HomeMy WebLinkAbout00-05032Renee Harper, the minor Plaintiff, by
Rhonda Harper, her guardian,
Plaintiff
VS.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00- Sn2 a-. CIVIL TERM
Jeremiah Nilson,
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 a6 , 2000,
AT 14-9) M., IN COURTROOM NO. 3 OF HE CfJMBERLAND
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 subject you to a charge of indirect criminal contempt which is punishable
by a fine of up to $1,000.00 and/or up to six months in jail under 23 Pa.C.S. §6114. Violation
may also subject you to prosecution and criminal penalties.under the Pennsylvania Crimes
Code. Under federal law, 18 U.S.C. §2265, this Order is enforceable anywhere in the United
States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you travel
outside of the state and intentionally violate this Order, you may be subject to federal criminal
proceedings under the Violence Against Women Act, 18 U.S.C. § 2261-2262.
You should take this paper to your lawyer at once. You have the right to have a lawyer
represent you at the hearing. The court will not, however, appoint a lawyer for you. If you
do not have a lawyer or cannot afford one, go to or telephone the office set forth below to find
out where you can get legal help. If you cannot find a lawyer, you may have to proceed
without one.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE, CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717)249-3166
AMERICANS WITH DISABILITIES ACT OF 1990
The Court of Common Pleas of Cumberland County is required by law to comply with the
Americans with Disabilities Act of 1990. For information about accessible facilities and reasonable
accommodations available to disabled individuals having business before the court, please contact
our office. All arrangements must be made at least 72 hours prior to any hearing or business before
the court. You must attend the scheduled conference or hearing.
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Renee Harper, the minor Plaintiff, by Rhonda : IN THE COURT OF COMMON
Harper, her guardian, : PLEAS OF
Plaintiff : CUMBERLAND COUNTY,
: PENNSYLVANIA
V.
Jeremiah Jacob Wilson,
Defendant
No.
CIVIL ACTION - LAW
PROTECTION FROM ABUSE
TEMPORARY PROTECTION FROM ABUSE ORDER
Defendant's Name is: Jeremiah Jacob Wilson
Defendant's Date of Birth is: January 8, 1980
Defendant's Social Security Number is: 194-60-5241
Name(s) of All protected persons, including Plaintiff and minor children:
1. Renee D. Harper
AND NOW, on 18th Day of July, 2000 upon consideration of the attached Petition
for Protection from Abuse, the court hereby enters the following Temporary Order:
Plaintiffs request for a temporary protection order is granted.
1. Defendant shall not abuse, harass, stalk or threaten any of the above persons in
any place where they might be found.
2. Defendant is prohibited from having ANY CONTACT with Plaintiff, or any
other person protected under this Order, at any location, including but not limited
to any contact at Plaintiffs school, business, or place of employment. Defendant
is specifically ordered to stay away from the following locations for the duration
of this order.
-Plaintiffs residence located at 901 Newville Road, Carlisle, Pennsylvania,
and any future place of employment Plaintiff may establish.
- Plaintiffs school located at Carlisle High School,723 West Penn Street,
Carlisle, Pennsylvania.
3. Defendant shall not contact Plaintiff, or any other person protected under this
Order, by telephone or by any other means, including through third persons.
4. The following additional relief is granted:
- The Cumberland County Sheriffs Department shall attempt to make
service at Plaintiffs request and without pre-payment of fees, but service
may be accomplishedunder any applicable Rule of Civil Procedure.
-This Order shall be docketed in the office of the Prothonotary and
forwarded to the Sheriff for service. The Prothonotary shall not send a copy
of this Order to Defendant by mail.
- This Order shall remain in effect until modified or terminated by the Court
and can be extended beyond its original expiration date if the Court finds
that Defendant has committed an act of abuse or has engaged in a pattern or
practice that indicates risk to Plaintiff.
- Defendant shall refrain from harassing Plaintiffs relatives.
- Defendant is enjoined from damaging or destroying any property owned
solely by Plaintiff.
5. 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
Carlisle State Police Department
6. 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.
