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HomeMy WebLinkAbout01-7120 FX LIDDIAN MARCEL STREET, For herself and on behalf of her minor children: DEAN LENIER STREET, JR., and ANTHONY RALPH KINSEY, Plaintiffs Vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW ; NO. 01- 7 J:J.b CIVIL TERM DEAN LENIER STREET, SR., 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 1lL day of December, 2001, at N:OO l1.m., in Courtroom No. -2L.. ofthe Cumberland County Courthouse, 1 Courthouse Square, Carlisle, PA. 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 injail under 23 Pa.C.S. g6ll4. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. g226S, 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. S 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 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. ~-""'i~TWll_J!!!{:,L, k;u""_~"\,I^"""-""'cC"'.'-""C" ",_/:"-f~!'~'-,~'_; _,J ,_..,,~~"R-'f." __', ' .. ,."'~- -:: ',-"- '? ",. . "~~. .. - . -~ ~ ",-- . -. --~ lfiNV!\lA8NN3d AlNnoo Gt!\>'lY?!8vmo I g:O/ !~V 02 J:;a 10 AHV10NOH..C'-,;" jOIJJo~b3!i:I' " 'i ,:,,/ tilBflF, ,rfJ,UUJl-,~.l,l__u,., ,~" l",~_ U-, ,f,___ ,; :_ ' j",,,~ ,~r\~TJI~~o,'l:"'?'-"'_~' _,\$~~~~if~\'Cr-o!fij'iI'1"'-\-~-'f.o") "'"%1'>""~'''_':0}}'>-t~~~~~~T~~~~"~~~~~'~t{f:J.lllj~l!f~~~ ts UDDIAN MARCEL STREET, : In the Court of Common Pleas of for herself and on behalf of her minor children: DEAN LENIER STREET, JR., : CUMBERLAND County, and ANTHONY RALPH KINSEY, Plaintiff : Pennsylvania v. : Civil Action - Law ;No.OI-7/:20 DEAN LENIER STREET, SR., Defendant : Protection From Abuse and : Custody TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: DEAN LENlER STREET, SR., Defendant's Date of Birth is: December 8,1963 Defendant's Social Security Number is: 440-74-6952 Name(s) of All protected persons, including Plaintiff and minor children: I. LIDDIAN MARCEL STREET 2. DEAN LENIER STREET, JR. 3. ANTHONY RALPH KINSEY AND NOW, on 20th Day of December, 2001 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: Plaintiffs request for a temporary protection order is granted. 1. Defendant shall not abuse, harass, stalk or threaten any ofthe above persons in any place where they might be found. ';''if,~,~'j!1: :.:",_..1''''':\,':7"('J:''f_",:,'~''~''''''F,,,,''__N_,-'''''~--__' ,.~ n,v ";,,," ,__ <,' _n ,. ,"'" . ,t 2. Except for such contact with the minor chi1d/ren 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 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 current residence, which is confidential for her protection, and any other residence where she may reside. Plaintiffs place of employment, wherever that may be. The child care facility/residence ofthe child care provider ofthe parties' minor child, Dean Lenier Street, Jr. The school of Plaintiffs minor child, Anthony Ralph Kinsey. 3. Except for such contact with the minor chi1d/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 fma1 hearing in this matter, Plaintiff is awarded temporary custody of the following minor chi1d/ren: 1. DEAN LENIERSTREET, JR. Until the fma1 hearing, all contact between Defendant and the chi1d/ren shall be limited to the following: Pending further Order after the hearing scheduled in this matter, Defendant's contact with the parties' minor child, Dean Lenier Street, Jr., shall be supervised by a responsible third party of Plaintiffs choice. Defendant shall contact Plaintiffs attorneys in this case to arrange visits pending further Order. The 10ca11aw enforcement agency in the jurisdiction where the chi1d/ren are located shall ensure that the chi1d/ren are placed in the care and control of the Plaintiff in accordance with the terms of this Order. . '';:;r~~-::~(~~l ',' .'':'",'' ~''''~,"'--fi ~"'_ ",';";'"~ ,-'c'<' -- " ". ~. -I""~' '~ - - -." . - , ; - - , .., _~._" 5. Defendant shall immediately relinquish any firearms license the Defendant may possess, and the following weapons to the Sheriff's Office or a designated local law enforcement agency for delivery to the Sheriff's Office. 1. brass knuckles. Defendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration of this order. 6. The following additional relief is granted: Defendant is prohibited from having any contact with Plaintiffs relatives and Plaintiffs children listed in this petition, except as the court may find necessary with respect to supervised visitation with the parties' minor child, Dean Lenier Street, Jr. Defendant shall refrain from harassing Plaintiffs relatives. Defendant is enjoined from damaging or destroying any property jointly owned by the parties or owned solely by Plaintiff. 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: PENNSYLVANIA STATE POLICE CARLISLE POLICE DEPARTMENT 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 Petition and Order without prepayment of costs. 9. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL JUNE 20, 2003 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT :V~,\~, ,.JJ,~_.__ '" .' ,"'_~"" ,-''F:o' ';,::"/(, '" __': ""~'"<r- _~'.,_.;"O "~" ,-,,' . ~.- , Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fme of up to $1,000.00 and/or up to six months injail. 23 Pa.C.S. 96114. Consent ofthe Plaintiff to Defendant's retnm 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. 96113. 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. 992261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by 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. 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 connnitted 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 agen se cer made the arrest. Judge r~\;;).o\o \ Date Distribution to: Joan Carey David A. Lopez Attomeys for Plaintiff MidPenn Legal Services 8 Irvine Row, Carlisle, P A 17013 (717) 243-9400 or 1-800-822-5288 I FAXed & mailed to PSP -'''~:<;1ir"':'r:[ mnl, "t', --,~,;"!>,, ".", ." - , - <-",',y '"'-"', :1~'r- -", , '. " ~ - PFAD Number: LG1384806B LIDDIAN MARCEL STREET, : In the Court of Common Pleas of for herself and on behalf of her minor children: DEAN LENIER STREET, JR., : CUMBERLAND County, and ANTHONY RALPH KINSEY, Plaintiff : Pennsylvania v. : Civil Action - Law DEAN LENIER STREET, SR., Defendant ; No. 01-7 J ao : Protection From Abuse and : Custody PETITION FOR PROTECTION FROM ABUSE 1. Plaintiff's name is: LIDDIAN MARCEL STREET 2. I, (the Plaintiff), am filing this Petition on behalf of: - myself - and as Parent of minor Plaintiff(s) 3. Name(s) of ALL person(s), including minor children, who seek protection from abuse. a. UDDIAN MARCEL STREET b. DEAN LENIER STREET, JR. c. ANTHONY RALPH KINSEY 4. Plaintiff's address is confidential "'<~!j': \:'", \'- "'c' --~-'. ,. 'i~--_'~~'_'-'-("N-, ,. " ,-0 \-~ ""'ii',,'- 'IW;:',. ",""-d ,_ "O'_~"_" " '_'," _~" " ~ : 5. Defendant's Name is: DEAN LENlER STREET, SR., 6. Defendant is believed to live at the following address: Motel 6 , 1153 Harrisburg Pike, Room 115 , Carlisle, P A 17013 7. Defendant's Social Security Number is: 440-74-6952 8. Defendant's Date of Birth is: December 8, 1963 9. Defendant's Place of employment is: New England Motor Freight, Inc., 2800 Appleton Drive, Camp Hill, fA. Telephone: (717) 737-3000. 10. Defendant is an adult. 11. The relationship between the Plaintiff and the Defendant is: Parents of the same children Ex-Spouse 12. The Plaintiff and the Defendant been involved in the following court actions: a. Divorce b. Support 13. Other details of the court action are: STREET v. STREET, In Divorce, Cumberland County, No. 00-5497, Civil Action. Filed August 8, 2000, Divorce Decree entered February 13, 2001. STREET v. STREET, In Support (DRO and PACSES Nos. unknown). 14. The defendant has been involved in a criminal court action. "'0f'~"_:L~i[.t..:-;.,_,_ ._ '-,~--V7c___'~;" _ :t-.-;" _C-O' h ,-~' 1_'_ 0 , _ -_,~ 15. The defendant is currently on probation / parole. 16. The defendant is currently on County probation / parole. Description: Cumberland County Adult Probation, Probation Officer Jaime Rivera. 17. Plaintiff and Defendant are the parents of the following minor chi1d/ren: a. DEAN LENIER STREET, JR. Age: 4 years old. Child's address is: Confidential 18. 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. DEAN LENIER STREET, JR. For the past 5 years, this child has lived with: Plaintiff, her 14-year-old son, Anthony Kinsey, and the family they are temporarily residing with at a confidential location for their protection, from December 3, 2001, to the present. Plaintiff, Defendant, and Anthony, at 236 West North Street, Carlisle, PA, from February 2001, to December 3, 2001. Plaintiff, Defendaut, and Anthony, at 29 South High Street, Apt. 3, Newville, PA, from summer 1999, to February 2001. Plaintiff and Defendant, at 29 South High Street, Apt. 3, Newville, P A, from January 1998, to summer 1999. Plaintiff, at an undisclosed location for her protection, from October 1997, to January 1998. Plaintiff and Defendant, at Meadowlands Apartments, Oklahoma City Oklahoma, from early July 1997, to October 1997. Plaintiff, Plaintiffs friend, Roxanne Randazzo, and Ms. Randazzo's 2 children, at 1909 West Oak Road, Vineland, New Jersey, from the date of the child's birth on June 1, 1997, to early July 1997. 19. The following other minor chi1d/ren presently live with Plaintiff: a. ANTHONY RALPH KINSEY Age: 14 years The Plaintiff's relationship to this child is: """'0i~"]"! ~ff ~ ..):,~,..,i':""" ,-Fl".'" _"-_; r _"h'~_ _ -I" .,. Mother 20. The facts of the most recent incident of abuse are as follows: On about Monday, December 17, 2001 location: 236 West North Street, Apt. 9, Carlisle, PA, Plaintiffs apartment. Without Plaintiffs knowledge or permission, Defendant entered Plaintiffs apartment where she was packing her belongings, and attempted to talk her into not attending the sentencing hearing scheduled on December 18, 2001, at 1:30 p.m. on the criminal assault charges pending against him. One of Defendant's bail conditions orders that he not have any contact with Plaintiff. A note that Defendant left at Plaintiffs apartment earlier that day verifies that he was actively searching her out, which exacerbated her fear. 21. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor chi1d/ren, (including any threats, injuries, or incidents of stalking) are as follows: In or about early November 2001, Plaintiff saw Defendant in his vehicle parked in the church parking lot across the street from her apartment. Defendant drove around to the front of Plaintiffs apartment, parked his vehicle on the street, and watched her apartment for approximately an hour. Plaintiff feared for her safety. On or about July 27,2001, Defendant grabbed Plaintiff by the neck, shoved her against the sink, and when she tried to get away from him, he repeatedly punched and slapped her about her head and body, causing her to fall to the floor, and dragged her across the floor. Plaintiffs 14-year-old son, Anthony, called 911 for help. The Carlisle Police responded. Defendant was arrested, charged with simple assault, and taken to Cumberland County Prison. Plaintiff sought medical attention at Carlisle Hospital for injuries she sustained as a result of this incident, which included, but were not limited to, swelling, bruising, and soreness about her head, face, arms, and body, a laceration on her foot, and abrasions on her leg and arm. A preliiminary hearing was held before District Justice Correal, the case was bound over for trial. At the pre-sentencing hearing held on December 18, 2001, before Judge Bayley, Defendant pled guilty to the charge of simple assault, and was sentenced to 3 months of unsupervised probation, fined, and ordered to pay court costs. In or about September 2001, Defendant shoved, slapped and punched, Plaintiffs son, Anthony, about his body. In or about September 2001, during a separate incident, Defendant punched Plaintiff. On or about May 28, 2001, Defendant grabbed Plaintiff, who he knew was approximately 6 weeks pregnant, shoved her down onto the bed, got on top of her and straddled her, punched her about her head, and pushed a pillow over her face preventing her from breathing, and causing her to fear for her life. Within 2 weeks after this assault by Defendant, Plaintiff miscarried her baby. On several occasions since approximately 2000, Defendant has abused the parties' 4-year-old child, Dean, in ways including, but not limited to, hitting him with a belt, demanding that the child touch a hot stove, resulting in a burn blister on Dean Jr. 's finger, and instructing the boy to reach into the toilet -:g,,,,'ij~-':%:,1. -."."";.,,, '<'. ,-"~-,w,,,__,,,-. __"_"~~'.' ,-',_,,_,' "1;', .7"""~_"',_-, - ~ "._, _._, _~_ and pick up feces. In addition, knowing that his that Dean, Jr., takes 3 different medications for Attention Deficit Disorder/Hyperactivity Disorder (ADD/HD), on one occasion when he had the child in his care, Defendant gave the child chocolate candy bars and coffee loaded with sugar. Since approximately 1997, Defendant has abused Plaintiff in ways including, but not limited to, shoving, restraining, slapping, punching, kicking, choking, and pulling her hair. In addition, Defendant has thrown and hit Plaintiff with household obJects such as telephones. Defendant has damaged and destroyed Plaintiff's property breaking several telephones, and a computer stand, and punching holes in walls. On several occasions Defendant has threatened to kill Plaintiff. 22. The Defendant has used, or threatened to use, the following weapon(s) against the Plaintiff or the minor chi1d/ren: a. brass knuckles. 23. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: PENNSYLVANIA STATE POLICE CARLISLE POLICE DEPARTMENT 24. There is an immediate and present danger of further abuse from the Defendant. 25. Plaintiff has suffered out-of-pocket financia110sses as a result of the abuse described above. Those losses are: any and all medical bills resulting from medical treatment Plaintiff required as a result of the incident which occured on or about July 27, 2001. 26. 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 chi1d/ren in any place where Plaintiff may be found. b. Award Plaintiff temporary custody ofthe minor chi1d/ren and place the following restrictions on contact between Defendant and chi1d/ren: Pending further Order after the hearing scheduled in this matter, Defendant's contact with the parties' minor child, Dean Lenier Street, Jr., shall be supervised by a responsible third party of Plaintiffs choice. Defendant shall contact Plaintiffs attorneys in this case to arrange visits pending further Order. c. Prohibit Defendant from having any contact with Plaintiff and/or minor chi1d/ren, either in "'V'!'i~J~) "< '-">1;--'I-:""_<_y:,.._,,',~,,,_~,,,,::-'fc:~-o-_'-'_'r,-w;r.".