HomeMy WebLinkAbout99-07640
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Rachael A. Roberts, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 99- -A - I0 CIVIL TERM
Christopher Roberts,
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 AT
r2. c^J ,MIN COURTROOM NO.--2-017 THE CUMBERLAND
COUNTY COURT OUSE, CARLISLE, PENNSYLVANIA.
You MUST obey the Order that is attached until it is modified or terminated by the court
after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this
Ordermay subject you to a charge of indirect criminal contempt which is punishable by a fine ofup
to S 1,000.00 and/or up to six months in jail under 23 Pa.C.S. §6114. Violation may also subject you
to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18
U.S.C. §2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories
and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate
this Order, you may be subject to federal criminal proceedings under the Violence Against Women
Act, 18 U.S.C. § 2261-2262.
You should take this paper to your lawyer at once. You have the right to have a lawyer
represent you at the hearing. The court will not, however, appoint a lawyer for you. If you
do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find
out where you can get legal help. If you cannot find a lawyer, you may have to proceed
without one.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE, CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717)249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact
our office. All arrangements must be made at least 72 hours prior to any hearing or business before
the court. You must attend the scheduled conference or hearing.
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Rachael A. Roberts,
Plaintiff
Vs.
Christopher Roberts,
Defendant
IN THE COURT OF COMMON PLEAS OF
:CUMBERLAND COUNTY, PENNSYLVANIA
:NO.99- '76'10 CIVILTERM
PROTECTION FROM ABUSE
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name: Christopher Roberts
Defendant's Date of Birth: 12/14/71
Defendant's Social Security Number: 189-62-8095
Names of the Protected Person: Rachael Roberts
AND NOW, this 23 ?dayofDecember,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 the above protected
person in any place where she might be found.
2. Defendant is evicted and excluded from the residence at 215 Reno
Avenue, New Cumberland, Pennsylvania, or any other permanent or temporary
residence where Plaintiff may live. Plaintiff is granted exclusive possession of the
residence. Defendant shall have no right or privilege to enter or be present on the
premises.
3. Except for contact regarding the minor children, Defendant is prohibited
from having ANY CONTACT with Plaintiff at any location, including, but not limited,
to any contact at Plaintiffs residence or place of employment. Defendant is specifically
ordered to stay away from the following locations for the duration of this Order: Any
place where Plaintiff is employed.
4. Except for contact regarding the minor children, 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: Joshua J. Roberts (DOB
12/16/95) and Jerimiah T. Roberts (DOB 3/9/98).
Until the final hearing, all contact between Defendant and the children
shall be limited to the following: Plaintiff shall have primary physical
custody of the children. Defendant shall have a right to visitation with
the children at times and places agreed upon by the parties.
The local law enforcement agency in the jurisdiction where the children
are located shall ensure that the children are placed in the care and
control of Plaintiff in accordance with the terms of this Order.
? 6. Defendant shall immediately relinquish the following weapons to the Sheriffs
Office or a designated local law enforcement agency for the delivery to the Sheriffs Office:
Defendant is prohibited from possessing, transferring or acquiring anyotherweapons
for the duration of this Order.
X? 7. The following additional relief is granted:
The Cumberland County Sheriffs Department shall attempt to make
service at Plaintiff's requestandwithoutpre-payment of fees, butservice
may be accomplished under any applicable Rule of Civil Procedure.
This Order shall be docketed in the office of the Prothonotary and
forwarded to the Sheriff for service. The Prothonotary shall not send a
copy of this Order to Defendant by mail.
This Order shall remain in effect until modified or terminated by the
Court and can be extended beyond its original expiration date if the
Court finds that Defendant has committed an act of abuse or has
engaged in a pattern or practice that indicates risk of harm to Plaintiff.
Defendant is enjoined from damaging or destroying any property owned
jointly by the parties or owned solely by Plaintiff.
Defendant is to refrain from harassing Plaintiffs relatives.
