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Home My WebLink About01-0555 FX ~ , ' "-i .,--' 1-", ""'--'", --" '''''''''j,,' SHERRI GOSSARD, for herself : IN THE COURT OF COMMON PLEAS OF and on behalf of JAMES GOSSARD, a minor child and SARAH GOSSARD, a minor child : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN PROTECTION FROM ABUSE LARRY GOSSARD, Defendant : NO. 2001 - .j-.!,5' CIVIL TERM PETITION FOR PROTECTION FROM ABUSE I. Plaintiffs name is: Sherri Gossard, 2. I am filing this Petition on behalf of [x] Myself and/or [ x ] Another Person If you checked "myself," please answer all questions referring to your self as "Plaintiff's. " If you checked "Another Person," indicate your relationship with the Plaintiff's [x ] parent of minor Plaintiff(s) [ ] applicant for appointment as guardian ad litem of minor Plaintiff( s) [ ] adult household member with minor Plaintiff(s) [ ] court appointed guardian of incompetent Plaintiff(s) 3. Name(s) of ALL person(s), including Plaintiff and minor children, who seek protection from abuse: Sherri Gossard, James Gossard and Sarah Gossard [ ] Plaintiff s address is confidential or [ x] Plaintiff s address is: 46 N. East Street, Carlisle, P A 4. Defendant is believed to live at the following address: 15 Piper Court, Carlisle, PA. Defendant's Social Security Number (if known) is: 182-50-6611 Defendant's date of Birth is: 11/8/62 I I , -1- Defendant's place of employment is: Pennsylvania Department of Corrections, State Correctional Institution at Camp Hill, Camp Hill, P A [ ] Check here if Defendant is 17 years old or younger. 6. Indicate the relationship between Plaintiff's and defendant. [ x] Spouse [ ] Current/former sexual/intimate partner [ ] Ex-spouse [ ] Parent/child [ ] Persons who live or have lived like spouses [ ] other relationship by blood or marriage [ x] Parents of the same children 7. Have Plaintiff's and Defendant been involved in any of the following court actions [x ] Divorce [ ] Custody [x] Support [ ] Protection From Abuse If you checked any of the above, briefly indicate when and where the case was filed and the court number if known: A divorce action was filed on June 29, 2000 under file number 2000-4656 in the Cumberland County Courthouse, Carlisle, P A and a support complaint has been recently filed by the Plaintiff's and have yet to receive an assigned PACSES Number. 8. Has the Defendant been involved in any criminal court action? No. If you answered Yes, is the Defendant currently on probation? 9. Plaintiff's and Defendant are parents of the following minor child!ren: Name Ages who reside at (list address unless confidential) James Gossard, born February 25,1990 and is 10 years old and resides at 46 N. East St. Carlisle, P A. Sarah Gossard, born December 14, 1995 and is 5 years old and resides at 46 N. East St. Carlisle, P A. 10. If Plaintiff and Defendant are parents of any minor children together, is there an existing Court Order regarding their custody? NO If you answered Yes, describe the terms of the Order (e.g., primary, shared, legal and! or physical custody): '." " ~" I ._< If you answered Yes, in what county and state was the Order issued? (a) If you are now seeking an Order of child custody as part of this petition, list the following information: Child's Name Person(s) child live with Address, unless confidential When (b) List any other persons who are known to have or claim a right to custody of each child listed above. NI A Name Address Basis of Claim 11. The following other minor child/ren presently live with Plaintiff: None. Name(s) Age(s) Plaintiff s relationship to child/ren 12. The facts of the most recent incident of abuse are as follows: Approximate Date: Approximate Time: Place: January 15,2001 9:15 p.m. Plaintiff's home Describe in detail what happened, including any physical or sexual abuse, threats, injury, incidents of stalking, medical treatment sought, and/or calls to law enforcement: At 9:15 p.m. on the evening of January 15, 2001, Defendant appeared at the Plaintiff's home without notice. At that time he confronted the Plaintiff regarding her request to change the Order that each of their names appeared on mortgage documentation with their lender. This discussion then became more animated regarding other fmancial matters at which time the Defendant announced that he "will come into the house when I feel like it". The Defendant also admitted that he had entered the premises forcefully in the past and had secured entry by breaking a door in the basement. While no physical violence occurred on January 15, 2001, the Defendant exhibited severe anger, to a degree that he had shown in the past at times when he had become violent with the Plaintiff and the parties' children. On January 9, 2001, the Defendant entered into the home without knocking while the parties' son James and a friend were in the home. At that time he went to the parties' china cupboard and removed personal papers that belong to the Plaintiff and when the parties' son inteljected, the Defendant told his son "what are you looking at". Later that evening when the Plaintiff contacted the Defendant by telephone and requested that he stay away or at least call prior to coming to the home he advised her" I can come when ever I want that he had done it before to remove other documents from the home and that he would do it again". On January 8, 2001 the Defendant parked his truck in front of the home for 3 Yz hours and left papers at the Plaintiffs door causing her concern and fear. 13. If the Defendant has committed prior acts of abuse against Plaintiff or the minor child/ren, describe these prior incidents, including any threats, injuries, or incidents of stalking, and indicate approximately when such acts of abuse: On several prior occasions the Defendant has hit parties' child James. The child's counselor advises that the child has begun to model his behavior upon that of the father in terms of the child's propensity to become violent. An example of the type of abuse that the Defendant has utilized against the child occurred during the middle of the scholastic year of 1999-2000 at which time the Defendant used a baseball bat to repeatedly strike the bottom of the child's feet. This caused the child such pain and discomfort that individuals at the child's school noted the injuries and a report was made to the Children and Youth Services. During the fall of 1999 during an argument between the Plaintiff and Defendant the Defendant ripped shelves off of the wall and threw cans of paint and paint thinner against the wall and on the floor he attempted to pick the Plaintiff up and forcibly remove her up the basement stairs. He injured her ankle severely, which caused it to swell significantly. While yelling and screaming at her, he pushed a door shut on her hand breaking her finger and continued to pin her. This incident took place in front of the children. The parties' son James, shocked by this incident attempted to call 911 for help. The Defendant grabbed him and backed him into the corner threatening him not to utilize the phone. In June 2000 the Plaintiff had to intercede between the Defendant and the parties' son to protect him. At that time, the Defendant threatened to use guns and "blow his brains out". 