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HomeMy WebLinkAbout99-07746 •. .a' J ?:r; j'v w, ?, r,?z ;?'? z ?i' ?,,?? f± LAW OFFICES MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET P.O. BO% 1062 HARRISBURG, PA. 17106 171712369426 1. EMANUEL MEYERS 0915-19701 FAX (7171236-2817 BRUCE D. DESFOR LAURIE A. SALTZGIVER CATHERINE A. BOYLE ,.C {Y\??rf{ January 4, 2000 The Honorable J. Wesley Oler CUMBERLAND COUNTY COURTHOUSE 1 Courthouse Square Carlisle, PA 17013 Re: David A Mangam v Booumila Mangam Dear Judge Oler: Enclosed please find courtesy copies of my client's Answer to Wife's Petition for Protection from Abuse which is currently scheduled for a hearing before you on January 7, 2000 at 11:15 a. m. Also, enclosed please find a copy of a Petition for Protection from Abuse filed by David Mangam. If possible, would you kindly schedule the enclosed Petition for the same date and time as Wife's Petition. Thank you for your attention to this matter. If you have any questions, please do not hesitate to contact me. CAB/skc enclosures cc: David Man Matthew J very /?yours, ,? truly `?/? ///J? BOGUMILA MANGAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. No. DAVID A. MANGAM, CIVIL ACTION - LAW Defendant PROTECTION FROM ABUSE TEMPORARY ORDER 5 AND NOW, this day of ?e c e--? es 1999, upon review of the Petition of Plaintiff, the court enters the following Temporary Order: 1. The defendant shall refrain from abusing, harassing, threatening, or stalking the Plaintiff or the minor children or placing any of them in fear of abuse in any place where they may be found. 2.'T1 defendant is enjoined and prohibited from wing at, entering, attem to ente ,--or " visiting the residence of Plaintiff located at array Drive, Mechanicsburg, PA 17055, within this C a y, and an Sequent residence in which Plaintif esides during the pen e f this Order, and iff is granted exclusive possession of the premises. 3`T ant is prohibited from having an the Plaintiff, inclu of li , entering the place of employment, business e o of Y.ie ?r Lhe minor children, and rassing the Plaintiff. 7 4. ThP-Pra3?!t rf f? ward orary cus o y o en, Caro .tne ang am. 5. The defendant is ordered to provide the following additional relief: 6. This Order shall be enforced by any law enforcement agency in a County where a violation of this order occurs. 7. Law enforcement officers, the staff of the County Registry of Protection Orders, and Court personnel shall not disclose the address of the domestic violence program or any confidential address of the plaintiff to the defendant, his counsel, or any third party. 8. A copy of this Order shall be served on the Hampden Township police departments. This Order shall, likewise, be served on the State Police. A copy of this Order shall be forthwith filed in the County Registry of Protection Orders. Copies shall also be provided to the Sheriff, the Prothonotary, the plaintiff's counsel, and the plaintiff. 9. The Sheriff or (Specify other adult individual) is directed to serve and file the aforementioned copies of this Order without prepayment of costs. Said copies shall be certified. 10. This Order shall remain in full force and effect until modified or terminated by this Court. 11. The defendant's Social Security number is 089-38-5288. The date of birth of the defendant is August 9, 1943. 12. A hearing shall be held on the ? day of? 1999 200 at //.'.t LS- A.? P.M. in courtroom No. of the Cumber and Couny Court ouse, located at one Courthouse Square, Carlisle, Pennsylvania 17013. 13. THIS IS AN ORDER OF COURT. ANY VIOLATION OF THIS ORDER SHALL CONSTITUTE CONTEMPT OF COURT AND MAY BE PUNISHABLE BY A FINE UP TO $1,000.00 AND A JAIL SENTENCE OF UP TO SIX MONTHS. BY THE COURT J. ?...- ? i, I .. i I .. .ter. ?? Myra ?... ?....?.....?: N?vLw`i ?i BOGUMILA MANGAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. No. 94- '77 qC. C' ,.t 72, DAVID A. MANGAM, CIVIL ACTION - LAW Defendant PROTECTION FROM ABUSE NOTICE TO DEFEND YOU HAVE BEEN SUED IN COURT. The Plaintiff is the person suing on behalf of the abused person(s). Attached is a copy of the Petition which indicates the relief the Plaintiff is requesting. Also included in the Petition are Plaintiff's reasons for these requests. You must appear at the hearing on the day of 1999/2000, at A.M./P.M. in Court Room No. of the Court of Common Pleas of Cumberland County, located at One Courthouse Square, Carlisle, Pennsylvania 17013. If you do not appear at the hearing at the time and place as set forth above, the Order requested by Plaintiff may be granted in your absence, and you may lose money or property rights or other rights important to you, and/or a bench warrant may be issued directing the Sheriff to bring you into Court. If a copy of a TEMPORARY ORDER is attached, you must obey it until the hearing. If you do not obey it, the police can arrest you and you may be charged with indirect Criminal Contempt. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. YOU HAVE A RIGHT TO HAVE AN ATTORNEY REPRESENT YOU AT THE HEARING. 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 MAY GET LEGAL HELP. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 BOGUMILA MANGAM, Plaintiff vs. DAVID A. MANGAM, Defendant : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA No. 99. 771/4 a,*. j -rG.-- CIVIL ACTION - LAW PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE TO THE HONORABLE JUDGE OF SAID COURT: 1. My name is Bogumila Mangam. I am the Plaintiff in this case. I am an adult individual. 2. I live in this County at 3818 Pamay Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 3. 1 am filing this Petition for temporary and final protection Orders pursuant to the Protection From Abuse Act, 23 Pa.C.S.A. Section 6101 et seq. I am also seeking relief as guardian for the children whose names are Caroline A. Mangam and Victoria 0. Mangam. 4. The abused persons are living in this County at the marital residence of 3818 Pamay Drive, Mechanicsburg, Pennsylvania 17055. 