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Home My WebLink About01-04679IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF PENNA. '~ Jennifer A. Dell, ~`., .= Plaintiff VERSUS Jdm R. Dell, Defendant N O. 01-4679 DECREE IN DIVORCE AND NOW, VGG~Ng ~G.J (p ZQd IT IS ORDERED AND DECREED THAT AND Jennifer A. Dell Jd1n R. Dell ARE DIVORCED FROM THE BONDS OF MATRIMONY. PLAINTIFF, DEFENDANT, THE COURT RETAINS JURISDICTION OF THE FOLLOWING CLAIMS WHICH HAVE BEEN RAISED OF RECORD IN THIS ACTION FOR WHICH A FINAL ORDER HAS NOT YET BEEN ENTERED; None. BY THE COURT: PROTHONOTARY JENNIFER A. DELL, Plaintiff v. JOHN R. DELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN DIVORCE NO. 01-4679 CIVIL TERM PRAECIPE TO TRANSMIT RECORD To the Prothonotary: Transmit the record, together with the following information, to the court for entry of a divorce decree: Ground for divorce: irretrievable breakdown under §3301(c) of the Divorce Code. 2. Date and manner of service of the complaint: U.S. Mail, certified no. 7099 3400 0018 4996 9442, restricted delivery, return receipt requested on August 16, 2001. 3. Date of execution of the affidavit of consent required by §3301(c) of the Divorce code: by plaintiff on November 21, 2001; by defendant on November 21, 2001. 4. Related claims pending: none. 5. Date plaintiff s Waiver of Notice was filed with the prothonotary: December 3, 2001. Date defendant's Waiver of Notice was filed with the prothonotary: December 3, 2001. Date: December 3, 2001 i ~~ ~V ~ ~ ichelle L. An erso Certified Legal Intern for Plaintiff TH S M.PLACE ROBERT E. RAINS TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 C7 u t_ _._ ~-, n7 ~°: _ - ;- r" C: _ '~''_ e ~~ i °J ~ .. _Lfj -C ..r, CEO ~:~ -C .:. una.~a'.WaceFw .. w>a~.n-:e't-T v .: ,,:~. =-~nxxc'sa& a~t;~!r..c --.-,.,~: _. _~~+-~,~caxgrv~w~{5„: •d A~,L~ ~ Y . pUG 0 8 2007,,,~R JENNIFER A. DELL, : IN THE COURT OF COMMON PLEAS OF ~ y Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION -LAW IN CUSTODY JOHN R. DELL, ,,! G Defendant : NO. Ol- `~7 / CIVIL TERM CUSTODY AGREEMENT AND ORDER rd THIS AGREEMENT, made this 'Z,~J' day of SfJu~, 2001, between Jennifer A. Dell, hereinafter Mother, and John R. Dell, hereinafter Father, concerns the custody of their child, Jessica Robin Dell, born August 23, 1998. Mother and Father desire to enter into an agreement as to the custody of their child. Mother and Father agree to the following: 1. Mother and Father shall share legal custody of Jessica. 2. Mother shall have primary physical custody of Jessica. 3. Father shall have partial physical custody of Jessica as follows: a. Father shall have physical custody of Jessica every other weekend, beginning July 2~ , 2001, from Friday at 6 p.m. until Sunday at 6 p.rn.. b. Father shall have physical custody of Jessica every Tuesday and Wednesday evening, beginning July 3~ , 2001, from 4:00 p.m. until 8:00 p.m.. c. Holidays. The holiday schedule shall supersede the normal custodial schedule. 1 J ~ 1) Beginning Labor Day, September 3, 2001, Mother and Father shall aitemate custody of Jessica on the following holidays: Memorial Day, Fourth of July, and Labor Day. The times for the holidays in this paragraph shall be from 9:00 a.m. unti17:00 p.m.. 2) Thanksgiving. Mother and Father shall alternate custody of Jessica on Thanksgiving Day from 9:00 a.m. unti17:00 p.m.. In odd numbered years, Father shall have custody of Jessica on Thanksgiving Day, in even numbered years, Mother shall have custody of Jessica on Thanksgiving Day. 3) Christmas. Mother and Father shall alternate custody of Jessica on Christmas as follows: The Christmas holiday will be divided into two time periods each yeaz. Period "A" will be December 24"' at noon until. December 25t'` at noon. Period "B" will be December 25~` at noon until December 26~' at noon. In odd numbered years, Mother will have custody of Jessica during Period B, and Father will have custody during Period A. In even numbered years, Mother will have custody of Jessica during Period A, and Father will have custody during Period $. 