The URL can be used to link to this page

Home My WebLink About01-05490 Ida M. Pennington, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. Tammy S. Erb, Ol- 5490 CIVIL TERM Defendant :PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A HEARING ON THIS MATTER IS SCHEDULED ON i ,2001,AT = ~~ .M., IN COURTROOM NO. 3 OF HE CUMBERLAND COUNTY COUR OUSE, 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 subj ect you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six months in jail under 23 Pa.C.S. §6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. §2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. § 2261-2262. 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 ®F 1990 The Court of Cowmon Pleas of Cumberland County is required by law to comply with the Americans with Aisabilities 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. Ida M. Pennington Plaintiff IN THE COURT OF COMMON :PLEAS OF CUMBERLAND COUNTY, :PENNSYLVANIA v. Tammy S. Erb Defendant No. Q ~5t19 (~ CIVIL ACTION -LAW PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Tammy S. Erb Defendant's Date of Birth is: January 15, 1959 Name(s) of All protected persons, including Plaintiff and minor children: 1. Ida M. Pennington AND NOW, on 20th Day of September, 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. 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. Defendant is specifically ordered to stay away from the following locations for the duration of this order. Plaintiffs residence located at 754 Dogwood Terrace, Boiling Springs, Pennsylvania. I Any future place of employment Plaintiff may establish. 3. 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. The following additional relief is granted: -Defendant shall not harass Plaintiff's relatives. -Defendant shall not damage or destroy any property owned by Plaintiff. 5. 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, Carlisle 6. 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. 7. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MARCH 20, 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 Plaintiffto 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 chazges 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 3 of this Order, defendant shall be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence 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. Distribution to: MidPenn Legal Services Faxed & Mailed to PSP Cumberland County Sheriff PFAD Number: AA1334047L Ida M. Pennington Plaintiff IN THE COURT OF COMMON :PLEAS OF CUMBERLAND COUNTY, :PENNSYLVANIA v. Tammy S. Erb Defendant CIVIL ACTION -LAW PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE 1. Plaintiffs name is: Ida M. Pennington 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. Ida M. Pennington 4. Plaintiff s Address is :754 Dogwood Terrace ,Boiling Springs, PA 17007 5. Defendant's Name is: Tammy S. Erb 6. Defendant is believed to live at the following address: 620 North Hanover Street ,Carlisle, PA 17013 7. Defendant's Date of Birth is: January 15,1959 .> 8. Defendant's Place of employment is: Excel Logistics, Middletown PA 9. Defendant is an adult. 10. The relationship between the Plaintiff and the Defendant is: Current or former sexuaUintimate partner 11. The facts of the most recent incident of abuse are as follows: On or about September 10, 2001, Defendant called Plaintiff continuously for several hours. Defendant went to Plaintiffs residence and threw chairs, computer monitor, and other items into Plaintiff's driveway causing her to fear for her safety. Plaintiff contacted the police who cited Defendant for criminal mischief. 12. 