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FE8 1,' 1~94~
TAMMY 1. BLACK,
Plaintiff
v,
: IN THB COURT Of COMMON PLEAS OP
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
: PROTnCTlON FROM ABUSE,
: CUSTODY
JEPPREY R. BLACK,
Defendant
: NO, tPSS"CIVIL 1994
TEMPORARY PROTECTIVE ORDER
AND NOW, this .Y ~ay of F('~II,.vl ' 1994 at':~t I.m.,
upon presentation and contlderation of the within Petition, and upon f1ndlna that plaintiff,
Tammy 1. Black, residina in Cumberland County, Pennsylvania, Is In immediate and present
danaer of abUSCI from defendant, Jeffrey R. Black, the followlna Temporary Order is entered.
Defendant, Jeffrey R. Black, Is hereby enjoined from abuslna or harasslna plaintiff,
Tammy J. Black, either personally or through his agents.
Defendant, leffrey R. Black, is hereby ordered to stay away from petitioner's residence
at42~ First Street, Carlisle, Cumberland County, Pennsylvania, her place of employment at 542
South Hanover Street, Carlisle, Cumberland County, Pennsylvania, and at All Thatlazz Dance
Studio at 5660 Hanover Road, Brushtown, York County, Pennsylvania.
Temporary custody of Sarah B. Black, Is hereby awarded to plaintiff, Tammy " Black,
This Order shall remain In effect until pending further order of the court,
You, leffrey R. Black, defendant, have been sued In court to obtain custody of the child.
You are ordered to appear In person at the scheduled hearing held on this matter on the
'j',
. ,J, ./ day of . "~I. " .r.) , 1994 at ': ,) m. In Courtroom No, \ .
Plaintiff may proceed In forma pauperis per-ding a further order after the hear\na.
Service of certified copy of the PeUtlon and this Order ,hall be provided by Ibe Sheriff
of Cumberland County.
The Police Departments of Carlisle and Conewaao will be provided coplOl of Ibl. Order
by attorney for plaintiff, and are directed to enforce this Order by am.t for Indirect criminal
contempt without warrant upon probable cause that this Order has been vlolaltd, whelber or not
Ibe violation I. committed In the presence of the police offlcer, 23 Pa.C.S. 16113. In the event
Ibat an arrest is made under this section, the defendant shall not be taken to jail but .hall be
taken without necessary del a before the Court that 19ued the Ordor. L...J (:/
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TAMMY J. BLACK
Plaintiff'
: IN THE COURT OF COMMON PI.BAS OF
: CUMOllRLAND COUNTY, PENNSYLVANIA
Y.
.
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: CIVIL ACTION. LAW
: PROTECTION FROM ABUSE,
: CUSTODY
JEFFREY R. BLACK,
Defendant
: NO.
CIVIL 1994
PETITION FOR TEMPORARY PRQTECTIVE ORDER
AND CUSTODY
The petlllon of Tammy J, Black res~tfully represents as follows:
COUNT I. PROTEC1'ION FROM ABUSF;
1. Plaintiff Is an adult Individual who resides at 425 First Street, Carlisle,
Cumberland County, Pennsylvania, Plaintiff brlnllS this action for herself.
2. Defendant is an adult Individual who resides at 533 South Hanover Street,
Carlisle, Cumberland County, Pennsylvania.
3. Plaintiff and defendant were married on February 8, 1986. The parties separated
In November of 1993.
4. Plaintiff and defendant are the natural parents of Sarah B. Black, born September
8, 1986.
