HomeMy WebLinkAbout01-2911 FX
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MAY 1 4 ZOOl
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HEATHER SHANEZ EARLY,
Plaintiff
: IN TIffi COURT OF COMMON PLEAS OF
vs,
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01- ;J111
CIVIL TERM
JASON GEORGE COLLINS,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed
against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In
particular, you may be evicted from your residence and lose other important rights.
A hearing on this matter is schednled on the~ day of May, 2001, at ;;.'.30 fJ. .m., in
Courtroom No....:L- on the 4th Floor of the Cumberland County Courthouse, 1 Courthouse Square,
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 in jail under 23 Pa. C.S. 96114. Violation may also subject you to prosecution and criminal penalties
under the Pennsylvania Crimes Code, Under federal law, 18 US.C, 92265, this Order is enforceable
anywhere in the United States, tribal lands, US. 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 US.C. 92261-2262,
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 find out where you can get legal help. If
you cannot find a lawyer, you may have to proceed without one.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue, Carlisle, Pennsylvania 17013
Telephone Number: (717)249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before the court. You must attend the
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scheduled conference or hearing. . '
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HEATHER SHANEZ EARLY,
Plaintiff
: In the Court of Common Pleas of
: CUMBERLAND County,
v,
: Pennsylvania
: No, 01- ~1((
JASON GEORGE COLLINS,
Defendant
: Protection From Abuse and
: Custody
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: JASON GEORGE COLLINS
Defendant's Date of Birth is: June 6, 1974 .
Defendant's Social Security Number is: 189-60-6110
Name(s) of All protected persons, including Plaintiff and minor children:
1. HEATHERSHANEZEARLY
AND NOW, on 14th Day of May, 2001 upon consideration of the attached Petition
for Protection from Abuse, the court hereby enters the following Temporary Order:
Plaintiff's request for a temporary protection order is granted.
1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any
place where they might be found.
2. Except for such contact with the minor child/ren as may be pennitted under
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paragraph 4 of this Order, 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.
Plaintiff's curreut resideuce, which is uudisclosed for her protectiou, and auy
other locatiou where she may stay for the duration of this Order.
Plaintiff's placed of employment, wherever that may be.
The child care facility, wherever that may be.
3. Except for such contact with the minor child/ren as may be permitted under
paragraph 4 of this Order, 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. Pending the outcome of the final hearing in this matter, Plaintiff is awarded
temporary custody of the following minor child/ren:
1. JASON DYLAN COLLINS
Until the final hearing, all contact between Defendant and the child/ren shall be
limited to the following:
Pending further Order of Court after the hearing scheduled in this matter,
Defeudant's contact with the minor child shall be by supervised visitation.
DefeudlUlt shall contact MidPenn Legal Services, attorneys for Plaintiff, at 1-
800-822-5288 to arrange for the visitation.
The local law enforcement agency in the jurisdiction where the child/ren are
located shall ensure that the child/ren are placed in the care and control of the
Plaintiff in accordance with the terms of this Order.
5. The following additional relief is granted:
Defendant is prohibited from having any contact with Plaintiff's relatives.
Defendant is ordered to refrain from harassing Plaintiff's relatives.
Defendant is enjoined from damaging or destroying any property owned
solely by Plaintiff.
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6. A certified copy of this Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
NEW CUMBERLAND 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 lMIMEDIATEL Y TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL NOVEMBER 14, 2002 OR UNTIL
OTHERWISE MODIFIED OR TERlvllNATED BY THIS COURT AFTER
NOTICE AND HEARING.
NOTICE TO THE DEFENDAl"'-T
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 iail. 23 Pa,c.S, 96114, 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 fi1i.!lg of appropriate court papers for that purpose, 23 Pa,C.S.
96113, Defendant is further notified that violation of this Order may subject himlher
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LV aLw HaJ. Cl:) a.l U P .1 LJ. 0. ,lUCJ. un:. -1 CiJ..Ul.iJiYJ.vaL a. '-' .11'1:;;;:) U C LU LV .L 1.
charges and penalties under the Violence Against Women Act, 18 U.S,C, 992261-
2262.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shaH be enforced by the police who have jurisdiction over the plaintiff's
residence OR any location where a violation ofthis order occurs OR where the
defendant may be located. If defendfuit 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 onaw 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. Weanons must forthwith be delivered to the Sheriff's office of the countv
which issued this Order, which office shall maintain possession of the weapons'until
fhrthpr ()rrll3T Af+h1C! ('"Al1n llnlpC!s thp. n1ea~('\n/o arp p,,~rlp.n~~ oj' 0 ~n.fY'lP -in urh-ich
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case, they shall remain with the law enforcement agency whose officer made the
arrest.
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BY THE COURT:
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Judge
Date
Distribution to:
MidPenn Legal Services
8 Irvine Row, Carlisle, P A 170 I3
(7] 7) 243-9400 or ] -800-822-5288
tRUE COpy FROM RECORD
In T ostirnooy willlrllOf. I here unto set my hand
tIl1d tOO ooal 01 said n ~t 1~lslI'l. Pa.
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FA.Xed & mailed to PSP
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HEATHER SHANEZ EARLY,
Plaintiff
v.
JASON GEORGE COLLINS,
Defendant
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PFADNumber: SA1245845M
: In the Court of Common Pleas of
: CUMBERLAND County,
: Pennsylvania
; No. 01- ,;).c;ll
: Protection From Abuse and
: Custody
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiff's name is:
HEATHER SHANEZ EARLY
2, I, (the Plaintiff), am filing this Petition on behalf of:
- myself
3, Name(s) of ALL person(s), including minor children, who seek protection from abuse,
a. HEATHERSRANEZEARLY
4, Plaintiff's Address is : CONFIDENTIAL
5, Defendant's Name is:
JASON GEORGE COLLINS
6, Defendant is believed to live at the following address:
19 Shady Lane, Enola, PA 17025
7. Defendant's Social Security Number is:
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189-60-6110
8, Defendant's Date of Birth is:
June 6, 1974
9, Defendant's Place of employment is:
Joe's Tree Service, Enola, PA
10, Defendant is an adult.
