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CHARITY L YN WADE,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
VS.
WESLEY EARL WADE,
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"'.;, DEFENDANT
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: NO. 2001-d';)&.I CIVIL TERM
: 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 from your residence and lose other
important rights.
AHEARING ON TIDS MATTER IS SCHEDULED ON ,.4~ c2 3 ,Dll,AT
1 -'gU ~ I.M., IN COURTROOM NO. 3 OF HE CUMBt:RLAND
COUNTY COUR HOUSE, 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 fme of up
to $1,000.00 and/or up to six months injail under 23 Pa.C.S. S6114. Violation may also subject you
to prosecution and criminal penalties under the Pennsylvania Crimes Code, Under federal law, 18
U.S.C. S226S, 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, S 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 LIBERTY AVENUE, CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717)249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cwnberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact
our office. All arrangements must be made at least 72 hours prior to any hearing or business before
the court. You must attend the scheduled conference or hearing,
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Charity Lyn Wade
Plaintiff
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYL VANIA
v.
: No.
Wesley Earl Wade
Defendant
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: Wesley Earl Wade
Defendant's Date of Birth is: May 5,1966
Defendant's Social Security Number is: 223-94-3631
Name(s) of All protected persons, including Plaintiff and minor children:
1. Charity Lyn Wade
.
AND NOW, on ~/g ,}.t;r)/ upon consideration of the attached Petition for
Protection from A use, thb 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:
161 Castle Drive
Mechanicsburg, P A 17055
or any other pennanent 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.
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3. 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 Plaintiffs school, business, or place of employment. Defendant
is specifically ordered to stay away from the following locations for the duration
of this order.
Plaintiffs place of employment located at Blockbuster Video,
Mechanicsburg, Pennsylvania.
Plaintiffs school located at Harrisburg Area Community College,
Harrisburg, Pennsylvania.
4. Defendant shall not contact Plaintiff, or any other person protected under this
Order, by telephone or by any other means, including through third persons.
5. 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 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.
Defendant shall not possess, transfer, or aquire any firearms including any
shotguns, handguns, or rifles for the duration ofthis Order.
6. A certified copy of this Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
Hampden Township Police Department
7. 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.
8. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL OCTOBER 18, 2002 OR UNTIL OTHERWISE
MODIFIED OR TERMINATED BY THIS 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 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 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, 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/s are evidence of a crime, in which
case, they shall remain with the law enforcement agency whose officer made the
arrest.
, Judge
Distribution to:
Joan Carey, Attorney for Plaintiff J .
MidPenn Legal Services f (1;/. e~ ~ ~
8 Irvine Row, Carlisle, PA 17013 j ~ if !r~/tJl
FAXED and mailed to PSP . 1./ / 1~/6J I
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PFAD Number: DXl232668J
Charity Lyn Wade
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYL VANIA
Plaintiff
v.
( /1- -A-;~
; No, 01- ;l.2.(. U>>JI.
Wesley Earl Wade
Defendant
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiff's name is:
Charity Lyn Wade
2. I, (the Plaintift), am filing this Petition on behalf of:
- myself
3. Name(s) of ALL person(s), including minor children, who seek protection from abuse.
a. Charity Lyn Wade
4, Plaintiff's Address is: 161 Castle Drive, Mechanicsburg, PA 17055
5. Defendant's Name is:
Wesley Earl Wade
6. Defendant is believed to live at the following address:
Cumberland County Prison, 1101 Claremont Road, Carlisle, PA 17013
7. Defendant's Social Security Number is:
223-94-3631
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8. Defendant's Date of Birth is:
May 5, 1966
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 defendant has been involved in a criminal court action.
13. The facts of the most recent incident of abuse are as follows:
On or about April 16, 2001, Defendant threatened to punch Plaintiff in the face and told
her to get out of the residence causing her to fear for her safety which she did for her
safety. Later, Defendant went to Plaintiffs friend's residence where she had gone and
threatened that if Plaintiff did not return to the residence, he would kill her. When
Defendant and Plaintiff returned home, Defendant grabbed Plaintiff by the hair, pulled
her off of the couch, screamed at her to get out of the residence, and threw her keys at
her hitting her in the leg. As Defendant smacked Plaintiff in the back of the head forcing
her out into the kitchen. Once in the kitchen, Defendant blocked Plaintiff by standing in
front of her, grabbed her by the neck, and choked her causing her to lose vision and gasp
for air. Defendant grabbed Plaintiff, threw her out ofthe residence, and threatened to kill
her. Plaintiff left and went to a friend's house to call the police. Defendant took Plaintiffs
car and Plaintiffs friends saw him walking around the trailer court where Plaintiff lived
waving a shotgun causing Plaintiff to fear for her life. The police arrived and arrested
Defendant, charged him with simple assault and placed him in Cumberland County
Prison
14. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor
childlren, (including any threats, injuries, or incidents of stalking) are as follows:
In or about April 2001, Defendant grabbed Plaintiff by the throat and threw her onto the
floor causing her to hit her head.