4) Easter. The Easter holiday will be divided into two time periods each year. Period "A" will be Easter Sunday from 8:00 a.m. unti12:00 p.m.. r. ~ Period "B" will be Easter Sunday from 2:00 p.m. unti18:00 p.m.. Mother shall have custody of Jessica during Period A, and Father shall have custody of Jessica during Period B. 5) Mother shall have custody of Jessica each Mother's Day beginning at 9:00 a.m., and Father shall have custody of Jessica each Father's Day from 9:00 a.m unti16:00 p.m.. d. All other times as agreed by the parties. 4. Mother and Father shall be entitled to reasonable telephone access with the child while the child is in the other's custody. 5. Mother and Father shall notify the other of all medical care the child receives while in that parent's care. Mother and Father will notify the other immediately of medical emergencies which arise while the child is in that parent's care. 6. Neither parent will do anything which may estrange the child from the other party, or injure the opinion of the child as to the other pazent or which may hamper the free and natural development of the child's love and respect for the other parent. 7. Custodial exchanges shall occur in the parking lot of the Kentucky Fried Chicken restaurant on Hanover Street in Carlisle. q AY 8. The parties intend to be bound by the terms of this Agreement and intend for this Agreement to be made an Order of Court. 7o R. Dell, Defendant ~' / 1 ~/ v Hubert X. Gi y, Esquire Eroujos & Troy, P.C. 4 North H over Street Carlisle, PA 17013 TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Cazlisle, PA 17013 717-243-2968 ORDER AND NOW this ~~ day of A.. .. _, 2001, the above Custody Agreement is approved and entered as an Order of Crnirt. o 'ferA. De aintiff ~~~L(1~E's------' 'chelle L. Anderso ' Certified Legal Intem O 5 M. PLACE ROBERT E. RAINS ~A O~ ~~. c> O l ~ ,=, ~ '-'_ ~-, C7 C" t. ~~+ ~ ~~ f `', ~~~ =! •~ ~ ~J ~ i\F ,V -<: ~1N~ fr1~SNN3d A.'~~n~'~~, ..:, ,~a~~~~n~ uG ~Z ':v 6- Jill! ?~ ~° JENNIFER A. DELL, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION -LAW IN DIVORCE AND CUSTODY JOHN R. DELL, Defendant : NO. 2001- ~rio~~jCIVIL TERM NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary, Cumberland County Courthouse, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 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. CUMBBRLAND COUNTY BAR ASSOCIATION 2 Liberty Avenue Carlisle, PA 17013 717-249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. JENNIFER A. DELL, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE AND CUSTODY JOHN R. DELL, Defendant : NO. 2001- y(e79 CIVIL TERM DIVORCE COMPLAINT WITH CUSTODY COUNT The plaintiff, Jennifer A. Dell, by her attorneys, the Family Law Clinic, sets forth the following cause of action in divorce and custody: COUNTI DIVORCE UNDER 23 Pa.C.S. §§3301(c) AND 3301(d) OF THE DIVORCE CODE Plaintiff is Jennifer A. Dell, whose current residence is confidential. 2. Defendant is John R. Dell, who currently resides at 7073 Carlisle Pike, Lot 154, Carlisle, Cumberland County, Pennsylvania, since 1995. Plaintiff has been a bona fide resident in the Commonwealth for at least six months immediately previous to the filing of this complaint. 4. The plaintiff and defendant were married in the Summer of 1995 in Virginia. 