HomeMy WebLinkAbout01-1834 FX
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ANTHONY N. THOMAS
ATTORNEY AT LAW
2205 Paxton Church Road
Harrisbmg, P A 1711 0
Office: (717) 541-9979
Fax: (717) 541-9495
Email: athomaslaw@msn.com
April 3, 2001
Honorable Edward E. Guido
Cumberland County Courthouse
1 Courthouse Square
Carlisle, P A 170
Morris v. Morris
Docket No.: 01-1834 Civil Te
Our File No.: 0007-001
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Please be advised that the parties in the above-referenced matter have entered into
an agreement to set aside the Temporary Protection from Abuse Order issued on March
29,2001. Your office was contacted on April 3, 2001, to provide notice that the hearing
scheduled for April 4, 2001, at 8:30 a.m. would not be necessary. A Stipulation in the
Divorce Action is being prepared outlining the terms of the parties' agreement and will
be immediately forwarded to your office. In addition, we will fIle a Praecipe to Set Aside
the Temporary Protection from Abuse Order accompanied by a new order for this
purpose for your signature.
Thank you very much for your understanding and assistance.
Cc: Diane G. Radcliff; Esquire
Sandra Morris
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MAR 2 9 200~
SANDRA MORRIS,
Plaintiff,
v.
: IN TIfE COURT OF COMJ\i[ON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -
PROTECTION FROM ABUSE ACT
ROBERT K MORRIS,
Defendant.
NO.: C:>/- IPJ~ (?,O~(y~
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 Wlder Title 23 (Domestic Relations) ofthe Pennsylvania Consolidated Statutes,
including child custody proceedings Wlder Chapter 53 (relating to custody). It J
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A hearing of the matter is scheduled for the U day of ~~/L- ,2001, at _.M., in
Courtroom N.s- at Cumberland COWlty Courtho~arlisle, Pe sylvania.
You MUST obey the Order that is attached Wltil 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 and/or up to six months in jail Wlder 23 Pa.C.S. ~ 6114. Violation may also
subject you to prosecution and criminal penalties Wlder the Pennsylvania Crimes Code. Under
federal law, 18 U.S.c. ~ 2265, this Order is enforceable anywhere in the United States, tribal
lands, U. S. Temtories 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 Wlder the
Violence Against Women Act, 18 U.S.C. ~~ 2261-2262.
YOU SHOULD TAKE TIDS PAPER TO YOUR LAWYER AT ONCE. YOU
HAVE THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT TIIE HEARING.
THE COURT WILL NOT, HOWEVER, APPOINT A LAWYER FOR YOu. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE TIIE
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.
Lawyer Referral Sel"llice
.f1' Floor, Cumberland County Courthouse
Carlisle, PA 17013
(717) 240-6200
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SANDRA MORRIS,
Plaintiff,
: IN TIlE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVlL ACTION -
PROTECTION FROM ABUSE ACT
ROBERT K MORRIS,
Defendant.
NO.: f) 1- I J'J'I
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiff's name is Sandra Morris.
2. Plaintiff, Sandra Morris, by and through her attorney, Anthony N. 1110mas, files this
Petition on her own behalf, and behalf on her minor child, Frank P. Morris.
Plaintiff is the mother of the minor child.
3. Plaintiff Sandra Morris, and her minor child, Frank P. Morris, seek protection from
abuse.
4. Plaintiff's address is 1974 Randall Road, Enola, PA 17025.
5.
A.
Defendant's address is believed to be 821 Briarwood Lane, Camp Hill, P A 17011.
B. Defendant's Social Security Number is 188-46-5289.
C. Defendant's date of birth is November 4, 1953.
D. Defendant's place of employment is Exel Logistics, Mechanicsburg, P A.
E. Defendant is over the age of 18.
6. The relationship between Defendant and Plaintiff is husband and wife, respectively.
7. Plaintiff and Defendant will be involved in a court action including divorce, custody,
support or protection from abuse.
8. Defendant has not been involved in any criminal court action.
9. Plaintiff and Defendant are the parents ofthe minor child, Frank P. Morris, who is
believed to currently resides at 821 BrialWood Lane, Camp Hill, PA 17011.
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10. There is not an existing court Order regarding the child's custody.
