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MAR 1 3 2001tP
DALLAS MICHAEL CONRAD,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNT, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
DONALD EDWARD VERNET, JR,
Defendant
: NO. OI-N'fiJ
CIVIL TERM
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. Any protection order granted by a court may be considered in subsequent
proceedings under Title 23 (Domestic Relations) of the Pennsylvania Consolidated Statutes,
including child custody proceedings under Chapter 53 (relating to custody).
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A hearing on the matter is scheduled for the ~ day of WQLL001, atI::2(i.f., in
Courtroom.....3- at the Cumberland County Courthouse, Carlisle, Pennsylvania.
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 subj ect 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. 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 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. SS 2261-2262.
YOU SHOULD TAKE TIDS 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 ALA WYEROR 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
(717) 249-3166
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DALLAS MICHAEL CONRAD,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
DONALD EDWARD VERNET, JR.,
Defendant
:NO. CJI-I'I'-Io
CIVIL TERM
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name: Donald Edward Vemet, Jr.
Defendant's Date of Birth: Unknown.
Defendant's Social Security Number: Unknown.
Names of All Protected Persons, including Plaintiff and minor children: Dallas Michael Conrad.
AND NOW, this /3 ~y of ht~ 2001, upon consideration of the attached
Petition for Protection from Abuse, the court hereby enters the following Temporary Order:
[Xl 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place
where they might be found.
[ ] 2. Defendant is evicted and excluded from the residence or any other permanent or temporary
residence where Plaintiff may live. Plaintiff is granted exclusive possession of the residence.
Defendant shall have no right or privilege to enter or be present on the premises.
[Xl 3. Defendant is prohibited from having ANY CONTACT with Plaintiff, 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: 602 Meadowbrook Road, Carlisle, P A.
[Xl 4. Defendant shall not contact Plaintiff by telephone or by any other means, including third
persons.
[ ] 5. Pending the outcome ofthe final hearing in this matter, Plaintiff is awarded temporary custody
of the following minor childlren: N/A.
[X] 6. Defendant shall immediately relinquish the following weapons to the Sheriffs Office or a
designated local law enforcement agency for delivery to the Sheriffs office:
Any firearms in his possession or control.
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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
resides and any other agency specified hereafter:
[X] 9. TillS ORDER SUPERSEDES [X] ANY PRIOR PFA ORDER AND [ ] ANY PRIOR
ORDER RELATING TO CHILD CUSTODY.
10. TillS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN
EFFECT UNTIL SEPTEMBER 12, 2002 OR UNTIL OTHERWISE MODIFIED OR
TERMINATED BY TillS 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 fme of up to $1,000.00 and/or up to six months in j ail.
23 Pa.C,S. ~ 6114. Consent of the Plaintiff to Defendant's retum 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. ~ 6113. Defendant is further notified that violation of this Order may
subjecthim to state charges and penalties under the Pennsylvania Crimes code and to federal charges
and penalties under the Violence Against Women Act, 18 U.S.C. ~~ 2261-2262.
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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
4 of this Order may be made without warrant, based solely on probable cause,
whether or not the violation is committed in the presence of law enforcement.
Subsequent to an arrest, the law enforcement officer shall seize all weapons
used or threatened to be used during the violation of this Order OR during prior
incidents of abuse. Weapons must forthwith be delivered to the 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 weapons are evidence of a
crime, in which case, they shall remain with the law enforcement agency whose
officer made the arrest.
(1) Defendant is prohibited from acquiring or possessing any weapons for
the duration of this order.
(2) Defendant may, upon the expiration of this order, request that the
sheriff return any weapons held pursuant to this order. The sheriff
shall determine if defendant is otherwise legally entitled to possess the
weapons. If the protection from abuse order has expired and
defendant is legally entitled to possess weapons, the sheriff shall
present an order to the court authorizing that the weapons be returned
to defendant. Otherwise, the sheriff shall notify defendant that he must
file a petition with the court seeking a return of the weapons, in which
case the court, upon petition, will schedule a hearing with notice to
plaintiff.
