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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'fY, PENNSYLVANIA CIVIL "CTION - LAW NO. CIVIL 1994 No (}LI_ Fill) (iv, I lor~ PROTECTION FROM ABUSE CAROL RIIDI:NBACH l puintiff THOMAS W, REIDENB"CH, Defendant TEMPORARY PROT~CTIVE ORDER AND NOW, this :n- day of March, 1994, upon presentation and consideration of the within Petition, and upon finding that the plaintiff, Carol Reidenbach, now residing at 1925 Esther Drive, carlisle, Cumberland county, pennsyl vallia, and their three minor children are in immediate and present. danger of abuse from the defendant, Thomas W. Reidenbach, the following Temporary Order is entered, The defendant, Thomas w. Reidenbach, now residing at 1925 Esther Drive, Carlisle, Cumberland County, PennsylvanJ.a, is hereby enjoined from physically abusing the plaintiff, Carol Reidenbach, and their three minor children or placing them in fear of abuse and i. excluded from the residence located at 1925 Esther Drive, carlisle, Cumberland county, Pennsylvania, a residence which is owned jointly by the plaintiff and the defendant. The defendant is hereby notified that it he resides in the plaintiff's domicile contrary to this order, he may be in indirect criminal contempt which i. punishable by a fine not to exceed $1,000.00 and/or by a .entenoe of up to six months in jail and any other appropriate punishment. Resumption of co-residence on the part of the plaintiff and defendant ahall not nullify the proviaions of the court order direotinq the defendant to refrain from abusinq the plaintiff and their three minor ohildr~n. The defendant is ordered to refrain from havinq any direct or indireot oontaot with the plaintiff ~nd their three minor ohildren inoludinq, but not limited to, telephone and written oommunioation.. The defendant is enjoined from harassinq and stalkinq the plaintiff and from harassinq the plaintiff's family. The defendant is enjoined from phoninq or enterinq the plaintiff'. plaoe of employment. Thi. Order shall remain in effeot until a final order i. entered in this oase. A hearinq shall (. r'" 1.. .. the "' 1 day of ~~ , 1994, at .- ~" .., No.~, Cumberland County Courthouse, Carlisle, PQnnsylvania. be held on this ~: jo 11m., in matter on Courtroom The Cumberland county Sheriff's Department shall attempt to Il\ake .ervioe at the plaintiff's request, but servioe may be aooompli.hed under any applicable rule of Civil Procedure. The appropriate police departments will be provided with a copy of this Order by the plaintiff's attorney. This Order shall be enrorced by any law enforoement aqency where a violation occurs by arrest for indirect oriminal contempt without warrant upon probable cause that this Order has been violated, whether or not the violation i. committed in the presence of the police offioer. In the event that an arrest is made under this section, the defendant ahall be taken without unnecessary delay before the court that i.aued the order. When that court is unavailable, the defendant ahell be taken before the appropriate diatriot jUatioe. (33 P.S. I 6113). By the court, JudVft , I ., " ,I ',. ,I I , I ;11 I' I I, " ,I , " I' I, )"1 , , , I " " , I , " " " " , d " I,' I v. IN TH~ COURT OF COMMON PLEAS OF CUMB~RLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW "I I CAROL RIXDINBACHi P aintitt THOMAS W. REIDENBACH, DeteneSant NO, CIVIl. 