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OFFICE OF THE DISTRICT ATTORNEY
OF CUMBERLAND COUNTY ,
ONE COURTHOUSE SQUARE JUN 1 g 1999
CARLISLE, PENNSYLVANIA 17019
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LESLIE ANN CORRIGAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V.
99-3324 CIVIL
DANIEL L. CORRIGAN
Defendant CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this day of June, 1999, this court certifies that the
attached complaint has been properly completed and verified, and there is probable cause
for the issuance of process. In consideration of the attached Commonwealth's Petition,
the defendant, DANIEL L. CORRIGAN, is directed to appear for trial on the charge of
Indirect Criminal Contempt before the Court on the ?f/ Aday of 1999 at
'
rh) o'clock P.m. in Courtroom # 3 of the Cumberland County ourthouse, 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,
ti /I /
(oq) Geor? E. Hoffer P J.
Jonathan R. Birbeck,
Chief Deputy District Attorney
DANIEL L. CORRIGAN
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LESLIE ANN CORRIGAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
DANIEL L. CORRIGAN, 99'3324 CIVIL
Defendant : CHARGE: INDIRECT CRIMINAL CONTEMPT
_CQMMONWEALTH'S PETITION FOR A HEARING ON CHARGES
OF INDIRECT CRIMINAL CONTEMPT
Jonathan R. Birbeck, Chief Deputy District Attorney of Cumberland County,
Pennsylvania, brings the following Petition for a hearing on charges of Indirect Criminal
Contempt:
1. A Protection from Abuse Order was issued by the Court. A true and correct
copy of the Order is attached.
2. The defendant's violation of this Order is averred in the attached criminal
complaint.
3. The victim requests the filing of an Indirect Criminal Contempt Charge.
4. The District Attorney's Office approves the filing of this criminal complaint.
5. The Commonwealth is requesting a hearing on the charges of Indirect
Criminal Contempt pursuant to 23 Pa.C.S.A. § 6113.
6. The plaintiff and/or the defendant may seek modification of the Order based
on the filing of this petition as the Court deems appropriate following the trial
in addition to any other sentence. 23 Pa.C.S.A. § 6113.
WHEREFORE, the Commonwealth requests the defendant be commanded to
appear before the Court on the charge of Indirect Criminal Contempt.
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: Cumberland
ietetyal Dintrict wtheri 09-1_01
Dlatrict ,I„etice Ni ..Hm. Charles A. Clermnt Jr.
1106 Carlisle Rd.
Cane Hill, PA 17011
(717) 761-4940
ocket No.:
ate Filed;
TN:
ferdant'n Recd/Ethnicity
m Nu[e ? A An
? MioPenic ? Nati" Aselim
fadant'n A.K.A.
laint/jrcicjmt "Mb"
1999-06-133
DEFENDANT: VS.
NAME end ADDRESS
r DANIEL LMaW OORRIGAN 1
2408 BROOKWX= ST,
HARRISBURG, PA. 17104
L
? elsdc 1] Paialeaex tmdmt'o D.O.E. Eaxhnt'e social senuYty Na
? nee m Male 04/23/1970 578-90-5265
fmdmt'n Vehiclo InEoxaatim: _
PL[e Nxber state Reginttatim stidter(Mt/yy) Efate
leant/La:idmt N M 'if xher
sm
-i
District Attorney's Office Approved [] Disapproved because:
fnn diotrict att,,W nay teytila that the filing Pa-R.Cr..P. 107.) 03`Pl nt, enact amxmt affidavit, ar both be wed bi' the attonial. far the
DmrazA lth prior to
(lime of Attoary tar CtaaanaalU,
Plasee Print ar
7-RACY P. Kgr 1l'P7 (9 gna[t¢e of AGtov:ey for U,mpnyl t-hr?
(Oats
of
•rr°,
-•--ter wp'xma t or Agway RnPx nt<d sd P
do hereby state:(check the appropriate box)
Agee y aD
1. ® I accuse the above named defendant, who lives at the address set forth above
? 1 accuse an defendant whose name is unknown to me but who is described as
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 NEW CSNIBERIADD
S . NEW CiMBERIANfj BORO 412 3RD
in -aMERiANfI lPlxa•POlitlosl Subdivioiml
County on or about. 4-QuNE-99
------------
Participants were: (if there were participants, place their names here, repeating the name of the above defendant)
IIANIEL LANKMN QDRRI .AN
2. The acts committed by the accused were:
(set Eoath a aamatg, of the facto M fficiMt to advise the dafadent of the M to of tM offs
WiU° ooto. in rot oufEici mt. In a aaofy case, VW suet cite the o,xcifie oectitn he cam' A cit tim to the otatu all-j dly dolated
INDIRECT (`R?MqAL T, INIHAT THE D e" ttim of the o wte ar ot""rv allegedly violated.)
P80II'JCITON OF ABUSE ORDER DID VIOLATE THIS ORDER = CN nlE
LEAVIM A MESSAGE ON LESLIE CDRRIGAN ANSWERIIQ; MAa . THIS qUUMJXM AND
IN DIRECT VIOLATION
OF NOT 00"IAC'P IN PARAGRAPH 4 IN THE P.F.A. STATIM THAT IS IN
PR
OMmiTID FROM HAVING ANY aw,7C= BY 1ELEp1 AND THE IS DOXMVT IP HE DID DID HAVE ANr IS
AT TM WIMMZr SMRF
NEW CLMMXZ is WITH HER
DID PEAK WiiHRilIH THE PLAINTIFF ' ON OR ACTT 07-,TUNE-99 AT 2145. HE
PARAGRApH 3. OF THE P. F.A. IN VIOLATION OF SEC,23. 561IS IN 13. DST VIOLATIOAT OF
AMC 411-(1/%) Intannt Vmaiml
1.3
(Continuation of 2.)
Defendant Name: DMEL+ LAMIM O RMChAN
Docket Number:
POLICE
CRIMINAL- COMPLAINT I
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 23 -
(PA 9te[uts) (counts)
(Section) (SUb•ee<tlon)
of the ??? (]
'. r• -?'??? (PA statute) (counts)
(section) (sub-Section)
0
of the ,
(counts)
1• (PA Statute) e)
(section) (Sub-Section)
' of the 0
?• (PA Statute) (tounte)
(Section) (Sub-Section)
3. I ask that a warrant of arrest or a summons be issued and that the defendant be req i e dd toa m rthe chargescompleted
i have made. (In order for a warrant of arrest to issue, the attached atGda
and sworn to before tho issuing authority.
