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HomeMy WebLinkAbout94-04692 ~ ~ ' ~ ~. ~ "~'\ -.. \ i ~ ~ ~: ~/ I J J PENNY DAWN COWFER, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94 - L/ lD q;} CIVIL TERM . . vs. PROTECTION FROM ABUSE RONALD E. SNOWBERGER, JR., Defendant TEMPORARY PROTECTIVE ORDER this 19;;' day of August, 1994, upon presentation AND NOW, and consideration of the within Petition, and upon finding that the plaintiff, PENNY DAWN COWFER, now residing at 1004 N. West street, carlisle, Cumberland county, pennsylvania, is in immediate and present danger of abuse from the defendant, RONALD E. SNOWBERGER, JR., the following Temporary Order is entered. The defendant, RONALD E. SNOWBERGER, JR., now residing at an unknown location, is hereby enjoined from physically abusing the plaintiffr PENNY DAWN COWFER, or placing her in fear of abuse and is ordered to stay away from the residence located at 1004 N. West Street, Carlisle, Cumberland county, Pennsylvania, a residence which is leased solely by the plaintiff. The defendant is hereby notified that if he resides in the plaintiff's domicile contrary to this order, he may be in indirect criminal contempt which is punishable by a fine not to exceed $1,000.00 and/or by a sentence of up to six months in jail and any other appropriate punishment. Resumption of co-residence on the part of the plaintiff and defendant shall not nullify the provisions of the Court Order directing the defendant to refrain from abusing the (. plaintiff. 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 shall be held on this matter on the ~:sfl<- day of August, 1994, at i(:/V n.m. in Courtroom I No. ) , Cumberland County Courthouse, Carlisle, Pennsylvania. The plaintiff may proceed in forma pauperis pending a further order after the hearing. The Cumberland County Sheriff's office shall attempt to make service at the plaintiff's request, but service may be accomplished under any applicable rule of civil Procedure. The Carlisle Police Department will be provided with a copy of this Order by attorneys for plaintiff. This Order shall be enforced by any law enforcement agency where a violation occurs by arrest for indirect criminal contempt without warrant upon probable cause that this Order has been violated, whether or not the violation is committed in the presence of the police officer. In the event that an arrest is made under this section, the defendant shall be taken without unnecessary delay before the court that issued the Order. When that court is unavailable, the t--'- :-u~ defendant shall be taken betore the appropriate district justice (23 Pa.C.S,A. section 6113), By the Court, J. ,.. .,,~-,..~;,;oIi PENNY DAWN COWFER, plaintiff : IN THE COURT OF COMMON PLEAS OF . . CUMBERLAND COUNTY, PENNSYLVANIA NO. 94 - LJ",qJ. CIVIL TERM vs. . . PROTECTION FROM ABUSE RONALD E. SNOWBERGER, JR., 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. i ;1 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. l COURT ADMINISTRATOR, 4th FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 240-6200 ! i r. I :1 , ~ " r PENNY DAWN COWFER, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94 - 41&.9;. CIVIL TERM vs. PROTECTION FROM ABUSE RONALD E. SNOWBERGER, JR., Defendant PETITION FOR PROTECTIVE ORDER 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 1004 N. West Street, Carlisle, Cumberland County, Pennsylvania, 17013. 2. The defendant is an adult individual whose residence is unknown to the plaintiff. 3. The defendant is the plaintiff'S former intimate partner. 4. Since approximately 1991, the defendant has attempted to cause and has intentionally, knowingly, or recklessly caused bodily injury to the plaintiff, and by physical menace has placed the plaintiff in fear of imminent serious bodily injury. This has included but is not limited to the following specific instances of abuse: a. On or about August 15, 1994, the defendant grabbed the plaintiff by the arms and restrained her saying, "I'll put you in a sleeper hold and tell the kids you went to sleep forever," causing the plaintiff to fear for her safety. b. On or about August 10, 1994, the defendant grabbed the plaintiff by the arms and screamed in her face, causing the plaintiff to fear for her safety and call the police. c. On or about July 15, 1994, the defendant grabbed the plaintiff by the arms and threatened to kill her. d. Since in or around May of 1994 on a weekly basis, the defendant forcefully grabbed hold of the plaintiff and on several occasions pushed her up against walls restraining her. e. On or about July 6, 1993, the defendant threatened to kill the plaintiff, grabbed her by the throat with both hands, shoved