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""''11 (.,e'" " ~-1 l- f: 'I "'" ~-, /' . ., k~~"'" '_d ,_ ,....."..-._~>....~'; CERTIFICATION OF PFA'S Case Number fltJ,2-39 CWi.l TMm- ~25m~. r:~~: ~A/~1o;7- ~/O victim's Name: 1(401 ~~ 1YJ~~ Name Balance Due: $ qq, 5"0 170 State Surcharge 171 State Fine 260 Sheriff Cost ADD $ aG; 00 $ $ J. q. 00 DELETE $ $ $ 502 Restitution $ $ Name -PMt~ ~ (9UJv- Address $ /fS; 50 City State Zip Name Address $ City State _ Zip Name Address $ City State _ Zip Prothonotary Office ~ Person Certifying Information ~~fli.u.- Date /01311"7 I I , KATHY LYNN MILLER, Plaintiff :IN THE COURT OF COMMON PLEAS OF v. :CUMBERLAND COUNTY, PENNSYLVANIA :NO, 94-239 CIVIL TERM :PROTECTION FROM ABUSE CHARLES EDGAR MILLER, JR., Defendant TEMPORARY PROTECTION ORDER AND NOW, this/lf ~ay of October, 1997, upon presentation and consideration of the within Petition, and upon finding that the Plaintiff, Kathy Lynn Miller, and her children, now residing at 141 East Louther Street, First Floor, Carlisle, Cumberland County, Pennsylvania, is in immediate and present danger of abuse from the defendant, Charles Edgar Miller, Jr., the following Temporary Order is entered. The Defendant, Charles Edgar Miller, Jr. (SSN: 197.54.3340)(DOB: 11113/62), now residing at l24 Ann Street, 1st Floor, Middletown, Dauphin County, Pennsylvania, is hereby enjoined from physically abusing the Plaintiff, Kathy Lynn Miller, or their children, or from placing them in fear of abuse. The children are: Joseph Michael Miller, born October 19, 1991 and Jennifer Hailey Miller, born April 4, 1995. The Defendant is ordered to stay away from the Plaintiff's residence at 141 East Louther Street, 1st Floor, Carlisle, Cumberland County, Pennsylvania, a residence which is leased by the Plaintiff, and is ordered to stay away form any residence the Plaintiff may in the future establish for herself. The Defendant shall remain in his vehicle at all times during the transfer of custody, or in other ways shall abide by the rules of any visitation supervision program, such as the Carlisle YWCA, The Defendant is ordered to refrain from having any direct or indirect contact with the Plaintiff including, but not limited to, telephone and written communications, except for the limited purpose of facilitating custody arrangements, The Defendant is enjoined from harassing and stalking the Plaintiff, and from F'"J~) ,-- ".,". , ;, ,I Cr ell f.r;1\ \, , , \ j: ~~ \ ClR,'.:: ~-'.~ '~1'..';--:"1' (-L:;-~>,f~"; ,_ /; ,'..1 :, harassing her relatives, or the parties' minor children. The Defendant is enjoined from entering the PlaintiIT's place of employment and the day care facility of the minor children. Any custodial arrangements in which the Defendant is to visit with the minor children shall be arranged for in a supervised setting, through the YWCA of Carlisle program or any similar program agreed to by the parties. The Defendant is enjoined from removing, damaging, destroying or selling any property owned by the Plaintiff. A violation of this Order may subject the defendant to: i) arrest under 23 Pa.C.S. !}6113; ii) a private criminal complaint under 23 Pa.C.S. !}6113.1; ill) a charge of indirect criminal contempt under 23 Pa.C.S. !}6114, punishable by imprisonment up to six months and a f'me of$100.00-$I,OOO.00; and iv) civil contempt under 23 Pa.C.S. !}6114.1. 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 the defEndant has committed an act of abuse or has engaged in a pattern or practice that indicates risk of harm to the Plaintiff. This Order replaces any prior Orders entered at the above term and number. The defendant is ordered to relinquish to the sheriff's department and weapons which he owns or possesses (a switchblade knife), and the Defendant is prohibited from acquiring or possessing any weapons for the duration of this Order. ,J :1.1 A HEARING SHALL BE HELD ON THIS MATI'ER ON &l'b{J, 1997, AT IfJ:30/l.M., IN COURTROOM NO..::L, OF THE CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA. The Plaintiff has already been permitted to, and may continue to proceed without pre-payment of fees pending a further Order after the hearing. The Cumberland County SheriIT's Department shall attempt to make service at the plaintiIT'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 Defendant's counsel for service, given that the Defendant has previously been served with the original Petition in this case and counsel has entered an appearance on behalf of the Defendant. The Carlisle and any other relevant Police Department shall be provided with a certified copy of this Order by the Plaintiff's attorney. This Order shall be enforced by any law enforcement agency where a violation occurs by arrest for indirect criminal contempt without warrant upon probable cause that this Order has been violated, whether or not the violation is committed in the presence of the police officer. In the event that an arrest is made, under this section, the Defendant shall be taken without unnecessary delay before the court that issued the order. When that court is unavailable, the Defendant shall be taken before the appropriate district justice. (23 Pa.C.S. fi6113). By the Court A ,6 . 11 .' V. I IN THE COURT OF COMMON PLEAS OP I CUMBERLAND COUNTY, PENNSYLVANIA I I NO. 94-239 CIVIL TERM I I CIVIL AC~ION - LAW I PROTECTION FROM ABUSE KATHY LYNN MILLER, PLAINTIFF CHARLES EDGAR MILLER, JR. DBPENDAN~ SUPPLEMENTAL PETITION FOR PROTECTION ORDER AND REQUBST FOR HEARING COMES NOW, the Plaintiff in the above matter, Kathy L. Miller, by her attorney, Samuel W. Milkes, and requests of this Honorable Court that it modify the current Temporary Protection Order and that it schedule a hearing for entry of a final Protection from Abuse Order in the above case. In support of this request, Plaintiff alleges as follows: 1. Based upon a Prior Petition for Protection Order filed by the Plaintiff on September 23, 1997, a Temporary Protection Order was entered by the Honorable Kevin A. Hess on September 23, 1997. A copy of the prior Petition and Temporary Order are attached. 2. On October 2, 1997 by stipulation of the parties, through their counsel, the matter was continued generally without prejudice to either party to request a hearing, and the terms of the September 23, 1997 order remained in effect until modified or terminated by the Court. A copy of this Order is also attached. 3. Since the incidents described in the prior Petition, the following has occurred, posing an immediate threat to the safety and well-being of the Petitioner and her minor children: , . . . .' a. On October 12, 1997, the Plaintiff appeared at the residence of the Defendant, in her automobile, for the scheduled exchange of the minor child, Jennifer. b. The Plaintiff had first appeared at a Fox market, nearby the Defendant's residence, as the parties had previously agreed, in order to meet in a more public setting, but the Defendant failed to appear at this location. She therefore proceeded to his residence, where he already was exercising visitation with their son. b. This exchange was to take place in Middletown, Dauphin County, where the Defendant resides. c. At the time of the exchange, present in the Plaintiff's automobile was also an adult female friend, Nancy Nixon. d. without provocation, and apparently because the Plaintiff had brought with her an adult friend, the Defendant became enraged and immediately began shouting obscenities at the Plaintiff, in the presence of the parties' daughter. He then spit at the Plaintiff in her face. He threatened to "punch [her] in the mouth." The Defendant then grabbed the minor child, Jennifer, born April 4, 1995, being two years of age, and while holding the child, grabbed the Plaintiff and choked the Plaintiff. He also stated to the Plaintiff that he may not be at his residence, the point of exchange of the children, when it was time for Plaintiff to retrieve the children. e. Nancy Nixon was able to telephone the Middletown police by cellular telephone. f. The police responded to the scene and at the time of filing of this Petition it is believed and therefore averred that the ,~"':~"." > '.. .' police intend to apprehend the Defendant and charge him with indirect criminal contempt of the Court's prior Temporary Order. g. As a result of this incident the Plaintiff received treatment at the Carlisle Hospital and the Plaintiff's child, Jennifer, complained of stomach pains from being squeezed so hard by the Defendant during the altercation. 4. The incident described above is a similar and follow-up circumstance to that described in the prior Petition, at paragraph (4C), in which the Defendant has used exchanges of the two minor children as a time to express his frustrations to Plaintiff and to physically assault the Plaintiff. 5. The incident described above reflects a situation in which the Defendant has now not only placed the Plaintiff in fear of further abuse and has abused the Plaintiff, as defined in the Protection from Abuse Act, but he has also placed a minor child in a dangerous situation and has abused the minor child, as defined under the Act. > 1 WHEREFORE, for the above referenced reasons, the Plaintiff respectfully requests of this Honorable Court that: a. A hearing be scheduled in the above matter for the purpose of considering the relief previously requested in the prior Petition for Protection Order, and in addition, granting further temporary relief in the way of supervised visitation as the visitation the Defendant would have with the minor children, so as to avoid any risk of further harm or threat of harm to the children and so as to avoid any contact between the parties surrounding " ii ! ~l ! " . , " .. ..' exchanges of custody. b. until a hearing can be held in this matter, Plaintiff respectfully requests that this Court amend its prior Temporary Protection Order to include a requirement that any visitation of the Defendant with the children be in a supervised setting, which can be arranged through a program available at the Carlisle Area YWCA, or another mutually agreed-upon provider. Respectfully submitted, \O\I"\~1 B~?'~ JACOBSEN & MILKES 52 E. High Street Carlisle, PA 17013 (717) 249-6427 Attorney No. 30130 . . " . .. ..1 The above named Plaintiff, Kathy Lynn Miller, verifies that the statements made in the above Petition are true and correct. The Plaintiff understands that false statements herein are made subject to the penalties of 18 Pa.C.s. !l4904 relating to unsworn falsification to authorities, Date: /O.J3.en /') Kathy' I ynn Miller, Plaintiff ,\ ' KA TIIY LYNN MILLER. Plaintiff : IN THE COURT OF COMMON PLEAS OF v, : CUMBERLAND COUNTY. PENNSYL VANIA : NO, 94-239 CIVD.. TERM CHARLES EDGAR MILLER. JR.. Defendant : PROTECTION FROM ABUSE TEMPORARY PROTECTION ORDER AND NOW, this ,n~ay of September, 1997, upon presentation and consideration of the within Petition, and upon finding that the plaintiff. Kathy Lynn Miller, now residing at 141 East Louther Street. 1st Floor. Carlisle, Cumberland County, Pennsylvania, is in immediate and present danger of abuse from the defendant. Charles Edgar Miller, Jr., the following Temporary Order is entered, The defendant, Charles Edgar Miner, Jr. (SSN: 1 97-54-3340)(D08: 11/13/62). now residing at 124 Ann Street, 1st Floor. Middletown, Dauphin County, Pennsylvania, is hereby enjoined from physically abusing the plaintiff. Kathy Lynn Miller, or from placing her in fear of abuse, The defendant is ordered to stay away from the plain tift's residence located at 141 East Louther Street, 1st Floor. Carlisle, Cumberland County, Pennsylvania, a residence which is leased by the plaintiff. and is ordered to stay away from any residence the plaintiff may in the future establish for herself, The defendant shall remain in his vehicle at all times during the transfer of custody, The defendant is ordered to refrain from having any direct or indirect contact with the plaintiff including. but not limited to, telephone and written communications. except for the limited purpose of facilitating custody arrangements, The defendant is enjoined from harassing and stalking the plaintiff and from harassing her relatives. or the panies' minor children. The defendant is enjoined from entering the plain tift's place of employment and the day care facility of the minor children, The defendant is enjoined from removing, damaging, destroying or selling any property owned by the plaintiff. A violation of this Order may subject the defendant to: i) arrest under 23 Pa.C.S. ~6113; ii) a private criminal complaint under 23 Pa.C.S. ~6113.1; iii) a charge of indirect criminal contempt under 23 Pa.C.S. ~6114. punishable by imprisonment up to six months and a fine ofSl00.00-$1.000.00; and iv) civil contempt under 23 Pa.C.S. ~6114.1. This Order shall remain in effect until modified or tenninated by the Coun and can be extended beyond its original expiration date if the Coun finds that the defendant has committed an act of abuse or has engaged in a pattern or practice that indicates risk of hann to the plaintiff. The defendant is ordered to relinquish to the sherilrs department any weapons which he owns or possesses (a switchblade knife). and the defendant is prohibited from acquiring or possessing any weapons for the duration of this Order. A HEARING SHALL BE HELD ON THIS MAlTER ON CP.:.td<-<- _-?J . 1997. AT _~' Vll P .M..IN COURTROOM NO. i.f. OF THE CUMBERLAND COUNTY COURTHOUSE. CARLISLE. PENNSYLVANIA. The plaintiff may proceed without pre-payment of fees .pending a funher order after the hearing, The Cumberland County Sherift's Depanment shall attempt to make service at the plaintift'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 the defendant by mail. The Carlisle Police Department shall be provided with a certified copy of this Order by the plaintiffs attorney, This Order shall be enforced by any law enforcement agency where a violation occurs by arrest for indirect criminal contempt without warrant upon probable cause that this Order has been violated. whether or not the violation is committed in the presence of the police officer. In the event that an arrest is made. under this section, the defendant shall be taken without unnecessary delay before the court that issued the order, When that court is unavailable, the defendant shall be taken before the appropriate district justice, (23 Pa,C.S, ~61 13). By the Court, Is/ idl."":" C JJc.ol.J/ , , Judge Joan Carey LEGAL SERVICES. INC. Attorney for Plaintiff TRUE COpy FROM RECORD In Testimony wl\er8Of, I here unto I8t mv hind and the seal of said Court.at Carlisle. PlI. 