;-,Jiil;r,__,il~-l'r"Mj"q"("'~''''1 !"'!i"""%'1;'l"i'<1s~,",1"~I!&;Ith!l:-ir!.d4!ilfr:;W!i,1'r,,,,,)~,,;' l;,;:i!*,"'>",lliEi~,.&_,"!L",,;;';?iW,,;.~;;illkt~ldi~oS:lli~'-~~~~""'f.">I~illo!!I;l.mw,,*,,!R~~~~il!M:1!ii,faiM("'~ * - <~ -~, ,..,.,"- o ;i~~. :'--,2:':::1:1 gl :~~;:::~; :;"'C: :;.:, --;; -.. 'c ~ ~-."" ~J>,", " ,,~~ " , ~ C) ;_c,;; ;:;J 1 tr " -} -v (..) -< ! J- '"' _ e-, ._"'__~," _ V~,__ ~- , _' ,- ." LOlDA MERCEDES STEVENSON, for herself and on behalf of her minor children: MARK CHRISTOPHER STOKES, JR., MATTHEW ADAM STOKES, and CHRISTOPHER MICHAEL STOKES, Plaintiffs : In the Court of Common Pleas of : CUMBERLAND County, : PENNSYLVANIA . : Civil Action - Law vs, : No, 01- MARK CHRISTOPHER STOKES, SR., Defendant . : Protection From Abuse : No. 01-475 CONTINUED TEMPORARY ORDER AND NOW, this 9th Day of April, 2001, pursuant to 23 Pa,C.S. S6107(c), the terms and conditions of the Temporary Order issued on 23rd Day of January, 200], 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 May 30, 2001, at 9:30AM in Courtroom 3 of the Cumberland County Courthouse, One Courthouse Square, Carlisle. est en! Judge C~~ Oy-II-Dl ~~5 Distribution To: MidPenn Legal Services Faxed & Mailed to PSP Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 ~ll!$jliiOi>~""it'n_,,~~i.~[~lllJ~i\jl,l;lI;[:i>.Mli!lt1~,$iO>~,~~~lIUta~_"--" \-./riJC\~1r.'- 'JJ Ir,c>~:-"H\;i\',)Jd\i..:!d ^' \ ,\" -'- ,~ , " ,,~_:,_, I !kYJ~^I(I:1 .., _J'."'~ ;,~. "I ;:; :'1 [:,'iJ o I ~;d~ In 1.-' ~............'-"-~~,"* 'Jil>!ll.;ij;,hr"') '" "'~ .. ,_~ "0, ""-,-, ~'""d""__', ".~ ~ LOIDA MERCEDES STEVENSON, : IN THE COURT OF COMMON PLEAS OF for herself and on behalf of her minor children: MARK CHRISTOPHER STOKES, JR., : CUMBERLAND COUNTY, PENNSYLVANIA MATTHEW ADAM STOKES, and CHRISTOPHER MICHAEL STOKES, : CIVIL ACTION - LAW Plaintiffs vs. MARK CHRISTOPHER STOKES, SR., Defendant : NO, 01-475 CIVIL TERM : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff, Loida Mercedes Stevenson, by and through her attorney, Joan Carey of MidPenn Legal Services, 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 January 23,2001, scheduling a hearing for February 1,2001, at 3 :30 p.m,; because the defendant was not served, the hearing was continued to February 26, 200 I, and again to April 10, 2001, at 2:30 p,m. 2, In early April, the defendant retained the Family Law Clinic to represent him, and the parties agree, by and through their respective counsel, that the hearing be rescheduled to afford them time to execute a Consent Agreement. 3, The Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. . WHEREFORE, the 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 eighteen months from the date it was entered or until further Order of Court, whichever comes first. oan Carey, Attorney for Pia' ti DPENN LEGAL SER S 8 Irvine Row Carlisle, P A 17013 .. ." LOllA MERCEDES STEVENSON, for herself and on behalf of her minor children: MARK CHRISTOPHER STOKES, JR, MATTHEW ADAM STOKES, and CHRISTOPHER MICHAEL STOKES, Plaintiffs vs, MARK CHRISTOPHER STOKES, SR., Defendant I, ,- -,-' ":',",,~:, '0" <-,',_i' _ ___ ~~.....