HomeMy WebLinkAbout01-06075
OCT 2001 '
ROXANNE COSTOPOULOUS,
Plaintiff
V.
JOHNNY E. WRIGHT,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
NO. 01 - &675 CIVIL TERM
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth
in the following pages, 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 the matter is scheduled for the 151 , day of'W4W-1r ? 2001, at 3
.m., in Courtroom a at the Cumberland County Courthouse, 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. S. § 6114. Violation may also subj ectyou
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 YOURLAWYERAT 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
(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.
30
s
U; fir; 2ix s>,,
,s
CGh'viw?F;?h,ti4 ?U'ufv?TY
PctJl?!SYL?/ANiA
`= h
ROXANNE COSTOPOULOUS,
Plaintiff
V.
JOHNNY E. WRIGHT,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
NO. 01 -6075 CIVIL TERM
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name: Johnny Edward Wright
Defendant's Date of Birth: May 14, 1958
Defendant's Social Security Number:
Names of All Protected Persons, including Plaintiff and minor child/ren: Roxanne Costopoulous
AND NOW, this e? 161, day of ?, 2001, upon consideration of the
attached Petition for Protection From Abuse, the court hereby enters the following Temporary
Order:
[X] 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place
where they might be found.
[X] 2. Defendant is evicted and excluded from the residence at 132 West South Street,
Apartment 1, Carlisle, Pennsylvania, 17013 or any other permanent or temporary residence
where Plaintiff may live. Plaintiff is granted exclusive possession of the residence. Defendant
shall have no right or privilege to enter or be present on the premises.
[X] 3. Defendant is prohibited from having ANY CONTACT with Plaintiff 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:
[X] 4. Defendant shall not contact Plaintiff by telephone or by any other means, including
through third persons.
[] 5. Pending the outcome of the final hearing in this matter, Plaintiff is awarded temporary
custody of the following minor child/ren:
The local law enforcement agency in the jurisdiction where the child/ren are located shall ensure
that the child/ren are placed in the care and control of the Plaintiff in accordance with the terms
of this Order.
[] 6. Defendant shall immediately relinquish the following weapons to the Sheriffs Office or a
designated local law enforcement agency for delivery to the Sheriffs office:
Defendant is prohibited from possessing, transferring or acquiring any other weapons for
the duration of this order.
[] 7. The following additional relief is granted:
[X] 8. A certified copy of this Order shall be provided to the police department where Plaintiff
resides and any other agency specified hereafter:
Carlisle Police Department
[X19. THIS ORDER SUPERSEDES [X] ANY PRIOR PFA ORDER AND[] ANY PRIOR
ORDER RELATING TO CHILD CUSTODY.
[X] 10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN
IN EFFECT UNTIL 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 plaintiffs
residence OR any location where a violation of this order occurs OR where the defendant may be
located. If defendant violates Paragraphs 1 through 6 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 Sheriffs office of e county which issued this
Order, which office shall maintain possession of the til further Order of this court,
unless the wea on/s a r e evidence of a crime in ch cas , cy shall remain with the law
enforcement agency whose officer made the est.
to z
DaW 'I
ROXANNE COSTOPOULOUS,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
JOHNNY E. WRIGHT,
Defendant
NO. 01 -(0075 CIVIL TERM
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiffs name is: Roxanne Costopoulous
2. I am filing this Petition on behalf of [X] Myself and/or [] Another Person.
3. Name(s) of ALL person(s), including Plaintiff and minor children, who seek protection
from abuse:
Roxanne Costopoulous
4. [] Plaintiffs address is confidential or
[X] Plaintiffs address is: 132 W. South St. Apt. 1, Carlisle, PA 17013
5. Defendant is believed to live at the following address: 132 W. South St. Apt. 1, Carlisle,
PA 1
Defendant's Social Security Number (if known) is:
Defendant's date of birth is: May 14, 1958
Defendant's place of employment is: Unemployed, applied for disability
[] Check here if Defendant is 17 years old or younger.
6. Indicate the relationship between Plaintiff and Defendant.
[] Spouse [X] Current/former sexual/intimate
partner
[] Ex-spouse [] Parent/child
[] Persons who live or have lived like spouses [] Other relationship by
blood/marriage
[] Parents of the same children
7. Have Plaintiff and Defendant been involved in any of the following court actions? No.
[] Divorce [] Custody [] Support [] Protection From Abuse
If you checked any of the above, briefly indicate when and where the case was filed and
the court number if known:
8. Has the Defendant been involved in any criminal court action? Unknown
If you answered Yes, is the Defendant currently on probation? No.
9. Plaintiff and Defendant are parents of the following minor child/ren: N/A
10. If Plaintiff and Defendant are parents of any minor child/ren together, is there an existing
court order regarding their custody? N/A
11. The following other minor child/ren presently live with Plaintiff: N/A
12. The facts of the most recent incident of abuse are as follows:
Approximate Date: 10/22/01 Approximate Time: Place: 132 W. South St. Apt. 1,
Carlisle, PA 17013
Describe in detail what happened, including any physical or sexual abuse, threats, injury,
incidents of stalking medical treatment sought, and/or calls to law enforcement:
Plaintiff and Defendant were arguing, when Defendant threw her into a chair. He had one
hand around her neck trying to choke her, and the other pulled back, making a fist, as if he were
going to punch her. Then Defendant lifted Plaintiff and threw her onto the couch. He pinned her
down with his weight. Again, he had one hand around her neck trying to choke her, and the
other hand was in a fist near her face.
13. If the Defendant has committed prior acts of abuse against Plaintiff or the minor
child/ren, describe these prior incidents, including any threats, injuries, or incidents of stalking,
and indicate approximately when such acts of abuse occurred:
There are numerous other instances of abuse, beginning about mid-August 2001.
