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wcek shall be determined by the agreement ol'thc parties through continued communication.
d) The petitioncr shall transport the child 10 rcspondent for his periods of partial
custody, at the end of which respondent shall transport the child back to petitioner.
7. TIle respondent is aware that petitioner will be moving from this jurisdiction and enters
this agreement notwithstanding petitioner's imminent departure.
8. The respondent has been advised that the undersigned counsel represents the petitioner
alone, and that he has the right to rctain separate counsel to represent his interests. With this
information and understanding his rights, respondent has chosen to represent himself and to enter
this agreement.
9. The parties intend to be legally bound by this agreement, and they intend that this
agreement will be entered as an Order of Court.
DONALD M. MARRITZ
Staff Attorney
Robert E. Rains, Supervising Attorney
Thomas M. Place, Supervising Attorney
FAMILY LAW CLINIC
4S North Pitt Street
Carlisle, P A 17013
717-243-2968
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Tara L. Dukes,
Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION.LAW
IN PROTECTION FROM ABUSE
Kevin R. Knight,
Respondent
NO. 99- (<(('If ~ CIVIL TERM
CONSENT AGREEMENT AND FINAL ORDER
0;1"
This Agreement is entered on this 2.l day of April, 1999, by the petitioner, Tara L.
Dukes, and the respondent, Kevin R. Knight, each of whom is represented by counsel, as
indicated below. Without admiuing the allegations of abuse, the respondent agrees that the
Court shall enter an Order containing the following terms:
I. Respondent shall not abuse, cause reasonable fear of abuse, threaten with violence,
or harass petitioner, whether personally or through his agents.
2. Respondent shall not enter any of petitillner's present or future places of employment.
3. Except for contact pertaining to the parties' minor child, Khaila R. Knight, the
respondent shall not have any direct or indirect contact with the petitioner including, but not
limited to, telephone and written communications.
4. Except for necessary contact pertaining to the minor child, respondent agrees not to
trespass at petitioner's address.
5. Respondent shall not to harass or stalk petitioner or petitioner's relatives.
6. The Carlisle Police Department shall be provided with a certified copy of this Order
by the petitioner's attorney. This Order shall be enforced by any law enforcement agency where
a violation occurs, by arrest for indirect criminal contempt without warrant upon probable cause
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that this Order has been violated, whcther or not the violation is commilled in the presence of
the police officer. In the evcnt that an arrcst is made, undcr this section, thc respondent shall
be taken without neccssary delay beforc thc court that issucd thc order. Whcn that court is
unavailable, the respondent shall be taken before the appropriatc district justice. (231',S. ~6113).
7. The parties intend to be legally bound by the terms of this agrcement and request that
a Protection Order be entered to reflect the above terms. The respondent has been advised of
his right to have a hearing.
8. BRADY INDICATOR:
a) The Petitioner and the Respondent have cohabited together and have one (I)
child together, Khaila R. Knight.
b) This order is being entered after a hearing of which the Respondent received
actual notice and had an opportunity to be heard.
c) This Order restrains the Respondent from harassing, stalking, or threatening
the Petitioner.
d) Respondent represents a credible threat to the physical safety of the Petitioner.
e) The terms of this Order prohibit Respondent from using, attempting to use,
or threatening to use physical force against the Petitioner or protected person that would
reasonably be expected to cause bodily injury.
9. THIS ORDER SUPERSEDES ANY PRIOR PFA ORDER.
10, All provisions of this order shall expire in one year, on April 2.L, 2000,
however the Petitioner may ask the Court, after notice and hearing, to extend the term of the
Order, pursuant to 23 Pa. C.S. ~ 6108(e).
.
~
NOTICE TO TilE RESPONDENT
VIOLATION OF TillS ORDER MAY RESULT IN YOUR ARREST ON TIlE
CHARGE OF INDIRECT CRIMINAL CONTEMPT WIIICIIIS PUNISHABLE BY A FINE
OF UP TO $1,000.00 AND/OR A JAIL SENTENCE OF UP TO SIX MONTIIS. 23 PA.C,S.
fi 6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL
PENALTIES UNDER TIlE PENNSYLVANIA CRIMES CODE. TIllS ORDER IS ENFORCE-
ABLE IN ALL FIFTY (50) STATES, TilE DISTRICT OF COLUMllIA. TRIBAL LANDS,
U.S. TERRITORIES AND TIlE COMMONWEALTH OF PUERTO RICO UNDER THE VIO-
LENCE AGAINST WOMEN ACT, 18 U.S.C, ** 2261.2262. IF YOU TRAVEL OUTSIDE
OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER YOU MAY BE SUB.
JECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C. fifi 2261
-2262. UNDER PARAGRAPH 10. YOU MA Y BE SUBJECT TO FEDERAL PROSECUTION
AND PENALTIES UNDER TilE "BRADY" PROVISIONS OF THE GUN CONTROL ACT,
18 V.S.C. ** 922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR
AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over the petitioner's residence OR any location where
a violation of this order occurs OR where the respondent may be located, shall enforce this
order. An arrest for violation of Paragraphs 1 through 7 of this order may be without warrant,
based solely on probable cause, whether or not the violation is commilled in the presence of the
police. 23 Pa.C.S. fi 6113.
Subsequent to an arrest, the police officer shall seize all weapons used or threatened to
be used during the violation of the protection order or during prior incidents of abuse. When
the respondent is placed under arrest for violation of the order, the respondent shall be taken to
the appropriate authority or authorities before whom respondent is to be arraigned. A
"Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police
officer OR the petitioner. Petitioner's presence and signature are not required to file the
complaint.
If sufficient grounds for violation of this order are alleged, the respondent shall be
arraigned, bond set and both parties given notice of the date of the hearing,
L ---./ / 0
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?ra L. Dukes, r~ti6ner
v
B~ Raney6
Certified Legal Intern
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Wayne Shade, Esquire
Counsel for Respondent
Tara L. Dukes,
Petitioner
v.
IN TilE COURT OF COMMON PLEAS OF
CUMDERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION.LAW
IN PROTECTION FROM ABUSE
Kevin R. Knight,
Respondent
NO, 99 . 1'6'1 j.. CIVIL TERM
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT, If you wish to defend against the claims set forth in the
following pages, 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 frorn your residence and lose other important rights.
A hearing on the mailer is scheduled for theK.a. ,day of April 1999, at J:co o'clock 1.m., in
Courtroom I at the Cumberland County Courthouse, Carlisle, Pennsylvania.
.
You MUST obey the Order that is allached 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 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
(717) 249-3166
Tara L. Dukes,
Petitioner
IN TIlE COURT OF COMMON PLEAS OP
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION PROM ABUSE
v,
Kevin R. Knight,
Respondenl
NO, 99 - 'if.2- CIVIL TERM
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendanl'S Name: Kevin R. Knight
Respondent's Date of Birth: 2-9-71
Respondent's Social Security Number: 186-66-2487
Name of Person Protected: Tara L. Dukes
,
AND NOW, this "?O ~ay of March, 1999, upon consideration of the attached Petition for Protection
From Abuse, the court hereby enlers the following Temporary Order:
1. Respondent shall not abuse, harass, stalk or threaten any of the above persons in any place where they
might be found.
2. Respondent is excluded from any residence where Petitioner may be living.
3. Respondent is prohibited from having any contact with Petitioner at any location, including but not
limited to any COnlaet at Petitioner's school, business, or place of employment, except as necessary
concerning the care and custody of their child.
4. Respondent shall not contact Petitioner by telephone or by any other means, including through third
persons, except Petitioner's attorneys.
5. A certified copy of this Order shall be provided to the Carlisle Police Department.
6. THIS ORDER APPLIES IMMEDIATELY TO RESPONDENT AND SHALL REMAIN IN EFFECT
UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING.
Tara L. Dukes,
Petitioncr
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
v,
Kevin R. Knight,
Respondent
NO. 99 - /3f'.2.- CIVIL TERM
I'ETITION liOR PROTECTION FROM ABUSE
1. Petltloncr's nalllc is: Tura L. Dukes
2, 111111 filing this Petition on behalf of myself.
3. NlIl11e of person who is seeking protection from abuse: Tara L. Dukes
4. Petitioner's address is confidential.
S. Respondenl is belicved to live at the following address: 7 Belly Nelson Ct., Carlisle
Respondcnt's Social Security Number (if known) is: 186-66-2487
Respondent's date of birth is: 2-9-71
Respondcnt's place of employment is: N/A
6. Petitioner and Respondent have lived together in the past and have one child together.
7. Petitioner previously filed a Protection From Abuse Action in Dauphin County in March 1999, but
voluntarily discontinued it upon Repondent's promise that he would seek counseling.
8. Respondent is currently facing simple assault charges as a result of the most recent incident alleged
below.
9. Petitioner IInd Respondent are the natural parents of Khaila R. Knight, born 2-13-97.
The child is currently living with Respondent's parents. The Petitioner has not been allowed to have
any physical contact with Khaila since March 13, 1999.
10, There is no existing custody order pertaining to Khaila. The child has lived with the following
pcople, at the following adrresses,
Persons child lived with
Father, Mother & Siblings
"
Address
445 Radcliffe Drive, Harrisburg
5082 Lilac Lane, Harrisburg
4941 Highland Street, Harrisburg
When
Dec 98 - Mar 99
Jun 98 - Dec 98
Jun 96 - Jun 98
"
,.
11. The following other minor children prescntly live with Petitioner:
Name(s) ~ Petilioner's relalionshiD to children
Shawn Butler, Jr. 3 Mother
Latresha L. Dukes 5 Mother
Jessica Martinez 13 Guardian
12. The facts of the most recent incident of abuse are as follows:
Approximate Date: 3-13-99 Approximate Time: 10:00 a.m. Place: Motel (6) Six, Carlis1e,PA
On or about this date the Respondent entered the parties' hotel room. An argument ensued, after which
the Petitioner asked the Respondent to leave. He came into the bathroom, punched her in the head and
bit her arm, both of which caused her substantial pain.
13. The Respondent has committed prior acts of abuse against Petitioner, including but not limited to the
following:
a) On or about February 15th, 1999, in Harrisburg, the Respondent followed the Petitioner all day while
she was running errands. He periodically called her throughout the day and told her exactly what she
was doing. He flattened the tires of her car. As a result of this course of conduct, Petitioner reasonably
feared bodily injury.
b) Sometime between during February, 1999, at 445 Radcliffe Road, in Harrisburg, the Respondent
came to the Petitioner's house to pick up their daughter. An argument followed and the Petitioner asked
him to leave. As she was trying to close the door, Respondent hit her in the face and tried to pull the
child out the door. After the incident the Respondent hid in her apartment complex and watched her
for a few hours. He kept calling her and leaving threatening messages, As a result of this course of
conduct, Petitioner feared of serious bodily injury.
c) On or about December 25th, 1998, at 445 Radcliffe Road, in Harrisburg, the Petitioner's family had
gotten together for holiday dinner. The Respondent was there and was unhappy with the Petitioner.
