HomeMy WebLinkAbout94-03949
JESSICA ANN RINIER,
Plaintiff
IN TilE COURT OF COHHON PLEAS OF
CUHBERLAND COUNTY, PENNSYLVANIA
NO, 94 - 3949
CIVIL TERM
v.
PROTECTION FROH ABUSE
AND CUSTODY
SCOTT HARRISON BROWN,
Defendant
~ROTECTIVE ORDER
AND NOW, this ~ day of July, 1994, upon consideration of
the Consent Agreement of the parties, the following Order is
entered:
1. The defendant, SCOTT IIARRISON BROWN, is enjoined from
physically abusing the plaintiff, JESSICA ANN RINIER, or from
placing her in fear of abuse.
2. The defendant, SCOTT HARRISON BROWN, is ordered to
refrain from harassing or stalking the plaintiff, and from
harassing the plaintiff'S relatives.
3. The defendant, SCOTT HARRISON BROWN, is ordered to stay
away from the plaintiff'S residence located at 121 Third Street,
Lemoyne, except to pick up and drop off the child at the doorway
of the plaintiff'S apartment.
4. This Order shall remain in effect for a period of one
year.
5. The Lemoyne 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,
JESSICA ANN RINIER,
plaintiff
IN THE COURT OF COMMON PLEAS OF
CUHBERLAND COUNTY, PENNSYLVANIA
NO. 94 - 3949
CIVIL TERM
v.
PROTECTION FROH ABUSE
AND CUSTODY
SCOTT HARRISON BROWN,
Defendant
1\ ~~ CUSTODY ORDER
AND NOW, this'Jdl- day of July, 1994, upon consideration of
the parties' Consent Agreement, the following Order is entered
with regard to custody of the parties' child, VINCENT BROWN.
1. The plaintiff, hereinafter referred to as the mother,
and the defendant, hereinafter referred to as the father, will
share physical and legal custody of the child.
2. The mother and father will alternate physical custody
each week transfering custody on Sundays at 6:00 p.m.
3. The mother and father will notify each other of all
medical care the child receives while in that parent's care.
Each parent will notify the other immediately of medical
emergencies which arise while the child is in that parent's care.
4. 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
other parent.
child's, i t'tlVl!.or "r~~/jlect
',~'I: I'i' : I
1 \'J!
for the
J.
i
JESSICA ANN RINIER,
plaintiff
IN TilE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 - 3949
CIVIL TERM
v.
PROTECTION FROH ABUSE
AND CUSTODY
SCOTT IlARRISON BROWN,
Defendant
CONSENT AGREEHENT
This Agreement is entered on this
day of July, 1994,
by the plaintiff, JESSICA ANN RINIER, and the defendant, SCOTT
HARRISON BROWN. 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, SCOTT HARRISON BROWN, agrees to refrain
from abusing the plaintiff, JESSICA ANN RINIER, or from placing
her in fear of abuse.
2. The defendant agrees not to harass the plaint:iff or the
plaintiff'S relatives.
3. The defendant agrees to stay away from the residence
located at 121 Third street, Lemoyne, except to pick up and drop
of the child at the doorway of the plaintiff'S apartment.
4. The defendant, although entering into this Agreement,
does not admit the allegations made in this Petition.
5. The defendant understands that the Protective order
entered in this matter shall be in effect for a period of one
year,
6. The defendant understands that t:his Order will be
enforceable in the same manner as the Court's prior Temporary
Protect:ive Order entered in this case.
7. The defendant and the plaintiff agree to the entry of
an Order providing for the following custody schedule for their
child:
a. The plaintiff, hereinafter referred to as the
mother, and the defendant, hereinafter referred to as
the fnther, will share physical and legal custody of
t:he child.
b. The mother and tather will alternate physical
custody each week transfering custody on sundays at
6:00 p.m.
c. The mother and father will notify eoch other of all
medical care the child receives while in that parent's
care. Each parent will notify the other immediately of
medical emergencies which arise while the child is in
that porent's care.
d. Neither party shall do anything which moy est:range
the child from the other parent, or injure the opinion
of the child as to the other parent or which may homper
the free and natural development of the child's love or
respect for the other parent.
WHEREFORE, the parties request that on Order of court be
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OTN ABUSIl
HD-0000024-94
. Final 1"1.11"0 Authorllyr1o ~ lOlT'pl.'''d by filla' IU\llng Authority , eTr.n'!'II~ mmln1tllllnulngAI'Ihollty
CBARLIlS A, CLEHENT, JR, 0911101 r
e Nlma and AddIH'(( .,1 Nama' 1!l1I ' Da"I~.nr" B I~~'I N_u y'~ln!lI.II..u'nu-Authollly
CR-210-94
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240 S, 4TH ST. JE....RIl "RANKS
LIDlOYNIl. PA 17043 LEHOYHE POLICE DIlPT
655 MARKET STRIlIlT
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07 125 I 94 B CUHHIlRLAND CTY PRISO CARLISLE PA
COPY, CLERK OF COURTS
Cenified this 27 t It
day of
,1994
Myc
Aapc 601 A.94
PRINTED, 7/27/94 11120107
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I UOt~1t ~mber 01 f .".II"u,"g AulnOlll.,. ri' C(>/TImO" 1'I,..l)I>(.~" ~umh" J 11111, IIlfl"', "11'"" Numl"f
OTN ABU6I
HD-0000024-94
4 fl~ IltUlllg Alllnnrllyflu I'" wmpl",d hy ""llluul"g Aulh,,"1y . " llTIlnl'.rr-.JI'nm 111"111 lllulng Au,tlOltty
CHARLES A. CLEHENT, JR, I 09 11 101 I
II Nam. and AddfHIII .11 Na"'.' "Ill ' !lal'llJlltnj'fl' 1lI)O:~"'I~I.lIr_'""i.I'..u,ngAulhu'lty
CR-210-94
~ BROlIN, SCOTT HARRISON ll~i,,;rWt;;' R,gnlfil C(IIt'III.,nl (Nlm, ,""1 AII'II."1
240 S. 4TH ST, JErrRI!:Y rRANKS
~ LEHOYHE, PA 17043 LEHOYNE POLICE DEPT
655 MARKET STREET
LEHOYNE. PA 170U
~ 10..\"," 01 Ol"h I" r,..",R..,f' '3 Opt/llot (~'''M Numb./ r;: la 0\1 '10 OCA I' lladg' Nun,b,'/UI'I'ltllllJ
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07 125 I 94 B CUHBERLAND CTY PRISO CARLISLE PA
COPYI CLERK OF COURTS
Certllled this 2 7l II
day 01
,10 94
641al, rlr*lIp,r.llnl
If1Cou"
Iollol UO vv
~!7 94
AOPC 601 A-94
PRINTtDI 7/27/94 11120107
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OTN ABUSE
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HO S, .TH aT,
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-';-~~.a.t....rllli VIOLA'l'1111Ulf ORDER-11'.rA1
