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J(.\THY JO WRIGHT
Plaintiff
for herself and on behalf
of her minor ohildren:
TRAVIS STINE
JENNIFER STINE
.
.
IN THE COURT OF COMMON PLEAS OP
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
V.
JAMES DAVID STINE
Defendant
NO. 94-6113 CIVIL TBRH
ORDER OF COURT
'l.d:l
AND NOW, this 0.7 day of October, 1995, upon
consideration of the attached Petition, it is hereby directed
that an expedited hearing shall be scheduled so as to consider
the issue of an extension of the Order of Protection from Abuse
issued October 28, l. 994. The Order of Protection fro: Abuse
issued October 28, 1994 shall be extended until the he~ing in
thi~S atter. This hearing shall be held on the ~ day
of _ , 1995 at "7;30 e." in Courtroom Nulllber
.
IT IS SO ORDERED.
J.
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OCT 2
8 l~ ,\H '95
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KATHY JO WRIGHT,
Plaintiff
for herself and on behalf
of her minor children:
TRAVIS STINE
JENNIFER STINE
IN THE COURT OF COMMON PLEAS OF
: CUMBERLAND COUNTY, PENNSYLVANIA
: CIVIL ACTION - LAW
.
.
V.
.
.
.
.
JAMES DAVID STINE,
Defendant
: NO. 94-6113 CIVIL TERM
PETITION TO EXTEND ORDER
FOR PROTECTION FROM ABUSE
AND NOW comes Plaintiff, Kathy Jo Wright, by and through her
attorney, Gregory J. Katshir, Esqui.re, with the following
Petition to Extend Order for Protection from Abuse and avers as
follows:
1. This matter involves a Protection from Abuse matter
between the parties.
2. On October 28, 1994, this Honorable Court issued an Order
for Protection from Abuse. The Order expires on October 28,
1995.
3. Pursuant to the Order, Defendant is prohibited from
abusing, threatening to abuse, stalking Plaintiff or the minor
children or from having any contact with Plaintiff.
4. The Order also provided that Plaintiff shall have primary
physical custody of the minor children with periods of visitation
with Defendant. No other Order of Court exist with respect to
the custody of the minor children.
5. Throughout the past year, Defendant has repeatedly
telephoned the residence of Plaintiff and the residence of
Plaintiff'. mother. Plaintiff has discontinued her telephone
service due to the frequent calls from Defendant. Defendant
continues to telephone the residence of Plaintiff's mother.
6. Throughout the past year, Defendant has repeatedly
telephoned Plaintiff at her place of business. The telephone
calls to Plaintiff's place of bu.sines. were of a harassing and
soaetiaes threatening nature.
7. Additionally, at the conclusion of a support conference
in May, 1995, D.fendant threatened to kill Plaintiff if anything
were to happen to the parties minor children.
The above na.ed Plaintiff, Kathr J. Wriqht, verifies that
the state..nts .ade in the above Pet tion are true and correct.
Plaintiff understands that falsQ state.ents herein .ade are
subject to the penalties of 18 Pa. C.S. Section 4904, relatinq to
unsworn falsification to authorities.
Date' I'J - ..f1.;:j 9Y
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KATHY JO WRIGHT,
Plainti ff
for herself and on behalf
of her minor children:
TRAVIS STINE
JENNIFER STINE
V.
JAMES DAVID STINE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
.'
CIVIL ACTION - LAW
NO. 94-6113 CIVIL TERM
IN RE: PROTECTION FROM ABUSE
ORD.ERQLCJlURI
AND NOW, this 28th day of October, 1994, this matter
having been called on a petition of Kathy Jo Wright,
individually and on behalf of Travis Stine, born January 26,
1979, and Jennifer Stine, born June 5, 1980, seeking a
protection from abuse order against James David Stine, and
without admission by defendant, the parties having reached
agreement to resolve the issues that are before the Court this
date, IT I S ORDERED THAT:
1. Defendant is prohibited and restrained from
abusing, threatening to abuse, or stalking plaintiff or the
minor children.
2. Defendant sholl have no contact with plaintiff and
is prohibited from going to or in any separate residence in
which she may live, including her current residence at 130 Eost
Creek Read, Newburg.
3. Defendant shall reimburse plaintiff for any
medical expenses not covered by insurance or lost wages
resulting from the incident that gave rise to this complaint.
4. Defendant shall not have any firearms in his
possession or under his control.
