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LOUANN STACY SPEESE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
vs.
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01- IpCJV/
CIVIL TERM
HENRY HAMMOND STANLEY,
Defendant
: PROTECTION FROM ABUSE AND CUSTODY
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may
proceed against you and a FINAL Order may be entered against you granting the relief requested in the
Petition. In particular, you may be evicted from your residence and lose other important rights.
A hearing on this matter is scheduled on the ~ 6bay of November, 2001, at II :/54 .m., in
Courtroom No.2 on the 4th Floor ofthe Cumberland County Courthouse, 1 Courthouse Square,
Carlisle, Pennsylvania.
You MUST obey the Order that is attached until it is modified or terminated by the court after notice
and hearing. If you disobey this Order, the police may arrest you. Violation ofthis Order may subject you
to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six
months in jail under 23 Pa.C.S. g6114. Violation may also subject you to prosecution and criminal penalties
under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. g2265, 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. g 2261-2262.
You should take this paper to your lawyer at once. You have the right to have a lawyer represent
you at the hearing. The court will not, however, appoint a lawyer for you. If you do not have a lawyer or
cannot afford one, go to or telephone the office set forth below to find out where you can get legal help. If
you cannot find a lawyer, you may have to proceed without one.
CUMBERLAND COUNTY BAR ASSOCIATION
2 Liberty Avenue, Carlisle, Pennsylvania 17013
Telephone Number: (717)249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is reqnired 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.
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LOUANN STACY SPEESE,
Plaintiff
: In The Court of Common Pleas of
: CUMBERLAND County,
v.
: Pennsylvania
: Civil Action - Law
HENRY HAMMOND STANLEY,
Defendant
. 0\
; No. 01- cPt)
: Protection From Abuse and
: Custody
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: HENRY HAMMOND STANLEY
Defendant's Date of Birth is: November 9, 1954
Defendant's Social Security Number is: 224-98-2554
Name(s) of All protected persons, including Plaintiff and minor children:
1. LOUANN STACY SPEESE
AND NOW, on 15tl1 Day of November, 2001 upon consideration of the attached
Petition for Protection from Abuse, the court hereby enters the following Temporary
Order:
1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in
any place where they might be found.
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2. Pending the outcome of the fmal hearing in this matter, Plaintiff is awarded
temporary custody of the following minor childlren:
1. DIANA LOUANN STANLEY
2. HANNAH ELIZABETH STANLEY
Until the fInal hearing, all contact between Defendant and the child1ren shall be
limited to the following:
Defendant may visit the parties' minor children, DIANA LOUANN
STANLEY AND HANNAH ELIZABETH STANLEY, on dates and at times
mutually agreed by the parties.
The local law enforcement agency in the jurisdiction where the childlren are
located shall ensure that the childlren are placed in the care and control of the
Plaintiff in accordance with the terms of this Order.
3. The following additional relief is granted:
Defendant is enjoined from damaging or destroying any property jointly
owned by the parties or owned solely by Plaintiff.
4. A certifIed copy of this Order shall be provided to the police department where
Plaintiff resides and any other agency specifIed hereafter:
SmREMANSTOWN POLICE DEPARTMENT
HAMPDEN TOWNSHIP POLICE DEPARTMENT
5. The sheriff, police or other law enforcement agencies are directed to serve the
Defendant with a copy of the Petition, any Order issued, and the Order for
Hearing without prepayment of costs. The Petitioner will inform the designated
authority of any addresses, other than the Defendant's residence, where Defendant
can be served. The Prothonotary is directed to file this Petition and Order without
prepayment of costs.
6. TIDS ORDER SUPERSEDES
ANY PRIOR PFA ORDER
7. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL MAY 15, 2003 OR UNTIL OTHERWISE
MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND
HEARING.
NOTICE TO THE DEFENDANT
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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 injail. 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.
~6l13. 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 D.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 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 ofthis 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 weapon/s are evidence of a crime, in which
case, they shall remain with the law enforcement agency w er made the
arrest. /
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Distribution to:
David A. Lopez, Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row, Carlisle, PA 17013
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PFAD Number: LF1359813Q
LOUANN STACY SPEESE,
Plaintiff
: In The Court of Common Pleas of
: CUMBERLAND County,
v.