She asked him to leave and he would not. Then he threatened to take Khaila away from her and kicked
in her door. Petitioner believed she was in danger of imminent serious bodily injury.
d) Sometime during November, 1998, the Respondent came into a public restaurant where Petitioner was
eating and confronted her. He punched her in the face. Later, when the parties were outside in the
parking lot, he choked her, causing her substantial pain.
e) Sometime in the fall of 1997, at 1276 Oyler Road, in Harrisburg, the Respondent had been drinking
and an argument oceured. The Respondent broke a kitchen chair and hit the Petitioner with a piece of
it, causing her substantial pain.
f) While the petitioner was pregnant with Khaila, in January, 1997, the Respondent pushed her against
the wall and caused her substantial pain. She then went to the hospital, where she went into premature
labor and delivered the child.
14, Idemify the police tlepartmelll or Jaw enforcement agency in thc area in which Petitioner lives that
should he provided wilh " copy of the protection order: Carlisle Police Department
15, '11lere is an immediule "nd presenl danger of further abuse from thc Respondent.
FOR TilE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY
ORDER, and ArTER IIEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING (CHECK ALL
FORMS OF RELIEF REQUESTED):
A, Reslrnin Respondent from abusing, threatening, harassing, or stalking Petitioner and/of minor chiJd/rcn
in any place where Petitioner may be found.
B. Exclude Respondent from Petitioner's residence and prohibit Respondent from attempting to enter any
temporary or perrnlment residence of Ihe Petitioner,
C. Prohibit Respondent from having any contact with Petitioner and/or minor child, either in person, by
telephone, or in writing, personally or through third persons, including but not limited to any contact
at Petitioner'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.
D. A ward Petitioner temporary custody of the Khaila R. Knight
E. Prohibit Respondent from having any contact with Petitioner's relatives and Petitioner'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.
F. Grant such relief as the court deerns appropriate.
G. Order the police or other law enforcement agency to serve the Respondent with a copy of this Petition,
any Order issued, and the Order for Hearing. The Petitioner will infonll the designated authority of
any addresses, other thank Respondent's residence, where Respondent can be served.
,/
,;~;c5
Certified Legal Intern
~wd~
ROBERT E. RAI ,Supemsmg Attorney
DONALD MARRITZ, Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, P A 17013
717/243-2968
,
Tara L, Dukes,
Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION.LAW
IN PROTECTION FROM ABUSE
Kevin R. Knight,
Respondent
NO. 99- ,~{~ CIVIL TERM
CONSENT AGREEMENT AND FINAL ORDER
~...,
This Agreement is entered on this & day of April, 1999, by the petitioner, Tara L.
Dukes, and the respondent, Kevin R. Knight, each of whom is represented by counsel, as
indicated below. Without admitting the allegations of abuse, the respondent agrees that the
Court shall enter an Order containing the following terms:
1. Respondent shall not abuse, cause reasonable fear of abuse, threaten with violence,
or harass petitioner, whether personally or through his agents,
2. Respondent shall not enter any of petitioner's present or future places of employment.
3. Except for contact pertaining to the parties' minor child, Khaila R. Knight, the
respondent shall not have any direct or indirect contact with the petitioner including, but not
limited to, telephone and written communications.
4. Except for necessary contact pertaining to the minor child, respondent agrees not to
trespass at petitioner's address.
5. Respondent shall not to harass or stalk petitioner or petitioner's relatives.
6. The Carlisle Police Department shall be provided with a certified copy of this Order
by the petitioner's attorney. This Order shall be enforced by any law enforcement agency where
a violation occurs, by arrest for indirect criminal contempt without warrant upon probable cause
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i E~IBIT
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lhal this Order has been viola led , whelher or nOI the viola lion is comrnitted in the presence of
the police officer. In the event that an arrest is made, under this seclion, the respondent shall
be taken without necessary dclay bcforc the court that issued the order. When that court is
unavailable, the respondent shall be taken before the appropriatc districtjusticc. (23 P.S. ~6113).
7, The parties intend to be legally bound by the terms of lhis agreement and request that
a Protection Order be entered to reflect the above telms. The respondent has been advised of
his right to have a hearing.
8. BRADY INDICATOR:
a) The Petitioner and the Respondent have cohabited together and have one (I)
child together, Khaila R. Knight.
b) This order is being entered after a hearing of which the Respondent received
actual notice and had an opportunity to be heard.
c) This Order restrains the Respondent from harassing, stalking, or threatening
the Petitioner.
d) Respondent represents a credible threat to the physical safety of the Petitioner.
e) The terms of this Order prohibit Respondent from using, attempting to use,
or threatening to use physical force against the Petitioner or protected person that would
reasonably be expected to cause bodily injury.
9. THIS ORDER SUPERSEDES ANY PRIOR PPA ORDER.
10. All provisions of this order shall expire in one year, on April ..2...1-, 2000,
however the Petitioner may ask the Court, after notice and hearing, to extend the term of the
Order, pursuant to 23 Pa. C.S. ~ 6108(e).
,
NOTICE TO THE RESI'ONI)ENT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE
CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICIIIS PUNISHABLE BY A FINE
OF UP TO $1,000.00 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C,S.
~ 6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL
PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE, THIS ORDER IS ENFORCE-
ABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS,
U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER TIlE VIO-
LENCE AGAINST WOMEN ACT, 18 U,S.C. ~~ 2261-2262. IF YOU TRAVEL OUTSIDE
OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER YOU MAY BE SUB-
JECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C. ~~ 2261
-2262. UNDER PARAGRAPH 10, YOU MAYBE SUBJECT TO FEDERAL PROSECUTION
AND PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT,
18 U.S.C. ~~ 922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR
AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over the petitioner's residence OR any location where
a violation of this order occurs OR where the respondent may be located, shall enforce this
order. An arrest for violation of Paragraphs 1 through 7 of this order may be without warrant,
based solely on probable cause, whether or not the violation is committed in the presence of the
police. 23 Pa.C.S, ~ 6113.
Subsequent to an arrest, the police officer shall seize all weapons used or threatened to
be used during the violation of the protection order or during prior incidents of abuse. When
the respondent is placed under arrest for violation of the order, the respondent shall be taken to
the appropriate authority or authorities before whom respondent is to be arraigned. A
"Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police
officer OR the petitioner. Petitioner's presence and signature are not required to file the
complaint.
If sufficient grounds for violation of this order are alleged, the respondent shall be
arraigned, bond set and both parties given notice of the date of the hearing.
L -...../ ~.
7c?' Y.~< ." ~
,~ara 1. Dukes, <~j ner
B~ RaneyO
Certified Legal Intern
t1/~:v r nJr'
Wayne Shade, Esquire
Counsel for Respondent
i'..,
Tara L. Dukes,
Petitioner
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
I
Kevin R. Knight,
Respondent
NO, 99 - (rf5"?- CIVIL TERM
CONSENT AND APPROVAL FOR APPEARANCE UNDER Pa.B.A.R. 322
I hereby consent to the appearance of Brian P. Raney , a
certified Legal Intern under the supervision of an attorney, in the
above-entitled Protection From Abuse proceeding before the
Honorable J. Wesley Oler at 8:30 a,m. on Wednesday, April 21, 1999.
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Date
"ih/~cy
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)'/y~
~~1fL' Du ~s -
attorney for Brian P. Raney, certified
As the supervising
under Pa.B,A.R. 322, I approve of his appearance on behalf of the
above-named client in the above-named proceeding.
Date
1- JI- 17'
Ctt/t RN~
ROBERT E. RAINS
supervising Attorney
DONALD M. MARRITZ
Staff Attorney
FAMILY LAW CLINIC
45 North pitt street
carlisle, PA 17013
717-243-2968
;: PETITIONER'S
J EXHrlT
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APR 0 '/ 1999)'
Y
Tara L. Dukes,
Plaintiff
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
Kevin R. Knight,
Defendant
NO. 99 - 1882 CIVIL TERM
ORDER
AND NOW,
this ~/day
of April,
1999,
the attached motion is
granted.
The hearing in this case is continued to the 21st day of April
full force and effect.
1999, at 8:30 a.m. The Court's Order of March 30, 1999, shall remain in
BY THE COURT,
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Tara L. Dukes,
Plaint if f
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
IN PROTECTION FROM ABUSE
v.
Kevin R. Knight,
Defendant
NO. 99 - 1882 CIVIL TERM
MOTION FOR CONTINUANCE
The Plaintiff, by her attorneys, Family Law Clinic, respectfully
represents that:
1. On March 30, 1999, Plaintiff filed this action and the Court
entered a temporary protection from abuse order and set a hearing for April
8, 1999.
2. There is a scheduling conflict that prohibits Plaintiff's counsel
from being able to attend that hearing.
3. Plaintiff's counsel has contacted Defendant's counsel, Wayne F.
Shade,Esq. who concurs with this motion.
WHEREFORE, Plaintiff prays that the Court continue the hearing in this
matter generally, at the call of either
party.
,~~~
Supervising Attorney
DONALD MARRITZ,
Staff Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
~~~.
Brian P. Raney,
Certified Legal Intern
Tara L. Dukes,
Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
I
v.
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
Kevin R. Knight,
Respondent
NO. 99 - WI J.. CIVIL TERM
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT, If you wish to defend against the claims set forth in the
following pages, 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 frorn your residence and lose other important rights.
A hearing on the matter is scheduled for theg.a. , day of April 1999, at 3:00 o'clock 1.m., in
Courtroom I at 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 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.
Cumberland County Bar Association
2 Liberty A venue
Carlisle, Pennsylvania 17013
(717) 249-3166
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.
Tara L. Dukes,
Petitioner
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
v.
Kevin R. Knight,
Respondent
NO. 99 - /J'f,1.. CIVIL TERM
PETITION FOR PROTECTION FROM ABUSE
1. Petitioner's name is: Tara L. Dukes
2. I am filing this Petition 011 behalf of myself.
3. Name of person who is seeking protection from abuse: Tara L. Dukes
4. Petitioner's address is confidential.
5. Respondent is believed to live at the following address: 7 Belly Nelson Cl., Carlisle
Respondent's Social Security Number (if known) is: 186-66-2487
Respondent's date of birth is: 2-9-71
Respondent's place of employment is: N/A
6. Petitioner and Respondent have lived together in the past and have one child together.
7. Petitioner previously filed a Protection From Abuse Action in Dauphin County in March 1999, but
voluntarily discontinued it Upon Repondent's prornise that he would seek counseling.
