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Home My WebLink About01-03408 .- Robin Elizabeth Zorn, Plaintiff v. Ralph Bernard Zorn Jr., Defendant : IN THE COURT OF : COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYL VANIA : No. 01-3408 : CIVIL ACTION - LAW : PROTECTION FROM ABUSE : AND CUSTODY ORDER TO VACATE AND NOW, this: 21st Day of August, 2001, 1. This matter is dismissed without prejudice. 2. Costs of this proceeding are waived. 3. The Temporary Order (Filed on Jun 4, 2001) is hereby vacated. Distribution to: . MIDPENN ~EGAL SERVICES ~ ~ ~ Faxed & MaIled to PSP -!{ ';1.I-O! @ ",.;;U . Johanna Kopecky, Attorney for Defendant ~ ~ A<a- W Saidis, Shuff, Flower, and Lindsay - / {7 26 West High Street Carlisle, Pa ~, ., ."" -, . ,-r','''' , ~ ~ .tr" _.C.__, --_.:--- . . l'ilH_R~~iliOOW~il1~~Ii.~~~,*,~~;j,,^ti~<i{"Af.~;~.!i!\)1;'i.~Jilio:,~~~_'f.'" .i1!!l~1'1ofV"--- ,clo,~ -''''!iH' ~- " "~~'" ~.,"--".."~,",,, '. '",. . pi '\: n'-', ?: 1\1 .0' ~\lr '/ i (\I~. . Ijl H-..[; \.,,' C' 1""'Ci" '".,) C'.JUi'H'/ v\V'.c,~' ,..I"" ., I'! PENr\SYL\j!~r', \ ,; .. ~ (fl/ACi ..~ -t; 'm;&/<>/-/~ -t; /?.sj:j (!. J?, v- J11./! L.~. ,_6,h,~:,~~td;:J""""Ik_',_ ~J~ _ "'~ .,'~"-'_o', ,',p=<~,,,,,~,,,,, "''' ' .=.f" ~.~_,~;~ '''~ .. "r>~ .. ,"~,,' ".__~_..~ ,- -. Robin Zorn, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 01-3408 CIVIL TERM Ralph Bernard Zorn, Defendant : PROTECTION FROM ABUSE & CUSTODY PETITION TO VACATE ORDER AND WITHDRAW ACTION Plaintiff, Robin Zorn, by and through her attorney, David Lopez ofMidPenn Legal Services, requests that the Court vacate the Temporary Protection From Abuse Order, including custody, in the above-captioned case and that the action be withdrawn on the grounds that: 1. A Petition for Protection From Abuse was filed and a Temporary Protection From Abuse Order was issued by this Court on June 4, 200 I, scheduling a hearing for June 12,2001, at 3:00 p.m. before Judge Hoffer. 2. Cumberland County Sheriff s deputies served Defendant with a certified copy of the Notice of Hearing, Temporary Protection From Abuse Order and Petition for Protection From Abuse on June 6, 2001, at the defendant's residence located at 1150 Crane's Gap Road, Carlisle, Pennsylvania. 3. The parties agreed, by and through their respective attorneys, to the continuance of the hearing: the Order for Continuance entered on August 8, 2001, rescheduled the hearing for October 1,2001, at 2:00 p.m. 4. The parties are in the process of reconciling their differences and attending counseling. 5. Plaintiff requests that the Temporary Protection From Abuse Order which includes -i1f-j} '0 k - -," ~. custody, entered on Jooe 4, 2001, be vacated and the action withdrawn without prejudice to her. WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate the Order, and that the action be withdrawn without prejudice to Plaintiff. Respectfully submi ted, / I Carey and David Lop Attorneys for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 '-'H__>__", VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. ~4904, relating to unsworn falsification to authorities. Dated: PJ'~ () / 0 7 ~)1I1~l~A, o III Zorn, P aintiff 'S-"J", ~'''-;' ,C' u, .'''-'" ~.. ~ <<..,'= ,- ~"'~ ,< ""-j" ~". .""",-.'~,.." "",,",~:o,~..,~,,- ., "nr Q C:) , , f.) ~ n ,- :> , " IT! ::.' :;-) -;-; (II ~ 1.= /:. C-- "'.) i::) (f) -< , r: -'i ~? j:; , '-"'i C~ ~ C:',; (=) C~ C) '" Z ~ =< - :JJ C) -< Ii " I--::! .'. ,.111.-__ ~ ''''.'' .~,lJ!~_,_ '0_. J~ ~,. . ~~~~,~ ,rr,jli!!\~~~:!:.oT'J~ffl~~;,j;'f"i;r-'tl:r-i,!~",'ni*l"h~1':;6i~H:7al~_~~%-:i'.'0'?~*,1'b"!