7. THIS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL
REMAIN IN EFFECT UNTIL JANUARY 18, 2002 OR UNTIL OTHERWISE
MODIFIED OR TERMINATED BY THIS COURT AFTER NOTICE AND
HEARING.
NOTICE TO THE DEFENDANT
Defendant is hereby notified that violation of this Order may result in arrest for
indirect criminal contempt, which is punishable by a fine of up to $1,000.00 and/or
up to six months in jail. 23 Pa.C.S. §6114. Consent of the Plaintiff to Defendant's
return to the residence shall not invalidate this Order, which can only be changed or
modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S.
§6113. Defendant is further notified that violation of this Order may subject him/her
to state charges and penalties under the Pennsylvania Crimes Code and to federal
charges and penalties under the Violence Against Women Act, 18 U.S.C. §§2261-
2262.
NOTICE TO LAW ENFORCEMENT OFFICIALS
This Order shall be enforced by the police who have jurisdiction over the plaintiffs
residence OR any location where a violation of this order occurs OR where the
defendant may be located. If defendant violates Paragraphs 1 through 3 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 this Order OR during prior incidents of
abuse. Weapons must forthwith be delivered to the Sheriffs office of the county
which issued this Order, which office shall maintain possession of the weapons until
further Order of this court, unless the weapon/s are evidence of a crime, in which
case, they shall remain with the law enforcement agency whose officer made the
arrest.
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PFAD Number: QV 1112424H
Renee Harper, the minor Plaintiff, by Rhonda : IN THE COURT OF COMMON
Harper, her guardian, : PLEAS OF
Plaintiff : CUMBERLAND COUNTY,
:PENNSYLVANIA
V.
No. ,v-5Z3a2,6c11j
Jeremiah Jacob Wilson,
Defendant CIVIL ACTION - LAW
PROTECTION FROM ABUSE
PETITION FOR PROTECTION FROM ABUSE
1. Plaintiffs name is:
Rhonda L. Harper
2. I, (the Filer), am filing this Petition:
- as Parent of minor Plaintiff(s)
3. Filer's Name is:
Rhonda L. Harper
4. Filer's Address is:
Betty Nelson Trailer Court, Box 41, Carlisle, PA 17013
5. Name(s) of ALL person(s), including minor children, who seek protection from abuse.
a. Renee D. Harper
6. Plaintiffs Address is : 901 Newville Road, Carlisle, PA 17013
7. Defendant's Name is:
Jeremiah Jacob Wilson
8. Defendant is believed to live at the following address:
Cumberland County Prison, 1101 Claremont Drive, Carlisle, PA 17013
9. Defendant's Social Security Number is:
194-60-5241
10. Defendant's Date of Birth is:
January 8,1980
11. Defendant's Place of employment is:
Carlisle Tire & Wheel Carlisle PA
12. Defendant is an adult.
13. The relationship between the Plaintiff and the Defendant is:
Current or former sexual intimate partner
14. The defendant has been involved in a criminal court action.
15. The facts of the most recent incident of abuse are as follows:
On or about July 10, 2000, Defendant followed Plaintiff, screamed vile names at her, and when
Plaintiff asked him to leave, he refused. Defendant pushed Plaintiff, grabbed her by the throat,
and threw her on the hood of a car. When Plaintiff got up, Defendant grabbed her by the shirt
and pushed her. Plaintiff suffered scratches and marks on her neck, chest, and arms as a result
of the incident of abuse. Defendant was arrested by the Carlisle Police for simple assault and is
currently incarcerated at the Cumberland County Prison.
16. 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:
In or about the beginning of February 2000, Defendant entered the Plaintiff's father's residence
univited and screamed vile names at Plaintiff. Plaintiffs step-mother told the defendant to leave.
Defendant later received a citation for disorderly conduct and was sent a defiant trespass letter.
In or about November or December 1999, Defendant pushed Plaintiff onto the bed and screamed
vile names at her. When Defendant's friend came into the room to stop Defendant, Defendant
pushed his friend, grabbed a knife, held it to his friend and threatened him that if he ever got
into his business again he would kill him causing Plaintiff to fear for her safety and that of
Defendant's friend.
