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HomeMy WebLinkAbout99-05250.? w;.? a??? +;,, ;?(Ri[ u'n *i'!}? \y i?'{:. Y5ii1 L .!!S i KATHERINE E. SMITH :IN THE COURT OF COMMON PLEAS Plaintiff :OF CUMBERLAND COUNTY, PENNSYLVANIA Vs. :NO. 99 - 5250 CIVIL TERM BART W. SMITH Defendant :PROTECTION FROM ABUSE :AND CUSTODY FINAL ORDER OF COURT Defendant's Name: BART W. SMITH Defendant's Date of Birth: APRIL 12, 1960 Defendant's Social Security Number: 202-56-9778 Names of all Protected Persons, including Plaintiff and minor child/Yen: KATHERINEtE. SMITH AND NOW, this _ day of , 1999, the court having jurisdiction over the parties and the subject- matter, it is ORDERED, ADJUDGED, and DECREED as follows: Plaintiff is represented by LEE E. OESTERLING ESQUIRE Defendant is unrepresented but is aware of his/her right to have an attorney/in represented by ? of ?. 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. After a hearing in the above captioned matter, the Court finds that Defendant, *, has abused Plaintiff, *, pursuant to 23 PaC.S.56102. Defendant. though properly served, failed to appear for the heating. ? Plaintiff's request for a Final Protection Order is denied OR E Plaintiff's request for a Final Protection order is granted. 1811. Defendant shall not abuse, stalk, harass, threaten -- LEGAL SERVICES. IF7C. 2438026 Plaintiff or any other protected person in anyplace 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 entex. or be present on the premises. G on [Insert date and time], Defendant may enter the residence to retrieve his/filer clothing and other personal effects, provided that Defendant is in the company of a law enforcement officer when such retrieval is made. ? 3. Except as provided in Paragraph 5 (anal Paragraph #8 if any unusual circumstances) of this Order, Defendant is prohibited from having ANY CONTACT with Plaintiff at any location, including, but not limited to any contact at Plaintiff's school, business, or place of employment. Defendant is specifically ordered to stay away from the following locations for the duration of this order: Plaintiff's residence located at Cumberland County, Pennsylvania, and any other residence Plaintiff may establish. ? a. Except as provided in Paragraph 5 of this order, Defendant shall not contact Plaintiff by telephone or by any other mear,s, 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 s^all immediately turn over t- 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/rer.: P.15 LEGAL SERVICES, INC. 2438926 ? 7. Defendant is prohibited from possessing, transferrin7 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 56108 of this Act: a. Law enforcement agencies, human service agencies and school districts shall not disclose the presence of Plaintiff and/or address, telephone number, or any other demographic information about Plaintiff and/or child/ren except by further Order of court. b. 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. C. Defendant is required to relinquish to the sheriff any firearm license Defendant may possess. Defendant's weapons and firearm license may be returned at the expiration of the protection Order after Defendant has submitted a written request to the Court for the return of the weapons and the Court has notified Plaintiff of the request and given Plaintiff an opportunity to respond. A copy of this Order shall be transmitted to the chief or heed of the police department of (where Defendant resides) and the sheriff of (where Defendant resides) County. d. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. e. Defendant is to refrain from harassing Plaintiff's relatives (or the minor child/ren). P.16 f. Defendant is ordered to pay the costs of this action, including filing fees, service feea, and surcharge of $25.00 or The court costs and fees are waived. LEGAL sERVICES. INC. 2439026 F.17 B- Defendant is ordered to pay $250.00 to reimburse one of Legal Services, inc.'s funding sources for the cost of litigation in this case (or remove this paragraph if case is settled). ? 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. E/10. The costs of this action are waived as to Plaintiff and imposed on Defendant. ? 11_ Defendart shall pay $* to Plaintiff as compensation for Plaintiffs 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 petitior- shall include ail 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 p: filing of this petition. ? 12. BRADY INDICATOR 1.0 Plaintiff or protected person(s) is a spouse, former spouse, LEGAL SERVICES, INC. 243902E 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 tc, restrain Defendant from harassing, stalking, or threatening Plaintiff or protected person W . 4•+'Q Defendant represents a credible threat to the physical safety of Plaintiff or other protected person(s) OR Q 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 expe;-ted to cause bodily injury. C 13. THIS ORDER SUPERCEDES ? ANY PRIOR PFA ORDER AND C ANY PRIOR ORDER RELATING TO CHILD CUSTODY- 14. All provisions of this Order shall expire in 0126 year. NOTICE TO DEFENDANT VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH I5 PUNISHABLE BY A FINS OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO 92X MONTHS. 