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HomeMy WebLinkAbout94-00262 :; ,.... E V) , '" ~\ \ / 'j- ~' ~. Q-l --I i i I i Ji . i I , . . ~'~~~~'~-'~'~-~--~-*----)"~'~~::~~~'-~:~~ $ - - ~ ~ ^ ~ ~ ~.; ~ a ~.' ~ ~ :. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY STATE OF ~ PENNA, ~ .~ ~ ,., ~ $ ~ ~ ~ ~~ oS * ,;, ~ ~ '.' .', ~ ~ i '.' .', * !I ,;, ~ 8 , ~ ~ .:" " ~ ~,~ ,', ~ ,', ~ *. ',' ~ ~ ',' ~ ... ~ ... (~ )':' ?~ ~ ',' ~ By Hc lX: d cJLr.(~, !~ Allcst:J '.>14~IId.. ['. ~,~~...~).J. .~ ~"~l K ~ ~ -:t.. ~ ~., - - ,---/ ~(---..--._- _...,__.____...._____..o... 0 '.0__"" o. .~ ~~~*-*~**--***----*---*~--*~-~. w ~, i :~ ~ ..' t..~ ~ LINDA L. SMITH 'I ............ '! N ll. .........~.~.?..~.~yl~""""..,.... 19 94 .', ~ i ~.~ --.......... 'I w .... Vel'511S ~ ~.' GREGDRYLSMITH.. ~ '.' ,.; :, i. i ,~ a ',' DECREE IN DIVORCE j '.' ,.'~ * ~ ,'~ ,; ~ ~ ~ i ..' AND NOW, ,. oop~~~Io,~oo ')oooooo. 19 .&J. '!oo. it is ordered and decreed that '" .L.i.n,d,a, ,L", ,S,mi,t,h. . , , , . . . . , , , , . , , , , , , . , , . . , . , , . ". plaintiff, and,.,.. ,Gr.egor.y.L. .Smith",oo.oo,.....,....oo,.oo...",oooo, defendant, are divorced from the bonds of matrimony. i '.' ..' ~ i ~.' The court retoins jurisdiction of the following claims which have been raised of record in this action for which a final order has not yet been entered; ~ ". ~ i ... ., ,. ,. ,.,'~,., ,..........,.,.,...,."".,. ,."" ..".. ,." ,.., .., ,.., ...." ~ ~.4 Prothonotary ~ ,,' ~ f.' * '.' * .~ ~ :p- I' i.,. I~ >1~C! ~~ ~ o//~?9y ,..t. LINDA L. SMITH, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 262 CIVIL 1994 GREGORY L. SMITH, CIVIL ACTION - LAW Defendant In Divorce PRAECIPE TO TRANSMIT RECORD TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please transmit the record, togather with the following Information, to the Court for the entry of a Decree in Divorce: 1. The ground for divorce is irretrievable breakdown under Section 3301 Ic) of the Divorce Code. 2. Date and manner of service of the Complaint: By an Affidavit of Service executed by Gregory L. Smith, Defendant on February 2, 1994. 3. Date of execution of the Affidavit of Consent required by Section 3301 Ie) of the Divorce Code: The Plaintiff executed her Affidavit of Consent on November 18, 1994 and the Defendant executed his Affidavit of Consent on November 22, 1994. 4. . . There are no related claims pending. 5. Date and manner of service of the notice of intention to file Praecipe to Transmit Record: Not applicable. Respectfully Submitted, Date J 1- :<9 -tif /HANDt;Ft~N..~ IENER (' L. .____ ~ !. , .- By W. Scott Hennin ,Esq. 1.0. #32298 319 Market .Street P.O. Box 1177 Harrisburg, PA 17108 (717) 238-2000 Attorney for Plaintiff "'='" 0") - :';;>- ::~; to j , ~ . ...~ "..:0 .~: '_';.,:,," ~C,U4t ,") ~:. :".2 ~., "' ~ r0- C ":I" = p'') ,.. "" -- - .~. ~ , " LINDA L. SMITH, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. J.fD;). Clv.-I 1'1'1Y GREGORY L. SMITH, Defendant CIVIL ACTION - LAW IN DIVORCE NOTICE TO DEFEND AND CLAIM RIGHTS You have been sued In court. If you wish to defend against the claims set forth In the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for the divorce Is indignities or Irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available at the Office of the Prothonotary at CUMBERLAND COUNTY COURTHOUSE. CARLISLE. PENNSYLVANIA 17103. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. 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. Cumberland County Court Administrator Fourth Floor Cumberland County Courthouse Carlisle, PA 17013 Telephone (717) 240-6200 HANDLER AND WIENER By: W. Scott Hennin ATTORNEY FOR INTJ F 319 Market Street, .alB /. Harrisburg, Pennsylvania 17108 Supreme Court 10#32298 v, NO. d.wJ (,'V. I 1111/ LINDA L, SMITH, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff GREGORY L. SMITH, Defendant : CIVIL ACTION - LAW IN DIVORCE COMPLAINT IN DIVORCE 1. The Plaintiff Is Linda L. Smith, an adult individual who currently resides at 625 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania 17043. 