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HomeMy WebLinkAbout94-03284 a.: .., '- ~ ~ '" ~ ~ ,~ : ~ \ ::'l! \ " I / ,.' ,:\wplll<JlllIlvmtIKccf",PI'A VS. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94. ~,~b4' CIVIL TERM, 1994 PROTECTION FROM ABUSE NORMAN D. KEEFER and SHARON L. KEEFER, Plalntlffa/Petltloners NORMAN KEEFER, JR., and JEFFREY KEEFER, Defendants/Respondents (v AND NOW, this 17. day of June, 1994, upon presentation of the within Petition and upon finding that Norman D. Keefer and Sharon L. Keefer are In Immediate and present danger of abuse from the Defendants. the Defendants, Norman Keefer, Jr., and Jeffrey Keefer, are enjoined from physically abusing the Plaintiffs, Norman D. Keefer and Sharon L. Keefer, or placing them In fear of abuse. The Defendants are Ordered to refrain from having any contact with the Plaintiffs, from harassing the Plaintiffs, from coming to the Plaintiffs' place of business or to their residence at 934 Valley Road, Enola. Enola, Carlisle, PA 17025. This Order shall remain In effect until a Final Order I~ entered In this case. A hearing shall be held on this matter on the ~. 7" day of ill ~( , 1994. In Courtroom No. ~ of the Cumberland County Courthouse at Carlisle, PA, at , : . " ' o'clock, .,:-.M, The Enola Pollee Department shall be provided with a copy of this Order by Attorneys for Plaintiffs, This Order shall be enforced by any law enforcement agency where a violation occurs by arrest for Indirect criminal contempt without a warrant upon a 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 Defendants shall be taken without unnecessary delay before the Court that Issued the Order, When that Court Is unavailable, the Defendants shall be arraigned before the appropriate District Justice. Plaintiffs are permitted to proceed In forma Plluperls un ' ~yrirlng set above or further order of this Court. 1/ / By the C I. I (I ',' I j I J, ) .:\.,,11 \cjl\clj,,,,..IKr.rCl ,I'I'A VI. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94- CIVIL TERM, 1994 PROTECTION FROM ABUSE NORMAN D. KEEFER Ind SHARON L. KEEFER, Plllntlffl/Petltlonerl NORMAN KEEFER, JR., and JEFFREY KEEFER, Defendantl/Relpondents ~ YOU HAVE BEEN SUED IN COURT. If you wish to defend against the claims set forth In the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing in writing with the Court your defenses or objections to the claims set forth against you. You are warned that If you fall to do so the case may proceed without you and a Judgment may be entered against you by the Court without further notice for any money claimed In the Complaint 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 LAWVER AT ONCE. IF YOU DO NOT HAVE A LAWVER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURT HOUSE FOURTH FLOOR CARLISLE, PA 17013 (717) 240-6200 FLOWER, MORGENTHAL, FLOWER & LINDSAY Attorneys for Plaintiffs/Petitioners By: Carol J. Lindsay. Esquire 11 East High Street Carlisle, PA 17013 (717) 243.6613 1.0. No. 44693 "\wplllcJll4l,...,\K..rCl,I'I'A has placed by physical menace the Plaintiff Sharon D, Keefor In fear of Imminent serious bodily InJuries. Said Instances Include, but are not limited to, the following: A, On or about Friday, June 3, 1994, Norman Keefer, Jr., came to the Plaintiffs' residence and grabbed the Plaintiff by the throat, pinning her against a window and stating, "I'm going to kill your fucking ass" and, while holding her against the window by her throat, he drew back his fist as If to punch the Plaintiff and said, "If I hit you, I'll put you through this window: This Incident took placa at approximately 11 :30 o'clock A.M. At that time, Defendant pinned the Plaintiff for approximately 15 minutes, ranting, cursing and shouting until a friend of the Plaintiff's who witnessed the Incident pulled the Defendant off the Plaintiff stating, "You're going to kill her," to which the Defendant responded, "she deserves 11." After the Defendant was pulled from the Plaintiff. he left the residence leaving tho Plaintiff shaken and afraid, The Plaintiff called the Police. B. On or about May 17, 1994, after an argument at the Plaintiff's residence, the Defendant Norman Keefer, Jr., threw two plates at the Plaintiff and tried to push her down some stairs. 