--
TYPE OF DISPOSIT ION OTHER INFORMATION
101 GUILTY PLEA I-INAI 31, PRE.SENTENCE INVESTIGATION ..
102 GUILTY PLEA TO A LESSER OFFENSE PLEA A. PRE.SENTENCE.STATE I-
103 NOLO CONTENDERE B PRE.SENTENCE.COUNTY I-
2011 NOllE PROSSEDM'ITHDRAWN C. PSYCHIATRIC EVALUATION I-
202 QUASHEDIDISMISSEDiDEMURRER SUSTAINED lllB o PRE.SENTENCE ANO PSYCHIATRIC -
203 OTHER ISPECIFVt MISSAL E NOT REQUESTED
204 DISMISSAL UNDER PA R CRIM P 1100 32 TRIAL COMMENCED OATE I
3011 JURY 33 NO, TRIAL DAYS I I I
tRIAL
302 COURT 34, DISPOSITION DATE
311 NOT GUILTY V~R, 35, SENTENCE DATE
312 GUILTY DIGT 36 EFFECTIVE DATE OF SENTENCI
313 GUILTY OF A LESSER CHARGE 37, FUGITIVE YES
401 ARD COUNTY NO 38 DEFENSE COUNSEL "
402 ARD STATE prNA\ Tv A PUBLIC DEFENDER I-
403 DISPOSITION IN LIEU OF TRIAL (lISP B PRIVATELY RETAINEO I-
C. COURT APPOINTED I-
501 DIAGNOSTIC CLASSIFICATION CENTER o SELF REPRESENTED
- 502'
REGIONAL CORRECTIONAL FACILITY PRISON 39. DEFENSE COUNSEL NAME 40, 10 NO,
,--- 503 COUNTY JAIL
511 STATE IPBPPIIlEGULAR PROBATION
512 STATE (PBPPI PROBATION WIO VERDICT p,,,, 41 PRESIDING JUDGE ILAST NAME FIRsn
-- __ 1513) _ COUN1Y,IlEGUlAIl PIlOBATION BAllON
514\ COUNTY,PIlORATION WIO VEIlDICT
---
521 flNES,TOTAL AMOUNT ONI Y $ flt'dB 42 COUNTY 3.CODE
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1- 522 COSTS.TOTAL AMOUNT ONLY $ ANIl
___ ___ __ ~3 FINES AND COSTS SIJSPfNDED COSTS
____ __. (531) DEATH PENALTY Mise 44 NAME OF PERSON REPORTING
1---. -- _U'__ _ 532) MENTAL HOSPIT AL
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I,
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--- --.. ,- ---, ,--- .. 1515 MARKET STREET, SUITE 1428
1111 __
-- --- ---- --- -- - - -- -- PtilLAOELPHIA, PENNSYLVAN'A 18'02
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!~ ~I O~n_.._n____.._ __.... _._.. __ ,
USE REVERSE SIDE FOil REMAIlKS
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PRINTED.
112 19
COPY I Cl,ERK OF COURTS
Aope 001 B Y3
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OTN ABUBE
HD-0000024-94
4 fln.lltlulnQ AuthOflty"O be tomplpliPd by 1rI.,luu,"g AuthOllty " !I1.n,lpIrP<.!fun,'ru\I.lluu1ng,4,ulhpllly
CHARLEB A, CLEHENT. JR, 10911T01 I I I
e N.me alld Add~..(I..1 N.~"'TH'U ' Oa'jOl. r,,,i'" 8 Doc"" t!n. oI_lnltl'lluumg AlllhOllty
CR-210-94
I BRONN, BCOTT I!ARRIBON g Alflanl Who 8,~nll'<j Campl,jnllN,m, ,nd Add'"']
240 B. 4TII BT, JEFrRE FRANIlB
LEHOYNE, PA 170U LEHOYNE POLICE DEPT
655 MARKET BTREET
0 LEHOYNE, PA 170U
~ l~..l!-w~!l'rlh II' B~I'J~' 1 J 0".,.101 lin"t' Numbflr I';;" HI unl 1'6 ocA l' o.dgl Numl!tl,f{)IfK;" I [)
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III "Committed nIl. 6i'Codp OJ 1'1.(. 01 ellmmI1m.fl!
07 125 I 94 D CUMBERLAND CTY PRIBO CARLIBLE PA
COPY, TRIAL COURT ADMIN
Cortlfied this
dayo!
My commission expires !lrst Monday 01 January, 1996.
,19_
SEAL
I, tho abovo namod ISSUing Authorltv COlll1y lhalthls Transcrlplls a liuo ond
corrocl Tianscrrpl of lho Dockot.
AOPC 501 A.o4
PRINTED 1 7/27/94 11120107
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, Dockei Humbtt d I. 'lIall..vlng ALlllWIlt)'
01 r;l'''H'H1I1I'I''Il.I>'M~1'1 Numllf'l
lHl.t.klfll1I,II\AI.nnN."'nl..,
OTN ABUSE
HD-00000~4-94
CHARLBS A, CLEMENT, JR.
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BROWN, SCOTT HARRISON
240 S, 4TH ST.
LEMOYNE, PA 17043
, lla'~t"".nr"'f B lll>e:k.,"!!t ul 1l\ll'lll..umg Aulhntlly
I CR-HO-94
U ~"'.I\' ~hO B19nf'l1 (.0"'111.'111 iN1m. and Addl.nl
JEFFREY FRANIlS
LEMOYNE POLICE D!PT
655 MARIlET STREET
LEMOYNE, PA 17043
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071~5 194
B
CUMaERLAND CTY PR180
CARLtBLE
PA
COPYI DISTRICT ATTORNEY
Certifiod Ihis
day of
My commission oxpires first Mondey 01 January, 1000.
,19
------'-~-l
Il.ll.,,. 1'1"" Iljll fl.nt,
1"Cn,,'1
M~ llll '1'/
07 [27 I 94
--.--.-- -..-..,. ----
SEAL
I. 11\0 8hovo Il81llll(1lsslJIng AulllOrrlv C0I11fy that this Tlanscliplls 0 tlUO ond
tDrroclllansLllpt 01 IImllockol
AOPC 601 A,94
PRINTEDI 7/~7/94 111~0101
-
-- -
.J! S SIC A I\NN 1\ I N 111\ ,
P JOInt I f I
IN 1111 COIIIII 01 (OMMON I'IFI\S OF
ClIMBIIII I\NIJ COIINTY, PENNSYLVANIA
V,
SCOTT HARRISON BROWN,
[)ell1lHJanl
NO, lJlj-39/I<J CIVIL TEIlM
PIlOTECTJON FROM ABUSE
AN\l ClISTOIlY
IN RE; __INDIRECT CfUMINALCONTEMPJ
OHDER OF COURT
AND NOW, July I'b, 1994, at 4:15 p.m,. aftl1r hl1aring and
consideratIon of the testImony presented, we do fInd beyond 0
reasonable doubt that lhe defendant did knowingly violate our
Order of July 15, 199/1. WI! do therefore find the defendant to
be In Indirect criminal contempt.
Hoving found him in indirect criminal contempt, we sentence
him to 0 term of Imprisonment in the Cumberland County Prison of
four months, We give 11im credi t for one day previously served
on this sentence. We now place him on parole for the balance of
the unexpired term on the condition that he be and remain on
good behavIor and comply with 011 the conditions of our Order of
July 15, 1994, until any other written resolution is reoched or
until that Order is changed after hearing In court.
By the Court.
~ ~
~ :;ft
"!'f IHf- ~
..().. .,
~ ~,..{'.
.:;. j~Q(;.;r-
Willlllnl (.'''Gbhig, Esqulrl1
Sr, ~sl st(lI~f Distrlcl Attorney
f'J '.' ":
TlmoUlY L. 'C'!J.owges, Esquire
AS51~ont~P~bllc \lelender
lior e r, J.
ProlJlJlion Offl ce
ecl'
'11I1 f
C1l1MINAI U lM1'1 AII~ I
IPOl.lCE I
coMPLAINT NUMIiEIl IVEAR '
CR-0000210-94 ,19~4.
COl1lpiuinl Numhllffi II OlhUl Pmlir.illontB
lVIlE-----llilMIlEIC
CR__l!Q._
,',IIAHI.ES A. CI.EHENT .Ill,
U'511l1CT JUSTICE
M^OI51EIlI^1. UI511llCT NO, UIJ-I-OI
1106 ClIr 11 III " Illllld
Cmllp 11111. I'll, 17011
, 111l fill.
