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Staci L. Grimes, :IN THE COURT OF COMMON PLEAS
Plaintiff
OF CUMBERLAND COUNTY, PENNSYLVANIA
VS.
:NO. 99 - ,3 S6 1 CIVIL TERM
Shawn C. Daws,
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../{
kAlk4earing on this matter is sch-?•?ed for the , -
day of
1999, at Id Q m., in Courtroom No.
he 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 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 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.
Staci L. Grimes, :IN THE COURT OF COMMON PLEAS
Plaintiff
:OF CUMBERLAND COUNTY, PENNSYLVANIA
VS.
:NO. 99 - (p CIVIL TERM
Shawn C. Daws,
Defendant :PROTECTION FROM ABUSE
:CUSTODY
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendants Name: Shawn C. Dews
Defendants Date of Birth: 03/14/70
Defendantis Social Security Number: 454-08-1861
Name of Protected Perso s: Staci ;L1G*riimess
AND NOW, this day of upon
consideration of the ttached Peton or Protection from ?Abuse, the
court hereby enters the following Temporary Order:
® 1. Defendant shall not abuse, harass, stalk or threaten any of the
above persons in any place where they might be found.
® 2. Defendant is evicted and excluded from Plaintiff 1a residence
located at 120 South Queen Street, Shippensburg, Cumberland County,
Pennsylvania, which is leased solely by Plaintiff and 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. Defendant shall remain in
his vehicle at all times during the transfer of custody.
? 3. Except for such contact with the minor child/ren 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 school, business, or place of
employment. Defendant is specifically ordered to stay away from the
following locations for the duration of this Order: 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 Defendant, (and any other residence Plaintiff may
establish), 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.
? 4. (Except for such contact with the minor child/ren 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
persons.
® 5. Pending the outcome of the final hearing in this matter.
Plaintiff is awarded temporary custody of the following minor child:
Adrian C. Grimes Date of Birth: 02/09/94
Until the final hearing, all contact between Defendant and the child
shall be limited to the following: at times agreed upon by the parties.
Defendant shall not remove the child from the Commonwealth of
Pennsylvania.
The local law enforcement agency in the jurisdiction where the child is
located shall ensure that the child is 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: Mid Cumberland Valley Regional Police Department and
Pennsylvania State Police.
? 9. THIS ORDER SUPERSEDES ? ANY PRIOR PFA ORDER AND ? 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.
56114. 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 Q.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 Plaintiffs 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.
Joan Carey
Attorney for Plaintiff
Staci L. Grimes, :IN THE COURT OF COMMON PLEAS
Plaintiff
:OF CUMBERLAND COUNTY, PENNSYLVANIA
VS.
:NO. 99 CIVIL TERM
Shawn C. Daws,
Defendant :PROTECTION FROM ABUSE
:AND CUSTODY
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiff's name is Staci L. Grimes.
2. The name of the person who seeks protection from abuse is Staci
L. Grimes
3. Plaintiff's address is 120 South Queen Street, Shippensburg,
Cumberland County, Pennsylvania 17257.
4. Defendant is believed to live at the following address: 120
South Queen Street, Shippensburg, Cumberland County, Pennsylvania
17257.
Defendant's Social Security Number is 454-08-1861.
Defendant's date of birth is 03/14/70.
Defendant's place of employment is Gingerbread Man, located at 13
East King Street, Shippensburg, Cumberland County, Pennsylvania 17257.
5. Defendant is Plaintiff's intimate partner.
6. Plaintiff seeks temporary custody of the following child:
Name Address Sirthdate
Adrian C. Grimes 120 South Queen St. 02/09/94
Shippensburg, PA 17257
7. Plaintiff and Defendant are the parents of the following minor
child:
Name Ace
Adrian C. Grimes 02/09/94
Address
120 South Queen St.
Shippensburg, PA 17257
8. The following information is provided in support of Plaintiff fIs
request for an Order of child custody:
(a) The child was born out of wedlock.
(b) The child is presently in the custody of Plaintiff and
Defendant who reside at 120 South Queen Street, Shippensburg ,
Cumberland County, Pennsylvania.
(c) During the past five years, the child has resided with the
following persons and at the following addresses:
Persons child
Child's name lived with Address When
Adrian C. Grimes Plaintiff/
Defendant
120 South Queen St. 08/97-Present
Shippensburg, PA
Plaintiff/
Defendant
Plaintiff
Plaintiff/
Defendant
Plaintiff/
Defendant
177 Starvis Lane 04/97-08/97
Tire Hill, PA
177 Starvis Lane 09/95-04/97
Tire Hill, PA
593 E. Valverde Rd. 11/94-09/95
Corrales, NM
233 East King St. 02/94-11/94
Shippensburg, PA
(d) Plaintiff, the mother of the child, is currently residing at
120 South Queen Street, Shippensburg, Cumberland County, Pennsylvania.
(e) She is single.