her against a wall, and threw the plaintiff onto a couch. The defendant again grabbed the plaintiff by the throat, pulled his arm back and said, "I'm doing it right now," causing the plaintiff to fear for her safety. f. On or about July 3, 1993, the defendant picked up a knife, held it in the air towards all the people gathered in the room, including the plaintiff, and threatened to kill them all. The defendant grabbed the plaintiff forcing her to come with him. A friend coaxed the knife from the defendant and when the police were called, the defendant left the residence. g. Approximately three years ago, the defendant held a gun to the plaintiff's head and threatened to kill her. 5. The plaintiff believes and therefore avers that she will be in immediate and present danger of abuse from the defendant, and that she is in need of protection from such abuse. 6. The plaintiff desires that the defendant be restrained from entering her place of employment, having any contact with her, harassing or stalking the plaintiff, and from harassing the plaintiff's relatives. B. EXCLUSIVE POSSESSION 7. The home from which the plaintiff is asking the Court to exclude the defendant is rented in the name of PENNY COWFER and the defendant voluntarily left the residence on August 18, 1994. C. ATTORNEY FEES 8. The plaintiff asks for attorney fees to be paid to Legal Services, Inc., pursuant to the Protection from Abuse Act. D. STATUS TO PROCEED IN FORMA PAUPERIS 9. The defendant is employed at Carlisle container and has an hourly salary of approximately $7.25. 10. The plaintiff currently is employed at George's Flowers and receives $5.00 per hour. 11. The plaintiff does not have funds available to pay the 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 et sea., 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. f' ...t-.:o...o~>'! 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. Ordering the defendant to stay away from the residence located at 1004 N. West street, Carlisle, which the defendant moved from on August 18, 1994. 4. Ordering the defendant to stay away from any residence the plaintiff may in the future establish for herself. B. Schedule a hearing in accordance with the provisions of the "Protection from Abuse Act," and, after such hearing, enter an order to be in effect for a period of one year: 1. Requiring the defendant to refrain from abusing the plaintiff or placing her in fear of abuse. 2. Requiring the defendant to refrain from having any contact with the plaintiff, including, but not limited to, entering the plaintiff's place of employment, harassing or stalking the plaintiff, and harassing the plaintiff's relatives. 3. Ordering the defendant to stay away from the residence located at 1004 N. West street, Carlisle. 4. Ordering the defendant to stay away from any residence the plaintiff may in the future establish for herself. f' 5. Ordering the defendant to pay attorney fees to Legal Services, Inc, pursuant to the Protection From Abuse Act. The plaintiff further asks that this Petition be filed and served without payment of costs, pending a further order at the hearing, and that a copy of this Petition and Order be delivered to the Carlisle Police Department as the Police Department with jurisdiction to enforce this Order. The plaintiff prays for such other relief as may be just and proper. Respectfully submitted, \ {~, Jo n carey &. !l'nI: Attorney for ~a~ntiff LEGAL SERVICES, INC. a Irvine Row Carlisle, PA 17013 (717) 243-9400 The above-named Plaintiff, Penny Dawn Cowfer, verifies that the statements made in the above Petition are true and correct. Plaintiff understands that false statements herein are made subject to the penalties of 18 Pat C.S. 64904, relating to unsworn falsification to Date: <6-11-11 , --- .I G ~'r ~~ ~.- .",...~ 0">' = 0..-' ".. . I '.~ '-~. .,: > f- .-.;~.. '" -. a \J ~>- ~ . 4 ~ o Cl t.r\ "'"' .Ip' "'.' PENNY DAWN COWPER, plaint iff IN THE COURT OP COMMON PLEAS OP CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4692 CIVIL TERM vs. RONALD E. SNOWBERGER, JR., defendant PROTECTION FROM ABUSE ORDER FOR CONTINUANCE AND NOW, this J ,..... ,~ day of August, 1994, upon consideration of the attached Motion for Continuance, the matter scheduled for hearing on August 25, 1994, is hereby continued until (9r!-dW ill , 1994, at /1-' '/'(1 )';"M. in Courtroom No.3. The Temporary Protective Order will remain in effect pending further Order of Court. A copy of this Order for Continuance will be provided to the Carlisle Police Department by the plaintiff's attorney. By the Court, J. ~ ,.'