HomeMy WebLinkAbout01-06347
j, , , ,. , ~." , ~-"'"
-.
CHRISTINA JONES,
Plaintiff
: IN THE COURT OF COMMON PLEAS
vs.
: OF CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01 -{. 3Cf 7 CIVIL TERM
TORREY KEVIN JONES,
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 for the I sf:i day of November, at 3: 0 D in
Courtroom No.~ ofthe 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 ofup to $1,000.00 and/or up to six months in jail under 23 Pa.C.S.
~61l4. Violation may also subject you to prosecu,tion and criminal penalties under the
Pennsylvania Crimes Code. Under federal law, 18 V.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 HELD.
IF YOU CANNOT FIND A LAWYER, YOU MAY HAVE TO PROCEED WITHOUT
ONE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LffiERTY AVENUE
CARLISLE, PENNSYL VANIA 17013
TELEPHONE NUMBER: (717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the
court, please contact our office. AIl 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.
-~~ ~~~ ,,~' ~"
iii
'1
,~^fr".'
J-,c,,'-"
",
/
,7.',.. 'I
I-of'l; . ,
.. f Q
C,},
";,:
1..'/"_:','
"'/::?r::/':L:'::'",:
r'C;"1'16 "-' , ('"
I Vi V\)11 , ,,:;:'/();\Il~'
""'V1I/1 ' r
..
~.~j~""'J,: J!i::jm_r!Ji!(~1l1, ,,"'^'_ ~~,~~ ' ~~l ,",_'r'.,l.jjj_1\?T4''W~'7-l'Wf'-''>1liMl''''~'I'~~;~,'A~~, '!(]'_~nt,~_~.'r,!If~~_"___~$:'fl1:.Q!,.Ll,~~~!
-.
,..,
c.'o"';-"- ,.'.,.,.
" .~~, . '
, ,~ '.' "~. ~-,.,
10.; ii;;;:~
Christina Ann Jones,
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYL VANIA
Plaintiff
v,
Torrey Kevin Jones
: No. 01- (, 3'-17
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
.
Defendant
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: Torrey Kevin Jones
Defendant's Date of Birth is: December 24, 1968
Name(s) of All protected persons, including Plaintiff and minor children:
1. Christina Ann Jones
AND NOW, on 7th Day of November, 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. Pending the outcome of the fmal hearing in this matter, Plaintiff is awarded
temporary custody ofthe following minor child/ren:
1. Samantha Lee Jones
2, Hailey Catherine Jones
3. Donovan Charles Jones
fA,:
1-,
~, - ~".-" "; ,~-,
"'''. ,'. ;' -'-
~ -~ - 0'" ,,-~- 'C" ~iC
Until the final hearing, all contact between Defendant and the child/ren shall be
limited to the following:
Defendant shalI have periods of visitation at times and places that are
mutually agreed upon by the parties.
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.
3. A certified copy ofthis Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
Pennsylvania State Police
4. 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.
5. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL MAY 7, 2003 OR UNTIL OTHERWISE
MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND
HEARING,
NOTICE TO THE DEFENDANT
Defendant is hereby notified that violation ofthis Order may result in arrest for
indirect criminal contempt, which is punishable by a fme of up to $1,000.00 and/or
up to six months injaiL 23 Pa.C,S. S6114. Consent ofthe 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,
S6113, Defendant is further notified that violation ofthis Order may subject him/her
to state charges and penalties under the Pennsylvania Crimes Code and to federal
charges and penalties nnder the Violence Against Women Act, 18 U.S.C, SS2261-
2262,
NOTICE TO LAW ENFORCEMENT OFFICIALS
""'l
--
'. '<~.- ''',~." ,-, ^'~--- "",~.;-",;""'.' '-'~~-'H'---~""'::"'''(;~i
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, 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 oflaw
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 weapon/s are evidenc fa crime, in which
case, they shall remain with the law enforcement agency ose office made the
~l ~
\\J~
, Judge
1
". "1.#')01
,
Date
Distribution to~
Joan Carey
David A, Lopez CY.f.<~ to fM.pJ.. S
Attorneys for Plaintiff
MidPeun Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400 or
1-800-822-5288
FAXed and mailed to PSP - //.t) '7.b J . );J:J zP.M...