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 September 9, 2001, Defendant called Plaintiff's residence and left a message for Plaintiff stating she was coming over and Plaintiff should leave for her own safety. Defendant came to the residence, pounded on the front door several times with a hammer, and threatened to break the window ff Plaintifff did not let her in. Defendant broke the window on the door, and reached in and attempted to unlock the door. Plaintiff called the police, ran to the door, and attempted to keep it shut by securing the lock on the door and holding her foot. against it. Defendant grabbed Plaintiff by the arm and tried to pull her arm through the broken window. Plaintiff pulled back causing her to fall onto the broken glass on the floor. Defendant fled Plaintiff s residence and returned later when the Carlisle State Police was present. Defendant was told by the police not to have contact with Plaintiff. Plaintiff suffered several cuts on her leg as a result of the incident of abuse. Plaintiff suffered reasonable fear of imminent serious bodily injury. 13. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: Pennsylvania State Police, Carlisle 14. There is an immediate and present danger of further abuse from the Defendant. 15. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or minor child/ren in any place where Plaintiff may be found. b. 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, inchding but not limited to any contact at Plaintiffs school, business, nr place of employment, except as the court may find necessary with respect to partial custody and/or visitation with the minor children. c. Order Defendant to pay the costs of this action, including filing and service fees. d. Order the following additional relief, not listed above: -Defendant shall not harass Plaintifff s relatives. -Defendant shall not damage or destroy any property owned by Plaintiff. -Defendant shall pay $250.00 to one of MidPenn Legal Services funding sources as reimbursement for litigation in this case. e. Grant such other relief as the court deems appropriate. f Order the police or other law enforcement agency to serve the Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. Respectfully Submitted by: avid A. Lopez, Esq. Agency: MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717)-243-9400 or 1-800-822-5288 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 knowledge. I understand that any false statements are made subject to the pengalties o/f 18 Pa.C.S. §4904, relating to unsworn falsification to authorities. Dated: / /~~/ ~ ~ _~ ~~ Ida M. Penningto Isintiff ~...c,ua6~~a1~NikWf~.~-s:.~.: cwsrs~ iar'els, ,.. ; _ :.~;. ::i~„r„saR4.e~I~~i~ee~~3.~w5a3~iHa~iax5i~t- : ' ; xii?~ . . ~ Q - ~ ~ ~~T : ;~ CJJ _ ~- --~ . ~ __ r~ lri ..; ';"' -J `' ~J ~~ S 1~ ~ ~ ' ~_ l~ yyy~~ Y 9 yyy~ ~-~ ~, +- "h ~.. c~ ~ ~'- ~n ~~ x.e~~ ns/zn/nt TAti 15:Ofi FAX 777 240 6573 CUMB CO PROTHONOTARY ~ X1001 e ~ aa~s~za~s~a:MSa:x xaffis~zs~mzsmas~w *~a BIULT'I TN REPORT aka N~&Y&N~ES%~Yi&~ffi~S~~St~NY8~k~~~t T%/R% NO 2809 INCOMPLETE T%/R% TRANSACTION OH [ O179p2490779 PSP [ 0379p2405331 CP [ 04]92438026 LS ERROR OFFICE OF THE PROTHONO'I`ARY CUhBERLANp 0.7UNPY Ol7URTHgUSE ONE CCURTHOfJSE S~tARE CARLISLE, PA. 170I3-3387 (717 240-6195 FAX (7I7) 24D-6573 V I A T E L E C O F I E R TO: PA STATE POLICE - ('6n/`~y~~1~ rjPlleJr3t, ~ f~.PR.-f• FAX k: 717-249-0779 F'RCM: CORTIS R. LONG RE: PFA ORDERS t~SSAGE: L NU. OF PAGES (IN:.`LUDING DOVER SHEE1'~ 7ttis is irnt~d qtly ftg the , ~, ctf die irclivi[hs91 cr aiYity ho c,Rtirit is is ate. ~ ~i' arzttain in6®trit(m fret >s Ex'ivi~, arnfidFnt3ai. artil enmt~ flan A;crtrvro lr[~[' ~ la,r. If d>; t cif this n> is rOt the .irtt~t7a~ rgcilxipttt, Y~ ~ ttP1,'~ rotifaied drat aty rl;~+ninatirn, r1;cYritcrt;m r~ mpyiry t~ this mmLnS~.afi[7n is strictly pedtibidtad. If yczt have xerni~ ttus crnmrtic.:itial in 21Z+:~, plt~e t~'~-fY is imrecliatelY ~ telept're e-nd Cshh>tn rte ~iyirr3l rr W ~s a: tiP_ 2tXbc' .3~IIEiS utd t}72 ~:.5. [;~F••i3]. ~,Vl[k=- '(tR'~k crv. Ida M. Pennington Plaintiff v. Tammy S. Erb Defendant IN THE COURT OF COMMON :PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA No. 01-5490 CIVIL ACTION -LAW PROTECTION FROM ABUSE ORDER TO VACATE AND NOW, this: 19th Day of November, 2001, 1. This matter is dismissed without prejudice. 2. Costs of this proceeding are waived. 