5. The person I am filing this Petition against is David A. Mangam, the defendant, who resides at 3818 Pamay Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055. 6. The defendant's Social Security number is 089-34-5288. The defendant's date of birth is August 09, 1943. 7. The defendant is related to the abused person(s) as husband and father. 8. The defendant works at Collins Hall, U.S. Army War College, Carlisle Barracks, located at Carlisle, Pennsylvania 17013. 9. The name(s) of the owner(s) or renter(s) of the residence from which I am asking the Court to exclude the defendant are David A. Mangam and Bogumila Mangam. 10. The facts of the most recent incident of abuse are as follows: Date: December 18, 1999 Time: 11:30 p.m. Location: 3818 Pamay Drive, Mechanicsburg, Pennysylvania Statement: The Defendant and I were having a verbal argument about him restricting my daughter Caroline's internet use. My daughters Caroline (17) and Victoria (11) were both present. I was attempting to remove Victoria from the room. The Defendant and Caroline continued the argument behind my back, with the Defendant ordering Caroline to go to her room. Caroline refused to move, and the Defendant started pushing her. The argument escalated, and the Defendant grabbed Caroline by the neck, causing bruises, and threatened to throw her down a full flight of steps. He did push her toward the steps, but I was able to direct her away from the stairs. He continued the argument, however, becoming more and more physical, including pulling Caroline down the hall by her hair. I managed to take is glasses away. When he came after me, I gave Caroline. The Defendant grabbed me by the neck and threatened, to Caroline, that he would hurt me if she did not give his glasses back. Caroline refused. The Defendant caught Caroline, sat on her, and put her into a head lock. The Defendant was preventing Caroline from breathing when she ultimately had to bite him on the chest in order to break free from the head lock. The police were called to the scene, and they have documented the marks on Caroline's forehead, arm, and neck. 11. The defendant has physically abused me and/or the minor children in the past. The following are some examples of past abusive conduct: A. On December 23, 1999, Caroline came home about midnight when called by her mother. Upon arriving home, Caroline found her mother locked in her bathroom. The Defendant took Caroline's cell phone from her room and refused to return it. When Caroline tried to get the phone from him, the Defendant elbowed her and then struck her across the throat with his forearm. and without reason, B. The Defendant has repeatedly, exercised physical control over the Plaintiff and the minor children, rising to the level of emotional abuse, by: - locking Caroline's car into the garage (12/24/99) - immobilizing Caroline's care by removing essential parts and by wheel-locks (several occasions) - immobilizing Plaintiff's car by removing essential parts (12/29/99) - taken phones, disconnected phones (12/28) - broke lap top and fax machine (12/23) - restricted Plaintiff's business internet (12/24) C. The defendant has been controlling, manipulative, harassing, abusive and demanding of the Plaintiff and the minor children many times in the past, with arguments that are lately becoming more and more violent, upsetting, and frightening. 12. The abused person(s) are in immediate danger of further abuse and a Court Order is necessary to protect the abused. 13. I believe that service cannot be safely effected by an adult individual other than a law enforcement officer. 14. 1 ask for attorney fees and costs pursuant to the Protection From Abuse Act. 15. The abused and/or I have suffered out-of-pocket losses as a result of the defendant's abuse. 16. The defendant has used or threatened to use the following weapons in his abuse against the abused person(s) : n/a. WHEREFORE, Plaintiff requests that this Honorable Court award the following relief: A. Grant a Temporary Order pursuant to the Protection from Abuse Act: Ordering the defendant to stop abusing, harassing, threatening, and/or stalking the abused and the Plaintiff, and to stop placing the abused and the Plaintiff in fear of abuse in any place where they may be found; Evicting the defendant from the marital residence at 3818 Pamay Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 at which the abused is now living and from any subsequent residence in which the abused lives during the pendency of this Order, and granting exclusive possession of the premises to the abused; Ordering the defendant to provide and pay for alternative suitable housing for the abused, approved by the Plaintiff, and granting exclusive possession of the housing to the abused; Prohibiting the defendant from having any contact with the abused, including, but not limited to, restraining the defendant from entering the place of employment, business, or school or recreation of the abused and from harassing the abused or the abuseds' relatives; Granting temporary custody of the minor children to the Plaintiff; Directing the Sheriff's Department of Cumberland County (or other law enforcement agency) to serve a copy of the Petition and Temporary Order upon the defendant without prepayment of costs; B. Schedule a hearing and, at such hearing, enter a one-year Order which includes the above in addition to the following: Granting temporary support for the abused in the maximum amount allowed under law; Ordering the defendant to reimburse Plaintiff's and the abused's out-of-pocket losses suffered as a result of the abuse; Ordering the defendant to pay all costs associated with the filing and service of the law suit and to pay Plaintiff's and the abused's attorney's fees; and Granting any other relief the Court deems appropriate. vw ? i Matthew J. Law Offices 2108 Market Camp Hill, ID# 72655 Date: 4shelman, Esquire / of Patrick F. Lauer, Jr. Street, Aztec Building ?ennsylvania 