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HomeMy WebLinkAbout99-04087r? t' "uf 5 .?F . ` 1 w+ J v ft ` 41- a? F K M. I 'A [LASH uu E 1. L /ZW C W n ? . - wa?? mood Y J z , J G C v a L Zx ^ U ? a LL Z Signature (FIRST) (INITIAL[ CLE.IA "ME IN TIME WT IN REPRESENTING: ti ,LT .7 G ?S Phone # (???71 ? OP- ?LY? ) N z6 06/27/99 11:16PM OO1k0IN AM *0025 )99ACBAL $0.00 1P/18 T438.00 06L WSERV $38.00 06/28/99 11:54AM 00100529 Ai;w #0025 3KKKAL $38.00 MDSE ST $38.00 TAX 1 $2.28 DfARGE1 $40.28 WMAL $0.00 I 1 I N - I r? I 74 r. II'1 i 9 I r n. .. ,. I,a qll. I i I r .I ? iF' it ? ?,udli `. FCIF LI .;1111 ?i Lr7:-•I-, ?" .J IF I IC CI I kJ' Iw.M i ?r 44A pLLA1 (USi) NMIE (ilp$i? (INIiIRL ) iIMEI TIME Wf ?? J { ? V LE / CT ?.Jv EEi IDLp`Els1 REPRESENTING: ? A?N L .Si lE d Zly p yvi N P41rv C9EgT 0 ll EN ENO. Phone # ( ) 07/01/99 8:53PM 001#075 1 PAN / ##t010i4a 3BSECBAL 40.00 K w 71448.00 3 9. -10.00/ %2 -4.80 v 081- XXXSERV 443.20 07/02/99/ 4:OOPM 001#0792 ANN ?-- #004 0 3XXPBRL 443.20 PHONE 40.70 = MDSE ST 443.90 w ^ N TAX 1 42.88 = n ^ CHARGEI 446.78 O 0 a J 3B3MAL 40.00 CL a: Y-i z = .4z a 0 C` w^- xx Z n¢ =LL a n `r: inn l i i(4f . r. t t t Ir4! l i ` ll O MST) NAME SU ? Wok r o r Z `l, nUC p LL IpRSn IINITMLI I CLERa I TIME IN ,/q 110 7/,, Phone # ( ) , 07/11/99 11:11AM 001#1421 / #4050 )mCBAL 40.00 w 38.00 1P/1B TM4.00 -10.00': :2 -11.40 MDSE ST 4102.60 TAX 1 $6.84 MGEI $109.44 WOMAl_ Signature TIME WT A3;7; 40.00 Ii 1 1 ( L' r I, t I -liitIFIts l irll HH 7 II-11?F't i lr'hcl ..,? i 101P 111 ltl vi;::: ?1mti .T..- i T:-Iiit11 F 1i 1;:4pU, ! i 1 rll_IF. j, I:? I,I1 G: _._ I i i •?_ • ?.. 'Y'IN ?. 1 I w4,q J 7 4`r CN NHGINLE CC lkr 1 N p001A MSTI N..EE, (fllliil IINITI/.L) CLENF 1-?N 111 MF Wi r?!V rte{. /!'r?l (J 1 ??'cC/?i? sTNEST e?opess IN REPRESENTING:-._ cFwt.?- CE O rNa? n r Y j` C n r - M K- = y p W C, ? r U d Signature U - Phone # -_ 06/29/99 2:04AM 00140567 Ariz: ? 1 Y 6a+G1'ut t #0035 )9!*CBAL $0.00 /Z o c.•? 1P/18 T1$38.00 h? -10.00% ?- .2 -3.80 08L XXXSERV $34.20 06/29/99 12:05PM 001#0588 A3fx #0035 )MPBAL $34.20 MDSE ST $34.20 TAX 1 $2.28 CHARGE $36.48 906aEBAL $0.00 I ;. 'r i suprz 'CP aTiaurt IIf firm 7affiaxritt Mink PistY d JOAN L. STEHULAK. ESQUIRE 434 MAIN CAPITOL BUILDING DEPUTY PROTHONOTARY P.O. BOX 624 SHIRLEY BAILEY HARRISBURG. PENNSYLVANIA 17106 CHIMP CLERK 17171787.6101 January 25, 1999 DUplAv"Cou t"GaUpa18 REGISTRATION UNDER RULES 321 & 322 (PENNSYLVANIA EAR ADMISSION RULES) OF ELIGIBLE LAW STUDENT William J. Patch IV 250 Walnut St. Carlisle, PA 17013 TO THE APPROVED SUPERVISING ATTORNEY: Professor Robert Rains Professor Thomas Place Donald Marritz, Esquire Family Law Clinic The Dickinson School of Law The Pennsylvania State University 45 N. Pitt St. Carlisle, PA 17013 The above-named law student has been approved and certified under Pa. H.A.R. 321 & 322 by: Harvey A. Feldman Associate Dean The Dickson School of Law The Pennsylvania State University 150 South Colleae Street Carlisle, PA 11013-2899 as a duly enrolled law student who has completed at least three (3) semesters of legal studies, or the equivalent thereof, is of good character, has been adequately trained and is of competent legal ability to perform as a legal intern as of 01/25/99. Pursuant to such certification and in accordance with and subject to the provisions of Pa. H.A.R. 321 & 322, the above student has been registered and you have been approved to perform the duties of supervising attorney. WITNESS my signature and the seal of this Court, January 25, 1999. Can u ac, Esquire Deputy Prothonotary /lz LAURIE G. NORLAND, Plaintiff V. JAY E. GALLAGHER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN PROTECTION FROM ABUSE NO. 99 - 4087 CIVIL TERM I hereby consent to the appearance of William J. Patch, IV Certified Legal Intem under the supervision of an attorney, in the above-entitled Protection From Abuse proceeding before the Honorable Kevin A. Hess at 9:00 a.m. on Monday, July 12, 1999. Date la ?? L rie G. Norland As the supervising attorney for William J. Patch IV., certified under P.B.A.R. 322, I approve of his appearance on behalf of the above-named client in the above-named proceeding. Date ? // ?