Loading...
HomeMy WebLinkAbout01-1794 FX CORlNNE RODRIGUEZ, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF VS. : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. 2001- rt{l! . CIVIL TERM KOREY KENNY ATTA WOOTEN, DEFENDANT : PROTECTION FROM ABUSE AND CUSTODY NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A HEARING ON TIDS MATTER IS SCHEDULED ON 41VU-/ '3 ,DIl,AT ~," 3 () at., IN COURTROOM NO. .;3 OF tHE CUMBERLAND COUNTY COURmOUSE, 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 subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six months injail under 23 Pa.C.S. g6ll4. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. g2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel oJltside 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. g 2261-2262. You should take this paper to your lawyer at once. You have the right to have a lawyer represent you at the hearmg. The court will not, ho:wever, appoint a lawyer for you. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to fmd out where you can get legal help. If you cannot find a lawyer, you may have to proceed without one. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE, CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717)249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Corinne Rodriguez : IN THE COURT OF : COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYL VANIA Plaintiff v. : No. Korey Wooten Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE : AND CUSTODY TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Korey Wooten Defendant's Date of Birth is: February 9,1977 Defendant's Social Security Number is: 253-29-7432 Name(s) of All protected persons, including Plaintiff and minor children: I. Corinne Rodriguez AND NOW, on 27th Day of March, 2001 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: Plaintiff's request for a temporary protection order is granted. 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. 2. Defendant shall be evicted and excluded from the residence at: 157 South Enola Drive Enola, P A 17025 or any other permanent or temporary residence where Plaintiff or any other person protected under this Order 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 of Plaintiff or any other person protected under this Order. --"' .,." - ~ " - ~ . ~,~ -" 3. Pending the outcome of the final hearing in this matter, Plaintiff is awarded temporary custody of the following minor child/ren: 1. Jasmine KayIa Rodriguez 2. Jacob Kyle Rodriguez 3. Joshua Lalib Rodriguez Until the final hearing, all contact between Defendant and the child/ren shall be limited to the following: The parties shall share legal custody of the children. Plaintiff shall have primary physical custody of the minor children. Defendant shall have partial custody of the minor children at times and places agreed upon by the parties. The local law enforcement agency in the jurisdiction where the child/ren are located shall ensure that the child/ren are placed in the care and control of the Plaintiff in accordance with the terms of this Order. 4. The following additional relief is granted: The Cumberland County Sheriff's Department shall attempt to make service at 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 Defendant by mail. 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 fmds that Defendant has committed an act of abuse or has engaged in a pattern or practice that indicates risk of harm to Plaintiff. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. Defendant is to refrain from harassing Plaintiff's relatives. 5. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: The East Pennsboro Police Department 6. The sheriff, police or other law enforcement agencies are directed to serve the Defendant with a copy of the Petition, any Order issued, and the Order for Hearing without prepayment of costs. The Petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. The Prothonotary is directed to file this Petition and Order without prepayment of costs. ~ '-' '- - "" ' "I~'I 7. THIS ORDER APPLIES IMMEDIA TEL Y TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL SEPTEMBER 27, 2002 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months in jail. 23 Pa.C.S. ~6114. Consent of the Plaintiff to Defendant's return to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. ~6113. Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. ~~2261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiffs residence OR any location where a violation of this order occurs OR where the defendant may be located. If defendant violates Paragraphs I through 3 of this Order, defendant shall be arrested on the charge ofIndirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence of law enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriffs office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this court, unless the weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. ....... Distribution to: MidPenn Legal Services Faxed & Mailed to PSP '____,.'.,n" . i", ,_.y ~Iimi~~~cil<i:Jil*!I1iill.~Miill..'ili;;]lii4cl..,;i)k<""'i;;ff."o',,,icieJM~.t~~""~' -o,~"",,"~...~ltil1~iili.OOll!m'--i! L Jll__,,~ . ~,~". -~ --'^ ~,~-,,",~ ,~,>,~".-,. ~"", "-'~~" ,'-.~ "1' "'"1 \ ''''i.pA \!\" ";/\ I/\'.J' ". ,."':" ('If' . l ~ <", ,f'".~~--,g~tf',J\ Id ). \ \lfYj:J C".';! I'. ,..... . ......1 ., I\.,. ~ '~'1 .~.. ~,\,.!, L'l d\J~~ \ 0 '::t' 'V "'-- 'lj'cllC;,::Ji"-'_ f\ 1 ,,{'~ r ~', :;:::A:\'::\\.Y-'" "<.J; , _, ~,,>. _~ ~V" '^. ~.~~~_~ili'J>,~ ~~"' ,~ ~ - .-~ -'"" ~; '-';;it PFAD Number: SXI219207L Corinne Rodriguez Plaintiff : IN THE COURT OF : COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v. ; No. ol-nCJ'l (J;Jd /',;U.4..... : CIVIL ACTION - LAW : PROTECTION FROM ABUSE : AND CUSTODY Korey Wooten Defendant PETITION FOR PROTECTION FROM ABUSE I. Plaintiffs name is: Corinne Rodriguez 2. I, (the Plaintiff), am filing this Petition on behalf of: - myself 3. Name(s) of ALL person(s), including minor children, who seek protection from abuse. a. Corinne Rodriguez 4. Plaintiffs Address is : 157 South EnoIa Drive, EnoIa, P A 17025 5. Defendant's Name is: Korey Wooten 6. Defendant is believed to live at the following address: 40 West Main Street, Mechanicsburg, P A 17055 7. Defendant's Social Security Number is: 253-29-7432 .~. ., ~ "'n't. "i('j 8. Defendant's Date of Birth is: February 9, 1977 9. Defendant's Place of employment is: Fry Communications, Mechanicsburg 10. Defendant is an adult. 11. The relationship between the Plaintiff and the Defendant is: Current or former sexual/intimate partner 12. The defendant has been involved in a criminal court action. 13. Plaintiff and Defendant are the parents of the following minor childlren: a. Jasmine K. Rodriguez Age:3 Child's address is: 157 South EnoIa Drive, Enola, P A 17025 b. Jacob K. Rodriguez Age:19 months Child's address is: 157 South Enola Drive, Enola, P A 17025 c. Joshua K. Rodriguez Age:5 months Child's address is: 157 South Enola Drive, Enola, P A 17025 14. Plaintiff is seeking an Order of child custody as part of this petition. The following is a list of the children and where they have live for the past 5 years: a. Jasmine Kayla Rodriguez For the past 5 years, this child has lived with: Plaintiff, Maternal Grandparents-Carlisle Pike, Mechanicsburg, Pennsylvania- Birth to Nov. 98 Plaintiff- Peachwood Place Apts, Waycross, Georgia- Nov. 98 to Aug. 99 Plaintiff, Maternal Grandparents, and cousin- 1360 Y orktowne Road, Mechanicsburg, Pennsylvania- Nov. 98 to Feb. 00 ''', -1 Plaintiflf and Defendant-14191/2 Carswell Ave., Waycross, Georgia-Feb. 00 to July 00 Plaintiff, Maternal