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Home My WebLink About94-02927 REBEKAH J. STAUB CHRISTOPHER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . v. CIVIL ACTION - LA W No.9'f -.J:lJ-,::IVIL T9H" 7i~ PROTECTION FROM ABUSE . . . . JOHN CHRISTOPHER, III, Defendant . . : TEMPORARY PROTECTIVE ORDER AND NOW, this ls1 day of June, 1994, upon presentation and consideration of the within Petition, and upon finding that Rebekah J. Staub Christopher, now residing in Cumberland County, PeMsylvania, is in immediate and present danger of abuse from the defendant, John Christopher, the following Temporlll}' Order is entered, The defendant, John Christopher, whose current address is 4225 Roth Lane, Mechanicsburg" PeMsylvan!a 17055, and/or 93 "Bot Street, Carlisle, PeMSylvania 17013, is hereby enjoined from physically abusing the plaintiff, Rebekah J. Staub and their minor child, or placing them in fear of abuse and is ordered to stay away from any location where they may reside, The plaintiff is hereby awarded primlll}' physical custody of the parties' minor child, A1leshia Y. Christopher. The defendant is hereby notified that if he fails to follow this Order, he may be in indirect criminal contempt which is punishable by a fine not to exc~ed $1,000,00 and/or by a sentence of up to six months in jail and any other appropriate punishment. Resumption of co-residence on the part of the plaintiff and the defendant shall not nullifY the provisions of the court order directing the defendant to refrain from abusing the plaintiff. This Order shall remain in effect until a final order is entered in this case, A hearing shall beheld on this matter on the 2~ day of June, 1994, at r.~,(, l1,m, in Courtroom No. .- !:J . Cumberland County Courthouse, Carlisle, PeMsylvania, " The Cumberland County Sheriff's Office shall attempt to make service at the plaintifi's request, but service may be accomplished under any applicable rule of Civil Procedure. The PeMsylvania State Police, Carlisle Substation, Warden of the Cumberland County Prison, Sheriff of Cumberland County, the District Juslice of Carlisle, and 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 uMecessary delay before the court that issued the Order. When that court is unavailable, the defendant shall be arraigned before the appropriate district justice. (23 Pa,C.S.A. ~6113). BY THE COURT, ~ ~i cJ' UL~00l · J. 2 REBEKAH J. STAUB CHRISTOPHER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA . . . . CIVIL ACTION. LA W NO. CIVIL 1994 v. . . JOHN CHRISTOPHER, III Defendant . . PROTECTION FROM ABUSE . . NOTICE You have been sued in court, If you wish to defend against the claims set forth in the following pages, you must take action promptly after this Petition, Order and Notice are served, by appearing personally or by attorney at the hearing scheduled by the Court and presenting to the Court your defenses or objections to the claims set forth against you, You are warned that if you fail to do so the Court may proceed without, 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 NOTICE 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 Fourth Floor Cumberland County Courthouse Carlisle, PA 17013 (717) 240-6200 3 REBEKAH J. STAUB CHRISTOPHER, : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERI..AND COUNTY, PENNSYLVANIA , , v. . . CIVIL ACTION - LA W NO. CIVIL 1994 : JOHN CHRISTOPHER, III Defendant . . . . PROTECTION FROM ABUSE PETITION FOR PROTECTIVE ORDER AND NOW comes the Petitioner, Rebekah 1. Staub Christopher, by her attorneys, Irwin, Irwin & McKnight, Esquires and presents this petition for a protective order under the Protection from Abuse Act, 23 Pa,C,S,A, Section 6101 et seq" representing as follows: 1. The Petitioner is Rebekah 1, Staub Christopher, an adult individual presently residing at 1 053 Rebecca Street, Carlisle, Pennsylvania 17013. 2, The Respondent is 10hn Christopher, III, an adult individual residing at 4225 Roth Lane, Apt 103, Mechanicsburg, Pennsylvania 17055. 