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Home My WebLink About01-0374 FXChristina Marie Cain, :1N THE COURT OF COMMON PLEAS OF Plaintiff vs. Robert Lee Moyer, CUMBERLAND COUNTY, PENNSYLVANIA N0.2001- 3~ CIVIL TERM 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 ~~ °~~ ~(IOI,AT 3~ ~ .M., IN COURTROOM NO. ,S OF THE UMBERLAND COUNTY COURTHOUSE, 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 subj ect you to a charge of indirect criminal contempt which is punishable by a fine of up to $1,000.00 and/or up to six months in jail under 23 Pa.C.S. §6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under federal law, 18 U.S.C. §2265, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel outside of the state and intentionally violate this Order, you maybe 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`O~F 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: ~~~~ ~~ ~~s:r~wn si ~~r io ~~i~~~~.4~~i~ Christina Marie Cain Plaintiff v. IN THE COURT OF COMMON :PLEASOF :CUMBERLAND COUNTY, :PENNSYLVANIA :No. ol- 3~j' Robert Lee Moyer Defendant CIVIL ACTION -LAW PROTECTION FROM ABUSE TEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name is: Robert Lee Moyer Defendant's Date of Birth is: November 2,1972 Name(s) of All protected persons, including Plaintiff and minor children: 1. Christina Marie Cain AND NOW, on~%Aa(• /9_~~pon consideration of the attached Petition for Protection from Abuse, th court hereby enters the following Temporary Order: Plaintiff s request for a temporary protection order is granted. 1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. 2. The following additional relief is granted: The Cumberland County Sheriff s Department shall attempt to make service at Plaintiff s request and without pre-payment of fees, but service may be accomplished under any applicable Rule of Civil Procedure. This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service. The Prothonotary shall not send a copy of this Order to Defendant by mail. This Order shall remain in effect until modified or terminated by the Court and can be extended beyond its original expiration date if the Court fmds 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 Plaintiff s relatives. 3. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Carlisle Police Department 4. The sheriff, police or other law enforcement agencies are directed to serve the Defendant with a copy of the Petition, any Order issued, and the Order for Hearing without prepayment of costs. The Petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. The Prothonotary is directed to file this Petition and Order without prepayment of costs. 5. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL JULY 18, 2002 OR UNTIL OTHERWISE MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND HEARING. NOTICE TO THE DEFENDANT Defendant is hereby nofified 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. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the police who have jurisdiction over the plaintiffs residence OR any location where a violation of this order occurs OR where the defendant maybe located. If defendant violates Paragraph 1 of this Order, defendant shall 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 tllis 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 weapons are evidence of a crime, in which case, they shall remain with the law enforcement agency whose officer made the arrest. Date U ~a M. 6!~- J. ~,,,.~ ~,,,y.~.~---a .mom-~<.F~-!U ~s/~ ~,'J 9 Pam, `'"~ Cep-~,~,.~ ~.