6. The Defendant Jeffrey Keefer has attempted to cause, or has Intentionally, knowingly or recklessly caused, bodily Injury to the Plaintiffs Norman D. Keefer and Sharon L. Keefer and has placed, by physical menace, the Plaintiffs In fear of Imminent serious bodily Injury, Said Instancal Include, but are not limited to the following: A. On or about May 16, 1994 at approximately 5:00 o'clock P.M., Jeffrey Keefer wrapped a telephone cord around Plaintiff Sharon L. Keefer's neck and squeezed It. holding her against him and shouting to the Plaintiff Norman D. Keefer, "Get away from me or I'm going to choke her." The Plaintiff Sharon L. Keefer was afraid for her life. Plaintiff Norman D. Keefer was able to pin Jeffrey Keefer and force him to release Plaintiff Sharon L. Keefer. The police were called and took tha Defendant from the Plaintiffs' home. B. In February, 1994, Defendant Jeffrey Keefer came to the rlalntlffs' home. An argument ensued and Defendant Jeffrey Keefer wrapped a telophone chord around Defendant Norman D, Keefer's neck, Defendant squeezed the chord until Plaintiff fell to his knees and his face turned blue as Defendent pulled on the chord. Plaintiff suffered Injuries to his neck and was fearful for his life, 4 .:\wpll\cjIWl'....\K..rn,I'I'A C, Approximately two years ago In Marysvllle, Pennsylvania, after an argument over money, Defendant Jeffrey Keefer wrapped a telephone cord around the neck of Plaintiff Norman D, Keefer and forced him to the floor as he pulled on the telephone cord, Plaintiff was fearful for his life and suffered Injuries to his neck, The Police were called and removed the Defendant from the house, D, In December 1993, on Lamb's Gap Road, Perry County, Pennsylvania, at approximately 10:30 o'clock A.M., Defendant Norman Keefer, Jr., hit the Plaintiff across her lower back with a log. The Plaintiff fell to the ground and then. when she got up. the Defendant hit her again on the arm with the log. During this Incident, the Defendant said, "I'll kill you. I hate you." As a result of this attack, the Plaintiff suffered a large lump on her arm and significant pain to her lower back. 7. The Plaintiffs believe and therefore aver that they will be In Immediate and present danger of abuse from the Defendant and that they arG In need of protection from such abuse, The fear of Immediate abuse from the Defendant Jeffrey Keefer who Is presently Incarcerated Is occasioned by the Plaintiffs' Inability to determine when Jeffrey Keefer will be released from Dauphin County Prison. 8. The Plaintiffs desire the Defendants to be ordered to refrain from any contact with them. 9. The Plaintiffs desire the Defendants to be ordered to refrain from any harassment of them, 10. The Plaintiffs desire the Defendants to be ordered to stay away from their home at 934 Valley Road, Enola, Cumberland County, Pennsylvania 17023 B, .CUSTODY 11, Plaintiff Sharon L. Keefer shares with Defendant Norman Keefer, Jr, custody of Justin Keefer, born July 28, 1988. A copy of the Custody Order of this Court Is attached hereto a8 Exhibit IIAII, 5 c:\wpJI \cjl\4.lvom\krrrr. ,III'A 12, The Plaintiffs ask this Court to enjoin the Defendant from visiting with said child at the Plaintiffs' residence and from taking him from Plaintiffs' residence until further order of this Court. C. IN FORMA PAUPERIS 13. The Plaintiffs herein are qualified by Legal Services Incorporated for pro bono representation In'the Instant case, 14. Plaintiff Sharon L. Keefer Is unemployed and Plaintiff Norman D. Keefer Is employed as a delivery man for Phillips Office Supplies. His monthly Income Is $970.00. In addition, the Plaintiffs receive $478,00 per month In social security payments for the child Justin Keefer. their rent Is $750.00 per month, which does not Include utllllles, 15. Plaintiffs are unable to pay the costs of the present action. WHEREFORE, pursuant to the provisions of the Protection from Abuse Act, 23 Pa. C,S.A. Section 6101 et seq., as amended, the Plaintiffs pray this Honorable Court to grant a Temporary Order requiring the Defendants to refrain from abusing the Plaintiffs or placing them In fear of abuse, requiring them to refrain from having any contact with the Plaintiffs, requiring them from harassing the Plaintiffs or coming to their residence, permitting