I
(f) Plaintiff currently resides with the following persons:
Name Relationship
Shawn C. Daws boyfriend
Adrian C. Grimes son
(g) Defendant, the father of the child, is currently residing at
120 South Queen Street, Shippensburg, Cumberland County, Pennsylvania.
(h) He is single.
(i) Defendant currently resides with the following persons:
Name Relationship
Staci L. Grimes Girlfriend
Adrian C. Grimes Son
(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:
(1) 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.
(2) Defendant has shown by his abuse of Plaintiff that he
is not an appropriate role model for the minor child.
(3) Defendant's behavior has adversely affected the
child.
(4) Defendant has threatened to remove the child from the
Commonwealth of Pennsylvania.
9. The facts of the most recent incident of abuse are as
follows:
on or about June 13, 1999, Defendant head-butted Plaintiff in
the nose. Their minor child entered the room and found the
Plaintiff on the floor. Defendant threw Plaintiff's keys into
another yard, preventing her from leaving. Defendant grabbed
the telephone forcefully from Plaintiff when she attempted to
call a friend for help. Defendant lifted the Plaintiff
forcefully from the sofa where she was lying.
10. Defendant has committed the following prior acts of abuse
against Plaintiff or the minor child:
a. In May 1999, Defendant screamed directly in her ear,
causing her to have difficulty hearing for
approximately a week. The minor child observed the
incident.
b. In or around the summer 1995, Defendant hit Plaintiff on
the shoulder with a closed fist. Defendant chased
Plaintiff around the room and punched her left arm
repeatedly, causing a bruise which lasted approximately a
month. The minor child observed the incident.
c. In or around the summer 1995, Defendant picked Plaintiff up by
her arms and threw her onto the floor, causing her to suffer a
sprained ankle. The minor child observed the incident.
d. In or around 1995, the minor child stopped speaking coherently
after witnessing the abusive behavior of the Defendant. The
child required speech therapy for an extended period of time
thereafter.
e. On numerous occasions, Defendant has abused Plaintiff in
ways including the following: punched her; thrown her;
thrown objects at her; and dragged her by the hair.
11. 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: Mid Cumberland Valley Regional Police Department and
the Pennsylvania State Police.
12. There is an immediate and present danger of further abuse from
the Defendant.
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. Award Plaintiff temporary custody of the minor child and place the
following restrictions on contact between Defendant and child:
Defendant shall not take the child out of the Commonwealth of
Pennsylvania without the written permission of Plaintiff or Court Order
permitting him to do so.
C. Prohibit Defendant from having any contact with Plaintiff's
relatives.
D. Order Defendant to pay the costs of this action, including filing
fees, service fees, and surcharge of $25.00.
E. Order Defendant to pay $250.00 to reimburse one of Legal Services,
Inc.'s funding sources for the cost of litigation in this case, in the
event the matter goes to hearing.
F. 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.
G. 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 Defendant's residence, where Defendant can be
served.
Plaintiff prays for such other relief as may be just and proper.
Respectfully submitted,
Dated: 45?'- -2S -- '9y
Philip Ariganti,
Andrea Levy,
Joan Carey
Attorneys for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
VERIFICATION
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 best of my knowledge. I understand that any
false statements are made subject to the penalties of 18 Pa.C.S. §4904,
relating to unsworn falsification to authorities.
ti
Dated: Z4-,D 24- (999
--?- C
Staci L.' rimes, Plaintiff
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-03861 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
GRIMES STACI L
VS.
DAWS SHAWN C
TREVOR KENT Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within PROTECTION FROM ABUSE
upon DAWS SHAWN C was served
defendant, at 16:11 HOURS, on the 28th day of June the
1999 at CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE
SHIPPENSBURG, PA 17257
CUMBERLAND
,
County, Pennsylvania, by handing to SHAWN C. DAWS
a true and attested copy of the PROTECTION FROM ABUSE
together with & CUSTODY, NOTICE OF HEARING & ORDER,
TEMPORARY
PROTECTION FROM ABUSE ORDER
and at the same time directing His attention to the contents thereof.
Sheriff's Costs.
So
Docketing 18
00 answers:
Service
Affidavit .
3.10
Surcharge 00
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8.00
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Sworn and subscribed to before me
this .79 w day of
19 9q A.D.
Staci L. Grimes,
Plaintiff
V.
Shawn C. Daws,
Defendant
AND NOW, this _&_y day of
Motion for Continuance, the matter
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- 3861 CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
, 1999, upon consideration of the attached
hearing on. by this Court's Order of June 28,
1999, is hereby rescheduled for hearing on July 20 , 1999, at 9 :30 a.m. in Courtroom No. 3 .
The Temporary Protection Order shall remain in effect for one year or until modified or
terminated by the court.
The Cumberland County Sheriffs Department shall attempt to make service at the
plaintiffs request and without pre-payment of fees, but service may be accomplished under any
applicable rule of Civil Procedure.
