HomeMy WebLinkAbout01-0623 FX
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NATALIEA. TAYLOR,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 0/ -C;.2.3 CIVIL TERM
WILLIAM S. TAYLOR,
Defendant
PROTECTION FROM ABUSE
AND CUSTODY
NOTICE
You have been sued in court. If you wish to defend against the claims set forth in the
following pages, you must take action promptly after this Petition, Order and Notice are served,
by appearing personally or by attorney at the hearing scheduled by the Court and presenting to
the Court your defenses or objections to the claims set forth against you. You are warned that if
you fail to do so the Court may proceed without you, and a judgment may be entered against you
by the Court without further notice for any money claimed in the Petition or for any other claim
or relief requested by the plaintiff. You may lose money or property or other rights important to
you. Any Protection Order granted by a Court may be considered in any subsequent
domestic relations proceedings, including custody actions.
FEES AND COSTS
If the case goes to hearing and the judge grants a Protection Order, a surcharge of $25.00 will
be assessed against you. You may also be required to pay attorney's fees.
You have the right to be represented by counsel. You should take this paper to your
lawyer at once. 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.
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.
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NATALIE A. TAYLOR,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
NO. Of, (,J,3
CIVIL TERM
WILLIAM S. TAYLOR,
Defendant
PROTECTION FROM ABUSE
AND CUSTODY
PETITION FOR PROTECTION ORDER
AND CUSTODY
RELIEF UNDER THE PROTECTION FROM ABUSE
ACT, 23 Pa.C.S. 9 6101 et seq.
A. ABUSE
1. The plaintiff, Natalie A. Taylor, is an adult individual residing at 63 North 31"
Street, Camp Hill, Cumberland County, Pennsylvania.
2. The defendant, William S. Taylor, date of birth not known, whose social security
number is 194-52-1745, is an adult individual residing at 63 North 31" Street, Camp Hill,
Cumberland County, Pennsylvania.
3. The defendant is the plaintiff's husband and father of the parties minor children,
Katie Taylor, born September 14, 1990, Eden Taylor, born November 18, 1991, and Brooke
Taylor, born June 2,1996.
4. Since the beginning of the relationship, the defendant has attempted to cause and
has intentionally, knowingly, or recklessly caused bodily injury/serious bodily harm to the
plaintiff, has placed the plaintiff in reasonable fear of imminent serious bodily injury, and has
knowingly engaged in a course of conduct or repeatedly committed acts toward the plaintiff
which have placed the plaintiff in reasonable fear of bodily injury. This has included, but is not
limited to, the following specific instances of abuse:
a. On or about January 19,2001 at approximately 2:30AM the
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defendant, who was drunk at the time, arrived home to find the
plaintiff asleep in bed with the two older daughters. When the
defendant entered the room, he began yelling at the plaintiff. A
verbal argument ensued. The plaintiff went downstairs to get the
youngest child, Brooke, and put Brooke to bed, when the defendant
grabbed the plaintiff and began pushing, screaming and spitting in
her face. The plaintiff slapped the defendant in the face to get his
attention and to stop the abusive screaming. The defendant
temporarily relented and the plaintiff retreated to the second floor
where the two older children remained. The defendant resumed
yelling and following the plaintiff. The defendant cornered the
plaintiff near the second floor bedroom and began pushing the
plaintiff at which point the plaintiff kicked the defendant in the leg
and broke free from the defendant. The defendant then hit the
plaintiff across the side of her head nearly causing the plaintiff to
lose consciousness. In response to the defendant's drunken rage
the plaintiff threw a beer can at the defendant.
b. On or about December 24, 2000 the defendant argued with
the plaintiff and threw a pair of scissors, pointed part first, at the
plaintiff, placing the plaintiff in fear of her safety and creating a
hostile environment.
c. During the Fall of 2000 the defendant continued to verbally
abuse the plaintiff and placed her in fear of her safety.
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d. On or about October 2000 the defendant pushed the
plaintiff, causing injury, and placing the plaintiff in fear of abuse.
e. On or about September 15,2000 the defendant grabbed the
plaintiff by the arm, shoved her into a wall, and spit at her, causing
pain and placing the plaintiff in fear for her safety.
f. On or about September 9, 2000 the Defendant confronted
the plaintiff at KoKoMo's when he proceeded to argue with the
plaintiff and pushed her into her car, causing the plaintiff to fear
for her safety.
g. In December 1998 the defendant accused the plaintiff of
having an affair. The defendant armed himself with a shotgun and
began searching for the "fictional boyfriend" of the plaintiff. The
plaintiff was not present when the defendant armed himself, but,
feared for her safety as a result of his actions.
5. The plaintiff believes and therefore avers that she and the minor children are in
immediate and present danger of abuse from the defendant should they remain in the home
without the defendant's exclusion and that they are in need of protection from such abuse.
6. The plaintiff desires that the defendant be prohibited from having any direct or
indirect contact with the plaintiff or the minor children including, but not limited to, telephone
and written communications, except for the limited purpose offacilitating custody arrangements.
7. The plaintiff desires that the defendant be enjoined from harassing and stalking
the plaintiff, and from harassing the plaintiff's relatives, or the minor children.
8. The plaintiff desires that the defendant be restrained from entering her place of
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employment/business or the school(s) and day care facility/facilities of the minor children.
9. The plaintiff desires that the defendant be enjoined from damaging or destroying
any property owned jointly by the parties or owned solely by the plaintiff.
10. The plaintiff desires that any weapons the defendant owns, possesses, and has
used or threatened to use against the plaintiff and/or the minor children be confiscated by the
Sheriffs Department.
B. EXCLUSIVE POSSESSION
II. The plaintiff currently has no place to stay with her children except the marital
home, and the defendant has family and friends in the area with whom he can stay.
12. The plaintiff desires possession of the home to give the greatest degree of
continuity to the lives of the children and to allow them to continue their education at their
schools and to continue their school and social activities.
C. SUPPORT
13. The defendant has a duty to support the plaintiff and the minor children.
14. The plaintiff is in need of financial support from the defendant including, but not
limited to: health insurance coverage, payment of unreimbursed medical expenses for the
plaintiff and the children, the rent/mortgage payment on the residence at 63 North 31" Street,
Camp Hill, Cumberland County, Pennsylvania.
15. The defendant is employed with the Legislative Management Committee, and has
armual salary of approximately $33,000.00.
16. The plaintiffs income is insufficient to provide for her minimal needs and those
of the children until such time as a support order can be obtained by filing at the Domestic
Relations Office.
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17. The plaintiff intends to petition for support within two weeks of the issuance of a
protective order.
D. TEMPORARY CUSTODY
18. The plaintiff seeks temporary custody ofthe following children: Katie Taylor,
born September 14, 1990; Eden Taylor, born November 18, 1991; and Brooke Taylor, born June
2, 1996, now residing at 63 North 31" Street, Camp Hill, Cumberland County, Pennsylvania,
19. The children were born during wedlock.
20. The children are presently in the custody of the plaintiff, Natalie A. Taylor, who
resides at 63 North 31 ,t Street, Camp Hill, Cumberland County, Pennsylvania.