5 At this time the mother shall have primary
physical cus tody of TrrJVis arlcl Jennifer. W~lf!n defendant is
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released from prison, he shall have such periods of temporary
phYSical custody of the children to which the parties may agree,
or if they are unable to agree, which shall be determined
through custOdy litigation. Any periOds of temporary phYSical
custOdy of the children to which the parties may agree sholl be
set with arrangements where:'y the children con be picked un and
delivered without defendant having any contact with the
plainti ff.
one year.
6. This order shall remain in effe for a period of.
Philip C. Briganti, EsqUire
For Plaint! ff
Frederick I. Huganir, ESqUire
For Defendant
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ICATHY JO WRIGHT
Plaintiff
IN THE COURT OF COMMON PLJIAS
OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL ACTION - LAW
)
)
)
)
)
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)
)
NO
IN DIVORCE
CIVIL 1994
va.
JAMBS DAVID STINE
Defendant
IN RE: Baergency petition for special Relief in the Fo~ of an
Injunction
SPECIAL RELIEF HEARING ORDER OF COURT
tJ.,
AND NOW, this L~ day of November, 1994, upon
conaideration of the attached Emergency Petition, it is hereby
directed that an expedited hearing shall be scheduled so as to
~n.ider the iSBue of an injunction prOhibiting Defendant fro.
, withdrawing any aonies from hi~~~ThiS hearinJ .hall be
hald on the --:30-u.. dab/f . 1994 at ;30 e.N
h..J.1I1 ~..- "^"",....._kLa .-L~" u..t~~~. ..:;CL.
IT IS SO ORDERED.
J.
<<~
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NovJ 5
2, 56 PH .,.,
'I IJFFIC!
OF 111', t',,'rHON?TA~"
C'U"'liENlANti r.nUHH
, pr;NN~l', I'AN'A
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vs.
) IN THE COURT OF COMMON PLEAS OF
)
) CUMBERLAND COUNTY, PENNSYLVANIA
)
) NO. 94-6113 CIVIL TERM
)
) EMERGENCY PETITION FOR SPECIAL
) RELIEF IN THE FORM OF AN
) INJUNCTION
KATHY JO WRIGHT,
Plaintiff
JAMES DAVID STINE
Defendant
EMERGENCY PETITION FOR SPECIAL RELIEF
IN THE FORM OF AN INJUNCTION
AND NOW, comes Plaintiff, Kathy Jo Wright, by and through
her attorney, Gregory J. Katshir, Esquire, with the following
Emergency Petition for Special Relief in the Form of an
Injunction, requesting relief from this Honorable Court as
follows:
1. This matter involves a divorce and equitable distribution
existing between the parties.
2. Defendant is the common law husband of Plaintiff.
3. The parties, who have lived together as husband and wife
since 1979, 8eparated in August, 1994.
4. During the marriage, Defendant worked at Shippel\sburg
State University as a custodian.
5. As an employee at Shippensburg state University,
Defendant participated in the pension plan, offered through his
..ployer, since the commencement of his employment. Defendant
participated in the pension plan during the marriage and the
value of the pension accrued during the marriage.
6. The exact value of Defendant's pension is unknown
however, it is believed by Plaintiff to be approximately
$30,000.00.
7. A portion, or all of, Defendants pension may be marital
property subject to equitable distribution.
8. The Defendant's pension is the only asset of value in the
IIUlrital estate.
,
9. Plaintiff believes and avers that Defendant is attempting
to, and will, withdraw the .ntire value of his pension from hi.
pension plan to pay attorney fee.. Plaintiff also believe. that
Defendant will deplete the marital asset to avoid equitable
distribution.
10. D.f.ndant has mad. stat.m.nts to the .ffect that h. will
.tte.pt to withdraw his p.nsion. Plaintiff beli.ves that
Defend.nt .ay attempt to withdraw funds to pay for attorney's
fees for a pending cri.inal matt.r.
11. If D.f.ndant withdraws his p.nsion and sp.nds the .oney
or otherwise dispos.s of it, h. will d.pl.t. the .ntir. value of
the marital .stat..
12. Plaintiff will be irr.parabl. harm.d if D.f.ndant is
perwitt.d to withdraw funds fro. his p.nsion.
13. Du. to the urg.ncy of this matt.r and the limit.d ti..
within which to act, Plaintiff was unable to obt.in any specific
information r.garding the D.f.ndant's p.nsion such as valu., type
of plan or plan custodian's nam..
