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HomeMy WebLinkAbout99-06146Tiffanic M. Shapiro, the Minor Plaintiff, by : IN THE COURT OF COMMON PLEAS OF Stephanie Shapiro Hunt, her guardian, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. : NO.99-0/4LO CIVIL TERM Dennis E. Ryan, Defendant : PROTECTION FROM ABUSE NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth in the following papers, you must appear at the hearing scheduled herein. If you fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A HEARING ON THIS MATTER IS SCHEDULED ON Cddhl 1.3 ,1R AT 3 ?) ( ) P.M., .M., IN COURTROOM NO. ,AOF THE CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA. 4 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. E? 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 i our office. All arrangements must be made at least 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. I ??r r1 ?J , „?. 9? ?rT - 7 F'r'i 1: pR }1 C+ ` _..-?:? Tiffanic M. Shapiro, a Minor Plaintiff, by : IN THE COURT OF COMMON Stephanie Shapiro Hunt, her guardian : PLEAS : CUMBERLAND COUNTY, Plaintiff : PENNSYLVANIA V. :No. t q- Co I Dennis E. Ryan Defendant CIVIL ACTION - LAW PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Dennis E. Ryan Defendant's Date of Birth is: July 4, 1978 Name(s) of All protected persons, including Plaintiff and minor children: 1. Tiffanie M. Shapiro AND NOW, on OK upon consideration of the attached Petition for Protection from use, the court hereby enters the following order: Plaintiffs request for a temporary protection order Is granted. 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 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. Plaintiffs residence located at 152 North Pitt Street, Carlisle, PA Plaintiffs school located at Carlisle High School, Carlisle, PA Plaintiffs place of employment located at the Jewish Home Of Harrisburg, Linglestown, PA 3. Defendant shall not contact Plaintiff by telephone or by any other means, including through third persons. 4. The following additional relief is granted: - Prohibit Defendant from having any contact with Plaintifrs relatives. 5. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Carlisle Borough Police 6. The police or other law enforcement agencies arc directed to serve the Defendant with a copy of the Petition, any Order issued, and the Order for Hearing. The Petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. 7. 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 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. 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 violates Paragraphs I through 3 of this Order, defendant may be arrested on the charge of Indirect Criminal Contempt. An arrest for violation of this Order may be made without warrant, based solely on probable cause, whether or not the violation is committed in the presence of law enforcement. Subsequent to an arrest, the law enforcement officer shall seize all weapons used or threatened to be used during the violation of this Order OR during prior incidents of abuse. Weapons must forthwith be delivered to the Sheriffs office of the county which issued this Order, which office shall maintain possession of the weapons until further Order of this court, unless the weapon/s arc evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. Distribution to: Legal Services Faxed & Mailed to PSP Carlisle Police Department Carlisle Area High School BY THE COURT: Judge Date PFAD Number: YJI035607V Tiffanie M. Shapiro, a Minor Plaintiff, by Stephanie Shapiro Hunt, her guardian Plaintiff v. Dennis E. Ryan Defendant : IN THE COURT OF COMMON :PLEAS : CUMBERLAND COUNTY, :PENNSYLVANIA : No. 14(v CIVIL ACTION - LAW PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE 1. Plaintiffs name is: Tiffanie M. Shapiro 2. 1, (the Filer), am filing this Petition: - as Parent of minor Plaintiff(s) 3. Filcrs Name is: Stephanie D. Sbapiro-Hunt 4. Filer's Address is: 152 N. Pitt Street, Carlisle, PA 17013 5. Name(s) of ALL person(s), including minor children, who seek protection from abuse. a. Tiffanie M. Shapiro 6. Plaintiffs Address is : 152 North Pitt Street, Carlisle, PA 17013 7. Defendant's Name is: Dennis E. Ryan 8. Defendant is believed to live at the following address: 3700 Sheaff Lane Apt. B317 Philadelphia, PA 19145 9. Defendant's Date of Birth is: July 4, 1978 10. Defendant's Placc of employment is: unemployed 11. Defendant is an adult. 12. The relationship between the Plaintiff and the Defendant is: Current or former sexual/intimate partner 13. The defendant has not been Involved in a criminal court action. 