'NCIDEHT HuMbER IUCRNO,~
"""10TH" .",.n....._.. _'n_
E 566333-5
---_. .-. "--' -._-----
COMMONWEALTH OF PENNSYLVANIA
VS.
1.1'tlw. JdLJ:uy R...t'IllUks,.. _...._._'_.__nn..'_.
f\.IIIII'"fllfl,llllJ
NAMI
AND
Dill NilAN I
,-
Scott llarrison Brown
240 s. 4th Strest
AIlIlIH ~;~; Lemoyns. Ps. 17043
Ill' LcmUYllc, lloJ:uugi!l'ul1clllllluartmllut,.._ .,-"
f 1./(1/1111 III f'l/IIHlI'III m,ll..'nUI np'l'\t"lIII'l/lilllll~jMII.j' \"hdll/llrUlI
IlBA
AKA
DODI
SSNI
12-04-72
200-52-9678
W/M/21 yrs,
dll hcrch) 'lillC:
(I W I i1,'rll'C Ihc ahlllc lIal1lcd dclclldulIl, IIhll hlc. III thc addrcs. 'CI rlllih alhllC Ill,
_ -'0 I i1n:II'C all illdilldllal Ilhmc III1I1lC I, IIl1kllll\\lI I" mc hili Ilh" "dc,cllhcd a' _____
-
~
~ 0 hi, IIldllilmc or pllplllilr dc,lpllilll"lI " IIl1klh,"1I III mc II lid. Ihcrclillc. I hillC dC\lpllillcd him hcrcllI '" Jllhll
f 1l11C: 1IIIh ,Inlilllllp Ihc pCllillliI\\' "I' Ihc ('"ml1l"lIIlclIllh "I' I'CIIII,)\lillllilat ,121"South.:rh~rd...,':lt.
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f; .1cmoYUILJlllJ:llUgh'n~nna.'.._.....,_,___...__'__n_. . ------ .,-.-.-.,
'" _,__.____,_..___,....__' III ..I:unblldiUUL ,.. ('lllllll)' "II or ahlllll ,Julym25._1.a94~__-3~U_l'bl_
~ Parlil'illilnl!r'l \\ell' (I/fht'h'hOi"'j/1tI.I(I,iII/I/'/"" t!W/llIiIllW,/Il'Ii' 'lllllllllll!!lIl'II,IIIIl""',,hlll.-dd,'IIII,"lfl SCOTT HARRISON BROWN
Thc .IL'I' rlllllllllllcd hI Ihc nrrll,cd Ilcrc, 0
(2)
lNOIRECT ClllMINAL CONl'I\HI'T
In that the nbove named defendant, Scntt lIarrtaon 1Irown. dId intentionally and/or
knowingly violate an order of court. (CIVIL HilI-! NO, 3949 , 1994, ISSUEll UNllEll
TilE 1'1l0TECTlON Fllml AIIUSE ACT I1Y TilE 1I0NOI\AIIU: .IUllGE GEOllGE 1', 1101' FE 11 , on the above
date and time, The defendant did violate the snid order in that he did grab the
plnintiff, .Iessicn Ann llinier, nround the thront. shoved her about the face,
pUBhed her to the floor causing redlless and hruising to the face nnd throat arees
tll1lt thIs officer personally observed at the scene, nnd the defendant violated the
order in that he was physically in the resIdence. uninvited by the plaintiff and did
proceed with the cOllrse of action that was In vlolntlon of this order,
nil or Ilhlch Ill'''' apaiml Ill' pcacc allll dlplIll)' 111' Ihc ('I1IllIllI1I1\\Callh "I' I'CI1I1') 110111101 alld ,'''l1tmr)' 111 Ihe Act nf A"Clllhl)',
or 111 l'il1lalllll1 of al1d of Ihc Arl "I' -2.J Pa.n.R.A.
(. '.'firm} ,'"h. 11"./11111 J
or thc Ordll1allcC 111'
f H,lIllj"/.\lth dO/I/IlII!
(.1) I n,k lhill a lIalTal11 "I alTc,t 111' a '"1111111111' hI' ls.llcll alld lhal lhc a!'rll'cll he Icqllilcd to all\\ler Ihc char~c'
I halc Illade,
(4) I leril)' 111iI1 Ihc farl' 'CI linlh III thl, rlllllplall1l IIIC Hill' III1lI c"l'Icrl 111 Ihc h",1 or 111) kllll\\lcdgc 111' il1fl1l'11111111111
0111I1 hell'" Thl' Icrll'iralioll I, mndc ,"hjcrl III Ihc pCllllllic' 111' Serllllll 41!114 111' thc ('rlmc, ('odc IIH POI. l'. S
! 41)04) ,,'Iallllp 10 1111\\11111I fnl\lliclllillll 111 IIl1lhllrillc,
_J!llY ;15. 1994
__. ...",." I'12L
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;~III''''(I'lIIfI'IIH'lll/''
ANIl NOW. 1111 1111\ dal,' .July 25
vcrllicd, '1I1111hal Ihcll' " I',ohahl,' rallIL' 1'111
, 1'1 1)4 . I \'\'11111
1\I,Ualll'l' III pl'lIl'~'"
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AIII'!..I" tit
.ARIU:ST WARRANT AFFmA"1T
CIIAIII.EB A, CI.EHENT, .J II,
IJISTllICI HIS lilT
M"~"ll'III1IIJ"IIIl'1 ~tl. 09-1-01
"lIl1lrlallll ~ll
"UI
Ilrr
CIl
Numllfl
CIl-0000210-94
1994
210
'.llll1rllllll Nil' III Hlhe'1 1'1I111\11IMI'
I.lQ6CAl~I,.I~J.I;Rll'd,!;fIt'W,lJnl'.1 l'A.HlIl.
COMMONWI:ALTlI 01' PENNSYLVANIA
CUMDEIlLAND
! BS
".."..,.......,,, ....................,...........,...........
"' N E 566333-5
COMMllNWI'AI,lIl11F I'ENNSYLVANIA
\,&,
COUNT\' OF
I)(,HNIJANT: (NBme Rnd Bddrm)
r SC01'! IIAIlIHSON 1l1l0WN .,
240 S. 4th Street
J.omoyne I I'a. 17043
L
.. ..r.~.~f!l..J.'!JJ.I:".'!y...f.r.!\n ~~.I.. .~~!1)!!y'!!!!.. .~!!IC?~.~.I.I. ..!~C? ~.I.~.~ I.., ~~ 5... H.'! .r~~,t" ,S,t.:,. .I.,~.IIl"Jlle., ,I'!!~. ,. ,1.7~~.3"... ...... ..... ...
tNlmr of Affilnll lI'lIhn ()t(llrlUltnIIH Adttle'u nlPlI\llt Alllanll lltltllhnnt Number)
being duly sWllrn (or affirmed) bcfore me, according 10 law, dcplllcs and sa)" IhBllhm is probable callie 10 believe Iha':
PROIIAIlI.E CAUSE IIELIEI' IS JlASEIl ON 1I1E FOLLOWINO FACTS ANIl CIRCUMSTANCES: (see Inslrue,
below)
On Monday. July 25. 1994. at 3130 I'M, myself and Officer lIart of Lemoyne Police
Department responded to a 911 call of a Domestic Violence/Protection from Abuae Violation
at 121 S. 4th Street. Lemoyne Dorough. The Complaintant, Jessica Ann Rlnier advised
that Scott II, Drown was In her apartment attempting to take her 17 Month baby child away
from her and that he was also abusing her,
Officer lIart and myself arrived shortly thereafter and did find a Scott lIarrlson
Drown In Rlnler's apartment with/holding a child, I did speak with the complaintant/
plaintiff at the scene and she did advise me that the defendant was in violation of
a Protection From Abuse Order Issued from the Court of Common Pleas of Cumberland County,
Pennsylvania. signed by the lIonorable Judge George E. Hoffer. in which the Lemoyne Police
Department was already in reclept of both the original order dated July 15, 1994 and
the CONTINUANCE ORDER dated July 21, 1994, The plaintiff did tell me that the defendant
did grab her around the throat and did shove her about her face and puseded her to the
floor to grab the child from her. This officer did obaerve redness and bruising to her
face. throat, neck and frontal forearm areas.
