HomeMy WebLinkAbout94-02211
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TONYA MARIE CRUM,
petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
"
v. 94-2211 CIVIL TERM
RICHARD ANTHONY HODGE,
Defendant INDIRECT CRIMINAL CONTEMPT
IN REI APPOINTMENT OF COUNSEL
ORDER OF COURT
AND NOW, this 28th day of March, 1995, upon
consideration of the Defendant's application for the assignment
of counsel, and it appearing that the Public Defender's Office
may have a conflict with respect to this case, Michelle R.
St. Clair, Esquire, is appointed by the Court to represent the
Defendant.
By the Court,
Travis N. Gery, Esquire
Assistant District Attorney
Michelle R. St. Clair, Esquire
Court-appointed Counsel
Court Administrator
CCP
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TONYA MARIE CRUM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
rr')
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 - ~.;lll CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
vs.
RICHARD ANTHONY HODGE,
Defendant
PROTECTIVE ORDER
AND NOW, this ~ day of June, 1994, upon consideration of
the Consent Agreement of the parties, the following Order is
entered:
1. The defendant, RICHARD ANTHONY HODGE, is enjoined from
physically abusing the plaintiff, TONYA MARIE CRUM, or from
placing her in fear of abuse.
2. The defendant, RICHARD ANTHONY HODGE, is enjoined from
having any contact with the plaintiff, except for the purpose of
facilitating visitation, including but not limited to, harassing
or stalking the plaintiff, and harassing the plaintiff's
relatives.
3. The defendant, RICHARD ANTHONY HODGE, is ordered to stay
away from the residence located at 111 North Hanover Street,
Carlisle, Pennsylvania, and from any other residence the
plaintiff may establish for herself in the future, except for the
purpose of facilitating visitation. The defendant shall seek
modification (change) of this Order before living with the
plaintiff in a domicile she may establish for herself in the
future, wherever it may be. 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 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 defendant shall not
nullify the provisions of the Court Order directing the defendant
to refrain from abusing the plaintiff.
4. The defendant is ordered to pay the plaintiff's out-of-
pocket losses which are listed on the "Out-of-Pocket Losses" form
in the amount of $172.10 within 120 days of the entry of this
Order.
5. This Order shall remain in effect for a period of one
year.
6. The Carlisle Police Department will be provided with a
copy of this Order by attorneys for plaintiff and may enforce
this Order 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 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 PS section 6113).
By the Court
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.
TONYA MARIE CRUM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
.
.
CUMBERLAND COUNTY, PENNSYLVANIA
: NO. 94 - ~lJI CIVIL TERM
vs.
PROTECTION FROM ABUSE
AND CUSTODY
RICHARD ANTHONY HODGE,
Defendant
CUSTODY ORDER
AND NOW, this ~ day of June, 1994, upon consideration of
the parties' Consent Agreement, the following custody Order is
entered with regard to custody of the parties'
child, TYSHAWN TYLER HODGE.
1. The plaintiff will have primary physical and legal
custody of the child.
2. The defendant will have visitation with the child at
times and places to be mutually agreed upon by the parties.
3. Neither party shall do anything which may estrange the
child from the other parent, or injure the opinion of the
child as to the other parent or which may hamper the free and
natural development of the child's love or respect for the other
parent.
By the court,
/
~
TONYA MARIE CRUM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 -
CIVIL TERM
vs.
PROTECTION FROM ABUSE
: AND CUSTODY
RICHARD ANTHONY HODGE,
Defendant
.
.
CONSENT AGREEMENT
This Agreement is entered on this
day of June, 1994,
by the plaintiff, TONYA MARIE CRUM, and the defendant, RICHARD
ANTHONY HODGE. The plaintiff is represented by Joan Carey, of
Legal Services, Inc.; the defendant is unrepresented but is aware
of his right to have an attorney. The parties agree that the
following may be entered as an Order of Court.
1. The defendant, RICHARD ANTHONY HODGE, agrees to refrain
from abusing the plaintiff, TONYA MARIE CRUM, or from placing her
in fear of abuse.
2. The defendant agrees not to have any contact with the
plaintiff, except for the purpose of facilitating visitation.
3. The defendant agrees not to harass or stalk the
plaintiff or harass the plaintiff's relatives.
4. The defendant agrees to stay away from the residence
located at 111 North Hanover Street, Carlisle, Pennsylvania,
except for the purpose of facilitating visitation.
5. The defendant agrees to stay away from any residence the
Plaintiff may establish for herself in the future, except for the
purpose of facilitating visitation.
..
6. The defendant agrees to reimburse the plaintiff's out-
of-pocket losses suffered as result of the abuse including but
not limited to the losses listed on the 1I0ut-of-Pocket
Lossesll form in the amount of $172.10 within 120 days of the
entry of this Order.
7. The defendant, although entering into this Agreement,
does not admit the allegations made in this Petition.
B. The defendant understands that the Protective Order
entered in this matter shall be in effect for a period of one
year.
9. The defendant understands that this Order will be
enforceable in the same manner as the Court's prior Temporary
Protective Order entered in this case.
10. The defendant and the plaintiff agree to the entry of
the following custody order regarding their child, Tyshawn Tyler
Hodge:
a. The mother will have primary physical and legal
custody of the child.
b. The father will have visitation with the
child at times and places which are mutually agreed upon
by the parties.
c. The parties realize that their child's well being
is paramount to any differences they might have between
themselves. Therefore, they agree that neither party will
do anything which may estrange the child from the other
parent, or injure the opinion of the child as to the other
..... . ,
parent or which may hamper the free and natural development
of the child's love or respect for the other parent.
WHEREFORE, the parties request that an Order of Court be
entered to reflect the above terms.
Q~ \ ~ m QJi l (If{\
~onya M. Crum, Plaintiff
"-
an Carey
Attorney for Pl
LEGAL SERVICES,
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
AND NOW, this
reDER FOR CONTINUANCE
~ day of May, 1994,
upon consideration of
v.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-2211 CIVIL TERM
TONYA MARIE CRUM,
Plaintiff
RICHARD ANTHONY HODGE,
Defendant
PROTECTION FROM ABUSE
AND CUSTODY
the attached Motion for Continuance, the hearing scheduled for
May 6, 1994, at 8:30 a.m. in Courtroom No.5, is continued until
'/J?a.u ,t)? ,1994, at ,J:3.? ~ .M. The Temporary Protective
Order will remain in effect pending further order of Court.
A copy of this Order for Continuance will be provided to the
Carlisle Police Department by the attorneys for the plaintiff.
By the Court,
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TONY A MARIE CRUM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-2211 CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
v.
RICHARD ANTHONY HODGE,
Defendant
MOTION FOR CONTINUANCE
The plaintiff moves this Court for an Order continuing the
hearing of this case until further Order of Court, on the grounds
that:
1. A Temporary Protective Order was issued by this Court on
the 27th day of May, 1994, scheduling a hearing for the 6th day
of May, 1994, at 8:30 a.m.
2. The Cumberland County Sheriff's Department has attempted
to serve the defendant, but have bee~ unable to effect service.
3. The plaintiff requests that a continuance be entered and
that the Temporary Protective Order remain in effect pending
further order of court.
4. A copy of the Order for Continuance will be delivered to
the Carlisle Police Department by attorneys for the plaintiff.
WHEREFORE, the plaintiff moves this Court to grant the
plaintiff's Motion, and to continue this matter until further
Order of Court.
~ ~cal] C'a tC!~/_
, oan Carey
.
Attorney for Pl intiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle PA 17013
(717) 243-9400
~la'<\,~-'
TONYA MARIE CRUM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-2211 CIVIL TERM
PROTECTION FROM ABUSE
v.
RICHARD ANTHONY HODGE,
Defendant
ORDER FOR CONTINUANC~
AND NOW, this
2f] tf., day of May, 1994, upon cons i derat i on of
the attached Motion for Continuance, the hearing scheduled for May
27, 1994, at 2:30 p.m., in Courtroom No.5 of the Cumberland County
Courthouse, Carlisle, Pennsylvania, has been continued until the
/Ii~'day of 9<.,,10-" ,1994 at 3:co
{J .m.
,
The Temporary Protective Order of April 27, 1994, remains in
effect pending further order of Court.
A copy of this Order for Continuance will be provided to the
Carlisle Police Department by the attorneys for the plaintiff.
By the Court,
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.
"
,
TONYA MARIE CRUM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
v.
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-2211 CIVIL TERM
PROTECTION FROM ABUSE
RICHARD ANTHONY HODGE,
Defendant
MOTION FOR CONTINUANCE
The plaintiff, by and through her attorney, Joan Carey of
Legal Services, Inc. states the following:
1. A Temporary Protective Order was issued by this Court on
the 27th day of April, 1994, scheduling a hearing for the 6th day
of May, 1994. When the defendant had not been served, this Court
granted a continuance until May 27th, 1994 at 2:30 p.m.
2. The Cumberland County Sheriff's Department has attempted
to serve the defendant, but has been unable to effect service.
3. The plaintiff requests that a continuance be entered and
that the Temporary Protective Order remain in effect pending
further order of court.
4. A copy of the Order for Continuance will be delivered to
the Carlisle Police Department by attorneys for the plaintiff.
WHEREFORE, the plaintiff requests that an Order for
Continuance be entered and that pending further Order of Court the
-
..
-, .
Temporary Protective Order remain in effect.
Reepectfully submitted,
. f~
n Carey
,
Attorney for Pl
LEGAL SERVICES,
8 Irvine Row
Carlisle PA 17013
(717) 243-9400
SHERIFF'S RETURN
CCM-lONWEAL'llI OF PENNSYLVANIA:
COUNI'Y OF ClMBERLAND
VS
In The Court of Common Pleas of
Cumberland County, Pennsylvania
No. 94-2211 Civil Term
Temporary Protective Order
Protection From Abuse and Custody
Petition for Protective Order
and Custody
Tonya Marie Crum
Richard Anthony Hodge
Barrv J. Horn
, ~XUltir Deputy Sheriff of
CUmberland County, Pennsylvania, who being duly sworn according to law, says.
Temporary Protective Order Protection From Abuse
that he served the withinand Custody Petition for Protective Order & Custody
upon Richard Anthony Hodqe
, the defendant. at
11: 44
o'clock
A .M. ~~ I EDST, on the
01
day of June
. 19....2...4at
Cumberland County Prison, Claremont Rd.,
Carlisle
Pennsylvania, by handing to Richard Hodge
, CUmberland County,
Temporary Protective Order Protect~on From Abuse
a true and attested copy of the and Custody Petition for Protective Order, &
Custody
and at the same time directing his attention to the contents thereof and
the "Notice to Plead" endorsed thereon.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
14.00
2.80
16.80
So answers:
rfJ~~#-e
R. Thanas Kline. eriff
by
}
Sworn and subscribed to before rre
this <7 tf: day of ~"'~_
19 "1'( A.D.
Deputy Shenff
(~-j~,-,- c.. 'llI..d.C.-, ~ '
Prothonotary
TONYA MARIE CRUM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 - dlJ.Jl CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
.
.
.
.
vs.
RICHARD ANTHONY HODGE,
Defendant
.
.
.
.
TEMPORARY PROTECTIVE ORDER
AND NOW, this ~~day of April, 1994, upon presentation
and consideration of the within Petition, and upon finding that
the plaintiff, TONYA MARIE CRUM, now residing at 111 North
Hanover street, Apt. 2, Carlisle, Cumberland County,
Pennsylvania, is in immediate and present danger of abuse from
the defendant, RICHARD ANTHONY HODGE, the following Temporary
Order is entered.
The defendant, RICHARD ANTHONY HODGE, now residing at 152
West North Street, Carlisle, Cumberland County, Pennsylvania, is
hereby enjoined from physically abusing the plaintiff, TONYA
MARIE CRUM, or placing her in fear of abuse and is ordered to
stay away from the residence located at 111 North Hanover street,
Carlisle, Cumberland County, Pennsylvania, a residence which is
leased solely by the plaintiff. 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
, !
,
,
I'
defendant shall not nullify the provisions of the Court Order
directing the defendant to refrain from abusing the plaintiff.
Temporary custody of TYSHAWN TYLER HODGE is hereby awarded
to the plaintiff, TONYA MARIE CRUM.
The defendant is ordered to refrain from having any contact
with the plaintiff including, but not limited to, restraining the
defendant from harassing or stalking the plaintiff, and from
harassing the plaintiff's relatives.
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 I~ day of May, 1994, at J:~o ~ .m. in Courtroom
NO.~ ,Cumberland County Courthouse, Carlisle, Pennsylvania.
The plaintiff may proceed in forma pauperis 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 Carlisle 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 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.A. section 6113).
By the court,
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TONYA MARIE CRUM,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 -
CIVIL TERM
vs.
PROTECTION FROM ABUSE
: AND CUSTODY
RICHARD ANTHONY HODGE,
Defendant
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.
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
:-
TONYA MARIE CRUM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL TERM
NO. 94 -
vs.
PROTECTION FROM ABUSE
AND CUSTODY
RICHARD ANTHONY HODGE,
Defendant
PETITION FOR PROTECTIVE ORDER
AND CUSTODY
RELIEF UNDER THE PROTECTION FROM ABUSE ACT
23 P.S. SECTION 6101
A. ABUSE
1. The plaintiff is an adult individual whose permanent
address is 111 North Hanover Street, Apt. 2, Carlisle, Cumberland
County, Pennsylvania, 17013.
2. The defendant is an adult individual residing at 152
West North Street, Carlisle, Cumberland County, Pennsylvania,
17013.
3. The defendant is the father of the plaintiff's child.
4. Since approximately August 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 April 20, 1994, the defendant kicked the
plaintiff's door in, grabbed the plaintiff by the hair, pulled
her to the floor, and punched her in the chest leaving only when
the telephone rang. The plaintiff telephoned the police who came
and made a report. After the police left, the defendant knocked
on the plaintiff's window, causing the plaintiff to fear for her
safety and again call the police. After she hung up the
telephone, the defendant again kicked the door in and hit the
plaintiff's boyfriend with a 2 x 4 piece of wood. The plaintiff
again called the police. The Carlisle Police Department are
looking for the defendant and to the best of the kplaintiff's
knowledge, will be charging the defendant with buglary and
assault.
b. On or about April 13, 1994, the defendant came to the
plaintiff's residence at 2:00 a.m. and demanded to be let in.
When the plaintiff opened the door, the defendant pushed her out
of the way and came into the house. The defendant then pushed
the plaintiff toward the bedroom. When the plaintiff attempted
to call the police, the defendant hung up the phone and ripped
the cord out of the wall.
c. On or about April 3, 1994, the defendant came into the
plaintiff's residence through the kitchen window, went into the
plaintiff's bedroom where she was sleeping, put one hand over her
mouth and the other on her throat. The defendant would not let
the plaintiff out of bed and forced her to sleep with him.
d. On or about March 20, 1994, the defendant kicked in the
plaintiff's door and slapped the plaintiff across the face. The
defendant then punched the plaintiff in the arm and the middle of
her back, and pushed his fists into her back forcing her toward
the bedroom. The defendant threatened the plaintiff saying,
"There's nothing you can do because the PFA ain't no good no
more." The plaintiff's previous PFA had expired the day before.
During the period of time that the plaintiff's PFA was in effect,
the defendant violated it three times and spent time in the
Cumberland County Jail.
5. The plaintiff believes and therefore avers that she will
be 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 restrained
from having any contact with her, harassing or stalking the
plaintiff, and from harassing the plaintiff's relatives.
B. TEMPORARY CUSTODY
7. The plaintiff seeks temporary custody of the following
child:
~
TYSHAWN TYLER HODGE
Present Residence
~
1 yr.