-",>__'>,__ ,too"~ ,,,~,p ,. "~__7f':' '. - ~ ,",' "'-'--'~',,-'~I""""'-" .._ person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Plaintiff's school, business, or place of employment, except as the court may find necessary with respect to partial custody and/or visitation with the minor chi1d/ren. d. Prohibit Defendant from having any contact with Plaintiff's relatives and Plaintiff's 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. e. Order Defendant to temporarily tum over weapons to the Sheriff of this County and prohibit Defendant from transferring, acquiring, or possessing any such weapons for the duration ofthe Order. f. Direct Defendant to pay P1aintifffor the reasonable financia110sses suffered as the result of the abuse, to be determined at the hearing. g. Order Defendant to pay the costs ofthis action, including filing and service fees. h. Order the following additional relief, not listed above: Order Defendant to refrain from harassing Plaintiffs relatives. Enjoin Defendant from damaging or destroying any property jointly owned by the parties or owned solely by Plaintiff. 1. Grant such other relief as the court deems appropriate. J. 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: k:,h.J ~ c/ Joan Carey tJ Agency: David A. Lopez Attorneys for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 or 1-800-822-5288 ':""''''''~~J,_.,,?,:_': "c_,.,~~,-,j.,"-_h",__~_,_:'h. '_<,~__ .' ., ,,~_* - ., e_', ,;,-, .' ~,. " 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.94904, relating to unsworn falsification to authorities. Dated: /;J- /)/-0/ ",'m,~i':,. 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FAX #: 717-249-0779 .. ~! ~: CURTIS R. LONG RE: PFA ORDERS MESSAGE: --1fl- lID. OF PAGES (Il'Y.:r..UOING COVf:R SHEET) This IlEIi6a1' is intEn:l:d Q11y fur tte I"Q'! of lie irrliv:ida1. cr mti,t;y to...trlch is js cdh. ,j. em <<w a;ntain infi:mmticn ltal: is IriviJ,eg;;d. cmf:ide1t:ial ;;nj eerpt fmn ",,..-,1,,,,, ore m:i!l:' @1 io;n'''~, (f tte ~ oc this" -:J! is rot 1113 inlBlkJ. n;cipiart:. }OJ are ~ rotif:ie1 ltal: iflj dissEmiIetiD1. d.ist:rib..lticn cr CJ::QIin3 of this o::mn.nicatim lli sb:ictly~. If)'W h;r.e :EB:ciwj tillS a:mIU1ir,r.Ja1 in amr. plgB9 o::tify l.8 :inmrliately ~ lBlft:h:re arlleb.Jcn tiE! ~" "<J' to LS at I:t'e fto..,. .dh...,.. via tte D.S. p::atal. fBVit:e. 1la1k:)O.I. '-~-F~''-'''''-'-'>it';-'l'"~~~", '._._ f.m!! 00[1 .~ , ~.Ii!\l:l!fl'II~""",,_ ~ ~ lJ1 SHERIFF'S RETURN - NOT FOUND CASE NO: 2001-07120 P . COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND STREET LIDDIAN MARCEL VS STREET DEAN LENIER SR R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, DEFENDANT STREET DEAN LENIER SR but was unable to locate Him in his bailiwick. He therefore returns the PROTECTION FROM ABUSE , NOT FOUND , as to the within named DEFENDANT , STREET DEAN LENIER SR UNABLE TO LOCATE AT ANY OF THE ADDRESSES PROVIDED. Sheriff's Costs: Docketing Service Affidavit Surcharge 18.00 4.14 .00 10.00 .00 32.14 So a~~~~~ .~ R'. Thomas Kline Sheriff of Cumberland County LEGAL SERVICES 01/24/2002 Sworn and subscribed to before me this .:Io~ day of4 ;lcr(J;L A.D. ~Q~,~, Pro h notary 'n,"'1'f(';~~9"',~",~.. _~. _ ~"'~" -" -, ,"~', 1; - "~,~~ ~ ,","'~ '~-"~ - - " . INSTRUCTIONS TO DEFENDANT The Plaintiff has filed a civi11egal action against you under the Protection From AbuseAct and has obtained a Temporary Protection From Abuse Order. The Plaintiff is prepared to pursue the hearing scheduled in this matter in order to obtain a Final Order of Court which will remain in effect for 18 months. @AS an alternative, you mav settle the case by consenting to the entry of a Final Order of Court. If you wish to settle the case you should call MidPenn Legal Services as soon as possible at (717) 243-9400 or 1-800-822-5288, and ask to speak to the staff person handling the case. The Final Order of Court must be signed by the parties before the scheduled hearing so that the Court can be informed of the settlement and the hearing canceled. In some cases, regardless of whether the case settles, the judge requires that the parties appear for the scheduled hearing, and, in a brief procedure, the judge confirms that the parties understand and consent to the entry of the Final Order of Court. FEES AND COSTS If you do not consent to the entry of a Final Order of Court, the case will be contested and the hearing will proceed as scheduled. At the hearing, if the Plaintiff prevails and the judge grants a Final Order of Court, you will be assessed court costs and fees, a $25.00 domestic violence surcharge, and any other relief that the judge may order, including, but not limited to, $250.00 to Cumberland County, one ofMidPenn Legal Services' funding sources, to pay the cost oflitigating this case. You shonld take the attached documents which have been served on you to your lawyer innnediate1y. You have the right to be represented in this matter. If you do not know of an attorney or cannot afford one, you may contact: Cumberland County Bar Association 2 Liberty Avenue, Carlisle, PA 17013 Telephone: (717) 249-3166 or 1-800-990-9108 ~ LIDDIAN MARCEL STREET, For herself and on behalf of her minor children; DEAN LENIER STREET, JR., and ANTHONY RALPH KINSEY, Plaintiffs Vs. : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA DEAN LENIER STREET, SR., Defendant : CIVIL ACTION - LAW : NO. 01- 7/0>.0 CIVIL TERM : 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 req)lested in the Petition. In particular, you may be evicted from your residence and lose other important rights. F"- A hearing on this matter is scheduled ou the /11 day of December, 2001, at /0. 