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HomeMy WebLinkAbout94-04902 , ,I I' , , ~\ I I'!; tit 1,1 Pt " , II 1 ::c il" -7 1 :r , , ~" , " , . \ 'i ,I ),,' " , , .., I" I I ~/ . I ~ ..-All>" -., ..' ,'/,J n~',l,t tJ'4:r,:,~~ '\: l~r:; :' ~!~:' ),fl i . j..__..l',1'il})jl.'I.....,,,-..,,,,' 1,';',-, ._-j .' [.,'J,y...-." ...' ',(" -,.. :j);;tt1 '~ll! ,~ I ,;:.~" ./-, ,,~~jl~I,:~,~':ii;lC/ ,'!<,,', ," ' , .... ~ \J . f ,. " -,.:.. ",.'nl,jt\ ','I, /, j j ,I I, I '1, 1'\" I, I 1 ' """,'/'1''''1 ":,, d'......"......, /':j,d~J'}O' ~"'I.\;l:1 ~r' 1IIUt' I ~~~lf Il,' I ,!! l I I 'I 1 '. III'" '11", 1 II' ' ,;i ,I> I \ " . ~~"'" j' , . ;ltl /i'!'l\I:;[;"l'~:I, I,r';r' : I< 'I '" ,"'. ~ f!:',' "( ( " 'l'! I f I \;1'1/' '\' . I" !,........'; ~.... rj,., J"~J, J,I I' 1 Il', ,~", , I,I'~I: JJr ;{pW,} J:,'".' f ,"', !, ';0,;' ,'iJt11t'tl ~";ti~,fl'~>"I'{tLII'''~ ...... '. ",<\.,,,.1,,"1,,,,)11"/,, ,',1 ::..'.~'" m'...,., 'I" o1',\,',:~:;\l /, ,: ;:,,',: ",,:<,, ~ J ", ,I ~ ~ "'" ,I I \ " ;' I Jr,' I ~ I,! ~~, " I}I ';\ ,; " I I" ,~ It I' ~ CONNEE LOUISE HEMPT, Plaint i ft IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94 - ~_~2. CIVIL TERM vs. PROTECTION FROM ABUSE MICHAEL A. HEMPT, Defendant JEMPOMfl:LP-BQllr,;T 1 VE ORQt.Fj AND NOW, this.J<.L~ day of August, 1994, upon presentation and consideration of the within Petition, and upon finding that the plaintiff, CONNEE LOUISE HEMPT, now residing at 3790 Mountainview Road, Mechanicsburg, Cumberland CQunty, Pennsylvania, is in immediate and present danger of abuse from the defendant, MICHAEL A. HEMPT, the following Temporary Order is entered. The defendant, MICHAEL A. HEMPT, now residing at 505 Third Street, New Cumberland, Cumberland County, Pennsylvania, is hereby enjoined from physically abusing the plaintiff. CONNEE LOUISE HEMPT, or placing her in fear of abuse and is ordered to stay away from the residence located at 3790 Mountainview Road, Mechanicsburg, Cumberland County, Pennsylvania, except for the purpose of facilitating periods of partial custody by waiting outside the residence in his vehicle. The residence is jointly owned by t he part ies, but t he defendant moved out of vo I unt 1\1' i1 Y in June 1994. The def endant is hereby not if i ed t hat if hI' resides in the plaintiff's domicile contrarv 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-residencl3 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, except for the purpose of facilitating periods of partial custody, including, but not limited to, harassing or stalking the plaintiff. 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 ltl'" day of September, 1994, at 1:<1', C-.m. in Courtroom No. lX ,Cumberland County Courthouse, Carlisle, Pennsylvania. 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 Hampden Township 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 CONNEE LOUISE HEMPT, Plaintiff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94 - CIVIL TERM vs. PROTECTION FROM ABUSE MICHAEL A. HEMPT, Defendant MQIJ.Q.E 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 the stairs, and started arguing with the plaintiff. The defendant then reached down and grabbed the plaintiff with one hand on the buttocks and the other hand in the plaintiff's pelvic area. The plaintiff went to the closet to get things the defendant had requested and as she was crouched down, tha defendant repeatedly pushed her down with his leg. When the plaintiff stood up, the defendant stood on her feet to prevent her from leaving and argued with her. The defendant became angry and punched the plaintiff in the pelvic area with his fist. The defendant then spit in the plaintiff's face and hair. When the plaintiff went for the telephone, the defendant left. The plaintiff suffered soreness and pain about her pelvic area. b. On or about August 7, 1994, the defendant punChed the plaintiff in the ribs with his fist, knocking the wind out of the plaintiff and causing soreness. c. In or around