: Pennsylvania
HENRY HAMMOND STANLEY,
Defendant
: Civil Action - Law
: No. 01- (p ,>0 I
: Protection From Abuse and
: Custody
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiff's name is:
LOUANNSTACYSPEESE
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. LOUANN STACY SPEESE
4. Plaintiff's Address is: 110 East Main Street, 1st Floor, Shiremanstown, PA 17011
5. Defendant's Name is:
HENRY HAMMOND STANLEY
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6. Defendant's address is:
unknown.
7. Defendant's Social Security Number is:
224-98-2554
8. Defendant's Date of Birth is:
November 9,1954
9. Defendant's Place of employment is:
Owner/operator of H & S Paving, P.O. Box 388, Carlisle, P A 17013. Cell phone:
(717) 608-8784.
10. Defendant is an adult.
11. The relationship between the Plaintiff and the Defendant is:
Parents of the same children
Current or former sexual/intimate partner
12. The defendant has beeu involved in a criminal court action.
13. Plaintiff and Defendant are the parents of the following minor child/ren:
a. DIANA LOUANN STANLEY
Age: 4 years old
Child's address is: 110 East Main Street, Shiremanstown, P A 17011
b. HANNAH ELIZABETH STANLEY
Age:16 months old
Child's address is: 110 East Main Street, Shiremanstown, P A 17011
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:
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a. DIANA LOUANN STANLEY
For the past 5 years, this child has lived with:
Plaintiff and Diana's siblings, Hannah Elizabeth Stanley, and Breanna Marie
McCloskey, at 110 East Main Street, 1st Floor, Shiremanstown, P A, from late
August 2001, to the present.
Plaintiff, Hannah, and Breanna, at Pine Ridge Estates, 7 Pine Road, Apt. 502,
Mt. Holly Springs, PA, from June 16, 2000, to late August 2001.
Plaintiff and Breanna, at Pine Ridge Estates, 7 Pine Road, Apt. 502, Mt. Holly
Springs, PA, from 1997, to June 15, 2000.
b. HANNAH ELIZABETH STANLEY
For the past 5 years, this child has lived with:
Plaintiff and Hannah's siblings, Diana Louann Stanley, and Breanna Marie
McCloskey, at 110 East Main Street, 1st Floor, Shiremanstown, PA, from late
August 2001, to the present.
Plaintiff, Diana, and Breanna, at Pine Ridge Estates, 7 Pine Road, Apt. 502,
Mt. Holly Springs, PA, from the date of Hannah's birth on June 16, 2000, to
late Angust 2001.
15. The following other minor childJren presently live with Plaintiff:
a. BREANNA MARIE McCLOSKEY
Age: 8 yrs. old
The Plaintiffs relationship to this child is:
mother
16. The facts of the most recent incident of abuse are as follows:
On about Sunday, October 21, 2001
location: Mechanicsburg, Hampden Township, Pennsylvania
Defendant grabbed Plaintiffs car keys from her hand, pulled her hair, and repeatedly punched
and slapped her about her face and arm. Plaintiff got away from Defendant and telephoned 911
for help. The Hampden Township Police responded. Defendant was arrested, charged him with
simple assault and harassment, and taken to Cumberland County Prison. Plaintiff sought
medical attention for injuries she sustained as a result of this incident which included, but were
not limited to, bruising, swelling and soreness about her eyes, nose, fmger, and her arm;
lacerations near her eye and nose; her finger and her nose were broken, and a clump of hair was
pulled out of her scalp. A hearing on the criminal charges was held before District Justice
Thomas R. Placey on November 7, 2001, at 2:00 p.m., and the charges were bound over for trial.
17. The police department(s) or law enforcement agencies that should be provided with a copy of the
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protection order are:
SmREMANSTOWN POLICE DEPARTMENT
HAMPDEN TOWNSIDP POLICE DEPARTMENT
18. There is an immediate and present danger of further abuse from the Defendant.
19. Plaintiff has suffered out-of-pocket fmanciallosses as a result of the abuse described above. Those
losses are:
any costs incurred by Plaintiff that were not paid by medical insurance, for medical treatment
she received for injuries she sustained as a result of the incident which occured on or about
October 21, 2001.
