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HomeMy WebLinkAbout01-2000 FX , Lynne Romanoski, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 2001- ~oor-. CIVIL TERM Raymond Rornanoski, Defendant : PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted frorn your residence and lose other important rights. AHEARINGONTmSMATTERISSCHEDULEDON ~ll. ~AT ...2; f/i) .0 .M., IN COURTROOM No.3 OF HE 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 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. ~6ll4. Violation may also subject you to prosecution and criminal penalties under 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, 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. ~ 2261-2262. You should take this paper to your lawyer at once. You have the right to have a lawyer represent you at the hearing. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to 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 LffiERTY 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 of1990. 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. '-',,", , Lynne Ann Romanoski Plaintiff : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v. : No. Raymond Francis Romanoski Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Raymond Francis Romanoski Defendant's Date of Birth is: April 8, :8.953 Defendant's Social Security Number is: 187-42-5703 Name(s) of All protected persons, including Plaintiff and minor children: AND NOW, on ,,() upon consideration of the attached Petition for Protection from Ab se, t1ie court hereby enters the following Temporary Order: Plaintiffs request for a temporary protection order is granted. 1. Defendant shall not abuse, harass, stalk or threaten any ofthe above persons in any place where they rnight be found. 2. Defendant is prohibited from having ANY CONTACT with Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at Plaintiff's school, business, or place of employment. Defendant is specifically ordered to stay away from the following locations for the duration ofthis order. Any current or future residence Plaintiff may establish. Plaintiffs place of employment located at Career Link, Labor and Industry building, Harrisburg, Pennsylvania. " I -, ,^ ,. ~",--,. J i __ -, 0_ _, '., 'w~ c. ,,'~ , ~ ==-- , 3. Defendant shall not contact Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 4. The following additional relief is granted: 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 finds 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: Capitol Police department West Shore Regional Police Department Nanticoke 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. 7. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL OCTOBER 5, 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 injail. 23 Pa.C.S. g6114. 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. g6l13. Defendant is further notified that violation of this Order may subject himlher to state charges and penalties under the Pennsylvania Crimes Code and to federal '0:.).';\,4_ .", _. _~ . .~-~ ~ y^ ~ - . ~, .~ , charges and penalties under the Violence Against Women Act, 18 D.S.C. ~~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. 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 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 rnust 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/s are evidence of a crirne, in which case, they shall remain with the law enforcement agency whose officer made the arrest. Judge , - ~(.,J ' Pcwlo.. Distribution to: MidPenn Legal Services :3 Faxed & Mailed to PSP Cumberland County Sheriff 01./ -01.. -6 I RKS ~ .J,. <." .=...." it ~~_. .' ~ .