~",;;, : In the Court of Common Pleas of : Cumberland County, Pennsylvania : Civil Action - Law : No. 01- 475 Civil Term : Protection From Abuse ACCEPTANCE OF SERVICE I, Steven Boell, Legal Intem, do hereby certifY that on April 10, 2001, I accepted service of the Temporary Protection From Abuse Order, Petition for Protection From Abuse, and Continuances in the above-captioned matter on behalf of Defendant , Mark Christopher Stokes, Sr., and certifY that I am llUthorized to do so. Date: 4/;;0/ &} I . ~--' ~ Steven Boell, Legal Intern q(jl~. ~ Teri Henning, Supervising Professor Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 .~ J!l1~lMt~MJj!:~~ ~..- .il~_~IOI~~'"G!W!!!:wii~'-l>.i;~iii; "< " ,~" ,-,-- ^<, 1'- ~-4''';.<;~ji -Ji::M!iil:'i".mMf " ~ ~~,. ,J ~:-"w= 'I ^ .'" ,,- r.n - " ". . . (") 0 0 C -n ;l:: .",. "UOJ --0 :D mrn ::0 Z::'l} N ""'j"'r:~-n &i:E; ~f"'10 0'> {~!t} 20 -0 -Jj" ;< /"S-ri ~o :3: ".('') 0 r;:' -p:::;rn 5>c :::::, ~ U1 ~ CJ1 '-< . ..,.....- ,~ ,- ; .. - ',>~. h- ,'_' I.:, '.' _-,' ~-_~,~ . ' " '" =,,<0 -1.",,"-'-, , LOIDA MERCEDES STEVENSON, for herself and on behalf of her minor children: MARK CHRISTOPHER STOKES, JR., MATTHEW ADAM STOKES, and, CHRISTOPHER MICHAEL STOKES, Plaintiffs : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYL V ANlA : CIVIL ACTION - LAW : NO. 01-475 v. : PROTECTION FROM ABUSE MARK CHRISTOPHER STOKES, SR., Defendant/Petitioner ORDER OF COURT AND NOW, this ~1 ~ay of m~/' ,2001, upon consideration of Petitioners' Petition for a Continuance, it is ordered and directed that the hearing on this matter scheduled for May 30, 2001, at 9:30 a,m, shall be continued until August 7,2001 at 3:30 p,m, BY THE COURT, J, ./1 L~ 5 -,29-()J ~~ I . ' -, ^ . ~^"~ i,J,f; j LOIDA MERCEDES STEVENSON, for herself and on behalf of her minor children: MARK CHRISTOPHER STOKES, JR, MATTHEW ADAM STOKES, and, CHRISTOPHER MICHAEL STOKES, Plaintiffs : IN THE COURT OF COMMON PLEAS :OFCUMBERLANDCOUNT~ : PENNSYLVANIA : CIVlLACTION - LAW : NO. 01-475 v. : PROTECTION FROM ABUSE MARK CHRISTOPHER STOKES, SR, DefendantlPetitioner PETITION FOR A CONTINUANCE The Petitioner, Mark Christopher Stokes, Sr., by his attorneys, the Family Law Clinic, hereby petitions this Honorable Court to grant a continuance of the hearing in this matter, currently scheduled for May 30, 2001 at 9:30 a.m. In support of his petition, Petitioner represents the following: 1. The Petitioner is Mark Christopher Stokes, Sr. 2. On January 23, 2001 a Temporary Protection From Abuse Order was issued against the Petitioner. 3. The Temporary Protection From Abuse Order was issued on behalf of Loida Mercedes Stevenson, Mark Christopher Stokes, Jr., Matthew Adam Stokes and Christopher Michael Stokes. 4. The Temporary Protection From Abuse Order is to remain in effect until July 23, 2002 or until otherwise modified or terminated by this Court. 5. Under the Temporary Protection From Abuse Order, Petitioner is to have NO CONTACT with any of the plaintiffs. ,~-- ' ,~ " '-,-I; ~" "'-~- '.- '" ":'--~-""::v- ", 6. The hearing in this matter is scheduled for May 30, 2001 at 9:30 a.m. 7. Petitioner wishes to attend the scheduled hearing and oppose the entry of a PF A Order. 