100 /t.m., in Courtroom No. A of the Cumberland County Courthouse, 1 Courthouse Square, C~rlisle, PA. 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 an4l0rup to six months in jail under 23 Pa.C.S. 96114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federa11aw, 18 U.S.C. 92265, this Order is:enforceab1e anywhere in the United States, triba11ands, 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. 9 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 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. "_;-f,j;;,,~~,^~ ~ T I'C"'..,. _,~ ~ ~, -~ . ~ -~, -~ 7'-' I , ~ 11[-- " LIDDIAN MARCEL STREET, for herself and on behalf of her minor children: DEAN LENIER STREET, JR., and ANTHONY RALPH KINSEY, Plaintiff : In the Court of Common Pleas of : CUMBERLAND County, : Pennsylvania v. : Civil Action - Law ;No.Ol- 7'~ DEAN LENIER STREET, SR., Defendant : Protection From Abuse and : Custody TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: DEAN LENIER STREET, SR., Defendant's Date of Birth is: December 8, 1963 Defendant's Social Security Number is: 440-74-6952 Name(s) of All protected persons, including Plaintiff and minor children: 1. LIDDlAN MARCEL STREET 2. DEAN LENIER STREET, JR. 3. ANTHONY RALPH KINSEY AND NOW, on 20th Day of December, 2001 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: Plaintiffs request for a temporary protection order is granted. 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. -:'":!t""'~;"", ;' f" '~:;",r~-,_ ",-,_,-,,_'<<....:rry,_, __, ,0,'., _ "';""1 ' ., , '-'" --"~-,'- , , " " 2. Except for such contact with the minor chi1d/ren as may be permitted under paragraph 4 of this Order, Defendant is prohibited from having ANY CONTACT with Plaintiff, or any other person protected nnder 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 current residence, which is confidential for her protection, and any other residence where she may reside. Plaintiffs place of employment, wherever that may be. The child care facility/residence ofthe child care provider ofthe parties' minor child, Dean Lenier Street, Jr. The school of Plaintiffs minor child, Anthony Ralph Kinsey. 3. Except for such contact with the minor chi1d/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 chi1d/ren: 1. DEAN LENIER STREET, JR. Until tbe fmal hearing, all contact between Defendant and the child/ren sball be limited to the following: Pending further Order after the hearing scheduled in this matter, Defendant's contact with the parties' minor child, Dean Lenier Street, Jr., shall be supervised by it responsible third party of Plaintiffs choice. Defendant shall contact Plaintiffs attorneys in this case to arrange visits pending further Order. The 10ca11aw enforcement agency in the jurisdiction where the chi1d/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. "~-Pi';'''1>_1'!1i~:W_~~=->-, ""C".>i<.". ~__ "', \' ._.11 ,. ~ 5. Defendant shall immediately relinquish any firearms license the Defendant may possess, and the following weapons to the Sheriff's Office or a designated local law enforcement agency for delivery to the Sheriff's Office. 1. brass knuckles. Defendant is prohibited from possessing, transferring or acquiring any other firearms license or weapons for the duration of this order. 6. The following additional relief is granted: Defendant is prohibited from having any contact with Plaintiffs relatives and Plaintiff's children listed in this petition, except as the court may find necessary with respect to supervised visitation with the parties' minor child, Dean Lenier Street, Jr. Defendant shall refrain from harassing Plaintiffs relatives. Defendant is enjoined from damaging or destroying any property jointly owned by the parties or owned solely by Plaintiff. 7. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: PENNSYLVANIA STATE POLICE CARLISLE POLICE DEPARTMENT 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 Petition and Order without prepayment of costs. 9. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL JUNE 20, 2003 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT --,.i"'''''.'1'1~,",5~_\ ~,~,_,~~_",.~'~".____,,~, ,~, '..1:':""- ,-., -,~ -, - r--- 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. 96114. Consent of the Plaintiff to Defendant's retnm 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. 96113. 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. 992261- 2262. NOTICE TO LAW ENFORCEMENT OFFICIALS T11is Order shall be enforced by 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. 