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HomeMy WebLinkAbout01-2719 FX . - [ " I ~ '~ ,:, ,;;".-, "' - ~~M.ik . . 4" . .' MAy 0 4 200t4? KAREN D. JOHNSEN Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CNIL ACTION-LAW IN PROTECTION FROM ABUSE TODD W. ABICHT, Defendant : NO. 01 -.)'7/1 CNIL TERM NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following p~ges, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed agamst 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 the matter is scheduled for thel'la, day of"YJ?~ 2001, at ~.m, in Courtroom I at the Cumberland County Courthouse, ennsylvania. 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 PaCS. 9 6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law , 18 U.S.C 92265, 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 99 2261-2262. YOU SHOULD TAKE TIDS PAPER TO YOUR LA WYERAT ONCE. YOUHA VE THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEARING. THE COURT WILL NOT, HOWEVER, APPOINT A LAWYER FOR YOu. IF YOU DO NOT HAVE ALA WYER OR CANNOT AFFORD ONE, GOTOOR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT FIND A LAWYER, YOU MAY HA VB TO PROCEED WITHOUT ONE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 " '. .. , KAREN D. JOHNSEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION.LA W IN PROTECTION FROM ABUSE v. TODD W. ABICHT, Defendant : NO.01-2,\~ CIVILTERM TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name: Todd W. Abicht Defendant's Date of Birth: 11/23/57 Defendant's Social Security Number: 187 48 9003 Names of All Protected Persons, including Plaintiff: Karen D. Johnsen AND NOW, this f") tL day of vV1 2..1--,2001, upon consideration of the attached Petition for Protection From Abuse, the court hereby enters the following Temporary Order: [X] L Defendant shall not abuse, harass, stalk or threaten Karen D. Johnsen in any place where she might be found. [] 2. Defendant is evicted and excluded from any permanent or temporary residence where Plaintiff may live. [X] 3. Defendant is prohibited from having ANY CONTACT with Plaintiff 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 of this Order: Ciber, Inc. 3314 Market Street Camp Hill, PA 17013 [X] 4. Defendant shall not contact Plaintiff by telephone or by any other means, including through third persons. Pending the outcome of the final hearing in this matter, Plaintiff is awarded temporary custody of the following minor child/ren: [X] 6. Defendant is prohibited from possessing, transferring or acquiring any weapons for the duration of this order [] 5. [X] 7. The following additional relief is granted: , ~ I ,"" " ' " ii~ ,- " A) PI.aintiff shall be permitted to return to herresidence at 135 North 21st Street, Camp Hill, Penpsylvania, for the purpose of retrieving her personal belongings, including, but not lunited to, her clothing, computer, and medical and fmancial files. Plaintiff may retrieve these items at any time on May 4, 2001, provided that she is accompanied by a police officer or other law enforcement official. Thereafter, Plaintiff may return to the residence on a date and time to be agreed upon by the parties, through counsel. B) Defendant shall not damage or otherwise depreciate the value of any of Plaintiffs property in his possession. C) Defendant shall immediately turn over all of Plaintiff s credit cards and A TM cards to the law enforcement official serving this Order. In the event that the Defendant has made any purchases or withdrawals using those cards since May 3, 2001, Defendant shall be responsible for those purchases. [X] 8. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Camp Hill Police Department, Cumberland County Adult Probation and Parole Office. [X] 9. TillS ORDER SUPERSEDES [X] ANY PRIOR PFA ORDER AND [ ] ANY PRIOR ORDER RELATING TO CHILD CUSTODY [X] 10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MODIFIED OR TERMINATED BY TillS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 andlorup to six months in jail 23 Pa. C.S ~ 6114. Consent of the Plaintiff to Defendant 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 US.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 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 of law enforcement ,,'T-, ~ " I~ ,,,"=' '.. I' ~:r' ",",,'---,,' " 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 ('VIllI'] l.t>o\ Date L BY THE COURT. ~ o VG~ vf 1 _~~-",..~:ii~'!J-,"~~;!"~~~;Sjj""""IiJH""'~/',""""L"'''';'''-",'''''''WjjN,i;1iilf,j#Ji,lilUtt1H- ~~~~.~~~-"~MIii@llIl,' (::1 r ~ .. P. t i. ~ ""t:, If",.ur~~,,~,,~,"~,,~ _ ,:n ~ ~. l-=:- ~~ :;2 >-.~z '-'<i~ -~:") ::J C', .::!~~ I 0:,(, ;;,-- ~:::c:z .- :..UIU ~'C!: fQ f.L ~- ~ -'" H ::;J c> C) u .,",~,_ _">".,_~"w~_ "". ~~ ,""-'~- .".y-,-- ,~ ~'-- -~--' -'-^''''' 0,_" ~ Litill ".-1 " . l'","",~ ", ~ J" j~ ~, f". ' "'';;;'_~'n<';;,i KAREN D. JOHNSEN, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION.LA W IN PROTECTION FROM ABUSE TODD W. ABICHT, Defendant : NO. 01. L 119 CIVIL TERM PETITION FOR PROTECTION FROM ABUSE 1. Plaintiffs name is: Karen D. Johnsen 2. I am filing this Petition on behalf of Myself 3. Name(s) of ALL person(s), including Plaintiff and minor children, who seek protection from abuse: Karen D. Johnsen 4. [x] Plaintiffs current address is confidential. Herresidence is 135 North 21" Street, Camp Hill, Pennsylvania. 