8. Petitioner began anew job on May 1,2001, for which he has a probation period of 90 days. Petitioner may not miss a day of work until his 90 days probation expires on or about August 1, 2001. 9. Plaintiffs, by their attorney, MidPeun Legal Services, have consented to this continuance. 10. Petitioner asks that this Court reschedule the hearing in this matter until some time after August 1, 2001, so that he can attend the hearing. WHEREFORE, Petitioner respectfully requests that this Court grant a continuance in this matter until after August 1, 2001, to allow time for Mr. Stokes' work probation period to expire so that Mr. Stokes can attend the hearing scheduled in this matter. Date: May 29, 2001 Respectfully submitted, ~C{L. ~ r* --0\~ Debra Hart Munchel Certified Legal Intern -;J-~ ~ J ~ERT E. RAINt J THOMAS M. PLACE TERl L. HENNING Supervising Attorneys FAMlL y LAW CLINIC 45 North Pitt Street Carlisle, P A 17013 (717) 243-2968 ,~ ,~~ -,- ~- - ",' ',~", I __.c,.<_;;, ,-, "-'. "" '-~";,-;,"_. '" '< .c. . , CERTIFICATE OF SERVICE I, Debra Hart Munchel, hereby certify that on this 29th day of May, 2001, I am serving a true and correct copy of the Petition For a Continuance on the following individual, by fIrst class mail, postage prepaid: Joan Carey, Esq. MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 Date: May 29, 2001 ~lo.~.l*~J~ Debra Hart Munchel CertifIed Legallntem F AM1L Y LAW CLINlC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 - 0-liilii~iilI~".J.; ,,-~ .~'_ ~ ~&tEIiUJl.~JJiO)\1~1~~ ,~ '""-'~-" ,~ "'~ ,~ ~ ~ , . ,.~. "~ ,~-, .. '" ~, '0""" o. ",. ' '--! I C G ~.;: CI c '- d< r n ~ ~ T' (,;:, f--J \D , ~c ~ '-j , .'~~ 2.-': " (-, .J' r"-:' ':.-lJ - ~- - L, .. ~ =2 .'-.:J ~] co --< ,"'-- " _ ~ " 0' ;_, . "",-.~'-'..-;.' ;."~--I,--, '~', ,C ,<, -~".i' ,,_;;,..., ~~_~,_>" <to t. LOIDA MERCEDES STEVENSON, for herself and on behalf of her minor children: MARK CHRISTOPHER STOKES, JR., MATTHEW ADAM STOKES, and, CHRISTOPHER MICHAEL STOKES, Plaintiffs : IN THE COURT OF COMMON PLEAS :OFCUMBERLANDCOUNT~ : PENNSYL V ANlA : CNlL ACTION - LAW : NO. 01-475 v. : PROTECTION FROM ABUSE MARK CHRISTOPHER STOKES, SR., DefendantlPetitioner ORDER ALLOWING DEFENDANT TO TESTIFY BY TELEPHONE AND NOW, this c; day of ~, 2001, pursuant to Pa.R.C,P. 1930.3 and upon review of the attached Uncontested Petition to allow Defendant, Mark C. Stokes, to Testify by Telephone, it is hereby ordered that Mark C. Stokes, may testify by telephone at the Protection From Abuse hearing scheduled for Tuesday, August 7,2001 at 3:30 p.rn. for the limited purpose of addressing telephone contact between hinIself and the parties' children. By th~"<:pUTf,-/ ( .~ l~~~ .ItHon._George E. Ho _I"'"'' .ij~:rj\t'>b'}1IHjj ~ , ....;- ,-" 1 ' ,~~~ ""'...;:ili...~~ilil8l/!' VINVA1ASNN3d )JJ~nO~) (!1\'\ill:i38V'lnO lS:8 "iV 9- tintt /0 · '''fir.'';"',, ,,'.' '"" '0 ^d\_vl' l~,/r-ii\"':CCi :1;")1; .J- 38!:J:iD-CI31i::i .. ",'-" ~_<,c,__. ' '^' ,;;'", " ^_ J. ,^~^ -", _~ ~J .. , l;/it'~~l~~~,~~~Ii~nQ JJ.NnOv c ' ~ ty\\j \[) . II \\\1 l;j- '-'I . , 8\ 'c' I U;.l11'J'1\C,;':::'~ -:\'\1'1 f\OoJ ''''-V)H--IC,I-\.J,.J '^' :J\-.. ,-- ~o ~ _, l --.)