-/ i f ov, DONALD MARRITZ Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 JUL ` 2 1%Wi? LAURIE G. NORLAND, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW V. IN PROTECTION FROM ABUSE JAY E. GALLAGHER, Defendant NO. 99 - 408'1 CIVIL TERM NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on the matter is scheduled for the /, zTh , day of July, 1999, at_06 o'clock C?,_.m., in Courtroom No. L_i?_ at the Cumberland County Courthouse, Carlisle, Pennsylvania. You MUST obey the Order that is attached until it is modified or terminated by the court after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six months in jail under 23 Pa.C.S. § 6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. § 2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. §§ 2261-2262. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEARING. THE COURT WILL NOT, HOWEVER, APPOINT A LAWYER FOR YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT FIND A LAWYER, YOU MAY HAVE TO PROCEED WITHOUT ONE. Cumberland County Bar Association 2 Liberty Avenue Carlisle, Pennsylvania 17013 (717) 249-3166 LAURIE G. NORLAND, Plaintiff V. JAY E. GALLAGHER, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN PROTECTION FROM ABUSE NO. 99 - LCFj CIVIL TERM TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name: Jay E. Gallagher Defendant's Date of Birth: September 12, 1955 Defendant's Social Security Number: unknown Names of All Protected PersoW ;rie G. Norland AND NOW, this ? day of July, 1999, upon consideration of the attached Petition for Protection From Abuse, the court hereby enters the following Temporary Order: [X] 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 the residence at 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. [X] 3. 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: [X] 4. Defendant shall not contact Plaintiff by telephone or by any other means, including through third persons. [] 5. Pending the outcome of the final hearing in this matter, Plaintiff is awarded temporary custody of the following minor child/ren: n/a [X] 6. Defendant shall immediately relinquish all firearms in his possession or control to the Sheriff's Office or a designated local law enforcement agency for delivery to the Sheriff's office. Defendant is prohibited from possessing, transferring or acquiring any other weapons until further order of court. [X] 7. The following additional relief is granted: Defendant is prohibited from destroying, damaging, or interfering with plaintiff's use and enjoyment of her personal property, wherever located. [X] 8. A certified copy of this Order shall be provided to the police department where Plaintiff resides. [] 9. THIS ORDER SUPERSEDES [ ] ANY PRIOR PFA ORDER AND [ ] ANY PRIOR ORDER RELATING TO CHILD CUSTODY. [X] 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 THE 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 Ps.C.S § 6114. Consent of the Plaintiff to Defendant return to the residence shall not validate 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. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiffs residence OR any location 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 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: LAURIE G. NORLAND, Plaintiff V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN PROTECTION FROM ABUSE JAY E. GALLAGHER, Defendant NO. 99 -y087 CIVIL TERM PETITION FOR PROTECTION FROM ABUSE 1. The Plaintiff's name is Laurie G. Norland. 2. Plaintiff is filing this Petition on behalf of herself. 3. Name(s) of ALL person(s) who seek protection from abuse: Laurie G. Norland. 4. Plaintiff's address is: 114 Lee Ann Court, Enola Pa. 17025 5. Defendant is believed to live at the following address: 114 Lee Ann Court, Enola Pa. 17025 Defendant's Social Security Number (if known) is: Defendant's date of birth is: September 12, 1955 Defendant's place of employment is: unemployed [] Check here if Defendant is 17 years old or younger. 