P.J.
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DALLAS MICHAEL CONRAD,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CNIL ACTION - LAW
: PROTECTION FROM ABUSE
DONALD EDWARD VERNET, JR.,
Defendant
:NO.
CIVIL TERM
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiff's name is: Dallas Michael Conrad
2. I am filing this Petition on behalf of myself.
3. N ame(s) of ALL person(s), including Plaintiff and minor children, who seek protection from
abuse: Dallas Michael Conrad
4. Plaintiff's address is: 602 Meadowbrook Road
Carlisle, PA 17013
5. Defendant is believed to live at the following address: 3461 Spring Road
Carlisle, PA 17013
Defendant's Social Security Number (if known) is: unknown.
Defendant's date of birth is: Unknown. Defendant is approximately 40 years old.
Defendant's place of employment is: self-employed.
6. Indicate the relationship between Plaintiff and Defendant.
[ ] Spouse [ ] Current / former sexual / intimate partner
[ ] Ex-spouse [ ] Parent! child
[ ] Persons who live or have lived like [X] Other relationship by blood / marriage
spouses Step-parent / steo-child
[ ] Parents of the same children
7. Have Plaintiff and Defendant been involved in any of the following court actions?
[ ] Divorce [ ] Custody [ ] Support [X] 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:
On Januaryl2, 2001, Brenda Lee Vernet, on behalf of herself and the plaintiff, filed a
Petition for Protection from Abuse against Donald Edward Vernet, Jr., in Cumberland
County, Pennsylvania, Docket No. 01-261. On or about February 22nd, 2001, Brenda Lee
Vemet filed a Petition to Vacate and Withdraw the PF A Order/Action. The Court vacated
the temporary Order and dismissed the action on February 28'h, 2001. A copy of the Order
to Vacate is attached hereto as Exhibit A.
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8. Has the Defendant been involved in any criminal court action? Yes. Prior to 1988,
Defendant was imprisoned for auto theft. Upon information and belief, Defendant has
recently been arrested for possession of firearms by a convicted felon.
If you answered Yes, is the Defendant currently on probation? Unknown.
9. Plaintiff and Defendant are parents of the following minor childlren: N/ A
10. If Plaintiff and Defendant are parents of any minor childlren together, is there an existing
court Order regarding their custody? N/ A
11. The following other minor childlren presently live with Plaintiff: N/ A
12. The facts of the most recent incident of abuse are as follows:
Approximate Date: Christmas 2000 Approximate Time: Place: 3461 Spring Road,
Carlisle, P A
At the end of December, 2000, Dallas was laying across the foot of his mother's bed when
Donald came into the room and told Dallas to get off of the bed. When Dallas would not,
Don picked Dallas up with both hands by the back of the shirt and threw Dallas against the
wall. Dallas then fell to the floor. Dallas left the house and got into his mother's car and
locked all the doors while his mother was inside the house calling the police. Donald came
out to the car and was yelling at Dallas from outside the car. Donald then told Dallas that
"if you come back to the house, you're done." While he was saying this, Donald was making
the form of a gun with his thumb and forefinger. Then, Donald opened up his jacket and
showed Dallas the gun he had in his waistband. After this incident, Dallas went to his
grandparents' house where he now lives. Donald drives by the house numerous times in one
day, on many occasions. He also calls Dallas and Dallas' aunt, Barbara Culhane, who lives
next door to the grandparents.
13. If the Defendant has committed prior acts of abuse against Plaintiff or the minor childlren,
describe these prior incidents, including any threats, injuries, or incidents of stalking, and
indicate approximately when such acts of abuse occurred:
Approximate Date: Approximate Time: Place:
The abuse has been continuous since Dallas was 5 years old. Dallas recalls incidents where
Donald grabbed him by the throat, threw him up against walls and furniture, and punched
and kicked him. The first time any abuse was reported to the police was when Dallas was
about 15 or 16 years old. He and Donald were arguing and Donald threw Dallas into a chair,
causing bruises to the back of his neck. Donald proceeded to punch Dallas and throw him
to the floor and kick him. On a number of occasions, Donald told Dallas that when he tums
18, he was going to "get" him. Dallas tumed 18 on February 23, 2001.