I'LEASE IH~AD AND HHJ.OW THESE INSTRUCTIONS CAREI;UI.I,y
I. If inforl11l1tion WIIS ohtllincd Irnmllnolher person. e,~. 1111 inlorl11alll. a pri\'a'c dlilen, or a lellow law offieer. 'laic
specificRlly whlll illlorl11Rlilln was recei\'c~, an~ how 1111I1 when ,uch illlonualion wa, ohtllinc~. Slale a',olhe IBclUal hasis for
helie\'ing ,uch Illher person 10 he reliahle,
2, If sur\'eillance was l11a~c. 'Iale whal illformalion wa, ohtllillc~ hI' ,uch ,ur\'cillallcc, hI' whoRl II wQS ohlaincd, and stale
dRIC, lime UII~ plucc III ,uch ,ur\'eillance,
.1, Slale Ilther pertinenl laCIs within persllnul kllllwledge of IIffillnl.
4, Slale uny udditilll inlnrl11alion w",i~cred pertineu' III JU'lily Ihis uppliculilln,
.(:4lm,. 1\... ':1., .. Td, ,..J,~tIIl1yn~..1)11U~!I .U~7.........7.17..,.7.61.,.,a7,JL,...
!'l1(j~^Il.tu OtffI~li .\Illl~l" III 1'~I\""III1/I" IIAlHil ~C1 IJISlllln"'NII
, 19 94
(SEAL)
01\11<111.11 "III COIIlI ~tl
09-1-111
1>i1ll' ('011111\1'1'1011 r\plll'\
1-1-96
Iii III1 ""/111'"
1106 CarllHle Hd., CIIII\I' lilli, I'A 11011
1'110"
(717) 761-49/,0
. '
<< '
" , I ' "- ~ ~ ..' ~ .'
JESSICA ANN RINIER,
Plaintiff
IN THE COURT OF COHHON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 - .1 (; '/ q CIVIL TERM
vs,
PROTECTION FROM ABUSE
AND CUSTODY
SCOTT HARRISON BROWN,
Defendant
TEMPORARY PROTECTIVE ORDER
, IV
AND NOW, this I':> day of July, 1994, upon presentation and
consideration of the within Petition, and upon finding thnt the
plaintiff, JESSICA ANN RINIER, now residing at 121 Third street,
Apt. 2L, Lemoyne, cumberland county, Pennsylvania, is in
leased solely by the plaintiff and to which the plaintiff moved
to avoid abuse, or any other residence the plaintiff may
establish for herself, 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 0
fine not to exceed $1,000.00 and/or by a sentence of up to six
months in jail Ilnd any other appropriate punishment. Resumption
immediate and present danger of abuse from the defendant, SCOTT
HARRISON BROWN, the following Temporary Order is entered.
The defendant, SCOTT HARRISON BROWN, now residing at 240
South 4th Street, Lemoyne, Cumberland county, Pennsylvania, is
hereby enjoined from physically abusing the plaintiff, JESSICA
ANN RINIER, or placing her in fear of abuse and is ordered t:o
stay away from the residence located at 121 Third street, 2L,
Lemoyne, Cumberland county, Pennsylvania, a residence which is
.
'" '
.i" i..
Ii,! ;,1 ~H '911
, ,
~/ t
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ii'f
.'
of co-residence on the part of the plaintiff and defendont shall
not nullify the provisions of the Court Order directing the
defendant to refrain from abusing the plaintiff.
Temporary custody of VINCENT BROWN is hereby awarded to the
plointiff, JESSICA ANN RINIER, and the Cumberland county
Sheriff's Department will help facilitate the transfer of
custody.
The defendant is ordered to refrain from having any contact
with the plaintiff inClUding, but not limited to, entering the
plaintiff'S place of employment, harassing or stalking the
plaintiff, and harassing the plaintiff'S relatives.
This Order shall remain in effect until a final order is
entered in this case. A hearing
the ,..1/~r day of JUly, 1994, at
shall be held
(. fl) /I".m.
on this matter on
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 Lemoyne 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.
VB.
I IN THE COURT OF COHMON PLEAS OF
I
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I NO. 94 - 11'1'1 CIVIL TERM
I
I PROTECTION FROM ABUSE
AND CUSTODY
JESSICA ANN RINIER,
plaintiff
SCOTT HARRISON BROWN,
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 NUHBERI (717) 240-6200
vs.
I IN THE COURT OF COMMON PLEAS OF
I
I CUHBERLAND COUNTY, PENNSYLVANIA
I
I NO. 94 - lfY7 CIVIL TERM
I
I PROTECTION FROM ABUSE
I AND CUSTODY
I
I
JESSICA ANN RINIER,
Plaint:iff
SCOTT HARRISON BROWN,
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 121 Third street, Lemoyne, Cumberland county,
Pennsylvania, 17043,
2. The defendant is an adult individual residing at 240
South 4th street, Lemoyne, cumberland county, Pennsylvonia,
17043.
3. The defendant is the father of the plaintiff'S child.
4. since approximately September 1993, 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 abusel
a. On or about July 1, 1994, while the plaintiff was
holding her 17-manth-old baby, the defendant slapped t:he
plaintiff across the face, causing the plaintiff to fear for her
safety due to past physical assaults by the defsndant. The
plaintiff was forced to leave the residence without her baby.
The defendant: threatened that if she took the baby out of the
house, the defendant would come after her and kill her.
b. On or about June 18, 1994, while the plaintiff and
defendant were arguing, the defendant slapped the plaintiff in
the face approximately seven times. After the defendont spit in
the plaintiff'S face four times, he grabbed the plaintiff by the
ankles and pulled her off of the couch. The defendant kicked the
plaintiff approximately three times in the side and hip. The
defendant again grabbed the plaintiff by the ankles and dragged
her across the floor. He then grabbed her by the hair and banged
the back of her head on the floor approximately three times. The
defendant then grabbed the plaintiff'S shorts and underwear,
forcefully removed them, and forced the plaintiff to have sex.
Afterward the defendant ejaculated in the plaintiff'S face and
hair. While the plaintiff was in the bathroom, the defendant
told the plaintiff she had better leave because he had just
thought of a new way of killing her. The plaintiff was forced to
leave without her child. The plaintiff suffered bruising to her
shoulder, a bloody nose, sorness to the back of her head, and red
blotches under her eye.
c. In or around April 1994, the defendant grabbed the
plaintiff by the jaw and neck, and banged her head against the
wall approximatelY three times. The defendant then threw a can
full of soda at the plaintiff, just missing her head.
d. In or around February 1994, the defendant grabbed the
plaintiff by the throat, forced her up against a wall, and choked
her.
e. During the plaintiff's pregnancy, the dsfendant slapped
the plaintiff in the face, and pushed her on sevsral occassions
with enough force to cause her to fall down.
5. On July 2, 1994, the plaintiff left her residence at 240
South 4th street, Lemoyne, cumberland county, Pennsylvania in
order to avoid further abuse.
6. 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.
7. The plaintiff desires that the defendant be restrained
from entering her place of employment, having any contact with
her, harassing or stalking the plaintiff, and from harassing the
plaintiff'S relatives.