'This :J h.:/ day Q' -<k.." 1Q 97 '-t..,. {,' 7'J"tPb.., l~ I ' Prothonotary L ,~~r{.: KATHY LYNN MILLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL VANIA v. NO, 94-239 CIVIL TERM CHARLES EDGAR MILLER, JR.. Defendant PROTECTION FROM ABUSE NOTICE You have been sued in court, If you wish to defend against the claims set forth in the following pages. you must take action promptly after this Petition, Order and Notice are served, by appearing personally or by attorney at the hearing scheduled by the Court and presenting to the Court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so the Court may proceed without you. and a judgment may be entered against you by the Court without further notice for any money claimed in the Petition or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you, FEES AND COSTS If the case goes to hearing and the judge grants a Protection Order. a surcharge of$2S,OO will be assessed against you, You may also be required to pay attorney fees to Legal Services. Inc. for their representation of the plaintiff. You should take this paper to your lawyer at once. 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. COURT ADMINISTRATOR, 4th FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 240-6200 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. "......._~"....:_, KATHY LYNN MILLER, Plaintiff IN nm COURT OF COMMON PLEAS OF CUMBERLAND COUNTY . PENNSYLVANIA v, NO, 94.239 CIVIL TERM CHARLES EDGAR MILLER, JR" Defendant PROTECTION FROM ABUSE PETITION FOR PROTECTION ORDER RELIEF UNDER TilE PROTECTION FROM ABUSE ACT. 23 Pa.C.S. g6101 et scq. A. ABUSE L The plaintiff. Kathy Lynn Miller. is an adult individual residing at 141 East Louther Street, 1st Floor. Carlisle. Cumberland County. Pennsylvania 17013, 2, The defendant. Charles Edgar Miller. Jr, (SSN: 197-54-3340)(008: 11/13/62), is an adult individual residing at 124 Ann Street. 1st Floor. Middletown. Dauphin County. Pennsylvania 17057-1310, 3, The defendant is the husband orthe plaintiff and the father of the parties' children, 4, Since approximately March 1997. the derendant has attempted to cause and has intentionally. knowingly. or recklessly caused bodily injury to the plaintiff. has placed her in reasonable fear of imminent serious bodily injury. has knowingly engaged in a course of conduct or repeatedly committed acts toward the pluintiff including following the plaintiff without proper authorization, under circumstunees which huve pluced the plaintiff in reasonable fear of bodily injury, This has included. but is not limited 10. the following specific instances of abuse: a) On or ubout September 16. 1997. the defendant telephoned the plaintiffs home upproximutely 15 times lellving messages on her answering machine, b) On or ubout September 6. 1997. the derendant telephoned tbe plaintiff. threatened to cut up her und her friend. und threatened to beat them both ifhe saw . , the plaintiffs mend coming out of her house. The defendant carries a switchblade knife with him, The plaintiff fears for her safety. c) On or about September I, 1997, the defendant screamed in the plaintiffs face. pointed his finger in her face. threatened her saying that she and her mend had an "ass whipping" coming to them, and shoved the plaintiff backward against a counter, When the plaintiff took the children out to the car. the defendant followed them. and in front of the children. harassed her about any sexual relationship she might have with her friend repeatedly and badgered her about having sex with him. When the plaintiff told the defendant that their relationship was over, he slapped her on the side of her face and head, called her obscenities. followed her around to the driver's side door. spat in her face as she got into the car, called her a whore, and pounded on the driver's side window as she backed the car away, The plaintiff feared for her safety and that of her children, The defendant telephoned the plaintiffs home and left a message on her answering machine asking that she call him back. When she called him back, the defendant screamed at her and threatened to make her life miserable. He further threatened to cut her and her friend up and threatened to give her friend an "ass whipping". The defendant also told the plaintiff that he was going to sit in front of her house in a car and watch her activities. d) In or about late August 1997, the defendant telephoned the plaintiffs home and when the answering machine came on he screamed that if someone hangs up the phone again he was going to shove the goddamned phone up their ass, The defendant telephoned several more times. screamed that the plaintiff was an ignorant bitch, that he was going to stay on the line, and he demanded that she pick up the telephone because he WliS coming to the house to see the kids. The plainliffs leen-aged nephew. who was babysiuing her children, was afraid to answer the lelephone when the defendant called and was scared to remain in the house. The plaintiO's sister came nndgot her son and the plaintiffs children and took them to her home for safely. e) In or IIbout March 1997, the defendant screamed at the plaintilTin front of their children and threntened thnt he would beat her and anyone she might be seeing. The plnintiO'took the children nnd returned to her home, t) The plninlilT tiled n Temporary Protection Order and Petition for I'roteclion From Abuse nnd Custody agninst the defendant on January 19. 1994 (see aunehed Exhibit A. incorpornted nnd mnde a part hereto). S. The plainlilT believes nnd therefore nvers thnt she is in immediate and present dnnger of abuse from the defendant and that she is in need of protection from such abuse. 6. The plnintiO' desires thnt the defendant be prohibited from having any direct or indirecl contnet with the plainliO' including. but not limited to, telephone and written cOlllmunientions. except lor the limited purpose of faeilitnting custody arrangements. 7. The plaintilT desires thai the defendant be enjoined from hnrassing and stalking the plaintilT. IInd from harassing her relatives, nndthe minor children. 8. The plaintilT desires that the defendant be restrained from entering her place of employment. or the day care facility of the minor children. 9. The plninlilT desires lhat the defendant be enjoined from removing, damaging, destroying or selling any property owned by the plaintiff. 10. The plaintilf desires that any weapons the defendant owns or possesses (switchblade knife) be conliscated by the Sherill's Department and that the defendant be prohibited from acquiring or possessing any weapons for the duration of the Temporary I'rolection Order. B. EXCLUSIVE POSSESSION II. The residence from which the plaintiff is asking the Court to order the defendant to stay away from is rented in the name of the plaintiff and the defendant has never resided there, C. REIMBURSEMENT FOR COST OF CASE 12. Ordering the defendant to pay $250.00 to Cumberland County, one of Legal Services. Inc.'s funding sources, in lieu of attorneys' fees. as reimbursement for the cost of litigating this case and assessing the $25,00 surcharge and court costs to the defendant if the case goes to hearing, WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of October 7. 1976, 23 P.S, ~6101 ~ mi., as amended, the plaintiff prays this Honorable Court to grant the following relief: A, Grant a Temporary Order pursuant to the "Protection from Abuse Act" I, Ordering the defendant to refrain from abusing the plaintiff or from placing her in fear of abuse. 2. Ordering the defendant to refrain from having any direct or indirect contact with the plaintiff including. but not limited to. telephone and written communications, except for the limited purpose of facilitating custody arrangements, 3, Ordering the defendant to refrain from harassing and stalking the plaintiff and from harassing her relatives and the minor children, 4, Prohibiting the defendant from entering the plaintiffs place of employment and the day care facility of the minor children. 5. Prohibiting the defendant from removing, damaging, destroying or selling property owned by the plaintiff. . I .. 6, Ordering the defendant to stay away from the plaintiffs residence located at 141 East Louther Street, 1st Floor. Carlisle, Cumberland County, Pennsylvania, and ordering the defendant to stay away from any residence the plaintiff may in the future establish for herself, 7, Ordering the defendant to relinquish to the sheriffs department any weapons which he owns or possesses (a switchblade knife). and prohibiting the defendant from acquiring or possessing any other weapons for the duration of the Temporary Protection Order. B. Schedule a hearing in accordance with the provisions of the "Protection from Abuse Act." and, after such hearing, enter an order to be in effect for a period of one year: I, Ordering the defendant to refrain from abusing the plaintiff or from placing her in fear of abuse, 2, Ordering the defendant to refrain from having any direct or indirect contact with the plaintiff including, but not limited to. telephone and written communications, except for the limited purpose of facilitating custody arrangements. 3, Ordering the defendant to refrain from harassing and stalking the plaintiff and from harassing her relatives and the minor children, 4, Prohibiting the defendant from entering the plaintiffs place of employment and the day care facility of the minor children, 5, Prohibiting the defendant from removing, damaging, destroying or selling property owned by the plaintiff, 6. Ordering the defendant to stay away from the plaintiffs residence located at 141 East Louther Street. 1st Floor, Carlisle. Cumberland , , County. Pennsylvania. and ordering the defendant to stay away from any residence the plaintiff may in the future establish for herself, 7, Ordering the defendant to relinquish to the sherift's department any weapons which he owns or possesses (a switnchblade knife), and prohibiting the defendant from acquiring or possessing any other weapons for the duration of the Protection Order. 8, Ordering the defendant to pay $250,00 to Cumberland County, one of Legal Services, Inc,'s funding sources. in lieu of attorneys' fees, as reimbursement for the cost of litigating this case and assessing the $25,00 surcharge and court costs to the defendant if the case goes to hearing, The plaintiff further asks that this Petition be filed and served without payment offees and costs by the plaintiff, pending a further order at the hearing, and that a certified copy of this Petition and Order be delivered to the Carlisle Police Department which has jurisdiction to enforce this Order, The plaintiff prays for such other relief as may be just and proper, Respectfully submitted, : ,"-'1..' ~'-~LV v oan Carey, Attorney fir Plaintiff 0/ LEGAL SERVICES. INC. 8 Irvine Row Carlisle. PA 17013 (717) 243-9400 '. , . . , , The above-named plaintiff. Kathy Lynn Miller, verifies that the statements made in the above Petition are true and correct, The plaintiff understands that false statements herein are made subject to the penalties of 18 Pa,C,S, ~4904 relating to unsworn falsification to authorities, Date: (.\ \ ~. C\ \ h(~\,,-\ ~~\H\ l..\\~~l\.L'l Kathy Lynn Mill r, Plaintiff .. I~" ~;T . . . . JAN 1 J _ '-I lath1 L. Miller, Plaintiff . . IN THE OOUBT OF COMMON PLEAS OF . . CUMBllBLAND OOUNTY', PENNSYLVANIA Y. . CIVIL ACTION - LAW . . . : NO. J 3 CJ CIVIL 1994 . PROTECTION FROM ABUSE . . AND CUSTODY . Charles E. Miller, Jr., Defendant AND NOW, this T?Y PROTECTIVE ORDER / q 7 day of January 1994, upon presentation and consideration of the within Petition, and upon finding that the plaintiff, now residing at 112 Lawrence Lane, Carlisle, Cumberland County, Pennsylvania, is in immediate and present danger of abuse from the defendant, Charles E. Miller, Jr., the following Temporary Order is entered. The detendant, Charles E. Miller, Jr., now residing at 752 State Street, Lemoyne, Cumberland County, Pennsylvania, is hereby enjoined from physically abusing the plaintiff, Kathy L. Miller, or placing her in fear of abuse and ordered to stay away from the residence located at 112 Lawrence Lane, Carlisle, Cumberland County, Pennsylvania, a residence which is not owned or leased by the defendant.r-The defendant is hereby notified that if he resides in the plaintiff's domicile contrary to this Order, he may be in indirect criminal contempt which is punishable by a fine not to exceed $1,000.00 and/or by a sentence of up to six months in jail and any other appropriate punishment. Resumption of co-residence on the part of the plaintiff and the defendant shall not nullify the provisions of the court order directing the defendant to refrain from abusing the Plaintit~ Temporary custody of Joseph Michael Miller is hereby awarded to the plaintiff, Kathy L. Miller. The defendant is ordered to retrain from having any contact with the plaintiff except facilitating cust~~lt\Ell~~ minor child. " , . , . .. The defendant is ordered to retrain from entering the plaintiff's place of employment, from stalking the plaintiff, or fro. harassing the plaintiff or the her relatives. The defendant is ordered to refrain from daaaging or destroying any property owned by the plaintiff or jointly owned by the parties. This Order shall remain in effect until a final order is entered in this case. A hearing shall be held on this matter on the d }~ay of January, 1994, at I: j () 1/... in Courtroom No.~, Cumberland County I Courthouse, Carlisle, Pennsylvania. The plaintiff may proceed in !2tmA nauneris pending a further order after the hearing. The Cumberland County Sheriff's office shall attempt to make service at the plaintiff'S request, but service may be accomplished under any applicable rule of Civil Procedure. The Pennsylvania State Police Department will be provided with a copy of this Order by attorneys for plaintiff. This Order shall be enforced by any law enforcement agency when a violation occurs by arrest for indirect criminal contempt. The arrest may be without warrant upon probable cause that this Order haa been violated, whether or not the violation is committed in the presence of the police officer. In the event that an arrest is made under this section, the defendant shall be taken without unnecessary delay before the court that issued the Order. When that court is unavailable, the defendant shall be arraigned before the appropriate district justice. (23 Pa.C.S.A. Section 6113). __, ~- ........ ':-" ,'~'"'.I''' :!. ~t:~~'='D ft:,:..; ....,.~..,!'. .' :..l/.:l .~L-l,o.,'''....$l 'i1'-')~ .,..".' ......... . '., ..,...,.... ....:rr'in~:ld !l ..