14. List the weapon(s) that the Defendant has used or threatened to use against Plaintiff or the minor child/ren: An unspecified number of firearms. 15. Identify the police department or law enforcement agency in the area in which Plaintiff s lives that should be provided with a copy of the protection order: Carlisle Police Department and Pennsylvania State Police Department. 16. There is an immediate and present danger of further abuse from the Defendant. CHECK THE FLLOWING BOXES ONLY IF THEY APPLY TO YOUR CASE AND PROVIDE THE REQUESTED INFORMATION k-~L I,. , -"1.- :Ii [ X] Plaintiff's are asking the court to evict and exclude the Defendant from the following residence: 46 N. East Street and 48 N. East Street, Carlisle, P A. [ ] owned by (list owners, ifknown): [ ] rented by (list all names, if known): [ ] Defendant owes a duty of support to Plaintiff's and/or the minor children [ ] Plaintiff has suffered out-of-pocket fmanciallosses as a result of the abuse described above. Those losses are: 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 (CHECK ALL FORMS OF RELIEF REQUESTED): [ x ] A. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or minor children I any place where Plaintiff's may be found. [ x ] B. Evict/exclude Defendant from Plaintiffs residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff's. [] C. Require Defendant to provide Plaintiff and/or minor child/ren with other suitable housing. [] D. Award Plaintiff temporary custody of the minor child/ren and place the following restrictions on contact between Defendant and child/ren: [ x ] E. Prohibit Defendant from having any contact with Plaintiff and/or minor children, either in person, by telephone, or in writing, personally or through third persons, including but limited to any contact at Plaintiff'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 children. [x] F. 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. [ x ] G. Order the Defendant to temporarily turn over weapons to the Sheriff for this County and prohibit Defendant from transferring, acquiring or possessing any such weapons for the duration of the Order. , ~'" .~ I, - . ,_.~- I . - ~ . [] H. Order Defendant to pay temporary support for Plaintiff and/or the minor child/ren, including medical support and [ ] payment of the rent or mortgage on the residence. [] I. Direct Defendant to pay Plaintiff's for the reasonable financial losses suffered as the result of the abuse, to be determined at the hearing. [ x ] J. Order Defendant to pay the costs of this action, including filing and service fees. [x] K. Order Defendant to pay Plaintiff's reasonable attorney's fees. [] L. Order the following additional relief, not listed above: [ x ] M. Grant such relief as the Court deems appropriate. [x] N. 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 Plaintiff's will inform the designated authority of any addresses, other than Defendant's residence, where Defendant can be served. Date: 11 'ZG !O I . VERIFICATION OF PLEADINGS The foregoing document is based upon information which has been gathered by my counsel and myself in the preparation of this action. The language of the document may, in part, be the language of my counsel and not my own. I have read the statements made in this document and to the extent that it is based upon information which I have given to my counsel, it is true and correct to the best of my knowledge, information and belief. To the extent that the contents of the statements are that of counsel, I have relied upon counsel in making this Verification. I understand that false statements herein are made subject to the penalties of 18 P A. C.S. ~ 4904, relating to unsworn falsification to authorities. D'"' h It .200~ ~~t-, - ", y -, ~--""""-}(i . . ~ JANt6 20pJ" SHERR! GOSSARD, for herself : IN THE COURT OF COMMON PLEAS OF and on behalf of JAMES GOSSARD, a minor child and SARAH GOSSARD, a minor child v. : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW : IN PROTECTION FROM ABUSE : NO. 2001- 66'$ CML TERM LARRY GOSSARD, Defendant NOTICE OF BEARING AND ORDER YOU HA VB BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you in 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. //'V . ~ hearing on the matter is scheduled for the ~, day .z,.~~ ' 2001, at ,;2.:)0 o'clock, in Court room #.3 at Cumberland Co Courthouse, Carlisle, Pennsylvania. . of the 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 $1,000.00 and/or up to six months in jail under 23 Pa.C.S S 6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. S 2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. SS 2261-2262. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOUR HAVE THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEARING. THE COURT WILL NOT, HOWEVER, APPOINT A LAWYER FOR YOU. IF YOU DO NOT HAVE A LWAYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT FIND A LAWYER, YOU MA Y HAVE TO PRECEED WITHOUT ONE. Cumberland County Bar Association 2 E. Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 !!'n,"c!cc . . ,I' ,..... T. LI~, . l.1TI,.~ .~ ,t~ ."^ ' , , '~~~ "" '. - 0" '" I" ';";'c "--'~ -'.',',_ ""k;", """,,~.-, '_~",,' ,'.';0-'c,,'. .~. '. ,-~.~-~ 'r . '~~~=-",-w"'T"<>~"~~"},f2t~~ " ~~; '1 ~ < o ~ ""-" 11\ ~ J .j ~ ~ lJ FF Ff'L(y..':{-;/"'.r (,,,,eo "f'. l'.>~~'~:: ,."':'/ 1'"~vt: .It" :h" :-<> :,f1-Jr.:i\j,....frt,ny ... "--' , t-~,; 'j~..t1l1n t 'l ;') "., , 01 JAN 26 PM 3:::14 CUM8EHIJlJ\iO COUNlY PENNSYLVANIA ~ ,.i__~~~~"'~'jl!'lfl':-lJi"jl.'l'U";'Y*~'F~'"1'W:~~AA!1!~!Jt>>$.'jn,""'-ffIW"''''''i'' """',";''f.w,~I)'iJl~~f:lf~~ ~~ , -.