14. The facts of the most recent incident of abuse are as follows: On about Monday, September 27,1999 at approximately 12:30AM location: residence On or about September 27, 1999, Defendant became angry, grabbed Plaintiff by her face, lifted her off of the bed, grabbed her by the throat, and shoved her back onto the bed. When Plaintiff attempted to stand up, Defendant grabbed her by her throat and threw her back onto the bed. Defendant threatened Plaintiff stating that she was not she was not allowed to leave him causing her to fear for her safety. When Plaintiff did attempt to leave the residence, Defendant grabbed her by the back of her neck and pulled her back into the apartment. Defendant slapped Plaintiff across the face and shoved her Into the closet. Defendant grabbed Plaintiff by her throat and threw her onto the bed telling her that she was not not allowed to leave and threatened to kill Plaintiff and himselL Defendant smashed Plaintiff in the face with the heel of his palm causing brusing about one eye and a broken blood vessel in the other eye. 15. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor children, (including any threats, injuries, or incidents of stalking) are as follows: In or about the beginning of August 1999 - Defendant became angry when Plaintiff was leaving the residence and took her car keys. Defendant returned Plaintiff's keys but threatened her by stating she was not allowed to leave the residence. When Plaintiff left the residence, Defendant chased her down the street, grabbed her neck, demanded that she return to the house, and pulled her back to the residence. Defendant became angry when Plaintiff attempted to use the phone, grabbed it from her, and carried her upstairs. In or about May 1999 - Defendant grabbed Plaintiff by her throat, squeezed it, and pinched Plaintiff on her arms and legs causing bruises. In or about March/April 1999 - Defendant pushed Plaintiff out of the apartment and locked the door. When Plaintiff started walking to her mother's residence, Defendant ran up to her, grabbed her, and ripped her shirt, and pulled her back to the apartment. HISTORY Since January 1999, Defendant has abused Plaintiff In the following ways: harassed her by his controlling behavior,grabbed her by the throat, choked her, and threatened to kill her causing her to fear for her life. 16. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: Carlisle Borough Police 17. There is an immediate and present danger of further abuse from the Defendant. 18. FOR THE REASONS SET FORTH ABOVE, I REQUEST 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 and/or minor children in any place where Plaintiff may be found. b. Prohibit Defendant from having any contact with Plaintiff and/or minor children, 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. c. Prohibit Defendant from having any contact with Plaintiffs relatives and Plaintiffs children listed in this petition, except as the court may find necessary with respect to partial custody and/or visitation with the minor child/rcn. d. Order Defendant to pay the costs of this action, including filing and service fees. e. Order the following additional relief, not listed above: Order Defendant to pay $250.00 to reimburse one of Legal Services, Inc.'s funding sources toward the cost of litigation in this case. f. Order the police or other law enforcement agency to serve the Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. VERIFICATION 1 verify that I am the petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my knowledge. I understand that any false statements are made subject to the Penalties of 18 Pa. C.S. §4904, relating to unswom falsification to authorities za,x 61ua" kr ;A;S& n Signature VERIFICATION 1 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. 1 understand that any false statements are made subject to the penalties of 18 Pa.C.S. §4904, relating to unworn falsification to authorities. Dated: _ Ocdi AAA (0. 1 qqq ?t 4I r`" IiflfaeN. Shapiro, Minor laintiff St aine Shapiro-Hunt, Guardian t1, > - <; _ V? J a U V •C? Q h Y J Tiffanic Shapiro, the Minor Plaintiff, by Stephanie Shapiro Hunt, her guardian, Plaintiff V. Dennis E. Ryan, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA NO. 99-6146 CIVIL TERM : PROTECTION FROM ABUSE AND NOW, this _ 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 7,1999, is hereby rescheduled for hearing on W-YgMhr R, 1999, at 2:30 R.M. in Courtroom No. 2. The Temporary Protection order shall remain in effect for one year or until modified or terminated by the court. The Cumberland County Sheriffs Department shall attempt to make service at the plaintiffs request and without prc-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 Prothomotary shall not send a copy of this order to the defendant by mail. A certified copy of this Order for Continuance shall be provided to the Carlisle Police Department by the plaintiffs attorney. Joan Carey Legal Services, Inc. Attorney for Plaintiff Tiffanie Shapiro, the Minor Plaintiff, by Stephanie Shapiro Hunt, her guaridian, Plaintiff V. Dennis E. Ryan, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA NO. 99-6146 CIVIL TERM PROTECTION FROM ABUSE The Plaintiff, Tiffanie Shapiro, 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 7, 1999, scheduling a hearing for October 13, 1999, at 3:30 p.m. 2. The Cumberland County Sheriffs Department deputized the Philadelphia Sheriffs Department to serve Defendant with a certified copy of the Temporary Protection From Abuse Order and Petition. The Philadelphia Shcriff was unable to effect service on Defendant. 