2, The Defendant Is Gregory L. Smith, an adult Individual who currently resides at 625 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania 17043. 3. Plaintiff and Defendant have resided In the Commonwealth of Pennsylvania for at least six (6) months immediately previous to the commencement of this action and are citizens of the United States. 4. The Plaintiff and Defendant were married on August 25, 1977, In New Cumberland, Pennsylvania. 5. There have been no prior actions of divorce or for annulment between the parties In this or any other jurisdiction. . 6, The Plaintiff has been advised of the availability of counseling and has been advised that she may have the right to request the Court to require the parties to participate In counseling, 7. The marriage is Irretrievably broken. WHEREFORE, Plaintiff requests the Court to Enter a Decree of Divorce pursuant to Section 3301 (c) of the Divorce Code. COUNT 1 (Request for divorce under Section 3301 (a) of the Divorce Code) 8. Paragraphs 1 through 7 are Incorporated herein by reference thereto. 9. Defendant, Gregory L. Smith, has offered such indignities to Plaintiff, the Innocent and Injured spouse, so as to render the Plaintiff's condition Intolerable and life burdensome. WHEREFORE, Plaintiff requests the Court to enter a Decree of Divorce pursuant to Section 3301 (a) of the Divorce Code. HANDLER AND WIENER 2 Date 1-' <; - 9 t/ ~N.-~ y. ~nuf 0 LINDA L. SMITH, lalntiff I verify that the statements made In this Complaint In Divorce are true and correct to the best of my knowledge, Information and belief. I understand that false statement are made herein subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. 3 -=r ~ $ 11 ~ , ., , :>:: c_ .... .... '" ~ 1"-' .~ r... c~'-J ~4 ..... -::: ..-. . Ie 01) 0 .~ ~I,,) -- 1; 0.: <"J .~~ I : . ' ,.. ..$) - \.IQ ~ f'- t"') \ .;:) v.:. ::r- ~ t ;; *- Q ~ \') ,~ - '--' 'ooJ ,~ .~ ~ ........ l'b 0: 1&1 Z 1&1 ~ t ~ .,. ~ e ~ O.li !; .. ;; tZ"~-Q..~O o .... W " . "'" II" a: c a:,::) ~a:~q=F: 1&1 01 Q. i E oJ - · o I'l ~ Z <( J: I I .' 'H ""',f~ ,~=.~. , SHERIFF'S HE'J'lJRN COolMONWEAL111 or PENNSYINANIA: COUNTY OF' CLMBERLAND In The Court of Common Pleas of Cumberland County, Pennsylvania NO, 262 Civil Term 1994 Temporary Protective Order Petition For Relief Under the Protection From Abuse Act Linda L, Smi th VS Gregory L, Smi th Timothy Reitz , l;K<<JKWfXi$Jl( Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, that he served the within Tern orary Under the upon Greqory L, Smith for Relief 0' clock P .M, EST / IlID5lIX on the 28 day of January , 19 94 at 625 Hummel Ave" Lemoyne . Cumberland County, Pennsylvania, by handing to Gregory L, Smi th a true and attested copy of the Temporary Under the and at the same time directing his Protective Order Petition for Relief , Protect~on trom Aouse ACt attention to the contents thereof and the "Notice to Plead" endorsed thereon. Sheriff's Costs: Docketing Service Affidavit Surcharge So answers: ..........,/,c/ /~# ?'~ J::!;5.,yX'~<< 1 ~...e' R. Thanas Kline, Sheriff 14,00 8,96 2.00 24,96 Pd. by Atty, 1-31-94 by 1 i;ii(- ~ Deputy S eriff . Sworn and subscribed to before rre this 3 old. day of l...JJ,<.<.....y 'i'1 A.D. 19 (,. j'"....... 0 nl';:rL~ ~.I., , I r. Prothonotary ... LINDA L. SMITH, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Petitioner v. NO. 262 Civil 1994 GREGORY L. SMITH, CIVIL ACTION - LAW IN ASSUMPSIT Respondent AFFIDAVIT OF SERVICE On the 2nd day of February, 1994, I hereby certify that a true and correct copy of Plaintiff's Complaint in Divorce containing Notice to Defend and Claim Rights was " serve~_upon Defendant, Gregory L. Smith, by return receipt requested, restricted .. ' delivery at 625 Hummel Avenue, Lemoyne, Pennsylvania 17043. The green certified return~receipt card is attached hereto as Exhibit" A" . I verify that the statements made in this Affidavit are true and correct. understand that false statements herein are made subject to the penalties of 18 Pa.C.S. ~4904 relating to unsworn falsification to authorities. HANDLER AND WIENER Date: 'J,-7-9Y By W co nnlng squire A orney 1.0. # 298 319 Market reet P.O. Box 1177 Harrisburg, PA 17108 (717) 234-8031 ATTORNEY FOR PLAINTIFF ":2- S" ?;,.. o' ... O&J~.,r-: :.,>c.. ,..t I~~t,:....: :~. .":::c ~: :r ~ .::. . ~.;.... .; ':'i;dil _ ../0_;;: -. 