8. A certified copy of this Order shall be provided to the police department
where Plaintiff resides and any other agency specified hereafter: New Cumberland
Police Department.
P, _1
-..-M
? 9. THIS ORDER SUPERSEDES
? ANY PRIOR PFA ORDER and
? ANY PRIOR ORDER RELATING TO CHILD CUSTODY
10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND
SHALL REMAIN IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS
COURT AFTER NOTICE AND HEARING.
NOTICE TO DEFENDANT
Defendant is hereby notified that violation of this Order may result in arrest for
indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up
to six months in jail. 23 Pa.C.S. §6114. Consent of the Plaintiff to Defendant's return
to the residence shall not invalidate this Order, which can only be changed or modified
through the filing of appropriate court papers for that purpose. 23 Pa.C.S. §6113.
Defendant is further notified that violation of this Order may subject him/her to state
charges and penalties under the Pennsylvania Crimes Code and to federal charges and
penalties under the Violence Against Women Act, 18 U.S.C. §§ 2261-2262. Any
protection order granted by a court may be considered in any subsequent proceedings,
including child custody proceedings, under title 23 (Domestic Relations) of the
Pennsylvania Consolidated Statutes.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the police who have jurisdiction over the
plaintiff's residence OR any locations where a violation of this order occurs OR where
the defendant may be located. If defendant violates Paragraphs 1 through 6 of this
Order, defendant may be arrested on the charge of Indirect Criminal Contempt. An
arrest for violation of this Order may be made without warrant, based solely on
probable cause, whether or not the violation is committed in the presence of law
enforcement.
Subsequent to an arrest, the law enforcement officer shall seize all weapons used
or threatened to be used during the violation of this Order OR during prior incidents
of abuse. Weapons must forthwith be delivered to the Sheriff's 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.
Rachael A. Roberts, : IN THE COURT OF COMMON PLEAS OF
Plaintiff'
: CUMBERLAND COUNTY, PENNSYLVANIA
vs.
: NO.99- CIVIL TERM
Christopher Roberts,
Defendant : PROTECTION FROM ABUSE
PETITION FOR PROTECTION FROM ABUSE
The Plaintiff is Rachael A. Roberts.
2. The name of the person who seeks protection from abuse is Rachael A. Roberts.
3. Plaintiff's address is 215 Reno Avenue, New Cumberland, Pennsylvania.
4. Defendant is believed to live at 1528 Meadowlark Way, Harrisburg, Pennsylvania.
Defendant's Social Security Number is 189-62-8095.
Defendant's date of birth is 12/14/71.
Defendant's place of employment is PHEAA, Harrisburg, Pennsylvania.
5. Defendant is Plaintiffs husband.
6. Plaintiff and Defendant have been involved in the following court actions for divorce::
Case name Case No. Date filed Court
Roberts v. Roberts 99-5837 9/22/99 Cumberland Co.-Common Pleas
7. Plaintiff seeks temporary c ustody of the following children:
Name Address Birthdate
Joshua J. Roberts 215 Reno Ave. 12/16/95
Jeremiah T. Roberts New Cumberland, Pa 3/9/98
8. Plaintiff and Defendant are the parents of the following minor child/ren:
Name Ase
Joshua J. Roberts 4 years old
Jeremiah T. Roberts 1 '/- years old
The following info rniation is provided in support of Plaintift's request for an Order of
child custody:
a) The children were not born out ofWedloek.
b) The children are presently in the custody of Plaintiff, Racael Roberts, who
resides at 215 Reno Avenue. New Cumberland, Cumberland County, Pennsylvania.
C) During the past five years the child have resided with the following persons and
at the following addresses:
Persons children lived with Address
Maternal grandmother, Watertown, N.Y.
