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HomeMy WebLinkAbout01-03590 ~"."~"=~"~ . . ':-J,:, ';-~- 'I"s', .~" >, "'. ~ _ - - > ~-', 'i-;" ,. ERIN ANN SULLIVAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 01- ~O CIVIL TERM CHRISTOPHER LYNN ADAMS, 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 the Ji!'day of June, 2001, at / " j 0 ".m., in Courtroom No. ~ on the 4th Floor of the Cumberland County Courthouse, 1 Courthousl 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 ofindirectcriminaI contempt which is punishable by a fine of up to $1,000,00 and/or up to six months in jail under 23 Pa.C,S. ~61I 4. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code, Under federal law, 18 US.C. ~2265, this Order is enforceable anywhere in the United States, tribal lands, US, Tenitories and the .Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminaI proceedings under the Violence Against Women Act, 18 U S,C. ~ 2261-2262, You should take this paper to your lawyer at once. You have tire right to have a lawyer represent you at the hearing. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. If you cannot find a lawyer, you may have to proceed without one. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, Pennsylvania 17013 Telephone Number: (717)249-3166 AMERIC~S WITH DISABILITIES ACT OF 1990 The Court of Common Plea$'ofCumberland 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 in4i',(duaIs having business~re the court, please contact our office. All arrangements must be made at least n qpljfs prior to any hearin~ or business before tbe court. You must attend the scheduled conference or hearing. ');"""~~""""~ "~ . . ..11 ~ "[ 1 ~~'~-'~"-i . . . ERIN ANN SULLIVAN, Plaintiff : In the Court of Common Pleas of : CUMBERLAND County, v. : Pennsylvania : : Civil Action - Law CHRISTOPHER LYNN ADAMS , Defendant : No. 01- : Protection From Abuse TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: CHRISTOPHER LYNN ADAMS Defendant's Date of Birth is: October 6, 1976 Name(s) of All protected persons, including Plaintiff and minor children: 1. ERIN ANN SULLIVAN AND NOW, on nth 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. Defendant is prohibited from having ANY CONTACT with Plaintifl; or any other person protected under this Order, at any location, including but not limiteli'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. Plaintiff's current residence: ~ ff ,~ ~ I,'; ,~ ,-, c- - , , " -IiUlli ~L'~ . -'-' -- lJU'~f 3612 Kent Drive, Mechanicsburg, PA and any other place where she may stay during the term of this Order. Plaintiff's place of employment: Rite Aid Pharmacy 2023A Linglestown Road, Harrisburg, PA (Dauphin County) and any other place where Plaintiff may be employed. Plaintiff's school: Academy of Medical Arts and Business 2301 Academy Drive, Harrisburg, PA (Dauphin County) 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. Defendant shall immediately relinquish any firearms license the Defendant may possess, and the following weapons to the Sherifi's Office or a designated local law enforcement agency for delivery to the Sheriff's Office, L any and all firearms and/or weapons. Defendant is prohibited from possessing, transferring or acquiring MlY other firearms license or weapons for the duration of this order. 5. The following additional reliefis granted: Defendant is prohibited from having any contact with Plaintiff's relatives. Defendant shall refrain from harassing Plaintiff's relatives. Defendant is enjoined from damaging or destroying any property owned by Plaintiff. 6. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: HAMPDEN TOWNSHIP POLICE DEPARTMENT SUSQUEHANNA TOWNSHIP POLICE DEPARTMENT (Dauphin County) DAUPHIN COUNTY DISPATCH ~' . n"; < :1., -,. ";'~ ;~'. - , , ' 7. The sherifl; police or other law enforcement agencies are directed to serve the Defendant with a copy of the Petition, any Order issued, and the Order for Hearing without prepayment of costs. The Petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. The Prothonotary is directed to file this Petition and Order without prepayment of costs. 8. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAlN IN EFFECT UNTIL DECEMBER 11, 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 $1,000.00 and/or up to six months in jail. 23 Pa. C. S. ~6114. Consent of the Plaintiff to Defendant's return to the residence sba1l not invalidate this Order, which can only be changed or modified through the filingofappropriate court papers for that purpose. 23 Pa.C.S. ~6113. Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S,C. ~~2261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiffs residence OR any location where a violation of this order occurs OR where the defendant may be located. If defendant violates Paragraphs 1 through 4 of this Order, defendant shall be arrested on the charge of Indirect Criminal Contempt An arrest fer violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence oflaw enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sherifl's office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this court, unless the weaponls are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest -,.' , ] ,~- ~",,-r; -$f . - - ,~' ,', -', '.,.<' -I., ~~'.- . ~ ",-_~..J"..;;; ,,_'to :,;.L, ; lI~~iic Distribution to: David A. Lopez, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row, Carlisle, P A 17013 FAXed and mailed to PSP .J A -LlJNi, lJ~l 'IIMJ!_ >>"' J\illU!!!mJlK.) '"-,' ~n:R ~", < < ,~>--- "." ".',-"".'-" - ,_. , ," ,;,- ',",-~ ~~-, .- -, l~'r-~!.J '{\T;C~",T1!"'V OF !~.::: j ,-.. , "Jj/"il ~~ ~ j \~ 01 Ji'" I, /);"/. 3: I)Q " 011 : I, . . ~ '1 ~ ~ ~ ~ CUMBEF!LilNO COUN'IY PENNSYLVANIA ~l'h " 'f) ,j~ ,.,. 0,"" 'icli<';'0'1~~"~ji'\~Wl~~~,~;~l,)~!lI! . "7 .'WJ;f''i~1')',,>>;.;j\;,'t1->i.1>,i,,'-)'g,W;~;. .'";" ,"''''''''~-~." -. .~,-,--' ..1.. , -', ',;...;,~ - -. '1li - , '.ii.li.- PFAD Number: CTl259948E ERIN ANN SULLIVAN, Plaintiff' : In the Court of Common Pleas of : CUMBERLAND County, : Pennsylvania v. : Civil Action - Law ; No. 01- 3590 CuJ 7.fAA'><- CHRISTOPHER LYNN ADAMS, Defendant : Protection From Abuse PETITION FOR PROTECTION FROM ABUSE 1. Plaintiffs name is: ERIN ANN SULLIVAN 2. I, (the Plaintift), am filing this Petition on behalf of: - myself 3, Name(s) of ALL person(s), including minor children, who seek protection from abuse. a. ERIN ANN SULLIVAN 4. Plaintiffs Address is : 3612 Kent Drive, Mechanicsburg, PA 17050 5. Defendant's Name is: CHRISTOPHER LYNN ADAMS 6. Defendant is believed to live at the following address: 2100 Market Street, 2nd Floor Apartment, Camp HiU, PA 17011 \'''''''..,'''~ ~ . ,,~ " .~. "'~ :0" -~. " r"'" 1;,-; ~" ". > f_-";' }., ~,,~~,._ -~, ., 7, Defendant's Date of Birth is: October 6, 1976 8. Defendant's Place of employment is: Three Mile Island, Middletown, Dauphin County, PA. TeL: (717) 948-8971. 9. Defendant is an adult. 10. The relationship between the Plaintiff and the Defendant is: Current or former sexual/intimate partner 11. The facts of the most recent incident of abuse are as follows: On about Saturday, May 12,2001 location: Lemoyne, PA, Plaintiff's boyfriend's residence. Defendant foDowed Plaintiff and slashed aD fonr tires on her car, which was parked outside her boyfriend's residence. When Plaintifftokf Defendant that sh~ knew he had slashed her tires, he threatened her saying, "I'D use the same knife on you that I used on your tires." Plaintiff suffered reasonable fear ofimminent serous bodily injury. 