the beginning of June 1994, the defendant pushed the plaintiff into her bed, causing her to hit her thigh on the frame and suffer bruising. d. In or around the end of April 1994, the defendant pushed the plaintiff into the wall, causing her to hit her head against the wall. e. In or around March 1994, while the plaintiff was sitting in a chair, the defendant pushed the chair with enough force to break the leg of the chair, causing the plaintiff to fear for her safety. f. In the past, on apprOXimately a weekly basis, the defendant has abused the plaintiff in ways inCluding, but not limited to, the following: pushing the plaint iff with his body, knocking her off balance, and standing on the plaintiff's feet. 5. The plaintiff believes and therefore avers that she will be in immediate and present danger of abuse from the defendant, and that she is in need of protection from such abuse. 6. The plaintiff desires that the defendant be restrained from having any contact with her, except for the purpose of facilitating periods of partial custody, and from harassing or stalking her. L-_ilCJ.~UIL.f-QSSESS1.QN 7. The home from which the plaintiff is aSking the Court to exclude the defendant is owned in the names of CONNEE and MICHAEL HEMPT, but the defendant voluntarily moved out in June 1994. h..--.l..Q.S~...E.s. 8. The plaintiff asks for attorney fees to be paid to Legal Services, Inc. pursuant to the Protection from Abuse Act. 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. 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, except for the purpoae of facilitating periods of partial custody, including, but not limited to, harassing or stalking the plaintiff. 3. Ordering the defendant to stay away from the residence located at 3790 Mountainview Road, Mechanicsburg, except for the purpose of facilitating periods of partial custody by waiting outside the residence in his vehicle. 4. Ordering the defendant to stay away from any residence the plaintiff may in the future establish for herself, except for the purpose of facilitating periods of partial custody by waiting outside the residence in his vehicle. B. Schedule a hearing in accQrdance 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: I. Requiring the defendant to refrain from abuJing the plaintiff or placing her in fear of abuse. 2. Requiring the defendant to refrain from having any contact with the plaintiff, except for the purpose of faCilitating periods of partial custody including, but not limited to, harassing or stalking the plaintiff. 3. Ordering the defendant to stay away from the residence located at 3790 Mountainview Road, Mechanicsburg, except for the purpose of facilitatinG periods of partial custody by waiting outside the residence in his vehicle. 4. Ordering the defendant to stay away from any r:: , .. ", " " " , ',01 " " ,I t/ll ,'I, ',Il Jli " , " I" , " ',' , @ ~uc 30 3 3J rM '9~ ;. I-Ice .I'I'~fM\'f ;'lir .^ .' ", I . .. i . ~ ' :' ';:,~ fJl.fO.r()1'~' f1itt (~.,..q S.O() ~ f ,+>:5'0 .btJ F' att, eu,~ I j- 2~V .,-..~._......_.......~.,......._~...,."...- )...., ""--1111I1 J~ I J'111 ~'h\_n..~ ' '" .~ ~ i t c ~.' ," " .. ,~ . it. .' , .'1 ,; ,~ .' .'"1,'.., t, lt1'-"'~~ ".( ,'j' . , ,,' , I I I II' i il. 1/\ {'IJ I " ""',,, I .' 1,'I',",,'n :jl\1 )'., "',;' ",'I"!,'., I ,'tI,;1 :-1;:' I'!.", i,l ,I Ii 'I~. , '1/ I, I'i '" , , , " I ''Ii " ,,' , ' " I, I, ", )'1" J, ~ .' , ;' 'I , , , ", " ',,;;'h,'" , ~; ... 1 I I'.. " " h I' . ", . \1, .' ~ " . f 1_1 , , ,(IL'>i,'!,+"'\i j' ',i" ",I'.'II'(h-'iJi't',', c.. .', .1;:,,/.;"',.1{ """,;,~l,' t ',";"", (:,,>.,-..!: \,~! II~ ',il',.J i.', ",';,!;,:;,'" ' 11/,I-;:I/":'>j"Ii'"",""'''.'''':'i ";,!-i!','Jl.lli::i("/V,'i;~' ,i, 1:":"""/';"""(,1 'I" 'pT'!;,;",'" .1, i"',\,~.'~I1/JJI[II!i.r(" ,.1, ",' ',' }, \"iY . ,I:.II ~';; i' "i'" , ' I.{ ". "..... '~;,'.. .f!,. ""T-".;'~~ ' I' " . ....,.', .. " '" '., "'t~'~";"'~:'\l\'::'I',"::','l,\~,l;)i.':/r'( ''''''.'