HomeMy WebLinkAbout01-05193Danielle Lynn Fithian, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
ol- S193 CIVIL TERM
Walter Christopher Jane,
Defendant :PROTECTION FROM ABUSE AND CUSTODY
NOTICE OF HEARING AND ORDER
ypU 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 SCHEDU ED ON ~~,~'ZlID1,AT
~/ ~ / J`y ~.M., IN COURTROOM NO. ~OF THE CUMBERLAND
COUNTY COURTHOUSE, 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 j ail under 23 Pa.C.5. §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.
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
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
hearine or business before the court. You must attend the scheduled conference or hearing.
t ~i~~.
~'~ I
]~'f '-,'
Danielle Lynn Fithian
Plaintiff
v.
IN THE COURT OF COMMON
PLEAS OF
:CUMBERLAND COUNTY,
;PENNSYLVANIA
:No. o~-s1R3
Walter Christopher Jane
Defendant
CIVIL ACTION -LAW
PROTECTION FROM ABUSE
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: Walter Christopher Jane
Defendant's Date of Birth is: April 26,1975
Defendant's Social Security Number is: 192-54-5476
Name(s) of All protected persons, including Plaintiff and minor children:
1. Danielle Lynn Fithian
AND NOW, on 31st 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, stalk or threaten any of the above persons in
any place where they might be found.
2. Except for such contact with the minor children as maybe permitted under
paragraph 4 of this Order, 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.
3. Except for such contact with the minor children as maybe permitted 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. Pending the outcome of the final hearing in this matter, Plaintiff is awarded
temporary custody of the following minor children:
1. Christian Michael Jane, born on July 8, 2001
Until the final hearing, all contact between Defendant and the children shall be
limited to the following:
Plaintiff shall have temporary primary physical custody of the minor child.
Defendant shall not have contact with the minor child until further Order of
Court.
Upon service of the Temporary Protection From Abuse Order and Petition
by law enforcement, Defendant shall return child to Plaintiff pending further
Order of Court.
The local law enforcement agency in the jurisdiction where the children are
located shall ensure that the children are placed in the care and control of the
Plaintiff in accordance with the terms of this Order.
5. The following additional relief is granted:
-Defendant shall not harass Plaintiff s relatives.
-Defendant shall-not damage or destroy any property owned jointly by the
parties or 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:
Pennsylvania State Police of Carlisle
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.
8. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL MARCH 3, 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 4 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
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.
BY TH COiJ
~ -- .~QT
CVY N S ~ udge
~v~ 3t ~ha_I
Date
Distribution to:
MidPenn Legal Services
Faxed & Mailed to PSP
~,.,ewT. ~.,uc+~. '
~~`°
:.,.-..
~.
r
PFAD Number: EK1325088W
Danielle Lynn Fithian
Plaintiff
v.
IN THE COURT OF COMMON
:PLEAS OF
:CUMBERLAND COUNTY,
:PENNSYLVANIA
No. a~- ,~r93 7~-
Walter Christopher Jane
Defendant
CIVIL ACTION -LAW
PROTECTION FROM ABUSE
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiffs name is:
Danielle Lynn Fithian
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. Danielle Lynn Fithian
4. Plaintiffs Address is :207 Plaza Drive ,Boiling Springs, PA 17007
5. Defendant's Name is:
Walter Christopher Jane
6. Defendant is believed to live at the following address:
1519 Bensalem Blvd. ,Bensalem, PA 19020
7. Defendant's Social Security Number is:
192-54-5476
8. Defendant's Date of Birth is:
Apri126,1975
9. Defendant's Place of employment is:
Charles Oldsmobile, Bristol, Pennsylvania
10. Defendant is an adult.
11. The relationship between the Plaintiff and the Defendant is:
Current or former sexuaUintimate partner
12. The defendant has been involved in a criminal court action.
13. The defendant is currently on probation /parole.
14. The defendant is currently on County probation /parole.
Description: Bucks County
15. Plaintiff and Defendant are the parents of the following minor children:
a. Christian Michael Jane
Age:7 weeks
Child's address is: 1519 Bensalem Blvd. ,Bensalem, PA
16. Plaintiff is seeking an Order of child custody as part of this petition.
The following is a list of the children and where they have live for the past 5 years:
a. Christian Michael Jane, born on July 8, 2001
For the past 5 years, this child has lived with:
July 8, 2001 until Present-1519 Bensalem B1vd.,Bensalem,
Pennsylvania -Plaintiff, Defendant, and Paternal grandmother
17. The facts of the most recent incident of abuse are as follows:
On or about August 26, 2001, Defendant screamed at Plaintiff, pushed his finger in her
face, and left the residence with the child. Defendant is denying Plaintiff contact with the
child.
