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ROSANNA MARIE DULAK,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs,
: NO. 01- ,159~
CIVIL TERM
JULIE MARIE DULAK,
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 onthe ,& f\;;ay of June, 2001, at !: 3 () .m., in
Courtroom No..-1-- on the 4th Floor of the Cumberland County Courthouse, 1 Courthous~uare,
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, ~6114. Violation may also subject you to prosecution and criminal penalties
under the Pennsylvania Crimes Code. Underfederallaw, 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 DlSABlLlTIESACT OF 1990
The Court of Common Pleas of Cumberland Countfisr~uireaby la.~ 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 offi(le. All arrangements
must be made at least 72 hours prior to any hearing or business before the court, Yon must attend the
scheduled conference or hearing,
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GU/v!eEIiLAND C
PENN?YLVAN~UN1Y
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ROSANNA MARIE DULAK,
Plaintiff
: In the Court of Common Pleas of
: CUMBERLAND County,
v.
: Pennsylvania
JULIE MARIE DULAK,
Defendant
: Civil Action - Law
~No. 01- )59;L. C:wJ -fb-
:
: Protection From Abuse
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: JULIE MARIE DULAK
Defendant's Date of Birth is: December 16, 1958
Name(s) of All protected persons, including Plaintiff and minor children:
1, ROSANNA MARIE DULAK
AND NOW, on 11th Day of June, 2001 upon consideration ofthe 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 shall be evicted and excluded from the residence at:
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705 Henry Street
Meehanicsbnrg, PA
or any other permanent or temporary residence where Plaintiff or any other person
protected under this Order may live. Plaintiff is granted exclusive possession of
the residence. Defendant shall have no right or privilege to enter or be present on
the premises of Plain tiff or any other person protected under this Order,
3. 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 Plaintifl'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 residence listed above.
4. Defendant shall not contact Plaintiff, or any other person protected under this
Order, by telephone or by any other means, including through third persons.
5. The following additional relief is granted:
Defendant is ordered to refrain from harrasing Plaintiff's relatives.
Defendant is prohibited from having any contad with Plaintiff's relatives.
Defendant is enjoined from damaging or destroying any property owned
solely 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:
MECHANICSBURG 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 t4e designated authority of
any addresses, ot~r than the Defendant's residence, where Defendant can be
served. The Prothonotary is directed to file this Petition and Order without
prepa)1l1ent of costs.
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8. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL DECEMBER 11, 2002 OR UNTIL
OTIIERWISE 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 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 US.C. ~~2261-
2262,
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the police who have jurisdiction over the plaintiff's
residence OR any location where a violation of this order occurs OR where the
defendant may be located. If defendant violates Paragraphs I through 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 l!ll 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 offi~e 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
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Distribution to:
David A. Lopez, Attorney for Plaintiff ~ -{;,. ~ /l1 t'f,,5
MidPenn Legal Services
IHrvine Row, Carlisle, PA 17013
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PFAD Number: JM1261062Y
ROSANNA MARIE DULAK,
Plaintiff
: In the Court of Common Pleas of
: CUMBERLAND County,
v.
: Pennsylvania
: Civil Action - Law
JULIE MARIE DULAK,
Defendant
.
: No. 01- 3.1"1.J..
: Protection From Abuse
PETITION FOR PROTECTION FROM ABUSE
1. Plaintifl's name is:
ROSANNA MARIE DULAK
2. I, (the Plaintifl), am filing this Petition on behalf of:
- myself
3. Name(s) of ALL person(s), including minor children, who seek protection from abuse.
a. ROSANNA MARIE DULAK
4. P1aintifl's Address is: 705 Henry Street, Mechanicsburg, PA 17055
5. Defendant's Name is:
JULIE MARIE DULAK
6. Defendant's address is:
unknown.
7. Defendant's Date of Birth is:
D~ember 16, 1958
8, Defendant's Place of employment is:
unemployed
9, Defendant is an adult.
10, The relationship between the Plaintiff and the Defendant is:
Parent I Child
I L The defendant has been involved in a criminal court action.