5. Over the course of their relationship, plaintiff has been placed In fear of imminent
bodily Injury and or death by physical menace and has been subject to infliction of false
Imprisonment. this has Included but Is not limited to the followinlllnstances of abuse:
6. On November 8,1993, plalntlffauempted to leave the family home to go to work.
Defendant attempted to prevent plaintiff from leaving the family home by obstructlnll the doors
and windows of the house. Defendant only permitted plaintiff to leave the house after a1terlna
her vehicle In IORIO manner 10 that il would not start. After neelnll from the house, plaintiff
ran to a public telephone where she called her friend for uslslance, Her friend lOOk her to the
Carlisle police station and the pulice returned with her 10 the family home. Upon their arrival,
the pollee found the defendant hysterically crying with empty bOllle~ of medlcallon nearby along
with a suicide notc. The defendant wu then transported by the ambulance 10 the Carlisle
hospital. The child had been In the house the entire time and therefore witnessed the defendant'.
suicide attempt.
7, On December 12, 1993, the defel)dantshowed up at the Eaale's Club In Hanover
and tried to take Sarah oul of her dance recital. After yelling obscenities and creatlna a scene,
he was escorted from the club. The Hanover police were subsequently contacted and later
ordered him 10 stay away from the plalntlfrs dance studio In Hanover.
8. Since the parties' separation in November 1993, the defendant has repeatedly
made verbalthreata 10 the plaintiff saying he would kill her and anyone around her If she tried
10 divorce him. The lut such threat to kill the plaintiff was made on or about February 1,1994,
On one occasion In October, he grabbed the plalntifrs throat and pushed her up agalnsl a wall
while statlna that "I could just kill you."
9. The defendant hu harassed and continues 10 harass and threaten the plaintiff In
person and on the telephone.
10. Plaintiff believes and therefore avers thaI she will be In Immediate and present
danaer of serious abuse from defendant and that she is In need of protection from abuse.
WHEREFORE, pursuant 10 the provisions of the .Protection From Abuse Act" 23
Pa,C,S. 16101 et aeq., plaintiff prays this Honorable Court to arantthe foilowlna relief:
A. Orant a Temporary Order pursuant to the .Protection From Abuse Act,.
t
I) Requlrlna the defendant to refrain from abu1lna the plaintiff, either
perlOnally or throuah till lIents; and
2) Excludlna Ole defendant from Ole plalntlfrs residence at 425 Firat Street,
Carll,le, Cumberland County, Pennsylvania; her place of employment at 542 South Hanover
Street, Carlisle, Cumberland County, Pennsylvania; and at All That 1azz Dance Studio at 5660
Hanover Road, Brumtown, York County, Pennsylvania; and
3) Preventlna Ole defendant from hamsina and threaten!na the plaintiff In
perlOn or on the telephone.
B. Schedule a hearlna In accordance with Ole provisions of the "Protection From
Abuse Act"; and
C. After such hearlna, enter an order aaainst the defendant, to be in effect for one
year, u follows:
I) Dlrcctlna the defendant to refrain from abuslnathe plaintiff.
2) Prohibltlna the defendant from havina any contact with the plaintiff,
(except for the purpose of exchanllinll custody of the child) Includlnll, but not limited to,
restralnlna the defendant from enterlnll the place of employment or business of the plaintiff and
from hUUllna the plaintiff or plalntlfrs relatives or minor children.
COUNT II. IN FORMA PA\1PERIS
II. The a1leaatlons In paragraphs one throuah ten are Incorporated herein by
reference .
12. Plaintiff does not have funds available to pay the costs of mlna and service.
WHBREFORE, plaintiff prays that the petition be mod and service shall be made
without payment of costa per 23 PIl.C.S. 16106(b).
mid" willi the followlna person.:
riImI Relltlona!)l>>
Sarah B. Black Dauahter
16. 1110 relationship of defendant to the child II thlt of father. The defendant
currently reside. Y/lth tho followlna personl: None
17, Plaintiff has not participated as a party or witness, or In another capacity, In other
litlaalion concernln, tho custody of the child in this or another court.
Plaintiff has no Information of I cUltody proc.cedlna concernlnathe child pendina
In a court of thl. Commonwealth.
Plaintiff dOCl not know of I person not a party tQ the proceedlnas who has
physical custody of the child or claims to have custody or visitation r1t1hts with respect to the
child.