14. It would be appropriat., bas.d upon applicable
PennsYlvania law, specifically 23 Pa. C.S.A. S.ction 3505(.), to
issu. .n injunction prohibiting Def.ndant from withdr.wing, or
.tt..pting to withdraw, his p.nsion, in ord.r to prev.nt the
depletion or disposition of a m.rital ass.t until furth.r
.gr....nt of Ord.r of Court.
1~. Your Pl.intiff r.qu.sts that this Honorabl. Court
sch.dul. an .xpedit.d h.aring to consid.r the issuanc. of .n
injunction to prohibit Def.ndant from withdrawing his p.nsion or
.ny portion th.reof and/or grant such r.li.f as may be d....d
.ppropriate in light of the circumstanc.. of this matt.r.
WHEREFORE, Plaintiff r.qu.sts that appropri.t. r.li.f be
grant.d.
R.spectfully submitt.d,
9
J. Xatshir, Esquir.
for Plaintiff
.
.
The above na.ed Plaintiff, ~athr J. Wriqht, verifie. that
the .tate..nt. aade in the above Pet tion are true and oorreot.
Plaintiff under.tand. that fal.e .tate.ent. herein .ade are
.ubjact to the panaltie. of 18 Pa. C.S. Seotion 4904, relatinv to
unaworn fal.ifioation to authoritie..
Date I
II-If. 9~
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NOY 15 .. cJ.t,
KATHY JO WRIGHT,
plaintiff
tor her.elf and on behalf
of her minor children:
TRAVIS STINE
JENNIFER STINE
v..
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 - ~3 CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
JAMES DAVID STINE,
Defendant
TEMPORARY PROTECTIVE ORDER
AND NOW, this ~ day of October, 1994, upon pre.entation
and consideration of the within petition, and upon finding that
the plaintiff, KATHY JO WRIGHT, and her children, now residing at
61 East Creek Road, Newbur.g, Cumberland county, pennsylvania, are
in immediate and present danger of abuse from the defendant,
JAMES DAVID STINE, the following Temporary Order is entered.
The defendant, JAMES DAVID STINE, currently incarcerated in
the Cumberland county prison, cumberland County, pennsylvania, is
heroby enjoined from physically abusing the plaintiff, KATHY JO
WRIGHT, or her children, and from placing them in fear of abuse
and i. ordered to stay away from the residence located at 641
East Creek Road, Newburg, Cumberland County, Pennsylvania, a
re.idence which is owned by the plaintiff's parents. The
defendant i. 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
fro. abusing the plaintiff.
Temporary custody of TRAVIS and JENNIFER STINE is hereby
awarded to the plaintiff, KATHY JO WRIGHT.
The defendant is ordered to relinquish to the sheriff's
depart.ent the following weapons which he has used or threatened
to use against the plaintiff: 3 shotguns which are at the
defendant's grandparents located at 808 Molly pitcher Highway,
Shippensburg, pennsylvania.
The defendant is ordered to refrain fro. 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 :J~o.. day of OQ.~ , 1994, at 1..fi (.1..... in
Courtroom NO.~, Cumberland county Courthouse, carlisle,
pennsyJ.vania.
The plaintiff may proceed in forma pauDeris pending a
further order after the hearing.
The Cumberland County Sheriff's office shall attempt to .ake
service at the plaintiff'S request, but service may be
accomplished under any applicable rule of Civil prQcedure.
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 defendant by
KATHY JO WRIGHT,
Plaintiff
for herself and on behalf
of her minor children:
TRAVIS STINE
JENNIFER STINE
ve.
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 - vII 3 CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
JAMES DAVID STINE,
Defendant
1l0TICE
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 eet forth against you. You are warned that if you
fall 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 I,EGAL HELP.
COURT ADMINISTRATOR, 4th FLOOR
CUMBERLAND COUNTY COURTHOUSE
CARLISLE, PENNSYLVANIA 17013
TELEPHONE NUMBER: (717) 240-6200
KATHY JO WRIGHT,
plaintiff
tor her.elt and on behalf
ot her minor children:
TRAVIS STINE
JENNIFER STINE
v..
