The URL can be used to link to this page

Home My WebLink About01-06529 ~"'-- , .~ " ~ 1,,-,,-'- .... ,-,:~ -,~., ,',*.."""~\lg , .. - . LEANNE COLLEEN LAYNE, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. CIVIL ACTION - LAW LARKIN LAYNE, Defendant NO. 01-6529 CIVIL TERM ORDER OF COURT AND NOW, this 21st day of December, 2001, upon consideration of Plaintiffs Petition for Protection from Abuse, and following a hearing held on December 20, 2001, and the court finding that Defendant's conduct has not been shown to have risen to the level of abuse as defined in 23 Pa. C.S. s6102(a), the petition is denied and the Temporary Protection from Abuse Order dated November 19,2001, is vacated. NOTHING HEREIN is intended to represent a finding that Plaintiff did not have adequate legal cause for leaving the marital residence, for purposes of spousal support. IN THE EVENT that the parties are unable to resolve the issue of custody, the court will entertain a petition for special relief on that issue if accompanied by a complaint for custody. BY THE COURT, Joan Carey, Esq. '" \ Mid-Penn Legal Services ~~ ~ 8 Irvine Row -,--- - Carlisle, P A 17013 L YJ..-} 1- D RJ? Attorney for Plaintiff , VliWA1ASNN3d . MNnoo Ci:'Nif:ESVvna (; '1 :1; wd I Z ~1]a I 0 AI::iV1Q;,!Ot:10(;d ~.'Hl :10 t''''~ '..i'-L....JU"'...-I .::hJ~.:J....' j lid ~ """-"~ .'" _I ,~" "_'<"'~""'"_~~U,_"c ':""'_"~;" '~~:\'!':-~j . .- Gregory Cutler, Esq. 50 E. High Street Carlisle, PA 17013 Attorney for Defendant :rc :f~ f5P C.P 2J 1-.". ~ " ~,' ~ ""':..... .10, I " ..;l~~~", ' ".'-A' "-~. 'ilL -'~i (717) 240-6195 ~. PAX (717) 240~6573 v I ATE LEe 0 PIe R TO: PA STATE" Nl..%c-E - ~b.4.,1 P. .- /l!/fJcess.. . fAX!; 7/)-,JII,. "'?)1 fRC1ol: CURTIS R. LONG RE; P1=A- (}ebGtlS MESSAGE: ;J 11:). OF' PAGES (INCr.AJDING CQVE;R SHEET) 1his ~ is inta1:Bl cnly fir tte ISO of ITe in::li.VidB1 <r mti~ tJJ WUd1 is is cilll. ;r1, aUffBi a::ntl:tin inIi::IITatim !hat is p:ivil.eg;d, o:nf:idential a"d eo<aTpt fmn t\i.....l......1re mEr 'll'H.w.l.. JEw. [f tl-e mrt!r of tl1is " 'W is rot: tI13 inlalkl a!lCipialt, }'OJ are l~ rotifiOO tl'6t a1y dissamn'Jt.it:n. cI.i.s1:riJ:uti cr a:pjin:;J c€ !:his crnm.nica!:jaJ ~ strictly p:t:hibi.too. If)OJ h;II.e I.'l:Cl!iI.OO [JUS ccmn.ni('.~tim in err:r. p:lJ;l;sa rotify 1.6 imre:liately ty telep-t:re m:l (eturTl tie crigiral. ~ to l.B i3~ tle ro-: a:ilress vie tie ~!.S. ~tall:e[\.im. 'ltErk }O.l. .____~__. _____ - "w _ ___h_' ......---,_.-,,~- .----- -"-'---- N(lI1::: [f YOO l:q I\Q1' [U':.CC:lVE AI.l. 'lliE PI\Gf.S, OR IWY PAGES ARE UNet.EAIl, PLErSE: CALl. (717) 240-6195 /IS SOCiN !>S P03SIBf.E AND flSl( fOR '!HE: SF:NDER. llalma dO dSd 1l:tSotzd6ltO ] 6LL06t;;d6110 ] He;; :110 N:OLLOVSNVlLL Yll/XL aL~dWOON:I ON: Yll/XL $*$$$$***********$*$$$$**** u* LllOdffil N:.L IL'Il1JIl *** $*$*$******$$$***$*$******$ lOO~ AllVLONOELOlld 00 HWilO ~LS9 OY;; L1L ~~~ SS:Sl Illd 10/1;;/;;1 - ~i" ~t>l> - ~L...~.~.. ~~ . L.. lr~j~""~'~r' -," -1!ii"'Hi!l:;jj~"~<iml,,&'. SHERIFF'S RETURN - REGULAR CASE NO: 2001-06529 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND LAYNE LEANNE COLLEEN VS LAYNE LARKIN CPL TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon LAYNE LARKIN the DEFENDANT , at 1837:00 HOURS, on the 19th day of November, 2001 at 81 E MAIN ST NEWVILLE, PA 17241 by handing to LARKIN LAYNE 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 7.80 .00 10.00 .00 35.80 .