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HomeMy WebLinkAbout99-03560G? m A9 ¢!XI i `'1 S Tracy L. Zeigler, IN THE COURT OF COMMON PLEAS Plaintiff , :OF CUMBERLAND COUNTY, PENNSYLVANIA vs. :NO. 99 - CIVIL TERM James A. Zeigler, , Defendant :PROTECTION FROM ABUSE AND CUSTODY NOTICE OF KHARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims net 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 for the /- ?A dam of June, 1999, at_fro 4 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. 56114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. 52265, 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. 52261-2262. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEARING. TEE 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 HELD. 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 Americana 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. , w? I L? Tracy L. Zeigler :THE COURT OF COMMON PLEAS Plaintiff :OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. :NO. 99 - CIVIL TERM James A. Zeigler, Defendant :PROTECTION FROM ABUSE AND CUSTODY TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name: James A. Zeigler Defendant's Date of Birth: 1/16/58 Defendant's Social Security Number: 193-52-9264 Name of Protected Person: Tracy L. Zeigler AND NOW, this day of 1t.. nc_ , 1999, upon consideration of the attached Petitio3 for Protection from Abuse, the court hereby enters the following Temporary orders ® 1. Defendant shall not abuse, harass, stalk or threaten any of the above persona in any place where they might be found. ? 2. Defendant is evicted and excluded from Plaintiff's residence located at , Cumberland County, Pennsylvania, (a residence which is jointly owned/leased by the parties; owned/leased by the entireties; owned/leased solely by Plaintiff/Defendant to which Plaintiff and the minor child/ren moved to avoid abuse, which is not owned or leased by the Defendant, 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, except for the limited purpose of transferring Custody of the parties' child/ren. Defendant shall remain in his vehicle at all times during the transfer of custody.) ®3. Except for such contact with the minor child 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 Plaintiff's place of employment located at the Labor and Industry Building, 7t" and Forester Streets, Harrisburg, PA. Defendant is specifically ordered to stay away from the following locations for the duration of this Order: Plaintiff's residence located at 860 Walnut Street, Apartment A-3 Cumberland County, Pennsylvania, a residence which is leased by the Plaintiff and any other residence Plaintiff may establish, except for the limited purpose of transferring custody of the parties' child. 04. Except for such contact with the minor child as may be permitted under Paragraph 5 of this Order, Defendant shall not contact Plaintiff by telephone or by any other means, including through third persona. ® S. Pending the outcome of the final hearing in this matter. Plaintiff is awarded temporary custody of the following minor child: Jesse A. Zeigler (DOB 10/45/95) Until the final hearing, all contact between Defendant and the child shall be limited to the following: At times agreed upon by the parties. The local law enforcement agency in the jurisdiction where the child are located shall ensure that the child 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 Sheriff's 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 another act of abuse or has engaged in a pattern or practice that indicates continued 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. ® 8. A certified copy of this order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: West Shore Regional and Harrisburg City Police Departments. ? 9. THIS ORDER SUPERSEDES O ANY PRIOR PFA ORDER AND O ANY PRIOR ORDER RELATING TO CHILD CUSTODY 10. 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. 46114. Consent of 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. 56113. 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 D.S.C. SS 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 Plaintiff's residence OR any locations where a violation of this order occurs OR where 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 Sheriff's office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this Court, unless the weapon/s are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. BY THE COURT Joan Carey ?Z Attorney for Plaintiff 0"? J'- Tracy L. Zeigler, :IN THE COURT OF COMMON PLEAS Plaintiff :OF CUMBERLAND COUNTY, PENNSYLVANIA VS. :NO. 99 - CIVIL TERM James A. Zeigler, Defendant :PROTECTION FROM ABUSE AND :CUSTODY PETITION FOR PROTECTION FROM ABUSE 1. Plaintiff's name is Tracy L. Zeigler. 2. The name of the person who seeks protection from abuse is Tracy L. Zeigler. 