~ . ~ PFAD Number: BGl223398R Lynne Ann Rornanoski Plaintiff : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v. : No. .200 I - JcrOO Raymond Francis Rornanoski Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE I. Plaintiff's name is: Lynne Ann Romanoski 2. I, (the Plaintiff), am filing this Petition on behalf of: - myself 3. N ame( s) of ALL person( s), including minor children, who seek protection from abuse. a. Lynne Ann Romanoski 4. Plaintiff's Address is : Confidential, , S. Defendant's Name is: Raymond Francis Romanoski 6. Defendant is believed to live at the following address: 600 N. 3rd St., WormIeysburg, PA 17043 7. Defendant's Social Security Number is: 187-42-5703 "'B'4 lJ"""__,_,,.IC, ,",.<, -_,,~, " , 0 8. Defendant's Date of Birth is: April 8, 1953 9. Defendant's Place of employment is: unemployed 10. Defendant is an adult. 11. The relationship between the Plaintiff and the Defendant is: Spouse 12. The Plaintiff and the Defendant been involved in the following court actions: a. Protection From Abuse 13. Other details ofthe court action are: Protection From Abuse, Luzeme County, March 1999 14. The defendant has been involved in a criminal court action. 15. The facts of the most recent incident of abuse are as follows: location: 600 North 3rd St., Wormleysburg On or about March 24, 2001, Defendant screamed in Plaintiffs face and threw the telephone onto the floor to prevent the Plaintiff from calling police, threatened Plaintiff several times that if Plaintiff left him, he would kill her, pushed everything off of the dresser, where Plaintiff was sitting, slammed the door several times, and left in a rage with the Plaintiffs dog. 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: On or about March 25 to March 27, 2001, Defendant left approximately 18 messages for Plaintiff on her voice mail at work, including several that Defendant threatened to kill himself. On or about March 23, 2001, Defendant screamed at Plaintiff as she drove her to work, slammed his hands up and down on the steering wheel, and threatened to ';":="<,=,, ~-,""-"~-"" ,~ " . - ~ - I. ~"_I kill her if she left him. On or about March 20, 2001, Defendant pointied a knife at Plaintiff while they were eating dinner and threatened that he could kill her causing her to fear for her life. On or about March 15,2001, Defendant became enraged, picked up Plaintiff's dog by his back, and threw it outside to wonder the neighborhood for approximately two hours. In late December of 2000, Defendant threatened that if he killed Plaintiff, he could live for free in the prison and that he had nothing to lose causing her to fear for her life. During a separate incident in December, Defendant followed Plaintiff into the street as she fled the residence, picked her up from behind and carried her back into the residence, and pushed her down into the chair by her shoulders. When Plaintiff attempted to get up out ofthe chair, Defendant pushed her down by the shoulders. In or about March 1999, Defendantt pushed Plaintiff by her shoulders into the wall, grabbed the phone from her so that she could not call the police, and smacked her. Since approximately December 1998, Defendant has abused Plaintiff in ways including the following: grabbed, pushed, and threatened to kill her. Defendant continuously phones Plaintiff at her place of employment after she has asked him to stop. On several occasions, Defendant kicked the dogs or picked them up by the hair on their back. 17. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: Capitol Police Department West Shore Regional Police Nanticoke Police Department 18. There is an immediate and present danger of further abuse from the Defendant. 19. 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. Pr.ohibit Defendant from having any contact with Plaintiff and/or mInor child/ren, either in person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Plaintiffs school, business, or place of employment, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/ren. -;'~il__ _ , ~~ ."