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$1.000.00 and/or by a Bentence of up to six months In Jail and any other
appropriate punlBhllent. Resumpt Ion of co-res idence on the part of the plaint i ff
and defendant shall not nullify the provisions of the court order directing the
defendant to refrain from abusing the plaintiff,
case.
This Order Bhall reuin in effect unt II a final order Is entered In this
,1 f1<.-.
held on this utter on the 7 day of November,
In Courtroom NO._...3. CU..berland County Courthouse.
A hearlna shall be
t/~'lJ J.t',....
I
1994, at
Carlisle. Pennsylvania.
The plaintiff ..ay proceed 10 ~ PBUPeris pending a further order after
the hearing,
The Cumberland County Sheriff's Department shall attempt to .ake service
at the plaintiff's request. 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
~his Order to the defendant by mai I.
The Carlisle and Middlesex Township Police Departments will be provided
with certified copies of this Order by the plaintiff's attorney. This Order
shall be enforced by any law enforcement agency where a violat ion 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 aade 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 befors the appropriate district justice. (23 P.S. I 6113).
By the Court.
Judae
I
CANDY A. TAYLOR,
IN 1liE COURT OF (nM)N PLEAS OF
Plaint! rr
v.
ClMlF.RLAND COUNTY, PENNSYLVANIA
NO. 94- ~.1~3 CIVIL TERN
KIM S. TAYLOR,
DefendMt
PR<YI'ECTION FROM ABUSE
NOTICE
You have been sued in court. If you wish to defend against the clalas set
forth in the following pages, you .ust take action pro.ptly after this Petition,
Order and Not ice are served, by appearing personally or by sttorney at the
hear Ing scheduled by the Court and present ing to the Court your defenses or
objections to the claims set forth against you. You are wa:ned that If you fail
to do so the Court may proceed wi thout you. and Ii judgJlent MY be entered aaainst
you by the Court without further notice for any ~ney clai~d in the Petition or
for any other claim or relief requested by the plaintiff. You asy lose DOney or
property or other rights i.portant to you.
roo llIIlULD TAKE nlIs PAPP.R TO YOUR LAWYER AT <JolC2. IP roo DO tI1I' HAW A
LAWYER OR CNN7I' AFF'ORD <WE, 00 TO OR 'I'F.LP.I'IDft! 11lB OFFICI! SBI' IQl11I ~ TO
PIND our lIHERE roo CAN C.EJ' LHIAL HELP.
COURT ABlINISTRATOR. 4th fLOOR
CUMBERLAND COlMI'Y COl1R11lOOSE
CARLISLE. PENNSYI,vANIA 170lJ
TELEPHONE NUMBER: ( 717) 240-6200
CANDY A. TAYLOR.
IN THE COURT OF C(MoIQN PLEAS OF
Plaintiff
v.
CUMBERl,AND COUNl'Y. PENNSYLVANIA
NO. 94- ~.:l.:l3 CIVIL TERM
KIM S. TAYLOR.
Defendant
PROTECTION FROM ABUSE
PBTITICW FOIl PROI'ECTICW 0l!ID
RELIEF tIII>ER THE PROI'ECTI<If I'IQI ABUSE
ACT. 23 P.S. I 6101 et seq.
A. AIllJS~
1. The plaintiff Is an adult Individual whose permanent address Is 174
East High Street. Carlisle, CU.berland County, Pennsylvania, 17013.
2. The defendant is an adult Individual residing at 610 Conodoguinet
Avenue. Carlisle, CUmberland County. Pennsylvania, 17013.
3. The defendant is the former husband of the plaintiff and the father
of the part ies' two children.
4. Since approximately 1986, 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 plaint iff in fear of illlDinent serious
bodily injury. This has included but is not limited to the following specific
instances of abuse:
a, On or about October 14, 1994, the defendant entered the
plaintiff's home without knocking. demanded to talk to her. refused
to leave when she asked him to. and lunged toward the plaintiff when
she tried to back away from him, The plaintiff pleaded with the
defendant to leave her alone saying she would call the police. When
she picked up the telephone, the defendant knocked the telephone out
of her hand and threatened her saying, "If you call the cops your
head's COMing orr," The defendant went outside and the plaintiff
locked the door behind hi.. He becue enrqed, punched his fist
through the screen door and window causing the window to break. The
plaintiff telephoned the Carlisle Police who charged the defendant
with crl.inal .ischief and sUlllll8ry harassllent. A prell.inary
hearing will be held before District Justice Correal on Dece.ber 8,
1994, at 2:00 p...
b. In or about late SepteMber, 1994, the defendant telephoned the
plaintiff's hoIIe at approxiutely 1:00 a... and threatened her
saying, "I better not find the two of you or I'. gonna kill you."