4. I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information
and belief. This verification is made subject to the penalties of Section 4904 of the Crimes Code(18 PA. C.S.
6 4904) relating to unworn falsification to authorities.
'19 `/ y
/gneture o AEttant)
19 I certify the complaint has been properly
AND NOW, on this date
completed and verified. An 1 avlt o pro a e cause mus-Tcomple-tea in order for a warrant to issue.
SEAT.
(leeuing Aathorlty
IMeglsurt• Dletrlct 2.3
ADPC 413•(4/e41(lnternet Verelon) -
J
POLICE
ame: DANIEL IANKION CORRIGAN CRIMINAL COMPLAINT
EFDocket :Number:
AFFIDAVIT of PROBABLE CAUSE
ON 04-JUNE-99 AT 1628 HOURS DANIEL CORRIGAN CALLED LESLIE CORRIGAN'S API'. ABED
LEFT A MESSAGE ON HER TELEPHONE ANS OMr- MAaHM• THE MESSAGE WAS WRITTEN DoM WORD
FOR WORD AND IS THE FOILOWRIG•
"HI, I JUST GOT YOUR REALY NICE INFORMATION FROM THIS BULLSHIT 'THING YOU FILED
WITH THE COURT SYSTEM." "YOU KNOW YOU SHOULD HAVE READ TT BEFORE YOU DID SING I CAN
NOT COME TO THE HOUSEOR SEEE THE KIDS SINCE YOU HAVE OJSIUDY OVER THEM." "ALL KIIMS
OF SHIT LESSIE, YOU KNOW , I SUGGEST YOU DROP THIS OR WE'LL BE IN COURT ON THE 91H THIS LESLIE,
P
OF JUNE." "I'LL HAVE MY ATTORNEY THERE." "I'M NOT GOIIx !O PITT M WrIH ??? IT ?T
T HIS IS RIDICULOUS AND YOU CAN RECORD THIS MESSAGE I KNOW BECAUSE
YOUR ANSWF2IN" TRIM." "THIS IS RIDICULOUS, LESLIE."
ON 07-JUNE-99 AT 2145 LESLIE SAID THAT SHE WAS AT NICK'S 114 CAFE' AND HAD JUST
WALKED OUT OF THE BUILDING WHEN SHE SAW DANIEL CO ? DRDRIVE EA WHICH .
LESLIE WALKED ACROSS THE BRIDGE ST TO THE UNII?T IS IN PLAIN VIETHE PAY W OF PHONE WHI •
IO THE FRONT OF THE BUILDING OUTSIDE. am pinZ THE PARKING UST OF NICK'S AGAIN AND WE
LESLIE SAW THAT E
DANILE BUILDING. LESLIE AROUND CALL AND WAS SPEAKING ON THE
WENT TO THE REAR OF THE I3iTl. LESLIE MADE HER PHONE ID THE GAS j
PM E WHEN DANIEL DROVE CN TO THE PARKING LOr OF THE UN? E WAS SL9aNDII9G. DANIEL
PUMPS WHICH ARE ABOUT 15 FEET FROM THE PAY PHONE WHERE
GUT OUT OF THE CAR AND PIMPED GAS. AFTER HE WAS DONE HE APPROACHED LESLIE AND ASKED
HER IF SHE WAS ON A DATE. HE THIN TOLD HER THAT HE STILL LAVER HER AND HE MENTIONED
HTE PFA AND WANTED TO KNOW IF SHE WAS STILL GOING TO GO u ROUGH WITH THE PFA HEARINGS II
ECT• BOTH 3 AND 4.
H ? WITH LESLIE ARE A VIOLATION OF THE PFA PARAGRAPHES
PFA NUMBER 99-3324CIVIL SIGNED BY JUDGE HOFFER AND SERVED ON THE DEFaMANT PRIOR
To HIS cwmcr WITH no PLAnmFF.
2A FF KII43 _ J BEING DULY SWORN ACCORDING TO
LAW, DEPOSE AND SAY THAT THE FACTS SET FORTH IN TAE FOREGOING AFFIDAVIT ARE
TRUE AND CORRECT TO THIN BEST OF MY KNOWLEDGE, INFORMATION AND BELIEF.
mpg etuia f Af ESenCI
19_
Sworn to me and subscribed before me this dflY of
District Justice
_ Date
SEAL
My commission expires first Monday of January,
3-3
A(11'C e1S-U/96111nurnet V-101-11)
LESLIE ANN CORRIGAN,
Plaintiff
vs.
DANIEL LANCKTON CORRIGAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- ..?3V CIVIL TERM
PROTECTION FROM ABUSE AND CUSTODY
YOU HAVE BEEN SUED IN COURT. Ifyou 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 maybe entered against you granting the relief requested in the Petition. In particular, you maybe
evicted from your residence and lose other important rights.
A HEARING ON THIS MATTER IS SCHEDULED ON THE L DAY OF JUNE, 1999, AT
IN COURTROOM NO. 3 OF THE CUMBERLAND COUNTY COURTHOUSE,
CARLISLE, PENNSYLVANIA.
You MUST obey the Order that is attached until it is modified or terminated by the court atler 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 before the court, please contact our office. All arrangements must be made
at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or
hearing
LESLIE ANN CORRIGAN,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DANIEL LANCKTON CORRIGAN, : NO. 99- _ CIVIL TERM
Defendant : PROTECTION FROM ABUSE AND CUSTODY
TEMPORARY PROTECTION
ER-OM ABUSE ORDER
Defendant's Name: DANIEL LANCKTON CORRIGAN
Defendant's Date of Birth: 04/23/70
Defendant's Social Security Number: 578-90-5265
Name of Protected er n: LESLIE ANN CORRIGAN
AND NOW, this day of June, 1999, upon consideration of the attached Petition for
Protection from Abuse, the court hereby enters the following Temporary Order:
L Defendant shall not abuse, harass, stalkorthreaten anyoftheabove persons
in any place where they might be found.