18, At the time of the parties' separation In November of 1993, an Informal verbal
qrccment was reached between the parties arranalna for the child to spend the majority of the
time willi the mother, with partial physical custody In the father In the amount of 3 daYI per
week. This arranaement has brolten down for the following reasons:
a) There has been an Increasing pattern of violent threats against the plaintiff as set
forth In paraaraphl I . 10.
b) Stranle and inexplicable behavior by the defendant indudlna al1eaatlons that the
mother and her friends are conllOrtlnl with the devil.
c) Threats by the defendant that he will not return the child to the plaintlfrs custody.
19. The best Interest and permanent welfare of the child will be served by lrantlnl
the relief rcqueated due to the defendant's conduct as set forth in paraaraphs 1 - 18, and his
Increuln. erratio behavior.
20. Each parent whose parental rlahll to the child have not been terminated and the
penon who hu phyalcal custody of the child have been named II partie. to this action.
WHEREfORE, plaintiff requests the court to:
A. Enter a temporary order alvina her custody of said minor child pendlna
disposition of the petition, per 23 Pa.C.S. 16108(a)(4), and
B. After the hcarlna on this petition, arant plaintiff custody of said child,
Respectfully submitted,
Date 1/0/1t(
Christine O. urat
Certlfled Leaallntem
Jtn11 r1 JP-
THOMAS M, PLACB
LINDA B. FISHER
ROBBRT E. RAINS
Supervlllnl Attorney
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FAMILY LAW CLINIC
4' North Pit! Street
Carlisle, PA 17013
7171243.2968
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COMMONWEALTH OP PENNSYLVANIA
COUNTY OP CUMBERLAND
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: 55.
I verify that the statements made In this Petition are true lU\d correct to the beat of my
perlOnallmowledlo and belief. I understand that false statements herein are made subject 10 the
penalties of 18 Pa.C,S. Section 4904, relatinllO unsworn falsification 10 authodtlea.
Date
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TAMMY J. BLACJ(,
plaintiff
IN THI COURT OF COMMON PLIAS or
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
PROTECTION FROM ABUSE
6!5!5 CIVIL 1994
v.
JEFFRIY R. BLACK,
Oefendant
ORDER OF CO{!RT
AND NOW, thi. 14th day of February, 1994, at
31415 p,m., the Detendant, Jettr.y R. Black, now appearin; in
court in re.pon.e to the Temporary Protective ord.r dat.d this
date at 9145 a.m., and having indicated to the Court and
promi.ed to the Court that he will r.turn the child, Sarah, to
the .heritt'. ottice by 8100 a.m., February 15, 1994, and the
Court having advised the Detendant that the hearing in this
proteotion trom l!Ibuse case will be held on February 22, 1994, at
8145 a.m. in the courthouse, and having turther advi.ed the
Detendant that the Court would conDider a motion trom hi.
coun.el to modity thiB Order, the hearing will be held a.
scheduled, and the Court accepts the promise of the Det.ndant to
return the child at the aforesaid time.
Robert Raine., Esquire
Family Law Clinic
For the Plaintitt
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Jettrey R. Black, pl'O .e
533 S. Hanover Street
cerUIl., PA 17013
SherHt
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IN THIl COURT OF COMMON PLIllA8 0'
CUMallRLJUiD COUNTY, PKNNSYLVANIA
CIVIL ACTION ~ LAW
NO. 655 CIVIL ~ 'Cf\4
TAMMY J. BLACK,
PctUtioner
JJ!lFfRY R. BLACK,
Re.pondent
PROTECTION FROM ABUSB
TEMPORARY PROTECTIVE OR9ER
AND NOW, thh ,;J-day of February, 1994, upon pr..entation and
con.ideration of the within Cro..-Petition For Protective Order,
and upon finding that the Cro..~Petition.r, Jeffry R. alaok, now
re.iding at 533 South Hanover Street, Carli.le, Cumberland County,
penn.ylvania, 1. in immediate and pre.ent danger of abu.e from the
Croa.-Re.pondent, Tammy J. Black, the following Temporary Order i.
entered.