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 may visit the parties' minor children, DIANA LOUANN STANLEY
AND HANNAH ELIZABETH STANLEY, on dates and at times mutually
agreed by the parties.
c. Direct Defendant to pay Plaintiff for the reasonable financial losses suffered as the
result of the abuse, to be determined at the hearing.
d. Order Defendant to pay the costs of this action, including filing and service fees.
e. Order the following additional relief, not listed above:
Enjoin Defendant from damaging or destroying any property jointly owned by
the parties or owned solely by Plaintiff.
Order Defendant to submit to a drug and alcohol evaluation through
Cumberland County Dni.gandAIcohol Services, 36 West High Street, 3rd
Floor, Carlisle, PA (717) 240-6300 or 697-0371, and follow and successfully
complete any and all recommendations for treatment.
Order Defendant to enroll in one of the batterers programs listed below,
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successfully complete the 26-week program, and follow and complete any
related recommendations for treatment made by the program staff. Defendant
shall be responsible for the payment of all costs related to enrolling and
attending the program and for any costs for additional treatment
recommended by staff.
Choices at Tressler Counseling Services
940 Century Drive, Mechanicsburg, P A
(717) 795-0330
Mosaic Partnership Counseling Services
2001 North Front Street, Harrisburg, PA
(717) 234-6438
f. Grant such other relief as the court deems appropriate,
g. Order the police or other law enforcement agency to serve the Defendant with a
copy of this Petition, any Order issued, and the Order for Hearing. The petitioner
will inform the designated authority of any addresses, other than the Defendant's
residence, where Defendant can be served.
David A. Lopez, Esq.
Agency: Midpenn Legal Services
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400 or
1-800-822-5288
Respectfully Submitted by:
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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 unswom
falsification to authorities
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ClJMBERLAND 0'XJlITI'Y OOIJRTHOOSE
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CARLISLE. PA. 17013-3387
(717) ~40-6195
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717-249-0779
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CURTIS R. LONG
RE:
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MESSAGE :
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LOUANN STACY SPEESE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: NO. 01-6501 CIVIL TERM
HENRY HAMMOND STANLEY,
Defendant
: Protection From Abuse and Custody
AFFIDAVIT OF SERVICE
I, Brian S. Walk, hereby certify that on November tL, 2001, I did accept service of a
certified copy ofthe above-captioned Notice of Hearing, Temporary Protection From Abuse Order
and Petition for Protection From Abuse on behalf of Defendant, Henry Hammond Stanley, at my law
office located at 108-112 Walnut Street, Harrisburg, Dauphin County, PA 17101.
Date: /)-/9- 0/
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LOUANN STACY SPEESE,
Plaintiff
: In The Court of Common Pleas of
: CUMBERLAND
: County,Pennsylvania
v.
: Civil Action - Law
.
HENRY HAMMOND STANLEY,
Defendant
: Protection Prom Abuse and
: Custody
.
: No. 01-6501'
CONTINUED TEMPORARY ORDER
AND NOW, this 26th Day of November, 2001, pursuant to 23 Pa.C.S. S6107(c), the terms
and conditions ofthe Temporary Order issued on 15th Day of November, 2001, in the
above-captioned case are hereby continued in full force and effect. This order is in effect
until May 15,2003.
A hearing on this matter is scheduled for December 10,2001, at 1O:30AM in Courtroom 2
ofthe Cumberland County Courthouse, One Courthouse Square, Carlisle.
BY
Distribution To:
MidPenn Legal Services
Paxed&MailedtoPSP, CoP. LS, IHl?-OI
Brian Walk, Attorne'y for Defendant
108-112 Walnut Street
Harrisburg, PA 17101
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LOUANN STACY SPEESE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: NO. 01-6501 CIVIL TERM
HENRY HAMMOND STANLEY,
Defendant
: Protection From Abuse and Custody
MOTION FOR CONTINUANCE
Plaintiff, Louann Speese, 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 November
15,2001, scheduling a hearing for November 26, 2001, at 11:15 a.m.
2. The defendant's attorney, Brian Walk, located at 1 08-112 Walnut Street, Harrisburg,
Pennsylvania, accepted service on behalf of the defendant, Henry H. Stanley.