- '" ..,. ,-.... c. Order Defendant to pay the costs of this action, including filing and service fees. d. Order the following additional relief, not listed above: Defendant shall not damage or destroy any property owned solely by Plaintiff or jointly by the parties. Defendant shall not harass Plaintiffs relatives. Defendant shall pay $250.00 to one of MidPenn Legal Services funders as reimbursement for litigation in this case. e. Grant such other relief as the court deems appropriate. f. 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. Respectfully submitted, Date: '//5/01 . 1 oarrCarey, Attorney for MID-PENN LEGAL S 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 iQistribution to: Mid-Penn Legal Services Fax and Mail PSP I'\ t,' /It' ,.. ''4' \,~ " '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: ~-;< ~O f _ /ftfYMdA16 ~{R~ "~"_~'_,'__"'J _"'-',,_. .~_~_ _ ,'_',h"_ ''1'- -'" " ., ( :;Ji ;1wn _,~,r:o::"'" -~ , - .........-~,~, ---~ ~- -~'",--, -,-,,'," '" ''5~'"'' .".,-, "--~'"' "';""-'''''''-'1'''''''"'-''1 I -~ <:;; ',;.. ~,. (") c \Ji0 ~;" ~~~ -- S:':'-': );;:~~ ,;?.:: :< ~ T'-l'j:~n-lf.;.t~':t",.g"th' c') ':') ,] ~::: ~:,U I (!-; ',., ::J 13~ _~~"lmij'J<H~H'<''''~,''''f~J''''''''illf~'~!lNk~f\~~",-,,?l!@i'~~Ii'lfJjj'-f'':'l!'H.~~~~~1<!iSm;~,t r 04/06/01 FRI 09:03 FAX 717 240 6573 C~ CO PROTHONOTARY ~001 '- TRANSMISSION OK TX/RX NO CONNECTION TEL CONNECTION ID ST. TIME USAGE T PGS. RESULT ********************* *** TX REPORT *** ********************* 2546 95326552 04106 09: 02 01'03 3 OK , <__<_0 11-' , PROTHONOTARY'S FEES CUMBERLAND COUNTY CARLISLE, PA Effecli ve 1 anuary [, 1998 CURTIS R. LONG Prothonotary , . I I ~ ,~-"'~-~ <~.... 04/09/01 MON 07:45 FAX 717 240 6573 CT\MB CO ,PROTHONOTARY . *************************** 'M MULTI TN REPORT ... *************************** TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2552 [ Oll 9p240533I [ 03]9p2438026 [ 04]92490779 ERROR OFFICE OF THE PROTHQ\OTARY CUMeERIANO COONTY COURnlOOSE ONE CCXJRTHOOSE SQUAAE CARLISLE, PA. 17013-3387 (717) 240-6195 FAX (717) 240-6573 VIA TELECOE>lER TO: PA STATE POLICE . ~r.~h" J (J,e,uss. FAX 8: 717-249-0779 .- ~: CURTIS R. LONG RE: PFA ORDERS MESSAGE: I4i 001 CENTRAL PROCESS LEGAL SERVICES PSP $ ~y..J ~~t- rJl ~~\J. /HA J..!. J.. 110. OF PAGES (I\lY-:r..UDING lXNER SHEET) This ~ is iute. dd rnly ftr tte I.ile of tte irdividal (r mtity b:> ..rum is is ~ 11. : :I. ;;nl IlB'f a:.nb.Iin infumBtia1 ttat is ~, \'.mfidmial ad amp: furo rli....l..... ~ I.I1:t!r -WI ;"""'1.. 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OF PAGES (INCLUDING COVtR SHEET) This ~ is :i.l,teM cnly toe tte Ule of the irrli~ II 61titj In \otrid) is is .'d;).._ I. a-d ney a::ntain ir\ti:Ill'I'eti ttat is p:iv.ilsg;rl. o::nf:id:ntial. a:d @l(SJJ;lt fron ni&"ln,um ua:r ,<<,1 irri-11.. laor. rf ~'>;;:' of this ~ is rrt tie inl::a1:R1 re::ipia-rt:. yw ere te!.'a:1f rotififd lhit CI1l' c;lissemiretim. : . 'or o:wirg cf this a:nm..nicatim is sb:ictly prlrlbitEd. If)O..l tflve ra;ei-.a:l ttus ;1',,' '. ,r.Jm in err.r. please mtify I.S imTEdiaLel,y q, telt;p1;re crd returo tie adgiral..: "'T to J.6 al ,,;.... ............... . It "5 1 ' "'--'. ..' ffi:)",: a..LU.= VJa e ,'. . lD"ta s::l:'o'l!':e. .."'''' )0..1. ,<?t.~~- ~,~ , ~ ~-""" - , . r -. ~ -r"~ ~ ~ - I - I I I, I - " =~. Lynne Ann Romanoski Plaintiff : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v. . : No. 01-2000 Raymond Francis Romanoski Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE FINAL ORDER OF COURT Defendant's Name is: Raymond Francis Romanoski Defendant's Date of Birth is: April 8, 1953 Defendant's Social Security Number is: 187-42-5703 Name(s) of All protected persons, including Plaintiff and rninor children: I. Lynne Ann omanoski AND NOW, thi I ~ ~~ having jurisdiction over the parties and the su ~ ct-matter, i is ORDERED, ADJUDGED and DECREED as follo s: Upon agreement ofthe parties for the entry of a consent order, this order will be entered without any admission ofliability by the defendant and without a finding of abuse by this court: Plaintiffs 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. '~~~"'~r~~'w""~~5"'"" - ~.