HomeMy WebLinkAbout01-04864Loretta Lynn Sheriff,
Plaintiff
vs.
Ronald Ray Richardson, Jr.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.Ol- ~~~~ 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 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 ay of August, 2001, at
.3 ~ ~ m., in Courtroom No. ~ on the 4th Floor of the Cumberland County
Courthou e, l 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 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 Rnco. If you travel outside of
the state and intentionally violate this Order, you may be subject to federal criminal
proceedings under the Violence Against Women Act, 18 U.S.C. § 2261-2262.
You should take this paper to your lawyer at once. You have the right to have a lawyer
represent you at the hearing. The court will not, however, appoint a lawyer for you. If you do
not have a lawyer or cannot afford one, go to or telephone the office set forth below to find out
where you can get legal help. If you cannot find a lawyer, you may have to proceed without
one.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue, Carlisle, Pennsylvania 17013
Telephone Number: (717)249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the court,
please contact our office. All arrangements must be made at least 72 hours prior to any
hearing or business before the court. You must attend the scheduled conference or hearing.
Temporary Protection From Abuse Order
Loretta Lynn Sheriff,
Plaintiff
Page 1 of 3
IN THE COURT OF COMMON
PLEAS OF
CUMBERLAND COUNTY,
:PENNSYLVANIA
v.
Ronald Ray Richardson Jr.,
Defendant
CIVIL ACTION -LAW
PROTECTION FROM ABUSE
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: Ronald Ray Richardson Jr
Defendant's Date of Birth is: September 26,1968
Name(s) of All protected persons, including Plaintiff and minor children:
1. Loretta Lynn Sheriff
AND NOW, on 17th Day of August, 2001 upon consideration of the attached
Petition for Protection from Abuse, the court hereby enters the following Temporary
Order:
Plaintiffs request for a temporary protection order is granted.
1. Defendant shall not abuse, harass, stalls or threaten any of the above persons in
any place where they might be found.
2. Defendant is prohibited from having ANY CONTACT with Plaintiff, or any
other person protected under this Order, at any location, including but not limited
to any contact at Plaintiff s school, business, or place of employment. Defendant
is specifically ordered to stay away from the following locations for the duration
of this order.
Plaintiff's current residence located at 204 Firehouse Road, Shippensburg,
Pennsylvania, and any future residence she may establish.
Plaintiff's current place of employment at H and H, 730 E. King Street,
Shippensburg, Pennsylvania, and any future places of employment.
Plaintiff s current place of employment at H and H, 730 E. King Street,
Shippensburg, Pennsylvania, and any future places of employment. '
3. The following additional relief is granted:
The Cumberland County Sheriffs Department shall attempt to make service
at Plaintiffs request and without pre-payment of fees, but 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 has 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 Plaintiffs relatives.
4. A certified copy of this Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
Pennsylvania State Police Department
5. 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.
6. THIS ORDER APPLIES IIvIMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL FEBRUARY 17, 2003 OR UNTIL OTHERWISE
MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND
HEARING.
NOTICE TO THE DEFENDANT
Temporary Protection From Abuse Order
Page 3 of 3
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 plaintiffs
residence OR any location where a violation of this order occurs OR where the
defendant maybe located. If defendant violates Paragraphs 1 through 2 of this
Order, defendant shall be arrested on the chazge 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
threatened to be used during the violation of this Order OR during prior incidents of
abuse. Weapons must forthwith be delivered to the Sheriffs office of the county
which issued this Order, which office shall maintain possession of the weapons until
further Order of this court, unless the weapons are evidence of a crime, in which
case, they shall remain with the law enforcement agency whose officer made the
arrest.
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Distribution to:
MidPenn Legal Services
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Loretta Lynn Sheriff,
Plaintiff
PFAD Number: KJl'31496cU
IN THE COURT OF COMMON
:PLEASOF
CUMBERLAND COUNTY,
PENNSYLVANIA
v.