B, TE1IPORARY CUSTODY
o. The plaintiff seeks temporary custody of t:he following
child:
~
VINCENT M. BROWN
Present Residence
~
240 s, 4th Street
Lemoyne, PA
The child was born out of wedlock.
17 mos.
The child is presently in the custody of SCOTT HARRISON
BROWN who resides at 240 S, 4th street, Lemoyne, Pennsylvonia.
During the child's lifetime, the child has resided with the
following persons and at t:he following addresses I
I:iAIMl
Addreeses
D.W
plaintiff,
defendant ,
defendant's family
45 Creekside Dr.
Enola, PA
2/23/93 - 3/93
plaintiff ,
defendant
312 S. Front st.
Wormleysburg, PA
shelter
3/93 - 2/94
plaintiff
plaintiff,
defendant ,
defendant's family
plaintiff ,
defendant
45 Creekside Dr.
Enola, PA
2/94 - 3/94
3/94 - 3/94
240 S. 4th st.
Lemoyne, PA
3/94 - 7/2/94
The mother of the child is JESSICA ANN RINIER, currently
residing at 121 Third Street, Lemoyne, Pennsylvania.
She is single.
The father of the child is SCOTT HARRISON BROWN, current:ly
residing at 240 S. 4th Street, Lemoyne, Pennsylvanio.
The plaintiff currently resides by herself.
9. The plaintiff has not previouslY participated in any
litigation concerning custody of the above-mentioned child in
this or any other Court.
10. The plaintiff has no knowledge of any custody
proceedings concerning this child pending before a court in this
or any other jurisdiction.
11. The plaintiff does not know of any person not a part:y
to this action who has physical custody of the child or claims to
have custody or visitation rights with respect to the child.
12. The best interests and permanent welfare of t:he child
will be met if custody is temporarily granted to the plaintiff
pending a hearing in this matter for the following reasons:
a. The plaintiff is a fit parent who can best take
care of her child.
b. The defendant has shown by his abuse of the
petitioner that he is not an appropriate role model for the
child.
C. EXCLUSIVE POSSESSION
13. The home from which the plaintiff is asking the Court
to exclude the defendant is rented in the name of JESSICA ANN
RINIER, and the defendant has never resided there.
D. SUPPORT. SECTION
14. The defendant has a duty to support their minor child.
15. The defendant is employed at Hayflower Hoving Company
and the plaintiff is unaware of his salary.
16. The plaintiff is employed at Glen Hiller's Warehouse
and currently receives approximately $5.00 per hour.
17. The plaintiff'S income is insufficient to provide for
the needs of her child until such time as a support order can be
obtained by filing at the Domestic Relations Office.
10. The plaintiff intends to petition for support within
two weeks of the issuance of a protective order.
E. ATTORNEY FEES
19. The plaintiff asks for attorney fees to be poid to
Legal Services, Inc, pursuant to the Protection from Abuse Act.
F. STATUS TO PROCEED IN FORMA PAUPERIS
20. The plaintiff does not have funds ovailable to pay t:he
fees for filing and service.
WHEREFORE, pursuant to the provisions of the "Protection
from Abuse Act" of October 7, 1976, 23 P.S. Section 6101 gt li\m.,
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,
entering the plaintiff's place of employment, harassing or
stalking the plaintiff, and 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 121 Third street, Lemoyne, which the
parties have never shared.
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 "proteotion from Abuse Aot," and, after suoh hearing, enter
an order to be in effect for a period of ono yearl
I. 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
contaot with the plaintiff, including, but not limited to,
entering the plaintiff'S place of employment, harassing ~r
stalking the plaintiff, and harassing the plaintiff'S
relatives.
3. ordering the defendant to stay away from the
residence located at 121 Third street, Lemoyne, which the
parties have never shared.
4. ordering the defendant to stay away from any
residence the plaintiff may in the future establish for
herself .
5. Granting support to the plaintiff in the amount: of
$30.00 per week payable by mail.
6. Ordering the defendant to pay attorney fees to
Legal services, Inc., pursuant to the Protection From Abuse
Order.
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 Lemoyne Police Department as the Police Department wit:h
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
21. The allegations of Count I above are incorporat:ed
herein as if fully set forth.
22. The best interests and permanent welfare of the child
will be served by confirming custody in the plaintiff as set:
forth in Paragraph 12 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,
rt
oan Carey
At:torney for aint:iff
LEGAL SERVICES, INC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
The above-named plaintiff, Jessica Rinier, verifies t:hat the
statements made in the above Petition are true and correct. The
plaintiff understands that false statements herein are made
subject to t:he penalties of 18 Pa. C.S. section 4904, relating t:o
unsworn falsification to authorit:ies.
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ANN RINIER,
Plaintiff
CUHBERLAND COUNTY, PENNSYLVANIA
V.
NO. 94-3949 CIVIL TERM
SCOTT HARDING BROWN,
Defendant
PROTECTION FROH ABUSE AND CUSTODY
AND NOW,
~ FOR CONTINUANCE
this ~ day of July, 1994, upon consideration of
the attached Hotion for continuance, the hearing scheduled for July
21, 1994 in Courtroom No. 3 of the Cumberland County Courthouse,
Carlisle, Pennsylvania is generally continued.
The Temporary Protective Order of July 15, 1994, remains in
effect pending further order of Court.
This order is entered without prejudice to either part:y to
request a hearing if the agreement cannot be finalized.
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JESSICA ANN RINIER,
Plaintiff
I IN THE COURT OF COMMON PLEAS OF
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I CUMBERLAND COUNTY, PENNSYINANIA
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I NO. 94-3949 CIVIL TERM
I
I PROTECTION FROM ABUSE AND CUSTODY
V.
SCOTT HARDING BROWN,
Defendant
HOTION FOR CONTINUANCE
The plaintiff, by and through her attorney, Joan Carey of
Legal Services, Inc. states the following I
1. On the 15th day of July, 1994, the plaintiff filed a
Protection From Abuse action and the court entered a Temporary
Protective Order and scheduled a hearing for the 21st day of JUly,
1994.
2. Legal Services has been in contact with the defendant who
agrees that the hearing be generally continued to afford the
parties time to execute a Consent Agreement.
3. The plaintiff agrees to a continuance of the hearing, and
requests that the Temporary Protective Order remain in effect
pending further Order of Court.
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.
Respectfully SUbmitted,
(',::)
, \J'.AL;(,'"
oan Carey
Attorney for ,
LEGAL SERVICES, INC.
a Irvino Row
Carlisle PA 17013
(717) 243-9400
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COOl'11'Y 01' CLM1JEIUJ\ND
In '1'ho Court Of Common Pleas of
Cumberland County, Pennsylvania
No. 94-3949 Civil Term
l'rotection From Abuse and Custody
potition for Protective Order &
custody
Jessica Ann Rinier
VB
Scott lIarrison Ilrown
~'i mothy Reitz
. lWWl1f)IlllC Deputy Sheriff of
CUnberland County, Pennsylvania, who being duly sworn ac=rdint~J.o ~~\hfPd'R' for
Protection From Abuse and Cus y
that he served the within protective Order and Custody .
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upon Hcott lIarrison Ilrown
P.M. >IM*,. EDST, on the 15th
, the defendant, at
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, 1994 at
day of
4~ ~reekview Drive, Enola
Pennsylvania, by handing to Scott II. Ilrown
, CUnberland County,
a true and attested copy of the ffi8ayci' i on From Abuse and custody Peti tiop
for Protective Order and C .
and at the 511I1'13 time directing his attention to the contents thereof and
the "Notice to Plead" endorsed thereon.