1::~I&.. ,-..;;;:~ ..."" 00 E o rY> ...... - CI::I m t..o:: .. ... *u~ . .',~;i:.:" . Exhibit" A" I ;'.;>~<:';.tf~,~ d!; - ~.... .~+( '''; ..., ~~, ,.r r IL>..)f'i: :":',f~j E: o ".. '" - 0;) '.; .l;'tM 1- ;:!-...... ......::.:1 t;. <..~ "" ~ ( ( { ( ) \ , ~- , .,_':~;-:1:;- - pd\pr.\.ppe.~..nt " LINDA L. SMITH, . IN THE COURT OF COMMON PLEAS OF . Plaintiff I CUMBERLAND COUNTY, PENNSYLVANIA I v. . NO. 262 CIVIL 1994 . . . GREGORY L. SMITH, I CIVIL ACTION LAW Defendant . IN DIVORCE . ENTRY OF APPEARANCE Please enter our appearance on behalf of the defendant, Gregory L. Smith, in the above captioned matter. ST(E-LaFAVER t ne, Esquire .0. No. 39785 414 Bridge Street, P.O. Box E New Cumberland, PA 17070 Telephone I (717) 774-7435 - ,"f B ':r" C70 . >-.. ~... ...;e ""t")-;;J-t (.)z(,;,;;';' ~OQ~ \...:Z:o>- 0.- 7!'-J : -r, _I >- ',,' ,~:' jy1 ... .-._5.;z , "jU.,IZ ...,....')14.1 "::tu.. I..~ o ::c' 0... ~ .-t C") -:r <"J a= ~ LINDA L. SMITH, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 262 CIVIL 1994 GREGORY L. SMITH, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 21, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the filing of the Complaint. 3. I have been advised of the availability of marriage counseling and have agreed to waive the same. 4. I understand that I may lose rights concerning alimony, division of property;lawyer's fees or expenses if I do not claim them before a divorce Is granted. 5. I consent to the entry of a Final Decree of Divorce. I verify that the statements made in this Affidavit of Consent are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~4904 relating to unsworn falsification to authorities. Date:--rlNM1l1/IlIL,g ,qq1 ~l1dA.AY . j(\\. 1*'" LINDA L. SMITH Plaintiff -=- ...." - :c:: C'... .... o. -:r "'.,... ~...: .' ..: \.J f ", ", ~ ''''-'. ~' -:"";-..,"-"". ;.'; c::> C"'"'I ... c:> -- - LINDA L. SMITH, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff v. NO. 262 CIVIL 1994 GREGORY L. SMITH, Defendant CIVIL ACTION - LAW IN DIVORCE AFFIDAVIT OF CONSENT 1. A Compleint in Divorce under Section 3301 (c) of the Divorce Code was filed on January 21, 1994. 2. The marriage of Plaintiff and Defendant is irretrievably broken and ninety (90) days have elapsed from the filing of the Complaint. 3. I have been advised of the availability of marriage counseling and have agreed to waive the same. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses If I do not claim them before a divorce Is granted. 5. I consent to the entry of a Final Decree of Divorce. I verify that the statements made In this Affidavit of Consent are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. ~490: relating to unswo:~.fa:?~atlon to ~~jri,~,. Date: 11l.~ ;!;t...' >.....:JUL, (L 04' GRE~O . L. SMITH Defend nt "::I'" en . ~... .,:~ .t '~, ,. '-,~..I'" .:c l~ '~~:~ -;. .'- ':,r, = C._ ..... <:) -:r Cl cry ,.. :fa j .~~~~ .~ -. C't.':. , , LINDA L. SMITH, petitioner IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW PROTECTION FROM ABUSE 262 CIVIL 1994 v. GREGORY L, SMITH, Respondent IN RE: PROTECTION FROM ABUSE ORDER OF COURT AND NOW, this 4th day of February, 1994, upon consideration of the Petition for Relief Under the Protection From Abuse Act, and upon agreement reached in open court between the Petitioner, Linda L, Smith, represented by W, Scott Henning, Esquire, and the Respondent, Gregory L. smith, it is ordered and directed as follows: 1, The Respondent, Gregory L, smith, is directed and prohibited from abusing or harassing the Petitioner or otherwise having any contact with the Petitioner, including any telephone contact, unless the same is related to issues involving the parties' minor children, 2, The Respondent, Gregory L, Smith, is directed to remain away from the Petitioner's residence located at 177 Cedar Lane, carlisle, Cumberland county, Pennsylvania, and any other residence at which she may reside, and her place of employment, the Department of Education, 333 Market street, Harrisburg, Dauphin county, Pennsylvania, 3, A true and correct copy of this Order shall be sent by Petitioner's counsel by certified mail, return receipt requested, to the Middlesex Township Police Department and the city Qf Harrisburg Police Department, which shall have appropriate jurisdiction to enforce this Order. 