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LYNNE AUMILLER-CHRISTENSEN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of her minor child:: CUMBERLAND COUNTY, PENNSYLVANIA
Madison Gwendolyn Christensen,
VS. : NO.99- ?oN s- CIVIL TERM
DAVID ALLAN CHRISTENSEN,
Defendant : PROTECTION FROM ABUSE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the
following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may
proceed against you and a FINAL Order may be entered against you granting the relief requested in the
Petition. In particular, you may be evicted from your residence and lose other important rights.
A HEARING ON THIS MATTER IS SCHEDULED ON MAYo2l,1999, AT 3, 0?.M.,
IN COURTROOM NO. ?-OF THE CUMBERLAND COUNTY COURTHOUSE, CARLISLE,
PENNSYLVANIA.
You MUST obey the Order that is attached until it is modified or terminated by the court after notice
and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you
to a charge of indirect criminal contempt which is punishable by a 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
TELEPHONE NUMBER: (717)249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with
Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to
disabled individuals having business belive the court, please contact our office. All arrangements must be made at
least 72 hours prior to any hearing or business bciitte the court. You must attend the scheduled conference or
hearing.
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LYNNE AUMILLER-CHRISTENSEN,
Plaintiff
forherselfand on behalf of her minor child:
Madison Gwendolyn Christensen,
VS.
DAVID ALLAN CHRISTENSEN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- 3oSr CIVIL TERM
PROTECTION FROM ABUSE
TEMPORARY PROTECTION
FROM ABUSE ORDER
Defendant's Name: DAVID ALLAN CHRISTENSEN
Defendant's Date of Birth: 02/13/68
Defendant's Social Security Number: 200-56-1818
Names of Protected Persons: LYNNEAUMILLER-CHRISTENSEN, Plaintiff, for herself and
on behalf of her minor chj MADISON GWENDOLYN CHRISTENSEN, 3 years old.
AND NOW, th? day of May, 1999, upon consideration of the attached Petition for
Protection from Abuse, the court hereby enters the following Temporary Order:
1. Defendantshall notabuse, harass, stalk or threaten any of theabovepersons
in any place where they might be found.
® 2. Defendant is excluded from the residence at I I Amherst Drive, Camp Hill,
Cumberland County, Pennsylvania, a residence owned solely by Plaintiff, or any other
permanent or temporary residence where Plaintiff may live. Plaintiff is granted exclusive
possession of the residence. Defendant shall have no right or privilege to enter or be present
on the premises.
3. Defendant is prohibited from having ANY CONTACT with Plaintiff at any
location, including, but not limited, to any contact at Plaintiff's place of employment and/or
at the day care facility of her minor child. Defendant is specifically ordered to stay away from
the following locations for the duration of this Order:
Plaintiffs place of employment: Aumiller Auto Parts, Route 147, Halifax,
Dauphin County, Pennsylvania.
Day care facility of the minor child: Brookside Montessori School, 3708
Rosemont Avenue, Camp Hill, Cumberland County, Pennsylvania.
4. Defendant shall not contact Plaintiff by telephone or by any other means,
including through third persons.
? 5. Pending the outcome of the final hearing in this matter. Plaintiff is awarded temporary
custody of the following minor child/ren:
Until the final hearing, all contact between Defendant and the child/ren shall be limited
to the following:
The local law enforcement agency in the jurisdiction where the child/ren are located shall
ensure that the child/ren are placed in the carcand control of Plaintiff in accordance with
the terms of this Order.
? 6. Defendant shall immediately relinquish the following weapons to the Sheriffs Office
or a designated local law enforcement agency for the delivery to the Sheriffs Office:-Defendant is
prohibited from possessing, transferring or acquiring any other weapons for the duration of this
Order.
7. The following additional relief is granted:
The Cumberland County Sheriffs Department shall attempt to make service at
Plaintiffs request and without pre-payment of fees, but service may be
accomplished under any applicable Rule of Civil Procedure.
This Order shall be docketed in the office of the Prothonotary and forwarded
to the Sheriff for service. The Prothonotary shall not send a copy of this Order
to Defendant by mail.
This Order shall remain in effect until modified or terminated by the Court and
can be extended beyond its original expiration date if the Court finds that
Defendant has committed an act of abuse or has engaged in a pattern or
practice that indicates risk of harm to Plaintiff and/or the minor child.
Defendant is enjoined from damaging or destroying any property owned solely
by Plaintiff.