In or about 1999, on several occasions, Defendant slapped Plaintiff on the back of the
head, sometimes he pinned her against the wall.
Defendant and Plaintiff were separated from approximately June 1999 until January
2000.
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Since approximately 1999, Defendant has abused Plaintiff in ways including, but not
limited to, the following: slapped, grabbed, pulled her hair, and choked her causing
marks on her neck. Defendant has verbally abused Plaintiff by calling her vile names,
and threatened to kill her.
15. The police department(s) or law enforcement agencies that should be provided with a copy of
the protection order are:
Hampden Township Police Department
16. There is an immediate and present danger of further abuse from the Defendant.
17, Plaintiff is asking the court to evict and exclude the Defendant from the following residence:
161 Castle Drive
Twiggs Mobile Home Park
Mechanicsburg, P A 17055
Rented By:Plaintiff owns the mobile home. Both parties lease the lot.
18, 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 Plaintiffs residence and prohibit Defendant
from attempting to enter any temporary or permanent residence of the
Plaintiff,
c. Prohibit 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 Plaintiff's 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.
d, Order Defendant to temporarily turn over weapons to the Sheriff of this
County and prohibit Defendant from transferring, acquiring, or possessing
any such weapons for the duration of the Order.
e. Order the following additional relief, not listed above:
Defendant shall not damage or destroy any property owned jointly by
the parties or solely by Plaintiff.
Defendant shall not harass Plaintiff's relatives.
Defendant shall pay $250.00 to one of MidPenn Legal Serivces funding
sources as reimbursement for litigation in this case.
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Defendant shall not possess, transfer, or aquire any firearms
including shotguns, handguns, or rifles for the duration ofthis
Order.
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 infonn the designated
authority of any addresses, other than the Defendant's residence,
where Defendant can be served.
Respectfully submitted,
Date: Lj - J "i - 0 I
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an Carey
Attorney for Plaintiff
MidPenn Legal Services
Slrvine Row, Carlisle, PA 17013
(717) 243-9400
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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. ~4904, relating
to unsworn falsification to authorities.
Dated:
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CHARITY L YN WADE,
Plaintiff
: In the Court of Common Pleas of
: CUMBERLAND County,
: PENNSYLVANIA
v.
:
: Civil Action - Law
: NO. 01-2261
WESLEY EARL WADE,
Defendant
: Protection From Abuse
FINAL ORDER OF COURT
Defendant's Name is: WESLEY EARL WADE
Defendant's Date of Birth is: May 5, 1966
Defendant's Social Security Number is: 223-94-3631
Name(s) of All protected persons, including Plaintiff and minor children:
1. CHARITY LYN WADE
AND NOW, this 19th Day of June, 2001 the court having jurisdiction over the parties
and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows:
After hearing the testimony and upon finding that Plaintiff has been abused within the
meaning of the Protection From Abuse Act, the following Order is entereed:
Plaintiff, Charity Lyn Wade, is represented by Joan Carey ofMidPenn Legal Services;
Defendant, Wesley Earl Wade, is unrepresented, but has been advised of his right to
counsel in this matter.
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.
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2. Defendant is completely evicted and excluded from the residence at:
Twigg's Mobile Home Park
161 Castle Drive
Mechanicsburg, P A
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 under this Order.
3. 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 Plaintifl's school, business, or place of employement. Defendant is
specifically ordered to stay away from the following locations for the duration of this
order.
PlaintitJ's school:
Harrisburg Area Community College
1 HACC Drive
Harrisburg, P A
4. Defendant shall not contact the Plaintiff; or any other person protected under this
Order, by telephone or by any other means, including through third persons.
5. Defendant shall immediately turn over to the Sheriff's Office, or to a local law
enforcement agency for delivery to the Sheriffs Office, any firearms license the
Defendant may possess, and the following weapons used or threatened to be used by
Defendant in an act of abuse against Plaintiff and/or the minor children.