11, The relationship between the Plaintiff and the Defendant is:
Parents of the same children
Cnrrent or former sexual/intimate partner
12, The defendant has been involved in a criminal court action.
13, The defendant is currently on probation I parole.
14. The defendant is currently on County probationJparole.
Description: Cumberland County, PA, Probatiou Officer: Greg Richardson
15, Plaintiff and Defendant are the parents of the following minor child/ren:
a. JASON DYLAN COLLINS
Age: 8 months old
Child's address is: CONFIDENTIAL
16, Plaintiff is seeking an Order of child custody as part of this petition,
The following is a list of the children and where they have live for the past 5 years:
a. Jason Dylan Collins
F or,the past 5 years, this child has lived with:
Plaintiff at an undisclosed location from May 3, 2001, to the present.
Plaintiff and Defendant at 276 Susquehanna Avenue, Enola, P A, from March
3, 2001 to May 3, 2001.
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Plaintiff at Vantage Honse Rehabilitation Center, Lancaster, PA, from
December 20, 2001, to March 3, 2001.
Plaintiff at the The Salvation Army's Stewart House, South Hanover and East
. Pomfret Streets, Carlisle, PA, from October 2000, to December 20,2001.
Defendant, Sherri Collins, Brandy D., and Amber and Poncho Early, at 276
Susquehanna Avenue, Enola, PA, from September 23,2000, to October 2000.
Plaintiff, Defendant, and Sherri Collins, at 276 Susquehanna Avenue, Enola,
PA, from September 14, 2000, to September 23,2000.
Plaintiff, at The Lourdes House, Livingston Street, Steelton, PA, from the date
of Jason Dylan Collins' birth on September 5, 2000, to September 14, 2000.
17, The facts of the most recent incident of abuse are as follows:
On about Thursday, May 03, 2001
Defendant refused to return the parties' 8-month-old baby, Jason, to Plaintiff unless she went to
Perry County with him to pick up the child. Fearing that Defendant would continue to withhold
the child from her if she did not go along, Plaintiff got into his car. Defendant drove recklessly
and at high speeds from Enola in Cumberland County to the house where the baby was in Perry
County, causing Plaintiff to fear for her safety. After picking up the baby, Defendant drove
Plaintiff and the child back to his mother's home in Enola. Defendant became angry when
Plaintiff tried to leave with the baby, got into her car, refused to get out, and yelled at her. As
she drove, Defendant punched the windshield with such force that it shattered, threatened to kill
her and himself, and choked her. Defendant threatened to cause Plaintiff to wreck her friend's
car, grabbed the steering wheel twice, and shifted the automatic transmission into park causing
the car to stop. Defendant spat chewing tobacco on Plaintiff and about the ear, poured beer on
the seat, kicked his feet through the windshield, and repeatedly puncbed the side windows,
shattering the passenger side window and lacerating his arm. Plaintiff drove Defendant to the
Emergency Room at Holy Spirit Hospital and telephoned 911 for help. Officers from the East
Pennsboro Township and West Shore Regional Police Departments responded, Plaintiff reported
the incident, and the police charged him with vandalizing the car.
18, Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor child/ren,
(including any threats, injuries, or incidents of stalking) are as follows:
In mid April,2001, Defendant yelled in Plaintiff's face while she held their 7-month-old baby,
and threw her clothing outside.
In or about early April 2001, Defendant argued with Plaintiff on the street in front of their
residence, and tore both her shirts off, preventing her from leaving.
On or about September 24, 2000, Defendant called Plaintiff vile names, followed her outside to
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her car, and repeatedly punched her car windshield shattering it.
On or abont September 23, 2000, Defendant, who was in the front passenger seat, argned with
Plaintiff, yelled at her and the parties' 3-week-old infant and Plaintiff's 3-year-old danghter, who
were in their car seats in the back seat. While Plaintiff was standing outside the car at the
driver's side, Defendant leaned over, tnrned the keys in the ignition and started the car, and
pushed the accelerator down with his hand, cansing the car to lurch backward. When Plaintiff
jumped into the car and stopped the car, Defendant grabbed a beer bottle, smashed it against
the windshield, causing it to crack, screamed at her, grabbed her head, and repeatedly slammed
her head against the driver's side window.
On or about September 19, 2000, Defendant grabbed Plaintiff by tbe back of the neck, shoved
her face into the couch, and screamed at her.
In or about August 2000, Defendant, who was driving the car, threatened to kill himself, drove
recklessly and at high speeds causing Plaintiff, who was 8 months pregnant, to fear for ber safety
and that of her unborn child, and punched the passenger side window of the car breaking it.
On or about late July, 2000, Defendant grabbed Plaintiff's head with both his hands and
squeezed it, then shoved her to the ground. Plaintiff was 7 months pregnant at the time.
In or about July 2000, when Plaintiff was 7 months pregnant, Defendant yelled in her face,
grabbed her by the neck, lifted her up off of the floor, and pushed her down onto the couch
ontop of her 3-year-old daughter, who was sitting on the couch, and choked Plaintiff until she
could not talk or breathe. A friend intervened and Defendant let go of Plaintiff. Plaintiff
sustained soreness about her neck as a result of this incident, and was unable to talk or breathe
for several seconds after Defendant released her.
Since approximately September 1999, Defendant has abused Plaintiff in ways including, but not
limited to, shoving, slapping, choking, and pulling her hair. On several occassions Defendant
drove his car toward Plaintiff, causing her to have to move to avoid being hit and placing her in
fear for her safety. Defendant threw household objects at Plaintiff including, but not limited to:
telephones, a lamp which broke when it hit the wall leaving a hole in the wall, a hot pizza which
had just been taken from the oven.