3, The parties were married on April 4, 1994 in Hagerstown, Maryland, There has been one (1) child born to the parties: namely, Alleshia y, Christopher, age two (2), born February 12, 1992, 4 4, While the parties dated, the defendant has displayed much violence toward the plaintiff including severe physical and mental abuse, 5, The defendant's acts of violence include but are not limited to the following: a, On Friday evening on May 20, 1994, the parties were together at their apartment located at 4225 Roth Lane, Apt. 103, Mechanicsburg, Pennsylvania 17055, with their daughter, A1leshia and with Ashley, age (4), another daughter of the plaintiff. At approximately 11 :00 P,M" the parties had an argument. The defendant threatened to leave and then the defendant dragged the plaintiff out of bed and then slammed the plaintiff against the wall. After a short time, the defendant struck the plaintiff on the face, The plaintiff then left the apartment with both children and has not returned, b. On Monday, May 30, 1994, the plaintiff went to pick up her daughter, Alleshia, at the residence of the defendant's mother, Lisa Christopher at 93 "B" Street, Carlisle, in order for her to visit her grandmother, The plaintiff arrived at 12:00 noon to discover Lisa and A1leshia gone and the defendant alone in the residence, He stated that he had hidden their daughter and slapped the plaintiff in the face and threw her to the ground, The defendant has not returned A1leshia to the plaintiff. 6, Plaintiff avers that she is in fear of serious bodily injury by the defendant, and also fears that her child is in danger, 5 WHEREFORE, Plaintiff respectfully requests this Honorable Court to enter an order providing that : a, Defendant shall refrain from abusing, threatening with violence, harassing or visiting the Petitioner in any manner; b. Defendant shall be excluded from any residence where the Petitioner and her minor children may reside; c. Plaintiff shall be granted primary physical custody of the parties' minor child; and said child must be immediately returned to the plaintiff; and d, Such other relief as this Court deems necessary. Respectfully submitted, May3!,1994 6 . . VERIFICATION The foregoing Petition is based upon infonnation which has been gathered by my counsel and myself in the preparation of this lawsuit. The language of this document may in part be the language of my counsel and not my own, I have read the statements made in this Petition and to the extent that they are based upon infonnation which I have given to my counsel, they are true and correct to the best of my knowledge, infonnation and belief. To the extent that the contents of the statements are that of counsel, I have relied upon counsel in making this verification, I understand that false statements herein made are subject to the penalties of 8 Pa,C,S, ction 4904, relating to unsworn falsification to authorities, /1 Dale: May 31, 1994 . ~ I~ t ' '" ''''~ lll-..!) '~ ~ ~ ~~ 0 .",.. ~~ ~~ \.() en 1~ ~ ~ . , ~,.!). ~ = ... -..9 - --.: -- ~"'l "J Z9~ ~ * :tl:. t; ':) 'l1 " l.t) ~ ~ -11~ Q '" :::t- => -, ~ H ~< ... ... ~ 0.... ... r:: 0 N ",:a ..... '" N ..:... 'tl 1-4 . N i5~ ~ r:: r:: Z . ~ ':' :=.... Ql ~ a .. !:! ....l>< ~ '" '" ... " .. ~u)~~CIl 0..... Ql U 5 ~ 0 z[@::'ig:~ f-<'" ~ ..: . ~ ~ ~ " '" . ~ ., ~ VI ~ O~ .... .... .... ~fi! .. ~"'I ..: .... ~ 0 ~ z ....l:O: := .... ~o CIll ;; .. < . ~ 0 "Zt-40 U w ... ~ UI::O:>": . z~ a z "- % ,. 0 ........~ o:l ..: 0:> . 0 VI ~~f-<U ~ ~ .... .... .! ~ . .. z o U z := f-<f-< . z 0< 0 f-< . '" ....U w ~ .. . VI f-ou .... '" > 0 f-<~ "- .. ..: ....l f-< f-< ~f-< . .. 0 :r Ii P~t-4 U . '" "'0 1-4 . ~ o :>-t1.t ..., .... ..: ~ . 0 VI c.J HOE-! ..: '" . III ;lUZO ~ := w :; ~ ...: U .... . ~ :=~ '" ~ ~ ~~ ~ S"J o:l ~ 0 ....U ..., .... ; ... /.,,\\' Olli('~" '-"- 'JUN (J 1 if]94 .' lHWIN, IRWIN & ~lclC'nGHT REBEKAH J. STAUB CHRISTOPHER, I IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA I v. I 94-2927 CIVIL TERM I r JOHN CHRISTOPHER, III, Defendant PROTECTION FROM ABUSE ORDER OF COURT AND NOW, this 8th day of June, 1994, upon consideration of the Petition for Protective Order, and it being related in open court at the time scheduled for a hearing on this matter by counsel for the Plaintiff, Marcus A. McKnight, III, Esquire, that the sheriff has been unable, as of this date, to serve the Defendant with notice of the hearing and a copy of the petition, and it being further related that the child in this matter has been returned to the mother, upon motion of the Plaintiff, the hearing in this matter is continued generally in order to facilitate service upon the Defendant, and the temporary protective order previously entered on June 1, 1994, shall remain in full force and effect pending a rescheduled hearing. By the Court, . dt-.. J Wesley 01 Marcus A. McKnight, III, Esquire Counsel for Plaintiff .,', Islr ~6, ~~ 1;'; S C NO, L...'1-oc,. ~"lF c1,?