14. List the weapon(s) that Defendant has used or threatened to use against Plaintiff or the minor
child/ren: Gun
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15. IdentifY the police department or law enforcement agency in the area in which Plaintifflives
that should be provided with a copy of the protection order: Middlesex Police Department
16. There is an innnediate and present danger of further abuse from the Defendant.
CHECK THE FOLLOWING BOXES ONLY IF THEY APPLY TO YOUR CASE AND
PROVIDE THE REQUESTED INFORMATION
[ ] Plaintiff is asking the court to evict and exclude the Defendant from the following
residence:
[] owned by (list owners, ifknown):
[ ] rented by (list all names, ifknown):
[ ] Defendant owes a duty of support to Plaintiff and/or the minor children.
[] Plaintiff has suffered out-of-pocket financial losses 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
child/ren in any place where Plaintiff may be found.
[ ] B. Evict/ exclude Defendant from Plaintiff s residence and prohibit Defendant from attempting
to enter any temporary or permanent residence of the Plaintiff.
[ ] C. Require Defendant to provide Plaintiff and/or minor child/ren with other suitable housing.
[ ] D. Aware Plaintiff temporary custody of the minor child/ren and place the following restrictions
between Defendant and child/ren:
[X] E. Prohibit Defendant from having any contact with Plaintiff, either in person, by telephone,
or in writing, personally or through third persons, including but not limited to any contact
at Plaintiffs school, business, or place of employment.
[ ] F. ProhibitDefendant from having any contact with Plaintiff s relatives and Plaintiff's children
listed in this Petition, except as the court may fmd 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.
[ ] H. Order Defendantto pay temporary support for Plaintiff and/or the minor child/ren, including
medical support and [ ] payment of the rent or mortgage on the residence.
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[ ] 1. Direct Defendant to pay Plaintiff for the reasonable fmanciallosses 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.
[ ] K. Order Defendant to pay Plaintiffs reasonable attorney's fees.
[X] L. Order the following additional relief, not listed above:
Plaintiff is permitted to return to 3641 Spring Road, Carlisle when the Defendant will not be
present at a date and time to be agreed upon, and arranged by counsel for the parties, in order
to collect personal items and his automobile.
[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 will inform the
designated authority of any addresses, other than Defendant's residence, where Defendant
can be served.
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J Michelle L. AnderSon
Certified Legal Intern
HO S M. PLACE
R ERT E. RAINS
TERI L. HENNING
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
(717) 243-2968
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BRENDA LEE VERNET, : IN THE COURT OF COMMON PLEAS OF
for herself and on behalf of her minor child:
DALLAS MICHAEL CONRAD, : CUMBERLAND COUNTY, PENNSYL VANIA
Plaintiffs
vs. : NO. 01-261 CIVIL TERM
DONALD EDWARD VERNET, JR.,
Defendant : PROTECTION FROM ABUSE
ORDER TO VACATE
AND NOW, this$~ day of February, 2001, upon Plaintiff's Petition to Vacate Order and
Withdraw Action:
1. This matter is dismissed without prejudice.
2. Costs of this proceeding are waived.
3. The Temporary Protection From Abuse Order entered on January 12, 2001, is
hereby vacated.
By thjurt, ~
/5(1!,"{,n ;;/. J",y
Ke A. Hess, Judge
Distribution to:
Joan Carey
MaIyann Murphy
Attorneys for Plaintiff
MidPenn Legal Services
8 hvine Row "
Carlisle, PA 17013
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Exhi~:Lt A
Hubert X. Gilroy, Attorney for Defendant
Broujos & Gilroy
4 North Hanover' Street
Carlisle, PA 17013
FAXed and mailed to PSP
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VERIFICATION
I verify that I am the petitioner as designated in the present action and that the facts and
statements contained in the above Petition are true and correct to the best of my knowledge. I
understand that any false statements are made subject to the penalties of 18 Pa.C.S. 94904, relating
to unsworn falsification to authorities.