6. 7. 8. The parties are former sexual/intimate partners. Plaintiff and Defendant have not been involved in any of the following court actions: Divorce, Custody Support, Protection From Abuse. The most recent incident of abuse took place on or about June 24th, 1999, at about 11:30 pm - 12:00am, at the former joint residence, 114 Lee Ann Court, Enola Pa. 17025. Plaintiff entered home and found garage door opener disconnected, various items moved around house, her possessions thrown on the floor, and defendant locked in the upstairs computer room. Plaintiff knocked on door to get defendant's attention. Defendant refused to answer. A few moments later defendant came out of the computer room, stormed downstairs. Defendant then kicked plaintiff's belongings. Plaintiff, who is a registered nurse, attempted to pick up her nursing bag, which held her equipment, and defendant tried to kick it out of her hands. Plaintiff was forced to back away, until defendant finally kicked her hand causing substantial pain and forcing her to drop the bag. As a result of the incident plaintiff noticed a welt and bruise on her hand, and various bruises on her arms and legs. 9. Defendant has committed prior acts of abuse against Plaintiff, including but not limited to: a) On several occasions over the last few months, defendant has physically threatened Plaintiff in a way to cause plaintiff fear for her immediate safety by abruptly standing and physically intimidating plaintiff. Defendant would also stare at his gun case during arguments intimidating plaintiff that he intended to use these weapons. These acts caused Plaintiff to fear for her safety. b) During an argument between plaintiff and defendant in February or March, 1999, plaintiff poured a glass of water on defendant's chest in an attempt to get defendant's attention. Defendant leaped up, walked to his gun cabinet and began loading his weapons while staring at plaintiff. Plaintiff was placed in fear that defendant intended to cause severe pain to her and would use the weapons. 10. Defendant has used or threatened to use firearms against Plaintiff. 11. The Enola and Carlisle Police Departments shall be provided with a copy of the protection order. 12. There is an immediate and present danger of further abuse from the Defendant. CHECK THE FOLLOWING BOXES ONLY IF THEY APPLY TO YOUR CASE AND PROVIDE THE REQUESTED INFORMATION: [X] Plaintiff is asking the court to evict and exclude the Defendant from the residence at 114 Lee Ann Court, Enola Pa. 17025, which is rented by Laurie G. Norland and Jay E. Gallagher. [X] Plaintiff has suffered out-of-pocket financial losses of at least $273 as a result of the abuse described above, as follows: a) Plaintiff has lost wages of at least $168 from having to take off of work because of Defendant's abuse. b) Plaintiff has been forced to spend at least $105 for alternated housing. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING (CHECK ALL FORMS OF RELIEF REQUESTED): [X] A. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/of minor child/ten in any place where Plaintiff may be found. [X] B. Evict/exclude Defendant from Plaintiffs residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff, or require Defendant to provide Plaintiff with other suitable housing. [X] C. Prohibit Defendant from having any contact with Plaintiff, either in person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Plaintiffs school, business, place of employment or any other location. [X] D. Order the Defendant to temporarily turn over weapons to the Sheriff for this County and prohibit Defendant from transferring, acquiring or possessing any such weapons for the duration of the Order. [X] E. Direct Defendant to pay Plaintiff for the reasonable financial losses suffered as the result of the abuse, to be determined at the hearing. [X] F. Order