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HomeMy WebLinkAbout99-06096?yG?? a?3ft J `,ba r L r 7a r J a k (;'?{,?rfJ???+, t i ?, i` ? I 1 Nr1 i i?` Y^M Y ^. i ' {P ? P.?s kS A yy ? r ? ???? ??yP }p *Y ! f FF?-F ? iY U. ?}. '.? Y?! - t o a t.?vS C- 4 x.. try.. x iL qu 4 4x ? 3 'tr?,. Y gdr.':ry> l11 a ? S a. } ? &SI ?. S rFhy ?tl 3 v tP r R v.{ ?r z M VnM Yt <I- as t x K 4 i C?kK t li. Y t I?jl V t S' ps C:@ fi i f ".e I EDGAR B. BAYLEY ; •, ,? :.; ,:44. JUDGE , v vk+• I COURTHOUSE SQUARE LEE,, PENNSYLVANIA 17013-3307, ? J\ ?- - JAM 09'0 1 1 r•. -L7A I, Mr -Paul E. Reichenbaugh, Jr. 16aSouth Enola Drive lnoM, PA 17025 ?fj? aAJ Y t -. r.• .:, z- 034: .4• W..Y ......, ...__w.w,t_ ?_...... _ ?. ?_.?.. ? .f a. 1 i S x< t M .. ' d .'ea ? ?Y?7 i 1 HEATHER ANN McCLEAF, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW PAUL EDWARD REICHENBAUGH, JR. Defendant : NO. 99-6096 CIVIL TERM ORDER OF COURT AND NOW, this 9th day of January, 2001, I adjudicate defendant in contempt. Defendant may purge himself of contempt by paying the $513.96 due, in the probation office of Cumberland County, not later than February 1, 2001. Upon failure of defendant to make the payment as directed, he is committed to the Cumberland County Prison for a period of up to six months until he has complied with the terms of this order. Joan Carey, Esquire For Plaintiff Paul Edward Reichenbaugh, Jr. 209 Herman Avenue Lemoyne, PA 17043 AND 168 South Enola Drive Enola, PA 17025 Probation CCP Sheriff prs SHERIFF'S RETURN - REGULAR CASE NO: 1999-06096 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MCCLEAF HEATHER ANN VS REICHENBAUGH PAUL EDWARD JR ROBERT L. FINK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within ORDER OF COURT was served upon REICHENBAUGH PAUL EDWARD JR the DEFENDANT , at 0016:15 HOURS, on the 16th day of January 2001 at 209 HERMAN AVE LEMOYNE, PA 17070 by handing to JENNIFER RHOADES a true and attested copy of ORDER OF COURT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costa: So Answers- PP Docketing 18.00 =. Service 10.54 `,.,. ^ Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 38.54 01/17/2001 Sworn and Subscribed to before Sy: me this j i IA- day of Deputy STieri-M Prothonotary HEATHER ANN MCCLEAF, Plaintiff V. PAUL EDWARD REICHENBAUGH, JR: Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-6096 CIVIL TERM AND NOW, this 15th day of December, 2000, the rule entered against the defendant to show cause why he should not be adjudicated in contempt is made absolute. Final adjudication shall be conducted on Tuesday, January 9th, 2001, at 10:00 a.m., in courtroom Number Two, Cumberland County Courthouse, at which time the defendant is ordered and directed to appear. Service of this order shall be made by the Cumberland County Sheriff's Department. Joan Carey, Esquire For the Plaintiff Paul Edward Reichenbaugh, Jr. 209 Herman Avenue Lemoyne, PA 17043 AND 168 South Enola Drive Enola, PA 17025 Sheriff it IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. NO. 99-6096 CIVIL TERM PAUL EDWARD REICHENBAUGII, JR., : Defendant : CONTEMPT NOTICE OF HEARING AND ORDER AND NOW, this day of November, 2000, in consideration of the attached Petition in the above-captioned case, Defendant, PAUL EDWARD REICHENBAUGH, JR., is directed to b. appear for a hearing on Contempt before the Court on the :5 day of (-e_1-x14 < ; 2000, at 361.4 M. in Courtroom No. 2 on the 4' Floor of the Cumberland County Courthouse, Carlisle, Pennsylvania. You should take this paper to your lawyer at once. You have the right to have a lawyer represent you at the hearing. If you do not have a lawyer or cannot afford one, go to or telephone the Cumberland County Bar Association at 2 Liberty Avenue, Carlisle, Pennsylvania, 17013 (717) 249-3166, to find out where you can get legal help. Further, if you fail to appear, an arrest warrant may be issued. The Sheriff of Cumberland County is directed to serve thi!r -r and Petition upon the Defendant without cost to Plaintiff. C) Joan Carey, Attorney for Plaintiff LEGAL SERVICES, INC. Paul Edward Reichenbaugh, Jr., Defendant 168 South Enola Drive Enola, PA 17025 By the Edgar I3. %r CN1 r C` .\J 7q (v y,. t. ... rtl HEATHER ANN McCLEAF, Plaintiff vs. PAUL EDWARD REICHENBAUGH, JR., Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA NO. 99-6096 CIVIL TERM CONTEMPT PETITION FOR CONTEMPT OF PROTECTION FROM ABUSE ORDER Plaintiff, Heather Ann McCleaf, by and through her attorney, Joan Carey of Legal Services, Inc„ states the following: Plaintiff filed a Petition for Protection From Abuse and a Temporary Protection Order was entered on October 5, 1999. Judge Edgar B. Bayley entered the Final Order of Court (see attached Exhibit A. incorporated herein by reference) on November 22, 1999, in open Court with the parties present. Plaintiff was represented by Joan Carey of Legal Services, Inc., and Defendant proceeded pro se. 2. Defendant has not reimbursed Plaintiff for her out-of-pocket losses of $563.96 total pursuant to paragraph eleven of the Final Protection Order entered on November 22, 1999. Since the entry of the Order, Defendant has made one payment of $50.00 to Plaintiff which she received on or about September 14, 2000. 3. On or about August 31, 2000, Legal Services, Inc. staff hand-delivered a letter dated August 31, 2000, to Defendant (see Exhibit B, incorporated herein by reference) in the presence of his Probation Officer, Jaime Riviera, at the offices of Cumberland County Adult Probation. The letter advised Defendant that unless he paid Plaintiff the Coun-ordered costs that he owed, he faced a contempt action. 