them to proceed In forma pauperis and enjoining the Defendant Norman Keefer, Jr" from exercising rights of visitation or partial custody at the residence of the Plaintiffs. The Plaintiffs also request a hearing In accordance with the Protection from Abuse Act and, following such hearing, the entry of an Order requiring the Defendants to refrain from abusing the Plaintiffs, from harassing the Plaintiffs and from coming to the Plaintiffs' resldence, and enjoining the Defendant Norman Keefer, Jr" from visiting with Justin Keefer at 6 APR 8 1993 'G SHARON KBBFBR! Plalntiff V DAWN KBBFBR and NORMAN KBBFBR, JR. Defendants IIN THB COURT OF COMMON PLBAS OF ICUMBBRLAND COUNTY, PBNNSYLVANIA I INO. 4011 - CIVIL - 1991 I ICIVIL ACTION - CUSTODY I I OROIR AND NOW, thh q jk, day of flll'.:..L , 1993, upon consideration of the attached CUDtOdy conclrtdtor Report, it is ordered and directed as followsl I. The Paternal Grandmother Sharon Keefer and the Father Norman Keefer, Jr. and the Mother Dawn Strock shall enjoy shared legal custody of Kristin B. Keefer, born June 22, 19B6 and Justin M. Keefer, born July 2B, 19B7. 2. The Grandmother and the Father shall enjoy primary physical custody of Justin. 3. The Mother shall enjoy primary physical custody of Kristin. 4. Parties shall exchange physical custody of the minor children on alternating weekends from Friday at 6100 p.m. until Sunday at 5100 p.m. under a schedule whereby the children shall be together on each weekend. For the first two months, the alternating weekend schedule shall only be for one weekend per month, and thereafter shall alternate on consecutive weekends. 5. Neither party shall consume illegal drugs while they have custody of either of the minor children. 6. The part! havln9 the childre~ fo~ the waakond will ~rovide transportat on and will remain in the car during the transfer custody. 7. The parties will alternate holidays as followsl Baster, Memorial Day, Labor Day, Thanksgiving, and Christ- thl!l of mas. The Mother will have both ohildren from Christmas Bve, 1993 at 6100 p.m. until Christmas Day at 11100 a.m. The Father and Grandmother will have the children from 11100 a.m. Christmas Day until Deoember 26 at 11100 a.m. This schedule for Christmae shall alternate eaoh year thereafter. EXHIBIT I 1l^1I ,. .- . ',' LAW OFFICE6 FLOWER, MORGENTHAL, FLOWER . LINDSAY A I'l\OFESSIONAL coal'ORA 'nON ' tll;AST HIGH STREET, CARLISLE. PENN8Yl.VANIA 1101J.J01. ,. . vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94. ~,}1\4-CIVIL TERM,1994 PROTECTION FROM ABUSE NORMAN D. KEEFER and SHARON L. KEEFER, PI alntlffs/petltlon ers \ \ NORMAN KEEFER, JR., and JEFFREY KEEFER, Defendants/Respondents AND NOW, this nJl\ day of June, 1994, upon presentation of the within Petition and upon finding that Norman D. Keefer and Sharon L. Keefer are In Immediate and present danger of abuse from the Defendants, the Defendants, Norman Keefer, Jr., and Jeffrey Keefer, are enjoined from physically abusing the Plalnllffs, Norman D. Keefer and Sharon L, Keefer, or placing them In fear of abuse. The Defendants are Ordered to refrain from having any contact with the Plaintiffs, from harassing the Plaintiffs, from coming to the Plaintiffs' place of business or to their residence at 934 Valley Road, Enola, Enola, Carlisle, PA 17025. This Order shall remain ~~ ~ffe~ until a Final Order Is entered In this case. A hearing shall be held on this matter on the' .f \ day of :JII~' 1994, In Courtroom No.l1- of the Cumberland County Courthouse at Carlisle, PA, at ~ \ (I o'clock, ~,M. The Enola Pollee Department shall be provided with a copy of this Order by Attorneys for Plaintiffs. This Order shall be enforced by any law enforcement agency where a violation occurs by arrest for Indirect criminal contempt without a warrant upon a probable cause that this Order has been violated, whether or not the violation Is committed In the presence of the Pollee Officer. In the event that an arrest Is made under this section, the Defendants shall be taken without unnecessary delay before the Court that Issued the Order. When that Court Is unavailable, the Defendants shall be arraigned before the appropriate DI'ltrlct Justice. Plaintiffs are permitted to proceed in forma pauperis until the hearing set above