Defendant to pay the costs of this action, including filing and service fees. [X] G. Order Defendant to pay Plaintiff's reasonable attorney's fees. [X] H. Order the following additional relief, not listed above: Defendant shall be prohibited from destroying, damaging, or interfering with plaintiff's use and enjoyment of her property. [X] I. Grant such other relief as the court deems appropriate. [X] J. Order the police or other law enforcement agency to serve the Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The Plaintiff will inform the designated authority of any addresses, other than Defendant's residence, where Defendant can be served. WiWafit . Patch IV Certified Legal Int m T A M, LACE ROBERT E. RAINS Supervising Attorneys DONALD MARRITZ Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 VERIFICATION Understanding that the making of any false statement would subject me to the penalties of 18 Pa.C.S § 4904, I verify that I am the Plaintiff 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, information and belief. ie G. Norland, Plaintiff Dated: July 2, 1999 V \ T n. . QL C 1NV V J u n ? h V 06/28/99 08:53 FAY 717 776 9284 COMMONWEALTH OF PENNSYLVANIA U.J.(09-3-02) UUINI1 09-3-02 WNama: Han. HELEN B. SHULENBERGER Addl,,V P.O. BOX 155 27 W. BIG SPRING AVENUE NEVVILLE, PA 17241 ToNPllonr (717 ) 776 - 3187 PLAINTIFF REOLIESTS CONFIDENTIALITY OF PETITION OF THE PLAINTIFF 1, 6,04,; a Ndr/g7d , hereby petition for emergency relief from abuse (Name of Plalnf ff-plmse type) X on behalf of myself ? on behalf of the following (child) (children) to whom I am a (parent) (adult household member) (guardian) ? on behalf of the following incompetent adult to whom I am guardian (Name) (Address) (Name) (Address) Emergency relief from abuse is required because there is immediate an present danger of abuse y the defendant to (me) and to the above listed (child) (children) (incompele acl@W-namesladdres sheet of paperland attach he eto jon a separate nn trio ur ISAUINU AU I MUKI I Y At an ex pane nearing on LZL+ v a: r,s ffArl, I have found upon good cause that it is necessary to protect the (plaintiff) and above listed (child) (children) (incompetent adult). ? 1 have NOT found that it is necessary to Issue a protective order. ?s? zat ACTION OF ISSUING AUTHORITY Having found upon good cause shown that it is necessary to protect the (plaintiff) and above listed (child) (children) (incompetent adult), I have taken the following action on this petition: Ordered the defendant to refrain from abusing the plaintiff and/or minor child, children, incompetent adult. ? Ordered the defendant to refrain from having any contact with the plaintiff or minor children, including restraining the defendant from entering the place of employment or business or school of plaintiff or minor children and from harassing plaintiff, plaintiff's relatives or minor children. ? Ordered the eviction of the defendant from the (household) (residence) at (and) (Address) ? Ordered restoration of possession to the (household) (residence) at ? Allowed the defendant to provide suitable, alternate housing by con: (Address) To: (Sheriff) (Constable) (Police Officer) (Police Department). In compliance with the order(s) appearing above, you are hereby directed ? to evict (Noma of Defendant) from the premises at (and) ? to restore premises at (Acores`) to (Atldrase) (Name of Planlif ) 9 001 PETITION FOR EMERGENCY RELIEF FROM ABUSE PLAINTIFF: NA and ADDRESS p oe NOrI?d - 1e1U-/L5,? _i ?/? Lem Ann a-- Il- LE?x /4 , (P4 /-70 a?, J VS. DEFENDANT: NAME and ADDRESS Jet //I/ (.een,. `dLtr LCna /a: , p? / 7d asp J Docket No.: Date Filed: Orders issued are pursuant to the Protection from Abuse Act, Act No. 216 (1976j, as amis ided.WARNING: Failure to comply with these orders may result in a finding of CRIMINAL CONTEMPT pursuant to 42 Pa. C.S$ 4137. This offense is punishable by a One and/or imprisonment. These orders exoire at the end of the next business day the Court deems itself available. These orders will be immediately certified to the Court of Common Pleas, .