12. 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: On or about April 15, 2001, Easter Sunday, Defendant repeatedly telephoned Plaintiff at her residence despite her telling him to to contact her and the letter that she mailed to him advising him not to have any further contact witbber. On or about March 26, 2001, Defendant telephoned Plaintiff at her place of employment, screamed at her and repeatedly threatened, "I will kill you and your whole fucking family." Since approximately March 2001, Defendant has repeatedly telephoned Plaintiff at her workplace and at her residence. On one occasion in March, Defendant telephoned Plaintiff at her place of employment approximately 30 times. In or about late February 2001, Defendant waited in the parking lot ofPlaintift"s place of employment, tried to talk to her about reconciling with him, and when she refused and tried to get away from-him, called her vile names, grabbed her, and punched her in the eye. Plaintiff sustained redness, sweDing and soreness about her eye and face as a result of this incident. In or about February 2001, for approximately one week and on a daily basis, Defendant stalked .;~- . ," ~, '- "I.,; "' ~.'::,,,i.h~';,- -'~""';;"-'';;;;'''''I'n -4 ",' Plaintiff by waiting in the parking lot of her employment when she arrived at work, went to lunch, and left work at the end ofthe day. During this period of time, Defendant repeatedly approached Plaintiff, tried to talk her into reconciling with him,caDed her vile names, and on several oceasions grabbed her by the arm and restrained her when she tried to get away from him, causing her to fear for her safety. In or about December 2000, when Plaintiff told Defendant that she wanted to end their relationship, he threatened her teHing her that she would never be with anyone else, spit ou ber, shoved her to the Door, and repeatedly spat on her. As Plaintiff got up and tried to leave, Defendant grabbedber and shoved her to the Door. In or about fall 2000, Defendant drove at speeds up to 70 mpb causing Plaintiff to fear for ber safety, screamed at her,ancH)8ckbanded her in the face twice. Then Defendant reached across Plailltiff, opened the passenger side car door and attempted to push her out of the moving vehicle. Plailltitl's seatbelt prevented her from being pushed out ofthe car. Since approximately August 2000, Defendant has abused Plaintiff in ways including, but not limited to, shoring, grabbillg, slapping, and punching her; attempting to run her car off the road, and stalkillg her by foRowing her about in public places, foRowing her to her boyfriend's residence, waiting for her at her place of employment, and driving by her home to ascertain her whereabouts. Defendant has telephoned Plaintiff repeatedly at her place of employment and at her home after being told verbally and by letter not to contact her. Defendant vandalized Plailltiff's property 011 several occasiollS,oftell at times when he stalked her, causillg damage to her vehicle by "keying" it, scratching "whore" in several places on the car, letting the air ont of the tires on her car while it was parked at her place of employment and she was working, alld slashillg the tires on her car. In addition, Defelldallt has threatelled Plailltift" sayillg, "I'R win or nobody will win"; "I'll have you or nobody will have you"; "You'll only be with one person"; and "rr you don't