Sheriff '6 Cos ts I
Docketing
Service
Affidavit
Surcharge
So answers I
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61\'0111 and subscribed to before me
this --1.L~__ day of
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SCOTT BROWN,
Plaintiff
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
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CIVIL ACTION - LAW
IN CUSTODY
JESSICA ANN RINIER,
Defendant
ORDER
AND NOW,
this
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1995,
the
parties having agreed to the entry of an Order of custody,
as provided in the attached custody Agreement, it is hereby
ORDERED and DECREED that custody of the minor child, vincent
Marcolin Brown, shall be as folloWSI
1. CUSTODY OF MINOR CHILD: FATHER and MOTHER agree
that they shall have shared legal custody of the parties'
minor child, Vincent Marcolin Brown, in terms of decision
making powers regarding the health, education and welfare of
the child. FATHER and MOTHER agree that FATHER shall have
primary physical custody of the parties' minor child,
Vincent Marcolin Brown, while MOTHER shall have partial
physical custody of vincent Marcolin Brown.
E. MOTHER shall have custody on Thanksgiving
Day from 5100 p.m. through 8100 a.m. the next day,
F. Mother's Day with MOTHER'
G. Father's Day with FATHER'
H. MOTHER shall have custody on vincent
Marcolin Brown's birthday, February 23, from 5100
p.m. on February 23 until 8:00 a.m. on February
24,
I. The term "holiday" means the day itself
and overrides any scheduled weekend visitations
for the day on which the holiday is celebrated,
and
J. Such other times as the parties may
hereinafter agree.
3 . HARASSMENT OR INTERFERENCE: The parties further
agree that they will not utilize their respective rights of
custody in order to harass or interfere with the other's
right to live and remain separate and apart from each other.
In the event that either party utilizes custody rights to
harass or interfere as hereinabove desoribed, the parties
expressly agree that, in addition to all other legal and
equitable remedies available to them, they may make
3
immediate application with the court of appropriate
jurisdiction to pursue appropriate jUdicial remedies for
said harassment or interference.
4. ENTRY OF COURT ORDER; MOTHER and FATHER agree
that this Agreement shall be formalized by the entry of a
Court Order of custody in accordance with the terms and
provisions of this Agreement by a Court of competent
jurisdiction, and that this Court Order shall supersede the
previous custody Order entered at Docket No. 94-3949 in the
Court of Common Pleas of Cumberland county.
5. OTHER CUSTODY RIGIITSI In addition to any
provisions which may be contained herein regarding custody
rights set forth hereinabove, each party shall have the
following rights with respect to the minor childl
A. Reasonable telephone calling privileges
to 8:30 p.m.
B. Access to report cards and other relevant
information concerning the progress of the minor
child in school,
C. Approval of extraordinary medical and/or
dental treatment, except, in the case of an
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6. ILLNESS OF THE MINOR CHILDl In the event of any
serious illness of the minor child at any time, the party
then having physical custody of said minor child shall
immediately communicate with the other party by telephone or
any other means, informing the other party of the nature of
the illness. During such illness, each party shall have the
right to visit the child as often as he or she desires,
consistent with the proper medical care of the child.
7.
DOCUMENTS:
Each party shall, at the request of
the other, execute, acknowledge and deliver to the other
party any documents which may be reasonably necessary to
give full force and effect to this custody Agreement.
8. VOLUNTARY EXECUTION AND FAIRNESS OF THE AGREEMENT:
Each party acknowledges that this custody Agreement has been
entered into by his and her own volition, and with the
advice of. separate, independent counsel, with full knowledge
of the facts and full information as to their legal rights
and that each believes the custody Agreement to be
reasonable and in the best interest of the minor child
under the circumstances and not the result of any duress or
undue influence.
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9. BITUBl Thh custody A\I....m.nt shall be construed
and governed in accordance with the laWI of the commonwealth
of Pennsylvania.
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DESCRIPTIVe IIEAIlINQI.II
'l'ho desoriptive headings
used herein are for conveni ence onl y. 'l'hey shall have no
effect whatsoever in dotermining the rights and obliqations
of the parties.
11. BINDING EFFECtl
Each of the parties hereto
intends to be legally bound. In the event that either party
breaches any provision of this Agroement, and the other
party retains counsel to 8Bsist in enforcing the terms
thereof, the parties hereby agree that the breaohing party,
if found In oontompt and ordered by the court, will pay all
attorneys fees, court costs and expenses incurred by the
other party in enforcing that atipulation.
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CUSTODY AGREEMENT
THIS AGREEMENT, made this ) ) ,- , .J day of February,
1996, by and between SCOTT BROWN, hereinafter referred to as
"FATHER" ,
-AND-
JESSICA ANN RINIER, hereinafter referred to as
"MOTHER".
WITNESSETHl
WHEREAS, the parties are the parents of one (1) child,
Vincent Marcolin Brown, born February 23, 19931 and
WHEREAS, diverse and unhappy differences and disputes
have arisen between the parties and it is the intention of
MOTHER and FATHER to live separate and apart, and the
parties hereto being desirous of settling their respective
rights of custody I
NOW, THEREFORE, the MOTHER and FATHER, each intending
to be legally bound hereby agree as followSl
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1. CUSTODY OF MINOR CHILDI FATHER and MOTHER agree
that they shall have shared legal custody of the parties'
minor child, Vincent Marcolin Drown, in terms of decision
making powers regarding the health, education and welfare of
the child. FATHER and MOTIIEIl agree that FATHER shall have
primary physical custody of the parties' minor child,
Vincent Marcolin Drown, while MOTHER shall have partial
physical custody of Vincent Marcolin Brown.
2. MOTHER' B IUGHTB ot' PARTIAL CUSTODY I MOTHER shall
be entitled to reasonable rights of custody of vincent
Marcol in Brown nt lIuch timell as are reasonable and
convenient to the parties.
I f the parties ars unable to
agree, MOTH Ell shall have the following rights of partial
custody I
A. Alternating weekends from 6100 p.m.
Friday until 6100 p.m. Sunday.
n. Every Wednesday evening from 4100 p.m.
through 7100 p.m.
C. Alternating holidays, consisting of New
Year's Day, Easter, Memorial Day, Indepsndence
2
Day, and Labor Day, from 5100 p.m. of the prior
day until 8100 p.m. of the holidaYI
D. Christmas shall be divided into two (2)
periods of custody to be alternated. The first
suoh period shall be from 12: 00 p.m. on Deoember
24 through 12100 p.m. Deoember 25. The second
such period shall be from 12100 p.m. on Deoember
25 through 12:00 p.m. on December 26 with MOTHER
having the first such period in 19951
E. MOTHER shall have custody on
Thanksgiving Day from 5:00 p.m. through 8100 a.m.
the next daYI
F. Mother's Day with MOTHER 1
G. Father's Day with FATHER 1
H. MOTHER shall have custody on vincent
Maroolin Brown's birthday, February 23, from 5100
p.m. on February 23 until 8100 a.m. on February
241
I. The term "holiday" means the day itself
and overrides any scheduled weekend visitations
for the day on which the holiday is celebrated 1
and
J. suoh other times as the parties may
hereinafter agree.
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3. HARASSMENT OR INTERFERENCE I The parties further
agree that they will not utilize their respective rights of
oustody in order to harass or interfere with the other's
right to live and remain s~parate and apart from each other.
In the event that either party utilizee custody rights to
harass or interfere as hereinabove described, the parties
expressly agree that, in addition to all other legal and
equitable remedies available to them, they may make
immediate application with the Court of appropriate
jurisdiction to pursue appropriate jUdicial remedies for
said harassment or interference.
4.