21. The relationship of plaintiff to the children is that of natural mother.
22. The relationship of defendant to the children is that of natural father.
23 . Plaintiff has not participated as a party or witness, or in another capacity, in other
litigation concerning the custody of the child in this or another court.
24. Plaintiff has no information of a custody proceeding concerning the child pending
in a court of this Commonwealth.
25. Plaintiff does not know of a person not a party to the proceedings who has
physical custody of the child or claims to have custody or visitation rights with respect to the
child.
26. The plaintiff/mother seeks primary custody for the following reasons:
a. The plaintiff is a responsible parent who can best take care of the
minor children and has provided for the emotional and physical needs of the
children since their births.
b. The defendant has shown by his abuse of the plaintiff that he is not
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an appropriate role model for the minor children.
c. The defendant's behavior has adversely affected the children.
27. Each parent whose parental rights to the child have not been terminated and the
person who has physical custody of the child have been named as parties to this action.
WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of
October 7, 1976,23 Pa.C.S. S 6101 et seq., as amended, the plaintiff prays this Honorable Court
to grant the following relief:
A. Grant a Temporary Order pursuant to the "Protection from Abuse Act:"
I. Ordering the defendant to refrain from abusing the
plaintiff and/or placing her in fear of abuse.
2. Ordering the defendant to refrain from having any
direct or indirect contact with the plaintiff including, but not
limited to, telephone and written communications, except to
facilitate custody arrangements.
3. Ordering the defendant to refrain from harassing
and stalking the plaintiff and from harassing the plaintiff's
relatives.
4. Prohibiting the defendant from entering the
plaintiff's place of employmentlbusiness.
5. Prohibiting the defendant from damaging or
destroying property jointly owned by the parties or owned solely
by the plaintiff.
6. Granting possessIOn of the home located at 63
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North 31'( Street, Camp Hill, Cumberland County, Pennsylvania, to
the plaintiff to the exclusion of the defendant pending a final order
in this matter, except for the limited purpose of transferring
custody of the parties' children. The defendant shall remain in his
vehicle at all times during the transfer of custody.
7. Ordering the defendant to stay away from the
plaintiffs residence located at 63 North 31 ,( Street, Camp Hill,
Cumberland County, Pennsylvania, and any other residence the
plaintiff may establish, except for the limited purpose of
transferring custody of the parties' children. The defendant shall
remain in his vehicle at all times during the transfer of custody.
8. Granting temporary custody of the minor children to
the plaintiff.
9. Ordering the defendant to relinquish to the sheriffs
department any weapon( s) which he owns, possesses or has used or
threatened to use against the plaintiff and/or the minor children:,
and prohibiting the defendant from acquiring or possessing any
other weapons for the duration of the order.
B. Schedule a hearing in accordance with the provisions of the "Protection from
Abuse Act," and, after such hearing, enter an order to be in effect for a period of one year:
1. Ordering the defendant to refrain from abusing the
plaintiff and/or placing her in fear of abuse.
2. Ordering the defendant to refrain from having any
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direct or indirect contact with the plaintiff including, but not
limited to, telephone and written communications, except to
facilitate custody arrangements.
3. Ordering the defendant to refrain from harassing
and stalking the plaintiff and from harassing the plaintiff's
relatives.
4. Prohibiting the defendant from entering the
plaintiff's place of employment/business.
5. Prohibiting the defendant from damaging,
destroying property jointly owned by the parties or owned solely
by the plaintiff.
6. Granting possessIOn of the home located at 63
North 31" Street, Camp Hill, Cumberland County, Pennsylvania, to
the plaintiff to the exclusion of the defendant, except for the
limited purpose of transferring custody of the parties' children.
The defendant, shall remain in his vehicle at all times during the
transfer of custody.
7. Ordering the defendant to stay away from the
plaintiff's residence located at 63 North 31" Street, Camp Hill,
Cumberland County, Pennsylvania, and any other residence the
plaintiff may establish, except for the limited purpose of
transferring custody of the parties' children. The defendant shall
remain in his vehicle at all times during the transfer of custody.
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8. Ordering the defendant to relinquish to the sheriff s
department any weapons which he owns, possesses or has used or
threatened to use against the plaintiff and/or the minor children,
and prohibiting the defendant from acquiring or possessing any
other weapons for the duration of the Order.
9. Granting support to the plaintiff and/or the minor
children in the amount of $250.00 per week, payable to the
plaintiff in the form of a check or money order, mailed to her
residence, and ordering the defendant to provide health coverage to
the spouse and/or minor children, directing the defendant to pay all
of the unreimbursed medical expenses of the plaintiff (spouse)
and/or minor children of the defendant to the provider or to the
plaintiff when she has paid for the medical treatment and directing
the defendant to make or continue to make rent or mortgage
payments on the residence of the plaintiff.
10. Granting temporary custody of the minor children to
the plaintiff.
The plaintiff further asks that this Petition be filed and served without payment of fees
and costs by the plaintiff, pending a further order at the hearing, and that a certified
copy/certified copies of this Petition and Order be delivered to the Pennsylvania State Police and
the Camp Hill Police Department which have jurisdiction to enforce this Order.
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The plaintiff prays for such other relief as may be just and proper.
Respectfully submitted,
Date J/3t>!t>)
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Austin F. Grogan', E u'
24 North 32nd Street
Camp Hill, Pennsylvania 17011
(717) 737-1956
Attorney for Plaintiff
ID #59020
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VERIFICATION
The above-named plaintiff, NATALIE A. TAYLOR, verifies that the statements made in
the above Petition are true and correct. The plaintiff understands that false statements herein are
made subject to the penalties of 18 Pa.C.S. S 4904 relating to unsworn falsification to authorities.
Date: I/JI) J () I
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NATALIE A. TAYLOR
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NATALIE A. TAYLOR,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO.Of-(".;;J.:J CIVIL TERM
WILLIAM S. TAYLOR,
Defendant
PROTECTION FROM ABUSE
AND CUSTODY
PROTECTION ORDER
,2001, upon presentation and consideration
children, Katie Taylor, born September 14, 1990, Eden Taylor, born November 18, 1991, and
Brooke Taylor, born June 2, 1996, now residing at 63 North 31" Street, Camp Hill, Cumberland
County, Pennsylvania, are in immediate and present danger of abuse from the defendant, William
S. Taylor, the following Temporary Order is entered. *Law enforcement agencies, human
service agencies and school districts shall not disclose the presence of the plaintiff or
furnish any address, telephone number, or any other demographic information about the
plaintiff except by further Order of Court.
The defendant, William S. Taylor, date of birth not known, whose Social Security
number is 194-52-1745, now residing at 63 North 31" Street, Camp Hill, Cumberland County,
Pennsylvania, is hereby enjoined from physically abusing the plaintiff, Natalie A. Taylor, or
placing her in fear of abuse.