In or about late summer or early fall 1999, Defendant pushed the plaintiff onto the hood of a car
and screamed at her. The police arrived and made Defendant leave.
Since approximately June of 1999, Defendant has abused Plaintiff in ways including the
following: pushed, grabbed, and screamed vile names at Plaintiff. Defendant constantly harassed
Plaintiff as to her whereabouts and isolated her from her friends.
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 child/ren in any place where Plaintiff may be found.
b. Prohibit Defendant from having any contact with Plaintiff and/or minor child/ren,
either in person, by telephone, or in writing, personally or through third persons,
including but not limited to any contact at Plaintiffs school, business, or place of
employment, except as the court may find necessary with respect to partial custody
and/or visitation with the minor child/ren.
c. Order Defendant to pay the costs of this action, including filing and service fees.
d. Order the following additional relief, not listed above:
- Defendant shall pay $250.00 to one of Legal Services, Inc.'s funding sources
for the cost of litigation in this case.
- Order Defendant to refrain from harassing Plaintiffs relatives.
- Enjoin Defendant from damaging, or destroying any property owned by
Plaintiff.
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.
submitted,
Date: 7?/?llJ r9
Philip C. Brilfanti, Andrea Lel , Joan Carey
and Maryann Murphy, Attorneys for Plaintiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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 knowledge. I
understand that any false statements are made subject to the penalties of 18 Pa.C.S. §4904, relating
to unworn falsification to authorities.
Dated: ?L 10 Q a "?
Renee Harper, Plaintiff
13 ? . ?la42 Qa
Rhonda Harper, Guardian
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SHERIFF'S RETURN - REGULAR
CASE NO: 2000-05032 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
HARPER RENEE A MINOR ET AL
VS
WILSON JEREMIAH
CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of
Cumberland County, Pensylvania, who being duly sworn according to law,
says, the within PROTECTION FROM ABUSE
was served upon
WILSON JEREMIAH the
DEFENDANT , at 0013:30 HOURS, on the 18th day of July , 2000
at CUMBERLAND COUNTY PRISON 1101 CLAREMONT DRIVE
CARLISLE, PA 17013 by handing to
JEREMIAH WILSON
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
me this ;21,&!- day of
?dUJ A.D.
Prothonotary
So Answers:
R. Thomas Kline
07/19/2000
By:
Deputy Sherif
I : ,
Renee Harper, the minor Plaintiff, by Rhonda : IN THE COURT OF COMMON
Harper, her guardian, : PLEAS OF
Plaintiff : CUMBERLAND COUNTY,
:PENNSYLVANIA
V.
Jeremiah Jacob Wilson,
Defendant
No. 00-5032
CIVIL ACTION - LAW
PROTECTION FROM ABUSE
FINAL ORDER OF COURT
Defendant's Name is: Jeremiah Jacob Wilson
Defendant's Date of Birth is: January 8, 1980
Defendant's Social Security Number is: 194-60-5241
Name(s) of All protected persons, including Plaintiff and minor children:
1. Renee D.Parper
AND NOW, this nay of July, 2000 the court having jurisdiction over the parties
and the subject-m Otter, it is ORDERED, ADJUDGED 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:
Plaintiffs 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. Defendant is prohibited from having ANY CONTACT with the Plaintiff, or any
other person protected under this Order, at any location, including but not limited to
any contact at Plaintiffs school, business, or place of employment. Defendant is
specifically ordered to stay away from the following locations for the duration of
this order.
-Plaintiffs residence located at 901 Newville Road, Carlisle, Pennsylvania, and
any future place of employment Plaintiff may establish.
- Plaintiffs school located at Carlisle High School,723 West Penn Street,
Carlisle, Pennsylvania.
3. Defendant-shall not contact the Plaintiff, or any other person protected under this
Order, by telephone or by any other means, including through fhird persons.
4. The following additional relief is granted as authorized by §6108 of the Act:
- Defendant shall refrain from harassing Plaintiffs relatives.