3-//- (}7
Date
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Dallas Michael Conrad
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DALLAS MICHAEL CONRAD,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
v.
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
DONALD EDWARD VERNET, JR,
Defendant
: NO.
CIVIL TERM
FINAL ORDER OF COURT
Defendant's Name: Donald Edward Vernet, Jr.
Defendant's Date of Birth:
Defendant's Social Security Number:
Names of All Protected Persons, including Plaintiff and minor children: Dallas Michael Conrad.
AND NOW, this day of , 2001, the court having jurisdiction over the
parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows:
[ ] Plaintiff s request for a fmal protection order is denied.
OR
[ ] Plaintiff s request for a final protection order is granted.
[ ] 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 or any other residence where
Plaintiff 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.
[ ] 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 the 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:
[ ] 4. Except as provided in Paragraph 5 of this Order, Defendant shall not contact the Plaintiff, or
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any other person protected under this order, by telephone or by any other means, including through
third persons.
[ ] 5. Custody of the minor children shall be as follows:
[ ] 6. Defendant shall immediately turn over to the SherifPs Office, or to a local law enforcement
agency for delivery to the SherifPs Office, the following weapons used or threatened to be used by
Defendant in an act of abuse against Plaintiff and/or the minor child/ren:
[ ] 7. Defendant is prohibited from possessing, transferring or acquiring any other weapons for the
duration ofthis order. Anyweapons delivered to the sheriff under Paragraph 6 of this Order or under
Paragraph 6 of the Temporary Order shall not be returned until further order of court.
[ ] 8. The following additional relief is granted as authorized by S 6108 of the Act:
[ ] 9. Defendant is directed to pay temporary support as follows:
[ ] 10. The costs of this action are waived as to the Plaintiff and imposed on Defendant.
[] 11. Defendant shall pay $
which are as follows:
to Plaintiff as compensation for Plaintiff's out-of-pocket losses,
OR
[ ] Plaintiff is granted leave to present a petition, with appropriate notice to Defendant to
requesting recovery of out of pocket losses, copies of all bills and estimates of
repair, and an order scheduling a hearing. No fee shall be required by the Prothonotary's office for
the filing of this petition.
[] 12 BRADY INDICATOR
1. [] The Plaintiff or protected person(s) is a spouse, former spouse, a person who cohabits
or has cohabited with the Defendant, a parent of a common child, a child of that person, or
a child of the Defendant.
2. [ ] This order is being entered after a hearing of which the Defendant received actual
notice and had an opportunity to be heard.
3. [ ] Paragraph 1 of this Order has been checked to restrain the Defendant from harassing,
stalking, or threatening Plaintiff or protected person(s).
4. [ ] Defendant represents a credible threat to the physical safety of the Plaintiff or other
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protected person( s).
OR
[ ] The terms of this order prohibit Defendant from using, attempting to use, or threatening
to use physical force against the Plaintiff or protected person that would reasonably be expected to
cause bodily injury.
[ ] 13. TillS ORDER SUPERCEDES [ ] ANY PRIOR PFA ORDER AND [ ] ANY PRIOR
ORDER RELATING TO CHILD CUSTODY.
14. All provisions of this order shall expire in one year, on
NOTICE TO THE DEFENDANT
VIOLATION OF TillS ORDER MAY RESULT IN YOUR ARREST ON THE
CHARGE OF INDIRECT CRIMINAL CONTEMPT WillCH IS PUNISHABLE BY A FINE
OF UP TO $1,000.00 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 12 P A.C.S.
~ 6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL
PENAL TIES UNDER THE PENNSYLVANIA CRIMES CODE.
TillS 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.
~ 2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE
TillS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS
UNDER THAT ACT. 18 U.S.c. ~~ 2261-2262. IF PARAGRAPH 12 OF TillS ORDER HAS
BEEN CHECKED, YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND
PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT, 18
U.S.c. ~ 922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR
AMMUNITION.