~.~. . t: .... . '_..:';~ ~":'.';"~._'I,"'" ''',.' ... ,,;'.\ ~.r~ ..':":'~ '.~ .'. '" -. _. ~ 1:"~ ,~/.S-r._.j~'" ~_, l::l.' ~ . ;tlJ \;I""'il"-''''':'/ , ..~l ...HI..... By the Court, /5/~^r~~ ~ J. ; , i i i I ~ Dated: October 14, 1997 Vl?v . cAlr GINNY~Y c- ~ . KATHY LYNN MILLER, Plain tilT :IN THE COURT OF COMMON PLEAS 0Jt' . . :CUMBERLAND COUNTY, PENNSYLVANIA v. . :NO. 94-239 CIVIL TERM CHARLES EDGAR MILLER, JR., Defendant . :PROTECTION FROM ABUSE CERTIFICATE OF SERVICE I, Ginny Massey, hereby certify that a true and correct copy of a Temporary Protection Order and Supplemental Petition for Protection Order and Request for Hearing, in the above captioned matter, was duly served upon counsel for the Defendant, Charles E, Miller, by depositing it in the U.S. Mail, regular delivery, on October 14, 1997, addressed as follows: I Mark Locke Family Law Clinic 45 North Pitt Street Carlisle, PA 17013 j I I hereby verify that the statements made in the foregoing are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. 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MILLER 141 EAST LOOTHER STREET 1ST FLOOR CARLISLE, PA 17013 July 15, 1997 ~ pmnOND'S I ~'M Samuel Milkes Jacobsen & Milkes 52 East High Street Carlisle, PA 17013 Dear Sam: I have reviewed the letter in regards to custody. I would first like to say that I think it is very important for the children to see there father. But it is more important that they see him on a regular bases. I would like the visit to continue the way they are for Joe which is every other week end starting on Friday at 5:00pm and ending on Sunday at 7:00pm instead of 5:00pm. As far as a week or two in the summer, that is fine with me, however, Joe has some problem with that he is not sure weather on not he wants to stay with his father for a whole week. In regards to Jennifer, I think it would be in her best interest not to have overnight visit as of yet. She is having a difficult time being left with her father, she becomes very distraught when I go to leave and Chuck does not know how to comfort her instead becomes very angry with her for crying. Jennifer is at a very tender age and she does not know how to deal with her fathers anger. The place where Chuck is living is not very safe and or clean. I think for now it is Jennifer's best interest to continue the visits the way they are for another six months, then if everything is going well increase the visits to all day Sunday 8:00am to 7:00pm for six months and then try one overnight a weekend Saturday 8:00am to Sunday 7:00pm. I would also like to include a Holiday schedule that states every other Holiday 8:00am to 7:00pm and on Chuck's Holiday he would need to make arrangements to pick up the children and I will pick them up at the end of the visit. Should you have any questions, please feel free to contact me at 245-5771 Monday thru Friday 8:00am to 4:30pm. v"Mr~~Y9~mL Q ~_ t \ ~thy L. Miller ~upr.em.e <1louri of '.enns~lhctnict 2B1li{){)12 ~i5fricl JOAN L. STEHULAK. ESQUIRE DIPUTY 'RDTHONOt.RY SHIRLEV BAILEY CHII' CLERK .~. MAIN CA'ITOL IUILDINO '.0. ao. ea4 H,,"'tlSIUND. "ENNIVLYANIA 1'Ioe 17171 ,.,.e,., May 20, 1997 REOISTRA~ION UNDBR RULES 321 , 322 (PBNNSYLVANIA BAR ADMISSION RULES) OF ELIGIBLE LAW STUDENT Mark C. Locke 102 S. West St., Apt. 3 Carlisle, PA 17013 TO TIlE APPROVED SUPBRVISING A'l'TORNEYI Robert Rains, Katherine Person, Thomas Place & Gail Shearer, Esq. Family Law Clinic The Dickinson School of Law 45 N. Pitt St. Carlisle, PA 17013 The above-named law student has been approved and certified under Pa. B.A.R. 321 & 322 bYI Harvey A. Feldman, Esq.,. Associate Dean 150 South College st. Carlisle, PA 17013-2899 I \ as a duly enrolled law student who has completed at least four (4) semesters of legal studies, or the equivalent thereof, is of good character, has been adequately trained and is of competent legal ability to perform as a legal intern as of OS/20/97. Pursuant to such certification and. in accordance with and subje't to the provisions of Fa. B.A.R. 321 & 322, the above student has been registered and you have been approved to perform the duties of supervlqing attorney. WITNESS my aigDature aDd the aeal of thia COurt, May 20, 1997. /js .:---. Jt-. /-. Date IL - 0-. I-t /'7 I t ,.... ) -... .,.1 ',Lr... Charles E; V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 6289 - CIVIL - 1994 Civil Action- Custody CHARLES E. MILLER, Plaintiff KATHY L. MILLER, Defendant No. 239 - CIVIL - 1994 Protection From Abuse CONSENT AND APPROVAL POR APPEARANCE UNDER Pa.B.A.R. 322 I hereby consent to the appearance of Mark Locke, a Certified Legal Intern under the supervision of an attorney, in the above-entitled Custody and Protection From Abuse proceeding before the Honorable Kevin Hess at 10:30 a.m. on Monday, October 27, 1997. As the supervising attorney for Mark Locke, certified under Pa.B.A.R. 322, I approve of his appearance on behalf of the above-named client in the above-named proceeding. Date 10 I) 7 / 't 7 I , .5aLfi~~ C.Ga-Vf.-- THOMAS M. PLACE ROBERT E. RAINS KATHERINE C. PEARSON Supervising Attorney DONALD MARRITZ Staff Attorney FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/243.2968 . MAY 03 1994 JA- KATHY L. MILLER, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v . . :NO. 239 - CIVIL - 1994 . . CHARLES E. MILLER, Defendant . . :CIVIL ACTION - CUSTODY COURT ORDBR AND NOW, this <(" day of r>?a., , 1994, the parties having appeared before the Custody Conciliator, the following Order is entered in accordance with the attached Custody Conciliation Report: 1. The Mother, Kathy L. Miller, and the Father, Charles E. Miller, shall share legal custody of Joseph M. Miller, born October 19, 1991. 2. The Mother shall have primary physical custody of the minor child. 3. The Father shall have temporary physical custody of the minor child on one day a week being Saturday or Sunday starting at 10 A.M. and going until 7 P.M. This period of temporary custody shall be exercised at Father's sister's home or in the presence of Father's sister. Unless agreed otherwise by the parties, the parties shall alternate this temporary custody between Saturday and Sunday, with it commencing such that Father has custody of the minor child on April 16 and the following weekend his custody shall be Sunday with the arrangement alternating thereafter. 4. Mother shall handle transportation for exchange of custody. 5. The parties will convene again for a conference before the Conciliator on Thursday, June 23, 1994, at 8:30 A.M. at the Cumberland County Courthouse, 4th floor Conference Room. BY THE COURT, co: .^/~~~) 11 Jud~~ Kevin A. Hess Joan Carey, Esquire - ('<of,o'fJJ:...',,(~"" .~.l. "... ' Patrick Quinn, Student Attorney , -t 1'04 .\,.. T t..",\ ~,t_\..,~ ,5'/-1/-''1-. ? ~6, l.~ r If J:.l ,..I ~. I J"" , "J1 KATHY L. MILLER, Plaintiff :IN THE COURT OF COMMON PLEAS OF :CUMBERLAND COUNTY, PENNSYLVANIA v . . :NO. 239 - CIVIL - 1994 . . CHARLES E. MILLER, Defendant . . :CIVIL ACTION - CUSTODY PRIOR JUDGE: KEVIN A. HESS CONCILIATION CONFERENCE SUHHARY REPORT IN ACCORDANCE WITH CUMBERLAND COUNTY RULE OF CIVIL PROCEDURE 1915.3-8(b), the undersigned Custody Conciliator submits the following report: 1. The pertinent information pertaining to the child who is the subject of this litigation is as follows: Joseph Michael Miller, born October 19, 1991. 2. A Conciliation Conference was held on April 14, 1994, with the following individuals in attendance: The Mother, Kathy L. Miller, with her counsel, Joan Carey, Esquire, and the Father, Charles E. Miller, with his counsel from the Family Law Clinic, Patrick Quinn, Student Attorney. 3. The parties agreed to the entry of an Order in the form as attached. '1./J i ( 4 I( DATE Hubert X. Gilroy, Esq Custody Conciliator KathY L. Miller Plaintiff IN THE COURT OF COIlION PLEAS OF ClJ4BERLAHD COUNTY. PENNSYLVANIA No. 23V of 1994 Civil Term vs. Protection From Abuse & Custodv Charles E. Miller Defendant PRAECIPE TO WITHDRAW ACTION On January 19. 1994. the Dla1ntiff filed a Petition for a TemDOrarv Protect1ve Order. and an Order was entered on that date. On January 27. 1994. the Darties siRned a Consent ARreement and a Protective and TemDOrary CustodY Order was entered. On May 4. 1994. a CustodY Order was entered based on the Darties consent. At this time. the Dlaintiff reauests that the Orders be vacated and that no further leRal action be Dursued bY counsel. To Lawrence E. Welker Prothonotary 19~ ;~'n~.. JOyr Carey, Attorney fo ., . ' No. 239 Tenn. 19 94 ;" KathY L. Miller . Plaintiff Ys. Charles E. Miller . Defendant PRAECIPE Joan Carey 19 94 . Atty. Fl1ed LEGAL SERVICES. INC. = ... .... '" "'1 r-..> .~t .' ,.:... . '- ""-" ;-::.; l~r.'::;)_ :'-,..':;,~~ ~.-., -\ ~ -<~ W Nt -", ::J:: - c.o ...c.. . ",,',' Kathy L. Miller, Plaintiff : IN THE COURT OF COMMON PLEAS OF . . : CUMBERLAND COUNTY, PENNSYLVANIA . . . . CIVIL ACTION - LAW NO. d<31 CIVIL 1994 PROTECTION FROM ABUSE AND CUSTODY v. Charles E. Miller, Jr., Defendant . . . . TEMPORARY PROTECTIVE ORDER AND NOW, this /'7" day of January 1994, upon presentation snd consideration of the within Petition, and upon finding that the plaintiff, now residing at 112 Lawrence Lane, Carlisle, Cumberland County, Pennsylvania, is in immediate and present danger of abuse frOB the defendant, Charles E. Miller, Jr., the following Temporary Order is entered. The defendant, Charles E. Miller, Jr., now residing at 752 State Street, Lemoyne, Cumberland County, Pennsylvania, is hereby enjoined from physically abusing the plaintiff, Kathy L. Miller, or placing her in fear of abuse and ordered to stay away from the residence located at 112 Lawrence Lane, Carlisle, Cumberland County, Pennsylvania, a residence which is not owned or leased by the defendant. The defendant is hereby notified that if he resides in the plaintiff's domicile contrary to this Order, he may be in indirect criminal contempt which is punishable by a fine not to exceed $1,000.00 and/or by a sentence of up to six months in jail and any other appropriate punishment. Resumption of co-residence on the part of the plaintiff and the defendant shall not nullify the provisions of the court order directing the defendant to refrain from ~busing the plaintiff. "'\,. .... Temporary custod1'of'Jo~eph MLehael Miller . ' is hereby awarded to the " plaintiff, Kathy L. ~~l~~. 'b. H. ef nl ,~ The defendant is orderea to-~~ain from having any contact with the plaintiff except facilitating custody of their minor child. , \, " hK 2\ \0 11 ~M '91\ , r,'" " ~ . Ie:.. l',~' . ! I;' ; 'i'.i C ,,'r '.,.,;, .'. . " The defendant is ordered to refrain from entering the plaintiff's place of employment, from stalking the plaintiff, or fro. harassing the plaintiff or the her relatives. The defendant is ordered to refrain froa damaging or destroying any property owned by the plaintiff or jointly owned by the parties. This Order shall remain in effect until a final order is entered in this 'J rIll, A hearing shall be held on this matter on the --'\ I day of January, case. 1994, at ;; 3,\ , I , ' .11. in Courtroom No.-L, Cumberland County , Courthouse, Carlisle, Pennsylvania. The plaintiff may proceed in f2rmA oauoeris pending a further order after the hearing. The Cumberland County Sheriff's office shall attellpt to lIake service at the plaintiff's request, but service may be accomplished under any applicable rule of Civil Procedure. The Pennsylvania State Police Department will be provided with a copy of this Order by attorneys for plaintiff. This Order shall be enforced by any law enforcement agency when a violation occurs by arrest for indirect crillinal contempt. The arrest may be without warrant upon probable cause that this Order has been violated, whether or not the violation is comaitted in the presence of the police officer. In the event that an arrest is made under this section, the defendant shall be taken without unnecessary delay before the court that issued the Order. When that court is unavailable, the defendant shall be arraigned before the appropriate district justice. (23 Pa.C.S.A. Section 6113). By the Court, /l;L J. Kathy L. Miller, : IN THE COURT OF COMMON PLEAS OF Plaintiff . . . CUMBERLAND COUNTY, PENNSYLVANIA . . . CIVIL ACTION - LAW : v. NO. CIVIL 1994 . . Charles B. Miller, Jr., . PROTECTION FROM ABUSE . Defendant AND CUSTODY NOTICB You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action promptly after this Petition, Order and Notice are served, by appearing personally or by attorney at the hearing scheduled by the Court and presenting to the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the Court may proceed without you, and a judgment may be entered against you by the Court without further notice for any .oney claimed in the Petition or for any other claim or relief requested by the plaintiff. You may lose .oney or property or other rights i.portant to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCB. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BBLOW TO FIND OUT WHERE YOU CAN GET LBGAL HBLP. COURT ADMINISTRATOR, 4TH FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLB, PENNSYLVANIA 17013 TBLBPHONE NUMBER: (717) 240-6200 Kathy L. Miller, Plaintiff : IN TIlE COURT OF COMMON PLEAS OF . . CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW v. : NO. CIVIL 1994 . . Charles B. Miller, Jr., Defendant : PROTECTION FROM ABUSE : AND CUSTODY PETITION FOR PROTIlCTIVIl ORDER AND CUSTOIlY RELIEF UNDER THE PROTECTION FROM ABUSE ACT. 23 Pa. C.S.A. Section 6101 et. sea. A. ABUSB 1. The plaintiff is an adult individual whose per.anent address was 752 State Street, Lemoyne, Cumberland County, Pennsylvania, 17043. 2. The plaintiff is temporarily staying at 112 Lawrence Lane, Carlisle, Pennsylvania, for her own protection and to avoid further abuse as is more fully set forth herein. 3. The defendant is an adult individual residing at 752 State Street, Lemoyne, Cumberiand County, Pennsylvania, 17043. 4. The defendant is the plaintiff's husband. 