-I~' ;c" ~i!,', ""'1,', -J;. - -- -' , '~- C...;'-" .""",_-',,, '~ '.....~""Ii1t,' , - LOIDA MERCEDES STEVENSON, for herself and on behalf of her minor children: MARK CHRISTOPHER STOKES, JR., MATTHEW ADAM STOKES, and, CHRISTOPHER MICHAEL STOKES, Plaintiffs : IN THE COURT OF COMMON PLEAS :OFCUMBERLANDCOUNT~ : PENNSYL V ANlA : CIVIL ACTION - LAW : NO. 01-475 v. : PROTECTION FROM ABUSE MARK CHRISTOPHER STOKES, SR., Defendant/Petitioner UNCONTESTED PETITION TO ALLOW DEFENDANT, MARK C, STOKES, TO TESTIFY BY TELEPHONE Petitioner, Mark C. Stokes, hereby petitions this Court, pursuant to Pa.R.c.P. 1930.3, to allow hin1 to testify by telephone in the Protection From Abuse hearing in this case. In support of his petition, Petitioner represents the following: 1. A Protection From Abuse hearing has been scheduled in this matter for Tuesday, August 7,2001 at 3:30 p.m, 2. While denying the allegations of abuse, Petitioner will consent to entry of a Protection From Abuse Order. The only issue as to which the parties do not currently agree is related to telephone contact between Petitioner and the parties' children. 3. Petitioner is unable to appear for the hearing because he lives and works in New York City as a window washer and cannot afford to miss a day of work and pay for the costs of a trip to Central Pennsylvania at this time. 4. On August 7 at 3:30 p.rn, Petitioner will be available to participate in the hearing via telephone, ,',,,", , -",-, " .. ',- ' I-;~ ' , , ",', u ,,_,_~,,_,~ .,', -''''','' , 5. Plaintiff's counsel at Legal Services has been notified of the filing of this petition, and has consented to allowing Petitioner to participate and testify by telephone for the limited purpose set forth above. 6. Pursuant to Pa.R.C.P. 1930.3, the Court may permit a party to testify by telephone in domestic relations matters. WHEREFORE, Petitioner asks the Court to allow the Petitioner to testify by telephone at the Protection From Abuse hearing on Tuesday, August 7,2001 at 3:30 p.m. for the limited purpose of addressing telephone contact between hinIself and the parties' children. Date ~~~ ~ ~'\ '\Jo~,,~,,-~~ Debra Hart Munchel Certified Legal Intern ~~ Thomas M. Place Ten L. Henning Supervising Attorneys FAM1L Y LAW CLINlC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ".' ~> ,., ,,"""-'''-~ ." " ,,-,-. , ,"".",,,,,-i.. ,.c> ,~" . 1-, ,,-' . ,<, '"",-" p, i' ,d,'--''',,~,,~ ,,--,:~,,/~- "ii," , ,'< j. LOIDA MERCEDES STEVENSON, for herself and on behalf of her minor children: MARK CHRISTOPHER STOKES, JR., MATTHEW ADAM STOKES, and, CHRISTOPHER MICHAEL STOKES, Plaintiffs v. MARK CHRISTOPHER STOKES, SR., Defendant/Petitioner -, ..;;-.;~~ :j " I" : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYL V ANlA : CIVIL ACTION - LAW : NO. 01-475 : PROTECTION FROM ABUSE CERTIFICATE OF SERVICE I, Debra Hart Munchel, Certified Legal Intern at the Family Law Clinic, hereby certify that I anI serving a true and correct copy of the Uncontested Petition to Allow Defendant, Mark