Defendant has slapped and punched Plaintiff. He has also choked her and dragged her by her
hair.
Around the end of August, Defendant punched Plaintiff several times in her head. He
also pulled a knife on her and held it to Plaintiffs neck with one hand, while choking her with the
other hand. Plaintiff passed out.
14. List the weapon(s) that Defendant has used or threatened to use against Plaintiff or the
minor child/ren:
Defendant pulled a knife on the Plaintiff during one incident at the end of August, 2001.
Plaintiff believes that Defendant has disposed of the knife.
15. Identify the police department or law enforcement agency in the area in which Plaintiff
lives that should be provided with a copy of the protection order:
Carlisle Police Department
16. There is an immediate and present danger of further abuse from the Defendant.
CHECK THE FOLLOWING BOXES ONLY IF THEY APPLY TO YOUR CASE AND
PROVIDE THE REQUESTED INFORMATION
[X] Plaintiff is asking the court to evict and exclude the Defendant from the following
residence: 132 W. South St. Apt. 1, Carlisle, PA 17013
[X] owned by (list owners, if known): Brian Shotto
[X] rented by (list all names, if known): Roxanne Costopoulous
[] Defendant owes a duty of support to Plaintiff and/or the minor children.
[] Plaintiff has suffered out-of-pocket financial losses as a result of the abuse described
above. Those losses are:
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 (CHECK ALL FORMS OF RELIEF REQUESTED):
[X] A. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff in any place
where Plaintiff may be found.
[X] B. Evictlexclude Defendant from Plaintiff s residence and prohibit Defendant from
attempting to enter any temporary or permanent residence of the Plaintiff.
[] C. Require Defendant to provide Plaintiff and/or minor child/ren with other suitable
housing.
[] D. Award Plaintiff temporary custody of the minor child/ren and place the following
restrictions on contact between Defendant and child/ren:
[X] E. Prohibit Defendant from having any contact with Plaintiff, 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.
[] F. Prohibit Defendant from having any contact with Plaintiffs relatives and Plaintiffs
children listed in this Petition, except as the court may find necessary with respect to partial
custody and/or visitation with the minor child/ren.
[] G. Order the Defendant to temporarily turn over weapons to the Sheriff for this County and
prohibit Defendant from transferring, acquiring or possessing any such weapons for the duration
of the Order.
[] H. Order Defendant to pay temporary support for Plaintiff and/or the minor child/ren,
including medical support and [] payment of the rent or mortgage on the residence.
[] I. Direct Defendant to pay Plaintiff for the reasonable financial losses suffered as the result
of the abuse, to be determined at the hearing.
[X] J. Order Defendant to pay the costs of this action, including filing and service fees
[] K. Order Defendant to pay Plaintiffs reasonable attorney's fees.
[] L. Order the following additional relief, not listed above:
[X] M. Grant such relief as the court deems appropriate.
[X] N. 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 Plaintiff will inform the
designated authority of any addresses, other than Defendant's residence, where Defendant can be
served.
10 /'Zy'o p
7-,L?
Lily L. heung
Certified Legal Intern
"'24- THOMAS
M. PLACE
ROBERT E. RAINS
TERI L. HENNING
Supervising Attorneys
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
VERIFICATION
Understanding that the making of any false statement would subject me to the penalties
of 18 Pa.C.S § 4904, I verify that I am the Plaintiff 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,
information and belief
i017,9 o? ?
Da Roxanne Costopoulous
r'a't t t"; ?? -
rF \J
f 5
CD, -
L
v
?
1?
10/24/01 WED 12:57 FAX 717 240 6573 CURB CO PROTHONOTARY
Zoo]
sssssssssssssssssssssssssss
sss MULTI IN REPORT sss
sssssssssssssssssss*sssssss
TX/RX NO 2852
INCOMPLETE TX/RX
TRANSACTION OK [ 0119P2490779 PSP
[ 0319P2405331 CP
ERROR
OFFICE OF THE PROTHONOTARY
CUtMERLAND COUNTY COURTHOUSE
ONE COURTHOUSE SQUARE
CARLISLE, PA. 17013-3307
(717) 240-6195
FAX (717) 240-6573
V I A T E L E C O P I ER
TO; PA STATE POLICE - l"C?/ti?I?I I?OCCSS. J{,?? s °p.s.p
FAX q: 717-249-0779
FROM: CURTIS R. LONG
RE: PFA ORDERS
MESSAGE:
J?
NO. OF PACES (IN`'LUDING COVER SHEET)
Ttds m rimy is i Yterded aay fw the use of the utivx1ml cr m ty W uhich is is a sd. ad may
PC<ltdm mffime'= dgt is Pavaacad. 031f b tial ad Oergt fmn dlcOost.o unchr aWbcdxa IW- If
ti,e roadw of d-ds is rot the inbeixW ceziphent, yw are hw4 r t ied dtt ay diswdninatior,
dis&i ittun cr a.Pying of this aam xuoaticn is strictly pmhibitei. If y u ht?ae woeived [lus
caminicatia1 in e2m-x, pieese ratify OS im a iatEly ty beleph-rxs aid return tt a origin W LO a;
de a via de U.S. poFtal sEnda-_. 'Ihgt* yw.
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-06075 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
COSTOPOULOUS ROXANNE
VS
WRIGHT JOHNNY E
DOUGLAS DONS
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE was served upon
WRIGHT JOHNNY E
the
DEFENDANT , at 1555:00 HOURS, on the 24th day of October 2001
at 10 SOUTH HANOVER ST
ISLE. PA 17013
JOHNNY WRIGHT
by handing to
a true and attested copy of PROTECTION FROM ABUSE
together with
and at the same time directing His 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 31,u- day of
2("I A. D.