3. The Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of one year from the date it was entered or until further Order of Court, whichever comes first. 4. A certified copy of the Order for Continuance will be delivered to the Carlisle Police Department by the attorney for the Plaintiff. j WHEREFORE, the 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 or until further Order of Court, whichever comes first. Respectfully submitted, &!?Z JIL%ar2ey Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 ?i ?c w u? t ?- ` r 4 ? ;?.r I )_.r ? ?C. CJ; . ? (,, . l ` 7? J'i. ?_. (_ ':: JI jJ 12 ? R, Y;1 ?-? U ? :? Tiffanie Shapiro, the Minor Plaintiff, by Stephanie Shapiro Hunt, her guardian, Plaintiff V. Dennis E. Ryan, Defendant : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA NO. 99-6146 CIVIL TERM : PROTECTION FROM ABUSE AND NOW, thistday of November, 1999, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on November 8, 1999 by this Court's Order of October 13,1999, is hereby rescheduled for hearing on, December 2, 1999, at 1:30 p.m. in courtrtroom No. 2. The Temporary Protection order shall remain in effect for one year or until modified or terminated by the court. The Cumberland County Sheriffs Department shall attempt to make service at the plaintiff's request and without pre-payment of fees, but service may be accomplished under any applicable rule of Civil Procedure. This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service. The Prothomotary shall not send a copy of this Order to the defendant by mail. A certified copy of this Order for Continuance shall be provided to the Carlisle Police Department by the plaintiffs attorney. B?tle Court, Edgar B. Joan Carey Legal Services, Inc. Attorney for Plaintiff FtlEf} ?`?;C`?iARY uNY r r•.r.' Tiffanie Shapiro, the Minor Plaintiff, by Stephanie Shapiro Hunt, her guaridian, Plaintiff V. Dennis E. Ryan, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA NO. 99-6146 CIVIL TERM : PROTECTION FROM ABUSE The Plaintiff, Tiffanie Shapiro, by and through her attorney, loan 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 7,1999, scheduling a hearing for October 13, 1999, at 3:30 p.m. 2. The Cumberland County Sheriffs Department deputized the Philadelphia Sheriffs Department to serve Defendant with a certified copy of the Temporary Protection From Abuse Order and Petition. The Philadelphia Sheriff was unable to effect service on Defendant. 3. The Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of one year from the date it was entered or until further Order of Court, whichever comes first. 4. A certified copy of the Order for Continuance will be delivered to the Carlisle Police Department by the attorney for the Plaintiff. WHEREFORE, the 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 ofone year from the date it was entered or until further Order ofCourt,whichevercomes first. Respectfully subs fitted, Carey Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 Tiffanie Shapiro, the Minor Plaintiff, by : IN THE COURT OF COMMON FLEAS OF Stephanie Shapiro Hunt, her guardian, Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO, 99-6146 CIVIL TERM Dennis E. Ryan, Defendant : PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, this J" day of December, 1999, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on December 2, 1999, by this Court's Order of October 7, 1999, is hereby rescheduled for hearing on December 13,1999, at 10:30 a.m. in Courtroom No. 2. The Temporary Protection From Abuse Order shall remain in effect fora period of one year from the date it was entered or until further Order of Court, whichever comes first. A certified copy of this order for Continuance will be provided to the Carlisle Police Department by the plaintiffs attorney. By the Court, Edgar B. Bayley, Judge Joan Carey LEGAL SERVICES, INC. Attorney for Plaintiff Dennis Ryan Pro Se Defendant Tiffanic Shapiro, the Minor Plaintiff, by Stephanie Shapiro Hunt, her guardian, Plaintiff VS. IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6146 CIVIL TERM Dennis Ryan, Defendant PROTECTION FROM ABUSE MOTION FOR CONTINUANCE The plaintiff, Tiffanic Shapiro, by and through her attorney, Joan Carey of Legal Services, Inc. moves the Court for an Order rescheduling the hearing on the above-captioned case on the grounds that: A Temporary Protection From Abuse Order was issued by this Court on October 7, 1999, scheduling a hearing for December 2, 1999 at 1:30 p.m. 2. The Cumberland County Sheriffs Department deputized the Philadelphia Sheriffs Office who served Defendant with a certified copy of the Temporary Protection From Abuse Order on November 17, 1999, at 3700 Shcaff Lane Apt. B317, Philadelphia, Pennsylvania, 19145. 