. ' J..;\ .' f\',' ~'!"; -1:1 ""l' ',' ;: 'i-i) I , \ \IS, ~\ st \ \ 62 ~n~ . ~'"i - ~ PENNY DAWN COWFER, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4692 CIVIL TERN vs. RONALD E. SNOWBERGER, JR., defendant PROTECTION FROM ABUSE MOTION FOR CONTINUANCE The plaintiff moves the Court for an Order to continue the hearing in the above-captioned case on the grounds that: 1. A Temporsry Protective Order was issued by this Court on August 19, 1994, sCheduling a hearing for August 25, 1994, at 4:00 p.m. 2. The defendant has left Cumberland County and the Cumberland County Sheriff's Department has not been able to serve the defendant. 3. The plaintiff requests a continuance to afford the Sheriff's Department time to effect service on the defendant at a new location. 4. The plaintiff further asks that the Temporary Protective Order remain in effect pending further Order of Court. 5. A copy of the Order for Continuance will be delivered to the Carlisle Police Department by sttorneys for the plaintiff. WHEREFORE, the plaintiff requests that the Court grant the Motion to continue this matter and that the Temporary " Protective Order remain in effect until further Order of Court. Respectfully submitted, an Carey Attorney for Pia ntiff LEOAL S~RVICES. INC. B Irvine Row Carlisle, PA 17013 (717) 243-9400 <, ," . SHERIFF'S RETURN COMMONWEALTH OF PENNSYLVANIA In The Court of Common Pleas of Cumberland County, Pennsylvaia COUNTY OF CUMBERLAND No. 94-4692 Civil Term Temporary Protective Order Protection From Abuse Penny Dawn Cowfer VS Ronald E. Snowberger Jr. R. THOMAS KLINE, Sheriff, who being duly sworn according to law, says, that he made diligent search and inquiry for the within named defendant to wit: Ronald E. Snowberger Jr. but was unable to locate him in his bailiwick. He therefore returns the TemDorarv Protective Order Protect~ FOUND, as to the within named From Abuse defendant, Ronald E. Snowberger Jr.. Defendant's Aunt stated he mav have moved to Altoona, PA. I . Sheriff's Costs: Docketing Service Affidavit Surcharge So answers: // __1,' ~~. \ ,'-<'~ .--''':: >;_ ///'r'-"~- R. THOMAS KLINE, 14.00 2.80 ~ /----..-:" ,/~7;: 2.00 18.80 Sheriff Sworn and subscribed to before me this 31~ day of aJ" ..r A.D. 19 9'1 'rJ:i'" (;, n,L'"tl,_ ~. thonotary . {........ . - INSTRUCTIONS TO TIlE D~"JmuAN'l' As you know, the plaintiff has filed a legal action against you under the Protection From Abuse Act and has obtained a Temporary Protective Order. The plaintiff is prepared to have a hearing held in order to obtain a Final Protective Order effective for one (1) year. As an alternative, you may consent to the entry of the Final Protective Order to be in effect for one year. If you are willing to consent you should call Legal Services, Inc., 243-9400 or 766-8475, and ask to speak to the staff person handling the case about a Consent Agreement. The Consent Agreement should be prepared before the time scheduled for the hearin~ so the Court will know ahead of time that the case will not be contested. In most cases. regardless of whether a settlement by Consent Agreement has been reached. the parties must appear in court at the time scheduled for hearing. If the case is uncontested, the court appearance will be brief, The judge will make sure the parties understand ~he Consent Agreement and Final Protective Order. If YOU do not agree to the entry of the Final Protective Order, a contested hearin~ will take place at the scheduled time. When a Final Protective Order is entered. it will be sent or given to you, the plaintiff, and the appropriate police deDartments. If you fail to abide by the terms of the Final Protective Order you will be subject to immediate arrest, and a fine of up to $1,000.00 and/or a ,jail sentence of up to six mDnths and other relief. You have the right to be represented in this matter. You should take the legal papers that have already been served on you to your lawyer immediately. If you do not know of an attorney or cannot afford one, you may contact: Court Administrator, 4th Floor Cumberland County Courthouse Carlisle, PA 17013 (7171 243-9400 PENNY DAWN COWFER, Plaintiff : IN THE COURT OF COMMON PLEAS OF . . . . . . . . CUMBERLAND COUNTY, PENNSYLVANIA NO. 94 - 4~q~ CIVIL TERM vs. . . : PROTECTION FROM ABUSE RONALD E. SNOWBERGER, JR., Defendant . . . . . . TEMPORARY PROTECTIVE ORDER AND NOW, this Iq1~day of August, 1994, upon presentation and consideration of the within Petition, and upon finding 'that the plaintiff, PENNY DAWN COWFER, now residing at 1004 N. West Street, Carlisle, Cumberland County, Pennsylvania, is in immediate and present danger of abuse from the defendant, RONALD E. SNOWBERGER, JR., the fOllowing Temporary Order is entered. The defendant, RONALD E. SNOWBERGER, JR., now residing at an unknown