Prothonotary
So Answers:
R. Thomas Kline
10/25/2001
FAMILY LAW
By : Q /
Deputy Sheriff
f
ROXANNE COSTOPOULOUS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
V. IN PROTECTION FROM ABUSE
JOHNNY E. WRIGHT,
Defendant NO. 01 - 6075 CIVIL TERM
FINAL ORDER OF COURT
Defendant's Name: Johnny Edward Wright
Defendant's Date of Birth: May 14, 1958
Defendant's Social Security Number:
Names of All Protected Persons, including Plaintiff and minor children: Roxanne Costopoulous
AND NOW, this day of November, 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. The following additional relief is granted as authorized by § 6108 of the Act:
Defendant, provided that he is accompanied by a constable or other local law enforcement
official, will be permitted to return to 132 West South Street, Apartment 1, Carlisle,
Pennsylvania, 17013, at a date and time to be agreed upon, and arranged by counsel for the
parties, in order to collect his personal belongings.
3. All fees and costs 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:
Carlisle Police Department
THIS ORDER SUPERCEDES [X] ANY PRIOR PFA ORDER AND [ ] ANY PRIOR ORDER
RELATING TO CHILD CUSTODY.
All provisions of this order shall expire in eighteen months, on May 1, 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 $1,000.00 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 CRUVIES 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.
A,
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shallbe enforcedby the police who have jurisdiction over the plaintiffs residence
OR any location where a violation of this order occurs OR where the defendant may be located. If
defendant violates Paragraphs 1 through 2 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.
BY
B44?ffd B. Bayley
E dre
This Order is entered pursuant to the consent of Plaintiff and Defendant:
rte,.....--...
s
7e
oxanne Costopoulo*usn&lff , Johnny B. g t, Defendant
1r;,4 x
Lily . Cheung, Certifiedfegal Intern
for Plaintiff
L
Teri L. Henning, Supervis g Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968
rn IM,
='
-
r r _r
xm
c
L/01/01 THU 11:59 FAX 717 240 6573 CUNB CO PROTHONOTARY
?0
TX/RX NO
INCOMPLETE TX/RX
TRANSACTION OR
ERROR
sssssssssssssxxxsssssssssss
sss MULTI TN REPORT sss
xsxxaxzaxxasaassaasxsassxax
2856
[ 0119P2490779 PSP
[ 03]9p2405331 CP
rTTHU rn PROTHONOTARY
w Oi
TX/RX NO
INCOMPLETE TR/R%
TRANSACTION OK
ERROR
aaaaaxaaaasaxaaaaaaxxaaaaaa
sss MULTI TN REPORT sss
assssssxsasasassasssassasss
2839
( 0119P2490779
1 0319PZ405331
PSP
CP
OFFICE OF THE PROTHONOTARY
CUMBERLAND COUNTY COURIMCUSE
ONE COURTHOUSE SQUAN
CARLISLE, PA. 17013-3387
(717) 240-6195
FAR (717) 240-6573
V I A T E L E C 0 P.I E R
TO: PA STATE POLICE - CCU-t- Afocasi.
PAX R: 717-249-0779
FKM: CURTIS R. LONG
RE: PFA ORDERS
MESSAGE
ROXANNE COSTOPOULOUS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
01-6075 CIVIL
V.
JOHNNY WRIGHT,
Defendant CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this . rt_-:: day of NOVEMBER, 2001, this Court certifies that
the attached complaint has been properly completed and verified, and there is probable
cause for the issuance of process. In consideration of the attached Commonwealth's
Petition, the defendant, JOHNNY WRIGHT, is directed to appear for trial on the charge
of Indirect Criminal Contempt before the Court on the III day of 'V\ U11 , 2001
at 3.00 o'clock -?.m. in Courtroom # of the Cumberland County Courthouse,
Carlisle, Pennsylvania.
The defendant has a right to be represented by an attorney. If the defendant
cannot afford an attorney, upon request one will be assigned to represent the defendant.
If the defendant wishes assignment of counsel, contact should be made prior to trial with
the Cumberland County Public Defender's Office at 717-240-6285. Further, if the
defendant fails to appear, an arrest warrant will be issued.
The Sheriff of Cumberland County is directed to serve this Order and Petition
upon the defendant. The assessment of costs to be determined by the Trial Judge
subsequent to trial.
Jonathan R. Birbeck,
Chief Deputy District Attorney
JOHNNY E. WRIGHT
cyz. -6 /Lo 6.
---,N1 - I
.? 'a'??nwias s, ws!a?=.?n,n .sa.z =x .. E•w?,. ,. >. ,?s?_ ss. Sic4:e?wn9a °uti?¢csn.wu?-iwiv?ttsw'?"- wc?". °?"'"?ve?:@S ?'^
)TI 1,
i;
ROXANNE COSTOPOULOUS, :IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : 01-6075 CIVIL TERM
JOHNNY E. WRIGHT,
Defendant
CHARGE: INDIRECT CRIMINAL CONTEMPT
COMMONWEALTH'S PETITION FOR A HEARING ON CHARGES
OF INDIRECT CRIMINAL CONTEMPT
Jonathan R. Birbeck, Chief Deputy District Attorney of Cumberland County,
Pennsylvania, brings the following Petition for a hearing on charges of Indirect Criminal
Contempt:
1. A Protection from Abuse Order was issued by the Court. A true and correct
copy of the Order is attached.
2. The defendant's violation of this Order is averred in the attached criminal
complaint.
3. The victim requests the filing of an Indirect Criminal Contempt Charge.
4. The District Attorney's Office approves the filing of this criminal complaint.
5. The Commonwealth is requesting a hearing on the charges of Indirect
Criminal Contempt pursuant to 23 Pa.C.S.A. § 6113.
