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Home My WebLink About01-0362 FX~w ~ $zoo~,l~ TRACY MAXWELL, Individually and on behalf of her minor children, Amanda Conrad, Dylan Conrad, and Trevor Conrad, Plaintiffs IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. WAYNE CONRAD, JR. and SHIRLEY CONRAD NACE, Defendants CIVIL ACTION-LAW IN PROTECTION FROM ABUSE N0. O1 - 3(d~ CIVIL TERM NOTICE OF HEARING AND ORDER YOU HAVE BEEN SUED IN COURT. Ifyou wish to defend against the claims set forth in the following pages, you must appear at the hearing scheduled herein. Ifyou fail to do so, the case may proceed against you and a FINAL Order may be entered against you granting the relief requested in the Petition. In particular, you may be evicted from your residence and lose other important rights. A hearing on the matter is scheduled for the day ofu~~~~~ n s 2001, at ~`•~qm., in Courtroom _.~_ at the Cumberland County Co Ouse, Pe ylvania. You MUST obey the Order that is attached until it is modified or terminated by the court after notice and hearing. Ifyou disobey this Order, the police may arrestyou. 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. Ifyou travel outside of the state andmtentionally violate this Order, you may be subj ectto federal criminal proceedings under the Violence Against Women Act, 18 U.S.C. §§ 2261-2262. YOU SHOULD TAKETHISPAPERTOYOURLAWYERATONCE. 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 (717) 249-3166 TRACY MAXWELL, Individually and on behalf of her minor children, Amanda Conrad, Dylan Conrad, and Trevor Conrad, Plaintiffs v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION-LAW IN PROTECTION FROM ABUSE WAYNE CONRAD, JR. and SHIRI.EY CONRAD NACB, Defendants :NO. O1 - -3~-L CIVIL TERM TEMPORARY PROTECTION FROM ABUSE ORDER Defendants' Names: Wayne Conrad, Jr., Shirley Conrad Nace Defendants' Dates of Birth: Mr. Conrad: 9/2/48, Mrs. Nace: 8/18/50 Defendants' Social Security Numbers: Unknown Names of All Protected Persons, including Plaintiff and minor children: Tracy Maxwell, and her minor children, Amanda Conrad, Dylan Conrad, and Trevor Conrad, hereinafter "the children." AND NOW, this L ~ s`~ day of ~, 2001, upon consideration of the attached Petition for Protection From Abuse, the co rk hereby enters the following Temporary Order: [X] 1. Defendants Wayne Conrad, Jr. and Shirley Conrad Nace shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. [ ] 2. Defendants are evicted and excluded from the residence at or any other permanent or temporary residence where Plaintiff may live. Plaintiff is granted exclusive possession of the residence. Defendant shall have no right or privilege to enter or be present on the premises. [X] 3. Defendants Wayne Conrad, Jr. and Shirley Conrad Nace are prohibited from having ANY CONTACT with Plaintiffs at any location, including but not limited to any contact at Plaintiffs' residence, school, business, or place of employment. Defendants are specifically ordered to stay away from the following locations for the duration of this Order: 223 Clay Street, West Fairview, Cumberland County, Pennsylvania, 17025 East Pennsboro Middle School in Enola, PA Wordsworkh Academy located on Cameron Street in Harrisburg, PA. [X] 4. Defendants shall not contact Plaintiffs by telephone or by any other means, including through third persons. [] 5. Pending the outcome of the fmal hearing in this matter, Plaintiff is awarded temporary custody of the following minor children: Until the final hearing, all contact between Defendant and the children shall be limited to the following: N/A [] 6. Defendant shall immediately relinquish the following weapons to the Sheriffs Office or a designated local law enforcement agency for delivery to the Sheriff s office: Defendant is prohibited from possessing, transferring or acquiring any other weapons for the duration of this order. [] 7. The following additional relief is granted: [X] 8. A certified copy of this Order shall be provided to the police department where Plaintiffs reside and any other agency specified hereafter. [X] 9. THIS ORDER SUPERSEDES ANY PRIOR PFA ORDER AND ANY PRIOR ORDER RELATING TO CHILD CUSTODY. [X] 10. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANTS AND SHALL REMAIN IN EFFECT UNTIL MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT Defendants 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.5. § 6114. Consent of the Plaintiff or Plaintiffs to a Defendant's return to the residence shall not validate this Order, which can only be changed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. § 6113. Defendants are 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 defendants may be located. If a 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 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 weapons are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. J~n.Z(, 2ao( Date Lv f~~R'" ~l~ 0/-,23-x' / ,~-ol ~ ~sP-c P ~n,~,a(~ PSP >- cx ~ O J.. co ~ '~j~2 5. {? ~' j c ` ~ ~4. ~ '' ~:._ ~ L./ (~ TRACY MAXWELL, Individually and on behalf of her minor children, Amanda Conrad, Dylan Conrad, and Trevor Conrad, Plaintiffs v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION-LAW IN PROTECTION FROM ABUSE WAYNE CONRAD, JR. and SHIItLEY CONRAD NACE, Defendants :NO. O1 - ~'~°~' CIVIL TERM PETITION FOR PROTECTION FROM ABUSE 1. Plaintiffs name is: Tracy Maxwell 2. I am filing this Petition on behalf of myself and my children. My children's names are Amanda Conrad, Dylan Conrad, and Trevor Conrad My address is: 223 Clay Street, West Fairview, Pennsylvania, 17025 Name(s) of ALL person(s), including Plaintiff and minor children, who seek protection from abuse: Tracy Maxwell, Amanda Conrad, Dylan Conrad, Trevor Conrad 4. Defendants are brother and sister. a) Wayne Conrad, Jr. i) is believed to live at the following address: 175 Woods Drive Mechanicsburg, PA ii) Social Security Number (if known) is: Unknown iii) Date of birth: 9/2/48 iv) Place of Employment: Same as place of residence b) Shirley Conrad Nace i) is believed to live at the following address: 919 West Trindle Road Mechanicsburg, PA ii) Social Security Number (if known) is: Unknown iii) Date of birth is: 8/18/50 iv) Place of employment is: The County Home, Clairmont Rd., Carlisle, PA. 5. Indicate the relationship between Plaintiff and Defendant. a) Wayne Conrad, Jr. and Tracy Maxwell are former intimate sexual partners. They engaged in one sexual act. [] Spouse [X] Former sexual/intimate partner [] Ex-spouse [] Persons who live or have lived like spouses [] Parents of the same children b) Wayne Conrad, Jr. and the children are related by blood. Mr. Conrad is the paternal uncle to Amanda Conrad. He is the grandfather to Dylan Conrad and Trevor Conrad. 6. 8. 10. [] Spouse [] Ex-spouse [] Persons who live or have lived like spouses [] Pazents of the same children [] Pazent/child [] Other relationship by blood/marriage [] Former sexual/intimate partner [] Pazent/child [X] Other relationship by blood/marriage c) Shirley Conrad Nace and Tracy Maxwell are related by affinity. Shirley Conrad. Nace's sister is married to Ms. Maxwell's father, and is therefore, Ms. Maxwell's step- aunt. [] Spouse [] Former sexual/intimate partner [] Ex-spouse [] Pazent/child [] Persons who live or have lived [X] Other relationship by blood/marriage like spouses [] Parents of the same children d) Shirley Conrad Nace and the children are related by blood. Mrs. Nace is the paternal aunt of Amanda Conrad. She is the paternal great aunt of Dylan Conrad and Trevor Conrad. [] Spouse [] Former sexual/intimate partner [] Ex-spouse [] Parent/child [] Persons who live or have lived [X] Other relationship by blood/marriage like spouses [] Parents of the same children Have Plaintiff and Defendant been involved in any of the following court actions? No. [] Divorce [] Custody [] Support [] Protection From Abuse Have the Defendants been involved in any criminal court action? Yes. Wayne Conrad Jr. has been charged with hazassment and threats against Ms. Maxwell and her boyfriend Robert Nace. Mr. Conrad is currently out on bail with the condition that he will not have any contact with Ms. Maxwell or Mr. Nace. Plaintiff and Defendant are parents of the following minor children: NONE If Plaintiff and Defendant are parents of any minor children together, is there an existing court Order regarding their custody? N/A 11. The facts of the most recent incident of abuse are as follows: The Defendants have been stalking and harassing Ms. Maxwell and her children for almost seven months. On Sunday, January 14, 2001, Ms. Maxwell and Robert Nace were driving to a friend's house. While traveling, they noticed a small green car following them. Ms. Maxwell and Mr. Nace recognized the car as one belonging to Deb Butler. Deb Butler is Shirley Conrad Nace's best friend and they believe that Shirley Conrad Nace was in the vehicle. On Wednesday, January 17, 2001 Ms. Maxwell received a disturbing letter from Bryan Conrad. Bryan is Dylan and Trevor Conrad's father. Bryan is the son of Wayne Conrad Jr. and the nephew of Shirley Conrad Nace. In the letter Bryan stated that he feared for the well-being of Tracy and the children, and warned that they had better be careful because they were being watched. A copy of the letter is attached as Exhibit "A". In December 2000 Wayne Conrad, Jr. and Shirley Conrad Nace drove past Ms. Maxwell's residence, beeping the horn and screaming. Shirley Conrad Nace screamed that she would get Ms. Maxwell, her boyfriend Robert Nace, and Ms. Maxwell's children. She then screamed that they would all pay for what they have done. 13. If the Defendants have committed prior acts of abuse against Plaintiff or the minor children, describe these prior incidents, including any threats, injuries, or incidents of stalking, and indicate approximately when such acts of abuse occurred: In May 2000 Wayne Conrad, Jr. began calling Tracy's house. He said that Tracy's life was in his hands. Wayne Conrad, Jr. also began stalking Tracy. Wayne Conrad, Jr. has also threatened to have Tracy's children taken away from her. In May 2000, Shirley Conrad Nace called Ms. Maxwell's home and told her that she would have her children taken away from her. In June 2000, Shirley Conrad Nace called Ms. Maxwell's home and stated, "I'll make sure that I bury you and Bob both." From July through September 2000, Shirley Conrad Nace would drive into the parking of lot of Ms. Maxwell's home and watch Ms. Maxwell in her home. This happened approximately every two days. Ms. Maxwell saw and recognized Shirley Conrad Nace on these occasions. On October 29, 2000, Tracy reported these incidents to the police, and pursued the matter in court. Wayne Conrad, Jr. called Tracy and said, "When you and Robert go out, you better watch yourselves and your children." 14. List the weapon(s) that Defendant has used or threatened to use against Plaintiff or the minor children: 15. Identify the police department or law enforcement agency in the area in which Plaintiff lives that should be provided with a copy of the protection order: East Pennsboro 16. There is an immediate and present danger of further abuse from the Defendants. CHECK THE FOLLOWING BOXES ONLY IF THEY APPLY TO YOUR CASE AND PROVIDE THE REQUESTED INFORMATION [ ]Plaintiff is asking the court to evict and exclude the Defendant from the following residence: [] owned by: [] rented by (list all names, if known): [] Defendant owes a duty of support to Plaintiff