3. The parties agree that the hearing be rescheduled to afford them time to negotiate a consent agreement. 4. The plaintiff requests that the Temporary Protection Order remain in effect pending further Order of Court. WHEREFORE, the plaintiff requests that an Order for continuance be entered and that pending further Order of Court the Temporary Protection Order remain in effect. Respectfully submitted, a) Joan Carey Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, Pa 17013 L-? O v 1C-1 ? U Tiffnnic Shapiro, the Minor Plaintiff, by Stephanie Shapiro I Lunt, her guardian, Plaintiff V. Dennis li. Ryan, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA : NO. 99-6146 CIVIL. TERM PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, this ll day of December, 1999, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on December 13. 1999, by this Court's Order of December 2,1999, is hereby rescheduled for hearing on. December 27, 1999, at 1:30 p.m. in courtroom No. 2. The Temporary Protection Order shall remain in effect for one year or until modified or terminated by the court. The Cumberland County Sheriffs Department shall attempt to make service at the plaintiffs request and without pre-payment of fees, but service may be accomplished under any applicable rule of Civil Procedure. A certified copy of this Order for Continuance shall be provided to the Carlisle Police Department by the plaintiffs attorney. Joan Carey Legal Services, Inc. Attorney for Plaintiff Dennis Ryan Pro Se Defendant C??t . ?,.s GEC ?..f .1' F; Tiffanic Shapiro, the Minor Plaintiff, by Stephanie Shapiro Hunt, her guaridian, Plaintiff V. Dennis E. Ryon, Defendant IN TI IL• COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA NO. 99-6146 CIVIL TERM PROTECTION FROM ABUSE MOTION FOR CONTINUANCE The Plaintiff, Tiffanic Shapiro, 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: I. A Temporary Protection From Abuse Order was issued by this Court on October 7, 1999, scheduling a hearing for October 13, 1999, at 3:30 p.m. 2. A Continuance was filed December 2, 1999, rescheduling the hearing for December 13, 1999, at 10:30 a.m. 3. The parties agree that the hearing be rescheduled to afford them time to negotiate a consent agreement. 4. The Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of one year from the date it was entered or until further Order of Court, whichever comes first. 5. A certified copy of the Order for Continuance will be delivered to the Carlisle Police Department by the attorney for the Plaintiff. WHEREFORE, the 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 or until further Ordcr ofCourt, whichever comes first. Respectfully submitted, rt?? U 7-(.?? (,/Joan Carey , Attorney for Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 c?7 ?y 4! l yr J j . ' n ? fS Tiffanie Shapiro, the Minor Plaintifff, by Stephanie Shapiro Hunt, her guardian, Plaintiff VS. Dennis E. Ryan, Defendant IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-6146 CIVIL TERM PROTECTION FROM ABUSE FINAL PROTECTION ORDER Defendant's Name: Dennis E. Ryan Defendant's Date of Birth: July 4, 1978 Defendant's Social Security Number: Unknown to Plaintiff Names of Protected Person: Tiffanie Shapiro AND NOW, this ? day of December, 1999, the court having ' jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDGED, and DECREED as follows: The Plaintiff, Tiffanie Shapiro, Is represented by Joan Carey of Legal Services, Inc.; the Defendant, Dennis Ryan, is unrepresented, but has been advised of his right to counsel in this matter. The Defendant, although agreeing to the terms of this Order, does not admit the allegations made in the Petition. Plaintiffs request for a Finni Protectinn 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 the Plaintiff or any other protected person in any place where they might be found. O 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. ? On at m., Defendant may enter the residence to retrieve his/her clothing and other personal effects, provided that Defendant is in the company ofa law enforcement officer when such retrieval is made. ® 3. Defendant is prohibited from having ANY CONTACT with the Plaintiff at any location, including, but not limited to, any contact at the Plaintiff's school, residence, or place ofemployment. Defendant is specifically ordered to stay away from the following locations for the duration of this Order: Plaintiff's residence located at 152 North Pitt Street, Carlisle, Pennsylvania. Plaintiff's school located at Carlisle High School, Carlisle, Pennsylvania. Plaintiff's place of employment located at the Jewish Home of Harrisburg, Linglestown, Pennsylvania. © 4. Defendant shall not contact the Plaintiff by telephone or by any other means, including third parties. ? 5. Custody of the minor children, (names of the children subject to the provision of this paragraph] shall be as follows: [state to whom primary physical custody awarded; state terms of partial custody or visitation, if any](or see attached Custody Order) ? 