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HomeMy WebLinkAbout01-03528 DAWN MICHELLE MILLER, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO. 2001- 35~ CIVIL TERM CLIFFORD L. MARTIN, JR., DEFENDANT : PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A HEARING ON THIS MATTER IS SCHEDULED ON ~ IZ--,DI],AT .J: Ii) Ad., IN COURTROOM NO. ~? OF E 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 sixmonthsinjail 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 U.S.C. ~2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S,C. ~ 2261-2262. You should take this paper to your lawyer at once. You have the right to have a lawyer represent you at the hearing. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to 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 scheduled conference or hearing. c:c."..,"W .. ~ , _ Yl ~*~!<'}h'i!VIlk"bikill1;!(.w.o!M"~U\f~\i~~"_)(@'i>-J"P"'k_"<&_,~~~"",~~;m~j~lIi:ilf",-!l\"''&,*&R.i(!t''i!il1~ri;iillii!!j,;f!lliiJj~I!LjlL~' 'j FiLED-OfFICE OF :~~~':'_'}Yi-iClf.JOTpJ~Y 01 JUN - 'I PI'i 2: 39 CUMBtflLAND COUNlY PENNSYLVANLil. '\':-'H.".",lL!VH,~,~~_~ ,f~_".,,~]~lL;,,~,_,QlJ]lL_.,Ji'r",,'_?'~, _,,". ,"" ". ' _~",- , -~'~, .=",' "7Y' _'., _,,'" ~.. iltil'liilii1l\1iil~ ,> 0,_ ~_ ~ ,_. , 1 '"I -,! ! ~ ~; Plaintiff : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA Dawn Michelle Miller v. ~No. 01- ~J~ Clifford LeRoy Martin Jr. Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE . TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Clifford LeRoy Martin Jr. Defendant's Date of Birth is: March 9,1950 Defendant's Social Security Number is: 159-44-0967 Name(s) of All protected persons, including Plaintiff and minor children: 1. Dawn Michelle Miller AND NOW, on 7th Day of June, 2001 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: Plaintifrs 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. ';"'1;"", "" II r 2. Defendant is prohibited from having ANY CONTACT with Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at Plaintiff's school, business, or place of employment. Defendant is specifically ordered to stay away from the following locations for the duration of this order. Plaintiffs residence located at 20 East Portland Street, Mechanicsburg, Pennsylvania. Plaintiffs place of employment located at EDS, 4600 West Port Drive, Mechanicsburg, Pennsylvania. 3. Defendant shall not contact Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 4. The following additional relief is granted: This Order shall remain in effect until modified or terminated by the Court and can be extended beyond its original expiration date if the Court finds that Defendant has committed an act of abuse or has engaged in a pattern or practice that indicates risk of harm to Plaintiff. Defendant shall not harass Plaintiffs relatives. Defendant shall not damage or destroy any property owned jointly by the parties or solely by Plaintiff. 5. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Mechanicsburg Police Department Lower Allen Township Police Department 6. The sheriff, police or other law enforcement agencies are directed to serve the Defendant with a copy of the Petition, any Order issued, and the Order for Hearing without prepayment of costs. The Petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. The Prothonotary is directed to file this Petition and Order without prepayment of costs. 7. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL DECEMBER 7, 2002 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT ~,,1' ~ ~" '."" ., I '':':I'''!l'' ;-r 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. ~6114. Consent of the Plaintiff to Defendant's return to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. ~6113. Defendant is further notified that violation of this Order may subject himlher to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 V.S.C. ~~2261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiffs residence OR any location where a violation of this order occurs OR where the defendant may be located. If defendant violates Paragraphs I through 3 of this Order, defendant shall be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence of law enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriffs office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this court, unless the weapon/s are evidence ofa crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. Judge ------~-----------n l-~- - - Distribution to: MidPenn Legal Services ..~ Ii> ~ /11 fJ /.. S Faxed&MailedtoPSP - (l;~r;AJJ e (kp/'-s Cumberland County Sheriil--- ~. >'- . -",,,,,~- -I' ., 'I[' PF AD Number: DFl264638Q : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYL VANIA Dawn Michelle Miller Plaintiff v. ; No. &1- 3523' CUn:L ,~ Clifford LeRoy Martin Jr. Defendant : CIVIL ACTION - LAW : PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE 1. Plaintiff's name is: Dawn Michelle Miller 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. Dawn Michelle Miller 4. Plaintiff's Address is: 20 East Portland Street, First Floor, Mechanicsburg, PA 17055 5. Defendant's Name is: Clifford LeRoy Martin Jr. 6. Defendant is believed to live at the following address: 490 Hoffman Drive, Harrisbnrg, PA 17111 ;L ,,' , . 1"1' r "'-" 7. Defendant's Social Security Number is: 159-44-0967 8. Defendant's Date of Birth is: March 9, 1950 9. Defendant's Place of employment is: Unemployed 10. Defendant is an adult. II. The relationship between the Plaintiff and the Defendant is: Current or former sexual/intimate partner 12. The defendant has been involved in a criminal court action. 13. The facts of the most recent incident of abuse are as follows: On or about May 29, 2001, Defendant entered Plaintiff's apartment uninvited, and demanded sex, and threatened that if Plaintiff was going to use the knife, which she was using to cut an apple, she better kill him because there were more knives in the kitchen and he would cut Plaintiff and her father up. Fearing for her safety, Plaintiff dropped the knife, and Defendant grabbed her around the neck, pushed her into the bathroom with one hand while he pulled her clothes off with the other. Defendant forced Plaintiff to lie over the sink and sexually assaulted her, and then forced her to sit on the toilet, grabbed her by the hair and neck, tightened his grip, and threatened to kill her if she did not perform oral sex. Defendant watched as Plaintiff got a shower and got dressed to make sure she did not call the police. When Defendant let Plaintiff go to work, she called the police. 14. 