3. The parties agree, by and through their respective counsel, that the hearing be
rescheduled to afford them time to execute a Consent Agreement.
4. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect
for a period of18 months from the date it was entered, through May 15, 2003, or until further Order
of Court, whichever comes first.
WHEREFORE, Plaintiff requests that the Court grant this Motion and reschedule this matter
for hearing, and that the Temporary Protection From Abuse Order remain in effect for a period of 18
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months from the date it was entered, through May 15, 2003, or until further Order of Court,
whichever comes fIrst.
David Lopez, Attorney for Plain
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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11/27/01 TUE 09:33 FAX 717 240 6573
CUMB CO PROTHONOTARY
1i!I001
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*.... MULTI TN REPORT ....*
***************************
TX/RX NO
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OfFICE: or 1liE PflO'fHQ-.lCYfARY
aJMBERLAND COJNrY COUR'IHaJSE
OOE CCURTHaJSE SQUARE
CARLISLE. PA. 17013-3387
(717) 240-6195
FAX (717) 240-6573
V I ATE LEe 0 pIE R
FAX #:
PA STATE POLICE .. e~4111i,,1
717-249-0779
1'4.t us.
_ M.I'.I...S.
TO:
PRCN:
CURTIS R. LONG
RE:
PFA ORDERS
MESSAGE :
LJ r-o. OF PAGES (INCr..uoING CI:lVER SHEET)
'This - iJ' is hlte.:bJ ally fix' tte 1.00 of tte :irdi~ a: mtiq- In Wlid1 is is nJl. 'I, ;nl nay
anlLlin infi:KIral:irn tmt: is ~, o:nfifuntial a-d e<aTP: ftt:m ni.,....l"",.ce utE;- '{PH....nlp lao1. rf
I:l~ rmk of this ITe "T is rot tIe inteni9:1 re:::ipimt, ~ are l'a:'€by rotifiB:I th!lt i!Cfj ~ticn.
distri.b.l\:.1o oc c;q;ying af this c:xrnn:t1icatim i'; $\:rictly IIDWitrd. If)'O.\ ta>.e re:ei\<3d tlus
a:mnnir.:r..im in etP.;r, plee3e rd;i{'y U> irrm'diat:ely ~ tE.l.eI;:hTe ;nl ret\,lrn tie a::ig:irBl1l "'T to l.S Hl
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LOUANN STACY SPEESE,
Plaintiff
: In The Court of Common Pleas of
: CUMBERLAND County
: Pennsylvania
v.
: Civil Action - Law
: No. 01-6501
HENRY HAMMOND STANLEY,
Defendant
: Protection From Abuse and
: Custody
FINAL ORDER OF COURT
Defendant's Name is: HENRY HAMMOND STANLEY
Defendant's Date of Birth is: November 9, 1954
Defendant's Social Security Number is: 224-98-2554
Name(s) of All protected persons, including Plaintiff and minor children:
1. LOUANN STACY SPEESE
AND NOW, this 10th Day of December, 2001 the court having jurisdiction over the
parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as
follows:
Plaintiff, Louann Stacy Speese, is represented by David A. Lopez ofMidPenn Legal
Services; Defendant, Henry Hammond Stanley, is represented by Bryan S. Walk,
Attorney at Law.
Defendant, although agreeing to the terms of this Order, does not admit the
allegations made in the Petition.
Plaintiffs request for a final protection order is granted.
':,
-
1-,
'^t_il~'
- Co' ~~~
". - -." ff6':' -.\' '~';~
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. DIANA LOUANN STANLEY
2. HANNAH ELIZABETH STANLEY
shall be as follows:
. Primary physical custody of the minor child/ren is awarded
to the Plaintiff.
. Defendant shall have visits with th,e parties' minor children,
DIANA LOUANN STANLEY and'HANNAH ELIZABETH
STANLEY, on dates and at times mutually agreed by the
parties.
3. The following additional relief is granted as authorized by 96108 of the Act:
Defendant is enjoined from damaging or destroying any property jointly
owned by the parties or owned solely by Plaintiff.
The court costs and fees are waived.
Within 7 days ofthe entry ofthis Order, Defendant shall contact Cumberland
County Drug and Alcohol Services and schedule an intake appointment.