<-o ,./'11'14. ..... p. . , l~ . ;. ~ ;.. .. -....... w". '. . -. ~ '. ,.. , ... '; . .' r . .. ... .'.' ..--.., .~-,.. ........ .'-. . SHERIFF'S RETURN CCMlONWEAL'TH OF PENNSYLVANIA, COl./NI"i OF CLMBERLAND Rebekah J. Staub Christopher In the Court of Common Pleas of Cumberland County, Pennsylvania No. 94-2927 Civil Term Temporary Protective Order Protection from Abuse Notice and Petition and Continuance Order VS John Christopher III Audrey G. Adams, , ~~ffj!(~ Deputy Sheriff of Cunberland County, Pennsylvania, who being duly sworn according to. law, savsA Temporary Protect~ve Order Protect~on from buse that he served the withinNotice and Petition and Continuance Order upon John Christopher III o'clock . the defendant. at 3:45 P. .M.~ / EDST. on the , 19-2.4at 9th June day of Cumberland County Sheriff Office, Carlisle Pennsylvania, by handing to John Chris topher II I . Cunberland County, a true and attested copy of the Protection from Abuse Petition and Order , 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 So answers: 14.00 2.80 ,~/~ '. .. .....t'... ... ....-.~;... .. 1. R. Thanas Kline. Sheriff 2.00 18.80 Pd. by Atty. 6-10-94 by () II ",.eu 11. t2~nw..-I Depu t~Sheriff Sworn and subscribed to before ere this N~ day of ':'_,). ~,. 19 (,''f A.D. ~~~~ Q hL..{u._ 1'~7 - Prothonotary - REBEKAH J. STAUB CHRISTOPHER, . . Plaintiff . . . . v. . . . . JOHN CHRISTOPHER, III, . . Defendant . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION - LAW 94-2927 CIVIL TERM AND NOW, this ORDER OF COURT 1'- fL, day of June, 1994, a hearing on the Petition for Protective Order in the above matter is SCHEDULED for Monday, July lB, 1994, at 3:30 p.m., in Courtroom No.5, Cumberland County Courthouse, Carlisle, Pennsylvania. The Temporary Order entered on June 1, 1994, shall remain in full force and effect pending the said hearing. BY THE COURT, J. Marcus A. McKnight, III, Esq. 60 West Pomfret Street Carlisle, PA 17013 Attorney for Plaintiff Taylor P. Andrews, Esq. 7B W. Pomfret Street Carlisle, PA 17013 Attorney for Defendant :rc .,,'r ; .J ,t.I '~II c/<> ..r> ,~ ,~ 1 J J [i I! ~ REBEKAH J. STAUB CHRISTOPHER, : IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA v. . CIVIL ACTION - LAW . . PROTECTION FROM ABUSE . JOHN CHRISTOPHER, III, . . Defendant . 94-2927 CIVIL TERM . IN RE: PROTECTION FROM ABUSE ORDER OF COURT AND NOW, this 18th day of July, 1994, upon consideration of the Petition for Protective Order in the above-captioned matter, and pursuant to an agreement reached and dictated in open court in the presence of the parties, it is ordered and directed as follows: 1. The Temporary Protective Order entered June 1, 1994, is hereby made permanent, and Defendant, John Christopher, III, is hereby enjoined from physically abusing the Plaintiff, Rebekah J. Staub Christopher, and their minor child, Alleshia Y. Christopher, age two, born February 12, 1992, or placing either of them in fear of abuse. 2. Plaintiff, Rebekah J. Staub Christopher, is awarded physical custody of the parties' minor child, Alleshia Y. Christopher, subject to the right of John Christopher, III, to have partial custody each week from 6:00 p.m. on Thursday until Sunday at 9:45 a.m. John Christopher, III, shall pick up said Alleshia Y. Christopher on Thursday, and he or his mother shall deliver Alleshia Y. Christopher on Sunday to the JUt Z" IU so 4H '911 ,l'f fC!;. , " ":)/, 'TMi)' '. ! -" ".L~;~.Cl' c,,\...., T'f . ;"'; '" ~i :'Yi. ...~... ~ >" " '.., , I r ,I I'i I' -. " .... plaintiff, Rebekah J. Staub Christopher. 3. This Order shall remain in effect until June 1, 1995, unless modified or terminated prior to that date by this Court. 4. The carlisle Borough 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 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 P.S. Section 6113). By the Court, , I J. MARCUS A. McKNIGHT, III, ESQUIRE For the Plaintiff _ ~... ~eL"':~fk '1loLS Iq<j. ...t p, TAYLOR P. ANDREWS, ESQUIRE For the Defendant wcy