4, Respondent is directed to allow Petitioner to j,- ~. , ~~J;.,::_,-,; FE~ 8 2 29 f'H '9~ >.d.tCt I't . YHV;ru.y 1:;Uf..~~; :\") r-i,. ;ll '''.;I:!;; . '.,q".,\ ............~~<_...,. ... peacefully retrieve her personal possessions from the residence located at 625 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania, with the aid of a local law enforcement officer, said officer to be compensated, if compensation is required, by Respondent, This Order shall be enforced by any law enforcement agency in any county where a violation has occurred. An arrest for violation of this Order may be made without warrant upon probable cause whether or not the violation is committed in the presence of a police officer, 23 Pa,C.S section 6113(a), Prosecution for indirect criminal contempt shall not preclude prosecution for underlying criminal charges, Should the Court find that Respondent has violated one or more provisions of this Order, he will be adjudged guilty of indirect criminal contempt and may be sentenced to pay a fine of up to one thousand dollars ($1000.00) and serve a jail sentence of up to six (6) months and may include other relief, This Order shall remain in full force and effect for the period of one year from the date of its entry, By the Court, W, SCOTT HENNING, ESQUIRE For the Petitioner J Wesley 01 CI>1'-\. """:"..c<<<. .:).jcr /'1 t{ . (f A.>' wcy C4~ ~c...{. -:k- R"lI",,-'&",.:t .A. I ~/c;'i . ..... <? ,.' . 4 . LINDA L. SMITH, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Petitioner v. NO. 262 Civil 1994 GREGORY L. SMITH, CIVIL ACTION - LAW IN ASSUMPSIT Respondent TEMPORARY PROTECTIVE ORDER AND NOW, this ~ ~ay of J? n ..., ")..Ii ' 1994, It Is hereby ordered that: 1. A Hearing will be held on the II~,( day of tk(~ v 'A '<'J' 1994 at ~ ...&...m. In Courtroom No. . ,; , Cumberland County Courthouse, One -. Courthouse Square, Carlisle, Pennsylvania pertinent to the foregoing Petition for Relief under the Protection from Abuse Act. 2. The Respondent, Gregory L. Smith Is directed and prohibited from abusing or harassing the Petitioner or otherwise having any contact with the Petitioner, Including any telephone contact. 3. The Respondent, Gregory L. Smith Is directed to remain away from the Petitioner's residence located at 177 Cedar Lane, Carlisle, Cumberland County, Pennsylvania and place of employment located at the Department of Education, 333 Market Street, Harrisburg, Dauphin County, Pennsylvania. 4. A copy of this Order and Petition shall be served on the Respondent by the Sheriff. A true and correct copy of the Order shall likewise be sent by certified mail, return receipt requested to the Middlesex Township Police Department and City of Harrisburg Police Department which shall have appropriate jurisdiction to enforce this Order. ,(//1.(( r:--'/' >---, -/', L /, ;t-<.~ d 'I,; '7 /-/'1 BY THE COURT: ~ /'(;0-, [(j elf . J. VI:.? . JAH 27 II 33 AH '9~ . -'. I fIG! Of IH: ,I" I 'ION. r~~y CUkL<;c ~!.:J c; . d r Pl ti,i-f!jf~. ;;~~;'I.~ LINDA L. SMITH, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Petitioner v. NO. 262 Civil 1994 GREGORY L. SMITH, CIVIL ACTION - LAW IN ASSUMPSIT Respondent PETITION FOR RELIEF UNDER THE PROTECTION FROM ABUSE ACT TO THE HONORABLE JUDGES OF SAID COURT: The Petition of Linda L. Smith, by and through her attorneys, Handler and Wiener, respectfully represents as follows: 1. The Petitioner, Linda L. Smith, Is an adult Individual residing at 177 Cedar Lane, Carlisle, Cumberland County, Pennsylvania. The Petitioner brings this action on behalf of herself. 