Defendant shall submit to a drug and alcohol evaluation throngh Cumberland
County D & A Services, and follow and successfully complete any and all
recommendations for treatment by staff. Defendant shall be finaucially
responsible for any costs related to treatment.
Cumberland County Drug & Alcohol Services
36 West High Street, Carlisle, P A 17013
(717) 240-6300 or 697-0371
Within 7 days of the entry ofthis Order, Defendant shall contact one of the
barterer's programs listed below and schedule an intake appointment.
Defendant shall attend and successfully complete the 26-week batterer's
program, and, in addition, follow and complete any related recommendations
for ongoing treatment made by the program staff. Defendant shall be
financially responsible for any costs related to enrolling and attending the
program and any additional costs for ougoing treatment recommended by
staff.
~1
tnl
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~-,:""-,~'~I
. .
Choices (batterer's program)
Tressler Counseling Services
940 Century Drive, Mechanicsburg, P A 17055
(717) 795-0330
Mosaic Partnership Counseling Services
2001 North Front Street, Harrisburg, PA 17101
(717) 234-6438
4. Defendant shall pay (costs not billed as of entry of this Order) to Plaintiff as
compensation for Plaintiff's out-of-pocket losses, which are as follows:
any costs not covered by insurance which Plaintiff incurred for medical
treatment she received for injuries she sustained as a result of the incident
which occured on or about October 21, 2001. Defendant shall pay the costs
directly to the service provider{s) within 30 days of receipt of the billing
statement(s) from Plaintiff.
5. A certified copy ofthis Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
SmREMANSTOWN POLICE DEPARTMENT
HAMPDEN TOWNSmP POLICE DEPARTMENT
6. THIS ORDER SUPERSEDES:
1. ANYPRIORPFAORDER
2. ANY PRIOR ORDER RELATING TO CHILD CUSTODY
7. All provisions of this order shall expire on: June 11, 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 PAC.S. ~61l4. VIOLATION MAY ALSO SUBJECT YOU TO
PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA
CRIMES CODE.
>,
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- -""- - -', --'-_-.',",
-, - - ,,,--,-,
l:"-i'(~-'- JIit'u:"i:'
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 ~92261-
2262. IF THE BRADY INDICATOR PARAGRAPH APPEARS IN THE ORDER,
YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES
UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT, 18 U.S.C.
~922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR
AMMUNITION,
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over the plaintiff's 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 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.S. ~6113.
Subsequent to arrest, the police officer shall seize all weapons used or threatened to
be used during the violation of the protection order or during prior incidents of abuse.
The shall maintain possession of the weapons until further order of this Court.
When the defendant is placed under arrest for violation ofthis 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
~ ~ bond set~t:iespi~pOtiCe Ofth: d~~Ofthe . g.
tWlOfl~ c.p LSBytlre
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R'Ks
avid A, Lopez, Attome or a ntiff
MidPenn Legal Services
8 Irvine Row, Carlisle, PA 17013
B alk, Attorney for Defendant
1 2 Walnut Street, Harrisburg, PA 17101
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12/11/01
TUE 09:57 FAX 717 240 6573
CUMB CO PROTHONOTARY
~001
***************************
*** MULTI TN REPORT ***
* $: * $: $: $: $::$: $: $::11::11::11::11::11:::1::11: $: $::11: $: *::1: $:-* $: *
TKIRX NO
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2894
[ 01] 9p2490779
[ 03]9p2405331
[ 04]92438026
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ERROR
,
,
OFFICE Of THE PRarHoo:::rrAAY
OJM8ERLAND caJNI'Y OOUR'IHOOSE
ONE COURTHOOSB SQUARE
CARLISLE, PA. 17013-3387
(717) 240-6195
FAX (717) 240-6573
v I ATE LEe 0 PIE R
'10: Pll. STATE POLICE - Ce,,". PwfJ4tS-;.. M. (J. J...S.
.-
FAX ":
717-249-0779
FRCM: CURTIS R. LONG
RE; PFA ORDERS
MESSAGE:
-1<-.