111 N. Hanover Street
Carlisle, PA
The child was born out of wedlock.
The child is presently in the custody of TONYA MARIE CRUM
who resides at 111 North Hanover Street, Carlisle, Pennsylvania.
During the child's lifetime, the child has resided with the
following persons and at the following addresses:
Name
plaintiff &
defendant
Addresses
11 South pitt Street
Carlisle, PA
Dates
5/4/93 - 8/93
plaintiff, Jane
Middaugh
121 Cold Spring Rd.
Carlisle, PA
8/93 - 9/93
-
(plaintiff'S mother),
& Jerry Cobb (plaintiff's
mother's boyfriend)
plaintiff, defendant,
and Helene & Richard
Davis (defendant's
grandparents)
152 West North st.
Carlisle, PA
9/93 - 12/93
plaintiff 111 N. Hanover st.
Carlisle, PA
plaintiff & 111 N. Hanover st.
defendant carlisle, PA
plaintiff 111 N. Hanover st.
Carlisle, PA
12/93 - 2/93
2/93 - 3/93
3/93 - present
The mother of the child is TONYA MARIE CRUM, currently
residing at 111 N. Hanover street, Apt. 2, Carlisle,
Pennsylvania.
She is single.
The father of the child is RICHARD ANTHONY HODGE, currently
residing at 152 W. North Street, carlisle, Pennsylvania.
The plaintiff currently resides with the following persons:
Name
Relationship
TYSHAWN TYLER HODGE
son
8. The plaintiff has not previously participated in any
litigation concerning custody of the above mentioned child in
this or any other Court.
9. The plaintiff has no knowledge of any custody
proceedings concerning this child pending before a court in this
or any other jurisdiction.
10. The plaintiff does not know of any person not a party
b,/t~\"_
to this action who has physical custody of the child or claims to
have custody or visitation rights with respect to the child.
11. The best interests and permanent welfare of the child
will be met if custody is temporarily granted to the plaintiff
pending a hearing in this matter for reasons including the
following:
a. The plaintiff is a fit parent who can best take
care of her child.
b. The plaintiff has been the primary caretaker of the
child.
c. The defendant has shown by his abuse of the
plaintiff that he is not an appropriate role model for the
child.
C. LOSSES
12. The plaintiff has suffered losses as a result of the
abuse by the defendant. The losses are listed on Exhibit A which
is attached and incorporated herein by reference.
13. The plaintiff asks for attorney fees to be paid to
Legal Services, Inc., pursuant to the Protection from Abuse Act.
D. STATUS TO PROCEED IN FORMA PAUPERIS
14. The defendant is unemployed.
15. The plaintiff currently receives public assistance in
the amount of $316.00 per month.
16. The plaintiff does not have funds available to pay the
fees for filing and service.
:dIIi~'!;,~", "
from Abuse Act" of october 7, 1976, 23 P.S. section 6101 ~ .w!,g.,
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:"
1. Requiring the defendant to refrain from abusing the
plaintiff or placing her in fear of abuse.
2. Requiring the defendant to refrain from having any
contact with the plaintiff, including, but not limited to,
restraining the defendant from harassing or stalking the
plaintiff, and from harassing the plaintiff's relatives.
3. Granting temporary custody of the minor child to
the plaintiff.
4. Ordering the defendant to stay away from the
residence located at 111 N. Hanover street, Carlisle.
5. Ordering the defendant to stay away from any
residence the plaintiff may in the future establish for
herself.
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:
1. Requiring the defendant to refrain from abusing the
plaintiff or placing her in fear of abuse.
2. Requiring the defendant to refrain from having any
contact with the plaintiff, including, but not limited to,
restraining the defendant from harassing or stalking the
plaintiff, and from harassing the plaintiff's relatives.
3. ordering the defendant to stay away from the
residence located at 111 N. Hanover street, Carlisle.
4. Ordering the defendant to stay away from any
residence the plaintiff may in the future establish for
herself.
5. Ordering the defendant to reimburse the plaintiff's
out-of-pocket losses suffered as a result of the abuse
including but not limited to the losses listed on the
attached sheet marked Exhibit "A".
6. Ordering the defendant to pay attorney fees to
Legal Services, Inc., pursuant to the Protection From Abuse
Act.
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 Carlisle Police Department as 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
17. The allegations of Count I above are incorporated
herein as if fully set forth.
18. The best interests and permanent welfare of the child
will be served by confirming custody in the plaintiff as set
{'
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forth in Paragraph 11 of the Petition.
WHEREFORE, pursuant to 23 P.S. section 5301 ~ ~., 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,
.,
oan Carey
Attorney for Pla' tiff
LEGAL SERVICES, INC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
(-
The above-named plaintiff. TONYA M. CRUM. 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. Section 4904, relating to
unsworn falsification to authorities,
Date: Lj, JJ" (}~'I
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o ya ~ Crum,
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Plaintiff
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TONYA MARIE CRUM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
.
.
.
.
CUMBERLAND COUNTY, PENNSYLVANIA
:
vs.
.
.
.
.
NO. 94 -
CIVIL TERM
.
.
PROTECTION FROM ABUSE
AND CUSTODY
RICHARD ANTHONY HODGE,
Defendant
PROTECTION FROM ABUSE
LOSSES SHEET
Telephone Expense:
Repairs for ripped telephone cord
$ 15.80
Interior Repair Expense:
Repairs for door that had been kicked
in several times
$136.30
clothing Expense:
Reimbursement for ripped clothing
$ 20.00
TOTAL
172 .10
EXHIBIT "A"
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I.
or from
TONYA MARIE CRUM,
Plaintiff
IN THE COURT OF COMMON PLEAS ,OF
vs.
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 - .:J~, I CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
.
.
\, . ,.
RICHARD ANTHONY HODGE, "It;, t
Defendant
PROTECTIVE ORDER
AND NOW, this ~day of June, 1994, upon consideration of
the Consent Agreement of the parties, the following Order is
entered:
physically abusing the
placing her in fear of
2. The defendant
rQ)
J/, ~l 'J ( .fJ t
ljoined from
1. The defendant
ljoined from
or stalking the plain1
le purpose of
to, harassing
iff's
having any contact wit
facilitating visitatic
relatives.
3. The defendan'
rdered to stay
away from the residence located at 111 North Hanover Street,
Carlisle, Pennsylvania, and from any other residence the
plaintiff may establish for herself in the future, except for the
purpose of facilitating visitation. The defendant shall seek
modification (change) of this Order before living with the
plaintiff in a domicile she may establish for herself in the
future, wherever it may be. The defendant is hereby notified
Commonwealth's
, EXHIBIT
I
5/3/14 tA}. Y
..
.
W,
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.
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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 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 defendant shall not
nullify the provisions of the Court Order directing the defendant
to refrain from abusing the plaintiff.
4. The defendant is ordered to pay the plaintiff's out-of-
pocket losses which are listed on the "Out-of-Pocket Losses" form
in the amount of $172.10 within 120 days of the entry of this
Order.
(.
5. This Order shall remain in effect for a period of one
year.
6. The Carlisle Police Department will be provided with a
copy of this Order by attorneys for plaintiff and .ay enforce
this Order 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 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 PS Section 6113).
By the Court
.
TRUE COPY FROM RECORD
In Te~t:m~ny whtrcor. I h.-rp unl1 set my h3:'l~
and the seal of said (ourl al Carlis!e, Pa.
This ....J.Q...~ day of ..~. ............1.~9..'(.i':
~ JB..r
--....-- . . .,;
..;:b..... ......p.;~i,;.o~~.
1.5/ ~. ld-,~O') t9t_, 9-v.
J. We ey Oler, Jr., J.
CRIMINAL COMPLAINT
(POLICE)
DISTRICT JUSTICE
MAGISTERIAL DISTRICT NO.
Complaint Numba,a II Othar Parllclpanta
I,
Ptlrn Mckinney
( Namt' fif Al11u"')
COMMONWEALTH OF PENNSYLVANIA
DEFENDANT: VS.
NAME r-
AND Richard Antmny EXIiIilK
111 N. Hanover St.
ADDRESS rNl~!~:~a. 17013
RSA SSN. 168-48-3232
AKA
of 53 W. South St. Carlisle.Pa.
( IJt'nIlI)' UI'f'U"",t'lII "' UKt'n(l' Il'pn.'Jl!fltt.J 1111J polit/fal .tllhtlirL\/on)
do hereby Slale:
(I) 0 I accuse the above named defendant, who lives at lhe address sel forth above or.
o I accuse an individual whose name is unknown to me but who is described as
j
.
.
'~
~
~
~
is
~
o his nickname or popular designation is unknown to me and. therefore. I have designated him herein as John
Doe; with violating the penal laws of the Commonwealth of Pennsylvania at 111 N. Hanover St.
( Piau -[\Jllt/ca! SuMlfulan)
in Cllnberland County on or about 8-3-94 at 0325 hrs.
Part ici pan ts were (If thtfl' M't'rr pllrUclpanu, pfacf thr/r namr.! ht'rr. rrpealing tilt namr of aba"t dr/tndanl):
(2) The acts committed by the aceused were: @ Indirect Criminal Contempt -: The ,defendant violated the
order issured under the Protection Fran Abuse Act in No. 9li.;.et1'f"'Mfl;M~94' on the 9th day
of June 1994,by the Hororable J. Wesley Oler Jr. which order directed the defendant not to
but Tonya Marie Crum in fear of abuse in that the defendant did pick Tonya Crun up and
KXXXX throwed her into a sterio causing a cut on the back of her leg. This happened on
8-3-94 at 0325 hrs. at Tonya Crum Jl1OffiOOIX residence.
all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of Assembly.
or in violation of' 10190;,' and of the Aet of, :&HIIIl JUne 23,1978,PrOtection from abuse
( Stet/on) ( .\'lIb. .\('('lIon)
or the'" :. Ordinance of
(/\lfitiCCl/Sllh.dM.lillll)
(3) 1 ask that a warrant of arrest or a summons be issued and that the accused be required to answer the charges
I havc made.
(4) I verify that the facts set forth in this complaint are true and correct to the best of my knowledge or information
and belief. This verirication is made subject to the penalties of Section 4904 of the Crimes Code (18 Pa. C. S.
~ 4904) relating to unsworn falsirication to aUlhorities.
.19
erk ~~ .
(Slgnaltrt.! ('(lm~
AND NOW, on this date ,19 _' I certify the complaint has been properly completed and
veriried. and that there is probable cause for issuance of process,
(SEAL)
(.\(IJgbtt'riaJ[)j\t,trtJ
( lUlling AlllhflrUr)
ACPC 411-86
, ;',
-1
AFFIDAVIT RIDER CONTAINING PROBABLE CAUSE FOR THE ISSUANCE OF A WARRANT OF ARREST
FOR Richard Anthony Hodge 111 N. Hanover St. Carlisle,Pa. DOB 2-9-66
On8-3-94 at approx 0325 hrs. the Defendant Richard Anthony Hodge was at 111 N. Hanover sT.
Apt.#2. Hr Hodge and the victim Tonya Crun got into a pushing match. The victim was throwed
into a sterio in the living room. A pEEce of glass door broke off the sterio and cut the victim
KKKK leg( back part). The suspect then left the scene. There is a Prote~tion from abuse and
custody on the suspect Hodge. The order states that Mr. Hodge is enjoined from physically
abusing Tonya Crun.
Executed this ................ day 01 ............................ 19......
&b~~- ->
gnatu~
Per~onally appeared before me on .............................., 19...... the Alllant above named. who. being duly sworn
(aflirmed) according to law, signed this Allldavlt Rider In my presence and deposed and said that the facts set forth
therein are true and correct to the best of Alllants knowledge. Information and belief.
(Issuing Authority)
(SEAL)
.
TONYA MARIE CRUM
Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
94-2211 CIVIL
RICHARD ANTHONY HODGE
Defendant
CHARGE: INDIRECT CRIMINAL ATTEMPT
ORDER OF COURT
AND NOW, this ~ day of July, 1994 in consideration of
the attached.Commonwealth's Petition, a warrant is issued for the
arrest of the Defendant, Richard Anthony Hodge. If the defendant
is found during normal Courthouse hours the defendant is to be
brought immediately before the Court. If not found during
Courthouse hours the defendant is to be taken to the on-call
District Justice and bail set pursuant to the Rules of Criminal
Procedure. Furthermore, after appearing before the District
Justice the defendant is advised to appear before the Court
Administrator at the open of the next business day.
Defendant has a right to be represented by an attorney. If
the defendant cannot afford an attorney, one will be assigned to
represent the defendant.
By the Court,
~
Thomas A. Placey, Esquire
Assistant District Attorney
Richard ~hon~ Hodge, Defendant
- -
,-,
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.
, '
TONYA MARIE CRUM
Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
94-221l CIVIL
RICHARD ANTHONY HODGE
Defendant
CHARGE: INDIRECT CRIMINAL ATTEMPT
COMMONWEALTH'S PETITION FOR A HEARING ON CHARGES
OF INDIRECT CRIMINAL CONTEMPT
Thomas A. Placey, Assistant District Attorney of Cumberland
County, Pennsylvania brings the following Petition for a hearing
on charges of Indirect criminal Contempt:
l. A Protection from Abuse Order was issued by the Court.
A true and correct certified copy of the docKet is attached.
2. The defendant.s violation of this Order is averred in
the attached criminal complaint and affidavit of probable cause.
3. The police were unable to locate the defendant in their
jurisdiction.
4. The victim requested the police to file charges of
Indirect Criminal Contempt upon information received.
5. The police ascertained the immediate safety of the
victim.
6. The Commonwealth is requesting a hearing on the charges
of Indirect Criminal Contempt pursuant to 23 Pa.C.S.A. S6ll3.
WHEREFORE, the Commonwealth requests the defendant be
commanded to appear before the Court on the charge of Indirect
Criminal Contempt.
Respectf~:~y__s~bmitted,
Th mas
As i
Attorney
. .
LEGAL SERVICES. Ii .C.
H IOVINL now
CAf~l1SlE, PlNtJSYLI/,\NI^ 1/(il:!
171712436400
r.x 1.,'71 743oo7G
West Shore (717) 7fG.&175
Shippontuurg (7171 !J3("'~~~Ctl
"-,:- '....!'
APR 2 ~.199lt.d
.~~-.':::'...I
TONYA MARIE CRUM,
Plilintiff
III TilE COUHT 01' COMMON PLEA~; Or'
CUMRERLAIID COUlITY, PENNSYLVANIA
NO. 94 - ~J_lL CIVIL TERM
V5.
PROTECTION FROM ABUSE
i\ND CUSTODY
RICHARD ANTHONY HODGE,
Defendant
AND Ilml,
TF.J.:!l~QBA B..Y, J'80TJ5S::UYf._,QRD EB
this 2~1~dilY of "pril, 1994,
upon presentiltion
and consideration of tl10. within Petition, ilnd upon finding that
the plaintiff, TOllYA MARIE CPUM, now residing at III North
llilnovl.~r Street, Apt. ;.~, Carlisle, Cnmbcrland county,
Pennsylvan ia, ::; in j mmediate ilntl pn"",nt dLlngcr of abuse from
the defendant, RICHARD ,\ti'l'1l01IY HODGE, th.) following Temporary
Order is entered.
The defendant, RICIlARD ANTHONY HODGE, nml residing at 152
West Horth street, Cilrlisle, Cumberland county, Pennsylvania, is
hereby enjoined from physically abusing the plaintiff, TONYA
MARIE CHUM, or placinq her in feilr of abuse and is ordered to
stay away from the residence located at 111 1I0rth Hanover Street,
Carlisle, Cumborland County, Pennsylvaniil, a residence which is
leased solely hy the plilintift. The defendant is hereby notified
that if he resides in the Illaintiff's domicile contrary to this
Order, he may b1"' in indirect criminal contempt. \<hich is
punish:tblt' by a fine not to exceed $1,000.00 and/ol.' by a ~;entence
ot "p to :;i;.: month" in jai] '1nd iln)' other appropriate punishmont.