12, The defendant is not currently on probation I parole
13. The facts of the most recent incident of abuse are as follows:
On about Thursday, May 24, 2001 at approximately 1:30AM
location: 705 Henry Street, Mechauicsburg, PA, Plaintiff's residence
At approximately 1:30 a.m., Defendant woke Plaintiff, her 74-year-old mother, screamed at her,
threatened to kill ber with an ice-pick. and repeatedly puncbed ber with.herfliSts about berhead
and shoulders. When- PlaintitT tried to caD 911 for help, Defendant knocked the telepboneout of
her hand, and as Plaintiff tried to leave the residence, Defendant punched hfr with her fists
about her head, neck, and shoulders. Defendant knocked chairs over, and screamed at Plaintiff
further threatening to kill her and to trash and torch the house. Plaintiff susfained soreness
about her head, redness about her neck as a result of this incident. Plaintiff suft"ercd reasonable
fear of imminent serious bodily injury. Plaintiff reported the incident to the Mechanicsburg
Police.
14. The police department(s) or law enforcement agencies that should be provided with a copy of the
protection order are:
MECHANICSBURG POLICE DEPARTMENT
IS. There is an immediate and present danger of further abuse from the Defendant.
16. Plaintiff is asking the court to evict and exclude the Defendant from the following residence:
705 Henry Street, Mechanicsburg, PA
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Owned By:
Rosanna Marie Dulak, Plaintiff
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. Evict/exclude Defendant from Plaintifl:'s residence and prohibit Defendant from
attempting to enter any temporary or permanent residence of the Plaintiff.
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 Plaintiffs 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 Plaintift's relatives and Plaintift'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. Order Defendant to pay the costs of this action, including filing and service fees,
f Order the following additional relief; not listed above:
Order Defendant to refrain from harassing Plaintiff's relatives.
Enjoin Defendant from damaging or destroying any property owned solely by
Plaintiff.
Order Defendant to pay $250.00 to one of MidPenn Legal Services' funding
sources to pay the cost oflitigating this case.
g, Grant such other relief as the court deems appropriate.
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.
David A. Lopez, Esq.
Agency: MidPenn Legal Services
8 Irvine Row, Carlisle, PA
Respectfully Submitted by:
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VERIFICA TION
I veri1Y 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:
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R01anna Marie Dulak, Plaintiff
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06/II/VI MON 15:17 FAX 717 240 6573
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CUMB CO PROTHONOTARY
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OFflCE Of' '!lIE PRornCN)'l'ARY
CUMBERLAND COJNTY COURWOOSE
OOE CUJR'lHaJSE SQUARE
CARLISLE. PA. 17013-3367
(717) ~40-6195
FAX (717) 240-6573
V I ATE LEe 0 PIE R
TO: PA STATE POLICE - CeNt. ,q,lIeesr:... M.IJ. J...S .
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FAX n:
717-249-0779
~: CURTIS R. LONG
RE: PFA ORDERS
MESSAGE:
---.-..-------.
.-2- 00_ OF I?l\GES (INCWDING COVER SHEET)
TI1i.s ~ is int:arl3:l ally fir tte l6e of tie irrliviI:UU cr entity to \\tlich is is tdlLm.... en! mft
crntaln inft:matit;n t:tm: is p:ivilig;rl. o:nfid31tia1 <rd ~ fix:m ri;<rl"" II"E! \I"li;!r 'W1 ;..-1" 1&1. If
t1-e re;;B:- of this 1\ "';J' is rot tl-e intade::l m:::ipie'lt, )O.l are tereI:y rotified tt-at <nf d,is;m1iret.iD1.
d.isl:riJ:utim OC a:pfirg r:f. this connnicatim is strictly p;thibit:OO. If}Ul h;r.e rs:eiu:d UuS
o:nmnir.r..im in emr. pkme rot:ify l13 irmaiiotely q. tele1;h:re a"d tebJm tie .:rigirnl" -"'1' to LS at
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ROSANNA MARIE DULAK,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
:CUMBERLANDCOUNTY, PENNSYLVANIA
vs.
