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Home My WebLink About01-06815 RUTH C. MILLER, On behalf of her minor son, BRANDON L. SCOTT, Plaintiff Vs. SHAWN STERLING SCOTT, Defendant : IN THE COURT OF COMMON PLEAS : OF CUMBERLAND COUNTY, PENNSYLVANIA ; NO. 01 - ft,C{~IVIL TERM : 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 yon 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. 6A ~ A hearing on this matter is scheduled for the ~ day of at ;J;fJfJ p"" in Courtroom NQ....l... of the 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 fme of up to $1,000.00 and/or up to six months in jail under 23 Pa.C.S. ~6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. ~2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. ~2261-2262. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEARING. THE_ COURT WILL NOT, HOWEVER, APPOINT A LAWYER FOR YOU. IF YOU DO NOl' 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 LmERTY 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. ':-;;'i7l'J1, Jf "_,_ _,_, ~" " .,", ":"'1:'1 ,,~ . ~ J~1:':l~~~"'1"".t,Yj "-- vJT[~'r"-lr - ,--= -,"..~" '~__L > - '""" Ruth C. Miller, on behalf of her minor son, Brandon Lashawn Scott : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff v. : No. . Shawn Sterling Scott : CIVIL ACTION - LAW : PROTECTION FROM ABUSE Defendant TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Shawn Sterling Scott Defendant's Date of Birth is: July 24, 1965 Name(s) of All protected persons, including Plaintiff and minor children: 1. Brandon Lashawn Scott AND NOW, on 28th Day of November, 2001 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: Plaintiff's request for a temporary protection order is granted. 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. 2. Defendant shall be evicted and excluded from the residence at: 233 North Bedford Street Carlil.se, P A or any other permanent or temporary residence where Plaintiff or any other person protected under this Order may live. Plaintiff is granted exclusive possession ofthe residence, Defendant shall have no right or privilege to enter or be present on the premises of Plaintiff or any other person protected under this Order. '0J .";,-~,~~,,,-_L,,,.'f>P;..-"-_"_. -"-'" "'.>-"'-",' ,~r - ,-~, . , -MZ~_~_"'I'r."'I'!t'l "",,"<ff ~-~',,,, ~ 3. 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 Plaintiff's school, business, or place of employment. Defendant is specifically ordered to stay away from the following locations for the duration of this order. Plaintiffs school, Wilson Middle School, 900 Waggoners Gap Road, Carlisle, PA 4. Defendant shall not contact Plaintiff, or any other person protected under this Order, by telephone or by any other means, including through third persons. 5. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Carlisle Police Department 6. The sheriff, police or other law enforcement agencies are directed to serve the Defendant with a copy ofthe Petition, any Order issued, and the Order for Hearing without prepayment of costs. The Petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. The Prothonotary is directed to file this Petition and Order without prepayment of costs. 