When
12/95 to 2/96
Plaintiff and Defendan
Plaintiff and Defendant
1610 Blue Mountain
Parkway, Harrisburg,
2/96 to 6/96
Plaintiff and Defendant
Plaintiff and Defendant
197 Joya Circle
Harrisburg, Pa
215 Reno Avenue
New Cumberland, Pa
6/96 to 7/97
7/97/ to Present
d) Plaintiff, the mother of the children, is currently residing at 215 Reno Avenue,
New Cumberland, Cumberland County, Pennsylvania.
C) She married.
0 Plaintiff currently resides with the following persons:
Name Relationship
Joshua Roberts Son
Jerimiah Roberts Son
g) Defendant, the father of the children, is currently residing at 1528 Meadowlark
Way, Harrisburg, Cumberland County, Pennsylvania.
h) He is married.
i) Defendant currently resides with the following persons:
Name Relationship
Ken Roberts Father
j) Plaintiff has not previously participated in any litigation concerning custody of
the above mentioned children in this or any other Court.
k) Plaintiff has no knowledge ofany custody proceedings concerning therechildren
pending before a court in this or any other jurisdiction.
1) Plaintiff does not know any person not a party to this action who has physical
custody ofthe children or claims to have custody or visitation rights with respect to the
children.
nt) The best interests and permanent welfare of the minor children will be met if
custody is temporarily granted to Plaintiff pending a hearing in this matter for reasons
including:
1) Plaintiff is a responsible parent who has provided for the
emotional and physical needs of the children since their births,
and who can best take care of the minor children.
2) Defendant has shown by his abuse of Plaintiff that he is not an
appropriate role model for the minor children.
9. The facts of the most recent incident of abuse are as follows:
On or about December 13, 1999, Defendant told Plaintiff he wanted half
of everything in the house and would use a chainsaw if he had to causing
her to fear for her safety. Defendant left the residence and called Plaintiff
8 times in an hour and a half in spite of Plaintiffs telling him she did not
want to speak to him causing her to fear for her safety.
10. Defendant has committed the following prior acts of abuse against Plaintiff:
a) On or about December 11, 1999, Defendant called Plaintiff
approximately 30 times in the evening. During the first 15 calls
Defendant threatened that he would do whatever he needed to get her
back causing her to fear for her safety. During the next 15 calls
Defendant continued to threaten Plaintiff saying that he would make her
life miserable exacerbating Plaintiffs fear because of Defendant's
escalating anger and persistence. When Plaintiff reminded Defendant of
the letter he received from Legal Services which informed him of her
criminal and civil legal remedies if he continued to threaten or abuse her,
Defendant said that he did not care and that he would go to jail because
he wanted her back.
b) On or about December 3, 1999, Defendant followed Plaintiff to her car
in spite of her telling him to leave her alone, blocked her car door so she
could not get in, and grabbed her, bumped up against her, and forced
unwanted sexual advances upon her.
C) On or about September 11, 1999, Defendant made unwanted sexual
advances toward Plaintiff causing her to fear for her safety.
d) In or about May 1999, Defendant became depressed and stated that he
could not go on and that he wanted to end it causing her to fear for her
safety because of his instability and past violence toward her.
C) In or about December 1997, Defendant punched Plaintiff in the hands
and anus, grabbed her by the hair and pulled her head back. As Plaintiff
stood beside the open ear door, Defendant backed up the car causing the
door to hit her in the stomach. Defendant got out of the car, grabbed
Plaintiff by the throat, and threatened to kill her.
f) Since 1996, Defendant has abused Plaintiff in ways including the
following : pushed and grabbed her; hit her in the head with a soda can;
made unwanted sexual advances, and intimidated her by raising his
hands as if he were going to hit her. On one occasion, Defendant became
angry, grabbed Plaintiff and forcefully pushed her down the hall, threw
her onto the bed, ripped her clothes, forced her legs apart, and punched
her in the stomach and thighs when she screamed for him to stop.
11. The following police department or law enforcement agency in the area in which
Plaintiff lives should be provided with a copy of the Protection Order: New Cumberland
Borough Police.