23 PA.C.S. 96114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS ORDER SS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DI9TRICT OF COLUMRTA, TRIBAL LANDS, U.S. TERRITORIES, AND TEE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACTION, 18 U.S.C. 52265. TP YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.9.C. 56 2261-2962. IF PARAGRAPH 12 OF THIS ORDER HAS BEEN CHEC]CYD, YOU MAY 9E SUBJECT TO FEDERAL PROSECUTION AND PENALTIES UNDER THE -IBRADY" PROVISIONS P.19 LEGAL SERVICES, I14r_. 2438026 • .. P.13 OF THE GUN CONTROL ACTION, 18 U.S.C. 8922(a), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION. NOTICE TO LAW INFORCIMENT 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 seise 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, Z W&xA2al Judge If entered purs;;a t to the consent of Plaintiff and Defendant: r?. c"? 'r??r ?, ?: ;'? 1'ry . 4 LEC14L SERVICES. INC: (Plaintiff s signature) 2436026 Defendant's signature) )MMMXMM= LEE E. OESTERLING Attorney for Plaintiff .rLOt<n.a.e:e ?- %? Sy Attorney for Defendant dd ' or Pro Se Defendant P.20 SHERIFF'S RETURN - REGULAR CASE NO: 1999-05250 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SMITH KATHERINE E VS. SMITH BART W KATHY CLARKE , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon SMITH BART W the defendant, at 19:05 HOURS, on the 27th day of August 1999 at 111 SOUTH WALNUT STREET MECHANICSBURG, PA 17055 _,CUMBERLAND County, Pennsylvania, by handing to BART SMITH a true and attested copy of the PROTECTION FROM ABUSE together with NOTICE OF HEARING AND ORDER, TEMPORARY PROTECTION FROM ABUSE ORDER, PETITION FOR PROT. FROM ABUSE and at the same time directing His attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 Service 6.20 Affidavit .00 Surcharge 8.00 RT omas i5 eri $32.20 08/31/1999 by ITe u y S)ner"t- Sworn and subscribed to before me this day of 19A.D. ??ono ary?af AUG 2 7 1999 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHERINE E. SMITH Plaintiff, V. BART W. SMITH Defendant No. -'R-5Q lD C. a-Team Civil Action - Protection From Abuse NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following pages, you must appear at the hearing scheduled herein. If you fail to do so the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on the matter is scheduled for the / S f day of fpf. 1999, at Q% ' 0 0 A m in Courtroom S , at Cumberland County Courthouse, Carlisle, Pennsylvania. You MUST obey the Order that is attached until it is modified or terminated by the court after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this Order may subject you to a charge of indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months in jail under 23 Pa.C.S. §6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law 18 U.S.C. §2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you may be subject to federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. §§2261-2262 YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE A RIGHT TO HAVE A LAWYER REPRESENT YOU AT THE HEARING. THE COURT WILL NOT HOWEVER, APPOINT A LAWYERFOR 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, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHERINE E. SMITH Plaintiff, No. (45QV-o 9TH' f M V. BART W. SMITH Civil Action - Protection From Abuse Defendant TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name: Bart W. Smith Defendant's Social Security Number (if known) is: 202-56-9778 Defendant's date of birth is: April 12, 1960 Names of All Protected Persons, including Plaintiff and minor child/ren: Katherine E. Smith AND NOW, this day ofAuauj?l , 1999 upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: X 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. [ ] 2. Defendant is evicted and excluded from the residence at (NONCONFIDENTIAL ADDRESS FROM WHICH DEFENDANT IS EXCLUDED) 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. PJ 3. 9e6rar, Defendant is prohibited from having ANY CONTACT with Plaintiff at any location, including but not limited to any contact at Plaintiffs school, business, or place of employment. Defendant is specifically ordered to stay away from the following locations for the duration of this Order. [ ] 4. Except for such contact with the minor child/ren as may be permitted under Paragraph 5 of this Order, Defendant shall not contact Plaintiff by telephone or by any other means, including through third persons. [ ] 5. Pending the outcome of the final hearing in this matter, Plaintiff is awarded temporary custody of the following minor child/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 the Plaintiff in accordance with the terms of this Order. [ ] 6. Defendant shall immediately relinquish the following weapons to the Sheriffs Office or a designated local law enforcement agency for delivery to the Sheriffs office. Defendant is prohibited from possessing, transferring or acquiring any other weapons for the duration of this order. [ ] 7. The following additional relief is granted: [ ] 8. A certified copy of this Order shall be provided to police department where Plaintiff resides and any other agency specified hereafter: [ ] 9. THIS ORDER SUPERSEDES [ ] ANY PRIOR PFA ORDER AND [ ] ANY PRIOR ORDER RELATING TO CHILD CUSTODY. 