- Defendant is enjoined from damaging or destroying any property owned
solely by Plaintiff.
- The court costs and fees are waived.
5. 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
Carlisle State Police Department
6. THIS ORDER SUPERSEDES:
1. ANY PRIOR PFA ORDER
7. All provisions of this order shall expire on: January 21, 2002
NOTICE TO THE DEFENDANT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE
CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY
A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX
MONTHS. 23 PA.C.S. §6114. VIOLATION MAY ALSO SUBJECT YOU TO
PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA
CRIMES CODE.
THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT
OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE
COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST
WOMEN 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 OFFICIALS
11 -
The police who have jurisdiction over the plaintiffs residence OR any location where
a violation of this order occurs OR where the defendant may be located, shall enforce
this order. An arrest for violation of Paragraphs 1 through 3 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. Plaintiffs 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.
Od
B D
#el. 10,10e ent
Judge
If enter pursuant to the consent of plaintiff and defendant:
P amti Signature De ndant's Signature
Distribution to:
Joan Carey, Attorney for Plaintiff
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
?a
Rhonda Harper, Gu rdian
Faxed & Mailed to PSP- 010'60
Jerimiah Wilson
c/o Cumberland County Prison
1101 Claremont Drive
Carlisle, PA 17013
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07/27/00 TRU 13:35 FAX 717 240 6573 CUMB CO PROTHONOTARY Q001
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RENEE HARPER, the minor Plaintiff: IN THE COURT OF COMMON PLEAS OF
by Rhonda Harper, her guardian, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. : NO. 00-5032 CIVIL TERM
JEREMIAH JACOB WILSON,
Defendant : CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this day of MAY, 2001 this Court certifies that the
attached complaint has been properly completed and verified, and there is probable cause
for this issuance of process. In consideration of the attached Commonwealth's Petition, a
WARRANT IS ISSUED FOR THE ARREST of the Defendant, JEREMIAH JACOB
WILSON.
If the defendant is found during normal Courthouse hours, the defendant is to be
brought immediately before the Court. If not found during Courthouse hours, the
defendant is to be taken to the on-call District Justice and bail set pursuant to the Rules of
Criminal Procedure.
Defendant has a right to be represented by an attorney. If the defendant cannot
afford an attorney, upon request one will be assigned to represent the defendant. The
assessment of costs to be determined by the Trial Judge subsequent to trial.
By the Court,
r A. noffer PJ.
Jonathan R. Birbeck
Chief Deputy District Attorney> - _-Jr- 30 - dl
JEREMIAH JACOB WILSON'
iJ INSYL 4gNIA
RENEE HARPER, the minor plaintiff,: IN THE COURT OF COMMON PLEAS OF
By Rhonda Harper, her guardian, : CUMBERLAND COUNTY, PENNSYLVANIA
Plaintiff
V. : 00-5032 CIVIL
JEREMIAH JACOB WILSON,
Defendant
CHARGE: INDIRECT CRIMINAL CONTEMPT
COMMONWEALTH'S PETITION FOR A HEARING ON CHARGES
OF INDIRECT CRIMINAL CONTEMPT
Jonathan R. Birbeck, Chief Deputy District Attorney of Cumberland County,
Pennsylvania, brings the following Petition for a hearing on charges of Indirect Criminal
Contempt:
1. A Protection from Abuse Order was issued by the Court. A true and correct
copy of the Order is attached.
2. The defendant's violation of this Order is averred in the attached criminal
complaint.
3. The victim requests the filing of an Indirect Criminal Contempt Charge.
4. The District Attorney's Office approves the filing of this criminal complaint.
5. The Commonwealth is requesting a hearing on the charges of Indirect
Criminal Contempt pursuant to 23 Pa.C.S.A. § 6113.
6. The plaintiff and/or the defendant may seek modification of the Order based
on the filing of this petition as the Court deems appropriate following the trial
in addition to any other sentence. 23 Pa.C.S.A. § 6113.