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 - (Q 113 CIVIL TERM
PROTECTION FROM ABUSE
AND CUSTODY
JAMES DAVID STINE,
Detendant
PETITION FOR PROTECTIVE ORDER
AND CUSTODY
~ELIEF UNDER THE PROTECTION FROM ABUSE ACT
23 P.S. SECTION 6191
A. ABUSE
1. The plaintiff is an adult individual who.e permanent
addre.. i. P.O. Box 225, Newburg, Cumberland County,
penn.ylvania, 17240. The plaintiff brings this action for
herself and on behalf of her minor children.
2. The defendant is an adult individual currently
incarcerated in the Cumberland County Prison, Carli.le,
Cumberland County, Pennsylvania, 17013.
3. The defendant is the plaintiff's common law husband.
4. Since approximately August 1994, the defendant has
attempted to cause and has intentionally, knowingly, or
reckle..ly cau.ed bodily injury to the plaintiff, and threatened
her children, and by physical menace ha. placed the plaintiff and
her children in fear of imminent serious bodily injury. This has
included but is not limited to the following specific instance.
of abu.e:
a. On or about October 15, 1994, the defendant repeatedly
called the plaintiff on the telephone, asking her to come over to
the home and talk, but the plaintiff refused. Later, the
plaintiff's son called the plaintiff asking her to come OVer and
piok him up to take him somewhere. When the plaintiff arrived,
the defendant came to the door and asked the plaintiff to oome
inside. Once inside, wh~n the plaintiff went to leave, the
defendant forced the plaintiff away from the door with his body,
grabbed her by the throat, and dragged her to the bedroom. The
defendant thftn pushed the plaintiff onto the bed, straddled her,
and slapped her about the head approximately three times, causing
bruising, loss of hearing, and a headache. The defendant then
told the plaintiff that this was her day to die, reached into the
oloset, and pulled out a sawed off shotgun. While holding it,
the defendant showed the plaintiff that the shotgun was loaded,
cocked it, and press~d it to the side of the plaintiff'S head,
threatening to blow her head off. The defendant then placed the
gun under the plaintiff'S chin and repeated several times that he
was going to kill her. The defendant put the gun down and while
holding the plaintiff by the throat, punched her with his fist in
the mouth and face several timeo, causing bleeding to the lip and
nose, swelling, and bruising. When the plaintiff tasted the
blood and told the defendant that ohe was going to be sick, the
defendant told the plaintiff to throw up on the floor, and that
it didn't matter because her brains were going to be scattered
everywhere. The defendant went into the bathroom to get a cloth.
In an attempt to escape, the plaintiff tried to push the
defendant into the bathtub. The defendant grabbed the
plaintiff's shirt and ehoved her toward the bedroom. The
plaintiff and defendant etruggled and while etill holding onto
her shirt, the defendant punched her repeatedly about the head
and arm. The plaintiff grabbed the shotgun from the defendant's
pante, turned her back, and tired it at the floor. Having heard
the shot, the defendant's sister-in-law entered the trailer and
the plaintiff told her to take the gun. The defendant's father
entered, and a scuffle ensue~ between the defendant and his
father. The plaintiff ran trom the trailer, got into the car
with her two children, and drove to the police station. The
plaintiff was then seen and treated at the Chambersburg Hospital
nmergency Roo.. The detendant was arrested and is in the
Cumberland county Prison on $50,000 bail. Also on this date, the
defendant contacted the plaintiff's triend before the incident
and told the friend that if the plaintitf wasn't going to be with
him, she wouldn't be with the friend either. The defendant al.o
told hi. unr.le that he was going to kill her, the children, and
her parents if they got involved. The defendant has threatened
the plaintiff .everal times with this threat.
b. In or around the beginning ot August 1994, the defendant
w.nt through Mechaniceburg, knocking on doors, trying to find the
plaintiff and her friend. A phone call warned the plaintiff that
the defendant was looking for her. The plaintiff went out the
beck door and into the parking lot to her car, only to find that
the defendant had parked his truck in back ot her car, preventing
her trom leaving. The defendant approached the plaintift,
intoraed her that she was goinq with him, grabbed her by the
hair, and threw her into the front seat of his truck. The
detendant told the plaintiff that he had a gun, cau.inq the
plaintiff to fear for her safety. The defendant then demanded
that the plaintiff tell him which apartment wae her friend's
apartment. The defendant then went to the friend'. apartment and
started an argument. The police arrived and made the defendant
leave. The plaintiff suffered a headache from this incident.
5. The plaintiff believes and therefore aver. that she and
her children will be in immediate and present danger of abuse
from the defendant, and that she and her children are 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 relative..