..81''1' 1 r , MrJi':"T~\':ll';U:~i,;T\i',A'I" "'1..._...... ,~f'I" ,./;Jl~ .1"1'" 1,':,1' "'1 ,j ('. v . '"l'i'" "_I;i."'';'!''I''''''(''I'\'~~'''.J._~'' ~\)/;'ti'..I;~:{t'f'l' , 'IM__" m.. \ ''i~'ll,;' '"i/',''' ,,( 1 , ", , , "r' .,."" 'if J\ lI.lo.i ' ,,1)../,_'),1,'" I", ,,' "...rrt7UIIUiII ' , :.." .;!j}.rt~\~;'i,~.WI!i\,-I. 'II:'!I'*......."'I'~ ~""l',' ,'\I.I! . ,.' ." ,~,,. :'''.'')''i:'I'",' ", ~t~~I_"l'mlllio_' ~}Jl\' I~'f I \, ,I "'I' ..' " ; ..' ." " 'I ,'" " " 1,1' " " "Ii ',~: ,i",l ,,Ii "I , " " " ~ , I " ,( '~ ,,I '\. , ::~ '~ ~ ~') r1 r " r. lV, , " , , ..._.~~ ,--- J} ~~ (.l1 '< ~ -\3 } 1 oj '>. ... e:- , 1/>0 " , , " I,. r I jl .) , ? " ;, . ~ r . r \,d \, ~ vs. I IN TilE COURT OF COMMON PLEAS OF I I CUMBERLAND COUNTY, PENNSYLVANIA I I NO. 94 - 4902 CIVIL TERM I I PROTECTION FROM ABUSE CONNEE LOUISE HEMPT, plaintiff MICHAEL A. HEMPT, Defendant AND NOW, this PROTECTIVE ORDER 7{1/- ____ day of October, 1994, upon consideration of the Consent Agreement of the parties, the following Order is entered: 1. The defendant, MICHAEL A. HEMPT, is enjoined from physically abusing the plaintiff, CONNEE LOUISE HEMPT, or from placing her in fear of abuse. 2. The defendant, MICHAEL A. HEMPT, is enjoined from initiating any contact with the plaintiff, except for the purpose of custody, and such communication will be done by telephone. 3. The defendant, MICHAEL A. HEMPT, is enjoined from harassing or stalking the plaintiff. 4. The defendant, MICHAEL A. HEMPT, is ordered to stay away from the residence located at 3790 Mountainview Road, Mechanicsburg, Pennsylvania, except for the purpose of facilitating periods of shared custody by waiting outside the residence in his vehicle, and from any other residence the plaintiff may establish for herself in the future. The defendant shall seek modification (change) of this Order before living with the plaintiff in a domicile she may establish for herself in the future, wherever it may be. The defendant is hereby notified that if he resides in the plaintiff's domicile contrary to this order, he may be in indirect criminal contempt which is punishable by a fine not to exceed $1,000 and/or by a sentence of up to six months in jail and any other appropriate punishment. Resumption of co-residence on the part of the defendant shall not nullify th~ provisions of the Court Order directing the defendant to refrain from abusing the plaintiff. 5. This Order shall remain in effect for a period of one year. 6. The Hampden Township Police Department wil.l be provided with a copy of this Order by attorneys for plaintiff and may enforce this Order by arrest for indirect criminal contempt without warrant upon probable cause that this Order has been violated, whether or not the violation is committed in the presenc~ of the police officer. In the event that an arrest is made under this section, the defendant shall taken without unnecessary delay before the Court that issued the Order. When that Court is unavailable, the defendant shall, b - , the appropriate district justice (23 ~S/S~cti aken before '0'0 VB. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94 - 4902 CIVIL TERM PROTECTION FROM ABUSE CONNEE LOUISE HEMPT, Plaintiff MICHAEL A. HEMPT, Defendant CONSENT AGREEMENT This Agreement is entered on this ~ day of September, 1994, by the plaintiff, CONNEE LOUISE HEMPT, and the defendant, MICHAEL A. HEMPT. The plaintiff is represented by Joan carey, of Legal Services, Inc.; the defendant is represented by Samuel L. Andes, of Andes, Vaughn & Bangs. The defendant has reviewed the averments set out in the plaintiff's Petition and denies all of them. Nevertheless, to avoid any further dispute in the matter, the parties agree that th~ following may be entered as an Order of Court. 1. The defendant, MICHAEL A. HEMPT, agrees to refrain from abusing the plaintiff, CONNEE LOUISE HEMPT, or from placing her in fear of abuse. 2. The defendant agrees not to initiate any contact with the plaintiff, except for the purpose of custody, and such communication will be done by telephone. 