meet with me, I'll kill you. I have guns, I carry a gun. Don't think I won't use it." Defendant is employed as an armed security guard at Three Mile Island. Plaintiff fears for her life. Shortly after Defendant vandalized Plaintiff's vehicle, he also vandalized a brand new vehicle which was parked in the driveway of Plaintiff's parents' home where Plaintiff resides. Defendant "keyed" and defaced the new Car scratching "whore" on the car. Defendant later told Plaintiff that he did not know that the new car belonged to her father and admitted to her that he vandalized her father's car because he thought that it was hers. 13, The Defendant has used, or threatened to use, the following weapon(s) against the Plaintiff or the minor child/ren: a. any and llll firearms and/or weapons. 14. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: HAMPDEN TOWNSHIP POLICE DEPARTMENT "-"'.'" : ,,; _,1<0-" -'.", ,--;'-i- -."-'" -.--->*,.- ". WEST SHORE REGIONAL POLICE DEPARTMENT SUSQUEHANNA TOWNSHIP POLICE DEPARTMENT (Dauphin County) DAUPHIN COUNTY DISPATCH 15. There is an immediate and present danger of further abuse from the Defendant. 16. Plaintiff has suffered out-of-pocket financial losses as a result of the abuse described above. Those losses are: the cost Plaintiff incurred for damage to her vehicle as a result of Defendant repeatedly vandalizing the car, and her lost wages. 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:lren in any place where Plaintiff may be found. b. Prohibit Defendant from having any contact with Plaintiff and/or minor child/ren, either in person, by telephone, orin 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. 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. d. Order Defendantto temporarily turn over weapons to the Sheriff ofthis County and prohibit Defendant from transferring, acquiring, or possessing any such weapons for the duration of the Order. 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 fees. g. Order the following additional relief, not listed above: Order Defendant to refrain from harassing Plaintiffs relatives. Enjoin Defendant from damaging or destroying any property owned by Plaintiff. Order Defendant to address his anger and violence in relationships by .< , ~ ~- < ,;_-, j h , _,~"",__ -~;_-_'", ,-,'_i __ '~i.'> d "'<11"''''-; attending and successfully completing the Choices progralll at Tressler Counseling Services located at 960 Century Drive in Mechanicshurg, PA (717) 795-0330. Order Defendant to pay $250.00 to one of MidPenn Legal Services' funding sources to pay the costs of litigating this case. h. Grant such other relief as the court deems appropriate. 1. Order the police or other law enforcement agency to serve the Defendant with a copy ofthis Petition, any Order issued, and the Order for Hearing. The petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. Respectfully submitted, Date: Cn II (!tl ( I vid A. Lopez, Attorney for MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 or 1-800-822-5288 ,,"i~'k;=~, .."" l-:.' i-;'-'_J~-'. ~".~,--,'-- .......~--- i-.' ",-." .~ i:iIk....~'" '. VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S.~4904, relating to unsworn falsification to authorities. Dated: {g - '1 - 0 I ~ ~.JJ~ Erin Ann Sullivan, Plaintiff "_~Ii11~ii&J_~_t;:;~":~ !!~_~$ll~~';''!ill!:!W~~'i(;\~"-c ~-r'r.;; , ;i' --~,- ,~."- ,,- " ,-- -_- ~c.i="'^- L'{ [0 ;";'~'il1 '!!ilL Q ,~ . _:"~J _' ~J.. ,~ ~- ~ ~ (") C) c S c_ ___I ""tJ 0' c:: -1"1 rnf~-; :::-.2: .',~ Z:J , ;!;~S zro. cl)2',: r?(~ ~ ~ ""T) -,-' ::::::..! eO =-1: o. " Z,-, (") )> ~" 1;;' (SIT'! C -, ~ :,.) '" :D .