The Cro..-ReBpondent, 'rammy J. Black, who.e ourrent addre.. i.
believed to be 425 Urst Street, CarliBle, Cumberland County,
penn.ylvania, h hereby ,mjoined from physioally abusing the Cro..~
Petitioner, Jeffry R. Black, or placing him in fear of abu.e.
'l'hie Order .hall remain in effect until a final order h
entered in thiB ca.e. A hearing .hall be held on thi. matter on
the 22nd day of February, 1994, at 8.45 a.m. in Courtroom No.5,
Cumberland County Courthouae, Carliale, Ponnaylvania.
The PennBylvania State Police, Carliale Subetation, Sheriff of
Cumberland County, the Di.trict JUBtice of Carli.le, the Carli.le
Police Department, and the Conewago Town.hip Police Department will
be provided with a copy of this Order by attorney a for plaintiff.
Thi. Order .hall be enforced by any law enforcement agenoy where a
violation occur. by arre.t for indirect oriminal contempt without
warrant upon probable caU88 that this Order ha. been violated,
TAMMY J. BLACK,
Potltlo""
IIN THt: COURT OF COMMON PLEAS OF
I CUMBt:RLAND COUNTY, PENNSYLVANIA
n.
I CIVIL, ACTION. LAW
I
I NO. 6l!l! CIVIL 1994
I PETITION FOR PROTECTIVE ORDER
Jt:FFRY R. BLACK,
Rl1spo"",,,t
Q/lDElJ. QE rJl1lllI
NOW. this day of February, 1994. upon cross-petition of Jeffi'y R. Black, Tammy J,
Black Is directed to refrain from abusing, threatening with violence, harassing or visiting JeftTy R,
Black at his residence. his place of employment or in any other public or private place, JeftTy R.
Black is now residing at 53J South Hanover Street, Carlisle, Cumberland County, Pennsylvania
17013, and Tammy J. Black is prohibited from visiting or being in the area of that residence or
any future residence except for the transfer of custody of the parties' minor daughter. Further,
JeftTy R. Black is given exclusive possession of the maritnl home at 533 South Hanover Street,
Carlisle, PA 17013.
Pending the final disposition of the present custody action between the psrtles, flied to No,
649 Civil 1994, the previous order of this Court dated February 14, 1994, Is hereby modified to
provide that Jel1Ty R. Black shall have partial custody of the parties' minor daughter, Sarah B.
Black on Sundays, from 8:00 a,m, until Monday at 8:30 a,m., on Tuesdays, from 3:20 p.m. until
Wednesday at 8:30 a.m, and on Wednesdays, from 3:20 p.m, until Thursday at 8:30 a,m, JeftTy
R, Black will be responsible for transportation of the child and except for Sunday morning, all
pick-ups and returns ot'the child will be at the child's school,
other place In order 10 protect him from contact with respondent, prev"nt further physical abuse
and the threat thereof snd prevenllnjury to him,
10. Jeffi'y R, Black flied a custody action to No, 649 Civil 1994 in this Court which is
pending for conciliation and further disposition by this Court if necessary. He believes and
theref?r avers that this Court should refrain from proceeding on the custody issue presented In
Tammy J. Black's petlllon at this time, in order to permit the normal conciliation process to take
place,
II. However, in the meantime, pending flnal disposition of the custody proceeding, JeftTy
R, Black requires an order providing for temporary partial custody of the parties' minor daushter,
Sarah B, Black, as follows: on Sundays, from 8:00 a,m. until Monday at 8:30 a.m., on
Tuesdays, from 3:20 p.m. until Wednesday at 8:30 a.m, and on Wednesdays, from 3:20 p,m, until
Thursday at 8:30 a,m, Jelfry R. Black will be responsible for transportation of the child and
ellcept for Sunday morning, all pick-ups and returns of the child will be at the child's S(hool.