: NO. 01- 3592 CIVIL TERM
JULIE MARIE DULAK,
Defendant
: PROTECTION FROM ABUSE
ORP~FORCONTuruANCE
AND NOW, this I ~ day of June 2001, upon consideration of the attached Motion fur
Continuance, the matter scheduled for hearing on June 18, 2001, by this Court's Order ofJune 11,
2001, is hereby rescheduled for hearing on August 16, 2001 at 3 :30 p,m. in Courtroom NO.3 of the
Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania,
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
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ROSANNA MARIE DULAK,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 01- 3592 CIVIL TERM
JULIE MARIE DULAK,
Defendant
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
Plaintiff, Rosanna Dulak, by and through her attorney, Joan Carey ofMidPennLegal 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 11,
2001, scheduling a hearing for June 18, 2001, at 3:30 p.m.
2. The Cumberland County SherifPsDepartment has been unable to effect service on the
defendant.
3. Plaintiff requests that the above captioned matter be rescheduled to afford the
Cumberland County Sheriff time to serve the defendant with the Temporary Protection From Abuse
Order and Petition,
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
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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
18 months from the date it was entered or until further Order of Court, whichever comes first.
Respectfully submitted, /
J Carey, Attorney Plaintiff
MidPenn Legal Servi es
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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ROSANNA MARIE DULAK,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: NO. 01-3592 CNIL TERM
JULIE MARIE DULAK,
Defendant
: PROTECTION FROM ABUSE
ORDER FOR CONTINUANCE
AND NOW, this ,J~lffiy of August, 2001, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on August 16, 2001, at 3:30 p.m. by this Court's
Order of June 15, 200 I, is hereby rescheduled for hearing on November 19, 2001, at 9:30 a.m. in
Courtroom No.3 on the 4th Floor of the Cumberland County Courthouse, 1 Courthouse Square,
Carlisle, Pennsylvania.
The Temporary Protection From Abuse Order shall remain in effect for a period of 18
months from the date it was entered, through December 11, 2002, or until further Order of Court,
whichever comes first.
Cumberland County Sheriff's Department
(of! per'50(lQ1r iJ'vff)
Joan Carey
David A. Lopez
Attorneys for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, P A 17013
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ROSANNA MARIE DULAK,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: NO. 01- 3592 CIVIL TERM
JULIE MARIE DULAK,
Defendant
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
Plaintiff, Rosanna Dulak, by and through her attorneys, Joan Carey and David A. Lopez of
MidPenn Legal Services, moves the Court for an Order rescheduling the hearing in the above-
captioned case on the grounds that:
1. A Motion was filed and an Order for Continuance was entered on June 15,2001,
rescheduling the hearing for August 16,2001, at 3:30 p.m.
2. On August 10, 2001, the Dauphin County Sheriff's Department advised MidPenn
Legal Services staff that they were unable to locate Defendant to serve her with the Order for
Continuance, Temporary Protection From Abuse Order and Petition for Protection From Abuse.
Plaintiff has no further information on Defendant's whereabouts at this time.
3. Plaintiff requests that the above captioned matter be rescheduled pending service of
Defendant.
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, through December II, 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
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18 months from the date it was entered, through December 11,2002, or until further Order of Court,
whichever comes first.