(L(J. '- 1\I1.l"1. S.
--';" ,- -/- -. "'_:~iI1~_!
PF AD Number: ZG 1362622C
Christina Ann Jones,
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYL VANIA
Plaintiff
v.
: No. 01- (,34')'
Torrey Kevin Jones
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
Defendant
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiff's name is:
Christina Ann Jones
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. Christina Ann Jones
4. Plaintiff's Address is: 12 Maple Avenue, Walnut Bottom, PA 17266
5, Defendant's Name is:
Torrey Kevin Jones
6. Defendant is believed to live at the following address:
123 Partridge Circle, Carlisle, P A 17013
7, Defendant's Date of Birth is:
December 24, 1968
:~
."
_. .] . ,'-", ..', ,_ - _.c '2"-
~,'__;-<, -c..
-,,-, -"'"
, -" -.,-i__'
. -,' '-ii'JUi~~
8. Defendant's Place of employment is:
Self-employed painter
9, Defendant is an adult.
10, The relationship between the Plaintiff and the Defendant is:
Spouse
Parents of the same children
II. The defendant has been involved in a criminal court action.
12, The defendant is not currently on probation / parole
13. Plaintiff and Defendant are the parents of the following minor child/ren:
a. Samantha Lee Jones
Age:8
Child's address is: 12 Maple Ave, Walnut Bottom, Pa 17266
b, Hailey Catherine Jones
Age:2
Child's address is: 12 Maple Ave, Walnut Bottom, Pa 17266
c, Donovan Charles Jones
Age:l
Child's address is: 12 Maple Ave, Walnut Bottom, Pa 17266
14. 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. Samantha Lee Jones
For the past 5 years, this child has lived with:
Christina and Torrey Jones - 439 First Street, Carlisle, PA-
4/93-12/95
Christina and Torrey Jones - 22 N. High Street, Newville, PA
12/95-6/98
Christina and Torrey Jones -12 Maple Ave, Walnut Bottom
6/98-10/28/01
Christina Jones and Barbara and Donald Fraker (Plaintiffs
.-~:
~ -
~,I
_' ",~"_,,l
'-.' "
" '-,hi' ~ .,c,>~,<E,,,
"'ll-M.-~'
parents)- 4141 Enola Road, Newville, PA 10/28/01-11/07/01 .
Christina Jones - 12 Maple Avenne, Walnut Bottom 11/07/01
b. Hailey Catherine Jones
For the past 5 years, this child has lived with:
Christina and Torrey Jones - 12 Maple Ave. Walnut Bottom,
Pa 3/99-10/28/01
Christina Jones and Barbara and Donald Fraker (plaintiffs
parents)- 4141 Enola Road, Newville, PA 10/28/01-11/07/01
Christina Jones - 12 Maple Avenue, Walnut Bottom 11/07/01
c. Donovan Charles Jones
For the past 5 years, this child has lived with:
Christina & Torrey Jones - 12 Maple Avenue, Walnut
Bottom, PA 9/00-10/28/01
Christina Jones and Barbara and Donald Fraker (plaintiffs
parents)- 4141 EnoIa Road, Newville, PA 10/28/01-11/07/01
Christina Jones -12 Maple Avenue, Walnut Bottom 11/07/01
15. The facts of the most recent incident of abuse are as follows:
On about Sunday, October 28, 2001 at approximately 6:30PM
location: 12 Maple Ave. Walnut Bottom, Pa 17266
To avoid arguing with Defendant, Plaintiff went into the bedroom, and
Defendant blocked the door with his body refusing to let her leave the room.
When Plaintiff was able to get past Defendant and while she was holding their
1 year old, Defendant shoved her, demanded that she put the child down and
leave the residence. Plaintiff went to the neighbors and telephoned the
Pennsylvania State Police. Defendant was arrested for simple assault and
harassment.
16, Prior incidents of abuse that the Defendant has committed against Plaintiff or the
minor child/ren, (including any threats, injuries, or incidents of stalking) are as
follows:
On or about October 27, 2001, Defendant grabbed Plaintiff by the shirt, threw
~.
,.1
_", ,_" o.