1\194 PROT~CTION FROM ABUSE 110'1'101 You have been .ueeS in court. It you wish to detend again.t the claim. .et forth in the tollowing pages, you must take action promptly after this Petition, Order and Notice are sel'ved, by appearing personally or by attorney at the hearing scheduled by the Court and pre.enting to the Court your de tenses or objections to the claim. .et forth against you. You are warned that it you tail to do .0 the Court may proceed without you, and a judgment may be entereeS against you by the Court without turther notice for any money claimed in the Petition or tor any othor claim or relief reque.ted by the plaintiff. You may lose money or property or other rights important to you. YOU IHOULD TAKI THII 'A'IR TO YOUR LAWYIR AT ONOI. Ir YOU DO MOT KAVI A LAWYll OR CABHOT ArrORD ONI, 00 TO OR TILI'HONI THI OrrICI liT rOITH .ILOW TO rIND OUT WHIRl YOU CAN OIT LIOAL HIL'. COURT ADMINISTRATOR, 4th FLOOR cUMB~RLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER I (717)240-6200 v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW CAROL REIDENBACH1 puintitt THOMAS W. REIDENBACH, Ddendant NO. CIVIL 1994 PROTECTION FROM ABIISE >>ITITIOH rOR PIOTICTIVI QRDIR .ILII' UHDI. TII PIOTICTIOH rROM AIUII ACT, 23 P... . .101 It .eq. A. AIU.I 1. The plaintiff is an aduJ,t individual whose permanent addre.. il 1925 Esther Drive, carlisle, Cumberland CQunty, Pennlylvanla, 17013. 2. The defendant is an adult individual residing at 1925 Either Drive, Carlisle, Cumberland county, Pennsylvania, 17013. 3. The plaintiff and defendant have been living together as hUlband and wife since June 18, 1983. 4. The plaintiff and defendant have three minor children, on. age seven and twins age four. 5. Since approximately 1987, the defendant has attempted to cause and has intentionally, knowingly, or recklessly caused bodily injury to the plaintiff and their three minor children and by phy.ical menace has placed the plaintiff and their three minor ohildren in fear of imminent serious bodily injury. This has inoluded but i. not limited to the following specific instances of abu.el a. on or about March 19, 1994, the defendant went to work taking all of the keys to the house, and cars, the checkbooks, and savings book.. plaintiff went to the bank only to find that defendant had withdrawn all of the money in their aooounts. b. On or about Maroh 18, 1994, the defendant joined plaintiff and her seoretary, Traoi Coon, at the Gingerbread Man in Carli.le, Cumberland County, Pennsylvania, 17013. Defendant bought plaintiff a drink, plaintiff asked defendant to sit down so the ohair would not get taken, defendant did not know if he wanted to .it down, plaintiff told him to makeup his mind so someone olse oould u.e the ohair so it would not get taken. Defendant said, "tine I won't sit down, I'll get the fuck out of here and go home." When plaintiff got home, defendant started to fight with her in front of the kids. Plaintiff said she would not fight with him in front of the children, and oalled her parents to oome and get them. plaintiff's parents refused to oome, so defendant oalled his parsnts, and they came and to get the ohildren. Defendant then asked plaintiff it she wanted a divoroe. Plaintiff said yes, defendant .aid fine. Defendant asked plaintiff who her attorney would be and she replied, Bill Dunoan. Defendant said, tine. De"endant then told plaintiff, you are not going to get the kids, plaintiff replied that she would not let him have them, Defendant then picked plaintiff up and threw her across the kitchen. Defendant then told her to "get out of my house." plaintiff said no and defendant then drug plaintiff across the kitchen, pioked her up and physioally threw her out of the door. Plaintiff oalled her aunt from her van to piok her up and has been staying with her since then. c. Early in the morning, on or about Maroh 18, 1994, the plaintiff called defendant to jump the dead battery in his oar. Defendant showed up in plaintiff's van with both of their daughter.. Defendant oUBsod at plaintiff, plaintiff flipped defendant the finger, defendant then pulled plaintiff out of the oar .haking and