~~,<- ,,11 I~'- .,,,, I I' I h,.... ~__ 0'" , ,,_. " '1 L F~~I'I\llIlIlJ~f~'~ilIl. ~,,- .o-~,;;;; - ,. ", ',I..;; -'." c, ,,"' ,=,"~' "'~~~., , =,,' - '-'" -~.,-", " '-~'''-I-';''l''it"'tl't'''' ~'lLN1""'-' I~--j~-,,-~,-};~~ ',"'P':-":- '-:i"f'h'j 'tIli,.[\{'\'l''''''/ .., ! I"n ..'!...n':'0,\!N:d /1.0_1'1 In J (,,\ ~'J"l~ !"'~-'\ L'., '.,'" ":-'-;':,:!'lno jiG :.C' "J .., ~i :'.,10 7[' l' :'1 ! n I" (('J, ; ',,' I],. J~~1f~~~,~~<jf%<4i~j;;;'j:""""'''';'?''-'''_t~'i'l'RWi!C'''''''''J''o/-"'_tWJ\f'1'4'W~~:~"'"""lf'1l.;'C"~_~~<\l!W~i\!lIj~~'~ 2. The following additional relief is granted as authorized by 96108 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. Defendant shall enroll in the Tressler Choices Program, a 26 week batter's program, within 30 days of the entry ofthis Order. Defendant shall sign a release so that Plaintiff can contact Defendant's counselor and discuss information including Defendant's progress and attendance in the program. Defendant shall successfully complete the program and follow any recommendations given by the counselor. The court costs and fees are waived. 3. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Capitol Police department West Shore Regional Police Department Nanticoke Police Department 4. THIS ORDER SUPERSEDES: 1. ANYPRIORPFAORDER 5. All provisions of this order shall expire on: October 9, 2002 NOTICE TO THE DEFENDANT VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S. 96114. VIOLA TION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENAL TIES UNDER THE PENNSYLVANIA CRIMES CODE. '-1),;, ~1 - ~ , ,'" ':": '", ",.' , '" ,'____'1"_, " _ ~__~! " _,~, 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 ~~226l- 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 OFFICXALS The police who have jurisdiction over the plaintiff's residence OR any location where a violation of this order occurs OR where the defendant may be located, shall enforce this order. An arrest for violation of Paragraph 1 of this order may be without warrant, based soley on probable cause, whether or not the violation is committed in the presence of the police. 23 Pa.C.S. ~6l13. Subsequent to arrest, the police officer shall seize all weapons used or threatened to be used during the violation of the protection order or during prior incidents of abuse. The Cumberland County Sheriff shall maintain possession of the weapons until further order of this Court. When the defendant is placed under arrest for violation of this order, the defendant shall be taken to the appropriate authority or authorities before whom defendant is to be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police officer OR the plaintiff. Plaintiff's presence and signature are not required to file the complaint. If sufficient grounds for violation of this order are alleged, the defendant shall be arraigned, bond set and both parties given notice of the date of the hearing. Raymond Romanoski, Defendant 600 North 3~ Street Wormleysburg, PA 17043 oan Carey Attorney for Plaint' f ~ ~l1y*' MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 t~,_._~~, ~...., ~ -'~- '""I' , , , - -'1 I I , ), 'Ii' {: " ~; i oJ ""~) ,~.)""' ~_"1' Distribution to: MidPenn Legal Services Faxed & Mailed to PSP Rayrnond Rornanoski 600 North 3rd Street Wormleysburg, PA 0, , c ___., :~':---~, - 0 ~_ -I. .c _-~ - 1,1 \'<" 04/12/01 r THU 15:33 FitX' 7i7"240 6573 CUMB CO PROTHONOTARY. ~001 *************************** *n MULTI TN REPORT *** *************************** TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2568 [ 01J9p2405331 [ 03J9p2438026 [ 04J92490779 CENTRAL PROCESS LEGAL SERVICES PSP ERROR , , OFFICE OF THE PRD'rnCNOTF\RY CUMBERLJI.ND (XXJNTY CXlUR'IHOOSE ONE CCXJRTIiaJSE 9:!UARE CARL~SLE. PA. 17013-3387 (717) 240-6195 FAX (717) 240-6573 V I ATE L E COP I E R fAX N: PA STATE POLICE - CeN", I'''''t.es!... 111. fJ. J...S. 717-249-0779 ",; TO: ffiOM: CURTIS R. LONG RE: PFA ORDERS MESSAGE: Y' 00. OF PAGES (INCLUDING COVER SHEET) , This II CJ]: is inta1:lt!d O'Il.y fir tte ll!lC of tt'e irdividJ;ll (][" Entity to Wlich is is .., 1, .iI. aU lTB':f o:nta:in infi.:un:It:irn !tat is ~. anf:identia1 ad eetpl; fmn du.r1....rre IIli!r '{{'l;,..nl" larI. . rf tI'2 ~ of tI1is ~ is rot tI-e inteUrl m;ipialt. :rw are lEetJy 1Dl:if.ie1 ttat lfij ~tJa1. dist:rib.rt:ia1 cc a:w:ir9 of this ronn.nicatim is strictly prlIibiba:!. ~f}':IJ teI.e rErei1.9:l tJus o:nmnic.:t-..:im in eo:tr. pl.e:ooe ruti.fY u;; irme:l.ioteJ.y q> \e1efh:re <nl rellIm tie a:igirel. II :;>'J' to l.E at "~~,,",",!"