4. Plaintiff needs the money to pay creditors for debts she has accrued due to incidents of abuse including, but not limited to, medical costs for treatment of her injuries including surgery and replacement of property damaged or destroyed by Defendant. WHEREFORE, the Plaintiff asks that a hearing be held and that the Defendant be found in contempt of the Final Protection Order, and that this Court take whatever measures necessary, including imprisonment pursuant to § 6114,1(c), to compel Defendant to make the past due payments totaling $513.96 to Plaintiff. Respectfully submitted, v 1. tij6an Carry, Attorney forg LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 • Y f 6/1/r} !li?ir s ys r j rYy' t ?hF i fi .ei N•Y 1 ,y DEC - 2 V9k HEATHER ANN McCLEAF, Plaintiff VS. PAUL EDWARD REICHENBAUGH, JR., Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6096 CIVIL TERM PROTECTION FROM ABUSE Defendant's Name: PAUL EDWARD REICHENBAUGH, JR. Defendant's Date of Birth: 08/03171 Defendant's Social Security Number: 105-64-9806 Name of Protected Person: HEATHER ANN McCLEAF AND NOW, thls2Z day of November, 1999, the court having jurisdiction over the parties and the subject-matter, it Is ORDERED, ADJUDGED, and DECREED as follows: 1 Plaintiff, Heather Ann McClean, Is represented by Joan Carey of Legal Services, Inc.; Defendant, Paul Edward Reichenbaugh, Jr., Is unrepresented, but has been advised of his right to counsel In this matter. °I Defendant, although agreeing to the terms of this Order, does not admit the allegations made In the Petition. Plaintiff's 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 © 1. Defendant shall not abuse, stalk, harass, threaten Plaintiff or any other protected person in any place where she might be found. ? 2. Defendant is completely evicted and excluded from the residence at _ 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. EXHIBIT A 0 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. 3. Defendant Is prohibited from having ANY CONTACT with Plaintiff at any location, Including, but not limited to, any contact at Plaintiff's current residence, or any other residence she may, in the future, establish for herself, and/or her place of employment. Defendant Is specifically ordered to stay away from the following locations for the duration of this Order: Pla[ntiff'sre Id nce:426Market Street, Apt. DoLemoyne, Cumberland County, Pennsylvania. ' : 117 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania. Plaintiff's olacc of emnlo?m?n:; Crossroads Middle School, Fishing Creek Road, New Cumberland, York County, Pennsylvania. © 4. Defendant shall not contact the Plaintiff by telephone or by any other means, Including third parties. O 5. Custody of the minor children„ shall be as follows: (or see attached Custody Order) 13 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/rcn: _ 0 7. Defendant isprohibited fromposscssing, transferring or acquiring anyothcrweapons 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. This Ordershall remain in effect Call be <;?K DetersJanHs ?a s ? 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 Plaintiffdoes not file a complaint for support with the Court within fiReen (15) 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 $563.96 to Plalntlff Order. is Exhibit A, Inc ere Howe: see attached 4?{t¢? ce. nil ?ha I e,?o t I g?me?+L e w of SAitStf; fn We ofm mon y C payaeTo`P1nin an hi`a((c O r?' mailing address do Catherine McClear,117 Bosler Avenue, Lemoyne, PA 17043. fPaymmttr ? 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 ? L Plaintiff or protected pcrson/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 alter a hearing of which 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 pcrson/s. ? 4. Defendant represents a credible lhrcat to the physical safety of Plaintiff or other protected persons 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 UppCEDES L4^#\ QC. Q--, `l ? ANY PRIOR ORDER RELATING TO CHILD CUSTODY. 14. AU provisions of this Order shall expire one year from the date this Order Is entered. VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BYA 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 MAYBE 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. The police who have jurisdiction over Plainti fPs 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 wan-ant, 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 Sheriffs 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 for violation of this Order are alleged, Defendant shall be arraigned, bond set and both parties given notice of the date of the hearing. ?, f BY Edgar B. Bayley, Order i/entered pu4ant to the Onsent of Plaintiff? d r Paul Edward Reichenbaugh, J .,Defendant c/o Beth S ever 211 O Avenue, 2n4 Flo Apt. New Cu berland, PA 17 0 LEGAL SERVIC 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 TRUE COPY FROM RECORD In Test ninny whereof, I here unto set my hand and the seal of said Court at Carlisle, Pa. This ...A:?. day of.....Y?. 19A.?. Prothonotary . HEATHER ANN McCLEAF, Plaintiff Vs. PAUL EDWARD REICHENBAUGH, JR., Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6096 CIVIL TERM : PROTECTION FROM ABUSE OUT-OF-POCKET LOSSES Plaintiffrequests that Defendant reimburse herout-of-pocket losses, including but not limited to the following: Any and all medical expenses relating to injuries Plaintiff sustained as a result of the incidents which occurred on or about January 12, 1999, and December 1998. Medical bills S 75.00 Any and all expenses/costs incurred by Plaintiff to repair and/or replace property damaged and/or destroyed, including, but not limited to, lost wages, as a result of the incidents which occurred on or about September 21, 1999, August 20, 1999, January 12, 1999, and in July 1998. Lost wages from 9/21/99 and 1/12/99 incidents 178.96 Replace car windshield from 8/20/99 and 7/98 incidents 260.00 Replace cellular telephone from 1/12/99 incident 50.00 TOTAL S 563.96 EXHIBIT A LEGAL SERVICES, INC. 8lrvine Row rr..UM F.. (in. CWSMbmh. g.P.mg1...r17m( Carlisle, Pennsylvania 17013 (71') 2645134 (717) 243.9400 ¢1 s. w.,eby M su.a Fax (717) 243.8026 o. 5w.r.r.