Defendant is to refrain from harassing Plaintiffs relatives or the minor child.
® 8. A certified copy of this Order shall be provided to the police department where
Plaintiff resides and any other agency specified hereafter: Lower Allen Township Police
Department.
9. THIS ORDER SUPERSEDES
ANY PRIOR PFA ORDER
0 ANY PRIOR ORDER RELATING TO CHILD CUSTODY
THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN
IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE
AND HEARING.
NOTICE TO DEFENDANT
Defendant is hereby notified that violation of this Order may result in arrest for indirect
criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months in jail.
23 Pa.C.S. §6114. Consent of the Plaintiff to Defendant's return to the residence shall not invalidate
this Order, which can only be changed or modified through the filing of appropriate court papers for
that purpose. 23 Pa.C.S. §6113. Defendant is further notified that violation of this Order may
subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal
charges and penalties under the Violence Against Women Act, 18 U.S.C. §§ 2261-2262. Any
protection order granted by a court may be considered in any subsequent proceedings, including
child custody proceedings, under title 23 (Domestic Relations) of the Pennsylvania Consolidated.
Statutes.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the police who have jurisdiction over Plaintiffs residence
OR any locations where a violation of this order occurs OR where Defendant may be located. If
Defendant violates Paragraphs I through 6 of this Order, Defendant may be arrested on the charge
of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant,
based solely on probable cause, whether or not the violation is committed in the presence of law
enforcement.
Subsequent to an arrest, the law enibreement officer shall seize all weapons used or
threatened to be used during the violation of this Order OR during prior incidents of abuse.
Weapons must forthwith be delivered to the Sheriffs office of the county which issued this Order,
which office shall maintain possession of the weapons until further Order of this Court, unless the
weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency
whose officer made the arrest.
BY THE CQUI?T,
4 Judge
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
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LYNNE AUMILLER-CHRISTENSEN,
Plaintiff
for herself and on behalf of her minor child:
Madison Gwendolyn Christensen,
vs.
DAVID ALLAN CHRISTENSEN,
Defendant
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- 308!r' CIVIL TERM
PROTECTION FROM ABUSE
PETITION FOR
PROTECTION FROM ABUSE
The Plaintiff is Lynne Aumiller-Christensen.
2. The persons who seek protection from abuse are Lynne Aumiller-Christensen, Plaintiff,
for herself and for her minor child, Madison Gwendolyn Christensen.
3. Plaintiffs address is 1 I Amherst Drive, Camp Hill, Cumberland County, Pennsylvania
17011.
4. Defendant resides with his mother, Kathryn Christensen, at her home located at 382
Wyatt Road, Harrisburg, Dauphin County, Pennsylvania 17104-1578.
Defendant's Social Security Number is 200-56-1818.
Defendant's date of birth is 02/13/68.
Defendant is employed at the House of Representatives, Capitol Complex, Harrisburg,
Dauphin County, Pennsylvania 17120-0028.
5. Defendant is Plaintiff's former husband.
6. Plaintiff and Defendant have been involved in the following court action for divorce:
Case name Case No. Date tiled Court of Common Pleas
Christensen v. Christensen 97- Dauphin County
7. Defendant has been involved in the following criminal court actions:
Lower Allen Township Police charged Defendant with two counts of stalking
as a result of the incidents involving Plaintiff which occurred in or about April 1999.
Defendant is also believed to have an arrest record in Dauphin County for a DUI
and a drug charge.
8. The facts of the most recent incident of abuse are as follows:
Date: On or about May 8, 1999
Time: 5:05-5:15 p.m.
Place: I I Amherst Drive, Camp Hill, Cumberland County, Pennsylvania,
Plaintiffs residence.
On or about May 8, 1999, from 5:05-5:15 p.m., Defendant telephoned
Plaintiff s residence five times, screamed and yelled her, and demanded to know
why the Lower Allen Township Police charged him with stalking her. Plaintiff
repeatedly told Defendant not to call her again, but he ignored her, and during
one telephone call, threatened her saying, "If you don't let me see Maddy (the
parties' 3-year old daughter), you'll die tonight." Fearing for her safety, and that
of her minor child, Plaintiff reported the incident to the Lower Allen Township
Police Department.