3. The defendant agrees not to harass or stalk the plaintiff. 4. The defendant agrees to stay away from the residence located at 3790 Mountainview Road, Mechanicsburg, Pennsylvania, '. " ,1 " " " I .i )~."I' ! 1,1 /' I,' r. I' ~ v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4902 CIVIL TERM PROTECTION FROM ABUSE CONN!! LOUISE HEMPT, Plaintiff MICHAEL A. HEMPT, Defendant TBKPORARY PROTIOTION ORDIR AND NOW, this l)tJ~ day of April 1996, upon presentation and consideration of the within Petition, and upon finding that the plaintiff, CONNEE HEMPT, now residing at 3790 Mountainview Road, Mechanicsburg, Cumberland county, Pennsylvania, is in immediate and present danger of abuse from the defendant, MICHAEL A. HEMPT, the following Temporary Order is entered. The defendant, MICHAEL A. HEMPT, S5N:202-46-5529 and 00B:8/19/55, now residing at 505 Third street, New cumberland, Cumberland County, Pennsylvania, is hereby enjoined from physically abusing the plaintiff, CONNEE HEMPT, or placing her in fear of abuse. The defendant is ordered to stay away from the plaintiff's residence located at 3790 Mountainview Road, Mechanicsburg, Cumberland county, Pennsylvania, a residence from which the defendant moved several years ago, except for the limited purpose of transferring custody of the parties' children. The defendant shall remain in his vehicle at all times during the transfer of qustody. The defendant is ordered to refrain from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications, except for the limited purpose of facilitating custody arrangements. The defendant is enjoined from harassing and stalking the plaintiff and from harassing the plaintiff'S relatives, The defendant is enjoined from entering the plaintiff'S place of employment. The defendant is enjoined from removing, damaging, destroying or selling any property owned solely by the plaintiff. A violation of this order may subj.ct the d~fendant tOI i) arrest under 23 Pa. C.8. 5'113; ii) a private criminal complaint under 23 Pa. C.8. 56113.1; iii) a charq. of indirect criminal contempt under 23 Pa. C.8. 56114, punishable by imprisonment up to six months and a fine of fl00.00-fl,000.00; and iv) civil contempt under 23 Pa. C.8. 5'114.1. Resumption of co-residenc~ on the part of the plaintiff and defendant shall not nullify the provisions of the court order. This Order shall remain in effect until modified or terminated by the Court after notice or hearing and can be extended beyond its original expiration date if the Court finds that the defendant has committed another act of abuse or has engaged in a pattern or practice that indicates continued risk of harm to the plaintiff. A hearing shall be April, 1996, at ~,~l' held on this matter on the .~ 1)1. day of ,..'.m., in Courtroom NO...i-, Cumberland County Courthouse, Carlisle, Pennsylvania. The plaintiff may proceed without pre-payment of fees pendinq a further order after the hearinq. The Cumberland county Sheriff's Department shall attempt to make .ervice at the plaintiff's request and without pre-payment of tees, but service may be accomplished under any applicable rule of civil Procedure, This Order shall be docketed in the office of the Prothonotary and forwarded to the Sheriff for service. The Prothonotary shall not send a copy of this Order to the defendant by mail. The Hampden Township Police Department shall be provided with a cdrtified copy of this Order by the plaintiff's attorney. This Order shall be enforced by any law enforcement aqency 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 unnecessar.y delay before the court that issued the order. When that court is unavailable, the defendant shall be taken before the appropriate district justice. (23 pal Y'S. S 6113). I By the c01t, .~,//J Edq!'{. · BaYl~Y, JUdqe r:' -- .....'-1 , " , ; 'Jl .~ J " I '., .. , I , I ,j\,..JL , ,I,.\. ,'I (I " illH'''L)I'1~l,,'1 \'Yl'C.'grl .