U 2. Defendant is evicted and excluded from the residence at 412 3n0 Street, New II
Cumberland, Cumberland County, Pennsylvania, or any other permanent or temporary
residence where Plaintiff may live. Plaintiff is granted exclusive possession of the residence. 1
Defendant shall have no right or privilege to enter or be present on the premises.
3.
Except for such contact with the minor children as may be permitted under
Paragraph 5 of this Order, Defendant is prohibited from having ANY CONTACT with
Plaintiff at any location, including, but not limited, to any contact at Plaintilrs place of
employment and/or the day care facility of the minor children. Defendant is specifically
ordered to stay away from the following locations for the duration of this Order:
'nt ike place ofemnlovment:
Turnpike Club Key West at the holiday Inn, Pennsylvania
Turnpike at Interstatt 83, New Cumberland, York County, Pennsylvania. i
R.
DR
.mare facility Qf minor children: Wherever that may be.
?.
M/ 4. Except for such contact with the minor children as maybe permitted under
Paragraph 5 of this Order, Defendant shall not contact Plaintiff by telephone or by any other
means, including through third persons, other than for the limited purpose of facilitating
custody arrangements.
® 5. Pending the outcome of the final hearing in this matter. Plaintiff is awarded
temporary custody of the following minor children:
Daniel Lewis Corrigan, Anna Elizabeth Corrigan, and Madeline Marie Corrigan.
Until the final hearing, all contact between Defendant and the children shall be
limited to the following: at times mutually agreed upon by the parties.
The local law enforcement agency in the jurisdiction where the children are
located shall ensure that the children are placed in the care and 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 Sheriff's Department shall attempt to make service at
Plaintiff's 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.
Defendant is enjoined from damaging or destroying any property owned jointly
by the parties or owned solely by Plaintiff.
Defendant is to refrain from harassing Plaintiff's relatives or the minor
children.
8. A certified copy of this Order shall be provided to the police department
where Plaintiff resides and any other agency specified hereafter: New Cumberland Police
Department.
® 9. THIS ORDER SUPERSEDES ANY PRIOR PFA ORDER AND 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 the plaintiffs residence
OR any locations where a violation of this order occurs OR where the defendant may be located.
If defendant violates Paragraphs 1 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 enforcement officer shall seize all weapons used or threatened
to be used during the violation of this Order OR during prior incidents of abuse. Weapons must
forthwith be delivered to the 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 weapons are
evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer
made the arrest.
Ige
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
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LESLIE ANN CORRIGAN,
Plaintiff
vs.
DANIEL LANCKTON CORRIGAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3324 CIVIL TERM
PROTECTION FROM ABUSE AND CUSTODY
Defendant's Name: DANIEL LANCKTON CORRIGAN
Defendant's Date of Birth: 04/23/70
Defendant's Social Security Number: 578-90-5265
Names of Protected Person: O\LIE ANN CORRIGAN
AND NOW, this (0 day of June, 1999, the court having jurisdiction
over the parties and the subject-matter, it is ORDERED, ADJUDGED, and
DECREED as follows:
Plaintiff, Leslie Ann Corrigan, is represented by Joan Carey of Legal Services, Inc.;
Defendant, Daniel Lanckton Corrigan, is represented by Jacqueline M. Verney, Attorney at Law.
Defendant, although agreeing to the terms of this Order, does not admit the allegations
made in the Petition.
ID Plaintiffs 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 Plaintiff or any other
protected person in any place where they might be found.
0 2. Defendant is completely evicted and excluded front the residence at 412 3'
Street, New Cumberland, Cumberland County, Pennsylvania, 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.
® Defendant shall contact his counselor counsel for Plaintiff to arrange a date and
time mutually agreeable with Plaintiff to transfer his property. Defendant shall
designate no more than two third parties to retrieve his clothing, personal effects, and
other property items from Plaintiffs residence. Defendant shall not enteror be present
on the premises, but shall remain on the street in front of Plaintiffs residence during
the transfer. See attached Exhibit A.
® 3. Except as provided in Paragraph 5 of this Order, Defendant is prohibited from
having ANY CONTACT with the Plaintiff at any location, including, but not limited to, any
contact at the Plaintiffs place of employment and/or the day care facility of the minor
children. Defendant is specifically ordered to stay away from the following locations for the
duration of this Order:
Plaintiffs place of employment: Club Key West at the Holiday Inn,
Pennsylvania Turnpike at Interstate 83, New Cumberland, York County,
Pennsylvania.
Day care facility of minor children: Wherever that may be.
4. Except as provided in Paragraph 5 of this Order, Defendant shall not contact
the Plaintiff by telephone or by any other means, including third parties, other than for the
limited purpose of facilitating custody arrangements.
Q 5. Custody of the minor children, Daniel Lewis Corrigan, Anna Elizabeth
Corrigan, and Madeline Marie Corrigan, shall be as follows:
Plaintiff shall have primary physical custody of the children and the parties
shall share legal custody. Defendant shall have periods of partial custody with
the children at times mutually agreed upon by the parties pending further
Order of Court after a conciliation conference. (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 children: _
? 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.
8. The following additional relief is granted as authorized by §6108 of this Act:
i 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
i Defendant has committed an act of abuse or has engaged in a pattern or
practice that indicates risk of harm to Plaintiff.
Defendant is enjoined from damaging or destroying any property owned jointly
by the parties or owned solely by Plaintiff.
S
Defendant is to refrain from harassing Plaintiff's relatives or the minor
children.
Defendant shall remain in his vehicle at all times during transfer of custody.
® 9. Defendant is directed to pay temporary support for the parties' minorchildren,
Daniel Lewis Corrigan, Anna Elizabeth Corrigan, and Madeline Marie Corrigan, as follows:
On June 9,1999, Defendant shall pay $145.00 in the form of a check or money
order made payable to Plaintiff and transferred to her through respective counsel for
the parties,
Commencing June 23, 1999, Defendant shall make bi-weekly payments of
$290.00 ($145.00 per week) in the form of a check or money order made payable to
Plaintiff mailed to her mailing address. 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 $55.00 to Plaintiff as compensation for Plaintiffs out-of-
pocket losses, which are as follows: $20.00 re-imbursement for medical insurance co-pay
charges for two prescriptions, and $35.00 re-imbursement for the cost to replace personal
items damaged/destroyed. Defendant shall reimburse Plaintiff $55.00 on June 9,1999, in the
form of a check or money order made payable to Plaintiff and transferred to her through
respective counsel for the parties.