9. Defendant has committed the following prior acts of abuse against Plaintiff:
a) In or about late April 1999, Defendant telephoned Plaintiff at her home.
and threatened to blow up her house, blow up the business of her friend, Scott's,
and kill them both. Plaintiff reported the incident to the Lower Allen Township
Police who filed stalking charges against Defendant as a result of this incident
and others which had occurred since March 1999. District Justice Clement
scheduled a preliminary hearing in the case on June 24, 1999, at 11:30 a.m.
b) From early to mid-April 1999, Defendant abused Plaintiff in ways
including the following: telephoned Plaintiff several times and threatened to
blow up her residence and the business of her friend and to kill them both and
threatened to kill her; told Plaintiff that he drives by her house at all hours, takes
down license plate numbers of any vehicles in her driveway, borrows money
from people to buy gas so he could drive by her house; telephoned her in the
early hours of the morning demanding to know whose vehicle was in her
driveway and to know about her sexual relations with anyone she has dated.
C) In or about late March 1999, Defendant told Plaintiff during a telephone
conversation that when he went to her home on or about March 21, 1999, he
took down the license plate numbers of vehicles belonging to her guests which
were parked in her driveway, and had a friend of his who works at the
Pennsylvania Department of Transportation trace the plate numbers and provide
him with the names, addresses and telephones numbers of her friends.
Defendant boasted to Plaintiff that he had telephoned her male friend, Scott,
saying that he knew where he lived and was going to kill him because he did not
want anyone else in her life except himself. Defendant had telephoned Scott at
his business several times, hanging up the telephone at times and during some
calls demanding that he stay away from Plaintiff.
Plaintiff mailed a letter to Defendant after the incident which occurred
on or about March 21, 1999, advising him not to go to her residence or her place
of employment again or he would be considered a defiant trespasser, and not to
harass her further (see attached Exhibit A, incorporated hereto by reference).
Plaintiff mailed copies to the Lower Allen Township Police and the
Pennsylvania State Police. Defendant telephoned Plaintiff after receiving the
letter demanding to know why she sent him the letter.
d) On or about March 22, 1999, at approximately 8:00 a.m., Plaintiff was
talking on the telephone when the doorbell rang, and before she could stop her,
Plaintiff's 3-year-old daughter opened the door. Defendant entered the house,
walked into the living room where Plaintiff stood, grabbed the telephone from
her hand, and hung up the receiver disconnecting her call. Defendant
interrogated Plaintiff about who she was associating with. Only when Plaintiff's
friend, who was concerned for her safety, called back, did Defendant leave.
e) On or about March 21, 1999, Defendant telephoned Plaintiff at her
residence, asked if he could come over, and although she told him not to come
because she had company, he said that he was going to come over anyway.
Defendant arrived at Plaintiffs home moments later, knocked on the door, and
when she did not answer the door, he yelled through the mail slot in the door
calling her fucking whore, and slut, and questioned her 3 year old daughter to
try to find out who was in the house. Plaintiff's sister came to her house and
told Defendant to leave, which lie did, After Defendant left, Plaintiff, who
feared for her safety if Defendant were to come back, took her child and went
to her sister's home for her protection. As Plaintiff and her child got across the
street to her sister's yard, Defendant drove up, parked in the middle of the street,
got out of his car, and screamed and yelled at Plaintiff repeatedly calling her
names, and threatened to vandalized her vehicle and that of her friend.
Plaintiff's sister told Defendant to leave and he did.
10. The following police department or law enforcement agency in the area in which
Plaintiff lives should be provided with a copy of the Protection Order: Lower Allen Township Police
Department.
11. There is an immediate and present danger of further abuse from Defendant.
12. Plaintiff is asking the Court to exclude Defendant from her residence at 11 Amherst
Drive, Camp Hill, Cumberland County, Pennsylvania, which is owned solely by her.
13. Plaintiff has suffered the following out-of-pocket financial losses as a result oftheabuse
described above: see attached Exhibit B, incorporated hereto by reference.
WHEREFORE, PLAINTIFF REQUESTS THAT THE COURT ENTER A
TEMPORARY ORDER, AND AFTER HEARING, A FINAL ORDER THAT WOULD DO
THE FOLLOWING:
A. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff
and/or her minor child in any place where Plaintiff may be found.
B. Exclude Defendant from Plaintiffs residence and prohibit Defendant from
attempting to enter any temporary or permanent residence of the Plaintiff.
C. Prohibit Defendant from having any contact with Plaintiff, either in person, by
telephone, or in writing, personally or through third persons, including, but not limited
to, any contact at Plaintiffs place of employment or at the minor child's day care
facility.