°°'7"'• Inv (717) 734-7623 West Shore (717) 766.8475 Shippensburg (717) 530-5866 August 31, 2000 Paul Edward Reichenbaugh, Jr. 326 Yd Street West Fairview, PA 17025 Re: McCLEAF v. REICHENBAUGH, JR. No. 99-6096 Civil Term Protection From Abuse Mr. Reichenbaugh: On November 22, 1999, at the hearing scheduled in the above-captioned case before Judge Edgar Bayley, you agreed to the terms and the entry of the Final Protection Order which the judge signed on that date (a certified copy is attached), and a certified copy of the Final Protection Order was mailed to you by the Prothonotary's Office to the address where you indicated you were residing at that time: c/o Beth Steever, 211 Geary Avenue, 2"d Floor Apt., New Cumberland, PA 17070. When you appeared before Judge Bayley on November 22"d, he modified paragraph I I of the Final Protection Order regarding the amount of S563.96 in costs you are ordered to pay to Heather McCleaf. At your request, the Judge changed the monthly payment amount that you are to pay to Heather from $94.00 to $50.00, and changed the payment due date from the first day of each month to the 1516 day of each month, with payments to commence as of December 15, 1999. To date you have not made a single payment to Ms. McCleaf and arc in contempt of the Court's Order. As of August 15, 2000, the amount you owe her is $450.00. If you do not pay Ms, McCleaf the 5450.00 currently owed by next Thursday, September 7, 2000, our is prepared to file a petition with the Court charging you with contempt of the Order and a hearing will be scheduled before Judge Bayley. Sincerely, LEG L SER?jCfiS -EVC. Jan Terpening Paralegal cc: zHeathe. Ann McClea f Vera, Cumberland County Adult Probation nd County District AtIgXftffff B 10 SERVING ADAMS, CUMBERLAND, FRANKLIN AND FULTON COUNTIES Una i .(?! .. Y. r ?F JS Iy.f _ v Ott y tt J 4 C) I EDGAR B.BAYLEY JUDGE 1 COURTHOUSE SQUARE CARLISLE, PENNSYLVANIA 17013-3387r +r? r ?S74 1 ..1 qua.; • r- Paul E. Reichenbeugh, Jr. "` "`° •' r• 168 South Enola Drive sgl,aM?y ,., i.,. Enola, PA 17025 { J1N OSO 1 :833_ 111111111111111111111111111111?1111111111,11111111111111111111 s? - t :r HEATHER ANN MCCLEAF, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. PAUL EDWARD REICHENBAUGH, JR: Defendant 99-6096 CIVIL TERM ORDER OF COURT AND NOW, this 15th day of December, 2000, the rule entered against the defendant to show cause why he should not be adjudicated in contempt is made absolute. Final adjudication shall be conducted on Tuesday, January 9th, 2001, at 10:00 a.m., in Courtroom Number Two, Cumberland County Courthouse, at which time the defendant is ordered and directed to appear. Service of this order shall be made by the Cumberland County Sheriff's Department. Joan Carey, Esquire For the Plaintiff Paul Edward Reichenbaugh, Jr. 209 Herman Avenue Lemoyne, PA 17043 AND 168 South Enola Drive Enola, PA 17025 Sheriff it , . I TRUE Cc?"Y r lu TAI,r? ^1 .•h.n??f, I F.rrc unto :•t ;? ? i.,rd At at cAi HEATHER ANN McCLEAF, : IN THE. COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO.99-l.0"CIVIL TERM PAUL EDWARD REICHENBAUGH, JR., : Defendant : 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. 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 on October L , 1999, at '3 .M., in Courtroom No. of the Cumberland County Courthouse, Carlisle, Pennsylvania. You MUST obey the Order that is attached until it is modified ortcrminatcd by the court aflcrnotice 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 S 1,000.00 and/or up to six months injail under 23 Pa.C.S. 56114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under ' Acral 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 he made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. HEATHER ANN McCLEAF, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO.99- t.6'16 CIVIL TERM PAUL EDWARD REICHENBAUGH, JR., : Defendant : PROTECTION FROM ABUSE Defendant's Name: PAUL EDWARD REICHENBAUCH, JR. Defendant's Social Security Number is 105-64-9806 Defendant's date of birth is 08/03/71 Name of Protected Person: HEATHER ANN McCLEAF AND NOW, this 411 day of UC o-bLr , 1999, upon consideration of the attached Petition for Protection from Abuse, the court hereby enters the following Temporary Order: 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons In any place where they might be found. ? 2. Defendant is evicted and excluded from the residence at _ 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 current residence or at any other residence she may, In the future, establish for herself, and/or at her place of employment. Defendant Is specifically ordered to stay away from the following locations for the duration of this Order: Plaintiffs current residence: 117 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania Plaintiff !s mother's residence: 426 Market Street, Apt. B, Lemoyne, Cumberland County, Pennsylvania Plaintiffs place of employment: Crossroads Middle School, Fishing Creek Road, New Cumberland, York 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 children: Until the final hearing, all contact between Defendant and the child/rcn shall be limited to the following: The local law enforcement agency in the jurisdiction where the children arc located shall ensure that the children arc placed in the care and control of Plaintiff in accordance with the teens of this Order. ? 