3. Plaintiff's address is 860 Walnut Street, Apartment A-3, Lemoyne, Pennsylvania. 4. Defendant is believed to live at 1395 Letchworth Road, Camp Hill, Pennsylvania, 17011. Defendant's Social Security Number is 193-52-9264. Defendant's date of birth is 1/16/58. Defendant's is currently unemployed. 5. Defendant is Plaintiff's husband. 6. Plaintiff seeks temporary custody of the following child: Name Address Birthdates Jesse A. Zeigler 860 Walnut Street 10-25-95 Apt. A-3, Lemoyne, Pa 7. Plaintiff and Defendant are the parents of the following minor child: Name Acre Address Jesse A. Zeigler 3 years old 860 Walnut Street Apt. A-3, Lemoyne, Pa The following information is provided in support of Plaintiffs request for an Order of child custody: (a) The child was not born out of wedlock. (b) The child is presently in the custody of Plaintiff, Tracy L. Zeigler, who resides at 860 Walnut Street, Apartment A-3, Lemoyne, Cumberland County, Pennsylvania. (c) Since his birth the child persons and at the following add Person(s) child Childs name lived with Jesse A. Zeigler Plaintiff and Defendant has resided with the following :esses: Address when 124 Mt.View Terrace Oct.95 Dover, PA to Aug.98 Jesse A. Zeigler Plaintiff and 1395 Letchworth Rd. Aug.98 to Defendant Camp Hill, PA Dec. 98 Jesse A. Zeigler Plaintiff,Mike 4403 Royal Oak Dr. Jan.99 to and Fran Langan Camp Hill, PA March 99 Jesse A. Zeigler Plaintiff 860 Walnut St. March 99 Lemoyne, PA to Present (d) Plaintiff, the mother of the child, is, currently residing at 860 Walnut Street, Apartment A-3, Lemoyne, Cumberland County, Pennsylvania. (e) She is married. (f) Plaintiff currently resides with the following persons: Name Relationship Jesse A. Zeigler Son (g) Defendant, the father of the child, is currently residing at 1395 Letchworth Road, Camp Hill, Cumberland County, Pennsylvania. (h) He is married. (i) Defendant currently resides with the following person/s. Name Relationshifl David L. Zeigler Brother Troy Myers Nephew (j) Plaintiff has not previously participated in any litigation concerning custody of the above mentioned child in this or any other Court. (k) Plaintiff has no knowledge of any custody proceedings concerning this child 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 child or claims to have custody or visitation rights with respect to the child. (m) The best interests and permanent welfare of the minor child will be met if custody is temporarily granted to Plaintiff pending a hearing in this matter for reasons including: Plaintiff is a responsible parent who has provided for the emotional and physical needs of the child since his birth, and who can best take care of the minor child. 8. The facts of the most recent incident of abuse are as follows: On or about May 29, 1999, Defendant opened the door to his residence and pulled Plaintiff into the house by her hair, called her vile names, grabbed her by the shoulders causing bruises, and pushed her into the couch. Defendant reached into Plaintiff's car as she tried to leave and tried to pull her head through the window by her hair. Defendant screamed at Plaintiff that he was going to get her causing her to fear for her safety. 9. Defendant has committed the following prior acts of abuse against Plaintiff: a. On or about January 24,1999, Defendant punched Plaintiff in the head and told her to get out. b. On or about November 1, 1998, Defendant grabbed Plaintiff on the sides of her head and forcefully pushed her head backwards into the basement door. Later that same day, Defendant pulled Plaintiff off of the floor by her arms and shoved her onto the couch. Defendant grabbed Plaintiff by the throat and pushed her back onto the couch when she tried to leave the residence. c. On or about November 2, 1998, Defendant forcefully grabbed Plaintiff by the front of her shirt with both hands and pushed his fists upward under her face causing a cut on her lip. d. On several occasions since 1992, Defendant called Plaintiff vile names and pushed her causing bruises. On two separate occasions Defendant abused Plaintiff in the following ways: 1.)threw her onto the kitchen floor, straddled her, and pinned her shoulders down causing her to fear for her safety, and 2) chocked her as she breast fed her son. 10. The following police departments or law enforcement agencies in the area in which Plaintiff lives should be provided with a copy of the Protection Order: West Shore Regional Police and Harrisburg City Police Departments. 11. There is an immediate and present danger of further abuse from the Defendant. 12. Plaintiff is asking the Court to order Defendant to stay away from the residence at 860 Walnut Street, Apartment A-3, Lemoyne, Pennsylvania, which is rented by Plaintiff. 