Pe"U'"p1 ion 01 c"-I',,~,idencr' nn the p.~I.t 01 the plaintiff ;Ind
defendant shall not nullify the provisions of the Court Order
directing the defendant to refrain from nbusing the plaintiff.
Temporary custody of 'rYSIlAWN TYLER HODGE is hereby awarded
to the plaintiff, TaNYA MARIE CRUM.
The defendant is ordered to refrain from having any contact
with the plilintiff inclUding, but not limited to, restraining the
defendant from harassing or stalking the plaintiff, and from
harassing the plaintiff'S relatives.
1~is Order shall remain in effect until a final order is
entered in this case. A hearing shall be held on this matter on
the
,. .
,- ./.1..
day of Hay,
1994, ilt '\':","i!~____.e_.m. in Courtroom
No. 5-'
, Cu~berland County Courthouse,
C~rlisle, Pennsylvania.
The plainr.iLf ma,' procc'ed jJ} !'Qt:!1l-!1 pal1P_l'ri,! pending a
further order after the hearing.
The Curnb~!'Jand COUtlt~. Sheriff's oft ice stlall attempt to make
service at ttlQ plaintif['s re4u0st, hut ~crvjcc may be
accomplished unctcr any a~plicable rule of civil Procedure.
The Carlisle Polict' tJcpartment will be provided with a copy
of this Order by attorn',}'s [or plidntiff. This Order shall be
en forced by .nlY I i"" f'n forcemellt agency \.:hcrc a v io In tion occurs
hy arrest for indirect criminal contempt without warrant upon
probable cause that this Order haG 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 "hill 1 be t;lken v:i tholl!-. IInrll'Cc:':;al"Y drday b,!/orc the
COUI-t l:h;) t i 'c'Gll(,c] the Orde,".
\'i!ll'n t11;lt l'()\ll"t 1'; llnilv,l i.l able, the
;" .
defendant shall be taken before the appropriate district justice
(23 Pa.C.S.A. section 6113).
By the Court,
( '!' .'- . ~
./' 'Ii "i
-V-",--,-":-k:UJ->--Z'S'~~~l .. j.
TRUE COpy FROM RECORD
In Testimony whereof, I here unto set my hand
and the se I of sa C t Carlisle ~
Thl ~ da 0 19'
4AIJ- ,.
ry
. ....~ '-.,. . ,
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-,.
"-,
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. '.' '. (- "..". . :~
....JUN 09 183t (LiL
. .
L!;w, I SI;RVIC(;:.. .
b '"VINE HOW
CARLISLE, P~NNSYLVANIA tllJlJ
17171 243.9400
Fax 17171 24.).002~
We,,! Shoro (717) 71l6-lJ475
ShlpplJnsburo 1717) 53()'5tY'Y.J
"_"',.~_-,,.;.,o'
."'..J
,.\,.
.....-:~~:.
TONYA MARIE CRUM,
PI nintH f.
I t/ TilE COUla OF COHHON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
I/O. 9.j - _Ad:1L (; I VII, TEHM
vs.
PROTECTION FROM ABUSE
AND CUS')'ODY
RICHARD AN'rIlONY IIODGE,
nef.endant
PRO~I.:EC'l'IYJ~Q.B.DEB
AND NON, thi!; .i1~ dilY of June, 1994, upon consideration of
the Consent Agreement of the pilrties, the following Order is
entered:
1. 'I'he defendilnt, RICHARD ANTHONY HODGE, is enjoined from
physically ilbusing the plnintiff, TaNYA MARIE CRUM, or from
placing her in feDr of ilbusc.
2. The defendnnt, IUCIf!\RD ANTHONY HODGE, is enjoined from
bilving any contilct with the plilintiff, except for the purpose of
facilitating visitation, including bllt. not limited to, harassinf/
or stalking the plaintiff, and haras!;ing the plaintiff'S
relatives.
'1. The defendant, R rCII.'.PD ANTIlOllY HODGE, is ordered to stay
.I\.!ay from t.ne> !""sidence> 10C',ltcd aL 111 lIorth Hanover street,
ea r.1 i 51 c, l'n.n:1sy 1 V:1I1 i 'J, (11ld t roi.l any oth(~r res ic1cncc the
plaintiff may pstai,lish for herself. in the future, except for the
purpose of f,-,cilitatinq visit."tion. The defendant shall seek
r.1odificiltion (dlilnqe) of this Or'l':r before 1 ivinq with the
plaintiff ill " domici 1e she may I~"t;\blisit for IlCrs.~lf in the
future, whel:ev('l' it rrilY he. The defend"n!: i::; hereby notified
/
"
that if he resides in the plaintiff's domicile contrafY t6 thig
Order, he may bc in indirect criminal contempt which is
punishablc by a fine not to cxceed $1,000 and/or by a sentcnce of
up to six months in jail and any other nppropriato punishment.
Rcsumption of co-ru~idcncc on thc part of the defendant shall not
nullify the provisions of the Court Order directing the defcndant
to refra in from abu~inq t.he plaint iff.
4. The defendant is ordered to pay the plaintiff'S out-of-
pocket losscs '"hich ace listed on the "Out-of-Pocket Losses" form
in the amount of $17~.lO within l~O days of the entry of this
Order.
5. This Order shall remain in cffect for a period of one
year.
6. 'rho carlisle Police Department will be provided with a
copy of this Order by attorneys for plaintiff and may cnforce
this Order by arrest for indirect criminal contempt without
warrant upon probable cause that this Order has been violated,
whether or not thc violation is committcd in the presence of the
police officer. In the event that an arrest is made under this
section, the defendant shall taken ~ithout unnecessary delay
before the Court t:hat i!;su1.,d the Clrder. \'Ihen that Court is
una'JiliJablp, 1"11" 'ietocnd,lnt shnll be \:.,1:0n before t.he appropriate
,li.~;tric~... jU;.t:Cf! ()-~ p~~ :~ection (lllJ).
TRUE COpy FROM RECORD
In Testimony whereof, I here unto set my hand
and t seal of said t Carllsle, PJZ'
Thi- 'day ~ '19~
By the. COU1't
f / /' , " '/
I' '.;.... 1..- / ~,,;'.
r:- W-;,-;<rey .10 1'(,1' ;-Jr=~-T:-:J~- --.-
J
CRIMINAL COMPLAINT
(POLICE)
-'".l
DISTRICT JUSTICE
MAGISTERIAL DISTRICT NO. 09-2-01
Paula Correal,
Iii W. High St., 2nd floor
Carlisle PA 17013
Complaint Numbera II Olhe, Pa'tlclpant.
A 95741
COMMONWEALTH OF PENNSYLVANIA
DEFENDANT: Vs.
r-
I,
Ptlrn. K. D. McCoy #20
( 'vamf' of A.lllant )
Carlisle Police Dept.
(ldl'mO.I' ,!t'/'urlml'll' IIf "KI'IIIT O'(I"".\c',,'coJ and Il/llilimJwhdil'i.\/t",)
NAME
AND
ADDRESS
.:J;
HS.A
AKA
Richard Antmny Hodge
151 W. North St.
Carlisle, PA 17013
black/male/21 DOB 02-09-66
of
do hereby slate:
(1) !XI 1 accuse lhc above named defendant, who lives at the address set forth ahove or.
o I accuse an individual whose namc is unknown to me but who is described as
j
o his nickname or popular designation is unknown 10 me and, thercfore. 1 have designated him herein as John
Doc: with violating the penal laws of the Commonwcahh of Pennsylvania at 111 N. Hanover St., Apt. 2
( Plact .I\)/I'/CQI SubdMJ/on)
"
"
.<
'"
<
f::
i Carlisle Borough in CU'llberland County on or aboul 07-10-Q4
~. Participants were (~f'ht'n..ltw'l'paflifi{ltlntJ. plan'tht'jrnamf'.t h~rr. ft'pc.'a1lng lh('nam('lifabol'edtftnJanl):
"pprnx
01'i'i hr",
(2)
The acts committed by the accused were: 0
Indirect Criminal Contempt - in that the defendant
violated the Order issued under the Protection From Abuse Act in No.94-2211 Civil on
June 9, 19':14, uy Lhe Honorable J. I~esley Ole., Jr., which Order directed defendant not
to place Tonya Marie Crum in fear of abuse, not to haVe any contact with the plaintiff
except for visitation, and not to harass the plaintiff. The defendant went to 111 N.
Hanover St. Apt. #2 at approximately 0355 hrs. and attempted to open the door of the
plaintiff's residence but a chain prevented it. Theo4fendant attempted to persuade the
plaintiff to let him in. Police were called to the scene but Hodge had left. While
speaking to the plaintiff in the front of the residence a rear windDw was pushed in and
a mirror breaking was neard. Police discovered the window on the floor and footprints
on an ad;acent roof next to the window. This occured ;ust minutes after Hodge had left
the front of the residence.
all of whieh were against the peacc and dignity of thc Commonweahh of Pennsylvania and contrary to thc Act of Assembly,
or in violation of 10190 and of the Act of June 23.1978 ProtectiorFFrom Abus/:rn.
( S<<IJOIJ) (SlIb. Wt'lill" )
or the
Ordinance of
( 1~,fj'lftll.\'lIh."i\'i.\i/ln)
(3) 1 ask that a warrant of arresl or a summons bc issucd and lhat the accuscd be rcquircd to answer the charges
1 havc made.
(4) 1 verify lhat lhe facts sel forth in this complaint are true and correct to lhe beSl of my knOWledge or information
and bclief. This verification is made subject to thc penahies of Section 4904 of thc Crimes Code (18 Pa. C. S.
~ 4904) rclating 10 unsworn falsificalion to authorilics.
,19
r D (SI?!1~)
AND NOW, on tbis datc , 19 _' I ccrtify Ihe complaint has been properly completed and
verified, and that therc is probable cause for issuance of process.
OQ-2-01 .
( .\(UR;."I'r;ullh\trlct)
IIHlllnK Allthor;,r J
(SEAL)
AOPC 411.86
OIlICINM. Sf r Ilf VI 11';1 ~;iDr 1011 W<\IVUl MHl loorNOTtCs
, '-
AFFIDAVIT RIDER CONTAINING PROBABLE CAUSE FOR THE ISSUANCE OF A WARRANT OF ARREST
. . .
FOR
OOB 02-09-66
Richard Anthony Hod~e
On 07-l0-94 at approximately 0356 hrs. Tonya Marie Crlm reported that Richard
Anthony Hodge was at her door trying to get in her residence at 111 N. Hanover St.,
Apt. 2. Hp. had pushed the door open but a chain was on it. Upon arrival Officers
found that Hodge had already left. While talking with the victim at the front pa~t
of the hDuse there wpre noises in the rear or the house. A rear windDw was discovered
on a bathroom floor. It had been pushed in and footprints were found on an adj:;.cent
roof next to the window. This occured just a couple of minutes after Officers had
arrived. A few minutes later Hodge called the victim on the telephone.
Executed this ................ day 01 ............................ 19......
11 ~~I~lant)
Personally appeared before me on ............................... 19...... the AllIant above named who being duly sworn
(alllrmed) according to law. signed this AllIdavlt Rider In my presence and deposed and said thai the tacts set forth
therein are true and correct to the best of AllIants knowledge. Information and belief.
(Issuing Authority)
(SEALJ
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./
TONYA MARIE CRUM,
Plaintiff
: IN THE COURT OP COMMON PLEAS OP
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v.
: 94-2211 CIVIL TERM
:
RICHARD ANTHONY HODGE,
Defendant
: PROTECTION PROM ABUSE
: AND CUSTODY
IN RE: DEPENDANT POUND GUILTY
ORDER OP COURT
AND NOW, this 3rd day of August, 1994, upon
consideration of the complaint for indirect criminal contempt,
and following a trial, the Court finds the Defendant guilty of
indirect criminal contempt in the form of a violation of the
Protection from Abuse Order entered by this Court on June 9,
1994.
By the Court,
Thomas A. P1acey, Esquire
Assistant District Attorney
William G. Braught, Esquire
Assistant Public Defender
CCP
:alr
VIH\'.\l':-,HH3d
UHnoo O"Vl~JBHnO
AYV1c.HO~) -',: ,'1110
3011d0 "",
~6. Hd LE 2 ~ :lRV
TONYA MARIE CRUM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
: 94-2211 CIVIL TERM
.
.
RICHARD ANTHONY HODGE, PROTECTION FROM ABUSE
Defendant AND CUSTODY
IN RE: SENTENCING
ORDER OF COURT
AND NOW. this 3rd day of August, 1994, the
Defendant, Richard Anthony Hodge, having been found guilty by
the Court of indirect criminal contempt in the form of violation
of the Protection from Abuse Order dated June 9, 1994, the
sentence of the Court is that the Defendant undergo imprisonment
in the Cumberland County Prison for a period of twenty days.
Work release is authorized for the Defendant if the prison can
accommodate the same.
By the Court,
/1 /7/
I . / I .. / ('\'/ /
W~~{ / I
JUWeSley 0 e ~ ~.
Thomas A. Placey, Esquire
Assistant District Attorney
William G. Braught, Esquire
Assistant Public Defender
CCP
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.
..
..
TONY A MARIE CRUM,
PETITIONER
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: 94-2211 CIVIL TERM
RICHARD ANTHONY HODGE,
DEFENDANT
: CHARGE: INDIRECT CRIMINAL
CONTEMPT
ORDER OF COURT
AND NOW, this I.~ ~ay of OCTOBER, 1994, in consideration of the attached
Commonwealth's Petition, a WARRANT IS ISSUED FOR THE ARREST Df the Defendant,
RICHARD ANTHONY HODGE. If the defendant is found during normal Courthouse
hours, the defendant is to be brought immediately before the CDUrt. If not found during
COUrthDUse hours, the defendant is tD be taken to the on-call District Justice and bail set
pursuant to the Rules of Criminal Procedure. Furthermore. after appearing before the
District Justice the defendant is advised to appear before the Court Administrator at the open
of the next business day.
Defendant has a right to be represented by an attorney. If the defendant cannDt afford
an attDrney, one will be assigned to represent the defendant.
By the Court,
J
I
,
)/
I .
Thomas A. Placey
Assistant District Attorney
Richard Anthony Hodge
Defendant
Office of the Public Defender
Ucr 1:1 Ii III rtl '9~
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.
.
,
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~
TONY A MARIE CRUM,
PETITIONER
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: 94-2211 CIVIL TERM
RICHARD ANTHONY HODGE,
DEFENDANT
: CHARGE: INDIRECT CRIMINAL
CONTEMPT
COMMONWEAL TH'S PETITION FOR A HEARING ON CHARGES
OF INDIRECT CRIMINAL CONTEMPT
Thomas A. Placey, Assistant District AttDrney of Cumberland County, Pennsylvania
brings the following Petition for a hearing on charges of Indirect Criminal Contempt:
I. A Protection from Abuse Order was issued by the Court. A true and correct
certified copy of the Order is attached.
2. The defendant's second violation of this Order is averred in the attached criminal
complaint and affidavit of probable cause.
3. The police were unable to locate the defendant in their jurisdictiDn as upon the
police arrival the defendant fled.
4. The victim requested the police to file charges of Indirect Criminal Contempt
upon information received.
S. The police ascertained the immediate safety of the victim.
6. The C' .
) lwealth is requesting a hearing on the charges of Indirect Criminal
Contempt pursl...lOt to 23 Pa.C.S.A. ~6113.