The plaintiff, fearing for her life, telephoned the Carlisle Police
Departllent and asked theM to watch her hoIIe.
c. In or about July, 1994, the defendant, who has been divorced
frOM the plaintiff since September. 1991, made various threats on
the plaintiff's life including: telling her he would kill her, her
boyfriend; and saying if he couldn't have her, nobody would.
d. In or about June. 1994, the defendant threatened to har. the
plaintiff and kill her.
e. In or about 1990. the defendant choked the plaintiff causing
her to fear for her life. The plaint i ff sustained red I18rks and
bruises about her neck.
f. Since apprOXimately 1986. the defendant abused the plaintiff
in ways including. but not limited to intiMidating her by punching
holes In walls. breaking household iteMS, throwing lit cigarettes
and hitting her with theM causing burns, physically restraining her
with one hand while threatening her with his fist drawn back to hit
her. restraining her by cornering her or blocking doorways with his
body, choking her, and threatening her life.
~. The plaintiff believes and therefore avers that she is In i.-edlate
and present danger of abuse froll the defendant and that she Is in need of
protection fro. such abuse.
6. The plaintiff desires that the defendant be prohibited froe having
any direct or indirect contact with the plaintiff including, but not II.ited to,
telephone and written communications, except for the li.ited purpose of
facilitating custody arrangements.
7. The plaintiff desires that the defendant be enjoined frOll harassing
snd stalking the plaintiff, and from harassing the plaintiff's f..ily.
8. The plaintiff desires that the defendant be restrained froecntering
her place of employment or the schools of the minor children.
B. EXCLUSIVE POSSESSION
9. The home from which the plaintiff is asking the Court to exclude the
defendant Is :rented In the name of the plaintiff, Candy A. Taylor, and she is not
seeking the eviction of the defendant from hiS residence.
C. SUPPORT
10. The defendant has a duty to support the minor children.
II. The defendant Is employed at Giant Food and Atwood COnstruction, and
has annual salary of approximately $20,000.
12. The plaintiff's Income Is Insufficient to provide for her .lni..1
needs and those of the chi Idren unt i 1 such t ille as a support order can be
obtained by filing at the Domestic Relations Office.
13. The plaint Iff intends to pet It ion for support within two weeks of the Issuance of a protective order.
IlLJDnHLm,~ IN _lORMO\ PAllIDIS
14. The plaint iff works at Dally ~;xpress, and earns a salary of
approxi..tely $16,900.
IS. The plaint I ff does not hAve funds available to pay the fees for
filins and service of this lawsuit,
'MiEREFORE, pursuant to the provisions of the "Protect ion froa Abuse Act"
of October 7, 1976, 23 P.S. 8 6101 ~. ~., as amended, the plaintiff prays this
Honorable Court to grant the following relief:
A. Grant a Temporary Order pursuant to the "Protect ion froe Abuae
Act:"
1. Ordering the defendant to refrain froe abusing the
plaintiff and/or placing her in fear of abuse;
2. Ordering the defendant to refrain frOll having any direct
or indirect contact with the plaintiff includina, but not
limited to, telephone and written co..unications, except to
facilitate custody arrangements;
3. Ordering the defendant to refrain fro. harassing and
stalking the plaintiff and from harassing the plaintiff's
fuily;
4. Prohibiting the defendant froe entering the plaintiff's
place of employment and the schools of the minor children;
S. Ordering the defendant to stay away froe the plaintiff's
residence located at 174 East IIigh Street, Carlisle,
Cuaberland County, Pennsylvania, and
6. Ordering the defendant to stay away froe 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:
I. Ordering the defendant to refrain frOll abusing the
plaintiff and/or placing her In fear of abuse.