-\0 \-.' ~. ..j I"~ H w ',) v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4902 CIVIL TERM PROTECTION FROM ABUSE CONNEE LOUISE HEMPT, Plaintiff MICHAEL A. HEMPT, Defendant 'ITITION-1Q& 'ROTICTION ORDIR RILII' UNDIR THI 'ROTICTION 'RON AlUSI ACT, 23 '.S. S 6101 et leq. A. AlUSI 1. The plaintiff, CONNEE HEMPT, is an adult individual . residing at 3790 Mountainview Road, Mechanicsburg, Cumberland county, Pennsylvania 17055, 2. The defendant, MICHAEL A. HEMPT, SSN:202-46-5529 and 00B:8/19/55, is an ~dult individual residing at 505 Third street, New Cumberland, Cumberland County, Pennsylvania, 17070. 3. The defendant is the husband of the plaintiff. 4. Since approximately 1994, the defendant has attempted to cause and has intentionally, knowingly, or recklessly caused bodily injury to the plaintiff, has placed the plaintiff in reasonable fear of imminent serious bodily injury, and has knowingly engaged in a course of conduct or repeatedly committed acts toward the plaintiff under circumstances which have placed the plaintiff in reasonable fear of bodily injury. This has included, but is not limited to, the following specific instances of abuse: a, On or about March 16, 1996, the defendant returned the children to the plaintiff and upon leaving, pinched the plaintiff's arm, b. In or around the beginning of March 1996, the defendant punctured the plaintiff's tires on several occassions, causing the plaintiff to fear for her safety. c. In or around the boginning of March 1996, during a telephone conversation, the defendant told the plaintiff he was not finished with her yet. The defendant called back several minutes later and told the plaintiff to sleep well, causing the plaintiff to fear for her safety. d. In or around January 1996, the defendant entered the plaintiff's residence uninvited and when the plaintiff found the defendant sitting in her living room and attempted to get him to leave, he pushed her, causing her to injure her back. The plaintiff telephoned the police and the defendant left her residence. e. There had been a history of abuse in the relationship and in October 1994, a Protection From Abuse Order was entered. 5. The plaintiff believes and therefore avers that she is 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 prohibited from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications, except for the limited purpose of facilitating custody arrangements. 7. The plaintiff desires that the defendant be enjoined from harassing and stalking the plaintiff, and from harassing the plaintiff'S ~elatives. 9. The plaintiff desires that the defendant be restrained from entering her place of employment. 10. The plaintiff desires that the defendant be enjoined from removing, damaging, destroying or selling any property owned solely by the plaintiff. B. BXCLU8IVB P08SBSSION 11. The home from which the plaintiff is asking the Court to exclude the defendant is owned in the names of CONNEE and MICHAEL HEMPT, but the defendant left this residence several year!l ago. C. ATTORNBY .BBS 12. The plaintiff asks that the defendant be ordered to pay reasonable attorney fees to Legal Services, Inc. WHEREFORE, pursuant to the provisions of the "Protection f'rom Abuse Act" of October 7, 1976, 23 P.S. S 6101 .!l.t 0Sl., 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 I" 1. Ordering the defendant to refrain from abusing the plaintiff or placing her in fear of abuse; 2. Ordering the defendant to refrain from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications, except to facilitate custody arrangements; 3. Ordering the defendant to refrain from harassing and stalking the plaintiff and from harassing the plaintiff'S relatives; 4. Prohibiting the defendant from entering the plaintiff'S place of employment; 5. prohibiting the defendant from r.emoving, damaging, destroying or selling property owned solely by the plaintiff; 6. Ordering the defendant to stay away from the plaintiff'S residence located at 3790 Mountainview Road, Mechanicsburg, Cumberland County, Pennsylvarlia, except for the purpose of transferring custody during which time the defendant will remain in his vehicle; 7. 