5. Plaintiff and defendant have lived separate and apart since June 16, 2001. 6. There have been no prior actions for divorce or for annulment between the parties. 7. The marriage is irretrievably broken. 8. Plaintiff has been advised that counseling is available and that plaintiff may have the right to request that the court require the parties to participate in counseling. WHEREFORE, Plaintiff requests the court to enter a decree of divorce. '-, couNTia CUSTODY 9. Plaintiff repeats and realleges paragraphs 1 through 8. 10. Plaintiff seeks custody of the following child: Name Present Residence Age Jessica Robin Dell The child was not born out of wedlock. The child is presently in the custody of Jennifer A. Dell, whose current residence is confidential. Confidential 2 years, 11 months (August 23, 1998) During the past five years, the child has resided with the following persons and at the following addresses: Persons Address Dates Jennifer A. Dell Jennifer A. Dell, John R. Dell, Linda Dell (Grandmother) Confidential 7073 Carlisle Pike Lot 154 Carlisle, PA 17013 June 17, 2001 to present August 23, 1998 until June 16, 2001 The mother of the child is Jennifer A. Dell. She is married. The father of the child is John R. Dell. He is married. 11. The relationship of the defendant to the child is that of father. The defendant resides with the following persons: Name Relationship Linda Dell Mother 12. The relationship of plaintiff to the child is that of mother. The plaintiff currently resides with the following persons: Confidential 13. Plaintiff has participated as a party in other litigation concerning the custody of the child in this Court. Plaintiff filed a Petition for Protection from Abuse against Defendant on June 25, 2001 (Cumberland County Court of Common Pleas Docket No. OI-3867). On June 26, 2001, The Honorable Edgar B. Bayley issued a Temporary Protection from Abuse Order, which included a provision for custody. The parties signed a Final Consent Order, made an Order of Court on July 25, 2001, which also includes a custody provision. A copy of the Final Order is attached hereto as Exhibit A. The teams in the Final PFA Order are consistent with the Custody Agreement and Order, which is signed by the parties and attached to this Complaint. Plaintiff has no other information of a custody proceeding concerning the child pending in a court of this Commonwealth, or any other state. Plaintiff does not know of a person not a party to the proceedings who has physical custody of the child or claims to have custody or visitation rights with respect to the child. 14. The best interest and permanent welfare of the child will be served by granting the relief requested because: a) Plaintiff is the primary caretaker of the child; b) Plaintiff provides the child with adequate moral, emotional, and physical surroundings as required to meet the child's needs; c) Plaintiff has permitted and encouraged continuing contact between Defendant and the child and will continue to do so; d) Plaintiff is willing to accept custody of the child; e) Plaintiff continues to perform the parental duties and enjoys the love and affection of the child. f) Plaintiff and Defendant have signed a Custody Agreement and Order, which is attached to this Complaint. 