2. Ordering the defendant to refrain frOll having any direct
or indirect contact with the plaintiff including, but not
limited to, telephone and written cOlIIDunlcations, except to
facilitate custody arrangements.
3. Ordering the defendant to refrain frolll harassing and
stalking the plaintiff and frOll harassing the plaintiff's
family.
4. Prohibiting the defendant from entering the plaintiff's
place of employment and the schools of the minor children.
5. Ordering the defendant to stay away frOll the plaint Iff's
residence located at 174 East High Street, Carlisle,
CUlllberland County, Pennsylvania.
6. Ordering the defendant to stay away from any residence
the plaintiff may in the future establish for herself.
7. Grant ing support to the plaint iff for the minor children
In the amount of $75,00 per week payable to the plaintiff In
the form of a check or IIIOney order, l18i led to her residence.
8. Ordering the defendant to pay all costs of filing and
service of this lawsu i t and attorney's fees to Legal Services,
Inc.
The plaintiff further asks that this Petition be filed and served without
paYlll'nt of costs, pending a further order at the hearing, and that certified
copies of this Petition and Order be delivered to the carlisle snd Middlesex
Township Police Departments who have jurisdiction to enforce this Order.
The plaintiff prays for such other relief as may be just and proper.
Respectfully submitted,
Plaint I
L8lAL SERVICIlS, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
The abovs-~d plaintiff. candy A, Taylor, verifies that the state..nts
ude in the above Petition are true and correct. The plaintiff understands that
'alse state..nts herein are aade subject to the penalties of 18 Pa. C.S. 14904
relatina to unsworn falsification to suthoritie8.
Dete:
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CANDY A. TAYLOR.
IN TIlE COURT OF CQtoN)N PI.EAS OF
CUMBERl,AND COUNTY, PENNSYLVANIA
NO, 94-6223 CIVIl. TERN
Plaint Iff
v.
KIN S, TAYLOR,
Defendant PROTECTION t~ON ABUSE
_ A. ~ PIlOI'I!CI'I~ ORDER
this~day of November. 1994, upon consideration of the
AND NOW.
Consent Agreement of the parties. the following Order Is entered:
1. The defendant, Kim S. Scott. Is enjoined frail physically abusing the
plaintiff. Candy S. Taylor, and/or frail placing her in fear of abuse.
2. The defendant Is enjoined froll having any direct or indirect contact
with the plaintiff including, but not limited to, telephone and written
cOllllunlcatlons, except for the limited purpose of facilitating custody
arrangellents.
3. The defendant is prohibited from entering the plaintiff's place of
employment, or the schools of the children or the day care facility of the .Inor
chi ldren.
4, The defendant is ordered to refrain from harassing and stalking the
plaintiff and from harassing the plaintiff's fallily.
5. The defendant is ordered to stay away from the plaintiff's residence
located at 174 East High Street, Carlisle. CUlllberland County, Pennsylvania,
except for the limited purpose of transferring custody during which times the
defendant shall remain In his vehicle.
6. The defendant is ordered to stay away from any residence the
plaintiff may In the future establish for herself.
"
7. The defendant is ordered to pay Interim support to the plaintiff for
the parties' minor children In the amount of $25.00 per week payable to the
plaintiff In the form of a check or money order by mall pending the entry of an
order by the CUmberland County Domestic Relations Office.
8. This Order shall remain I~ effect for a period of one year.
9. The carlisle and Middlesex Township Pol ice Departments shall be
provided with certified copies of this Order by the plaintiff's attorney 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 presence of the police officer. In the event that an arrest
Is lade 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 P.S.
B 6113).
Judge
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7. The defendant agrees to pay Interim support to the plaintiff for the
parties' .inor children in the amount of $25.00 per week payable to the plaintiff
In the forE of a check or money order by mail pending the entry of an order by
the eu.berland County Domestic Relations Office.
8, The defendant, although entering into this Agreelllent I does not ad. I t
the allegations made In the Petition.
9. Thp. defendant understands that the Protection Order entered in this
matter shall be in effect for a period of one year.
10. The defendant understands that this Order shall be enforceable in the
sae I118nner as the Court's pr ior Temporary Protect ion Order entered in this case.
'MIEREFORE, the part les request that a Protect ion Order be entered to
reflect the above terms.