8. Respondent is currently facing simple assault charges as a result of the most recent incident alleged
below.
9. Petitioner and Respondent are the natural parents of Khaila R. Knight, born 2-13-97.
The child is currently living with Respondent's parents. The Petitioner has not been allowed to have
any physical contact with Khaila since March 13, 1999,
10. There is no existing custody order pertaining to Khaila. The child has lived with the following
people, at the following adrresses.
Persons child lived with
Father, Mother & Siblings
..
Address
445 Radcliffe Drive, Harrisburg
5082 Lilac Lane, Harrisburg
4941 Highland Street, Harrisburg
When
Dec 98 - Mar 99
Jun 98 - Dee 98
Jun 96 - Jun 98
"
II, The following other minor children prescmly Iivc with Petitioncr:
Name(s) ~ Petitioner's relationshio 10 children
Shawn Buller, Jr. 3 Mother
Latresha L. Dukes 5 Mother
Jessica Martinez 13 Guardian
12. The facts of the most reccm incident of abuse are as follows:
Approximate Date: 3-13.99 Approximate Time: 10:00 a.m. Place: MOlel (6) Six, Carlisle,PA
On or about this date the Respondcnt emered the parties' hotel room. An argumem ensued, after which
the Petitioner asked the Rcspondem to leave. He came imo the bathroom, punched her in the head and
bit her arm, both of which caused her substantial pain.
13. The Respondent has commiued prior acts of abuse against Petitioner, including but not limited to the
following:
a) On or about February 15th, 1999, in Harrisburg, the Respondent followed the Petitioner all day while
she was running errands. He periodically called her throughout the day and told her exactly what she
was doing. He flattened the tires of her car. As a result of this course of conduct, Petitioner reasonably
feared bodily injury.
b) Sometime between during February, 1999, at 445 Radcliffe Road, in Harrisburg, the Respondent
came to the Petitioner's house to pick up their daughter. An argumem followed and the Petitioner asked
him to leave. As she was trying to close the door, Respondent hit her in the face and tried to pull the
child out the door. After the incident the Respondent hid in her apartment complex and watched her
for a few hours. He kept calling her and leaving threatening messages. As a result of this course of
conduct, Petitioner feared of serious bodily injury.
c) On or about December 25th, 1998, at 445 Radcliffe Road, in Harrisburg, the Petitioner's family had
gotten together for holiday dinner. The Respondent was there and was unhappy with the Petitioner.
She asked him to leave and he would not. Then he threatened to take Khaila away from her and kicked
in her door. Petitioner believed she was in danger of imminent serious bodily injury.
d) Sometime during November, 1998, the Respondent came into a public restaurant where Petitioner was
eating and confronted her. He punched her in the face. Later, when the parties were outside in the
parking lot, he choked her, causing her substantial pain.
e) Sometime in the fall of 1997, at 1276 Oyler Road, in Harrisburg, the Respondent had been drinking
and an argument oecured. The Respondent broke a kitchen chair and hit the Petitioner with a piece of
it, causing her substantial pain.
f) While the petitioner was pregnant with Khaila, in January. 1997, the Respondent pushed her against
the wall and caused her substantial pain. She then went to the hospital, where she went into premature
labor and delivered the child.
14. Identify thc police department or law enforccment agency in the area in which Petitioner lives that
should be provided with a copy of the protcction ordcr: Carlisle Police Depanment
IS. There is an immediate and present dangcr of furthcr abuse from the Respondent.
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 (CHECK ALL
FORMS OF RELIEF REQUESTED):
A. Restrain Respondent from abusing, threatening, harassing, or stalking Petitioner and/of minor child/ren
in any place where Pctitioner may be found.
B. Exclude Respondent from Petitioner's residence and prohibit Respondent from attempting to enter any
temporary or permanent residence of the Petitioner.
C. Prohibit Respondent from having any contact with Petitioner and/or minor child, either in person, by
telephone, or in writing, personally or through third persons, including but not limited to any contact
at Petitioner'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.
D. Award Petitioner temporary custody of the Khaila R. Knight
E. Prohibit Respondent from having any contact with Petitioner's relmives and Petitioner'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.
F. Grant such relief as the court deems appropriate,
G. Order the police or other law enforcement agency to serve the Respondent 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 thank Respondent's residence, where Respondent can be served.
/
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Certified Legal Intern
l!M ~~;,;"g A~~,
DONALD MARRITZ, Staff Attorney
FAMILY LAW CLINIC
45 Nonh Pitt Street
Carlisle, PA 17013
717/243-2968
VERIFICATION
Understanding that the making of any false statement would subject me to the penalties of 18 Pa.C.S
I
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;
~ 4904, I verify that I am the Petitioncr in the present action, and that the facts and statements containcd in
the above Petition are true and correct, to the best of my knowledgc, information and belief.
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"
TARA L. DUKES,
petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v,
CIVIL ACTION - LAW
KEVIN R. KNIGHT,
Respondent
NO. 99-1882 CIVIL TERM
IN RE:
CUSTODY AGREEMENT
ORDER OF COURT
AND NOW, this 21st day of April, 1999, with
respect to custody of the parties' child, Khaila R. Knight (date
of birth February 13, 1997), and pursuant to an agreement
reached in open court between Tara L. Dukes, the child's mother,
represented by the Family Law Clinic, in the person of Brian P.
Raney, supervised by Professor Robert Rains, Esquire, and Kevin
R. Knight, the child's father, pro se, it is ordered and
directed as follows:
1. The parties shall have shared legal custody of
their child, Khaila R. Knight.
2. The mother shall have primary physical custody
of the child.
3. The father shall have partial physical custody
of the child every week, picking the child up on Sunday between
6:00 and 6:30 p.m. and returning the child on Tuesday between
6:00 and 6:30 p.m. The father shall be responsible for the
transportation of the child to and from such visits.
4. The father shall not take the child outside of
the state of Pennsylvania without express prior consent of the
mother.
5. The parties intend to be legally bound by the
.,
.
that this Order has been violated, whether or not the violation is committed in the presence of
the police officer. In the eventlhat an arrest is made, under this section, the respondent shall
be taken without necessary delay before the coun thai issued the order. When that coun is
unavailable, the respondent shall be taken before the appropriate district justice. (73 P.S. ~6113).
7. The panies intend to be legally bound by the terms of this agreement and request that
a Protection Order be entered to reflect the above terms. The respondent has been advised of
his right to have a hearing.
g, BRADY INDICATOR:
a) The Petitioner and the Respondent have cohabited logether and have one (I)
child together, Khaila R. Knight.
b) This order is being entered after a hearing of which the Respondent received
acrual notice and had an opportunity to be heard.
c) This Order restrains the Respondent from harassing, stalking, or threatening
the Petitioner.
d) Respondent represents a credible threat to the physical safety of the Petitioner.
e) The terms of this Order prohibit Respondent from using, atternpting to use,
or threatening to use physical force against the Petitioner or protected person that would
reasonably be expected to cause bodily injury.
9. THIS ORDER SUPERSEDES ANY PRIOR PFA ORDER.
10, All provisions of this order shall expire in one year, on April , 2000.
however the Petitioner may ask the Court, after notice and hearing. to extend the term of the
Order, pursuant to 23 Pa, C,S. ~ 6108(e).
NOTICE TO THE RESPONDENT
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 $1,000.00 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S.
~ 6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL
PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS ORDER IS ENFORCE-
ABLE IN ALL FIFTY (SO) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS,
U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER TIlE VIO-
LENCE AGAINST WOMEN ACT, 18 U.S.C. n 2261-2262. IF YOU TRAVEL OUTSIDE
OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER YOU MAY BE SUB-
JECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C. ~~ 2261
-2262. UNDER PARAGRAPH 10, YOU MAYBE SUBJECT TO FEDERAL PROSECUTION
AND PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT,
18 U.S.C. ~~ 922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR
AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over the petitioner's residence OR any location where
a violation of this order occurs OR where the respondent may be located, shall enforce this
order. An arrest for violation of Paragraphs I through 7 of this order rnay be without warrant,
based solely on probable cause, whether or not the violation is commined in the presence of the
police. 23 Pa.C.S, ~ 6113.
Subsequent to an arrest, the police officer shall seize all weapons used or threatened to
be used during the violation of the protection order or during prior incidents of abuse. When
the respondent is placed under arrest for violation of the order, the respondent shall be taken to
the appropriate authority or authorities before whom respondent is to be arraigned. A
"Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police
officer OR the petitioner. Petitioner's presence and signature are not required to file the
complaint.
If sufficient grounds for violation of this order are alleged. the respondent shall be
arraigned, bond set and both parties given notice of the dale of the hearing.
~.
ent
~.
Certified Legal Intern
/c/o r~
Wayn~de. Esquire
Counsel for Respondent
.. , ,
J;;:>tr' J:;t'--
Donald MarrilZ, Staff Attorney
Robert E. Rains, Supervising Attorney
FAMILY LAW CUNIC
4S North Pitt Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243.3639
Counsel for Petitioner
Order
AND NOW, this _ day of April, 1999, the foregoing Agreement is approved and
entered as an Order of Court.
J. Wesley Oler, Judge
Tara L. Dukes,
Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
Kevin R. Knight,
Respondent
NO. 99-
CIVIL TERM
I.
,
t
CONSENT AGREEMENT AND FINAL ORDER
'l /~T
This Agreement is entered on this ~ day of April, 1999, by the petitioner, Tara L.
Dukes, and the respondent, Kevin R. Knight, each of whom is represented by counsel, as
indicated below. Without admitting the allegations of abuse, the respondent agrees that the
Coun shall enter an Order containing the following terms:
1. Respondent shall not abuse, cause reasonable fear of abuse, threaten with violence,
or harass petitioner, whether personally or through his agents.
2. Respondent shall not enter any of petitioner's present or future places of employment.
3. Except for contact penaining to the panies' minor child, Khaila R. Knight, the
respondent shall not have any direct or indirect contact with the petitioner including, but not
Iirnited to, telephone and written communications.
4. Except for necessary contact penaining to the minor child, respondent agrees not to
trespass at petitioner's address.
5. Respondent shall not to harass or stalk petitioner or petitioner's relatives.
6. The Carlisle Police Department shall be provided with a certified copy of this Order
by the petitioner's attorney, This Order shall be enforced by any law enforcement agency where
a violation occurs, by arrest for indirect criminal contempt without warrant upon probable cause
that this Order has been violated, whether or not the violation is committed in the presence of
the police officer. In the event that an arrest is made, under this section, the respondent shall
be taken without necessary delay before the court that issued the order. When that court is
unavailable, the respondent shall be taken before the appropriate district justice. (23 P.S. ~6113).