5. Since approximately April 1992, the defendant has attempted to cause and has intentionally, knowingly, or recklessly caused bodily injury to the plaintiff and by physical menace has placed the plaintiff in fear of imminent serious bodily injury. This has included but is not limited to the following specific instances of abuse: a. On or about January 4, 1994, the defendant became angry, punched walls, slammed a door, nnd screamed causing the plaintiff to fear for her safety. The defendant slapped the plaintiff forcefully across the face and told the plaintiff that there had been many times while she was sleeping that he thought about slitting her throat. b. In or about September 1993, the defendant became angry, threw a clock with a glass front on it, and broke the glass. When the plsintiff bent over to clean the meas up, the defendant caae up behind her, grabbed her around the throat, and choked her. The plaintiff struggled and got free of the defendant's grip. c. Since approximately April 1992, the defendant has on several different occasions pushed, slapped, and choked the plaintiff. The defendant has also threatened the plaintiff with statements including the following: that he wished he would have hit her harder, that he should have knocked her out so she'd be lying on the floor, and that he should have knocked her teeth down her throat. 6. On or about January II, 1994, the plaintiff and her child left their residence at 752 State Street, Lemoyne, Cumberland County, Pennsylvania in order to avoid further abuse. 7. The plaintiff believes and therefore avers that she will be in im.ediate and present danger of abuse from the defendant and that she is in need of protection from such abuse. 8. The plaintiff desires that the defendant be ordered to refrain from having any contact with her except to facilitate custody of their minor child. 9. The plaintiff desires that the defendant be ordered to refrain from entering her place of employment, from stalking the plaintiff, and from harassing the plaintiff or her relatives. 10. The plaintiff desires that the defendant be ordered to refrain from destroying or damaging her property or any property jointly owned by the parties. B. TEMPORARY CUSTODY 11. The plaintiff seeks temporary custody of the following child: ~ Present Residence AM Joseph Michael Miller 112 Lawrence Lane Carlisle, PA 2 yrs. old DOB 10/19/91 The child was not born out of wedlock. The child is presently in the custody of ths plaintiff, Kathy L. Miller, who is temporarIly residing at 112 Lawrence Lane, Carlisle, Pennsylvania. During the child's lifetime, the child has resided with the following persons and at the following addresses: ~ Addresses 12m!! Plaintiff, defendant 752 State St. 10/19/91 to Lelloyne, PA 1/11/94 Plaintiff, Jeanne 112 Lawrence Lane 1111/94 to Schwartz (plaintiff's Carlisle, PA present 1I0ther), Nancy Nixon (friend) The 1I0ther of the child is the plaintiff, Kathy L. Miller, currently residing at 112 Lawrence Lane, Carlisle, Pennsylvania. The plaintiff currently resides with the following persons: ~ Relatlonshio Joseph Michael Miller Jeanne Schwartz Nancy Nixon She is married. Son Mother Friend The father of the child is the defendant, Charles E. Miller, Jr., currently residing alone at 752 State Street, Lelloyne, Pennsylvania. He is lIarried. 12. The plaintiff has not previously participated in any litigation concerning custody of the above mentioned child in this or any other Court. 13. The plaintiff has no knowledge of any custody proceedings concerning this child pending before a court in this or any other jurisdiction. 14. The plaintifC does not know oC any person not a party to this action who has physical custody oC the child or claims to have custody or visitation rights with respect to the child. 15. The best interests and permanent welCare oC the child will be met if custody is temporariiy granted to the plaintiff pending a hearing in this matter for reasons including the Collowing: a. The plaintiCC is a Cit parent who can best take care oC her child. b. The deCendant has shown by his abuse oC the plaintiCC that he is not an appropriate role model Cor the child. C. EXCLUSIVE POSSESSION 16. The home which the plaintifC is asking the Court to order the defendant to stay away from is owned in the name oC Jeanne Schwartz. 17. The deCendant is living at his own residence located at 752 State Street, Lemoyne, Pennsylvania. D. STATUS TO PROCEED IN FORMA PAUPKIlIS 18. The deCendant is unemployed. 19. The plaintifC is employed at Boring Soil and Testing Company and has a gross weekly salary oC approximately $300.00. 20. The plaintifC does not have funds available to pay the Cees for Ciling and service. WHEREFORE, pursuant to the provisions oC the "Protection from Abuse Act" oC October 7, 1976, 23 Pa.C.S.A. Section 6101 et sea., as amended, the plaintiff prays this 1I0norable Court to grant the following relieC: A. Grant a Temporary Order pursuant to thr "Protection Crom Abuse Act": 1. Requiring the deCendant to reCrain Crom abusing the plaintiCf or placing hrr in Cear oC abuse. 2. Requiring the deCendant to reCrain Crom having any contact with the plaintiCC except to Cacilitate custody oC their minor child. 3. Requiring the deCendant to reCrain Crom entering the plaintifC's place oC employment, from stalking the plaintiCf, and Crom harassing the plaintiCC or her relatives. 4. Granting temporary custody of the minor child to the plaintifC. 5. Ordering the deCendant to stay away Crom the residence located at 112 Lawrence Lane, Carlisle, Pennsylvania. 6. Ordering the deCendant to stay away Crom any residence the plaintiCC may in the Cuture esta~lish Cor herselC. 7. Ordering the deCendant to reCrain Crom damaging or destroying any property owned solely by the plaintiCC or any property owned jointly by the parties. B. Schedule a hearing in accordance with the provisions oC the "Protection Crom Abuse Act," and, after such hearing, enter an order to be in efCect Cor a period oC one year: 1. Requiring the deCendant to reCrain Crom abusing the plaintiCC or placing her in Cear oC abuse. 2. Requiring the deCendant to reCrain Crom having any contact with the plaintiCC except to Cacilitate custody oC their minor child. 3. Requiring the deCendant to reCrain Crom entering the plaintiCC's place oC employment, Crom stalking the plaintiCC, and Crom harassing the plaintiCC or her relatives. 4. Ordering the deCendant to stay away Crom the residence located at 112 Lawrence Lane, Carlisle, Pennsylvania. 5. Ordering the defendant to stay away from any residence the plaintiff may in the future establish for herself. 6. Ordering the defendant to refrain from damaging or destroying any property owned solely by the plaintiff or any property owned jointly by the parties. The plaintiff further asks that this Petition be filed and served without payment of costs, pending a further order at the hearing, and that a copy of this Petition and Order be delivered to the Pennsylvania Police Department ~s the Police Department with jurisdiction to enforce this Order. The plaintiff prays for such other relief as may be just and proper. COUNT II CUSTODY UNDER PENNSYLVANIA CUSTODY LAW 21. The allegations of Count I above are incorporated herein as if fully set forth. 22. The best interests and permanent welfare of the child will be served by awarding custody to the plaintiff as set forth in Paragraph 15 of the Petition. WHEREFORE, pursuant to 23 P.S. gg 5301-5366, and other applicable rules and law, the plaintiff prays this Honorable Court to award custody of the minor child to her. The plaintiff prays for such other relief as may be just and proper. Respectfully submitted, (J '; \;'1__ ,.'.'. . Ie" /. /' ,,:: ,,_ )~" \..::-,c',. . Joan Carey II Attorney for Plaintiff LEGAL SERVICES, INC. a Irvine Row Carlisle, PA 17013 (717) 243-9400 . The above-named plaintiff, Kathy L. Miller, verifies that the state.ents made in the above Petition are true and correct. The plaintiff understands that false state.ents herein are made subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorities. Date: /-/{/oc) K(d-17l/ y L171~ L L~A Kathy L. Miller, Plaintiff 0 '<:;) ~ (J) en ,0. " IV) ...J.... :r: 'i=t -::: <- :~ 'I.) f. . . @) ,n , LI #:'::) "-5' '" ~ ;r. ., -, .~'< '.'-- ;}~.::1'" . .. ... .......'..............'..;;.. -"" ..... ...-..".. ....~. ....,... ..... . , SHERIFF'S RETURN CO>1MONWEAL'Ili OF PENNSYLVANIA: COUNTY OF CLMBERLAND In The Court of Common Pleas of Cumberland County, Pennsylvania No. 239 Civil Term 1994 Temporary Protective Order Protection From Abuse and Custody Notice and Petition for Protection From Abuse Ka thy L. Miller VS Charles E. Miller, Jr. Harrv Kinq , soex~~XDeputy Sheriff of Cumberland County, Pennsylvania, who being duly swom according to law, says, that he served the within Temporary Protective Order Protection From Abuse and Custody Notice & Petition for Protection upon Charles E. Miller, Jr. , the defendant, at 2:25 o'clocJt'rom Abuse p.M. EST / ~~, on the 21 day of January , 19~at 1710 Market St.. Apt. 18, Camp Hill . Cumberland County, Pennsylvania, by handing to Charles E. Miller, Jr. a true and attested copy of the Tern orar Protective Order Protection Frqm Abuse and Custody Notice & Petition for Protect on From A use and at the SBire time directing his attention to the contents thereof and the "Notice to Plead" endorsed thereon. Sheriff's Costs: Docketing Service Affidavit Surcharge 14.00 8.40 2.00 24.40 So answers: ......../~/? ~'/4 ...-:;"" (J;'/' .. ~"'!. 1~ #~'>''',,,,~.o..:..... ~ R. 'I'hanas Kline. Sher:iff ,/ '/ --;.:;~.,-.. ~ ~~--. / Depu t Y , She ' \, . by Swom and subscribed to before rre this n 1: day of lp..~, , I 19 9'1 A.D. C; 'f" C. )l~<-<-- , '*~ . Prothonotary KATHY L. MILLER Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PROTECTION FROM ABUSE/CUSTODY v. CHARLES E. MILLER, Defendant NO. 239 OF 1994 ORDER RE: CUSTODY AND NOW, this ).7 r~ day of. It Ie (( II I,Y_' 1994, upon consideration of the attached Consent Agreement, it is hereby directed that the parties and their respective counsel appear . 'I~I b,lt>. (/>.,1"""",,_ before, ~....b("'rt-l.{~~ th~ conciliator, at L/1h-flGZ/f (..,.. ,on the:;2S'1:!ay of rrbrf.AelfY , 1994, at &'tf.nm., for a Pre-Hearing Custody Conference. At such conference, an effort will be made to resolve the issues in dispute; or if this cannot be accomplished, to define and nanow the issues to be heard by the court, and to enter into a temporary order. All children age five or older may also be present at the conference. Failure to appear at the conference may provide grounds for entry of a temporary or permanent order. Pending further order of court, the following temporary order with regard to custody of the parties' child, Joseph Michael Miller shall be in effect: 1. The parties shall have shared legal custody. 2. Plaintiff shall have primary physical custody. 3. Defendant shall have supervised visitation at the YWCA, Carlisle. Transportation of Joseph to and from the supervised visitation shall be provided by the plaintiff. '">>'1 THE COURT, r. YOU SHOULD TAKE THIS PAP9R TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA VB A LAWYER OR CANNO)' AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO F4ND OUT WHERE YOU CAN GET LEGAL HELP. OFFICE OF THE COURT ADMINISTRATOR COURTHOUSE, 4th Floor CARLISLE, PA 17013 7171240-6200 ,:j'IIC€ Of ~..~ ", i:'in.~'T.\II~ Cl;l.OJtf;I,"t:l (.':;;'1" 'I;'~' c', ',..' 1/"\' ...,1il'''''{',1. JAH Z7 I ~z PH '9~ KATHY L. MILLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY , PENNSYLVANIA CIVIL ACTION-LAW PROTECTION FROM ABUSE/CUSTODY V. CHARLES B. MILLER, Defendant NO. 239 OF 1994 ORDER RE: ABUSE AND NOW, this 2'r day of :fa....,., , 1994, the parties having reached an agreement on a disposition of the abuse count of the Plaintifrs petition, the court does accept their agreement and orders as follows: 1. Defendant shall refrain from abusing the plaintiff or placing her in fear of abuse. 2. Defendant shall refrain from having any contact with the plaintiff except to facilitate visitation of their minor child, Joseph. 3. Defendant shall refrain from entering the plaintifrs place of employment, from stalking the plaintiff and from harassing the plaintiff and her relatives. 4. Defendant shall stay away from the plaintifrs current residence at 112 Lawrence Lane, Carlisle, Cumberland County, Pennsylvania or any residence of the plaintiff may in the future establish for herself. The defendant is hereby notified that if he resides in the plaintifrs domicile contrary to this Order, he may be in indirect criminal contempt which is punishable by a fine not to exceed $1,000.00 and/or by a sentence of up to six months in jail and any other appropriate punishment. Resumption of co-residence on the part of the plaintiff and the defendant shall not nullify the provisions of the court order directing the defendant to refrain from abusing the plaintiff. S. Defendant shall refrain from damaging or destroying any property owned solely by the plaintiff or any property owned jointly by the parties. 6. This Order shall remain in effect for one year. 7. The Police Department of Carlisle will be provided a copy of this Order by attorney for Plaintiff, and directed to enforce the above abuse provisions by arrest for indirect criminal contempt without warrant upon probably cause that this Order has been violated, whether or not the violation is committed in the presence of the police officer. (23 Pa.C.S. 16113). In the event that an arrest is made under this section, the Defendant shall not be taken to jail but shall be taken without unnecessary delay before the court that issued the Order. ,4 d- J. / / .-.:2 l;:- :z: '''"'' -.l ,. 2":~~' . Y, , " '.:;:::;,1., ":: (: ;~~~,1 . ., ....., .~~l.~ ........~ rxl '0 '.... ~ .. ...... -=. KATHY L. MILLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION-LAW PROTECTION FROM ABUSFJCUSTODY V. CHARLES E. MILLER, Defendant NO. 239 OF 1994 CONSENT AGREEMENT AND NOW, this day of , 1994, the parties having reached an agreement on a disposition of this petition, enter into the following settlement to be made an Order of Court. I. Without admitting any of the allegations of the petition, the defendant agrees that he will abide by the following provisions: a. Defendant shall refrain from abusing the plaintiff or placing her in fear of abuse. b. Defendant shall refrain from having any contact with the plaintiff except to facilitate visitation of their minor child. c. Defendant shall refrain from entering the plaintifrs place of employment, from stalking the plaintiff and from harassing the plaintiff and her relatives. d. Defendant shall stay away from the plaintifrs current residence at 112 Lawrence Lane, Carlisle, Cumberland County, Pennsylvania or any residence of the plaintiff may in the future establish for herself. The defendant is hereby notified that if he resides in the plaintifrs domicile contrary to this Order, he may be in indirect criminal contempt which is punishable by a fine not to exceed $1,000.00 and/or by a sentence of up to six months in jail and any other appropriate punishment. Resumption of co-residence on the part of the plaintiff and the defendant shall not nullify the provisions of the court order directing the defendant to refrain from abusing the plaintiff. e. Defendant shall refrain from damaging or destroying any property owned solely by the plaintiff or any property owned jointly by the parties. The Court's order reflecting the provisions of this paragraph shall remain in effect for one year. 2. The Police Department of Carlisle will be provided a copy of the Order reflecting the above terms of this agreement by the attorney for Plaintiff, and is directed to enforce the abuse provisions by arrest for indirect criminal contempt without warrant upon probable cause that this Order has been violated, whether or not the violation is committed in the presence of the police officer. In the event that an arrest is made under this section, the Defendant shall not be taken to jail but shall be taken without unnecessary delay before the court that issued the Order. 