The defendant is excluded from and is ordered to stay away from the plaintiff's residence
located at 63 North 31" Street, Camp Hill, Cumberland County, Pennsylvania, a residence which
is jointly leased by the parties; (and any other residence the plaintiff may establish), except for
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CUM8Ef\lJ\i,iD COUN1Y
PENNSYLV."'NIA
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the limited purpose of transferring custody of the parties' children.
The defendant is ordered to refrain from having any direct or indirect contact with the
plaintiff including, but not limited to, telephone and written communications, except for the
limited purpose of facilitating custody arrangements.
The defendant is enjoined from harassing and stalking the plaintiff and from harassing the
plaintiff's relatives.
The defendant is enjoined from entering the plaintiff's place of employment/business.
The defendant is enjoined from damaging or destroying any property owned jointly by
the parties or owned solely by the plaintiff.
A violation of this Order may subject the defendant to: i) arrest under 23 Pa.C.S.
96113; ii) a private criminal complaint under 23 Pa.C.S. 96113.1; iii) a charge of indirect
criminal contempt under 23 Pa.C.S. 96114, punishable by imprisonment up to six months
and a fine of $100.00-$1,000.00; and iv) civil contempt under 23 Pa.C.S. 96114.1.
Resumption of co-residence on the part of the plaintiff and defendant shall not nullify the
provisions of the court order.
This Order shall remain in effect until modified or terminated by the Court and can be
extended beyond its original expiration date if the Court finds that the defendant has committed
another act of abuse or has engaged in a pattern or practice that indicates continued risk of harm
to the plaintiff.
Temporary custody of the parties minor children, Katie Taylor, born September 14, 1990,
Eden Taylor, born November 18, 1991, and Brooke Taylor, born June 2,1996, is hereby awarded
to the plaintiff, Natalie A. Taylor.
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The defendant is ordered to relinquish to the sheriff's department any weapon(s) which he
owns, possesses, has used or threatened to use against the plaintiff and the defendant is
prohibited from acquiring or possessing any other weapons for the duration of this Order and is
required to relinquish to the sheriff any fuearm license the defendant may possess. The
defendant's weapons and fuearm license may be returned at the expiration of the Protection
Order after the defendant has submitted a written request to the Court for the return of the
weapons and the Court has notified the plaintiff of the request and given the plaintiff an
opportunity to respond. A copy of this Order shall be transmitted to the chief or head of the
police department of Camp Hill, Pennsylvania and the sheriff of Cumberland County.
A hearing shall be held on this matter on the /0 rW day of .:/J.'~001, at
II : ~ .Am., in Courtroom No.J , Cumberland County Courthouse, Carlisle, Pennsylvania.
,
The plaintiff may proceed without pre-payment of fees pending further order of court.
The Cumberland County Sheriffs Department shall attempt to make service at the
plaintiff's request and without pre-payment of fees, but service may be accomplished under any
applicable rule of Civil Procedure.
This Order shall be docketed in the office of the Prothonotary and forwarded to the
Sheriff for service. The Prothonotary shall not send a copy of this Order to the defendant by
mail.
The Pennsylvania State Police and the Camp Hill Police Department will be provided
with a certified copy/certified copies of this Order by the plaintiff's attorney. This Order shall be
enforced by any law enforcement agency where a violation occurs by arrest for indirect criminal
contempt without warrant upon probable cause that this Order has been violated, whether or not
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the violation is committed in the presence of the police officer. In the event that an arrest is
made under this section, the defendant shall be taken without unnecessary delay before the court
that issued the order. When that court is unavailable, the defendant shall be taken before the
appropriate district justice. (23 Pa.C.S. S 6113).
By the Court,
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01/31/01 WED 09:57 FAX 717 240 6573
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CUMB CO PROTHONOTARY
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141001
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TRANSACTION OK
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01]9p2405331
04]92490779
CENTRAL PROCESS
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OFFICE OF TIlE PROl'HON:JTARY
CliMl3EflLAND CXXJNTY a:x.JR'IHOOSE
ONE a:x.JR'IHOOSE SQUARE
CARLISLE, PII. 17013-3367
(717) 240-6195
FAX (717) 240-6573
v I 11 TEL E COP I E R
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PA STATE POLICE
FAX ":
717-2.49-0779
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ClJRTIS R. LONG
RE:
PFA ORDERS
MESSAGE :
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-00623 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
TAYLOR NATALIE A
VS
TAYLOR WILLIAM S
CPL. TIMOTHY REITZ
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE
was served upon
TAYLOR WILLIAM S
the
DEFENDANT
, at 0020:05 HOURS, on the 30th day of January ,2001
at 63 NORTH 31ST ST
CAMP HILL, PA 17011
by handing to
WILLIAM S TAYLOR
a true and attested copy of PROTECTION FROM ABUSE
together with
AND CUSTODY, TEMPORARY PROTECTION ORDER, NOTICE
OF HEARING, PETITION
and at the same time directing His attention to the contents thereof.
Additional Comments
WEAPONS CONFISCATION
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
9.30
.00
10.00
.00
37.30
So Answers:
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R. Thomas Kline
01/31/2001
Sworn and Subscribed to before
~'C::
By: VA
me this .)~ day of
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t)'t. .0 )y. Jp,. , "Ajar
Prothonotary
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NATALIE A. TAYLOR,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-623 CIVil TERM
PROTECTION FROM ABUSE AND CUSTODY
WilLIAM S. TAYLOR,
Defendant
IN RE: PFA HEARING
ORDER OF COURT
AND NOW, January 31, 2001, the Order of Court of January 30,
2001, to the above term and number, shall be amended as follows:
A hearing shall be held on this matter on the 9th day of
February, 2001, at 11 :00 a.m. in Courtroom No.3, Cumberland County
Courthouse, Carlisle, Pennsylvania.
The remainder of the Order shall remain in effect as written.
By the Court,
Austin F. Grogan, Esquire
24 North 32nd Street
Camp Hill, PA 17011
COPl€S'
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FiLED-Oi:FI('f'
(iF F'r: ,.:r;""rL!'~~I' ;-Ol"ARY
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OIFEB-1 AHil:02
CUMaEHuiJ~[) COUNTY
PENNSYLVA~j!A
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NATALIEA. TAYLOR,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-623 CIVIL TERM
WILLIAM S. TAYLOR,
Defendant
PROTECTION FROM ABUSE AND CUSTODY
ORDER
AND NOW, this IL/~ day of YVI.......J., 2001, upon agreement of the parties and
without a finding of abuse and without admitting to the allegations in the Petition, the following
Protective Order is entered:
1. Defendant, William S. Taylor, is hereby prohibited from abusing, stalking,
threatening, or harassing in any manner, including by telephone, the Plaintiff, Natalie A. Taylor,
either physically or by verbal threats, wherever she may be and is specifically excluded from the
marital home located at 63 North 21 st Street, Camp Hill, Pennsylvania, or any other residence she
may establish. The Defendant is further prohibited from having contact or communication by
any means with the Plaintiff. The Defendant is further restrained from entering the place of
employment or business or school of the Plaintiff and/or minor children.