WHEREFORE, the Commonwealth requests the defendant be"omm,,paided to
appear before the Court on the charge of Indirect Criminal
Attorney
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF: bxnber'land
District Nuber: 09-2-01
Justice Nare:Non. Paula P. Correal
1 Courthouse Square
Carlisle Pa. 1701300
(717)240-6564
POLICE
CRIMINAL COMPLAINT
COMMONWEALTH OF PENNSYLVANIA
Vs.
DEFENDANT:
NAME and ADDRESS
r JEPE`U.AH JACOB WILSON
90 N. NEPI=Y ST.
ocket No.: YORK, PA 17403
Date Filed:
OTN: L J
efadaM's Race/Ethnicity efedant's Sex efedant?a D.O.B. efedant's Social Security Number efedent's SID
M6hite ? Asian ? Black ? Female
? Hispanic ? Native Averican ? lxilo M Male 01/08/1980 194-60-5241 247-39-26-1
Plate Number State Registration Sticker(MM)
State
PA. 25862370
01-001452
District Attorney's Office Approved FIDisapproved because:
(The district atto mry ra}uire
at the omplaint, arrest warrant affidavit, or both be approved by the attorney for the Cammnaealth prior to
filing Pa.R.Cr.P. 1)
(Nane 0 Attorney or ease rim or Type) (Signature Attorney or Cmmiwalth) (Date)
I, DETECTIVE THOMAS A. KIBLER 2606
(Name of Affient-Please Print or Type) (officer Bade Number/I.D.)
of North Middleton Township Police 0211500 99-000414
(Identify Department or Agency Represented and Political subdivision) (Police Agency CRI Number) (Originating Agency Case Nuiber(OCA))
do hereby state:(check the appropriate box)
1. ® I accuse the above named defendant, who lives at the address set forth above
? I accuse an defendant whose name is unknown tome but who is described as
? I accuse the defendant whose name and popular designation or nickname is unknown to me and whom I have
therefore designated as John Doe
with violating the penal laws of the Commonwealth of Pennsylvania at 901 NEWVILLE RD. IN NORTH
MIDDI= TOT^=P (Place-PoliticaL subdivision)
in Cumberland County on or about 05/27/2001
Participants were: (if there were participants, place their names here, repeating the name of the above defendant)
EREMIAH JACOB WILSON
2. The acts committed by the accused were:
(Set forth a sumary of the facts sufficient to advise the defendant of the nature of the offense charged. A citation to the statute allegedly vioLated
without more, is not sufficient. In a sumary case, you must cite the specific section and subsection of the statute or ordinance allegedly violated.)
INDIRECT CRIMINAL CONTEMPT
The DEFEi = did violate the order issued under the Protection From Abuse Act
in No. 00-5032 Civil, issued 18 July 2000, by the Honorable George E. Hoffer, which
directed the DEFENDANT; Jeremiah Jacob Wilson on 18 July 2000 to refrain from making
or having any camuuLication, including telephone contact with the victim; Renee
Harper or others with wham the conmInication would be likely to cause annoyance or
alarm to the victim; to wit 5 threatening and harassing telephone calls were made by
Wilson to Renee Harpers father, Rodney Green between 0030 hours and 0500 hours on 27
May 2001, putting the victim, Renee Harper, in fear for their safety.
(Sec. 10190 June 23, 1978 PROTICN FROM ABUSE ACT).
AOPC 412-0/96)(Intemet Version) 1-3
(Continuation of 2.)
POLICE
Defendant Name: JERREMLAH JACOB WILSON
CRIMINAL COMPLAINT
Docket Number:
all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act
of Assembly, or in violation of 1. 10190 of the PFA ACT 6/23/78 1
(Section) (Sub-Section) (PA Statute) (counts)
2.
(Section)
3.
(Section)
(Sub-Section)
of the
(PA Statute) (counts)
(PA Statute) (counts)
(PA Statute) (counts)
4.