Grandparents, and cousin- 1360 Y orktowne Road,Mechanicsburg, Pennsylvania- July 00 to Dec. 00 Plaintiff and Defendant-157 S. Enola Drive,Enola, Pennsylvania- Dec. 00 to Present b. Jacob Kyle Rodriguez For the past 5 years, this child has lived with: Plaintiflf- Peachwood Place Apts, Waycross, Georgia- Nov. 98 to Aug. 99 PIaintiflf, Maternal Grandparents, and cousin- 1360 Y orktowne Road, Mechanicsburg, Pennsylvania- Nov. 98 to Feb. 00 Plaintiff and Defendant-14191/2 Carswell Ave., Waycross, Georgia- Feb. 00 to July 00 PIaintiflf, Maternal Grandparents, and cousin- 1360 Y orktowne Road,Mechanicsburg, Pennsylvania- July 00 to Dec. 00 Plaintiflf and Defendant-157 S. Enola Drive,Enola, Pennsylvania- Dec. 00 to Present c. Joshua Lalib Rodriguez For the past 5 years, this child has lived with: Plaintiff, Maternal Grandparents, and cousin- 1360 Y orktowne Road,Mechanicsburg, Pennsylvania- July 00 to Dec. 00 Plaintiflf and Defendant-157 S. EnoIa Drive,Enola, Pennsylvania- Dec. 00 to Present 15. The facts ofthe most recent incident of abuse are as follows: On or about March 8, 2001, Defendant grabbed the phone from Plaintiff and choked her with both hands causing her to have a problem breathing. When Plaintiff was able to get away, she ran to her room and locked the door. Defendant attempted to break the lock with a screwdriver to get into the room. When PlaintiffIeft the bedroom, Defendant followed her aronnd the house and back to the bedroom. Defendant poked the screwdriver at a bassinette causing dents in it, knelt down beside Plaintiff who was on the floor, hit the floor aronnd her with the screw driver, and threatened her that he was angry enough to put the screw driver through her and kill her causing her to fear for her safety. Plaintiff phoned the police when Defendant left for work. Defendant was charged with terroristic threats and simple assault. Plaintiff suffered injuries including pain and bruising about her neck. 16. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor child/ren, (including any threats, injuries, or incidents of stalking) are as follows: In or about 1997, Defendant slapped Plaintiff across the face scratching her face with his ring. Defendant was arrested and placed in a Georgia prison for approximately one week. 17. The police department( s) or law enforcement agencies that should be provided with a copy of the protection order are: The East Pennsboro Police Department 18. There is an immediate and present danger of further abuse from the Defendant. 19. Plaintiff is asking the court to evict and exclude the Defendant from the following residence: 157 South Enola Drive EnoIa, P A 17025 Owned By: Eric and Stacey Blaschak Rented By:Korey Wooten and Corinne Rodriguez 20. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or minor child/ren in any place where Plaintiff may be found. b. Evict/exclude Defendant from Plaintiff's residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff. c. Award Plaintiff temporary custody of the minor child/ren and place the following restrictions on contact between Defendant and child/ren: The parties shall share legal custody of the children. Plaintiff shall have primary physical custody of the minor children. Defendant shall have partial custody ofthe minor children at times and places agreed upon by the parties. d. Order Defendant to pay the costs of this action, including filing and service fees. e. Order the following additional relief, not listed above: ~~ '-I"" Defendant shall not damage or destroy any property owned jointly by the parties or solely by the Plaintiff. Defendant shall not harass Plaintiff's relatives. Defendant shall pay $250.00 to one of MidPenn Legal Service's funding sources as reimbursement for litigation in this case. f. Grant such other relief as the court deems