HomeMy WebLinkAbout99-05019F i !?
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MAENG C. JOHNSON,
Plaintiff
vs.
WALTER L. JOHNSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- $ p/ 9 CIVIL TERM
PROTECTION FROM ABUSE
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. Ifyou 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 HEARJNG ON THIS MATTER IS SCHEDULED ON 073 _, 1999,
AT .,IN COURTROOM NO.3 OF THE CUMBERLAND COUNTY
COURTHOUSE, ARLISLE, PENNSYLVANIA.
You MUST obey the Orderthat is attached until it is modified or terminated by the court after
notice and hearing. If you disobey this Order, the police may acres: 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.
MAENG C. JOHNSON,
Plaintiff'
vs.
WALTER L. JOHNSON,
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: WALTER L. JOHNSON
Defendant's Date of Birth: 08/25/49
Defendant's Social Security Number: 259-76-9189
Name of Protected P • MAENG C. JOHNSON
AND NOW, this ay of August, 1999, upon consideration of the attached Petition
for Protection from Abus , 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.
0 2. Defendant is evicted and excluded from the residence at 2108 Cedar Run Drive,
Apt. 106, Camp Hill, 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. Defendant is prohibited from having ANY CONTACT with Plaintiff at any
location, including, but not limited, to any contact at Plaintiffs places of employment.
Defendant is specifically ordered to stay away from the following locations for the duration
of this Order: Plaintiffs places of employment:
Quaker Oats - St. John's Church Road, Shiremanstown, Cumberland County,
Pennsylvania
Chesapeake Display and Packaging Company - 350 Silver Spring Ro44,
Mechanicsburg, Cumberland County, Pennsylvania
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 Sheriffs Office
ora designated local law enforcement agency for the delivery to the Sheriffs Office: Ddikdat
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 an act of abuse or has engaged in a pattern or
practice that indicates 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 Plaintiffs relatives or the parties' minor
child.
8. A certified copy of this Order shall be provided to the police departments where
Plaintiff resides and/or works or to any other agency specified hereafter:
Plaintiff's residence: lower Allen 'T'ownship Police Department
Plaintiffs places of employment: Hampden Township Police Department
9. THIS ORDER SUPERSEDES
ANY PRIOR PFA ORDER
? ANY PRIOR ORDER RELATING TO CHILD CUSTODY
THIS ORDERAPPLIES IMMEDIATELY TO DEFENDANTAND 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 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 9Nor,
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,
r 4F udge
Joan Carey, Attorney for Plaintiff
LEGAL SERVICES, INC.
Lower Allen Township Police Department (Plaintiff's residence)
2108 Cedar Run Drive, Apt. 106, Camp Hill, PA 17011
Hampden Township Police Department (Plaintiff's places of employment)
Quaker Oats,St. John's Church Road, Shiremanstown, PA
Chesapeake Display & Packaging Co., 350 Silver Spring Road, Mechanicsburg, PA
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MAENG C. JOHNSON, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO. 99- Soil CIVIL TERM
WALTER L. JOHNSON,
Defendant : PROTECTION FROM ABUSE
PETITION FOR
PROTECTION FROM ABUSE
The Plaintiff is Maeng C. Johnson.
2. The name of the person who seeks protection from abuse is Maeng C. Johnson.
3. Plaintiffs address is 2108 Cedar Run Drive, Apt. 106, Camp Hill, Cumberland County,
Pennsylvania 17011.
4. Defendant is currently incarcerated in Cumberland County Prison, Carlisle, Pennsylvania
17013.
Defendant's Social Security Number is 259-76-9189.
Defendant's date of birth is 08/25/49.
Since Defendant retired from the Army 10 years ago, he has been unemployed.
5. Defendant is Plaintiffs husband.
6. Defendant has been involved in the following criminal court action:
Lower Allen Township Police Department arrested and charged Defendant with
simple assault as a result of the incident which occurred on or about August 11,
1999, involving Plaintiff as described in paragraph 7 of this Petition.
The facts of the most recent incident of abuse are as follows:
Approximate Date: August 11, 1999
Approximate Time: 10:00 p.m.
Place: 2108 Cedar Run Drive, Apt. 106, Camp Hill, Cumberland
County, Pennsylvania, the marital residence
On or about August 11, 1999, Defendant punched Plaintiff in the shoulder twice,
knocking her to the floor, and when she got up, he backhanded her with his fist
in the face. Plaintiff sustained bruising, swelling, and soreness about her
shoulder and eye as a result of this incident. Plaintiff telephoned 911 for help.