12. There is an immediate and present danger of further abuse from Defendant.
WHEREFORE, PLAINTIFF REQUESTS THAT THE COURT ENTER A
TEMPORARY ORDER, AND AFTER HEARING, A FINAL ORDER THAT
WOULD DO THE FOLLOWING:
A. Restrain Defendant from abusing, threatening, harassing, or stalking
Plaintiff in any place where Plaintiff may be found.
B. Evict and Exclude Defendant from the residence and prohibit Defendant
from attempting to enter any temporary or permanent residence of the Plaintiff.
C. Prohibit Defendant from having any contact with Plaintiff either in
person, by telephone, or in writing, personally or through third persons,
including, but not limited to, any contact at Plaintiffs residence or place of
employment, except as the Court may find necessary with respect to partial
custody and/or visitation with the minor children.
D. Prohibit Defendant from having any contact with Plaintiffs relatives.
E. Order Defendant to pay S25.00 for 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:
The Defendant is enjoined from damaging or destroying any property
owned jointly by the parties or owned solely by Plaintiff.
The Defendant is to refrain from harassing 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
Defendant's residence, where Defendant can be served.
Plaintiff prays for such other relief as may be just and proper.
Respectfully submitted,
?j
I
'/Joan Carey, Attorney for Iaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
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 arc made subject to the penalties of 18 Pa.C.S. §4904, relating
to unswom falsification to authorities.
Dated: /2 / 7/99
Rachael Roberts, Plaintiff
,_:
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Rachael A. Roberts,
Plaintiff
`vy
Christopher Roberts,
VS.
Defendant
IN THE COURT OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99- 11[ qD CIVIL TERM
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.
AHEAR_ING ON THIS MATTER IS SCHEDULED ON ? a ,1999; AT
M., IN COURTROOM NO. 3_ OF THE CUMBERLAND
COUNTY COURT OUSE, CARLISLE, PENNSYLVANIA.
You MUST obey the Order that is attached until it is modified or terminated by the court
after notice and hearing. If you disobey this Order, the police may arrest you. Violation of this
Order may subject you to a charge of indirect criminal contempt which is punishable by a fine of up
to$1,000.00and/or uptosixmonths injail under 23Pa.C.S.§6114. Violation may also subject you
to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18
U.S.C. §2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories
and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate
this Order, you may be subject to federal criminal proceedings under the Violence Against Women
Act, 18 U.S.C. § 2261-2262.
You should take this paper to your lawyer at once. You have the right to have a lawyer
represent you at the hearing. The court will not, however, appoint a lawyer for you. If you
do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find
out where you can get legal help. If you cannot find a lawyer, you may have to proceed
without one.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE, CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717)249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact
our office. All arrangements must be made at least 72 hours prior to any hearing or business before
the court. You must attend the scheduled conference or hearing.
Rachael A. Roberts, : IN THE COURT OF COMMON PLEAS Of
Plaintiff
VS.
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99 96`/0 CIVIL TERM
Christopher Roberts,
Defendant : PROTECTION FROM ABUSE
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name: Christopher Roberts
Defendant's Date of Birth: 12/14/71
Defendant's Social Security Number: 189-62-8095
Names of the Protected Person: Rachael Roberts
A
AND NOW, this -??dayofDecember, 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 the above protected
person in any place where she might be found.
2. Defendant is evicted and excluded from the residence at 215 Reno
Avenue, New Cumberland, Pennsylvania, or any other permanent or temporary
residence where Plaintiff may live. Plaintiff is granted exclusive possession of the
residence. Defendant shall have no right or privilege to enter or be present on the
premises.
[9> 3. Except for contact regarding the minor children, Defendant is prohibited
from having ANY CONTACT with Plaintiff at any location, including, but not limited,
to any contact at Plaintiff's residence or place of employment. Defendant is specifically
ordered to stay away from the following locations for the duration of this Order: Any
place where Plaintiff is employed.