7. The parties intend to be legally bound by the terms of this agreement and request that
a Protection Order be entered to reflect the above terms. The respondent has been advised of
his right to have a hearing.
8. BRADY INDICATOR:
a) The Petitioner and the Respondent have cohabitcd together and have one (I)
child together, Khaila R. Knight.
b) This order is being entered after a hearing of which the Respondent received
actual notice and had an opportunity to be heard.
c) This Order restrains the Respondent from harassing, stalking, or threatening
the Petitioner.
d) Respondent represents a credible threat to the physical safety of the Petitioner.
e) The terms of this Order prohibit Respondent from using, attempting to use,
or threatening to use physical force against the Petitioner or protected person that would
reasonably be expected to cause bodily injury.
9. THIS ORDER SUPERSEDES ANY PRIOR PFA ORDER,
10. All provisions of this order shall expire in one year, on April , 2000,
however the Petitioner may ask the Court, after notice and hearing. to extend the term of the
Order. pursuant to 23 Pa. C.S. ~ 6108(e).
NOTICE TO THE RESPONDENT
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 $1,000.00 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S.
~ 6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL
PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS ORDER IS ENFORCE-
ABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA. TRIBAL LANDS,
U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIO-
LENCE AGAINST WOMEN ACT, 18 U.S.C. ~~ 2261-2262. IF YOU TRAVEL OUTSIDE
OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER YOU MAY BE SUB-
JECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C. ~~ 2261
-2262. UNDER PARAGRAPH 10, YOU MA Y BE SUBJECT TO FEDERAL PROSECUTION
AND PENALTIES UNDER THE "BRADY" PROVISlONS OF THE GUN CONTROL ACT,
18 U.S.C. ~~ 922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR
AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over the petitioner's residence OR any location where
a violation of this order occurs OR where the respondent may be located, shall enforce this
order. An arrest for violation of Paragraphs I through 7 of this order may be without warrant,
based solely on probable cause, whether or not the violation is committed in the presence of the
police. 23 Pa.C.S, ~ 6113.
Subsequent to an arrest, the police officer shall seize all weapons used or threatened to
be used during the violation of the protection order or during prior incidents of abuse. When
the respondent is placed under arrest for violation of the order, the respondent shall be taken to
the appropriate authority or authorities before whom respondent is to be arraigned. A
"Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police
officer OR the petitioner. Petitioner's presence and signature are not required to file the
complaint.
If sufficient grounds for violation of this order are alleged, the respondent shall be
arraigned, bond set and both parties given notice of the dale of the hearing,
~~{~~
Va L. DUkes~ner -
t1/~#U( Fa.L(
Wayne shade. Esquire
Counsel for Respondent
arr:t;-o
Donald MarrilZ, Staff Attorney
Robert E. Rains, Supervising Attorney
FAMILY LAW CLINIC
45 North Pin Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
Counsel for Petitioner
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Order
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AND NOW, this _ day of April, 1999, the foregoing Agreement is approved and
entered as an Order of Court.
J. Wesley Oler. Judge
Tara L. Dukes,
Petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION-LAW
IN PROTECTION FROM ABUSE
c_
Kevin R. Knight,
Respondent
NO. 99-
CIVIL TERM
CONSENT AGREEMENT AND FINAL ORDER
This Agreement is entered on this "21 S 'lday of April, 1999, by the petitioner, Tara L.
Dukes, and the respondent, Kevin R. Knight, each of whom is represented by counsel, as
indicated below. Without admilling the allegations of abuse, the respondent agrees that the
Court shall enter an Order containing the following terms:
1. Respondent shall not abuse, cause reasonable fear of abuse. threaten with violence.
or harass petitioner, whether personally or through his agents.
2. Respondent shall not enter any of petitioner's present or future places of employment.
3. Except for contact pertaining to the parties' minor child, Khaila R. Knight, the
respondent shall not have any direct or indirect contact with the petitioner including, but not
limited to, telephone and written communications,
4. Except for necessary contact pertaining to the minor child, respondent agrees not to
trespass at petitioner's address,
5. Respondent shall not to harass or stalk petitioner or petitioner's relatives.
6. The Carlisle Police Department shall be provided with a certified copy of this Order
by the petitioner's allorney. This Order shall be enforced by any law enforcement agency where
a violation occurs, by arrest for indirect criminal contempt without warrant upon probable cause
~ I
that this Order has been violated, whether or not the violation is committed in the presence of
the police officer. In the event that an arrest is made, under this section, the respondent shall
be taken without necessary delay before the coun that issued the order. When that court is
unavailable, the respondent shall be taken before the appropriate district justice. (23 P.S. ~6113).
7. The panies intend to be legally bound by the terms of this agreement and request that
a Protection Order be entered to reflect the above terms. The respondent has been advised of
his right to have a hearing.
8. BRADY INDICATOR:
a) The Petitioner and the Respondent have cohabited together and have one (1)
child together, Khaila R. Knight.
b) This order is being entered after a hearing of which the Respondent received
actual notice and had an opportUnity to be heard,
c) This Order restrains the Respondent from harassing, stalking, or threatening
the Petitioner.
d) Respondent represents a credible threat to the physical safety of the Petitioner.
e) The terms of this Order prohibit Respondent from using, attempting to use,
or threatening to use physical force against the Petitioner or protected person that would
reasonably be expected to cause bodily injury.
9. THIS ORDER SUPERSEDES ANY PRIOR PPA ORDER.
10, All provisions of this order shall expire in one year, on April , 2000,
however the Petitioner may ask the Court, after notice and hearing, to extend the term of the
Order, pursuant to 23 Pa. C.S, ~ 6108(e),
NOTICE TO THE RESPONDENT
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 $1,000.00 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S.
~ 6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL
PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE, THIS ORDER IS ENFORCE-
ABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS,
U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIO-
LENCE AGAINST WOMEN ACT, 18 U.S.C. ~~ 2261-2262. IF YOU TRAVEL OUTSIDE
OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER YOU MAY BE SUB-
JECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C. H 2261
-2262. UNDER PARAGRAPH 10, YOU MAY BE SUBJECT TO FEDERAL PROSECUTION
AND PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT,
18 U.S.C. 99 922(G), FOR POSSESSION. TRANSPORT OR RECEIPT OF FIREARMS OR
AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over the petitioner'S residence OR any location where
a violation of this order occurs OR where the respondem may be located, shall enforce this
order. An arrest for violation of Paragraphs I through 7 of this order may be without warram,
based solely on probable cause, whether or not the violation is committed in the presence of the
police, 23 Pa.C.S. 96113.
Subsequent to an arrest, the police officer shall seize all weapons used or threatened to
be used during the violation of the protection order or during prior incidents of abuse. When
the respondent is placed under arrest for violation of the order, the respondent shall be taken to
the appropriate authority or authorities before whom respondent is to be arraigned. A
"Complaint for Indirect Criminal Comempt" shall then be completed and signed by the police
officer OR the petitioner, Petitioner's presence and signature are not required to file the
complaim.
If sufficient grounds for violation of this order are alleged. the respondent shall be
arraigned, bo d set and both PJrties given notice of the date of the hearing.
r:
ra L. Dukes.
~~.
Certified Legal Intern
j(I(ij~l.f ;:- Y!d<.
WaymlShade. Esquire
Counsel for Respondent
. ,.
J?~~u;,
Donald MarrilZ, Staff Attorney
Robert E. Rains, Supervising Attorney
FAMILY LAW CUNIC
4S North Pin Street
Carlisle, PA 17013
(717) 243-2968
Fax: (717) 243-3639
Counsel for Petitioner
Order
AND NOW, this _ day of April, 1999, the foregoing Agreement is approved and
entered as an Order of Court.
J. Wesley Oler, Judge
. ,
i
I
j
that this Order has been violated, whether or not the violation is committed in the presence of
the police officer, In the event that an arrest is made, under this section, the respondent shall
be taken without necessary delay before the court that issued the order. When that court is
unavailable, the respondent shall be taken before the appropriate district justice. (23 P.S. ~6113).
7. The parties intend to be legally bound by the tenns of this agreement and request that
a Protection Order be entered to reflect the above terms. The respondent hus been advised of
his right to have a hearing.
8. BRADY INDICATOR:
a) The Petitioner and the Respondent have cohabited together and have one (I)
child together. Khaila R. Knight.
b) This order is being entered after a hearing of which the Respondent received
actual notice and had an opportunity to be heard.
c) This Order restrains the Respondent from harassing, stalking, or threatening
the Petitioner.
d) Respondent represents a credible threat to the physical safety of the Petitioner.
e) The terms of this Order prohibit Respondent from using, attempting to use,
or threatening 10 use physical force against the Petitioner or protected person that would
reasonably be expected to cause bodily injury,
9, THIS ORDER SUPERSEDES ANY PRIOR PFA ORDER.
10. All provisions of this order shall expire in one year, on April , 2000,
however the Petitioner may ask the Court. after notice and hearing, to extend the term of the
Order, pursuant to 23 Pa. C.S. ~ 6108(e).
./
NOTICE TO THE RESPONDENT
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 $1,000.00 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S.
~ 6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL
PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS ORDER IS ENFORCE-
ABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS,
U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIO-
LENCE AGAINST WOMEN ACT, 18 U.S.C. ~~ 2261-2262. IF YOU TRAVEL OUTSIDE
OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER YOU MAY BE SUB-
JECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C. ~~ 2261
-2262. UNDER PARAGRAPH 10. YOU MA Y BE SUBJECT TO FEDERAL PROSECUTION
AND PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT,
18 U.S.C. ~~ 922(G), FOR POSSESSION. TRANSPORT OR RECEIPT OF FIREARMS OR
AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over the petitioner's residence OR any location where
a violation of this order occurs OR where the respondent may be located. shall enforce this
order. An arrest for violation of Paragraphs I through 7 of this order may be without warrant,
based solely on probable cause. whether or not the violation is committed in the presence of the
police. 23 Pa.C.S, ~ 6113.
Subsequent to an arrest. the police officer shall seize all weapons used or threatened to
be used during the violation of the protection order or during prior incidents of abuse. When
the respondent is placed under arrest for violation of the order, the respondent shall be taken to
the appropriate authority or authorities before whom respondent is to be arraigned. A
"Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police
officer OR the petitioner. Petitioner's presence and signature are not required to file the
complaint.