? 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 ofwhich Defendant received actual
notice and had an opportunity to be heard.
? 3. Paragraph 1 of this Order has been checked to restrain Defendant from
harassing, stalking, or threatening Plaintiff or protected person/s.
? 4. Defendant represents a credible threat to the physical safety of Plaintiff or
other protected persons 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. THIS ORDER SUPERCEDES:
® ANY PRIOR PFA ORDER and
ANY PRIOR ORDER RELATING TO CHILD CUSTODY.
I 14. All provisions of this Order shall expire one year from the date this Order is
entered.
NOTICE TO THE DEFENDANT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE
OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF UP TO
$1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S. §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.
The police who have jurisdiction over Plaintits 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 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 ofabuse. The Cumberland
County Sheriff's Department shall maintain possession of the weapons until further Order of this f
Court. When Defendant is placed under arrest for violation of the 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, Plaintiffs 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 )fe idant: {
Leslie Ann Corrigan, Plaintiff Daniel Lanckton Cortigan, I3ef dant
ti
Atto 5 me i
oan
Carey, or Plaintiff
cqu ine M. Verney, Attorn ey for'
fendant
LEGAL SERVIC S, INC
. 44 South Hanover Street
8 Irvine Row Carlisle, PA 17013
Carlisle, PA 17013 (717) 243-9190
(717) 243-9400
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LESLIE ANN CORRIGAN,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DANIEL LANCKTON CORRIGAN, ; NO. 99-3324 CIVIL TERM
Defendant : PROTECTION FROM ABUSE AND CUSTODY
PROPERTY TRAPVSFER
The following clothing, personal effects, and items of property shall be transferred to
Defendant from Plaintiffs residence on a date and time mutually agreed upon by the parties through
counsel or by Defendant contacting Plalntifrs counsel directly to make arrangements. Defendant
shall designate no more than two third parties to retrieve the listed items from Plaintiffs residence.
Defendant shall not enter or be present on the premises, but shall remain on the street in front of
Plaintiff's residence during the transfer.
Defendant's clothing
Defendant's personal effects, including all personal papers
1 dresser
1 19" portable television
Half of all comp disks owned by the parties
All Defendant's stereo component equipment (Plaintiff shall retain the portable
stereo system)
In addition, at the time of transfer, Defendant shall return to PUntiff the following:
I Suburban Cable pager
1 Motorola pager tv J
r f
EXHIBIT A
f'
i
LESLIE ANN CORRIGAN,
Plaintiff
vs.
DANIEL LANCKTON CORRIGAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3324 CIVIL TERM
PROTECTION FROM ABUSE AND CUSTODY
OUT-OF-POCKET LOSSES
Plaintiffrequests that the defendant reimburse her out-of-pocket losses, including but not limited
to the following:
Any and all expenses/costs incurred to repair and/or replace clothing/property damaged and/or
destroyed on or about May 18, 1999.
Medical insurance co-pay amount for Plaintiffs medication
destroyed by Defendant 20.00
Plaintiff's personal effects destroyed by Defendant 35.00
TOTAL LOSSES $55.00
EXHIBIT B
i_
LESLIE ANN CORRIGAN,
Plaintiff
vs.
DANIEL LANCKTON CORRIGAN,
Defendant
I
i;
AND NOW, this _e% day of June, 1999, the following Order is entered by consent of the :: ; •: •: •:::,:
parties with regard to custody of the parties' children, Daniel Lewis Corrigan, Anna Elizabeth
Corrigan, and Madeline Marie Corrigan:
Plaintiff, hereinafter referred to as the mother, and Defendant, hereinafter referred to
as the father, shall share legal custody of the children.
2. The mother shall have primary physical custody of the children.
3. The father shall have partial custody of the children a minimum of two days per week
at times mutually agreed upon by the parties.
4. The mother and father, by mutual agreement, may vary from this schedule at any time,
but the Order shall remain in effect until further Order of Court after a conciliation conference.
5. There shall be reasonable notice given to the other party if a scheduled period of
partial custody needs to be canceled or modified and a make-up period shall be offered within a
reasonable time frame.
6. The mother and father agree that each shall notify the other immediately of medical
emergencies which arise while the children are in that parent's care.
7. Neither party shall do anything which may estrange the children from the other parent,
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3324 CIVIL TERM
PROTECTION FROM ABUSE AND CUSTODY
or injure the opinion of the children as to the other parent or which may hamper the free and natural
I
development of the children's love or respect for the other parent.
•i•
This Order is entered pursuant to the consent of Plaintiff and Defendant:
Leslie Ann Corrigan, Plaintiff C, Daniel Lanc bn Corrigan, Defend t
oAttor y for Plaintiff d c9 ine M. Verney, Attorney for 'fendant
Carey, LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
I
By the Court,
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LESLIE ANN CORRIGAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 99-.2,?aV CIVIL TERM
DANIEL LANCKTON CORRIGAN,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following
papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and
a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be
evicted from your residence and lose other important rights.
A HEARING ON THIS MATTER IS SCHEDULED ON THE DAY OF JUNE, 1999, AT
//-%z) M., IN COURTROOM NO.3 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 before the court, please contact our office, All arrangements must be made
at least 72 hours prior to any heating or business before the court. You must attend the scheduled conference or
hearing.
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FILE D-u FlCF
OF TL"=' u!' TH'CtJOTARY
99 JUN -•2 PH 2: 10
CUiJE;:HLtJ'!Q CCUNTY
PFNNSYLV,%!A
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---------------
LESLIE ANN CORRIGAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: N0.99- CIVIL TERM
DANIEL LANCKTON CORRIGAN,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
TEMPORARY PROTECTION
FROM ABUSE ORDER
Defendant's Name: DANIEL LANCKTON CORRIGAN
Defendant's Date of Birth: 04123/70
Defendant's Social Security Number: 578-90-5265
Name of Protected aern.: LESLIE ANN CORRIGAN
AND NOW, this day of June, 1999, upon consideration of the attached Petition for
Protection from Abuse, the court hereby enters the following Temporary Order:
® I. Defendantshall not abuse, harass, stalkorthreatenanyoftheabovepersons
in any place where they might be found.