?vfxa4?
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4. Except for contact regarding the minor children, Defendant shall not
contact Plaintiff by telephone or by any other means, including through third persons.
? ANY rkuVxrrn,........,.-_.
? ANY PRIOR ORDER RELATING TO CHILD CUSTODY
XC> 10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND
SHALL REMAIN IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS
COURT AFTER NOTICE AND HEARING.
NOTICE TO DEFENDANT
Defendant is hereby notified that violation of this Order may result in arrest for
indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or up
to six months in jail. 23 Pa.C.S. §6114. Consent of the Plaintiff to Defendant's return
to the the shall notite courtt papers for that purpose.h23 geda.Cor.Smodified. §6 13. this Order, which can only be through hrough the fi filing ling appropriate
Defendant is further r notified that violation of this Order may subject him/her to state
charges and penalties under the Pennsylvania Crimes Code and to federal charges and
penalties under the Violence Against Women Act, 18 U.S.C. §§ 2261-2262• Any
protection order granted by a court may be considered in any subsequent proceedings,
including child custody proceedings, under title 23 (Domestic Relations) of the
Pennsylvania Consolidated Statutes.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the police who have jurisdiction over the
plaintiffs residence OR any locations where a violation of this order occurs OR where
the defendant may be located. If defendant violates Paragraphs 1 through 6 of this
Order, defendant may be arrested on the charge of Indirect Criminal Contempt. An
arrest for violation of this Order may be made without warrant, based solely on
probable cause, whether or not the violation is committed in the presence of law
used
enforcement.
Subsequent to an arrest, the law enforcement officer shall seize all weapon dents
or threatened to be used during the violation of this Order OR during prior 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 they shall remain hwi with the law unless the weapon/s are evidence of a crime, in which
enforcement agency whose officer m de the arrest.
Christopher Roberts,
Defendant ;PROTECTION FROM ABUSE
PETITION FOR PROTECTION FROM ABUSE
1. The Plaintiff is Rachael A. Roberts.
2. The name of the person who seeks protection from abuse is Rachael A. Roberts.
3, Plaintiffs address is 215 Reno Avenue, New Cumberland, Pennsylvania.
4, Defendant is believed to live at 1528 Meadowlark Way, Harrisburg, Pennsylvania.
Defendant's Social Security Number is 189-62-8095.
Defendant's date of birth is 12/14/71.
Defendant's place of employment is PHEAA, Harrisburg, Pennsylvania.
5, Defendant is Plaintiffs husband.
6. Plaintiff and Defendant have been involved in the following court actions for divorce::
Case name Case No. Date filed Court Roberts v. Roberts 99-5837 9/22/99 Cumberland Co.-Common Pleas
7. Plaintiff seeks temporary custody of the following children:
Name Address Birthdate
Joshua J. Roberts 215 Reno Ave. 12/16/95 Jeremiah T. Roberts New Cumberland, Pa 3/9/98
8. Plaintiff and Defendant are the parents of the following minor children:
Name Age
Joshua J. Roberts 4 years old
Jeremiah T. Roberts 1 '/2 years old
vs. CIVILTERM
N0.99- 2?o _
Rachael A. Roberts, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
:CUMBERLAND COUNTY, PENNSYLVANIA
VS.
: NO. 99-7640 CIVIL TERM
Christopher Roberts,
Defendant : PROTECTION FROM ABUSE CUSTODY
AND NOW, thisliday of December, 1999, upon consideration of the attached
Motion for Continuance, the matter scheduled for hearing on December 29, 1999, by this
Court's Order of December 23, 1999, is hereby rescheduled forbearing on January 10, 2000,
at 3:30 p.m. in Courtroom No. 3.
The Temporary Protection From Abuse Order shall remain in effect for a period of
one year from the date it was entered or until further Order of Court, whichever comes first.
A certified copy of this Order for Continuance will be provided to the New
Cumberland Police Department by the plaintiffs attorney.