location, is hereby enjoined from physically abusing the plaintiff, PENNY DAWN COWFER, or placing her in fear of abuse and is ordered to stay away from the residence located at 1004 N. West Street, Carlisle, Cumberland County, Pennsylvania, a residence which is leased solely by the plaintiff. The defendant is hereby notified that if he resides in the plaintiff's domicile contrary to this Order, he may be in indirect criminal contempt which is puniShable by a fine not to exceed $1,000.00 and/or by a sentence of up to six months in jail and any other appropriate puniShment. Resumption of co-residence on the part of the plaintiff and defendant shall not nullify the provisions of the Court Order directing the defendant to refrain from abusing the plaintiff. 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 shall be held on this matter on the .;1.$1" day of August, 1994, at LJ:DO II .m. in Courtroom , No. ~ , Cumberland County Courthouse, Carlisle, Pennsylvania. The plaintiff may proceed in forma DauDeris pending a further order after the hearing. The Cumberland County Sheriff's office shall attempt to make service at the plaintiff's request, but service may be accomplished under any applicable rule of civil Procedure. The Carlisle Police Department will be provided with a copy of this Order by attorneys for plaintiff. This Order shall be enforced by any law enforcement agency where a violation occurs by arrest for indirect criminal contempt without warrant upon probable cause that this Order has been violate~, whether or not the violation is committed in the presence of the police officer. In the event that an arrest is made under this section, the defendant shall be taken without unnecessary delay before the court that issued the Order. When that court is unavailable, the defendant shall be taken before the appropriate district justice (23 Pa.C.S.A. Section 6113). By the Court, is / ,Jjr flj' {l I'll ~ I I J. TRUE COpy FROM RECORD In Testimony whereof, I ~rB wnto set my I\IInd and the 9!la1 (II ~~ Coo~~l~' lk This /'1Jt.. ,'jl:'/ 01._ ~. 19- ~p/,~. Pllllhooot.1l1 PENNY DAWN COWFER, plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94 - CIVIL TERM vs. PROTECTION FROM ABUSE RONALD E. SNOWBERGER, JR., Defendant NOTICE You have been sued in court. If you wish to defend against the claims set forth in the fOllowing pages, you must take action promptly after this Petition, Order and Notice are served, by appearing personally or by attorney at the hearing scheduled by the Court and presenting to the Court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the Court may proceed without you, and a judgment may be entered against you by the Court without further notice for any money claimed in the Petition or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. COURT ADMINISTRATOR, 4th FLOOR CUMBERLAND COUNTY COURTHOUSE CARLISLE, PENNSYLVANIA 17013 TELEPHONE NUMBER: (717) 240-6200 PENNY DAWN COWFER, Plaintiff . . . . . . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA : NO. 94 - CIVIL TERM vs. . . PROTECTION FROM ABUSE RONALD E. SNOWBERGER, JR., Defendant . . PETITION FOR PROTECTIVE ORDER 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 1004 N. West Street, Carlisle, Cumberland County, Pennsylvania, 17013. 2. The defendant is an adult individual whose residence is unknown to the plaintiff. 3. The defendant is the plaintiff's former intimate partner. 4. Since approximately 1991, the defendant has attempted to cause and has intentionally, knowingly, or recklessly caused bodily injury to the plaintiff, and by physical m9nace h~s placed the plaintiff in fear of imminent serious bodily injury. This has included but is not limited to the following specific instances of abuse: a. On or about August 15, 1994, the defendant grabbed the plaintiff by the arms and restrained her saying, "I'll put you in a sleeper hold and tell the kids you went to sleep forever," causing the plaintiff to fear for her safety. {' b. On or about August 10, 1994, the defendant grabbed the plaintiff by the arms and screamed in her face, causing the plaintiff to fear for her safety and call the police. c. On or about July 15, 1994, the defendant grabbed the plaintiff by the arms and threatened to kill her. d. Since in or around May of 1994 on a weekly basis, the defendant forcefully grabbed hold of the plaintiff and on several occasions pushed her up against walls restraining her. e. On or about July 6, 1993, the defendant threatened to kill the plaintiff, grabbed her by the throat with both hands, shoved her against a wall, and threw the plaintiff onto a couch. The defendant again grabbed the plaintiff by the throat, pulled his arm back