WHEREFORE, petitioner requests this Court to enter an order providing thst:
a, Tammy J. Black shall refrain tiOnl abusing, threatening with violence, harasslns or
visiting the Jefti'y R. Black in any manner ellcept as necessary to elTect the transfer of custody;
b, Jel1Ty R, Black shall have ellclusive possession of the marital home and Tammy J,
Black shall otherwise be excluded from being in the area of any residence as petitioner shall be
living lTom time to time and from all contact with IeftTy R. Black when he is at his place of
employment or at any other place except as necessary to elTectthe transfer of custody; and
I'
flllf;R I Fl" I H 1lf:'l'lJIlN
L'(~M!I" Of' PENNBYIN/INIA.
CllUtfl'Y 01" CLM1If:RIJlND
VB
In The Court of Common Pleao of
Cumberland County, Pennoylvanla
No. 655 Civil 'rerm 1'194
1'empor;lry Protect. lve Order,
Not.i<:e Ilnd PetHion for Temporary
Protective Order tlnd Custody
1'ammy ,1. Dltwk
Jeffrey R. Blank
llnrr~ f10rn
_~_.' Qt1QXfJl<ll>lt Doputy Sheriff of
ClI1lberland County, Pennsylvania, Who being duly swnm flceording to IflW, eays,
th(lt ho served tho within Tem,F,ortJry Protect i va Order., Notice i1nd PetJ tion
for. 'remporflry pr'otecTTve""(fi-oer'Brio"CLiEifOily
upon _.2!!!J.f!E1.. R. Bulck , the defondilllt, at }JJ"~.__, o'c1cx~k
"~_.M, EST 1lfJ)1'l, on tho ~_i._,__.__ day of J::.obrua.~___, 1994 at
The Carlisle Po.u.ce,JleE!~.....2L~--,~outh EH.!.__.____.' Cunberland County,
Cflrliele
PellnsylvflnifJ, by handing to ,/ e f f!_~J:'..!!.!..!!-':.~_____".______.___
Tcmpornry pr.otecDve Or.der, Notlco and Ptltition
a true and attested copy of thef~Telllporar.y Pr.ote~:tivo Order. & Custody,
aryj at the eallX! timo dir.ect ing hiB
attention to the contente thereof anri
the "Notice to Plead" endorsl..>d thereon.
Sheriff's COStSI
Docketing
Service
Affidavit
Surcharge
So answors I
l4.00
2.80
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R. Th<J1l<1s Kline;' 'h" :ifi' ,",.'
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Sworn and subscribed to before me
Deputy
this ; i ,04{ day of 't/:'OJ."f
19 t/ '( A.D.
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Prothonotary
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: IN THB COURT OF COMMON PLEAS OF
: CUMBBRLAND COUNTY, PBNNSYINANIA
: CIVIL ACTION. LAW
: PROTECTION FROM ABUSB,
: CUSTODY
TAMMY I. BLACK,
Plaintiff
IEFFREY R. BI.ACK,
Defendant
; NO. 6S.!)- CIVIL 1994
l~~PORARY PROT~CTIVE ORDER
AND NOW, this /li*day Of,jiA-wtw;. 1994 at r"6#.:,
upon presentation and consl<!eration of the within Petition, and upon finding that plaintiff,
Tammy I. Black, resldina In Cumberland County, Pennsylvania, is in Immediate and prescnt
danger of abuse from defendant, leffrey R, Black, the followlna Temporary Order Is entered.
Defendant, leffrey R. Black, Is hereby enjoined from abusing or harassing plaintiff,
Tammy I. Black, either personally or through his agents,
DefendBllt, leffrey R. Black, is hereby ordered to 3tay away from petitioner's residence
at42S First Street, Carlisle, Cumberland County, Pennsylvania, her place of employment at S42
South Hanover Street, Carlisle, Cumberland County, Pennsylvania, and at All That lazz Dance
Studio at S660 Hanover Road, Brushtown, York County, Pennsylvania.