D. Prohibit Defendant from having any contact with Plaintiffs relatives.
E. Direct Defendant to pay Plaintiff for the reasonable financial losses suffered as
a result of the abuse, to be determined at the hearing.
F. Order Defendant to pay the costs of this action, including filing and service fees.
G. Order Defendant to reimburse Cumberland County, a Legal Services funding
source, $250.00 for the value of the legal services provided to Plaintiff for the cost of
litigating this case if the case goes to hearing.
H. Order the following additional relief, not listed above:
Defendant is enjoined from damaging or destroying any property owned by
Plaintiff.
Defendant is to refrain from harassing Plaintiff s relatives or her minor child.
1. Grant such other relief as the court deems appropriate.
J. Order the police or other law enforcement agency to serve Defendant with a
copy of this Petition, any Order issued, and the Order for Hearing. The Petitioner will
inform the designated authority of any addresses, other than Defendant's residence,
where Defendant can be served.
Date: ?? - I-
/Respectfully( ssuubmitted,
oars Carey, Attorney fo aintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
i
VERIFICATION
1 verify that I am the Petitioner as designated in the present action and that the facts and
statements contained in the above Petition are true and correct to the best of my knowledge. I
understand that any false statements are made subject to the penalties of 18 Pa.C.S. §4904, relating
to unswom falsification to authorities,
Dated:
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Lynn=Ruth Aumiller-Christensen, Plaintiff
MARCH 24, 1999
DAVID CHRISTENSEN
382 WYATT ROAD
HARRISBURG, PA 17104
Dear MR. CHRISTENSEN;
This letter gives you official notice that you will be considered a
DEFIANT TRESPASSER if you come to my residence at 11 AMHERST DRIVE,
CAMP HILL, PA 17011 or my place of employment at AUMILLER'S AUTO
PARTS, RT. #147, P.O. BOX 515, HALIFAX, PA 1703 2.
The penalty for defiant trespass is up to ONE YEAR IN JAIL.
Furthermore, if you continue to commit acts which alarm or
seriously annoy me, and which serve no legitimate purpose, you could
be prosecuted for the summary offense of HARASSMENT. The penalty for
harassment is up to 90 DAYS IN JAIL.
A copy of this letter is being given to the LOWER ALLEN POLICE DEPT.
and the HALIFAX POLICE DEPT. They will be called,if you defy this request
and come to my residence or my place of employment or if you continue to
harass me.
LYNNE AUMILLER-CHRISTENSEN
c: File
LOWER ALLEN POLICE DEPT.
HALIFAX POLICE DEPT.
AUMILLER'S AUTO PARTS
EXHIBIT A
LYNNE AUMILLER-CHRISTENSEN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of her minor child:: CUMBERLAND COUNTY, PENNSYLVANIA
Madison Gwendolyn Christensen,
Vs. : NO. 99- CIVIL TERM
DAVID ALLAN CHRISTENSEN,
Defendant : PROTECTION FROM ABUSE
OUT-OF-POCKET LOSSES
The Plaintiff requests that Defendant reimburse her out-of-pocket losses, including but not
limited to the following:
Lost wages as a result of the incidents which occurred since March 1999. $540.00
EXHIBIT B
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LYNNE AUMILLER-CHRISTENSEN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of her minor child, : CUMBERLAND COUNTY, PENNSYLVANIA
Madison Gwendolyn Christensen,
vs. : NO. 99-3085 CIVIL TERM
DAVID ALLAN CHRISTENSEN,
Defendant : PROTECTION FROM ABUSE
AND NOW, this
of June, 1999, upon consideration of the attached Motion for
Continuance, the hearing scheduled on May 27, 1999, at 3:30 p.m. is rescheduled for hearing on
Tuesday, June 15, 1999, at 3:00 p.m. in Courtroom No. 3.
The Temporary Protection From Abuse Order shall remain in effect for a period of one year
from the date it was entered, through May 21, 2000, oruntil further Order ofCourt, whichever comes
first.
A certified copy of this Order for Continuance shall be provided to the Lower Allen
Township Police Department by Plaintiffs attorney.
George E. Hiller, President Judge
Joan Carey, Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013 .tc.fYt( U???y 9.
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Karl E. Rominger, Attorney for Defendant T+
LAW OFFICES OF PAUL BRADFORD ORR
50 East High Street
Carlisle, PA 17013
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rE?'?f??sYLV?1NU?