-"\ilf14li\:ti~
her onto the floor, and punched her in the stomach and about the \Jody sl!veral
times, while screaming at her. Defendant punched Plaintiff in the jaw' .
approximately 2 times, leaving bruises.
In or around August, 2001, Defendant shoved Plaintiff, grabbed her by the
shirt, and physically threw her out the door of the residence.
In or around July, 2001, Defendant screamed at Plaintiff, grabbed her by the
nightgown, threw her around the room, causing her to hit her head on the wall,
and threw her out the door of the residence, ripping her gown. Plaintiff
managed to get back into the house and slept in the children's room for the
night.
17, The police department( s) or law enforcement agencies that should be provided with
a copy ofthe protection order are:
Pennsylvania State Police
18, There is an immediate and present danger of further abuse from the Defendant.
19, The Defendant owes a duty of support to Plaintiff and/or minor child/ren,
20. 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, Award Plaintiff temporary custody of the minor child/ren and
place the following restrictions on contact between Defendant
and child/ren:
Defendant shall have periods of visitation with the children
at times and places that are mutually agreed upon by the
parties.
c. Order Defendant to pay temporary support to Plaintiff and/or the
minor child/ren, including medical support and payment of the
rent or mortgage on the residence.
d, Order Defendant to pay the costs ofthis action, including filing
and service fees.
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
:n
-
'~' ,,,.
.'.---, ^ Ie"""",;,. ,"-,'"-, -.' ,',.., -~- "'jjiti'
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:
J an Carey, Attorne
David Lopez, Attorney
MidPenn Legal Services
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
- ~'
~,;".;"~~~~' .
, ~.~
~~
.~i-
.'
~< '''''''''''~'ffi.,,:,
VERIFICATION
I verify that I am the Plaintiff 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: /1- 0(;; -0 I
~~
Christina Jones, PI intiff
';~~~~""'""",,","'~m"',,",
~
.~
~
,lll, , LL...._
. JJ
"c' '}- .," .'~ -
",E,,_\~"""'iWr1';<;,.!;l,'0.m**:___~tF.ii""'.0Ni~ .~i~~~Jtl:L!jI ~g~Jl!!r
_~,~V_ ~_,,>~.,.'" _. _~,_,,,,.,,,_"~ m ~",__'1l''''''''_,,"-''' _~ ,_~, "~ ">'<< =,_ ~_.~"'_,"> '~"'~"T ., ~_" ~~
t
~
-?
\
'""
G'
--
L':'"
-<
r::
~;(-,
)." ?-C~
.=;:
~'"
=<
1_;'-
n,:-.
n
,....
_r;r;':
,"""
''',.j
:~ ,...
-~
___-1
=.1
:::'J
-<
11/07/01 WED 12:2Z'FAX 717 240 6S73.
I, ~ "" _. " I'
-"
~","". "....... -u ["Jij~W;lli))._~J",-
CUi!IB CO PROTHONOTARY
141001
***************************
u* MULTI TN REPORT ***
**************~************
TX/RX NO
INCOMPLETE TX/RX
TRANSACTION OK
2860
[ 01]9p2490779
[ 03]9p2405331
[ 04]92438026
PSP
CP
LS
ERROR
..
,
OfFICE Of TIlE PRc:rrnrnarAAY
aJM8ERLANO CCXJNrY CXlURTHOOSE
ONE CXXJRTHOOSE SQUARE
CARLISLE. PA. 17013-3387
(717) 240-6195
fAX (717) 240-6573
V I ATE LEe 0 PIE R
TO: PI'. STATE POLICE - CellI. 1'''/)4($-:'. - M. Po J..S.
,
fAX .:
717-:;!49-0779
F'Ra'i: CURTIS R. LONG
1m: PFA ORDERS
MESSAGE:
. -L 00. Of PAGES (INCWDIIIIG CDVER SHEET)
This ~ is iub;,..l:1l rnly fi:r tte \.Ee of I:te irdividJ:ll cr 81tit;y b:l Wrid1 is is ,,11..!i:: 1, a-d Ill'ff
crntDin .infi':vIBtim.1tat is p::iY:iJJ:gad. o:nf:kB1t:ia1 Hrl emIP: fmn 6i....l....,u-e I.f'der >g?li.......1.. la4. [f
1:1"13 ~ of ti1is I, "W is rnI: tiE inlErde:l m:;ipient, }UI are IRmt rutifiErl ttat enj (lisslEnli.ret:.i.cn.
d.istril:ut::ir cr awing cC this corm.rucll':Jro .i!; st:rict:ly (Xd1ibitai. If \O.l te.e te:.ci\6l !Jus
<.':ClIllU1ic.,tirn in er:m:-. plaB3 roti.fY us ;itrm;rl.ialEJ.y W teleflne arl mb.Jrn tie Or:igiml". IT;g' to LS al
"1'
"I ",-,
- '~" ~---" ,-.