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 or about October 1999, when Defendant moved out of the residence, he left a suicide note and threatened that he was "not going out alone" causing Plaintiff to fear for her life. In or about August 1999, Defendant screamed vile names at Plaintiff and threw a v' '. -,-,;" ," "1"1' .1 - ,- laundry basket at her. Defendant threatened that be was "going to take care of Plaintiff once and for all", and went to his office downstairs where he had guns and knives. Fearing for her safety, Plaintiff took the children and attempted to leave the residence. Defendant grabbed Plaintiff by the throat, lifted her off of the floor, and threw her onto the floor causing her to land on the minor child's arm. As a result, the child suffered a sprained wrist. Defendant kicked Plaintiff several times. Plaintiff suffered injuries including bruising and scratches on her neck and bruises on her legs. On or about October 1997, Defendant became enraged, smacked Plaintiff across the face, pushed her to the ground, and threw her into the bathroom. Defendant then forced Plaintiff to have sexual intercourse. While Plainitiff was on the ground, Defendant stomped on her several times. Plaintiff suffered pain and bruises on her lower back as a result of the incident of abuse. Since approximately 1991, Defendant has abused Plaintiff in ways including, but not limited, to the following: grabbed, choked, slapped, and pulled her hair. On several occasions, Defendant forced Plaintiff to have sexual intercourse with him. Defendant stomped on Plaintiffs stomach when she was pregnant with her son and several times he has held her at gunpoint. On a separate occasion, Defendant has grabbed Plaintiff by the hair, slapped her in the head several times, and choked her until she gasped for air. During an incident in 1992, as Plaintiff turned to leave the room, Defendant stabbed her two times causing lacerations from the knife in several places and a punctured lung and damaged colon that required surgery as a result of the incident. Defendant and Plaintiff have separated several times in the past, however, Plaintiff can see the escalation beginning again. 15. The police department(s) or law enforcement agencies that should be provided with a copy ofthe protection order are: Mechanicsburg Police Department Lower Allen Police Department 16. There is an immediate and present danger of further abuse from the Defendant. 17. 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. Prohibit Defendant from having any contact with Plaintiff and/or '1A, ,~ " ,;" , '1'1' ., 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. c. Order Defendant to pay the costs of this action, including filing and service fees. d. Order the following additional relief, not listed above: Defendant shall not harass Plaintiffs 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 MidPenn Legal Services funding sources as reimbursement for litigation in this case. e. 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. _UIIYSOOnri<<OObr-J.;;J @~ . oan Carey Agency: MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 "~ ., , l~r 1---' I ~ ~~-. . 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. S4904, relating to unsworn falsification to authorities. Dated: 4- )1.16 1 D,/j;!;J l;iJi "''''-J1' II :J i'< ~" I~~< ~. ," .", 0', 'h W",.,;, '-nl'J""'6Il( , mr"'~T':-'Wil*l"jf );''''"'''"'i1~'''- e~o-j"'="if~;';;~I'nff:~[--'if-;---r . n c ?:: -On:: QJni ~ -, ;'?r (,;jJ"- ~i5 ::D: 2:(") 50:0 C 2:: ::< ~_\~ 'I.l (~, ,\'c .... , - \ , 0' t(') <:::> o .., - '--- c- :;;4:;: -..,1 'r' :.,,:1'1 . '~ "'(",~r-n :;j.C:J ()rL --._~ ~-) :-':::::.8 (. )-:.. :>0 C'<'.., ., :--~I "". Xl. -< , '--.J \:) ::;:(~ ~ f...:l M~ ~" J ~.!/Jlmpj~0'" ""F'''I'Pl'JnJ,.rr~''~~~~ff-i-!b';<(.:c''c-''_1t'lf1;,j"!'