~Of~~W_~~,~.il~IH~ Robin Elizabeth Zorn, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 01- 3408 CIVIL TERM Ralph Bernard Zorn, Jr., Defendant : PROTECTION FROM ABUSE AND CUSTODY ORDER FOR CONTINUANCE AND NOW, this 7th day of August, 2001, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on August 7, 200 I, at 3 :00 p.m. by this Court's Order ofJune 7, 2001, is hereby rescheduled for hearing on October 1st, 2001, at 2:00 p.m. in Courtroom No.3. The Temporary Protection From Abuse Order shall remain in effect for a period of eighteen months from the date it was entered, through December 4, 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 Johnna Kopecky, Attorney for Defendant ~ ~ SAIDIS, SHUFF, FLOWER, AND LINDSAY 26 West High Street Carlisle, PA 17013 r./(..Ol 4- 'J.._-<< , ',' -n~; _,~ - ,-'_4-" - '-'-"'_' , - , , (-.'" .. - " , ~ . ~:iiit<~!ji!Jd'!#t!1I;ii",b:JwJf!;?<t''-btG!''~~~,).~M'.;b,,''i;~<:Hili*,0'@'"Jh~(';'<':L_}C!'~j,fG~\4"it"T"'ja..ii".\;."~"':,,,,i!W'~j;iijW~~!~~-'.~~~j~lliMt..~~~~J.. t:1J,{~ ~'c,,~,,^,,;:,I', '""",,:r_-',,~ ,_,"""~~""~ _~~" ,.eo ._%,',~_<__ ""_\"~'~""" ..~"n=' ,. Z<,~, _'~ ." -,--,,-.r; C;-\-(\\'\'-\'V'''r--.-r'I\l:J:'f .',_'.- :'~--r,,;(\<\)\t\\l. .,e, , , ".' 9: \I \ h'\ \ G \ t\\}G \ \) .. ,'nul\1I'I """'le::,\U v'.J C\.lN\?E~0si\..'iI'N~ " >dAl['m~':l'dJC , , '~j .~ '< Robin Elizabeth Zorn, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-3408 CML TERM Ralph Bernard Zorn, Jr., Defendant : PROTECTION FROM ABUSE AND CUSTODY MOTION FOR CONTINUANCE The Plaintiff, Robin Elizabeth Zorn, by and through her attorney, Joan Carey of MidPenn Legal Services, moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. A Continuance was issued by this Court on June 7, 200 I, scheduling a hearing for August, 7, 2001, at 3:00 p.m. 2. Upon request of the Court, the hearing has been rescheduled to October 1,2001, at 2:00 p.m. in Courtroom 3. 3. Plaintiff requests that the Temporary Protection From Abuse Order shall remain in effect for a period of eighteen months from the date it was entered, through December 4, 2002, or until further Order of Court, whichever comes first. WHEREFORE, Plaintiff requests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in effect for a period of one year from the date it was entered, through December 4, 2002, or until further Order of Court, whichever comes first. Respectfully submitted, oan Carey, Attorney for P, ntiff MIDPENN LEGAL SE CES 8 Irvine Row Carlisle, PA 17013 -- ,""-r:7"F';'~'>' ." ~-. ,_, '+'~~"'''',,(:::,'''T_ '_' I/.""~ ",^c - ': '" , ~, c ~ . ~ - .,- ~ -,~ , ., ,,- . , '1'_ '~1 ' _"If .,'''. .. ~ ..0 ~ f-- (;, 6< t~~, :t: Q~ Q~'::_~ Q.... 0:3 r-" }[?i) (~) ~~\ - --,Z U___:' "'-'Z (.!:; :CiLW --. -, 'no- ;;: ~ ::> CJ C) , <;"'" ,,'" i; " ri I' " " Ii n I [1 , i:i i ~ , " -- .~- -"-'~',,-'" _~ ~~ ""'"'"~~_I''-''''''' -- "J, -"J'" "h_',,;d";~ "',~-t__'"'.' '~'o" o",,,,,,-.~>"- """::'nfitiii' ~ I] ]1K':OC1~~JI\l_~ . _ J;i!.~il!~~~~IjJH;~-l~I?"~~'ffl';Wi'H&itj!I~~'ffl!Il,;tI;i~!lJ~~,~~",;jry~,);."#"j""'i'\~"1"'""",.."!,r~,,,w,,,,:m<~W!;;~F'!N?i~~~'ll~~~"IWHmWi~"l!I~w,~~~~ SHERIFF'S RETURN - REGULAR CASE NO: 2001-03408 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ZORN ROBIN ELIZABETH VS ZORN RALPH BERNARD JR STEVEN WHISTLER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon ZORN RALPH BERNARD JR the DEFENDANT , at 0014:55 HOURS, on the 6th day of June , 2001 at CUMBERLAND CO. SHERIFF'S OFF 1 COURTHOUSE SQUARE CARLISLE, PA 17013 by handing to RALPH ZORN a true and attested copy of PROTECTION FROM ABUSE together with and at the same time directing His attention to the contents thereof. Additional Comments --- CONFISCATED WEAPONS AT PLAINTIFFS RESIDENCE ON 6/4/01 Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 3.10 .00 10.00 .00 31.10 So ;s~~_~~t R. Thomas Kline 06/07/2001 Sworn and Subscribed to before BY:\~ L04) Deputy Sheriff me this :H I:!o: day of y~.....