If sufficient grounds for violation of this order are alleged. the respondent shall be
arraigned, bond set and both panies given notice of the date of the hearing.
J/>
/f
,/Tara C Dukes,~i lOner
::~
Certified Legal Intern
/~~~nc r ~~
Wayne Shade, Esquire
Counsel for Respondent
SHERIFF'S RETURN - REGULAR
CASE NO: 1999-01882 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DUKES TARA L
VS.
KNIGHT KEVIN R
CPL. MICHAEL BARRICK
, Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within NOTICE OF HEARING AND ORDER was served
upon KNIGHT KEVIN R the
defendant, at 8:23 HOURS, on the 30th day of March
1999 at BETTY NELSON TRAILER PARK LOT # 4
CARLISLE, PA 17013 ,CUMBERLAND
County, Pennsylvania, by handing to KEVIN R. KNIGHT
a true and attested copy of the NOTICE OF HEARING AND ORDER
together with TEMPORARY PROTECTION FROM ABUSE ORDER
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So answers: /~~
~~~<~~
R. mas ::J.ne, erJ.
18.00
3.10
.00
8.00
$~~..LU
03/31/1999
by
;;K'g?-.f/
;..
.
Sworn and subscribed to before me
this 10 day of /If';' ,. 0
1999 A D./
{>m,J J lJM~,fJnY
J U L 2 6 1999\\'>'
TARA L. DUKES,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
99-1882 CIVIL
KEVIN R. KNIGHT,
Defendant
: CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW,lhis .),br.... day of July, 1999, this Court certifies that the attached
complaint has been properly completed and verified, and lhere is probable cause for the
issuance of process, In consideration of the attached Commonwealth's Petition, the
defendant, KEVIN R. KNIGHT, is directed to appear for trial on the charge of Indirect
Criminal Contempt before the Court on the K- day of M\.l<;-r ,1999 at
ZS: $"' o'clock :::! .01. in Courtroom #.-!..- of the Cumberland County Courthouse, Carlisle,
Pennsylvania.
The defendant has a right to be represented by an attorney. If the defendant
cannot afford an attorney, upon request one will be assigned to represent the defendant.
If the defendant wishes assignment of counsel, contact should be made prior to trial with
the Cumberland County Public Defender's Office at 717-240-6285. Further, if the
defendant fails to appear, an arrest warrant will be issued.
The Sheriff of Cumberland County is directed to serve this Order and Petition
upon the defendant. The assessment of costs to be determined by the Trial Judge
subsequent to trial.
By the court,.. //' /. ,(
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Ilt~~{~j
t/W I 0\(':1 J' '-" '/' J
,:! es ey c/ r., :~.
William I. Gabig,
Senior Assistant District Attorney
KEVIN R. KNIGHT
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. ;,;OMMONWEALTH OF PENNSYLVANIA
COUNTY OF: OJrrberlLU1d
Ilt...,.1 DlllrlOIIMlJe<': 09-3-03
Illrlol Jlallc:e _:Hen. SUsan K. DAY
229 Mill St. PO Box 167
Mt. Holly Sprirgs, I'A
POLICE
CRIMINAL COMPLAINT
COMMONWEALTH OF PENNSYLVAMA
VB.
elq:llcre:
(717) 486-7672
DEFENDANT:
NAME end ADDRESS
r Kevin Randolph Knight
7 Betty Nelson Ct.
Carlisle PA 17013
717-243-4123
L
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enb1t'J SJD
186-66-2847
cni:nt's Or vet1& L cerso IMt:Ier
State
PA 22781702
II nt/Ire om tMt:ler la nt/ln:; ant NUJbers other Partie ID1ts IIRS Cait
H02-1077912 260
District Attorney's Office n Approved 0 Disapproved because:
IThe district ettorn:!Y rmy ro:pire~t the ccnplafnt, arrest Wlrr8"lt afficbvit, or txlth I::e q::pl"CM;!d bt the attCll'Tl!y for the Camtrwealth ~Ior to
Illt1l P..R.cr.P. lOT.)
.
U~are Of Attorney tor t..anlD"WeOltn . to'lease print or I~)
I, 'fur Kirk A Perkins
(Nale of Affllnl'Pleese Print or TIPl)
of PA State Police
(Identity DqJortnUlI or ArPr:f R"""""led trd Polllical 9.lxlivlsienl
do hereby Btate:{check the appropriate box)
1. IXI I accuse the above named defendant, who lives at the address set forth above
o I accuse an defendant whose name is unknown to me but who is described as
(::iIg'Qtt.re Of Attorrey Tor l.mTI'tr1olCOurl)
(uateJ
PAPSP1000
(Polloo ArPr:f au Nurberl (Orlslmtfra Iq!rr;y Case lMlJe<'(tcA))
3805
(Officer Ilaclle Nurber/I.D.l
o I accuse the defendant whose name and popular designation or nickname is unknown to me and whom I have
therefore designated as John Doe
with violating the penal laws of the Commonwealth of Pennsylvania at 7 Pine Rd., AI? # 605 Mt Holly
Springs PA 17013 South Middleton Twp. (Pleoe-potltlcal 9.lxl,vlsien)
in CUmberland County on or about 07 /16/99 @ aoorox. 2130 hrs
Participants were: (if there were participants, place their names here, repeating the name of the above defendant)
Kevin Randolph Kniqht
2. The acts committed by the accused were:
(Set forth 8 sunmry of the facts sufficient to advise the d!fen:Ult of the mtt.re of the offense char9E!Cf. A citatfm to the statl.e allegedly ....iolated
witha.Jt 1IDre, is rot sufficimt. In a sumary case, yaJ RUSt cite the 5p!Cffic sectia1 m:f Sltsectim of the statute or ordinerce alleged[y ....Iolated.)
TIle Defendant did violate the order issued under the protection fran abuse act F.R.
1992-512 dated 06/04/92, by the court of Cbmon Pleas of Ci..nTUJerland County. The
P.F.A. No. 99-1882 Civil Term, was issued by the Honorable Wesley Oler Jr., on
03/30/99. The Defendant did call the victim at her residence, using profane
language, and in a harassing mmner, which is in violation of said P.F.A Order.
N:PC 412.(4196)(Jnterrct Versia1)
1-3
. .
tc~:It1nuat1on or 2.)
De~ndantName: Kevin Randolph Knight
Docket Number:
POLICE
CRIMINAL COMPLAINT
all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act
of Assembly, or in violation of 1. 6113 of the DR 1
(Section) (Sub-Section) CPA Statute) (counts)
2. of the
(Section) (Sub-Section) CPA Statute) (counts)
3. of the
(Section) (Sub-Section) (PA St.tute) (counts)
4. of the
(Section) (Sub-Seetlon) CPA Statute) (counts)
3. I ask that a warrant of arrest or a summons be issued and that the defendant be required to answer the charges
I have made. (In order for a warrant of arrest to issue, the attached affidavit of probable cause must be completed
and sworn to before the issuing authority.
4. I verify that the facts set forth in this complaint are true and correct to the best of my knowl e or information
and belief. This verification is made subject to the penalties of Section 4904 of the Cri od 18 P A. C.S.
114904) relating to unsworn falsification to authorities.
"~'I> . '19
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AND NOW, on this date . 19 . I certify the complaint has been properly
completed and verified. An afl1davlt of probable cause must be completeCI in order for a warrant to issue.
SEAL
(MaglsterI8\ DIstrict)
AOPC 412-C4/96)'lnternet Version)
(ISsuing Autnorlty)
2-3
lhallhis Order has been violatcd, Whelher or nOI Ihe violation is commilled in the presence of
Ihc police officer. In Ihe event Ihal an arresl is /lIade, under this seclion, the respondem shall
be laken wirhout necessary delay before the courr Ihut iSsued Ihe ordcr. When thaI coun is
unavailable, lhe respondent shall he taken before lhc appropriate dislricljustice. (23 P,S. ~6113).
7. The parties intend ro be legally bound by the tenns of this agreement and requesllhar
a Prolection Order be elllered io reflecI the above lerms. The respondem has been advised of
his right 10 have a hearing.
8. BRADY INDICATOR:
a) The Petirioner and lhe Respondent have cohabited together and have one (I)
child together, Khaila R. Knight.
b) This order is being entered after a hearing of which the Respondem received
actual notice and had an opponunity 10 be heard.
c) This Order restrains Ihe Respondem from harassing, stalking, or threatening
the Petitioner.
d) Respondent represents a credible threat to the physical safely of Ihe Petitioner.
e) The terms of this Order prohibit Respondem from using, attempting to use,
or threatening to use phYSical force against lhe Petitioner or protected person Ihat would
reasonably be expected 10 cause bodily injury.
9, THIS ORDER SUPERSEDES ANY PRIOR PPA ORDER.
10, All provisions of this order shall expire in one year, on April 21-. 2000,
however the Petilioner may ask the Coun, after notice and hearing, to eXlend (he term of the
Order, pursuam to 23 Pa, C,S, ~ 6108(e).
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NOTICE TO TilE IUISI'ONDENT
VIOLATION or THIS ORDER MAY HESULT IN YOUR AHHEST ON TIlE
CHARGE OF INDIRECT CRIMINAL CONTEMlyr WIIICIIIS PUNISIIABLE BY A rlNE
or: UP TO $1,000.00 AND/OH A JAIL SENTENCE or UP TO SIX MONTIIS. 23 PA.C,S.
fi 61/4. VIOLATION MAY ALSO SUBJECT YOU TO PHOSECUTION AND CRIMINAL
PENAI.TIES UNDER THE PENNSYLVANIA CHIMES CODE. THIS ORDEH IS ENrORCE_
AULE IN ALL PIPTY (SO) STATES, TIlE DISTRICT OF COLUMBIA, TRIBAL LANDS,
U.S. TERRITORIES AND THE COMMONWEALTII OF PUERTO RICO UNDER THE VIO-
LENCE AGAINST WOMEN ACT, 18 U.S.C. -fifi 2261-2262. IF YOU TRAVEL OUTSIDE
or: THE STATE AND INTENTIONALLY VIOLATE THIS ORDER YOU MAY BE SUB-
JECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C. gg 2261
-2262, UNDER PARAGRAPH 10, YOU MA Y BE SUBJECT TO FEDERAL PROSECUTION
AND PENALTIES UNDER THE "BRADY" PROVISIONS OF THE GUN CONTROL ACT,
18 U.S,C. fifi 922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR
AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over the petitioner's residence OR any location where
a violation of this order Occurs OR where the respondent may be located, shall enforce this
order. An arrest for violation of Paragraphs I through 7 of this order may be without warrant,
based solely on probable cause, whether or not the violation is committed in the presence of the
police, 23 Pa.C.S, fi 6113,
Subsequent to an arrest, the police officer shall seizc all weapons used or threatened to
be used during the violation of the protection order or during prior incidents of abuse. When
the respondent is placed under arrest for violation of the order, the respondent shall be taken to
the appropriate authority or authorities before whom respondent is to be arraigned. A
"Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police
offieer OR the petitioner. Petitioner's presence and signature are not required to file the
complaint.