and/or the minor children. [] Plaintiff has suffered out-of-pocket fmancial losses as a result of the abuse described above. Those losses are: 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: [X] A. Restrain Defendants from abusing, threatening, harassing, or stalking Plaintiffs in any place where Plaintiffs may be found. [] B. Exclude Defendant from Plaintiff's residence and prohibit Defendant from attempting to enter any temporary or permanent residence of the Plaintiff. [] C. Require Defendant to provide Plainfiff and/or minor child/ren with other suitable housing. [] D. Award Plaintiff temporary custody of the minor child and place the following restrictions on contact between Defendant and child: [X] E. Prohibit Defendants from having any contact with Plaintiffs either in person, by telephone, or in writing, personally or through third persons, including but not limited to any contact at Plaintiffs' residence, school, business, or place of employment. [X] F. Prohibit Defendants from having any contact with Plaintiffs' relatives and Plaintiff's children listed in this Petition. [] G. Order the Defendant to temporarily turn over weapons to the Sheriff for this County and prohibit Defendant from transferring, acquiring or possessing any such weapons for the duration of the Order. [] H. Order Defendant to pay temporary support for Plaintiff and/or the minor child/ren, including medical support and [] payment of the rent or mortgage on the residence. [] I. Direct Defendant to pay Plaintiff for the reasonable fmancial losses suffered as the result of the abuse, to be determined at the hearing. [X] J. Order Defendants to pay the costs of this action, including filing and service fees. [] K. Order Defendant to pay Plaintiff's reasonable attorney's fees. [] L. Order the following additional relief, not listed above: [X] M. Grant such relief as the court deems appropriate. [X] N. Order the police or other law enforcement agency to serve the Defendants with a copy of this Petition, any Order issued, and the Order for Hearing. The Plaintiff will inform the designated authority of any addresses, other than Defendants' residence, where Defendants can be served. t iS o i Dat ara L Kurtzman '~~ ` Certified Legal Intern ~ ' M. PLA ROBERT E. RAINS TERI L. HENNING Supervising Attorneys FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 ~. ~~'~ t ~ ~ ~ ~"~' Q c.2rC~ ~L ~.-~i ~ ~ .~eiY+~G,/}22 ~_,~=,.tom°?~ v~y~'`"~~ , -~ ~.t~c~ Qr;1 ~wf -~^^~%z-roc-C ~ ~..L-~7/ -~c2G'~ ~ J / ~ ~. ~z~ ~ ~~ ~~~~ ~~ ~~ ~~ ~ G~ ~0 ~u~ ~ ~~_ ~~~ _ ~.~. . ~ - ~ ~ -~/ ~~~ ~ . ~~ ~ ~,~ . ~ . ~` _~~ `~ / ~ ~ F c iV ' ... ~ _, y j ~.a . - -- l~~~l ~~ ~~`~~" ,,,.tip ~ti~~~ _ ~-~~: ;~ ~ ~~~ ~~ ~t ~~ ~~ -~y~~I.~ C.Gc~~-y G~G4L~/~L/L -~Cc~~ ~~~2. ~- ,moo ~.~- . -- _. .. _. _~~ _.. , . , . ,_. .:_. _.... , ~ ...v ~~iE ____. _ __ _.. __ D ' D ~ - /._ . .. _ _ ._ . ?~ VERIFICATION Understanding that the making of any false stz of 18 Pa.C.S § 4904, I verify that I am the Plaintiff in statements contained in the above Petition are true and information and belief. ~ -I"'4~ Date ould subject me to the penalties nt action, and that the facts and to the~best of my knowledge, MAXWELL, TRACY, Individually and on behalf of her minor children, Amanda Conrad, Dylan Conrad, and Trevor Conrad, Plaintiffs v. WAYNE CONRAD, JR. and SHIRLEY CONRAD NACE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA :CIVIL ACTION-LAW IN PROTECTION FROM ABUSE :NO. O1 - CIVIL TERM FINAL ORDER OF COURT Defendants' Names: Wayne Conrad, Jr. and Shirley Conrad Nace Defendants' Dates of Birth: Mr. Conrad: 9/2/48, Mrs. Nace: 8/18/50 Defendants' Social Security Numbers: Unknown Names of All Protected Persons, including Plaintiff and minor children: Tracy Maxwell and her minor children, Amanda Conrad, Dylan Conrad and Trevor Conrad, hereinafter "the