00_ OF PAGES (INCUJDING COVER SHEI?I')
Thls II 1~' is inunBl a\ly fir tte UlC of tte irdivid..e1 <r IDti~ In..rum is is ",n,: i, en! m;I'f
o::ntain :init:metiO'l \:tat is p:ivilEg;rl. cmt::ideJtial ad e<atpl: fi:on <.1j.....l.-...1UO mEr "{'PHI">h]", low. If
tl., ~ ri.'. this ~ is rot t:I-e intelki a:cipimt. yw are ~ mtifiJrl th3t <n/ ~ti01,
d.ist:rih.rt:i< cr a:Pld.r~ of this CJ:/lIIU'lio:rtim lli strictly prltibitJ.'.d. If yw trn.e re:;ei\B:l tius
ITmlUUf,r.Jro in err;r, pl.EeSe rotify us imre:l.iately ty tel.eJ;h~re m:l return lie adg;irelll_:: f"'J' to lB at
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LOUANN STACY SPEESE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
Ys.
: CUMBERLAND COUNTY, PENNSYL VANIA
: NO. 01-6501 CIVIL TERM
HENRY HAMMOND STANLEY,
Defendant
: Protection From Abuse and Custody
ORDER OF COURT
AND NOW, this h day 0~2002, upon consideration of the attached Petition,
the Final Order of Court in the above-captioned case entered on December 10,2001, is hereby
modified to vacate the portion of paragraph 3, which required Defendant to attend a batterer's
program. In all otherrespects, the Final Order of Court entered on December 10, 2001, remains in
full force and effect.
/
I
/
David A. Lopez \ \ \ \
Joan Carey- na..nd€:d peR.':>OOa. IV
Attorneys for Plaintiff 0
MIDPENN LEGAL SERVICES
8 Irvine Row
Carlisle, P A 17013
>
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RP
Brian A. Walk
Attorney for Defendant
112 Walnut Street
Harrisburg, P A 17101
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LOUANN STACY SPEESE,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
vs.
: CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 01-6501 CIVIL TERM
HENRY HAMMOND STANLEY,
Defendant
: Protection From Abuse and Custody
PETITION TO MODIFY
ORDER OF COURT
Plaintiff, Louann Stacy Speese, by and through her attorneys, David A. Lopez and Joan
Carey of MidPenn Legal Services requests that the Court modifY the Final Protection Order in the
above-captioned case as follows:
1. A Final Protection Order, including custody, was entered on December 10, 2001, by
agreement ofthe parties.
2. Plaintiff desires that the Final Order of Court be modified to vacate the portion of
paragraph 3, which requires Defendant to attend a batterers program.
3. Plaintiff desires that all other provisions of the Final Order of Court entered on
December 10,2001, remain in full force and effect.
WHEREFORE, Plaintiff requests that the Final Order of Court entered on
December 10, 2001, be modified to reflect the above provision, and that in all other respects, the
Order remain in full force and effect.
Respectfully submitted,
~L~
Joan Carey
Attorneys for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, P A 17013
~
'ON <_~
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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. g4904, relating
to unsworn falsification to authorities.
Dated: ~~/z;r
.
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"
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LOUANN STACY SPEESE,
Plaintiff
: In The Court of Common Pleas of
: CUMBERLAND County
: Pennsylvania
v.
: Civil Action - Law
: No. 01-6501
HENRY HAMMOND STANLEY,
Defendant
: Protection From Abuse and
: Custody
FINAL ORDER OF COURT
Defendant's Name is: HENRY HAMMOND STANLEY
Defendant's Date of Birth is: November 9,1954
Defendant's Social Security Number is: 224-98-2554
Name( s) of All protected persons, including Plaintiff and minor children:
1. LOUANN STACY SPEESE
AND NOW, this 10th Day of December, 2001 the court having jurisdiction over the
parties and the subject-matter, it is ORDERED, ADJUDGED and DECREED as
follows:
Plaintiff, Louann Stacy Speese, is represented by David A. Lopez ofMidPenn Legal
Services; Defendant, Henry Hammond Stanley, is represented by Bryan S. Walk,
Attorney at Law.
Defendant, although agreeing to the terms of this Order, does not admit the
allegations made in the Petition.
Plaintiff's request for a f'Inal protection order is granted.