C. Stokes, to Testify by Telephone on the following person by hand delivery this 3'd day of August, 2001: Joan Carey MidPeml Legal Services 8 Irvine Row Carlisle, P A 17013 Y')fl~~\~~~ Debra Hart Munchel Certified Legallntem FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 , ,," v.' ). ,..' I', . -~, ~ ; ," ~--,- ~'I,: LOllA MERCEDES STEVENSON, for herself and on behalf of her minor children: MARK CHRISTOPHER STOKES, JR., MATTHEW ADAM STOKES, and, CHRISTOPHER MICHAEL STOKES, Plaintiffs : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, : PENNSYLVANIA : CNlL ACTION - LAW : NO. 01-475 v. : PROTECTION FROM ABUSE MARK CHRISTOPHER STOKES, SR., DefendantlPetitioner ORDER AND NOW, this <It day of ~2001, by agreement of the parties, this matter is generally continued in order for the parties to execute a Consent Agreement. The January 23,2001 Temporary Order shall remain in effect, ~- "':<~ cc: Joan Carey, Esquire, Counsel for Plaintiff The Family Law Clinic, Counsel for Defendant i/ ,~ ~'\ ..... lli'" ", "_,',,V .m~tl ~ ". ,~~ ,,- ,. -iliil:tif""'"lN' w ..''- ,", ~ . 'rirLl.il~' .--.' ,~'0-',' "~",. _ ... .. ('(.i""~~:' __"~," ", ",. lIJtiil. vi.' ",.",","'" ,... "'''''''0",.""",,,, , T' d'" ",c:.""""~"NrO d'''-'i'll\ ". ';: (\'0-\;::"'\\ '\1\\......... 1'"",\-'\ ,>," f"" ,',. ,\1:',(\\),,) \'\ j'Y'\\ ' \ ;.,\';~~ V ,\\':- \) \ .)\ C)~ ',\')\ ';\' ",.,,(;.:;!.;, "'j,\'. \J)~L,;,.,>-.,,',,\~d "~~ f" -:\"y , '"'1'":i.":;', ",' --, ~ '__l; ,-,,',,'< - I. '",",,,-;"",, . '~,- , ' ~. . ~';", LOIDA MERCEDES STEVENSON, : In the Court of Common Pleas of for herself and on behalf of her minor children: MARK CHRISTOPHER STOKES, JR" : CUMBERLAND County, MATTHEW ADAM STOKES, and CHRISTOPHER MICHAEL STOKES, : PENNSYLVANIA Plaintiffs : Civil Action - Law vs, : No. 01-475 MARK CHRISTOPHER STOKES, SR., Defendant : Protection From Abuse FINAL ORDER OF COURT Defendant's Name is: MARK CHRISTOPHER STOKES, SR. Defendant's Date of Birth is: October 21,1963 Defendant's Social Security Number is: 080-56-5085 Name(s) of All protected persons, including Plaintiff and minor children: 1. LOIDA MERCEDES STEVENSON 2. MARK CHRISTOPHER STOKES, JR. 3, MATTHEW ADAM STOKES 4, CHRISTOPHER MICHAEL STOKES AND NOW, this 5th Day of October, 2001 the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows: Plaintiff, Loida Mercedes Stevenson, is represented by Joan Carey of MidPenn Legal Services; Defendant, Mark Christopher Stokes, Sr" is represented by Debra Hart Munchel, Certified Legal Intern and Ten 1. Henning, Supervising Attorney of Family Law Clinic, Defendant, although agreeing to the terms of this Order, does not admit the allegations made in the Petition, I',;;" ,-' : '" ~c. " ,'-'~'" ,-I" ;, " '~'-'~~"-"': ~ "'q.,,~ 1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other protected person in any place where they might be found. 