HomeMy WebLinkAbout99-04912
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DOROTHY LOUISE ROSS,
Plaintiff
Vs.
DALE KEVIN CROOKS,
Defendant
:IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 99 - 4912 CIVIL TERM
:PROTECTION FROM ABUSE
FINAL ORDER OF COURT
Defendant's Name: Dale Kevin Crooks
Defendant's Date of Birth: 3/5/58
Defendant's Social Security Number: Unknown
Names of all Protected Persons: Dorothy Louise Ross
AND NOW, this ?-? day of September, 1999, the court having
jurisdiction over the parties and the subject-matter, it is
ORDERED, ADJUDGED, and DECREED as follows:
Plaintiff is represented by Joan Carey of LEGAL SERVICES, INC.;
Defendant is unrepresented but is aware of his right to have an
attorney. The parties agree that the following may be entered as
an Order of Court. Defendant, although agreeing that an Order
may be entered, does not admit to the allegation made in the
Petition.
? Plaintiff'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, 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 *[NONCONFIDENTIAL ADDRESS FROM WHICH DEFENDANT IS
EXCLUDED] or any other residence where Plaintiff may live.
Exclusive possession of the residence is granted to Plaintiff.
Defendant shall have no right or privilege to enter or be present
on the premises.
? On [Insert date and time], Defendant may enter the residence
to retrieve his/her clothing and other personal effects, provided
that Defendant is in the company of a law enforcement officer
when such retrieval is made.
® 3. 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
Pennsylvania Turnpike Commission, Harrisburg, Pennsylvania.
Defendant is specifically ordered to stay away from the following
locations for the duration of this Order: Plaintiff's residence
located at 4181 Elk Court, #107, Mechanicsburg, Cumberland
County, Pennsylvania, and any other residence Plaintiff may
establish.
0 4. Defendant shall not contact Plaintiff by telephone or by
any other means, including third parties.
? 5. Custody of the minor children, [names of the children
subject to the provision of this paragraph] shall be as follows:
[state to whom primary physical custody awarded; state terms of
partial custody or visitation, if any) (or see attached Custody
order)
? 6. Defendant shall immediately turn over to the Sheriff's
Office, or to a local law enforcement agency for delivery to the
Sheriffs 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.
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® S. The following additional
by 56108 of this Act:
relief is granted as authorized
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 Defendants 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).
4.11 Defendant represents a credible threat to the physical
safety of Plaintiff or other protected person(s) OR
? The terms of this order prohibit Defendant from using,
attempting to use, or threatening to use physical force against
Plaintiff or protected person that would reasonably be expected
to cause bodily injury.
® 13. THIS ORDER SUPERCEDES ® ANY PRIOR PFA ORDER AND ? ANY
PRIOR ORDER RELATING TO CHILD CUSTODY.
14. All provisions of this Order shall expire in one year.
NOTICE TO DEFENDANT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE
CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A
FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS.
23 PA.C.S. 56114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION
AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS
ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF
COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES, AND THE COMMONWEALTH OF
PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACTION, 18 U.S.C.
52265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY
VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL
PROCEEDINGS UNDER THAT ACT. 18 U.S.C. 55 2261-2262. IF
PARAGRAPH 12 OF THIS ORDER HAS BEEN CHECKED, YOU MAY BE SUBJECT
TO FEDERAL PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS
OF THE GUN CONTROL ACTION, 18 U.S.C. 5922(G), FOR POSSESSION,
TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over Plaintiff is residence
OR any location where a violation of this Order occurs OR where
Defendant may be located, shall enforce this Order. An arrest
for violation of Paragraphs 1 through 7 of this Order may be
without warrant, based solely on probable cause, whether or not
the violation is committed in the presence of the police. 23
Pa.C.S. 56113.
Subsequent to an arrest, the police officer shall seize all
weapons used or threatened to be used during the violation of the
Protection Order or during prior incidents of abuse. The [insert
the appropriate name or title] shall maintain possession of the
weapons until further Order of this Court. When Defendant is
placed under arrest for violation of the Order, Defendant shall
be taken to the appropriate authority or authorities before whom
Defendant is to be arraigned. A "Complaint for Indirect Criminal
Contempt" shall then be completed and signed by the police
officer OR Plaintiff, 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.
BY THE COURT,
Kevin Hess, Judge
If entered pursuant to the consent of Plaintiff and Defendant:
Dorothy oss, Plaintiff
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Dale Crooks, Defendant
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Joan arey (/
Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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DOROTHY LOUISE ROSS,
Plaintiff
VS.
DALE KEVIN CROOKS,
Defendant
:IN THE COURT OF COMMON PLEAS
:OF CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 99 - //k CIVIL TERM
:PROTECTION FROM ABUSE
NOTICE OF HEARING AND ORDER
YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims
not forth in the following papers, you must appear at the hearing scheduled
herein. If you fail to do so, the case may proceed against you and a FINAL
Order may be entered against you granting the relief requested in the
Petition. In particular, you may be evicted from your residence and lose
other important rights.
A hearing on this matter is scheduled for the 40 CA day of
August, 1999, at 3 .30 /).m., in Courtroom No. of the Cumberland
County Courthouse, Carlisle, Pennsylvania.
You MUST obey the Order that is attached until it is modified or
terminated by the court after notice and hearing. If you disobey this Order,
the police may arrest you. Violation of this Order may subject you to a
charge of indirect criminal contempt which is punishable by a fine of up to
$1,000.00 and/or up to six months in jail under 23 Pa.C.S. 56114. Violation
may also subject you to prosecution and criminal penalties under the
Pennsylvania Crimes Code. Under federal law, 18 D.S.C. 52265, this Order is
enforceable anywhere in the United States, tribal lands, U.S. Territories and
the Commonwealth of Puerto Rico. If you travel outside of the state and
intentionally violate this Order, you may be subject to federal criminal
proceedings under the Violence Against Women Act, 18 U.S.C. 52261-2262.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE THE RIGHT
TO HAVE A LAWYER REPRESENT YOU AT THE HEARING. 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 NUMBERt (717) 249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to
comply with the Americana with Disabilities Act of 1990. For information
about accessible facilities and reasonable accommodations available to
disabled individuals having business before the court, please contact our
office. All arrangements must be made at least 72 hours prior to any hearing
or business before the court. You must attend the scheduled conference or
hearing.
,. ,
DOROTHY LOUISE ROSS,
Plaintiff
V8.
DALE KEVIN CROOKS,
Defendant
IN THE COURT OF COMMON PLEAS
:OF CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 99 - CIVIL TERM
:PROTECTION FROM ABUSE
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name: Dale Kevin Crooks
Defendant's Date of Birth: 3/5/58
Defendant's Social Security Number: Unknown to Plaintiff
Name of Protected Person: Dorothy Louise Ross
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 Plaintiff's
residence located at , Cumberland County, Pennsylvania, (a
residence which is jointly owned/leased by the parties;
owned/leased :,y the entireties; owned/leased solely by
Plaintiff /Defendant to which Plaintiff and the minor child/ren
moved to avoid abuse, which is not owned or leased by the
Defendant, or any other permanent or temporary residence where
Plaintiff may live. Plaintiff is granted exclusive possession of
the residence. Defendant shall have no right or privilege to
enter or be present on the premises, except for the limited
purpose of transferring custody of the parties' child/ren.
Defendant shall remain in his vehicle at all times during the
transfer of custody.)
® 3. Defendant is prohibited from having ANY CONTACT with
Plaintiff at any location, including, but not limited to any
contact at Plaintiff's place of employment which is located at
the Pennsylvania Turnpike Commission, Harrisburg, Pennsylvania.
Defendant is specifically ordered to stay away from the following
locations for the duration of this order: Plaintiff's residence
located at 4181 Elk Court, #107, Mechanicsburg, Cumberland
County, Pennsylvania, a residence which is leased solely by
Plaintiff.
® 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:
Until the final hearing, all contact between Defendant and the
child/ren shall be limited to the following:
The local law enforcement agency in the jurisdiction where the
child/ren are located shall ensure that the child/ren are placed
in the care and control of Plaintiff in accordance with the terms
of this order.
? 6. Defendant shall immediately relinquish the following
weapons to the Sheriff is Office or a designated local law
enforcement agency for the delivery to the Sheriff fIs 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 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.
® S. A certified copy of this Order shall be provided to the
police department where Plaintiff resides and any other agency
specified hereafter: Hampden Township and Lower Swatara.
? 9. THIS ORDER SUPERSEDES D ANY PRIOR PFA ORDER AND O ANY PRIOR
ORDER RELATING TO CHILD CUSTODY
10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN
IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE
AND HEARING.
NOTICE TO DEFENDANT
Defendant is hereby notified that violation of this Order
may result in arrest for indirect criminal contempt, which is
punishable by a fine of up to $1,000.00 and/or up to six months
in jail. 23 Pa.C.S. 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 U.S.C. SS 2261-2262. Any protection order granted
by a court may be considered in any subsequent yroceedinas,
including child custody proceedings under title 23 (Domestic
Relations) of the Pennsylvania Consolidated Statutes.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This order shall be enforced by the police who have
jurisdiction over Plaintiff's residence OR any locations where a
violation of this order occurs OR where Defendant may be located.