3. The Final Order (Filed on Oct 24, 2001).is hereby vacated. C~~k~. Hoffelr, President v Judge ~~ Distribution to: • ~ MidPenn Legal Services ~~ Q~Ra.A Faxed & Mailed to PSP ~ ~ f ~~S ,~P-~.s !Z-~-Of ,~. ,, ;,. ,_i_ ,r ~; r 1 Ida Pennington, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA VS. N0.2001-5490 CIVIL TERM Tammy S. Erb, , DEFENDANT :PROTECTION FROM ABU5E PETITION TO VACATE ORDER AND ~VITIIDRA~V ACTION Plaintiff, Ida Pennington, by and through her attorney, David Lopez of MidPenn Legal Services, requests that the Court vacate the Final Protection Order 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 September 20, 2001, scheduling a hearing for September 2b, 2001, 1:30 p.m. before Judge Hoffer in Courtroom No. 3 of the Cumberland County Courthouse. A Final Protection Order was entered on October 23, 2001, by agreement of the parties. 2. The parties are in the process of reconciling their differences. 3. Plaintiff requests that the Final Protection Order 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. David Lopez, Attorr MIDPENN LEGAL 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 ~ r~ 6 6 / ~' Ida Pennington, aintiff e r> c'~ _.. a -.~ r --~ ~~ ; _ !. } s i- . ' ~ -- ~ ` r:_ c~ ~:i s~ .~ .r- 12/05/01 N'kD 11:10 FA% 717 240 6573 CUMB CO PROTHO t' ~~ NOTARY Cdr n n t ' « ~%N Y~88~*Bffi$*affixc*ffiS m~B B%R ~%~K<~Y$ ' *~~ ffi[1LTI TN REPORT` :rage aaaaaaaaaaaaaaaaaaaaaaaaaaa T%/R% NO 2889 INCOffiPLETE T%/RX [ 0319p2405331 Cp TRANSACTION OR [ 0119p2490779 pgp [ 04]92438026 LS ERROR OFFICE OF THE PR0IHONOCARY CUN~ERLAND COUMI'Y O]URTHOU9E ONE OOURTHOUSE SQUARE CARLISLE, PA. 17013-3387 (717) 240-6195 FAX (717) 240-6573 V I A T E L E C O P I E R TO: FAX ~: FRCtd ; RE: P~SS,AGE PA STATE POLICE - `CIU7''RA~ P+~D<tSS. _ 1~A ~~-' 717-249-0779 CURTIS R. LONG PFA ORDERS .-- NO. OF PAGES (INt:'LUDING CDVER SHEET) This rt iS irrtr3'C15d enly f~ litc u~ aE dt? iridividal a ettity do e+ttith is is end, ~ ~Y ~~jn in£emmtitn t]"Ht ]5 FL1tli~, aQ~fid3ttidl 3Y1 ~T.[irl t9;crlro av Lft~ ~ 7SJ. [f the tt3yier ad: this rt~ is rot d~ intarl3c, t:ecipiatt, ynt are ['~ rotifiSd that ay r7T~ntittatun, r];~,~;r,t~im cr t~tyirtg t7E thSs antrnrtit~.at]at is strictly ~ciibiUa3. Li; yw h~.e xt3oeirsi t}tis Ot7~tY4Cr7(,~`.;m it pxKx, ply rotiiy us ;mmri;.4tptY px, ~i-rte atd nehrcn tte izicprt31 rres~age W ~ a: li'e ~~' vid de :!.S. poFtal s¢vioe. TreNc you. Ida M. Pennington Plaintiff :1N THE COURT OF COMMON ;PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. Tammy S. Erb No. 01-5490 Defendant CIVIL ACTION -LAW PROTECTION FROM ABUSE FIl~TAL ORDER OF COURT Defendant's Name is: Tammy S. Erb Defendant's Date of Birth is: January 15,1959 Name(s) of All protected persons, including Plaintiff and minor children: 1. Ida M. P--en~yyngton ~~~R AND NOW, this~tl Day of October, 2001 the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows: Upon agreement of the parties for the entry of a consent order, this order will be entered without any admission of liability by the defendant and without a finding of abuse by this court: Plaintiffs 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. 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. Plaintiff's residence located at 754 Dogwood Terrace, Boiling Springs, Pennsylvania. Any future place of employment Plaintifff may establish. 3. The following additional relief is granted as authorized by §6108 of the Act: -Defendant shall not harass Plaintiff s relatives. -Defendant shall not damage or destroy any property owned by Plaintiff. -Defendant shall not make any threatening or harassing phone calls to Plaintiff. Any non-threatening, non-harassing, phone contact between the parties shall mot be deemed a violation of this Order. -The court costs and fees are waived. 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, Carlisle 5. THIS ORDER SUPERSEDES: 1. ANY PRIOR PFA ORDER 6. All provisions of this order shall expire on: Apri12, 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 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 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 2 of this order may be without warrant, based soley on probable cause, whether or not the violation is committed in the presence of the police. 