6. The plaintiff and/or the defendant may seek modification of the Order based
on the filing of this petition as the Court deems appropriate following the trial
in addition to any other sentence. 23 Pa.C.S.A. § 6113.
WHEREFORE, the Commonwealth requests the defendant be commanded to
appear before the Court on the charge of Indirect Criminal Contempt.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND CRIMINAL COMPLAINT AND
09201
Meg. Dist. No.:
DJ Name: Hon. PAULA P CORREAL
Address: 1 COURTHOUSE SQ
CARLISLE PA 17013
Telephone: 717 240 6564
AKA:
JOHN WRIGHT
PROBABLE CAUSE AFFIDAVIT
COMMONWEALTH OF
PENNSYLVANIA
DEFENDANT: Vs.
NAMEand ADDRESS
JOHNNY EDWARD WRIGHT
132 W SOUTH ST
CARLISLE PA 17013 0000 00
Docket No.:
Date Filed: - ;
OTN:
Registration Number Annual Sticker Number OLIN Number SID Number
I
Complaint Number I Complaint Numbers a other Participants I 20011l1pc tleptllgrnher, CAR 1642UCR Number
R.S.A.: BM 43 DOB : 05 14 1958 000USS..S..#: 122 52 2139
OR NO.: PA0210200
District Attorney's Office - Approved -Disapproved because:
(The District Attorney may require that the complaint, arrest warrant affidavit, or both be approved by the attorney for the Commonwealth prior to filing.
Pa.R.Cr.P. 107.) When the affiant is not a police officer as defined in Rule 51(C) and the offense(s) charged include(s) a misdemeanor or felony which
does not involve a clear and present danger to any person or the community, the complaint shall be submitted to the attorney for the Commonwealth, who
shall approve or disapprove without unreasonable delay).
(Issue Date) lgneture
I, (Name of Affiant) PO JEFFREY D KURTZ BADGE 5
Of CARLISLE PD
residing at 53 WEST SOUTH ST CARLISLE PA 17013
do hereby state: (check appropriate area)
1. % 1 accuse the above named defendant, who lives at the address set forth above or,
I accuse an individual whose name is unknown to me but who is described as
I accuse the defendant whose name and popular designation or nickname is unknown to me and whom I
have therefore designated as John Doe
with violating the vnenal laws of the Commonwealth of Pennsylvania at: CARLISLE
132 W SOUTH ST CARLISLE (Place-Poligcal Subdivision)
in (county) CUMBERLAND on or about it 03 2001 1229 HRS
Participants were: (if there were participants place their names here, repeating name of above defendant)
2. The acts committed by the accused were:
(Set forth a summary of the facts sufficient to advise the defendant of the nature of the offense charged. Neither the evidence nor the statute
allegedly violated need be cited, nor shall a citation of the statute allegedly violated, by itself, be sufficient. In a summary case, set forth a
citation of the specific section and subsection of the statute or ordinance allegedly violated).
** INDIRECT CRIMINAL CONTEMPT - ADULT
CTS 1
THE ACTOR DID VIOLATE THE PROTECTION FROM ABUSE ORDER
NUMBER 01-6075
THE ORDER WAS SIGNED BY THE HONORABLE JUDGE EDGAR B BAYLEY
THE ORDER WAS DATED 11/01/01
Copy: District Justice Defendant Return of Service Police
4/97wp
CRIMINAL COMPLAINT AND
W. PROBABLE CAUSE AFFIDAVIT
Page 2
Defendant Name JOHNNY EDWARD WRIGHT Docket Number:
THE ACTOR VIOLATED THE ORDER BY WRIGHT IN THAT HE DID APPEAR AT
THE RESIDENCE OF COSTOPOULOS, 132 W SOUTH ST, APT 1, CARLISLE
AGAINST THE ABOVE MENTIONED ORDER. PARAGRAPH #2 STATES: THE FOL-
LOWING ADDITIONAL RELIEF IS GRANTED AS AUTHORIZED BY 6108 OF THE
ACT: DEFENDANT (WRIGHT), PROVIDED TAHT HE IS ACCOMPANIED BY A
CONSTABLE OR OTHER LAW ENFORCEMENT OFFICIAL, WILL BE PERMITTED
TO RETURN TO 132 W SOUTH ST, APT 1, CARLISLE PA, 17013 AT A DATE
AND TIME TO BE AGREED UPON, AND ARRANGED BY COUNSEL FOR THE PAR-
TIES, IN ORDER TO COLLECT HIS PERSONAL BELONGINGS. WRIGHT WENT
TO THE RESIDENCE BY HIMSELF WITHOUT A LAW ENFORCEMENT OFFICIAL.
ALL OF WHICH WERE AGAINST THE PEACE AND DIGNITY OF THE COMMONWEALTH OF
PENNSYLVANIA AND CONTRARY TO THE ACT OF ASSEMBLY,
OR IN VIOLATION OF 6114 Al OF THE ACT OF 23
OR THE ORDINANCE OF
3. 1 ask that a warrant of arrest or a summons be issued and that the accused be required to answer the charges
I have made. (in order for a warrant of arrest to issue, the attached affidavit of probable cause must be
completed and sworn to before the issuing authority.)
4. 1 verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information
and belief. I certify the complaint has been properly completed and verified, and that there is probable cause
for the issuance of process. This verification is made subject to the penalties of Section 4904 of the Crimes
Code (18 PA. C.S. 4904) relating to unsworn falsification to 8uthorities.
Date:
AND NOW, on this date,
verified, and that there is probable cause for issuance
epstene isstra
6ertfy the g(brrgolaint has been properly completed and
)f p/"ocess.( /
suing m orw (SEAL)
ROXANNE COSTOPOULOUS,
Plaintiff
V.