19, The police department(s) or law enforcement agencies that should be provided with a copy of the
protection order are:
NEW CUMBEP.LAND POLICE DEPARTMENT
20, There is an inunediate and present danger of further abuse from the Defendant,
21. Plaintiff has suffered out-of-pocket financial losses as a result of the abuse described above, Those
losses are:
the cost Plaintiff incurred to replace the windshield on her car which was destroyed by
Defendant during the incident which occured on or about September 24, 2000, and the cost to
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replace Plaintiff's passenger-side car window which Defendant broke during the incident which
occured in or about August 2000.
22. 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 childlren in any place where Plaintiff may be found.
b, Award Plaintiff temporary custody of the minor child/ren and place the following
restrictions on contact between Defendant and child/ren:
Pending fnrther Order of Court after the hearing scheduled in this matter,
Defendant's contact with the minor child shall be by supervised visitation.
Defendant shall contact MidPenn Legal Services, attorneys for Plaintiff, at 1-
800-822-5288 to arrange for the visitation.
c, Prohibit Defendant from having any contact with Plaintiff and/or minot 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, Prohibit Defendant from having any contact with Plaintiff's relatives and Plaintiff's
children listed in this petition, except as the court may find necessary with respect to
partial custody and/or visitation with the minor child/ren,
e. Direct Defendant to pay Plaintiff for the reasonable financial losses suffered as the
result of the abuse, to be determined at the hearing.
f Order Defendant to pay the costs of this action, including filing and service tees.
g, Order the following additional relief, not listed above:
Order Defendant to refrain from harassing Plaintiff relatives.
Enioin Defendant from damal!inl! or destrovinl! anv DrODertv owned solelv bv
Plaintiff.
Order Defendant to pay $250.00 to one of MidPenn Legal Services' funding
sources to pay the cost of litigating this case.
h. Grant such other relief as the court deems appropriate,
1. 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
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will inform the designated authority of any addresses, other than the Defendant's
residence, where Defendant can be served.
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Respectfully Submitted by: .~ ~'-c.u
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Agency:
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Joan Carey, Att. for Plain'
MidPenn Legal Services
8 Irvine Row
Carlisle, P A 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.
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HEATHER SHANEZ EARLY,
PlaiIltifl'
v.
JASON GEORGE COLLINS,
Defendant
PFAD Number: SA1245845M
: In the Court of Common Pleas of
: CUMBERLAND County,
: Pennsylvania
.
;No,OI-,;l.911 ~ /~
: Protection From Abuse and
: Custody
PETITION FOR PROTECTION FROM ABUSE
1, Plaintiffs name is:
HEATHER SHANEZ EARLY
2, I, (the Plaintiff), am filing this Petition on behalf of:
- myself
3. Name( s) of ALL person( s), including minor children, who seek protection from abuse.
a. HEATHER SHANEZ EARLY
4, Plaintiffs Address is: CONFIDENTIAL
5, Defendant's Name is:
JASON GEORGE COLLINS
6. Defendant is believed to live at the following address:
19 Shady Lane, Enola, P A 17025
7. Defendant's Social Security Number is:
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189-60-6110
8. Defendant's Date of Birth is:
June 6,1974
9. Defendant's Place of employment is:
Joe's Tree Service, Enola, PA
10, Defendant is an adult.
11. The relationship between the Plaintiff and the Defendant is:
Parents of the same children
Currfllt or former sexual/intimate partner
12, The defendant has been involved in a criminal court action.
13, The defendant is currently on probation I parole.
14. The defendant.is currently on County probation J parole.
Description: Cumberland County, PA, Probation Officer: Greg Richar-dson
15, Plaintiff and Defendant are the parents of the following minor child/ren:
a. JASON DYLAN COLLINS
Age: 8 months old
Child's address is: CONFIDENTIAL
16, Plaintiff is seeking an Order of child custody as part of this petition.
The following is a list of the children and where they have live for the past 5 years:
a. Jason Dylan Collins
For the past 5 years, this child has lived with:
Plaintiff at an undisclosed locatien frem May 3, 2001, te the present.
Plaintiff and Defendant at 276 Susquehanna Avenue, Enela, PA, from March
3, 2001 to May 3, 2001.
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Plaintiff at Vantage House Rehabilitation Center, Lancaster, PA, from
December 20, 2001, to March 3, 2001.
Plaintiff at the The Salvation Army's Stewart House, South Hanover and East
Pomfret Streets, Carlisle, PA, from October 2000, to December 20, 2001.
Defendant, Sherri Collins, Brandy D., and Amber and Poncho Early, at 276
Susquehanna Avenue, Enola, PA, from September 23,2000, to October 2000.
Plaintiff, Defendant, and Sherri Collins, at 276 Susquehanna Avenue, Enola,
PA, from September 14, 2000, to September 23, 2000.
Plaintiff, at The Lourdes House, Livingston Street, Steelton, PA, from the date
of Jason Dylan Collins' birth on September 5, 2000, to September 14, 2000.
17, The facts of the most recent incident of abuse are as follows:
On about Thursday, May 03, 2001
Defendant refused to return the parties' 8-month-old baby, Jason, to Plaintiff unless she went to
Perry County with him to pick up the child. Fearing that Defendant would continue to withhold
the child from her if she did not go along, Plaintiff got into his car. Defendant drove recklessly
and at high speeds from Ennla in Cumberland County to the house where the baby was in Perry
County, causing Plaintiff to fear for her safety. After picking up the baby, Defendant drove
Plaintiff and the child back to his mother's home in Enola. Defendant became angry when
Plaintiff tried to leave with the baby, got into her car, refused to get out, and yelled at her. As
she drove, Defendant punched the windshield with such force that it shattered, threatened to kill
her and himself, and cbokedher. Defendant threatened to cause Plaintiff to wreck her friend's
car, grabbed the steering wheel twice, and shifted the automatic transmission into park causing
the car to stop. Defendant ,spat chewing tobacco on Plaintiff and about the car, poured beer on
the seat, kicked his feet through the windshield, and repeatedly punched the side windows,
shattering the passenger side window and lacerating his arm. Plaintiff drove Defendant to the
Emergency Room at Holy Spirit Hospital and telephoned 911 for help. Officers from the East
Pennsboro Township and West Shore Regional Police Departments responded, PIaintiff reported
the incident, and the police charged him with vandalizing the car.
18, Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor child/ren,
(including any threats, injuries, or incidents of staIking) are as follows:
In mid April,2001, Defendant yelled in Plaintiff's face while she held their 7-month-old baby,
and threw her clothing outside.
In or about early April 2001, Defendant argued with Plaintiff on the street in front of their
residence, and tore both her shirts off, preventing her from leaving.
On or about September 24, 2000, Defendant called Plaintiff vile names, followed her outside to
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her car, and repeatedly punched her car windshield shattering it.
On or about September 23,2000, Defendant, who was in the front passenger seat, argued with
Plaintiff, yelled at her and the parties' 3-week-old infant and Plaintiff's 3-year-old daughter, who
were in their car seats in the back seat. While Plaintiff was standing outside the car at the
driver's side, Defendant leaned over, turned the keys in the ignition and started the car, and
pushed the accelerator down with his hand, causing the car to lurch backward. When Plaintiff
jumped into the car and stopped the car, Defendant grabbed a beer bottle, smashed it against
the windshield, causing it to crack, screamed at her, grabbed her head, and repeatedly slammed
her head against the driver's side window.
On or about September 19, 2000, Defendant grabbed Plaintiff by the back of the neck, shoved
her face into the couch, and screamed at her.
In or about August 2000, Defendant, who was driving the car, threatened to kill himself, drove
recklessly and at high speeds causing Plaintiff, who was 8 months pregnant, to fear for her safety
and that of her unborn child, and punched the passenger side window of the car breaking it.
On or about late July, 2000, Defendant grabbed Plaintiff's head with both his hands and
squeezed it, then shoved her to the ground. Plaintiff was 7 months pregnant at the time.
In or about July 2000, when Plaintiff was 7 months pregnant, Defendant yelled in her face,
grabbed her by the neck, lifted her up off of the floor, and pushed her down onto the couch
ontop of her 3-year-old daughter, who was sitting on the couch, and choked Plaintiff until she
could not talk or breathe. A friend intervened and Defendant let go of Plaintiff. Plaintiff
sustained soreness about her neck as a result of this incident, and was unable to talk or breathe
for several seconds after Defendant released her.
Since approximately September 1999, Defendant has abused Plaintiff in ways including, but not
limited to, shoving, slapping, choking, and pulling her hair. On several occassions Defendant
drove his car toward Plaintiff, causing her to have to move to avoid being hit and placing her in
fear for her safety. Defendant threw hOJlsehold objects at Plaintiff including, bnt not limited to:
telephones, a lamp which broke when it hit the wall leaving a hole in the wall, a hot pizza which
had just been taken from the oven.
19. The police department( s) or law enforcement agencies that should be provided with a copy of the
protection order are:
NEW CUMBERLAND POLICE DEPARTMENT
20. There is an immediate and present danger of further abuse from the Defendant.
21. Plaintiff has suffered out-of-pocket financial losses as a result of the abuse described above, Those
losses are:
the cost Plaintiff incurred to replace the windshield on her car which was destroyed by
Defendant during the incident which occured on or about September 24, 2000, and the cost to
I
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replace Plaintiff's passenger-side car window which Defendant broke during the incident which
occnred in or about August 2000.
22. 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" Award Plaintiff temporary custody of the minor child/ren and place the following
restrictions on contact between Defendant and child/ren:
Pending further Order of Court after the hearing scheduled in this matter,
Defendant's contact witb the minor cbild sball be by supervised visitation.
Defendant shall contact MidPenn Legal Services, attorneys for Plaintiff, at 1-
800-822-5288 to arrange for the visitation.
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 ~t Plaintiff's school, business, or place of
employment, except as the court may firtd necessary with respect to partial custody
and/or visitation with the minor child/ren.
d, Prohibit Defendant from having any contact with Plaintiff's relatives and Plaintiff's
children listed in this petition, except as the court may firtd necessary with respect to
partial custody and/or visitation with the minor child/ren.
e, Direct Defendant to pay Plaintiff for tbe reasonable financial losses suffered as the
result of the abuse, to be determined at the hearing,
f. Order Defendant to pay the costs ofthis action, including filing and service fees,
g, Order the following additional relief, not listed above:
Order Defendant to refrain from harassing Plaintiff relatives.
Enioin Defendant from damal!:inl!: or destrovinl!: any orooertv owned solely bv
Plaintiff.
Order Defendant to pay $250.00 to one of MidPenn Legal Services' funding
sources to pay the cost of litigating this case.
h, Grant such other relief as the court deems appropriate.
I. 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
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will inform the designated authority of any addresses, other than the Defendant's
residence, where Defendant can be served,
Respectfully Submitted by:
Joan Carey, Att. for Plaint'