or further order of this Court. , , By the Court, TRUE copy FROM RECORD In Testimony wher~, I here unlo sel ~ hand and Ihe seal of sa . al C:r11SIe. ~. j, TII 1l(\. IV t- 19~ .j)..., \ / PnI\)tO ~1~1 " .t /t) l /(;{ ~ IlJlA IY IIJt'L(~ ( J. ,ll'v ()'lL(~ J t t{r (?,I _ " J " ' , ' c:\...,JI\(jl\diY~I\Kecffr.P"A vs, IN THE counT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94- CIVIL TERM, 1994 PROTECTION FROM ABUSE NORMAN D. KEEFER Bnd SHARON L. KEEFER, Plaintiffs I Petition ers NORMAN KEEFER, JR., Bnd JEFFREY KEEFER, Defendants/Respondents NQII.CE YOU HAVE BEEN SUED IN COURT. II you wish to defend against the claims set forth In the following pages, you must take action within twenty (20) days after this Complaint and Notice are served. by entering a written appearance personally or by attorney and filing In writing with tha Court your defenses or objections to the claims set forth against you. You are warned that If you fall to do so the case may proceed without you and a Judgment may be entered against you by the Court without further notice for any money claimed In the Complaint 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 LAWVER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURT HOUSE FOURTH FLOOR CARLISLE, PA 17013 (717) 240-6200 FLOWER, MORGENTHAL, FLOWER & LINDSAY Attorneys for Plaintiffs/Petitioners By: Carol J. Undsay, Esquire 11 East High Street Carlisle. PA 17013 (717) 243-6513 I,D. No, 44693 ':\"1'IIIoII\4i.....\I(,.,,,,I'I'A has placed by physical menace the Plaintiff Sharon D, Keefer In fear of Imminent serious bodily Injuries. Said Instances Include, but are not limited to, the following: A, On or about Friday, June 3, 1994, Norman Keefer, Jr., came to the Plaintiffs' residence and grabbed the Plaintiff by the throat, pinning her against a window and stating, "I'm going to kill your fucking ass" and, while holding her against the window by her throat, he drew back his fist as If to punch the Plaintiff and said, "II I hit you, I'll put you through this window." This Incident took place at approximately 11 :30 o'clock A.M. At that time, Defendant pinned the Plaintiff for approximately 15 minutes, ranti~g, cursing and shouting until a friend of the Plaintiff's who witnessed the Incident pulled the Defendant off the Plaintiff stating, "You're going to kill her,' to which the Defendant responded, "she deserves It." Alter the Defendant was pulled from the Plaintiff, he lelt the residence leaving the Plaintiff shaken and afraid. The Plaintiff called the Police, B, On or about May 17, 1994, alter an argument at the Plaintiff's residence, the Defendant Norman Keefer, Jr., threw two plates at the Plaintiff and tried to push her down some stairs, 6. The Defendant Jeffrey Keefer has attempted to cause, or has Intentionally, knowingly or recklessly caused, bodily Injury to the Plaintiffs Norman D. Keefer and Sharon L. Keefer and has placed, by physical menace, the Plaintiffs In fear of Imminent serious bodily Injury. Said Instances Include, but are not limited to the following: A, On or about May 16, 1994 at approximately 5:00 o'clock P.M., Jeffrey Keefer wrapped a telephone cord around Plaintiff Sharon L. Keefer's neck and squeezed It, holding her against him and shouting to the Plaintiff Norman D, Keefer, "Get away from me or I'm going to choke her." The Plaintiff Sharon L. Keefer was efrald for her 1I1e, Plaintiff Norman D. Keefer was able to pin Jeffrey Keefer and force him to release Plaintiff Sharon L. Keefer. Tha pollee were called and took the Defendant from the Plaintiffs' home, fl In February, 1994, Defendant Jeffrey Keefer came to the Plelntlffs' home. An argument ensued and Defendant Jeffrey Keefer wrapped a telephone chord around Defendant Norman 0, Keefer's neck. Defendant squeezed the chord until Plaintiff fell to his knees and his face turned blua as Defendant pulled on the chord, Plelntlff suffered Injuries to his neck Bnd was fearful for his life. 4 c:ltlplll<jll4i'.....IK..r",rrA C. Approximately two years ago In Marysville, Pennsylvania, after an argument over money, Defendant Jeffrey Keefer wrapped a telephone cord around the neck of Plaintiff Norman D, Keefer and forced him to the floor as he pulled on the telephone cord. Plaintiff was fearful for his life and