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NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over the plaintiffs residence OR any location where a
violation of this order occurs OR where a violation of this order occurs OR where the defendant may
be located, shall enforce this order. An arrest for violation of Paragraphs I through 7 of this order
may be without warrant, bllSed solely on probable cause, whether or not the viollltion is committed
in the presence of the police. 23 Pa.C.S. S 6113.
Subsequent to an arrest, the police officer shall seize all weapons used or threatened to be
used during the violation of the protection order or during prior incidents of abuse. The
shall maintain possession of the weapons until further order of this Court.
When the defendant is placed under arrest for violation of the order, the defendant shall be
taken to the appropriate authority or authorities before whom defendant is to be arraigned. A
"Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police officer
OR the plaintiff. Plaintiffs presence and signature are not required to file the complaint.
If sufficient grounds for violation of this order are alleged, the defendant shall be arraigned,
bond set and both parties given notice of the date of the hearing.
BY THE COURT:
Judge
Date
If entered pursuant to the consent of plaintiff and defendant:
DallllS Michael Conrad
Donald Edward Vemet, Jr.
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03/13/01 TUE 2}:55 FAX 717 240 6573
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CUlJIB CO PROTHONOTARY
141001
***************************
*** MULTI TN REPORT ***
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TXlRX NO
INCOMPLETE TX/RX
TRANSACTION OK
2494
[ 01] 9p2405331
[ 04192490779
CENTRAL PROCESS
PSP
ERROR
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MAR 13 200ttb
v.
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNT, PENNSYLVANIA
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
DALLAS MICHAEL CONRAD,
Plaintiff
DONALD EDWARD VERNET, JR.,
Defendant
: NO. 0 I - I '/ <10
CIVIL TERM
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 maybe entered against you granting the relief
requested in the Petition. In particular, you may be evicted from your residence and lose other
important rights. Any protection order granted by a court may be considered in subsequent
proceedings under Title 23 (Domestic Relations) of the Pennsylvania Consolidated Statutes,
including child custody proceedings under Chapter 53 (relating to custody).
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A hearing on the matter is scheduled for the L day of tf\.....-'- 2001, at' M., in
Courtroom p at the Cumberland County Courthouse, Carlisle, Pennsylvania,
You MUST obey the Order that is attached until it is modified or tenninated by the court
after notice and hearing, If you disobey this Order, the police may arrest you. Violation of this order
may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to
$1,000.00 andlorup to six IUOnthB in jail under 23 Pa.e.S. ~ 6114, Violation may also sUbjectYOll
to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law , 18
U .s.c. ~ 2265, tins Order is enforceable anywhere in the United States, tribal lands, U.S. Tenitories
and th,e 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_Sc. 9~ 2261-2262.
YOU SHOULD TAKE TIllS PAP;ER TO YOUR LA WYERAT ONCE. YOU HAVE
THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT TIlE HEARING. TIlE
COURT WILL NOT, HOWEVER. APPOINT A LAWYER FOR YOU. IF YOU DO NOT
HAVE A LA WYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE
SET FORTH BELOW TO FIND OUT WllERE YOU CAN GET LEGAL HEll'. IF YOU
CANNOT FIND A LAWYER, YOU MAY HAVE TO PROCEED WITHOUT ONE.
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-01440 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CONRAD DALLAS MICHAEL
VS
VERNET DONALD EDWARD JR
KENNETH GOSSERT , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within NOTICE OF HEARING & ORDER was served upon
VERNET DONALD EDWARD JR
the
DEFENDANT
, at 0015:25 HOURS, on the 13th day of March
at CUMBERLAND CO. SHERIFFS' OFF. 1 COURTHOUSE SQUARE
, 2001
CARLISLE, PA 17013 by handing to
DONALD E. VERNET, JR.
a true and attested copy of NOTICE OF HEARING & ORDER together with
TEMPORARY PROTECTION FROM ABUSE ORDER,
PETITION FOR PROTECTION FROM ABUSE
and at the same time directing His attention to the contents thereof.