If sufficient grounds for violation of this order are alleged, the respondent shall be
arraigned, bond set and both parties given notice of the dale of the hearing.
o
ndent
~ .
Brian P. RaneyG
Certified Legal Intern
---tf~ %.t/ / cf7~.
Wayne Shade. Esquire
Counsel for Respondent
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VICTIM'S NAME:
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207 DISTRICT ATTORNEY $ 10.00 $
204 COURT COSTS (CLERK OF COURTS I $ 15.00 $
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PERSON, CERTJFYING INFO!lMATION -1!.Jmpo) ..{1
DATE!f3-99
STATE
ZIP
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TARA L. DUKES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
99-1882 CIVIL TERM
v.
KEVIN R. KNIGHT,
Defendant
CHARGE: INDIRECT CRIMINAl, CONTEMPT
IN RE: DEFENDANT FOUND GUILTY
ORDER OF COURT
AND NOW, this 2nd day of August, 1999, upon
consideration of the charge of Indirect Criminal Contempt in the
above-captioned matter, and following a trial in which the
Defendant was represented by Arla M. Waller, Esquire, and the
Commonwealth was represented by William I. Gabig, Esquire, the
Court finds the Defendant guilty of Indirect Criminal Contempt.
By the Court,
J/CA
J Wesley 01
William I. Gabig, Esquire
Assistant District Attorney
Arla M. Waller, Esquire
Assistant Public Defender
Probation
Sheriff
Victim - Witness
:srs
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SEP 1 6 199~
Tara L. Dukes,
Petitioner
v.
: IN TIlE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION-LAW
IN PROTECTION PROM ABUSE
Kevin R. Knight,
Respondent
NO. 99. 1882
CIVIL TERM
AND NOW THIS
ORDER OF COURT
1?~aYOf <(pi-
, 1999, upon consideration of the
attached petition, the ~ro~ection from Abuse 01 der dated April 21, 1999 is hereby ~a7ate~.
PI2 10? r-/Is COU/\ sc( s.L"fl11 selvc.. ccrt(:S J Tlr'd
cD do u pW7 ZJ? 7 /.X....J CJl.(~CLvt-tcJ?f drjc.PClr~1Z.
2.nj r~~,s..il'.s. wb,'c.L, rcco-'cd corles c.
0'fsh :) r a) c/.
BY THE COURT:
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TARA L. DUKES
Plaintiff/Respondent
VS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
KEVIN R. KNIGHT
Defendant/Petitioner
CIVIL ACTION - CUSTODY
NO. 1999-1882 CIVIL TERM
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against
the claims set forth in the fOllowing pages, you must take action
within twenty (20) days after this complaint and notice are served,
by entering a written appearance personally or by attorney and filing
in writing with the court your defenses or objections to the claims
set forth against you. You are warned that if you fail to do so the
case may proceed without you and the court may enter a decree of
divorce or annulment against you. A jUdgment may also be entered
against you for any other claim or relief requested in these papers
by the plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children.
When the ground for divorce is indignities or irretrievable breakdown
of the marriage, you may request marriage counseling. A list of
marriage counselors is available in the Office of the Prothonotary's
at the first floor in the Cumberland Courthouse, One Courthouse
Square, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP.
YOU DO NOT
THE OFFICE SET
Cumberland County Bar Association
2 Liberty Avenue
CarliSle, PA 17013
1-800-990-9108
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- ~ -. .....
TARA L. DUKES
Plaintiff/Respondent
VS
IN THE COURT OF COMMON PLEAs
CUMBERLAND COUNTY, PENNSYLVANIA
KEVIN R. KNIGHT
Defendant/Petitioner
CIVIL ACTION - CUSTODY
NO. 1999-1882 CIVIL TERM
PETITION FOR SPECIAL AND EMERGENCY RELIEF
AND NOW, comes the Defendant/Petitioner, Kevin Knight, by
and through his ,attorney, Gail SOUders, Esquire, and files the
fOllowing Petition for Special and Emergency Relief and in support
thereof avers as follows.
1. Defendant/Petitioner is Kevin Knight, an adult individual
residing at 3240 Southwest 44th Street, Fort LaUderdale,
Florida 33312. (hereafter "Father")
2. Plaintiff/Respondent is Tara Dukes an adult individual
residing at 1637 Naudian Street, HarriSburg, Pennsylvania
17104. (hereinafter "Mother")
3. The parties are parents of one minor child namely Khaila
Knight born February 13, 1997.
4. The current Order regarding child custody is the Order of
April 21, 1999. See Exhibit A.
5. In March of 2003, parties agreed to an alternative custody
arrangement where the child would live with Father since
Mother was homeless.
6. Additionally, child was not regularly attending school while
in Mother's care. See Exhibit B.
7. Father was the primary caretaker of the child from March 2003
through July 2004.
8. Since child has been in Father's care she has been attending
school regularly.
9. In the beginning of July of 2004, Father dropped child off
with Mother with the understanding that she would return to
Florida for school in August.
07/2&/2004 10~42
.9549&11 872
STEVE AND LIN~
PAGE 01
",
P'IDt '/lflll. __ nt:
.
717 au AT.S
2804.a?"1.
1:1'17
IlI:f7 P.~
TARA L. DUDs, Xlf TID: COURT Oi' 00t0aI PLlIAs 0'
Petitioner c:tlMBBRI.Nm COtl!l'rlr, P.DIfsn.wurzA
' .
v. CIVU. AC'l'IOW - LllJJ
Dvnf R. BIGHT,
Ra8pOndent 110. 9.9-18S.a CIVIL TBRH
Ill. JUh CV5ToD'l' AORBllIIIDlT
Otmn OP rnrJ'RT
AND NOW, this 21.t day of April, 1999, with
X..lllpec:t to l::U8tOCly of the part!..' child, lOIai1. R. Xr11ght Cdate
of birtb PeDX\la2:y 13, 111117), and P\lX'8\Wlt to all ag'Z8aIent;
reached in open court between Tara L. Pulcge,' the' child'. lIlOth_r,
repreBUltad by the Pamily Law Clinic, in the perao.ll ot Briall P.
Rauoy, lIuperviBe4 by ProfulIOr RObart Ra.i.n8, Bsqu:1re. and 1Cevin
' -
R. Itnight, the c:h1ld'. fathtir, pro Be, it iB ordered 8Dd
directed aD fo11owu:
1. :rhe parties shall have .harcid legal cult:ody of
their ohild, !Chaila R. Jr:igh1:.
2. The IlIOther shall have primazy phYSioal OUIItcdy
of tile child..
3. The fathar allall bave partial Phyuiaal OUIItody
of the child every week, p1cJcing tile child up on SUnday lletween
6100 ~ 6:~o p.m. Utd rctuming the, child on TueBdfty between
6:00 and 6:30 p.lII. The father shall be rellPODe:l.ble for the
tran8PQrtation of the child to and frOlll such visit...
4. The ,father ehsU not take the ohild outside of
the state of Psnnllylvanb. without exprelOB prior conaent of the
IlIOther ,
S. The partie" intend. to be legally tloUlll1 by the
Exhibit A
JlI..U-IU 11111.
FB>>IIl IICI WlQTMY ICl<<lOL
71741QU4
NZ/J r.~tIOT Nil
4 Forie Road
BoiUng SprJDg~, PA 17007
W.Q.1Ico~
T.ltpbll/le: 7t7....6-3406
1'1<lII1Il1I" 717-4811.3654
80' Holly rID
M" tIl.ll,. ~ FA 1706$
Mattf13. 2003
Ms. Tara Dukes
7 Pine Roat.l. ~
ML Holly Springs, PA 17065
r>t" MI. D!lkes,
l1'Ie Boartl fA Educa~on reqilll'8$ that school aged pupils tlIlI'lllled In the llI:Mol$ or the dialri<lt allllnd sd1001
I'8!lUlllrly In lICCCI'dMce With !he /aWl Of the iIaIe. Tllo f'IJI'CaIiCnQI PAlgl'am ofttted I:>y ItI6 di&trict Is
predlcalllO upon the pmtnce of 111& pupil and requires contlnully of InslnJt;llcn snd classroom participation.
Acoordingto ovrat!llndane4 record$, )OUTCIIUCI. Khalfa, has a loW Qf 111abilellCell. I(~reccrda diIl'l!rliom
lhllIamounr. pl~ contact Mrs. Sharon Giselman 81.258.64114 llXL 3402.
In aCCOrdanoe with SOUlIl MJddleton S<:llQO/ DlsUf&;t Policy@218 whfCllaUllas _
Illness -
mell,", dDCU/ll8nt.atlan may 1If l'1IqUlred for stlldent IIIlsencq over
fltteon (15) daylI during Iho ec:haa/ year.
Medical dOCUmentaUon wRl ~ NtJulredfor each ~ day Khal1.a I. ab!:enl due 1lCllUne!l8. Abs__ due
to IUness without nHldiDill dce~mentAtJon will be marked UlleJccUsed.
EnclolUld iG a QOf)y or SOIlll1 Middleton SchOOl Oisb1cfs polley on attMdllllCll. It you have BrIY questfonc,
please feel free 10 ean me at W.G. RI"" E<lamantary ScI100lltt 2~ eXL 3400.
Sincerely,
~~
sg
EnClllsuret
CC: Ol'lll9 Paxton, Attendance SectOllolY
CllroI\I POsavec, School COIInse/or
DoIlle NawCOlll'!r, ~ Nu"",
Exhibit B
TARA I.. DUKES
Pl.AINTIFF
IN TilE ('OURT OF COMMON PLEAS OF
('UMIlEIU.AND COUNTY. I'ENNSYJ.V ANIA
v,
99.1882 C1VILA(TIONLAW
KEVIN R. KNIGHT
DEFENDANT
IN CUSTODY
OlmER OF COllin
AND NOW, Thursday, August 05. 2004 . upon consideration of the attached Complaint.
it is hereby directed that parties and their respective counsel appear belore Melissa 1'" (;reevy, Esq., ' the conciliator.
at 30t Market Street, Lemoyn., PA 17043 on Thursday, August 26, 2004 at 1 :00 PM
for a Pre-Hearing Custody Conference. At such conference. an enort will be made to resolve the issues in dispute; or
if this cannot be accomplished, to define and narrow the issues to be heard by the court, and to enter into a temporary
order. All children aj(e five or older may also be present at the eonrerenee. Failure to appear at the conrerence may
provide grounds for entry ora temporary or permanent order.