6. Defendant shall immediately turn over to the 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 sheriffunder Paragraph 6 of this Order or under Paragraph 6 of the Temporary Order shall not be returned until further Order of Court. 0 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 by Plaintiff. The Defendant is to refrain from harassing Plaintiff's relatives. ? 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 (I5) 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 shallpay$ to Plaintiffas compensation for PlaintitTs 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 ?o 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 ? I. The 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 afler 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 persons. ? 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 and ? ANY PRIOR ORDER RELATING TO CHILD CUSTODY. ® 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 FNFORCEMF.NT 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 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 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. IfsuHicient grounds for violation ofthis Order are alleged, Defendant shall bgagaigned, bond set and both parties given notice of the date of the hearing. r Edgar B. This Order is entered pursuant to the consent ofPlaintitTand Defendant: 7`' anie Shapiro, Plaintiff Dennis E. Ryan, Defendant Pro?Se?'? ?. Ste ainie Shapiro Hun(, Guardia IC2-L2/' 9 RiIKS' f ? /?rcct?- 4 .Co A Carey, Attorney f laintiff P3 LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 ?? „_ .r„? ,,,; ^z? , ?, x ? cr ;?i ?'',1 3:1, • . ?, }, ,, ., , y w. ,: ??, ??, ?, ? °; 4, ? ;?Y s• ?`#'4 `nl ;? $x. i ,. x N SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1999-06146 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND SHAPIRO TIFFANIE M ET AL VS. RYAN DENNIS E R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, t6 wit: RYAN DENNIS E but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of PHILADELPHIA County, Pennsylvania. to serve the within PROTECTION FROM ABUSE On December 10th, 1999 , this office was in receipt of the attached return from PHILADELPHIA County, Pennsylvania. Sheriff's Coats: So answ s: Docketing 18.00 ?' Out of County 9.00 >? . Surcharge 8.00 mds &liriZ, onerlLL 0 00/00/0000 Sworn and subscribed to before me this IL day oK? 3e9 ;,7ov4-i A.D. SHKRIPP'S R[TURN - SUMMONS/COMPLAINT ,>l?ta ?0/ro VERSUS ,49e NU/s Z. A) COMMON PLEAS NO. F' O ? COUNTY COURT / TERM. 19 / f No. 6 /y6 a / ® Defendant SERVED AND MADE KNOWN TO ex,11V I e /c Y!'O ? Defendant Company by handing a true and attested copy of the within Summon s/Complaint, issued in the above captioned matter on /lc'.u 19 ? , at i o'clock, _$ M., E.S.T./D.S.T. at 276U L.,g.cJe , in the County of Philadelphia, State of Pennsylvania, to [$] (1) the aforesaid defendant, personally; ? (2) an adult member of the family of said defendant, with whom said defendant resides, who stated that his/her relationship to said defendant is that of ? (3) an adult person in charge of defendant's residence; the said adult person having refused, upon re- quest, to give his/her name and relationship to said defendant; ? (4) the manager/clerk of the place of lodging in which said defendant resides; ? (5) agent or person for the time being in charge of defendant's office or usual place of business. ? (6) the and officer of said defendant Company; So Answers, JOHN O. GREEN. Sheriff Deputy Sberill 12-39 (R*r. 1297) In The Court of Common Pleas of Cumberland County, Pennsylvania Shapiro Tiffanie, et. al. VS. Dennis E. Ryan No. 99-6146 Civil Now, 11/8/99 , 19_, I, SHERIFF OF CUMBERLAND COUNTY, PA, do hereby deputize the Sheriff of Philadelphia County to execute this Writ, this deputation being made at the request and risk of the Plaintiff. PFA is already in possession of the Phila - Ov?ct Co. Sheriff's Dept., enclosed find continu that corresponds. Thank You. Sheriff of Cumberland County, PA Affidavit of Service Now, , 19_, at within upon at by handing to a and made known to So answers, the contents thereof. Sheriff of Sworn and subscribed before me this _ day of , 19 O'clock M. served the copy of the original COSTS SERVICE _ MILEAGE _ AFFIDAVIT County, PA I?3Y[X¢•CK?M.txR'°Y ? . `?: u+l ?:'. ) `Y ? n. r..`e `.'" "i .c M.IA^ya}.. rr.Y ., ?wi .. • i[aer.y ? -? V a!n -a.. m!avve?++cesnvaw.....nun+m 07/99 THU 12:43 FAX 717 240 8573 corn en DRn'rnnNrer10V 9O. L l4!_ c sstsssssssttssssesstt ses TX REPORT sst sssststssststsssstess TRANSMISSION OK TX/RX NO 1520 CONNECTION TEL 92490779 CONNECTION ID ST. TIME 10/07 12:38 USAGE T 04'48 PCS. 11 RESULT OK /21/80 TUE 10:22 PAX 717 210 8573 rltrn rn vwminvr Anv .?_ sss TI REPORT •ss ss.?ss.sssssea..s.ss TRANSMISSION OK TX/RX NO CONNECTION TEL CONNECTION ID ST. TIME USAGE T PGS. RESULT 1045 02100778 12/21 10:17 05'15 7 OK r ,