6. Defendantshallimmediately relinquish thefollowing weaponstotheSheriffsOffice or a designated local law enforcement agency for the delivery to the Sheriffs Office: Defendant is prohibited from possessing, transferring or acquiring any other weapons for the duration of this Order. 7. The following additional relief is granted: The Cumberland County Sheriffs Department shall attempt to make service at 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 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 by Plaintiff. Defendant Is to refrain from harassing Plaintiff's relatives. ® 8. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: D 9. THIS ORDER SUPERSEDES ANY PRIOR PFA ORDER. ? 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. 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 S 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. This Order shall be enforced by the police who have jurisdiction over the plaintiff's residence OR any locations where a violation of this order occurs OR where the defendant may be located. If defendant violates Paragraphs I 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 wan-ant, 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. Joan Carcy, Attorney for Plaintiff LEGAL SERVICES, INC. Certified copies to: West Shore Regional Police Department New Cumberland Police Department Fairview Township Police Department (York County) HEATHER ANN McCLEAF, : IN THE COURT OF COMMON PLEAS OF Plaintiff VS. : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 99- 4 05G CIVIL TERM PAUL EDWARD REICHENBAUGH, JR., : Defendant : PROTECTION FROM ABUSE Plaintiff is Heather Ann McCleaf. 2. The name of the person who seeks protection from abuse is Heather Ann McCleaf. 3. Plaintiff is temporarily residing at 117 Boslcr Avenue, Lemoyne, Cumberland County, Pennsylvania 17043. 4. Defendant is currently residing at 211 Geary Avenue, 21 Floor Apt., New Cumberland, Cumberland County, Pennsylvania 17070. Defendant's Social Security Number is 105-64-9806. Defendant's date of birth is 08/03/71. Defendant's place of employment is Gullifty's Restaurant, Cedar Cliff Mall, Camp Hill, Cumberland County, Pennsylvania. 5. Defendant is Plaintiffs former intimate partner. 6. Defendant has been involved in the following criminal court action: Defendant was arrested by the New Cumberland Police and charged with simple assault and harassment as a result of the incident which occurcd on or about September 21, 1999, involving Plaintiff. Defendant was arraigned before District Justice Clement, and his bail set at $5,000. Defendant made bail and was released from custody. On or about September 23, 1999, Defendant pled guilty in Cumberland County Court of Common Picas to charges of DUI and driving without a license. Sentencing on his case is pending. Defendant was incarcerated in Cumberland County Prison from January 26, 1999, through January 29, 1999, for unpaid fines resulting from charges of driving without a license and disorderly conduct. Defendant indicated to Plaintiff that he had been arrested and charged with burglary in New York State. The facts of the most recent incident of abuse arc as follows: Approximate Date: On or about September 21, 1999 Approximate Time: 8:00 a.m. Place: 211 Geary Avenue, New Cumberland, Cumberland County, Pennsylvania, Defendant's current residence. On or about September 21, 1999, Defendant argued with Plaintiff as she spoke with her sister-in-law on the telephone, grabbed the telephone out of her hand, and with it, grabbed some of her hair which he ripped from her scalp. Defendant interrogated Plaintiff about her relationships with other men, called her derogatory names while pacing back and forth in front of her as she sat on a chair, and punched her on the side of her head near her eye. Defendant threatened Plaintiff saying that he hoped he would see her out socially somewhere so he could have some of his "Harrisburg bitches" take care of her, and told her that revenge is sweet. Defendant punched the refrigerator, and threatened that Plaintiff was going to "get it" if she was not out of his face by the time he counted to three. The New Cumberland Police arrived at Defendant's residence (Plaintiffs sister-in-law telephoned 911 when Defendant disconnected their telephone call), arrested Defendant, charged him with simple assault and harassment, and arraigned him before District Justice Clement, who set Defendant's bail at $5,000. Defendant made bail and was released. 