5. Defendant is believed to live at the following address: 135 North 21" Street, Camp Hill, P A 17013 Defendant's Social Security Number (if known) is: 18748 9003 Defendant's date of birth is: 11/23/57 Defendant's place of employment is: unemployed [] Check here if Defendant is 17 years old or younger. 6. Indicate the relationship between Plaintiff and Defendant [] Spouse [x] Current/former sexual/intimate partner [] Ex.spouse [] Parent/child [] Persons who live or have lived like spouses [] Other relationship by blood/marriage [] Parents of the same children 7. Have Plaintiff and Defendant been involved in any of the following court actions? [] Divorce [] Custody [] Support [x] Protection From Abuse If you checked any of the above, briefly indicate when and where the case was filed and the court number if known: On November 22, 2000, this Court entered a PFA Order against Defendant, after consent by the parties. On January 24, 2001, Plaintiff filed a Petition to Vacate the PFA Order, and on January 25, 2001, this Court entered an Order vacating the Order. 8. Has the Defendant been involved in any criminal court action? Yes. Defendantwas charged with assaulting plaintiff in November of 2000. If you answered Yes, is the Defendant currently on probation? Yes -0. ,~~~ . ~ ....._,~ , I .L 'J"_~'. ","",' '.lit! . . 9. Plaintiff and Defendant are parents of the following minor child/ren: N/ A. 10. If Plaintiff and Defendant are parents of any minor child/ren together is there an existing court Order regarding their custody? N/ A. ' 11. The following other minor child/ren presently live with Plaintiff: N/ A. Name(s) Age(s) Plaintiff's relationship to child/ren 12. The facts of the most recent incident of abuse are as follows: Approximate Date: May 3, 2001 Approximate Time: evening Place: 135 N. 21 ,t St. Camp Hill, P A, 17013 Describe in detail what happened, including any physical or sexual abuse, threats, injury incidents of stalking, medical treatment sought, and/or calls to law enforcement: ' On Thursday evening, the defendant slapped the plaintiff in the face, pulled her hair, jerked her neck, sprayed air freshener in her eyes, choked her, grabbed her at the chest, and detained her on the sofa, not allowing her to leave or sleep until 6 AM Friday morning. The defendant detained the plaintiff on the sofa until she agreed to "work things out" with him. On Thursday, May 3,2001, the defendant attempted to pick up plaintiffs check from work When he was not able to get it, he took all of her credit cards, and her MAC card from her purse. 13. If the Defendant has committed prior acts of abuse against Plaintiff or the minor child/ren, describe these prior incidents, including any threats, injuries, or incidents of stalking, and indicate approximately when such acts of abuse occurred: On Monday, April 30, 2001, the defendant slapped the plaintiff in the face leaving bruises on her face. Likewise, he left nail markings on her neck when he grabbed her by the neck and choked her. The defendant banged the plaintiff s head against the sofa's wood railing and grabbed her by the chest. The defendant kept the plaintiff detained on the sofa, not letting her sleep or leave until 4 AM the next morning. The defendant kept the plaintiff detained on the sofa until she agreed to work things out with him. On November 7, 2000, the defendant became angry with the plaintiff The plaintiffleft their bedroom and went to sleep in the couch. The defendant followed her and as she sat on the couch, the defendant punched her in the nose three times causing her nose to bleed profusely. The defendant told the plaintiff that she was lucky that this time it was just her nose. The plaintiff grabbed some kleenex to stop the flow of the blood and went back upstairs. The defendant followed her and ordered her to go back downstairs and get out of the way. The plaintiff went outside and paced around the driveway. The defendant locked her out. The plaintiff rang the bell to get back in. The defendant opened the door and grabbed the plaintiff by the shoulders and banged her head against the wall. The plaintiff s glasses flew off her face. The defendant picked up the glasses and put them on the kitchen counter. The plaintiff grabbed her glasses from the counter and the glasses in her hand. The Defendant told her to give him the "goddamned glasses." She refused. The defendant grabbed the plaintiff by the shirt, ripping her shirt, and threw her to the floor where he banged her head repeatedly on the floor. When the plaintiff cried out in pain, the defendant called her a baby and slammed her head against the floor again. The defendant stuck his knee into the plaintiff s rib cage as she lay on the floor and choked her with one hand around the throat. The defendant told her he would kill her ifhe had to get her glasses back The plaintiff released her grip on the glasses and the defendant took them The plaintiff got up and ran from the house. The plaintiff ran to the police station, but no one answered. The plaintiff returned home where she was locked out again. Plaintiff rang the door bell and plaintiff entered the home. The defendant demanded to know where she had ,.""""-"~ -~ - . ~~.