-_ -,.?.-,. T„m aonvc aaCNITIf1NICr) AnT ?X4R LAURIE G. NORLAND, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN PROTECTION FROM ABUSE V. NO. 99-4087 CIVIL TERM JAY E. GALLAGHER Defendant ORDER OF COURT AND NOW this day of , 1999 upon agreement of the parties the Temporary Protection from Abuse Order entered the 2"' day of July 1999 is continued pending dismissal of this case on July 31, 1999. If no further hearing is requested in this matter then the Temporary Protection from Abuse Order entered on July 2, 1999 is Vacated. Pursuant to this Order and pending the dismissal Defendant agrees to pay $200.00 to Plaintiff for her costs incurred and is to pay the first $80.00 of the cost of this Action. Further, Defendant is Ordered to allow Plaintiff use of the residence on six days which she is to be off work, and agrees not to be present during those time periods. Defendant will allow the Plaintiff to gather her possessions to leave the State and relinquish all of his interests in the waterbed. The no-contact provision of the July 2, 1999 Order is modified to allow limited contact. J. The Dale F. Shughart Conununity Law Center Karl E. Rominger, Esquire LAW OFFICES OF PAUL BRADFORD ORR ATTORNOY AT LAN 50 EAST HIGH STREET CARLISLE, PA 17013 The Law Offices of Paul Bradford Orr 50 East High Street Carlisle, PA 17013 P t 1 T LAW OFFICE'S OF PAUL BRADFORD ORR ATTORNEY AT Lmv 50 [AST HIGII STREET CARLISLE, PA 17013 The Dale F. Shughart Community Law Center AT"I'N: William J. Patch IV 45 North Pitt Street Carlisle, PA 17013 33°SA M .1, t SHERIFF'S RETURN - REGULAR CASE NO: 1999-04087 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND NORLAND LAURIE G VS. GALLAGHER JAY E CHRISTOPHER EVANS , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon GALLAGHER JAY E the defendant, at 16:33 HOURS, on the 2nd day of July 1999 at 114 LEE ANN COURT ENOLA, PA 17025 CUMBERLAND County, Pennsylvania, by handing to JAY E GALLAGHER a true and attested copy of the PROTECTION FROM ABUSE together with NOTICE OF HEARING AND ORDER, TEMPORARY PROTECTION FROM ABUSE ORDER and at the same time directing His attention to the contents thereof. Additional Comments: WEAPONS CONFISCATED Sheriff's Costs: So answers- Docketing 18.00 Affidavit 8..68 Surcharge 8.00 K1 omas line, S rif£ 8-07/06/1999 U by 7 t ?Z u-y eri Sworn and subscribed to before me this 6 a" day of 19_ qCj A.D. ro on?? LAURIE G. NORLAND, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN PROTECTION FROM ABUSE V. JAY E. GALLAGHER Defendant NO. 99-4087 CIVIL TERM ORDER OF COURT AND NOW this 11' day of Qw?y _, 1999 upon agreement of the parties the Temporary Protection from Abuse Order entered the 2nd day of July 1999 is continued pending dismissal of this case on July 31, 1999. If no further hearing is requested in this matter then the Temporary Protection from Abuse Order entered on July 2, 1999 is Vacated. Pursuant to this Order and pending the dismissal Defendant agrees to pay $200.00 to Plaintiff for her costs incurred and is to pay the first $80.00 of the cost of this Action. Further, Defendant is Ordered to allow Plaintiff use of the residence on six days which she is to be off work, and agrees not to be present during those time periods. Defendant will allow the Plaintiff to gather her possessions to leave the State and relinquish all of his interests in the waterbed. The no-contact provision of the July 2, 1999 Order is modified to allow limited contact. Y J. The Dale F. Shughart Community Law Center d?k Karl E. Rominger, Esquire ?`?"