!m - - ~ "I I! ~ , ,. ,- "- '~"I ....-., ~~~-, Lynne Ann Rornanoski Plaintiff : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v. : No. 01-2000 Raymond Francis Romanoski : CIVIL ACTION - LAW : PROTECTION FROM ABUSE Defendant CONTINUED TEMPORARY ORDER AND NOW, this 10th Day of April, 2001, pursuant to 23 Pa.C.S. ~6107(c), the terms and conditions of the Temporary Order issued on 6th Day of April, 2001, in the above-captioned case are hereby continued in full force and effect until further order of the court. Distribution To: ] MidPenn Legal Services Faxed & Mailed to PSP ~LP- LS " Raymond Romanoski Pro Se Defendant 4-/'1-01 RKS ;+~""~l 0/_ ~ ,>',-", _-'_OR ,",_ ,. ~~'I _ .._,._ ,,,,,. _ -, , ~ '""N\/'~'''Q''t\t:J^1 Vll \,/\ 1./\\)\! 'i_11-o ,,,, 1 /"1' ,...,,,'I,l,r>.I^ 'jN(I"r', I,' "'~"'i" J J\ J 'I . ,".. '.,: ~, - -, '.- ,e c; I :G ln' -,--, I., "" w~,w ~[!'1U "L~~wt"iIf~~;~JlI1_ -" _,J.l.A\tIlI!!U!I~. " 1;-', ," .~ U -<' >,'"" ,& ~''''-<'-~'- '.o~ '-"1,1- ~".t'jjiit'1IiilM""='kun.i~'~'""r"~~;r'r<':'f_l ;Mf!)tl'_~.1!)mW""'J'i1l'<J!W"Sf'''~I;'~~",~~,*i~\~\.(j!~:r'-':W'l!'0i!'Jl'l!li'i\Ij.,,,,!jm;;'i_~l€!~)~~m!\!fflW~r~~~ S,.!,," _>, Lynne Romanoski Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-2000 CIVIL TERM Raymond Romanoski, Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE The Plaintiff, Lynne Romanoski, by and through her attorney, Philip Briganti ofMidPenn Legal Services, moves the Court for an Order continuing generally the hearing in the above-captioned case on the grounds that: I. A Temporary Protection From Abuse Order was issued by this Court on April 6, 2001, scheduling a hearing for April II, 2001, at 2:00 p.m. 2. The Cumberland County Sheriffs Department served Defendant with a certified copy of the Temporary Protection From Abuse Order and Petition for Protection From Abuse at his residence, 600 North 3'd Street, Wormleysburg, Pennsylvania, on April6, 2001 at 4:30 p.m. 3. The parties agree that the hearing be continued generally to afford them time to execute a Consent Agreement in this matter. 4. The Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. ~ -" ' -~ - - < ~. -"'.'" WHEREFORE, the Plaintiff requests that the Court grant this Motion and continue this matter generally, and that the Temporary Protection From Abuse Order remain in effect for a period of eighteen rnonths from the date it was entered or until further Order of Court, whichever comes first. Philip Briganti, Att ey for Plaintiff MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 "-:i,,, _'_~. -".. ,.,,~ ~>o ,_ " <.....- , -1="'" , ' 0..,1 ,,- SHERIFF'S RETURN - REGULAR CASE NO: 2001-02000 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ROMANOSKI LYNNE VS ROMANOSKI RAYMOND JASON VI ORAL , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon ROMANOSKI RAYMOND FRANCIS the DEFENDANT , at 0019:30 HOURS, on the 6th day of April , 2001 at 600 NORTH 3RD STREET WORMLEYSBURG, PA 17043 by handing to RAYMOND RAMANOSKI a true and attested copy of PROTECTION FROM ABUSE together with NOTICE OF HEARING & ORDER, TEMPORARY PROTECTION FROM ABUSE ORDER, PETITION and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.30 .00 10.00 .00 37.30 So Answers: ...1 ~V Vf:~ R. Thomas Kline 04/09/2001 " A.D. Sworn and Subscribed to before By: me this J,(pit.. day of ':. Protnbn ~"""IQ ,,!.,,} " .'."f' " ~t~_4-~.,~", _,~~<< " ~~ "" I I , ~