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Home My WebLink About99-04746 (2) R r;v ;,rt i r jl\ )Y y 4. : nN Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V5. John E. Foose, NO. 99 - 4746 CIVIL TERM Defendant : PROTECTION FROM ABUSE ORDER OF COURT AND NOW, this Iy? day of August, 1999, upon consideration of the attached Petition, the Temporary Protection Order in the above captioned case dated August 6, 1999, is hereby vacated. A certified copy of this Order will be provided to the Newville Police Department by the plaintiffs attorney. By the Court Edward E. Guido, Judge Joan Carey _ l r• r..ud•d 6?/4?49. Attorney for Plaintiff 9 ,.5. a . Jessica M. Foose, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 99 - 4746 CIVIL TERM John E. Foose, Defendant : PROTECTION FROM ABUSE PETITION TO VACATE. ORDER Plaintiff requests the Court vacate the Final Protection From Abuse Order in the above- captioned case on the grounds that: 1. A Temporary Protection Order was issued by this Court on August 6, 1999, scheduling a hearing for August 16, 1999, at 8:45a.m. 2. At this time Plaintiff requests that the Temporary Order entered on August 6, 1999, be vacated without prejudice. 3. A certified copy of this order will be sent to the Newville Police Department by Plaintiffs attorney. WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate the Order without prejudice. Respectfully submitted, (717) 243-9400m or Plaintiff Carlisle, PA 17013 Levy, tto LEGAL SERVICES, INC A rea 8Irvine Row 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. Dated: - G C/ ) e\? 6- (-/ y ?OQ-Ir Jessica M. Foose Vs. NO. 99-y? CIVIL TERM John E. Foose, Defendant : PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following; papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on the matter is scheduled for the ?? of August, 1999, atm., 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. §6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. §2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. § 2261-2262. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEARING. THE COURT WILL NOT, HOWEVER, APPOINT A LAWYER FOR YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT FIND A LAWYER, YOU MAY HAVE TO PROCEED WITHOUT ONE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717)249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. Jessica M. Foose, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99- CIVIL TERM John E. Foose, Defendant PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name: John E. Foose Defendant's Date of Birth: 9/30/64 Defendant's Social Security Number: 166-524302 Names of Protected Person: Jessica M. Foose AND NOW, this 6r day of August 1999, upon consideration of the attached Petition for 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 the residence at *, *, Cumberland County, Pennsylvania, or any other permanent or temporary residence where Plaintiff may live. Plaintiff is granted exclusive possession of the residence. Defendant shall have no right or privilege to enter or be present on the premises. ? 3. Except for such contact with the minor 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 Plaintiffs place of employment located at the Chambersburg Mall, Chambersburg, Pennsylvania. Defendant is specifically ordered to stay away from the following locations for the duration of this Order: Plaintiffs residence located at 264 Henderson Street, Carlisle, Pennsylvania. ? 4. 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 persons. ? 5. Pending the outcome of the final hearing in this matter. Plaintiff is awarded temporary custody of the following minor child: Until the final hearing, all contact between Defendant and the child shall be limited to the following: **. 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 the Plaintiff in accordance with the terms of this Order. ? 6. Defendant shall immediately relinquish the following weapons to the Sheriffs Office or a designated local law enforcement agency for the delivery to the Sheriffs Office: Defendant is prohibited from possessing, transferring or acquiring any other weapons for the duration of this Order. ® 7. The following additional relief is granted: The Cumberland County Sheriffs Department shall attempt to make service at 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 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. Enjoin Defendant is from damaging, destroying, removing, or selling any property owned jointly by the parties or owned solely by Plaintiff. Enjoin Defendant from harassing Plaintiffs relatives. ® 8. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Carlisle Police Department and the Newville Police Department. ? 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. §6114. Consent of the Plaintiff to Defendant's return to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. §6113. Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. §§ 2261-2262. Any protection order granted by a court may be considered in any subsequent proceedings, including child custody proceedings, under title 23 (Domestic Relations) of the Pennsylvania Consolidated Statutes. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiff's residence OR any locations where a violation of this order occurs OR where the defendant may be located. If defendant violates Paragraphs 1 through 6 of this Order, defendant may be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence of law enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriffs office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this Court, unless the 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 Attorney for Plaintiff Judge Jessica M. Foose, Plaintiff VS. John E.Foose, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99- CIVIL TERM PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE Plaintiffs name is Jessica M. Foose, The name of the person who seeks protection from abuse is Jessica M. Foose. 3. Plaintiffs address is 264 Henderson Street, Carlisle, Pennsylvania, 17013. 