7. THIS ORDER SUPERSEDES ANY PRIOR ORDER RELATING TO CHILD CUSTODY 8. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MAY 28, 2003 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months in jail. 23 Pa.C.S. g61l4. Consent of the Plaintiff to Defendant's return to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. g6113, Defendant is further notified that violation of this Order may subject himlher to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 V.S.C. gg226l- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS ~ I' !'P" ~ This Order shall be enforced by tho: police. who have jurisdiction over the plaintiff's residence OR any location where a violation of this order occurs OR where the defendant may be located. If defendant violates Paragraphs I through 4 of this Order, defendant shall be arrested on the charge ofIndirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence oflaw enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriff's office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this court, unless the weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. Judge Distribution to: Legal Services Faxed & Mailed to PSP I ---- C. p. LS )I oJ. q -61 - RYt ']00...'-' Co.R.~ PLfF not presell ,"F:;~,.~L,;.,~,.~.. ^"'". - y. '1'" 1;1~~j-~;oi1~:~~jd-m~~~.:$;~f'~tlliiH}i~mk~!~_~i~~~~<E"'~ <,c'o ';,'. I-,'J;\- ,!L;-;:..',- ,"','~o,. 1,!<",Jl\I,~J..lnllJ"lJl~_!I1IlJII!.I!<..""" _",,".", "~~,_ __',_~_ ," -r_'"_'''' - ,._,~", ,,,yo \....'i'. :~~~L ~ \~:,:~~,2:~~~~:~'\~Jl"l'HY -~ I C!'"'M ') Q r,-~ .1:'-1 3: :i:3 \.j I'",) \- t~... ",,,""Y',' ,"'" (y" '''TY C\ j'\I;i--<~.f'\jj.\:\U ..;,.iUI'li "''''';:~~r._i'\.-! !Q\iL:' \//1\\11,\ ("C\\I\ \i....,1 ~j...." .Ii, ~ ""';"f""'.' "" ". ".""1'1"'" ",. 'Y' '"0''' .-'il</f,f '-"-'--'fY,;;"-~,-,,,,-,,-,:- .",!"r_,'c:_" ... PFADNumber: ZD1374567Q Ruth C. Miller, on behalf of her minor son, Brandon Lashawn Scott : IN THE COURT OF COMMON : PLEAS OF : CUMBERLAND COUNTY, : PENNSYLVANIA Plaintiff v. : No. . Shawn Sterling Scott : CIVIL ACTION - LAW : PROTECTION FROM ABUSE Defendant PETITION FOR PROTECTION FROM ABUSE 1. Plaintiff's name is: Ruth Miller 2. I, (the Filer), am filing this Petition: - as Parent of minor Plaintiff(s) 3. Filer's Name is: Rnth C. Miller 4. Filer's Address is: 233 N. Bedford St., Carlisle, PA 17013 5. Name(s) of ALL person(s), including minor children, who seek protection from abuse. a. Brandon Lashawn Scott 6. Plaintiffs Address is: 233 N. Bedford St., Carlisle, PA 17013 "I~=-~' ,- ,-," - "-(~~I;;\t~",<>;~,,_,;;>, _',0'7_' - >-,'" '" 7. Defendant's Name is: Shawn Sterling Scott 8, Defendant is believed to live at the following address: Cumberland County Prison, Carlisle, P A 1701307 9. Defendant's Date of Birth is: July 24, 1965 10. Defendant's Place of employment is: Sentinel 11. Defendant is an adult. 12. The relationship between the Plaintiff and the Defendant is: Parent / Child 13. The defendant has been involved in a criminal court action. 