3. The parties request this court to order a pre-hearing custody conference regarding their minor child Joseph Michael Miller (d.o.b. 10/19/91). 4. Pending further order of court, the parties agree to the following temporary provisions regarding custody of Joseph: a. The parties shall have shared legal custody. b. Plaintiff shall have primary physical custody. c. Defendant shall have supervised visitation at the YWCA, Carlisle. Transportation of Joseph to and from the supervised visitation shall be provided by the plaintiff. ~~/lt}-I LJ7J<2Lu KATIlY L: MILLER Plaintiff -j/zia. '. (lit e. ~~ ,u CHARLES E. MILLER v Defendant rkI:: UkLj CAREY Attorney for Plaintiff ~J~ NARDUCCI Certified Legal Intern LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 717/243.9400 ~~-:-_~;.~ J THOMAS M. PLACE ROBERT E. RAINS LINDA E. FISHER HARVEY A. FELDMAN Supervising Attorney THE FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 717/240-5204 or 717/243-2968 Counsel for Defendant ~p ...,.\.(1\( I KATHY L. HILLER, Plaintiff v : IN THE COURT OF COMMON PLEAS OF :CUHBERLAND COUNTY, PENNSYLVANIA : :NO. 239 - CIVIL - 1994 . . CHARLES E. HILLER, Defendant . . :CIVIL ACTION - CUSTODY COURT ORDER '"'~ AND NOW, this do I day of A.u..-e:' , 1994, the Conciliator being advised that the pa~ies in this case have reached an agreement, the Conciliator relinquishes jurisdiction. KJ Hubert X. Gilroy, Es ire Custody Conciliator ~ c;, .... = "'-- ".., .':-; ','-4 -, , , - > : ,...... ..u._ KATHY LYNN MILLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA v. NO. 94-239 CIVIL TERM CHARLES EDGAR MILLER, JR" Defendant PROTECTION FROM ABUSE TEMPORARY PROTECTION ORDER AND NOW, this .;.l3v(day of September, 1997, upon presentation and consideration of the within Petition, and upon finding that the plaintiff, Kathy Lynn Miller, now residing at 141 East Louther Street, 1st Floor, Carlisle, Cumberland County, Pennsylvania, is in immediate and present danger of abuse from the defendant, Charles Edgar Miller, Jr., the following Temporary Order is entered. The defendant, Charles Edgar Miller, Jr. (SSN: I 97-54-3340)(DOB: 11/13/62), now residing at 124 Ann Street, 1st Floor, Middletown, Dauphin County, Pennsylvania, is hereby enjoined from physically abusing the plaintiff. Kathy Lynn Miller, or from placing her in fear of abuse. The defendant is ordered to stay away from the plaintil1's residence located at 141 East Louther Street, 1st Floor, Carlisle, Cumberland County, Pennsylvania, a residence which is leased by the plaintiff, and is ordered to stay away from any residence the plaintiff may in the future establish for herself, The defendant shall remain in his vehicle at all times during the transfer of custody. The defendant is ordered to refrain from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications, except for the limited purpose of facilitating custody arrangements. The defendant is enjoined from harassing and stalking the plaintiff and from harassing her relatives, or the parties' minor children, f;~.~{,t:'~!. rILED-CFFICE OF ".J:" Ixr"';c'r'll )T,."Oy " '.. ,. ....1.\.."... '\., ,) 97 Sr.? 23 PI: /: 56 CU'"y., '.'(""!"" 'rl_":.:,;....\:...~'.UU\.,l F';:I\'J'.:3)'L'lAN!;\ I,,~ . . I , I , , I . ! The defendant is enjoined from entering the plaintill's place of employment and the day care facility of the minor children. The defendant is enjoined from removing, damaging, destroying or selling any property owned by the plaintiff. A violation of this Order may subject the defendant to: i) arrest under 23 Pa.C.S. ~6lt3; ii) a private criminal complaint under 23 Pa.C.S. ~6113.1; iii) a charge of indirect criminal contempt under 23 Pa.C.S. ~6114. punishable by imprisonment up to six months and a fine ofSI00.00-51.000.00; and iv) civil contempt under 23 Pa.C.S. ~6114.1. This Order shall remain in effect until modified or terminated by the Court and can be extended beyond its original expiration date ifthe Court finds that the defendant has committed an act of abuse or has engaged in a pattern or practice that indicates risk of harm to the plaintiff. The defendant is ordered to relinquish to the sherirrs department any weapons which he owns or possesses (a switchblade knife). and the defendant is prohibited from acquiring or possessing any weapons for the duration of this Order. A HEARING SHALL BE HELD ON THIS MA TIER ON @t-t ''2 , J') LI AT ,J . {lO .M..IN COURTROOM NO. ---1--. OF THE COUNTY COURTHOUSE. CARLISLE. PENNSYLVANIA. . ;2- . 1997. CUMBERLAND The plaintiff may proceed without pre-payment of fees pending a further order after the hearing. The Cumberland County Sherill's Department shall attempt to make service at the plaintill'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 the defendant by mail. ~-. ." The Carlisle Police Department shall be provided with a certified copy of this Order by the plaintiffs attorney. This Order shall be enforced by any law enforcement agency where a violation .. occurs by arrest for indirect criminal contempt without warrant upon probable cause that this Order has been violated. whether or not the violation is committed in the presence of the police officer. In the event that an arrest is made. under this section. the defendant shall be taken without unnecessary delay before the court that issued the order. When that court is unavailable, the defendant shall be taken before the appropriate district justice. (23 Pa.C.S. ~6113). By the Court, Judge Joan Carey LEGAL SERVICES, INC. Attorney for Plaintiff KATHY LYNN MILLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYL VANIA v. : NO. 94-239 CIVIL TERM CHARLES EDGAR MILLER, JR., Defendant : PROTECTION FROM ABUSE NOTICE You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action promptly after this Petition, Order and Notice are served, by appearing personally or by attorney at the hearing scheduled by the Court and presenting to the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the Court may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Petition or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. FEES AND COSTS If the case goes to hearing and the judge grants a Protection Order, a surcharge of$2S.00 will be assessed against you. You may also be required to pay attorney fees to Legal Services, Inc. for their representation of the plaintiff. You should take this paper to your lawyer at once. 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. COURT ADMINISTRATOR, 4th FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 240-6200 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. CHARLES EDGAR MILLER, JR., Defendant : PROTECTION FROM ABUSE KATHY LYNN MILLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA v. : NO, 94-239 CIVIL TERM PETITION FOR PROTECTION ORDER RELIEF UNDER THE PROTECTION FROM ABUSE ACT, 23 Pa,C.S. ~6101 et seq. A. ABUSE I. The plaintiff, Kathy Lynn Miller, is an adult individual residing at 141 East Louther Street, 1st Floor, Carlisle, Cumberland County, Pennsylvania 17013. 2. The defendant, Charles Edgar Miller, Jr. (SSN: 1 97-54-3340)(DOB: 11113/62), is an adult individual residing at 124 Ann Street, 1st Floor, Middletown, Dauphin County, Pennsylvania 17057-1310. 3. The defendant is the husband ofthe plaintiff and the father of the parties' children. 4. Since approximately March 1997, the defendant has allempted to cause and has intentionally, knowingly, or recklessly caused bodily injury to the plaintiff, has placed her in reasonable fear of imminent serious bodily injury, has knowingly engaged in a course of conduct or repeatedly commilled acts toward the plaintiff including following the plaintiff without proper authorization, under circumstances which have placed the plaintiff in reasonable fear of bodily injury. This has included, but is not limited to, the following specific instances of abuse: a) On or about September 16, 1997, the defendant telephoned the plaintiff's home approximately 15 times leaving messages on her answering machine, b) On or about September 6, 1997, the defendant telephoned the plaintiff, threatened to cut up her and her friend, and threatened to beat them both ifhe saw the plaintiffs friend coming out of her house. The defendant carries a switchblade knife with him. The plaintiff fears for her safety. c) On or about September I, 1997, the defendant screamed in the plaintiffs face, pointed his finger in her face, threatened her saying that she and her friend had an "ass whipping" coming to them, and shoved the plaintiff backward against a counter. When the plaintiff took the children out to the car, the defendant followed them, and in front of the children, harassed her about any sexual relationship she might have with her friend repeatedly and badgered her about having sex with him, When the plaintiff told the defendant that their relationship was over, he slapped her on the side of her face and head, called her obscenities, followed her around to the driver's side door, spat in her face as she got into the car, called her a whore, and pounded on the driver's side window as she backed the car away, The plaintiff feared for her safety and that of her children, The defendant telephoned the plaintiff's home and left a message on her answering machine asking that she call him back. When she called him back, the defendant screamed at her and threatened to make her life miserable. He further threatened to cut her and her friend up and threatened to give her friend an "ass whipping". The defendant also told the plaintiff that he was going to sit in front of her house in a car and watch her activities, d) In or about late August 1997, the defendant telephoned the plaintiff's home and when the answering machine came on he screamed that if someone hangs up the phone again he was going to shove the goddamned phone up their ass. The defendant telephoned several more times, screamed that the plaintiff was an ignorant bitch, that he was going to stay on the line, and he demanded that she pick up the telephone because he was coming to the house to see the kids. The plaintiff's teen-aged nephew, who was babysitting her children, was afraid to answer the telephone when the defendant called and was scared to remain in the house. The plaintiff's sister came and got her son and the plaintiff's children and took them to her home for safety. e) In or about March 1997, the defendant screamed at the plaintiff in front of their children and threatened that he would beat her and anyone she might be seeing, The plaintiff took the children and returned to her home, t) The plaintiff filed a Temporary Protection Order and Petition for Protection From Abuse and Custody against the defendant on January 19, 1994 (see attached Exhibit A, incorporated and made a part hereto), S. The plaintiff believes and therefore avers that she is in immediate and present danger of abuse from the defendant and that she is in need of protection from such abuse. 6. The plaintiff desires that the defendant be prohibited from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications, except for the limited purpose of facilitating custody arrangements. 7. The plaintiff desires that the defendant be enjoined from harassing and stalking the plaintiff, and from harassing her relatives, and the minor children, 8. The plaintiff desires that the defendant be restrained from entering her place of employment, or the day care facility of the minor children. 9. The plaintiff desires that the defendant be enjoined from removing, damaging, destroying or selling any property owned by the plaintiff. 10. The plaintiff desires that any weapons the defendant owns or possesses (switchblade knife) be confiscated by the Sheriffs Department and that the defendant be prohibited from acquiring or possessing any weapons for the duration of the Temporary Protection Order. B. EXCLUSIVE POSSESSION II. The residence from which the plaintilTis asking the Court to order the defendant to stay away from is rented in the name of the plaintilTand the defendant has never resided there. C. REIMBURSEMENT FOR COST OF CASE 12. Ordering the defendant to pay $250.00 to Cumberland County, one of Legal Services, Inc.'s funding sources, in lieu of allomeys' fees, as reimbursement for the cost of litigating this case and assessing the $25.00 surcharge and court costs to the defendant if the case goes to hearing. WHEREFORE. pursuant to the provisions of the "Protection from Abuse Act" of October 7, 1976,23 P.S. ~6101 !:l gn" as amended, the plaintilTprays this Honorable Court to grant the following relief: A. Grant a Temporary Order pursuant to the "Protection from Abuse Act:" I. Ordering the defendant to refrain from abusing the plaintilT or from placing her in fear of abuse. 2. Ordering the defendant to refrain from having any direct or indirect contact with the plaintilT including, but not limited to, telephone and wrillen communications, except for the limited purpose of facilitating custody arrangements. 3. Ordering the defendant to refrain from harassing and stalking the plaintilT and from harassing her relatives and the minor children, 4. Prohibiting the defendant from entering the plaintiffs place of employment and the day care facility of the minor children. 5. Prohibiting the defendant from removing, damaging, destroying or selling property owned by the plaintiff. 6. Ordering the defendant to stay away from the plaintitl's residence located at 141 East Louther Street, 1st Floor, Carlisle, Cumberland County, Pennsylvania, and ordering the defendant to stay away from any residence the plaintiff may in the future establish for herself. 