"
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-
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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. DIANA LOUANN STANLEY
2. HANNAH ELIZABETH STANLEY
shall be as follows:
. Primary physical custody of the minor child/ren is awarded
to the Plaintiff.
. Defendant shall have visits with the parties' minor children,
DIANA LOUANN STANLEY and HANNAH ELIZABETH
STANLEY, on dates and at times mutually agreed by the
parties.
3. The following additional relief is granted as authorized by g6108 of the Act:
Defendant is enjoined from damaging or destroying any property jointly
owned by the parties or owned solely by Plaintiff.
The court costs and fees are waived.
Within 7 days of the entry of this Order, Defendant shall contact Cumberland
County Drug and Alcohol Services and schedule an intake appointment.
Defendant shall submit to a drug aud alcohol evaluation through Cumberland
County D & A Services, and follow and successfully complete any and all
recommendations for treatment by staff. Defendant shall be fmancially
responsible for any costs related to treatment.
Cumberland County Drug & Alcohol Services
36 West High Street, Carlisle, PA 17013
(717) 240-6300 or 697-0371
Within 7 days of the entry ofthis Order, Defendant shall contact one of the
batterer's programs listed below and schedule an intake appointment.
Defendant shall attend and successfully complete the 26-week batterer's
program, and, in addition, follow and complete any related recommendations
for ongoing treatment made by the program staff. Defendant shall be
financially responsible for any costs related to enrolling and attending the
program and any additional costs for ongoing treatment recommended by
staff.
,~,.
"
, I
. .
1",,,,- ~
-
. -f :-iil;B>i-
Choices (batterer's program)
Tressler Counseling Services
940 Century Drive, Mechanicsburg, P A 17055
(717) 795-0330
Mosaic Partnership Counseling Services
2001 North Front Street, Harrisburg, PA 17101
(717) 234-6438
4. Defendant shall pay (costs not billed as of entry of this Order) to Plaintiff as
compensation for Plaintiff's out-of-pocket losses, which are as follows;
any costs not covered by insurance which Plaintiff incurred for medical
treatment she received for injuries she sustained as a result of the incident
which occured on or about October 21, 2001. Defendant shall pay the costs
directly to the service provider(s) within 30 days of receipt ofthe billing
statement(s) from Plaintiff.
5. A certified copy of this Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter:
SmREMANSTOWN POLICE DEPARTMENT
HAMPDEN TOWNSIDP POLICE DEPARTMENT
6. THIS ORDER SUPERSEDES:
1. ANY PRIOR PF A ORDER
2. ANY PRIOR ORDER RELATING TO CHILD CUSTODY
7. All provisions ofthis order shall expire on: June 11, 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 PENNSYL VANIA
CRIMES CODE.
J""r~." W'~"
~ ~-
I, ,
",-",
1~1liI<I''';~~
~- --~~"~1Iii'"'".~~
;.'"r~~
THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT
OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE
COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST
WOMEN ACT, 18 U.S.C. ~2265. IF YOU TRAVEL OUTSIDE OF THE STATE
AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO
FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S,C ~~2261-
2262. IF THE BRADY INDICATOR PARAGRAPH APPEARS IN THE ORDER,
YOU MAY BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES
UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT, 18 U.S,C.
~922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR
AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over the plaintiff's 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 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.S. ~6113. .
Subsequent to arrest, the police officer shall seize all weapons used or threatened to
be used during the violation of the protection order or during prior incidents of abuse.
The 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 me 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.
nUE COPY FROM RECORD
In Testimony where f, I here unto set my hand
and seal of sai C urt ~carlislel Pa. B th C urt
11 y eo, .
...... .... .:;:;:~. ;f!!.i::l~. ~ljoy ) 1j
pursuant to the onsent of Plaintiff and Defendan
.5e.-----
. tiff
avid A. Lopez, Attorne
MidPenn Legal Services
8 Irvine Row, Carlisle, PA 17013
Henry? .' nd Stiinley, Defe t
/"fi /-- "/ "I,,?-""
/:::f t:2..~-?-..._
Bry)ll'f'S.. Walk, Attorney for Defendant
1 r2 Walnut Street, Harrisburg, P A 17101
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s 2001
"
LOUANN STACY SPEESE,
Plaintiff
: In The Court of Common Pleas of
: CUMBERLAND County
: Pennsylvania
v.