Agency: MidPenn Legal Services
8 Irvine 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.
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HEATHER SHANEZ EARLY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs,
JASON GEORGE COLLINS,
Defendant
: NO.Ol- de; I{ CIVIL TERM
: PROTECTION FROM ABUSE AND CUSTODY
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following papers, you must appear 8,t the hearing scheduled herein. If you fail to do so, the case may proceed
against you and 3 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 tkis matter is scheduled on the).1 S~ay of May, 2001, at tJ; 3.J ,-,,'1m., in
Courtroom No..3.- ou the 4th Floor of the Cnmberland County Courthouse, 1 Courthousl Square,
Carlisle, Pennsyfvania,
You MUST obey the Order that is attached until it is modified or terminated by the ~urt after notice
and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subjt(ct you
to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six
months in jail under 23 Pa.c. S. ~6114. Violation mayldso subject you to prosecution and criminal penaIties
under the Pennsylvania Crimes Code. Under federal law, 18 US,C. ~2265, this Order is enforceable
anywhere in the United States, tribal lands, US. 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 notha\i'ea laV\'}'er or
cannot afford one, go to orte1ephone the office set forth below to find out where you can get!egal help. If
you cannot find a lawyer, you may have to proceed without one.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue, Carlisle, Pennsylvania 17013
Telephone Number: (717)249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the Am~cans
with Disabilities Act of 1990. For infonnation about accessible facilities and reasonable accbmmodations
available to disable(jindividuals having business before the court, please contact our office. All arrang~ents
must be made at least 72 hours prior to any hearing or business before ~e pourt. You qlUst attepd the
scheduled conferem:e or hearing, . '
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HEATHER SHANEZ EARLY,
Plaintiff
: In the Court of Common Pleas of
: CUMBERLAND County,
v.
: Pennsylvania
.
: No, 01- ;),'1/1
JASON GEORGE COLLINS,
Defendant
: Protection From Abuse and
: Custody
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: JASON GEORGE COLLINS
Defendant's Date of Birth is: June 6, 1974
Defendant's Social Security Number is: 189-60-6110
Name(s) of All protected persons, including Plaintiff and minor children:
1. HEATHER SHANEZ EARLY
AND NOW, on 14th Day of May, 2001 upon consideration of the attached Petition
for Protection from Abuse, the court hereby enters the following Temporary Order:
Plaintiff's request for a temporary protection order is granted.
1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any
place where they might be found,
2. Except for such contact with the minor child/ren as may be permitted under
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paragraph 4 of this Order, 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.
Plaintiff's cnrrent residence, which is undisclosed for her protection, and any
other location where she may stay for the dnration of this Order.
Plaintiff's placed of employment, wherever that may be.
The child care facility, wherever that may be.
3. Except for such contact with the minor child/ren as may be permitted under
paragraph 4 ofthis Order, 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. Pending the outcome of the final hearing in this matter, Plaintiff is awarded
temporary custody of the following minor child/ren:
1. JASON DYLAN COLLINS
Until the final hearing, all contact between Defendant and the child/ren shall be
limited to the following:
Pending fnrther Order of Court after the hearing scheduled in this matter,
Defendant's contact with the minor child shall be by supervised visitation.
Defendant shall contact MidPenn Legal Services, attorneys for Plaintiff, at 1-
800-822-5288 to arrange for the visitation.
The local law enforcement agency in the jurisdiction where the child/ren are
located shall ensure that the child/ren are placed in the care and control of the
Plaintiff in accordance with the terms of this Order.
5. The following additional relief is granted:
Defendant is prohibited from having any contact with Plaintiff's relatives.
Defendant is ordered to refrain from harassing Plaintiff's relatives.
Defendant is enjoined from damaging or destroying any property owned
solely by Plaintiff.
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6. A certified copy ofthis Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
NEW CUMBERLAND 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
~erved The Prothonotarv i~ directed to file thi~ Petition and Order without
- - - , - - - - - J -- - - . - ~ -. - -- -
prepayment of costs.
8. TillS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTiL NOVEMBER 14, 2002 OR UNTiL
OTHERWISE MODIFIED OR TERMINATED BY THIS COURT AFTER
NOTICE AND HEARING,
NOTICE TO THF, 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, 96114. 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 fil1'1g ofappropnate court papers for that purpose. 23 Pa.C.S.
~6113, Defendant is further notified that violation of this Order may subject himJher
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charges and penalties under the Violence Against Women Act, 18 US.C. 9~2261-
2262,
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the police \vho have jurisdiction over the plaintiifs
residence OR any location where a violation of this order occurs OR where the
A-<'-nA--' may 1.._ '_ca'M' Tf A-<'--d--t ":-l-'M nO"a-nn-hs 1 '1..-0"-1.. A of'1..:. "rd-n
U~LCl U4.iu. U ~ IV ..~. 1. U'VU;:;l1 an v IV at'VO) 1.- Q..l OJ. 4Vl 1 Ull UOJ.1 ""t UllO) V 'VI,
defendant shall be arrested on the charge of Indirect Criminal Contempt. An arrest
for violation of this Order may be made withoui warrani, 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
fhrt'hpr nr~p.1'" nf't'h1(! (>nnrl lUllilp.QQ thp. uTP>'3.n.n.n/'t! c;:a-rp. p.u;r1~I'p "f'.l cn'""p l'n'l1.7h;f"h
..................s....s .......s...................... "'............................"', ........"" t4..L.... .."""I"......u,............... ........-u................... .........0,4- ................., ..s ....................s
case, they shall remain with the law enforcement agency whose officer made the
arrest.
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Distribution to:
MidPenn Legal Services
8 Irvine Row, Carlisle, P A 17013
(717) 243-9400 or 1-800-822-5288
FAXed & mailed to PSP
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CUMB CO PROTHONOTARY
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OFfICE OF TI-lE PRan-lCllOTARY
CUMBERLAND CXXJNTY CQURTHOOSE
ONE <XXJRTHCXJSE SQUARE
CARLISLE, PA. 17013-3387
(717) 240-6195
FAX (717) 240-6573
V I ATE L E COP I E R
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PA STATE POLICE . ~e~TA4 r~.~a$$.-
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SHERIFF'S RETURN - REGULAR
CASE NO: 2001-02911 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
EARLY HEATHER SHANEZ
VS
COLLINS JASON GEORGE
SGT. DAVID ZEIGLER
, Sheriff or Deputy Sheriff of
Cumberland County,pennsylvania, who being duly sworn according to law,
says, the within PROTECTION F~OM ABUSE
was served upon
COLLINS JASON GEORGE
the
DEFENDANT
, at 0009:35 HOURS, on the 17th day of May
, 2001
at CUMBERLAND CO. SHERIFF'S OFF
1 COURTHOUSE SQUARE
CARLISLE, PA 17013
by handing to
JASON COLLINS
a true and attested copy of PROTECTION FROM ABUSE
together with
AND CUSTODY, NOTICE OF HEARING & ORDER
TEMP PFA, PETITION
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:
~~J~-t:~
R. Thomas Kline
05/17/2001
Sworn and Subscribed to before
By:
4J;jfif?