14. The defendant is not currently on probation / parole 15. Plaintiff and Defendant are the parents.pf the following minor child/ren: a. Brandon Lashawn Scott Age: 13 Child's address is: 233 North Bedford Street, Carlisle, P A 17013 16. There is an existing court order regarding the custody of the Plaintiffs and Defendant's minor children, County: Dauphin State: Pennsylvania 17. The facts of the most recent incident of abuse are as follows: On about Friday, November 16,2001 location: 233 North Bedford Street, Carlisle Defendant became angry at Plaintiff, Brandon Scott, the parties' son,who is 13 r .. ~..."...",. :1 ~ year old, pulled off his belt, s"!'llng t~e belt at Brandon, hitting him in the_head _ and causing him to fall to the Door. Defendant continued to beat Brandon with the belt abont his body. When Plaintiff's mother tried to intervene, Defendant turned on her, raising the belt at her. Defendant kicked Brandon across the Door, causing him to hit the refrigerator. Plaintiff was able to get up and run to his room where be Ded tbe house tbrougb his window and stayed with a friend for the night. Plaintiff suffered pain and bruising about his body. The next day, Brandon and his mother telephoned the police regarding the abuse and they arrested Defendant for simple assault. 18, The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: Carlisle Police Department 19. There is an immediate and present danger of further abuse from the Defendant. 20. Plaintiff is asking the court to evict and exclude the Defendant from the following residence: 233 North Bedford Street Carlilse, P A Rented By:Ruth Miller and Shawn Scott 21. 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 residence of the Plaintiff. c. 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/ren. d. Order Defendant to pay the costs of this action, including filing and service fees. e. Order the following additional relief, not listed above: Order Defendant to stay away from Plaintiffs School, Wilson Middle School, located at 900 Waggoners Gap Road, Carlisle, P A ".ir~!:711~ _;""<;'""~ .". ~~_",_,_ '._.~< _,~,. ""^"":I "'1."'-" ,.r . ~. ,'- r .;'''~lit.!l,;-J ~.,_ ,. ,,_ "."" ,. 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. - ,,,,,,, -!"'"!~I- ~ Respectfully Submitted by: ~V~r oan Carey, Attome MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 Agency: , _,~ A-,:,.,,- ",' ~-, " ~-~. .. " r~.""'.ln~'.r1flA"--''''. ~",' . . .-'," ... 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: fI-Z-fi-OI ~b (h~ Ruth Miller, Plaintiff ~NwL 41~ j~ Brandon ScotE, Minor '.'~k, ___-'~.._;-':~::-, '-,< 1:___ "", C'_ ,Or"' .,-- ".~ >"~>""".'-'"-'~""'"'''If''' '''11WiilllllllT.,^uiH!]li jii1jl[-~" ... . (') CJ I!) C ~n r <: ';-e; t'JU..> D -n rnr'i'" - . ::;.:::.::c f') ; ;"~-l Zl,- !,.,......., (,0 -::~- ~ U) ~\ ~~~ -(/. r::.c:: -0 -.. " f )>c :::~: ..,.. ~ 0-,;(") ~c) c.) ;;~-\rn ~ );-">~ ~ ~ L.. ::::; -~ :D -< CO -< \. ~ , ~ ...."" h~ .11. .._,,,,)lllJ,_.J:,_,,,;<~_~.,"J-r'~,' "';'(_' -~,,- ~,-. ~__ ":~" '~_;:_>__ j!