~~-O - ~ ~i~'~- S. Distribution to: MidPenn Legal Services Faxed & Mailed to PSP PFAD Number: GDI 184424T Christina Marie Cain Plaintiff IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, :PENNSYLVANIA v. Robert Lee Moyer Defendant :No. ol- 3~y CIVIL ACTION -LAW PROTECTION FROM ABUSE PETITION FOR PROTECTION FROM ABUSE 1. Plaintiffs name is: Christina Marie Cain 2. I, (the Plaintiff), am filing this Petition on behalf of: - myself 3. Name(s) of ALL person(s), including minor children, who seek protecfion from abuse. a. Christina Marie Cain 4. Plaintiffs address is confidential 5. Defendant's Name is: Robert Lee Moyer 6. Defendant is believed to live at the following address: Cumberland County Prison ,1101 Claremont Road ,Carlisle, PA 17013 7. Defendant's Date of Birth is: November 2,1972 8. Defendant's Place of employment is: unemployed 9. Defendant is an adult. 10. The relationship between the Plaintiff and the Defendant is: Current or former sexual/intimate partner 11. The defendant has been involved in a criminal court action. 12. The defendant is currently on probation /parole. 13. The defendant is currently on County probation /parole. Description: Perry County 14. The facts of the most recent incident of abuse are as follows: On about Sunday, January 07, 2001 at approximately 9:30AM location: alley behind Molly Pitcher Hotel Defendant wrapped his arm around Plaintiff s neck, punched her in the arm, and attempted to take Plaintiff s keys from her. When Plaintiff pushed the button for her car alarm to alert someone to help her, Defendant put his arm around her neck a second time and punched her. Defendant continued to try to get Plaintiff s keys from her. When Plaintiff s friend attempted to help Plaintiff, Defendant slapped Plaintiffs friend in the face. Defendant threatened to kill her Plaintiffs daughter. A resident at the Molly Pitcher heard the comotion and called the police. The police arrived and arrested Defendant who was charged with simple assault and harassment. 15. Prior incidents of abuse that the Defendant has committed against Plaintiff or the minor child/ren, (including any threats, injuries, or incidents of stalking) are as follows: Throughout the year 2000, on several occasions Defendant became angry and threatened to kill Plaintiff sstep- father, and cause bodily harm to her daughter, mother, and ex-husband. On or about Easter 2000, Defendant shoved Plaintiff into the bathroom door causing her to fear for her safety. On or about Mother's Day weekend of 2000, Defendant jumped on top of Plaintiff s car when she attempted to drive away and kicked the windshield until it shattered. Defendant got the fire jack out of the vehicle and hit Plaintiff s trunk causing a dent. When Plaintiff got out of the car, Defendant attempted to push her down. 16. The police department(s) or law enforcement agencies that should be provided with a copy of the protection order are: Carlisle Police Department 17. There is an immediate and present danger of further abuse from the Defendant. 18. FOR THE REASONS SET FORTH ABOVE, I REQUEST THAT THE COURT ENTER A TEMPORARY ORDER, and AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: a. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff and/or minor children in any place where Plaintiff maybe found. b. Order Defendant to pay the costs of this action, including filing and service fees. c. Order the following additional relief, not listed above: Defendant shall not harass Plaintiff's relatives. Defendant shall not damage or destroy any property owned by Plaintiff. Defendant shall pay 5250.00 to one of MidPenn's fnnding sources as reimbursement for litigation in this case. d. Grant such other relief as the court deems appropriate. e. Order the police or other law enforcement agency to serve the Defendant with a copy of this Petition, any Order issued, and the Order for Hearing. The petitioner will inform the designated authority of any addresses, other than the Defendant's residence, where Defendant can be served. Respectfully submitted, Date: ~ / ~ 0 Distribution to: MidPenn Legal Services Fax and Mail PSP oan Attorne for Pl ' 'ff Y. Y MID-PENN LEGAL SERVICES 8 Irvine Row Cazlisle, PA 17013 VERIFICATION I verify that I am the Petitioner as designated in the present action and that the facts and statements contained in the above Petition are true and correct to the best of my lrnowledge. 