children." AND NOW, this day of , 2001, the court having jurisdiction over the parties and the subject-matter, it is ORDERED, ADJUDICATED and DECREED as follows: Note: Space is provided to allow for 1) the court's general findings of abuse; 2) inclusion of the terms under which the order was entered (e.g, that the order was entered with the consent of the parties, or that the defendant, though properly served, failed to appear for the hearing, or the reasons why plaintiff s request for a final PFA order was denied); and/or 3) information that may be helpful to law enforcement (e.g., whether a weapon was involved in the incident of abuse and/or whether the defendant is believed to be armed and dangerous). [] Plaintiff s request for a final protection order is denied. OR [] Plaintiffs request for a final protection order is granted. [] 1. Defendant shall not abuse, stalls, harass, threaten the Plaintiff or any other protected person in any place where they might be found. [] 2. Defendant is completely evicted and excluded from the residence at or any other residence where Plaintiff and the children 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 ,Defendant may enter the residence to retrieve his/her clothing and other personal effects, provided that Defendant is in the company of a law enforcement officer when such retrieval is made. [] 3. Except as provided in this Order, Defendant is prohibited from having ANY CONTACT with the Plaintiff and the children at any location, including but not limited to any contact at the Plaintiff s school, business, or place of employment. Defendant is specifically ordered to stay away from the following locations for the duration of this Order. [] 4. Except as provided in this Order, Defendant shall not contact the Plaintiff by telephone of by any other means, including through third persons. [] 5. Custody of the minor children shall be as follows: [] 6. Defendant shall immediately tum 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 children. [] 7. Defendant is prohibited from possessing, transferring or acquiring any other weapons for the duration of this order. Any weapons delivered to the sheriff under paragraph 6 of this Order or under Paragraph 6 of the Temporary Order shall not be returned until further order of court. [] 8. The following additional relief is granted as authorized by § 6108 of the Act: [] 9. Defendant is directed to pay temporary support for: as follows: This order for support shall remain in effect until a final support order is entered by this Court. However, this order shall lapse automatically if the Plaintiff does not file a complaint for support with the court within fifteen days of the date of this order. The amount of this temporary order does not necessarily reflect Defendant's correct support obligation, which shall be determined in accordance with the guidelines at the support hearing. Any adjustments in the final amount of support shall be credited, retroactive to this date, to the appropriate party. [] 10. The costs of this action are waived as to the Plaintiff and imposed on Defendant. [] 11. [] Defendant shall pay $ to Plaintiff as compensation for Plaintiffs out-of- pocket losses, which are as follows: [] Plaintiff is granted leave to present a petifion, with appropriate notice to Defendant, to requesting recovery ofout-of-pocket losses. The petition shall include an exhibit itemizing all cliamed out-of-pocket losses, copies of all bills and estimates of repair, and an order scheduling a hearing. NO fee shall be required by the Prothonotary's office for the filing of this petition. [] 12. BRADY INDICATOR. [] 1. The Plaintiff or protected person(s) is a spouse, former spouse, a person who cohabitates or has cohabitated with the Defendant, a parent of a common child, a child of that person, or