~, -, ~.,""."""",","'~U""_ _~_ """"",-"",,,,_~,~~,"i' been. The defendant told the plaintiff if she went to the police station, he would kill her. In the middle of September 2000, in the Bahamas in the middle of the afternoon the defendant became angry and attempted to lock the plaintiff out of the hotel room. The defendant slapped the plaintiff in the face, grabbed her by the shoulders, and threw her against a half wall causing her to hit the railing on top of the wall with her face, causing her glasses to gouge her face under her left eye. The stucco on the wall scraped her forehead when she slid down the wall, causing her to bleed. The defendant grabbed the plaintiff's ann and pulled her into the room. 14. List the weapon(s) that Defendant has used or threatened to use against Plaintiff or the minor child/ren: 15. Identify the police department or law enforcement agency in the area in which Plaintifflives that should be provided with a copy of the protection order: Camp Hill Police Department 16. There is an immediate and present danger of further abuse from the Defendant CHECK THE FOLLOWING BOXES ONLY IF THEY APPLY TO YOUR CASE AND PROVIDE THE REQUESTED INFORMATION [ ] Plaintiff is asking the court to evict and exclude the Defendant from the following residence: [] owned by (list owners, if known) [] rented by (list all names, if known): [] Defendant owes a duty of support to Plaintiff and/or the minor children. [X] Plaintiff has suffered out-of.pocket fmanciallosses as a result of the abuse described above. Those losses are: about $4100.00 from a joint savings account FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING (CHECK ALL FORMS OF RELffiF REQUESTED): [x] A Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff in any place where Plaintiff may be found. [] B. Evict/exclude Defendant from Plaintiff's residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff. [] C. Require Defendant to provide Plaintiff and/or minor child/ren with other suitable housing. [] D. A ward Plaintiff temporary custody of the minor child/ren and place the following restrictions on contact between Defendant and child/ren: [ x] E. Prohibit Defendant from having any contact with Plaintiff, either in person, by telephone, or in writing, personally or through third persons, including but not limited to any contact. at 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. ,,~~""""- ~~.< I. '" ,-,' .~'~ '~- ~1'!'~_-,,,,.,,,-,, [] F. Prohibit Defendant from having any contact with Plaintiffs relatives and Plaintiffs children listed in this Petition, except as the court may fmd necessary with respect to partial custody and/or visitation with the minor chi1d/ren. [X] G. Prohibit Defendant from transferring, acquiring or possessing any weapons for the duration of the Order. [] H. Order Defendantto pay temporary support for Plaintiff and/or the minor child/ren, including medical support and [] payment of the rent or mortgage on the residence. [x] L Direct Defendant to pay Plaintiff for the reasonable fmanciallosses suffered as the result of the abuse, to be determined at the hearing. [x] J Order Defendant to pay the costs of this action, including filing and service fees. [] K Order Defendant to pay Plaintiffs reasonable attorney's fees. [ x] L Order the following additional relief, not listed above: 1) Plaintiff shall be permitted to return to herresidence at 135 North 21 st Street, Camp Hill, Pennsylvania, for the purpose of retrieving her personal belongings, including, but not limited to, her clothing, computer, and medical and fmancial files. Plaintiff may retrieve these items at any time on May 4, 2001, provided that she is accompanied by a police officer or other law enforcement official. Thereafter, Plaintiff may return to the residence on a date and time to be agreed upon by the parties, through counseL Defendant shall not damage or otherwise depreciate the value of any of Plaintiffs property in his possession. Defendant shall immediately turn over all of Plaintiffs credit cards andATM cards to the law enforcement official serving this Order. In the event that the Defendant has made any purchases or withdrawals using those cards since May 3, 2001, Defendant shall be responsible for those purchases. 2) 3) [] M. Grant such relief as the court deems appropriate. : .~ ..~~, - ."'- "I ~ . '.'., "....~O, "''''~'''':';,''h"" [ X] N. Order the police or other law enforcement agency to serve the Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The Plaintiff will inform the designated authority of any addresses, other than Defendant's residence, where Defendant can be served. ~ek - .. ~ e rufer G son Certified Legal Intern ~:fd- ROBERT E. RAINS TERl L HENNlNG Supervising Attorneys FAMILY LAW CLINIC 4S North Pitt Street Carlisle, PA 17013 717/243.2968 -j ,1 ~-''-',' ,~"'" "~'" > N___ -if VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa.C.S ~ 4904, I verify that I am the Plaintiff 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, information and belief 5/'-1/01 Date ~O~"090.AJ Name ~ t < -'] 1,1, " > .