WHEREFORE, the Commonwealth requests the defendant be commanded to appear
before the Court on the charge of Indirect Criminal Contempt.
//
LEGAL :,tEIlV"1ES, I; ,.
8 UIVIIIE now
CAnLlStE, PENNSYLVANIA 1l01:,
17171 2.13.9400
Fox (717) 243.nQ2d
JUN 0'9.1994 d.le
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5hlpPof1:iI.J'Jr9 (717) 530.58GG
'l'ONY A HAIU E CHUr.!,
I' \;1 i nt i f(
TN 'rllE C')llllT OF COMMON PLEAS OF
curmF.RLAtlD COUNTY, PENNSYLVAllIA
1I0. ~I'l -:,' ~.LL C1 V I L 'l'Eml
V,,
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PROTECT I :lll FIWN M\USE
l.tlD ClJST'.lD?
IHCIIARIJ AII'l'1l0N'{ IWf":a:,
Dp ft'nrlilnt
/dIP 1/0\1, th i:;
I'BqTEC'I'l ~!ILOB[1E[~
-IL rJilY of ,lunro,
~L.,
upon consideration of
1'l9~,
the Con~;l'nt Agreement: 01 t:Iw parties, tl]l~ followinq order is
cntercej:
1. The defendant, HlCIlAIW fdlTIlOlIY WJlJGE, is enjoined from
physically abusing the plaintiff, TONYA MARIE CRUH, or from
placinq her in fear of abuse.
~. 'rhe defend,lIlt, IHClllllm AlJTIIONY IlDDGE, is enjoined from
having any contact with the plilintiff, except [or the purpose of
facilitating visitation, incluclinq but not limited to, harassing
or stall:ing the plaintiff, ,11lC! hdl',-!:]sinq ttw plaint:iff's
re lf3ti "f~S.
.~. ThQ defl:>n~];__lnt, RfC'IfJ\HD Id!'l'1I0HY HODGE, is ordored to _..tay
iJ1,o.'a~. 1 r l;n Lhc r.C:.:...ittl'n(~~ lrll'fj;:'p,j .It 111 !:~)l~th I!{l.nover. strC'ct,
("'r.li:~illl I'~nn~}ylv.1~li l, dl~d :"l~cm .-It)"}" oLII('\1: t"C'sidr:>nce thC'
pJilin!.ill mil')' CSLl<-IL,h in!" 11('1','.(>11 in ti1" future, C'x<.:ept for the
purpo:."C' 1'; f'lcllitatinq vi:;it,-ltion. 'Ii)':' detentiont ~,;hall Geek
modifi~ation (ch~nYQ) ot !.his Ordcr beforr Jiving witll the
plaintitt in a domici Ie she I~.ay e,.t:ablish inl' herself in thl?
future, wherever it rnilY be. The dcfcnd~nt in hereby notified
..
, ,
, .
, ,
th~t if he resides in the pl~intif['G domicile contrary to thi~
Onll'l', he milY be in indin::ct erimill.ll contempt. ,o/hich is
punish;I1>le by u fine not to ,,:,~cC'l.d ~;l,OOr' ..nd/or by ,1 sentence of
up to :; ix month,,; in j '\ j] and ;my other ,,["'peopr i il tc pun i shmcnt.
Hcsun:ption of co-rc~;ide!\Le on the part of th", defendant, shall not
nu I I it '{ the prov isiam; of the COUI.t Order d j reet ing the defendant
to refr~in from abusinq the plaintiff.
4. The defendant in ordered to P3Y the plaintiff's out-of-
pocf:et: losses wh ieh .\t'" ! i stc,d on the "ou t-of -Pocket Losses" form
in thp ;lmOllnt of $17;!.10 loJithin l~O d"ys of the entry of this
Order.
~. This Ordel' sllall n::m~in in effect for a period of one
year.
h. The Carlisle Pol ice Dcrartmcnt Hill be provided loJith a
cory of this Orde,' by al:l:rwneys for plaintiff and may enforce
this Order by ill' rest for indirect cri~inill contempt witllout
"Iilrrant upon probable Cill1Se thilt this Orrlc'r has been violated,
whether or not the viol~tion is commi~tacl in the presence of the
policl:' of f icar. In the event th;\ t an arrest is milde> under th is
section, the defend.Ii'\'. ,;h.lI1 taf:l'n "Iit'hollt unnecessary clelay
befol'O t l1e Court t.h'lt i';~;lJ1,d tile- Onler. \'1h..n that Court is
una'lil i LtlJ!c, tho defelldant ;;h..11 be t~f;en before the appropriate
distrio:t- j\lstice (7.1 1'5 f>cct.ion C;J1'l).
TRUE COpy FROM RECORD
In TesUmon~ whereof, I here unto set IflY hand
an!! the seal of. d 0 at Carlisle, f~:
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J. Heslev Oler, Jt<.' J.
, . lJ
olary
CRIMINAL COMPLAINT
(POLICE)
...
NT
Complaint Numbers it Other Participants
P au 1 a Cor rea 1 DISTRICT JUSTICE
MAGISTERIAL DISTRICT NO. 09 - 2 - 0 1
16 W. High s to 2nd floor
Carlisle, Pa. 17013
A 94624
INCIDENT NUMBER UCR NO.
94-15748
I.
Co!. Griest 1/38
(SlIlIIl'O/AJI1cllll)
Carlisle Pol;~p
( !dI'fIt''-\' dt'purtmt'lll orll~c'II(1' ('('flft'wl/lt'd /.ll/d po/itinll.whdhi,\iofl)
COMMONWEALTH OF PENNSYLVANIA
DEFENDANT: Vs,
r-
Richard Anthony Hodge
111 N. hanover st. Apt. 2 Carlisle
B1ck-m- 2/9/66
SSIl 168-48-3232
5'6" 145 lbs.
NAME
AND
ADDRESS
of
RSA.
AKA
do hereby state:
( I) Glx I accuse Ihe above named defendllllt. who lives at the address sel forlh above or,
o I accuse an individual whose name is unknown to me but who is described as
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o his nickname or populllr designalion is unknown to me lInd. therefore, I have designllted him herein as John
Doc: with violating the penal laws of lhe Commonwellllh of Pennsylvania lit III N. Hanover st.
C l' 1 ( 1'1/1('(' .l\,/illmf ."'"hdlrl.dlUl)
ar 1S " in \;umberland County on or aboul 10/9/94 aporox.. 0453
Participants were ('/"II/l'ft' ",C'fl'pafridpclflh. plaft' ,J,C';'''ilIllC'.\ IU'Il', n'/lt',uilll: ,ht"III111t'I!(abo\"t'Je'fi'"Jallt):
(2) The acts committed by the accused were:@INDIRECT CRIMINAL CONTEMPT-in that the defendant
violated the Order issued under the Protection From Abuse Act in No. 94-2211
on 6/9/94. by the Honorable J. Wesley OlerJr., which order directed iRX~k.~ the
defendant not to abuse the victim or place ~ in fear of abuse or be at the
above.re~iden7e u~less facilitating custody, in that the defendant did punch
the v1ct1m tW1ce 1n the mouth causing injury. AdditionallYI the defendant
pulled a hair braid from the victim's scalp and carried the phone around inthe
apartment so the victim could not call police. Moreover, the defendant was at
the residence while not facilitating child custody.
all of which were against the peace and dignity of lhe Commonweallh of Pennsylvania and contrary to the Act of Assembly,
or in violation of 10190 and of the Acl of June 23, 1978Protection from
( .'k'Clfll" ) ( Sllb. ,\('clitlll ) Abu 9 e
or the
Ordinance of
( Political Sub .JMlton)
(3) I ask that a warrant of arrest or a summons be issued and lhat lhe accused be required to answer the charges
I have made.
(4) I verify lhal the facls sel forth in this complaint are lrue and correct to the besl of my knowledge or information
lInd belief. This ve,ification is made subject to the penalties of Section 4904 of lhc Crimes Code (18 Pa. C. S.
~ 4904) relating 10 unsworn falsification to authorities.
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( Sign'lflll"',!( ('mnplainant)
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AND NOW. on this date ('...Ie 11 .rd., 19 ~. I certify the complaint has been properly compTeled and
verified. and that there is probable cause for issuance of process. I'
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TONYA MARIE CRUM,
PETITIONER
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: 94-2211 CIVIL TERM
RICHARD ANTHONY HODGE,
DEFENDANT
: CHARGE: INDIRECT CRIMINAL
CONTEMPT
ORDER OF COURT
AND NOW, this L1:-day of OCTOBER, 1994, in consideratiDn of the attached
CDmmonwealth's Petition, a WARRANT IS ISSUED FOR THE ARREST of the Defendant,
RICHARD ANTHONY HODGE. If the defendant is found during normal Courthouse
hDurs, the defendant is to be brought immediately befDre the Court. If not found during
Courthouse hours, the defendant is tD be taken to the on-call District Justice and bail set
pursuant to the Rules of Criminal Procedure. Furthermore, after appearing before the
District Justice the defendant is advised to appear before the Court Administrator at the open
of the next busi ness day.
Defendant has a right to be represented by an attorney. If the defendant cannDt afford
an attDrney, one will be assigned to represent the defendant.
By the Court,
&b
Jr. Judge
ThDmas A. Placey
Assistant District Attorney
Richard Anthony Hodge
Defendant
Office of the Puhlic Defcnder'/
C~EALTH (f PENW\.
VS
RICHARD ANTHOtN f{)))JE
IN THE roJRT (f ffi'T1)N PI..EftS
UffiERI..AND COONlY J PENW\,
94-2211 CIVIL
[J W[LL[AM D[EHLJ DEPUTY SHER[FF BE[NG DULY SWCRN BY LAW SAYS, m\T ON MARCH 25J 1995 THE
ABOVE NAMED SUBJECT WAS ARRESTED BY CARLISLE BCRO. POLICE DEPT, AND THE N. MIDDLETON lWP,
POL[CE DEPT, ON TH[S BENCH WARRANT. SUBJECT WAS TRANSPCRTED BY THE ARRESTING AUTHORITIES
TO THE CLMBERLAND COUNlY PR[SON WHERE HE [S LODGED WAITING FURTHER ACTION OF THE COURT,
SHERIFF COSTS: $0,00 SO ANSWERS,
R, THa.1A~EJ S.1ER [FF
BY __~~__l___~_____
WILLIAM DlEHLJ DEPUTY
&on
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RICHARD ANTHONY HODGE,
Defendant
.
.
TONYA MARIE CRUM,
Petitioner
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
v.
: 94-2211 CIVIL TERM
: INDIRECT CRIMINAL CONTEMPT
IN RE: TRIAL DATE ~ BAIL SET
ORDER OF COURT
AND NOW, this 28th day of March, 1995, the
Defendant, Richard Anthony Hodge, now appearing in Court with
his court-appointed counsel, Michelle R. St. Clair, Esquire,
pursuant to a warrant issued for his arrest by this Court on
October 13, 1994, and pursuant to an agreement between the
Defendant, through his counsel, and the Commonwealth, in the
person of Travis N. Gery, Esquire, a trial on the charge of
Indirect Criminal Contempt in this matter is scheduled for
Thursday, April 20, 1995. at 8:30 a.m. Bail is set in this
matter at $1,000.00 without prejudice to the Defendant's right
to file a formal motion for a reduction of bail.
By the Court.
/
J
Travis N. Gery, Esquire
Assistant District Attorney
Michelle R. St. Clair, Esquire
Court-appointed Counsel
CCP
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CASH OR NOMINAL BAIL BOND
CERTIFICATION OF BAIL
AND DISCHARGE
~
COMMONW(ALTII V:i (Dt'lutlfJ.n N....-r1r11W1d A,/l:kftMi)
Richard Anthony Hodge
151 West North Street
Carlisle. PA l701J
[lil ROR (no surety) DNominal Bail
D Boll {Iotal amount set, II anYI $
o CondItions 01 Release (aside 110m appearing al Coutl when required:)
(attach addendum. it necessary)
SECURITY OR SURETY IF ANYj
D Cash in full amount of bOil
D Percenlage cosh bail
D Money furnished by
D Defendant
D 3rt! Parly
JUDGE OR ISSUING AUTUonlTV
Hon. J. Wesley 01er. Jr.
APPEARANCE OR BAIL BOND
THIS BOND IS VALID FOR THE ENTIRE PROCEEDINGS AND UNTIL
FULL AND FINAL DISPDSITIDN OF THE CASE INCLUDING FINAL
DISPOSITION OF ANY PETlTlDN FOR WRIT OF CERTIORARI OR
APPEAL TIMELY FILED IN THE SUPREME COURT OF THE UNITED
STATES.
1'01.11:1 CA~;[ "10
0.1 NO
CP TlnM& flO
- (:itAlltil t~il--'---~---- --~--~---
94-221l Civil Term
O"TE Of CIIAIlGUSI
Contempt: Violation of
Protection from Abuse Order
DATE ANO TIME
NEXT COURT ACTION
lOCATION
TO:
D Detention Canter
DOltlCr
I hereby certify that sulficient bail has been entered
D By tho defendant
D On behalf of tho delendant by:
(~t & Adl:tvs5 01 SuofyJ (LICMSe No'
. Relund 01 cash bail will be made within 20 days after
final dIsposition. (Pa.R.Cr.P.40 15(b) I
. Refund of all other types of bail will be made promptly after
20 days tollowing final disposition. (PaR.Cr.P.40 15(011
. Bring Cash Bni! Receipt to Clerk of Court.
DISCHARGE THE ABOVE.NAMED DEFENDANT FROM CUSTOOY IF
DETAINED FOR NO OTHER CAUSE THAN THE ABOVE STATED
Given under my hand and the Ollicial Seal of this Court.
this 20th day of April
~';1JJ~-rJ. a. ~~
l~OflS.~UInjlAulhOfltYJ Dept.
95
.19_.
(SEALI
Prothy.
WE. THE UNDERSIGNED. defendant and surety. our successors. heirs and assigns. aro jointly and severally bound to pay to tho
Commonwealth of Pennsylvania the sum of dollars ($ ).
SEE REVERSE SIDE FOR BAIL CONDITIONS
TO BE USED ONLY FOR PERCENTAGE CASH BAIL:
The undersigned about to become Surety In the case cited herein, beirKJ duly sworn (or affirmed), deposes and says:
I ACKNOWLEOGE THAT I AM LEGALLY RESPONSIBLE FOR THE FULL AMOYNT OF THE BAIL.
The follOWing acknowledgement IS also appllc.,ble ~ ..-', / / / ,-7 / / .
1/ Percentage Cash BilIllS used 15.....!~ o>'(/.,'{, (ft /J~:~J~ro>';I
".nT'1.'1 20 19-L5 <iK;NJ,lWU or 01 Ff '.(lM,l P /
THIS BOND SIGNED ON_-"",,, I
01___ __ _ .c:,'lI::.J,Jsle PENNSVLVANIA
1. I reside al
and my occupahon is
2. I have no undisposed of criminal cases against me pendil\{)
in the Courts of lhe aforesaid County, except as fallows.
SKJlled and t1cknowledged belore me this
20th day 01 April . 19 __ 95
fl;, .. J . ~l a, IV ttia,t.-L.-
~'\...-~~""""AuI"""~1 Dpty. Prothy.
AOPC 4 U.Ii;>
my phone number is
and I work for _____
3. I am not Surely on .my bond of any kind except as follows:
OAf[ "MOIJPlY DEfENDANT
.t I htlvc carefully mad the foregOing affidavit and know It IS
hue and correct
ISEALI
Signature 0/ Surety (May be BondSl11il/1, &,;1 Agency, or pf/vote
indivtdual 01 organization). Except when defendant IS released on his
own rocognizance (nOR), this must be signed in all bail situations,
includmg nonllf1<JI bel/I.