I 2. Defendant is evicted and excluded from the residence at 412 3r° Street, New
Cumberland, Cumberland County, Pennsylvania, 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. Except for such contact with the minor children as may be permitted under
Paragraph 5 of this Order, Defendant is prohibited from having ANY CONTACT with
Plaintiff at any location, including, but not limited, to any contact at Plaintiffs place of
employment and/or the day care facility of the minor children. Defendant is specifically
ordered to stay away from the following locations for the duration of this Order.
Plaintiffs place ofemployment: Club Key West at the Holiday Inn, Pennsylvania
Turnpike at Interstate 83, New Cumberland, York County, Pennsylvania.
Day care facility of minor children: Wherever that may be.
LInt/ 4. Except for such contact with the minor children as maybe permitted under
Paragraph 5 of this Order, Defendant shall not contact Plaintiff by telephone or by any other
means, including through third persons, other than for the limited purpose of facilitating
custody arrangements.
ID 5. Pending the outcome of the final hearing in this matter. Plaintiff is awarded
temporary custody of the following minor children:
Daniel Lewis Corrigan, Anna Elizabeth Corrigan, and Madeline Marie Corrigan.
Until the final hearing, all contact between Defendant and the children shall be
limited to the following: at times mutually agreed upon by the parties.
The local law enforcement agency in the jurisdiction where the children are
located shall ensure that the children are placed in the care and 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 Sheriff s 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 Sheriff's Department shall attempt to make service at
Plaintiff's 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.
Defendant is enjoined from damaging or destroying any property owned jointly
by the parties or owned solely by Plaintiff.
Defendant is to refrain from harassing Plaintiff's relatives or the minor
children.
MON
In/ 8. A certified copy of this Order shall be provided to the police department
where Plaintiff resides and any other agency specified hereafter: New Cumberland Police
Department.
ID 9. THIS ORDER SUPERSEDES ANY PRIOR PFA ORDER AND 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) ofthe Pennsylvania Consolidated Statutes.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the police who have jurisdiction over the plaintiff's residence
OR any locations where a violation of this order occurs OR where the 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 enforcement officer shall seize all weapons used or threatened
to be used during the violation of this Order OR during prior incidents of abuse. Weapons must
forthwith be delivered to the 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.
ige
loan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
LESLIE ANN CORRIGAN,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
vs.
NO. 99- -3 J y CIVIL TERM
DANIEL LANCKTON CORRIGAN,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
PETITION FOR
PROTECTION FROM ABUSE
COUNTI
1. The Plaintiff is Leslie Ann Corrigan.
2. The name of the person who seeks protection from abuse is Leslie Ann Corrigan.
3. Plaintiffs address is 412 3' Street, New Cumberland, Cumberland County, Pennsylvania
17070.
4. Defendant's current address is unknown to Plaintiff.
Defendant's Social Security Number is 578-90-5265.
Defendant's date of birth is 04/23/70.
Defendant's place of employment is Domino's Pizza, 501 South 29d' Street, Harrisburg,
Dauphin County, Pennsylvania.
5. Defendant is Plaintiffs husband.
6. Plaintiff seeks temporary custody of the following children
Name Address Birthdate
Daniel Lewis Corrigan 412 3rd Street 12/21/90
New Cumberland, PA
Anna Elizabeth Corrigan 412 3rd St 04/16/95
New Cumberland, PA
Madeline Marie Corrigan 412 Yd St 12/22/97
New Cumberland, PA
Plaintiff and Defendant are the parents of the following minor children:
Name Age
Daniel Lewis Corrigan 9 years old
Anna Elizabeth Corrigan 4 years old
Madeline Marie Corrigan 17 months old
8. The following information is provided in support of Plaintiffs request for an Order
of child custody:
a) The children were not born out of wedlock
b) The children are presently in the custody of Plaintiff Leslie Ann Corrigan,
who resides at 412 Yd Street, New Cumberland, Cumberland County, Pennsylvania.
C) During the past five years the children have resided with the following
persons and at the following addresses:
Persons children lived with Address When
Plaintiff 412 3b Street From 05/18/99
New Cumberland, PA to the present
Plaintiff and Defendant 412 and Street From 03/99
New Cumberland, PA to 05/18/99
Defendant and Plaintiffs 8808 Trafalgar Square From 10/98
father, Gerald Gelwicks Springfield, VA to 03/99
Plaintiff, Defendant and Post Corners Trail From 1996
Plaintiffs father Centerville, VA to 1998
Plaintiff, Defendant and 4514 Banff Street From 1994
Plaintiffs father Annandale, VA to 1996
d) Plaintiff, the mother of the children, is Leslie Ann Corrigan, currently residing
at 412 3"' Street, New Cumberland, Cumberland County, Pennsylvania.
C) She is married.
f) Plaintiff currently resides with the following persons:
Name Relationship
Daniel Lewis Corrigan her son
Anna Elizabeth Corrigan her daughter
Madeline Marie Corrigan her daughter
g) Defendant, the father of the children, is Daniel Lanckton Corrigan, whose
current residence is unknown to Plaintiff
h) He is married.
i) Plaintiff is unaware of Defendant's current living arrangements.
j) Plaintiff has not previously participated in any litigation concerning custody
of the above mentioned children in this or any other Court.
k) Plaintiff has no knowledge of any custody proceedings concerning these
children pending before a court in this or any other jurisdiction.
1) Plaintiff does not know any person not a party to this action who has physical
custody of the children or claims to have custody or visitation rights with respect to
the children.
m) The best interests and permanent welfare of the minor children will be met
if custody is temporarily granted to Plaintiff pending a hearing in this matter for
reasons including:
1) Plaintiff is a responsible parent who has provided for the emotional
and physical needs of the children since their births, and who can best take
care of the minor children.
2) Defendant has shown by his abuse of Plaintiff that he is not an
appropriate role model for the minor children.
3) Defendant's behavior has adversely affected the children.