and said, "I'm doing it right now," causing the plaintiff to fear for her safety. f. On or about July 3, 1993, the defendant picked up a knife, held it in the air towards all the people gathered in the room, including the plaintiff, and threatened to kill them all. The defendant grabbed the plaintiff forcing her to come with him. A friend coaxed the knife from the defenda~t' end when the police were called, the defendant left the residence. g. Approximately three years ago, the defendant held a gun to the plaintiff's head and threatened to kill her. 5. The plaintiff believes and therefore avers that she will be in immediate and present danger of abuse from the defendant, and that she is in need of protection from such abuse. 6. The plaintiff desires that the defendant be restrained from enterinq her place of employment, havinq any contact with her, harassinq or stalkinq the plaintiff, and from harassinq the plaintiff's relatives. B. EXCLUSIVE POSSESSION 7. The home from which the plaintiff is askinq the Court to exclude the defendant is rented in the name of PENNY COWFER and the defendant voluntarily left the residence on Auqust 18, 1994. C. ATTORNEY FEES 8. The plaintiff asks for attorney fees to be paid to Leqal Services, Inc., pursuant to the Protection from Abuse Act. D. STATUS TO PROCEED IN FORMA PAUPERIS 9. The defendant is employed at carlisle Container and has an hourly salary of approximately $7.25. 10. The plaintiff currently is employed at Georqe's Flowers and receives $5.00 per hour. 11. The plaintiff does not have funds available to pay the fees for filinq and service. WHEREFORE, pursuant to the provisions of the "Protection from Abuse Act" of October 7, 1976, 23 P.S. Section 6101 ~ ~., as amended, the plaintiff prays this Honorable Court to grant the fOllowing relief: A. Grant a Temporary Order pursuant to the "Protection from Abuse Act:" 1. Requirinq the defendant to refrain from abusing the plaintiff or placinq 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. Ordering the defendant to stay away from the residence located at 1004 N. West street, Carlisle, which the defendant moved from on August 18, 1994. 4. ordering the defendant to stay away from any residence the plaintiff may in the future establish for herself. B. Schedule a hearing in accordance with the provisions of the "Protection from Abuse Act," and, after such hearing, enter an order to be in effect for a period of one year: 1. Requiring the defendant to refrain from abusing the plaintiff or placing her in fear of abuse. 2. Requiring the defendant to refrain from having any contact with the plaintiff, including, but not limited to, entering the plaintiff's place of employment, harassing or stalking the plaintiff, and harassing the plaintiff's relatives. 3. Ordering the defendant to stay away from the residence located at 1004 N. West Street, Carlisle. 4. Ordering the defendant to stay away from any residence the plaintiff may in the future establish for herself. 5. Ordering the defendant to pay attorney fees to Legal Services, Inc, pursuant to the Protection From Abuse Act. The plaintiff further asks that this Petition be filed and served without payment of costs, pending a further order at the hearing, and that a copy of this Petition and Order be delivered to the Carlisle Police Department as the Police Department with jurisdiction to enforce this Order. The plaintiff prays for such other relief as may be just and proper. Respectfully submitted, .1.\ {~, Jo n carey fr, Attorney for ~a n iff LEGAL SERVICES, INC. a Irvine Row Carlisle, PA 17013 (717) 243-9400 t' The above-named Plaintiff, Penny Dawn Cowfer, verifies that the statements made in the above Petition are true and correct. Plaintiff understands that false statements herein are made SUbject to the penalties of 18 Pa. C.S. 64904, relating to unsworn falsification to Date: ~-11-1( lil!iliiiith;! I i , I I. . I!:!!D ~ C!B ~ :;-:;~ .., " ., ."l , ." PENNY DAWN COWFER. Plaintiff IN THE COURT OF COMMON PLEAS OF ClIlBERLAND COUNTY. PENNSYLVANIA VB. No. 94-4692 PROTECTION FROM ABUSE CIVIL TERM RONALD E. SNOWBERGER. JR.. , Defendant PRAECIPE TO WITHDRAW ACTION The Dlaintiff in the above-caDtioned case reauests that the Petition for Protection from Abuse filed on AUQust 19. 1994. be withdrawn. and the Temoorarv Order be vacated. To Lawrence E. Welker Prothonotary AUQust 30. 19~ gf~ (~ Joan Cae Y, Attorney r Plaintiff ~~ No. 94-4692 CIVIL TERM PENNY DAWN COWFER. Plaintiff VB. RONALD E. SNOWBERGER. JR. Defendant P RAE C I P E Filed AURust 30th 1994 I Atty. Joan Carev LEGAL SERVICES. INC. ~ u.> - ~'';1 t ,.\, r: -:or. w ~., ... ,. ",' ~...,:": - 5\ ;.'.?; ~"l 'f~ ". "" -; .~:; -'.1 ~ . ~