- c." , ." ,'-'~"" ,,::;. "". c... . . SHERR! GOSSARD, for herself : IN THE COURT OF COMMON PLEAS OF and on behalf of JAMES GOSSARD, a minor child and SARAH GOSSARD, a minor child : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION - LAW : IN PROTECTION FROM ABUSE LARRY GOSSARD, Defendant : NO. 2001 - 5:{'::' CIVIL TERM TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name: Larry Gossard Defendant's Date of Birth: November 8,1962 Defendant's Social Security Number: 182-50-6611 Names of all protected persons, including Plaintiff s and minor child/ren: Sherri Gossard, James Gossard and Sarah Gossard ~ ~ AND NOW, this c2b day of flUU /' 200~, upon consideration of the attached Petition for Protec . From duse, the court hereby enters the following Temporary Order: [x] 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. [ x] 2. Defendant is evicted and excluded from the residence at [46 North East Street, Carlisle, P A] or any other permanent or temporary residence where Plaintiff s may live. Plaintiff's are granted exclusive possession of the residence. Defendant shall have no right or privilege to enter or be present on the premises. [ x] 3. Except for such contact with the minor child/ren as may be permitted under Paragraph 5 of this Order, Defendant is prohibited from having ANY CONTACT with Plaintiff's 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: (enter address here) residence; 46 N. East Street, Carlisle, P A; and P A Dept. of Agriculture, Bureau of Food Safety and Lab Services (Plaintiff's work place) ~..~~. , J, -';_1_.:., ,i,\ , ~ , . " , [ x] 4. Except for such contact with the minor child/ren as may be permitted under Paragraph 5 of this Order, Defendant shall not contact Plaintiff's by telephone or by any other means, including through third persons. [ ] 5. Pending the outcome of the final hearing in this matter, the parties shall continue to exchange custody based upon the schedule that they have reached informally. [ x] 6. Defendant shall innnediately relinquish the following weapons to the Sheriff's Office or a designated local law enforcement agency for delivery to the Sheriff's office: All Hunting Knives, Butcher Knives, Pocket Knives, Unregistered Handguns, Registered Handguns and Shotguns. The Defendant is prohibited from possessing, transferring or acquiring any other weapons for the duration of this Order. [ ] 7. The following additional relief is granted: [x] 8. A certified copy of this Order shall be provided to the police department where Plaintiff's resides and any other agency specified hereafter: Carlisle Police Department, Pennsylvania State Police Department. [ ] 9. THIS ORDER SUPERSEDES [ ] ANY PRIOR PFA ORDER AND [ ] ANY PRIOR ORDER RELATING TO CHILD CUSTODY. [x] 10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL 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 $1,000.00 and/or up to six months in jail. 23 Pa.C.S. ~ 6114. Consent of the Plaintiff's to Defendant's return to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. S6113. Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to Federal Charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. S~ 2261-2262. .1 ,'~I ^,- !iiA'l1Ji:n . . NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the Plaintiff's residence OR any location where a violation of this Order occurs OR where the defendant may be located. If Defendant violates Paragraphs 1 through 6 of this Order, Defendant may be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence oflaw enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriff's office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this Court, unless the weaponls are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. BY THE COURT, J. p~ 01/26/01 FiRI 16:53 FAX 717 240 6573 [ I,~" - ~~ TXlRX NO INCOIlIPLETIl TX/RX - TRANSACTION OK ERROR *************************** u* llIULTI TN REPORT u* **~****$******************* CUMB CO PROTHONOTARY @001 2426 [ 01J9p2405331 [ 04 J 924'90779 CENTRAL PROCESS PSP ^ .OfF1CE OF '!liE PRCYI'HCN1l'AAY aJMBERLAND COONrY COUR'lliOOSE ONE: caJR'I1l{XJSE SQUARE CARLISLE. PA. 17013-3387 (717) 240-6195 FAX (717) 240-6573 ;VIA TELECOPIER . c,~n\-ro-1 PrOc.~11 'ro; WP. FAX~: (717-) - ;)1.(.9 - 01119 ~ ~; CURTIS R. LONG RE: PpA (Jr:d.e..r:s. MESSAGE , .. A- 110, OF PAGES (INCWOIlIlG CCM:~ SHEET) 1his ~ is intm:l!;rl cnl.y fer: tte I.Bil of tte irrlividcl. cr ~ In Wrlch is is ",ll. 'i, a'rllffi\l a:ntain int\:llrmticn ttat is p:ivileg::rl, anfidantial aU ~ frnn di.....l""lre l.I"d'!r "tl"H....nll' J.;w. If ttE ~ of ttrls ~ is rot Ii~ :inleni3::l ......;pi"""lt:. )0-1 am ~ rotifiOO tl:at 1rPf d,issaTdratkn. dist:rituti01 c:r o:witg oc ttris ~..Jcn ill strictly p:d1Jbita:l. If}OJ I\;M! z:a:ei1.6:l ttus ~~,r .eirn in l".OXJ[', oll!EGe rd:ify u;; :imra:l:iately. tv lele{:trre an teWm lie <:rig:in:U 11_ ;g' 10 L$ at ...~' ~ . . , ,.~ - .~"'.\- SHERIFF'S RETURN - REGULAR CASE NO: 2001-00555 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GOSSARD SHERRI VS GOSSARD LARRY KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon GOSSARD LARRY the DEFENDANT , at 0017:25 HOURS, on the 26th day of January ,2001 at 15 PEIPER COURT CARLISLE, PA 17103 by handing to LARRY GOSSARD 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 18.00 3.10 .00 10.00 .00 31.10 S;;;~~~e R. Thomas Kline 01/29/2001 Sworn and Subscribed to before me this /-ar- day of J'~) "'~ I A.D. C 4h-{2 ~PP'-<{~ vothonotary . " J ........... '-^-, ,.. '''-'.'- - ~~, .t- c SHERRY GOSSARD, for herself and on behalf of JAMES GOSSARD, a minor child, and SARAH GOSSARD,: NO. 01-555 CIVIL TERM a minor child IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. IN RE: PROTECTION FROM ABUSE LARRY GOSSARD SHERI GOSSARD IN THE COURT OF COMMON PLEAS OF CUMTERLAND COUNTY, PENNSYLVANIA v. NO. 00-4656 CIVIL TERM LARRY GOSSARD IN DIVORCE ORDER OF COURT AND NOW, February 5, 2001, the parties through their respective counsel have appeared before the Court and entered into the following agreement: The temporary Protection From Abuse Order dated January 26, 2001. is hereby vacated. All weapons confiscated by the Sheriff shall be returned to the defendant immediately. Effective this date, the plaintiff, Sherry Gossard, is hereby granted exclusive possession of 46 North East Street, Carlisle, Pennsylvania. By the Court, James Kayer, Esquire For the Plaintiff Marcus McKnight, Esquire For the Defendant fYla.; led. 9- ~)ce~ -+0 PS P OJ.-O~-(J I ~! 1':1\ r[J .'::}~F\Ct. 0:: . ,';:'{-'c,,"OTi\RY 01 FEB ..5 Pi'l 3: 14 CUMBEfiLK\u COUNTY PENNSYLYI"N1A ';0. , j ..- ,." _flllffl~ " ."- ~." , . "' -~. _V'~. '.' < "~ _".-c~" .."",. ~_ ~.- , "._,~,~ ." ~-'J ." , ,.,,'_ . _l~_M.~~~i)I~-lH~\!l~~lH[.: l Jl!iWm~l!i.~~!!j~1'f(Ir~lW!llfr .~l!l,p,,; ""~.\"" ",~,,"'<-;O 1~"~~ ....-. . : 1 " ~,;,;.~> '"0; 02/06/01 TUB 13:52 FAX 717 240 6573 CUMB CO PROTHONOTARY 141001 *************************** *"* MULTI TN REPORT u* *************************** TXlRX NO INCOMPLETE TX/RX TRA.NSACTION OK 2440 01]9p2405331 0319p2438026 04]92490779 CENTRAL PROCESS LEGAL SERVICES PSP ERROR . OFFICE Of' THE PRCflliOOOTARY aJM8ERLAND CCXINIY OOURWaJSE OOE CCXJRTHOOSE SQUARE CARLISLE, PA. 17013-3387 (717) 240-6195 FAX (717) 240-6573 cf LS TO: PA STATE POLICE V I ATE LEe 0 PIE R FAX ~; 717-249-0779 -) rnCl1: CURTIS R. LONG HE: PFl< ORDERS MESSAGE : , ,:1..L NO. OF PAGES (INCWDING COVER SHEET) 1his ~ is it,ll::! Uo:l a\l.y fur liB IHl of tte in:livitial cr entity ill Wrlch is .is ~ l1. j,.;rd rrert CO'Itdin infi:n:Jmt::irn t:ret is p:ivili:g;d, o::nf:identW a"d ~ fr:on dio;rl..... we ll1k" 'TIJ1,,,*,1" li;w. If t1~ .rretr of this ~ is rot t1'e intJ::rd3'; lECipiart:. 