A. The child, Frank P. Morris, has resided during the past five years with Plaintiff
Sandra Morris and Defendant Robert K. Morris at their home located at 1974
Randall Road, Enola, P A 17025.
B. No other persons are known to have or claim a right to custody of the child listed
above.
11. No other minor child/ren presently live with Plaintiff.
12, Most Recent Incident of Abuse. The facts of the most recent incident of abuse are as
follows:
Approximate Date: March 14, 2001
Approximate Time: 6:00 P.M.
Place: 1974 Randall Road, Enola, P A 17025
On the above date, Defendant approached Plaintiff screaming and yelling profanities
within inches ofPlaintifl's face as he accused her of having an affair. Defendant raised
his clenched fists in a manner that caused Plaintiff to feel threatened and to fear that
Defendant would inflict bodily injury.
13. Prior Acts of Abuse Against Plaintiff.
A. In 1985, Plaintiff was a passenger in a car driven by Defendant. Defendant
became very angry and screamed and yelled profanities at Plaintiff. Defendant
began to operate the vehicle erratically and to drive at a high rate of speed.
Defendant then reached over Plaintiff, opened the passenger-side car door where
Plaintiff was sitting, and demanded that she get out while the car was moving,
B. In 1990, Plaintiff observed Defendant punching her 11 year old son from a prior
marriage, Matthew Oravec, in the stomach.
14. No weapon(s) were used, or threatened to be used by Defendant against Plaintiff.
15. The police department or law enforcement agency in the area in which Plaintiff lives that
should be provided with a copy of the protection order is Hampden Township Police
Department.
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16. There is an immediate and present danger of further abuse from the Defendant.
A. Plaintiff is asking the court to evict and exclude the Defendant from the residence
located at 1974 Randall Road, Enola, P A 17025, which is oWIled by Plaintiff and
Defendant.
B. Defendant owes a duty of support to Plaintiff and/or the minor child.
FOR THE REASONS SET FORTII ABOVE, I REQUEST THAT THE COURT ENTER
A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD
DO THE FOLLOWING:
1. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or
minor child in any place where Plaintiff may be found.
2. Evict/exclude Defendant from Plaintiff's residence and prohibit Defendant from
attempting to enter any temporary or pennanent residence of the Plaintiff.
3. Award Plaintiff temporary custody of the minor child and place the following restrictions
on contact between Defendant and child:
A. Plaintiff requests that Defendant be prohibited from unsupervised visitation with
the minor child. This request is intended to prevent Defendant from negatively
influencing the child against Plaintiff, and to prevent the possibility of other harm
to the minor child in retaliation against Plaintiff.
B. In the alternative, Plaintiff requests that Ian Krotee, Plaintiff's sister, who resides
at 604 Lawrence Avenue, West LaWIl, P A 19609, be assigned temporary foster
care during the pendency of these proceedings.
4. Prohibit Defendant from having any contact with Plaintiff and/or minor child, either in
person, by telephone, in writing, personally or through third persons, including but not
limited to any contact at Plaintiff and/or minor child's school, bnsiness, or place of
employment, except as the court may fmd necessary with respect to partial custody
and/or visitation with the minor child.
5. Prohibit Defendant from having any contact with Plaintiff's relatives.
6. Order Defendant to pay temporary support for Plaintiff and/or the minor child, including
medical support and payment of the rent or mortgage on the residence.
7. Order Defendant to pay the costs of this action, including filing and service fees.
8. Order Defendant to pay Plaintiff's reasonable attorney's fees.
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9. Order the following additional relief, not listed above:
A. Plaintiff requests that Defendant be ordered to return the originals and all copies
of Plaintiff's personal notebooks that contain recordings of the events that took
place at prayer sessions attended by Plaintiff.
B. Plaintiff requests that Defendant be prohibited from discussing the contents of the
aforementioned notebooks with any third party.
C. Plaintiff also requests that Defendant be ordered to return the originals and all
copies of Plaintiff's notes from sermons that were located in Plaintiff's bible,
10. Grant such other relief as the court deems appropriate.
11. 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 Defendant's residence, where
Defendant can be served.
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VERIFICATION
I, Anthony N. Thomas, verifY that I am the attorney for 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 18 Pa.C.S. 9 4904, relating to unsworn falsification to authorities.
