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RENEE S. HESS,
Petitioner,
V.
MARK A. HESS, SR.,
Respondent
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- 113"s1 CIVIL TERM
TEMPORARY PROTECTIVE ORDER
AND NOW, this 1?^ day of 1999, upon presentation and
consideration of the within Petition, and upon finding that the Petitioner RENEE S. HESS,
residing at 528 3rd Street, Carlisle, Cumberland County, Pennsylvania, is in immediate
and present danger of abuse from the Respondent, MARK A. HESS, SR., the following
Temporary Order is entered.
The Respondent, MARK A. HESS, SR., whose current address is 2091 Ritner
Highway, Carlisle, Cumberland County, Pennsylvania, is hereby enjoined from physically
abusing the Petitioner, RENEE S. HESS, or placing her in fear of abuse, and is excluded
from and is ordered to stay away from the residence and premises located at 410 Pindale
Road, Carlisle, Cumberland County, Pennsylvania.
This Order shall remain in effect until a final Order is entered in this case. A
hearing shall be heard on this matter on the day of 'c(/c Jr _? , 199; at
/0:3y o'clock << m. in Courtroom Number _ ? Cumberland County Courthouse,
Carlisle, Pennsylvania. Service of the certified copy of the Petition and this Order shall be
provided by the Cumberland County Sheriffs Department.
The Pennsylvania State Police will be provided with a copy of this Order by Attorney
for the Petitioner and may enforce this Order by arrest for indirect criminal contempt
without warrant upon probable cause that this Order has been violated, whether or not the
violation is committed in the presence of the Police Officer. In the event that an arrest is
made under this section, the Respondent shall not be taken to jail but shall be taken
without necessary delay before the Court that issued the Order. When the Court is
unavailable, the Respondent shall be arraigned before a District Justice who shall set bail
according to the provisions of Chapter 4000 of the Pennsylvania Rules of Criminal
Procedure.
BY THE COURT.
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RENEE S. HESS, : IN THE COURT OF COMMON PLEAS
Petitioner, : CUMBERLAND COUNTY, PENNSYLVANIA
V. : NO. 99- CIVIL TERM
MARK A. HESS, SR.,
Respondent
NOTICE
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set
forth in the following pages, you must take action within twenty (20) days after this
Complaint and Notice are served, by entering a written appearance personally or by
attorney and filing in writing with the Court your defenses or objections to the claims set
forth against you, You are warned that if you fail to do so the case may proceed without
you and a judgment may be entered against you by the Court without further notice for any
money claimed in the Complaint or for any other claim or relief requested by the Petitioner.
You may lose money or property or other rights important to you.
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
RENEE S. HESS,
Petitioner,
V.
MARK A. HESS, SR.,
Respondent
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- Ya'j / CIVIL TERM
PETITION FOR PROTECTIVE ORDER
Relief under the Protection from Abuse Act, 35 P.S. Section 10181 at seq.
1. Petitioner is an adult individual who is currently residing at 528 3rd Street,
Carlisle, Cumberland County, Pennsylvania.
2. Respondent is an adult individual who is currently residing at 2091 Ritner
Highway, Carlisle, Cumberland County, Pennsylvania. Respondent is employed at G. S.
Electric, 1700 Ritner Highway, Carlisle, Cumberland County, Pennsylvania.
3. The Petitioner and Respondent were married on April 10, 1993.
4. For many months the Respondent has attempted to cause and has
intentionally, knowingly, or recklessly caused bodily injury and serious bodily harm to the
Petitioner and by physical menace has placed the Petitioner in fear of imminent serious
bodily injury. This has included but is not limited to the following specific incidents of
abuse: A. On or about August 1993, Respondent threw hot chocolate in
Petitioner's face and all over clothes;
B. On or about October 1993, Respondent knocked Petitioner on the
floor and kicked her in the back with his boots and proceeded to lock
Petitioner out of the house;
C. On or before July 1994, Petitioner had wisdom teeth extracted and
Respondent grabbed her face around her mouth causing her to
bleed;
D. On or about February 1999, Respondent hit Petitioner on the back
with metal golf clubs causing a welt on Petitioner's back;
E. On or about March 1999, Respondent came home intoxicated
and tried to take Petitioner's car so that he could wreck it but
proceeded to enter the house striking Petitioner on the head with his
head causing a knot on her forehead and two black eyes;
F. On or about March 1999, Respondent locked Petitioner and their son
out of the house; Petitioner called the police but they said no crime
had been committed;
G. On or about April 1999, Respondent moved out of Petitioner's
home;
H. On or about July 4, 1999, while Respondent was dropping their son
off at Petitioner's parents house, Respondent grabbed Petitioner out
of car causing a large bruise on Petitioner's arm and requiring
Petitioner's father to help remove Respondent from Petitioner;
5. Petitioner believes and therefore avers that she will be in immediate and
present danger of serious abuse from Respondent should he not be excluded from her
residence at 528 3rd Street, Carlisle, Cumberland County, Pennsylvania and that she is
in need from protection from such abuse.