8. Defendant has committed the following prior acts of abuse against Plaintiff: a) On or about September 27, 1999, Defendant telephoned Plaintiff's residence at approximately 2:30 a.m., despite the bail condition set by District Justice Clement on September 21, 1999, which prohibits any contact with Plaintiff. Defendant told Plaintiff that he loved her, questioned her about who she was dating, tried to coerce her to drop the PFA action and the criminal charges against him, and told her to call a taxi and come to his residence. Plaintiff refused, hung up, and telephoned 911 to report the call. Defendant had his friend, Bcth Steever, telephone Plaintiff at her residence on September 26, 1999, and then he got on the telephone and spoke to her. During a telephone call to Plaintiff in late September 1999, Defendant told her that he had driven by her residence several times the previous week to see if she was home. Each time Defendant spoke to Plaintiff he tried to talk her into dropping the criminal charges, and asked her to rendezvous with him. b) On or about January 12, 1999, Defendant shoved Plaintiff to the floor several times, kicked her about her torso while wearing steel-toed boots, grabbed the telephone from her as she tried to call for help, and broke the telephone by throwing it on the floor and stomping on it. Defendant struck Plaintiff on the side of her head and face with a picture frame, breaking the glass which cut her face, mashed the lit end of a cigarette against Plaintiffs face under her eye, and threw video tapes and a chair at her, which narrowly missed hitting her. When Plaintiff tried to get away from him, Defendant ran to the other side of the wall, and as Plaintiff rounded the comer, he punched her in the face, knocking her backward to the floor, and causing her to lose consciousness. Defendant screamed and yelled at Plaintiff as she lay on the floor, grabbed her and dragged her into the bathroom, grabbed herby the hair and shoved her against the floor, screamed that she was messing up the carpet (Plaintiff, who has chronic asthma, was in respiratory distress, coughing blood and bleeding from her facial injuries), and yelled at her to get a towel and clean up the blood. Later, after Plaintiff went to bed, Defendant forcibly had sex with her despite her crying and pleading with him to leave her alone. Plaintiff sought medical attention for injuries she sustained as a result of this incident which included, but were not limited to, bruising and soreness about her torso, head, face, legs, and arms; lacerations and a burn on her face; soreness and hair loss about her scalp, and headaches. Plaintiff, who was advised by her physician not to go to work for a couple days due to her injuries, was fired from her job for missing work. c) On or about September 12, 1999, Defendant telephoned Plaintiffs sister-in-law, Nan McClcaf, who Plaintiff is temporarily residing with, threatened that he knew where Plaintiff lived, where she worked, and that he would hunt her down and find her. Later the same evening, Defendant had his friend, Beth Stecver, telephone Plaintiff. Plaintiffs sister-in-law answered the telephone, and while she was on the phone with Ms. Stccvcr, she heard Defendant yell in the background that he would "get" Plaintiff. d) On or about August 20, 1999, Defendant punched Plaintiffs rear-view mirror, breaking it off of the windshield, causing the windshield to crack, and repeatedly punched the dashboard of her vehicle, cracking the dashboard and breaking the lock to the glove box. c) In or about late summer 1998, Defendant punched Plaintiff on the side of her head while she was driving, and spat on her several times. I) In or about July 1998, Defendant shoved Plaintiff to the ground, broke the rcar- view mirror offofthe windshield of her vehicle, and punched the windshield several times, breaking it. g) In or about December 1998, Defendant grabbed Plaintiff by the neck under her jaw, lifted her off of the floor, and threw her onto a chair. Plaintiff sought medical treatment for injuries she sustained to her neck and jaw as a result of this incident, which included swelling and soreness on one side of her jaw, and left her unable to close her jaw on that side. h) During their relationship, since approximately 1997, Defendant has threatened to kill plaintiff if she ever "cheated" on him, threatened to kill her and himself, and threatened to cause her father, who in in frail health, to suffer a fatal heart attack. Defendant has also threatened to slash the tires on Plaintiffs vehicle causing her to have to hide her car to avoid him vandalizing it. 9. The following police departments or law enforcement agencies in the area in which Plaintiff lives should be provided with a copy of the Protection Order: West Shore Regional Police Department (Plaintiffs residence) Fairview Township Police Department, York County (Plaintiffs work) 10. There is an immediate and present danger of further abuse from Defendant. 11. Plaintiff has suffered the following out-of-pocket financial losses as a result of the abuse described above: see attached Exhibit A, incorporated hereto by reference. 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. 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 Plaintiffs residence, wherever that may be, and/or her place of employment. C. Prohibit Defendant from having any contact with Plaintiffs relatives. D. Direct Defendant to pay Plaintiff for the reasonable financial losses suffered as a result of the abuse, to be determined at the hearing. E. Order Defendant to pay the costs of this action, including filing and service fees. F. 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. G. Order the following additional relief, not listed above: Defendant is enjoined from damaging or destroying any property owned by Plaintiff. Defendant is to refrain from harassing Plaintiffs relatives. H. Grant such other relief as the court deems appropriate. 1. 