- .:l-b-c / A . D . (~~ t2 ~# othonotary ,)(. '-"^;"< 1,_, < <,-","-" e' ~ ., , --~ " I , ~ " Robin Elizabeth Zorn, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 01- 3408 CIVIL TERM Ralph Bernard Zorn, Jr., Defendant : PROTECTION FROM ABUSE AND CUSTODY ORD~ FOR CONTINUANCE AND NOW, this~day of June, 2001, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on June 7, 2001, at 3 :00 p.m. by this Court's Order ofJune 4, 200 I, is hereby rescheduled for hearing on August 7, 200 I, at 3 :00 p.m. in Courtroom No. 3. The Temporary Protection From Abuse Order of June 4,2001, shall remain in effect for a period of eighteen months from the date it was entered 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 Ralph Bernard Zorn, Jr., Pro Se 1150 Crane's Gap Road Carlisle, PA 17013 '""'~~.. .le "r""'-',"",~~; - ,c""..l", ,~ oiW,." P,;.' !~"~MJt:t.iHilli.' - '. -nl~if4l1iir: C I -n "\-F'~~ \.,\j:.~rI..J\- -1\....1- ,r\r~ I'T-.""'" '''1'-'(\-\ my Ur-- . i_';".l.;~""',!,.,Ji\ll,-}.im 0\ JUN-l PH 2:25 CUMSERLfND COUNTY PENNSYLVANiA ~J i;!i!'4:tlh~~r,;!iID.lk",t>C ~ - - l~~ ~. . Robin Elizabeth Zorn, Plaintiff : IN THE COURT OF COMMON PLEAS OP : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO. 01-3408 CIVIL TERM Ralph Bernard Zorn, Jr., Defendant : PROTECTION PROM ABUSE AND CUSTODY MOTION FOR CONTINUANCE The Plaintiff, Robin Elizabeth Zorn, by and through her attorney, Joan Carey of MidPenn Legal Services, moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. A Temporary Protection Prom Abuse Order was issued by this Court on June, 4, 2001, scheduling a hearing for June, 7, 2001, at 3:00 p.m. 2. The Cumberland County Sheriffs Department served Defendant with a certified copy of the Temporary Protection Prom Abuse Order and Petition for Protection Prom Abuse at his residence located at 1150 Crane's Gap Road, Carlisle, PA 17013, on June 6, 2001. 3. The parties agree that the hearing be rescheduled pending further Order in this matter. 4. The Plaintiff requests that the Temporary Protection Prom Abuse Order remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. ~ - ~ - -" -j1"-, WHEREFORE, the Plaintiff requests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ''i'(!t.-:r:l1~ _~ ~,_ ',_ ~"_'" '::''''':"'_~, . ~, ~ 'r_. -, - ~-~ . '-- -, ~" ". , " ~'~ ",- "~J'~-""._ ~~.' '_'="~'" ~,.m",""""_'~'"""",,'~O .~ .~ [S to (') 0 0 c: 'Tl s: <- ---:::! -ocr.; C:: I>~ mn' :;~ Z::CJ Zc;, I ,~l(T\ (.13/' ...J jj(-' -<2~ ',::1 'fJ kG -~ :~ ~~ )>n ::z: Zo )>c 01 Z J.) ~ :;:! (,) ?Z ''';,'1I! "~_ _~~:i!{Jr_ ,,,,,,,~~~i!I1."J.~~~)~}l!\'l!J:~~i!Il~ll1li!!Mi!j!!m;r4~!f~<'WF"dt~f'~;iTJ:-:\P-i'ii_G",'C';~f~,:V"",",~l"O_~Nw~!ffifA~:W;iO!>'$'T~i:Wimlt,*",,;;})H,~i~~~Fi';""~iWJ~~~~~~ .' ROBIN ELIZABETH ZORN, PLAINTIFF : IN THE COUR'fOF COMMON PLEAS OF VS. : CUMBERLAND COUNTY, PENNSYLVANIA ; NO. 200l-d1IO~ CIVIL TERM RALPH BERNARD ZORN, JR. 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 MATIERIS SCHEDULED ON ~; '" (7 ;DI,AT 3 :1/7J ~ .M., IN COURTROOM NO. ~ 0 HE CUMBERLAND - COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA. You MUST obey the Order that is attached until it is modified or terminated by the court after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six months injail under 23 Pa.C.S. 96114. 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. 92261-2262. Y oU.should take this paper to your lawyer at once. You have the rightto have a lawyer represent you at the hearing. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to fmd out where you can get legal help. If you cannot find a lawyer, you may have to proceed without one. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE, CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717)249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. Forinformation 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 : """ ." -~. ,.i'i" , '--~ ".,' "C;' - ~ . -", ,-., - - ~ ~ . . , Robin Elizabeth Zorn, Plaintiff : IN THE COURT OF : COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v. Ralph Bernard Zorn Jr., Defendant . ; No. Of- ,3<16'1 Ct;;J-r~ : CIVIL ACTION - LAW : PROTECTION FROM ABUSE : AND CUSTODY . . TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Ralph Bernard Zorn Jr. Defendant's Date of Birth is: August 11,1967 Defendant's Social Security Number is: 198-54-6342 Name(s) of All protected persons, including Plaintiff and minor children: I. Robin Elizabeth Zorn AND NOW, on 4th Day of June, 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 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 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. r-'~ . -, _, .' _, ,_ ~ ,M~ ~'-"-""'- " " " ~ Plaintiff's residence located at517 Adams Road, Carlisle, Pennsylvania, or any future residence Plaintiff may establish. Any future place of employment Plaintiff may establish. 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: I. Seth Marton Zorn 2. Amy Nicole Zorn Until the final hearing, all contact between Defendant and the child/ren shall be limited to the following: Plaintiff shall have primary physical and legal custody of the minor children. Defendant shall have supe~ised visits at times and places mutually agreed upon by the parties. The visits shall be supervised by an agreed upon third party. Defendant's vistitation shall be conditioned upon his taking prescribed medications and following any ofthe doctors recommendations. 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. Defendant shall immediately relinquish any firearms license the Defendant may possess, and the following weapons to the Sheriffs Office or a designated local law enforcement agency for delivery to the Sheriffs Office. 1. Any and all ftrearms and/or weapons, including but not limited to, any handguns, shotguns, and/or rifles. Defendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration of this order. 6. The following additional relief is granted: This Order shall remain in effect until modified or terminated by the Court and can be extended beyond its original expiration date ifthe Court fmds that Defendant has committed an act of abuse or has engaged in a pattern or practice that indicates risk of harm to Plaintiff. Defendant is enjoined from damaging or destroying any property owned :-::_;;.~ -"'~-<,~-" '!~-, - ~-."" '" -,*" ".-f " ", " , jointly by the parties or owned solely by Plaintiff. Defendant is to refrain from harassing Plaintiff's relatives. 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: North Middleton Township Police South Middleton Township Police 8. 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. 9. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL DECEMBER 4, 2002 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months in jail. 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 filing of appropriate court papers for that purpose. 23 Pa.C.S. 96113. Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. 992261- 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 ofthis order occurs OR where the defendant may be located. If defendant violates Paragraphs I through 5 of this Order, defendant shall be arrested on the charge ofIndirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence oflaw enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons 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 >!"