10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT Defendant is hereby notified that violation of this Order may result in arrest for indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up to six months in jail. 23 Pa.C.S. § 6114. Consent of the Plaintiff to Defendant's return to the residence shall not invalidate this Order, which can only by changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. § 6113. Defendant is further notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. § § 2261-2262. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiffs residence OR any location where a violation of this order occurs OR where the defendant may be located. If defendant violated 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 any 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 W7 cer made the arrest. BY Judge 8-/;7 /4F5 Date Jimy 49V"I' )7 P.: 12: 17 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA KATHERINE E. SMITH Plaintiff, V. BART W. SMITH Defendant No. `-1`1 ,r) C-) ;. 1 T fM : Civil Action - Protection From Abuse PETITION FOR PROTECTION FROM ABUSE 1. Plaintiffs name is: Katherine E. Smith 2. I am filing this petition on behalf of: [ x ] Myself and/or [ ] Another Person If you checked "myself, "please all questions referring v yourself as "Plaintiff." If you checked another person, "please answer all questions referring to that personas the"Plaintiff; "and provide your address here, unless confidential- If you checked "Another Person, " indicate your relationship with Plainif - [ J parent of minor Plaintiff(s) [ J applicant for appointment as guardian adlitem of minor Plaintff(s) [ J adult household member with minor Plaintiff(s) [ J court appointed guardian of incompetent Plaintf(s) 3. Name(s) of ALL person(s), including Plaintiff and minor children who seek protection from abuse: Katherine E. Smith. 4. [ ] Plaintiffs address is confidential or, [X] Plaintiffs address is: 9 Audobon Drive, Dillsburg, PA 17019. 5. Defendant is known to live at the following address: 111 South Walnut Street, Mechanicsburg, PA 17055. Defendant's Social Security Number (if known) is: 202-56-9775 Defendant's date of birth is: April 12, 1960 Defendant's place of employment is: Triangle Fire Protection [ J check here if defendant is l7 years old or younger 6. Indicate the relationship between Plaintiff and Defendant. [ x ] Spouse [ ] Current or former sexual/intimate partner [ ] Other relationship by blood or marriage [ ]Ex-spouse [ ] Parent/Child [ ] Persons who live or have lived like spouses [ ] parents of the same children [ ] Brother/Sister 7. Have Plaintiff and Defendant been involved in any of the following court actions? [ x ]Divorce [ x ] Custody [ ] Support [ ] Protection from Abuse If you checked any of the above, briefly indicate when and where the case was filed and the court number if known: May 28, 1999; Cumberland County Court of Common Pleas; 99-2260 Civil Term. 8. Has the Defendant been involved in any criminal court action? Not to Plaintiffs knowledge. If you answered yes, is the Defendant currently on probation? 9. Plaintiff and Defendant are the parents of the following minor child/ren: Claire Smith; 12 years old; 111 South Walnut Street, Mechanicsburg, PA 17055. 10. If Plaintiff and Defendant are parents of any minor child/ren together, is there an existing court Order regarding their custody? Yes. If you answered Yes, describe the terns of the Order (e.g., primary, shared, legal and or physical custody): Shared legal and physical custody. If you answered Yes, in what county and state was the order issued? Cumberland, Pennsylvania If you are now seeking an Order of child custody as part of this petition, list the following information (a) Where has each child resided during the past five years? (b) List any other persons who are known to have or claim a right to custody of each child listed above: 11. The following other minor child/ren presently live with Plaintiff? 12. The facts of the most recent incident of abuse are as follows: Approximate Date: August 25, 1999 Approximate Time: 10:00 to 11:00 p.m. ; Place: Plaintiff's residence; Defendant observed on several instances driving slowly by Plaintiff's residence with headlights turned off, was seen with what appeared to be video camera. Upper Allen Police responded to call from Plaintiff. Approximate Date: August 19, 1999; Approximate Time: 11:00 a.m. ; Place: Defendant's residence while picking up daughter; Defendant yelled at daughter to get out of Plaintiffs car, and proceeded to yell at Plaintiff while pounding on car "Are you moving in with him?