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 DefendanPs residence, where Defendant can be served. Respectfull submitted, Date: ?D 19 L.tn a?? 6b Carey, Atto for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717)243.9400 I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the penalties of 18 Pa.C.S. §4914, relating to unswom falsification to authorities. Dated: fzg 214?q Heather Ann McCleaf, Plaintiff HEATHER ANN McCLEAF, Plaintiff VS. PAUL EDWARD REICHENI Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO.99- CIVIL TERM IAUGH, JR., : : PROTECTION FROM ABUSE OUT-OF-POCKET LOSSES Plaintiff requeststhat Defendant reimburse herout-of-pocket losses, including but not limited to the following: Any and all medical expenses relating to injuries Plaintiff sustained as a result of the incidents which occurred on or about January 12, 1999, and December 1998. (Copies of medical bills forthcoming). Any and all expenses/costs incurred by Plaintiff to repair and/or replace property damaged and/or destroyed, including, but not limited to lost wages as a result of the incidents which occurred on or about September 21, 1999, August 20, 1999, January 12, 1999, and July 1998. (The amount of damages and/or total lost wages was not available at the time of filing this Petition). S. EXHIBIT A .. . _. ., 1 .. _,. J \? w c9 "' '? r- °? ,,,?_, s;, '';,_ ?. ?:,.:? 7 i???. yr ,'fn 1n? ? y 4...? p..- 'l? / "1?; f.. a ..ii "• CJ ct? ?J1 ?j CJ J 1 W' V SHERIFF'S RETURN - REGULAR AMENDED CASE NO: 1999-06096 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MCCLEAF HEATHER ANN VS. REICHENBAUGH PAUL EDWARD JR 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 REICHENBAUGH PAUL EDWARD JR the defendant, at 20:15 HOURS, on the 5th day of October , 1999 at GUILIFTY'S BAR & RESTAURANT CEDAR CLIFF MALL CAMP HILL, PA 17011 CUMBERLAND , County, Pennsylvania, by handing to PAUL E. REICHENBAUGH, JR a true and attested copy of the PROTECTION FROM ABUSE , together with NOTICE OF HEARING & ORDER, TEMPORARY PROTECTION , FROM ABUSE ORDER, PETITION , and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 9.30 Affidavit .00 Surcharge 8.00 $35.30 So answers: o'v? / z. ? 10/06/199 by Sworn and subscribed n to before me this h.». day of CYc"11, 19 ! A. D. L4-- ?. , Plaintiff VS. CUMBERLAND COUNTY, PENNSYLVANIA : NO. 99-6096 CIVIL TERM PAUL EDWARD REICHENBAUGH, JR., : Defendant : PROTECTION FROM ABUSE AND NOW, this2!1 day of October, 1999, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on October 13, 1999, by this Court's Order of October 5, 1999, is hereby rescheduled for hearing on Thursday, November 4, 1999, at 11:00 a.m. In Courtroom No. 2. The Temporary Protection From Abuse Order shall remain in effect for a period of one year from the date it was entered, through October 5, 2000, or until further Order of Court, whichever comes first. The Cumberland County Sheriffs Department shall attempt to make service at Plaintiffs request and without prepayment 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. Certified copies of this Order for Continuance shall be provided to the West Shorc Regional and New Cumberland Police Departments by Plaintiffs attorney. Court, Edgar B. Bayley, HEATHER ANN McCLEAF, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-6096 CIVIL TERM PAUL EDWARD REICHENBAUGH, JR., : Defendant : PROTECTION FROM ABUSE Plaintiff, Heather Ann McClcaf, 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 October 5, 1999, scheduling a hearing for October 13, 1999, at 3:00 p.m.. 2. The Cumberland County Sheriffs Department served Defendant with acertifled copy of the Temporary Protection From Abuse Order and Petition for Protection From Abuse on October 5, 1999, at his place of employment, Gullifty's Bar and Restaurant, Cedar Cliff Mall, Camp Hill, Cumberland County, Pennsylvania. 3. On October 12, 1999, after being advised of his right to counsel in the above- captioned matter, Defendant indicated to Legal Services, Inc. staff that he wanted to settle the case by agreeing to the terms and entry of the Final Protection Order. 4. Because Defendant told Legal Services, Inc. staff that it would be a hardship for him to travel to Carlisle to sign the Consent Agreement, attempts were made to accommodate Defendant by having the proposed Final Protection Order hand-delivered to the New Cumberland Police Department on October 12, 1999, and then to the West Shore Regional Police Department on October 13, 1999. Legal Services, Inc. staff telephoned Defendant each time and advised him that the paperwork was at the respective police department, awaiting his signature. Defendant failed to go to either department and never signed the Consent Agreement. 5. On October 21,1999, a preliminary hearing was held before District Justice Clement on criminal charges filed against Defendant by the New Cumberland Police related to the September 21, 1999, incident involving Plaintiff. Before the hearing began, an advocate from the Cumberland County Victim Witness Program, acting on behalf of Legal Services, Inc. staff, hand- delivered the proposed Final Protection Order to Defendant for his signature. Defendant agreed to sign the Final Protection Order conditioned on Plaintiff dropping the criminal charges. Plaintifftold the police officer that she wanted to proceed with the hearing, and after her testimony, the District Justice bound the charges over for hearing. 6. Plaintiff requests that the hearing be rescheduled. 7. Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of one year from the date it was entered, through October 5, 2000, or until further Order of Court, whichever comes first. 