B. TEMPORARY CVSTOQ,l
7. The plaintiff .eeks temporary custody of the following
children:
H.lUIul
pre.ent Residence
6SH
TRAVIS STINE
P.O. Box 225
Newburg, PA
15 yrs.
JENNIFER STINE
same addre.s
14 yrs.
The children were not born out of wedlock.
The children are pre.ently in the cu.tody of KATHY JO WRIGHT
who r..ide. at P.O. Box 225, Newburg, Penn.ylvania.
During the p..t five y..r., the childr.n have r..id.d with
the following p.r.ons .nd .t the following .ddr.....:
HIU Addr..... Dat..
pl.intiff . d.f.nd.nt Strohm Ro.d 1989 - 8/94
Shipp.n.burq, PA
plaintiff with Newburq, PA 8/94 - 10/15/94
J.nnif.r
d.f.nd.nt with Strohm Road 8/94 - 10/15/94
Travi. Shipp.n.burq, PA
plaintiff with Newburq, PA 10/15/94 - pr...nt
both children
Th. mother ot the children i8 KATHY JO WRIGHT, curr.ntly
r..iding .t 641 Ea8t Creek Road, Newburq, Penn8ylv.ni..
She 18 married.
Th. f.th.r of the children i8 JAMES DAVID STINE, curr.ntly
incarcerat.d in the Cumberland county pri.on.
Th. plaintift currently re.ide. with the following person.:
liAIIlI.
JENNIFER STINE
TRAVIS STINE
CURVEY DUNCAN
ICENNETH DUNCAN
Relation.hiD
dauqhter
.on
mother
father
8. The plaintiff ha. not pr.viou.ly particip.t.d in .ny
litiqation concerning cu.tody of the above-mentioned children in
thi. or .ny other Court.
9. The plaintift has no knowledge of .ny cu.tody
proce.ding~ concerning the.e children pending before a court in
thi. or any oth.r juri.diction.
10. The pl.intiff doe. not know ot any per.on not a p.rty
to this action who has physical custody ot the childr.n or claims
to have custody or visitation rights with r.sp.ct to the
children.
11. Th. best inter.sts and p.rman.nt w.ltare ot the
children will b. met it custody is t.mporarily granted to the
pleintift pending a h.aring in this matt.r tor the tollowing
reasons:
a. Th. plaintitt i. a tit parent who can b.st take
care ot her children.
b. Th. d.t.ndant has .hown by hi. abu.e ot the
petition.r that he is not an appropriate role model tor the
children.
c. Th. detendant has d.mon.trat.d by his abuse ot the
childr.n that he is an untit par.nt.
C. EXCLUSIVE POSSESSION
12. Th. home trom which the plaintitt is aSking the Court
to exclude the detendant is owned in the name. ot CURVEY and
KENNETH DUNCAN, the plaintitt'. parents.
a......- LOSSES and ATTORNEY FEES
13. Th. plaintitf has suttered lo..e. as a r.sult of the
abuse by the d.tendant. The 10.... are listed on Exhibit A which
is attached and incorporated herein by reterenc..
14. The plaintift asks tor attorn.y tees be paid to Legal
S.rvic.s, Inc., pursuant to the prot.ction trom Abu.. Act.
E. STATUS TO PROCEED IN FORMA PAUPERIS
15. The defendant had been employed at Shippen.burg
univer.ity and the plaintiff i. unaware of hi. .alary.
16. The plaintiff currently i. employed at Fry
coaaunication. and receive. approximately $920.00 monthly.
17. The plaintiff doe. not have fund. available to pay the
fee. for filing and .ervice.
WHEREFORE, pur.uant to the provi.ion. of the "protection
fro. Abu.e Act" of October 7, 1976, 23 P.S. Section 6101 At 818.,
a. a.eJlded, the plaintiff pray. thil Honorable Court to grant the
following relief:
A. Grant a Temporary Order purluant to the "Protection from
Abu.e Act:"
1. Requiring the defendant to refrain from abu.ing the
plaintiff and her minor children or placing them in fear of
abu.e.
2. Requiring the defendant to refrain from having any
contact with the plaintiff, including, but not li.ited to,
entering the plaintiff'. place of employment, hara..ing or
.talking the plaintiff, and hara..ing the plaintiff'.
relative. or minor children.
3. Granting temporary cUltody of the minor children
to the plaintiff.
4. ordering the defendant to .tay away from the
re.ldence located at 641 Ealt Creek Road, Newburg.
penn.ylvania.