JOHNNY E. WRIGHT,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
NO. 01 - 6075 CIVIL TERM
FINAL ORDER OF COURT
Defendant's Name: Johnny Edward Wright
Defendant's Date of Birth: May 14, 1958
Defendant's Social Security Number:
Names of All Protected Persons, including Plaintiff and minor children: Roxanne Costopoulous
AND NOW, this IV- day of November, 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. The following additional relief is granted as authorized by § 6108 of the Act:
Defendant, provided that he is accompanied by a constable or other local law enforcement
official, will be permitted to return to 132 West South Street, Apartment 1, Carlisle,
Pennsylvania, 17013, at a date and time to be agreed upon, and arranged by counsel for the
parties, in order to collect his personal belongings.
All fees and costs 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:
Carlisle Police Department
THIS ORDER SUPERCEDES [X] ANY PRIOR PFA ORDER AND [ ] ANY PRIOR ORDER
RELATING TO CHILD CUSTODY.
All provisions of this order shall expire in eighteen months, on May 1, 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 $1,000.00 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 CREMES 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.
2
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 may be located. If
defendant violates Paragraphs 1 through 2 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 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.
BY THE COURT:
s
Bayley, J.
E
112q
This Order is entered pursuant to the consent of Plaintiff and Defendant:
oxanne Costopoulous, aintiff Johnny E. g t, Defendant
"I /t-'4
Lily`. Cheung, Cei ie egal Intern
for Plaintiff
r
Teri L. Henning, Supervisi g Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013 TRUE Q 0Fy F-Roc RECORD
(717) 243-2968
In I vc4" nv"'?' V?iNv?F-4, a It i~B LPi?i?"'U"., d? Y £ "_i dl
Boa, C6, s alas $af?..L.. a. L'::k :W'u? "?L=•
g
`- ? ?"1far'?
ROXANNE COSTOPOULOUS, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
01-6075 CIVIL
V.
JOHNNY WRIGHT,
Defendant : CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this ;-,? day of NOVEMBER, 2001, this Court certifies that
the attached complaint has been properly completed and verified, and there is probable
cause for the issuance of process. In consideration of the attached Commonwealth's
Petition, the defendant, JOHNNY WRIGHT, is directed to appear for trial on the charge
of Indirect Criminal Contempt before the Court on the ' ft' , day of _ & l? ?u?t tXf?, 2001
ati-00 o'clockP.m. in Courtroom # 9 of the Cumberland County Courthouse,
Carlisle, Pennsylvania.
The defendant has a right to be represented by an attorney. If the defendant
cannot afford an attorney, upon request one will be assigned to represent the defendant.
If the defendant wishes assignment of counsel, contact should be made prior to trial with
the Cumberland County Public Defender's Office at 717-240-6285. Further, if the
defendant fails to appear, an arrest warrant will be issued.
The Sheriff of Cumberland County is directed to serve this Order and Petition
upon the defendant. The assessment of costs to be determined by the Trial Judge
subsequent to trial.
By the Court,
Jonathan R. Birbeck,
Chief Deputy District Attorney
JOHNNY E. WRIGHT
S Edg B. Bayley J.
TRUE COPY FROM REOORD
to T-44k" whereat, I here Uft 99 my heap
4+ad IM e$0 of said Cgwd at COW. Pa
r
ROXANNE COSTOPOULOUS, :IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. : 01-6075 CIVIL TERM
JOHNNY E. WRIGHT,
Defendant
CHARGE: INDIRECT CRIMINAL CONTEMPT
COMMONWEALTH'S PETITION FOR A HEARING ON CHARGES
OF INDIRECT CRIMINAL CONTEMPT
Jonathan R. Birbeck, Chief Deputy District Attorney of Cumberland County,
Pennsylvania, brings the following Petition for a hearing on charges of Indirect Criminal
Contempt:
1. A Protection from Abuse Order was issued by the Court. A true and correct
copy of the Order is attached.
2. The defendant's violation of this Order is averred in the attached criminal
complaint.
3. The victim requests the filing of an Indirect Criminal Contempt Charge.
4. The District Attorney's Office approves the filing of this criminal complaint.
5. The Commonwealth is requesting a hearing on the charges of Indirect
Criminal Contempt pursuant to 23 Pa.C.S.A. § 6113.
6. The plaintiff and/or the defendant may seek modification of the Order based
on the filing of this petition as the Court deems appropriate following the trial
in addition to any other sentence. 23 Pa.C.S.A. § 6113.
WHEREFORE, the Commonwealth requests the defendant be commanded to
appear before the Court on the charge of Indirect Criminal Contempt.
LVIVIIVIVINVV N In Vr rtIV NOY LVNNIH
COUNTY OF CUMBERLAND .
r ,, 09201
Mag. Dist. No.
DJ Name: Hon. PAULA P CORREAL
Address: 1 COURTHOUSE SQ
CARLISLE PA 17013
Telephone: 717 240 6564
AKA:
JOHN WRIGHT
CRIMINAL COMPLAINT AND
PROBABLE CAUSE AFFIDAVIT
COMMONWEALTH OF
PENNSYLVANIA
DEFENDANT: VS'
NAME and ADDRESS
JOHNNY EDWARD WRIGHT
132 W SOUTH ST
CARLISLE PA 17013 0000 00
Docket No.:
Date Filed: t
OTN:
Registration Number Annual Sticker Number ?OILLN NNuu?mJbberrpa13 r3 SID Number
Complaint Number Complaint Numbers it other Participants 2 0 0111 U fJ CAR 642 uOR N=ber
R.S.A.: BM 43 DOB : 05 14 1958 S.S.4: 122 52 2139
ORI NO.: PA0210200
District Attorney's Office - Approved -Disapproved because:
(The District Attorney may require that the complaint, arrest warrant affidavit, or both be approved by the attorney for the Commonwealth prior to filing.