- -;,' KAREN D. JOHNSEN, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA CNIL ACTION-LAW IN PROTECTION FROM ABUSE TODD W ABICHT, Defendant : NO. 01 . CNIL TERM FINAL ORDER OF COURT Defendant's Name: Todd W. Abicht Defendant's Date of Birth: 11/23/57 Defendant's Social Security Number: 187 48 9003 Names of All Protected Persons, including Plaintiff and minor children: Karen D. Johnsen AND NOW, this day of , 20_, the court having jurisdiction over the parties and the subject.matter, it is ORDERED, ADJUDICATED and DECREED as follows: Note: Space is provided to allow for 1) the court's general fmdings of abuse; 2) inclusion of the terms under which the order was entered (e.g., that the order was entered with the consent of the parties, or that the defendant, though properly served, failed to appear for the hearing, or the reasons why plaintiffs request for a fmal PF A order was denied); and/or 3) information that may be helpful to law enforcement (e.g., whether a weapon was involved in the incident of abuse and/or whether the defendant is believed to be armed and dangerous). [] Plaintiffs request for a fmal protection order is denied. OR [] 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 [NONCONFIDENTIAL ADDRESS FROMWlllCH DEFENDANT IS EXCLUDED] or any otherresidencewhere Plaintiff may live. Exclusive possession of the residence is granted to Plaintiff Defendant shall have no right or privilege to enter or be present on the premises. [] On , Defendant may enter the residence to retrieve his/her clothing and other personal effects, provided that Defendant is in the company of a law enforcement officer when such T' -~ ~ - ~ ...Ljj .--~.. ~ "'~!~;' retrieval is made. [] 3. Except as provided in Paragraph 5 of this Order, Defendant is prohibited from having ANY CO.N~ACT with the. Plaintiff at any location, including but not limited to any contact at the Plamtlffs school, busmess, or place of employment Defendant is specifically ordered to stay away from the following locations for the duration of this Order. [] 4. Except as provided in Paragraph 5 of this Order, Defendant shall not contact the Plaintiff by telephone or by any other means, including through third persons. [] 5. Custody of the minor children, [names of the children subject to the provision of this paragraph] shall be as follows: [state to whom primary physical custody awarded; state terms of partial custody or visitation, if any.] [] 6. Defendant shall immediately turn over to the Sheriffs Office, or to a local law enforcement agency for delivery to the Sheriffs Office, the following weapons used or threatened to be used by Defendant in an act of abuse against Plaintiff and/or the minor child/ren. [] 7. Defendant is prohibited from possessing, transferring or acquiring any other weapons for the duration ofthis order. Anyweapons delivered to the sheriff under paragraph 6 of this Order or under Paragraph 6 of the Temporary Order shall not be returned until further order of court. [] 8. The following additional relief is granted as authorized by 9 6108 of the Act: [] 9. Defendant is directed to pay temporary support for: [insert the names of the persons for whom support is to be paid] as follows: [insert amount, frequency and other terms and conditions of the support order]. This order for support shall remain in effect until a final support order is entered by this Court However, this order shall lapse automatically if the Plaintiff does not file a complaint for support with the court within fifteen days of the date of this order. The amount of this temporary order does not necessarily reflect Defendant's correct support obligation, which shall be detennined in accordance with the guidelines at the support hearing. Any adjustments in the final amount of support shall be credited, retroactive to this date, to the appropriate party. [] 10. The costs of this action are waived as to the Plaintiff and imposed on Defendant [] 11. [] Defendant shall pay $ to Plaintiff as compensation for Plaintiff's out.of.pocket losses, which are as follows: OR [] Plaintiff is granted leave to present a petition, with appropriate notice to Defendant, to [insert the name of the judge or court to which the petition should be presented] requesting recovery of out.of.pocket losses. The petition shall include an exhibit itemizing all cliamed out.of.pocket losses, copies of all bills and estimates of repair, and an order scheduling a hearing. NO fee shall be required by the Prothonotary's office for the filing of this petition. [] 12. BRADY INDICATOR. [] 1. The Plaintiff or protected person(s) in a spouse, fonn~r spous~, a person who cohabita~es or has cohabitated with the Defendant, a parent of a common Child, a child of that person, or a child of the Defendant --{;~~ .......,_.~o ._ _"C ~ ~, t ~ , - ~" '0 '~'''',"_''',,,,",,_ [] 2. This order is being entered after a hearing of which the Defendant received actual notice and had an opportunity to be heard. [] 3. Paragraph 1 of this Order has been checked to restrain the Defendant from harassing stalking, or threatening Plaintiff or protected person( s). ' [] 4. Defendant represents a credible threatto the physical safety of the Plaintiff or other protected person(s) OR [] The terms of this Order prohibit Defendant from using, attempting to use or threatening to use physical force against the Plaintiff or protected person that would reasonably be expected to cause bodily injury. [] 13. THIS ORDER SUPERSEDES [] ANY PRIOR PFA ORDER AND [] ANY PRIOR ORDER RELATING TO CHILD CUSTODY 14. All provisions of this order shall expire jp one year, on [insert expiration date l NOTICE TO THE DEFENDANT VIOLATION OF TillS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WIllCH IS PUNISHABLE BY A FINE OF UP TO $1,000.00 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PAC.s. S 6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRlMINALPENALTmS UNDER THE PENNSYLVANIA CRIMES CODE. TillS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, US. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 US.C. SS 2261.2262. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE TillS ORDER YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT 18US.C. SS2261.2262. IFPARAGRAPH 12 OF TillS ORDER HAS BEEN CHECKED, YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTmS UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT, 18 US.C. SS 922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION. 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, an arrest may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence of law enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriff's office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of the this Court, unless the weapons are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. (l) Defendant is prolu'bited from acquiring or possessing any weapons for the duration ofthis order. ~ - .1 ' ~ ~ " jlt;.h"",,",:W-"-~l>'<>:S:.' (2) Defendant may, upon the expiration if this order, request that the sheriff return any weapons held pursuant to this order. The sheriff shall determine if defendant is otherwise legally entitled to possess the weapons. If the protection from abuse order has expired and defendant is legally entitled to possess weapons, the sheriff shall present an order to the court authorizing that the weapons be returned to defendant. Otherwise, the sheriff shall notify defendant that he must file a petition with the court seeking a return of the weapons, in which case the court, upon petition, will schedule a hearing with notice to the plaintiff. BY THE COURT: Judge Date If entered pursuant to the consent of the plaintiff and defendant: (Plaintiffs signature) (Defendant's signature) ~~ijjl' {_.im~~it,~ffil--,if",,,,,,,j,!.~~1ffi!l&il~lHU'iJi;'wf,"~"";!iif;""';';"';,.-Q'Iili!W;,,,,,;;",,~nra:'t7"-',IJi~r '"''''''-iIIl''''~~ z ,~ __ _~_'_,~__M ,~"b,,.,.,."" "', ,~,~ ~,^, ,--=~,~" ~, ,"",~ty=~'~ ,~ " ~'11' f'i'~~L~_J , . t n c n c "t.; .... -UCC rTln"i -C ',} ;.~:..."O -?,- ~ eJ) ':t> ,~-- -~, -<,:< ~'-) [<C -V T, :l:':c ..j.,. (''5 z.) ,---0 i.-=jl""/ Pc r. Z S-~ --j :n -< --< -- ~.~^, , ,- ,~ . . I -& ~"'''''''''''''' "~.~ "....~ & j ~~' ~ ';- .-',' .. il< ~-~~", 05/09/01 WED 09: 57~ EAX 717 240 6573 CUMB CO PROTHONOTARY 141001 *************************** .u MULTI TN REPORT ... $************************** TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2599 [ OIl 9P2405331 [ 04]92490779 CENTRAL PROCESS PSP ERROR , , OFfICE or" TliE PROfHCX\ICII'ARY CUMBERLAND CXXJN'IY COUR'Il!CXJSE ONE COUR'IHOOSC: SQtJAJlE CARLISLE, ~A. 17013-3387 (717) 240.6195 FAX (717) 240-6573 V I ATE LEe 0 PIE R TO; PA STATE POLICE . (!(-.i'tAIl' t?t'C"t: $S. /JII. A-t:. , FAX ": 717-249-0779 !"RG1 : CURTIS R. LONG RE: PFA ORDERS MESSAGE : J~ .- 00. OF PAGES (INCLUDING COVER SHEET) '!his" "]' is intEnirl c.nly :tilL tiE I.Be of tte irdiv:idHl a:: mti\;y lD IIh.ich is is .,dh. l,,;rd ll5Y cmt:rin .irlfi:xJmtim t:tat is lXiviJapi. o:nl;idEnt;ial. ad BhBq;:t froI1 n;""'\""'JrB lIrl=r "WH.w.lp 1;w. {f tl'e ~ <:i \his ~ is rot l:l'e in\:efI);j:1 ta::ipimt, )OJ are reo;t:J,t rotifud that <<rf disl;l!mireti!n. o:l.istciI;utim cr fXP{irg of this o;mn.niCatim is strictly [Xl:I"I.ibital. If)OJ tme mcei.\e:l Ims o::J1lIUi:ic.,...i01 in =, plaEe rol:i1Y U$ iIms:liatcly ~ tele!;tt:re e;d retum tie ~ II . "'0/ ID I.S FIt tm ffp.': a:tIl:ess via tiE ~!.S. ptal secviD3. 'Il'B1k ~, --~~" "- ,~l"~, ~, ......J.'""'. c L, j'---:-,,' J"~, ,,:,.: ,1", '. , - ,\;,-,~ .. , " . KAREN D. JOHNSEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION . LAW : PROTECTION FROM ABUSE TODD W. ABICHT, Defendant : NO. 01.2719 CIVIL TERM CONSENT AND APPROVAL FOR APPEARANCE UNDER Pa.B.A.R. 322 I hereby consent to the appearance of Jennifer Garrison, a Certified Legal Intern under the supervision of an attorney, in the above.captioned proceeding before the Honorable 1. Wesley Oler, Jr. at 4:00 p.m. on Monday, May 14, 2001. Date: May 14, 2001 c1vL(J~}o ~'L.Q.()~ Karen D. Johnsen As the supervising attorney for Jennifer Garrison, certified under Pa.B.A.R. 322, I approve of her appearance on behalf of the above.named client in the above.named proceeding. Date: May 14, 2001 L eri L Henning Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 . ~ --', , '.-;""C"., ' ~'", "'~: , " , 'RECE:lVED JAN 'Z 5 2001 Shelley A. Carrara. Esq. Deputy Prothonotary Patricia A. Honard Chief Clerk . Supreme Court of Pennsylvania Western District January 23, 2001 801 City-County Building PittSburgh, P A 15219 412-565.2816 www.aopc.org Robert E. Rains, Esq. Family Law Clinic, The Dickinson School of Law 45 N. Pitt Street Carlisle, PA 17013 RE: Garrison, Jennifer No.50 INT 2001 Dear Attorney Rains: The above-named law student has been approved and certified under Pa BAR 321 and 322 by: Dickinson School of Law Feldman, Harvey Associate Dean as a duly enrolled law student who has completed at least three (3) semesters at legal studies, or the equivalent thereof, as being of good character and competent legal aOlllty. and as being adequately trained to perform as a legal intern as of January 23. 2001 Pursuant to such certification and in accordance with and subject to the provISions of Pa. BAR 321 and 322, the above-named student has been certified as a legal Intern and you have been approved to perform the duties of supervising attorney WITNESS my signature and the seal of this Court. January 23. 