~~~~ R. Thomas Kline 11/20/2001 LEGAL SERVICES me this :u. ""- day of Sworn and Subscribed to before By: 'fLu... U MA L. _;J..g-,yf A . D . ~ a !h/~tI,,-", ~ rothonotary r <~ .:\..,.... '~.~'j"""""~'" ... ... Leanne Colleen Layne, Plaintiff : IN THE COURT OF COMMON PLEASE OF : CUMBERLAND COUNTY, PENNSYL VANIA vs. : NO. 01-6529 CML TERM Larkin Layne, Defendant : PROTECTION FROM ABUSE : AND CUSTODY ORDER FOR CONTINUANCE AND NOW, this "lilt tt. day of November, 2001, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on November 29, 200 I, is hereby rescheduled for hearing on December 20, 2001, at 11: 15 a.m. in Courtroom No. 1. The Temporary Protection From Abuse Order shall remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. By the Court, Joan Carey III C' MidPenn Legal Services --r C (') 1fv\..P.. ( vC/V /J 'C-6 Attorney for Plaintiff 11- 2.'1-0( Gregory Cutler J Law Office of Paul Orr )vL C..,)1 ,L {/. L'i -D ( Attorney for Defendant -< .,' >,,~ ~, - _,Jill _ 11.1_,1,_,-, _ .,,_~ ~:" J!f!l!~fl1fflDl1~nrMJr~, _~ ~ ~ _ C '->w"..' "-",'_",' '^ "~.---"~' -. - .--.\ /JT;\f-iV OJ 29 'I' ')' I . (I.; CUj\/;8EHL)\i\l) COUNTY PENNSYLVANIA - , ~f~r?~'l;r!::E[~I]Jlt:?:_",~[i'~~~_;,U\U,,~,:,:~- ,_~]~lJiN. I\II!III. :)~'fr\,,~-.~~~ItjJ'1~~~,_,-,-,,_- ;_.~'_"'~ ' .' _ -- - - ,~~~r~!l.~_-~J~ . ~ ~-" - ~ , I :;, '" ~- :L... > '-~-~;,\,,: - .. Leanne Colleen Layne, Plaintiff : IN THE COURT OF COMMON PLEASE OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 01-6529 CIVIL TERM Larkin Layne, Defendant : PROTECTION FROM ABUSE AND : CUSTODY MOTION FOR CONTINUANCE The Plaintiff, Leanne Layne, by and through her attorney, Joan Carey ofMidPenn Legal Services, moves the Court for an Order rescheduling the hearing in the above- captioned case on the grounds that: I. A Temporary Protection From Abuse Order was issued by this Court of November 19, 2001, scheduling a hearing for November 29,2001, at 10:00 a.m. 2. The Cumberland County Sheriffs Department served Defendant with the . Temporary Protection Order on November 19,2001. 3. The Defendant is being represented by Greg Cutler, Attorney, who has contacted MidPenn Legal Services to request a Continuance due to a conflict in his schedule. 4. The Plaintiff is in agreement with that request. 5. The Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes fIrst. WHEREFORE, the Plaintiff requests that the Court grant this Motion and reschedule this matter for hearing, and that the Temporary Protection Prom Abuse Order '~ - ~-- .., I . ,- .". "",,",.,;~,i( ... remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. Respectfully submitted, ~y Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 ~j ":-__~'--,':'_ ,/, __,' _":- ':",: ", - _, -_ _-," -,'-,;_ '-, _ --,,:,,<'i- - -,-",',' ~_)ji!f~c]jill!jll!ftiii~~it"'iIIIl\_~""iil:llilc~iiiJ!i.:ri~.......",,,,,,,,,,,,,,,,t . """'illiilU,'Ld" .. .,'" --" -,-,~~~ ~, - ~,_._ ",..' """~' c, <", ,",' ~'~-;)~_~.iii-;'$,~iJli(] '.'h'"",'. ",-;',,:.,-' ,,~ ~,~,""" _ ,'~_- " _ d ,A ~ C) c ;.e: wcT l"!J U; ~:'_L -7f~" 1:/5 ;., .."