6. Defendant is prohibited from possessing, transferring or acquiring any other firearms
license or weapons for the duration of this order. Any weapons and/or firearms
license delivered to the sheriff pursuant to this order or the Temporary Order shall
not be returned until further order of the court. Defendant may, upon the
expiration of this Order, request that the sheriff return any firearms and/or weapons
held pursuant to this Order. The sheriff shall detennine if Defendant is otherwise
legally entitled to possess the firearms and/or weapons. If the Protection From
Abuse Order has expired and Defendant is legally entitled to pos~ess firearms and/or
weapons, the sheriff shall present an Order to the Court authorizing that the firearms
and/or weapons be returned to Defendant. Otherwise, the sheriff shall notifY
Defendant that he/she must file a petition with the Court seeking a return of the
firearms and/or weapons, in which case the Court, upon petition, will schedule a
hearing with notice to Plaintiff.
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7. 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 ordered to refrain from harassing Plaintiff's relatives.
Defendant is ordered to pay $250.00 to the County of Cnmberland, one of
MidPenn Legal Services' funding sources, for the cost of litigating this case.
8. The costs of this action are waived as to the Plaintiff and imposed on Defendant, as
follows:
Court costs
Sheriff's fees
Domestic Violence surcharge $25.00
9. BRADY INDICATOR
. 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.
. This order is being entered after a hearing of which the Defendant received
actual notice and had an opportunity to be heard.
. Defendant represents a credible threat to the physical safety of the Plaintiff or
other protected person(s).
. The terms of this order prohibit Defendant from using, attempting to use, or
thr\mtening to use physical force against the Plaintiff or protected person that
would reasonably be expected to cause bodily injury.
10. A certified copy of this Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
HAMPDEN TOWNSHIP POLICE DEPARTMENT
MECHANICSBURG POLICE DEPARTMENT
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11. TIllS ORDER SUPERSEDES:
1. ANYPRIORPFAORDER
12. All provisions of this order shall expire on: December 19, 2002
NOTICE TO THE DEFENDANT
VIOLATION OF TIDS 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/ORAJAIL SENTENCE OF UP TO SIX
MONTHS. 23 PA.C.S. ~6114. VIOLATION MAY ALSO SUBJECT YOU TO
PROSECUTION AND CRIMINAL PENALTIES 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
WOMf;N ACT, 18 U.S.C. ~2265. IF YOU IRA VEL 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 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 OFFIClALS
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 Paragraphs 1 through 6 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. ~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's Department 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.
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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.
Date
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Plaintifl's Signature
Defendant's Signature
Distribution to:
Joan Carey, Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row, Carlisle, P A 17013
Wesley Earl Wade, Defendant
Cumberland County Prison
11 01 Claremont Road
Carlisle, PA 17013
Faxed & Mailed to PSP
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OFFICE OF 'I1:IE PR01llCN.)TARY
CUMBERLAND COONI"'( COURTHOOSE
ONE C'C1JRTHOOSE SQUARE
CARLISLE, PA. 17013-3387
(717) 240-6195
FAX (717) 240-6573
V I ATE LEe 0 PIE R
TO:
PA STATE POLICE - CellI. PN'CotS'!:, . M. (J. J...S .
FAX ":
717-249-0779
meM:
CURTIS R. LONG
RE:
PFA ORDERS
MESSAGE:
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~6/22/01 FRI 14:42 FAX 717 240 6573
qUMB CO PROTHONOTARY
,
141001
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OFl'lCE OF '1lIE PR(1l1-l<N1l'ARY
CUMBERLAND COJNI"Y CX)URTHOOSE
ONE CCXJRTIlOOSB ~ARE
CARLISLE, PA. 11013-3387
(717) 240-6195
PAX (717) 240-6573
V I ATE L E COP 1 E R
FAX H:
PA STATE POLICE - CellI. PHlte$t:...
717-249-0779
/III. P, J...S .
TO:
rncM:
CURTIS R. LONG
RE:
PFA OROERS
MESSAGE:
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04/18/01 WED 14:29 FAX 717 240 6573
,
CUMB CO PROTHONOTARY
141001
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*** MULTI TN REPORT ***
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TXlRX NO
INCOMPLETE TXlRX
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[ 04]92490779
CENTRAL PROCESS
LEGAL SERVICES
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OFF'ICE OF' mE PROlliCNITARY
O.IMBERl..AND a::xJNTY COURllIOOSE
ONE COOR1ll00sE SQlJARE
CARLISLE, PA. 17013-3387
(717) 240-6195
FAX (717) 240-6573
V I ATE LEe 0 PIE R
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PA STATE POLICE:. Ce"f. f/ptle"sr..- /11. P,I..$.