2. The Respondent, Gregory L. Smith, Is an adult Individual whose current address is 625 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania. 3. The Petitioner and Respondent are husband and wife, having been married on August 25, 1977. 4. The Petitioner and Respondent have been separated since January 15, 1994. A Divorce Action was instituted by Petitioner in the Court of Common Pleas for Cumberland County on January 21, 1994. (Docket No. 262 Civil 19941 5. On January 24, 1994, Respondent has followed your Petitioner to her doctor's office and when the vehicle In which Petitioner was riding pulled away, Respondent chased Petitioner's vehicle. Respondent subsequently pulled In front of Petitioner's vehicle, stopped his vehicle, jumped out of his vehicle and accosted the vehicle In which Petitioner was riding by kicking the vehicle, and pounding his fists on the window. All during this time Respondent, who was totally out of control, made threatening statements and gestures to the Petitioner which placed her In fear of serious bodily harm. The Petitioner reported this Incident to the Lower Allen Township pollee. 6. The Respondent has abused Petitioner In the past and has put your Petitioner In fear for her health, safety and life. WHEREFORE, the Petitioner respectfully prays for the entry of a Protection Order granting the following relief: (al Directing the Respondent to refrain from physically or mentally abusing or harassing the Petitioner, including telephone and personal contact at either Petitioner's place of residence or place of employment. (bl Directing that the Respondent is to remain away from the premises at 177 Cedar Lane, Carlisle, Cumberland County, Pennsylvania, and any subsequent address at which she may reside, and her place of employment, the Department of Education, 333 Market Street, Harrisburg, Dauphin County, Pennsylvania. Respectfully Submitted, HANDLER AND WIENER '- By W. Scott Hen n 1.0.#3229 319 Market Street P.O. Box 1177 Harrisburg, PA 1 108 (7171234-8031 Attorney for Plaintiff -2- .~ I'-'''''-~.'' - -- ..._ I verify that the statements made in this Petition for Relief Under the Protection From Abuse Act are true and correct to the best of my knowledge, Information and belief. I understand that false statements made herein are subject to the penalties of 18 Pa.C.S. t4904 relating to unsworn falsification to authorities. Date /-J~ ~9l./ ,YLY1da. V ~;;j, "- Linda L. Smith -3- t VJ ... ~ , ~ I \:i ..... \1f :l- I.., ... CJ IQ .. II l., 11\ \\ ~ .~ ~~ a: III Z III .. -.. 0 ::!: tl E :O~S:~S- ~Zt:i~.; o .c(; . g ja:~~;~ I&J m ~ ..JM ~ a Z <( :I: JAN 26 1994 i, . LINDA L. SMITH, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Petitioner v. NO. 262 CIVIL 1994 GREGORY L. SMITH, CIVIL ACTION - LAW IN ASSUMPSIT Respondent PROTECTIVE ORDER AND NOW, this _ day of , 19_, upon presentation and consideration of the within Petition and upon finding that the Petitioner, Linda L. Smith, is in immediate and present danger of abuse from the Respondent, Gregory L. Smith, the following Protective Order is entered: 1 . . The Respondent Gregory L. Smith is directed and prohibited from abusing or harassing the Petitioner or otherwise having any contact with the Petitioner, Including any telephone contact, unless the same is related to Issues involving the parties' minor children. 2. The Respondent Gregory L. Smith Is directed to remain away from the Petitioner's residence located at 177 Cedar Lane, Carlisle, Cumberland County, Pennsylvania and any other residence at which she may reside and her place of employment, the Department of Education, 333 Market Street, Harrisburg, Dauphin County, Pennsylvania. ~ 3. A true and correct copy of the Order shall be sent by certified mail, return receipt requested to the Middlesex Township Pollee Department and the City of Harrisburg Police Department which shall have appropriate Jurisdiction to enforce this Order. 