Kim S.
t~
At torney for
'1./'
PlaintlR
UXlAL SERVICES, INC.
8 Irvine Row
Carlisle, PA 17013
(717) 243-9400
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CANDY S. TAYLOR,
Plaintiff
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
V.
KIM S. TAYLOR,
Defendant
94-6223 CIVIL
CHARGE: INDIRECT CRIMINAL CONTEMPT
ORDER 01" COURT
(IV
AND NOW, this Z~ day of November, 1994 in consideration of
the attached Commonwealth's petition, the defendant, Kim S.
Taylor, is directed to appear before the Court on the ~/~r day of
,Yitt..MJl/uAJ, 1994 at ;: Ju o'clock -j2.m. in Courtroom . ~ of
the Cumberland County Courthouse, Carlisle, Pennsylvania, to show
cause why the defendant should not be adjudicated in indirect
criminal contempt of Court.
Defendant has a right to be represented by an attorney. If
defendant cannot afford an attorney, one will be assigned to
represent the defendant. Further, if defendant fails to appear
an arrest warrant will be issued.
By the Court,
J.
Thoma. A. P1acey, Zlquire
A..i.tant District Attorney
Kim S. Taylor, Defendant
Office of The Public Defender
LUalch
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CANDY S. TAYLOR,
Plaintiff
IN THE COURT OF COMMON PLEAS OP
CUMBERLAND COUNTY, PBNNSYLVANIA
V.
: 94-6223 CIVIL
KIM S. TAYLOR,
Defendant
CHARGE: INDIRECT CRIMINAL CONTEMPT
COMMONWBALTH'S PETITION FOR A HBARING ON CHARGES
OF INDIRECT CRIMINAL CONTEMPT
Thomas A. Placey, Assistant District Attorney of Cumberland
County, Pennsylvania, filefl the following petition for a hearing on
charges of indirect criminal contempt againflt Kim S. Taylor, as
follow. :
1. A Protection From Abuse Order was entered by the Honorable
George E. Hoffer on November 2, 1994. A certified copy of the Court
Order is attached as Exhibit 1.
2. Defendant's violation of this Order is averred in the
attached criminal complaint. Attached as Exhibit 2.
3. The police, upon contact by the victim, ascertained her
immediate safety, and were not able to locate the defendant in the
vicinity.
4. The victim has requeJted the filing of charges on indirect
criminal contempt.
5. The Commonwealth is requesting a hearing on the charge. of
indirect criminal contempt pursuant to 23 Pa.C.S.A. Section 6113.
WHEREfORB, the Commonwealth requests a hearing on the charge of
indirect criminal contempt of the Protection From Abuse Order.
Resp~c~tUt1y~mitted,
hl~. Plaeay
A'si~~n~,District Attorney
....... ..,... ~ .
1. The d.tendant ,. ordered to pay inter'. .upport to the plaint itt 'lor
. the partles' ..Inor children In the lUIIOunt or $23.00 per week payable to the
plaintiff in the form of a check or money order by mail pending the entry of an
order by the CUmberland County Domestic Relations Office.
8. This Order shall remain in effect for a period of one year.
9, The Carlisle and Middlesex Township Police Departlllents shall be
provided with certified copies of this Order by the plaintiff's attorney 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 presence of the police officer, In the event that an arrest
is lIIIde under this sect ion. the defendant shall be taken wi thout 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 P.S.
.
! 6113).
By the Court,
'/.s/~ ~. ~
George E. Hoffer, Judge
.
TRUE COpy F~OM R~CORD
In T..r:;n.',1" ','n 'r::. i :,:., ~"In Izt my hand
and tho Stal y': s;;~ ,'." "1' "'I',le p.
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oJ) fiii-' Prolhono ary
CRIMiNAl COMPLAINT
(POLlCE)
DISTRICT JUSTICE
MAGISTERIAL nlSTRICT NO. 09-2-01
1 Courthouse Square
Carlisle, PA 17013
A 94668
COMMONWEALTH OF PENNSYLVANIA
DEFENDANT: VS.
r
Karen J. Finkenbinder, Badge 28
( Nm"I' of Ainun,'
of Carlisle folice Department
(lJ,ntlb' d~f'4J'tml'nr or aKenn" f1'pftwntt'U 11111/ polllinlllllhJll'I.lio,,)
NAME
AND
ADDRESS
{'J,;,':,,:. ,1\:"11;'
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lC1lI S. TlylM:
651 ,<:oclodo&u:tAnet ~ .