23 Pa.C.5. §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 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. ~& If entered pursuant to the consent Ida Pro se David Lopez ~ Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 ~,~e ~`~ ~~ ~~ p~ `D.~ Q~,~ ~ ~~ ~~ ,(~~ ~e ~ ~-`~ 1 ~5 .t.~iis:;~.~-?~ ^i~r=:-~^a~a~Mk'snnsfi.~;4ies „waa., :_ :.~t:ti~,~tv.,, ...:.; a]sakitu`3~X'~tKa~F'i::~tixN~~4vfltl _ .• _ :. till~~df~~i/1i71 V~~~ iiU ~5 a';'~ ??,1~~ i0 ~, _.~, . ~.a~i~ ca ~~ ~ -° ~~ ~o iJ:!..~i}'~~ il: . ; 10/24/01 V9ED 12:13 FA% 717 240 6573 CIIffiB co PROTRfINOTARV f,h nn, *,ssa*~at~,kas*Yxix~a~gs~ts*a:s~k ~xz MLILTj T~' REPORT s~:e 88*~XB:k&~:N88&*88ffi88*~~~ffi8*S T%/R% NO 2851 INCOffiPLETE T%/R% TRANSACTION OK [ O119p2490779 pgp [ 03]9p2405331 Cp [ 04]92438026 LS ERROR h OFFICE pF THE PROTHONC)'CARY CLH~'BERLAND COUNTY Gl~UR'IH(XJSE ONE CI.7UR`['H(XJSE SQUARE CARLISLE, PA. 17D13-3367 (717) 240-6195 FAx (717) 240-6573 V I A T E 4 E C Q P I E R To: PA STATE POLICE - CEy~• rROCG SS, - M, ~J, ~,5. FAX a: 717-249-D779 ~ ' FRCM: CURTTS R. LANG RE: PFA ORDERS MESSAGE: N0. OF PAGES (I[3"~LUL7ING COVER SHEET) 'tl'as m is ink cnly $ctt tte ise C~ tlE iY[11V]dk11 cr H1Y9.ty h7 ~tiirtt is i5 and ~Y orntain ~ tl'~ as [xavilec~d. mn£iriafiial aid eaai~ £LOn d;cr•7rsap u~ ~pLjtsY11B ]ew. Cf Gee z~~r of tliis a is rot H'e intetlFt.] ~i}a11~t, ya, ~e 1~ roti.fied fret ary di~~• ~' aAY~J ~ tlvs aortnnicaFim is str7uChly pcettihibed. TP 5'a tine ceoex~ed t}us mnnnic.~'~ign in FriCx', pleeee roti.Cy is imn~liahly b,' bel~i~ eCd ~eltrcn tt:e ~ru~nrxl m ~ at aa.,. .a... .. ~3R,ar.. .,.~ 1-Y~e el a ....-.f-~7 r.... ~.-... M,~....1.. ..-.. Mr ~ Ida M. Pennington Plaintiff v. Tammy S. Erb Defendant IN THE COURT OF COMMON :PLEAS OF CUMBERLAND COUNTY, :PENNSYLVANIA No. 01-5490 CIVIL ACTION -LAW PROTECTION FROM ABUSE CONTINUED TEMPORARY ORDER AND NOW, this 26th Day of September, 2001, pursuant to 23 Pa.C.S. §6107(c), the terms and conditions of the Temporary Order issued on 20th Day of September, 2001, in the above-captioned case are hereby continued in full force and effect .This order is in effect until March 26, 2003. A hearing on this matter is scheduled for November 28, 2001, at 9:30AM in Courtroom 3 of the Cumberland County Courthouse, One Courthouse Square, Carlisle. Distribution To: MidPenn Legal Services Faxed & Mailed to PSP Tammy Erb, Defendant Pro Se .~ ~' m p~S q_s~-a/ CP. /hP~s `"~ ,ov~~ ,~ .. ~,.~ ~. r ~ f ! t~;: ` ~. ~. ~.. ~ ~iS, ~ . . ~, 1(,\' Ida Pennington : IN THE COURT OF COMMON PLEAS OF Plaintiff v. Tammy Erb, CUMBERLAND COUNTY, PENNSYLVANIA NO. O1- 2153 CIVIL TERM Defendant :PROTECTION FROM ABUSE MOTION FOR CONTINUANCE The Plaintiff, Ida Pennington, by and through her attorney, David Lopez of MidPenn Legal Services, moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds that: 1. A Temporary Protection From Abuse Order was issued by this Court on September 20, 2001, scheduling a hearing for September 26, 2001, at 1:30 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 at his residence located at 620 North Hanover Street, Carlisle, Pennsylvania, on September 20, 2001, at 8:50 p.m. The parties agree that the hearing be rescheduled to afford them time to execute a consent agreement. 4. The Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. WHEREFORE, the Plaintiff requests that the Court grant this Motion reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. 1VgIDPENN LEGAL 8 Irvine Row Carlisle, PA 17013 (717)243-9400 G " '=" -- ~' c --- - -i c:: y( - Y`t~ (';a -J „~ •< S:i -c SHERIFF'S RETURN - REGULAR CASE NO: 2001-05490 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PENNINGTON IDA M VS ERB TAMMY KATHY CLARKE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon ERB TAMMY S the DEFENDANT at 2050:00 HOURS, on the 20th day of September, 2001 at 620 N HANOVER ST CARLISLE, PA 17013 TAMMY ERB by handing to a true and attested copy of PROTECTION FROM ABUSE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.25 Affidavit .00 Surcharge 10.00 .00 31.25 Sworn and Subscribed to before me this ;(8~ day of i.~ ,~.GV1 A.D. . ~ . Li 7'h Q® .e.4 Prothonotary So Answers: .~~~~ R. Thomas Kline 09/21/2001 By: Dep y heriff