6. Respondent is currently residing at 2091 Ritner Highway, Carlisle,
Cumberland County, Pennsylvania.
7. The child of Petitioner and Respondent's marriage, MARK A. HESS, JR.,
resides with Petitioner at 528 3rd Street, Carlisle, Cumberland County, Pennsylvania.
WHEREFORE, pursuant to the provisions of the Protection from Abuse Act of
October 7, 1976, 35 P.S. Section 10181 et seq. as amended, the Petitioner prays this
Honorable Court to grant the following relief:
A. Grant the Temporary Order pursuant to the Protection from Abuse Act:
1. Requiring the Respondent to refrain from abusing the Petitioner or
placing her in fear of abuse;
B. Schedule a hearing in accordance with the provisions of the Protection from
Abuse Act: and after such hearing, enter an Order to be in effect for a period of one year:
Requiring the Respondent to refrain from abusing the Petitioner or
placing her in fear of abuse;
The Petitioner further asks that a copy of this Petition and Order be delivered to the
Pennsylvania State Police Department as the police department with jurisdiction to enforce
this Order.
The Petitioner further asks that a certified copy of this Petition and Order be served
on the Respondent by the Cumberland County Sheriff.
The Petitioner prays for such other relief as may be just and proper.
Respectfully Submitted
TURO LAW OFFICES
2.t q
Date
LISA M'GR SON, Esquire
32 South 86dford Street
Carlisle, PA 17013
(717) 245-9688
Attorney for
VERIFICATION
I verify that the statements made in the foregoing Petition For Protective Order are
true and correct. I understand that false statements herein are made subject to the
penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities.
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Date( RENEE S. HESS
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RENEE S. HESS, IN THE COURT OF COMMON PLEAS OF
PLAINTIFF CUMBERLAND COUNTY, PENNSYLVANIA
V.
MARK A. HESS, SR.,
DEFENDANT 99-4521 CIVIL
ORDER OF COURT
AND NOW, this L day of August, 1999, this temporary order is
entered pending any further order entered in any separate custody case that may be
instituted by either party:
(1) The mother, Renee S. Hess shall have physical custody of Mark A. Hess,
Jr.
(2) The father, Mark A. Hess, Sr., shall have the child:
(a) every other weekend from Saturday morning at 9:00 a.m. until
Monday either before school or before he goes to work; and
(b) at such other times as the parties may agree.
Lisa Greason, Esquire
For Plaintiff
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Sally J. Winder, Esquire -'
For Defendant
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By the Court,
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RENEE S. HESS, : IN THE COURT OF COMMON PLEAS OF
PETITIONER : CUMBERLAND COUNTY, PENNSYLVANIA
V.
MARK A. HESS, SR.,
RESPONDENT 99-4521 CIVIL
ORDER OF COURT
AND NOW, this SKA- day of August, 1999, IT IS ORDERED:
(1) The petition of Renee S. Hess seeking a protection from abuse order, IS
DENIED.
(2) The temporary protective order entered on July 27, 1999, IS VACATED.
Lisa Greason, Esquire
For Petitioner
Sally J. Winder, Esquire
For Respondent
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-04521 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HESS RENEE S
VS.
HESS MARK A SR
RICHARD SMITH Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within TEMPORARY PROTECTIVE ORDER was served
upon HESS MARK A SR the
defendant, at 12:15 HOURS, on the 27th day of July
1999 at 2091 RITNER HIGHWAY
CARLISLE, PA 17013 CUMBERLAND
County, Pennsylvania, by handing to MARK A. HESS, SR.
a true and attested copy of the TEMPORARY PROTECTIVE ORDER
together with NOTICE & PETITION FOR PROTECTIVE ORDER
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00 So answers:
3.00i..tt
8.00 1z-TZ m g ine, neri r
$Z9ZIJ-
07/27/1999
by
Sworn and subscribe- to before me
this d 7 p" day ofL.
19 99 A.D.
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