LYNNE AUMILLER-CHRISTENSEN,
Plaintiff
for herself and on behalf of her minor child,
Madison Gwendolyn Christensen,
VS.
DAVID ALLAN CHRISTENSEN,
Defendant
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3085 CIVIL TERM
PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
Plaintiff, Lynne Aumilier-Christensen, by and through her attorney, Joan Carey of Legal
Services, Inc., moves the Court for an Order rescheduling the hearing in the above-captioned case
on the grounds that:
I. A Temporary Protection From Abuse Order was issued by this Court on May 21,
1999, scheduling a hearing for May 27, 1999, at 3:30 p.m. in Courtroom No. 3.
2. The Cumberland County Sheriffs Department deputized the Dauphin County
Sheriffs Department, and Defendant was served with a certified copy of the Temporary Protection
From Abuse Order and Petition for Protection From Abuse at his residence at 382 Wyatt Road,
Harrisburg, Dauphin County, Pennsylvania.
3. Defendant indicated to Legal Services, Inc. staff on May 26, 1999, that although he
was advised that he had a right to counsel, he did not want representation in this matter, that he
desired to settle the case, and agreed to meet with Legal Services, Inc. staff at 11:00 a.m. on May 27,
1999, at the Cumberland County Courthouse to review and sign the Final Protection Order. When
they met, Defendant advised Legal Services, Inc. staff that he had retained Karl E. Rominger of the
Law Offices of Paul Bradford Orr to represent him in this matter.
4. Counsel for Defendant requests that the hearing be rescheduled, and Plaintiff, by and
through her attorney, agrees.
5. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect
for a period of one year from the date it was entered, through May 21, 2000, or until further Order
of Court, whichever comes first.
6. A certified copy of the Order for Continuance will be delivered to the Lower Allen
Township Police Department by the attorney for Plaintiff.
WHEREFORE, Plaintiff requests that the Court grant this Motion and reschedule this matter
for hearing, and that the Temporary Protection From Abuse Order remain in effect for a period of
one year from the date it was entered, through May 27, 2000, or until further Order of Court,
whichever comes first.
Respectfully submitted,
Join Carey, Attorney f w (Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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LYNNE AUMILLER-CHRISTENSEN,
Plaintiff
for herself and on behalf of her minor child,
Madison Gwendolyn Christensen,
vs.
DAVID ALLAN CHRISTENSEN,
Defendant
IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3085 CIVIL TERM
PROTECTION FROM ABUSE
ORDER FOR CONTINUANCE
AND NOW, thisji' of June, 1999, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on June 15, 1999, at 3:00 p.m. by this Court's Order
of June 7, 1999, is hereby continued generally.
This Order is entered without prejudice to either party to request a hearing.
The Temporary Protection From Abuse Order shall remain in effect for a period of one year
from the date it was entered, through May 21, 2000, or until further Order of Court, whichever comes
first.
A certified copy of this Order for Continuance shall be provided to the Lower Allen
Township Police Department by Plaintiffs attorney.
Joan Carey, Attorney for Plaintiff
LEGAL SERVICES, INC.
Karl E. Rominger, Attorney for Defendant
LAW OFFICE OF PAUL BRADFORD ORR
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LYNNE AUMILLER-CHRISTENSEN,
Plaintiff
for herself and on behalf of her minor child,
Madison Gwendolyn Christensen,
vs.
DAVID ALLAN CHRISTENSEN,
Defendant
IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3085 CIVIL TERM
PROTECTION FROM ABUSE
Plaintiff, Lynne Aumiller-Christensen, by and through her attorney, Joan Carey of Legal
Services, Inc., moves the Court for an Order continuing generally the hearing in the above-captioned
case on the grounds that:
A Temporary Protection From Abuse Order was issued by this Court on May 21,
1999, scheduling a hearing for May 27, 1999, at 3:30 p.m. Defendant was served with a certified
copy of the Notice of Hearing and Temporary Protection From Abuse Order and Petition for
Protection Order on May 26, 1999, by the Dauphin County Sheriff's Department.
2. Defendant retained Karl E. Rominger of the Law Office of Paul Bradford Orr to
represent him in this matter. On May 27, 1999, counsel for Defendant requested that the case be
rescheduled, and Plaintiff, by and through her attorney, agreed.
3. Plaintiff filed a Motion for Continuance and an Order for Continuance was entered
on June 7, 1999, rescheduling the hearing for June 15, 1999, at 3:00 P.M.