a child of the Defendant. []2. This order is being entered after a hearing of which the Defendant received actual notice and had an opportunity to be heard. []3. Paragraph 1 of this Order has been checked to restrain the Defendant from harassing, stalking, or threatening Plaintiff or protected person(s). []4. Defendants represent a credible threat to the physical safety of the Plaintiff or the children OR [] The terms of this Order prohibit Defendant from using, attempting to use, or threatening to use physical force against the Plaintiff or the children that would reasonably be expected to cause bodily injury. [] 13. THIS ORDER SUPERSEDES [] ANY PRIOR PFA ORDER AND [] ANY PRIOR ORDER RELATING TO CHILD CUSTODY. 14. All provisions of this order shall expire in eighteen (18) months, on June 18. 2002. NOTICE TO TFIE DEFENDANT VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A F1IVE OF UP TO $1,000.00 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 THI? VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. §§ 2261-2262. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER YOU MAYBE 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 ACT, 18 U.S.C. §§ 922(G), FOR POSSESSION, TRANSPORT OR RECEIPT OF FIREARMS OR AMMUNITION. NOTICE TO LAW ENFORCEMENT OFFICIALS The police who have jurisdiction over the plaintiff s residence OR any location where a violation of this order occurs OR where the defendant may be located, shall enforce this order. An arrest for violation of Paragraphs 1 through 7 of this order may be without warrant, based solely on probable cause, whether or not the violation is committed in the presence of the police. 23 Pa.C.S. § 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 [insert the appropriate name or title] shall maintain possession of the weapons until further order of this court. When the defendant is placed under arrest for violation of the order, the defendant shall betaken 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 the plaintiff Plaintiff s presence and signature are not required to file the complaint. If sufficient grounds for violation of this order are alleged, the defendant shall be arraigned, bond set and both parties given notice of the date of the hearing. BY THE COURT: Judge Date If entered pursuant to the consent of the plaintiff and defendant: Tracy Maxwell, Plaintiff Wayne Conrad, Jr., Defendant Shirley Conrad Nace, Defendant ~ a~ ('Q~ _y =~ yG,~ ~ n _ ,~ ~ -.:~:.zwe~a. w~~~z.~~ ... 01/23/01 TCrE 09:16 FA% 717 240 6573 CUMB CO PROTRONOTARY f~j 0 0' i v T%/R% NO INCOffiPLETE T%/R% TRANSACTION OR ERROR 2411 xxxxixxxxxxxixxxxxxxxxxxxxx xxx ffiULTI TN REPORT xxx xxxxsxxxxxxxxxxxxxxxxxxxxxx O119p2406331 [ 04]92490779 CENTRAL PROCESS PSP C TO: I` ; p FAX p: C~wC'•.~"~~~ FROM: CURTIS R. LONG RE: PFA ORDERS MESSAGE: OFFICE OF THE pROTHOVOTARY Ci~IDERLAND ~UIVTY ODUR']t]CUSE ONE Ct)URT[-]OUSE SQUARE CARLISLE. PA. 17013-33$7 (717) 240-6195 FAX (717) 240-6573 V I A T E L E C O P I E R -- ~~~ NO. OF PA(~S IIBY;.'fd]6ING COVER SHEET) 'itris = is intr~c>:3d rniy f~ >i~ ~ ~ tre irdiVi~~l ~ entity tra vouch is is ~'®s3. ~ ~Y ppl~jj~ infraakAYirn t}yt jg ~j_yj]~~ (~irionF3a1 ~ ~~ ~Cpn r7imlr.am ~~+~ ~],j[fvh1P ]av. If 137e 1~^']eY' r~ t111S rtE 7S nit t11e lnt~lt~'i LBGI]ll-K]7t. yt?.1 e1LE h~7f n7Yif7ed t11Bt aly d]-S9~>3>rILTI. d3S'~t.~tim or ~'jn9 ~ t1tiG5 aonnnicc-~ei[Xf is s~lcrly )xrtlibiteci. If yai tFaue jived lfus I gOI1R,RL'iC.a`irn ir. qx~,g, notify tu^ ]R1iBd]dtlEly ty b.'le~tv-fX: 2nd xeti¢n t#~ ^~~ r~l ~ us al d~ ~_• pia tree :!.S. petal s¢~~ire. Tt~lk yal. ~,. ' X CASE NO: 2001-00362 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MAXWELL TRACY ET AL VS CONRAD WAYNE JR RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE WAYNE JR was served upon the DEFENDANT at 0013:50 HOURS, on the 23rd day of January 2001 at 175 WOODS DRIVE MECHANICSBURG, PA 17055 by handing to WAYNE CONRAD, JR. a true and attested copy of PROTECTION FROM ABUSE together with NOTICE OF HEARING, TEMPORARY PROTECTION FROM ABUSE ORDER, PETITION and at the same time directing His attention to the contents thereof. Sheriff's Costs Docketing 18.00 Service 5.58 Affidavit .00 Surcharge 10.00 .00 33.58 Sworn and Subscribed to before me this ~.ad- day of ~..e.