yelling at her. plaintiff then drove her van horn., While on the way home plaintiff's daughter said to her, limy dad says your a dumb fuokinq bitch. II d. On or about January, 1994, the plaintiff was stuok in their driveway because of the snow. The defendant kiok.d plaintiff in the leg while wearing steel-toed boots. Plaintiff's .eor.tary, Traci Coon witnessed the bruises from this incident. e. On or About Winter, 1994, Plaintiff and Traci Coon w.nt to happy hour at the Gingerbread Man in Carlisle, Cumberland County, Pennsylvania, Traci's boyfriend called carol's house looking for her, but asked for Carol. Defendant, enraged, called plaintiff at the establishment ordering her to come home right now. plaintiff went home. Traoi called plaintiff'S house to explain reaohing only the son. The son was afraid so Traci oame to the house, Defendant then threatened Traoi Coon. f. On or about January 1, 1993, plaintiff and defendant were to take the ohildren to see plaintiff's grandmother in a nursing home. Defendant began to fight.: with the plaintiff, grabbed the ohildren, took them into the house and locked the plaintiff out. plaintiff broke the screen door to get in to get the ohildren. plaintiff got the children and went to visit her qrandmother. q. on or about Bummer, 1993, Defendant punched his Bon in tht stomach in front of one of son's friends. h. On or about 1993, plaintiff threatened to stab defendant when he WIlS slappin'1 her around to make him stop. He .topped and oalled plaintiff parents ri'1ht away to tell them their daughter tried to atab him. i. On or about 1991 or 1992, Plaintiff had nai'1hbors over for pizza. One of defendant/a two or three year old dau'1hter~ dr.nk half of his glass of lemonade, Defendant went crazy yelling and swearing at the ohild. j. On or about 1987, defendant kicked in the side ot plaintiff's new oar with hia steel-toed boots when she tried to get away from him. k. Defendant/s daughter was upstairs cryin'1 because ahe did not want to '10 to bed, Defendant went upstairs to take care .of her. Plaintiff went up because dau'1hter continued to cry. Plaintiff found daughter with a hand print welt across her bottom. Plaintif1? took the child to show her mother, and told her miniater about it the next day at counselin'1. 1. The defendant has pulled the phone out of the wall when plaintiff has threatened to call the police. m. The defendant has continued to yell and swear at the plaintiff and her three children daily. He grabs and ahakes plaintiff and the children often. 6. The plaintiff believes and therefore avers that she and her three minor children are in present dan'1er of abuse from the defendant and that they are in need of protection from such abu.e. 7. The plaintiff desires that the defendant be prohibited from havinq any direct or indirect contact with the plaintiff and " I their three children inoludin9, but not limited to, telephone and written communications. 8. The plaintiff desires that thlJ detendant be enjoined from hara..inIJ and .talkin9 the plaintiff I and from harassin9 the plaintiff/s relatives. 9. The plaintiff desires that the defendant be restrained t.rom enterinIJ her place of employment. 10. The plaintiff desires that the three minor ohildren be placed in her exolusive care and custody, B. IXCLU8IVI POIII18IO~ 11. The house and property from which the plaintiff i. askinIJ the court to exclude the defendant is owned in the name of both plaintiff and defendant, as husband and wife. a. LOlliS 12. The plaintiff asks for attorney's fees for Duncan' otto, P.c., court costs and filing fees pursuant to the Proteotion from Abuse Act. WHEREFORE, pursuant to the provisions of the "Proteotion from Abu.e Aot" of ootober 7, 1976,23 P,B. S 6101 n U.ll., alS amended, the plaintiff