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: ~~~(~ ~ ~n,~o~i~c.r4', ~ ~ ~s , ~~tina Cain, Plaint~~ ~w-.gym c3 D ,~, Yj ~ ~ re ~' ,,^''i Ti l11 ~~(~' ~s ==~ Q -~ f ~ ^~~ '~C ° ~C ^C d 1 i ~~ C~ r •~ 07./]_9/07. FRI 7.3:59 FAX 717 240 6573 CUffiB CO PROTHONOTARY ~ f~j 001 a~*s ffi[1LTI TN REPORT ~*~ *~%3Y~%~5~~%2i:k N~B~%~*k38**~&~~RB T%/R% NO 2404 INCOffiPLETE T%/RX TRANSACTION OK C O179p2405331 CENTRAL PROCESS - C 0379P2438026 LEGAL SERVICES C 04]92490779 PSP ERROR r OFFICE OF THE PROT]iCNOTARY CUhffiERLANG COUN'CX COURTHOUSE ONE COURTFIWSE SQUARE CARLISLE, PA. 17013-3387 (717) 240-6195 ~ ~ ~t ~'~1 ~-~ J TU: FA 5TATE PQLICE FAX q; 717-249-0779 FRAM: CURTIS R. LONG RE: PFA ORDERS MESSAGE FAX (717) 240-6573 V I A T E I, E C O P I E R ~~ NO. OF PA(~5 (IM;.'!.UDING COVER SHEEP) This is in> utly fc~ tt~ isE: of tf a irxti~+irhtil ~ art~.ty tci vA~~ is is at#->~,sed. and rtay pQ'~jn in$n7let=rt7 tE'Y7t i5 ~7Vi1FJ~d, o~lfid3it]dl 31d 0C9I~ fZUn d7'9C'lrxa era 4t~ ~jptj]~ ldv. If 0>? >~r ~ trtis is rot de zntsr7~] ~eci[iient, ycu ate ]>~ n5txfied that ay di~niratital. distr~kut m cg cbp,~irxj c~ this mmuvra~;rn is shxictly rrrrhihi hsd. If yw have r~ieined ttus cr~m~nic.3;~cn it ecx~.x, pl~se notify ~s ;~w;.~tv by t~d-rre exl ~~.an He ~r-i!:ri!tal n W u3 a~ Christina Marie Cain Plaintiff :1N THE COURT OF COMMON : PLEAS OF :CUMBERLAND COUNTY, :PENNSYLVANIA v. Robert Lee Moyer Defendant No. 01-374 CIVIL ACTION -LAW PROTECTION FROM ABUSE FINAL ORDER OF COURT Defendant's Name is: Robert Lee Moyer Defendant's Date of Birth is: November 2,1972 Name(s) of All protected persons, including Plaintiff and minor children: 1. Christina Marie Cain /~ ~,~oo~ AND NOW, this 1 ~ fw, the court having jurisdiction over the parties and the subjectbject~s ORDERED, ADNDGED and DECREED as follows: Upon agreement of the parties for the entry of a consent order, this order will be entered without any admission of liability by the defendant and without a finding of abuse by this court: Plaintiff's request for a final protection order is granted. 1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other protected person in any place where they might be found. 2. The following additional relief is granted as authorized by §6108 of the Act: 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 Plaintiff s relatives. The court costs and fees are waived. 3. A certified copy of this Order shall be provided to the police department where Plaintiff resides and any other agency specified hereafter: Carlisle Police Department 4. T$IS ORDER SUPERSEDES: 1. ANY PRIOR PFA ORDER 5. All provisions of this order shall expire on: July 24, 2002 NOTICE TO THE DEFENDANT VIOLATION OF THI5 ORDER MAY RESULT IN YOUR ARREST ON THE CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX MONTHS. 23 PA.C.S. §6114. VIOLATION MAY ALSO SUBJECT YOU TO PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA CRIMES CODE. THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST WOMEN ACT, 18 U.S.C. §2265. IF YOU TRAVEL OUTSIDE OF THE STATE AND INTENTIONALLY VIOLATE THIS ORDER, YOU MAY BE SUBJECT TO FEDERAL CRIMINAL PROCEEDINGS UNDER THAT ACT. 18 U.S.C §§2261- 2262. IF THE BRADY INDICATOR PARAGRAPH APPEARS IN THE ORDER, 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 OFFICLALS The police who have jurisdiction over the plaintiffs residence OR any location where a violation of this order occurs OR where the defendant maybe located, shall enforce this order. An arrest for violation of Paragraph 1 of this order may be without warrant, based soley on probable cause, whether or not the violation is committed in the presence of the police. 