17011-4706 Tel. (717) 763-1800 BOGUMILA MANGAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff :CUMBERLAND COUNTY, PENNSYLVANIA vs. No. DAVID A. MANGAM, CIVIL ACTION - LAW Defendant PROTECTION FROM ABUSE VERIFICATION I, Bogumila Mangam, state that I am the Plaintiff in the above-captioned case and that the facts set forth in the above Petition are true and correct to the best of my knowledge, information, and belief. I realize that false statements herein are subject to the penalties for unsworn falsification to authorities under 18 Pa. C.S. 5 4904. Bog ila Mangam -7- Date: G BOGUMILA MANGAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-7746 Civil Term DAVID A. MANGAM, CIVIL ACTION Defendant IN DIVORCE ORDER AND NOW, this day of 2000, upon review of Defendant's Answer to Plaintiff's Petition for Protection Abuse, the Court hereby dismisses Plaintiff's Petition and vacates the Temporary Order. BY THE COURT: Judge MEYERS. DESFOR, SALTZGIVER 6 BOYLE j? 410 NORTH SECOND STREET • P,O. BOX 1062 - HARRISBURG, PA 17106 II (717) 236.9428 • FAX(717)236-2817 BOGUMILA MANGAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-7746 Civil Term DAVID A. MANGAM, CIVIL ACTION Defendant IN DIVORCE ANSWER TO WIFE'S PETITION FOR PROTECTION FROM ABUSE 1. No answer required. 2. No answer required. 3. No answer required. 4. No answer required. 5. No answer required. By way of further answer, Defendant temporarily relocated to the Hampton Inn, Mechanicsburg, Cumberland County, Pennsylvania. 6. No answer required. 7. Admitted. 8. Admitted. 9. Admitted. 10. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demander at trial. By way of further answer, Plaintiff's recitation of the incident which occurred on December 18, 1999 is inaccurate and incomplete. By way of background, the parties' oldest daughter's, Caroline's, grades are slipping and she is demonstrating unruly and inappropriate behavior both in and out of school. For these reasons, Defendant sought to restrict Caroline's internet use. Furthermore, 2 ?i ii MEYERS, DESFOR, SALTZGIVER 6 BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 II (717) 2369428 • FAX (717) 236.2817 '?7 Caroline insists on using a rental vehicle provided to the parties as a result of an accident earlier in 1999. Caroline is only 17 years of age and not permitted by law It use the vehicle. Depsite this, Plaintiff repeatedly allows the child to use the vehicle, even though there are two other vehicles available for the child's use. A subsequent argument ensued between Caroline and Defendant because Caroline was upset she was not permitted to use the rental vehicle. Caroline repeatedly used vile and inappropriate language to refer to her father as well as striking and kicking her father repeatedly. Plaintiff joined in on the argument including taking Defendant's glasses from him and tossing them back and forth with her daughter. Ultimately, Plaintiff was the one to notify the police to the scene. 11. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demande at trial. By way of further answer, all incidents cited by Plaintiff are incomplete and inaccurate. Rather, Plaintiff is the aggressor toward Defendant and has on repeated occasions assaulted him, including striking him in the face until bleeding. The incident was witnessed by the parties' minor child and photographs were taken of Husband. The police have been repeatedly summoned to the household by Defendant on prior occasions. Defendant also files a Petition for Protection from Abuse comtemporeneously with 3 MEYERS. DESFOR, SALTZGIVER 6 BOYLE I 410 NORTH SECOND STREET . P.O.BOX1062 • HARRISBURG, PA 17108 (717) 236.9428 • FAX(717)236-2817 f i 1 1 i 12 13 14 15 16 this Answer. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demande at trial. By way of further answer, neither Plaintiff or the parties, children are in immediate danger of further abuse and a Court order is not necessary to protect any of the named parties. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demanded at trial. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demande at trial. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demande at trial. No answer required. 4 MEYERS, DESFOR, SALTZGIVER 8 BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 HARRISBURG, PA 17108 (717)236-942B • FAX(717)236-2817 I I WHEREFORE, Defendant David A. Mangam respectfully requests this Honorable Court dismiss Plaintiff's Petition for Protection From Abuse. lly submitted, ,Catherine A. Boyle,Pq MEYERS, DESFOR, SAL GI & BOYLE Attorney I.D. #76328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for Defendant 5 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG. PA 17108 (717) 236.9428 • FAX(717)236-2617 BOGUMILA MANGAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-7746 Civil Term DAVID A. MANGAM, CIVIL ACTION Defendant IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Answer to Plaintiff's Petition for Protectiong from Abuse was sent to: Matthew Eshelman, Esquire Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 (sent via Federal Express Overnight mail) Bogumila Mangam 3818 Pamay Drive Mechanicsburg, Pennsylvania 17055 (sent via certified mail, resticted delivery) r atherine A. Boyle, Attorney for Plainti /?/o 0 6 MEYERS, OESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 2369428 • FAX (717) 2362817 re r j of my knowledge, information and belief. I understand that fals statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to i I VERIFICATION i I, David A Mangam , verify that the statements made in this Angwpr to Plaintiff's Patitinn for n t t' from Ah11sP are true and correct to the best authorities. n i' Dated: 1/4/2000 ( ) Plaintiff C (x ) Defendant i I I MEYERS. DESFOR, SALTZGIVER B BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG. PA 17108 (717) 236.9428 • FAX(717)236-2817 BOGUMILA MANGAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-7746 Civil Term DAVID A. MANGAM, CIVIL ACTION Defendant IN DIVORCE ORDER AND NOW, this day of 2000, upon review of Defendant's Answer to Plaintiff's Petition for Protection fro Abuse, the Court hereby dismisses Plaintiff's Petition and vacates the Temporary Order. BY THE COURT: Judge t°:'"Z MEYERS. DESFOR, SALTZGIVER 8 BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17106 (717) 236-9428 • FAX(717)236-2817 BOGUMILA MANGAM, Plaintiff VS. DAVID A. MANGAM, Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 99-7746 Civil Term CIVIL ACTION IN DIVORCE ANSWER TO WIFE'S PETITION FOR PROTECTION FROM ABUSE 1. No answer required. 