me this :t3~
day of
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Cfr-Q ~ip'A~AP:;
rothonotary
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HEATHER SHANEZ EARLY,
Plaintiff
: In the Court of Common Pleas of
: CUMBERLAND County, Pennsylvania
vs,
: No, 01-2911 Civil Term
JASON GEORGE COLLINS,
Defendant
: Protection From Abuse and Custody
O. ER FOR CONTINUANCE
AND NOW, thiS1Jf da of May, 2001, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on Monday, May 21, 2001, by this Court's Order of
May 14,2001, is hereby continued generally,
This Order is entered without prejudice to either party to request a hearing.
TIle Temporary Protection From Abuse Order shall remain in effect for a period of 18 months
from the date it was entered, through November 14, 2002, or until further Order of Court, whichever
comes first.
By the Court,
Joan Carey, Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
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Philip H. Spare, Attorney for Defendant
Snelbaker Brenneman & Spare
44 West Main Street
Mechanicsburg, PA 17055
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HEATHER SHANEZ EARLY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 01"2911 CIVIL TERM
JASON GEORGE COLLINS,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
MOTION FOR CONTINUANCE
Plaintiff; Heather Shanez Early, by and through her attorney, Joan Carey of MidPenn Legal
Services, moves the Court for an Order continuing generally the hearing in the above-captioned case
on the grounds that:
1. A Temporary Protection From Abuse Order was issued by this Court on May 14, 2001,
scheduling a hearing for May 21, 2001, at 2:30 p,m, in Courtroom No, 3,
2. The Cumberland County Sheriff's Department served Defendant with a certified copy of
the Temporary Protection From Abuse Order and Petition for Protection From Abuse on May 17,
2001, at 9:35 a.m. in the Cumberland County Sheriff sDepartment, Cumberland County Courthouse,
1 Courthouse Square, Carlisle, Pennsylvania,
3. Defendant has retained Philip H. Spare of Sne1baker Brenneman & Spare to represent
him in the matter
4. The parties agree, by and through their respective counsel, that the hearing be continued
generally pending further Order in this matter.
5. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for
a period of 18 months from the date it was entered, through November 14, 2002, or until further
Order of Court, whichever comes first.
;~, - ~=- - ".," . ~-~
WHEREFORE, 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 18
months from the date it was entered, through November 14, 2g02, or until further Order of Court,
whichever comes first,
~-~
~ Attomeyfi Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
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., --
HEATHER SHANEZ EARLY,
Plaintiff
: In the Court of Common Pleas of
: CUMBERLAND County, Pennsylvania
vs,
: No, 01-2911 Civil Term
JASON GEORGE COLLINS,
Defendant
: Protection From Abuse and Custody
ORDER FOR CONTINUANCE
AND NOW, this X<ray of May, 2001, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on Monday, May 21,2001, by this Court's Order of
May 14, 2001, is hereby continued generally,
This Order is entered without prejudice to either party to request a hearing,
The Temporary Protection From Abuse Order shall remain in effect for a period of 18 months
from the date it was entered, through November 14, 2002, or until further Order of Court , whichever
comes first.
By the Court,
Ii ~lJ-\~ ~. #f6n~
rge E. Hoffer, President Judg
Joan Carey; Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
r RUE COpy FROM RECORD
ijIT1 T 3st~no~~~" wr~f~~~ ~ ! ~er{~ Ufl~(~ sm my j;afU)
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Philip H. Spare, Attorney for Defendant
Snelbaker Brenneman & Spare
44 West Main Street
Mechanicsburg, PA 17055
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.MAY 1 4ZDDl
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HEATHER SHANEZ EARLY,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
vs.
; NO. 01- ~111
CIVIL TERM
JASON GEORGE COLLINS,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed
against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In
particular, you may be evicted from younesidence and lose other important rights.
A hearing on this matter is scheduled on thedJAof' day of May, 2001, at ;;:.30 fl, .m., in
Courtroom No....3.- on the 4th Floor of the Cumberland County Courthouse, 1 Courthouse Square,
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 in jail under 23 Pa. C. S. ~6114, Violation may also subject you to prosecution and criminal penalties
under the Pennsylvania Crimes Code, Under federal law, 18 US,C. ~2265, this Order is enforceable
anywhere in the United States, tribal lands, US. Tenitories 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 US.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 find out where you can get legal help. If
you cannot find a lawyer, you may have to proceed without one.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue, Carlisle, Pennsylvania 17013
Telephone Number: (717)249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans
with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations
available to disabled individuals having business before the court, please contact our office. All arrangements
must be made at least 72 hours prior to any hearing or business before t~e ~O!lrt. You !)lust attend the
scheduled conference or hearing, , ,
'"""""""'_,w,,-I
HEATHER SHANEZ EARLY,
Plaintiff
: In the Court of Common Pleas of
: CUMBERLAND County,
v,
: Pennsylvania
JASON GEORGE COLLINS,
Defendant
: No. 01- ~lf((
: Protection From Abuse and
: Custody
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is; JASON GEORGE COLLINS
Defendant's Date of Birth is: June 6, 1974 .
Defendant's Social Security Number is: 189-60-6110
Name(s) of All protected persons, including Plaintiff and minor children:
1. HEATHER SHANEZ EARLY
AND NOW, on 14th Day of May, 2001 upon consideration of the attached Petition
for Protection from Abuse, the court hereby enters the following Temporary Order:
Plaintiff's request for a temporary protection order is granted.
1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any
place where they might be found.