Ronald Ray Richardson Jr.,
Defendant
CIVIL ACTION -LAW
PROTECTION FROM ABUSE
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiffs name is:
Loretta Lynn Sheriff
2. I, (the Plaintiff), am filing this Petition on behalf of
- myself
3. Name(s) of ALL person(s), including minor children, who seek protection from
abuse.
a. Loretta Lynn Sheriff
4. Plaintiffs Address is :204 Firehouse Road ,Shippensburg, PA 17257
5. Defendant's Name is:
Ronald Ray Richardson Jr
6. Defendant is believed to live at the following address:
20 Spring Street ,Shippensburg, PA 17257
7. Defendant's Date of Birth is:
September 26,1968
8. Defendant's Place of employmenbis:
ChemDry Carpet, Road Way Trucking
9. Defendant is an adult.
10. The relationship between the Plaintiff and the Defendant is:
Current or former sexual/intimate partner
11. The defendant has been involved in a criminal court action.
12. The defendant is currently on probation /parole.
13. The defendant is currently on County probation !parole.
Description: Franklin County
14. The following other minor children presently live with Plaintiff:
a. Kerstin Nichole Sheriff
Age: 4
The Plaintiffs relationship to this child is:
mother
15. The facts of the most recent incident of abuse aze as follows:
On or about August 12, 2001, Defendant repeatedly drove past PlaintifFs
residence causing her to fear for her safety. Plaintiff called the Pennsylvania
State Police in Carlisle and reported the incidents. Pennsylvania State Police
later arrested Defendant for simple assault and harassment and placed in
Franklin County Prison.
16. Prior incidents of abuse that the Defendant has committed against Plaintiff or the
minor children, (including any threats, injuries, or incidents of stalking) aze as
follows:
On several occasions between July 18, 2001, and August 12, 2001, Defendant
stalked Plaintiff in ways including, but not limited to, repeatedly waiting
outside her place of employment then following her home, waiting on different
roads along the way to Plaintiffs residence then following her, lurking outside
her residence, following her to the bank, and repeatedly calling her on the cell
_~~~~-~
phone.
On or about July 18, 2001, while Plaintiff was getting out of her car, Defendant
squeezed and pulled at PlaintifFs arm causing a bruise. When Plaintiff
resisted, Defendant grabbed her, choked her, and slammed her onto the
ground causing PlaintifFs head to hit the ground.
17. The police department(s) or law enforcement agencies that should be provided with
a copy of the protection order are:
Pennsylvania State Police Department
18. There is an immediate and present danger of further abuse from the Defendant.
19. FOR THE REASONS SET FORTH AEOVE, 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 children in any place where
Plaintiff may be found.
b. Evict/exclude Defendant from Plaintiffs 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 children, either in person, by telephone, or in writing,
personally or through third persons, including but not limited to
any contact at Plaintiff s school, business, or place of
employment, except as the court may find necessary with respect
to partial custody and/or visitation with the minor children.
d. 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.
e. Grant such other relief cis the court deems appropriate.
£ 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,
Date: ~ ~
oan Carey
Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row, Carlisle, PA 17013
(717)243-9400
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: l~ J~ C~ ~ ~ h-~' "`~~ ~~~
Loretta Lynn Sheriff, Plaintiff
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OFFICE OF TfiE pR0'['kiGNDTARY
CUMBERLAND COUNTY CbUR'iHCUSE
CNE O~CfRTHWSE SQUARE
CARLISLE. PA. 17013-3387
(717) 240-6195
F,qx (717) 240-b573
V I A T E L E C 0 P I E R
~; PA STATE POLICE. - `EYf• PROCC.s~. ~ M. ~'. ~.S
FAX q: 717-249-0779 •
FRCM: CURTIS R. LONG
RE: PFA ORDERS
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Loretta Lynn Sheriff,
Plaintiff
IN THE COURT OF COMMON
:PLEASOF
CUMBERLAND COUNTY,
;PENNSYLVANIA
v.
Ronald Ray Richardson Jr.,
Defendant
No. 01-4864
CIVIL ACTION -LAW
PROTECTION FROM ABUSE
CONTINUED TEMPORARY ORDER
AND NOW, this 23rd Day of August, 2001, pursuant to 23 Pa.C.S. §6107(c),
the terms and conditions of the Temporary Order issued on 17th Day of August,
2001, in the above-captioned case are hereby continued in full force and effect .
This order is in effect until February 17, 2003.
Upon consideration of the attached Motion for Continuance, the matter is
hereby continued generally.
This Order is entered without prejudice to either party to request a hearing.