2. No answer required. 3. No answer required. a. No answer required. 5. No answer required. By way of further answer, Defendant temporarily relocated to the Hampton Inn, Mechanicsburg, Cumberland County, Pennsylvania. 6. No answer required. 7. Admitted. e. Admitted. 9. Admitted. 10. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demancie at trial. By way of further answer, Plaintiff's recitation of the incident which occurred on December 18, 1999 is inaccurate and incomplete. By way of background, the parties' oldest daughter's, Caroline's, grades are slipping and she is demonstrating unruly and inappropriate behavior both in and out of school. For these reasons, Defendant sought to restrict Caroline's internet use. Furthermore, 2 MEYERS. DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717(2360428 • FAX (717) 236.2817 Caroline insists on using a rental vehicle provided to the parties as a result of an accident earlier in 1999. Caroline is only 17 years of age and not permitted by law t use the vehicle. Depsite this, Plaintiff repeatedly allows the child to use the vehicle, even though there are two other vehicles available for the child's use. A subsequent argument ensued between Caroline and Defendant because Caroline was upset she was not permitted to use the rental vehicle. Caroline repeatedly used vile and inappropriate language to refer to her father as well as striking and kicking her father repeatedly. Plaintiff joined in on the argument including taking Defendant's glasses from him and tossing them back and forth with her daughter. Ultimately, Plaintiff was the one to notify the police to the scene. 11. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demande at trial. By way of further answer, all incidents cited by Plaintiff are incomplete and inaccurate. Rather, Plaintiff is the aggressor toward Defendant and has on repeated occasions assaulted him, including striking him in the face until bleeding. The incident was witnessed by the parties' minor child and photographs were taken of Husband. The police have been repeatedly summoned to the household by Defendant on prior occasions. Defendant also files a Petition for Protection from Abuse comtemporeneously with 3 MEYERS. OESFOR, SALTZGIVER 8 BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236.9428 • FAX(717)236-2817 74 1 this Answer. 12. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demanded at trial. By way of f urther answer, neither Plaintiff or the parties, children are in immediate danger of further abuse and a Court Orde r is not necessary to protect any of the named parties. 13. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demanded at trial. 14. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demanded at trial. 15. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demande at trial. 16. No answer required. 4 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG. PA 17100 (717) 2369420 • FAX(717)236-2817 WHEREFORE, Defendant David A. Mangam respectfully requests this Honorable Court dismiss Plaintiff's Petition for Protection From Abuse. ly submitted, atherin, e A. Boy 7.e, qua MEYERS, DESFOR, SAL GIVER & BOYLE Attorney I.D. #76328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for Defendant 5 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236--428 • FAX(717)236-2817 !•?-M BOGUMILA MANGAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-7746 Civil Term DAVID A. MANGAM, : CIVIL ACTION Defendant IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Answer to Plaintiff's Petition for Protectiong from Abuse was sent to: Matthew Eshelman, Esquire Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 (sent via Federal Express Overnight mail) Bogumila Mangam 3818 Pamay Drive Mechanicsburg, Pennsylvania 17055 (sent via certified mail, resticted delivery) 6 l ( vG atherine A. Boyle, E uire Attorney for Plainti I /y/O CJ MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236.9428 • FAX(717)236-2817 VERIFICATION verify that the I, statements made in this P r ni intiffla PPtii-inn fnr are true and correct to the bes P-rn prtinn frnm A7-+n cP of my knowledge, information and belief. I understand that fals statements herein are made subject to the penalties of is Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 1/4/2000 _ J ` ?/- ? ( ) Plaintiff G (x ) Defendant I I i I-? MEYERS, DESFOR. SALTZGIVER 6 BOYLE 410 NORTH SECOND STREET • P.O BOX 1062 • HARRISBURG, PA 17108 (717) 236.9428 • FAX (717) 236-2817 1 BOGUMILA MANGAM, IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-7746 Civil Term DAVID A. MANGAM, CIVIL ACTION Defendant IN DIVORCE ORDER AND NOW, this day of ., 2000, upon review of Defendant's Answer to Plaintiff's Petition for Protection fro Abuse, the Court hereby dismisses Plaintiff's Petition and vacates the Temporary Order. BY THE COURT: Judge I I it Ij MEYERS, DESFOR, SALTZOIVER 6 BOYLE II 410 NORTH SECOND STREET • PA. BOX 1062 • HARRISBURG. PA 17108 (717) 2369428 • FAX(717)236-2817 BOGUMILA MANGAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-7746 Civil Term DAVID A. MANGAM, CIVIL ACTION Defendant IN DIVORCE ANSWER TO WIFE'S PETITION FOR PROTECTION FROM ABUSE 1. No answer required. ; 24 No answer required. , 3. No answer required. 4. No answer required. 5. No answer required. By way of further answer, Defendant temporarily relocated to the Hampton Inn, Mechanicsburg, Cumberland County, Pennsylvania. 6. No answer required. 