4. Respondent Is directed to allow Petitioner to peacefully retrieve her personal possessions from the residence located at 625 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania, the aid of a local law enforcement officer, said officer to be compensated, If compensation is required, by Respondent. This Order shall be enforced by any law enforcement agency in any county where a violation has occurred. An arrest for violation of this Order may be without warrant upon probable cause whether or not the violation Is committed In the presence of a police officer. 23 Pa.C.S. ~6113(a). Prosection for Indirect criminal contempt shall not preclude prosection for underlying criminal charges. Should the Court find that Respondent has violated one or more provisions of this Order, he will be adjudged guilty of Indirect criminal contempt and may be sentenced to pay a fine of up to one thousand dollars ($1,000.00) and serve a jail sentence of up to six (6) months and may include other relief. THIS ORDER SHALL REMAIN IN FULL FORCE AND EFFECT FOR A PERIOD OF ONE (1) YEAR FROM THE DATE OF ITS ENTRY. BY THE COURT: J. .. LINDA L. SMITH, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Petitioner v. NO. 262 CIVIL 1994 CIVIL ACTION - LAW IN ASSUMPSIT GREGORY L. SMITH, Respondent PROTECTIVE ORDER AND NOW, this _ day of , 19_, upon presentation and consideration of the within Petition and upon finding that the Petitioner, Linda L. Smith, is in Immediate and present danger of abuse from the Respondent, Gregory L. Smith, the fOllowing Protective Order Is entered: 1. The Respondent Gregory L. Smith is directed and prohibited from abusing or harassing the Petitioner or otherwise having any contact with the Petitioner, Including any telephone contact, unless the same is related to Issues Involving the parties' minor children. 2. The Respondent Gregory L. Smith Is directed to remain away from the Petitioner's residence located at 177 Cedar Lane, Carlisle, Cumberland County, Pennsylvania and any other residence at which she may reside and her place of employment, the Department of Education, 333 Market Street, Harrisburg, Dauphin County, Pennsylvania. '- 3. A true and correct copy of the Order shall be sent by certified mall, return receipt requested to the Middlesex Township Police Department and the City of Harrisburg Police Department which shall have appropriate Jurisdiction to enforce this Order. 4. Respondent Is directed to allow Petitioner to peacefully retrieve her personal possessions from the residence located at 625 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania, the aid of a local law enforcement officer, said officer to be compensated, If compensation is required, by Respondent. This Order shall be enforced by any law enforcement agency In any county where a violation has occurred. An arrest for violation of this Order may be without warrant upon probable cause whether or not the violation is committed in the presence of a pollee officer. 23 Pa.C.S. ~6113(a). Prosection for Indirect criminal contempt shall not preclude prosection for underlying criminal charges. Should the Court find that Respondent has violated one or more provisions of this Order, he will be adjudged guilty of Indirect criminal contempt and may be sentenced to pay a fine of up to one thousand dollars ($1,000.00) and serve a Jail sentence of up to six (6) months and may Include other relief. THIS ORDER SHALL REMAIN IN FULL FORCE AND EFFECT FOR A PERIOD OF ONE (1) YEAR FROM THE DATE OF ITS ENTRY. BY THE COURT: J. LINDA L. SMITH, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Petitioner v. NO. 262 CIVIL 1994 GREGORY L. SMITH, CIVIL ACTION - LAW IN ASSUMPSIT Respondent PROTECTIVE ORDER AND NOW, this _ day of , 19_, upon presentation and consideration of the within Petition and upon finding that the Petitioner, Linda L. Smith, Is in Immediate and present danger of abuse from the Respondent, Gregory L. Smith, the following Protective Order Is entered: 1. The Respondent Gregory L. Smith Is directed and prohibited from abusing or harassing the Petitioner or otherwise having any contact with the Petitioner, Including any telephone contact, unless the same Is related to issues Involving the parties' minor children. 