23 Pa.C.S. §6113. Subsequent to 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 shall maintain possession of the weapons until further order of this Court. When the defendant is placed under arrest for violation of this order, the defendant shall be taken to the appropriate authority or authorities before whom defendant is to be arraigned. A "Complaint for Indirect Criminal Contempt" shall then be completed and signed by the police officer OR the plaintiff: Plaintiff's presence and signature aze not required to 61e the complaint. If sufficient grounds for violation of this order aze alleged, the defendant shall be arraigned, bond set and both parties given notice of the date of the hearing. BY w E. Guido, JucTge d ~ ~a ( - -. Date If entered pursuant to the consent of plaintiff and defendant: This Order is entered pursuant to the consent of Plaintiff and Defendant: Ct ' ina Cain, Plaint Robert Moyer, Defendant Pro Se Defendant 1 oan Carey, Attorney fo lainiiff MIDPENN LEGAL RVICES 8 Irvine Row Carlisle, PA 17013 (717)243-9400 o~enca-~o PSP ~QxEd +o Pgp,.LS-C~P oz-o i -oi ~~ ~ ~,o C~o~- v~ ~~:e E,; ~..~~~~a ui~~'t ~ v _ .. off. ., q,.~ ., ... ~erao- --n;~,~ -, .-,;v~..r.~r!um .._.- ..rari~a?tsa~~!p ....... .' ~ ool 02/02/01 FRI 08:32 FAX 717 240 6573 CUffiB CO PROTHONOTARY s::s~~zs~wssa~~~aa*~asx~*~e~~** ixt: MULTI TN REPORT :~* a:~:~~xax~~ss~**~:~*ixasx~*~~s~ 3 TX/RX NO INCOMPLETE T%/RX TRANSACTION OR ERROR 2433 [ 0119p2405331 [ 04]92490779 CENTRAL PROCESS PSP rn OFFICE OF THE PROTHCNt7CARY CUMEERLAND COUNZY OOPJRTHCUSE ONE COUR'1Ti0USE SQUARE CARLISLE, PA. 17013-3387 (717) 240-6195 ~ro: FN{ N: FRCr4: 'Q FAX (717) 240-6573 ~~r 1 V I A T E L E C O P I E R ~S ['~~.~ ~~ l ~rv~~es~'r~~r ~- ~t~o ~ 531 CURTIS R. LONG ~' ~ F,4 D rd ~ ~s MESSAGE: ND. OF PAGES (IN^f.WING COVER SHEET) '~ ltds ~~: is arm ally fior ti,~ IsE ~ ~ irxliv;rl+~1 oc s~tity ~ w,dlicil is ;s ~ ~v ornra;., iniic~atir.a, that is ~, ornEidar»a. a13 eamrpL• exan ~+a+lrxa ~m ,nom BEpiic~ite k~. [ F tip t~ a£ this is rot ale intet~i xeciair3it, ya, ace hece-br roti_Eisd #k1t a'y diatitn, d-ctr+t~n•;m ~ p~rjry~ pf tt11S Q7RR.fllCdt;m ]S' Strctly ~'[d'libitAd. If yo, Ysn+E xed~.~ Ous oo[Ouvc.~. irn it ter. ple~e rna•'-w us imiediat~Ly br tiF;],e~-t:r~ a-a Letlrcn tt~ Viral ~ ~ ~: the ~-U.: via Lt~'.!.S. petal 9e[~ia2. Thank yut. 92/02/01 FRI 08:38 FA% 717 .40 6573 CUMB CO PROTHONOTARY fool 1 ~s~a:zsixstsa~ixxss~~e~~** stix T% REPORT xa~* z s~RMZZac ~&YYR~k~YY&N~:kYB~ TRANSMISSION OR T%/R% NO 2434 CONNECTION TEL 9p2438026 CONNECTION ID LEGAL SERVICES ST. TIME 02/02 08:33 USAGE T 02'28 PGS. 6 RESULT OR M O('FICE OF THE.PRdCHONOTARY CYJN~3ERLAND dOLiNtY COURTHCUBE p~VE COURTFICUSE SQUARE 4 CARLISLE, PA. 17013-3387 (717) 240-6195 FAx (717) 240-6573 ~~~ V I A TELECOF I E R To: ~ P ~~ ~u I ~r vG-c 55 «~ FAX ~: ~ -- d ~o -- S ~ 3 f ~; CURTIS R. LONG ~~ ~ F~~ Ord~~s MESSAGE: ~r ND. OF PACES (INCLUDING OOM1/ER ^aNEEC) r~ it ~-~-- ^- ~: a... ,... ,.i.;.i. is ie , ~ .. .. - uei uei ul rivx xL: J4 rein rl~ t4u oars ~umn vu rnuxnuivuxnnx yJVVi N:&S~N ~kYY*858~ffiYYB~N~ffit&~Yffi YSffiN: *z: ffiULTI TN REPORT sx~~ *~azs~xssa~zzsx~~e~zsa~~axs~**:s* T%/R% NO 2435 INCOffiPLETE T%/Rb TRANSACTION OK [ O1]9p2405331 CENTRAL PROCESS [ 0319p2438026 LEGAL SERVICES [ 04192490779 PSP ERROR ,~ ~~ ~~ Christina Marie Cain Plainti v. Robert Lee Moyer Defendant : IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, :PENNSYLVANIA