7. Ordering the defendant to relinquish to the sheritl's department any weapons which he owns or possesses (a switchblade knife), and prohibiting the defendant from acquiring or possessing any other weapons for the duration of the Temporary Protection Order. B. Schedule a hearing in accordance with the provisions of the "Protection from Abuse Act," and, after such hearing, enter an order to be in effect for a period of one year: I. Ordering the defendant to refrain from abusing the plaintiff or from placing her in fear of abuse. 2. Ordering the defendant to refrain from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications, except for the limited purpose of facilitating custody arrangements, 3. Ordering the defendant to refrain from harassing and stalking the plaintiff and from harassing her relatives and the minor children. 4. Prohibiting the defendant from entering the plaintitl's place of employment and the day care facility of the minor children, 5. Prohibiting the defendant from removing, damaging, destroying or selling property owned by the plaintiff. 6. Ordering the defendant to stay away from the plaintitl's residence located at 14] East Louther Street, 1st Floor, Carlisle, Cumberland r. -""--~'" ~,.....'.'''i County. Pennsylvania. and ordering the defendant to stay away from any residence the plaintiff may in the future establish for herself. 7. Ordering the defendant to relinquish to the sheriffs department any weapons which he owns or possesses (a switnchblade knife), and prohibiting the defendant from acquiring or possessing any other weapons for the duration of the Protection Order. 8. Ordering the defendant to pay $250.00 to Cumberland County, one of Legal Services. Inco's funding sources, in lieu of attorneys' fees, as reimbursement for the cost of litigating this case and assessing the $25,00 surcharge and court costs to the defendant if the case goes to hearing. The plaintiff further asks that this Petition be filed and served without payment of fees and costs by the plaintiff. pending a further order at the hearing, and that a certilied copy of this Petition and Order be delivered to the Carlisle Police Department which has jurisdiction to enforce this Order. The plaint iff prays for such other relief as may be just and proper. Respectfully submitted. , --tv a.~t~ oan Carey. Attorney Ii LEGAL SERVICES, INC. 8 Irvine Row Carlisle. PA 17013 (717) 243-9400 " The above-named plaintiff, Kathy Lynn Miller, verifies that the statements made in the above Petition are true and correct. The plaintilT understands that false statements herein are made subject to the penalties of 18 Pa,C.S. ~4904 relating to unsworn falsification to authorities. Date: C\. \ ~. q l hC~\l--\ ~~\H\ '-\\~. Kathy Lynn Mill r, PlaintilT I~l ~--y ~ Kathy L. Miller, Plaintitf : IN THE COURT OF COMMON PLEAS OF JAN 1 J -. \../ : : CUMBERLAND COUNTY. PENNSYLVANIA : : CIVIL ACTION - LAW . . NO. ~ 31 CIVIL 1994 PROTECTION FROM ABUSE AND CUSTODY v. . . Charles E. Miller, Jr., Defendant . . AND NOW, this TEMPORARY PROTECTIVE ORDER / q q- day of January 1994, upon presentation and consideration of the within Petition, and upon finding that the plaintiff, now residing at 112 Lawrence Lane, Carlisle, Cumberland County, Pennsylvania, is in immediate and present danger of abuse from the defendant, Charles E. Miller, Jr., the following Temporary Order is entered. The defendant, Charles E. Miller, Jr., now residing at 752 State Street, Lemoyne, Cumberland County, Pennsylvania, is hereby enjoined from physically abusing the plaintiff, Kathy L. Miller, or placing her in fear of abuse and ordered to stay away from the residence located at 112 Lawrence Lane, Carlisle, Cumberland County, Pennsylvania, a residence which is not owned or leased by the defendant.r-The defendant is hereby notified that if he resides in the plaintiff's domicile contrary to this Order, he may be in indirect criminal contempt which is punishable by a fine not to exceed $1,000.00 and/or by a sentence of up to six months in jail and any other appropriate punishment. Resumption of co-residence on the part of the plaintiff and the defendant shall not nullify the provisions of the court order directing the defendant to refrain from abusing the Plaintif,i:~ Temporary custody of Joseph Michael Miller is hereby awarded to the plaintiff, Kathy L. Miller. The defendant is ordered to refrain from having any contact with the EXHIBIT A plaintiff except facilitating custody of their minor child. The defendant is ordered to refrain from entering the plaintiff's place of employment, from stalking the plaintiff, or from harassing the plaintiff or the her relatives. The defendant is ordered to refrain from da8aging or destroying any property owned by the plaintiff or jointly owned by the parties. This Order shall remain in effect until a final order is entered in this case. A hearing shall be held on this matter on the d }-aJday of January, 1994, at I; ? 0 tJ... in Courtroom NO...ii..., Cumberland County I Courthouse, Carlisle, Pennsylvania. The plaintiff may proceed in !2ImA oauoeris pending a further order after the hearing. The Cumberland County Sheriff's office shall attempt to make service at the plaintiff's request, but service may be accomplished under any applicable rule of Civil Procedure. The Pennsylvania state police Department will be provided with a copy of this Order by attorneys for plaintiff. This Order shall be enforced by any law enforcement agency when a violation occurs by arrest for indirect criminal contempt. The arrest may be without warrant upon probable cause that this Order has been violated, whether or not the violation is co..itted in the presence of the police officer. In the event that an arrest is made under this section, the defendant shall be taken without unnecessary delay before the court that issued the Order. When that court is unavailable, the defendant shall be srraigned before the appropriate district justice. (23 Pa.C.S.A. Section 6113). -r-"- """ .~..It'1 ,".i".{'" ~'I r;F.-r~~r~O f r.:.:',": "~...:lt.... ."; "../ ," ;\ .l.o.;\', 1 ','" 'r~.,. 'r"",' . ", ....."'..- ";'~".~ t';: ff~',' n:'.~d .11 ...... ; .,. .' .. By the Court, ilj /5/ g;"r~.4 ~ J. i I I .i H ~ j /"j -..( 4j 1 4 I I I I , l i , , I ~ C) ~ "'- ....l ,-- .. .'. IJJQ - ::J 4'" ~L':, (.:.j~) L ~_. -'~ W':~,' .1.. n.. n::~ ~r' ("I .,.-, ~.. ,: r-: 4".,!.., . Cr. e-..: ''1'" a:\! , Ii\.. ; ~-:/ " b.i l'-i:-tl ,- _. v.: tl..<~ ::.:f ~ t- ~..l 0" U "j..- i ......-......-- KATHY LYNN MILLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs, : NO. 94-239 CIVIL TERM CHARLES EDGAR MILLER, JR., Defendant : PROTECTION FROM ABUSE PRAECIPE TO WITHDRAW APPEARANCE To the Prothonotary: Legal Services. Inc. hereby withdraws its appearance as counsel for the plaintiff in the above- captioned acti~n, Date: / P -I - 9 7 ,p1dn (.~ Joan Carey Philip C. Briganti Jane Muller-Peterson Allorneys for Plaintiff LEGAL SERVICES. INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 PRAECIPE TO ENTER APPEARANCE To the Prothonotary: Please enter mv appearance on behalf of the plaintiff. Kathv Lvnn Miller. in the above-captioned case. 'S~~~/ Allorney for Plaintiff JACOBSEN & MILKES 52 East High Street Carlisle, PA 17013 (717) 249-6427 Date: 1Q(~ \ ~f ">- ~) ," ~ C" I:: '. ,-- ., ~5 UJ~;~. - '; U;' ~: . 0 ts:.::..' 0- ~f~:' , " " I .'1 : \.W \. ~. ;-l t- j[lj u: ~~ w :-nr:.- .;", c; ''; LI, ~ ::> (.) u . @OCT 0 2 1997 CHARLES E. MILLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94.239 . CIVIL TERM V. KATHY L. MILLER, Defendant PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW. this 'Z.~ day of October. 1997. upon consideration of the attached Stipulation for Continuance, the matter scheduled for hearing on October 2, 1997 at 3:00 p.m. in Courtroom No.4. by this Coun's Order of September 23, 1997, is hereby continued generally. This Order is entered without prejudice to either pany to request a hearing. The Temporary Protection Order shall remain in effect until modified or terminated by the coun. Cenified copies of this Order for Continuance will be provided to the Carlisle Police Depanment by the plaintiffs attorney. By fu, C~~J. A. Hess, Judge Family Law Clinic Counsel for Defendant Mark C. Locke - Legal Intern Katherine C. Pearson - Attorney at Law , /' (~'(_L_' A/lt"C.t~.. .,,'- JO,~ ';7 Samuel Milkes Counsel for Plaintiff '-I""' ' FILED 'C,:FlCE OF ", ", ''''-'''-'''''''('V ' I ",", 1",.'li'",., 970Cr_) "': ~1'27 ';; ... f,. .. ."" eli.,.." ''-'J\!'jv ,~.... _. .... 1...' -./, '. J I Fi.:\'\;'~;/"_',.,:,.,.,..t-\ . . CHARLES E. MILLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 94-239 - CIVIL TERM KATHY L. MILLER, Defendant PROTECTION FROM ABUSE STIPULATION FOR CONTINUANCE The defendant, Charles E. Miller. through his attorney. the Family Law Clinic, and plaintiff Kathy L. Miller, through her attorney, Samuel Milkes, request that the Court grant an Order continuing generally the hearing in the above captioned matter on the grounds that: 1. A temporary order was issued by this Court on September 23, 1997 and a hearing was scheduled on October 2, 1997, at 3:00 p.m., in Courtroom No.4. 2. At the time of the temporary order, plaintiff was represented by Joan Carey of Legal Services. 3. On October I, 1997 Legal Services withdrew their appearance and Samuel Milkes entered his appearance on behalf of Kathy L. Miller. 4. The parties by and through their counsel agree that the hearing be generally continued to afford them time to reach an agreement. 5. The parties by and through their counsel agree that the Temporary Protection Order will remain in effect until a new hearing can be scheduled or until modified or tenninated by the court after notice or hearing. 6. Certified copies of the Order for Continuance will be delivered to the Carlisle Police Department by the attorney for the plaintiff. . . Wherefore, the parties request that the Court grant an Order continuing this matter generally, and that the Temporary Protection Order remain in effect until further Order of Court. ~~ .-samuel Milkes Counsel for Plaintiff Respectfully Submitted, flU -AJtL.-/ Mark Locke Certified Legal Intern '7iattUl.-u..~ C, 11 a....tv----' Thomas M. Place Robert E. Rains Katherine C. Pearson SUPERVISING ATIORNEY Donald Marritz STAFF ATIORNEY Counsel for Defendant FAMILY LAW CLINIC 45 North Pitt Street Carlisle, PA 17013 (717) 243-2968 Fax: (717) 243-3639 ">- r-- '- ~ C": [;: i~ (.6 , " ~'r UJ~: ) , u", ~- \..- C,:~._I ~ . , . , ~;: t:: " ,,' ...' '. -';~ I, ~..., I -i:.. I- \. ~Ej ceLl' (..) ;C!:J... F' c:::: ~.::~ t!. r- ::.> 0 Cf'l U , .~!i::':E! FF'::;': EF:Ti_::\l-: t..I:,j T uF CI,.'L:llTY :::A[~E ~;!-i: I '~-J)~j ~ ~',;.J:':~r_:', F' COI111ONWE,\L I'll DF r'ElIfiC;'I'LV MII,\: COUNTY OF CUMBERLAND MILLEr, r;ATfIY L ur:- r':J. trlLJ..ER. (~HARLF.S E IR R. T:'lf;H\,'I;:; E 11 nf' Shc'r.lfi, who bLj~ng dul)' sworn iJccord..Lng +'0 ld;'{, zoi';:;':, that he. ;:ra.dc.. ~ dlli{Jc.nt ;::a:>lrch und inqul.ry for t.hE' with~n rla~1>:..,j dc.fendant, tel 'Wit: .Jil.b1.;;F; CHAHLES E JH but w~s lJnable to locdte Hlm ~rl hl~ ba11~w~clt. lie thereforE' d;':-'pl,:~.-i..::G.'d thE:~ sher.1JJ r.:1f ['A'-.'PH I n COUrny County, Pennsylvan~a. to ~;eJ'V0 the wl~hln F'R01'ECTIOr~ fRON ABUSE ':.In Oc-:te,bpr ')t,h. 19:;7 this offIce was in receipt of t.h<, it.t~,jched return ironl [.AUFh):: ((JUrrr", COUI)t,/. Pl;.'nnzylvan~a. ':r:.:,; ~.f.f ";..- Co;::-~t2.?: : "".' ., ,\:,1, i rl':l ',!ur. ;.:,f Cc,unty ~.: I.J l-i.~ h d 1'g ;.;:. 18.0C' 9.00 .;. \)(' :..;,:',' dn:~w76 :~; ~./;/? ._~.<. ,/-;:/~ h -~/ >:f ,c,.,~.,,..,,,.,.~ .-~~ r:::-.hvma~ . El.l.ne, ;;,)hE.lI' .:ill )> .;,~'.:I. 0:,;) C,:J" ..;,..0:... x.1G0~i ; ;. ;Jnd "';UD ;;;;-i:::- r 1 t .::..d t: ~ (:',t c. 1 (-' ;;;"_' +.;;", ._~_ -:id;.' oJ /Jl.iiP.l'.... :'" ...2..l ^. r,. ---'-'C)t,~I~r-~Q-;;}~4l( . . .~ -- r ',.,: ... _ j . ~ _...,\ ~ : ~. Ralph G. McAllister Chlel Dopuly Office of the Sheriff Mary Jallo Snydor HOlll E 610310 OopulV William T. Tully Solicit Of Michael W. Rinehart hssi.lonl Clllel Depuly Dauphin Counly tiollitiburn. PcnnEiylvonla 1/101 111 f) 255,2800 J. R. Lotwick Sheriff COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN SHERIFF'S RETURN No. 2170-T - - -97 OTHER COUNTY NO. 94-239 AND NOW I September 26, 1997 at 9:22MI served the within TEMPORARY PROTECTION ORDER, NOTICE & PET upon MILLER JR., CHARLES EDGAR MILLER JR., CHARLES EDGAR by personally handing to 1 true attested copy(iesl of the original TE~IPORARY PROTECTION ORDER, NOTICE & PET and making known to him/her the contents thereof at 124 ANN ST. 1ST FL. MIDDLETOWN, PA 00000-0000 NOTE I nEFT. IlF.NJED H.WING. O\'.'mNG,POSSESSING WEAPONS iNCLUDING SWITCH BLADE WE SEARCH RESIDENCE - NO WEAPONS FOUND Sworn al1'1 subscribed to bef~~~me this 26TH day oft 1PTEMBER, 1997 V rt'.ff f ' . I j c.-. a.~:';7...Q) PROTHONOTARY TE/MS So z;;u ~'iff of Dauphin County, Pa. c.~ " BY ~.l:a".;/ ~ ~PUT'.{ SH FE--" Sheriff's COStSI 50.00 PD 00/00/00 RCPT NO .", In 'l:he Court or Common Pleas oH':umberlund Lounty, - . Kathy Lynn Miller VS. Charles Edgar Miller, Jr. No. 94-239 Civil Term 19_ Now, Sept. 23. Dauphin 1991.9_.1 SHERIFF OF CUMBERLAND COUNTY, PA do bereb~' deputize tbe Sberlffof Counl)' to necute this Writ. this deputation being made attbe request and risk of tbe Plaintiff. r~~/~ SberlffofCumberland Counl)'. Pa. Affidavit of Service 19 .at o'clock ~I, sel'\'ed tbe i"ow, witbin upon at by banding to attested cop~' of the original tbe contents tbereof, a true and and made known 10 So answers, Sheriff of Counl)', Pa. COSTS S\\orn and subscribed before me this day of 19_ SERVICE MILEAGE AHIDA VIT s s KATHY LYNN MILLER, Plaintiff V. CHARLES EDGAR MILLER, JR., Defendant I IN THE COURT OF COMMON PLEAS OF I CUMBERLAND COUNTY, PENNSYLVANIA I I CIVIL ACTION - LAW I 94-239 CIVIL TERM I I PROTECTION FROM ABUSE IN RE I TEMPORARY PROTECTIVE ORDER ORDER OF COURT AND NOW, this 27th day of October, 1997, pending further order, the temporary protective order dated October 14th, 1997, remains in full force and effect with the exception of the provision barring his entry into the daycare facility. Samuel W. Milkes, Esquire For the Plaintiff Xatherine Pearson, Esquire Mark C. Locke, Esquire Family Law Clinic 4S North pitt Street Carlisle, PA 17013 For the Defendant mal By the Court, /Iii Hess, J. _ ~.,; (h....~..( 101 :L'iI/9'1. ..4. "P. . . , KATHY LYNN MILLER, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA vs. 94-239 CIVIL CHARLES EDGAR MILLER, JR., Defendant PROTECTION FROM ABUSE ORDER AND NOW, this ~F" day of October. 1997, after hearing and careful considemtion of the testimony adduced, it is ordered and directed that: I. The defendant, Charles Edgar Miller, Jr.. (SSN: 197-54-3340) (DOB: 11113/62), now residing at 124 Ann Street, 1st Floor, Middletown, Dauphin County, Pennsylvania, is hereby enjoined from physically abusing the plaintiff. Kathy Lynn Miller, or from placing her in fear of abuse. 