2. Except as provided in Paragraph 3 of this Order, Defendant is prohibited from having ANY CONTACT with the 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 employement. Defendant is specifically ordered to stay away from the following locations for the dUlation of this order. Plaintiffs current residence, which is confidential, and any other residence she and her minor children may establish for themselves during the term of this Order. Wherever Plaintiff and/or her minor children may be employed dnring the term oHhis Order. The schools of the minor children, which are confidential. Defendant shall not contact the Plaintiff, Loida Mercedes Stevenson, by telephone or by any other means, including through third persons. 3. Custody of the following minor children: 1. MARK CHRISTOPHER STOKES JR. 2, MATTHEW ADAM STOKES 3. CHRISTOPHER MICHAEL STOKES shall be as follows: . PARAGRAPH 3 OF THIS ORDER IS NOT A CUSTODY ORDER AND IS NOT INTENDED TO GIVE DEFENDANTIFATHER ANY CUSTODIAL RIGHTS. PARAGRAPH 3 OF THIS ORDER IS INTENDED TO LIMIT AND DEFINE THE PARAMETERS OF DEFENDANTIFATHER'S CONTACT WITH THE CHILDREN WHO ARE PROTECTED PERSONS UNDER THIS PROTECTION FROM ABUSE ORDER. DefendantlFather of Plaintiffs children listed in this Order, shall be permitted contact of a non-harassing nature with the children as follows: Father is permitted to write letters to the children at a Post Office box paid for by Father, or at an address mutually ..'" . , -1--, ~; i-he, !%\."', agreed upon by the parties. The parties have agreed that Father's initial letter to each child will be sent to the Family Law Clinic, which will forward them to MidPenn Legal Services, for forwarding them to the children. Father shall provide the children with his telephone number and prepaid telephone cards and the children shall be per.mitted to call the Father as they desire. Plaintiff shall not interfere with the children calling their father if the children wish to do so. Any such non-harassing contact between DefendantlFather and the children shall not be a violation ofthis Order, 4. The following additional relief is granted as authorized by g6l08 of the Act: Defendant is prohibited from having any contact with Plaintiff's relatives and Plaintiff's children, except as provided in Paragraph 3 ofthis Order. Defendant is ordered to refrain from harassing Plaintiff's relatives and Plaintiff's children. The court costs and fees are waived. 5. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: APPROPRIATE POLICE DEPARTMENTS 6. THIS ORDER SUPERSEDES: 1. ANY PRIOR PF A ORDER 7. All provisions of this order shall expire on: February:z.~, 2003 NOTICE TO THE DEFENDANT - " , - '.'-'_M" " ~ ~"ilhf VIOLATION OF TIllS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT wmCH IS PUNISHABLE BY A FINE OF UP TO $1,000 ANDIOR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S. ~6114, VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYL V ANlA CRIMES CODE. THIS ORDER IS ENFORCEABLE IN ALL FIFTY (SO) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, US. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, IS US.C, ~226S.IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE TillS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT.lSUS,C ~~226l- 2262. IF THE BRADY INDICATOR PARAGRAPH APPEARS IN THE ORDER, YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT, IS US.c. ~922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION. NOTICE TO LAW ENFORCEMENT OFFICIALS 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, shall enforce this order. An arrest for violation of Paragraphs 1 through 3 of this order may be without warrant, based soley on probable cause, whether or not the violation is committed in the presence of the police. 23 Pa.C,S, ~113. Subsequent to arrest, the police officer shall seize all weapons used or threatened to be used during the violation of the protection order or during prior incidents of abuse. The shall maintain possession of the weapons until further order ofthis Court. When the defendant is placed under arrest for violation of this order, the defendant shall be taken to the appropriate authority or authorities before whom defendant is to be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police officer OR the plaintiff. Plaintiffs presence and signature are not required to file the complaint. If sufficient grounds for violation of this order are alleged, the defendant shall be arraigned, bond set and both parties given notice of the date of the hearing. ~ 'l"1in BY THE COURT, Judge This Or er is entered pursuan to the consent of Plaintiff and Defendant: ~c~ Mark Christopher Stokes, Sr., Defendant -! ;;;;;jd:::;Z- Carey Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 S\JoOJ.sJ....~l*~h.o9 Debra Hart Munchel Certified Legal Intern for Defendant ~~. It/- Thomas M. Place Robert E. Rains Supervising Attorneys Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 ~~ c.- \? ~ ~? ~~~~M,t~~>i';'~,~1I!J@fU~~~~it~~;'j)i"';'~-=~"'~I~~-~" ,::.qr', J-- ~ [.l"~'~--""""5'P;^~,",'.r~~~L " '~" ,0 -- ."",."",.., VINvi\l}..~;I\INjd 'n"'" , rOJ ""'1...)r:) '\11 ~\" ' L ) i" I ,~' "1"-"!' i l / J d :."r. -' "',,, " i U ::! ; '\: ~ ,bU" ~ 1 -- ~'J" I' , '_" ',I ,.,,- ,- 1',--- "~",,""~' ....'W&""j,~ -~"~MIlli ~" '. ., ..~ ~ '''1 ~~ _ __~_~..u;. I. .,. .j~"""Jt-'- 10/05/01 FRI 12:48 FAX 717 240 6573 CUlIIB CO PROTHONOTARY ~001 *************************** *** MuLTI TN REPORT *** *************************** TX/RX NO JNCOMPLETE TX/RX TRANSACTION OK 2832 I 01] 9p2490779 I 03]9p2405331 I 04]92438026 PSP CP LS ERROR . . OFfICE m' '!HE PRCYI'HCNYtAR'l CUMBERLAND ClXJNfY COUR1HCXJSE ONE COURTHOOSE SQUARE CARLISLE. PA. 17013-3387 (717) 240-6195 FAX (717) 240-6573 V I ATE LEe 0 PIE R TO: PA STATE POLICE - (!tf.,I"", P.eDe.C.as.. 111.1'. L. ~ . FAX #: 717-249-0779 c ., ~; CURTIS R. LONG RE: PFA ORDERS MESSAGE : L()~ 00. OF PAGES (IW-:WDING OOVER SHEET) 'Il1is ~ is inlb(bJ rnJ,y fir lfB tsO) of lfB irdivitlJal. a; HJtity to Wlich is is 01]. I. en! rray o:ntain infumHt:im lh:lt is J;rivi.le;Jrl. cmf:idential en:l earpt fmn i1i.....]NOIte ~ 'f-pH.....nlE" Iiw. rf tI-e ~ of this ~ is rot tl-e inle-de:l t.<Cipislt, )0..1 are l1erfby rotifial lh:lt ""I (!isgEmimtirn, distrib.lt.im cr o:pfirg of this o:rnnnicatim is stdct1y p:dUhi.tai. If)O..l h:M3 L'a:Eiw:l lh:1.s <XmlU1icdtim in eo:>;r. pleEee n::tify \S irrrnrliately l:!f tal.ePl:re ood r:eb.lm ttE odgin3lll~ -ry' to u:; at the an.-: <d:lmss via tie ,l.S. rn<tnl -.vi"" ~ .~.