FAX ,:
717-249-0779
I'RCM :
CURTIS R. LONG
RE:
PFA ORDERS
MESSAGE: :
-f:- 00. OF PAGES (INCWDING COVER SHEET)
This" '9' is intel dd c;nly fur: tte use af lie irdivid.al cr mtil:y b:J W:rlch is is <ill!: 1, a"rl nay
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distrit.ut:im cr c;q;y~ cE. this ~icn is $\rlct1y p:dUbita1. If:\W teve re:;ei"ej ttllS
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Charity Lyn Wade
Plaintiff
v.
Wesley Earl Wade
Defendant
"
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
: No. 01-2261
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
.
CONTINUED TEMPORARY ORDER
AND NOW, this 22nd Day of May, 2001, pursuant to 23 Pa.C.S. ~6107(c),
the tenus and conditions of the Temporary Order issued on 18th Day of April,
2001, in the above-captioned case are hereby continued in full force and effect
until further order of the court.
A hearing on this matter is scheduled for the June 19,2001, at 3:30PM in
Courtroom 3 of the Cumberland County Courthouse, One Courthouse Square,
Carlisle.
Distribution To:
MidPenn Legal Services
Faxed & Mailed to PSP
Wesley Wade, Defendant
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BY THE COURT:
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Judge
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CHARITY L YN WADE,
PLAINTIFF
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL Y ANIA
YS.
: NO. 2001-2261 CIVIL TERM
WESLEY EARL WADE,
DEFENDANT
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
The Plaintiff, Charity Lyn Wade, by and through her attorney, Joan Carey of MidPenn Legal
Services, moves the Court for an Order rescheduling the hearing in the above-captioned case on the
grounds that:
1.A Continuance was filed April 24, 2001, rescheduling the hearing for May 22, 2001 at
3 :30 p.m.
2. The parties agree that the hearing be rescheduled to afford them time to execute a
consent agreement.
3. 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 reschedule this matter
for hearing, and 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.
Carey, Attorney for R
MIDPENN LEGAL SE
8 Irvine Row
Carlisle, P A 17013
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-02261 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
WADE CHARITY LYN
VS
WADE WESLEY EARL
TREVOR KENT
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE
was served upon
WADE WESLEY EARL
the
DEFENDANT
, at 1605:00 HOURS, on the 18th day of April
2001
at CCP
1101 CLAREMONT ROAD
CARLISLE, PA 17013
by handing to
WESLEY WAVE
a true and attested copy of PROTECTION FROM ABUSE
together with
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
3.10
.00
10.00
.00
31.10
So Answers:
r~~J
R. Thomas Kline
00/00/0000
Sworn and Subscribed to before
By:
,-:;~ AJ
l Deputy Sheriff
me this
day of
A.D.
.
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Charity Lyn Wade
Plaintiff
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
: No. 01-2261
Wesley Earl Wade
Defendant
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
CONTINUED TEMPORARY ORDER
AND NOW, this 23rd Day of April, 2001, pursuant to 23 Pa.C.S, 96107(c), the
terms and conditions of the Temporary Order issued on 18th Day of April, 2001, in
the above-captioned case are hereby continued in full force and effect until further
order of the court.
A hearing on this matter is scheduled for the May 22,2001, at 3:30 PM in
Courtroom 3 of the Cumberland County Courthouse, One Courthouse Square,
Carlisle,
ent
dge
Distribution To: j-
MidPenn Legal Services cqay fU>();U"ltfl V<-n
Faxed & Mailed to PSP Y-iZlf-tJ/
Wesley Wade, Defendant G:Jfy ,Me" 1",0(
Cumberland County Prison
11 0 I Claremont Drive
Carlisle, P A 17013
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,.
Defendant
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01- 2261 CIVIL TERM
: PROTECTION FROM ABUSE AND CUSTODY
Charity Lyn Wade
Plaintiff
v,
Wesley Earl Wade,
MOTION FOR CONTINUANCE
The Plaintiff, Charity Wade, by and through her attorney, Joan Carey of MidPenn Legal
Services, moves the Court for an Order rescheduling 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 18,
2001, scheduling a hearing for April 23, 2001 at 3:00 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 the
Cumberland County Prison, 1101 Claremont Road, Carlisle, Pennsylvania on April 18, 2001 at 4:05
p.m.
3, The parties agree that the hearing be rescheduled to afford them time to execute a
consent agreement.
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.
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WHEREFORE, the Plaintiff requests that the Court grant this Motion and reschedule this
matter for hearing, and 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.
dan Carey, Attorney for Plai
MIDPENN LEGAL SER
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
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