: Civil Action - Law
: No. 01-6501
HENRY HAMMOND STANLEY,
Defendant
: Protection From Abuse and
: Custody
MODIFIED FINAL ORDER OF COURT
Defendant's Name is: HENRY HAMMOND STANLEY
Defendant's Date of Birth is: November 9,1954
Defendant's Social Security Number is: 224-98-2554
Name(s) of All protected persons, including Plaintiff and minor children:
1. LOUANN STACY SPEESE
AND NOW, this 5th Day of March, 2002 the court having jurisdiction over the parties and
the subject-matter, it is ORDERED, ADJUDGED and DECREED as follows:
The Final Order of Court in the above-captioned case entered on December 10, 2001, is
hcreby modified to vacate the portion of paragraph 3, which requircd Defendant to attend a
battcrer's program. In all other respccts, the Final Ordcr of Court entered on Dccember 10,
2001, remains in full force and effect.
Plaintiff, Louann Stacy Speese, is represented by David ALopez of MidPcnn Legal
Scrvices; Defendant, Henry Hammond Stanley, is rcpresented by Bryan S. Walk, Attorney
at Law.
Defendant, although agreeing to the terms of this Order, does not admit the allegations
made in the Petition.
m
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Plaintiff's request for a modified 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. DIANA LOUANN STANLEY
2. HANNAH ELIZABETH STANLEY
shall be as follows:
. Primary physical custody of the minor child/ren is awarded to the
Plaintiff.
. Defendant shall have visits with the parties' minor children,
DIANA LOUANN STANLEY and HANNAH ELIZABETH
STANLEY, on dates and at times mutually agreed by the parties.
3. The following additional relief is granted as authorized by S6108 of the Act:
Defendant is enjoined from damaging or destroying any property jointly owned by
the parties or owned solely by Plaintiff.
The court costs and fees are waived.
Within 7 days ofthe entry ofthis Order, Defendant shall contact Cumberland
County Drug and Alcohol Services and schedule an intake appointment. Defendant
shall submit to a drug and alcohol evaluation through Cumberland County D & A
Services, and follow and successfully complete any and all recommendations for
treatment by staff. Defendant shall be financially responsible for any costs related to
treatment.
Cumberland County Drug & Alcohol Services
36 West High Street, Carlisle, PA 17013
(717) 240-6300 or 697-0371
4. Defendant shall pay (costs not billed as of entry of this Order) to Plaintiff as
compensation for Plaintiffs out-of-pocket losses, which are as follows:
any costs not covered by insurance which Plaintiff incurred for medical treatment
she received for injuries she sustained as a result ofthe incident which occured on
or about October 21, 2001. Defendant shall pay the costs directly to the service
provider(s) within 30 days of receipt ofthe billing statement(s) from Plaintiff.
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5. A certified copy of this Order shall be provided to the police department where Plaintiff
resides and any other agency specified hereafter:
SHIREMANSTOWN POLICE DEPARTMENT
HAMPDEN TOWNSHIP POLICE DEPARTMENT
6. THIS ORDER SUPERSEDES:
1. ANY PRIOR PF A ORDER
2. ANY PRIOR ORDER RELATING TO CHILD CUSTODY
7. All provisions of this order shall expire on: June 11, 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 PAC.S. 96114.
VIOLA TION 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 OFFICIALS
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, 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.S. 96113.
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.
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When the defendant is placed under arrest for violation of this order, the defendant shall be
taken to the appropriate authority or authorities before whom defendant is to be arraigned.
A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by the
police officer OR the plaintiff. Plaintiffs presence and signature are not required to file the
complaint.
If sufficient grounds for violation of this order are alleged, the defendant shall be arraigned,
bond set and both parties given notice of the date of the hearing.
BY THE COURT:
Edgar B. Bayley, Judge
Date
If entered pursuant to the consent of plaintiff and defendant:
Plaintiffs Signature
Defendant's Signature
Distribution to:
David A. Lopez
Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
Bryan S. Walk
Attorney for Defendant
112 Walnut Street
Harrisburg, PA 17101
Faxed & Mailed to PSP
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