2001 Very truly yours, ~~d~y- {~-. e:,~ . - // Shelley A. Carrara Deputy Prothonotary Idal cc: Mr. Harvey A Feldman Associate Dean Ms. Jennifer Garrison ~ , ,;' I ~ , ~'" - , ~ ~ J _ } '<~ ,", -'~", ~,' <', '> J_~',-> ",,' ,,; tiiJ; I> KAREN D. JOHNSEN, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CNIL ACTION.LA W IN PROTECTION FROM ABUSE TODD W. ABICHT, Defendant : NO. 01 .2719 CNIL TERM FINAL ORDER OF COURT Defendant's Name: Todd W. Abicht Defendant's Date of Birth: 11.23.57 Defendant's Social Security Number: 187-48.9003 Names of All Protected Persons, including Plaintiff: Karen D. Johnsen AND NOW, this ~ day of May, 2001, the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows: Pursuant to the consent of the parties, which does not constitute Defendant's admission to the averments of abuse in the petition, the following order will be entered: 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. 2. Defendant is prohibited from having ANY CONTACT with the Plaintiff, at any location, including but not limited to any contact at the Plaintiff's school, business, or place of employment Defendant is specifically ordered to stay away from the following locations for the duration of this Order: Ciber, Inc., 3314 Market Street, Camp Hill, PA, 17011 . 3. Defendant shall not contact the Plaintiff, or any other person protected under this order, by 1 '-~~Jffil?ii~"*liii~i~~!?k,"\""';;'''D:''''''ii'if::'!1ili~1W1"l~;,j~U:iJl,,,,Jo;-:k.';"',-""" ""lIili JJ.Nn~~j(~}~12~~N1d ~ - "., ,.,_,C1"I.~" '. '._' ...i',")/'l Iv ",. "1 ' '--,J:J '(. ~U C J " . ".0 j AgH 10 )Ji\/!;r,,; , '''''''.'..I..',,)i -~U .""'~ ,',~ ''',0- ,_ "w", ',~' ,~_,_ "~k",, _",'~, ~,' ,,,,,,.. ~'" ,'><"_"'.,O,.,"~'~ ., ^' -~ --~ , ~~- ~ ~~."~ ~' ~"""""" ,." ,'~" , -- ~, .. -" ,,' h I h; .. I ~ ': I: Ii :'i ., Ii I II i II II Ii ,:! lei ! i:i ! ,- "" " -, d ~~".. OJ'", - ;;V";"h,.,<, ,';-~-" J~ >,,'0' "_'1" . . telephone or by any other means, including through third persons. 4. Defendant is prohibited from possessing, transferring or acquiring any weapons for the duration of this order. 5. All fees and costs are waived. 6. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Camp Hill Police Department Cumberland County Adult Probation and Parole Office THIS ORDER SUPERCEDES [X] ANY PRIOR PFA ORDER AND [] ANY PRIOR ORDER RELATING TO CHILD CUSTODY All provisions ofthis order shall expire in eighteen months, on November ~, 2002. -n;;., Qrc4r \'" e.f\kt.-c~ W,-t\,",Ch.)\" ?r...~""~LL- -t-o e.-;-rk..<- ~o-c ", ~L-Q~\O -\--,~1>L\1.PD \v('f")O,,/u;}. ~(O<"\ -\\v- "00-"'0 o-.C-<-O...J"\ 0-\' '\'e..t'\.f'<:>\\~"",,,~- ~~<\::C!.. 'O"'""~. 2 , -J, . " .',--,- " '~ . ~1."N"""",,"",~;),_ .. NOTICE TO THE DEFENDANT VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPTWmCH IS PUNISHABLE BY A FINE OF UP TO $1,000.00 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 12 P A.C.S. ~ 6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENAL TIES UNDER THE PENNSYLVANIA CRIMES CODE. 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 PARAGRAPH 12 OF THIS ORDER HAS BEEN CHECKED, YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT, 18 U.S.c. ~ 922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION. 3 ,;- ,~~ ^" " '-",~,l if.- ,_' i""~~J;;_,; . .. 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 an arrest 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 weapons are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. (1) Defendant is prohibited from acquiring or possessing any weapons for the duration of this order. (2) Defendant may, upon the expiration ofthis order, request that the sheriff return any weapons held pursuant to this order. The sheriff shall determine if defendant is otherwise legally entitled to possess the weapons. If the protection from abuse order has expired and defendant is legally entitled to possess weapons, the sheriff shall present an order to the court authorizing that the weapons be returned to defendant. Otherwise, the sheriff shall notify defendant that he must me a petition with the court seeking a return of the weapons, in which case the court, upon petition, will schedule a hearing with notice to plaintiff. Jv . \1l"~ ~ v../ ;'0.e. .,,~ tep 7 .5-/~-O I p~:.:) iXs mO:, led ft\~ 4 ,-, , , ' . ~ '. ", . . . This Order is entered pursuant to the consent of Plaintiff and Defendant: ch'Q.,')O "~A.A04~ -d~~~' Karen D. Johnsen,ilai~tiff Todd W. Abicht, Defendant e nifer G for Plaintiff ~L J: / ~ , Ten . enning, SupemYtng Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 May 14,2001 5 _ ~ _ ~_ i'\_ ~ 1ill""";."",L."""",,,h;..~,, ~ ,- - ,.....;.. ..l. ~ _ l - ~" ~ ~ ~ .iL..~l:jJ~!Fli;* 05/18/01 FRI 11:21 FAX 717 240 6573 .. CUMB CO PROTHONOTARY @001 *************************** u, MULTI TN REPORT ... *************************** TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2616 ERROR [ 01l9p2405331 [ 04]92490779 CENTRAL PROCESS PSP , , OFF1CE OF THE PROI'HCN:lTARY CUMBERLAND <XI.1NTY OJURlliOOSE ONE a:xJll'ffiOOSE 9::lUAllE CARLISLE, PA. 17013-3387 (717) 240-6195 FAX (717) 240-6573 VIA TELECOPIER TO: PA STATE POLICE . Ct.,t. P"hte.t.t. FAX *: 717-249-0779 .. ., ~: CURTIS R. LONG RE: PFA ORDERS MESSAGE : ~ 00. OF PAGES (INCr..tIDING (..'(Y.IEll SHEET) This ~ is i1,t;.;.Qj:J, o11y fiX' tte we of tte irdividal cr Efltity to Irtrid1 is is ..11. I, cnlll'af antain irtfi::Jatetim ttBt is p::i.villg!d. a:nfilB1tial ;nj emrpt fnm QicrJ""'llll t.nEr <I-P'il>'hl.. lat. rf tl'E ~ of this ~ is rot tiB inta'd3:l J'H;:ip.ient. ~ are ten;by rotif:ia:l ttet iDf di!si/llirIeltiat. d.:istriWtirn oc a:wirg (f. this c:rnTllJ"licat'..Jm lli strictly prltibibrl. If ~ tave ta:ci\Ed tius o:rnnnic.Jtial in em:r;, p1m5e mtify 1.B .irm'e:1iately ty telepnE crrl mtvm Ita ocigiml ":""'9" to LS at ........ ,.....,.. -rt'b__ vi" ~ ~l.S. ttPlta1 ser:vim. 'l1'H'k~. "- ~-, _ ~"k~_~~"""""'- ~ ~."" ~"""'"-,;",'" ,~__ ~ _' i,l",. .-'"--' ''''~k, SHERIFF'S RETURN - REGULAR CASE NO: 2001-02719 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND JOHNSEN KAREN D VS ABICHT TODD W JASON VrORAL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE OF HEARING & ORDER was served upon ABICHTTODD W the DEFENDANT , at 0017:30 HOURS, on the 9th day of May , 2001 at CUMBERLAND COUNTY PRISON 1101 CLAREMONT ROAD CARLISLE, PA 17013 by handing to TODD W. ABICHT a true and attested copy of NOTICE OF HEARING & ORDER together with 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 3.10 .00 10.00 .00 31.10 So Answers: ~~~~t:~ R. Thomas Kline 04/10/2001 Sworn and Subscribed to before By: me this d23Ml day of ~ :J-&v ( A.D. ~'<r,-,Q~ ~ I"" fpt'othonotary , F:\FILES\DA T AFILE\Ckudoc,clIr\t0368-pra.lftde Created; 05122/01 12:27:49 PM Revis~d: 05122/01 0,2:11:05 PM WAYNE LeCLAIR, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 01-2819 CIVIL ACTION - LAW CUMBERLAND V ALLEY MOTORS, Defendant JURY TRIAL DEMANDED PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Enter the appearance of MARTSON DEARDORFF WILLIAMS & OTTO on behalf of Plaintiff in the above matter. MARTSON DEARDORFF WILLIAMS & OTTO Date: May 23, 2001 ,"'" ~~ , '" ~. , .~ ,., ", " ,.' ~".,"~:, '~""'''~'~;~'O ".'+ii . \ CERTIFICATE OF SERVICE I, Tricia D. Eckenroad, an authorized agent for Martson Deardorff Williams & Otto, hereby certifY that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, P A, first class mail, postage prepaid, addressed as follows: John F. Yaninek, Esquire 3401 North Front Street Harrisburg, P A 1711 0 MARTS ON DEARDORFF WILLIAMS & OTTO By Tncia D. Eckenroad en East High Street Carlisle, P A 17013 (717) 243-3341 Dated: May 23,2001 wm]f!i,_.~~~ -; ;'<:'"'""..IiI'Ji~ ~;.... , ", , r~ I~ , ":~.i'---RiL '&;ruI!!1~~m-~-'i;Mb:l\K<8i!';~.:~Mt~M~ ' ~,,, ~"',-~"',. > ~~ , ~ .-~ . c',,~...il''{~l' " 1') /i/ 1"11'" /f~:-' It [~~:,- >"-" ~(:5 .r;:. <: ~ (J-, ! Ii Ii I, i! II ! '"--) -- :> ".~ "- c,:" .~':> F\5 .. --('! ~ :__,~ C) C5n-j ,1 :0 ~; "" " ~ " '" -, ,. <, - ,< ,'., ~"", ~"'~ ~.If':';'~ .-" JlJN 1 8200t rP KAREND. JOHNSEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW : IN PROTECTION FROM ABUSE TODD W. ABICHT, Defendant : NO. 01-2719 CIVIL TERM ORDER OF COURT AND NOW,this ~ day of :r '-l....\ c.... 2001, upon consideration of the attached Petition to Vacate Order, it is hereby ordered that: 1. The Final Order of Court for Protection from Abuse dated May 14, 2001, is vacated, without prejudice. 1'<m L. {'b 2-D 0 I J Date '!;:{_~~_M!iA4t.illil!lfiilij#g31lie!-i:mm~R!\l~~Mii'"br1O-:-ki",,*lU.";,,<&"',,-'R~":t'=~",~~~g- , ~,~' '-. ~iIIII.'~ , "'", _M .~u,.,"""4l!.' ~~ ,~'.~ i i'-j Ii 'I II I' II I i c .:p Gp 'c/? -rl> c/ :> ;/ -A .~~ ~ ~ ~ /p:W ~u, ~~~.~~~TV - . It/-N-'? It?~/ '9 \;TiNV,\l,\SNN2d MNnCO C\!'11\~c!g\^'\m .', 'S LI\.! ii I N!i\' 10 'v" In- . ("_>_"'''': ',-'I -' A'cl\fI'J!\;"""--'l..".-__L .," l- - 3bL~_:iCt{JTi'd !Ill I ,.~__.~~"__,,",,~,~'",_,,""_.",~~'.O'"''uN'_ *" _._""",o~",, _," .__0" ,'~ ~~- " . ,-- <_ l I ~-,-- - , ~~_'''J--< >6-., '.' - "',.,~"; "-,< ,~,:','. a'~>";;"''-: - I":"::;;; KAREN D. JOHNSEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : CIVIL ACTION-LAW : IN PROTECTION FROM ABUSE TODD W. ABICHT, Defendant : NO. 01-2719 CIVIL TERM PETITION TO VACATE ORDER Petitioner, Karen Johnsen, through her attorneys, the Family Law Clinic, hereby moves to vacate, without prejudice, the following: Final Order of Court dated May 14, 2001. In support of her petition, Karen Johnsen states the following: 1. Petitioner, through the Family Law Clinic, filed a Petition for Protection From Abuse on May 4,2001 with this Court. 2. A Temporary Protection From Abuse Order was entered May 7, 2001, signed by the Honorable 1. Wesley Oler, Jr. 3. A hearing on the Petition for Protection From Abuse was scheduled for May 14,2001 at 4:00 p.m. in Courtroom 1. 4. On May 14,2001, the parties reached a Consent Agreement, and a Final Order of Court was entered. A true and correct copy of the May 14, 2001 Order is attached as Exhibit "A". 5. Petitioner now wishes to vacate the Order entered on May 14,2001. 6. To that end, Petitioner has instructed the Family Law Clinic to file this Petition to Vacate Order. :'1 ',-" " ;-~~,' c_ '~- ','" _"",(" 'C;~'_",,,.."",,,' .-, , " , '('( WHEREFORE, Petitioner requests that the court vacate, without prejudice, the Final Order entered May 14,2001. ~ Date ~d .> THOMAS M. PLACE ROBERT E. RAINS TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 N. Pitt. St. Carlisle, P A 17013 717/243.2968 Attorneys for Karen Johnsen !. u ,~~ - ,-"""~..~,-; KAREN D. JOHNSEN, Plaintiff IN THE COURT OF COMl\10N PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. CIVIL ACTION-LA W IN PROTECTION FROM ABUSE TODD W ABICHT, Defendant NO. 01 - 2719 CIVIL TER1v1 FINAL ORDER OF COURT Defendant's Name: Todd W. Abicht Defendant's Date of Bilth: 11-23-57 Defendant's Social Security Number: 187-48-9003 Names of All Protected Persons, including Plaintiff: Karen D. Johnsen AND NOW, this ~ day of May, 2001, the COUlt having jurisdiction over the pa11ies and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows: Pursuant to the consent of the pm1ies, which does not constitute Defendant's admission to the averments of abuse in the petition, the following order will be entered: Plaintiff's request for a final protection order is granted. I. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other protected person in any place where they might be found. o Defendant is prohibited from having ANY CONTACT with the Plaintiff, at any location, including but not limited to any contact at the Plaintiffs school, business, or place of employment. Defendant is specifically ordered to stay away from the following locations for the duration of this Order Ciber, Inc., 3314 Market Street, Camp Hill, PA, 17011 3. Defendant Sh111I not contact the Plaintiff, or any other person protected under this order, by f'f..Hlb\T A ~ .. ~~ -~ J ~"~" ..... ) " ~-, ,-' '" :<. "'t"~ telephone or by any other means, including through third persons. 4 Defendant is prohibited from possessing, trans felTing or acquiring any weapons for the duration of this order 5. All fees and costs are waived. 6. A ceI1ified copy of this Order shall be provided to the police depar1ment where Plaintiff resides and any other agency specified hereafter: Camp Hill Police Department Cumberland County Adult Probation and Parole Office THIS ORDER SUPERCEDES [X] ANY PRIOR PFA ORDER AND [ ] ANY PRIOR ORDER RELATING TO CHILD CUSTODY All provisions of this order shall expire in eighteen months, on November l'i , 2002. --r\",", Orclu'" \",,> t~~(-('L(~ \,,-..)'-\'\'\0"/' ?l'"_~d..'\u... -to l'/; +\~ \' 0"<'\ '\ ,'-c'c::S~"'cA;0 -\-'\v-- 1P 1-\1..0 D \C~C'I\o'! u:\ ~(D" ;.... <) \' c-":"""J.... L ~c...0~ c~cc...o-.-f'.\ c-...\\(,...DJ"\"::>, -J~\~ ~\O-<\.e....... U . .:r\ v.- 0~~\O 2 ~ ~ ~. , h", " "-- '~~-(\ NOTICE TO THE DEFENDANT no LA. nON OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FL'iE OF UP TO Sl,OOO.OO AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 12 PA.C.S. S 6114. VIOLATION MAY ALSO SUBJECT YOUTO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE, THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES Al\'D THE COMMONWEAL TI-I OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.c. S 2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND lNTENTIONALLYVIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMlNAL PROCEEDINGS UNDER THAT ACT. 18 U.S.c. SS 2261-2262. IF PARAGR~PH 12 OF THIS ORDER HAS BEEN CHECKED, YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT, 18 U.S.c. S 922(G), FOR POSSESSION, TR<\NSPORT OR RECEIPT OF FIREARMS OR Al\'IMUNfTION. 3 -" ~. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction overthe 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 an an'est may be made without wanant, based solely on probable cause, whether or not the violation is committed in the presence of law en forcement. Subsequent to an anest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse Weapons must forthwith be delivered to the Sheriff's office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this Court, unless the weapons are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. (1) Defendant is prohibited from acquiring or possessing any weapons for the duration of this order. (2) Defendant may, upon the expiration of this order, request that the sheriff return any weapons held pursuant to this order. The sheriff shall determine if defendant is otherwise legally entitled to possess the weapons. If the protection from abuse order has expired and defendant is legally entitled to possess weapons, the sheriff shall present an order to the court authorizing that the weapons be returned to defendant. Otherwise, the sheriff shall notify defendant that he must me a petition with the court seeking a return of the weapons, in which case the court, upon petition, will schedule a hearing with notice to plaintiff. TRUE COPY FROM RECORD In Testi ny whereaV I here unto set my hand and t '1 ofsaid,(our'/lt..a lisle, Pa ....l~....70'V:....... '.., !Jr'..,~ 4 !.1i......'x:;lJ,/)1 . .. 'J' p thonotary " - "#&=,">",6-, ~ I -,,-, ~/Q.O 0 "JJL .AO",:=J Karen D. Johnsen, Plaintiff entered pursuant to the consent of Plaintiff and Defendant: d~~~' Todd W. Abicht, Defendant This Order is F AMIL Y LAW CLINIC 45 N Olth PittS treet Carlisle, PA 17013 (717) 243~2968 May 14,2001 5 ... ~'- -~__""""'''''''''''''"""-O-;'_ if. ., -~- "d,;. -_ __w.' ,;;.~, < , h"'<X VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa.C.S. 9 4904, I verify that I am the Plaintiff 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, information and belief. l..11'iJIDI ~ cJ.,MA) '>..~ Karen Johnsen "~, .'- ;-, ;", ""., " -"- - -:';';'~4:, . . KAREN D. JOHNSEN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v, : CIVIL ACTION-LAW : IN PROTECTION FROM ABUSE TODD W. ABICHT, Defendant : NO. 01- 2719 CIVIL TERM CERTIFICATE OF SERVICE I, Jennifer Garrison, hereby certify that I am serving a true and correct copy of the Petition to Vacate Order on the following person at the following address, by first class mail, postage prepaid: Mr. ToddAbicht Cumberland County Prison 11 0 1 Claremount Road Carlisle, P A 17013 Date~ ~~~ ennifer G son Certified Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. Carlisle, PA 17013 717-243-2968 GMJ;~i$lli<r~":-':~"",ill4,"W--_J;:,ill,jhl~U~4!>>'l:!;~""1>l"I~,",,~..~,);ijig~;;,:'i~'ci"bol;j;j;~.l~""{""~~~tI,-",i~~~-ii~ a - ~~~~ -~/ . ~ iniitlM~. &:.Lftrn:r "'-"....'m1:#:i1;!i..::,i~:. _~ , ~n "~, ,- -~, i1~'~i'i"_c. ".,,,,,,-,,,-~~ o ~ -cr._, n~l!-' ~7 '---, ~,_. -;-, -/r-- (~;'-T <,' .' Gt=-~: ',-'" .~" 2~;-.-< )>c.: L: -.--t -<. ,~,_.~ ',-:' !' i , , : ~ I " '1 ,..--'- t::;) C,) .".) t.) 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