If Defendant violates Paragraphs 1 through 6 of this Order,
Defendant may be arrested on the charge of Indirect Criminal
Contempt. An arrest for violation of this order may be made
without warrant, based solely on probable cause, whether or not
the violation is committed in the presence of law enforcement.
Subsequent to an arrest, the law enforcement officer shall
seize all weapons used or threatened to be used during the
violation of this Order OR during prior incidents of abuse.
Weapons must forthwith be delivered to the 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,
Judge
Joan Carey
Attorney for Plaintiff
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DOROTHY LOUISE ROSS,
Plaintiff
VS.
DALE KEVIN CROOKS,
Defendant
:IN THE COURT OF COMMON PLEAS
:OF CUMBERLAND COUNTY, PENNSYLV
NO. 99 - y9 /.z., CIVIL TERM
:PROTECTION FROM ABUSE
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiff's name is Dorothy Louise Ross.
2. The name of the person who seeks protection from abuse is
Dorothy Louise Ross.
3. Plaintiff's address is 4181 Elk Court, #107,
Mechanicsburg, Pennsylvania, 17055.
4. Defendant is believed to live at the following address:
469 Stacey Drive, King of Prussia, Pennsylvania 19406.
Defendant's Social Security Number is unknown to Plaintiff.
Defendant's date of birth is 3/5/58.
Defendant's place of employment is Costco Wholesale Company,
Mall Road, King of Prussia, Pennsylvania.
5. Defendant is Plaintiff's former intimate partner.
6. The facts of the most recent incident of abuse are as
follows:
On or about July 24, 1999, Defendant grabbed Plaintiff from
behind, threw her down, and restrained her by forcefully placing
his knees on her arms. Defendant slapped Plaintiff repeatedly in
the face until her nose began to bleed profusely. Defendant
choked Plaintiff and dragged her through the hallway.
Defendant's mother called 911. Plaintiff sought medical
treatment at Montgomery Hospital for injuries including bruises
to her arms, eye, and nose.
Since this incident, Defendant has called Plaintiff almost
daily, at times leaving 33 messages a day. Defendant also has
contacted Plaintiff's family and friends in an attempt to locate
her, causing her to fear for her safety.
7. Defendant has committed the following prior acts of abuse
against Plaintiff:
a. In or around July 1999, Defendant hit Plaintiff in
the side of her head.
b. In or around June 1999, Defendant grabbed Plaintiff
by her hair and shoved her face into the carpet causing
brush burns about her face.
c. Throughout their relationship since October 1998,
Defendant abused Plaintiff in ways including the following:
throwing, restraining, slapping, and choking her.
8. 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: Hampden Township and Lower
Swatara.
9. There is an immediate and present danger of further abuse
from the Defendant.
10. Plaintiff is asking the Court to order Defendant to stay
away from the residence at 4181 Elk Court, #107, Mechanicsburg,
Pennsylvania, which is rented by Plaintiff.
WHEREFORE, PLAINTIFF REQUESTS THAT THE COURT ENTER A TEMPORARY
ORDER, AND AFTER HEARING, A FINAL ORDER THAT WOULD DO THE
FOLLOWING:
A. Restrain Defendant from abusing, threatening, harassing, or
stalking Plaintiff in any place where Plaintiff may be found.
B. Order Defendant to stay away from Plaintiff's residence and
prohibit Defendant from attempting to enter any temporary or
permanent residence of Plaintiff.
C. Prohibit Defendant from having any contact with Plaintiff,
either in person, by telephone, or in writing, personally or
through third persons, including, but not limited to any contact
at Plaintiff's place of employment.
D. Prohibit Defendant from having any contact with Plaintiff's
relatives.
E. Order Defendant to pay the costs of this action, including
filing fees, service fees, and surcharge of $25.00.
F. Order Defendant to pay $250.00 to reimburse one of Legal
Services, Inc.'s funding sources for the cost of litigation in
this case.
G. 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.
H. 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,
oan Carey
Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
Dated:
I verify that I am the Plaintiff as designated in the present
action and that the facts and statements contained in the above
Petition are true and correct to the 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//O y /CriE? /. xi,
Dorothy oss, Plaintiff
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DOROTHY LOUISE ROSS,
PLAINTIFF
VS.
DALE KEVIN CROOKS,
DEFENDANT
IN THE COURT OF COMMON PLEAS
:OF CUMBERLAND COUNTY, PENNSYLVANIA
.NO. 99 - 4912 CIVIL TERM
:PROTECTION FROM ABUSE
ORDER FOR CONTINUANCE
AND NOW, this 19' day of August, 1999, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on August 20, 1999, by this Court's Order of August
13, 1999, is hereby rescheduled for hearing on 5evcrnher 3 , 1999, at 3.30 :P.m. in
Courtroom No. 3.
The Temporary Protection From Abuse Order shall remain in effect for a period of one year
from the date it was entered or until further Order of Court, whichever comes first.
Certified copies of this Order for Continuance will be provided to the Lower Swatara Police.
and Hampden Township Police Departments by the plaintiffs attorney.
By the Court,
A. Hess, Judge
Kevjti 7
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
99 Vr I y Pli J: 12
-WNIY
PEiNN'Sl'Lw,aVA
DOROTHY LOUISE ROSS,
PLAINTIFF
VS.
DALE KEVIN CROOKS,
DEFENDANT
:IN THE COURT OF COMMON PLEAS
OF CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 99 - 4912 CIVIL TERM
:PROTECTION FROM ABUSE
MOTION FOR CONTINUANCE
The Plaintiff, Dorthy Ross, by and through her attorney, Joan Carey of Legal Services, Inc.,
moves the Court for an Order rescheduling the hearing in the above-captioned case on the grounds
that:
1. A Temporary Protection From Abuse Order was issued by this Court on August 13,
1999, scheduling a hearing for August 20, 1999, at 3:30 p.m.
2. The Cumberland County Sheri ff s Department has deputized the Montgomery County
Sheriffs Department to serve the Temporary Protection From Abuse Order and Petition on
Defendant. The Defendant has not yet been served with the Order and Petition.
3. The Plaintiff requests that the Temporary Protection From Abuse Order remain in
effect for a period of one year from the date it was entered or until further Order ofCourt, whichever
comes first.
4. Certified copies of the Order For Continuance will be delivered to the Lower Swatara
Police and Hampden Township Police Departments by the attorney for the Plaintiff.
WHEREFORE, the Plaintiff requests that the Court grant this Motion reschedule this matter
for hearing, and that the Temporary Protection From Abuse Order remain in effect for a period of
one year from the date it was entered or until further Order of Court, whichever comes first.
Respectfully submitted,
Joan Carey'
Philip C. Briganti U
Attorneys for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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CASE NO: 1999-04912 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ROSS DOROTHY LOUISE
VS.
CROOKS DALE KEVIN
R. Thomas Kline Sheriff, who being duly sworn according
to law, says, that he made a diligent search and inquiry for the within
named defendant, to wit: CROOKS DALE KEVIN
but was unable to locate Him in his bailiwick. He therefore
deputized the sheriff of MONTGOMERY COUNTY County, Pennsylvania.
to serve the within PROTECTION FROM ABUSE
On August 27th 1999 , this office was in receipt of
the attached return from MONTGOMERY COUNTY County, Pennsylvania.
Sheriff's Costs: So answers:
Docketing 18.00 !? ` >
Out of County 9.00 Surcharge 8.00 RT-I om s in 5 eri
$3b. uu 00/00/0000
Sworn and subscribed to before me
this ,27 4SZ day of
19 99 A. D.
C ,i
??rotToni?o'f-ary'&
SHERIFF'S RETURN
PROTHONOTARY # :V- 3748
DEFENDANT : Dale Kevin Crooks
DOCUMENT SERVED : PFA
INDIVIDUAL SERVED :Dale Crooks
RELATIONSHIP TO DEFENDANT-: Defendant
DATE AND PREVAILING TIME-:August 19,1999 @ 14:30
LOCATION : Costco Wholesale Company, Mall Road,
King of Prussia, PA
THE ABOVE DOCUMENT WAS SERVED ON THE DEFENDANT AS PER
INFORMATION LISTED ABOVE IN THE COUNTY OF MONTGOMERY,
COMMONWEALTH OF PENNSYLVANIA.
AFFIRMED AND SUBSCRIBED BEFORE ME ON SO ANSWERS,
THIS DAY. August 24,1999
?z?dG ? .?aEEew
NOTAR PUBLIC
NOTARIAL SEAL
H?1.ENE FRIEDMAN, Notary Public
Fl,,istown, Montgomery o., PA
y My Comm!sslon hupires ADril 1, 2000
FRANK P. LALLEY
SHERIFF OF MONTGOMERY
Cavaliere/BeEd
DEPUTY SHERIIFFFF?