ENTRY OF COURT ORDERl
MOTHER and FATHER agree
that this Agreement shall be formalized by the entry of a
Court Order of custody in accordance with the terms and
provisions of this Agreement by a Court of competent
jurisdiction, and further agree that this Agreement and
subsequent entry of Order shall supersede the Order for
custody entered at Docket No. 94-3949 in the Court of Common
Pleas for Cumberland county.
5.
OTHER CUSTODY RIGHTS I
In addition to any
provisions which may be contained herein regardinq oustody
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rights set forth hereinabove, eaoh puty shall have the
following rights with respeot to the minor ohildl
A. Reasonable telephone oalling privileges
to 8130 p.m.
B. Access to report cards and other relevant
information concerning the progress of the minor
child in schoo11
C. Approval of extraordinary medical and/or
dental treatment, except, in the case of an
emergency and provided that such approval shall
not be unreasonably withheld1 and
D. The right to participate in making major
deoisions affecting the best interest of the minor
ohild, including major medical, religious, and
educational decisions1 educational decisions shall
be defined as those decisions directly related to
or affecting the academic performance of the minor
child in the classroom.
Each of the parties
agrees to provide the other with his/her address
and telephone numbers, and to advise each other of
any change thereof within ten (10) days. Each of
the parties also agrees that in the event he/she
intends to permanently relooate from the
5
B. VOLUNTARY EXECUTION AND FAIRNESS OF THE AGREEMENT I
Each party acknowledges that this custody Agreement has been
entered into by his and her own volition, and with the
advice of separate, independent counsel, with full knowledge
of the facts and full information as to their legal rights
and that each believes the custody Agreement to be
reasonable and in the best interest of the minor child under
the oircumstances and not the result of any duress or undue
influence.
9. SITUS I This Custody Agreement shall be construed
and governed in accordance with the laws of the commonwealth
of Pennsylvania.
10. DESCRIPTIVE HEADINGS: The descriptive headings
used herein are for convenience only. They shall have no
effect whatsoever in determining the rights and obligations
of the parties.
11. BINDING EFFECTl Each of the parties hereto
intends to be legally bound hereby. In the event that
either party breaches any provision of this Agreement, and
the other party retains counsel to assist in enforcing the
7
terms thereof, the parties hereby agree that the breaching
party, if found in contempt and ordered by the court, will
pay all attorneys fees, court costs and expenses incurred by
the other party in enforoing that stipulation.
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IN WITNESS WHEREOF, the parties heroto have set their
hands and seals the day and year first above written.
WITNESS I
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AI. q.!AA,:1-v{
. SCOTT BROWN
:'"'j ~LhJ
fl. .g~~[JA ~~/i~~i~~ U
B
COMMONWEALTH OF PENNSYLVANIA I
I SSI
COUNTY OF DAUPHIN I
On this, the ,~J,~ day of February, 1995, before me, a
Notary Public, personally appeared Scott Brown, known to me
(or satisfactorily proven) to be the person whose name is
subscribed to the within instrument and acknowledged that
he executed the same for the purposes therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and notarial
seal.
~ .
VV)~vJ.p 1 y~
NOTARY PUBLIC
Notarial 5aal
Michele B. Millar Notary Public
Middletown Bora, Dauphin County
Mv Commlulon E.plrea JulV 6, 1998
, Peml)+r.ril AssociaIlOn 01 NWltIIlS
9
COMMONWEALTH OF PENNSYLVANIA I
I SSI
COUNTY OF CUMBERLAND I
f f~
On this, the .~( day of February, 1995, before me, a
Notary Public, personally appeared Jessica Ann Rinier,
known to me (or satisfactorily proven) to be the person
whose name is subscribed to the within instrument and
acknowledged that she executed the same for the purposes
therein contained.
IN WITNESS WHEREOF, I hereunto set my hand and notarial
seal.
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NOTARY PU, C
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NOIAR/AI. SIAl. !
IWlO/ F. BYEIIS, N01ARY ,",Ipi" 'e I
DOIIO Of CARUSl.E. CUMBDU.AHO ell! ';1/ I
'IY ro'llI'I(lj'ON mlRCs MAANl" rprr!
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I'ATRICK F.I.AU.:R, JR.
Atlorne)' 01 I.ow
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JBSSICA ANN RINIER!
PIa ntiff
VB.
SCOT'l' BRONN
Defendant
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IN TUB COURT OP COMMON PLBAS OP
CUMBBRLAND COUNTY, PBNNSYLVANIA
No. 1994-3949
CIVIL ACTION - AT LAW
CUSTODY
AMERICANS WITH DISABILITIBS ACT OP 1990
The Court of Common Pleas of Cumberland County is required by
law to comply with the Americans with Disabilities Act of 1990.
For information about accessible facilities and reasonable
accommodations availabls to disabled individuals having business
before the court, please contact our office. All arrangements must
be made at least 72 hours prior to any hearing or business before
the court. You must attend the scheduled conference or hearing.
SCOTT BROWN,
Defendant
I IN TUB COURT OF COMMON PLBAS
I CUMBERLAND COUNTY, PBNNSYLVANIA
I
I No. 1994-3949
I
I CIVIL ACTION - AT LAW
I IN CUSTODY
JESSICA ANN RINIER!
Pla1ntiff
VS.
PETITION FOR MODIFICATION OF A PARTIAL
CUSTODY OR VISITATION onDBB
The Petitioner, Jessica Ann Rinier, through her attorneys, The
Law Of fices of Patrick F. Lauer, Jr., files this Petition for
Modification of a Custody Partial Custody or Visitation Order
against the Respondent, and in support thereof, avers the
following I
1. The petition of Jessica Ann Rinier, Mother, respectfully
represents that on March 9, 1995, an Order of Court was entered in
regard to Vinoent Marcolin Brown, the parties' minor ohild, for
shared legal oustody, with primary physical custody being with the
Father, and partial physical custody with the Mother, a true and
correct oopy of whioh is attached. See Exhibit "A".
2. This Order should be modified because I
a. Primary physical cUlltody of the minor child has been
with Mother, at her home, since August 29, 1999,
b. The minor ohild is ourrently in school at the
Mothsr's location, and
c, Mother's school district requires confirmation of
formal physical custody for registration I and
d. The current custodial arrangement should be
memorialized by stipulation or court order in the
interest of predictability, stability and the
child's well being.
WBBRBPORB, Petitioner requeets that the Court modify the
existing Order for Partial Custody because it will be in the best
interest of the child.
Datal
A ').) bO
Matthew J.
HOB Marke
Camp Hill,
10' 46430
shelman, Esquire
street, Aztec Building
ennsylvania 17011-4706
Tel. (717) 763-1BOO
JBSSICA ANN RINIBR1
Pla nUff
& IN TBB COURT OF COMMON PLBAS OF
& CUMBERLAND COUNTY, PENNSYLVANIA
&
I No. 1994-3949
&
& CIVIL ACTION - AT LAW
& IN CUSTODY
VB.
SCOTT BROWN,
Defendant
VERIFICATION
I, JeBsica Ann Rinier, state that I am the Plaintiff in the
above-captioned case and that the facts set forth in the above
Petition for Modification of Custody Order are true and correct to
the best of my knowledge, information, and bslief. I realize that
false statements herein are subject to the penalties for unsworn
falsification to authorities under 18 Pa. C.B. S 4940.
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Je s ca Ann -Rinier .
Datel~CtJ
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EXHIBIT A
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SCOTT BROWN,
Plaintitt
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
NO. /qr,(!. .'3999
CIVIL ACTION - LAW
IN CUSTODY
v.