~~~~~~~I\!:!!fjj'~i!.W!if,t~I~!H'I'~i~~ 06/07/01 THU 15:21 FAX 717 240 6573 CUMB CO PROTHONOTARY 141001 . . ****$$$******************** *** MULTI TN REPORT *** *************************** TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2664 [ 04]9p2583343 [ 01]9p2490779 [ 03]9p2405331 LS PSP CP ERROR , , OFl"lCE OF THE PRarn(N)1'ARY OJMB<::RLAND o:xJN'Ii' CCi!.JR1l100SE CX'lE COOR11lCUSE SJUARE CARLISLE. PA. 17013-3387 (717) 240-6195 FM (717) 240-6573 VIA TELECOPIER 'to: FAX ~: PA STATE POLICE. (!e14rl. P."ell ~a.. M. tJ. L.J, 717-249-0779 FTlO-1 : CURTIS R. LONG RE: PFP. ORDERS MESSAGE: : -J.-" 00, OF PAGES (IOCf.AJDI[IK; COlIER SHEETl 'llIis" T~ is :i..lb:odd ally fix' tte \He d. tte irdiv:i!lm cc Entity to w'lidl is is ;:Ill- -".! ~, a-d I1'Bf antain infumetim ttal: is Irivileg;d. anfid31tial ~ asT{.t frail (l~....,l""rne \J'd:lr ~;.-..hlp. laII. If ItE rerl9r d. t:h:is ~ is rot liB intenB:l recipim!:. .,:u are ~ rotifia:! lret <Dj dil;semitl3tiO'l. cl.istri\:lJt.i or cqving cf tl1is a;rnnnica"...im il< strictly prltibitErl. If 'rW h;r..e ra:;e.ive:i UuS o:mn.nic.r...im in ecr.r. pI.e;loe rotify 1,S irma:l.iately l:!f lelepn"e.;rd ~etuJ:n tie a:ig:in!U " ""1' 1:0 u; at -- -.. ~..... .-_"--1.......................... ~'''''" ,!,"I"'l'\fV,,"'~ ""l-ll~ ~ " ~ ., "C," ,- Dawn Michelle Miller, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 2001-3528 CIVIL TERM Clifford L. Martin, Jr., Defendant : PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, this 12th day of June, 2001, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on June 12, 200 I, by this Court's Order of June 7, 2001, is hereby rescheduled for hearing on July 24,2001, at 3:00 p.m., by this Court's Order. The Temporary Protection From Abuse Order 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, t Joan Carey MIDPENN LEGAL SERVICES, Attorney for Plaintiff O.-C?'l~ ~ Co-py 5erlJ'~d ~ ",~ '. '""I~~I "-,, "-,,,,._,-,~," 'c- - .. "-'-.' v~ ~1\Je1l ~ N\.L.~. ~ ._~~p~r. ~ '"~l h _" .' -;'1>"-:"- . !1l.. - '.. .~., 'C""', . ,^". ~mllJ1$)";a.~~,~~!n'~~"'''.~JO<:I!;I'~" ,,-, -, ~:'5"" '",,..,,. _~~ ,,- .~' -, "",~-, -'",~~ ".,/ 'd'; "",'w',[~_ ',"' ';<"- ,.,.,- tY~i'j1'''''''"'r"-''''>-='~~_;:'-'i''r~Ylr[l'<,,' '~(~ C) a c: s: ~ vc:' S? [!~~, ."'."~ ,'-"- Zr- (02:.' I" ~~~- .J <~. ~n .~. -r-:; ~?i. ::;;u .~ C '- ~ 5~~' CO ':J:J ", m:~~!fv~~JlIl\j~~J~1lii"~,!<[Ijj~~fi'\@jll/f!ii~~'imlm-I"~~~;;;W~"~~'f~iijll$1U&t~~I~!~lIj'Flm~'~'f' Dawn Michelle Miller, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY,PENNSYL VANIA v. : NO. 2001- 3528 CIVIL TERM Clifford L. Martin, Jr., Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE The Plaintiff, Dawn Michelle Miller, 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 From Abuse Order was issued by this Court on June 7, 2001, scheduling a hearing for June 12, 2001, at 3:00 p.m. 2. The Cumberland County Sheriff s Department has been unable to effect service on the defendant. 3. The Plaintiff requests that the hearing be rescheduled 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. WHEREFORE, the Plaintiff requests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection From Abuse Order ,,""-''''.,-' ,,"".,- P'''I - ..W_ .~ remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. Respectfully submitted, Plaintiff MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PAl 70 13 (717) 243-9400 "~ , ~- c j-"I'"'I['-- , -., '", - "'0"'" ,-',,n ~',_:.,")-c- "'. --r'" iii'- -""--~'"-,,,",. _.~- '1 IT : ~ '-: - _ '":_:"'rv," ""'11 ~~';)C' :. cJ ~ " i I~... 'tot - '-'N~"('?L-;-;Y' '''1't'~:' ';;il';;~~Y -":'rtI'4-~i~'iIl1'I"tI"[J71f~~~t~3)]'- V'i:i'~:;":_~-~i:: (") c- ?: ~i57; fJJr6 ~.::r",l ,<" r< 0:5.