2. Except for such contact with the minor child/ren as may be pennitted under
paragraph 4 ofthis Order, 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.
Plaintiff's current residence, which is nndisclosed for her protection, and any
other location where she may stay for the duration of this Order.
Plaintiff's placed of employment, wherever that may be.
The child care facility, wherever that may he.
3. Except for such contact with the minor child/ren as may be permitted under
paragraph 4 of this Order, 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. Pending the outcome of the final hearing in this matter, Plaintiff is awarded
temporary custody of the following minor child/ren:
1. JASON DYLAN COLLINS
Until the final hearing, all contact between Defendant and the child/ren shall be
limited to the following:
Pending further Order of Court after the hearing scheduled in this matter,
Defendant's contact with the minor child shall be by supervised visitation.
Defendant shall contact MidPenn Legal Services, attorneys for Plaintiff, at 1-
800-822-5288 to arrange for the visitation.
The local law enforcement agency in the jurisdiction where the child/ren are
located shall ensure that the child/ren are placed in the care and control of the
Plaintiff in accordance with the terms of this Order.
5. The following additional relief is granted:
Defendant is prohibited from having any contact with Plaintiff's relatives.
Defendant is ordered to refrain from harassing Plaintiff's relatives.
Defendant is enjoined from damaging or destroying any property owned
solely by Plaintiff.
6. A certified copy ofthis Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
NEW CUMBERLAND 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. TIllS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL NOVEMBER 14, 2002 OR UNTIL
OTHERWISE MODIFIED OR TERMINATED BY TIllS COURT AFTER
NOTICE AND HEARING,
NOTICE TO THE DEFEl\'DANT
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 andlor up
to six months injail. 23 Pa.C.S, S6114. Consent of the Plaintiff to Defendant's retul.1l
to the residence shall not invalidate this Order, which can only be changed or
modified throug.h 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 alld penalties under the Pennsylvaiua Crimes Code and to federal
charges and penalties under the Violence Against Women Act, 18 U.S,C. SS2261-
2262.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shan 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 ofthis Order OR during prior incidents of
abuse. Weapons must forthwith be delivered to the Sherift's office of the county
which issued this Order, which office shall maintain possession of the weapons until
ihrlher nrrf""'r ^f' tlu' C! .....nllrt I1nl""'H! th"", nlP~p' 0'" IS arp. Ptrid~"'c~ of a ~n'm~ 1.1'1 "ll.1h1ch
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case, they shall remain with the law enforcement agency whose officer made the
atlest.
BY THE COURT:
/s / IJelM r' f!.ll/f <J
, , . fJ
Judge
Date
Distribution to:
MidPenn Legal Services
8 Irvine Row, Carlisle, PA 17013
(717) 243-9400 or 1-800-822-5288
T RUE COPY FROM RECORD
II! T I'IStlroony wooreof, I hero unto set my llanO
and full sua! 01 said Court at Carllsl3. PIi.
nd~ !f~ day ~~':'J:~ ~L
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"-. I ( llrothonomry
FAXed & mailed to PSP
0.'1'- .
, ,
HEATHER SHANEZ EARLY,
Plaintiff
v.
JASON GEORGE COLLINS,
Defendant
PFAD Number: SA1245845M
: In the Court of Common Pleas of
: CUMBERLAND ComIty,
: Pennsylvania
:No.Ol- ~'111
: Protection From Abuse and
: Custody
PETITION FOR PROTECTION FROM ABUSE
1, Plaintiff's name is:
HEATHER SHANEZ EARLY
2, I, (the Plaintiff), am filing this Petition on behalf of:
- myself
3. Name(s) of ALL person(s), including minor children, who seek protection from abuse.
a. HEATHER SHANEZ EARLY
4. Plaintiff's Address is : CONFIDENTIAL
5. Defendant's Name is:
JASON GEORGE COLLINS
6. Defendant is believed to live at the following address:
19 Shady Lane, Enola, PA 17025
7. Defendant's Social Security Number is:
"C~
189-60-6110
8, Defendant's Date of Birth is:
June 6, 1974
9, Defendant's Place of employment is:
Joe's Tree Service, Enota, PA
10, Defendant is an adult.
11. The relationship between the Plaintiff and the Defendant is:
Parents of the same children
Current or former sexual/intimate partner
12. The defendant has been involved in a criminal conrt action.
13, The defendant is currently on probation I parole.
14. The defendant.is currently on County probation J parole.
Description: Cumberland County, PA, Probation OffICer: Greg Richardson
15. Plaintiff and Defendant are the parents of the following minor child/ren:
a. JASON DYLAN COLLINS
Age: 8 months old
Child's address is: CONFIDENTIAL
16, Plaintiff is seeking an Order of child custody as part of this petition.
The following is a list of the children and where they have live for the past 5 years:
a. Jason Dylan Collins
F or,the past 5 years, this child has lived with:
Plaintiff at an undisclosed location from May 3, 2001, to the present.
Plaintiff and Defendant at 276 Susquehanna Avenue, Enola, PA, from March
3, 2001 to May 3, 2001.
Plaintiff at Vantage House Rehabilitation Center, Lancaster, P A, from
December 20, 2006), to March 3, 2001.
Plaintiff at the The Salvation Army's Stewart House, South Hanover and East
. Pomfret Streets, Carlisle, PA, from October 2000, to December 20, 2006.
Defendant, Sherri Collins, Brandy D., and Amber and Poncho Early, at 276
Susquehanna Avenue, Enola, PA, from September 23,2000, to October 2000,
Plaintiff, Defendant, and Sherri Collins, at 276 Snsquehanna Avenue, Enola,
P A, from September 14, 2000, to September 23, 2000.
Plaintiff, at The Lourdes House, Livingston Street, Steelton, PA, from the date
of Jason Dylan Collins' birth on September 5, 2000, to September 14, 2000.