..... -~. ~~ ;gu c z ::<! EffJJ " <" ......,...., "n C) .- ;~ ;') '0 _, '~J ::> u:) ~~~ ?~ ~~~ l~il -~ ~ -< "~ L. ~I:'" -"'__"'(";,c" <_,;' '-'-'l~~%;; " LEANNE COLLEEN LAYNE, Plaintiff : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA vs. . : NO. 01 -(.S).9 CIVIL TERM LARKIN LAYNE Defendant : PROTECTION FROM ABUSE : AND CUSTODY NOTICE OF HEARING AND OIillER 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 grauting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights.~,p IUYl , A hearing on this matter is scheduled for the Olf 1Jt... day of November, at If) ;1)1) in Courtroom No.-L 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 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. ~2265, this Order is enforceable anywhere in the United States, triballands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside ofthe state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. g2261-2262. YOU SHOULD TAKE TillS 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 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 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. " ~ =. __"w. -,.'- "~ ,-, ,"- ",,-,> >'.4. ,~ <~.""";L~,,~ "~.<"-..,,,,,,,,<,-~~,~~,.,,~,,-~..~~.,. ~'-' C{ "'i:: ]\1,:) T,b,J{V n Ile:OI.' I Q c::::.,. 2 a \.J '~d" -' I j i do ,".... CUM8E~~~LANO COUNTY PENt'!SYlV/\NIA , . ,.~m.~)~,~JLr~:R!,rlf" JI~~~lX',v::.IJiilf.m~~,!".",_~J~~~~!I!!",J~J\4j;~-!11m:IRffiMJ.~"'ill""!i*"fiJ');)!l~"~~;f'1W%-Wt~~~~~[~~~~~~~~] c' ,., _, - ':~..~ ' . . . . , L...:o..-.' ,~",'~. ,''''''-' '.,:0>" .,~.~, ',.J,":".. '"~i,' . . . Leanne Colleen Layne : IN THE COURt OF COMMON. : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff v. 6/ _ : No. (,:;".2 II Larkin Layne : CIVIL ACTION - LAW : PROTECTION FROM ABUSE Defendant TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Larkin Layne Defendant's Date of Birth is: April 10, 1970 Defendant's Social Security Number is: 260-51-0964 Name(s) of All protected persons, including Plaintiff and minor children: 1. Leanne Colleen Layne AND NOW, on 19th Day of November, 2001 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: Plainti.frs request for a temporary protection order is granted. 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. 2. Except for such contact with the minor childlren as may be permitted under paragraph 4 of this Order, Defendant is prohibited from having ANY CONTACT with Plaintiff, or any other person protected under this Order, at any location, including but not limited to any contact at Plaintiffs school, business, or place of employment. .--"". . -- .. t,j ~"l ~. ~' , .:..J~ -,' .,,', ~ " : ,-~ '-' ,-,';,-' ce- '. '-~~"'Ei('::iit:l:; 3. Except f~r such Contact with the minor clllld/ren as may be permitted under paragraph 4 of this Order, Defendant shall not contact Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 4. Pending the outcome of the final hearing in this matter, Plaintiff is awarded temporary custody of the following minor child/ren: 1. Audrey Elizabeth Layne 2. Larkin Miller Layne 3. Nathaniel Joshua Layne 4. Gabrielle Colleen Layne Until the final hearing, all contact between Defendant and the child/ren shall be limited to the following: No contact 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. 