Temporary custody of Sarah B. Black, Is hereby awarded'to plaintiff, Tammy I, Black.
This Order shall remaln in effect until pending further order of the court.
You, leffrey R. Black, defendant, have been sued In court to obtain custody of the c~i1d.
You are ordered to appear in rrson at the scheduled hearing held on this matter on the
.).).J.day ofJ~, 1994 a(tJ"~m, in Courtroom No. (
Plaintiff may proceed In forma pauperis pending a further order after the hearing.
Service 01 certified copy 01 tho Petition and this Order ~hall be provided by tho Shorllf
01 Cumberland County.
Tho Police Departments of Carlisle and Conewljo will be provided copies 01 thl. Order
by attorney for plaintlfl, and are directed to enforce this Order by armt lor Indirect criminal
contempt without warrant upon probable cause that this Order has been violated, whether or not
the violation is committed In the presence 01 the police officer, 23 PI.C.S. 16113, In the event
that an arrest Is made under this section, the defendant .han not be taJcen to Jail but shall be
taJcen without necessary delay before the J:ourt that Issued ~e O!der. , . "'.J , ~
(U .w. ~h~ :tW -lk. 1.)ll."i/'4- !f,Vt A-Q, ;i:c fl.hu..~, iT ,(;1Ju
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CAV.I/C. () U By e Court, fJ Q
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TRUE COP\' 'ROM RECORD
In Tsallmony W1lereof, I here onto set my MIIIJ
8M IIle s' ill III said Cr)u I Carllsr., P..
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her vehicle In some manner 50 that It would not start. After fleeing from the house, plaintiff
ran to a public telephone where she cal1ed her friend for assistance. Her friend took her to tho
Carlisle pollee station and the pollee returned with her to the family home, Upon their arrival,
the pollee found the defendant hysterically crying with empty bottles of medication nearby alona
with a suicide note. The defendant was then transportld by the ambulance to the Carlisle
hospital. The child had been In the house the entire time and therefore wltnened the defendant',
suicide attempt,
7. On December 12, 1993, the defendant showed up at the Eagle's Club In Hanover
and tried to take Sarah out of her dance recital. After yelling obscenities and creating a scene,
he was escorted from the club, The Hanover pollee were subsequently contacted and later
ordered him to stay away from the plaintifrs dance studio In Hanover.
8. Since the parties' separation In November 1993, the defendant has repeatedly
made verbal threatJ to the plaintiff saying he would kill her and anyone around her If she tried
to divorce him. The last such threat to kill the plaintiff was made on or about February 1, 1994.
On one occasion In October, he grabbed the plaintifr s throat and pushed her up against a wall
while stating that 'I could just kill you.'
9. The defendant has harassed and CQntinues to harass and threaten the plaintiff In
person and on the telephone,
10. Plaintiff believes and therefore avers that she will be In Immediate and present
danger of serious abuse from defendant and that she is In need of protection from abuse.
WHEREFORE, pursuant to the provisions or the .proter.tion From AbuSCl Act. 23
Pa,C,S. 16101 et seq., plaintiff prays this Honorable Court to grant the fol1owlng relief:
A, Grant a Temporary Order pursuant to thr .Protectlon From Abuse Act,"
1) Rcqulrina Ihc defendant 10 refrain from abuslna the plaintiff, chhcr
personaily or throuah his lIIenll; and
2) Ilxcludlna Ihe defendant from Ihe plalntlfr$ residence at 425 Pirst Slreet,
Carlisle, Cumberland County, Pennsylvania; her place of employment at 542 South Hanover
Street, Carllslc, Cumberland County, Pennsylvania; and at All TIlat Jazz Dance Studio at 5660
Hanover Road, Brushtown, York County, Pennsylvania; and
3) Preventlnalhe defendant from harasslna and thrcatenlna the plaintiff In
person or on the t.elephone,
8, Schedule a hearlnaln accordance with the provisions of the "Protection From
Abuse Act"; and
C, After such hearlna, enter an order against the defendant, to be In effect for one
year, as follows:
I) Dlrectlnathe defendant to refrain from abusing the plaintiff.