7. Admitted. 8. Admitted. 9. Admitted. 10. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demanded at trial. By way of further answer, Plaintiff's recitation of the incident which occurred on December 18, 1999 is inaccurate and incomplete. By way of background, the parties' oldest daughter's, Caroline's, grades are slipping and she is demonstrating unruly and inappropriate behavior both in and out of school. For these reasons, Defendant sought to restrict Caroline's internet use. Furthermore, 2 I MEYERS, DESFOR, SALTZGIVER 6 BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717)236-942B • FAX(717)236-2817 11 Caroline insists on using a rental vehicle provided to the parties as a result of an accident earlier in 1999. Caroline is only 17 years of age and not permitted by law use the vehicle. Depsite this, Plaintiff repeatedly allows the child to use the vehicle, even though there are two other vehicles available for the child's use. A subsequent argument ensued between Caroline and Defendant because Caroline was upset she was not permitted to use the rental vehicle. Caroline repeatedly used vile and inappropriate language to refer to her father as well as striking and kicking her father repeatedly. Plaintiff joined in on the argument including taking Defendant's glasses from him and tossing them back, and forth with her daughter. Ultimately, Plaintiff was the one to notify the police to the scene. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demander at trial. By way of further answer, all incidents cited by Plaintiff are incomplete and inaccurate. Rather, Plaintiff is the aggressor toward Defendant and has on repeated occasions assaulted him, including striking him in the face until bleeding. The incident was witnessed by the parties' minor child and photographs were taken of Husband. The police have been repeatedly summoned to the household by Defendant on prior occasions. Defendant also files a Petition for Protection from Abuse comtemporeneously with 3 MEYERS, DESFOR, SALTZGIVER 8 BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717(2369428 • FAX(717)236-2817 this Answer. 12. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is deman, at trial. By way of further answer, neither Plaintiff or the parties' children are in immediate danger of further abuse and a Court order is not necessary to protect any of the named parties. 13. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is at trial. 14. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demande at trial. 15. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demande at trial. 16. No answer required. 4 MEYERS. DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG. PA 17108 (717)236.9428 • FAX(717)236-2817 WHEREFORE, Defendant David A. Mangam respectfully requests this Honorable Court dismiss Plaintiff's Petition for Protection From Abuse. tfully submitted, ?(/ /(- ? & i I L. atherine A. Boyle, quire MEYERS, DESFOR, SAL GIVER & BOYLE Attorney I.D. #76328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for Defendant 5 Ii MEYERS, DESFOR, SALTZGIVER 8 BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17100 (717( 236.9420 • FAX (717) 236.2817 BOGUMILA MANGAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-7746 Civil Term DAVID A. MANGAM, CIVIL ACTION Defendant IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Answer to Plaintiff's Petition for Protectiong from Abuse was sent to: Matthew Eshelman, Esquire Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 (sent via Federal Express overnight mail) Bogumila Mangam 3818 Pamay Drive Mechanicsburg, Pennsylvania 17055 (sent via certified mail, resticted delivery) c:acnerine H. DVy-, Attorney for Plainti I lztlo 0 6 MEYERS, DESFOR, SALTZGIVER 8 BOYLE Ih 410 NORTH SECOND STREET P.O. BOX 1062 HARRISBURG, PA 17108 II (717) 236.9428 • FAX (717) 2364817 .i 4 A r? VERIFICATION I, _naviA A_ MnnClam , verify that the I statements made in this Answer to Plaintiff's Petition for Prnf-nntinn frnm AhllaP are true and correct to the best of my knowledge, information and belief. I understand that false) statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. I Dated: 1/4/2000 ,I / ( ) Plaintiff (x ) Defendant i MEYERS. DESFOR, SALTZGIVER 6 BOYLE 410 NORTH SECOND STREET • PO. BOX 1062 • HARRISBURG. PA 17100 (717) 236.9426 • FAX (717) 2362817 BOGUMILA MANGAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-7746 Civil Term DAVID A. MANGAM, : CIVIL ACTION Defendant IN DIVORCE ORDER AND NOW, this day of 2000, upon review of Defendant's Answer to Plaintiff's Petition for Protection fro Abuse, the Court hereby dismisses Plaintiff's Petition and vacates the Temporary Order. BY THE COURT: Judge MEYERS, DESFOR, SALTZGIVER 8 BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236.9428 • FAX(717)236-2817 c;i BOGUMILA MANGAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-7746 Civil Term DAVID A. MANGAM, CIVIL ACTION Defendant IN DIVORCE ANSWER TO WIFE'S PETITION FOR PROTECTION FROM ABUSE 1. No answer required. r, ) -, 2. No answer required. 3. No answer required. c. 4. No answer required. ='- 5. No answer required. By way of further answer Defendaht -c temporarily relocated to the Hampton Inn, Mechanicsburg, Cumberland County, Pennsylva nia. 6. No answer required. 7. Admitted. 8. Admitted. 9. Admitted. 10. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demande at trial. By way of further answer, Plaintiff's recitation of the incident which occurred on December 18, 1999 is inaccurate and incomplete. By way of background, the parties' oldest daughter's, Caroline's, grades are slipping and she is demonstrating unruly and inappropriate behavior both in and out of school. For these reasons, Defendant sought to restrict Caroline's internet use. Furthermore, 2 MEYERS, DESFOR, SALTZGIVER 6 BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236.9429 • FAX (717) 236.2817 Caroline insists on using a rental vehicle provided to the parties as a result of an accident earlier in 1999. Caroline is only 17 years of age and not permitted by law t use the vehicle. Depsite this, Plaintiff repeatedly allows the child to use the vehicle, even though there are two other vehicles available for the child's use. A subsequent argument ensued between Caroline and Defendant because Caroline was upset she was not permitted to use the rental vehicle. Caroline repeatedly used vile and inappropriate language to refer to her father as well as striking and kicking her father repeatedly. Plaintiff joined in on the argument including taking Defendant's glasses from him and tossing them back and forth with her daughter. Ultimately,i Plaintiff was the one to notify the police to the scene. 11. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demande at trial. By way of further answer, all incidents cited by Plaintiff are incomplete and inaccurate. Rather, Plaintiff is the aggressor toward Defendant and has on repeated occasions assaulted him, including striking him in the face until bleeding. The incident was witnessed by the parties' minor child and photographs were taken of Husband. The police have been repeatedly summoned to the household by Defendant on prior occasions. Defendant also files a Petition for Protection from Abuse comtemporeneously with 3 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • P,O. BOX 1062 • HARRISBURG, PA 17108 II (717) 236.9428 • FAX(717)236-2817 this Answer. 12. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demander at trial. By way of f urther answer, neither Plaintiff or the parties, children are in immediate danger of further abuse and a Court orde r is not necessary to protect any of the named parties. 13. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demande at trial. 14. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demands, at trial. 15. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demands at trial. 16. No answer required. 4 MEYERS. DESFOR, SALTZGIVER 6 BOYLE 410 NORTH SECOND STREET - P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236.9428 • FAX (717) 236.2817 LRS'T1 E ,1. 1r WHEREFORE, Defendant David A. Mangam respectfully requests this Honorable Court dismiss Plaintiff's Petition for Protection From Abuse. y submitted, Katherine A. Boyle, q- MEYERS, DESFOR, SAL' 1 & BOYLE Attorney I.D. #76328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for Defendant 5 MEYERS, DESFOR, SALTZGIVER & BOYLE 410 NORTH SECOND STREET • RO. BOX 1062 • HARRISBURG, PA 17108 (717) 236.9428 • FAX (717) 236.2817 BOGUMILA MANGAM, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-7746 Civil Term DAVID A. MANGAM, CIVIL ACTION Defendant IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Answer to Plaintiff's Petition for Protectiong from Abuse was sent to: Matthew Eshelman, Esquire Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 (sent via Federal Express overnight mail) Bogumila Mangam 3818 Pamay Drive Mechanicsburg, Pennsylvania 17055 (sent via certified mail, resticted delivery) atherine A. Boyle, E uire Attorney for Plainti ? ?y'/o O i I? 6 Ii ?I MEYERS, DESFOR, SALTZOIVER & BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717)236.9428 FAX(717)236-2817 _._ 1nww?ws??1!®Ifd? I , VERIFICATION I, naviA A_ Mangam , verify that the statements made in this Ancwar fn Plain7-iffla Pot-i+-inn fnr PrntPn+inn frnm Ah11SP are true and correct to the bes of my knowledge, information and belief. I understand that fals statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904, relating to unsworn falsification to authorities. Dated: 1/4/2000 ( ) Plaintiff C (x ) Defendant MEYERS. OESFOR. SALTZGIVER 8 BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 . HARRISBURG. P !717) 2369428 • FAX (717) 236.2B17 BOGUMILA MANGAM, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-7746 Civil Term DAVID A. MANGAM, CIVIL ACTION Defendant IN DIVORCE ORDER AND NOW, this day of 2000, upon review --?' of Defendant's Answer to Plaintiff's Petition for Protection Abuse, the Court hereby dismisses Plaintiff's Petition and vacates the Temporary Order. BY THE COURT: Judge MEYERS. DESFOR, SALTZGIVER 6 BOYLE 1il 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 i (717) 236.9428 • FAX(717)236-2817 BOGUMILA MANGAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-7746 Civil Term DAVID A. MANGAM, CIVIL ACTION Defendant IN DIVORCE ANSWER TO WIFE'S PETITION FOR PROTECTION FROM ABUSE 1. No answer required. 2. No answer required. 3. No answer required. _ 4. No answer required. I 5. No answer required. By way of further answer, Defendant haE temporarily relocat ed to the Hampton Inn, Mechani;c'sbuzg, Cumberland County, Pennsylvania. 6. No answer required. 7. Admitted. 8. Admitted. 9. Admitted. 10. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demande at trial. By way of further answer, Plaintiff's recitation of the incident which occurred on December 18, 1999 is inaccurate and incomplete. By way of background, the parties' oldest daughter's, Caroline's, grades are slipping and she is demonstrating unruly and inappropriate behavior both in and out of school. For these reasons, Defendant sought to restrict Caroline's internet use. Furthermore, 2 MEYERS. DESFOR, SALTZGIVER 8 BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX(717)236-2817 Caroline insists on using a rental vehicle provided to the parties as a result of an accident earlier in 1999. Caroline is only 17 years of age and not permitted by law t use the vehicle. Depsite this, Plaintiff repeatedly allows the child to use the vehicle, even though there are two other vehicles available for the child's use. A subsequent argument ensued between Caroline and Defendant because Caroline was upset she was not permitted to use the rental vehicle. Caroline repeatedly used vile and inappropriate language to refer to her father as well as striking and kicking her father repeatedly. Plaintiff joined in on the argument including taking Defendant's glasses from him and tossing them back and forth with her daughter. Ultimately, Plaintiff was the one to notify the police to the scene. 11. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demands, at trial. By way of further answer, all incidents cited by Plaintiff are incomplete and inaccurate. Rather, Plaintiff is the aggressor toward Defendant and has on repeated occasions assaulted him, including striking him in the face until bleeding. The incident was witnessed by the parties' minor child and photographs were taken of Husband. The police have been repeatedly summoned to the household by Defendant on prior occasions. Defendant also files a Petition for Protection from Abuse comtemporeneously with 3 MEYERS, DESFOR, SALTZGIVER & BOYLE - 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236-9428 • FAX(717)236-2817 this Answer. 12. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demandec at trial. By way of further answer, neither Plaintiff or the parties' children are in immediate danger of further abuse and a Court order is not necessary to protect any of the named parties. 13. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is demanded at trial. 14. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is at trial. 15. Denied. This averment contains conclusions of fact and law to which no answer is required and proof thereof is at trial. 16. No answer required. 4 MEYERS, DESFOR, SALTZGIVER 8 BOYLE I?I 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG. PA 17108 i (717) 236.9428 • FAX(717)238-2817 WHEREFORE, Defendant David A. Mangam respectfully requests this Honorable Court dismiss Plaintiff's Petition for Protection From Abuse. y submitted, /V i I at-h ine A. Boyle, q MEYERS, DESFOR, SAL GI & BOYLE Attorney I.D. #76328 410 North Second Street P.O. Box 1062 Harrisburg, PA 17108 (717) 236-9428 Attorney for Defendant 5 MEYERS, DESFOR, SALTZGIVER & BOYLE ? 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG, PA 17108 (717) 236.9428 • FAX (717) 236.2817 BOGUMILA MANGAM, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA VS. NO. 99-7746 Civil Term DAVID A. MANGAM, CIVIL ACTION Defendant IN DIVORCE CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing Answer to Plaintiff's Petition for Protectiong from Abuse was sent to: Matthew Eshelman, Esquire Law Offices of Patrick F. Lauer, Jr. 2108 Market Street, Aztec Building Camp Hill, Pennsylvania 17011-4706 (sent via Federal Express Overnight mail) Bogumila Mangam 3818 Pamay Drive Mechanicsburg, Pennsylvania 17055 (sent via certified mail, resticted delivery) Attorney for Plainti !/?/o O 6 MEYERS. DESFOR, SALTZGIVER 6 BOYLE 410 NORTH SECOND STREET • PA. BOX 1062 • HARRISBURG, PA 17108 (717) 236.9428 • FAX(717)236-2817 VERIFICATION verify that the I, y * ti* a n qgm I statements made in this p p in P1 ini-iffl Pptii-in fnr ii prni-prfinn frnm Ahii-ca are true and correct to the besq of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. ! I C.S. Section 4904, relating to unsworn falsification to authorities. i Dated: 1/4/2000 ( ) Plaintiff C (x ) Defendant MEYERS. DESFOR, SALTZGIVER 8 BOYLE 410 NORTH SECOND STREET • P.O. BOX 1062 • HARRISBURG. PA 17100 !717) 236.9428 - FAX (717) 236.2BI7 ?1s?n?If11oM? BOGUMILA MANGAM, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 99-7746 CIVIL TERM ? DAVID A. MANGAM, CIVIL ACTION - LAW Defendant PROTECTION FROM ABUSE - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - DAVID A. MANGAM, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. BOGUMILA MANGAM, Defendant NO. 2000-81 CIVIL TERM CIVIL ACTION - LAW PROTECTION FROM ABUSE ORDER OF COURT AND NOW, this 7th day of January, 2000, upon consideration of the Petition for Protection from Abuse filed at No. 99-7746 Civil Term and of the Petition for Protection from Abuse filed at No. 2000-81 Civil Term, and pursuant to an agreement reached in court among the parties and their respective counsel, Catherine A. Boyle, Esquire, on behalf of David A. Mangam, and Matthew J. Eshelman, Esquire, on behalf of Bogumila Mangam, it is ordered and directed as follows: 1. The parties have agreed to enter reciprocal consent orders. The order shall be without admission of wrongdoing or liability in terms of the definition of abuse as set forth in the Domestic Relations Code. 2. Each party specifically stipulates that they shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found, particularly with reference to the definition of abuse as set forth in the Domestic Relations Code. 3. Husband, David A. Mangam, is evicted and excluded from the marital residence located at 3818 Panay Drive, Mechanicsburg, Cumberland County, Pennsylvania, 17055, which property is owned by the parties, and any other permanent or .Iw- r 00 XN 12 AH 10: 18 CUib-WR;.A;`i0 FFNVSIIVANgU i li temporary residence where wife, Bo Mangam, may reside. Likewise, wife, Bo Mangam, is evicted and excluded from the husband's residence located at 521 Barry Court, Mechanicsburg, Cumberland County, Pennsylvania, 17055. Neither party shall have the right or privilege to enter or be present on the premises previously described except for the limited purpose of transferring custody of the parties' children. Whichever party shall be dropping off the child at a period of an exchange of custody shall remain in their vehicle during the transfer of custody. 4. The parties further stipulate to negotiate through counsel a date and time for husband, David A. Mangam, to be present at the marital residence with a law enforcement officer, such as a constable or other individual, at the cost of Mr. Mangam, to jointly go through the personal property contained in the marital residence for the purpose of specifically allowing Mr. Mangam'to pick up any personal effects which may specifically be his, any property which is jointly agreed to be nonmarital property, and any other such property as the parties may mutually agree. The parties will further agree that they will make attempts to exchange in advance lists of specific personal property to minimize any difficulties at the time of the exchange. Wife, Bo Mangam, specifically agrees not to permanently remove any items of personal property from the marital residence prior to the exchange taking place. 