Christina Ann Jones,
Plaintiff
: In The Court of Common Pleas of
v.
: Cumberland County,
: Pennsylvania
Torrey Kevin Jones,
Defendant
: No. 01-6347 Civil Action
: Protection From Abuse
FINAL ORDER OF COURT
Defendant's Name is: Torrey Kevin Jones
Defendant's Date of Birth is: December 24,1968
Name(s) of All protected persons, including Plaintiff and minor children:
1. Christina Ann Jones
AND NOW, this 9th Day of November, 2001 the court having
jurisdiction over the parties and the subject-matter, it is ORDERED,
ADJUDGED and DECREED as follows:
Upon agreement ofthe 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:
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. Custody of the following minor children:
1. Samantha Lee Jones
2. Hailey Catherine Jones
3. Donovan Charles Jones
shall be as follows:
,:,;--"-,,j.-~>-i-;,;i~.,,:~,-:,,:.<,-,:~ f '"" ''-'Ii
~ '.,~ ' -
. Primary physical custody of the minor child/ren
is awarded to the Plaintiff.
. See attached Custody Order.
3. A certified copy of this Order shall be provided to the police
department where Plaintiff resides and any other agency specified
hereafter:
PENNSYL V ANlA STATE POLICE
4. THIS ORDER SUPERSEDES:
1. ANYPRIORPFAORDER
2. ANY PRIOR ORDER RELATING TO CHILD
CUSTODY
S. All provisions of this order shall expire on: May 9,2003
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. 96114. VIOLATION
MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL
PENAL TIES 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. 92265. 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 992261-
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. 9922(G), FOR POSSESSION,
TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFTICMLS
[~~
.,
",'
I~>' ",,_. : ,
- -j. '~ .
I~';'~;i~
- The police who have jurisdiction over the plaintiff's residence OR ally
location where a violation of this order occurs OR where the defendant
may be 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 ofthe police. 23 Pa.C.S. g6l13.
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 Sheriffs
Department 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. Plaintiff's 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.
-
Edgar . Bayley, Jufte
\.t~ 17 ."UIt>'
- Date
If entered pursuant to the consent of plaintiff and defendant:
N/i~ ~tl:/A../
Christina Jones, lamtJff
.~
~
Carey, Attorney for
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
Distribution to:
MidPenn Legal Services
Torrey Jones, Pro Se Defendant, 123 Partridge Circle, Carlisle, PA
Faxed & Mailed tdPSP
I
5~
.~. 1/-13-0 I
17013 ~ ~~
;r c, ",.c.'''',..."c,' "~",,,C"c"'.'UC, .'" ,', ,"h"',' ."" "
UJ, =~,,~..,
, ;."~ .,-",'1
"'''''''''""-'=;'''N '''>''~'f-.'~- "~-" r~";'''IYkSI-!r-'' '/""". H_"" ,:r""'''-~~'~
"nil'.' IT"
;-t:_
C' flG'"
j ,]
'v
{\ Ir_,~ P: '!~)
.,. \" "*l-.
r-,! 1",,: '!. ,--: ,~" ,.!" i" ,"~ I '!\' .