'Pl arB i"er:I't!f mtifiEd tmt CD! clliB'Inimtim. di$triI:utirn OL a:w:in9 of this CllITlUlil:Btkn is strictly p:dribil:Ed. If}OJ tau:: re:Eiva:! ttus ~.3~ in ~:. ~ rot:ity lB ~~y. bt tele;;h:re a"d teb.nn tie aig:irelll~-g> tv L13 al , ',- , 0'_ ,--,' .. '-'~ PFAD Number: PR1389314D SHERI LEIGH DOVE, : In The Court of Common Pleas of for herself, and on behalf of her minor children: JAMES SCOTT GOSSARD, and : CUMBERLAND County, SARAH CATHERINE GOSSARD, Plaintiffs : Pennsylvania v. : Civil Action - Law : No. 01-555 LARRY EUGENE GOSSARD, Defendant : Protection From Abuse PETITION FOR PROTECTION FROM ABUSE 1. Plaintiffs name is: SHERI LEIGH DOVE 2. I, (the Plaintiff), am filing this Petition on behalf of: - myself - and as Parent of minor Plaintiff(s) 3. Name(s) of ALL person(s), including minor children, who seek protection from abuse. a. SHERI LEIGH DOVE b. JAMES SCOTT GOSSARD c. SARAH CATHERINE GOSSARD 4. Plaintiffs Address is : 62 West Ridge Street, Carlisle, P A 17013 5. Defendant's Name is: LARRY EUGENE GOSSARD J.~___ _ _ .'_0_, '""1!<i0 6. Defendant is believed to live at the following address: 46 North East Street, Carlisle, P A 17013 7. Defendant's Social Security Number is: 182-60-6611 8. Defendant's Date QfBirth is: November 8, 1962 9. Defendant's Place of employment is: SCI Camp Hill, Lisburn Road, Camp Hill, PA 17011. Tel.: (717) 737-4531. Work hrs.: 10 p.m.-6 a.m. 10. Defendant is an adult. 11. The relationship between the Plaintiff and the Defendant is: Parents of the same children Ex-Spouse 12. The Plaintiff and the Defendant been involved in the following court actions: a. Divorce b. Support c. Protection From Abuse 13. Other details of the court action are: DOVE v. GOSSARD, In Divorce, Cumberland County, No. 00-4656, Civil, fIled June 29, 2000, final decree entered September 12, 2001. DOVE v. GOSSARD, Protection From Abuse, No. 01-555, Cumberland County, Temporary Protection From Abuse Order entered January 26, 2001, vacated February 5, 2001. DOVE v. GOSSARD, In Support, Cumberland County (DRO and PACSES Nos. unknown). 14. The defendant has been involved in a criminal court action. 15. The defendant is not currently on probation I parole "-' '''' -:.~;--~.,,;,,~"-: "o";"iIIl!la'W' n,_,',,,.i., ~ - ~,- ~~J.,. ""~'~Rldi'~I\!!i_~-~j " ,,',,", '''' ~ -" '~'^'"""" -? ' ",.."." "...'.. .""," -.1 .,~._'-;= '. _" "h " , ~ --' ~= I " - ->.',- *' 16. Plaintiff and Defendant are the parents of the following minor child/ren: a. JAMES SCOTT GOSSARD Age: 12 years old Child's address is: 62 West Ridge Street, Carlisle, PA 17013 b. SARAH CATHERINE GOSSARD Age: 6 years old Child's address is: 62 West Ridge Street, Carlisle, PA 17013 17. 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. JAMES SCOTT GOSSARD For the past 5 years, this child has lived with: Plaintiff and child's sister, Sarah Catherine Gossard, at 62 West Ridge Street, Carlisle, PA, from June 2001, to the present. Plaintiff and Sarah, at 46 North East Street, Carlisle, P A, from June 2000, to June 2001. Plaintiff, Defendant, and Sarah, at 46 North East Street, Carlisle, PA, from 1996, to June 2000. b. SARAH CATHERINE GOSSARD For the past 5 years, this child has lived with: Plaintiff and child's brother, James Scott Gossard, at 62 West Ridge Street, Carlisle, PA, from June 2001, to the present. Plaintiff and James, at 46 North East Street, Carlisle, PA, from June 2000, to June 2001. Plaintiff, Defendant, and James, at 46 North East Street, Carlisle, PA, from 1996, to June 2000. 18. The facts of the most recent incident of abuse are as follows: On about Saturday, December 15, 2001 location: 62 West Ridge Street, Carlisle, PA, Plaintiffs residence. Defendant telephoned Plaintiffs residence, and yelled at the parties' 12-year-old son, James. When Defendant continued to yell, the child hung up the telephone. Within a few minutes, Defendant arrived at Plaintiffs residence, yelled at Plaintiff and James, and threatened Plaintiff saying, "You had better figure out who is going to take care of the kids because I am going to put a bullet in your head, then blow my brains out." Fearing for her life, Plaintiff reported the incident to the Carlisle Police. ~1,"O ,I L~~'" Defendant was arrested, charged with terroristic threats, harassment, and stalking, his firearms/weapons were seized, and he was taken to Cumberland County Prison. The preliminary hearing on the criminal charges was held before District Justice Correal on December 20, 2001, the case was bound over for trial, and Defendant's bail was set at $10,000, unsecured. Conditions of Defendant's bail are that he have no contact with Plaintiff, nor the parties' children pending resolution of custody, Domestic Violence conditions, and that his firearms/weapons remain in the custody of the Carlisle Police Department. Defendant was released from Cumberland County Prison after the hearing. 19. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor child/ren, (including any threats, injuries, or incidents of stalking) are as follows: In or about June 2001, Defendant grabbed James by the arm, pulled him inside his house, and threatened the boy saying, "I'll show you I'm your father; I'm going to beat your ass." On or about January 15, 2001, Defendant came to Plaintiffs residence unannounced and uninvited, argued with her, threatened that he would enter her residence whenever he pleased, and told Plaintiff that he had entered her home on at least one occasion by forcing open the basement door. Fearing for her safety, Plaintiff contacted a lawyer, and on January 26, 2001, filed a Petition for Protection From Abuse and a Temporary Protection From Abuse Order was entered to the above docket number. From approximately July 2000, to January 2001, Defendant came to Plaintiffs residence an average of 2-3 times a month, unannounced and uninvited, in an angry mood, and yelled at her and the parties' son, James, and harassed them. In addition, during this time period, Defendant drove by Plaintiffs residence several times a week to ascertain her whereabouts, and told her that he did so; told her that he had followed her in the car, and telephoned her several times a week at her residence, and also called her at her work and harassed her. In or about late June 2000, when Plaintiff asked Defendant to leave the marital home, he threatened that the police would have to take him out in a body bag. In or about mid-June 2000, Defendant yelled at Plaintiff, and in the presence ofthe parties' children, threatened to kill