~o-, _ _,~, '_", ",,~_, ,-- n' - _,~__'" _ 0' <: '~." '" . . . further Order of this court, unless the weaponls are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. Defendant may upon the expiration of this Order request that the Sheriff return any firearms and/or weapons held pursuaut to this Order. The Sheriff shall determine if Defendant is otherwise legally entitled to possess the firearmsandlor weapons. lft{le Protection From Abuse Order has expired and Defendant is legally entitled to possess firearms and/or weapons, the Sheriff shall present an Order to the Court authorizing that the fireanns and/or weapons be returned to Defendant. Otherwise the Sheriff shall notify Defendant that helshemust me: a petition with the Court seeking a return of the firearms andlor weapons, in which case the Court, upon petition,will schedule a hearing witl:\ notice to Plaintiff. BY THE COURT, fN ;l t. "''1-1'"'' ~Judge Distribution to: MidPerm Legal Services Faxed & Mailed to PSP Cumberland County Sheriff West Chester County Sheriff Uf:, ",'_' - "~'~_' 'r- ,r' .. I" - " ':f;'W;;<1h!~.g!\!ill,N"<j'61i'~;;\",,,,;,,,,,~.;,jL"',;:o",,i~,,,'&;~>;,,i'l'U',"""'-Y''''''',~0!'''__; "____..,'j'",j~,;,:ii:~W!.tiHffl<'""'~!lif:l"_B)Mlil;~l[j\!iI,jill..,!;.w;Ili!i~".,~.-.'~~<_.,"'"-- ~~.~~~ T""''''lla~~!Sl''''''"~ '''"'l.IIU- ~ ~ .~ "ji&U.1iIi - ff, ~,~f!'I,<,' .'F\n"O.'CfFlCE .:-7..::,("... 'r,oO '~J.1ARY OF 'Tr~~__. f'!;'~..), r\..;:"~! 0\ JUN -4 Pt-1 3: 44 CUMBERLAilD COUt'.'TY PENNSYLVANIA "';":{"".">' ~;, '" -',;,o."S," , 7:'0>,'.' ,"=, ",- '*" ,.,,[ .. .~,;\,," 'J)~'..,' H,g-,~.,j_"~ -::< .'07',"". .. ,,~I- -,--,." -"".,- .. '- 'c. -'" .. ~~ PFAD Number: REl26l627K Robin Elizabeth Zorn, Plaintiff : IN THE COURT OF : COMMON PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA v. Ralph Bernard Zorn Jr., Defendant ; No. b/_ 3'1Q~ CUx::.f I.L-. : CIVIL ACTION - LAW : PROTECTION FROM ABUSE : AND CUSTODY . . PETITION FOR PROTECTION FROM ABUSE I. Plaintiff's name is: Robin Elizabeth Zorn 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. Robin Elizabeth Zorn 4. Plaintiff's Address is : 517 Adams Road, Carlisle, Pa 17013 5. Defendant's Name is: Ralph Bernard Zorn Jr. 6. Defendant is believed to live at the following address: Va Hospital, Room 58B, Coatesville, Pa 19320 7. Defendant's Social Security Number is: "-:~-,,,, -----~" -'-""""'(,--"'~- -"."-' ,. " ,,- ., -,~~ 198-54-6342 8. Defendant's Date of Birth is: August 11, 1967 9. Defendant's Place of employment is: Disabled Vet 10. Defendant is an adult. II. The relationship between the Plaintiff and the Defendant is: Spouse Parents of the same children 12. Plaintiff and Defendant are the parents of the following minor child/ren: a. Seth Marton Zorn Age: 11 Child's address is: 517 Adam Road, Carlisle, Pa 17013 b. Amy Nicole Zorn Age:4 Child's address is: 517 Adam Road, Carlisle, Pa 17013 13. 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. Seth Marton Zorn For the past 5 years, this child has lived with: -Plaintiff and Defendant 1150 Cranes Gap Road Carlisle, P A Nov. 99 until Present -Plaintiff and Defendant 120 Amy Drive Carlisle, P A .,"I'*j ,f'. , . " < - ~"r . ~ l!! .~- 1993 until Nov. 99 b. Amy Nicole Zorn For the past 5 years, this child has lived with: -Plaintiff and Defendant 1150 Cranes Gap Road Carlisle, PA Nov. 99 until Present -Plaintiff and Defendant 120 Amy Drive Carlisle, P A 1993 until Nov. 99 14. The facts of the most recent incident of abuse are as follows: On or about May 11, 2001, Defendant became enraged and screamed at Plaintiff causing her to fear for her safety; grabbed the phone from her when she attempted to call the police and threw it to the ground causing it to shatter, and threw a lit cigarette at Plaintiff and the children nearly hitting the daughter