(SEALI
ADORE 55 Of ~URl T'I ::;Url[Ty COMPANy OH{}[fENDANT
Stnty No (V Ph>les.s.tma/ tlondsmM h:ense No "EIp.nJtJM Dam
ORIGINAL
.'
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TONYA MARIE CRUM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
v.
RICHARD ANTHONY HODGE,
Defendant
94-2211 CIVIL TERM
ORDER OF COURT
AND NOW, this 20th day of April, 1995, the
Defendant, Richard Anthony Hodge, now appearing in court with
his Court-Appointed Counsel, Michelle R. st. Clair, Esquire, and
having tendered a plea of guilty to indirect criminal contempt
for violation of a Protection From Abuse Order issued by this
Court on June 9, 1994, the Defendant's plea of guilty is
accepted.
Sentence in this case is scheduled for Tuesday,
June 13. 1995, at 9:00 a.m. Pursuant to a request for a
continuance of sentencing made by Defendant's counsel, sentence
IS CONTINUED from that date until Tuesday. July 25, 1995, at
9:00 a.m. at which time the Defendant shall present himself for
sentencing without further Order of Court.
The reason for the deferral of sentence is to
enable the Defendant and the Plaintiff to continue or initiate
counseling inasmuch as they have apparently reconciled.
The Defendant shall be released on his own
recognizance on this charge conditioned upon his execution of
the necessary bail document.
~~,"'.
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MR 21/ 9 'U ~il'95
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By the court,
J
THOMAS A. PLACEY, ESQUIRE
Sr. Assistant District Attorney
MICHELLE ST. CLAIR, ESQUIRE
Court-Appointed Counsel
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Sheri"
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HDRACE A. JOHNSON
Solicitor
OFFICE OF THE SHERIFF
Courl House
Carlisle, Pennsylvania 17013
April 26. 1995
Lawrence E. Welker
Cumberland County Prothonotary
Carlisle. Pa.
SUBJECT CIVIL SUBPOENAS
1./
94-2211 Civil Richard Hodge
2.80
2.
94-6558 Civil Linwood Richardson Jr.
2.80
Total
$5.60
So answers:
.,_./.,,,..-;;t'. .
RONNY A. ANDERSON
Chlof Dopuly
AUDREY G. ADAMS
Roal Estato Dopuly
.,'
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R. Thomas Kline. Sheriff
..'"
AUTHORITY TO PAY COURT APPOINTED COUNSE~ i I:' . i ~ -, nil /,..,-
I -
, C,)\inr 2 VOUCHER
o Ol'.>lr.cl JU5tlce >b Common Pleas 0 Appell.le o Othor " " . -~-_.- N!l 1145
J FOR ID J. C p. APPELL..,TEI 4. AT tCITY/STATEl 5 BUDGET COOE
C.P. Carlisle, PA/Cumberland Co. (I,,"-n 3wVo aU
6 IN THE CAse OF 1 CHARGEJOFFENSE 'PURDON CIfATlO~ll 8 0 PETTY OFFENSE
Crum " Hodge 23 Pa.C.S.A. ~6114 o FELONY 0 MISDEMEANOR
'J PROCEEOI~4GS (DesCflbe brlellyl 11 PERSON REPRESENTED 12. CIVIL DOCKET NO
IX D.I.rod.", . Ad\,i1I 94-2211 Civil Te
indirect criminal contempt , rJ Oe',,"r1,1nt .JII.'".I.
J ApOfl!"'" lJ C'i!W'NAL OOCKET NO
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to Pln:)o~, REPRESENTED tFull Namel . ~ P'onoll'I:l"'" C".rge,1 W,th V,OI.',cn - 14. APPEALS COCKET NO
-
Richard Anthony Hodge . - 0'''.' N
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3/28/95 16 NAME OF ATTORNEV/PAYEE.....P:
Avpl ~_I'l!' MAILING ADDRESS ~-' I =
- ..
Michelle R. st.~ir -
CD
Griffie & Associa es c.n
Hon. J. Wesley Oler, Jr. 200 North Hanover street
NAME OF COMMON PLEAS JUDGE ASSIGNED TO CASE Carlisle, PA 17013
11 TELEPHONE No 18 5C";'''l ~[:uRI'" NO I)A ~ "1 ~;O
243-5551
CLAIM FOR SERVICES OR EXPENSES
19 SERVICE HQUPS OATES AMOUNTS CLAIMEO
.1 A"a.g"m,n' andlor Pie. l 3/28 MuU'Dly rl'e per hour lime' tOlal
t) P,ellmlnary H,,,,ng hours 10 ob'aln "In Cour1R com.
pensallon Enltr lOll' below
e. Mohon, and ReQue,ls
... d Bolli He.llngs
0:
::> tt Senlenc. H.atlng, .8 7/2<;
0
u I. T"al . ~ 4/20
;;
o Re'loc:tllon Heatings
n JU"'II'lIle Hearings
I ApPlIal, Court 19,," TOTAL IN COURT COMPo
I OU'lttt ISoec,fy on addllronal '''eetsl
TOTAL HOURS. 2.6 X$'N~OUR -s130.00
20. a lnler'-l.e....' .and conl.renc., l.2 ?I?R 4/<; 4 11 Mulll~ty rat. per hOuf times IOI.a1
b Obla,nlno and ,e...lewlng record' C. ll?R 4/24 hou's. Enter lolal "Oul of Court~
..... comDen.allon belo......
00: c Legal feuareh and br'lel.....f1tlng . c. 4/<; 4/7. 4/17
...::>
::>0 ~ In...esnQ3tJ'19 and ottle, wo,,," (Speoly on !ldchoonm $hIlts) 20,," TOTAL OUT OF COURT
ou
h,,"r'n~ ';nn 3,0 A 11 A 4/1Q.7/2 COMPo
TOTAL HOURS - 8.4 X $4<) PER HOUn - S 336.00
2\ ITEMIZATION OF REIMBURSABLE EXPENSES AMT PER ITEM
~/t!p.;)a9 S 25 oor mile . Q -. -- l.UU
0: , ~ ..._1 1-_ "nil ,,_~~ f',,~ho_~nM Co orisonl
w
J: 2',," TOTAL ITEMIZED EXP.
...
0
-$ 2.00
22 CERTIFICATION OF AnORNEY/PAYEE 2J. GRAND TOTAL CLAIMED
Has compunsallon and/or reimburalmenllOl work In thl, cal. pr.vloulty been applied for? DYES XI NO -$ 468.00
II yes, ....,rp. you paid" DYES o NO Ifyes.bywhamwereyau paid? Howmuch1
Has the person reprosented paid any maney 10 you, or to you' knowl.dge Inyone else, In connection wllh Ihe miner tor 2A. DEDUCT. PRIOR PYlolTS.
whlcn you .....e'l! ,lppolnted 10 provide represen\atlo~? 0 {1S ~ N~. II ~et gi.... delalls on .ddl~P1l:leS.ls -$
I sweolr or allllm Ihelrulhorconectne" (111 (,..... C ~ ( a..\..... \. ql) 25 NET AMDUNT CLAIMED
01 ltoe oIbo...o slalomnnl, Slgn.tur.~"Orney/P.ye. Oal. .s
" ~.";
"6 \, r''''"" I ~.J .tVt.-orL oZ7- 21. AMT. APPROVED
.. I. .. S.qM.llu'.ol .0". A\l.'. (l . 1\ "lS'
.......' '.' Jua~. . -s ",~,bb
COPV 1 ' Mail to c\,trl Administrator at com lehon 01 service
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COMMONWEALTH
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
v.
94-2034
CHARGE:
CRIMINAL TERM
(A) SIMPLE ASSAULT
(B) CRIMINAL MISCHIEF
CPL. BRENT GRIEST
RICHARD ANTHONY HODGE
OTN: E726552-1
AFFIANT:
~
94-2211
CHARGE:
CIVIL TERM
INDIRECT CRIM. CONTEMPT
It; RE: SEN'IENCE
ORDER OF COURT
AND NOW, this 25th day of July, 1995, the
Defendant, Richard Anthony Hodge. now appearing in court for
sentence with his court-appointed counsel, Michelle R.
st. Clair, Esquire, and having previously entered a plea of no
contest at Number 94-2034 Criminal Term to Count A, Simple
Assault, a misdemeanor of the second degree, and Count B,
criminal MiSChief, a summary offense. and having previously
entered a plea of guilty to Indirect criminal contempt at Number
94-2211 civil Term, and the Court being in receipt of a
pre-sentence investigation report with respect to the charges at
Number 94-2034, upon which it relies, the sentences of the Court
are as follows:
At Number 94-2034 Criminal Term, Simple Assaul~1r
a misdemeanor of the second degree,
to pay the costs of prosecution and undergo imprisonment in tHe)
,-,
Cumberland County prison for a period of not less than 87 days.-.:
nor more than 23 months. It appearing that the Defendant has~)
I
.... .....0...
-
served the minimum portion of the sentence, he is immediately
paroled on this charge conditioned upon his being and remaining
on good behavior and complying with all written directions of
his parole officer.
At Count B, Criminal Mischief, a summary offense,
the Defendant is sentenced to pay the costs of prosecution.
At Number 94-2211 civil Term, Indirect criminal
Contempt, the Defendant is sentenced to pay the costs of
prosecution, including any Sheriff's fees and any costs
associated with the Protection from Abuse proceeding, and to
undergo imprisonment in the Cumberland County Prison for a
period of 56 days. It appearing that the Defendant has served
the sentence imposed herein, he shall be released with respect
to this charge.
By the Court,
Travis N. Gery, Esquire
Assistant District Attorney
Michelle R. St. Clair. Esquire
court-Appointed Counsel for Defendant
Probation
C.C.P.
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COMMONWEALTH
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
,
,
V.
1994-52211
TERM," NO.
RICHARD ANTHONY HODGE
CHARGE:
CASE TRANSFERRED
FROM CIVIL DIVISIO
OTN: AFFIANT:
IN RE: RULE TO SHOW CAUSE
/'
ORDER OF COURT
AND NOW, September 25, 1995, 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
,~
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October l3, 1995
at 9:30 AM in Courtroom No.4,
of the
..:.i
Cumberland County Courthouse, Carlisle, Pennsylvania.
Service of the petition to be made on the defendant by Certif~ed
Mail, Return Receipt Requested and by regular mail.
By the Court,
,t4L
District Attorney's Office
Public Defender's Office
Probation Of flce
,
'--
1. Report to the Probation Office in person at the time and date
set by the Collections Officer. ,~
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COMMONWEALTH
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
RICHARD ANTHONY HODGE
TERM & NO.
PROB. NO.
CHARGE:
1994-52211
27566
CASE TRANSFERRED
FROM CIVIL DIVISIO
OTN: AFFIANT:
IN RE: PETITION FOR RULE TO SHOW CAUSE WHY THE DEFENDANT SHOULD
NOT BE HELD IN CONTEMPT OF COURT
AND NOW, September 25. 1995, the Probation Office of Cumberland
County, respectfully petitions Your Honorable Court to isaue a Rule
why the defendant should not be held in contempt of court.
The defendant has failed to comply with the Court Order dated
7/25/l995.
The defendant has failed to:
2. Make regular payments on the fines, costs, and restitution as
agreed.
3. Other:
1.-,
.....
The defendant has agreed to pay
$101.60 per month.
Date last paid was 0/00/0000.
The balance is
$lOl. 60.
Therefore your petitioner prays this Honorable Court issue a Rule
why the defendant should not be held in contempt of court.
Respectfully submitted,
1
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COMMONWEALTH
IN THE COURT OF COMMON PLEAS OF
v
CUMBERLAND COUNTY, PENNSYLVANIA
--. 94-2034 CRIMINAL TERM
. '''-'2320 CRIMINAL 1993
'" 1994-52211 ./
'\,1993-50866 t
.
.
RICHARD A. HODGE
.
.
IN RE: BENCH WARRANT
ORDER OF COURT
AND NOW, this 13th day of October, 1995, at 10:15
a.m., a bench warrant is issued for the arrest of the defendant.
By the Court,
Thomas Placey, Esquire
Sr. Assistant District Attorney
Probation
~A.d
Kev A. Hess, J.
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TONYA MARIE CRUM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
.
.
v.
: CIVIL ACTION - LAW
:
RICHARD ANTHONY HODGE,
Defendant
.
.
94-2211 CIVIL TERM
ORDER OF COURT
AND NOW, this 20th day of April, 1995, the
Defendant, Richard Anthony HOdge, now appearing in court with
his Court-Appointed Counsel, Michelle R. st. Clair, Esquire, and
having tendered a plea of guilty to indirect criminal contempt
for violation of a Protection From Abuse Order issued by this
Court on June 9, 1994, the Defendant's plea of guilty is
accepted.
sentence in this case is scheduled for Tuesday,
June 13, 1995, at 9:00 a.m. Pursuant to a request for a
continuance of sentencing made by Defendant's counsel, sentence
IS CONTINUED from that date until Tuesday, July 25, 1995, at
9:00 a.m. at which time the Defendant shall present himself for
sentencing without further Order of Court.
The reason for the deferral of sentence is to
enable the Defendant and the Plaintiff to continue or initiate
counseling inasmuch as they have apparently reconciled.
The Defendant shall be released on his own
recognizance on this charge conditioned upon his execution of
the necessary bail document.
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By the Court,
J
THOMAS A. PLACEY, ESQUIRE
Sr. Assistant District Attorney
"~LLE ST. CLAIR, ESQUIRE
~~~~~-APpointed Counsel
CCP
wcy
TONYA MARIE CRUM,
Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY. PENNSYLVANIA
.
.
v. 94-2211 CIVIL TERM
RICHARD ANTHONY HODGE,
Defendant INDIRECT CRIMINAL CONTEMPT
IN RE: APPOINTMENT OF COUNSEL
ORDER OF COURT
AND NOW, this 28th day of March, 1995, upon
consideration of the Defendant's application for the assignment
of counsel, and it appearing that the Public Defender's Office
may have a conflict with respect to this case, Michelle R.
St. Clair, Esquire, is appointed by the Court to represent the
Defendant.
By the Court,
Travis N. Gery, Esquire
Assistant District Attorney
Michelle R. St. Clair, Esquire
J Court-appointed Counsel
Court Administrator
CCP
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'-
TONYA MARIE CRUM,
Petitioner
.
.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVAN:IA
v.
94-2211 CIVIL TERM
.
.
:
RICHARD ANTHONY HODGE,
Defendant
: INDIRECT CRIMINAL CONTEMPT
IN RE: TRIAL DATE & BAIL SET
ORDER OF COURT
AND NOW, this 28th day of March, 1995, the
Defendant, Richard Anthony Hodge, now appearing in Court with
his court-appointed counsel, Michelle R. St. Clair, Esquire,
pursuant to a warrant issued for his arrest by this Court on
October 13, 1994, and pursuant to an agreement between the
Defendant, through his counsel, and the Commonwealth, in the
person of Travis N. Gery, Esquire. a trial on the charge of
Indirect Criminal Contempt in this matter is scheduled for
Thursday, April 20, 1995, at 8:30 a.m. Bail is set in this
matter at $1,000.00 without prejudice to the Defendant's right
to file a formal motion for a reduction of bail.