himself using his gun to blow his brains out. In or about June 2000, Defendant yelled at Plaintiff, pushed the door closed against her hand, and grabbed her by the neck and pinned her against the side of the house. Plaintiff sllstained soreness, swelling, and bruising about her hand and finger, and soreness about her neck as a result ofthis incident. Plaintiffs finger was painful and she was unable to use it for several months after the incident. In or about fall 1999, Defendant argued with Plaintiff, pulled shelves off the wall, threw cans of paint and other household items about the room and against the wall, picked her up as she stood on the stairs, and dropped her, causing her to fall down several stairs. Plaintiff sustained bruising, swelling, and soreness about her ankle as a result of this incident, and her ability to walk was impaired for several days after the incident. From approximately 1997, to 2000, Defendant abused James in ways including, but not limited to, yelling at him, and slapping him about his head several times a week. In 2000, James began seeing a . ' I. , --.;';, ~,'" therapist dueto his aggressive behavior in school. During an incident in 1999-2000, Defendant repeatedly struck James on the soles of his feet with a baseball bat, causing soreness and bruising about his feet. The incident was reported to Cumberland County Children & Youth Services. After the investigation" CYS determined that the case was unfounded, but recommended that Defendant seek counseling for his violent behavior. During an incident in 1997, when James was 7 years old, he tilted his chair back on two legs, and Defendant kicked the chair out from under him, causing the boy to fall to the floor and hit his head against the concrete wall. James sustained a gash on the back of his head as result of this incident. 20. The Defendant has used, or threatened to use, the following weapon(s) against the Plaintiff or the minor child/ren: a. any and all firearms/weapons, including, but not limited to: handguns, b. rifles, c. shotguns, d. bows and arrows. 21. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: CARLISLE POLICE DEPARTMENT DAUPHIN COUNTY DISPATCH HARRISBURG POLICE DEPARTMENT 22. There is an immediate and present danger of further abuse from the Defendant. 23. Plaintiff has suffered out-of-pocket financial losses as a result of the abuse described above. Those losses are: Lost wages. 24. 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. Evict/exclude Defendant from Plaintiffs residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff. c. Award Plaintiff temporary custody of the minor child/ren and place the following restrictions on contact between Defendant and child/ren: Pending further Order after the hearing scheduled in this matter, Defendant shall have no contact with the parties' two minor children, James Scott Gossard, and Sarah Catherine Gossard. lfl]iilfl! "l-L < '-> !IY':jj~~i.u:ct't.-Ju~ '--jd~~~!i~.liM~~~f~;'- . ,~" ~~~"' " "~ ,~.~~ '-~ ",.. ~ -- - ,.. "al "---11- Ii" -~~i'>" ",,,. '-',-.'-,..-.-., "->-..--- ..:' "" "' """"'. , 1 J c,'. I " - "~ ..-"",',-" ~ ~'\-J d. 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 find necessary with respect to partial custody and/or visitation with the minor child/ren. e. 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. f. 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. g. Direct Defendant to pay Plaintiff for the reasonable financial losses suffered as the result of the abuse, to be determined at the hearing. h. Order Defendant to pay the costs of this action, including filing and service fees. I. Order the following additionaL relief, not listed,above: Order Defendant to refrain from harassing PIaintifrs relatives. Enjoin Defendant from damaging or destroying any property owned solely by Plaintiff. Order Defendant to enroll in the Choices program for batterers at Tressler Lutheran Services in Mechanicsburg or through Mosaic Counseling Services in Harrisburg, successfully complete the 26-week program, and follow and complete any recommendations for treatment made by the program staff. Defendant shall be responsible for the payment of all costs related to enrolling and attending the program and for any costs for additional treatment recommended by staff. J. Grant such other relief as the court deems appropriate. k. 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. ' Agency: ~r.~ David A. L ez Joan Carey Philip C. Briganti Attorneys for Plaintiff MidPenn Legal Services Respectfully Submitted by: '" '"z-~ ~ ',;;rei VERIFICA nON 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.g4904, relating to unsworn falsification to authorities. Dated: lr/;;;u;6; I I ~j~ "-d' "-"jilf\.". '~""'~j_mf.ilii:~ ,.,- -;, '.k"-iIl'iI:~{~1\B' .<,;~. _"';~~"=rl ;" 't~~lWi~ -~~ --;. -.-- 'h ,.. . "-,,,~ -. '^!'. ,~ " --~-, -~ f ",,",-,,,,"':' iii( =- III .,J , ~ ~ :i: 0 0 0 ~ -n ""- a .-~ ""0 OJ rT1 r;~ ;TI mrn c., z::n '" ~.o\3 ZS;: -.0 . (lJ,/" ~~6 ~C5 ""0 H.CI' ,.)::D ~~' :x ~o , 0 ;;;:;C:l .'.~m ,.,.c 'f? ~ Z, tA' ?o. =< Ul -< ~ ~ ~-~ , Ji.('i>iw;.,'dl:.i.,;' ~I"', - i ".: _-<;'c SHERI LEIGH DOVE, : In The Court of Common Pleas of for herself, and on behalf of her minor children: JAMES SCOTT GOSSARD, and : CUMBERLAND County, SARAH CATHERINE GOSSARD, Plaintiffs : Pennsylvania v. : Civil Action - Law : No. 01-555 LARRY EUGENE GOSSARD, Defendant : Protection From Abuse TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: LARRY EUGENE GOSSARD Defendant's Date of Birth is: November 8, 1962 Defendant's Social Security Number is: 182-60-6611 Name(s) of All protected persons, including Plaintiff and minor children: 1. SHERI LEIGH DOVE 2. JAMES SCOTT GOSSARD 3. SARAH CATHERINE GOSSARD AND NOW, on 21st Day of December, 2001 upon consideration ofthe attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: Plaintiffs request for a temporary protection order is granted. 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. - , - ,,' ~""'"~-"\. '. ~' 2. 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 Plaintiffs school, business, or place of employment. Defendant is specifically ordered to stay away from the following locations for the duration of this order. Plaintiff's current residence listed below and any other location where she may reside during the term of this Order. 62 West Ridge Street Carlisle, P A Plaintiff's place of employment: Pennsylvania Department of Agriculture 2301 North Cameron Street Harrisburg, Dauphin County, PA The schools ofthe parties' minor children The child care facility of the parties' 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 of the final hearing in this matter, Plaintiff is awarded temporary custody of the following minor child/ren: 1. JAMES SCOTT GOSSARD 2. SARAH CATHERINE GOSSARD 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 this matter, Defendant shall have no contact with the parties' two minor children, James Scott Gossard, and Sarah Catherine Gossard. 