appropriate. g. Order the police or other law enforcement agency to serve the Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. Date: -3/27/01 / / Respectfully submitted, ct~r:c;tPJamti1I MID-PENN LEGAL SERVICES 8 Irvine Row Carlisle, P A 17013 Distribution to: MidPenn Legal Services Fax and Mail PSP " :. t-f, ",,"'" ~ " , , ~~, . < \ 1~ VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subjectto the penalties of1S Pa.C.S. ~4904, relating to unsworn falsification to authorities. Dated: l 3-~&-O I (~~MQ/0'1^'~<'r Corinne Rodriguez, Plaintiff ...'".. ~ ~~]li)j~ru~;:i~i;;t~fliJli,j_~.iI~~I;;I!lil&j~~,jb#:""';"N,,",li,~,;;.lli'd~,,iliilgjji!l~"~";~ii.ilIil!lllillli;Ml;Blr '~>"""''''!lI-___- ~""";"~~';""^" .",,-'--'><i. liiiif~, 'JU -- 31;),7/01 Cod. ~ ~ -tv)-!' ~<. 3/.:27/0/ pd ,~ jJPIt 3!:J)/t71 PH v0 ~. c~'" ~o/-;/4fe/~; 5. /'. / t .T.c_,,~, ,__,., '_~" __",'.,',*"_,_~~~"",,,~,,__,~_~,__ .", ","_"." ,~,__ '__',<~~','~"_ , ,__ _~_~H<~~_. ~_~. ~\. ",,\;,> .., . '" l>' v, .%- 0 c::> 0 C <,' -., -0 '" ;::: rnfn -''IT, ~S~~.i '" " r,) '. r- -..... ~~ ":ED [::e; ,~-;) ,..i:> }; 7Cj -, .,~: ':~o :'~:;..c5 5>C 0) (511J :2-: :r=~ :::< 0 '0 :0 -< L .s. - C. fJ '1:2 :2.J~,-"l. -I.....J 1~,'..1i~'..' 03/~/Ol 'TIlE 16: 22 FAX 717 240 6573 cilliB CO PROTIIONOTARY - 141001 ************$************** *** MULTI TN REPORT *** *************************** TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2530 [ 01l9p2405331 [ 03]9p2438026 [ 04]92490779 CENTRAL PROCESS LEGAL SERVICES PSP ERROR , ,- ~ OfFICE Of THE PROI'H(X>DTAf!Y CUMBERLAND caJNl'Y OOURTIiOOSE ONE CCXJR'I'HOOSE SQUARE CARLISLE. PA. 17013-3387 (717) 240-6195 FAX (717) 240-6573 VIA TELECOPIER '00: PA STATE POLICE Ce~ P~oCeSSi~j I ~ p. LJI' I S;-e., (I,'C.W FAX #: 717-249-0779 ~: CURTIS R. LONG RE: I'FA ORDERS MESSAGE : -- ---- -- ~ r-o. OF PAGES (IN'""....worr-a:; COlfER SHEET) '!his IIHJ7'J' js inl1lrl:.'lai ally tix tte u;e of tte itdiviO.el cr aJt:,ity trJ ..rom is is cdh. I, .nI ~ <mtdin i.nfcJllretim ttet is ~. cmfid;ntial at! e<aq:t fI.1:ro (j;<rl,..."JrP.1Il'Ja" Wli........1.. llw.t:,H tl-e mrt:r of. this II :: 'JT is rot 1;1:e in~ ~pi""1t. }oW cu;e t'ereI:y rot:i..fim ttat enj dis;Elniretid.f;. d:is\:ritl.Jt:i cr o;wirg cf. this (Dlf1U'Iicatim is st:ricUy (Zdrlbita1. If}oW I<M:' m;ei..w Uus ___,_~,_ ,~_ nl== rrt-ifit '''' intraiiate1v tv \Bled1'nl a-n urtum tie trigirBI. II";s.5ElJ'! to L.G ,,~ Corinne Rodriguez : IN THE COURT OF : COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff v. : No. 01-1794 Korey Wooten Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE : AND CUSTODY FINAL ORDER OF COURT Defendant's Name is: Korey Wooten Defendant's Date of Birth is: February 9,1977 . Defendant's Social Security Number is: 253-29-7432 Name(s) of All protected persons, including Plaintiff and minor children: 1. Corinne ~o . glez 'l/) 0 , \0, AND NOW, this the court having jurisdiction over the parties and the suoje t-matter, it is ORDERED, ADJUDGED and DECREED as follows: Upon agreement of the parties for the entry of a consent order, this order will be entered without any admission of liability by the defendant and without a finding of abuse by this court: Plaintiffs request for a fmal 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 at: 157 South Enola Drive Enola, P A 17025 or any other residence where Plaintiff or any other person protected under this Order may live. Exclusive possession of the residence is granted to Plaintiff. Defendant shall have no right or privilege to enter or be present on the premises of Plaintiff or any other person protected m~'= under this Order. 3. Custody of the following minor children: 1. Jasmine KayIa Rodriguez 2. Jacob Kyle Rodriguez 3. Joshua Kaleb Rodriguez shall be as follows: . -See Attached Custody Order 4. The following additional relief is granted as authorized by ~61 08 of the Act: Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. Defendant is to refrain from harassing Plaintiff's relatives. The court costs and fees are waived. S. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: The East Pennsboro Police Department 6. THIS ORDER SUPERSEDES: 1. ANYPRIORPFAORDER 2. ANY PRIOR ORDER RELATING TO CHILD CUSTODY 7. All provisions of this order shall expire on: October 13, 2002 NOTICE TO THE DEFENDANT , '." ..~""'~ ~- 'j ill '"' VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S. ~6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENAL TIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. ~2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C ~~2261~ 2262. IF THE BRADY INDICATOR PARAGRAPH APPEARS IN THE ORDER, YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT, 18 U.S.C. ~922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION. NOTICE TO LAW ENFORCEMENT OFFICIALS The police who have jurisdiction over the plaintiffs residence OR any location where a violation of this order occurs OR where the defendant may be located, shall enforce this order. An arrest for violation of Paragraphs I through 3 of this order may be without warrant, based soley on probable cause, whether or not the violation is committed in the presence ofthe police. 23 Pa.C.S. ~6113. Subsequent to arrest, the police officer shall seize all weapons used or threatened to be used during the violation of the protection order or during prior incidents of abuse. The Cumberland County Sheriff shall maintain possession of the weapons until further order of this Court. When the defendant is placed under arrest for violation of this order, the defendant shall be taken to the appropriate authority or authorities before whom defendant is to be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police officer OR the plaintiff. 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. "-1-1 , , '. b Z' j ~''''''' -'/::'\, If entered pursuant to the consent of Plaintiff and Defendant: C,__ ~~+ an Carey Attorney for Plaintiff MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, P A 17013 Distribution To: MidPenn Legal serV~ges:J COf! ~D(tt\lIrl qlv(J} Fax and Mail to PSP I 0 Korey Wooten, Defenda ~~4il*!4<il;:!~IliiIfjif41I.!i;&;J~Y~l!tHi'__;:;-\."""'W-H'~'Z'ill'&"'i!jd~"-<Iill'41i1_:iIIl~@i"""'''''''''~ ',- ...."'WILliiil~".;.~. .'~ ~BlilI!!t~~ _r \/J'..",i/\! I (",.,~ -. ; 1',1"'>.",-".." \'i\'~i\'ll..Jrl '-'.1 \i !! )' I "~,~~!.'~'!n" , 'I j,_, 6U .,", . ~~ .~ I " C,;J 'j i_;i --''-' ), ;.I.::,;,.JIlLlUI U ,L,. .c'"'' ~ < " ~, <"'. ~, -,,- ~ -,,~'" '. ,,'~. ~,. .~ -. .~ ,. ;~ CORINNE RODRIGUEZ, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 2001-1794 CIVIL TERM KOREYKENNYATTA WOOTEN, DEFENDANT : PROTECTION FROM ABUSE AND CUSTODY CUSTODY ORDER AND NOW, this _ day of April 2001, upon consideration of the parties' Consent Agreement, the following Order is entered with regard to custody of the parties' children: Jasmine Kayla Rodriguez, Jacob Kyle Rodriguez, and Joshua Kaleb Rodriguez. 1. The plaintiff, Corinne Rodriguez, hereinafter referred to as the mother, and the futher, Korey Wooten, hereinafter referred to as the father, shall share legal custody of the children. 2. The mother shall have primary physical custody of the children. 3. The father shall have partial custody of the children at times and places agreed upon by the parties. 4. The parties shall share custody of the children on the holidays at times and places agreed upon by the parties. 