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 yearl 1. ordering the defendant to refrain from abusing the plaintiff or placing her in fear of abuse. 2. Ordering the defendant to refrain from having any direct or indirect contact with the plaintiff including, but not limited to, telephone and written communications, except to facilitate custody arrangements. 3. Ordering the defendant to refrain from harassing and stalking the plaintiff and from harassing the plaintiff's relatives. 4. Prohibiting the defendant from entering the plaintiff's place of employment. 5. Prohibiting the defendant from removing, damaging, destroying or selling property owned solely by the plaintiff. 6. ordering the defendant to stay away from the plaintiff's residence located at 3790 Mountainview Road, Mechanicsburg, Cumberland county, Pennsylvania, except for the purpose of transferring custody during which times the defendant will remain in his vehicle. ! I [.! " l'ill ',I li['ll'lllt'; /1. I i ,j itl'l I' II ,'" 1:11;1,), 11': I,f! " , III ! 'I) . ii' ... ~ j! i I I ' '; 11i'11I 1'1 11/\1'\ 1\ \ \,'1.1.' Ii , , I'i , .;.! " , i I I , , 1[1 (' ! \. , i, II [, 'I , I " , , , , , , u I ;; " , , ; , I , I \ ., I Ijl , - , , .' , I Li \ ,Ii \, , II) .' I' , " , J;, ('IJl', ~ I I' 1 I I,' t ,I lil"11] I' ," ,.1)1,'11 \/,.. ;'. \','..,1 , It,;. II !;!I'II T II' -.,11 i,l 'I, 1\ ',Il' kl. " , " 1,li, !I 'I' I! ill. I',j' .' ;, ,,! I I, II f : 1,./ I I j i ~ i r'!: i '/" i: i , !" ," .,'II!'!I',!':I,I/.II!1 , ill)'!" ,II .. , .," )'1 i, ii,\I! 1'1' 111'_" I', ! ,I !ii,_1 " , t 11,1 1',1/ l'l, \i.I.l'il,: l' Ii I ~ L r .1'11 "(11\ /1, h 'IT '1 I'll !l, , ,I di'" 1 ,j" IIi' ,Iii.: j I. Ii. ,ii I I-i' H' , " ',I , I" 'jt, if I I: h,; I .'1, f, 1/;' ! ' t" ." t,I, V'i' ' ':;~b/ ,.#~' ,'l ,', ~';.-'.i:,;,;;.~:~~:.;U~ ~ ~~ !. I I' ,1-',' :., ,', ., ,j i Iii( '..1';1 ':1 .rl i; l" 'I',.' .t7/1I~~,,! '. ' ,.".1 :1 " !!:- I" ~ tf4 C~If,t...Q, fk...(.4.-,I~' , " .~ " !' ", ,I . . c, ;1 II " " !, , , I' I ~:; \, . v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4902 CIVIL TERM PROTECTION FROM ABUSE CONNEE LOUISE HEMPT, Plaintiff MICHAEL A. HEMPT, Defendant AND NOW, ~~I~ON ORDIR this~~ day of July, 1996, upon consideration of . the Consent Agreement of the parties and with no admission by the defendant as to the allegations of abuse made in the plaintiff's Petition for Protection, the following Order is entered: 1. The defendant, MICHAEL A, HEMPT, is enjoined from physically abusing the plaintiff, CONNEE LOUISE HEMPT, or from placing her in fear of abuse. 2. The defendant is enjoined from having any direct or indirect contact with the plaintiff (except by communications through their respective attorneys or parents), including, but not limited to, telephone and written communicatio~s with the plaintiff, except for the limited purpose of facilitating custody arrangements, discussing their children, or communicating in any way regarding their children. 3. The defendant is ordered to refrain from harassing and stalking the plaintiff and from harassing the plaintiff's relatives. 4. The defendant is prohibited from entering the plaintiff's place of employment. 5. The defendant is prohibited from removing, damaging, destroying or selling any property owned by the plaintiff. 6. The defendant is ordered to stay away from the plaintiff's residence located at 3790 Hountainview Road, Hechanicsburg, cumberland county, Pennsylvania, and from any residence the plaintiff may in the future establish for herself, except for the limited purpose of transferring custody during which times the defendant shall remain in his vehicle. 7. The Court costs and fees are waived. 