8. Certified copies of the Order for Continuance will be delivered to the West Shore Regional and New Cumberland Police Departments by the attorney for Plaintiff. WHEREFORE, Plaintiff requests that the Court grant this Motion and 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, through October 5, 2000, or until further Order of Court, whichever comes first. Respectfully submitted, i v oan Carey, Attorney f laintiff ,/j LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717)243.9400 2 yNe .- ze? 4 x ? ' i f? Ri (3 ?-.4 Gi:\i?(iYM err ....-.": .a..::...v ..:. .... ..... .._. .._.,_ ......:. SHERIFF'S RETURN - REGULAR CASE NO: 1999-06096 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MCCLEAF HEATHER ANN VS. REICHENBAUGH PAUL EDWARD JR RICHARD SMITH , Sheriff or Deputy Sheriff of CUMBERLAND County, Pennsylvania, who being duly sworn according to law, says, the within ORDER FOR CONTINUANCE was served upon REICHENBAUGH PAUL EDWARD JR the defendant, at 19:00 HOURS, on the 1st day of November , 1999 at 211 GEARY AVE 2ND FLOOR APT NEW CUMBERLAND, PA 17070 CUMBERLAND , County, Pennsylvania, by handing to BETH STEEVER (ROOMMATE) a true and attested copy of the ORDER FOR CONTINUANCE , and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So answers: Docketing 18.00 `; Service 11.16 Affidavit 100 Surcharge 8.00 K. 1'PfaTPfd , 5 - $37.16-11/03/1999 by y"-- Sworn and subscribed to before me this 91' day of .,. .? 19 4) A.D. n. i rro? ?4T CERTIFICATION OF PFA OONnMV CASE NUMBER 99-6096 CIVIL TERM NAME PAUL EDWARD REICHENBAUGH JR 211 GEARY AVENUE 2nd FLOOR NEW CUMBERLAND PA 17070 VICTIM'S NAME: HEATHER ANN MCCLEAF BALANCE DUE: $563.96 ADD DELETE 170 STATE SURCHARGE $ $ 171 STATE FINE $ $ 260 SHERIFF COST ($1.50 ? ADDTL) $ $ 207 DISTRICT ATTORNEY $ $ 204 COURT COSTS (CLERK OF COURTS) $ $ 502 RESTITUTION NAME HEATHER ANN M CLEAF $ 563.96 $ ADDRESS c/o CATHERINE MCCLEAF 117 BOSLER AVENUE CITY LEMOYNE STATE PA ZIP 17043 S $ ADDRESS CITY STATE ZIP NAME ADDRESS S CITY STATE. ZIP PROTHONOTARY OFFICE. f^ PERSON, CERTIFYING INFORMATION _j an J ]Q/1 ; DA _0_JU .-^_-- 1 F, : IN THE COURT OF Plaintiff VS. CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6096 CIVIL TERM PAUL EDWARD REiCHENBAUGH, JR., : Defendant : PROTECTION FROM ABUSE FINAL PROTECTION ORDER Defendant's Name: PAUL EDWARD REICIIENBAUGII, JR. Defendant's Date of Birth: 08/03/71 Defendant's Social Security Number: 105-64-9806 Name of Protected Person: HEATHER ANN McCLEAF AND NOW, this2Z day of November, 1999, the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED, and DECREED as follows: Plaintiff, Heather Ann McCleaf, Is represented by Joan Carey of Legal Services, Inc.; Defendant, Paul Edward Relchenbaugh, Jr., 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. Plaintiff's request for a Final Protection Order is granted pursuant to the consent of Plaintiff and Defendant. O Plaintiffs request for a Final Protection Order is denied 1. Defendant shall not abuse, stalk, harass, threaten Plaintiff or any other protected person in any place where she might be found. O ?. Defendant is completely evicted and excluded from the residence at _ 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 he 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. ® 3. Defendant Is prohibited from having ANY CONTACT with Plaintiff at any location, Including, butnotlimited to,anycontact at PlaintifPscurrent residence, oranyother residence she may, in the future, establish for herself, and/or her place of employment. Defendant is specifically ordered to stay away from the following locations for the duration of this Order: Plaintiff's residence: 426 Market Street, Apt. B, Lemoyne, Cumberland County, Pennsylvania. Plainif ! parent's S1WS ce: 117 Bosler Avenue, Lemoyne, Cumberland County, Pennsylvania. Plaintiff's place of employment: Crossroads Middle School, Fishing Creek Road, New Cumberland, York County, Pennsylvania. 4. 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 Shcriirs Officc, the following weapons used or threatened to be used by Defendant in an act of abuse against Plaintiff and/or the minor children: ? 7. Defendant is prohibited from possessing, transferring oracquiring any otherweapons 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. Tlttiol on Act: ?u( This Order shall remain in effect !he Geulp+oad' _ t p?ractlcc-thatJndlegles-r1s ,? ?n? I?? aging 0 ?? P_'6aaMttV _ Defeadae"t4ti-refry s. O 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 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 arc waived as to Plaintiff and imposed on Defendant. © 11. Defendant shall pay $563.96 to Plaintiff is 0r4er-ag.cosz&poa#m Itowe: see attached Exhibit A, Incq?p?aeela? fc ACC. jlg?n?1@pjshaJl np??c P1o t 1 gYmcprc4 amount of S , n e o m mon y ord r ms a pa"ya?fo i"o'"Ca n an ?it`aife to er mailing address c/o Catherine McCleaf, 117 Bosler Avenue, Lemoyne, PA 17043. Paymentr ? 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. Plaintiff or protected persons 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 tiller a hearing of which Defendant received actual notice and had an opportunity to be heard. ? 3. Paragraph 1 of this Order has been checked to restrain Defendant from harassing, stalking, or threatening Plaintiff or protected pcrson/s. ? 