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HomeMy WebLinkAbout01-04582Elizabeth Ann Nunez-Feliz, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.OI- 4582 CIVIL TERM Julio A. Feliz, Defendant PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, this ~ day of August, 2001, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on the 7s' day of August, 2001, at 11:15 a.m. by this Court's Order of August 1, 2001, is hereby rescheduled for hearing on the 24`" day of September, 2001, at 11:00 a.m. in Courtroom No. 2. The Temporary Protection From Abuse Order of August 1, 2001, shall remain in effect for a period of 18 months from the date it was entered, through February 1, 2003, or until further Order of Court, whichever comes first. This Order shall be docketed in the office of the Prothonotary, but the Prothonotary shall not send a copy of this order to the Defendant by mail. By the Ca Edgar B. Bayley, Joan Carey, Attorney for Plaintiff • ~~~ /~ Elizabeth Ann Nunez-Feliz, Plaintiff vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.OI- 4582 CIVIL TERM Julio A. Feliz, Defendant PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff, Elizabeth Ann Nunez-Feliz, by and through her attorney, Joan Carey, moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: A Temporary Protection From Abuse Order was issued by this Court on August 1, 2001, scheduling a hearing for August 7, 2001, at 11:15 a.m. 2. Service of Defendant has not been accomplished. 3. 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 February 1, 2003, 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 18 months from the date it was entered, through February 1, 2003, or until further Order of Court, whichever comes first. Respectfully submitted, ~' Carey, Attorney for intiff x. Elizabeth P~rsn Nunez-Feliz, Plaintiff Julio A. Feliz, vs. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.OI-~,~ A~ CIVIL TERM 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 maybe 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 rl day of August, 2001, at ~ l: I Q .m., in Courtroom No. _~ on the 4`~ Floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. You MUST obey the Order that is attached until it is modified or terminated by the court after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six months in jail under 23 Pa.C.S. §6114. Violation may also subject you to prosecution and criminal penalfies under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. §2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you maybe subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. § 2261-2262. You should take this paper to your lawyer at once. You have the right to have a lawyer represerrt you at the hearing. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. If you cannot find a lawyer, you may have to proceed without one. CUMBERLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue, Carlisle, Pennsylvania 17013 Telephone Number: (717)249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Ctunberland County is required by law to comply with the ,.2~rlericans with Disabilities Act of I990. For information about accessible facilities and reasonable accommoda ions available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Elizabeth Ann Nunez-Feliz, Plaintiff IN TIC. COURT OF COMMON :PLEASOF :CUMBERLAND COUNTY, :PENNSYLVANIA v. Julio A. Feliz, Defendant :No. ~~-4 ~$~ CIVIL ACTION -LAW PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Julio A. Feliz Defendant's Date of Birth is: September 3,1958 Defendant's Social Security Number is: 105-76-4041 Name(s) of All protected persons, including Plaintiff and minor children: 1. Elizabeth Ann Nunez-Feliz AND NOW, on 1st Day of August, 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. 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 Plaintiffs school, business, or place of employment. 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. Defendant shall immediately relinquish any firearms license the Defendant may possess, and the following weapons to the Sheriffs Office or a designated local law enforcement agency for delivery to the Sheriffs Office. 1. Handgun (357 Magnum) Defendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration of this order. 6. The following additional relief is granted: The Cumberland County Sheriff's Department shall attempt to make service at Plaintiffs request and without pre-payment of fees, buff service may be accomplished under any applicable Rule of Civil Procedure. This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service. The Prothonotary shall not send a copy of this order to the Defendant by mail. This order can be extended beyond its original expiration date if the court finds that Defendant bas committed another act of abuse or has engaged in a pattern or practice that indicates continued risk of harm to Plaintiff. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. Defendant is ordered to refrain from harassing Plaintiffls relatives. 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Carlisle Police Department Mechanicsburg Police Department 8. The sheriff, police or other law enforcement agencies are directed to serve the Defendant with a copy of the Petition, any Order issued, and the Order for Hearing without prepayment of costs. The Petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. The Prothonotary is directed to file this Petition and Order without prepayment of costs. 9. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL FEBRUARY 1, 2003 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 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 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 plaintiff s residence OR any location where a violation of this order occurs OR where the defendant maybe located. If defendant violates Paragraphs 1 through 5 of this Order, defendant shall be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this Order maybe 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 -,~, :, arrest. Distribution to: P MidPenn Legal Services Faxed & Mailed to PSP ~ ~ f : d g d.." .,~r~..~` ~~? L,c~J. ~~~ Waa Nc~ '~re5eny-F ~c~rect ie GP, ~~ (I: 0`~ PFAD Number: WE1293906P Elizabeth Ann Nunez-Feliz, Plaintiff v. Julio A. Feliz, Defendant : IN THE COURT OF COMMON :PLEASOF :CUMBERLAND COUNTY, :PENNSYLVANIA CNIL ACTION -LAW PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE 1. Plaintiffs name is: Elizabeth Ann Nunez-Feliz 2. I, (the Plaintiff), am filing this Petition on behalf o£ - myself 3. Name(s) of ALL person(s), including minor children, who seek protection from abuse. a. Elizabeth Ann Nunez-Feliz 4. Plaintiffs Address is :102 West High Street ,Carlisle, PA 17013 5. Defendant's Name is: Julio A. Feliz 6. Defendant is believed to live at the following address: 126 Franklin Avenue , Apt. l ,Brooklyn, NY 11205 7. Defendant's Social Security Number is: 105-76-4041 8. Defendant's Date of Birth is: September 3,1958 9. Defendant's Place of employment is: Atlantis Express Transportation 10. Defendant is an adult. 11. The relationship between the Plaintiff and the Defendant is: Spouse 12. The defendant has been involved in a criminal court action. 13. The facts of the most recent incident of abuse are as follows: In or about the beginfng of July, 2001, when Plaintiff spoke to Defendant, he threatened to kill her. On or about July 14, 2001, when Plaintiff spoke to Defendant on the telephone, he told her that he would come to her residence on her birthday, August 7, and give her a present. Plaintiff understood this to be a threat to bring a gun to Carlisle and kill her which caused her to fear for her safety. 14. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor children, (including any threats, injuries, or incidents of stalking) are as follows: On or about June 8, 2001, Defendant approached Plaintiff at her residence in Carlisle, demanding that she return to Brooklyn with him or he would kill her. When Plaintiff refused, he grabbed her arm causing bruises and told her she had "better sign his green card or else" causing the Plaintiff to fear for her safety. In or about April 2001, Defendant tied Plaintiffs legs, and cuffed her hands, and sexually assaulted her causing pain and vaginal bleeding. Defendant also held and squeezed Plaintiff s shoulder causing bruising. This incident caused Plaintiff pain and reasonable fear of imminent serious bodily injury. Since approximately 1995, on several different occasions, Defendant has threatened to kill Plaintiff, slapped her, punched her, shoved her, and choked her. On one occasion in 1996, Defendant grabbed her by the hair, pulled her into a car, and grabbed her by the neck. On another occasion sometime between 1996 and 1997, Defendant forcefully slapped Plaintiff causing her to fall to the floor and punched her. In 1997, shortly after they were married, Defendant told Plaintiff that if she wasn't a good wife, he would do to her what he did to his first wife. He then went on to say that he shot his first wife's boyfriend and murdered his wife by slitting her throat. The Defendant has repeatedly told Plaintiff this from time to time during their marriage causing Plaintiff to fear for her life. He has also threatened on several occasions to shoot Plaintiff and anybody she is with causing her to fear for her safety. 15. The Defendant has used, or threatened to use, the following weapon(s) against the Plaintiff or the minor children: a. Handgun (357 Magnum) 16. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: Carlisle Police Department Mechanicsburg Police Department 17. There is an immediate and present danger of further abuse from the Defendant. 18. Plaintiff is asking the court to evict and exclude the Defendant from the following residence: 102 West High Street, Carlisle, Pennsylvania. Rented By:Plaintiff 19. 