-are you moving in with him in 3 months?" " Answer Me!!!" "If you move in with him and have Claire around him - I'm going to slit both your throats." Mechanicsburg Police notified and report was taken. After said incident from 3:40 p.m. until the end of Plaintiff's shift at 11:00 p.m. Defendant continued to phone Plaintiff repeatedly at her place of employment without legitimate reason and threatening to appear at her place of employment with no legitimate reason for doing so. Approximate Date: August 3, 1999; Approximate Time: 3:30 p.m ; Place: Dr. Carroll's Office; Defendant threatened Plaintiff in front of counselor stating that if Plaintiff ever brought the parties daughter around a male friend of Plaintif'f's "I'D do whatever I have to do and I don't care if I end up in jail - I don't care if I rot in hell" 13. If the Defendant has committed prior acts of abuse against Plaintiff or the minor child/ren, describe these prior incidents, including any threats, injuries, or incidents of stalking, and indicate approximately when such acts of abuse occurred: Defendant has repeatedly shown up at late hours at Plaintiffs place of employment without legitimate reason, has postured with a hammer while yelling threats at Plaintiff, and has repeatedly called Plaintiff at unusual hours and used language designed to alarm and annoy Plaintiff . 14. List the weapon(s) that Defendant has used or threatened to use against Plaintiff or the minor child/ren: By extrapolation a knife or sharp object capable of slitting a throat. 15. Identify the police department or law enforcement agency in the area in which Plaintiff lives that should be provided with a copy of the protection order: Carroll Township, P.D. 16. There is an immediate and present danger of further abuse from the Defendant. CHECK THE FOLLOWING BOXES ONLY IF THEY APPLY TO YOUR CASE AND PROVIDE THE REQUESTED INFORMATION [ j Plaintiff is asking the court to evict and exclude the Defendant form the following residence: [ ] owned by (list owners, if known): [ ] rented by (list all names, if known): [ ] Defendant owes a duty of support to Plaintiff and/or the minor child/ren. [x] Plaintiff has suffered out-of-pocket financial losses as a result of the abuse described above. Those losses are: Attorneys fees plus filing fees and sheriffs costs to be assessed at the time of hearing. ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING (CHECK ALL FORMS OF RELIEF REQUESTED): [xj A. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or minor child/ren in any place where Plaintiff may be found. [ ] B. Evict/exclude Defendant from Plaintiffs residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff. [ ] C. Require Defendant to provide Plaintiff and/or minor child/ren with other suitable housing. [ J D. Award Plaintiff temporary custody of the minor child/ren and place the following restrictions on contact between Defendant and child/ren. [x j E. Prohibit Defendant from having any contact with Plaintiff and/or minor child/ren, either in person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Plaintiffs school, business, or place of employment, except as the court may find necessary with respect to partial custody and/or visitation with the minor/children. [x ] F. Prohibit Defendant from having any contact with Plaintiffs relatives and Plaintiffs children listed in this Petition, except as the court may find necessary with the respect to partial custody and/or visitation with the minor child/ren. [ ] G. Order Defendant to temporarily turn over weapons to the Sheriff of this County and prohibit Defendant from transferring, acquiring or possessing any such weapons for the duration of the Order. [ ] H. Order Defendant to pay temporary support for Plaintiff and/or the minor child/ren, including medical support and [ ] payment of the rent or mortgage on the residence. [x] I. Direct Defendant to pay Plaintiff for the reasonable financial losses suffered as the result of the abuse, to be determined at the hearing. [x] J. Order Defendant to pay the costs of this action, including filing and service fees. [xj K. Order Defendant to pay Plaintiffs reasonable attorney's fees. [ ] L. Order the following additional relief, not listed above. [ ] M. Grant such other relief as the court deems appropriate. [x] N. Order the police or other law enforcement agency to serve the Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The petitioner will inform the designated authority of any addresses, other than Defendant's residence, where Defendant can be served. VERIFICATION I verify that I am the petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unswom falsification to authorities. Signature Date: ` f, ?u1 c ? 4- c or 00 U G (Y Respectfully Submitted, Lee E. Oesteiliffg,-Esquirc Attorney I.D.N 71320 20 South Market Street Mechanicsburg, PA 17055 (717) 790-0490 Attorney for Plaintiff, Katherine E. Smith