In The Court of Common Pleas of Cumberland County, Pennsylvania
Dorothy Louise Ross
VS.,
Dale Kevin Crooks
No. 99-4912 Civil
Now, 8/19/99 19____,, I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Montgomery County to execute Pis Writ, this
deputation being made at the request and risk of the Plaintiff,
Sheriff of Cumberland County, PA
Affidavit of Service
Now, at /1/ 5 v o'clock P M. served the
within U N rC? a r! e ? '?a . ;J
upon e. Cw s
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by handing to'T. Cy, r,;
a 1u e copy of the original
and made known to the contents thereof.
Au -je So answers,
( ?C Q ?pty1?? {
3(ni ` 2t , -,"rl u s S , •, , :, Sheriff of -/17 , C u ,y r , r --County. PA
o,v ` I).a i ? ?? s r?`"I f
COSTS
Sworn and subscribed before SERVICE
me this _ day of _ , 19_ MILEAGE
AFFIDAVIT
DOROTHY ROSS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
99-4912 CIVIL
DALE CROOKS,
Defendant CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this r t day of December, 1999, this Court certifies that the
attached complaint has been properly completed and verified, and there is probable cause
for the issuance of process. In consideration of the attached Commonwealth's Petition,
the defendant, DALE CROOKS, is directed to appear for trial on the charge of Indirect
4W
Criminal Contempt before the Court on the `? _ day of 1999 at
o'clock a.m. in Courtroom # -?/ of the Cumberland County Courthouse, Carlisle,
Pennsylvania.
The defendant has a right to be represented by an attorney. If the defendant
cannot afford an attorney, upon request one will be assigned to represent the defendant.
If the defendant wishes assignment of counsel, contact should be made prior to trial with
the Cumberland County Public Defender's Office at 717-240-6285. Further, if the
defendant fails to appear, an an-est warrant will be issued.
The Sheriff of Cumberland County is directed to serve this Order and Petition
upon the defendant. The assessment of costs to be determined by the Trial Judge
subsequent to trial.
Jonathan R. Birbeck,
Chief Deputy District Attorney
By the Court, //?? `l
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Kev' A. Hess J.
DALE CROOKS
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DOROTHY ROSS, : IN THE COURT OF COMMON PLEASOF
Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA
V. :99-4912 CIVIL
DALE CROOKS,
Defendant
CHARGE: INDIRECT CRIMINAL CONTEMPT
COMMONWEALTH'S PETITION FOR A HEARING ON CHARGES
OF INDIRECT CRIMINAL CONTEMPT
Jonathan R. Birbeck, Chief Deputy District Attorney of Cumberland County,
Pennsylvania, brings the following Petition for a hearing on charges of Indirect Criminal
Contempt:
1. A Protection from Abuse Order was issued by the Court. A true and correct
copy of the Order is attached.
2. The defendant's violation of this Order is averred in the attached criminal
complaint.
3. The victim requests the filing of an Indirect Criminal Contempt Charge.
4. The District Attorney's Office approves the filing of this criminal complaint.
5. The Commonwealth is requesting a hearing on the charges of Indirect
Criminal Contempt pursuant to 23 Pa.C.S.A. § 6113.
6. The plaintiff and/or the defendant may seek modification of the Order based
on the filing of this petition as the Court deems appropriate following the trial
in addition to any other sentence. 23 Pa.C.S.A. § 6113.
WHEREFORE, the Commonwealth requests the defendant be commanded to
appear before the Court on the charge of Indirect Criminal Contempt.
Respectfully
99 DEC - I Ni 2'. 39
cum-:.t.-, c cou,nr
PEN,i,;? 2vrNw
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF Cpl IBFRt AND
D). Name It.., COMMONWEALTH OFI
Add1fe CUMBERLAND COUNTY
COURTHOUSE
CARLISLE, PA 17013
Teleplhme.
Date Filed:
OTN:
COMMONWEALTH OF PENNSYLVANIA
VS.
DEFENDANT:
NAME and ADDRESS
DALE CROOKS
468 STACEY DRIVE
KING OF PRUSSIA, PA 19406
(Nome o Altomey fa the Commonwealth - Pleuc Prim or Type) (Signature o'All-q for CommonwealN)
at,,
1' Defective Le?Jtia R. Woodford
Name of ARanl -Please Print or Type 49-8
Ofre., Badge Numbcr/t. D.
OF Cumberland Counm nferr:,e e.<,....a.r.. nm.__ _.-._, .-_.... _.. - -
doherebystate: (check nppraprinfc Wren)
® 1 accuse the above named defendant, who lives at the address set forth above or,
? 1 accuse the defendant whose name in unknown to me but is described as
? 1 accuse the defendant whose name and popular designation or nickname is unknown to me and whom I have therefor designated as
John Doe.
with violating the penal laws of the Commonwealth of Pennsylvania at 81"ine Row, Carlisle, PA in Cumberland County on or about
November 4, 1999.
Part icipants were: (tfthem were participants, place their names here, creating name of above defendant)
DALE CROOKS
2. The acts committed by the accused were:
(Set Fanha rummeryofthe fxurulricienttoudviseede oft henaur<oflhcoRemecharged Acimtionm WC emwm nll<gdly violamd, without morc,irnotsulfcient Inammmaryeuse,yoummtcile
Werpc<iac action and mbumion ofWeminute or mdinone allegedly viola MJ
INDIRECT CRIMINAL CONTEMPT - 23 Pa. C.S. §6114
Actor did violate a Protection From Abuse order signed by a Pennsylvania Court of Common Pleas
Judge.
Victim: Dorothy Ross
PFA Order Number and Date of Issue: 994912
POLICE
CRIMINAL COMPLAINT
Violation committed. Defendant did forward a letter to Legal Services, specifically Joan Carey, Esq.
Enclosed with the letter was a check for $70.00 made payable to Dorothy L. Ross. In the memo area
on the front of the check, the Defendant wrote the following message to the Plaintiff, "I think of you
every waking moment."
------.--._-+ - --..- IJ .epprvvem U utsapproved because:
(The District Attorney may require that the complaint, anest warrant affidavit, or both be approved by the Attorney for the Commonwealth priorto riling. Pa.R.Cr.P. 107.)
Defendant Name: DALE CROOKS
Docket Number:
4& POLICE
CRIMINAL COMPLAINT
all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of Assembly, or in violation of
1• 6114 of the 13 PA
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3. 1 ask that 0 a warrant ajarresr or Z a summons be issued and that the defendant be required to answer the charges I have made. (In
order for a warrant of arrest to issue, the attached affidavit of probable cause must be completed and sworn to before the issuing authority.)
4. 1 verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information and belief This verification is
??m,,a?d'?e1subj'ect to the penalties of Section 4904 of the Crimes Code (18 PA. C.S. 4904) relating to unswornalsifications to authorities.
M(Dade) ctq1
(Slitnatur of Comphlnanq
AND NOW, on this date , I ee ?ifyhe complaint has been properly completed and verified. An affidavit
of probable cause must be completed in order for a warrant to issue.
Waglaterial Diatricl)
(1uulne Authority)
(SEAL)
2
AFFIDAVIT OF PROBABLE CAUSE COMPLAINT NUMBER YEAR TYPE NUMBER
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
Detective Letitia R. Woodford
(Name of Affiant)
OTN
COMMONWEALTH OF PENNSYLVANIA
DEFENDANT: VS,
NAME DALECROOKS
AND 468 STACEY DRIVE
ADDRESS KING OF PRUSSIA, PA 19406
of Cumberland County District Attorney's Office, Criminal Investigation Division
(Identify department or agency represented and political subdivision)
being duly swom (or affirmed) before me, according to law, deposes and says that there is probable cause to believe that:
PROBABLE CAUSE BELIEF IS BASED ON THE FOLLOWING FACTS AND CIRCUMSTANCES:
Your affiant is a Detective in the Cumberland County District Attorney's Office, Criminal Investigation Division and has
been so employed for the past 2 years.
On or about November 4, 1999, Legal Services, Inc., located at 8 Irvine Row, Carlisle, PA 17013, specifically, Attorney
Joan Carey, received a letter signed by Dale K. Crooks and dated November 1, 1999. Enclosed with this letter was a personal check,
#136, made payable to the order of Dorothy L. Ross in the amount of $70.00. Handwritten in the memo section of this check were
the words, "I think of you every waking moment." This check was signed by Dale K. Crooks. Legal Services, Inc., according to their
operating procedures were required to forward this check to the Plaintiff. Plaintiff is currently in possession of this check.
This is in direct violation of Paragraph #4 of Final Protection Order, 99-4912, signed by the Honorable Kevin A. Hess on
September 3, 1999, pursuant to the consent of the Plaintiff and Defendant. Paragraph #4 states the following: "Defendant shall not
contact Plaintiff by telephone or by any other means, including third parties.