(Sub-Section)
(Section) (Sub-Section)
of the
of the
3. I ask that a warrant of arrest or a summons be issued and that the defendant be required to answer the charges
I have made. (In order for a warrant of arrest to issue, the attached affidavit of probable cause must be completed
and sworn to before the issuing authority.
4. I verify that the facts set forth in this complaint are true and correct to the best f my knowledge or information
and belief. This verification is made subject to the penalties of Section 4904 o e Crimes Code(18 PA. C.S.
4904) relating to unsworn falsification to authorities.
tgna ure o rant
AND NOW, on this date , I certify the complaint has been properly
completed and verified. An affidavit o probable cause must be compd in order for a warrant to issue.
agisten a District) (Issuing Authority)
AOPC 412-(4/96)(Internet Version) 2-3
Defendant Name: JEREMIAH JACOB WILSON
Docket Number:
POLICE
CRIMINAL COMPLAINT
AFFIDAVIT of
CMP./Inc. No. 01-001452
'RUSE
1. YOUR AFFIANT IS DETECTIVE THOMAS A. KIBLER OF THE NORTH MIDDLETON TOWNSHIP POLICE
DEPARTMENT.
2. ON 27 MAY 2001 THIS DEPARTMENT WAS DISPATCHED TO 901 NEKVILLE RD. FOR A REPORTED
PROTECTION FROM ABUSE ACT VIOLATION. UPON ARRIVAL I WAS ADVISED 13Y A RENEE HARPER
THAT SHE HAS AN ACTIVE PEA (CIVIL # 00-5032) AGAINST A JER04IAH JACOB WILSON SIGNED
BY JUDGE HOFFER; EFFECTIVE 18 JULY 2000.
3. THE PEA DIRECTS WILSON FROM MAKING ANY COMMUNICATION, INCLUDING TELEPHONE CONTACT
WITH THE PLAINTIFF OR OTHERS WITH WHOM TEE C(]vVUNICATION WOULD LIKELY CAUSE ANNOYANCE
OR ALARM.
4. ON 27 MAY 2001 BETWEEN 0030 HOURS AND 0500 HOURS, JEREK AH JACOB WILSON PLACID
FIVE TELEPHONE CALLS TO RENEE HARPERS RESIDENCE LOCATED AT 901 NEWVILLE RD. IN NORTH
MIDDLETON TOVNSIICP, AT WHICH TIME WILSON VERBALLY THREATENED AMID HARASSED HARPERS
FATHER, RODNEY GREEN.
I, DETECTIVE THOMAS A. KIBLER , BEING DULY SWORN ACCORDING TO
LAW, DEPOSE AND SAY THAT THE FACTS SET FORTH IN THE FOREGOING AFFIDAVIT ARE
TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE, ,,FORMATION AND BELIEF.
11L 'A41
Migna ure o 'Tian
Sworn to me and subscribed before me this day of
Date , District Justice
My commission expires first Monday of January, SEAL
AOPC 412-(4/96)(Internet Version) 3-3
Renee Harper, the minor Plaintiff, by Rhonda : IN THE COURT OF COMMON
Harper, her guardian, : PLEAS OF
Plaintiff : CUMBERLAND COUNTY,
:PENNSYLVANIA
V.
No. 00-5032
Jeremiah Jacob Wilson,
Defendant CIVIL ACTION - LAW
PROTECTION FROM ABUSE
FINAL ORDER OF COURT
Defendant's Name is: Jeremiah Jacob Wilson
Defendant's Date of Birth is: January 8, 1980
Defendant's Social Security Number is: 194-60-5241
Name(s) of All protected persons, including Plaintiff and minor children:
1. Renee D.9 rper
AND NOW, this Day of July, 2000 the court having jurisdiction over the parties
and the subject-m tter, it is ORDERED, ADJUDGED 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:
Plaintiffs 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. Defendant is prohibited from having ANY CONTACT with the Plaintiff, or any
other person protected under this Order, at any location, including but not limited to
any contact at Plaintiffs school, business, or place of employement. Defendant is
specifically ordered to stay away from the following locations for the duration of
this order.
-Plaintiffs residence located at 901 Newville Road, Carlisle, Pennsylvania, and
any future place of employment Plaintiff may establish.