8. This Order shall remain in effect until Merch 31, 1997, and can be extended beyond its original expiration date if the Court finds that the defendant has committed an act of abuse or has engaged in a pattern or practice that indicates risk of harm to the plaintiff on a continued basis. This Order shall be enforceable in the same manner as the Court's prior Temporary Protection Order entered in this case. 9. This Order may subject the defendant to: i) arrest under 23 Pa. C.S. 56113; ii) a private criminal complaint under 23 Pa. C.S. 56113.1; iii) a charge of indirect criminal contempt under 23 Pa. C.S. 56114, punishable by imprisonment up to six months and a fine of $100.00-$1,000.00; and iv) civil contempt under 23 Pa. C.S. 56114.1, Resumption of co-residence on the part of the plaintiff and defendant shall not nullify the provisions of the oourt order. 10. The Hampden Township Police Department shall be provided with a certified copy of this Order by the plaintiff's v. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO. 94-4902 CIVIL TERM CONNEE LOUISE HEMPT, Plaintiff MICHAEL A. HEMPT, Defendant PROTECTION FROM ABUSE CONSBNT AGRBBMBNT ,~,~ This Agreement is entered on this ~~ day of July, 1996, by the plaintiff, CONNEE LOUISE HEMPT, and the defendant, MICHAEL A. HEMPT. The plaintiff is represented by Joan Carey of LEGAL SERVICES, INC,; the defendant is represented by Samuel L. Andes, Attorney-at-Law. The parties agree that the following may be entered as an Order of Court. 1. The defendant, MICHAEL A. HEMPT, agreeo to refrain from abusing the plaintiff, CONNEE LOUISE HEMPT, or from placing her in fear of abuse. 2. The defendant is enjoined from having any direct or indirect contact with the plaintiff (except by communications through their respective attorneys or parents), including, but not limited to, telephone and written communications with the plaintiff, except for the limited purpose of facilitating custody arrangements, discussing their children, or communicating in any way regarding their children. 3. The defendant agrees not to harass and stalk the plaintiff and harass the plaintiff's relatives. 4. The defendant agrees not to enter the plaintiff's place of employment. 5. The defendant agrees not to remove, damage, destroy, or sell any property owned by the plaintiff, 6. The defenJant agrees to stay away from the plaintiff's residence located at 3790 Mountainview Road, Mechanicsburg, Cumberland County, Pennsylvania, and any residence the plaintiff may in the future establish for herself, except for the limited purpose of transferring custody during which times the defendant shall remain in his vehicle. 7. The defendant, although entering into this Agreement, does not admit the allegations made in the Petition. 8. The defendant understands that the protection Order entered in this matter will be in effect until March 31, 1997, and can be extended beyond its original expiration date if the Court finds that the defendant has committed an act of abuse or has engaged in a pattern or practice that indicates risk of harm to the plaintiff on a continued basis. The defendant understands that this Order will be enforceable in the same manner as the Court's prior Temporary Protection Order entered in this case. 9. Violation of the Protection Order may subject the defendant to: i) arrest under 23 Pa. e.s. 56113; ii) a private criminal complaint under 23 Pa, e.s. 56113.1; iii) a charge of indirect criminal contempt under 23 Pa, e.s. 56114, punishable by imprisonment up to six months and a fine of $100.00-$1,000.00; . '"I;, ~ 1: :;\1 ){i'I-1 :~ijl f," 'Ii",d,- ; ".'1 ;/'f-.ll,i-:: ",,,:,r::,i' 1',",,11 ',i' -I,:' "/"'!'., I,' , , , " 'I, '.' \. I." , " "",', , " , , ,,' i-~ I,i!, " "'- ", I,! I,' , ,I, " :.1 ',i,. !t( '1';' " ,I. 1/ II. " ,.,.1 ",:.1' , " " , I , .' \ '. .'" ,~ 1 ~"..t f i' , , " ..1 ';':, "'.;1. " " , , ", " I \ .':/-, "'~"'_''''-'''H\'-;-''''C''~''': u,._......._.......'-.. "",0-, .,-;~...,. ", I.'" , " " "p: -, ., ','_"_ , . t .. , "1 .. 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