By the Court,
J
/
Travis N. Gery, Esquire
Assistant District Attorney
Michelle R. St. Clair, Esquire
~Court-appointed Counsel
CCP
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TONY A MARIE CRUM,
PETITIONER
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
: 94-2211 CIVIL TERM
RICHARD ANTHONY HODGE,
DEFENDANT
: CHARGE: INDIRECT CRIMINAL
CONTEMPT
ORDER OF COURT
AND NOW, this \~ \ay of OCTOBER, 1994, in consideration of the attached
Commonwealth's Petition. a WARRANT IS ISSUED FOR THE ARREST of the Defendant,
RICHARD ANTHONY HODGE. If the defendant is found during normal Courthouse
hours, the defendant is tD be brought immediately before the Court. If not found during
Courthouse hDurs, the defendant is to be taken to the on-caJ1 District Justice and bail set
pursuant to the Rules of Criminal Procedure. Furthermore, after appearing before the
District Justice the defendant is advised to appear before the Court Administrator at the open
of the next business day.
Defendant has a right to be represented by an attorney. If the defendant cannot afford
an attorney, one will be assigned to represent the defendant.
By the Court I
J
Thomas A. Placey
Assistant District Attorney
Richard Anthony Hodge
Defendant
FILE COpy ~~
Office of the Public Defender
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Ol'l 1, I r;nn.;Ji 1 L.. V7\'NJA
v.
.
: 94-2211 CIVIL TERM
RICHARD ANTHONY HODGE,
DEFENDANT
: CHARGE: INDIRECT CRIMINAL
CONTEMPT
COMMONWEAL TH'S PETITfON FOR A HEARING ON CHARGES
OF rNDIRECT CRIMINAL CONTEMPT
Thomas A. Placey, Assistant District Attorney of Cumberland County I Pennsylvania
brings the following Petition for a hearing on charges of Indirect Criminal Contempt:
1. A Protection from Abuse Order was issued by the Court. A true and correct
certified copy of the Order is attached.
2. The defendant's second violation of this Order is averred in the attached criminal
complaint and affidavit Df probable cause.
3. The police were unable to locate the defendant in their jurisdiction as upon the
police arrival the defendant fled.
4. The victim requested the police tD file charges of Indirect Criminal Contempt
upon infonnation received.
5. The police ascertained the immediate safety of the victim.
6. The Commonwealth is requesting a hearing Dn the charges of Indirect Criminal
Contempt pursuant to 23 Pa.C.S.A. ~6113.
WHEREFORE, the Commonwealth requests the defendant be commanded to appear
before the Court on the charge of Indirect Criminal Contempt.
lacey
istrict Attorney
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IN THE COURT OF COMMON PLEAS OF
TONYA MARIE CRUM,
Plaintiff
CUMBERLAtlD COUNTY, PENNSYLVANIA
1'10.94 - ~.;l.lf CIVIL TERM
vs.
PROTECTI'J!I FRON .:>'BUSE
AND CUST'JDY
RICHARD ANTHONY HODGE,
Defendant
PROTECTIVE ORDER
AND NOW, this ~ day of June, 1994, upon consideration of
the Consent Agreement of the parties, the following Order is
entered:
1. The defendant, RICHARD ANTHONY HODGE, is enjoined from
physically abusing the plaintiff, TONYA MARIE CRUM, or from
placing her in fear of abuse.
2. The defendant, RICHARD ANTHONY HODGE, is enjoined from
having any contact with the plaintiff, except for the purpose of
facilitating visitation, including but not limited to, harassing
or stalking the plaintiff, and harassing the plaintiff'S
relatives.
3. The defendant, RICHARD ANTHONY HODGE, is ordered to ~tay
awa; from the residence lo~ated at 111 Ncrth Hanover Street,
Carlisl('~, Pennsy\\'~nii', "1'0 ::re,[l1 '-,:1')" other resi.dence the
plaintiff may establish for herselt in th0 future, except for the
purpo~c ,:f ::1cilitating vi.:31.~i',tior:. 7h,~ ::!c::end-:\nt shall see}~
modification (change) of this Order befo~e living with the
plaintiff in a domicile she may establish for herself in the
future, wherever it may be. The defendant is hereby notified
_.....~-... - ._.~
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that if he resides in the plaintiff's domicile contrary t'6--Elfis-'
Order, he may be in indirect criminal contempt which is
punishable by a fine not to exceed $1,000 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 defendant shall not
nullify the provisions of the Court Order directing the defendant
to refrain from abusing the plaintiff.
4. The defendant is ordered to pay the plaintiff's out-of-
pocket losses which are listed on the "Out-of-Pocket Losses" form
in the amount of $172.10 within 120 days of the entry of this
Order.
5. This Order shall remain in effect for a period of one
year.
6. The Carlisle Police Department will be provided with a
copy of this Order by attorneys for plaintiff and may enforce
this Order 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 defenda~t shall ta.:en \~itho\lt unnecessary delay
before the Court that issued the Order. When that Court is
una'J;:l i lable, the defendilnt shall be ta.:ell before the appropriate
distri~t justice (23 PS Section 6113).
TRUE COpy FROM RECORD
In Test!mon~ whereof. I here unto salrny hand
and the I 01 _ d 0 at Carlisle, f~:
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By the Court
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Carlisle. Pa. 17013
A 94624
Col. Griest 01R
( Nam. of A/fIanl)
Carlisl~ Pnl ;f""
( Identify dtpanmenl or altn~ Irpresented and poJiliCDJ JubJI"tJion)
RSA.
AKA
COMMONWEALTH OF PENNSYLVANIA
DEFENDANT; VS.
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n:tlionY:BI9.i:Ige.:.<,u . ;~.:. .
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~no..<~v.e.r;.t. :ilf':':~2:\trar,1is1e
fj/)J. '6 ,',....r;,.fi(, .c':.,.. .:H ,,::' .
y. :~n'3 2"'::'h"ffl. '[.j'~. 1f...
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th....b'Zi': ....;," \~~.. ._\..' "'l~'..
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do hereby state:
(I) G1x (accuse the above named defendant. who lives at the address set forth above or,
~ 0 I accuse an individual whose name is unknown 10 me but who is described as
~
o his nickname or popular designation is unknown to me and, therefore. ( have designated him herein as John
Doe; with violaling the penal laws of the Commonwealth of Pennsylvania at III N. Hanove r st.
C 1. 1 ( PI",.. Political Subdi.lsiOll)
_ar_ts_p
in !;umberland County on or about 10/9/94 approx.. 0453
Participants were (II/heft Wlft partlclpanu. pl<<t IlItfr IIames herr. I't~atlnr Me I14meo! abol/tdtfindanl):
2) The acts committed by the accused were: 0INDIRECT CRIMINAL CONTEMPT-in that the defendant
iolated the Order issued under the Protection From Abuse Act in No. 94-2211
n 6/9/94, by the Honorable J. Wesley OlerJr., vhich order directed iKX~k.~ the
efendant not to abuse the victim or place ~ in fear of abuse or be at the
bove.re~iden7e u~less facilitating custody, in that the defendant did punch
he V1ct1m t~lce 1n the mouth causing injury. Additionally, the defendant
ulled a ha1r braid from the victim's scalp and carried the phone around inthe
partme~t so the victim could not call police. Moreover, the defendant vas at
he res1dence vhile not facilitating child custody.
of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of Assembly.
in violation of~~......~ and ~I,~et~:; of the ACl ofi";'YJune~3;:.H?8Piri?!:ection from
($<<IiOll) (Sub,s<<lion) Abuse
the . ~~-f5~:~~f~i1~I;,'r.~~}::;:;!~ Ordinance of /(~.~~/t...~~~1"::.~~";"~':-';"~ :i't:.:..\.". ..-
( PoJilicaJ Sub. divUlOfl )
( ask that a warrant of arrest or a summons be issued and that the accused be required (0 answer the charges
I have made.
I veriry lhat the facts set forth in this complaint are true and correCl to the best or my knowledge or mrormatlon
and belier. This verification is made subject to the penalties of Seclion 4904 of (he Crimes Code (I SPa. C. S.
~ 4904) relating to unsworn falsification to authorities.
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D NOW. on this date r'., r 11' n. 19 ...3.:L, I certify the complaint has been properly completed and
ried, and that there is probable cause for issuance or process. , ' I. .
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(SEAL)
tPC411.00
ORIGINAL'SEE REVERSE SIDE FOR WAIVER AND FOOTNOTES
'CRIMiNAl COMPLAINT
(POUCE)
OISlllICT JUS11CE
MAGISTERIAL OISlllICT NO,
A 95769
. ':~r:r~~t;'~~~-:..
Ptlrn M::kinney
( ,vam, of Affiont)
of 53 W. South St. Carlisle.Pa.
t Idtntl/y dtpanmtlll or artnt)" rrprrullltd Qnd pol/Ileal JubcJ/rlJlolf)
COMMONWEALTH OF PENNSYLVANIA
DEFENDANT: VS.
r' .-.....-.
NAME ~- -A;;tm EXIIIlX
AND 111 N. HSnovei St.
ADDRESS ~~!~~a. 17013
R5.A. SSN. 16li~-3232 .
AKA
I.
do hereby state:
(1) 0 I accuse the above named defendant, who lives at the address set forth above or.
o I accuse an individual whose name is unknown to me but who is described as
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o his niekname or popular designation is unknown to me and. therefore. I have designated him herein as John
Doe: with violating the penal laws of the Commonwealth of Pennsylvania at 111 N. Hanover St.
(1'lIIt:t.I'tJlUiatJ Subd/fIsiDlr)
in Cllnberland County on or about 8-3-94 at 0325 hrs.
Participants were (I/thtrt """'pQrIidptUlU.p/DatJttlnl"lrIa htrt. rtpItI/1Itr WNJlrlloftJb<md<fINlant):
(2) The acts committed by the accused were: (3) Indirect Criminal Cont~t - The defendant violated the
order issured under the Protection Fran Awse Act in No. '..WiII__ _.__._,~ on the 9th day
of June 1994,by the Hororable J. Wesley Oler Jr. which order directed the defendant not to
wt Tonya Marie Crun in fear of awse in that the defendant did pick Tonya Crun up and
xxxxx throwed her into a sterio causing a cut on the back of her leg. This happened on
8-3-94 at 0325 hrs. at Tonya Crun jlXImM(X residence.
all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of Assemblv.
or in violation of '<r;7'10190 ~~ and ,....<,~~~....'!<.,': of the Act of ,,_ rJUne'23.1978'PrdteCtr~rl::\Cab.
(StctJon) (SIdJ._lon)
or the ~,..~~'::'~~'E7""4~ Ordinance of' '--~T-''''''''~~~:~~'~'''''~'~J~~~:'~';.'~-- .,~ ~-. .:-:~.
( Politico! Sub. d..uion)
(3) 1 ask that a warrant or. arrest or a summons be issued and that the accused be required to answer the charges
I have made.
(4) I verify that the facts set forth in this complaint 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.
,19
/?rk ~~
(Si,,,,, o/Compl"in"nl) 7
AND NOW, on this date . 19 _, 1 certify the complaint has been properly completed and
verified. and that there is probable cause for issuance of process.
. . . . . "
'. . ...... ....l. . _'.
(/"ut., Au/ho"ry)
(SEAL)
(!It~tmoJ Durn<l)
~"
-
.--..~
AFFIDAVIT RIDER CONTAINING PROBABLE CAUSE FOR THE ISSUANCE OF A WARRANT OF ARREST
FOR Richard Anthony Hodge 111 N. Hanover St. Carlislc,Pa. ooB 2-9-66
On8-3-94 at approx 0325 hrs. the Defendant Richard Anthony Hodge was at 111 N. Hanover SO.
Apt.#2. Mr Hodge and the victim Tonya Crun got into a pushing match. The victim was throwed
into a sterio in the living room. A peece of glass door broke off the sterio and cut the viet
HlI]!i leg( back part). The suspect then left the scene. There is a Protection fran awse and
custody on the suspect Hodge. 1he order states that Mr. Hodge is enjoined from physically
abusing Tonya Crun.
Executed this ................ day 01 ............................ 19......
~~~. ~
gnatu~
Personally appeared belore me on ............................... 19...... the AlIIant above named. who. being duly sworn
(atlirmed) according to law. signed this AlIIdavit Rider In my presence and deposed and said that the laclS setlorth
therein are true and correct to the best 01 ^"lanlS knowledge. Information and belief.
:,
TONYA MARIE CRtlM,
Plaintiff
: IN THE COURT OP COMMON PLEAS OP
CUMBERLAND COUNTY, PBNNSYLVANU
v.
94-2211 CrvIL TERM
RICHARD ANTHONY HODGE,
Defendant
: PROTECTION PROM ABOSE
: AND CUSTODY
IN RB: SENTENCING
ORDER OP COURT
AND NOW, this 3rd day of August, 1994, the
Defendant, Richard Anthony Hodge, having been found guilty by
the Court of indirect criminal contempt in the form of violation
of the Protection from Abuse Order dated June 9, 1994, the
sentence of the Court is that the Defendant undergo imprisonment
in the cumberland County Prison for a period of twenty days.
Work release is authorized for the Defendant if the prison can
accommodate the same.
By the Court,
/' /l(
1'// // t"\ ....
U/~~{t; .
J ~ IWesley 0 e .~ ."..
V
Thomas A. Placey, Esquire
Assistant District Attorney
William G. Braught, Esquire
Assistant Public Defender
CCP
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~61 HJ 8E Z ~ ~nv
,
TONYA MARIE CRUM
petitioner
: IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
V.
94-2211 CIVIL
CHARGE: INDIRECT CRIMINAL ATTEMPT
RICHARD ANTHONY HODGE
Defendant
ORDER OF COURT
AND NOW, this ~ day of July, 1994 in consideration of
the attached.Commonwealth's petition, a warrant is issued for the
arrest of the Defendant, Richard Anthony Hodge. If the defendant
is found during normal Courthouse hours the defendant is to be
brought immediately before the Court. If not found during
Courthouse hours the defendant is to be taken to the on-call
District Justice and bail set pursuant to the Rules of Criminal
Procedure. Furthermore, after appearing before the District
Justice the defendant is advised to appear before the Court
Administrator at the open of the next business day.
Defendant has a right to be represented by an attorney. If
the defendant cannot afford an attorney, one will be assigned to
represent the defendant.
By the Court,
Thomas A. Placey, Esquire
Assistant District Attorney
Richard ~hony Hodge, Defendant
. .
......
'.
-,
-...
~
::,
-,
TaNYA MARIE CRUM
Petitioner
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
94-221l CIVIL
CHARGE: INDIRECT CRIMINAL ATTEMPT
RICHARD ANTHONY HODGE
Defendant
COMMONWEALTH'S PETITION FOR A HEARING ON CHARGES
OF INDIRECT CRIMINAL CONTEMPT
Thomas A. Placey, Assistant District Attorney of Cumberland
County, Pennsylvania brings the following petition for a hearing
on charges of Indirect Criminal Contempt:
1. A protection from Abuse Order was issued by the Court.
A true and correct certified copy of the docket is attached.
2. The defendant's violation of this Order is averred in
the attached criminal complaint and affidavit of probable cause.
3. The police were unable to locate the defendant in their
jurisdiction.
4. The victim requested the police to file charges of
Indirect Criminal Contempt upon information received.
5. The police ascertained the immediate safety of the
victim.
6. The Commonwealth is requesting a hearing on the charges
of Indirect Criminal Contempt pursuant to 23 Pa.C.S.A. S61l3.
WHEREFORE, the Commonwealth requests the defendant be
commanded to appear before the Court on the charge of Indirect
Criminal Contempt.
Respectfully submitted,
Th
As
Attorney
::';~),f{'~,:~~.~
LEGAL SERVICES, II,e.
8 IRVINE ROW .... ~;.~
CARLISLE. PENNSYLVANIA 17013
17171 243-9400
on . ". ; .,1. 0 Fax 17.17) .2.4J.<1026;; . >"
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0:: .. :APR ~ 7:199~\l
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West Shol1l (717) 76&-8475
Shippensbu'g 17171 530-5866
-. -..-------
TONYA MP.RIE CRUM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 - ;lv~ II CIVIL TERM
vs.