On or about August 24,.2001, Defendant followed Plaintiff as she left the residence.
Defendant punched and kicked Plaintiff in the back causing her to fall to the ground,
pulled her hair, spit in her face, and slapped her in the chest. At the time of the incident,
Plaintiff was holding her seven week old son her arms. When the Plaintiff fell to the
ground, the baby hit the back of his head on a stone causing a bump. Plaintiff took the
child to the hospital to be examined.
18. 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:
pn or about Easter Sunday 2001, Defendant followed Plaintiff as she left the residence,
grabbed her by the hair, and slapped her in the chest. Plaintiff was pregnant at the time
of the incident. Later, when Plaintiff returned to the residence, Defendant had thrown all
of her belongings onto the front lawn.
Since approximately May 2000, Defendant has abused Plaintiff in ways including the
following: pushed, slapped, punched, kicked, and spit in her face. On several occasions,
Defendant has twisted Plaintiffls arms and pulled her thumb backwards causing pain and
soreness.
19. The police department(s) or law enforcement agencies that should be provided with a copy of
the protection order are:
Pennsylvania State Police of Carlisle
20. There is an immediate and present danger of further abuse from the Defendant.
21. 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 children in any place where Plaintiff may be found.
b. Award Plaintiff temporary custody of the minor children and place the
following restrictions on contact between Defendant and children:
Plaintiff shall have primary temporary custody of the minor child.
Defendant shall not have contact with the minor child until further
Order of Court.
Upon service of the Temporary Protection From Abuse Order and
Petition bylaw enforcement, Defendant shall return the minor child to
Plaintiff pending further Order of Court.
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 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 children.
d. Order Defendant to pay the costs of this action, including filing and service
fees.
e. Order the following additional relief, not listed above:
-Defendant shall not harass Plaintift"s relatives.
-Defendant shall not damage or destroy any property owned jointly by
the parties or solely by Plaintiff.
-Defendant shall pay $250.00 to one of MidPenn Legal Services funding
sources as reimbursement for litigation in this case.
£ Grant such other relief as the court deems appropriate.
g. Order the police or other law enforcement agency to serve the Defendant
with a copy of this Petition, any Order issued, and the Order for Hearing.
The petitioner will inform the designated authority of any addresses, other
than the Defendant's residence, where Defendant can be served.
Respectfully
., Date: ~ d
Distribution to:
fiavid Lopez, Attorney for
MID-PENN LEGAL SEI
8 Irvine Row
Carlisle, PA 17013
(717)243-9400
MIDPENN LEGAL SERVICES
Fax and Mail to PSP
VERIFICATION
I verify that I am the Petitioner as designated in the present action and that the facts and
statements contained in the above Petition are true and correct to the best of my knowledge. I
understand that any false statements are made subject to the penalties of 18 Pa.C.S.§4904, relating to
unsworn falls, ific~jation to authorities.
Dated: CJ / l ~ !~ ~ i~
~~~~
"Danielle 'thian, Plaintiff
~ -..: C7 r_. __~
~.',
+ i
A _ _
~ _ ..