suffered Injuries to his neck. The Police were called and removed the Defendant from the house. D. In December 1993, on Lamb's Gap Road, Perry County, Pennsylvania, at approximately 10:30 o'clock A.M., Defendant Norman Kaafer, Jr" hit the Plaintiff across her lower back with a log, The Plaintiff fell to the ground and then, when she got up, the Defendant hit her again on the arm with the log. During this Incident, the Defendant said, "I'll kill you. I hate you." As a result of this attack, the Plaintiff suffered a large lump on her arm and significant pain to her lower back. 7. The Plaintiffs believe and therefore aver that they will be In Immediate and present danger of abuse from the Defendant and that they are In need of protection from such abuse. The fear of Immediate abuse from the Defendant Jeffrey Keefer who Is presently Incarcerated Is occasioned by the Plalntlffs' Inability to determine when Jeffrey Keefer will be released from Dauphin County Prison. 8. The Plaintiffs desire the Defendants to be ordered to refrain from any contact with them. 9. The Plaintiffs desire the Defendants to be ordered to refrain from any harassment of them. 10. The Plaintiffs desire the Defendants to be ordered to stay away from their home at 934 Valley Road, Enola, Cumberland County, Pennsylvania 17023 B. CUSTODY 11. Plaintiff Sharon L. Keefer shares with Defendant Norman Keefer, Jr. custody of Justin Keefer, born July 28, 1988, A copy of the Custody Order of this Court Is attached hereto as exhibit "A", 5 c:'....I.lell\4lvorulK.du,I'I'^ 12. The Plaintiffs ask this Court to enjoin the Defendant from visiting with said child at the Plaintiffs' residence and from taking him from Plaintiffs' residence until further order of this Court. C. IN FORMA PAUPERIS 13. The Plelntlffs herein are qualified by Legal Services Incorporated for pro bono , representation In'the Instant case. 14. Plaintiff Sharon L. Keefar Is unemployed and Plalnllff Norman D. Keefer Is employed as a delivery man for Phillips Office Supplies. His monthly Income Is $970.00, In addition, the Plaintiffs receive $478.00 per month In social security payments for the child Justin Keefer. Their rent Is $750.00 per month, which does not Include utilities. 15. Plalnllffs are unable to pay the costs of the present action. WHEREFORE, pursuant to the provisions of the Protection from Abuse Act, 23 Pa, C.S.A. Section 6101 et seq., as amended, the Plalntllls pray this Honorable Court to grant a Temporary Order requiring the Defendants to refrain from abusing the Plaintiffs or placing them In fear of abuse, requiring them to refrain from having any contact with the Plalnllffs, requiring them from harassing the Plaintiffs or coming to their residence, permitting them to proceed In forma pauperis and enjoining the Defendant Norman Keefer, Jr., from exercising rights of visltallon or partial custody at the residence of the Plaintiffs. The Plaintiffs also request a hearing In accordance with the Protection from Abuse Act and, following such hearing, the entry of an Order requiring the Defendants to refrain from abusing the Plaintiffs, from harassing the Plalntllls and from coming to the Plaintiffs' residence, and enjoining the Defendant Norman Keefer, Jr., from visiting with Justin Keefer at 6 APR 8 . SHARON KEEFERt Pla ntiff V DAWN KEEFER and NORMAN KEEFER, JR. Defendants IIN THE COURT OF COMMON PLEAS OF ICUMBERLAND COUNTY, PENNSYLVANIA I INO. 4011 - CIVIL - 1991 I ICIVIL ACTION - CUSTODY I I i/... AND NOW, this ~ day of the attached CUDtody Conci dir.ected as followsl 1. The Paternal Grandmother Sharon Keefer and the Father Norman Keefer, Jr. and the Mother Dawn Strock shall enjoy ehared legal custody of Kristin B. Keefer, born June 22, 1986 and Justin M. Keefer, born July 28, 1987. ORDER M:.L , 1993, upon coneideration of tor Report, it is ordered and 2. The Grandmother and the Father ehall enjoy primary phyeical custody of Justin. 3. The Mother shall enjoy primary phyeical custody of Kristin. 4. Parties shall exchange physical custody of the minor children on alternating weekends from Friday at 6100 p.m. until sunday at 5100 p.m. under a schedule whereby the children shall be together on eaoh weekend. For the first two months, the alternating weekend scheduls shall only be for one weekend per month, and thereafter shall alternate on consecutive weekends. 