",0.,,,,.,,,,, '."l 'j~UIHY
PE[\]!'I}SYL\/!.,j\liA
"
.JJ~'3c"'~"""I1"f;'_;~-~":1:~-"'--",W""""'i';',;~rM"jj:~"*~!fi[fJnl~!~!HLJ~,~ ;lJ~,,- ;<,C1_" ".'''; '-y,".'[~I~T-;~-~
,
J" -,I'
'io' j,",-^" -,;,i,j,;""",.-c..Jj,-,,,:., _o"--~;'l'j;,,a.,,__',_~,~,;-,,. ':'0'_; ',' -. L-'~':_
Christina Jones,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 2001-6347
CIVIL TERM
Torrey Kevin Jones,
Defendant
: PROTECTION FROM ABUSE AND
: CUSTODY
CUSTODY ORDER
AND NOW, this
day of November, 2001, the following Order is entered by
consent of the parties with regard to custody of the parties' children, Samantha Lee Jones,
DOB 4/14/93, Hailey Catherine Jones, DOB 3/25/99, and Donovan Charles Jones, DOB
9/22/2000.
1. Plaintiff, hereinafter referred to as the mother, and Defendant, hereinafter
referred to as the father, shall share legal custody of the children.
2. The mother shall have primary physical custody of the children.
3. The father shall have partial custody of the children on alternating weekends
from Friday at 5:30 p.m. until Sunday at 5:30 p.m., and one day per week at a day and time to
be agreed upon by the parties.
4. The mother and father shall share the following holidays: New Years, Easter,
MemorialDay, July 4th, and Labor Day, Thanksgiving Day and Christmas Day at times to be
mutually agreed upon by the parties.
5. The mother and father shall have the right to one uninterrupted week of
vacation upon reasonable notice to the other parent and upon giving the other parent the
address and phone number where they can be reached.
5. The mother and father, by mutual agreement, may vary from this schedule at
any time, but this Order extends beyond the Protection From Abuse Order and remains in
effect nntil further Order of Court.
.@}
,...
I
"l'~, ,-" ,.",---. __,_,..,.,_;0, ,_ .,' ~" ,~_;__.\,,;:~ _,;.,,_ o",-~,_:i:;,-~- .,'::
-'I"),c1
6. The mother and father agree tliat eacn shall notify the other immediately of
medical emergencies which arise while the children are in that parent's care.
7. Neither party shall do anything which may estrange the children from the other
parent, or injure the opinion of the children as to the other parent or which may hamper the
free and natural development of the children's love or respect for the other parent.
By the Court,
Edgar B. Bayley, Judge
This Order is entered pursuant to the consent of Plaintiff and Defendant:
(!;i lz,{ dit /Y1 (, r.l /.L/
Christina Jones, Plain f
Tor2f~!~
oan Carey, Attorney for P
MidPenn Legal Services
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
io.:\,:
,
"
~~u'
L
,''i _wi', ^ '_i,:J
-'1-~~~~)-:
11/13/01 TUE 09:25 FAX 717 240 6573
, CUMB CO PROTHONOTARY
141001
, '
***************************
*** MULTI TN REPORT ***
***************************
TX/RX NO
INCOMPLETE TX/RX
TRANSACTION OK
2864
[ 01] 9p2490779
[ 03]9p2405331
[ 04]92438026
PSP
CP
LS
ERROR
,
,
OFFrCE Of WE PRarHrnarAAY
CUMBERLAND CXXJNfY cotIRWOOSE
ONE CCXJRTIiCXJSE SQUARE
CARLISLE, PA. 17013-3387
(717) 240-6195
FAX (717) 240-6573
V I ATE L E COP I E R
TO:
PI'. STATE POLICE -
C c~dltlt I
1It.,US. - ,",P.I..J.
FAX r:
717-249-0179
,
"
~: CURTIS R. LONG
RE: PFA ORDERS
MESSAGE::
7 00. OF PAGES (INCWDING OJIIER SHEET)
'!his IlESSJg:> is inlIrdrl rnly fur tte I.&:! rff. li1'l irdiviliDl II mtiqt to W1ic.h js js.o;. ~ :l. en:! !leY
crntiin infi:JLm;rtim.!tat is p:ivil.eg:d. o:.nfUntial Hrl BCBT{t: fm'n diF"1..... rre IllEr >g?11'"""1.. 1&1. rr
1:I-e ra:mr of this ~ is rot: tl-e inte'd;r:1 m::-ipi"lt. )OJ am ~ rutifia1 ltat enj d.is;eniret,:i!n,
d.istrilul;iro cr awirg of this o:roTU1io3tiO'l i!; strictl.y p:d1.iI:litlrl. If}Q.I taI.e w:ei\6l !JuS
COTIlUlic.r...iro in er:m:-. plm3e rd:iiy \B inmrliately tv te1ft:h:re an mb.Jrn tI-e cr::igiml. II~. f")" to L6 8!