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 ofthe Plaintiff in accordance with the terms ofthis Order. ~-~, - ...:......,1 ,'" . , 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 Sheriffs Office. I. any and all firearms/weapons, including, but not limited to: handguns, 2. rifles, 3. shotguns, 4. bows and arrows. 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 Plaintiffs relatives. Defendant is ordered to refrain from harassing Plaintiffs relatives. 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: CARLISLE POLICE DEPARTMENT DAUPHIN COUNTY DISPATCH HARRISBURG POLICE DEPARTMENT 8. The sheriff, police or other law enforcement agencies are directed to serve the Defendant with a copy ofthe 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 SUPERSEDES ANY PRIOR PFA ORDER ANY PRIOR ORDER RELATING TO CHILD CUSTODY '"; .~. ,c~~. _ ~ ,-, " ,_, ~ '_> ,l 'J ,~':< -, @,~ \ 10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL JUNE 21, 2003 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. S6114. Consent of the Plaintiffto Defendant's return to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. 96113. Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under the Peunsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. SS2261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiff'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 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 of law enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation ofthis Order OR during prior incidents 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 ofthis court, unless the weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. Judge ....,- -.-.. .- Distribution to: David A. Lopez Joan Carey Philip C. Briganti 1-" '/-;- -"'''' ..<~,. '~-~" SHERI LEIGH DOVE, For herself and on behalf of her minor children: JAMES SCOTT GOSSARD, and SARAH CATHERINE GOSSARD, Plaintiffs Vs. LARRY EUGENE GOSSARD, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-555 CIVIL ACTION : 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 TJJ ~y of December, 2001, at .J.. ',~ m., in Courtroom No.3 of the Cumberland County Courthouse, 1 Courthouse Square, CJIisle, Pennsylvania. You MUST obey the Order that is attached until it is modified or terminated by the court afternotice and hearing. If you disobey this Order, the police may arrest you. Violation ofthis 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. 96114. Violation may also subject you to prosecution and criminal penalties under the Peunsylvania Crimes Code. Under federal law, 18 U.S.C. S2265, 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. S 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 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 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. ,,"'-<");l.:ttl\1b;~lf r~ " _ ~~l>lWk:li~J#~~bg'":<-j""It"""" klUUJii'~"tiit-'l~!M~.~",if~,~~?,'ffii~. -,','-' ." ,., ,."._" .II-'~-- 'j riP'-l' ~ ~"""'I '-'''_0 _II. VlNV/ilASNN3d JJ.NnOo OM1l1:J381f\1(l:) 6 ry :8 Wd I Z 330 10 I U\.IICN'O' " "" , -"H -"" ^ClV.l . 'I H1J.,.h;:,J '::iLL :JV' 301:1::10-0311:1 ~ , ~""',~-,~ : ,~ -." -;" '-----......;',~," ~)~, 12/"2!101 . FRI 16: 39 FAX 717 240 6573 CUMB GO PROTHONOTARY 141001 *$$$****$$*****$*$*$*$*$**$ **$ MULTI TN REPORT $*$ *$$*********$*$*********$** TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2913 01]9p2490779 03]9p2405331 04]92438026 PSP CP LS ERROR . . OFFICE OF TIlE PROUiCN:1rARY CUMBERLANO co:JNrY CXXJR'IHaJSE ONE caJR'IHaJSE SQUARE CARLISLE. PA. 17013-3387 (717) 240-6195 FAX (717) 240-6573 V I ATE L E COP I E R TO: PA STATE POLICE w Cellf, f'1P,e.t:S~.. M, Po t...S . FAX ": 717-249-0779 FRCM ~ CURTIS R. LONG RE: PFA ORDERS MF.SSAGE: ; ~ 00. OF PAGES (INCLUDING (DYER SHEET) This.. ,,- is illbaLW mly Iir liE lEe c:4: liE irdividal <r 81til;y to Wl:idl is is alh. I, .;rd I1Crt a:ntain inftJoTatim tmt is Iriv.i.le.Jrl. anficHltial cn:1 acmp: frcm d,.....I,.". n:e II'(}&- i{:pH.-.MIF! Ja./. ff tlE m..~ at It1is ~ is rot liE inl;e'O;(! ~. }OJ are ~ rotifiEd ttat I;'nf dis'.;Em:ira1:kn. di$trib.It:iat ac <XP.firg of this COI1lU'Iicatlo'J is strictly prltibi.ta:l. If \O.l I'eI.e re:ei.1.<<I LItiS a:ImUlic.3ticn in =. p1.eBae ratify lS inmrliatBly l:y tele!;h:re <rcl Ieturn lie o:igjnll..c "'T to I.S at L.L._ ..L..-. .. ...:_ L.I.__ ",... .___' _, __. - .' ..~ 1-. <2'"">_ -.-','-'. ~""-' >- 1 Sherry Leigh Dove, For herself and on behalf of Her minor children: James Scott Gossard and Sarah Gossard,Plaintiffs Vs. Larry Gossard, Defendant : IN THE COURT OF COMMON PLEASE OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 51 J.;H CIVIL TERM OhS-S\S : PROTECTION FROM ABUSE : AND CUSTODY MOTION FOR CONTINUANCE The Plaintiff, Sherry Leigh Dove, by and through her attorney, David Lopez of MidPenn Legal Services, moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. A Temporary Protection From Abuse Order was issued by this Court of December 21, 2001, scheduling a hearing for December 26, 2001, at 2:00 p.m. 2. The Cumberland County Sheriffs Department served Defendant with the Temporary Protection Order. 3. The Defendant is being represented by Marcus McKnight, Attorney, who has contacted MidPeun Legal Services, and the parties are in the process of negotiating a settlement. 4. The parties request that a continuance be entered in the above-captioned case to afford the parties time to negotiate a Consent Agreement. 5. 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 ~ ;,- I.. '-j.. . ~, ~ --" remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. Respectfully submitted, 'avid Lopez Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 ',--- ~'~li/:"li1J~i!t1ffi!~~"~\('lI~'IDi:Ii~~~i40~~"'" "-"'- y,--=- , ^ 0- , ~","",~ ..'''''" _' '_~""'"', ,~, ~-< ~~ "<.-. ~ .~~.~ ".,~ --wiUii i '~ '. -'.' ~ ~ 0 C ~;~ ~ :::~~ a --on.... ,.q c, mrT; (-:> Z:::C' f'-"'" z~, -.,j <fJ.~--,: -J . .=<: 4'':- ~~.~C) r:;o :r:: ~ii r~ ~o ..... =0 'P. C) ):>c: --1 ~ 0 '"b jJ to -< 11 1i5lJ.i-<- "J . n' ,-~---~. "'- '., 1"",-'_,,,-'1:.' ~. - L;,. Sherry Leigh Dove, For herself and on behalf of Her minor children: James Scott Gossard and Sarah Gossard, Plaintiffs Vs. Larry Gossard, Defendant : IN THE COURT OF COMMON PLEASE OF : CUMBERLAND COUNTY, PENNSYL VANIA : NO. Bl 6529 CIVIL TERM Ol-SSS : PROTECTION FROM ABUSE : AND CUSTODY ORDE~FOR CONTINUANCE AND NOW, thiS~ day of December, 2001, upon consideration ofthe attached Motion for Continuance, the matter scheduled for hearing on December 26, 2001, at 2:00 p.m., is hereby rescheduled for hearing on ~/J1p(.if r ~ ,at '$< 3o;?JIm. inCourtroomNo.".3 . I The Temporary Protection From Abuse Order shall remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. By the Court, David Lopez - &;I.