This Order shall be docketed in the office of the Prothonotary and forwarded to the
Sheriff for service. The Prothonotary shall not send a copy of this Order to the defendant by
mail.
Certified copies of this Order for Continuance will be provided to the Mid Cumberland
Valley Regional and the Pennsylvania State Police Departments by the plaintiffs attorney.
George E Hoffer,
Philip C. Briganti,
Andrea Levy,
Joan Carey
Attorneys for Plaintiff
Shawn C. Daws
Pro Se Defendant
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Staci L. Grimes, IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 99-3861 CIVIL TERM
Shawn C. Daws,
Defendant PROTECTION FROM ABUSE
AND CUSTODY
MOTION FOR CONTINUANCE
The plaintiff, by and through her attorney, Philip C. Briganti of Legal Services, Inc.,
moves the Court for an Order rescheduling the hearing in the above-captioned case on the
grounds that:
A Temporary Protection Order was issued by this Court on June 28, 1999,
scheduling a hearing for July 1, 1999, at 11:30 a.m.
2. The Cumberland County Sheriffs Department served the defendant with a
certified copy of the Temporary Protection Order and Petition for Protection Order on June 28,
1999, at approximately 4:11 p.m. at the Sheriffs Office in the Cumberland County Court of
Common Pleas.
The parties agree that the hearing be rescheduled to afford them time to execute a
Consent Agreement.
4. The plaintiff requests that the Temporary Protection Order remain in effect until
modified or terminated by the court after notice or hearinP.
5. Certified copies of the Order for Continuance will be delivered to the
Pennsylvania State and the Mid Cumberland Valley Regional Police Departments by the attorney
for the plaintiff.
WHEREFORE, the plaintiff requests that the Court grant this Motion and reschedule this
matter for hearing, and that the Temporary Protection Order remain in effect until further Order
of Court.
Respectfully submitted,
P ilip C. ganti,
Andrea Levy,
Joan Carey
Attorneys for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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Staci L. Grimes, :IN THE COURT OF COMMON PLEAS
Plaintiff
:OF CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
:NO. 99 - 3861 CIVIL TERM
Shawn C. Daws,
Defendant :PROTECTION FROM ABUSE
:AND CUSTODY
FINAL ORDER OF COURT
Defendant's Name: Shawn C. Daws
Defendants Date of Birth: 03/14/70
Defendant's Social Security Number: 454-08-1861
Name of Protects on: S ci L, Grimes
AND NOW, this ay of 1999, the
court having jur adiction over he a ties and the subject-
matter, it is ORDERED, ADJUDGED, an ECREED as follows:
Plaintiff is represented by Philip C. Brigaati 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 allegations made
in the Petition.
? Plaintiff's request for a Final Protection Order is denied OR
® Plaintiff's request for a Final Protection Order is granted.
® 1. Defendant shall not abuse, stalk, harass, or 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 120 South Queen Street, Shippensburg, Cumberland
County, Pennsylvania or any other residence where Plaintiff may
live. Exclusive possession of the residence is granted to
Plaintiff.
? 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.
? 3. Except as provided in Paragraph 5 (and Paragraph #8 if any
unusual circumstances) 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 school,
business, or place of employment. Defendant is specifically
ordered to stay away from the following locations for the
duration of this order: Plaintiff's residence located at
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, Adrian C. Grimes, date of
birth: 02/09/94, shall be as follows: Plaintiff, hereinafter
referred to as the mother, shall have primary physical custody of
the child. The mother and Defendant, hereinafter referred to as
the father, shall share legal custody of the child, with the
mother having the final decision if there is a disagreement. The
father shall have partial custody of the child. The mother and
the father shall agree upon times and dates of partial custody.
? 6. Defendant shall immediately turn over 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.
08. The following additional relief is granted as authorized
by $6108 of this Act3
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 O 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. 56119. 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 ACT, 18 U.S.C.
62265. 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. 66 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. 6922(0), 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. 66113.
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 police
officer 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,
Plaintiff's presence and signature are not required to file the
complaint.
If sufficient grounds for violation of this order are
alleged, Defendant shall be arraigned, bond set and both parties
given notice of the date of the hearing.
If entered pursuant to the consent of Plaintiff and Defendant:
Stac L. Grimes, Plaintiff
i / O
Philip' C. Briq#1ti,
Andrea Levy,
Joan Carey
Attorneys for Plaintiff
Shawn C. Daws, Defendant
Shawn C. Daws
Pro Se Defendant
BY THE COURT,
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06/28/99 MON 14:16 PAX 717 240 6573
CUMB CO PROTHONOTARY 49-.3FGi gool
TRANSMISSION OK
TX/RX NO
CONNECTION TEL
CONNECTION ID
ST. TIME
USAGE T
PGs.
RESULT
sass*xxssssssfsfsssss
xsf TX REPORT fss
fxfiSf xxf xixf xixfffxi
1317
92490779
06/28 14:12
03'28
7
OK