Respectfully submitted,
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MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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SHERIFF'S RETURN - OUT OF COUNTY
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,CASE NO: 2001-03592 P
COMM6NWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DULAK ROSANNA MARIE
VS
DULAK JULIE MARIE
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:
DULAK JULIE MARIE
but was unable to locate Her
in his bailiwick. He therefore
deputized the sheriff of DAUPHIN
County, Pennsylvania, to
serve the within PROTECTION FROM ABUSE
On Auqust
24th , 2001 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs:
Docketing
Out of County
Surcharge
18.00
9.00
10.00
.00
.00
37.00
08/24/2001
R. homas Klin:
Sheriff of Cumberland County
Sworn and subscribed to before me
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Prothonotar
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@ffite of tfrc ~4criff
William T. Tully
Solicitor
J. Daniel Basile
ChiefDeputy
Mary Jane Snyder
Real Estate Deputy
Michael W. Rinehart
Assistant Chief Deputy
Dauphin County
Harrisburg, Pennsylvania 17101
ph: (717) 255-2660 fax: (717) 255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania
DULAK ROSANNA MARIE
vs
County of Dauphin
DULAK JULIE MARIE
233-6230
Sheriff's Return
No. 2023-T - -2001
OTHER COUNTY NO. 01-3592
I, Jack Lotwick, Sheriff of the County of Dauphin, State of
Pennsylvania, do hereby certify and return, that I made diligent
search and inquiry for DULAK JULIE MARIE 233-6230
LIVING WITH GILBERTO DIAZ REYES
the DEFENDANT named in the within PFA NOTICE/HEARING/ORDER & CONTINUENCE
and that I am unable to find him/her in the County of Dauphin, and
therefore return same NOT FOUND, August 17, 2001
DEFENDANT WAS EVICTED FROM 1411 BOMBAUGH ST., HBG., 17103 PER EUGENE MALEY,
LANDLORD. EXPIRED BEFORE DEFENDANT COULD BE FOUND.
Sworn and subscribed to
So Answers 1
Jf~
before me this 17TH day of AUGUST, 2001
~. ~fJNM)
Sheriff of Dauphin County, Pa.
PROTHONOTARY
By
Deputy Sheriff
Sheriff's Costs: $0.00 PD 00/00/0000
RCPT NO
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In The Court of Common Pleas of Cumberland County, Pennsylvania
Rosonna Marie Dulak
VS.
Julie Marie Dulak
SERVE: Julie Marie Dulak
No.
01
3592 civil
Now, July 24, 2001
, 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 of the Plaintiff.
~~~-#
Sheriff ofCurnherland County, PA
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
$
$
.
.
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"
ROSANNA MARIE DULAK,
Plaintiff
: IN THE COlJRT OF COMMON PLEAS OF
:CUMBERLANDCOUNTY, PENNSYLVANIA
vs,
. NO. 01- J.52.~ CIVIL TERM
JULIE MARIE DULAK,
Defendant
: PROTECTION FROM ABUSE
ORDERJ~1)R_CO_NTINlTANCE
AND NOW, this .L:l!bday of June 2001, upon consideration of the attached Motion tor
Continuance, the matter scheduled for hearing on June 18, 200], by this Court's Order of June I I,
2001, is hereby ~J1~qj.\ledJQ[J)~i!-\1#fi!?~~ij',gii~fJ:8,~ddr~['l;;agp.frt:'irtcittJttf6(jmNo J of the
10:lZ\lmtt~dand. CQynty.Collrthouse" 1..Cburt:house.Squar~..C~rlisle,.penllsyl\lania."
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,
, i C'
15/( ,q C
George E.' laffer, President
Joan Carey, Attomey for Plaintiff
MIDPENN LEGAL SF:RVICES
8 Irvine Row
Carlisle, PA 17013
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TRUE C,.;PY FROM RF.cmm
In TeitimC'ny ,,'k,r,'" !. ! n8le \Hlto ~"'t my hand
and :jlT(, sa. ill of sai ('1I-'..rt..1It Carlisle, Pa.
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ROSANNA MARIE DULAK,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
vs.
: CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 01- 3S7'- CIVIL TERM
JULIE MARIE DULAK,
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.
"f-
A bearing on this matter is scheduled on the J.1;. day of June, 2001, at _i : ~ O.m., in
Courtroom No. -3- on the 4th Floor of the Cnmberland County Courthouse, 1 ~quare,
Carlisle, Pennsylvania.
You MUST obey the Order that is attached until it is modified or tenninatedby 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 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.