~' -t!lzuit MidPenn Legal Services ~ Attorney for Plaintiff Marcus McKnight - VIII;%;,: ~ /1~7 /t?/ Irwin, McKnight & Hugh~s VOCk Attorney for Defendant . :-~"~'" ~ "~~,o __~~ __"" '.~,"'__' '~O""~~,--"._-"",,,,~-. ~<. _~~._~~__.'_."S" Of: ;:!lJJ) {):~FiCE , ~'T! !n~!nl'I"Rv -', -\-.,) """i t'.. I 01 OfC27 P~l 2:45 CUMBEHLAND COUNiY PeNNSYLVANIA ,..- IIill-Hl_ ,,1!I!.I..)lIm 1" _nt"L ,)~'~_~~~~ilfl\'jr,w:;.~~\lI!Hll.~~~~~t.lIR~J:,>_~, "_~._",.,."_,_~,,,; ~",,'_' - -,,~~- .0 > ~r " ~'l , ' """"~~1[L , SHERIFF'S RETURN - REGULAR CASE NO: 2001-00555 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND GOSSARD SHERRI VS GOSSARD LARRY JASON VIORAL , Sheriff or Deputy Sheriff of Cumberland County,pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon GOSSARD LARRY the DEFENDANT , at 2018:00 HOURS, on the 21st day of December, 2001 at 46 NORTH EAST STREET CARLISLE, PA 17103 by handing to LARRY GOSSARD a true and attested copy of PROTECTION FROM ABUSE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.25 .00 10.00 .00 31.25 So Answers: r~~~ R. Thomas Kline Sworn and Subscribed to before 12/27/2001 LEGAL SERVICES By: 6 ~y Sheriff me this ,}~ day of 9-U"Q ~~"" AD MV(2~.~ r~thonotary ~~,~ e '~ ,,'.- '. " 'L Sherry Leigh Dove, For herself and on behalf of Her minor children: James Scott Gossard and Sarah Gossard, Plaintiffs Vs. Larry Gossard, Defendant : IN THE COURT OF COMMON PLEASE OF : CUMBERLAND COUNTY, PENNSYLVANIA SS'S : NO. 01-~ CIVIL TERM : PROTECTION FROM ABUSE : AND CUSTODY MOTION FOR CONTINUANCE The Plaintiff, Sherry Leigh Dove, by and through her attorney, David Lopez of MidPenn Legal Services, moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. A Temporary Protection From Abuse Order was issued by this Court of December 21, 2001, scheduling a hearing for December 26,2001, at 2:00 p.m. 2. The Cumberland County Sheriff's Department served Defendant with the Temporary Protection Order. 3. The Defendant is being represented by Marcus McKnight, Attorney, who has contacted MidPeun Legal Services, and the parties are in the process of negotiating a settlement. 4. The parties request that a continuance be granted in the above-captioned case to afford the parties time to execute a Consent Agreement. 5. 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 PoRI I ~ .-- ,-~< '~ .. -~ >,-,;: / remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. Respectfully submitted, a . Lopez Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 lti ,.,. - <{ i,. . ,JD1'i\l"lY ~ {j 02.JM1-9 f'ij 4:20 CUMb:':11Lh,\1CJ COUNTY PENNS\lVANiA I ~ l ~ ~ J]; i I I I ! ;w ........ .,," '''< ,,- -~, ~ " ,,,,,,'-,<>-,,,,,,,-,):- "c_ Sherry Leigh Dove, For herself and on behalf of Her minor children: James Scott Gossard and Sarah Gossard, Plaintiffs Vs. Larry Gossard, Defendant : IN THE COURT OF COMMON PLEASE OF : CUMBERLAND COUNTY, PENNSYLVANIA US : NO. 01-~ CIVIL TERM : PROTECTION FROM ABUSE : AND CUSTODY ORDE~OR CONTINUANCE AND NOW, this U day of January, 2002, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on January 9, 2002, at 3:30 p.m., is hereby rescheduled for hearing on February 11, 2002, at 9:30 a.m., in Courtroom No.1. The Temporary Protection From Abuse Order shall remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. By the Court, David Lopez MidPenn Legal Services Attorney for Plaintiff Marcus McKnight Irwin, McKnight & Hughes Attorney for Defendant ~ ~ /.II-O~ 9-- , ~ _ "",~J r~ ~' <--,~, ~-~"' .'.. - ,,~' , .~',. ""'~.., ,,'I ""'y,~: .1,:'''I~",I!JT.,~\Ji.V ". .". . 0') I r 1\ I IJ P'I'I ',: r.; 0 if.. ...., ,~1,,1 'I l' .. 'J" , "";;;'~' nnil'l"TY CU~'/li.:.J":'I'.Lh,\l.J \.,).,..,"" 'l1 P""IN",VII/^NII..\. Cl'i ....'!k r\! 1,/ ~<n ,'~ ~'~'~n. . ,~~. , ",,~Jlt,r, II': !JIl!r1j,~,~~,r~J~l'! 'l""',;t;,,~,,~I!!~",,"1"'~~,'J.'~,*,~~~~~~~~ l,,~J~.~;i - " I,,' ~ ,-,"" _~"""",,I,= ".' ., ",' ,',. .' ~.', . ., ,-,,",.\ "'->-_-,0'.,_,,,;'"..,.,""-;;'-,,0"";"'"- . . " t SHERI LEIGH DOVE, : In The Court of Common Pleas of for herself, and on behalf of her minor children: JAMES SCOTT GOSSARD, and : CUMBERLAND County, SARAH CATHERINE GOSSARD, Plaintiffs : Pennsylvania v. : Civil Action - Law : No. 01-555 LARRY EUGENE GOSSARD, Defendant : Protection From Abuse : No. 01-555 FINAL ORDER OF COURT Defendant's Name is: LARRY EUGENE GOSSARD Defendant's Date of Birth is: November 8, 1962 Defendant's Social Security Number is: 182-60-6611 Name(s) of All protected persons, including Plaintiff and minor children: 1. SHERI LEIGH DOVE 2. JAMES SCOTT GOSSARD 3. SARAH CATHERINE GOSSARD \ . AND NOW, th~ th Day of February, 2002 the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows: Pursuant to consent of the parties, which does not constitute Defendant's admission to the averments of abuse in the petition, the following order will be entered: Plaintiff, Sheri Leigh Dove, is represented by Joan Carey of MidPeun Legal Services; Defendant, Larry Eugene Gossard, is represented by Marcus A. McKnight, III of Irwin McKnight & Hughes Plaintiff's request for a final protection order is granted. :I . "', +.,,,, ,,~." 'J' +;- , ../ . '-r") \ '<. C~j 'f' ;; Ii: /< '--'-' \1"\:''1/,..""--,, .IV/v.'i-""""> __ b..!:::;~ilj";;\-J /'\"-" 'c:iVNSVi 1/.~'UUN7\, 'lviW!A II ~;!lr_ _.=~= " 11 J.~lR"", . ,," lI.,t1 I' ,-Cbt ~;~IijjI;Jil!1~iW'k;I~""",";~c~,~,,!It '. ",,,-,';'~,,~'''' ,'eJ_"';."",_"" "TIltHi-""i'd'^"'~'d" .~_ , ~,~~IfjIi~_!@,~T", WB,IIT!'W~' ~ ,~ ',I -,', ,';'q'"u--- ~ _ '^ ",','""" '~,. __"'_ ,. "',M ,__ ~"',"_ .," , ' ~ 'j': , , 1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other protected person in any place where they might be found. 2. Defendant is completely evicted and excluded from the residence at: 62 West Ridge Street, Carlisle, P A, except for the purpose of facilitating visitation, at which time Defendant shall wait outside the residence, or any other residence where Plaintiff or any other person protected under this Order may live. Exclusive possession of the residence is granted to Plaintiff. Defendant shall have no right or privilege to enter or be present on the premises of Plaintiff or any other person protected under this Order. 3. Except as provided in Paragraph 5 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 Plaintiff's school, business, or place of employement. Defendant is specifically ordered to stay away from the following locations for the duration ofthis order. Plaintifrs place of employment: Pennsylvania Department of Agriculture 2301 North Cameron Street Harrisburg, Dauphin County, P A The schools ofthe parties' minor children Contact between Plaiutiff and Defeudant and minor children regarding visitation/custody arrangements pursuant to an Order after conciliation, shall not be deemed a violation ofthis Order. 