with the cigarette. Defendant followed Plaintiff and the children into the house, grabbed several 22 shells that were on the table, held them in Plaintiffs face and threatened, "You fucking cunt, you see these, this is what you need in your head," causing her to fear for her life. Defendant left the residence and took the children to stay in a motel for the night. One on occasion, Defendant threw a basketball at the minor child, Seth, with such force that it caused a bruise on his arm. On or about May 14, 2001, Defendant called his VA Advocate on the phone, stated he had a loaded gun, and threatened to shoot himself. Defendant's caseworker recommended he sign himself into the VA hospital. Defendant has been at the hospital since May 15, 2001. 15. 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: Since approximately 1996, on several occasions, Defendant has become infuriated with the children, screamed at them, and grabbed them. Plaintiffs fear for her safety and that of her children is exacerbated by the fact that Defendant suffers from Post Traumatic Stress Disorder and the Persian Gulf Syndrome. In fact, a counselor from the VA contacted Plaintiff regarding Defedant's instability and recommended she seek a Protection From Abuse Order for her protection and that of her children. ft.'(lf~;I[_ .. _ _""~,~. 16. The Defendant has used, or threatened to use, the following weapon(s) against the Plaintiff or the minor child/ren: a. Any and all firearms and/or weapons, including but not limited to, handguns, shotguns, and/or rifles. 17. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: North Middleton Township Police South Middleton Township Police 18. There is an immediate and present danger of further abuse from the Defendant. 19. The Defendant owes a duty of support to Plaintiff and/or minor child/ren. 20. 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: Plaintiff shall have primary physical and legal custody of the minor children. Defendant shall have supervised visits at times and places agreed upon by the parties. The visits shall be supervised by an agreed upon third party. Defendant's visits shall be conditioned upon his taking his prescribed medications and following the doctors recommendations. c. Prohibit Defendant from having any contact with Plaintiff and/or minor child/ren, either in person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Plaintiff's school, business, or place of employment, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/ren. d. Order Defendant to temporarily turn over weapons to the Sheriff of this County and prohibit Defendant from transferring, acquiring, or possessing any such weapons for the duration ofthe Order. oi,itn:..~_" " ."- ,-~ - -j. ., e. Order Defendant to pay temporary support to Plaintiff aI).d/or the minor child/ren, including medical support. . f. Order Defendant to pay the costs of this action, including filing and service fees. g. Order the following additional relief, not listed above: Defendant shall not harass Plaintiff's relatives. Defendant shall not damage or destroy any property owned jointly by the parties or solely by Plaintiff. Defendant shall pay $250.00 to one of Mid Penn's funding sources as reimbursement for litigation in this case. h. 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. R~PoctMIYS""""'~bY~ ~7 Joan Carey Agency: MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 "'#!," ..,... ~~,'~,. -".,""""- --- ~,~ ~ 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. 94904, relating to unsworn falsification to authorities. Dated: (p \ - 0 \ ~~ ~F---- R bin Zorn, Plaintiff ,.{if-, ;'" !~ p 3> ~ r- r:P f ~ &- . 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