2. Primary physical custody of the parties children, Katie Taylor, born September
14, 1990; Eden Taylor, born November 18, 1991; and Brooke Taylor, born June 2,1996 is
granted to the Plaintif:fIMother. Defendant shall have partial custody by agreement or following
a custody conference.
3. The Defendant is hereby notified that if he violates this Order, he may be held in
indirect criminal contempt which is punishable by a fine not to exceed $1,000.00 and by a
sentence of up to six (6) months in jail and by other possible relief, or he may be held in civil
contempt. Beginning to or resumption ofliving at residence to which the Defendant is excluded
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by this Order could result in a finding of indirect criminal contempt or civil contempt. Consent
of the Plaintiff to resume contact or cohabitation does not invalidate, nullify, or void the
provisions of this Order as it relates to the prohibition against abuse. Further, any violation of
this Order may also constitute a crime under the Pennsylvania Criminal Code, and those
penalties may be in addition to those imposed as contempt pursuant to this Order.
4. Any police department having appropriate jurisdiction pursuant to the Protection
From Abuse Act, 23 P.S. 96101 et seq., may arrest Defendant for violation of said Order without
warrant upon probable cause whether or not the violation is committed in the presence of the
police department. The Defendant's social security number is 194-52-1745.
5. This Order shall remain in effect for J i1 months from the date thereof.
6. Costs of this proceeding are placed on the Defendant. Costs are to be paid at the
Office of Prothonotary of Cumberland County by ~ I 'i ) ,;. t>b I
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CUMBS;HlAi\itJ COUNlY
PENNSYLVANIA
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NATALIE A. TAYLOR,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL V ANlA
NO. 01-623 CIVIL TERM
WILLIAMS. TAYLOR,
Defendant
PROTECTION FROM ABUSE AND CUSTODY
STIPULATION
AND NOW, this 1 tlLday of ~001, the parties agree to the following:
1. The Defendant, William S. Taylor, will refrain from abusing, stalking,
threatening, or harassing in any manner, including by telephone, the Plaintiff, Natalie A. Taylor,
either physically or by verbal threats, wherever she may be;
2. The Defendant specifically agrees to refrain from entering the marital residence
located at 63 North 31 st Street, Camp Hill, Pennsylvania, or any other residence the Plaintiff may
establish.
3. Furthermore, the Defendant agrees to refrain from having contact or
communication by any means with the Plaintiff. Communication regarding the parties' minor
children shall be conducted through the Plaintiff's parents until further Order of Court.
4. The Defendant agrees to refrain from entering the place of employment or
business or school of the Plaintiff and/or minor children.
5. Plaintiff/Mother shall have primary physical custody of the parties' children,
Katie Taylor, born September 14, 1990; Eden Taylor, born November 18, 1991; and Brooke
Taylor, born June 2,1996. Defendant shall have partial custody by agreement or following a
custody conference.
6. The Defendant understand that if he violates this Stipulation, he may be held in
indirect criminal contempt which is punishable by a fine not to exceed $1,000.00 and by a
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sentence of up to six (6) months injail and by other possible relief, or he may be held in civil
contempt. Beginning to or resumption ofliving at residence to which the Defendant is excluded
by this Stipulation could result in a fmding of indirect criminal contempt or civil contempt.
Consent of the Plaintiff to resume contact or cohabitation does not invalidate, nullify, or void the
provisions of this Stipulation as it relates to the prohibition against abuse. Further, any violation
of this Stipulation may also constitute a crime under the Pennsylvania Criminal Code, and those
penalties may be in addition to those imposed as contempt pursuant to this Stipulation.
7. Any police department having appropriate jurisdiction pursuant to the Protection
From Abuse Act, 23 P.S. 96101 et seq., may arrest the Defendant for violation of said Order
without warrant upon probable cause whether or not the violation is committed in the presence of
the police department. The Defendant's social security number is 194-52-1745;
8. This Stipulation shall remain in effect until further Order of Court.
9. The Defendant, William Taylor, enters this Stipulation without admitting any of
the allegations set forth in the Protection From Abuse Petition.
WHEREFORE, the parties respectfully request this Honorable Court to issue an Order
ratifying this Stipulation.
~~F
TNESS
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NATALIE TAYLOR
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WITNESS
LIAM S. TAYLOR
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NATALIE A. TAYLOR,
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
PlaintiIDRespondent,
v.
: NO. 01-623
CIVIL ACTION - LAW
WILLIAM S. TAYLOR,
IN CUSTODY
DefendantlPetitioner.
ORDER
AND NOW, this day of , 2001, upon
consideration of the attached Complaint, it is hereby directed that the parties and their respective
counsel appear before , the Conciliator, at
, on , the day
of , ~, at o'clock _.m., for a Pre-Hearing
Custody Conference. At such conference, an effort will be made to resolve the issues in dispute;
or if this cannot be accomplished, to define and narrow the issues to be heard by the Court, and to
enter into a temporary Order. All children age five or older may also be present at the conference.
Failure to appear at the conference may provide grounds for entry of a temporary or permanent
Order.
FOR THE COURT,
By
Custody Conciliator
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
YOU DO NOT HA VB A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP
OFFICE OF THE COURT ADMINISTRATOR
COURTHOUSE, 4TH FLOOR
CARLISLE, PA 17013
(717) 240-6200
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CUMB co PROmONOTARY
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CENTRAL PROCESS
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OFl'lCE OF 'IllE PRCYIrlCXIOTARY
CUMBERLAND ffiJNr'{ COUImiOOSE
cx-sE axJRTHCXJSE SQUARE
CARLISLE. PA. 17013-3387
(717) 240-6195
FAX (717) 240-6573
VIA TELECOPIER
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C!~Ntre.,q' Preol!..e..ssi41'j
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RE: PFA ORDERS
MESSAGe :
-L.....- fIK). OF PAGES (INCWDING COVER SHEET)
1h:is m:ssa::l" is in1:e'l:i;;O cnly fur tte lSC of tte irrlividu91 or 6'll:ity to ..rom is is cdll. :: i. Ef"CI rrBj
a::nt:ain ~ thrt is p:iviJ.e;;J:d. =d:fu1:tial a-d 6<BTP= fu:m ni....1no:ure I..l:'IB:' ,<<,1 irHl1.. l2w. If
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NATALIE A. TAYLOR,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYL VANIA
NO. 01-623 CIVIL TERM
WILLIAM S. TAYLOR,
Defendant
PROTECTION FROM ABUSE AND CUSTODY
ORDER
AND NOW, this / ~fh day ofmaa:L, 2001, upon agreement of the parties and
without a finding of abuse and without admitting to the allegations in the Petition, the following
Protective Order is entered:
I. Defendant, William S. Taylor, is hereby prohibited from abusing, stalking,
threatening, or harassing in any manner, including by telephone, the Plaintiff, Natalie A. Taylor,
either physically or by verbal threats, wherever she may be and is specifically excluded from the
marital home located at 63 North 21st Street, Camp Hill, Pennsylvania, or any other residence she
may establish. The Defendant is further prohibited from having contact or communication by
any means with the Plaintiff. The Defendant is further restrained from entering the place of
employment or business or school of the Plaintiff and/or minor children.