4. Defendant represents a credible threat to the physical safety of Plaintiff or other protected persons 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. T IS UPORCEDES O? litre 6(16 111 ? ? ANY PRIOR ORDER RELATING TO CHILD CUSTODY. ® 14. All provisions of this Order shell expire one year from the date this Order Is entered. VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BYA 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 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 I 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 Sheriffs 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 arc 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) Edgar B. Bayley, f' Order i/ entered pudant to the c nsent of Plaintiff/and Ann McCleaf, Plaintiff Joan Carey, Attgfncy for LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717)243.9400 Paul Edward Reichenbaugh, J ., Defendant c/o Beth S ver 211 G Avenuc, 2nd Flo Apt. New Cu berland, PA 17 0 PLED-WFI; E Cf TN2 "?THCI^'DTAw 99 NOV 22 PH 3: 59 CLIWIEnuVi L) GJi1'tiIly PElVIv'SnvAVW HEATHER ANN MCCLEAF, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 99-6096 CIVIL TERM PAUL EDWARD REICHENBAUGH, JR., : Defendant : PROTECTION FROM ABUSE QUI-OF-POCK-El LOSSES Plaintiffrcquests that Defendant reimburse herout-of-pocket losses, including but not limited to the following: Any and all medical expenses relating to injuries Plaintiff sustained as a result of the incidents which occurred on or about January 12, 1999, and December 1998. Medical bills S 75.00 . Any and all expenscs/costs incurred by Plaintiff to repair and/or replace property damaged and/or destroyed, including, but not limited to, lost wages, as a result of the incidents which occurred on or about September 21, 1999, August 20, 1999, January 12, 1999, and in July 1998. Lost wages from 9/21/99 and 1/12/99 incidents 178.96 Replace car windshield from 8/20/99 and 7/98 incidents 260.00 Replace cellular telephone from 1/12/99 incident 50.00 TOTAL S 563.96 EXHIBIT A ?. HEATHER ANN McCLEAF, : IN THE COURT OF COMMON PLEAS OF PLAINTIFF : CUMBERLAND COUNTY, PENNSYLVANIA V. PAUL EDWARD REICHENBAUGH, JR., DEFENDANT : 99-8098 CIVIL TERM ORDER OF COURT AND NOW, this f day of November, 1999, upon request of defendant for a continuance to obtain counsel, unopposed by counsel for plaintiff, the hearing now scheduled for November 4, 1999, Is rescheduled to Monday, November 22, 1999, at 3:00 p.m., In Courtroom Number 2, Cumberland County Courthouse, Carlisle, Pennsylvania. All provisions in the temporary protection from abuse order entered on October 5, 1999, shall remain In full force and effect. By the Court, ; Joan Carey, Esquire For Plaintiff Paul Relchenbaugh, Pro se 211 Geary Avenue New Cumberland, PA 17070 ll-y-Q9 iZLl? :sea rlErr- j!tl^C Q ntr ;,r '!;nTn9Y HEATHER ANN McCLEAF, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA V. CIVIL ACTION - LAW PAUL EDWARD REICHENBAUGH, JR. Defendant NO. 99-6096 CIVIL TERM AND NOW, this 9th day of January, 2001, I adjudicate defendant in contempt. Defendant may purge himself of contempt by paying the $513.96 due, in the probation office of Cumberland County, not later than February 1, 2001. Upon failure of defendant to make the payment as directed, he is committed to the Cumberland County Prison for a period of up to six months until he has complied with the terms of this order. Joan Carey, Esquire For Plaintiff Paul Edward Reichenbaugh, Jr. 209 Herman Avenue Lemoyne, PA 17043 AND 168 South Enola Drive Enola, PA 17025 Probation CCP Sheriff pre ,p q,u' 0\' * C rf .'1'- ?. ?J 1 :.. i7 .i• 7 SHERIFF'S RETURN - REGULAR CASE NO: 1999-06096 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MCCLEAF HEATHER ANN VS REICHENBAUGH PAUL EDWARD JR CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE OF HEARING & ORDER was served upon REICHENBAUGH PAUL EDWARD JR the DEFENDANT , at 0015:20 HOURS, on the 29th day of November , 2000 at 168 S. ENOLA DRIVE ENOLA, PA 17025 by handing to PAUL E. REICHENBAUGH, JR. a true and attested copy of NOTICE OF HEARING & ORDER together with PETITION FOR CONTEMPT OF PROTECTION OF ABUSE ORDER and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 9.92 ?j`?,t? Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 37.92 11/30/2000 Sworn and Subscribed to before By: me this /3-n: day of Deputy She ff ALt-p....LP&4vt) A.D. Q, IPA , ri- rop thonotary y HEATHER ANN McCLEAF, Plaintiff V. PAUL EDWARD REICHENBAUGH, JR: Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 99-6096 CIVIL TERM AND NOW, this 15th day of December, 2000, the rule entered against the defendant to show cause why he should not be adjudicated in contempt is made absolute. Final adjudication shall be conducted on Tuesday, January 9th, 2001, at 10:00 a.m., in Courtroom Number Two, Cumberland County Courthouse, at which time the defendant is ordered and directed to appear. Service of this order shall be made by the Cumberland County Sheriff's Department. Joan Carey, Esquire For the Plaintiff Paul Edward Reichenbaugh, Jr. 209 Herman Avenue Lemoyne, PA 17043 AND 168 South Enola Drive Enola, PA 17025 Sheriff It b ti 'Y ?Ll al-3-01 -3 XS • 3TARY 3 01-wl-3 P,f 1:SI? p?'wsri?a i? - N . ?s a 3 4 o 1F, yY ;fSy' r.? n•, ?av a.? a `{t i S 9Li Y a ?A SHERIFF'S RETURN - REGULAR CASE NO: 1999-06096 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MCCLEAF HEATHER ANN VS REICHENBAUGH PAUL EDWARD JR DAWN KELL , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within ORDER OF COURT was served upon REICHENBAUGH PAUL EDWARD JR the DEFENDANT , at 0018:29 HOURS, on the 4th day of January , 2001 at 209 HERMAN AVE LEMOYNE,•PA 17043 by handing to JENNIFER RHOADS (GIRLFRIEND) a true and attested copy of ORDER OF COURT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 SERVICE 9.92 Affidavit .00 Surcharge 10.00 .00 37.92 Sworn and Subscribed to before me this /U- day of `Jim-a-4?f Jnn/ A.D. So Answers: 00 R. Thomas Kline- 01/05/2001 By 1) cl, 1 d . r O Q? Deputy Sheriff rothonotary