` ;Lr , i F:-= t Y nr"? ?JTIVI 99 Jl!! 14 f,ii It' 46 LAURIE G. NORLAND, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN PROTECTION FROM ABUSE V. JAY E. GALLAGHER, Defendant NO. 99.4087 CIVIL TERM ORDER OF COURT AND NOW, this z i ` day of, the Sheriff of Cumberland County is directed to be release to the custody of Jay E. Gallagher any and all firearms in his possession or other property he now holds which belong to Jay E. Gallagher. BY THE COURT, 4 4 J. Cumberland County Sheriffs Department Karl E. Rominger, Esquire 7/a I / 9 rf . Attorney for Defendant William Patch, Intern The Dale F. Shughart Community Law Cente } C') N F- c Cl?i (, 44 ) ] LL l V7 h U O i p ,t P 1 6 1999 LAURIE G. NORLAND, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN PROTECTION FROM ABUSE V. NO. 99-4087 CIVIL TERM JAY E. GALLAGHER Defendant ORDER OF COURT AND NOW, this __ day of 1999, upon consideration of the within Petitoner, it is hereby ordered and directed that a hearing be scheduled for _ day of 1997, at _ _ o'clock _ m. in Courtroom No. _, Cumberland County Courthouse, Cumberland County, Pennsylvania. BY THE COURT: J. :a t? k?4 `S y ?; F.Yaf y. LAURIE G. NORLAND, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN PROTECTION FROM ABUSE V. JAY E. GALLAGHER Defendant NO. 99-4087 CIVIL TERM PETITION FOR RETURN OF PROPERTY NOW COMES Jay E. Gallagher by and through his Attorneys, The Law Offices of Paul Bradford, Karl E. Rominger, Esquire and requests that this Court return to him the firearms now in possession of the Cumberland County Sheriff for the following reasons: 1. A Temporary Protection from Abuse Order was entered on the 2nd day of July 1999. 2. As part of the July 2, 1999 Protection from Abuse Order, Defendant's firearms were placed in custody of the Cumberland County Sheriff pending a hearing. 2. By an Order dated July 14, 1999, the Honorable Kevin A. Hess vacated the Temporary Protection from Abuse Order. (Exhibit A) 3. Therefore, the weapons now in possession of the Cumberland County Sheriffs Department are to be immediately returned to the Petitioner. WHEREFORE, Petitioner respectfully requests this Court to Order the Cumberland County Sheriffs Department to release said weapons to the Petitioner. Date: > ? 1 i Respectfully submitted, THE LAW OFFICES OF PAUL BRADFORD ORR Karl E. Rominger, Esquire 50 East High Street Carlisle, PA 17013 (717) 258-8558 Supreme Court I.D. 81924 LAURIE G. NORLAND, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN PROTECTION FROM ABUSE V. NO. 99-4087 CIVIL TERM JAY E. GALLAGHER Defendant CERTIFICATE OF SERVICE I hereby certify that on this date, S a ?YT 1999,1 delivered a true and correct copy of the attached Petition to the Dale F. Shughart Community Law Center. Respectfully submitted, LAW OFFICES OF PAUL BRADFORD ORR Karl E. Rominger, Esquire Attorney for Defendant 50 East High Street Carlisle, PA 17013 (717) 258-8558 " LAURIE G. NORLAND, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW IN PROTECTION FROM ABUSE V. JAY E. GALLAGHER Defendant : NO. 99-4087 CIVIL TERM ORDER OF COURT AND NOW this /4day of-d ?l 1999 upon agreement of the parties the Temporary Protection from Abuse Order entered the 2nd day of July 1999 is continued pending dismissal of this case on July 31, 1999. If no further hearing is requested in this matter then the Temporary Protection from Abuse Order entered on July 2, 1999 is Vacated. Pursuant to this Order and pending the dismissal Defendant agrees to pay $200.00 to Plaintiff for her costs incurred and is to pay the first $80.00 of the cost of this Action. Further, Defendant is Ordered to allow Plaintiff use of the residence on six days which she is to be off work, and agrees not to be present during those time periods. Defendant will allow the Plaintiff to gather her possessions to leave the State and relinquish all of his interests in the waterbed. The no-contact provision of the July 2, 1999 Order is modified to allow limited contact. J'5i7 a. ? J. The Dale F. Shughart Community Law Center Karl E. Rominger, Esquire 11?' Y 1? L ' lr } 1 1 SL 1 a O s W o LM a > w n ?o? 5 a n^yn x d ' ' W . co . ?Il n a rHl 13:12 FAX 17 240 6573 CUM13 CO PROTHONOTARY 7- Y vl ( Q001 ##i#i#E#ii#x#E#iiix## x## TX REPORT #ss s##ExssE#Exsxss#ExEix TRANSMISSION OK TX/RX NO 1323 CONNECTION TEL 92490779 CONNECTION ID ST. TIME 07/02 13:09 USAGE T 03'08 PGs. 5 RESULT OK