2. Primary physical custody of the parties children, Katie Taylor, born September
14, 1990; Eden Taylor, born November 18, 1991; and Brooke Taylor, born June 2,1996 is
granted to the Plaintiff/Mother. Defendant shall have partial custody by agreement or following
a custody conference.
3. The Defendant is hereby notified that ifhe violates this Order, he may be held in
indirect criminal cOlltempt which is punishable by a fme not to exceed $1,000.00 and by a
sentence of up to six (6) months injail and by other possible relief, or he may be held in civil
contempt. Beginning to or resumption of living at residence to which the Defendant is excluded
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by this Order could result in a fmding of indirect criminal contempt or civil contempt. Consent
of the Plaintiff to resume contact or cohabitation does not invalidate, nullify, or void the
provisions of this Order as it relates to the prohibition against abuse. Further, any violation of
this Order may also constitute a crime under the Pennsylvania Criminal Code, and those
penalties may be in addition to those imposed as contempt pursuant to this Order.
4. Any police department having appropriate jurisdiction pursuant to the Protection
From Abuse Act, 23 P.S. 96101 et seq., may arrest Defendant for violation of said Order without
warrant upon probable cause whether or not the violation is committed in the presence of the
police department. The Defendant's social security number is 194-52-1745.
5.
This Order shall remain in effect for
I J. months from the date thereof.
6. Costs of this proceeding are placed on the Defendant. Costs are to be paid at the
Office of Prothonotary of Cumberland County by lJpr.1 I 0. 10(J I
BY THE COURT,
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NATALIEA. TAYLOR,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-623 CIVIL TERM
WILLIAM S. TAYLOR,
Defendant
PROTECTION FROM ABUSE AND CUSTODY
STIPULATION
AND NOW, this 1 t1!.,day of ~ 2001, the parties agree to the following:
1. The Defendant, William S. Taylor, will refrain from abusing, stalking,
threatening, or harassing in any marmer, including by telephone, the Plaintiff, Natalie A. Taylor,
either physically or by verbal threats, wherever she may be;
2. The Defendant specifically agrees to refrain from entering the marital residence
located at 63 North 3151 Street, Camp Hill, Pennsylvania, or any other residence the Plaintiff may
establish.
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3. Furthermore, the Defendant agrees to refrain from having contact orllm ~
Z:n
communication by any means with the Plaintiff. Communication regarding the paj~ .r
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children shall be conducted through the Plaintiff's parents until further Order of C~ ~
4. The Defendant agrees to refrain from entering the place of emPIOyme~ or ~
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business or school of the Plaintiff and/or minor children.
5. Plaintifti'Mother shall have primary physical custody of the parties' children,
Katie Taylor, born September 14, 1990; Eden Taylor, born November 18,1991; and Brooke
Taylor, born June 2, 1996. Defendant shall have partial custody by agreement or following a
custody conference.
6. The Defendant understand that ifhe violates this Stipulation, he may be held in
indirect criminal contempt which is punishable by a fine not to exceed $1,000.00 and by a
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sentence of up to six (6) months in jail and by other possible relief, or he may be held in civil
contempt. Beginning to or resumption ofliving at residence to which the Defendant is excluded
by this Stipulation could result in a finding of indirect criminal contempt or civil contempt.
Consent of the Plaintiff to resume contact or cohabitation does not invalidate, nullifY, or void the
provisions of this Stipulation as it relates to the prohibition against abuse. Further, any violation
of this Stipulation may also constitute a crime under the Pennsylvania Criminal Code, and those
penalties may be in addition to those imposed as contempt pursuant to this Stipulation.
7. Any police department having appropriate jurisdiction pursuant to the Protection
From Abuse Act, 23 P.S. 96101 et seQ., may arrest the Defendant for violation of said Order
without warrant upon probable cause whether or not the violation is committed in the presence of
the police department. The Defendant's social security number is 194-52-1745;
8. This Stipulation shall remain in effect until further Order of Court.
9. The Defendant, William Taylor, enters this Stipulation without admitting any of
the allegations set forth in the Protection From Abuse Petition.
WHEREFORE, the parties respectfully request this Honorable Court to issue an Order
ratifYing this Stipulation.
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NATALIE TAYLOR
WITNESS
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CBRTIFICATIOO OF PFA CCNl'EMPT
CASE rn-IBER 0 (- (, l..~
NAME Wi Ilte(Wf, 0. T~/or
VICTIM'S NAME:
NcJ4(if" A. la-y(Dr-
BALANCE DUE: $ Ii ).. ~D ADD DELETE
170 STATE SURCHARGE $ $
L7l STATE FINE $ $
260 SHERIFF COST ($1.50 +, ADDTL) $ 3 (. ;)0 $
201 DISTRICT ATTORNEY $ 15.00 $
204 COURT COSTS (CLERK OF COURTS) $ 15.00 $
502 RESTITUTION
NAME :;> rvtk t> i\Ofn f Y $ 'r5.5b $
ADDRESS
CITY
STATE
ZIP
NAME
$
$
ADDRESS
CITY
STATE
ZIP
NAME
$
$
ADDRESS
CITY
STATE
ZIP
'ROTHONOTA'Y OFF'CR 'A~ ~
PERSON CERTIFYING INFORMATION ~ .
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NATALIEA. TAYLOR
PLAINTIFF
V.
WILLIAMS. TAYLOR
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-623
CIVIL ACTION LAW
IN CUSTODY
ORDER OF COURT
AND NOW, Friday, March 30, 2001 , upon consideration of the attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator,
at 214 Senate Avenue, Suite 105, Camp HilI, PA 17011 on Monday, April 23, 2001 at 11:00 a.m.
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Failure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the conciliator 48 hours prior to scheduled hearing.
FOR THE COURT,
By: Isl
Melissa P. Greevy. EsqbtJ
Custody Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilites 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.
yOU SHOULD TAKE TIllS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HA VB AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIlE OFFICE SET
FORTIl BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, Pennsylvania 17013
Telephone (717) 249-3166
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NATALIE A TAYLOR,
. IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff/Respondent,
v.
: NO. 01-623 CIVIL TERM
WILLIAM S. TAYLOR,
. IN CUSTODY
DefendantlPetitioner,
PETITION FOR SHARED LEGAL
AND PHYSICAL CUSTODY
AND NOW, comes the Petitioner, William S. Taylor, by and through his
attorneys, Mancke, Wagner, Hershey & Tully, and files the following Petition for
Custody:
1. Tom Petitioner, William S. Taylor, is an adult individual currently residing
at 427 South York Street, Mechanicsbmg, Cmnberland County, Pennsylvania.
2. The Respondent, Natalie A. Taylor, is an adult individual currently
residing at 63 North 31 st Street, Camp Hill, Cumberland County, Pennsylvania.