The Lower Allen Township Police responded, arrested Defendant, charged him
with simple assault, and took him to Cumberland County Prison where he
remains. A preliminary hearing is scheduled before District Justice Manlove on
Thursday, August 18, 1999, at 10:00 a.m.
8. The following police departments or law enforcement agencies in the area in which
Plaintiff lives and/or works should be provided with a copy of the Protection Order:
Plaintiff's residence: Lower Allen Township Police Department
Plaintiff's places of employment: Hampden Township Police Department
9. There is an immediate and present danger of further abuse from Defendant.
10. Plaintiff is asking the Court to evict and exclude Defendant from the residence at 2108
Cedar Run Drive, Apt. 106, Camp Hill, Cumberland County, Pennsylvania, which has been the
marital residence since 1989, and is rented in the name of Defendant.
11. Defendant owes a duty of support to Plaintiff and the parties' minor child.
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 she may be found.
B. Exclude Defendant from Plaintiffs residence at 21 Cedar Run Drive, Apt. 106,
Camp Hill, Cumberland County, Pennsylvania, and prohibit Defendant from attempting
to enter any temporary or permanent residence Plaintiff may establish for herself.
C. Require Defendant to provide Plaintiff and the parties' minor child with other
suitable housing.
D. 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 her place of employment.
E. Order Defendant to pay temporary support for Plaintiff and the parties' minor
child, including medical support and payment of the rent on the marital residence.
Order Defendant to pay the costs of this action, including filing and service fees.
G. Order Defendant to reimburse Cumberland County, a Legal Services funding
source, $250.00 for the value of the legal services provided to Plaintiff for the cost of
litigating this case if the case goes to hearing.
H. Order the following additional relief, not listed above:
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 Plaintiffs relatives or the minor child.
Grant such other relief as the court deems appropriate.
J. 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. The Petitioner will inform
the designated authority of any addresses, other than Defendant's residence, where
Defendant can be served.
Respectfully submitted,
,-r
Date: 7
;Joan Carey, AttomeyTor Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
VERIFICATION
I 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: .Q /r/ / G J-
Maeng Johnson, Plaintiff
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SHERIFF'S RETURN - REGULAR
CASE NO: 1999-05019 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
JOHNSON MAENG C
vs.
JOHNSON WALTER L
KATHY CLARKS Sheriff or Deputy Sheriff of
CUMBERLAND County, Pennsylvania, who being duly sworn according
to law, says, the within PROTECTION FROM ABUSE was served
upon JOHNSON WALTER L the
defendant, at 16:45 HOURS, on the 18th day of August
1999 at CUMBERLAND COUNTY PRISON 1101 CLAREMONT ROAD
CARLISLE, PA 17013 CUMBERLAND
County, Pennsylvania, by handing to WALTER L. JOHNSON
a true and attested copy of the PROTECTION FROM ABUSE
together with NOTICE OF HEARING AND ORDER, TEMPORARY PROTECTION
FROM ABUSE ORDER
and at the same time directing His attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00 So answers. 3.10
F
8.00 omas ine, ri
$29.10 08/19/1999
by
Sworn and subscribed to before me
this -Ai- day of
1A.D.
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MAENG C. JOHNSON,
Plaintiff
vs.
WALTER L. JOHNSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5019 CIVIL TERM
PROTECTION FROM ABUSE
FINAL PROTECTION ORDER
Defendant's Name: WALTER L. JOHNSON
Defendant's Date of Birth: 08/25/49
Defendant's Social Security Number: 259-76-9189
Name of Protected Person: l1NG C. JOHNSON
AND NOW, this " day of August, 1999, the court having jurisdiction
over the parties and t fie subject-matter, it is ORDERED, ADJUDGED, and
DECREED as follows:
Plaintiff, Maeng C. Johnson, is represented by Joan Carey of Legal Services, Inc.;
Defendant, Walter L. Johnson, is unrepresented, but has been advised of his right to counsel in this
matter.
Defendant, although agreeing to the terms of this Order, does not admit the allegations
made in the Petition.
Plaintifrs request for a Final Protection Order is granted pursuant to the consent of
Plaintiff and Defendant.
? Plaintiffs request for a Final Protection Order is denied
0 1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other
protected person in any place where they might be found.
0 2. Defendant is completely evicted and excluded from the residence at 2108 Cedar
Run Drive, Apt. 106, Camp Hill, Cumberland County, Pennsylvania, 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_ at _.m., 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.