-'... r::F:;';- .:i::-'-- -=.:....("'. ~(-': )5; . .- S- < :< -. 9 :~'1 f~ C;;J - r. '--' -J,; '- EE '>~, .~"') {"< 't',-., - l\j 2="',~ _ .~d ~~ ,. (' ) (5 rr~ -r,." .::c' -<" ,~~ """'~~_J"I~1!)!> .1 .1'/ ". ~~~u-".._ '-"'"_":!,~-_'1J~~jIi;-W~~""W'~-'Ti'N'W' -W,)C";T~'~W!~~~~~I!M~I!f ./ ., SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 2001-03528 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MILLER DAWN MICHELLE VS MARTIN CLIFFORD L JR R. Thomas Kline , Sheriff or Deputy Sheriff who being duly sworn according to law, says, that he made a diligent search and and inquiry for the within named DEFENDANT , to wit: MARTIN CLIFFORD L JR but was unable to locate Him deputized the sheriff of DAUPHIN in his bailiwick. He therefore County, Pennsylvania, to serve the within PROTECTION FROM ABUSE On June 22nd , 2001 , this office was in receipt of the attached return from DAUPHIN Sheriff's Costs: Docketing Out of County Surcharge Dep Dauphin Co 18.00 9.00 10.00 25.50 .00 62.50 06/22/2001 omas Kline iff of Cumberland County Sworn and subscribed to before me this /9& day o~ ~/ A.D. (~\ ~Q.~~ Prothonotary' 1 '1"1 ~ -- of ., @ffh:e of tlyr ~4:eriff William T. Tully Solicitor J. Daniel Basile Chief Deputy Mary Jane Snyder Real Estate Deputy Michael W. Rinehart Assistant Chief Deputy Dauphin County Harrisburg, Peunsylvania 1710 I ph: (717) 255-2660 fax: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania MILLER DAWN MICHELLE vs County of Dauphin MARTIN CLIFFORD L JR PERSONAL SERVICE Sheriff's Return No. 1641-T - -2001 OTHER COUNTY NO. 01-3528 Pu~D NOW: June 18, 2001 at 1:46PM served the within PFA ORDER FOR CONTINUENCE upon MARTIN CLIFFORD L JR PERSONAL SERVICE by personally handing to HIM 1 true attested copy(ies) of the original PFA ORDER FOR CONTINUENCE and making known to him/her the contents thereof at 490 HOFFMAN DR. HARRISBURG, PA 17111-0000 c-.p~ PROTHONOTARY So Answers I JR~ Sworn and subscribed to before me this 19TH day of JUNE, 2001 Sherifp~ala:=' Pa. BY Deputy Sheriff Sheriff's Costs: $0.00 PD 00/00/0000 RCPT NO FURE ,.'i',,,., -- ~. 1'"1 ~, --~- '.< . I RONNY R. ANDERSON Chief DepLIly R. THOMAS KLINE She.<lff EDWARD L. SCHORPP Solicitor OFFICE OF THE SHERIFF PATRICIA A. SHATTO Real Estate Deputy One Courthouse Square Carlisle, Pennsylvanie 17013 Hon. J.R. Lotwick Sheriff of Dauphin County P.O. Box 1067 Harrisburg, PA 17108 RE: Dawn Michelle Miller vs Clifford L. Martin, Jr. Order for Continuance/01-3528 Civil TO: Dear Sir: Enclosed please find Order for Continuance to be servedupon Clifford L. Martin, Jr. 490 Hoffman Drive, Harrisburg, PA in your County. Kindly make service thereof and send us your return of service. Enclosed is the advance payment which you requested. ;~~ .... . .~ R. Thomas Kline, sl,~ Cumberland County, Pem1sylvania Enclosures: -f"l, _ '^ ,," _,_ _rr<, ~ I-I ''" R. THOMAS KLINE Sheriff RONNY R. ANDERSON Chief Deputy EDWARD L. SCHORPP Solicitor OFFICE OF THE SHERIFF PATRICIA A. SHATTO Real Estate Deputy One Courthouse Square Carlisle, Pennsylvania 17013 Hon. l.R. Lotwick Sheriff of Dauphin County P.O. Box 1067 Harrisburg, PA 17108 RE: Dawn Michelle Miller vs Clifford L. Martin, Jr. 01-3528 Civil/P~, Notice & Order Temp PFA, Petition TO: Dear Sir: Enclosed please find P~, Notice of Hearinq & Order. Temp PFA. Pp.tition to be servedupon Clifford Martin. Jr... 490 Hnf'fm"n nri"B Harrisburg, PA 17111 in your County. Kindly make service thereof and send us your return of service. Enclosed is the advance payment which you requested. ;~~.. t. .