In lieu of the details outlined above, I respectfully request the Defendant be summoned to appear before this Court on a
charge of Indirect Criminal Contempt.
Sworn to and subscribed before me this day of
(Signature of Issuing Authority)
DISTRICT JUSTICE COURT NO.
Date Commission Expires:
Complaint Numbers if Other Participants
INCIDENT NUMBER UCR NO.
99-1505 260
OFFICE ADDRESS:
Phone:
(SEAL)
,19
DOROTHY LOUISE ROSS,
Plaintiff
Vs.
DALE KEVIN CROOKS,
Defendant
IN THE COURT OF COMMON PLEAS
:OF CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 99 - 4912 CIVIL TERM
:PROTECTION FROM ABUSE
FINAL ORDER OF COURT
Defendant's Name: Dale Kevin Crooks
Defendant's Date of Birth: 3/5/58
Defendant's Social Security Number: Unknown
Names of all Protected Persons: Dorothy Louise Ross
AND NOW, this ? ? day of September, 1999, the court having
jurisdiction over the parties and the subject-matter, it is
ORDERED, ADJUDGED, and DECREED as follows:
Plaintiff is represented by Joan Carey of LEGAL SERVICES, INC.;
Defendant is unrepresented but is aware of his right to have an
attorney. The parties agree that the following may be entered as
an Order of Court. Defendant, although agreeing that an order
may be entered, does not admit to the allegation made in the
Petition.
? Plaintiff's request for a Final Protection Order is denied OR
0 Plaintiff's request for a Final Protection order is granted.
® 1. Defendant shall not abuse, stalk, harass, threaten
Plaintiff or any other protected person in any place where they
might be found.
? 2. Defendant is completely evicted and excluded from the
residence at *[NONCONFIDENTIAL ADDRESS FROM WHICH DEFENDANT IS
EXCLUDED] or any other residence where Plaintiff may live.
Exclusive possession of the residence is granted to Plaintiff.
Defendant shall have no right or privilege to enter or be present
on the premises.
? On [insert date and time], Defendant may enter the residence
to retrieve his/her clothing and other personal effects, provided
that Defendant is in the company of a law enforcement officer
when such retrieval is made.
® 3. Defendant is prohibited from having ANY CONTACT with
Plaintiff at any location, including, but not limited to any
contact at Plaintiff's place of employment, located at the
Pennsylvania Turnpike Commission, Harrisburg, Pennsylvania.
Defendant is specifically ordered to stay away from the following
locations for the duration of this Order: Plaintiff's residence
located at 4181 Elk Court, #107, Mechanicsburg, Cumberland
County, Pennsylvania, and any other residence Plaintiff may
establish.
® 4. Defendant shall not contact Plaintiff by telephone or by
any other means, including third parties.
? 5. Custody of the minor children, [names of the children
subject to the provision of this paragraph] shall be as follows:
[state to whom primary physical custody awarded; state terms of
partial custody or visitation, if any](or see attached custody
order)
? 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.
® S. The following additional relief is granted as authorized
by 96108 of this Act:
a. This Order shall remain in effect until modified or
terminated by the Court and can be extended beyond its original
expiration date if the Court finds that Defendant has committed
another act of abuse or has engaged in a pattern or practice that
indicates continued risk of harm to Plaintiff.
b. Defendant is enjoined from damaging or destroying any
property owned jointly by the parties or owned solely by
Plaintiff.
C. Defendant is to refrain from harassing Plaintiff's
relatives.
d. The court costs and fees are waived.
? 9. Defendant is directed to pay temporary support for [insert
the names of the persons for whom support is to be paid]
as follows: [insert amount,
frequency and other terms and conditions of the support order]
This Order for support shall remain in effect
until a final support order is entered by this Court. However,
this Order shall lapse automatically if Plaintiff does not file a
complaint for support with the Court within fifteen days of the
date of this Order. The amount of this temporary order does not
necessarily reflect Defendant's correct support obligation, which
shall be determined in accordance with the guidelines at the
support hearing. Any adjustments in the final amount of support
shall be credited, retroactive to this date, to the appropriate
party.
? 10. The costs of this action are waived as to Plaintiff and
imposed on Defendant.
? 11. Defendant shall pay $* to Plaintiff as compensation for
Plaintiff's out-of-pocket losses, which are as follows:
OR
? Plaintiff is granted leave to present a petition, with
appropriate notice to Defendant, to [insert the name of the judge
or court to which the petition should be presented] requesting
recovery of out-of-pocket losses. The petition shall include an
exhibit itemizing all claimed out-of-pocket losses, copies of all
bills and estimates of repair, and an Order scheduling a hearing.
No fee shall be required by the Prothonotary's office for the
filing of this petition.
? 12. BRADY INDICATOR
1.0 Plaintiff or protected person(s) is a spouse, former spouse,
a person who cohabitates or has cohabited with Defendant, a
parent of a common child, a child of that person, or a child of
Defendant.
2.0 This order is being entered after a hearing of which
Defendant received actual notice and had an opportunity to be
heard.
3.0 Paragraph 1 of this order has been checked to restrain
Defendant from harassing, stalking, or threatening Plaintiff or
protected person(s).
4.0 Defendant represents a credible threat to the physical
safety of Plaintiff or other protected person(s) OR
? The terms of this order prohibit Defendant from using,
attempting to use, or threatening to use physical force against
Plaintiff or protected person that would reasonably be expected
to cause bodily injury.
® 13. THIS ORDER SUPERCEDES ® ANY PRIOR PFA ORDER AND 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. 56114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION
AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS
ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF
COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES, AND THE COMMONWEALTH OF
PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACTION, 18 U.S.C.
52265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY
VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL
PROCEEDINGS UNDER THAT ACT. 18 U.S.C. SS 2261-2262. IF
PARAGRAPH 12 OF THIS ORDER HAS SEEN CHECKED, YOU MAY BE SUBJECT
TO FEDERAL PROSECUTION AND PENALTIES UNDER THE 'OBRADY" PROVISIONS
OF THE GUN CONTROL ACTION, 18 U.S.C. 5922(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. 56113.
Subsequent to an arrest, the police officer shall seize all
weapons used or threatened to be used during the violation of the
Protection Order or during prior incidents of abuse. The [insert
the appropriate name or title] shall maintain postsession 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.
BY THE COURT,
1? fI
Kevin . Hess, Judge
If entered pursuant to the consent of Plaintiff and Defendant:
Dorothy oss, Plaintiff
>16? x ?J
Dale Crooks, Defendant
Joan arey
Attorney for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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DOROTHY ROSS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
99-4912 CIVIL
DALE CROOKS,
Defendant CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this 1, day of December, 1999, this Court certifies that the
attached complaint has been properly completed and verified, and there is probable cause
for the issuance of process. In consideration of the attached Commonwealth's Petition,
the defendant, DALE CRnnTCC ic rlirartPrl M onnoor fi,r tA: l ,,,, 0- charge of Indirect
Criminal Contempt be& .LZ, 1999 at
-?b o'clock m. in ( Courthouse, Carlisle,
d
Pennsylvania. Th
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ant
, \? the defendant
cannot afford an attorne sent the defendant.
If the defendant wishes p Je prior to trial with
the Cumberland County
defendant fails to appea Further, if the
The Sheri 'f of C rder and Petition
upon the defendant. Th, : Trial Judge
subsequent to trial.
By the Court,
l ?' I K(/U18 6L • #w40
Kevin A. Hess J.
Jonathan R. Birbeck,
Chief Deputy District Attorney
DALECROOKS TRUE CGPY 090
to To."titrorvy t+rh + gip, i r~Afe ua;., ??st my hang
and t 1 11, oa! C11 Ca_disie, Pa.
T4
d o (PeJ2c- 1
honotary
DOROTHY ROSS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
99-4912 CIVIL
DALE CROOKS,
Defendant CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this ? day of December, 1999, this Court certifies that the
attached complaint has been properly completed and verified, and there is probable cause
for the issuance of process. In consideration of the attached Commonwealth's Petition,
the defendant, DALE CROOKS, is directed to appear for trial on the charge of Indirect
Criminal Contempt before the Court on the tt- day ofN t '(L, 1999 at
3 -06 o'clock ?.m. in Courtroom # of the Cumberland County Courthouse, Carlisle,
Pennsylvania.
The defendant has a right to be represented by an attorney. If the defendant
cannot afford an attorney, upon request one will be assigned to represent the defendant.
If the defendant wishes assignment of counsel, contact should be made prior to trial with
the Cumberland County Public Defender's Office at 717-240-6285. Further, if the
defendant fails to appear, an arrest warrant will be issued.
The Sheriff of Cumberland County is directed to serve this Order and Petition
upon the defendant. The assessment of costs to be determined by the Trial Judge
subsequent to trial.
By the Court,
(s( K("Ij/n a- • ka)
Kevin A. Hess J.