15. Each parent whose parental rights to the child have not been terminated and the person who has physical custody of the child have been named as parties to this action. WHEREFORE, plaintiff requests the court to grant her shared legal custody and primary physical custody of the child and enter an Order in the form of the signed agreement attached hereto. Date ~Ll.CO Respectfully submitted, ~ ~~~~ i Michelle L. Anders Certified Legal Intem L TH S M.PLACE ROBERT E. RAINS TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 VERIFICATION I verify that the statements made in this Complaint are true and correct. I understand that false statements herein aze made subject to the penalties of 18 Pa. C.S. §4904, relating to unsworn falsification to authorities. Date: ~~- ~ ~ ht o J rifer A. D 1, laintiff JENNIFER A. DELL, Plaintiff v. JOHN R. DELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN DIVORCE AND CUSTODY NO. O1- ~((Q7 q CIVIL TERM PRAECIPE TO PROCEED IN FORMA PAUPERIS To the Prothonotary: Kindly allow Jennifer A. Dell, Plaintiff, to proceed in forma pauperis. I, Michelle L. Anderson, Certified Legal Intern in the Family Law Clinic, for the party proceeding in forma pauperis, certify that I believe the party is unable to pay the costs and that I am providing free legal service to the party. Date: _~_ ichelle L. Andais n Ce Tied Legal Intern L___ ~~ R RT E. RAINS THOMAS M. PLACE TERI L. HENNING Supervising Attorneys THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717)243-2968 ~'} ~_ `_' ~~ „T y ~ ~,, ~ ~~ < < ~ ~~ -~ ~ ~~; ~r _ v , o '~-~ . ~: n, ~- ~- ...n Postage $ Q ~ Certified Fee ~T 2 ~ , V Return Receipt Fee ~ b7 (Endorsement Requiretl) A ~ D p Restrictetl Delivery Fee ~ (Endorsement Requiretl) , 2 ~ Total Pasfage & Fees ' } $ T, Q m rt Clearg P legs e y ry (toi Feclp le pt's ya ~ t/ ', Y lV4 ll \NI ` ~ y/p lz y ~ n / ~ / ~ ~~ ~ U ~ S~ ~ , _~S'r! YI I `-? .. l' LC o . ~ . . c. cafe, r ^ Complete ifema 1; 2, a0tl 3. AIaO COmplBte item 4 if Restricted Delivery is desired. ^ Print your name and address on the reverse - so that we can return the catd to you. ^ Attach this card to the back of the mailpiece, or on the front if space permits. 1. Article Atldressed to: Jdhr1 R. l~.e-t ~~'~ ~rifsie, ~t k2. Lo+ l ~L{ '(y~rl~Sle ,~ 1813 2. ~ ~I M~ III ~ • ~ I I ~~ fll ~I - ~ - A Received ~tiy (Please Pririt Clearty) B. Date of Delivery C. Si~99n/av~ture n X VH K ~~ ^ Agent '.. M, r ^ Addressee ' D. I elivery address different from gem t? ~ yes If ES, enter delivery address below: ^ No _..-:~. ;Mail Receipt for Memhandise PS Focrn 3811; July 1999 Domestic ReturnABipt ~, tgzsassaMmes ' id JENNIFER A. DELL, : IN THE COURT OF COMMON PLEA5 OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v, :CIVIL ACTION -LAW IN DIVORCE AND CUSTODY JOHN R. DELL, Defendant : NO. 01-4679 CIVIL TERM PROOF OF SERVICE Understanding that the making of any false statement would subject her to the penalties of 18 Pa. C.S. §4904 (relating to unswom falsification to authorities), the undersigned verifies that Michelle L. Anderson mailed a true copy of the Divorce Complaint with Custody Count on the Defendant by placing the same in the U.S. Mail, certified no. 7099 3400 0018 4996 9442, restricted delivery, return receipt requested, postage prepaid, on the 7~ day of August, 2001 addressed as follows: John R. Dell 7073 Cazlisle Pike, Lot 154 Carlisle, PA 17013 Sender's receipt no. 7099 3400 0018 4996 9442 is attached hereto and incorporated by reference. On or about the 17'" day of August, 2001, green return receipt no. 7099 3400 0018 4996 9442 was delivered to the Family Law Clinic, bearing the signature John R. Dell and showing a date of service of August 16, 2001. The return receipt is attached hereto and incorporated by reference. z~ Date 'chelle L. An rson Certified Legal Intern FAMILY LAW CLINIC 45 N. Pitt St. Cazlisle, PA 17013 717-243-2968 -Fl ~ CU ~~ ~f'~l Z r- ; ~~ ~-~; Y; t? ~..