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I
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JESSICA ANN RINIER,
Detendant
11
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,
,
ORDER
AND NOW,
this
9.iJ.,
'n1a. ...c./....
day ot Febt'llary ,
1995, the
parties having agreed to the entry of an Order of Custody,
as provided in the attached Custody Agreement, it is hereby
ORDERED and DECREED that custody of the minor child, Vincent
Marcolin Brown, shall be as followSl
,
i
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I
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1. CUSTODY OF MINOR CHILDl FATHER and MOTHER agree
that they shall have shared legal custody of the parties'
minor child, Vincent Marcolin Brown, in terms of decision
making powers regarding the health, education and welfare of
the child. FATHER and MOTHER agree that FATHER shall have
primary physical custody of the parties' minor child,
Vincent Marcolin Brown, while MOTHER shall have partial
physical custody of Vincent Marcolin Brown.
,
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d
II
6. ILLNESS OP THE MINOR CHILOl In the event of any
..riou. illne.. of the minor child at any time,' the party
then having physical custody of said minor child shall
immediately communicate with the other party by telephone or
any other means, informing the other party of the nature of
the illness. During such illness, each party shall have the
riqht to visit the child as often as he or she desires,
consistent with the proper medical care of the child.
7.
DOCUMENTS I
Each party shall, at the request of
the other, execute, acknowledge and deliver to the other
party any docUlDents which may be reaBonably necessary to
give full force and effect to this custody Agreement.
B. VOLUNTARY EXECUTION AND FAIRNESS OF THE AGREEMENT I
Each party acknowledges that this Custody Agresment has been
entered into by his and her own volition, and with the
advice of separate, independent counsel, with full knowledge
of the facts and full information as to their legal rights
and that each believes the custody Agreement to be
reasonable and in the best interest of the minor child
under the circumstances and not the result of any dursss or
undue influence.
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9. SITUS I This custody Agreement shall be construed
and governed in accordance with the laws of the commonwealth
of Pennsylvania.
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10.
DESCRIPTIVE HEADINGS I
The descriptive headings
used herein are for convenience only. They shall have no
effect whatsoever in determining the rights and obligations
of the parties.
11. BINDING EFFECTl
Each of the parties hereto
intends to be legally bound. In the event that either party
breaches any provision of this Agreement, and the other
party retains counsel to assist in enforcing the terms
thereof, the parties hereby agree that the breaching party,
if found in contempt and ordered by the Court, will pay all
attorneys fees, Court costs and expenses incurred by the
other party in enforcing that stipulation.
BY THE COURT I
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JESSICA ANN RINIER,
Plaintiff
VS.
I IN TUE OOlJRT Of' cn'olMa'l PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
I NO. 94-3949 CIVIL TERM
I
I CIVIL ACTION - LAW
I
I CUSTODY
soorr BR<l\'N,
Defendant
CJUlBR OF mJRT
AND to, this .23'" day of '" AAv
consideration of the attached CUstody concilQtion
and directed as followSl
, 2000, upon
Report, it is ordered
1. 'l'tle prior order of this Court dated March 9, 1995 is vacated and
replaced with thie order.
2. 'l'tle Mother, Jessica Ann Rinier, and the Father, SCott Brown, shall
have shared legal custody of Vincent Marcolin Brown, born February 23,
1993. Each parent ahall have an equal right, to be exercised jointly with
the other parent, to make all major non-emergency decisions affecting the
Child's general well-being inclUding, but not limited to, all decisions
regarding his health, education and religion.
3. n1e Mother shall have primary p1ysical custody of the Child.
4. The Father shaIl have partial physical custody of the Child on
alternating weekends from Friday at 6100 p.m. through Sunday at BlOO p.m.,
beginning May 26, 2000. The Father shall also have custody of the Child at
any other times arranged by agreement of the parties. The parties shall
continue to discuss special custody arrangements for the surrmer with
expanded custody for the Father.
5. The parties shaIl share or alternate having custody of the Child
on hOlidays as follows I
A. aUUB'DIAS1 n1e Christmas holiday shall be divided into
Segment A, which shall run from Christmas Eve at 12100 noon
through Christmas Day at I2100 noon, and Segment Il, which
shaIl run fran Christmas Day at 12100 noon through Decenber 26
at 12100 noon. 'I11e Father shall have custody of the Child
during Segment A in even numbered years and during Segment B
in odd nunbered yesrs. 'I'Ile Mother shaIl have custody of the
Child during Segment A in odd numbered years and during
Segment Il in even numbered years.
B. ALTmNATIN<J IKlLIDAYSl 'I'he parties shall alternate having
custody of the Child on the foIIowing holidays from 9100 a.m.
until BlOO p.m.l Easter Sunday, MenoriaI Day, JuIy 4th, Labor
Day, and 'nlanksgiving Day. The alternating holiday scheduIe
shall begin with the Father having custody of the Child on
Memorial [~y in 2000.
C. H01'IlBR'S DAY/FATllBR'S DAY: The Mother shall have custody of
the child every year on Mother's Day from 9100 a.m. until BlOO
p.m. and the Father shall have custody of the Child every yesr
on Father's Day from 9100 a.m. until BlOO p.m.
D. The holiday custody schedule shall supersede and take
precedence over the regular custody schedule.
E. In the event the Father's period of holiday custody falls
il1l1lediately before or following his regular period of weekend
custody, the Father's regular/holiday period of custody shall
run continuously.
6. Both parties shall be entitled to have custody of the Child for 2
uninterrupted weeks (consecutive or nonconsecutive) during each surrmer
school break upon providing at least 3 weeks advance notice to the other
party.
7. When the Father is receiving custody of the Child, the parties
shall exchange custody at the Wendy's restaurant in Highspire. When the
Mother is receiving custody of the Child, the parties shall exchange
custody at the McDonalds restaurant at the East Town Mall in Lancaster.
B. The Father may file a Petition within thirty (30) days of the date
of this order to request an additional Custody Conciliation Conference to
review the provisions of this order.
BY THE
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CCl Matthew J. Eshelman, Esquire - Counsel for Mother
SCott Brown, Father
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JESSICA ANN RINIER,
Plaintiff
I IN THE OOURT OF CXlMMOO PLEAS OF
I CUMBERLAND COUNTY, PENNSYLVANIA
I
: NO. 94-3949 CIVIL TERM
vs.
.
.
I CIVIL AC1'ION - LAW
srorT BROON,
Defendant
.
.
I CUSTODY
PRICR JUDGB: GeoI:ge B. Iloffer
ClJS'lOOY CXH:ILIATIOO 5lMARY REPCRT
IN ACXXJUW<<:E WITII CltlBBRLAND CDm'Y RULB OF CML 1<<o""oOOB
1915.3-8, the undersigned custody Conciliator submits the following reportl
1. 'ltte pertinent information concerning the Child who is the subject
of this litigation is as follows:
NAME
ClJRRIWl'LY IN ClJS'lOOY OF
DATE OF BIRTII
Vincent Marcolin Brown
February 23, 1993
Mother
2. A Conciliation Conference was held on May 17, 2000, with the
following individuals in attendance I The Mother, Jessica Ann Rinier, with
her counsel, Matthew J. Eshelman, Esquire. 'ltte Father, Scott Brown, did
not attend the Conference or contact the Conciliator. The Father is not
represented by counsel in this matter.
3. It should be noted that a CUstody Conciliation Conference was
originally scheduled for May 2, 2000 at which the Father aleo did not
appear. However, it was determined that the Father had not been served
with a copy of the order scheduling the Conciliation Conference and
therefore a second Conference was scheduled for May 17, 2000. The Mother's
counsel indicated at the May 17 Conference that the Father had been served
with notice of the Conference by both certified and regular mail.
4. Based on representations made by the Mother and her counsel at the
Conference and the fact that the Father did not attend although he was
served with notice, the Conciliator recOlll1lends an Order in the form as
attached.
f Ma...., { ~ I ,.}. fWd
Date
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DaWn . Sund y, Esqu re
CUstody Conciliator