Car11ale,PA . 17013 " .
5/4/59
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AK A
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SOCa
do hereby state:
(I) III I accuse the above named defendant. who lives at t~e address set forth above or,
~ 0 I accuse an iOl!ividual whose name is unknown to me but who is described as
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o his nickname, or popular desi@nat.ion is unknown to me and, therefore, I ha}'c. duignaled him her~in as John
Doe: with v,olatong the penal laws of the Commonwealth of Pennsylvania at 1/4 r;. Hlgh Street
( Pfat'f! . Pulitical SubdlvlJ/tJn)
Carlisle __ in c.lmber!ano County on or about H/l!/~ - H/lJ/':I4 Iran about
Participants were (i{,heft ~'t'ft ptJftidpum.\, pllJa' ,heir 'lilith'\' III'ft', Nlk.'lltil/ll ,111' /111m/! of ahfwl! JdeffJUflt ), U/W hrs to ;L.j,j{) hrs
(2) The acts commiued by the accused were: 0 INDIRECT CRIMINAL <XlNTEMPI'
The defendant violated the Order issued under the Protection Fran Abuse Act in No. 94-6223,
Civil Tern on 2 November 1994 by the Honorable George Hoffer, which Order directed
defendant not to: have any direct or indirect contact with the plaintiff incJ.uding but
not limited to, telephone and written cOlllllUnications, except for the limited purpose of
facilitating custody arrangements. The defendant did deliver or cause to have delivered
a letter written to Candy A. Taylor by the defendant and did on 11/23/94 call her several
times and leave messages on the plaintiff I s answering machine which were vituperate and
caused the plaintiff great distress.
aU ,of ,:"hich were aaainst the peace and dianilY of the Commonwealth of PennsylvarJjil al1.d lO\!n\(ary, to .!tle. ! Ac}~i\se!!!~ly.
or In ViolatIOn of . 10190 . _ and of the Act of JUne :u, ~9'. ~~'~
( Malon) ( Suh .~tffif}" )
or .he <.,'::" Ordinance of
(J)
( Polltil'lll Sufi. Jlyl,~/fln )
I ask that a warrant of arrest or a summons be issued and that the accused
I have made,
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be required to answer the charaes
(4) I verify that the facts set forth in this complaint are true and correct to the best of my knowledae or information
and belief, This verification IS made subject to the penalties or ction 4904 of the ('ri es Code (18 Pa. C. S.
f 4904) relatina to unsworn falsification to authorities,
, 19
AN~ NOW, on this date , 19 _' I certify the complaint has bun properly completed and
venfled. and that there IS probable cauS( for issuance of proc(S~
(,V~:fll"~.'1 bl,~"kl )
(SEAL)
(7U"ittll ,fu(h"",,, J
AOPC4'1.1I!I
EXHIBIT 2
()Rh....d~jAl Sf:f FIE, IJ'FFlf.;r ~';Inf FOH \NAI'IfH ANO ~ (J()rr~()n:o:;
CANDY S. TAYLOR,
plaintiff
IN THE COURT or COMMON PLEAS or
CUMBERLAND COUNTY, PENNSYLVANIA
94-6223 CIVIL TERM
v.
KIM S. TAYLOR,
Defendant
INDIRECT CRIMINAL CONTEMPT
ORDER OF COURT
AND NOW, this 21.t day of December, 1994, the
partie. having appeared before the Court together with their
re.pective counsel, Thomas Placey, Esquire, Di.trict Attorney
for the wife, and William Braught, Esquire, Public Defender
for the hu.band, and both partie. having requested that the
hearing be continued for a period of 90 day., we do .0 continue
this hearing, to be relisted at the request of either .ide.
Should neither side request a hearing within 90
days, we will deem the petition alleging a violation to be
withdrawn and di.missed with prejudice. W. do this at the
request of both partie. in this cas..
By the Court,
Thoma. A. Placey, Esquire
Assistant District Attorney
William G. Braught, Esquire
Assistant Public Defender
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