-J -< I\.) Cr' ....J ... :} t l' ~ " ~ '" '\, , <:> - ,,' 06/11/01 - "-~"-,!'''j i""""-""I-~"""."" ~ I MON 14: 57 F"u 717 240 6573 "~ ' .1 ht~.:... '[" ll!M;m.-,,,,~,~,,,' *******~******************* *** MULTI TN REPORT *** *************************** CUMB CO PROTHONOTARY 1i!J00l TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2672 ERROR [ 01l9p2490779 [ 03]9p2405331 PSP CP --- , , OFFICE Of' THE PRarHONaI'ARY CUMBERLAND CCXJN1'Y COURWaJSE CNE COOR'lllOOSE SQUARE CARLISLE, ?A. 17013-3387 (717) 240-6195 FAX (717) 240-6573 v I ATE LEe 0 PIE R TO: "" ..I.... I q Co /VI.I'.I..S. PA STATE POLICE . ~~~T"A ~p .$$. - FAX i: 717-249-0779 ( ~: CURTIS R. LONG RE: PFA ORDERS MESSAGE: q ~. Of' PAGES (IOCf.UDING COVER SHEET) '!his ~ :is illtelWl ally fir t:tE ~ of tlB in:Iivilhll ex- alt:iq. to Wrld1 is is..n. ~ I, erd ~ a:ntain infWnoIticn. tlat is ~. W"lfid;ntial em e<aq:t fmn i1;.....Jcst~ IJ"d:r 'fPJ;tWili; larI. {f tlE ~ of l.tris ~ is rot; tIe inleU:d ra::ipieot, }OJ are iEI:\lI:f rotif.ie:l ttet a1}' dis;emiretial, dis1:riJ:.utiro cr awing ~ this OOllTu'lli:atio1 ~ strictly p:dtibiIa:l. If}O.l taI.e J:Emi1lOO ltus 0Jll1UIir.3::irn in et:t'I:r. p:\ff;Ele rotify lB itma:liiltely ty leU!J;h:rn arl reb.Jm tlE a:igimlll , V' lP L6 at . -..:J..:L.-..... ...;.. 14-...,. '~c:. ~~l FP'I"V':i~. TI-a1k ~. i0"~~-~"'~I' " ~~ ~" ... ~,--~~,~I'-'-'-....- " . '-".--< .~.' -.",,:k" SHERIFF'S RETURN - REGULAR CASE NO: 2001-03590 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SULLIVAN ERIN ANN VS ADAMS CHRISTOPHER LYNN GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon ADAMS CHRISTOPHER LYNN the DEFENDANT , at 0020:45 HOURS, on the 11th day of June , 2001 at 2100 MARKET ST 2ND FLOOR CAMP HILL, PA 17011 by handing to CHRISTOPHER LYNN ADAMS a true and attested copy of PROTECTION FROM ABUSE together with NOrICF. OF HF.ARTN(:; ANI) ORflRR, 'l'f'MP Pl'A. PR'I'T'I'TON and at the same time directing His attention to the contents thereof. DEFENDANT STATED WAT HE WES NOT HAVE ANY WEAPONS. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 9.30 .00 10.00 .00 37.30 So Answers: .~. . ~~~-'~f'~ R. Thomas Kline 06/12/2001 Sworn and Subscribed to before me this J.';& day of BY~J I~v~ Deputy She ff tk2~' a~. Prothonotary , ~ A.D. ,. ~-- -""-'J' .- " --,'"--1,:,, ,-oi,,- -,.-.;1:,.;" -'~-- ',_i'"........-~ ERIN ANN SULLIVAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 01- 3590 CIVIL TERM CHRISTOPHER LYNN ADAMS, Defendant : PROTECTION FROM ABUSE AND NOW, ~e :::OO~~:=:~~ ,,,,,," Motinn ro' Continuance, the matter scheduled for hearing on June 18,2001, by this Court's Order ofJune 11, 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 of18 months from the date it was entered or until further Order of Court, whichever comes first. By the Court, -]~, ~ r~.O\ L-- 01.-). Joan Carey, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 Marlin L. Markley, Attorney for Defendant Law Offices of Pat Lauer, Jr. 2108 Market Street Camp Hil~ PA 17011 ~ <'-- .~ -.,,- 0' " h <' , -.'_o~,_" --, "~="i:fcc ERIN ANN SULLIVAN, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 01- 3590 CIVIL TERM CHRISTOPHER LYNN ADAMS, Defendant : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff, Erin Sullivan, by and through her attorney, Joan Carey ofMidPenn Legal Services, moves the Court for an Order continuing generally the hearing in the above-captioned case on the grounds that: I. A Temporary Protection From Abuse Order was issued by this Court on June 11, 2001, scheduling a hearing forJune 18, 2001, at I :30 p.m. 2. The Cumberland County Sheriffs Department served Defendant with a certified copy of the Temporary Protection From Abuse Order and Petition for Protection From Abuse at his residence located at 2100 Market Street, Camp Hill, Pennsylvania, on June 11,2001, at 8:45 p.m. 3. The parties agree, by and through their respective counsel, that the hearing be continued generally to afford them time to execute a Consent Agreement. 4. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of 18 months from the date it was entered or until further Order of Court, whichever comes first. ;-= .~~ ." -,,---I ,o~~_" _.....-.;_-,~"' --~" L'~1;~, 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 or until further Order of Court, whichever comes first. . Carey, Attorney for MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 :&i[-wiJi'u~,~~!~~~j;j~dlliJj~~_~~~i.%~li;:'iJ'ii*~""'~Hj"l!'l;:ffi.'.i"'"ef".Ali~I~~';;' ,~",_"'r,'. ,~.__ ~~ _ ,,,_~f";:>ri~_'_"" ,j,''''',,~ _;~"% ,,,"_'C. '"'^'~',_~ ,? =~, ",_c'" ~""" """-:f',~ -w ufllN! 1Il .-.....L.._-'~1l1i~tT....,.Vl.~ ._~.;."'_'r, ]~Ull._tli o c: ~.,.. "Uii !.:p6: <C.. ~. 655' ;::; :;~,;-~ :;.:0 20 j;; () c::: 2:: =< ~ ~ "",-,"."'-' .:::::> .j;:- l"''''" ~; ! II 'I Ii ,I '! a o ..., -'~~j - '-i~21 ~2 -- ''''I- <F! ,.~~~$ ':-.;c) :rj-, ~~f:~ 55 """ " .:Jt J:- .'_, ,~~',''''''''~'''''"~'''_ """"'-"'_" ,r,,' "''''' -,. "-;,, ,,",,,-if.h,, - -~, ''-''0. _;, _"~ '-' ,~. .1 '. :_ ~ , "- " '[t' .:'~, ERIN ANN SULLIVAN, Plaintiff : In the Court of Common Pleas of : CUMBERLAND County, : Pennsylvania v. : Civil Action - Law : No. 01-3590 CHRISTOPHER LYNN ADAMS, Defendant : Protection From Abuse FINAL ORDER OF COURT Defendant's Name is: CHRISTOPHER LYNN ADAMS Defendant's Date of Birth is: October 6, 1976 Name(s) of All protected persons, including Plaintiff and minor children: 1. ERIN ANN SULLIVAN AND NOW, this 19th Day of June, 2001 the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADruDGED and DECREED as follows: Plaintifi; Erin Ann Sullivan, is represented by David A. Lopez ofMidPenn Legal Services; Defendant, Christopher Lynn Adams, is represented by Marlin L. Markley of the Law Offices of Patrick F. Lauer, Jr. Defendant, although agreeing to the terms of this Order, does not admit the allegations made in the Petition. Plaintiffs request for a fmal protection order is granted. 1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other protected person in any place where they might be found. """,'i. ~ .' .-," ;:-'1-, ~. J." 2. Defendant is prohibited from having ANY CONTACT with the Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at Plaintiff's school, business, or place of employement. Defendant is specifically ordered to stay away from the following locations for the duration of this order. Plaintiffs current residence: 3612 Kent Drive, Mechanicsburg, PA and any other place where she may stay during the term of this Order. Plaintiff's place of employment: Rite Aid Pharmacy 2023A Linglestown Road, Harrisburg, P A (Dauphin County) and any other place where Plaintiff may be employed during the term of this Order. Plaintiffs school: Academy of Medical Arts and Business 2301 Academy Drive, Harrisburg, PA (Dauphin County) 3. Defendant shall not contact the Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 4. Defendant shall immediately turn over to the Sheriff's Office, or to a local law enforcement agency for delivery to the Sheriff's Office, any firearms license the Defendant may possess, and the following weapons used or threatened to be used by Defendant in an act of abuse against Plaintiff and/or the minor children. I. any and all firearms and/or weapons. 5. Defendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration of this order. Any weapons and/or firearms license delivered to the sheriff pursuant to this order or the Temporary Order shall not be returned until further order ofthe court. DEFENDANT, MAY, HOWEVER, POSSESS FIREARMS, SHOTGUNS AND/OR RIFLES, ISSUED BY HIS EMPLOYMENT AT THREE IvlILE ISLAND TO BE USED SOLELY FOR THE LIMITED PURPOSE OF PERFORMING HIS JOB REQUIREMENTS AS AN ARMED SECURITY GUARD. DEFENDANT'S JOB-RELATED POSSESSION OF FIREARMS, SHOTGUNS AND/OR RIFLES ISSUED BY HIS EMPLOYER SHALL BERESTRlCTED TO THE THREE IvlILE ISLAND FACILITY AND ASSIGNED PERIMETER. UNDER NO C;IRCUMSTANCES MAY DEFENDANT POSSESS ANY FIREARM, SHOTGUN AND/OR RIFLE FOR ANY OTHER REASON, AT ANY OTHER LOCATION DURING THE TERM OF THIS ORDER. Defendant may, upon the expiration of this Order, request that the sheriff return any firearms and/or weapons held pursuant to this ',>,-'-0.:' ,",'" j. :';_,~,.,~,,- ';'T;;~ ~- -~- ' , ." I. '",,-' ,<"_ Ii 'W'~~illr~I!~~ , . Order. The sheriff shall determine if Defendant is otherwise legally entitled to possess the firearms and/or weapons. If the Protection From Abuse Order has expired and Defendant is legally entitled to possess firearms andfor weapons, the sheriff shall present an Order to the Court authorizing that the firearms and/or weapons be returned to Defendant. Otherwise, the sheriff shall notify Defendant that he must file a petition with the Court seeking a return of the firearms and/or weapons, in which case the Court, upon petition, will schedule a hearing with notice to Plaintiff 6. The following additional relief is granted as authorized by 96108 of the Act: Defendant is prohibited from having any contact with Plaintiff's relatives. Defendant shall refrain from harassing Plaintiffs relativeS. Defendant is enjoined from damaging or destroying any property owned by Plaintiff. Defendant is ordered to enroll (within 10 days of the entry of this Order) in the Choices program for batterers at Tressler Counseling Services, 960 Century Drive, Mechanicsburg, P A (717-795-0330), successfully complete the 26-week program, and follow and complete any related recommendations for treatment made by the program staff. Defendant shall be responsible for the payment of aU. costs related to enrolling and attending the program and for any costs for additional treatment recommended by staff. The court costs aud fees are waived. 7. A certified copy of this Order shall be provided to the poliqe department where Plaintiff resides and any other agency specified hereafter: HAMPDEN TOWNSHIP POLICE DEPARTMENT WEST SHORE REGIONAL POLICE DEPARTMENT SUSQUEHANNA TOWNSHIP POLICE DEPARTMENT (Dauphin County) DAUPHIN COUNTY DISPATCH S. THIS ORDER SUPERSEDES: 1. ANY PRIOR PF A ORDER 9. All provisions of this order shall expire on: June 19, 2002 "'"",,,,~ ~- .,;;-:1,;.;. _- _ NOTICE TO THE DEFENDANT VIOLATION OF TillS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PAC.S. ~6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S;C. ~2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C g~2261- 2262. IF THE BRADY INDICATOR PARAGRAPH APPEARS IN THE ORDER, YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT, 18 U.S.C. g922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION. NOTICE TO LAW ENFORCEMENT OFFICIALS The police who have jurisdiction over the plaintifl's residence OR any location where a violation of this order occurs OR where the defendant may be located, shall enforce this order. An arrest for violation of Paragraphs I through 5 of this order may be without warrant, based soley on probable cause, whether or not the violation is committed in the presence of the police. 