5. Contact between the parties shall be limited to the express purpose of discussing the welfare and/or exchange of the children. 6. Each party is prohibited from entering the place of employment, business or school of Bo Mangam, David A. Mangam or Caroline A. Mangam, and from harassing, abusing, threatening or stalking the wife, Bo Mangam, or the minor children, Caroline A. Mangam and/or Victoria O. Mangam. 7. The wife, Bo Mangam, is awarded temporary primary physical custody of the minor children, Caroline A. Mangam and Victoria O. Mangam, subject to periods of partial physical custody and/or visitation as follows: The parties have agreed that they shall share legal custody of both children. 8. The parties have agreed that primary physical custody of Victoria Mangam shall be with mother subject to periods of partial physical custody in father as follows: Father shall have every other weekend, beginning from Friday after school until Sunday evening at 8:30 p.m. Beginning January 12, 2000, father shall have custody of Victoria from after school until 8:30 p.m. and every other Wednesday thereafter. Beginning January 19, 2000, father shall have custody of Victoria from 6:00 p.m. until Thursday morning when the child begins school and every other Wednesday thereafter. 9. The parties have agreed to a holiday schedule as follows: (1) Easter shall be with spent with mother every year. (2) Thanksgiving shall be spent with father every year. (3) The parties have agreed to alternate the following major holidays: Memorial Day, Fourth of July, Labor Day, New Years Day, and Victoria's birthday. This alternating holiday schedule will occur such that mother shall have Memorial Day 2000 and alternate thereafter. The time for the holiday custody shall be from 9:00 a.m. until 8:30 p.m. (4) Christmas holidays shall be broken into two segments. Segment A shall occur from after school, when the child is dismissed for Christmas break, until 2:00 p.m. Christmas Day. Segment B shall occur from 2:00 p.m. on Christmas Day until 6:00 p.m. December 27th. Father shall have Segment A in 2000 and all even numbered years thereafter. (5) Each year Mother's Day shall be spent with mother and Father's Day shall be spent with father. Periods of custody will be from 9:00 a.m. until 8:30 p.m. (6) The parties acknowledge that Victoria shall have other days off from school not specifically mentioned in the agreement. The parties agree to alternate these days and have custody from 9:00 a.m. until 8:30 p.m. unless otherwise agreed. Mother has agreed to provide a copy of the child's school schedule to father as soon as possible. (7) Each party shall have three uninterrupted weeks through the summer vacation, which weeks shall not be exercised consecutively. Notice of when the party intends to exercise his or her summer custody schedule shall be provided to the other party no later than thirty days ahead of time. The holiday at summer schedules shall supersede the weekly custody arrangement previously dictated. (8) The alternating weekends schedule with father shall commence Friday, January 14, 2000. 10. The husband shall pay temporary support to the wife in the amount of $2,150.00 per month, payable on the 15th day of each month, and allocated as follows: $1,360.00 per month is child support, $240.00 per month spousal support, and $550.00 per month mortgage contribution. These amounts are ordered without prejudice to either party in a determination of long term support at a later date. Wife shall have filed a complaint for support at the Office of Domestic Relations within ten days. 11. This order shall remain in full force and effect for a period of one year from today's date. 12. A copy of this order shall be forthwith filed in the county and statewide registries of protection orders. Copies shall also be provided to the Sheriff of Cumberland County, the Prothonotary of Cumberland County, counsel for husband, counsel for wife, and the Hampden Township Police Department. Service shall be made by counsel for wife. 13. The parties are 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. Section 6114. Consent of either party to resume cohabitation shall not invalidate this order. Either party may be arrested on the charge of indirect criminal contempt thereby. 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 a law enforcement officer. 14. This order shall supersede any prior order of this court with respect to protection from abuse and/or child custody. 15. For registration purposes, husband's name is David A. Mangam. His date of birth is August 9, 1943. His Social Security number is 08-934-5288. Wife's name is Bogumila Mangam, also known as Bo Mangam. Her date of birth is September 29, 1957. Her Social Security number is 59-538-6310. By the Court, J. Mesley Oler1 Jr. J. Catherine A. Boyle, Esquir "*W ?R U Attorney for David A. Mangam 1_/ 2rO O Matthew Eshelman, Esquire p Attorney for Bogumila Mangam Sheriff :srs SHERIFF'S RETURN - REGULAR CASE NO: 1999-07746 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MANGAM BOGUMILA VS MANGAM DAVID A KATHY CLARKE , Sheriff or Deputy Sheriff of Cumberland County, Pensylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon the MANGAM DAVID A DEFENDANT at 0013:34 HOURS, on the 30th day of December , 1999 at BURGER KING RESTAURANT CARLISLE PLAZA MALL by handing to CARLISLE, PA 17013 DAVID A MANGAM a true and attested copy of PROTECTION FROM ABUSE together with TEMPORARY PROTECTION FROM ABUSE ORDER, NOTICE OF HEARING, PETITION and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18,00 Service 3.10 Affidavit .00 Surcharge 8.00 .00 29.10 Sworn and Subscribed to before me this .31„-h day of Lw«, Ltrcc7 A.D. a Prothonotary So Answers: R. Thomas Kline 01/03/2000 By. ZCt,L L(. alci--az- Deput Sheriff