4. The parties, by and through their respective counsel, have negotiated an agreement
and request a general continuance in this case to facilitate the review and signing of the documents.
5. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect
for a period of one year from the date it was entered, through May 21, 2000, or until further Order
of Court, whichever comes first.
6. A certified copy of the Order for Continuance will be delivered to the Lower Allen
Township Police Department by the attorney for Plaintiff.
WHEREFORE, Plaintiff requests that the Court grant this Motion and continue this matter
generally, and that the Temporary Protection From Abuse Order remain in effect for a period of one
year from the date it was entered, through May 21, 2000, or until further Order of Court, whichever
comes first.
Joan Carey, Attome#or Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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, SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 1999-03085 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
AUMILLER-CHRISTENSEN LYNNE
VS.
CHRISTENSEN DAVID ALLAN
R. Thomas Kline _ , Sheriff, who being duly sworn according
to law, says, that he made a diligent search and inquiry for the within
named defendant, to wit: CHRISTENSEN DAVID ALLAN
but was unable to locate Him in his bailiwick. He therefore
deputized the sheriff of DAUPHIN COUNTY County, Pennsylvania.
to serve the within PROTECTION FROM ABUSE
On June 16th, 1999 this office was in receipt of
the attached return from DAUPHIN COUNTY County, Pennsylvania.
Sheriff's Costs: So answers: /
Docketing 18.00
Out of County 9.00
i
Surcharge 8.00 m s ine, 61
U 00/00/0000
Sworn and subscribed to before me
this /6 t? day of QA&
1999 A.D.
n
rouiono r
Marv Jane Snyder
Real Estate lepity
William T. Tully
Solicitor
Ralph G. McAllister
Chief Deputy
Michael W. Rinehart
Assistant Chief Deputy
Dauphin County
Harrisburg, Pennsylvania 17101
ph:(717)255.2660 fas:(717)255.2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania AUMILLER-CHRISTENSEN LYNNE
vs
County of Dauphin CHRISTENSEN DAVID ALLAN
Sheriff's Return
No. 1026-T - - -1999
OTHER COU14TY NO. 99-3085
AND NOW: May 26, 1999
PROTECTION FROM ABUSE
at 2:45AM served the within
upon
CHRISTENSEN DAVID ALLAN by personally handing
to DEF 1 true attested copy(ies)
of the original PROTECTION FROM ABUSE and making known
to him/her the contents thereof at DAUPHIN COUNTY COURTHOUSE
HARRISBURG, PA 00000-0000
Sworn and subscribed to
before me this 7TH day of NNE, 1999
c1r?c?It
PROTHONOTARY
of E a$hprfff
So Answers,
lex??
Sheriff of Dauphin County, Pa.
By
Deputy riff
Sheriff's Costs: $0.00 PD 00/00/0000
RCPT NO
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In The Court of Common Pleas of Cumberland County, Pennsylvania
Lynne Aumille-Christensen
David AllanVChristensen
No.99-3085 Civil
Now, May 21 , 19 99 , 1, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Dauphin County to execute this Writ, this
deputation being made at the request and risk of the Plaintiff.
er-.
Sheriff of Cumberland County, PA
Affidavit of Service
Now,
within
upon
at
by handing to _
a
and made known to
So answers,
the contents thereof.
Sheriff of
Sworn and subscribed before
me this _ day of 19
19_, at o'clock M. served the
copy of the original
COSTS
SERVICE
MILEAGE _
AFFIDAVIT
County, PA
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LYNNE AUR-CHRISTENSEN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
for herself and on behalf of her minor child, CUMBERLAND COUNTY, PENNSYLVANIA
Madison Gwendolyn Christensen,
vs. : NO. 99-3085 CIVIL TERM
DAVID ALLAN CHRISTENSEN,
Defendant : PROTECTION FROM ABUSE
FINAL PROTECTION ORDER
Defendant's Name: DAVID ALLAN CHRISTENSEN
Defendants Date of Birth: 02/13/68
Defendant's Social Security Number: 200-56-1818
Names of Protected Persons: LYNNE AUMILLER-CH TENSEN, Plaintiff, and her minor
child, MADISON GWEtYN CH S E S
AND NOW, this day of*rse,199 he court having jurisdiction over the parties
and the subject-matter, it s ORDERED, ADJ GED, and DECREED as follows:
Plaintiff, Lynne Aumiller-Christensen, is represented by Joan Carey of Legal Services,
Inc.; Defendant, David Allan Christensen, is represented by Karl E. Rominger, Attorney at
Law, Law Office of Paul Bradford Orr.