3. The parties are husband and wife having been married October 13, 1989.
4. The parties are the natmal parents of three (3) children, Katherine, born
September 14, 1990; Eden, born November 18,1991; and Brooke, born June 2,
1996,
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5. The children were born during wedlock.
6. The Petitioner herein is the natural father of the aforementioned children
,
and the Respondent is the natural mother of the aforementioned children.
7. Petitioner is aware of no other person asserting custody or partial custody
rights and knows of no other party that should be included in the proceeding.
8. From June 14, 1996, when the purchased the home listed in paragraph 2
above, the parties resided together with the children lmtil January 30, 2001.
As of January 30,2001, the Petitioner herein moved to the address contained
in paragraph 1 above, with the children remaining with the Respondent at the
address contained in paragraph I above.
9. There was a prior proceeding regarding the custody of the children at the
above-captioned number when a temporary order was entered as a result of a
consent regarding a PF A that was filed by the Respondent herein.
10. Petitioner believes and therefore avers that it is in the best interest of the
children to provide shared legal and shared physical custody of the children in order
to promote the relationship by and between both parents and the children, in that the
Petitioner is able to care for the day to day needs of the children, Petitioner is able
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to provide the appropriate nurturing and the appropriate care for the children, all
evidencing that it is in the best interests of the children to grant the relief requested.
WHEREFORE, Petitioner prays this Court to grant relief in the form of
shared legal and shared physical custody of the children.
Respectfully submitted,
Mancke, Wagner, Hershey & Tully
. ard
I.D. #23103
2233 North Front Street
Harrisburg, PA 17110
(717) 234-7051
Attorneys for Petitioner
Date: .5IILflbl
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VERIFICATION
I verify that the statements made in the foregoing
document are true and correct. I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S.
section 4904, relating to unsworn falsification to authorities.
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DATE:
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MAY 0 82001 rJ1
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NATALIE A. TAYLOR,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-623
vs.
WILLIAM S. TAYLOR,
Defendant
CIVIL ACTION - LAW
CUSTODY
Guido, J. ORDER OF COURT
AND NOW, this I' ~ day o~ ' 2001, upon consideration of the
attached Custody Conciliation Summary Repo t is hereby ordered and directed as follows:
1. Legal Custody. The parties, Natalie A. Taylor and William S. Taylor, shall have
shared legal custody of the minor Children, Katherine Taylor, born September 14, 1990, Eden
Taylor, born November 18, 1991 and Brooke Taylor born June 6,1996. Each parent shall
have an equal right, to be exercised jointly with the other parent, to make all major non-
emergency decisions affecting the Children's general well-being including, but not limited to,
all decisions regarding their health, education and religion. Pursuant to the terms of Pa. C. S.
S 5309, each parent shall be entitled to all records and information pertaining to the Children
including, but not limited to, medical, dental, religious or school records, the residence address
of the Children and of the other parent. To the extent one parent has possession of any such
records or information, that parent shall be required to share the same, or copies thereof, with
the other parent within such reasonable time as to make the records and information of
reasonable use to the other parent.
2. Poysical Custody. Mother shall have primary physical custody. Father shall have
partial physical custody arranged as follows:
A. On the following dates, Father shall have physical custody from Friday at
5:00 p.m. until Sunday at 8:00 a.m. May 4, 2001 through May 6, 2001;
May 18, 2001 through May 20, 2001; June 1, 2001 through June 3, 2001;
July 6, 2001 through July 8, 2001.
B. Additionally, Father shall have custody from Noon until 7:00 p.m. on the
Sundays of his custodial weekends and shall make the appropriate
adjustments for the Children's soccer schedule.
C. Father shall have physical custody each Tuesday evening from 5:00 p.m.
until 8:00 p.m. each Tuesday in May, July 10, 2001, and August 28,2001.
D. Father shall have the following summer custody schedule: June 22, 2001,
through July 1, 2001; July 28, 2001, through August 4, 2001; and August
19, 2001, through August 26, 2001.
-"'-
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No. 01-623 Civil Term
E. Independence Day. Father shall have custody on Independence Day
from 4:00 p.m. July 4, 2001, until 9:00 a.m. July 5, 2001.
3. Mother shall provide Father with copies of a schedule of the Children's activities.
4. This Order is temporary in nature, In the event that the parties are not able to
resolve the issues of the custody by agreement within sixty days of the date of this Order,
counsel for either party may contact the Conciliator to schedule an additional Custody
Conciliation Conference.
Edward E. Guido, J.
Dis!: P. Richard Wagner, Esquire, Mancke, Wagner, Hershey & Tully, 2233 N. Front Street, Harrisburg, PA 17110
Austin F. Grogan, Esquire, 24 N. 32"' Street, Camp Hill, PA 17011
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NATALIE A. TAYLOR,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-623
vs.
WILLIAM S. TAYLOR,
Defendant
CIVIL ACTION - LAW
CUSTODY
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the Children who are the subject of this
litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN CUSTODY OF
Katherine Taylor
Eden Taylor
Brooke Taylor
September 14,1990
November 18,1991
June 6, 1996
Mother
Mother
Mother
2. A Custody Conciliation Conference was held on April 30, 2001, with the following
individuals in attendance: the Mother, Natalie A. Taylor, and her counsel, Austin F. Grogan,
Esquire; the Father, William S. Taylor, and his counsel, P. Richard Wagner, Esquire.
3. The parties were seen for a Custody Conciliation Conference and reached an
agreement in the form of an Order as attached. Father's counsel shall prepare and file an
executed stipulation modifying the terms of the PFA issued by Judge Guido on March 14,
2001, so that its terms will not conflict with the agreements the parties have made with regard
to custody of their Children.
Melissa Peel Greevy, Esquire
Custody Conciliator
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NATALIE A. TAYLOR,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
Plaintifli'Respondent,
v.
: NO: 01-623 CIVIL TERM
: CIVIL ACTION - LAW
WILLIAM S. TAYLOR,
: PROTECTION FROM ABUSE
DefendantfPetitioner.
ORDER
AND NOW, this 2-0 day of
,2001, upon
presentation of a Petition on behalf of William S, Taylor, and being advised that the
Respondent, Natalie A. Taylor, concurs with the request in the Petition, it is hereby
ORDERED and DECREED that the Protection From Abuse Order currently in
effect shall be amended to eliminate the prohibition of the Petitioner herein from
owning and possessing his weapons which had previously been placed in the
custody of the Sheriff of Cumberland County.
It is further ORDERED and DIRECTED that the Sheriff release, relinquish
and discharge unto the Petitioner herein the weapons that are currently in the
possession of the Sheriff which belong to the Peti1jone
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NATALIE A. TAYLOR,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff/Respondent,
v.
: NO: 01-623 CIVIL TERM
: CIVIL ACTION - LAW
WILLIAM S. TAYLOR,
: PROTECTION FROM ABUSE
Defendant/Petitioner.