5. The following additional relief is granted: - Defendant is ordered to stay away from any residence the Plaintiff has now or may establish for herself in the future. - Defendant is prohibited from having any contact with Plaintiff's relatives. 6. A certified copy ofthis Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Appropriate police departments 7. The sheriff, police or other law enforcement agencies are directed to serve the Defendant with a copy of the Petition, any Order issued, and the Order for Hearing without prepayment of costs. The Petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. The Prothonotary is directed to file this Petition and Order without prepayment of costs. 8. THIS ORDER APPLIES IMMEDIA TEL Y TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MAY 19, 2003 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT .1...' - ,^" , ,..,.' ,~- -'" ~- _A~'-', r-c" '" -"If n-'fff1t,:,I-jj;'/~ Defendands hereby notified that violiltion 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 4 of this Order, defendant shall be arrested on the charge ofIndirect 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 connnitted 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 weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. 1~,z...DO I Date Distribution to: Legal Services Faxed & Mailed to PSP "~ . "," J ,'_.' . .. ,.. - -~:'; '''L.~;~'il;jo>l1ri#., PFAD Number: NH367043U Leanne Colleen Layne : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYL VANIA Plaintiff v. Larkin Layne ; No. OI-&SdC{ : CIVIL ACTION - LAW : PROTECTION FROM ABUSE Defendant PETITION FOR PROTECTION FROM ABUSE I. Plaintiff's name is: Leanne Colleen Layne 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. Leanne Colleen Layne 4. Plaintiff's address is confidential 5. Defendant's Name is: Larkin Layne 6. Defendant is believed to live at the following address: 81 East Main Street, Newville, Pa 17241 "-, ,,~.. r, ....IJ. ' ""~ "-",-,- ; .'L' :a'i --;,;-<,;"" ,'-';1 .G""l.' 'LJ1H~~Mff@ji 7. Defendant's Social Security Number is: 260-51-0964 8. Defendant's Date of Birth is: April 10, 1970 9. Defendant's Place of employment is: E.C. Snyder, Inc., 250 South 18th Street, Harrisburg, PA 10. Defendant is an adult. 11. The relationship between the Plaintiff and the Defendant is: Spouse Parents of the same children 12. The Plaintiff and the Defendant been involved in the following court actions: a. Protection From Abuse 13. Other details of the court action are: PFA in 1995, Montgomery County #95-16576 14. The defendant has been involved in a criminal court action. 15. Plaintiff and Defendant are the parents of the following minor child/ren: a. Audrey Elizabeth Layne Age:7 Child's address is: Confidential b. Larkin Miller Layne Age:3 Child's address is: Confidential c. Nathaniel Joshua Layne Age:l Child's address is: Confidential d. Gabrielle Colleen Layne Age:3 weeks Child's address is: Confidential ~'i! '" _'I ,~.-- ,~ < _e ,;';_'0.