(~/.,,,~~J¢,,,, r~U~ry~,r ~ ~ Ate. ~D~,,.~ ~( P othonotary So Answers: R. Thomas Kline O1j24j2001 By: 1 ' CASE NO: 2001-00362 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MAXWELL TRACY ET AL VS CONRAD WAYNE JR RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within PROTECTION FROM ABUSE was served upon NACE SHIRLEY CONRAD the DEFENDANT at 0016:05 HOURS, on the 23rd day of January 2001 at 919 WEST TRINDLE ROAD MECHANICSBURG, PA 17055 SHIRLEY CONRAD NACE by handing to a true and attested copy of PROTECTION FROM ABUSE together with NOTICE OF HEARING, TEMPORARY PROTECTION FROM ABUSE ORDER, PETITION and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answer 6.00 ~ 5.58 !!!~~~ .00 ~ 10.00 R. Thomas Kline nn L 1 J V Sworn and Subscribed to before me this Imo" day of Js.l~., baa o~oy / A.D. ~ Prothonotary ' ' 01/24/2001 By: ~ .~~. ,~ w TRACY MAXWELL, Individually and on behalf of her minor children, Amanda Conrad, Dylan Conrad, and Trevor Conrad, Plaintiff v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PROTECTION FROM ABUSE WAYNE CONRAD, JR., and SHIRLEY CONRAD NACE, Defendants No. 01-362 CIVIL TERM ORDER OF COURT AND NOW, this 26th day of January, 2001, upon consideration of the Plaintiff's Petition for Protection from Abuse, and following an initial half day of hearing held on this date, and the case not having been concluded, the record shall remain open, and an additional half day of testimony is scheduled for Monday, April 9, 2001, at 9:30 a.m., in Courtroom No. 1, Cumberland County Courthouse, Carlisle, Pennsylvania. It is noted that at the time of adjournment on today's date, Plaintiff had completed her case-in-chief, and Plaintiff's Exhibits 1, 2, and 3 had been identified and admitted. Defendants had not yet commenced their case-in-chief, and no other exhibits had been identified or admitted. Pending the continued hearing, the Temporary Protection from Abuse Order issued on January 21, 2001, shall remain in full force and effect. Y V IL4V(i.~~~I~ll `~~~' ~ „cif ~., it ~1 ,{L :. ~1~1.~!w+~4wxifsaP~F„~,xa~en!s°~err~x'Ss~tsg~ew~R~iw¢c&~. '.... w~. ... e Kara I. Kurtzman, Certified Teri L. Henning, Esquire Staff Attorney Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 For the Plaintiff John M. Glace, Esquire 132 Walnut Street Harrisburg, PA 17101 For the Defendants wcy - 4_-- ~ a-09.01 ~, By the Court, TRACY MAXWELL, Individually and on behalf of her minor children, Amanda Conrad, Dylan Conrad, and Trevor Conrad, Plaintiffs v. WAYNE CONRAD, JR. and SHIItLEY CONRAD NACE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW IN PROTECTION FROM ABUSE :NO. O1 - 362 CIVIL TERM CONSIa/NT AND APPROVAL FOR APPEARANCE iJNDER Pa.B.A.R 322 I hereby consent to the appearance of Kara I. Kurtzman, a Certified Legal Intem, under the supervision of an attomey, in the above-entitled Protection from Abuse proceeding before the Honorable Judge Oler at 8:45 a.m. I- / -b1 Date on January 26, O1. _~1!