Jonathan R. Birbeck,
Chief Deputy District Attorney
DALE CROOKS TRUE C•t -Py FP Wi r'- ORD
to Tavtitlwlvy irha+ W , i twflt ua;n ser my hana
and t r seal " sat ^a;u t i t;a?isle, Pa.
ihl d 19-•
honotary
DOROTHY ROSS, : IN THE COURT OF COMMON PLEASOF
Plaintiff : CUMBERLAND COUNTY. PENNSYLVANIA
V. :99-4912 CIVIL
DALE CROOKS,
Defendant
CHARGE: INDIRECT CRIMINAL CONTEMPT
COMMONWEALTH'S PETITION FOR A HEARING ON CHARGES
OF INDIRECT CRIMINAL CONTEMPT
Jonathan R. Birbeck, Chief Deputy District Attorney of Cumberland County,
Pennsylvania, brings the following Petition for a hearing on charges of Indirect Criminal
Contempt:
1. A Protection from Abuse Order was issued by the Court. A true and correct
copy of the Order is attached.
2. The defendant's violation of this Order is averred in the attached criminal
complaint.
3. The victim requests the filing of an Indirect Criminal Contempt Charge.
4. The District Attorney's Office approves the filing of this criminal complaint.
5. The Commonwealth is requesting a hearing on the charges of Indirect
Criminal Contempt pursuant to 23 Pa.C.S.A. § 6113.
6. The plaintiff and/or the defendant may seek modification of the Order based
on the filing of this petition as the Court deems appropriate following the trial
in addition to any other sentence. 23 Pa.C.S.A. § 6113.
WHEREFORE, the Commonwealth requests the defendant be commanded to
appear before the Court on the charge of Indirect Criminal Contempt.
Respectfully
Deputy
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DIN.. If.. COMMONWEALTH OFPENNSYLV
AdI CUMBERLAND COUNTY
COURTHOUSE
CARLISLE, PA 17013
Telephone:
Date Filed:
OTN:
COMMONWEALTH OF PENNSYLVANIA
VS.
DEPENDANT:
NAME and ADDRM
DALE CROOKS
468 STACEY DRIVE
KING OF PRUSSIA, PA 19406
ame Am,ney or Comntmw -Pam Pont or ypa) (Stpiaurt Ananry wCamnwnweiN)
IDae)
1, Detective Letitia R. Woodford 49-8
Name of Arrant- Pleae Print or Type Omcer Badge NnmbrA.D.
OF Cumberland County District Attorney's Office, Criminal Investigation Division PA021013A
,=c DepeDrant or Agency Represented and Political Stabdivis oat Police Agency ORl Number Originating Agency Case Number(OCA)
do hereby state: (check appropriate area)
® 1 accuse the above named defendant, who lives at the address set forth above or,
? 1 accuse the defendant whose name in unknown to me but is described as
? 1 accuse the defendant whose name and popular designation or nickname is unknown to me and whom I have therefor designated as
John Doe.
with violating the penal laws of the Commonwealth of Pennsylvania at 8Inine Row, Carlisle, PA in Cumberland County on or about
November 4, 1999.
Participants were: (if them were participants, place their runes here, repeating name of above defendant)
DALE CROOKS
The acts committed by the accused were:
(Set FaMammmay ofthe fats alriaient to advise the defendant ofthe tatne f1h, onrese changed Acitation to thesumm allegedly violated. without more. is not sufficient. rnasummatycac,yourrutcite
the spaific ecNm and aub,ztian afthe ataute a ardinence allegedly violatN.)
INDIRECT CRIMINAL CONTEMPT -13 Pa. C.S. §6114
Actor did violate a Protection From Abuse order signed by a Pennsylvania Court of Common Pleas
Judge.
Victim: Dorothy Ross
PFA Order Number and Date of Issue: 994912
POLICE
CRIMINAL COMPLAINT
Violation Committed. Defendant did forward a letter to Legal Services, specifically Joan Carey, Esq.
Enclosed with the letter was a check for $70.00 made payable to Dorothy L. Ross. In the memo area
on the front of the check, the Defendant wrote the following message to the Plaintiff, "I think of you
every waking moment."
District Attorney's Office ? Approved ? Disapproved because:
(The District Attorney may require that the complaint, artedt warrant afrtdavit, or both be approved by the Attorney for the Commonwealth prior to filing. Pa.P O.P. 107.)
Defendant Name: DALE CROOKS POLICE
Docket Number:
ait CRIMINAL COMPLAINT
all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of Assembly, or in violation of:
1. 6114 of the 23 PA. C.S. 1
kn? (PA InlWel 1 0M G)Y)
2. of the
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3. 1 ask that Q a rvarrant ojarrest or ® a summons be issued and that the defendant be required to answer the charges I have made. (In
order for a warrant of arrest to issue, the attached affidavit of probable cause must be completed and swom to before the issuing authority.)
4. I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information and belief. This verification is
?made subject to the penalties of Section 4904 of the Crimes Code (18 PA. C.S. 4904) relating to unswom alsiftcations to authorities.
(u re/ (S Lnrtu of Ca02.-eQ
AND NOW, on this date , I ce ify the complaint has been properly completed and verified. An affidavit
of probable cause must be completed in order for a warrant to issue.
(Maginarlal Dhtdcp (Druing Authority) (SEAL)
AFFIDAVIT OF PROBABLE CAUSE COMPLAINT NUMBER YEAR TYPE NUMBER
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
OTN
COMMONWEALTH OF PENNSYLVANIA
DEFENDANT: VS.
NAME DALECROOKS
AND 468 STACEY DRIVE
I, Detective Letitia R. Woodford ADDRESS KING OF PRUSSIA, PA 19406
(Name of Affront)
of Cumberland County District Attorney's Office, Criminal Investigation Division
(Identify department or agency represented and political subdivision)
being duly sworn (or affnned) before me, according to law, deposes and says that there is probable cause to believe that:
PROBABLE CAUSE BELIEF IS BASED ON THE FOLLOWING FACTS AND CIRCUMSTANCES:
Your affiant is a Detective in the Cumberland County District Attorney's Office, Criminal Investigation Division and has
been so employed for the past 2 years.
On or about November 4, 1999, Legal Services, Inc., located at 8 Irvine Row, Carlisle, PA 17013, specifically, Attorney
Joan Carey, received a letter signed by Dale K. Crooks and dated November 1, 1999. Enclosed with this letter was a personal check,
#136, made payable to the order of Dorothy L. Ross in the amount of $70.00. Hand written in the memo section of this check were
the words, "I think of you every waking moment." This check was signed by Dale K. Crooks. Legal Services, Inc., according to their
operating procedures were required to forward this check to the Plaintiff. Plaintiff is currently in possession of this check.
This is in direct violation of Paragraph #4 of Final Protection Order, 99-4912, signed by the Honorable Kevin A. Hess on
September 3, 1999, pursuant to the consent of the Plaintiff and Defendant. Paragraph #4 states the following: "Defendant shall not
contact Plaintiff by telephone or by any other means, including third parties.
In lieu of the details outlined above, I respectfully request the Defendant be summoned to appear before this Court on a
charge of Indirect Criminal Contempt.
Sworn to and subscribed before me this day of
(Signature of Issuing Authority)
DISTRICT JUSTICE COURT NO.
Date Commission Expires:
Complaint Numbers if Other Participants
INCIDENT NUMBER UCR NO.
99-1505 260
OFFICE ADDRESS:
Phone:
(SEAL)
19
DOROTHY LOUISE ROSS,
Plaintiff
Va.
DALE KEVIN CROOKS,
Defendant
:IN THE COURT OF COMMON PLEAS
:OF CUMBERLAND COUNTY, PENNSYLVANIA
:NO. 99 - 4912 CIVIL TERM
:PROTECTION FROM ABUSE
FINAL ORDER OF COURT
Defendant's Name: Dale Kevin Crooke
Defendant's Date of Birth: 3/5/58
Defendant's Social Security Number: Unknown
Names of all Protected Persons: Dorothy Louise Ross
AND NOW, this 3 day of September, 1999, the court having
jurisdiction over the parties and the subject-matter, it is
ORDERED, ADJUDGED, and DECREED as follows:
Plaintiff is represented by Joan Carey of LEGAL SERVICES, INC.;
Defendant is unrepresented but is aware of his right to have an
attorney. The parties agree that the following may be entered as
an Order of Court. Defendant, although agreeing that an order
may be entered, does not admit to the allegation made in the
Petition.
? Plaintiff'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, 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 *[NONCONFIDENTIAL ADDRESS FROM WHICH DEFENDANT IS
EXCLUDED] or any other residence where Plaintiff may live.
Exclusive possession of the residence is granted to Plaintiff.
Defendant shall have no right or privilege to enter or be present
on the premises.
? On [Insert date and time], Defendant may enter the residence
to retrieve his/her clothing and other personal effects, provided
that Defendant is in the company of a law enforcement officer
when such retrieval is made.
® 3. Defendant is prohibited from having ANY CONTACT with
Plaintiff at any location, including, but not limited to any
contact at Plaintiff 'a place of employment, located at the
Pennsylvania Turnpike Commission, Harrisburg, Pennsylvania.