2. The defendant is enjoined from harassing and stalking the plaintiff. and from harassing her relatives. The defendant is enjoined from entering the plaintiffs place of employment. 3. The defendant is enjoined from removing. damaging, destroying or selling any property owned by the plaintiff. A violation of this order may subject the defendant to: I) arrest under 23 Pa.C.S. Section 61 13; ii) a private criminal complaint under 23 Pa.C.S. Section 6113.1; Hi) a charge of indirect criminal contempt under 23 Pa.C.S. Section 6114. punishable by imprisonment up to six months and a fine 01'$100.00 - $1,000.00; and iv) civil contempt under we Pa.C.S. Section 6114.1. This order shall remain in effect for a period of one year. The costs of this action shall be borne by the defendant. The Carlisle and any other relevant Police Department shall be provided with a certified copy of this order by the plaintilT's attorney. This order shall be enforced by any law enforcement agency where a violation occurs by arrest for indirect criminal contempt without warrant upon probable cause that this order has been violated, whether or not the violation is committed in the presence of the police officer. In the event that an arrest is made, under this section, the defendant shall be taken without unnecessary delay before the court that issued the order. When that court is unavailable, the defendant shall be taken before the appropriate district justice. (23 Pa.C.S. Section 6113). BY THE COURT, -/,'^ j,.' A 4-, Kevin A. Hess, J. Samuel Milkes, Esquire For the Plaintiff I Mark Locke Family Law Clinic For the Defendant . ..~.i. IO/~lIlfj7. CArFI.-U>' rY' ,4. fl. :rlm v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PROTECTION FROM ABUSE No. 94-239 CIVIL TERM KATHY LYNN MILLER, Plaintiff CHARLES EDGAR MILLER, JR. Defendant IN RE: RULE TO SHOW CAUSE ORDER OF COURT AND NOW, May 13, 1998, in consideration of the attached petition, the Court issues a Rule to Show Cause on the defendant why he should not be adjudged in Contempt of Court for failing to pay the sums set forth in the petition. The Rule is returnable and the hearing shall be held on Friday, June 5, 1998, at 9:30 A.M. in Courtroom No.4, Cumberland County Courthouse, Carlisle, Pennsylvania. Service of the Rule to be made on defendant by Certified Mail, return receipt requested and by regular mail. By the Court, .... <L. //IL Kevin'A. Hess, J. Office of the District Attorney I Public Defender Probation Office :dp ~ ~~ '-:>.M\."C..t-,.~ It.>.r\;, ~l). '" ~. f~) C~. ...,-. \:~? ", t" (; , ~ :;~ c.'. , , " C:, - ~~ " .t ; t l\: . i'- ,. (~. ---'1 i...J V' :.) . \.'io.. ' '"~ V. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PROTECTION FROM ABUSE No. 94-239 CIVIL TERM KATHY LYNN MILLER, Plaintiff CHARLES EDGAR MILLER, JR. Defendant PETITION TO SHOW CAUSE WHY THE DEFENDANT SHOULD NOT ~E HELD IN CONTEMPT OF COURT AND NOW, May 13, 1998, the Probation Office of Cumberland County, respectfully petitions Your Honorable Court to issue a Rule why the defendant should not be held in contempt of court. The defendant has failed to comply with the Court Order dated October 28, 1997. The defendant has failed to: [] Report to the Probation Office in person at the time and date set by the Collections Officer. [X] Make regular payments on the fine, costs and restitution as agreed. [ ] Other The defendant has agreed to pay $99.50 per month. Date last paid was never. The balance is $99.50. I verify that the facts set forth in this petition are true and correct to the best of my knowledge or information and belief. This verification is made subject to the penalties of section 4904 of the Crimes Code (18 Pa. C.S. @4904) relating to unsworn falsification to authorities. Respectfully .Kl!;( Ll,~( Petitioner submitted, /..' " )/. ,-r1lp~ ,. .,. en '.. " - (.,": 11: G~ if., : ut~ ( ,,~; C:~ ;;.: ._\ ~ -' ,., 9i ;'J C:, ~" , .. -', :'t... ,. J li: .', ~ , :\... i . - - " I t:r. :-j u ...' (J ... KATHY LYNN MILLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA . . V. CIVIL ACTION - LAW PROTECTION FROM ABUSE CHARLES EDGAR MILLER, JR. Defendant No. 94-239 CIVIL TERM IN RE: PETITION FOR CONTEMPT OF COURT ORDER OF COURT AND NOW, this 4th day of June 1998, the defendant having paid in full all sums owed, the Petition for Contempt of Court dated May 13, 1998, is dismissed. Office of the District By the Court, .Ad Probation Office :dp p,;J:G--C:p,:E , O~ " ," ,,,,,r'1,.!r,,,o()llril .~ i ~.-,'''. ,.: ',.- .', '. - '," ' ~(I jUi\ - 'J 'i'l\ '3: 7.4 C\,M:'3;::;ci~ .:..' vCJiJi"-lii I-'cNt;S'llW";"\'" KATHY LYNN MILLER, Plaintiff : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 94-239 CIVIL TERM CHARLES EDGAR MILLER, JR., 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 JULY M ,1999, AT 3:L{se..M. IN COURTROOM NO. L OF THE CUMBERLAND COUNTY COURTHOUSE, CARLISLE, PENNSYLVANIA. You MUST obey the Order that is attached until it is modified or tenninated 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 injail under23 Pa.C.S. ~6114. Violation may also subject you to prosecution and criminal penalties under the Pennsylvania Crimes Code. Under fedemllaw, 18 U.S.C. ~226S, this Order is enforceable anywhere in the United States, tribal lands, U.S. Territories and the Commonwealth of Puerto Rico. If you tmvel 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 10 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 ASSOC]ATlON 2 LIBERTY AVENUE, CARLISLE, PENNSYLVANIA 170]3 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 infonnation 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 ]east 72 hours prior to any hearing or business before the court. You must attend the scheduled conference or hearing. F:'...rO--'::,'r;:~ 0- " ," '.. --, 'n.. --{ 10'( ~ .' , . " 'i '..i 99 '1'1 "0 ["" '), t:'fI '" '" t~ t I .J' ..1 "" C"" .0', . . "I'lTY \;I/';:::~~,L.I ~ '.:...' 1...1......-..".,,\ f'-"\ ':\'1 V! ",:.\ t:1'I"-...I"-..'.,,. . Kathy Lynn Miller, : IN THE COURT OF COMMON PLEAS OF Plainti tT : CUMBERLAND COUNTY , PENNSYLVANIA vs. : NO. 94-239 CIVIL TERM Charles Edgar Miller, Jr., Defendant : PROTECTION FROM ABUSE JEMPORARY PROTECTION FROM ABUSE ORDER Defendant's Name: Charles Edgar Miller, Jr. Defendant's Date of Birth: 11/13/62 Defendant's Social Security Number: 197-54-3340 Names Protected Person: Kathy Lynn Miller AND NOW, this 20 ~ay of .T u ( ... , 1999, upon eonslderation of the attaehed Petition for Protection fro~reby enters the following Temporary Order: 129 I. Defendant shall not abuse, harass, stalk or threaten any of the above persons in any place where they might be found. o 2. Defendant is evicted and excluded /Tom the residence at _ or any other pennanent or temporary residence where PlaintitT 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. 129 3. Exeept for such contact with the minor children as may be permitted under Paragraph 5 of this Order, Defendant Is prohibited from having ANY CONTACT with PlalntltT at any location, Ineludlng, but not limited, to any contact at Plalntlfrs place of employment located at Carlisle Hospital, 246 Parker Street, Carlisle, Pennsylvania. Defendant is specifically ordered to stay away from the following locations for the duration of this Order: Plaintiff's residence located at 141 East Louther Street, Carlisle, Pennsylvania. 129 4. Except for such contact with the minor children as may be permitted under Paragraph 5 of this Order, Defendant shall not contact Plaintiff by telephone or by any other means, Including through third persons. lJ 5. Pending the outeomeofthe final hearing in this mailer. Plaintiffis awarded temporary custody ofthe following minor ehild/ren: Until the final hearing, all contact between Defendant and the child/ren shall be limited to the following: The local law enforcement agency in the jurisdiction where the child/ren are located shall ensure that the child/ren are placed in the care and control of Plaintiff in accordance with the tenns of this Order. lJ 6. Defendant shall immediately relinquish the following weapons to the Sheritl's Offiee or a designated local law enforcement agency for the delivery to the Sheritl's Office: ~dd is prohibited from possessing, transfening or acquiring any other weapons for the duration of this Order. lID 7, 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 ofthis Order to Defendant by mall. This Order shall remain in effect until modified or terminated by the Court and can be extended beyond its original expiration date if the Court finds that Defendant has committed an act of abuse or has engaged in a pattern or practice that indicates risk of harm to Plaintiff. Defendant is enjoined from damaging or destroying any property owned jointly by the parties or owned solely by Plaintiff. Defendant is to refrain from harassing Plaintiff's relatives. lID 8. A certified copy ofthis Order shall be provided to the pollee department where Plaintiff resides and any other agency specified hereafter: Carlisle Police Department and the Middletown Police Department. lID 9. THIS ORDER SUPERSEDES lID ANY PRIOR PFA ORDER and o ANY PRIOR ORDER RELATING TO CHILD CUSTODY TillS ORDER APPLIES IMMEDIATELY TO DEFENDANT AND SHALL REMAIN IN EFFECT UNTIL MODIFIED OR TERMINATED BY TillS COURT AFTER NOTICE AND HEARING. NOTICE TO DEFENDANT Defendant Is hereby notified that violation of this Order may result In arrest for Indirect criminal contempt, which Is punishable by a fine of up to $1,000.00 and/or up to six months In jail. 23 Pa.C.S. ~6114. Conscnt of the Plaintiff to Defendant's return to the resldenee shall not Invalidate this Order, which can only be chanl:ed or modified through the filing of appropriate court papers for that purpose. 23 Pa.C.S. ~6113. Defendant Is further notified that violation of this Order may subject him/her to state charges and penalties under the Pennsylvania Crimes Code and to federal charges and penalties under the Violence Against Women Act, 18 U.S.C. ~~ 2261-2262. Any protection order granted by a court may be considered In any subsequent proceedings, Including child custody proceedings, under title 23 (Domestic Relations) of the Pennsylvania Consolidated Statutes. NOTICE TO LAW ENFORCEMENT OFFICIALS This Order shall be enforced by the pollee who have jurisdiction over Plalntlfrs residence OR any locations where a violation of this order occurs OR where Defendant may be located. If Defendant violates Paragraphs I 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 Sherlfrs office of the county which issued this Order, which office shall maintain possession ofthe 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. ,Judge Joan Carey LEGAL SERVICES, INC. Attorney for Plaintiff KATHY LYNN MILLER, PlaintitT : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 94-239 CIVIL TERM CHARLES EDGAR MILLER, JR., Defendant : PROTECTION FROM ABUSE PETITION_FOR PROTECTION FROM ABUSE I. The PlaintitTis Kathy Lynn Miller. 2. The name of the person who seeks protection from abuse is Kathy Lynn Miller. 3. Plaintiffs address is 141 East Louther Street, Carlisle, Cumberland County, Pennsylvania 17013. 4. 17039. Defendant's address is 124 Ann Street, Middletown, Dauphin County, Pennsylvania Defendant's Social Security Number is: 197-54-3340. Defendant's date of birth is 11113/62. To the best ofPlaintitT's knowledge, Defendant is unemployed. 5. children. Defendant is Plaintiffs fonner husband and the father of the parties' two minor 6. PlaintitTand Defendant have been involved in the following court actions: Case name PFA Divorce Custody Support Case No. 94-239 Date filed 01/19/94 11/25/97 (final) Court Cumberland Co.-Common Pleas Cumberland Co.-Common Pleas Cumberland Co.-Common Pleas Cumberland Co.-Common Pleas 94-6289 , I' 7. Defendant's criminal history includes, but is not limited to, convictions and incarceration in Dauphin County for aggravated assault, simple assault, and charges of Indirect Criminal Contempt filed through the Dauphin County Court as a result of his violations of the above-captioned Temporary Protection Order entered by Judge Kevin A. Hess on October 14,1997, (seeparagrnph 6) and the subsequent Protection Order entered on October 28, 1997, (see paragraph 6) both to the above-captioned docket number. Dauphin County Judge Scott A. Evans entered an Order on January 19, 1999, (Dauphin Co. No. 4526 S 1997)(see Exhibit A, made a part herein by reference) sentencing Defendant to 6 months incarceration in Dauphin County Prison for contempt, to run consecutive with that Court's prior sentences that were imposed by Judge Evans' two Orders ofSeptcmber 2, 1998, (see Exhibit B, made a part herein by reference) entered after a second Indirect Criminal Contempt hearing in that action, and Judge Evans' Order of November 13, 1997, (see Exhibit C, made a part herein by reference) entered after hearing and Defendant's plea of guilty to violating this Court's Temporary Protection Order entered on October 14, 1997, which ordered him to the batterer's counseling program upon his release from prison, and set out restrictions as listed in the Order. As a result ofthe Defendant's violations, and non- compliance of the these Orders, Defendant was incarcerated in Dauphin County Prison from September 2, 1998, through July 2, 1999. 