~~ R. Thomas Kline, s,~ Cumberland Count)', Pemlsylvania Enclosures: !-v,.,~?, ~""~, 1'1 '-J'" In The Court of Common Pleas of Cumberland County, Pennsylvania Dawn Michelle Miller VS. Clifford L. Martin, Jr. (Order for Continuance) No. 01-1')7.8 Civi 1 Now, 6/13/01 ,20 _, I, SHERIFF OF CUMBERLAND COUNTY, P A, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk ofthe Plaintiff. _ . .~~~~~~ . Sheriff of Cumberland County, P A Affidavit of Service Now, ,20_, at o'clock M. served the within upon at by handing to a copy of the original and made known to the contents thereof. So answers, Sheriff of County, PA Sworn and subscribed before me this _ day of ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ "'So." , .. .' "" ." "-. r . In The Court of Common Pleas of Cumberland County, Pennsylvania Dawn Miller VS. Clifford Martin, Jr. No. 01-3528 Civil Now, 6/7/01 ,20_, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Dauphin County to execute this Writ, this deputation being made at the request and risk ofthe Plaintiff. .~~~~~~ . Sheriff of Cumberland County, PA Affidavit of Service Now, , 20_, at o'clock M. served the within upon at by handing to a copy ofthe original and made known to the contents thereof. So answers, Sheriff of County, P A Sworn and subscribed before methis_dayof ,20_ COSTS SERVICE MILEAGE AFFIDAVIT $ $ -,.-, . ,~.....~.I. . . DA WNMICHELLE MILLER, PLAINTIFF , . : IN THE COURT OF COMMON PLEAS OF V. : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 0'-3528 CIVIL TERM 01- 3~ CLIFFORD 1. MARTIN, JR., DEFENDANT : PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, this 24th day of July, 2001, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on July 24, 2001 at 3 :00 p.m., by this Court's Order of June 12,2001, 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 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 ! . 1-2'1-6/ Lawrence Rosen Attorney for Defendant Krevsky, Rosen & Smith 1101 North Front Street Harrisburg, P A 17102-3324 '\~-'il'\'F'"",,""' __ :--" "'~", ,. " ~ F, rr ~= , -I , DAWN MICHELLE MILLER, PLAINTIFF : IN THE COURT OF COMMON PLEAS OF V. : CUMBERLAND COUNTY, PENNSYLVANIA ClI- 3'GJS1 : NO. at 11J I CIVIL TERM CLIFFORD 1. MARTIN, JR., DEFENDANT : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE The Plaintiff, Dawn Michelle Miller, by and through her attorney, Joan Carey of MidPenn Legal Services, moves the Court for an Order generally continuing the hearing in the above-captioned case on the grounds that: 1. A Continuance was issued by this Court on June 12,200 I, rescheduling a hearing for July 24, 2001, at 3:00 p.m. 2. The parties, by and through their respective counsel, request that the hearing be generally continued to afford them time to execute a Consent Agreement. 3. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. WHEREFORE, Plaintiff requests that the Court grant this Motion and generally continue 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. Respectfully submitted J~':~ti Attorneys for Plaintiff MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 :1~=r- 0,,_ : fr""'1 "-1 [' i i.:~_ ?IJ;,I -~--"ij-<--". (_. till . ". ~ ~ ,.~,-,,,"~ -~ _'~"_ _ "'". ~'c ""'" e" O"'~'._. '.' ,<-<.~~,> ,.. ~ -"~ <lr'r...-^.". "~""'-r ~II!!'II".:oo:;,~:i~n..j!fJ'l._"o/".~.~.'I!l~~~.~>'lli~M);j~"l"'W":W"....t4;-"'....,,:"'-.;.,~"""'l'i";m!'W-~n~.~Jl),~\mitWl~jH!!!l~~i!ijIlMj;~.