Defendant is specifically ordered to stay away from the following
locations for the duration of this order: Plaintiff's residence
located at 4181 Elk Court, #107, Mechanicsburg, Cumberland
County, Pennsylvania, and any other residence Plaintiff may
establish.
® 4. Defendant shall not contact Plaintiff by telephone or by
any other means, including third parties.
? 5. Custody of the minor children, [names of the children
subject to the provision of this paragraph]. shall be as follows:
[state to whom primary physical custody awarded; state terms of
partial custody or visitation, if any] (or see attached Custody
order)
? 6. Defendant shall immediately turn over to the Sheriff's
office, or to a local law enforcement agency for delivery to the
Sheriffs 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.
N S. The following additional relief is granted as authorized
by 56108 of this Act:
a. This Order shall remain in effect until modified or
terminated by the Court and can be extended beyond its original
expiration date if the Court finds that Defendant has committed
another act of abuse or has engaged in a pattern or practice that
indicates continued risk of harm to Plaintiff.
b. Defendant is enjoined from damaging or destroying any
property owned jointly by the parties or owned solely by
Plaintiff.
C. Defendant is to refrain from harassing Plaintiff's
relatives.
d. The court costs and fees are waived.
? 9. Defendant is directed to pay temporary support for [insert
the names of the persons for whom support is to be paid]
as follows: [insert amount,
frequency and other terms and conditions of the support order]
This order for support shall remain in effect
until a final support order is entered by this Court. However,
this Order shall lapse automatically if Plaintiff does not file a
complaint for support with the Court within fifteen days of the
date of this order. The amount of this temporary order does not
necessarily reflect Defendant's correct support obligation, which
shall be determined in accordance with the guidelines at the
support hearing. Any adjustments in the final amount of support
shall be credited, retroactive to this date, to the appropriate
party.
? 10. The costs of this action are waived as to Plaintiff and
imposed on Defendant.
? 11. Defendant shall pay $* to Plaintiff as compensation for
Plaintiff's out-of-pocket losses, which are as follows:
OR
? Plaintiff is granted leave to present a petition, with
appropriate notice to Defendant, to (insert the name of the judge
or court to which the petition should be presented] requesting
recovery of out-of-pocket losses. The petition shall include an
exhibit itemizing all claimed out-of-pocket losses, copies of all
bills and estimates of repair, and an Order scheduling a hearing.
No fee shall be required by the Prothonotary's office for the
filing of this petition.
? 12. BRADY INDICATOR
1.0 Plaintiff or protected person(s) is a spouse, former spouse,
a person who cohabitates or has cohabited with Defendant, a
parent of a common child, a child of that person, or a child of
Defendant.
2.0 This order is being entered after a hearing of which
Defendant received actual notice and had an opportunity to be
heard.
3.0 Paragraph 1 of this order has been checked to restrain
Defendant from harassing, stalking, or threatening Plaintiff or
protected person(s).
4.0 Defendant represents a credible threat to the physical
safety of Plaintiff or other protected person(s) OR
? The terms of this Order prohibit Defendant from using,
attempting to use, or threatening to use physical force against
Plaintiff or protected person that would reasonably be expected
to cause bodily injury.
® 13. THIS ORDER SUPERCEDES ® ANY PRIOR PFA ORDER AND ? ANY
PRIOR ORDER RELATING TO CHILD CUSTODY.
14. All provisions of this Order shall expire in one year.
NOTICE TO DEFENDANT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE
CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A
FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS.
23 PA.C.S. 56114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION
AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS
ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF
COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES, AND THE COMMONWEALTH OF
PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACTION, 18 U.S.C.
52265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY
VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL
PROCEEDINGS UNDER THAT ACT. 18 U.S.C. SS 2261-2262. IF
PARAGRAPH 12 OF THIS ORDER HAS BEEN CHECKED, YOU MAY BE SUBJECT
TO FEDERAL PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS
OF THE GUN CONTROL ACTION, 18 U.S.C. 5922(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. 56113.
Subsequent to an arrest, the police officer shall seize all
weapons used or threatened to be used during the violation of the
Protection Order or during prior incidents of abuse. The [insert
the appropriate name or title] shall maintain possession of the
weapons until further Order of this Court. When Defendant is
placed under arrest for violation of the Order, Defendant shall
be taken to the appropriate authority or authorities before whom
Defendant is to be arraigned. A "Complaint for Indirect Criminal
Contempt" shall then be completed and signed by the police
officer OR Plaintiff, 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.
BY THE COURT,
Kevin Hess, Judge
If entered pursuant to the consent of Plaintiff and Defendant:
Dorothy oss, Plaintiff
Dale Crooks, Defendant
L/G cey
Joan arey Q,/^
Attorney for Plaintiff
LEGAL SERVICES, INC.
S Irvine Row
Carlisle, PA 17013
(717) 243-9400
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LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, Pennsylvania 17013
(717) 243-9400
Fax (717) 243-8026
West Shore (717) 766.8475
Shippensburg (717) 530-5866
November 10, 1999
Dorothy Ross
4181 Elk Court, #107
Mechanicsburg, PA 17055
RE: Ross v. Crooks
No. 994912 Civil Term
Protection From Abuse
Dear Dorothy:
Frxnhlin Faun We
C.bxmkMUry 14nnylvsNe 17x11
(719) %6534
432 S. Wa.hinpnn Stje t
GOt rkry, l'rnnrylvxnle 17121
(7171 144623
Enclosed please find a check in the amount of $70.00 from Mr. Crooks, As we discussed
on the telephone today, we have no reimbursement responsibilities by Mr. Crooks through your
Protection Order so I'm not sure why he is sending you this amount. You may want to make a
copy of the check and give it to your attorney in case Mr. Crooks is confused with monetary
responsibilities through the criminal proceedings.
I also read the letter to you over the telephone that was sent with the check and you
agreed that I would keep it in our files but would not be forwarding that letter to you.
Should you have any questions, please don't hesitate to contact my office.
Sincerely,
SML
Enclosure
LE9 VSE ES , INC.
l?runlC_
Lawrence
S;aralegal
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SERVING ADAMS, CUMBERLAND, FRANKLIN AND FULTON COUNTIES
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DOROTHY ROSS, IN THE COURT OF COMMON PLEAS OF
Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA
V.
99-4912 CIVIL TERM
DALE CROOKS, CIVIL ACTION - LAW
Defendant PROTECTION FROM ABUSE
IN RE: CONTEMPT
ORDER OF COURT
AND NOW, this 9th day of December, 1999, after
hearing, we find the defendant in willful contempt of the within
protective order, and he is thus adjudged.
Sentence of the Court is that the defendant pay
the costs of prosecution, a fine of $200.00, and undergo
unsupervised probation for a period of 6 months on the condition
that he abide by the letter of the existing protective order and
any violation to result in a warrant for his arrest. c
Jonathan R. Birbeck, Esquire
Assistant District Attorney
Arla M. Waller, Esquire
Assistant Public Defender
Probation
Sheriff
Victim Witness
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170 STATE SURCHARGE
171 STATE FINE
260 SHERIFF COST ($1.50 + ADDTL)
207 DISTRICT ATTORNEY
204 COURT COSTS (CLERK OF COURTS)
502 RESTITU)rj ON
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Dorothy Ross, IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 99-4912 CIVIL TERM
Dale Crooks,
Defendant : PROTECTION FROM ABUSE
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 promptly after this Petition, Order and Notice are served, by
appearing personally or by attorney at the hearing scheduled by the Court and presenting to the Court
your defenses or objections to the claims set forth against you. You are warned that if you fail to do
so the Court may proceed without you, and a judgment may be entered against you by the Court
without further notice for any money claimed in the Petition or for any other claim or relief
requested by the plaintiff. You may lose money or property or other rights important to you. Any
Protection Order granted by a Court may be considered in any subsequent domestic relations
proceedings, including custody actions.
FEES AND COSTS
If the case goes to hearing and thejudge grants a Protection Order, a surcharge of $25.00 will
be assessed against you. You may also be required to pay up to $250.00 to reimburse one of Legal
Services, Inc.'s funding sources for Legal Services Inc.'s representation of the plaintiff.
You have the right to be represented by counsel. 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, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 249-3166 or TOLL FREE: 1-800-990-9108
FAY: (717)249-2663
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.
Dorothy Ross, IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
Vs. NO.99-4912 CIVIL TERM
Dale Crooks,
Defendant PROTECTION FROM ABUSE
TEMPORARY EXTENSION OF PROTECTION ORDER
AND NOW, this day of August 2000, upon presentation
and consideration of the within petition and upon finding that
the defendant has engaged in a pattern or practice that indicates
continued risk of harm to the plaintiff, the following Order is
entered:
The Protection Order of September 3, 2000, shall be extended
beyond the expiration date of September 3, 2000, such that it
remains in effect for eighteen months until February 3, 2002 or
until further order of Court.