a =~ . __ ~=
-~i~03Yd+4 RR*e!?ft^• ~-~£n ~&s icy xfm~ v°PC'
08/31/01 FRI 14:51 FA% 717 240 6573 CUMB CO PROTHONOTARY
~jool
~~:s~a~xzcixxs~a~*~a:ix~$~~~~**a~
~~~ MULTI TN REPORT ~:~
:e*as~~ax~*s~*xa~x~uc~a~*~4*~:~
T%/R% NO 2783
INCOMPLETE T%/R%
TRANSACTION OK [ O119p2490779 PSP
[ 0319p2405331 CP
[ D4192438026 LS
ERROR
n
OFFICE OF THE PROTtiCIVO'['ARY
CUr~ERLANO GOUNTY COIJRTHWSE
AYE COURTHCN.SE 9~UARE
CARLISLE, PA. 17013-3387
(717) 240-6195
FAA (717) 240-6573
V I A T E L E C O F I E R
'ro:
FAX N:
FRCM
RE:
MESSAGE;
PA STATE POLICE - 6Cv~. ~l?OCGSS.~
717-249-0779
CURTxS R. LONG
PFA ORDERS
M. R ~.5.
NC?. OF PAGES (YNCLUDING (`7VER SHUE'1')
_.
This is inL~t3~j rn].y &a tine ua~ of tie udivid~al ¢ eetiky to w{tidt is is acad. 3d ~sey
arntain in5arn~im ~ tl et as pCivi]Agad. aonfidar~i~31 arcl em~pt bvn di9C]aaae u'ctrar a~lic~ ]Ew. [F
the c~ of thv nesar~ is rot l3'e in1~tilBCi ~a[~1ant, ya cae l8!'~ rn~t3£i6d tfgt ary dj~~inatim,
r1;ciT'ir. shim ¢ ~Ij~ ~ ttti.5 arnrtuctii~itxl i:: striC`C1.Y lnhibilx'd. TE you ttgV~ 1'~mPivecl tSus
aunruiic'-',.ion il'i Exxrx, ,terry us imrt~,i,~te].y cy he1Qi-t.ne acd cetian de axicpral. n m ~ at
Danielle Lynn Fithian
Plaintiff
1N THE COURT OF COMMON
:PLEAS OF
:CUMBERLAND COUNTY,
PENNSYLVANIA
v.
Walter Christopher Jane
No. 01-5193
Defendant
CIVIL ACTION -LAW
PROTECTION FROM ABUSE
FINAL ORDER OF COURT
Defendant's Name is: Walter Christopher Jane
Defendant's Date of Birth is: Apri126,1975
Defendant's Social Security Number is: 192-54-5476
Name(s) of All protected persons, including Plaintiff and minor children:
1. Danielle Lynn Fithian
Appearances by Parties and/or Counsel:
. Plaintiff appeared personally and is represented by: Joan
Carey, MidPenn Legal Services
. Defendant appeared personally and is represented by:
Philip Spare, Snelbaker, Brenneman, and Spare
AND NOW, this 7th Day of September, 2001 the court having jurisdiction
over the parties and the subject-matter, it is ORDERED, ADJUDGED and
DECREED as follows:
Plaintiffs request for a Final Protection Order is granted, after hearing upon
finding abuse within the PFA Act.
Plaintiff s request for a final protection order is granted.
1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other
protected person in any place where they might be found.
2. Except as provided in Paragraph 4 of this Order, Defendant is prohibited
from having ANY CONTACT with the Plaintiff, or any other person
protected under this Order, at any location, including but not limited to any
contact at Plaintiffs school, business, or place of employement. Defendant is
specifically ordered to stay away from the following locations for the
duration of this order.
Plaintiffs residence located at 207 Plaza Drive, Boiling Springs,
Pennsylvania.
Any current or future place of employment Plaintiff may establish.
3. Except as provided in Paragraph 4 of this Order, Defendant shall not contact
the Plaintiff, or any other person protected under this Order, by telephone or
by any other means, including through third persons.
4. Custody of the following minor children:
1. Christian Michael Jane, born on July 8, 2001
shall be as follows:
. Primary physical custody of the minor child/ren is
awarded to the Plaintiff.
. See attached Custody Order.
5. The following additional relief is granted as authorized by §6108 of the Act:
-Defendant shall not harass PlaintifFs relatives.
-Defendant shall not damage or destroy any property owned jointly by
the parties or solely by Plaintiffo
- Any contact by the parties, including but not limited to, phone calls in
reference to the minor child or custody exchange of the minor child shall
not be deemed a violation of this Order.