~ - _ :a <r, ~? JENNIFER A. DELL, Plaintiff v. JOHN R. DELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN DIVORCE NO. 01-4679 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REOUE5T ENTRY OF A DIVORCE DECREE UNDER§3301(c) AND §3301 d2 OF THE DIVORCE CODE I consent to the entry of a fmal decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: ~~/ ', ~l 1~/ ~ 'fer A 11, Plaintiff c'? ~ i 1 C -- -. ~ l.. ~Ta y r ;-', F __ a ~t'~" ~ r: W _ },. ~' cs fJ yl -Y'I ~L, C >tn : 4 .t { ~,~^~M1 ~~~ ~^ - n~+°~- ~ Pn, k., ,.."n .~ _'La3?' a}~4ea FPS-?~i ~S ~ .. JENNIFER A. DELL, IN THE COURT OF COMMON PLEA5 OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE JOHN R. DELL, Defendant : N0. 01-4679 CIVIL TERM AFFIDAVIT OF CONSENT 1. A complaint in divorce under §3301(c) of the Divorce Code was filed on August 6, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities. Date: I/'~/" O1 ~. J n R. Dell, Defendant ~, ,~-, , , __ - ~ ' o f- i !N ~i. ~ ~~~-~ ~~' ~-~ jTl ~~- .. '^ 6~ ~iY ._m2n .. _. ._ M 9'YJnt uws-..-w- ,>5M#~r+~s•~s2k~~.mw~lni~rea~'!~A~RF»~ JENNIFER A. DELL, Plaintiff v. JOHN R. DELL, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW IN DIVORCE NO. 01-4679 CIVIL TERM WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER §3301(cLNI §33010 OF THE DIVORCE CODE I consent to the entry of a fmal decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: ~ ~ ~ ~ ~ ' Q ( rw Jo R. Dell, De endant ..~ n ~~ ~- -- ~ _. ~,~ ~ , N ._. ~ ~ ~ o i CfJ _ °~ .- w _ .r !~ ~ _ , ~ - C - `-_{ _ r.. -~ ` sD JENNIFER A. DELL, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE JOHN R. DELL, Defendant NO. 01-4679 CIVIL TERM AFFIDAVIT OF CONSENT A complaint in divorce under §3301(c) of the Divorce Cade was filed on August 6, 2001. 2. The marriage of plaintiff and defendant is irretrievably broken and ninety days have elapsed from the date of filing and service of the Complaint. 3. I consent to the entry of a final decree of divorce after service of notice of intention to request entry of the decree. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Date: ~~- ~~- (~ ~ ~ w Je rifer A. e 1, Plaintiff C~ ra C_: _ ..._ :- .. ..~4" n-~~ = -~ ~ w . , -_ _ c4 a° - : ~ . :~ i_ o ~ _- y~ ..~ _ _ r '4 € n r -~7 k' TENNIFER A. DELL, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. JOHN R. DELL, Defendant CIVIL ACTION -LAW PROTECTION FROM ABU5E N0. 2001- 3867 FINAL ORDER OF COURT Defendant's Name: John R. Dell Defendant's Date of Birth: December 25, 1969 Defendant's Social Security Number: Unknown CNIL TERM Names of All Protected Persons, including Plaintiff and minor children: Jennifer A. Dell AND NOW, this ~~ day of July, 2001, the Court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows: Pursuant to the consent of the parties, which does not constitute Defendant's admission to the averments of abuse in the petition, the following Order will be entered: Plaintiff's request for a final protection order is granted. Defendant shall not abuse, stalk, harass, or threaten the Plaintiff or any other protected person in any place where they might be found. 2. Except for such contact with or regarding the minor child as maybe permitted under paragraph 4 of this Order, Defendant is prohibited from having ANY CONTACT with Plaintiff, or any other person under this Order, at any Location, including, but not limited to, any contact at Plaintiff's school, business, or place of employment. Except for such contact with or regarding the minor child as may be petmitted under paragraph 4 of this Order, Defendant shall not contact Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 4. Defendant is permitted to contact Plaintiff for the limited purpose of custody and child related issues. Pending conciliation or agreement of the parties, Plaintiff and Defendant shall share legal custody of their minor daughter. Plaintiff shall have primary physical F~IIBIT nAn .,,.a 4 custody of the child, and Defendant shall have partial physical custody as follows: a. Alternating weekends from Friday at 6:00 p.m. until Sunday at 6:00 p.m., to begin on (,l~ 21 2dO1. b. Tuesday and Wednesday evenings from 4:00 p. m. until 8:00 p.m.. c. Other times as agreed upon by the parties. d. Custodial exchanges shall occur in the parking lot of the Kentucky Fried Chicken restaurant on Hanover Street in Cazlisle. 