A violation of this Order may subject the defendant to: i)
arrest under 23 Pa.C.S. §6113; ii) a private criminal complaint
under 23 Pa.C.S. 56113.1; iii) a charge of indirect criminal
contempt under 23 Pa.C.S. §6114, punishable by imprisonment up to
six months and a fine of $100.00-$1,000.00; and iv) civil
contempt under 23 Pa.C.S. 56114.1. Resumption of co-residence on
the part of the plaintiff and defendant shall not nullify the
provisions of the court order.
A hearing shall be held on this matter on they day of _
/L cte.1J, 2000, at . o .m., in Courtroom No.
Cumberland County Courthouse, Carlisle, Pennsylvania.
The plaintiff may proceed without pre-payment of fees
pending a further order after the hearing.
The Cumberland County Sheriff fIs Department shall attempt to
make service at the 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 the defendant
by mail.
The Hampden Township, Silver Springs Township, and Lower
Swatara Police Departments will be provided with a certified copy
of this order by the plaintiff's attorney. This order shall be
enforced by any law enforcement agency where a violation occurs
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
defendant shall be taken without unnecessary delay before the
court that issued the order. When that court is unavailable, the
defendant shall be taken before the appropriate district justice.
(23 Pa.C.S. 5 6113).
By the Court,
Kevin Hess, Judge
Joan Carey _ (20P 1gs 9f0r4-)
Attorney for Plaintiff
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Dorothy Ross,
Dale Crooks,
Plaintiff
V.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4912 CIVIL TERM
Defendant PROTECTION FROM ABUSE
PETITION FOR EXTENSION OF
THE PETITION FOR PROTECTION FROM ABUSE
23 Pa.C.S. §6108(e)
The plaintiff, Dorothy Ross, by and through her attorney, Joan Carey of Legal Services,
Inc., states the following:
The plaintiff filed a Petition for a Protection Order on August 13, 1999, and a
Protection Order was entered on September 3, 1999.
2. The plaintiff requests an Extension of the Protection Order for reasons including,
but not limited to, the following:
a. On or about August 8, 1999, Defendant made approximately 113 phone calls
to Plaintiff at her work and residence containing vulgar, threatening, and hideous messages.
Defendant was charged with harassment by communication and was denied the ARD program
by the District Attorney's office due to the content of the messages. Because of the number of
phone calls Plaintiff received at her place of employment, Plaintiff was caused undo stress and
risked losing her job. See Exhibit A incorporated hereinafter by reference.
b. On or about November 1, 1999, Defendant violated the Protection Order by
sending a check to Legal Services, Inc. which stated "I think of you ever waking moment" on
the memo line. This court found Defendant guilty of Indirect Criminal Contempt on December
9, 1999. See Exhibit B incorporated herein by reference.
C. In or about February 2000, Defendant contacted Legal Services, Inc., in an
attempt to arrange a meeting with Plaintiff. Defendant stated to Legal Services staff that he
still loved Plaintiff and thought of her ever waking moment. Legal Services, Inc. contacted
Plaintiff who stated she never wanted to see him again.
d. Because of Defendant's pattern of continued obsessive and harassing behavior,
Plaintiff fears for her safety and requests that the Protection Order be extended.
WHEREFORE, the plaintiff asks that the Protection Order dated September 3, 1999, be
extended beyond the expiration date of September 3, 2000, such that it remains in effect for an
additional eighteen months or until further Order of Court.
Respectfully submitted,
r"I
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Joan Carey
Attorney for Plainti
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
VERIFICATION
1 verify that 1 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: "P //,p hD _ I e k o /1C E?
Dorthy Ross, laintiff
SENT BY: VICTIM WITNESS; e"") 8-15. 0 10:08;
COMMONWEALTH OF I'FNNSYT,VANIA
COUN'IYOF(I M IERLANn
w. n.: 09-3-04
MI a"'" tax.. THOMAS P. PLACEY
AAaa.. 104 SOUTH SPORTING IIILL ROAD
MECHANICSBURG, IrA 17055
Tiilpll- 717-714/LRYIn
Data Fit=]:
OTN:
7172438028; p2/4
. POLICE
CRIMINAL COMPLAIM'
COMMONWEALTH OF PENNSYLVANIA
All.
m'.rlAnam:
mAMLaW "UP135
DALE KEVIN CROOKS
469 s mill DRTVF.
King of Prussia, PA 19406
( rule lr AllmnY V Mmfmra .r . nnau l)Iel InpmmurrMMlnnry M1x MlNlnlygl,l
1• Detective Lydda IVnndforl( 49-8
nanlan nail leas nnl,l pl lyye umWa ge .an wn. ).
OF c?alebedand Counry DisMetac.arorney'...0 c'r)Crirnlno(/nvcaligullon bivtylon P(A0110).?A
r ay rmrnt nr AP.<ney Aymwn s n lent SuaWnv... Pon, Agenev Ual Vum hr ng lalmr Aanx:Y burr
( .A
d0 hereby state: (nhcak flpproprlna area)
1. ® I accost the above named defendant, who lives at the address sct forth atruvc nr,
? I accuse the def'endunt whose name in unknown to me bill is described as
? 1 accuse the defendant whose name land popular designution of nickname is unknown to me and wheat I have Iherefor designated as
John Doc,
with violating the panel laws of the Cumntonweallh of Pennsylvania uI 4184 F/k trotter, Merhamicburg in Cumberland Counry on or about
August 8. 1999 throught August is, 1999.
Participants were: urdwre wCe Pullclmma, plow n)cil naulee Jim, meerfina onus nrahuve d<fmanill
DA/.p. KEVIN CROOKS
7. The acts fwm fitted by the accused were:
(en tine n rummsy aft rwam.,.W.W the aftnlrmi nnl.,,n.Vla of alt nn'll'.- I..,,y,.d Aell....Li lb.u:.ma 11nnn...„140, :11,%ilLan mmu. n n,n,umiml. In a wo"Inyraw yes mw nn
ftll^ln.IlWi. W IntvfaaLM1 M. raalYa M1 w,\'aylfr ehimly ryi,aJ )
AAJt4SSMENTBYC'OMMUNIC'ATIOA,- Idpa. C,P, pSSO4(a)(1)
The defendant did, with Intent to harass another, make repeated communications anonymously or at
extremely inconvenient tunes, or in offensively cnarse language.
Pcraon llarasred: Dorolhy Ross
all of which were against the peace and dignify orthe Communwc;dlh of Pennsylvania and contrary to the Act of Assembly, or in violation of
1. 3304
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SENT BY: VICTIM WITNESS;
DOROTHY ROSS,
7 -20- 0 10:17; 717 240 7805 . 7172438028; #7/7
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V.
DALE CROOKS,
Defendant
99-1912 CIVIL TERM
CTVIL ACTION • LAW
PROTECTION FROM ABUSE
IN RE: CONTEMPT
ORDER OF COURT
AND NOW, this 9th day of December, 1999, after
hearing, we find the defendant in willful contempt of the within
protective order, and he i.s thus adjudged.
Sentence of the Court is that the defendant pay
the costs of prosecution, a fine of $200.00, and undergo
unsupervised probation for a period of G months on the condition
that he abide by the letter of, the existing protective order and
any violation to result in a warrant for his arrest.
By the Court,
Jonathan R. Sirbeck, Poquire
Assistant District Attorney
Aria M. Waller, Esquire
Assistant Public Defender
Probation
Sheriff
"?c tim Witness
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Kevin .. Hess, J.
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-04912 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ROSS DOROTHY LOUISE
VS
CROOKS DALE KEVIN
CPL. TIMOTHY REITZ , sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE was served upon
CROOKS DALE KEVIN the
DEFENDANT , at 0011:50 HOURS, on the 22nd day of August 2000
at CUMBERLAND COUNTY COURTHOUSE 1 COURTHOUSE SQUARE
CARLISLE, PA 17013 by handing to
DALE CROOKS
a true and attested copy of PROTECTION FROM ABUSE together with
TEMPORARY EXTENSION OF PROTECTION ORDER
PETITION FOR EXTENSION
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 3.10
Affidavit .00
Surcharge 10.00
.00
31.10
Sworn and Subscribed to before
me this 3y r day of
.2 C70 A. D.
?- 2 -A 10 ,_ - .. LPaz:,-
So Answers
R. Thomas Kline i
08/23/2000
By:
othonotary
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Dorothy Ross : IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 99-4912 CIVILTERM
Dale Crooks,
Defendant : PROTECTION FROM ABUSE
ORDER FOR CONTINUANCE
AND NOW, this 3o' day of August, 2000, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on August 28, 2000, by this Court's Order of August
21, 2000, is hereby rescheduled for hearing on September 13, 2000, at 1:30 p.m. in Courtroom No.
4.
The Temporary Protection From Abuse Order shall remain in effect for a period of eighteen
months from the date it was entered or until further Order of Court, whichever comes first.