Defendant, although agreeing to the terms of this Order, does not admit the allegations
made in the Petition.
Q Plaintits request for a Final Protection Order is granted pursuant to the consent of
Plaintiff and Defendant.
? Plaintiffs request for a Final Protection Order is denied
® 1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other
protected person in any place where they might be found.
? 2. Defendant is completely evicted and excluded from the residence at _ or any other
residence where Plaintiff may live. Exclusive possession of the residence is granted to Plaintiff.
Defendant shall have no right or privilege to enter or be present on the premises.
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? On - at_. m., Defendant may enter the residence to retrieve his/her clothing and
other personal effects, provided that Defendant is in the company of a law
enforcement officer when such retrieval is made.
I' 3. Defendant is prohibited from having ANY CONTACT with Plaintiff at any
location, including, but not limited to, any contact at Plaintiffs residence, her place of
employment, and/or the school/day care facility of her minor child. Defendant is specifically
ordered to stay away from the following locations for the duration of this Order:
Plaintiff's residence: 11 Amherst Drive, Camp Hill, Cumberland County,
Pennsylvania
Plaintiff's place of employment: Aumiller's Auto Parts, Route 147, Halifax,
Dauphin County, Pennsylvania.
School/day care facility of minor child: Brookside Montessori School, 3708
Rosemont Avenue, Camp Hill, Cumberland County, Pennsylvania.
® 4. Defendant shall not contact the Plaintiff by telephone or by any other means,
including third parties.
® 5. Custody of the minor child, Madison Gwendolyn Christensen, shall be as
follows: See attached Temporary Custody Order.
? 6. Defendant shall immediately turn over to the Sheriffs Office, or to a local law
enforcement agency for delivery to the Sheriffs Office, the following weapons used or threatened
to be used by Defendant in an act of abuse against Plaintiff and/or the minor child:
? 7. Defendant is prohibited from possessing, transferring or acquiring any other weapons
for the duration of this Order. Any weapons delivered to the sheriff under Paragraph 6 of this Order
or under Paragraph 6 of the Temporary Order shall not be returned until further Order of Court.
ID S. The following additional relief is granted as authorized by §6108 of this Act:
1) This Order shall remain in effect until modified or terminated by
the Court and can be extended beyond its original expiration date if the
Court finds that Defendant has committed an act of abuse or has
engaged in a pattern or practice that indicates risk of harm to Plaintiff
and/or her minor child.
2) Defendant is enjoined from damaging or destroying any property
owned solely by Plaintiff.
3) Defendant is to refrain from harassing Plaintiffs relatives or her
minor child.
? 9. Defendant is directed to pay temporary support for -as follows:-. This Order for
support shall remain in effect until a final support order is entered by this Court. However, this
Order shall lapse automatically if Plaintiff does not file a complaint for support with the Court within
fifteen (15) days of the date of this Order. The amount of this temporary order does not necessarily
reflect Defendant's correct support obligation, which shall be determined in accordance with the
guidelines at the support hearing. Any adjustments in the final amount of support shall be credited,
retroactive to this date, to the appropriate party.
? 10. The costs of this action are waived as to Plaintiff and imposed on Defendant.
? 11. Defendant shall pay$_toPlaintiffascompensation forPlaintiffs out-of-pocket losses,
which are as follows: OR
? Plaintiff is granted leave to present a petition, with appropriate notice to Defendant, to
requesting recovery of out-of-pocket losses. The petition shall include an exhibit itemizing
all claimed out-of-pocket losses, copies of all bills and estimates of repair, and an Order scheduling
a hearing. No fee shall be required by the Prothonotary's office for the filing of this petition.
? 12. BRADY INDICATOR
? 1. The Plaintiff or protected person/s is a spouse, former spouse, a
person who cohabitates or has cohabited with Defendant, a parent of a common
child, a child of that person, or a child of Defendant.
? 2. This Order is being entered after a hearing of which Defendant
received actual notice and had an opportunity to be heard.
? 3. Paragraph 1 ofthis Order has been checked to restrain Defendant from
harassing, stalking, or threatening Plaintiff or protected persons.
? 4. Defendant represents a credible threat to the physical safety of
Plaintiff or other protected person/s OR
? The terms of this Order prohibit Defendant from using, attempting to use, or
threatening to use physical force against Plaintiff or protected person that would
reasonably be expected to cause bodily injury.