2) prohlbltlna the defendant fro,n havlna any contact with the plaintiff,
(except for the purpose of exchanging custody of the child) Including, but not limited 10,
restralnlnglhe defendant from entering the place of employment or business of the pial miff and
from harassing the plaintiff or plaintlfr s relatives or minor children,
.
COUNT II. IN FORMA PAUPERIS
11. The a1lealtlons In paragraphS one through t.en are Incorporated herein by
reference.
12. Plaintiff does not have funds available to pay the costs of filing and service.
WHEREFORE, plaintiff prays that the petition be flled and service shall be made
without payment of COStl per 23 Pa,C.S. 06l06(b).
resides with the followlna persons:
NuIlI Jl~'atlQJlIIhID
Sarah B, Black Dauahter
16, The relationship of defendant to the child Is that of father. The defendant
currently resides with the followlna persons: None
17. Plaintiff has not participated as a party or witness, or in another capacity, In other
Iitlaatlon concemlna the custody of the child In this or another court.
Plaintiff has no Information of a custody proceeding concemlna the child pendlna
In a court of this Common~ealth.
Plaintiff does not know of a person not a party to the proceedillas who has
physical custody of the child or claims to have custody or visitation rlahts with respect to the
child.
18. At the time of the parties' separation in November of 1993, an Informal verbal
aareement WI., reached between the parties arrangina for the child to spend the majority of the
time with the mother, with partial physical custody In the father in the amount of 3 days per
week. this arranaement has broken down for the followlna reason,:
a) There has been an increaslna pattem of vlolen,t threats against the plaintiff as set
forth In paraaraphs I . 10.
b) Strange and Inexplicable behavior by the defendant Including allegations that the
mother and her friends are consorting with the devil.
c) Threats by the defendant that he will not return the child to the plalntlfrs custody.
19. The best Interest and permanent wel fare of the child will be served by granting
the relief rcquealCd due to the defendant's conduct as set forth in para&raphs I - 18, and his
Increasinl erratic behavior,
20. IlaI:h parent whose parental rI&hts to the child have not been terminated and the
person who hu physical custody of the child have been named as parties to this &Ction.
WHEREFORE, plaintiff requests the court to:
A, Enter a temporary order alvina her cuslody of said minor child pendinl
disposition of the petition, per 23 Pa,C.S. 16108(a)(4), and
B. After the hearlnl on this petition, Brant plaintiff custody of said child.
Respectfully submitted,
Date
~/O /ql
f
Christine O. unl
Certified Le&a! Intern
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JIf/II,! f1 \ >f-
THOMAS M. PI-ACE
LINDA E. FISHER
ROBERT E. RAINS
Supervisin~ Attorney
FAMILY LAW CLINIC
45 North Pitt Street
Carlisle, PA 17013
717/243-2968
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COMMONWEALTH OP PENNSYLVANIA
COUNTY OP CUMBBRLAND
~ $$.
I verify that the statements mllde In thit Petition are true and correct to the betl of my
perlOw knowledle and belief. I understand that false statements herein are mlU.le subject to the
penalties of 18 Pa.C.S. Section 4904, relatlnllO unsworn falsiflcation 10 authorltlca.