2. The Respondent Gregory L. Smith Is directed to remain away from the Petitioner's residence located at 177 Cedar Lane, Carlisle, Cumberland County, Pennsylvania and any other residence at which she may reside and her place of employment, the Department of Education, 333 Market Street, Harrisburg, Dauphin County, Pennsylvania. 3. A true and correct copy of the Order shall be sent by certified mall, return receipt requested to the Middlesex Township Police Department and the City of Harrisburg Police Department which shall have appropriate Jurisdiction to enforce this Order. 4. Respondent Is directed to allow Petitioner to peacefully retrieve her personal possessions from the residence located at 625 Hummel Avenue, Lemoyne, Cumberland County, Pennsylvania, the aid of a local law enforcement officer, said officer to be compensated, if compensation Is required, by Respondent. This Order shall be enforced by any law enforcement agency In any county where a violation has occurred. An arrest for violation of this Order may be without warrant upon probable cause whether or not the violation Is committed In the presence of a police officer. 23 Pa.C.S. ~6113(a). Prosection for Indirect criminal contempt shall not preclude prosection for underlying criminal charges. Should the Court find that Respondent has violated one or more provisions of this Order, he will be adjudged guilty of Indirect criminal contempt and may be sentenced to pay a fine of up to one thousand dollars ($1,000.00) and serve a jail sentence of up to six (6) months and may Include other relief. THIS ORDER SHALL REMAIN IN FULL FORCE AND EFFECT FOR A PERIOD OF ONE (1) YEAR FROM THE DATE OF ITS ENTRY. BY THE COURT: J. " c LINDA L. SMITH, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA Petitioner v. NO. 262 CIVIL 1994 CIVIL ACTION - LAW IN ASSUMPSIT GREGORY L. SMITH, Respondent PROTECTIVE ORDER AND NOW, this _ day of , 19_, upon presentation and consideration of the within Petition and upon finding that the Petitioner, Linda L. Smith, is in Immediate and present danger of abuse from the Respondent, Gregory L. Smith, the following Protective Order is entered: 1. The Respondent Gregory L. Smith Is directed and prohibited from abusing or harassing the Petitioner or otherwise having any contact with the Petitioner. Including any telephone contact, unless the same Is related to issues Involving the parties' minor children. 2. The Respondent Gregory L. Smith is directed to remain away from the Petitioner's residence located at 177 Cedar Lane, Carlisle, Cumberland County. Pennsylvania and any other residence at which she may reside and her place of employment. the Department of Education, 333 Market Street, Harrisburg, Dauphin County, Pennsylvania. '. ,- 3. A true and correct copy of the Order shall be sent by certified mall, return receipt requested to the Middlesex Township Police Department and the City of Harrisburg Police Depar1ment which shall have appropriate jurisdiction to enforce this Order. 4. Respondent Is dlrec1ed to allow Petitioner 10 peacefully retrieve her personal possessions from the residence located at 625 Hummel Avenue, lemoyne, Cumberland County, Pennsylvania, the aid of a local law enforcement officer, said officer to be compensated, if compensation Is required, by Respondent. This Order shall be enforced by any law enforcement agency In any county where a violation has occurred. An arrest for violation of this Order may be without warrant upon probable cause whether or not the violation Is committed In the presence of a police officer. 23 Pa.C.S. ~6113(a). Prosection for Indirect criminal contempt shall not preclude prosection for underlying criminal charges. Should the Court find that Respondent has violated one or more provisions of this Order, he will be adjudged guilty of Indirect criminal contempt and may be sentenced to pay a fine of up to one thousand dollars ($1,000.00) and serve a jail sentence of up to six (6) months and may include other relief. THIS ORDER SHAll REMAIN IN FUll FORCE AND EFFECT FOR A PERIOD OF ONE (1) YEAR FROM THE DATE OF ITS ENTRY. BY THE COURT: J.