_:""_,,,,~J ,_,'~iI~':~l;'ji~'*:>!tJi;:;'>'I;!!d'))'~1'i;W_~"$i'U&~Ji!!'!~'tw:~~~j~iw~~~1Ji'.~~lifl'~~ 11/29/01 THU 16:13 FAX 717 240 6573 CUMB CO PROTHONOTARY 141001 *************************** *** MULTI TN REPORT *** ***********~*************** TX/RX NO INCOMPLETE TX/RX TRANSACTION OK 2884 [ 04]92438026 [ 01]9p2490779 [ 03]9p2405331 LS PSP CP ERROR " . or-Frcr Of' 1'HE PR0TI1().\OtARY CUMBERlAND 0)(JN'f'Y COURTI-lClJSE Ct-lF.: COORTHOOSE SQUARE CARLISLE, PA_ 17013-3387 (717) 240-6195 FAX (717) 240-6573 V I ATE LEe 0 PIE R TO: PI'< STATE POLICE - Cellf. 1'1t"c.c~!;,' M. Po 1...$. FAX n: 717-249-0779 , FRCM: CURTIS R. LONG RE: PFA ORDERS MESSAGE: . -L 00. OF PAGES (INCLUDING lDVER SHEET) nus Il'I'" :1" is ir,b..~ mly fir It"e u;e of t:h3 ir<lliIiO.el cr ~ tD Wrld1. is is rln. I, .:n:l nay =rtain infi:.motil:n. ttm: is p:i.vilJ;g;d, o:nfidffitial an e>ce'tPI: fmn dicrll'A lr.e \.I"deJ: "t:PH.....nl.. Jaor. [f tI-e mrl1:r of this -~ ~ is rot tie inllard;t:1 recipient, ~ 8I:e !-en;bf rotif:ia:l IhIt in}' dil:;Semin!Jtial. disl:rih1tim cr <XI?fiog of this <nmuticatiro ~ strictly~. If ~ taw m:eiwd l.hLs a:mnni(.;t.:im in eI:l'J[', plEese rutify lEi imIBiiatBly tv t:eJ.Et:h:re aU IBtum tie ocigiraJ. II '-"'f' tD l.G al tte itu.c' ~ via Ite [l.S. p:fltal s;r..ire. 'Itai<;)CU. .;'o"'J1.&lRlm, ~ _ _'!!'_,.,."'~"_ ~'" ~ 1'M'V'i:l!"'--r ~"-,~. . ~ '--1 -~ ~- ,."..,...~~, - -,.~~; SHERIFF'S RETURN - REGULAR CASE NO: 2001-06815 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MILLER RUTH C ON BEHALF OF VS SCOTT SHAWN STERLING TREVOR KENT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon SCOTT SHAWN STERLING the DEFENDANT , at 1625:00 HOURS, on the 29th day of November, 2001 at CUMBERLAND COUNTY PRISON 1101 CLAREMONT RD CARLISLE, PA 17013 by handing to SHAWN SCOTT 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. Thomas Kline 11/30/2001 LEGAL SERVICES Sworn and Subscribed to before By: ;1~~ Deputy Sheriff me this 304 day of d"O 0 ( A.D. r '-''"~, . _ _1Ijil!!l~i"t'r:1 ...,-. '''''r " - ,. ""' ~"--"~-'... , -- ~ ,': ;1;""""'-"'- ~--~-"- "<,,-- ,,~ ,~ Ruth C. Miller, On behalf of her minor son, Brandon Lashawn Scott Plaintiff : IN THE COURT OF COMMON PLEASE OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. Shawn Sterling Scott, Defendant : NO. 01-6815 CIVIL TERM : PROTECTION FROM ABUSE ORD R FOR CONTINUANCE day of December, 2001, upon consideration of the AND NOW, this attached Motion for Continuance, the matter scheduled for hearing on December 5, 2001, is hereby rescheduled for hearing on January 2, 2002, at 3:00 p.m. in Courtroom No.3. 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 MidPenn Legal Services n . f1 /" ., - Attorney for Plaintiff -r-'V~~ VMVlCL. (J)--~/ Shawn Sterling Scott),. '(). I 111 _ L -AI Pro Se Defendant I ~ fIlA. ') . U ';"'''::: - , "1Y,~-_;o "'. >-,'1' <,--,.,- ~~~iI,t.~~W.it'~~~~~iiW~"'-W~1~,",_;;0T,,""Ml:<<!#~~'iii'illiJJ 'L' o>,Lli':' .''''M -~ -'""l>.."" -:W_~ T~3-~r "'~i,ii'~ "'1''' -,,'- ",'!v'-'-'--"'~-""-'''ilic"-- illii ute: r "-"",, '"-,,,"- """"':; J; nFe;; ,if:'!!: i 7 CU^!~~kj~Vlil,~ii~~)!VTY 4,j,UJIlJ..J..IIIitJIWU ..n~" ,. c,_~,,,~., , ,,~~, ,,',,-= ,,,'_~~_ , ~ Ruth C. Miller, On behalf of her minor son, Brandon Lashawn Scott Plaintiff : IN THE COURT OF COMMON PLEASE OF vs. Shawn Sterling Scott, Defendant : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL TERM : NO. 01-6815 : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE The Plaintiff, Ruth Miller and Brandon Scott, by and through their attorney, Joan Carey of MidPeun 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 29,2001, scheduling a hearing for December 5, 2001, at 2:00 p.m. 2. The Cumberland County Sheriffs Department served Defendant on November 29,2001, at the Cumberland County Prison. 3. MidPeun Legal Services was recently informed that Defendant was moved from the Cumberland County Prison to the Dauphin County Prison on November 30, 2001. 4, The Defendant cannot be transported to Cumberland County for the hearing without appropriate notice to the Sheriffs Department. 5. Plaintiff requests an Order continuing the matter to afford us time to have Defendant transported to Cumberland County for the hearing or to settle the matter by agreement. 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. 4f_~,__ ~_ ',' . .,,, ;'~ d-_'." ". ',_ ~ - ._~ - ~'I:--' -, - .....,,"'~_" <._ ~"._ _,. _ ~,.__ ._< 0 _ , ~ WHEREFORE, the 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 eighteen months from the date it was entered or until further Order of Court, whichever comes first. Respectfully submitted, ~? Joan Carey Attorney for Plainti MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ,1\ ~f~ "--/'-'-"- >"~":-'_'?_'Cl~_~ ,-",,' h',,~;,. " -" ~, -1 ","... -';;;__2-')'---: !\I!!lI!1"""." '..' , .,,"~~"J J!.'t ;'~'\;"N.'",~~'b"'(~-'"",,,:,!,,:!.-,,,:,: ,l~lW_Ii, "'"' ';~ ,,~ll;f,Mif:-i!I._:, ft._P:11 ~,) ,<"~,~.,~,, m , ..~ "~'Tm"'~""'Il~linm!!f':l\'~4;~' ~ (-~:; . ) . , :-:'::1 -'!~ ('"') " ,''', er; '-0' -<' ~,,:'" c; 5 -:::;. ~; ,-~... ~~ ~"'J :~ -c ,- =< A! ,{, {~:;: ,~~~i .!'Ji?>"'?,.\;ii f";i !.'i/l_' <'j>,- >~ Iii" Ai :.i~~.~,':.'.'.:-:...~.'.i.,.i_',,,,'_~.;~:.L.'.:'~."...~~.;~ ,It?~,"',_'1I~~,ijil;F~-H;!:ro~'J_''''''~M~1~~-;:::~1l_lI,,~~Ifr~~.JlfiI~~~r~;~' "":,-:',,;:~0; RUTH C. MILLER, On behalf of her minor son, BRANDON L. SCOTT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. SHAWN STERLING SCOTT, Defendant : NO. 01- 6815 CIVIL TERM : PROTECTION FROM ABUSE ORDE~OR CONTINUANCE AND NOW, this 2~~ January, 2002, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on January 2,2002, at 3:00 p.m., by this Court's Order of December 5, 2001, is hereby rescheduled for hearing on January 10,2002, at 11 :00 a,m. in Courtroom No.3. The TemponllY 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 MidPenn Legal Services Attorney for Plaintiff < ~ ~ J-D!J'O.v 9-, Shawn Scott Pro Se Defendant ;(!",~If!; n,~:~!I;,""i-,-,:?' , ,,',_ ", ,', ,_ " r" ~, , .. j -'~""-"I1!r~li ;;:ffi'~~bti:~JJm~*NH'-'A'i"i:iti,J.<&.."EII;t!tr1itl(~.1J'j'~i',;,IJ,i:;',$.,0it:1>.""'ii~'''',_"', ,,,,,.jk~1~--'d&~~>i:""'~tl~-~' 'l ,-;',k~_"~i,'~~"!_,"'''' , '=~_.._'_ -',....,,~H""-' " ":!iIJtr~~~" ., ~~ ---.-- Fii..ED.~()jT!CE OF T' ,- '''''C)T' "'1 'O"'RY ,:-L~ ~'"!-. , >C..JN .r\! 02J.~N-3 fiti 9:39 CUMBfHLAND COUNTY PENNSYL\\ANIA '"'UjIi-l.jlfiilJ!M ~;' RUTH C. MILLER, On behalf of her minor son, BRANDON L. SCOTT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. SHAWN STERLING SCOTT, Defendant : NO. 01- 6815 CIVIL TERM : PROTECTION FROM ABUSE MOTION FOR CONTINUANCE The Plaintiff, Ruth Miller and Brandon Scott, by and through their attorney, Joan Carey of Legal Services, Inc., 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 on November 29,2001, scheduling a hearing for December 5, 2001, at 2:00 p.m. 2. The Cumberland County Sheriff's Department served Defendant with a certified copy of the Temporary Protection From Abuse Order and Petition for Protection From Abuse at the Cumberland County Prison on November 29,2001. 3. Prior to the hearing on December 5, 2001, Defendant was transferred to the Dauphin County Prison and a Continuance was requested to afford the Sheriff time to transport Defendant. The hearing was rescheduled to January 2,2002, at 3:00 p.m. 4. Legal Services has contacted Defendant and was attempting to negotiate a settlement, but negotiations broke down and a hearing is necessary, 5. The parties agree that the hearing be rescheduled to afford the Sheriff time to transport Defendant from Dauphin County to the hearing. 6. 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, ';'.;j,~JJ~!'1i~ ~,q, ,~ ','f_~' -~_ , ~"" ,.~-~ whichever comes first. WHEREFORE, the 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 eighteen months from the date it was entered or until further Order of Court, whichever comes first. Respectfully submitted, ~ oaifCarey, Attorney for LEGAL SERVICES, IN 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ':'~~J]Jl~:" _7',<' ~>;" t, '."" '-' ~', /'- -'r-,;'- _.!I'! ~a. ,IT "~~,~ . ,,- ,"'~n____' .,~ _ ~~.,~~""_'i.,-ei.(, ",,~. ,~ '" . .~.. .... "~"~~"""""'*liir"" . liBillllllilllI"I"iW C1 C~) 0 C r-v <'"' 'n -055 , tllill :~ ~~: z ~, I ~H8 (f) t> N -<" ~ L /:~{6 !;: C) -n j> '-:- - t ~ zQ ::1: ~""~o L >~ ~ om z ",-,1 =< (.f1 >' <::> :D -< -~ "~-",-;-,,,,,, ." .~_ ,'~-"""~~1'?'~'< ]7 . ,,-,- _~,...~.~m~[5I, V_<, ~ .".,~-_.."..~~~, ~: ".,.~R_,~'gt&,;:mall!!it:_'J"!;'F':';'!J'J'<:"t;""_'?~f):<"";'r;'-'--';"-;"'~i"'",wo^"";+~)~~Wi1!'r'~!i."':":-'~'""~'_~'jI(,,,,';;f,'J-.t;,;"m~~~J!;T~i!.'! RUTH C. MILLER, On behalf of her minor son, BRANDON 1. SCOTT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. SHAWN STERLING SCOTT, Defendant : NO. 01- 6815 CIVIL TERM : PROTECTION FROM ABUSE WRIT OF HABEAS CORPUS AD TESTIFICANDUM And now, this g ~ay of January, 2002, in consideration of the within Petition, a Writ of Habeas Corpus Ad Testificandum is issued directing that the Cumberland County Sheriffs Department bring the defendant, SHAWN STERLING SCOTT, to the Cumberland County Courthouse, Courtroom No.3, at II :00 a.m. on Thursday, January 10,2002. By the Court, (-3'0)... WJ. P-e-wt ~ ~le.u; (ljli} ,f. S~lFf~ ~ .Jis' ,-\:it- ,J.Il,,l,;J!f ,1_~_j -:, ""_,'<;'" _ ,_~ "'''''>'_ "-f' -" :'11 ". ""._ _, ^ _. h_" I" ~f_, ....,,-. 'jtt_i~l!li~A~Mrr~}~~~iii~11t8'-~F~,{"'A'*t';2h""h.~l;;,g~~1,"m.$.th:jjjl~i~{",j< '" "':-"o....,~~~:! 01; ~",-.~' ~ ~ ': . ,..[ ,_"","h '" '~!H ,,~.. '" ". "'''', ~il. F:}".nf:'~:jCF nF ' " ':,<,~'L:(I\ ,()'rARY ,"., I "".cl';',...11 02 JMI -3 JUliO: 20 CUM~fflL/tNO COUNTY rENNSYLV/,NlA ~,~H,..Ll ~], UIllIlILDJ ,w,~,w",liJl,."",,,,..~,.,,,,,",W.,.,,,,,, """ ',,"'" , , RUTH C. MILLER, On behalf of her minor son, BRANDON L. SCOTT, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. SHAWN STERLING SCOTT, Defendant : NO. 01- 6815 CIVIL TERM : PROTECTION FROM ABUSE PETITION FOR WRIT OF HABEAS CORPUS AD TESTIFICANDUM The Plaintiff, by and through his attorney, Joan Carey of Legal Services, Inc" states the following: I. The plaintiff filed a Petition for a Protection from Abuse Order and a Temporary Protection Order was granted on November 29,2001, by this Court. 2. Continuances have been issued and currently there is a hearing scheduled for January 10, 2002, at 11:00 a.m. 3. The defendant is currently incarcerated in the Dauphin County Prison and has been served with a copy of the Temporary Protection Order. WHEREFORE, the plaintiff requests that this Court order the Cumberland County Sheriffs Department to transport the defendant, SHAWN STERLING SCOTT, from the Dauphin County Prison to the Cumberland County Courthouse for the hearing scheduled for January 10, 2002, at 11 :00 a.m. Respectfully submitted, ~~L o!ln Carey Attorney for Plamtlff MidPeun Legal Services 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 ::;~-~::___,-_,><. ',- ~f_"f1""_~_~"o.-_,-__,__~,"-'''T" ,'_""''1,,_~,r.,_,'- ~<' _"'1!1~l? y, . 0 '. .. - 1'r ,r=<"""'il ,""",..,,.. ,V'", .,,,. "~___""_~~~ ._~W -, '""'&<l-"'-'_",~""-';' C{ i!-,,-y,-'",-~'u1t~rk:Yj"l'~crrt~]~iIMTff"'] ~~'~ :~I r"''"--'-~^r-~ITrT'tr :,~",f[lt~:,~"",.,!fll!!].l); ~l ~'__ _.lt~~J~f.5ljlii_!u\~~!jlr,"%,~:q__ .;:~~" l~_,,~_~t!!'f~f~;"M;i~~'l_~^'"";''i'1<~f'i~~W8<-~^,*,'J~~J'J@'~~@tf'i'"W~~~,i'\~~-'~r~[~)}~_:-',:,ft-!j- Ruth C. Miller, On behalf of her minor son, Brandon Lashawn Scott, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-6815 CIVIL TERM vs. Shawn Sterling Scott, Defendant : PROTECTION FROM ABUSE ~RDER OF COURT AND NOW, this~ day ofJanuary, 2002, upon consideration of the attached Petition, the Temporary Protection Order in the above-captioned case entered on November 29,2001, is hereby vacated and the action withdrawn without prejudice to Plaintiff. A certified copy of this Order shall be provided to the Carlisle Police Department by Plaintiff's attorney. By the Court, Joan Carey Attorney for Plaintiff MidPenn Legal Services .~ ~ 1-11~;1.. 9- Shawn Scott Pro Se Defendant J~ fs~, c. P. oJ frtft..J ?~~t).w. ,'. ""',~_ ,--f- ,_, _.- -Vf -I . <" """T. ~ ~~""'"' ';~~I~i;;"if.M~W~~llil;b;i:';7~E~'{,,$~t$i<!i~~tlili;,i~~<%r{'ti,"'t!>i";-lj~'M,'rt,~~l"~li.i'~."'~~M~; ". "..':,.j'- Ill..,i.", ....'>>'.. ....., ~n"'~"~ .",,~,"A", .'~ " , ,~".,. ,__ ~,,~ _ ,~,~. ,",.- , ~~- -',.~- 'f"-~;'[;"""~'''''-;-j;l'IEIl._ nh'_L!i~_~df" H81"- '< F-il \...'1" - LY' :':JT/\~iY (J~~ Jni I 0 1')\'1 '1. r:.:n t. ~.I' ',1 '-" CU I".. """"'~I'I"n/ tv tH::nU",i\U lJU...; \j I PENNSYLVANIA ~ ,- ~ ~~ .., .. '.r"' .. '~"""'i Ruth C. Miller, On behalf of her minor son, Brandon Lashawn Scott, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 01-6815 CIVIL TERM ys. Shawn Sterling Scott, Defendant : PROTECTION FROM ABUSE PETITION TO VACATE ORDER AN!) WITHDRAW ACTION Plaintiff, Ruth Miller, by and through her attorney, Joan Carey, of MidPenn Legal Services, requests that the Court vacate the Temporary Protection Order in the above-captioned case and that the action be withdrawn on the following grounds: I, A Petition for Protection From Abuse was filed and a Temporary Protection From Abuse Order was issued by this Court on November 29,2001. 2. Defendant is currently incarcerated in the Dauphin County Prison and will be incarcerated for a period of time. 3. Plaintifffeels that at this time her son is not in danger and she wishes to withdraw the Protection From Abuse action. 4. Plaintiff requests that the Temporary Protection Order be vacated and the action withdrawn without prejudice to her. 5. A certified copy of this Order will be provided to the Carlisle Police Department >':'~~" ',;c)~1.r", """,_,!,,,,,,,,_*:~;,,,;~;_,",. ~."'_ ~ . -~," ,-.- h 1IlIIll!II! ~- by the attorney for Plaintiff. WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate the Order, and that the action be withdrawn without prejudice to Plaintiff. Respectfully submitted, ~~ Attorney for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 "'!./.J""~,;~)li,",,,,, .., - . - ,~ -~ "~,~r ":,,.,~ "'--~'- .- ^ 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. !l4904, relating to unsworn falsification to authorities. Dated: l-/O-Od I~ Jll;f.1&,- Ruth C. Miller, Plaintiff "~:\}1;~_~;r ~c_~_ ,,,, _. ~,_y. ",: , !I!"!'ll" ,.""",,, . ., , - "---.. ,,' ~, ,~ .,' 1!l!JI!I!""=~",.,,, ,,~< ~,. . ' o\JU1'1ftml '-,-,' "'" ,.,' ... ~ ',,' ,.<0', ,'~ & "_~,,~_, 'r "1-, <. "_'~, '-'d_<Y> "" .C',," "~"',', ,q. 1"" ""-"'illlflfij nliiflimrrc' """'--,'~;".- o ~; -oct rnrr 70" -..'- ~~~:- -(.'- GC. ~- :2.:c' ~=CJ >'(= ??: ::<! r.::~ :"-..l c::. '~~,,' " ',.-J -" ~. t." " ,I'.ft,_ ' , _ ,_)Tp;g~l'ff.,~~~i~@WJWft:"'i\Tff"",_"",,~~!".q~,#t;.<%>&;;l;W&ln~w:j'jj;~~1jPf'Bf>"~W~i!i.;Wi!iW~'J.1l~~,l.~~ff< 01/11/02 FRI 12:39 FAX 717 24~ 6573- CUMB CO PROTHONOTARY 141001 *************************** *** MULTI TN REPORT *** *************************** TXlRX NO INCOMPLETE TX/RX TRANSACTION OK 2931 01]9p2490779 03]9p2405331 04]92438026 PSP CP LS ERROR , , " , orFrCB OF' 'tHE PRO'IllQN:)TARY CUMBERLAND o:xJ/ITrY COlIR1HOOSE ONE COORTHOOSE 3:lUARE CMUS LE. PA. 17013- 3367 (717) 240-6195 FAX (717) 240-6573 v rAT E LEe 0 PIE R TO: PA Sf ATE POLICE - CellI. I''''U&!:,. M, tJ. J...S. FAll; ": 717-249-0779 F'RCM : CURTIS R. LONG RE: Pf'A ORDERS MESSAGE : -1-- NO. 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