prays this Honorable Court to grant the following relief I A. Grant a Temporary Order pursuant to the IIproteotion from Abu.e Aotl" 1. ordering the defendant to refrain from abusing the plaintiff and their three ohildren or plaoing them in fear of abu.e, I i I i I 2. Orderinq the defendant to refrain from havinq any direot or indireot contact with the plaintiff and their children includinq, but not limited to, telephone and written cOl\llllunioations, 3. ordel:1nq the defendant to refrain from hara.sing the plaintiff's family, ... Prohibiting the defendant fronl entering the plaintiff's place of employment, 6. Orderinq the defendant to st.ay away re.idence located at 1925 Esther Drive, carlisle, County, penn.ylvania, and 6. Orderinq the defendant to stay away from any re.idence the plaintiff may in the future eetablish for herself. B. Schedule a hearinq in accordance with the provisions of the "Protection from Abuse Act," and, after such hearinq, enter an order to be in effect for a period of one yearl 1. Orderinq the defendant to refrain from abusing the plaintiff and their three children or placinq them in fear of abu.. . from the cumberland 2. Ordsring the defendant to refrain from having any direct o. indirect contact with the plaintiff and their ohildren includinq, but not limited to, telephone and written cOl\llllunication.. 3. Orderinq the defendant to refra in from harassing and .talking the plaintiff and from harassing the plaintiff's family. ... Prohibiting the defendant from enterinq the plaintiff'. plaoe of employment. ~. ordering the defendant to stay away from the re.idenoe located at 1925 Esther, Drive, carlisle, Cumberland County, Penn.ylvania. 6. Ordering the defendant to stay away from any re.!dence the plaintiff may in the flJture establish for hereel f . 7. ordering the defendant to pay attorney's fees to Duncan , otto, P.C. The plaintiff further asks that this Petition be f Hed and served, pending further order at the hear,ing, and that certified copie. of this Petition and Order be deliverea to the appropriate police departments with jurisdiotion to enforoe this Or.der. The plaintiff prays for such other relief as may be just and proper. Respectfully submitted, , 1;(' %/ - ~:~l~. M::~~~~~1q~~ Attorney for Plaintiff Duncan' otto, P.C. 1 Irvine Row carlisle, PA 17013 (717) 249-7780 , I I' , HIf~;rlt 10'10' t H JU':'I\JHN ~inl OF P~:NNBVI.vANl^, COOm'Y Of' CLMBERlNID In The Court of Common Pleas of Cumherland County, Pennsylvania No, 94-1410 civil Term Temporary Protective Order Protection From Abuse Notice & Petition Carol Reidonbach VS Thomas W. Reidenbach Robert I.. fink ___, :Mlltlt<f(~if Deputy Sheriff of CUlVJedand County, PennsylvanIa, who boing duly sworn according to law, says, that he served tho within Temporary ProtectIve Order Protection from Abuse Not ice,--PeTi t Ion upon Thomas W. Re iden b,:,.ch __.' tho dofend/mt, at 11145 0 'clock A .M. EST / UlI'I, on the --.---3~~.___ day of ~~}e Aire Drive, Carlis~.~______ March . 19....!:\st , CUmberland County, Pennsylvania, by handing to Thomas Reidenbach a true and attested copy of the Tempornry Protec t ive Order Protec tion F'rpm 1iffiI 8 e -NOl:LC e & P e l:rtnm and at tho Sdll10 timo dirocting his __.__ attention to the contents thereof and the "JIIotice to Ple/ld" ondorsoo thoroon. Sheriff' B Costs I llocketing Service Affidavit Surcharge So Mswqrs}-/ . .-J -~O.p. . ,'-::::-" r 4~~~./":''''-'''''''''' .1'~~.,:::"..~ ( 14.00 2. 80 2.00 18.80 Pd. by Atty. 3-25-94 R. Thanas Klino, Sheriff by~/t:t-c7:rk Deputy Sheriff Sworn and Bubscribcd to before 1m this . ,J'I t! day of Jl1u, 1-- 19 '7'( ^.ll. "P;"I! ..