5. The mother and father shall notify each other of all medical care the children receive while in that parent's care. Each parent will notify the other immediately of medical emergencies which arise while the children are in that parent's care. 6. Neither party shall do anything which may estrange the children from the other parent, or injure the opinion of the children as to the other parent or which may hamper the free and natural development of the children's love or respect for the other parent. This Custody Order extends beyond the expiration of the Protection From Abuse Order in the above captioned case and remains in effect pending further order of court regarding custody. By the Court, If entered pursuant to the consent of Plaintiff and Defendant: orey K. Wooten, Defendant Pro Se Joan Care and Maryann Murph' Attorneys for Plaintiff MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, P A 17013 ~-~"l., " ~ ~:~,~~_~~i'''''M<rt,*",~'':''l"04'-oH~\l;'~M;;':~~'''''"''--'j-(i1i1lfl_''''''y' ')<:1 )OU'I'J;t 1::t5'XJId '\ Pdll:Old f w'!vt! ~prJ J1fd O),'C , ':;")"J/I'}J5 I '3 b~lJ/ TIll d 'j'') 'S", J~d .;1.~m.J~~,iJ]j,l,mJ ,',"'<-<_~n,_>"","","_,,"~"" "~~_'''''''',,I' "," " _ ~,.,' .',..A",._", ...'<",. ,~" " ~ ,,-\, "..}~,\ j C'~ ii- rj" , \''''\'",!\\,\,,)l\: \l C ;JJ<r:h'~: \'- i''':~-r-:(~~vl,~(Y) S8 :s J)::,'--J_~:~ " . ::d \" !", r.,','.', ~ l c;.:J':l D ,"",", ' ~ " ....""""~ -"r''''-~'~'''' ~ -'1 I W~ ^ ~~ ~t ,_.' - 1.1, _;"'__'h_ -"llililllltIU.> 04/16/01 BON 14:48 FAX 717 240 6573 CUMB CO PROTHONOTARY ~001 *************************** ... MULTI TN REPORT ... *************************** ,- TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2572 01]9p2405331 03]9p2438026 04]92490779 CENTRAL PROCESS LEGAL SERVICES PSP ERROR ^ OFFICE 01' THE PROn-ICNJTARY CUMBERLAND o::xJNTY muRTHOOSE ONE COORTHCXJSE SQUARE CARLISLE. PA. 17013-3387 (117) 240-6195 FAX (717) 240-6573 V I ATE LEe 0 PIE R TO: PA STATE POLICE. ~tf~tlul P~ouu.~ f/1,I'./...!. FAX ~: 717-249-0779 '" ~: CURTIS R. LONG RE: PI'A ORDERS MESSAGE : J () 00. OF PAGES I INCLUDING COVER SHEET) This il!5t"J' is intB1::lErl cnly :Il::r tI"e \.Q] of tte in:li.v:idHl. cr Entity b;J W1id1 is is n}l. : 1, a-d ImY crnl1rin :lnfi:matjm. that is p:ivileg!d, anf:idntia1. al:I. exarp: fr.tm ";.....l""'wel.J"Cl3:' >rr>l;n'hlp JaoJ. [f tI"e m:rtt af this" V' is rot tiE intan:o m:ipimI;, }'OJ are I'eI.'Ibt rotifiErl lh:lt all (\is;laniret.iC11, distriI:ut;iaI or cq::yirg a this amnnicatjOl is strictly prlUbita1. If}O.l taI.e m:6.va:l t,Iu.s <Xnll\l"\i\'.:r,j(n in ~. ple!I$e rot:i1'y lB inrreiiatBly l:7f ~:m .nl tetum tie .;r;igirel ,,_ ""g' to l.S at o...L.....~, " ...:_ ....._r...... .. . . ~ I II "~ .,', illi. " ~' SHERIFF'S RETURN - REGULAR CASE NO: 2001-01794 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND RODRIGUEZ CORRINE VS WOOTEN KOREY KENNYATTA ROBERT L. FINK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within PFA & CUSTODY, NOTICE OF was served upon WOOTEN KOREY KENNYATTA the DEFENDANT , 2001 , at 0018:30 HOURS, on the 4th day of April at FRY COMMUNICATIONS MECHANICSBURG, PA 17055 CHURCH AVE BLDG 2 KOREY WOOTEN by handing to a true and attested copy of PFA & CUSTODY, NOTICE OF together with HEARING & ORDER, TEMPORARY PROTECTION FROM ABUSE ORDER and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 5.58 .00 10.00 .00 33.58 Sworn and Subscribed to before me this ;(,.'f~ day of ~i;2.vo/ ~ A.D. (J~. . (] /hJ Ie.-, ~ j'I/rothonotary 1 So Answers: ~~~~~t R. Thomas Kline 04/06/2001 By: ~~:;t:)c9v eputy Sher' '" . ()"::; 1,.,,:,... ~ . Corinne Rodriguez ~ ,,' h ~,_ ~ Plaintiff v. Korey Wooten Defendant "1 "' . ~'. '",.--, i^ '['_I ~ -::,'":,.-',~';., -,_-''., :i"~'i,-,+:-':'-;,,, >c''''_;- '--~~'., ~,~" : IN THE COURT OF : COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA : No. 01-1794 : CIVIL ACTION - LAW : PROTECTION FROM ABUSE : AND CUSTODY ORDER TO VACATE AND NOW, this: 19th Day of November, 2001, 1. This matter is dismissed without prejudice. 2. Costs of this proceeding are waived. 