5. Neither party shall consume illegal drugs while they have custody of either of the minor children. 6. The party havIng the childre~ for the weakond will ~rovide transportation and will r.emain in the oar during the transfer custody. 7. The parties will alternate holidaye ae follows I Baster, Memorial Day, Labor Day, Thanksgiving, and Christ- th'!l of mas. The Mother will have both children from Chrietmae Eve, 1993 at 6100 p.m. until Christmas Day at 11100 a.m. The Father and Grandmother will have the children from 11100 a.m. Christmas Day until December 26 at 11100 a.m. This schedule for Christmas shall alternate each year thereafter. EXHIBIT I 1IT\" ~ H "l .... . .... ... ...:i ...l' 0 (:: ~ .tl ~ 7. t- .... N <>-0 ~.... ... ... N:;!~"" ;~~~ 'j ~ ~<!= :S 'tl ~g~~~ l'-~N'" <l N <l '~ 'tl <l ~ <l ' ... 'tl .... ~ ~ UJZ...... > o ~... 8 . ~ ~ ij p. 2l 8 lJ_~~Ul..J f:l W .~ ~~ ~ . o-...JUII1:I:>- l:)~< ~ . ~ o ~.... >-l:) Ul ~~ ~ to [) <LI.l-Z 000 ~8~~ . :Eo-.~~:I:z ~~ ~ ~~~@tii~ 1i~1i..J 8~~~ c:i~c:i"":' . 0 ~O~o(~~ ~~~~ ~ ;~ 0 . O~g: :::~ I~ it ..J 0( ~~~~ i~ ~ j _~~u -- -- ___t:i. . . . . .(j ~ 7~('f"ct'f . , I' L,.' , j' [)~ , "l .... H ... ... ~I . 0 (:: i III tJ ~ ~ !:; ... N ... ... ~~ ~, ! ~>-!= 1-< N..J~.... 'li ~~~~z ~rl ,~ 'tl ~ ~ . ij ~ <l ' ... 'tl UJ ~.... < o ~... ij .... ... lJ '" I- > 5: p, . 2l 8 ::lo":r:..J ~ li~ B ~ ~ D'. UIl1 >- ~~~~ [) , . ~ o ~.... >- L.:l Ul ;t~ t> 0 O(I!!-~ ~ ~~ '" :ED'.~~:r: o~o:z ~ .UJ-Ol-W Ii ,1i:J ~~ . ~~:!lt:Ultl. ci~ci'"" ;u Q 0 O~"~ul ~g~5 ~ . I~ o ~ It: ::: Ql .~ I~ el ~ 0( ~ ~~_S ~p. < - - -- u ~ " . ~ - - ~" =~_::"""'_~~;"::;-~~_"'__.=:,:::::.':':.;,."'_ =,:::;;::,,-'-'-0:;:::':=-':=:=":::: _=-~._.... _~~__=__.'_ - --- . . 'AlIn II H~fl' , t {~ , ';'''1'llleJlldlvrmlk.dll,PJ''' vs. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNtY, PENNSYLVANIA 94~,5) ~L/CIVIL TERM, 1994 PROTECTION FROM ABUSE NORMAN D. KEEFER and SHARON L. KEEFER, Plaintiffs/Petitioners NORMAN KEEFER, JR., and JEFFREY KEEFER, Defendants/Raspondents IEMfQBABY.QB.Q.EB f~ AND NOW, this /1r day of June, 1994, upon presentation of the within Petition and upon finding that Norman D.~r and Sharon L. Keefer are In Immediate and present danger of abuse from the Defendants, the Defendants, Norman Keefer, Jr., and Jeffrey Keefer, are enjoined from physically abusing the Plaintiffs, Norman D. Keefer and Sharon L. Keefer, or placing them In fear of abuse. The Defendants are Ordered to refrain from having any contact with the Plaintiffs, from harassing the Plaintiffs, from coming to the Plaintiffs' place of business or to their residence at 934 Valley Road, Enola, Enola, Carlisle, PA 17025. This Order shall remain In effect until a Final Order ~slt~~d In this case. A hearing shllll be held on this matter on the .::JYL- day of /_ . t. , ~994, Infourtroom No. ,?--Of the Cumberland County Courthouse at Carlisle, PA, at "rD 0 clock, ~,M. The Enola Police Department shall be provided with a copy of this Order by Attorneys for Plaintiffs. this Order shall be enforced by any law enforcement agency where a violation occurs by arrest for Indirect criminal contempt without a warrant upon a 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 Defendants shall be taken without unnecessary delay before the Court that Issued the Order. When that Court Is unavailable, the Defendants shall be arraigned before the appropriate District Justice, Plaintiffs are permitted to proceed In forma pauperis until the hearing set above or further order of this Court, By the Court, c' , (I, ;t.. , ,/ --\..Z'--'a~- . )> C'Jj -Alf/ tr~' (=.", 1)(- "'-r: I--r - / I ~ _=-J c:\wp) I \ejl\di\lD.u\Kedcr ,Pi'A VB. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA 94- CIVIL TERM, 1994 PROTECTION FROM ABUSE NORMAN D. KEEFER and SHARON : L. KEEFER, Pial ntlNs /Petltlon ers NORMAN KEEFER, JR., and JEFFREY KEEFER, Defendants/Respondents NQI.lCf YOU HAVE BEEN SUED IN COURT. II you wish to defend agalnsttha claims set forth In the following pages, you must take action within twenty (20) days after this Complaint and Notice are served, by entering a written appearance personally or by attorney and filing In writing with the Court your defanses or objections to the claims set forth against you. You are warned that If you fall to do so the case may proceed without you and a Judgment may be entered against you by the Court without further notice for any money claimed In the Complaint 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 LAWVER AT ONCE. IF YOU DO NOT HAVE A LAWVER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE BET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR CUMBERLAND COUNTY COURT HOUSE FOURTH FLOOR CARLISLE, PA 17013 (717) 240-6200 FLOWER, MORGENTHAL, FLOWER & LINDSAY Attorneys for Plaintiffs/Petitioners By: Carol J, Undsay, Esquire 11 East High Street Carlisle, PA 17013 (717) 243-5513 1.0, No. 44693 C:'''1'J IIcJI\4l'.....\K..,or, I'I'A has placed by physical menace the Plaintiff Sharon D, Keefer In fear of Imminent serious bodily InJuries, Said Instances Include, but are not limited to, the following: A, On or about Friday, June 3, 1994, Norman Keefer, Jr" came to the Plaintiffs' rosldence and grabbed the Plaintiff by the throat, pinning her against a window and stating, "I'm going to kill your fucking ess' and, while holding her against the window by her throat, he drew bBck his fist as If to punch the Plaintiff Bnd said, "If I hit you, I'll put you through this window," This Incident took pi Bee Bt approximately 11:30 o'clock A,M, At that time, DefendBnt pinned the Plaintiff for approxlmBtely 16 minutes, ranting, cursing and shouting until a friend of the Plaintiff's who witnessed the Incident pulled the Defendant off the Plaintiff stBtlng, "You're going to kill her,' to which the Defendant responded, "she deserves It." After the Defendant was pulled from the Plaintiff, he left the residence leaving the Plaintiff shaken and afraid. The Plaintiff called the Pollee, B, On or about May 17, 1994, Bfter Bn Brgument Bt the PIBlntlff's residence, the Defendant NormBn Keefer, Jr" threw two plates Bt the Plaintiff Bnd tried to push her down some stairs. 6. The DefendBnt Jeffrey Keefer hBS Bttempted to cause, or has Intentionally, knowingly or recklessly caused, bodily Injury to the Plaintiffs Norman D. Keefer and Sharon L. Keefer and has placed, by physical menace, the PIBlntlffs In fear of Imminent serious bodily Injury. Said Instances Include, but are not limited to the following: A, On or about May 16, 1994 Bt Bpproxlmately 5:00 o'clock P,M" Jeffrey Keefer wrapped a telephone cord around Plaintiff Sharon L. Keefer's neck and squeezed It, holding her agBinst him and shouting to the Plaintiff Norman D, Keefer, "Get away from me or I'm going to choke her," The PIBlntlff Sharon L. Keefer was afraid for her life, Plaintiff Norman D, Keefer WBS able to pin Jeffrey Keefer and force him to release Plaintiff ShBron L. Keefer. The pollee were called and took the Defendant from the Plaintiffs' home, 8, In February, 1994, Defendant Jeffrey Keefer cama to the Plaintiffs' home, An argument ensued and Defendant Jeffrey Keefer wrapped a telephone chord Braund Defendant Norman D, Keefer's neck, Defendant squeezed the chord until Plaintiff fell to his knees and his face turned blue as Defendant pulled on the chord, Plaintiff suffered Injuries to his neck and was fearful for his life. 4 c:\",J l\cjl\divom\Kctltr .I'IIA C. Approximately two years ago In Marysvllle, Pennsylvania, altar an argument over money, Defendant Jeffrey Keefer wrapped a telephone cord around the neck of Plaintiff Norman D, Keefer and forced him to the floor as he pulled on the telephone cord. Plaintiff was fearful for his life and suffered Injuries to his neck, The Police were called and removed the Defendant from the house, D. In December 1993, on Lamb's Gap Road, Perry County, Pennsylvania, at approximately 10:30 o'clock A,M" Defendant Norman Keefer, Jr., hit the Plaintiff across her lower back with a log, The Plaintiff fell to the ground and then, when she got up, Ihe Defendant hit her again on the arm with the log. During this Incident, the Defendant said, "I'll kill you, I hate YOll,' As a result of this attack, the Plaintiff suffered a large lump on her arm and significant pain to her lower back. 7. The Plaintiffs believe and therefore aver that they will be in immediate and present danger of abuse from the Defendant and that they are In need of protection from such abuse. The fear of Immediate abuse from the Defendant Jaffrey Keefer who Is presently Incarcerated Is occasioned by the Plaintiffs' Inability to determine when Jeffrey Keefer will be released from Dauphin County Prison. 