8. Defendant has committed the following acts of abuse against Plaintiff: In or about early December 1998, Defendant, who was incarcernted in Dauphin County Prison for severnl violations of the Protection Order, sent two letters to Plaintiff, causing her to fear for her safety in part because defendant threatened to move to her town upon his release from prison. Defendant had violated the Protection from Abuse Order on several occasions in or about August of 1998 and in October of 1997 by threatening, intimidating, and physically abusing Plaintiff while transferring custody of the parties' two minor children. Defendant served consecutive prison sentences of approximately ten months and was released from Dauphin County Prison on July 2, 1999, and Plaintiff fears for her safety and that of her ehildren who have been exposed to Defendant's assaultive behavior many times at the transfer of custody. Although PlaintilT's divorce from Defendant was final in November 1997, he continues to claim that she is and always will be his wife, causing her to fear for her safety. To the best of PlaintilT's knowledge, Defendant has made no allemptto register for the batters' program which Judge Evans ordered him to attend upon his release from prison, which exacerbates her tear. 9, The following police department or law enforcement agency in the area in which Plaintiff lives should be provided with a copy of the Protection Order: Carlisle Police Department Middletown Police Department 10. There is an immediate and present danger of further abuse from Defendant. II. Plainti ffis asking the Court to order Defendant from the residence at 141 East Louther Street, Carlisle, Cumberland County, Pennsylvania, which is rented by Plaintiff. WHEREFORE, PLAINTIFF REQUESTS THAT THE COURT ENTER A TEMPORARY ORDER, AND AFTER HEARING, A FINAL ORDER THAT WOULD DO THE FOLLOWING: A. Restrain Defendant from abusing, threatening, harassing, or stalking Plaintiff in any place whcre she may be found. B. Order Defendant to stay away from Plaintitl's residence and prohibit Defendant from attempting to enter any temporary or pennanent residence of the Plaintiff. C. Prohibit Defendant from having any contact with Plaintiff, either in person, by telephone, or in writing, personally or through third persons, including, but not limited to, any contact at Plaintifl's place of employment, except as the Court may find nccessary with respect to partial custody and/or visitation with the minor children. D. Prohibit Defendant from having any contact with Plaintitl's relatives except as the court may find necessary with respect to partial custody and/or visitation with the minor children. E. Order Defendant to pay the costs of this action, including filing and service fees. F. Order Defendant to reimburse Cumberland County, a Legal Services funding source, $250.00 for the value of the legal services provided to Plaintiffforthe cost of litigating this case if the case goes to hearing. G. Order the following additional relief. not listed above: Defendant is to refrain from harassing Plaintifl~s relatives or the minor children. Defendant is to remain in his residence or his vehicle at all times during transfer of custody. H. Grant such other relief as the court deems appropriate. I. Order the police or other law enforcement agency to serve Defendant with a copy of this Petition. any Order issued, and the Order for Hearing. Petitioner will infonn the designated authority of any addresses. other than Defendant's residence, where Defendant can be served. Respectfully submitted. Date: 7-/9-7'/ 1 //) ~ /~JI.,/ ~<--/ (/}oan Carey, Attorney rtf Plaintiff LEGAL SERVICES, INC. 8 Irvine Row Carlisle, P A 17013 (717) 243-9400 -, VERIFICAJ:ION 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 unsworn falsification to authorities. Dated: 1'3.QQ f(, " '.-," ,-,' 14 15 16 17 18 19 20 21 22 23 24 25 "---" 1 ~ KATHY MILLER f". 2 IN THE COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA VS NO. 4526 S 1997 3 CHARLES MILLER NON-COMPLIANCE 4 5 ORDER 6 7 8 9 AND NOW, thi~ 2nd day of September, 1998, I find the 10 Defendant has not' complied with the Court's Order. 11 Consequent~y, we are putting in the suspended Order and 12 re-imposing a four-mnnth sentence effective today's date. 13 BY THE COURT: -:><\ ~ SCOTT A. EVANS, JUDGE distribution: Petitioner, 141 'E;, Louther St., 1st , 1sle, PA 17013 Respondent, ' Charles ",130 Miller I Jr., 124 Ann Street, Middletown, PA 17057 District Attorney's 9ffice Public Defender~B Office Dauphin County'Sheriff Dauphin CQunty Emergency Management - Attn: Roy J. Hyatt, Jr. Pennsylvania State Police Dauphin County Prison Central PA' Legal SerVices, 213-A North Front St., Hbg., PA 17101 Dauphin County Victim/Witness Assistance Program -9L Dauphin County Pretrial Services (\~~ Bureau of' Fines and Costs _::::'.J.. 19 I herzi,v cr,(lify It, t th") r();"'~goifl9 is a fru'J ~.nd f.vwi"c.(~. CQ;':yr.r;;: ~he o:1wnal" !""i 1\ ........ I ' , . ,.-,- 01' ~... :'."'....1 \."... DAUPHIN COUNTY COUR~~JYl EXHIBIT I A . .....--..-..-..---------.-.------....-----..--.---..--....------.---.----------.-----. 19 ~ I ~~r Y coolly t at l/1e fo~golrn:liS a true no CQii"f:CI cO:J\,~f the orlgJnal "1\ lUes.. : \ . I . I . ..... ~ ) i """':1'- 1\ ..;--',._. .'...... . ./~" ; '. ,.' SCOTT A. EVANS, JUDGE ~ distribution: , . " _ )___ 19 Petitioner, 141'E,"LcutherSt.. 1st FlooL, \.oclLJ.J.sle, PA 17013 Respondent, Cha~les'E. Miller, Jr., 124 Ann Street, 20 Middletown, PA '17057 District Attorney~e,office 21 Public Defender's ,Office DauphinCcunty Sheriff 22 Dauphin County,Emergency Management - Attn: Roy J. Hyatt, Jr. P~nnsylvania State Police 23 Dauphin County Prison Central PA LeglilServictls, 213 -A North Front St., Hbg., PA 17101 Dauphin,county'Victim/Witness Assistance Program 25 Dauphin County Pretrial Services Bureau of Fines and Costs ~, 1 .......... 2 . 3 4 5 6 7 8 9 10 11 12 13 ',-. 14 1 ~ KATHY MILL . r-. IN 'Lo.1i: COURT OF COMMON PLEAS DAUPHIN COUNTY, PENNSYLVANIA NO. 4526 S 1997 ~':'" Pr(.~ 18 24 ~' va CHARLES MILLER : NON-COMPLIANCE o ROE R AND NOW, this 2nd day of September, 1998, based on the testimony and'weighing, I find the Defendant in Contempt of the 'Court's Order, sentence him to six months incarceration at Dauphin County, Prison to run consecutive to the sentencs imposed on the non-compliance. BY 'I'HE COURT: DAUPHIN COUNTY COURT REPORTERS . .-----------------------------------------------------------------------.--------------------------------- 06/15/1999 07:35 II .-, t'"'\ '" ',- KATHY L. MILLER, , Petitioner, VB ", . IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY, PENNSYLVANIA NO. 4526 S 1997 INDIRECT CRIMINAL CONTEMPT CHARLES B. .'MILLER, ,JR.. , Respondent!. o R D E R AND ~OW! this 19th day of January, 1999, upon , " Respondent':5 acknow1;edgment of contempt, the Court sentences him to six mon~hs incarcera~iQn in Dauphin County Prison to run consecutive to the' s'an~enC!!es that have heretofore been imposed. '....... This sentence is hereby suspended upon the Respondent ',s compl:!.l;ltlce !I.\'lQ ongoing compliance wi th the Court' s Final Protection From';Abuse Order, which includes but is not limited to the'itell\s,,'tbat have been discussed in open court that are part and parcel, of ;"this negotiated'. 'plea; being that the defendant only send.appropriatemail to the children; no longer communicate..wtth, the,'Pet;iitioner by mail .or otherwise, and that he , , continue with'hisbatterer's counseling after his release from Dauphin County Pri~on. /-d).IJ ", 1~ "BY THE I hereby certify that the,'foregolna 18 a ' troe and correct CO]Pf the origlnil" . fJlad. . , ~fwt. .~..~; Proth notary . COURT: /4 _.._-~ - -'-. . ~ EVANs:,.. J EXHIBIT " ',-- , SCOTT A. (Distributions on Page 2.) '-B '...... '-, 6 la 1999 D 13a 000_ 1 781677 , ~ r"I , " Distribution: ' " Kathy L. Miller, 1418.;Louther St., 1st Fl., Carlisle, PA 17013 Charles M~l1er,:124':.rmn,Street, Middletown, PA 17057 Dauphin CO?ntYSheriff's Office Dauphin CO\U1!:Y,;Prisort. Office of Diatxict' At.tQ'2:'ney, Deborah E. CurciUo Office of PUblic Def~nders, Diane L. Morgan Central PA'Lagal,BerVices, 213~A N. Front St., Hbg., PA 17101~2240 ',-' Roy J. Hyatt, Jr.~, D ..'C; '~ergency Management, 112 Market Bt., Hbg." PA 1'7101 Middletowi1.l>pI:ic~ De>>.b.,',:~O W. Emaus St., Middletown, PA 17057 Hbg. POlice'Dept., 'C70'Lt. Rapak, 123 Walnut St., Hbg., PA " 17,101"",,,,,...,;.: .. PA State POl'!cEl', 'iaQO';~erton Avenue,'Hbg., PA 17110 Victim/Witness :Assie~~~ce Program, Laurie ReileY~Snell Karla Snyd~r,. case:"PlQr~er, D.C. Pre-trial Services, 1205 S9utp 2~t;h.~'St.; Hbg., PA 17111 YWCA 215 MarketSt",'1:fbg., PA 17101 " I) ("\ " . ~ 0.65,,3 Cjb , " " tl ___......_.___.~..4.4 _.___.._....... _....~. 4. . __-e. ...... ... . ..0... '. ..... .,.. ...__.............:.. " 0&/15/1999 07:35 ---------------------------------------------------------------------------------------------------------. I\. 1 Z 3 4 5 6 7 8 9 10 11 12 l. 13 14 15 16' 17 18 19 20 7177781&77 DVSCP PAGE 1& 1 KA'rHY LYNN MILLER : IN THE COURT OF COMMON PLEAS . . DAUPHIN COUNTY, PENNSYLVANIA . . : NO. 4526 S 199~ . . CHARLES EDGAR MILLER, JR. : INDIRECT CRIMINAL CONTEMPT o R D E R AND NOW~ this 13th day of November, 1997, finding that the Defendant based on his admission violated the temporary protection from abuse order entered by the Honorable Kevin A. Hess, we hereby sentence the Defendant to be inoarcerated at Dauphin County Prison for four months, fine in the amount of $100 which is the minimum required by law. Therefore, I must impose one hundred dollars. The sentence herein imposed, however is suspended provided that the Defendant forthwith enroll in the batterers counseling program as designed by Dauphin county and successfully oomplete said program. EXHIBIT I c , , I .... I " , . ~ ., " , .. _._--, " "..:: ,... ..',' '.... I"", , ' -. ..' r\ DAUPHIN COUNTY COURT REPORTERS . --.-.----...------.----.--------------------------------------------------------------------------------. PAGE 17 06/15/1999 07:35 , 1 2 3 4 5 6 7 8 9 10 11 12 ~ 13 14 15 16 17 18 19 20 21 22 71 77781677 DVSCP 2 Failure to do so would then impose four months incarceration. Successful completion will ~en forever suspen~ the four'month sentence and the hundred dollars fine herein.' imposed. BY THE COURT: SCOTT A. EVANS, JUDGE distribution: Kathy 'Lynn Miller; 14i E. LOuther st., 1st FI, Carlisle, PA 17042 Charles Edgar Miller, 124 Ann St., 1st Fl. Middletown, PA 17057 Leqal Services Deborah curcillo;,'Esq. District Attorney's Office Paul Muller, Esq.,. PUblic Defender's Office Dauphin County Sheriff Dauphin County Emergency Management - Attn: Roy J. Hyatt, Jr. Harrisburg Police' Department Dauphin County Prison Dauphin County V~atim/Witness Assistance Program Dauphin county Pretrial services ~ '1' ~ . '/ l-,' , 'C 1i ""'l .. >- If) >- I:~ (...: e; -~ ,.. -- \Us: - .::> ~;~ ~. :t.: .~~~ ~":-' 0- .- <i::.. ":\ ;"'.J ,'~ C' 0 _'-~ff) ~31~ c-.: ",~: :,(.'5 ~l', -' ,..,11 .C. :::' .~~O- -, ,. ,., r.> :;-;> CJ U' (.) , v '-" Kathy Lynn Miller. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs, : NO. 94-239 CIVIL TERM Charles Edgar Miller, Jr., Defendant : PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, this 2.J. day of~~ f ~9, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on July 29. 1999, at 3:45 p.m. by this Court's Order of July 20, 1999, is hereby continued generally. This Order is entered without prejudice to either party to request a hearing, The Temporary Protection From Abuse Order shall remain in effect for a period of one year from the date it was entered. through July 20, 2000, or until further Order of Court, whichever comes first. A certified copy of this Order for Continuance shall be provided to the Carlisle Police Department by Plaintiff's attorney. By the Court. cA. Joan Carey /') LEGAL SERVICES, INC. I..<)f / t s P E" 1Z..su..J ~.l (~I ~ ur...) Attorney for Plaintiff f '." i ~" , " ~~ D r ~ fr; " " ,.. i\jl ~~: II:: C~.t ;'~C'l\'.\~ I'~}. 'f-." . ~'" ;11 I". ,'\ Kathy Lynn Miller, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA vs. : NO. 94-239 CIVIL TERM Charles Edgar Miller, Jr., Defendant : PROTECTION FROM ABUSE MOTJON FOR CONTINUANCE Plaintiff, Kathy Lynn Miller. by and through her attorney, Joan Carey of Legal Services, Inc., moves the Court for an Order continuing generally the hearing in the above-eaptioned ease on the grounds that: 1. A Temporary Protection From Abuse Order was issued by this Court on July 20, 1999, scheduling a hearing for July 29, 1999, at 3 :45 p.m. 2. The Cumberland County Sheriff's Department deputized the Dauphin County Sheriff's Department, whose deputies attempted to serve Defendant with a certified copy of the Temporary Protection From Abuse Order and Petition for Protection From Abuse at his residence several times without success and were finally advised by a woman in the apartment building that he had vaeated his apartment and that the utilities had been shut off. 3. Plaintiffrcquests that the hearing scheduled in this case on July 29, 1999, be continued generally until Defendant ean be loeated and served, 4. Plaintiffrcquests that the Temporary Protection From Abuse Order remain in effect for a period of one year from the date it was entered. through July 20, 2000, or until further Order of Court, whichever comes first. S. A certified copy of the Order for Continuance will be delivered to the Carlisle Police Respectfully submitted, Department by the attorney for Plaintiff. WHEREFORE, 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 one year from the date it was entered, through July 20, 2000, or until further Order of Court, whichever comes first. LEGAL SERVICES, INC. 8 Irvine Row Carlisle, PA 17013 (717) 243-9400 01121/99 WED 07:12 FAX 717 240 6573 CUMB CO I'ROTlIONOTARY 9 'J. .).3? raJOOI ..................... ... TX REPORT ... ..................... TRAN5MISSION OK TX/RX NO CONNECTION TIll. CONNECTION ID ST. TIME USAGE T PGS. RESUI.T 1359 92490779 07/21 07:05 07'11 16 OK . SHERIFF'S RETURN - OUT OF COUNTY CASE NO: 1994-00239 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MILLER KATHY L VS. MILLER CHARLE3 E JR R. Thomas Kline , Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named defendant, to wit: MILLER CHARLES E JR but was unable to locate Him in his bailiwick. He therefore deputized the sheriff of DAUPHIN to serve the within PROTECTION FROM ABUSE County, Pennsylvania. On October , this office was in receipt of Pennsylvania. 1st, 1999 the attached return from DAUPHIN County, Sheriff's Costs: Docketing Out of County Surcharge Dep. Dauphin Co 18.00 9.00 8.00 25.50 So an~.L ~., ~mas KlinA f $bU.:>U 10/01/1999 Sworn and subscribed to before me this I <JJ- day of ffJa; 1..... .. 19 tfrt A.D. -\ ( 1~7t.A- f\r )l~~o~ It'i .! roc a @ttite of tlp~ ~4~riff 1: Ralph G. McAllister Clllefl)epuly f\lary Jane Snyder Real Est"le 1J.:l1'ly William T. Tully Solicilor Michael W. Rinehart Assislanl Chief Do:puty D:llIphin COUllly Harrisburg. Pcnn~'lnlllia 17 III I ph: (717) 255.26611 I.X: (717) 255-2889 Jack Lotwick Sheriff Commonwealth of Pennsylvania MILLER KATHY LYNN vs County of Dauphin : MILLER CHARLES EDGAR JR Sheriff's Return No. 1579-T - -1999 OTHER COUNTY NO. 94-239 I, Jack Lotwick, Sheriff of the County of Dauphin, State of Pennsylvania, do hereby certify and return, that I made diligent search and inquiry for MILLER CHARLES EDGAR JR the DEFENDANT named in the within PROTECTION FROM ABUSE and that I am unable to find him/her in the County of Dauphin, and therefore return same NOT FOUND, September 28, 1999 RETURNED NOT FOUND ON 07-27-99. this 28TH day O;rsfPTEMBER, 1999 ~. l f)0AMu0 j'fp Sworn and subscribed to before me Sheriff of Dauphin County, Pa. PROTHONOTARY By Deputy Sheriff Sheriff's Costs: $0.00 PO 00/00/0000 RePT NO