PETITION FOR SPECIAL RELIEF
AND NOW, comes your Petitioner, William S. Taylor, by and through his
attorneys, Mancke, Wagner, Hershey & Tully, and files the following Petition for
Special Relief:
1. Your Petitioner, William S. Taylor, is the Defendant in the above-
captioned PF A.
2. The Respondent, Natalie A. Taylor, is the Plaintiff in the above-captioned
PFA.
3. The Court of Common Pleas of Cumberland County entered a Temporary
Protection Order dated January 30, 2001, as a result of which the Sheriff of
Cumberland County took possession of the following three (3) weapons belonging
to the Petitioner:
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A. 35 Remington Deer Rifle;
B. 12 gauge Savage Shotgun; and
C. 12 gauge Winchester Shotgun. (It may be a Remington)
4. The Respondent herein has filed an action in divorce at No. 01-3601 Civil
Term, Court of Common Pleas of Cumberland County, and both parties aie
currently represented by counsel.
5. The parties are attempting to resolve all domestic issues in an amicable
fashion pursuant to that divorce complaint.
6. On or about the 16th day of November, 2001, during a 4-party conference,
the parties agreed that the weapons that heretofore had been placed in the custody
of the Sheriff could be released unto the Petitioner herein for purposes of the
Petitioner herein engaging in extra curricular activities involving hunting.
7. The Respondent, through legal counsel, Austin F. Grogin, Esquire,
concurs in the filing of this Petition, and further concurs in the Order that permits the
Sheriff to release custody of the weapons unto the Petitioner herein.
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8. Petitioner avers and confirms to the Court that the utilization of the
weapons will solely be for lawful extra curricular activities in the form of hunting
small and/or big game.
9. Petitioner requests this Court to relieve the Petitioner from the provisions
of the PF A that prohibit him from possessing weapons, and requests this Court to
direct the Sheriff to release the aforementioned weapons unto the Petitioner herein.
WHEREFORE, Petitioner prays this Court to grant the relief requested in the
form of directing the Sheriff to return unto the Petitioner the 35 Remington Deer
Rifle, the 12 gauge Savage shotgun, and the 12 gauge Winchester (Remington)
shotgun.
Respectfully submitted,
Date: II/ICJ /tJl
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Mancke, Wagner, Hershey & Tully
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I.D. #23103
2233 North Front Street
Harrisburg, P A 17110
(717) 234-7051
Attorneys for Petitioner
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VERIFICATION
I verify that the statements made in the foregoing
document are true and correct,
I understand that false
statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to
DATE:
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NATAL/EA. TAYLORACRI
PLAINTIFF
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYL VANIA
v.
01-623
CIVIL ACTION LAW
WILLIAM S. TAYLOR
DEFENDANT
IN CUSTODY
ORDER OF COURT
AND NOW, Thursday, November 20, 2003 , upon consideration ofthe attached Complaint,
it is hereby directed that parties and their respective counsel appear before Melissa P. Greevy, Esq. , the conciliator,
at 301 Market Street, Lemoyue, PA 17043 on Mouday, December 22, 2003 at 9:00 AM
for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to defme and narrow the issues to be heard by the court, and to enter into a temporary
order. All children age five or older may also be present at the conference. Fai]ure to appear at the conference may
provide grounds for entry of a temporary or permanent order.
The court hereby directs the parties to furnish any aud all existing Protectiou from Abuse orders,
Special Relief orders, aud Custody orders to the couciliator 48 hours prior to scheduled hearing.
FOR THE COURT.
By: Isl
Melissa P. Greevy. Esq.
Custody Conciliator
1/
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabi]ites Act of] 990. 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.
YOU SHOULD TAKE 1HIS PAPER TO YOUR ATTORNEY AT ONCE. IF YOU DO NOT
HAVE AN ATTORNEY OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania ] 70] 3
Telephone (717) 249-3 ]66
/(- cJ.f-03
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NATALIE A. TAYLORACRI,
: IN TIIE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
PlaintiIDRespondent,
v.
: NO: 01-623 CIVIL TERM
WILLIAM S. TAYLOR,
: IN CUSTODY
DefendantIPetitioner.
ORDER
AND NOW, this
day of
,2003, upon Petition of the
Defendllnt, William S, Taylor, the matter is referred to a custody conciliator,
, for purposes of scheduling a custody conciliation
immediately,
BY THE COURT:
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NATALIE A. TAYLORACRI,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYL VANIA
PlaintiflJRespondent,
V. .
: NO: 01-623 CIVIL TERM
WILLIAM S. TAYLOR,
: IN CUSTODY
DefendantJPetitioner.
PETITION FOR CUSTODY CONCILIATION
AND NOW, comes your Petitioner, William S. Taylor, by and through his
attorneys, Mancke, Wagner & Spreha, and files the following Petition for Custody
Conciliation:
1. Your Petitioner, William S. Taylor, is the Defendant in the above-captioned
matter.
2. The Respondent, Natalie Taylor Acri, is the Plaintiff in the above-captioned
matter,
3. Petitioner filed a Petition for Relief in the Court of Common Pleas of Dauphin
County at No. 2003-CV-3890, based upon the Respondent's moving from the jurisdiction
of the Dauphin County Court.
4. The Respondent herein filed Objections to the Petition arguing the jurisdiction
properly was within Cumberland County.
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5, As a result, the Court of Common Pleas of Dauphin County issued an Order
transferring the custody case to the Cumberland County docket at No. 01-623.
6, Petitioner now seeks to have the custody Petition referred to a custody
conciliator to address the rights of the Petitioner herein as set forth in the petition for
custody filed September 9,2003, in the Court of Common Pleas of Dauphin County, a
copy of which Petition is attached hereto, incorporated herein by reference, made a part
hereof, and marked as Exhibit A.
7, Petitioner believes and therefore avers that this court should assign this matter
to a custody conciliator immediately for proceedings in Cumberland County.
WHEREFORE, Petitioner prays this Court to grant the relief as requested.
Respectfully submitted,
Mancke, Wagner & Spreha
By
P. Ric d Wagner, Esquire
3103
2233 North Front Street
Harrisburg, P A 1711 0
(717) 234-7051
Attorneys for Petitioner
Date: /1/1/ t3
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SEP-17-2003 12:19PM FROM-MANCKE WAGNER SPREHA
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T-735 P 002/006 F-l12
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WilLIAM TAYLOR,
: IN THE COURT OF COMMON PLEAS
: DAUPlITN COUNTY, PENNSYL VANIA
Petitioner,
: NO: d. 003 Q.v .3 890 C I'C
v.
: CIVll. ACTION - LAW
NATALIE A. TAYLOR ACRl,
: IN CUSTODY
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AND NOW, comes your Petitioner, William Taylor, by and through"ins w
Respondent.
PETITJON FOR EMERGENCY RELIEF
attorneys, Mancke, Wagner & Spreha, and files the following Petition for
Emergency Relief:
1. Your Petitioner, William Taylor, is an adult individual residing at 427 S.
York Street, Mechanicsburg, Cumberland County, Pennsylvania.