8. The Plaintiffs desire the Defendants to be ordered to refrain from any contact with them, 9. The Plaintiffs desire the Defendants to be ordered to refrain from any harassment of them, 10, The Plaintiffs desire the Defendants to be ordered to stay away from their home at 934 Valley Road, Enols, Cumberland County, Pennsylvania 17023 B. CUSTODY 11, Plaintiff Sharon L. Keefer shares with Defendant Norman Keefer, Jr, custody of Justin Keefer, born July 28, 1988, A copy of the Custody Order of this Court Is attached hereto as exhibit llA", 5 C:\"1'J I \cJI\dlvOR,\Kcdu ,I'I'A 12. The Plaintiffs ask this Court to enjoin the Defendant from visiting with said child at the Plaintiffs' residence and from taking him from Plaintiffs' residence until further ordar of this Court, C. IN FORMA PAUPERIS 13, The Plaintiffs herein are qualified by Legal Services Incorporated for pro bono representation In'the Instant case. 14. Plaintiff Sharon L. Keefer Is unemployed and Plaintiff Norman D. Keefer Is employed as a delivery man for Phillips Office Supplies, His monthly Income Is $970,00, In addition, the Plaintiffs receive $478,00 per month In social security payments for the child Justin Koefer. Their rent Is $750,00 per month, which does not Include utilities. 15. Plaintiffs are unable to pay the costs of the present action. WHEREFORE, pursuant to the provisions of the Protection from Abuse Act, 23 Pa, C,S.A. Section 6101 et seq., as amended, the Plaintiffs pray this Honorable Court to grant a Temporary Order requiring the Defendants to refrain from abusing the Plaintiffs or placing them In fear of abuse, requiring them to refrain from having any contact with the Plaintiffs, requiring them from harassing the Plaintiffs or coming to their residence, permitting them to proceed In forma pauperis and enjoining the Defendant Norman Keefer, Jr" from exercising rights of visitation or partial custody at the residence of the Plaintiffs, The Plaintiffs also request a hearing In accordance with the Protection from Abuse Act and, following such hearing, the entry of an Order requiring the Defendants to refrain from abusing the Plaintiffs, from harassing the Plaintiffs and from coming to the Plaintiffs' residence, and enjoining the Defendant Norman Keefer, Jr., from visiting with Justin Keefer at 6 I, APR 8 SHARON KEEFERt Ph ntiff V DAWN KEEFER and NORMAN KEBFER, ,TR. Defendants IIN THB COURT OF COMMON PLEAS OF ICUMBERLAND COUNTY, PBNN8YLVANIA I INO. 4011 - CIVIL - 1991 I ICIVIL ACTION - CUSTODY I I ORDER AND NOW, this qi/... day of {)Jv:...L , 1993 upon consideration of the attached Cuotedy Conci~tor Report, it is ordered and dirscted as follows I 1. The Paternal Grandmother Sharon Keefer and the Father Norman Keefer, Jr. and the Mother Dawn Strock shall enjoy shared lsgal custody of Kristin B. Keefe~, born June 22, 1986 and Justin M. Keefer, born July 28, 1987. 2. The Grandmother and the Father shall enjoy primary physical custody of Justin. 3. The Mother shall enjoy primary physical custody of Kristin. 4. Parties shall exchange physical custody of the minor children on alternating weekends from Friday at 6100 p.m. until Sunday at 5100 p.m. under a schedule whereby the children shall be together on each weekend. Par the first two months, the alternating weekend schedule shall only be for one weskend per month, and thereafter shall alternate on consecutive weekends. 5. Neither party shall consume illegal drugs while they have custody of either of the mincr children. 6. The party havIng the chi1dre~ for the wukond will ~rovids transportation and will remain in the car during the transfsr custody. ' 7. The parties will alternate hclidays ae followSI Baster, Memorial Day, Labor Day, Thanksgiving, and Christ- th'!l of mas. The Mother will have both children frcm Christmae Eve, 1993 at 6100 p.m. until Christmas Day at 11100 a.m. The Father and Grandmother will have ths children from 11100 a.m. Christmas Day until December 26 at 11100 a.m. This schedule for Christmas shall alternate each year thsreafter. EXHIBIT I "/,\11