5. Ordering the defendant to .tay away from any
reeidence the plaintiff may in the future e.tabli.h for
her.elf.
6. ordering the defendant to relinqui.h to the
.heriff'. department the following weapon. which he ha. u.ed
or threatened to u.e against the plaintiff and her minor
children: 3 .hotgune currently located at the defendant'.
~randparent.' home at 808 Molly Pitcher Highway,
Shippen.burg, Pennsylvania.
B. Schedule a hearing in accordance with the provi.ions of
the "protection from Abu.e Act," and, after .uch hearing, enter
an order to be in effect for a period of one year:
1. Requiring the defendant to refrain from abu.ing the
plaintiff or her minor children or placing them in fear of
abu.e.
2. Requiring the defendant to refrain from having any
contact with the plaintiff, including, but not limited to,
entering the plaintiff'. place of employment, harassing or
.talking the plaintiff, and haraaaing the plaintiff's
relativea or minor children.
3. Ordering the defendant to atay away from the
re.id.nce located at 641 Eaat Creek Road, Newburg,
Pennsylvania.
4. Ordering the defendant to atay away from any
residence the plaintiff may in the future establi.h for
her.elf.
5. Ordering the defendant to relinquish to the
.heriff'. department the following weapon. which he has u.ed
or threatened to u.e again.t the plaintiff and her minor
children: 3 .hotguns currently located at the defendant'.
grandparent.' home at 808 Molly Pitcher Highway,
Shippeneburg, penn.ylvania.
6. Ordering the defendant to reimbur.e the plaintiff'.
out-of-pocket 10.... Buff.roed a. a result of the abu..
including but not limited to the 10.... li.ted on the
attach.d sheet marked Exhibit "A".
7. Ordering the def.ndant to pay attorn.y fe.s to
Legal S.rvices, Inc. pur.uant to the Protection From Abu.e
Act.
The plaintiff further asks that this Petition be filed and
served without paym.nt of co.ts, pending a further ord.r at the
h.aring, and that a copy of this Petition and Order be delivered
to the penn.ylvania State, Mid-Cumberland Valley Regional, and
Mechanic.burg Polic. Department. as the Police Departments with
juri.diction to enforce this Order.
The plaintiff pray. for .uch other r.li.f as may be ju.t and
proper.
COUNT II
CUSTODY UNDER PENNSYLVANIA CUSTODY LAW
18. The allegation. of Count I above are incorporated
herein a. if fully .et forth.
19. The be.t int.re.ts and permanent welfare of the
children will be .erved by confirming custody in the plaintiff a.
sst forth in Paragraph 11 of the Petition.
WHEREFORE, pursuant to 23 P.S. Section 530111 aag., and
other applicable rules and law, the plaintiff prays this
Honorable Court to award custody of the minor children to her.
The plaintiff prays tor such other relief as may be just and
proper.
Re.pectfully submitted,
~~" Ii~..~
Jo n Car V
Philip C. Briganti
Attorneys for Plaintiff
LE~AL SERVICES, INC.
a Irvine Row
Carlisle, PA 17013
(717) 243-9400
The above-nallMld Plaintiff. Kathy J. Wright, verifies that
the .tatement. made in the above Petition are true and correct.
Plaintiff underetand6 that fal.. etatellMlnts herein are made
subject to the penalties of 18 Pa. C.S. 14904, relating to
unsworn fal.ification to authoritie..
Date:
~-~/-91j
.
&1.1 ",1..t.~J.!.t
ICATHY JO WRIGHT,
plaint.1ff
for her.elf and on behelf
of her minor children:
TRAVIS STINE
JINNIPER STINE
v..
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IN THE COURT OF COMMON PLEAS OP
CUMBERLAND COUNTY, PENNSYLVANIA
NO. 94 -
CIVIL TERM
PROTEOTION FROM ABUSE
AND CUSTODY
JAMES DAVID STINE,
Defendant
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LOSSES
lDII
MEDICAL:
AMOUNT.
Any .edical expen.e. not covered
by in.urance
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SHERIFF'S DEPARTMENT
157 LINCOLN WAY EAST, CHAMBERSBURG, PENNSYLVANIA 17201 (717) 261.3877 cOIIputer
-,,---- . "" "". ". "SHERIFF SERVICE [IN~T~UCTlONSFO~S~;"ICE-;;;;;'ROCESS PIe... Iype or prllll
PROCESS RECEIPT, and AFFIDAVIT OF RETURN legibly Do not delach .ny caple.