PROTECTION FROM ABUSE
AND CUSTODY
RICHARD ANTHONY HODGE,
Defendant
AND NOW,
TEMPORARY PROTECTIVE ORDER
this 2 f'/ t~ day of April, 1994, upon presentation
and consideration of the within Petition, and upon finding that
the plaintiff, TONYA }~.RIE CRL~, now residing at 111 North
Hanover Street, Apt. 2, Carlisle, Cumberland County,
Pennsylvania, is in irr.mediate and present danger of abuse from
the defendant, RICHARD ANTHONY HODGE, the following Temporary
Order is entered.
The defendant, RICHARD ANTHONY HODGE, now residing at 152
West North Street, Carlisle, Cumberland County, Pennsylvania, is
hereby enjoined from physically abusing the plaintiff, TONYA
MARIE CRUM, or placing her in fear of abuse and is ordered to
stay away from the residence located at 111 North Hanover Street,
Carlisle, Cumberland County, Pennsylvania, a ~esidence which is
leased solely by the plaintiff. The defendan~ is hereby notified
that if he resides in the plaintiff's domicile contrary to this
Order, he may be in indirect criminal conte~pt 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 othe~ ap~ropriate punishment.
Resu~ption of co-residence on the part of the plaintiff and
I"
I
I
defendant shall not nullify the provisions of the Court Order
directing the defendant to refrain from abusing the plaintiff.
Temporary custody of TYSHAWN TYLER HO~GE is hereby awarded
to the plaintiff, TONYA MP.RIE CRUM.
The defendant is ordered to refrain from having any contact
with the plaintiff including, but not limited to, restraining the
defendant from harassing or stalking the plaintiff, and from
harassing the plaintiff's relatives.
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 l,tI.. day of May, 1994, at F:.:3c ,a.m. in courtroom
No. ~ , Cumberland county Courthouse, carlisle, Pennsylvania.
The plaintiff may proceed in forma pauperis pending a
further order after the hearing.
The Cu~barland 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 Carlisle Police Department will be provided with a copy
of this Order by attorneys fcr plaintiff. This Order shall be
enforced by any law enforcement agency where a violation occurs
by arrest for indirect criminal con~empt without warrant upon
probable cause that this Order has been violated, ~hether 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 lS unavailable, the
- -..-.. .....-. - ....-.--.....-------....-- ......
defendant shall be taken before the appropriate district justice
(23 Pa.C.S.A. Section 6113).
By the court,
I
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./'.,/.il.,-, ""'--
V" ;j; _'J '- , ~ :J .
. '. ;h,
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TRUE qopY FROM RECORD
In Testl'1lOnj' whereof, 1. here unto set my hand
and the. of sa C CarlIsle ~J.
Thl .( cia 19.!t.Y=....
. . ~: - >.
.- ..-...------ ---..-----.----.-------
TONYA MARIE CF.~~,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
..:",,)
:
CUMBERLAND COUNTY, PEIlNSYLV;'.NIA
NO. 94 - ~.;l II CIVIL TERM
vs.
PROTECTIOIl FROM ABUSE
AND CUSTOD'i
RICHARD i\.N'!HONY HODGE,
Defendan-c
PROTECTIVE ORDER
AND NOW, this ~ day of June, 1994, upon consideration of
the Consent Agreement of the parties, the following Order is
entered:
1. The defendant, RICHARD ANTHONY HODGE, is enjoined from
physically abusing the plaintiff, TONYA MARIE CRUM, or from
placing her in fear of abuse.
2. The defendant, RICHARD ANTHONY HODGE, is enjoined from
having any contact with the plaintiff, except for the purpose of
facilitating visitation, including but not limited to, harassing
or stalking the plaintiff, and harassing the plaintiff's
relatives.
J. The defendant, RICH~P.D ANTHONY HODGE, is ordered to stay
~~av f~CM th~ ~esidence located at 1:2 t:o~th Ha~over Street,
Carlisle, ~2~~sylvania, and fron any other residence the
p:a:~~i:f may establish for herSElf in the future, except for the
p~rpose of facilitating visitation. ~he defendant shall seek
nodification (change) of this Order before living with the
plaintiff in a domicile she may establish for herself i~ the
future, wherever it may be. The defendant is hereby notified
. .
,
that if he resides in the plaintiff's domlcTle' contra:-y-filfnls
Order, he may be in indirect criminal contempt ~hich is
punishable by a fine not to exceed $1,000 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 t~e defendant shall not
nullify the provisions of the Court Order directing the defendant
to refrain from abusing the plaintiff.
4. The defendant is ordered to pay the plaintiff's out-of-
pocket losses which are listed on the "Out-of-Pocket Losses" form
in the amount of $172.10 within 120 days of the entry of this
Order.
5. This Order shall remain in effect for a period of one
year.
6. The Carlisle Police Department will be provided with a
copy of this Order by attorneys for plaintiff and may enforce
this Order by arrest for indi:-ect 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 taken ~ithout unnecessary delay
before the Court that issued the 0rder. When that Court is
unavailatle, the defencant shall be ~a~en befcrc the appropriate
dist~jct justice (23 PS Section 61:3).
TRUE COPY FROM RECORD
In Testimo~' whereof, I here unto set my hand
and t seal of sai~ Carlisle, 1)./,
Thi day . 19~
By the Court
.
- I
\ I / ' . .
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J. /Wesley Ole-r;
J .'
-
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;..... / 1 \,.--:'
Jr". ,. J.
Prolhon
.~/(.
(,
of
C'lIMINAL COMPLAINT
(POLICE)
DISTRICT JUSTICE
MAGISTERIAL DISTRICT NO. 09-2-01
Paula Correal
l~ W. Hi~~ St., 2nd floor
Carlisle, PA 17013
A 95741
Ptlrn. K. D. McCo~ #20
I Nomt 0 Affiant)
Carlisle Police Deot.
( Idtntlfy dtptmmtnt 01 D,"II'" rtprrJtnltd and po/Weal JUbd"'UIOfl)
COMMONWEALTH OF PENNSYLVANIA
DEFENDANT: VS.
NAME ~~tbf~~ffii6die'
AND . -'. 1 'i1 :tL:1brth St. ...:..:'..-':;
ADDRESS; :.Qiriis1e,"'PA '17013:. ~/.
--. -- :.....:....
black/male/2t OOB 02-~l>>!'
- .
-. ---:.41"
RS.A.
AKA
Jo hereby stale:
( 1 ) lXI I accuse the above named defendant, who lives at the address set fonh above or.
_ 0 I accuse an individual whose name is unknown to me but who is described as
.is
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j.
c
~
...
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,c
~.
o his nickname or popular designation is unknown to me and. therefore. I have designated him herein as John
Doe: with violating the penal laws of the Commonwealth of Pennsylvania at 111 b1. Hanover St., Apt. 2
( PIaa. fb/j/JaJJ Subd;./sIDll)
07-10-Qu ApprnY O~~~ hr~
2)
Carlisle Borough in Cunberland County on or about
Participants were (lI.h... wt..patrlcipanlJ. phlalhtlflUJJ"es 1ItIr. rrpttJ/J", .ht_ofab<Mdr:ftndDnJ),
The acts committed by the accused were: 0
Indirect Criminal Contempt - in that the defendant
violated the Order issued under the Protection From Abuse Act in No.94-2211 Civil on
June 9, 19Y4, t:J'j the Honorable J. Wesley Oler, Jr., I1Ihi.ch Order directed defendant not
to place Tonya Marie Crum in fear of aOOse, not to have any contact with the plaintiff
except for visitation, and not to harass the plaintiff. The defendant went to 111 N.
Hanover St. Apt. #2 at approximately 0355 hrs. and attempted to open the door of the
plaintiff's residence rot a chain prevented it. Theaefendant attempted to persuade the
plaintiff to let him in. Police were called to the scene rot Hodge had left. While
speaking to the plaintiff in the front of the residence a rear window was pushed in and
a mirror breaking was heard. Police discovered the window on the floor and footprints
on an ad;acent roof next to the window. This occured .;ust minutes after Hodge had left
the front of the residence.
all of which were against the peace and dignity of the Commonwealth of Pennsylvania and contrary to the Act of Assembly.
Jr in violation of !"':'10190. ',~ y .~. - and ..~-: . .' . .'. , _. of the Act of ':Jiii'ie""13:1978 ProtectIon ,t:!:'lin':AIlUSe~r
ISla;on) (Sub.~Uonl
Jr the ~-,:--~ --- . --. . Ordinance of ......_~- .
.- ...-- OO:--J ,--".-..-
( PolitiCal Sub. d'VLlIOn)
, 3) I ask that a warrant of arrest or a summons be issued and that the accused be required to answer the charges
I have made.
(4) I verify that the facts set fonh in this complaint are true and correct to the best of my knowledge or infonnation
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.
, 19
?( D;SI~1
AND NOW, on this date , 19 _' I cenify the complaint has been properly completed and
verified. and that there is probable cause for issuance of process.
~~n-~"'..~~. :
( MarUlmaJ DuU1C1)
(SEAL)
(lsJlllnr Authorrn')
AOPC 4' '.86
"
," ~- ..-.... ,- .
.
AFFIDAVIT RIDER CONTAINING PROBABLE CAUSE FOR TH'E ISSUANCE OF A WARRANT OF ARREST
,
FOR
roB 02-09-66
R;chard Anthnny Hndfe
On 07-10-94 at approximately 0356 hrs. Tonya Marie Crun reported that Richard
Anthony Hodge was at her door trying to get in her residence at 111 N. Hanover St. I
Apt. 2. Hp. had pushed the door open but a chain was on it. Upon arrival Officers
found that Hodge had already left. While talking with the victim at the front pa:t
of the house there were noises in the rear or the house. A rear window was discovered
on a bathroom floor. It had been pushed in and footprints were found on an adj::.cent
roof next to the window. This occured just a couple of minutes after Officers had
arrived. A few minutes later Hodge called the victim on the telephone.
Executed this .................. day 01 ............................. 19......
?!D.~
(Signature 0 lant
(P~~naIlY appeared belore me on ............................... 19...... the Alflant above named who being duly sworn
ah r~ed) according to law. signed this Alfldavll Rider In my presence and deposed and said thai the facts set forth
t erem are true and correct to the best 01 A"lanlS knowledge. Information and bellet.
(SEAL)
TONYA MARIE CRUM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 - ~.).,t CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
-:..;.,
vs.
RICHARD ANTHONY HODGE,
Defendant
PROTECTIVE ORDER
AND NOW, this ~ day of June, 1994, upon consideration of
the Consent Agreement of the parties, the following Order is
entered:
1. The defendant, RICHARD ANTHONY HODGE, is enjoined from
physically abusing the plaintiff, TONYA MARIE CRUM, or from
placing her in fear of abuse.
2. The defendant, RICHARD ANTHONY HODGE, is enjoined from
having any contact with the plaintiff, except for the purpose of
facilitating visitation, including but not limited to, harassing
or stalking the plaintiff, and harassing the plaintiff's
relatives.
3. The defendant, RICHARD ANTHONY HODGE, is ordered to stay
away from the residence located at 111 North Hanover Street,
Carlisle, Pennsylvania. and from any other residence the
plaintiff may establish for herself in the future, except for the
purpose of facilitating visitation. The defendant shall seek
modification (change) of this Order before living with the
plaintiff in a domicile she may establish for herself in the
future, wherever it may be. The defendant is hereby notified
5. This Order shall remain in effect for a period of one
By the Court
r
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 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 defendant shall not
nullify the provisions of the Court Order directing the defendant
to refrain from abusing the plaintiff.
4. The defendant is ordered to pay the plaintiff's out-of-
pocket losses which are listed on the "out-of-Pocket Losses" form
in the amount of $172.10 within 120 days of the entry of this
Order.
year.
6. The Carlisle Police Department will be provided with a
copy of this Order by attorneys for plaintiff and may enforce
this Order 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 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 PS section 6113).
/'t
~ /. '..
[1-1 -1 J.:;.'.-, (/ .
J.; Wesley Oh(5t J~!' J.
TONYA MARIE CRUM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
.
.
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
: NO. 94 - ~;l." CIVIL TERM
vs.
:
PROTECTION FROM ABUSE
: .\lID CUSTODY
RICHARD ANTHONY HODGE,
Defendant
CUSTODY ORDER
AND NOW, this ~ day of June, 1994, upon consideration of
the parties' Consent Agreement, the following Custody Order is
entered with regard to custody of the parties'
child, TYSHAWN TYLER HODGE.
1. The plaintiff will have primary physical and legal
custody of the child.
2. The defendant will have visitation with the child at
times and places to be mutually agreed upon by the parties.
3. Neither party shall do anything which may estrange the
child from the other parent, or injure the opinion of the
child as to the other parent or which may hamper the free and
natural development of the child's love or respect for the other
parent.
By the Court,
TONYA MARIE CRUM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
.
.
: CUMBERLAND COUNTY, PENNSYLVANIA
.
.
: NO. 94 -
CIVIL TERM
vs.
:
: PROTECTION FROM ABUSE
: AND CUSTODY
RICHARD ANTHONY HODGE,
Defendant
:
.
.
CONSENT AGREEMENT
This Agreement is entered on this
day of June, 1994,
by the Plaintiff, TONYA MARIE CRUM, and the defendant, RICHARD
ANTHONY HODGE. The plaintiff is represented by Joan Carey, of
Legal Services, Inc.; the defendant is unrepresented but is aware
of his right to have an attorney. The parties agree that the
following may be entered as an Order of Court.
1. The defendant, RICHARD ANTHONY HODGE. agrees to refrain
from abusing the plaintiff, TONYA MARIE CRUM, or from placing her
in fear of abuse.
2. The defendant agrees not to have any contact with the
plaintiff, except for the purpose of facilitating visitation.
3. The defendant agrees not to harass or stalk the
plaintiff or harass the plaintiff's relatives.
4. The defendant agrees to stay away from the residence
located at 111 North Hanover Street, CarliSle, Pennsylvania,
except for the purpose of facilitating visitation.
5. The defendant agrees to stay away from any residence the
Plaintiff may establish for herself in the future, except for the
purpose of facilitating visitation.
6. The defendant agrees to reimburse the plaintiff's out-
of-pocket losses suffered as result of the abuse including but
not limited to the losses listed on the "Out-of-Pocket
Losses" form in the amount of $172.10 within 120 days of the
entry of this Order.
7. The defendant, although entering into this Agreement,
does not admit the allegations made in this Petition.
8. The defendant understands that the Protective Order
entered in this matter shall be in effect for a period of one
year.
9. The defendant understands that this Order will be
enforceable in the same manner as the Court's prior Temporary
Protective Order entered in this case.
10. The defendant and the plaintiff agree to the entry of
the following custody order regarding their child, Tyshawn Tyler
Hodge:
a. The mother will have primary physical and legal
custody of the child.
b. The father will have visitation with the
child at times and places which are mutually agreed upon
by the parties.
c. The parties realize that their child's well being
is paramount to any differences they might have between
themselves. Therefore. they agree that neither party will
do anything which may estrange the child from the other
parent, or injure the opinion of the child as to the other
.'
parent or which may hamper the free and natural development
of the child's love or respect for the other parent.
WHEREFORE, the parties request that an Order of Court be
entered to reflect the above terms.
~It"v\ 1 ~ m C1B I rvY\
nya M. crum, Plaintiff
,~ / :z;:::J'
. .