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 in any place where Plaintiff may be found. B. Order Defendant to stay away from Plaintiff's residence and prohibit Defendant from attempting to enter any temporary or permanent residence of Plaintiff. C. Award Plaintiff temporary custody of the minor child and place the following restrictions or contact between Defendant and child: At times agreed upon by the parties. D. 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 Plaintiff's place of employment, except as the Court may find necessary with respect to partial custody and/or visitation with the minor child. E. Prohibit Defendant from having any contact with Plaintiff's relatives. F. Order Defendant to pay the costs of this action, including filing fees, service fees, and surcharge of $25.00. G. Order Defendant to pay $250.00 to reimburse one of Legal Services, Inc.'s funding sources for the cost of litigation in this case. H. Order the following additional relief, not listed above: a. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. b. Defendant is to refrain from harassing Plaintiff's relatives. I. Grant such other relief as the court deems appropriate. 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. Plaintiff will inform the designated authority of any addresses, other than Defendants residence, where Defendant can be served. COUNT II CUSTODY UNDER PENNSYLVANIA CUSTODY LAiP 13. The allegations of Count I above are incorporated herein as if fully set forth. 14. The best interest and permanent welfare of the minor child will be served by confirming custody in Plaintiff as set forth in paragraph #7 of the petition. WHEREFORE, pursuant to 23 Pa.C.S.§ 5301 et. Sec., and other applicable rules and law, Plaintiff prays this Honorable Court to award custody of the minor child to her. Plaintiff prays for such other relief as may be just and proper. Respectfully submitted, C Joark/ Carey Attorney for aintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 Dated: I verify that I am the Plaintiff as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the beet of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. 54904, relating to unsworn falsification to authorities. C%0199 Dated: Tracy L. Zeigler C' tJ J CJ G? U SHERIFF'S RETURN - REGULAR CASE NO: 1999-03560 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ZEIGLER TRACY L VS. ZEIGLER JAMES A TIMOTHY REITZ Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon ZEIGLER JAMES A the defendant, at 17:20 HOURS, on the 10th day of. June 1999 at 1395 LETCHWORTH ROAD CAMP HILL, PA 17011 CUMBERLAND County, Pennsylvania, by handing to JAMES A. ZEIGLER a true and attested copy of the PROTECTION FROM ABUSE together with AND CUSTODY NOTICE OR HEARING & ORDER, TEMPORARY PROTECTION FROM ABUSE ORDLP and at the same time directing 111.n attention to the contents thereof. Sheriff's Costs: So answers: Docketing 10.00 //?? Affidavit 9.00 10040a?, ra/.ae ? Surcharge 8.00 R-f.,ynumas Kline/ eri S35-30- 06/11/1999 by r? u y e 7 L) P 7- Sworn and subscribe to before me this //I" day of?.41 19 94 A.D. >?1?. j- Prot11U11ULCALy 1 ti Tracy L Zeigler, :IN THE COURT OF COMMON PLEAS Plaintif f OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. :NO. 99 - 3560 CIVIL TERM James A. Zeigler, Defendant :PROTECTION FROM ABUSE : AND CUSTODY FINAL ORDER OF COURT Defendant's Name: James A. Zeigler Defendants Date of Birth: 1/16/58 Defendants Social Security Number: 193-52-9264 Names of Protected Person: Tracy L. Zeigler AND NOW, this IID day of June, 1999, the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED, and DECREED as follows: Plaintiff is represented by Joan Carey of LEGAL SERVICES, INC.; Defendant is unrepresented but is aware of his right to have an attorney. The parties agree that the following may be entered as an Order of Court. Defendant, although agreeing that an Order may be entered, does not admit to the allegation made in the Petition. ? Plaintiff fIs request for a Final Protection order is denied OR ®Plaintiff's request for a Final Protection Order is granted. 01. Defendant shall not abuse, stalk, harass, threaten 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 *[NONCONF IDENTIAL ADDRESS FROM WHICH DEFENDANT IS EXCLUDED] 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. ? On (Insert date and time), 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. 03. Except as provided in 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 Plaintiff's place of employment at the Labor and Industry Building, 7th and Forester Streets, Harrisburg, Pennsylvania. Defendant is specifically ordered to stay away from the following locations for the duration of this Order: Plaintiff's residence located at 860 Walnut Street Apt. A-3, Lemoyne, Cumberland County, Pennsylvania, and any other residence Plaintiff may establish. ® 4. Except as provided in Paragraph 5 of this order, Defendant shall not contact Plaintiff by telephone or by any other means, including third parties. ® 5. Custody of the minor child, Jesse A. Zeigler (DOH 10/25/95), shall be as follows: See attached Custody order. ? 