No. 01-374 CML ACTION -LAW PROTECTION FROM ABUSE FINAL ORDER OF COURT Defendant's Name is: Robert Lee Moyer Defendant's Date of Birth is: November 2,1472 Name(s) of All protected persons, including Plaintiff and minor children: 1. Christina Marie Cain ~ ~a0 ( AND NOW, this i ~: the court having jurisdiction over the parties and the subject-ma er, it is ORDERED, AD7UDOED and DECREED as follows: Upon agreement of the parties for the entry of a consent order, this order will be entered without any admission of liability by the defendant and without a finding of abuse by this court: Plaintiff's request for a iiitatal protection order is granted. 1. Defendant shall not abuse, stalk, harass, threaten the Plaintiff or any other protected person in any place where they might be found. 2. The following additional relief is granted as authorized by §b 108 of the Act: SHERIFF'S RETURN - REGULAR 1 CASE N0: 2001-00374 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OE CUMBERLAND CAIN CHRISTINE MARIE VS MOYER ROBERT LEE CPL. TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says,-the within PROTECTION FROM ABUSE was served upon ROBERT LEE DEFENDANT the at 0014:46 HOURS, on the 19th day of January 2001 at CUMBERLAND CO. PRISON CARLISLE. PA 17013 ROBERT L. MOYER 1101 CLAREMONTI RD by handing to a true and attested copy of PROTECTION FROM ABUSE together with NOTICE OF HEARING & ORDER, TEMPORARY PROTECTION FROM ABUSE ORDER, PETITION and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 3.10 Affidavit .00 Surcharge 10.00 .00 31.10 Sworn and Subscribed to before m/e tlhis ~lY ~ day of ~i~T_ ~2/~~~7 /^ A . D . So Answers: R. Thomas Kline 01/19/2001 By . _.____- _ D uty Sher f rdthonotary ~. Christina Marie Cain Plaintiff v. IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, :PENNSYLVANIA No. 01-374 Robert Lee Moyer Defendant CIVIL ACTION -LAW PROTECTION FROM ABUSE CONTINUED TEMPORARY ORDER AND NOW, this 29th Day of January, 2001, pursuant to 23 Pa.C.S. §6107(c), the terms and conditions of the Temporary Order issued on 19th Day of January, 2001, in the above-captioned case are hereby continued in full force and effect until further order of the court. BY T OU E war E. Gui o, Ju ge Distribution To: MidPenn Legal Services Faxed & Mailed to PSP F Y q_. SJJ~ ~ ~Z %) _ ~% ~ .C:-i°" Gf _.a .: '_ C: ,, _,, ` j J , L -' ~ ~, ~ ~1 A Christina Marie Cain, Robert Lee Moyer, Plaintiff vs. Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA N0.2001- CIVIL TERM PROTECTION FROM ABUSE MOTION FOR CONTINUANCE The Plaintiff, Christina Cain, by and through her attorney, Joan Carey of MidPenn Legal Services, moves the Court for an Order continuing generally the hearing in the above-captioned case on the grounds that: A Temporary Protection From Abuse Order was issued by this Court on January 19, 2001, scheduling a hearing for January 26, 2001, at 3:00 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 the Cumberland County Prison, 1101 Claremont Drive, Carlisle, Pennsylvania, on January 19, 2001, at 2:46 p.m. The parties agree that the hearing be continued generally to afford them time to execute a consent agreement. 4. The Plaintiff requests that the Temporary Protection From Abuse Order remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. WHEREFORE, the Plaintiff requests that the Court grant this Motion and continue this matter generally, and that the Temporary Protection From Abuse Order remain in effect for a period of eighteen months from the date it was entered or until further Order of Court, whichever comes first. Respectfully submitted, oan Carey, Attorney for Pl ' 'ff MIDPENN LEGAL SERVICES 8 Irvine Row Carlisle, PA 17013 (717)243-9400 ~ 4~ C:. C ~` M z ;, ~~` ~ _ - ''= ' rc: ~ ~ `{. ~C lv S7