9. The facts of the most recent incident of abuse are as follows:
Approximate Date: On or about May 18, 1999
Place: 412 3rd Street, New Cumberland, Cumberland County,
Pennsylvania, Plaintiff's residence
On or about May 18, 1999, Defendant argued with Plaintiff after she refused
to give him her car keys, dumped the contents of her purse out looking for the keys,
and stomped on the contents damaging and destroying her personal articles.
Defendant became angry when he could not find the keys, pulled back his fist causing
Plaintiff to fear that he was going to punch her, shoved her, and threatened to kill
her. Defendant went upstairs and yelled down threatening Plaintiff further saying,
"I'm gonna kill you, I promise. It might not be now, but it'll be in five or ten years"
Fearing for her safety, PWntiff telephoned the police for help. The New Cumberland
advised Defendant to leave the residence. Defendant has been living at an
unknown location since leaving the residence.
10. Defendant has committed the following prior acts of abuse against Plaintiff:
a) . In or about December 1998, Defendant argued with Plaintiff screaming
and yelling at her. Fearing for her safety, Plaintiff locked herself in the
bedroom. Defendant forced the door open damaging it, shoved Plaintiff out the
bedroom door, slammed the door, and repeatedly punched her about her arm
with his fists. Plaintiff ran and hid from Defendant. Plaintiff sustained bruising
and soreness about her arm as a result of this incident.
b) In or about October 1998, after Plaintiff had moved from Virginia to
New Cumberland, Pennsylvania, to get away from Defendant, he followed her,
broke into her apartment while she was away, and removed important personal
documents belonging to her.
c) In or about September 1998, Defendant admitted to Plaintiff that he had
installed a listening device on their telephone line and monitored her telephone
conversations while she was still living in the marital home.
d) In or about summer 1998, after Plaintiff moved out of the marital home
and was temporarily staying in a hotel, Defendant hired a private detective who
followed her, pounded on her hotel room door repeatedly, broke the hotel door
to gain entrance to her room, and shoved her to the floor causing her to fear for
her safety.
11. 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: New Cumberland Police
Department.
12. There is an immediate and present danger of filrther abuse ;om Defendant.
13. Plaintiff is asking the Court to evict and exclude Defendant from the residence at 412
Yd Street, New Cumberland, Cumberland County, Pennsylvania, which is rented by Plaintiff
14. Defendant owes a duty of support to Plaintiff and the parties' minor children.
15. Plaintiff has suffered the following out-of-pocket financial losses as a result of the abuse
described above: see attached Exhibit A. 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 minor child in any place where Plaintiff may be found.
B. Evict and exclude Defendant from Plaintiffs residence and prohibit Defendant
from attempting to enter any temporary or permanent residence of the Plaintiff.
C. Require Defendant to provide Plaintiff and/or minor children with other suitable
housing.
D. Award Plaintiff temporary custody of the minor children and place the following
restrictions or contact between Defendant and children: Defendant may have partial
custody according to a schedule mutually agreed upon by the parties pending further
Order after hearing scheduled in this matter.
E. 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 and/or the school or day care facility
of the minor children, except for the limited purpose of facility custody arrangements.
F. Prohibit Defendant from having any contact with Plaintiffs relatives listed in this
Petition, except as the court may find necessary with respect to partial custody with the
minor children.
G. Order Defendant to pay temporary support for Plaintiff and/or the minor
children, including medical support and payment of the rent on the residence.
H. Direct Defendant to pay Plaintiff for the reasonable financial losses suffered as
a, result of the abuse, to be determined at the hearing.
Order Defendant to pay the costs of this action, including filing and service fees.
J. 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.
K. Order the following additional relief, not listed above:
Defendant is enjoined from damaging or destroying any property owned jointly
by the parties or owned solely by Plaintiff
Defendant is to refrain from harassing Plaintiff's relatives or the minor children.
L. Grant such other relief as the court deems appropriate.
M. 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.
COUNT II
CUSTODY UNDER PENNSYLVANIA CUSTODY LAW
16. The allegations of Count I above are incorporated herein as if fully set forth.
17. The best interest and permanent welfare of the minor children will be served by
confirming custody in Plaintiff as set forth in paragraph 8 of the petition.
WHEREFORE, pursuant to 23 Pa.C.S.§ 5301 et. ft., and other applicable rules and law,
Plaintiff prays this Honorable Court to award custody of the minor children to her.
Plaintiff prays for such other relief as may be just and proper.
Respectfully submitted,
Date: -?
+;=arey, Attorney f' Piainu
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
VERIFICATION
I verify that 1 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: J??o7 9o -
Leslie Ann Corrigan, Plaintiff
LESLIE ANN CORRIGAN,
Plaintiff
vs.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
DANIEL LANCKTON CORRIGAN, : N0.99- CIVIL TERM
Defendant : PROTECTION FROM ABUSE AND CUSTODY
QUT-®F-POCKET' LOSSES
Plaintiff requests that the defendant reimburse her out-of-pocket losses, including but not
limited to the following:
Any and all expenses/costs incurred to repair and/or replace clothing/property damaged
and/or destroyed, including, but not limited to lost wages as a result of the incidents which occurred
on or about May 18, 1999.
Lost wages
Medical insurance co-pay amount for Plaintiff's medication
destroyed by Defendant
Plaintiffs work clothing disposed of by Defendant
Plaintiff's personal effects destroyed by Defendant
TOTAL LOSSES
EXHIBIT A
$100.00
20.00
25.00
60.00
$205.00
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LESLIE ANN CORRIGAN, : IN THE COURT OF COMMON PLEAS OF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. CIVIL ACTION -LAW
DANIEL LANCKTON CORRIGAN, NO. 99-3324
Defendant
: PROTECTION FROM ABUSE AND
: CUSTODY
ORDER OF COURT
AND NOW, this / day of cTLJJK. , 1999, upon
consideration of the attached Temporary Custody Order, it is hereby directed that the
parties and their re eetiv counsel shall appear before . 1 ? 120
the Conciliator, at l +vi Bono, 1:11 I`Ift n A t r4-M"the
tt,
day ofd 1999 at D :,30 o'clock,ti,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 a Temporary Order. All children age five or older may also be
present at the Conference. Failure to appear at the Conference may provide grounds for
entry of a temporary or permanent order.
FOR THE COURT,
BY: Custody ? .