6. Defendant shall immediately turnover to the Sheriff's Office, or to a local law enforcement agency for delivery to the Sheriff's Office, the following weapons used or threatened to be used by Defendant in an act of abuse against Plaintiff and/or the minor child/ren; ? 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. 0 8. The following additional relief is granted as authorized by 56108 of this Act: a. 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 another act of abuse or has engaged in a pattern or practice that indicates continued risk of harm to Plaintiff. b. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. C. Defendant is to refrain from harassing Plaintiff's relatives. d. The court costs and fees are waived. ? 9. Defendant is directed to pay temporary support for [insert the names of the persons for whom support is to be paid] as follows: [insert amount, frequency and other terms and conditions of the support order] 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 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 $* to Plaintiff as compensation for Plaintiff's out-of-pocket losses, which are as follows: OR ? Plaintiff is granted leave to present a petition, with appropriate notice to Defendant, to [insert the name of the judge or court to which the petition should be presented] 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 1.0 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. 2.0 This order is being entered after a hearing of which Defendant received actual notice and had an opportunity to be heard. 3.0 Paragraph 1 of this Order has been checked to restrain Defendant from harassing, stalking, or threatening Plaintiff or protected person(s). 4.0 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. THIS ORDER SUPERCEDES ® ANY PRIOR PFA ORDER AND® ANY PRIOR ORDER RELATING TO CHILD CUSTODY. 14. All Provisions of this Order shall expire in one year. NOTICE TO 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. 56114. 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, IS U.S.C. 52265. 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. 55 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. 5922(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. 56113. 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 [insert the appropriate name or title] shall maintain possession of the weapons until further Order of this 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. BY THE COURT; Edgar B If entered pursuant to the consent of Plaint,Xff and Defendant: awl, Tracy L. Zeigler J es A. Zeig er Plaintiff Pro Se Defendant J n Carey Attorney for Plaintiff 8 Irvine Row Carlisle, PA 17013 ?i? J,l .1? `?r`? .. uI _ . ,. - Tracy L. Zeigler Plaintiff V. James A. Zeigler Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-3560 CIVIL TERM PROTECTION FROM ABUSE AND CUSTODY CUSTODY ORDER AND NOW, this IL- " day of June, 1999, upon consideration of the parties' Consent Agreement, the following order is entered with regard to custody of the parties' child, Jesse A. Zeigler. 1. Plaintiff, hereinafter referred to as the mother, shall have primary physical and legal custody of the child. 2. Defendant, hereinafter referred to as the father, shall have partial custody of the child, on dates and at times agreed upon by the mother and father. 3. The parties shall share the following holidays: Easter, Memorial Day, the Fourth of July, Labor Day, Thanksgiving, and Christmas at times agreed upon by the mother and father. 4. The father shall have the right to see the child on his birthday at a time to be agreed upon by the mother and father. 5. 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. 6. The mother and father shall supply each other with a current address and phone number at all times. 7. Both parties shall have reseasonable phone contact with the child while in the other parties care. 8. The mother and father agree that each shall notify the other immediately of medical emergencies which arise while the child is in that parent's care. 9. Neither party shall do anything which may estrange the child from the other parent, or injure the opinion of the child as to the other parent or which may hamper the free and natural development of the child's to "r. respect for the other parent. Edgar B. T3a)Aey, Judge if entered pursuant to the consent of Phtintiff and Defendant: _ 1? 1vA? Tracy L. Zeigler &1141n Japes A. Zeig er Plaintiff Pro Se Defendant Jo n Carey Attorney for Plaintiff a a a