Yon 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 tor you. If you do not have a lawyer or
cannot afford one, go tQ 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 busiriess before the court. You must attend the
scheduled conference or hearing,
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ROSANNA MARIE DULAK,
Plaintiff
: In the Court of Common Pleas of
: CUMBERLAND County,
v,
: Pennsylvania
: Civil Action - Law
JULIE MARIE DULAK,
Defendant
; No, 01- ~Sf~
: Protection From Abuse
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: JULIE MARIE DULAK
Defendant's Date of Birth is: December 16, 1958
Name(s) of All protected persons, including Plaintiff and minor children:
L ROSANNA MARIE DULAK
AND NOW, on 11th Day of June, 2001 upon consideration of the attached Petition
for ProtectionfrQm Abuse, the court hereby enters the following Temporary Order:
Plaintiff's reqnest 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 shall be evicted and excluded from the residence at:
",M.l.U&i~
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."~~-~
705 Henry Street
Mechanicsburg, PA
or any other permanent or temporary residence where Plaintiff or any other person
protected under this Order may live. Plaintiff is granted exclusive possession of
the residence. Defendant shall have no right or privilege to enter or be present on
the premises of Plaintiff or any other person protected under this Order.
3. Defendant is ptohibitedfrom 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 residence listed above.
4. Defendant shall not contact Plaintiff, or any other person protected under this
Order, by telephone or by any other means, including through third persons.
5. The following additional relief is granted:
Defendant is ordered to refrain from harrasing Plaintiff's relatives.
Defendant is prohibited from having any contact with Plaintiff's relatives.
. Defendant is enjoined from damaging or destroying any property own~
solely 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:
MECHANICSBURG 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 tl\e 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
prepilY\llent of costs.
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8. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL DECEMBER 11, 2002 OR UNTIL
OTHERWISE MODIFIED OR TERMINATED BY TillS COURT AFTER
NOTICE AND HEARING.
NOTICE TO THE DEFENDANT
Defendant is hereby notified that violation of this Order may result in arrest for
indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up
to six months in jail. 23 Pa,C.S, 96114, Consent of the Plaintiff to Defendant's return
to the residence shall not invalidate this Order, which can only be changed or
modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S,
96113, Defendant is further notified that violation of this Order may subject him/her
to state charges and penalties under the Pennsylvania Crimes Code and to federal
charges and penalties under the Violence Against Women Act, 18 U.S.c. 992261-
2262.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the police who have jurisdiction over the plaintiff's
residence OR any location where a violation of this order occurs OR where the
defendant may be located. If defendant violates Paragraphs 1 through 4 of this Order,
defendant shall be arrested onthe charge of Indirect Criminal Contempt An arrest
for violation of this Order may be made without warrant, based solely on probable
cause, whether or not the violation is committed in the presence oflaw enforcement.
Subsequent to an arrest, the law enforcement officer shall seize !\II weapons used or
threatened to be used during the violation of this Order OR during prior incidents of
abuse. Weapons must forthwith be delivered to the Sheriff's offipe of the county
which issued this Order, which office shall maintain possession of the weapons until
further Order ofthis court, unless the weaponls are evidence ofa crime, in which
case, they shall remain with the law enforcement agency whose officer made the
arrest
BY THE COURT:
1f~fJ\r- > ~
1'ClJo.. .
TRUE COpy FROM RECORD
In T !lStimooy wnereof, I here unto set my llanO
and tile seal of saki at Cartl$ltl. PI.
Thi /I ii::day ~ /
JJnzi.-
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Ptvthonlltllfl'
Distribution to:
David A. Lopez, Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row, Carlisle, PA 17013
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PFAD Number: JM1261062Y
ROSANNA MARIE DULAK,
Plaintiff
: In the Court of Common Pleas of
: CUMBERLAND County,
v,
: Pennsylvania
: Civil Action - Law
JULIE MARIE DULAK,
Defendant
;No,OI- 359/
: Protection From Abuse
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiffs name is:
ROSANNA MARJE DULAK
2. I, (the Plaintifi), am filing this Petition on behalf of:
- myself
3, Name(s) of ALL person(s), including minor children, who seek protection from abuse,
a. ROSANNA MARJE DULAK
4. Plaintiffs Address is: 705 Henry Street, Mechanicsburg, PA 17055
5. Defendant's Name is:
JULIE MARJE DULAK
6. Defendant's address is:
unknown.