By the Court,
Judge
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
Ralph Pinskey
PINSKEY AND FOSTER
Attorney for Defendant
,C? '472
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Rachael A. Roberts, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
:CUMBERLAND COUNTY, PENNSYLVANIA
VS.
NO. 99-7640 CIVIL TERM
Christopher Roberts,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
MOTION FOR CONTINUANCE
The Plaintiff, Rachael Roberts, by and through her attorney, Joan Carey of Legal
Services, Inc., moves the Court for an Order rescheduling the hearing in the above-captioned
case on the grounds that:
A Temporary Protection From Abuse Order was issued by this Court on
December 23, 1999, scheduling a hearing for December 29, 1999, at 2:00 p.m.
2. The Cumberland County Sheriffs Department served Defendant with a
certified copy of the Temporary Protection From Abuse Order and Petition for Protection
From Abuse at his residence,1528 Meadowlark Way, Harrisburg, Pennsylvania, on
December 28, 1999, at 4:00 p.m.
3. The parties agree, by and through their counsel, that the hearing be
rescheduled at the request of Defendant's counsel.
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.
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5. A certified copy of the Order for Continuance will be provided to the New
Cumberland 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 Order of Court,
whichever comes first.
Respectfully submitted,
iian Carey, Attorney for laintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
Rachael A. Roberts, : IN TFIE COURT OF COMMON PLEAS OF
Plaintiff
CUMBERLAND COUNTY, PENNSYLVANIA
v : NO. 99-7640 CIVIL TERM
Christopher Roberts,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
AND NOW, this
l
day of January, 2000, upon consideration of the attached Motion for
Continuance, the matter scheduled for hearing on January 10, 2000, by this Court's Order of
December 29, 1999, is hereby rescheduled for hearing on February 9, 2000, at 10:00 a.m. in
Courtroom No. 3.
The Temporary Protection From Abuse order shall remain in effect for a period of one year
from the date it was entered or until further Order of Court, whichever comes first.
A certified copy of this Order for Continuance will be provided to the New Cumberland
Police Department by the plaintiff's attorney.
By the Court,
E. Hoffer
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
?Co?u?l •/?`
-Ze -00
ono
Judge
Ralph Pinskey
PINSKEY AND FOSTER
Attorney for Defendant
I Rachael A. Roberts, : IN THE COURT OF COMMON PLEAS OF
Plaintiff'
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
NO. 99-7640 CIVIL TERM
Christopher Roberts,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
MOTION FOR CONTINUANCE
The Plaintiff, Rachael Roberts, by and through her attorney, Joan Carey of Legal
Services, Inc., moves the Court loran 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
December 23, 1999 scheduling a hearing for December 29, 1999, at 2:00 p.m.
2. A Continuance was filed on December 29,1999, rescheduling the hearing for
January 10, 2000, at 3:30 p.m.
3. The parties agree, by and through their counsel, that the hearing be
rescheduled to afford
them time to execute a Consent Agreement.
4. The Plaintiff requests that the Temporary Protection From Abuse Order
I
remain in effect fbr 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 provided to the New
Cumberland 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 f'or a period of one year from the date it was entered or until further Order of Court,
whichever comes first.
Respectfully submitted,
or Carey, Attome/ Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717)243-9400
SHERIFF'S RETURN - OUT OF COUNTY
CASE NO: 1999-07640 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
ROBERTS RACHAEL A
VS
ROBERTS CHRISTOPHER
R. Thomas Kline Sheriff or Deputy Sheriff who being
duly sworn according to law, says, that he made a diligent search and
and inquiry for the within named DEFENDANT , to wit:
ROBERTS CHRISTOPHER
but was unable to locate Him in his bailiwick. He therefore
deputized the sheriff of DAUPHIN County, Pennsylvania, to
serve the within PROTECTION FROM ABUSE
On January 11th , 2000 , this office was in receipt of the
attached return from DAUPHIN
Sheriff's Costs:
Docketing 18.00
Out of County 9.00
Surcharge 8.00
DEP. DAUPHIN CO 25.50
.00
60.50
01/11/2000
Sworn and subscribed to before me
this jl.,r day of t?!?