~ Tra e As the supervising attorney for Kara L Kurtzman, certified under Pa.B.A.R. 322, I approve of her appearance on behalf of the above-named client in the above-named proceeding. Date ~ 2~ f7) THOMAS M. ROBERT E. RAINS Supervising Attorney TERI L. HENNING Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243-2968 _-- ~ a~ ,VUit`V~ ~'~ ~~'~ Shelley A. Carrara, Esq. Deputy Pro[honotary Pa[ricia A. Honard Chief Clerk Robert E. Rains, Esq. Disability Law Clinic 45 N. Pitt Street Carlisle, PA 17013 RE: Kurtzman, Kara I. No.890 INT 2000 Dear Attorney Rains: ....i- Y . Supreme Court of Pennsylvania Western District BOl CityCounty Building Pittsburgh, PA 15219 September 6, 2000 412-565-2816 www.aopc.org The above-named law student has been approved and certified under Pa. B.A.R. 321 and 322 by: Dickinson School of Law Feldman, Harvey Associate Dean as a duly enrolled law student who has completed at least three (3) semesters of legal studies, or the equivalent thereof, as being of good character and competent legal ability, and as being adequately trained to perform as a legal intern as of September 5, 2000. Pursuant to such certification and in accordance with and subject to the provisions of Pa. B.A.R. 321 and 322, the above-named student has been certified as a legal intern and you have been approved to perform the duties of supervising attorney. WITNESS my signature and the seal of this Court, September 6, 2000 Very t yours, ~L~~ ShelleyA arrara~~~ Deputy Prothonotary lalf PARENTS TRACY - - -Michael Amanda Wayne Jr Bryan - - - Dy] an Shirley - x -Robert Kathy = ~=~- ~Ed (Tracy's Father) ~ p~~'~, ;~~ Nace TRACY Trevor ~/,~a 3~ TRACY MAXWELL, Individually and on behalf of her minor children, Amanda Conrad, Dylan Conrad, and Trevor Conrad, Plaintiffs v. WAYNE CONRAD, JR., and SHIRLEY CONRAD NACE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION -LAW NO.O1-362 CIVIL TERM ORDER OF COURT AND NOW, this 9~' day of April, 2001, upon consideration of Plaintiff's Petition for Protection from Abuse, and following a hearing held on January 26, 2001, and April 9, 2001, and the Court finding that Defendants have committed abuse as defined in the Protection from Abuse Act, the terms of the Temporary Protection from Abuse Order dated January 21, 2001, including notice and warning provisions, are hereby entered as a permanent protection from abuse order. THE DURATION of this permanent order shall be I8 months, dating from January 21, 2001. FEES, COST5 and a $25.00 surcharge are assessed against Defendants pursuant to 23 Pa. C.S. §6106. BY THE COURT, J. e ey Oler r J. ~ `~" J~""`'`" ~~ Dy-lD-o l R}4s a ij~~ ~. a r Kara I. Kurtzman, Certified Legal Intern Teri L. Henning, Esq. Staff Attorney Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 John M. Glace, Esq. 132 Walnut Street Harrisburg, PA 17101 Attorney for Defendants :rc TRACY MAXWELL, Individually and on behalf of her minor children, Amanda Conrad, Dylan Conrad, and Trevor Conrad, Plaintiffs v. WAYNE CONRAD, JR., and SHIRLEY CONRAD NACE, Defendants IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PROTECTION FROM ABUSE No. 01-362 CIVIL TERM ORDER OF COURT AND NOW, this 9th day of April, 2001, upon consideration of Plaintiff's Petition for Protection from Abuse, and following a second day of hearing in the matter, the record is declared closed, and the matter is taken under advisement. Kara I. Kurtzman, Certified Legal Intern ~g~`' Teri L. Henning, Esquire J('nO~'" Family Law Clinic 1 ` 45 North Pitt Street (J~~,,yv"~p'1 ~\ Carlisle, PA 17013 ` 6`t~~~ For the Plaintiffs ~~S John M. Glace, Esquire 132 Walnut Street Harrisburg, PA 1'7101 For the Defendants wcy By the Court, i ,,, ~~ , ; i` ~,~:~~~ .,,;ilk n,. r . . ~i~~~ a .. , ~_, CERTIFICATION OF PFA CONTEMPT C1~SE ~~ 01-362 Civil NAME Wayne Conrad, Jr. 175 Woods Drive Mecanicsburg PA 17055 Shirley Conra acs 919 W. Trindle Road Mechanicsbur~yq ~A BALANCE DUE: $ ~~ /. ~ l70 STATE SURCHARGE 171 STATE FINE 260 SHERIFF COST ($1.50 + ADDTL) 207 DISTRICT ATTORNEY 204 COURT COSTS (CLERK OF COURTS) 502 RESTITUTION NAME Prothonotary ADDRESS VICTIM'S NAME: v Maxwell ADD s :~55~' $ J $ 15.00 $ 15.00 DELETE r $ CITY STATE ZIP NAME $ $ ADDRESS CITY STATE ZIP NAME $ $ ADDRESS CITY STATE ZIP PROTHONOTARY OFFICE PERSON CERTIFYING INFORMATION - ~i - o`I