Pa.R.Cr.P. 107.) When the afffant is not a police officer as defined in Rule 51(C) and the offense(s) charged include(s) a misdemeanor or felony which
does not involve a clear and present danger to any person or the community, the complaint shall be submitted to the attomey for the Commonwealth, x
shag approve or disapprove without unreasonable delay).
(lesua Date) (Signature)
1, (Name ofAfsent) PO JEFFREY D KURTZ BADGE 5
Of CARLISLE PD
residing at 53 WEST SOUTH ST CARLISLE PA 17013
do hereby state: (check appropriate area)
1. X I accuse the above named defendant, who lives at the address set forth above or,
_ I accuse an individual whose name is unknown to me but who is described as
I accuse the defendant whose name and popular designation or nickname is unknown to me and whom I
have therefore designated as John Doe
with violatin the ppenal laws of the Commonwealth of Pennsylvania at: CARLISLE
132 WgSOUTH ST CARLISLE (PlaoaPoltoalsubohrisim,)
in (County) CUMBERLAND on or about ll 03 2001 1229 FIRS
Participants were: (if there were participants place their names here, repeating name of above defendant)
2. The acts committed by the accused were:
(Set forth a summary of the facts sufficient to advise the defendant of the nature of the offense charged. Neither the evidence nor the statute
allegedly violated need be cited, nor Shelia citation of the statute allegedly violated, by itself, be sufficient. In a summary case, set forth a
citation of the specific section and subsection of the statute or ordinance allegedly violated). ,
** INDIRECT CRIMINAL CONTEMPT - ADULT CTS 1
THE ACTOR DID VIOLATE THE PROTECTION FROM ABUSE ORDER
NUMBER 01-6075
THE ORDER WAS SIGNED BY THE HONORABLE JUDGE EDGAR B BAYLEY
THE ORDER WAS DATED 11/01/01
Copy: DlstrIct Jusfice Defendant Return of Service Police 4197wp
Page 2
Defendant Name JOHNNY EDWARD WRIGHT
CRIMINAL COMPLAINT AND
PROBABLE CAUSE AFFIDAVIT
Docket Number:
THE ACTOR VIOLATED THE ORDER
THE RESIDENCE OF COSTOPOULOS,
AGAINST THE ABOVE MENTIONED O
LOWING ADDITIONAL RELIEF IS G
ACT: DEFENDANT (WRIGHT), PRO
CONSTABLE OR OTHER LAW ENFORC
TO RETURN TO 132 W SOUTH ST,
AND TIME TO BE AGREED UPON,
TIES, IN ORDER TO COLLECT HIS
TO THE RESIDENCE BY HIMSELF
ALL OF WHICH WERE AGAINST THE P
PENNSYLVANIA AND CONTRARY TO
OR IN VIOLATION OF 6114
OR THE ORDINANCE OF
BY WRIGHT IN THAT HE DID APPEAR AT
132 W SOUTH ST, APT 1, CARLISLE
RDER. PARAGRAPH #2 STATES: THE FOL-
RANTED AS AUTHORIZED BY 6108 OF THE
VIDED TAHT HE IS ACCOMPANIED BY A
EMENT OFFICIAL, WILL BE PERMITTED
APT 1, CARLISLE PA, 17013 AT A DATE
AND ARRANGED BY COUNSEL FOR THE PAR-
PERSONAL BELONGINGS. WRIGHT WENT
WITHOUT A LAW ENFORCEMENT OFFICIAL.
EACE AND DIGNITY OF THE COMMONWEALTH OF
THE ACT OF ASSEMBLY,
Al OF THE ACT OF 23
3. 1 ask that a warrant of arrest or a summons be issued and that the accused be required to answer the charges
I have made. (In order for a warrant of arrest to Issue, the attached affidavit of probable cause must be
completed and sworn to before the issuing authority.)
4. 1 verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information
and belief. I certify the complaint has been properly completed and verified, and that there is probable cause
for the issuance of process. This verification is made subject to the penalties of Section 4904 of the Crimes
Code (18 PA. C.S. 4904) relating to unswom falsification to authorities.
Date:
AND NOW, on this date, I
verified, and that there is probable cause for issuance I
(Magisteral utms
4ertify the gorr laint has been properly completed and
?f process. /
ming AuthorM (SEAL)
ROXANNE COSTOPOULOUS,
Plaintiff
V.
JOHNNY E. WRIGHT,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
NO. 01 - 6075 CIVIL TERM
FINAL ORDER OF COURT
Defendant's Name: Johnny Edward Wright
Defendant's Date of Birth: May 14, 1958
Defendant's Social Security Number:
Names of All Protected Persons, including Plaintiff and minor children: Roxanne Costopoulous
AND NOW, this /St day of November, 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. The following additional relief is granted as authorized by § 6108 of the Act:
Defendant, provided that he is accompanied by a constable or other local law enforcement
official, will be permitted to return to 132 West South Street, Apartment 1, Carlisle,
Pennsylvania, 17013, at a date and time to be agreed upon, and arranged by counsel for the
parties, in order to collect his personal belongings.
All fees and costs are waived.
A certified copy of this Order shall be provided to the police department where Plaintiff
resides and any other agency specified hereafter:
Carlisle Police Department
THIS ORDER SUPERCEDES [X] ANY PRIOR PFA ORDER AND [ ] ANY PRIOR ORDER
RELATING TO CHILD CUSTODY.
All provisions of this order shall expire in eighteen months, on May 1, 2003.