-_"'.;-' 'V<', '-";'';';;r-'~",.,~'' "'_, Ji_%l:;~~;.r~ 16. Plaintiff is seeking an Order of child custody as part of this petition. The following is a list of the children and where they have live for the past 5 years: a. Audrey Elizabeth Layne For the past 5 years, this child has lived with: Leanne and Larkin Layne 1009 Rosemont Parkway, Roswell, GA 1996-1998 Leanne and Larkin Layne 29 S. Baltimore Street, Franklintown, PA 1998-112001 Leanne and Larkin Layne 81 E. Main Street, Newville, PA 1/2001-11/2/01 Leanne Layne, Donn & Patricia Miller (Plaintiff's parents) 1011 Braggtown Road, Dillsburg, PA 11/02/01-present b. Larkin Miller Layne For the past 5 years, this child has lived with: Leanne and Larkin Layne 1009 Rosemont Parkway, Roswell, GA 1997-1998 Leanne and Larkin Layne 29 S. Baltimore Street, Franklintown, P A 1998-112001 Leanne and Larkin Layne 81 E. Main Street, Newville, PA 1/2001-11/2/01 Leanne Layne, Donn & Patricia Miller (Plaintiff's parents) 1011 Braggtown Road, Dillsburg, PA 11/02/01-present c. Nathaniel Joshua Layne For the past 5 years, this child has lived with: Leanne and Larkin Layne 29 S. Baltimore Street, Franklintown,Pa 17323 -11/1999-112001 Leanne and Larkin Layne 81 E. Main Street, Newville, Pa 1/2001-11102/01 Leanne Layne, Donn & Patricia Miller (plaintiff's parents) 1011 Braggtown Road, Dillsburg, PA 11/02/01-present d. Gabrielle Colleen Layne For the past 5 years, this child has lived with: Leanne and Larkin Layne 81 E. Main Street, Newville, Pa .:~ ,,,j-, ~A< ,,';-" .;i-~"';';~. 0 '<-' :,-,-,'-.;':'.-,. a_JwJflilld bkth-llI02/01 .. '. Leanne Layne, Donn & Patricia Miller (plaintiffs parents) 1011 Braggtown Road, Dillsburg, PA 1l/02/01-present 17. The facts of the most recent incident of abuse are as follows: On about Monday, October 22, 2001 location: 81 E. Main Street, Newville, Pa 17241 Defendant grabbed Plaintiff by the arms, forced her into a chair, grabbed the chair to prevent her from getting up, and forcefully shook the chair while screaming at her, causing her to fear for her safety. Plaintiff was 8 months pregnant during this incident. Plaintiff obtained a Protection from Abuse Order in Montgomery County in 1995. Defendant is drinking heavily again. 18. 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 5, 2001, while Plaintiff was sitting in a chair, Defendant forced Plaintlffto look at him, yelled obscenities at her, grabbed the arms of the chair, keeping her in that spot so she could not get away, and screamed at ber. Plaintiff was pregnant and fearful for her safety. On or about October 4, 2001, Defendant came at Plaintiff, who was 8 months pregnant, got in her face and threatened her saying, "You and your parents are fucked," causing her to fear for her safety. In the past, Defendant has abused Plaintiff in ways including, but not limited to the following: Slapping her in the face, pinching, pushing, punching, grabbing her breasts, and restraining her. 19. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: Appropriate Police Departments 20. There is an immediate and present danger of further abuse from the Defendant. 21. The Defendant owes a duty of support to Plaintiff and/or minor child/ren. 22. 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. Evict/exclude Defendant from Plaintiffs residence and prohibit Defendant from attempting to enter any temporary or permanent ~- , ~ I ~ .