Conciliator
The Court of Common Pleas of Cumberland County is required by law to comply with
the Americans with Disabilities Act of 1990. For information about accessible facilities
and reasonable accommodations available to disabled individuals having business before
the court, please contact our office. All arrangements must be made at least 72 hours
prior to any hearing or business before the court. You must attend the scheduled
conference or hearing.
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
(717) 249-3166
II _
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G•aa• 99 ? ???1? ? ???
Gas • 99 ?? .??! .-?„ ?!. ??? _
LESLIE ANN CORRIGAN,
Plaintiff
VS.
DANIEL LANCKTON CORRIGkN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-3324 CIVIL TERM
PROTECTION FROM ABUSE AND CUSTODY
TEMPORARY CUSTODY O"ER
AND NOW, this 4_6ay of June, 1999, the following Order is entered by consent of the
parties with regard to custody of the parties' children, Daniel Lewis Corrigan, Anna Elizabeth
Corrigan, and Madeline Marie Corrigan:
Plaintiff, hereinafter referred to as the mother, and Defendant, hereinafter referred to
as the father, shall share legal custody of the children.
2. The mother shall have primary physical custody of the children.
3. The father shall have partial custody of the children a minimum of two days per week
at times mutually agreed upon by the parties.
4. The mother and father, by mutual agreement, may vary from this schedule at any time,
but the Order shall remain in effect until further Order of Court after a conciliation conference.
5. There shall be reasonable notice given to the other party if a scheduled period of
j partial custody needs to be canceled or modified and a make-up period shall be offered within a
reasonable time frame.
5. The mother and father agree that each shall notify the other immediately of medical
emergencies which arise while the children are in that parent's care.
. 7, Neither party shall do anything which may estrange the children from the other parent,
or injure the opinion of the children as to the other parent or which may hamper the free and natural
development of the childreds love or respect for the other parent.
By the Court,
t "- ` Ge g6t` eHffer, r 'dent Judge
This Order is entered pursuant to the consent of Plaintiff and Defendant:
Les fie Ann Corrigan, Plaintiff Daniel Lanc on Corrigan, Defend t
'loan Carey, Atto y for Plaintiff Mcq ine M. Verney, Attorney for fendant
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
to
and
44 South Hanover Street
Carlisle, PA 17013
(717) 243-9190
TRUE COPY FRO
Testintaty whereof, I het
of
RECORD
ao set my hand
I A14' 11111(1 01
' Jacqueline A9. Verney
JUN 1 g 1999.
441 IIANVYIR )I 4 (AKIN I, IW IAII I . 1/11) N1-YIYJ • IAA. (/I/1,41-1)IC
4 SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 1999-03324 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CORRIGAN LESLIE ANN
VS.
CORRIGAN DANIEL LANCKTON
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: CORRIGAN DANIEL LANCKTON
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 19.00 '
Surchargeunty 8.0000 ?? ,>,?.:
mas a e, e i
$75=-
00/00/0000
Sworn and subscribed to before me
this _!G lm? day of
19 99 A.D.
-lid t,
Mat), Jane Snyder
Real Estate Deputy
William T. Tully
Solicitor
Ralph G. McAllister
Chief Ix putt'
Michael W. Rinehart
Assistant Chief Deputy
Dauphin County
Harrisburg, Pennsylvania 17101
1)h:(717)255-2660 fax:(717)255-2R89
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania CORRIGAN LESLIE ANN
vs
County of Dauphin CORRIGAN DANIEL LANCKTON
Sheriff's Return
No. 1099-T - - -1999
OTHER COUNTY NO. 99-3329
AND NOW: June 9, 1999 at 3:35PM served the within
PROTECTION FROM ABUSE,NOTICE,ORDER & PET upon
CORRIGAN DANIEL LANCKTON by personally handing
to DEF
1 true attested copy(ies)
of the original PROTECTION FROM ABUSE, NOTICE, ORDER & PET and making known
to him/her the contents thereof at POE: DOMINO'S PIZZA
501 SOUTH 29TH ST
HARRISBURG, PA 00000-0000
Sworn and subscribed to
before me this 7TH day of JUNE, 1999
F
1-)04kf /'A,)
PROTHONOTARY
(011tce Of $ rSheri ff
So Answers,
)Cp/
Sheriff of in a.
By
uty Sheriff
Sheriff's Costs:S0.00 PD 00/00/0000
RCPT NO
4
(
ET
In The Court of Common Pleas of Cumberland County, Pennsylvania
Leslie Ann Corrigan
VS.
Daniel Lanckton Corrigan
No. 99-3324 Civil 19
Now,ti / 2 / 99 191 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.
Sheriff of Cumberland County, Pa.
Affidavit of Service
Now,
at
by handing to
attested copy of the original
the contents thereof.
So answers,
Sheriff of
COSTS
Sworn and subscribed before
me this day of_
SERVICE S
19 MILEAGE
AFFIDAVIT
19 , at _ o'clock M, served the
County, Pa.
a true and
and made known to
s
CERTIFICATION OF PFA CONTEMPT
CASE - 33
NAME n
rxrrig u_?, ?A 1'll0?_
BALANCE DUE: $
170 STATE SURCHARGE
171 STATE FINE
260 SHERIFF COST ($1.50 + ADDTL)
207 DISTRICT ATTORNEY
204 COURT COSTS (CLERK OF COURTS)
502 RESTIT TION 1
NAME
?nb} ?•?
ADDRESS
CITY
NAME
ADDRESS
NAME
ADDRESS
VICTIM'S NAME:
L08JiP Ann onrriQor\
ADD
S ?l,L r n
$ 10.00
$ 15.00
STATE
STATE
S
DELETE
S
S
$
ZIP
ZIP
CITY STATE ZIP
PROTHONOTARY OFFICE
PERSON CERTYFYING INFORMATION -
QATF.?J??
` 1-
LESLIE ANN CORRIGAN, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V. 99-3324 CIVIL TERM
DANIEL L. CORRIGAN, CHARGE: INDIRECT CRIMINAL CONTEMPT
Defendant
IN RE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, June 29, 1999, 3:10,p..m., the matter having
been called for a hearing on the Commonwealth's petition
charging indirect criminal contempt of a temporary PFA order,
and the defendant having appeared for hearing together with his
personal counsel, Jacqueline Verney, Esquire, and having
admitted the allegations of the petition, we do find the
petition to be supported beyond a reasonable doubt.