4. Defendant is believed to live at 4 West Main Street, Apartment #3, Newville, Pennsylvania. Defendant's Social Security Number is 166-52-4302. Defendant's date of birth is 9/30/64. Defendant's place of employment is Navy Depot, Mechanicsburg, Pennsylvania, 17055 and Pino's Pizza, I East Main Street, Newville. 5. Defendant is Plaintiffs husband. 6. Defendant has been involved in the following criminal court action: In or about 1997, Defendant was charged with terroristic threats and harassment by communication. In or about April 1997, Defendant was charged with indirect Criminal Contempt for violation of a Protection From Abuse Order that was taken out by his first wife. 7. The facts of the most recent incident of abuse are as follows: On or about July 12, 1999, Defendant became angry at Plaintiff and hit her in the face several times which rendered her unconscious and she suffered convulsions for a short time. The doctor in the emergency room stated Plaintiff had a concussion and a closed head injury. Defendant was arrested and charged with simple assault. 8. Defendant has committed the following prior acts of abuse against Plaintiff: a. In or about November 1998, Defendant grabbed Plaintiff by the arm and threw her across the bathroom floor causing rug bums on her knees. b. In or about June 1998, Defendant grabbed Plaintiff by her wrist, grabbed her leg, twisted it, and attempted to pull her out of the car. Defendant grabbed the trunk rack, pulled it off of the car, and threw it causing Plaintiff to fear for her safety. 9. 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: Carlisle Police Department and the Newville Police Department. 10. 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. Order Defendant to pay the costs of this action, including filing fees, service fees, and surcharge of $25.00. C. Order Defendant to pay $250.00 to reimburse one of Legal Services, Inc.'s funding sources for the cost of litigation in this case. D. Order the following additional relief, not listed above: a. Enjoin defendant from damaging, destroying, removing or selling any property owned jointly by the parties or owned solely by the plaintiff. b. The Enjoin defendant from harassing the plaintiffs relatives. E. Grant such other relief as the court deems appropriate. F. 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 petitioner 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, 0/' - J Carey d Philip C. Briganti Attorneys for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 VERIFICATION I verify that I am the petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa,C.S. §4904, relating to unsworn falsification to authorities. Dated: L2 lqq ') ")6 iJ- -da Jessica M. Foose hg? ;' ?., ,_ ?,. ?? _ ;; ,? .,? .? w \h ??? a v w ?C .2 ?l w w ? v? Jessica M. Foose, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-y? C114, IVIL TERM John E. Foose, Defendant PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on the matter is scheduled for the &? of August, 1999 a?. Courtroom Nc , of the Cumberland County Courthouse, Carlisle, Pennsylvania. in You MUST obey the Order that is attached until it is modified or terminated by the court after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six months in jail under 23 Pa.C.S. §6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. §2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. § 2261-2262. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE THE RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEARING. THE COURT WILL NOT, HOWEVER, APPOINT A LAWYER FOR YOU. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT FIND A LAWYER, YOU MAY HAVE TO PROCEED WITHOUT ONE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717)249-3166 AMERICANS WITH DISABILITIES ACT OF 1990 The Court of Common Pleas of Cumberland County is required by law to comply with the Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable accommodations available to disabled individuals having business before the court, please contact our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. i?r?_a ?i ??' n tLr?'; i. ;'. u ? ' ?r -^i ? ?^... Jessica M. Foose, IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA vs. John E. Foose NO. 99- CIVIL TERM , Defendant PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name: John E. Foose Defendant's Date of Birth: 9/30/64 Defendant's Social Security Number: 166-524302 Names of Protected Person: Jessica M. Foose AND NOW, this day of August 1999, upon consideration of the attached Petition for 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 the residence at *, *, Cumberland County, Pennsylvania, or any other permanent or temporary residence where Plaintiff may live. Plaintiff is granted exclusive possession of the residence. Defendant shall have no right or privilege to enter or be present on the premises. 3. Except for such contact with the minor 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 Plaintiffs place of employment located at the Chambersburg Mall, Chambersburg, Pennsylvania. Defendant is specifically ordered to stay away from the following locations for the duration of this Order: Plaintiff's residence located at 264 Henderson Street, Carlisle, Pennsylvania. ? 4. 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 persons. ? 5. Pending the outcome of the final hearing in this matter. Plaintiff is awarded temporary custody of the following minor child: Until the final hearing, all contact between Defendant and the child shall be limited to the following: **. 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 the Plaintiff in accordance with the terms of this Order. ? 6. Defendant shall immediately relinquish the following weapons to the Sheriffs Office or a designated local law enforcement agency for the delivery to the Sheriffs Office: Defendant is prohibited from possessing, transferring or acquiring any other weapons for the duration of this order. ® 7. The following additional relief is granted: The Cumberland County Sheriffs Department shall attempt to make serv at plaintiffs request and without pre-payment of fees, but service may be ice 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. Enjoin Defendant is from damaging, destroying, removing, or selling any property owned jointly by the parties or owned solely by Plaintiff. Enjoin Defendant from harassing Plaintiff's relatives. ® S• A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Carlisle Police Department and the Newville Police Department. 