® 13.
® 14.
THE DATE THIS ORDER IS ENTERED.
VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE
CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE
OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S.
§6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL
PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS ORDER IS
ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL
LANDS, U.S. TERRITORIES, AND THE COMMONWEALTH OF PUERTO RICO UNDER
THE VIOLENCE AGAINST WOMEN ACTION, 18 U.S.C. §2265. IF YOU TRAVEL
OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY
BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C.
§§ 2261-2262. IF PARAGRAPH 12 OF THIS ORDER HAS BEEN CHECKED, YOU MAY
BE SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE "BRADY"
PROVISIONS OF THE GUN CONTROL ACTION, 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 Plaintiff's residence OR any location where a
violation of this Order occurs OR where Defendant 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. The
Cumberland County Sheriffs Department shall maintain possession of the weapons until
further Order of this Court. When Defendant is placed under arrest for violation of the
THIS ORDER SUPERCEDES ANY PRIOR PFA ORDER, and
ANY PRIOR ORDER RELATING TO CHILD CUSTODY.
ALL PROVISIONS OF THIS ORDER SHALL EXPIRE ONE YEAR FROM
Order, Defendant shall be taken to the appropriate authority or authorities before whom
Defendant is to be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be
completed and signed by the police officer OR Plaintiff, Plaintiff's presence and signature are
not required to file the complaint.
If sufficient grounds for violation of this Order are alleged, Defendant shall be
arraigned, bond set and both parties given notice of the date of the hearing.
This Order is entered pursuant to the consent of Plaintiff and Defendant:
Lynne Aumiller-Christensen, Plaintiff
Joan Carey
'
Philip C. Briganti
Attorneys for Plaintiff
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
David Allan Christensen, Defendant
Karl E. ominger, Attorney for Defendant
Law Office of Paul Bradford Orr
50 East High Street
Carlisle, PA 17013
(717) 258-8558
BY THE COURT,
LYNNE AUMILLER-CHRISTENSEN,
Plaintiff
for herself and on behalf of her minor child,
Madison Gwendolyn Christensen,
vs.
DAVID ALLAN CHRISTENSEN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3085 CIVIL TERM
PROTECTION FROM ABUSE
AND NOW, this (4_ day of heRo?1 V9, the following Order is entered by consent of the
parties with regard to custody of the parties' child, Madison Gwendolyn Christensen.
1. The Plaintiff, hereinafter referred to as the mother, shall have primary physical and
legal custody of the child.
2. The father shall have the right to supervised visitation with the child through the
supervised visitation program at the YWCA in Carlisle or another mutually agreed upon program.
3. The supervised visitation may begin three (3) months after the entry of the Final
Protection Order, and shall be at the initiation of the father and coordinated through the mother's,
custody attorney, Maria P. Cognetti, 200 North 3rd Street, Harrisburg, PA 17108 (717-232-2103).
4. This Order shall remain in effect pending further Order of Court.
This Order is entered pursuant to the consent
h
Lynne Aumiller-Christensen, Plaintiff
loan Carey // ...d,
Philip C. Briganti
Attorneys for Plaintiff
Legal Services, Inc.
Karl E. Rominger, Attorney for Defendant
Law Office of Paul Bradford Orr
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PRAECIPE FOR LISTING CASE FOR ARGUMENT
(Must be typewritten and submitted in duplicate)
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
Please list the within matter for the next Argument Court.
CAPTION OF CASE
(entire caption must be stated in full)
Nub c,4s T. Roacps
VS.
CoMMo(JCdEAtJM of I E WYCV-404
(Plaintiff)
(Defendant)
No- qg-323yCivil 19
1. State matter to be argued (i.e., plaintiff's motion for new trial, defendant's
demwrer to complaint, etc.):
1-AELIM10AILY 08j7V-GTl0rJS
2. Identity counsel who will argue case:
(a) for plaintiff: /YJ rGffigO J W /C Soa
Address: $?(s atRa? ,gVs,,N?
(b) for defendant: cAMP14(w- PA 1'7o/f-?4 7
Address: F/lF)NG(S le. FY'L.TJ?r
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3: i will notify all parties in writing within two days that this case has
bees listed for argument.
4. Argument Court Date: Z')Cfbj3cZ 13 1
171 Lo
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Dated: Attorney far p(atumf?
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CONNECTION TEL
CONNECTION ID
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RESULT
1331.
92490779
07/09 14:40
04'05
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