- Plaintiffs school located at Carlisle High School,723 West Penn Street,
Carlisle, Pennsylvania.
3. Defendant shall not contact the Plaintiff, or any other person protected under this
Order, by telephone or by any other means, including through third persons.
4. The following additional relief is granted as authorized by §6108 of the Act:
- Defendant shall refrain from harassing Plaintiff's relatives.
- Defendant is enjoined from damaging or destroying any property owned
solely by Plaintiff.
- The court costs and fees are waived.
5. 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
Carlisle State Police Department
6. THIS ORDER SUPERSEDES:
1. ANY PRIOR PFA ORDER
7. All provisions of this order shall expire on: January 21, 2002
NOTICE TO THE DEFENDANT
VIOLATION OF THIS ORDER MAY RESULT IN YOUR ARREST ON THE
CHARGE OF INDIRECT CRIMINAL CONTEMPT WHICH IS PUNISHABLE BY
A FINE OF UP TO $1,000 AND/OR A JAIL SENTENCE OF UP TO SIX
MONTHS. 23 PA.C.S. §6114. VIOLATION MAY ALSO SUBJECT YOU TO
PROSECUTION AND CRIMINAL PENALTIES UNDER THE PENNSYLVANIA
CRIMES CODE.
THIS ORDER IS ENFORCEABLE IN ALL FIFTY (50) STATES, THE DISTRICT
OF COLUMBIA, TRIBAL LANDS, U.S. TERRITORIES AND THE
COMMONWEALTH OF PUERTO RICO UNDER THE VIOLENCE AGAINST
WOMEN 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 OFFICIALS
The police who have jurisdiction over the plaintiffs residence OR any location where
a violation of this order occurs OR where the defendant may be located, shall enforce
this order. An arrest for violation of Paragraphs 1 through 3 of this order may be
without warrant, based coley 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. Plaintiffs 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.
?d
B 0 R :
qWNrrsi ent
Judge
If entere pursuant to the consent of plaintiff and defendant:
Plainti Signature De ndanfs Signature
Distribution to:
Joan Carey, Attorney for Plaintiff
Legal Services, Inc.
8 Irvine Row
Carlisle, PA 17013
Rhonda Harper, Gu rdian
Faxed & Mailed to PSP- 7 -,?G-60
Jerimiah Wilson
c/o Cumberland County Prison
1101 Claremont Drive
Carlisle, PA 17013
RENEE HARPER, the minor IN THE COURT OF COMMON PLEAS OF
Plaintiff by Rhonda CUMBERLAND COUNTY, PENNSYLVANIA
Harper, her guardian,
Plaintiff
V. NO. 00-5032 CIVIL TERM
JEREMIAH JACOB WILSON
Defendant CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this 19th day of June, 2001, after hearing
and consideration of testimony presented, the Court does find we
have a reasonable doubt, consequently we find the indirect
criminal contempt charge not supported and dismiss it, defendant
to be released. We direct that the defendant submit to processing
before he is released from custody.
Alina Andreoli, Certified Legal Intern
Office of the District Attorney
Robin C. Marable, Certified Legal Inte n ?? M{}Y
Office of the District Attorney 'U - 1?
Probation
Sheriff
CCP
pcb
By the Court,
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i
'
V).A. Q ...
-
RENEE HARPER, the minor
Plaintiff by Rhonda
Harper, her guardian,
Plaintiff
V.
JEREMIAH JACOB WILSON
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 00-5032 CIVIL TERM
CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this 12th day of June, 2001, it appearing to
the Court that one or both sides may have additional witnesses to
call, further hearing in the case is set for Tuesday, June 19,
2001, at 3:00 p.m. in this courtroom.
By the Court,
// I Ahjft--'?
Ge g c fer, Y.J.
Alina Andreoli, Certified Legal Intern
Office of the District Attorney
Robin C. Marable, Certified Legal Intern
Office of the District Attorney
Probation
Sheriff
CCP
pcb
f
PENNSYLVANIA