By the Court,
Hess, Judge
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
Dale Crooks
Pro Se Defendant
I
Dorothy Ross : IN THE COURT OF COMMON PLEAS OF
Plaintiff
Dale Crooks,
V.
Defendant : PROTECTION FROM ABUSE
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-4912 CIVIL TERM
MOTION FOR CONTINUANCE
The Plaintiff, Dorothy Ross, by and through her attorney, Joan Carey 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 From Abuse Order was issued by this Court on August 21,
2000, scheduling a hearing for August 28, 2000, at 3:30 p.m.
The Cumberland County Sheriffs Department served Defendant with a certified copy
of the Temporary Protection From Abuse Order and Petition for Protection From Abuse at his the
Cumberland County Courthouse, August 22, 2000.
3. 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 From Abuse Order remain in
effect for a period of eighteen months from the date it was entered or until further Order of Court,
whichever comes first.
WHEREFORE, the Plaintiff requests that the Court grant this Motion and continue this
reschedule this matter for hearing, and that the Temporary Protection From Abuse Order remain in
effect for a period of eighteen months from the date it was entered or until further Order of Court,
whichever comes first.
Respectfully submitted,
can Carey, Attome or Plaintiff
LEGAL SERVI , INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
P1
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OFFICE OF llfE PROTHONOTARY
CUMBERLAND COUNTY CouRTHOUSE
ONE COURTHOUSE SQUARE
CARLISLE, PA. 17013-3367
(717) 240-6195
FAX (717) 240-6573
V I A T E L E C O P I E R
TO:
FAX 0:
FROM:
RE:
MESSAGE:
PA STATE POLICE
717-249-0779
CURTIS R. LONG
PFA ORDERS
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Dorothy Ross, :IN THE COURT OF COMMON PLEAS
Plaintiff
:OF CUMBERLAND COUNTY, PENNSYLVANIA
Vs.
:NO. 99 -4912 CIVIL TERM
Dale Crooks,
Defendant :PROTECTION FROM ABUSE
FINAL ORDER OF COURT
Defendant's Name: Dale Crooks
Defendant's Date of Birth: 3/5/58
Defendant's Social Security Number: 176-52-6452
Names of all Protected Persons: Dorothy Ross
AND NOW, this &P -t day of September 2000, the court having
jurisdiction over the parties and the subject-matter, it is
ORDERED, AD=GED, and DECREED as follows:
Plaintiff is represented by Joan Carey of LEGAL SERVICES, INC.;
Defendant is unrepresented but is aware of his right to have an
attorney. The parties agree that the following may be entered as
an Order of Court. Defendant, although agreeing that an order
may be entered, does not admit to the allegation made in the
Petition.
? Plaintiff'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, 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 *[NONCONFIDENTIAL ADDRESS FROM WHICH DEFENDANT IS
EXCLUDED] or any other residence where Plaintiff may live.
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Exclusive possession of the residence is granted to Plaintiff.
Defendant shall have no right or privilege to enter or be present
on the premises.
? On [Insert date and time] , Defendant may enter the residence
to retrieve his/her clothing and other personal effects, provided
that Defendant is in the company of a law enforcement officer
when such retrieval is made.
® 3. Defendant is prohibited from having ANY CONTACT with
Plaintiff at any location, including, but not limited to any
contact at Plaintiff's residence, 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 4181 Elk Court, #107,
Mechanicsburg, Cumberland County, Pennsylvania, and any other
residence Plaintiff may establish and her place of employment
located at Pennsylvania Turnpike Commission, Harrisburg,
Pennsylvania.
® 4. Defendant shall not contact Plaintiff by telephone or by
any other means, including third parties.
? 5. Custody of the minor children, (names of the children
subject to the provision of this paragraph] shall be as follows:
[state to whom primary physical custody awarded; state terms of
partial custody or visitation, if any] (or see attached Custody
Order)
? 6. Defendant shall immediately turnover to the Sheriff's
Office, or to a local law enforcement agency for delivery to the
Sheriff's office, the following weapons used or threatened to be
used by Defendant in an act of abuse against Plaintiff and/or the
minor child/ren:
? 7. Defendant is prohibited from possessing, transferring or
acquiring any other weapons for the duration of this Order. Any
weapons delivered to the sheriff under Paragraph 6 of this Order
or under Paragraph 6 of the Temporary Order shall not be returned
until further order of Court.
M S. The following additional relief is granted as authorized
by 56108 of this Act:
a. This Order shall remain in effect until modified or
terminated by the Court and can be extended beyond its original
expiration date if the Court finds that Defendant has committed
another act of abuse or has engaged in a pattern or practice that
indicates continued risk of harm to Plaintiff.
b. Defendant is enjoined from damaging or destroying any
property owned jointly by the parties or owned solely by
Plaintiff.
C. Defendant is to refrain from harassing Plaintiff's
relatives.
d. The court costs and fees are waived.
? 9. Defendant is directed to pay temporary support for [insert
the names of the persons for whom support is to be paid]
as follows: [insert amount,
frequency and other terms and conditions of the support order]
This Order for support shall remain in effect
until a final support order is entered by this Court. However,
this order shall lapse automatically if Plaintiff does not file a
complaint for support with the Court within fifteen days of the
date of this Order. The amount of this temporary order does not
necessarily reflect Defendant's correct support obligation, which
shall be determined in accordance with the guidelines at the
support hearing. Any adjustments in the final amount of support
shall be credited, retroactive to this date, to the appropriate
party.
? 10. The costs of this action are waived as to Plaintiff and
imposed on Defendant.
? 11. Defendant shall pay $* to Plaintiff as compensation for
Plaintiff's out-of-pocket losses, which are as follows:
OR
? Plaintiff is granted leave to present a petition, with
appropriate notice to Defendant, to [insert the name of the judge
or court to which the petition should be presented] requesting
recovery of out-of-pocket losses. The petition shall include an
exhibit itemizing all claimed out-of-pocket losses, copies of all
bills and estimates of repair, and an order scheduling a hearing.
No fee shall be required by the Prothonotary's office for the
filing of this petition.
? 12. BRADY INDICATOR
1.0 Plaintiff or protected person(s) is a spouse, former spouse,
a person who cohabitates or has cohabited with Defendant, a
parent of a common child, a child of that person, or a child of
Defendant.
2.11 This Order is being entered after a hearing of which
Defendant received actual notice and had an opportunity to be
heard.
3.0 Paragraph 1 of this Order has been checked to restrain
Defendant from harassing, stalking, or threatening Plaintiff or
protected person(s).
4.0 Defendant represents a credible threat to the physical
safety of Plaintiff or other protected person(s) OR
? The terms of this order prohibit Defendant from using,
attempting to use, or threatening to use physical force against
Plaintiff or protected person that would reasonably be expected
to cause bodily injury.
® 13. THIS ORDER SUPERCEDES ® ANY PRIOR PFA ORDER AND ? ANY
PRIOR ORDER RELATING TO CHILD CUSTODY.
® 14. All provisions of this Order shall expire in eighteen
months.
NOTICE TO DEFENDANT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE
CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A
FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS.
23 PA.C.S. 56114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION
AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS
ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF
COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES, AND THE COMMONWEALTH OF
PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACTION, 18 U.S.C.
52265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY
VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL
PROCEEDINGS UNDER THAT ACT. 18 U.S.C. 55 2261-2262. IF
PARAGRAPH 12 OF THIS ORDER HAS BEEN CHECKED, YOU MAY BE SUBJECT
TO FEDERAL PROSECUTION AND PENALTIES UNDER THE "BRADY" PROVISIONS
OF THE GUN CONTROL ACTION, 18 U.S.C. 5922((3), FOR POSSESSION,
TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION.
NOTICE TO LAW ENFORCEMENT OFFICIALS
The police who have jurisdiction over Plaintiff's residence
OR any location where a violation of this order occurs OR where
Defendant may be located, shall enforce this Order. An arrest
for violation of Paragraphs 1 through 7 of this Order may be
without warrant, based solely on probable cause, whether or not
the violation is committed in the presence of the police. 23
Pa.C.S. 56113.
Subsequent to an arrest, the police officer shall seize all
weapons used or threatened to be used during the violation of the
Protection Order or during prior incidents of abuse. The [insert
the appropriate name or title] shall maintain possession of the
weapons until further Order of this Court. When Defendant is
placed under arrest for violation of the Order, Defendant shall
be taken to the appropriate authority or authorities before whom
Defendant is to be arraigned. A "Complaint for Indirect Criminal
Contempt" shall then be completed and signed by the police
officer OR Plaintiff, Plaintiffs presence and signature are not
required to file the complaint.
If sufficient grounds for violation of this Order are
alleged, Defendant shall be arraigned, bond set and both parties
given notice of the date of the hearing.
BY THE COURT,
/OV
Kevin V. Hess, Judge
If entered pursuant to the consent of Plaintiff and Defendant:
orothy ss, Plaintiff
Dale Crooks, Defendant
Pro Se
11
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DAk
Joan Carey h?-
Attorney for Plaintiff
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
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