2. Respondent, Natalie A. Taylor Acri, is an adult individual residing in
Pottstown, Pennsylvania, at an address unknown to the Petitioner, having
previously lived at 755 Terry Hall Road, Millersburg, Dauphin County,
Pennsylvania.
3. Petitioner and Respondent were husband and wife, having since divorced,
and the Respondent remarried Dr. Joseph Acri.
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4. The parties are the natural parents of three (3) children, Katherine, born
September 14,1990, Eden, born November 18,1991, and Brooke, born June 2,
1996.
5. Petitioner is the natural father of the aforementioned children; Respondent
is the natural mother.
6. The children were all born during wedlock.
7. During the last five (5) years, the children have resided at the following
addresses with the following persons:
A. During the previous five (5) years up until January 29, 200 I, with the
Petitioner and Respondent at 63 North 31 st Street, Camp Hill,
Cumberland County, Pennsylvania;
B. From January 29,2001, until approximately the Swnmer of 2002, with
the Respondent and her husband, Dr, Joseph Acri at 63 N. 310t Street,
Camp Hill, Cumberland County, Pennsylvania;
C. From the Summer of 2002 until the end of August 2003, at 755 Terry
Hall Road, Millersburg, Dauphin County, Pe1lllsylvania, with the
Respondent and her husband;
SEP-17-Z003 12:19PM FROM-MANCKE WAGNER SPREHA
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D. From the end of August 2003 with the Respondent and her husband at
an address unknown in Pottstown, Pennsylvania.
8. At the end of August 2003, dwing a period of partial custody with the
Petitioner herein, the children confided in the Petitioner that the mother was
removing them from school and moving somewhere in Pottstown.
9, Petitioner herein inquired of the Respondent where she was moving, and
RespOrldent has refused to disclose the location where they are living. refused
to dil'J:.Iose the Dame ofthe school that the children are attending, and refused to
provide the Petitioner with any contact whatsoever concerning the move.
10. Petitioner believes and therefore avers that the move was not made in the
best interests of the children, was self-serving to the Petitioner and her new
husband, and is designed to maintain a strong relationship between the children and
the Petitioner.
11. Petitioner's immediate family as well as Respondent's immediate family
live in the Central Pennsylvania Area, i.e., Camp Hill and Mechanicsburg area.
12. Petitioner believes the surreptitious conduct of the Respondent is
designed to defeat the Petitioner's rights of custody and partial custody of his
SEP-17-Z00, IZ:19PM FROM-MANCKE WAGNER SPREHA
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children which is further evidenced by the fact that as of the filing of this Petition,
Respondent has not disclosed to the Petitioner the location of the children, the
address, the school and the name of the medical provider or any other information
whatsoever.
13. Petitioner has attempted to contact the Respondent, however, she has
refused to disclose the location of the Respondent and the children.
WHEREFORE, Petitioner prays this Court to grant his emergency relief in
the form of awarding custody of the children to him immediately, pending a bearing
to determirle whether or not under Gruber v. Gmber, the move is in the best
interests of the children.
Respectfully submitted,
Mancke, Wagner & Spreha
..2
By
, Richard Wagner, Esquire
I.D. #23103
2233 North Front Street
Harrisburg, P A 17110
(717) 234-7051
Attorneys for Petitioner
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VERIFICATION
I verify that the statements made in the foregoing
document are true and correct. I underst~nd th~t false
statements herein are made subject to the penalties of 18 Pa.C.S.
Section 4904, relating to unsworn
DATE:
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NATALIE A. TAYLOR ACRI,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-623 CIVIL TERM
v.
WILLIAM S. TAYLOR,
CIVIL ACTION - LAW
IN CUSTODY
Defendant
ORDER OF COURT
AND NOW, this 'j1It day of February, 2004, upon consideration of the attached
Custody Conciliation Summary Report, it is hereby ordered and directed as follows:
1. LeQal Custody; The parties, Natalie A. Taylor Acri and William S. Taylor, shall
have shared legal custody of the minor children, Katherine J. Taylor, born September 14,
1990, Eden D. Taylor, born November 18,1991, and Brooke A, Taylor, born June 2,1996.
Each parent shall have an equal right, to be exercised jointly with the other parent, to make
all major non-emergency decisions affecting the children's general well-being including, but
not limited to, all decisions regarding their health, education and religion. Pursuant to the
terms of Pa. C. S. 35309, each parent shall be entitled to all records and information
pertaining to the children including, but not limited to, medical, dental, religious or school
records, the residence address of the children and of the other parent. To the extent one
parent has possession of any such records or information, that parent shall be required to
share the same, or copies thereof, with the other parent within such reasonable time as to
make the records and information of reasonable use to the other parent.
2. Phvsical Custodv. Mother shall have primary physical custody subject to
Father's rights of partial custody which shall be arranged as follows:
A. To commence February 13, 2004, on alternating weekends from
Friday at 5:00 p.m. until Sunday at 8:30 p.m.
B. To commence February 3, 2004, each week on either Tuesday
or Wednesday from 5:30 p,m. until 8:30 p.m.
C. At such other times as the parties may agree.
D. Father will provide transportation for the children to their activities
which occur during his custodial time.
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NO. 01-623 CIVIL TERM
3. Vacation. Each parent shall be entitled to two (2) weeks of custody for
purposes of summer vacation upon thirty (30) days notice to the other parent. In the event
that the parties have scheduled conflicting or overlapping vacations, the party first providing
written notice shall have choice of vacation time.
4. Holidavs. The parties shall split and/or alternate holidays as they may
mutually agree.
5. In the event that Mother intends to relocate at a distance of greater than
twenty-five (25) miles from her present residence, she will provide Father with sixty (60)
days written notice of her intent in order to allow the parties to either work out an alternative
custodial plan or petition the Court for a Gruber hearing.
J.
Dist:
Diane G. Radcliff, Esquire, 3446 Trindle Road, Camp Hill, PA 17011
P. Richard Wagner, Esquire, 2233 N. Front Street, Harrisburg, PA 17110
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FEB 06 2004
NATALIE A. TAYLOR ACRI,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 01-623 CIVIL TERM
v.
CIVIL ACTION - LAW
WILLIAM S. TAYLOR,
IN CUSTODY
Defendant
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the children who are the subject of this
litigation is as follows:
DATE OF BIRTH
CURRENTLY IN THE CUSTODY OF
NAME
Katherine J. Taylor
Eden D. Taylor
Brooke A. Taylor
September 14, 1990
November 18,1991
June 2, 1996
Mother
Mother
Mother
2. A Custody Conciliation Conference was held on February 2, 2004 in response
to Father's November 14, 2003 filing of a Petition for Conciliation. Present for the
conference were: the Mother, Natalie A. Taylor Acri, and her counsel, Diane G. Radcliff,
Esquire; the Father, William S. Taylor, and his counsel, P. Richard Wagner, Esquire.
3. The parties reached an agreement in the form of an
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Date ssa Peel Greevy, Esquire
Custody Conciliator
:223834