9. THIS ORDER SUPERSEDES ? ANY PRIOR PFA ORDER AND PRIOR ORDER RELATING TO CHILD CUSTODY ANY ® 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. §6114. Consent of the Plaintiff to Defendant's return to the residence shall not invalidate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. §6113. Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 1S U.S.C. §§ 2261-2262. Any protection order granted by a court may be considered in any subsequent proceedings, including child custody proceedings, under title 23 (Domestic Relations) of the Pennsylvania Consolidated Statutes. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiffs residence OR any locations where a violation of this order occurs OR where the defendant may be located. If defendant violates Paragraphs 1 through 6 of this Order, defendant may be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence of law enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriffs office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this Court, unless the 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 Attorney for Plaintiff Judge CN-f e4 t1of .l . Jessica M. Foose, : IN THE COURT OF COMMON PLEAS Plaintiff OF CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 99- CIVIL TERM John E. Foose, Defendant PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE 1. Plaintiffs name is Jessica M. Foose. 2. The name of the person who seeks protection from abuse is Jessica M. Foose. 3. Plaintiffs address is 264 Henderson Street, Carlisle, Pennsylvania, 17013. 4. Defendant is believed to live at 4 West Main Street, Apartment #3, Newville, Pennsylvania. Defendant's Social Security Number is 166-52-4302. Defendant's date of birth is 9/30/64. Defendant's place of employment is Navy Depot, Mechanicsburg, Pennsylvania, 17055 and Pino's Pizza, 1 East Main Street, Newville. 5. Defendant is Plaintiffs husband. 6. Defendant has been involved in the following criminal court action: In or about 1997, Defendant was charged with terroristic threats and harassment by communication. In or about April 1997, Defendant was charged with Indirect Criminal Contempt for violation of a Protection From Abuse Order that was taken out by his first wife. 7. The facts of the most recent incident of abuse are as follows: On or about July 12, 1999, Defendant became angry at Plaintiff and hit her in the face several times which rendered her unconscious and she suffered convulsions for a short time. The doctor in the emergency room stated Plaintiff had a concussion and a closed head injury. Defendant was arrested and charged with simple assault. 8. Defendant has committed the following prior acts of abuse against Plaintiff a. In or about November 1998, Defendant grabbed Plaintiff by the arm and threw her across the bathroom floor causing rug burns on her knees. b. In or about June 1998, Defendant grabbed Plaintiff by her wrist, grabbed her leg, twisted it, and attempted to pull her out of the car. Defendant grabbed the trunk rack, pulled it off of the car, and threw it causing Plaintiff to fear for her safety. 9. 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: Carlisle Police Department and the Newville Police Department. 10. 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. Order Defendant to pay the costs of this action, including filing fees, service fees, and surcharge of $25.00. C. Order Defendant to pay $250.00 to reimburse one of Legal Services, Inc.'s funding sources for the cost of litigation in this case. D. Order the following additional relief, not listed above: a. Enjoin defendant from damaging, destroying, removing or selling any property owned jointly by the parties or owned solely by the plaintiff. b. The Enjoin defendant from harassing the plaintiffs relatives. E. Grant such other relief as the court deems appropriate. F. 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 petitioner 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, J Carey d Philip C. Briganti Attorneys for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 VERIFICATION I verify that I am the petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Dated: Z/3 Lq9 J - Jessica A Foose 2^ q M !1 ?? u ?? ???\ ?\ r ? ?._ ?\ '?v ? Ti' Jessica M. Foose, Plaintiff : IN THE COURT OF COMMON PLEAS OF vs. CUMBERLAND COUNTY, PENNSYLVANIA John E. Foose, NO. 99 - 4746 CIVIL TERM Defendant : PROTECTION FROM ABUSE PETITION TO VACATE ORDER Plaintiff requests the Court vacate the Final Protection From Abuse Order in the above- captioned case on the grounds that: 1 A Temporary Protection Order was issued by this Court on August 61 1999, scheduling a hearing for August 16, 1999, at 8:45a.m. 2. At this time Plaintiff requests that the Temporary Order entered on August 6, 1999, be vacated without prejudice. 3• A certified copy of this order will be sent to the Newville Police Department by Plaintiff s attorney. WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate the Order without prejudice. Respectfully submitted, AMrea Levy, ttorn or Plaintiff LEGAL SER S, 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. Dated: `M? Jessica M. Foose Jessica M. Foose, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 99 - 4746 CIVIL TERM John E. Foose, Defendant : PROTECTION FROM ABUSE ORDER OF COURT AND NOW, this 1444? day of August, 1999, upon consideration of the attached Petition, the Temporary Protection Order in the above captioned case dated August 6, 1999, is hereby vacated. A certified copy of this Order will be provided to the Newville Police Department by the plaintiffs attorney. By the Court -4 Edward E. Guido, Judge Joan Carey Attorney for Plaintiff `V (3 xS, (',, , ? 4°s P &/? 6 /? T. `,?i,.. „?1-7 .+ }^ , i '"E.. V .' ?. J I ?. _