-~~~ -~
....i........~.'.
,',
~"" --'--~t.fYI''-"'
SHERIFF'S RETURN - REGULAR
CASE NO: 2001-06347 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
JONES CHRISTINA
VS
JONES TORREY KEVIN
DOUGLAS DONS ON
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE
was served upon
JONES TORREY KEVIN
the
DEFENDANT
, at 1615:00 HOURS, on the 7th day of November, 2001
at 123 PARTRIDGE CIRCLE
CARLISLE, PA 17013
by handing to
TORREY K JONES
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
Service
Affidavit
Surcharge
So Answers:
18.00
3.25
.00
10.00
.00
31.25
.r~/~~
R. Thomas Kline
me this ~ e:::
day of
11/13/2001
LEGAL SERVICES 0
By: O~ ~
Deputy Sheriff
Sworn and Subscribed to before
'11 tr7 '-' AAA j~ " .:2-ihJ / A. D .
~ 0, )uJ#.v J~'f
rothonotary I
-,".
~,J""",~"""",._",~,
-~ - ."."....
-"""':_y-';;"'_',I-:_."--4,,,-~'fuJdffri"-M~l1niijfiL_1il'r.~~;;->ro:;;'ii",ge",.d'~~'~
~
. . ~ffi',?O~.-. ",."'" _ m '"..,~_ ~~. ,."' '__~~_"""_'C_"--"~~'''' '"" .-,.~. ",'. _"'. ,~ ,~~ ...", .' _, .,,'=_,~~_, - "~,..".. .,_ ""',,", '-~
r~lli_1iIl
-"~
"._~
--
1<.-,'
"L
" ,-'c"
--.'.. -,'l>-' ~- ,"'-i" "-'"", ,,; - '-_., _i' -"'--.i'",,,,-- -';;;';""w";';' _, '-' ""_~_I~:,;;:
Christina Ann Jones,
Plaintiff
: In The-Court of Common Pleas of
v.
: Cumberland County,
: Pennsylvania
Torrey Kevin Jones,
Defendant
: No. 01-6347 Civil Action
: Protection From Abuse
: No. 01-6347
.
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
ORDER TO V ACAT:E
AND NOW, this: 4th Day of December, 2001, upon Plaintiffs motion to
withdraw or discontinue this action,
1. This matter is dismissed without prejudice.
2. Costs of this proceeding are waived.
3. The Final Order (Filed on Nov 13, 2001) is hereby vacated.
g . Bayley
O~ III ~(
I' Date
Distribution to: jJ ~77~
Legal Services L-
Torrey Jones, Defendant . . .s
faxed & Mailed to pSP I k I / -0 I RX:
~
)D8lI
IllBt ~_~
.'''~~--_H''= ""__,""_ i,-- _~_,,',', "--"''''''_'"
""~"_,,,,._,l'1!I!!~fI
"_1
,... -~ r..
\1 _
'n_"'~~=_ '''~, _ ~,. ,_,
" ~"'Ii
'_'1
,
!',
-)fFPS
p';-\
. "
\: \u,
r'., '~
\"IU;'"
"< l'J"'JNTY
1:',n'1 \' ,,' >~
:~~I':;'\ i~:,';!;:', i'l\l,~.N,lll\
t'""C\\.1 '-.0 \ ~.I .1
-m:~14,lI_J""__,, _, L. ,L:!l!~~~~'f;:J!'r+..ifP,{-,.",_,,~I!;:;;"J:',,~j,jRi"'-'f.'~'.,m,-'"~~_~~'lo~~~~;~-', - 1..~~_ - ,UW!~l )~~~?
~ "'
~" "J___~_'_,,-.' ...',.. < _ -" ,"""",O~'J_"_;- _' ~"
'--:~'; ~<~:
'ir'"'iei
~
Christina Ann Jones,
: IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: NO. 01-6347
CNIL TERM
Torrey Kevin Jones,
Defendant
: PROTECTION FROM ABUSE
: AND CUSTODY
PETITION TO VACATE ORDER AND WITHDRAW ACTION
Plaintiff requests the Court vacate the Final Protection From Abuse Order in the above-
captioned case on the grounds that:
1. A Temporary Protection Order was issued by this Court on November 7, 2001,
scheduling a hearing for November 15,2001, at 3:00 p.m.