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 andor minor children in any place where Plaintiff maybe found. b. Evict/exclude Defendant from Plaintiff 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 Plaintiffand/or minor children, 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 fmd necessary with respect to partial custody and/or visitation with the minor children. d. Order Defendant to temporarily turn over weapons to the Sheriff of this County and prohibit Defendant from transferring, acquiring, or possessing any such weapons for the duration of the Order. e. Order the following additional relief, not listed above: Enjoin Defendant from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. Order Defendant to refrain from harassing Plaintiff s relatives. Order Defendant to pay the costs of this action, including filing and services fees. Order Defendant to pay $250.00 to reimburse one of MidPenn Legal Services' funding sources toward the cost of litigation in this case. f. Grant such other relief as the court deems appropriate. g. 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, Dater © ~ David Lopez Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row, Carlisle, PA 17013 (717)243-9400 or1-800-822-5288 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 lrnowledge. 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:~~ ~~t ®~ ~ ~ ~ ~ ~~ Elizab i Ann Nunez-Feliz, Plaintiff Ik."t. OS/O1/O1 WED .,II:OS~FA% 717 240 6573 CUMB CO PROTHONOTARY ~' ~ ~ I~j001 s~~ MULTI TN REPORT *m~ ~:a*xs~~~~~a~~aa~rax~**~*ra~~*~: T%/R% NO 2738 INCOMPLETE T%/R% TRANSACTION O% [ O179p2490779 PSP [ 0319p2405331 CP [ 04192438026 LS ERROR r OFFICE OF THE PRG'fHONN(YCARY CUMBERLAND GCXMI'Y COURTHGUS6 CXJE COUR`IliOUSE 5~UARE CARLISLE, PA. 17013-3387 (717) 240-6195 FAx (717) 240-6573 V IA TEI,gCOP IER TO; PA STATE POLICE - 4C~If. rROQG~'~.' M, p.,~.s. FAR q: FRCM: RE: h1ESSAGE 717-249-D779 CURTIS R. LONG PFA ORDERS ,_ NQ. OF PAGES (IN.^.I,UDING COVER SHEET) Tins Ss it~rr~ rnly fig cYe lse cf khe irdivic3.~a1 cr artity ba Htiicit is is • a,~ Rev CX!'Itd717 i«f**"~r~m tl'Idt 7S ¢iVi]e~d~ Crzlfidd'ltial. 31~ P.~F7[17t fS4f1 flierlrK,ma L[ld~l ~ Lr31. ff [le 1L~31 C~ tt1.La ft .i5 YKSt the 3n631'C99Ci IFX`Ip1~lt, ya, are tC'J~7J ratified dt3t ay di~nw~U~• ~ictrin ~tim aC cr.'~/irg c~ this 4~mutica:icn is 5(17ctiy ~Iibihed. I£ )a trd~e LeoF1~ dus ..........:~~;m ir. or»^a^ nlaFaaP R~'1 fV Lt5 Lfif~]d~?L.V k1J TL°lE~i1"Y~: dl~ C217A~1 [3L~ ~. fl ~ Ua 7: _:-r .. i ELIZABETH ANN NUNEZ-FELIZ, IN THE COURT OF COMMON PLEAS OF PLAINTIFF :CUMBERLAND COUNTY, PENNSYLVANIA V. JULIO A. FELIZ, DEFENDANT 01-4582 CIVIL TERM ORDER OF COURT AND NOW, this ?fit f--- day of September, 2001, counsel for plaintiff representing that they have been unable to effectuate service of the petition, IT IS ORDERED that the hearing scheduled this date, IS CANCELLED. The hearing is continued until 11:00 a.m., Monday, October 22, 2001. The temporary order entered on August 1, 2001, shall remain in full force and effect until further order of court. By the Court, Edgar B. Bayley, J. David Lopez, Esquire ~ „(~ For Plaintiff ~` :saa Cq• ~5~01 Elizabeth Ann Nunez-Feliz, Plaintiff vs. Julio A. Feliz, Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.OI- 4582 CIVIL TERM PROTECTION FROM ABUSE MOTION FOR CONTINUANCE Plaintiff, Elizabeth Ann Nunez-Feliz, by and through her attorney, David Lopez, moves the Cowl for an Order continuing generally the hearing in the above-captioned case on the grounds that: A Temporary Protection From Abuse Order was issued by this Court on August 1, 2001, scheduling a hearing for August 7, 2001, at 11:15 a.m. 2. On August 1Q 2001, the Judge signed an Order for Continuance and rescheduled the hearing for September 24, 2001, at 11:00 a.m. because service of Defendant was not accomplished. 3. Plaintiffrequeststhat the Temporary Protection From Abuse Order remain in effect for a period of 18 months from the date it was entered, through February 1, 2003, or until further Order of Court, whichever comes first. WHEREFORE, Plaintiff requests that the Court grant this Motion and continue this matter generally, and that the Temporary Protection From Abuse Order remain in effect for a period of 18 months from the date it was entered, through February 1, 2003, or until further Order of Court, whichever comes first. Resp ct lly sub 'tte~ David Lopez, Attorn for Plain ff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717)243-9400 ELIZABETH ANN NUNEZ-FELIZ, Plaintiff JULIO A. FELIZ, vs. Defendant 1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.Ol- 4582 CIVIL TERM PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, this ~..5~' day of October, 2001, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on September 24, 2001, at 11:15 a.m. by this Court's Order of August 10, 2001, is hereby rescheduled for hearing on February 4, 2002, at 11:00 a.m. in Coumoom No. 2 on the 4a' floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania.. The Temporary Protection From Abuse Order entered on August 1, 2001, shall remain in effect for a period of 18 months from the date it was entered, through February 1, 2003, or until further Order of Court, whichever comes first. This Order shall be docketed by the office of the Prothonotary, but the Prothonotary shall not send a copy of this order to the Defendant by m David A. Lopez, Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row, Carlisle, PA 17013 Caliph T. Mathis, Sheriff 210 Joralemon Street, Room 909 Brooklyn, New York 11201 / ~ \ ~, ~jT li' )6 - ~~-d ~ ELIZABETH ANN NUNEZ-FELIZ, Plaintiff NLIO A. FELIZ, vs. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.OI- 4582 CIVIL TERM PROTECTION FROM ABUSE BUSE MOTION FOR CONTINUANCE Plaintiff, Elizabeth Ann Nunez-Feliz, by and through her attorney, David A. Lopez, 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 enterd on August 1, 2001, scheduling a hearing for August 7, 2001, at 11:15 a.m. Service of Defendant was not accomplished. 2. A Motion was filed and an Order for Continuance was entered on August 10, 2001, rescheduling a hearing for September 24, 2001, at 11:00 a.m. Due to the tragic events which occurred at the World Trade Center on September 11, 2001, the Sheriff s Office in New York City was assigned to disaster relief and the Temporary Protection From Abuse Order in this case was not able to be served. 3. Plaintiff requests that the hearing be rescheduled to facilitate 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 February 1, 2003. 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, through February 1, 2003, or until further Order of Court, whichever comes first. Respe,2~f llysub~tte David A. Lopez, Attorr;~y for~laintiff MidPenn Legal Services 8 Irvine Row, Carlisle, PA 17013 (717)243-9400 or1-800-822-5288 .~ ~., ~--~ ,,° =g•' . S i .isii'~~ FINANCE NEW • YORK THE CITY OF NEW YORK DEPARTMENT OF FPIANCE DUE TO THE TRAGEDY AT THE WORLD TRADE CENTER ON SEPTEMBER 11~, 2001, THE SHERIFF'S OFFICE WAS 1~TOBILiZED TO AID IN THE DISASTER RELIEF. UNFORTUNATLY, WE WERE UNABLE TO SERVE YOUR PAPERS. YOUR PAPERS ARE BEING RETURNED TO YOU. IF-YOU OBTAINED A NEW COURT DATE AND WOULD LIKE THE SHERIFF'S OFFICE TO SERVE THEM, BRING THIS LETTER IN WITH 3 COPIES OF THE NEW PAPERS AND THE SHERIFF'S OFFICE WILL SERVE THEM FOR NO FEE. PLEASE CALL 718-802-3545 BEFORE COMING INTO THE OFFICE OR MAILING IN YOUR PARERS AS THE OFFICE IS STILL NOT FUNCTIONING AND WE MAY NOT BE ABLE TO SERVE YOUR PAPERS IN TIME FOR YOUR NEW COURT DATE. THANK YOU FOR YOUR UNDERSTANDING IN THIS TIME OF CRISIS. EXHIBIT A CALIPH T MATHIS • SHERIFF 210 JORALEMON STREET • ROOM 909 • BROOKLYN • NY 11201 www.nyc.gov/finance ELIZABETH ANN NUNEZ-FELIZ, Plaintiff JULIO A. FELIZ, vs. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.Ol- 4582 CIVIL TERM PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, this~~ day of February, 2002, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on February 4, 2002, at 11:00 a.m. by this Court's Order of October 24, 2001, is hereby rescheduled for hearing on March 28, 2002, at 11:00 a.m. in Courtroom No. 2 on the 4`" floor of the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania.. The Temporary Protection From Abuse Order entered on August 1, 2001, remains in effect for a period of 18 months from the date it was entered, through February 1, 2003, or until further Order of Court, whichever comes first. This Order shall be docketed by the office of the Prothonotary, but the Prothonotary shall not send a copy of this order to the Defendant by mail. Court, Edgar B. Bayley, David A. Lopez, Attorney for Plaintiff MidPenn Legal Services ~ ,h„A„¢,.~ c ~.~..- ~ /h~~s. 8 Irvine Row, Carlisle, PA 17013 /'~ Caliph T. Mathis, Sheriff New York City Sheriff's Department 210 Joralemon Street, Room 909 Brooklyn, New York 11201 ELIZABETH ANN NUNEZ-FELIZ, Plaintiff NLIO A. FELIZ, vs. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. O1- 4582 CIVIL TERM PROTECTION FROM ABUSE BUSE MOTION FOR CONTINUANCE Plaintiff, Elizabeth Ann Nunez-Feliz, by and through her attorney, David A. Lopez, 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 October 24, 2001, rescheduling a hearing for February 4, 2002, at 11:00 a.m. Defendant, whose last known address was 126 Franklin Avenue, Apt. 1, Brooklyn, New York 11205, has not yet been served with a certified copy of the Temporary Protection From Abuse Order and Petition for Protection From Abuse. 2. Plaintiff requests that the hearing be rescheduled to facilitate service of Defendant. 3. 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 February 1, 2003. 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, through February 1, 2003, or until further Order of Court, whichever comes first. Respectfully submitted, David A. Lopez, Attorney for ~lairittff MidPenn Legal Services 8 Irvine Row, Carlisle, PA 17013 (717)243-9400 or1-800-822-5288