6. 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 of Carlisle
7. THIS ORDER SUPERSEDES:
1. ANY PRIOR PFA ORDER
2. ANY PRIOR ORDER RELATING TO CHILD
CUSTODY
8. All provisions of this order shall expire on: March 7, 2003
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 $1,000 AND/OR A JAIL SENTENCE
OF UP TO SIX MONTHS. 23 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.S. TERRITORIES AND
THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE
AGAINST WOMEN ACT, 18 U.S.C. §2265. IF YOU TRAVEL OUTSIDE OF
THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY
BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT
ACT. 18 U.S.C §§2261-2262. IF THE BRADY INDICATOR PARAGRAPH
APPEARS IN THE ORDER, YOU MAY BE SUBJECT TO FEDERAL
PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS
OF THE GUN CONTROL ACT, 18 U.S.C. §922(G), FOR POSSESSION,
TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
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,
shall enforce this order. An arrest for violation of Paragraphs 1 through 4 of this
order maybe without warrant, based coley on probable cause, whether or not
the violation is committed in the presence of the police. 23 Pa.C.S. §6113.
Subsequent to arrest, the police officer shall seize all weapons used or
threatened to be used during the violation of the protection order or during prior
incidents of abuse. The Cumberland County Sheriff shall maintain possession
of the weapons until further order of this Court.
When the defendant is placed under arrest for violation of this order, the
defendant shall be taken to the appropriate authority or authorities before whom
defendant is to be arraigned. A "Complaint for Indirect Criminal Contempt"
shall then be completed and signed by the police officer OR the plaintiff.
Plaintiffs presence and signature are not required to file the complaint.
If sufficient grounds for violation of this order are alleged, the defendant shall
be arraigned, bond set and both parties given notice of the date of the hearing.
BY THE COURT:
Kevin A. Hess, Judge
Date
Danielle Fithian, :IN THE COURT OF COMMON PLEAS OF
Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION
Walter Christopher Jane,
Defendant : No. 01-5193 PROTECTION FROM ABUSE
TEMPORARY CUSTODY ORDER
And now, this day of September, 2001, after hearing in the above captioned
case, the following Temporary Custody Order is entered regarding custody of minor child,
Christian Michael Jane, born on July 8, 2001.
1. The plaintiff, Danielle Fithian, hereinafter referred to as Mother, and the defendant,
Walter Christopher Jane, hereinafter referred to as Father shall share legal custody of
the minor child.
2. Mother shall have primary physical custody of the minor child.
3. Father shall have periods of partial custody as follows:
a. Every other weekend from Friday until Sunday at times mutually agreed upon
by the parties, and
b. Other times agreed upon by the mother and father.
4. Mother and Father shall share custody of the minor child for holidays at agreed
upon times.
5. Mother shall have custody of the child on Mother's Day, and Father shall have
custody of the child on Father's day at mutually agreed upon times.
6. Father shall have the right to two(2) non-consecutive weeks of custody in the
summer. Father shall give mother sixty (60) days notice as to when he wishes to exercise
those periods of custody.
7. The parties shall share transportation of the minor child with Mother transporting
the child to and from Father's residence on Friday, September 14, 2001, and Sunday,
September 16, 2001, and Father providing transportation to and from Mother's residence
on Friday, September 28, 2001, and Sunday, September 30, 2001. Transportation will
continue to alternate according to this schedule unless agreed upon by the parties.
8. This Temporary Custody Order is entered without prejudice to either party to file a
custody case.
By the Court,
Kevin A. Hess, Judge
Distribution to:
Joan Carey
Attorney for Plaintiff
Philip Spare
Attorney for Defendant
`"
Danielle Lynn Fithian
Plaintiff
v.
Walter Christopher Jane
Defendant
: IN THE COURT OF COMMON
:PLEAS OF
CUMBERLAND COUNTY,
:PENNSYLVANIA
No. 01-5193
CIVIL ACTION -LAW
PROTECTION FROM ABUSE
ORDER TO VACATE
AND NOW, this: 11th Day of September, 2001,
1. This matter is dismissed without prejudice.
2. Costs of this proceeding are waived.
3. The Temporary Order (Filed on Aug 31, 2001) is hereby vacated.
BY THE COURT•
evin A. Hess, Judge
~4 // Zoo/
Date
Distribution to:
MidPenn Legal Services rcc~; /nu~4P g_ /~ - n ~ ~--.