2. The parties executed an agreement and a protection order was entered on
November 9,2001.
3. At this time Plaintiff requests that the Final Order entered on November 9, 2001,
be vacated without prejudice.
4. A certified copy of this Order of Court will be provided to the East Pennsboro
Township Police Department by the attorney for Plaintiff.
WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate the
Order without prejudice.
Respectfully submitted,
n Carey, Attorney ti Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
.- -,~.'"~ ~-,
-
~
-'",~'w~>- - ,__;,'-_;,i", ,:;:""';",:: ;'.,If.,' k":'-':-::":>"':":f+;
.
VERIFICATION
I verifY that I am the plaintiff as designated in the present action and that the facts and
statements contained 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.
Date: /;;'-0'1- 0/ ~~~{L~
Christina Ann Jones, Plaintiff
#~~~r1lfi1r~")~~:ft1~~~~~~Wi":i!I,,":~""!<"iiffiQ;.Jill-It;'~~~fJj'~ \~, J1 ,,'\_i~ -",-j
~n
0_'
~.'^ ," .',~,"W,~~_."_~ ,'>""",_,.~
,
"'. '[.' '~~rllllJi'.j'.--' "[,, ,~ ";,,".!,-,"-',- ",,",,' '-.' ~-,
C)
r"
~::
"1:)[_1]
1'1lrr!
-c? -
tse--
'C;
~-
~~
::<
__ C. ,,.''',",~,, .,' ,~-,,_, .~," ~ ~L~"." -,
...
.,-- ,--'~-,,- "'.~\
(:_',~I
~~
c;
-,'
-:...\1
f.",)
:~
?~
-<
7JH
_J..~
--
-
L~,. ~.
~~ <,
.. " ,~O
~"",,,-'-'
='-' , '-'ID~;'
12/11/01 WE 14:23 FAX 717" 240 6573
CUMB CO PROTHONOTARY
141001
***************************
*** MULTI TN REPORT ***
***************************
TXlRX NO
INCOMPLETE TX/RX
TRANSACTION OK
2899
[ 03] 9p2405331
[ 01] 9p2490779
[ 04]92438026
CP
PSP
LS
ERROR
OFfICE Of THE PROrHrnarARY
aJM8ERLAND axJNTy COURTHaJSE
ONE COURTHCXJSE SQUARE
CARLISLE, PA. 17013-3387
(717) 240-6195
FAX (717) 240-6573
V I ATE LEe 0 PIE R
TO:
PA STATE POLICE. reNlIb,'
f'~r.t' US.
_ M.I-i.. S.
F'N( ":
717-249-0779
.-
F'RCM ;
CURTIS R. LONG
RE:
PFA ORDERS
MESSAGE :
LJ _ 00. OF' PAGES (IOCWOING COVER SHEET)
This I'" --.y is intm:kl rnly fi::a- tte use of tte irdiv.id.Bl cr mtiqf Iv Wrid1 is is ..'b n:l. a-d Ill'ff
CO'IWn :infi:mmtirn !:tat: is p:;.~, anf':ida1t.ial <ni a<<;J'(I,'ll: fmn di....l.....,Q3a I.l1k >g?1i.......l.. liw. [f
ti-.:: .reek d tf1is ~ is rot tiE int:ert:kl t:R"ip;ent;, \O.l ace te:r;by rct:if.ia1 that cry dJ!,setr\irot:.i.cn.
distrihJti.rn oc o:p,rir;;J cC this a:mnn.icatiO'l ~ strictly (XdribilBi. It ~ l'eI.e re:ei1.6:l ltus
o::rmuill:.~tim in er:r;r. p\efEE rc;t.i.ty \S inm:l:liolEly W ~:re Hrl teWrn tle a:igirelll......-'""T to lS al
tte of"o,.-. a:ihess via tiE ~!.S. p::I':;ta1 seruw. 'Ih:rdc \O.l.
.