NOTICE TO THE DEFENDANT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE
CHARGE OF INDIRECT CRIMINALCONTEMPT WHICHIS PUNISHABLE BYA FINE
OF UP TO $1,000.00 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.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.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforcedby the police who have jurisdiction over the plaintiff s residence
OR any location where a violation of this order occurs OR where the defendant may be located. If
defendant violates Paragraphs I through 2 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 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.
BY THE COURT:
s ?.
If Bayley, J. CIET
This Order is entered pursuant to the consent of Plaintiff and Defendant:
oxanne Costopoulous, aintiff Johnny E. *tig?t be ndant
/kd) J '
Lily f-. Cheung, Certified egal Intern
for Plaintiff
Teri L. Henning, Supervise g Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013 7y "pe: M RECORD
: vi ..
(717) 243-2968 S5 e -,s r2 - 1.tfsTn; °t f ' r
?.W., : _:•, a li r-ei 1.
nr ?S
1n Trt .f
p s,
cS es y 0 1?, ? {.
('Jl?.
u .:..: .. .. .... : -:.•rvn:'Rm`. mc=,tasrse.tx€'e?d?+ewentiG€',ei??m„ ::
i%a®m _ _ 'S°?d$?Afl'1¢yP??4Ki.RPT+Tf}°S%I'WftA6kW?YFM9i A?31?` ?`tA . .. ..
ROXANNE COSTOPOULOS,
Plaintiff
V.
JOHNNY E. WRIGHT,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
NO. 01 - 6075 CIVIL TERM
MODIFIED FINAL ORDER OF COURT
Defendant's Name: Johnny Edward Wright
Defendant's Date of Birth: May 14, 1958
Defendant's Social Security Number: 122-52-2139
Names of All Protected Persons, including Plaintiff and minor children: Roxanne Costopoulos
AND NOW, this day o44D,' 2001, the court having jurisdiction over
the parties and the subject-matter, it is ADJUDGED and DECREED as follows:
Pursuant to Plaintiffs Petition for Modification, the Final Order of Court entered on
November 1, 2001, shall be modified and the following Modified Final Order of Court is
entered:
Plaintiff's request for a modified final protection order is granted.
1. Defendant shall not abuse, stalk, harass, or threaten the Plaintiff in any place where
she might be found.
2. This Order does not prevent contact between the parties.
3. The court costs and fees related to this action are waived.
4. A certified copy of this Order shall be provided to the Carlisle Police Department and
the Pennsylvania State Police.
5. This Order supersedes any prior PFA Order.
6. This Order applies immediately to Defendant and shall remain in effect until May 1,
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 $1,000.00 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S. §
6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL
PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE.
THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF
COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONWEALTH OF
PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. §2265. IF
YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS
ORDER YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER
THAT ACT. 18 U.S.C. §§ 2261 -2262.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over the plaintiffs residence OR any location where a
violation of this order occurs OR where the defendant may be located, shall enforce this order.
An arrest for violation of Paragraph 1 of this order may be without warrant, based solely on
probable cause, whether or not the violation is committed in the presence of the police. 23
Pa.C.S. § 6113.
Subsequent to an arrest, the police officer shall seize all weapons used or threatened to be
used during the violation of the protection order or during prior incidents of abuse. The Police
Department shall maintain possession of the weapons until further order of this Court.
When the defendant is placed under arrest for violation of the order, the defendant shall
be taken to the appropriate authority or authorities before whom defendant is to be arraigned. A
"Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police
officer OR the plaintiff. Plaintiffs presence and signature are not required to file the complaint.
If sufficient grounds for violation of this order are alleged, the defendant shall be
arraigned, bond set and both parties given notice of the date of the hearing.
"-6 `wuf
Date
BY TH$,OURT:
Edgar B. Bayley, J.
Distribution: Johnny E. Wright, Defendant - r'`) w
The Family Law Clinic, Counsel for Plaintiff
ec?'% c(IVBN'6 Family Lakt mlc'
r?.
C- P l/
?!0
Ri?
-TI
'
F
{
ROXANNE COSTOPOULOS,
Plaintiff
V.
JOHNNY E. WRIGHT,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
NO. 01 - 6075 CIVIL TERM
PETITION FOR MODIFICATION
Plaintiff, Roxanne Costopoulos, by and through her attorneys, the Family Law Clinic,
represents the following:
1. Plaintiff, Roxanne Costopoulos, and Defendant, Johnny Edward Wright, are in the
process of reconciling their differences.
2. Plaintiff desires that the Final Order of Court entered on November 1, 2001, be
modified to vacate paragraph 2, which permitted Defendant to return to 132 West South Street,
Apartment 1, Carlisle, Pennsylvania, 17013, to collect his belongings only if he was
accompanied by a constable or other local law enforcement official. Plaintiff proposes a new
paragraph 2, which allows for contact between the parties. The November 1, 2001 Final Order is
incorporated by reference and attached as Exhibit "A".
3. Plaintiff desires that all other provisions of the Final Order of Court entered on
November 1, 2001, remain in full force and effect.
WHEREFORE, Plaintiff requests that the Final Order of Court entered on November 1,
2001, be modified to reflect the above provisions, and that in all other respects, the Order remain
in full force and effect.
November 6, 2001 Respectfully Submitted,
L' eung
rtified Legal In ern
/'?Vl-
Ro ert E. Rains
Thomas M. Place
Teri L. Henning
Supervising Attorneys
THE FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
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. I understand that any false
statements are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn
falsification to authorities.
Date: /( l /
oxanne Costopoulos, Pl ' tiff
ROXANNE COSTOPOULOUS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
V. IN PROTECTION FROM ABUSE
JOHNNY E. WRIGHT,
Defendant NO. 01 - 6075 CIVIL TERM
FINAL ORDER OF COURT
Defendant's Name: Johnny Edward Wright
Defendant's Date of Birth: May 14, 1958
Defendant's Social Security Number:
Names of All Protected Persons, including Plaintiff and minor children: Roxanne Costopoulous
AND NOW, this 10- day of November, 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. The following additional relief is granted as authorized by § 6108 of the Act:
Defendant, provided that he is accompanied by a constable or other local law enforcement
official, will be permitted to return to 132 West South Street, Apartment 1, Carlisle,
Pennsylvania, 17013, at a date and time to be agreed upon, and arranged by counsel for the
parties, in order to collect his personal belongings.
Exhib1+ A
3. All fees and costs 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:
Carlisle Police Department
THIS ORDER SUPERCEDES [X] ANY PRIOR PFA ORDER AND [ ] ANY PRIOR ORDER
RELATING TO CHILD CUSTODY.
All provisions of this order shall expire in eighteen months, on May 1, 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 $1,000.00 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.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.
2
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 may be located. If
defendant violates Paragraphs 1 through 2 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 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.
BY THE COURT:
ayley, J.
C"1 hA-
This Order is entered pursuant to the consent of Plaintiff and Defendant:
oxanne Costopoulous, aintiff Johnny E. t, Defendant
Lily f-. Cheung, Certifie egal Intern
for Plaintiff
Teri L. Henning, Supervise g Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
(717) 243-2968 Ug ?FY FROM RECORQ
ill To Imony whereof, t here unto set my hand
3 end the ? ? ld Court at Carlisle, Pa,
protlwr?otarY
ROXANNE COSTOPOULOS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
V. IN PROTECTION FROM ABUSE
JOHNNY E. WRIGHT,
Defendant NO. 01 - 6075 CIVIL TERM
CERTIFICATE OF SERVICE
I, Lily L. Cheung, Certified Legal Intern, the Family Law Clinic, hereby certify that I am
serving a true and correct copy of a Petition for Modification on the defendant, Johnny Edward
Wright, at the following address, by regular U. S. Mail, this 6" day of November, 2001:
Cumberland County Prison
1101 Claremont Rd.
Carlisle, PA 17013
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717-243-2968
11/08/01 THU 09:18 FAX 717 240 6573 CUMB CO PROTHONOTARY C¢?1001
aasaaaaaassssssssssssasaaaa
sss MULTI IN REPORT saa
aaaaaaaaasaaassssssaasaaaaa
TX/RX NO
INCOMPLETE TX/RX
TRANSACTION OK
ERROR
2861
[ 0119P2490779 PSP
[ 0319P2405331 CP
10/10/01 WED 13.04 FAX 717 240 6573 COMB CO
sssssssssssxxssssssxsssstss
sss MULTI TN REPORT xss
ssssssssssssaa::xsxxsx?ssss
TX/RX NO
INCOMPLETE TX/RX
TRANSACTION OK
ERROR
2639
[ 01)9P2490779 PSP
I 0339P2405331 CP
001
11
OFFICE OF THE PROTHONOTARY
CUMBERLAND 0XINTY COUR7HWSE
ONE COURTHOUSE SQUARE
CARLISLE, PA. 17013-3387
(717) 240-6195
FAX (717) 240-6573
V I A T E L E C 0 P I E R
TO: PA STATE POLICE - Cem-t. I190cesi.
FAX q: 717-249-0779 '
FTCH CURTIS R. LONG
RE: PFA ORDERS
MESSAGE:
ROXANNE COSTOPOULOUS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION - LAW
JOHNNY WRIGHT,
Defendant NO. 01-6075 CIVIL TERM
ORDER OF COURT
AND NOW, this 7th day of November, 2001, the
defendant is adjudicated in contempt. Disposition is that he
undergo imprisonment in the Cumberland County Prison for time
served to 90 days and pay a fine of $100.00. He is released
immediately on condition that he be and remain on good behavior
and comply with all terms and conditions of the protection from
abuse order.
By the f era ,
y4
Edgar B
Michael W. Mervine, Esquire
Assistant District Attorney
John A. Abom, Esquire
For Defendant
Probation
CCP
Sheriff
prs
J.
0?
P'r1h2TARY
t.)I h'E'! I All 10% 43
CUMBER LIVivC COUNTY
PENNSYLVANIA
COMMONWEALTH
V
JOHNNY EDWARD WRIGHT
OTN:
IN RE: APPOINTMENT OF COUNSEL
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
01-6075 Civil
CHARGES:
Indirect Criminal Contempt
ORDER OF COURT
AND NOW, November 13, 2001, Jason P. Kutulakis, Esquire, is hereby
appointed to represent the defendant in the above-captioned matter.
By the Court,
Geo e V o er, P.J.
District Attorney
Jason P. Kutulakis, Esq.
Court Appointed for Defendant
Cumberland County Courthouse
Public Defender
:Id
C`rP^pO ?I-i??ol
._ . ,11
.+A3a. m ',.e.,,, iu - ? -«x_ i-.1?" ?JUie kY nsitaauwsa k s ..3v o-a.o:yMm6`?e?ma?3uY -? Y=,••Y?t3
f ....',
Tf
G,I N0" v -4
I' AIM 9:34
CUlra&Le%,NU Cf)U,%,7y
PPNWfVANA
'JUL 0 6 2007p^''
THERESA L. WHEATLEY,
Plaintiff .
v
RICHARD F. RUFRANO,
Defendant .
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 01-6075
IN CUSTODY
COURT ORDER
AND NOW, this day of July, 2007, the Conciliator being advised that the parties have
reached an agreement and that the Conciliator needs to take no further action, the
Conciliator relinquishes jurisdiction.
Hubert
C. Gilroy, Esquire
Conciliator
FAMESU2311\12321.W6entley v Padmo Order
10 :Z Wid 9- I G LOOZ