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Attorney for Plaintiff Sandra Monis
Date 3/z'11c1
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SANDRA MORRIS,
Plaintiff,
IN TIIE COURT OF COMMON PLEAS
CUMBERLAND CmMlY, PENNSYLVANIA
v,
CIVIL ACTION -
PROTECTION FROM ABUSE ACT
ROBERT K MORRIS,
Defendant.
NO.:
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant: Robert K. Morris
Defendant's Date of Birth: November 4, 1953
Defendant's Social Security Number: 188-46-5289
Names of All Protected Persons, including Plaintiff and the minor child/ren:
Sandra Morris .....u.d. f"'"-I.ll Y. Ivluu~",
AND NOW, this d~~y of fd.~ .2001, upon consideration of the attached
Petition for Protection from Abuse, the court hereby enters the following Temporary Order:
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Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place
where they might be found.
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Until the final hearing, all contact between Defendant and the child shall be limited to the
following:
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8 The lo..wall..uv ......ld\..~ ..........U1vlll 4gt,;IlCY m me JUflsctlctlon wnere lilt,; ~ldld ~ lu,","L--1
..&ludl...uMHS tkat 81...... ,-,l";'ld;" l'lavvd';"'1 d.~ [l):)h;;. \.idlt,; (lUU control or me .t'JamtifPs
sister. Jan Kmtee: in :tr.r:nl'rlj:Jnr.e: with the term~ ofth;~ Qrder.
o 6. The following additional relief is granted:
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A certified copy of this Order shall be provided to the police department where Plaintiff
resides and any other agency specified hereafter:
TIllS ORDER SUPERSEDES,g. ANY PRIOR PF A ORDER AND 0 ANY PRIOR
ORDER RELATING TO CHILD CUSTODY.
TIllS ORDER APPLlES IMMEDlATEL Y TO DEFENDANT AND SHALL REMAIN
IN EFFECT UNTIL OR UNTIL OTIlERWISE MODIFlED OR
TERMINATED BY TillS COURT AFTER NOTICE AND HEARING.
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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 $1,000.00 and/or up to six months in
jail. 23 Pa.C.S. ~ 6114. Consent of the Plaintiff to Defendant's return to the residence shall not
invalidate this Order, which can only be changed or modified tlrrough the filing of appropriate
court papers for that purpose. 23 Pa.C.S. ~ 6113. Defendant is further notified that violation of
this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes
Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.c.
~ S 2261-2262.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the police who have jurisdiction over the plaintiff's
residence OR any location where a violation of this order occurs OR where the defendant may be
located. ]f defendant violates Paragraphs 1 through 6 of this Order, defendant shall be arrested on
the charge of Indirect Criminal Contempt. An arrest for violation of this Order may be made
without warrant, based solely on probable cause, whether or not the violation is committed in the
presence oflaw enforcement.
Subsequent to an arrest, the law enforcement officer shall seize all weapons used or
threatened to be used during the violation of this Order OR during prior incidents of abuse.
Weapons must forthwith be delivered to the Sheriff's office of the county which issued this
Order, which office shall maintain possession of the weapons until further Order of this court,
unless the weapon/sare evidence of a crime, in which case, they shall remain with the law
enforcement agency whose officer made the arrest.
Judge
3/ ;t/o (
Date:
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03/29/01 THU 14:26 FAX 717 240 6573
ClIMB CO PROTHONOTARY
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*****$*********************
.u MULTI TN REPORT ...
*************.*************
TX/RX NO
INCOMPLETE TX/RX
TRANSACTION OK
2538
01]9p2405331
04]92490779
CENTRAL PROCESS
PSP
ERROR
,
OfF1CE OF THE PRCJI'HCU:1rARv
CliMBERLAND COON'IY CXXJRTIiCOSE
ONE COUR'lliOOSE SQUARE
CARLISLE. PA. 17013-3387
(717) 240-6195
FAX (717) 240-6573
V I ATE LEe 0 prE R
TO:
C~~L Pn.oa:.~~~J
PA STATE POLICE
FAX #:
717-249-0779
F1lCM :
CORTIS R. LONG
RE:
PFA ORDERS
MESSAGE::
Ii-. NO. OF PAGE;S (INCWOING COVER SHEET)
'n1is ~ is :intElrl;d cnl.y fur \he use oi' tte irdivithil. cr 81tit;y tD W'1id1 is is cdb............J. ifil rrey
antain .infi:mTBtim ttat is p:ivilsg;rl. anfiO:mial <ni e<srp: fu:m n; (;1""1 031 Ire Uli::!r' 'It)lit'".''Ohlp 1cw. rf
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SANDRA MORRIS,
Plaintiff,
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -
PROTECTION FROM ABUSE ACT
v.