So an wars ?
R'.' Thomas Kline /
Sheriff of Cumberland County
vov A.D.
Prothonotary
of fire of '4r C*4eri ff
Nlarv Jane Sncder
Read Emilie Ihpnc
William T. Tully
Solicitor
Dauphin Cauaq
Harrisburg. Pennsylvania 17101
plr (717) 255-206o 1h:(717)255-2889
Jack Lotwick
Sheriff
Commonwealth of Pennsylvania ROBERTS RACHAEL
vs
County of Dauphin ROBERTS CHRISTOPHER
Sheriff's Return
No. 2609-T - - -1999
OTHER COUNTY NO. 99-7690
Ralph G. McAllister
Chief Ik-putS
Michael W. Rinehart
Assistma Chief IkputS
AND NOW: December 28, 1999 at 9:OOPM served the within
PFA & ORDER Upon
ROBERTS CHRISTOPHER by personally handing
to DEFT 1 true attested copy(ies)
of the original PFA & ORDER and making known
to him/her the contents thereof at 1528 MEADOWLARK WAY
HARRISBURG, PA 00000-0000
Sworn and subscribed to
before me this 29TH day of DECEMBER, 1999
?L?
PROTHONOTARY
So Answers,
?)e?9 /(
Sheriff of D hin Canty- a.
By
D uty?SS(h?je?,riff
Sheriff's Costs: S0.00 PD 00/00/0000
RCPT NO
ET
In The Court of Common Pleas of Cumberland County, Pennsylvania
Rachael A. Roberts
VS.
Christopher Roberts
No. 99-7640 Civil
Now, 12/23/99 19_, I, SHERIFF OF CUMBERLAND COUNTY, PA, do
hereby deputize the Sheriff of Dauphin County to execute this Writ, this
deputation being made at the request and risk of the Pl
00 aintiff. i'"e 5 -?
e
Sheriff of Cumberland County, PA
Affidavit of Service
Now, _
within
upon
at
by handing to _
a
and made known to
copy of the original
So answers,
the contents thereof.
Sheriff of
Sworn and subscribed before
me this _ day of , 19
COSTS
SERVICE _
MILEAGE _
AFFIDAVIT
County, PA
S
S
19_, at o'clock M. served the
gn4?C'.:i
Rachael A. Roberts, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
:CUMBERLAND COUNTY, PENNSYLVANIA
VS.
: NO.99-7640 CIVIL TERM
Christopher Roberts,
Defendant : PROTECTION FROM ABUSE CUSTODY
0" ®R I UAI-CIE 71000
AND NOW, this day of Doee+rrbe?!R?, upon consideration of the attached
Motion for Continuance, the matter scheduled for hearing on February 9, 2000, by this
Court's Order of January 6, 2000, is hereby generally continued.
This Order is entered without prejudice to either party to request a hearing.
The Temporary Protection From Abuse Order shall remain in effect for a period of
one year from the date it was entered or until further Order of Court, whichever comes first.
A certified copy of this Order for Continuance will be provided to the New
Cumberland Police Department by the plaintiffs attorney.
By the Court,
E. Hover, President Judge
Joan Carey
LEGAL SERVICES, INC.
Attorney for Plaintiff
Ralph Pinskey
PINSKEY AND FOSTER
Attorney for Defendant
r_ ?
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v'-
YG ,._'?i., r.. ...
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?!,
S? _._.,,?_.®
Rachael A. Roberts, : IN THE COURT OF COMMON PLEAS OF
Plaintiff
VS.