3. The Final Order (Filed on Apr 16, 2001) is hereby vacated. Distribution to: MidPenn Legal Services Faxed & Mailed to PSP c.'p I L.5 .~ t~raYr esident Judge , .rrj',*(lJrfPii~i~__~:tIl!Mi~~~';~.'i#'-:!~;,,:oj;l~rtW-l@~~~"...i~'- ...."liiilll'~ ~-;r""""'-" " ~ VlNVAlASNN3d '!'II{lrt'-' (-,;"c.,-" t"'"\ti'ftf"ltj /\..... \i. r::".-'j '.; \:';:' 1>-,--':--1" L'll J1"..- or :01 :,4~t C "'I" 1(" -.'" I ~l' i i i " '4 _ '.I ' r;f~f",~~Lk-~,~",~,n~"'_"'~i_~~,Il~LJ;[J-\i~J~~,I'-!,:~'" ',0" ""'~1-,-Y,_-o '1_'''!_'''- ,~~_ ,- "<,,,,_ ~,,~ _~,,'~ .0N ,___ , Il!''''- ~""_ ~"_'- .j"',",'.'\'-Jj)"--:;.';:",,, -'c""~ '----" "" ", ~ , ,I"",,~-,.; . o' " , ," '_:"" ~ _ > " ,J., ", ,-.,-LI,."'-;,, ,.,~, .'-'=',",,"~',', "-.'-,,_ --.",,~ '" ..c-."""...::;, " " Corrine Rodriquez, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 2001-1794 CIVIL TERM Korey Wooteu, DEFENDANT : PROTECTION FROM ABUSE PETITION TO VACATE ORDER AND WITHDRAW ACTION Plaintiff, Corrine Rodriguez, by and through her attorney, David Lopez of MidPenn Legal Services, requests that the Court vacate the Final Protection Order in the above- captioned case and that the action be withdrawn on the grounds that: 1. A Petition for Protection From Abuse was filed and a Temporary Protection From Abuse Order was issued by this Court on March 27, 2001, scheduling a hearing for April 3, 2001, before Judge Hoffer in Courtroom No. 3 of the Cumberland County Courthouse. A Final Protection Order was entered on April 16, 2001, by agreement of the parties. 2. The parties are in the process of reconciling their differences. 3. Plaintiff requests that the Final Protection Order be vacated and the action withdrawn without prejudice to her. WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate the Order, and that the action be withdrawn without prejudice to Plaintiff. David Lopez, Attorney ~ r PI . MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 - .', 'J ", ,,-'I,," '" ~.' ",Ie 'I, ,,-'.i ,'.~ 0'"",'.;,.. ., + ,,' '~, ',. '<"-.'1' \ 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. ~4904, relating to unsworn falsification to authorities. Dated: /1 d9/()( .o!,\ ~.,~...., d.~" ", ~--;r. ril~!i'.tIiJl~~~~i'.v+:if-r.'M'1;,ii"-'Jli~~"i~~~g_;tlt;~Jai ~'"_ o!.r- "1- i}' ~,r),"-,_~~;, ;_,~ :~, JliJT'''''''_ ".I JJ~J~~",..",.,,,.,,, " c~",~," ',,~,_.' ,., ", ^, ",~, , ' . -" ,'__.~ _~ ~~~. .~ ~-~. Iii "~.~'~"""'Jd_!liliIlW'~ -,."" '~d.' ',,_~~. _."",'_p,," ,'~ '.r . ..;",. ;:Rn~: ~?-l (f) '7~~ ~~~ Zo ;D.c z =< c; C:';' C ", ~ ~-,; ::-") ~::": "..- '0-"_.1 -;:,:.;,",; ~'::4 ~,- ~' :D -< co- -:,.) .... ~ ~"'" ,":-'-' I -1~L " ' ~OII;i;t.ij~il..jlillfiIIUmL , 12/05/01 WED 11:10 FAX 717 240 6573 CUMB to ~R~THONOTARY 1iZI001 *************************** 03*. IlfULTI TN REPORT *** *************************** TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2889 [ 03]9p2405331 [ Oll 9p2490779 [ 04]92438026 CP PSP LS ERROR . , OFFICE OF '!HE PROIHCNJTAlly ClJMBERfAND CXXlNIY CDUR'IHOOSE OOE OXJR'I1iCUSE ~ CARLISLE, PA. 17013-3387 (717) 240-6195 FAX (717) 240-6573 V I AtE L E COP I E R 'IO: PA STATE POLICE . (!e,.;f.tI' fJ"',e US. 1M,/). I..!. FAX .: 717-249-0779 .~ FRQol : CURTIS R. LONG RE: PFA ORDERS MESSAGE : .3. l'KJ. OF PAGES lIN':r..lJDING CCNER SHEET) . '!his ~ is iute d'rl ally frr tte l.SC of tte :in:liv:idal cr r;ntity lD W'l:ich :is :is ",110 ::.l, irtl <ref anlliin :irlfum'at:icn I:hrt: :is p:iv.i.J.e1,;d, =U':id31tial irtl el<e1'[:t 6:on "';.....1,..., '"' tnb" "!.::t'H...nl,. Ja.l. [f tte ~ of this ~ :is not t1-e intErl:B:1 m::ipiatt:, 'tOJ are ~ rutifit;d ttat dV d.i.ssetTtimticn, d:isIriIJ.J1jrn cr a:p{irg af tii:is o:J1ITU1icat,rn lli strictly prlUbitHl. If 'tOJ hMl te::ei~ Itus C1)lllUli(.;t'.Jm in enxr. pla'ee rotifY ill :irrna:iiately l:Iy t:el.Eth:re an reblrn tie od/;Jiralll :7 to LI5 at tie <tn..: ~,_ v:i.e tie ~!.S. p:Atal ffirV1re. 'll'a"k'tOJ. \ "',