Date ~}~hr
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TAMMY J. BLACK, I IN THE COURT OF COMMON PLEAS or
P1dntit~ I 'i CUMBERLAND COUNTY, PENNSYLVANIA
I ,r
V. I CIVIL ACTION - LAW
I PROTECTION FROM ABUSE
JErFRY R. BLACK, I
Detendant I 655 CIVIL 1994
IN REI MODIFICATION OF TEMPORARY CUSTODY ORDER
ORDE~ OF COUR~
AND NOW, thi. 22nd day day of February, 1994,
upon aqr..ement reached in open court between the parties and
their respective oounse1 with respect to the custody ot the
parti.s daughter, Sarah, and pending a custody conciliation
conference, it is ordered and decreed as folloWSI
1. Mother and father shall have shared le9a1
custody of Sarah B. Black.
2. Mother and father shall have shared physioal
custody ot Sarah B. Black.
J. Father shall have physical custody ot the
child from 9130 a.m. sunday until he takes her to school on
Monday, and after eohoo1 on Tuesday until ha takes her to school
on Thursday morning.
4. Mother shall have physical custody of the
ohild at all other times.
This Order will remain in effeot until a oustody
conoiliation has been hvld in this case.
v.
rill }j l.a '~\\
iJ~T~E COVRT OF COMMON PLEAS or
CUMBERLAND ~OUNTY, PENNSYLVANIA
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CIVIL ACTION'. LAW
PROTECTION FROM ABUSE
656 CIVIL 1994
TAMMY J. BLACJ(/
FlainU tf
JEFFRY R. BLACK,
Detendl!lnt
ORDER OF COURT
AND NOW, this 22nd day of February, 1994, upon
oondderaUon of the Petition For Proteotion Fl;'oln Abuse and the
croes-Petition For Proteotion From Abus~ filed in the
above-oaptioned matter, and upon agreement of the parties
reaohed in open oourt with their respeotive counsel, it is
ordered, adjudged, and deoreed as followsr
1. Defendant shall not abuse the Plaintiff
either personally or through his agents.
2. Plaintiff shall not abuse the Defendant
either personally or through her agents.
3. Defendant shall not harass the Plaintiff
either personally or through his agents.
4. Plaintiff shall not harass the Defendant
either personally or through her agents.
6. Defendant 1s not to enter or oome within 100
yards of the Plaintiff's residence at 425 First street,
Carlisle, Cumberland County, Pennsylvania, or any future
residenoe ehe may establish. Defendant also shall not enter
Plaintiff'S place of employment at 542 South HanOVer Street,
carlisle, Cumberland cQunty, Pennsylvania. Defendant shall not
come within 100 yard. ot All That Ja~z Dance studio at 6660
Hanover Road, Brushtown, York County, penn.ylvania, except in
the event that the partie.' dauqhter has a dance reoital which
Defendant shall be permitted to attend.
6. Plaintiff shall not enter Defendant'.
residence at 633 South Hanover street, Carlisle, Cumberland
County, Pennsylvania. Plaintiff ehall not enter or come within
100 Yl!lrd. of any future residence Defendant may establish l!Ind/or
his place of employment.
7. Plaintiff and Defendant shall have no contact
exoept as is necessary and in the best interest of the partiel'
child, Sarah B. Black.
The parties are notified that if they violate the
terms of this Order, they will be in indireot criminal oontempt
which is punishable by a fine not to exceed $1000.00 and/or by a
sentence of up to six months in jail and any other appropriate
punishment.
The appropriate polioe department shall be
provided with a oertified oopy of this Order by oounsel in the
case. 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 ha.
been violated, whether or not the violation it committed in the
presence of the police officer. In the event that an arrest i.
made under thl. "Qtlon, the D.f.ndant .h.ll b. tak.n withQu~
unn.c....ry d.l.y b.fore the Court th.t lsQued the Order. When
that Court i. unaval1able, the Defendant .hall be taken b.fore
the appropriate Di.trlct Justloe (23 Pa.C.S. Seotion 6113) .
This Order shall remaln in erreot for a period of
on. year.
By the court,
THOMAS CALABRIA, INTERN
THOMAS M. PLACE, ESQUIRE
family Law clinlo
For the Plaintlff
HAROLD S. IRWIN, III, ESQUIRE
For the Derendant
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