4. Except as provided in Paragraph 5 of this Order, Defendant shall not contact the Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 5. Custody of the following minor children: 1. JAMES SCOTT GOSSARD 2. SARAH CATHERINE GOSSARD shall be as follows: " ",.- ". , ; . Primary physical custody of the minor childlren is awarded to the Plaintiff. . Defendant's rights to visitation/custody shall be determined upon further Order after conciliation. 6. Defendant shall immediately turn over to the Sheriff's Office, or to a local law enforcement agency for delivery to the Sheriff's Office, any firearms license the Defendant may possess, and the following weapons used or threatened to be used by Defendant in an act of abuse against Plaintiff and/or the minor children. 1. any and all firearms/weapons, including, but not limited to: handguns, 2. rifles, 3. shotguns, 4. bows and arrows. 7. Defendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration of this order. Any weapons and/or firearms license delivered to the sheriff pursuant to this order or the Temporary Order shall not be returned until further order of the court. Defendant may possess firearms in conjunction with his employment where they are kept at work and not in Defendant's home. Such work related possession of firearms shall not be deemed a violation of this Order. Defendant may, upon the expiration of this Order, request that the sheriff return any firearms and/or weapons held pursuant to this Order. The sheriff shall determine if Defendant is otherwise legally entitled to possess the firearms and/or weapons. If the Protection From Abuse Order has expired and Defendant is legally entitled to possess firearms and/or weapons, the sheriff shall present an Order to the Court authorizing that the firearms and/or weapons be returned to Defendant. Otherwise, the sheriff shall notify Defendant that he/she must file a petition with the Court seeking a return of the firearms and/or weapons, in which case the Court, upon petition, will schedule a hearing with notice to Plaintiff. 8. The following additional relief is granted as authorized by S6108 of the Act: Defendant is prohibited from having any contact with Plaintiff's relatives. Defendant is ordered to refrain from harassing Plaintiff's relatives. Defendant is enjoined from damaging or destroying any property owned solely by Plaintiff. , """, ,,--, ~ ' ~ ;"-"",.- , ,; i; j. , ~' ~ ~ <,. ~, ',c."- ~", f _~, ~ -"c'.' CO" . ., - , .C'" .. - <,_. ' ""<u - "'''_.",. --:+ , -' Defendant shall complete at least six months of anger management counseling with his therapist, Dr. Rodney Benner of Mazzitti & Sullivan Counseling Services, unless the counseling is ended by recommendation ofthe counselor. Defendant shall follow any recommendations that the counselor makes. Plaintiff may verify with Dr. Benner or his office that Defendant has successfully completed his counseling. , The court costs and fees are waived. 9. 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 DAUPHIN COUNTY DISPATCH HARRISBURG CAPITOL POLICE 10. THIS ORDER SUPERSEDES: 1. ANY PRIOR PF A ORDER 2. ANY PRIOR ORDER RELATING TO CHILD CUSTODY 11. All provisions of this order shall expire on: December 31,2002 NOTICE TO TBE DEFENDANT VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 P A.C.S. S6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENAL TIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. S2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C SS2261- 2262. IF THE BRADY INDICATOR PARAGRAPH APPEARS IN THE ORDER, YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES , _ _~ k ---~ " ' ".,- " "'. "1 ''''''''" '.' ,'" "-'-;--2.,;,, ,~~ 4, UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT, 18 U.S.C. g922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION. NOTICE TO LAW ENFORCEMENT OFFICIALS The police who have jurisdiction over the plaintiff's 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 7 ofthis 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. S6113. 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 Cumberland County Sheriff shall maintain possession of the weapons until further order of this 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. Plaintiff's 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. sident --ie - '-" Sheri Leigh ' ve, Plaintiff , ~~/ Attorney for Plaintiff MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 & HUGHES Distribution to: MidPenn Legal Services Marcus McKnight, Attorney for Defendant ) Faxed 81- Mailed to PSP I CoP L5 07..-ll-OJ... 'RYf ~""Ii=""" - " L._ ~ '- ~ mil -~~~ 02/12/02 TUE 09:35 FAX 717 240 6573 CUMB CO <PRO'rHONOTARY 19]001 *************************** ... MULTI TN REPORT ... *************************** TXlRX NO INCOMPLETE TX/RX TRANSACTION OK 2971 ERROR [ 01]9p2490779 [ 03j9p2405331 [ 04192438026 PSP CP LS ~ Of'l'ICE OF THE PROI'HQIIOTARY CUMSERLANO CXXJNT'{ CDURWOOSE ONE COOR'rnOOSE SQUARE ~LISLE, PA. 17013-3367 (717) 240-6195 FAX (717) 240-6573 v rAT E LEe 0 PIE R 1'0: PA STATE POLICE ~ Cc:"t. Plla te.s.J. .. FAX N; 717-249-0779 l'RCM ; CURTIS R. LONG RE: PFA ORDERS MESSAGE : --'.t!~ NO. OF PAGES (INCWDING rovER SHEET) 'Itris ~ is intEnHl c:nly fir tte lEe of t.m irdiv:iriHl cr artity to W1id1 is is all"" : I, a"rlllll'/ antain ir1fi::mHtio"t ttHt is ~, cmf:id;nt:ial ad e<B1{1: nun t'li""'l......rre 1.I:1Er 't:Pli.-.f11p liW. If tiE .r;e;rR at !his ~ is rot tle intE'ftb:i nripimt. }QI are ~ rot.i.f.ie1 lt1at a:II ~ticn. distriJ:.ut:irn IX awinJ cr this rnun.nin;ttJai it;; st:dct:ly p:ctrlhilB:I. Xf}U1 rn..e :r:e:2.i."w tJ'us a::mnnir:.~t:im in emr, ~ rr:tify LG :irmB:l.ial2ly ty tEleJ;hnl ad l:ebJm tie ar:ig:in;ll " "'J' to 1.S at :,~~L,_ ""'~_'"_"N ~~ ~ ~I J, J _ _"~ ,,-, ... ~ . ~-.;:--i i i Sheri Leigh Dove, for herself, and on behalf of her minor children:James Scott Gossard and Sarah Catherine Gossard, Plantiff's V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA 555 Civil 2001 Larry Eugene Gossard Defendant ITEMS: Whitetail Bear Bow 25 Arrows & Quiver w/22 Arrows ~ ORDER AND NOW, this~ Day of ~ . t ~~~ ~OIlOWing Order is entered: The protection from abuse order in the above-captioned case having expired on December 31, 2002, and the defendant having requested the return of the weapons/firearms held pursuant to the order, and the defendant otherwise being legally entitled to possess the weapons/firearms, IT IS ORDERED that all weapons/firearms held by the sheriff shall be returned to the defendant. By the Court, CC: R. Thomas Kline, Sheriff Cumberland County Sheriff's Office