0 3. Defendant is prohibited from going to and/or having any contact with Plaintiff
at her places of employment. Defendant is specifically ordered to stay away from the following
locations for the duration of this Order:
Plaintiff's places of employment:
Quaker Oats - St. John's Road, Mechanicsburg, Cumberland County,
Pennsylvania
Chesapeake Display & Packaging Company, 350 Silver Spring Road,
Mechanicsburg, Cumberland County, Pennsylvania
? 4. Except as provided in Paragraph 5 of this Order, Defendant shall not contact the
Plaintiff by telephone or by any other means, including third parties.
? 5. Custody of the minor children,, shall be as follows: (or see attached Custody Order)
? 6. Defendant shall immediately turn over to the Sheriffs 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.
8. The following additional relief is granted as authorized by §6108 of this Act:
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 an act of abuse or has engaged in a pattern or
practice that indicates risk of harm to Plaintiff.
The Defendant is enjoined from damaging or destroying any property owned
jointly by the parties or owned solely by Plaintiff.
The Defendant is to refrain from harassing Plaintiff's relatives or the minor
child.
? 9. Defendant is directed to pay temporary support for _ as follows: _. 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 (15) days ofthe 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$_toPlaintiffascompensation forPlaintiffs out-of-pocket losses,
which are as follows: OR
? Plaintiff is granted leave to present a petition, with appropriate notice to Defendant, to
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. The 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. This Order is being entered after a hearing ofwhich Defendant received actual
notice and had an opportunity to be heard.
? 3. Paragraph I of this Order has been checked to restrain Defendant from
harassing, stalking, or threatening Plaintiff or protected person/s.
? 4. 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.
? ANY PRIOR ORDER RELATING TO CHILD CUSTODY.
FUN
Ld/ 14. All provisions of this Order shall expire one year from the date this Order is
entered.
NOTICE TO THE 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. §6114.
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. §2265. 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. §§ 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. §922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF
FIREARMS OR AMMUNITION.
NOTICE TO LAW
ENFORCEMENT OFFICIALS
The police who have jurisdiction over Plaintiffs 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. §6113.
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 Cumberland
County Sheriff's Department 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 f'or 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,
4re AOP Jud e
This Order is entered pursuant to the consent of Plaintiff and Defendant:
Maeng C. Johnson, Plaintiff
W ter L. nso , Defendant
oan Carey, Attornc r Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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MAENG C. JOHNSON,
Plaintiff
vs.
WALTER L. JOI INSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5019 CIVIL TERM
PROTECTION FROM ABUSE
?MORDER OF COURT
AND NOW, thit day of September, 1999, upon consideration of the attached Petition, the
Final Protection Order in the above-captioned case entered on August 26, 1999, is hereby vacated
and the action withdrawn without prejudice to Plaintiff.
A certified copy of this Order shall be provided to the Lower Allen Township and Hampden
Township Police Departments by Plaintiffs attorney.
By the Court,
4
r e E. Hoffer, Presi ent Judge
Joan Carey, Attorney for Plaintiff
LEGAL SERVICES, INC.
Walter L. Johnson, Defendant
c/o James Hunter
51 1 North Harrisburg Street
Steelton, PA 17110
FLEF? OFFICF
99 SEP 17 PH to 09
cUMHDaL'vNV wuMY
PEMNSYLVANA
MAENG C. JOHNSON,
Plaintiff
vs.
WALTER L. JOHNSON,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-5019 CIVIL TERM
PROTECTION FROM ABUSE
PETITION TO VACATE ORDER
AND WITHDRAW ACTION
Plaintiff, Maeng C. Johnson, by and through her attorney, Joan Carey of Legal Services, Inc.,
requests that the Court vacate the Final Protection Order in the above-captioned case and that the
action be withdrawn on the grounds that:
1. A Petition for Protection From Abuse was filed and a Temporary Protection From Abuse
Order was issued by this Court on August 18, 1999, and a Final Protection Order was entered by
agreement of the parties on August 26, 1999.
2. Plaintiff and Defendant are in the process of reconciling their differences.
3. Plaintiff requests that the Final Protection Order be vacated and the action withdrawn
without prejudice to her.
4. A certified copy of this Order will be provided to the Hampden Township and Lower
Allen Township Police Departments by the attorney for Plaintiff.
WHEREFORE, Plaintiff requests that the Court grant the relief requested and vacate the Order,
and that the action be withdrawn without prejudice to Plaintiff.
Respectfully submitted,
Joan Carey, Attorney for P tiff
LEGAL SERVICES, INC.
8 Irvine Row, Carlisle, PA 17013
?,
?_
VERIFICATION
I 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 unworn falsification to authorities.
Date{: %iff / M - d/l,hoo-
Maeng Johnson, Plaintiff
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