I PlAINTIFFIS'-'-'" "" .. . "I:' coUii,'NliMBEfi- ..-..."
IAtlIy JO WlIGllT ~4-~1J'cj,yj,L~n1__",,_____
3.OEfENOAN,'iST'.' "" " ,4 IV"PE C,lF,W, fUTllRCO,MP,l,AINT
JAlmS DAVID STINIJ'1;'QcecUt,m t'!C!!II,,~\IU'Cu.t04y
SEAVE.--'"{-~b''~~E~;"l!~~~~'A;;~~~I';'''.AI''''''' i, '<1'.1 ".'11" '''lll'';IIl'PIIONOf "'''"'f,'''\' "'H',,," lJ '''AU''DO'-'~::~u_
. 6, AOOftESfi IStHwl or flFD, Ap.lrIlTlI'!ll Nfl Cdy HUI') rwp ~1l;11t' ilnd liP ClJ(lt~)
AT .___,,_,,8~~ .H/:)~L'l PITt:H,,!1. HIGHWAY. SHIPPENSBURG. PA . . ,,".n'__
7.INOICATEUNUSUAlSEfMCE i'1COMMONOfP^ I;DEYIJlI!1 II<lJIIIH . . ._.._..___".__
~,~=.:::.~..~_.~~.._.~.~ 19 , ' , I, SHEfllFF OF rnANKllN COUN T V, PA , do '",,,,hy dnpul'w nil' Sheri" 01
___~__~~,._ ___ .___._.__.. CUUflty Iu 1'l(I'C!lh! thiS Writ and make return thereof accordlllq
to law. This deputation being madu 111 Ih~: rCe ItH'~l drll j risk uf IIII! r:I;llflllff ._
..llPECW: INsmucTICIftiSOROTHERINFORMATIONTHATWlll ASSIST IN EXPEDlnNG SERVICE:
';IJJ.iillJ..<Jl!JiArih.J:ui!,"0jiJI_lt ~
'LIAS. SOV! A COpy or TIlE nUl ORDER ON DEJ!MDANTS GIWlDPAUNTS. DAVID AtlD ISTHE. STIli! AT
808 *>LLY PITCH!l HIGHWAY. SHIPPENSBURG. PA AND CONn.CATE THREE SHOTGnS. D!n1IDUT IS IIf
CUMlDLAIID COUIlT'f PilSON. HE WILL BE SI!RVED TIlERE.
NOTE ONLY APPlICABI E ON WRIT OF EXECUTION: N,B_ WAIVER OF WATCHMAN-Any r11-!pllly sht!r1l1 te,'vyuh) upon ut ,llLlChltlO dllY properly Imdflr
wilhln writ may leave same withoul ;1 W,llr;hl11,\ll, If I ,.11',1, 10 I'y 'If V,ll< ,Ill, ",' r I~i I, 1I1111! III 1)IJ:i'll'~iSlnf1, ;tlll!r 11(,111'11110 PI'tVJll (Jllt.!v f or ;Illilc.~rm.!nt_ WIthout
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e. SlClNA1\lIIE olllrTOAHEY or olh", ORIGINATOR , ~'I) III f PHONE NUMF.lFfl [, I DAfE.___,,_
12, SEND "'"onCE"OF se-RVICE-C'Opy TO NAME AND ADDRESS BflOW: tThi's area musl bO compfeted I' nohce is to be mailed)
LIGAL SKlVIC!S - SRIlI" R. THOMAS KLINE. Court HouRe Carlisle. PA 17013
-".. SiiCifBEI6W FOR USE OF SHERIFF ONLY ';";OONOTWfIlTE BELOW tHis&:.iNE'u-
~~acc;~~~~~~;~'i:~~~~') ." Sr.:rUR-~,(t" ~:o::LtI~'''J:3~;' T'ii;:-T; gJ~:~~fv~;:i ."'T; ;~/~;!i4:~~_:~
Ie. thereby CERTlFV and REtuAN Ihall1(hil ", p!'r~;')Il,rlll '" ,! vl'd CI hd...' , 10'<]01: ,'vldl~I1CP 01 sprW;e) .1~ ~;hOWllln '~lt!m..Irk'1' n h;lV~> U,lu-'Ctlll:',j ag shown
in "Rema,ks", the wril or r.;ornplilinl dl!'~,;rl t.~d 1m th., IIl<h..I,jII,J1 (< Imj'ilrlj, u ,rpul,dlUIl, pic. al ttw ,lIhlrt'~'j ~jhowll ol[)'")Vt! or UIl the Indlvu.luiJl, ctJmpan)l.
corporation, fllc_, al the address in~wrlt!d below hy 1100n, 1I11Hj d TRUE and ATTESTED COPY Ih~m'r,1
-----_._,_...-~. . -,-.