5. All fees and costs are waived. 6. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Middlesex Police Department Carlisle Police Department Pennsylvania State Police THIS ORDER SUPERCEDES [X] ANY PRIOR PFA ORDER AND [X] ANY PRIOR ORDER RELATING TO CHILD CUSTODY. All provisions of this order shall expire in eighteen months, on ~~' ~~ .-~~ NOTICE TO THE DEFENDANT VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF UP TO $1000.00 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 12 Pa.C.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.5. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. §2265. II+ YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAYBE SUBJECT TO FEDERAL CRIMINAL PROCEEDTSTGS UNDER THAT ACT: 18 U.S.C. §§2251-2262. IF PARAGRAPH 12 OF THIS ORDER HAS BEEN CHECKED, YOU MAYBE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE ~BRADY" PROVISIONS OF THE GUN CONTROL ACT, 18 U.S.C. §922(G), FOR POSSESSION, TRANSPORT OR RECEH'T OF FIREARMS OR AMMUNITION. ,a.~ NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who havejurisdiction over the plaintiff's residence OR any location where a violation of this Order occurs OR where the defendant may be located. If defendant violated Paragraphs 1 through 3 of this Order an arrest may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence of law enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriff'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 weapons are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. n /`BY T COURT Date ~~ 2 O ~ {-~ The norable Edgar B. This Order is entered pursuant to the consent of Plaintiff and Defendant: ~ ~P_ It~ nifer A 11, Plaintiff Mic~~Ander on Certified Legal Intern for Plaintiff ~1 J n R. Dell, Defendan ~.. , T MAS M. PLACE ROBERT E. RAINS TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 b~ Hubert X. ~Iroy Broujos Gilroy, P.C. 4 Nort Hanover Street Carlisle, PA 17013 717-243-4574 TRUE t;~P'~ I=RC?1,~ RE~'~'~~n In Testimony whereof, ~f here urlo set my hand and t seal of said ~rt•at Car is;e, Pa.. xvnwacrp JENNIFER A. DELL, IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA v. :CIVIL ACTION -LAW IN DIVORCE JOHN R. DELL, Defendant NO. 01-4679 CIVIL TERM CERTIFICATE OF SERVICE I, Michelle L. Anderson, hereby certify that I am serving a true and correct copy of Plaintiffl s Affidavit of Consent, Plaintiff s Waiver of Notice of Intention to Request Entry of a Divorce Decree Under §3301(c) of the Divorce Code, Defendant's Affidavit of Consent, Defendant's Waiver of Notice of Intention to Request Entry of a Divorce Decree Under §3301(c) of the Divorce Code, the Vital Statistics Form, and the Praecipe to Transmit Record, on the following person, the Defendant, by depositing copies of the same in the U.S. mail, postage prepaid, this 3`d day of December, 2001: John R. Dell 7073 Carlisle Pike, Lot 154 Carlisle, PA 17013 ~- Michelle L. An on ~~~~~ Certified Legal Intem FAMILY LAW CLIlVIC 45 North Pitt Street Carlisle, PA 17013 717-243-2968 ~~,.~,~ <-; r~ ~-~ C~ -- 'T7 c,` u} = C__ r ~% - ~ ti C' r'? T : ._-. _~~ . ~~ .. _ ~. -.J a ~> -. i .arm asge;~-n^a tie i rns~ 7,N~_ ". ., s€%sNg9i