The court hereby dIrects the parties to furnish any and all existing Protection from Abuse orders,
Special Relief orders, and Custody orders to the concilialor 48 hours prior to scheduled hearing.
FOR THE COURT.
By: /s/
mho
Melissa P. Greev.y, Esq.
Custody Conciliator
The Court or Common Pleas or Cumberland County is required by law to comply with the
Americans with Disabilites Act or 1990. For inronnntion about accessible facilities and reasonable
accommodations available to disabled individuals having business bcrore the court, please contact our office.
All arrangements must be made at least 72 hours prior to any hearing or business befbre the court. You must
attend the scheduled eonrerenee or hearing.
YOU SHOULD TAKE THIS PAPER TO YOUR AnORNEY AT ONCE. IF YOU DO NOT
HAVE AN A nORNEY OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE OFFICE SET
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP,
Cumberland County Bar Association
32 South Bedford Street
Carlisle, Pennsylvania 17013
Telephone (717) 249.3166
Plaintiff
IN THE COURT OF COMMON PLEAS
DAUPHIN COUNTY, PENNSYLVANIA
~l
!
I
TARA L. DtntES
VB.
CIVIL ACTION - CUSTODY
KEVIN R. KNIGHT
Defendant
NO. 99-1882 CIVIL TERM
ORDER
You, , are ORDERED to appear in person in
the Custody Mediation Office, Cumberland County Courthouse on
at o'clock a,m./p.m. for a Pre-Hearing
Custody Conference. At such Conference, an effort will be made to
resolve the issues in dispute; or if this cannot be accomplished, to
define and narrow the issues to be heard by the Court, and to enter
into Temporary Order. Children need not be present unless requested
by the Conference Officer. Failure to appear at the Conference may
provide grounds for entry of a temporary or permanent Order.
For the Court:
Date:
By
Custody Conference Officer
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
1-800-990-9108
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 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.
TARA L. DUKES
Plainti~E/Re.pond.nt
VS
IN THE COURT or CONNON PLEAs
CUMBERLAND COUNTY, PENNSYLVANIA
KEVIN R. KNIGHT
D.~.ndant/Petition.r
CIVIL ACTION - CUSTODY
NO. 1999-1882 CIVIL TERM
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against
the claims set forth in the fOllowing pages, you must takA action
within twenty (20) days after this complaint and notice are served,
by entering a written appearance personally or by attorney and filing
in writing with the court your defenses or objections to the claims
set forth against you. You are warned that if you fail to do so the
case may proceed without you and the court may enter a decree of
divorce or annulment against you. A jUdgment may also be entered
against you for any other claim or relief requested in these papers
by the plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children.
When the ground for divorce is indignities or irretrievable breakdown
of the marriage, you may request marriage counseling. A list of
marriage Counselors is available in the Office of the Prothonotary's
at the first floor in the Cumberland Courthouse, One Courthouse
Square, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNuLMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. 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.
Cumberland County Bar Association
2 Liberty Avenue
Carlisle, PA 17013
1-800-990-9108
WHEREFORE, Petitioner/Defendant requests that the Court modify the
existing Order to primary physical and joint legal custody of Khaila
Knight because it would be in the best interest of the child.
~~~
Gail Guida Souders
Attorney for the Plaintiff
Guida Law Offices
111 Locust Street
Harrisburg, PA 17101
(717) 236-6440
Supreme Court ID# 68740
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07/26/2004 10:42
9549611872
STEVE AND LINDA
PAGE 01
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I'IVl '/AIL __ lITC
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717 a.. ID'r.J
-.117-1.
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TARA L. DlJIQls ,
Petitioaer
v.
or THtI: CXlURT OV ':oJOaI PLHAs OF
CC)lD~ COtlli'rY, PIDIIrBYL~:rA
CIVIL ACTImI' - LAJf
ImVm R. 1IJfIGHT,
Respondent
I
I
I NO. 99-~88~ CIVIL TBRK
IN. RBI ~IlY AGRBIlMIDrr
0R1'nnJ OIl mr~
AND NOIf, this 21et day of April, 1999, wieh
respect to OUlItOl1y of the partiall' child, Khail. R. JCnight (clate
of birtb Feb:mary 13, 111117). aud PUX'CUADt. to an ~l:
reached in open court betwaen Tara L. Dultee; the' child'. lIlOther,
represented by the Family Law Clinic, in the person of Brian P.
Raney, lJupex-vit:ed by ProfeslIOr Robert RA1na, Bsquire. and JCeYin
' .
R. Itni!lht, the ch114'. father, pro Be, it ilJ ordered and
direal:ed a. fo1~OWVI
1 . The parties shall have! shanid legal custody gf
their child, Khaila Ro. It:cigM.
.2 . The mother shall have primary phYSical ClWItody
of tile child.
3 . '1'he father allall bave partial phYl'ical c;:ual:ocly
of the child every week, picking the child up on SUnday between
6:00 imd 6:30 p.m. Uld retuming the child OIl 'l'ullllday between
6,00 and 6:30 p.lII. The father shall be responsible for the
transportation of the child to and from such viait...
,. The ,father .hall not tall;e the child oul:side of
the stat.. of Pannsylvanill without express prior co_ent of tho:
lIlOther ,
S. The Partie.. intend to be 1esally boUl:l4 by t:he
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AUG 03 2004<
TARA L. DUKES.
Plaintiff
IN TIlE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LA W
KEVIN R. KNIGHT,
Dcfendant
NO. 99.1882CIVIL TERM
ORDER OF COURT
AND NOW, this 2nd day of August. 2004, upon considcration of Dcfendant's
Petition for Special and Emcrgcncy Rclief, this mattcr is refcrred to the custody
conciliation process pursuant to C.C.R.P. 1915.12-1, and the Court Administrator is
requested to facilitate this rcfcrral.
BY THE COURT,
Family Law Clinic
45 N. Pitt Street
Carlisle, PA 17013
Attorney for Plaintiff
Gail Guida Souders, Esq.
III Locust Street
Harrisburg, P A 17101
Attorney for Defendant
n(,mber1and County Court
/.A.d~inistrator
:rc
~
TARA L, DUKES
Plaintiff/Respondent
VS
IN THE COURT 011' COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - CUSTODY
KEVIN R. !QUGHT
Defendant/Petitioner
NO. 1999-1882 CIVIL TERM
NOTICE TO DEFEND
You have been sued in court. If you wish to defend against
the claims set forth in the following pages, you must take action
within twenty (20) days after this complaint and notice are served,
by entering a written appearance personally or by attorney and filing
in writing with the court your defenses or objections to tho claims
set forth against you. You are warned that if you fail to do so the
case may proceed without you and the court may enter a decree of
divorce or annulment against you. A judgment may also be entered
against you for any other claim or relief requested in these papers
by the plaintiff. You may lose money or property or other rights
important to you, including custody or visitation of your children.
When the ground for divorce is indignities or irretrievable breakdown
of the marriage, you may request marriage counseling. A list of
marriage counselors is available in the Office of the Prothonotary's
at the first floor in the Cumberland Courthouse, One Courthouse
Square, Carlisle, Pennsylvania.
IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY,
LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,
YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT
HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE O,E;FlCi
FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. c g
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Carlisle, PA 17013
1-800-990-9108
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TARA L, DUJCJI:S
Plaintitt/Respondent
VS
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - CUSTODY
KEVIN R. KNIGHT
Detendsnt/Petieioner
NO. 1999-1882 CIVIL TERM
PETITION FOR SPECIAL AND EMERGENCY RELIEF
AND NOW, comes the Defendant/Petitioner, Kevin Knight, by
and through his .attorney, Gail Souders, Esquire, and files the
following Petition for Special and Emergency Relief and in support
thereof avers as follows.
1. Defendant/Petitioner is Kevin Knight, an adult individual
residing at 3240 Southwest 44th Street, Fort Lauderdale,
Florida 33312. (hereafter "Father")
2. Plaintiff/Respondent is Tara Dukes an adult individual
residing at 1637 Naudian Street, Harrisburg, Pennsylvania
17104. (hereinafter "Mother")
3. The parties are parents of one minor child namely Khaila
Knight born February 13, 1997.
4. The current Order regarding child custody is the Order of
April 21, 1999. See Exhibit A.
5. In March of 2003, parties agreed to an alternative custody
arrangement where the child would live with Father since
Mother was homeless.
6. Additionally, child was not regularly attending school while
in Mother's care. See Exhibit B.
7. Father was the primary caretaker of the child from March 2003
through July 2004.
8. Since child has been in Father's care she has been attending
school regularly.
9. In the beginning of July of 2004, Father dropped child off
with Mother with the understanding that she would return to
Florida for school in August.
,
10, On July 13, 2004, Father spoke to child and she told him that
for the past two days, she and her siblings have been home
alone without a babysitter while Mother is working,
11. On that day, Father called police but no charges were filed
but an incident report was documented.
12, Since July 13, 2004, Mother has denied all phone contact with
child nor will she speak to Father.
13. Additionally, Mother is not permitting child to return to
Florida for school.
14. Mother told Father's mother that she was being evicted from
her home on August 1, 2004.
15. Since the 1999 Order does not reflect what the parties have
been practicing, Father has filed a Motion to Modify the
Order,
16. Father believes and therefore avers that between the time of
the filing of the Petition for Modification and the actual
hearing, that the parties will be unable to reach an
agreement concerning the primary custody and partial custody
of the child.
17. Since school begins on August 16, 2004, it would be in the
best interest of the child for Father to have primary
physical custody during the interim time frame pending
outcome of the Petition for Modification seeking primary
physical custody for the all the other above-mentioned
reasons.
WHEREFORE, for all of the reasons stated above, Father requests this
Honorable Court grant him primary physical custody of the Khaila
Knight.
Respectfully submitted,
Gai Guida Souders
Attorney for Plaintiff
Guida Law Offices, P.C.
111 Locust Street
Harrisburg, PA 17101
717 236-6440
Supreme Court ID #68740
07/2&/20a4 la:42
9549&11872
STEVE AND LINDA
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'tARA L. 00JalS , I nr '1'IlX OOUJl.T or OOIDm PL8As or
petitiClllllr I ~ COtlH'l'lr, PIIIaInL~
I
v. I CIVIL ACrIOll - LIIJf
I
ImVI1f R. IOfrGH'l' , I
Ila~t I NO. 9.9"1.882 CIVIL '1'!IRK
J:ilI. JlBr ~..",..y AGRBBM:IDIT
0Rmm Oli' COtJ'R'r
AND NOlf, tbb n.t day of April, 1999, wit:h
reaper;t to ouatody of the parti.., child, Jtbaila a. JCJ11ght (date
of bi:r:t:h UeD:NaJ:y 13, 1.11117), aud. pUr81W1t to tu:I lI91;- 8nt
reached ill open court between Tare L. Dulce;; the' ch1lc1'. moth",
repA"anted by the Il'lUIlily Law Clinic, in tbe penon of Brian P.