Additional Comments
DEFENDANT STATED THAT THE CUMBERLAND COUNTY SHERIFFS'
DEPT. ALREADY HAS ALL OF HIS WEAPONS FROM A PRIOR PFA
WITH CONFISCATION.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
.00
.00
10.00
.00
28.00
So Answers:
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R. Thomas Kline
03/14/2001
me this ~ ~.!&-
day of
Sworn and Subscribed to before
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othonotary
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APR 0 5 2001t1/
DALLAS MICHAEL CONRAD,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
DONALD EDWARD VERNET,
Defendant
: NO. 01-1440
CIVIL TERM
ORDER OF COURT
AND NOW, this ~ ~y of April, 2001, upon Plaintiff's Petition to Vacate Order and
Dismiss Action, it is hereby ordered and directed as follows:
1. Plaintiff s Petition for Protection From Abuse is dismissed without prejudice.
2. The Temporary Protection From Abuse Order entered on March 13, 2001, is
hereby vacated.
By the Court,
e E. Hoffer PJ.
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DALLAS MICHAEL CONRAD,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
; PROTECTION FROM ABUSE
DONALD EDWARD VERNET,
Defendant
: NO. 01-1440
CIVIL TERM
PETITION TO VACATE ORDER AND DISMISS ACTION
Plaintiff, Dallas Michael Conrad, by and through his attorneys, the Family Law Clinic,
hereby requests that the Court vacate the Temporary Protection From Abuse Order entered on
March 13, 2001 in the above-captioned case, and dismiss this action. In support of his Petition,
Plaintiff avers as follows:
1. Plaintiff filed a Petition for Protection From Abuse with this Court on March 13,
2001. A Temporary Protection From Abuse Order was issued by this Court on
March 13,2001, scheduling a hearing for March 23,2001, at 9:30 a.ill. before The
Honorable George E. Hoffer.
2. The parties are in the process of reconciling their differences.
3. Plaintiff does not want to pursue this action and requests that the Temporary
Protection From Abuse Order entered on March 13, 2001, be vacated and that the
Petition for Protection From Abuse be dismissed without prejudice.
4. On Monday, April 2, 2001, the Family Law Clinic contacted the office of Hubert
Gilroy, Esquire, counsel for Defendant, and asked whether he would concur with
this Petition. Mr. Gilroy's secretary informed the Family Law Clinic on Tuesday,
April 3, 2001, that Mr. Gilroy does not oppose this Petition.
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WHEREFORE, Plaintiff requests that the Court vacate the Temporary Protection From
Abuse Order entered.on March 13,2001, and dismiss this action without prejudice.
Afr;l ?) ZOo \
Respectfully submitted,
jj;ijJJJL Y r2udiWl--
VMichelle L. AndeRton
Certified Leg:ntern /
~M. PLACEi,./'
ROBERT E: RAINS
TERI L. HENNING
Supervising Attorneys
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlile, PA 17013
(717) 243-2968
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VERIFICATION
I verify that I am the Plaintiff as designated in the present action and that the facts and
statements contained in the attached 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. S 4904,
relating to unsworn falsification to authorities.
~aU'a- /It ~~
Dallas Michael Conrad
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Date
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DALLAS MICHAEL CONRAD,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
DONALD EDWARD VERNET,
Defendant
: NO. 01-1440
CIVIL TERM
CERTIFICATE OF SERVICE
I, Michelle L. Anderson, hereby certify that I am serving a true and correct copy of the
Petition to Vacate Order and Dismiss Action for Plaintiff, Dallas Michael Conrad, on the
following person, counsel for Defendant, by depositing a copy of the same in the United States
mail, postage prepaid, this 5th day of April, 2001:
Hubert X. Gilroy, Esquire
Broujos & Gilroy, P.C.
Attorneys at Law
4 North Hanover Street
Carlisle, Pennsylvania 17013
v~ ~ IIAJ4;M12--
Michelle L. AnderS'Cln
Certified Legal Intern
THE F AMIL Y LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968