17, The facts of the most recent incident of abuse are as follows:
On about Thursday, May 03, 2001
Defendant refused to return the parties' 8-montb-old baby, Jason, to Plaintiff unless she went to
Perry County with him to pick up the child. Fearing that Defendant would continue to withhold
the child from her if she did not go along, Plaintiff got into his car. Defendant drove recklessly
and at high speeds from Enola in Cumberland County to the house where the baby was in Perry
County, causing Plaintiff to fear for ber safety. After picking up the baby, Defendant drove
Plaintiff and the child back to his mother's home in EnoIa. Defendant became angry when
Plaintiff tried to leave with the baby, got into her car, refused to get out, and yelled at her. As
,she drove, Defendant punched' the windshield with such force that it shattered, threatened to kill
her and himself, and choked her. Defendant threatened to cause Plaintiff to wreck her friend's
car, grabbed the steering wheel twice, and shifted the automatic transmission into park causing
the car to stop. Defendant spat chewing tobacco on Plaintiff and about the car, poured beer on
the seat, kicked his feet through the windshield, and repeatedly punched the side windows,
shattering the passenger side window and lacerating his arm. Plaintiff drove Defendant to the
Emergency Room at Holy Spirit Hospital and telephoned 911 for help. Officers from the East
Pennsboro Township and West Shore Regional Police Departments responded, Plaintiff reported
the incident, and the police charged him with vandalizing the car.
18. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor chi!d/ren,
(including any threats, injuries, or incidents of stalking) are as follows:
In mid April,2001, Defendant yelled in Plaintiff's face while she held their 7-month-old baby,
and threw her clothing outside.
In or about early April 2001, Defendant argued with Plaintiff on the street in front of their
residence, and tore both her shirts off, preventing her from leaving.
On or about September 24, 2000, Defendant called Plaintiff vile names, followed her outside to
I
her car, and repeatedly punched her car windshield shattering it.
On or about September 23, 2000, Defendant, who was in the front passenger seat, argued with
Plaintiff, yelled at her and the parties' 3-week-old infant and Plaintiff's 3-year-old daughter, who
were in their car seats in the back seat. While Plaintiff was standing outside the car at the
driver's side, Defendant leaned over, turned the keys in the ignition and started the car, and
pushed the accelerator down with his hand, cansing the Cal' to lurch backward. When Plaintiff
jumped into the car and stopped the car, Defendant grabbed a beer bottle, smashed it against
tbe windshield, causing it to crack, screamed at her, grabbed ber bead, and repeatedly slammed
her head against the driver's side window.
On or abont September 19, 2000, Defendant grabbed Plaintiff by the back of the neck, shoved
her face into the concb, and screamed at her.
In or abont Angust 2000, Defendant, who was driving the car, tbreatened to kill himself, drove
recklessly and at high speeds causing Plaintiff, who was 8 months pregnant, to fear for ber safety
and that of ber unborn child, and puncbed the passenger side window of the car breaking it.
On or about late July, 2000, Defendant grabbed Plaintiff's head with both his hands and
sqneezed it, then shoved her to the ground. Plaintiff was 7 months pregnant at the time.
In or about July 2000, when Plaintiff was 7 mouths pregnant, Defendaut yelled in her face,
grabbed her by the neck, lifted her up off of the Ooor, and pushed her down onto the couch
ontop of her 3-year-old daughter, who was sitting on the couch, and choked Plaintiff uutil she
could not talk or breathe. A friend intervened and Defendant let go of Plaintiff. Plaintiff
sustained soreness about her neck as a result of this incident, and was unable to talk or breathe
for several seconds after Defendant released her.
Since approximately September 1999, Defendant has abused Plaintiff in ways including, but not
limited to, shoving, slapping, choking, and pulling her hair. On several occassions Defendant
drove his car toward Plaintiff, cansing her to have to move to avoid being hit and placing her in
fear for her safety. Defendant threw household objects at Plaintiff including, but not limited to:
telephones, a lamp which broke when it hit the wall leaving a hole in the wall, a hot pizza which
had just been taken from tbe oven.
19, The police department(s) or law enforcement agencies that should be provided with a copy of the .
protection order are:
NEW CUMBERLAND POLICE DEPARTMENT
20. There is an immediate and present danger of further abuse from the Defendant.
21. Plaintiff has suffered out-of-pocket financial losses as a result of the abuse described above, Those
losses are:
the cost Plaintiff incurred to replace the windshield on her car which was destrnyed by
Defendant during the incident which occured on or about September 24, 2000, and the cost to
replace Plaintiff's passenger-side car window which Defendant broke during the incident which
occured in or about August 2000.
22. 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, Award Plaintiff temporary custody of the minor child/ren and place the following
restrictions on contact between Defendant and child/ren:
Pending further Order of Conrt after the hearing schednled in this matter,
Defendant's contact with the minor child shaD be by supervised visitation.
Defendant shall contact MidPenn Legal Services, attorneys for Plaintiff, at 1-
800-822-5288 to arrange for the visitation.
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,
induding 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. Prohibit Defendant from having any contact with Plaintiff's relatives and Plaintiff's
children listed in this petition, except as the court may find necessary with respect to
partial custody and/or visitation with the minor child/ren.
e, Direct Defendant to pay Plaintiff for the reasonable financial losses suffered as the
result of the abuse, to be determined at the hearing.
f Order Defendant to pay the costs ofthis action, including filing and service fees,
g, Order the following additional relief, not listed above:
Order Defendant to refrain from harassing Plaintiff relatives.
Enioin Defendant from dama!!in!! or desUovin!! any nronertv owned solelv bv
Plaintiff.
Order Defendant to pay $250.00 to one of MidPenn Legal Services' funding
sources to pay the cost oflitigating this case.
h, Grant such other relief as the court deems appropriate.
1. 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 by/ . _ ~~
f j Joan Carey, Att, for Plaint#'
Agency: MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
~r;!1r05U.
VERIFICATION
I verity 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,g4904, relating
to unsworn falsification to authorities. '
. Dated: ~;; j/
/9