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7. Defendant's Date of Birth is:
December 16, 1958
8. Defendant's Place of employment is:
unemployed
9. Defendant is an adult.
10, The relationship between the Plaintiff and the Defendant is:
Parent / Child
II. The defendant has been involved in a criminal court action.
12. The defendant is not currently on probation / parole
13. The facts of the most recent incident of abuse are as follows:
On about Thursday, May 24, 2001 at approximately 1:30AM
location: 705 Heury Street, Mechanicsburg, PA, Plaintiff's residence
At approximately 1:30 a.m., Defendant woke Plaintiff, her 74-year-old mother, screamed at her,
threatened to kill her with an ice-pick, and repeatedly punched her with her fists about her head
and shoulders. When Plaintiff tried to call 911 for help, Defendant knocked the telepl,lone out of
her hand, and as PlaintitTtried tokave the residence, Deftlildantpllnched her with her fists
about her head, neck, and shoulders. Defendant knocked chairs over, and screamed at Plaintiff
further threatening to kill her and to trash and torch the house. Plaintiff sus*ained soreness
about her head, redness about her neck as a result of this incident. Plaintiff suffered reasonable
fear of imminent serious bodily injury. Plaintiff reported the incident to the Mechanicsburg
Police. .
14. The police department(s) or law enforcement agencies that should be provided with a copy of the
protection order are:
MECHANICSBURG POLICE DEPARTMENT
15. There is an immediate and present danger of further abuse from the Defendant.
16. Plaintiff is asking the court to evict and exclude the Defendant from the following residence:
705 Henry Street, Mechanicsburg, PA
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Owned By:
Rosanna Marie Dulak, Plaintiff
17, FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A
TEMPORARY ORDER, and AFTER HEARlNG, 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, Evict/exclude DeHmdant from Plaintifl's residence and prohibit Defendant from
attempting to enter any temporary or permanent residence of the Plaintiff.
c, Prohibit Defendant from having any contact with Plaintiff and/or minor childlren,
either in person, by telephone, or in writing, personally or through third persons,
including but not limited to any contact at Plaintifi'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 Plaintifl's relatives and Plaintifi'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. Order Defendant to pay the costs of this action, including filing and service fees,
f Order the following additional relief; not listed above:
Order Defendant to refrain from harassing Plaintiff's relatives.
Enjoin Defendant from damaging or destroying any property owned solely by
Plaintiff.
Order Defendant to pay $250.00 to one of MidPenn Legal Services' funding
sources to pay the cost of litigating this case.
g, Grant such other relief as the court deems appropriate.
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,
~
Respectfully Submitted by:
David A. Lopez, Esq.
Agency: MidPenn Legal Services
8 Irvine Row, Carlisle, P A
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VERIFICA TION
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:
~-.- C/-CJ /
v~~~ /dd~c-J
Rornna Marie Dulak, Plaintiff
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ROSANNA MARIE DULAK,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: NO. 01-3592 CIVIL TERM
JULIE MARIE DULAK,
Defendant
; PROTECTION FROM ABUSE
ORDER FOR CONTINUANCE
AND NOW, this ~day of November, 2001, upon consideration of the attached Motion
for Continuance, the matter scheduled for hearing on November 19,2001, at 9;30 a.m. by this
Court's Order of August17, 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 December II, 2002, or until further Order of Court.
Joan Carey, Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
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ROSANNA MARIE DULAK,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
vs.
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01- 3592 CIVIL TERM
JULIE MARIE DULAK,
Defendant
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
Plaintiff, Rosanna Dulak, 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 Motion was filed and an Order for Continuance was entered on August 17,2001,
rescheduling the hearing for November 19, 2001, at 9:30 a.m.
2. The Dauphin County Sheriff s Department was unable to locate Defendant to serve
her with the Order for Continuance, Temporary Protection From Abuse Order and Petition for
Protection From Abuse. Plaintiff has no further information on Defendant's whereabouts.
3. Plaintiff requests that the above captioned matter be continued generally.
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, through December 11, 2002, or until further
Order of Court.
WHEREFORE, Plaintiff requests that the Court grant this Motion and continued generally
this matter, and thatthe Temporary Protection From Abuse Orderremain in effect for a period of18
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months from the date it was entered, through December 11, 2002, or until further Order of Court.
Respectfully submitted,
~
o Carey, Attorney for PI
MidPenn Legal Services
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
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