17, D!he~~J~~!!~f~__a,rKj return. ~ N~~..FO~NO 1",,:.1'1','" I .1111 (l'l,dil,' t<l 111',d"
18, Name and htle of individual Sf!fVellllf n'.11 ';h')Wrl ;It)'I'JI' I
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a3 ArIE~-'SI~~a[~~"IDe~~nt [' 0;~,J8M';~ 10;~ Int l oa,el MIle, lDeP Inl [ Dale [MII.',l Depint [ Oa'. jMI~.J~DiP.lnl.
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__ _ 18.00 2.00 9.20 .29.2.0. . "2.i.2ll..___.,,._
30. REMARKS
10/28 Left card. no on. h~..
10/28 DAVIn AND ESTHER STIrn: ADVISE nlAT THEY no NOT HAVE ANY Wl!APONS THAT InOMG TO
JAKES STINE. WF~ONS SHOULD STILL Br. AT DEfENDANTS RElID!NCE OR IN THI POSSISSIGI
or IIROTHE., KEN. IV KEN HAS THf:M. ADVISED TIlEM TO TURN OVI!R TO CU~U~JI."D1'"
16th so ANSWt:R.
'1',01"" "I
94 I." I'"."p
3' AffIRMED and subSCribed III bp'nrt' fill' nil',
34 day 01 .
NOVIMUR
l!-j
ROBERT .. MURlAY
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Of AUntORI1(l,!~'~!.J.I~~:~ AU r~I(HlLr_~~~.!r~_LI !~.E. _ ~
SHERIFF Of fRANKLIN COUNTY
['.'1 1111o'1.~~ ~"~'_'~~__.._._._,_,__
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An- T.M!I Ccurt Of C.:mmc:'l ?Ie:s Of C:.Jr.::'-:.:It'i:nd C.::u:-:~y, Pannsylvc::ni=
Kathy Jo Wright, for herself ~nd on behalf of her minor children: Travis Stine
and Jennifer Stine Vs.
Jame. David Stine
SERVE: David & Esther Stine
".1. ............__..........
~o.
94-6113 Civil Term
':1
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KATHY JO WRIGHT,
PLAINTIFF
V.
JAMES DAVID STINE,
DEFENDANT
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
94-8113 CIVIL TERM
~
AND NOW, thll 29th day of November, 1994, the Sheriff of Cumberlll'ld
County I. hereby ordered and directed to tranlport the abov.named detendll'lt from
the Cumberland County Prllon to the Cumberland County Courthoule for the civil
heerlng lCheduled for November 30, 1994, at 2:30 p.m., In Courtroom Number 2.
It I. further ordered that the Sheriff of Cumberland County Ihall return .
d.,.,c:lInt to the Cumberland County Prison following th
ng.
, J.
Gregory J. Katlhlr, Eequlre
For PIlintlff
JIm.. DavId Stine, Pro ..
SherIff of Cumberland County
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plaintiff
for herself and on behalf
of her ainor children:
TRAVIS STINE
JENNIfER STINE
: IN THE COURT or COMMON PLEAS or
CUMBERLAND COUNTY, PENNSYLVANIA
v.
94-6113 CIVIL TERM
CIVIL ACTION - LAW
PROTECTION FROM ABUSE
JAMES DAVID STINE,
Defendant
IN RE: PETITION TO EXTEND PROTECTION FROM ABUSE ORDER
ORDER OF COURT
AND NOW, this 6th day of November, 1995,
following a hearing on the merits, the within Petition To Extend
protection from Abuse order entered on October 28, 1995,
IS GRANTED. The order is extended through October 27, 1996.
Kathy Jo wright, mother, is granted primary
physical custody of Travis stine and Jennifer stine. The
father, James David stine, shall have temporary physical custody
as the parents shall agree.
By the cou~,
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Gregory J. ~atshir, Esquire n.1
for the plaintiff . ~
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JerryA. Weigl., Esquire 1I11~14f'-
for the Defendant
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