23 Pa.C.S. g6113. Subsequent to arrest, the police officer shall seize all weapons uset;l or threatened to be used during the violation of the protection order or during prior incidents of abuse. The Cumberland County Sheriffs Department shall maintain possession of the weapons until further order of this Court. When the defendant is placed under arrest for violation of this order, the defendant shall be taken to the appropriate authority or authorities before whom defendant is to be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police officer OR the plaintiff. Plaintiff's presence and signature are not required to file the complaint. If sufficient grounds for violation of this order are alleged, the defendant shall be arraigned, bond set and both parties given notice ofthe date of the hearing. i..;' -, > ~~"~. -, ",!-.1/I,s.h,"'M "~ ~~~, "'~....o~_,,,,,,", ;1 "~Ifu-~,,""~~;...~-,. If entered pursuant to the cons~nt of Plaintiff and Defendant: ~1 b.L Christopher l;m Adams, Defendant d~~ndant Law Offices of Patrick F. Lauer, Jr. DaVId A Lopez, Attorney fo MidPenn Legal Services Distribution to: David A Lopez, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row, Carlisle, PA 17013 Marlin L. Markley, Attorney for Defendant Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Camp Hill, P A 17011 FAXed and mailed to PSP - (,/t'i/Ol ~ Oa~ - (i7rt::L?i<..10 4~l ['~/c.c..c CoPl'o;' 9r'c.>-9V -J-o t,/I<t/O{ ~ - Cbpy VYt'b.c~ (pl,q/o I T~hh"L~ '"' ", ~.......- ,..1"""_""""0' L ~ 1.- I"-~';!l@il 'iiIIi lLLJUki'OOM$:,' 06/19/01 TUE 15:15 FAX 717 240 6573 CUMB CO PROTHONOTARY 1i!I001 *************************** *** MULTI TN REPORT *** *************************** TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2684 [ 04J9p2583343 [ 01J9p2490779 [ 03J9p2405331 LS PSP CP ERROR , , Off( CE Of THE PRcr('HClIlOI'ARY CUMBERtAND CO'..JNTY CDURniCllSE ONE COURTHClISE SQUAIlE CARLISLE. PA. 17013-3387 (717) 240-6195 fAX (717) 240-6573 V I ATE LEe 0 PIE R TO; pf>. STATE POLICE - CellI. I'Hle.e s'/:.. M. P. J..S . .- ., FAX n: 717-249-0779 ~: CURTIS R. LONG RE: PFA ORDERS MESSAGE: ~ 00. 01' PAGES (INCWOING WVEll SHEET) 'Ihis ". "1' is ;i" ,1:eJ drl ally fi:JL tre \$i: of tte irdiv:ido.el. cr mtit;y In Wrid1 is is cd:h. i,.nI fI5Y o::ntilin :inftmmtim ttat is p:iv:i.1egrl. aneidential ad e<a1l;t fm1l ";....1,..,.,.... I.IlH" -WH.-.t>le Uw. [f Ite re;!H" CJf this II -g" is rot t1-e inta-W::; J:eCipia:!t. ~ are ~ rutifiB:l ltet <nf d,issaniratim, d.istriI:.ul::i or: o:;p{irg cf. this curm..n.icatirn is strictly p:d1ibited. If ~ tava mEi..a'l ltus o:mnnic.!'".Jm in emr. pJ.e;lsle rotify U3 :imTe:liately Of telfP\:re .;rd return tie crigirelll_ :rp to u;; at WI'> i'tTk' a:tiress vj.;l tiE ~!.S. m>ta1. ~. 'Ih::rd> )OJ. Tressler Counseling Services of the Capital Region 960 Century Drive p.o. Box 2001 Mechanicsburg. PA 17055-0707 PI'\'Il": (717) 795-0330 FeIX: (717) 795-0445 ! n",TDLI.- 1-800-654-5984 (P" Roll,lY Savitt') ll'l\'W."ti'lk,)iI.['I~f ..1 Prl':)r.l/l/('1 Ol,7A-,'1! Ultih'hlll S,'c"i,Tl Alinis/rit's Dear J",vlc.€. +f.o~ Name C+Mz..'~ A-,~s po - 0\ - ~~'70 ?F4- ~- , Date: ,1- 2.0-01 01 ~,I ,~~ .'l. ,,-\,.tr-'.'"-"':"~C';fh -/0\ P'O. _Has successfully completed CHOICES Domestic Violence Program as of _ Is in danger of receiving an administrative discharge. '\/' Has received an administrative discharge as of ll-~'-c.r Due to: J Excessive Absences Continued Acts of Violence _ Non-Payment of Fees Other Please Contact me at 795-0330 if you require additional information. CC: Chris Adams 640 Dunkle School Road Halifax, PA 17032 Erin Sullivan 36.12 Kent Drive Mechanicsburg; PA 17055 Michael P. Cline LSW CHOICES Program Coordinator "