RaIley, lIupervice4 by ProfeallOr RObert: Rain.v, B/irqtU%'a. IIZId JCeY1n
. . .
R.. Knight, the child'. fatlutr, pro Be, it ilJ ordered lUId
directed ." fo11owul
1. The parties I1ha.ll have 8har8d legal cu8t:ody of
their child, !Chaile R.. !:night.
:I. The mother shall have prilllllry phYSioal CWItody
of the ch11cl..
3 . The fathar shall bave puUal phy8ioal ClUJl:cdy
of the ch:l.1d. every week, p1c:king the child up Oil. Sunday between
6.00 and 6,30 p.m. aDd returning the, child 011 'l.'ue.clay between
6rOO and 6:30 p.lII. The father ahall be re8pOD1I~le for l:ha
transportation of the child to and from 8UC!h vi.it...
4 . The ,father _hall 1I0t take the child outllida of
the state of Pennsylvania without express prior conaent of the
lIIOchar ,
S. The partie" intend to be legally I:loWld by the
Exhibit A
PAGE 01
~
TARA L. DUlCES
Plaintiff/aa.pondent
VS
IN THB COURT OF COMMON PLBAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - CUSTODY
ltZVIN R, !(NIGHT
Defendant/Petitioner
NO. 1999-1882 CIVIL TERM
CERTIFICATE OF SERVICE
I hereby certify that on July 26, 2004, I served a copy of the Petition for Special and
Emergency Relief upon the persons and in the manner indicated below, which service satisfies the
requirements of Pennsylvania Rule of Civil Procedure. 403.
Service by Certified Mail to:
Tara Dukes
1637 Naudian Street
Harrisburg, P A 17104
~~;f
Guida Law Offices, P.C.
111 Locust Street
Harrisburg, PA 17101
717-236-6440
Dated: July 26, 2004
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NO. 99.1882 CIVIL TERM
B. Christmas. For Christmas 2004, Mother shall have custody for
Christmas Eve and Christmas Day. Father will have custody commencing December
26, 2004 and continuing throughou1 the remainder of the school break until the day
before school reconvenes in 2005.
C. Sprino Break. Father shall have custody of the child during the child's
spring break. Father shall retum the child to Mother's custody one full day prior to
the commencement of school.
4. Transportation. The Father shall arrange and provide transportation for his
periods of physical custody.
5. Teleohone Assess. Mother and Father shall be entitled to reasonable
telephone access wllh the child while the child is in the other's custody.
6. The parties shall keep one another advised of their current address and
telephone number.
7. Mother and Father shall notify the other immediately of medical emergencies
which arise while the child is in that parent's care.
8. Both parents shall establish a no-conflict zone for their children and refrain
from making derogatory comments about the other parent in the presence or earshot of the
children and, to the extent possible, shall prevent third parties from making such comments
in the presence or earshot of the children.
9. In the event that either parent would be homeless, the child's primary custody
shall be transferred to the other parent until the home situation of the homeless parent has
been re-stabllized.
10. The Custody Conciliation Conference shall reconvene on February 10,
2005 at 11 :00 a.m. at the office of the Custody Conciliator, Melissa Peel Greevy,
Esquire, 301 Market Street, Lemoyne, PA 17043. This Custody Conciliation Conference
date may be cancelled by the mutual agreement of the parties should the parties agree that
it is not necessary at that time. However, the parties shall make that determination not less
than one (1) week in advance of that conference date.
BY THE COURT:
.J.
Dist:
~iI Guida Souders. Esquire. Guida Law Offices, ,C..111 Locust Street. Harrisburg. PA 17101
J{ucy Johnston-Walsh, Esquire. Family Law Clinic. 45 North Pill Street. Carlisle. PA 17013
Amy L, Kruzel. CLio Family Law Clinic. 45 North Pill Street. Carlisle. PA 17013
J fI~tD.o4
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SEP 06 2004
IN CUSTODY
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TARA L. DUKES,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99.1882 CIVIL TERM
v.
CIVIL ACTION - LAW
KEVIN R. KNIGHT,
Defendant
CUSTODY CONCILIATION SUMMARY REPORT
IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE
1915.3-8, the undersigned Custody Conciliator submits the following report:
1. The pertinent information concerning the child who is the subject of this
litigation is as follows:
NAME
DATE OF BIRTH
CURRENTLY IN THE CUSTODY OF
Khaila R. Knight
February 13, 1997
Mother
2. A Custody Conciliation Conference was held on August 26, 2004 following
Mother's Motion for Modification of Custody filed on July 28, 2004. Attending the
Conference were: the Mother, Tara L. Dukes and her counsel. Lucy Johnston-Walsh,
Esquire and Amy L. Kruzel, CLI; the Father, Kevin R. Knight and his counsel, Gail Guida
Souders, Esquire. The last Order entered in this matter had been on April 21, 1999. In
March of 2003, the parties had modified the custodial plan without formalizing it in writing.
This modification, which left the child in the physical custody of the Father continued until
July, 2004.
3.
9/1~Y;
elissa Peel Greevy, Esquire
Custody Conciliator
Date
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3. The following holiday schedule shall supercede the nonnal schedule. The holiday
schedule may be changed as mutually agreed by the parties.
a. Thanksgiving - Father shall have physical custody of the child during the
child's Thanksgiving school break. Father shall return the child to
Mother's custody one full day prior to the commencement of school.
b. Christmas - The parties shall alternate custody of the child for the
Christmas holiday as follows: In odd numbered years, Father will have
custody from December 23rd until one full day prior to the commencement
of school. In even numbered years, Mother shall have custody on both
Christmas Eve and Christmas Day and Father shall have custody from
December 26th until one full day prior to the commencement of school.
c. Spring Break - Father shall have physical custody of the child during the
child's school spring break. Father shall return the child to Mother's
custody one full day prior to the commencement of school.
4. Transportation - Father shall arrange and provide transportation for his periods of
physical custody.
5. Neither party shall remove the child from the country without first obtaining the
consent of the other party.
6. Mother and Father shall be entitled to reasonable telephone access with the child
while the child is in the other's custody.
7. The parties shall keep one another advised of their current address and telephone
number.
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TARA L. DUKES,
Plaintiff/Respondent
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
CIVIL ACTION - LA W
IN CUSTODY
KEVIN R. KNIGHT,
DefendantlPetitioner
: No. ]999-]882 CIVIL TERM
CUSTODY AGREEMENT
THIS AGREEMENT, made this 22. day of April, 2005, between Tara L. Dukes
("Mother") and Kevin R. Knight ("Father") concerns the custody of their child: Khaila Knight,
born Febmary 13, 1997, hereinafter ("the child.")
Mother and Father desire to enter into an agreement as to the custody of the child,
Mother and Father agree to the following:
I. Mother and Father shall have shared legal custody of the child.
2. Mother shall have primary physical custody of the child subject to the Father's
periods of partial custody, which shall be arranged as follows:
a. During the child's summer school recess, beginning the week after school
is dismissed for the summer and returning to Mother one week prior to the
commencement of the next school year.
b. If Father is going to be visiting in Virginia or Pennsylvania, after
providing forty-eight hours notice to Mother, Father will be entitled to
partial custody arranged by mutual agreement of the parties. Although
these periods of partial custody shall not be unreasonably withheld, Father
understands that with only forty-eight hours notice, the Mother and child
may have already scheduled other plans for the time that Father will be
visiting.
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3, The following holiday schedule shall supercede the normal schedule. The holiday
schedule may be changed as mutually agreed by the parties.
a. Thanksgiving - Father shall have physical custody of the child during the
child's Thanksgiving school break. Father shall return the child to
Mother's custody one full day prior to the commencement of school.
b. Christmas - The parties shall alternate custody of the child for the
Christmas holiday as follows: In odd numbered years, Father will have
custody from December 23m until one full day prior to the commencement
of school. In even numbered years, Mother shall have custody on both
Christmas Eve and Christmas Day and Father shall have custody from
December 26th until one full day prior to the commencement of school.
c. Spring Break - Father shall have physical custody of the child during the
child's school spring break. Father shall return the child to Mother's
custody one full day prior to the commencement of school.
4, Transportation - Father shall arrange and provide transportation for his periods of
physical custody.
5. Neither party shall remove the child from the country without first obtaining the
consent of the other party.
6. Mother and Father shall be entitled to reasonable telephone access with the child
while the child is in the other's custody.
7. The parties shall keep one another advised of their current address and telephone
number.
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8. Mother and Father shall notify each other of all medical care the child receives
while in the parent's care. Mother and Father shall notify the other as soon as
reasonably possible of medical emergencies which arise while the child is in that
parent's care.
9. Neither party shall do anything, nor shall they permit third parties to do anything
which may estrange the child from the other party, or injure the opinion ofthe
child as to the other parent or which may hamper the free and natural
development of the child's love and respect for the other parent.
10. In the event that either party would be homeless, the child's primary custody shall
be transferred to the other parent until the home situation of the homeless parent
has been re-stabilized.
11. The parties intend to be bound by the terms of this Agreement and intend for this
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Agreement to be made an Order of Court.
//
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Tara , ukes
PlaintifflRespondent
t2"1rUj- Ii It/II ~ J
Amy L Kruzel
Certified Legal Intern
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Anne Macdonald-Fox
Counsel for the Respondent
SUPERVISING ATTORNEYS
L-JA
Gail Guida Souders
Counsel for Petitioner
F AMIL Y LAW CLINIC
45 N. Pitt Street
Carlisle, P A 17013
717-243-2968
GUIDA LAW OFFICES, P.C.
111 Locust Street
Harrisburg, PA 17101
717-236-6440
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TARA L. DUKES,
PlaintifflRespondent
RECEIVED MAY 172005 fl'1'
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
v.
: CIVIL ACTION - LA W
: IN CUSTODY
KEVIN R. KNIGHT,
DefendantlPetitioner
: No, 1999-1882 CIVIL TERM
ORDER OF COURT
And now, this _( cr fL day of 0-1,,> 7
is approved and entered as an Order of the Court.
,2005, the foregoing Agreement
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In T B:ittmOnv
and the seal ;,
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