~. ~ ~",,-. -,--~ ,,~~I'~:Ll' '_."0"___",,";' '""."~~;"~f_", residence of the Plaintiff. . c. Award Plaintiff temporary custody of the minor child/ren and place the following restrictions on contact between Defendant and child/ren: Defendant shall have visitation with the children at times and places to be agreed upon by the parties. d. Prohibit Defendant from having any contact with Plaintiff and/or minor child/ren, either in person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Plaintiffs school, business, or place of employment, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/nino e. 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. f. Order Defendant to pay temporary support to Plaintiff and/or the minor child/ren, including medical support . g. Order Defendant to pay the costs of this action, including filing and service fees. h. Grant such other relief as the court deems appropriate. 1. Order the police or other law enforcement agency to serve the Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. Respectfully Submitted by: J arey David Lopez Attorneys for Plaintiff Agency: MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 , - "~-,, ~. ,_J ",I 'k.-" -, ,.-"1' ;,-c,' -;- 2.'-,"''';- , '~-j-'i1~ ~i' j . . 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 l8 Fa.C.S. ~4904. relating to unsworn falsification to authorities. Dated: II /JS~ /0) I ~ Leanne C. Layne. laintiff =~::1ii ---- '" ~~ ~~ ~\ " '---c. -+'ls. ,l~s.~ 'tL3 .~ ~ .b cs:. '" ~M~~ 1 ~tt ) L-J ..:J~~ 1 "l_~ ~ \j ~ '0 ~ ~ l(\( vj .-.J "" ," .~.~ .,.. "' 'y ~ h,~'__'" "'">0',_"," ~--,",,->~ . '=~b',' -.';'-C' "-1"',,", ,,'"'0" """~-''''~U''''Y-'''''''';'^'~;''''III''.lilnt'-"'~' l~o--";_"'l::'~~ nr" .....;:' Tt f,~L~!~':,:sr!;~~t ", i', ,I,,.' j"';'~./---J.'JTJf?'y' [I.,' IIO.V I . , 9 Pi'; 2: .32 CUI/BFCP'l.' ('" PEi-Ji~:SYL~I,\i\';YNTY Vn.l'il, e O~6 <3 '\ 1 ~ . . ....0>...,...... ~r-JlIM~S!:~t~L""!_=Jf_f{ yq]l_"~~~~ItI~__I)"g"."._'.,,~;;~-,.~~,~;Wf<!i'f..'%B4(~~:"f&.<<t'",,f01~F..ig1"i~lf\~~~~~:ip,~J]:,'>;~~1i~~ 11/19/01 MON 16:20 P"v n.o. 717 240 6573 .......'~ - I, ~~,,_-, .".'.. - .lJ1i~~':' .-- ".'"" "-'~J.n'~'i.~ . . *************************** L ~** MULTI TN REPORT *** ***************~*****~***** CliMB CO PROTHONOTARY 141001 . . TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2874 ERROR [ 01] 9P2490779 [ 03]9p2405331 [ 04]92438026 PSP CP LS -' ., " . OFF'ICE Of 11iE PRCYrHCN:1rMY CUMBERLAND OX/N'l"{ COUR'llICOSE CiNE COJRTHOOS E !;QUARE CARLISLE, PA. 17013-3387 (717) 240-6195 PAX (717) 240-6573 v rAT E LEe 0 PIE R TO: PA STATE POLICE - CellI. PdbC.C$r... M.P- J...S. FAX ff: 717-249-0779 ffia.1 : CURTIS R. LONG RE: PfA ORDERS MESSAGE: ....L 110. OF PAGeS (INCUJOING COVER SHEET) 'Itds lTeS!aJ:' :is inb;l"drl ally fi:r tIE ~ of tte irdiviQ.el IX Entit;y to mich is is ,,11. ~!m:l, a'"d 1T6Y o:::ntain inftmat:.im ttet is J;ti~. o:nflrl:ntial m:l ~ fD:m rli....l~ma I.l"d;or "yH'"'*"'''' l<w. [f tj-a L'l:lrl&' of this ~ is rot: lie mlEn:h::l ~. ~ are tea:bJ IDti€ie1 ltat TUJ dia;aniratim. distclubm IX awio;J cf. this cmrrr.nicatim .i<; stcict1y p:d1.ibilB1. If ~ tale re:ei\lErl (Jus . . '-'- .- ~ ,,1...... rnt-il'v '" inrrB:iiate1v b{ IBk1;tne ad telm:n I;te a:igimlll 'IT to U; <It