Richard A. Hod
efendant
an Carey
Attorney for Pl
LEGAL SERVICES,
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
SHERIFF'S RE'roRN
CCM1CiNWEALni OF PENNSYLVANIA:
COlJNI"{ OF ClMBERLAND
In The Court of Common Pleas of
Cumberland County, Pennsylvania
No. 94-2211 Civil Term
Temporary Protective Order
Protection From Abuse and Custody
Petition for Protective Order
and Custody
Tonya Marie Crum
VS
Richard Anthony Hodge
Barrv J. Horn
. ~ltlt Deputy Sheriff of
CUnberland County, Pennsylvania, who being duly swom according to law, says.
Temporary Protective Order Protection From Abuse
that he seIVed the withinand Custody Petition for Protective Order & Custody
upon Richard Anthonv Hodqe
, the defendant, at
11:44
o'clock
A .M. ~n / EDST, on the
01
day of June
, 192...4at
Cumberland County Prison. Claremont Rd..
Carlisle
Pennsylvania. by handing to Richard HOdge
, CUnberland County.
Temporary Protective Order Protect10n From Aouse
a true and attested copy of theand Custody Petition for Protective Order, &
Custody
and at the same time directing his attention to the contents thereof and
the "Notice to Plead" endorsed thereon.
Sheriff's Costs:
Docketing
SeIVice
Affidavit
Surcharge
l4.00
2.80
16.80
So answers:
:/7/ ~
r~~~1~ :.e
R. Thanas Kline, eriff
by
}
Swom and subscribed to before me
Deputy Shenff
this
qe::
...,
day of
\."~
.,
19 "iV A.D.
~)~/.A- t1. 7n.LL,~
Prothonotary
,
TONYA MARIE CRUM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-2211 CIVIL TERM
v.
RICHARD ANTHONY HODGE,
Defendant
PROTECTION FROM ABUSE
ORDER FOR CONTINUANCE
AND NOW, th i s 27 tt.. day of May, 1994, upon cons i derat i on of
the attached Motion for Continuance, the hearing scheduled for May
27, 1994, at 2:30 p.m., in Courtroom No.5 of the Cumberland County
Courthouse, Carlisle, Pennsylvania, has been continued until the
,11l~'day of eJ.'-<Jt<7-' ,1994 at .3:CtJ tJ .m.
77 .
The Temporary Protective Order of April 27, 1994, remains in
effect pending further order of Court.
A copy of this Order for Continuance will be provided to the
Carlisle Police Department by the attorneys for the plaintiff.
By the Court,
,- eLf
I / J "
i C(/~)L
.lJ Wesley Ol<J
Jr., J.
,
TONYA MARIE CRUM, IN THE COURT OF COMMON PLEAS OF
Plaintiff
v.
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-2211 CIVIL TERM
PROTECTION FROM ABUSE
RICHARD ANTHONY HODGE,
Defendant
MOTION FOR CONTINUANCE
The plaintiff, by and through her attorney, Joan Carey of
Legal Services, Inc. states the following:
1. A Temporary Protective Order was issued by this Court on
the 27th day of April, 1994, sCheduling a hearing for the 6th day
of May, 1994. When the defendant had not been served, this Court
9ranted a continuance until May 27th, 1994 at 2:30 p.m.
2. The Cumberland County Sheriff's Department has attempted
to serve the defendant I but has been unable to effect service.
3. The plaintiff requests that a continuance be entered and
that the Temporary Protect i ve Order remain in effect pendi ng
further order of court.
4. A copy of the Order for Continuance will be delivered to
the Carlisle Police Department by attorneys for the plaintiff.
WHEREFORE I the plaintiff requests that an Order for
Continuance be entered and that pending further Order of Court the
. ".,.
'.
Temporary Protect;ve Order rema;n in effect.
Respectfully subm;tted,
Carey
Attorney for Pl 'ntiff
LEGAL SERVICES, INC.
a Irvine Row
Carlisle PA 17013
(717) 243-9400
.'
"
TONYA MARIE CRUM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
v.
: NO. 94-2211 CIVIL TERM
RICHARD ANTHONY HOOGE,
Defendant PROTECTION FROM ABUSE
AND CUSTODY
AND NOW, this
reDER FOR CONTINUANCE
~ day of May, 1994, upon consideration of
the attached Motion for Continuance, the hearing scheduled for
May 8, 1994, at 8:30 a.m. in Courtroom No.5, is continued until
..-/)')~ ~? ,1994, at :;:30 P.M. The Temporary Protective
Order will remain in effect pending further order of Court.
A copy of this Order for Continuance will be provided to the
Carlisle police Department by the attorneys for the plaintiff.
By the Court,
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. VVOw<?
J.' esley Oler, Jr., J.
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TONYA MARIE CRUM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
v.
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94-2211 CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
RICHARD ANTHONY HODGE,
Defendant
MOTION FOR CONTINUANCE
The plaintiff moves this Court for an Order continuing the
hearing of this case until further Order of Court, on the grounds
that:
1. A Temporary Protective Order was issued by this Court on
the 27th day of May, 1994, scheduling a ~earing for the 6th day
of May, 1994, at 8:30 a.m.
2. The Cumberland County Sheriff's Department has attempted
to serve the defendant, but have been unable to effect service.
3. The plaintiff requests that a continuance be entered and
that the Temporary Protective Order remain in effect pending
further order of court.
4. A copy of the Order for Continuance will be delivered to
the Carlisle Police Department by attorneys for the plaintiff.
WHEREFORE, the plaintiff moves this Court to grant the
plaintiff's Motion, and to continue this matter until further
Order of Court.
~
, oan Carey
Attorney for Pl intiff
LEGAL SERVICES, INC.
8 Irvine Row
Carlisle PA 17013
(717) 243-9400
.
TONYA MARIE CRUM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 - ~ CIVIL TERM
vs.
: PROTECTION FROM ABUSE
: AND CUSTODY
RICHARD ANTHONY HODGE,
Defendant
.
.
AND NOW,
TEMPORARY PROTECTIVE ORDER
this ~~day of April, 1994, upon presentation
and consideration of the within Petition, and upon finding that
the plaintiff, TONYA MARIE CRUM, now residing at 111 North
Hanover Street, Apt. 2, CarliSle, Cumberland County,
Pennsylvania, is in immediate and present danger of abuse from
the defendant, RICHARD ANTHONY HODGE, the following Temporary
Order is entered.
The defendant, RICHARD ANTHONY HODGE, now residing at 152
West North street, Carlisle, Cumberland County, Pennsylvania, is
hereby enjoined from physically abusing the plaintiff, TONYA
MARIE CRUM. or placing her in fear of abuse and is ordered to
stay away from the residence located at 111 North Hanover Street,
CarliSle. Cumberland County, Pennsylvania, a residence which is
leased solely by the plaintiff. 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 $l,OOO.OO 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
defendant shall not nullify the provisions of the Court Order
directing the defendant to refrain from abusing the plaintiff.
Temporary custody of TYSHAWN TYLER HODGE is hereby awarded
to the plaintiff, TONYA MARIE CRUM.
The defendant is ordered to refrain from having any contact
with the plaintiff including, but not limited to, restraining the
defendant from harassing or stalking the plaintiff, and from
harassing the plaintiff's relatives.
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 f,t:i day of May, 1994, at ?~~c )l .m. in Courtroom
No.~ ,Cumberland County Courthouse, Carlisle, Pennsylvania.
The plaintiff may proceed in forma pauperis 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 Carlisle 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 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.A. Section 6113).
By the Court,
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TONYA MARIE CRUM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
:
: NO. 94 -
CIVIL TERM
vs.
.
.
PROTECTION FROM ABUSE
AND CUSTODY
RICHARD ANTHONY HODGE,
Defendant
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.
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
TONYA MARIE CRUM,
Plaintiff
: IN THE COURT OF COMMON PLEAS OF
.
.
: CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 -
CIVIL TERM
vs.
PROTECTION FROM ABUSE
AND CUSTODY
RICHARD ANTHONY HODGE,
Defendant
PETITION FOR PROTECTIVE ORDER
AND CUSTODY
RELIEF UNDER THE PROTECTION FROM ABUSE ACT
23 P.S. SECTION 6101
A. ABUSE
1. The plaintiff is an adult individual whose permanent
address is 111 North Hanover Street, Apt. 2, Carlisle, cumberland
County, Pennsylvania, 17013.
2. The defendant is an adult individual residing at 152
West North Street, Carlisle, Cumberland County, Pennsylvania,
17013.
3. The defendant is the father of the plaintiff's child.
4. Since approximately August 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 April 20. 1994, the defendant kicked the
plaintiff's door in, grabbed the plaintiff by the hair, pulled
her to the floor, and punched her in the chest leaving only when
the telephone rang. The plaintiff telephoned the police who came
and made a report. After the police left, the defendant knocked
on the plaintiff's window. causing the plaintiff to fear for her
safety and again call the police. After she hung up the
telephone, the defendant again kicked the door in and hit the
plaintiff's boyfriend with a 2 x 4 piece of wood. The plaintiff
again called the police. The Carlisle Police Department are
looking for the defendant and to the best of the kplaintiff's
knowledge, will be charging the defendant with buglary and
assault.
b. On or about April 13, 1994, the defendant came to the
plaintiff's residence at 2:00 a.m. and demanded to be let in.
When the plaintiff opened the door, the defendant pushed her out
of the way and came into the house. The defendant then pushed
the plaintiff toward the bedroom. When the plaintiff attempted
to call the police, the defendant hung up the phone and ripped
the cord out of the wall.
c. On or about April 3, 1994, the defendant came into the
plaintiff's residence through the kitchen window, went into the
plaintiff's bedroom where she was sleeping, put one hand over her
mouth and the other on her throat. The defendant would not let
the plaintiff out of bed and forced her to sleep with him.
d. On or about March 20, 1994, the defendant kicked in the
plaintiff's door and slapped the plaintiff across the face. The
defendant then punched the plaintiff in the arm and the middle of
her back, and pushed his fists into her back forcing her toward
the bedroom. The defendant threatened the plaintiff saying,
"There's nothing you can do because the PFA ain't no good no
more." The plaintiff's previous PFA had expired the day before.
During the period of time that the plaintiff's PFA was in effect,
the defendant violated it three times and spent time in the
Cumberland County Jail.
5. The plaintiff believes and therefore avers that she will
be 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 restrained
from having any contact with her, harassing or stalking the
plaintiff, and from harassing the plaintiff's relatives.
B. TEMPORARY CUSTODY
7. The plaintiff seeks temporary custody of the following
child:
~
Present Residence
Asm
TYSHAWN TYLER HODGE
111 N. Hanover street
Carlisle, PA
The child was born out of wedlock.
1 yr.
The child is presently in the custody of TONYA MARIE CRUM
who resides at 111 North Hanover Street, Carlisle, Pennsylvania.
During the child's lifetime, the child has resided with the
following persons and at the following addresses:
~
plaintiff &
defendant
Addresses
11 South Pitt Str~et
Carlisle, PA
Dates
5/4/93 - 8/93
plaintiff, Jane
Middaugh
121 Cold Spring Rd.
Carlisle, PA
8/93 - 9/93
(plaintiff's mother),
& Jerry Cobb (plaintiff'S
mother's boyfriend)
plaintiff, defendant,
and Helene & Richard
Davis (defendant's
grandparents)
152 West North St.
Carlisle, PA
9/93 - 12/93
plaintiff 111 N. Hanover St.
Carlisle, PA
plaintiff & 111 N. Hanover St.
defendant Carlisle, PA
plaintiff 111 N. Hanover St.
Carlisle, PA
12/93 - 2/93
2/93 - 3/93
3/93 - present
The mother of the child is TONYA MARIE CRUM, currently
residing at 111 N. Hanover Street, Apt. 2, Carlisle,
Pennsylvania.
She is single.
The father of the child is RICHARD ANTHONY HODGE, currently
residing at 152 W. North Street, Carlisle, Pennsylvania.
The plaintiff currently resides with the following persons:
~
Relationship
TYSHAWN TYLER HODGE
son
8. The plaintiff has not previously participated in any
litigation concerning custody of the above mentioned child in
this or any other Court.
9. The plaintiff has no knowledge of any custody
proceedings concerning this child pending before a court in this
or any other jurisdiction.
10. The plaintiff does not know of any person not a party
to this action who has physical custody of the child or claims to
have custody or visitation rights with respect to the child.
11. The best interests and permanent welfare of the child
will be met if custody is temporarily granted to the plaintiff
pending a hearing in this matter for reasons including the
following:
a. The plaintiff is a fit parent who can best take
care of her child.
b. The plaintiff has been the primary caretaker of the
child.
c. The defendant has shown by his abuse of the
plaintiff that he is not an appropriate role model for the
child.
C. LOSSES
12. The plaintiff has suffered losses as a result of the
abuse by the defendant. The losses are listed on Exhibit A which
is attached and incorporated herein by reference.
13. The plaintiff asks for attorney fees to be paid to
Legal Services, Inc., pursuant to the Protection from Abuse Act.
D. STATUS TO PROCEED IN FORMA PAUPERIS
14. The defendant is unemployed.
15. The plaintiff currently receives public assistance in
the amount of $316.00 per month.
16. The plaintiff does not have funds available to pay the
fees for filing and service.
from Abuse Act" of October 7, 1976, 23 P.S. section 6101 ~ ~.,
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:"
1. Requiring the defendant to refrain from abusing the
plaintiff or placing her in fear of abuse.
2. Requiring the defendant to refrain from having any
contact with the plaintiff. including, but not limited to,
restraining the defendant from harassing or stalking the
plaintiff, and from harassing the plaintiff's relatives.
3. Granting temporary custody of the minor child to
the plaintiff.
4. Ordering the defendant to stay away from the
residence located at 111 N. Hanover street, Carlisle.
5. Ordering the defendant to stay away from any
residence the plaintiff may in the future establish for
herself.
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:
l. Requiring the defendant to refrain from abusing the
plaintiff or placing her in fear of abuse.
2. Requiring the defendant to refrain from having any
contact with the plaintiff. including, but not limited to,
restraining the defendant from harassing or stalking the
plaintiff, and from harassing the plaintiff's relatives.
3. Ordering the defendant to stay away from the
,
residence located at 111 N. Hanover street, Carlisle.
4. Ordering the defendant to stay away from any
residence the plaintiff may in the future establish for
herself.
5. Ordering the defendant to reimburse the plaintiff's
out-of-pocket losses suffered as a result of the abuse
including but not limited to the losses listed on the
attached sheet marked Exhibit "A".
6. ordering the defendant to pay attorney fees to
Legal Services, Inc., pursuant to the Protection From Abuse
Act.
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 Carlisle Police Department as 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
17. The allegations of Count I above are incorporated
herein as if fully set forth.
18. The best interests and permanent welfare of the child
will be served by confirming custody in the plaintiff as set
forth in Paragraph 11 of the Petition.
WHEREFORE, pursuant to 23 P.S. Section 5301 gt ~., 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,
oa~ Carey
Attorney for Pla' tiff
LEGAL SERVICES, INC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
The above-named plaintiff, TONYA M. CRUM, 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. Section 4904, relating to
unsworn falsification to authorities.
Date:
Lj - 11., . CjLI
.
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(1",,/( ,'j I
Plaintiff
.--..~~J,
TONYA MARIE CRUM,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.
.
:
: NO. 94 -
CIVIL TERM
vs.
.
.
PROTECTION FROM ABUSE
AND CUSTODY
RICHARD ANTHONY HODGE,
Defendant
PROTECTION FROM ABUSE
LOSSES SHEET
Telephone Expense:
Repairs for ripped telephone cord
$ 15.80
Interior Repair Expense:
Repairs for door that had been kicked
in several times
$136.30
Clothing Expense:
Reimbursement for ripped clothing
$ 20.00
TOTAL
172 .10
EXHIBIT "A"
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