:CUMBERLAND COUNTY, PENNSYLVANIA
NO. 99-7040 CIVIL TERN
Christopher 2oberts,
Defendant : PROTECTION FROM ABUSE AND CUSTODY
MOTION FOR CONTINUANCE
The Plaintiff, Rachael Roberts, by and through her attorney, Joan Carey of Legal
Services, Inc., moves the Court foran Order for a general continuance in the above-captioned
case on the grounds that:
A Continuance was filed on January 6, 2000, scheduling a hearing for
February 9, 2000, at 10:00 a.m.
2. The Cumberland County Sheriffs Department served Defendant with a
certified copy of the Temporary Protection From Abuse Order and Petition for Protection
From Abuse at his residence,1528 Meadowlark Way, Harrisburg, Pennsylvania, on
December 28, 1999, at 4:00 p.m.
3. The parties agree, by and through their counsel, that the hearing be generally
continued to afford them time to execute an 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.
A certified copy of the Order for Continuance will be provided to the New
Cumberland Police Department by the attorney for the Plaintiff.
WHEREFORE, the Plaintiff requests that the Court grant this Motion and generally
continue this matter 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,
i
Moan Carey, Attorne or Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
r.--
Rachael A. Roberts. : IN'TI IE COIJRT OF COMMON PLEAS OF
Plaintiff ; CUMBERLAND COUNTY. PENNSYLVANIA
vs.
N0.99 - 7640 CIVIL"PERM
By the Court.
Christopher Roberts.
Defendant : PROTECTION FROM A13USE
AND CUSTODY
ORDf.11: OF COURT
AND NOW. this 4:7 day of March. 2000. upon consideration of the attached
Petition. the Final Protection Order in the above captioned case dated December 23, 1999, is
hereby vacated and the action withdrawn without prejudice to Plaintiff.
Joan Carey
Attorney for Plaintiff
Ralph Pinskey
Attorney for Defendant
/rg E. Hoffer, Preside t Judge
d0
GU Fi"o " 17 Ali 10: 5
rr3UN7Y
PEN, YL MA-N k
Rachael A. Roberts. : IN THE COURT OF COMMON PLEAS OF
Plaintiff'
CUMBERLAND COUNTY. PENNSYLVANIA
VS.
NO.99-7640 CIVILTERM
Christopher Roberts,
Defendant : PROTECTION FROM ABUSE"
AND CUSTODY
PETITION TO VACATE ORDER AND WITHDRAW ACTION
Plaintiff requests the Court vacate the Temporary Protection From Abuse Order in the
above-captioned case on the grounds that:
A Temporary Protection Order was issued by this Court on December 23. 1999, in
scheduling a hearing for December 29, 1999, at 2:00 p.m.
2. The parties agreed to generally continue the hearing for the Protection from Abuse
until all issues were resolved through a divorce.
3. The signed final divorce papers were filed on March 8, 2000, in the Cumberland
County Courthouse.
4. At this time Plaintiff requests that the Temporary Order entered on December 23,
1999, be vacated without prejudice.
WHEREFORE. Plaintiff requests that the Court grant the relief requested and
vacate the Order without prejudice.
Respectfully submitted,
?? Y?LV V"? _' L'?
J' Joan Carey. Attorney f Plaintiff
LEGAL SERVICES. 64C.
8 Irvine Row
Carlisle. PA 17013
(717) 243-9400
n::_
VERIFICATION
I verify that tam the Petitioner as designated in the present action and that the facts and
statements contained in the above Petition are true and correct to the best of my knowledge.
I understand that any false statements are made subject to the penalties of 18 Pa.C.S. §4904,
relating to unsworn falsification to authorities.
Dated: iS.6O
Rachad A. Robins, Plai,itiff
19/93/99 Tj!U 99.51 RAY 717 24O 8573
CUMB CO PROTHONOTARY qq_ 7LYO
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TRANSMISSION OR
TX/RX NO 1651
CONNECTION TEL 92490779
CONNECTION ID
ST. TIME 12/23 09:43
USAGE T 08'01
PGS. 12
RESULT OK
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