-' 0, lk,tP<>~ ,--O.all:'. I , -t-~ Prothonotary , I I , Ij I. " v.. I IN ~HE COURT OF COMMON PLBAS OF I CUMBBRLAND COUNTY, PENNSYLVANIA I I NO. 94-1410 - CIVIL I I Proteotion From AblJ.. I CAROL REIDENBACH[ Plaintitt THOMAS W. REIDENBACH, Detendant MOTION FOR CONTINUANCE TO THE HONO~BLE GEORGE E. HOFFERI LAW Q'''cu aNII-IAk." . .~INNIM.N AND NOW, oomes the Detendant, Thoma. W. Reidenbaoh, by and through hi. Attorney., snelbaker , Brenneman, P.C., and state. the tollowing in support ot thi. Motionl 1. A hearing i. ourrently .oheduled on thi. matter on the 39th day ot Maroh, 1994 at 9130 A.M. in Courtroom No.3 or 6, cumberland county Court Hou.e, Carli.le, Pennsylvaltia, 3. One ot Detendant'. witn..... tor the hearinq is Renneth Trea.ter, Jr., brother ot the Plaintitt herein. Renneth Treaster, Jr. i. a member ot the Quarryville (Lanoaster county), P.nnsylvania polioe toroe. 3. Renneth Treaet.r, Jr. will be unable to be pre.ent at the hearing ourrently .oheduled in thi. matter. He i. required to attend a preliminary hearing in a pending oriminal. matter in Lanoaster County at 9100 A.M. on Tue.day, Maroh 29, 1994. Ba.ed on intormation and beliet, the preliminary hearing involves tho tran.ter ot a pri.oner trom Gratertord Prison and ha. been oontinued on previou. oooa.ion.. 4. Mr. Trea.ter'. testimony is vital to the r..olution ot this matter. j I'".' 5. D.t.ndant und.r.tand. that it may be n.c....ry to .xtend the temporary proteotive order pur.uant to 23 Pa. C.S. 56107(0) until a hearinq on this matter is held. 6. Coun.el tor Detendant ha. intormed couns.l tor Plaintitt ot the ne.d tor a oontinuanoe in thi. matter. As ot the time ot the preparation ot this Motion, Plaintitt's ooun.el had not yet repli.d to the reque.t tor oontinuance. Due to the time oon.traint. involved, Defendant'. oounsel oould wait no lonqer tor a reply. WHEREFORE, Detendant, Thomas W. Reidenbaoh, r..peottully request. your Honorable Court to order a oontinuanoe ot the hearinq ourrently soheduled tor Maroh 29, 1994 at 9130 A.M. SNELBARER , BRENNEMAN, P.C. BY4~(d,"Y~e. ilip~ . S are 44 W..t Main street Meohanio~bur9' PA 17055~031B (717) 697-8528 Attorney. tor Detendant , , , LAW O,,"CU .NILIAKI" . I~INNIMAN -2- ""j I " 'I Jt' ~r.: " \~ f.... ' ," ~L)C:'.f ,- I.),,,, I, ~ r;~""~ l'l' I,! "'''/'' I " - ..' Jo. ~.J I _,'U . :1' I " ,~' 'II , I :~' ~ ". ,/,, llj./I I ,"\,U .tt,) .\ .. '-~ . " " '1It_, ' "" " " ., .:1 I "1',.11:1/1'1'" " 1"';\,1,1, ,,';,,','.' It.', ,. III :i'-'}{I ','i'" ,1\,' " /-,\1,': , ,I" ',: ,'i, "I I " , I " ',:,' ,,'I " , :\1, .." '" i , 'I , I' " ,:\"1 " , ,I, .,j I ,I I'I ':/ , I, t;' ", " ," I' 1",1 I' " , , " ~, 1"1,,.' ]) J~t " " ,I I 'I, old , " " , " I , i".: '~nl '",," '.1'1:1 ,'!",I 'I ,\;,',1.''.1' . "J' I ".,.r I' 101' !.I, "<lll' .,'. I'." ."1 ,,, 1,1' "'I'I\i,! " "f ,,' ,.,. ')1, "." ',lli,"<,{:I -'I 'I '.I '/', \," ;1/,',.,(, ,','",';'I,"J ',f '\','.':,-'.',,";;\ I, :;',/. " I \ 'I~ ,/,:(\\'t,:'1 ",II "I !'/"'i'l ,I ,."i'; 1 ,.j, .-', ,,"- ~e, - I" ,'-'j ."'1 't,l ')'-III'llfl"il I :" ':,<,l::~,:,;:\,'llf;,~~ '.,' \\" '," ''-oj " ',.' 1"') ,,/ /,;" , 'i_>/j' ,'" -;,\J '. ',> "d , ,~:I ,ll: "I','" ',' i. , " ,'j ';, ,',1 " " r," ',OJ 1.1 "'I , 'j ",,-, .'\c",> ,-"lid,... :""""" , ',. ,d." "'i.'" \'i 'c. ,"1 ~'~r,;(\'ji)~ ,1,',.:;',;1' "! .'.'.'11:' '".oil '.'\'1'1 . "~'I I "'I ',,-'\ I',l' I' "" '.' ~ " ,t " \/t"'\1 ',',,1';' !/, ~ , ), ,,, , , '" ';, "1 I " ). I , . , I , 'I .,' 1-'1' \.': , ., ,'., .J ,'?, ! ,::,1 \ ~ CAROL REIDENBACHi I IN THE COURT OF COMMON PLEAS OF P aintitt I I CUMBERLAND COUNTY, PENNSYLVANIA I v. I CIVIL AC'l'ION - lAW I THOMAS W. REIDENBACH, I NO. 1410 CIVIL 1994 Detendant I I PROTECTION FROM ABUSE 1I010nl TO THE PROTHONOTARY OF CUMBERLAND COUNTY I Plea.. mark the above captioned case discontinued. Thank you, :f~// JttUJ< ~-~ Rachel L. Mensch, Esquire Attorney tor Plaintitt ,I " 'I " I' I, , , " I' , , " " I " .1 , " " " '