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 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 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. Distribution to: Joan Carey David A. Lopez Attorneys for Plaintiff MidPenn Legal Services 8 Irvine Row, Carlisle, P A 17013 (717) 243-9400 or 1-800-822-5288 "'''''''''0&;)0 r"""'~-~fI>./l. t:_,:,;:\~!i;,F. -\lli r(~-_1~~/r)"':,}; t.;i"~ '~,\/!.;;a ~ t.,-,.,II>J d T '(:'; 'l.F~'" , ,." eq^ "''' llan " , ~ ~n~v~~iHJ .". .;>..' . " C" ,,"""k' Pa .... ;JjfS;JJ,I:id(- 'I., FAXed & mailed to PSP -;-~'''"Y_"'-,~'''''Y,:p,g\, -;~ ~l,J~\l ,- ~ ~ ~.~ PFADNurnber: LGl384806B UDDIAN MARCEL STREET, : In the Court of Common Pleas of for herself and on behalf of her minor children: DEAN LENlER STREET, JR., : CUMBERLAND County, and ANTHONY RALPH KINSEY, Plaintiff : Pennsylvania v. : Civil Action - Law ; No. 01- 1/~ DEAN LENlER STREET, SR., Defendant : Protection From Abuse and : Custody PETITION FOR PROTECTION FROM ABUSE 1. Plaintiff's name is: LIDDIAN MARCEL STREET 2. T, (the Plaintiff), am filing this Petition on behalf of: - myself - and as Parent of minor Plaintiff(s) 3. Name(s) of ALL person(s), including minor children, who seek protection from abuse. a. LIDDIAN MARCEL STREET b. DEAN LENIER STREET, JR. c. ANTHONY RALPH KINSEY 4. Plaintiff's address is confidential ~",,""J;"t\1lMVlF\ )l!i-r,\o, .~, .',~" ~"L_, J _~, _"~ _~" . 5. Defendant's Name is: DEAN LENIER STREET, SR., 6. Defendant is believed to Eve at the following address: Motel 6 , 1153 Harrisburg Pike, Room 115, Carlisle, PA 17013 7. Defendant's Social Security Number is: 440-74-6952 8. Defendant's Date of Birth is: December 8, 1963 9. Defendant's Place of employment is: New England Motor Freight, Inc., 2800 Appleton Drive, Camp Hill, PA. Telephone: (717) 737-3000. 10. Defendant is an adult. 11. The relationship between the Plaintiff and the Defendant is: Parents of the same children Ex-Spouse 12. The Plaintiff and the Defendant been involved in the following court actions: a. Divorce b. Support 13. Other details of the court action are: STREET v. STREET, In Divorce, Cumberland County, No. 00-5497, Civil Action. Filed August 8, 2000, Divorce Decree entered February 13, 2001. STREET v. STREET, In Support (DRO and PACSES Nos. unknown). 14. The defendant has been involved in a criminal conrt action. 'i-":"'lC-!'(*"-*I"!'1i:~''- . ~ . Ji ,J~,,~[ . _. ...,." '1"__ ~. , 15. The defendant is currently on probation / parole. 16. The defendant is currently on County probation / parole. Description: Cumberland County Adnlt Probation, Probation Officer Jaime Rivera. 17. Plaintiff and Defendant are the parents of the following minor chi1d/ren: a. DEAN LENIER STREET, JR. Age: 4 years old. Child's address is: Confidential 18. 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. DEAN LENIER STREET, JR. For the past 5 years, this child has lived with: Plaintiff, her 14-year-old son, Anthony Kinsey, and the family they are temporarily residing with at a confidential location for their protection, from December 3, 2001, to the present. Plaintiff, Defendant, and Anthony, at 236 West North Street, Carlisle, PA, from February 2001, to December 3, 2001. Plaintiff, Defendant, and Anthony, at 29 South High Street, Apt. 3, Newville, PA, from snmmer 1999, to February 2001. Plaintiff and Defendant, at 29 South High Street, Apt. 3, Newville, P A, from January 1998, to summer 1999. Plaintiff, at an undisclosed location for her protection, from October 1997, to January 1998. Plaintiff and Defendant, at Meadowlands Apartments, Oklahoma City Oklahoma, from early July 1997, to October 1997. Plaintiff, Plaintiffs friend, Roxanne Randazzo, and Ms. Randazzo's 2 children, at 1909 West Oak Road, Vineland, New Jersey, from the date of the child's birth on June 1, 1997, to early July 1997. 19. The following other minor child/ren presently live with Plaintiff: a. ANTHONY RALPH KINSEY Age: 14 years The Plaintiff's relationship to this child is: ;",")-~~ -- ,',,>,-,-, ,'" ~, Mother 20. The facts of the most recent incident of abuse are as follows: On about Monday, December 17,2001 location: 236 West North Street, Apt. 9, Carlisle, PA, Plaintiffs apartment. Without Plaintiffs knowledge or permission, Defendant entered Plaintiff's apartment where she was packing her belongings, and attempted to talk her into not attending the sentencing hearing scheduled on December 18, 2001, at 1:30 p.m. on the criminal assault charges pending against him. One of Defendant's bail conditions orders that he not have any contact with Plaintiff. A note that Defendant left at Plaintiffs apartment earlier that day verifies that he was actively searching her out, which exacerbated her fear. 21. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor chi1d/ren, (including any threats, injuries, or incidents of stalking) are as follows: In or about early November 2001, Plaintiff saw Defendant in his vehicle parked in the church parking lot across the street from her apartment. Defendant drove around to the front of Plaintiff's apartment, parked his vehicle on the street, and watched her apartment for approximately an hour. Plaintiff feared for her safety. On or about July 27,2001, Defendant grabbed Plaintiff by the neck, shoved her against the sink, and when she tried to get away from him, he repeatedly punched and slapped her about her head and body, causing her to fall to the floor, and dragged her across the floor. Plaintiffs 14-year-old son, Anthony, called 911 for help. The Carlisle Police responded. Defendant was arrested, charged with simple assault, and taken to Cumberland County Prison. Plaintiff sought medical attention at Carlisle Hospital for injuries she sustained as. a result of this incident, which included, but were not limited to, swelling, b,ruising, and soreness about her head, face, arms, and body, a laceration on her foot, and abrasions on her leg and arm. A preliiminary hearing was held before District Justice Correal, the case was bound over for trial. At the pre-sentencing hearing held on December 18,2001, before Judge Bayley, D,efendant pled guilty to the charge of simple assault, and was sentenced to 3 months of unsupervised probation, fiued, and ordered to pay court costs. In or about September 2001, Defendant shoved, slapped and punched, Plaintiffs son, Anthony, about his body. In or about September 2001, during a separate incident, Defendant punched Plaintiff. On or about May 28, 2001, Defendant grabbed Plaintiff, who he knew was approximately 6 weeks pregnant, shoved her down onto the bed, got on top of her and straddled her, punched her about her head, and pushed a pillow over her face preventing her from breathing, and causing her to fear for her life. Within 2 weeks after this assault by Defendant, Plaintiff miscarried her baby. On several occasions since approximately 2000, Defendant has abused the parties' 4-year-old child, Dean, in ways including, but not limited to, hitting him with a belt, demanding that the child touch a hot stove, resulting in a burn blister on Dean Jr. 's finger, and instructing the boy to reach into the toilet ,,^^";~}~T"~1fIjIl!j') .. .. ~ o~, I ~. , and pick up feces. In addition, knowing that his that Dean, Jr., takes 3 different medications for Attention Deficit Disorder/Hyperactivity Disorder (ADDIHD), on one occasion when he had the child in his care, Defendant gave the child chocolate candy bars and coffee loaded with sugar. Since approximately 1997, Defendant has abused Plaintiff in ways including, but not limited to, shoving, restraining, slapping, punching, kicking, choking, and pnlIing her hair. In addition, Defendant has thrown and hit Plaintiff with household objects such as telephones. Defendant has damaged and destroyed Plaintiffs property breaking several telephones, and a computer stand, and punching holes in walls. On several occasions Defendant has threatened to kill Plaintiff. 22. The Defendant has used, or threatened to use, the following weapon(s) against the Plaintiff or the minor chi1d/ren: a. brass knuckles. 23. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: PENNSYLVANIA STATE POLICE CARLISLE POLICE DEPARTMENT 24. There is an immediate and present danger of further abuse from the Defendant. 25. Plaintiff has suffered out-of-pocket financia110sses as a result of the abuse described above. Those losses are: any and all medical bills resulting from medical treatment Plaintiff required as a result of the incident which occured on or about July 27, 2001. 26. 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 ininor child/ren in any place where Plaintiff may be found. b. Award P1aintifftemporary custody of the minor chi1d/ren and place the following restrictions on contact between Defendant and child/ren: Pending further Order after the hearing scheduled in this matter, Defendant's contact with the parties' minor child, Dean Lenier Street, Jr., shall be supervised by a responsible third party of Plaintiffs choice. Defendant shall contact Plaintiffs attorneys in this case to arrange visits pending further Order. c. Prohibit Defendant from having any contact with Plaintiff and/or minor child/ren, either in '7":,;,,,,"1;~]<;~~~, "_.0_"__" _" ,_ '",,"" '" .~ _~ , , , - person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Plaintiff's 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. Prohibit Defendant from having any contact with Plaintiff's relatives and Plaintiff's children listed in this petition, except as the court may fmd necessary with respect to partial custody and/or visitation with the minor chi1d/ren. e. Order Defendant to temporarily turn over weapons to the Sheriff of this County and prohibit Defendant from transferring, acquiring, or possessing any such weapons for the duration of the Order. . f. Direct Defendant to pay P1aintifffor the reasonable financial losses suffered as the result of the abuse, to be determined at the hearing. g. Order Defendant to pay the costs of this action, including filing and service fees. h. Order the following additional relief, not listed above: Order Defendant to refrain from harassing Plaintiffs relatives. Enjoin Defendant from damaging or destroying any property jointly owned by the parties or owned solely by Plaintiff. I. Grant such other relief as the court deems appropriate. . J. 