Distribution To:
MidPenn Legal Services
Attorneys for Plaintiff
Paul Bradford Orr
Attorney for Defendant
_50 E. High Street
Carlisle, PA 17013
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Loretta Lynn Sheriff, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
v.
Ronald Ray Richardson, Jr.,
Defendant
CUMBERLAND COUNTY, PENNSYLVANIA
NO.O1-4864 CIVIL TERM
PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
Plaintiff, Loretta Lynn Sheriff, by and through her attorney, David Lopez, moves the
Court 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
17, 2001, scheduling a hearing for August 22, 2001, at 3:00 p.m.
2. The Cumberland County Sheriff s Department served Defendant with a certified
copy of the Temporary Protection From Abuse Order and Petition for Protection From Abuse on
August 20, 2001.
Defendant has retained Paul Bradford Orr to represent him in the matter.
4. The parties agree, by and through their respective counsel, that the hearing be
continued generally pending further Order in this matter to afford them time to execute a
consent agreement.
5. 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 17, 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 17, 2003, or until further
Order of Court, whichever comes first.
Res ctfully s}ilarnitta
.o
avid Lopez, Attorn for lain '
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717)243-9400
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Loretta Lynn Sheriff,
Plaintiff
IN THE COURT OF COMMON
PLEAS OF
:CUMBERLAND COUNTY,
: PENNSYLVANIA
v.
Ronald Ray Richardson 7r.,
Defendant
No: 01-4864
CIVIL ACTION -LAW
PROTECTION FROM ABUSE
CONTINUED TEMPORARY ORDER
AND NOW, this 23rd Day of August, 2001, pursuant to 23 Pa.C.S. §6107(c),
the terms and conditions of the Temporary Order issued on 17th Day of August,
2001, in the above-captioned case are hereby continued in full force and effect .
This order is in effect until February 17, 2003.
Upon consideration of the attached Motion for Continuance, the matter is
hereby continued generally.
This Order is entered without prejudice to either party to request a hearing.
BY THE COURT:
Distribution To:
MidPenn Legal Services
Attorneys for Plaintiff
Paul Bradford Orr
Attorney for Defendant
50 E. High Stteet -'~ ~~ ~ ~`~'~ ~' ~~~ RECD
Carlisle, PA 17013 Dm ?"est. ny whereof I her o set
aa~d t eal o'f/said ou~ at C lisle,/
Faxed & Mailed to PSP I'hi. _. _ .2r df - _ _ /Lpl .
Loretta Lynn Sheriff,
Plaintiff
v.
Ronald Ray Richardson, Jr.,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO.OI-4864 CIVIL TERM
PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
Plaintiff, Loretta Lynn Sheriff, by and through her attorney, David Lopez, moves the
Court for an Order continuing generally the hearing in the above-captioned case on the grounds
that:
1. A Temporary Protection From Abuse Order was issued by this Court on August
17, 2001, scheduling a hearing for August 22, 2001, at 3:00 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 on
August 20, 2001.
3. Defendant has retained Paul Bradford Orr to represent him in the matter.
4. The parties agree, by and through their respective counsel, that the hearing be
continued generally pending further Order in this matter to afford them time to execute a
consent agreement.
5. 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 17, 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 17, 2003, or until further
Order of Court, whichever comes first.
Res tfully s n9itte
avid Lopez, Attorn for lain '
Midl'enn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717)243-9400
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-04864 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
FF LORETTY LYNN
VS
RICHARDSON RICHARD RAY
TREVOR KENT Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE was served upon
RICHARDSON RONALD RAY JR the
DEFENDANT at Q013:15 HOURS, on the 20th day of August 2001
at CUMBERLAND COUNTY PRISON 1 COURTHOUSE SQUARE
CARLISLE, PA 17013 by handing to
RONALD R. RICHARDSON, JR
a true and attested copy of PROTECTION FROM ABUSE together with
NOTICE OF HEARING & ORDER, TEMP PFA, PETITION
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
3.25
.00
10.00 R. Thomas Kline
. 0 0 ~-
31.25 08/20/2001
Sworn and Subscribed to before
me this ,~jp ~ day of
~..~,., 'Jtrvl A.D.
~~~.,t,~ a. >~~.,
o honotary
By: ''7
/'-'i~tfv~2
Deputy Sheriff