At the suggestion of Mrs. Corrigan, through the
District Attorney's office speaking on her behalf, that the
Court impose no jail term on the defendant, sentence of the
court is that the defendant shall be placed on probation for a
period of three months without supervision on condition that he
pay any costs associated with this proceeding and that he abide
by the conditions of the final protective order, entered by
consent, of June 10, 1999.
Jonathan R. Birbeck, Esquire
Chief Deputy District Attorney !mod
Jacqueline Verney, Esquire C 91
_
For the Defendant
Probation Office
Copies delivered on
Sheriff
Legal Services -
:mtf
yS ?•
By the Court,
i
LED-0rFICE
OF TNFI
r^ n7}:iy?dOTARY
99 JUL - 7 PM 3+ 46
CL1hpENNSYLVA iA COUNTY
I
SEP p g 1999
LESLIE ANN CORRIGAN,
Plaintiff
v
DANIEL LANCKTON CORRIGAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-3324 CIVIL
IN CUSTODY
COURT ORDER
AND NOW, this tit day of September, 1999, upon consideration of the attached Custody
Conciliation RePo ordered and directed as follows:
1. The prior custody orders issued in this case are vacated.
2. The Mother, Leslie Ann Corrigan, and the Father, Daniel Lanckton Corrigan, shall
enjoy shared legal custody of Daniel Lewis Corrigan, bom December 21, 1990;
Anna Elizabeth Corrigan, bom April 14, 1995; and Madeline Marie Corrigan, bom
December 22, 1997.
3. The Mother shall enjoy primary physical custody of the minor children.
4. The Father shall enjoy periods of temporary physical custody of the minor children
as follows:
A. September 4, 1999 at 8:00 am. until September 6, 1999 at 7:00 p.m.
B. September 18, 1999 at 8:00 am. until September 19, 1999 at 7:00
p.m.
C. October 9, 1999 at 8:00 a.m. until October 11, 1999 at 7:00 p.m.
D. October 23, 1999 at 8:00 a.m. until October 24, 1999 at 7:00 p.m.
E. November 6, 1999 at 8:00 am. until November 7, 1999 at 7:00 p.m.
F. November 25, 1999 at 5:00 p.m. until November 28, 1999 at 7:00
p.m.
G. December 11, 1999 at 8:00 am. until December 12, 1999 at 7:00
p.m.
H. December 26, 1999 at 12:00 p.m. until January 2, 2000 at 12:00 p.m.
1. January 15, 2000 at 8:00 a.m. through January 17, 2000 at 7:00 p.m.
5. Both parties shall enjoy telephone access with the minor children during the time
they are with the other parent.
6. The parties shall meet again with the custody Conciliator for a conference on
January 20, 2000 at 8:30 a.m.
cc: Jacqueline M. Verney, Esq. ?3 ?qq
Jan Terpening"`°? 9 ?,.?
I
f.
v:
U
?. w i16
.
IN THE COURT OF COMMON PLEAS OF
LESLIE ANN CORRIGAN, CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
: CIVIL ACTION - LAW
v NO.99-3324CML
DANIEL LANCKTON CORRIGAN, IN CUSTODY
Defendant
Prior Judge: George E. Hoffer
CONCILIATION CONFERENCE SUMMARY REPORT
OFPROCEDURE
followCIVIL ing RULE
IN ACCORDANCE WITH THE MBE 1Ra o D COUNTY
1915.3-8(b), the undersigned
I The pertinent information pertaining to the children who are the subject of this litigation is
as follows: April 14,
Daniel Lewis Corrigan, born December
21, 19*1 Decembe 22a 1947 Beth Corrigan, bon 1995; and Madeline Marie Corrigan,
held on August 31, 1999, with the following individuals in
2 A Conciliation Conference was
attendance:
with her representative, Jan Terpemng of Legal Services;
The Mother, Leslie Ann Corrigan, with his counsel, Jacqueline M. Verney, Esquire.
and the Father, Daniel Lanckton Corrigan,
3, The parties agree to the entry of an order in the form as attached'
l ? Es w
Hubert X. Gilroy, q
DATE Custody Conciliator
JAN 2 4 200wP
LESLIE ANN CORRIGAN,
Plaintiff
v
DANIEL LANCKTON CORRIGAN,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-3324 CIVIL
IN CUSTODY
COURT ORDER
AND NOW, this ?b day of January, 2000, upon consideration of the attached Custody
Conciliation Report, it is ordered and directed as follows:
1. The prior Custody Order of September 1999 shall remain in effect with respect to
the shared legal custody arrangements and with Mother having primary physical
custody.
2. Father shall continue to enjoy periods of temporary physical custody in accordance
with the schedule the parties have worked out over the past few months.
3. In the event either party desires this matter to be again referred to a Custody
Conciliator, that party may contact the Conciliator directly to arrange for a
Conference.
I
cc: Jacqueline M. Verney, Esquire
Jan Terpening
Gepo.(rg?e?E. ei?7u
RK?
f 1
i
?l
LESLIE ANN CORRIGAN,
Plaintiff
v
DANIEL LANCKTON CORRIGAN,
Defendant
Prior Judge: George E. Hoffer
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
NO. 99-3324 CIVIL
IN CUSTODY
CONCILIATION CONFERENCE SUMMARY REPORT
IN ACCORDANCE WITH THE CUMBERLAND COUNTY CIVIL RULE OF PROCEDURE
1915.3-8(b), the undersigned Custody Conciliator submits the following report:
1. This case was before the Conciliator last August at which time the Conciliator recommended an
interim Order with the scheduling of a second Conciliation Conference for January 20, 2000.
The Mother and her counsel appeared at the January 20'h Conciliation Conference but the Father
and his counsel did not appear. The Conciliator contacted the Father's attorney who requested
that the matter be continued and rescheduled if possible. Mother's counsel suggested that the
parties are working matters out between themselves at this time. Based upon this situation, the
Conciliator recommends an Order in the form as attached.
6 U?
DATE
Hubert X. Gilroy, Esquire
Custody Conciliator