Faxed & Mailed to PSP - e. P. v- tvi ~ ~s
e.y~ ~..~.~~ ~ l~, f° -
t~fN~/1U,5,VN~d
£~~8 E~~ ~I d~S 1~
Danielle Fithian,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
Walter Christopher Jane,
Defendant
NO.01-5193 CIVIL TERM
: PROTECTION FROM ABUSE & CUSTODY
PETITION TO VACATE ORDER
AND WITHDRAW ACTION
Plaintiff, Danielle Fithian, by and through her attorney, Joan Carey of MidPenn Legal
Services, requests that the Court vacate the Temporary Protection From Abuse Order, including
custody, in the above-captioned case and that the action be withdrawn on the grounds that:
1. A Petition for Protection From Abuse was filed and a Temporary Protection From
Abuse Order was issued by this Court on August 21, 2001, scheduling a hearing for
September 7, 2001, at 11:15 a.m. before Judge Hess.
2. After hearing, but before a Final Order was entered, Plaintiff contacted MidPenn Legal
Services and requested we withdraw the Temporary Protection From Abuse Order including
Custody.
3. The parties are in the process of reconciling their differences.
4. Plaintiffrequeststhatthe Temporary Protection From Abuse
Order which includes custody, entered on August 31, 2001, be vacated and the action withdrawn
without prejudice to her.
WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate the
Order, and that the action be withdrawn without prejudice to Plaintiff.
Respectfully submitted,
Joan Carey, Attorney f laintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
~~~~
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: ~~f °~~
Daniell Fithian, Plaintiff
c
' ~
Y
~- ~ ~;
z. ~^. ~„
~~
,
~:
~ _ -
-~
~ _.
~
-t-. -
_ ,
~C._
I.s `~~«
~:r;
G ?~~
~ ~
. iui.tri""t > _£ "e. e. ,i. 'i F]+'.'M46. cn~pR4: 1,
09/12/01 ,wED 09:46 FAX 717 240 6573 CLIMB CO PROTBnNnTaRV '
fh n n
ffi %k88*S&*i&*~S~~~E%F*S8ffi~%8**Y:&
~*s MULTI TN REPORT :aa:~
*~~:Ra*xsu~:ea:*x:z~*~aea~ix~**s~*~
T%/R% NO 2796
INCOMPLETE T%/R%
TRANSACTION OK [ O119p2490779 pgp
[ 03]9p2405331 Cp
[ 04]92438026 LS
ERROR
OFFICE OF TrIE PROTHONOTARY
CUMBERLAND OOUN'PY COUR'CHCUSE
ONE COURTHOUSE SQUARE
CARLISLE, PA. k7013-3387
(7171 240-6195
FAX (717) 240-6573
V I A T E L E C O P I E R
TO; PA STATE POLICE - ~ev~°Rw/ /"Re~css. _ /YI.P4.S -p~,p
FAX R: 717-249-0779
F]~]; CURTIS R. LONG
RE: PFA ORDERS
MESSAGE:
~~ ND. OF PACES (INvLU[iING COVER SPIFFY)
'L1ti5 i5 ?Ilt mly fix the use ~ the i,riiSrirlsal Q' glt'LY.y m Fitictt ]$ is a'd rrey
nrnrain ;n£rimflrirn thdt is ¢ivila~d, CCnfidential aid agatr,7C fiaan Clia~tr`avv ux}~ lau. [f
tl~ xea)Px ~ this rre is rot the inUd~l xecipir'rt, yvu arcs Itex~ rtatafied that ~i' ~~.
dastizkut9a~ of oop7ing ~ tllis aomnnicaiirn is cntirtly pRttibibBd. Lf you rave xgnei~] ~tus
- `---- -~_a.... .,....,,i: aFol.r hr }clrrh'rw rYd x~trxcn L3E LZ7C~Iff31 ITess'a~~ tY) ~ a: