HomeMy WebLinkAbout01-06976
REBECCA SUE GRAHAM,
Plaintiff
: IN THE COURT OF COMMON PLEAs
vs.
: OF CUMBERLAND COUNTY, PENNSYL VANIA
; NO. 01 -(p91fo CIVIL TERM
T~OTHYDAVIDSTARNE~
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. Il f11
A hearing on this matter is scheduled for the ~ day of December, at 3: or::> in
Courtroom No.3- 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.
~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 TillS PAPER TO YOUR LAWYER AT ONCE. YOU
HAVE THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEARING.
THE COURT WILL NOT, HOWEVE~ APPOINT A LAWYER FOR YOlU. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORl> ONE, GO TO OR TELEPHONE THE
OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELD.
IF YOU CANNOT FIND A LA WYE~ YOU MAY HAVE TO PROCEED WITHOUT
ONE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LmERTY AVENUE
CARLISLE, PENNSYL VANIA 17013
TELEPHONE NUMBER: (717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities and
reasonable accommodations available to disabled individuals having business before the
court, please contact our office. 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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Rebecca Sue Graham
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND ~OUNTY,
: PENNSYL VANIA
Plaintiff
v,
Timothy David Starner
~ No, Ol-(PQ1/P
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
Defendant
TEMPORARY PROTECTION FROM ABUSE
ORDER
Defendant's Narne is: Timothy David Starner
Defendant's Date of Birth is: October 29, 1970
Defendant's Social Security Number is: 163-70-4451
Name(s) of All protected persons, including Plaintiff and minor children:
L Rebecca Sue Graham
AND NOW, on 11th Day of December, 2001 UpOll consideration of the attached
Petition for Protection from Abuse, the court hereby enters the following Temporary
Order:
Plaintiffs request for a temporary protection order is granted.
1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in
any place where they rnight be found,
2. Defendant shall be evicted and excluded from the residence at:
22 East Street, Apt. 6, Mt. Holly Springs
or any other permanent or temporary residence where Plaintiff or any other
person protected under this Order may live, Plaintiff is granted exclusive
possession of the residence. Defendant shall have no right or privilege to enter or
be present on the premises of Plaintiff or any other person protected under this
Order.
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3. Except for such contact with the minor child/ren as may be permitted under
paragraph 5 of this Order, Defendant is prohibited from having ANY CONTACT
with Plaintiff, or any other person protected under this Order, at aIo/ location,
including but not limited to any contact at Plaintiffs school, busin~ss, or place of
employment. Defendant is specifically ordered to stay away from the following
locations for the duration of this order,
Plaintiffs place of employment, Knouse Foods.
4. Except for such contact with the minor child/ren as may be permitted under
paragraph 5 of this ilider, 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. Pending the outcome of the fmal hearing in this rnatter, Plailltiffis awarded
temporary custody of the following minor child/ren:
1. Destini Starner
2, Kayli Starner
Until the final hearing, all contact between Defendant and the child/ren shall be
limited to the following:
At times and places mutually agreeable to the parties.
The local law enforcement agency in the jurisdiction where the child/ren are
located shall ensure that the child/ren are placed in the care and control of the
Plaintiff in accordance with the terms of this Order.
6. The following additional relief is granted:
- Defendant is prohibited from having any contact with Plaintiffs relatives,
except as the court may find necessary with respect to partial custody and/or
visitation with the minor child/ren.
- Defendant is ordered to pay the costs of this action, including filing and
service fees.
7. A certified copy of this Order shall be provided to the police depamnent where
Plaintiff resides and any other agency specified hereafter:
Mt. Holly Springs Police Department
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8. 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 Petitioll and Order without
prepaymellt of costs,
9. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL JUNE 11,2003 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 fille of up to $1,000.00 and/or
up to six months injail, 23 Pa,C,S, ~6l14, 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 eIder 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, SS2261-
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 5 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 ill 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.
I Judge
Fh..Kr
Distribution to:
Legal Services
Faxed & Mailed to PSP
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PFAD Number: HS1379999E
Plaintiff
: IN THE COURT OF COMMON
: PLEAS OF
: CUMBERLAND COUNTY,
: PENNSYLVANIA
Rebecca Sue Graham ,
v,
: No.
Timothy David Stamer
Defendant
: CIVIL ACTION - LAW
: PROTECTION FROM ABUSE
PETITION FOR PROTECTION FROM ABUSE
1, Plaintiff's name is:
Rebecca Sue Graham
2. I, (the Plaintift), am filing this Petition on behalf of:
~ myself
3, Name(s) of ALL person(s), including minor children, who seek protection from
abuse.
a. Rebecca Sue Graham
4. Plaintiff's Address is: 22 East Street, Apt. 6, Mt. Holly Springs, PA 17065
5, Defendant's Name is:
Timothy David Starner
6, Defendant is believed to live at the following address:
8 Park Street, Mt. Holly Springs, P A 17065
7. Defendant's Social Security Number is:
163-70-4451
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8, Defendant's Date of Birth is:
October 29, 1970
9, Defendant's Place of employment is:
Shaffer Brothers Construction (machinest)
10, Defendant is an adult.
1 L The relationship between the Plaintiff and the Defendant is:
Ex-Spouse
12. The defendant has been involved in a criminal court action.
13, The defendant is not currently on probation / parole
14, Plaintiff and Defendant are the parents of the following minor child/ren:
a. Destini Starner
Age:9
Child's address is: 22 East Street, Apt. 6 , Mt Holly
Springs, P A 17065
b. Kayli Starner
Age:5
Child's address is: 22 East Street, Apt. 6 , Mt Holly
Springs, P A 17065
15, 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, Destini Starner
For the past 5 years, this child has lived with:
Plaintiff - 22 East Street, Apt.6, Mt. Holly Springs P A 4/2001
- present
Defendant - 8 Park Street, Mt. Holly Springs P A 10/2000 -
4/2001
Plaintiff & Defendant - 8 Park Street, Mt. Holly Springs P A
1996 - 10/2000
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b, Kayli Starner
For the past 5 years, this child has lived with: I
Plaintiff - 22 East Street, Apt.6, Mt. Holly SpringsP A 4/2001
- present
Defendant - 8 Park Street, Mt. Holly Springs P A 10/2000 -
4/2001
Plaintiff & Defendant - 8 Park Street, Mt. Holly Springs P A
1996 - 10/2000
16. The facts of the most recent incident of abuse are as follows:
On about Wednesday, November 21, 2001 at approximately 2:45AM
location: Plaintiff's residence
Defendant entered Plaintiff's residence, and while she was sleeping, he
unzipped her pants. When Plaintiff awoke and questioned Defendant as to
what he was doing, Defendant's reply was that he was "coming in to see what
was going on." Plaintiff told Defendant to leave and she fIled III report with Mt.
Holly Springs Police who charged Defendant with criminal trespass, criminal
attempt of indecent assault, and burglary. A preliminary hearing has been
scheduled.
17, Prior incidents of abuse that the Defendant has committed against Plaintiff or the
minor childlren, (including any threats, injuries, or incidents of stalking) are as
follows:
On or about December 25, 2000, Plaintiff was sleeping on a couch when she
woke up to defendant unbuttoning her pajamas. Plaintiff got up and went to
her mother's room to sleep for the evening.
In or around 1999, Defendant grabbed Plaintiff and threw her down in an
alleyway. Police were called and charged Defendant with harassment, public
drunkeness, and disorderly conduct.
On another occasion in 1999, Defendant pinned Plaintiff to a wall, spit in her
face, and slapped her in the face with an open hand several times.
In or around 1994, Defendant grabbed Plaintiff off of the couch by her wrists
and threw her into a television set.
18. The police department(s) or law enforcement agencies that should be provided with
a copy of the protection order are:
Mt. Holly Springs 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
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residellce:
22 East Street, Apt. 6, Mt. Holly Springs, P A
Rellted By:Rebecca Graham
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 frorn abusing, threatening, harassing,or
stalking Plaintiff and/or minor child/ren in any place where
Plaintiff may be found.
b, Evict/exclude Defendant from Plaintiff's residence and prohibit
Defelldant from attempting to enter any temporary or permanent
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:
At times and places mutually agreeable to 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/ren,
e, Prohibit Defendant from having any contact with Plaintiff's
relatives and Plaintiff's children listed ill 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 the costs of this action, includillg filing
and service fees,
g, Grant such other relief as the court deems appropriate,
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h, Order the police or other law enforcement agency to serve the
Defendant with a copy of this Petitioll, any Order issued, and the
Order for Hearing, The petitioner will inform the desi$I1ated
authority of any addresses, other than the Defendant's tesidence,
where Defendant can be served.
Respectfully Submitted by:
oan Carey, Attorney
Agency: MidPenn Legal Services
8 Irvine Row
Carlisle, PA 17013
(717) 243~9400
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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:
/2/1/2rYJI
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l2{ian'L
m, Plaintiff
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12/12/01 WED 10: 23 FAX 717 240 6573
CliMB CO PROTHONOTARY
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OFFICE OP TIlE PRCm-lCl'oPThR'f
CUMBERLAND CCXJNiY OOURWWSE
():IlE CWFn'HWSE SQUARE
CARLISLE, PI\.. 1701)-3387
(717) 240-6195
FAX (717) 240~6573
V I I\. TEL E COP I E R
TO:
PA. STATE POLICE - Ce"l. ,q"e.e ~~. . JIll. (J. J...r .
fAX ":
717-249-0779
FilO'1 :
CURTIS R. LONG
RE:
PFA ORDERS
MESSAGE :
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SHERIFF'S RETURN ~ REGULAR
CASE NO: 2001-06976 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GRAHAM REBECCA SUE
VS
STARNER TIMOTHY DAVID
HAROLD WEARY
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE
was served upon
STARNER TIMOTHY DAVID
the
, at 1035:00 HOURS, on the 12th day of December, 2001
DEFENDANT
at SHAEFFER BROTHERS
405 N EAST STREET
CARLISLE, PA 17013
by handing to
TIMOTHY DAVID STARNER
a true and attested copy of PROTECTION FROM ABUSE
t0gether with
and at the same time directing His attention to the contents thereof,
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18,00
3,25
.00
10,00
,00
31,25
So Answers:
r~~"<~
R, Thomas Kline
12/13/2001
LEGAL SERVICES
Sworn and Subscribed to before
By:
~/!~/'
Deputy She ff
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Rebecca Sue Graham,
Plaintiff
: IN THE COURT OF COMMON PLEASE OF
: CUMBERLAND COUNTY, PENNSYL VANIA
vs,
: NO, 01~6976 CIVIL TERM
Timothy David Stamer,
Defendant
: PROTECTION FROM ABUSE
ORDER FOR CONTINUANCE
AND NOW, 1bi'.tt~ ,fD,_b~, 2001, ""on "',,;.remtioo of rl"
attached Motion for Contilluance, the matter scheduled for hearing on Decernber 19,
2001, at 3:00 p,rn" is hereby generally continued,
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 ,
Attorney for Plaintiff (l0'j)...\..t..D '", \
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Timothy Stamer RV 5
Pro Se Defendant 'J\
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Rebecca Sue Graharn,
Plaintiff
: IN THE COURT OF COMMON PLEASE OF
: CUMBERLAND COUNTY, PENNSYLVANIA
vs,
: NO, 01-6976 CIVIL TERM
Timothy David Starner,
Defendant
: PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
The Plaintiff, Rebecca Sue Graham, by and through her attorney, Joan Carey of
MidPenn Legal Services, moves the Court for an Order generally contilluing the matter in
the above-captioned case on the grounds that:
1, A Temporary Protection From Abuse Order was issued by this Court on
Decernber 12,2001, scheduling a hearing for Decernber 19,2001, at 3:00 p,m,
2, Defendant was served by the Cumberland County Sheriffs Department on
December 12, 2001.
3, Defendant contacted MidPenn Legal Services and indicated that he would
sign a Consent Agreement.
4, The parties request an Order generally continuing the rnatter to afford them
time to execute a Consent Agreement.
5, The Plaintiff requests that the Temporary Protectioll From Abuse Order
remains 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
generally continue this matter, and that the Temporary Protection From Abuse Orders
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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 subrnitted,
k~..
Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
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Rebecca Sue Graharn
: IN THE COURT OF COMMON
: PL'EAS OF
: CUMBERLANDiCOUNTY,
: PENNSYL V ANI}\
Plaintiff
v.
: No, 01~6976
Timothy David Starner
: CIVIL ACTION.. LAW
: PROTECTION FROM ABUSE
Defendant
FINAL ORDER OF COURT
Defelldant's Name is: Timothy David Starner
Defendant's Date of Birth is: October 29, 1970
Defendant's Social Security Number is: 163-70-4451
Name(s) of All protected persons, including Plaintiff and rninor
children:
1, Rebe~raham
AND NOW, this ' ..~ ~"~ ~~ il'?;:he court having
jurisdiction over the parties and the subject-matter, it is ORDERED,
ADJUDGED and DECREED as follows:
Upon agreement of the parties for the entry of a consent order, this
order will be entered without any admission of liability by the
defendant and without a finding of abuse by this court:
Plaintiff's request for a final protection order is granted.
1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any
other protected person in any place where they might be found,
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2. Defendant is completely evicted and excluded from the residence at:
22 East Street, Apt. 6, Mt. Holly Springs, Pennsylvania, I except
for the purpose of facilitating custody at which times Dtifendant
shall wait outside the residence.
or any other residence where Plaintiff or any other person protected
under this Order may live, Exclusive possession of the residence is
granted to Plaintiff, Defendant shall have llO right or privilege to
enter or be present on the premises of Plaintiff or any other person
protected under this Order.
3. Except as provided in Paragraph 5 of this Order, Defendallt is
prohibited from having ANY CONTACT with the Plaintiff, or any
other person protected under this Order, at any location, including
but not limited to any contact at Plaintiffs school, busilless, or place
of employement. Defendant is specifically ordered to stay away
from the following locations for the duration of this order,
Plaintiffs place of employment, Knouse Foods.
Contact between Plaintiff and Defendant regarding the parties'
children shall not be deemed a violation of this Order.
4. Except as provided in Paragraph 5 of this Order, Defendant shallllot
contact the Plaintiff, or any other person protected under this Order,
by telephone or by any other means, including through third
persons,
5. Custody of the following minor children:
1, Destini Starner
2, Kayli Starner
shall be as follows:
. Primary physical custody of the minor
child/ren is awarded to the Plaintiff.
. See attached Custody Order.
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6. The following additional relief is granted as authorized by ~6108 of
the Act:
- Defendant is prohibited from having any contact with I
Plaintiffs relatives, except with respect to partial custOlJy and/or
visitation with the minor children.
The court costs and fees are waived.
7. A certified copy of this Order shall be provided to the police
department where Plaintiff resides and any other agency specified
hereafter:
Mt. Holly Springs Police Department
8. THIS ORDER SUPERSEDES:
1. ANY PRIOR PF A ORDER
9. All provisions of this order shall expire on: June 18, 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, S6114,
VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION
AND CRIMINAL PENAL TIES UNDER THE PENNSYL V ANlA
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 SS2261-2262, 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
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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 plaintiffs residence OR any
location where a violation of this order occurs OR where the d~fendant
may be located, shall enforce this order, An arrest for violatiotj. of
Paragraphs I through 5 of this order may be without warrant, ~ased
soley on probable cause, whether or not the violation is comm[tted 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 or4et or
during prior illCidents of abuse, The Cumberland CountySh~riff '
shall maintain possession of the weapons until further order of this
Court,
Whell the defendant is placed under arrest for violation ofthisi order,
the defendant shall be taken to the appropriate authority or au~orities
before whom defendant is to be arraigned, A "Complaint for Ipdirect
Criminal Contempt" shall then be completed and signed by th~ police
officer OR the plaintiff, Plaintiffs presence and signature are bot
required to file the cornplaint.
If sufficient grounds for violation of this order are alleged, the
defendant shall be arraigned, bond set and both parties given 1I-otice of
the date of the hearing.
identj
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J n Carey
Attorney for Plaintiff
MidPenn Legal Services
8 Irvine Row
Carlisle, P A 17013
(717) 243-9400
Distribution to: ' .
MidPenn Legal Services ~ ~ 1- /t,..o .b
Timothy Starner, Pro Se Defendari't ~ bl. H
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Rebecca Sue Graharn,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYL VANIA
vs.
: NO, 01-6883 CIVIL TERM
Timothy David Starner,
Defendant
: PROTECTION FROM ABUSE
: AND CUSTODY
.-fA.. CU TODY ORDE :zoD1-.
AND NOW, this ~ ~~ of , 1, n consideration of the parties' Consent
Agreement, the following Order is entered with regard to custody of the parties' children, Destini
and Kayli Starner,
1. The plaintiff, hereinafter referred to as the mother, shall have primary physical and
legal custody of the children,
2, The defendant, hereinafter referred to as the father, shall have partial custody
according to the following schedule:
a, Every Saturday from 1 I :00 a,m, until Sunday at 4:00 p,m, subject to
mother's right to custody for an entire weekend each month upon
notice to the father of her intended weekend,
b, Any other times that are mutually agreed upon by the parties,
3. Each parent will notify the other immediately of medical emergencies which arise
while the children are in that parent's care,
4, Neither party shall do anything which may estrange the children from the other parent,
or injure the opinion of the children as to the other parent or which rnay hamper the free and
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natural development of the children's love or respect for the other parent.
By the Court,
If entered pursuant to the consent of Plaintiff and Defendant:
n Carey, Attorney fo
MidPenn Legal Services
7 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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01/16/02 WED 16:07 FAX 717 240 6573
CUMB CO PROTHONOTARY
I
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*** MULTI TN REPORT ***
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[ OIl 9p2490779
[ 03]9p2405331
[ 04]92438026
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OFfICE OF THE PROTllO\\J'l'AHY
CUMBERLAND CCXJNTY COUR11-lCXJSE
eM; mJR'IHOOSE SQUARE
CARLISLE, PA. 17013-3387
(717) 240~6195
FAX (717) 240~6573
V I ATE LEe 0 PIE R
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I'A STATE POLLCE ~ (!e.'\I'I. P.tDee$.S.. ~.
fAX ~:
717-249-0779
fRQ<1 :
CURTIS R. LONG
RE:
PFA ORDERS
MESSAGE:
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