ROBERT K. MORRIS,
Defendant.
NO.: 0 (- / rJ' Y 0'17/ --1a17>YJ
AFFIDAVIT OF SERVICE
I, Anthony N. Thomas, the undersigned, hereby state that I served a copy of the Petition
=-~z;rary Order in the above-captioned action upon the Defendant by handing the papers to
t:I r.?: #o17r.'f at the following address:
821 Briarwood Lane
Camp Hill, P A 17011
on the 2 9tf. day of #~, 2001, at approximately ~'$o'clock ft.m.
I verify that the statements made in this Affidavit are true and correct. I understand that
false statements herein are made subject to the penalties of 18 PaC.S. ~ 4904, relating to
unsworn fulsification to authorities.
~~
2205 Paxton Church Road
Harrisburg, P A 1711 0
(717) 541-9979
Date: 3/2 7 ~/
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SANDRA MORRIS,
Plaintiff;
v.
ROBERT K. MORRIS,
Defendant.
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MAya a 2001 tJO
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -
PROTECTION FROM ABUSE ACT
Ol~ If341- 1f
NO.:~I-I608 CIVIL TERM
ORDER
AND NOW, this 71-day of May, 2001, in consideration of Plaintiff's attached
motion, it is hereby ordered and decreed that the temporary protection from abuse order entered
against Defendant is set aside.
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DISTRIBUTION TO:
Anthony N. Thomas, Esquire
2205 Paxton Church Road
Harrisburg, P A 1711 0
Jane Alexander, Esquire
148 S. Baltimore Street
P,O. Box 421
Dillsburg, PA 17019-0421
Diane G. Radcliff, Esquire
3448 Trindle Road
Camp Hill, PA 17011
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SANDRA MORRIS,
Plaintiff,
v.
: IN THE COURT OF COMMON PLEAS
: CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -
PROTECTION FROM ABUSE ACT
ROBERT K. MORRIS,
Defendant.
NO.: 01-1608 CIVIL TERM
PLAINTIFF'S MOTION TO SET ASIDE
THE TEMPORARY PROTECTION FROM ABUSE ORDER
AGAINST DEFENDANT
AND NOW, this _ day of May, 2001, comes Plaintiff Sandra Morris, by and
through her attorney, Anthony N. Thomas, Esquire, and files this motion to set aside the
temporary protection from abuse order entered against Defendant Robert K. Morris on March 29,
2001. In support thereof, Plaintiff states as follows:
1. Plaintiff filed a Petition for Protection from Abuse with an attached order against
Defendant on March 29,2001. (See Attachment "A").
2. On the same date, this honorable Court granted Plaintiff's petition in part, and denied it in
part, issuing a temporary order pending a final hearing that was scheduled for April 4, 2001.
(See Attachment "A").
3. The Temporary Protection from Abuse Order was limited to prohibiting Defendant from
abusing, harassing, stalking or threatening Plaintiff in any place where she might be found.
4. Prior to the final hearing, the parties entered into an agreement under which Plaintiff's
person would be satisfactorily protected.
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5. Plaintiff s counsel notified the Court of the agreement, and complied with its instruction
to send written notice to the Court. (See Attachment "B").
6. On May 4,2001, the parties filed a stipulation with an attached order in accordance with
the agreement. (See Attachment "C").
7. This honorable Court accepted the parties' stipulation in its entirety and issued an order
on May 8, 2001. (See Attachment "C").
WHEREFORE, Plaintiff respectfully requests the Court to grant its motion to set aside
the temporary protection from abuse order issued against Defendant.
Date: 1/7/ 24tJ/
omas, Esquire
2205 Paxto hurch Road
Harrisburg, PA 17110
Supreme Court ID# 85150
(717) 541-9979