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: tlt,.,...,1 ~I!-_ ,:.(/ . Joan Carey (J Agency: David A. Lopez Attorneys for Plaintiff MidPenn Legal Services 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 or 1-800-822-5288 o.'+r"~~<!')Ff'" -~ - ~"< -~. ~= , ~ >," - ' 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.94904, relating to unsworu falsification to authorities. Dated: //-IY-J/ ? .'?/ ~ --'~ Ian Marcel Street, Plaintiff , ~ji'e;,i~ill':'1"~~,~",,_"""""m <<_ ,. _, " , ,_ ,.,,- . ~-, ~- - . ~~~~; '.-.2~\i;';;;;''';~'--'' ~~:~':'~;'~~~~:'''T{t-:'~''~'::Jifli1il_~':-' "i'::~,,;-~"(F;-;J:'.-::l'::<"o '_",. ,'~" -- ""~-/ ',<-"'-'/' :.... .C",W_;;,~,-"";,,,N' . {,~- -- ~-,- 1,'V,,,q>>- - '-1 \ ~ ~ '6b ~~ ~ ,W"A , <~~Jlh &:~ YINV/IlASNN3d ]-i !:~ 1-'~'::.1\1:J 10.1 lit! 95 01 .1.. 1, 02 J30 {J IJlI "J.l.finGQ ;",;,'} ";::.::JGHflO ,~JIB3HS J!ll ;10 J81JJO ~~ !Il'J,.!;;,l~L .' 4'!~~~~Wf!!W,~$~l,?-~i'-'i~4t,;-",,~~, """_1,,,,;,:,,~~'_"x':''''f__'''~-s';P~'''f~~\''"fiM'il~~N;ig\i'i'^&''f.W0m;j''''K'~'~~'''~~1l!1!~IA~ r<~ LIDDIAN MARCEL STREET, For herself and on behalf of her minor children: DEAN LENIER STREET, JR., and ANTHONY RALPH KINSEY, Plaintiffs Vs. DEAN LENIER STREET, SR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA : CIVIL ACTION - LAW : NO. 01-7120 CIVIL TERM : PROTECTION FROM ABUSE AND CUSTODY ORDERFORCONT~ANCE AND NOW, this .z.'I day of December, 2001, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on Thursday, December 27, 2001, at 10:00 a.m. by this Court's Order of December 20, 2001, is hereby continued generally. This Order is entered without prejudice to either party to request a hearing. 0 \0\.'. ~- 90& ~it~ -HJ ~,... ./lPt.AJIU2. u..& vt.o-h~ ~ ~ i/ III-h Crl./~The Temporary Protection Prom Abuse Order shall remain in effect for a period of 18 months from the date it was entered, through June 20, 2003, or until further Order of Court, whichever comes first. /' .~ Joan Carey, Attorney for Plaintiff ~ ~~ m~ MidPenn Legal Services 6'{ ,0 \ 8 Irvine Row (' v, -1-'1 Carlisle, PA 170131/- \1}.: 1:f!,!~I~,o_~____' ,'.7~"T_,_ . .,-~"~- -, --~ _ ;'-F "1'" 'cor. ., ~-~ ,~--01-_W ~~~ ~-~~ ^" ~._. ~_.. ~h-"~"-d_'~~'- ~.,~ ,-~ .~,-""- ~ - .-. ViNII^lASNN3d JJ.NnOO C1N,{'lfD81'lnO 61 :6 liV L'2: :J3U \ U l'l:lI:()\~t.'ld: :'- - '..--' - 1\ 'f}J.,,\...:l\/I,_,J,.'''-'4 ...... :!rl'~_I~!n."-(!'~; I,;..i .,)\. ,~,~ " '-' _,. I . 1"11. HI-P.T.~~n"'1__" ,_ _. _,,,,,,"jt!,,,"'1""~~~.@_J.., "~ 1 ,._" ,. .~. _,~i;'!'$;W;},N-'J;~~~1;Jf"":''1!\<i.1il.:'~L'lW':;t"':'!~~:''~~~~~,R#t:~J1\!$'tl~i\W"'!~~I'~~!.i~_ , LIDDIAN MARCEL STREET, For herself and on behalf of her minor children: DEAN LENIER STREET, JR., and ANTHONY RALPH KINSEY, Plaintiffs Vs. DEAN LENIER STREET, SR., Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : CIVIL ACTION - LAW : NO. 01-7120 CIVIL TERM : PROTECTION FROM ABUSE AND CUSTODY MOTION FOR CONTINUANCE Plaintiff, Liddian Marcel Street, by and through her attorney, Joan Carey ofMidPenn Legal Services, moves the Court for an Order continuing generally the hearing in the above-captioned case on the grounds that: 1. A Temporary Protection From Abuse Order was issued by this Court on December 20,2001, scheduling a hearing for Thursday, December 27,2001, at 10:00 a.m. 2. The Cumberland County Sheriff's Department attempted to serve Defendant with a certified copy of the Temporary Protection From Abuse Order and Petition for Protection From Abuse, but was unable to locate him. Defendant moved from his last known address and left no forwarding address, and Defendant was fired from his last place of employment. 3. Plaintiff requests that the hearing be continued generally pending further Order in this matter. 4. Plaintiff requests that the Temporary Protection From Abuse Orderremain in effect- for a period of 18 months from the date it was entered, through June 20, 2003, or until further Order of Court, whichever comes first. '?"''M~"",J_~_, "'"-'"-'!3"'7<}E",','" _'"_'_'_._'_'.""'''' _1,- ".. ., ",,~ ,r'_" ~ , . WHEREFORE, Plaintiff requests that the Court grant this Motion and continue generally this matter, and that the Temporary Protection From Abuse Order remain in effect for a period of 18 months from the date it was entered, through June 20, 2003, or until further Order of Court, whichever comes first. Respectfully submitted, oan Carey, Attorney fo aintiff MidPenn Legal Services 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 ','$~'j;;-~~ v '~'~'~"~,' ,~,~ ~-,. of' " . "-"'~", '1: - ,-- ~ - ':f'~:1ri[ll<(^_ -~"~-- ~. ,'. """,-"",., ,~O ,- A',.." 0 Co ,",..';.; -'o',{ _~~_ ,;",r' J_;""'",~'" ;_~h- ,- ." ,-, . j'e,- " .;:., ,,-, "'"" '" ,;-""" , """,,,""~ _o~^' -;,.'J'J"",,"""~_ ~,~" - -, 0 1::;' 0 C "Tl ~:: Cl f -0 (J" ,'1 F: fTilT1 " Z:J:i N ,. 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